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Home My WebLink About95-01213 ~ J . -7 ] (!j ~ I po I ~! Ol c<) - ~ i - I I IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA SAMUEL E. BLACK and JACQUELINE H. BLACK, PETITIONERS CIVIL ACTION - LAW . . V. NO. 96- 1.213 CIVIL TERM CHRISTOPHER LUCAS and MICHELLE R. LUCAS, RESPONDENTS CUSTODY ORDER OF COURT NOW, -.f1 ':JJt.k.. lo the within Stipulation follows: ,1996, upon consideration of and Agreement, it is hereby ordered as 1. PETITIONERS and RESPONDENTS shall share legal custody of the minor child, MEGAN ELIZABETH LAMASON, and pursuant to this grant of shared legal custody, each parent shall have equal access to all pertinent information and reports that may be generated by medical, educational, psychological and other professionals who may work with their child. Each parent shall discuss major decisions effecting the child's well being in the areas of medical, educational, emotional, spiritual, social, and material needs with the opposite parent. 2. PETITIONERS shall exercise primary residential custody of said minor child. RESPONDENTS shall exercise partial residential custody as can be agreed by the parties. PETITIONERS shall not unreasonably withhold their consent to partial custody, as the purpose of this Agreement is to allow each party to maintain strong and meaningful relationships with the child. 3. On holidays, the parties shall exercise shared physical custody of the child as can be mutually agreed. 4. Neither party shall do anything which may estrange the child from the other party, or injure the opinion of the child as to the other party or which may hamper the free and natural development ?;~v,tl~~.i"c}ji'l,d~:_s love or respect for the other party. AIj"l~,ut:\:.;.' j , '; ~Jl:!t: 56. WJ EE 2 01 H'IW By the Court, ,/1 J. I IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA SAMUEL E. BLACK and JACQUELINE H. BLACK, PETITIONERS : CIVIL ACTION - LAW . . . . V. NO. 96- 1~/3 CIVIL TERM CHRISTOPHER LUCAS and MICHELLE R. LUCAS, RESPONDENTS CUSTODY PETITION FOR ENTRY OF AGREEMENT AND NOW come the Petitioners, SAMUEL E. BLACK and JACQUELINE H. BLACK, by and through their attorney, Richard L. Webber, Jr., and file this Petition pursuant to Pa.R.C.P. No. 1915.7, averring the following: 1. BLACK, who Allen Road, Petitioners are SAMUEL E. BLACK and JACQUELINE reside in Cumberland County, Pennsylvania, at Carlisle. H. 261 2. Respondents are CHRISTOPHER LUCAS and MICHELLE R. LUCAS, who reside at 1075 Harrisburg Pike, Room 9, Carlisle, 3. The Respondents are natural parents of MEGAN ELIZABETH LAMASON, born February 22, 1987. 4. On or about March 2, 1995, the parties entered into an Agreement regarding custody of the child. Said Agreement is attached hereto and incorporated by reference herein. 5. The best interest of the child would be served by the entry of an Order of Court reflecting the terms of the Agreement. WHEREFORE, Petitioner requ~sts your Honorable Court to approve the attached Agreement and enter it as an Order of Court. Respectfully submitted, ;U j'~4:i Richard L. Webber, . Attorney for Petitioner 366 Green Spring Road P.O. Box 40 Newville, PA 17241-0040 ( 717) 776-6566 IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA SAMUEL E. BLACK and JACQUELINE H. BLACK, PETITIONERS CIVIL ACTION - LAW . . V. . . : NO. 95- 1.J1.3 CIVIL TERN CHRISTOPHER LUCAS and MICHELLE R. LUCAS, RESPONDENTS . . CUSTODY T~ S~LATION AND AGREEMENT is made this ,~?<l day of '/ Lt, , 1995, by and between SAMUEL E. BLACK and JACQUELINE H. BLACK, hereinafter referred to as "PETITIONERS," and CHRISTOPHER LUCAS and MICHELLE R. LUCAS, hereinafter referred to as "RESPONDENTS." 1 . Black, of Pennsylvania PETITIONERS are Samuel E. Black and Jacqueline H. 261 Allen Road, Carlisle, Cumberland County, 17013. 2. Lucas, of County, PA Kingstown, RESPONDENTS are Christopher Lucas and Michelle R. 1075 Harrisburg Pike, Room 9, Carlisle, Cumberland 17013, with mailing address of P.O. Box 511, New PA 17072. 3. RESPONDENTS are the natural parents of MEGAN ELIZABETH LAMASON, born February 22, 1987. 