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HomeMy WebLinkAbout99-06845 t v ?f i ar W. Co; p tc,^•;e: c. :c• :c'_:_?'„°' ;°:^ s:• •v:• .:• ce• ;v, <s: s:• •:o: <s: ;..:a:,..W., -W, ts: •:e:• -% •:es •;e:...s•::•i1 '.} IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ' of STATE OF PENNA. t J`.?'1^Yl?.r ?f e LINDA LEHMAN , f ? a>. 99-6845 19 ++ e J Plaintiff KENDALL S. LEHMAN Defendant ••• t: DECREE IN DIVORCE i. yaoo 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° fe .......... ................................................. i! fly T1 % c ,, ,,-t- . nttcst: J. Prothonotary wow ±.?•: •'s;• Le> :e;• W. W. IV. -'.C. 'V- Le> •,e? ;o:? •;o:• -:s; ?:r; ?:o:? •:o:? :r :e;? ;o:? ?:r:? (ri _e:? ?:n ?:oi ;e;? •;e <o <o:• •:e>• .. / ? ?Ic?rc l.?f ?Njf 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 ? i - L ! C: a t -1 C:' :n 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 L' za ?v 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. l l ' 11"?7 I'Cill ?1 ttfJo ;In-"-1 1-1 - Date Linda Lehman ry T M ?r n ?J 7 1. r?J ?\v ?f O 1 ti n J I CL 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 l l/ Ron Turo, Esquire 32 South Bedford Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff N Cr, m a Q 0 0 rn Cl) E 0 m a 0 a re N d L c O m m E E °Y a 2 O T n 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 . 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 ` xj Return Recent for Merchandise ?COD 7. Date of Delivery r G,/'/??:Yv fee is paid) e(L llli 1994 1e25v5 99 o0:23 Y 2 N n 1 Y E IL rn N 0 0 till, Y c m F . _'?1 -_ ,;_ ?_? ?- ?? ;, ?-? ,=_? _ r,? tv ?_' L1 __ ' _1 ?.? (a ?) -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 .. ? -? 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. 0=?? 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 ;=