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HomeMy WebLinkAbout08-6141 ?i EDWARD D. SCHLEMMER, Plaintiff V. REGAN STROMAN LYNCH, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, :PENNSYLVANIA : CIVIL ACTION - LAW :CUSTODY NO. 0S- COMPLAINT FOR CUSTODY AND NOW, comes Plaintiff, EDWARD D. SCHLEMMER, by and through his attorney, ROBERT B. LIEBERMAN, ESQUIRE, and respectfully represents as follows: 1. Plaintiff, EDWARD D. SCHLEMMER, is an adult individual, residing at 44 North York Street, P.O. Box 57, Etters, York County, Pennsylvania. 2. Defendant, REGAN STROMAN LYNCH, is an adult individual, residing at 14 Keller Street, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff, EDWARD D. SCHLEMMER, seeks custody of the following children: Name Residence Age Kyle E. Schlemmer 14 Keller Street, Mechanicsburg, PA 3 years Keller K. Schlemmer 14 Keller Street, Mechanicsburg, PA 2 years 4. The children were born to EDWARD D. SCHLEMMER and REGAN STROMAN LYNCH. 5. Since birth, the children have resided at various addresses initially with Plaintiff and Defendant. Since December 1, 2007, the children have resided with Defendant at three different locations. 6. The father of the children, EDWARD D. SCHLEMMER, is currently residing at44 North York Street, P.O. Box 57, Etters, York County, Pennsylvania. He is single. 8. The mother of the children, REGAN STROMAN LYNCH, is currently residing at 14 Keller Street, Mechanicsburg, Cumberland County, Pennsylvania. She is married. 9. The relationship of Plaintiff, EDWARD D. SCHLEMMER, to the children is that of father. The Plaintiff currently resides with his parents, Nancy S. Schlemmer and Edward D. Schlemmer, Sr. and his sister, Desiree Schlemmer. 10. The relationship of Defendant, REGAN STROMAN LYNCH, to the children is that of mother. The Defendant currently resides with the children and her husband, John Lynch. 11. Plaintiff, EDWARD D. SCHLEMMER, has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in a court of this Commonwealth or any other state. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 12. The best interest and permanent welfare of the children will be served by granting the relief requested because Plaintiff is ready, willing and able to provide a stable home environment for the children. 13. Each party 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, Plaintiff, EDWARD D. SCHLEMMER, requests this Honorable Court to grant him, joint legal and primary physical custody of the subject minor children. Respectfully submitted, /a-to-6k DATED: ROBERT B. LIEBERMAN, ESQUIRE 500 North 3rd Street, 12d' Floor P.O. Box 1004 Harrisburg, PA 17108-1004 (717) 236-1485 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Complaint for Custody are true and correct based upon my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. DATED: to - d _ '0 v Z-Y WARD D. SCHLEMMER, Plaintiff Ly c? r C) FR c? EDWARD D. SCHLEMMER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-6141 CIVIL ACTION LAW REGAN STROMAN LYNCH IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, October 21, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, November 13, 2008 at 9:30 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. FOR THE COURT, By: /s/ Hubert X. Gilroy, Es q. Custody Conciliator 01 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 oic :,I' IY4 l z lJo SGQZ r1s:?'li J t .v:: 'W -tj ?.:1s1 V EDWARD D. SCHLEMMER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. CUSTODYNISITATION REGAN STROMAN LYNCH, Defendant : NO. 08-6141 CIVIL TERM AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN . SS. Personally appeared before me, a Notary Public in and for said Commonwealth and County, ROBERT B. LIEBERMAN, ESQUIRE, who, being duly sworn according to law, deposes and says: 1. That on October 14, 2008, a Complaint for Custody was filed on behalf of Plaintiff and against Defendant in the above case. 2. That on October 16, 2008, I forward by certified mail, return receipt requested, a certified copy of the Complaint for Custody to Defendant, REGAN STROMAN LYNCH, at 14 Keller Street, Mechanicsburg, Cumberland County, Pennsylvania. 3. That the aforesaid copy of the Complaint for Custody sent to Defendant, REGAN STROMAN LYNCH, was delivered, on October 21, 2008, as evidenced by the return receipt card signed by Defendant and attached hereto. -.. 4. That to the best of my information and belief the signature on the return receipt card is, in fact, the signature Defendant, REGAN STROMAN LYNCH. SWORN TO and subscribed before me this -3-D day of 6.,V* ?BFR.. , 2008. N&ry Public My Commission Expires: COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL CHERYL L. FERGUSON, Notwy Public cis Hwfi"I, Ow"wpw "w' county My Cary Wion Expkes April 6, 2012 cc Q" M M F $ Q Postage Certified Fee J ? ID III ??? Retum Receipt Fee (Endorsement Re uired) Postmark Here 0 q Rretricted Delivery Fee (Endorsement Required) r- RJ Total Postage & Fees n I/ OBI /e?ir?iC Wan ---- 0 street, Opt. Mo.; G/? - r` .. PO Box No. ----------- J.