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Home My WebLink About96-03580 vs. t IN THE COURT OF COMMON PLEAS OF I t CUMBERLAND COUNTY, PENNSYLVANIA I I NO. 96-3'ib( CIVIL TERM KURT A. REIMER, Plaintiff THERF.SA SANDRA NAZAY, Defendant CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached complaint, it is hereby directed that the parti~s and their respective counsel appear before i ) I f ) "I ~ \. (,il ".. /j. J I " , the conciliator, at"I, ., 1"/1 .11 II "",) It II,J' ILl R _ . on the ,.'liI day of (I II ~t 1;1 1996, at '/.I( '.' .m., for a Pre-Hearing custody Conference. At such conference, an effort will be made to resolve the issues in disputel or. if this cannot be accomplished, to def ine and narro\~ the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. For the Court, },,/'J\l"li l'l\n,~,i, .!\ )lu}i1IL/H',1" custody conciliator'l~ T YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 0R CANNOT AFFORO ONE, GO TO CR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR, 4th FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PEN;ISYLVANIA 17013 TELEPHONE NUMBER: (717) 240-6200 AMERICANS WITH DISABILITIES ACT OF~O The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Acto of 1990. For information 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 scheduled hearing or business before the court. You must attend the scheduled conference or hearing. She is divorced. The father of the child is Kurt A. Reimer, currently residing at 22 South Eighth street, Lemoyne, Cumberland county, Pennsylvania 17043. He is single. 4. The relationship of plaintiff to the child is that of father. The plaintiff currently resides with the following persons: ~ Relationshio Travis August Reimer every other weekend son 5. The relationship of defendant to the child is that of mother. The defendant currently resides with the following persons: ~ Relationshio Kristofer Tyler Nazay son 6. 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. Plaintiff has no information of a custody proceeding concerning the child 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 child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested for reasons including the fOllowing: a. The father has a relationship with the child and rO Q . ....; ~ (! '.- fn ~"' r " i: ,t/I r') .; t )- " .;~ f~' , ' :.') ,: I c:j l) , .. rl~,:~ ' .., ',? .' .! ~;'11 t..:11' 1,\1 ':'j ,- , ~, lij. '~ \" , "; 1 (,) l.-ii c) M~1'lOAY,I.'l', _lfi~JJP..l'QR'L9' _nU1J9ff FOR ~2^V2rQPROCB2D IN ~O~HA ~AJJPBRiS 1. I am the plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the informat ion be low re laUng to my ability to pay the fees and costs is true and correct. (a) Nama: __ RlJrs_A,Reimu______ _ _______~ _______ Address I __ ll2SQ\.ll;/} el;n S.J;re~l; _ _ ___,____ _ ____.r.!1moyn!l_L..I'A_ J.7_Q~3 _ _ _ _____________ Social Security Number: 18Q-~(i:-')'.l7;L _,_,,________ (b) If you are presently employed, state Employer: ,__ffi!'L_ _ _ ___________________________________ Address: H/A ___,_________________ Salary or wages per month: ~/h_ Type of work: _N./h_ _____ __ _ _ ______ If you are presently unemployed, state Date of last employment: J/30/9(i____,_______,~_ Salary or wages per month:',2QQ8.i)~________,_,_ Type of workl HillwriUng anc;lc).!lJ;'ic"l______________,__ (c) Other income within the past twelve months Business or profession: NOne _________________,___,______ Other self-employment: _None,_ __,__ ______,______________ (f) Debts and obligations Mortgage ~ ..NOM... ...__..._...._......__.__.__. _____...__ Re n t t . .J.6..9..o.,.OO.__ _...._.. __.._..... ..._.___...____.._..._.___._____. Loans 1.1I1uu. F1mmc.!l. - U..oOO,OO_.......__..___..__.__ MonthlY Expenses I, Oil-In, 0!LJUQc.tr.1.c.-:J~6,..9Q/.. .....__... .fh2IJ.!1_-:-U7.56, V1/la-'50. 00 ,OhcQY'r':"'~0..09.L___._.__.__ uT'X~C;9':"'23,00, CaPle-it 9 ..96 ,'I.'ruh-=I,l~,..;llL. .Wlltflr4t SeWflr-J17. 50, Gro<;eri!3e':"UOO. 00., __... ..__m___... ..hMJ;\) imHI1;ancll-'25. 00, Ga/.Jo),infl-.140 ,90,...R.UtUII.. _.'_... 1nll\lrancll-,e. 30, mb<;ll 1 1.,nIl91,l1l-' 35 .00, IH!PPQ.tl.::Ull~Q.Q (g) Persons dependent upon you for support (Wit e) (Husband) Name: tlo))'__ Children, if any: Name 1 _...KriBtoiu N!I~!n'. ... ..Tr~'i;!,lL.R~J.mu.. _.._m.... Age : -1._Y.rJl~__ __Ln:.IL.-..__ 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. /g;:; c-( :y2.~.c ~~ A:"'ReI~~'-Pl;!intifi" .-..