HomeMy WebLinkAbout06-6597(
Suzanne Spencer Abel, Esq.
22 East Street, #6
Mt. Holly Springs, PA 17065
(717) 829-3206
spencer abel_esq@fastmail.fm
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LEZLI JUNE LEAR,
Plaintiff
v
JAMES PAUL LEAR,
Defendant
No. 2006 45q? CIVIL
CIVIL ACTION - LAW
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 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
AVISO
USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de
las demandas que se presentan mcis adelante en las siguientes p6ginas, debe tomar
acci6n dentro de los pr6ximos veinte (20) dias despu6s de la notificaci6n de esta
Demanda y Aviso radicando personalmente o por medio de un abogado una
comparecencia escrita y radicando en la Corte por escrito sus defensas de, y
objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que
si usted falla de tomar acci6n como se describe anteriormente, el caso puede proceder
sin usted y un fallo por cualquier suma de dinero reclamada en la demands o cualquier
otra reclamaci6n o remedio solicitado por el demandante puede ser dictado en contra
suya por la Corte sin mds aviso adicional. Usted puede perder dinero o propiedad u
otros derechos importantes para usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO IMMEDIATAMENTE.
SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA.
ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO
CONSEGUIR UN ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES
POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE
AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A
PERSONAS QUE CUALIFICAN.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Dauphin County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities
and reasonable accommodations available to disabled individuals having business
before the court, please contact our office at 717-255-2796. 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.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LEZLI JUNE LEAR,
Plaintiff
No. 2006 - loSR? CIVIL
v
JAMES PAUL LEAR,
Defendant
CIVIL ACTION - LAW
DIVORCE
PURSUANT TO 23 P.S. §3301(c), OR §3301(co of the DIVORCE CODE
COUNT 1 - COMPLAINT FOR DIVORCE
AND NOW, this day of November, 2006, comes Plaintiff, Lezli June
Lear, by and through her attorney, Suzanne Spencer Abel, Esq., and who files the
following Complaint for Divorce and Custody, and in support thereof avers as follows:
1. The Plaintiff is Lezli June Lear, residing at 706 Lisburn Road, Camp Hill,
Pennsylvania 17011-7424, Cumberland County, since 2005.
2. The Defendant is James Paul Lear, residing at 931 31st Street, Camp Hill,
Pennsylvania 17011-5809, Cumberland County, since October 21, 2006, when
Defendant permanently abandoned the marital residence to live with the woman
he began dating in September 2006.
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. Plaintiff and Defendant were married on February 1, 2003, in Mechanicsburg
Pennsylvania, Cumberland County, and separated on September 23, 2006,
when Defendant moved out of the marital residence and into his girlfriend's
house. The parties have no minor children from the marriage.
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 defendant may
have the right to request that the court require the parties to participate in
counseling.
8. Plaintiff requests the court to enter a decree of divorce.
COUNT 2 - COMPLAINT FOR EQUITABLE DISTRIBUTION
9. Paragraphs 1 through 8 are incorporated herein by reference.
10. The parties own real property that qualifies as marital property, subject to
equitable distribution.
11. Plaintiff has incurred substantial legal fees, costs, and expenses to obtain the
related PFA, docketed at # 06-6394 Civil Term, Cumberland County,
Pennsylvania as well as the instant Complaint for Divorce, and does not have the
means to pay such fees, costs and expenses absent an order for Alimony,
pending resolution of the parties' equitable distribution.
12. Plaintiff requests the court to enter an order equitably distributing the marital
assets, and awarding counsel fees, costs, and expenses.
Page 2
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a
Decree of Divorce, and an Order equitably distributing the marital assets, awarding
alimony, counsel fees, costs, and expenses, along with any other relief as permitted by
statute.
Respectfully submitted,
Suzanne Spencer Abel, Attorney at Law
C'
I W W'5?1 P Ott
uza Spen Abel, Esq.
Attor&wy ID #202443
22 East Street, #6
Mt Holly Springs, PA 17065
(717) 829-3206
spencer abel_esq@fastmail.fm
Counsel for Plaintiff, Lezli June Lear
Page 3
VERIFICATION
I VERIFY that 1 have personal knowledge of all facts not of record set forth in the
foregoing pleading, and that such statements are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to
authorities.
Date:
CERTIFICATE OF SERVICE
1 certify that, concurrent with filing the foregoing Complaint for Divorce, I am this
day serving a copy of same by regular, First Class U.S. Mail to the following:
Lesley Beam, Esq.
