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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 -TI a cz (Ji C n ? ll M l- 11 ^ Q (c 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 t ); ? _?O, om - J ? 73 e "% 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 r-? C? ??= ' ?; ? _? -- r_ty ?1.., ? ?:.i : -- ? ^? ?? ?"'; 6b .?+' `=j- . . y y, 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 ?1 ?..., ? c c,_ ? -r? - c ?? - ?- -- 3 ? •. ? -, .??. ?.?, r-Ch 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 C. .? t_.. !?,? ?. . j ? . .. ?? "° ?? f ;J`? N _ i c'1 _. _,. - - -. _ ? , ._.._ y? t't a ~' t? 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 C7 -.? T- 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 CTI Ott ..? -Ti N 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: + Z., 0410 + ' ATT T: ,J . cy + + , Im A j7n + PROTH TARY f IV ?r? G7 V o- ,j/ • 7f 6 7, L ,?/ 0/