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HomeMy WebLinkAbout09-4363 CHARLES D. LEEDS, Plaintiff V. MELISSA A. LEEDS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERTLAND COUNTY, PENNSYLVANIA N 0. o s -y3 6 3 S-2000 CIVIL ACTION-LAW IN DIVORCE 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 of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property of 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 counseling. A list of marriage counselors is available at the Office of the Prothonotary at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEED OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GTRANTED, 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 32 S. Bedford Street Carlisle, PA 17013 JOANNE MARINO MC GREEVY ATTORNEY FOR PLAINTIFF .4P CHARLES D. LEEDS: Plaintiff V. MELISSA A. LEEDS, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ©9- 5/3 63 1-2009 CIVIL ACTION-LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW COMES the above-named Plaintiff, by Joanne Marino McGreevy, Esquire, and seeks to obtain a Divorce from the above-named Defendant upon the grounds hereinafter set forth: 1. Plaintiff, CHARLES D. LEEDS, is an adult individual who is sui juris and resides at 2211 Pine Road, Newville, PA 17241. 2. Defendant MELISSA A. LEEDS, is an adult individual who is sui juris and resides at 227 Plaza Drive, Boiling Springs, PA 17007. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. To the knowledge of the Plaintiff, the Defendant has been a bona fide resident in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 5. The Plaintiff and Defendant were married December 14, 2002, in Carlisle, Cumberland County, Pennsylvania. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Plaintiff has been advised of the availability of counseling and the right to request that the court require the parties to participate in counseling. 8. The Defendant is not currently a member of the armed services of the United States or any of its allies. COUNT I. REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 9. The Plaintiff avers that the ground on which the action is based is that the marriage is irretrievably broken. y 10. After ninety (90) days from the date of the filing of this complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. WHEREFORE, IF BOTH PARTIES FILE AFFIDAVITS CONSENTING TO A DIVORCE AFTER NINETY (90) DAYS HAVE ELAPSED FROM THE FILING OF THIS COMPLAINT, PLAINTIFF RESPECTFULLY REQUESTS THE COURT TO ENTER A DECREE OF DIVORCE PURSUANT TO SECTION 3301(c) OF THE DIVORCE CODE. -?? DATE l tfRAXI&ES D. EDS PLAINTIFF JOANNE MARINO MCGREEVY ATTORNEY FOR THE PLAINTIFF 137 S. West Street Carlisle, Pennsylvania 17013 717-243-0092 S.Ct. #47612 CHARLES A. LEEDS, Plaintiff V. MELISSA A. LEEDS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :NO S-2009 CIVIL ACTION-LAW IN DIVORCE VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.§ 4904, relating to unsworn falsification to authorities. DATE G PLAINTIFF CA rl OF ` 'UOiAW '41 JVW 29 Ph 12.0 1 4 3 3 ?, s-o p d- J-1 FAT s ??? Tky 1/6 -115 Rya-?`? 33? CHARLES D. LEEDS, Plaintiff V. MELISSA A. LEEDS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :NO. O -y343 52009 CIVIL ACTION-LAW IN DIVORCE ENTRY OF APPEARANCE To the Prothonotary: Please enter my appearance as attorney of record for CHARLES D. LEEDS, Plaintiff, in the above-captioned matter. I may be served as follows: Joanne Marino McGreevy Attorney at Law 137 S. West Street Carlisle, PA 17013 717-243-0092 My Supreme Court I.D. # is 47612. A- Joanne Marino McGreevy 9_44? Sincerely, -OFFiCE OF RZTME 29 JUN 29 P1412: 0 I R"kw4 Y .I?9