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Home My WebLink About00-01047 . ~. . , ",'-, ,'" "' , '~" MICHAEL HOWARD, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY,PENNSYL VANIA C;u: L ~., : NO. ~QX> ~ 101../7 KAREN HOWARD, Defendant : CML ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before ~r\ ::;,,~ f\~ the Conciliator, on the \3 day of ~r:.... \ ,2000 at g', 3 b o'clock --.CL.m., at t~i;~c~land ~~ ~~tj~:~\,~~ Cllrlisle, Pennsylvania, for a Custody Conciliation. 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. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. BY THE COURT: Date of Order:.-2ldt \ \) \) By: cmnS'('\~, ~uNltio~-, Custody Conciliator C t:~0 YOU SHOULD TAKE TillS 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 LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LffiERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ;) ";;) f'. C) tJ C) ro:2 9 -c{j ~ -,:)9 -N) '~ ., CD .-< ';} :~s: :1 i CUtliJi..:('L/\ t,;r')!ji\Tt ;]C-,r\!;\I'~\"J Vt ;\j'I:'I': " ." ivll.....,"'\. ',,"1. w<to/1_~z4~ 51~ frt~ ~ df aldI ~ ~ ~ --;; a:If ~~ "r ~~....- ~,!,..,.,."". =~'" , . . , . i~=<==""-~~'-' ^, ~~._~~, ,", !ry<~~~,1J!J?:'","--, "rJc - '~ .1. .l1lll.i:i:li1~i!lllllU!''-! MICHAEL HOWARD, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY,PENNSYL VANIA ; NO. clDtrtJ- /0'17 ~ ~ KAREN HOWARD, Defendant : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Michael Howard, an adult individual who resides at 12 Mount alIen Drive, Cumberland County, Mechanicsburg, Pennsylvania, 17055 2. The Defendant is Karen Howard, an adult individual who resides at 14 Pocono Drive, Cumberland County, Mechanicsburg, Pennsylvania, 17055. 3. The Plaintiff seeks shared physical and legal custody of the following child: Name Date of Birth Age Joshua Howard 12/12/82 17 The child is presently in the physical custody of his mother, who resides at the address above. The child was born in wedlock. 4. During the past five years the child has lived with the following persons at the following addresses: a. 14 Pocono Drive, Mechanicsburg, P A, with both parents and sibling b. 14 Pocono Drive, Mechanicsburg, P A with Mother and sibling - I ^~~~IIjj~L" 5. The Mother of the child is Karen Howard, currently residing at the above address. Her marital status is separated. 6. The Father of the child is Michael Howard, currently residing at the above address. His marital status is separated. 7. The relationship of the Plaintiff to the child is that ofF ather. Plaintiff currently resides alone. 8. The relationship of the Defendant to the child is that of Mother. Defendant currently resides with the following persons: Name Relationship Joshua Howard Alisha Howard Son Daughter 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. Plaintiffhas no information of the custody proceedings of 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 child or claims to have custody or visitation rights with the child. 9. The best interest and permanent welfare of the child will be served by granting the relief requested because: a. Plaintiff has shared in the caretaking of the child and has provided the child with consistent and loving care. ,) ~'. ,I... ~WIi.: b. Plaintiff is willing and able to continue to provide proper care arid supervision of the child. c. Plaintiff can provide a stable and loving environment to the child. d. The 17 year old child desires to live with each parent an equal amount of time. 10. Each parent whose parental rights of the child has not been terminated and the person who has physical custody of the child has been named as parties to this action. There are no other persons who are known to have a claim or right to custody or visitation in this matter. WHEREFORE, Plaintiff requests the Court to grant shared legal and physical custody of the minor child to the Plaintiff. Respectfully Submitted, ~.