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Home My WebLink About96-00399 1 "1 I I J1 I . I '?I I , J! / I f: ~ Jl j 0-1 0-1 0)1 P .1'1 " \ P " ~ " -" .... ..... c; .. ... ~ t; ~ q: ~ ~ M ~; r::: C> , UI!:-l .. :~ ,. qc~~ ('1 '1 ~ ': (....j (,J.- , .'.. ~ .... 01 ~.- :-J 8'- i: :n ,.... ....... ':~i; If.:>' ' . . i'l(J r- ~: -- , !l.1. u_ '0 ~.. . 0 ..J '" (..J ~ CARL R. LEED, JR., PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLANDCOUNTY, PENNSYLVANIA VS. : NO. 'Ji... J '? 't Cl~'L{' v,....... CIVIL ACTION - LAW SUSAN K. LEED, DEFENDANT 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 arc 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 divor~e 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, 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 ALA WYER 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 CARLISLE, PA 17013 (717) 240-6200 .:-.-. "':,,", .. CARL R. LEED, JR., PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA VS. NO. CIVIL ACTION - LAW SUSAN K. LEED, DEFENDANT IN DIVORCE COMPLAINT IN DIVORCE I. The Plaintiff, Carl R. Leed, Jr., is an adult individual who currently resides at 6280 Carlisle Pike, Lot 100, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Defendant, Susan K. Leed, is an adult individual whose current address is 5913 Tyler Drive, Harrisburg, Dauphin County, Pennsylvania 17112. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on August 13, 1977 in Mechanicsburg, Pennsylvania. 5. The panies separated on or about March 8, 1995. 6. Neither pany has instituted any prior action of divorce or annulment with regard to this marriage in this or any other jurisdiction. 7. There are two children by this marriage: Jason R. Leed, born April 9, 1982 and J\lstin C. Leed, born December 28, 1983. 8. Neither pany is a member of the Armed Forces of the United States of America. 9. The marriage is irretrievably broken. , , Page 2 10, The Plaintiff avers that he has been advised of the availability of counseling and that she may have the right to request that the Court require the parties to participate in counseling, Wherefore, the Plaintiff requests this Honorable Court to enter a Decree of Divorce in this mailer pursuant to 3301(c) or 3301(d) of the Divorce Code, Respectfully submiued, DeArmond & DeArmond .J~' ..I'oitl. B. UCt\.nnulld, Eliqltirr. Allomey ID Number 58878 2800 Market Street Camp Hill, PA 17011 (717) 730-9394 DATE: j /,~ I .1996 , /:.,.., ". ..... i,c....... .... '" 'Y...:~..' . VERIFICATION I, the undersigned, do hereby verifY that the statements made in the foregoing instrument are true and correct to the best of my knowledge, information and belief. I understand that statements herein are made subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. Gu Q R ld{~.Q ~.. \ Date: U \ \J \ q \ I \ ) , < '...'.r- CARL R. LEED, JR., PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 96.399 Civil Term : CIVIL ACTION - LAW SUSAN K. LEED, DEFENDANT : IN DIVORCE AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 25, 1996. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint. 3. I consent to the entry of a final Decree of Divorce. 4. I 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. 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. Section 4904 relating to unsworn falsification to authorities. Date: O.t 1~.0c14, N 1&, I ~1I}(7~~:(L , Susan K. Leed, Defendant . j , .- ~..-- ,~'{"::-";~.." .~'~~ DatelJf2iL'U4J N9i:J \);/JlT.~I- Susan K. Leed, efendant CARL R. LEED, JR., PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 96-399 Civil Term : CIVIL ACTION - LAW SUSAN K. LEED, DEFENDANT : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRV OF A DIVORCE DECREE UNDER SECTION 330Hc\ OF THE DIVORCE CODE I. 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 iff 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. -,