HomeMy WebLinkAbout06-5720JESSICA M. HOWE, IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2006 - CIVIL TERM
JEREMIAH J. LECRONE, SR., CIVIL ACTION-LAW
Defendant IN CUSTODY
ORDER OF COURT
AND NOW this day of , 2006, upon consideration of the
attached Custody Complaint, it is hereby directed that the parties and their respective counsel
appear before , Esquire, the conciliator, at
on , the day of , 2006 at m.,
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. Absent a special request and prior
arrangements with the conciliator, children are discouraged from attending the conciliation
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 at
least 48 hours prior to the scheduled conference.
FOR THE COURT,
BY
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities 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 LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER 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, PA 17013
(717) 249-3166
JESSICA M. HOWE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2006 - 3.20 CIVIL TERM
JEREMIAH J. LECRONE, SR., CIVIL ACTION-LAW
Defendant IN CUSTODY
COMPLAINT FOR CUSTODY
1. Plaintiff is Jessica M. Howe, an adult individual, residing at 135 Tower Circle,
Carlisle, Cumberland County, Pennsylvania, 17013-9627.
2. Defendant is Jeremiah J. Lecrone, Sr., an adult individual, residing with his
sister, Mary Lecrone, at 363 C Street, Carlisle, Cumberland County, Pennsylvania, 17013-
1832.
3. Plaintiff seeks primary custody of the following child:
Name Present Residence Date of Birth
Jeremiah J. Lecrone, Jr. 135 Tower Circle 10/28/2003 - Present
Carlisle, Pennsylvania 17013-9627
The child was born out of wedlock.
The child is presently in the custody of the defendant, who resides at 363 C Street,
Carlisle, Cumberland County, Pennsylvania, 17013-1832.
During the past five years, the child has resided with the following persons and at the
following addresses:
Name Address Date
Jeremiah J. Lecrone, Sr. 363 C Street 9/25/2006 - Present
Carlisle, Pennsylvania 17013-1832
Jessica M. Howe 135 Tower Circle 10/28/2003 - 9/25/2006
Jeremiah J. Lecrone, Sr. Carlisle, Pennsylvania 17013-9627
The mother of the child is Jessica M. Howe, currently residing at 135 Tower Circle,
Carlisle, Cumberland County, Pennsylvania, 17013-9627.
She is not married.
The father of the child is Jeremiah J. Lecrone, Sr., currently residing at 363 C Street,
Carlisle, Cumberland County, Pennsylvania, 17013-1832.
He is not married.
4. The relationship of the plaintiff to the child is that of natural mother.
The plaintiff currently resides with the following persons:
Name Relationship
None.
5. The relationship of defendant to the child is that of natural father.
The defendant currently resides with the following persons:
Name Relationship
Marv Lecrone Sister
Sarah Lecrone Niece
Sereena Lecrone Niece
Zebadiah Freeman Nephew
Jeremiah J. Lecrone, Jr. Son
6. 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.
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. Each parent whose parental rights to the child have not been terminated and the
person who has physical custody of the child has been named as parties to this action. All
other persons, named below, who are known to have or claim a right to custody or visitation of
the child will be given notice of the pendency of this action and the right to intervene.
NAME ADDRESS BASIS OF CLAIM
None.
WHEREFORE, Plaintiff requests your Honorable Court to grant her primary legal and
primary physical custody of the child.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
Michael A. Scherer, Esquire
I.D. 61974
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
Attorney for Plaintiff
mas\Domestick owelcustody.comp
JESSICA M. HOWE,
Plaintiff
V.
JEREMIAH J. LECRONE, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006 -
CIVIL TERM
CIVIL ACTION-LAW
IN CUSTODY
VERIFICATION
The statements in the foregoing Complaint For Custody are based upon information
which has been assembled by my attorney in this litigation. The language of the statements is
not my own. I have read the statements; and to the extent that they are based upon
information which I have given to my counsel, they are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsifications to authorities.
