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LISA LORING,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - CUSTODY
vs.
ANDREW REYES,
Defendant
1 ~! 1
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(II II, c.
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11)
NO.
ORDRR
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AND NOw,~upon consideration of the Stipulation of the parties
dated i' - 1', Y'--- , IT IS HEREBY ORDERED AND DECREED as
follows:
1. LISA LORING and ANDREW REYES shall have shared legal
custody of their son, KENNETH ANDREW REYES LORING, born
November 5, 1993;
2. LISA LORING shall have primary physical custody of said
child;
3. ANDREW REYES shall have periods of temporary physical
custody for the purposes of visitation as follows:
a. Alternating weekends from Friday at 6:00 P.M.
to Sunday at 6:00 P.M.
b. One evening per week from 5:00 P.M. to 9:00 P.M..
The exact day shall be arranged with two weeks
prior notice to the Mother.
c. Each parent shall have three (3) non-consecutive
weeks each year for vacation from Sunday to
Saturday. Each party shall give thirty (30) days
written notice of their choice of weeks. Same
cannot be exercised during any holiday period.
d. Parties shall share the holidays of Easter, New
Years Day, Memorial Day, 4th of July, Labor Day,
Thanksgiving and Christmas Day with the Father
having the period of 2:00 P.M. to 9:00 P.M. on each
of those days.
e. The child's birthday shall be shared equally as the
parties can schedule. The child shall be with
Mother on Mother's Day and Mother's birthday and be
with Father on Father's Day and Father's birthday.
f. During the first year the parties shall exchange
the child at a public place, such as the Kentucky
Fried Chicken restaurant on Lowther Street in
Lemoyne, or as otherwise reasonable arranged.
Father and Mother may telephonically or through
third parties make confirmation or arrangements for
the pick-up and delivery of the child.
4. The parties shall first offer each other the right to
care for the child in the event a temporary babysitter is
required during periods of custody exercised by the other
parent.
5. Neither parent shall take the child from the continental
United states without giving a 30 day written notice to
the other parent. Full disclosure of satisfactory travel
plans and itinerary must be provided to the other parent
at that time.
BY THE COURT:
, /J/L
J.
-
vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - CUSTODY
LISA LORING,
Plaintiff
ANDREW REYES,
Defendant
NO.
CUSTODY STIPULATION
THIS AGREEMENT is made this %-~ day of6""~1995
,/
by and between LISA LORING, Cumberland County, pennsylvania,
(hereinafter referred to as "Mother") and ANDREW L. REYES,
Cumberland County, Pennsylvania, (hereinafter referred to as
"Father").
WITNESSETH
WHEREAS, Mother and Father are the parents of Kenneth Andrew
Reyes Loring, born November 5, 1993;
WHEREAS, Mother and Father desire to define their rights of
custody and visitation in regard to their son, Kenneth;
NOW THEREFORE, the parties, intending to be legally bound, do
agree as follows:
1 . Mother and Father shall have shared legal custody of
their son, Kenneth Andrew Reyes Loring.
The parties
shall therefore consult on issues of major importance of
the child's life in order to determine actions in the
3
.,.
"-,.,
child's best interest.
2. Mother shall be the child's primary physical custodian.
Father shall have temporary physical custody of the child
for the purposes of visitation as follows:
a. Alternating weekends from Friday at 6:00 P.M. to
Sunday at 6:00 P.M.
b. One evening per week from 5:00 P.M. to 9:00 P.M.
The exact day shall be arranged wi th two weeks
prior notice to the Mother.
c. Each parent shall have three (3) non-consecutive
weeks each year for vacation from Sunday to
Saturday. Each party shall give thirty (30) days
written notice of their choice of weeks. Same
cannot be exercised during any holiday period.
d. Parties shall share the hOlidays of New Years Day,
Easter, Memorial Day, 4th of July, Labor Day,
Thanksgiving and Christmas Day with the Father
having the period of 2:00 P.M. to 9:00 P.M. on each
of those days.
e. The child's birthday shall be shared equally as the
4
parties can schedule. The child shall be with
Mother on Mother's Day and Mother's birthday and
Father on Father's Day and Father's birthday.
f. During the first year the parties shall exchange
the child at a public place, such as the Kentucky
Fried Chicken restaurant on Lowther street in
Lemoyne, or as otherwise reasonable arranged.
