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HomeMy WebLinkAbout00-02463 0' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . <Ii<li <Ii :f. . . w~ ,,)..-,. _ w .-\; ."d" ~ .. . . . <Ii;t;<Ii :f. <Ii IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF RANDY To. GOSHORN VERSUS VICTORIA E. GOSHORN, PENNA. No. 00-2463 CIVIL TERM PT,liINTTl"l" DF.FF.NnAN'I' DECREE IN DIVORCE AND NOW, ~~ "l...?" , --wti! iT is ORDERED AND DECREED THAT AND R.'\NDY L. COSRORN , PLAiNTIFF, VTr.'I'ORTA F. GOSHORN , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURiSDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHiCH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE . . . . . . ATTEST: OTHONOTARY <Ii <Ii'" :t::f.:t. . . . . . .. . J. , -~,. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , " ~ , '" .... ~}..-; . " ' .. " . .~", ';;';ijo /O-d0<ZJ ~ ~~~4~ ~~-w ~~~4- d:r~ , .~ .~~!!iI!t'1 ~_;~~ """_ _ ......_ _. "'l''''~~ "_. ^ ., . - ~ , "';"i- RANDY L. GOSHORN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION VICTORIA E. GOSHORN, Defendant NO. 00-2463 CIVIL IN DIVORCE PIlAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for Divorce: Irretrievable breakdown under 5 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified Mail served on Victoria Goshorn on May 3, 2000. 3. Defendant executed the Affidavit of Consent required by 5 3301(c) of the Divorce Code on August 10, 2000. Plaintiff executed the Affidavit of Consent required by 5 3301(0) of the Divorce Code on August 8, 2000. Affidavits of Consent were filed on August 29, 2000. 4. There are no related claims pending as property issues were resolved by signed and filed Property Settlement Agreement. Page 1 of 2 - "__, .,je "0, 5. Date Plaintiff's Waiver of Notice in ~ 330l(c) Divorce as filed with the Prothonotary August 29, 2000. Date Defendant's Waiver of Notice in ~ 3301(c) Divorce was filed with the Prothonotary August 29, 2000. Law Office of Michael D. Rentschler, P.C. Dated: ~~~/2-cerv :~~~ -? MICHAEL D. RENTSCHLER, ESQUIRE Attorney for Plaintiff 1300 Market Street, Suite 200 Lemoyne, PA 17043 (7171 975-9129 Supreme Court ID No. 45836 Page 2 of 2 t;ji!mWl~MJtilil~I~~~.m;:~~~~~.W:~" ~~.~ ~~ o ~; ,JC.' ~'~l c.~ -,.. L:"", ;::;C~ 2: =< "~.o~, ^ -. '..' -," ~. .~ , c.") Cl .-:) ~,.) -; . t~) "';\ .., : ",J::' \;:) ..i;..:....; --,'"",, ", ! .:.C} :~~~ ~~:;:~ -,.... 5 -< --0 ~7 ::;) CP "\ - ',- . APR " 5lD8f1.P , .KAAJD'f L. ~slfC)RAJ Plaintiff : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION LAW V V/c:,jjIZIA J::. ~/(()fe~ Defendant . . : NO.OO-~'(63 CIVIL 20 : CUSTODYNlSITATION ORDER OF COURT AND NOW, this ~ day of ~ I' ( , upon consideration of the attached complaint, it is her by directe Jhat th parties an? their re~ecy.'fe cOjJnsEll jlPp~ar before . Iv-- t , (I, . the concIliator, at !I" ~ ~~~ (~ ,he day of j\) \~ ' 20 DO ,at 3;3D A. M., for a Prehearing C stody Conference. At such confere ce, 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 the court, and to enter into a temporary order. All children age five or older may also 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: J&) 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 FOR BELOW TO FINS OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 . i ~, nn " -'. <' ~"",", -'~~-',~-> " " " "-'A~ ,_ '"'' -.- "~" -,~-,-, >'---'-' ">";''M (1('/ '-..'L i /(] D;,' I',' ..... .." i i i (:: :'J5 CUI :L.~.'l"! .,i" , ", d...' \, "L.r , .1 l' 1'\ In,. PENNSlil...\/'~F\jl,c{Ji\Jj r If-d~~O {}d. t?~/P~Z 4' ~ 'Jt~. nr:-~ ~ Y2ff -.t-dz#. ~~~#,~~ 1f -dJ Or:} ~<noo , . , ~~ ,-~':T ~ ""_'_'__~M~=~ ~,~_ _ l;nJW!IIl~glJlJ , l~~l"ii~l~il'",~~~ij, ,""""'" - .~-,~ .. .!li-~-' ", RANDY L. GOSHORN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. CIVIL ACTION : NO. 00- ::l4W Ci(,)(,('7-~ : IN DIVORCE VICTORIA E. GOSHORN, Defendant NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, P A 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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 LEGAL HELP. Court Administrator Cumberland County Courthouse 1 Courthouse Square, Fourth Floor Carlisle, P A 17013 (717) 240-6200 - ~-"._;rl. , RANDY L. GOSHORN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : CIVIL ACTION VICTORIA E. GOSHORN, Defendant : NO. : IN DIVORCE NOTICE OF RIGHT TO COUNSELING You are one of the parties in the above-captioned action in divorce. By virtue of Section 202 of the Pennsylvania Divorce Code, it is a duty of the Court to advise both parties of the availability of counseling and upon request of either provide both parties a list of qualified professionals who provide such services. Accordingly, if you desire counseling a list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, I Courthouse Square, Carlisle, PA 17013-3387. Prothonotary ~ -"~ .