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Home My WebLink About02-4012HAROLD S. IRWIN, 111, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF STACY L. LEHMAN, V. Plaintiff JEFFREY A. LEHMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 02 - yo 0- CIVIL TERM : 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 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 STACY L. LEHMAN, Plaintiff V. JEFFREY A. LEHMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 02. CIVIL TERM : IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(C) OF THE DIVORCE CODE NOW, comes the plaintiff, by her attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Stacy L. Lehman, an adult individual residing at 10 Cabin Lane, Shippensburg, Cumberland County, Pennsylvania 17257. 2. The defendant is Jeffrey A. Lehman, an adult individual residing at 110 McAllister Church Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The plaintiff has been a resident 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 July 20, 1991, in Steelton, Dauphin County, Pennsylvania. 5. 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. 2 6. The plaintiff avers that he 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 demands judgment dissolving the marriage between the parties and for such further relief as your Honorable Court may deem equitable and just. I verify that the statements made in this complaint 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. August 22, 2002 .lam/GIC Attorney for plaintiff 35 East High Street Carlisle, Pennsylvania 17013 (717) 2436090 STACY L. LEHMAN, Plaintiff V. JEFFREY A. LEHMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAIN NO. 02. CIVIL TERM IN DIVORCE The plaintiff, being duly sworn according to law, deposes and says: 1. 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. 1 understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. I 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 unswom falsification to authorities. August 22, 2002 1 / ? STA LEHMAN, Plaintiff 4 W M W ?1 ?? ?? (? ?\ o N ? Ts ? ??? G7 ? ? -? ?- ?'` C 7V ?%`?? ? ; b?? =? ' ? G a : Ci?r -? ? ?' -n t.? STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JEFFREY A. LEHMAN, : NO. 02 - CIVIL TERM Defendant : IN DIVORCE PETITION FOR CUSTODY NOW comes the plaintiff, Stacy L. Lehman, by her attorney, Harold S. Irwin, III, Esquire, and presents the following petition for custody, representing as follows: 1. The plaintiff is Stacy L. Lehman, an adult individual residing at 10 Cabin Lane, Shippensburg, Cumberland County, Pennsylvania 17257. 2. The defendant is Jeffrey Lehman, an adult individual residing at 110 McAllister Church Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are the parents of a minor son, namely Kody A. Lehman (born March 5, 1993, age 9 years). 4. The child resided with the parties from the time of her birth until August 22, 2002, when the parties separated. Since that time the child has lived with plaintiff. 5. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth, other than the existing Order filed to this term and number. 6• Plaintiff does not know of a person not a party to the proceedings who ha s physical custody of the child or claims to have custody or visitation rights with res the child. pect to 7. Plaintiff believes and therefor avers that the best interests and permanent welfare of the child require that the parties have joint legal custody of the child, that plaintiff have primary physical custody and that defendant have specified periods of temporary custody and visitation with the child in accordance with a schedule and und certain conditions which may be agreed upon at a conciliation to be held in this matte er r. WHEREFORE, plaintiff respectfully requests that the court enter an order providing for the legal and physical custody of the child as aforesaid. August 22, 2002 HAROLD S. IRWIN, III Attorney for Plaintiff 35 East High Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court I.D. No. 29920 V RM M ATION I do hereby verify that the acts set forth in this understand that false statements herein are Petition are true and made cone. I Section 4904, relating to unswom subject to the falsification to authorities, penalties of 18 Pa.C.S. August 22, 2002 f STAG . EHI C-s f??- cJ ?- o r? STACY L. LEHMAN, Plaintiff v. JEFFREY A. LEHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 02 - 4012 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(1) NOW, Harold S. Irwin, 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 above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on or about August 29, 2002, by certified mail "restricted delivery", addressed to the defendant at 110 McAllister Church Road, Carlisle, Pennsylvania 17013, by certified mail, return receipt No. 7000 2510 0009 2828 7273. 3. That a copy of the sender's receipt and signed receipt for certified mail is attached hereto. 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 falsificationAo authorities. August 30, 2002 Harold S. Irwin, III Attorney for plaintiff 1 ? I i, 2, and 3. ftem 4 lfPAfbk tad D*-WY 18 dasind. ¦ Prb t your nema and address on the mverse so dw we con mituum to card to you. • Attach t A card to the back of the mvifl em, or on the ft m if space Pwm ts. 1.Ardide Addleasd to: . t10 Ma A l1jsrER CArUR cRusLE PA t?o13 2. ArficM Ntmbw (rywmw hom &Mvice h"O PS Form 3811, 'August 20 m =OF CID Postage ru CID Certified Fee ru Return Receipt Fee c' (Endorsement Required) C3 C3 Restricted Delivery Fee 0 (Endorsement Required) O Total Postage 6 Fees a tr "' Sent To SrFf R C3 -- N O Bo x or P o.- ?lV ------'-----------° C 3 City, State, ZIP+4 i~ lidWWary addlaas dltalett from am 17 U-14111111111 M YES, enter ddWery addnse below: ? No 3. Swios Tim 1LC«nned Mall o Explass Mau ? R.pWKW KAMum Rece+pt for Merdnrtdise ? 6telred Mes o C.O.D. 4. ROW$Chd Dearery7 (Extra FOO "TA ReMtm Receipt 10259"1-M-0381 a r_ X 5 J v ? Z? ii ?O 7J STACY L. LEHMAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 02-4012 CIVIL ACTION LAW JEFFREY A. LEHMAN IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, September 04, 2002 upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, September 17, 2002 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: !s! lacqueline M Verney, Es_q, Custody Conciliator 'The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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, Pennsylvania 17013 Telephone (717) 249-3166 17 U!i :? ??? ? ? X35 00 z1o Ur i.? STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF PLAINTIFF, : CUMBERLAND COUNTY, PENNSYLVANIA V. :024012 CIVIL ACTION LAW JEFFREY A. LEHMAN, : IN CUSTODY DEFENDANT. , PETITION FOR SPECIAL RELIEF AND NOW, comes the Petitioner/Defendant, Jeffrey A. Lelman, by and through his attorneys, IRWIN, McKNIGHT & HUGHES, and files this Petition for Special Relief, making the following statement: 1. The Petitioner/Defendant is Jeffrey A. Lehman, ail adult individual residing at 110 McAlister Church Road, Carlisle, Cumberland County, Pennsylvania ][ 7013. 2. The Plaintiff/Respondent is Stacy L. Lehman, an adult individual residing at 10 Cabin Lane, Shippensburg, Cumberland County, Pennsylvania 17257. 3. The parties were married on July 20, 1991, and are the natural parents of Kody A. Lehman, born March 5, 1993. 4. The parties separated on or about August 26, 2002, and the minor child has continued to go to his previous school in Plainfield. 5. On or about September 4, 2002, the Plaintiff/Respondent filed a Petition for Custody, and a conciliation was set for September 17, 2002. 6. In an effort to settle this matter, the parties agreed to a Stipulation and Agreement relative to custody of their minor child, and the Plaintiff/Respondent's attorney, Harold S. Irwin, III, Esquire, prepared said Stipulation and Agreement. Attached as Exhibit "A" is a copy of said Agreement. 7. Having reached an agreement between the parties, the Defendant/Petitioner signed and notarized the Agreement and forwarded it to the Plaintiff/Respondent's attorney on September 17, 2002. 8. Since that time, the parties have been operating under the terms of this Agreement. 9. On or about January 6, 2003, the Defendant/Petitioner was notified that the Plaintiff/Respondent had intended to change the school in which the minor child was attending. 10. In good faith, the Defendant/Petitioner agreed to cancel the conciliation previously scheduled for September 17, 2002, with the understanding that the parties would share physical custody as noted in the Stipulation and Agreement prepared by the Plaintiff/Re:spondent's attorney. 11. Once the Defendant/Petitioner notified the opposing attorney of her intention to change schools, the Defendant/Petitioner was notified that the Plaintiff/Respondent had terminated her previous attorney, Harold S. Irwin, III, and that the Stipulation prepared by Attorney Irwin was never signed by the Plaintiff/Respondent. 12. The Defendant/Petitioner believes and therefore avers that it is in the best interest of the minor child that he remain in the school district in which he is currently attending and that the Plaintiff/Respondent be enjoined from changing the school in which the minor child is attending until a full hearing on the merit is held or subsequent Order of Court. WHEREFORE, the Defendant/Petitioner respectfully requests that the Plaintiff/Respondent be enjoined from changing the school in which the minor child, Kody A. Lehman, is currently attending. Respectfully submitted, IRWIN, McK] 41GHT & HUGHES Marcus A. Mc:Kni t, III, E! 60 West Pomfi•et treet Carlisle, PA 1 7013 717-249-2353 Supreme Court I.D.#: 25476 Attorney for the Defendant/Petitioner, Jeffrey A. Lehman Dated: January -7-1 2003 VERIFICATION The foregoing document is based upon information which has been gathered by my 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. REYA. LEHMAN 0700 3 Date: 7 EXHIBIT "A" HAROLD S. IRWIN, 111, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF STACY L. LEHMAN, Plaintiff V. JEFFREY A. LEHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 02 - 4012 CIVIL TERM : IN DIVORCE ORDER OF COURT NOW, this day of 2002, upon presentation and consideration of the attached Stipulation and Agreement and upon agreement of the parties, it is hereby ordered and decreed that the attached agreement is made an Order of Court. BY THE COURT, J. HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF STACY L. LEHMAN, Plaintiff V. JEFFREY A. LEHMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02 - 4012 CIVIL TERM IN DIVORCE STIPULATION AND AGREEMENT THIS STIPULATION AND AGREEMENT entered into this day of September, 2002, by and between JEFFREY A. LEHMAN (hereinafter referred to as "Father") and STACY L. LEHMAN (hereinafter referred to as "Mother"). NOW THIS AGREEMENT WITNESSETH THAT: WHEREAS, the Father and Mother are the natural parents of a minor child, namely Kody A. Lehman (born March 5, 1993, age 9 years); and WHEREAS, the parties wish to enter into an agreement relative to the custody, partial custody, and support of the child. NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as follows: 1. The parties shall have joint legal custody of the child; however, in the event that an emergency decision must be made by the party with physical custody of the child at the time and the other party cannot be contacted, then the parties agree that the party with physical custody of the child at the time shall be permitted to make such decision on his or her own. 2. The parties shall have shared physical custody of the child according to a schedule as the parties may mutually agree from time to time, with the understanding that each party's time with the child shall be on as much an equal basis as is reasonably possible. 3. Father and Mother shall share visitation on the child's birthday and on holidays. 4. Father shall always have the child on Father's Day and Mother shall always have the child on Mother's Day. 5. The parties shall each have up to two weeks of uninterrupted time with the child during the Summer, scheduled as the parties may mutually agree. 6. Both parties shall have reasonable telephone contact with the child while the child is in the other's custody. 7. The parties shall keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to insure that the health, welfare and well being of the child is protected. 8. The parties shall do nothing that may estrange the child from either party or hinder the natural development of the child's love or affection for the other party. 9. The parties will utilize the other parent for such childcare as may be necessary, so long as the use thereof is convenient and reasonable and can be accomplished with a minimum of transportation issues. 10. Any modification or waiver of any of the provisions of this agreement shall be effective only if made in writing and only if executed with the same formality of this agreement. 11. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 12. The parties desire that this agreement be made an order of Court through the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County has jurisdiction over the issue of custody of the parties' minor child and shall retain such jurisdiction should circumstances change and either party desire further or require further modification of said Order. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound by the terms hereof, set forth their hands and seals the day and year herein set forth. WITNESSETH: `'?