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HomeMy WebLinkAbout08-3113 ORDER AND NOW, this day of , 2008, upon consideration of Melanie L. Erb, Esquire ID # 84445 The Law Office of Darrell C. Dethlefs 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone - (717) 975-9446 Fax - (717) 975-2309 MErb(?dcdlaw.net Attorney for Plaintiff LARYSSA E. VAN LIEU : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY PENNSYLVANIA V. RONALD EUGENE BENTZ Defendant NO. O V-3113 C(?, I CIVIL ACTION -LAW IN CUSTODY the within Complaint for Custody and Stipulation as to Custody, it is hereby Ordered and Decreed as follows: 1. Mother shall retain full legal custody of the Child. 2. Physical custody of said Child shall be as follows: a. Mother shall have primary, sole custody of the Child, Holden Rhys Lawrence Van Lieu. b. Father shall have visitation as follows: i. Father shall have visitation of the Child at the residence of Mother and Child at any time which shall be mutually agreed upon with Mother having the right of final approval for the day and time chosen. Father shall be responsible for transportation to and from Mother's residence or upon the location mutually agreed upon by Mother and Father. 3. Mother shall have final determination as to the schedule for visitation relative to any holidays. 4. The holiday visitation schedule shall supersede and take precedence over any regular visitation schedule. 5. Each parent shall provide the other with the address of their respective residences and the telephone number of said residence. 6. Mother shall keep Father informed of all medical appointments and any and all problems pertaining to the Child. BY THE COURT, J. Melanie L. Erb, Esquire ID # 84445 The Law Office of Darrell C. Dethlefs 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone - (717) 975-9446 Fax - (717) 975-2309 MErb@dcdlaw.net Attorney for Plaintiff LARYSSA E. VAN LIEU : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY PENNSYLVANIA V. :NO. OF- 3112 l.zv- / Q? RONALD EUGENE BENTZ CIVIL ACTION -LAW Defendant : IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, by and through her attorney, who files this Complaint for Custody and avers as follows: 1. The Plaintiff is Laryssa E. Van Lieu, an adult individual, currently residing at 8 Dubs Circle, Mechanicsburg, Cumberland County, PA. 2. The Defendant is Ronald Eugene Bentz, an adult individual currently residing at 619 North Hanover Street, Carlisle, Cumberland County, PA. 3 (a). Plaintiff sole legal and physical custody of Holden Rhys Lawrence Van Lieu, born March 28, 2008, in accordance with the parties' fully executed Stipulation as to Custody. 3(b). The child was not born out of wedlock. The child is presently in the custody of Plaintiff, Laryssa E. Van Lieu who resides at 8 Dubs Circle, Mechanicsburg, Cumberland County, PA. Her relationship to the minor child is that of Mother. Since the child's birth, the child has resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Laryssa E. Van Lieu 8 Dubs Circle birth-present Mechanicsburg, PA Judith K. Van Lieu Lawrence E. Van Lieu 3(c). The mother of the child is Laryssa E. Van Lieu, currently residing at 8 Dubs Circle, Mechanicsburg, Cumberland County, PA. She is married. The father of the child is Ronald Eugene Bentz, currently residing at 619 North Hanover Street, Carlisle, Cumberland County, PA. He is married. 4. The relationship of Plaintiff to the child is that of Mother. The Plaintiff currently resides with the following persons: Name Relationship Holden Rhys Lawrence Van Lieu Son Judith K. Van Lieu Mother Lawrence E. Van Lieu Father 5. The relationship of Defendant to the child is that of Father. The Defendant currently resides with the following persons: Name Relationship Robert Bentz Paternal grandfather Mrs. Robert Bentz Paternal grandmother 6(a). Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 6(b). Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because the parties have entered into a Stipulation of Custody, a fully executed copy of which is attached hereto as Exhibit "A". 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as a party to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: NONE. