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Home My WebLink About96-00913 ~ i !\ \ f. ~ J r.f) - a- n " ~ 1iI1 !ill ,) ,/ ^" ~\ ~i ~i :ill ~I ~, ~I ~I .. :1 ~I , i ~I : I ~I ~ .', ~ ~ ~ ,;, ., ~ ~ ~ :;, ., ~ ~ ',' :il ~ ~ ~ .;.;. <.; :.;. -:.:-.:.;. :. -:.;. -:.~. -:.;. .;+;.:.:. -:+;. -:+;. .:.:. .;+:. ';4 -:.-:. .:.:- .:+:. -:.;. .:+;. .:.:. .:.:. .:.~. -:<<. <..:. -:+:. .:+:- ':.:. .:.;. -:.: ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY t:I' STATE OF ~~~ :ill ~I '/ ~i ~ ~ , -:.:. '4r.' .:.:- .~;. ,~;. .:+:. PENNA. JOHN D. LILLY, Plaintiff ;\; tl,9l)~cHL . .' u'uUu, II) 96 Vel':HI~ LISA M. LILLY, Defendant AND NOW. DECREE IN I V 0 Refit ~'.l fP~ , , , , ,(, ~,. 199(5"". it is ordered and decreed that" ,J9", ,D~, ,LILLy.""""."""""".."",.., plaintiff, and. , , , , , , , , , , ,L,I.~..., M." ,yn.,~'(, , , , , , , , . , , , , ' , , , ' , , , , , , . . , , " defendant, are divorced frorn the bonds of matrimony. The court retoins jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; ".,., ,NOJJ~""".,."".",."..,.",....." AlIe. v' f' ,/ J //. ,<-' -././ --LJ . . .,ti."IU Jf.,.( "~/. ~M~lfI?lIi~*/ . -I (/ ,*J:j"/l.' ,;< XL...... f /~7!- I I '~rothotl0Iary :~ .~..~..~~..~.~..~..~.*.,~..~..~..~.*.*..~.~..~.~.~,~,.~.~.~. ~ :;, ":0 ~ :~ ~ ~ ~ ~ :~ ., ~ ~ :!l ~ I~ I... . .~ /.:, I~ i',' I~ I~ I~ ~ ~ ~ ~ ~ ~ '. ~~ l~ (." i!il / : I~ )'. I' I~ (" I~ ',~ I' ~~ ,~ ~ ~ , i.', I~ .-"" '/.;I!J4t. ,;:.:1 ,;,-1"Jf. /11,::11/ -d, :v-/~43a~'" .j..;xl ,~~ '7.J.h.' ,/IK..R/ ~, ?~ JOHN D. LILLY, I N THE roJRT OF C(MoI('tI PLEIIS OF CU1BE:HLAND, COJNTY. PENNSYLVANIA Plaintiff NO.96-913 1996 CIVIL VB. LISA M. LILLY , Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under Section 3301 (c) J3ei-td111~ of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the canplaint: March 4, 1996 - Complaint Sent Certified and Restricted to Defendant and was received bv Defendant on March 5, 1996. 3. Canplete either Paragraph A. or B. A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the plaintiff Auqust 23, 1996 by the defendant Auqust 10. 1996 B. (1) Date of execution of the plaintiff's affidavit required by Section 3301 ld) of the Divorce Code: NA (2) Date of service of the plaintiff's affidavit upon the defendant: NA 4. Related claims ~nding: None 5. Indicate date and manner of service of tl~ notice of intention to file praeci~ to transmit record. and attach a copy of said notice under Section 3301 (d)(l)(i) of the Divorce Code Date: August 26, 1996 -4Fm,~f, ~;:3 At orney for Plaintiff/Dcfe..Jdlll .....10 (") ...~., (" c; 0' .... aiL ~.. ::J .t.:. -;-, If:] ;;":f-u ~.> "1 ~:, (.n. 0) .)(,1 .~ l:~() r~ '. ~:: .-" 'I ~):' (". ,~. ('i ,. :...) " - ~n , l,,) .~.J 'n :;~! " '/' ~ -{ .~ , f " ,.... : ~ " } j .~ " J V -+ .... " ' , -"- eL- l" " V , r,_ n. ., (~ c'") (j () (} G \.(l l{) .J l}': <.:.. . f.j III '" ' , (J l() ()? r'x - p: rc ,,, ~, .' ,', ,-.... .t" t/'i v 00 1 -- \,.'"1 c - 04- L' , ~ l.,; , rl1 ,..: L, ~ tt !'. , I ~ cL ..J u ..: .... ?i ~~ i~~ ~~~ ~~~ ~~-l Z~~ -Uu .... .... .... 'i:: .... . as ~~ .... -l > .i ~~ .... -l OJ U ... o > .... Q z ii :J ::: ~ !lID ~ce ~~ ;:) ~ ID I td .. OJ .. ~ Il - ... Iii i ~ a . ... ~ ~ .. v > .. OJ .. II Z OJ x Z Z ~ ~ 0 ~ .; f Z Il '1 ,... ~ w .. .. ~ i .. . :I: c: - . Q i ;}i .... -l ... c: '... oj .... ! ~ oJ..>lfi. ~ tJ;d. ~ /'J/;i, a7! ~~l,. ~'iiJ8'.?~ ~~ Ma~ ~ ~. a.,;J(,9& ~ fJkd ~ ~ ~ II ~ -. "', . f.,.. > . J . , .- . -j ., I I l , I I . JUtlll. LILl.Y, Phinti ff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA VI, NO. ql..v - <-in CIVIL TERM LISA M. LILI''fa.f.ndant CIVIL ACTION - LAW CUSTODY/VISITATION ORDER OF COURT AND NOW, this 1J1"day of he Dr....... 