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HomeMy WebLinkAbout04-0551 TODD E. LEEDOM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04- SSI CIVIL TERM MICHELE E. LEEDOM, Defendant : CIVIL ACTION - CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is TODD E. LEEDOM, an adult individual whose residence is at 10 Stine Avenue, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is MICHELE E. LEEDOM, an adult individual whose residence is at 36 Sub Division Road, Newville, Cumberland County, Pennsylvania. 3. Plaintiff seeks partial custody of his child BRODY TODD LEEDOM, born February 27, 2003, currently residing at 36 Sub Division Road, Newville, Cumberland County Pennsylvania. 4. The child are presently in the custody of Defendant. 5. Since the child's birth, the child has resided at the following addresses: Name Address Dates Parents 10 Stine Avenue, February 27, Carlisle, Pennsylvania 2003 - November 1 , 2003 November 1 , 2003 - Present 6. The relationship of the Plaintiff to the children is that of natural father. 7. The relationship of the Defendant to the children is that of natural mother. 8. The Plaintiff has not participated as a party or in any other capacity, in other litigation concerning the custody of the child in this or any other Court. 9. Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. 10. The best interest and permanent welfare of the child will be served b granting the Plaintiff the following periods of partial custody: MICHELE E. LEEDOM 36 Sub Division Road Newville, Pennsylvania a. Every other weekend from Friday at 5:00 p.m. through Sunday at 7:00 p.m. b. Every Wednesday from 5:00 p.m. until 8:00 p.m. c. One full week during each of the months of June, July and August. d. Alternating holidays from 8:00 a.m. to 7:00 p.m. The holidays shall be New Year's Day, Memorial Day, 4th of July, Labor Day and Thanksgiving Day, with the father having custody on Memorial Day, 2004. e. The parties shall alternate the Christmas holiday. The father shall have custody of the child from 6:00 p.m. Christmas Eve until 3:00 p.m. Christmas Day in odd numbered years and the mother shall have this period in even numbered years. The mother shall have custody of the child from 3:00 p.m. Christmas Day until 6:00 p.m. December 26th in odd numbered years and the father shall have this period in even numbered years. f. Mother shall have physical custody from 8:00 a.m. until 7:00 p.m. on Mother's Day and Father shall have physical custody from 8:00 a.m. until 7:00 p.m. on Father's Day. g. The party receiving custody shall provide transportation from the custodial parent's residence. 11 . Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. No other persons are known to have or claim to have any right to custody 0 visitation of the child other than the parties to this action. WHEREFORE, Plaintiff requests your Honorable Court to refer this case to a Custody Conciliator. ~ (~kf D:Je uire VERIFICATION I verify that the statements made in the foregoing Custody Complaint are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. S4904 relating to unsworn falsification to authorities. -3 lilJ :/ If)() 'I Date 7cW!:U~ rOOD E. L~EDOM iV t ~ 0 ....., c:~ ~-" 0 ,:::=> ~ ~ < ~- .Tl .,.., --i r<i ..,- , cr;J i'i':!:! , - ~ 0- I -om ::DO -l: \.0 0' d D' .___.,0 ~ :t;.... "'r::-ri :I.: b:!J -....0 .7(-) r c: ~". rn -J :;;: <..) ,-1 - p: _._J ? .' w ~ ~] \;0 -< 1- Ii TODD E. LEEDOM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-551 CIVIL TERM MICHELE E. LEEDOM, Defendant : CIVIL ACTION - LAW : IN DIVOF1CE AFFIDAVIT OF SERVICE - HEREBY CERTIFY THAT I served a trul3 and correct copy of the Divorce Complaint filed in the above captioned case upon Michele, by certified mail, return receipt requested on February 9, 2004 addressed to: Michele E. Leedom 36 Sub Divison ROcld Newville, PA 17241 and did thereafter receive same as evidenced by the attached Post Office receipt card dated February 11, 2003. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF, I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. TURO LAW OFFICES d./;3 Io/j Date rXJ9/oL/ nJI/t'Yv<", Cot i ~~~?';.