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('IVII. ACTION. LA \\'
CIIIUSTOPIIElt A. I.Ei'iICII.
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:-':0. '18-59111
IN ClISTOIIY
OIUlElt OF CO[JRT
AN)) NOW this 1_':'da)' of i,Jr, ::
:=. 1998, ai'lcr rcvicwing thc Custody
Agrccmcnt filcd in this mattcr. it is hcrchy ORDERED AND DECREED Ihat Ihc Cuslody
Agreement. daled III I t 1998. signcd hy thc Plaintilf and Dcfcndant. hc madc an ordcr of this
court. The Custody Agrccmcnl shall bc binding on cach oflhc partics until such timc thaI it is
changcd by mutual agrccmcnt of thc partics or by furlhcr ordcr of Ihis court.
BY THE COURT:
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Durlng the past three years, the child has resided with the
following persons and at the following addresses:
Persons
Addresses
Dates
Mother &
Father
119 N. sporting Hill Road
Mechanicsburg, PA
10/16/96-
7/15/98
Mother
4810 Charles Road, Apt. 3
7/15/98-
date
Mechanicsburg, PA
The mother of the child is Brady Lee J. Lenich, currently
residing at 4810 Charles Road, Apartment 3, Mechanicsburg, PA.
She is married.
The father of the child is Christopher Allen Lenich who
resides at 119 N. Sporting Hill Road, Mechanicsburg, PA 17055.
He is married.
4. The relationship of plaintiff to the child is that of
mother. The plaintiff currently resides with the following
persons:
Relationship to the child
Name
child only.
5.
The relationship of Defendant to the child is that of
The defendant currently resides with the following
father.
persons:
Name
Relationship
No one.
2
6. Neither party hau participated au d pal-ty or witness,
or in another capacity, in other litigation concerning the
custody of the child in this or another court.
Plaintiff does not know of a person not a party to tl~
proceedings who has physical custody of the child or claims to
have custody or visitation rights with respect to the child.
7. 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 her life.
B. Plaintiff can provide a stable environment.
C. Plaintiff can provide a loving home.
8. Each parent whose parental rights to the child have not
been terminated and the person who has physical custody of the
child has been named as parties to this action.
WHEREFORE. Plaintiff requests this Honorable Court to
grant her legal custody and primary physical custody of the
child subject to the father's periods of liberal visitation.
Respectfully submitted,
/~ .
~el S. Travis
Attorney for Plaintiff
Supreme Court ID No. 77399
4076 Market Street, Suite 209
Camp Hill, PA 17011
(717) 731-9502
3
.'
VERIFICATION
r verify that the statements made in this Complaint are true
and correct.
r understand that false statements herein are made
subject to the penalties of 18 Pac C.S. Section 4904 relating to
unsworn falsification to authorities.
DATED:
P - ,) 9 - q 7/
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Brad~/Lee J. Le.nfch
Plaintiff "
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Miclmcl S. Travis
Allomcy at Law
3904 Trin~lc Roa~
Camp Ifill, PA 170 II
(717) 73 1.9502
BRADY LEE CORNMAN (LENICII),
Plaintiff/Petitioner
) IN TilE COLlin OF COMMON PLEAS
) CUMBERLANI) COlINTY,I'ENNSYLVANIA
)
) No. 1998-5901 CIVIL TERM
)
) Civil Action - Law
) In Custod~'
"S_
CHRISTOPHER A. LENICH,
Defendant/Respondent
PETITION FOR MODIFICATION
OF A PARTIAL CUSTOI>Y ORDER
RE: RACHEL SHAE LENICH
I. The petition of Brady Lee Cornman. whose married name was Brady Lee Lcnieh,
respeclfully represents that on November 24, 1998, an Order of Courl was entered for partial
custody, a true and correct copy of which is attached.
2, This Order should be modified because Respondent has moved to Lebanon
County, Pennsylvania, Additionally, Petitioner has little weekend time with Rachel. She is
unable to schedule activities for Rachel on the weekends due to a lack of scheduled periods of
weekend custody.
3. Pelitioner now resides at 6 Railroad Avenue, Shiremanstown, Cumberland
County, Pennsylvania.
4, Respondent now resides at 229 N. 16th Street, Lebanon, PA 17042,
5. It is in the best interesl of Rachel to have visitation with her Father on alternating
weekends, subject to additional periods of partial euslody as Ihe parties may agree.
