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Home My WebLink About05-1291 .. i) , SHAWN 1. LEONARD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 0'5" - I.A t1/ Civil Term SHARON 1. LEONARD, Defendant : ACTION 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. 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 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 St. Carlisle, Pa. 17013 (717) 249-3166 .. , ... SHAWN 1. LEONARD, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. Civil Term SHARON J. LEONARD, Defendant : ACTION IN DIVORCE COMPLAINT IN DIVORCE I. Plaintiff is Shawn 1. Leonard, a competent adult individual, who has resided at 5 Penny Lane, Carlisle, Cumberland County, Pennsylvania, 17013, since 2003. 2. Defendant is Sharon 1. Leonard, a competent adult individual, who has resides at I Orchard View Park, Gardners, Cumberland County, Pennsylvania, 17324. 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 18, 1994 in 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 two children together. 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 arc true and correct. I understand that false statements herein arc made subject to the penalties of 18 Pa.C.S. S4904 relating to unsworn falsification to authorities. Respectfully submitted, Date: 3-l'- 06 J e Adams, Esquire .D. No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF "1.:, ~. ~ ~f\ '. 12' , ~ o ~ ~. C:J '. l.,.. \ l'-> , "" , c l'~., C) ::',; --n ~:.-' , rt --- .. ,~ . l.~ SHAWN 1. LEONARD, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. (JS::" 1;)'1'/ Civil Term SHARON J. LEONARD, Defendant ACTION IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a counter- affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT OF SEPARATION I. The parties to this action separated in 1995 and have continued to live separate andapart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose my rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 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. 94904 relating to unsworn falsification to authorities. Date: 3-g - OS- /1// Shawn 1. Leonard, Plaintiff SHAWN L. LEONARD, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V ANI vs. : No. 05 - 1291 Civil Term SHARON J. LEONARD, Defendant : ACTION IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this March 29, 2005, I, Jane Adams, Esquire, hereby certifY that on March 22, 2005, a certified true copy of the NOTICE TO DEFEND and COMPLA TIN DIVORCE was served, via certified mail, restricted delivery, return receipt requested, ddressed to: Sharon Leonard 1 Orchard View Park Gardners, Pa. 17324 DEFENDANT . Complete II1wns 1, 2, and 3. Also complete 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 mallpi$ce. or on the front if space permits. 1. Article Addressed to: ShGlf'On L eo I) "a. I'd 1 Ot-cha.~ View"Por K G /:l-{' dl'\6"S , PAl '7.:52+ 2.__ (llonoIIoI'--~ PS Form 3811 , Februlry 2004 Don1eIIIc Return 1_11140 u ~an Adams, Esquire LD No. 79465 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ~ """::J ~Tl -, I_V t:'-) '~'~} ;"',) ;''-..) v-:> SHAWN L. LEONARD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 05 - 1291 Civil Term SHARON 1. LEONARD, Defendant : CUSTODY CUSTODY COMPLAINT 1. Plaintiff is Shawn L. Leonard, who currently resides at 5 Penny Lane, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Sharon J. Leonard, who currently resides at 1 Orchard View Park, Gardners, Pa, 17324. 