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JENNIE L. LAVENDER
Plaintiff
.
.
IN THE COURT OF COMMON
PLEAS OF CUHIlEllLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. ,31'81 CIVIL 1991-J
VII.
MICHAEL A. LAVENDER
Defendant
ORDBIl OP COURT
lHD NOW, JC~t\v.""'I d 7.
199Li upon consideration of the attached complaint,
it ill hereby directed that the parties and their respective counsel appear before
Sc:"",,~1 L. 1'1""::>, Esquire, the conciliator, at SCJ<;- fl.1. l1-th Sf. '-<'>(/'Jovnt-
, Pennsylvania, on w("ltttoJ""t\e ~I day of Pf'hrl.\l\.r'l, 1991/,
at ----L- o'clock fJ.m., for a Pre-Hearing CUstody Conference. At such conference,
an effort viII be made to resolve the issues in dispute; or if this cannot be
accomplished, to define and narrov the issues to be heard by the court, and to enter
into a temporary order. Either party may bring the child vho is the subject of this
custody action to the conference, but the children's attendance is not mandatory.
Failure to appear at the conference may provide grounds for entry of a temporary or
permanent order.
POl THE COURT,
By
I A_
stody Conciliator
7p'1
YOU SHOULD TAKE THIS PAPBl TO YOUR LAWYEl AT ONCE. IF YOU DO NOT HAVE A LAWYEl Oil
CANNOT AFFORD ONE, GO TO Oil TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHBIlE YOU
CAN GET LEGAL HELP.
OFFICE OF THE COURT ADHINISTRATOIl
COURTHOUSE, 4TH FLOOIl
CARLISLE, PA 17013
(n7) 240-6200
J~H Z7 I IIZ PH '9~
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
JENNIE L. LAVENDER
plaintiff
CIVIL ACTION - CUSTODY
V.
NO. 31'd. C;'1,4.l. 199'/
MICHAEL A. LAVENDER
Defendant
COMPLAINT FOR CUSTODY
AND NOW comes Plaintiff, Jennie L. Lavender, by and through
her attorneys, Kundrat & Sedor, and makes the following claim for
custody averring in support thereof as follows:
1. The Plaintiff is Jennie L. Lavender, residing at 635
Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania 17043.
2. The Defendant is Michael A. Lavender, residing at 903
Spring circle, Mechanicsburg, Cumberland County, Pennsylvania
17055.
3. Plaintiff seeks custody of the following child:
lWm
PRESENT RESIDENCE
Am;;
DATE OF
BIRTH
Ashley Marie Lavender
635 Bosler Ave.
Lemoyne, PA
The Child was not born out of wedlock. The child is
1 yr.
12/03/93
presently in the custody of Plaintiff, Jennie L. Lavender,
residing at 635 Bosler Avenue, Lemoyne, Pennsylvania 17043.
During the past five years, the child has resided with the
1
following persons and at the following addresses:
UAm& Address
Jennie L. Lavender 635 Bosler Ave.
Lemoyne, PA 17043
Jennie L. Lavender 903 Spring Circle
Michael A. Lavender Mechanicsburg, PA
17055
Dates
11/13/93 to
the Present
12/03/92 to
11/13/93
The mother of the child is Plaintiff, Jennie L. Lavender,
currently residing at the address set for in paragraph one
herein, who is married to Defendant, Michael A. Lavender.
The father of the child is Defendant, Michael A. Lavender,
currently residing at 903 Spring circle, Mechanicsburg,
Pennsylvania, who is married to Plaintiff.
4. The relationship of Plaintiff to the child is that of
Mother. The Plaintiff currently resides with the following
persons:
~
Yvonne James
RELATIONSHIP
Mother
Thomas James
Father
5. The relationship of Defendant to the child is that of
Father. The Defendant currently resides with the following
persons:
NAME RELATIONSHIP
None Known N/A
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.
