HomeMy WebLinkAbout08-2494JEFFREY R. LEES, IN THE COURT of COMMON PLEAS,
Plaintiff CUMBERLAND COUNTY,
PENNSYLVANIA
V.
No. O ?- d 4 C? Tom...
CHRISTA J. LEES,
Defendant CIVIL ACTION - CUSTODY
To: The Judges of Said Court:
Complaint for Custody
f?
AND NOW this) 7`'day of April, 2008 comes Plaintiff, JEFFREY R. LEES, above
named, by and through his attorney, John M. Glace, Esquire, and presents this Complaint
for Custody as follows:
1. Plaintiff Jeffrey R. Lee is an married adult individual who presently resides at
108 Prowell Drive, Camp Hill, Cumberland County, Pennsylvania, 17011.
2. Defendant Christa J. Lees is an married adult individual who resides at 160 East
Cumberland Road, Enola, Cumberland County, Pennsylvania 17025..
3. Above parties are the biological parents of Angelina Jane Lees (dob: 6/11/04);
Lennon Michael Lees (dob: 9/21/06) ; Christian Alexander Lees (9/21/06). Said
minor children were born in of wedlock.
4. For the preceding five (5) years, all the aforementioned minor children have
resided at
a. 160 East Cumberland Road, Enola, PA and
b. 2117 Princeton Avenue, Apartment 5, Camp Hill, PA 17011
5. The parties separated on or about March 12, 2008 and Plaintiff has had very
limited access to his minor children since that date at the caprice of the Defendant mother.
6. No other custody actions have been commenced in any other jurisdiction(s) nor
have the parties entered into a voluntary agreement.
7. It is the best interests of the minor children to continue to maintain contact with
their father through periods of partial physical custody.
8. All parties of interest have been made party to this action.
9. No named party is a present member of the Armed Services of United States.
WHEREFORE, Plaintiff JEFFREY R. LEES, respectfully requests that this
Honorable Court grant him shared legal custody and partial primary physical custody of his
minor children.
Respectfully submitted,
The Law Office of ohn M. Glace
John lace, Esquire
Sum Ict. ID: 23933
134 Walnut Street
H sburg, PA 17101-1612
(717-238-5515)
VERIFICATION
I verify that the statements made in the foregoing Complaint for Custody are
true and correct to the best of my understanding and belief. I understand that false
statements herein are made subject to the penalties provided by 18 Pa. CSA, Section
4904, relating to unsworn falsification to authorities.
Date:
Jeffrey R. Lees
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that this /7 day of April, 2008 I have served a true and
correct copy of the foregoing Complaint for Custody, by first class mail, postage
prepaid, upon:
Christa J. Lees
160 East Cumberland Road
Enola, PA 17025
Make, Esquire
Ct. ID: 23933
132-134 Walnut Street
Harrisburg, PA 171101-1612
(717) 238-5515
Counsel for Plaintiff
TV P 4
9.5
O cam
- '?
?1
? %,-t s7?rn
G LP
,4
JEFFREY R. LEES IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
CHRISTA J. LEES
DEFENDANT
2008-2494 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Thursday, April 24, 2008 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, May 21, 2008 at 12:00 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 Custodv orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/ Daum S. Sunda Es q.
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
AV"
iA?
7 - 'fir
A;;7 s-rh
;-IIHI do
MAY 2 3 2000
JEFFREY R. LEES IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. 2008-2494 CIVIL ACTION LAW
CHRISTA J. LEES
Defendant IN CUSTODY
ORDER
AND NOW, this 21st day of May , the conciliator, being advised by counsel for both
parties that all custody issues have been resolved by agreement between the parties, hereby
relinquishes jurisdiction. The custody conciliation conference scheduled for May 21, 2008, is
cancelled.
FOR THE COURT,
Dawn S. Sunday, Esquire
Custody Conciliator
-
??a
r
IN THE COURT OF COMMON PLEAS,
JEFFREY R. LEES, CUMBERLAND COUNTY,
Plaintiff PENNSYLVANIA
V. No. 2008 - 2494
CHRISTA J. LEES,
Defendant CIVIL ACTION- CUSTODY
To; Judges of Said Court:
Motion to Approve Stipulation for Custody
AND NOW, this y of of June 2008, the above parties in the above captioned
matter, both being represented by counsel, respectfully move this Honorable Court to
approve the attached Stipulation for Custody as an Order of Court, in support thereof,
present the following:
1. The above parties have with the intent to enter into a Custody Order and to be
legally thereafter be bound have mutually reached a Stipulation of Custody for Angelina
Jane Lees ( dob: 6/11/08); Lennon Michael Lees ( dob: 9/21/06) and Christian Alexander
Lees ( 9/21/06) said Stipulation and proposed Order, executed by all parties and their
counsel , is attached hereto as Exhibit "A" and is made part hereof.
2. Counsel for above Plaintiff respectfully moves this Honorable Court to sign the
attached Order and direct Plaintiffs counsel to make distribution of all original copies of
the Order and Stipulation.
Respectfully submitted
The Law Office of John M. Glace
J " . Glace, Esquire
up a Ct. ID: 23933
U- 4 Walnut Street
Harrisburg, PA 17101
717-238-5515
C 5 •Z Wd 61 NAP 80QZ
A?bl ?v; I O'Sd 3Nl
Exhibit "A"
W
JEFFREY R. LEES,
Pbdatiff
V.
CHRISTA J. LEES,
Defendant
IN THE COURT OF COMMON PLEAS,
CUMBERLAND COUNTY,
PENNSYLVANIA
No. 2009 - 2494
CIVIL ACTION- CUSTODY
STIPULATION for CUSTODY of
ANGELINA JANE LEES (deb: 6/11/14), LENNON MICHAEL LEES
(dob: 941190 =W MtISTIAN ALEXANDER LEES (deb: 941/96)
AND NOW, this day of May, 2008, the above parties in the above optioned
matter, both being rued by counsel, hereto stipulate and agree as follows:
1. LEGAL CUSTODY of minor children ANGELINA JANE LEES, born June
11, 2004; LENNON MICHAEL LEES, born September 21,2006; and CHRISTIAN
ALEXANDER LEES, born Septenber 21, 2006, shall be jointly held, which will include
all major decision concerning the child, including but not limited to, the child's health,
welfare, education, religious training and upbringing. Bode parties are allowed access to
any and all records concerning these matters.
2. PRIMARY PHYSICAL CUSTODY shall be with Defendant Mother,
captioned above, CHRISTA L LEES.
