HomeMy WebLinkAbout06-5740JEREMIAH J. LECRONE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
JESSICA J. HOWE, NO. Din 57yG- CIVIL TERM
Defendant IN CUSTODY
COMPLAINT FOR CUSTODY
AND NOW comes the Plaintiff, Jeremiah J. Lecrone, by his attorneys, Irwin &
McKnight, and presents the following Complaint for Custody.
1.
The Plaintiff, Jeremiah J. Lecrone, is an adult individual with an address of P. O., Box 448,
Carlisle, Cumberland County, Pennsylvania 17013.
2.
The Defendant, Jessica M. Howe, is an adult individual with an address of 135 Tower
Circle, Carlisle, Cumberland County, Pennsylvania 17013.
3.
The parties are the natural parents of one (1) child, namely, Jeremiah J. Lecrone, Jr., born
October 28, 2003.
4.
The Plaintiff desires that the parties have shared legal custody of the minor child,
Jeremiah J. Lecrone, Jr.
5.
The Plaintiff desires primary physical custody of the minor child, Jeremiah J. Lecrone, Jr.
with periods of temporary physical custody to Defendant as the parties can agree.
6.
The best interests and permanent welfare of the minor child requires that the Court grant
the Plaintiff's request as set forth above.
WHEREFORE, the Plaintiff, Jeremiah J. Lecrone, respectfully requests that he be
awarded primary physical custody and shared legal custody of Jeremiah J. Lecrone, Jr., as
provided herein, with periods of temporary physical custody to Defendant as provided herein.
Respectfully submitted,
IRWIN & McKNIGHT
By:
U West Pomfret Street
Carlisle, Pennsylvania 1701 3222
Sup
249-2353
rem sort I D. No. 6
Date: September 29, 2006
VERIFICATION
The foregoing document 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.
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MIAH J. LECRONE
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JEREMIAH J. LECRONE, SR. IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
JESSICA J. HOWE
DEFENDANT
06-5740 CIVIL ACTION LAW
IN CUSTODY
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, 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
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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.
BY THE COURT,
cc: Marcus A. McKnight, III, Esquire
Michael A. Scherer, Esquire
rt - 'i c c
'i
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
JEREMIAH J. LECRONE, SR.,
Plaintiff
v
JESSICA J. HOWE,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 06-5720
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.
/a-?? -a
DATE
Hurt X. Gil y, Esquire
Custody Co diator
NOV 2 0 2006
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 =2006-5740 VIL ACTION - LAW
JESSICA J. HOWE, IN CUSTODY
Defendant
COURT ORDER
AND NOW, this 2 7- -4 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 n n t#itil December
C.~J
26`h at noon. Both segments shall be alternated with Father h#ving tyre 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,
?i A/*
Kevin . Hess, Judge
Cc:
ael A. Scherer, Esquire
arcus A. McKnight, III, Esquire
4.- '"5:)
. . ,
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 ] 8 2D07 W
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
ORDER
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.
/4"(,3/
ubert X. Gilroy,,Esquire
Custody Conciliator
1E COPY FROM RECORD
Tesdmm whereof, 4 ? are unto set my f
the seal of said v Ca WI% AL
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JEREMIAH J. LECRONE,
Plaintiff
V.
JESSICA J. HOWE,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2006 - 5740 CIVIL TERM
IN CUSTODY
PETITION FOR MODIFICAITON
OF CUSTODY
AND NOW comes the Plaintiff, Jeremiah J. Lecrone, by his attorneys, Irwin &
McKnight, P.C., and presents the following Petition for Modification of Custody:
1.
The Plaintiff, Jeremiah J. Lecrone, is an adult individual with an address of 3290 Big
Spring Road, Blain, Perry County, Pennsylvania 17006.
2.
The Defendant, Jessica M. Howe, is an adult individual with an address of 135 Tower
Circle, Carlisle, Cumberland County, Pennsylvania 17013.
3.
The parties are the natural parents of one (1) child, namely, Jeremiah J. Lecrone, Jr., born
October 28, 2003.
4.