-,Otira .y.? (SEAL) E 9 L; Y A. LEHMAN (SEAL) STACY L. LEHMAN COMMONWEALTH OF PENNSYLVANIA : :SS: COUNTY OF CUMBERLAND On this, thei day of September, 2002, before, the undersigned officer, appeared JEFFREY A. LEHMAN, known to me (or satisfactorily proven) to be the same person whose name is subscribed to the within instrument, and acknowledged that he executed this agreement for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. f Notarial Seal 1 Martha L. Noel, Notary Public (SEAL) Cartiete Boro, Cumberland County NOt Ubll My Commission Expires Sept. 18, 2= ry Member, Pennsylvania Association of Notaries COMMONWEALTH OF PENNSYLVANIA : :SS: COUNTY OF CUMBERLAND On this, the day of September, 2002, before, the undersigned officer, appeared STACY L. LEHMAN, known to me (or satisfactorily proven ) to be the same person whose name is subscribed to the within instrument, and acknowledged that she executed this agreement for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public (SEAL) CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, do hereby certify that I have served a true and correct copy of the foregoing document upon the person indicated below by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below: Ms. Stacy L. Lehman 10 Cabin Lane Shippensburg, PA 17257 IRWIN, McKNIGHT & HUGHES Supreme Court I.D. Nk. ?6476 60 West Pomfret St. Carlisle, PA, 17013 (717) 249-2353 Dated: January 7, 2003 Pik C Gv ? V (7 7-; ?. ?r r ? ? STACY L. LEHMAN, :IN THE COURT OF COMMON PLEAS OF PLAINTIFF, : CUMBERLAND COUNTY, PENNSYLVANIA V. : 02-4012 CIVIL ACTION LAW JEFFREY A. LEHMAN, : IN CUSTODY DEFENDANT. PETITION FOR CUSTODY AND NOW, this day of January, 2003, comes the Defendant, Jeffrey A. Lehman, by and through his attorneys, IRWIN, McKNIGHT & HUGHES, and files this Petition for Custody, making the following statement: 1. The Defendant/Petitioner is Jeffrey A. Lehman, an adult individual residing at 110 McAlister Church Road, Carlisle, Cumberland County, Pennsylvania 17013 2. The Plaintiff/Respondent is Stacy L. Lehman, an adult individual residing at 10 Cabin Lane, Shippensburg, Cumberland County, Pennsylvania 17257. 3. The parties were married on July 20, 1991, and separated on or about August 26, 2002, 4. The parties are the natural parents of one (1) child, namely, Kody A. Lehman, born March 5, 1993. 5. On or about September 4, 2002, the Plaintiff/Respondent filed a Petition for Custody, and a conciliation was set for September 17, 2002. 6. In an effort to settle this matter, the parties agreed to a Stipulation and Agreement relative to custody of their minor child, and the Plaintiff/Respondent's attorney, Harold S. Irwin, III, Esquire, prepared said Stipulation and Agreement. Attached as Exhibit "A" is a copy of said Agreement. 7. Having reached an agreement between the parties, the Defendant/Petitioner signed and notarized the Agreement and forwarded it to the Plaintiff/Respondent's attorney on September 17, 2002. 8. In good faith, the Defendant/Petitioner agreed to cancel the conciliation on September 17, 2002, with the understanding that the parties would share physical custody as noted in the Stipulation and Agreement prepared by the Plaintiff/Respondent's attorney. 8. In good faith, the Defendant/Petitioner agreed to cancel the conciliation on September 17, 2002, with the understanding that the parties would share physical custody as noted in the Stipulation and Agreement prepared by the Plaintiff/Respondent's attorney. 9. Since that time, the parties have been operating under the terms of this Agreement. 10. On or about January 6, 2003, the Defendan.t/Petitioner was notified that the Plaintiff/Respondent had intended to change the school in which the minor child was attending from his previous school district. 11. Once the Defendant/Petitioner notified the opposing; attorney of her intention to change school districts, the Defendant/Petitioner was notified that the Plaintiff/Respondent had terminated her previous attorney. 12. The Defendant/Petitioner believes and therefore avers that it is in the best interest of the minor child that he remain in the school district which he is currently attending and that the Plaintiff/Respondent's threats to remove the minor child from his school and enroll him in another school cause the minor child distress and instability. The Defendant/Petitioner also believes and therefore avers that it is in the best interest of the minor child that the Defendant/Peltitioner be granted primary physical custody of the minor child, Kody A. Lehman. WHEREFORE, the Defendant/Petitioner respectfully requests that he be granted primary physical custody with partial physical custody to the Plaintiff/Respond.ent as agreed upon by the parties. Respectfully submitted, IRWIN, MCKNIGHT & HUGHES By: Dated: ? / , 2003 Carlisle, PA 17013 717-249-2353 Supreme Court I.D. No: 25476 VERIFICATION The foregoing document is based upon information which has been gathered by my 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. -44ZY&A!.?L?EHMAN ac?o 3 Date: , EXHIBIT "A" HAROLD S. IRWIN, 111, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JEFFREY A. LEHMAN, : NO. 02 - 4012 CIVIL TERM Defendant : IN DIVORCE ORDER OF COURT NOW, this day of 2002, upon presentation and consideration of the attached Stipulation and Agreement and upon agreement of the parties, it is hereby ordered and decreed that the attached agreement is made an Order of Court. BY THE COURT, J. HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243.6090 ATTORNEY FOR PLAINTIFF STACY L. LEHMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. JEFFREY A. LEHMAN, Defendant CIVIL ACTION - LAW NO. 02 - 4012 CIVIL TERM IN DIVORCE STIPULATION AND AGREEMENT THIS STIPULATION AND AGREEMENT entered into this . day of September, 2002, by and between JEFFREY A. LEHMAN (hereinafter referred to as "Father") and STACY L. LEHMAN (hereinafter referred to as "Mother"). NOW THIS AGREEMENT WITNESSETH THAT: WHEREAS, the Father and Mother are the natural parents of a minor child, namely Kody A. Lehman (born March 5, 1993, age 9 years); and WHEREAS, the parties wish to enter into an agreement relative to the custody, partial custody, and support of the child. NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as follows: The parties shall have joint legal custody of the child; however, in the event that an emergency decision must be made by the party with physical custody of the child at the time and the other party cannot be contacted, then the parties agree that the party with physical custody of the child at the time shall be permitted to make such decision on his or her own. 2. The parties shall have shared physical custody of the child according to a schedule as the parties may mutually agree from time to time, with the understanding that each party's time with the child shall be on as much an equal basis as is reasonably possible. 3. Father and Mother shall share visitation on the child's birthday and on holidays. 4. Father shall always have the child on Father's Day and Mother shall always have the child on Mother's Day. 5. The parties shall each have up to two weeks of uninterrupted time with the child during the Summer, scheduled as the parties may mutually agree. 6. Both parties shall have reasonable telephone contact with the child while the child is in the other's custody. 7. The parties shall keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to insure that the health, welfare and well being of the child is protected. 8. The parties shall do nothing that may estrange the child from either party or hinder the natural development of the child's love or affection for the other party. 9. The parties will utilize the other parent for such childcare as may be necessary, so long as the use thereof is convenient and treasonable and can be accomplished with a minimum of transportation issues. 10. Any modification or waiver of any of the provisions of this agreement shall be effective only if made in writing and only if executed with the same formality of this agreement. 11. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 12. The parties desire that this agreement be made an order of Court through the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County has jurisdiction over the issue of custody of the parties' minor child and shall retain such jurisdiction should circumstances change and either party desire further or require further modification of said Order. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound by the terms hereof, set forth their hands and seals the day and year herein set forth. WITNESSETH: (SEAL) EY A. LEHMAN (SEAL) STACY L. LEHMAN COMMONWEALTH OF PENNSYLVANIA : :SS: COUNTY OF CUMBERLAND On this, the 1 day of September, 2002, before, the undersigned officer, appeared JEFFREY A. LEHMAN, known to me ( or satisfactorily proven ) to be the same person whose name is subscribed to the within instrument, and acknowledged that he executed this agreement for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. f Notarial Seal Martha L. Noel, Notary Public (SEAL) Carlisle 9oro, Cumberland County Not ryubli My Commission Expires Sept. 1a, Member, Pennsylvania Association of Notaries COMMONWEALTH OF PENNSYLVANIA : :SS: COUNTY OF CUMBERLAND On this, the day of September, 2002, before, the undersigned officer, appeared STACY L. LEHMAN, known to me (or satisfactorily proven ) to be the same person whose name is subscribed to the within instrument, and acknowledged that she executed this agreement for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public (SEAL) CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, do hereby certify that I have served a true and correct copy of the foregoing document upon the person indicated below by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below: Ms. Stacy L. Lehman 10 Cabin Lane Shippensburg, PA 17257 IRWIN, McKNJVHT & HUGHES Marcus AiMcKnigh"11, Esquire Supreme Court I.D. No. 25476 60 West Pomfret St. Carlisle, PA 17013 (717) 249-2353 Dated: January 7, 2003 t7 'r t r, { n f w a c.? C') STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF PLAINTIFF, : CUMBERLAND COUNTY, PENNSYLVANIA V. :02-4012 CIVIL ACTION LAW JAN 0 9 2003 L JEFFREY A. LEHMAN, DEFENDANT. IN CUSTODY ORDER OF COURT AND NOW, this $ day of January, 2003, upon consideration of the attached Petition for Special Relief, t r m A. a A hearing is hereby set in this matter for I 3 , 2003, at 47.106 A .m. Courtroom # S , Carlisle, Pennsylvania. in the Cumberland County Courthouse, `Q I 1Ud c?.el'?veRe? 40 01 -) 0 C f1aak\ e'A- ?0 W? ?n C w ?i? r N STACY L. LEHMAN, Plaintiff/Respondent V. JEFFREY A. LEHMAN, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-4012 CIVIL TERM IN CUSTODY IN RE: PETITION FOR SPECIAL RELIEF DENIED ORDER OF COURT AND NOW, this 13th day of January, 2003, after hearing, the Petition for Special Relief is DENIED. ?Marcus A. McKnight, III, Esquire Attorney for Defendant/Petitioner "/ Jane Adams, Esquire Attorney for Plaintiff/Respondent v srs RXs 0-13-o3 t,?rn ,.+ r f1 ?''r'r?(?1', . ,,, STACY L. LEHMAN, Plaintiff V. JEFFREY A. LEHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 4012 CIVIL ACTION LAW : IN CUSTODY PRA ECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of Plaintiff, STACYY L. LEHMAN, in the above-captioned case. Date: /-/0-0.3 BY: _ ' e Adams, Esquire I.D 1o. 79465 South Pitt St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF l ? ?^? y 3 ??? t.a} ??, ,; r a., _ tJ? _'_' U.. '..?1 ?,? t. ? rvg , • • ? ?J i ! ?"` STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 024012 CIVIL TERM JEFFREY A. LEHMAN, Defendant IN CUSTODY AFFIDAVIT OF SERVICE. I, JUSTIN GOTTWALD, a competent adult, being duly sworn according to law, depose and say that at 1:37 p.m. on January 10, 2003, I personally served by hand delivery the attached Petition for Special Relief and Order of Court scheduling a hearing for Monday, January 13, 2003 at 9:00 a.m. in the Cumberland County Courthouse before The Honorable Edward E. Guido in the above-captioned case: To: Stacy L. Lehman I verify that the statements in this return of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A Section 4904 relating to unsworn falsification to authorities. Date: January May 13, 2003 .-r G IN G 1ALD Sworn and subscribed before me this 13th day of January 1 q03 No Public Notarial Seal Martha L. Noel Notary Public Carlisle Boro, Cumberland County My Commission Expires Sept. 18, 2003 Member, Pennsylvania Association of Notaries CZ ? r.-.? ?n . Cii4r, ?:. -- r-?? - _. G:; ,. .y_ J`..(" Nom, ?_ - { ?... -t- ? ?^? ? 'T' ^Y? f_- ; -1 a Tai -? ?? a t J? _-? STACY L. LEHMAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 02-4012 CIVIL ACTION LAW JEFFREY A. LEHMAN IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, January 10, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. the conciliator, Tuesday, February 11, 2003 at 9:30 AM at 4th Floor, Cumberland County Courthouse, Carlisle on for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a at the conference mayy order. All children age five or older may also be present at the conference. Failure to appear provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Tacaueline M__ Verney Esa. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the reasonale Americans with Disabilites Act of 1990. For information about accessible facilities alease co tact our office. accommodations available to disabled individuals having business before the court, pc. 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. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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, Pennsylvania 17013 Telephone (717) 249-3166 VI)..'v#Ov, s JN3 CJ, F67. ,Fi A,Uftr". v t' iI_ '!y ,,t STACY L. LEHMAN, Plaintiff V. JEFFREY A. LEHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 4012 CIVIL ACTION LAW IN CUSTODY PRAECIPE TO WITHDRAW APPEARANCE TO THE PROTHONOTARY: Please withdraw my appearance for Plaintiff, Stacy Lehman, in the above- captioned matter. By: Date: *6 3 Harold S. Irwin, 111, 35 East High St. Carlisle, Pa. 17013 (717) 243-6090 I.D. No. ? ? - ? «.o == ?? F? 2Sa 4Y . ?