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Home My WebLink About05-4009JULIE E. LECHNER, : IN THE COURT OF COMMON PLEAS OF Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW 2005 - 4~9 CIVIL TERM KEVIN R. LECHNER, Defendant. IN DIVORCE NOTICE 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 in 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 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 FH.E 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, Pennsylvania 17013 717-249-3166 1-800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland 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 office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. JULIE E. LECHNER, Plaintiff, v. IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA . CIVIL ACTION -LAW zoos - yon r cIVIL TERM KEVIN R. LECHNER, Defendant. IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO 'IONS 3301 C A1VD ~D OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Julie E. Lechner, by and through her attorneys, Irwin, & McKnight, and files this Complaint in Divorce against the Defendant, Kevin R. Lechner, representing as follows: 1. The Plaintiff is Julie E. Lechner, an adult individual residing at 251 Wagner Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Kevin R. Lechner, an adult individual currently residing at 29 Heritage Drive, Carlisle, Cumberland County, Pennsylvania 17013 3. The Plaintiff and Defendant have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The Plaintiff and the Defendant were married on April 9, 1994, in Lawrence County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Pursuant to the Divorce Code, Sections 3301(c) and 3301(d), the Plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 7. The Plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the Plaintiff respectfully requests judgment dissolving the marriage between the two parties. Respectfully submitted, IRWIN Bc McKNIGAT Dated: August 4, 2005 By:,~' " - ~~ Ma u . Mc t, III, Esquire Su rem Court I.D. No. 5476 West Po et Profession Building 60 West Po et Street Cazlisle, Pennsy 'a 1701 -3222 (717) 249-2353 VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by counsel and myself in the preparation of this action. I have head the statements made in this document and they are true and correct to the best of my lmowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. n r ~ ~ N, IE E. LECH Date: August 4, 2005 JULIE E. LECHNER, Plaintiff, v. KEVIN R. LECHNER, Defendant. IN THE COURT OF COMMON PLEAS Or' : CUMBERLAND COUNTY, PENNSYLVANIA , CIVIL ACTION -LAW . 2005 - CIVIL TERM . IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: L I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsificafion to authorities. Date: August 4, 2005 ' r ~ / ' L ' JiJ ~ E. LECHNE `~ J' ~~/q~ ~~ h) 1 ~ (:Ln ~ l ~ cs; T ~ '~ V ~ V '-ti'° [-_7 ~ ~~ ~ ~~~ ~ L 9J ~ F ~ ~_l ~!~t ~ ilms ~ - ~.~~ W C., JULIE E. LECHNER, Plaintiff IN THE COUP:T OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 2005-4009 CIVIL TERM KEVIN R. LECHNER, Defendant AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. ]1920.4 (al(Il(i) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CIVIL ACTION -LAW IN DIVORCE . S5: NOW, Mazcus A. McKnight, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the captioned action in divorce. 2. That a certified copy of the Complaint in Divorce was served upon the defendant, Kevin R. Lechner, on August 9, 2005, by certified, restricted delivery mail, addressed to him at Cazlisle Farm Service, 260 York Road, Caziisle, Pennsylvania 17013, with Return Receipt Number 7003 3110 0004 5770 5544. 3. That the said receipt for certified mail is signed and. attached hereto and made a part hereof. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 F'a. C. S. Section 4904, relating to unsworn falsificafion to authorities. ~ // MAdZCUS A.(~c T, III, ESQUIRE Attorney for Rliinti Date: August 10, 2005 -, r ~ - ~ ~Z ~ l~ ~, ~ ° e~.~- ~loli ~, ~ ~ ro.upe , s .1n0 ~ O CattlOetl Faa `~ ~ 3 p s `, ~ ~ (E~onM~ent~Hepuhad) - t ...../ 5 ~ ° ~@r~ l ~;Il/iltl4~!~~~ ° ~ op. ~„ 3.5~ ~ .