The parties have shared physical custody of said minor child per Order of Court dated
November 22, 2006, a copy of which is attached hereto and marked as Exhibit "A".
5.
The Plaintiff desires that the parties have shared legal custody of the minor child,
Jeremiah J. Lecrone, Jr.
6.
The Plaintiff desires primary physical custody of the minor child, Jeremiah J. Lecrone, Jr.
during the school year so that he may attend the West Perry School District in September of
2009. During the school year, Defendant will have periods of temporary physical custody as the
parties can agree.
7.
During the summer months, the Defendant will have shared physical custody of said
minor child as the parties currently enjoy.
8.
The best interests and permanent welfare of the minor child requires that the Court grant
the Plaintiff s request as set forth above.
WHEREFORE, the Plaintiff, Jeremiah J. Lecrone, respectfully requests the following:
A. That he be awarded primary physical custody of Jeremiah J. Lecrone, Jr.
during the school year;
B. Shared legal custody of Jeremiah J. Lecrone, Jr.; and
C. Shared physical custody of Jeremiah J. Lecrone, Jr. during the summer months.
Respectfully submitted,
IRWIN & N YKNIGIJT, P.C.
By:
Marcus IA. igh ZII, Esquire
Attorn or Plaintiff
60 )Vest Pomfret Stre
17013-3222
(717) 249-2353
Supreme Court I. D. No. 25476
Date: February 23, 2009
EXHIBIT "A"
NOV 20 2DD8
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
COURT ORDER
f) 1) n8
AND NOW, this 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 noon until December
26th at noon. Both segments shall be alternated with Father having the first
segment in 2006 with the parties alternating thereafter.
.
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,
n
Kevin A. Hess, Judge
Cc: Michael A. Scherer, Esquire
Marcus A. McKnight, III, Esquire
set my hand
,a y .: sle, Pa.
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
VERIFICATION
The foregoing document 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.
REMIAH LECRONE
Date: February 23, 2009
JEREMIAH J. LECRONE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
NO. 2006 - 5740 CIVIL TERM
JESSICA J. HOWE, .
Defendant IN CUSTODY
CERTIFICATE OF SERVICE
I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached Petition was
served upon the following by depositing a true and correct copy of the same in the United States
mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and
addressed as follows:
Michael A. Scherer, Esq.
O'Brien, Baric & Scherer
19 West South Street
Carlisle, PA 17013
IRWIN & MgKNIGHT, P.C.
By:
et
60 W t Pomfr Str
Carli e, PA 170
(717 249-2353
Sunr me Court I.D. No. 25476
uire
Date: February 23, 2009
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JEREMIAH J. LECRONE IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
2006-5740 CIVIL ACTION LAW
JESSICA J. HOWE
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Friday, February 27, 2009 , 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, April 09, 2009 at 9:30
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. Gilro 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
f v :? [)id LZ e 3 J 60V,
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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.
Date: 0 3 20--
Jessica M. Howe
CERTIFICATE OF SERVICE
• I hereby certify that on March 9+ , 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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APR 14 2009A
JEREMIAH J. LECRONE,
Plaintiff
VS.
JESSICA J. HOWE,
Defendant
PRIOR JUDGE: Kevin A. Hess
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2006-5740
IN CUSTODY
COURT ORDER
AND NOW, this 5-4 day of April, 2009, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
1. A hearing is scheduled in Court Room No. 4 of the Cumberland County Courthouse
on the,13" day of 2009 at ?; 30,q m. At this hearing, the father shall
be the moving party and shall proceed initially with testimony. Counsel for the
parties shall file with the Court and opposing counsel a memorandum setting forth
the history of custody in this case, the issues currently before the Court, a summary
of each parties position on these issues, a list of witnesses who will be called to
testify on behalf of each party and a summary of the anticipated testimony of each
witness. This memorandum shall be filed at least five days prior to the mentioned
hearing date.
2. Pending further Order of this Court, this court's prior order of November 22, 2006,
shall remain in place subject to the understanding that mother shall have custody of the
minor child from Saturday, April 11, at 7:00 p.m. until Sunday, April 12, at 3:00 p.m.
for the Easter Holiday.
cc: veusan Kay Candiello, Esc
,)Orichael A. Scherer, Esgv.
