Loading...
HomeMy WebLinkAbout07-5546LAWRENCE G. LANTZ, Plaintiff, vs. EVELYN T. LANTZ, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 07 - 55?ta Civ.'( Term : CIVIL ACTION - LAW : IN DIVORCE N O T I C E TO DEFEND AND CLAIM RIGHTS 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 any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other 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 Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania 17013. 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 YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 LAWRENCE G. LANTZ, Plaintiff, vs. EVELYN T. LANTZ, Defendant. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA NO. CIVIL ACTION - LAW IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with § 3302(d) of the Divorce Code, you may request the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania 17013. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be bome by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. 9 of 9 KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQ. ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 (beam@kopelaw.com LAWRENCE G. LANTZ, Plaintiff, vs. EVELYN T. LANTZ, Defendant. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA : NO. 0-7- SSy(' ? CIVIL ACTION -LAW IN DIVORCE AND CUSTODY COMPLAINT IN DIVORCE AND CUSTODY AND NOW comes the above-named Plaintiff, LAWRENCE G. LANTZ, by and through his attorney, LESLEY J. BEAM, ESQ., and makes the following Complaint in Divorce and Custody: 1. The Plaintiff is LAWRENCE G. LANTZ, an adult individual who currently resides at 10 Thyme Court, Mechanicsburg, Cumberland County, Pennsylvania 17050. All legal papers may be served on Plaintiff through his counsel at 4660 Trindle Road, Suite 201, Camp Hill, Pennsylvania 17011. 2. The Defendant is EVELYN T. LANTZ, an adult individual who currently resides at 10 Thyme Court, Mechanicsburg, Cumberland County, Pennsylvania 17050. Defendant is expected to be relocating from the marital residence shortly. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on March 11, 1987, in Santa Ana, Orange County, California. 5. The Parties separated on or about August 24, 2007 when Plaintiff confronted Defendant on her extramarital affair and Defendant informed Plaintiff of her desire to end the marriage and move out of the marital residence. 6. Neither Plaintiff nor Defendant has been in military service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 8. Plaintiff has been advised of the availability of marriage counseling and the right to request that the Court require the parties to participate in counseling. CO_UNT_I REQUEST FOR A NO-FAULT DIVORCE UNDER § 3301(c) OF THE DIVORCE CODE 9. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 10. The marriage of the parties is irretrievably broken. 2 of 9 WHEREFORE, if both parties file affidavits consenting to a divorce after (90) ninety days have elapsed from the date of service of this Complaint, Plaintiff respectfully requests that the Court enter a Decree of Divorce pursuant to § 3301(c) of the Divorce Code. COUNT II REQUEST FOR A NO-FAULT DIVORCE UNDER § 3301(d) OF THE DIVORCE CODE 11. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 12. The marriage of the parties is irretrievably broken. 13. The parties are living separate and apart within the marital residence, will continue to do so, and at the appropriate time Plaintiff will submit an affidavit alleging that the Parties have lived separate and apart for at least two (2) years as specified in § 3301(d) of the Divorce Code. WHEREFORE, Plaintiff respectfully requests that the Court enter a Decree of Divorce pursuant to § 3301(d) of the Divorce Code. COUNT III REQUEST FOR A FAULT DIVORCE UNDER § 3301(a)(2) OF THE DIVORCE CODE 14. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 15. Defendant has committed adultery. 16. This action is not collusive as defined by § 3309 of the Divorce Code. 3 of 9 WHEREFORE, Plaintiff respectfully requests that the Court enter a Decree of Divorce pursuant to § 3301(a)(2) of the Divorce Code. COUNT IV REQUEST FOR A FAULT DIVORCE UNDER § 3301(x)(6) OF THE DIVORCE CODE 17. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 18. Defendant has offered such indignities to Plaintiff, who is the innocent and injured spouse, so as to render Plaintiff's condition intolerable and life burdensome. 19. This action is not collusive as defined by § 3309 of the Divorce Code. WHEREFORE, Plaintiff respectfully requests that the Court enter a Decree of Divorce pursuant to § 3301(a) (6) of the Divorce Code. COUNT V REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER § 3502(a) OF THE DIVORCE CODE 20. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 21. Plaintiff and Defendant have acquired marital property as defined by the Divorce Code, which is subject to equitable distribution pursuant to § 3502(a) of the Divorce Code. 4 of 9 22. Plaintiff and Defendant have been unable to agree to the equitable distribution of said property, as of the date of filing of this Complaint. 23. Plaintiff requests that the Court equitably divide, distribute, or assign the marital property between the parties. WHEREFORE, Plaintiff respectfully requests that the Court enter an order of equitable distribution of marital property pursuant to § 3502(a) of the Divorce Code. COUNT VI REQUEST FOR CONFIRMATION OF CUSTODY UNDER fi$ 3104(a)(2) AND 3323(b) OF THE DIVORCE CODE 24. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 25. The parties are the parents of the following unemancipated children who reside with Plaintiff and Defendant at the current time, though Defendant intends to relocate shortly: NAME AGE SEX D.O.B. Rebecca Lantz 13 years old Female 8/17/1994 Victoria Lantz 8 years old Female 9/28/1998 26. During the past five years, the children have resided with the following persons and at the following addresses: 5 of 9 PERSONS ADDRESSES DATES Lawrence G. Lantz Evelyn T. Lantz 110 Thyme Court Mechanicsburg, PA 17050 July 2003 - Present Lawrence G. Lantz Evelyn T. Lantz 100 Water Street Landisburg, PA 17040 1996 - July 2003 27. 