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Home My WebLink About96-04655 'I t ~ , J : \, ~ / , ! 1 ~ I '" } ., ,~ ~.::~ ~ '" :~ ~- ~ <, f-' ",j "h~ .i w':, . . Q,'; . . ~ ~ ~i:o -~.~ !...:- ~;:i ...., (- ';;0- c. ,;:, .w ... .... '" UJD. C".; 1% - ., . -.... y tELJ.' E. 1 -lr'O I 0 :t i ..1. ;'0- - ,- -"'- .;: , ~il t1. ....., ~-) <:l ~ 0 0-' U :;:j- ~ -t s~ - - - .... - f:l ...~ ~ !ll~ [f~~~ . tc ~~ ;ieJ~ , ~ ii! . - . Ill" ~ ~~ = "'Ill U ~i Cl\ .., Cl\ - . - \0 '" ,.:. - .... CHARLES E. PETRIE ATTOAA'EY AT LAw 3528 BRISBAN STREET HARRISBURG, PENNSYLVANIA 1711l hi),; i.. I I~dll (I- , . . c. Two one-week segments each year upon giving thirty days' notice to Mother. The segments shall not be taken consecutively. d. The Christmas holiday shall be divided into two segments: Segment "A" shall commence on Christmas Eve at 10:00 A.M. and shall end on Christmas Eve at 5:00 P.M. Segment "B" shall commence on Christmas Day at 10:00 A.M. and shall end on Christmas Day at 5:00 P.M. Father shall have Segment "A" in 1996 and in all subsequent even-numbered years; Mother shall have Segment "A" in 1997 and in all subsequent odd-numbered years. e. At such other times as the parties shall agree. J. , , , " I .-n c.. ~. r") :, -'-' '. ) ~ I 11 ...1 ." -< .~ .=::' CARRI A. ANDERSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. NUMBER: DEREK R. ANDERSON, SR., Defendant CUSTODY MOTION NOW COMES the Plaintiff, CARRI A. ANDERSON, by her attorney, Charles E. Petrie, and respectfully represent as follows: 1. That Plaintiff is CARR I A. ANDERSON, an adult individual currently residing at 2117 Prins ton Avenue, Apartment 1, Camp Hill, County of Cumberland, Pennsylvania. 2. That Defendant is DEREK R. ANDERSON, SR., an adult individual currently residing at R.D. 3, Box 184-A, Coudersport, County of Potter, pennsylvania. 3. That Plaintiff and Defendant are the natural parents of a minor child DEREK ROBERT ANDERSON II, born September 30, 1994. 4. That the parties have entered into a Stipulation concerning the matters of custody and visitation with respect to the minor child, and the said Stipulation is attached hereto. 5. That the parties desire that said Stipulation be entered Respectfully submitted as an Order of Court. WHEREFORE, Plaintiff respectfully requests that Your Honorable Court enter an Order pursuant to the attached Stipulation. rh.~~ CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiffs CARRI A. ANDERSON, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DEREK R. ANDERSON, SR., Defendant NUMBER: 'll.. '-I G . j' 'J'" (~~(:f.j' EL<-- CUSTODY COMPLAINT FOR CUSTOD" NOW COMES the Plaintiff, CARRI A. ANDERSON, by her attorney, Charles E. Petrie, and respectfully represents as follows: 1. Plaintiff is CARRI A. ANDERSON, who currently reside at 2117 Prinston Avenue, Apartment 1, Camp Hill, County of Cumberland, Pennsylvania. 2. Defendant is DEREK R. ANDERSON, SR., who currently resides at R.D. 3, Box 184-A, Coudersport, County of Potter, Pennsylvania. 3. Plaintiff seeks to have rights of primary physical custody with respect to DEREK ROBERT ANDERSON II, born September 30, 1994. The child was not born out of wedlock. The child is presently in the custody of Plaintiff, CARRI A. ANDERSON. Since birth the child has resided with the following persons and at the following addresses: From birth until October 30, 1995, with both parents in Dover, Delaware; from October, 1995, until March, 1996, with Plaintiff in Dover, Delaware; from March, 1996, until August 4, 1996, with Plaintiff at 995-A Boiling Springs Road, Mechanicsburg, Pennsylvania; from August 4, 1996, until the present with Plaintiff at 2117 prinston Avenue, Apartment 1, Camp Hill, Pennsylvania. The mother of the child is CARRI A. ANDERSON, who currently resides at 2117 prinston Avenue, Apartment 1, Camp Hill, pennsylvania. She is married. The father of the child is DEREK R. ANDERSON, SR., who currently resides at R.D. 3, Box 184-A, Coudersport, Pennsylvania. He is married. 4. The relationship of the Plaintiff to the child is that of mother. The Plaintiff currently resides with the child and with her sister, Jennifer Gerner. 5. The relationship of the Defendant to the child is that of father. He currently resides with his parents, Dennis and Ma~y Anderson. 6. 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 in another court. The Plaintiff has no information of a custody proceeding concerning the custody of the child in this or in another court. Plaintiff does not know of a person not a party to these proceedings who has physical custody of the child or who 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 confirming rights of primary physical custody in Plaintiff. 8. Each parp.nt whose parental rights to the child have not been terminated and the persons who have physical custody of the child have been named as parties to this action. 9. The parties have entered into a Stipulation, attached hereto, setting forth their agreement concerning custody of the minor child. WHEREFORE, Plaintiff requests the Court enter an Order confirming rights of primary physical custody in Plaintiff. Respectfully submitted, ~r~ CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiffs 2. That the parties shall share legal custody. 3. That the Father of the minor child, DEREK R. ANDERSON, SR., shall have rights of temporary physical custody in accordance with the following schedule: a. Every other weekend from Friday at 5:00 P.M. until Sunday at 5:00 P.M. b. Every other holiday from 10:00 A.M. until 5:00 P.M. The holidays shall include New Year's Day, Memorial Day, Independence Day, Labor Day, and Thanksgiving, commencing with Father having the child for Labor Day in 1996. The child shall spend Father's Day with Father and Mother's Day with Mother regardless of the regular weekend custody schedule. c. Two one-week segments each year upon giving thirty days' notice to Mother. The segments shall not be taken consecutively. d. The Christmas holiday shall be divided into two segments: Segment "A" shall commence on Christmas Eve at 10:00 A.M. and shall end on Christmas Eve at 5:00 P.M. Segment "B" shall commence on Christmas Day at 10:00 A.M. and shall end on Christmas Day at 5:00 P.M. Father shall have Segment "A" in 1996 and in all subsequent even-numbered years; Mother shall have Segment "AU in 1997 and in all subsequent odd-numbered years. e. At such other times as the parties shall agree. IN WITNESS WHEREOF, the parties have hereunto set their hands and official seals. WITNESS &&!~sI-{{~t7?c