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HomeMy WebLinkAbout02-4884ROBERT LOWRY, V. KAREN LOWRY, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : : CIVIL ACTION - LAW : : CUSTODY NO. ~>~ CU TODYCO P INT AND NOW, comes Plaintiff, Robert Lowry, through his attorney, the Law Office of Darrell C. Dethlefs, and avers the following: Plaintiff is Robert Lowry, an adult individual with a residence located at 560 Boxwood Lane, Carlisle, Pennsylvania 17013. The Defendant is Karen Lowry, an adult individual with a residence which is unknown. However, she receives mail at 560 Boxwood Lane, Carlisle Pennsylvania. 4. 5. 6. Plaintiff seeks primary physical and joint legal custody of Christian Nathaniel Lowry, born March 31, 2000 (hereinafter known as Child). Plaintiff, Robert Lowry, and Defendant, Karen Lowry are married. Christian Nathaniel Lowry was born during the marriage. Plaintiff and Defendant are the natural parents of Christian Nathaniel Lowry. Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. The best interests and permanent welfare of the children will be served by granting the relief requested because the Plaintiff is better able to provide a stable, secure environment in which to raise the child. Plaintiff is requesting joint legal custody and shared physical custody of the child. Plaintiff, Robert Lowry is a member of the United States Army National Guard. Defendant is not a member of the Armed Forces of the United States or any of its allies. WHEREFORE, Plaintiff respectfully requests this Court to grant joint legal custody and shared physical custody of the child and the right of first refusal for child care. Date: By: Respectfully Submitted, - ~ ~ykosh ^ttorney I.D. 555§1 3805 Market Street Camp Hill, P^ 17011 (717) ROBERT LOWRY, V. KAREN LOWRY, Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CUSTODY NO. VERIFICATION I hereby verify that the statements of fact made in the foregoing Petition for Custody, are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the criminal penalties contained in 18 Pa C. S. Section 4904, relating to unsworn falsification to authorities. Date: (~//~/~) ,/~ ~__ ~'-.~/'/~ Robert Lowry f ROBERT LOWRY, ¥. KAREN LOWRY, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : : CIVIL ACTION - LAW : CUSTODY NO. I hereby verify that the statements of fact made in the foregoing Petition for Custody, are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the criminal penalties contained in 18 Pa C. S. Section 4904, relating to unsworn falsification to authorities. Date: RObert Lowry ROBERT LOWRY IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA : V. : 02-4884 CIVIL ACTION LAW KAREN LOWRY DEFENDANT : IN CUSTODY ORDER OF COURT AND NOW, Tuesday, October 15, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greev~, Esq. , the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Tuesday, November 12, 2002 at 12:30 PM 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/ Melissa P. Greevy. Esq. 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 alTangements 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 ROBERT LOWRY, Plaintiff : IN THE ~:OURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW KAREN LOWRY, : Defendant : CUSTODY NO. ~3. -- '/~/~/./ / CUSTODY COMPLAINT AND NOW, comes Plaintiff, Robert Lowry, through his attorney, the Law Office of Darrell C. Dethlefs, and avers the following: Plaintiff is Robert Lowry, an adult individual with a residence located at 560 Boxwood Lane, Carlisle, Pennsylvania 17013. .. The Defendant is Karen Lowry, an adult individual with a residence which is unknown. However, she receives mail at 560 Boxwood Lane, Carlisle Pennsylvania. Plaintiff seeks primary physical and joint legal custody of Christian Nathaniel Lowry, born March 31, 2000 (hereinafter known as Child). Plaintiff, Robert Lowry, and Defendant, Karen Lowry are married. Christian Nathaniel Lowry was born during the marriage. 5. Plaintiff and Defendant are the natural parents of Christian Nathaniel Lowry. Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. The best interests and permanent welfare of the children will be served by granting the relief requested because the Plaintiff is better able to provide a stable, secure environment in which to raise the child. 8. Plaintiff is requesting joint legal custody and shared physical custody of the child. Plaintiff, Robert Lowry is a member of the United States Army National Guard. Defendant is not a member of the Armed Forces of the United States or any of its allies. WHEREFORE, Plaintiff respectfully requests this Court to grant joint legal custody and shared physical custody of the child and the right of first refusal for child care. Date: Respectfully Submitted, By: ~' _ ~v /M~'chael J~ykosh Attorney I.D. 58851 3805 Market Street Camp Hill, PA 17011 (717) 975-9~.