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Home My WebLink About97-01701 ~ I I I \I) ~ . ."':) ........ ~ ' , :; ~, I I I I I \ \ 'e', ....... ~i". .1 ~;,,~;~. ."""',.. '~;71~h:-" "''''if~.: JOSHUA 0, LOCK : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : CIVIL ACTION - LAW : CUSTODY/VISITATION : Q'l-17l>/ : NO. 96- CIVIL TERM JOANNE LOCK Defendant ORDER OF COURT AND NOW, Ar:,r \ l I.u..., 1997, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before .\'"'hrhC"1f> \ LJ~ClI\9c..". f.'II~' the conciliator, at '';(''(~ -\ , I ;>\' I~,-\t) ~ on the S th day of ~l...X' t' _ , 1997, at \ 0 o'clock. Q.....m., for a Pre-Hearing Cuslody 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 inlo a temporary order. All children age five or older may also be present atlhe conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: By:11lidJill f)(~ . f?n. in pP. I ~~ Cuslody Conciliator (1D) The Court of Common Pleas of Cumberland County is required by law to comply wilh 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 our office. All arrangements must be made alleast 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 LAWYER AT ONCE. II' YOU DO NOT HAVE A LAWYER OR CANNOT AI'FORD ONE, GO TO OR TELEPHONE THE OFI'ICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Office of the Court Adminislr:llor Cumberland County Court House. Fourth Floor Carlisle, PA 17013 (717) 240-62(]() NAME ADDRESS DATES Joanne Lock 37 Hillcrest Road 1/24/97 to Worleysburg, PA 17043 present Joanne Lock and 37 Hillcrest Road August 1993 to Joshua Lock Worleysburg, PA 17043 January 24, 1997 Joanne Lock and 35 Green Street Approx. 1982 to Joshua Lock Harrisburg, PA 17102 August 1993 The mother of the children is Joanne Lock, currently residing at 37 Hillcrest Road, Wonnleysburg, Pennsylvania, 17043, She is married. The father of Ihe children is Joshua Lock, currently residing at 2550 Waterford, Camp Hill, Pennsylvania, 17011. He is married. 4. The relationship of the Plaintiff to the children is that of father. The Plaintiff currently resides alone. 5, The relationship of the Defendant to the children is that of mother. The Defendant currently resides with the following persons: Rebecca Lynn Lock, Sarah Ann Lock, Anna Leah Lock and Martin Benjamin Lock, children. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 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. 7. The best interest and permanent welfare of the childrcn will be served by granting the relief requested for the following reasons: A, A Court Order of custody and structured visitation is desired so that the Plaintiff and the children may plan their schedules accordingly, and so that misunderstanding and unmet expectations regarding custody and visitation can be avoided, and also so that the children are not used in a manipulative fashion. B, Defendant has recently indicated her intention to move to Arizona with the children, Plaintiff challenges the good faith of such a move which would be very disruptive to the lives and educational programs for the children, C. Defendant has deprived Plaintiff of any opportunity to participate in major decisions affecting the best interest of the minor children, including religious and educational decisions. 8, Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action, WHEREFORE, Plaintiff requests the Court to grant shared legal custody of the children to Plaintiff and Defendant, and to grant partial custody of the children to Plaintiff if Defendant !I , remains with the children in their existing school district, and to grant custody of the children to Plaintiff if Defendant moves from the West Shore School District. Respectfully submitted, By: - a lor P. Andrews, Esq. A'lIorney for Plaintiff 78 West Pomfret Street Carlisle, PA 17013 Telephone: (717) 243-0123 Supreme Court ID No. 15641 i. COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) I verify that the statements made in the foregoing Complaint are true and correct. I understand that false stalemenls herein are made subject to the penalties of 18 Pa.C.S. ~4904. relating to unsworn falsification to authorities. DATE: 00 ~ ~!:- . -..0', ~ ' _.r,_' ,',_,-";',.,."