HomeMy WebLinkAbout04-2315
Plaintiff
: IN THE COURT OF COMMON PLEAS
; CUMBERLAND COUNTY, PENNSYL VANIA
~ No. 0'1- .z3/,,)/ CivilTerm
GARYR. LEACH,
vs.
TRICIA R. LEACH,
: ACTION 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 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 or other rights important to you,
including custody or visitation of your children.
Where 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 at the
Office of the Prothonotary, Cumberland County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER 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 South Bedford St.
Carlisle, Pa. 17013
(717) 249-3166
GARY R. LEACH,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 0 '-I ~ "z:J IS
Civil Term
vs.
TRICIA R. LEACH,
ACTION IN DIVORCE
Defendant
COMPLAINT IN DIVORCE
1. Plaintiff is Gary R. Leach, a competent adult individual, who has resided at 67 E.
North Street, Carlisle, Cumberland County, Pennsylvania, since 1994.
2. Defendant is Tricia R. Leach, a competent adult individual, who has resided at 266 S.
Hanover St., Apt 4, Carlisle, Cumberland County, Pennsylvania, since November 2002.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at
least 6 months immediately previous to the filing of this Complaint.
4. The Plaintiff and the Defendant were married on June I, 1985 in Carlisle, Cumberland
County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. Plaintiff has been advised that counseling is available and that plaintiff may have the
right to request that the court require the parties to participate in counseling.
7. Plaintiff and Defendant have three children together, namely, Stephanie Elizabeth
Leach, date of birth, November 24, 1985, Joseph Stuart Leach, date of birth, June 23, 1988, and
Daniel Robert Leach, date of birth, January 19, 1990.
8. Plaintiff and Defendant are both citizens of the United States of America.
9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States
of any of its allies.
10. The Plaintiff avers that the grounds on which this action is based are: That the
marriage is irretrievably broken.
WHEREFORE, Plaintiff requests the court to enter a decree in divorce.
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. 94904 relating to unsworn
falsification to authorities.
ch -f( 1
Gary ~, Plaintiff
Respectfully submitted,
Dme r /401
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Adams, Esquire
. No. 79465
South Pitt Street
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
GARY R. LEACH,
vs.
: No.
04 - 2315 Civil Term
TRICIA R. LEACH,
: ACTION IN DIVORCE
Defendant
AMENDED AFFIDAVIT OF SERVICE
AND NOW, this June 4, 2004, I, Jane Adams, Esquire, hereby certifY that
on or about May 29, 2004, a certified true copy of the NOTICE TO DEFEND AND
COMPLAINT IN DIVORCE were served, to the Defendant, via certified mail, restricted delivery
return receipt requested, at:
Tricia R. Leach
266 S. Hanover St.
Carlisle, Pa. 17013-3904
DEFENDANT
1
J.D. o. 79465
36 outh Pitt Street
arlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
GARY R. LEACH,
'IS.
No.
04 - 2315
Civil Term
TRICIA R. LEACH,
ACTION IN DIVORCE
Defendant
MARRIAGE SETTLEMENT AGREEMENT
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THIS AGREEMENT, made this 6>-g day of (21~~ ,2005, by and
between, Gary R. Leach, of Carlisle, Cumberland County, Pen~ylvania, herb4n\fter referred to
as "Husband", and Tricia Leach, hereinafter referred to as "\Vife";
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on June 1, 1985, in Carlisle,
Pennsylvania, and;
WHEREAS, there were three children born ofthis marriage;
WHEREAS, differences, disputes, and difficulties have arisen between the parties and it
is the intention of Husband and Wife to live separate and apart for the rest of their natural lives,
and the parties desire to settle their respective financial property rights and obligations as
between each other, including the settling of all matters betwl~en them relating to ownership and
equitable distribution of real and personal property; the settling of all matters between them
relating to the past, present, and future support, alimony, and/or maintenance of Husband or
Wife; and in general, the settling of any and all possible claims by one against the other or
against their respective estates;
NOW THEREFORE, Wife and Husband, each intending to be legally bound, hereby
covenant and agree as follows:
1. FULL DISCLOSURE OF ASSETS. Each party warrants that he or she has made a
full and fair disclosure of income, assets, and their valuation prior to the execution of this
Agreement as well as any other fact relating in any way to tht~ subject matter of this agreement.
These disclosures are part of the consideration made by each party for entering into this
agreement.
