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2. The Father shall have primary physical custody of the
Children.
3. The Mother shall have temporary physical cuetodY of the
Children as follows:
A. On alternate weekends from Friday evening until
Saturday evening at times mutually agreed upon by the
parties;
B. On one evening per week on the day and at times
mutually agreed upon by the parties.
C. At such other times as are mutually agreed upon by
the parties, provided a minimum of 24 hours notice is given
to the Father by the Mother.
4. The Mother shall have unlimited telephone contact with
the Children, provided that such telephone contact occurs between
the hours of 9:00 a.m. and 9:00 p.m.
5. The Mother shall provide transportation for all periods
of temporary custody.
6. The parties agree that the Court of Common Pl~as of
Cumberland County, Pennsylvania, shall retain jurisdiction of
this matt.r.
7. The parties agree that this Stipulation and Agreement
may be entered as an Order of Court by the Court of Common Pleas
of Cumberland County, Pennsylvania.
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CLINTON S. ~INER,
Plaintiff
.
.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
q{,- /N' ~
NO. ~ . J CIVIL TERM
v.
MICHELLE L. KINER,
Defendant
IN DIVORCE AND CUSTODY
_OTIC. TO D...XO AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against
the clai.. .et forth in the following pages, you must take prompt
action. You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be
entered against you by the court. A judgment may also be entered
aqainst you tor any other claim or relief requested in these
papers by the plaintiff. You may lose money or property or other
rights important to you, including custody or visitation of your
children.
When the ground for the divorce is indignities or
irretrievable breakdown of the marriage, you may request marriage
counselling. A list of marriage counselors is available in the
Office of the Prothonotary at Cumberland County Courthouse,
Carlisle, Pennsylvania.
IF YOU 00 NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE
OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO
CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.
IF YOU 00 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.
Court Administrator
Fourth Floor
Cumberland County Courthouse
CarliSle, PA 17013
(717) 240-6200
CLINTON S. KINER,
Plaintiff
IN THE COURT or COMMON PLEAS or
CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO.~-
CIVIL TERM
MICHELLE L. KINER,
Defendant
IN DIVORCE AND CUSTODY
COMJLAI~ UWD" ..OTIO. 3301(0) O~ 3301(4)
O. ~. DIVO.C. COD.
COUNT I
1. The Plaintiff is Clinton S. Kiner, who currently reside.
at 513 Meals Road, Gardners, Cumberland County, Pennsylvania,
since February, 1991.
2. The Defendant is Michelle L. ~iner, who currently
reside. at 499 West Olde York Road, Carlisle, Cumberland county,
Pennsylvania, since December 16, 1995.
3. Plaintiff and Defendant have been bona fide residents in
the Commonwealth for at least six months immediately previous to
the filing of this Complaint.
4. The Plaintiff and Defendant were married on June 1, 1984
in Newville, Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. The marriage is irretrievably broken.
7. The Plaintiff has been advised of the availability of
marriage counselling and that the Plaintiff may have the right to
request that the court require the parties to participate in
counselling.
8. Plaintiff requests the court to enter a decree of
divorce.
,
The Plaintiff currently resides with the following persons:
HAms Re1ationshiD
Dianne L. Kiner Mother
13. The relationship of Defendant to the children is that of
mother. Defendant currently resides with the following persons:
HAms Relationship
Mother and step-father
13. The Plaintiff has not participated as a party or witness
in other litigation concerning the custody of the children.
plaintiff has no information of a custody proceeding
concerning the children pending in a Court of this Commonwealth.
Plaintiff does not know of a person not a party to this
proceeding who has physical custody of the children or claims to
have custody or visitation rights with respect to the children.
14. The best interest and permanent welfare of the children
will be served by granting the relief requested because the
children will remain in the same stable household that they have
resided for the past five years.
15. Each parent whose parental rights to the children has
not been terminated and the person who has physical custody of
the children has been named as parties to this action.
WHEREFORE, Plaintiff requests the court to grant custody of
the children to Plaintiff.
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