~;m' 1 oodlo'.2 fo, 'd,";onel..";,,,. , g,omplete itecns 3, 4a, and 4b. a I'trnt your name and address Of'l the reverse of this form so thai we can return this card to you. o Attach this form to the front of the maiJpiece, or on the back if space does nol !! permit. :t: C Write "Ratum Receipt Requested' on the mailpiece below the article number. c lJ The Return Receipt will show 10 whom the article was delivered and the date o delivered. , ~~:~~:sst~QedaYl !k ~ b 0\11 "':':::oJ M ~lA.M\\Q \ 9A- llJLj } I J! 4a. Article' Number 1 J j r ! II ~ .~ . ~ 1 4b. Service Type o Registe!red DE'!llJ:OS!rIifai, ~tum Receipt for Merchandise ~d o Insured DeOD 7. Date of Delivery 8. AddressE~IS Address (Only if requeSfecl and fee is paid) 102595-H9-B-0223 DomeSiic Return Receipt o c: s: -oCCl ~gj Z. (n~ ,-, c:;:;:> c:? ....1 rn GO -J -< "]:>> :1C " ih?l ~39 (?IQ, ~r ",' ;:5 '--) ",'<:.""n ~-{ C:^? ['..> -J ~ ., .,.;:. -<'" TODD E, LEEDOM PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA V, 04-551 CIVIL ACTION LAW MICHELE E, LEEDOM DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, ~onday,February23,2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline~. Verney, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, ~arch 16,2004 at 9:30 AM for a Pre-Hearing Custody Conference, At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference, Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearin~. FOR THE COURT, By: Isl Jacqueline M. Verney. Esq. Custody Conciliator (/ ~ The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990, For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office, All arrangements must be made at least 72 hours prior to any hearing or business before the court, You must attend the scheduled conference or hearing, YOU SHOULD TAKE TI-llS PAPER TO YOUR ATTORNEY AT ONCE, IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~~fp~~~ ,J:k ~~?Ih ~r~~~7.n hrJ FL'.e niJ he. e It(l,~r[' V,i\~"-ii\~ll, (;\;1, i -; .J }J ~\rnri"~':' , .( '--' ~j \-:'~~, ".... .",.... :;,:::) 28 :2 !!d ;12 8::J:l ~ooz ,l V,,'l (-'~" :i"\lll r"~1 I j .. r\w'(""-u,i\,)f'.J.\.)C( .~L'l ..1"'''1 ?:~:::J:1G-lJ~rf!.:ll ..- .A.. MAR 1 6 2004 i (] TODD E. LEEDOM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2004-551 CIVIL TERM : CIVIL ACTION - LAW MICHELE E. LEEDOM, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this ~ day of vV1 '?.J C l , 2004, upon consideration ofthe attached Custody Conciliation Report, it is ordered and directed as follows: I. The Father, Todd E, Leedom, and the Mother, Michele E. Leedom, shall have shared legal custody of Brody Todd Leedom, born February 27, 2003. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding his health, education and religion, 2, Mother shall have primary physical custody of the child, 3, Father shall have the following periods of partial physical custody: A. Beginning March 16, 2004, three consecutive hours every week on Father's day off from work, said day and times as agreed by the parties, B. Beginning June 16,2004, eight consecutive hours every week on Father's day off from work, said day and times as agreed by the parties. C, Beginning August 16,2004, one overnight every week on Father's day off from work, said day and time as agre<:d by the parties, D. Beginning September 16, 2004 every oth~r week, two overnights to coincide with Father's days offfrom work, said days and times as agreed by the parties, E, Such other times as the parties agree, 4, The following holidays shall be shared as agreed by the parties from 9:00 a.m, to 3:00 p,m, and 3:00 p,m, to 9:00 p,m.: Memorial Day, July 4th, Labor Day, Thanksgiving Day, New Year's Day. 5, Christmas shall be divided into two Blocks. Block A shall be from 6:00 p,m, Christmas Eve to 3:00 p,m, Christmas Day, Block B shall be from 3:00 p,m, Christmas Day to 6:00 p,m. December 26. Mother shall have Block A in even numbered >- Cl ~ er- e') <e oN z I-' U_,Q ,:,J..:t:' (.)