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Home My WebLink About05-3463 McNEES WALLACE & NURICK LLC By: Debra Denison Cantor Attorney ID No. 66378 100 Pine Street Harrisburg, PA 17108-1166 (717) 232-8000 (717) 237-5300 facsimile dcantor@mwn.com Attorneys for Plaintiff ALAN R. LEHMAN, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05 ~ 34(,.3 ~ Tt.- REGINA D. LEHMAN, 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 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 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 Courthouse, One Courthouse Square, Carlisle, PA 17013. 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 - 2 - McNEES WALLACE & NURICK LLC By: Debra Denison Cantor Attorney 10 No. 66378 100 Pine Street Harrisburg, PA 17108-1166 (717) 232-8000 (717) 237-5300 facsimile dcantor@mwn.com Attorneys for Plaintiff ALAN R. LEHMAN, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05 ~ 3'1(.3 ~ fLu.-. REGINA D. LEHMAN, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Alan R. Lehman, who currently resides at 12 Sussex Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Regina D. Lehman, who currently resides at 12 Sussex Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on March 6, 2003, at Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. Plaintiff hereby waives his right to such counseling. 8. After 90 days have elapsed from the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 9. In the alternative, Plaintiff will file a 3301 (d) Affidavit and provide the appropriate Notices two years from the date of separation. WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce under Section 3301(c) or (d) of the Divorce Code. COUNT I Equitable Distribution 10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference. 11. Plaintiff and Defendant have acquired property, both real and personal, during their marriage. 12. The parties have acquired marital debt during their marriage. 13. Plaintiff and Defendant may be unable to resolve amicably the property issues in this matter. -2- WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property and debt. McNEES WALLACE & NURICK LLC Dated: 7/5/DS- Attorneys for Plaintiff - 3- VERIFICATION Subject to the penalties of 18 Pa, C.S.A. 94904 relating to unsworn falsification to authorities, I hereby certify that the facts set forth in the foregoing document are true and correct to the best of my information and belief. /J/~ /([L Alcm R. Lehman Dated: 26 0tr-G. 2a)/ r~ " " " c:: <;'- .....,.. ..L G .. -"" C) '" 0 = r- '''' " "'" ~ (- =r c::: 1"11:I1 n (-- 'Jtn , J , ~3$ P) ......, -" :;~:o _ :x: \....C) tsm .. .. ';;! J...l rv :0 - \i-. -0 --< l:) 0 c '" ~ d 0 t G t McNEES WALLACE & NURICK LLC By: Debra Denison Cantor Attorney ID No. 66378 100 Pine Street Harrisburg, PA 17108-1166 (717) 232-8000 (717) 237-5300 facsimile dcantor@mwn.com Attorneys for Plaintiff ALAN R. LEHMAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05;- 3l/W {!;u;{__'-r~ IN DIVORCE v. REGINA D. LEHMAN, Defendant AFFIDAVIT OF ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce on behalf of my client Regina D. Lehman, in the above-captioned matter. ~~(d-"' rylou Ma s Dated: r:,/l/65 I t . ,.. ",,'" u , -' g ~, -r:l-(~ D)t;., z( (/~[ kL t~~ Z -, -< ~ :5'\ ~ Co" ~ ~~ - ~9 c..n ~o -:t:::f\ 72-: ~ 5~ O~ ~ ~ .....I , IIIIl ....... ,,-~.."..-..,...,...,^,,^, .. McNEES WALLACE & NURICK LLC BY: DEBRA DENISON CANTOR, ESQUIRE Attorney 1.0. No. 66378 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 (717) 237-5300 facsimile dcantor@mwn.com ALAN R. LEHMAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-3463 Civil REGINA D. LEHMAN, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on July 7,2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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.SA Section 4904 relating to unsworn falsification to authorities. Aj,~ fJ- Alan R. Lehman Dated: J <j M uv b r<.' \,.,;') ---- - McNEES WALLACE & NURICK LLC BY: DEBRA DENISON CANTOR, ESQUIRE Attorney \.D. No. 66378 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 (717) 237-5300 facsimile dcantorailmwn.com Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ALAN R. LEHMAN, v. NO. 05-3463 Civil REGINA D. LEHMAN, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER !i3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand thai 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 thai 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 slatements 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. S4904 relating to unsworn falsification to authorities. 