HomeMy WebLinkAbout05-3544PAULA ANN LEHMER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
THOMAS DAVID LEHMER, : NO. OS- 359/ CIVIL TERM
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 of divorce or annulment may be entered against you for
any 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 Cumberland County Courthouse, Carlisle, Cumberland County,
Pennsylvania, 17013.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, 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.
Pennsylvania Lawyer Referral Service
Pennsylvania Bar Association
P.O. Box 186
Harrisburg, PA 17108
(800) 692-7375
PAULA ANN LEHMER,
Plaintiff
V.
THOMAS DAVID LEHMER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. C"f--J,5s4Y CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE
NO FAULT
Plaintiff is Paula Ann Lehmer, an adult individual currently residing at 915 Alison
Avenue, Mechanicsburg, Cumberland County, Pennsylvania.
2. Defendant is Thomas David Lehmer, an adult individual currently residing at 534
Brighton Place, Mechanicsburg, Cumberland County, Pennsylvania.
3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so
for at least six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on April 6, 2002, in Cumberland County,
Pennsylvania.
5. There have been no other prior actions for divorce or annulment between the parties.
6. Neither the Plaintiff nor the Defendant are members of the United States Armed
Forces or its Allies.
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, 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' marriage is irretrievably broken.
10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90)
days from the date of service of this Complaint, consent to this divorce.
WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23
P.S. Section 3301 (c) of the Domestic Relations Code.
Respectfully submitted,
v
L t? 6 n --
Hannah Herman-Snyder, Esqui e
Attorney for Plaintiff
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
VERIFICATION
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section
4904, relating to unsworn falsifications to authorities.
DATE: bS- 1&LlI'""' i(tJmt?
Paula Ann Lehmer, Plaintiff
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PAULA A. LEHMER : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
, -3svy
THOMAS D. LEHMER, NO. 05-t+'' S CIVIL TERM
Defendant : IN DIVORCE
AFFIDAVIT OF SERVICE
AND NOW, this ?):)- day of July, 2005, comes Hannah Herman-Snyder,
Esquire, counsel of record for Plaintiff, and states that a true and attested copy of a
Complaint in Divorce was sent to Defendant, Thomas D. Lehmer, at his address of 534
Brighton Place, Mechanicsburg, Pennsylvania by certified mail, return receipt requested.
A copy of said receipt is attached hereto indicating service was made on July 22, 2005.
%c.ry L W
Hannah Herman-Snyder, Esqu re
Attorney for Plaintiff
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717) 243-55511
(800)347-5557,
Sworn and subscribed to
before me this „171'3' day
of 2005
NOTARY PU3LIC
NOTARIAL SEAL
MMIINl. NOSNORN, STARYMIBLIC
CARLISLE BORO., CUMBERLAND COUNTY
MT C MMISSION EXPIRES APRIL 11 2007
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PAULA ANN LEHMER, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 05-3544
THOMAS DAVID LEHMER, CIVIL ACTION - LAW IN
DEFENDANT DIVORCE
CERTIFICATE OF SERVICE
I, James R. Demmel, Esquire, counsel for Defendant in the above captioned matter, do
hereby certify that I served a true and correct copy of the foregoing Defendant's Answers to
Plaintiff's First Set of Interrogatories on counsel for Plaintiff by hand-delivery on the 11 day of
November, 2005, addressed as follows:
Hannah Herman-Snyder, Esquire
Griffie & Associates
200 North Hanover Street
Carlisle, PA 17013
By:
SMIGEL, ANDERSON & SACKS, LLP
J emmel, Esquire I.D. #: 90918
441i N ,oAh Front Street
Harrisburg, PA 17110
(717) 234-2401
Attorney for Plaintiff
PAULA ANN LEHMER, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 05-3544
THOMAS DAVID LEHMER, CIVIL ACTION - LAW IN
DEFENDANT DIVORCE
I, James R. Demmel, Esquire, counsel for Defendant in the above captioned matter, do
hereby certify that I served two copies of the foregoing Defendant's First Set of Interrogatories
on counsel for Plaintiff by depositing same in the U.S. Mail, postage prepaid for first class mail,
on J min ? ??? addressed as follows:
Hannah Herman-Snyder, Esquire
Griffie & Associates
200 North Hanover Street
Carlisle, PA 17013
SMIGEL, ANDERSON & SACKS, LLP
By:
W North Front Street
Harrisburg, PA 17110
(717) 234-2401
Attorneys for ]Defendant
I.D. 90918
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PAULA ANN LEHMER, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 05-3544
THOMAS DAVID LEHMER, CIVIL ACTION - LAW IN
DEFENDANT DIVORCE
I, James R. Demmel, Esquire, counsel for Defendant in the above captioned matter, do
hereby certify that I served two copies of the foregoing Defendant's First Request for Production
of Documents on counsel for Plaintiff by depositing same in the U.S. Mail, postage prepaid for
11
first class mail, on J Okl addressed as follows:
Hannah Herman-Snyder, Esquire
Griffie & Associates
200 North Hanover Street
Carlisle, PA 17013
SMIGEL, ANDERSON & SACKS, LLP
By:
es . Demmel, Esquire LD. 90918
4 orth Front Street
Harrisburg, PA 17110
(717) 234-2401
Attorneys for Defendant
- 11 -
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/JRD/smm//March 27, 2007 9:06 AM
PAULA ANN LEHMER, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 05-3544
THOMAS DAVID LEHMER, CIVIL ACTION - LAW IN
DEFENDANT DIVORCE
MOTION FOR APPOINTMENT OF MASTER
Defendant, Thomas Lehmer, moves the court to appoint a master with respect to the
following claims:
(X) Divorce (X) Distribution of Property
O Annulment O Support
O Alimony O Counsel Fees
() Alimony Pendente Lite () Costs and Expenses
and in support of the motion states:
1. Discovery is complete as to the claim(s) for which the appointment of a master is
requested.
2. The non-moving party has appeared in the action by her attorney, Hannah Herman-
Snyder, Esquire.
3. The statutory ground(s) for divorce are 3301(c) or 3301(d).
4. The action is contested with respect to the following claims: divorce and equitable
distribution.
5. The action does not involve complex issues of law or fact.
6. The hearing is expected to take one (1) day.
7. Additional information, if any, relevant to the motion: none.
8485-1-4
40
Respectfully Submitted,
j SMIGEL, ANDERSON & SACKS, LLP
Dater
MOVING PARTY
Thomas Lehmer
LeRoy Smigel, Esquire
James R. Demmel, Esquire
4431 North Front Street
Harrisburg, PA 17110
(717) 234-2401
By:
?<?y S igel, Esquire I.D.#: 09617
me . Demmel, Esquire I.D.#: 90918
4431 North Front Street
Harrisburg, PA 17110
(717) 234-2401
Attorneys for Defendant
NON-MOVING PARTY
Paula Ann Lehmer
Hannah Herman-Snyder, Esquire
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
PAULA ANN LEHMER,
PLAINTIFF
V.
THOMAS DAVID LEHMER,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-3544
CIVIL ACTION - LAW IN
DIVORCE
CERTIFICATE OF SERVICE
li
I, James R. Demmel, Esquire, counsel for Defendant in the above-captioned matter, do
i
hereby certify that I served a true and correct copy of the foregoing Motion for Appointment of
II
Master on counsel for Plaintiff by placing same in the U.S. Mail, first class, postage paid on the
3 day of April, 2007, addressed as follows:
HANNAH HERMAN-SNYDER, ESQUIRE
GRIFFIE & ASSOCIATES
200 NORTH HANOVER STREET
CARLISLE, PA 17013
SMIGEL, ANDERSON & SACKS, LLP
By:
L oy S gel, Esquire I.D.#: 09617
Ja . emmel, Esquire I.D.#: 90918
4431 North Front Street
Harrisburg, PA 17110
(717) 234-2401
Attorneys for Defendant
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PAULA ANN LEHMER, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 05-3544
THOMAS DAVID LEHMER, CIVIL ACTION- LAW IN
DEFENDANT 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 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, Cumberland County Courthouse, Carlisle, Pennsylvania, 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
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumbedand County is required by law to comply with the Americans with
Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled
individuals having business before the Court, please contact our offce. All arrangements must be made at least 72 hours prior
to any hearing of business before the Court.