3. Plaintiff is the father of the following children and seeks custody of the following children: NAME DOB/AGE ADDRESS AsWey Leonard 12/24/90 (14) 5 Penny Lane Carlisle, Pa. 17013 Ryan Leonard 9/19/94 (10) 5 Penny Lane Carlisle, Pa. 17013 Mother and Father married on June 18, 1994. Father currently has primary physical custody ofthe children. During the past five years, the children have resided with the following persons and at the following addresses: NAME ADDRESSES DATES Shawn Leonard Christy Brownawell (Girlfriend) as well as Hunter Shane, ShyAnne Shane and Rodney Shane 5 Penny Lane Carlisle, Pa. 17013 2002 - present Shawn Leonard 910 Creek Road Lynn Leonard (grandmother) Carlisle, Pa. 17013 Shane Leonard (uncle) Christy Brownawell (girlfriend) 2000 - 2002 The mother of the children is: Sharon Leonard, and she currently resides at: I Orchard View Park, Gardners, Pa. 17324. She is married to: Shawn Leonard. The father the children is: Shawn Leonard, and he currently resides at: 5 Penny Lane, Carlisle, Pa. 17013. He is married to : Sharon Leonard. 4. The relationship of plaintiff to the children is that of Father. The persons that the Plaintiff currently resides with are: the children, his girlfriend, his girlfriend's children, and Rodney Shane. 5. The relationship of defendant to the children is that of Mother. The defendant currently resides with her boyfriend, Chris Bitner. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a party to the proceedings who has physical custody of the child or anyone who claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: Father has had primary custody of the children since the couple separated over Christmas. 1995. Father has demonstrated his ability to provide a stable and lovinl! home for the children. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff requests the court to grant custody of the children. """ Gl\blbS dams, Esquire o. 79465 uth Pitt Street Carlisle, Pa. 17013 (717) 245-8508 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. 94904 relating to unsworn falsification to authorities. Do" r;,/r h ~S ^f\ ~~ v, () w ~ o ~ ~ J\ ~ " , \ () c -. '" ('::::> cO> <en <- c: z o -n ~~ f1l'~ @ ""TlS ;"c;J . >~o . ::,-'."T' ':.-"S :'~J :;;.l") '~jrn ~ .JJ .< cro -t) r::;; w SHAWN L. LEONARD PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 05-1291 CIVIL ACTION LAW SHARON J. LEONARD DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, Juue 23. 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, July 12,2005 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Tacqueline M. Verney, Esq. Custody Conciliator y The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For infonnation about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 170 I 3 Telephone (717) 249-3166 '??~p ~~~J 5'O'['C'P - ~.j? "}:?':1Jo'Y ~ J(/. ['e.~ ~,Pp p --7 ~ 4tp -P9 .5OE'~ l' I S :f lid S Z Nnl~ soaz 1;.)"li._., 1','.1 , :JHl .If) ,,~, V_.u.\,..d iJ.,I<J'C1CJ _. .:tv :j:)i~:!:30''''0311:J SHAWN L. LEONARD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 05 - 1291 Civil Term SHARON J. LEONARD, Defendant : ACTION IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this June 29, 2005, I, Jane Adams, Esquin:, hereby certifY that on June 23, 2005, a certified true copy of the CUSTODY COMPLAINT was served, via certified mail, restricted delivery, return receipt requested, addressed to: ."" Nathan Wolf, Esquire 37 South Hanover St. Carlisle, Pa. 17013 ATTORNEY FOR DEFENDANT . CornpIoM IlImIl, 2, end 3. AIllo "",..,Ael& nom 4 ff Restricted Delivery Is desired. . Print your name and address on th8 reve... so that we can return the card to you. . Attach this card to the back of the mellpJecei or on the front ff space pennlts. 1. Article Addressed to: Nat\1Vl uJO( f I e~. 3~ Sovth HZ{f1O!1tf' 9. C "l!r-h>le /p A (,/0/3 3. Selvlce Type ~er8d- [J IMUnId M81I o Expreos Mall o Return _pt for MerchandIse o C.O.D. 4. FWL I I ~ DIlIYorIIIE>fra Fee) 0 "'" 2.__ C-1k>m_1abeI) PS Fonn 3811, February 2004 7004 1350 0003 7284 9263 ~_m_ 102&15-02-M-1S40 i Respectfully S bmitted: ( e dams, Esquire D. o. 79465 6 outh Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FORPLAINTWF g ';:to ~ ~ 7' ~\ ~.