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Home My WebLink About05-2707 'i" Shaun K. Lyter, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05- ;J 101 CIVIL TERM v. Kathy Lynn Lyter, Defendant : CIVIL ACTION - CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Shaun K. Lyter, an adult individual whose residence is at 264 Chicken Hollow Road, Newport, Perry County, Pennsylvania. 2. Defendant is Kathy Lynn Lyter, an adult individual whose residence is at 51 Ashford Drive, Enola, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of his child, Katlyn Sue Lyter, born September 18, 1999, currently residing at 51 Ashford Drive, Enola, Cumberland County, Pennsylvania 17025. 4. The child is presently in the custody of Defendant. 5. Since the child's birth, the child has resided at the following addresses: Name Address Dates Kathy Lynn Lyter 51 Ashford Drive April, 04 to current Enola, PA Kathy Lynn Lyter 483 Myers Street West Fairview, PA 00 - April, 04 6. The relationship of the Plaintiff to the children is that of natural father. 7. The relationship of the Defendant to the children is that of natural mother. 8. The Plaintiff has not participated as a party or in any other capacity, in other litigation concerning the custody of the child in this or any other Court. 9. Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. 10. The Plaintiff as been paying child support pursuant to Cumberland County Order docketed at 00836S2001, PACSES, Case Number 001103905. 11. The best interest and permanent welfare of the child will be served by granting the relief requested because the Plaintiff and the child have developed a bond and the mother has not only been uncooperative with the development of that bond but has improperly restricted the custody/visitation between parent and child to supervised settings. 12. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. No other persons are known to have or claim to have any right to custody or visitation of the child other than the parties to this action. WHEREFORE, Plaintiff requests your Honorable Court grant the Plaintiff request for shared legal custody and liberal and partial physical custody/visitation of the child. Respectfully Submitted TURO LAW OFFICES Iii $~:3 ~s Date / Il VERIFICATION I verify that the statements made in the foregoing Custody Complaint are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. f;/;J3)or;- Date /J f~=;a ~~----- ShaurlK. Lyt/// L___--> CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Complaint in Custody upon Shaun K. Lyter, by depositing same in the United States Mail, first class, postage pre-paid on the ~{1J, day of /Yl J1 V ,2005, from Carlisle, Pennsylvania, / addressed as follows: Kathy Lynn Lyter 51 Ashford Drive Enola, Pennsylvania 17025. TURO LAW OFFIC alen R. Waltz, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688; FAX 717.245.2165 ~ '-. \'.- 't:::: ~ <v G> 'j\. ~ ~ :v1 ).,) \.4.. ~ :-;: d ~ ~ ~ ~ 8 ~i? :":1 ;1: .J-.'- SHAUN K. LYTER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 05-2707 CIVIL ACTION LA W KATHY L YNN LYTER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, May 26, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, June 10, 2005 , the conciliator, at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or ifthis cannot be accomplished, to define and narrow the issues to be heard by the court. and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or penn anent order. Tbe court bereby directs tbe parties to furnisb any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to tbe conciliator 48 bours prior to scbeduled bearin2. FOR THE COURT, By: Isl Hubert X. Gilroy, Esq. Custody Conciliator ~r The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For infonnation 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 HA VE 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 (7 I 7) 249-3166 --- ..,f ~# ~...-r ~ JP.(N _# 'Z~ ~ 9::J-Le-9 ~~,~~S()U'> \ (' :Z u.-\ I 7 \ \'1\ cpro J ;" ...' _.J I~ 'i, ,. 'i jl."Il';'" RECEIVED JUl13 2005Y'~ SHAUN K. LYTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAN][) COUNTY, PENNSYL VANIA v No. 05-2707 CIVIL TERM KATHY LYNN LYTER, Defendant IN CUSTODY COURT ORDER AND NOW, this /0(' day of July, 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Shaun K. Lyter, and the Mother, Kathy Lynn Lyter, shall enjoy shared legal custody of Katlyn Sue Lyter, born September 18, 1999. 2. The Mother shall enjoy primary physical custody of the minor child. 3. The Father shall enjoy periods of partial temporary custody of the minor child as follows: A. On alternating weekends commencing the weekend of July 8. For the first three weekends, Father shall enjoy one overnight on alternating weekends with the overnight to be arranged between the parties. Assuming everything goes well, this schedule shall expand to two overnights on alternating weekends from Friday evening at approximately 5:00 until Sunday evening until approximately 6:00. The parties may modify these time schedules as they agrel~. . V':i\'(i\l\~;i<,.1 r~jd ) 11\'(l.....;"- '''T' I' I . :"..,'~.