_ ?., v '= .?_. ?;: - -rc-? ?-- ? ` , ; .,_ ? - ??,? r; _ J, ? ? MAR 1 3 2003 STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2002-4012 CIVIL TERM JEFFREY A. LEHMAN, : CIVIL ACTION - LAW Defendant IN CUSTODY TEMPORARY ORDER OF COURT AND NOW, this day of /"`? , 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Stacy L. Lehman, and the Father, Jeffrey A. Lehman shall have shared legal custody of Kody A. Lehman, born March 5, 1993. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. Mother shall have primary physical custody of the Child. 3. Father shall have periods of partial physical custody as follows: A. Beginning March 14, 2003 alternating weekends from Friday after school to Sunday at 6:00 p.m. B. Every Monday from after school to 8:00 p.m. C. Alternating Wednesdays and Thursdays from after school to 8:00 p.m. 4. The Easter holiday shall be shared such that Father shall have physical custody of the Child from Friday at 12:00 noon to Saturday at 12:00 noon. Mother shall have physical custody of the Child from Saturday from 12:00 noon to Sunday. 5. Mother shall have physical custody of the Child on Mother's Day and Father shall have physical custody of the Child on Father's Day at times agreed by the parties. 6. Father shall be responsible for all transportation unless otherwise agreed by the parties. 7. The parties agree to submit themselves, the Child, and anyone living in their household, in a timely fashion, to a custody evaluation conducted by Dr. Arnold Shienvold. Each party shall pay for their respective charges for the custody evaluation. Mother shall have ten (10) days from the date of the conciliation conference to notify the Conciliator that she does not agree with this provision and thereby request a hearing. 8. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Either party may request another conciliation conference upon receipt of the custody evaluation. J. cc: Jane Adams, Esquire, Counsel for Mother Marcus A. McKnight, III, Esquire, Counsel for Father 3 I ? A 14 Ij } a STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :2002-4012 CIVIL TERM JEFFREY A. LEHMAN, : CIVIL ACTION - LAW Defendant IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kody A. Lehman March 5, 1993 Mother 2. A Conciliation Conference was held in this matter on March 11, 2003, with the following individuals in attendance: The Mother, Stacy L. Lehman, with her counsel, Jane Adams, Esquire and Father, Jeffrey A. Lehman, with his counsel, Marcus A. McKnight, III, Esquire. 3. A prior Order of Court, dated January 13, 2003 was entered by the Honorable Edward E. Guido denying Father's Petition for Special Relief. 3. The parties agreed to the entry of an Order in the form as attached. 3 -(12- -t23 Date Jac elfin . Verney, Esquire Cu ody Conciliator STACY L. LEHMAN, Plaintiff V. JEFFREY A. LEHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 4012 CIVIL ACTION LAW : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 l STACY L. LEHMAN, Plaintiff V. JEFFREY A. LEHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 4012 CIVIL ACTION LAW IN DIVORCE ADDITIONAL CLAIMS OF PLAINTIFF AND NOW COMES, Plaintiff, Stacy L. Lehman, by and through her attorney, Jane Adams, Esquire, and files the following additional claims under the Divorce Code: COUNT I - DIVORCE 1. The Plaintiff avers that the grounds on which the action and this claim for divorce are based are: that the Plaintiff has offered such indignities to the person of the Defendant, the innocent and injured spouse, as to render her condition intolerable and life burdensome. 2. This action is not collusive. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree in Divorce, divorcing the Plaintiff and Defendant. COUNT II - EQUITABLE DISTRIBUTION OF PROPERTY 3. Plaintiff incorporates by reference the averments set forth in paragraphs 1-13 fully as though the same were set forth at length. 4. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. 5. Defendant is currently living in the marital home. 6. Plaintiff and Defendant have been unable to agree as to an equitable division of said marital property as of the date of the filing of this petition. 7. Plaintiff is seeking an equitable division of all marital property. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as marital property. COUNT III - ALIMONY AND ALIMONY PENDENTE LITE 8. Items 1 - 7 are herein incorporated by reference. 9. Plaintiff lacks sufficient property to provide for her reasonable needs in accordance with the standard of living of the parties established during the marriage. 10. Plaintiff is unable to support herself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 11. The Defendant has a much higher earning capacity and does or is capable of earning a substantial income from which he would be able to contribute to the support and maintenance of Plaintiff to pay her alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plaintiff from Defendant Alimony and/or Alimony Pendente Lite in such sums as are reasonable and adequate to support and maintain Plaintiff in the station of life to which she has become accustomed during the marriage. COUNT IV - COUNSEL FEES, COSTS AND EXPENSES matter. 12. Items 1 - 11 are herein incorporated by reference. 13. Plaintiff is without sufficient funds to retain counsel to represent her in this 14. Without counsel, Plaintiff cannot adequately prosecute her claims against Defendant and cannot adequately litigate her rights in this matter. 15. Defendant enjoys a substantial income and/or has the earning capacity to earn a substantial income and is well able to bear the expense of Plaintiff's attorney and the expense of this litigation. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of counsel fees, costs, and expenses. Respectfully Date: 3,3/-03 lop J e Adams, Esquire .D. No. 79465 36 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF V VERIFICATION I verify that the statements made in this petition 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 falsification to authorities. r date: _331- d Stacy Z Lehman, Plaintiff !i ft- ?F LAJ C d f T p J C? ?J r? STACY L. LEHMAN, Plaintiff V. JEFFREY A. LEHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 4012 CIVIL .ACTION LAW IN CUSTODY MOTION FOR A HEARING 1. Movant is Jane Adams, Attorney for the Plaintiff in the above-captioned matter. 2. Pursuant to the custody Order of March 13, 2003, (Hereto attached as Exhibit A), a custody evaluation was completed by Dr. Chrissi Hart and reviewed and approved by Dr. Arnold Shienvold. 3. The custody evaluation was completed on October 6, 2003. 4. Plaintiff and Defendant have been unable to agree on custody arrangement regarding their minor son. 5. Movant has talked with her client who at the present time wishes to have a court hearing WHEREFORE, Movant respectfully requests that a custody hearing be set at the next available date. Respectfully submitted, Date: / b J e A s, Esquire 6 S itt Street Carlisle, Pa. 17013 (717) 245-8508 I.D. No. 79465 Attorney for Plaintiff MAR 1 3 2003 STACY L. LEHMAN, Plaintiff V. JEFFREY A. LEHMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-4012 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY TEMPORARY ORDER OF COURT AND NOW, this 11 YK day of 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Stacy L. Lehman, and the Father, Jeffrey A. Lehman shall have shared legal custody of Kody A. Lehman, born March 5, 1993. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. Mother shall have primary physical custody of the Child. Father shall have periods of partial physical custody as follows: A. Beginning March 14, 2003 alternating weekends from Friday after school to Sunday at 6:00 p.m. B. Every Monday from after school to 8:00 p.m. C. Alternating Wednesdays and Thursdays from after school to 8:00 p.m. 4. The Easter holiday shall be shared such that Father shall have physical custody of the Child from Friday at 12:00 noon to Saturday at 12:00 noon. Mother shall have physical custody of the Child from Saturday from 12:00 noon to Sunday. 5. Mother shall have physical custody of the Child on Mother's Day and Father shall have physical custody of the Child on Father's Day at times agreed by the parties. 6. Father shall be responsible for all transportation unless otherwise agreed by the parties. 7. The parties agree to submit themselves, the Child, and anyone living in their household, in a timely fashion, to a custody evaluation conducted by Dr. Arnold Shienvold. Each party shall pay for their respective charges for the custody evaluation. Mother shall have ten (10) days from the date of the conciliation conference to notify the Conciliator that she does not agree with this provision and thereby request a hearing. 8. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Either party may request another conciliation conference upon receipt of the custody evaluation. J. cc: Jane Adams, Esquire, Counsel for Mother Marcus A. McKnight, III, Esquire, Counsel for Father nt cop. Pn A 'mod q ft- f here OA# unto se? STACY L. LEHMAN, Plaintiff V. JEFFREY A. LEHMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :2002-4012 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 19153-8, the undersigned Custody Conciliator submits the following report: 1 • The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kody A. Lehman March 5, 1993 ]Mother 2_ A Conciliation Conference was held in this matter on March 11, 2003, 1S ith the following individuals in attendance: The Mother, Stacy L. Lehman, with her counsel. Jane Adams, Esquire and Father, Jeffrey A. Lehman, with his counsel, Marcus A. McKnight, III, Esquire. s. A Prior Order of Court, dated January 13, 2003 was entered by the Honorable Edward E. Guido denying Father's Petition for Special Relief. 3• The parties agreed to the entry of an Order in the form as attached. -/ G%3 / t , V F tic ct da?te Jacquelin - Verney, Esquire CuAody Conciliator t, VERIFY I verify that the statements made in this petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities. Date:// , Stacy L. L? an, Plaintiff tl CERTIFICATE OF SERVICE I, Jane Adams, Esquire, hereby certify that a true and correct copy of the within Interrogatories have been served upon the following individual, by United States Mail, first class, postage prepaid, in Carlisle, Pennsylvania on the,;,/ day of ®e 2003. Marcus McKnight, Esquire Irwin & McKnight 60 W. Pomfret St. Carlisle, Pa. 17013 Date: /Z _ 2 _ 03 ?' By: dams ane , Esquire r n ts? ? %3 ?FT; 7 1 C' J C. `C .iLJ g+C; L5 v ? -c STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 20024012 CIVIL TERM JEFFREY A. LEHMAN, CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of December, 2003, upon review of the Answer to the Motion of the Plaintiff, this case is remanded to Jacqueline M. Verney, Esquire, Custody Conciliator, to schedule a Conciliation Conference pursuant to Paragraph eight (8) of this Court's Order of March 13, 2003. By the Court: Edward E. Guido, Judge cc: Jane Adams, Esq. Attorney for Plaintiff Marcus A. McKnight, Esq. Attorney for Defendant STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 20024012 CIVIL TERM JEFFREY A. LEHMAN, Defendant CIVIL ACTION - LAW IN CUSTODY ANSWER TO THE MOTION FOR A HEARING AND NOW, this 5th day of December, 2003, the Defendant, Jeffrey A. Lehman, makes the following Answer to the Motion for a Hearing filed by Jane Adams, Esq., in this case: 1. The averments of fact contained in paragraph one (1) of the Motion are admitted. 2. The averments of fact contained in paragraph two (2) of the Motion are admitted. 3. The averments of fact contained in paragraph three (3) of the Motion are admitted. 4. The averments of fact contained in paragraph four (4) of the Motion are beyond the knowledge of the Defendant. The Plaintiff or her counsel have not reported any problem with the current Order of Court, and the Defendant does not know the changes which the Plaintiff is 2 seeking. Paragraph eight (8) of the Order of Court dated March 13, 2003, requires that this case be scheduled for a Conciliation Conference with Jacqueline Verney, Custody Conciliator. 5. The averments of fact contained in paragraph five (5) of the Motion are denied. On the contrary, the Order of Court which is in effect requires the parties to first seek a Custody Conciliation Conference with Jacqueline Verney, Custody Conciliator. A copy of the Plaintiff's Motion with the Order of Court dated March 13, 2003, is attached this Motion and marked as Exhibit "A". WHEREFORE, the Defendant requests that Your Honorable Court remand this custody case to Jacqueline Verney, Esquire, in order to schedule a Custody Conciliation Conference. Respectfully submitted, IRWIN & McKNIGHT By: 61 Marc s A. M j17013- quire Atto ey 60 West Po fret Carlisle, P yl222 717-249-2353 Supreme Court I .D. No: 25476 Date: December 5, 2003 3 EXHIBIT "A" STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 02 - 4012 CIVIL ACTION LAW JEFFREY A. LEHMAN, : IN CUSTODY Defendant ORDER OF COURT AND NOW, this day of 2003, upon review of the Motion for a Hearing, the Court orders and directs that a hearing regarding custody shall be scheduled in Courtroom No. 5, of the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pa. On the Day of 200, at a.m./p.m. J. cc: Jane Adams, Esquire Marcus McKnight, Esquire STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVAW V. : NO. 02 - 4012 CIVIL ACTION LAW rr " z JEFFREY A. LEHMAN, : IN CUSTODY Defendant MOTION FOR A HEARING :2 1. Movant is Jane Adams, Attorney for the Plaintiff in the above-captioned matter. 2. Pursuant to the custody Order of March 13, 2003, (Hereto attached as Exhibit A), a custody evaluation was completed by Dr. Chrissi Hart and reviewed and approved by Dr. Arnold Shienvold. 3. The custody evaluation was completed on October 6, 2003. 