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 another court. 28. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. 29. Plaintiff does not know of a person not a party to these proceedings who has physical custody of the children or who claims to have custody, partial custody or visitation rights with respect to the children. 19. The best interests and permanent welfare of the children will be served by granting the requested relief. WHEREFORE, Plaintiff respectfully requests that pursuant to §§ 3104(a)(2) and 3323(b) of the Divorce Code, the Court enter an Order awarding Plaintiff shared legal custody and primary physical custody of the children. Respectfully Submitted, KOPE & ASSOCIATES Date: J. rj, Esq. 6of9 . • 'ELP-11-2007 06:29P FROM:LANTZ 717C691C1803 TO:7617572 P.18 i, Lawrence G. Lentz, the Plaintlff in this rustler, Nave read the foregoing CompWnt I vwffy that my ave nmb In this ComplaW are his and =red and based upon my pereonst WoMedge. i understand that any Use skkw e * henein are made subject 10 the penalties of 18 Pa. C.S. 4904 relating ID unavom falsificadons to Darted: A - ?/ - o? ?W Q OT JUT antra cm i trwicmw v 'a„rA 71RJ-T9L-LTL Lb:9i LBez/TT/5e ...( "€ -0 c = cn r- # c Z 0 00 ?_ f .. ° c, s D C) = (z f o : c: T IV !t (?r KOPE $ ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQUIRE ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam9i)-koyelaw.com Attorney for Plaintiff LAWRENCE G. LANTZ, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PA vs. NO. b ?• SSG EVELYN T. LANTZ, : CIVIL ACTION - LAW Defendant. : IN CUSTODY CUSTODY COMPLAINT 1. The Plaintiff is Lawrence G. Lantz, residing at 10 Thyme Court, Mechanicsburg, Cumberland County, Pennsylvania 17050 (hereinafter "Plaintiff" or "Father"). All legal papers may be served on Plaintiff through his attorney at 4660 Trindle Road, Suite 201, Camp Hill, Pennsylvania 17011. 2. The Defendant is Evelyn T. Lantz, currently residing at 10 Thyme Court, Mechanicsburg, Cumberland County, Pennsylvania 17050 (hereinafter 3. NAME "Defendant" or "Mother"). Defendant is expected to be relocating shortly., Plaintiff seeks primary physical and shared legal custody of the following children: Rebecca Lantz Victoria Lantz PRESENT RESIDENCE 10 Thyme Court Mechanicsburg, PA 10 Thyme Court Mechanicsburg, PA AGE 13 years old D.O.B. 8/17/1994 8 years old D.O.B. 9/28/1998 4. Rebecca Lantz and Victoria Lantz (hereinafter the "children°) were born in wedlock. 5. The children are presently residing with Plaintiff and Defendant at 10 Thyme Court, Mechanicsburg, Cumberland County, Pennsylvania 17050. Plaintiff has filed for divorce and Defendant intends to vacate the marital home. 6. During the past five years, the children have resided with the following persons and at the following addresses: PERSONS ADDRESSES DATES Lawrence G. Lantz 110 Thyme Court July 2003 - Present Evelyn T. Lantz Mechanicsburg, PA 17050 Lawrence G. Lantz 100 Water Street 1996 - July 2003 Evelyn T. Lantz Landisburg, PA 17040 7. The mother of the children is Evelyn T. Lantz, residing at 10 Thyme Court, Mechanicsburg, Cumberland County, Pennsylvania 17050. She is married but separated. 8. 9. 10. The father of the children is Lawrence G. Lantz, residing at 10 Thyme Court, Mechanicsburg, Cumberland County, Pennsylvania 17050. He is married but separated. The relationship of Plaintiff to the children is that of Father. Father currently resides with Mother and the children, but is expecting Mother to relocate shortly. The relationship of Defendant to the children is that of Mother. Mother currently resides with Father and the children, but will be relocating shortly. 11. Plaintiff has not participated as a party in previous litigation concerning the custody of the children. 12. Plaintiff does not know of a person not a party to the proceeding who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 13. Plaintiff is requesting shared legal and primary physical custody of the children subject to partial custody and/or visitation by Defendant. 14. The best interest and permanent welfare of the children will be served by the granting relief requested because: (a) The children have lived with their Father and Mother in the family home since 2003. Remaining primarily in the home to which the children have become accustomed will provide the children with a sense of stability, safety, and structure that will be even more important as the parties seek a divorce; (b) Father has been the primary parent of the children for the majority of their lives. Specifically, Father is the primary foster parent of special needs foster children, and as such, he works at the home; (c) As a consequence of Father's occupation, he is home during the day and can provide constant and better supervision; (d) Because Father is a primary foster parent, he cares for foster children who live at the family residence and have developed relationships with the children. It would be in the children's best interests to be able to continue these relationships with other children who have played an important role in their lives; (e) Mother has recently become involved in a relationship and has been leaving the children and the home for extensive periods of time, despite the pleas of the children to leave said relationship. (f) Mother has been lying to the children and Father regarding her whereabouts, as a result of her pursuit of this extramarital relationship, and leaving the children unattended when she has promised to watch them. As a consequence, Mother is not a responsible or reliable parent who can be trusted to put the needs of her children before her own selfish pursuits. To the contrary, Father devotes himself to raising these children; (g) Father is able to provide a stable home and emotional environment for the children, and has done such for the children for years; and (h) Father has the facilities to provide for the care, comfort and control of the children, as well as the intention and desire to do so. Father will continue to provide such to the children for their care, comfort and control. 