2
cV~~'
Laskowkski, Esq.
Attorney I.D. #37422
1800 Linglestown Road
suite 304
Harrisburg, PA 17110
(717) 234-3911
Attorney for Plaintiff
plaintiff has no information of any custody proceeding
concerning the child pending in a court of this commonwealth.
Plaintiff does not know of any person not a party to the
proceedings who has physical custody or visitation rights with
respect to the child.
7. The best interest and permanent welfare of the child
will be served by granting the relief requested because:
Defendant has threatened and did on at least one occasion remove
the child from plaintiff's custody refusing to return the child
to Plaintiff; furthermore Plaintiff feels that she is better able
to care for the day to day needs of the child and has done so
since the child's birth.
8. Each parent whose parental rights to the child have not
been terminated and the person who has physical custody of the
child have been named as parties to this action. No other
persons are known to Plaintiff to have or claim a right to
custody or visitation of the child.
WHEREFORE, Plaintiff, Jennie L. Lavender, requests the court
to grant custody of the child to Plaintiff.
KUNDRAT & SEDOR
3
JENNIE L. LAVENDER
Plaintiff
CIVIL ACTION - CUSTODY
IN THE COURT OF COMHON PLEAS OF
CUMBERLAND COUNTY
V.
NO.
MICHAEL A. LAVENDER
Defendant
VERIFICATION
I, Jennie L. Lavender, do hereby verify that the facts
stated in Plaintiff's Complaint for Custody are true and correct.
I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn
falsification to authorities.
Dated: /-I'8-qJ./
By:
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JENNIE L. LAVENDER, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND
) COUNTY, PENNSYLVANIA
vs. )
) NO, 312 CIVIL 1994
MICHAEL A. LAVENDER, )
DeUmdant ) CUSTODY
q p'F--
AND NOW, this day of
ORDBR
lJ.-l) {l l L (,..-;-1994, upon receipt of the
conciliator's report, it appearing that the parties have agreed upon the terms and
provisions of this order which was dictated in their presence and approved by them, we
hereby order as follows:
1. Legal custody of the minor child, Ashley Marie Lavender, born December 3,
1992, shall be shared by her parents, the Plaintiff, Jennie L. Lavender, and the
Defendant, Michael A. Lavender.
2.
Primary physical custody of the said minor child is hereby awarded to her
mother.
II
The father shall have and enjoy the following periods of temporary or partial
3.
,custody with the child:
A. Alternating Sundays, commencing on Sunday, February 27, 1994, from
10:00 a.m. until 7:00 p.m.;
B. Alternating Saturdays, commencing on Saturday, March 5, 1994, from
2:00 p.m. until 7:00 p.m.;
C. Every Wednesday and Thursday evening from 4:30 p.m. until 7:30 p.m.
In the event that the mother's work schedule changes and she works evenings
other than Wednesday and Thursday, the father's evenings with the child shall
be changed to the evenings she is scheduled to work. The mother shall
provide the father with at least one week's advance notice of any such
1
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change. In addition, the father shall contact the mother by 2:00 p.m. on the
Wednesdays and Thursdays he is scheduled to have the child to confirm the
time when he will be able to pick the child up, The mother shall provide the
father, no later than Harch 1, 1994, with a telephone number where he may
either speak to her during the daytime or leave a message that she will be
certain to receive.
4.
This order is intended to be temporary only and, for that reason, we make no
,
I
Iprovision for overnight periods of temporary custody, the division of time over the
,I holidays, during the summer, or at other times. The parties are encouraged to try to
i!
,I
II resolve other matters regarding custody of their child by agreement but are reminded
"
"
,I
ii that any such agreement must be mutual and that both of them must consent to it. In
'i
lithe event that either of the parties wishes to change or modify this order or any
ilprovision thereof, within the next 180 days, they shall return directly to the
!!conciliator to do so and neither need file a formal motion or petition with the court,
il
!Ibut may write directly to the conciliator, Samuel L. Andes, and send a copy of that
1 letter to the Court Administrator.