'I, 1996, upon consideration of the ettaclled Complaint', it is lIereby di ected tllat the parties and their respective counsel eppear bef re -~ . the conciliator, at - ~ Ion the, '~y of fV'vlu~ . 1996. .m., for aPe-Hearing Custody Conference. At such conterence, an ellort will be made to resolve tile issues in dispute; or if this cannot be accomplislled, 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 tile conference. Failure to appear at the conference may provide grounds lor entry of a temporary or permanent order. FOR THE COURT, By: Custody Conciliator The Court of Common pleas of Cumberland County is required by law to comply witll the Americans with Disabilities Act of 1990. For information about acce.sible lacilities 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. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LANYER OR CABNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO riND OUT WHERE YOU CAN GET LEGAL HELP. '''t. OPPICE OF THE COURT ADMINISTRATOR CUMBERLAND COUNTY COURT HOUSE One Courthouse Square - 4th PL Carlisle. PA 17013 (717) 240-6200 k'.....'.",.. ,....--.(".- '1,', . ....\. .Ii ('" rrr" ^..~ 0" ~, \' ;'., .:: iJ ~~: ',-/9 ;"1.. Ct...);;,> r.'u,-., . "I , ',['.L\ 1\ JOHN D. LILLY, IN THE COURT OF COMMON PLEAS CUMBERLAND COfJN'l'Y, PENNSYLVANIA PI alnt i ff vs. NO. ql.l1 q 13 Ci~i1 Term LISA H. L[L[,Y, CIVIL ACT[ON - LAW [N D[VORCE / CUSTODY Defendant COUNT I I COMPLA[NT UNDER SECTION .310lfCI OF TUE D[VORCE CQDE 1. The Plaintiff is ,John D. Lilly, an adult indi~idual, sui juris, who currently resides at 100 Eltcker Road. Apt. B, Carlisle, C'JmberLand County, Pennsyl~ania 17013, 2. The Defendant is Lisa H. Lilly, an adult individual, sui juris, who currently resides at 68 Rolo Court, Hechanicsburq, Cumberland County, Pennsyl~ania 17055. ), Plaintiff has been a bona fide resident of the Commonwealth of Pennsyl~ania for at least six (6) months immediately prior to the filinq ot this Complaint. 4. The Plaintiff and Defendant were married on January 6, 1990, in Enola, East Pennsboro Township, Cumberland County, Pennsyl~ania. 5, The Plaintiff and Defendant were separated in October 1995. h, There has been no prior action far di~orce or annulment of the marriaqe t.rween the partle~ hstctu In Ihis or any other jurisdiction. ~ 1 ~ 7. Plaintiff avers that there is one (1) child of the parties under elqhteen (18), namely: Ashley Marie Lilly, age five (5), born June 20, 1990. 8. The Plaintiff and Defendant are both citizens of the United states of America. 9. The Defendant is not a member on active duty of the Armed Forces of the Unlted states of America nor any of its allies. COUNT II ~OMPL~I~T,_~~DER SECTION 3301Ia)16) Q~HE DIVORCE CQQg 10. The Plaintiff avers that the grounds upon which this action is based is that the marriage is irretrievably broken. ll. Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling prior to a Divorce Decree being handed down. 12. All of the averments in Paragraphs 1 through 11 are incorporated hereln as though each was set forlh under Count II as in Count I. 11, tn th~ alternative, Plaintiff avers that the Defendant hath offered "l~h indignitie~ to the persou at the Plaintiff, the innocent and injured .pa""" '0 as to render his condition Intolerable and life burdensome. - 2 - ~.Q.v.!tl'_, LU GLAIM FOR ~QY!TABLE DISTgJ]QIIO~ OF HARII!kJP~&IX YftDER SEC1l0H 40l OF THE Q1~ORCE CQDg r, i' 14. All of the averments in Paragraphs 1 through 13 are Incorporated herein by reference thereto. WHEREFORE, Plaintiff requests the Court to enter a Decree In Divorce: A. Dissolving the marriage between the Plaintiff and Defendant; B. Equitably distributing all marital property owned by the parties; and C. For such further relief as the Court may determine equitable and . Just. COUNT IV REOlJEST FOR eM Il,D CUSTODY 15. All of the averments in Paragraphs 1 through 14 are incorporated herein by reference thereto. 