-, , ~ ,~ - ,- - , ~"~.~--fr% \ RANDY L. GOSHORN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. CIVIL ACTION : NO. (td. .2'1(.. J {}WJ 1".u- VICTORIA E. GOSHORN, Defendant : IN DIVORCE COMPLAINT IN DIVORCE AND CUSTODY 1. Plaintiff is RANDY L. GOSHORN, a citizen of Pennsylvania, residing at 58 Subdivision Road, Newville, Cumberland County, Pennsylvania. 2. Defendant is VICTORIA E. GOSHORN, a citizen of Pennsylvania, residing at 122-B South Third Street, Lemoyne, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant are sui iuris and have been bonafide residents of the Commonwealth of Pennsylvania for at least six months immediately preceding the filing of this Complaint. 4. The parties are husband and wife and were lawfully married on June 19, 1999 in Cumberland County, Pennsylvania. 5. The marriage is irretrievably broken. 6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 8. The Plaintiff has been advised of the availability of counseling and of the right to 1 "~ - ~ -. . '.', ., request that the Court require the parties to participate in counseling. COUNT I Request for Divorce Due to Irretrievable Breakdown Under 3301(c) ofthe Divorce Code 9. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 10. The marriage of the parties is irretrievably broken. 11. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant i I.; I:: I' I may also file such an affidavit. 12. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, if both parties file affidavits to a divorce after ninety (90) days have elapsed from the filing of this Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 330l(c) of the Divorce Code. COUNT II Request for Divorce Due to Irretrievable Breakdown Under 3301(d) ofthe Divorce Code 13. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 14. The marriage of the parties is irretrievable broken. 15. After a period of two (2) years has elapsed from the date of separation, Plaintiff 2 ".~=>b"~ ~ , ~', :->1 :;. "- intends to file her affidavit of having lived separate and apart. 16. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, if two (2) years have elapsed from the date of separation and Plaintiff has filed her affidavit, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(d) of the Divorce Code. COUNT III Request for Confirmation of Custody Under 3104 of the Divorce Code 17. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 18. Plaintiff is RANDY L. GOSHORN residing at 58 Subdivision Road, Newville, Cumberland County, Pennsylvania. 19. Defendant is VICTORIA E. GOSHORN residing at 122-B South Third Street, Lemoyne, Cumberland County, Pennsylvania. 20. Plaintiff seeks partial physical and joint legal custody of the following child: Name Present Residence Age Dustin Edwards Goshorn 122-B South Third Street Lemoyne, PA 17043 14 months 21. The child was born out of wedlock. 22. The child is presently in the custody of Mother who resides at 122-B South Third Street, Lemoyne, Cumberland County, Pennsylvania. 3 ~, ~_d. ..' ~Jili-", i .' ., 23. Since birth, the child has resided with the following persons at the following addresses: Person Address Victoria Goshorn and Defendant's Mother and Father, Gloria Hoag and Tom Hoag 122- B South Third Street Lemoyne, PA 17043 Victoria Goshorn and Defendant's Mother Gloria Hoag 122-B South Third Street Lemoyne, PA 17043 24. The mother of the child is VICTORIA E. GOSHORN who currently resides at 122-B Third Street, Lemoyne, Cumberland County, Pennsylvania. 25. She is married to RANDY GOSHORN. 26. The father of the child is RANDY GOSHORN who currently resides at 58 Subdivision Road, Newville, Cumberland County, Pennsylvania. 27. He is married to VICTORIA GOSHORN. 28. The relationship of Plaintiff to the child is that off ather. 29. The relationship of Defendant to the child is that of mother. The Defendant currently resides with the child and the Defendant's mother. 