15. Each parent whose parental rights to the children have not been terminated and the persons who have physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff requests that this Honorable Court award Plaintiff primary physical and shared legal custody of the children. Respectfully Submitted, KOPE & ASSOCIATES Dated: - o t26- By: Lesley ebam, Esq. . 'EtP-11-2007 06:26P FROM:LANTZ 717C691C1803 TO:7617572 P.8 1. UN Mr" G. Uw&, the PWnVff In Oft rrradw. have rasa! the lbrepoinp Complaint. 1 verify that my evements in this Conoo t we We mW am, and besed upon my poraonai knoNdedp. 1 undarstsnd that any false debunwft haWn am made subject to the penafts of 18 Pa. C.S. 4904 raloWV tD unswom fal s to ems. Dated: 9 -1/- 0.7 as G. 7 of 9 RTJ#pp -*Yd.a ."I d w -L-Ir d ZLSL-191-4LTL Lv:9T LB@t1T1166 "' rvi IL LAWRENCE G. LANTZ IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 2007-5546 CIVIL ACTION LAW EVELYN T. LANTZ IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, September 25, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, October 09, 2007 at 3:00 PM 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 pennanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ ohn . M r. Es . 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ? ?d ?.? ass ?aaZ 0n -413?? v OCT 122007r? LAWRENCE G. LANTZ IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 07-5546 Civil Term EVELYN T. LANTZ Defendant : ACTION IN CUSTODY COURT ORDER AND NOW, this /4 day of October, 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: Legal Custody: The Father, Lawrence G. Lantz, and the Mother, Evelyn T. Lantz, shall enjoy shared legal custody of the minor Children, Rebecca Lantz, born 8/17/94, and Victoria Lantz, born 9/28/98. The parties 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 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody: The Father shall have primary physical custody of the Children subject to Mother's partial physical custody as follows. Mother shall have physical custody of the Children every Friday from 4:00 pm,until 9:00 pm. and every Sunday from 10:00 am. until 8:00 pm. The parties may alter/expand Mother's physical custody by mutual agreement. 3. Exchanges: The non-custodial parent shall pick the Children up at the other parent's residence, unless the parties mutually agree to an alternate location. 4. The non-custodial parent shall be entitled to have reasonable liberal telephone contact with the Children. 5. In the event of a medical emergency, the custodial party shall notify the other parties as soon as practicable after the emergency is handled. 91 '01 WV L 1 130 LODZ , ? C3i` f` s i1`„ cl '3}- i JO 6. Neither parry may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. 7. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 8. During periods of physical custody, the parties understand that each parent is encouraged to maximize their respective time with the Children without involving third parties. It is further understood that the best interest of the Children would be best served by the parties' consideration of the Children's comfort level regarding third parties. 9. Holidays: Father shall have physical custody of the Children for Thanksgiving and on Christmas Eve through Christmas Day at noon. Mother shall have physical custody of the Children from noon on Christmas Day until 9:00 pm. The parties shall split the Christmas school break as mutually agreed upon. All other major holidays and the Children's birthdays shall be alternated and arranged as mutually agreed upon. 10. This Order is entered pursuant to 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. Counsel for the parties are directed to contact the assigned Conciliator to schedule a status update to ascertain whether overnight physical custody with Mother would be appropriate. BY J. Cc: ley Beam, Esq., 4660 Trindle Rd., Ste 20y, Camp Hill, PA 17011 Mira Boyanowski, Esq., 2080 Linglestown , Ste 201, Harrisburg, PA 17110 ,,Ahn J. Mangan, Esq. 'o'ff \r LAWRENCE G. LANTZ Plaintiff V. EVELYN T. LANTZ Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 07-5546 Civil Term : ACTION IN CUSTODY CONCILIATION CONFERENCE SUNEVIARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(B), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Rebecca Lantz 8/17/94 Father Victoria Lantz 9/28/98 Father 2. A Conciliation Conference was held on October 9, 2007 with the following individuals in attendance: The Father, Lawrence G. Lantz, with his counsel, Lesley Beam, Esquire The Mother, Evelyn T. Lantz, with her counsel, Cara Boyanowski, Esquire 3. The parties agreed to the entry of an Order in the form as attached. Date: 7 l John gan, Esquire Cust dy onciliator Cara A. Boyanowski, Esquire Pa. Supreme Court ID No. 68736 Serratelli, Schiffman, Brown and Calhoon, P.C. 2080 Linglestown Road Suite 201 Harrisburg, Pennsylvania 17110 Telephone (717) 540-9170 Fax (717) 540-5481 Attorney For Defendant LAWRENCE G. LANTZ, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-5546 CIVIL TERM EVELYN T. LANTZ, CIVIL ACTION - LAW Defendant IN DIVORCE DDar. r+TDV Please enter the appearance of Cara A. Boyanowski, Esquire, as attorney for the Defendant in the above-captioned matter. Dated: 0Aa(ah)40",?- Cara A. Boyano ski, Esquire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 C'? ? C7 L? ? --r1 -?? S,?"" = } C _ : ? .?"? ? ? . Fm 27 aoos LAWRENCE G. LANTZ : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 07-5546 Civil Term EVELYN T. LANTZ Defendant : ACTION IN CUSTODY Prior Judge: Kevin A. Hess, J. COURT ORDER AND NOW, this Z' day of 1 , 2008, upon consideration of the attached Custody Conciliation Report, it is ord red and directed that: 1. The prior Order of Court dated October 16, 2007 is hereby VACATED. 