Loading...
HomeMy WebLinkAbout02-2939IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA P. LANTZ, Plaintiff V. NO. 02-- c99 39 CI v%X ??A rv A M. LANTZ, CIVIL ACTION - LAW Defendant DIVORCE NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ADAM P. LANTZ, Plaintiff V. NO. O 2- 2q. bg C (.Lj ? 'CtA k+--j ANGELA M. LANTZ, : CIVIL ACTION - LAW Defendant DIVORCE COMPLAINT AND NOW, this day of June, 2002, comes the Plaintiff, %DAM P. LANTZ, by attorney, DIANE G. RADCLIFF, ESQUIRE, and files :his Complaint in Divorce, of which the following is a statement: COUNT I: DIVORCE DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 L. The Plaintiff is ADAM P. LANTZ, an adult individual residing at 516 Berkshire Lane, Mechanicsburg, Cumberland County PA 17050. !. The Defendant is ANGELA M. LANTZ, an adult individual residing at 516 Berkshire Lane, Mechanicsburg, Cumberland County, PA 4. 5. 6. 17050. Plaintiff and/or Defendant have been bona fide residents of the Commonwealth for at least six (6) months previous to the filing of this Complaint. Plaintiff and Defendant were married on January 14, 1995 at New Cumberland, Cumberland County, Pennsylvania. There have been no prior actions of divorce or annulment between the parties. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to -2- participate in counseling. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The Plaintiff avers that the ground on which the action is based is that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court to enter a cree in divorce, divorcing the Plaintiff and Defendant. COUNT II: CUSTODY 9. Paragraphs 1 through 8 are incorporated by reference hereto as fully as though the same were set forth at length. 10. Plaintiff seeks joint legal and physical custody of the following children: NAME PLACE OF RESIDENCE AGE D.O.B. Samantha Lantz 516 Berkshire Lane, 6 10/7/95 Mechanicsburg, PA Alexander Lantz 516 Berkshire Lane, 2 3/3/00 Mechanicsburg, PA DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 11. The children were not born out of wedlock. 12. The children are presently in the custody of the Plaintiff and Defendant who reside at 516 Berkshire Lane, Mechanicsburg, PA. 13. Since 1998, the children have resided with the following persons and at the following addresses: PERSONS ADDRESSES DATES Plaintiff and 516 Berkshire Lane, 1998 to Defendant Mechanicsburg, PA present 14. The mother of the children is Angela M. Lantz, currently -3- residing at 516 Berkshire Lane, Mechanicsburg, PA. She is married. 15. The father of the children is Adam P. Lantz, currently residing at 516 Berkshire Lane, Mechanicsburg, PA. He is married. 16. The relationship of Plaintiff to the children is that of father. The Plaintiff currently resides with the following persons: 17 persons: DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 L8. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. _9. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims -4- The relationship of Defendant to the children is that of mother. The Defendant currently resides with the following to have custody or visitation rights with respect to the children. 0. The best interest and permanent welfare of the children will be served by granting the relief requested because: The parties have entered into a Stipulation for the entry of a court order granting them joint legal and physical custody of the children, which is being filed of record and submitted for entry concurrently herewith. 1121. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff requests the Court to grant the parties point legal and physical custody of the children in accordance with the terms of their Stipulation being filed concurrently herewith. Respectfully submitted, , ESQUIR eTrin:71eRoad 011 # 32112 Phone: (717) 737-0100 Fax: (717) 975-0697 DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP IULL, PA 17011 (717) 737-0100 -5- VERIFICATION ADAM P. LANTZ verifies that the statements made in this Complaint are true and correct. ADAM P. LANTZ understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to Ilauthorities. ADAM P. LANTZ DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 -6- O n Ci ? 171 Lc Al: 4 a°- r m IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ADAM p. LANTZ, Plaintiff V. : NO. 2002-02939 ANGELA M. LANTZ, CIVIL ACTION - LAW Defendant DIVORCE ACCEPTANCE OF SERVICE I, Angela M. Lantz, the Defendant in the above captioned action, hereby accept service of the complaint filed in the above captioned matter on June 19, 2002. Date: 2 ANGE M. LANTZ - 1 - mu - G C :u _ y - t v T . < C7 ? _ . ADAM P. LANTZ 6.11.02. CUSTODY STIPULATION AND ORDER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ADAM P. LANTZ, Plaintiff NO. U Z? Zq' CIVIL TERM V. CIVIL ACTION - LAW IN CUSTODY ANGELA M. LANTZ, Defendant CUSTODY ORDER AND NOW, this 3A_a? of -)a_? 