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Home My WebLink About04-2087 Plaintiff: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO: 01.{ -~7 C."U\l~~ : CIVIL ACTION - LAW JOHN LEO, v. VICKIE C. LEO, : IN DIVORCE Defendant. NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree in divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for another claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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 2 LIBERTY AVENUE Carlisle, PA 17013 (717) 249-3166 Plaintiff; : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO: 04-~0I7 Q;U~t-r~ : CIVIL ACTION - LAW JOHN LEO, v. VICKIE C. LEO, : IN DIVORCE Defendant. COMPI .ATNT IN DIVORCE AND NOW, comes the Plaintiff, John Leo, by and through his attorneys, and files the following Complaint in Divorce: 1. The Plaintiff, John Leo, is an adult individual currently residing at 335 Holly Brook Road, Carlisle, Cumberland County, Pennsylvania, with a mailing address of P.O. Box 734, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant, Vickie C. Leo, is an adult individual currently residing at 345 Hickory Road, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have both been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months prior to the filing of this Complaint. 4. Plaintiff and Defendant are husband and wife having been married on November 24, 1967, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. Neither Plaintiff nor Defendant are members of the Armed Forces of the United States or any of its Allies. 7. Plaintiff has been advised of the availability of counseling and that he has the right to request that the Court require both parties to participate in counseling. 8. The Plaintiff avers as grounds on which this action is based are: A. That the marriage is irretrievably broken pursuant to 93301(c) of the Divorce Code; and B. That as of March 31, 2006, the parties will have lived separate and apart for a period of at least two (2) continuous years pursuant to 9330I(d) of the Divorce Code. WHEREFORE, Plaintiff prays this Court to enter a Decree in Divorce. Respectfully submitted, y; ~ tt, ~Wre I.D. #23 03 2233 Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Plaintiff Date: 5/0/0<; -2- VERI FICA TION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. 1f~~9~DY Date k- o ~ ;0 (j) ~ f- .\t- ~ .... ~ c & ~ -V ~ 6' ?- -.J .(L ~1 y ~ C) ~~ 0 ~..) -rl c_; J,;.- c) C' -..: -r,!, , ~-J ..... f;-i;:~l -~) C) ", -, -.J JOHN A. LEO, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V ANlA Plaintiff, v. : NO. 2004-2087 CIVIL ACTION - LAW VICKI CLEO, IN DIVORCE Defendant. AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 10,2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. DATE:..)'(j -)"- oS- ct, <~! r-.....,) c;::, = ';.:J"l (") -rl I'.) r,) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOHN A. LEO, Plaintiff No. 2004 - 2087 v. CIVIL ACTION - LAW VICKI C. LEO, Defendant (In Divorce) AFFIDAVIT OF CONSENT COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND ) L A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 10,2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of the Notice of Intention to Request Entry of a Divorce Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. e.S., Section 4904 relating to unsworn falsification to authorities. Date: d Sworn to and subscribed before me this .).-~\ day of .. 2005. l- \ r-..C\ \. \ oj Ie",> . \. ...~'^ u._ ',-_\.. 1..._ (U; \ , \.~...) \\ '(j COMMONWEALTH OF PE SYLVANIA Notarial Seal Michelle M. Bross. Notary Public Lower Paxton Twp.. Dauphin County My Commission Expires Sept. 23. 2006 Member, PeMsyfvania Association of Notaries ". ~ r'-' ;L~ ~,,~\ ,:f\ ;:',,) ."'"-"' r""':" JOHN A. LEO, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V ANIit':--, Plaintiff, v. : NO. 2004-2087 : CIVIL ACTION - LAW VICKI C. LEO, : IN DIVORCE Defendant. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330Hc) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of divorce without notice. 2. 