-eg --- - - ---------------------- ROBERT B. LIEBERMAN, Esquire Attorney for Plaintiff at >z n ki o m can a m ~- M T M C3 n RID i -utC'. d films EDWARD D. SCHLEMMER, Plaintiff VS. REGAN K. LYNCH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Custody : NO. 08 - 6141 PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter the appearance of the Family Law Clinic on behalf of Regan K. Lynch, the Defendant, in the above captioned matter. November 7, 2008 Christina erreira Certified Legal Intern Anne Wald-Fox, Esq. Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 d NOV 18 2008 (1 EDWARD D. SCHLEMMER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW REGAN K. LYNCH, NO. 2008-6141 Defendant IN CUSTODY COURT ORDER AND NOW, this day of November, 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The father, Edward D. Schlemmer, and the mother, Regan K. Lynch, shall enjoy shared legal custody of Kyle Schlemmer, born March 11, 2005, and Keller Schlemmer, born November 2, 2006. 2. The Mother shall enjoy primary physical custody of the minor children. 3. The Father shall enjoy periods of temporary physical custody of the minor children as follows: A. On alternating weekends from Saturday at 9:00 a.m. until Sunday at 7:00 p.m.; B. At such other times as agreed upon by the parties. 4. For exchange of custody, the parties shall meet at the Sheetz near the Harrisburg Mall at the designated time, unless agreed otherwise by the parties. 5. The Mother shall always have custody on Mother's Day and the Father shall always have custody on Father's Day. This provision shall supercede any other provision of this Order. The Mother's Day and Father's Day custody shall start at 9:00 a.m. Saturday through 7:00 p.m. Sunday. I 6. The holiday schedule shall be handled as follows, unless agreed otherwise by the parties: A. For the Christmas holiday, Christmas shall be divided into two segments: Segment A shall be from December 24`h at noon until December 25`h at noon, and Segment B shall be from December 25`h at noon until December 26`h at noon. These segments shall be alternated each year with the Father having Segment A in 2008 and the parties alternating thereafter. B. Thanksgiving shall be divided into two segments: the first segment shall be from 9:00 a.m. until 3:00 p.m., and the second segment shall be from 3:00 p.m. until 9:00 p.m. For Thanksgiving, 2008, the Mother shall have the first segment and the Father shall have the second with the parties alternating thereafter. C. The parties shall alternate custody on Easter, Memorial Day, July 4`h and Labor Day. Times shall be from 9:00 a.m. until 7:00 p.m. If the holiday is a Monday and Father has custody on the weekend preceding that, Father shall keep custody through the holiday on Monday. The alternating holiday schedule shall start with Mother having Easter, 2009. 7. Neither parent shall consume alcohol or illegal drugs while the children are in their custody, nor shall they allow a third party to do so while the children are in their presence. 8. In the event the Father has the children and has contact with the Maternal Grandmother or Maternal Step-Grandfather, Father shall ensure that that custody is in a public location or at his residence. 9. Both parents shall work with each other to ensure that the other parent has adequate time to celebrate each child's birthday which may be the day before or after the birthday. cc: 10. Each parent shall enjoy two weeks of vacation with the minor children during the summer months, with these weeks not being consecutive and each week will include the parent's respective weekend. Each parent shall give the other one at least thirty (30) days notice as to when they intend to exercise the vacation. 11. The above Order is entered pursuant to an agreement of the parties. The parties may modify or alter this Order as they agree. Absent an agreement, the parties must follow this Order. If either party desires to modify the Order, that party may petition the Court to have the case again scheduled with the Custody Conciliator for a conference. Robert B. Lieberman, Esquire Ms. Christina Ferreira /1-IP-08' L?- . j ?? ?y ?= ,. d+ , ?.? ?= ?„ a:?, °?