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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MA'l"I'HBW BOOKER, JR., I CIVIL ACTION - LAW
Plaintiff I
I
v, I NO. 97-4udvl CIVIL TBRM
I
LORI L, LISK, I
Defendant I CIVIL ACTION - CUSTODY
AND NON, <h1. ~ d.y of
conBideration of Plaintiff'e petition
, 1997, upon
r Emergency Relief, .,
he~~'-J lw Q~n~uv~5~ rv~
, 1997_ at
..,.. r---4* G.-...UQQII Ko._
, C~'mhlilrlAnd
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Courthnna.o. .carl.:LalQ,,-~nn~_
~ ~"../). BY THE CDDRT,
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY/ PENNSYLVANIA
MATTHBW BOOKSR/ JR./ I CIVIL ACTION - LAW
Plaintiff I
I
V. I NO. 97- CIVIL TERM
I
LORI L. LISK/ I
Defendant I CIVIL ACTION - CUSTODY
AND NOW/ this
OiliaR OP COUR'~
day of
, 1997, upon
the Petition for Emergency Relief, the Plaintiff, Matthew Booker,
Jr" is awarded sole physical custody pending issuance of the
Order of Court or Conciliation Conference.
By the Court,
J.
c:,~~...........,
IN THB COURT OF COMMON PLBAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MATTHEW BOOKBR, JR"
Plaintiff
CIVIL ACTION - LAW
v,
NO, 97- '/f., jl.,.CIVIL TERM
LORI L, LISK,
Defendant
CIVIL ACTION - CUSTODY
PBTITION FOR BMERGBNCY RBLIBF
AND NOW, this 27th day of August, 1997, comes the Plaintiff,
Matthew Booker, Jr., by and through his attorneys/ Hanft & Vohs,
and files this Petition for Emergency Relief as follows I
1. The parties are the natural parents of the minor child,
Kari Laughman, born December 9, 1995,
2. Plaintiff, Matthew Booker, Jr., through his counsel
filed for primary custody on this date.
3, On July 31, 1997, Cumberland County Children & Youth
Services received a referral from TresLlla Boyd, Children's
Services, Brooklyn, New York, regarding the minor child, age 1 i.
Ms. Boyd reported that her agency currently had said child in a
foster home and the child's mother, Lori Lisk's, whereabouts were
unknown.
4. Ms. Boyd reported that the child was allegedly brought
to the 75th Precinct Police Department in Brooklyn, New York, by
a friend of the mother's, "Bobbie Jo".
5. "Bobbie Jo" allegedly reported that she and the child's
mother had "hitched' a ride with a truck driver from Carlisle to
New York City. "Bobbie Jo' allegedly reported that Lori Lisk
C,~nlO'NllO&D-""""'U"T
New York City. .Bobbie Jo. allegedly reported that Lori Lisk
left New York City with the truck driver and .Bobbie Jo. was
caring for the child.
6, On or about July 29 - July 30, 1997, .Bobbie Jo.
repor.ted to the New Yor.k City Police that she was no longer able
to care for the child and requested that the child be removed
from her physical custody.
7, On July 31, 1997, Tresilla Boyd, Children's Services,
Brooklyn, New York, contacted this Agency and requested that
Cumberland County Children & Youth take custody of the child
since the child's mother resides in Cumberland County.
B. On July 31, 1997, Ms. Boyd reported that he agency had
contacted the maternal grandmother, but the maternal grandmother
declined to assume responsibility for the child,
9. In March of 1997, Cumberland County Children & Youth
Services was notified that Lori Lisk permitted Bobbi Jo
Hutchison-McClure to take her daughter, Kari Laughman, to New
York City.
10, On March 19, 1997, Cumberland County Children & Youth
Services informed Lori Lisk that Bobbi Jo Hutchison-McClure had a
criminal conviction for endangering the welfare of children.
11, On March 19, 1997, Lori Lisk reported that she would
not allow Bobbi Jo Hutchison-McClure to take her daughter to New
York City in the future or allow Bobbi Jo Hutchison-McClure to
care for her daughter overnight or for long periods of time.
12, As of August 6, 1997, Lori Lisk has not yet contacted
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MATTHEW BOOKER, JR, I
plaintiff I
I CIVIL ACTION - LAW
v. I IN CUSTODY
I
LORI LISK, I NO, 97-
Defendant I
CBRTIFICATB OF SBRVICB
AND NOW, this 27th day of August, 1997, I, William C, voh8,
E8quire, hereby certify that I have this day served the following
per80n with a copy of the foregoing document, by depositing same
in the United Statos Mail, Fir.st Class, postage Prepaid,
addressed as follows I
Joan E, Carey, Esquire
LEGAL SERVICES
8 Irvine Row
Carlisle, PA 17013
~~
W li_ C \'t...".