4 `
PAULA ANN LEHMER, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 05-3544
THOMAS DAVID LEHMER, CIVIL ACTION - LAW IN
DEFENDANT DIVORCE
ANSWER AND NEW MATTER TO COMPLAINT IN DIVORCE
AND NOW, comes Defendant, Thomas Lehmer, by and through his counsel, Smigel,
Anderson & Sacks, LLP, and files this Answer and New Matter to Complaint in Divorce and in
support thereof, avers as follows:
ANSWER
1. Admitted.
2. Admitted in part. Defendant admits that as of the time the Complaint was filed,
he resided at 534 Brighton Place, Mechanicsburg, PA. Defendant's current address is 114 June
Drive, Camp Hill, Cumberland County, PA.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted.
7. No response required.
8. Admitted.
9. Admitted.
10. Admitted.
NEW MATTER - EQUITABLE DISTRIBUTION
11. Defendant repeats and realleges the averments of paragraphs 1 through 10, which
are incorporated by reference herein.
12. Plaintiff and Defendant possess various items of both real and personal marital
property that are subject to equitable distribution by this Court.
WHEREFORE, Defendant respectfully requests that this Honorable Court equitably
distribute the marital property after an inventory and appraisement has been filed by the parties.
Respectfully Submitted,
Date: Z b?
SMIGEL, ANDERSON & SACKS
By:
D---
Le*06-ySmjg?661, squire ID #09617
Ja emmel, Esquire I.D. 90918
4431 North Front Street
Harrisburg, PA 17110
(717) 234-2401
Attorneys for Defendant
PAULA ANN LEHMER,
PLAINTIFF
V.
THOMAS DAVID LEHMER,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-3544
CIVIL ACTION - LAW IN
DIVORCE
CERTIFICATE OF SERVICE
I, James R. Demmel, Esquire, counsel for Defendant in the above captioned matter, do
hereby certify that I served a copy of the foregoing Defendant's Answer and New Matter to
Complaint in Divorce on counsel for Plaintiff by depositing same in the U.S. Mail, postage
prepaid for first class mail, on the 3 day of April, 2007, addressed as follows:
Hannah Herman-Snyder, Esquire
Griffie & Associates
200 North Hanover Street
Carlisle, PA 17013
SMIGEL, ANDERSON & SACKS, LLP
By:
eRo Smigel, Esquire ID #09617
Qzw6s R. Demmel, Esquire I.D. 90918
4431 North Front Street
Harrisburg, PA 17110
(717) 234-2401
Attorneys for Defendant
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PAULA ANN LEHMER,
PLAINTIFF
V.
THOMAS DAVID LEHMER,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-3544
CIVIL ACTION - LAW IN
DIVORCE
INVENTORY & APPRAISEMENT OF
THOMAS DAVID LEHMER
ASSETS OF PARTIES
Thomas David Lehmer marks on the list below those items applicable to the case at bar
and itemizes the assets on the following pages.
(X) 1. Real property
(X) 2. Motor vehicles
(X) 3. Stocks, bonds, securities and options
() 4. Certificates of deposit
(X) 5. Checking accounts, cash
(X) 6. Savings accounts, money market and savings certificates
() 7. Contents of safe deposit boxes
() 8. Trusts
(X) 9. Life Insurance policies (indicate face value and current beneficiaries
() 10. Annuities
() 11. Gifts
() 12. Inheritances
() 13. Patents, copyrights, inventions, royalties
() 14. Personal property outside the home
() 15. Businesses (list all owners, including percentage of ownership, and
officer/director positions held by a party with company.)
() 16. Employment termination benefits - severance pay, workman's compensation
claim/award
() 17. Profit sharing plans
() 18. Pension plans (indicate employee contribution and date plan vests)
(X) 19. Retirement plans, Individual Retirement Accounts
() 20. Disability payments
(X) 21. Litigation claims (matured and unmatured)
() 22. MilitaryN.A. benefits
() 23. Education benefits
() 24. Debts due, including loans, mortgages held
(X) 25. Household furnishings and personalty (include as a total category and attach
itemized list if distribution of such assets is in dispute
O 26. Other
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LIABILITIES OF PARTIES
Thomas David Lehmer marks on the list below those items applicable to the case at bar
and itemizes the liabilities on the following pages.
SECURED
(X) 1. Mortgages
() 2. Judgments
() 3. Liens
() 4. Other secured liabilities
UNSECURED
(X) 5. Credit card balances
() 6. Purchases
(X) 7. Loan payments
() 8. Notes payable
() 9. Other unsecured liabilities
CONTINGENT OR DEFERRED
() 10. Contracts or Agreements
() 11. Promissory notes
() 12. Lawsuits
() 13. Options
() 14. Taxes
() 15. Other contingent or deferred liabilities
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VERIFICATION
I, Thomas D. Lehmer, verify that the statements contained in the foregoing pleading are true
and correct to the best of my knowledge, information and belief. I understand that false statements
therein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to
authorities.
Date: / t fl 7 /
Thomas A Lehmer
PAULA ANN LEHMER,
PLAINTIFF
V.
THOMAS DAVID LEHMER,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-3544
CIVIL ACTION- LAW IN
DIVORCE
CERTIFICATE OF SERVICE
I, James R. Demmel, Esquire, counsel for Defendant in the above-captioned matter, do
hereby certify that I served a true and correct copy of the foregoing Inventory & Appraisement of
Thomas David Lehmer on counsel for Plaintiff by placing same in the U.S. Mail, first class,
postage paid on the 3 day of April, 2007, addressed as follows:
HANNAH HERMAN-SNYDER, ESQUIRE
GRIFFIE & ASSOCIATES
200 NORTH HANOVER STREET
CARLISLE, PA 17013
SMIGEL, ANDERSON & SACKS, LLP
By:
Roy S igel, Esquire I.D.#: 09617
t JD
emmel, Esquire I.D.#: 90918
4431 North Front Street
Harrisburg, PA 17110
(717) 234-2401
Attorneys for Defendant
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8485-1-4
PAULA ANN LEHMER,
PLAINTIFF
V.
THOMAS DAVID LEHMER,
DEFENDANT
APR 081ppV4
10
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-3544
CIVIL ACTION - LAW IN
DIVORCE
ORDER
AND NOW, this day of , 2007, ?• ??? `??:!CQ?/
Esquire, is appointed master with respect to the following claims: divorce and equitable distribution.
BY T T:
CALA )24
J.
11
Hannah Herman-Snyder, Esquire
Griffie and Associates
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
Attorney for Plaintiff
PAULA ANN LEHMER,
Plaintiff
V.
THOMAS DAVID LEHMER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. F.R. 2005-3544
CIVIL ACTION - LAW
IN DIVORCE
CERTIFICATE PREREQUISITE TO SERVICE
OF A SUBPOENA PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena for documents and things pursuant to Rule
4009.22, Plaintiff hereby certifies that:
1) A Notice of Intent to serve the subpoena, with a copy of the subpoena attached
thereto, was mailed or delivered to the party at least twenty days prior to the date
on which the subpoena was sought to be served;
2) A copy of the Notice of Intent, including the proposed subpoena, is attached to
this certificate;
3) Plaintiff has not received any objections to the subpoena being served upon
Citibank, and the Defendant has waived the twenty (20) day waiting period.
4) The subpoena to be served is identical to the subpoena attached to the Notice of
Intent.