3. PARTIAL PHYSICAL CUSTODY shall be with the Plaintiff Father
JEFFREY R. LEES captioned above, as follows,
a. Overnight visits for one (1) night on alternating weeks. This night should be
mutually agreed upon based on Father's work schedule, but no later than forty-
eight (48) hours prior to the overnight visit and with Father picking the children
up at 6:00 PM and Mother picking the children at 6:00 PM at the conclusion of
the visit; and
b. Overnight visits for two (2) nights to alternate with those one night overnight
visits described in the preceding subparagraph to include all terms and conditions
above stated; and
c. Father will also be able to visit minor children one evening per week for two
(2) hours with all I ?m q ortation to be provided by Father, and
d. Father shall have reasonable telephone access to children, but no more than one
(1) call per night and four (4) per week and not to extend beyond fifteen (15)
minutes in the aggregate; and
e. Parties shall alternate the following major holidays: Easter, Memorial Day;
Fourth of July; Labor Day and Thanksgiving and said andodud period shall nm
from 10:00 AM to 6:00 PM. Mother shall have the four (4) holidays on even
numbered years; and
f. Christmas shall be divided into two segments which shall alternate annually. On
the odd numbered years Father shall have custody from noon, December 24th
until noon December 25th wherein that period of custody shall terminate on noon,
December 26th and the established custody schedule shall re-commence. On the
even numbered years Mother shall have custody during the first segment; as above
described; and
g. Mother shall have custody on Mother's day and Father shall have custody on
Father's Day: and
h. Holiday custody schedules take precedence over the regular custody schedule;
and
n`om`
i. Each parry shall be entitled to two (2consecutive weeks of vacation during
summer vacation. Each party shall provi the other with thirty (30) days notice of
that parties intent to exercise this right, the dates of the vacation, and any
destination. Otherwise the above custody schedule controls: and
j. All the above partial custody schedules are subject to mutually agreed
ametrdment, but any amendment must be agreed prior to transfer.
4. RELOCATION Neither party shall relocate without Prim advisement of thirty
(30) days to other party.
5. EMERGENCY In the event of a medical emergency to any minor child, the
custodial party shall immediately notify the other party as soon as practicable.
• f?otp bible,
'1"IF.S• T1?te'ofsbsU!3;?;?.o4, t1?.
b. COW ' T of ply in*0 ??the
ova cow b--O the ltd P?o fivo as ? oOW of COWL and
7. 'nits STW F, tln? p'?es l° ? ?? on8? fut1Y
WJO have
IN Wand above a r?t i _ yea tine, .
COPY of ? 1 .0,40a for ? 7e*ey F,. IAes
G ?an?
for P
v
vm l for De°dant
Co
J
BY TIV, COUP-T.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that this `day of June, 20081 have served a true and
correct copy of the foregoing Motion to Approve Stipulation for Custody, by first class
mail, postage prepaid, upon:
Samuel L. Andes, Esquire
525 North Twelfth Street
Lemoyne, PA 17043
Counsel for Defendant
f?.
Jo? Glace, Esquire
Su a Ct. ID: 23933
132=134 Walnut Street
Harrisburg, PA 171101-1612
(717) 238-5515
Counsel for Plaintiff/Movant
JEFFREY R. LEES,
Plaintiff
V.
CHRISTA J. LEES,
Defendant
To; Judges of Said Court:
JUG Yo ?nnr (? q
IN THE COURT OF COMMON PLEAS,
CUMBERLAND COUNTY,
PENNSYLVANIA
No. 2008 - 2494
CIVIL ACTION- CUSTODY
Motion to Approve Stipulation for Custody
I I k
AND NOW this
dy a. of June 2008, the above
parties in the above captioned
matter, both being represented by counsel, respectfully move this Honorable Court to
approve the attached Stipulation for Custody as an Order of Court, in support thereof,
present the following:
1. The above parties have with the intent to enter into a Custody Order and to be
legally thereafter be bound have mutually reached a Stipulation of Custody for Angelina
Jane Lees ( dob: 6/11/08); Lennon Michael Lees ( dob: 9/21/06) and Christian Alexander
Lees ( 9/21/06) said Stipulation and proposed Order, executed by all parties and their
counsel , is attached hereto as Exhibit "A" and is made part hereof.
2. Counsel for above Plaintiff respectfully moves this Honorable Court to sign the
attached Order and direct Plaintiffs counsel to make distribution of all original copies of
the Order and Stipulation.
,rn
60 :0 lk!V S? N"Ir 0001
Respectfully submitted
The Law Office of John M. Glace
An N4. . Glace, Esquire
$up e Ct. ID: 23933
1
- 4 Walnut Street
Harrisburg, PA 17101
717-238-5515
CS :Z Wd 61 Ml r BOOT
????(n;?r?i f(r t` "'d :'
?L7Vllri`vui i1??:?? :'Hi
Exhibit
fit x I
IN THE COURT OF COMMON PLEAS,
JEFFREY R. LEES, CUMBERLAND COUNTY,
Pbdntiff PENNSYLVANIA
V. No. 2000 - 2494
CHRISTA J. LEES, :
Defendant CIVIL ACTION- CUSTODY
STIPULATION for CUSTODY of
ANGELINA JANE LEES (dob: 6111/04), LENNON MICHAEL LEES
fdob: 9/21/061 and CSRISTIAN ALEXANDER LEES (deb: 9!21/06)
AND NOW, this day of May, 2008, the above parties in the above captioned
matter, both being reWeserrted by counsel, hereto stipulate and agree as follows:
1. LEGAL CUSTODY of minor children ANGEU NA JANE LEES, born June
11, 2004; LENNON MICHAEL LEES, born September 21, 2006; and CHRISTIAN
ALEXANDER. LEES, born September 21, 2006, shall be jointly held, which will include
all major decision concerning the child, including but not limited to, the child's health,
welfare, eduction, religious training and upbringing. Both parties are allowed access to
any and all records concerning these matters.
2. PRIMARY PHYSICAL CUSTODY shall be with Defendant Mother,
captioned above, CHRISTA J. LEES.
3. PARTIAL PHYSICAL CUSTODY shall be with the Plaintiff Father
JEFFREY R. LEES optioned above, as follows;
a. Overnight visits for one (1) night on alternating weeks. This night should be
mutually agreed upon based on Fag's work schedule, but no later than forty-
eight (48) hours prior to the overnight visit and with Father picking the children
up at 6:00 PM and Mother picldng the children at 6:00 PM at the conclusion of
the visit; and
b. Overnight visits for two (2) nights to alternate with those one night overnight
visits described in the preceding subparagraph to include all terms and conditions
above stated; and
c. Father will also be able to visit minor children one evening per week for two
(2) hours with all transportation to be provided by Father; and
d. Father shall have reasonable telephone access to children, but no more than one
(1) call per night and four (4) per week and not to extend beyond fifteen (15)
minutes in the aggregate; and
e. Parties shall alternate the following major holidays: Easter, Memorial Day;
Fourth of July; labor Day and Thanksgiving and said custodial period shall run
from 10:00 AM to 6:00 PM. Mother shall have the four (4) holidays on even
numbered years; and
f. Christmas shall be divided into two its which shall alternate annually. On
the odd numbered years Father shall have custody from noon, December 24th
until noon December 25th wherein that period of custody shall terminate on noon,
December 26th and the established custody schedule shall re-commend. On the
even numbered years Mother shall have custody during the first segment, as above
described-, and
g. Mother shall have custody on Mother's day and Father shall have custody on
Father's Day: and
h. Holiday custody schedules take precedence over the regular custody schedule;
and
i. Each party shall be entitled to two (2 consecutive weeks of vacation during
summer vacation. Each party shall provi& the other with thirty (30) days notice of
that parties intent to exercise this right, the dates of the vacation, and any
destination. Otherwise the above custody schedule controls: and
All the above
j. partial custody schedules are subject to mutually agreed
amendment, but any amendment must be agreed prior to transfer.
