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HomeMy WebLinkAbout00-03083 ~ ~ 0'" . "_'__ J '. - ~. v-n-!lI!$tri-,,-~. , 'I MELISSA M. LYTER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. MARK S. LYTER, JR. DEFENDANT 00-3083 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT I)' AND NOW, this 23rd day of May ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear befonMelissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the ~ day of June , 2000, at 9:15 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 defme 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. FOR THE COURT, By: Isl Melissa P. Greery. ES~ 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 ATIORNEY 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_ I!; Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 . , h._ _ ., _f_'_ . ~ - ," . -~~-. FILEO'-Qr'FICE OF ThE r'AOTHONOTARY 00 MAY 30 PM 2: 32 CUMSElRIJWD COUN1Y PtNNSYLVAN/A . /7 _/ hB~ MA~ zb ~S-:. . 530. aJ uvr- '""'/7 ~n' 5;p.C;~ 7l~ /U~ Z ~ ~ 5:.fo,:>? ~ Z 4 ~ .~ 4 d..da...; . _.~__ _ 'I!"l'!':"":..___,lll11.""7"'1' ~. ""!' ,- -~ ~ -~"~~ .. _...--~ _'f'f-1p..,.,,,,,,,,,.)l'l!'Il,!III li1fi!9!lll~Yi1Jfi'1!!ill!!l~_..~: .__~,.Jll!I!Il!Q~, . ""'"-~-_, "l1'_"'_~~ .~.=- lIliJ ',' I 0'_ ~_,"- .~ - - " h-.:: ., . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAN MELISSA M. LYTER, Plaintiff v. MARK S. LYTER, JR., Defendant NO. OO'30~3 Civil Term IN CUSTODY ORDER OF COURT AND NON, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , the Conciliator, at on the day of , 2000, at ___.m., 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. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent Order. BY THE COURT: Custody Conciliator 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 AVENtJE CARLISLE, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact the office set forth above. 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. ,~. . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MELISSA M. LYTER, . . Plaintiff . . . . v. . NO. rHJ- 30F-3 Civil Term . . . MARK S. LYTER, JR., . . Defendant . IN CUSTODY . COMPLAINT FOR CUSTODY i~; ;11 ,;1,1 AND NOW comes the Plaintiff, MELISSA M. LYTER, by and through her attorney, Maryann Murphy, Esquire, of Legal Services, Inc., and respectfully files this Complaint for Custody, and in support thereof avers as follows: 1. The Plaintiff is MELISSA M. LYTER who currently resides at 411 Wren Court, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is MARK S. LYTER, JR. whose current address is unknown, however, he is employed by Saturn of Carlisle Pike, 6515 Carlisle Pike, Mechanicsburg, Cumberland County, Pennsylvania. 3. The Plaintiff seeks primary physical and shared legal custody of the following children: NICHOLAS LYTER, born June 17, 1996 and NATHEN LYTER, born July 20, 1998 d,_. -,,' -" 4. The children were born out of wedlock. They currently reside with the Plaintiff and the Plaintiff's grandmother. 5. During the lifetime of the children, they have resided at the following addresses with the following persons: Time with Whom Address birth-6/97 10 West Locust Street Plaintiff/Plaintiff's Eno1a, PA grandmother 6/97-7/98 10 West Locust Street Plaintiff/Defendant Enola, PA Plaintiff's grandmother 7/98-11/98 306 Valley Road Plaintiff/Defendant Marysville, PA Defendant's parents/ Defendant's sisters 11/98-4/26/00 411 Wren Court Plaintiff/Defendant Mechanicsburg, PA Plaintiff's grandmother 4/26/00-present 411 Wren Court Plaintiff/Plaintiff's Mechanicsburg, PA grandmother 6. The father of the children is MARK S. LYTER, JR. He is married to Plaintiff. 7. The mother of the children is MELISSA M. LYTER. She is married to Defendant. 8. The children currently reside with Plaintiff and her grandmother. 9. The Plaintiff has not participated as a party or witness, . -ji; ,I [:1 ;'j " , '-J i I I i j I I 1 I I , " i :! , ::1 ! ,i :i .I , I 'j , I ,'1 ;j '-j i i , " I -J " -"-," " or in any other capacity, in other litigation concerning the custody of the children in this or any other Court, except as set forth above. 10. The Plaintiff has no information of a custody proceeding concerning the children pending in a Court of this Commonwealth. 11. The Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children, or claims to have custody or visitation rights with respect to the children. 