I
I
1
I
1
II
I
I Stanley J. A. Laskowkski, Esquire
I Attorney for Plaintiff
1
iHichael A. Lavender, pro se
i 903 Spring Circle
iHechanicsburg, PA 17055
Dy Q::\3. ~~.
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IN THE COURT OF COHHON
PLEAS OF CUHBERLAND
COUNTY, PENNSYLVANIA
JENNIE L. LAVENDER,
Plaintiff
NO,
312 CIVIL 1994
[HICHAEL A. LAVENDER,
Defendant
,I
"
IIJUDGE PREVIOUSLY ASSIGNED: None
I
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!I
II
,I
II undersigned Custody Conciliator submits the following report:
I' 1. The pertinent information concerning the child who is the subject of this
11
II litigation is as follows:
Ii
I
II
I
II Ashley Harie Lavender 3 December 1992 Plaintiff/Hother
I! 2. A Conciliation Conference was held on 23 February 1994 and the following
,I individuals were present: the Plaintiff and her attorney, Stanley J. A. Laskowkski,
'I
Ii
!IEsquire; the Defendant appeared without counsel.
II 3. The parties were able to reach agreement for the entry of a temporary order
'I
II which resolves all issues for the next several months.
Ii
'i presence and approved by both of them.
CUSTODY
CONCILIATOR CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUHBERLAND COUNTY RULE OF CIVIL PROCEDURE 19l5.3-S(bl, the
NAHE
BIRTHDATE
CURRENTLY IN
CUSTODY OF
The order was dictated in their
In the event they wish to modify the order,
! they are return directly to the conciliator. With the entry of this order, no further
i action is necessary at this time.
,
2 Harch 1994
~
Samuel L. Andes
Custody Conciliator
II
I,
"
I
i
JENNIE L. LAVENDER,
Plaintiff
)
)
)
)
)
)
)
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
NO. 312 CIVIL 1994
CUSTODY
vs.
MICHAEL A. LAVENDER,
Defendant
ORDER
AND NOW, this
, 1994, upon receipt of the
day of
conciliator's report, it appearing that the parties have agreed upon the terms and
provisions of this order which was dictated in their presence and approved by them, we
! I hereby order as follows:
I,
"
It 1. Legal custody of the minor child, Ashley Marie Lavender, born December 3,
111992, shall be shared by her parents, the Plaintiff, Jennie L. Lavender, and the
IIDefendant, Michael A. Lavender.
H
:: 2. Primary physical custody of the said minor child is hereby awarded to her
,
,
mother.
" 3. The father shall
II custody with the child:
I'
I'
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:1
have and enjoy the following periods of temporary or partial
A.
Alternating Sundays, commencing on Sunday, February 27, 1994, from
10:00 a.m. until 7:00 p.m.;
B. Alternating Saturdays, commencing on Saturday, March 5, 1994, from
2:00 p.m. until 7:00 p.m.;
C. Every Wednesday and Thursday evening from 4:30 p.m. until 7:30 p.m.
In the event that the mother's work schedule changes and she works evenings
other than Wednesday and Thursday, the father's evenings with the child shall
be changed to the evenings she is scheduled to work. The mother shall
provide the father with at least one week's advance notice of any such
1
change. In addition, the father shall contact the mother by 2:00 p.m. on the
Wednesdays and Thursdays he is scheduled to have the child to confirm the
time when he will be able to pick the child up. The mother shall provide the
father, no later than March 1, 1994, with a telephone number where he may
either speak to her during the daytime or leave a message that she will be
certain to receive.
