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HomeMy WebLinkAbout04-4507 (). TAMARA J LEGGE, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. : NO. o<!.Y$"o'Y ~ I........ TODD S LEGGE, Defendant. : 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 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 counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS' 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 OF 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 Cumberland County Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, P A 17013 (717) 240-6200 Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 </. '1rO'T G.v.:1 T.w- TAMARA J LEGGE, v. TODD S LEGGE, Defendant. CIVIL ACTION- DIVORCE COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE COUNT I - DIVORCE 1. Plaintiff is Tamara J Legge, who currently resides at 102 A Old Cabin Hollow Road, Dillsburg, York County, Pennsylvania. 2. Defendant is Todd S Legge, who currently resides at 1909 Princeton Ave, Camp Hill, Cumberland County, Pennsylvania. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing ofthis Complaint. 4. The Plaintiff and Defendant were married on October 4, 1997 in Harrisburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the Parties. 6. The marriage is irretrievably broken. 7. Neither Party is a member of the Armed Forces of the United States or any of its allies. 8. The Plaintiff has been advised of the availability of counseling and that either Party may compel the other by Order of Court to attend counseling sessions. WHEREFORE, Plaintiff respectfully requests that your Honorable Court enter a Decree in Divorce under Section 3301 of the Divorce Code. COUNT II--CUSTODY 9. The Plaintiff incorporates by reference Paragraphs I through 8 of the Complaint for Divorce as fully set forth herein. 10. There were two (2) children born during this marriage, to wit: Kassidy R Legge, born September 6, 1998 and Brody D Legge, born June 26, 2002. II. During the past five (5) years, the children have resided with the following persons and at the following addresses: Person(s) Tamara J. Legge Address 102 A Old Cabin Hollow Rd. Dillsburg, P A Dates August I, 2004 - present Tamara and Todd Legge 102 A Old Cabin Hollow Rd Dillsburg, P A Prior to August I, 2004 12. The Court of Common Pleas of Cumberland County, Pennsylvania, Family Division, has the sole and exclusive jurisdiction in this matter, pursuant to the Uniform Child Custody Jurisdiction Act, and the Commonwealth Child Custody Jurisdiction Act for the following reasons: a) Cumberland County, Pennsylvania, has been the children's home county within six (6) months before the commencement of the instant proceedings. b) It is in the best interest and welfare of the children that the Court of Common Pleas of Cumberland County, Pennsylvania, assume jurisdiction because the children have a significant connection with this jurisdiction, and there is available in this jurisdiction substantial evidence concerning the children's present or future care, protection, training and personal relationships. c) No other state has jurisdiction in this matter under the requirements of the Uniform Child Custody Jurisdiction Act and the Commonwealth Child Custody Jurisdiction Act. 13. The Plaintiff has not participated in any capacity whatsoever in any other litigation concerning the custody of the minor children in this or any other state. 14. The Plaintiff does not know if any other person than the Defendant herein claims to have custody or partial custody rights with the minor children. IS. The Plaintiff submits that it is in the best interest and welfare ofthe children that the Plaintiff be granted custody of the children, and that the Plaintiff can best provide the minor children with a more stable, healthful, religious, and proper environment. WHEREFORE, Plaintiff prays that the Honorable Court grant custody of the minor children of the Parties to Plaintiff. Respectfully submitted, ROBINSON & GERALDO Date: 11'5/0'\ , By: aeriild S. Robinson, Esquire Attorney J.D. #27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for Plaintiff 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. I ---'" ~ ~a J Legge ./ CERTIFICATE OF SERVICE I, Gerald S. Robinson, Esquire, do hereby certify that on the 24th day of 2004, I caused a true and correct copy of the Order to be served upon the following individual by first class mail by depositing same in the United States, postage prepaid, in Harrisburg, Pennsylvania. Todd S Legge 1909 Princeton Ave Camp Hill, P A 17011 Respectfully submitted, ROBlNst GERALDO By: j ~ Gerald S. Robinson, Esquire Attorney LD. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110 (717) 232-8525 ~ ~ r' ~-! ~ ~ ..., )> '" il) "- '"' '" d "- t Q ~ ~ ~ "- '-'\ '" -c Ii', If, _. ~ \' , ~ g '" ....-:.l t::;-, 0r- <./) c) " .-1 fE?: !"n ~':J " o 'T . -;-, ~: f:'5 ~--~;!n ..( ~ -,. , CD ~.~ 9? l'v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TAMARA J. LEGGE Plaintiff v. TODD S. LEGGE Defendant No. 04-4507 Civil Action - Law DIVORCE PRAECIPE TO WITHDRAW /ENTER APPEARANCE TO THE PROTHONOTARY: Please WITHDRAW my appearance as ounsel for the Plaintiff, TAMARA J. LEGGE, in the above-captioned case. Dated: ,.2./,1. <-{I (Jv ,2006 * * * * * * * ERALD S. ROBINSON, ESQUIRE Atty. ID No. 27423 4407 North Front Street Harrisburg, Pennsylvania 17110 (717) 232-8525 Please ENTER my appearance as counsel for LEGGE, in the above-captioned case. laintiff, TAMAR J. ;JCT>><T,liIM....HF.RIlOJ.D,SCHAI'MANNLI.P AITORNt<YSA1 LAW 12~ F..'T MA"~ETS'I"REJ-:T Y().K,PESN."U~~LA 174l:11 rELWH{)NF.:r7l7)846.~8,(> Dated: JIJ ,2006 II SUZ H.GRIEST, ESQUIRE 129 ast Market Street York, Pennsylvania 17401 (717) 846-8856 Sup. Ct. ID No. 34362 (~ -n ':'') W \ ~_. ~? ,'.--:" :.:2 .',.' ,......