12. Each parent whose parental rights to the children have not been terminated, and the persons who have physical custody of the children, have been named as parties to this action. There are no other persons known to have or claim a right to custody or visitation of the children and therefore, no further notice of the pendency of this action and the right to intervene shall be given, other than to the parties named herein. 13. The best interest and permanent welfare of the minor children will be served by granting Plaintiff primary physical and shared legal custody. -~ 'I J !~ , " I , I J :'! I :1 , ., I II :1 Ij "j i i-,1 " [:1 1'1 i: , ~ ] 11 ,j !:j ':j " iJ f!] ij 1"1 I.: I i; 1.1 !! i; i " i1 . ~-~~~./;u<(-,;, . WHEREFORE, Plaintiff requests this Honorable Court to grant her primary physical and shared legal custody of NICHOLAS and NATHEN. Respectfully submitted, / Maryann Murphy, Legal Services, 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for Plaintiff 1,- -!U~.L . VERIFICATION I, MELISSA M. LYTER, verify that the statements made in the foregoing Custody Complaint 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. 1f{~ itZlp - MELISSA M. LYTER ' ~' ' - C" ,_.' ~, ' . J' .",. '- ., ,<,', . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MELISSA M. LYTER, Plaintiff VS. MARK S. LYTER, JR., Defendant : NO. Civil Term : IN CUSTODY CERTIFICATE OF SERVICE I, Maryann Murphy, Esquire, do hereby certify that on the day of , 2000 I served a true and correct copy of the foregoing Custody Complaint on counsel for the Defendant, ANDREW NORFLEET, ESQUIRE, at the address set forth below, by placing a copy of same in the United States Mail, first class, postage prepaid. Andrew Norfleet, Esquire METZGER WICKERSHAM 3211 North Front Street Harrisburg, PA 17110 Respectfully submitted, Maryann urphy, Legal Services, 8 Irvine Row Carlisle, PA 17013 (717) 540-8600 LD. # 61900 .'.-. 'f,! i"l i:,~ ~i i ;;:1 !" i'! ;1 q "f !:i ri Ii' )j ;'; :'1 I:': I;' I': '" I~i :" '_I ::i (i iJ , i'! ,-f rl :1 Ii I'.!. , Ii II Ii !i il -~.~ ~~ liU:dtl~RI~ . ,,'<h.~ ~~i1J ~ "'lJsllmli~~' -:.. __"!Ilf - .. ~ '. ,<'~ ."'_ .,;~ :,C-',","">_'_ .... .~"'-,,,,,., . 1--\ 0 Cd 0 ~ C 0 . :~"'- -n ~ -rJ;;-;) :1: .--1 ~ nl~:'- :12* ?:'~:?] ~~~:2 ....-0;. , I \ (n -'!::;\"11 ~ ~~fj CO ~::~~ j;: ."~ :t7~ --~ -'r' _,r ,'--1-1 ~~; -:-~. ~~ -j ~ ~:'?-n ,- ...Y ~ W 'i;! C) ~ \\\ ~) , ii! , I I I i l;;:; , '~ ,. , - ',' ~.i.'., , ~ , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MELISSA M. LYTER, Plaintiff v, Do - 30<<3 ~ : IN CUSTODY : NO. MARK S, LYTER, JR., Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, MELISSA M. LYTER, Plaintiff, to proceed in founa oauoeris, I, Maryann Murphy, Esquire, of Legal Services, Inc., attorney for the party proceeding in forma oauoeris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party, The party's affidavit showing inability to pay the costs of litigation is attached hereto. ~~ ~ ,l/L Maryinn rphy, Esquire Legal Services, mc, 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 LD. # 61900 Attorney for Plaintiff '- "' - ';-i ;1 . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA CML ACTION - LAW MELISSA M. LYTER, Plaintiff : NO. v, : IN CUSTODY MARK S. LYTER, JR., Defendant AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS ,: :1 II ~ i ,I i,j I .1 [j 'i tl Ii Ii :i '1 ,I 'I I I, II II I, -i .1 I II 'I :r ,I 'I I J :1 1. I am MELISSA M. LYTER, Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: MELISSA M. LYTER Address: 411 Wren Court. Mechanicsbufl!. PA 17055 (b) Social Security Number: 170-62-6813 If you are presently employed, state N/A Employer: N/A Address: N/A Salary or wages per month: N/A Type of work: N/A " c ,,- - ,-" "Of Y - ~ ';"1 , . If you are presently unemployed, state Date of last employment: 2/99 (Temp work - 2 weeks) Salary or wages per month: $180.00 Type of work: Janitorial Interest: -0- " I I-J ,I , , I :1 ,'j I 'I (c) Other income within the past twelve months Business or profession: "0- Other self-employment: -0- Dividends: -0- Pension and annuities: -0- Social Security benefits: -0- Support payments: -0- Disability payments: -0- Unemployment compensation and supplemental benefits: -0- Workman's compensation: -0- Public Assistance: -0- Other: -0- (d) Other contributions to household support NONE (Wife)(Husband) Name: N/A the parties are seDarated If your (husband) (wife) is ernployed, state Employer: N/A 'i . . 