„~~~~ "~ ram roww m Fba $ I S y c~ m c~ °o °REVIN & L1iCHI1ER p -- t u °---•~° --- r 3~gid~E"F/1RF1"SS&PIC6' """ m~~__ '--_ ............. PA 17013 n o Qri c ~ m~ -~ ~ ;o ~~ _ _;~ f? v +r ~ t`~ {4 JULIE E. LECHNER, PlaintifflPetitioner v. IN THE COURT OF COMMON PLEA5 OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 2005-4009 CIVIL TERM KEVIN R LECHNER, Defendant/Respondent PROTECTION FROM ABUSE PETITION FOR PROTECTIVE ORDER AND NOW comes the Plaintiff/Petitioner, JULIE E. LECHNER, by her attorneys, Irwin & McKnight, Esquires, and presents this Petition for a Protective Order under the Protection from Abuse Act, 23 Pa.C.S.A. Section 6101 et seq., representing as follows: 1. The Petitioner is JULIE E. LECHNER, an adult individual presently residing at 251 Wagner Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Respondent is KEVIN R LECHNER, an adult individual whose last known address is 251 Wagner Drive, Carlisle, Pennsylvania17013. 3. The parties have been involved in divorce and custody court actions in the Court of Common Pleas, Cumberland County, Pennsylvania. The divorce matter is filed at 2005-4009 and the custody action is filed at OS-3303. 4. The parties are the parents of the following minor children: a. ANDREW K LECFINER, born December 30, 1994 b. ADAM D. LECHNER, born October 24, 1996 c. MEGAN D. LECHNER, born February 5, 2002 5. The parties had been separated May 31, 2005 until March 15, 2006. On March 15, 2006 Respondent returned to the marital home and has refused to attend counseling. Since his return the Respondent has grown angry and his outbursts have become more frequent and have been directed at both the Petitioner and the children. 6. The Petitioner and her minor children has been placed in fear of serious bodily injury due to the Respondent's threats and abuse and his abusive behavior. 7. On May 13, 2006, when the Respondent returned home, he became angry when the Petitioner had moved some of his belongings from the bedroom to the basement. 8. The Respondent became angry and directed his anger toward the Petitioner by pushing her against the doorway to the bedroom causing multiple bruising on the Petitioners upper body. 9. The Petitioner fears for the welfare of herself and her children in light of the Respondent's recent behavior since he returned to the marital home. WHEREFORE, Petitioner respectfully requests this Honorable Court to enter an order providing that a. Respondent shall not abuse, stalk, harass, andJor threaten the Petitioner, her minor children, and her relatives, in any place where they maybe found; Respondent is prohibited from having any contact with the Petitioner, her minor children, and her relatives, at any location including but not limited to home, school, or place of employment; c. Respondent is prohibited from contacting the Petitioner, her minor children, and her relatives by telephone or by any other means, including through third parties; d. Respondent's physical custody of the minor children be suspended until the Respondent successfully completes anger management counseling; e. The Petitioner is granted exclusive possession of the marital home at 251 Wagner Drive, Carlisle, Pennsylvania 17013; E The Respondent is prohibited from possessing andfor purchasing a firearm or other weapon; and g. Such other relief as this Court deems necessary. Respectfully submitted, IRWIN & McI{NIGHT B .l ~ ~i Y~ Marcus A. Mc t, II Esquire Supreme Court LD. 547b Attorney for Petitioner 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 717-249-2353 Date: May 16, 2006 VERIFICATION The foregoing document is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. . ~ CQ.cJ J IE E. LECHNER Date: 05 = ~~ - , 2006 C7 a ~~ ~ Gy ~~ n, i ~t l _. ~3C 7%•~._., !" (xi ~; .. ~~ 'Y] ~ 1. A[Ll _~ G C7 ~~ ^'~ .~ MAY 18 2006,.,,,,/ JULIE E. LECHNER, Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. KEVIN R. LECHNER, Defendant/Respondent CIVIL ACTION - LAW 2005-4009 CIVIL TERM PROTECTION FROM ABUSE DTEMPORARY PROTECTIVE ORDER AND NOW, this ~ U~day of May, 2006, upon presentation and consideration of the within Petition, and upon fording that Plaintiff/Petitioner, JULIE E. LECHNER , r •-..:.