HomeMy WebLinkAbout97-04055
~
i
~
~
~
q
(
1
-....J.
/
='
.
. ';a
~
~
<::)
~
~
<:)-
~
shall deliver the child to school or, if school is not in session,
to the appropriate day care provider.
C. On the Thursdays following his weekend visitation,
from after school until Friday morning at which time he shall
deliver the child to school or, if school is not in session, the
appropriate day care provider,
D. During the summer months, Father shall have the
child for the second and third week of June; the second and
third week of July; and the second and third week of August.
Mother shall have the child during the other weeks of the
summer.
3. The parties shall alternate the major holidays, those holidays
being defined as Thanksgiving, New Year's Day, Easter. Memorial Day.
snd Labor Day. These periods of partial custody shall occur from 9:00
a.m. until 7:00 p.m. This alternating schedule shall begin with
Mother having Thanksgiving in 1997.
4. The Christmas holiday shall be split into two segments.
Segment A shall be from Christmas Eve day at 9:00 a.m. until
Christmas Day at 9:00 a,m.; Segment B shall be from Christmas Day
at 9:00 a.m. until December 26th at 9:00 a,m. Father shall have
Segmsnt A in 1997 and all odd-numbered years thereafter and
CRISTI A, LEHMAN,
: IN TilE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v,
: CIVIL ACTION - LAW
: NO, 91- -<t(,~S$ (:~v,'llfl2l'\
ARTHUR G, MEADATH,
Defendant
: IN CUSTODY
COMPLAINT FOR ClISTODY
I. The Plaintiff is Cristi A. Lehman, residing at 118 Abolition Street, #2, West
Fairview, Cumberland County, Pennsylvania,
2, The Defendant is Arthur G. Meadath, residing at 430 Second Street, West
Fairview, Cumberland County, Pennsylvania,
3, Plaintiff seeks custody of the following child:
~
Present Residence
DOB
Brian Wade Meadath
118 Abolition Street, #2
West Fairview, PA 17025
12119/90
The child was born out of wedlock,
The child is presently in the custody ofCristi A, Lehman. who resides at 118
Abolition Street,II2, West Fair.iew, Cumberland County, Pennsylvania,
During the past live years, the child has resided with the following persons and at
the following addresses:
Persons
Address
UJ1g
Cristi A Lehman
Randallsto\\n, MD
1993-94
CriStl A. Lehman
Ashlc) SImms
6376 Snuthy Square
Glen Bumie, MI>
1994-95
'"
>- \J') ;-
'i' " ~,;
'~ N "
I.U
c}r
p.: .. . -
ij
, ,"'l
r.:, C'.:
.
.' e "
~, ,
~'..
:- 'j
( , l1' .c)
7. Father learned that the ehild earned failing grades for 71h grade during the 2003-2004
school year.
8. The child also displayed behavioral problems that concerned Father.
9. Father took the child to a psychologist. Edward Batista, Ph.D, whereupon Father
learned that the child is fearful of Mother and displays a rebellious attitude as a result
ofthaL
10. Father believes that Mother suffers from anger management issues and has physically
punished the child without cause,
II. Father is concerned for the child's safety and well-being while in his Mother's
custody.
12, The child has expressed a strong desire to reside primarily with his Father.
13. Father currently resides with his wife. Beth Meadath. and their two minor children,
and has appropriate accommodations to allow for the child to reside primarily with
Father.
14. Father currently is enrolled in Harrisburg Area Community College to study nuclear
medicine technology and attends class on Monday. Wednesday and Friday until 2:00
p.m. and on Tuesday and Thurday until 11:00 a.m.
IS. Mother cum:ntly resides with her husband. Gene Kreiger. and his son on alternating
weekends.
16. Mother cum:ntly is employed at Advantix Marketing, working Monday through
Friday from 7:00 a.m, to 4:30 p.m.
17. Father is available to care for the child on a daily basis.
shall deliver the child to school or, if school is not in session,
to the appropriate day care provider.
C. On the Thursdays following his weekend visitation,
from after school until Friday morning at which time he shall
deliver the child to school or, if school is not in session. the
appropriate day care provider,
D. During the summer months, Father shall have the
child for the second and third week of June; the second and
third week of July; and the second and third week of August,
Mother shall have the child during the other weeks of the
summer,
3. The parties shall alternate the major holidays, those holidays
being defined as Thanksgiving, New Year's Day, Easter, Memorial Day,
and Labor Day. These periods of partial custody shall occur from 9:00
a.m, until 7:00 p.m. This alternating schedule shall begin with
Mother having Thanksgiving in 1997.
4. The Christmas holiday shall be split into two segments.
Segment A shall be from Christmas Eve day at 9:00 a.m. until
Christmas Day at 9:00 a.m.; Segment B shall be from Christmas Day
at 9:00 a,m. until December 26th at 9:00 a.m. Father shall have
Segment A in 1997 and all odd-numbered years thereafter and