4. Plaintiff and Defendant have been unable to agree on custody arrangement regarding their minor son. 5. Movant has talked with her client who at the present time wishes to have a court hearing WHEREFORE, Movant respectfully requests that a custody hearing be set at the next available date. Respectfully submitted, Date: J e A ams, Esquire 6 S itt Street Carlisle, Pa. 17013 (717) 245-8508 I.D. No. 79465 Attorney for Plaintiff MAR 13 2003 VS STACY L. LEHMAN, Plaintiff V. JEFFREY A. LEHMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-4012 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY TEMPORARY ORDER OF COURT AND NOW, this r day of 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Stacy L. Lehman, and the Father, Jeffrey A. Lehman shall have shared legal custody of Kody A. Lehman, born March 5, 1993. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. Mother shall have primary physical custody of the Child. 3. Father shall have periods of partial physical custody as follows: A. Beginning March 14, 2003 alternating weekends from Friday after school to Sunday at 6:00 p.m. B. Every Monday from after school to 8:00 p.m. C. Alternating Wednesdays and Thursdays from after school to 8:00 p.m. 4. The Easter holiday shall be shared such that Father shall have physical custody of the Child from Friday at 12:00 noon to Saturday at 12:00 noon. Mother shall have physical custody of the Child from Saturday from 12:00 noon to Sunday. 5. Mother shall have physical custody of the Child on Mother's Day and Father shall have physical custody of the Child on Father's Day at times agreed by the parties. 6. Father shall be responsible for all transportation unless otherwise agreed by the parties. 7. The parties agree to submit themselves, the Child, and anyone living in their household, in a timely fashion, to a custody evaluation conducted by Dr. Arnold Shienvold. Each party shall pay for their respective charges for the custody evaluation. Mother shall have ten (I0)'days from the date of the conciliation conference to notify the Conciliator that she does not agree with this provision and thereby request a hearing. 8. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Either party may request another conciliation conference upon receipt of the custody evaluation. J. cc: Jane Adams, Esquire, Counsel for Mother Marcus A. McKnight, III, Esquire, Counsel for Father In whO ; f her FROM ftoft my 4W h?spal of # e onto set r M17, at Ca{(Ilan, ]J La.4Z.Y1 Q ?? STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :2002-4012 CIVIL TERM JEFFREY A. LEHMAN, : CIVIL ACTION - LAW Defendant IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 19153-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kody A. Lehman March 5, 1993 Mother 2. A Conciliation Conference was held in this matter on March 11, 2003, ?cidn the following individuals in attendance: The Mother, Stacy L. Lelunan, with her counsel. Jane Adams, Esquire and Father, Jeffrey A. Lehman, with his counsel, Marcus A. McKnight, 111, Esquire. 3. A prior Order of Court, dated January 13, 2003 was entered by the Honorable Edward E. Guido denying Father's Petition for Special Relief. The parties agreed to the entry of an Order in the form as attached. Date Jacquelin %M. Verney, Esquire- Cu§?ody Conciliator V VERIFICATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. . 41. Date: j% s1 D U'L Stacy L. Lehman, Plaintiff r,' CERTIFICATE OF SERVICE I, Jane Adams, Esquire, hereby certify that a true and correct copy of the within Interrogatories have been served upon the following individual, by United States Mail, first class, postage prepaid, in Carlisle, Pennsylvania on the 4;)d day of J)e c e y/ 2003. Marcus McKnight, Esquire Irwin & McKnight 60 W. Pomfret St. Carlisle, Pa. 17013 Date: OS By:l ?/? ane dams, Esquire STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 20024012 CIVIL TERM JEFFREY A. LEHMAN, CIVIL ACTION - LAW Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached document was served upon the following by hand delivering a true and correct copy of the same, on the date referenced below to the address as follows: Jane Adams, Esquire 36 South Pitt Street Carlisle, PA 17013 IRWIN & McKNIGHT By: Marcus A. ight, 60 West Po fret Street Carlisle, P 17013 (717) 249-2 3 Supreme Court No Date: December 5, 2003 /W Esquire 4 cr ?- J STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF L4 Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA DEL 42003 V. : NO. 02 - 4012 CIVIL ACTION LAW JEFFREY A. LEHMAN, : IN CUSTODY Defendant Q7? ORDER OF COURT AND NOW, this v ?" " day ofk( ae)'?/ 2003, upon review of the Motion for a dW. iw*? y,+?Q tie a q?,,,,,.,%r.yt=.? Hearing, k ! n ?. 3 t or? ti 'a! A464 C Pirtrnnm -?I cc: Jane Adams, Esquire ?Marcus McKnight, Esquire J 12-08?? ,NVAIASNN3 I 5?:0l?b 8-Jju STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA - c> ?- w V. N0.2002 4012 CIVIL TERM ? r t JEFFREY A. LEHMAN, CIVIL ACTION - LAW v crti ?t;- Defendant r IN CUSTODY c - T _ mac:, rv ci ANSWER TO THE MOTION FOR A HEARING cn AND NOW, this 5th day of December, 2003, the Defendant, Jeffrey A. Lehman, makes the following Answer to the Motion for a Hearing filed by Jane Adams, Esq., in this case: 1. The averments of fact contained in paragraph one (1) of the Motion are admitted. 2. The averments of fact contained in paragraph two (2) of the Motion are admitted. 3. The averments of fact contained in paragraph three (3) of the Motion are admitted. 4. The averments of fact contained in paragraph four (4) of the Motion are beyond the knowledge of the Defendant. The Plaintiff or her counsel have not reported any problem with the current Order of Court, and the Defendant does not know the changes which the Plaintiff is 2 seeking. Paragraph eight (8) of the Order of Court dated March 13, 2003, requires that this case be scheduled for a Conciliation Conference with Jacqueline Verney, Custody Conciliator. 5. The averments of fact contained in paragraph five (5) of the Motion are denied. On the contrary, the Order of Court which is in effect requires the parties to first seek a Custody Conciliation Conference with Jacqueline Verney, Custody Conciliator. A copy of the Plaintiff's Motion with the Order of Court dated March 13, 2003, is attached this Motion and marked as Exhibit "A". WHEREFORE, the Defendant requests that Your Honorable Court remand this custody case to Jacqueline Verney, Esquire, in order to schedule a Custody Conciliation Conference. Respectfully submitted, IRWIN & McKNIGHT By: Mare" A. M Knight, III, si ,to ey for Defend t 60 West Po fret Street Carlisle, Pe ylva a 17013- 717-249-2353 Supreme Court I.D. No: 25476 Date: December 5, 2003 3 EXHIBIT "A" STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 02 - 4012 CIVIL ACTION LAW JEFFREY A. LEHMAN, : IN CUSTODY Defendant ORDER OF COURT AND NOW, this day of 2003, upon review of the Motion for a Hearing, the Court orders and directs that a hearing regarding custody shall be scheduled in Courtroom No. 5, of the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pa. On the Day of , 200, at a.m./p.m. J. cc: Jane Adams, Esquire Marcus McKnight, Esquire STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVAW .m V. : NO. 02 - 4012 CIVIL ACTION LAW -U mi JEFFREY A. LEHMAN, : IN CUSTODY < Defendant 4 MOTION FOR A HEARING 1. Movant is Jane Adams, Attorney for the Plaintiff in the above-captioned matter. 2. Pursuant to the custody Order of March 13, 2003, (Hereto attached as Exhibit A), a custody evaluation was completed by Dr. Chrissi Hart and reviewed and approved by Dr. Arnold Shienvold. 3. The custody evaluation was completed on October 6, 2003. 4. Plaintiff and Defendant have been unable to agree on custody arrangement regarding their minor son. hearing Movant has talked with her client who at the present time wishes to have a court WHEREFORE, Movant respectfully requests that a custody hearing be set at the next available date. Respectfully submitted, Date: 1 J e A ams, Esquire 6 S itt Street Carlisle, Pa. 17013 (717) 245-8508 I.D. No. 79465 Attorney for Plaintiff MAR 13 2003 STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2002-4012 CIVIL TERM JEFFREY A. LEHMAN, : CIVIL ACTION - LAW Defendant IN CUSTODY TEMPORARY ORDER OF COURT AND NOW, this i i day of 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Stacy L. Lehman, and the Father, Jeffrey A. Lehman shall have shared legal custody of Kody A. Lehman, born March 5, 1993. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. Mother shall have primary physical custody of the Child. 3. Father shall have periods of partial physical custody as follows: A. Beginning March 14, 2003 alternating weekends from Friday after school to Sunday at 6:00 p.m. B. Every Monday from after school to 8:00 p.m. C. Alternating Wednesdays and Thursdays from after school to 8:00 p.m. 4. The Easter holiday shall be shared such that Father shall have physical custody of the Child from Friday at 12:00 noon to Saturday at 12:00 noon. Mother shall have physical custody of the Child from Saturday from 12;00 noon to Sunday. 5. Mother shall have physical custody of the Child on Mother's Day and Father shall have physical custody of the Child on Father's Day at times agreed by the _ parties. 6. Father shall be responsible for all transportation unless otherwise agreed by the parties. 7. The parties agree to submit themselves, the Child, and anyone living in their household, in a timely fashion, to a custody evaluation conducted by Dr. Arnold Shienvold. Each party shall pay for their respective charges for the custody evaluation. Mother shall have ten (I0)'days from the date of the conciliation conference to notify the Conciliator that she does not agree with this provision and thereby request a hearing. 8. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Either party may request another conciliation conference upon receipt of the custody evaluation. cc: Jane Adams, Esquire, Counsel for Mother Marcus A. McKnight, III, Esquire, Counsel for Father why orew. I h FiEO? f - of l bore onto ,set my,4W ? o c) STACY L. LEHNIAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :2002-4012 CIVIL TERM JEFFREY A. LEHMAN, : CIVIL ACTION - LAW Defendant IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kody A. Lehman March 5, 1993 Mother 2. A Conciliation Conference was held in this matter on March 11, 2003, kith the following individuals in attendance: The Mother, Stacy L. Lelunan, with her counsel. Jane Adams, Esquire and Father, Jeffrey A. Lehman, with his counsel, Marcus A. McKnight, III, Esquire. 3. A prior Order of Court, dated January 13, 2003 was entered by the Honorable Edward E. Guido denying Father's Petition for Special Relief. The parties agreed to the entry of an Order in the form as attached. 5 -/ z -i'_3 Date it I Jacquelin & . Verney, Esquire Cu§?ody Conciliator tR VERIFICATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. Date: 2-9 - 0 cc Stacy L. Lehman, Plaintiff v° CERTIFICATE OF SERVICE I, Jane Adams, Esquire, hereby certify that a true and correct copy of the within Interrogatories have been served upon the following individual, by United States Mail, first class, postage prepaid, in Carlisle, Pennsylvania on the day of Oe C.O t e 2003. Marcus McKnight, Esquire Irwin & McKnight 60 W. Pomfret St. Carlisle, Pa. 17013 /. / Date: By: 57dims, Esquire STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2002-4012 CIVIL TERM JEFFREY A. LEHMAN, CIVIL ACTION - LAW Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached document was served upon the following by hand delivering a true and correct copy of the same, on the date referenced below to the address as follows: Jane Adams, Esquire 36 South Pitt Street Carlisle, PA 17013 IRWIN & McKNIGHT By: Marcus A. fight, II Esquire 60 West Po fret Street Carlisle, P 17013 (717) 249-2 3 Supreme Court-1-11 No. 25 6 Date: December 5, 2003 4 STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2002-4012 CIVIL TERM JEFFREY A. LEHMAN, CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this S' day of December, 2003, upon review of the Answer to the 4` Motion of the Plaintiff, this case is remanded to Jacqueline M. Verney, Esquire, Custody Conciliator, to schedule a Conciliation Conference pursuant to Paragraph eight (8) of this Court's Order of March 13, 2003. e Court: Edward E. Guido, Judge cc: ?fane Adams, Esq. Attorney for Plaintiff 7 ,Marcus A. McKnight, Esq. Attorney for Defendant `4il'ri v!?V%ryJI DEC 1 7 2003 STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 2002-4012 CIVIL TERM JEFFREY A. LEHMAN, : CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: The prior Order of Court dated March 13, 2003 is hereby vacated. 2. The Mother, Stacy L. Lehman, and the Father, Jeffrey A. Lehman shall have shared legal custody of Kody A. Lehman, born March 5, 1993. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 3. Mother shall have primary physical custody of the Child. 4. Father shall have periods of partial physical custody as follows: A. Alternating weekends from Friday after school to Sunday at 7:00 p.m. B. Every Monday and Wednesday from after school to 7:30 p.m. C. In the event Father is unable to pick up the Child from school, he shall notify Mother who will pick up the Child and return to her place of employment where Father may pick up the Child. 5. Christmas 2003 shall be divided so that Mother shall have physical custody of the Child from Christmas Eve until 2:00 p.m. Christmas Day and Father shall have physical custody of the Child on Christmas Day from 2:00 p.m. to 8:00 p.m. For all succeeding Christmas holidays, custody shall be divided into two Blocks. Block A shall be from 4:00 p.m. Christmas Eve to 4:00 p.m. Christmas Day. Block B shall be from Christmas Day at 4:00 p.m. to December 26 at 4:00 p.m. Father shall have custody of the Child for Block A in even numbered years and Block B in odd numbered years and Mother shall have physical custody of the Child for Block A in odd numbered years and Block B in even numbered years. 