Father and Mother may telephonically or through
third parties make confirmation or arrangements for
the pick-up and delivery of the child.
3. The parties shall first offer each other the right to
care for the child in the event a temporary babysitter is
required during periods of custody exercised by the other
parent.
4. Neither parent shall take the child from the continental
United states without a 30 day written notice to the
other parent. Full disclosure of satisfactory travel
plans and itinerary must be provided to the other parent
at that time.
5. The parties hereby affirm their desire for this Agreement
to be entered as an Order of Court. The parties
acknowledge that each has had the opportunity to consult
5
with counsel concerning execution of this Stipulation.
The parties do hereby stipulate to the incorporation of
its terms into such an Order.
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LISA LORING
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nd sUb~dbed
t /- :.6<-, day
_ , 1995
MOTHER:
FATHER:
Sworn to and sUbi~ibed
befo~~is day
of , 1995
~A62L
'NOTARY PUBLIC
"-...---__6lIIII
_M.OlrMNoIIlY~
ComPl+I!aaro.~ 22.,lIi1T
MyecmmisslCll
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ANDRE REYES '7
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Barbara Swnple-Sullivan. Esquire
Supreme Cnurt #32317
549 Bridge Slr."t
New Cumberland.I'A 17070
(717)774-1445
LISA LORING,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PlaintitT
v.
No. 95-4273
ANDREW REYES,
CIVIL ACTION-CUSTODY
Defendant
AFFIDAVIT OF SERVICE
I, Barbara Swnple-Sullivan, Esquire. dn hereby certify Olatl ,,,,,,'ed a copy nf the Petlllon for Modlncatlon of
Custody Order in the abnve-eaptioned matter by United States Mail. Restricted Delivery, Certili...t No. 7003 0500
000 I 6564 5444, Relurn R...eipl Requested. on lhe abn\'C-named Defendant. Andrew R.')'cs, nn September 17.2004 at
Defendant's last knmm address: 6t3.B Brld~e Street, New Cumberland, PA 17070. Tbe nriginal receipt and rclurn
receipt card arc attached heretn os Exhibil . A".
I hereby certify that the facts set fnrth abn\'e ore true ond eorr...t tn the best of my knnwledge, infnrmatinn and
belief. I understand that any false statements made herein arc subj."ltn penalties of 181'0. C.S.A. !j4904 relating to
unswnm falsilieation to authorities.
Dat...t: septemb.2Y004
('
Ilarbara Sumple-Sulli\'an. Esquire
549 Bridge Slreet
New Cumberlalld.I'A 17070-1931
(717)-774.1445
Supreme Cnurt \1) #32317
Attorney fnr I'lailltill'
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LISA LORING
PLAINTIFF
IN TII E COI IRT OF ('OMMON ('LEAS OF
CUMIlElU.ANIl COUNTY. PENNSYLVANIA
v,
95-4273 CIVil. MTION LAW
ANDREW REYES
DEFENDANT
IN CUSTODY
OIUlEI{ OF COI IltT
AND NOW. Thursday. September 23. 2004 , upon eonsider~tion of the attached Compluint.
it is herehy directed that parties and their respective counsel appear helhreJD<llue!!nel\.J., Ver.!l~Y-, Es_q._., the conciliator.
at 4th Floor. Cumberland Counly Courthouse. Carlisle on Thursday. Oelober 14. 2004 ut 8:30 A1\1
for a Pre-Hearing Custody Conlercnce. At such confercnce. an eflim will be made to resolve the issues in dispute; or
if this cannot be accomplished. to define and narrow thc issues 10 be heard by the court, and to cnter into a temporary
order. All children nj!e livc or older may als!> bc present at the eonlcrenec. Failurc to appear at the conlerenee may
provide grounds for entry of a temporary or permanent order,
The court hereby directs the pnrtles to furnish uny und ull exlstlnll I'roteetlnn from Abuse orders.
Special Relief orders. nnd CUSlody orders to the conciliator 411 hours prior to scheduled henrlnJ:.
FOR TilE COllRT.