GRIFFIE AND ASSOCIATES
By:%(x 06 N,t2,Mn1, - \,?,A,A\
Hannah Herman-Snyder, EsgiAre
200 North Hanover Street
Carlisle, PA 17013
Telephone: (717) 243-5551
_?j -?
Date:
Hannah Herman-Snyder, Esquire
Griffie and Associates
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
Attorney for Plaintiff
PAULA ANN LEHMER,
Plaintiff
V.
THOMAS DAVID LEHMER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. F.R. 2005-3544
CIVIL ACTION -LAW
IN DIVORCE
NOTICE OF INTENT TO SERVE SUBPOENA TO
PRODUCE DOCUMENTS AND THINGS FOR
DISCOVERY PURSUANT TO RULE 4009.21
TO: Thomas Lehmer, c/o James Demmel, Esquire
Smigel, Anderson & Sacks, LLP
4431 North Front Street
Harrisburg, PA 17110
PLEASE TAKE NOTICE that Plaintiff, Paula A. Lehmer, intends to serve a subpoena
identical to that attached to this notice upon the following:
1. CT Corporation
MasterCard Account Number 54241804 6246 9237
1515 Market Street
Philadelphia, PA 19102
You have twenty (20) days from the date listed below in which to file on record and serve
upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may
be served.
GRIFFIE AND ASSOCIATES
By: N n h trek N'troy ftA_
Hannah Herman-Snyder, Esc
Attorney I.D. #91537
200 North Hanover Street
Carlisle, PA 17013
Telephone: (717) 243-5551
Date: cl - 1 -l - ?) :
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
PAULA ANN LEHMER,
Plaintiff
V.
THOMAS DAVID LEHMER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. F.R. 2005-3544
CIVIL ACTION - LAW
IN DIVORCE
TO: CT Corporation
1515 Market Street
Philadelphia, PA 19102
RE: Account Number 54241804 6246 9237
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: Credit card statements for every billing cycle from April 1, 2002 to the end of
February of 2005
at Griffie and Associates 200 North Hanover Street Carlisle, Pennsylvania, 17013.
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with
the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance
the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the
parry serving this subpoena may seek a court order compelling you to comply with it.
This subpoena was issued at the request of the following person:
Hannah Herman-Snyder 91537
Attorney's Name Identification Number
200 North Hanover Street (717)24375551
Carlisle PA 17013 Telephone Number
Address
Attorney for Paula A. Lehmer
Date:
Seal of the Court
BY THE COURT,
BY
Prothonotary
Deputy Prothonotary
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Hannah Herman-Snyder, Esquire
Griffie and Associates
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
Attorney for Plaintiff
PAULA ANN LEHMER,
Plaintiff
V.
THOMAS DAVID LEHMER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. .2005-3544
CIVIL ACTION -LAW
IN DIVORCE
CERTIFICATE PREREQUISITE TO SERVICE
OF A SUBPOENA PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena for documents and things pursuant to Rule
4009.22, Plaintiff hereby certifies that:
1) A Notice of Intent to serve the subpoena, with a copy of the subpoena attached
thereto, was mailed or delivered to the party at least twenty days prior to the date
on which the subpoena was sought to be served;
2) A copy of the Notice of Intent, including the proposed subpoena, is attached to
this certificate;
3) Plaintiff has not received any objections to the subpoena being served upon
Citibank, and the Defendant has waived the twenty (20) day waiting period.
4) The subpoena to be served is identical to the subpoena attached to the Notice of
Intent.
GRIFFIE AND ASSOCIATES
By:
Hannah Herman-Snyder, Esq i1 re
200 North Hanover Street
Carlisle, PA 17013
Telephone: (717) 243-5551
Date: 1O - ,?,q - d1
.4
Hannah Herman-Snyder, Esquire
Griffie and Associates
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
Attorney for Plaintiff
PAULA ANN LEHMER,
Plaintiff
V.
THOMAS DAVID LEHMER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2005-3544
CIVIL ACTION -LAW
IN DIVORCE
NOTICE OF INTENT TO SERVE SUBPOENA TO
PRODUCE DOCUMENTS AND THINGS FOR
DISCOVERY PURSUANT TO RULE 4009.21
TO: Thomas Lehmer, c/o James Demmel, Esquire
Smigel, Anderson & Sacks, LLP
4431 North Front Street
Harrisburg, PA 17110
PLEASE TAKE NOTICE that Plaintiff, Paula A. Lehmer, intends to serve a subpoena
identical to that attached to this notice upon the following:
1. Citicorp Corp. Credit Services Inc., USA
c/o CT Corporation
MasterCard Account Number 54241804 6246 9237
1515 Market Street
Philadelphia, PA 19102
w
You have twenty (20) days from the date listed below in which to file on record and serve
upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may
be served.
GRIFFIE AND ASSOCIATES
By:?4h nu•k?na.natiarLamy,bq
V
Hannah Herman-Snyder, Esquire
Attorney I.D. #91537
200 North Hanover Street
Carlisle, PA 17013
Telephone: (717) 243-5551
Dater C'? - i'1- (3
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Hannah Herman-Snyder, Esquire
Griffie and Associates
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
Attorney for Plaintiff
PAULA ANN LEHMER,
Plaintiff
V.
THOMAS DAVID LEHMER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2005-3544
CIVIL ACTION -LAW
IN DIVORCE
To: Citicorp Credit Services, Inc. USA
c/o CT Corporation
Account Number 5424 1804 6246 9237
1515 Market Street
Philadelphia, PA 19102
NOTICE
You are required to complete the following Certificate of Compliance when producing documents or things pursuant
to the Subpoena.
CERTIFICATE OF COMPLIANCE WITH SUBPOENA
TO PRODUCE DOCUMENTS TO THINGS PURSUANT
TO RULE 4009.23
I, , certify to the best of my knowledge, information and belief that all documents or
other things required to be produced pursuant to the subpoena issued on , have been
produced.
Date:
Signature of person served
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Hannah Herman-Snyder, Esquire
Griffie and Associates
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
Attorney for Plaintiff
PAULA ANN LEHMER,
Plaintiff
V.
THOMAS DAVID LEHMER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2005-3544
CIVIL ACTION -LAW
IN DIVORCE
CERTIFICATE PREREOUISITE TO SERVICE
OF A SUBPOENA PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule
4009.22, Defendant hereby certify that:
1) A Notice of Intent to serve the subpoena, with a copy of the subpoena attached
thereto, was mailed or delivered to each party at least twenty days prior to the date
on which the subpoena was sought to be served;
2) A copy of the Notice of Intent, including the proposed subpoena, is attached to
this certificate;
3) Plaintiff has not received any objections to the subpoena being served upon Chase
Card Bank, USA, N.A., and the Defendant has waived the twenty (20) day
waiting period.
4) The subpoena to be served is identical to the subpoena attached to the Notice of
Intent.
GRIFFIE AND ASSOCIATES
Hannah Herman-Snyder, Esq#ire
200 North Hanover Street
Carlisle, PA 17013
Telephone: (717) 243-5551
Date: I I - 19 - 0'7
• t ? • 1
Hannah Herman-Snyder, Esquire
Griffie and Associates
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
Attorney for Plaintiff
PAULA ANN LEHMER,
Plaintiff
V.
THOMAS DAVID LEHMER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2005-3544
CIVIL ACTION -LAW
IN DIVORCE
NOTICE OF INTENT TO SERVE SUBPOENA TO
PRODUCE DOCUMENTS AND THINGS FOR
DISCOVERY PURSUANT TO RULE 4009.21
TO: Thomas Lehmer, c/o James Demmel, Esquire
Smigel, Anderson & Sacks, LLP
4431 North Front Street
Harrisburg, PA 17110
PLEASE TAKE NOTICE that Plaintiff, Paula A. Lehmer, intends to serve a subpoena
identical to those attached to this notice upon the following:
1. Chase Bank USA, N.A.
National Subpoena Processing
7610 W. Washington St., IN1-4054
Indianapolis, IN 46231
Visa 'Account Number 4640 1820 12717389
You have twenty (20) days from the date listed below in which to file on record and serve
upon the undersigned an objection to the subpoenas. If no objection is made, the subpoenas may
be served.