DATE: `P,IrIY,r Z? . , 2006
- r Jessica M. Howe
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JESSICA M. HOWE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2006 - 52-20 CIVIL TERM
JEREMIAH J. LECRONE, SR., CIVIL ACTION-LAW
Defendant IN CUSTODY
PETITION FOR EMERGENCY RELIEF
PURSUANT TO PA.R.C.P. 1915.13
AND NOW, comes Jessica M. Howe, by and through her attorney, Michael A. Scherer,
Esquire, of O'Brien, Baric & Scherer, and respectfully represents as follows:
1. Plaintiff is Jessica M. Howe (hereinafter referred to as "Mother"), an adult
individual residing at 135 Tower Circle, Carlisle, Cumberland County, Pennsylvania, 17013-
9627.
2. Defendant is Jeremiah J. Lecrone, Sr. (hereinafter referred to as "Father"), an
adult individual who left the marital residence without notice and who is residing with his sister,
Mary Lecrone, at 363 C Street, Carlisle, Cumberland County, Pennsylvania, 17013-1832.
3. The parties are the natural parents of Jeremiah J. Lecrone, Jr. (hereinafter
referred to as "Child"), born October 28, 2003.
4. Mother is employed as a receptionist/billing clerk at Carlisle Neurocare, a group
of physicians specializing in neurology.
5. Father does not work at this time. His last job was in July, 2006 and he has a
sporadic work history.
6. There are no prior custody Orders in this case.
7. Simultaneous to the filing of this Emergency Petition, Mother has filed a
Complaint for Custody and is awaiting the scheduling of a custody conciliation.
8. On or about Monday, September 25, 2006, Father removed Child from the
residence that the parties had shared since Child's birth without an agreement to do so and
without Mother's consent.
9. Since the parties' separation, Mother has had not had any contact with Child or
Father.
10. Prior to September 25, 2006, Child had been enrolled at the Carlisle Early
Education Center for daycare. Child has not been attending the Carlisle Early Education
Center since September 25, 2006.
11. Prior to September 25, 2006, Mother had been the primary caretaker of Child
and had been actively involved in Child's life.
WHEREFORE, Mother respectfully requests this Honorable Court award her some
periods of physical custody of Child pending the custody conciliation.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
Michae A. Scherer, Esquire
I.D. # 61974
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
Attomey for Plaintiff
maslDomestic%Howe%emergencyrelief.pet
JESSICA M. HOWE,
Plaintiff
V.
JEREMIAH J. LECRONE, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006 -
CIVIL TERM
CIVIL ACTION-LAW
IN CUSTODY
VERIFICATION
I verify that the statements made in the foregoing Petition For Emergency Relief
pursuant to Pa.R.C.P. 1915.14 are true and correct. I understand that false statements herein
are made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsification to
authorities.
Date: , 2006
J sica M. Howe
LJ
OCT 0 3 200
JESSICA M. HOWE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. ; NO. 2006 - CIVIL TERM
JEREMIAH J. LECRONE, SR., CIVIL ACTION-LAW
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this day of d "M ? , 2006, upon consideration of
the within Petition For Emergency Relief Pursuant To Pa.R.C.P. 1915.13, a hearing is set in
this matter for e4ocy the geday of 2006 at
dQ Ot.m. in Courtroom No. 4 of the Cumberland County Courthouse, Carlisle,
Pennsylvania.
BY THE COURT,
,v. chael A. Scherer, Esquire
O'Brien, Baric & Scherer
19 West South Street
Carlisle, Pennsylvania 17013
eremiah J. Lecrone, Sr.
c/o Mary Lecrone
363 C Street
Carlisle, Pennsylvania 17013-1832
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JESSICA M. HOWE IN THE COURT OF COMMON PLEAS OF
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
V. 06-5720 CIVIL ACTION LAW
JEREMIAH J. LECRONE, SR.
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Thursday, October 05, 2006 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, October 19, 2006 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
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 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, Esg.