'k- --. l!.uim.2lq. Salary or wages per month: N/A Type of work: N/A Contributions from children: -0- (e) Property owned Cash: $100,00 Checking Account: -0- 1 '1' , i: 'j Savings Account: -0- Certificates of Deposit: "o- Real Estate (including home): -0- Motor vehicle: Make N/A Cost N/A Stocks; bonds: -0- Other: -0- (t) Debts and obligations Mortgage: -0- Rent: $200,00 Loans: -0- Monthly Expenses: $1.000.00 Year N/A Amount owed N/A (g) Persons dependent upon you for support (Wife) (Husband) Name: N/A " -~",,;.! Children, if any: Name: Nicholas Age: 3 Name: Nathen Age: 1 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. 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:5-/'-I-(Jj 11(;~fI! h%' MELISSA M. LYTER '-7-' Ti:"& L' ~ ~''''''~;L:&tjjJll.i_.:MiIiRwr~ .... "",,;,-,~ - .-./. ,--.",,,,,. ,-=,,'-~""'~ .UJMli:Jii!IiiIi~~~i'liMl'~~~~ . - ~ .'"~-, C) 92t~ ~S~:: ----- '" gL5 ~~~l -'7 ::':4 -< II C::) C) :J~ ::1't .~( o .'n ::..-1 ;'-{1:D .... ",";rn :J.~IY 0,,- :::j~;!' /5-n ~~c:__ ;::::; am o;;i ~ 0' :;:-:';> ~,,,< _~4. ~~) Cl I'j ~ _.~~ ~'< .L- ~__o .c ;.'.' > ~- ~, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL VANIA , CIVIL ACTION" LAW MELISSA M. LYTER, Plaintiff No. 00-3083 Civil Term v. MARK S. LYTER, JR., Defendant IN CUSTODY ORDER OF COURT AND NOW, this 2:D ~ day of ::r u.J)~ ,2000, upon consideration of the attached Stipulation for Entry of a Custody Order, IT IS HEREBY ORDERED AND DECREED that custody of the minor children NICHOLAS LYTER, born June 17, 1996; and NA THEN LYTER, born July 20, 1998, is awarded as follows: I. The parents shall share legal custody of the minor children_ (a) All major decisions affecting the children's growth and development shall be made by the parents jointly, after discussion and consultation with each other and with a view towards obtaining and following an harmonious policy in the children's best interest. These decisions include, but are not limited to, medical, educational and religious matters. (b) Each parent shall give support to the other in their role as parent and to take into account the concerns of the other for the physical and emotional well-being of the children. (c) While in the presence of the children, neither parent shall make, or permit any other person to make, any remarks or do anything which could in any way be construed as derogatory ~ ~. .~"""!"..l . '~_',""",",..~.,,';" .lIt ",.. -'~ -"."" . ,=' ,-,,, 'r.. .-_~.." .._.~ .'-.""r"""-';'--~"I' ;L. '" ~~ f , uo J~n;,: ~: {'{l i: I.,.. CUfvic;:~l-{j'i\:",; l),),J!,JTY PENNSYlV:\N~\ . . r~~~~~MlII~~WW"1 , i I~!~l!f " ., ,,;, "-1,'- ',,"," h" or uncomplimentary to the other parent. It shall be the express duty of each parent to uphold the other parent as one whom the children should respect and love. (d) Each parent shall have the duty to notifY the other of any event or activity that could reasonably be expected to be of significant concern to the other parent. Each parent shall provide the other with a current telephone number and address for contact. (e) The parents shall communicate directly with one another concerning any parenting issues requiring consultation and agreement and regarding any proposed modifications to the physical custody schedule which may, from time to time, become necessary. (f) With regard to any emergency decisions which must be made, the parent with physical custody of the children at the time shall be pel1nitted to make the decision necessitated by the emergency without consulting the other parent in advance. However, the parent with physical custody making an emergency decision shall inform the other of the emergency and consult with her/him as soon as possible. Day"to-day decisions of a routine nature, including those related to medical care, shall be the responsibility of the parent having physical custody at the time. (g) Each parent shall be entitled to complete and full information from any doctor, dentist, teacher, etc. and have copies of any reports given to them as a parent. Such documents include, but are not limited to, medical reports and school report cards. Both parents may, and are encouraged to, attend school conferences and activities, as their schedules permit. Both parents' names shall be listed with the school. Both parents shall provide the other with any and all information received by them from the school. 