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HomeMy WebLinkAbout00-06630 ,"11 , ,1, " ~O ,',< , . - . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. . Diane B. Lherisson . No. 00-6630 Civ; ] Plaintiff . VERSUS Patrick Lher;sson Defendant DECREE IN DIVORCE . 7-" , 'ZA> 0 I , IT IS ORDERED AND AND NOW, ~~ DECREED THAT Diane B_ r.hpriF;Ron , PLAINTIFF, . P~~rirk T.hpri~~nn , DEFENDANT, AND " " ARE DIVORCED FROM THE BONDS OF MATRIMONY, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BE:EN ENTERED; NO'1e " " ~~~ROTHONOTAR~ " " ~h~ . . . . . . . . . " . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . " . . " . . . . . . . . . Iii ''',H,,,,,"," -. " ~'. 3' 7,CJ( 3-) 'Of lI!If ~, r "~ -, 1Hr'"" V'" W t~ Rt,;Ali, 4 ~ /1~ ,~~ {:If!- ,~, ,,~1lI ~~", """",lJIf!IJII'tl!!W~~~I'!"IilIiiij,l~@!l~.~Iffi!~~~l~=:~ ,.-~"~~ ,00 '~f""c',\~cc: ~'-:""~1~' ,"'~' . l'-.',J' ". .,d,_,-"...bW..>. ,',' , J:;,.""lli0:" DIANE B, LHERISSON Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V, : CIVIL ACTION - LAW PATRICK LHERISSON Defendant : NO,OO-6630 : IN DIVORCE CIVIL TERM PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under S 3301(c) of the Divorce Code. 2, Date and marmer of service of the Complaint: Acceptance of Service dated October 6, 2000, 3. Date of execution ofthe affidavit of consent required by ~ 3301(c) or The Divorce Code: by the Plaintiff; February 27, 2001; by the Defendant: February 27,2001. 3, Related claims pending: None 4. Date Plaintiff's Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: February 28, 2001, Date: February 28,2001 Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: February 28, 2001. ?~ Karl E, Rominger, Esquire 155 South Hanover Street Carlisle, P A 17013 (717) 241-6070 Supreme Court ID No, 81924 __iMi~Him'J;h;;-Ai>"'->i;"'_'li~i~iil1"l;!~11\Hl""L~~"*""",'\;i,'Hh~ii,j1""T:lIy,;i@j~~~10liit~~wlilili:i->-!ail::'illjiihj~~!IlMUiIil!I!iB!'-'T' .~.~~~. U_''T ",~ ",,- .",~, ,_ ~,~" 0,' r,,~l ..~, .,,, - n ~ ~~"',' 0'~:: gi:~' ~;3 -' c:: :?..: ::.~ If 'I I, Ii i1 II I! I' ,I II Ii I " Ii 'I " " !i C~ ~, <~ ::-::~ ,,~ " C"'" ,~"' , . ,._'.J 0...'"1 ,~~~ (... +. . ~ ,.,.",'"., ,.,",,,_,,~"~ j_'..iJ_",,,,",,,,,,~j"<",,,,',,~; ."",.,C';", ~'_';;;;<',~,"'C'_ _-",~,.:' DIANE BETH LHERISSON, Plaintiff : IN TItlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. , : CIVIL ACTION - LAW ; NO,<X:>- CPrr;:OCIVIL TERM : IN DIVORCE PATRICK LHERISSON, Defendant NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action, You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court, A judgment may also be entered against you for an)l other claim or relief requested in these papers by the Plaintiff. You may lose money or property or o~er rights important to you, including custody or visitation of your children, When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court Hou~e, High and Hanover Streets, Carlisle, IF YOU DO NOT FILE A CLAIM FOR AL~ONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIivoRCE OR ANNULMENT IS GRANTED, I YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Curnberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 Phone: (717) 249-3166 -~ ~'"' """1", ,< ^ , ,.",.,,,' , ""^',i.' .-," '-it,,,", ",', "~""~-'-<.c~~".' '" !;_~ '_," - ""; " iM:.'-, DIANE BETH LHERISSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW PATRICK LHERISSON, Defendant : NO. PO - U30 CIVIL TERM : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Diane Lherisson, who currently resides at 352 North Middlesex Road, Carlisle, Cumberland County, Pennsylvania 17013, 2. Defendant is Patrick Lherisson, is believed tb be a Pennsylvania resident residing in Dauphin County. 3, Plaintiff and Defendant are sui juris, and both have been bona fide residents of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on August 29,1987. 5. There have been no prior action of divorce Qr armulment between the parties in this or any other jurisdiction, 6, The marriage is irretrievably broken 7, Plaintiff has been advised that counseling is available, and that Plaintiff may have the right to request that the Court require the parties to participate in counseling, 8, Plaintiff requests the Court to enter a Decree in Divorce. ''''1' '0..' '.'