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09-3546
CHRISTIAN R. QUIGLEY, JR.., Plaintiff V. LORRI A. LIVENGOOD, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. -r.c? CIVIL ACTION - LAW CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Christian R. Quigley, Jr., residing at 1204 Edinburg Circle New Cumberland, Pa. 17070. 2. Defendant is Lorri Livengood, residing at 6250 Galleon Drive, Mechanicsburg, PA 17050. 3. Plaintiff seeks custody of the following children: Name Present Address Date-of-Birth Julia M. Quigley 6250 Galleon Drive April 16, 1992 Mechanicsburg, PA 17050 Kyle C. Quigley 6250 Galleon Drive December 5, 1994 Mechanicsburg, PA 17050 Kristin L. Quigley 6250 Galleon Drive October 4, 1996 Mechanicsburg, PA 17050 Josiah D. Quigley 6250 Galleon Drive July 18, 1999 Mechanicsburg, PA 17050 Jeremiah B. Quigley 6250 Galleon Drive March 30, 2001 Mechanicsburg, PA 17050 4. The children were born in wedlock. The children are presently in the custody of Defendant Mother, residing at 6250 Galleon Drive, Mechanicsburg, PA 17050. 5. During the past five (5) years, the children have resided with the following persons the following address(es): Name Address Dates Defendant Mother 6250 Galleon Drive February 2009 to Mechanicsburg, PA 17050 present Defendant Mother 305 Liberty Court 2005 to February 2009 Mechanicsburg, PA 17055 6. The mother of the children is Lorri Livengood currently residing at 6250 Galleon Drive, Mechanicsburg, PA 17050. She is single. 7. The father of the children is Christian R. Quigley, Jr. currently residing at 1204 Edingburg Circle, New Cumberland, PA 17070. He is single. 8. The relationship of Plaintiff to the children is that of natural father. Plaintiff currently resides with the following person(s): Name Relationship Self 9. The relationship of Defendant to the children is that of natural mother. Defendant currently resides with the following person(s):. Name Relationship Brian* Defendant Mother's friend *resides there sometimes. 10. Plaintiff has participated as a parry or a witness, or in any other capacity in other litigation concerning the custody of the children in this or any other Court: Court of Common Pleas of Fairfield County, Ohio, Division of Domestic Relations, Case No. 05 DR 73. The parties entered into a Shared Parenting Decree as part of their Domestic Relations Support Action. No Court Hearings were ever held in Ohio. The action was transferred to Cumberland County, and subsequent Order permitting said transfer to Pennsylvania are attached hereto as Exhibit No. 1 and Exhibit No. 2. 11. The Defendant and the children have resided continuously in Pennsylvania since approximately July of 2005. 12. The Ohio Domestic Relations Action was transferred to Cumberland County, Pennsylvania in 2008 to Civil Action 115-5-2008. 13. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 14. 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 except possibly the children's step maternal grandmother, Camille Livengood of 5256 Foxcroft Court, Sarasota, Florida 34232. 15. The best interest and permanent welfare of the children will be served by granting the relief requested because: a. Defendant Mother Lorri A. Livengood recently re-enlisted with the United States Air Force, Air National Guard or Air Force Reserves and is going on active duty outside of the Cumberland County, PA from July 1, 2009 through September 30, 2009 and is not able to physically care for the parties minor children during said time; and b. Plaintiff Father resides in New Cumberland, Cumberland County, Pennsylvania and he is able to provide for the primary physical custody of the parties minor children while the Defendant is on any period of active duty with the Air Force, Air National Guards, or Air Force Reserves; and C. Defendant Mother plans to send the children to Sarasota, Florida to be in the physical custody of their Step maternal grandmother which arrangement is not acceptable to Plaintiff Father nor is such a plan in the best interest and permanent welfare of the minor children; and d. The minor children have been in Cumberland Valley School District for the past four years and it is not in their best interests that they change schools to Sarasota, Florida for September 2009; and e. Plaintiff Father is ready, able and willing to have primary physical custody and the law favors a parent over a non parent in any custody dispute. f. Plaintiff's father, mother and step mother all reside locally and are able to watch the minor children on any occasions when Plaintiff Father may have to travel for work. Plaintiff has significant ability to plan his work travel schedule. 15. 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, Plaintiff Father requests the Court grant him primary physical custody of the parties' five minor children from July 1, 2009 through September 30, 2009 and during any and all subsequent periods of Defendant Mother's periods of active duty with the United States Air force, Air National Guard or Air Force Reserves, and grant the parties shared legal custody of the minor children.. submitted, UGH, PC Date: S^ A . VI Jo eQy1 L u ; Esquire Alto D No.: 64 1 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Christian R. Quigley, Jr. VERIFICATION I, Christian R. Quigley, Jr., hereby verify and state that the facts set forth in the foregoing pleading are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn ver:.fication to authorities. DATE: S Z?? Christian . Quigle r. IN THE COURT OF COMMOXS? FAIRFIELD COUNTY, OHIO DIVISION O D C RELATIONS 2N FEB -2 AM 10: 06 Defendant. Case No. 05 DR 73 JUDGE JACKSON SHARED PARENTING DECREE This cause came before the Court on November 9, 2005, upon the motion of the parties for LORI L. QUIGLEY, vs. UL- CLERK, C,;: LOMTS Plaintiff, FAIRi ;EL D r, ;-;, 0,4 10 CHRISTIAN R. QUIGLEY, JR., an order granting the parties shared parenting of the minor children pursuant to the Shared Parenting Plan jointly submitted by the parties. WHEREFORE, upon review of the plan, the Court approves said plan and grants the parties shared parenting under the terms of the shared parenting plan and makes the provisions of the plan orders of this Court. The Court hereby orders, adjudges and decrees that the plan is hereby incorporated into this decree and is in the best interest of the minor children, Julia M. Quigley, born April 16, 1992, Kyle C. Quigley, born December 5, 1994, Krista L. Quigley, born October 4, 1996, Josiah D. Quigley, born July 18, 1999 and Jeremiah B. Quigley, born March 30, 2001. STATUTORY NOTICES A. ADDRESS CHANGE NOTICE: EACH PARTY TO THIS SUPPORT ORDER MUST NOTIFY THE CHILD SUPPORT ENFORCEMENT AGENCY IN WRITING OF HIS OR HER CURRENT MAILING ADDRESS, CURRENT RESIDENCE ADDRESS, TELEPHONE NUMBER, CURRENT DRIVER'S LICENSE NUMBER, AND OF ANY CHANGES IN THAT INFORMATION. EACH PARTY MUST NOTIFY THE AGENCY OF ALL CHANGES UNTIL FURTHER NOTICE FROM THE COURT. IF YOU ARE THE OBLIGOR UNDER A CHILD. SUPPORT ORDER AND YOU FAIL TO MAKE THE ?L4 ?.- - M, REQUIRED NOTIFICATIONS YOU MAY BE FINED UP TO $50.00 FOR A FIRST OFFENSE, $100.00 FOR A SECOND OFFENSE, AND $500.00 FOR EACH SUBSEQUENT OFFENSE. IF YOU ARE AN OBLIGOR OR OBLIGEE UNDER ANY SUPPORT ORDER AND YOU WILLFULLY FAIL TO MAKE THE REQUIRED NOTIFICATIONS YOU MAY BE FOUND IN CONTEMPT OF COURT AND BE SUBJECTED TO FINES UP TO $1,000.00 AND IMPRISONMENT FOR NOT MORE THAN 90 DAYS. IF YOU ARE AN OBLIGOR AND YOU FAIL TO MAKE THE REQUIRED NOTIFICATIONS YOU MAY NOT RECEIVE NOTICE OF THE FOLLOWING ENFORCEMENT ACTIONS AGAINST YOU: IMPOSITION OF LIENS AGAINST YOUR PROPERTY; LOSS OF YOUR PROFESSIONAL OR OCCUPATIONAL LICENSE, DRIVER'S LICENSE, OR RECREATIONAL LICENSE; WITHHOLDING FROM YOUR INCOME; ACCESS RESTRICTION AND DEDUCTION FROM YOUR ACCOUNTS IN FINANCIAL INSTITUTIONS; AND ANY OTHER ACTION PERMITTED BY LAW TO OBTAIN MONEY FROM YOU TO SATISFY YOUR SUPPORT OBLIGATION. B. CHILD SUPPORT TERIvIIlVATION NOTICE: THE RESIDENTIAL PARENT OR THE PERSON WHO OTHERWISE HAS CUSTODY OF A CHILD FOR WHOM A SUPPORT ORDER IS ISSUED IS ALSO ORDERED TO IMMEDIATELY NOTIFY, AND THE OBLIGOR UNDER A SUPPORT ORDER MAY NOTIFY, THE FAIRFIELD COUNTY CHILD SUPPORT ENFORCEMENT AGENCY OF ANY REASON FOR WHICH THE SUPPORT ORDER SHOULD TERMINATE, INCLUDING, BUT NOT LIMITED TO, THE CHILD'S ATTAINMENT OF THE AGE OF MAJORITY IF THE CHILD NO LONGER ATTENDS AN ACCREDITED HIGH SCHOOL ON A FULL-TIME BASIS AND THE SUPPORT ORDER DOES NOT PROVIDE FOR THE DUTY OF SUPPORT TO CONTINUE PAST THE AGE OF MAJORITY; THE CHILD CEASING TO ATTEND SUCH A HIGH SCHOOL ON A FULL-TIME BASIS AFTER ATTAINING THE AGE OF MAJORITY, IF THE SUPPORT ORDER DOES NOT PROVIDE FOR THE DUTY OF SUPPORT TO CONTINUE PAST THE AGE OF MAJORITY; OR THE DEATH, MARRIAGE, EMANCIPATION, ENLISTMENT IN THE ARMED SERVICES, DEPORTATION OR CHANGE OF LEGAL OR PHYSICAL CUSTODY OF THE CHILD. C. RELOCATION NOTICE: Pursuant to Ohio Revised Code Section 3109.051(G) the parties hereto are hereby notified as follows: IF THE RESIDENTIAL PARENT INTENDS TO MOVE TO A RESIDENCE OTHER THAN THE RESIDENCE SPECIFIED IN THE COURT ORDER, THE RESIDENTIAL PARENT SHALL FILE A NOTICE OF INTENT TO RELOCATE WITH THIS COURT, ADDRESSED TO THE ATTENTION OF THE RELOCATION OFFICER, UNLESS OTHERWISE ORDERED PURSUANT TO O.R.C. SECTIONS 3109.051(G)(2),(3), AND (4), A COPY OF SUCH NOTICE SHALL BE MAILED BY THE COURT TO THE OTHER PARENT. UPON RECEIPT OF THE NOTICE, THE COURT, ON ITS OWN MOTION OR THE MOTION OF EITHER PARTY, MAY SCHEDULE A HEARING WITH NOTICE TO BOTH PARTIES TO DETERMINE 2 WHETHER IT IS IN THE BEST INTEREST OF THE CHILD TO REVISE THE RESIDENCE SCHEDULE. D. RECORDS ACCESS NOTICE: Pursuant