HomeMy WebLinkAbout98-02505
.....
~
.~
~
",
.....
~
~
l
\. 1\'
(~
,
:--.....
...
.~
...
"-J
j;
~
<:::)
\r)
<"'(
I
~
~
~
Nioholas R. Lori
Sara E. Lori
Christopher J. Lori
Son
Daughter
Son
6
Plaintiff has not participated as a party or witness, or in another
capaci ty, in other Ii tigation concerning the custody of the child
in this or in another Court.
7
Plaintiff has no information of a custody proceeding concerning the
child pending in a court of this Commonwealth.
8
Plaintiff does not know of a person not a party to the proceedings
who has physical custody of the child or claims to have custody or
visitation rights with respect to the child.
9
The best interest and permanent welfare of the children would be
served by granting primary physical custody of the children to
Plail1tiff because she has been the primary caretaker of the
children and she desires to keep the children intact, as a family
unit, whereas Defendant desires to separate the children, with
~'>- 1,[1
~~ ,
c; C
G I'
lUC' l.~ "
C;,./
p.V ,\i'~ , .
,..,
~Ii'~ c..
I;
p,.
u:..-
[L~ l. , .
r! ,._m
.( '.
I.J. ~.; ,-\.
0 fC' .~)
0' (.:1
t
~ ~ ~'~
~~~() ~~
()~~C:;~
~ ~ ~ ~.~
/~ ,JUN ] 5 1998
MARGARET S. LORI, I IN THE COURT OF CCJMMCX.l PLEAS OF
Plaintiff . CUMBERLAND COON'l'Y, PENNSYLVANIA
.
I
vs. . NO. 98-2505 CIVIL TERM
.
:
CARL D. LORI, : CIVIL AL~lON - LAW
Defendant : IN CUS'l'ODY
auJBR a.> ~
AND Naol, this 4th day of June, 1998, the Conciliator, upon the
request of Plaintiff'e to discontinue this custody action and cancel the
CUstody Conciliation Conference scheduled for June 10, 1998, hereby
relinquishes jurisdiction in this case.
FOR THE COURT,
l;!.a-d:f.;,cf'IJ
Custody Conciliator
IWtGARIT 8. LORI, I IN THE COURT OW COMMON PLIAS OW
Plaintiff I CUMBERLAND COUNTY, PINN8YLVANIA
I
VI. I NO. t8~2505 CIVIL TERM
I
CARL D. LORI, I CIVIL ACTION - LAW
D.ferAd.nt I CUSTODY
AND NOW this
CUSTODY QBQIB
\~
\
of the parties' Consent Agreement,
'2-'(;
day of
, 1998, upon
oonsideration
the following
Custody Order is entered with regard to custody of the parties'
children, David M. Lori, Nioholas R. Lori, Sara L. Lori, and
Christopher J. Lori:
1. The plaintiff, hereinafter referred to as the "Mother" / and
the defendant, hereinafter referred to as the "Father", shall share
legal oustody of the ohildron.
2. Mother shall have primary physical oustody of Sara E. Lori
and Christopher J. Lori.
3. Father shall have primary physioal custody of David M. Lori
and Nioholas R. Lor!.
4. Mother shall have partial oustody of David M. Lori and
NichOlas R. Lori on the following schedule:
(a) Alternating weekends from Friday at 4: 00 p. m. through
Sunday at 7:00 p.m.;
(b) Every other Tuesday evening from 4:00 p.m. until 8:30
p.m., with the Tuesday periods of partial oustody to
be on the Tuesday prior to the weekend that, Mother
exercises her periods of partial custody, as filet forth
in subparagraph (a), above.
(0) Every other Thursday evening from 4:00 p.m. until 8:30
p.m., with the ~hursday period of partial custody to
be on the Thursday fOllowing Mothor's period of
partia 1 custody, as set fort.h in subparagraph (a),
above.