~.5 ROBERT LOWRY, Plaintiff V. KAREN LOWRY, Defendant : IN, THE ~OURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA .- : CIVIL ACTION - LAW : : CUSTODY NO. I hereby verify that the statements of fact made in the foregoing Petition for Custody, are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the criminal penalties contained in 18 Pa C. S. Section 4904, relating to unsworn falsification to authorities. Robert Lowry / ROBERT LOWRY PLAINTIFF Vo KAREN LOWRY DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02.4884/ CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, October 23, 2002 _, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Tuesday, November 12, 2002 at 12:30 PM 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/ Me!issa P. Greevv. Esa. 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 ROBERT LOWRY, KAREN LOWRY, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4884 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this /7 o J~ day of ~ ~ ~ ~ L~,~ , 2002, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The Father, Robert Lowry, and the Mother, Karen Lowry, shall have shared legal custody of the minor child, Christian Nathaniel Lowry, born March 31, 2000. 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 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 of 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. 2. Eb.v~. Mother shall have primary physical custody subject to Father's right of partial physical custody which shall be arranged as follows: A. From Friday at 5:00 p.m. until Sunday at noon on two (2) weekends per calendar month. Father's weekends shall be arranged to not include the weekends on which he is on duty for the National Guard. To facilitate making custodial arrangements, Father has provided Mother with a copy of his National Guard schedule through September 3, 2003. Father's first custodial weekend shall commence on November 23, 2002. B. At other such times as the parties may agree. C. Father shall provide Mother with a cop!/of his National Guard and work schedule and updates thereto as they shall come to him. NO. 02-4884 CIVIL TERM 3. ~d~. Transportation instant to custody shall be shared by the parties by effecting the custodial exchange at a mutually agreeable meeting place. The first choice of meeting place shall be the home of the paternal grandparents. In the event that arrangement does not work out, the parties will meet at the McDonald's on High Street in Cadisle or at such other meeting place as the parties may agree. 4. Holidays. Because Father's work schedule for Christmas is available to him less than two (2) weeks before the holiday each year, the parties are expected to be flexible with each other in order to provide for Christian to have time with both parents on the days of December 24th or December 25th each year. Unless otherwise agreed, in even numbered years, Mother shall have custody from December 24th at noon until December 25th at noon. In odd numbered years, Mother shall have custody from December 25th at noon until December 26th at noon. In even numbered years, Father shall have custody from December 25th at noon until December 26th at noon. In odd numbered years, Father shall have custody from December 24th at noon until December 25th at noon. Dist: BY THE COURT: /~Vlichael A. Pykosh, Esquire, 3805 Market Street, Camp Hill, PA 17011 ,~,Mark F. Bayley, Esquire, 155 South Hanover Street, Carlisle, PA 17013 ROBERT LOWRY, KAREN LOWRY, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4884 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY 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 Christian Nathaniel Lowry March 31,2000 CURRENTLY IN THE CUSTODY OF Ivlother 2. A Custody Conciliation Conference was held on November 12, 2002 in response to Father's Custody Complaint, which was filed on October 7, 2002. Mother filed a Divorce Complaint on October 17, 2002, docketed at 02-5040, which also contains a count for custody. Her claims will be consolidated with that of Father's Custody Complaint which was filed first in time. Present for the conference were the Father, Robert Lowry, and his counsel, Michael J. Pykosh, Esquire; the Mother, Karen Lowry, and her counsel, Mark F. Bayley, Esquire. 3. The parties reached an agreement in the form of an Order as attached. Counsel agreed to the Conciliator entering the appropriate Order to dispose of the two (2) pending custody complaints and consolidating the/,.cus~dy matter into one action. Therefore, two (2) Orders appear with this report. / l I 1.3/o Es-uire Melissa ~'ee y, q Date Custody Conciliator