to Ohio Revised Code Sections 3109.051(H) and 3319.321(B)(5)(a) the parties hereto are hereby notified as follows: EXCEPTING AS SPECIFICALLY MODIFIED OR OTHERWISE LIMITED BY COURT ORDER, AND SUBJECT TO O.R.C. SECTIONS 2301.35 (G)(2) and 3319.321(F), THE PARENT WHO IS NOT THE RESIDENTIAL PARENT IS ENTITLED TO ACCESS TO ANY RECORD THAT IS RELATED TO THE CHILD, UNDER THE SAME TERMS AND CONDITIONS AS THE RESIDENTIAL PARENT, AND TO WHICH SAID RESIDENTIAL PARENT IS LEGALLY PROVIDED ACCESS. ANY KEEPER OF A RECORD WHO KNOWINGLY FAILS TO COMPLY WITH THIS ORDER IS IN CONTEMPT OF COURT. E. DAY CARE CENTER ACCESS NOTICE: Pursuant to Ohio Revised Code Section 3109.051(1), the parties hereto are hereby notified as follows: EXCEPTING AS SPECIFICALLY MODIFIED OR OTHERWISE LIMITED BY COURT ORDER, AND IN ACCORDANCE WITH O.R.C. SECTION 5104.011, THE PARENT WHO IS NOT THE RESIDENTIAL PARENT IS ENTITLED TO ACCESS TO ANY DAY CARE CENTER THAT IS OR WILL BE ATTENDED BY THE CHILD WITH WHOM VISITATION IS GRANTED, TO THE SAME EXTENT THAT THE RESIDENTIAL PARENT IS GRANTED ACCESS TO THE CENTER F. SCHOOL ACTIVITIES NOTICE: Pursuant to Ohio Revised Code Section 3109.051 (J), the parties are hereby notified as follows: EXCEPTING AS SPECIFICALLY MODIFIED OR OTHERWISE LIMITED BY COURT ORDER, AND SUBJECT TO O.R.C. SECTION 3319.321(F), THE PARENT WHO IS NOT THE RESIDENTIAL PARENT IS ENTITLED TO ACCESS, UNDER THE SAME TERMS AND CONDITIONS AS THE RESIDENTIAL PARENT, TO ANY STUDENT ACTIVITY THAT IS RELATED TO THE CHILD AND TO WHICH THE RESIDENTIAL PARENT OF THE CHILD LEGALLY IS PROVIDED ACCESS. ANY SCHOOL EMPLOYEE OR OFFICIAL WHO KNOWINGLY FAILS TO COMPLY WITH THIS ORDER IS IN CONTEMPT OF COURT. G. WAGE WITHHOLDING NOTICE: ALL CHILD SUPPORT AND/OR SPOUSAL SUPPORT UNDER THIS ORDER SHALL BE WITHHELD OR DEDUCTED FROM THE INCOME OR ASSETS OF THE OBLIGOR PURSUANT TO A WITHHOLDING OR DEDUCTION NOTICE OR APPROPRIATE COURT ORDER ISSUED IN ACCORDANCE WITH SECTION 3113.21 OF THE REVISED CODE OR A WITHDRAWAL DIRECTIVE ISSUED PURSUANT TO SECTION 3113.214 OF THE 3 REVISED CODE. AND SHALL BE FORWARDED TO THE OBLIGEE IN ACCORDANCE WITH SECTIONS 3113.21 TO 3113.213 OF THE REVISED CODE. NOTICES REQUIRED BY THE PRECEDING LANGUAGE SHALL BE SENT TO THE FAIRFIELD COUNTY CHILD SUPPORT ENFORCEMENT AGENCY, 239 WEST MAIN STREET, LANCASTER, OHIO 43130, ATTN: NOTICE OFFICER This decree is effective as of the date filed. S. FARRELL CKSON, JUDGE APPROVED: Per Authorization Paul R. Panico 0047196 300 South Second St., 2'd Floor Columbus, Ohio 43215 (614) 224-4004 Attorney for Plaintiff F. TOBY DANIEL & ASSOCIATES 49 Hill Road North Pickerington, Ohio 43147 (614) 837-5992 Attorney for Defendant Signed memo entry 11-9-OS Christian R. Quigley, Jr., Defendant 4 Signed memo entry 11-9-05 Lorri L. Quigley, plaintiff IN THE COURT OF COMMON PLEAS OF FAIRFIELD COUNTY, OHIO DIVISION OF DOMESTIC RELATIONS LORI L. QUIGLEY, Plaintiff, vs. Case No. 05 DR 73 CHRISTIAN R. QUIGLEY, JR., JUDGE JACKSON Defendant. SHARED PARENTING PLAN The parties hereto, Lorrmi L. Quigley, Mother, and Christian R. Quigley, Jr., Father, are parents of the minor children, Julia M. Quigley, born April 16, 1992, Kyle C. Quigley, born December 5, 1994, Krista L. Quigley, born October 4, 1996, Josiah D. Quigley, born July 18, 1999 and Jeremiah B. Quigley, born March 30, 2001. The parties agree that it is in the best interest of the minor children that the parents share in the parenting. The parties agree to the following shared parenting plan: 1. Each party shall be the residential parent of the children, however, Mother shall be the residential parent for purposes of school registration. The parties acknowledge Mother has relocated to the Harrisburg, Pennsylvania area, with the children. It is possible that Father will also relocate to that area. 2. The companionship schedule shall be liberal and flexible. Father shall have extensive time with the children any time he travels to Pennsylvania, and shall have parenting time according to the Fairfield County Rule 17.0 Long Distance Companionship Schedule. The Father shall provide reasonable notice, preferably at least three (3) days, of his intention to exercise his parenting time. If Father relocates to Pennsylvania, then the parenting time schedule will be according to the Fairfield County Rule 17.0 Companionship Schedule. The children shall reside with Mother at all other times. A copy of Rule 17 is attached as Exhibit A. 3. Each parent shall be reasonable and cooperative in attempting to mutually agree to additional times that the children may be with the other parent for special occasions and events that cannot be anticipated herein. 4. Effective July 1, 2005, Father shall pay Mother the sum of Two Thousand Thirty- Nine and 81/100 Dollars ($2,039.81) per month, plus a two percent (2%) processing charge, for a total of Two Thousand Eighty and 61/100 Dollars ($2,080.61) per month as and for child support for the five minor children. A child support worksheet is attached as Exhibit B. Child support shall be paid via a wage deduction order issued to Husband's employer. All child support arrearage accrued prior to July 1, 2005, if any, shall be reduced to (0) zero by the Fairfield County Child Support Enforcement Agency. Each party's obligation for support shall continue until the death, emancipation, or the attainment of the age ofmajority ofthe children, as provided in Ohio Revised Code Section 3103.03, and shall continue so long as the children continuously attend, on a full time basis, any recognized and accredited high school, even when the children have attained the age ofmajority, however, child support shall not continue past the child's nineteenth (19`h) birthday. Each party's child support obligation shall terminate if the child di or ecomes emancipated. 5. For the tax year 2006, and ch year thereafter until modified by agreement or by the court, Father shall claim the minor children Kyle, Krista, Josiah and Julia as tax exemptions and Mother shall claim the minor child Jeremiah as a tax exemption. other becomes employed and has an annual adjusted 30 oeo. o?? gross income in excess of $i;?, then Mother shall be permitted to claim Josiah and Jeremiah for that tax year. Mother shall provide Father all 1099's and W-2s by February 15'h to document her adjusted gross income. If documented, Father shall execute IRS form 2 to permit Mother to claim both children that year. If Mother fails to provide Father documentation of her adjusted gross income by February 15`h, then Father shall be permitted to claim four of the children. When there are only two children that can be taken as tax exemptions, then each party shall claim one child each year. When only one child is eligible to be claimed by the parents, then the parties will alternate taking the exemption each year with the Father claiming the exemption in the first year in which there is only one eligible child remaining. F--"L "**^' `f o" 2oay'? -}?? ji,M4;#) Sk-tLL P.l+ To,:.tl Tie ?ph•cf?er "Of',L a ?M? ot?tl•'?e A-VJ 6. Each party shall be responsible for maintaining and providing a proper residence forte ??? `eJ the children and shall otherwise be responsible for maintaining and providing for the children during t-I?sw?«?? the time that the children are residing with them. 7. Father will maintain a comprehensive health insurance plan for the benefit of the eve ate" A minor children. Father and mother shall each pay 50% of any and all uninsured or unreimbursed ?%*I&L medical, optical, dental, orthodontic, psychological, psychiatric or prescription drug expenses after Ack? said expenses have been submitted to any and all available insurance. ?.,?r1aA aAAo 8. The parties acknowledge that each has the ability to provide guidance, concern and a proper home life for the minor children. The parties agree to share in the parenting of the minor .J children so that each party may continue having a full and active role in providing a sound environment for the minor children. The parties agree to promote a healthy and beneficial relationship with the other parent and will not demean, speak or act out negatively in any manner that would damage the natural flow of love and caring between both parents and the minor children. 9. The parties shall consult with each other with respect to all matters of major importance affecting the welfare of the children. Any and all major decisions made concerning the children's health, education and welfare shall be made jointly by the parties, including choice of child care providers. 3 A. Decision Making. Notwithstanding the foregoing, the following shall apply in the event the Parents cannot or do not agree on education-related decisions, activities and functions of the children, and health-related decisions concerning the minor children: (1) Education-Related Decisions (a) It is the goal that the Parents make all education-related decisions regarding the children, including but not limited to, entrance into school, and all ongoing school-related issues, jointly, and all best efforts shall be put forth by both Parents toward this goal. E&4, 9Aee-0 s hail Q? a „{ ho,L F C5 0%,) u •1,cy7'v en Cost F+,2 Peej"oaL [uR 7Yr. Hoz -I-,LO SeOea w, All . TKf % r'"If a decision needs to be reached concerning the children, Mother and Father shall each make the other aware of the issue, including all possibilities and the p* , y pros and cons of each as relayed to her/him, all documentation, contact information, "sue websites, costs, etc., within 24 hours. The other parent shall respond with his/her ??. suggestions/positions within the next 24 hours. If the parents are unable to agree on the course of action after this dialogue they shall jointly and at the same time, consult with the appropriate school professional(s), including teachers, tutors and the v principal, to obtain any and all relevant information on the issue and to share his/her points of view and obtain that professional's opinion. In the event that the Parents still cannot reach an agreement on the course of action to be taken, AFTER all the above has transpired in good faith, for the first instance of deadlock Mother shall be entitled to make the final decision, promptly providing Father with notice of said decision. For the second such deadlock, Father shall be entitled to make the final decision, promptly providing Mother with notice of said decision. Thereafter, final decision making authority shall be alternated. 