6. Thanksgiving shall be alternated from year to year by the parties from 9:00 a.m. to 9:00 p.m. Father shall have physical custody of the Child in even numbered years and Mother shall have physical custody of the Child in odd numbered years. 7. The Easter holiday shall run from 9:00 a.m. to 9:00 p.m. and shall be alternated such that Mother shall have physical custody of the Child in even numbered years and Father shall have the Child in odd numbered years. 8. Mother shall have physical custody of the Child on Mother's Day and Father shall have physical custody of the Child on Father's Day, both from 9:00 a.m. to 9:00 P.M. 9. Father shall be entitled to three consecutive weeks of physical custody of the Child in the summer, provided he supply at least 30 days prior notice to Mother. Mother shall be entitled to two consecutive weeks in the summer provided she supply at least 30 days prior notice to Father. In the event of a conflict of weeks the party first requesting the time shall prevail. 10. Father shall be responsible for all transportation during the week. Transportation shall be shared on weekends such that the receiving party shall transport unless otherwise agreed by the parties. 11. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. J. cc%I'ane Adams, Esquire, Counsel for Mother /Marcus A. McKnight, III, Esquire, Counsel for Father l?-IS-Q3 G 0 :6 f;'1 8 ! 730 ECOZ A! NIONOH108d 3H1 d0 ?ii:la0--031id STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :2002-4012 CIVIL TERM JEFFREY A. LEHMAN, : CIVIL ACTION - LAW Defendant IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kody A. Lehman March 5, 1993 Mother 2. A Conciliation Conference was held in this matter on December 16, 2003, with the following individuals in attendance: The Mother, Stacy L. Lehman, with her counsel, Jane Adams, Esquire and Father, Jeffrey A. Lehman, with his counsel, Marcus A. McKnight, III, Esquire. 3. A prior Order of Court, dated March 13, 2003 was entered by the Honorable Edward E. Guido providing for shared legal custody and primary physical custody in Mother with Father having periods of partial physical custody on alternating weekends and evenings during the week. 4. Following a custody evaluation, the parties agreed to the entry of an Order in the form as attached. Date cq ine M. Verney, Esquire Custody Conciliator 6 STACY L. LEHMAN, Plaintiff V JEFFREY A. LEHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW NO. 2002 -4012 EMERGENCY PETITION TO PREVENT THE DISSIPATION OF MARITAL ASSETS AND TO OBTAIN RECORDS AND NOW, comes the Petitioner, Jeffrey A. Lehman, by and through his attorney, Steven C. Courtney, Esquire and files the instant Petition and, in support thereof, avers as follows: 1. Petitioner is Jeffrey A. Lehman, Defendant in the above captioned action, currently residing at 48 State Road, Mechanicsburg, Cumberland County, Pennsylvania. 2. Respondent is Stacy L. Lehman, Plaintiff in the above captioned action, currently residing at 10 Cabin Lane, Shippensburg, Cumberland County, Pennsylvania. 3. Petitioner is the owner of a 1989 Chevrolet Camero, VIN # 1G1FP21F3KL160839 as evidenced by the attached Certificate of Title for a Vehicle. A true and correct copy of the Title is attached hereto as Exhibit "A". 4. During all times relevant hereto, the 1989 Chevrolet Camero, VIN # 1G1FP21F3KL160839 was in the sole possession of the Respondent. 5. During all times relevant hereto, Petitioner was intentionally prevented from having access to the vehicle by Respondent. 6. During all times relevant hereto, the vehicle was locked in the Respondent's garage. 7. During all times relevant hereto, Petitioner never abandoned the vehicle but was simply denied access thereto by Respondent. 8. On or about January 5, 2005, Petitioner learned that the title to the 1989 Chevrolet Camero, VIN # I G I FP2 I F3 KL 160 83 9 was transferred to Respondent's boyfriend, George Stojkovich. 9. Petitioner went down to the Pennsylvania Department of Motor Vehicles to learn how the title to the aforesaid vehicle was transferred without his signature as the legal and registered owner of the vehicle. 10. While the Petitioner was able to learn that the title to the 1989 Chevrolet Camero, VIN # 1G1FP2lF3KL160839 was transferred to George Stojkovich, the Pennsylvania Department of Motor Vehicles would not release any of the documents that were used to transfer the vehicle's title. 11. Petitioner learned that a court order was necessary in order to obtain the documentation relative to the transfer of the vehicle's title. 12. The 1989 Chevrolet Camero, VIN # 1 G 1 FP21 F3KL 160839 is a marital asset. 13. Petitioner avers that the Respondent transferred ownership of the 1989 Chevrolet Camero, VIN # 1G1FP21F3KL160839 in an attempt to dissipate the marital assets. 14. Petitioner avers that any transfer of the 1989 Chevrolet Camero, VIN # 1G1FP21F3KL160839 was fraudulent since he did not execute any of the documents to effectuate a transfer of the title to the aforesaid vehicle. 15. Petitioner avers that Respondent and/or George Stojkovich may sell the 1989 Chevrolet Camero, VIN # 1G1FP21F3KL160839 and keep sale proceeds. 16. Petitioner therefore requests this Honorable Court enter an Order preventing Respondent and/or George Stojkovich from selling, transferring or otherwise conveying the 1989 Chevrolet Camero, VIN # 1G1FP21F3KL160839. 17. Petitioner also requests that this Honorable Court enter an Order whereby he is able to obtain the documents that were used to transfer ownership of the 1989 Chevrolet Camero, VIN # 1G1FP21F3KL160839 from the Pennsylvania Department of Motor Vehicles. WHEREFORE, the Petitioner, Jeffrey A. Lehman, respectfully requests your Honorable Court to enter an Order preventing Respondent and/or George Stojkovich from selling, transferring or otherwise conveying the 1989 Chevrolet Camero, VIN # IGIFP21F3KL160839 and allow the Petitioner to obtain the documents that were used to transfer ownership of the 1989 Chevrolet Camero, VIN # 1 GIFP2lF3KL160839 from the Pennsylvania Department of Motor Vehicles. Respectfully Sub d; y Steven C. Courtney, Esquire 2215 Forest Hills Drive, Suite 36 P.O. Box 6280 Harrisburg, Pennsylvania 17112 Dated: Jan 07 05 03:03p KEEFER'S 717 697 4345 p.3 r? J ry? ri i CERTIFICATE OF TITLE FOR A VEHICLE*' • 176 1311?21J0g17f1U3c?92-001.1 l(;1FP21F)3TKL16101A39 I 14.59 8 1 C14EVROLE'T I 4277SS798U3 LE VIEHICIF f CP I 0 ! i S/03/01? 02A0001 0 e, I!pU; 1'01F OUP SEAT CAP PHIOH1aLESTATE 01'OAt Pn(X'n nA 11- .?. CK7AL MILES LXp01.1 STA'US = 3/15/90 I x/01/111 EI 0AIF FA TOM MATE. or ISJUE UNi :.nFrl WEIGli' ( ...v+„ , 3l^.STi i T:TIL ?Ti'11;i ••$ i k ! At:l iJAi_ t,!11 ?A::f ? l ! tAILEACE EX(:1 Flit' ihE LtU'. t i31AL I 1- • Uls NO! DILACIVAL K lEACE i 3 WIT 14F. ACr11;J 1.11 CAGE C.;_'.W-F. ; t TA)lPEMNG VFMF1El 4 F knIFT rndkl OL'L'AIE 7E1 ll';^! SURE i HF.,I;ilF l:t I?::V.NLrIT...E SOAK-M.' i A Al11 JLE VEIit::!L ? .E. j JEFFREY L LENMAN ` CLASSIC ITIBLE LIVEMIA (•? ,_F <:• %.411 ?.^. n i 110 MCALLISTER CHURCH t4 , ii ACA10II TI IAAI `?EHIILE ROAD i t'. GWNG VEHIk+i: =CARLISLE PA 17013 " REl0 :MICF1+I Fil i . S'TIiETT Allt' T = RFl-GVI'AEO 7. iCrt ',rE:rl; _E V VL141 LE ClYITMN, lllhS 141171!: _ Y: i 4GliV vtFni,l F f e fIHSi ULN i"AVCII U! SECOND UEM F"AVi!N 04 ?-------?- I LITHE FARMERS NATIONAL I' BANK L II a 5ixa!0 I.anlhlWrtt 's bgtem VF.(FI ':11M,.IM;Ign rtf 'ix! !Irvt :'?° 11`L ! {k "/? ' `` '!en!u)IJur iracd ro w.u.l y,c 7.tk lu iht a:rtr;uu cr AL.tx `!,-„':h.. o. .i ;I?q f? ' appf6Pf10A: tM4A 1,,:1 4^ ,[ nn;;1 LIEN +cr1 EraF u s / OAYATIVE Fn' FECONO LIEN FiFI F.:15ELt hi AWitomirc, REP ^ DATE .? 'El MAR ltlr; ,4oL1nE5 ~•U1THOfi12E0 RFPAESUTA TiVE FI (! 113 91349 T14E FARMERS NATIONAL ` 9 A NK i j BIG SPRING AVf' € 1 NEWILLE PA 17241 i I irCik .i: A IK•• 1:,110 ei ,. the .18, cU c-is ^1 :ha Prli -Ayk-a aCf;,«bnen! H..Z........v ...n..r u. ,. 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'.:?T •ir :;nu.J: 'rA•. nya CC'fv!Fti.ItASeR . :. .. ?.^'iiN:: ?':[+:m`•a: Us.::ecJ''ry' 774EET . ' - - ." ?:•:: -... + ?., +.r n.rtn.. •J:{. :.\ I:prNs, ? AJOrit' :5 vac.., . n:..rr 1.+.. .. •..r.. :•;. v'e?,• .::.: - _ ,.... .. - -. ...__..__... .. _. _. __..-?-._... _.___ ror -onr xrr- i <tA,, i.F PUI/CryaSE PNICE 1 ` x; NTUHE qF P- p?Tir •1 I0AYNI6TEMNG OATH iV:H.:H.\SfH SIGN.ITLAE 1 ,? ? ^urrtusEii arcroai Lb'URCk/:SEH Ai:!Si W r I ii,tvilPNMtT N *AE I+<I t'r. - SELt.ER LN$'T - - I HANDPRWTNA-UF HERE {`Ja ..•,M1a.:•1 N:•• ::r•,: CZ ^lt'CU: a'SM'M{:C U,31 'i:'A ?"C•AMaM :C`.Tnq ? 1A5? fIRS7 nrio:: and rclicrt No aGwwil milaago d Itio vetecla, Tt:NC NA.;CR ?:i rut., :u)w:rsA r+v.? :,.. .^25.v.:. •.1 :. r,•-.`,, ,ai}r:•?I,s ' ': i:.N(::::(?C?urn¢{\5 4- I Y:i •t h':' r•'yq '/?:. .. n.!I-.f. 11r. ^,t. ';lii!?y lil`ri'byi AI?,Y.(•?- sua a . Rrf3EL, ANL, swoWN TO Ei I ORE ME. ' DAY YEAR ra7_ _P• )tgmc*kASe PPICe __ _?___ -4114p';!SrH SiGiu.\il!Nt STACY L. LEHMAN, Plaintiff JEFFREY A. LEHMAN, Defendant AND NOW, this IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION-LAW NO. 2002 -4012 CERTIFICATE OF SERVICE 16 day of January, 2005, I, Steven C. Courtney, Esquire, do hereby certify that I, this day, served a copy of the foregoing Petition by first class mail to the following parties: Jane Adams, Esquire 36 S. Pitt Street Carlisle, PA 17013 Steven c. Courtney, Esquire C5 - C rl i' F5 STACY L. LEHMAN, Plaintiff V. JEFFREY A. LEHMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02 - 4012 CIVIL ACTION LAW : IN CUSTODY NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a counter- affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT OF SEPARATION 1. The parties to this action separated on and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose my 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. §4904 relating to unworn falsification to authorities. Date: _/ ---?? Stacy Ifs ehman, Plaintiff C"7 - '?' ?` ? t"i r !? v? " t3 f.. _ -i ?? [ t - ''?7 .?- ?- t'._3 "? ?' ; `' ? .r :?? y ti 2005 J q^.l 1 2 STACY L. LEHMAN, Plaintiff v JEFFREY A. LEHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW NO. 2002 -4012 ORDER AND NOW, this day of 2005, upon consideration of the foregoing Petition, it is hereby ORDERED AND DECREED that a hearing in the matter is scheduled for the 00 * day of 2005, at 1J 3 0 Am. in Courtroom No. ir at the Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania. By the C J. J h i a?,;,?6 r "117 -- 1 ? f 0 K I V, '!4 1 ? L - - rt .%' !,'d ?-l I E`j. x;1107 STACY L. LEHMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION-LAW NO. 2002 -4012 JEFFREY A. LEHMAN, Defendant DEFENDANT'S COUNTER-AFFIDAVIT UNDER &3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two (2) years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. X (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b), above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth, I will need notice of intention to request Divorce Decree, the Divorce Decree may be entered without further notice to me, and f shall be unable thereafter to file any economic claims. I verify that the statements made in this Counter-Affidavit re true and correct. I understand that false statements herein are made subject to the penalties of lE Pa. C.S. Section 4904 relating to the unsworn falsification to authorities. ?f Date: 1-17-CY ?Gr Jef man NOTICE: IF YOU DO NOT WISH TO OPPOSE T14E ENTRY OF A DIVORC- DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU NEED NOT FILE THIS COUNTER-AFFIDAVIT. CERTIFICATE OF SERVICE AND NOW, this -__L1_-_ day of , 2005 I, Steven C. Courtney, Esquire, attorney for Defendant, hereby certify that I served a copy of the Counter Affidavit this day by depositing the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Jane Adams, Esquire 64 S. Pitt Street Carlisle, PA 17013 By: ?G- Steven c. Courtney :a ?? ?, ;> ;: STACY L. LEHMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V JEFFREY A. LEHMAN, Defendant CIVIL ACTION-LAW NO. 2002 -4012 COUNTERCLAIM OF DEFENDANT AND NOW, comes the Defendant, Jeffrey A. Lehman, by and through his attorney, Steven C. Courtney, Esquire and files the following Counterclaim and in support thereof, avers as follows: COUNTI COUNTERCLAIM FOR EQUITABLE DISTRIBUTION Defendant and Plaintiff are the owners of tangible and intangible personal property which is the subject to equitable distribution. 2. Defendant and Plaintiff are believed to be the owners of retirement and investments which are the subject to equitable distribution. 3. Defendant has incurred debt as a result of the marriage which is subject to equitable distribution. WHEREFORE, the Defendant, Jeffrey A. Lehman, seeks an Order for equitable distribution of martial assets and debts. Respectfully Su By 221?esi His rive, Suite 36 P.O. Box 6280 Harrisburg, Pennsylvania 17112 STACY L. LEHMAN, Plaintiff V JEFFREY A. LEHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW NO. 2002 -4.012 CERTIFICATE OF SERVICE AND NOW, this day of January, 2005, I, Steven C_ Courtney, Esquire, do hereby certify that I, this day, served a copy of the foregoing document by first class mail to the following parties: Jane Adams, Esquire 64 S. Pitt Street Carlisle, PA 17013 VERIFICATION I, Jeffrey Lehman, do hereby verify that the facts set forth in the foregoing Pleading are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. 4, 01 Date: 1-17-05- 'AZ45!?? Je ehman ?_.