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Home My WebLink About95-02115 11 ;J -I t .; -l ( ~ I J i j I I ; I I , , I , I I ! LO i - - . o Z .-'~'~~~~-~.~_~~~_~ro**_)-~"~~'~.,~~.~~'~ ti! -. - ---.--- !. . . ti! .,' $ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ~. STATE OF 1~. PENNA. $ " " 8 ~ " " 8 8 " " ^NN~I. LElINAN, I\: II. 95-2~~.5 .. .., II) " " Plaintiff ti! .' VI'I'.-;!I:; ~ '.' BRIAN K, LFi~1AN t " " Defendant ." ~ e ~ DECREE IN DIVORCE AND NOW, '.' ,V)y~t ~),'~", ',2.-~.., 19. ,~,f:-;t Is ordered and decreed that .. .~~~ ,~I , ,LF;I!l'!^N , , , . . . , , . , . . , , , , , , .. , . , .. , , " plaintiff, and, . '" ,. .. ,. .llRI(\N, K.. LEl~It.IN, . , . . . . , , , , , ., , , " , ,. . ." ,., defendant, ore divorced from the bonds of matrimony, ." ~ ~ ~ The court retains jurisdiction of the fol/owing claims which have been raised of record in this action for which a final order has not yet been entered; ~n """"""""'",."""., r!1!'!, Pilr~~c~, r~F~PY. ~(1C;:9rP9r\l~9. ~I,wk~ttpl,l~~qon and i~ Agreement for Custody and I'artial.eustody dated I ~ ......,.. ,August, 17" 1995,........,..,.)..,...,........, '.' Il y T".{ C" II r, I / I ~;-:::-~ ~\;\ A:IC'I;v^~h~ '~'~; /~bA~//j1"rf.:,~f-?,,:;'- e:;f"" ,Y ,):2u ,r,;? / ~ Prothonotnry ~ .:.:. .:.;. -:.:. ,:.:- <..:- .:~;. ':.:. ,:.;. -:.;. .:.:. .:.;. .:.:- 8 ~ ~ '" ~ 8 8 " " '" " " " 8 ~ ',' 8 8 ~ ~ f~ 8 8 8 8 S $ 8 8 * ~ '.' ti! '. ~ ',' ~ ':> ~ ~ )~ ;'.' i * .J. ii: ~ I * I ----.. -. STIPULATION AND AGREEMENT FOR CUSTODY AND PARTIAL CUSTODY COMES NOW, ANN LEHMAN, by and through her attorney, Arthur T, McDermott, Esquire, and BRIAN K. LEHMAN, representing himself pro se, and do stipulate and agree upon the following I 1. Ann Lehman and Brian K. Lehman are the natural parents of one minor child, Travis A, Lehman, born January 11, 1992, 2. Primary custody of the minor child, Travis A. Lehman, shall be placed in the mother, Ann Lehman. 3, The parties shall have shared legal custody of the minor child, Travis A, Lehman. 4, The father, Brian K, Lehman, shall have certain rights of partial custody of the minor child. Father shall have the child every other weekend beginning Friday, June 30, 1995 at 7100 p.m until the following Sunday, July 2, 1995 at BIOO p.m., and shall have the minor child on alternating weekends thereafter for the same days and hours. This agreement recognizes that Father is currently in the Armed Services stationed in Puerto Rico and weekend visitation at this time is not feasible, 5. Father has unlimited telephone contact with the child, at his own expense, before BI30 p.m. 6, Father shall have custody of the minor child on The father can reach the child anytime Father's Day. Mother shall have custody of the minor child on Mother's Day, .-- ---.., 7, Father and Mother will reach a mutual agreement in regards to holiday visitation. 8, Father shall have custody of the minor child on Christmas Day each and every year from 12100 noon until 8100 p.m, 9, Father shall have custody of the minor child at other times as may be mutually agreed upon between the parties. 10, Mother shall not unreasonably withhold rights of visitation or temporary custody. 11. Father shall be responsible for transportation arrangements to and from partial custody unless otherwise mutually agreed upon by mother and father, 12, Father shall have custody of the minor child for a period of not less than ten ( 10) weeks per year as mutually agreed to by mother and father, 13, The parties agree and anticipate that this Agreement for Custody and Visitation may be entered as an Order of Court in the Court of Common Pleas of Cumberland County, Pennsylvania. 14. The parties do hereby stipulate and agree that they waive their respective rights to be present in court at the time an order is made pursuant to this Agreement for Custody and Visitation. f I: I i J~ 'to_ I c: L. , ,...., ,...., J I " ,- - II: N I ",~ '~l U1 N ,. ,;"";C"J ." I ,m or = -..;. -~;. c.D I -< CJ"I ANN M, LEHMAN, Plaintiff I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I I CIVIL ACTION - LAW I NO, I vs. BRIAN K. LEHMAN, Defendant IN DIVORCE COMPLAINT IN DIVORCB COMES NOW, Plaintiff ANN M. LEHMAN, through her attorney, Arthur T. McDermott, Esquire and avers as follows I COUNT I - DIVORCE 1. Plaintiff is Ann M. Lehman, who currently resides at 14 W. Main Street, P,O. Box 243, Plainfield, Cumberland County, PA 170B1. 2. Defendant is Brian X. Lehman, who currently is stationed at 1002 C Buchanan Heights, P.O, Box 34235, Fort Buchanan, Puerto Rico 00934-0235. 3, Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint, 4. The plaintiff and defendant were married on May 23, 1992 in Cumberland County, Pennsylvania, 5, There have been no prior actions of divorce or for annulment between the parties, 6, The marriage is irretrievably broken, and the partie. are proceeding under Section 3301(c) of the Divorce Code. 7, Defendant is a member of the United States Armed Forces, .. ~ :,' r - ::;A -- ~?