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Home My WebLink About01-4079 ~ $ ~ ~el -,rv /o-ee~ ~r-? ~~/fJ /o.tr.~ '\ ~.;'- ., -' '" ...... '~ .. . , , . Rodger L. Leach, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. D I - t.f 0 '7 i} CIVIL TERM vs. CIVIL ACTION--LA W Lisa A. Leach, Defendant 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 in 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 the Cumberland County Courthouse, High and Hanover Streets, 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 (717) 249-3166 .. '. Rodger L. Leach, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA NO. 0 I - '-/0 "7 ? CIVIL TERM vs. CIVIL ACTION--LAW Lisa A. Leach, Defendant IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Rodger L. Leach, who currently resides at 3780 Lot 4 A Spring Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Lisa A. Leach, who currently resides at 213 Pharis Street, Syracuse, New York. 3. Plaintiff and defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on February 20, 1982 at Newport, 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 require the parties to participate in counseling. .. J 8. Plaintiff requests the court to enter a decree of divorce. Respectfully submitted, Law Office of James K. Jones, Esquire o~~ J~K. Jones, E 're Attorney for Plaintiff 7 Irvine Row Carlisle, PA 17013 (717) 240-0296 I verify that the statements made in this Complaint are true and correct to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. ~~ Rodger . Leach . () - tA $ 7> P r--_ N ? " ~~ " "- '- ~ ~ " d N ~ ~ (J:) ~ :s " \. ....'- .~, .... { ,:.> G ~ J1 IQ ill 6<7 -' C v' \ ~, '8 ~ ~ Rodger L. Leach, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. CIVIL TERM DI- '-/0'71 ~ ,- ~ CIVIL ACTION- -LAW Lisa A. Leach, Defendant 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 UNDER SECTION 3301 (<1) OF THE DIVORCE CODE 1. The parties to this action separated in November, 1984 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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. Date: 6/~1'1 Of Rodg~/ 44Af" g v\ <;:. ..., f> N ? ""'" \~: ~ N ~ ......, ~ . ~ RODGER L. LEACH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. : NO. ~ CIVIL TERM D/- 4cnq LISA A. LEACH Defendants IN DIVORCE AND NOW, this 10'711 day of AFFIDAVIT OF SERVICE Au c,t-t} t , 2001, comes James K. Jones, Esquire and certifies that he mailed a true and correct copy of the Complaint in Divorce, Affidavit Under Section 3301 (d) of the Divorce Code and Notice to Request Entry of Divorce Decree in the above-captioned matter to the defendant by certified mail, restricted delivery. Said return receipt is attached hereto indicating service was made on July 3,2001. . ones, Esquire Atto ey for Plaintiff 7 Irvine Row Carlisle, P A 17013 (717) 240-0296 Complete items 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 mailpiece, or on the front if space permits. 1. Article Addressed to: L'\ S-A A. LtAc-~ ~ 12:> r hClR-~S ~+ . S"/ K -:ALu2€-) ]{ I Y . '0;::'. 8S J 3 'd-O Lj D. Is delivery address different from item 1? If YES, enter delivery address below: 3. Service Type o Certified Mail o Registered o Insured Mail o Agent o Addressee DYes o No o Express Mail o Return Receipt for Merchandise o C.O.D. 4. Restricted Delivery? (Extra Fee) 2. Article Number (Copy from service label) 10'1 g 3J.,.;t6 aGog ,5515 PS Form 3811, July 1999 Domestic Return Receipt () :9.-, ~ ~ Yes 102595-00-M-0952 0 c:: () c: ~~ ~.~ - ~JfY. .-- f11r.\ S ~ ~iL- - (. ~ '?-:. \- ~c~~: ~-l' CO -:PC -----, C(:) Z '..J1 :2 '.<:) ~ __-1 -< .....1 ~ ') ~ . _l. IN THE COURT OF COMMON PLEAS RODGER L. LEACH CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL DIVISION LISA A. LEACH NO. 01-4079 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown unde~t~ 3301 (d)(1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Certified mail, restricted delivery, return receipt requested service on July 3, 2001 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by ~3301 (c) of the Divorce Code: by plaintiff ; by defendant (b) (1) Date of execution of the affidavit required by ~3301 (d) of the Divorce Code: June 28, 01 (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Filed on June 29, 2001; served on July 3, 2001 4. Related claims pending: none 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: served on July 3, 2001 by certified mail, restricted de live (b) Date of plaintiff's Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: Date defendant's Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: ------- .-- \....,..." - o ~~ -00; fn1;~' -Z~:\ /_1~ . (j') , :::.<. s::: "\7--. "?' "'--'., """l~ ')? C-. ?::i -"- 'r~ .:-- ~~;-) - (.. +) ~: c:) .' .n t~ ----------- i . ..t Rodger L. Leach, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA NO. CIVIL TERM v. CIVIL ACTION- -LAW Lisa A. Leach, Defendant IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: Lisa A. Leach: You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the ~3301 (d) affidavit. Therefore, on or after J ul y 23, 2001, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit whicp you may file with the prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the di~orce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU CO 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 BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166. ~ 0> (') ~; -oh, O1f'.. ~-: ::'. 2:l: S?, ~~: ~C-; > C'.'. ~ vJ <:t> \1"1 C'() '> ? ~ ',. c:' ~--) "':;:> :.n ( . _---r-: C.n '_Tl (;Q '_~~'l IN THE COURT OF COMMON PLEAS RODGER L. LEACH CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL DIVISION LISA A. LEACH NO.01-4079 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under 93301 (c) 3301 (d)(1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Certified mail. restricted delivery, return receipt requested service on July 3, 2001 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by 93301 (c) of the Divorce Code: by plaintiff ; by defendant (b) (1) Date of execution of the affidavit required by 93301 (d) of the Divorce Code: June 28, 01 (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Filed on June 29, 2001; served on July 3, 2001 4. Related claims pending: none 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: served on July 3, 2001 by certified mail, restricted delivery. Defendant'sCounter-affidavit dated 8/19/01 and filed 8/21/01. (b) Date of plaintiff's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: Date defendant's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: ~,a;nte o ..- '? ~ '" N ., C) '^ -0 ~ s=: c- ~-;:~ ) ;.) c;. Rodger L. Leach, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA 01- '10'1'1 NO. CIVIL TERM v. CIVIL ACTION- -LAW Lisa A. Leach, Defendant IN DIVORCE COUNTER - AFFIDAVIT UNDER ~330l (d) OF THE DIVORCE CODE 1. Check either (a) or (b) : "1- (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): _ (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b) : _ (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, divisions of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. , ." I verify that the statements made in this counter-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 falsifications to authorities. Date: ~ ICj \0\ v ~~'-MCAGh Lisa A. Leach NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER - AFFIDA VIT. ~t-- --------- () N :~: ) ..;:: ~ "\:, j ~( r:--; :"~ ~-,:) t,) -; 1 Ii , . .z:-