~t:l"""- \..L,.(I), iT, ' - ,;' .-, ,\~: 1J I 0 :01 ~,IV +,1 inJ' SOOl A. >~',,,(,,.i"'c'l("'.'r' :JH1' ~O w 'I.....VI -A), t _ \..JL~) -l .:J 3~)I:J:lO'-G=n!~ 'Or 4. Assuming the schedule outlined above goes well, it is anticipated that a more permanent Order will be entered addressing holidays and vacation issues. The parties can work those out themselves and enter into an Agreement prepared by their attorneys or, in the alternative, the attorneys for the parties may contact the Custody Conciliator directly for a telephone conference after which the Conciliator can recommend a modified Order to the Court. BY THE COURT: I Cc: Galen R. Waltz, Esquire Elizabeth B. Stone, Esquire ~ ,~ 7 -N -0<: (~ SHAUN K. LYTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v No. 05-2707 CIVIL TERM KATHY LYNN LYTER, Defendant IN CUSTODY CONCILIATION CONSULTATION SUMMARY REPORT IN ACCORDANCE ~TH THE CUMBERLAND COUNTY CITIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Condliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Katlyn Sue Lyter, born September 18, 1999 2. A Conciliation Conference was held on June 30, 2005, with the following individuals in attendance: The Father, Shaun K. Lyter, with his attorney, Galen R. Waltz, Esquire, and the Mother, Kathy Lynn Lyter, with her attorney, Elizabeth B. Stone, Esquire 3. The parties agreed to the entry of an Order as attached. I-{~- or Date w?L Hubert X. roy, Esquire Custody onciliator SHAUN KARL LYTER IN THE COURT OF COMMON PLEAS OFc PLAINTIFF CUMBERLAND COUNTY, PENNSYLVA4=- ='M C ^ r... ?? ? n as rf., ` 2005-2707 CIVIL ACTION LAW ?> L - < C.) ? ?}W KATHY LYNN LYTER IN CUSTODY _ .. " DEFENDANT ORDER OF COURT AND NOW, Tuesday, July 03, 2012 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, July 20, 2012 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, Esq. _ 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 infonnation 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 ? A;4)&n'1 L'or. :5&-r"' c es 1-Y7'er ?- X. 07 4, .ProY/ 6,s9 - /JVI44 a? TA ??z 4 SHAUN KARL LYTER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVAI v 2005-2707 CIVIL ACTION -LAW KATHY LYNN LYTER, Defendant IN CUSTODY PRIOR JUDGE: Kevin A. Hess COURT ORDER AND NOW, this 6 , day of August, 2012, upon consideration of the attached Conciliation Report, it is ordered and directed that this Court's prior Order of July 14, 2005, is and replaced with the following Order: 1. The father, Shaun Karl Lyter, and the mother, Kathy Sue Lyter, shall enjoy shared custody of Katlyn Sue Lyter, born September 18, 1999. 2. The mother shall enjoy primary physical custody of minor child. 3. The father shall enjoy periods of partial physical custody of the minor child as follows: A. On alternating Sundays from noon until 6:00 p.m. unless the parties agn other times. The parties shall share transportation with an exchange of cus taking place at the Dollar Store along Route 11115. The parties shall al each other at least fifteen minutes time in case the parties are late, an( parties are directed to communicate with each other with respect to transportation issues. to the B. The father shall also enjoy reasonable telephone contact with the minor c C. This is a TEMPORARY Order. The Conciliator shall conduct Conciliation Conference via telephone with counsel for the parties on October 5, 2012, at 8:00 a.m. At that time and assuming things are prof well with the father visiting his child, it is anticipated that father's pe partial physical custody will be expanded No party shall be permitted to relocate the residence of the child where said relocation significantly impair the ability to exercise custody unless every individual who has custc rights to the child consents to the proposed relocation or the court approves the prop relocation. Any party proposing to relocate MUST comply with 23 Pa. C.S. § 5337. BY THE COURT, - /I At/r, Kevin A!?Aess, Judge cc: &/Jessica Holst, Esquire Al Elizabeth B. Stone, Esquire &P'te6 ma-led C" I ev N c c? On of r CD F. ? T; i r SHAUN KARL LYTER, Plaintiff v KATHY LYNN LYTER, Defendant PRIOR JUDGE: Kevin A. Hess : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAl 2005-2707 CIVIL ACTION - LAW IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF C PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this liti as follows: Katlyn Sue Lyter, born September 18, 1999. 2. A Conciliation Conference was held on July 31, 2012, with the following indi in attendance: The father, Shaun Karl Lyter, with his counsel, Jessica Holst, Esquire, and the Kathy Lynn Lyter, with her counsel, Elizabeth B. Stone, Esquire. 3. The parties agree to the entry of an Order in the form as attached. Date: August, 2012 Hubert X. G' oy, Esquire Custody C nciliator is r') c') C7 m N