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Home My WebLink About05-5680 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA JONATHAN M. LEHRIAN Plaintiff Civil Action Law -vs- NO. C~ - StJO Ctt..>~l<-Y-<fA-,,",,\ BRANDI L. LEHRIAN Defendant IN DIVORCE aV.ffi. NOTICE TO DEFEND AND CLAIM RIGHTS TO: Brandi 1. Lehrian, Defendant You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. Ajudgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Chambersburg, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER=S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Pennsylvania Bar Association-Lawyer Referral Service Telephone 1-800-692-7375 (PAonly) or 717-238-6715 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 the Prothonotary's Office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend any scheduled conference or hearing. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA JONATHAN M. LEHRIAN Plaintiff Civil Action Law -vs- NO. o S' -.r~ C,u~LI~ BRANDI L. LEHRIAN Defendant IN DIVORCE av.m. COMPLAINT UNDER SECTION 3301(C) OR (D) OF THE DIVORCE CODE IRRETRIEVABLE BREAKDOWN NOW comes the Plaintiff and for cause of action against the Defendant says: I. The Plaintiff is Jonathan M. Lehrian, an adult individual who currently resides at 107 Vaughn Road, Shippensburg, Franklin County, Pennsylvania 17257 since January 2001. 2. The Defendant is Brandi L. Lehrian, an adult individual who currently resides at 586 Mauch Chunk Road, Palmerton, Carbon County, Pennsylvania since September, 2005. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 6, 2003 in Newburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised ofthe availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. The Defendant is not a member of the Armed Services of the United States or any of its Allies. Respectfully subrni tted, Reichard Law Offices, LLC D.~MJ Attorney 10 # 07324 Attorney for Plaintiff 70 West King Street Chambersburg, P A 17201 (717)267-2288 VERIFICATION I hereby veri fy that the facts set forth in the foregoing Document are true to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: / t- ,) '( - 65' ~... ~--:':"'"::::::"-- Jofi~th; M~ ehriaJ1 L~- -- /' P -IQ ....~ ~ 8 -- () g N ~ t ';";; cf' ..... ~'"~ :x :r:" \l -r1 '-~,.1 c:> rll-:=: r{)f:" ..:: -01,-, (> t')s I -roy 6u ~ - :-2:i, -<;... ~. r-~\_ -u 90 ~ <- ::>:c ...c::: 1;(-,: .;<.-m ~ ~'C,I r:':' S ,,~ s::; ,> '--J ~ $7 ::< ): U\ -+- -L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JONATHAN M. LEHRIAN Plaintiff Civil Action Law -vs- NO. 05-5680 Civil Term BRANDI L. LEHRIAN, Defendant IN DIVORCE aV.m. NOTICE TO DEFEND AND CLAIM RIGHTS TO: Brandi L. Lehrian, Defendant You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown ofthe marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Pennsylvania Bar Association-Lawyer Referral Service Telephone 1-800-692-7375 (PA only) or 717-238-6715 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 the Prothonotary's Office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend any scheduled conference or hearing. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA JONATHAN M. LEHRIAN, Plaintiff Civil Action Law -vs- NO. 05-5680 Civil Term BRANDI L LEHRIAN, Defendant IN DIVORCE aV.m. AMENDED COMPLAINT UNDER SECTION 3301(C) OR (0) OF THE DIVORCE CODE NOW comes the Plaintiff Jonathan M. Lehrian by and through his attorney D. Lloyd Reichard, 11, Esquire and hereby amends the Complaint previously filed in the above captioned action Under Section 3301 (C) or (D) of the Divorce Code as follows: I The allegations set forth in Paragraph I is amended as follows: "The Plaintiff is Jonathan M. Lehrian, an adult individual who currently resides at 107 Vaughn Road, Shippensburg, Cumberland County, Pennsylvania 17257 since January 2001. 