GRIFFIE AND ASSOCIATES
Hannah Herman-Snyder, Esquire p
Attorney I.D. #91537
200 North Hanover Street
Carlisle, PA 17013
Telephone: (717) 243-5551
Date: i C) - I I- p`1
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
PAULA ANN LEHMER,
Plaintiff
V.
THOMAS DAVID LEHMER,
Defendant
TO: CHASE BANK USA, N.A.
National Subpoena Processing
7610 W. Washington Street, IN1-4054
Indianapolis, IN 46231
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2005-3544
CIVIL ACTION - LAW
IN DIVORCE
ACCOUNT NO. 4640 1820 1271 7389
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: Credit card statements for every billing cycle from April 1, 2002 to the end
of February 2005.
at Griffie and Associates, 200 North Hanover Street, Carlisle, Pennsylvania, 17013.
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with
the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance
the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the
party serving this subpoena may seek a court order compelling you to comply with it.
This subpoena was issued at the request of the following person:
Hannah Herman-Snyder
Attorney's Name
200 North Hanover Street
Carlisle, PA 17013
Address
Date:
Seal of the Court
91537
Identification Number
(717)243-5551
Telephone Number
Attorney for Paula A. Lehmer
BY THE COURT,
BY
Prothonotary
Deputy Prothonotary
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Hannah Herman-Snyder, Esquire
Grime and Associates
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
Attorney for Plaintiff
PAULA ANN LEHMER,
Plaintiff
V.
THOMAS DAVID LEHMER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2005-3544
CIVIL ACTION -LAW
IN DIVORCE
CERFICIATE PREREQUISITE TO SERVICE
OF A SUBPOENA PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena for documents and things pursuant to Rule
4009.22, Plaintiff hereby certifies that:
1) A Notice of Intent to serve the subpoena, with a copy of the subpoena attached
thereto, was mailed or delivered to each party at least twenty days prior to the date
on which the subpoena was sought to be served;
2) A copy of the Notice of Intent, including the proposed subpoena, is attached to
this certificate;
3) Plaintiff has not received any objections to the subpoena being served upon Chase
Bank USA, N.A. and the Defendant has waived the twenty day waiting period.
4) The subpoena to be served is identical to the subpoena attached to the Notice of
Intent.
GRIFFIE AND ASSOCIATES
By:4',?Ar?i?n-?mn
Hannah Herman-Snyder, Esquire
200 North Hanover Street
Carlisle, PA 17013
Telephone: (717) 243-5551
Date: 1_)- iy -6]
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Hannah Herman-Snyder, Esquire
Griffie and Associates
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
Attorney for Plaintiff
PAULA ANN LEHMER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
THOMAS DAVID LEHMER,
Defendant
: NO. 2005-3544
CIVIL ACTION -LAW
IN DIVORCE
NOTICE OF INTENT TO SERVE SUBPOENA TO
PRODUCE DOCUMENTS AND THINGS FOR
DISCOVERY PURSUANT TO RULE 4009.21
TO: Thomas Lehmer, c/o James Demmel, Esquire
Smigel, Anderson & Sacks, LLP
4431 North Front Street
Harrisburg, PA 17110
PLEASE TAKE NOTICE that Plaintiff, Paula A. Lehmer, intends to serve a subpoena
identical to that attached to this notice upon the following:
1. CHASE BANK USA, N.A.
National Subpoena Processing
7610 W. Washington Street, IN1-4054
Indianapolis, IN 46231
Account Number 4226 6106 5437 2677
You have twenty (20) days from the date listed below in which to file on record and serve
upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may
be served.
GRIFFIE AND ASSOCIATES
By:%.a....,? 0 ? 0A c?.? try
Hannah Herman-Snyder, Esquifte
Attorney I.D. #91537
200 North Hanover Street
Carlisle, PA 17013
Telephone: (717) 243-5551
Date: 1.1- l,) - o:1
. -0
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
PAULA ANN LEHMER,
Plaintiff
V.
THOMAS DAVID LEHMER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2005-3544
CIVIL ACTION -LAW.
IN DIVORCE
TO: CHASE BANK USA, N.A.
NATIONAL SUBPOENA PROCESSING
7610 W. WASHINGTON STREET, IN1-4054
INDIANAPOLIS, IN 46231
ACCOUNT NUMBER 4226 6106 5437 2677
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: Credit card statements for every billing cycle from April 1, 2002 to the
end of February 2005.
at Griffie and Associates, 200 North Hanover Street, Carlisle, Pennsylvania. 17013
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with
the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance
the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the
party serving this subpoena may seek a court order compelling you to comply with it.
This subpoena was issued at the request of the following person:
Hannah Herman-Snyder 91537
Attorney's Name Identification Number
200 North Hanover Street (717)243-5551
Carlisle, PA 17013 Telephone Number
Address
Date:
Seal of the Court
Attorney for Paula A. Lehmer
BY THE COURT,
BY
Prothonotary
Deputy Prothonotary
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PAULA ANN T,[ I-TM1;R,
Plaintiff
v.
TIIOMAS DAVID LI IIMI R,
Defendant
IN '1'HT? COt-R'I OF, O?VIMON PLEA: OF
CUMI*RLAND COUNTY, PLNNSYLVANIA
IN DIVW.CE
NC1. ?005-14
IN DIVOR(Ii.
AFFIDAVIT OF CONSENT
A Complaint in Divorce under §3301(c) of the Divorce Code was tiled on July
mail.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of tiling and service of the Complaint.
3. I consent to the entry of a final Decree of Divorce after service of notice or
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 MADF SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO
ITNSWOR?•' FALSIFICATION TO AUTHORITIES.
DATE:
PAULA ANN LEHMEIZ. Plaintiff
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PAULA ANN LEHMER,
Plaintiff
V.
THOMAS DAVID LEHMER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
IN DIVORCE
NO. 2005-3544
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
THE ENTRY OF A DIVORCE DECREE
UNDER 43301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in 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 VI, RIFY THAT THE S'[ AT'EMENTS MAiIF II?T 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: h \Itgak 14-n? /,?
PAULA ANN LEHMER, Plaintiff
r
OCT-13-2006 10:31AM FROM-SMIGEL ANDERSON SACKS 7172343611 T-065 P 002/005 F-654
SMIGEL, ANOCKSON & SACKS, LLP
James R. Demmel, Esquire ID 090919
4431 North Front Street. Yu Fir.
I-lurrisburs. PA 17110-177C
(717) 234-24111
iden?mel0ct11r, QM
Attomey for Defendunt
PAULA ANN LEHMER, IN THE COURT OF COMMON PLEA
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 05-3544
THOMAS DAVID LEHMER, CIVIL ACTION- LAW IN
DEFENDANT DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under §330I (e) of the Divorce Code was filed on J?1 Y 13
a
2005.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety O0) days
have elapsed from the date of filing and service of the Complaint.
3. 1 consent to the entry of a final Decree of Divorce after service of notice of i?itention 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.S. §4904 relating tp,1 unsworn
falsification to authorities.
Datc: ?o /-t`o P
Thomas David Lehmer',
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OCT-13-2006 10:31AM FROM-SMIGEL ANDERSON SACKS
SMIGEL. ANDERSON & SACKS. LLP
Jumes R. Donmel. Esquire ID 090918
4431 North From Strict, 3'° Fir.
I.larri%burg, PA 17110-1778
(717) 234-2401
&MIngI2---as IIo.eom
Anurney 1'or Detendam
PAULA ANN LEHMER,
PLAINTIFF
V.