~ e f:C. Z)' r ti;:..p I j"'>" - ':2.C -0 ~a z. c::, :::s: 5'-~ ~ :0\ ~ t1\ ~ fJ,) ~ECEIVED AUG 032005 ~ SHAWN L. LEONARD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-1291 CIVIL TERM SHARON J. LEONARD, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 'i~ day of ~ v ,2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I. The Father, Shawn L. Leonard and the Moth'~r, Sharon J. Leonard, shall have shared legal custody of Ashley Leonard, born December 24,1990 and Ryan Leonard, born September 19, 1994. Each party shall have an equal right, to be exercised jointly with the other party, to make all major non-emergeney decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. This means that both parents shall be entitled to all information from school and medical professionals. 2. Father shall have primary physical custody of the Children. 3. follows: Mother shall have periods of partial physical custody of the Children as A. One week in the summer of2005 beginning August 12,2005 to August 19,2005. Three weeks in each summer thereafter, one week in June, July and August. Mother shall provide Father with 30 days prior notice of the week she selects. B. Beginning August 26, 2005 alternating weekends from Friday at 6:00 p.m. to Sunday at 6:00 p.m. C. Such other times as the parties agree. 4. Thanksgiving shall be shared such that Fath(:r shall always have physical custody of the children until Thanksgiving at 5:00 p.m. M01her shall have physical custody of the children from 5:00 p.m. Thanksgiving until Monday at 6:00 p.m. 5. Christmas shall be shared as follows: In odd numbered years Father shall have physical custody of the children from the day school recesses for Christmas vacation to December 26 at 6:00 p.m. In even numbered years, Father shall have physical custody of the children from the day school recesses to December 24 at 6:00 ',u.. .r: \.Pj '\- ~l\l\i s@l ~v JC~ p.m. In odd numbered years, Mother shall have physical <:ustody of the children from December 26 at 6:00 p.m. to the day before school resumes and in even numbered years Mother shall have physical custody of the children from December 24 at 6:00 p.m. to the day before school resumes. 6. The parents shall alternate the following holidays: Labor Day, Memorial Day and July 4th. Mother shall have physical custody ofth<: children on Labor Day, 2005. 7. Mother shall have physical custody of the children on Mother's Day and Father shall have physical custody of the children on Father's Day at times agreed by the parties. 8. Transportation shall be shared such that the parties shall meet at the UniMart in Plainfield, Pennsylvania. 9. The parties shall have reasonable telephone c:ontact with the children. 10. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions ofthis Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, cc: Jane Adams, Esquire, Counsel for Father Nathan C. Wolf, Esquire Counsel for Mother '/fJ J. ~ ~ 8_'1_01 ~. SHAWN L. LEONARD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2005-1291 CIVIL TERM SHARON J. LEONARD, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: I. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Ashley Leonard Ryan Leonard December 24, 1990 September 19, 1994 Father Father 2. A Conciliation Conference was held in this matter on August 2, 2005, with the following individuals in attendance: Father, Shawn L. Leonard, with his counsel, Jane Adams, Esquire and Sharon J. Leonard, with her counsel, Nathan Wolf, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. t-;;. -us Date ~:::y'~~i~ Custody Conciliator .. SHAWN L. LEONARD, Plaintiff vs. SHARON J. LEONARD, Defendant ..' .', : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 05 - 1291 Civil Term : ACTION IN DIVORCE , . ," -, . -.; .' 