4. RELOCATION Neither party shall relocate without prior advisement of thirty
(30) days to other party.
5. EMERGENCY In the event of a medical emergency to any minor child, the
custodial party shall immediately notify the other party as soon as practicable.
6. CONDUCT of PARTIES. The parties shall refiain from making derogatory
comments about the other party in the pence of the children and, to the extent possible,
shall prevent third parties firm making such comments in the presence of the children.
7. This STIPULATION shall be entered as an Order of Court.
IN W 7NF.SS WMBEOF, the parties hereto have hereunto set their hands and
seals the day and year above written and have each received an original fully executed
copy of tNs stipulation for Custody.
Glace., Esquire
for Plaintiff
L
uel LAndes, Esquire
Counsel for Defendant
Jeffrey R. Lees
IT
c6ii J es
a BY THE COURT:
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that this 16k-day of June, 2008 I have served a true and
correct copy of the foregoing Motion to Approve Stipulation for Custody, by first class
mail, postage prepaid, upon:
Samuel L. Andes, Esquire
525 North Twelfth Street
Lemoyne, PA 17043
Counsel for Defendant
1
Johtj Glace, Esquire
Suds a Ct. ID: 23933
132=134 Walnut Street
Harrisburg, PA 171101-1612
(717) 238-5515
Counsel for Plaintiff/Movant
r
..,,
'te ?' C7
: Z-3
ar
ZE"
JEFFREY R. LEES, : IN THE COURT OF COMMON PLEAS
PLAINTIFF : OF CUMBERLAND COUNTY,
: PENNSYLVANIA
vs. : NO. 2008 —2494 CIVIL TERM V
CHRISTA J. LEES, : CIVIL ACTION- LAW 2
DEFENDANT : IN DIVORCE
0 C., r=
-2 ---1 �
PRAECIPE FOR WITHDRAWAL OF APPEARANCE - --s
Please withdraw my appearance on behalf of the Defendant, Christa J. Lees. =c) ,C
ry
Respectfully submitted,
Dated: ir DA;2013 Adow _� v ■
�
� uel L. Andes, squire
Counsel for Defendant
PA I.D. #
525 North Twelfth Street
P.O. Box 168
Lemoyne, PA 17013
(717) 761-5361
PRAECIPE FOR ENTRY OF APPEARANCE
Please enter my appearance on behalf of the Defendant, Christa J. Lees.
Respectfully submitted,
Dated: , 2013 ° /0, d !
Susan Kay an4 iello, Esquire
Counsel for(De i.ndant
PA I.D. # 649.8
710 Gladstone Court
Mechanicsburg, PA 17055
(717) 724-2278
JEFFREY R. LEES, : IN THE COURT OF COMMON PLEAS,' 'r'
PLAINTIFF : OF CUMBERLAND COUNTY, r
: PENNSYLVANIA 0
daO
VS. : NO. 2008 - 2494 5 y
""4
CHRISTA J. LEES, : CIVIL ACTION - LAW y -c5 o
DEFENDANT . ACTION FOR CUSTODY
NOTICE 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 action within twenty (20) days after this Petition and
Notice are served, by entering a written appearance personally or by attorney and filing in
writing with the Court your defenses or objections to the claims set forth against you. You are
warned that if you fail to do so the case may proceed without you and a judgment may be entered
against you by the Court without further notice for any money claimed in the Petition or for any
other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
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.
Court Administrator
Fourth Floor
Cumberland County Courthouse
1 Courthouse Square
Carlisle PA 17013
((717)240-6200
°°I
� d
O
CKL Hco
9aae-lay
JEFFREY R. LEES, : IN THE COURT OF COMMON PLEAS
PLAINTIFF : OF CUMBERLAND COUNTY,
: PENNSYLVANIA 7:2)n ••-'k
vs. : NO. 2008 -2494 o'
a'
CHRISTA J. LEES, : CIVIL ACTION -LAW
DEFENDANT : ACTION FOR CUSTODY c2 n o v,
a
PETITION FOR MODIFICATION OF CUSTODY ORDER zs'
AND NOW,comes the Defendant/Petitioner, CHRISTA J. LEES , by and through her
counsel, Susan Kay Candiello, Esquire, and files this Petition for Modification of Custody Order
upon a cause of action of which the following is a statement:
1. The Defendant/Petitioner is CHRISTA J. LEES, who currently resides at 160 East
Cumberland Road, Enola, Cumberland County, Pennsylvania, 17025.
2. The Plaintiff/Respondent is JEFFREY R. LEES, who currently resides at 507
Market Street, Millersburg, Pennsylvania, 17061.
3. Defendant/Petitioner seeks Shared Legal Custody and Primary Physical Custody
of the following children:
Name Present Residence Date of Birth
ANGELINA JANE LEES 160 East Cumberland Road June 11, 2004
Enola, PA
LENNON MICHAEL LEES 160 East Cumberland Road September 21, 2006
Enola, PA
CHRISTIAN ALEXANDER LEES 160 East Cumberland Road September 21, 2006
Enola, PA
4. The children were born during the parties' marriage.
5. The children are presently in a Primary Custody of Defendant/Petitioner who
resides at 160 East Cumberland Road, Enola, PA, 17025.
6. During the past five (5) years, the children has resided with the following persons
at the following addresses:
Name(s) Address Dates
Defendant/Petitioner 160 East Cumberland Street 2006 to Present
Enola, PA
7. The mother of the child is Defendant/Petitioner whose current address is 160 East
Cumberland Road, Enola, Cumberland County, PA 17025.
8. Plaintiff and Defendant are in the process of getting a divorce.
9. The father of the child is Plaintiff/Respondent, who currently resides at 507
Market Street, Millersburg, PA, 17061.
10. Defendant/Petitioner currently resides with her three children.
11. Plaintiff/Respondent is in a relationship. Plaintiff/Respondent currently resides
with his paramour, Jennifer Bair and their son, Conor Lees.
12. Defendant/Petitioner has participated as a party in a prior custody agreement
concerning the custody of the children in this court. The court,term and number, and its
relationship to this action are as follows: the court was Cumberland County,the docket number
is 2008-2494,the result was a custody order which is attached hereto and made a part hereof as
Exhibit"A".
13. Defendant/Petitioner has no information of a custody proceeding concerning the
children pending in a court of this Commonwealth at this time.
14. Defendant/Petitioner 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.
15. The best interest and permanent welfare of the children will be served by granting
the relief requested because:
A. Mother has always been the primary care giver for the children and
loves them dearly;
B. Father has a history of mental illness, tried to commit suicide in the
presence of the children and was committed to Holy Spirit
Hospital;
C. Father has a history of alcohol and illegal substance abuse;
D. Father's girlfriend is employed, at his home doing sex tapes for the
interne.