2002, upon consideration of the within Stipulation FOR Custody Order executed by ADAM P. LANTZ (hereinafter referred to as "Father and ANGELA M. LANTZ (hereinafter referred to as "Mother")(Mother and Father are sometimes hereinafter referred to individually "Parent" and collectively "Parents") pertaining to their minor children, SAMANTHA LANTZ, born October 7, 1995, and ALEXANDER LANTZ, born March 3, 2000 (hereinafter referred to as the "Children"), IT IS HEREBY ORDERED AND DECREED as follows: A. LEGAL CUSTODY: The Parents shall share and have joint legal Custody of the Children. Each Parent shall be entitled to participate, jointly with the other Parent, in all major non-emergency decisions affecting the Children's - 1 - ADAM P. LANTZ 6.11.02. CUSTODY STIPULATION AND ORDER health, education, religion and general well being. Pursuant to the foregoing the following shall apply: 1. Access to Information: Each Parent shall be entitled to access to any and all information, persons, entities and documentation regarding the same so that informed decisions can be made. 2. Non-major Decisions: Non-major decisions involving the Children's day to day living shall be made by the Parent then having custody, but to the extent possible, the Parents shall attempt to make such rules and follow such schedules as would provide the Children with continuity regardless of the then existing custodial Parent. 3. Emergency Decisions: Emergency decisions regarding the Children shall be made by the Parent then having physical custody, but that Parent shall immediately communicate to the other Parent the nature and extent of the emergency and shall provide that other Parent with all information pertaining to the treatment so that the other Parent may be involved in the decision making process at the earliest possible time. 4. Copies of Documents: To the extent not reasonably available to the other parent, upon receipt by a Parent, copies of the Children's school schedules, special events notifications, report cards and the like shall be provided to the other Parent, unless the documents are otherwise reasonably available to the other Parent. Each Parent shall share with the other Parent any other information and documentation, or copies thereof, that each Parent possesses regarding the Children within such reasonable time as to make the records and information of reasonable use to the other Parent. 5. Notice of Activities: Each Parent shall provide the other Parent with at least 48 hours advance notice of school or other activities - 2 - ADAM P. LANTZ 6.11.02. CUSTODY STIPULATION AND ORDER whenever possible if notice thereof is not reasonably available to the other Parent. 6. No Derogatory Comments: Neither Parent shall make any derogatory comments about the other Parent in the presence of the Children and to the extent possible shall prevent third parties from making any such comments in the presence of the Children. 7. No Discussion: Neither Parent shall discuss any aspect of the custodial situation with the children and shall not utilize the Children for purposes of conveying information or inquiries pertaining to the Children to the other Parent. 8. Appointments: Each Parent shall notify the other Parent of any medical, dental, optical and psychological appointments and/or treatment for the Children sufficiently in advance thereof so that the other Parent can attend. 9. Care Providers: Each Parent shall provide the other Parent with the name, address and phone number of any babysitter or other daycare providers that regularly watch the Children for that Parent 10. Telephone Contact: Both Parents shall be afforded reasonable telephone contact with the Children while in the other Parent's custody and for said purposes each Parent shall provide the other Parent with his or her home phone number where the Children can be reached when in the that Parent's custody. Each Parent shall provide the Children with reasonable privacy during phone conversations and shall not listen in or otherwise interfere with the phone conversations. 11. Temp orar Absence from Commonwealth: If either Parent intends on removing the Children from the Commonwealth of Pennsylvania for a period in excess of forty-eight (48) hours that Parent shall - 3 - ADAM p. LANTZ 6.11.02. CUSTODY STIPULATION AND ORDER provide the other Parent with the address and phone number where the Children can be reached during the period of absence. 