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Home My WebLink About96-03263 . . " ~~~~tF:~ , -".),i. ;7.; , TH& t.AW '""1 Or. KILLIAN &.' GEPkART caRTI,II\) Cl.'lPVJUN' "'., . . . ' '') 1 2 1998V (::;:~{- 111 'IN.,~"..r. , ;1, , \.,:':':. _'0 o. aox ... t~C\~>HAARI.8URo. PENNSYLVANIA 1710S.o888 ,t',",,'; I , , , J ,," ': t', (" ,-:,,' " . ;"; .I I " ,', ., "f \~ .. . '" {, ~ ;,...",'t\ c_ ~ \.' ~ ;' "',11 , , ,"/, ", J 'i' I f ", 'i t I, I,.. :. , , "",. ' .,tI...'>~_, , ,I; -,' ,. , ,t''', .... " '. , ,- , , . . :":, , 1 I! ~; I, I '\ i : It ! r ,'I: , t' ~~ I ,~ ft ! ~/~ \;;1 ! , f~l, ~ " I' , . \ I"~ , . I I ,. ~, , ! I , , iF J , ~ i "/ " CHERYL L, RIDDLE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 1~ GL~L 3).&3 CHARLES D. RIDD'.E, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER AND NOW, )U.lUf' Iii /99L , upon considerat ion of the attached compla'!nt, it ill hereby directed that the parties and their respective couns~ appear before m,~J.:>,,'L R'::1l'9r ' the conciliator, at .l,u ~".iJ.. JpI(~..J. (~, !i,'/1 . on the pI~ day o , 1996, at JJ:c,r) . m. for a Pre-Hearing Custo n erence, At such conference, an effort will be made to resolve the iesues 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 preeent at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, BY:fi~,/~.~"frt ~a~J~-:~r- sto y onc ator The Court of Common Pleas of Cumberland County is required by law to comPlr with the Americans with Disabilities Act of 1990. For informat on about accessible facilities 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 or hearing. YOU SHOULD TAXB THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAW A LAWYBR OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OrrICI SIT FORTH BBLOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Office of the Court Administrator Cumberland County Courthouse - Fourth Floor 1 Courthouse Square Carlisle, Pennsylvania 17013-3387 Telephone (717) 240-6200 CHERYL L. RIDDLE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N r;1,-32(.,~/~,'J'77_ o . L..!,,-,,-< v. CHARLES D. RIDDLE, Defendant CIVIL ACTION - LAW IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Cheryl L. Riddle, who presently resides at 18 East Green Street, Shiresmantown, Cumberland County, Pennsylvania. 2. The Defendant is Charles D. Riddle, who presently resides at 227 Walton Street, Lemoyne, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of their minor children, namely: ~ Present Address ~ Travis D. Riddle 18 East Green Street 10 years Shiresmantown, PA Lee C. Riddle 18 East Green Street 7 years Shiresmantown, PA The aforementioned children were not born out of wedlock. The children are presently in the custody of Plaintiff. During the past five (5) years, the children have resided with the following persons at the following addresses: ~ Address Dates Charles D. and Cheryl L. Riddle Cheryl L. Riddle 18 East Green Street Shiresmantown, PA Birth through August 1993 August 1993 to present 18 East Green Street Shiresmantown, PA The mother of the children is Cheryl L. Riddle, currently residing at 18 East Green Street, Shiremanstown, Pennsylvania. She is not married. The father of the children is Charles D. Riddle, currently residing at 227 Walton Street, Lemoyne, Pennsylvania. He io not married. 4. The relationship of Plaintiff to children is that of mother. 5. The relationship of Defendant to the children is that of father. 6. 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 the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interests and permanent welfare of the children will be served by granting the relief requested. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff respectfully requests this Honorable Court grant her custody of the children, Travis D. Riddle and Lee C. Riddle. --- ;) . Paul Helvy, Killian & Gepha 218 pine Street P.O. Box 886 Harrisburg, PA 17108 (717) 232-1851 Atty. 1.0. #53148 Dated: June 7, 1996 Attorneys for Plaintiff 2 VERIFICATION I hereby verify that the statements of fact made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the penalties contained in 18 Pa.C.S.A. 54904, relating to Unsworn falsification to authorities. , , " nvcfA.~J1Jn Dated: i': 4,: , G'Y'9b I,~ ;. , " . ~ ~_..... . ~ - . --- ~---------- ~...... ~_.' - en ~ o ~ ~~ q I:Q E il> ..l ~ i ~ i i ~L;I o ' 8 Ie il ~ . . - .. .. -' ... . .' , .' . . , .qi!( 1,;' J .or' ~ i "l ..... t. ~ ~~ ... ~ ~ .'~ ~ ~ . schedule shall be the Monday preceding the Father's alternating weekend schedule. 3. The parties ehall alternate the following major holidays: Labor Day, Thanksgiving, Easter, Memorial Day, and Fourth of July. This alternating schedule will begin with Father having Labor Day In 1996. 4. The Christmas holiday will be divided Into two segments. Segment A will be from Christmas Eve at 12:00 noon until Christmas Day et 2:00 p.m., while Segment B will be from Christmas Day at 2:00 p.m. until 26 December at 2:00 p.m. Father shall have Segment A In 1996 and all even-numbered yeers thereafter, and Segment B in 1997 and all odd-numbered years thereafter. Mother shall have Segment A In 1997 and ail odd-numbered years thereafter, and Segment B in 1996 end ail even-numbered years thereafter. 6. Mother shall have the children on Mother's Day, and Father shall have the children on Father's Day. 6. Father shall have three (3) non-consecutive uninterrupted weeks of summer vacation with the children. He should provide Mother with notification of the weeks In which he chooses to exercise these periods of vacation no later than May 1 st of each year. In the event that Father is going to go on vacation with the children which - - will extend beyond one week, he will notify Mother of those dates and the parties will work to ensure that Father has the availability to havs the children in excess of one weak. 7, Mother shall have two (2) uninterrupted weaks of vacation with the children during the summsr. She will notify Father by May 16th of each year of her two weeks In which she chooses to exercise these uninterrupted periods of custody. 8. Such other times as the parties may agree. J. Paul Helvy, Esquire Attorney for Plaintiff J. Gerald J. Shekletskl, Esquire Attorney for Defendant mlb () ~o f.;" 0' ~ ,..T "'" f' ;, I ,]OJ :-1 ., r!i~ , , (,';:' L'I -~ "" :', !7: '.. :,r. >:" ", .~ 1 , ;i; j"'l 'Y 'iJ .--, - -I -. I. .. 'oJ ~ ';" .. ",."..., - '. 6. The Plaintiff's position on custody Is as follows: See attached Order. 6. The Defendant's position on custody is es follows: See attached Order, 7. Nesd for separate counsel to represent children: None requested. 8. Nsed for Independent psychological evaluetlon or counseling: Neither party requested and the Concllletor does not believe any Is necessary. Date: 12 August 1996 .:.J