4
BY THE COURT,
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JEREMIAH J. LECRONE,
Plaintiff
VS.
JESSICA J. HOWE,
Defendant
PRIOR JUDGE: Kevin A. Hess
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2006-5740
IN CUSTODY
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL
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 April 9, 2009, with the following individuals
in attendance:
The mother, Jessica J. Howe, who appeared with her counsel, Michael A. Scherer,
Esquire, and the father, Jeremiah J. Lecrone, with his counsel, Marcus A. McKnight,
III, Esquire.
3. The parties have been working under a prior court order that was entered pursuant
to an agreement and physical custody has essentially been handled on a 50/50 basis
with the parties exchanging on a week on/week off schedule. In September of this
year, the child will need to start school. The father lives in Blaine, Perry County, and
the mother lives in North Middleton Township, Cumberland County. Accordingly,
a school district needs to be selected and, in light of the distance between the parties,
a week on/week off schedule will not be feasible once this child starts attending
school. As might be expected, the father suggested the child should attend school in
Perry County and the father should have primary custody during the school year but
the mother suggests the child should attend school in Cumberland County and that
she should have primary custody during the school year. A hearing is required on this
issue and the Conciliator recommends an Order in the form as attached.
Date: 4 ? , 2009
L/
Hubert X. Gilroy,
Custody Conciliar
4
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 CIVIL TERM
IN CUSTODY
JESSICA M. HOWE, IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
V
CIVIL ACTION - LAW
NO. 06-5720 CIVIL TERM
JEREMIAH J. LECRONE, SR.,: IN CUSTODY
IN RE: CUSTODY AGREEMENT
ORDER OF COURT
AND NOW, this 23rd day of July, 2009, after hearing,
and on agreement of the parties, the existing order of court
in this case is modified in the following particulars:
1) The parties will share legal custody of the
child, Jeremiah J. Lecrone, Jr., born October 28, 2003.
Each parent will be entitled to all school records, medical
records, counseling records and similar things associated
with the child.
2) The parents will share physical custody on the
following schedule, which shall be a two-week schedule which
shall alternate.
a) During week one father shall have the child
overnight on Sunday night and shall take the child to school
on Monday morning. Mother shall have the child after school
from Monday and overnight Tuesday, Wednesday, Thursday,
Friday and Saturday, at which point the parties shall
exchange custody on Sunday of week two at 6:00 p.m. in
Landisburg, Pennsylvania.
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2006-5740 & 2006-5720 CIVIL TERM
b) The father shall have the child overnight
on Sunday night and shall take the child to school on Monday
morning. Additionally, father shall have the child Monday
during week two overnight into Tuesday morning and shall
take the child to school Tuesday morning. Mother shall have
the child during week two overnight on Tuesday night and
Wednesday night. Father shall pick the child up from school
after school on Thursday and have the child overnight on
Thursday night, Friday night and Saturday night on week two.
The child shall attend school in the Carlisle School
District at Crestview Elementary School.
The parties shall enjoy daily phone contact with the
child regardless of which parent has custody at any given
time.
During the summer months the parties shall share
physical custody on a week-on/week-off basis, with the
parties exchanging the child in Landisburg, Pennsylvania,
on Friday at 5:00 p.m.
This order shall be effective on August 31, 2009,
which is the first day of school in the Carlisle School
District.
For the Christmas holiday, the parties shall
communicate with each other in an effort to work out an
agreement with respect to Christmas Eve and Christmas Day.
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.
06-5740 & 06-5720 CIVIL TERM
The second period shall be Christmas Day at noon until
December 26th at noon. Both segments shall be alternated
with the father having the first segment in 2006 with the
parties alternating thereafter.
The remaining holidays will be as the parties agree.
By the Court,
>41r"cus A. McKnight, III, Esquire
For Jeremiah J. Lecrone, Sr.
7IKycI ael Scherer, Esquire
For Jessica J. Howe
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