---.... Date: _1/;/7(-:____..___.. '. " ',. 'LI (,. '", , . " " : , l\!. .- ()" "~"~I C' , ~ ,. I:;] .:... '1-;; (~ .> ':1 (i" ,,' ',1 J .. '.') f;.:' .. ..~ I -=; ~ " ,. It] .'.1 l.; ~n <.) ii " vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-3580 CIVIL TERM KURT A. REIMER, Plaintiff THERESA SANDRA NAZAY, Defendant CUSTODY CUSTODY ORDER AND NOW, this ~ day of ~-:t 1996, upon consideration of the parties' Consent Agreement, the following Order is entered with regard to custody of the parties' child, KRISTOFER TYLER NAZAY, date of birth, December 24, 1988: 1. The plaintiff, KURT A. REIMER, hereinafter referred to as the father, and the defendant, THERESA SANDRA NAZAY, hereinafter referrod to as the mother, shall have legal custody with the father's right of shared legal custody beginning January 1, 1997. The father does not object to the child being raised Catholic or to hi~ attending Catholic school; either party may petition the court for a hearing if they cannot agree as to the child's religious or educational upbringing in the future. 2. The mother shall have primary physical custody. 3. The father shall have partial custody according to the following schedule: a. Every other weekend from Friday at 6:00 p.m. until Sunday at 6:30 p.m. phasing into this weekend schedule as follows: a half-day for the first custody weekend, a \!' :!-qlJ:',l:l.ay on the second custody weekend, one overnight , . " 9 I: l the third custody weekend, and the Friday through "I f' , . . 'sunday'pe~iod the fourth weekend, and alternate ...J I " f',..., _III. ..J ;. ....i;..,,'J ,:J weekends thereafter. The father shall arrange to have the first three periods of custody on weekends when he does not have custody of the child's half-brother. b. other times as agreed upon by the parties. 4. The h~liday custody schedule shall be as follows! a. Thanksgiving Day shall be shared between the parents, with the child spending one meal with the father and one meal with the mother. b. Christmas Eve, the child's birthday, the father shall have custody commencing at 7:00 p.m. on December 23rd until 5:00 p.m. on Christmas Eve. The mother shall have custody on Christmas Day. c. The mother shall have the child on Mother's Day and the father on Father's Day commencing at 7:00 p.m. the evening before the holiday until the evening of the holiday at 6:30 p.m. d. Easter, Memorial Day, the Fourth of July, Labor Day, and New Year's Day shall be alternated between the parties commencing at 7:00 p.m. the evening before the holiday until the evening of the holiday at 6:00 p.m. 5. The father shall have the right to custody of the child for two nonconsecutive weeks each summer unless the father takes the child for vacation out of state at which time he shall have two consecutive weeks. When the father takes the child on vacation out of state, he shall provide the mother with an address where the child will be staying and the telephone number. The father shall give the mother notice of his vacation by May 31st, or prior to that date if his vacation schedule is arranged. 6. 'rtle father Illhall give the mother the right of first refusal if he needs child care for an extended period while he has custody of the child if there are no paternal family members available to care for the child. 7. The parties, by mutual agreement, may vary from this schedule at any time. 8. The father understands that he shall be expected to take the child to sporting events and other prescheduled Bchool events during the father's scheduled periods of physical custody. 9. The parties shall not take the child away from the parent's residence for more than a twenty-four hour period without providing the other party with the location and telephone number of the intended destination. 10. The parties shall provide each other with reasonable telephone access to the child at all times. 11. The parties acknowledge that the r.aising of a child when the parties live separately carries with it special problems and obligations and each party shall cooperate with the other to the maximum extent possible to assure that the best interests and welfare of the child are served. 