/- :E: (:)0:'7 n:Q a... o~' 'L. -'- L~::::::i ~5 \t:l -;-""'>- 0: N ..,:('cn wO- ,.1:;? -ILU ~ .1.;2: I:C~ ..or: '~:.,..LU x: ~.o (1- --'T' ~ }5 = ::> = 0 ..... years and Block B in odd numbered years, Father shall have Block A in odd numbered years and Block B in even numbered years. 6. Mother shall have physical eustody of the child on Mother's Day from 8:00 a.m, to 7:00 p.m. Father shall have physical custody of the child on Father's Day from 8:00 a.m. to 7:00 p,m. 7, Neither party will consume alcohol or use illegal drugs immediately prior to or during their period of physical custody, 8, he child, Transportation shall be shared such that the receiving party shall transport 9. Neither party shall do or permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. 10, The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COlRT, U{? c~bert], Mulderig, Esquire, Counsel for Father vMarcus A, McKnight, III, Esquire, Counsel for Mother a3- ~~-O~ TODD E. LEEDOM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2004-551 CIVIL TERM : CIVIL ACTION -LAW MICHELE E. LEEDOM, Defendant : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915,3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Brody Todd Leedom February 27, 2003 Mother 2, A Conciliation Conference was held in this matter on March 16, 2004, Father, Todd E, Leedom, was present with his counsel, Robert J. Mulderig, Esquire, and Mother, Michele E, Leedom, was present with her counsel, Marcus A. McKnight, III, Esquire. 3, The parties agreed to the entry of an Order in the form as attached, 3 -I & -0'-/ Date CLd fl~ 9h ~ ~L Verney, Esquire Custody Conciliator II TODD E, LEEDOM, Plaintiff : IN THE COURT 0 COMMON PLEAS OF : CUMBERLAND C UNTY, PENNSYLVANIA v, : NO, 04-551 IVIL TERM MICHELE E, LEEDOM, Defendant : CIVIL ACTION - L W : IN DIVORCE AFFIDAVIT OF CONSENT 1, A Complaint in Divorce under ~3301 (c) of the ivorce dode was filed on February 9, 2004, 2, The marriage of Plaintiff and Defendant is irretri vably broken and ninety (90) days have elapsed from the date of the filing of the Camp aint. 3, I consent to the entry of the final Decree in Diva ce after service of Notice of Intention to request entry of the decree, I VERIFY THAT THE STATEMENTS MADE IN THE OREGdlNG AFFIDAVIT ARE TRUE AND CORRECT, I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa,C, . 94904, RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES, 5-=- 7-oLj Date ' T ~ ~ ~ -;P \ .-\ --- {~\ .-\ "5"~ i:\~E ....(1 \'\~ -'~1q i,,),() ..;:)~ :\\ \}:~ 0" .-.\ '..'-<r ,~) ":4. -;'::'" *'~ q <.f\ cP v- TODD E. LEEDOM, Plaintiff : IN THE COURT OF CO MON fLEAS OF : CUMBERLAND COUNT PENNSYLVANIA v. CIVIL ACTION LAW 2004-551 CIVIL ERM MICHELLE E. LEEDOM, Defendant IN DlVORC DEFENDANT'S AFFIDAVIT OF CONSEN 1. A Complaint in Divorce under Section 3301(c) of the Divoree Code was filed on February 9, 2004, 2, The marriage of plaintiff and defendant is irretrievably broken d ninety days have elapsed from the date of the filing of the complaint. 3, I consent to the entry of a final decree in divoree. 4, I understand that I may lose rights concerning alimony, division f property, lawyer's fees or expenses if I do not claim them before a divoree is granted, I veritY that the statements made in this affidavit are true and corree I underntand that false statements herein made are subject to the penalties of 18 Pa, C, S. Secti n 4904 relating to unsworn falsification to authorities, Date: ./ / // ,2005 ( MICHELLE E. LEE OM \C-~, ,_."" ~:-;~ ,-, :'\l '- .- ....,..-:' ~:: ~, II v, : IN THE COURT OF1 COMMON PLEAS OF : CUMBERLAND CO~NTY, PENNSYLVANIA : NO, 04-551 11VIL TERM : CIVIL ACTION - LA : IN DIVORCE TODD E. LEEDOM, Plaintiff MICHELE E, LEEDOM, I Defendant WAIVER OF INTENTION TO REQ EST ENTRY OF A DIVORCE DECREE U DER 3301 c OF THE DIVORCE CO E 1, I consent to the entry of a final Decree of Divorce without notice, 2, I understand that I may lose rights concern ng alirnbny, division of property, lawyer's fees or expenses if I do not claim thern befo a divorce is granted, 3, I understand that I will not be divorced until a Div rce Decree is entered by the Court and that a copy of the decree will be sent to rne i mediately after it is filed with the Prothonotary, I VERIFY THAT THE STATEMENTS MADE IN THE F REGOING AFFIDAVIT ARE TRUE AND CORRECT, I UNDERSTAND THAT FALSE TATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa,C,S S4904RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES, s= 1-0'/ Date . ~, -~ ~ cJ' """ :....c.1 ?.J I -' --- ?;-;:. ~~ 9 ~ s!