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an Order incorporating the terms of the parties' Stipulation as to Custody. Respectfully Submitted, Me ie rb, squire PA I.D. No. 84445 The Law Offices of Darrell C. Dethlefs 2132 Market Street Camp Hill, PA 17011 (717) 975-9446 Attorney for Plaintiff VERIFICATION I verify that the statements made in the Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: &t4 ssa ` Michael J. Pykosh, Esquire ID # 58851 The Law Office of Darrell C. Dethlefs 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone - (717) 975-9446 Fax - (717) 975-2309 mpykosh4Mcd1aw.net Attorney for Plaintiff LARYSSA E. VAN LIEU : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY PENNSYLVANIA V. : NO. RONALD EUGENE BENTZ : CIVIL ACTION -LAW Defendant : IN CUSTODY APSULATION AS TO CUSTODY AND NOW, this day of April, 2008, it is hereby stipulated and agreed between the parties as follows: 1. Laryssa E. Van Lieu is an adult individual residing at 8 Dubs Circle, Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as "Mother". 2. Ronald Eugene Bentz is an adult individual residing at 619 North Hanover Street, Carlisle, Pennsylvania, hereinafter referred to as "Father". 3. Holden Rhys Lawrence Van Lieu, born March 28, 2008, is the natural child of Laryssa E. Van Lieu and Ronald Eugene Bentz. Holden Rhys Lawrence Van Lieu shall be hereinafter referred to as "Child". 4. Mother shall retain full legal custody of the Child. 5. Physical custody of said Child shall be as follows: a. Mother shall have primary, sole custody of the Child. b. Father shall have visitation as follows: i. Father shall have visitation of the Child at the residence of Mother and Child at any time which shall be mutually agreed upon with Mother having the right of final approval for the day and time chosen. Father shall be responsible for transportation to and from Mother's residence or upon the location mutually agreed upon by Mother and Father. 6. Mother shall have final determination as to the schedule for visitation relative to any holidays. 7. The holiday visitation schedule shall supersede and take precedence over any regular visitation schedule. 8. Each parent shall provide the other with the address of their respective residences and the telephone number of said residence. 9. Mother shall keep Father informed of all medical appointments and any and all problems pertaining to the Child. 10. The parties hereby agree that the terms of this Stipulation shall be entered as an Order of Court by the Court of Common Pleas of Cumberland County, Pennsylvania. ,41q 16? Date 41~ q JO q Date M er - L ssa E. Van Lieu an i e u Father - Ronald Eugene Bentz Ronald Eugene entz cc; c? i CL L 9 - C ?? lF) C,r? , 'X:.. 7.. v N Oo tj Z) 140 e. 0 Ct ? U Wit"/ ORDER day of ay , 2008, upon consideration of AND NOW, this Melanie L. Erb, Esquire ID # 84445 The Law Office of Darrell C. Dethlefs 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone - (717) 975-9446 Fax - (717) 975-2309 MErb& dcdlaw.net Attorney for Plaintiff LARYSSA E. VAN LIEU : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY PENNSYLVANIA V. RONALD EUGENE BENTZ Defendant . NO.3113 C'i?i : CIVIL ACTION -LAW : IN CUSTODY the within Complaint for Custody and Stipulation as to Custody, it is hereby Ordered and Decreed as follows: 1. Mother shall retain full legal custody of the Child. 2. Physical custody of said Child shall be as follows: a. Mother shall have primary, sole custody of the Child, Holden Rhys Lawrence Van Lieu. b. Father shall have visitation as follows: i. Father shall have visitation of the Child at the residence of Mother and Child at any time which shall be mutually agreed upon with Mother having the right of final approval for the day and time chosen. Father shall be responsible for transportation to and from Mother's residence or upon the location mutually agreed upon by Mother and Father. 3. Mother shall have final determination as to the schedule for visitation relative to any holidays. 4. The holiday visitation schedule shall supersede and take precedence over any regular visitation schedule. 5. Each parent shall provide the other with the address of their respective residences and the telephone number of said residence. 