4 (2) Activities and Functions of the Children. (a) Each Parent shall provide the other with copies of all potential activity and function information for the children as soon as she/he is in receipt of same, including, but not limited to, schedules, names, telephone numbers and e-mail addresses of activity/function leaders, and activity location(s). Any relevant/ substantive information concerning the children and their activities/functions that may be communicated orally as opposed to in writing shall also be promptly communicated to the other Parent. Both Parents are permitted to attend at the same time any activity or function in which the children are involved. (b) It is the goal that the Parents make all activity/function related decisions regarding the children jointly and all best efforts shall be put forth by both Parents toward this goal. (c) Regardless of where the children are living, their participation in existing and renewed extracurricular activities, whether school related or otherwise, shall continue uninterrupted. This would include "practices" as well as competitive play, where applicable. The parent with whom they are residing at the time of the activity shall provide the transportation to these activities. Notice of all extracurricular activities, school related, or otherwise, in which the children participate, schedules of all extracurricular activities (handwritten, if no formal schedule is provided by the (activity) and the name of the activity leader (including address and telephone number if reasonably available) shall be exchanged between the parents. Once accomplished, it is the responsibility of the possessor parent to maintain this information and use it to assure the children's participation in their activities in a timely manner. 5 With respect to adding new activities, these will be added when a child expresses a strong interest or when it has been recommended for a specific purpose (e.g. to improve a motor skill, or to improve ability to socialize, or to improve eye- hand coordination, etc.).The parents will share the cost of two activities per quarter per child, each paying half. The activities chosen to share in the cost will be the most costly of those in which the child participates for that quarter. If equipment is required, the parents will equally share in the cost of that as well. The parents shall also pay for any school related fees above the standard tuition costs. A full accounting for each parent's expenditures for the children's activities costs and school related fees will be provided by the payor of the expense to the other parent on a monthly basis. On or before the 15`'' of the following month the parent who owes the net difference shall remit to the other any amount owed. Each Parent shall notify the other Parent as soon as information is available (preferably by April l" of each year) regarding the dates of all summer activities in which the minor children will participate. In the event the parents cannot agree to a specific extra-curricular activity program for any child in a specific year, for the first instance of deadlock Father shall be entitled to make the final decision, promptly providing Mother with notice of said decision. For the second such deadlock, Mother shall be entitled to make the final decision, promptly providing Father with notice of said decision. Thereafter, final decision making authority shall be alternated. (3) Health-Related Decisions. (a) Health-related decisions shall be defined as medical, dental, orthodontia, mental health and optical needs of the children. 6 (b) Emergency health decisions may be made by each Parent while exercising parenting time with the children. That Parent shall immediately inform the other Parent of the circumstances of the emergency and the decision. (c) Mother or Father shall make appointments for the children for their well-care and shall inform the other parent of the date, time, and location of all appointments as soon as scheduled. (d) Both Parents may attend all appointments. If either parent cannot attend the appointment, the following shall apply: within twenty-four hours, Mother/Father shall inform Father/Mother of the outcome of the appointment and provide all information (including, but not limited to, copies of all documentation/literature provided to the Parent who attends the appointment) from the appointment. Further, Mother/Father shall provide instructions regarding any care to be provided to the children including, but not limited to, the administering of medications and any follow-up appointments. (e) It is the goal that the Parents make all health-related decisions regarding the children jointly and all best efforts shall be put forth by both Parents toward this goal. (f) If the Parents cannot agree on a decision for routine and/or necessary health care, a second opinion will be sought by both Parents, with the cost of the second opinion being paid by each Parent equally and respectively, and the majority opinion will be the course of action that is pursued. Notwithstanding, in the event that the original diagnosing physician believes that an immediate decision is necessary (i.e., there is no time to pursue second opinions) then for the first instance of deadlock Mother shall be entitled to make the final decision, promptly providing 7 Father with notice of said decision. For the second such deadlock, Father shall be entitled to make the final decision, promptly providing Mother with notice of said decision. Thereafter, final decision making authority shall be alternated. (g) Mother or Father has the right to execute any consent forms necessary for treatment. 10. If either of the parties has knowledge of any illness or accident or other circumstance seriously affecting the health or welfare of the children, the Mother or Father, as the case may be, shall promptly notify the other, and both parties shall have unlimited visitation privileges in any institutional setting. 11. Each party shall be entitled to complete information/records from any physician, dentist, orthodontist, psychologist, psychiatrist, consultant or other specialist who treats or examines the children. 12. Each party shall be entitled to complete detailed information from any teacher/school official and shall be entitled to be furnished with copies of all reports or records with respect to the children's education. 13. The children shall be allowed to communicate by telephone with each parent on a reasonable basis, and each parent may telephone the children on a reasonable basis. 14. Each parent must keep the other informed of his or her current address and telephone number (home and work) at all times. 15. Neither parent shall permanently remove the children from the Harrisburg, Pennsylvania area without a court order, or the written permission of the other parent. 8 Signed by Christian R. Quigley, Jr. this Witness STATE OF OHIO COUNTY OF FAIRFIELD ss: day of N Ov f L-'3o r , 2005. C . s ianR. uigl , Jr. Before me, a Notary Public in and for said County, personally appeared the above named Christian R. Quigley, Jr. known to me to be the party described in and who executed the foregoing instrument and acknowledged that he executed the same of his own free act and deed, for the uses and purposes therein mentioned. IN WITNESS WHEREOF, I have hereunto subscribed my name and affixed my official seal this 9 ~ day of N o-- --?.?• .2005. Notary Public 10 Witness LbrriL- gleyI Witness STATE OF _ COUNTY OF ss: Before me, a Notary Public in and for said County and State, personally appeared the above named Lorri L. Quigley known to me to be the party described in and who executed the foregoing instrument and acknowledged that she executed the same of her own free act and deed, for the uses and purposes herein mentioned. IN WITNESS WHEREOF, I have hereunto subscribed my name and affixed my official seal this Z day of 2005. Signed by Lorri L. Quigley this L ?.7 day of 2005. SIGNED IN THE-PRESENCE OF: Notary Public II .. .?? ??...? v. v..r.?JC vc1 I ? JVIIWOI G VJJ VV 1L MIL 1 1• Z©0)9L 26 4A, IN THE COURT OF COMMON PLEAS, FAIRFIELD C( w ? Y DOMESTIC RELATIONS DIVISION ? " po LORI L. QUIGLEY, NK4, LORRI A. LIVENGOOD PLAINTIFF, vs. CHRISTIAN R. QUIGLEY, JR. DEFENDANT. X13 CASE NO. 2005 DR?-7- JUDGE KATHY S. MOWRY MAGISTR.aTE LAURA B. SMITH AGREED JUDGi<IE\T El\TRIr• This matter came on for hearing before the Court on November 6. 2007.. on the Motion of Defendant for modification of child support and spousal support. The Plaintiff was represented by counsel but did not appear: Defendant 'was present tvith counsel. The parties had entered into a Memorandum agreement, and the Court being well advised of the premises. it is ORDERED. ADJUDGED, and DECREED that: 1 The current child support obligation of the Defendant is S2,039.81 plus processing charge. The child support payment to be charged effective as of the filing date of the Vlotion of March 5, 20071 shall be 51,511.80, plus processing charge. A Child Support Calculation Worksheet is attached herewith. 