12. Relocation: Neither Parent shall remove the Children from Cumberland County, Pennsylvania on a permanent basis without first securing an order from this Court approving that relocation. B. PHYSICAL CUSTODY: The following shall apply regarding physical custody of the children: 1. Shared Phvsical Custody: The parties shall share physical custody of the children, in accordance with the following schedule: a. The shared physical custody shall be on a two week rotating schedule. In week one (1) Father shall have custody from Sunday at 6:00 p.m. until Tuesday at 6:00 p.m. and from Friday at 6:00 p.m. until Sunday at 6:00 p.m. and Mother shall have custody from Tuesday at 6:00 p.m. until Friday at 6:00 p.m. In week (2) Mother shall have custody on from Sunday at 6:00 p.m. until Tuesday at 6:00 p.m. and from Friday at 6:00 p.m. until Sunday at 6:00 p.m. and Father shall have custody from Tuesday at 6:00 p.m. until Friday at 6:00 p.m. The following is a table of those custodial periods: - 4 - ADAM P. LANTZ 6.11.02. CUSTODY STIPULATION AND ORDER b. Thursday Friday Saturday mother mother until 6:00 p.m Father after 6:00 p.m Father Father Father until 6:00 P.M. Mother after 6:00 P.m* Mother S ecial Provisions Reaardina Weekend Switching: The foregoing notwithstanding, if the Memorial Day and Labor Day holiday weekend periods herein provided result in a parent having custody for more than two (2) consecutive weekends, the party - 5 - Holidays/Special Days: Custody for the major holidays and mother's Day and Father's Day shall be in accordance with the following schedule: w ,h ADAM p. LANTZ 6.11.02. CUSTODY STIPULATION AND ORDER entitled to the holiday weekend shall switch weekends with the other Parent so that neither Parent has custody of the Children for more than two (2) consecutive weekends. tion Time: Each Parent shall be entitled to two c. Summer Vaca Children under uninterrupted weeks of custody of the and subject to the following terms and conditions: 1. Consecutive or Non-Consecutive Weeks: The weeks are to be exercised in two non-consecutive one (1) week periods. 2. Encompassing Regular Weekend: To the extent possible the summer vacation weeks shall be scheduled to encompass the selecting Parent's regular alternating weekend. 3. Weekend Switching: If said scheduling set forth in subparagraph 2 above is not possible or practical, then the Parent selecting the custodial time period that encompasses the other Parent's regular alternating weekend shall switch weekends with the other Parent so that neither Parent has custody of the Children for more than two (2) consecutive weekends. 4. Advance Written Notice: Each Parent must provide the other Parent with at least thirty (30) days advance written notice of his or her intention to exercise each of these custodial weeks. 5. Conflict: Should conflict arise between the selection of said weeks the first Parent to notify the other Parent of his or her selection shall have the right to exercise custody on the weeks selected and the other Parent shall select other times for his or her weeks so as to avoid any conflicts. - 6 - ADAM P. LANTZ 6.11.02. CUSTODY STIPULATION AND ORDER C, MISCELLANEOUS CUSTODY TERMS: 1. 2. 3 4 Transportation: The transportation necessary the Pthe arentstodThe exchanges herein set forth shall be shared by provide the Parent receiving custody of the Children shall transportation for that custodial exchange. .precedence: The holiday schedule shall take precedence over any other custodial period set forth herein. The other miscellaneous custodial periods shall take precedence over the regular alternating weekend and midweek custodial periods set forth herein. Unavailability: In the event either Parent is going to be out of his town or is otherwise unavailable o herxerc Parent acco Jingly uanddthe periods, they shall notify the opportunity to have custody other Parent shall be provided with the sitter for the period of unavailability before any third party baby or day care is utilized to watch the children. Modification: The Parents shall be at liberty to modify the custodial periods herein provided to accommodate their respective schedules and special events, subject, nonetheless in all respects modifications. "',?ts for any to the mutual agreement - 7 - ADAM P. LANTZ 6.11.02. CUSTODY STIPULATION AND ORDER Distribution To: ANGELA M. LANTZ DIANE G. RADCLIFF, ESQUIRE 516 BERKSHIRE LANE 3448 TRINDLE ROAD MECHANICSBURG, PA 17050 CAMP HILL, PA 17011 ATTORNEY FOR ADAM P. LANTZ - 8 - 0 CJ" r`ai ? :J ? d V W? r ADAM P. LANTZ, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 02-2939 CIVIL TERM ANGELA M. LANTZ, CIVIL ACTION - LAW Defendant DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 19, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit 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. Dated: a Q Angel M. Lantz N a ry _y U? at. N ' ? 