Kope Law & Associates, LLC
Counsel for James Lear, Defendant
4660 Trindle Road, Suite 201
Camp Hill, PA 17011
James Lear, Defendant
931 31 st Street
Camp Hill, PA 17011-5809
Date: I 1
'?IAI'ud?aa h
Suzan Sp r Abel
22 Ea Street, #6
Mt. Holly Springs, PA 17065
(717) 829-3206
spencer abet esq@fastmail.fm
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KOPE & ASSOCIATES, LLC
BY: LESLEY J. BEAM, ESQUIRE
ATTORNEY I.D. 91175
4660 Trindle Road, Suite 201
Camp Hill, PA 17011
(717) 761-7573
Ibeam(D-kopelaw.com
Attorney for Defendant
LEZLI JUNE LEAR : IN THE COURT OF COMMON PLEAS
Plaintiff, : CUMBERLAND COUNTY, PA
vs. : NO. 2006-6597
JAMES PAUL LEAR, CIVIL ACTION - LAW
Defendant. IN DIVORCE
NOTICE TO PLEAD
To: Lezli June Lear
Suzanne Spencer Abel, Esquire
22 East Street, #6
Mt. Holly Springs, PA 17065
You are hereby notified to file a written response to the enclosed Answer and
Counterclaim within twenty (20) days from service hereof or a judgment may be entered
against you.
KOPE & ASSQCIATES
By:
Date: January 18, 2007
KOPE & ASSOCIATES, LLC
BY: LESLEY J. BEAM, ESQUIRE
ATTORNEY I.D. 91175
4660 Trindle Road, Suite 201
Camp Hill, PA 17011
(717) 761-7573
Ibeam(a-kopelaw.com
LEZLI JUNE LEAR
Plaintiff,
vs.
JAMES PAUL LEAR,
Defendant.
Attorney for Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 2006-6597
CIVIL ACTION - LAW
IN DIVORCE
DEFENDANT'S ANSWER TO COMPLAINT IN DIVORCE
AND COUNTERCLAIM
AND NOW, comes the Defendant, James Paul Lear, by and through his attorney,
Lesley J. Beam, Esquire, and files the following Answer to Complaint in Divorce under
sections 3301(c), and 3301(d) of the Divorce Code and Counterclaim, and in support
thereof avers as follows:
COUNT 1 - Complaint in Divorce
1. Denied in part, admitted in part. It is admitted that Plaintiff is Lezli June
Lear. It is denied that Plaintiff is currently residing at 706 Lisburn Road in Camp Hill. It
is unknown where Plaintiff is residing at present.
2. Denied in part, admitted in part. It is admitted that Defendant is James
Paul Lear and that he currently resides at 931 31St Street, Camp Hill, Cumberland
County, Pennsylvania. It is denied that Defendant has lived there since October 21,
2006, and it is denied that Defendant permanently abandoned the marital residence to
live with another woman.
3. Admitted.
4. Denied in part; admitted in part. It is admitted that Plaintiff and Defendant
have no minor children from the marriage. It is denied that Plaintiff and Defendant were
married on February 1, 2003; to the contrary, Plaintiff and Defendant were married on
February 2, 2001, in Mechanicsburg, Cumberland County, Pennsylvania. It is further
denied that Plaintiff and Defendant separated on September 23, 2006, or that
Defendant moved out of the marital residence on that date and into his alleged
girlfriend's house. To the contrary, Plaintiff and Defendant did not separate until
October 27, 2006, when the Plaintiff wanted Defendant to leave the residence, and
called the police to force him to vacate the home. When Plaintiff was informed that
Defendant had the right to be present in his own home, Plaintiff fabricated PFA charges,
thus barring Defendant from the marital residence. Said PFA complaint was filed
November 3, 2006.
5. Admitted.
6. Admitted.
7. No answer is required.
8. No answer is required.
COUNT 2 - Complaint for Equitable Distribution
9. No answer is required.
10. Admitted.
11. Denied. After reasonable investigation, Defendants is without knowledge
or information sufficient to form a belief as to the truth of this averment and, therefore,
such allegations are deemed to be denied and strict proof thereof is demanded.
12. No answer is required.
COUNTERCLAIM
COUNT III
REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 (c) OF THE
DIVORCE CODE
13. The prior paragraphs of this Complaint are incorporated herein by
reference as though set forth in full.
14. 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, Defendant
respectfully requests that the Court enter a Decree of Divorce pursuant to Section 3301
(c) of the Divorce Code.
COUNT IV
REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 (d) OF THE
DIVORCE CODE
15. The prior paragraphs of this Complaint are incorporated herein by
reference as though set forth in full.
16. The marriage of the parties is irretrievably broken.
17. The parties are living separate and apart and at the appropriate time
Defendant will submit an affidavit alleging that the Parties have lived separate and apart
for at least two (2) years as Specified in Section 3301 (d) of the Divorce Code.