~ p....'(;. -(J~)! -uc;- ;~:\~~l ~'~:;~~~\ ~.:!t -'c.'- ::0 ..c t.n (J. - TODD E. LEEDOM, Plaintiff : IN THE COURT OF CO 2004-551 CIVIL : CUMBERLAND COUNT PENNSYLVANIA v. CIVIL ACTION MICHELLE E. LEEDOM, Defendant IN DIVORC WAIVER OF NOTICE OF INTENTION TO RE UE T ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I, I consent to the entry of a final Decree of Divorce without notice, 2, I understand that I may lose rights concerning alimony, division f property, lawyer's fees or expenses if I do not claim them before a divoree is granted, 3, I understand that I will not be divorced until a divoree deeree is and that a copy of the decree will be sent to me immediately after i Prothonotary, tered by the Court is filed with the I verify that the statements made in this affidavit are true and correct I undt.-'I'Stand that false statements herein made are subject to the penalties of 18 Pa, C.S, Secti n 4904 relating to unsworn falsifieation to authorities, Date: c--/, / ,2005 c__ '-, 'J '?'~ E. LEE OM ,----- ," >-' c-:-.:> c;.:' <;;..J-t (- "..... ~.J -- :-~: {";-.) C) ~'....;.' - TODD E. LEEDOM. Plaintiff : IN THE COURT OF CO MON PLEAS OF MICHELLE E. LEEDOM, Defendant IN DIVORC : CUMBERLAND COUNT ,PENNSYLVANIA v. CIVIL ACTION 2004-551 CIVIL ERM DEFENDANT'S MARRIAGE COUNSELING AFF DAVIT The defendant, being duly sworn aeeording to law, deposes and says: I, I have been advised of the availability of marriage counseling a d understand that I may request that the eourt require that my spouse and I participate in eounsel ng, 2, I understand that the court maintains a list of marriage counselors n the Prothonotary's Office, which list is available to me upon request. 3, Being so advised, I do not request that the court require tha my spouse and I participate in eounseling prior to a divorce decree being handed down, I verify that the statements made in this affidavit are true and correc, I understand that false statements herein made are subject to the penalties of 18 Pa, C.S, Sect' n 4904 relating to unsworn falsification to authorities, Date: / /. /' //'/ ,2005 C/,?,;;:>:'? d"~ c.>~- MICHELLE E.-LE ,~ ~) ~:,:; ....r-o -n'" ~,"\ .........-.-----.-.-.-... f t-.. ~h ,-' 1.:4"', ;'_l~:,~~~ >, , -:': (-::,; N II , TODD E, LEEDOM, Plaintiff : IN THE COURT 0 COMMON PLEAS OF : CUMBERLAND C UNTY, PENNSYLVANIA MICHELE E. LEEDOM, Defendant : CIVIL ACTION - : IN DIVORCE IVIL TERM v, : NO, 04-551 PRAECIPE TO TRANSMIT REC RD TO THE PROTHONOTARY: Transmit the record, together with the following inform tion to the court for entry of a Divorce Decree: 1, Ground for divorce: irretrievable breakdown der 9 (3301(c)) of the Divorce Code, 2, Date and manner of service of the complaint: C rtified, Returned Receipt mail delivered on or about February 11, 2004, 3. Date of execution of the Affidavit of Consent re uired by 93301(c) of the Divorce Code: By Plaintiff: May 9, 2004 By Defe dant: Ajlril1, 2005 4, Related claims pending: None, Date the Waiver of Notice in 93301 (c) divo ce was! filed with the Prothonotary: By Plaintiff: April 7, 2005 By Defe dant: April 1, 2005 'i)1Jo, 1h~ Michael M, Jero ins i, Esquire Attorney for Plai tiff Supreme Court 1.0, No, 92977 Turo Law Office 28 South Pitt Str et Carlisle, PA 170 3 Date Q ....., c::> = c.n :t'" -0 :;0 I -J o -., -:! :L ." rnj= IT1 :-gQ ~)6 }~~ ~~i;n ',> :'J.;! -<.. ~~ '2 U1 .0 ~--"'" !I TODD E. LEEDOM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO, 04-551 CIVIL TERM MICHELE E, LEEDOM, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1, A Complaint in Divorce under 93301 (c) of the Divorce Code was filed on February 9, 2004, 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3, I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree, I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT, I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa,C,S, 94904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES, i,I-;;ZI- oS- Date ~ ~--~ TOOO E. LEEDOM ?:5 o.