_,,-.c-,-. \;;:'-H;/!,~._t~-:: ' ..;-,' = i2;~~,;!;'1.: ~~ f- ~~:~:: ../:,- i ;.~: ~.:I:<~~<{:\i; , - .:.:-,;,,.';', ;..,..... "ii,'~" ''t'm' 1..-...'. . . ~ d~;~~~~:~~:F~t~:'. ,:;i:: .,,'. -.,'-'-, ;, '-".- ;~;:'~c'~-:- .''; ..;'.:_....1'" .: , /~, . ~. ",'" ::::' " '., 1 8 ~' i .')f~~g,ilt~1tti~:~;f~~W~l;;~~t~~;/~ :;::~~:.,~: ~ II II ,.; 'U,;., ,.; t.... ...'... i..'c- .'...lflJ- . .lIl.tl,~ ..:r;, . I~.. I ~ Ii , I"'i 'f:i s Jr;. ;~/.!l ,IflPlt'lI! .oj ",' i \ . \ .1 ",' ,:':'\ " '. .:,-~' : ",:' -:.'~. ;/';~~:'~~fit~::~?:~.~,- ~JUN1. II ~gl..'<'^."'.";'i JOSHUA D. LOCK, IN THE COURT OF COOMON PLEAS OF CU~lBERLAND COUNTY, PENNSYLVANIA . . Plaintiff . . vs. : NO. 97-1701 CIVIL TERM JOANNE LOCK, CIVIL ACTION - LAW IN CUSTODY Defendant OODER OF OXJRT AND tDi, this ~ day of upon consideration of the attached Custody ordered and directed as follows: \ U\'Ul.- , Conciliation Report, 1997, it is 1. The Father, Joshua D. Lock, and the Mother, Joanne Lock, shall have shared legal custody of Sarah Anna Lock, born December 29, 1980, Anna Leah Lock, born March 2, 1982 and Martin Benjamin Lock, born July 25, 1984. 2. The Mother shall have primary physical custody of the Children. 3. Pending further Order of Court or agreement of the parties, the Father shall have reasonable periods of partial custody with the Children as arranged between the parties. 4. The parties shall submit the Children (including Rebecca Lynn Lock) and themselves to mediation/counseling to address problems which have arisen concerning custody and the Children's ongoing relationships with the parties. The mediation/counseling shall be performed by Jessica Bainbridge, PhD, unless the parties mutually agree otherwise. The Father shall be responsible for the costs of the mediation/counseling. 5. Neither party shall enroll the Children in formal religious training or change (or create) the Children's church membership. 6. Upon completion of the above-mentioned mediation/counseling and in the event the parties have not, at that time, been able to resolve the custody issues counsel for the parties may contact the Conciliator to arrange for the scheduling of another Custody Conciliation Conference. 7. 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 agreement. In the absence of mutual agreement, the terms of this Order shall control. BY THE COURT, J. cc: Taylor P. Andrews, Esquire - Counsel for Father Samuel L. Andes, Esquire - Counsel for Mother - ~....,~-'-IoI~a/9? ...&. -t! i ~ I i r- r I I I I ! I I I I I I i i \ II I ! I \ 1 I F'I\:O-I'\-;t:\rr. 1., \';,I.J.. ()~ ~. .- ..- ..., ... .:;ltJ,Y ,. ~,.. . -, " ' ." ." ". 01 J\J:! 20 i\:\ 8: 2! CU:/,'::. ,.,;..,.',:- .,Uj\r'r \,:.""".,.,.".,. \...,. ..;ll.'..... " JOSHUA D. LOCK, : IN THE COURT OE' COMMON PLEAS OE' Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : VS. : NO. 97-1701 CIVIL TERM . . JOANNE LOCK, : CIVIL ACTION - LAW Defendant . IN CUSTODY . CllS'roDY COOCILIATIOO SlH1ARY REPOOT IN AcxnulANCE wrm <DIBERLAND CXXNl'Y RULE OF CIVIL PROCEOORE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CllRREN.rLY IN CUS'lOOY OF Rebecca Lynn Lock Sarah Anna Lock Anna Leah Lock Martin Benjamin Lock April December March July 2, 1979 29, 1980 2, 1982 25, 1984 Defendant/Mother Defendant/Mother Defendant/Mother Defendant/Mother 2. A Conciliation Conference was held on June 12, 1997, with the following individuals in attendance: The Father, Joshua D. Lock, with his counsel, Taylor P. Andrews, Esquire, and the Mother, Joanne Lock, with her counsel, Samuel L. Andes, Esquire. 3. 'l11e parties agreed to entry of an Order in the form as attached. JtJ;yJ . Date n {'177 , I)~i.~~tle Dawn S. Sunday, Esqui e Custody Conciliator