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
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JEREMIAH J. LECRONE, SR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v CIVI - LAW
JESSICA J. HOWE, NO.06-5740
Defendant ` IN CUSTODY
JEREMIAH J. LECRONE, SR, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v CIVIL ACTION - LAW
JESSICA J. HOWE, NO. 06-5720
Defendant IN CUSTODY
COURT ORDER
AND NOW, this 31 `' day of October, 2006, upon consideration of the attached
Custody Conciliation report, it is ordered that the following Temporary Custody Order is
entered:
1. The father, Jeremiah J. Lecrone, Sr., and the mother, Jessica J. Howe, shall
enjoy shared legal and shared physical custody of Jeremiah J. Lecrone, Jr., born
October 28, 2003.
2. Physical custody shall be handled with the parties sharing custody on a 50150
basis on week on/week off schedule. Exchange of custody shall be on Friday
evening at 5:00 p.m. unless agreed otherwise between the parties.
3. The parties may modify this schedule as they agree. Absent an agreement, the
schedule set forth above shall control.
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4. The parties shall meet again with the Custody Conciliator for a Conference on
Wednesday, November 15, 2006 at 8:30 a.m.
cc: Marcus A. McKnight, III, Esquire
Michael A. Scherer, Esquire
BY THE COURT,
Jas
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JEREMIAH J. LECRONE, SR.,
Plaintiff
v
JESSICA J. HOWE,
Defendant
JEREMIAH J. LECRONE, SR.,
Plaintiff
v
JESSICA J. HOWE,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 06-5740
IN CUSTODY
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 06-5720
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 Conciliator conducted a telephone conference call with legal counsel for the
parties and, based upon that discussion, recommends an Order in the form as
attached.
/0-a
DATE
HuKert X. Gil y, Esquire
Custody Co diator
r .
JESSICA M. HOWE
Plaintiff
v
JEREMIAH J. LECRONE, SR.,
Defendant
NOV 2 U 2006 AA
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-5720 IVIL ACTION - LAW
IN CUSTODY
-------------------------------------------------------------------------------------------------------------------------
JEREMIAH J. LECRONE, SR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v NO. 2006-5740 CIVIL ACTION - LAW
JESSICA J. HOWE, IN CUSTODY
Defendant
COURT ORDER
AND NOW, this 2- 2'j day of November, 2006, upon consideration of the attached
Custody Conciliation Report, it is ordered and directed that this Court's prior Order of
October 31, 2006 shall remain in place subject to the following modifications:
1. The Mother, Jessica M. Howe, shall enjoy custody with the minor child on
Thanksgiving for 2006 consistent with the alternating week schedule.
2. For the Christmas holiday, the parties shall communicate with each other in an
effort to work out an agreement with respect to a Christmas eve and Christmas
day schedule. If the parties are unable to work out an agreement on such a
schedule, the Christmas holiday shall be handled with a division of two different
periods of time: the first period shall be Christmas eve at noon until Christmas
day at noon, and the second period shall be Christmas day at nopn Otil December
26th at noon. Both segments shall be alternated with Father hiving tW first
segment in 2006 with the parties alternating thereafter. - .,
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3. The parties shall advise their attorneys which respect to the status of the case and
the attorneys shall conduct a telephone conference with the Conciliator on
Thursday, January 11, 2007 at 8:00 a.m.
4. In the event either parent is not able to care for the child for a period of three
hours or more because of work or other commitments, the custodial parent must
contact the non-custodial parent and give that parent the opportunity to provide
day care if he or she is available.
5. Both parties shall keep the other parent advised with respect to their living
situation, address, phone number and other appropriate contact information.
6. The parties shall use Carlisle Early Education Center for providing day care, and
the Carlisle Early Education Center is authorized to share all information with
both parents in light of the fact that this is a shared physical and shared legal
custody situation.
BY THE COURT,
Kevin . Hess, Judge
Cc: 'I' ael A. Scherer, Esquire
arcus A. McKnight, III, Esquire
4
i.