6. Mother shall keep Father informed of all medical appointments and any and all problems pertaining to the Child. BY THE COURT, \-t ", J. A 94Z3- - w I ttf IA4T S :9 WV 82 ),VWNOl 1 11 i LARYSSA E. VAN LIEU IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008 - 3113 CIVIL TERM RONALD E. BENTZ, CIVIL ACTION -LAW Defendant/Petitioner IN CUSTODY RELATED MATTERS The Honorable M. L. Ebert, Jr. previously signed the Order of Court in this matter. LARYSSA E. VAN LIEU : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008 - 3113 CIVIL TERM RONALD E. BENTZ, Defendant/Petitioner CIVIL ACTION -LAW IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY ORDER 1. The petition of Ronald E. Bentz respectfully represents that on the 270' of May, 2008, an Order of Court was entered for legal and physical custody of the child, Holden Rhys Lawrence Van Lieu, a true and correct copy of which is attached. 2. This Order should be modified because of the following: a. Ronald E. Bentz, Petitioner (hereinafter "Father") wishes to share legal custody of the child with Laryssa E. Van Lieu, Respondent (hereinafter "Mother"); the current Order provides Mother with "full legal custody" of the child; b. Father wishes to share physical custody of the child with Mother; the current Order provides Mother with full discretion as to when Father may see the child and places unreasonable conditions upon Father's custody; and c. Father wishes to have a fixed schedule for all holidays; the current Order provides Mother with full discretion as to the holiday schedule. WHEREFORE, Father requests this Honorable Court to grant him shared legal and shared physical custody of the child. Respectfully submitted, O'BRIEN, BARIC & SCHERER 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Petitioner VERIFICATION I verify that the statements made in this Petition for Modification of Custody Order are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Date"?/Q day of June 2008 onald . Ze- LARYSSA E. VAN LIEU : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008 - 3113 CIVIL TERM RONALD E. BENTZ, : CIVIL ACTION -LAW Defendant/Petitioner : IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that on July 10th, 2008, I, Robert J. Dailey, Esquire, did serve a copy of the Petition For Modification Of Custody Order, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Melanie L. Erb, Esquire Law Office of Darrell C. Dethlefs 2132 Market Street Camp Hill, PA 17011 Attorney for Plaintiff/Respondent ?l Robert . EXgIBIT (04 87 9 ,r Melanie L. Erb, Esquire ID # 84445 The Law Office of Darrell C. Dethlefs 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone - (717) 975-9446 Fax - (717) 975-2309 MEr?j{eldcdlaw.net Attorney for Plaintiff' LARYSSA E. VAN LIEU : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY PENNSYLVANIA V. : NO. 67-JH3 RONALD EUGENE BENTZ : CIVIL ACTION -LAW Defendant : IN CUSTODY ORDER AND NOW, this 4,2V-kjay of , 2008, upon consideration of the within Complaint for Custody and Stipulation as to Custody, it is hereby Ordered and Decreed as follows: 1. Mother shall retain full legal custody of the Child. 2. Physical custody of said Child shall be as follows: a. Mother shall have primary, sole custody of the Child, Holden Rhys Lawrence Van Lieu. b. Father shall have visitation as follows: i. Father shall have visitation of the Child at the residence of Mother and Child at any time which shall be mutually agreed upon with Mother having the right of final approval for the day and time chosen. Father shall be responsible for transportation to and from Mother's residence or upon the location mutually agreed upon by Mother and Father. 3. Mother shall have final determination as to the schedule for visitation relative to any holidays. 4. The holiday visitation schedule shall supersede and take precedence over any regular visitation schedule. 5. Each parent shall provide the other with the address of their respective residences and the telephone number of said residence. 6. Mother shall keep Father informed of all medical appointments and any and all problems pertaining to the Child. BY THE COURT, J. VCAL- YAUE ' COPY FROM FtECORU vii Tesdimm whovd, I two unw set mY ttano and the of Wd Cowt at Casl;s;a, Pa rhk C> ? Q r LP +, Q LARYSSA E. VAN LIEU IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-3113 CIVIL ACTION LAW RONALD E. BENTZ IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, July 18, 2008 , 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 Friday, August 22, 2008 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. 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: John J. Mangan, r., Esq. ,j 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 ??w i?nhtrt ?' ""t ??rtii?•J IT