~ - ~,'~ ".,~'_. """""''"'''-'''''''';:'".' . .,.'".' ;',{., ';.'-"',,0,.,';,-,,0,,;"",,'_, "" ' j{r.:J, I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C,S. ~ 4904, relating to unsworn falsification to authorities, Date: ~~,Io 0 Adw ~/5 ~00~ Diane Beth Lherisson, Plaintiff , ----=.~~--' By?'" Karl E. Rominger, Esquire Attorney for Plaintiff 155 South Hanover Street Carlisle, P A 17013 (717) 241-6070 o "_ , ~- ___",J" I~" ", , ; ,",,",; '>",,,"" ,--,' "'"';";,i~':,i.--,.,,,' <"; DIANE B, LHERISSON Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : CIVIL ACTION - LAW PATRICK LHERISSON Defendant : NO.00-6630 : IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 29,2000, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3, I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree, I verifY that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C,S, ~ 4904, relating to unsworn falsification to authorities. Date: :2P7)dl ~fk1;l~ ILl ~N0N- iane Lherisson, Plaintiff <c",,', - M.= "~~~iimi~lil!l~~~~Mttilli!ll!lliMiL:.E. ., -j, ,~ . m _ =, " ,~ <'~ ~ . .~." ~, ~ '~ C) C v t~~; i,K k(~'; .l~ ~23 S :.:J "'" ,-- ::> (J*"; '" r...., "-~ ...., r'1 GO;) ,~0 c:::: 2 ':'? [ ,= ". ^--c' "..." , ,"._~_".c",,~,,~'! . ",i',,,'. '" _~"''''~''"'''''_ . DIANE B, LHERISSON Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V, : CIVIL ACTION - LAW PATRICK LHERISSON Defendant : NO,OO-6630 : IN DIVORCE CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1, I consent to the entry of a final decree of divorce without notice, 2, I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted, 3, I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary, I verity that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C,S, 94904, relating to unsworn falsification to authorities, Date:;2.,P1 )/ dJ~^y~ /;/-b( /~..."L-- Diane LherissolilPlaintiff ~ , ~,",,-, ~,~ ^ ~ " '~..~~~ '''~~.''''''''r~~!!!iilf~!iIiI!~iilil ~o_' _>< ',","r~,~" .,,~ ,,~,~. "~,,o,~.., ,,' 0' '~~",' 1IlIIilf........./ .,'~ ~ .,'. " n L -' c: ::;;'" ---;-"1 ~Jt:- , 1"1\ L ~ ,::,;.1 Z /":"': :"'.) C/,: -, CJ -, .::~- '~', G\..-, ~~; G) Pc: -:;;- => ~=:l ", O"~ tr =..."'-~~ v~ ^~. "~~" ~t."-'"__' ','.' 0"",',,- ,'..,.-'c .'" ,,,',,' ." ,ilc"-.'-:'- ""'c. .' .- ,.-,,,,~;,,~.,-,- , \i.t; .,,~," . 0', DIANE B, LHERISSON Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : CIVIL ACTION - LAW PATRICK LHERISSON Defendant : NO,OO-6630 : IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT AND ACKNOWLEDGEMENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on September 29, 2000, and I acknowledge receipt of a copy of the same, which was served on me on October 6, 2000, by hand deliver. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3, I consent to the entry of a final decree of divorce, 4, I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted, 5. I have been advised of the availability of marriage counseling, and do not request that tb.e Court require that my spouse and I participate in said counseling, I verifY that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subjectto the penalties of18 Pa, C,S. ~4904, relating to unsworn falsification to authorities. Date: t),f I~ ~,,/ ~. -,;;",-" J~, -.<_ "" " "' ,~,~ ~~ lIili.~IlliI""'"'-~ """"""';'i~v!r..ttm1i!~LiMI~iliI;;~~~;"""~""""'" ~~. ~ ~ j Ill. , ~ jiUT~ ~~., -< c:: ~g .2': .__-1 ,-< :n ZO. C) c- '.,J -'q " '.~,", >,) c::' -v ......' CI' c !j;h ~' " ,. ,':, I",. ~ ',-, e"'" -' "'-,,'_.,, - ,"" '"', ,,,' . _" .,,"<.",-,--,~, '. "J' , :~ DIANE B, LHERISSON Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW PATRICKLHERISSON Defendant : NO.OO-6630 : IN DIVORCE CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1, I consent to the entry of a final decree of divorce without notice, 2, 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted, 3, I understand that! will not be divorced until a divorce decree is entered by the Court and that a copy of the decTee will be sent to me immediately after it is filed with the Prothonotary, I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C,S, 94904, relating to unsworn falsification to authorities, Date: oJ-/d /01 .... l' if!fllli~~~ ~-~jofa~~!.!l11iij~~ijf'""""Jid;'Jj~r' '" ~-, ~ , U'1I ~-,- ... ~~ o S;; -ott rn\,l- -7'-r'. -?' ~i~" ~z';?' >c L'~ =< , ~ ,~'-rt' C:) ., '"'":"\ ..