1 understand that 1 may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. 1 understand that 1 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. 1 verifY that the statements made in this affidavit are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. " DATE: 5,;-0:::,"- (~. Co, ~~~ <:J1 o -11 ::;5 :"':~i 2~ 1',) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOHN A. LEO, Plaintiff No. 2004 - 2087 v. CIVIL ACTION - LAW VICKI C. LEO, Defendant (In Divorce) WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~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 of property, lawyer's fees or expenses in 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 I further understand 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 this Waiver are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. "'" -tYfj 2, J DIJ5 yJ~C-~ Vicki C. Leo, Defendant . C) ~,~:~ ,::;'_.::> ,':J' > f") ,,) :;'1 :.:;l hl (,"j JOHN A. LEO, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO: 2004-2087 CIVIL VICKI C. LEO, CIVIL ACTION - LAW IN DIVORCE Defendant. CERTIFICATE OF SERVICE I, Debra K. Spinner, Secretary in the law firm of MANCKE, WAGNER and SPREHA, do hereby certify that on this date a copy of the COMPLAINT IN DIVORCE was served upon the following person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing the same in the United States mail, Harrisburg, Pennsylvania, certified, restricted delivery, return receipt requested, and addressed as follows: Ms. Vicki C. Leo 345 Hickory Road Carlisle, PA 17013 By ~' ~ OJ( " VMu.JJ Debra K. Spinn r, Secretary MANCKE, WAGNER & SPREHA 2233 North Front Street Harrisburg, PA 17110 DATE: 05/15/04 P. Richard Wagner, Esquire Attorney for Plaintiff . rn o IJ1 IJ1 o IT' '" I"- U.S. Postal Service", CERTIFIED MA~ECEIPT (Domestic Mail Only; NCi Insurance Coverage Provided) ::r o o Return RecieptFee o (Endorsement Required) Postage Certified Fee Postmark Here o Restricted Delivery Fee I:IJ (Endorsement Required) ...JJ ..-'l Total Postage & Fees rn D Sent To o I"- .. .. . . COMPI ETE THIS SECTION ON DELIVERY . · Compleleps,j".? and 3. Also cOmplete Item 4 n RestrIclea DelIvEHY Is desired. . Print yournBme aiiCI ~ on the reverse so th we can return the card to you. · Allac this card to the back of the mallplece. or on front n space pennils. res:sed to: Ms. Vickie C. Leo 345 Hickory Road Carlisle, PA 17013 B. R I D. Is delivery add""", d_ from Item 11 If VES, enter delIveoy _ below: 2. . ArtIcle Number (/Ian_from -we. PS Fonn 38'11.Augli9t 2001 3.~l)'pe ~M8I1 _~~M8I1 [] ~ ~ ReceIpt for MOIOhandlse [] Insured Man [] C.O.D. 4. RaslrIcted DalIvery? (&trB Fee) Yea 7003 1680 0004 7890 5503 DomEl$tic Return Reoelpt 1 02595-Q2.M- t 540 '_., l ^ J PC ?i =< (~ (": ; , 1 1""-.' ~j~ --, ~i'l :::1 ;~~ ... ~ o Ul JOHN A LEO, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO: 2004-2087 - CIVIL TERM VICKI C. LEO, : CIVIL ACTION - LAW Defendant. : IN DIVORCE PRAECIPE TO TRANSMIT THE RECORD TO THE PROTHONOTARY: TRANSMIT the record, together with the following infonnation, to the Court for entry of a Divorce Decree: I. Ground for divorce: irretrievable breakdown under Section 330 I(c) , 330 I (d) of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the Complaint: May 15,2004, by certified mail, restricted delivery, return receipt requested. 3. (Complete either paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: By Plaintiff: 05/02/05 By Defendant: 05/05/05 (b) (I) Date of Execution of the Plaintiff's Affidavit required Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiff's Affidavit unto the Defendant: 4. Related claims pending: None 5. (Complete ether (a) or (b).) (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit the Record, and attach a copy of said Notice under Section 3301(d) (I)(i) of the Divorce Code: (b) Date Plaintiff's Wavier of Notice was filed with the Prothonotary: 05/16/05 (c) Date Defendant's Waiver ofN . was filed with the Prothonotary: 05/16/05 , Esq. '- Attorney for Plaintiff t"-,' ~ ._) C':';I -"II c.~.J '.:;..I' .---! :~~ h~ C) !'::-' C" UI