By: Isl
mhc
IlK/flleIUle M. Verl~s.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 inlomlUtion about acccssible lacililies nnd rcasonnble
accommodations available to disabled individuals having business belclre Ihc court. please contact our olliee.
All arrangements must be made alleasl 72 hours prior to any heuring or business helhre the court. You must
attend the scheduled conference or hearing,
YOU SIIOULDTAKE TillS PAPER TO YOUR ATroRNEY AT ONCE, IF YOU DO NOT
HAVE AN AnORNEY OR CANNOT AFFORD ONE. GO TO OR TELEI'II0NE TIlE OFFICE SET
FORTII BELOW TO FINO OUT WIIERE YOU CAN GET I.EGAI. liEU',
Cumberland Counly 1l:1r Association
32 South Ikdlhnl Street
Carlisle. Pennsylv,min 1711 13
Telellhone (717) 249-31(,(,
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LISA LORING.
I'luinliff
IN TilE COURT OF COMMON PLEAS
CUMBERl.AND COUNTY.I'ENNSYl.V ANlA
,j
v.
No. 95-4273
ANDREW REYES,
Defendllnt
: CIVIL ACTION-CUSTODY
ORI)ER OF COUln
AND NOW. this _ dllY of . 2004. upon eonsiderutionofthe lI11uehed
Petition For Modiliclltion of Custody Order. it is hereby directed thut the purties IInd their
rcspective counsel uppcur belore . the Custody Conlerenee Onicer on
ut o'c1oek _.111. utthe DOlllestie Relutions Olliee locutcd at \3
North Hunover Street, Curlisle. I'ennsylvllniu tor u eonlerenee. At such Conlerenee. un enort
will be Illude to resolve the issues in dispute; or if this cunnot be uecomplished. to deline und
narrow the issues to be heurd by the Court und to enter into u Temporary Order. All children IIge
live or older shull ulso be present ut the Conlerence. Fuilure to uppeur utthis Conlerenee muy
provide grounds lor entry or a temporary or pemlUnent Order.
BY OR FOR TIlE COURT
Dute or Order:
Conlerence Onicer
YOU HAVE TIlE RIGHT TO A LAWYER. WHO MAY AITEND TilE
CONFERENCE AND REPRESENT YOU. IF YOU DO NOT IIA VE A LAWYER OR
CANNOT AFFORD ONE. GO TO OR TELEPHONE TIlE OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU MAY GET LEGAL HELP.
CUM\JERLANI) COUNTY \JAR ASSOCIATION
2 LIIJERTY AVENUE
Cllrlisle,l'enns)'h'uniu 17013
(717) 249-3166
AMERICANS WITII DISAHlLlTIES ACT OF 1990
The Court of Co mlllon Pie us ofCulllberlund County is required by luw to comply with
the American with Disabilities Act of 1990. For inli.mnalion ubout ueeessible lileilities and
reasonable accommodations uvuiluble to disubled individuals Imving business beli.lre the court.
please eontuct our ollice. Allllrrungements must be Illude ut leust n hours prior to uny hearing
or business betore the court. YOUlllust ullend the scheduled eonlerence or heuring.
Bllrhllru Sumple-Sulli"lII. Esquire
Supreme Cuurlll323 17
54') Bridge Slreet
New CUlllherllllld. I'^ 170711
(717) 714.1445
LISA LORING,
PllIintilT
: IN TIlE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY.
: PENNSYLVANIA
v.
: No. 95.4273
ANDREW REYES.
Delcndllnt
: CIVIL ACTION-CUSTODY
PETITION FUI{ MODIFICATION OF CUSTODY UlmER
I. Petitioner is Lisa Loring. un individual residing lit 1707 Bridge Street. New Cumberland.
Cumberland County. Pennsylvania 17071.
2. Respondent is Andrew Reyes. an individual residing at 613-13 Bridge Street. New
Cumberland. Cumberland County. Pennsylvllnia 17070.
3. Petilioner seeks sole leglll and physical custody of the child with an order of supcrvised
visitation for Respondent of the following child:
NAME
AnDRESS
!!ill!
11/5/1993
Kenneth Andrew Reyes Loring
1707 Bridge Street
NeIV Cumberland. PA
Thc child is currcntly in thc primal)' custody uf Muthcr ut 17117 Uridgc Strcct. Ncw
Cumbcrland. Cumbcrlund Cuunty, Pcnnsylvania 17ll71.
