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WILLIAM E. LEONARD, I IN TilE COURT OF COMMON PLEAS OF
plaint if f I CUMBERLAND COUNTY, PENNSYLVANIA
I
VS, I CIVIL ACTION - LAW
I
I NO, 95- ~(r ( I CIVIL
DEBRA L, LEONARD, I
Defendant I 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,
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 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 counseling. A list
of marriage counselors is available in the Office of the Prothonotary at
the Cumberland County Courthouse, Carlisle, PA 17013,
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYERIS FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, yOU
MAY LOSE THE RIGHT TO CLAIM I\NY OF THEM.
YOU SIIOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPIIONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GE'r LEGAL HELP.
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
ONE COURTHOUSE SQUARE
CARLISLE, PA 17013
Telephonel (717)240-6200
WILLIAM E, LEONARD,
Plaintiff
IN TilE COURT OF COMMON PLEAS OF
CUMBERLANU COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
VS,
DEBRA L, LEONARD,
Defendant
NO, 95-
IN DIVORCE
CIVIL
COMPLAINT UNDER SECTION 330l(C)
OF TilE DIVORCE CODE
COMES NOW, the Plaintiff, by Edward W. lIarker, his attorney
and respectfully represents as follows:
1. The Plaintiff, WILLIAM E. LEONARD, currently resides
at 7526 Wertzville Road, Carlisle, Pennsylvania, Cumberland
County, since April 1, 1994,
2, The Defendant is DEBRA L. LEONARD, who currently resides
at 7526 Wertzville Road, Carlisle, pennslvania, Cumberland
County, since April 1, 1994.
3, Plaintiff has been a bona fide resident of the Commonwealth
of Pennsylvania for at least six months immediately previous to the
filing of this Complaint,
4. The Plaintiff and Defendant were married on March 14, 1986
in Wellsburg, West Virginia,
5, There has not been a prior action of divorce or annul-
ments between the parties.
6. The marriage is irretrievably broken.