16. Plaintiff is John D. Lilly, an adult individual, residing at 100 Zlicker Road. Apt. B, Carlisle. cumberland County, Pennsylvania 17013. 17. Defendant is Lisa H. Lilly, an adult individual, residing at 68 RaiD Court. Hechanlcsburq, Cumherland County, Pennsylvania 17055. 18. The subject minor child was born of the plaintiff's and Defendant's 1I,.unage .and lB: A3HI.EY HAR!E LILt,Y, 391' five (5), born on June 20, 1990. - 3 - i" .0. Plaintiff does not know of a person not a party to the proceeding who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 27. Each parent whose parental rights to the minor child have not been termInated. and the person who has physical custody of the minor chiLd. have been named as a party to this action. 28. The best interest and permanent welfare of said minor child will be served by granting the relief requested because: a. Plaintiff/natural father is well able to adequately provide for the continuing health. educational needs and general welfare of the said minor chUd; b. Plaintiff/natural father is well able to adequately provide for said minor child with a proper anct wholesome environment. physically, emotionally. psychologically and socially within which to live; and, c. Plaintiff/naturaL father has been a primary caretaker of the minor child since her birth. d, [t is in the best interest of the child generally that shared legal and primary physical custody be granted to the chiLd's natural father, John p, Lilly, Plaintiff herein. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter a Decree [n Divorce: A. DissolVing the marrl'qp betw~en the Plaintiff and Defendant; - 5 - . B. Grant Plaintiff shared legal and primary physical custody of 1 1., ~ subject minor child; . C. Equitably distributing all marital property owned by the parties; j .;;1 ; . I and, D. For such further relief as the Court may determine equitable and just. Respectfully submitted, BATURIN & BATURIN . By:'j!)r:rn/CQ.. P j~a !J..v~ Monica E. Baturin, Esquire (Attorney 1.0. No. 73356) (Attorney for the Plaintiff) 717 North Second Street Harrisburg, PA 17~02 (717) 234-2427 Date: February 20,l996 . ',J- i .', - 6 - .-.---.... lq t'.' , f' , , l" : ~. :1;',; .' \~) ~; .',1 ') 'J ~ ~ ~~ " z ti ~ ... OJ .. ... ~ ... I II: II: - ~~ ~ :J ~ ~ * '"' .~ ~ !( c z OJ ~ . .~ .fl U III Z ~ ... III ~ ~ - 0 ;J .... 2l t: dS U .. C ~~ ~ o .. UI Z UI Z OJ >. Z . . I '8 ~ ~ _ J: .. Z ~ ~ II: l- lL 0 U . 8'"' :J II: .; J: ~ '.. 8 2l ~ 0 IL .c: Z II: ~ ..:l ~ :;) ~l'~ III !:: "' .. . . ... UI l- e X :s ~ ii ~ ~ II: :..... ~ ~ uc J: ",_., -1oJ'. . ....."._. ........ , ';.~"'" " '."