(d) Mother shall have partial custody of the minor
children, as aforesaid, in even-numbered years on the
following holidays:
L Memorial Day - 10:00 a.ln. through 7:00 p.m.,
except. if the holiday follows the weekend of
Mother's period of partial custody, as set forth
in Paragraph 4 (a), above, then in that event,
Mother may keep the minor children for the
entire weekend until 7:00 p.m. of the evening of
the holiday.
ii. Fourth of July - 10:00 a.m. through 7:00 p.m.
iii. Thanksgiving - 10:00 a.m. through 9:00 p.m.
iv. Christmas - Christmas Eve from Noon to 9:00 p.m.,
and on December 26 from Noon until 9:00 p.m.
(e) Mother shall have partial custody of the minor
children on odd-numbered years on the odd-numbered
years on the following holidays:
i. Labor Day - 10:00 a.m. through 7:00 p.m., except
if the hoHday follows the weekend of Mother's
period of partial custody as set forth in
paragraph 4(a), above, then and in that event,
Mother may keep the minor children for the
entire weekend until 7:00 p.m. of the evening of
the holictay.
ii. Christmas 9:00 p.m. on Christmas Eve
through Noon on Deoember 26.
Hi. New Year's 6:00 p.m. on New Year's Eve
through 8:00 p.m. on New Year's Day.
iv. Easter - 11:00 a.m. through 9:00 pm.
(f) Mother shall have partial custody of t.he minor
children, as aforesaid, for two (2) weeks in the
summer, to be oonsecutive or non-consecutive, with 30
days advanoe notice to Father as to the weeks in which
she wishes to exercise her custody rights pursuant to
this subparagraph.
5. Father shall have partial custody of Sara E. Lori and
Christ~pher J. Lori on the following schedule:
(a) Alternat.ing weekends from Friday at 4:00 p.m. through
Sunday at 7:00 p.m.;
(b) EV4;lry other Tuesday evening from 4:00 p.m. until 8:30
p.m., with the Tuesday periods of partial custody to
be on t.he Tuesday prior to the weekend that Father
exercises his per iods of partial custody, as set forth
in subparagraph (a), above.
(0) Every other Thursday evening from 4:00 p.m. until 8:30
p.m., with the Thursday period of partial custody to
be on the Thursday following Father's period of
partial custgldy, as set forth in subparagraph (a),
above.
(d) Father shall have partial oustody of the minor
ohildren, as aforesaid, in even-numbered years on the
following holidays:
i. Labor Day - 10:00 a.m. through 7:00 p.m., exoept
if the holiday follows -r.he weekend of Father's
period of partial custody as set forth in
paragraph 5(a), above, then and in that event,
Father may keep the minor children for the
entire weekend until 7:00 p.m. of the evening of
the holiday.
i1. Christmas 9:00 p.m. on Christmas Eve
through Noon on December 26.
iii. New Year's - 6:00 p.m. on New Year's Eve
through 8:00 p.m. on New Year's Day.
iv. Easter - 11:00 a.m. through 9:00 pm.
(e) Father shall have partial oustody of the minor
ohildren on odd-numbered years of the following
ho1i.days:
1. Memorial Day - 10:00 a.m. through 7:00 p.m.,
except if the holiday follows the weekend of
Father's period of partial custody, as set forth
in paragraph 5(a), above, then in that event,
Father may keep the minor children for the
entire weekend until 7:00 p.m. of the evening of
the holiday.
ii. Fourth of July - 10:00 a.m. through 7:00 p.m.
iii. Thanksgiving - 10:00 a.m. through 9:00 p.m.
iv. Christmas - Christmas Eve from Noon to 9:00 p.m.,
and on December 26 from Noon until 9100 p.m.
(f) Father shall have partial custody of the minor
oh!1dren, as aforesaid, for two (2) weeks in the
summer, to be oonsecutive or non-consecutive, with 30
days advance not.ice to Mother as to the weeks in which
he wishes to exercise his cust.ody rights pursuant to
this subparagraph.