Thc child wus born out of wcdlock.
During thc lust Iivc ycars, thc child has rcsidcd with thc following pcrsons and ut thc
following uddrcsscs:
I'ERSONS
AI)J)RESSES
nATES
Mothcr
17117 Bridgc Strcct
Ncw CUlllbcrlund
I 999-Prescnt
The Mother of thc child is Usu l.oring. currcntly residing ut 1707 Uridge Strect, New
Cumberlund. Cumbcrlund County. Pcnnsylvuuia. 17071.
The Futher of the child is Andrcw Rcycs. currcntly residing ut 613-B Bridge Street. New
Cumberland, Cumbcrlund County. Pcnnsylvania. 17070.
Thc parties wcre ncvcr ll1urricd.
4. The relationship of thc Pctitioncr to thc child is thm of Mothcr. Thc Petitioncr currently
rcsidcs with Ihc child and thc child's sibling. Christiun Loring.
5. The relationship of thc Rcspondcnttu thc child is tlmt of Futhcr. Thc Pctitioncr is not
ccrtain of Rcspondcnt's cUITCntliving arrangcmcnts.
:2
6. Petitioner und Respondent hud previousl)' purticiputed inu custody proceeding in this Coun.
A copy of the Custody Stipulution duted August K. 1995 und the Order udopting the
Stipulution duted August 21). 11)1)5. ure ulluehed hereto us Exhibit "A" und ineorporllted
herein by relerenee.
7. Petitioner hus no infonnution of u custody proceeding concerning the child pending in u
Court of this Conunonweulth.
8. Petitioner docs not know of u person not u puny to the proceedings who hus physicul custody
of the child or claims to have custody or visitation rights with respect to the child.
9. The best interest and permanent wellilre of the child will be served by gnmting Respondent
only supervised visitution with the child until verifiemion of his stubility und elllotionalund
psychological condition cun be verified. Although the lust Court Order wus entered in 1995.
Respondent has not followed slime. The last weekend visitmion period with the Respondenl
and thc child was approximutcly three years lIgo in September. 20ll I. Thereuller. the
Respondent usulllly only exercised contact with the child onu spomdie und infrequent basis
and then only for very short periods of time, These periods would usuully occur without
notice to the Petitioner lInd without reg;lrd tothe schedule in the existing Order. Petitioner
always ullelllpted to be Ilexible U111lullow Respondent this limited eontuetas he requested.
Recently. when an elllilreemel1l uetion Iilr support was entered. Respondent eontucted
Petitioner lInd wanted the supportlletion dropped. lie eUlne to the house und indicated thllt
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he would have no contact with the child ifshc droppcd the supportllnd lIrrcaruge. llowcver.
during this tcurful and highly cmotional confrontation. he lIctcd in un irrutionulmunncr. Ilc
rllged and scrcllllled. Ilc indicatcd dircctly to the child that hc hus hccnusing drugs and tlmt
hc drunk. This conlirmed u prohlcm which hmllongcd plagued thc Rcspondcntund which
cuuscd thc Pctitioncr to fcar (llr the salety of the child. Rcspondcnt hus also udvised
Pctitioncr of illcgulund improper activity relatcd to drug trunsuctions, which further cuusc
hcr lear lor thc child to hc in his custody. Rcspondcnt hus adviscd Pctitioncr hc is in dccp
dcpression. Pcnding vcrilicution ofthe status ofthe Rcspondcnt.Petitioncr rcquests that only
supervised visitation hc allowcd lor the Rcspondcnt, Thc child is learful ofthc Rcspondent
when he acts in such un irrutionalmunncr. Custody should hc superviscd until the Pctitioner
and the child arc comlllrtahle with huving contact with Respondent.
D'"'' !J/1.h-.2004
/
/
~m S,m,I.-S,m'M. '"",'re
, Attorncy lor Pctitioner
549 Bridge Strcet
New Cumherlund. P A 17070-1931
(717)774-1445
Supreme Court J.D. No. 32317
4
EXHIBIT "A"
LAW OI"FIC:ES
THIS IS A TRUE CORRECT COpy
..,... DnU."y.. OJ n.....