2. ADVICE OF COUNSEL. The Husband has employed and had the benefit or counsel
of Jane Adams, Esquire, as his attorney. Wife is Pro Se. Each party has carefully and
completely read this agreement and has been advised and is completely aware not only of its
contents but of its legal effect. Wife has been advised of her right to counsel, voluntarily elected
to forego representation, and understands that Jane Adams, Esquire is only representing
Husband.
3. SEP ARA TION. The parties intend to maintain separate and pennanent domiciles
and to live apart from each other. It is the intention and purpose of this agreement to set forth
their respective rights and duties while they continue to live apart from each other. Neither party
shall harass, annoy, injure, threaten, or interfere with the other party in any manner whatsoever.
4. SUBSEQUENT DIVORCE. The parties hereby acknowledge that Husband has filed
a Complaint in Cumberland County, Pennsylvania, claiming that the marriage is irretrievably
broken under the no-fault mutual consent provision of Section 3301(c) of the Pennsylvania
Divorce Code. Wife hereby expresses her agreement that the marriage is irretrievably broken
and expresses her intent to execute any and all affidavits or other documents necessary for the
parties to obtain an absolute divorce pursuant to Section 3301((:) of the Divorce Code. The
parties hereby waive all rights to request Court Ordered counseling under the Divorce Code. The
provisions of this Agreement relating to equitable distribution of property of the parties are
accepted by each party as a final settlement for all purposes whatsoever, as contemplated by the
Pennsylvania Divorce Code.
Should a decree, judgment, or order of separation or divorce be obtained by either of the
parties in this or any other state, country or jurisdiction, each of the parties hereby consents and
agrees that this Agreement and all of its covenants shall not be affected in any way by any such
separation or divorce; and that nothing in any such decree, judgment, order, or further
modification or revision thereof shall alter, amend, or vary any tenn of this Agreement, whether
or not either or both of the parties shall remarry. It is specifically agreed that a copy ofthis
Agreement or the substance of the provisions thereof, may be incorporated by reference into any
divorce, judgment, or decree. This incorporation shall not be regarded as a merger, it being the
specific intent of the parties to pennit this Agreement to survive any judgment and to be forever
binding and conclusive upon the parties.
5. DATE OF EXECUTION. The "date of execution" or "execution date" of this
agreement shall be defined as the date upon which it is executed by the parties if they have each
executed the Agreement on the same date. Otherwise, the "date of execution" or "execution
date" of this Agreement shall be defined as the date of execution by the party last executing this
Agreement. All provisions ofthis agreement shall be effectuatl~d by the parties within thirty
(30) days ofthe execution date ofthis agreement unless otherwise specified within this
agreement.
6. MUTUAL RELEASE OF ALL CLAIMS. HUSBAND and WIFE each do hereby
mutually remise; release, quit-claim and forever discharge the other and the estate ofthe other, of
and from any and all rights; titles, and interests, or claims in or against the property (including
income and gain from property hereafter accruing) of the other or against the estate of such other,
or whatever nature and wheresoever situate, which she or he now has or at any time hereafter
may have against such other, the estate of such other or any part thereof, whether arising out of
any former acts, contracts, engagements, or liabilities of such other or by way of dower or
curtesy, or claims in the nature of dower or curtesy of widow's or widower's rights, family
exemption or similar allowance, or under the intestate laws, or the right to take against the
spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other
rights of a surviving spouse to participate in the decease spouse's estate, whether arising under
the laws of Pennsylvania, any state, commonwealth, or territory of the United States, or any other
country, or any rights which Wife may have or at any time hereafter have against the other for
past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees,
costs, expenses, or equitable distribution of marital property whether arising as a result of any
marital relation or otherwise, except, and only except, all rights and agreements and obligations
of whatsoever nature arising or which may arise under this agreement or for the breach of any
thereof.
7. WARRANTY OF DEBTS AND FUTURE OBLIGATIONS. Each party warrants
that they have not contracted any debt or liability for the other or which the estate of the other
party may be responsible or liable, and except only for the rights arising out of this agreement,
neither party will hereafter incur any liability whatsoever for which the other party or the estate
of the other party, will be liable. Each party agrees to indemnify or hold harmless from the other
and against all future obligations of every kind incurred by them, :mcluding those for necessities.