7 t Pace I of E4, 1.4 NQ a ?Ctr y J 1 V f V../ . LVd JCS a JV? ?Wp? L M. J V U 1 L ...,r J ? r e ( f 2• Effective November 6. 2007. the Plaintiff is hereby responsible to provide health insurance for the minor children. In the event health insurance is no longer available to the Plaintiff: the responsibility to provide health insurance for the minor children shall revert to the Defendant. ?- The parties agree for this matter to be transferred to the proper jurisdiction in Pennsylvania upon application by either of the parties. `l• All other orders of the Court shal l remain in effect. IT IS SO ORDERED. APPROVED: Sys ??-- Facsimile $iQnattrre on File ! ?11912007 Ctertt"s Certificate Paul R. Panico Ohio Sup. Cr. Reg. No. 0047196 ?ftate' Fsirfieid County, ss: 4, fihe wtdomigr>ed Clerk of Courts of said County, hereby 00* Attorney for Plaintiff ?qw foregoing is a true snd Dopy the filed with of law `?. Ckrh of CotMs rroid W. Schwarz ,.' Ohio Sup. Ct. Reg. _Vo. 0047528 DW* Trial Attornev for Defendant 1P. 31 Ll Alk, a ;j Page 2 of 2 i F vry r 4 L :.v. i :a. i I .. ffl ii . itR •.? lGSSti p,/ • a4 a as ffy3 CHRISTIAN R. QUIGLEY, JR. IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-3546 CIVIL ACTION LAW LORRI A. LIVENGOOD IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, June 02, 2009 , 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, July 01, 2009 at 10:00 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: /s/ Dawn 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 FILED-A %,F THE ril r r 2909 AU111-2 Pil 'I: 3o t zeyoore fJUN E 92009 3 CHRISTIAN R. QUIGLEY, JR. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2009-3546 CIVIL ACTION LAW LORRI A. LIVENGOOD Defendant IN CUSTODY ORDER OF COURT --.. 2009, u on AND NOW, this ~~ day of ~l./ A! ~ P consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Lorri A. Livengood, and the Father, Christian R. Quigley. Jr., shall have shared legal custody of Julia Quigley, born April 16, 1992, Kyle Quigley, born December 5, 1994, Kristin Quigley, born October 4, 1996, Josiah Quigley, born July 18, 1999, and Jeremiah Quigley, born March 30, 2001. Major decisions concerning the Children including, but not necessarily limited to, their health, welfare, education, religious training and upbringing shall be made jointly by the parties after discussion and consultation with a view toward obtaining and following a harmonious policy in each Child'S best interest. Neither party shall impair the other party's rights to shared legal custody of the Children. Neither party shall attempt to alienate the affections of the Children from the other party. Each party shall notify the other of any activity or circumstance concerning the Children that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of'the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the Child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. 5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to either party as a parent as authorized by statute. 2. During any periods when the Mother is unavailable to provide care for the Children due to her military service, the Father shall have primary physical custodv of the Children. During periods when the Mother is available to provide care for the Children, the parties shall resume the current schedule under which the Mother has primary custody of the Children and the Father has partial custody as previously arranged between the parties. 3. The non-custodial parent shall be entitled to have liberal reasonable telephone contact with the Children. 4. As soon as possible following the custody conciliation conference, the Mother shall provide to the Father all medical insurance information for the Children as well as the names and telephone numbers of medical, dental and other treatment or care providers for the Children. 5. The parties agree that Pennsylvania has jurisdiction over this custody matter. 6. Nothing in the military Family Care Certification form on which the Mother may list alternative caregivers for the Children, shall affect the Father's custodial rights under this Order. 7. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THEE , J. cc: ~nne Harrison Clough, Esquire -Counsel for Father Kelly A. Sparvieri, Esquire -Counsel for Mother t ~,S /Y! c`t t l~ to f 3 c.~v`~ ~~ CHRISTIAN R. QUIGLEY, JR. Plaintiff vs. LORRI A. LIVENGOOD Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2009-3546 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPO1l2T IN ACCORDANCE WITH CUMBERLAND COUN~fY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME Julia Quigley Kyle Quigley Kristin Quigley Josiah Quigley Jeremiah Quigley DATE OF BIRTH April 16, 1992 December 5, 1994 October 4, 1996 July 18, 1999 March 30, 2001 CURRENTLY l[N CUSTODY OF Mother Mother Mother Mother Mother 2. A custody conciliation conference was held on June 23, 2009, with the following individuals in attendance: the Father, Christian R. Quigley, Jr., with his counsel, Joanne Harrison Clough, Esquire, and the Mother, Lorri A. Livengood, with her counsel, Kelly A. Sparvieri, Esquire. 3. The parties agreed to entry of an Order in the form as attached. 1 o, / Date Dawn S. Sunday, Esquire Custody Conciliator F~I.FC--~,°«r~,F 2UG9 JEiId 30 ~~~i I i = 3 ~-~ C'vt~~ ~ ':C, ~r FILED-OFFICE." ,, Li i ( AIjG, 15 FH I r Joanne Harrison Clough, Esquire Attorney ID No.: 36461 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Plaintiff CHRISTIAN R. QUIGLEY, JR., Plaintiff V. LORRI A. LIVENGOOD, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-3546 CIVIL ACTION -LAW IN CUSTODY PETITION TO MODIFY CUSTODY AND NOW, this day of 2011, comes Petitioner, Christian R. Quigley Jr., by and through his attorney, Joanne Harrison Clough, Esquire, and respectfully files this Petition to Modify Custody and, in support thereof, avers as follows: 1. Plaintiff Christian r. Quigley, Jr. is an adult individual currently residing at 1204 Edinburg Circle, New Cumberland, Pa. 17070. He is the natural father of the minor children Kyle Quigley, born December 5, 1994, Kristin Quigley, born October 4, 1996, Josiah Quigley, born July 18, 1999 and Jeremiah Quigley, born March 30, 2011. 2. Defendant Lorri A. Livengood is an adult individual currently residing at 6250 Galleon Drive, Mechanicsburg, PA 17050. She is the natural mother of the minor children. 'na o6 Aowk (2[<Vf _Z278 y po'?' 2 L ?.2YS 3. On June 30, 2009 an Order of Court granting Mother, Lorri Livengood and Father Christian R. Quigley shared legal custody of the minor children and reconfirming primary physical custody of the children with Petitioner Mother. A true and Correct copy of said Order is attached hereto. 4. In July of 2011, Defendant Mother contacted Plaintiff Father to notify him she intends to sell her home and she requested Plaintiff Father to take physical custody of the minor children and that she have partial physical custody for visitation purposes. 5. Defendant Mother also recently had a yard sale and sold most of the furniture in her residence and is selling one of her two cars. 6. Defendant Mother informed Plaintiff Father she is in dire economic circumstances and must sell her house, furniture and car immediately. 7. On or about August 1, 2011 Defendant Mother informed Plaintiff Father that she had vacated her residence and refuses to disclose where she is living with the parties' children and sent a text message to Father saying "We will b w friends from this point on. Need to b out of house to sell it". 8. For the past six plus months the minor child Kyle Quigley has been living in the primary physical custody of Plaintiff Father. 9. Defendant Mother has informed Plaintiff Father that he must take custody of the other the three other minor children, Kristin, Josiah and Jeremiah within the next few weeks because she cannot keep the children due to her economic circumstances. 10. Defendant Lorri Livengood is currently not represented by legal counsel and it is believed she may oppose this request to modify the Custody Order in this matter. WHERFORE, Petitioner Christian R. Quigley Jr. respectfully requests this Court grant his Petition to Modify custody and Modify the Custody Order dated June 30, 2009 granting him primary 2 physical custody of the children and Defendant Lorri Livengood partial physical custody of the minor children for purposes of visitation. Respectfully Submitted, JOA E HARRIS 1LO JOA'NZW RRISON C GH, ESQUIRE Attorney I.D. No.: 66378 3820 Market Street Camp Hill, PA 17011 (717) 763-1383 Attorney for Plaintiff 3 SUNS 92009 3 CHRISTIAN R. QUIGLEY, JR. Plaintiff vs. LORRI A. LIVENGOOD Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2009-3546 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this day of iV 6I A14L 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Lorri A. Livengood, and the Father, Christian R. Quigley, Jr., shall have shared legal custody of Julia Quigley, born April 16, 1992, Kyle Quigley, born December S, 1994, Kristin Quigley, born October 4, 1996, Josiah Quigley, born July 18, 1999, and Jeremiah Quigley, born March 30, 2001. Major decisions concerning the Children including, but not necessarily limited to, their health, welfare, education, religious training and upbringing shall be made jointly by the parties after discussion and consultation with a view toward obtaining and following a harmonious policy in each Child's best interest. Neither party shall impair the other party's rights to shared legal custody of the Children. Neither party shall attempt to alienate the affections of the Children from the other party. Each party shall notify the other of any activity or circumstance concerning the Children that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of 'the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the Child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to either party as a parent as authorized by statute. 