> 1 , ?, l ( C' l ': STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 02 - 4012 CIVIL ACTION LAW JEFFREY A. LEHMAN, : DIVORCE Defendant AFFIDAVIT OF SERVICE AND NOW, this January 20, 2005, I, Jane Adams, Esquire, hereby certify that on or about January 13, 2005, a certified true copy of Plaintiffs 3301(d) Affidavit of Separation, was served, via certified mail, return receipt requested, addressed to: Steven Courtney, Esquire 2215 Forest Hills Drive Harrisburg, Pa. 17112 • Complete rftwns 1.2. and 3. Abd oomplsb A ATTORNEY FOR DEFEND. ¦ Nma If Reatm an addr'y Is desired. X your name and edkteeas on the reverse so that we can return the card to you. ¦ Attach this card to the bark of. the mallpleoe, or on the front if space permb. Apere 1. ArtldeAddreamdto: D. bd*mysddweed2eretf=- pmt? 21% C /' ? " BYES onow deemy edews bsbw: O No trkt%j- v COUPZ-rf@ CS? 2215 fiorcsKlive HanfiS6o"jr ?? f?IlZ A dd °DE --Md RW*^t ptfa dbe # iiy ? Yes ?' s. A? fnarefmt„oyh anivtce lety 7303 31110 0004 5775 4313 PS Form 3811. February 2W4 OamnM tbsentireelpr toeenasarwa Submitted: Jay6 Adams, Esquire . No. 79465 64 South Pitt Street Carlisle, Pa. 1701.3 (717) 245-8508 ATTORNEY FOR PLAINTIFF ' ? i ? . ?C: STACY L. LEHMAN, Plaintiff V JEFFREY A. LEHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW NO. 2002 -4012 ORDER AND NOW, this day of2005, upon consideration of the foregoing Stipulation relative to the Emergency Petition to Prevent the Dissipation of Marital Assets and to Obtain Records, it is hereby ORDERED AND DECREED that Defendant's Petition is granted whereby Plaintiff and/or George P. Stojkovich are not allowed to sell or otherwise dissipate of the marital asset being a 1989 Chevrolet Camero until the issues involving the title transfer have been resolved. It is further ORDERED AND DECREED that the Pennsylvania Department of Motor Vehicles is allowed to release to the Defendant all of the necessary documents relative to the transfer of the title to the 1989 Chevrolet Camero, VIN # 1GIFP21F3KL160839 from Jeffrey A. Lehman to George P. Stojkovich. J. STACY L. LEHMAN, Plaintiff v JEFFREY A. LEHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW NO. 2002 -4012 STIPULATION RELATIVE TO THE EMERGENCY ]PETITION TO PREVENT THE DISSIPATION OF MARITAL ASSETS AND TO OBTAIN RECORDS It is hereby stipulated by and among the Plaintiff, Stacy L. Lehman, by and through her attorney, Jane Adams, Esquire and the Defendant, Jeffrey A. Lehman, by and through his attorney, Steven C. Courtney, Esquire as follows: 1. On or about January 14, 2005, Defendant filed an Emergency Petition to Prevent the Dissipation of Marital Assets and to Obtain Records. 2. A hearing is currently scheduled for January 28, 2005 at 10:30 A.M. 3. . The parties, through their counsel, have reached an agreement whereby alleviating the need for the hearing. 4 The parties hereby certify that the Defendant is allowed to obtain any and all documentation from the Pennsylvania Department of Motor Vehicle relative to the transfer of the title to the 1989 Chevrolet Camero, VIN # 1G1FP21F3KL160839 from Jeffrey A. Lehman to George P. Stojkovich. 5. The parties have agreed to allow this Honorable Court to enter an Order whereby allowing the Defendant to obtain the necessary documentation from the Pennsylvania Department of Motor Vehicle relative to the transfer of the title to the 1989 Chevrolet Camero, VIN # 1G1FP21F3KL160839 from Jeffrey A. Lehman to George P. Stojkovich. 6. The parties hereto, through their counsel, consent to the terms of this Stipulation. The parties agree that a facsimile copy of this Stipulation shall have the same effect as the original. Dated: Respectfully Submitted, By Steven C. Co Es 2215 Forest Hil D e, Surte 36 P.O. Box 628 Harrisburg, P nnsylvania 17112 STACY L. LEHMAN, Plaintiff V JEFFREY A. LEHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW NO. 2002 -4012 CERTIFICATE OF SERVICE AND NOW, this _?4_ day of January, 2005, 1, Steven C. Courtney, Esquire, do hereby certify that I, this day, served a copy of the foregoing Stipulation by first class mail to the following parties: Jane Adams, Esquire 64 S. Pitt Street Carlisle, PA 17013 re STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 02 - 4012 CIVIL ACTION LAW JEFFREY A. LEHMAN, : DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on or about August 26, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: S? Stacy L. L? an, Plaintiff r WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 4330I(c) AND 43301(d) OF THE DIVORCE CODE 1. 1 consent to entry of a final decree of divorce without notice. 2. 1 understand that 1 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. 1 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 are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: V (] Stacy L. LeG . in, Plaintiff STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 02 - 4012 CIVIL ACTION LAW JEFFREY A. LEHMAN, : DIVORCE Defendant AFFIDAVIT OF CONSENT 2002. 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on or about August 26, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unworn falsification to authorities. Date: 'l-/S-OS G/ J A. ehman, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) AND 43301(d) OF THE DIVORCE CODE 1. 1 consent to entry of a final decree of divorce without notice. 2. 1 understand that 1 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. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date: y_?f ps J Lehman, Defendant ?, ?; ,, ..? _.. -= ,' --, ?: ?; <<; ,' STACY L. LEHMAN, Plaintiff V. (JEFFREY A. LEHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 4012 CIVIL ACTION LAW IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE/WITHDRAWAL TO THE PROTHONOTARY: Please enter the appearance of Steven C. Courtney, Esquire, as Attorney of record for effrey A. Lehman, Defendant, in the above-captioned matter. Date: - d Respect" Submi teven . urtney, Esquire 22 orest Hills Drive, Suite 36 Harrisburg, Pa. 17112 (717) 540-3900 Please withdraw the appearance of Marcus McKnight, Esquire as Attorney of record for Jeffrey A. Lehman, Defendant, in the above-captioned matter. Marcus McKnight, 60 W. Pomfret St. Carlisle, Pa. 17013 (717) 249-2353 ?? '1 x7l STACY L. LEHMAN, Plaintiff V. JEFFREY A. LEHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 4012 CIVIL ACTION LAW DIVORCE PRAECIPE TO WITHDRAW PLAINTIFF'S ADDITIONAL CLAIMS TO THE PROTHONOTARY: Please withdraw Plaintiff, Stacy L. Lehman's Claims for Economic Relief, including, the claims for Equitable Distribution, Alimony, Alimony Pendente Lite, and Counsel Fees and Costs. Respectfully submitted: Date: e dams, Esqui 64 S itt St. C isle, Pa. 17013 4 (717) 245-8508 ATTORNEY FOR PLAINTIFF ,-_, -, ? ,?, ; ?, ._? = ?- ?r? , ,. _, ? ; + ,. f? 7 STACY L. LEHMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 02 - 4012 CIVIL JEFFREY A. LEHMAN, Defendant IN DIVORCE ORDER OF COURT AND NOW, this S day of 2005, all economic claims having been withdrawn b praecipe and both parties having signed affidavits of consent and waivers of notice of intention to request entry of divorce decree, there being no matters pending before the Master, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE COURT, r n ? .' v Geo-g , E. o fer, P. J. cc: Jane Adams Attorney for Plaintiff Steven C. Courtney Attorney for Defendant li-, v S' L? 1 ?. ,i,r .. U ? _.. -.-i STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 02 - 4012 CIVIL, ACTION LAW JEFFREY A. LEHMAN, : DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on or about August 26, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to rerst eet* ° ofm the decree. 2= " I verify that the statements made in this affidavit are true and correct. I also understand thatfalse vi 'r statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unswom falsificafion.to - ' authorities. - Date: `?°IS-OS j z;7 J yfIUVA. ehman, Defendant r? WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301(c) AND 63301(d) OF THE DIVORCE CODE 1. I consent to 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 are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date: ?jl_?s ps / J Lehman, Defendant Xyr- ?? na STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF J Plaintiff : CUMBERLAND COUNTY, PENNSYLVAI4IA `4(j V. : NO. 02 - 4012 CIVIL ACTION LAW JEFFREY A. LEHMAN, : DIVORCE c Defendant AFFIDAVIT OF CONSENT 2002. 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on or about August 26, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unworn falsification to authorities. Date: L( a, U 0 5 `? G ... Stacy L. an, Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301(c) AND 43301(d) OF THE DIVORCE CODE 1. 1 consent to 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 are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. Date: ', O 7 Stacy L. Le n n, Plaintiff STACY L. LEHMAN, Plaintiff V. JEFFREY A. LEHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 4012 CIVIL ACTION LAW IN CUSTODY 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 §3301(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by Certified mail, restricted delivery, return receipt requested on: August 29, 2002. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: April 20, 2005. By Defendant: April 15, 2005. 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: April 21, 2005. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: April 21, 2005. Date: dams, Esquire I.D. 0. 79465 ,64,y Pitt Street arlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff r; ?,a _ ? _ - .: ? -? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Stacy L Le an, am NO. VERSUS Jeffrey A. Lehman, Defendant DECREE IN DIVORCE AND NOW, A Stacy L. Lehman DECREED THAT AND Jeffrey A. Lehman No. 02 - 4012 Civil Term IT IS ORDERED AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. PLAINTIFF, DEFENDANT, 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; None. THE ATTEST: w (7?? _ J. PROTHONOTARY f??QJ J70. or 1 LAGUNA REYES MALONEY, LLP I I 19 NORTH FRONT STREET, HARRISBURG, PA 1 7 1 02 TEL.: (7 1 7) 233-5292 / FAX: (71 7) 233-5394 ATTORNEY FOR DEFENDANT STACY L. LEHMAN, § Plaintiff/Respondent § V. § JEFFREY A. LEHMAN, § Defendant/Petitioner § IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-4012 CIVIL TERM CIVIL ACTION - CHILD CUSTODY PETITION TO MODIFY CUSTODY ORDER AND NOW, comes the Petitioner, Jeffrey A. Lehman, by his attorneys, Laguna Reyes Maloney, LLP, and represents as follows: 1. Petitioner, Jeffrey A. Lehman, is an adult individual residing at 1 Westmoreland Avenue, Enola, Cumberland County, Pennsylvania 17025. Petitioner (hereinafter referred to as "Father"), is the natural father of Kody A. Lehman,born March 5, 1993. (hereinafter referred to as "the Child"). 2. Respondent, Stacy L. Lehman, is an adult individual residing at 10 Cabin Lane, Shippensburg, Cumberland County, Pennsylvania 17257. Respndent, (hereinafter referred to as "Mother"), is the natural mother of the child. 3. On December 17, 2003, an Order of Court was issued in the above-captioned case which granted the parties shared legal custody of the child. Mother was granted primary physical custody and Father was ordered to have partial physical custody. 4. (said Order is attached hereto as Exhibit "A"). Due to various changed circumstances, including the age/maturity of the Child and the career change of the Father, it would be in the best interest of the Child to reside primarily with his father. WHEREFORE, Petitioner prays that this Honorable a custody order awarding Defendant grant the following relief: the child. 4er R. Laguna, Jr., quire Supreme Court I.D. No.: 75900 Attorney for Defendant LAGUNA REYES MALONEY, LLP 1119 North Front Street Harrisburg, PA 17102 (717) 233-5292 1iEC 7 zno3 STACY L. LEHNIA , :Iii THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2002-4012 CIVIL TERM JEFFREY A. LEHMAN, : CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND phis uay of ;Gw, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: The prior Order of Court dated March 1:, 2003 is hereby vacated. ?. The Mother, Stacy- L. Lehman, and the Father, Jeffrey A. Lehman shall have shared legal custody of Kody A. Lehman, born March 571993- Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and 'religion. ?- Mother shall have primary, physical custody of the Child. 4. Father shall have periods of partial physical custody as follows: A. Alternating weekends from Fridav after school to Sunday at 7:00 p.m. B. Every Monday and Wednesday from after school to 7:30 p.m. C. In the event Father is unable to pick up the Child from school. he shall notify Mother who will pick up the Child and return to her place of employment where Father may pick up the Child. 5. Christmas 2003 shall be divided so that Mother shall have physical custody of the Child from Christmas Eve until 2:00 p.m. Christmas Day and Father shall have physical custody of the Child on Christmas Day firm,-, 2:00 p.m. to 8:00 p.m. For ail succeeding Christmas holidays, custody shall be divided into two Blocks. Block A shall be from 4:00 p.m. Christmas Eve. to 4:00 p.m. Christmas Day. Block B shall be from Christmas Day at =1:00 p.m. to December 2b at 4:00 p.m. Father shall have custody of the Child for Block A in even numbered years and Block B in odd numbered years and Mother shall have physical eustod? of the Child for Block A in odd numbered years and Block B 4r even numbered jars. EXHIBIT A 6. Thanksgiving shall be alternated from year to year by the parties from 9:00 a.m. to 9:00 p.m. Father shall have physical custody of the Child in even numbered years a rd Mother shall have physical custody of the Child in odd numbered years. 7. The Easter holiday shall run from 9:00 a.m. to 9:00 p.m. and shall be alternated such that Mother shall have physical custody of the Child in even numbered years and Father shall have the Child in odd numbered years. 