NEW CUMBERLANu. .....~NN5YLVANIA 17070.1931
PHONE (717)774.'448
FAlit (717)774.70811
,~
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liLISA LORING,
;; Plaintiff
i.
I'
II
,
i ANDREW REYES,
Ii Defendant
I
,I
.,
.'
,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - CUSTODY
;
I
,
, ,
(} oLtt-tL. ;) L't.-1~
NO. 95" /;2 7~
ORDER
O''J(..T;- ::l'l-tl....I/9rf..
AND NOW~lupon consideration of the Stipulation of the parties '
dated 8-~-c;S" , IT IS HEREBY ORDERED AND DECREED as
follows:
1. LISA LORING and ANDREW REYES shall have shared legal
custody of their son, KENNETH ANDREW REYES LORING, born
November 5, 1993;
2. LISA LORING shall have primary physical custody of said
child;
3. ANDREW REYES shall have periods of temporary physical
custody for the purposes of visitation as follows:
a. Alternating weekends from Friday at 6:00 P.M.
to Sunday at 6:00 P.M.
b. One evening per week from 5:00 P.M. to 9:00 P.M..
The exact day shall be arranged with two weeks
prior notice to the Mother.
c. Each parent shall have three (3) non-consecutive
weeks each year for vacation from Sunday to
Saturday. Each party shall give thirty (30) days
--w~,t-ten-nGt-i-ce-of-thei-r--chcrlce-of-we-eKs. ~ame
cannot be exercised during any holiday period.
d. Parties shall share the hOlidays of Easter, New
Years Day, Memorial Day, 4 th of July, Labor Day, ,
Thanksgiving and Christmas Day with the Father
having the periOd of 2:00 P.M. to 9:00 P.M. on each
of those days.
e. The child's birthday shall be shared equally as the
parties can schedule. The child shall be with
Mother on Mother's Day and Mother's birthday and be
with Father on Father's Day and Father's birthday.
f. During the first year the parties shall exchange
the child at a public place, such as the Kentucky
Fried Chicken restaurant on Lowther Street in
_..
::
5.
Lemoyne, or as. otherwise reasonable arranged.
Father and Mother may telephonically or through I
third parties make confirmation or arrangements for
the pick-up and delivery of the child.
The parties shall first offer each other the right to
care for the child in the event a temporary babysitter is
required during periods of custody exercised by the other
parent.
Neither parent shall take the child from the continental
United states without giving a 30 day written notice to
the other parent. Full disclosure of satisfactory travel
plans and itinerary must be provided to the other parent
at. that time.
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BY THE COURT:
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T!WE COP': F?,t;'/; P.~CORD
fn ~;~L~';!~, '" .~~.' ;'{:- - :.,...... ".','" my hand
c:ii th.: :::~: :>" ':'::.:: ~:"'.,,~ i~:.r:!:;, p~"
This ...;l.q~ Goy of .~.., .19,'1.,('
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-l)~ . Pro:aor.olary
:j
!iLISA LORING,
I i Plaintiff
II VS.
ilANDREW REYES,
Ii Defendant
!i
,j
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - CUSTODY
NO.
.~ J
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. by and
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CUSTODY STIPULATION. .~ '":i:: oW
THIS AGREEMENT" made thi, ~ d~;';;~:;"s
between LISA LORING, Cumberland County, Pennsylvania,
,I
.
(hereinafter referred to as "Mother") and ANDREW L. REYES,
Cumberland County, Pennsylvania, (hereinafter referred to as
"Father").
WITNESSETH
WHEREAS, Mother and Father are the parents of Kenneth Andrew
Reyes Loring, born November 5, 1993;
WHEREAS, Mother and Father desire to define their rights of
custody and visitation in regard to their son, Kenneth;
NOW THEREFORE, the parties, intending to be legally bound, do
., agree as follows:
1 . Mother and Father shall have shared legal custody of
their son, Kenneth Andrew Reyes Loring.
The parties
shall therefore consult on issues of major importance of
the child's life in order to determine actions in the
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child's best interest.
2.
Mother shall be the child's primary physical custodian.
Father shall have temporary physical custody of the child !
for the purposes of visitation as follows:
a.