4. This order is intended to be temporary only and, for that reason, we make no
provision for overnight periods of temporary custody, the division of time over the
holidays, during the summer, or at other times. The parties are encouraged to try to
resolve other matters regarding custody of their child by agreement but are reminded
that any such agreement must be mutual and that both of them must consent to it. In
the event that either of the parties wishes to change or modify this order or any
provision thereof, within the next 180 days, they shall return directly to the
conciliator to do so and neither need file a formal motion or petition with the court,
but may write directly to the conciliator, Samuel L. Andes, and send a copy of that
letter to the Court Administrator.
By the Court,
J.
Stanley J. A. Laskowkski, Esquire
Attorney for Plaintiff
Michael A. Lavender, pro se
903 Spring Circle
Mechanicsburg, PA 17055
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
JENNIE L. LAVENDER
Plaintiff
CIVIL ACTION - CUSTODY
V.
NO. 312 CIVIL 1994
MICHAEL A. LAVENDER
Defendant
CERTIFICATE OF SERVICE
I the undersigned hereby certify that I served a true and
correct copy of Order of Court dated January 27, 1994 and
Complaint for Custody upon Defendant Michael A. Lavender, by
United States First Class Mail, certified, return receipt
requested on February 2, 1993. The return receipt executed by
Defendant Michael Lavender dated February 3, 1994 is attached
hereto and is marked as Exhibit "A" and incorporated herein by
reference.
Respectfully submitted,
KUNDRAT &: SEDOR
~:dlv- (/ i,;,..t....JL.
Stanley J Laskowkski, Esq.
Attorney'I.D. #37422
1800 Linglestown Road
Suite 304
Harrisburg, PA 17110
(717) 234-3911
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P 8'10 424 100 r J,
RECEIPT FOR CERTIFIED MAIL ~1\>i
'"0 I"SURM.CI COJLIl.lf,l iRO~IPiO ry ,,1
'.OffO~INllR'1"'r'O""'llol"'ll t
(Stl(l Ren'/stl} (,
i:fI'C'HAEL LAVEND'
SlltJ'(l1 .IM No
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NG-G;fRGIr
MEC~^Nf~~fionG PA 1705
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Michael A. Lavender
903 Spring Circle
Mechanicsburg, PA 17055
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o RtQIItInd IJ 1"lUrId
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DOME8TlC RETURN RECEIPT.
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IN THE COURT OP COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 312-CIVIL-1994
JENNIE L. LAVENDER,
plaintiff
MICHAEL A. LAVENDER,
Defendant
CUSTODY
AND NOW,
J-\ \'/~ 7
, I
ORDER OF COURT
, 199L upon
consideration of the
attached complaint, it is hereby directed that the parties and
their respective counsel appear before S<,^ ""wi L.. fl,Jc.~ F:':tJ,t
~~S- f'1. j~HI1 st. LE'''''''1''f
, Pennsylvania, on ----:r-IAC-;tk"y the :;1011, day of
,199.3-, at I o'clock L.m., for a Pre-
Esquire, the conciliator, at
CZ/Ld
Hea ./. ng 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. Either party may
bring the child who is the subject of this custody action to the
conference, but the children's attendance is not mandatory.
Failure to appear at the conference may provide grounds for entry
of a temporary or permanent order.
FOR THE COURT,
By /ti'Hli,L/L /l~ t-5?/.
custody Conciliator 'J-?j?r:?
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.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, 4TH FLOOR
CARLISLE, PA 17013
(717) 240-6200
JUt 3/ i/ 23 :'H '95
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7.3/.9,[ C"PtJ ;&t,ed 4"'- ::S.tJ,.J:.; ..fie'
.
MICHAEL A. LAVENDER,
Defendant
CUSTODY
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 312-CIVIL-1994
JENNIE L. LAVENDER,
plaintiff
PETITION TO MODIFY CUSTODY ORDER
AND NOW, comes, Plaintiff, Jennie L. Lavender, by and
through her attorneys, KUNDRAT & SEDOR, and files this Petition
to Modify a Custody Order and in support thereof avers as
follows:
1. Plaintiff, Jennie L. Lavender, currently resides at 635
Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania 17043.