- "- " ~ ...c., ~~ \"\ . ~ ('., 0'1 a , . ".\ " 'i\:. "'- "'. cl v-1 C\ ... t'> <:' , - 'iI..:l ....... ~~ -l:: <f'o,. ~ ~.~ ~~ - ~ <.L,l ~ ~ Ln l,. ~ :' \Jj ~ ~ K-1 ' ('-..\ '- ~ ~. .st '\::.., ;:-.{.. ~'I :.> -.:.s~ uK, f' ANN M. LEHMAN, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I vs, I CIVIL ACTION - LAW I NO, 95-2115 BRIAN K, LEHMAN, I Defendant I IN DIVORCE AFPIDAVIT OP CONSBNT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on April 26, 1995. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3, I consent to the entry of a final decree of 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 are made subject to the penalties of 18 Pa. C.S. section 4904 relating to unsworn falsification to authorities. /.. , , 11\ \- ANN M, LEHMAN "\1' I Datel ' l 1 I'll. r.)-- '\,,:." IL..!-l..- ,) ~ Sworn to and Uk)''!''>! , 1995, subscribed before me this ~ day of ( Nota , NOTARIAL SEAl SHEllY O. SEXTON, NOTARYPUBUC CARLISLE BORO, CUMBEftl.AHll COUNlY MY COMMISSION EXPIRES ArRlL 21, I. Mlmbll, PIInnlylmll Asloellllon of.... ANN M. LEHMAN, , IN THE COURT OF COMMON PLEAS OF Plaintiff , CUMBERLAND COUNTY, PENNSYLVANIA , vs, , CIVIL ACTION - LAW , NO. 95-2115 BRIAN K. LEHMAN, , Defendant , IN DIVORCE WAIVER OF COUNSELLING ANN M. LEHMAN, being duly sworn according to law, deposes and says, 1. I have been advised of the availability of marriage counselling and understand that I may request that the Court require that my spouse and I participate in counselling. 2. I understand that the court maintains a list of marriage counselors in the Domestic Relations 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 counselling prior to a divorce decree being handed down by the Court. 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. ANN M, . I \, \ ,i), l "", \ ) LEHMAN me this ~'f!.. day of ( , I' (1t.~)11 (,f Sworn to 1995. and subscribed before ":.1 I ') C \ - ; _)'--.Q.ClL} .t:Lf",,\-, Nqt: ry Public NOTARIAL SEAL SHEll.V O. SEXTON, NOTARY PUBLIC CARLISLE BORO, CUMBERlAND COUNTY MY COMMISSION EXPIRES APRIL 28 1999 Member, f'lInnsylvania Assoe/lllon 01 NOllrl,. ANN M, LEHMAN, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I vs. I CIVIL ACTION - LAW I NO, 95-2115 BRIAN K, LEHMAN, I Defendant I IN DIVORCE AFPIDAVIT OP CONSBNT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on April 26, 1995. 2, The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of 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 are made subject to the penalties of 18 Pa, C.S, section 4904 relating to unsworn falsification to authOrities,;/ L f) - h ---1/\ BRIAN K.' LtHMAN Date I 14 Au~ust 1995 AT FORT BUCHANAN. PUERTO RICO: Sworn AUQ.ust I before me this 14th day of ;;- o /.. \\i .) 00) t r 0--- "-a -, ., co: '- .-. ., , '" '" " .. '" .- . U1 ,. .'-: " .... ... '-. ..' ')"1 -", .I' -f = "l}'- ...-:r - -, CD <.n 9 , Defendant IllUlIt ll<1ve guaranteed, round-trip ticketn and ,fl. ""-'". ~ \",h~ .oy.\. ~\. cOllunerical plane reservations and Defendant must have confirmed leave saved up to ensure that Defendant can spend time with said chi ld and to accompany ch ild back to Pennay 1 van ia and to be returned to 1673 Quail Drive, Carlisle, Cumberland County (child'n home county). If Defendant ia unable to accompany said child back to Pennsylvania, Defendant's wife, Elizabeth Lehman, will accompany said child. Plaintiff will go to airport to see child off and to pick up child. 10. Defendant will be entitled to no less than 10 non- consecutive weeks of partial physical custody including but not limited to B weeks to correspond with child's summer vacation, and two weeks at Christmas time on alternating years. 11. The parties further agree that the Defendant shall have a period of primary physical custody of the child from Friday, November 15, 1996 until Wednesday, January 15, 1997 at his residence in Puerto Rico, It is specifically agreed that should child express a strong desire to return to Plaintiff, Defendant will use emergency leave to return the child to Plaintiff. 12. The Defendant shall have custody of the minor child at other times as may mutually agreed upon between the parties. 13. The Plaintiff shall not unreasonably withhold rights of visitation or temporary custody. 14. The Defendant shall accompany the minor child in transportation to and from his residence in Puerto Rico. 15. If the Defendant is in Car lis le, Cumber land County, Pennsylvania at any other time on leave, the Defendant shall be " '. I, ~ ~...} r :11 ..,J 1 ... - "'- .... ~ 6,,'" ,~ ~. "., , , ", " I .,..'1 " ,,) ;h ,';1 :,-) )111 .. " , . . ~/