2. During any periods when the Mother is unavailable to provide care for the Children due to her military service, the Father shall have primary physical custody of the Children. During periods when the Mother is available to provide care for the Children. the parties shall resume the current schedule under which the Mother has primary custody of the Children and the Father has partial custody as previously arranged between the parties. 3. The non-custodial parent shall be entitled to have liberal reasonable telephone contact with the Children. 4. As soon as possible following the custody conciliation conference. the Mother shall provide to the Father all medical insurance information for the Children as well as the names and telephone numbers of medical, dental and other treatment or care providers for the Children. 5. The par:ies agree that Pennsylvania has jurisdiction over this custody matter. 6. Notlaing in the military Family Care Certification form on which the Mother may list alternative caregivers for the Children, shall affect the Father's custodial rights under this Order. 7. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE C , J. cc: JJ e Harrison Clough, Esquire - Counsel for Father iA. Sparvieri, Esquire - Counsel for Mother I ;E-(.- /Y1a at LCL COf J, to f 3 c?v? CHRISTIAN R. QUIGLEY, JR. Plaintiff vs. LORRI A. LIVENGOOD Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2009-3546 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Julia Quigley April 16, 1992 Mother Kyle Quigley December 5, 1994 Mother Kristin Quigley October 4, 1996 Mother Josiah Quigley July 18, 1999 Mother Jeremiah Quigley March 30, 2001 Mother 2. A custody conciliation conference was held on June 23, 2009, with the following individuals in attendance: the Father, Christian R. Quigley, Jr., with his counsel, Joanne Harrison Clough. Esquire, and the Mother, Lorri A. Livengood, with her counsel, Kelly A. Sparvieri, Esquire. 3. The parties agreed to entry of an Order in the form as attached. oo- 1 Ijr P JJ Date Dawn S. Sunday, Esquire Custody Conciliator FILED-40rriCE OF THE PP'C;,;nr,l0TARY 2009 JON 30 All f If: 3 4 VERIFICATION I, Christian R. Quigley, Jr., hereby verify and state that the facts set forth in the foregoing pleading are true and correct to the best of my information, knowledge and belief I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn verification to authorities. DATE: `T Christian R. Quigley, J CERTIFICATE OF SERVICE I, Connie Lee Limric, secretary to Joanne Harrison Clough, Esquire, do hereby certify that on this date I served a copy of the foregoing document on this same date by United States first class mail to the following individuals set forth below: Lorri Livengood 6250 Galleon Drive Mechanicsburg, PA 17050 Date: Co Li ic, secretAFy to Joanne Harrison Clough, Esquire Attorney ID No. 36461 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Plaintiff Joanne Harrison Clough, Esquire Attorney ID No.: 36461 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Plaintiff CHRISTIAN R. QUIGLEY, JR., Plaintiff V. LORRI A. LIVENGOOD, Defendant W1 JAPE 31 AM11:52 ;E3M EHNSYLD A A CY : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-3546 CIVIL ACTION -LAW IN CUSTODY AFFIDAVIT OF SERVICE I, Joanne Harrison Clough, Esquire, do hereby certify that on this date I served a Notice of Proposed Relocation To Be Completed by Party Intending to Relocate and a Counter-Affidavit Regarding Relocation, on Defendant Lorri M. Livengood and/or through her attorney, Thomas D. Gould by Hand Delivery, at the Custody Conciliation Conference held before Custody Conciliator, Dawn Sunday, on the 25th day of January 2012. By: Joanne Harrison Clough, Es ui e Attorney ID No. 36461 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Christian R. Quigley, Jr. -Z 11 - 1z J CHRISTIAN R. QUIGLEY JR. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2009-3546 CIVIL ACTION LAW LORRI A. LIVENGOOD Defendant IN CUSTODY ORDER OF COURT r AND NOW, this 7 day of 2012, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated September 20, 2011 is vacated and replaced with this Order. 2. The Father, Christian R. Quigley Jr., and the Mother, Lorri A. Livengood, shall have shared legal custody of Kyle Quigley, born December 5, 1994, Kristin Quigley, born October 4, 1996, Josiah Quigley, born July 18, 1999, and Jeremiah Quigley, born March 30, 2001. Major decisions concerning the Children including, but not necessarily limited to, their health, welfare, education, religious training and upbringing shall be made jointly by the parties after discussion and consultation with a view toward obtaining and following a harmonious policy in each Child's best interest. Neither party shall impair the other party's rights to shared legal custody of the Children. Neither party shall attempt to alienate the affections of the Children from the other party. Each party shall notify the other of any activity or circumstance concerning the Children that could reasonably be expected to be of concern,to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the Child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to either party as a parent as authorized by statute. 3. The Father shall have primary physical custody of the Children. 4. The Mother shall have partial physical custody of the Children in accordance with the following schedule: A. Spring Break: In every year, the Mother shall have custody of the Children over their Spring break which shall run from the day before the break begins through the last day of the vacation before school resumes, unless a portion of the Children's excused educational trip vacation is added to this period of custody as provided in this Order. B. Summer School Break: The Mother shall have custody of the Children during the summer school break for up to four weeks each year. The period of custody for the two youngest Children shall end prior to the beginning of football each summer which shall be determined as the date on which the football coach advises that the Children must be in attendance or not be able to play. The Mother shall be entitled to schedule the Children's periods of custody separately over the summer and may have custody of Kristin for up to four weeks without regard for the other Children's football activities. The Mother shall notify the Father at least 30 days in advance of her intention to schedule a period of summer custody under this provision with any or all of the Children. C. Thanksgiving/Christmas: In even numbered years, the Mother shall have custody of the Children for their Thanksgiving school break and the Father shall have custody for the Christmas holiday break. In odd numbered years, the Father shall have custody of the Children for the Thanksgiving break and the Mother shall have custody for the Christmas holiday vacation. The periods of custody under this provision shall run from the day before the first day of the holiday break through the last day before school resumes after the break unless additional excused educational trip days are added to the periods of custody as provided in this Order. D. In addition, the Mother shall be entitled to have custody of the Children whenever she travels to Pennsylvania upon providing at least 14 days advance notice to the Father. The Father shall make the Children available to the Mother while the Mother is in Pennsylvania. However, the Children shall not be removed from school unless otherwise agreed between the parties in advance. 5. The Mother shall be entitled to add to her periods of custody the maximum number of days permitted by the Children's school as excused absences for an educational trip each year. The parent who is making the travel arrangements for the Children for that period of custody shall determine how the days are added based upon the most advantageous flight arrangements. The Children shall not be removed from school except as excused and approved by the school in advance. 