2. Defendant is Michael A. Lavender, whose last known
address is 330 North 30th street, Camp Hill, Pennsylvania 17011.
3. The parties are the parents of the minor child, Ashley
Marie Lavender, born December 3, 1992, who currently resides with
Plaintiff at 635 Bosler Avenue, Lemoyne, Cumberland County,
Pennsylvania 17043.
4. On March 7, 1994 the Court entered an Order of Custody
granting Plaintiff primary physical custody of the minor child,
Defendant periods of temporary or partial custody of the minor
child, as well as joint legal custody to the parties. A true and
correct copy of the Order is attached hereto and incorporated
herein marked as Exhibit "A".
5. The prior Order of Court dated March 7, 1994 was
intended to be temporary and did not include a division of time
for holidays, summers and other times which issues are required
to be addressed by the parties and to which they have been unable
to mutually agree.
6. It is in the best interests and permanent welfare of the
minor child, Ashley Marie Lavender, to be served by modification
of the Court Order in order to alter periods of temporary or
partial custody for Defendant to consecutive Saturdays from 2:00
p.m. to 7:00 p.m. and Sundays from 10:00 a.m. to 7:00 p.m. on
alternating weekends, as opposed to one afternoon per weekend as
been currently scheduled and occurring pursuant to the pending
Order of Court.
7. Plaintiff believes that the modification of the periods
of partial physical custody by the Defendant will be in the best
interest of the minor child.
WHEREFORE, Plaintiff requests that the Court modify the
Court Order as set forth herein or as otherwise may be deemed in
the best interests of the minor child.
Respectfully submitted,
~ &~~
Stanley J. . Laskowski,
Attorney 1.0. #37422
1800 Linglestown Road
suite 304
Harrisburg, PA 17110
(717) 234-3911
2
1:
VERrFrCATrON
I do hereby verify that the facts stated in the foregoing
Petition to Modify custody Order 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.A. Section 4904 relating to unsworn falsification to
authorities.
Dated: 7 - /7-Q.s-
.
BXHIBIT
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:1 JENNIE L.
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
NO. 312 CIVIL 1994
LAVENDER,
Plaintiff
)
)
)
)
)
)
)
CUSTODY
vs.
MICHAEL A. LAVENDER,
Defendant
ORDER
AND NOW, this
tJ....
'7 day of 'TYla-vJu
, 1994, upon receipt of the
conciliator's report, it appearing that the parties have agreed upon the terms and
provisions of this order which was dictated in their presence and approved by them, we
I
!hereby order as follows:
j: 1. Legal custody of the minor child, Ashley Marie Lavender, born December 3,
'1992, shall be shared by her parents, the Plaintiff, Jennie L. Lavender, and the
I .
I
I Defendant, Michael A. Lavender.
,\
,
Ii
I mother.
i
d 3. The father shall
IjcustodY with the child:
I
I
2.
Primary physical custody of the said minor child is hereby awarded to her
have and enjoy the fOllowing periods of temporary or partial
A.
Alternating Sundays, commencing on Sunday, February 27, 1994, from
I 10:00 a.m. until 7:00 p.m.;
,I
I'
Ii B. Alternating Saturdays, commencing on Saturday, March 5, 1994, from
"
L 2:00 p.m. until 7:00 p.m.;
"
::
C. Every Wednesday and Thursday evening from 4:30 p.m. until 7:30 p.m.
~ ;
In the event that the mother's work schedule changes and she works evenings
I,
other than Wednesday and Thursday, the father's evenings with the child shall
be changed to the evenings she is scheduled to work. The mother shall
,
provide the father with at least one week's advance notice of any such
1
(....- . ..~
, .11
'I
'I
I,
I,
I
I
I
change. In addition, the father shall contact the mother by 2:00 p.m. on the
Wednesdays and Thursdays he is scheduled to have the child to confirm the
time when he will be able to pick the child up, The mother shall provide the
father, no later than March 1, 1994, with a telephone number where he may
either speak to her during the daytime or leave a message that she will be
certain to receive.