Attorney 10 No, 65208
11 West Pomfret Street, Suite 2
Carlisle, PA 17013
(717) 249-5373
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IN THE COURT OF COMMON PLEAS OF
CUMBBRLAND COUNTY, PENNSYLVANIA
MATTHBW BOOJ<BR, JR, I
Plaintiff I
I CIVIL ACTION - LAW
v. I IN CUSTODY
I
LORI LISK, I NO , 97- %1lc C\,...J:' 1 \li\l'1
Defendant I
ORDBR OF COURT
AND NOW, this ~'5 day of'W( '\('(1 ,ber- , 1996,
upon consideration of the attached Complaint, it is hereby
directed that the parties and their respective counsel shall
appear before HIe hClc." \ l ' 1."1..\ "J. \, r ,(\, , the Conciliator,
at') " .. \" , .J ~,,"\ , ~ t . - -)(~ on
the \ (0 day of \ ,\ \' ,\" . ( , 199 at:..1LW ).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 accompliahed, to deUne 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 THE COURT,
BYI_JIl.v:::(\() ...'J ,J.P"njn~~.
Custody Conciliator I ' 1 .)
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 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 SHO~LD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THB
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, 4TH FLOOR
CARLISLE, PA 17013
(717) 240-6200
(',~~NIl.VI1UOYCOW
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MATTHEW BOOKER, JR, ,
Plaintiff I
, CIVIL ACTION - LAW
v. , IN CUSTODY
,
LORI LISK, , NO, 97- 4t!l3lv C'u,vJ) TlU1,1)
Defendant ,
COMPLAINT FOR PRIMARY CUSTODY
AND NOW, this 27th day of August, 1997, comes plaintiff,
Matthew Booker, Jr., by and through his attorneys, HANFT' VORS,
and files the following Complaint for Primary Custody and in
support thereof avers as followt!l'
1. The Plaintiff is Matthew Booker, Jr., all adult
individual residing at 176 Moore Street, Wellford, South Carolina
29385,
2. The Defendant is Lori Lisk, 89 B Street, Apartment B,
Carlisle, Cumberland County, Pennsylvania 17013.
3. The Plaintiff seeks primary custody of the followinq
child,
lillm.!l
Present Residence
AWl
1 i years
Kari Laughman
89 B Street, Apt. B
Carlisle, PA 17013
Date Of Birth of Child, December 9, 1995
The child was born out of wedlock.
The child is presently in the custody of Cumberland County
Children' Youth Services.
C,~WllXJUI.lIoCW1'OOY.COM
The mother of the child is the Defendant, who last resided
at 89 B Street, Apartment B, Carlisle, Cumberland County,
Pennsylvania 17013. She is not married,
The father of the child is Plaintiff, who resides at 176
Moore Street, Wellford, South Carolina 29385. He is not married.
4. The relationshi~ of Plaintiff to the child is that of
father. The Plaintiff currently resides with his parents,
5. The relationship of Defendant to the child is that of
mother. The Defendant currently resides at an unknown looation.
6. Plaintiff has not partioipated as a party or witness, or
in any other oapacity, in other litigation ooncerning the oustody
of the child in this or another court.
The Plaintiff has no information of a custody proceeding
concerning the custody of the child in this or any other court.
The Plaintiff does not know of a person not a party to the
prooeedings who has physical custody of the child or claims to
have custody or visitation rights with respect to the child.
7. The best interests and permanent welfare of the child
will be served best by granting the relief requested because.
a) The Plaintiff is the natural father of the minor child,
b) The Plaintiff is ready, willing, and able to provide the
child with a home with adequate moral, emotional and physical
surroundings as required to meet the child's needs;
c) The Plaintiff is, and has always been, willing to accept
custody of the child;
C,~.1DiI
2
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MATTHEW BOOKER, JR, I
Plaintiff I
I CIVIL ACTION - LAW
v, I IN CUSTODY
I
LORI LISK, I NO, 97-
Defendant I
CBRTIPICATB OP SBRVICB
AND NOW, this 27th day of August, 1997, I, William C, Vohs,
Esquire, hereby certify that I have this day served the following
person with a copy of the foregoing document, by depositing Bame
in the United StateB Mail, First Class, Postage Prepaid,
addressed as follows I
Joan E. Carey, Esquire
LEGAL SERVICES
B Irvine Row
Carlisle, PA 17013
HANFT & VOHS
~v~.qui~
Attorney 10 No. 65208
11 West Pomfret Street, Suite 2
Carlisle, PA 17013
(717) 249-5373
~'COM
, 6
v,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 97.4636 CIVIL TERM
MATTHEW BOOKER, JR"
Plaintiff
Defendant
CIVIL ACTION-LAW
IN CUSTODY
LORI L1SK,
~ RD
AND NOW, this ~ day of
.
, 1997, the attached Stipulation
and Agreement Is hereby made an Order of Court and all prior Orders on this matter .
are hereby vacated,
BY THE COURT,
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as the parties may from time to time agree,
4, The parties will keep each other advised Immediately relative to any
emergencies concerning the child and shall further take any necessary steps to Insure
that lhe health and well being of the child Is protected,
5, Neither parent shall do anything which may estrange the child from the
other party, or injury the opinion of the child as to the other party or which may hamper
the free and development of the child's love or affection for lhe olher party,
6, Any modification or waiver of lha provisions of this Agreement shall be
effective only if made in writing and only If executed with the sar.1e formality as this
Stipulation and Agreement.