6. with respeot to the exercising of partial custody during
the summer months for the weeks in which partial custody i.s requested
by either parent, that parent shall have custody of all four
children. The period of partial cllstody exe.rcised by either parent
during the summer months shall take precedence over any other period
of parti.al custody afforded to the other paren herein.
7. During those periods of oustody designated herein as
partial custody periods and/or holidays, the party having custody
shall have custody of all of the minor children.
8. The holiday custody schedule as designated herein shall
take precedence over the regular custody schedule.
9. The parties realize that their children's well being is
paramount to any differences they might have .between themselves.
Therefore, they agree that neither party will do anything that may
estrange the children from the other parent, injure the opinion of
the children as to the other parent, or which may hamper the free and
natural development of the children's love or respect for the other
parent.
u.;. ~
~'i
IS'
~
.C"
r',"
1
~'
Fi
~
Hi!
B;I&~
~ f'
t::.
, e ~ ~~ ~
~ ~ f ~
I ~.: f'
..I 11l t::.
";
. .
'1
~ ,
,.
JUI 9.4 ~\
.' "
IQRGARIlT 8. LORI, I IN THIl COURT OF COMMON PLEA8 or
plaintiff I CUMBBRL~D COU8TY, PIlNNSYLVANXA
I
v.. I NO. 98-2505 CIVIL TERM
I
CARL D. LORI, I CIVIL ACTION - LAW
Detendant I CUSTODY
CONSIlNT AGREIlMBNT
This Agreement is entered on this q/l~__ day of .J U I'-'L-
1998 by the plaintiff, Margaret S. Lori, (hereinafter referred to as
the "Mother"), and the defendant, Carl D. Lori, (hereinafter referred
to as the "Father").
Mother is represented by Christopher C.
Houston, Esquire and Father is represented by I,inda A. Clotfelter,
Esquire. The parties agree to the entry of the following custody
order regarding their children, David M. Lori, d.o.b. 10/17/84,
Nicholas R. Lori, d.o.b. 8/8/86, Sara E. Lori, d.o.b. 9/20/88, and
Christopher J. Lori, d.o.b. 5/24/93:
1. Mother and Father shall share legal custody of the
children.
2. Mother shall have primary physical custody of Sara E. Lori
and Christopher J. Lori.
3. Father shall have primary physical custody of David M. Lori
and Nicholas R. Lori.
4. Mother shall have partial custody of David M. Lori and
Nicholas R. Lori on the following schedule:
(a) Alternating weekends from Friday at 4:00 p.m. through
Sunday at 7:00 p.m.;
(b) Every other Tuesday evening from 4:00 p.m. until 8:30
p.m., with the Tuesday periods of partial custody to
'. ~,
be on the 'l'ueoday prior to the weekend that Mother
exercises her perIods of partIal oustody, as set forth
in subp&ragraph (a), above.
(c) Every other Thursday evening from 4:00 p.m. until 8:30
p.m., with the Thursday period of partial oustody to
be on the Thursday following 110ther' s period of
partial custody, as set. forth in subparagraph (a),
above.
(d) Mother shall have partial custody of the minor
children, as aforesaid, in even-numbered years on the
following holidays:
i. Memorial Day - 10:00 a.m. through 7:00 p.m.,
except if the holiday follows the weekend of
Mother's period of partial custody, as set forth
in Paragraph 4 (a), above, then in that event,
Mot.her may keep the minor children for the
entire weekend until 7:00 p.m. of the evening of
the holiday.
ii. Fourth of July - 10:00 a.m. through 7:00 p.m.
iii. Thanksgiving - 10:00 a.m. t.hrough 9:00 p.m.
iv. Christmas - Christmas Eve from Noon to 9:00 p.m.,
and on December 26 from Noon until 9:00 p.m.