E. One year ago he broke the windshield of his co-workers car, during
his last drinking binge;
F. When the children visit with him they come home exhausted, teeth
not brushed, hair matted,they don't get any showers or baths, and
frequently not given meals;
G. Father buys the boys inappropriate gifts for Christmas and their
birthdays;
H. Mother has great love and concern for her child and does not
believe it is in her child's best interest to be living in the Father's
home for any significant length of time;
I. Mother believes her children would benefit from the stability and
security which she can provide in her home.
17. Each parent whose parental rights to the children have not been terminated
and the person who has physical custody of the children have been named as parties to
this action.
WHEREFORE, Defendant/Petitioner, CHRISTA J. LEES, requests this Honorable
Court continue Shared Legal Custody between the parties, and grant Defendant/Petitioner,
CHRISTA J. LEES, PRIMARY PHYSICAL CUSTODY and Plaintiff/Respondent,
JEFFREY R. LEES, PARTIAL PHYSICAL CUSTODY, of the minor children, ANGELINA
JANE LEES, LENNON MICHAEL LEES and CHRISTIAN ALEXANDER LEES.
Respectfully submitted,
LAW FIRM OF SUSAN KAY CANDIELLO
Dated: October /0, 2013 C)cS— ;�_� 176
san Kay Candi=llo Esquire
Counsel for Defen•ant/Petitioner
PA I.D. # 64998
710 Gladstone Court
Mechanicsburg PA 17055
(717) 724-2278
VERIFICATION
The undersigned hereby verifies that the facts averred in the foregoing document are true
and correct to the best of her knowledge, information, and belief. This verification is made
subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities.
DATED: l O 1� A.I 6.ar
CHRISTA J. LEES
EXHIBIT "A"
IN THE COURT OF COMMON PLEAS,
JEFFREY R.LEES, : CUMBERLAND COUNTY,
Plaintiff : PENNSYLVANIA
v. No. 200$-2494
CHRISTA J.LEES,
Defendant CIVIL ACTION-CUSTODY
STIPULATION for CUSTODY of
ANGELINA JANE LEES(doh:6/11/04),LENNON MICHAEL LEES
(doh:9/21100 and CHRISTIAN ALEXANDER LEES(Job;9/2100
AND NOW,this day of May,2008,the above patties in the above captioned
matter,both being represented by counsel,hereto stipulate and agree as follows:
1. LEGAL CUSTODY of minor children ANGELINA JANE LEES,born June
11,2004;LENNON MICHAEL LEES,born September 21,2006;and CHRISTIAN
ALEXANDER LEES,born September 21,2006,shall be jointly held,which will include
all major decision concerning the child,including but not limited to,the child's health,
welfare,education,religious training and upbringing.Both parties are allowed access to
any and all records concerning these matters.
2. PRIMARY PHYSICAL CUSTODY shall be with Defendant Mother,
captioned above,CHRISTA J.LEES.
3. PARTIAL PHYSICAL CUSTODY shall be with the Plaintiff Father
JEFFREY R.LEES captioned above, as follows;
a.Overnight visits for one(1)night on alternating weeks.This night should be
mutually agreed upon based on Father's work schedule,but no later than forty-
eight(48)bouts prior to the overnight visit and with Father picking the children
up at 6:00 PM and Mother picking the children at 6:00 PM at the conclusion of
the visit;and
b. Overnight visits for two(2)nights to alternate with those one night overnight
visits described in the preceding subparagraph to include all terms and conditions
above stated;and
c. Father will also be able to visit minor children one evening per week for two
(2)hours with all transportation to be provided by Father;and
d.Father shall have reasonable telephone access to children,but no more than one
(1) call per night and four(4)per week and not to extend beyond fifteen(15)
minutes in the aggregate;and
e.Parties shall alternate the following major holidays:Easter,Memorial Day;
Fourth of July;Labor Day and Thanksgiving and said custodial period shall run
from 10:00 AM to 6:00 PM.Mother shall have the four(4)holidays on even
numbered years;and
f.Christmas shall be divided into two segments which shall alternate annually.On
the odd numbered years Father shall have custody from noon,December 24th
until noon December 25th wherein that period of custody shall terminate on noon,
December 26th and the established custody schedule shall re-commence.On the
even numbered years Mother shall have custody during the first segment,as above
described;and
g.Mother shall have custody on Mother's day and Father shall have custody on
Father's Day:and
h.Holiday custody schedules take precedence over the regular custody schedule;
and
rlc --
9 __summer vacation Each party shall provi the other with thirty(vacation days of
ti\(1 • that parties intent to exercise this right,the dates of the vacation,and any
destination.Otherwise the above custody schedule controls:and
j. All the above partial custody schedules are subject to mutually agreed
amendment,but any amendment must be agreed prior to transfer.
4. RELOCATION Neither party shall relocate without prior advisement of thirty
(30)days to other party.
5.EMERGENCY In the event of a medical emergency to any minor child,the
custodial party shall immediately notify the other party as soon as practicable.
6.CONDUCT of PARTIES.The parties shall refrain from making derogatory
comments about the other party in the presence of the children and,to the extent possible,
shall prevent third parties from making such comments in the presence of the children.
7. This STIPULATION shall be entered as an Order of Court.
IN*DIVESS WHEREOF,the patties hereto have hereunto set their hands and
seals the day and year above written and have each received an original fully executed
copy of I• Stipulation for Custody.
Jo.I.!4 Glace.,Esquire Jeffrey it Lees
Co j . for Plaintiff
i
uel • Esquire
Counsel for Defendant
BY THE COURT:
A /4
J
, ....._. . ,,
,..,
,---e, ..Tk.,,,,,--,,,,.__,..,„ .
1 ..
' '''''.
. . .
.'.' '• N
. .,
7'.
,..
'1 r
. 7
t2 . ,l
. .
, . .
v IAR'
td . .
, .
. .+.
..
Ftj •
. •JEFFREY R. LEE
•
: IN THE COURT OF COMMON"PLEAS
,.. .
' v t v:
"' ' 3Z I 1 -. . C , . - 4„X., • -t:',t' ,I 4..'''''' 'L.- :L:2:7;4 ''
#0. .
' .
• .-UMBERLAND,COUNTY-Hi PENNSYLVANIA
Plaintiff :, - ': -2..: :-.'.'" "' nr IR - 0 -2 ---,, ,,. .
cUrit.),---,.u. •?01. 14 .• ',-:,-- ,. .'• -;NO -;:=.2 087 -4 .,..,,- .p...„-, -:-. ,..,., ,.- -
4s:...;- f,, , s-...,-ipt,.r. . ,,,, .. - ,... ",.-- , -,,,,._.,,,,.1--.,-,,,f,:,,,-, --.,,, r::'.S;:.„' .,, 'rr;:I ..';(,,::,s,..;.,'',,.. .. '■.
CHRIS,, , , 7,,.:-., Lir-. -. .;.■:',::-i:2": . `:.q-'..'` :• i...- f....: s :'.;..i.,7,■:;':ii,.,;g':1v. ,...,.,...ri'',-,:,'.7.,, n,::':-.k,:„./..:..,w_..,i--,'',,,,,,, .