7, The parties desire lhat this Stipulation and Agreement be made an Order
of Court to the Court of Common Pleas of Cumberland County,
8, The parties agree thaI in making this Agreement, there has been no
fraud, concealment, overreaching, coercion or other unfair dealing on the part of the
other,
9, The parties acknowledge that lhey have read and undersland the
provisions of this Agreement.
10, Each party acknowledges lhat the Agreement Is fair and equitable and
that it is not the result of any duress or undue influence,
IN WITNESS WHEREOF, the parties hereto Intending to be legally bound by the
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as the parties may from time to time agree,
4. The parties will keep each other advised Immediately relative to any
emergencies concerning the child and shall further take any necesssry steps to Insure
that the health and well being of the child Is protected,
5. Neither parent shall do anything which may estrange the child from the
other party I or Injury the opinion of the child as to the other party or which may hamper
the free and development of the child's love or affection for the other party,
6, Any modification or waiver of the provisions of this Agreement shall be
effective only If made In writing and only If executed with the same formality as this
Stipulation and Agreement.
7, The parties desire that this Stipulation and Agreement be made an Order
of Court to the Court of Common Pleas of Cumberland County.
6, The parties agree that In making this Agreement, there has been no
fraud, concealment, overreachlng, coercion or other unfair dealing on the part of the
other,
9, The parties acknowledge that they have read and understand the
provisions of this Agreement.
10. Each party acknowledges that the Agreement is fair and equitable and
that It Is not the result of any duress or undue influence,
IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the
The above-named plaintiff, Lori Lisk, verifies that the
statements made in the above Petition arc true Rnd correct, The
plaintiff understands that fulse statcments herein arc made subject to
the penalties of 18 Pa. C,S, g 4904, relntlnK to unsworn falsification
to authorities,
Date: 8'(2-4~
(Arnll~Jt-
Loti Llsk, Plaintiff
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In the parties entering a stipulation lor ~ustody dated October 20, 1997. Father indl~ated that he
obtained custody because Mother had IIBegedly abandoned the child with some care giver in
Ncw York. FlIthcr indicatcd that hc arrangcd lor the child to be brought here in Scptcmber.
1998, hut did not suggestthut it WIlS 10 be u permanent arrangement. He suys that the Mother hus
refused to return the child to him despite the previous Order entered in this case indicating that
he has primary custody. Father in the meantime has moved Irom South Carolina to Nevada.
6. The Defendant's position on custody is as lollows: An Order was entered in August,
1997, following a dependency hearing at which Mother was not present whereby Father was
given custody of the child. A stipulation was entered into by the parties on Octobcr 20.1997,
whereby Father had primary custody of the child subject to periods of custody with Mother as
agreed upon. Mother indicated that from August. 1997. to September. 1998. she saw thc child
only one time lor a period of two weeks. She indicates that she repeatedly tried to contact Father
but that Father would not provide her with any additional time. Ultimately in September. she
suggested that the parents of the Father brought the child to her because she alleges that the
Father was not actually taking care of the child and she has had the child ever since. She wants
primary physical custody of the child. She has raised several issues regarding the fitness of the
Father.
7. Need lilr separate counsel to represent child(ren): Neither party requested.
8. Need for independent psychological evaluation or counseling: None requested and the
Conciliator does not believe any is necessary.
9. A hearing in this mailer will take one duy.
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father providing for and paying the cost of the
transportation for this period of custody.
d. Other times agreed upon in writing by the parties,
4. The mother and father, by mutual agreement, may vary
from this schedule at Any time, but the Order shall remain in
effect until further order of court.
5. Transportation for the periods of custody in paragraph
3(a) and 3(~) ~bovc chul: he cfE~c~uated B~:t ~haL th. father
shall be responsible for 75\ of the transportation, be it the
cost for providing some type of mass-transit or actual driving,
and the mother shall be responsible for 25\ of the transportation
be it the cost for providing mass-transit or actual driving, The
father shall contact the mother at least sixty days prior to his
period of custody and arrange the manner of transportation, The
parties shall contact the mother at least one week prior to the
transfer date to insure that the specific transfer arrangements
are made as to the place and time for the transfer that is in
accordance with the terms of this Order.
6, The mother and father shall keep each other informed as
to that parent's current address and phone number.
7, The mother and father shall allow liberal telephone
contact with the child and the non-custodial parent, If either
parent takes the child away from the home for an extended period
(a period including two or more overnights), that parent shall
not j fy the oth'~r parer:t r:,f ': he o?ddreAs and telepho1'\E' n1lmber where
the child can be reached.
8, The mother and father agree that each shall notify the
other immediately of medical emergencies which arise while the
child is in that parent's care.
9. Neither party shall do anything which may estrange the
child from the other parent, injure the opinion of the child as
to the other parent, or which may hllmper the free and