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HomeMy WebLinkAbout00-00859 . . . ~.. DANIEL L. WILSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : Crvrr. ACTION - CUSTODY : NO. 2000 - 1'51 crvrr. TERM SHARON M. WILSON, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this \ \ day of te h 2000, upon consideration of the attached CQmplaint it is hereby directed that the parties and their respective counsel appear before . . . Esquire, the conciliator, at , \SJ....J(' ~ Pennsylvania, on the c... day of 2000 at ~O',~O ~.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 Conrt, and to enter into a temporary order. All children age five or older may be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: By: %~).\~~~~, Custody Conciliator '---_ L '<>>') 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 HELP. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 i,;;}j'J_ ~ -!'I ;., :,,, ;;;; j i: /J~ :;OUl~TY PENNSYL\/,A,NIA ddt!-~t? &d ~. ~ vd#.f1L/ d'~If.m '7!~ ~ Z 4M~ yd#-- QlbJlj.aJ ~ ~ <4u % ~ ';I~' -7' .. , ~. --~"."!"'~~ = '"" ",""" ,_' ~, . M"'l'O~"-~_."~,"", ",.~-- DANIEL 1. WILSON, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - CUSTODY : NO. 2000 - CIVIL TERM SHARON M. WILSON, Defendant : IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Daniel 1. Wilson, an adult individual currently residing at 620 Belvedere Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Sharon M. Wilson, an adult individual currently residing at 1278 Monticello Drive, Daytona Beach., V olusia County, Florida 32119. 3. The Defendant is the natural mother of the children, Tabitha Michelle Wilson, born January 21,1993, and Kristen Marie Wilson, born August 14,1994. 4. The children were born in wedlock. . 5. For the past five years, the children have resided with the following persons at the following addresses for the following lengths of time: NAMR DanielL. Wilson ADD!3ESS 620 Belvedere Street Carlisle, P A DATES July 1999 to present - , _ L w A~' _ " ~ L.., ':"'.J, ,Li NAMR DanielL. Wilson A DDRRSS 211 West Ridge Street Carlisle, P A DArns June 21, 1999 to July 1999 Daniel 1. Wilson Sharon M. Wilson 211 West Ridge Street Carlisle, PA January 1995 to June 21,1999 6. The natural mother of the children is Sharon M. Wilson who resides as foresaid. She is divorced. 7. The natural father of the children is Daniel 1. Wilson who resides as foresaid. He is divorced. 8. The relationship of the Plaintiff to the children is that of natural Father. The Plaintiff currently resides with the children. 9. The relationship of the Defendant to the children is that of natural Mother. The Defendant currently resides with her boyfriend. 10. The Plaintiff has no information of a custody proceeding concerning the children pending in any Court of this Commonwealth. 11. The best interest and permanent welfare of the children will be served by granting the relief requested as the Plaintiff is better suited to provide a stable environment to foster the children's well being. > . 12. The Plaintiff does not know of any person not a party to the proceedings who claims to have custody or visitation rights with respect to the children. WHEREFORE, the Plaintiff, Daniel L. Wilson, respectfully requests this Honorable Court to enter an Order scheduling the Parties for a Custody Conciliation. Respectfully su . . tted, ') ~ II - /-)y-.. Date: c:L . (/U viti homas S. Diehl Attorney for the Plaintiff 401 East Louther Street, Suite 103 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX , ~ '.' " ~~ I , ' VERlFICA nON I verifY that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904, relating to unsworn falsification to authorities. /J.ut:K~ DANIEL L. SON, P amtIff >- c,.. <t 1---'" ~~8 ~~]:~~ =::1' c:.~ (':~ lJ.~1 u.. \8 (") f':: z ~:} <C (~)::=; C)~ (~3 3';&? ]Z cr,:z /Ju.J -.--,-,-CL ~?: ::-J (.) cry t'~~ .;t. . \ ~ RJ \t) . f2 I ~~ ~; ~~ LAW OFFICE OF Thomas S. Diehl 401 East Louther Street, Suite 103 Carlisle, Pennsylvania 17013 fEB 1 6 2000 , ,", / \.' Telephone (717) 240-0833 , FAX (7i7) 240-0893 ... APR 1 4 200Q/)P DANIEL 1. WILSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW SHARON M. WILSON, Defendant NO. 2000-859 CIVIL IN CUSTODY COURT ORDER ~ AND NOW, this IS day of April, 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, DanielL. Wilson, and the Mother, Sharon M. Wilson, shall enjoy shared legal custody of Tabitha M. Wilson, born January 21, 1993 and Kristen M. Wilson, born August 14,1994. 