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HomeMy WebLinkAbout10-1141 SHANEN K. LESHER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. MICHAEL D. LESHER, Defendant : NO. 10- / 1411 CIVIL TERM 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 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 at CUMBERLAND COUNTY COURTHOUSE CARLISLE PENNSYLVANIA 17013 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: 717-249-3166 WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 r trfl? 3 t , , L 1?: L 1 83 Qtl7Z Wayn6 F. Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 ?- Telephone: 717-243-0220 Attorney for Plaintiff SHANEN K. LESHER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 10- 1 q , CIVIL TERM MICHAEL D. LESHER, : Defendant : IN DIVORCE COMPLAINT DIVORCE 1. Plaintiff in this Action in Divorce is SHANEN K. LESHER, an adult individual who resides at 312 South Broad Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is MICHAEL D. LESHER, an adult individual and citizen of the United States of America who resides at 20 West Market Street, Gratz, Dauphin County, Pennsylvania 17030. 3. Plaintiff has been a bona fide resident of Cumberland County, Pennsylvania, for more than six months previously to the filing of this Complaint and continuing to the commencement of this Action in Divorce. WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 4. Plaintiff and Defendant were lawfully joined in marriage on March 7, 2009, in Gratz, Pennsylvania. 5. The parties have been living separate and apart since September 11, 2009. 6. Plaintiff avers as the grounds on which this action is based that the marriage of the parties is irretrievably broken. In the alternative, Plaintiff avers as the grounds on which this action is based that Defendant has offered such indignities to the person of the Plaintiff, the innocent and injured spouse, as to render the condition of Plaintiff intolerable and the life of Plaintiff burdensome. In the further alternative, Plaintiff avers as the grounds on which this action is based that Defendant has committed willful and malicious desertion, absence from the habitation of the injured and innocent spouse, without reasonable cause, since September 11, 2009. 7. There have been no prior actions for divorce or annulment of this marriage in Pennsylvania or in any other jurisdiction. 8. This Action in Divorce is not collusive. WAYNE F. SHADE Attomey at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 9. Both parties to this Action in Divorce are legally capable of managing their own concerns. 10. Defendant herein is not a member of the armed forces of the United States of America. 11. There was one child born to the parties, namely, Austyn M. Lesher, born September 26, 2009. 12. Plaintiff has no adequate means of support for Plaintiff or the child. 13. 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. WHEREFORE, Plaintiff demands judgment dissolving the marriage between the parties. Wayne . Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 -3- I verify that the statements made in this pleading 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: February 17, 2010 45- L4== Shanen K. Lesher WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 SHANEN K. LESHER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW V. NO. 10- /1J( ( CIVIL TERM MICHAEL D. LESHER, Defendant : IN DIVORCE PRAECIPE TO PROCEED IN FORMA PA UPERIS TO: David D. Buell, Prothonotary Kindly allow Plaintiff SHANEN K. LESHER to proceed in forma pauperis. I, Wayne F. Shade, Esquire, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Date: February 17, 2010 Wayne H -Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 Attorney for Plaintiff N t © T1 T 5 ? 1 ry - ? B n - co 7J _< SHANEN K. LESHER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. NO. 10-1141 CIVIL TERM MICHAEL D. LESHER, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE WAYNE F. SHADE, ESQUIRE, certifies that he is counsel for Plaintiff in the above-captioned matter, that he did, on February 17, 2010, serve the Complaint in Divorce in the above-captioned matter upon Defendant by certified United States mail, postage prepaid, return receipt requested, addressee only, and that the same was received by Defendant on February 18, 2010, as evidenced by the return receipt card attached hereto bearing Certified No. 7001 2510 0006 5861 4264. It is understood that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: February 23, 2010 GC/ Wayn F. Shade 6V . -. .~' C""~ J ~ iJF r-~ - -~-, ; t~ ;~_ ,. -, ,_ , .~. - , WAYNE F. SHADE " ~~ Attorney at Law ~ , % ;-=:; 53 West Pomfret Street _~ __ '--; : Tr Carlisle, Pennsylvania ':::;. f'::' -t 17013 `~ GJ :~ .~ ~ Postage s b 1 ~o ~ Certified Fee 2 , S0 Febr~y 17 ,,D Return Receipt Fee ~[g o (Endorsement Required) 2. 3 0 U 10 ~ Restricted Delivery Fee Q (Endorsement Required) 4 , 5 0 O ,~ Totel Postage & Fees uY ~ Sent To Michael D. Lesher a sheet. Apt. No. 0 o,poaoXNo.20 West Market,._St~:e~~________________ o - ---- •-- -- -------•••••--•------------------•-- ~, City, srare, iiP:; ~.. _ - - - - ^ Complete items 1, 2, and 3. Also complete ftem 4 if Restricted Delivery is desired. ^ Print your name and address on the reverse so that we can return the card to you. ^ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Michael D. Lesher 20 West Market Street Gratz, PA 17030 A. 3lgnature B. Received by err- i ~ ~ i a- D. Is delivery dress different from item 1? ^ Yes H YES, enter delivery address below: ~' No 3. Servk:e Type ~ Certified Mail ^ Express Malt D Registered ^ Return Receipt for Merchandise ^ Insured Mail ^ C.O.D. 2. ArtideNumber rppl 2510 ~0~6 5861, 4264 (rrarwter from se-vrce -abe4 PS Form 3811, Februry 2004 Donteetic Rspam R.oelpc ~aesss~az-rrF,sao IN THE COURT OF COMMON PLEAS OF SHANEN K. LESHER ~ :CUMBERLAND COUNTY, PENNSYLVANIA V. MICHAEL D. LESHER NO 10-1141 CIVIL TERM DIVORCE DECREE AND NOW, V ~tN~ `~~ alb , it is ordered and decreed that SHANEN K. LESHER plaintiff, and MICHAEL D. LESHER ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None By the Court, ~~~~.~~ Co•I~• io ~.~.. iU c~h cam. rc~"~•~ea -~v -+o ~~e.