WHEREFORE, Defendant respectfully requests that the Court enter a Decree of
Divorce pursuant to Section 3301 (d) of the Divorce Code.
COUNT IV
REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER
SECTION 3502 (a) OF THE DIVORCE CODE
18. The prior paragraphs of this Complaint are incorporated herein by
reference as though set forth in full.
19. Plaintiff and Defendant have acquired marital property as defined by the
Divorce Code, which is subject to equitable distribution pursuant to Section 3502 (a) of
the Divorce Code.
20. Plaintiff and Defendant have been unable to agree to the equitable
distribution of said property, as of the date of filing of this Complaint.
21. After the date of separation, Plaintiff caused and/or failed to prevent the
causing of significant damage to the marital residence. Plaintiff failed to protect the
value of said residence, the primary marital asset in this matter. Defendant has incurred
significant cost in both time and labor to repair the damage done to the residence and
its fixtures. To that end, Defendant has also been solely responsible for all of the bills
incumbent with said residence
22. Defendant requests that the Court equitably divide, distribute, or assign
the marital property between the parties.
23. Defendant further requests that this Court credit Defendant with all of the
expenses and payments needed to regain and maintain the value of the marital
residence, the primary asset of the parties.
WHEREFORE, Defendant respectfully requests that the Court enter an order of
equitable distribution of marital property pursuant to Section 3502 (a) of the Divorce
Code.
Respectfully submitted:
KOPE & ASSOCIATES, LLC
C i
Date: toy By:
d&--
sley J am, Esquire
d e Road, Suite 201
4600 T411
Camp il, PA 17011
(717) 761-7573
I.D. No. 91175
VERIFICATION
I, James Paul Lear, the Defendant in this matter, have read the foregoing Answer
and Counterclaim. I verify that my averments in this Counterclaim are true and correct
and based upon my personal knowledge. I understand that any false statements herein
are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsifications
to authorities.
Dated:
James Paul Lear
KOPE & ASSOCIATES, LLC
BY: LESLEY J. BEAM, ESQUIRE
ATTORNEY I.D. 91175
4660 Trindle Road, Suite 201
Camp Hill, PA 17011
(717) 761-7573
(beam@kopelaw.com
Attorney for Defendant
LEZLI JUNE LEAR : IN THE COURT OF COMMON PLEAS
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
vs. NO. 2006-6597
JAMES PAUL LEAR, CIVIL ACTION - LAW
Defendant. IN DIVORCE
CERTIFICATE OF SERVICE
I, Lesley J. Beam, do hereby certify that on this 18th day of January, 2007, 1
served a true and correct copy of the foregoing Answer to Complaint in Divorce and
Counterclaim via regular U.S. First Class mail, postage prepaid, addressed as follows:
Suzanne Spencer Abel, Esquire
22 East Street, #6
Mt. Holly Springs, PA 17065
TES, LLC
By:
Ues1. 06am, Esq.
I.D. 91175
4660 rindle Road, Suite 201
Camp Hill, PA 17011
(717) 761-7573
Attorney for Defendant
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LEZLI JUNE LEAR,
Plaintiff
V
JAMES PAUL LEAR,
Defendant
No. 2006 - 6597
CIVIL ACTION - LAW
DIVORCE
PRAECIPE TO FILE ACCEPTANCE OF SERVICE
To the Prothonotary:
Kindly file the attached Acceptance of Service for this matter.
Respectfully submitted,
Neuharth Law Offices
q)I'A 31 it o '??"V. ,i it 1 4 1/ L U/
Suz e Spender Abel, Esquire
Id. No. 202443
Neuharth Law Offices
P.O. Box 359
Chambersburg, PA 17201
Phone: (717) 264-2939
Fax: (717) 263-2928
f ••
LEZLI JUNE LEAR, IN THE COURT OF COMMON PLEAS
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
vs. : NO. 2006-6597
JAMES PAUL LEAR, CIVIL ACTION - LAW
Defendant. IN DIVORCE
ACCEPTANCE OF SERVICE
I, Lesley J. Beam, Esquire, counsel of record for James Paul Lear in the above-
captioned action, hereby accept service of the Divorce Complaint under §§ 3301 (c) and
(d) of the Divorce Code, filed in the above-captioned matter, served by first class mail
on the date indicated below. I certify that I am authorized to accept service for the
Defendant.
