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HomeMy WebLinkAbout10-3834 10(f1 Jli~~ (0 Psi f2~ 0 f ~~..~E' `~1%`llllr ~'~~ ~ SHANNON LEGO, IN ~E ~t~7URT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA DAVID LEGO, Defendant CIVIL ACTION -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 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, First Floor, 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 LAWYER REFERRAL SERVICE Court Administrator 4th Floor Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 ~~ ~.~ i~~s~ SHANNON LEGO, Plaintiff v. DAVID LEGO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. .%O_ ° .~~.~~~ CIVIL ACTION -DIVORCE COMPLAINT UNDER SECTION 3301(cl OR 3301(d) OF THE DIVORCE CODE TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW, comes Plaintiff, Shannon Lego, by and through her attorney, Gary L. Kelley, and represents as follows: DIVORCE UNDER SECTION 3301(c) OR 3301(dl OF THE DIVORCE CODE 1. Plaintiff is Shannon Lego who resides at 876 Mandy Drive, Camp Hill, Cumberland County, Pennsylvania 17011 and has resided there in excess of six (6) months. 2. Defendant is David Lego who resides at 876 Mandy Drive, Camp Hill, Cumberland County, Pennsylvania 17011 and has resided there in excess of six (6) months. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 7, 2007 in Harrisburg, Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. ,, • 7. 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. 8. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff requests this Court to enter a divorce decree divorcing the parties from the bonds of matrimony. Respectfully submitted, ry L. Kelley D No. 6801 3117 estnut St t amp Hill, PA 17011 (717) 612-1484 Attorney for Plaintiff t ` 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. Section 4904, relating to unsworn falsification to authorities. Date: 12 At 1 9 n ? SHANNON LEGO, LL Ej IN THE COURT OF COMMON PLEAS 66 Plaintiff l Yf CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2010-3834 DAVID LEGO, CIVIL ACTION - DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was riled on June 10, 2010. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final Decree of Divorce. 4. 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. 5. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling prior to a Decree in Divorce being handed down by the Court. 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: ?l? 4 p C7 fE E+«T k lY`,t 12 All 9: 4 "=,m ;; SHANNON LEGO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. DAVID LEGO, Defendant NO. 2010-3834 CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301 (c) 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 this Affidavit are true and correct. I understand that false statements herein are made subject to the penalti unsworn falsification to authorities. Date: 18 Pa.C.S. Section 4904 relating to ,UMBEFk'Li%ND ?it 'f"Y PENN'SYLVANIA SHANNON LEGO, j/?lN THE COURT OF COMMON PLEAS Plaintiff "I CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2010-3834 DAVID LEGO, CIVIL ACTION - DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301 (c) 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 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: dg(?a, mo I=lL-1)-0F -iCE-- UT, 2010 NOV 12 All 04 OUMBERAID SHANNON LEGO, ?y G IN THE COURT OF COMMON PLEAS Plaintiff II CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2010-3834 DAVID LEGO, CIVIL ACTION - DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 10, 2010. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final Decree of Divorce. 4. 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. 5. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling prior to a Decree in Divorce being handed down by the Court. 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: SHANNON LEGO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2010-3834 DAVID LEGO, CIVIL ACTION - DIVORCE Defendant C: PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: -- ?' Transmit the record, together with the following information, to the Cour? ert o C: Gj cc-) ? n •69.. w,0. f-71 divorce decree: MF = 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the D ivorce Code. 2. Date and manner of service of the Complaint. June 11, 2010 by Certified Mail, Restricted Delivery. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff on November 12, 2010; and by Defendant on November 12, 2010. 4. 5. 2010. 2010. Related claims pending: NONE. Date Plaintiffs Waiver of Notice was filed with the Prothonotary: November 12, Date Defendant's Waiver of Notice was filed with the Prothonotary: November 12, Date: GO LAW OFFICES OF GARY L. KELLEY Gary . K Alley ID No. O1 3117 Chestnut Street Camp Hill, PA 17011 (717) 612-1484 Attorney for Plaintiff FILED-OFFICE i o THE PRDTHONO-j?jpv 2010 DEC 17 AM 10: 03 CUMBERLAND COUNTY PENNSYLVANIA SHANNON LEGO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2010-3834 DAVID LEGO, CIVIL ACTION - DIVORCE Defendant CERTIFICATE OF SERVICE I, GARY L. KELLEY, Esquire, attorney for PLAINTIFF in the above-captioned matter, do hereby certify that on June 11, 2010, I served a true and correct copy of PLAINTIFF'S Complaint In Divorce upon the DEFENDANT by First Class U.S. Certified Mail, Restricted Delivery, postage prepaid, at the following address: David Lego 876 Mandy Drive Camp Hill, PA 17011 _"?' P a, '- GAR KELLEY, sq ire I.D. 04-001 ?Ij 3117 Chestnut Street Camp Hill„ PA 17011 (717) 612-1484 Attorney for Plaintiff ¦ Complete Itbnta 1, 2, and 3. Also con" 86 Item 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: r i ? Agent Received by (Pdr fed /Ja?llsy -' c. *M of Delivery D. Is delhmy address aftr nt from item 17 ? Yes If YES, enter delivery address below: ? No 3. Seryloo Type Certmsd Mall 13 Express Mail C3 Registered ? Return Receipt for Merowmm ie O insured man ? C.O.D. 4. Restricted Delivery? it:xtra Fee) ee 2. Article Number MWLV rfromserv>csrew 7009 2250 0001 2035 8033 Ps Form 3811, February 2004 Dortteame lWan hroairyt 102595-02-M-1540 SHANNON LEGO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2010--3834 DIVORCE DECREE AND NOW, Pte, 2.2._ , t, it is ordered and decreed that SHANNON LEGO , plaintiff, and nAVTD LEGO , 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, fe-s-t.- J. Prothonotary iat?aA2/?o - c-ePi- 4y mgjel vir., a: ? Ivbfiee Cqoy mailed & ke/4( 'be&- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA -Sh'f?NN6f-1 /f?-66 Plaintiff Vs . File No. 7ol c) ?q Defendant 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 /Z - Z 2 - /D , hereby elects to resume the prior surname of 0-704-YOIII and gives this written notice avowing his / her intention pursu o S. 704. Date: tore tore of nam eing resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF (? um L?rlarao? On the 54 day of Apri I t 1, 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 here-arrto set my hand and official seal. Prothorio- tary or otary ublic WON= son Ing ??d W1014 ,? FILED-Off ICE OF THE PRoTijoNOTA r 2441 APR _5 Ph 3: 34 CUMOBLA D COUNTY PNNSY C ?? S 2.3