4~f- LL- Alan R. Lehman Dated: IV 1J -uzJ b . , r", 'I :<, ,,;,j SAIDIS, flOWER & LINDSAY ,l.nDRNEYs.Ar.lAW 26 West High Street Carlisle, PA ALAN R LEHMAN, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, . NO. 05-3463 REGINA D. LEHMAN, : CIVIL ACTION - LAW : IN DIVORCE Defendant DEFENDANT'S AFFIDAVIT OF CONSENT 1, A Complainlln Divorce under S 3301 (c) of the Divorce Code was filed July 7,2005. 2, The marriage of plaintiff and defendant is irrelrievably 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 in Divorce after service of notice of intention to request entry of the Decree. I verify lhat the statements made in this Affidavit are true and correct to the best of my knowledge, informalion and belief I understand thaI false slalements herein are made subject 10 the penalties of 18 Pa,C,S, 4904 relating to unsworn falsification to authorities, //c Date -/.?lj 0'c; , / , '~, '---:;/' /' o / ):<:. cC"_ Regina D, Lehman DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDERl\ 3301 (e) OF THE DIVORCE CODE I consenl to the entry of a final Decree of Divorce without nolice, 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 undersland that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of lhe Decree will be sent to me immediately after il is filed with the Prothonotary, I verify that the stalements made in thiS Affidavit are true and correcl to the best of my knowledge, information and belief 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~~& I e7) , Regina D. Lehma r' , ( --:,- (-) .:en ::::1 ~.,.) co ~., ) C', . . ALAN R. LEHMAN, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3463 CIVIL TERM Plaintiff v. REGINA D. LEHMAN, Defendant 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 a Divorce: 23 Pa, C.S. ~3301(c) - Mutual Consent _ Marriage irretrievably broken. 2. Date and Manner of Service of the Complaint: Date of service was July 20, 2005. The Complaint was served via First Class Mail on July 20, 2005. An Affidavit of Service was signed by Marylou Matas, Esquire on August 1, 2005 and filed with the Prothonotary on August 15, 2005. 3. Date of Execution of the Affidavit of Consent Required by Section 3301(c) of the Divorce Code: By Alan R. Lehman: February 14, 2006 By Regina D. Lehman: March 27, 2006 4. Related Claims Pending: All outstanding claims have been resolved by agreement. 5. Plaintiff's Waiver of Notice in ~3301(c) Divorce was signed on February 14, 2006 and filed on February 22, 2006. 6. Defendant's Waiver of Notice in S3301(c) Divorce was signed on March 27, Dated: 3/31/06 --- 2006 and filed on March 28, 2006. McNEES WALLACE & NURICK LLC ~:;(... r, enis antor . 0.663 100 Pine Street P. O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for Plaintiff, Alan R. Lehman - 2- - c~ '-> > c..) ~-(l 0 ---{ ~r I I; ( ]n__, C' r.~) .;) \,D -< .' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '. . . . ~~~~++++~+++.+.++++++.++++++.+++++~ . . . . . . . ++:+:+++ ++++:++ . .. n. :+::f.++ ... ... .n . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. ALAN R. LEHMAN No. 05-3463 PLAINTIFF VERSUS REGINA D. LEHMAN DEFENDANT DECREE IN DIVORCE AND NOW, /-l;2., '/ , 2 t?i:Jc. (" , . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . ++ :+ :+ :+' + :+ :+ :+ + + DECREED THAT ALAN R. LEHMAN AND REGINA D. LEHMAN ARE DIVORCED FROM THE BONDS OF MATRIMONY. CIVIL TERM , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT . . . . . . . ++++++++++++++++++++++~ NONE. /-J By THE COURT: --/ 7J!~ ~ ++++ . . . n. . :+::+ 't,,+>+,;+::+ '+ + Of.:+:+:+ 'f . ++++++:+: . PROTHONOTARY J. . . . . . . . . . . . . . . . . + . . . + + . . . . . . . . + . . . . . . + . . . , . . . . . . . . + . + . + . . . + . . + . . . . . . . . . . . . . . . . . . . . . . . . . i-V/'o?)lI r /. /'?tT~:d '7>1.,17 -?if L . h "r</ jr' -" /f?~ 4r? . I'll 10' L -;- . .-