~ ". JaM D. LILLY, I IN 'ftIE CWRT OF CCHoDI PlEA'> Plaintiff I CtJoIBERLAN) COONl'Y, PENtliYLVANIA I ve. I NJ. 96-913 CIVIL 'reRM I LISA M. LILLY, I CIVIL ACTION - L/tW Deferdant I IN DlVORCE/CUSTIDY CERTIFICA'm OF SERVICE I, Monica E. Baturin, Esquire, of the law firm of Baturin , Baturin, attorneys for the Plaintiff in the above-captioned I18tter;. do hereby certify that on March 4, 1996, 1 deposited in the United States Mail, at the United States Post Office, Feieral Square Station, Harrisburg, Pennsylvania, an ar- ticle of Certified Mail, Return Receipt Requested, postage pre-paid, marked "Restricted Delivery," a certified copy of the COll>laint in Divorce, Order of court requirinq attendance at Conciliation Conference and Notice to De- fend and Claim Rights attached therto, bearinq article no. Z 187 536 096, addressed to: Lisa M. Lilly, 68 Rolo Court, Mechanicsburg, PA 17055. The said article of Certified Mail, as shown by tre Postal Return Receipt Card ~ received by the Defendant herein on March 5, 1996, and accordinq to sane, was signed by her, to wit: Lisa M. Lilly, which card is attached here- to ard marked as Exhibit "A," along with the deposit slip dated March 4, 1996, for said Article of Certified Mail aforemmtioned. BAWRIN , BAWRIN '1kn ~ . By: 'i Wi €. wi\:> ~i~E. Baturn,~ire Attorney 1.0. No. 73356 717 North Second Street Harrisburg. PA 17102 (717) 234-2427 (Attorney for Plaintiff) Dated : March 6, 1996 -,#0 Z U"I 536 096 ~ Receipt for ..II"' Certified Mail _ No In8ur,JIu;.e CU....t4UU ProvIded A:1."~,=" 00 not Ultt fo' IntUfOdllOnal M..t ISee Rlt\llJnttl I t1sa M Lilly r I ~B' Rolo Court I I tn ... 1"1 ',', .,-t -I.' Mechanicsbur PA . 17055 .78 1.10 f',mlloQr ~"'I"...:t '... '0'''. Ii' ~ ...., , ""',1<,..""':.""'''''"" ~.75 1.l0 ,l"lo"" "'-d"l" ,'.....'.1 5.7) UI:.I.I V t.n I I.. .~~1IfdQJaallilltionll~ eCornc*le'" 3....1nd 4tl. I ...... JOAI""" If1d ........ on Ihe rwerM of \NI; tDrm 10 IhIII we '*' tMurn lNI -..- a=. hllofm tD" fronI oIlN~. Of on INIledI".,.ce '** nut . .WrtIe'~ Ra>>pf ~.oo IN ~ bItow the tttidlt rutMr. . .The Return R..pt ... IhOw 10 ..nom IN II1idtI .... ~ 1nd....!Me .- I At1IcI. Addr_ 10: LISA M LIU,y 68 ROLO CO JRT MECHANICSBURG PA 17055 111Io ........... .. -.g -- (lor.. _1M): 1,~'Addr_ ~ 2 t......, J ConIUt poIlmlI.tar lor 1M, J 4e, At1IcI. Numbor Z 187 516 096 "r 41), Service Type ~ _ . a RaQillerlld ~ o Expruo Mail 0 - J a Rolum RocoipI lor -- 0 COO II 70ateoln_ 1!t i J 8, _.....'. __ (CIttIy' f IIttd IN .. paid) ~ II' X ':1 '. PS Form 3811. o-...iIlef 11184 elum t Exhibit . A" " , 8 ,0 <;j1 0'" !: .,.,. -. ~,. :,: :Il ..', ;';i -;\l..c,;. if; .:' .'~ 'nCJ ~: .:0 JC ',) . ~~' '."fJ ,l~ ':ii'a ~- .. S;'.,. :"".' , '), ~; ~ .. ~., ~'J _I -< <7> ..... ~. . - ! f ~ ~ I I r I I I '! l ~ I ;\ I 'I ',! 8 \Q If' O. "I -rl ~i: ra '. r- ~.!l~ !Pt. ;; . ,..- t;,r ".J .,~ t,1~, "" , .-', ~~: ;:tI Jl] ;'::' .., ~( - '.10 S;" ::-.) "'iT' I..) l.. -j ?~: :.'1 ~. "',~ (1) ~ , I I I' i I I, \ ' / ~' /' ~ 4"t') 9. <n :Ii. .... I rj'" .- fl"!! " ['.: .':i '0 r.' :~ ti' c:.. ~. '-'6 ~:, :iJ~ '. ..j....,- o. S:- ...:~ I tl ' , '::.' :... ~ :..1 ,,, - cr, -. ,luKN D. LILLY, IN TKE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA plaintiff NO. 96-913 CIVIL TERM Vs. LiSA M. LILLY, Dllhndant CIVIL ACTION - LAN IN DIVORCE NAIVER or NOTICE OF INTENTION ~O REOUES~ ENTRY or A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of 4 FinaL Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees and 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 TO THE PENALTIES OF 18 PA. C,S. SECTION 4904 TO UNSWORN FALSIFICATION TO AUTHORITIES. ~ 1\ \ ,,,\ 1"ul DATE: ,jl"',,,..1 !,.;",\]., l f ,'\ C J /,;i __,' J i\'6:'~" ,/{I ,1. ,..1,,(; Lisa M. Lilly (SEAL) I' -"" , .. Q I.l) 0 ~.:f '" -,, ':'i... ~ o;J [B' ~ ",71 1 , G-J '~ ;;:..~ . j"'.J "_Ie tf? ~~ ru ,.> ~i " . '" '0 -:::) c::; :~.: .- '.-!i, ~.. =t.' ('jfl\ . (.- .,1 :,': "... .-. '," ~ .< . '" t i. i " i, I, ii L r ~ APH 111995c:lhL.. vs. ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOHN D. LILLY, Plaintiff LISA M. LILLY, Defsndant CIVIL ACTION - LAW NO. 96-913 CIVIL TERM DIVORCE/CUSTODY ORDER AND NOW, this -11 ~ day of ~. 1996, upon receipt of the Conciliator's Rllport, it appearing that the parties have reached an agresment as to all issues and that the agreement was dictated in their presence and approved by them. it is hereby ordered and directed as follows: 1. The parties will share legal custody of their minor child, Ashlsy Marie Lilly, d.o.b. 21 June 1990. 2. Father shall enjoy periods of partial custody and visitation with the minor child as follows: A. During the school year, every week from Friday at 3:00 p.m. until Sunday at 2:00 p.m. The parties agree that this time with the child will not include overnights until June of 1996. B. If Mother desires to have a weekend with the child. then she is entitled to a weekend provided that she gives Father live (5) days advance notice. -,. i: , ,- , i ~: !"",') . .J 11..\'",'\ .,... . "'ii."..',' .\ I l I I I I t f\ :' j' i' r ; , \i. \ I.' .. .. C. During the summer months, Father will have the child on alternating weekends from Friday at 3:00 p.m. until Sunday at 2:00 p.m. In addition, Father will have the child on Monday, Tuesday, Wednesday, and Thursday while Mother is at work from 9:00 a.m. until 2:30 p.m. 3. Father shall have one uninterrupted week of custody with the minor child in June over his vacation, and also in August. He will provide Mother with these weeks thirty (30) days in advance. 4. Both parties are entitled to have access with the child on the child's birthday, 21 June. 5. Father shall have the child on Father's Day, and Mother shall have the child on Mother's Day. These periods of visitation shall be from 9:00 a.m. until 6:00 p.m. 6. The parties agree to !Ilternate the major holidays, said major holidays to include Easter, Memorial Day, Fourth of July, labor Day, and Thanksgiving. This alternating schedule will commence with Father having Easter in 1996, and the schedule will alternate thersafter. 7. The Christmas holiday will be broken into two segments. Segment A will be from 12:00 noon on 24 December until 12:00 noon on 25 December. Segment B will be from 12:00 noon on 25 . Decsmber until 12:00 noon on 26 December. Father will have Segment A in 1996 and all even-numbered years thereafter. Mother will have Segment A in 1997 and all odd-numbered years thereaftsr. 8. The parties agree that neithsr of them shall smoke, drink, or swear in the presence of ths child, and further agree that they will not make any disparaging remarks about each other in front of the child. 9. Such other times as the parties may agree upon. BY THE COURT, tiJ~ Monica E. Baturin, Esquire Attorney for Plaintiff _ ~~~~/I~/f" ,. ,.,h. f'. Mrs. Lisa M. Lilly, pro se mlb o J. ,..~. . ~ "! '~oL." \J L'.li, I? L .4JlvTrfr In the Court or Common Pleas or Cumberlund Coonly, Pennsylvania va. No. q (. -'1\") Civil. 19 ~[;, L: s a Jl'1 L I' \)t}ENDANt ~ro \~U(\o\ Mu ; I PLe .),e. .,;',tl,.,.c.k,..; Coc,J '"3 _t\..-f ,~ co"~..>',,,(J ;" 11~;"tH +l <.' d; vGr<.(' C xl e , 1Q-=thc L:",+- ,,"~....r To Gee r~<: E, j,^,\~c. Ho~tu- 5cpf.13 ,ie Prulhollul:Iry 19 qL> (PbL Jl";37,5J) j of' ." '.TV.' .. f~ :.:e.. ~ r .. o.! I , . 'I I' I . I .' ... '.. " } . .: , , ~l , Nil. Tenn. 19 _ .S. PRAECIPE Filel! 19_ . Ally. p , '-) ') I : , . .1 ( "l . , " -q ,) ~[- , , 'J - .' c, h I.'; "~I . ~ 'J '.' ~, , J ?") >>~,. )\'1\ .- , [::' ~.~ ~ , :",.1 ~,;':. ? ,- .~ ~ ~ "'. . , ,,' , I.' ',." ...fA !