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HomeMy WebLinkAbout01-5753Michael S. Travis ID No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 AMY W. LANE, Plaintiff, VS. MICHAEL C. LANE, JR., Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 200 -0r? 3 IN CUSTODY COMPLAINT FOR CUSTODY TO THE HONORABLE JUDGES OF SAID COURT: 1. The Plaintiff is Amy W. Lane residing at 2190 Brunswick Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is Michael C. Lane, Jr. residing at 473 Walnut Street # 314, Dauphin County, Harrisburg, Pennsylvania 17101. 3. Plaintiff seeks shared legal custody and primary custody subject to the father's liberal periods of visitation of the following child: NAME PRESENT RESIDENCE DOB Dylan Michael Lane 2190 Brunswick Ave. 5/3/99 Mechanicsburg, PA 17055 The child was not bom out of wedlock. The child is presently in the custody of Amy W. Lane who resides at 2190 Brunswick Avenue, Mechanicsburg, PA 17055. The child has resided with the following persons and at the following addresses for the last five years: Persons Amy and Michael Lane Amy and Michael Lane Amy W. Lane Addresses 2190 Brunswick Avenue Mechanicsburg, PA 17055 2190 Brunswick Avenue Mechanicsburg, PA 17055 Dates Birth - 8/00 8/00 - 6/01 6/01 - date The mother of the child is Amy W. Lane, currently residing at 2190 Brunswick Avenue, Mechanicsburg, PA 17055. She is married to the father. The father of the child is Michael C. Lane, Jr., currently residing at 473 Walnut Street # 314, Harrisburg, PA 17101. He is married to the mother. 4. The relationship of plaintiff to the child is that of mother. The plaintiff currently resides with the child only. 5. The relationship of the defendant to the child is that of father. The defendant currently resides alone. 6. Neither party has participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 7. Plaintiff does not know of a person not a party to the proceedings who has of the child or claims to have custody or visitation rights with respect to the child. 8. The best interest and permanent welfare of the child will be served by granting the relief requested because: A. Plaintiff has participated in the primary care of the child throughout his life. B. Plaintiff can provide a stable environment. C. Plaintiff can provide a loving home. 9. Each parem whose parental rights to the child has not been terminated and the person who has physical custody oftbe child has been named as parties to this action. 10. The parties hereto have reached agreement with respect to custody. A copy of the parties Custody Stipulation and Agreement is attached hereto as Exhibit A. 11. The parties request that the Stipulation and Agreement be entered as an Order of Court. WHEREFORE, Plaintiff requests this Honorable Court to grant her shared legal custody and primary physical custody of the child subject to the father's periods of liberal visitation according to the custody stipulation attached hereto. bmitted, ~P~t~tiff Supreme court ID No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 Michael S. Travis ID No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 AMY W. LANE, Plaintiff, VS. VIICHAEL C. LANE, J1L, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. IN CUSTODY CUSTODY STIPULATION AND AGREEMENT AND NOW, come the parties hereto, Plaintiff, Amy W. Lane, ("Mother") and Defendant, Michael C. Lane, Jr., ("Father") as said parties have reached mutual agreement as to the custody of their child Dylan Michael Lane, bom May 3, 1999, and hereby stipulate to the following custody agreement, and hereby request the Court to enter the same as an Order of Court: 1. Mother and Father shall share legal custody of said child, as to all matters regarding the child's health, education, and welfare. 2. Mother shall have primary physical custody of said child, as Mother is relocating to the state of New Jersey, and the Father's visitation schedule shall be as follows: Father shall have physical custody of the child on alternating weekends from Friday at 7:00PM through 7:00PM Sunday beginning on 8eptemloer 28, ,2001. Father shall provide transportation to and from Mother's address, or otherwise agree to a mid-way exchange of said child. If there is no agreement, then Father shall provide transportation to and from the Mother's residence. The non-custodial parent shall have liberal telephone contact with the child. 3. Holidays. Mother shall have the Child on Memorial Day and Labor Day from 7 P.M. on the evening preceding the huliday until 7 P.M. on the day of the holiday. Father shall have the Child on July 4tn as outlined above. Exhibit A Easter. Mother will have the Child commencing on Good Friday at 8 P.M. until 5 P.M. Easter Sunday, beginning with the year 2002. Thanksgiving. The Child will be with Father from 7 P.M. on the evening preceding the holiday until 7 P.M. on the evening of Sunday. The above holidays will be alternated on a yearly basis unless both parties agree to abide by the original schedule. The holiday schedule supercedes the weekend schedule. Father's Day. Father shall have the Child on Father's Day from 11 A.M. to 7 P.M. Mother's Day. Mother shall have the Child on Mother's Day from 11 A.M. to 7 P.M. Christmas. The weekend prior to Christmas shall be with Father. Mother shall have the Child on Christmas Day. 4. Father shall have two non-consecutive weeks of uninterrupted visitation per year, after having given at least thirty (30) days notice to Mother. 5. If either parent is unable to keep their scheduled times of visitation they shall )rovide at least twenty-four (24) hours notice. 6. The parties shall have the right to modify any provision of the custody schedule hereto upon mutual agreement by both parties. In the event a proposed modification is not agreed to, the schedule as stated shall be complied with by the parties. The parties reserve the right to modify this Stipulation and Agreement through the court pursuant to Pennsylvania Law, ~s Cumberland County, Pennsylvania, shall retain jurisdiction. Amy W.~ane, Pl~qntiff Lane, Jr., VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. ~0~ ~.LIn$ tJ,.33U.L$ J.'a)ll:tV~l g/-OP $1A¥~.L 'S OI~T ~zool AMY W. LANE, Plaintiff, VS. MICHAEL C. LANE, JR., Defendant· : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : IN CUSTODY ORDER OF COURT A~ONow, this 'b~' dayof O~ ,2001, it is hereby O~OE~D and DECREED that the attached Custody Stipulation is entered as an Order of this Court. BY THE COURT: