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HomeMy WebLinkAbout99-06839h i L' 1 ?I Oo %,5i I U - 1) s < Cr. W Q NO J n, ).1 1 I, r r r.. 1 Y a r I ?) s l \ t 1 t4 1 )) { ! i I 1 _ + j 1 \ I 1 1 4 r , , + r t In i / 1 F O F , I I C I S 1 tin: 1 t JERIL G. BOSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 99-6839 CIVIL TERM : NO. 99-31 AMANDA LAWHON, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 0A day of , 2000, upon consideration of the attached Custody oncilia 'on Report, it is ordered and directed as follows: 1. The prior Order of this Court dated June 18, 1999 is vacated and replaced with this order. 2. The Father, Jeril G. Boson, and the Mother, Amanda Lawhon, shall have shared legal custody of Alexander P. Boson, born May 29, 1998, and Hailee Kaylynn Boson, born August 24, 1999. 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. Pursuant to the terms of this paragraph, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical and educational records and information. Each party shall ensure that the Children receive necessary medical treatment, including immunizations, when the Children are in that party's custody. 3. The parties shall share having physical custody of the Children on an equal basis in accordance with the following schedule: A. In even numbered years, the Mother shall have custody of the Children during the months of January, February, March, July, August, November and December and the Father shall have custody of the Children during the months of April, May, June, September and October. B. In odd numbered years, the Mother shall have custody of the Children during the months of April, May, June, September and October and the Father shall have custody of the Children during the months of January, February, March, July, August, November and December. C. The shared custody schedule set forth above shall be effective with respect to Alexander immediately, with the Mother having I. custody of Alexander until April It 2000 when the rather shall obtain custody. The Father's first period of custody with Hailee under the shared custody schedule shall not begin until September 1, 2000 due to the Child's young age. Thereafter, the custody schedule set forth above shall apply to Hailee as j well for all exchanges of custody. D. The non-custodial parent may have custody of the Children as arranged by agreement of the parties in the event he or she travels to the state in which the other party's residence is located. 4. The party receiving custody shall be responsible to provide transportation for the exchange of custody. 5. The parties agree that custody over holidays shall be determined by the regular custody schedule. 6. Each party shall ensure that the other party has his or her current address and telephone number. 7. The parties agree that this Court shall retain jurisdiction of this custody matter. 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. BY THE COURT i Edward E. Guido J. ?» J1' 1-1,3-OD cc: Peter B. Foster, Esquire - Counsel for Father RKS Maryann Murphy, Esquire - Counsel for Mother OJ 13 A,tl 9:n7 iY JERIL G. BOSON, Plaintiff VS. AMANDA LAWHON, Defendant PRIOR JUDGE: Edward E. Guido CUSTODY IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 99-6839 CIVIL TERM : NO. 99-31 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY 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 Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Alexander P. Boson May 29, 1998 Father Hailee Kaylynn Boson August 24, 1999 Mother 2. A Custody Conciliation Conference was held on January 4, 2000, with the following individuals in attendance: The Father, Jeril G. Boson, with his counsel, Peter B. Foster, Esquire, and the Mother, Amanda Lawhon, with her counsel, Maryann Murphy, Esquire. 3. The parties agreed to entry of an Order in the form as attached. 4. It should be noted that previously a custody action had been initiated by the Father under docket number 99-31 pertaining to the parties' Child Alexander. After the birth of the parties' second Child, an additional action was filed at docket number 99-6839. Counsel for the parties agreed at the Conference to have these matters consolidated so that this Order would set forth custody arrangements for both Children. Date 61 Dawn S. Sunday, Esquire' Custody Conciliator SPHON9 1717) 234-9911 IA%- (717):.. 934.79912: JERIL G. BOSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PE.N/NSYLVANIA VS. NO. ?;'a Z.1553! AMANDA LAWHON, CIVIL ACTION - LAW Defendant IN CUSTODY ORDER AND NOW, this 14 day of November, 1999, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before ,, I e conciliator, at tAc(?ioc c_Mj; 1, t'l\ , Cumberland County, Pennsylvania, on the day of J]t\\ W0?