8. Mother shall have physical custody of the Child on Mother's Day and Father shall have physical custody of the Child on Father's Day, both from 9:00 a.m. to 9:00 P.M. 9. Father shall be entitled to three consecutive weeks of physical custody of the Child in the summer, provided he supply at least 30 days prior notice to Mother. Mothcr shall be entitled to two consecutive weeks in the sunh-ner provided she supply- at least 30 days prior notice to Father. In the event of a conflict of weeks the party first requesting the time shall prevail. 10. Father shall be responsible for all transportation during the week. Transportation shall be shared on weekends such that the receiving party shall transport unless othemise agreed by the parties. 11. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control, k cc: Jane Adams. Esquire. Counsel for Mother N-larcus A. McKnight, III, Esquire, Counsel for Father -,. ?19 Yl A /} ?! i 4 ,,) A I? ?} f STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :2002-4012 CIVIL TERM. JEFFREY A. LEHMAN, : CIVIL ACTION - LA`'4' Defendant IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 191?.3-8. the undersigned Custody Conciliator submits the following report: 1, The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY N CUSTODY OF Kodv A. Lehman March 5, 1993 Mother A Conciliation Conference was held in this matter on December 1,5, ? 3.- - with the following individuals in attendance: The Mother, Stacy L. Lehman; with her counsel, Jane Adams. Esquire and Father. Jeffrey A. Lehman, with his counsel. Marcus A_ Mcltnight, iii. Esquire. 3. A prior Order of Court. dated March 13, 2003 was entered by the honorable Ed yard E. Guido providing for shared legal custody and primary physical custody in Mother with Father having periods of partial physical custody on alternating <<,eekends and evenings during the week. 4. Following a custody evaluation, the parties agreed to the entry of an Order iri the form as attached. ?,1. Esquire Date Custody Conciliator STACY L. LEHMAN, § Plaintiff § V. § JEFFREY A. LEHMAN, § Defendant § IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 20024012 CIVIL TERM CIVIL ACTION - CHILD CUSTODY CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I served a certified copy of the Petition to Modify Custody Order filed in the above-captioned case upon Plaintiff, regular first-class U.S. mail and certified mail, addressed to: Ms. Stacy L. Lehm,- 10 Cabin Lane .ppensburg, PA 1 oa? ?Y file Roger R. Laguna, Jr.,\ Esquire Supreme Court I.D. No.: 75900 VERIFICATION I verify that the statements made above are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein may subject me to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. //////"-Jeffrey A. Lehman '1'? ?- d 1 [\ '? W ?- ? ?tZ {..,? G` ?? _? ? ="'? r-• ;. ?, _ ?' -?: STACY L. LEHMAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JEFFREY A. LEHMAN DEFENDANT 02-4012 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, June 20, 2006 upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, July 20, 2006 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: ls/ ac ueline M. Verne Es a. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For infonnation 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. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 Telephone (717) 249-3166 07 x ?.U - jee-% 190- ee- f "70 ' ee, -7 b STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2002-4012 CIVIL ACTION - LAW JEFFREY A. LEHMAN, : IN CUSTODY Defendant ORDER OF COURT AND NOW, this 74'\ day of 2006, upon consideration of the attached Custody Conciliatio eport, it is ordered and directed as follows: 1. A Hearing is scheduled in Court Roo o. 3 of the Cumberland County Court House, on the g_ day of O 2006, at 9'' 30 o'clock, A . M., at which time testimony will be taken. For purposes of this Hearing, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the prior Order of Court dated December 17, 2003 shall remain in full force and effect with the following modifications: 3. Parties shall cooperate with counseling for Kody. 4. Parties shall not discuss the upcoming hearing with the child. 5. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. cc?rc er R. Laguna, Jr., Esquire, counsel for e Adams, Esquire, counsel for Mother 0 Edward E. Guido, J. y?iNAl?.Sn?`?cl MNncl,+ enn? ?11{.t -1. 11 STACY L. LEHMAN, PlaintifVRespondent V. JEFFREY A. LEHMAN, Defendant/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002-4012 CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-5, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kody A. Lehman March 5, 1993 Mother 2. A Conciliation Conference was held August 1, 2006 with the following individuals in attendance: The Father, Jeffrey A. Lehman, with his counsel, Roger R. Laguna, Jr., Esquire, and the Mother, Stacy L. Lehman, with her counsel, Jane Adams, Esquire. 3. The Honorable Edward E. Guido previously entered an Order of Court dated December 17, 2003 providing for shared legal custody, Mother having primary physical custody and Father having alternating weekends, two evenings per week and three consecutive weeks in the summer. 4. Father's position on custody is as follows: Father seeks shared legal and primary physical custody, with Mother having alternating weekends. Father maintains that the child is maturing and has requested to live with Father primarily. 5. Mother's position on custody is as follows: Mother seeks to maintain the status quo. She asserts that the child will have to change schools if he moves with Father. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and continuing the current Order with a modification regarding counseling for Kody and a restriction on the parents not to discuss the upcoming hearing with the child. It is expected the Hearing will take '/3 day. $ - 2 6 ? /"(. U.? Date Qacq E ine M. Verney, Esquire Custody Conciliator STACY L. LEHMAN, Plaintiff V. JEFFREY A. LEHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002 - 4012 CIVIL ACTION - LAW : IN CUSTODY na r-? C-73 MOTION FOR CONTINUANCE n 7n AND NOW comes the Plaintiff/Respondent, Stacy L. Lehman, by and througl ler T,, attorney, Jane Adams, and respectfully requests that the hearing scheduled in the above= captioned matter be continued. In support thereof it is respectfully represented that: 1. Plaintiff/Respondent is Stacy L. Lehman, (hereinafter referred to as "Mother"), whose current address is 10 Cabin Lane, Shippensburg, Cumberland County, Pennsylvania, 17257. 2. Defendant/Petitioner is Jeffrey A. Lehman, (hereinafter referred to as "Father"), who currently lives at 1 Westmoreland Avenue, Enola, 17025. 3. The parties are the natural parents of Kody Lehman, date of birth March 5, 1993, age 13 years. 4. A custody conciliation was held regarding Father's Petition for Modification of custody on August. 1, 2006 before Attorney Jacqueline Verney. As a result of that hearing a half- day custody hearing was scheduled for October 9, 2006. 5. At the hearing the parties discussed having a custody evaluation done by Deb Salem of Innerworks. 6. The child just recently started counseling with Joe Winterholter of Diakon Lutheran Services in Mechanicsburg, Pennsylvania. 7. Mother believes it would be helpful for the child to complete more counseling sessions before the custody hearing. 8. Mother may also pursue an evaluation from Deb Salem; such evaluation has not yet been started. 9. No prior continuances have been requested in this matter. 10. Mother's counsel contacted Father's Counsel, Roger R. Laguna, Jr., on September 15, 2006, and he indicated that he would not oppose the continuance. WHEREFORE, Plaintiff/Respondent Stacy L. Lehman, respectfully requests this Honorable Court to grant her requested continuance. Respectfully submitted, Date: 1 J ne Adams, Esquire .D. No. 79465 64 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF/RESPONDENT STACY L. LEHMAN CERTIFICATE OF SERVICE AND NOW, this September 15, 2006 I, Jane Adams, Attorney for Plaintiff/Respondent, Stacy L. Lehman, hereby certify that a copy of Mother's MOTION FOR CONTINUANCE has been duly served upon the Father's Counsel by placing such in the custody of the United States Postal Service, via certified mail, postage pre-paid addressed to: Roger R. Laguna, Jr., Esquire 1119 N. Front St. Harrisburg, Pa. 17102 ATTORNEY FOR FATHER d'an¢ Adams, Esquire I. No. 79465 6 4 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR STACY L. LEHMAN SEP 9 10[1ti STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2002 - 4012 CIVIL ACTION - LAW JEFFREY A. LEHMAN, : IN CUSTODY Defendant ORDER OF COURT AND NOW, this a day of , 2006, the hearing previously scheduled in the above-captioned matter is rescheduled for the 1 j day of , 2006, at Fo OV A.M.A%kjn Courtroom No. of the Cumberland County Courthouse in Carlisle, Pennsylvania. J. cc: Jane Adams, Esquire Roger R. Laguna, Jr., Esquire c A?Q ry 3 !fir;' -'11 '?t3J :6 WV ZZ d3S 90OZ ViONIC f LOW ?Nl JO STACY L. LEHMAN, Plaintiff V. JEFFREY A. LEHMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 4012 CIVIL ACTION LAW : IN CUSTODY MOTION FOR CONTINUANCE AND NOW comes the Plaintiff/Petitioner, Stacy L. Lehman, by and through her attorney, Jane Adams, and respectfully represents the following: 1. Plaintiff/Respondent is Stacy L. Lehman, (hereinafter referred to as "Mother"). 2. Defendant/Respondent is Jeffrey A. Lehman, (hereinafter referred to as "Father"); he is represented by Roger Laguna, Esquire. 3. The parties are the natural parents of one child, namely, Kody A. Lehman, date of birth, March 5, 1993. 4. A hearing before this Honorable Court was scheduled for December 11, 2006. 5. The parties recently reached an agreement regarding a Temporary Custody Order. A copy of the parties' signature on a Joint Motion for entry of the Order is submitted as Exhibit A. 6. Counsel for Mother has not yet received copies of the Motion with the original signatures of the parties. 7. The parties are requesting that this matter be rescheduled for May 2007, before the child's summer vacation and before the end of the child's school year. WHEREFORE, Plaintiff/Respondent Stacy A. Lehman, respectfully requests this Honorable Court to grant her requested continuance and enter the attached temporary Order. Date: Respectfully submitted, a J Adams, Esquire .D. No. 79465 outh Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR MOTHER STACY L. LEHMAN 12/07/06 THU 02:04 FAX 2335394 Frrm:IRWIN LAW OFFI13E STACY L. LEHMAN Plains iff v. JEFFREY A. LERNLAN, Dduidant LAGUNA 717 24::1 4 Xl 12/1)-,7/'M-16 K:42 All F .I.TMAX?4 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 4012 CIVIL ACTION LAW IN CUSTODY JOS. '?MELO-N FOR ENTRY OF TEN IF Q. - 11 DAMREGARDDUG VD-Y AND NOW, this day of , 2006, upon The joint mcdon of Plmntiff and Defeo ar A to imply an agreement of the Pattks, the parties hereby request an f the ar mcb ed custody Order. 1 119 North Front St. NA Harrisburg, Pa 17102 ATTORNEY FOR FATHER Dated: Jame Adams, Esquire 64 S_ Fitt St. Carlisle, Pa. 17013 ,ATTORNEY FOR MOTIR"M Dated: A z7vlal . Lbbman, Farhw Dared: Smey L. Lehman, Mother Dwed: IM 003 - vhct) r-hle?- - 12/08/2086 89:33 7175328969 From:IRWIN LAW OFFICE STACY L. LEHKM, Plaintiff V4 J FMY A. LEHMAKo Ddendaut PHAROSTRUCKSTOP PAGE 01 717 243 9200 12/07/2006 12:43 #431 P.004/004 IN TM COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 4012 C1V1L ACTION LAW Ilv CUSTODY M= HQ ,TION FaRF=, E M,RQRAft o ER REGA M CPJ TORY AND NOW, this day of , 2006, upon the Joint iaodon of Plaintiff and Defa:tdant, and to implement an agroemcat of the Parties, the patties hemby request entry of the attached custody Oxder. WITH SSETH: Roger I.aguan, EsgWro 1119 North Fkcnt St. Hxdsbmg, P& 17102 ATTORNEY FOR FATHER Dated: L7S!61c? ,Adams, Baquim . Pitt St. Pa. 17013 ATTORNEY FOR MOTHER D a W: / /i ?16 Jeffrey A. bibmen, Father ' Dated: Stacy L. vtlret D a 2 c d: I AI*ela 40 CERTIFICATE OF SERVICE AND NOW, this December 8, 2006, I, Jane Adams, Attorney for Plaintiff/Petitioner Stacy L. Lehman, hereby certify that a copy of Mother's MOTION FOR CONTINUANCE has been duly served upon the Father's Counsel by placing such in the custody of the United States Postal Service, via certified mail, postage pre-paid addressed to: Roger Laguna, Esquire 1119 North Front St Harrisburg, Pa. 17102 ATTORNEY FOR FATHER Jan Adams, Esquire I.D No. 79465 6 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR MOTHER M o _ co r STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 02 - 4012 CIVIL ACTION LAW DEC 0 8 20D JEFFREY A. LEHMAN, : IN CUSTODY F' ORDER OF COURT AND NOW, this qkik day of roolt? , 2006, it is hereby ORDERED and DECREED that the hearing scheduled in the above-captioned matter in Courtroom No. 3, of the Cumberland County Courthouse, on December 11, 2006, shall be continued until the -? A day of May, 2007, at To 1) a.m./140. J. cc: /ane Adams, Esquire 'A ger Laguna, Esquire IA 'i:?Q flZ -C Wd $- 330 060Z I AUVI ',h - i0--`d 3Nl JO _'^ '71? STACY L. LEHMAN, Plaintiff V. JEFFREY A. LEHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02 - 4012 CIVIL ACTION LAW IN CUSTODY TEMPORARY CUSTODY ORDER AND NOW, THIS ? Day of December, 2006, based on the agreement of the parties, it is hereby ORDERED and DECREED: 1. The hearing scheduled for December 11, 2006 shall be continued and another hearing shall be scheduled in May 2007. 2. The Mother, Stacy L. Lehman and the Father, Jeffrey A. Lehman shall at all times continue to share legal custody of Kody A. Lehman, born March 5, 1993. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education, and religion. As soon as practicable after the receipt by a party, copies of a child's school schedules, special events notifications, report cards, and similar items shall be provided to the other party. Each shall notify the other party of any medical, dental, optical and other appointments of a child with healthcare providers, sufficiently in advance thereof so that the other party can attend. 