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Home My WebLink About06-2162TIMOTHY SCOTT LEHMAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW KATHLEEN KATEKOVICH NO.) Defendant IN DIVORCE NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 Respectfully submitted, SAIDIS, FLOWER & LINDSAY SAIDIS, FLOWER & LINDSAY ATIDPNEYS•Ai•IpW 26 West High Street Carlisle, PA Va*, u Matas; squire Supreme Court ID # 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff TIMOTHY SCOTT LEHMAN Plaintiff vi KATHLEEN KATEKOVICH Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1 The Plaintiff is Timothy Scott Lehman, an adult individual residing at 2707 Wood Spring Drive, York, PA 17402. 2. The Defendant is Kathleen Katelovich, an adult individual residing at, 1780 Weatherburn Drive, New Cumberland, PA 17070. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 3, 1995 in Beaver County, Pennsylvania. 7. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 9. The Plaintiff has been advised that counseling is available and that she SAMIS, FLOWER & LINDSAY ATNRNfYS. Tluw 26 West High Street Carlisle, PA has the right to request that the court require the parties to participate in counseling. 10. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 of the Pennsylvania Divorce Code. Respectfully submitted, SAIDIS, FLOWER & LINDSAY Ma u Matas, squire Attod. 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Dated: A p Counsel for Plaintiff SAIDIS, FLOWER & LINDSAY nnowutvs•nrouw 26 Wrs, Fllgh Street Carlisle, PA CERTIFICATE OF SERVICE I, Marylou Matas, Esquire, of the law firm of SAIDIS, FLOWER & LINDSAY, hereby certify that on this date a copy of the attached document was served on the following individual, via certified mail, return receipt requested, postage prepaid, addressed as follows. Kathleen Katekovich 1780 Weatherburn Drive New Cumberland, PA 17070 SAIDIS, FLOWER & LINDSAY Marylou atas, Es#ire? Supreme-Court ID No. 84919 26 West High Street Carlisle, PA 17013 717-243-6222 SAIDIS, FLOWER &z LINDSAY ATN9NfV5.ALWW 26 Wm High Street Carlisle, PA 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. §4904, relating to unsworn falsifications to authorities. Timothy Sc tt Lehman ?'i , _ '?wy/yj? r T. ? ?? ?` ? ? ?} ? , " Y ti: e ,? ? ? ??. 1 TIMOTHY SCOTT LEHMAN, Plaintiff V. KATHLEEN KATEKOVICH Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint in the above-captioned matter SAMIS, FLOWER & LINDSAY ATIt)lUV M-0 LAW 26 West High Street Carlisle, PA Date Diane M. Dils, Esquire Attorney for the Defendant T-41 G v°` a TIMOTHY SCOTT LEHMAN, Plaintiff V. KATHLEEN KATEKOVICH LEHMAN, Defendant JN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :IN DIVORCE :NO. 06-2162 PRAECIPE FOR ENTRY OF APPEARANCE To the Prothonotary: Kindly enter the appearance of Elizabeth S. Beckley, Esquire, Charles O. Beckley, II, Esquire and Beckley & Madden, of Counsel, on behalf of the Defendant, Kathleen Katekovich Lehman, in the above-captioned matter. DATED: iz eth S. u' e Of Counsel BECKLEY & MADDEN 212 North Third Street I P.O. Box 11998 Charles O. Beckley, II, E ire Harrisburg, Pennsylvania 17108 (717) 233-7691 /III A? CERTIFICATE OF SERVICE I, Elizabeth S. Beckley, Esquire, hereby certify that a true and correct copy of the foregoing document was this day served upon the person and in the manner indicated below. SERVICE BY FIRST CLASS MAIL: Marylou Matas, Esquire Saidis, Flower & Lindsay 26 West High Street Carlisle, PA 17013 Diane M. Dils, Esquire Dils & Dils 1400 North Second Street First Floor Front Harrisburg, PA 17102 DATED: S7-3J-O) C 7 C ?a ,? U5 W < 1 ? w TIMOTHY SCOTT LEHMAN, Plaintiff/Respondent V. :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY :PENNSYLVANIA :CIVIL ACTION - LAW :1N DIVORCE KATHLEEN KATEKOVICH LEHMAN, : Defendant/Petitioner :NO. 06-2162 PETITION FOR EQUITABLE DISTRIBUTION, ALIMONY PENDENTE LITE, COUNSEL FEES, COSTS AND EXPENSES AND ALIMONY AND NOW comes the Defendant/Petitioner, Kathleen Katekovich Lehman, who, by and through her attorneys, Elizabeth S. Beckley, Esquire, Charles O. Beckley, II, Esquire, and Beckley & Madden, of Counsel, files this Petition for Equitable Distribution, Alimony Pendente Lite, Counsel Fees, Costs and Expenses and Alimony, in which she avers that: 1. Defendant/Petitioner, Kathleen Katekovich Lehman, is an adult individual residing at 1780 Weatherburn Drive, New Cumberland, Cumberland County, Pennsylvania 17070. 