6. The parties shall share responsibility for payment of the costs of transportation of the Children for the Mother's periods of custody as follows: A. For the spring break period of custody in 2012, the Father shall be responsible to make round trip flight arrangements for the Children and shall assume responsibility for the total cost. B. In 2012, the Mother shall make the round trip travel arrangements for her period of custody with the Children during the summer school break and shall be responsible to pay the total cost. C. In 2012, the Father shall be responsible to make the round trip travel arrangements for the Mother's period of custody with the Children over the Thanksgiving holiday and shall be responsible to pay the total cost. D. In 2013, the Mother shall be responsible to make the round trip travel arrangements for the period of custody over spring break and shall be responsible for the total cost. E. Thereafter, the parties shall continue alternating responsibility for making the round trip arrangements for the Children's travel for periods of custody and the party making the arrangements shall pay the total costs thereof. F. The Mother may elect to travel to Pennsylvania for a period of custody and if the Father was otherwise responsible for paying the costs of transportation of the Children to the Mother's residence during that same period, the Father shall contribute toward the Mother's travel expenses for that period in the total amount the Father would otherwise have spent on the Children's airline tickets. The Mother shall provide the Father with at least 14 days advance notice of her intent to travel to Pennsylvania for a period of custody and if the Father is responsible to contribute toward the Mother's costs, because he would have otherwise have bought plane tickets for the Children, the Father shall make the payment directly to the Mother within 14 days of the notice the Mother provides. Before purchasing airline tickets for the Children in accordance with this Order, the Father shall contact the Mother to confirm that the Children will be traveling to Florida rather than the Mother traveling to Pennsylvania. The Mother shall advise the Father as to her plan within 24 hours of being contacted by the Father. If the Mother does not respond to the Father's inquiry within 24 hours and there is a resultant increased cost to the Father for the airline tickets due to the Mother's delay, the Mother shall be responsible for the additional costs. 7. When it is the Father's responsibility to purchase roundtrip airline tickets for the Children for the Mother's period of custody, the Father shall schedule the roundtrip flights to originate from an airport of his choice to arrive at West Palm Beach Airport, Fort Lauderdale Airport or Orlando Airport. When the Mother is making arrangements for the roundtrip tickets for the Children for her periods of custody, the Mother shall schedule the roundtrip tickets to originate from Harrisburg, Baltimore- Washington International Airport or Reagan International Airport to arrive at an airport of her choice. 8. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY TH URT, Edward E. Guido J. t? cc: ?Joanne Harrison Clough Esquire - Counsel for Father ? Thomas D. Gould Esquire - Counsel for Mother (O,P t°s M4, i-eey a /i 3/i,;? 1-r 1 Ti LID nr CHRISTIAN R. QUIGLEY JR. Plaintiff vs. LORRI A. LIVENGOOD Defendant Prior Judge: Edward E. Guido CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2009-3546 CIVIL ACTION LAW IN CUSTODY 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kyle Quigley Kristin Quigley Josiah Quigley Jeremiah Quigley December 5, 1994 October 4, 1996 July 18, 1999 March 30, 2001 Father Father Father Father 2. A custody conciliation conference was held on January 12, 2012, with the following individuals in attendance: the Father, Christian Quigley Jr., with his counsel, Joanne Harrison Clough Esquire, and the Mother's counsel, Thomas D. Gould Esquire. The Mother, Lorri A. Livengood, participated in the conference by telephone from Florida where she currently resides. 3. The parties agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator February 16, 2012 Cumberland County Court House Prothonotary's Office 1 Court House Square Carlisle, PA 17013 n : - -n m z 2= r co r- _V Nr -<2> h, M M q l, --i - ? COURT OF COMMON PLEAS, CUMBERLAND CO, PENNYSLVANIA, NO. 2009-3546, CIVIL ACTION LAW CHRISTIAN R QUIGLEY, JR, PLAINTIFF VS LORRI A LIVENGOOD DEFENDANT I, Lord A Livengood, do acknowledge receipt of the proposed plan for relocation of the plaintiff, Christian R. Quigley, Jr. I, do believe that things in this paperwork/court order have been falsified and not completely accurate. I, after much consideration of the proposed actions to relocate the children to Ohio, do not agree to this move. I do not believe it would be in the best interest of the children. My oldest son, Kyle, will be in his senior year and I do not feel that this injunction in relocation will be wise. This child has been under juvenile supervision to see that he is successful in his endeavors to be a mature young man. Uprooting at this time,. I do believe would cause much anger and hostility with this child to resurface and push him into a greater depth of trouble. If he is left behind to finish out his senior year, he then would not be a part of this action being requested and now supervision would change to who??? As far as the job requesting his transfer, his dad and family have been helping while he is out of town. He has a large territory and his company had permitted him to move to PA six years ago. He has been with e 1 ?) --'S this company 25 years; and his job has been performed from Pennsylvania for 18 years. His relocation to Ohio was only for an allotted 7 years which the company gave him permission to move back to Pennsylvania to perform his job duties. Considering he would be moving with his girlfriend, it makes sense to move one child from Ohio to Pennsylvania than to uproot 4 children to Ohio especially after the major shifts already in their lives. What happens if that situation doesn't work out with the girlfriend? Do my children have to move again, and now where? Stability is a key in children's lives. This is a girlfriend, not a wife. Considering the accusations of not helping the father, let's clarify this one. After losing my home (sell/foreclosure), I did not have an option to do anything other than to try to find a new beginning, a place to live and a job. I did what was in the best interest of my children. The hardest thing I ever had to do in my life. I gave them temporally back to their dad that has had a secure job making six figures and a home to live in until I got back on my feet. I do believe the children need counseling and there has been too much tragedy and uprooting all ready to make such another major shift in their lives. I will possibly be open to the relocation after my oldest son graduates from high school. This gives the children time and myself time to reevaluate the circumstances and custody arrangements. I have not been able to afford an attorney, but requested Thomas Gould at the last custody hearing for a one-time event to represent me so I would not lose visitation rights of my children. At this hearing, nothing was mentioned about moving, and arrangements were already made to follow out visitation rights. I'm requesting another hearing on both issues on the relocation if the courts agree to this action. I, Lord A Livengood, do hereby certify that on this date I served a Notice of Refusal of the Proposed Relocation to the defendant Christian R. Quigley, Jr., and/or his attorney, JoAnne Harrison e ae6 Clough, and a copy to the Prothonatary's Office in Carlisle, Pennsylvania, 17013. Date: 451 SW Kabot Avenue, Pt St Lucie, FL 34953 Cc: JoAnne Harrison Clough, Defendant's Counsel, 3820 Market St, Camp Hill, PA, 17011 Christian R Quigley, Jr, 102 Franklin Circle, Mechanicsburg, PA, 17050 Cumberland Co Court House, Prothonotary's Office, 1 Court House Square, Carlisle, PA, 17013 CHRISTIAN R. QUIGLEY, JR., Plaintiff V. LORRI A. LIVENGOOD, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-3546 : CIVIL ACTION -LAW : IN CUSTODY NOTICE OF PROPOSED RELOCATION TO BE COMPLETED BY PARTY INTENDING TO RELOCATE I, Christian R. Ouiglev, Jr., parent of Kyle Quigley, born December 5 1994 Krista Quigley, born October 4, 1996, Josiah Ouigley, born July 14 1999 and Jeremiah Quigley born March 30 I intend to move over Christmas School Break and answer the following questions as follows. What is the address of the intended new residence? 8265 Clear Path Drive, Reynnoldsburg, Ohio 43068. 2. What is the mailing address of the intended new residence? 8265 Clear Path Drive, Reynoldsburg, Ohio 43068. 3. What are the name(s) and age(s) of all individual(s) who will be living at this new residence? Samsute Malimar Ninnie Puri 4. What is the home telephone number of the intended new residence? There is no land line, my cell phone is: (312) 735-4859 5. What is the name of the new school and the new school district? Pickerington Schools Fairfield County, Ohio 6.. What is the date of the proposed relocation? When Court approved or by summer of 2012 7. What are the reasons for the proposed relocation? Employer has repeatedly requested me to relocate to Ohio for emplo n ent because it is in the heart of My business account locations. When I reside in PA I must travel approximately 10 overnights per month to service my sales accounts in Ohio and the Midwest. Since I now have primary physical custody of my four children it is very difficult to meet these travel obligations. If I move back to Ohio with my children most of my travel obligations would be day trips and I would have my girlfriend who could care for the children the few occasions I may have to travel overnisht. 8. How do you propose to change the custody schedule that is currently in effect? Custody Order was modified on September 20, 2011 awarding me primary custody of the children since Mother delivered children to MypriMM custody on August 3, 2011 and moved from Pennsylvania. Mother is believed to be currently residing in Florida. The current Order does not need to be revised except to permit the relocation. Mother can experience periods of partial custody with the children in Ohio and/or the children can travel from Ohio to Florida to visit Mother. Mother shall be required to provide Father with her physical address and the names of all f '. individuals residing with Mother and provide Criminal Record Affidavits of individuals residing with Mother. C CU{V wogt4ty goo iw ?i, dc, jS"o? JZ 9. Is there any other information that is relevant to the„proposed relocation? has indicated she is curren residin in Florida. MG't 1? ? ka '? ?