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Home My WebLink About00-03257 p . "," "-= ~',-"" :" . JESSEJ.LE~ PLAINTIFF V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WHITNEY BLAIR MARIE PETTERSEN DEFENDANT 00-3257 CIVIL ACTION LAW IN CUSTODY 1,:1 ORDER OF COURT AND NOW, this 26th day of May ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main street, Mechanicsburg, PA 17055 onthe 19th day of July ,2000,at9:30AM 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. FOR THE COURT, By: /s/ Dawn S. SundaJl. 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 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 TIllS 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 d ~ FiLED- );:r uF r!.,:. DI' -l., riCE . ,--I, "DTHlh"40TARY 00 MAY 30 PH 2: 26 CUM8t;D pi:nkt:!J.D COUNTY ......'ol/;;VANlI\ .. f.30,m t!d..~ ~ z4 ~ SJo.co 71~ ~ ti dfI- 530-a? ~ /n~ ~ a:z;-~~ . . '~ , ~~-,.._.I~ ~ , IIIIINI' ~_ .,.,...,..,._~~~~;ro~~~~_7"~.._...",.~I~""'" - , . -" " ~ ,,,. 0_"_' .__ <, --'. ."'b' ' " ..i\ -'._~ -, - ,'-, --_"._">i__.' . "'.'_"J_',. ' , JESSE J. LEHMAN, Plaintiff : IN TIlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000- d.J.S'7 CIVIL TERM v. WHITNEY BLAIR MARIE PETTERSEN, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, this day of , 2000 upon consideration of the attached Complaint it is hereby directed that the parties and their respective counsel appear before Esquire, the conciliator, at , Pennsylvania, on the day of , 2000, at o'clock ,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. All children age five or older may be present at the conference. Failure to appear , at the conference may provide grounds for entry of a temporary or permanent order. FOR TIlE COURT: By: 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 TIDE OFFICE SET FORm BELOW TO FIND OUT WHERE YOU CAN GET HELP. TIlE CUMBERLAND COUNTY BAR ASSOClA TION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 1-800-990-9108 ^ I ,., '.' -:" i ,_0_ "-K ,,,,-,,C, ,,~ ," "" ," ,>+, [,_. ' {' .. JESSE J, LEHMAN, Plaintiff v, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 2000- 3-' 57 CIVIL TERM WHITNEY BLAIR MARIE PETTERSEN, : CIVIL ACTION - LAW Defendant : IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Jesse J. Lehman, an adult individual currently residing at 273 Redwood Lane, Carlisle, Cumberland County, Pennsylvania 17013, 2. Defendant is Whitney Blair Marie Pettersen, an adult individual currently residing at 33 Skyline Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055, 3. The Defendant is the natural mother of the child, Kadin Darius Lehman, born November 28,1999. 4. The child was born out of wedlock. 5. Since birth, the child has resided with the following persons at the following addresses for the following lengths of time: NAMF, A DD'RFSS DATFS Jesse Lehman Whitney Pettersen paternal grandparents 273 Redwood Lane Carlisle, P A November 28, 1999 to May 13, 2000 Whitney Pettersen maternal grandparents 33 Skyline Drive Mechanicsburg, P A May 13, 2000 to present 6, The natural mother of the child is Whitney Blair Marie Pettersen, who resides as foresaid. She is single, '.,- .", -~ .' ,~~--\ --,-.;"-,,," ~". " .~~~~- ',,' ,'; j. \, 7, The natural father ofthe child is Jesse J. Lehman, who resides as foresajd. He is single, 8. The relationship of the Plaintiff to the child is that of natural Father. The Plaintiff currently resides with the paternal grandparents of the child, 9. The relationship of the Defendant to the child is that of natural Mother. The Defendant currently resides with the child and the maternal grandparents of the child, 10. The Plaintiff has no information of a custody proceeding concerning the child pending in any Court of this Commonwealth, 11. The best interest and permanent welfare of the child will be best served by granting the relief requested as the Plaintiff is better suited to provide a stable environment to foster the child's well being. 