~-ia.,,~ r,....,.., ~,., - • is in immediate and present danger of abuse from the DefendanURespondent, KEVIN R LECHNER, the following Temporary Order is entered: The Defendant/Respondent, KEVIN R LECHNER, whose date of birth is August 10, 1970, social security number 189-60-3936, whose last known address was 251 Wagner Drive, Cazlisle, Pennsylvania 17013, is hereby enjoined from physically abusing, stalking, harassing, or threatening the Plaintiff/Petitioner, JUL1E E. LECHNER , i placing Uh~rtt in fear of abuse > , , Aatitionet3t her ho ennsylvattia nr at her 1 er The DefendantlKespondent is hereby notified that if he fails to follow this Order, he may be in induect cr;m;r,al contempt, which is punishable by a fine not to exceed $1,000.00 and/or by a sentence of up to six months in j ail and any other appropriate punishment. This Order shall remain in effect until a final order is entered in this case. A hearing shall be held on this matter on the ~y= day of , 2006, at~~.m. in Courtroom No. a- , Cumberland County Courthouse, Carlisle, Pennsylvania. The Cumberland County Sheriffs Office shall attempt to make service at the Plaintiff/Petitioner's request. The Prothonotary's Office is not to attempt to make service by mail. The North Middleton Township Police Department will be provided with a copy of this Order by attorney for Plaintiff/Petitioner. This Order shall be enforced by any law enforcement agency where a violation occurs by arrest for indirect criminal contempt without warrant upon probable cause that this Order has been violated, whether or not the violation is committed in the presence of the police officer. In the event that an arrest is made under this section, the Defendant/Respondent shall be taken without unnecessary delay before the court that issued the Order. When that court is unavailable, the Defendant/Respondent shall be arraigned before the appropriate district justice. (23 Pa.C.S.A. §6113). r ~p Ki~f`;I,~1 t;C~~jTti~,~l rt.l.+V~' 3~' ' rt~f~'~'1J 6Z .~ ld~ 81 A~rkd 9~~~ ~;d~~~r~~;:~.~.o~~d ~ ~a ~~.~~c~o~~~ BROADCAST REPORT TIME 05/18/2006 09:29 NAME PROTHONOTARY C LONG FAX 7172406573 TEL SER.k BRDH3J606381 PAGE(S) 04 I DATE TIME FAX ND.lhJAME DURATION PAGES? RESULT CDMMEN7 05/16 05/18 09:27 09:25 PSP CENTRAL PR05SIN 43 01:04 04 04 OK DK ECM ECM BUSY: BUSY/ND RESPONSE NG PDDR LINE CONDITION C'V COVERPAGE PC PC-FAX JULIE E. LECHNER, : IN THE COURT OF COMMON PLEAS OF Plaintiff%Petitioner CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2005-4009 CIVIL TERM KEVIN R. LECHNER, Defendant/Respondent PROTECTION FROM ABUSE ORDER OF COURT AND NOW, this ~~ day of May, 2006, upon the request of the parties the Protection From Abuse Hearing set for May 24, 2006 at 1:30 p.m. has been continued and rescheduled for June 26, 2006 at 1:30 p.m. The Order dated May 18, 2006, remains in full effect and force. BY THE COURT Edgaz B. Bayley, as M. Clark, Esquire azcus A. McKnight, III, Esquire ~~ 0`~~ a ..7 f- d is tLt = elr +~ 1:.. al. ~ ~_ ': ~~)~. r '. ~~ ti. y a N - .i1 t F- ~ i. W o t~..~i ~ v '~.<: \^~. ;~, j ~; >, JULIE E. LECHNER, Plaintiff v. KEVIN R. LECHNER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 2005-4009 CIVIL TERM IN DIVORCE MOTION FOR APPOINTMENT OF MASTER JULIE E. LECHNER, Plaintiff, moves the court to appoint a master with respect to the following claims: a. Equitable distribution of the marital assets; b. Costs and expenses; and c. Counsel fees. and in support of the motion states: 1. Discovery is complete as the claims(s) for which the appointment of a master is requested. 2. The Plaintiff, Julie E. Lechner, has appeared in this action by her attorney, Marcus A. McKnight, III, Esquire. 3. The statutory ground for divorce is No-Fault 3301(c). 4. Delete the inapplicable paragraph(s): a. The action is contested. b. An agreement has been reached with respect to the following claims: Divorce c. The action is contested with respect to the following claims: Equitable distribution of the marital assets; Costs and expenses; and. Counsel fees. 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take one-half (lh) day. 7. Additional information, if any, relevant to the motiq~: N Date: June 26, 2006 Plaintiff AND NOW the following claims: Esquire, is appointed Divorce Master with respect to By the Court: J. r,~ r"" "` -]~ _ ~~ ~ ._, •. - C -"~ ; 1 i . ~ "., :'J • ~'y~ . JULIE E. LECHNER, Plaintiff v. KEVIN R. LECHNER, Defendant CIVIL ACTION -LAW 2005-4009 CIVIL TERM IN DIVORCE PETITION FOR ECONOMIC RELIEF AND NOW, this 26th day of June 2006, comes [he Petitioner, Julie E. Lechner, by her attorneys, 1RWIN & McKNIGHT, and makes the following Petition for Economic Relief against the Respondent, Kevin R. Lechner, as follows: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 