THOMAS DAVID LEHMER,
DEFENDANT
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7172343611 T-065 P 003/005 F-654
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL ANIA
NO. 05-3544
CIVIL ACTION- LAW IN
DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
3301(c) AND 63301(M OF THE DIVORCE CODE
I consent to the entry of a final decree of divorce without notice.
2. 1 understand that I may lose rights concerning alimony, division of
or expenses if I do not claim them before a divorce is granted.
, lawyer's fees
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 Ine immediately after it is filed with the Protho otary.
I verify that the statements made in this Affidavit are true and correct. I unders and that false
statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn
falsification to authorities.
Date: /d`/.3 /., P
Thomas David Lebmer,
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PAULA ANN LEHMER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 05 - 3544 CIVIL
THOMAS DAVID LEHMER,
Defendant IN DIVORCE
ORDER OF COURT
AND NOW, this
day of 63?6_r
2008, the economic claims raised in the proceedings having been
resolved in accordance with a marriage settlement agreement
dated October 21, 2008, the appointment of the Master is
vacated and counsel can file a praecipe transmitting the record
to the Court requesting a final decree in divorce.
cc: ? Hannah Herman-Snyder
Attorney for Plaintiff
James R. Demmel
Attorney for Defendant
Oar'as .7,2t L(_
BY THE COURT,
QV v )c
Edgar B. Bayley, P.J.
n
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MARRIAGE SETTLEMENT AGREEMENT
AGREEMENT MADE this )j" day of c) (4 (, ,1- ) 2008, by and
between Paula Lehmer ("Wife") - A N D - Thomas Lehmer ("Husband"), at Harrisburg, Pennsylvania.
WHEREAS, the parties hereto are husband and wife having been married on April 6, 2002, at
Shiremanstown, PA;
WHEREAS, no children were born of this marriage.
WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the
parties and it is the intention of Husband and Wife to live separate and apart for the rest of their natural
lives, and the parties desire to settle fully and finally their respective financial and property rights and
obligations as between each other including, without limitation by specification: settling of all matters
between them relating to the ownership and equitable distribution of real and personal property; settling
of all matters between them relating to the past, present and future support, alimony and/or maintenance
of Wife by Husband or of Husband by Wife; and in general, the settling of any and all claims and
possible claims by one against the other or against their respective estates.
NOW, THEREFORE, in consideration of the foregoing premises and of the mutual promises,
covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt
of which is hereby acknowledged by each of the parties, Husband and Wife, each intending to be legally
bound hereby, covenant and agree as follows:
Divorce and Separation. The parties agree to the entry of a decree in divorce pursuant
to Section 3301(c) of the Divorce Code of 1980. Husband and Wife shall at all times hereafter have the
right to live separate and apart from each other and to reside from time to time at such place or places as
they shall respectively deem fit, free from any control, restraint, or interference whatsoever by the other.
Neither party shall molest the other or endeavor to compel the other to cohabit or dwell with him or her
by any legal or other proceedings. The foregoing provision shall not be taken to be an admission on the
part of either Husband or Wife of the lawfulness or unlawfulness of the causes leading to their living
apart.
The parties acknowledge that a divorce action has been filed in the Court of Common Pleas of
Cumberland County, Pennsylvania at docket number 05-3544. The parties have executed Affidavits of
Consent and Waivers of Notice of Intention to Request Entry of a Divorce Decree in the aforementioned
matter. Upon receipt of the fully executed Marriage Settlement Agreement, counsel for Wife shall
promptly file a Praecipe to Transmit Record and obtain a divorce decree.
2. Division of Property. Husband and Wife agree that the following constitutes an
equitable distribution of the marital property.
A. Husband's Property. The following property shall become the sole and
exclusive property of Husband:
1) Twenty seven thousand five hundred sixty seven and 10/100
($27,567.10) dollars, which is one-half of the remaining proceeds from the sale of the
property and lot situated at 915 Alison Avenue, Mechanicsburg, PA. Wife's counsel
holds the remaining proceeds and shall promptly pay this amount to Husband upon
receipt of the fully executed original of this Agreement.
2) All right, title and interest to any and all bank accounts, investment
accounts and all other financial accounts titled in Husband's name, either individually or
with another person or entity.
3) All right, title and interest in any and all life insurance policies in
2
which Husband has any ownership interest, either individually or with another person or
entity.
4) All right, title and interest in Husband's Highmark Investment Plan.
5) All right, title and interest in Husband's Highmark Pension Plan.
6) All right, title and interest in any and all motor vehicles titled in
Husband's name, either individually or with another person or entity.
7) All right, title and interest in any and all tangible and intangible
personal property titled in Husband's name or in Husband's control or possession.
B. Wife's Property. The following property shall become the sole and
exclusive property of Wife:
1) Twenty seven thousand five hundred sixty seven and 10/100
($27,567.10) dollars, which is one-half of the remaining proceeds from the sale of the
property and lot situated at 915 Alison Avenue, Mechanicsburg, PA.
2) All right, title and interest to any and all bank accounts, investment
accounts and all other financial accounts titled in Wife's name, either individually or with
another person or entity.
3) All right, title and interest in any and all life insurance policies in
which Wife has any ownership interest, either individually or with another person or
entity.
4) All right, title and interest in all shares of Fulton Financial Corporation
stock titled in Wife's name, either individually or with another person or entity.
3
5) All right, title and interest in all settlement proceeds received by Wife
from Fulton Financial Corporation.
6) All right, title and interest in any and all motor vehicles titled in Wife's
name, either individually or with another person or entity.
7) All right, title and interest in any and all tangible and intangible
personal property titled in Wife's name or in Wife's control or possession.
3. Taxes. The parties have heretofore filed joint federal and state tax returns. Both parties
agree that in the event any deficiency in federal, state or local income tax is proposed, or any assessment
of any such tax is made against either of them, each will indemnify and hold harmless the other from and
against any loss or liability for any such tax deficiency or assessment and any interest, penalty and
expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and
entirely by the individual who is finally determined to be the cause of the misrepresentations or failures
to disclose the nature and extent of his or her separate income on the aforesaid joint returns.
4. Additional Documentation. The parties agree to execute any deeds, assignments, titles
or other instruments necessary and appropriate to accomplish the aforesaid division of property.
5. Representations and Warranties. The parties represent and warrant to each other that
the property described in this Agreement represents all of the property in which they have any right, title
and interest, and that such property is subject to no mortgage, pledge, lien, security interest,
encumbrance or charge except those which are disclosed herein.
6. Equitable Division. By this Agreement the parties have intended to effect an equitable
division of their jointly owned property. The parties have determined that an equitable division of such
4
property conforms to a just and right standard, with due regard to the rights of each party. The division
of existing marital property is not intended by the parties to constitute in any way a sale or exchange of
assets, and the division is being effected without the introduction of outside funds or other property not
constituting a part of the marital estate. It is the intention of the parties to treat all transfers herein as
non-taxable.
7. Relinquishment of Rights. Except as expressly provided herein, Husband forever
relinquishes any right, title or interest he may now or hereafter have in any tangible or intangible assets
now belonging to Wife, and Wife forever relinquishes any right, title or interest she may now or
hereafter have in any tangible or intangible assets now belonging to Husband.
8. After-Acquired Property. Each of the parties shall hereafter own and enjoy
independently of any claim or right of the other, all items of property, be they real, personal or mixed,
tangible or intangible, which are hereafter acquired by him or her, with full power in him or her to
dispose of the same as fully and effectively, in all respects and for all purposes as though he or she were
unmarried.
9. Debts. Husband and Wife shall each be solely responsible for all debts in their respective
names, including but not limited to personal loans, charge accounts and credit cards. Pursuant to the
terms of this Agreement, Husband has received consideration for one half of the Visa credit card balance
held in his name alone such that he shall be responsible for paying off the remaining balance and shall
indemnify and hold Wife harmless from any collection activity regarding that debt. Both parties
represent and warrant to the other that as of the date of this Agreement they have not incurred, and in the
future will not contract or incur, any debt or liability for which the other or the estate of the other might
5
be responsible.
10. Liabilities. All debts, contracts, obligations or liabilities incurred at any time in the past
or future by either party will be paid promptly by said party, unless and except as otherwise specifically
set forth in this Agreement; and each of the parties hereto further promises, covenants and agrees that
each will now and at all times hereafter save harmless and keep the other or his or her estate indemnified
and save harmless from all debts or liabilities incurred by him or her, as the case may be, and from all
actions, claims and demands whatsoever with respect thereto, and from all costs, legal or otherwise, and
counsel fees whatsoever pertaining to such actions, claims and demands. Neither party shall, as of the
date of this Agreement, contract nor incur any debt or liability for which the other or his or her property
may be responsible, and shall indemnify and save harmless the other from any and all claims or demands
made against him or her by reason of debts or obligations incurred by him or her and from all expenses,
legal costs, and counsel fees unless provided to the contrary herein.
11. Counsel Fees, Costs and Expenses. Each party shall be responsible for his or her own
legal fees, costs and expenses incurred in connection with their separation and/or the dissolution of their
marriage.
12. Alimony. In exchange for and in consideration of the promises and representations made
hereunder, Husband and Wife hereby waive and release any and all right, title, interest, claims or
demand of whatsoever nature which he or she now has or hereafter can, shall or may have against the
other or the respective separate property of the other under the laws of the Commonwealth of
Pennsylvania or any other governing state, country, territory or jurisdiction in the nature of spousal
support, separate maintenance or support, alimony, either pendente lite, temporary, rehabilitative,
6
permanent or lump sum and right to seek equitable or community distribution or division or assignment
of property or similar marital rights. The spousal support order currently in effect through the
Cumberland County Domestic Relations Office docketed at Number 00520 S 2005 shall be terminated
as of the date the court enters the decree in divorce or November 7, 2008, whichever occurs first.
13. Full Disclosure. The respective parties do hereby warrant, represent and declare and do
acknowledge and agree that each is and has been fully and completely informed of and is familiar with
and cognizant of the wealth, real and/or personal property, estate and assets, earnings and income of the
other and that each has made a full and complete disclosure to the other of his or her entire assets and
liabilities and any further enumeration or statement thereof in this Agreement is specifically waived.
14. Releases. Each party does hereby remise, release, quitclaim and forever discharge the
other and the estate of the other from any and every claim that each other may now have, or hereafter
have or can have at any time, against the other, or in and to or against the other's estate, or any part
thereof, whether arising out of any former contracts, engagements or liabilities of the other, or by way of
dower or claim in the nature of dower, widow's rights, or under the intestate laws, or the right to take
against each other's will, or for support or maintenance, or of any other nature whatsoever, except any
rights accruing under this Agreement.
15. Indemnification. Each party represents and warrants to the other that he or she has not
incurred any debt, obligation, or other liability, other than described in this Agreement, on which the
other party is or may be liable. Each party covenants and agrees that if any claim, action or proceeding
is hereinafter initiated seeking to hold the other party liable for any other debts, obligations, liability, act
or omission of such party, such party will at his or her sole expense, defend the other against any such
7
claim or demand, whether or not well-founded, and that he or she will indemnify and hold harmless the
other party in respect of all damages as resulting therefrom. Damages as used herein shall include any
claim, action, demand, loss, cost, expense, penalty, and other damage, including without limitation,
counsel fees and other costs and expenses reasonably incurred in investigating or attempting to avoid
same or in opposing the imposition thereof or enforcing this indemnity, resulting to Husband or Wife
from any inaccurate representation made by or on behalf of either Husband or Wife to the other in this
Agreement, any breach of any of the warranties made by Husband or Wife in this Agreement, or breach
or default in performance by Husband or Wife of any of the obligations to be performed by such parry
hereunder. The Husband or Wife agrees to give the other prompt written notice of any litigation
threatened or instituted against either parry which might constitute the basis for a claim for indemnity
pursuant to the terms of this Agreement.
16. General Provisions. This Agreement constitutes the entire understanding of the parties
and supersedes any and all prior agreements and negotiations between them. There are no
representations or warranties other than those expressly set forth herein.
17. Fair and Equitable Contents. The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective counsel. Each party acknowledges that he or
she has received independent legal advice from counsel of his or her selection and that each fully
understands the facts and has been fully informed as to his or her legal rights and obligations. Each
party acknowledges and accepts that this Agreement is, under the circumstances, fair and equitable, and
that it is being entered into freely and voluntarily after having received such advice and with such
knowledge, and that execution of this agreement is not the result of any duress or undue influence and
8
that it is not the result of any collusion or improper or illegal agreement or agreements.
18. Breach. It is expressly stipulated that if either party fails in the due performance of any
of his or her material obligations under this Agreement, the other party shall have the right, at his or her
election, to sue for damages for breach thereof, to sue for specific performance, or to seek any other legal
remedies as may be available, and the defaulting party shall pay the reasonable legal fees for any services
rendered by the non-defaulting party's attorney in any action or proceeding to compel performance
hereunder.
19. Execution of Documents. Each party shall on demand execute any other documents that
may be necessary or advisable to carry out the provisions of this Agreement.
20. Modification. No modification, rescission or amendment to this Agreement shall be
effective unless in writing signed by each of the parties hereto.
21. Severability. If any provision of this Agreement is held by a Court of competent
jurisdiction to be void, invalid or unenforceable, the remaining provisions hereof shall nevertheless
survive and continue in full force and effect without being impaired or invalidated in any way.
22. Applicable Law. This Agreement shall be construed under the laws of the
Commonwealth of Pennsylvania.
23. Agreement Not to be Merged. This Agreement may be filed with the Court for
incorporation into the Decree of Divorce for purposes of enforcement only, but otherwise shall not be
merged into said Decree. The parties shall have the right to enforce this Agreement under the Divorce
Code of 1980, as amended, and in addition, shall retain any remedies in law or in equity under this
Agreement as an independent contract. Such remedies in law or equity are specifically not waived or
9
released.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year
first above written.
Witness:
°-? Nall .4
Paula Lehmer
Thomas Lehmer
10
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
. ss.
Personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and
County, Paula Lehmer, who being duly sworn according to law deposes and says that she is a party of
the foregoing Agreement and she executed same for the purposes therein contained.
Witness my hand and seal this Sr day of ,?CAhtr _, 2008.
0111A1 ?(
No Pu i
My Commission Expires:
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
Mi1?lAL >tiAL
. ss.
Personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and
County, Thomas Lehmer, who being duly sworn according to law deposes and says that he is a party of
the foregoing Agreement and he executed same for the purposes therein contained.
Witness my hand and seal this ( day of QC10109-4.- , 2008.
Notary Pu is
My Commission Expires:
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
11 Vicky L Fk Notary Pd*
Suequeharrra TwP., Dauphin County
W Cor?mission Expires Jan. 6,2D1 I
Member, Pennsylvania Association of Notaries
MARRIAGE SETTLEMENT AGREEMENT
AGREEMENT MADE this 1? $4 day of a (J c, be r , 2008, by and
between Paula Lehmer ("Wife") - A N D - Thomas Lehmer ("Husband"), at Harrisburg, Pennsylvania.
WHEREAS, the parties hereto are husband and wife having been married on April 6, 2002, at
Shiremanstown, PA;
WHEREAS, no children were born of this marriage.
WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the
parties and it is the intention of Husband and Wife to live separate and apart for the rest of their natural
lives, and the parties desire to settle fully and finally their respective financial and property rights and
obligations as between each other including, without limitation by specification: settling of all matters
between them relating to the ownership and equitable distribution of real and personal property; settling
of all matters between them relating to the past, present and future support, alimony and/or maintenance
of Wife by Husband or of Husband by Wife; and in general, the settling of any and all claims and
possible claims by one against the other or against their respective estates.