„ U ?3 ?'' EDWARD D. SCHLEMMER, Plaintiff vs. REGAN K. LYNCH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2008-6141 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL 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: Kyle Schlemmer, born March 11, 2005 Keller Schlemmer, born November 2, 2006 2. A Conciliation Conference was held on November 14, 2008, with the following individuals in attendance: The mother, Regan K. Lynch, who appeared with her counsel, Christina Ferreira, who is a student attorney with the Dickinson School of Law Family Law Clinic, and the father, Edward D. Schlemmer, with his counsel, Robert B. Lieberman, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. Date: November ( 8 , 2008 Hubert X. Gilr y, Esquire Custody Co iliator EDWARD D. SCHLEMMER, Plaintiff V. REGAN STROMAN LYNCH, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : CIVIL ACTION - LAW :CUSTODY NO. 08-6141 CIVIL TERM COMPLAINT TO MODIFY CUSTODY ORDER AND NOW, comes Plaintiff, EDWARD D. SCHLEMMER, by and through his attorney, ROBERT B. LIEBERMAN, ESQUIRE, and respectfully represents as follows: 1. Plaintiff, EDWARD D. SCHLEMMER, is an adult individual, residing at 44 North York Street, P.O. Box 57, Etters, York County, Pennsylvania. 2. Defendant, REGAN STROMAN LYNCH, is an adult individual, residing at 14 Keller Street, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff, EDWARD D. SCHLEMMER, seeks custody of the following children: Name Residence A&e Kyle E. Schlemmer 44 North York Street, Etters, PA 3 years Keller K. Schlemmer 44 North York Street, Etters, PA 2 years 4. The children were born to EDWARD D. SCHLEMMER and REGAN STROMAN LYNCH. 5. A Court Order regarding custody of the children was previously entered by the Honorable Edgar Bayley on November 18, 2008. A copy of the Court Order, which was entered following a conference with Hubert X. Gilroy, Esquire, is attached hereto marked "Exhibit A". 6. Defendant, REGAN STROMAN LYNCH, was incarcerated at the Lebanon County Prison on or about January 2, 2009. There are two charges lodged against Defendant and a detainer from Cumberland County, Pennsylvania. 7. The children have been residing with Plaintiff, Edward D. Schlemmer, since January 3, 2009. 8. The best interest and permanent welfare of the children will be served by granting the relief requested because Plaintiff is ready, willing and able to provide a stable home environment for the children. 9. Each parry whose parental rights for the children have not been terminated and the person who has physical custody have been named as parties to this action. WHEREFORE, Plaintiff, EDWARD D. SCHLEMMER, requests this Honorable Court to grant him joint legal and primary physical custody of the subject minor children. Respectfully submitted, , .-'69 DATED: RLIEBERMAN, ESQUIRE 500 North 3rd Street, 12" Floor P.O. Box 1004 Harrisburg, PA 17108-1004 (717) 236-1485 Attorney for Plaintiff IVUV I 0 Luup 61 EDWARD D. SCHLEMMER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW O 1 _ REGAN K. LYNCH, NO. 2008-6141 Defendant IN CUSTODY COURT ORDER AND NOW, this 1'?- day of November, 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The father, Edward D. Schlemmer, and the mother, Regan K. Lynch, shall enjoy shared legal custody of Kyle Schlemmer, born March 11, 2005, and Keller Schlemmer, born November 2, 2006. 2. The Mother shall enjoy primary physical custody of the minor children. 3. The Father shall enjoy periods of temporary physical custody of the minor children as follows: A. On alternating weekends from Saturday at 9:00 a.m. until Sunday at 7:00 p.m.; B. At such other times as agreed upon by the parties. 4. For exchange of custody, the parties shall meet at the Sheetz near the Harrisburg Mall at the designated time, unless agreed otherwise by the parties. 5. The Mother shall always have custody on Mother's Day and the Father shall always have custody on Father's Day. This provision shall supercede any other provision of this Order. The Mother's Day and Father's Day custody shall start at 9:00 a.m. Saturday through 7:00 p.m. Sunday. EXHIBIT?A, 6. The holiday schedule shall be handled as follows, unless agreed otherwise by the parties: A. For the Christmas holiday, Christmas shall be divided into two segments: Segment A shall be from December 24`h at noon until December 251h at noon, and Segment B shall be from December 25`h at noon until December 26`h at noon. These segments shall be alternated each year with the Father having Segment A in 2008 and the parties alternating thereafter. B. Thanksgiving shall be divided into two segments: the first segment shall be from 9:00 a.m. until 3:00 p.m., and the second segment shall be from 3:00 p.m. until 9:00 p.m. For Thanksgiving, 2008, the Mother shall have the first segment and the Father shall have the second with the parties alternating thereafter. C. The parties shall alternate custody on Easter, Memorial Day, July 4`h and Labor Day. Times shall be from 9:00 a.m. until 7:00 p.m. If the holiday is a Monday and Father has custody on the weekend preceding that, Father shall keep custody through the holiday on Monday. The alternating holiday schedule shall start with Mother having Easter, 2009. 