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Home My WebLink About05-5786 ~ vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. OS - S7?fD Cio ~ C--Tffl..-~ THOMAS LEE LEONARD Plaintiff, AMANDA LOUISE LEONARD, Defendant. CIVIL ACTION - LAW IN DIVORCE NOT ICE 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 action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. 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 STREET CARLISLE, PA 17013 THOMAS LEE LEONARD, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 05- 51:1(, AMANDA LOUISE LEONARD Defendant. CIVIL ACTION - LAW IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania 17013. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. THE LAW OFFICES OF SHANE B. KOPE BY: SHANE B. KOPE, ESQ. ATTORNEY 1.0.92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope@.comcast.net Attorney for Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ()~ - S'7Pf.,. {};(/~L ~8L~ CIVIL ACTION - LAW IN DIVORCE THOMAS LEE LEONARD Plaintiff, AMANDA LOUISE LEONARD, Defendant. COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, THOMAS LEE LEONARD, by and through his attorney, SHANE B. KOPE, ESQ., and makes the following Complaint in Divorce: 1. The Plaintiff is THOMAS LEE LEONARD, an adult individual who currently resides at 537 South Third Street, Lemoyne, Cumberland County, Pennsylvania, 17043. 2. The Defendant is AMANDA LOUISE LEONARD, an adult individual who currently resides at 537 South Third Street, Lemoyne, Cumberland County, Pennsylvania, 17043. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 16, 2000 in Cumberland County, Pennsylvania, 5. The Parties separated on May 27, 2005. 6. Neither the Plaintiff nor Defendant is in the military 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. 7. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 8. Plaintiff has been advised of the availability of marriage counseling and the right to request that the Court require the parties to participate in counseling. COUNT I REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 (e) OF THE DIVORCE CODE 9. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 10. The marriage of the parties is irretrievably broken. WHEREFORE, if both parties file affidavits consenting to a divorce after (90) ninety days have elapsed from the date of service of this Complaint, Plaintiff respectfully requests that the Court enter a Decree of Divorce pursuant to Section 3301 (c) of the Divorce Code. Dated: November 3,2005 Respectfully Submitted, THE LAW OFFICES OF SHANE B. KOPE ~~ ( .. ~~- - S,,- E," .1. ~.::, 'Slt'~, '"2. 5'~ ;~~7t.17~':'~ ~.'JPE ,.;.:.', :\i:.SE f:J' IIERIFICA1ION I, ThO"1<)~ lee leon~rd, I",e F'1!lint'ff in thiS 'fatter. h,Ml read the f,~rego"'9 Complail't I verify 'hat my avernents In th'T> Comp!!\i~t am true and cor:~ct ano t>asetl upon 'r.y p@rsonal KnOYliedge I understilnd tnst al'\Y f..\~e slat.me"'~ here,,) ",If! ,'r13cle SUb,leet to the penaltIes of 18 Pa CS 4904 relating \0 ul'lsworn fals,firal'ors to autnor,lles A I Dated II O~/~_ ~_,.",c/ ..--::.?'.~;../ e/',"/, ' ....___' M ~ _/ " ~*~o~rr:j -- ~n_H____ ,// RECEIVED NOV 0 3 2005 (:) ~ 7CJ - ~ ..a ~ () ~ ..... -- C> ~ t.v () ~ ~ C'? ...., r-- C';1 {~ i.._. Co':;' ~n ~ ..:....'..'1 ~ C~~j F':iS ~ -.:: I '.....I -' " (.,,,'; r'J ~D Ci --<.:. THE LAW OFFICES OF SHANE B. KOPE BY: SHANEB.KOPE,ESQ. ATTORNEY 1.0. 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope@comcast.net Attorney for Plaintiff THOMAS LEE LEONARD Plaintiff, :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 05-5786 AMANDA LOUISE LEONARD, Defendant. CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Shane B. Kope, do hereby certify that on this 11th day of November, 2005, I served a true and correct copy of the foregoing Complaint in Divorce via certified and regular U.S. First Class mail, postage prepaid, addressed as follows: Amanda Louise Leonard 537 South Third Street Lemoyne, PA 17043 THE LMI'.' OFFICQ OF SHANE B. KOPE ~~~d <S~a", B. Kop -, ." 1.0. 92zu7 - 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 (Attorney for Petitioner) r-:1 () C::' 1'1 c~:;) (;.J''' -'.... ~ - <.J'I .,.-:,~ ~>;>; - r,? .' e,) u:> THE LAW OFFICES OF SHANE B. KOPE BY: SHANE B. KOPE, ESQ. ATTORNEY 1.0.92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope@comcast.net Attorney for Plaintiff vs. :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-5786 THOMAS LEE LEONARD Plaintiff, AMANDA LOUISE LEONARD, Defendant. CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on November 7,2005. 