12. The intent of this Custody Order is to encourage both parents to share the rights, pleasures, and responsibilities of child rearing and to maintain a meaningful relationship with their child. KURT A. REIMER, Plaintiff vs. IN THE CCURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-3580 CIVIL TERM CUSTODY ~SEHT AGREEMENT THERESA SANDRA NAZAY, Defendant day of (l" .,.,. ,,/-- ." \ July', \ I. This Agreement is entered on this v . Iftj 1996, by the plaintiff, Kurt A. Reimer and the defendant, Theresa Sandra Nazay The plaintiff is represented by Joan CareYI the defendant is represented by Judith A. Calkin. The defendant and the plaintiff agree to the entry of the fOllowing custody Order regarding custody of their child, Kristofer Tyler Nazay: 1. The plaintiff, KURT A. REIMER, hereinafter referred to as the father, and the defendant, THERESA SANDRA NAZAY, hereinafter referred to as the mother, shall have legal custody with the father's right of shared legal custody beginning January 1, 1997. The father does not object to the child being raised Catholic or to his attending Catholic school! either party may petition the court for a hearing if they cannot agree as to the child's religious or educational upbringing in the future. 2. The mother shall have primary physical custody. 3. The father shall have partial custody according to the following schedule: a. Every other weekend from Friday at 6:00 p.m. until Sunday at 6:30 p.m. phasing into this weekend schedule as follows: a half-day for the first custody weekend, a full day on the second custody weekend, one overnight tho third oustody weekend, and the Friday through sunday p~riod the fourth weekend, and alternate weekends thereafter. The father shall arrange to have the first three periods of custody on weekends when he does not have custody of the child's half-brother. b. Other times as agreed upon by the parties. 4. The holiday custody schedule shall be as folloWSI a. Thanksgiving Day shall be sh~red between the parents, with the child spending one meal with the father and one meal with the mother. b. Christmas Eve, the child's birthday, the father shall have custody commencing at 7:00 p.m. on December 23rd until 5:00 p.m. on Christmas Eve. The mother shall hava custody on Christmas Day. c. The mother shall have the child on Mother's Day and the father on Father's Day commencing at 7:00 p.m. the evening before the holiday until the evening of the holiday at 6:30 p.m. d. Easter, Memorial Day, the Fourth of July, Labor Day, and New Year's Day shall be alternated between the parties commencing at 7:00 p.m. the evening before the holiday until the evening of the holiday at 6:00 p.m. 5. The father shall have the right to custody of the child for two nonconsecutive weeks each summer unless the father takes the child for vacation out of Istate at Which time he shall have two consecutive weeks. When the father takes the child on vacation out of state, he shall provide the mother with an address where the child will be staying and the telephone number. The father shall give the mother notice of his vacation by May 31st, or prior to that date if his vacation schedule is arranged. 6. The father shall give the mother the right of first refusal if he needs child care for an extended period while he has custody of the child if there ar~ no paternal family members available to care for the child. 7. The parties, by mutual agreement, may vary fr.om this schedule at any time. 8. The father understands that he shall be expected to take the child to sporting events and other prescheduled school events during the father's scheduled periods of physical custody. 9. The parties shall not take the child away from the parent's residence for more than a twenty-four hour period without providing the other party with the location and telephone number of the intended destination. 10. The parties shall provide each other with reasonable telephone access to the child at all times. 11. The parties acknowledge that the raising of a child when the parties live separately carries with it special problems and obligations and each party shall cooperate with the other to the maximum extent possible to assure that the best interests and welfare of the child are served. 12. The intent of thi$ Custody Order is to encourage both "" "'" ~ III ~ 10'; .. ~~; ,~ l~'i " , " :or. '.', ~: '1:;1 5". .... ~Jl'. a> i~ I !r!; , , 1 ILl' iq t-".~ ~., 'j'.... ....;.; l<. \J.) , ..i 0 (,I) .,) . ~ -- -. tr. ..:J " i'" /.;~ , .~ ~(') , , . ... Ci. ' .'- '''';.. .". '."1. .1: ,:-'1 df , j' ~i 6) ~ .. '-1) I ") eli' f,: 1111 '-, 111,. f- L'; lL ,,") .-:) <..) 0) l.)