~ ., I, I: I: ! I , Ii, . . JAMES M. BACH ATTORNEY AND COUNSELOR AT LAW 352 BOUTH SPORTING HILL ROAD ~.NlC8BURO, PENNA 17Oll6 (717) 737.2033 fiI AUG 2 8 1997 JOHN D. LILLY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF vs. No. 96-913 CIVIL 'rERM LISA M. LILLY DEFENDANT CUSTODY ORDER OF COURT AND NON, upon consideration of the attached COMPLAINT, it is hereby directed that the parties and their respective Counsel appear before \\.CMe\ L. (~rlf"f' r',,\, , the Conciliator, at ~;:) ::::'. , 'I,\'h ,'-,\-.. Cnr\\F 1+,\ \, ~:>A on the \ Co day of eX '("",he' r . 199", at \0' 00 9/p.m., 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 aged five or oldor shall also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent Order. I i I I FOR THE COURT: j)J' -;l. tin - BY. lC't\f\ U l.2 ,-.../ .I)e ~~ CUSTODY CONCILI RJ( \\:;,. ') 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 THIS OFFICE SET FORTH BELOW TO FIND OUT ~lHERE YOU CAN GET LEGAL HELP: OFFICE OF THE COURT ADMINISTRATOR CUMBERLAND COUNTY COURT HOUSE 4th FLOOR ONE, COURT HOUSE SQUARE CARLISLE, PA 17013 717-240-6200 ...11 V8. IIN THE COURT OP COMMON PLEAS OP ICUMBERLAND COUNTY, PENNSYLVANIA I ICIVIL ACTION - LAW INO. 96.913 CIVIL TERM I I CUSTODY JOHN D. LILLY, PLAINTIPP LISA M. LILLY, DEPENDANT COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, John D. Lilly, by his Attorney, JAMES M. BACH, and respectfully represents as follows: 1. The Plaintiff is John D. Lilly, residing at 24 Mallard Court, Mechanicsburg, Pennsylvania 17055. 2. The Defendant is Lisa M. Lilly, residing at 40 Pisgah Rest, Shermansdale, Pennsylvania 17090. 3. Plaintiff seeks custody of the following child: Ashley M. Lilly. 4. The child is presently in the custody of Lisa M. Lilly, who lives at 40 Pisgah Rest, Shermansdale, Pennsylvania 17090. 5. The natural Mother of the children is Lisa M. Lilly. 6. The natural Father of the children is John D. Lilly. 7. The relationship of Plaintiff to the children is that of Father. 8. The relationship of Defendant to the children is that of Mother. 9. The Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the children in this, or in any other Court. 10. Plaintiff has no information of a custody proceeding concerning the custody of said children pending in a Court of this Comlllonwealth, or in any other jurisdiction. 11. Plaintiff does not know of a person, not a party to the proceedings, who has physical custody of the children, or claims to have custody or visitation rights with respect to the children. 12. The best interest and permanent welfare of the children will be served by granting the relief requested, because the Plaintiff can provide a stable and wholesome home environment for the children. 13. E~ch parent whose parental rights of the children have not been terminated, and the person who has physical custody of the children, have been named as parties to the action. t i i I J I , t I I. e l- I ("') ,j) 0 ~; ...J ., "" .., ~lr,; ~._. :~l :0 , (T ii ' '(j .-' ~...~ '~.:I ", "jln .' I, ,(J .>; ....j . .'~) -, I, I::"'.. "" .:-;.] ,'> ", ',.. :~~ ~-': ...... ,(, d ;'.) :.~,t1 ,. ~~; :-:t '1- :J. C" '::1 Ul -- .~ \\ l> i ! I ii' I f I; I . "i' !', f I , ,. , 'I: "," ,j I ' JOHN D. LILLY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 96-913 CIVIL TERM LISA M. LILLY, Defendant CIVIL ACTION - LAW DIVORCE/CUSTODY ORDER AND NOW, this ~ day of ojo ~ cJ' , 1997, upon receipt of the Conciliator's Report, it appearing that the parties have agreed to the terms and provisions of this Order which was dictated in their presence and approved by them and their counsel. it is hereby ordered and directed as follows: 1. All prior Orders entered in this case are vacated. 