4. The relationship of PETITIONER, JACQUELINE H. BLACK to the child is that of great great-aunt. 5. With the exception of this action, neither party has participated as a party in other litigation concerning the custody of the child in this or any other court. 6. None of the parties has information of a custody proceeding concerning the children pending in a court within or outside this Commonwealth. 7. None of the parties knows of any person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 8. During the past five (5) years, the child has resided with the following persons and at the following addresses: &W: ADDRESS IW:i Samuel E. Black 261 Allen Road 2/16/95 to and Jacqueline H. Carlisle, PA 17013 present Black Scott Lucas 88 Cherry Lane 12/94 to Carlisle, PA 17013 2/16/95 Christopher and 19th and Briggs St. 10/94 to Michelle R. Lucas Harrisburg, PA 12/94 Christopher and Regency Woods Trailer Park 8/94 to 10/94 Michelle R. Lucas Carlisle, PA 17013 Christopher and 88 Cherry Lane 1990 to Michelle R. Lucas Carlisle, PA 17013 August 1994 9. The parties have reached an agreement with respect to the custody of the minor child and desire to reduce and incor- porate their agreement to an order of court. 10. The parties further agree that, in procuring this Agreement, there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. NOW, THEREFORE, the parties intend to be legally bound and waiving their right to be present when this Agreement and Order are presented and executed, hereby stipulate and agree that the Court may enter the following Order of Court in the above captioned case: ORDER OF COURT NOW, consideration of the within Stipulation it is hereby ordered as follows: , 1995, upon and Agreement, 1. PETITIONERS and RESPONDENTS shall share legal custody of the minor child, MEGAN ELIZABETH LAMASON, and pursuant to this grant of shared legal custody, each parent shall have equal access to all pertinent information and reports that may be generated by medical, educational, psychological and other professionals who may work with their child. Each parent shall discuss major decisions effecting the child's well being in the areas of medical, educational, emotional, spiritual, social, and material needs with the opposite parent. 2. PETITIONERS shall exercise primary residential custody of said minor child. RESPONDENTS shall exercise : partial residential custody as can be agreed by the parties. PETITIONERS shall not unreasonably withhold their consent to partial custody, as the purpose of this Agreement is to allow each party to maintain strong and meaningful relationships with the child. 3. On holidays, the parties physical custody of the child agreed. shall exercise shared as can be mutually 4. Neither party shall do anything which may estrange the child from the other party, or injure the opinion of the child as to the other party or which may hamper the free and natural development of the child's love or respect for the other party. By the Court, J. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, do execute this Stipulation and Agreement. WITNESS: ../~l c 4~....4 SAMUEL E. BLACK H, BLACK f\ } ~:!' J2,CI.,,,, ~R LUCAS 'a);. , ? }{;.? "1J](, v.i.fL /{,.' .t.fl./};JJ MICHELLE R. LUCAS .' I verify that the statements made in this Stipulation 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. Date: 3/~/7.::,- -/~."I r~.4...A. Samuel E. Black, Petitioner I verify that the statements made in this Stipulation 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. Date: _1/'J. /'lS- Jacq I verify that the statements made in this Stipulation 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. Date: '.) I CJ/ r; ( f (OQ_'J (, 'f: ~ ~ ",w. ((,>-, Christopher Lucas, Respondent I verify that the statements made in this Stipulation 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. Date: 3/2/95- mtL'..Ize.{!/ R ~(fl~/) .; Michelle R. Lucas, Respondent ct0 Pol.. (}'ft:: , 'io.~ 1- --, s,w SJ 1 '1S':50 HAR 7 3 III PH '95 flLE:;-OtrlCE OF THE f"QTljiJlI?TA~Y CU"fE1EiH..\~,O ~(lU"TY PtI/N5Yl\"'h'~ ~~~ '31,'(-/y~-, " ~ p. Oe.. J IVI