7. Neither parent shall consume alcohol or illegal drugs while the children are in their custody, nor shall they allow a third party to do so while the children are in their presence. 8. In the event the Father has the children and has contact with the Maternal Grandmother or Maternal Step-Grandfather, Father shall ensure that that custody is in a public location or at his residence. 9. Both parents shall work with each other to ensure that the other parent has adequate time to celebrate each child's birthday which may be the day before or after the birthday. 10. Each parent shall enjoy two weeks of vacation with the minor children during the summer months, with these weeks not being consecutive and each week will include the parent's respective weekend. Each parent shall give the other one at least thirty (30) days notice as to when they intend to exercise the vacation. 11. The above Order is entered pursuant to an agreement of the parties. The parties may modify or alter this Order as they agree. Absent an agreement, the parties must follow this Order. If either party desires to modify the Order, that party may petition the Court to have the case again scheduled with the Custody Conciliator for a conference. BY THE COURT, Judge cc: Robert B. Lieberman, Esquire Ms. Christina Ferreira rRUE COPY FROM RECORD i Terry whereof, i two unto sat my hane i d the of said COP" at Cariisie, Pa. rho xy ;,,...?. Prow EDWARD D. SCHLEMMER, Plaintiff vs. REGAN K. LYNCH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-6141 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL 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: Kyle Schlemmer, born March 11, 2005 Keller Schlemmer, born November 2, 2006 2. A Conciliation Conference was held on November 14, 2008, with the following individuals in attendance: The mother, Regan K. Lynch, who appeared with her counsel, Christina Ferreira, who is a student attorney with the Dickinson School of Law Family Law Clinic, and the father, Edward D. Schlemmer, with his counsel, Robert B. Lieberman, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. Date: November i , 2008 - - , L ubert X. Gilroy, Esquire Custody Conciliator VERIFICATION I verify that the statements made in the foregoing Motion to Modify Custody Order are true and correct based upon my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. Dated: ' - el EDWARD D. SCHLEMMER, Plaintiff LJ Q ?.??' ` ? 1 ? -. ` ? Ci ? ?? ? ? ??? ? ? j ?- rs °..? ?? t!t? -v ?? EDWARD D. SCHLEMMER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. REGAN STROMAN LYNCH DEFENDANT 2008-6141 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, January 12, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, January 16, 2009 at 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. FOR THE COURT, By: Is/ Hubert X. Giko 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 4kyf f, INVA` AS;Ni d kN[Pr) um Z 0 _£ Wd £ ! Nvf fiooz AdViONOHi AQHI 30 ?-l Q JAN 9 n 2009 Crr EDWARD D. SCHLEMMER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW REGAN STROMAN LYNCH, NO. 2008-6141 Defendant IN CUSTODY r ORDER G'P'( AND NOW, this Z day of January, 2009, the Conciliator being advised the parties have reached an agreement, the Conciliator relinquishes jurisdiction. Hubert X. Gilroy, Custody Conciliq ? °,.c, s tel. ?'' e??" ? ? , _. ^. o ?? f `7 ?/ ...° EDWARD D. SCHLEMMER, Plaintiff V. REGAN K. LYNCH Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY : NO. 08-6141 CIVIL STIPULATION THIS STIPULATION, made this 15th day of January, 2009, between Robert Lieberman, Esquire, counsel for Edward D. Schlemmer (hereinafter "Father"), land The Family Law Clinic, counsel for Regan K. Lynch (hereinafter "Mother"), concerns the custody of Kyle Schlemmer, born March 11, 2005, and Keller Schlemmer, born November 2, 2006, (hereinafter "the children"). Mother and father desire to enter into an agreement as to the custody o the children that supersedes the Court Order of November 18, 2008. Mother and Father have instructed their legal counsel to stipulate to the following. 1. Mother and Father shall share legal custody of the children. 2. Father shall have primary physical custody of the children. 3. Upon agreement, Father will permit Maternal Grandfather, Lyle take the children to visit Mother upon such terms and conditions as deems to be in their best interest. 