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Home My WebLink About00-01194 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DORIS J. DUNN, vs. NUMBER: (JCf:X)- \ \ q 4- fl ;,;1) T€J\fY\ TERANCE D. GERNER, Defendant IN CUSTODY ORDER AND NOW, this ----'a- day of j~ , 2000, upon consideration of the within Motion, Stipulation, and Complaint, it is hereby Ordered as follows: 1. It is the intention of the parties and the parties agree that they will share joint legal custody of their minor child, CHRISTINA MARIE GERNER, born October 2, 1982. The parties agree that major decisions concerning the child, including, but not necessarily limited to, the child's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the child's best interests. Each party agrees not to impair the other party's right to shared legal custody of the child. Each party agrees not to attempt to alienate the affections of the child from the other party nor to permit any third person to attempt to so alienate the affections of the child from the other party. Each party shall notify the " :1 II (II ,I' 'I I II y 'f '~'''\, ~^ ,.'", "'~,~,."~"""''')'e~",,,! ,~,~ ~""'_~ -, ~, "">.,,.. _ "'_" _~''''''''"''''''"''''?' ,,. ,~, '_~'''- -,_ ,_~, .. ~ '---,--, ''''___''''',,' "'" _c__"~.c__,,,,-,_,__,__O,'~~""""~',", "_~"""",,,,,,,_,_,>,,,. ,_ other of any activity or circumstance concerning the child that could reasonably be expected to be of concern to the other. Day-to-day decisions shall be the responsibility of the party then having physical custody. With regard to any emergency decisions which must be made, the party having physical custody of the child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that party shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any il 1 I I II ii 'I I reports given to either party. 2. Mother, DORIS J. DUNN, shall have primary physical custody of the subject minor child. 3. Father, TERANCE D. GERNER, shall have liberal rights of temporary physical custody of the minor child as the parties shall from time to time agree. 4. That jurisdiction over this custody matter shall be and remain in the Court of Common Pleas of Cumberland County, Pennsylvania. /..--.... A' " p- BY THE COUR,,( j ,/ ./ ~' '~ 3-7-00 RK3 ;,j I .1 " , " i .l ,~ ~ '. ii :1li -- I ' ", ~",_t""""",,_<~ .. ,,' ~_,_..." J. , ""'p".,-~,,"!-'-~'," , " ~ ",-,.~~, "'~." '_'C_~O '~5'"'_'""_ "~ -FC",. ,- '-', , ,--. ,!' . _~,C - ..too '. .:iU,JlL J,.,....~.. ,-.-' . ",_ n,_".' , ....... ,'J", '" ,~, ..- ,. ...'...,.... ..'" .. .- . "~I' ,-n r",;:~$'r: t. LCV-V1 \ IV\.. n~ .,.~< ;.cl,;\,.\('.Hri'iI\R'i '.../1 ',; l'_ '" ,," I ,J '-.J $\) \'IJ\\\ ~ 1 p,\'\ 9: Sl C\JN\8tJ(J'~~D CO\J~\'l '?E.~~S,{LVN~\J\ ... '...... , 5. That the parties desire that said Stipulation be entered as an Order of Court. WHEREFORE, Plaintiff respectfully requests that Your Honorable Court enter an Order pursuant to the attached Stipulation. Respectfully submitted /'t ~ --L r ,,""'" CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiff jj :1 !i Ii " 11 !i Ii ~'I ' , .". ".~__, , .~, ' ",",~-..,. ,--~~ ~~ ,,-<~.. .~, ~. ". .---~~- ._~" "., ", I I I i , ! ! I; ..~ _ I DORIS J. DUNN, IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NUMBER: dCXX) - \ \ q 4 C;,; 0 TtJ101 Plain tiff vs. TERANCE D. GERNER, Defendant IN CUSTODY MOTION NOW COMES the Plaintiff, DORIS J. DUNN, by and through her attorney, Charles E. Petrie, and respectfully represents as follows: 1. That Plaintiff is DORIS J. DUNN, an adult individual currently residing at 115 West Vine Street, Shiremanstown, County of Cumberland, Pennsylvania. 2. That Defendant is TERANCE D. GERNER, an adult individual currently residing at R.D., Coudersport, County of Potter, Pennsylvania. 3. That Plaintiff and Defendant are the natural parents of a minor child, CHRISTINA MARIE GERNER, born October 2, 1982. 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. __'"r__,fl,~_" ____"_~co .~, ,'_.~. '," ,- < 0' _,'_~_"'~' . >,- ~.~~ ^,-" "' -'."-' . - , -' '< - ' - -'" - ".,,-,'~ " ~- -- DORIS J. DUNN, Plain tiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. NUMBER: d..CX:o- \ \ qy. Cw;QT01fY\ IN CUSTODY TERANCE D. GERNER, Defendant COMPLAINT FOR CUSTODY NOW COMES the Plaintiff, DORIS J. DUNN, by her attorney, Charles E. Petrie, and respectfully represents as follows: 1. Plaintiff is DORIS J. DUNN, who currently resides at 114 West Vine Street, Shiremanstown, County of Cumberland, Pennsylvania. 2. Defendant is TERANCE D. GERNER, who currently resides at R.D., Coudersport, County of Potter, Pennsylvania. 