---', \'",) ("''', Cf.' -, '~ .-l '~ . q.;".., ~- "~,, ",'.' y '.. ,','" ,;;',;' "";'--"." " DIANE B, LHERISSON Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V, : CIVIL ACTION - LAW PATRICK LHERISSON Defendant : NO.00-6630 : IN DIVORCE CIVIL TERM ACCEPTANCE OF SERVICE I, Patrick Lherisson, hereby accept service of the Complaint in Divorce in the above- captioned action and I certify that I am authorized to do so. DATE: October 6, 2000 '- .;, ,,;,," "'"'-", ~~:j I "'-''-'~' ' ~MJ:. -', :i..iI~""niliimi.~~~m.~ -,,-=~,;.._~ .=-' ~iMiIIIIl f'" 1. (') f~ l:Jrt ~~r en)" ~c:-.' i~~~. ~- 2' -< -- C-:) C'J , ,~j"l (::~:J f',) c:.' -r..:' G.) :::> (n , ';~ <"~,'~ "" .1 ~~~~,.,:c .' ~ DIANE BETH LHERISSON PLAINTIFF V, PATRICK LHERISSON DEFENDANT IN THE COURT OF COMMON PLEAS OF ' CUMBERLAND COUNTY, PENNSYLVANIA 00-6630 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 26th day of January, 2001, upon consideration of the attached Complainl, it is hereby directed that the parties and their respective counsel appear beforeJacqueline M. Verney, Esq. , the conciliat at 4th Floor, Cumberland County Conrthonse, Carlisle on the 21st day of February, 200 I, at 8:30 a.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 accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order, All children age five or older may also be present at the conference, Failure to appear at the conference may provide grounds for entry of a temporary or permanent order, FOR TIIE COURT, By: Isl Jacqueline M. Verney. EW~ Custody ConCIlIator i, The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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 SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE, IF YOU DO NOT HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 , , "'-~ ,~ ~ " o_,~ ~ , "'^" "~ . "~r ," ,', ~,"^~,~ '-.' ,<'~ " ' ~ ~',,,,.,,,,.,,,,,,,"., . ' -' F!!..ED-{)I:FiGE cr '!,:::;OTAI1Y 01J4N31 PNI:[,Q ~ CUMBEFiL!\i\[i COUi'm PENNSYLVANIA i.}IOI- MtW ~t-<~ -h ;if ~J i r 31 tJl' 'J1~:.e I~ lP r/fI 'J/tJl- t~~~' 4!j~f;O# , ~!"'""l~.., I ~,~ ~"~.;:l=,_III'~~".'"",!!'J";';i,,'~~:r~-l',t>li.I"lWffiifi!'~~~W>~I''Y,"",.W''V1'ft'lj:;'~I!!II>1~,",:\I~~"'m~~ . . ~1 .,. ", 'l!ilIi~"~~ -~I' " '".., ~;'"" . ~'*",' ' DIANE BETH LHERISSON, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-6630 CIVIL TERM PATRICK LHERISSON, Defendant CIVIL ACTION - LAW IN DIVORCE AND CUSTODY NOTICE You have been sued in court, If you wish to defend against the claims set forth in the following pages, you must take prompt action, You are warned that if you fail to do so, the case may proceed without you and an order may be entered against you by the court, You may lose money or property rights important to you, including custody or visitation of your children, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM, YOU SHOULD TAKE THIS PAPER TO YOU LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717249-3166 By: , Dolgos ID6 8 PO Box 60809 Harrisburg, PA 17106-0809 717541-9660 """ ~I' ~" " " ~Iib. "~ '~.Iiiik! DIANE BETH LHERISSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-6630 CIVIL TERM PATRICK lHERISSON, Defendant CIVIL ACTION - LAW IN DIVORCE AND CUSTODY ORDER OF THE COURT AND NOW, , upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before , conciliator/Judge, at on the day of2001, at 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 accomplished, to define and narrow the issues to be heard b the court, and to enter into a temporary order. All children age five or older may also 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, By: Custody Conciliator/Judge The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990, For information 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 SHOULD TAKE THIS PAPER TO YOU LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717249-3166 ~~ ~ - "' -~ ~':...' DIANE BETH LHERISSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-6630 CIVIL TERM