3. Beginning January 1, 2007, at 4:00 p.m. the parties will have physical custody as follows. A. Father shall have primary physical custody of the child. B. Mother shall have partial physical custody as follows: i. Alternating weekends from Friday after school through Sunday at 7:00 p.m. ii. One evening during the week from after school through 7:30 p.m. iii. From Saturday April 7t'' at 3:00 p.m. through Sunday, April 8`' at 3:00 p.m. iv. On Mother's Day from 9:00 a.m. to 9:00 p.m. v. If either party's weekend fall on a weekend where the child has off school on a Monday holiday, they may keep the child through Monday at 7:00 p.m. vi. Other times as agreed by the parties. 3. Regarding counseling, it is hereby Ordered as follows: A. At the request of either party, Mother, Father and the child will complete an intake evaluation with a counselor, namely, Anthea Stebbins. The parties will share the cost for this counseling. Upon a recommendation for services, the parties will participate in family counseling. The parties may go to another family counselor upon mutual agreement. B. At the request of either party, Mother and Father will participate in a custody evaluation conducted by Deb Salem. The parties will share the cost for this evaluation. 4. This Order is entered pursuant to an agreement of the parties. the provisions of this Order by mutual consent. In the absence this Order shall control. J. The parties may modify the terms of cc: Roger Laguna, Esquire, for father Jane Adams, Esquire, for mother ?s 05/01/07 TLTE 02:12 FAX 2333394 LAGUNA IM 004 STACY L. LEHMAN, Pla o iff V. JEFFREY A. LEHMAN, Dei'ci dart AND NOW, this day of , 2007, UP331 the joint motion of Plaintiff and Defendant, a:adl to implement an age ent of the Parti Pi;, the parties IN THE COURT OF COMM ON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 4012 CIVIL ACTIOTf LAW IN CUSTODY JOINT MOTION FOR ENTRY OF, TEP;11:ORARY ORDER REGARDING CUSTODY hcT.eby request entry of thc., a ttached custody Ordi1 r. 1119 North Front4t. Harrisburg, Pa. 17102 ATTORNEY FOR FATI-VE il Dated: !r / J Adams, Esquire . Pitt St. c lisle, Pa. 17013 ATTORNEY FOR M07HER Dated: '?-)I'AlO9 C? r STACY L. LEHMAN, Plaintiff 5. JEFFREY A. LEHMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 4012 CIVIL ACTION LAW IN CUSTODY JOINT MOTION FOR ENTRY OF TEMPORARY ORDER REGARDING CUSTODY AND NOW this day of 1'-"0 CU_g 2007, come Plaintiff and Defendant by and through their attorneys and represent the folld? : 1. A hearing was previously scheduled for May 7, 2007 in the above-captioned matter before the Honorable Judge Edward Guido. 2. Plaintiff is represented by Attorney Jane Adams, and Defendant is represented by Attorney Roger Laguna. 3. Counsel for the parties have consulted with their respective clients and are in agreement with the request that the attached Temporary Order be entered as an Order of Court. 4. Counsel e both in agreement that this matter be rescheduled for a hearing before this Honorable Court at later date. SSETH: Roger Laguna, qu're 1119 North Front t Harrisburg, Pa. 17 2 ATTORNEY FOR FATHER Dated: 0-? WZ j a Adams, Esquire 64 JS. Pitt St. arlisle, Pa. 17013 ATTORNEY FOR MOTHER Dated: ?? h-.7 V r ? ? ":? F =. +"' l ?_ ?' ...ems STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 02 - 4012 CIVIL ACTION LAW JEFFREY A. LEHMAN, : IN CUSTODY ?j ORDER OF COURT 40^ '00 AND NOW, this 6 day of 1 , 200 , it is hereby ORDERED and DECREED that the hearing previously scheduled in the above-captioned matter in Courtroom No. 3, of the Cumberland County Courthouse, for May 7, 2007 shall be continued until the 4*A _ day of or-Ir 2007, at • 00 J. cc: Xane Adams, Esquire Xger Laguna, Esquire J -C 111 4 q ! ),'1;°" L10Z STACY L. LEHMAN, Plaintiff V. JEFFREY A. LEHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02 - 4012 CIVIL ACTION LAW IN CUSTODY TEMPORARY CUSTODY ORDER !A V AND NOW, THIS 7"Z?6 Day of X2007, based on the agreement of the parties, it is hereby ORDERED and DECREED: The hearing scheduled for May 7, 2007 shall be continued and another hearing shall be scheduled. 2. The Mother, Stacy L. Lehman and the Father, Jeffrey A. Lehman shall at all times continue to share legal custody of Kody A. Lehman, born March S, 1993. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education, and religion. As soon as practicable after the receipt by a party, copies of a child's school schedules, special events notifications, report cards, and similar items shall be provided to the other party. Each shall notify the other party of any medical, dental, optical and other appointments of a child with healthcare providers, sufficiently in advance thereof so that the other party can attend. 3. The prior Order of December 18, 2006 shall be modified by reference hereto to include the following summer schedule: "Summer Schedule: The summer schedule shall commence on the first Sunday after the last day of the child's school year, and then terminate one week prior to the start of the child's subsequent school year. Beginning the first Sunday after school ends, at 7:00 p.m., the parties shall share physical custody on an alternating weekly basis with Mother having a period of custody which will begin at 7:00 p.m. on the Sunday after school ends and continuing on until the following Sunday at 7:00 p.m. Thereafter, the parties shall alternate full-one week periods with the child, with the exchange occurring each Sunday evening at 7:00 p.m. If there is no subsequent mutual agreement, or subsequent superceding order, the Child shall return to Father at least one week prior to the start of the new school year and, thereafter, the Summer Schedule shall terminate and the prior Order of December 18, 2006 shall control as it did prior to the summer. 4. The prior Order of December 18, 2006 shall remain in effect in all other regards. 5. Regarding counseling, it is hereby Ordered as follows: A. The parties shall continue counseling with Anthea Stebbins, and shall follow her recommendations regarding counseling and the level of participation. The parties will share the cost for this counseling. The parties may go to another family counselor upon mutual agreement. 6. This Order is entered pursuant to an agreement of the parties. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. 5. It is specifically understood that Mother and Father shall do all that is required to ensure that the Child is able to continue to attend and actively participate in the extracurricular baseball and football teams, practice, games, etc., that Father enrolled him in at his school district. If travel and or attendance becomes a problem, the parties will cooperate to modify the summer schedule to some reasonable degree and in a limited fashion to remedy any travel or scheduling conflict that is currently unforseen. If there are substantial problems that have been documented and shared between counsel for the parties and which cannot be resolved between the parties and counsel, then either party may opt out of the summer schedule by giving one week written notice through counsel, and by default, the prior Order of December 18, 2006 shall control all matters. J. cc: Roger Laguna, Esquire, for father Jane Adams, Esquire, for mother STACY L. LEHMAN, Plaintiff V. JEFFREY A. LEHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02 - 4012 CIVIL ACTION LAW : IN CUSTODY MOTION FOR CONTINUANCE AND NOW comes the Plaintiff/Petitioner, Stacy L. Lehman, by and through her attorney, Jane Adams, and respectfully represents the following: 1. Plaintiff/Respondent is Stacy L. Lehman, (hereinafter referred to as "Mother"). 2. Defendant/Respondent is Jeffrey A. Lehman, (hereinafter referred to as "Father"); he is represented by Roger Laguna, Esquire. 3. The parties are the natural parents of one child, namely, Kody A. Lehman, date of birth, March 5, 1993. 4. A hearing before this Honorable Court was scheduled for August 6, 2007. 5. A Temporary Order, dated May 7, 2007, is currently in place. 6. Mother's counsel believes that the parties will be able to reach an agreement regarding legal and physical custody of the child. 7. Mother is requesting this matter be referred to conciliation in order to assist the parties with some of the minor issues regarding legal and physical custody. 8. Father's counsel, Roger Laguna, was consulted and concurs with this request. 9. This matter was previously ruled upon by Judge Guido. WHEREFORE, Plaintiff/Respondent Stacy A. Lehman, respectfully requests this Honorable Court to grant her request and enter the attached Order. Respectfully submitted, Date: J e Adams, Esquire D. No. 79465 64 South Pitt St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR MOTHER STACY L. LEHMAN ..4% CERTIFICATE OF SERVICE AND NOW, this July 31, 2007, I, Jane Adams, Attorney for Plaintiff/Petitioner Stacy L. Lehman, hereby certify that a copy of Mother's MOTION has been duly served upon the Father's Counsel by placing such in the custody of the United States Postal Service, via certified mail, postage pre-paid addressed to: Roger Laguna, Esquire 1119 North Front St Harrisburg, Pa. 17102 ATTORNEY FOR FATHER Jane Adams, Esquire D. No. 79465 64 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR MOTHER C? C-7 c o -n C= M:D _ 7T °,. OR O R C_ O Co IL STACY L. LEHMAN, Plaintiff V. JEFFREY A. LEHMAN, Defendant AND NOW, this to- ORDERED and DECREED: f AUG 012007 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 4012 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT day of , 2007, it is hereby 1. The hearing, which was scheduled for August 6, 2007, at 9:00 a.m. in Courtroom No. 3, is canceled. 2. This matter shall be referred to the conciliator, who shall schedule a conciliation at the earliest possible date to resolve all outstanding issues between the parties. 3. Pending further Order of Court, or mutual agreement of the parties, the prior Order of May 7, 2007 shall remain in effect. J. cc: /ae Adams, Esquire VR/oger Laguna, Esquire y w!ncif- , 60, $ gV Z- `Jtl 001 h SEP 13 2007 6 STACY L. LEHMAN, Plaintiff V. JEFFREY A. LEHMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 20024012 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this t 7 day of Cy "Oz_? , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. All prior Orders of Court are hereby vacated. 2. The Mother, Stacy L. Lehman, and the Father, Jeffrey A. Lehman shall have shared legal custody of Kody A. Lehman, born March 5, 1993. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 3. During the school year, Father shall have primary physical custody of the child. Mother shall have alternating weekends from Friday after school to Sunday at 8:00 p.m. Mother's weekend shall be extended if Friday or Monday is a school holiday, then Mother shall get the extra overnight. Mother shall also have physical custody one evening per week after school until 8:00 p.m., the day is left to Mother's discretion. s r 4. During the summer, the alternating weekend schedule shall reverse beginning the first Sunday in July until the second Sunday in August. That is, Mother shall have primary physical custody of the child beginning the first Sunday in July until the second Sunday in August and Father shall have alternating weekends from Friday to Sunday at 8:00 p.m. during this time period. After the second Sunday in August the school year schedule shall take effect. 5. Thanksgiving shall be alternated from year to year by the parties from 9:00 am. to 9:00 a.m. Father shall have physical custody of the child in even numbered years and Mother shall have physical custody of the child in odd numbered years. 6. Christmas shall be divided into two Blocks. Block A shall run from Christmas Eve at 2:00 p.m. to Christmas Day at 2:00 p.m. Block B shall run from Christmas Day at 2:00 p.m. to December 26 at 2:00 p.m. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. The remainder of the Christmas break shall be divided among the parties as equally as possible. 7. The Easter holiday shall be alternated from year to year by the parties from 9:00 a.m. to 9:00 p.m. Mother shall have physical custody of the child in even numbered years and Father shall have physical custody of the child in odd numbered years. 8. Mother shall have physical custody of the child on Mother's Day and Father shall have physical custody of the child on Father's Day, both from 9:00 am: to 9:00 P.M. 9. If the child's birthday falls on a school night, Mother shall be entitled to a block of time that evening. 10. Transportation shall be shared such that the relinquishing party shall transport. 11. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY J. cce Adams, Esquire, Counsel for Mother 70la, ge r R. Laguna, Jr., Esquire, Counsel for Father MNtiAWNN3d AINnor.) r ?p. ?? i?1i(1`J r' , v 01 :1 ! Wn 81 d3S, Llw AWIONOHIWd 3HI dfl 3?d.-!C??ld *h STACY L. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :20024012 CIVIL TERM JEFFREY A. LEHMAN, : CIVIL ACTION - LAW Defendant IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY DEPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kody A. Lehman March 5, 1993 Father 2. A Conciliation Conference was held in this matter on September 11, 2007 with the following individuals in attendance: The Mother, Stacy L. Lehman, with her counsel, Jane Adams, Esquire and Father, Jeffrey A. Lehman, with his counsel, Roger R. Laguna, Jr., Esquire. 3. The Honorable Edward E. Guido entered prior Orders of Court, dated May 7, 2007 and August 1, 2007 providing for shared legal custody, Father having primary physical custody during the school year with Mother having alternating weekends and for the parties to share physical custody of the child on a week on/week off basis during the summer. 3. The parties agreed to the entry of an Order in the form as attached. 13-0 4 , U Date acq line M.. Verney, Esquire Custody Conciliator