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Home My WebLink About05-2940KEVIN G. LEHMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2005- c294/6 CIVIL TERM ANGELA C. 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 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 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 Court House, 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 A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 KEVIN G. LEHMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2005- -291/8 CIVIL TERM ANGELA C. LEHMAN, • CIVIL ACTION-LAW Defendant IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is Kevin G. Lehman, an adult individual who currently resides at 10 Hidden Noll Road, Carlisle, Cumberland County, Pennsylvania 17013-9626. 2. Defendant is Angela C. Lehman, an adult individual who currently resides at 4736 Aldgate Green, Halethorpe, Baltimore County, Maryland 21227-1201. 3. Plaintiff and Defendant have been a bona fide residents in 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 October 18, 1991, in Lynchburg, Lynchburg City County, Virginia. COUNT I - DIVORCE 5. Plaintiff hereby incorporates by reference paragraphs 1 through 4 above. 6• There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. The Plaintiff has been advised of the availability of counseling and that he may have the right to request that the court require the parties to participate in Counseling. 9. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of he Plaintiff and against the Defendant. COUNT II-CUSTODY 10. Plaintiff hereby incorporates by reference paragraphs 1 through 9 above. 11. The Plaintiff is Kevin G. Lehman, an adult individual residing at 10 Hidden Noll Road, Carlisle, Cumberland County, Pennsylvania 17013-9626. 12. The Defendant is Angela C. Lehman, an adult individual residing at 4736 Aldgate Green, Halethorpe, Baltimore County, Maryland 21227-1201. 13. Plaintiff seeks custody of Michael J Lehman, Jr., born August 5, 1992. Powell, born April 12, 1991 and Kevin G. The children are presently in the custody of Defendant at 4736 Aldgate Green, Halethorpe, Baltimore County, Maryland 21227-1201. During the past five years, the children have resided with the following persons at the following addresses: Persons Residences Dates Angela C. Lehman Mother's Paramour Mother's Paramour's son Kevin G. Lehman Angela C. Lehman Kevin G. Lehman Angela C. Lehman 4736 Aldgate Green Halethorpe, Maryland 10 Hidden Noll Road Carlisle, Pennsylvania 233 Longs Gap Road Carlisle, Pennsylvania 5/25/2005 - Present 9/2003 - 5/25/05 5/2000 - 9/2003 The natural father of the children is Kevin G. Lehman, currently residing at 10 Hidden Noll Road, Carlisle, Cumberland County, Pennsylvania 17013-9626 He is married to the Defendant. The natural mother of the children is Angela C. Lehman, currently residing at 4736 Aldgate Green, Halethorpe, Baltimore County, Maryland 21227-1201. 14. plaintiff currently resides with the following persons: Names Relationship 15. The relationship of Defendant to the children is that of natural mother. Defendant currently resides with the following persons: Names Relationship Adult male Adult male's son Michael J. Powell Kevin G. Lehman, Jr. Paramour Paramour's son Son Son 16. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning the custody of the children in this or in any other Court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. She is married to the Plaintiff. The relationship of the Plaintiff to the children is that of natural father. The IT Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to intervene. WHEREFORE, Plaintiff requests your Honorable Court to grant him partial physical custody of the children. Respectfully submitted, Date: June 19 2005 O'BRIEN, BARIC & SCHERER Michael A. Scherer, Esquire I. D.# 61974 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff, Kevin G. Lehman maslDomesticlLeh man, Kevi nldivorce.comp KEVIN G. LEHMAN, Plaintiff V. ANGELA C. LEHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005- CIVIL TERM CIVIL ACTION-LAW IN DIVORCE VERIFICATION I verify that the statements made in this Complaint 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: June a 2005 .,- Kevin G. Lehman D c Q? cl) e •s4 ?c lC cJa om u a C?t? C ' Urn 217 co G w KEVIN G. LEHMAN, Plaintiff V. ANGELA C. LEHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-2940 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE ACCEPTANCE OF SERVICE: AND NOW, on this the /?. day of _, 2005, 1, Angela C. Lehman, Defendant, hereby accept service of the Divorce Complaint in the above action pursuant to Pa. R.C.P. 1920.4(e) and acknowledge receipt of a true and attested copy of said Complaint. 'Angela C. Lehman C1 ? ?a ? T cr+ ? c- -L -n "' ''?: ?'? r.? ?,?, ? ?' , O ? , ?Lr ?? t f^J GJ Curtis R. Long Prothonotary office of the protbonotarp CumberYanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 05 -.2 Qqa CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2 BY THE COURT, CURTIS R. LONG PROTHONOTARY nn, rmirthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573