\E-e OW F7 .l fly 1 ??? 10. I have included a counter-affidavit that you can use to object to the proposed relocation. WARNING TO NON-RELOCATING PARTY IF YOU WANT TO OBJECT TO THE PROPOSED RELOCATION, YOU MUST FILE THIS COUNTER-AFFIDAVIT WITH THE PROTHONOTARY'S OFFICE WITHIN THIRY (30) DAYS AFTER RECEIPT OF THIS NOTICE OR YOU WILL BE FORECLOSED FROM OBJECTING TO THE RELOCATION. Date: 1 ?1' 12 Respectfully submitted by, Counsel for Christia? 3820 Market Street Camp Hill, PA 17011 (717)737-5890 Attorney I.D. # 36461 Esquire Quigley, Jr. VERIFICATION I, Christian R Quigley, Jr., hereby verify and state that the facts set forth in the foregoing pleading are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn verification to authorities. DATE-4 /Y` ,r ff .? h 'an u' r. CHRISTIAN R. QUIGLEY, JR. plaintiff v LORRI M. LIVENGOOD IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY, PENNSYLVANIA NO. Docket # 2009-3546 CIVIL ACTION - LAW CUSTODY This proposal of relocation involves the following child/children: Child's Name Age Currently residing at: Kyle Quigley 17 102 Franklin Square Krista Quigley 15 Mechanicsburg, Pa. 17050 Josiah Quigley 12 Jeremiah Quigley 10 I have received a notice of proposed relocation and: 1. I do not object to the relocation and I do not object to the modification of the custody order consistent with the proposal for revised custody schedule as attached to the notice. 2. 1 do not object to the relocation, but I do object to modification of the custody order, and I request that a hearing be scheduled: a. Prior to allowing (name of child/children) to relocate. b. After the child/children relocate. 3. ZI do object to the relocation and I do object to the modification of the custody order, and I further request that a hearing be held on both matters prior to the relocation taking place. I understand that in addition to checking (2) or (3) above, I must also file this notice with the court in writing and serve it on the other party by certified mail, return receipt requested. If I fail to do so within 30 days of my receipt of the proposed relocation notice, I shall be foreclosed from objecting to the relocation. I verify that the statements made in this counter-affidavit 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 (- 221 F-J -- C) 2L??9 (Telephone) :425571 3 CHRISTIAN R. QUIGLEY, JR. Plaintiff vs. LORRI A. LIVENGOOD Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2009-3546 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this A444 day of 2011, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated June 30, 2009 is vacated and replaced with this Order. 2. The Father, Christian R. Quigley Jr., and the Mother, Lorri A. Livengood, shall have shared legal custody of Kyle Quigley, bom December 5, 1994, Kristin Quigley, born October 4, 1996, Josiah Quigley, bom July 18, 1999, and Jeremiah Quigley, born March 30, 2001. Major decisions concerning the Children including, but not necessarily limited to, their health, welfare, education, religious training and upbringing shall be made jointly by the parties after discussion and consultation with a view toward obtaining and following a harmonious policy in each Child's best interest. Neither party shall impair the other party's rights to shared legal custody of the Children. Neither party shall attempt to alienate the affections of the Children from the other party. Each party shall notify the other of any activity or circumstance concerning the Children that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the Child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to either party as a parent as authorized by statute. 3. The Father shall have primary physical of the Children. 4. The Mother shall have partial physical custody of the Children at her residence outside of Pennsylvania if the Children have a school break, or in Pennsylvania if the Mother travels to the local area as arranged in advance by agreement between the parties for which the Father shall not unreasonably withhold his consent. For one period of custody until the Mother obtains a more permanent residence, the Father agrees to contribute to the reasonable travel expenses for the Mother to come to Pennsylvania, with the -specific amounts to be established by agreement in writing in advance. :TIIe Father shall reimburse the Mother for those expenses to_which he agreed within 30 days of receiving a receipt from the Mother reflecting the expense. .. ::; 5. The Father shall regularly communicate with the Mother to share information pertaining to the Children. 6. Within four months of the date of this Order, either party may request the scheduling of an additional custody conciliation conference if necessary to review the arrangements. 7. The parties may modify the provisions of this Order by mutual consent in writing. In the absence of mutual consent in writing, the terms of this Order shall control. I, BY 4THE; Edward E. Guido J. cc: Joanne Harrison Clough Esquire - Counsel for Father Lorri A. Livengood - Mother TRIM COPY FROM RECORD and ft ad of ew cad at owo ft PP16 Hits on I IaQ.?- P Joanne Harrison Clough, Esquire Attorney ID No.: 36461 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Plaintiff CHRISTIAN R. QUIGLEY, JR., Plaintiff V. LORRI A. LIVENGOOD, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-3546 : CIVIL ACTION -LAW : IN CUSTODY AFFIDAVIT OF SERVICE I, Joanne Harrison Clough, Esquire, do hereby certify that on this date I served a Notice of Proposed Relocation To Be Completed by Party Intending to Relocate and a Counter-Affidavit Regarding Relocation, on Defendant Lorri M. Livengood and/or through her attorney, Thomas D. Gould by Hand Delivery, at the Custody Conciliation Conference held before Custody Conciliator, Dawn Sunday, on the 25th day of January 2012. By: Joanne Harrison Clou quire Attorney ID No. 36461 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Christian R. Quigley, Jr. I- 0jQ v ti?'\???o . ? ?ti2,-`?1 ?a??P -Nom i 4v CHRISTIAN R. QUIGLEY, JR. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2009-3546 CIVIL ACTION LAW LORRI A. LIVENGOOD Defendant IN CUSTODY Prior Judge: Edward E. Guido CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kyle Quigley Kristin Quigley Josiah Quigley Jeremiah Quigley December 5, 1994 October 4, 1996 July 18, 1999 March 30, 2001 Father Father Father Father. 2. A custody conciliation conference was held on September 15, 2011, with the following individuals in attendance: the Father, Christian R. Quigley Jr., with his counsel, Joanne Harrison Clough Esquire. The Mother, Lorri A. Livengood, is not represented by counsel in this matter and participated by telephone from her current location in South Carolina. 3. The parties agreed to entry of an Order in the form as attached. !5e,df rrJ-e-A / y ., dO I Date Dawn S. Sunday, Esquire Custody Conciliator Joanne Harrison Clough, Esquire Attorney ID No.: 36461 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Plaintiff CHRISTIAN R. QUIGLEY, JR., Plaintiff V. LORRI A. LIVENGOOD, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-3546 CIVIL ACTION -LAW IN CUSTODY AFFIDAVIT OF SERVICE I, Joanne Harrison Clough, Esquire, do hereby certify that on this date I served a Notice of Proposed Relocation To Be Completed by Party Intending to Relocate and a Counter-Affidavit Regarding Relocation, on Defendant Lorri M. Livengood and/or through her attorney, Thomas D. Gould by Hand Delivery, at the Custody Conciliation Conference held before Custody Conciliator, Dawn Sunday, on the 25 h day of January 2012. e By: Joanne Ha hson Clou quire Attorney ID No. 36461 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Christian R. Quigley, Jr. CHRISTIAN R. QUIGLEY, JR., : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009-3546 LORRI A. LIVENGOOD, : CIVIL ACTION -LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Petition for Modification of Custody and IS, Permission to Relocate and Request for Expedited Fukl Hearing, it is hereby directed that a hearing shall be held on the ) 7 day of , 2012, at 1730 a - M in Courtroom No. , in the Cumberland County Courthouse, located at One Courthouse Square, Carlisle PA 17013. ,DAIS '• .3 , R 9 - AA BY THE COURT, 4 W 2, r ^? S r-r1?;7 ,.J tl r J. DISTRIBUTION Joanne Harrison Clough, Esquire, 3820 Market Street, Camp Hill, PA 17011 ? Lorri A. Livengood, 451 Southwest Kabot Ave, Port St. Lucie, FL 34953 Copp e_5 ?,,ppWg?Tt#?I?OC?°?, f CHRISTIAN R QUIGLEY(" 1 tAINTIF k COMMON PLEAS 2012 h?R 10 CUMaERLaNO COUNT`t V PENNSYJ.Vp o PENNSYLVANIA LORRI A LIVENGOOD, DEFENDANT CUSTODY IN THE COURT OF CUMBERLAND COUNTY, CIVIL ACTION - LAW, IN NO. 209909W,- ORDER OF THE COURTS..... APRIL 5, 2012 Cumberland County Court House Prothonotary's Office 1 Court House Square Carlisle, PA 17013 TO WHOM IT MAY CONCERN: I, LORRI A LIVENGOOD, DEFENDANT, is hereby requesting an extension in this upcoming hearing on April 17th, 2012. 