2. A Certificate of Service for the complaint in divorce was filed on November 15, 2005. 3. The marriage of plaintiff and defendant is irretrievably broken and at least ninety (90) days have elapsed from the date of filing and service of the complaint. 4. 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 false statements herein are made subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date:~ , } "",,..,- >~ Tho 1~~G,8-'5lSC{ Social Security Number ----- THE LAW OFFICES OF SHANE B. KOPE BY: SHANE B. KOPE, ESQ. ATTORNEY 1.0. 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope(1ilcomcast net Attorney for Plaintiff THOMAS LEE LEONARD Plaintiff, :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 05-5786 AMANDA LOUISE LEONARD, Defendant. CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on November 7, 2005. 2. A Certificate of Service for the complaint in divorce was filed on November 15, 2005. 3. The marriage of plaintiff and defendant is irretrievably broken and at least ninety (90) days have elapsed from the date of filing and service of the complaint. 4. 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. ! 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: 317)00 I I d~k~ Amanda Louise Leonard ! {p3 (" ii' -to? z. 2- Social Security No. - " ___1 r ~ THE LAW OFFICES OF SHANE B. KOPE BY: SHANE B. KOPE, ESQ. ATTORNEY I.D. 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope@.comcast.net Attorney for Plaintiff vs. :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-5786 THOMAS LEE LEONARD Plaintiff, AMANDA LOUISE LEONARD, Defendant. CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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: :3 h) 00 I I 4>>V>4~ /~ Amanda Louise Leonard J (p 3 -CoiJ0)? 22. Social Security No. ,.;: .:;;':';. :\ __I --,~ TttomA5 UX LC60Ae.O IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL DIVISION f+fYlf11JOA UMS~ Ub~AeO NO. .;)..005 - '5 7'8 (0 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 ~3301 (c) S:l\l1(d)(1) =fllu E?i",--- ~ '-. (Strike out inapplicable section). Date and manner of service of the complaint: (2t; e.T I f1 &ro 5t:-e,vt^O W IJOvcmec<2- 19) 2005' 2. Lerr7!fL 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 ;;2/17,1 () 19 : by defendant 3/7/ tJb (b) (1) Date of execution of the affidavit required by ~3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: ~O tJli 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: (b) Date of plaintiff's Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: <5/3011)0 , I Date defendant's Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: , :s 11'-1) O(P , I "---- :X- ( S"?(U\L ~ Kp- J A orney for Plaintiff t Defendant ,...", ,'^) ~~: ;':Tl cr' I Cr; --; i~ (...; THE LAW OFFICES OF SHANE B. KOPE BY: SHANE B. KOPE, ESQ. ATTORNEY I.D. 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope@comcast.net Attorney for Plaintiff vs. :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-5786 THOMAS LEE LEONARD Plaintiff, AMANDA LOUISE LEONARD, Defendant. CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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: 3/1.7 /()0 . . as Lee Leonard /~5 -Cd-'5JS7 Social Security :-'. --\ T h~ I c;-; h) ;:_,,") ",'f.:+::+::+::+: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . + . . + + + . + + + + + + + + + + + + + + + + + + + + + + + . + + + + + + + + + + . . . . + + + + + . . . . + + + + + + + + + + + + + + . + + + :+'f:+ :+ + . . + + + + + + + . . + + . . + + + . + . + . + + . + . + + + . + :r.-- + . + + + + + + . + + :+: :+ :+: :+ :+: :+ :+ :+ :+: :+ :+ Of :+ :+ ++ :+::+::+: :+::+: :+:Of:+::+::+: :+:+:++ ++:+:+ :+ :++:+::+:+::+:+:+:+:+::+:+:+:+::+: :+::+:+::+::+::+::+::+:+:+: +:+:++:+::+::+:+:+::+: :+: + IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. I1fD fYl A S ) /3):; U:J:wAe.{) No. ()S - 57810 VERSUS 4mf}.V OA / J,)lH:-E UDAJA[2[) DECREE IN DIVORCE AND NOW'~ \\. DECREED THAT _Tl-tv/y)AS L.9; LEZ:lJUAQ.O ,~, IT IS ORDERED AND , PLAI NTI FF, AND Aff\.p.,,J 0 Pi (EVIL> PI eD , DEFENDANT, LtJu I Sf.. ARE DIVORCED FROM THE BONDS OF MATRIMONY. ... + + + . . + . + + + . + + + + + + + + + . + + + + + + + . . + + + . . . + + + + + + . + + . . + + + + . + . . . + BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; Uo~ BY T Arrmddi- :~ / ~ PROTHONOTARY . - +;+::+:+;+::+:+:+;+::+::+::+:+;+: ;+:'+';+::+'1':++ :+:+::+:+ Of' Of' + Of':+::tO :+::+: Of':+::+:+::+;+: ;+::+:+:+;+:;+: + Of':+::+: ,~? 2- /'{T'27>'11 ~;il, ~7 f/z"J .~ /fl' ~V p?n/ch.)- 7"(7 (e? -t" . 7rJ;:>tr "?v' ~5(' //'