30. Plaintiff has not participated in a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 31. Plaintiff has no information of another custody proceeding concerning the child pending in a court in this Commonwealth. 32. 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. 33. The best interest and permanent welfare of the child will be served by granting the 4 '" -~""'"""^ relief requested. 34. Each parent whose parental rights to 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 claim to a right to custody or visitation of the child, Consequently, no other persons will be given notice of the pendency ofthis action and the right to intervene. 35. Plaintiff desires to have reasonable and liberal visitation with the child and requests it because he is the child's natural father and it is in the best interest of the child that a strong bond between father and child be made. 36. Plaintiff has repeatedly requested to Defendant that he be permitted to have visitation with his child and Defendant has willfully denied him any visitation with his child. Consequently, Plaintiff requests compensatory "make up" days for those days he has been denied visits in addition to an Order giving him reasonable partial physical and joint legal custody of his child. WHEREFORE, Plaintiff respectfully prays your Honorable Court to grant minority physical and joint legal custody to the Plaintiff. Respectfully submitted, LAW OFFICE OF MICHAEL D. RENTSCHLER, P.C. ~~~~;;;:;~ / Michael D. Rentschler, Esquire Attorney for Plaintiff Supreme Court J.D. #45836 1300 Market Street, Suite 200 Lemoyne, PA 17043 (717) 975-9129 5 ,.<', , - "~ . " ~" .n~l-, ~ . VERIFICATION I, RANDY L. GOSHORN, verify that the statements made in the 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. ~~;L >>~ RANDY L. GOSHORN, Plaintiff .',[, ."" , """'w. . I_!~&i!iw::.bl~~ 7J(J \l::. r: :& l 6" '.J 8,,~ _ '0"~ ,~ _ ~ ". _ '- -". '^. ,. ~ ., , ". ~. --' '~'~'.""^' " ~Pv' ~ 8 0 ~ h ~ d~~&'~ , I G ~ 1 , ~~ 1-~ 9 , "," "w, ,~~, -VCi'J ~~, :: ~tj 2~C} ~~; , o 0 S C} ~ ~ ;-1 -< o 'T1 - , "'--," , , ~' ::::) {r. ... ; . . . ~ r " ~, P/:':OoF' 6P S~()rG6 Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery 'IS desire((. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Add~ed to: C. Signature D. Is delivery address different from item 1? If YES, enter delivery address below: o Agent D.,Addressee DYEis o No x V C"7"C:>.e-- A .:?; Ws4/.i?V /.;J.~e s.~ ~ .&:-rr- /:1- //070 2. Article Number (Copy from se 3. Service Type .:t!:."'Certified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes PS Form 381 j , Julii1'999 " ;',~, ,~ - " _ J~ '. """~ ~-~~' "~~:<o'~---fU, . "-~ -~, .-. , ~- .-,.~. ~ 1\1-;, I I 0 C) c:: c::; ~ 0 we] n nlrTl --I Z::o L~~ U) ~2~ 0:--"-' .- C'-) , ~! -' :"D C-.J -< . ~.,." - , RANDY 1. GOSHORN, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. CIVIL ACTION VICTORIA E. GOSHORN, Defendant : NO. 00-2463 CIVIL : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under 9 3301(c) of the Divorce Code was filed on April 19, 2000 and was served upon the Defendant on or about May 3, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint and the date of service of the complaint on the Defendant. 3. I consent to the entry of a fmal decree of divorce after service of a Notice ofIntention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming fmal. I verify that the statements made in this Affidavit are true and correct and I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. Dated: '1/1J" loa -li,A2~ -;L .b~ RANDY 1. GOSHORN, Plaintiff \'..~~"-,,. ,~~-,-,,~ ,c' .i-._I!Ift"=" ". "!lIV)r......~ ..."" "-~ -,<- -." ~.~.= - ~,~ _.~ ~- - -~ ~---"" ,. -~ - ~ ''''" Ii 0 Cl 0 c: 0 -II ~ "., --of "'" u!;D C;) :;:~=: morn Z::J::; r'.) :~~ Z~: C/) :? u:; ~r-, ;".-- ~~"' :t> ~~~ )o~ ::t: ~C j;; Ci ~9 ;''''~f 11 'c: -=1 :z => )> -j .1""' :q -:. -<c . "' " RANDY L. GOSHORN, Plaintiff vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION VICTORIA E. GOSHORN, Defendant : NO. 00-2463 CIVIL : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary . I verifY that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. S 4904 relating to unsworn falsification to authorities. Date: $ / ~ /0 0 ~~~~ -i J;~ RANDY L. GOSHORN, Plaintiff 00 , _ ..60-0' Jm~I:IW!I!iIll~'" l!