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Home My WebLink About02-1389 SAIDIS SHUFF, FLOWER & LINDSAY ATroRi~YS*AT,IAW 26 W. High Street Carlisle, PA Rebecca Leyon, Plaintiff Mo Dale Sharrah, Defendant : IN THE COURT Of COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : · NO. 2oo2-/ c w, TERM : : CIVIL ACTION - LAW : IN DIVORCE NOTICE 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 marriage counselling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Street, 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 LAVVYER 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 SAIDIS, SHUFF, FLOWER & LINDSAY Date: .2 -,2G .0-'~ 26 Wg,~F' High~treet Carlisle, PA 170'13 (717) 243-6222 Counsel for the Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY ATI~RI~YS~AT*LAW 26 W. High Street Carlisle, PA Rebecca Leyon, Plaintiff Dale Sharrah, Defendant : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002- CIVIL TERM : : CIVIL ACTION - LAW · IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE Date: 1. Plaintiff is Rebecca Leyon, who currently resides at 227 S. Pitt Street, Carlisle PA 17013, Cumberland County, Pennsylvania. 2. Defendant is Dale Sharrah, who currently resides at 1803-A Sterretts Gap Avenue, Carlisle PA 17013,Cumberland County, Pennsylvania. 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 May 18, 2001 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce. Respectfully submitted, SAIDIS, SHUFF, FLOW. ER & LINDSAY JohRf~C/J. Kop, e"cky, ~ uire 26 (~/~st High'Street Carlisle, PA 17013 (717) 243-6222 Counsel for the Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY ATfORI~YS~AT*iAW 26 W. High Street Carlisle, PA AFFIDAVIT I, Rebecca Leyon, being duly sworn according to law, depose and say: (1) I have been advised of the availability of marriage counselling and understand that I may request that the court require that my spouse and I participate in counselling. (2) I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. (3) Being so advised, I do not request that the court require that my spouse and I participate in counselling prior to a divorce decree being handed down by the court. 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. Dated: ,2.- ~ ~"' 0 ~ "~4~Re ec~ca Leyon, Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY ATrORNI/YS*AT*IAW 26 W. High Street Carlisle, PA 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.$. Section 4904, relating to unsworn falsification to authorities. '~ebecca Leyon, Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY ATTORi~*AT*LAW 26 W. High Street Carlisle, PA CERTIFICATE OF SERVICE On th,s · ~, (]ay of ~ , 2002, I, Johnna Kopecky, hereby certify that I served a true and correct copy of the foregoing Divorce Complaint via United States Mail, postage prepaid, addressed as follows: Dale Sharrah 1803-A Sterretts Gap Avenue Carlisle PA 17013 SAIDIS, SHUFF, FLOWER & LINDSAY I.D. #53147 26 West High Street Carlisle PA 17013 717.243.6222 Counsel for Plaintiff