WHEREFORE, Brady Lee Cornman prays this Honorable Court for an Order of Court
modifying the November 24, 1998 Order of Court granting Brady Lee Lenich primary physical
custody of Rachel Lenich, subject to Father's partial periods of custody on alternating weekends.
Respeetfu lysZitled,
ich, el . Travis
ID No. 77399
Attorney for Petitioner/Plaintiff
3904 Trindle Road
Camp Hill, I'A 1701 I
(717) 731-9502
BRADY LEE LENICH,
1'llIintiff
: IN THE COURT OF COMMON PLEAS
: ('tIMBERLAND COUNTY,I'ENNSYLVANJA
\'.
CI\'IL AcnON - LA W
CHRISTOPHER A. LENICH,
Dcfcndanl
NO. 98-5901
: IN CUSTODY
ORDER OF COURT
AND NOW this.3j: day ot:r) cw""",L..,'V ,1998, after reviewing the Custody
Agreement filed in Ihis maner, it is hereby ORDERED AND DECREED that the Custody
Agreement dated II /, &, 1998, signed by the Plaintiff and Defendant, be made an order of this
court. The Cuslody Agreement shall be binding on each Oflhe parties until such time Ihat it is
changed by mutual agreement of the parties or by further order of this court,
BY THE COURT:
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EXHIBIT
.TRUE COpy FROM RECORD
In l""ln1C""Y .,'..Ii! r(of, I h-:ru unto sot my hand
and '"a ;I.JI of silid (Ourl' ill Carlisle, Pa.
Th' CAlLa 'r1
IS.., "'To..,,,,, day uf....",...l:Q:l-I:-.,..., 19...'7:.[
...._...~..;..r~:t.....C<.."..,.12...'1f-( Yo
Zli4J- . Pr~lhonot~;Y"""-'-
A-
B.
On the .ChiJd's bitthdaylncxldJlumbcrcd years; lhc Mother shall have 1he Child
'i'f
on hcr birthday in even numbcred years.
C. Every year 011 Father's Day; the Mother shall have the Child eve!)' year on
Mother's Day.
D. On Ncw Year's Day, Memorial Day and Labor Day in even numbered years. The
MOlher shall have the Child on New Year's Day. Mcmorial Day and Labor Day in odd numbercd
years.
E. On Easter unlil 3:00p,m. in even numbered years. TIle Mother shall have Ihe
Child on Easter unlil 3:00p.m. in odd numbcred years,
F. Every Thanksgiving Day in even numbered years. The Mother shall have Ihe
Child on Thanksgiving Day in odd numbered years,
G. On Christmas Day in odd numbered years. The Mother shall have custody of the
Child on Christmas Day in even numbered years,
H. For each holiday, the parent without visilation shall have the righl to visilation on
the day before each named holiday until 6:00p.m.
3. Each parent shall be cnlitled to two weeks ofuninlerrupled vacation during the
year with thirty days wrillen notice; the weeks shall nol be consecutive unless af,'1'eed to by the
parties.
4. The parties shall share transportation for all exchanges of custody under this
agreement unless othel'\vise agreed by the parties.
5. Neither party shall do or say anything which may estrange the child from the other
parenl, injure the opinion of the child as to the other parent or hamper the free and nalural
development of the child's love and respect for the oilier parent.
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BRADY LEE CORNMAN (LENICII)
Plaintiff
lllL j :~ :~OG5 n\
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IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COlJNTY,l'ENNSYI.V ANIA
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vs.
1)8.51)01
CIVIL ACTION I.A W
CHRISTOPHER A. LENICII
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this _ "'YO day of .~--... , 2005,
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
upon
1. The prior Ordcr of this Court datcd Novcmbcr 24, 1998 is vacated and rcplaccd with this
Ordcr.
2. The Mother, Brady Lce Cornman, and the Fathcr, Christopher A. Lenich, shall have shared
legal custody of Rachel Shae Lenich, born October 16, 1996. Each parent shall have an equal right, to
be exercised jointly with thc other parent, to makc all major non-emergency decisions affecting the
Child's general well-being including, but nOllimitcd to, all decisions regarding hcr health, education
and religion. Pursuant to the terms of this paragraph cach parent shall be entitlcd to all records and
information pertaining to thc Child including, but not limited to, school and medical records and
information.