2. The parties shall share legal custody of their minor child, Ashley Marie Lilly, d.o.b. June 21. 1990. 3. Mother shall have primary physical custody of the minor child subject to periods of pal tial custody and visitation with Father as follows: A. During the school year, every weekend from Friday at 3:00 p.m. until Sunday at 2:00 p.m. r~ 1\ \I a ,~ ~ ' a' l; t,l. n:.( . B. If Mother desires to have a weekend with the child, then she is entitled to a weekend provided that shs gives Father five \5) days advance notice. ----- L; .. " I d I ! , i I i I t I ! t I l I I t - C. During the summer months, Father shall be entitled to a total of six (61 weeks with the child to occur on en alternating week basis which shall commence the fJrst full week following ths child's release from school, and shall not include the week prior to the child's return to school. In addition, Father shall have the child on Monday, Tuesday, Wednesday, and Thursday during the weeks when Mother has , custody of the child while Mother is at work from 9:00 a.m. until she is released from work. Mother shall provide Father, as soon as practical, the time when she intends to pick up the child ofter work. 4. Both parties are entitled to access with the child on the J f. r , i1 f i' ~ . i' " " child's birthday, June 21st. 5. Father shall have the child on Father's Day and Mother shall have the child on Mother's Day. These periods of partial custody and f~, . visitation shall occur from 9:00 a.m. until 6:00 p.m. \ , . . 6. The parties agree to alternate the major holidays, said major holidays to include Thanksgiving, Easter, Memorial Day, Fourth of " r July, and Labor Day. This alternating schedule will begin with Mother , r i ' 'I r. I having Thanksgiving in 1997. { ~ ., ....... 7. The Christmas holiday shall be broken into two segments. Segment A shall be from 12:00 noon on Christmas Eve until 12:00 noon on Christmas Day; Segment B shall be from 12:00 noon on Christmas Day until 12:00 noon on December 26th. Mother shall have Segment A in 1997 and all odd-numbered years thereafter and Segment B in 199B and all even-numbered years thsreafter. Father shall have Ssgment A in 1998 and all even-numbered years thsrsafter and Segment B in 1997 and all odd-numbered years thersafter. 8. The parties agree that neither of them shall smoke, drink, or swear in the presence of the child, and further agree that they will not make any disparaging remarks about each other in front of the child. 9. Such other times as the parties may agree. BY THE COURT, III James M. Bach, Esquire Coy A. Starr, Esquire - J ESLEY OL IO/:17/Qlf, .A.~. ~~c..l mlb vs. ) ) ) ) ) ) ) I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA JOHN D. LILLY, Plaintiff NO. 96-913 CIVIL TERM LISA M. LILLY, Defendant CIVIL ACTION - LAW DIVORCE/CUSTODY JUDGE PREVIOUSLY ASSIGNED: The Honorable J. Wesley Olsr, Jr. CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-S(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the childlren} who is(are) the subject of this litigation is as follows: NAME BIRTHDATE CURRENTLY IN CUSTODY OF Ashley Marie Lilly June 21,1990 Defendant 2. A Conciliation Conference was held on October 16, 1997, and the following individuals were present: the Plaitltiff and his attorney, James M. Bach, Esquire; the Defendant appeared witI' her attorney, Coy A. Starr, Esquire. 3. Items resolved by agreement: See attached Order. 4. Issues yet to be resolved: See attached Order. 5. The Plaintiff's position on custody is as follows: See attached Order.