PATRICK LHERISSON, Defendant CIVIL ACTION - LAW IN DIVORCE AND CUSTODY ORDER OF THE COURT AND NOW, , upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before , conciliator/Judge, at on the day of 2001, at 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 accomplished, to define and narrow the issues to be heard b the court, and to enter into a temporary order. All children age five or older may also 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, By: Custody Conciliator/Judge The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990, For information 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 SHOULD TAKE THIS PAPER TO YOU LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717249-3166 -. " , ".-- " , '. ' 0 _ .., ~ ~~__""~_' , , lJ:' DIANE BETH LHERISSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-6630 CIVIL TERM PATRICK LHERISSON, Defendant CIVIL ACTION - LAW IN DIVORCE AND CUSTODY NEW MATTER AND NOW, comes Defendant, Patrick Lherisson, by and through his attorney, Judith F, Dolgos, Esquire, and files the following New Matter in the above referenced Divorce action, and in doing so states as following: COUNT I: CUSTODY 9, Paragraphs 1 through 8 of the foregoing Complaint in Divorce are incorporated herein by reference as if set forth fully, 10, There are two children born of this marriage: Jessica Lherisson, age 17, Date of birth: August 25,1983, at Paris, France; Alexandre Pierre Lherisson, age 11, Date of birth: August 27, 1989, at Hershey, PA 11, Plaintiff is the natural mother of the subject minor children, 12, Defendant is the natural father of the subject minor children, 13. The children have lived with both the Plaintiff and the Defendant together from birth until June 18, 2000, when father was granted full custody by way of a Protection From Abuse Order entered against mother by this Honorable Court, 14, There have been no other orders for the custody of these children and all persons who have had custody of the minor children have been made a party to this matter. .~, .'" .~='''''' --', '.'_0 '.~' ,~,""<",,,,,. "'-'lIt~"'! 15, On August 30, 2000, by agreement of the parties, father withdrew the Protection From Abuse,order and permitted mother to re-enter the marital home where she was to reside with the children with father retaining rights to liberal periods of temporary custody of his I children. 16, On August 30, 2000, without father's previous consent or knowledge, Brian Maglenigen, mother's paramour, moved into the marital home where his children are residing, 17. Mr. Maglenigen continues to reside in the marital home and shares the marital bed with plaintiff, 18, Since 0efendant has lifted the PF A he has had not visitation with his daughter, Jessica and has seen his son, Alexandre only at the following times: a, November 12, 2000, from 10 am to 5 pm; b, November 19, 2000, from 10 am to 5 pm; c, December 3, 2000, from 10 am to 5 pm; d, December 9 & 10; and e, December 22, 23, 24 & 25, 19, There was a visit scheduled for January 13 & 14, but mother contacted father stating that his son did not want to visit with him, 20, There was a visit scheduled for January 20 & 21, but son called father at work an informed him that his mother would no longer allow the child to see his father, the child was distraught during the phone call, '- ,. ~ ~ "I&'~: , 21, Father and son have had to maintain a secret phone relationship in order to remain in contact, 22, Althou@h Alexandre has stated unequivocally that Mr. Maglenigen treats him nicely, he is frighteQed by threats made to him by Mr, Maglenigan regarding his father's safety, I 23, It has (jome to Defendant's knowledge that the Plaintiff no longer has a working telephone at her ~ouse, I 24, Father ,is concerned for the health, safety and welfare of his children and believes that it would @e in their best interest if they were to reside primarily with their father with periods , of temporary custody with their mother, WHEREFORE,: since the best interest of the minor children would be served in the primary custody of Defendant, Defendant requests this Honorable court to grant primary physical custody of