2. Plaintiff/Respondent, Timothy Scott Lehman, is an adult individual residing at 5332 Oxford Drive, Apt 64, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff/Respondent filed a Divorce Complaint in this matter on or about April 17, 2006, at the above-captioned docket number. 4. Plaintiff/Respondent and Defendant/Petitioner have acquired property, both real and personal, during the marriage which constitutes marital property subject to equitable distribution under the Divorce Code. 5. Plaintiff/Respondent and Defendant/Petitioner each owned, prior to the marriage, both real and personal property which has increased in value during the marriage, and/or which has been exchanged for other property which has increased in value during the marriage, all of which property is marital property, subject to equitable distribution under the Divorce Code. 6. Plaintiff/Respondent and Defendant/Petitioner have been unable to agree as to an equitable division of said property. 7. Defendant/Petitioner lacks sufficient property to provide for her reasonable means and is unable to support herself in the standard of living established during the marriage through appropriate employment. 8. Defendant/Petitioner has employed counsel, but is unable to pay the necessary and reasonable attorney's fees for said counsel. 9. Defendant/Petitioner is unable to sustain herself during the course of this litigation and will require alimony pendent elite in order to do so. 10. Defendant/Petitioner requires reasonable alimony to adequately maintain herself in accordance with the standard of living established during the marriage. 11. Plaintiff/Respondent has adequate earnings to provide for the 2 Defendant's/Petitioner's support and to pay her counsel fees, costs and expenses. WHEREFORE, Defendant/Petitioner, Kathleen Katekovich Lehman, respectfully requests the Court to: (1) divide all marital property equitably between the parties; (2) enter an award of Alimony Pendente Lite, interim counsel fees, costs and expenses, until final hearing and thereupon award such additional counsel fees, costs and expenses as deemed appropriate; and (3) enter an award of alimony in her favor. DATED: J-3/ u l Respectfully submitted, of Counsel BECKLEY & MADDEN 212 North Third Street li c P.O. Box 11998 Harrisburg, PA 17108 d (717) 233-7691 harles eckley, II 3 'May 22 2007 3:09PM NURSE RIDE HRCC (7171 221-1330 p.2 i VERMCAUO? L Kathleen Katekovich Lehman, hereby verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are Made subject to the penalties 18 Pa. i C. S. Section 4404, relating to unworn falsification to authorities. DATED: C 3 kOJ thleen Katekovich Lehman CERTIFICATE OF SERVICE I, Elizabeth S. Beckley, Esquire, hereby certify that a true and correct copy of the foregoing document was this day served upon the person and in the manner indicated below. SERVICE BY FIRST CLASS MAIL: Marylou Matas, Esquire Saidis, Flower & Lindsay 26 West High Street Carlisle, PA 17013 DATED: Siz AethS. , i I L ?.3 w r•a -.3 r L ? .-.? -1 Q F= T 4 4 l -IY SCOTT LEHMAN, Plaintiff v THLEEN KATEKOVICH Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-2162- : IN DIVORCE PRAECIPE TO WITHDRAW OF APPEARANCE THE PROTHONOTARY: Kindly withdraw my appearance on behalf of the Plaintiff, Timothy Scott Lehman, the above-captioned matter. Respectfully Submitted, SSAAI/DIS, FLOWER & LINDSAY Marylou tas, Esquire Attorney d. 