Date:
Lesley ./Beam, Esquire
Kope & Associates, LLC
ATTORNEY I.D. 91175
4660 Trindle Road, Suite 201
Camp Hill, PA 17011
(717) 761-7573
Counsel for Defendant
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LEZLI JUNE LEAR,
Plaintiff No. 2006 - 6597
v
CIVIL ACTION - LAW
JAMES PAUL LEAR,
Defendant DIVORCE
PRAECIPE TO FILE PLAINTIFF'S WAIVER OF NOTICE
To the Prothonotary:
Kindly file the attached Plaintiff's Waiver of Notice for this matter.
Respectfully submitted,
Neuharth Law Offices
guz e Spencef Abel, Esquire
Id. o. 202443
Neuharth Law Offices
P.O. Box 359
Chambersburg, PA 17201
Phone: (717) 264-2939
Fax: (717) 263-2928
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LEZLI JUNE LEAR,
Plaintiff
v
JAMES PAUL LEAR,
Defendant
No. 2006 - 06597
CIVIL ACTION - LAW
DIVORCE
WAIVER OF N4OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER §3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. 1 understand that I may lose rights concerning alimony, division of properly,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. 1 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.
Date: cT D
-/ If 0- 1
Le A J. Lear, Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LEW JUNE LEAR,
Plaintiff
v
JAMES PAUL LEAR,
Defendant
No. 2006 - 06597
CIVIL ACTION - LAW
DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under §3301(c) of the Divorce Code was fled on
November 15, 2006.
2. The marriage of plaintiff and defendant is irretrievable 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 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: Le i J. Lear, Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LEZLI JUNE LEAR,
Plaintiff
No. 2006 - 06597
v
JAMES PAUL LEAR,
Defendant
CIVIL ACTION - LAW
DIVORCE
WAIVER OF NO-? OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER §3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. 1 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. 1 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.
Date: c? D
Le i J. Lear, Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LEW JUNE LEAR, :
Plaintiff No. 2006 - 06597
v
CIVIL ACTION - LAW
JAMES PAUL LEAR,
Defendant DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under §3301(c) of the Divorce Code was filed on
November 15, 2006.
2. The marriage of plaintiff and defendant is irretrievable 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 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 unswom falsification to authorities.
Date:
e?7 61 Le i J. Lear, Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LEZLI JUNE LEAR,
Plaintiff
v
JAMES PAUL LEAR,
Defendant
No. 2006 - 06597
CIVIL ACTION - LAW
DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Kindly transmit the record, together with the following information, to the Court for
entry of a divorce decree:
1.
2
Ground for divorce: irretrievable breakdown under §3301(C) of the Divorce Code.
Date and Manner of service of Complaint: November 20, 2007, Affidavit of Service
from Defendant's Counsel of Record.
3
Date of Execution of the Affidavit of Consent required by §3301(C) of the Divorce Code:
By Plaintiff. April 25, 2007; By Defendant: September 27, 2007
4.
5.
Related claims pending: None.
Date Plaintiff's Waiver of Notice in §3301(C) was filed with the Prothonotary: October
1, 2007. Date Defendant's Waiver of Notice in §3301(C) was filed with the
Prothonotary: October ;, 2007.
Respectfully submitted,
Neuharth Law Offices
lam.
Suz Spencer bel, Esquire
Id. N&/202443
Neuharth Law Offices
232 Lincoln Way East
Chambersburg, PA 17201
Phone: (717) 264-2939
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LEZLI JUNE LEAR,
Plaintiff No. 2006 - 06597
v
CIVIL ACTION - LAW
JAMES PAUL LEAR,
Defendant DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under §3301(c) of the Divorce Code was filed on
November 15, 2006.
2. The marriage of plaintiff and defendant is irretrievable 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 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: '/,/,t j: . /o.7 ao_,.,.,, rI
James P. Lear, Defendant
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LEZLI JUNE LEAR, :
Plaintiff No. 2006 - 06597
v
CIVIL ACTION - LAW
JAMES PAUL LEAR,
Defendant
DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER §3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. 1 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. 1 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.
Date: Flo ? -
James P. Lear, Defendant
a
U
+ +
IN THE COURT OF COMMON PLEAS
+
OF CUMBERLAND COUNTY
+
+ STATE OF PENNA.
+
+ LEZLI JUNE LEAR
, 2006 - 6597 +
+
Plaintiff No.
+ +
+ VERSUS +
+ JAMES PAUL LEAR,
+ +
+
Defendant
+
+
+
+
DECREE IN
+
+
+ DIVORCE
+ +
+
+ +
+
+
+
AND NOW, OL$-b 6? /? IT IS ORDERED AND
+
+
+
Lezli June Lear
DECREED THAT PLAINTIFF, +
+ James Paul Lear +
+ AND 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 +
+
+
+ By THE C U RT:
+
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0410
+ '
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cy
+
+ , Im A j7n
+
PROTH TARY
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