4. Neither parent shall be under the influence of alcohol or illegal drug the children are in their custody, nor shall they allow a third party tc to while ?doso while the children are in their presence. r ` 5. Mother shall have right to petition to modify custody upon her incarceration. Christina Ferreira Certified Legal Intern aKI - OBERT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Counsel for Plaintiff FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 Fax (717)243-3639 ?. r Robert Lieberman, Esq 500 North Third Street Twelfth Floor Harrisburg, PA 17108 Counsel for Father (717) 236-1485 Fax (717) 236-777 from ?, , ..? `^? ,.k "_ # ?"'' i ? -? f .) .. ?? I `? tiV.r 7R 0 3 20096 EDWARD D. SCHLEMMER, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, : PENNSYLVANIA V. : CIVIL ACTION - LAW : IN CUSTODY REGAN K. LYNCH, Defendant : NO. 08-6141 COURT ORDER AND NOW, this day of "4,--,2009, IT IS HEREBY ORDERED AND DECREED that the attached stipulation executed by counsel for the parties is entered as an Order of Court. C: B. Lieberman, Esquire, 500 N. Third St., Floor 12, Harrisburg, PA 17101 ,/'Robert E. Rains, Esquire, FAMILY LAW CLINIC, 45 N. Pitt St., Carlisle, PA 17013 C?O ? ? S rrt? t /07 e Q M JJ tY. ? /? _.y +I Uu. t EDWARD D. SCHLEMMER, Plaintiff V. REGAN K. LYNCH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Custody :NO. 08 - 6141 CUSTODY AGREEMENT THIS AGREEMENT, made this?Yday of , 2009, between Regan K. Lynch, hereinafter Mother, and Edward D. Schlemmer, hereinafter Father, concerns the custody of their children: Kyle Schlemmer, born March 11, 2005, and Keller Schlemmer, born November 2, 2006. Mother and Father desire to enter into an agreement as to the custody of the children. Mother and Father agree to the following. 1. Mother and Father shall share legal custody of the children. 2. Mother and Father shall share physical custody of the children as agreed upon by the parties. 3. Mother and Father will agree upon drop off and pick up times and locations. 4. Mother and Father will agree upon which holidays the children will spend with each parent. 5. Mother and Father will notify each other of all medical care the children receive while in the parent's care. Mother and Father will notify the other immediately of medical emergencies which arise while the children are in that parent's care. 6. Neither parent will do anything which may estrange the children from the other party, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children's love and respect for the other parent. 7. Neither parent shall be under the influence of alcohol or illegal drugs while the children are in his or her custody, nor shall they allow a third party to do so while the children are in his or her presence. 8. The Family Law Clinic represents Mother and Attorney Robert Lieberman, Esquire represents Father in this matter. 9. The parties intend to be bound by the terms of this agreement and intend for this Agreement to be made an Order of Court. Edward D. Schlemmer, Plaintiff D?. Robert Lieberman, Esquire Counsel for Plaintiff 500 North Third Street Twelfth Floor Harrisburg, PA 17108 (717) 236-1485 1AAV J.4 2G/ eg K. Lync , De ndant Adam Britcher Certified Legal Intern Counsel for Defendant 'ROBE E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX MEGAN RIESMEYER Counsel for Defendant FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 Fax (717)243-3639 Ff! F i';E OF THE `OTAIPY 2009 JUL 28 A N c, 0 ,ate" EDWARD D. SCHLEMMER, Plaintiff V. REGAN K. LYNCH, Defendant JUL 2 9 2009 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :CUSTODY NO. 08 - 6141 CUSTODY ORDER AND NOW, this r?'C1 day of , 2009 as per the attached and signed Custody Agreement, the following terms are approved and entered as an Order of Court: 1. The Order of Court of February 6, 2009 is replaced by the following agreement. 2. Mother and Father shall share legal custody of the children. 3. Mother and Father shall share physical custody of the children as agreed upon by the parties. 4. Mother and Father will agree upon drop off and pick up times and locations. 5. Mother and Father will agree upon which holidays the children will spend with each parent. 6. Mother and Father will notify each other of all medical care the children receive while in the parent's care. Mother and Father will notify the other immediately of medical emergencies which arise while the children are in that parent's care. 7. Neither parent will do anything which may estrange the children from the other party, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children's love and respect for the other parent. 8. Neither parent shall be under the influence of alcohol or illegal drugs while the children are in his or her custody, nor shall they allow a third party to do so while the children are in his or her presence. BY THE C /I-T: c OBERT B. LIEBERMAN, Esq., for Father Five Hundred North Third Street Twelfth Floor PO Box 1004 Harrisburg, PA 17108 vl- AMILY LAW CLINIC, for Mother 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 Fax (717)243-3639 CO "es emu t Lc i 7/3o)/O9 tr/? J. RLED-C OF TH, R"' T H, 110TARY 2009 JUL 30 Pf1 12: 27