Alternating weekends from Friday at 6:00 P.M. to
Sunday at 6:00 P.M.
b. One evening per week from 5:00 P.M. to 9:00 P.M.
The exact day shall be arranged with two weeks
prior notice to the Mother.
c. Each parent shall have three (3) non-consecutive
weeks each year for vacation from Sunday to
Saturday. Each party shall give thirty (30) days
written notice of their choice of weeks. Same
cannot be exercised during any holiday period.
d. Parties shall share the holidays of New Years Day,
Easter, Memorial Day, 4th of July, Labor Day,
Thanksgiving and Christmas Day with the Father
having the period of 2:00 P.M. to 9:00 P.M. on each
of those days.
e. The child's birthday shall be shared equally as the
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parties can schedule. The child
shall be with
Mother on Mother's Day and Mother's birthday and
Father on Father's Day and Father's birthday.
,
;
f.
During the first year the parties shall exchange
the child at a public place, such as the Kentucky
Fried Chicken restaurant on Lowther street in
Lemoyne, or as otherwise reasonable arranged. '
Father and Mother may telephonically or through
third parties make confirmation or arrangements for
the pick-up and delivery of the child.
3. The parties shall first offer each other the right to
care for the child in the event a temporary babysitter is
required during periods of custody exercised by the other
parent.
4. Neither parent shall take the child from the continental
United states without a 30 day written notice to the
other parent. Full disclosure of satisfactory travel
plans and itinerary must be provided to the other parent
at that time.
5. The parties hereby affirm their desire for this Agreement
to be entered as an Order of Court.
The parties
acknowledge that each has had the opportunity to consult
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with counsel concerning execution of this stipulation.
The parties do hereby stipulate to the incorporation of
its terms into such an Order.
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NtJIan", Silal
Barbala Surr4JlI;-;;,..,a.1. No'.arv Potlir.
Now CUmbel1a<<l8om (;ulrOl<1iI""" : . ,1\10
thf CofM'oSSIO" Exl>n* 0::\. & 'S:J5
yMltia I\sS<lOaIlOO at Nou"",
MOTHER:
sworn to an subs~~~ed
before 'e hi ~~ day
of , 1995
~")/
, A CciifNG--'j/l
~.
NOTARY
~7=-.L~'2r- .
AN'DREW {EYES
Sworn to and SUb~Jlibed
bef~~this day
of _, 1995
~~~
TAR'l PUBLIC
M:lIaIIsISlIlII
'Tl1:lmll!l M 0Bvfn. NolaIY P\.tiIO
Camp HI BclIll. Cun:la1aoid COlJ1IV
My~,e.;:ns~:22, 11l'JT
II....,.".... ...." .il!/1IZ.~Ol
FATHER:
Oarbam SUlllple-Sullivan. Esquire
Supreme Court #32317
549 Oridge Slreel
New Cumberland.I'A 170711
(717) 774.1445
LISA LORING.
: IN TIlE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY.
: PENNSYLVANIA
Plaintitr
v.
: No. 95-4273
ANDREW REYES.
Defendant
: CIVIL ACTION - IN CUSTODY
VERIFICATION
I, Lisn Loring. hereby certity that thc facts set forth in the forcgoing PETITION FOR
MODIFICATION OF CUSTODY ORDER are true and correct to thc best of my knowledge.
infommlion and belief. I understand that any false statements made herein are subject to penalties of
18 Pa. C.S.A. *4904 relating to unsworn falsification to authorities.
DATED: flt/
l '--Y ---2- .
LISA LORING~ )
.2004
Ilarbam Sumple-SullivulI. ESlluire
Supreme Court #32317
549 Ilridge Slreel
New Cumberlalld. I'A 17070
(717) 774-1445
LISA LORING,
Plaintill'
: IN TIlE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYL VANIA
v.