~ ...."rl (.:J .oll :~3 i I ~ f"<~ -:::) -'0' II TODD E. LEEDOM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO, 04-551 CIVIL TERM MICHELE E. LEEDOM, Defendant : CIVIL ACTION -LAW : IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301 (g OF THE DIVORCE CODE 1, I consent to the entry of a final Decree of Divorce without notice, 2, I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted, 3, I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary, I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT, I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa,C,S, 34904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES, 'I-JI-tJ') Date ~.# /~ /TODD E. LEEDOM . ......--- "", ?:s q. c;.;l <.:_.1\ -I'-.~ ~':<'} - , /~ ~,') -"' C'') - - II TODD E. LEEDOM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO. 04-551 CIVIL TERM MICHELE E. LEEDOM, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the court for entry of a Divorce Decree: 1, Ground for divorce: irretrievable breakdown under ~ (3301(c)) of the Divorce Code, 2, Date and manner of service of the complaint: Certified, Returned Receipt mail delivered on or about February 11, 2004, 3, Date of execution of the Affidavit of Consent required by ~3301(c) of the Divorce Code: By Plaintiff: April 21, 2005 By Defendant: April 1 , 2005 4, Related claims pending: None, Date the Waiver of Notice in ~3301(c) divorce was filed with the Prothonotary: By Plaintiff: April 21, 2005 By Defendant: April 1 , 2005 Date Y hi) 0 S I , ~IIM, ~- Michael M, Jerominski, Esquire Attorney for Plaintiff Supreme Court /.0, No. 92977 Turo Law Offices 28 South Pitt Street Carlisle, PA 17013 f"-) c:;:'> C,') ;~; -n >_.J ~", '" ~ C) .!,.:~ -.-----........-.-.""..- TODD E, LEEDOM, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW MICHELE E. LEEDOM, Defendant NO, 04-0551 CIVIL TERM ORDER OF COURT AND NOW, this 15th day of April, 2005, upon consideration of Plaintiff's Praecipe To Transmit Record, and it appearing that Plaintiff's affidavit of consent was filed more than 30 days after its execution and is thus stale, a divorce decree will not be entered at this time, without prejudice to the parties' rights to correct the deficiency and file a new praecipe to transmit record, BY THE COURT, ,.-MiChael M, Jerominski, Esq, TUfo Law Offices 28 South Pitt Street Carlisle, PA 17013 Attorney for Plaintiff v1<1ichele E. Leedom 36 Sub Division Road Newville, PA 17241 .-.\ ..,Marcus A, McKnight, III, Esq, 60 West Pomfret Street Carlisle, P A 17013 :rc f~() .') ;\.! ".,1 Cd UdV SDOZ :10 ~- . . . . . . . +. . +. . . +. . +. +. . +. . . . . . . . . . . . . . . . . . . . . . <+. . <~ . +. . . . . . . . . . . . . . ;+:~:4':4' . .. :l;;+:;+::+: ... ;+::t:",;t'+.:f'f+++++'t;;+;:+. + +:+::+: +:+.:+. 'f.+ + '+:+.:+:'++'I'+'f.+;+;+:+:++'++ ++:f++<f . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA, Todd E. Leedom No, 04-551 VERSUS Mi(""h~l~ R r.",edOlll DECREE IN DIVORCE AND NOW, \'\'f' 2005 , IT IS ORDERED AND 'Z....l DECREED THAT Todd E. Leedom , PLAINTIFF, AND Michele E. , DEFENDANT, Leedom . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ARE DIVORCED FROM THE BONDS OF MATRIMONY, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None BY THE COURT: . . . . . . . . . ++ '+ '+' +:i:'+++++++++ 'f. :+:i';to +. . . . ++++++:+.++ ... ++o+.++:+:;+::+:'l'++ -I'1':+. Of +:+. "" . ++++'1'+.++++'+++ ;to:!'+"":+' . H. +. +. . +. +. . . . . . . . . . . . . . . . . . . . +. . . . . +. . . . . +. . +. . +. +. . . . . . . +. . +. . +. . . . . +. . . . . . . . +. . +. . . . . . . . . J, . . . . +. . +. +. . . +. +. . . +. . . . +. +. +. . ~J))1/ JP ,2 ~~ ",..;tl, _so [t J .~~ fp? 1-. T-->:n->l WIi;J -P?'? 5rJ' f~ )- ,. "