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HomeMy WebLinkAbout03-3419GOLDBERG, KATZMAN & SHIPMAN, P,C. Heather L Pa~erno, Esquire Supreme Court ID #87506 320 Market Street, P.O. Box 1268 Harrisburg, PA 17108-1265 Attorneys for Plaintiff TIMOTHY S. LEHMAN, Plaintiff, ¥. KATHLEEN K. LEHMAN, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. OJ~3qlq : CIVIL ACTION - LAW : CUSTODY/VISITATION Present Residence: 1780 Weatherburn Drive, New Cumberland, Cumberland County, Pennsylvania COMPLAINT FOR CUSTODY 1. Plaintiffis TIMOTHY S. LEHMAN, whose current address is 2707 Woodspring Road, York, York County, Pennsylvania. 2. Defendant is KATHLEEN K. LEHMAN, whose current residential address is 1780 Weatherbum Drive, New Cumberland, Cumberland County, Pennsylvania. 3. Plaintiff is the Father, and Defendant is the Mother of the Children who are the subject of this action. 4. Plaintiff seeks shared legal and primary physical custody off Names: Brooke Margaret Lehman, Date of Birth: June 21, 2001 Brady David Andrew Lehman, Date of Birth: May 15,2001 The children were not bom out of wedlock. Brooke Lehman was adopted by the parties in October 2002. The adoption petition for Brady Lehman is currently pending in Cumberland County. 5. The Children presently reside with their mother, the Defendant herein, at 1780 Weatherbum Drive, New Cumberland, Cumberland County, Pennsylvania. From birth until present, the Children lived at 1780 Weatherbum Drive, New Cumberland County, Pennsylvania, with their mother and father. Plaintiff/Father left the marital residence on or about July 14, 2003. 6. Brooke Lehman was adopted by both Plaintiffand Defendant in Dauphin County in October 2002. Brady Lehman is presently in the process of being adopted by Plaintiff and Defendant in Cumberland County. 7. The best interests and permanent welfare of the Children will be served by granting the relief requested. 8. Plaintiff has participated as a party in the adoption proceeding regarding the Children in this Court and Dauphin County. 9. Plaintiff is temporarily residing with his brother, Mark Lehman, sister-in-law, Casey Lehman, and niece, Maya at 2707 Woodspfing Drive, York, York County, Pennsylvania. 10. Defendant resides with the Children alone at 1780 Weatherbum Drive, New Cumberland, Cumberland County, Pennsylvania. 2 WHEREFORE, Plaintiff respectfully requests that the court grant the parties shared legal custody, that Plaintiff be awarded primary physical custody of his children, Brook and Brady Lehman, and that Defendant be awarded temporary physical custody to be determined. Respectfully submitted, GOLDBE~)J~ KATZMAN & SHIPMAN, P.C. BYi //~eatheJ~r ~ern~~ 320 Market Street, Post Office Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorneys for Plaintiff 98456.1 VERIFICATION I verify that the statements contained in the foregoing COMPLAINT FOR CUSTODY are tree and correct to the best of my knowledge, information and belief. I tmderstand that false statements contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: ~ . TIMOTHY LEHMAN TIMOTHY S. LEHMAN PLAINTIFF V. KATHLEEN K. LEHMAN DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 03-3419 CIVIL ACTION LAW : : IN CUSTODY ORDER OF COURT AND NOW, Tuesday, August 05, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Thursday, August 28, 2003 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be l~resent at the conference. Failure to appear at the conference may provide grounds lbr entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Melissa P. Greevy, Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans w/th Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. 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. YOU SHOULD TAKE TItlS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 GOLDBERG, KATZMAN & SHIPMAN, P.C. Heather L. Paterno, Esquire Supreme Court ID #87506 320 Market Strut, P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Plaintiff TIMOTHY S. LEHMAN, IN THE COURT OF COMMON PLEAS Plaintiff, V. KATHLEEN K. LEHMAN, Defendant. CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3419 CIVIL ACTION - LAW CUSTODY/VIS [TATION PRAECIPE TO WITHDRAw COMPLAINT TO THE PROTHONOTARY: Please withdraw the Complaint for Custody filed on behalf of Timothy S. Lehman in this matter on July 18, 2003. Dated: August 7, 2003 By: Respectfully Submitted, P.O. Box 1268 Harrisburg, PA 17108 Attorneys for Plaint~ .I AUG 1 4 ~003 ~/ TIMOTHY S. LEHMAN, Plaintiff V. KATHLEEN K. LEHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3419 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER TO RELINQUISH JURISDICTION AND NOW, this 11m day of August, 2003, counsel for the Plaintiff having filed a Praecipe to Withdraw Complaint in this action, the Conciliator hereby relinquishes jurisdiction of the above captioned matter. :217022 FOR THE BY: ~ ~~l~Gr~squ~e ~stody Conciliator