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Home My WebLink About02-0321ERIC AUGUST LEIDICH, Plaintiff JOY LEIDICH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA - CIVIL ACTION - LAW COMPLAINT IN DIVORCE NOTICE TO: JOY LEIDICH 16 Dead End Lane Shippensburg, PA 17257 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 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 the Cumberland County Courthouse, One Courthouse Square, 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 (800) 990-9108 Document #: 224559.1 ERIC AUGUST LEIDICH, Plaintiff JOY LEIDICH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW COMPLAINT IN DIVORCE COMPLAINT IN DIVORCE 1. The Plaimiff, Eric August Leidich, is an adult individual residing at 190 S.M.E., Shippensburg, Cumberland County, Pennsylvania. 2. The Defendant, Joy Leidich, is an adult individual residing at 16 Dead End Lane, Shippensburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 14, 1998, in Shippensburg, Cumberland County, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. Plaintiff's social security number is 064-56-5041, and Defendant's social security number is 100-84-7435. 7. There have been no prior actions of divorce or for annulment between the parties. 8. Plaintiff has been advised that counseling is available and that Plaintiffmay have the right to request that the Court require the parties to participate in counseling. Document #: 224559.1 06/02/99). Defendant. There was one child bom of this marriage, Kirsten Nichole Leidich (d.o.b. The marriage is irretrievably broken. The parties have been living separate and apart since July 31, 2001. Plaintiff requests the Court to enter a Decree in Divorce divorcing Plaintiff and WHEREFORE, Plaimiff requests that this Court enter a Decree in Divorce and any such other orders as are appropriate and just.. METZGER, WICKERSHAM, KNAUSS & ERB Date: By: Andrew C. Spears, Esquire Attorney I.D. No. 87737 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Document tl: 224559.1 VERIFICATION I, Eric August Leidich, hereby certify that the facts set forth in the foregoing Complaint in Divorce are tree and correct to the best of my knowledge, information and belief, and that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom falsification to authorities. Document #: 224559.1 RECORDOF DIVORCE OR ~'~ (CHECKON~ HUSBAND 1. f~E ~st) F,,;~;=; (Last) ERIC A. LEIDICH 3. RESIDENCE l : DATE (Month) (Day) (Year) OF BrRTH 2 9 75 · Pt.A~CE (S~tate ~,- FO~ C.~une-/) atm'. New York 1900 S.M.E. Shippensburg, Cumberland, PA M_--__-= I""~ i7. USUAL OCCUPATION THIS WHrrE ~.ACK O'n-~R (spec~y) WIFE Heberly 1~ RE~OENCE 17A.MARR~AGEC~LORENN~"~"-'~" OFTH~$,.L rTs. 20. I~" ~_"~ OF HUSBAND WIFE CHILDREN TO cusToov o~ [] [] 1 2?- DATE OF DECREE (M~h) (Day) 24, SIGNATURE OF TRANSCRIBING CLERK Joy Ann T.o-i d t rh mRn~ 8 S~r~t m'R.O. (~y, BO~O. m-'r~p. Cour~y Stye 1. P~CE (~m~ c~6 16 Dead End I.n~e, Shiopensbur~. Cumh~rln~ PA PA ~ ~ER (~) 14, U~ ~PA~ ~ I ?A [ ~E 8 ~ ~ O~ER (~) [-' H~ (Day) (Year) 14 lqqR WIFE OTHER (Specify) SPt. ITCUSTOOY OTHER(Specify) ~ 21, LEQALGROUNOSFOR [] [] I Irretrievable breakdown (Year; 123. OATE REPORt SENT TO VffAL RECORDS I ERIC AUGUST LEIDICH, Plaintiff, JOY LEIDICH, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-321 CIVIL ACTION - LAW COMPLAINT IN DIVORCE AMENDED COMPLAINT IN DIVORCE 1. The Plaintiff, Eric August Leidich, is an adult individual residing at 190 S.M.E., Shippensburg, Cumberland County, Pennsylvania. 2. The Defendant, Joy Leidich, is an adult individual residing at 16 Dead End Lane, Shippensburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. Plaintiff and Defendant were married on August 14, 1998, in Shippensburg, Cumberland County, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its Amendments. Plaintiffs Social Security number is 064-56-5041, and Defendant's Social Security number is o 193-56-0523. 7. 8. There have been no prior actions of divorce or for annulment between the parties. Plaintiff has been advised that counseling is available and that Plaintiff may have the fight to request that the Court require the parties to participate in counseling. Document #: 226574.1 9. There was one child bom of this marriage, Kirsten Nichole Leidich (d.o.b. 06/02/99). 10. The marriage is irretrievably broken. 11. The parties have been living separate and apart since May 31, 2001. 12. Plaintiff requests the Court to enter a Decree in Divorce divorcing Plaintiff and Defendant. WHEREFORE, Plaintiff requests that this Court emer a Decree in Divorce and any such other orders as are appropriate and just. METZGER, WICKERSHAM, KNAUSS & ERB Date: By: Andrew C. Spears, Esquire Attorney I.D. No. 87737 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Document#:226574.1 VERIFICATION I, Eric August Leidich, hereby certify that the facts set forth in the foregoing Amended Complaint in Divorce are true and correct to the best of my knowledge, information and belief, and that false statemems herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom falsification to authorities. Date: Eric August Leidich ERIC AUGUST LEIDICH, Plaintiff, JOY LEIDICH, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-321 CIVIL ACTION - LAW COMPLAINT IN DIVORCE AFFIDAVIT OF SERVICE I, Andrew C. Spears, counsel for Plaintiff, Eric August Leidich, hereby certify that a tree and correct copy of the Amended Complaint in Divorce was served upon the following, by certified mail, return receipt requested, on February 14, 2002. Attached hereto, marked as Exhibit A and incorporated herein by reference, is a copy of the Return Receipt indicating service upon: Joy Leidich 16 Dead End Lane Shippensburg, PA 17257 METZGER, WICKERSHAM, KNAUSS & ERB Date: By: Andrew C. Spears, Esquire Attorney I.D. No. 87737 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Exhibit A ERIC AUGUST LEIDICH, Plaintiff, V. JOY LEIDICH, Defendant. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-321 : CIVIL ACTION - LAW : : COMPLAINT IiX[ DIVORCE AFFIDAVIT OF CONSENT 1. An Amended Complaint in Divorce under §§ 3301(c) and (d) of the Divorce Code was filed on February 6, 2002 and served upon Defendant on February 14, 2002. 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. I verify that the statements made in this Affidavit are tree and correct. I understand that any false statements herein are made subject to the penalties of 18 Pa.C.S., § 4904, relating to unswom falsification to authorities. Dated: '~ric August Leidich ERIC AUGUST LEIDICH, Plaintiff, V. JOY LEIDICH, Defendant. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-321 : : CIVIL ACTION - LAW : : COMPLAINT IN DIVORCE WAIVER OF NOTICE OF INTENTION ']FO REQUEST ENTRY OF DIVORCE UNDER § 3301(c) OF DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights conceming alimony, division of property, lawyers' fees or expenses ifI 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 at, er it is filed with the Prothonotary. I verify that the statements made in this Affidavit are tree and correct. I understand that any false statements herein are made subject to the penalties of 18 Pa.C.S., § 4904, relating to unswom falsification to authorities. Dated:/Q~//~2~, Eric August Leidich ('3 0 0 ERIC AUGUST LEIDICH, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 02-321 JOY LEIDICH : CIVIL ACTION - LAW ..... '::: Defendant : : COMPLAINT IN DIVORCE ::'~: ' ,:, , ,, AFFIDA¥IT Of CONSEN~ :~'- -- <:~ 1. An Amended Complaint in Divorce under §§ 3301(c) and (d) of the Divorce Code was filed on February 6, 2002 and served upon Defendant on Feb:mary 14, 2002. 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. I verify that the statements made in this Affidavit are true: and correct. I understand that any false statements herein are made subject to the penalties of 18 Pa.C.S., § 4904, relating to unswom falsification to authorities. Dated: ERIC AUGUST LEIDICH, Plaintiff, V. JOY LEIDICH, Defendant. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-321 : : CIVIL ACTION - LAW : : COMPLAINT IN DIVORCE C~ WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE UNDER § 3301{c) OF DIVORCE COD~ I consent to the entry of a final decree of divorce without notice. I understand that I may lose rights concerning alimony, division of property, lawyers' fees or expenses ifI 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 tree and correct. I understand that any false statements herein are made subject to the penalties of 18 Pa.C.S., § 4904, relating to unswom falsification to authorities. Dated: ERIC AUGUST LEIDICH, JOY LEIDICH, Plaintiff : : : : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-321 IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following irfformation, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: A Complaint in Divorce was filed on February 6, 2002, and served on Defendant on February 14, 2002, by certified mail, return receipt requested. An Affidavit of Service was filed on February 22, 2002. 3. Complete either paragraph (a) or (b): (a) Oo)(1) Date of execution of Plaintiffs and Defendant's Affidavits of Consent required by Section 3301 (c) of the Divorce Code: Plaintiff: Defendant: October 7, 2002, filed October 17, 2002 October 14, 2002, filed October 17, 2002 Date of execution of Plaintiffs affidavit required by Section 3301(d) of the Divorce Code: NA (2) Date of filing and service of the plaimiffs affidavit upon the respondent: Filing: NA Service: NA Complete the appropriate paragraphs: (a) Related claims pending: None Document #: 244079.1 (b) Claims withdrawn: None (c) Claims settled by agreement of the parties: None (d) State whether any written agreement is to be incorporated into the Divorce Decree: N/A. (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached, if the decree is to be entered under section 3301(d)(1)(i) of the Divorce Code: Service: NA (b) Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: October 17, 2002 Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: October 17, 2002 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Dated: By Andrew C. Spears, Esquire Attorney I.D. No. 87737 P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Document #: 244079.1 ERIC AUGUST LEIDICH, Vo JOY LEIDICH, Plaintiff : : . Defendant : IN THE CO,URT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-321 IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this /~3~lay of October, 2002 I, Andrew C. Spears, Esquire, of Metzger, Wickersham, Knauss & Erb, P.C., attorneys for Plaintiff, Eric August Leidich, hereby certify that I served a copy of the Praecipe to Transmit Record this day by ,depositing the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Joy Leidich 16 Dead End Lane Shippensburg, PA 17257 METZGER, WICKERSIq~M, KNAUSS & ERB, P.C. By: Andrew C. Spears', Document #: 244079.1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE Of ~~ PI--NNA. ERTC AUGUST LEIDICH, Plaintiff VERSUS JOY LEIDICH, Defendant 02-321 DECREE IN DIVORCE Now, DECREED THAT AND ERIC AUGUST LEIDICH 2002 JOY LEIDICH , IT I$ ORDERED AND __, PLAINTIFF, , 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 ATTEST: PROTHONOTARY