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Home My WebLink About02-3376 GLENN L. BAER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW . : ~O.2.- 33?i, CIVIL TERM KELLY R. (BAER) LEHMAN, Defendant IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, Glenn L. Baer, by his attorneys, Irwin, McKnight and Hughes, and presents the following Complaint for Custody. 1. The Plaintiff is Glenn L. Baer, an adult individual residing at 11 Center Road, Newville, Cumberland County, Pennsylvania 17241. 2. The Defendant is Kelly R. (Baer) Lehman, an adult individual residing at 1673 Newville Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are the natural parents of one (1) minor child, namely Glenn L. W. Baer, II, born May 22, 1990. 4. The Plaintiff desires shared legal custody of the minor child, Glenn L. W. Baer, II. ,. 5. The Plaintiff desires primary physical custody of the minor child Monday through Friday of each week. 6. The Plaintiff desires that temporary physical custody of the minor child be with Defendant every weekend. 7. The Plaintiff desires that the time and place for the custody exchange of the minor child be as the parties agree. 8, The Plaintiff desires that the parties will provide for custody of Glenn L. W. Baer, II, during all holidays pursuant to his best interest. 9. The best interests and permanent welfare of the minor child, Glenn L. W, Baer, II, requires that the Court grant the Plaintiff's request as set forth above. WHEREFORE, Plaintiff, Glenn L. Baer, respectfully requests that he be awarded primary physical custody and shared legal custody of Glenn L. W, Baer, II, as provided herein, with periods of temporary custody to Defendant as provided herein. Respectfully submitted, By: 're Date: July 15, 2002 VERIFICATION The foregoing Complaint in Custody is based upon information which has been gathered by counsel and myself in the preparation of thir action. I have head 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. a: ~4~~ GLENN L. BAER Date: July 15,2002 - (":) f((j ~ ~ & ...J L ~ ~ +- \...-.!:.., ~ o ~ ..... JJ .J tv .c:. o (') c -;= -ofh fTIr;: ;?: :""!,) zc CFJ-' ' -<;< ~C) -,.;; C;;C LC-) ):>,..2 ~, ~ o r,) ,-, -,OJ (= ,-- (J"", (-") i:]f~ .,~, 100- ::0 -< ~: w :::> <T\ ---. i t\ ,. ,c:j GLENN L. BAER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF v. 02-3376 CIVIL ACTION LAW KELLY R. (BAER) LEHMAN DEFENDANT IN CUSTODY 9RDER OF COURT AND NOW, Monday, July 22, 2002 , upon consideration of the attached Complaint, ..~:~ it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, " 4th ""'. C......".... C...." C........... C".... on "'......". A....~ 15. '001 ,,8,30 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: /sl Tacqueline M. Vern~, Esq, r 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 ATIORNEY AT ONCE. IF YOU DO NOT HA VB AN ATIORNEY 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, Pennsylvania 17013 Telephone (717) 249-3166 GLENN L. BAER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW KELLY R. (BAER) LEHMAN, Defendant 02-3376 CIVIL TERM IN CUSTODY CUSTODY STIPULATION AND NOW, thj, g" day of 40", f ' 2002, the p""os, KELLY R. (DAER) LEHMAN and GLENN L. BAER hereby enter into the following Custody Stipulation and Agreement regarding their minor son, GLENN L. W. BAER, II: 1. The Plaintiff, Glenn L. Baer, is an adult individual who resides at 11 Center Road, Newville, Cumberland County, Pennsylvania 17241. 2. The Defendant, Kelly R. (Baer) Lehman, is an adult individual who resides at 1673 Newville Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are the natural parents of one (1) child, namely, Glenn L. W. Baer, II, born May 22, 1990. 4. The parties agree to have shared legal custody of the minor child, Glenn L. W. Baer, II. 2 5. The PlaintifflFather shall have primary physical custody of Glenn L. W. Baer, IT, Monday through Friday of each week. 6. The Defendant/Mother shall have temporary physical custody of Glenn L. W. Baer, IT, every weekend. The times and place for the exchange shall be agreed upon by the parties. 