Jessica and Alexandre Lherisson te their father, Patrick Lherisson, Defendant herein, COUNT 2: EQUITABLE DISTRIBUTION 25, Paragraphs 1 through 24 of the foregoing Complaint in Divorce and New Matter are incorporated herein by reference as if set forth fully, 26, Since tl:1e parties to this action are unable to determine a fair and equitable distribution of their mClrital assets, Defendant requests that this Honorable Court undertake to do so, ,-:;!ifi ~l"" ~~ ~ . ". , '.. ,.J ,0 , . ~' ~ . ~1,')" : WHEREFORE, Defendant prays this Honorable Court equitably distribute the marital assets in a fair and equitable manf)er. By: Respectfully Submitted, J cf h F, Dolgos I 8738 PO Box 60809 Harrisburg, PA 17106-0809 717541-9660 ' '..:MIFolilli.illllllll .. '"~' < " ^,-, - ---",',~' ",. ','.' .'~... ""'''''",",-, '," ~;,-' VERIFICATION I, PARTICK LHERISSON, certify that the statements made in the foregoing ANSWER AND NEW MATTER, are true and correct to the best of my knowledge and belief, I understand that false statements herein are made subject to the penalties of 18 Pa, C,S,A, ~ 4904, relating to /\ , I Dated: 'ttVtL /' :t I( 2Cl7J~ I J## unsworn falsification to authorities, -ma,,_' JO" J < ;"'d;H"'ftiMi" l' "" 'uti"j" . MAR 1 5 200ft/} DIANE BETHLHERISSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLV ANIA : NO. 2000-6630 CML ACTION - LAW V. . . PATRICK LHERlSSON, , Defendant : IN CUSTODY ORDER OF COURT AND NOW, this /(p'" day of /1?tvr.h ,2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Diane Beth Lherisson, and the Father, Patrick Lherisson, shall have shared legal custody of Jessica Lherisson, born August 25, 1983 and Alexandre Pierre Lherisson, born August 27, 1989. Each parent shall have an equal right, to be exeroised jointly with the other parent, to make all major non-emergenoy deoisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 2, Mother shall have primary physical custody of Jessica Lherisson, with Father having periods of partial physical custody as the child and Father agree. 3. Until Father relocates to the Cumberland Valley School District, Mother shall have primary physioal custody of Alexandre, with Father having periods of partial physical custody as follows: a, Alternating weekends from after work on Fridays to Sundays at 8:00 p,m. b. Mondays during the weeks that Father is not working that evening and Thursdays during the weeks that Father is not working that evening, from after work to 8:00 p.m. c. During weekend custody, the parties shall share transportation, with the receiving party picking up the child. During weekday custody, Father shall be responsible for all transportation. 4. Onee father relocates to the Cumberland Valley School District, the parties shall share physical custody of Alexandre, with Father having overnight custody on the following schedule to ooinoide with Father's work schedule: a. Alternating weekends from Friday after work to Sundays at 8:00 p.m. b. Mondays, Wednesdays and Fridays to coincide with Father's weekend oustody and on Tuesdays and Thursdays on alternating weeks. Pick-up shall be after work. . "", , I ~. "'; -" . .=' "";'" '~,'"" . "'liffU': i c. Transportation shall be shared with the receiving party being responsible for transportation unless otherwise agreed by the parties, d, Mother shall have custody of the child on Mother's Day. Father shall have custody of the child on Father's Day. e. Neither party shall do anything that may estrange the child from the other party, or injure the opinion of the child as to the other party, or may ~per the free and natural development of the child's love or affection (or the other party. e. The parties shall alternate the Christmas holiday. Block A shall be from 1i2:00 Noon Christmas Eve until 12:00 Noon Christmas Day. Block B *all be from 12:00 Noon Christmas Day to 12:00 Noon December 26, f. The parties shall alternate the following holidays: New Year's Day, Memorial Day, July 4th and Labor Day, , g. Eaoh party shall be entitled to two uninterrupted weeks of oustody ili the summer provided they give the other party 30 days prior notice. I h. 17he child shall not have access to guns in or around the home. i. Such other times as the parties may agree. 