No. 95-4273
ANDREW REYES,
Dcfcndant
: CIVIL ACTION -IN CUSTODY
CERTIFICATE OF SERVICE
I, BARBARA SUMPLE-SULLIV AN, ESQUIRE. do hereby ccrtify that on this datc, I
served a truc and corrcct copy of thc I'ETITION FOR MODIFICATION OF CUSTODY
ORDER, in the ubove-captioncd mallcr uponthc following individual. by United Slatcs first-class
mail, postage prepaid, addressed as follows:
Mr. Andrew L. Reyes
613-B Bridge Slrect
New Cumberland. PA ]7070/
/
Barbara Sumplc-Sullivan. Esquirc
549 Bridgc Strcct
NcwCumbcrland. PA 17070-1931
(717) 774-]445
Suprcmc Court I.D. 32317
Allorney for Petitioncr
DATE,~.2004
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OCT 1 8 2004 y:
LISA LORING,
l'luintirr
: IN TilE COURT OF COMMON I'LEAS OF
; CUMIIEIILANI> COUNTY, I'ENNSYLV ANIA
: NO. 1995-4273 CIVil. TERM
V.
ANDREW REYES,
I>crcndunt
: CIVIL ACTION. LAW
: IN CUSTOI>Y
ORI>ER OF COURT
AND NOW. this 2.1" day of OrJo4A/ .2004. upon
considemtion of the attached Custody Conciliation Report, it is ordered and direcled as
follows:
I. Father's periods of custody pursuant to the prior Order of Court dOled
August 29. J 995 sholl be held in obeyance.
2. The Falher. Andrew Reyes sholl attend atleasl two counseling sessions
with Cosey Sheinvold.
3. This Order is entered pursuant to on agreement of the parties at 0 Cuslody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent. the terms oflhis Order sholl control. Either
party may schedule anolher conciliation conference within 90 days of this Order.
BY THE COURT,
J.
~Barbam Sumple-Sullivan. Esquire. Counse lor Mother
~ark Silliker. Esquire. CounselliJr Mother
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LISA LORING,
l'laintlff
: IN TilE COURT OF COMMON PLEAS OF
: ClIMUEI{LANI> COllNTY.I'ENNSYLV ANIA
V.
: 1995-4273 CIVIL TERM
ANllREW REYES.
Defendant
: CIVIL ACTION. LAW
: IN CUSTOI>Y
PRIOR JUDGE: Kevin A. Hess. J.
CUSTOI>Y CONCILIATION SUMMARY REPORT
IN ACCORI>ANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
I. The pertinent infornmtion concerning the Child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH CURRENTL Y IN CUSTODY OF
Kenneth Andrew Reyes Loring November 5, 1993
Mother
2. A Conciliation Conference was held in this matter on October 14.2004,
with the following individuals in attendance: The Mother. Lisa Loring. wilh her counsel,
Barbam Sumple-Sullivan. Esquire and the Father. Andrew Reyes, with his counsel. Mark
Silliker, Esquire.
3. The Honorable Kevin A. Hess entered an Order of Court dated August 29.
1995 by stipulalion of the parties. The Order provided lor shared legal and primary
physical custody in Mother. Father to have nlternating weekends. Father has only
sporadically exercised his alternating weekends and most recently he exhibited erratic
behavior at pickup.
4.
The parties agreed to the entry of nn Order in the fornl as attached.
10 - IS" -0 Y
Dale
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(Icq line M. Verney. Esquire
Custody Conciliator
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Ilurburu SUIl1JlI~.Sulli\'aJl, H''1uir~
SUJlrcJll~ Court #32317
549 Ilrid8~ Slr~~t
N~w Cumberland,l'A 171170
(717) 774.1445
LISA LORING,
1'laintiO'
IN TIlE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
v,
No, 95-4273
ANDREW REYES,
Defendant
CIVIL ACTION-CUSTODY
A FFIDA VIT OF SERVICE
I, Barbara Sumple-Sullivan, Esquire, do hereby certify that 1 served a copy of the Order
scheduling the Custody Conciliation for October 14,2004 at 8:30 a.lI1. in the above-
captioned matter by United States Mail, Return Receipt Requested, Certified No, 7003 0500
0001 65645529, on the above-named Defendant, Andrew Reyes, on October 8,2004 at
Defendant's last known address: 613.B Bridge Strcet. New Cumberland, PA 17070. The
original receipt and return receipt card arc attached hereto as Exhibit "A",
I hereby certify Ihatlhe facts sel forth above arc true and correct to the best of my
knowledge, information and belief. I understand Ihat any false stalements made herein arc subject
to penalties of 18 Pa. C.S.A. ~904 relating to unsworn falsifica~i.