~ L ~L~ Marianne E. Rudebusch, Esquire 845 Sir Thomas Court, Suite lIB Harrisburg, P A 17109 (717) 657-0632 Id. No. 63522 Dated: :J-( '2-3 J 00 I ~ ~ 1 . . . I -iIIlIl'iW MICHAEL HOWARD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY,PENNSYLV ANIA v. : NO. KAREN HOWARD, Defendant : CIVIL ACTION - LAW : IN CUSTODY VERIFICATION I verify that the statements made in the foregoing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. By: MICHAEL HOW Date: ;;< --- fJ.:J - DZc::c<:.l ~~ ~~h~ ..a ~ ~~~a ....... ~ \ I ~ '<. ~ ~ J n ~~:~ " ~~,'') . - '.---'. _.". ?-:, C.'." r- :::'-~; --:' ~..':1 :;~ .t:.~ -< -'. . ~-:-J '.Ji Q j'...) --, ..i' , ~ 0 . IJ,I, " ._1_", > ", J -. MICHAEL HOWARD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY,PENNSYLV ANIA v. : NO. 2000-1047 KAREN HOWARD, Defendant : CIVIL ACTION -LAW : IN CUSTODY PROPOSED ORDER FOR CUSTODY AND NOW, this ~ day of ~ f t; I , 2000, upon review of the attached Custody Stipulation ofthe parties, it is hereby ORDERED as follows: I. The parties shall equally share physical and legal custody of Joshua Howard, born 12/12/82, as defined in Custodv and Grandparents Visitation Act, 23 P.C.S.A. Section 1001, et seq. 2. The parties shall equally share physical custody of Joshua with a schedule to be agreed upon by the parties taking into consideration Joshua's wishes. 3. In the event of any serious illness of the Joshua at any time, any party then having custody of him shall immediately communicate with the other party by telephone or ~ ,,- \.J,. -D\:~~\CE i~',:\nT/\FN 00 r~.P'? z C\ Ft\ t.:: 0 C..."..' .. ,. ".')11-" \ )\\,.'1....;,- ,~""l ,:""'.:1) ( ,; Ii "l I ...... ,.....,_'.. 'J '<' ...,.....-"~ ., PENNSYL\fj~N\/\ _,l'II!IllYil\tllIlIIll_ ''l'' ~~ ~JI!IIfflli t>A !""""'~ ~lI!t!m_ - . , -<I.......;".~ "" any other means, informing the other party of the nature of the illness. During such illness, each party shall have the right to visit Joshua as often as he or she desires, consistent with his proper medical care. The word "illness as used herein shall mean any disability which confines Joshua to bed under the direction of a licensed physician for a period in excess of forty-eight (48) hours. 4. The parties shall exert every reasonable effort to maintain free access and unhampered contact between Joshua and each of the parties, and to foster a feeling of affection between Joshua and the other party. Neither party shall do anything which may estrange Joshua from the other party, or injure his opinion as to his mother or father, or which may hamper the free and natural development of his love and respect for the other party. 5. The parties agree to submit this Stipulation to the Court and have it entered as BY THE COURT: ~..,~J Ii:,.,) ~1rv;;O ~~-JO' :) ~~ an Order of Court. tIk J. , ,I ~ ~. - Rii&, MICHAEL HOWARD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY,PENNSYLV ANIA v. : NO. 2000-1047 KAREN HOWARD, Defendant : CIVIL ACTION - LAW : IN CUSTODY STIPULATION FOR CUSTODY THIS AGREEMENT is made and entered into between MICHAEL H. HOWARD and KAREN HOWARD, hereinafter referred to as Father and Mother. The parties were married on 1/13/79 and there are two (2) children bom oftheir marriage, to wit, JOSHUA HOWARD, born 12/12/82 and ALISHA HOWARD, born 8/25/80. As a consequence of disputes and unhappy differences, the parties have separated. The parties desire to make arrangements in connection with custody of their minor child, JOSHUA HOWARD. It is therefore agreed: 1. The parties shall equally share physical and legal custody of Joshua Howard, born 12/12/82, as defmed in Custody and Grandoarents Visitation Act, 23 P .C.S.A. Section 1001, et seq. 2. The parties shall equally share physical custody of Joshua with a schedule to be agreed upon by the parties taking into consideration Joshua's wishes. - ~- , I .;.