1 have just received the paperwork today concerning the upcoming actions that I highly am not in favor of. In due respect, I am requesting a rescheduling of this hearing for proper preparation. I have just picked up my children from the airport yesterday for my parental visitation. They shall be in my custody until the 12th of April. I am need of some time to consult with an attorney concerning the actions to be able to present my case. I am not sure if I can find an attorney in such short notice. I am also requesting a phone conference. There is no way I can make it to Cumberland County from Florida. I am financially struggling, and if I take off time from my current job, I could be looking for more employment. I need this job because currently it is paying my child support. Considering the children will be in my care, I will not have time to properly prepare for this case that I am so strongly opposing. If I take the time now in the next week for preparation, I would be taking precious time from my children when this time is very important to me. I do believe the timing of this hearing was preplanned by the plaintiff and his attorney to offset me so I have no preparatory time to prepare. I do also believe the allegations stated in this document from the plaintiff's attorney are false. Let it be stated for the record, in early July, at least 30 days prior to him taking the kids into his custody, I had made a phone call to the plaintiff explaining that I am financially spent. My mortgage payment is in the arrears; alimony was to be ending; and I was behind in my bills. I had told the plaintiff that he would have to take the children until I could land back on my feet. My mortgage company was not willing to do any modifications of my loans. I, at the time, did not seem to be eligible for any of the programs to help save home owners from financial hardship. My mortgage company had suggested that I sell my home to save my credit on a short sale. I told the plaintiff, he would have to be taking the children until I could find a steady job and find another place to live ..... I DID NOT ABANDON MY CHILDREN; it was to be a temporary situation until I could find employment and housing once again. I have called many times to Domestic Violence, considering the plaintiff was an abuser in my 20 year relationship, 18 year marriage. I do have on file, calls to MidPenn for attorney help in the past 6-7 years and currently in this hardship, along with the PA Bar Association for help to maintain my parental rights after financial hardship, and the Domestic Violence office. The plaintiff and his attorney moved quickly to take permanent custody away from me, thus continually throwing horrendous allegations about my character around. His attorney contacted me via email without my permission attacking my character. I had then warned her not to contact me again with her opinions and not facts or her judgments against me via email without my permission; or I would contact the Bar Association because I did not believe she was upholding her professional vows. Now, again, I get this document full of lies and her accusations and statements of what she is calling abandonment. This is a strong statement, and I did what was in the best interest of my children. The hardest thing a mother could ever do considering the situation of 20 years of abuse from a man than never quitting his attacks after the divorce. However, he has a job that makes over a six figure income and he had the capability to be able to care for the children until I could find some recovery from the financial hardship I was under. I did find myself in Florida. Considering my job profession, there are many more opportunities to reestablish myself in a larger territory where there was need for what I was trained to do. Housing has also been established. My movement to Cumberland County was directed by the courts after the divorce because the plaintiff's job wanted him to move back to the East Coast. I had requested at the time to move to Florida with my parents so I could have help with the children after divorce, and was then denied. His job wanted him at the time in Pittsburgh. He was planning to move to central PA that is why I was denied Florida. Again, to uproot a senior from High School which has been a stable and solid environment for him for the last seven years after the divorce is a major mistake. Considering my hardships, no counseling from the father on any of these children, would be very disturbing and uprooting in his last year in high school. One child wants to move back with me to Florida. For the record again, let it be stated that I just recently reestablished my parental visitation rights. Upholding the accommodations again is a lie from the plaintiff's attorney. In this past hearing with Dawn Sunday, they forfeited the oldest son even from visitation rights. They didn't even include him in his rights until he graduated from high school under the plaintiff and his attorney's comments. When the children finally get visitation rights again, my oldest son has been on the phone to try to see me. Considering the plaintiffs obligations were to pay on the first terms, he is not included in this visitation. All 3 minors are with me now except this oldest son. If the plaintiff is acting like he is nonexistent in visitation rights, what will he do when he picks up to move to Ohio? Will the plaintiff leave him in PA with his oldest sister than has no residence? Under current custody actions, this will have to be changed again. I begged for mercy with the courts for financial help to find some attorney that would cut me a break for a one time hearing to regain my parental rights. Now it is void, if and when he moves to Ohio. There are designated airports, times, and if any child moves back with me under the direction of the courts, everything changes again. In this case, I am petitioning the court for another review of the visitation rights and custodial agreement. My objection of this proposed move is for the welfare of my children once again especially the two that are in high school; one his senior year. I will be contacting the plaintiffs attorney and the bar association concerning these false allegations and the defamation of my character with one more final warning. I find these comments/judgments harassing and disturbing and false in nature. What seems to be more disturbing to me is their lies and accusations/assumptions that have been told to my children and how this has affected my children and my relationship with them. My concern is the long term damage of these lies and mind games that are being played which involve my 5 children with no counseling or stability of hardships and traumas. This should never happen. I do believe it is stated in court documents no bashing of the other parent. Please contact me about the rescheduling of this hearing via email at mzLivengood@yahoo.com. My phone number is 561-818-0339. My mailing address is 451 SW Kabot Ave, Pt St Lucie, FL 34953. Thank you for your*mediate attention to this matter. RRI A JVVENGOOD, DEFENDANT DATE ?r?P ?? aciZ • I CHRISTIAN R. QUIGLEY, JR., Plaintiff V. LORRI A. LIVENGOOD, Defendant IN THE COURT OF CUMBERLAND COUNTY, COMMON , PENNSYLVANIA NO. 2009-3546 CIVIL ACTION -LAW IN CUSTODY ORDER OF COURT J? AND NOW, upon consideration of the attached Petition for Modification of Custody and permission to Relocate and Request for Expedited Full Hearing, it is hereby directed that a hearing shall 2012, at IF-'30,2 ' in Courtroom No. be held an the ll day of in the Cumberland County Courthouse, located at One Courthouse Square, Carlisle PA 17013. "' cxs - -' ' -:, BY THE COURT, = C_" .Dn '• 3 ??•/? J. DISTRIBUTION: Joanne Harrison Clough, Esquire, 3820 Market Street, Camp Hill, PA 17011 Lorri A. Livengood, 451 Southwest Kabot Ave, Port St. Lucie, FL 34953 TR1,1R COPY.FROM RECORD In Testimony whereof, here unto set my hand and the a" of Mid Coact at Ca 'sle, Pa. This Szq_day of 201 /??pvo&wotary CHRISTIAN R. QUIGLEY, JR., Plaintiff V. LORRI A. LIVENGOOD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009 - 3546 CIVIL ORDER OF COURT AND NOW, this 13TH day of APRIL, 2012, Defendant's request for a continuance of the hearing scheduled for Tuesday, April 17, 2012, is DENIED. We will begin the hearing as scheduled. If a further continuance is needed, we will consider it at that time. Defendant is granted permission to participate by telephone. ? Joanne Harrison Clough, Esquire Lorri A.Livengood 451 Southwest Kabot Ave. Port St. Lucie, Florida 34953 :sld . jy/1 B ourt, W Edward E. Guido, J. e 7 ?, CHRISTIAN R. QUIGLEY, JR.,: Plaintiff V. LORRI A. LIVENGOOD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-3546 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this 17th day of April, 2012, at the request of the Defendant, and with her assurance that she will be able to appear in person and not have to participate by telephone, and with the further assurance that there is a likelihood that she will be able to retain counsel, hearing in this matter is continued to Wednesday, May 30, 2012, at 10:00 a.m. in Courtroom Number 3 of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania, 17013. By the Court, Edward E. Guido, J. Joanne Harrison Clough, Esquire 3820 Market Street Camp Hill, PA 17011 Attorney for Plaintiff Lorri A. Livengood 451 Southwest Kabot Avenue ,C, Port St. Lucie, FL 34953 "n X -rt srs -am Q ?D t ind l?cL !Z'I? -r? T ??1? A N rr} ` r ? CHRISTIAN R. QUIGLEY, JR. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-3546 CIVIL TERM LORRI A. LIVENGOOD, CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this 30th day of May, 2012, after hearing, we find it is in the best interests of the children to allow Father to relocate to Ohio. In all other respects, our Order of February 9, 2012, shall remain in full force and effect. By the Court, Edward E. Guido, J. Joanne Harrison Clough, Esquire 3820 Market Street Camp Hill, PA 17011 ? Lorri A. Livengood ,,cox r_ 5420 North Ocean Drive West Palm Beach, FL 33404 '` d Lorri A. Livengood 451 Southwest Kabot Avenue -=- -` Port St. Lucie, FL 34953 ' s rs F; rs ? ? ri . led