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HomeMy WebLinkAbout06-1057 . v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.: D{p- f6S1 {t~~L ~82-L DWIGHT W. LEATHERMAN, Plaintiff CHARLENE A. LEATHERMAN, 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. Vou 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 V ou 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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. Court Administrator Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6100 v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.: O~-/6!;1 G'uL/~ CIVIL ACTION - LAW DWIGHT W. LEATHERMAN, Plaintiff CHARLENE A. LEATHERMAN, Defendant IN DIVORCE COMPLAINT IN DIVORCE L Plaintiff is Dwight W. Leatherman. who currently resides at 430 Brian Court, Mechanicsburg, Cumberland County, Pennsylvania, 2, Defendant is Charlene A. Leatherman, who currently resides at 1130 Belmont Road, Gettysburg. Adams County, Pennsylvania, 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing ofthis Complaint. 4. The Plaintiff and Defendant were married on September 10. 1961. 5. There have been no prior actions of divorce or tor annulment between the parties. 6, Divorce is sought pursuant to the provisions of the Divorce Code. Sections 3301 (c). and 3301(d). in that: a. The marriage is irretrievably broke. 7, 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 such counseling, 8. Plaintiff does not request counseling, pursuant to SS330l(c) and 3301(d) of the Divorce Code. 9. The Plaintiff in this action is not a member of the Armed forces. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce, Date";- ,/ <c/' O~; Respectfully submitted, / ,.?7;;' /~) / , / By: drew H. haw, ,S-quire Sup. Ct. 1D No. 87371 61 W. Louther St. Carlisle, PA 17013 (717) 249.1177 Attorney for Plaintiff . VERIFICATION I, Dwight W. Leatherman, verify that the statements made in this petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. S 4904 relating to unsworn falsification to authorities, Date: ~ I,J. I f tJ ?> % dlJJ6J' ~. / . " /1 ;' i ~ uJ. nY:/-~ Dwight W. Leath'erman __I \.:) ~ /'oJ ]<.. -CJ \\:. \\- \> ~ ~ ~ f. ~ -:cJ -:t F 1- .~. ) j"",'" ::"~\ -,-\ \ ,,((;) ("!::: ~- . . ... DWIGHT W. LEATHERMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 06-1057 CHARLENE A. LEATHERMAN, Defendant CIVIL ACTION - LAW IN DIVORCE PROOF OF SERVICE I, Andrew H. Shaw, Counsel for the Plaintiff, Dwight W. Leatherman, hereby certify that a true and correct copy of the Divorce Complaint in the above captioned case was served upon Defendant via First Class Mail on March 6, 2006, A copy of the Acceptance of Service is attached, Date: j.g"O(~ /' 0\ lA Andrew H. Sfi w, Esquire Counsel for Plaintiff PA Sup, Ct,1D Num. 87371 61 W. Louther St. Carlisle. PA l7013 717-249-1392 . DWIGHT W. LEATHERMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. No.: 06-1057 CHARLENE A. LEATHERMAN, Defendant CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE !, Charlene A. Leatherman, hereby accept service of the Divorce Complaint. Date: J~). ~ ,'J., 0010 i ,,' , ' \.." 1__ IN THE COURT OF COMMON PLEAS DWIGHT W. LEATHERMAN, CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL DIVISION CHARLENE A. LEATHERMAN NO. 06-1057 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) ~ta)(t}c:fIX~X (Strike out inapplicable section), 2. Date and manner of service of the complaint: March 6, 2006; Dei. accepted servi 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 6-5-06 ; by defendant 6-5-06 (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: )\Tone. 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: 6-19-06 Date defendant's Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: 6-19-06 ~~ Attorneyfor~ff/all 11 I "', = \:.-.:::' c,.-. 1.0 r::, "'.., DWIGHT W. LEATHERMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 06-1057 CHARLENE A. LEATHERMAN, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT L A complaint in divorce under ~ 3301 (c) of the Divorce Code was filed on February 22, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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 false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. Dated: is. ~ 5- 00 t W. Leatherman, Plaintiff o r-~ ~~., r-.> = <:=..::> CT' <- ~::: ",,"C- o -n --l ::r::-n fl1p -orc ~.--)O ':~~ ~~-~ .'2(") ~:srrl ::':".:1, db '< I.D ::'2 ...."" r:-~ <.D DWIGHT W. LEATHERMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 06-1057 CHARLENE A. LEATHERMAN, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under 93301 (c) of the Divorce Code was filed on February 22, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I veritY 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. 9 4904 relating to unsworn falsification to authorities. Dated: 6 ~ .(v() 0 ~~ Char lie A. Lea rman, Defendant "'> = c:..:J ~ C) ""71 3"! n1:r.i r- "'"'D r.. ~-:~2 r;: '-1~~,1 - -~.~ (;,~~ --':,:"Ti ~"";( j::>- '-r-: :< '- S_::~ UJ :::: - N \0 DWIGHT W. LEATHERMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 06-1057 CHARLENE A. LEATHERMAN, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. I consent to the 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 in 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: ~ - {'~ 0 c.. ~:. n r~~ '" C~ ''::-::::1 c;:r. o -n ::;:J fA:!.] ,- ~R8 :~1(~; c.... ~i'i I..D ~ " ,:_5~~~ .~ .'::::': ~:D .-< ~ I..D DWIGHT W. LEATHERMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 06-1057 CHARLENE A. LEATHERMAN, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(0 OF THE DIVORCE CODE 1. I consent to the 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! 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: l,~ ~v 0 " /' ~O~ .n,V. ~?(] C lene A. Lea rman, Defendant Q ,_. "", = g:~ o -11 '-4 ~ ;:1'1:0 e- n""; r-; "( C) l.i., i:j ~':; (Sh-e; ~~ .< c. cD l'.' L') . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . PENNA. . STATE OF DWIGHT W. LEATHERMAN No. 06-1057 VERSUS P.lfART'F.N'R A T,RA'1'HRRMAN . DECREE IN DIVORCE . . . . . . . . . . . . ~ Z1 ~b, AND NOW, . DECREED THAT DWIGHT W. LEATHERMAN AND CHARLENE A. LEATHERMAN . ARE DIVORCED FROM THE BONDS OF MATRIMONY, . . . . . IT IS ORDERED AND . , PLAI NTI FF, , DEFENDANT, . . 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. . AmsftA!!J!$, By TH . . . . . . . . . . J. . . . PROTHONOTARY . _~.? ~ '?!''''' 'R L~-" C""fP ~ % ~ 1<41-n; ~N" ., . . , ) / . ...... _'" ..' . ... So.. ... 1>.. ~ ' . . .