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 (717) 243-6486 - facsimile Zq jo Counsel for Plaintiff ENTRY OF APPEARANCE THE PROTHONOTARY: Kindly enter my appearance on behalf of the Plaintiff, Timothy Scott Lehman, in e above-captioned matter. Respectful Su fitted, L?Z_- FLOWM ,& UNDSAY Timothy ` Lehman 5345 Oxford Circle, Apt. 64 26 West High safer Mechanicsburg, PA 17055 Carlisle, PA ated: C1S ? ? O? --D rri i w c + IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAFE AUTO INSURANCE COMPANY, Plaintiff, v. KAREN BRUNER, CHRISTINA TEMES and CHRISTINA TEMES, ADMINISTRATRIX OF THE ESTATE OF HUNTER TEMES, DECEASED, CIVIL DIVISION NO.: 06-3101 PRAECIPE FOR LISTING CASE FOR ARGUMENT (Jury Trial Demanded) Defendants. Filed on Behalf of Plaintiff Counsel of Record for this Party: Jeffrey C. Catanzarite, Esquire PA I.D. #: 72765 Summers, McDonnell, Hudock, Guthrie & Skeel, L.L.P. Firm No. 911 2400 Gulf Tower 707 Grant Street Pittsburgh, PA 15219 (412) 261-3232 #14533 b LAW OFFICES OF PETER J. RUSSO, P.C. BY: Elizabeth J. Saylor, Esquire Attorneys for Plaintiff PA Supreme Court ID: 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: lsavlorna Dirlaw com TIMOTHY SCOTT LEHMAN, IN THE COURT OF COMMON PLEAS, Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA • CIVIL ACTION - LAW V. KATHLEEN KATEKOVICH, NO. 06-2162 CIVIL TERM Defendant IN DIVORCE ENTRY OF APPEARANCE AS COUNSEL Kindly enter my appearance as counsel on behalf of Timothy Scott Lehman, Plaintiff in the above captioned matter. Date: A - - Oe Law Offices of Peter J. Russo, P.C. 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Peter J. Russo, Esquire I.D. No. 72897 Elizabeth J. Saylor, Esquire I.D. No. 200139 t rr^ -? CA C) LAW OFFICES OF PETER J. RUSSO, P.C. BY: Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: Isaylor@pjrlaw.com TIMOTHY SCOTT LEHMAN, Plaintiff V. KATHLEEN KATE KOVICH LEHMAN, Defendant F'L OFFICE 2011 JUL 18 AN 10: 4 4 CUMBERLAND COUNT" PENNSYLV;,1,11r : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2162 CIVIL ACTION LAW IN DIVORCE PETITION FOR COURT APPROVAL TO WITHDRAW AS COUNSEL FOR PLAINTIFF AND NOW, comes The Law Offices of Peter J. Russo, P.C. (hereinafter "Counsel"), attorneys for the Plaintiff, Timothy Scott Lehman, and files this Petition for Court Approval to Withdraw, and in support thereof, states the following: 1. On or about September 2007 counsel was retained by Mr. Lehman who has a mailing address of 22 Barshinger Ave, York, PA 17403. 2. Counsel has represented Mr. Lehman in the above captioned matter since that time. 3. In June of 2011, Mr. Lehman informed the undersigned that due to financial reasons he wished to represent himself in the above referenced matter. 4. Petitioner has served a notice of the within petition on the party in the manner provided by Rule 440. A copy of the notice and the original certificate of service is attached hereto and incorporated herein as Exhibit A. 5. Opposing counsel, Elizabeth Beckley, Esquire, currently counsel of record, has indicated that she is in the process of withdrawing her appearance, while Kenneth F. Lewis, Esquire, is in the process of entering his appearance on behalf of the Defendant. Kenneth F. Lewis, Esquire, has indicated that he does not oppose the undersigned counsel's Petition to Withdraw. 6. No Judge has ruled in regards to the above captioned matter, however Judge M.L. Ebert has entered orders in regards to a related custody matter (No. 06-6848). WHEREFORE, the Law Offices of Peter J. Russo, P.C. respectfully requests this Honorable Court to grant its Petition to Withdraw as Counsel for Plaintiff in the above-captioned matter. Respectfully submit ed, Date: AW ES F PETER J. RUSSO, P.C. Petitioners Peter J. Russo, Esquire ID No. 72897 Elizabeth J. Saylor, Esquire ID No. 