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Home My WebLink About05-3303 JULIE E. LECHNER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW cYf- 3303 CIVIL TERM KEVIN R. LECHNER, Defendant IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, Julie E. Lechner, Jr., by her attorneys, Irwin & McKnight, and presents the following Complaint for Custody. 1. The Plaintiff, Julie E. Lechner, is an adult individual with an address of 251 Wagner Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant, Kevin R. Lechner, is an adult individual with an address of 29 Army Heritage Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are the natural parents of three (3) children, namely, Andrew K. Lechner, born December 30, 1994; Adam D. Lechner, born October 24, 1996; and Megan D. Lechner, born February 5, 2002. 4. The Plaintiff desires that the parties have shared legal custody of said minor children. 5. The Plaintiff desires primary physical custody of the minor children, Andrew K. Lechner, Adam D. Lechner, and Megan D. Lechner, with periods of temporary physical custody to Defendant as the parties can agree, 6, The best interests and permanent welfare of the minor children requires that the Court grant the Plaintiff s request as set forth above. WHEREFORE, the Plaintiff, Julie E. Lechner, respectfully requests that she be awarded primary physical custody and shared legal custody of Andrew K. Lechner, Adam D. Lechner, and Megan D. Lechner, as provided herein, with periods of temporary physical custody to Defendant as provided herein. Respectfully submitted, By: Date: June 24, 2005 JULIE E. LECHNER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, 05-3303 CIVIL ACTION LA W KEVIN R. LECHNER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, June 30, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hnbert X. Gilroy, Esq. at 4th Floor, Cumberland County Courthonse, Carlisle on Friday, July 22, 2005 , the conciliator, at 8:30 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. 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 pennanent order. The court herehy 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: Isl Hubert X Gilrov. Bsq. Custody Conciliator ~rf1 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 (717) 249-3166 . ~ ~';I- -w. ~ ~ P.$-L :-#fpt ~ ~14 ~5'L ~i714 $p ~ 1'9'~ l/r.61'P{l .w-.9c.. VINVA1ASNN3d AlNnrJ'"\ nl< ~ '""\1 ,.:;~ ... ",,' ,A -}""Aln" '. ".<.","jy'f V I Z :8 IoId S- lor sooz Ai:N10NOHlOCld 3H1 :10 3Q1:l:KKl318 - VERIFICATION The foregoing Complaint for Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief, I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities, /7 '/1<" 1./" (,,/ ' '. a.Ca.,) C r/\C(!i4'JU J IE E. LECHNER Date: June 24, 2005 ~ ~ ~ ~ -... - -, ~ "d ~ '--'\ ~~ -.J ~~ 0 ~~ ..c::.. r.l !; ~ :3- -,-.. c8 ", iE; CJ' c__ S:~ o -" ..... :I: ""l'1 rllr-'= -'~-l;n ~_i_ll:} ;,,'.;(!:; (~?~ (jfTl " .j ~}j -< 1'.' co "'TJ -.;.- r:-? (,;"l ,;[.-- 'V JULIE E. LECHNER Plaintiff RECEIVED AUG 22 Z005 yf' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW KEVIN R. LECHNER Defendant NO. 05-3303 IN CUSTODY COURT ORDER AND NOW, this ,7,.1 day of August, 2005, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. The mother, Julie E. Lechner, and the father, Kevin R. Lechner, shall enjoy shared legal custody of Andrew K. Lechner, born December 30,1994, Adam D. Lechner, born October 24, 1996, and Megan D. Lechner born Febrnary 5, 2002. 2. The mother shall enjoy primarily physical custody of th4l minor children. 3. The father shall enjoy periods of temporary physical custody with the minor children as follows: A. Alternating weekends from Friday after father gets off until Sunday evening at 7:00 pm. B. On two evening a week which shall be Tuesday and Thursday. During the school year, the time frame shall be from 5:30 to 8:30 pm. During the summer months the time frame shall be from 5:30 until 9:30 pm. C. At such other time as agreed upon by the parties. 4. During the summer months, both parties shall have at Ileast two weeks of vacation time with the minor children which shall be non consecutive. "- Cr:: "" h-, W".:: Q[o=<; l:f,~;:r: 0'"" 1 <,) Qn" !:::JC5~ iJ::j5 ~ _7 "'- cS: tr.> N (.!> ;:::, """ <.r.> ~ g::; Ii) - .,,:: --.:) o 5. Father shall always have custody of the minor children on Fathers Day and mother shall always have custody of the minor children on Mothers Day. This provision shall supercede any other provision or this Order. 6. The parties shall alternate or share major holidays as agreed between the parties. 7. There shall be a right of fIrSt refusal with respect to time with the minor children to cover situations where either parent is unavailable to take care of the children during their times of custody for a period of two hours or more. Under those circumstances, the custodial parent must notify the non-custodial parent and give them the fIrSt option of taking care of the minor children. 8. In the event either party becomes dissatisfied with this Order and desires to modify the Order and is uuable to reach agreement with the other parent, that party may petition the Court to have the case again scheduled with the Custody Conciliator for a conference. Additionally, in the event the parties are unable to work out details relative to minor issues such has holiday schedules, etc, legal counsel for the parties may contact the Conciliator directly to schedule another conciliation conference which may be by a telephone conference between the attorneys and the condliator. 9. The children are currently in counseling to address a variety of issues relating to the parties separation. In the event the counselor desires father to become involved in that counseling, father will cooperate and facilitate aU counseling sessions as necessary. BY THE COURT, Cc: a1lomas M. Clark, Esquire ~cus A, McKnight, E;s uire ~ . JULIE E. LECHNER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW KEVIN R. LECHNER Defendant NO. 05-3303 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custady Call1ciliatar submits the fallawing repart: 1. The pertinent infannatian pertaining to. the child/children who. are the subject af this litigatian is as fallaws: Andrew K. Lechner, barn December 30, 1994 Adam D. Lechner, barn Octaber 24, 1996 Megan D. Lechner, barn February 5,2002 2. A Canciliatian Canference was held an August 10, 2005, with the fallawing individuals in attendance: The mather, Julie E. Lechner, with her caunsel, Marcus McKnight, Esquire, and the father, Kevin R. Lechner, with his caunsel, Thamas M.. Clark, Esquire. 3. Based upan the recammendatian af the Canciliatar, th'1 parties are willing to. agree to. a temparary Order in the farm as attached. ~w oS-- DATE Hubert X. Gilray, ~squire Custady Cancili or