(e) Mother shall have partial oustody of the minor
ohildren on odd-numbered years on the odd-numbered
years on the following holidays:
i. Labor Day - 10:00 a.m. through 7:00 p.m., exoept
if the holiday follows the weekend of Mother's
,~.
period of partial custody as set forth in
paragraph 4 (a), above, then and in that event,
Mother may keep the minor children for the
entire weekend until 7:00 p.m. of the evening of
the holiday.
ii. Christmas 9: 00 p. m. on Christmas Eve
through Noon on December 26.
iii. New Year's 6:00 p.m. on New Year's Eve
through 8:00 p.m. on New Year's Day.
iv. Easter - 11:00 a.m. through 9:00 pm.
(f) Mother shall have partial custody of the minor
children, as aforesaid, for two (2) weeks in the
summer, to be consecutive or non-consecutive, with 30
days advance notice to Father as to the weeks in which
she wishes to exercise her custody rights pursuant to
this subparagraph.
S. Father shall have partial custody of Sara E. Lori and
Christopher J. Lori on the following schedule:
(a) Alternating weekends from Friday at 4:00 p.m. through
Sunday at 7:00 p.m.;
(b) Every other Tuesday evening from 4:00 p.m. until 8:30
p.m., with the Tuesday periods of partial custody to
be on the Tuesday prior to the weekend that Father
exercises his periods of partial custody, as set forth
in subparagraph (a), above.
(c) Every other Thursday evening from 4:00 p.m. until 8:30
p.m., with the Thursday period of partial custody to
be on the Thursday following Father's period of
partial oustody, as set forth in subparagraph (a),
above.
(d) Father shall partial have custody of the minor
ohl.ldren, as aforesaid, in even-numbered years on the
following holidays:
i. Labor Day - 10:00 a.m. through 7:00 p.m., except
if the holiday follows the weekend of Father's
period of partial custody as set forth in
paragraph 5(al, above, then and in that event,
Father may keep the minor children for the
entire weekend until 7:00 p.m. of the evening of
the holiday.
ii. Christmas 9:00 p.m. on Christmas Eve
t.hrough Noon on December 26.
Hi. New Year's 6:00 p.m. on New Year's Eve
through 8:00 p.m. on New Year's Day.
iv. Easter - 11:00 a.m. through 9:00 pm.
(e) Father shall have partial custody of the minor
ohildren on odd-numbered years of the following
holidays:
i. Memorial Day - 10:00 a.m. through 7:00 p.m.,
except if the holiday follows the weekend of
Father's period of partial custody, as set forth
in Paragraph 5(a), above, then in that event,
Father may keep the minor children for the
entire weekend until 7:00 p.m. of the evening of
t.he hoHday.
ii. Fourth of July - 10100 a.m. through 7100 p.m.
iii. Thanksgiving - 10100 a.m. through 9:00 p.m.
iv. Christmas - Christmas Eve from Noon to 9100 p.m.,
and on December 26 from Noon until 9:00 p.IO.
(f) Father Dha11 have partial custody of the minor
ohildren, as aforesaid, for two (2) weeks in the
summer, to be consecutive or non-consecutive, with 30
days advance notice to Mother as to the weeks in which
he wishes to exercise his custody rights pursuant to
this subparagraph.
6. Wi th respect to the exercising of' partial custody during
the summer months for the weeks in which partial custody is requested
by either parent, that parent shall have custody of all four
children. The period of partial custody exercised by either parent
during the summer months shall take precedence over any other period
of partial custody afforded to the other paren herein.
7. It is the intent of the parties to have custody of all of
the minor children during those periods of custody designated herein
as partial custody periods and/or holidrlYS.
8. The parties agree that the ho1 iday custody schedule as
designated herein shall take precedence over the regular custody
schedule.
9. 'l'he parties realize that their children's well being is
paramount to any differences they might have between themselves.
Therefore, they agree that neither party will do anything that may
estrange the children from t.he other parent, injure the opinion of