NOW, THEREFORE, in consideration of the foregoing premises and of the mutual promises,
covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt
of which is hereby acknowledged by each of the parties, Husband and Wife, each intending to be legally
bound hereby, covenant and agree as follows:
1. Divorce and Separation. The parties agree to the entry of a decree in divorce pursuant
to Section 3301(c) of the Divorce Code of 1980. Husband and Wife shall at all times hereafter have the
right to live separate and apart from each other and to reside from time to time at such place or places as
they shall respectively deem fit, free from any control, restraint, or interference whatsoever by the other.
Neither party shall molest the other or endeavor to compel the other to cohabit or dwell with him or her
by any legal or other proceedings. The foregoing provision shall not be taken to be an admission on the
part of either Husband or Wife of the lawfulness or unlawfulness of the causes leading to their living
apart.
The parties acknowledge that a divorce action has been filed in the Court of Common Pleas of
Cumberland County, Pennsylvania at docket number 05-3544. The parties have executed Affidavits of
Consent and Waivers of Notice of Intention to Request Entry of a Divorce Decree in the aforementioned
matter. Upon receipt of the fully executed Marriage Settlement Agreement, counsel for Wife shall
promptly file a Praecipe to Transmit Record and obtain a divorce decree.
2. Division of Property. Husband and Wife agree that the following constitutes an
equitable distribution of the marital property.
A. Husband's Property. The following property shall become the sole and
exclusive property of Husband:
1) Twenty seven thousand five hundred sixty seven and 10/100
($27,567.10) dollars, which is one-half of the remaining proceeds from the sale of the
property and lot situated at 915 Alison Avenue, Mechanicsburg, PA. Wife's counsel
holds the remaining proceeds and shall promptly pay this amount to Husband upon
receipt of the fully executed original of this Agreement.
2) All right, title and interest to any and all bank accounts, investment
accounts and all other financial accounts titled in Husband's name, either individually or
with another person or entity.
3) All right, title and interest in any and all life insurance policies in
2
which Husband has any ownership interest, either individually or with another person or
entity.
4) All right, title and interest in Husband's Highmark Investment Plan.
5) All right, title and interest in Husband's Highmark Pension Plan.
6) All right, title and interest in any and all motor vehicles titled in
Husband's name, either individually or with another person or entity.
7) All right, title and interest in any and all tangible and intangible
personal property titled in Husband's name or in Husband's control or possession.
B. Wife's Property. The following property shall become the sole and
exclusive property of Wife:
1) Twenty seven thousand five hundred sixty seven and 10/100
($27,567.10) dollars, which is one-half of the remaining proceeds from the sale of the
property and lot situated at 915 Alison Avenue, Mechanicsburg, PA.
2) All right, title and interest to any and all bank accounts, investment
accounts and all other financial accounts titled in Wife's name, either individually or with
another person or entity.
3) All right, title and interest in any and all life insurance policies in
which Wife has any ownership interest, either individually or with another person or
entity.
4) All right, title and interest in all shares of Fulton Financial Corporation
stock titled in Wife's name, either individually or with another person or entity.
3
5) All right, title and interest in all settlement proceeds received by Wife
from Fulton Financial Corporation.
6) All right, title and interest in any and all motor vehicles titled in Wife's
name, either individually or with another person or entity.
7) All right, title and interest in any and all tangible and intangible
personal property titled in Wife's name or in Wife's control or possession.
3. Taxes. The parties have heretofore filed joint federal and state tax returns. Both parties
agree that in the event any deficiency in federal, state or local income tax is proposed, or any assessment
of any such tax is made against either of them, each will indemnify and hold harmless the other from and
against any loss or liability for any such tax deficiency or assessment and any interest, penalty and
expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and
entirely by the individual who is finally determined to be the cause of the misrepresentations or failures
to disclose the nature and extent of his or her separate income on the aforesaid joint returns.
4. Additional Documentation. The parties agree to execute any deeds, assignments, titles
or other instruments necessary and appropriate to accomplish the aforesaid division of property.
5. Representations and Warranties. The parties represent and warrant to each other that
the property described in this Agreement represents all of the property in which they have any right, title
and interest, and that such property is subject to no mortgage, pledge, lien, security interest,
encumbrance or charge except those which are disclosed herein.
6. Equitable Division. By this Agreement the parties have intended to effect an equitable
division of their jointly owned property. The parties have determined that an equitable division of such
4
property conforms to a just and right standard, with due regard to the rights of each party. The division
of existing marital property is not intended by the parties to constitute in any way a sale or exchange of
assets, and the division is being effected without the introduction of outside funds or other property not
constituting a part of the marital estate. It is the intention of the parties to treat all transfers herein as
non-taxable.
7. Relinquishment of Rights. Except as expressly provided herein, Husband forever
relinquishes any right, title or interest he may now or hereafter have in any tangible or intangible assets
now belonging to Wife, and Wife forever relinquishes any right, title or interest she may now or
hereafter have in any tangible or intangible assets now belonging to Husband.
8. After-Acquired Property. Each of the parties shall hereafter own and enjoy
independently of any claim or right of the other, all items of property, be they real, personal or mixed,
tangible or intangible, which are hereafter acquired by him or her, with full power in him or her to
dispose of the same as fully and effectively, in all respects and for all purposes as though he or she were
unmarried.
9. Debts. Husband and Wife shall each be solely responsible for all debts in their respective
names, including but not limited to personal loans, charge accounts and credit cards. Pursuant to the
terms of this Agreement, Husband has received consideration for one half of the Visa credit card balance
held in his name alone such that he shall be responsible for paying off the remaining balance and shall
indemnify and hold Wife harmless from any collection activity regarding that debt. Both parties
represent and warrant to the other that as of the date of this Agreement they have not incurred, and in the
future will not contract or incur, any debt or liability for which the other or the estate of the other might
be responsible.
10. Liabilities. All debts, contracts, obligations or liabilities incurred at any time in the past
or future by either party will be paid promptly by said party, unless and except as otherwise specifically
set forth in this Agreement; and each of the parties hereto further promises, covenants and agrees that
each will now and at all times hereafter save harmless and keep the other or his or her estate indemnified
and save harmless from all debts or liabilities incurred by him or her, as the case may be, and from all
actions, claims and demands whatsoever with respect thereto, and from all costs, legal or otherwise, and
counsel fees whatsoever pertaining to such actions, claims and demands. Neither party shall, as of the
date of this Agreement, contract nor incur any debt or liability for which the other or his or her property
may be responsible, and shall indemnify and save harmless the other from any and all claims or demands
made against him or her by reason of debts or obligations incurred by him or her and from all expenses,
legal costs, and counsel fees unless provided to the contrary herein.
11. Counsel Fees, Costs and Expenses. Each party shall be responsible for his or her own
legal fees, costs and expenses incurred in connection with their separation and/or the dissolution of their
marriage.
12. Alimony. In exchange for and in consideration of the promises and representations made
hereunder, Husband and Wife hereby waive and release any and all right, title, interest, claims or
demand of whatsoever nature which he or she now has or hereafter can, shall or may have against the
other or the respective separate property of the other under the laws of the Commonwealth of
Pennsylvania or any other governing state, country, territory or jurisdiction in the nature of spousal
support, separate maintenance or support, alimony, either pendente lite, temporary, rehabilitative,
6
permanent or lump sum and right to seek equitable or community distribution or division or assignment
of property or similar marital rights. The spousal support order currently in effect through the
Cumberland County Domestic Relations Office docketed at Number 00520 S 2005 shall be terminated
as of the date the court enters the decree in divorce or November 7, 2008, whichever occurs first.
13. Full Disclosure. The respective parties do hereby warrant, represent and declare and do
acknowledge and agree that each is and has been fully and completely informed of and is familiar with
and cognizant of the wealth, real and/or personal property, estate and assets, earnings and income of the
other and that each has made a full and complete disclosure to the other of his or her entire assets and
liabilities and any further enumeration or statement thereof in this Agreement is specifically waived.