2. The parents shall share physical custody of NICHOLAS and NATHEN. The primary residence of the minor children shall be with MOTHER. ~ ~ :i " 'j 1 , ii :'1 I: '! , " " !! i i [I i 'i 1 :j , , ii I 'I il II " :1 .i , , i 'I , jo " , ~~ , -" ,. ~ """,-,,,,,,~. ,--,j I i] "j 3. MOTHER and FATHER shall each have the minor children for one week during the q I I I ! ;,j :l 'I i !I :1 ;1 "j U " ,'J ~1 1 j ,1 i ! i 'I i I . i I I i i II I' il i , F ATHER shall have custody from Fridays at 5 :30 p.m. until Sundays at 2:00 p.m. each week, except that MOTHER shall have the opportunity to have the minor children for an occasional weekend upon seventy-two (72) hours notice to FATHER. In that event, FATHER shall have the opportunity to see the children during the week. It is expected that FATHER shall have a suitable residence to accommodate the children during his periods of partial physical custody. summer months. A week shall be defined as seven (7) days. The parents shall give each other written notice of their chosen week for summer custody by June I" of each year, ifpossible. In the event that both parents choose the same week, the parent who gave first notice shall prevaiL 4. MOTHER shall have the children on Mother's Day and FATHER shall have the children on Father's Day as they can agree. Only in the event that the parents cannot agree, the hours shall be from 6:00 p.m. the evening before the holiday until 6:00 p.m. the day ofthe holiday, regardless of the usual schedule. 5. The parents shall share or alternate the holidays of Memorial Day, the Fourth of July and Labor Day each year as they can agree. Only in the event that the parents cannot agree, the hours shall be from 9:00 a.m. until 8:00 p.m. on the following schedule: In 2000 and in all even years thereafter, MOTHER shall have Memorial Day and Labor Day, and FATHER shall have the Fourth of July. In 200 I and in all odd years thereafter, FATHER shall have Memorial Day and Labor Day and MOTHER shall have the Fourth of July. 6. The parents shall share the holidays of Easter and Thanksgiving each year as they can " ~ ~ , , "", '--, !:1 'i agree. Only in the event that the parents cannot agree, the following shall be the schedule: In 2000 and in all even years thereafter, MOTHER shall have Easter from 9:00 a.m. until 2:30 p.m. and Thanksgiving from 2:30 p.m. until 8:00 p.m.; and FATHER shall have Easter from n -;; 2:30 p.m. until 8:00 p.m. and Thanksgiving from 9:00 a.m. until 2:30 p.m. In 2001 and in all odd years thereafter, FATHER shall have Easter from 9:00 a.m. until 2:30 p.m. and Thanksgiving from 2:30 p.m. until 8:00 p,m. and MOTHER shall have Easter from 2:30 7. MOTHER and FATHER shall share the Christmas holiday with the minor children as they ~ 1:1.; ;1 ,,',i p.m. until 8:00 p.m. and Thanksgiving from 9:00 a.m. until 2:30 p.m. can agree. Only in the event that the parents cannot agree, the Christmas holiday shall be divided into two (2) segments and shall be alternated between them each year. Segment "A" shall be from noon on December 24th until noon on Christmas Day. Segment "B" shall be from noon on Christmas Day until noon on December 26th. In 2000 and in all even years thereafter, MOTHER shall have Segment "A" and FATHER shall have Segment "B". In 2001 and in all odd years thereafter, FATHER shall have Segment "A" and MOTHER shall have Segment "B". 8. The parents shall each have the opportunity to see the minor children on their birthdays, June 17th and July 20th, and on each ofthe parents birthdays. 9. The schedules for all holidays, special occasions and vacations shall take priority over the regular weekly schedule. "" r- ~.-'~" 10. There shall be reasonable telephone access between the children and both parents. The children shall be permitted reasonable telephone access to place calls to their parents. II. By mutual consent of the parents, a revised schedule may be agreed upon between them for and in the best interests of their minor children. 12. This Order shall replace and supercede any and all prior Custody Orders, and shall remain in full force and effect until further Order of Court. BY THE COURT: ~ J. , '~ ~~c} ~Jc)O )J~ tI ~y.. ~ , -'"'"~. ~, '" ~ . ~~ "' --' '_!il~.lj[.)> . , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MELISSA M. LYTER, Plaintiff No. 00-3083 Civil Term v. MARK S. LYTER, JR., Defendant IN CUSTODY STIPULATION FOR ENTRY OF CUSTODY ORDER MELISSA M. LYTER (hereinafter referred to as "MOTHER"), and MARK S. LYTER, JR. (hereinafter referred to as "FATHER"), desiring to amicably settle and resolve all outstanding issues concerning custody with respectto NICHOLASL YTER, born June 17, 1996,.andNATHEN LYTER, born July20, 1998, the minor children involved in this action, hereby stipulate and agree to the entry of an Order of Court awarding cust()dy ofNICHOL,i\S and NATHE.N.as follows: 1. The parents agree to share legal custody of the minor children, (a) All major decisions affecting the children's growth and development shall be made by the parents jointly, after discussion and consultation with each other and with a view towards obtaining and following an harmonious policy in the children's best interest. These decisions include, but are not limited to, medical, educational and religious matters, (b) Each parent agrees to give support to the other in their role as parent and to take into account the concerns of the other for the physical and emotional well-being of the children. (c) While in the presence of the children, neither parent shall rnake, or permit any other person to make, any remarks or do anything which could in any way be construed as derogatory or uncomplimentary to the other parent. It shall be the express duty of each parent to uphold the other ,..~.~-~~." .-' 0 ~ ~ "i'II>H> ~~ I ~ J ~""__~1" /' . < parent as one whom the children should respect and love. (d) Each parent shall have the duty to notify the other of any event or activity that could reasonably be expected to be of significant concern to the other parent. Each parent shall provide the other with a current telephone number and address for contact. (e) The parents shall communicate directly with one another concerning any parenting issues requiring consultation and agreement and regarding any proposed modifications to the physical custody schedule which may, from time to time, become necessary. (f) With regard to any emergency decisions which must be made, the parent with physical custody of the children at the time shall be permitted to make the decision necessitated by the emergency without consulting the other parent in advance, However, the parent with physical custody making an emergency decision shall inform the other of the emergency and consult with herfhim as soon as possible, Day-to-day decisions of a routine nature, including those related to medical care, shall be the responsibility of the parent having physical custody at the time. (g) Each parent shall be entitled to complete and full information from any doctor, dentist, teacher, etc. and have copies of any reports given to them as a parent. Such documents include, but are not limited to, medical reports and school report cards, Both parents may, and are encouraged to, attend school conferences and activities, as their schedules permit. Both parents' names shall be listed with the school. Both parents shall provide the other with any and all information received by them from the school. 2, The parents agree that they shall share physical custody of NICHOLAS and NA THEN. The primary residence of the minor children shall be with MOTHER. FATHER shall have custody from Fridays at 5 :30 p.m. until Sundays at 2:00 p,m. each week, except that MOTHER shall have the opportunity to have the minor children for an occasional ._c., _""' ~ ' , -." ~ -. "~"'~~,. weekend upon seventy-two (72) hours notice to FATHER. In that event, FATHER shall have the opportunity to see the children during the week. It is expected that FATHER shall have a suitable residence to accommodate the children during his periods of partial physical custody. 3. MOTHER and FATHER agree that each shall have the minor children for one week during the summer months. A week shall be defined as seven (7) days. The parents shall give each other written notice oftheir chosen week for summer custody by June 1st of each year, if possible. In the event that both parents choose the same week, the parent who gave first notice shall prevail. 