2. Mother shall enjoy periods of temporary physical custody of the minor children as follows: A. On every two months for a period of eight (8) days, the time frame to be arranged between the parties. B. For a period of summer vacation to be two (2) weeks at the beginning of the summer and three (3) weeks at the end of the summer, the time frames to be arranged between the parties. C. At such other times as the parties may agree. D. The parties shall alternate major holidays to include New Year's Day, Easter, Memorial Day, July 4th, Labor Day, Thanksgiving and Christmas. The parties shall work between themselves to arrange the alternating holiday schedule. Mother have custody on Easter of 2000 with the parties alternating thereafter. 3. The parties may modifY this scheduled as they agree. However, absent an agreement between the parties, this schedule shall control. 4. Mother shall incur all expenses with respect to transportation of the minor children between Pennsylvania and Florida when Mother is exercising custody in Florida. " " L .., ": " 5. Either party may petition the court to have the case again scheduled before the Custody Conciliator in the event that party desires to modifY the custody order. Sharon M. Wilson 1278 Monticello Drive Daytona Beach, FL 32119 ~o ~,O ~,\ '? A--+- cc: Thomas S. Diehl, Esquire " ,'l'-' I'. ~ DANIEL 1. WILSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW SHARON M. WILSON, Defendant NO. 2000-859 CIVIL IN CUSTODY Prior Judge: CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: I. The pertinent information pertaining to the children who are the subject of this litigation is as follows: TabithaM. Wilson, born January 21,1993 and Kristen M. Wilson, born August 14, 1994. 2. A Conciliation Conference was held on April 6, 2000, with the following individuals in attendance: The Father, Daniel 1. Wilson, with his counsel, Thomas S. Diehl, Esquire; and the Mother, Sharon M. Wilson, who appeared without legal counsel. 3. The parties agree to the entry of an order in the form as attached. thy lOb ATE fdlt.~ Custody Conciliator .; ~-, - ~" ~,- .., .. '" .. ~>(';:-T;Ct .., ~-: -!,~:>KJ1AFlY :~;ri ?,;);:'I I >] ,~>U !,_L: j' . ," 'I' "? i'~1 j l . U...- Cui\;; ~Ej~;l,.,':~\iU COUNTY i:'E.:~NSYLV!\I\il!\ , ~ ,1lIl~__~ "-- --'-. -''',-' JUN 0 72001/P SHARON M.WILSON, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : Crvn.. ACTION. CUSTODY : NO. 99- a Crvn.. TERM . a=-85J : IN CUSTODY DANIEL 1. WILSON, Defendant ORDER OF THE COlmT AND NOW, this 8"'" day Of~ lcN't, 2001, upon presentation and consideration of the within Petition is is hereby ORDERED AND DECREED as follows: 1. SHARON M. WILSON [ hereinafter referred to as "Mother"] and DANIEL 1. WILSON [hereinafter referred to as" Father"] shall have shared legal custody of their children, Tabitha Michelle Wilson, born January 21, 1993 and Kristen Marie Wilson, born August 14, 1994. 2. Mother shall maintain primary physical custody of the children with periods of temporary physical custody belonging to the Father as the parties agree. 3. The parties shall have alternating physical custody of the children during the holidays as such mutually agreed times as the parties deem proper. 4. Transportation of the children shall be borne by the Father. This specifically includes and airfare necessary to transport the children. 5. The parties will keep each other advised immediately in the event of serious illness or medical emergency concerning the children, and shall take and necessary steps to ensure that the health and well-being of the children are protected. During such illness or medical emergency, both parties shall have the right to visit the children as often as he or she desires consistent with the proper medical care of the children. 1 c ,-, ,-.", " . ,- '-'1(; 6. The parties shall not do anything that may estrange the children from the other party, oruyure the opinion of the children as to the other party, or hamper the free and natural development of the children's love and affection for the other party. BY 2 . . '. " "........ , '\ ,., ~ "Fl'~E t.: t't'y"U"" -,v ,. ,";.,.,.:' ',~, 'O"'^'RY OF -: .. , .'