14. Releases. Each party does hereby remise, release, quitclaim and forever discharge the
other and the estate of the other from any and every claim that each other may now have, or hereafter
have or can have at any time, against the other, or in and to or against the other's estate, or any part
thereof, whether arising out of any former contracts, engagements or liabilities of the other, or by way of
dower or claim in the nature of dower, widow's rights, or under the intestate laws, or the right to take
against each other's will, or for support or maintenance, or of any other nature whatsoever, except any
rights accruing under this Agreement.
15. Indemnification. Each party represents and warrants to the other that he or she has not
incurred any debt, obligation, or other liability, other than described in this Agreement, on which the
other party is or may be liable. Each party covenants and agrees that if any claim, action or proceeding
is hereinafter initiated seeking to hold the other party liable for any other debts, obligations, liability, act
or omission of such party, such party will at his or her sole expense, defend the other against any such
7
claim or demand, whether or not well-founded, and that he or she will indemnify and hold harmless the
other party in respect of all damages as resulting therefrom. Damages as used herein shall include any
claim, action, demand, loss, cost, expense, penalty, and other damage, including without limitation,
counsel fees and other costs and expenses reasonably incurred in investigating or attempting to avoid
same or in opposing the imposition thereof or enforcing this indemnity, resulting to Husband or Wife
from any inaccurate representation made by or on behalf of either Husband or Wife to the other in this
Agreement, any breach of any of the warranties made by Husband or Wife in this Agreement, or breach
or default in performance by Husband or Wife of any of the obligations to be performed by such party
hereunder. The Husband or Wife agrees to give the other prompt written notice of any litigation
threatened or instituted against either party which might constitute the basis for a claim for indemnity
pursuant to the terms of this Agreement.
16. General Provisions. This Agreement constitutes the entire understanding of the parties
and supersedes any and all prior agreements and negotiations between them. There are no
representations or warranties other than those expressly set forth herein.
17. Fair and Equitable Contents. The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective counsel. Each party acknowledges that he or
she has received independent legal advice from counsel of his or her selection and that each fully
understands the facts and has been fully informed as to his or her legal rights and obligations. Each
party acknowledges and accepts that this Agreement is, under the circumstances, fair and equitable, and
that it is being entered into freely and voluntarily after having received such advice and with such
knowledge, and that execution of this agreement is not the result of any duress or undue influence and
8
that it is not the result of any collusion or improper or illegal agreement or agreements.
18. Breach. It is expressly stipulated that if either party fails in the due performance of any
of his or her material obligations under this Agreement, the other party shall have the right, at his or her
election, to sue for damages for breach thereof, to sue for specific performance, or to seek any other legal
remedies as may be available, and the defaulting party shall pay the reasonable legal fees for any services
rendered by the non-defaulting party's attorney in any action or proceeding to compel performance
hereunder.
19. Execution of Documents. Each party shall on demand execute any other documents that
may be necessary or advisable to carry out the provisions of this Agreement.
20. Modification. No modification, rescission or amendment to this Agreement shall be
effective unless in writing signed by each of the parties hereto.
21. Severability. If any provision of this Agreement is held by a Court of competent
jurisdiction to be void, invalid or unenforceable, the remaining provisions hereof shall nevertheless
survive and continue in full force and effect without being impaired or invalidated in any way.
22. Applicable Law. This Agreement shall be construed under the laws of the
Commonwealth of Pennsylvania.
23. Agreement Not to be Merged. This Agreement may be filed with the Court for
incorporation into the Decree of Divorce for purposes of enforcement only, but otherwise shall not be
merged into said Decree. The parties shall have the right to enforce this Agreement under the Divorce
Code of 1980, as amended, and in addition, shall retain any remedies in law or in equity under this
Agreement as an independent contract. Such remedies in law or equity are specifically not waived or
9
released.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year
first above written.
Witness:
Paula Lehmer
?e
Thomas Lehmer
10
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
. ss.
Personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and
County, Paula Lehmer, who being duly sworn according to law deposes and says that she is a party of
the foregoing Agreement and she executed same for the purposes therein contained.
Witness my hand and seal this a ?st day of O'Ch e'r , 2008.
Not Pu is
My Commission Expires:
NOiMMAt on
NOW vieft
?l
up ;== OWN" ja so "*,I
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
. SS.
Personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and
County, Thomas Lehmer, who being duly sworn according to law deposes and says that he is a party of
the foregoing Agreement and he executed same for the purposes therein contained.
Witness my hand and seal this ? 1 day of CK- , 2008.
Notary Ptolic
My
COMMONW A TN of PEN BYLVANA
11 ?`oobbirtel seal
Vicky L. Fitz, Notary Public
Susquehanna TwP., Dauphin
My Commission Exores Jan. 6,22011
Member, Pennsylvania Association of Notaries
C--
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2? c
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am
y
PAULA ANN LEHMER,
Plaintiff
V.
THOMAS DAVID LEHMER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: IN DIVORCE
NO. 2005-3544
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)
3301(d)(1) of the Diveree Code.
(Strike out inapplicable section).
2. Date and manner of service of the Complaint: by Acceptance of Service on July 27, 2006.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the Affidavit of Consent required by §3301 (c) of the Divorce
Code: by Plaintiff: 08/15/08 by Defendant: 10/13/08
(b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code:
(2) Date of filing and service of the plaintiffs affidavit upon the respondent:
4. Related claims pending: none
5. Complete either (a) or (b)
(a) Date and manner of service of the notice of intention to file Praecipe to Transmit
record, a copy of which is attached:
(b) Date of plaintiffs Waiver of Notice in §3301 (c) Divorce was filed with the
Prothonotary: August 21, 2008
Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the
Prothonotary: October 14, 2008
v
Hannah Herman-Snyder, Esq ire
GRIFFIE & ASSOCIATES
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
Paula Ann Lehmer,
Plaintiff
N O. 2005-3544
VERSUS
Thomas David Lehmer
Defendant
DECREE IN
DIVORCE
AND NOW, Nor?...Gv `/- , 2001 , IT IS ORDERED AND
DECREED THAT Paula Ann Lehmer
PLAINTIFF,
AND Thomas David Lehmer 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;
The parties' Property Settlement Agreement entered into on
October 21, 2008 is incorporated herein, but not merged.
BY THE OOURT:
ATTE
PROTHONOTARY
-% 'Opr?
PAULA ANN LEHMER,
Plaintiff
V.
THOMAS DAVID LEHMER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
IN DIVORCE ?a3
rn?
2005-3544
NO
.
IN DIVORCE
r-:
4c:)
5c w aM
NOTICE TO RESUME PRIOR SURNAME '
q N3
V
Notice is hereby given that the Plaintiff in the above matter, [select one by marking "X"]
prior to the entry of a Final Decree in Divorce,
or X after the entry of a Final Decree in Divorce, hereby elects to resume the
prior surname of PAULA A. STUM, and gives this written notice avowing her intention
pursuant to the provisions of 54 P.S. 704.
DATE: v2 II A
PAULA A. LEHMER
V?J/ I / 1?1
PAULA A. STUM
COMMONWEALTH OF PENNSYLVANIA :
COUNTY OF CUMBERLAND
SS.
On this, the day of , 2011, before me the undersigned
officer, personally appeared PAULA A. LEHMER, now known as PAULA. A. STUM, known to
me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing
instrument and acknowledge that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
1
of Public
COMMONWEALTH OF PENNSYLVANIA
Nohnsoi $ai
Sharon K. Johnson. Notary Pubtlc vek a ll.6v P d a
City of Harrisburg. Dauphin County
22
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4'v
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res. N
My Commission Exp
Member. Pennsylvania 9;&o ,Ition of WItarles uZ
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