- 44-at 3 -U? P.M-, for a Pre-IIearing 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. Either may bring the child who is the subject of this custody action to the conference, but the child's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent Order. BY THE COURT: By .?? t1G+? ?? ??t tYYfSls C - custody Conciliator (? ., r-r ,.. ;i..^.. ? 1 }',1 ? p? r,'. ; - 1 ? r. l I .I?l V ?.1 i ? ? ?, n??r99a ,,..,/u/?c J /r as ? ? CFf? ,«??? f ?? ?.,...lJ } ., ,; v. r 1 ' v JERIL G. BOSON, IN THE COURT OF COMMON PLEAS OF Plaintiff' CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. q,?. 6 e S,9 ?Un c i. AMANDA LAWHON, CIVIL ACTION - LAW Defendant IN CUSTODY COMPLAINT FOR CUSTODY Plaintiff is Jeril G. Boson, an adult individual currently residing at 3548 Green Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Amanda Lawhon, an adult individual currently residing at Apt. 326 102 W. Iiigh Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are natural parents of Hailee Kaylynn Boson, born August 24, 1999. 4. The child was born out of wedlock. 5. Since the child's birth, the child has resided with the following individuals at the following addresses for the following periods of time. Name Jeril G. Boson Address 3548 Green St. Camp Hill, PA 17011 Date August 24, 1999 to present Alexander P. Boson (parties' child) Name Address Date Bonnie Boson (Plaintiff's Mother) Amanda Lawhon Alexander P. Boson (parties' child) 6. single. 7. is single. 8. 102 W. High St. Apt. 326 Carlisle, PA 17013 August 24, 1999 to present The natural father of the child is leril G. Boson, who resides as aforesaid. Fie is The natural mother of the child is Amanda Lawhon, who resides as aforesaid. She The relationship of the Plaintiff to the child is that of natural father. Plaintiff currently resides with his mother and his older child, Alexander P. Boson, who is an older child of the parties. 9. The relationship of the Defendant to that of the child is that of natural mother. Defendant currently resides with Alexander P. Boson, an older child of the parties. 10. Plaintiff has not participated as a party or witness or in any other capacity in any litigation concerning custody of the child. 11. Plaintiff has no information of any custody proceedings concerning the child pending in any Court of this Commonwealth. 12. The best interest and permanent welfare of the child will be served by granting the relief requested because: a) Plaintiff' has provided the child with her only mental, emotional and physical stability; and b) Plaintiff is able to provide a better and more stable home and home atmosphere. 13. Plaintiff does not know any person not a party to these proceedings who claims to have custody or visitation rights with respect to the child. W[[EREFORE, Plaintiff requests your I lonorable Court to schedule a Custody Conciliation Conference followed by a hearing, at which time he should be granted primary physical custody of the child. November 10, 1999 Respectfully submitted, Peter B. Foster, Esquire PINSKEY & FOSTER 121 South Street I Iarrisburg, PA 17101 (717) 234-9321 Fax: (717) 234-7832 e VERIFICATION I verify that the statements made in the foregoing custody complaint are true and correct. I understand that false statements herein made are subject to the penalties of IS Pa. C.S. § 4904 relative to unsworn falsification to authorities. November 10, 1999 /Jell G. Boson ?J C t ON PLEAS OF JERIL G. BOSON, IN THE COURT OF COMM CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 99-31 CIVIL TERM VS. AMANDA LAWHON, Defendant CIVIL ACTION -LAW JERIL G. BOSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY,PENNSYLVANIA NO. 99-6839 CIVIL TERM VS. AMANDA LAWHON, Defendant CIVIL ACTION -LAW ORDER AND NOW, this 8T day of January, 2000 upon consideration of the Parties' Joint Motion for Consolidation, IT IS HEREBY ORDERED that the above-captioned civil actions are consolidated. BY THE R ?s J ? lU ?vv c? t i _,,.. , ll •I l? ? NO, 99-31 CIVIL TERM VS. AMANDA LAWHON, Defendant JERIL G. BOSON, Plaintiff CIVIL ACTION - LAW IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6839 CIVIL TERM VS. AMANDA LAWHON, Defendant CIVIL ACTION - LAW JOINT MOTION FOR CONSOLIDATION OF ACTION AND NOW, this 6th day of January, 2000, come the parties, Jeril G. Boson and Amanda Lawhon, by their respective attorneys request consolidation of these actions and, in support thereof, aver as follows: 1. Jeril G. Boson filed the Custody Complaint for the parties' minor child, Alexander P. Boson, d.o.b. May 29, 1998, on January 5, 1999 at Civil Action No. 99-31. 2, The parties agreed upon custody for said child and a custody Order pursuant to stipulation was entered. Said Order is attached hereto as Exhibit "A". 3, On November 10, 1999 Jeril G. Boson filed a Custody Complaint for the parties' minor child, Hailee Kaylynn Boson, d.o.b. August 24, 1999, at Civil Action No. 99-6839. 4, On January 4, 2000, the parties agreed on a custody arrangement for both children.