2 The allegations set forth in Paragraphs 2 thru 8 the Complaint filed on November I, 2005 are restated and incorporated here by reference. Respectfully submitted, Reichard Law Offices, LLC ~-/ D. r: oyd Reichard II, Esquire /' Attorney ID # 07324 Attorney for Plaintiff 70 West King Street Chambers burg, PAl 720 1 (717)267-2288 VERI FICA nON 1 hereby verify that the facts set forth in the foregoing Document are true to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: II-FI - ()!; /~~ ~than M. Lehrian .-------- c) ....(\ ~- I:?, C'" '-~J _,r ~ t;~: (') <.:;J - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JONATHAN M. LEHRIAN Plaintiff Civil Action Law -vs- NO. F.R. 2005-5680 BRANDI L LEHRIAN, Defendant IN DIVORCE aV.m. VERIFICATION OF SERVICE I, D. Lloyd Reichard, II, Esquire, the attorney for Plaintiff, Jonathan M. Lehrian, in the above-captioned action, hereby verify that a copy of the Divorce Complaint was served on Defendant, Brandi L. Lehrian, by Certified Mail return receipt at 586 Mauch Church Road, Palmerton, Pennsylvania on November 21, 2005. Said Return mail receipt is attached hereto and made a part hereof. I verify that the statements in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA C.S. S 4904, relating to unsworn falsification to authorities. By: D. L d eichard, II, Esquire 70 West King Street Chambersburg, PA 17201 (717) 267-2288 Attorney for Jonathan M. Lehrian IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JONATHAN M. LEHRIAN Plaintiff Civil Action Law -vs- NO. FR 2005-5680 BRANDI L. LEHRIAN, Defendant IN DIVORCE aV.m. VERIFICATION OF SERVICE \ . Complete ~ems 1, 2, and 3. Also complete item 4 n Restricted Delivery Is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mall piece, or on the front W space pennils. 1. Article Addressed to: . ~~ Lcl1 i'QM 5~Co ""MeA (1Ui\ Ie ReI.. ~~~'l\ ~~ I&D1I 3. Serv.5' 1ype ~ Mall 0 Expnls8 Mall o Reg_ 0 Return RoooIpt for MerchandISe o Insured Mall Cl C.O.D. 4. Roslnc;ted DelIve1y? (Exl18 Fee) .. . 2.. Article Number (Transferrromseivlool8be1) PS Form 3811. Augus12001 7003 1680 0004 7782 9855 DomestIc Retum.Receipt 102595-02.M-1540 !.)as. Postal Service," CERTIFIED MAIL" RECEIPT (Domestic Mall Only, No Insurance Coverage ProVIded) U1 U1 <0 IT" ru <0 I'- I'- =r- D D o Return Reciept Fee (Endorsement Required) o Restricted Delivery Fee t:O (Endorsement Required) .ll .-'l Certified Fee ~' ( .~ '\ 1:silit/ \ Here, ~ , Total Postage & Fees $ rn ~ sen'~JY~_leh_UM:>.______m_____.___m___. ~;~~€::,:t__~~_(q__l'0lW_lh___~~_Ktl--- City. Sta". ZIP+4 10 p 14 \ '60'1 \ t," , ( ..: -< .1 C~ . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JONATHAN M. LEHRIAN Plaintiff Civil Action Law -vs- NO. 05-5680 Civil Term BRANDI L. LEHRIAN, Defendant IN DNORCE aV.m. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 63301(C) OF THE DIVORCE CODE I. I consent to the entry of a final divorce decree without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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 made hereunder are subject to the penalties of 18 P A C.S. Section 4904 relating to unsworn falsification to authorities. DATE ~/2ozl~ / /~N "" -~, ~.' on -, ~-~l :.c: <::;:;.::1 (:;,}". c_ I Ui '_n" ..,., N co IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JONATHAN M. LEHRIAN Plaintiff Civil Action Law -vs- NO. 05-5680 Civil Term BRANDI L. LEHRIAN, Defendant IN DIVORCE aV.m. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final divorce decree without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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 ofthe 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 made hereunder are subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. DATE 6b8/;:)e;o{p ! I 1i;..iL~ r-' ~~ {:)~~ (-::;:. {^-. " \ (.J'.. ---, -;;:- <r:~' -- G::' '.:,:'"6 -:;:;4" f:\~:, -"~',".