TA Ji LEES; ...--,,,'. ,--:--.• .. ; ,
- '-'1.-- 'CIV,ILIACTIeN'-,,4'CUSTOD,` -,-• _,•,..,, .:
•.
Defendant -
•
...„
..,
, ...
• ,
:-•: .. .i.-'---'„,.,.'•'--,,,..H ';...
.'.,
_•--.!T.., ...,....,:„-
,..-.J,.,,,,,,.„--,:.,-:.•'•:•„,.-.-..
.•., •......r.,).. ,..„..,-.-.;„„•,,='r.,--.:,-_'„.:......•,,,-,,,.,..,
.
! . 0C"I__N AL'RECOID AtUgt4 §TORYAFfIPAVIT
2 #'\ 1 i - , : y, i p ,
I I' ijA A__.441/ • /I' ereby swear ora ff , subject-to-pe n
a„:;.,..,l-,.t
i e;.......,.s,•`,•..
a,.:,,
• _ _ .
•
•
laWincluding 18:pa.
,
C.S.•§4.1901,Telating to unswo rn ,
• falsification to authorities that:
•,. .. .,•::-.i,_ .. , 7'—
1. . Unl'elssiiidiCatOttbVmy
,,...
„ ,
checking the box next to a crime below, neither I
„ - . . .
nor any member of IllYhO.usehold .have 6 been convicted, pled, „guilty or pled no
...--„,f-,,...,,.• .,•4 :I, .,,,,.. ,,mo. Li. ‘1,..''‘.-$ ..
cones ,.. ...,...,
contest to any ofthe•following
' • ,
. . • crirnes in Pennsylvania or in any other jurisdiction:
....., ..,...... .,.
NO EXCEPTIONS ', i .
. ,„..„.....
- ,I: - irliOlf.lriiiiri..01.':: ::14;:,'';'2,„''.':1•74.ii-';.:',4; ,
.. :-.4: 'f'.'''!'r■ .. m <:,....„4!c...4.; ,,..i.,Agir , .,_ ..,f,4'.."..e:eri,,,,-
: ' ''''''' ':rd.'Isfi.;.';'' ''';” .: .•'''.11•4'5'•••1•91":7errf ,'•'/•14• 31,i, 0111,6‘ ' ',W.:t'.PW.42,k-,.,..t.,-i.eipe''4.0',:'„,.. Dat;e,,..o„
Ui're "5"eetvirj,.-47:143:*?,%,:',4:',';`,;li'i ,$!:''''',44,1'...t1"4.,,--4,-''''''..ix.," 4"?',,,,,,' .2'11,;:iohr3A;)4%ifr,,h' 1:„.r.,:•-,:,,,-.. .--,N0,,,,,A,.---,,,,,01.,„
:,44 te-40Pr..A4041,E.°14- 0-4,-*1,44.P„-U.141'...i.'..'iec-J-Ifil44°.-H-7'1
-V II .'-'‘- *4."*.--,,,,loro--. -','?"..•-',..4., 4've..;:i''4,..'i...44:wioeij.,..,,'„
,a 'cokT., ',',V,141, t.413'W
..::).,,litililli*Loi):4,,,!°;LI`s:cre4r;..i.'.;;'::,i'l'ili....'"?,:..::,.: 7,4:,.."kl'-..,. `,4110,:d7t.t.,.,01,1:7;,:teik7.:::.4.4,?:;74151.;,,t4:4,i.',i'f,t7:-t,t4s'',tiv,',"rsilptg?,,'lj:l".tg:r!!,44.4yW:..,zrj,,7!JL.V,tj;$,',,,,_',4_,„,:_:,.,i,..,44:<,,,,,*,,,..4,.,,,:...,-'.2;.,..??....-„,.,-.,,,,i,4).:..,.,,..,::•?2,,,'..,
,,p,A:,c,m,.,•r.4",m,:',,Iii10:,,.7Tre',..7-14.eay:'?...k-,.'-itIV 144.,..;.:7.7.,';744'1',1=-1--I :'..1-6-..'='°",-Y-'71”- 1:- ,; .;.::!;-. -,.';'-'1:1-=!'',I;
.1:-if-.,-. „. „. 77:, ,=J,,,.....f.;,,.:,,,,;,-.'.,,: .„'',-';-:-.q'.i:".,'':::.:,,.."1 2.-.., .,''.',;:', '
'''t -"' l'f6t-':Vidlationkif,:ar,i.. .-'.-.::. : 2 ,t.1 •t>_
. '''' •1.:'::''' '..t Con emp.: , ,,,. ..... ,,1"-I. -5' -'''r7 *".: L-r:--1;-'_:....'-ir :',.... :-..! •.: '. - . . ,_,, ., . ,
E from.jAb'se' Ord4r.-, -'. ,irzi.'......; ;,:,,, ,„,-,--i.„ . •,,,,,,,,-, .,..
1___! :-:.-. „ ----.t :-.4-1-,.;::-.,:: •••:,,,, s,.,,,......:,:-„.,..,,,:_:, ..,,,,,: ,-„,,,,:, ,----,;‘,,..„•::,•
.,, (7r a'a reemen::,,,..,-:?,,-,,,.,.-.-..:=-'%,:,-;-*:-.,,,I.F.,-,74,..itr....,e,"7::::4:,:a7.:„:.„„:0,...„,,,,,t:?,-Atek,,t,r,%;,!•,*,:,
-'''''..''''..-.' '-'-.''' --'-'* 'Id If 'e'.4nflilienee'', N.1,,4-',Iii ..,.*r-T •„410L.3-",' IC:.',:;'.,, '0,-,;” ,.;i4ttpate .9
7t,e 0:1111;;;',1„1„.,Dr,LY41.04,0.,116.,,,ek,..4)., ,-,,ifr4f,,,,,45':.,..n..' ,. -...... ,,eil.:!,,;w,.1:'f::•'s ,„-:'v,.'.'w.1'&Ali''.,Vii,:v.-... '''.'."lr.'"'" '14,,:', Aft
..''''''''''''4'.117*°'f":';':VIIP(31114161tOntrol red;,,,-, •r>iit;,,,N,-,3 iill?;VA:04'''".:74,it''4 .w.:;==e;
.,0...610.).0 OP t.4,74.-04.4.v.-:..--44,pz.i4.--i'
A-:-...tok.:,...i.4.1R4444-k+.w,--: --,,. ---.:glit; '.',..„1,1(..A&,te, ,3,' '44, ..:'...;rj,-•^''' ' ''''•..• — —' „
i'°''''.••''' ''"'"'"'Io. tante,drdrugs,-,- -6, ,4-- '," — - - ■ ,. :
Possession, sale, delivery, T.,
s - --,-,Y:-.,-...1',......- ::,,-,;','''::::',.-`:.....7:7'.::::' ..:.: ,'''', .;'.. • .'.'- '..:".'f,:';-.. ,-.., .-A:, .-;
;V ri
tifatturingoroffering,fo Ej
,, .