7 c? `? N . _ `1 4 - C a cil ADAM P. LANTZ, Plaintiff V. ANGELA M. LANTZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 02-2939 CIVIL TERM CIVIL ACTION - LAW DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit 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. _ Dated: -7 /02k 11A 0$ e ?. Angel M. Lantz ? p O cri C i l ? CIl ADAM P. LANTZ, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 02-2939 CIVIL TERM ANGELA M. LANTZ, CIVIL ACTION - LAW Defendant DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 1.9, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit 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. Dated: ?-z?- oz Adam P. Lantz -10 "L cri ADAM P. LANTZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. No. 02-2939 CIVIL TERM ANGELA M. LANTZ, CIVIL ACTION - LAW Defendant DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit 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. Dated: 9 Z9- d - z-Adam P. Lantz o G tiU-: 7 ? " - PQ CJ3 -< IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ADAM P. LANTZ, Plaintiff V. ANGELA M. LANTZ Defendant TO THE PROTHONOTARY: NO. 02-2939 CIVIL ACTION - LAW DIVORCE Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. GROUND FOR DIVORCE: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. DATE OF FILING AND MANNER OF SERVICE OF THE COMPLAINT: a. Dare of filing o complaint: June 19, 2002 b. Mannar-af--EgMri ce of Comb ain : Certified Mail/Restricted Delivery C. T'"t^ of Service of Comp lain t: June 24, 2002 3. DATE OF EXECUTION OF THE AFFIDAVIT OF CONSENT REQUIRED BY SECTION 3301 (C) OF THE DIVORCE CODE: a plain ;ff: September 28, 2002 b. Defendant: September 27, 2002 OR DATE OF EXECUTION OF THE PLAINTIFF'S AFFIDAVIT REQUIRED BY SECTION 3301(D) OF THE DIVORCE CODE AND DATE OF SERVICE OF THE PLAINTIFF'S 3301 (D) AFFIDAVIT UPON THE DEFENDANT: a. n-te of Execu ion: N/A b. nate of Filling: N/A C. note of Service: N/A 4. RELATED CLAIMS PENDING: No issues are pending. No issues have been raised in this case, and there are no issues outstanding. 5. DATE AND MANNER OF SERVICE OF THE NOTICE OF INTENTION TO FILE PRAECIPE TO TRANSMIT RECORD, A COPY OF WHICH IS ATTACHED, IF THE DECREE IS TO BE ENTERED UNDER SECTION 3301(D)(1)(I) OF THE DIVORCE CODE: a. Date of Service: N/A b. Manner of Service: N/A OR DATE WAIVER OF NOTICE IN SECTION 3301(C) DIVORCE WAS FILED WITH THE PROTHONOTARY: a. Plaintiff's Waiver: October 4, 2002 b. Defendant's Waiver: October 2, 2002 G. 344Cndle R as Cam , PA 7011 Sup oza, D # 32112 Phone: (717) 737-0100 C-) o ul IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. NO• f12-299 CTVTT, TERM VERSUS Defendant DECREE IN DIVORCE AND NOW, 0 C'4? 9 , 2002 , IT IS ORDERED AND DECREED THAT ADAM P. LANTZ PLAINTIFF, AND ANGELA M. LANTZ DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; No issues have been raised, and no issues are outstanding. PROTHONOTARY V time ~ ADAM P. LANTZ, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 2002-2939 Civil ANGELA M. LANTZ, Defendant CIVIL ACTION -LAW CUSTODY PETITION FOR MODIFICATION OF A CUSTODY ORDER AND NOW, this day of March, 2007, comes Adam P. Lantz, Plaintiff listed above, by and through his attorney, William M. Shreve, and respectfully requests This Honorable Court to modify an existing custody order, and, in support thereof avers the following: 1. Plaintiff listed above, Adam P. Lantz, is the natural father of the children, currently residing at 814 Sixteenth Street, New Cumberland, PA 17070. 2. Defendant listed above, Angela M. Lantz, is the natural mother of the children, currently residing at 400 Seventh Street, Apt. 2, New Cumberland, PA 17070 3. The parties listed above had previously been involved in a custody action in reference to these children before This Honorable Court. 4. In 2002, a Custody Stipulation was entered regarding the minor children, between the Plaintiff, Adam P. Lantz, listed above and Angela M. Lantz, Defendant. In that stipulation, the Plaintiff and Defendant were granted shared legal and physical custody, with physical custody being on a two week rotating schedule. 5. The previous order should be modified because the best interests and welfare of the children, Samantha Lantz, born October 7, 1995 and Alexander Lantz born March 3, 2000, would best be served if primary physical custody was with their Father, Adam P. Lantz, with every other weekend to their Mother, Angela M. Lantz, for the following reasons: a. Samantha has resided with her Father, Adam P Lantz, since December 11, 2006 b. The children receive love and support from their Father and his Wife, Monica. C. Children will benefit from paternal grandparent's support, both of whom reside locally. d. Alex has always resided with his sister, Samantha Lantz. e. Alex currently is having ongoing challenges with his schooling. f. Father participates actively in extracurricular activities for the children. WHEREFORE, Adam P. Lantz respectfully requests that primary physical custody of both children be given to him, with every