2. Legal Custody: The Father, Lawrence G. Lantz, and the Mother, Evelyn T. Lantz, shall enjoy shared legal custody of the minor Children, Rebecca Lantz, born 8/17/94, and Victoria Lantz, born 9/28/98. The parties 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 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 3. Physical Custody: The Father shall have primary physical custody of the Children subject to Mother's partial physical custody as follows: a. Commencing 2/22/08, Mother shall have physical custody of the Children every other weekend from Friday 5:00 pm until Monday morning whereby Mother shall drop off Rebecca Lantz at school and Victoria Lantz off at Father's residence. b. Mother shall have additional periods of overnights or evenings during the week (Monday through Friday) as the parties may mutually agree. 4. Exchanges: The parties shall mutually agree to the share the transportation and mutually agree to the exchange locations, except as outlined in paragraph 3 (a). 5. The non-custodial parent shall be entitled to have reasonable liberal telephone contact with the Children. 1 ,j So :9 14 C- Ow HE i i w 3H. 10 6. In the event of a medical emergency, the custodial party shall notify the other parties as soon as practicable after the emergency is handled. 7. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other parry, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. 8. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 9. Holidays: All major holidays and the Children's birthdays shall be alternated and arranged as mutually agreed upon. 10. Each parent shall have two non-consecutive weeks of vacation with the Children per year. The requesting parent shall give the other parent 30 days advance notice of the requested time and this vacation week shall supersede the regular physical custody schedule. In the event the parties schedule conflicting vacations, the party first providing written notice shall have the choice of vacation. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. 11. This Order is entered pursuant to 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, W' J. Cc: -/Lesley Beam, Esq., 4660 Trindle Rd., Ste 2Z ."Camp Camp Hill, PA 17011 ?Cara Boyanowski, Esq., 2080 Linglestown d., Ste 201, Harrisburg, PA 17110 ?John J. Mangan, Esq. CC? 1 EG rna t LPL 3! 310 $ LAWRENCE G. LANTZ Plaintiff V. EVELYN T. LANTZ Defendant Prior Judge: Kevin A. Hess, J. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 07-5546 Civil Term : ACTION IN CUSTODY CONCILIATION CONFERENCE SUNIlK"Y REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(B), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Rebecca Lantz 8/17/94 Father Victoria Lantz 9/28/98 Father 2. An Order of Court was entered in this matter on October 16, 2007 and an updated conciliation conference was held on February 14, 2008 regarding Mother having overnights with the minor Children with the following individuals in attendance: The Father, Lawrence G. Lantz, with his counsel, Lesley Beam, Esquire The Mother, Evelyn T. Lantz, with her counsel, Cara Boyanowski, Esquire 3. The parties agreed to the entry of an Order in the form as attached. Date: = Z. Jo ix $ J. angan, Esquire to y Conciliator 7 KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQUIRE ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 (beam kopelaw.com Attorney for Plaintiff LAWRENCE G. LANTZ, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PA vs. NO. 2007-5546 EVELYN T. LANTZ, CIVIL ACTION - LAW Defendant. IN DIVORCE ACCEPTANCE OF SERVICE I, Cara A. Boyanowski, Esq. attorney for the Defendant in the above-captioned matter, hereby accepts service of the Complaint in Divorce. Date: 18 - 10 - 0-4 OIAUQ"' Cara A. Boyano ki, Esq. crT .C 4 ?. Cara A. Boyanowski, Esquire Supreme Court I.D. No. 68736 SERRATELLI SCHIFFMAN BROWN & CALHOON 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 - telephone (717) 540-5481 -facsimile cboyanowskiC ssbc-law.com Attorney for Defendant, Evelyn Teresa Lantz LAWRENCE G. LANTZ, Plaintiff/Petitioner V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO. 07-5546 Civil Term EVELYN T. LANTZ, Defendant/Respondent : CIVIL ACTION - LAW : IN CUSTODY/VISITATION PETITION FOR MODIFICATION OF CUSTODY ORDER AND NOW, comes Defendant/Petitioner Evelyn T. Lantz, by and through her counsel, Cara A. Boyanowski, Esquire, and respectfully represents: 1. The Defendant/Petitioner is Evelyn T. Lantz, an adult individual who resides at 2303 Warren Way, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Plaintiff/Respondent is Lawrence G. Lantz, an adult individual who resides at 10 Thyme Court, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. The parties are the natural parents of two minor children, namely, Rebecca Lantz, born August 17, 1994, and Victoria Lantz, born September 28, 1998. 4. On February 9, 2008, the Honorable Kevin A. Hess entered an Order of Court whereby, Defendant/Petitioner and Plaintiff/Respondent were awarded shared legal custody of both of their minor children, Plaintiff/Respondent was awarded primary physical custody of the minor children, and Defendant/Petitioner was awarded periods of partial physical custody of the minor children as follows: A. Alternating weekends from Friday at 5:00 p.m. through Monday morning, with a return to school; and B. Additional periods of overnights or evenings during the week (Monday through Friday) as the parties may mutually agree. A copy of the Order of Court dated February 29, 2008 is attached hereto and incorporated herein as Exhibit "A." At the custody conciliation conference held on February 14, 2008, Plaintiff/Respondent was reluctant to incorporate any specific overnight periods (during the work week) into the current custody order, stating he was unsure what the children would want, whether Defendant/Petitioner would be able to get the children to school on time due to her work schedule, etc. It was therefore agreed that the parties would mutually work out the details on this issue between themselves. 