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Home My WebLink About06-2056 MICHELLE LUCAS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW . . DANIEL LUCAS, Defendant : NO. 06 . : IN CUSTODY CIVIL TERM COMPLAINT FOR CUSTODY NOW comes the plaintiff, Michelle Lucas, by her attorney, Mark F. Bayley, Esquire, and presents the following complaint for custody, representing as follows: 1. The plaintiff is Michelle Lucas, an adult individual residing at 44 Limekiln Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is Daniel Lucas, an adult individual whose address is 1611 Market Street, Camp Hill, Cumberland County, Pennsylvania 17011, 3. The parties are the parents of one minor child, Morgan Lucas (born September 21, 1995, age 10 years). 4. The child resided with both parties from the time of her birth through the parties' separation date of March 24, 2006. 5, Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth, other than the existing Order filed to this term and number. 1- 6. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child, 7. Plaintiff believes and therefore avers that the best interests and permanent welfare of the child require that plaintiff have primary physical custody and that defendant have specified periods of partial physical custody and visitation at times agreed upon or deemed appropriate by the Court with the child. WHEREFORE, plaintiff respectfully requests that the court enter an order providing for the legal and physical custody of the child as aforesaid. D.led, ~ ~io/c(o ~ IRWIN & BAYLEY 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court 10 No. 87663 Attorney for Plaintiff , I VERIFICATION I do hereby verify that the facts set forth in this petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. April { ,2006 ~\clJL JLc-~ MICHELLE LUCAS F t-. ~'.~ 1...0 .. I: c__ 0..J . " "'- !;,~I ('# f=:: ;_:~~ ;'" , c-'--..~ r\ roF~ o~tcJ c: ~ -- pii: ~-Ji \ - .--C -c5 ';d ~ u <.:t- ~ ~~,) , '.Y ~. : ",' . ' :- - I~:! .' ,/'..'. -.- . (., ,iLl , PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV ANIA MICHELLE LUCAS v, 06-2056 CIVIL ACTION LA W DANIEL LUCAS DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, April 18,2006 , upon consideration of the attached Complaint, it is herehy directed that parties and their respeetive counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at .. ,4th Floor, Cumberl~nd<::o.~~!y_Cour!l1.ouse, '<=~r1i'-"'- on.____ 'l'l1.u~s<l.~Y,_l\1~y~:;,~Q()~_ at 9:30 AM for a Pre-Hearing Custody Conference, At such conferencc, an effort will be made to resolvc the issues in dispute; or if this cannot be accomplished, to dellne and narrow the issues to be heard by the court, and to enter into a temporary order. All children age Ilve or older may also be prcsent at the conference, 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 Gilrov. 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 information about accessible facilities and reasonable accommodations available to disabled individuals having business be!lJre the COllli, please contact our omce, All arrangements must be made at least 72 hours prior to any hearing or business bellJre 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 Bed!llrd Street Carlisle, Pennsylvania J 7013 Telephone (7 J 7) 249.3166 ,~ ~}J'7i'~. -# -w7" ~ ~7,7 ;n-I47'w f?p Z', t?{J'?'~? ?~~ ~9']l.1'7 :z /fJ"mi'/ ~ -I?{-? ':' C 111 :~\ ,;:: ;' i .:;t?- ;Jr-~-Il }V - (.?C'-;.;. ~VO{""/7 _"'1l.. , ~ "--6 ~ RECEiVED JUN 282008 q MICHELLE LUCAS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 06.2056 CIVIL ACTION - LAW DANIEL LUCAS, Defendant IN CUSTODY AND NOW, this COURT ORDER ~ a'f day of 2006, upon consideration of the attached Custody Conciliation Repo , it is ordered and directed as follows: 1. The Mother, Michelle Lucas, and the Father, Daniel Lucas, shall enjoy shared legal custody of Morgan Lucas, born September 21, 1995. 2. The Mother shall enjoy primary physical custody of the minor child. 3. The Father shall enjoy periods of temporary physical custody ofthe minor child as follows: A. On alternating weekends from Friday until Sunday, pursuant to a schedule for pick up and delivery as agreed upon by the parties. B. At such other times as agreed. 4. Holidays shall be shared between the parties pursuant to a schedule as agreed. 5. During the summer months, the parties shall alternate physical custody on a week- onlweek-off basis. The exchange of custody shall take place on Friday evening at 5:00. Each week during the summer, the non-custodial parent shall have the opportunity to have temporary custody of the minor child on Wednesday evening or on another evening agreed upon by the parties pursuant to a schedule agreed upon by the parties. 6. In the event either party is dissatisfied with this Order, that party may initiate another custody conciliation conference by having their attorney contact the Conciliator directly for scheduling of a conference. Judge Cc: Debra R. Mehaffie, Esquire \ I 7 Mark F. Bayley, Esquire,... IJ~ :;JO-d.!> ~-( e;5 nul W J1-(> ~ . Y) I :2 lid ~1/\1 1 :",,-- ,.\;(tJ 6";) ut.:", l..."P-7 c. J ,j II JJU,,,, _,-:~:d :3Hl jO ," (]jl!:1 . MICHELLE LUCAS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 06-2056 CIVIL ACTION - LAW DANIEL LUCAS, Defendant IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF 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 ofthis litigation is as follows: Morgan Lucas, born September 21, 1995 2. A Conciliation Conference was held on June 22, 2006 with the following individuals in attendance: The Mother, Michelle Lucas, with her counsel Mark F. Bayley, Esquire The Father, Daniel Lucas, with his counsel Debra R. Mehaffie, Esquire 3. The parties agreed to the entry of an Order in the form as attached. Date: June ;) { , 2006