4. This order is intended to be temporary only and, for that reason, we make no
provision for overnight periods of temporary custody, the division of time over the
I hOlidays, during the summer, or at other times. The parties are encouraged to try to
ilresolve other matters regarding custody of their child by agreement but are reminded
Ii that any such agreement must be mutual and that both of them must consent to it. In
I the event that either of the parties wishes to change or modify this order or any
provision thereof, within the next 180 days, they shall return directly to the
conciliator to do so and neither need file a formal motion or petition with the court,
but may write directly to the conciliator, Samuel L. Andes, and send a copy of that
letter to the Court Administrator.
II
I
I
I
i
.'
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'.
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I'
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dStanley J. A. Laskowkski, Esquire
I: Attorney for Plaintiff
Ii
~IMichael A. Lavender, pro se
il903 Spring Circle
pMechanicsburg, PA '17055
.
,
By the Court,
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TRUE COpy FROM RECORD
In Teslimon, 'ph r-d, i h:,. unto set my hand
and the seal of said Court at Carlisle, Pa.
This ....,'l.-!'::..... day of.J.:n,~......, 19,:l.~.
_.................J~~ A.. -D~~
.... .....Q.hIi ._
~' Prothono ary
2
J.
v.
IN THE COURT OF COKMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 312-CIVIL-1994
JENNIE L. LAVENDER,
plaintiff
MICHAEL A. LAVENDER,
Defendant
CUSTODY
CERTIFICATE OF SERVICE
I, Stanley J. A. Laskowski, Esquire, do hereby certify that
I have served a Petition to Modify custody Order by placing a
true and correct copy of same in the United states mail, first
class, postage prepaid thereon, on the~~ th Day of July 1995
addressed to the following person(s):
Michael A. Lavender
330 North 30th Street
Camp Hill, PA 17011
KUNDRAT & SEDOR
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Stanle . Esq.
Attorne I.D. #37422
1800 Linglestown Road
suite 304
Harrisburg, PA 17110
(717) 234-3911
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JENNIB L. LAVENDER, I IN THE COURT OP COMMON PLEAS
plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
v. I NO. 312 CIVIL 1994
I
HICHABL A. LAVENDER, I CIVIL ACTION - LAW
Defendant I CUSTODY
ORDER OP COURT
AND NOW,
this
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day Of~, 1995, pursuant to
the attached stipulation executed by the parties, it is hereby
ORDERED AND DECREED that the Custody Order of March 7, 1994 shall
be modified as follows:
1. Father and Mother shall have shared legal custody of the
child ASHLEY MARIE LAVENDER. Mother shall have primary physical
custody of the minor child.
2. Father shall have the following periods of partial
physical custody with the child:
a) Alternating weekends commencing August 11, 1995,
from 5:30 p.m. Friday to 7:30 p.m. Sunday;
b) Alternating -holidays from 9:00 a.m. to 7:30 p.m.
which holidays shall consist of Labor Day, Thanksgiving, Easter,
Memorial Day and Fourth of July. Partial custody shall commence
Labor Day 1995 with Father.
Father and Mother each shall have
custody on Father's Day and Mother's Day respectively, from 9:00
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a.m. to 7:30 p.m., which shall take precedence over the alternating
weekend schedule set forth herein;
c) Christmas shall be divided into two segments.
segment A shall run from December 24th at 5:00 p.m. to December
25th at 1:00 p.m. Segment B shall run from December 25th at 1:00
p.m. To December 26th at 1:00 p.m. The parties shall alternate
annually the Segments. Segment A shall commence in 1995 with
Father;
d) Mother may consider and discuss with Father
providing one additional weekday evening period of partial custody
at such time when Father's work schedule permits his regular and
consistent availability; such day and time to be mutually agreed
between the parties;
e) Father shall have the right annually to exercise one
continuous week of vacation partial custody, subject to Father
providing a minimum of thirty (30) days written notice to Mother
prior to commencing the vacation week.