6. Since the entrance of the February 29, 2008 Order of Court, Defendant/Petitioner has exercised physical custody on all of her alternating weekend periods of custody. 7. Since the entrance of the February 29, 2008 Order of Court, Defendant/Petitioner has exercised at least two overnight periods with the minor children each work week without experiencing any difficulties getting them to school on time. Since the entrance of the February 29, 2008 Order of Court, Defendant/Petitioner has relocated to a residence which is in the same school district as Plaintiff/Respondent and is approximately five (5) miles away from his residence. 9. Since the entrance of the February 29, 2008 Order of Court, the children have routinely expressed their desire to spend more time with Defendant/Petitioner, most recently, expressing their desire to live primarily with her. 10. Based upon the above information, Defendant/Petitioner wishes for the entrance of an Order of Court awarding her primary physical custody of her two minor children. WHEREFORE, Defendant/Petitioner, Evelyn T. Lantz, respectfully requests this Honorable Court modify the existing custody Order of Court to award her primary physical custody of the two minor children, Rebecca Lantz and Victoria Lantz. Respectfully submitted, SERRATELLI SCHIFFMAN BROWN & CALHOON oiffinwo" Cara A. Boyanows i, Esquire Supreme Court I.D. No. 68763 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Defendant/Petitioner VERIFICATION Upon my personal knowledge, information and belief, I, Evelyn T. Lantz, do hereby verify that the facts averred and statements made in the foregoing Petition are true and correct. I understand that false statements or averments therein made will subject me to the criminal penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: - - B ? CliZ Y• Evelyn T. Lantz ??,??b'? FEes72008 0' LAWRENCE G. LANTZ : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 07-5546 Civil Term EVELYN T. LANTZ Defendant : ACTION IN CUSTODY Prior Judge: Kevin A. Hess, J. COURT.ORDER AND NOW, this,94kday of 2008, upon consideration of the attached Custody Conciliation Report, it is ordere and directed that: 1. The prior Order of Court dated October 16, 2007 is hereby VACATED. 2. Legal Custody: The Father, Lawrence G. Lantz, and the Mother, Evelyn T. Lantz, shall enjoy shared legal custody of the minor Children, Rebecca Lantz, born 8/17/94, and Victoria Lantz, born 9/28/98. The parties 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 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 3. Physical Custody: The Father shall have primary physical custody of the Children subject to Mother's partial physical custody as follows: a. Commencing 2/22/08, Mother shall have physical custody of the Children every other weekend from Friday 5:00 pm until Monday morning whereby Mother shall drop off Rebecca Lantz at school and Victoria Lantz off at Father's residence. b. Mother shall have additional periods of overnights or evenings during the week (Monday through Friday) as the parties may mutually agree. 4. Exchanges: The parties shall mutually agree to the share the transportation and mutually agree to the exchange locations, except as outlined in paragraph 3 (a). 5. The non-custodial parent shall be entitled to have reasonable liberal telephone contact with the Children. V. In he event of a medical emergency, the custodial party shall notify the other parties as soon as practicable after the emergency is handled. 7. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. 11. This Order is entered pursuant to 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. Cc: Lesley Beam, Esq., 4660 Trindle Rd., Ste 201, Camp Hill, PA 17011 Cara Boyanowski, Esq., 2080 Linglestown Rd., Ste 201, Harrisburg, PA 17110 John J. Mangan, Esq. "$ io i 6 p Unto set mv '111d t 01 ids ow fit Cuti?at?, pt I hit. t 0.0 1 Irl r ?:d Q a 1:00 0?_' r- -,J tho"Itli 8. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consumelbe under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 9. Holidays: All major holidays and the Children's birthdays shall be alternated and arranged as mutually agreed upon. 10. Each parent shall have two non-consecutive weeks of vacation with the Children per year. The requesting parent shall give the other parent 30 days advance notice of the requested time and this vacation week shall supersede the regular physical custody schedule. In the event the parties schedule conflicting vacations, the parry first providing written notice shall have the choice of vacation. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. LAWRENCE G. LANTZ Plaintiff V. EVELYN T. LANTZ Defendant Prior Judge: Kevin A. Hess, J. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 07-5546 Civil Term : ACTION IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(B), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Rebecca Lantz 8/17/94 Father Victoria Lantz 9/28/98 Father 2. An Order of Court was entered in this matter on October 16, 2007 and an updated conciliation conference was held on February 14, 2008 regarding Mother having overnights with the minor Children with the following individuals in attendance: The Father, Lawrence G. Lantz, with his counsel, Lesley Beam, Esquire The Mother, Evelyn T. Lantz, with her counsel, Cara Boyanowski, Esquire 3. The parties agreed to the entry of an Order in the form as attached. Date: ^.. -Z Jo J. angan, Esquire to y Conciliator C,4s 6. td CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of Defendant's Petition for Modification of Custody Order upon all interested parties, via first-class United States mail, addressed as follows: Lesley J. Beam, Esquire KOPE & ASSOCIATES, LLC 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 Respectfully submitted, SERRATELLI SCHIFFMAN BROWN & CALHOON Cara A. Boyanows i, Esquire Supreme Court I.D. No. 68736 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Defendant Date: Z- 6- ?