JESSICA M. HOWE
Plaintiff
v
JEREMIAH J. LECRONE, SR.,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-5720 CIVIL ACTION - LAW
IN CUSTODY
-------------------------------------------------------------------------------------------------------------------------
JEREMIAH J. LECRONE, SR., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v NO. 2006-5740 CIVIL ACTION - LAW
JESSICA J. HOWE, IN CUSTODY
Defendant .
Prior Judge: The Honorable Kevin A. Hess
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 of this litigation is
as follows:
Jeremiah J. Lecrone, Jr., born October 28, 2003
2. A Conciliation Conference was held on November 15, 2006 with the following
individuals in attendance:
The Mother, Jessica M. Howe, with her counsel, Michael A. Scherer, Esquire
The Father, Jeremiah J. Lecrone, Sr., with his counsel, Marcus A. McKnight, III,
Esquire
3. The parties agreed to the entry of an Order in the form as attached.
Date: November 2006
ert X. . roy, Esquire
Custody onciliator
JAN 1 2 2D01 ANY
JESSICA M. HOWE : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v NO. 2006-5720 CIVIL ACTION - LAW
JEREMIAH J. LECRONE, SR., IN CUSTODY
Defendant
JEREMIAH J. LECRONE, SR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v NO. 2006-5740 CIVIL ACTION - LAW
JESSICA J. HOWE, IN CUSTODY
Defendant
ORDER
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AND NOW, this ? ( day of January, 2007, after conducting a telephone
conference with the attorneys for the parties and being advised that the Conciliator does
not need to take any further action, the Conciliator relinquishes jurisdiction.
i
ubert X. Gilroy, Esquire
Custody Conciliator
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JESSICA M. HOWE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2006 - 5720 CIVIL TERM
JEREMIAH J. LECRONE, SR., CIVIL ACTION-LAW
Defendant IN CUSTODY
- ----------------- - ---------------- - ---------- - ------------- - ---------------------------------------
JEREMIAH J. LECRONE, SR.,
Plaintiff
V.
JESSICA M. HOWE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006 - 5740 CIVIL TERM
CIVIL ACTION-LAW
IN CUSTODY
JESSICA M. HOWE'S ANSWER TO
PETITION TO MODIFY CUSTODY
AND NOW, comes Jessica M. Howe (hereinafter "mother"), by and through her
attorney, Michael A. Scherer, Esquire, and respectfully answers Jeremiah J. LeCrone's
(hereinafter "father") Petition as follows:
1. - 5. Admitted.
6. Denied. Jessica M. Howe desires to have primary physical custody of the
child so that the child attends school in the Carlisle School District, for the following
reasons:
a. Aside from a short stay with a friend after the parties' separated,
mother has continued to reside in the home where the parties raised the child.
b. Father has had several different residences since separation and
his residence in Perry County may not be permanent.
C. Father has no known job nor visible means to support the child.
d. The child's personal contacts and activities, such as daycare,
"Head Start" his physicians, dentist and other professionals are all from Carlisle and the
child has no known contacts with Perry County.
WHEREFORE, mother respectfully requests that the Court enter and Order for
shared legal custody, primary physical custody with mother and shared custody during
the summer months.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
Mic ae A. Scherer, Esquire
I.D. # 61974
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
Attorney for Plaintiff
mas.dir/domestic/howe/modifycustodypetition.ans
VERIFICATION
I verify that the statements made in the foregoing Jessica M. Howe's Answer To
Petition To Modify Custody are true and correct. I understand that false statements
herein are made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unsworn
falsification to authorities.
3
Date: 0
Jessica M. Howe
CERTIFICATE OF SERVICE
I hereby certify that on March g+ , 2009, I, Jennifer S. Lindsay, secretary at
O'Brien, Baric & Scherer, did serve a copy of Jessica M. Howe's Answer To Petition To
Modify Custody, by first class U.S. mail, postage prepaid, to the party listed below, as
follows:
Marcus A. McKnight, III, Esquire
Irwin & McKnight
60 West Pomfret Street
Carlisle, Pennsylvania 17013
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