5. This Order is entered pursuant to an agreement of the parties reached at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual cons~nt. In the absence of mutual consent, the terms of this Order shall control. J. .~ (\ ,,# 0.' \P<'. ....",,1<7 I,)'? ~~ cc: Judith F, Dolgos, Esquire Karl Rominger, Esquire , '"', , ":" ~~- " " ("'I~ .. UI'- I, 01 11t1f? I 6 PI'! 'i. I" I to,. ,'J. CUM"".' ,bthU\\U COUNTY PENNSYLVAN/.I\ ' ",' ~=='- ~-~,. "--~." r' III]! ,"', ~~~illj!0'!J',I~,'Pif"~oo;,~jBt..~~"'!;IH~!llR~~~q,~~~,. o. r~""",;-' ;-., - ",,';1' '--,)- , i - _< ' 0<, . -;., ~., :' I , . . II. ,~::;:: "... .. MAR 1 s 2DD1tfl DIANE BETHLHERISSON. Plaintiff V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY.PENNSYLV ANIA : No. 2000-6630 CML ACTION - LAW PATRICKLHERISSON. Defendant : IN CUSTODY , PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator sub$its the following report: I 1. The pertinent infonnation concerning the chtldren w~o are the subject of this litigation is as fol~ows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Jessica Lherisson August 25, 1983 Alexandre Pierre Lherisson August 27,1989 Mother Mother 2, A Conciliation Conference was held on this matter on March 14, 2001. Mother, Diane Beth Lherisson, was present with counsel, Karl Rominger, Esquire, and Father, Patrick Lherisson, was present with counsel, Judith F. Dolgos, Esquire, 3. The parties agreed to entry of an Order in the form as attached, 3 -/~-o I Date ~,~~.~, qu ine M. Verney, Esquire Custody Conciliator ",,;,<'"'- - ...."'-~ J '~TilDIi:iIIlIII . 't j~~41~~J.; . - t JUN 2 8 2n01 21^ DIANE BETH LHERISSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLV ANIA V. NO, 2000-6630 CIVIL TERM CIVIL ACTION - LAW PATRICK LHERISSON, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this "3~ dayof ~ ,2001, upon consideration of the attached Custody Conciliation eport, it is ordered and directed as follows: 1. and effect. The prior Order of Court dated Mach 16,2001 shall remain in full force 2, Father shall hold in abeyance his Petition for Contempt but reserves the right to pursue said Petition, including the payment of counsel fees at any future time, 3, The parties shall cooperate with each other in the selection of a counselor for the child, 4. This Order is entered pursuant to an agreement of the parties reached at a Custody Conciliation Conference, The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, ,J ~J' -~~~ C;".yO \ cc: Karl Rominger, Esquire - Counsel for Moth Judith F, Dolgos, Esquire, Counsel for Father j dH..u.@>i"J-~-'- ,~ ~,~ ,~-"~"' ~ , J,_,,_ . -....._"'-" O'lirit<ilil1lt1rAllh1'.<L 1 JUN 2 82001' ()fI\ DIANE BETH LHERISSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYL V ANlA V. 2000-6630 CIVIL TERM CIVIL ACTION - LAW PATRICK LHERISSON, Defendant IN CUSTODY PRIOR JUDGE: Kevin A. Hess, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Alexandre Pierre Lherisson August 27,1989 Mother 2. A Conciliation Conference was held in this matter on June 27, 2001. Mother, Diane Beth Lherisson, was present with counsel, Karl E. Rominger, Esquire, and Father, Patrick Lherisson, was present with counsel, Judith F. Dolgos, Esquire. 3. attached. The parties agreed to an amendment to the prior Order in the form {r;<g/Q / Date '1f;,U a ueline M. Verney, Esquire Custody Conciliator ;J "-~.>"dJlr I~""" .._ I ~~~, "'"'"'-' -~~~ffiJ'13,-. DIANE BETH LHERISSON PLAINTIFF V. PATRICK LHERISSON DEFENDANT IN TIIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-6630 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, May 09, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Veruey, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, May 23, 2001 at 2:30 ]~.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 accomplished, to defme and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish auy and all existiug Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Jacqueline M. Verney. Esq.#' Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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 SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ".' n - - 1 ~I o~:' ~-,~ ~~,:L~9::~;~?rT:F~ "")'\"J"Mw I/';JI' 01/"111' '0 hi 1 pf,! r-. .1 ,;:2') ,'- C'Uil/F' . \ti<:)t~,!...r " " . .L~.,il'i n.~.. "'r-' \/"1 II'I! j-'r.:NiVSy[j/"1~Vf;\u VTY 5/o.cJ! W ~ ~ :-G 4 f)~~ S;/t) .t)1 7!~ ~ ;e; ~ 5-/tJ,t1/ ~ ,t" L ~ ~ dt; ~~ ~. .iI!llU AlL! ,.,.,.~~,~!!;., ,""""""l'. ~~~l!i:'l~H.Q.%:~_re'j,%..,j11f"!\,!~~r;,WJ"W!),1)f5"ffie:,t1?-mli!'tjtY11i~~"li'mmrn;~l51j~~~, _ ~ ~~ ~Jl,~, <..-_'~:'" ,~~ ... , .~ ili iiB"i--: DIANE BETH LHERISSON, Plaintiff, Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. PATRICK LHERISSON, Defendant, Petitioner NO. 2000-6630 CIVIL ACTION-LAW IN CUSTODY NOTICE AND ORDER TO APPEAR Legal proceedings have been brought against you alleging you have wi11fu1ly disobeyed an Order of Court for custody. If you wish to defend against the claims set forth in the following pages, you may, but are not required to, file in writing with the Court your defenses or objections. Whether or not you file in writing with the court your defenses or objections, you must appear in person in court on . at . M., in Courtroom_ 1 Courthouse Square, Carlisle, PA 17013. IF YOU DO NOT APPEAR IN PERSON, THE COURT MAY ISSUE A WARRANT FOR YOUR ARREST. If the court finds that you have willfully failed to comply with its order for custody, you may be found to be in contempt of court and committed tojail, fmed or both. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GOTO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Court Administrator Cumberland County Courthouse Carlisle, P A 17013 717240-6200 ", BY THE COURT: Date: - ~.' ~ --,' ., , t.l_ , ",-, '''d '" ,~'.,",,,,'v'''-_"i''''''~'''' '';;'' 'co,," ."~ '0.'" U i'") DIANE BETH LHERISSON, Plaintiff, Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2000-6630 CIVIL ACTION-LAW PATRICK LHERISSON, Defendant, PE!titioner IN CUSTODY PETITION FOR CONTEMPT 1. Petitioner is Patrick Lherisson, DE!fendant in the above-referenced matter, who currently resides at 502 Twin Hills Road, Dillsburg, Cumberland County, Pennsylvania. 2. The Respondent is Diane Beth Lherissoll, Plaintiff is the above-referenced matter, who currently residE!s at 352 North MiddlE!sE!x Road, Carlisle, Cumberland County, Pennsylvania. 3. On March 16th, 2001, following a conciliation meeting with Attorney Jacqueline M. Verney, Esquire, the Honorable Kevin Hess, Judge of this Court, ordered and directed Mother shall have primilry physical custody of the parties minor child, Alexandre Pierre Lherisson until Father relocates to the Cumberland Valley School District, at which time the parents would share physical custody. A copy of the Order is attached hereto as Exhibit "A" and incorporated herein by reference thereto. 4. The Order specifically states at paragraph e. therein, that" ...Neither party shall do anything that may estrange the child from the other party, or injure the opinion of the child as to the other party, or may hampE!r the freE! and natural development of the child's love or affection for the other party," 5. SinCE! this Court's Order, refE!renced above, MothE!r has systematically madE! inroads into dE!stroying the relationship bE!tween Father and son. Specially, Mother has told son that Father is a drug addict and an alcoholic, that Father sleeps with multiply partners even 1 '"""~-~ I"'"" ., "--"'l though Father has a significant, monogamous relationship and Mother had made numerous unkind remarks about Father's girlfriend. 6. As a result of Mothers interference in Father's relationship with his son, the once open and loving relationship has deteriorated to the point that the minor son has refused to visit his Father and when they are together the usually pleasant and kind child is now angry, mean spirited and often makes hurtful remarks to not only Father, but to his girlfriend and to her child. 7. Respondent, by her actions, has willfully failed to obey said Order by her continuing interference and injurious behavior, which has caused an estrangement between Father and child. 