4. The parents agree that MOTHER shall have the children on Mother's Day and FATHER shall have the children on Father's Day as they can agree. Only in the event that the parents cannot agree, the hours shall be from 6:00 p.m. the evening before the holiday unti/6:00 p.m. the day of the holiday, regardless of the usual schedule. 5. The parents shall share or alternate the holidays of Memorial Day, the Fourth of July and Labor Day each year as they can agree. Only in the event that the parents cannot agree, the hours shall be from 9:00 a.m. until 8:00 p.m. on the following schedule: In 2000 and in all even years thereafter, MOTHER shall have Memorial Day and Labor Day, and FATHER shall have the Fourth of July. In 200 I and in all odd years thereafter, FATHER shall have Memorial Day and Labor Day and MOTHER shall have the Fourth of July. 6. The parents shall share the holidays of Easter and Thanksgiving each year as they can agree. Only in the event that the parents cannot agree, the following shall be the schedule: In 2000 and in all even years thereafter, MOTHER shall have Easter from 9:00 a.m. until ;;! ~-~ ,)),.4 "~ ]'li\!o)i!l 2:30 p.m. and Thanksgiving from 2:30 p.m. until 8:00 p.m.; and FATHER shall have Easter from 2:30 p.m. until 8:00 p.m. and Thanksgiving from 9:00 a.m. until 2:30 p.m. In 200 I and in all odd years thereafter, F ATHER shall have Easter from 9:00 a.m. until 2:30 p.m. and Thanksgiving from 2:30 p.m. until 8:00 p.m. and MOTHER shall have Easter from 2:30 p.m. until 8:00 p.m. and Thanksgiving from 9:00 a.m. until 2:30 p.m. 7. MOTHER and FATHER shall share the Christmas holiday with the minor children as they can agree. Only in the event that the parents cannot agree, the Christmas holiday shall be divided into two (2) segments and shall be alternated between them each year. Segment "A" shall be from noon on December 24th until noon on Christmas Day. Segment "B" shall be from noon on Christmas Day until noon on December 26th. In 2000 and in all even years thereafter, MOTHER shall have Segment "A" and FATHER shall have Segment "B". In 2001 and in all odd years thereafter, FATHER shall have Segment "A" and MOTHER shall have Segment "B". 8. The parents agree that each shall have the opportunity to see the minor children on their birthdays, June 17th and July 20th, and on each of the parents birthdays. 9. The schedules for all holidays, special occasions and vacations shall take priority over the regular weekly schedule. I O. The parents agree that there shall be reasonable telephone access between the children and both parents. The children shall be permitted reasonable telephone access to place calls to their parents. II. Both parents agree that, by their mutual consent, a revised schedule may be agreed upon rP'~~~~ ;_0 ~" ~. I --.........- ~"""'1>>..l' between them for and in the best interests of their minor children. 12. The parents agree that this Agreement shall be submitted to the Court of Common Pleas of Cumberland County for approval and for entry of an Order awarding custody as set forth herein, and the parents hereby request that this Honorable Court enter such an Order. IN WITNESS WHEREOF, the parties have executed this Stipulation for Entry of a Custody Order on the date indicated below. -I-r-Of) Date ~,!t~(} Date ~MJv~ Witness . ~ MARK S. LYTER, JR. ..~'-;!;j.';;;'-"'-'-"""'"""NJ~_!lilII~1li:I~~~_~.",~~~ ,...'" "~Il "0 ~.""'- . ~. I _'.W~~l-I' (:'9 ,'" 0 C) () c 0 ",1 ::Ct' C_ .---f "'"OC:.: nln--l -- Z:tJ :;:::: ~~~:. 1 U'1 '....,.J r"o \_J ~ -0 ::J ~O ....f:... C) -0 Co...." ;-=-:;r-r, Pc ,~ Z -"j r.' b =< :D C> -< MELISSA M. LYTER, Plaintiff, V. MARK S. L YIER, Defendant. -'-,I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 00-3083 Civil Action - Law In Custody ORDER OF COURT ... --~, JUN 26 2~ AND NOW, this 21st day of June, 2000, the Conciliator, being advised by Plaintiffs counsel that all custody issues have been resolved by Stipulation of the parties, hereby relinquishes jurisdiction in this case. FOR THE COURT, / Melissa Peel Greevy, Esquire Custody Conciliator ,'n(': ...'..... !'\}-n A. n"\J Fi\J::\rr~\:I_\(\\'.\O\t\'n 1 \ "., . '", j i ,;~' C'" \...... ',,'., ;\" \,'-' ?\'\ '): \ 1 GO J\..\\~2S '- C\.lM~[~~~~~~~Nl'l [:~ - w ~ ~. .,,-> ' , ~"- . ,._,"",,_flIil!!lill!W~f!!I~~)!lll'iliijrnMili~VllJ.:r~_.~1ff'W:![r. """IU!l!!ll!