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Home My WebLink About99-05311 0 h i 0 L L 0 G t Qj ynrr?tie .^Irw rx,?9pyf,i,Y.G}Ow 11{RV .]?,MYY ?9 LARRY A. MORRISON, JR., :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY,PENNSYLVANIA Plaintiff CIVIL ACTION AT LAW VS. No.. Rivil 1999 - -5& // CHEIDI W. FLOT, Defendant : CUSTODY VISITATION ORDER OF THE COURT And now, on this day of ',? , 1999, upon consideration of the attached complaint, it is hereby directed that the above parties and their respective counsel appear before ' to C C\ _Esquire, the Conciliator, at \ ? m0 Pennsylvania, on the =?J day of 1999, at \ \'.•O l7 P.M. for a Pre-hearing Custody Conference. At such conference, an efrort 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 be present at the conference. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent order. FOR THE COURT: By: I kk *n Custody Conciliator , 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 2 LIBERTY AVENUE CARLISLE, PENNSYLANIA 17013 (717) 249-3166 1.800-990-9108 .,, ... -? .., is .. a 9f ?lxq ?v( -« ?I xg? LARRY A. MORRISON, JR., :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY,PENNSYLVANIA Plaintiff vs. loo. ?- 5:3?/ ?;S1Terrn HEIDI W. FLOT, Defendant : CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, LARRY A . MORRISON, JR., by his Attorney, JAMES M. BACH, and respectfully represents as follows: 1. The Plaintiff is Larry A. Morrison, Jr., residing at 615 Williams Grove Road, Mechanicsburg, PA 17055. 2. The Defendant is Heidi W. Flot, residing at 795 Scenic Circle, New Cumberland, PA 17070. 3 . Plaintiff seeks custody of the following children: Hayden W. Flot, born on June 3, 1990. 4 . The child is presently in the custody of Heidi W. Flot, who lives at 795 Scenic Circle, New Cumberland, PA 17070. 5. The natural Mother of the children is Heidi W. Flot. 6. The natural Father of the children is Larry A. Morrison, Jr.. 7. The relationship of Plaintiff to the child is that of Father. 8. The relationship of Defendant to the child is that of Mother. 9. The Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the children in this, or any other Court. 10. Plaintiff has no information of a custody proceeding concerning the custody of said children pending in a Court of this Commonwealth, or in any other jurisdiction. 11. Plaintiff does not know of a person, not a party to the proceedings, who has physical custody of the children, or claims to have custody or visitation rights with respect to the children. 12. The best interest and permanent welfare of the children will be served by granting the relief requested, because the Plaintiff can provide a stable and wholesome home environment for the children. 13. Each parent whose parental rights of the children have not been terminated, and the person who has physical custody of the children, have been named as parties to the action. WHEREFORE, Plaintiff requests this Honorable Court to enter an Order, granting Plaintiff primary physical custody of the subject minor child. Respectfully submitted, DATE By: AMES M. BACH Attorney at Law Attorney I.D. H 18727 352 S. Sporting Hill Rd. MECHANICSBURG, PA 17055 717)737.2033 YERIFI,_ CATION I, LARRY A. MORRISON, JR. 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.44904, relating to unswom falsification to authorities. -moo-y? z. DATE YA. M RRISON, J . PLAINTIFF IT' ?1) III (?? ? 1 U.. _ i i_l I ? ??7 V 1`1 u JCL ". t c3m Lj% T Q?) U ? ? ? Q M ? H • ? } '4 I y F 'te' a < ? _ o = 1 _ 199?I?? e .I u C?" LARRY A. MORRISON, JR., Plaintiff VS. HEIDI W. FLOT, Defendant IN THE COURT Oh COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-5311 CIVIL TERM CUSTODYNISITATION ORDER AND NOW, this J i-i day of D 1999, upon receipt of the Conciliator's Report, it appearing that the parties have agreed to the terms and provisions of this Order which was dictated in their presence and approved by them, it is hereby ordered and directed as follows: 1. The parties shall share legal custody of the minor child, Hayden W. Flot, d.o.b. June 3, 1990. 