8. Petitioner believes and therefore avers, that to avoid further alienation of Father and son, that it is the best interest of the minor child that sole, primary custody by granted to Father, with periods of temporary custody in Mother. WHEREFORE, Petitioner respectfully prays that this Court adjudge the Respondent in contempt of court and to grant any and all other relief this Court may deem just and reasonable under the circumstances, including but not limited to entering an order granting primary physical custody to Petitioner, and assessing costs, including attorney's fees for these proceeding upon Respondent. Respectfully submitted: Date: May 1. 2001 - By: PO Box 60809 Harrisburg, PA 17106-0809 717541-9660 Fax 541-9663 2 " '" "W;!; , I I I I I I I I , I I , I I I ~~ -, ,- i ,,-' "'- -~," _~_ ,C', ~ ,. '""" ,;, ; ",i~: VERIFICATION I, PATRICK LHERISSON, certify that the statements made in the foregoing PETITION FOR CONTEMPT, are true and correct to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. ~ 4904, relating to unsworn falsification to authorities. "'-- Dated:/7J1 ~ lbvl ,,~' - . ,~ "', . ""-^ -, -~. ,. ;-" '. ,~- "~~~. ,j1 MM 1 5 200'l1J./ DIANE BETH LHERISSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLV ANIA V. : NO. 2000-6630 CIVIL ACTION - LAW PATRICK LHERISSON, Defendant : IN CUSTODY ORDER OF COURT ANDNOW,this Jl+h daYOffYla.f"ch ,2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Diane Beth Lherisson, and the Father, Patrick Lherisson, shall have shared legal custody of Jessica Lherisson, born August 25, 1983 and Alexandre Pierre Lherisson, born August 27, 1989. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 2. Mother shall have primary physical custody of Jessica Lherisson, with Father having periods of partial physical custody as the child and Father agree, 3. Until Father relocates to the Cumberland Valley School District, Mother shall have primary physical custody of Alexandre, with Father having periods of partial physical custody as follows: a. Alternating weekends from after work on Fridays to Sundays at 8 :00 p.m. b. Mondays during the weeks that Father is not working that evening and Thursdays during the weeks that Father is not working that evening, from after work to 8;00 p.m. c, During weekend custody, the parties shall share transportation, with the receiving party picking up the child. During weekday custody, Father shall be responsible for all transportation. 4. Once father relocates to the Cumberland Valley School District, the. parties shall share physical custody of Alexandre, with Father having overnight custody on the following schedule to coincide with Father's work schedule: a. Alternating weekends from Friday after work to Sundays at 8:00 p.m. b, Mondays, Wednesdays and Fridays to coincide with Father's weekend custody and on Tuesdays and Thursdays on alternating weeks. Pick-up shall be after work. >iW\-- ~ ' "I,"L.~ ~.~,~-~" ;,"", ,.,,'"-'~~, C_""_"''''>'"__-~~-~'''"'',-~,''>.' ."" ""'iil'i; c. Transportation shall be shared with the receiving party being responsible for transportation unless otherwise agreed by the parties, d. Mother shall have custody of the child on Mother's Day. Father shall have custody of the child on Father's Day. e. Neither party shall do anything that may estrange the child from the other party, or injure the opinion of the child as to the other party, or may hamper the free and natural development of the child's love or affection for the other party. e, The parties shall alternate the Christmas holiday. Block A shall be from 12:00 Noon Christmas Eve until 12:00 Noon Christmas Day. Block B shall be from 12:00 Noon Christmas Day to 12:00 Noon December 26, f. The parties shall alternate the following holidays: New Year's Day, Memorial Day, July 4(h and Labor Day. g. Each party shall be entitled to two uninterrupted weeks of custody in the summer provided they give the other party 30 days prior notice. h. The child shall not have access to guns in or around the home. 1. Such other times as the parties may agree. 5. This Order is entered pursuant to an agreement of the parties reached at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, ISI-f'j(ffJ d. 1L f)j)) J. cc: Judith F, Dolgos, Esquire Karl Rominger, Esquire