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 PH: 717-591-1755 FX: 717-591-1756 LAW OFFICES OF PETER J. RUSSO, P.C. BY: Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: lsgylor@Rirlaw.com Attorneys for Plaintiff TIMOTHY SCOTT LEHMAN, Plaintiff, V. KATHLEEN KATE KOVICH LEHMAN Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 06-2162 : DIVORCE NOTICE OF PETITION FOR COURT APPROVAL TO WITHDRAW AS COUNSEL FOR PLAINTIFF To: Timothy S. Lehman PLEASE TAKE NOTICE that the undersigned counsel is filing the attached petition to withdraw its appearance as your counsel in the above stated matter. Law Offilgg of Peter J. Russo, P.C. 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Peter J. Russo, Esquire I.D. No. 72897 Elizabeth J. Saylor, Esquire ? // I.D. No. 200139 Date: TIMOTHY SCOTT LEHMAN, Plaintiff, V. KATHLEEN KATE KOVICH LEHMAN Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-2162 DIVORCE CERTIFICATE OF SERVICE I, Lisa M. Hicks, hereby certify that I am on this day serving a copy of the Notice of Petition for Court Approval to Withdraw as Counsel for Plaintiff upon the person(s) and in the manner indicated below: US Mail addressed as follows: Timothy Scott Lehman 22 Barshinger Ave York, PA 17403 Date: K2 '423 Lisa M. Hicks, Legal Secretary TIMOTHY SCOTT LEHMAN, . Plaintiff V. KATHLEEN KATE KOVICH LEHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2162 CIVIL ACTION LAW IN DIVORCE CERTIFICATE OF SERVICE I, Derek M. Strouphauer, paralegal, hereby certify that I am on this day serving a copy of the Petition for Court Approval to Withdraw as Counsel for Plaintiff upon the person(s) and in the manner indicated below: US Mail addressed as follows: Elizabeth Beckley, Esquire 212 N. Third Street Box 11998 Harrisburg, PA 17108-1505 Kenneth F. Lewis, Esquire 1101 North Front Street 1St floor Harrisburg, PA 17102 Timothy Scott Lehman 22 Barshinger Ave York, PA 17403 Date: LJI? A - ere M. Strouphauer, Paralegal ,S IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2162 KATHLEEN KATE KOVICH CIVIL ACTION LAW LEHMAN, Defendant IN DIVORCE Def `nco z ?o C_ r- z-n rn F Ez r- N IN RE: PETITION FOR COURT APPROVAL -<> Q TO WITHDRAW AS COUNSEL FOR PLAINTIFF < C'- , , ? c.; a ORDER OF COURT :: --: to AND NOW, this 2.1 day of J J ?? 2011, upon consideration of the TIMOTHY SCOTT LEHMAN, Plaintiff V. Petition for Court Approval to Withdraw as Counsel for Plaintiff, and all other matters of record, the request of Elizabeth J. Saylor, Esquire, of the Law Offices of Peter J. Russo, P.C. for Court Approval to Withdraw as Counsel for Plaintiff, in the above-captioned matter, is hereby GRANTED. BY THE COURT, J. Distribution List: Elizabeth J. Saylor, Esquire 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Elizabeth Beckley, Esquire ES ?l ll/l 4 212 N. Third Street ? j Box 11998 Harrisburg, PA 17108-1505 Kenneth F. Lewis, Esquire 1101 North Front Street 1St floor Harrisburg, PA 17102 2.-> Timothy Scott Lehman 22 Barshinger Ave York, PA 17403 ftnno-Vvy tf tc) mar) vs 41111,e(er) k-twa/k. Case No. V lY —� ( L —c3 - C) i» =r,. Nca — STATEMENT OF INTENTION TO PROCEED �' ` C) -o c T•2 T 2 To the ourt: � ! 4q11,6er Zatzt41; intends to proceed with the above captioned atterV y''' Print Name )/Ct ►l `e(e 1 i (-Pvna j ign Na Date: I000I 4 S(sj'Cli!/�� IMPORTANT NOTE In the event that this is a second or subsequent filing of a Statement of Intention to Proceed, this matter will be referred to the President Judge for the purpose of conducting a status conference involving all counsel. The goal of the status conference will be to set the matter for trial or other final disposition within a time certain. Prior to the status conference, Counsel will be expected to submit to the court, in writing, a proposed schedule for the completion of discovery, the filing of dispositive motions and a report as to whether alternative dispute resolution has been used or discussed.