-OOq O .races t.t5 F ..? -1"1 ? HIP .7 t LAWRENCE G. LANTZ IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2007-5546 CIVIL ACTION LAW EVELYN T. LANTZ IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Monday, February 09, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, March 18, 2009 at 2:00 PM 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. 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 any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: ls/ John . Man an r. Es . 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 '49%*O?4W * -4 a ?,, r ? ?? py 0r w` V1'9 ern AT 1t6 ("?Y"?{ t [ 44,E-Y? oS -.l Wd 6r 83J60U ?, Cara A. Boyanowski, Esquire SERRATELLI SCHIFFMAN BROWN & CALHOON 2080 Linglestown Road Suite 201 / Harrisburg, PA 17110 (717) 540-9170 (telephone) (717) 540-5481 (facsimile) cbovanowski(&ssbc-law.com Attorney for Defendant LAWRENCE G. LANTZ, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW V. NO. 2007-5546 CIVIL TERM EVELYN T. LANTZ, . Defendant IN CUSTODY AFFIDAVIT OF SERVICE Cara A. Boyanowski, Esquire, being duly sworn according to law, states the following: I am the attorney for Evelyn T. Lantz, the Defendant in the above-captioned custody action. 2. On or about February 26, 2009, I forwarded a copy of the Petition for Modification of Custody Order, which was filed with the Cumberland County Court of Common Pleas on February 4, 2009, with an Order of Court scheduling the custody conciliation conference on the same, attached, by certified mail, return receipt requested. The said Petition and Order of Court were addressed to Plaintiff, Lawrence G. Lantz, 10 Thyme Court, Mechanicsburg, PA 17050. A true and correct copy of the Domestic Return Receipt (PS Form 3811), signed by Lawrence G. Lantz, is attached hereto as Exhibit "A." As evidenced by his signature and the United States Postal Service Track & Confirm form, Plaintiff, Lawrence G. Lantz, accepted service of the Petition for Modification of Custody Order and Order of Court on March 3, 2009. Respectfully submitted, SERRATELLI SCHIFFMAN BROWN & CALHOON, P.C. By: a "- 0-4 wo-fi W) Cara A. Boyanowski, Esquire Attorney No. 68736 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Defendant Date: ?J' ?'q ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the bads of the mailpiece,. _ or on the front If space permits. 1. Artkde Addressed to: LOu? u `f oAt 1 o rtKk? Vyu Qlak - A. ftrg X / B. ReCeiveffby (Printed AWM) I C. Date of Delivery D. is delivery address different from item 1? 0 Yes ff YES, enw deawy address below: 0 No 'Nu carom C))QA• AkA , P 05o a Too .w~ Mfan 0 evro a Mull 0 Rep WWW D Rohn. Racalpt for Merchendiee 0 insured and 0 C.O.D. 4. RestftW DaNvery? Pft FbW 13 rise 2. Article Number obwWfarltramService bw 7008 0150 0002 2957 6404 PS Form 3811, Fewamy 20owt Dan..tlo Hearn firrwbt ,cis ae.F,e.o USPS - Track & Confirm Page 1 of 1 LhVTEDSTJ TES PWAL ? i Home I Help Track & Confirm Track & Confirm Search Results Label/Receipt Number: 7008 0150 0002 2957 6404 Status: Delivered Your item was delivered at 2:41 PM on March 3, 2009 in MECHANICSBURG, PA 17050. _ -,_- AdditiDriitl D?+ttltitS • " R?rur? to tl?P$.?mlh fl?nr?? ? :_ `rack & Colldirm Enter Label/Receipt Number. Notifir-amn Options Track & Confirm by email Get current event information or updates for your item sent to you or others by email Go > Sde_M.ap Contact Us Forms Gov't. Services. Jobs Privacy-Policy Terms_of. Use Naticnal_$ Pr§mpr Accounts Copyright01989-2407 LISPS. All Rights Reserved. No FEAR Act EEO Data FOIA http://trkcnfrml .smi.usps.com/PTSInternetWeb/InterLabellnquiry.do 3/5/2009 n ,Zar,? ?.Ct ?T 1 i 11;r ; ?w •j r. • .?-? 3?? ; .? c? "'t' H MAR 3 1 2009 G LAWRENCE G. LANTZ : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. EVELYN T. LANTZ : No. 07-5546 Civil Term Defendant : ACTION IN CUSTODY Prior Judge: Kevin A. Hess, J. COURT ORDER AND NOW, this /,+- day of April 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: 1. All prior Orders entered in this matter are hereby VACATED and replaced with this Order. 2. Legal Custody: The Father, Lawrence G. Lantz, and the Mother, Evelyn T. Lantz, shall enjoy shared legal custody of the minor Children, Rebecca Lantz, born 8/17/1994, and Victoria Lantz, born 9/28/1998. The parties 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 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 3. Physical Custody: The Father and the Mother shall share physical custody of the Children on a repeating two week schedule (with Mother having every Monday and Tuesday overnights, Father having every Wednesday and Thursday overnights and the parents alternating weekends from Friday until Monday) as follows: a. Commencing 04/03/2009, Mother shall have physical custody of the Children from Friday at 6:00 pm until Wednesday morning before school. Father shall then have custody from Wednesday after school until Monday morning before school. b. Mother shall then have physical custody of the Children Monday at 6:00 pm until Wednesday morning before school. Father shall have from after 0 school Wednesday until Friday morning before school. c. Mother and Father may alter this schedule by mutual agreement in writing as necessary or proper in the Children's best interest. 4. Exchanges: Mother has agreed to provide the transportation for the Children. However, in the absence of agreement, the parties shall the share the transportation with the non-custodial parent picking up the Children. 5. The non-custodial parent shall be entitled to have reasonable liberal telephone contact with the Children. 