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HomeMy WebLinkAbout96-06171 ...... "'- ~ ......... ......, . " <)-- I 1 / / / i r i I , SCHREIBER, BEVERLY A. Plaintiff :IN THE COURT OF CCMMON PLEAS or :CUMBERLAND COUNTy, PENNSYLVANIA vs. : NO. 16 - (i;, /7/ Cu.:.J!. T~w~ SCHREIBER, RICHARD L. Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court, If you wiah to defend against the claims set forth in the following pagea, you muot take prompt action. You are warned that if you fail to do 00, tho caso may proceed without you and a decree in d i vorco or annu lment may be entered against you by the Court, A judgment may aloo be entered against you for any other claim or relief roquented in these papers by the Plaintiff. You may looe monoy Dr property or other rights important to you, including cuotl)dy or vloitution of your children. when the grounds for divorcu are indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counoeloro io aVililable in the office of the Prothonotary at: Office of the Prothonotary Cumberland County Court Hou.. One Courthou.. Square Carlisle, p.nn.ylvania, 17013 IF PROPERTY, ANNULMENT THESE. YOU DO NOT FILE A CLAIM POR LAWYERS FEES, OR EXPENSES, IS GRANTED, YOU MJ\Y LOSE '!'fiE ALIMONY, DIVISION REFORE A DIVORCE RIGHT 'ro CLAIM ANY OF OR OF YOU SHOULD TAKE THIS PAPER 1'0 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, Court Admini.trator cumb.rland County Court House rourth Floor On. Courthou.. Square Carli.l., PA 17013-3387 717-:l40-6:l00 co:) I (,) " ~ ~ ,~ ~ 0 g ~~\Q ~~ - ~ ). ~ 'V'I~ N~ I'<) ~ '-51"" 1"- :\I: it ~~ ~ { >- u:: ~: ~ ~~{( ~ . itl L a?. [. u. : ~ '.,. J ,) '. ,. " 0... ,.'j ~ 2 ;;:- - . t,l . (,.1 .'..l.. 11. '.1') ....J Ll O'l ,_J , BEVERLY A. SCHREIBER, Plaintiff : IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA VB. I No. qb -b/71 RICHARD L. SCHREIBER, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached COMPLAINT, it is hereby directed that the parties and their respective Counsel O ~ ).. \ c"" 'J<' , . ~I, ~""'I<.,,,..~ appear before ,,-,,..1\ >. h<''f ,'the Conciliator, at:> I.....~'."" on ~ theJll1day of -I)f".....btr , 199.fz, .-:It I PX.I(Jj;)/p.m., for a Pre- Hearing Custody Conference, At such 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 aged five or older may also be present at the conference. Failure to appear at the conftlrence may provide grounds for entry of a temporary or permanent Order. FOR THE COURT: BY 0,-,.-4 ,,<,L'<~-FS" CUSTODY CONCILIATOR ~pfl 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 THIS OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: OFFICE OF THE COURT ADMINISTRATOR CUMBERLAND COUNTY COURT HOUSE FOURTH FLOOR ONE COURT HOUSE SQUARE CARLISLE, PA 17013 (717)240-6200 BEVERLY A. SCHREIBER, Plaintiff vs. IIN THE COURT OF COMMON PLEAS OF ICUMBERLAND COUNTY, PENNSYLVANIA I No. '1''-' G I'll (!<.Z.U-U........ : CIVIL ACTION - LAW RICHARD L. SCHREIBER, Defendant CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, Beverly A. Schreiber, by her Attorney, JAMES M. BACH, and respectfully represents as follows: 1. The Plaintiff is Beverly A, Schreiber, residing at 1536 Grand View Avenue, Mechanicsburg, Pennsylvania, 17055. 2. The Defendant is Richard L. Schreiber, residing at 2001 Red Bank Road, Dover, Pennsylvania 17315. 3. plaintiff seeks custody of the following child: Leanna R. Schreiber, born 6-27-94. 4. The child is presently in the custody of Beverly A. Schrieber, who lives at 1536 Grand View Avenue, Mechanicsburg, Pennsylvania, 17055. 5, The natural Mother of the child is Beverly A. Sch:!:'eiber, 6. The natural Father of the child is Richard L, Schreiber. 7. The relationship of Plaintiff to the child is that of Mother. 8. The relationi3hip of Defendant to the child is that of Father. 9, The plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the child in this, or any other Court. 10. Plaintiff has no information of a custody proceeding concerning the custody of said child pending in a Court of this Commonwealth, or in any other jurisdiction. 11. Plaintiff does not know of a person, not a party to the proceedings, who has physical custody of the child, or claims to have custody or visitation rights with respect to the child. 12. The best interest and permanent welfare of the child will be served by granting the relief requested, because the plaintiff can provide a stable and wholesome home environment for the child. 13, Each parent whose parental rights of the child have not been terminated, and the person who has physical custody of the child, have been named as parties to the action, 2 i , 1 I I I I co I '.') '> ~ '"""" N ~" \n ':1 ;::r 14 ~. .\. ~ ] It if: ..- ...; ~l(~ n:' ' ~-i' (' IT L. ft" ' r~-: 'L o CI '" P- "'. ','-- ..;. ,- , :1, \ ~i ~ \l' 0' ^ .," I:;) ;;J.. ) (.J ~ ..:J" ~ Cl ,.. :it :5ot-r ~O O-J ~ :c O;"l "- '::i~ ~C' ~~:in E r- r' ;-. :1;. U.I '-' U:1r'D j!O '-'-' ~~o. Q "" II. \.0 d 0 en