1. The Petitioner is Julie E. Lechner who is the Plaintiff in a divorce action filed at Docket Number 2005-4009 in the Court of Common Pleas of Cumberland County, Pennsylvania. Her address is 251 Wagner Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Respondent is Kevin R. Lechner who is the Defendant in this divorce action. His address is 251 Wagner Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. The petitioner seeks the following relief from the Court: a. Equitable distributionef the marital assets; b. Costs and expenses; and c. Counsel fees. WHEREFORE, the Petitioner, Julie E. Lechner, requests the relief set forth above. Respectfully submitted, IRWIN & McI{NIGHT By: 60~st Pomfret Street C isle. PA 17013 71 Suprem rt I.D. No: Attorney for the Petitior Julie E. Lechner Date: June 26, 2006 VERIFICATION The foregoing document is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they aze true and correct to the best of my knowledge, information and belief. I understand that false statements herein made aze subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. J IE E. LEC E Date: ~~ ~~ W `y~ 1 C !` "' ~~, c} `•.` ~' -s U 1 r: ' -n ~, , r' ~, 't _ ~=. ri r {l1 ~J -~ li: ~...'..~~i. JULIE E. LECHNER, IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. KEVIN R. LECHNER, DEFENDANT 05-4009 CIVIL TERM ORDER OF COURT AND NOW, this ?ip day of June, 2006, the hearing scheduled for this date is cancelled and rescheduled for Monday, July 3, 2006, at 2:30 p.m., in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania. ,~fGarcus A. McKnight, III, Esquire For Plaintiff ;/Thomas M. Clark, Esquire For Defendant ~ :sal O~ SY} ~' ~~ L. ~. - ~ i-f TJ 'l{T, .1.. ~7 ': I ,.'. `^ ;~ ('ti G. r'~- :~ > Y (~ ~- JULIE E. LECHNER, Plaintiff v. KEVIN R. LECHNER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 2005-4009 CIVIL TERM IN DIVORCE MOTION FOR APPOINTMENT OF MASTER JULIE E. LECHNER, Plaintiff, moves the court to appoint a master with respect to the following claims: a. Equitable distribution of the marital assets; b. Costs and expenses; and c. Counsel fees. and in support of the motion states: 1. Discovery is complete as the claims(s) for which the appointment of a master is requested. 2. The Plaintiff, Julie E. Lechner, has appeazed in this action by her attorney, Marcus A. McKnight, III, Esquire. 3. The statutory ground for divorce is No-Fault 3301(c). 4. Delete the inapplicable pazagraph(s): a. The action is contested. b. An agreement has been reached with respect to the following claims: Divorce c. The action is contested with respect to the following claims: Equitable distribution of the marital assets; Costs and expenses; and Counsel fees. 5. 6. Date: The action does not involve complex issues of law or fact. The hearing is expected to take one-half ('h) day. Additional information, if any, relevant to the moti June 26, 2006 ._~ AND NOW the followi clazms: pho o`~ is appointed Divorce Master with respect to ~. r-> G~ ~ ~' ,. .J _~ ~~, r„~ ;., ;-; i~> ._ ~,,-„ <.:_ f -s >- -- ~-.- r:= -- _ . , t ,~, - :,~ ~- `- _~ ; r- ,. -> <.J c ~ Cj cN Q~ JULIE E. LECHNER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW KEVIN R. LECHNER, Defendant 05-4009 CIVIL TERM ORDER OF COURT AND NOW, this 3rd day of July, 2006, the petition for a protection from abuse order is denied. The petition is dismissed. The temporary order entered on May 18, 2006, is vacated. /Marcus A. McKnight, III, Esquire For Plaintiff /Thomas M. Clark, Esquire For Defendant Sheriff prs 6~, ~~ed . PLFF (~~ C~ '1~y~g P`~ `. f 7 ' ~~7 1 ,~ L I!7 l J~~~ _.J - ~.=„~ .a LL_ C~ ~ ~ ` TRANSMISSION VERIFICATION REPORT TIME 07/05/2006 15:49 NAME PROTHONOTARY C LONG FAX 7172406573 TEL SER.# BROH3J606381 DATE,TIME FAX NO./NAME DURATION PAGE(S) RESULT MODE 07105 15:49 9 24907799 2458792 00:00:18 02 OK STANDARD ECM OFFICE OF THE PROTHONOTARY GUNISERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA 1701.3-3357 (717) 240-G195 To: PSP, Central ProrPssin.g Fax# From: Cumberland County Prothonotary RE: Message: 2 No of pages (including cover sheet) This message is intended for the use of the individual or entity to which it is SHERIFF'S RETURN - REGULAR CASE NO: 2005-04009 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LECHNER JULIE E VS LECHNER KEVIN R WILLIAM CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon r T'n/"~TTTTL~D TIL~T7TTT ~ the DEFENDANT at 1321:00 HOURS, on the 18th day of May 2006 at CARLISLE FARM SERVICE CARLISLE, PA 17013 KEVIN R LECHNER by handing to a true and attested copy of PROTECTION FROM ABUSE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge !~ L,,_ h~ 02 y/C~ L. 260 YORK ROAD So Answers: 18.00 -'` ''`{`~•~ .00 10.00 R. Thomas Kline .00 32.40 00/00/0000 MCKNIGHT By. _ Deputy heriff JULIE E. LECHNER, Plaintiff v. KEVIN R. LECHNER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 2005-4009 CIVIL TERM . IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) and (d) of the Divorce Code was filed on August 5, 2005. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: March h~ , 2007 JULIE E. C ER ~ t~ r~ t >;i ~ o~ ~ .-_. , 4 ...~ ; - "Y ~F eo ~ ~~,) 11i \~ ~3 JULIE E. LECHNER, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 2005-4009 CIVIL TERM KEVIN R. LECHNER, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made aze subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: March ~ , 2007 JULIE E. C ER Plaintiff 1 --' .-a t t t- 7'~ ~~ ~''~ `~fa ( 1 _ _ $_- -_-r ~ ' `~ ._ ~ ~ ~..*=} JULIE E. LECHNER, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 2005-4009 CIVIL TERM KEVIN R. LECHNER, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) and (d) of the Divorce Code was filed on August 5, 2005. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are tnue and connect. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: March !~ , 2007 . E c`. ~-r °r~= 4. " ~n ~ __ i "m3 ~i . i y ~y 6wV r~-1 _• ~ ' Y '~" 3 _ f r. ' I .. ~ ~ 4. ~ry q r+ Ty: j j ~ ~ _ . ~ JULIE E. LECHNER, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 2005-4009 CIVIL TERM KEVIN R. LECHNER, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made aze subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: March _~ , 2007 IN R. LECHNER Defendant C'° ~ L~ -~, ~~ u.1 f4~ - .:" ~ ^ rt . ~....,. -- - +~ 171 ~'J " t G"J s ~"" L~~ ~"_ w..r. ~ !~"., _ •. ._1 ~. ~ ~iJ rr 4J ~ r JULIE E. LECHNER, Plaintiff vs. . KEVIN R. LECHNER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0. 05 - 4009 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this p~E{~ day of , 2007, the parties and counsel having entered into an agreement and stipulation resolving the economic issues on March 7, 2007, the date set for a four-party conference, the agreement and stipulation having been transcribed, and subsequently signed by the parties and counsel, the appointment of the Master is vacated and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent of the parties so that a final decree in divorce can be entered. BY THE COURT, ~ G Edgar B. Bayley, P.J. cc: arcus A. McKnight, III Attorney for Plaintiff ~omas M. Clark Attorney for Defendant ~o s. "~ b ~~ a~~ 0 C ~ 0 --~ ~~~. C.r~ :::'_ ~ .. ~~ -~ .,: ~ ~Y ~' <- i- ~ r-:-i C~" N C • JULIE E. LECHNER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. N0. 05 - 4009 CIVIL KEVIN R. LECHNER, Defendant IN DIVORCE THE MASTER: Today is Wednesday, March 7, 2007. This is the date set for a conference with counsel and the parties. Present in the hearing room are the Plaintiff, Julie E. Lechner, and her counsel Marcus A. McKnight, III, and the Defendant, Kevin R. Lechner, and his counsel Thomas M. Clark. A complaint in divorce was filed on August 5, 2005, raising grounds for divorce of irretrievable breakdown of the marriage. The Master has been provided affidavits of consent and waivers of notice of intention to request entry of divorce decree signed and dated today by both parties. The Master's office will file the originals with the Prothonotary's office. The divorce can, therefore, be concluded under Section 3301(c) of the Domestic Relations Code. On June 26, 2006, the Plaintiff filed a petition for economic relief raising claims of equitable distribution and costs and expenses. No claim has been raised by either .party for alimony. The Master has been advised that after negotiations this morning the parties have reached an 1 agreement with respect to the outstanding economic issues. The agreement is going to be placed on the record in the presence of the parties. The agreement as placed on the record will be considered the substantive agreement of the parties not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. After the agreement has