8. EQUITABLE DIVISION OF MARITAL PROPERTY. The parties have
attempted to distribute their marital property in a manner which conforms to the criteria set forth
in 23 Pa.C.S.A. s3501 et. seq. and taking into account the following considerations: the length of
the marriage, the age, health, station, amount, and sources of income, vocational skills,
employability, estate, liabilities, and needs of each of the parties, the contribution of each party to
the education, training, or increased earning power of the other party; the opportunity for each
party for future acquisitions of capital assets and income; the sources of income of both parties,
including but not limited to medical, retirement, insurance or other benefits; the contribution or
dissipation of each party in the acquisition, preservation, depreciation, or appreciation of the
marital property, including the contribution of each spouse as a homemaker; the value of the
property set apart to each party; the standard of living the parties established during the marriage;
and the economic circumstances of each party at the time the division of property is to become
effective.
The division of existing marital property is not intended by the parties to constitute in any
way a sale or exchange of assets, and the division is being effected without the introduction of
outside funds or other property not constituting marital property. The division of property under
this Agreement shall be in full satisfaction of all the marital rights of the parties.
9. OTHER PERSONAL PROPERTY. Husband and Wife do hereby acknowledge that
they have previously divided all their tangible personal property. Except as may otherwise be
provided in this Agreement, Wife agrees that all of the property of Husband or in his possession
shall be the sole and separate property of Husband; and Husbfmd agrees that all of the property
of Wife or in her possession shall be the sole and separate property of Wife. The parties do
hereby specifically waive, release, renounce, and forever abandon whatever claim, if any, he or
she may have with respect to the above items which shall become the sole and separate property
ofthe other.
10. MOTOR VEHICLES. With respect to the motor vehicles, owned by one or both
ofthe parties, they agree as follows:
(a) The(:)~~~\"'-~\~Q
property of Wife.
(b) The ~1Dl~,\z..
property of Hus, d.
shall be and remain the sole and exclusive
shall be and remain the sole and exclusive
The titles to the said motor vehicles shall be executed by the parties, if appropriate for
effecting transfer as herein provided, within thirty days of the execution date of this Agreement,
and said executed titles shall be delivered to the proper parties on the distribution date. Each
party agrees to be solely responsible for the amounts presently due and owing against his or her
respective automobiles.
11. MUTUAL WAIVER OF EMPLOYMENT BENEFITS. The parties agree to
waive any and all rights they have in and to each other's employment benefits, including but not
limited to both parties pensions and retirement plans and Incentive Savings Plans. The parties
agree never to assume any claim to such benefits of the other at any time in the future.
12. ALIMONY, ALIMONY PENDENTE LITE and LEGAL FEES. Each party
hereby waives any right to spousal support, alimony, or alimony pendente lite, and each party
agrees to be responsible for his or her own legal fees and exp.:nses. The parties herein
acknowledge that by this Agreement, they have respectively secured and maintained a substantial
and adequate fund with which to provide for themselves sufficient financial resources to provide
for their comfort, maintenance, and support in the station oflife to which they are accustomed.
Wife and Husband do hereby waive, release, and give up any rights they may respectively have
against the other for alimony, support, or maintenance. It shall be from the execution of this
Agreement the sole responsibility of each of the respective parties to sustain themselves without
seeking any support from the other party. All alimony to be paid under this agreement shall
terminate upon the recipient's remarriage or cohabitation with a person of the opposite sex.
13. INCOME TAX RETURNS. Husband and wife represent to each other that to the
best of their knowledge all federal, state, and local taxes requirl~d to paid with during the
marriage and during the periods covered by such tax returns have been paid. Husband and Wife
further represent that there are no tax deficiencies proposed or assessed against Husband and/or
Wife for such periods, and neither Husband nor Wife executed any waiver of the Statute of
limitations on the assessment or collection of any tax for such periods. If any deficiency in
federal, state, or local income taxes is proposed, or any assessment of any such tax is made
against the other party by reason of his or her having joined in the filing of joint federal, state or
local income tax returns, Husband and Wife shall indemnify and hold harmless the other against
and from any and all tax, interest, penalty, or expense relating from any such tax deficiency,
including reasonable counsel and accounting fees, and such tax, interest, and penalties or
expenses shall be paid solely and entirely by the responsible party as determined to be
attributable to that party on account of misrepresentation or failure to disclose relevant
information of income on the aforesaid joint returns.
14. WAIVER OR MODIFICATION TO BE IN WRITING. No modification or
waiver of any of the terms hereof shall be valid unless in writing and signed by both parties, and
no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent
default of the same or similar nature.
15. MUTUAL COOPERATION. Each party shall, at any time and from time to time
hereafter, take any and all steps and execute, acknowledge, and deliver to the other party any and
all further instruments and/or documents that the other party may reasonably require for the
purpose of giving full force and effect to the provisions of this Agreement.