3. Mother and Father shall refrain from making disparaging
comments about the other party in the child's presence and shall do
their best to assure that third parties make no such comments in
the child's presence.
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4. Neither party shall abuse alcohol, use drugs or smoke
cigarettes in the same vehicle or household when they have custody
of Ashley.
5. Any contact between the parties regarding custody matters
shall be between Jennie Lavender and Michael Lavender or their
respective counsel.
BY THE COURT:
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JllHNZll L. LAVENDER,
l'1aintiff
ZH THB COURT OF COMMOH PLBAS
CUMBERLAHD COUNTY, PBNHSYLVAHZA
HO. 312 CZVZL 1994
CZVZL ACTZOH - LAW
CUSTODY
v.
JaCBABL A. LAVENDER,
Defendant
STIPULATION
WHEREAS, the parties were married on July 27, 1991; and
WHEREAS, JENNIE L. LAVENDER (hereafter "Mother") presently
resides at 635 Bosler Avenue, Lemoyne, Cumberland county,
Pennsylvania 17043; and
WHEREAS, MICHAEL A. LAVENDER (hereafter "Father") presently
resides at 330 North 30th street, camp Hi~l, Cumberland County,
Pennsylvania 17011; and
WHEREAS, the parties are the parents of a minor child,
ASHLEY MARIE LAVENDER born December 3, 1992;
NOW THEREFORE, intending to be legally bound, it is hereby
agreed between the parties that:
1. Father and Mother shall have shared legal custody of
ASHLEY MARIE LAVENDER. Mother shall have primary physical
custody of the minor child.
2. Father shall have the following periods of partial
physical custody with the child:
a) Alternating weekends commencing August 11, 1995,
sunday;
b) Alternating holidays from 9:00 a.m. to 7:30 p.m.
which holidays shall consist of Labor Day, Thanksgiving, Easter,
Memorial Day and Fourth of July. Partial custody shall commence
" .
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Labor Day 1995 with Father. Father and Mother each shall have
custody on Father's Day and Mother's Day respectively, from 9:00
a.m. to 7:30 p.m., which shall take precedence over the
alternating weekend schedule set forth herein.
c) Christmas shall be divided into two segments.
Segment A shall run from December 24th at 5:00 p.m. to December
25th at 1:00 p.m. Segment B shall run from December 25th at 1:00
p.m. to December 26th at 1:00 p.m. The parties shall alternate
annually the segments. Segment A shall commence in 1995 with
Yi~~.
'1 ~___u,~, d) Mother may consider and discuss with Father
providing one additional weekday evening ~eriod of partial
custody at such time when Father's work schedule permits his
regular and consistent availability; such day and time to be
mutually agreed between the parties.
e) Father shall have the right annually to exercise
one continuous week of vacation partial custody, subject to
Father providing a minimum of thirty (30) days written notice to
Mother prior to commencing the vacation week.
~/ Fat~s~ll be spons
mino~~ld to~rom Mothe
er!ods of partial physical custody.
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4. Mother and Father shall refrain from making disparaging
comments about the other party in the child's presence and shall
do their best to assure that third parties make no such comments
in the child's presence.
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. .
5. Neither party shall abuse alcohol, use drugs or smoke
cigarettes in the same vehicle or household when they have
custody of Ashley.
6. It is further agreed that the parties hereto shall
stipulate and agree to the entry of an Order of Court conforming
joint legal custody and partial physical custody of their minor
child in accordance with the terms herein.
Signed this ~t~
{J111.wh
1995.
day of
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JOANNE HARRISON CLOUGH
ATI"I)RNIY AT IAU'
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