'AFFIDAVIT OF SERVICE AND NOW, this February 12, 2007, I, Jane Adams, Esquire, hereby certify that . '. . on March 22, 2005 a certified tru~ copy of the AFFIDA vq OF SEPARATION was served, via certified mail, restricted delivery, return receipt requested, adclressedto:' Sharon Leonard 1 Orchard View Park Gardners, Pa. 17324 DEFENDANT Adams, Esquire .1. . No. 79465 4 South Pitt Street' Carlisle, Pa. 17013 (717) 245-8508 . ATTO~Y FOR PLAINTIFF po. Jane Adams ATTORNEY AT LAW 64 SOUTH PITT STREET CARLISLE, PA. 17013 (717) 245-8508 voice (717) 243-9200 fax esaadams@aol.com VIA CERTIFIED MAIL, RESTRICTED DELIVERY March 14, 2005 Sharon Leonard 1 Orchard View Park Gardners, Pa. 17324 Re:Leonard v.Leonard No. 05 - 1291 Civil Term (Cumberland County) Dear Sharon: Enclosed please find a Complaint in Divorce and Affidavit of Separation which have been filed with the Cumberland County Prothonotary under section 3301 of the Divorce Code. You may want to consult an attorney regarding your legal rights and for assistance in this matter. Thank. you for your kind attention to the above. ve. ry truly yours, # ". ~{Q Ce(/{(JM!- Jf::j Adams, Esquire . /JA cc: Shawn Leonard .. COm~ iteffi81, a. Md a. AI/i6 ~. "".'. ,. Itern4IfA~l>8Hvllty'.~. ...... ' , iI .Prlnt your !'11m; IlId ~ 6h ti;e NlY8IIlI . 10 tiillt we cen f8tUrh till! CIitl to yoU, · Mach this cilrd tbll1li IloiOk lit th8ltl~ '. otDii~frohtlf~ce~" .. 1. Attlole Addmond 10, 8harvn Lt:Dt)~r<J 1 6;cha~V;f0 ~tl~k . GrJ-i-dYlel'5i PAt? 324:: 2. ArtlclliNUmIllir' '. ,. -, 1..1 003 3110 0004 ~:ftIlIil'eIrIvIoe~li:' 1:1 7 .. . 5775'-4450 ~Srljtl;;~~i1'iF,eIf\i~~;':' il_!~~~~.':'''' ""'Wh,. 102hUi.M>1540 C') c: ~ -ow, m':D Z,,, z.._ ej') .c:, !:2b J>~. Q -0 c: ~ g ~ ~; ~ %a N ~ ." ~ s::- SHAWN L. LEONARD, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 05 - 1291 Civil Term SHARON J. LEONARD, Defendant ACTION IN DIVORCE AFFJDA VIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on March 11,2005. 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 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: ;)-/9 -0) WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &330l(c) AND ~330l(d) 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 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. J - / 7 '0 /haIonl. Leon Date: () c ~ -ou; mrn Z"~' zr" ~~..~ !;2C ~( c....:;CJ :r-....c z ~ ~ c= c= --I .." r"'1 O:J N ~ ~iI1 ~iB 06 :~.., ~5 om ~ -< -0 :x ~ o -..J SHAWN L. LEONARD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 05 - 1291 Civil Term SHARON J. LEONARD, Defendant : ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under 9330l(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Sent certified mail, restricted delivery, return receipt requested, receipt signed, March 22,2005. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: March 9, 2007 By Defendant: February 19,2007 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: February 21, 2007 Date Plaintiffs Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: March 13,2007 Date: ~,\.~. 0 ~ Respectfully Submitted: ~ e Adams, Esquire . No. 79465 64 S. Pitt Street Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff o ~? r--:> = <..? .....J """'I?" _.0::::0. -p'lt :;;0 o .., :::;i J.- -r: fi'P. ~-~r~) -r: --h ~\~~ ....." "':0 :..<; w -0 -.J:.... 'i! (....1 SHAWN L. LEONARD, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 05 - 1291 Civil Term SHARON J. LEONARD, Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on March 11,2005. 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 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. ~ Date'3.Q.) /1 ~~~~Oon~d,DefenWmt WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &330l(c) AND 6330l(d) 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 u derstand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to u wo lfication to authorities. Date: "3, OJ ,7 ~ = = -..l ::lit ~ ::N o -.1 --4 :I:-n n1Fr. :fj c;; '~~ ':::::! ?P ~ w ~ w .- N 'to 'to ;!; ;!; ;!; IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. Shawn L. Leonard, Plaintiff No. No. 05 - 1291 Civil Term VERSUS Sharon J. Leonard, Defendant DECREE IN DIVORCE AND NOW, ~~ ..zJ," ,..LooT-, IT IS ORDERED AND Shawn L. Leonard DECREED THAT AND Sharon J. Leonard , PLAJ NTI FF, , 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. J. PROTHONOTARY ;!; ;!; ;!; ;!; ;!; ;!; ;!; ;!; ;!; ~C/ k 2 ~ ~tj (O.Le-r ~ p;Z~ ~? -r? ~o~ Lt'. E' " . . ~ . "!.. . ,~