16. APPLICABLE LAW. The Agreement shall be construed in accordance with the
laws of the Commonwealth of Pennsylvania which are in effect as of the date of execution of this
Agreement.
17. INTEGRATION. This Agreement constitutes the entire understanding of the
parties and supersedes any and all prior agreements or negotiations between them. There are no
representations or warranties other than those expressly set forth herein.
18. OTHER DOCUMENTATION. Wife and Husband covenant and agree that they
will forthwith execute any and all written instruments, assignments, releases, satisfactions, deeds,
notes, or such other writings as may be necessary or desirable for the proper effectuation of this
Agreement.
19. NO WAIVER OF DEFAULT. This Agreement shall remain in full force and effect
unless and until terminated under and pursuant to the terms of this Agreement. The failure of
either party to insist upon strict performance of any of the provisions of this Agreement shall in
no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any
,
default or breach of any provision hereof by construed as a waiver of any subsequent default or
breach of the same or similar nature, not shall it be construed as a waiver or strict performance of
any other obligations herein.
20. SEVERABILITY. If any term, condition, clause, or provision of this Agreement
shall be determined or declared to be void or invalid in law or otherwise, then only that term,
condition, clause, or provisions shall be stricken from this Agreement; and in all other respects,
this Agreement shall be valid and continue in full force, effect, and operation. Likewise, the
failure of any party to meet his or her obligations under anyone or more of the paragraphs herein,
with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter
the remaining obligations of the parties.
21. BREACH. If either party breaches any provisions of this agreement, the other party
shall have the right, at his or her election, to sue for damages for such breach, or seek other
remedies or relief as may be available to him or her, and the party breaching this contract should
be responsible for payment of legal fees and costs incurred by the other in enforcing their rights
under this agreement.
22. INFORMED AND VOLUNTARY EXECUTION. Each party to this agreement
acknowledges that he or she is fully informed as to the facts relating to the subject matter of this
agreement, is entering into this agreement voluntarily, free from fraud, undue influence, coercion
or duress of any kind, has given careful thought to the making of this agreement, has carefully
read each provision of this agreement, and fully and completely understands each provision of
this agreement.
IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and
year first above written:
WITNESS:
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~MMON~EAL TH OF ~E. NNSYL VANIA )
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OUNTYOFCUMBERLAND~~~ )
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On this, the LO day of GU,V'O.';'\, 2005, be/ure me, the undersigned officer,
personally appeared Gary R. Leach, wn to nkJ( or satisfactorily proven) to be the person
whose name is subscribed to the with' instrument, and acknowledged that he/she executed the
same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
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JH OF PENNSYLVANIA
Notarial Seal
Jane Adams, Notary Poblic
Carlisle 80m, Cumberlan;'; County
My Commission Expires Sept. 6, 2008
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Tricia Leach, Wife
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COMMONWEALTH OF PENNSYLVANIA )
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C\~TY OF CUMBERLAND )
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On this, the L't~ day Of~~~ ,2005, before me, the undersigned officer,
personally appeared Tricia Leach kn~ to e, r satisfactorily proven) to be the person whose
name is subscribed to the within ins ent, acknowledged that he/she executed the same for
the purposes therein contained.
corn~MfflM~ALim~F PENNSYLVANIA
Notarial Seal
JBlle Adams, NotarY Public
c.,fis~, Boro, Cumberland Count)'
My Commission Expires Sept. 6, 2008
SEAL
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Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
GARY R. LEACH,
VS.
No.
04 - 2315
Civil Term
TRICIA R. LEACH,
ACTION IN DIVORCE
Defendant
AFFIDAVIT OF CONSENT
1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on May 21, 2004.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the
date of the filing and service of the Complaint.
3. 1 consent to the entry of a final decree of divorce after service nfnotice of intention to request entry of
the decree.
I verify that the statements made in this affidavit are true and corre"t. I also understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to
authorities.
Date: J - d 8- 0 J
G,"lc:;i!1/~~
WAIVER OF NOTICE OF INTENTION
TO REOUEST ENTRY OF A DIVORCE DECREE
UNDER 63301(0) AND 6330Hdl OF THE DIVORCE CODE
I. I consent to 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 divnrced until a divorce decree is entered by the Court and that a cnpy nf
the decree will be sent to me immediately after it is filed with the Prnthonotary.
I verify that the statements made in this affidavit are true and cnrrect. [understand that false statements
herein are made subject to' the penalties of 18 Pa.C.S. g4904 relating to' unswnrn falsification to' authorities.
