HomeMy WebLinkAbout99-06845
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'.} IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY '
of
STATE OF
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LINDA LEHMAN ,
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J Plaintiff
KENDALL S. LEHMAN
Defendant •••
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DECREE IN
DIVORCE
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AND NOW . ............... ??.... , x?cx... it is ordered and
decreed that ... Linda ..Lehman ................................ plaintiff,
Kendall .S. Lehman
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; i°
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Prothonotary
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LINDA LEHMAN,
Plaintiff
V.
KENDALL S. LEHMAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6845 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information to the court for entry
of a Divorce Decree:
1. Ground for divorce: irretrievable breakdown under §3301(c) of the Divorce
Code.
2. Date and manner of service of the complaint: Certified mail on November
12, 1999.
3. Date of execution of the Affidavit of Consent required by §3301(c) of the
Divorce Code.
By Plaintiff: April 24, 2000 By Defendant: April 21, 2000
4. Related claims pending: None.
5. Date the Waiver of Notice in §3301(c) divorce was filed with the
Prothonotary:
By Plaintiff: April 24, 2000
RA, nPfanrinnt- Anril 91 9nno
Attorney for Plaintiff
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32 south Bedford Street -:
Cadlsle,iPA 17013,
(717) 245-9680
LINDA LEHMAN, :IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
V. :No. 99- (: CIVIL TERM
KENDALL S. LEHMAN, : CIVIL ACTION - LAW
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 are warned that if you fail to
do so, the case will proceed without you and a decree in divorce or annulment may 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 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 First Floor, Cumberland County
Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL
PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 A LAWYER 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
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
LINDA LEHMAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO.99- CIVIL TERM
KENDALL S. LEHMAN, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Linda Lehman, an adult individual, currently residing at 41 Run
Road, Lower Frankford Township, Cumberland County, Pennsylvania.
2. Defendant is Kendall S. Lehman, an adult individual, currently residing at
4 Fairview Street, Newville, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant are bonafide residents of the Commonwealth of
Pennsylvania and have been so for at least six months immediately previous to the filing
of this complaint.
4. Plaintiff and Defendant were married on October 4, 1980 in Shippensburg,
Cumberland County, Pennsylvania.
5. There have been no prior actions for divorce or annulment between the
parties.
6. The Defendant is not a member of the Armed Forces of the United States
of America, or its Allies.
7. The Plaintiff has been advised of the availability of counseling and the
right to request that the Court require the parties to participate in counseling. Knowing
this, the Plaintiff does not desire that the Court require the parties to participate in
counseling.
8. Plaintiff and Defendant are citizens of the United States of America.
9. The parties have lived separate and apart since May 1999 and continue to
live separate and apart as of the date of this Complaint.
10. The parties' marriage is irretrievably broken.
11. Plaintiff desires a divorce based upon the belief that Defendant will, after
ninety days from the date of the filing of this Complaint, consent to this divorce.
WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in
divorce.
11 2 C? y
Date
Respectfully Submitted
TURO LAW OFFICES
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Ron Turo, Esquire
32 South Bedford Street
Carlisle, PA 17013
(717) 245-9688
Attorney for Plaintiff
VERIFICATION
I verify that the statements made in the foregoing Divorce Complaint are true and
correct. I understand that false statements herein made are subject to the penalties of
Pa.C.S. §4904 relating to unsworn falsification to authorities.
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Date Linda Lehman
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LINDA LEHMAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99-6845 CIVIL TERM
KENDALL S. LEHMAN, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
AFFIDAVIT OF SERVICE
I HEREBY CERTIFY THAT I served a true and correct copy of the Divorce
Complaint filed in the above captioned case upon Kendall S. Lehman, by certified mail,
return receipt requested on November 12, 1999 addressed to:
Kendall S. Lehman
4 Fairview Street
Newville, PA 17241
and did thereafter receive same as evidenced by the attached Post Office receipt card
dated November 20, 1999.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT
OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE,
INFORMATION AND BELIEF, I UNDERSTAND THAT FALSE STATEMENTS HEREIN
MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904
RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES.
Date
TURD LAW OFFICES
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Ron Turo, Esquire
32 South Bedford Street
Carlisle, PA 17013
(717) 245-9688
Attorney for Plaintiff
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Lehman - Complaint Divorce
Z 452 476 363
US Postal Service
Receipt for Certified Mail
No Insurance Coverage Provided.
D. not ucn in, Intnrnatinnal htad /.4nn rnvan:nl
semi"Kendall S. Lehman
Street& Number
4 Fairview S
treet
Post Office, State. b ZIP Code
NeirlitVille.
Postage $ 55
Cethied Fee 1.40
Special Delivery Fee
Re anted Delivery Fee
Return Receipt Shoving t"
Whom d Date Delivered 1.25
ancient Recept 543wq Ill.
Dale, S Addressees Adcri ss
TOTAL Postage A Fees I s 3.20
Postmark or Date
November 12,
1999
SENDER: l also wish to receive the follow-
O Completo dcros 1 andor 2 for addbonal :cr..cos. ing services (for an extra fee):
Complete items 3.44. and 4b.
D Pnnt `ieur name and address m the Verse of this form So that Ke Can return pill,
wrd to you. 1. p Addressee's Address
? Allacn tn's form to the front of the mailpiece, or on the back if space does not
perms
2• ? Restricted Delivery
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O Wile WeNrn Fec"ipt Nogmsled'on Ilia mailp.ece below the erode number,
O The Return Receipt w3 snow m whom the amcle was delivered and the fall,
dotrvErad.
3. Article Addressed to: 4a. Article Number
Z 452 476 363
Kendall S. Lehman
4 Fairview Street
Newville, PA 17241
41b. Service Type
? Registered kCertilied
? Express Mail ? Insured
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xj Return Recent for Merchandise ?COD
7. Date of Delivery
r G,/'/??:Yv fee is paid)
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-IN DA LEHMAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v : NO. 99-6845 CIVIL TERM
KENDALL S. LEHMAN, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on
November 12, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of the filing of the Complaint.
3. 1 consent to the entry of the final Decree in Divorce after service of Notice
of Intention to request entry of the decree.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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.
4 1 ec- Linda Lehman
Date
LINDA LEHMAN,
Plaintiff
v.
KENDALL S. LEHMAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 991-6845 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
_WAIVER OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
§ 33010 OF THE DIVORCE CODE
1. 1 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 THE FOREGOING 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 Linda Lehman
.. ?
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LINDA LEHMAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-6845 CIVIL TERM
KENDALL S. LEHMAN, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under Section 3301(c) of the
Divorce Code was filed on November 12, 1999.
2. The marriage of plaintiff and defendant is irretrievably
broken and ninety days have elapsed from the date of filing and
service 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 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: April 2000
Kendall 'S. Lehman
Sworn to and subscribed before me
this day of Aril, 2000.
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NOTAFAAL flAL
BON9M L 00YLX WTAXY vusuc
6080 or CAALMP, Cl MUftANO COUNT'
wcomlmo"00""socrosesI> 301*
LINDA LEHMAN,
Plaintiff
V.
KENDALL S. LEHMAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6845 CIVIL TERM
CIVIL ACTION - LAW
IN 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. 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.
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. § 4904 relating to unsworn
falsification to authorities.
Date: y 7 / o 0 / ?/?
(Kendall S. Lehman
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