-.....~~, 1li<1il;i.i,' 3. In the event of any serious illness of the Joshua at any time, any party then having custody of him shall immediately communicate with the other party by telephone or any other means, informing the other party of the nature of the illness. During such illness, each party shall have the right to visit Joshua as often as he or she desires, consistent with his proper medical care. The word "illness as used herein shall mean any disability which confines Joshua to bed under the direction of a licensed physician for a period in excess of forty-eight (48) hours. 4. The parties shall exert every reasonable effort to maintain free access and unhampered contact between Joshua and each of the parties, and to foster a feeling of affection between Joshua and the other party. Neither party shall do anything which may estrange Joshua from the other party, or injure his opinion as to his mother or father, or which may hamper the free and natural development of his love and respect for the other party. 5. The parties agree to submit this Stipulation to the Court and have it entered as an Order of Court. ~., --" . I .....; a3/2~/2eea 17:56 717-657-1512 MARIANNE E RUDEBUSCH PAGE 84 ... v .j, IN WITNESS WHEREOF, and intending to be bound hereby, the parties have signed and sealed this Agreement on the /J dday of ~ ' 2000, at Harrisburg, Pennsylvania. ,~y4wtd2 N HOWARD COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF DAUPHIN On this the 1J'~day of ~ ,2000, before me the undersigned officer, personally appeared Karen Howard, satisfactorily proven to be the person whose name is subscribed to the within instrument, and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seat NO~/~~ Notarial Seal Kelly S. Baker, Notary Public South Middleton Twp., CurnberIend County My Commission Expires Feb. 7, 2004 Member, PennsylVania Association 01 Notatles . .'='. "'!li>-,' COMMONWEALTH OF PENNSYL VANIA SS. COUNTY OF DAUPHIN On this the /;pLdaYOf 11m.: ( , 2000, before me the undersigned officer, personally appeared Michael H~tJsfactonly proven to be the person whose name IS subscribed to the within instrument, and acknowledge that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. ~,~~ Not Public NOrIlllll\l &tIlL lIA..... A. .as.wAlC....., PublIc ........ PaldoII Twp., DoliIplIln Coutity, PA ,.,., ~ bpi"" Sept. 2.200:! . ,'''_' .,.:"'..""""'.,..,...."".,....",..",__~,""tt!:,'"">.,.,,,,'''."'''. 3 .~ Lt:. (- :-Z (""; 3$ . '"~I:':-r-' L'_ ::"-:1::3 ,-?, ~';:; r- /' ~:.) :);;-.'.: (~:'~ z r< uJ c .":1::.1- '-~ .~ .? .? =5 C) C) () MARIANNE E. RUDEJBUSCH AlTORNEY AT LAW 845 Sir Thomas Court Harrisburg, PA 17109 (717) 6~7-0632" Fax: (717) 657-1512 APR 1 9 200rUJ ., "'<c;' APR 2 ,~ 20~ ~ ~ ji;' \ c ';1 MICHAEL HOWARD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-1047 CIVIL TERM : : CIVIL ACTION - LAW KAREN HOWARD, Defendant . . : IN CUSTODY CRDER OF COORT AND ~, this 13th day of April, 2000, the Conciliator, being advised by Plaintiff's counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction. The Custody Conciliation Conference scheduled for today, April 13, 2000 is canceled. FOR THE COURT, Dawn~ Custody Conciliator ill O;J 0 ~ ~ r. c~ 1\0 l, ') , , I,', .~ C'UI!;/:~":';":[':; i ':---;li Ji\IT'1 \ ~_._, _..-',_ "",.. l PENI\)SYLV/,NI,". '" .. ~ ,~ _~,~~~~ ,.,,~ll'I!W~~~.'>>!ililRlJWU,lfj!fI{l!lll,-r"""~ ""7'-~ !,P~~f