.I
Dated: October!l. 2004
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L. Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, P A 17070-1931
(717).774-1445
Supreme Court 10 1132317
Attorney for PlaintiO'
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C'ERTIFIED MAIL.. RECEIPT
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Total Poet. & Feos
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RECEIVED APR 122005 ./
LISA LORING,
l'lalntirr
: IN TilE COURT OF COMMON I'LEAS OF
: CUMDERLANI) COUNTY, I'ENNSYLV ANIA
V.
: NO. 1995-4273 CIVIL TERM
ANDREW REYES,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
ORI)ER OF COURT
AND NOW, this 121h day of April, 2005, the parties have nol eonlaeled the
Coneilialor within 90 days from the dale of the prior Order. The Conciliator hereby
relinquishes jurisdiction in this mailer.
FOR THE COURT.
K'
line ~1. Verney, Esquire, Custod nciliator
rllED-O,:, i0::
OF TUr ''''0.' '1~,"'''I~t'1'(
II Ie rl., )1. ,~.. -t,....,
2005 ht>R 13 (;1\ 9: 23
CU',"" , ,'I i, IN1Y
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Borhoro Sumple.Sullivun, E.quire
Supreme Cuurt N32111
549 Bridlle Stn:et
New Cumherlund,l'A 11010
(111) 174.1445
RECEIVED
MAR ? ~ IUUb
BY:
\
.
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
LISA LORING,
v,
No. 95-4273
ANDREW REYES,
Defendant
: CIVIL ACTION-CllSTODY
ORDER ADOPTING STIPULATION OF PARTIES
AND NOW, 10 wil, lhis l1' day of ""I>.~"'"
. 2006, upon consideralion of the
allached Custody Stipulalion and on molion of Barbara Sumple-Sullivan, Esquire, counsel for
Plainliff, Lisa Loring, and Mark T, Silliker, Esquire, counsel for Defendant, Andrew Reyes, il is
hereby ordered, adjudged and decreed that the terms, conditions and provisions of the allached
Stipulation are adopted as an Order of Court as if sel forth herein at length,
BY THE COURT,
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OF T1 ir: F'r ""',')T/'H'f
200& liM~ 20 ;:i i 10: 08
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Uurhuru Surnplc.Sullivun. E'quirc
Supremc Court #32317
549 Ilridgc Sln'et
Ncll' Cwnhcrlund,l'A 1711711
(717) 774.1445
LISA LORING,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
Plainliff
v.
: No, 95-4273
ANDREW REYES,
: CIVIL ACTION-CUSTODY
Defendant
CUSTODY STIPULATION
THISAGllEEMENTismadethis,W day of nll It/L
. 2006, by and belween Lisa
Loring, (hereinafter referred to as "Mother") an adull individual residing at 1707 Bridge Streel, New
Cumberland, Cumberland County, Pennsylvania, and Andrew Reyes, (hereinafter referred to as
"Father") an adull individual residing at P.O. Box 17633. Tamoa. Florida 33682
WIT N E SSE T H:
WHEREAS, Lisa Loring (hereinafter "Mother") and Andrew Reyes (hereinafter
"Father") are the natural parents of Kennelh Andrew Reyes Loring, born November 5.
1993;
WHEREAS, in order 10 avoid continuing issues, lhe parties desire to enter inlo an
Agreement concerning lhe cuslody oflhis child;
NOW THEREFORE, the parties, inlcnding 10 be Icgally bound do agrce as
follows:
1. Mother shall have sole legal and sole physical custody of the child, Kenneth
Andrew Reyes Loring.
2. Father shall have no conlacl wilh lhe child excepl as inilialed and
authorized by MOlher. al her sole discrelion.
IN WITNESS WHEREOF, lhe parties hereto acknowledge that they are enlering into
this Agreement with the full knowledge thaI this Agreement shall be enlered as a court order
with the same force and effecl as if a full hearing on lhis matter has been held.
SIGNED, SEALED AND DELIVERED
IN THE PRESENCE OF:
W1TN2t W L
B...."-S~.D1".. "q.;~
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Lisa Loring -'
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