^,- BRANDI L. LEHRIAN, Defendant IN DIVORCE aV.m. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JONATHAN M. LEHRIAN Plaintiff Civil Action Law -vs- NO. 05-5680 Civil Term AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) was filed on November I, 2005. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce as I have waived notice of intention to request entry of divorce decree under 3301(c) of the Divorce Code. I verify that the statements made in this affidavit are true and correct. I understand that false statements made hereunder are subject to the penalties of 18 P A C.S. Section 4904 relating to unsworn falsification to authorities. DATE 1~~ I ~~ !-.~ 2~ c:.~ c,-. . 11 :i~~ .'-1 :-- c:' - JONATHAN M. LEHRIAN Plaintiff Civil Action Law IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA -vs- NO. 05-5680 Civil Term BRANDI L. LEHRlAN, Defendant IN DIVORCE aV.m. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330l(c) was filed on November 1, 2005. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce as I have waived notice of intention to request entry of divorce decree under 3301 (c) of the Divorce Code. I verify that the statements made in this affidavit are true and correct. I understand that false statements made hereunder are subject to the penalties of 18 P A C.S. Section 4904 relating to unsworn falsification to authorities. DATE ~ 1eJ. d t!).ool. ! / IJ.A; ~ JJJ BRAND L. LEHRlAN '-- c: "co (:"::::J <) q c.... c (,~ . j-"-. ::::1 ?~l iJJ -:--> i"T~ . : ('-::,~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JONATHAN M. LEHRlAN Plaintiff Civil Action Law -vs- NO. F.R. 2005-5680 BRANDI L. LEHRlAN, Defendant IN DIVORCE av.m. ., ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint Under Section 3301 (C) or (D) of the Divorce Code. Respectfully submitted, Date: II, .:13 - 6-5 p~k Brandi Lehrian 586 Mauch Chunk Road Palmerton, PA 18071 . loyd eichard, II, Esquire 70 West King Street Chambersburg, P A 17201 (717) 267-2288 Attorney for Plaintiff o <. '"'"'.' "" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JONATHAN M. LEHRIAN, Plaintiff CIVIL ACTION - LAW vs. No. 05-5680 Civil Term BRANDIL.LE~ Defendant In Divorce a.v.m 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. Grounds for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the como1aint: The Complaint was filed on November 1,2005; service was accepted by the Defendant on November 21, 2005. An Amended Complaint was filed on November 16, 2005, service of the Amended Complaint was accepted by the Defendant, on November 23, 2005 at 586 Mauch Chunk Road, Palmerton, P A 18071. 3. Date of execution of the affidavit reauired bv Section 3301(c) of the Divorce Code: The date of execution ofthe affidavit required by Section 3301(c) of the Divorce Code: by Plaintiff on July 3, 2006 and by Defendant on June 28, 2006. 4. Related claims oending: Equitable Distribution, Attorney Fees, Alimony and Alimony Pendente Lite; 5. Date Plaintiffs Waiver of Notice and Affidavit of Consent were filed with the Prothonotary: . July 11, 2006 Date Defendant's Waiver of Notice and Affidavit of Consent were filed with the Prothonotary: July 11, 2006 Respectfully submitted: ~~~ Attorney ill #07324 70 West King Street Chambersburg, PA 17201 Attorney for Plaintiff e I ~ .i: ,.. :;:I ~T "'. as"l - &i~ .!.a ~ ~c ~ i8 ~ ~. ~ :.n i ~ . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF JONATHAN M. LEHRIAN, Plaintiff VERSUS BRANDI L. LEHRIAN, Defendant . . . . . AND NOW, DECREED THAT . AND Brandi L. Lehrian . PENNA. No. 05-5680 . DECREE IN DIVORCE ~ c:Jl/. 'otp.;fIt . ~ ,IT IS ORDERED AND . ~7 Jonathan M. Lehrian , PLAINTIFF, , 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; . . . . -/17 ",?<""'-' "r trr:-' ~ . ..,;fiP 7 ~ ~ '17. U/.~ fir "2-~ "'" -1"1 'Xl QI $