other weekend to Angela M. Lantz Respectfully submitted, W iam M. Shreve Attorney ID#82337 3618 North Sixth Street Harrisburg, PA 17110 (717) 234-6001 ADAM P. LANTZ, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 2002-2939 Civil ANGELA M. LANTZ, Defendant CIVIL ACTION - LAW CUSTODY VERIFICATION I verify that the statements made in the foregoing Petition for Modification of a Custody Order 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- 1Z-o? Date 1 ADAM P. LANTZ, Plaintiff VS. ANGELA M. LANTZ, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2002-2939 Civil CIVIL ACTION - LAW CUSTODY CERTIFICATE OF SERVICE AND NOW this 5 day of March 2007, I William M. Shreve hereby certify that I have or will serve the within document upon the persons and in the manner indicated below: Service by First Class Mail: Angela M. Lantz 400 Seventh Street, Apartment 2 New Cumberland, PA 17070 ,r`Iliam M. Shreve n ? w ? C: 3 r.a W Q F-q J r??y ADAM P. LANTZ IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 02-2939 CIVIL ACTION LAW ANGELA M. LANTZ DEFENDANT . IN CUSTODY ORDER OF COURT AND NOW, Wednesday, March 28, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, April 17, 2007 at 2:00 PM 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: Is/ john. Man an r. Es q. IV 11 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 46, -C I Al t V S • I I HIV 2" dl LOOZ 3HI Jar 30;-?0?11311A SEP 0 7 2007 14 Adam P. Lantz, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. 02 - 2939 CIVIL ACTION LAW Angela M. Lantz, IN CUSTODY Defendant ORDER OF COURT AND NOW this J( day of 007, upon consideration of the attached Custody Conciliation Report, it is Ordere and Directed as follows: 1. The Mother, Angela M. Lantz, and the Father, Adam P. Lantz, shall have shared legal custody of the minor children, Samantha Lantz, born 10/7/1995 and Alexander Lantz, born 3/3/2000. 2. The parties agree that major decisions concerning the children's health, welfare, education and religion shall be made by them jointly, after discussion and consultation with the other, with a view toward obtaining and following a harmoniously policy in the children's best interest. 3. Primary physical custody of Samantha Lantz shall be with Father subject to Mother having partial physical custody of Samantha every other weekend. This schedule for Samantha shall coincide with Mother's physical custody of Alexander. The Mother and Father shall share physical custody of with Alexander with a week on / week off basis at their respective residences. 4. The pick up and drop off location shall be as mutually agreed upon by the parties. The non-custodial parent shall pick up the children. 5. The Mother and the Father are directed to utilize appropriate safety restraints while transporting the minor children; .Samantha Lantz and Alexander Lantz. 6. Should either Mother or Father desire to take Samantha Lantz and Alexander Lantz out of state for a day trip or take them on an over-night trip, one week's prior notice shall be given to the other party. 7. Telephone contact between Samantha Lantz and Alexander Lantz and the non-custodial parent shall be liberal as agreed upon between the parties. 4 8. Holidays: Holidays shall be mutually agreed up by the parties. 9. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this. Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference is hereby scheduled at the first available mutually agreed upon time by the parties. Counsel for the parties are directed to contact the undersigned conciliator to schedule said conciliation conference update. Distribution: Angela Lantz, 400 Seventh Street, Apt. 2 .New Cumberland, PA 17070 William M. Shreve, Esquire, 3618 North Sixth Street, Harrisburg, PA 17110 John J. Mangan, Esquire Oc? P Owozk,l?,L 9?io?o7' VINYAIASNtOd Z { '£ 'Id 01 43S LOOT MVIU .Qdd 3..4Q b-1140-(YU Adam P. Lantz, Plaintiff . V. Angela M. Lantz, Defendant . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02 - 2939 CIVIL ACTION LAW IN CUSTODY Prior Judge: Edgar B. Bayley, P.J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CW1L PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME Samantha Lantz Alexander Lantz 10/7/1995 3/3/2000 Children are currently in the shared legal and physical custody of Father, Adam P. Lantz and Mother Angela M. Lantz. 2. A Conciliation Conference was held on April 17, 2007 with the following individuals in attendance: The -Father, Adam P. Lantz, with his counsel, William M. Shreve, Esquire and the Mother, Angela M. Lantz, with her counsel, Attorney Beck, Esquire. 3. An Order of Court was previously entered per stipulation regarding physical custody of the children. 4. The parties agreed to the entry of an Order in the form as attached. 4?4 Date Jo gan, Esquir C od Conciliator DATE OF BIRTH