7. The parties shall provide for custody of Glenn L. W. Baer, IT, during all holidays pursuant to his best interest. 8. The parties shall keep each other advised immediately in the event of serious illness or medical emergency concerning the child, and shall take any necessary steps to ensure that the health and well-being of the child are protected. During such illness or medial emergency, both parties shall have the right to visit the child as often as he or she desires consistent with the proper medical care of the child. 9. The parties shall not do anything that may estrange the child from the other party, or injure the opinion of the child as to the other party, or hamper the free and natural development of the child's love and affection for the other party, 3 10. The parties may make such alternate arrangements regarding the physical custody of the child so long as they may mutually agree, The parties anticipate regularly varying from the tenus of this Stipulation in order to accommodate the schedules of each other and the child. However, if the parties cannot reach a mutual agreement, the tenus of this Stipulation and Order shall control. 11. Any modification or waiver of any other provisions of this Agreement shall be effective only if made in writing and only if executed with the same fonuality as this Stipulation and Agreement. 12. The parties desire that this Stipulation and Agreement be made an Order of the Court of the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over the issue of custody of the parties' minor child who has resided in Cumberland County for more than six months and shall retain such jurisdiction should circumstances change and either party desires or requires modification of said Order. 13. The parties acknowledge that they have read and understand the provisions of this Agreement. Each party acknowledges that the Agreement is fair and equitable and that it is not the result of duress or undue influence. 4 . 14. Each party has had an opportunity to consult independent legal counsel of his or her own selection. Each party regards the terms of this Agreement as fair and equitable, and each has signed it freely and voluntarily without relying upon any representation other than those expressly set forth herein. IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms set forth above, enter their hands and seals the date fIrst set forth above. x__ ~i ~. ~ f)(f10n LL Y . LEHMAN (SEAL) OL/~~~ GLENN L. BAER (SEAL) 5 (') ~ -oG- fill -,7 ' 6", ~; ~~C_; ~; (~ ~S? :':1 -< .~ '\_.,~..' l~"") o '~l-i --I ~ ;") -;: rJ " ~.Tl \.:;J (~) :;l""~ --... !:"" ()'> n ;:~m '-.-.1 :---i :U - / ...... . ~ ~ fp --:- ~ ~ <'"<7'''''-<:L ~ b z ~ ~~ <<'o-t?E:c. ~~ -r ~ ~~/-~ COt?-oe-L. Vfl\!~/n \ ('\'I\I::Jd U../('....'r . 1.0J, _' , 1\/;1, j, J 'l!' ;!'7;~=;pv~nJ 9'1 :1:; o L' -,1]1' 20 Ir'l; ;',()/ . ~.'~- dJ .. " GLENN L. BAER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 02-3376 CIVIL TERM KELLY R. (BAER) LEHMAN, Defendant IN CUSTODY ORDER OF COURT AND NOW, this l't~ay of ~002, upon presentation and consideration of the attached Custody Stipulation and Agreement, it is hereby Ordered and Directed that it be entered as an Order of Court. J. Kelly R. (Baer) Lehman Defendant Marcus A. McKnight, ill, Esq. Attorney for Plaintiff ~ - ~ ?_lq.O:b ~. '. V:NWIl}\SNN3d 1\.LNnOJ C1[.,"cI""F18;'In:) ilS :Z lid 5 I ~:illV ZO AtlV lCJJ_ ' :; ~)H~()-C-:.,j :::1 'r"\ :2\..J JAN 0 2 Z003 \r GLENN L. BAER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2002-3376 CIVIlL TERM KELLY R. (BAER) LEHMAN, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 2nd day of January, 2003, the Conciliator being notified that the parties have signed a Custody Stipulation in the above matter, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, -, j,'} I i, ., ,,' . .,_ 1/1 f j~c;~:~. '~::y, ESqUir~,~~;a~nciliator iX: _c" ~ l,l} -', (.) .~~ Li_~ ~:rj ~ j .....:.- (-', 2-, w C~~"'~ .-J... t-- lL (:J ,.... ~ ?)~ - 7' D<r' :3 ,.- -~~ ~ JL.... '...Z i.iiu.l ;' 1..\ 0... :'3 <-) :r: .~ ('-) I ::2~~ ~t.. -, , C'? o