The URL can be used to link to this page

Home My WebLink About99-03841s i F L2' a 4Nt ?1. ?a T Fp}? tl'y N N i Jennifer L. I ehnlan Attorney at Iaw F.O. BOX 6130 27 South Arlen! Street Harrisburg' FA 17112-0130 717-671-1200 4 ',1 RANDY L. ALLEN, V. Plai : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CYNTHIA A. ALLEN, Defendant NO. y9- 3i//-CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT ANDNOW, ?- z)</ vc directed that the parties and their resp, ctiva upon consideration of th counsel appear beforee attached cot RI ' t, it is hereb the conciliator, at 2 i , ' n°?4j?91? day of 1c c a Pre-Hearing Custody Conference. At such conferenc , an effort will be made 9o r9e ol1 a the ssues 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 THE COURT, By: Custody Conciliator 6 T he 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 cant, 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 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 TWO LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 U ? ? ?t ?./:?. J. ?I ?1...??.. ?i ???? . RANDY L. ALLEN, Plaintiff V. CYNTHIA A. ALLEN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 9 g 3,F,// 04,. y 7- CIVIL ACTION - LAW IN CUSTODY 1. Plaintiff is RANDY L. ALLEN, currently residing at 1900 Offs Bridge Road, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant is CYNTHIA A. ALLEN, currently residing at 106 North Arch Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff seeks partial custody of the following child: Name Present Address AU Sebastian L. Allen 106 N. Arch St. 4 (DOB 5-4-94) Mechanicsburg, PA 17055 4. The child was not bom out of wedlock. The child is presently in the custody of Defendant, CYNTHIA A. ALLEN, who resides at 106 North Arch Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 5. During the past five years he resided with the following persons at the following addresses: N=9W Address DXU Cynthia A. Allen 106 N. Arch St. Mechanicsburg, PA 17055 Approximately October, 1996 - present Cynthia A. Allen Randy L. Allen Cynthia A. Allen Columbia Avenue Enola 1900 Orrs Bridge Road Enola, PA 17025 October, 1995 - Approximately October 1996 Birth - October, 1995 6. The mother of the child is Defendant, CYNTHIA A. ALLEN who is currently residing at 106 North Arch Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. She is divorced from the Plaintiff and is presently unmarried. 7. The father of the child is RANDY L. ALLEN, currently residing at 1900 Orrs Bridge Road, Enola, Cumberland County, Pennsylvania 17025. He is divorced from the Defendant and is unmarried. 8. The relationship of Plaintiff to the child is that of Father. The Plaintiff currently resides with the following persons: None. 2 9. The relationship of Defendant to the child is that of Mother. Th: Defendant currently resides with the following persons: Sebastian L. Allen Son 10. Plaintiff has not participated as a party or a witness, or in any other capacity in other litigation concerning the custody of the child in this or any other court. 11. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 12. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or who claims to have custody or visitation rights with respect to the child. 13. The best interest and permanent welfare of the child will be served by granting the relief requestcd. 14. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff requests the Court to grant shared legal and physical custody of the child to he and the Defendant and requests that the Court establish a schedule of shared physical custody of the child. Respectfully submitted, By: Je fifer L. Lehman, Esquire Attorney I. D. #52784 27 South Arlene Street P.O. Box 6130 Harrisburg, PA 17112 (717) 671-1200 Date: June 24, 1999 I verify that the statements made in the foregoing Complaint in Custody are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. RANDY L. ALLEN Date: June 23, 1999 a?? ??, a `n ?, h 7 7 '? ?. a in .? ? ?? . __ ( i C`?- r P? _ ??-;? ?' i Ci -? _ ?? _ U? iJ RANDY L. ALLEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION-LAW VS. : NO. 99-3841 CIVIL TERM CYNTHIA A. ALLEN, Defendant IN CUSTODY " ORDER OF COURT AND NOW, this 12 f? day of .4yv5& , 1999, upon consideration of the attached Custody Concil ion Report, it is ordered and directed as follows: 1. The Father, Randy L. Allen, and the Mother, Cynthia A. Allen, shall have shared legal custody of Sebastian L. Allen, born May 4, 1994. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. The Mother shall have primary physical custody of the Child. 3. During the school year, the Father shall have partial physical custody of the Child on alternating weekends from Thursday at 5:30 p.m. through the following Monday morning when the Father shall transport the Child to school. During the interim weekends, the Father shall have custody of the Child from Thursday at 5:30 p.m. through the following Friday morning before school. The partial custody schedule set forth in this provision shall begin on Thursday, August 26, 1999 when the Father shall have custody of the Child from Thursday at 5:30 p.m. through the following morning and the Mother shall have custody of the Child during the weekend. 4. During the summer school break beginning in 2000, the parties shall equally share having custody of the Child with the specific schedule to be arranged by agreement of the parties. 5. The parties shall share or alternate having custody of the Child on holidays as follows: A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon, and Segment B, which shall run from Christmas Day at 12:00 noon through December 26 at 12:00 noon. The Mother shall have custody of the Child during Segment A in odd numbered years and during segment B in even numbered years. The Father shall have custody of the Child during Segment A in even numbered years and during Segment B in odd numbered years. B. THANKSGIVING: In every year, the Mother shall have custody of the Child on Thanksgiving Day until 1:30 p.m. and the Father shall have custody of the Child from 1:30 p.m. until the termination of his custody period under the regular schedule (either Friday morning or Monday morning.) C. EASTER &ADAY: The party who otherwise has custody of the Child over Easter Sunday under the regular custody schedule shall have custody of the Child for the holiday. D. MEMORIAL DAY/LABOR DAY: The Mother shall have custody of the Child every year over the Memorial Day holiday from Friday at 5:30 p.m. through Monday at 7:00 p.m., and the Father shall have custody of the Child every year over the Labor Day holiday from Friday at 5:30 p.m. through Monday at 7:00 p.m. E. JULY 4th: The party who otherwise has custody of the Child on July 4th under the regular custody schedule shall have custody of the Child on the holiday. F. V10THFR'S DAY/FATHER'S DAY: The Mother shall have custody of the Child every year on Mother's Day and the Father shall have custody of the Child every year on Father's Day from 9:00 a.m. until 7:00 p.m. 6. During the summer school vacation every year, each party shall be entitled to have custody of the Child for two weeks (consecutive or non-consecutive) upon providing at least sixty (60) days advance notice to the other party. 7. After following the custody schedule set forth in this order during the school year for a period of at least two (2) months, counsel for either party may contact the Conciliator to schedule an additional Custody Conciliation Conference if his or her client believes it is necessary to modify the schedule. In the event an additional Conference is necessary under this provision, neither party shall be prejudiced as to his or her position on custody due to that party's willingness to follow the schedule set forth in this order on a trial basis. 8. This order is entered pursuant to an agreement of the parties 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. cc: Jennifer L. Lehman, Esquire - Counsel for Father 04yn(?? S?i3?99 Herschel Lock, Esquire - Counsel for Mother BY THE COURT, RANDY L. ALLEN, Plaintiff VS. CYNTHIA A. ALLEN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION-LAW : NO. 99-3841 CIVIL TERM IN CUSTODY 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: Child's Name Sebastian L. Allen Date of Birth May 4, 1994 In Custody of Mother 2. A Conciliation Conference was held on August 4, 1999, with the following individuals in attendance: The Father, Randy L. Allen, with his counsel, Jennifer L. Lehman, Esquire, and the Mother, Cynthia A. Allen, with her counsel, Herschel Lock, Esquire. attached. 3. The parties agreed to entry of the order in the form as /71JG,at z / 9 9 9 tYWN?sf t./ Date Dawn S. Sunday, Esquire Custody Conciliator 3 _ g 44 4J 4-4 j AD Oad 7j?,o[o y ` ?y V j •iCi 7 H ? a s , U ? 2 ? g H i ? AUG 11 1991