3. Plaintiff seeks to have rights of primary physical and shared legal custody with respect to CHRISTINA MARIE GERNER, born October 2, 1982. The child was not born out of wedlock. The child is presently in the custody of Defendant, TERANCE D. GERNER. Since birth the child has resided with the following persons and at the following addresses: From January, 1995, until the present with Dad in Coudersport, Pennsylvania. The mother of the child is DORIS J. DUNN, who currently resides at 114 West Vine Street, Shiremanstown, Pennsylvania. She is not married. - -~;"'C"'_?I-~ ,~~--,-'_,,,,!,_,,,,_._~.,_~ ___~,,,,~,,,,,,,,,,,,,.,_,,,,, _.._ ~ ,~__<, ~",_~=__=, _ __ ~ _ .....m. _" N ","~ ,~ <" -- ,,, The father of the child is TERANCE D. GERNER, who currently resides at R.D., Coudersport, Pennsylvania. He is married. 4. The relationship of the Plaintiff to the child is that of mother. The Plaintiff currently resides alone. 5. The relationship of the Defendant to the child is that of father. He currently resides with the child and with his wife, Virginia. 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 and shared legal custody in Plaintiff. 8. Each parent 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. I' _ ",0"_""""""",,,,, ,.," h'",'_ p"",,,",,,}--:" ,.",.~"- ~_'''':''''~_~'_'' '__'~d C('"_._, . - -, -~ ,-" _'N __~_=,_."_~,_ ,_,=w. ", ,. ".'-', , . 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 and shared legal custody in Plaintiff. Respectfully submitted, ~k.~e~ CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiff "'-,,-,,~ ~-~ ,- ~,--"' - -~" - , , oS ,_~ ---~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I verifY that the statements in the foregoing Motion and Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. OJ,cilj,ftlO DATE , ~A "''''-<> ~cJ'Ln",,~ DORIS J. DO: N ~J_m _ "~N_ ,_ ,_,_ _~_ ,_ _" _ " ,-" ~ - . .-~~, . ~ ~. -~.- Plain tiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NUMBER: ~-I;q'-f Ci,;D 70,rn DORIS J. DUNN, vs. TERANCE D. GERNER, Defendant IN CUSTODY STIPULATION AGREEMENT, made this dPd day of Ii'~ , 2000, by and between TERANCE D. GERNER, hereinafter referred to as "Father;" and DORIS J. DUNN, hereinafter referred to as "Mother;" WITNESSETH: WHEREAS, the parties hereto are the natural parents of a minor child, CHRISTINA MARIE GERNER, born October 2, 1982; and WHEREAS, the parties have reached an agreement concerning the issues of custody and desire that this Stipulation be entered as Order by the Court of Common Pleas of Cumberland County, Pennsylvania; NOW, THEREFORE, intending to be legally bound, the parties hereby agree as follows: 1. It is the intention of the parties and the parties agree that they will share joint legal custody of their minor child. The parties agree that major decisions concerning the child, including, but not necessarily limited to, the child's health, welfare, education, religious training and upbringing shall be ^>" - -j' .- '~""-~,~,,,,,"~,, "-~ _, " '-,~,,, ,~c'-' '_"'._"' _ ""~ -'-'-, -. -- ~ -,' ,-,- --'~'~~, ,. -~, . " ,-~ ~ - ~ "'~-"~<-~, . '-' ,. i ,i ! 1 j 1 l 1 ,1 1 i ,~ , i '~ >1 j ~ ) ] ,'< 1 :1 1 j I ] :'J ) ~j i i :j J 'I 'I " "j :1 !) 'I ,i , i made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the child's best interests. Each party agrees not to impair the other party's right to shared legal custody of the child. Each party agrees not to attempt to alienate the affections of the child from the other party nor to permit any third person to attempt to so alienate the affections of the child from the other party. Each party shall notifY the other of any activity or circumstance concerning the child that could reasonably be expected to be of concern to the other. Day-to-day decisions shall be the responsibility of the party then having physical custody. With regard to any emergency decisions which must be made, the party having physical custody of the child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that party shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party. 2. Mother, DORIS J. DUNN, shall have primary physical custody of the subject minor child. 3. Father, TERANCE D. GERNER, shall have liberal rights of temporary physical custody of the minor child as the parties shall from time to time agree. <_,_~_~, _". ~__>_"_".~" v, ...",~,. "_ ,,,?h_~_ ,0 _,., ,'~" -,~-, ,~^, -~'---"--'--'''''''''~'--' ,~= -~,.~- , . ;~ 4. That jurisdiction over this custody matter shall be and remain in the Court of Common Pleas of Cumberland County, Pennsylvania. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. ~~ ITNESS ~~~~L TERANCE D. GERNER ~U"l'J WITNESS --if tiA~4J .J1~ --- ----- DORIS J. DU' "<!,>.~,- I-r--- ~~ !II . - , -~'"~,=' ~ -- -.- '" 'I i 2 0 ~ 0 $: ::J: :d ""Or-n J.;a rnfn ......,., Z-n "" n1r" (l ~ Z$i: I v~-n cn~ N 1:,0 ~ 1= (J1 -<2'; J j kO c:.141, 1;b 0 eo :J:>o ~~ ~o ::II: ~ -0 \U f() :Pc: om ()() Z ~ >3 =< i'.) ?-' "R. .0 -< +- -D 'P ~ llf - ~" - .~_.",,.ln ~"~"~- ~ ~~ _m~~~I~1!~'l'l'Wtll'i!"\'li!~~,Jl'J1;j ~~Ii!'mIlI~"~~