-. . :4,_ :• !=sal ,anyOnIrbiled substance...
or other drug or device,
RAMO. „,-...... .ii4SW„..:,•:...,4.7,-,p:',..,':,:,,„'„7„:„:-v,„:,1,..,,,:ti,..it,i,=;,,,,:°‘.:....ix--.11,A.;..,iirrtitsik.4,,,;”
''149*W k=t7"'7 •.,;,.--;,1 "44Y.c..t.k:,1,,,,TW7.41,;.,-1.',10'''''''',,.'04;::'..„..,., pr.h;z„,.,,',,,ka,;;14.4,..,, . i.?,..A.,--,,.!..,-,- . ..1=,...-7..r,-,..,,rr,'',0 Cr!., .
'441-13.)if Aek'',.1■1101;d0P-V,P.1,-'''',44:1$ph tio.N..:mi.i.,'..•'',-,4„ii.1.1;,,,P,a- .:lix.,*41kA*.v:'.......-,,,,,,,,,niviwqm'dt.-•: .
en rilinzionom to ‘,.-e, ,- wigt:,..,,t,.
1 zc:9?-11.0344: 6•=::-.„....,,,,,•!;.,,,,,-:,:-',„-:. ; -:-.--,..,.,,,,-::::,:,,,,,..,,..:',::
:,:,,,,,;:,:,,:44.4,:::.,i--.:: ,:i.,,:'.1,-.,,--Ir.,r,:::',',..,-;:,,•.c.,---.-:-,-- .',,.-:;...',!,;.:r,..,-., . .,-`• ,: 4,-.:: . i-: : :: ,, ?.-..1. ,,i'. .-:' •,:'
I' I 1 t Aggravated,Assaul , ,i, . ..,..-.- 11 .. 1=1
.•
..
RT7titratit7.-- ,7',:k '''',:,,,Ft we, ' .,.,0t.i.T.,,:•!..,'y.,vg.t.g.::',",,,44'i.,:-....-.0.0
-.* ....t,,,;,1,A16,
..,10.. ,,;,...- ..,,„.744.0, ,I,,,„,,, „.......,!„,:"5„,,w.,,,,
i. --; 144,....;,,,,;,.- .-, ;,.;41014' '':'4,:I% '. ; ff,' , .s.,A i,,o fe, ,...441.4":-...-.,,
•
4., '4."'.:'''''''.."'"'.1-.'.)''''''4.'''tii''ats. ,...0,,:i,,:.,,,, ---,,,:,.....0--t',4(17',;;',°....r. f A ''T'i,':'''',Fie"',Vf
• tit, „ ... 'i'•17„•,te94A1:4511*.lti1R4'',,,Sr.4:.i.f.''';'54:e.;'A.,;,.41,41,":.:ifl'.,:.•%.",'C't,:iftit:,Y 'kit.4,,gx.,' ,.‘”, .!,-4,,,d ,,,,...._w: ,,,,. ,.,,,.,, ,,:,_..„:,:‘ c,:t, ,..,,.... , ,;;;,,:. ..,..:,
.,Stalking, ,,,,,,:,,,.c,..; . ,,.: .,. , ,_ ,,,'"..;_ •*, '.. .....;,-.. ,.I'1.''''',.'"".1'''''''.. :4..1::,;:::.-- ,7:,:;;;; .r..,iga....'AVVr-C-Ilitket4re:' .
• '? '''' ' '' ' 1 -
. .
, ,"11'211,i41442:,X4''g.4%::;:.IFIKI.,",,P124441:01'4%Ci$YelAfAt,;'7 f''''ll't'id'''''''Zig%IAN'','AA.6'''''''' ""'We'l'''''V:4''.--',!:: :.:..:W.,a :%4.4.,!',...li'..:,,*::••••• 7:siiii,
v at-,,,""°,,,04,04, -1 n - ,,,,,,,..,0,, 0,v,:,,,,„,....;...1.!■:, .44,4.),',AT,,' "',lel.v4„......i.w.f.1,,,, ..on via...0*, ,
'-
1
.-
2. Unless indicated by my checking the box next to a crime below, neither I
nor any member of my household have a present and/or past history of violent or
abusive conduct, except as listed below:
Check = [
Other
all Crime Self Household Date
that Member
apply
A finding of abuse by a
fl Children &Youth Agency or 0 []
similar agency in Pennsylvania
or similar statute in another
jurisdiction
Abusive conduct as defined
�] under the Protection from
v
Abuse Act in Pennsylvania or =
similar statute in another
jurisdiction
Other: 0 0
Please list any evaluations, counseling or other treatment received following
conviction:
If any conviction above applies to a household member, not a party, state that
person's relationship to the child(ren).
OCTOBER t b 2013 ILL
11 ! 4ii / �5
OCTO Signature
Printed Name
3
JEFFREY R. LEES IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
2008-2494 CIVIL ACTION LAW
CHRISTA J. LEES IN CUSTODY
DEFENDANT •
ORDER OF COURT
AND NOW, Wednesday,October 16,2013 , upon consideration of the attached Complaint, it is
hereby directed that parties and their respective counsel appear before Dawn S.Sunday,Esq. , the conciliator,
at 39 West Main Street,Mechanicsburg,PA 17055 on Wednesday,November 20,2013 11:00 AM
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.
You must file with the Court a verification regarding any criminal record or abuse history regarding you and
anyone living in your household on or before the initial in-person contact with the court(including, but not limited to,
a conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition.
No party may make a change in the residence of any child which significantly impairs the ability of the other party
to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and
Pa.R.C.P. No. 1915.17 regarding relocation.
FOR THE COURT,
By: Is/ Dawn S. Sunday, Esq. ,yt■
Custody Conciliator Y'
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
1 " 32 South Bedford Street -0_4.
rn
Q (i
QA. €i[0Carlisle, Pennsylvania 17013 m
Telephone (717)249-3166 -tr>
`J . es
14446.1 . 11
10/17/1.3
c°
JEFFREY R. LEES, : IN THE COURT OF COMMON PLEAS
PLAINTIFF : OF CUMBERLAND COUNTY, r r s
: PENNSYLVANIA
vs. : NO. 2008 -2494
•
CHRISTA J. LEES, : CIVIL ACTION - LAW
DEFENDANT : ACTION FOR CUSTODY
STIPULATION FOR AGREED ORDER OF CUSTODY
The Plaintiff(hereinafter sometimes referred to as "Father") is JEFFREY R. LEES, who
currently resides at 5220 Carlisle Road, Wellsville, Pennsylvania, 17365.
The Defendant (hereinafter sometimes referred to as "Mother") CHRISTA J. LEES,
who currently resides at 160 East Cumberland Road, Enola, Pennsylvania, 17025.
ANGELINA JANE LEES (hereinafter sometimes referred to as "Angelina" born on
June 11, 2004, LENNON MICHAEL LEES (hereinafter sometimes referred to as "Lennon")
and CHRISTIAN ALEXANDER LEES (hereinafter sometimes referred to as "Christian"),
both born on September 21, 2006, are the subjects of this Stipulation for Agreed Order of
Custody.