6. In the event of a medical emergency, the custodial party shall notify the other parties as soon as practicable after the emergency is handled. 7. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. 8. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 9. Holidays: All major holidays and the Children's birthdays shall be alternated and arranged as mutually agreed upon. 10. Each parent shall have two non-consecutive weeks of vacation with the Children per year. The requesting parent shall give the other parent 30 days advance notice of the requested time and this vacation week shall supersede the regular physical custody schedule. In the event the parties schedule conflicting vacations, the party first providing written notice shall have the choice of vacation. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. 11. This Order is entered pursuant to 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. Cc: Z--,Iey Beam, Esq., 4660 Trindle Rd., Ste 201, Camp Hill, PA 17011 !C a Boyanowski, Esq., 2080 Linglestown Rd., Ste 201, Harrisburg, PA 17110 John J. Mangan, Esq. llf 'Y/,I/O' Regular Physical Custodial Schedule Monday Tuesday Wednesday Thursday Frida Saturday Sunda D M M M D D D M M M M M M D D D D D .+ LAWRENCE G. LANTZ Plaintiff V. EVELYN T. LANTZ Defendant Prior Judge: Kevin A. Hess, J. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 07-5546 Civil Term ACTION IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(B), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Rebecca Lantz 8/17/94 Father and Mother Victoria Lantz 9/28/98 Father and Mother 2. An Order of Court was entered in this matter on October 16, 2007, a status conciliation conference was held on February 14, 2008, an Order issued February 29, 2008 and a conciliation conference was held March 30, 2009 with the following individuals in attendance: The Father, Lawrence G. Lantz, did not appear but was represented by his counsel, Lesley Beam, Esquire The Mother, Evelyn T. Lantz, with her counsel, Cara Boyanowski, Esquire 3. The undersigned recommends the entry of an Order in the form as attached. 01 U Date: J0?6 angan, Esquire C to Conciliator ~ ~ LAWRENCE G. LANTZ IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. - No. 07-5546 Civil Term EVELYN T. LANTZ Defendant : ACTION IN CUSTODY Prior Judge: Kevin A. Hess, P.J. COURT ORDER AND NOW, this ~ day of August 2010, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: 1. All prior Orders entered in this matter are hereby VACATED and replaced with this Order. 2. Legal Custody: The Father, Lawrence G. Lantz, and the Mother, Evelyn T. Lantz, shall enjoy shared legal custody of the minor Children, Rebecca Lantz, born 8/17/1994, and Victoria Lantz, born 9/28/1998. The parties 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 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 3. Physical Custody: The Father and the Mother shall share physical custody of Victoria on a repeating two week schedule (with Mother having every Monday and Tuesday overnights, Father having every Wednesday and Thursday overnights and the parents alternating weekends from Friday-until Monday) and Mother shall have primary physical custody of Rebecca and Father partial custody pursuant to the schedule as follows: a. Commencing 04/03/2009, Mother shall have physical custody of Victoria from Friday at 6:00 pm until Wednesday morning before school. Father shall then have custody from Wednesday after school until Monday morning before school. b. Mother shall then have physical custody of Victoria Monday at 6:00 pm until Wednesday morning before school. Father shall have from after school Wednesday until Friday morning before school. c. In regazd to Rebecca, Father shall have at least two visits per week, at a minimum, pursuant to Father's and Rebecca's work schedules. The exact days and duration by agreement of the parties. d. Mother and Father may alter this schedule by mutual agreement in writing as necessary or proper in the Children's best interest. 4. Exchanges: Mother has agreed to provide the transportation for the Children. However, in the absence of agreement, the parties shall the shaze the transportation with the non-custodial pazent picking up the Children. 5. The non-custodial pazent shall be entitled to have reasonable liberal telephone contact with the Children. 6. In the event of a medical emergency, the custodial party shall notify the other parties as soon as practicable after the emergency is handled. 7. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. 8. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 9. Holidays: All major holidays and the Children's birthdays shall be alternated and arranged as mutually agreed upon. 10. Each parent shall have two non-consecutive weeks of vacation with the Children per yeaz. The requesting pazent shall give the other parent 30 days advance notice of the requested time and this vacation week shall supersede the regulaz physical custody schedule. In the event the parties schedule conflicting vacations, the party first providing written notice shall have the choice of vacation. Prior to departure, the parties will provide each other with information regazding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. Father has akeady designated August 18-23, 2010 as his vacation period with both Children; however, due consideration shall be given to Rebecca's desire to go on this vacation. 11. Counseling: The parties have agreed to, and shall, engage in therapeutic family counseling (with the focus on co-pazenting) with amutually-agreed upon professional. The cost of said. counseling, after appropriate payment through insurance, shall be split equally between the parties. 12. A status conference with the assigned conciliator is hereby scheduled for AuQUSt 27 2010 at 1.OO~m at the Court of Common Pleas in Carlisle, PA. 13. This Order is entered pursuant to 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: ~ Lesley Beam, Esq., 130 Walnut Street, P.O. Box 810, Harrisburg, PA 17108 / Diane Baker, Esq., 27 South Arlene St., Harrisburg, PA 17112 / John J. Mangan, Esq. ~~ n ~ ,. (`~ _.'S~ P ~ ~ ~; ^~ - , _, i- ..9 `'~ - = - -o ~'~` - ~ _... _ F . -, ~.