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HomeMy WebLinkAbout96-03462 - -+- -.,. I~ -..J .... t:') ~ 1 I, n) I ... > " tll' () I' .... t.. () L " I.t) (~ t' ~ , . ~ J, , ~ t ~ 't\ , ' J ,~ ~ iY t, . J i Dr- '-.:) - ~ I.' I) ~ ~~ - ~H..i2Q ",<fj-<!ll :51S nreO':~ I&:t'i~~~ ~ ~ ~ ~ ~~ ~~ c. ~ ~ . . . IwnUCK t., LAlIER. JR. AUurnry ut I.nw 110)\ Mill~l"I Sln'l'l ^Jh'~ IIUlllhll~ '",lInll Hdl. P^ 17011 c'l1'I1 Itd IKOO " ,"-" :" !h STBVEN W. CONRAD, I IN 'rHE COURT OF COMMON PLEAS Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I va. I No. qf- ':" JI/I..J. C...Il'/ 7('"1'1 I THBRESA CONRAD, I CIVIL ACTION - LAW Defendant I IN CUSTODY ORDER OF COURT AND NOW / thia ) '^",.? ~I, 1'1 (1 (.. / upon consideration of the attached complaint, it ia hereby directed that the .rartiea and their respective counsel appear before lilt( /1/(( f ,(.ltU)II.) the conciliator, at .102. Sodl, 1J'1h ,)1. ft,'i1/.' J(,/fJ f day of /ll1j0~+' ,1996, at 11"OCl/I.M., for a Pre-hearing Custody Conference. At such conference, an effort , on the 2.'2... 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. Either party may bring the child who is the subject of this l"'ustody action to the conference, but the child/children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURTI 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 LEGAT~ HELP. OFFICE OF THE COlffiT ADMINISTRATOR COURTHOUSE, FOURTH FLOOR CARLISLE, PA 17013 (717) 240-6200 STEVEN W. CONRAD, Plaintiff vs. I IN 'rHE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA I I No. I I CIVIL ACTION - LAW I IN CUSTODY THERESA CONRAD / Defendant COMPLAINT FOR CUSTQQX The Plaintiff, steven W. Conrad, through his attorneys, The Law Offices of Patrick F. Lauer, Jr. / files this Complaint for Custody, against the Defenriant / Theresa Conrad, and in support thereof, avers the following: 1. The Plaintiff is Steven W. Conrad, an adult individual and the natural Father, who currently rflsides at 602 Meadowbrook Road, Carlisle, Cumberland County/ Pennsylvania 17013. 2. The Defendant is Theresa Conrad, an adult individual and the natural Mother, who currently residee at 12 Elkins Street, Franklin, New Hampshire 03235 and has a mailing address of 87 Elkins Street, Franklin, New Hampshire 03235. 3. The Plaintiff seeks custody, partial custody, and/or visitation of the following child: ~ Present Address lig,li 3 (Feb. 22, 1992) Joseph Conrad 12 Elkins Street Fr.anklin, NH 03235 The child was not born out of wedlock. 4. The child is presently in the custody of Theresa Conrad, who currently resides at 12 Elkins Street/ Franklin, New Hampshire 03235. 5. During the past five years, the child resided with the following persons and at the following addresses I liAlnJi Address Dates Theresa Conrad 12 Elkins street Franklin, NH 602 Meadowbrook Road Carlisle, PA 17013 09/06/95-Present steven Conrad Theresa Conrad 02/22/92-09/08/95 6. The Mother of the child is Theresa Conrad, who currently , resides at 12 Elkins Street, Franklin, New Hampshire 03235, with I the subject of this petition. The Mother continues to be married to the natural Father. 7. The Father of the child is steven W. Conrad, who currentl.y resides alone, at 602 ~Ieadowbrook Road, Carlisle, , Cumberland County Pennsylvania 17013. The Father continues to be married to the natural Mother. 8. The Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 9. The Plaintiff has no information of a custody proceeding concerning the child currently pending in any court of this Commonwealth. 10. The Plaintiff doe a not know of a person not a party to the proceedings, who has physical custody of the chJ.ldren or claims to have physical custody or visitation rights with respect to the children. C\~~AY 1 9 1997 STEVEN W. CONRAD I IN THB COURT OF COMMON PLBAS OF Plaintiff I CUMBBRLAND COUNTY, PBNNSYLVANIA I ,N'1.- ve. I No. 96-~Civil Term I THERESA CONRAD, I CIVIL ACTION - LAW Defendant I CUSTODY/VISITATION ORDBR AND NOW, this L'~ 1997, upon Parties regarding day of ~1 conBideration of the attached Stipulation of the cUBtody of their minor child, Joseph Conrad, born February 22, 1992, it iB hereby decreed that thiB Stipulation iB entered dB an Order of Court. By the Court, , AIL I II - J. , ~ . PATRICK t', I,Allt:R. ,/R ^lll)rnc~ ~I L~" ~ 1 011 ....'.rln.' "'I!~d \/I~, l\tnl.lllll'. llltlllllllll.l.,\ 171)11 I'll'll 71l \.11<1)1/ . . ~ , ~ . IX ., ci i* U '-'l j '" ,-.. ;;l ~ 'n " ;C J w ~ -( .. ;j , c. '" ~ "" " '" . ~ <II "" .. " '" E ::; " - ~ ~ J: r- U 0 ~ , '" '" w -( ~ - w IX -of. c, I..J (- of, c.. . MAY l :) I~~j " ~I ~ M . ~ \" "j 1 \" . . STEVEN W. CONRAD, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF' CUMBERLAND COUNTY, PENNSYLVANIA ~4,,1- No. 96 - ~-Civil Term CUSTODY/VISITATION CIVIL ACTION - LAW THERESA CONRAD, Defendant fiTIPULATION WHEREAS the parties have born to them a child, namely Joseph Conrad, born February 22, 1992 (the child hereinafter), and WHEREAS, the parties wish to enter into an agreement relative to custody, partial custody, and visitation of the child, and THEREFORE, this 3 day of ,#.qci(SV- 1996 in consideration of the mutual covenants, promises, and agreements as hereinafter set forth, and intending to be legally bound, the parties agree as follows: 1. The Mother, Theresa Conrad, Ilhall have primary physical custody of the parties' minor child, Joseph Conrad. The parties shall share legal custody of the child jointly, 2. The Father, Steven Conrad, shall have visitation with Joseph Conrad, for a period of eight (8) consecutive weeks every Summer. Thill period shall co~nence no sooner than one week after the last day of school and shall end no later than one week before the first day back to school each year. C, /Jv (' ~ -3-.-- llec:all6e tll..--F'ather w';'ll hdV.. 1...", L1.an eight "",,,,k,, -Gt1l1un~L v~3it..a.t-iE>n clUJ:: ing 19PG, the PtltlAcl 101la11 L'C ...n.tit.leJ l.o j ~ l. ~ Ii.) ~ ,,. - ", '" - , ..0 , , "" ,. ~ " , '