2. Mother shall have primary physical custody of the minor child subject to periods of partial custody and visitation with Father as follows: A. Beginning on Saturday, October 30, 1999, from 10:00 a.m. until 7:00 p.m., and again on Sunday, October 31, 1999, from 10:00 a.m. until 7:00 p.m. B. On November 13, 1999, from 10:00 a.m. until 7:00 p.m., and again on November 14, 1999, from 10:00 a.m. until 7:00 p.m. C. Thereafter, Father shall have the child on an alternating weekend basis beginning on Friday at 6:00 p.m., and ending on Sunday at 7:00 p.m., this alternating weekend schedule to commence on November 26, 1999, and alternate thereafter. 3. After the commencement of the alternating weekend schedule, Father shall also be entitled to have periods of visitation with the child on the Wednesday following the weekend visitation from after school until 7:00 p.m. If it appears that this time conflicts with the child's extra-curricular activities such that Father cannot have this period of time, the parties shall ensure that the Father shall be entitled to one evening to have periods of partial custody and visitation as agreed upon. 4. The parties shall alternate the major holidays, those holidays being defined as Thanksgiving, Easter, Memorial Day, Fourth of July, and Labor Day. These periods of partial custody shall be from 10:00 a.m. until 7:00 p.m. This alternating holiday schedule shall commence with Mother having Thanksgiving in 1999. 5. Christmas shall be broken into two segments. Segment A shall be from Christmas Eve at 12:00 p.m., until Christmas Day at 2:00 p.m. Segment B shall be from Christmas Day at 2:00 p.m., until December 26'h at 7:00 p.m. Father shall have Segment A in 1999 and all odd years thereafter and Segment B in 2000 and all even years thereafter. Mother shall have Segment A in 2000 and all even years thereafter and Segment B in 1999 and all odd years thereafter. 6. The parties shall also split the remainder of the Christmas Holiday when the child is off from school. In 1999, Father shall have the child Wednesday, December 29'h at 12:00 p.m. until January 1"at 7:00 p.m. In future years, the parties shall evenly share those days as agreed upon. 7. Mother shall have the child on Mother's Day and Father shall have the child on Father's Day. These periods of partial custody and visitation shall be from 10:00 a.m. until 7:00 p.m. 8. Each party is entitled to one uninterrupted week of vacation in the months of June, July and August with the child. The parties shall provide each other with at least thirty (30) days advance notice of the weeks in which they intend to exercise these periods of exclusive custody. 9. Such other times as the parties may agree. BY THE COURT, J. James M. Bach, Esquire 1"A19 ?- Ms. Heidi W. Flot, pro se .'j• ap• mlb Sit""-? f',?!2:n LARRY A. MORRISON, JR., ) Plaintiff ) VS. ) ) HEIDI W. FLOT, ) Defendant ) JUDGE PREVIOUSLY ASSIGNED: None IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-5311 CIVIL TERM CUSTODYNISITATION CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child(ren) who is(are) the subject of this litigation is as follows: NAME BIRTHDATE CURRENTLY IN CUSTODY OF Hayden W. Flot June 3, 1990 Defendant 2. A Conciliation Conference was held on October 28, 1999, and the following individuals were present: the Plaintiff and his attorney, James M. Bach, Esquire; the Defendant appeared pro se. 3. Items resolved by agreement: See attached Order. 4. Issues yet to be resolved: See attached Order. 5. The Plaintiffs position on custody is as follows: See attached Order. 6. The Defendant's position on custody is as follows: See attached Order. 7. Need for separate counsel to represent child(ren): Neither party requested. 8. Need for independent psychological evaluation or counseling: None requested and the Conciliator does not believe any is necessary. Date: November 2, 1999 Mic ael L. 13angs Custody Conciliator