~ ~~Ul\L it\! 0\ JUN - (3 Pl"\ 3: 0 \ CUMSEHU\ND COUN'TY PENNSYLVANIA ~""I'""'!"" "",'","'" . _l!!IlIfflI"!_~~",," , ~""-:"-^ -,'", "".. :"'I,~' '~ .^ ,. , - ~,! " " .. SHARON M. wasON, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLANlA v. : CIVlL ACTION : N099- : ~-~S'1 : IN CUSTODY - CUSTODY CIVlL TERM DANIEL L. WILSON Defendant ClTSTODY STIPllT.A nON AND AGRF.F.MF.NT TIDS AGGREEMENT AND STIPULATION entered into on the day and year hereinafter set forth, by and between SHARON M. WILSON, hereinafter referred to as "Mother" and DANIEL L. WILSON hereinafter referred to as "Father". WHEREAS, the parties are the natural parents of Tabitha Michelle Wilson, born January 21, 1993, and Kristen Marie Wilson, born August 14, 1994; WHEREAS, Mother and Father are presently Divorced. WHEREAS, the parties wish to enter in an agreement relative to custody and partial custody of the children: and NOW THEREFORE, in consideration of the mutual covenants, promises, and agreements as hereinafter set forth, the parties agree as follows: 1. Mother shall maintain primary physical custody of the children with periods of temporary physical custody belonging to the Father as the parties agree. 2. The parties shall have alternating physical custody of the children during the holidays at such mutually agreed times as the parties deem proper. 3. Transportation of the children shall be borne by the Father. This specifically includes and airfare necessary to transport the children. ,-, ,.- '~~"- ,';"1..... ",' ~ ' ~ . 4. The parties will keep each other advised immediately in the event of serious illness or medical emergency concerning the children, and shall take any necessary steps to ensure that the health and well-being of the children are protected. During such illness or medical emergency, both parties shall have the right to visit the children as often as her or she desires consistent with the proper medical care of the children. 5. The parties shall not do anything that may estrange the children from the other party, or injure the opinion of the children as to the other party, or hamper the free and natural development of the children's love and affection for the other party. 6. Any modification or waiver of any of the provisions of this Agreement shall be affective only if made in writing and only if executed with the same formality as this Stipulation and Agreement. 7. The parties desire that this Stipulation and Agreement me made an Order of the Court of the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over the issue of custody of the parties minor children who have resided in Cumberland County for more than six months. 8. The parties acknowledge that they have read and understand the provisions of this Agreement. Each party acknowledges that the Agreement is fair and equitable, and that it is not the result of duress or undue influence. 9. This agreement shall take effect July 1, 2001. '. ,- - ~. ,_ d - . . . , , i~ ,'. IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms hereof set forth their signatures the day and Y..:J:::tiOned. <0 Dated: 05 -I J - :20<:;1 .;1J'? ~ WW;;;~ D L 1. WlLS~ Dated: sf 2 del ,,- ",~,,' ~ " " J.,,,;; ~. , ," .. ~ COMMONWEAL1H OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS On this d.5 dayof ~ , 2001, before me, the undersigned officer, personally appeared DANIEL L ON known to me { or satisfactorily proven} to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Ck.n I tt. rY) Jcto...u..b Notary Public NQTARIAI..SEAL ANNETTE M. STAUB. NolllIY Public BolOllg\\ of CalI\8le. CoIl~ ~ MY ~T.~n EllpIr88-.... STATE OF FLORIDA COUNTY OF y"lu.s:t>... :SS On this I' K day ofl14.-'1 ,2001, before me, the undersigned officer, personally appeared SHARON M. WILSON known to me { or satisfactorily proven} to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ,#:&.:.\'~\ Pwuast.1IW1 C2 .. '" ~.......'"""'- , ;.. .: iOctDb8r 18.1!OO1 . 0. ~ f1lti,iIi.:&' ___'''''''''''''.\!lll. &......_J Notary Public liiBW""O .,j '. iL'~"', ,~' u~_ "- '" ""-'-"'"lllilIkiIlilijliWJjjP- ~ ',"'""ill,.''' '"" " ~ .' (") 0 0 C -r, ;!';: '- ...-1 -UU) c:: ~T: 1T1,'P % ;'-:1:-TI -y-, .' r ~_k I . ~35!. w~ 0'> -<;2:: ::,1j~:1; !;2'O ;0. ~o :x b]J 2(") 58 9? om z """ ~ =<! w -< ~ ,"^ ^~ ~ ~ -." W,"~~ .