12. The Plaintiff does not know of any person not a party to the proceedings who claims to have custody or visitation rights with respect to the child, WHEREFORE, the Plaintiff, Jesse J. Lehman, respectfully requests this Honorable Court to enter an Order scheduling the Parties for a Custody Conciliation. Respectfully submitted, ::5- OY-OD Date: omas S. Diehl, Esquire Attorney for the Plaintiff 401 East Louther Street, Suite 103 Carlisle, Pennsylvania 17013 (717) 240-0833 ~, c 0,'" .',".._ n_~'", ,_ ',-'<:",-,_;J. '. ~ ' _.,:;, , I' \ ~ VERIFICATION 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. g 4904, relating to unsworn falsification to authorities. ~l~~~ JE 1. LE , Plaintiff , . I JESSE J. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. : NO. 00-3257 CIVIL TERM . . WHITNEY BLAIR MARIE PETTERSEN, : CIVIL ACTION - LAW Defendant : : CUSTODY ClIDER OF COORT AND NCW, this upon consideration of the attached ordered and directed as follows: ~ day of Custody ~~ Conciliati'sn , 2000, Report, it is 1. The Father, Jesse J. Lehman, and the Mother, Whitney Blair Marie Pettersen, shall have shared legal custody of Kadin Darius Lehman, born November 28, 1999. 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 healtrh~ education, and religion. 2. The parties shall have physical custody of the Child in accordance with the fOllowing schedule: A. The Mother shall have custody of the Child every week from 7:00 a.m. until 3:00 p.m. on Tuesday through Friday and from Saturday at 7:00 a.m. through Sunday at 7:00 p.m. B. The Father shall have custody of the Child at all other times not specified for the Mother. 3. The parties shall share or alternate having custody of the Child on holidays as follows: A. CIIRl:S'mAS: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon, and Segment B, which shall run from Christmas Day at 12:00 noon through December 26 at 12:00 noon. The Father shall have custody of the Child during Segment A in even numbered years and during segment B in odd numbered years. The Mother shall have custody of the Child during segment A in odd numbered years and during Segment B in even numbered years. B. EASTER: In every year, the Mother shall have custody of the Child on Easter until 12:00 noon and the Father shall have custody from 12:00 noon until the beginning of the Mother's next period of custody under the regular schedule. " ~ ,I . i. ok' . I C. MOTHER'S DAY/FATHER'S DAY: The Father shall have custody of the Child every year on Father's Day from 12:00 noon through the beginning of the Mother's next period of custody under the regular schedule. The Mother shall have custody of the Child on Mother's Day in accordance with the regular custody schedule. D. The holiday custody schedule shall supersede and take precedence over the regular schedule. 4. Each party shall be entitled to have custody of the Child for two weeks each summer (to be scheduled non-consecutively unless otherwise agreed) upon providing at least 60 days advance notice to the other party. 5. The party relinquishing custody shall be responsible to provide transportation for the exchange of custody unless otherwise agreed between the parties. 6. 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 llRltual consent. In the absence of llRltual consent, the terms of this Order shall control. J. cc: Thomas S. Diehl, Esquire - Counsel for Father Maryann Murphy, Esquire - Counsel for Mother C~ {lJaU 7-:;.3 -00 R){j ~~~~~ _,~ l'lI!ir:"--r"""".'~~' >$!\tlll'J'lffilll!,=_"" ;, <" ':~() , ';-'1 ')'~~i~( -':-'rK\ 'r ('J.__ ,r, 1./,--, ()~ ij,~? \<-- \,.-' ,\ -..) /~~~k(. //; , ""q;:,;(/..: ">j' \~/~- 0' l N. '// - ~:. ~ ~.p ,~ ",~~"""!"Il'lllmI~fR~_ ~~~'- ~" ....,r~_IIJIl.....".~~,~~ """'~-~~~,..._~w . ~ , .:J . JESSE J. LEHMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-3257 CIVIL TERM . . WHITNEY BLAIR MARIE PETTERSEN, : CIVIL ACTION - LAW Defendant : . CUSTODY . CUSTODY CCNCILIATICN SUMMARY REPCRr IN ACXXJIDANCE WITH CIJMBERLAND ~ RIJLE OF CIVIL PROCEIJUIRE 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 CURRFBl'LY IN CUSTODY OF Kadin Darius Lehman November 28, 1999 Mother/Father 2. A Conciliation Conference was held on July 19, 2000, with the following individuals in attendance: The Father, Jesse J. Lehman, with his counsel, Thomas S. Diehl, Esquire, and the Mother, Whitney Blair Marie Pettersen, with her counsel, Maryann Murphy, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date M t 1) :J-orW , ~~Ar Custody Conciliator