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Home My WebLink About96-02998 ~ I , i .' Ji :' 1 1 , I t 1, " , . I I , I, I . I I' I , I " i " , " " " " ' Ii 'I .,t, . , , I " . . , . I,' I . . . " ,I, " t:, ,II.' '" ',I " , , " ,', " 'I " , ' \ , " " ',,' I , " , " . " , , " , " " " . , 'I, " , , , , , ~ ,.., ~' _, r . '-.;:;,.'<) * t ~ - ~ ~~ 1")0;z4 ~ ~~'" <::::J \.:::::r ',. t. i' lq' < ' r: t.',' In ...'.'. j? cr Cl , ~ r< " I,ll . , ~ (; . " , 1._ 'I \' ... .., ... c - ,.., III >< Ii> lZl.., -'tJ Q 0< C lZl C 0 W ::l! 5! 1:'''' o QI e.. ~ ~ ;: Q III [i!~ tIl 1lI:.-l ::> 1IlD. OQ U ~ ~ all; ~ t!) a:I . Ill: e.. > e.. 0 ~S~DI III Ill: ra. . ell III Z ~ a 0 ell e.. z >< 0 lZl ..:l Ill: ... < W" Ill: 0< :::EX III tIl ..:l ell III D. I: I: I: H 0< 0 '" .., u ", " .' WI .., HI.:". ~i'''' 'it' "HI WITHI. "ft~ T AND ::iJ .. ~ Miffoo DI'. A~ IV IAW'Jffr(l$ ~&.i' MI' ~My 'Nl\Ywl_n fr) "IiI " WIl!tUIf l'ihPOHNl Ie) TIf ~'l'f~~IIWM!IV (10) [lAva '"1,)'" ~~"'~.'N~Ai~ .J:~, J:~'I" ., MANCKE, WAGN~A, HEFlSHEY & TULLY 'I' ,: : ";iJt, . . UHiAH4!V' 'hl~'" , . . ItIII..RLY 11TH IIDMIUf , I IN Tal COURT 0' C;OIIIION 'LIAS Plaintiff I CUMlIRLAND COUNTY, 'INNSYLVAHIA I (z ,(I( l V. I NO. 1/1. ,;'J,/~Jf I JAIIIS ROIIRT GOIDON, I Defendant I CIVIL ACTION - CUSTODY OIDIR 0' COURT "br,{ AND NOW, this ~ day of J l.,,~1l" . 19~. upon consideration of the attached Complaint, it iElhereby directed that the parties and their respective counsel appea! bet,Q.~e"o'Il i("-c..('- \ L. r", So f....~. the Conciliator, at ;l,":1 S.''i1l~. ,on -. the day of ~.. f.:L . 19~~. at o'clock --'!..,m, , for a Pre"Hearing cuStOa'Y Conference, At suc 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 preaent at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent Order, FOR THE COURT, By ~~~~~ Custody Conc liator ,'( 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 THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE. PA 17013 (717) 240-6200 "j r: " '1"1 " ,'"..\' , , " d-J ~ ~i.,~ ,>>I~4/-P d7# 4 ~ '3 4(, ~~..e /w~"itil 0 ~~ u'3.f,1; ~~k/.41o. /,/./3;<7 ~ ': , ;, " , 'I , ,I; " , , ", . , KIDIRI. Y 11TH IRDMAN , I IN THI COURT or COIDION PI.IAS Plaintiff I CUllBIIx.AND COUNTY, PINNSYI.VANIA I ..J 'I '/1 Cwd 71..,..- v. I NO. <7c. I JANIS ROIIIT GORDON, I Ddendant I CIVIL ACTION - CUSTODY COMPLAINT rOI CUSTODY 1, Plaintiff is Kimberly Beth Erdman (Mother), residing at 39 Annette Drive, Enola, Cumberland County, Pennsylvania 17025, 2, Defendant is James Robert Gordon (Father), residing at 7 Pine Road, Apt. 202, Mt, Holly Springs, Cumberland County, Pennsylvania 17065, 3 , Plaintiff seeks custody of the following child: Ryan William Gordon, 39 Annette Drive, Enola, Cumberland County, Pennsylvania, 17025; age 3~, The child was born out of wedlock. The child is presently in the custody of Kimberly Beth Erdman, 39 Annette Drive, Enola, Cumberland County, Pennsylvania 17025, 4, During the past five years, the child has resided with the following persons at the following addresses: a. From July 24, 1992, until September 1993, with the Plaintiff, Defendant and the child's maternal grandparents, Ronald and Sandra Erdman, at 39 Annette Drive, Enola, Cumberland County, Pennsylvania 17025; b, From September 1993, until present, with Plaintiff and her parents, Ronald and Sandra Erdman, at the same address. 5, Plaintiff is not married to the Defendant or anyone else, 6, The natural father of the child is James Robert Gordon, residing at 7 Pine Road, Apt, 202, Mt, Holly Springs, Cumberland County, Pennsylvania, 7, Defendant is not married to Plaintiff or anyone else, 8, The relationship of the Plaintiff to the child is that of natural mother, who currently revides with her parents, Ronald and Sandra Erdman, 9, The relationship of the Defendant to the child is that of natural father. 'Defendant currently resides with his girlfriend, Sarah Smith. 10. Plaintiff has not participated as a party or witness or in any other capacity in any litigation concerning the custody of this child in this OI any other court, Plaintiff has no information of a custody proceeding concerning the child pending in any court of this Commonwealth. Plaintiff does not know of a person not a party to this proceeding who has physical custody of the child or claims to have custody or visitation rights with respect to the child, 11. The best interest and permanent welfare of the child will be served by the granting of an order of joint legal and physical custody between Plaintiff and Defendant, Plaintiff seeks this order of court to formalize a legal custodial relationship which has existed since the time of the parties' separation, It is their desire to have a formal. of thill custody arrangement in place to facilitate the resolution of any disputes and to ensure appropriate healthcare coverage for the child. " ., ~ ~ I,) ~~ u ~ ~ q g i i ~ iH< . ~ \l g III i ~ " , . , , . .. .. .. , . " I , . '. i:JlIll tV I . . g ... ~ 6, The Defendant's position on custody Is as follows: See attached Order, 7, Need for separata counsel to represent child: None requested. 8, Need for Independent psychologlcel evaluation or counseling: None requested and the Conciliator does not balleve any Is necessary, Dete: 10 July 1996 ~ /:/1' (.", i (,7. Michael L. Bangs - , )/ Custody Conciliator l. " , , ' " " i , i' ',1.'1 ~ .2 J il.