been transcribed and reviewed for typographical errors, the draft will be sent to counsel to review for typographical errors, make any corrections as necessary, and then ask their clients to sign the agreement affirming the terms of settlement as stated on the record. In any event, when the parties leave the hearing room today they are bound by the terms of the agreement even though there is no subsequent signing of the agreement affirming the terms of settlement. Upon receipt by the Master of a completed agreement, the master will prepare an order vacating his appointment and counsel can then file a praecipe transmitting the record to the Court requesting a final decree in divorce. Mr. McKnight. MR. McKNIGHT: After extensive negotiations, we have come up with the following settlement: 1. The real estate will become the sole property of the wife. Husband agrees to sign a deed which he will place in the hands of his counsel, and wife will refinance the existing mortgage on the property into her own name and upon the time of the refinancing, husband's counsel will deliver 2 the deed to wife's counsel so that she can complete the refinancing. The refinancing will be accomplished by the end of June of 2007 or sooner. In addition to the mortgage, as part of the refinance, the Triple A credit card will be part of that refinancing and will be rolled into that. That credit card is a Visa card, No. 4264296282012548. In addition to that, from the amount refinanced, the new mortgage amount, husband will receive the sum of $6,000.00 in full satisfaction of his marital interest in the property and in other assets. 2. There is a family life insurance policy which husband agrees to sign over to the sole ownership of wife. Any cash value in the policy will be wife's property but she will be responsible for any payments that are due on that policy which is on the life of the parties and their children. It is a Prudential policy. 3. As far as other debt is concerned, the Chase credit card, last four digits 6842 will be the responsibility of the wife and the MBNA credit card, last four digits 8356 will be her sole responsibility. Husband is responsible solely for his Chase credit card, last four digits 9232. Each party agrees to hold harmless the other from any claims made by the credit card companies for payments made on the accounts that each party is assuming responsibility for. Julie Lechner will hold harmless Kevin Lechner from any claims on the Chase and MBNA credit card that she is responsible for; Kevin Lechner will hold harmless Julie Lechner from any claims made on the Chase credit card, 9232. Each will endeavor to put those credit cards in their name alone and eliminate any responsibility for the other party on those cards. 4. With regard to other assets, each one will keep their own IRA or employee benefit retirement plans. There is a small. retirement plan with husband's employer. He has an IRA account with Scudder and that will be his sole property. Wife has her own IRA or employee benefit accounts and a small stock -- employee stock ownership plan with her employer. Those will be her assets. Each party waives any right, title or interest in the assets of the other party's retirement assets as well as other personal property. 5. With regard to personal property, husband has certain items which we have identified as his .items in our pretrial, 3 that include things like the Farmall tractor, his demo car, Falcon car, red truck, Trail Blazer, wood working tools and chainsaw, the TV, VCR, green rocking chair, antique dresser, blue swivel chair, two plum lights. Those are things that he will take in addition to some wood that he has identified on the property. He will have to the end of June to remove those items. It is understood, however, that effective today, wife will have sole possession of the marital home and that he needs to have permission to come onto the property and he will identify dates when he wants to come back to the property to acquire his assets. All other assets on the property will be wife's with the understanding that there are several tools that wife needs to maintain the property, general things, shovels, small things. Wife is content that she can resolve that with husband. 