3. The parties shall have physical custody of the Child in accordance with the following
schedule:
A. During the school year, the Father shall have custody of the Child on two out of
evcry three weekends from Friday at 7:00 p.m. through Sunday at 7:00 p.m. The
Mother shall have custody of the Child at all other times not specified for the Father.
B. During the summer school break, the Father shall have custody ofthe Child for
three weeks beginning on the first Friday after the last day of school and ending on
the fourth Sunday after thc last day of school. The Mothcr shall have custody of the
Child during the middlc weckend of the Father's block of custody from Friday at
7:00 p.m. through Sunday at 7:00 p.m. The Father shall have custody of the Child
for the last thrce weeks of the summer school break, which period of custody shall
end on the last Sunday before school begins. The Father's period of custody under
this provision shall begin on Friday. The MOlher shall have custody ofthe Child
over the middlc weekend during thc Father's block of custody under this provision
from Friday at 7:00 p.m. through Sunday at 7:00 p.m. The Mother shall have
custody of the Child bctwcen the Iwo blocks of custody specified for the Father in
Ihis provision during thc sUmmcr school hrcak, !luring thc Mothcr's cxtcndcd
sUlllmcr pcriod of cuslody. Ihc Falhcr sll:lll havc custody or thc Child on altcrnating
wcckcnds from Friday al 7:00 p.m. through SUll<Iay al 7:1111 p.1II
C. Thc school yc,lr cuslody schcdulc shall rcsumc with Ihc Mothcr having custody or
Ihc Child on the lirsl weekend allcr Ihc heginning or thc Sell\Hll ycar ,md Ihc Falher
having lwo eonseeutivc wcckcnds Iherealler.
4, Each party sh"II bc cntitlcd to h"vc custody oflhe Child Illr two weeks (consccutive or non-
consecutive) each summer upon providing reasonahle adv"nce nolice 10 thc other p"rty. E"ch p"rlY
slmll schedule his or hcr v"e"tion periods or custody under this provision to 1',,11 wilhin th,,1 party's
extended block ofsul11mer custody under the rcgul"r sehcdule. In the cvcnt either p"rlY schedules a
conseeulive week ofv"c"tion custody which interfcres wilh lhe other p"rty's regular weekend period
of custody, a make-up weekend period ofcuslody shall be schedulcd on the next "v"ilable weekend.
5. The parties shall share having the custody of the Child on holidays as follows:
A. Christmas: The Christmas holiday slmll be divided into Segment A, which shall run
from Christmas Eve at 10:00 a.m. through Chrislmas Dayal 10:00 a.m., and
Segment B, which shall run from Christmas Day at 10:00 a,m, through
December 26 at 10:00 a.m. In odd numbcred ycars, the Father shall have custody of
the Child during Segment A and the Mother sh,,1I have custody during Segment B.
In even numbered years, lhe Mother shall have custody of the Child during
Segment A and the Father shall have custody during Segment B.
8. New Year's: The New Year's holiday shall be divided into Segment A, which shall
run from New Year's Eve at 10:00 a.m. through New Year's Dayal 10:00 a.m., and
Segment B, which shall run from New Year's Day at 10:00 a.m. through January 2
at 10:00 a.m. In odd numbered years, the Mother shall have custody of the Child
during Segment A and the Father shall have custody during Segment 8. In even
numbered years, the Father shall have custody of the Child during Segment A and
the MOlher shall have custody during Segment B. For purposes of this provision,
the entire New Year's holiday shall be deemed to fall within the same year as New
Year's Eve.
C. Easter: The Mother shall have custody of the Child on Easler Sunday in odd
numbered years and the Father shall have custody of the Child on Easter Sunday in
even numbered years. The specific times for the holiday period of custody under
this provision shall be arranged by agreement between the parties, with the
exception that the Child shall be returned to the Mother's custody by 7:00 p,m. on
Easter.
D. Thanksgiving: The Thanksgiving holiday shall be divided into Segment A, which
shall run from Wednesday at 7:00 p,m. Ihrough Thanksgiving Day at 3:00 p.m., and
Segment B, which shall run from Thanksgiving Day at 3 :00 p.m. through Friday at
7:00 p.m. In odd numbered years, the Father shall have custody of the Child during
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