It is Plaintiff and Defendant's belief that it is in the best interests of their minor children
to have a meaningful ongoing relationships with both his natural Mother and natural Father,
provided the children are in a safe environment.
WHEREFORE, Plaintiff, JEFFREY R. LEES, and Defendant, CHRISTA J. LEES,
have entered into a mutual agreement regarding the custody of their children and respectfully
request this Honorable Court to enter the following Order:
1. Father, JEFFREY R. LEES and Mother, CHRISTA J. LEES, shall share Legal
Custody (as defined in 23 Pa.C.S.A. Section 5302) of their minor children, ANGELINA JANE
LEES, LENNON MICHAEL LEES and CHRISTIAN ALEXANDER LEES. In the event
that Father is not capable of making decisions due to his addictions, mental and physical health,
Mother shall make all decisions herself.
2. All decisions affecting their children's growth and development including, but not
limited to: choice of camp, if any; choice of day care provider; medical and dental treatment;
psychotherapy, psychoanalysis, or like treatment; decisions relating to actual or potential
litigation involving their children, directly or as beneficiary, other than custody litigation;
education, both secular and religious; scholastic athletic pursuits and other extracurricular
activities shall be considered major decisions and shall be made by Father and Mother, jointly,
after discussion and consultation with each other and with a view towards obtaining and
following a harmonious policy in their children's best interest.
3. Mother and Father agree to keep the other informed of the progress of their children's
education and social adjustments. Mother and Father agree to communicate with each other and
not to use the children to avoid communication with the other parent. Mother and Father agree
not to impair the other's right to shared legal or physical custody of their children. Mother and
Father agree to give support to the other in the role as parent and to take into account the
consensus of the other for the physical and emotional well-being of their children.
4. While in the presence of their children, neither Mother nor Father shall make, or
permit any other person to make, any remarks or do anything which could in any way be
construed as derogatory or uncomplimentary to the other parent. It shall be the express duty of
each parent to uphold the other parent as one whom their children should respect and love.
5. It shall be the obligation of each parent to make their children available to the other
2
.I
in accordance with the physical custody schedule and to encourage their children to participate in
the plan hereby agreed and ordered.
6. Each parent shall have the duty to notify the other of any event or activity that could
reasonably be expected to be of significant concern to the other parent.
7. With regard to any emergency decisions which must be made, the parent with whom
the children is physically residing at the time shall be permitted to make the decision necessitated
by the emergency without consulting the other parent in advance. However, that parent shall
inform the other of the emergency and consult with him or her as soon as possible. Day-to-day
decisions of a routine nature shall be the responsibility of the parent having physical custody at
the time.
8. Mother and Father shall be entitled to complete and full information from any doctor,
dentist, teacher or authority and have copies of any reports given to them as a parent. Such
documents include, but are not limited to, medical reports, academic and school report cards,
birth certificates, etc. Both parents may and are encouraged to attend school conferences and
activities. Both parents' names shall be listed with the school their children attend as parents to
be contacted in the event of an emergency, and to be notified regarding school events. Each
party shall provide the other, promptly after receipt, with copies of report cards and notification
of major school events
9. Neither Mother nor Father shall schedule activities or appointments for their children,
which would require their attendance or participation at said activity or appointment during a
time when their children are scheduled to be in the physical custody of the other parent without
that parent's express prior approval.
3
10. The parties have agreed Mother, CHRISTA J. LEES shall have PRIMARY
PHYSICAL CUSTODY and Father, JEFFREY R. LEES shall have PARTIAL PHYSICAL
CUSTODY of their minor children, ANGELINA JANE LEES, LENNON MICHAEL LEES
and CHRISTIAN ALEXANDER LEES, in accordance with the following schedule:
A. Father shall have the children three nights a weekend, each month,
beginning October 4th after school and drops them off October 5th at 7:00 p.m. at
Mother's home. One night, the week Father does not have the children he shall
have the children after school through 7:30 p.m. during school and 8:30 p.m. in
the summer months;
B. Father shall make certain the children are not exposed to any form of
sexually explicit behaviours or acts.
C. Mother shall have the children during most holidays, Father shall ask if
he wants them. Christmas shall be divided so that Father has the children
Christmas Eve at an agreed upon time, and shall return them on Christmas Day
before 12:00 p.m.
D. Father shall have the children on Father's Day and Mother shall have
the children on Mother's Day;
E. All holidays and specially designated times for visitation with their
children shall supersede the regularly scheduled visitation.
11. The parties are encouraged to discuss and cooperate with each other when sharing
and making requests for changes in periods of visitation. All permanent changes in periods of
4
custody from those contained in this custody agreement shall be made in writing and signed by
both parties;
12. The custodial parent shall allow the children reasonable communication with the
non-custodial parent by telephone.
13. Mother and Father agree to be responsible for any ordinary everyday expenses which
occur during their individual custody periods with their children.
14. Mother and Father shall make certain they are fed and given the opportunity to eat.
15. During any period of custody or visitation, the parents shall not possess or use
controlled substances or consume alcoholic beverages to the point of intoxication. The
parties shall likewise assure, to the extent possible, that other household members and/or
houseguests comply with this prohibition.
16. No party will smoke cigarettes or tobacco products nor allow others to smoke in
the presence of the children.
17. CHARGES AND/OR CONVICTIONS
Neither parent has been convicted of or has plead guilty or no contest to a criminal
offense as set forth in 23 Pa.C.S.A. § 5303(b) and neither parent has been charged, convicted or
plead guilty or no contest to an offense set forth in 23 Pa.C.S.A. § 5303(b.1) or §5303(b.2).
Neither parent poses a risk of harm nor threat of harm to the children subject to this Custody
Order.
18. The parent with physical custody of their children agrees to keep the other parent
fully aware and informed of any successes, difficulties, activities, emergencies, etc., in which
their children has become involved.
5
.y
19. Mother and Father agree to provide each other with current information regarding
their children. Mother and Father also agree to have each other listed as an emergency contact
with any adult and/or agency their children interact with.
20. Father shall provide all transportation for the children.
21. Mother and Father agree to provide each other with written notice of their intent to
relocate a minimum of ninety (90) days prior to their move.
23. If the parties disagree and/or are unable to reach a joint decision regarding their
children, they agree to utilize either Counseling or Mediation to assist them to reach a resolution
before resorting to seeking a resolution through the court system;
24. Mother and Father shall be free to mutually agree to alter and/or change the terms of
this agreement. If the alteration and/or agreement is permanent and/or a change which will occur
on numerous occasions, the parties agree the alteration and/or change shall be in writing
and signed by both parents. lo)
# , f - — aar...........,
J ( g, __�
WITNESS JEFFREY R. LEES
C O
■ 1 _ �_u I� _�� I 41 1k.