Date: J 'eJ goo J-I!~ - -t1 i~ L
~Iaintiff
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Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
GARY R. LEACH,
vs.
No.
04 - 2315
Civil Term
TRICIA R. LEACH,
ACTION IN DIVORCE
Defendant
AFFIDAVIT OF CONSENT
1. A complaint in divorce under section 330](c) ofthe Divorce Code was filed on May 21, 2004.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the
date of the 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.
I verifY that the statements made in this affidavit are true and correct. I also understand that false
statements herein are made subject to the penalties of]8 Pa.C.S. 4904. relating to unsworn falsification to
authorities.
Date:
II;; f~S~
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Tricia R. Leach, Defendant
WAIVER OF NOTICE OF INTENTION
TO REOUEST ENTRY OF A DIVORCE DECREE
UNDER 63301(0) AND 6330Hd) OF THE DIVORCE CODE
I. I consent to 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 this affidavit are true and correct. I understand that false statements
herein are made subject to the penalties of]8 Pa.C.S. ~4904 relating to )1nswom falsificati,9n to authorities.
/ / / . /~ L( . r< . //<,_?,-",,/~
Date: 1;2 S/ {)'5-" ;> / ..(..(/
Tricia R. Leach, Defendant
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Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
GARY R. LEACH,
vs.
: No.
04 - 2315
Civil Term
TRICIA R. LEACH,
: ACTION IN DIVORCE
Defendant
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following infonnation 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 the service of the Complaint: Delivered bv certified mail,
restricted deliverv. return receipt requested on: May 29,2004.
3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code:
By Plaintiff:
January 28,2005.
By Defendant:
January 28, 2005.
4. Related claims pending: None.
5. Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the
Prothonotary: February 4,2005.
Date Plaintiffs Waiver of Notice in S3301(c) Divorce was filed with the
Prothonotary: February 4, 2005.
Date: a I I' O~
spectfullY~/~
Adams, Esquire
. No. 79465
64 S. Pitt Street
Carlisle, Pa. 17013
(717) 245-8508
Attorney for Plaintiff
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+:.i+++++++ +++ +:+++++++++++++++++++++++++++++++++++'f.++++++++?
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
Gary R. Leach, Plaintiff
No. 2004 - 2315 Civil Term
No.
VERSUS
Tricia R. Leach, Defendant
DECREE IN
DIVORCE
AND NOW,
fJV'.ro
c;;r 3. 'f) 8tA.
Jf;/)f , IT IS ORDERED AND
I~
Gary R. Leach
DECREED THAT
, PLAINTIFF,
Tricia R. Leach
AND
, DEFENDANT,
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; The property settlement agreement executed on January 28, 2005, and
Filed February 4, 2005, shall be incorporated but not merged into this Decree.
T:
Am,:~~
PROTHONOTARY
.
J.
.,/r;t ~.~ ~//' 5a (j.e
~' f)p fc f',rr"'""~' /'f' 5" LI e
,- ....
. "
. .
C; OUr:J
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
f tetiJJ, Hliialr//
I
Plaintiff
/J1/~/ff !2
,
Vs
L f 11(' /1, ~llnda<l
Defendant
FileNo.
# DOL! - J,3/:) ell .j'; on
IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff / defendant in the above matter,
[select one by marking "x"]
_ prior to the entry of a Final Decree in Divorce,
or . ~ after the entry of a Final Decree in Divorce dated
hereby elects to resume the prior surname of /.r(, c../ll'oR7"/lP~
RO-l3f RTS
written notice avowing his / her intention pursuant to the provisions of 54 P .S. 704.
Date: .3JgJ()(p ~~.:~ K :I..u.u>../-
Signature
J-fi>-/Ob-
,
, and gives this
~A-<"~ ;J ;J".~t;:;>
Signature of name being resumed
COMMONWEALTHOFPENNSYLVANIA )
COUNTY OF 1:a...k..t._..I)
On the ~ day of 7YiauL , 200 t , before me, the Prothonotary or the
notary public, personally appeared the above affiant known to me to be the person whose
name is subscribed to the within document and acknowledged that he / she executed the
foregoing for the purpose therein contained.
In Witness Whereof, I have hereunto set my hand hereunto set my hand and official
seal.
IIOTAR/AI. SfAI.
PROnlONOTARY. NOTARY PllBlIC
CARIJII.E ClIIIBEIlWO COlINT\' COWITHOllSE
MY COI11181011 EllPUIES .IANlIARY 4, 2010
<.L}~. / >>(0 '}1'
r7 '
Prothonotary or Notary Public
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