~~ __ _` :_ ~, ~ ,. BY THE COURT, LAWRENCE G. LANTZ Plaintiff v. EVELYN T. LANTZ Defendant Prior Judge: Kevin A. Hess, P.J. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07-5546 Civil Term ACTION IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(B), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Rebecca Lantz 8/17/94 Father and Mother Victoria Lantz 9/28/98 Father and Mother 2. An Order of Court was entered in this matter on October 16, 2007, a status conciliation conference was held on February 14, 2008, an Order issued February 29, 2008, a conciliation conference was held March 30, 2009, an Order issued Apri101, 2009 and a conference was held July 20, 2010 with the following individuals in attendance: The Father, Lawrence G. Lantz, with his counsel, Lesley Beam, Esquire The Mother, Evelyn T. Lantz, with her counsel, Cara Boyanowski, Esquire 3. The undersigned recommends the entry of an Order in the form as attached. Date: 4 / 5 / ~ J angan, Esquire ust ~ dy Conciliator AUG 2 7 20j u LAWRENCE G. LANTZ IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 07-5546 Civil Term EVELYN T. LANTZ Defendant : ACTION IN CUSTODY Prior Judge: Kevin A. Hess, P.J. ' ... w COURT ORDER z ? o AND NOW, this Z J _ day of August 2010, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: All prior Orders entered in this matter are hereby VACATED and replaced with this Order. 2. Legal Custody: The Father, Lawrence G. Lantz, and the Mother, Evelyn T. Lantz, shall enjoy shared legal custody of the minor Children, Rebecca Lantz, born 8/17/1994, and Victoria Lantz, born 9/28/1998. The parties 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 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 3. Physical Custody: The Father and the Mother shall share physical custody of Rebecca Lantz and Victoria Lantz. In regard to Rebecca, the parents shall share physical custody as the parents may agree. In regard to Victoria, the schedule shall be on a repeating two week schedule (with Mother having every Monday and Tuesday overnights, Father having every Wednesday and Thursday overnights and the parents alternating weekends from Friday until Monday) pursuant to the schedule as follows: a. Commencing 04/03/2009, Mother shall have physical custody of Victoria from Friday at 6:00 pm until Wednesday morning before school. Father shall then have custody from Wednesday after school until Monday morning before school. b. Mother shall then have physical custody of Victoria Monday at 6:00 pm until Wednesday morning before school. Father shall have from after school Wednesday until Friday morning before school. c. Mother and Father may alter this schedule by mutual agreement in writing as necessary or proper in the Children's best interest. 4. School District: The parties have agreed to, and shall, have Rebecca and Victoria Lantz attend school in Father's school district where he resides (Cumberland Valley School District) absent mutual agreement otherwise or further Order of Court. 5. Exchanges: Mother has agreed to provide the transportation for the Children. However, in the absence of agreement, the parties shall the share the transportation with the non-custodial parent picking up the Children. 6. The non-custodial parent shall be entitled to have reasonable liberal telephone contact with the Children. 7. In the event of a medical emergency, the custodial party shall notify the other parties as soon as practicable after the emergency is handled. 8. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. 9. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 10. Holidays: All major holidays and the Children's birthdays shall be alternated and arranged as mutually agreed upon. 11. Each parent shall have two non-consecutive weeks of vacation with the Children per year. The requesting parent shall give the other parent 30 days advance notice of the requested time and this vacation week shall supersede the regular physical custody schedule. In the event the parties schedule conflicting vacations, the party first providing written notice shall have the choice of vacation. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. 12. Counseling: The parties have agreed to, and shall, engage in therapeutic family counseling (with the focus on co-parenting) with a mutually-agreed upon professional. The cost of said counseling, after appropriate payment through insurance, shall be split equally between the parties. 13. This Order is entered pursuant to 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, P.J. Cc: L?esley Beam, Esq., 130 Walnut Street, P.O. Box 810, Harrisburg, PA 17108 ?lane Baker, Esq., 27 South Arlene St., Harrisburg, PA 17112 m J. Mangan, Esq. `o .3? LAWRENCE G. LANTZ Plaintiff V. EVELYN T. LANTZ Defendant Prior Judge: Kevin A. Hess, P.J. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 07-5546 Civil Term ACTION IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(B), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Rebecca Lantz 8/17/94 Father and Mother Victoria Lantz 9/28/98 Father and Mother 2. An Order of Court was entered in this matter on October 16, 2007, a status conciliation conference was held on February 14, 2008, an Order issued February 29, 2008, a conciliation conference was held March 30, 2009, an Order issued April 01, 2009, a conference was held July 20, 2010, an Order issued August 9, 2010 and a conference was held August 27, 2010 with the following individuals in attendance: The Father, Lawrence G. Lantz, with his counsel, Lesley Beam, Esquire The Mother, Evelyn T. Lantz, with her counsel, Diane Baker, Esquire 3. The undersigned recommends the entry of an Order in the form as attached. Date: John J. ang , Esquire Custo y Co ciliator