WITNESS RIST A J. LEES
6
COMMONWEALTH OF PENNSYLVANIA •
: SS:
COUNTY OF CUMBERLAND
On this, the a day of November, 2013, before me, a Notary Public, the undersigned
officer, personally appeared SUSAN KAY CANDIELLO, known to me (or satisfactorily
proven) to be a member of the bar of the highest court of said State and a subscribing witness to
the within instrument, and certified that she was personally present when JEFFERY R. LEES
and CHRISTA J. LEES, whose names are subscribed to the within Stipulation for Custody,
executed the same, and that said persons acknowledged that they executed the same for the
purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official Seal. "
r►a
0 ' `YLT\ 1
ir a y Public
OM ONW` T1 OF PENNSYLVANM
Notarial Seal
Lori Ann Dively,Notary Public
Lower Allen Twp.,Cumberland County
My CommJS5lon Expires Sept 13,2015
MEMBER,PENNSYLVANIA ASSOCIATION Of NOTARIES
7
J I "
E
JEFFREY R. LEES„.,, , ,k, 9 I. c : IN THE COURT OF COMMON PLEAS
Lr.13 fi 0 ,�i 1
CCiJi '' : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff 'EtNISYL\11\N 1A1
vs. NO. 2008-2494
CHRISTA J. LEES, :
Defendant : CIVIL ACTION - CUSTODY
CRIMINAL RECORD/ABUSE HISTORY AFFIDAVIT
I -Sec-c ILEH . LEE: S , hereby swear or affirm, subject to penalties of
law including 18 Pa. C.S. §4904 relating to unsworn falsification to authorities that:
1. Unless indicated by my checking the box next to a crime below, neither I
nor any member of my household have been convicted, pled guilty or pled no
contest to any of the following crimes in Pennsylvania or in any other jurisdiction:
NO EXCEPTIONS
- • 3I�ff
4
Contempt for violation of a
❑ Protection from Abuse order ❑ El
or agreemen ,
° Sri t m �,
Possession, sale, delivery, 6-0A-fa
El manufacturing or offering for ❑ ❑
sale any controlled substance
or other drug or device,
•
Aggravated Assault; ❑ ❑
❑ Stalking; ❑ ❑
INF
,kalax 3
* •ka . J 3 3r f : "� fl� _ 13 3ixr l , y�i• 33 3 J
1
pie❑ El
�,,.', ' ,i a 1=1 Unlawful restraint; ,-,, a :3�w h, ,,N ) $ ',4!..i. ,. �i ia M a 'i •se ti !li d , ; F / sg$ Maih t /- t/ j<s,y }, , =om avAU gos g s M c Y i
❑ False imprisonment; ❑ ❑
13 �/,yAy .� M¢ fM M MM �� rliilr �� /.. ,� z
€ ..y f �� �4{[p y! �`r 1,x/1 yf //i y�Egg
f iY f_„... s!//<... ,:...a�r3ayanl;sd3.. %� I d-h
Rape, statutory sexual
❑ assault, involuntary deviate
sexual intercourse, sexual
assault, aggravated indecent ❑ ❑
assault, indecent assault,
pe, a
abuse indecent of childrenexosur, sexual sexu l
exploitation of children,
sexual intercourse with an
animal or incest;
v�3 \�V - N y 3
III .. y �. £ iii//N/,d// i // s 3�'L
.a Y $� rN�A Y€ �yy l f'?` $r Y3`,f l:;C� /
1,14/ €� A a' �oi" k ��� 1 / y�i�i1 r:s A :y 4p1: 0,�r. i� A54•�:
� , .... ,r..,.,... ,': .::.� .. -... ..: •� i.. ,�. _.�. ..;,.. i iii.: ....
El Arson and related offenses; ❑ ❑
eza
Endangering the welfare of
❑ children; ❑ ❑
r , ,/�. ,fit€33 /r / i "' .,ayl r/,te z�a t�z
»,'» �� Y �r kg > o: _��ff io x'33-'€ €€ PI
� M /') lam/ - N3" 3� I€3 ' �r �€ 3�s `�I•k
Prostitution and related
❑ offenses; ❑ ❑
�� M R �€3 3 3d a /F_ 1 3 P 3 lY� 3 "3.ta �• / \:,!y
�r � .s I i 1 r j331h1f f�1 tM' i h 7 z
_� �..... E...I A �3 1.�!3 /%i ,: 3 ///�//f%%Dili!
Couption of minors or
El unlawful contact with a ❑ ❑
rr
minor;
2
2. Unless indicated by my checking the box next to a crime below, neither I
nor any member of my household have a present and/or past history of violent or
abusive conduct, except as listed below:
Check °
•
• all'. f y � �4� 3 •
A finding of abuse by a
I:1 Children &Youth Agency or 1=1 El similar agency in Pennsylvania
or similar statute in another
jurisdiction
Abusive cc�nd � � v ,,. °y
s Erb
•
Other:
❑ ❑ ❑
Please list any evaluations, counseling or other treatment received following
conviction:
If any conviction above applies to a household member, not a party, state that
person's relationship to the child(ren).
November /.7, 2013
Signature
Printed Name
3
JEFFREY R. LEES, : IN THE COURT OF COMMON PLEAS
PLAINTIFF : OF CUMBERLAND COUNTY, r,
c Cam,
PENNSYLVANIA -� "s,
crn CD r=
vs. : NO. 2008 -2494 2 rr,
(-- N _ M_
CHRISTA J. LEES, : CIVIL ACTION - LAW
DEFENDANT : ACTION FOR CUSTODY , y
v Z
ORDER OF COURT
AND NOW,this 12 day of Oe , 2013 upon consideration of the
attached Stipulation for Agreed Order of Custody, Defendant, CHRISTA J. LEES and
Plaintiff, JEFFREY R. LEES, shall SHARE LEGAL CUSTODY of the parties' minor
children, ANGELINA JANE LEES,LENNON MICHAEL LEES and CHRISTIAN
ALEXANDER LEES. Defendant, CHRISTA J. LEES, shall have PRIMARY PHYSICAL
CUSTODY and Plaintiff, JEFFREY R. LEES, shall have PARTIAL PHYSICAL
CUSTODY of the minor children, ANGELINA JANE LEES,LENNON MICHAEL LEES
and CHRISTIAN ALEXANDER LEES, in accordance with the language contained in the
within Stipulation.
BY THE COURT,
" 4
J.
�GlsQ n kay dm.od re//o; �-
lhr4;544 T. Le
c
4.e5 11^-4./ J ,,/ ,
JEFFREY R. LEES • IN THE COURT OF COMMON PLEAS OF
Plaintiff • CUMBERLAND COUNTY, PENNSYLVANIA
•
vs. • 2008-2494 CIVIL ACTION LAWc-'
ry,C173
,
C/7 f ' raj .�
CHRISTA J. LEES •
Defendant • IN CUSTODY
:c c
ORDER
AND NOW, this 19th day of November, 2013, the conciliator, having been advised by
Plaintiff's counsel that all custody issues have been resolved by agreement between the parties, hereby
relinquishes jurisdiction. The custody conciliation conference scheduled for November 20, 2013 is
canceled.
FOR THE COURT,
Dawn S. Sunday, Esquire r
Custody Conciliator