6. Each party has their own life insurance policy; wife with Prudential and husband with Nationwide. Each party will maintain that in their own name. 7. Wife holds husband harmless and will assume responsibility for the personal loans to her parents and will hold harmless and indemnify husband from any claim made from those personal loans. 8. Each party will be responsible for their own counsel fees and waives any claim for counsel fees from the other. 9. Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of .any jurisdiction to share in the property or the estate of the other as a result of the marital relationship including without limitation, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. Each will at the request of the other execute,- acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights, and claims. MR. McKNIGHT: Julie, you understand the terms of this settlement? 4 MR. LECHNER: Yes. MR. McKNIGHT: You are .going to have the house refinanced, have the Triple A refinanced into the mortgage and pay him $6,0.00.00 at settlement? MRS. LECHNER: Yes. MR. McKNIGHT: And you have to the end of June to do it? MRS. LECHNER: Yes. MR. McKNIGHT: Are you satisfied with that settlement and all other terms contained therein? MRS. LECHNER: Yes. MR. McKNIGHT: And you are happy with your counsel and the help that I have given you? MRS. LECHNER: Yes. MR. CLARK: Kevin, if you can just state your name, please. MR. LECHNER: Kevin Lechner. MR. CLARK: You had a chance, obviously, we are entering into an agreement today, and you are aware of what that agreement is? MR. LECHNER: Yes. MR. CLARK: And you have heard it stated on the record. Is that the agreement that we spoke about just prior to putting it on the record? MR. LECHNER: Yes. 5 MR. CLARK: Just one clarification, I explained to you that equity in the home, there was approximately, based on our calculations .approximately $34,000.00 in equity in that home and you understand that what you are receiving today is $6,000.00 of that plus the Triple A credit card is being paid off? MR. LECHNER: Right. MR. CLARK: And you understand that? And that is something that you decided on as a settlement that you wanted to resolve this matter and you are willing to agree to that? MR. LECHNER: Right. MR. CLARK: And are you happy with my representation with you on this case? MR. LECHNER: Yes. MR. CLARK: And you are okay with the agreement as it was stated on the record? MR. LECHNER: Yes. THE MASTER: Since we are not going to have any signatures today on the agreement, you understand that 6 when you leave here today you are bound by this agreement even though. you have not signed it? MR. LECHNER: Yes. MRS. LECHNER: Yes. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code. DATE: Knight, III Plaintiff Thomas M. Clark Attorney for Defendant Oy /~ 07 `! O _ J ie E. Lec er e Kevin R. Lechner 7 WITNESS: JULIE E. LECHNER, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA • CIVIL ACTION -LAW v. 2005 - 4009 CIVIL TERM KEVIN R. LECHNER, 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 Divorce: irretrievable breakdown under Section 3301(c) and or (d) of the Divorce Code. 2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon the defendant, Kevin R. Lechner, on August 9, 2005, by certified, restricted delivery mail, addressed to him at Carlisle Farm Service, 260 York Road, Carlisle, Pennsylvania, 17013, with Return Receipt Number 7003 31100004 5770 5544. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by plaintiff: March 7, 2007; by defendant: March 7, 2007. (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: (b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: 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 plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: March 8, 2007 Date defendant's Waiver of Notice in Section 3301(c) Divorc was filed with the Prothonotary: March 8, 2007 arcu A. Mc ,Esquire Attorney for Plaintiff Date: May 2, 2007 n r.,~ o Q .T~ t-. ~ = N ~ m .~ 7 ~ ~ 11~I THE COURT OF' COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~~ PENNA. ~.: ~ H - ~. JOLIE E. LECHNER PLAINTIFF N o. Zoos - X009 VERSUS KEVIN R. LECHNER DEFENDANT DECREE [ 1`~I DIVORCE AND NOW, y ~~~~, IT IS ORDERED AND DECREED THAT JULIE E. LECHNER PLAT NTl FF, AND KEVIN R. LECHNER ,DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RASED OF RECORD IN THfS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; PROTHONOTARY n w q pf t r f V