HomeMy WebLinkAbout94-04043
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IIN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
94- CIVIL TERM
ANDREA LYNN LENTZ,
Plalntl"
RUSSELL A. LENTZ,
Defendant
IN DIVORCE
COMPLAINT llY. DIVORCE PURSUANT IQ SECTION 330J(c)
QE THE DIVORCE CODE
NOW, comes the plaintiff, Andrea Lynn Lentz, by her attorneys, Irwin, Irwin &
McKnight, Esquires, and files this complaint in divorce against the defendant, Russell A. Lentz,
representing as follows:
1. The name of the plaintiff is Andrea Lynn Lentz and the name of the defendant is
Russell A. Lentz.
2. The plaintiff is Andrea Lynn Lentz, an adult individual residing at 115 South Cheslnut
Street, Mechanicsburg, Cumberland County, Pennsylvania 17055.
3. The defendant is Russell A. Lentz, an adult individual currently residing at 505 Spring
House Road, Camp Hill, Cumberland County, Pennsylvania 17011.
4, The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six
months prior to the filing of this action in divorce,
5, The plaintiff and the defendant were married on August 17, 1991, in Lisbum,
Cumberland County, Pennsylvania.
6, There was one child born of this marriage, namely Amy Leanne Lentz, age 2, born
June 9, 1992.
7, Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon
which this action is based that the marriage between the parties is irretrievably broken.
B. The plaintiff avers that she has been advised of the availability of counseling and that
said party has the right to request thst the court require the parties to participate in counseling.
WHEREFORE, the plaintilfdemandsjudgment dissolving tlte marriage between the two
parties,
I verifY that the facts contained herein 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.
July..1!1-, 1994
A~E~aintiff
By:
7013
~
ANDREA LYNN I.ENTZ,
Plailftlff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENN,fiYLVANIA
.
.
v.
.
.
CIVil. ACTION -I..AW
94- "1013 CIVIL TERM
PROTECTION FROM ABUSE
:
RUSSELL A. I.ENTZ
D~f~lftla/ft
.
.
..
TEMPORARY PROTECTfV.E ORQ,E8
AND NOW, this .J1"Jday of July, 1994, upon presentation and consideration of the
within Petition, and upon finding that Andrea Lynn Lentz, now residing in Cumberland County,
PeMsylvania, is in immediate and present danger of abuse from the defendant, Russell A, Lentz,
the following Temporary Order is entered,
The defendant, Russell A. Lentz, whose current address is 505 Spring House Road. Camp
Hill, Pennsylvania 17011, is hereby enjoined from physically abusing the plaintiff, Andrea Lynn
Lentz, and their minor child, or placing them in fear of abuse and is ordered to stay away from any
location where they may reside. The plaintiff is hereby awarded primary physical custody of the
parties' minor child, Amy Leanne Lentz. The defendant is hereby notified that if he fails to follow
this Order, he may be in indirect criminal contempt which is punishable by a fine not to exceed
$1,000,00 and/or by a sentence of up to six months in jail and any other appropriate punishment.
Resumption of co-residence on the part of the plaintiff and the defendant shall not nullify the
provisions of the court order directing the defendant to refrain from abusing the plaintiff.
This Order shall remain in effect until a final order is entered in this case. A hearing shall
be ~eld on this matter on the flU. day of ~_, 1994, at'~ ~'j 0. .m. in Courtroom No.
..L-, Cumberland County Courthouse, Carlisle, Pennsylvania.