~~~~tb.ll:I!iM!~~-'~~ ~~=.~ ,"m " _:'J ~ - ,~-" o u~ mr-.,.., 2'-'-' .....,.. -::,1,/ 055-,. ;:::; :<', c.. c~ ~ - ."'c' :z:c~- 5>c! 2 :< o a .~ o " -c:J ::; -,'~ r- "~~23 <)(1 ..=j~J ~.:~ t;.g orn 5;1 ::0 -< (;;) r'Cl \1:1 ~ L-!} <::> .;:- . ~~J ,_. ,. , . RANDY L. GOSHORN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION VICTORIA E. GOSHORN, Defendant : NO. 00-2463 CIVIL : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under S 330I(c) of the Divorce Code was filed on April 19, 2000 and was served upon the Defendant on or about May 3, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint and the date of service of the complaint on the Defendant. 3. I consent to the entry of a final decree of divorce after service of a Notice ofIntention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and 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. Dated: <6 ) / 0/ 0 6 rz l;;~ r=: ~. VICTORIA E. GOSHORN, Defendant ~lII'lIl!dlIliDlll___<Mm\lW~~~ ~'lllilI~fiI~ liil:iiI.iiil~~j "...... .= ~~~~I '.0 s;: ~- -053 rnrTl Z:J:J Zr;: ~''':;, ~cj ~~:: ";Pc 7"': ~ c::> o 'I .,.) -Yl ~ ',;3 r-.., v;) p-::: -.---, rll . ~:.;C? r'; ) ~~lr-:} -,-- " i~~5 ;?, .,",..\.... c:}~n -; -~ :0 ~~ ~-: --""" cD :::> en t ^ 'I . . . . ~ RANDY L. GOSHORN, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION VICTORIA E. GOSHORN, Defendant : NO. 00-2463 CIVIL : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. I consent to the entry of a [mal decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses ifI do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. c'S.A. g 4904 relating to unsworn falsification to authorities. Date: f6L/()/o() 'lJJ~A r-::. ~ VICTORIA E. GOSHORN, Defendant iDMi~~"" J~'''"'''''''< . . '~"Jii!~'~" .IIil.l! N_~ lilil't.l:lli~~~..w,-""17 ,~ ~-. =' -1IiilIIil ,-,~ ^ ~ '1'.1.1 !! , ;1 0 Cl c: <:::> 0 s: "~n "UC" 1> <h.l '11 ~; c:= Zfl; G') ~ill=.!:;l _To Zr"' 1'..) OJ -..."" 'cdT! ;::s;~' ',.0 -:--;-,"'0 ;<::0 = ~;:(:, PC' "'- ~r; Z .! :J;t (5""11 s:;;Sd 1O :>C) '- (jrn :;::: ~-"i ~ ::0 > -< en :n . -< , _ - ~o , . ,-~ ,- .'~ ~'"-,'- ",-;:;::;" " "',.,-:\.",', -- .-, "':'<,;--s-_c ~ ) JUL 1 2 2000tP RANDY 1. GOSHORN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW VICTORIA E. GOSHORN, Defendant NO. 00-2463 CIVIL IN CUSTODY COURT ORDER AND NOW, this l1 day of July, 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I. The following temporary custody order is entered: A. The Father, Randy 1. Goshorn, and the Mother, Victoria E. Goshorn, shall enjoy shared legal custody of Dustin Edwards Goshorn, born January 29, 1999. B. The Mother shall enjoy primary physical custody of the minor child. C. The Father shall enjoy temporary physical custody of the minor child for four (4) consecutive weeks starting July 8th on every Saturday from 9:00 a.m. until 5:00 p.m. The following four (4) weeks, Father shall have custody on every weekend from Saturday at 9:00 a.m. until Sunday at 5:00 p.m. 2. The parties shall meet again with the Custody Conciliator for a Conference on Tuesday, August 29, 2000 at 8:30 a.m. At this Conference, the Conciliator will review the results of the custody schedule implemented above with the parties. Assuming there are no problems with Father's exercise of temporary custody with the minor child, it is anticipated that the parties will work out an arrangement for a more traditional permanent custody order at that particular time. 3. In the event there are any significant problems with the custody arrangement as set forth above during the 8 week trial period, counsel for either party may contact the Conciliator directly to conduct an emergency Conciliation Conference over the telephone. 4. The parties shall share transportation for exchange of custody with the exception of July 8th when Father shall handle all transportation. . , 5. cc: - - Both parties shall keep the other parent advised with r~et to th home address. / MichaeID.Rentschler,Esquire "f.uv."_ ~ 1-13. In> Jane Adams, Esquire I -7- r' - -,'-, '=' .'>> '=~"~^~''''<~'''----~''"...'-'''''' --," < .- lephone number and J. u ~. ,.~ ~ J "~ -~~'P .~ ~ b-'~r>'"" - --~. ." 6 /,' Co, V 'b <:r /' v c~ ~(~ "t:> ~"\(.\\ \)-h";-- /1'~-i:~' _ "~,t..(~) (/ .-' ,;::?? l../'; tk- \.P" :C::-7~~ T ;,l ~ ~, -;'/ "<:-'. -;;,:.:'~~j . '\}~ >-) :...-,-,,'-";.:<;-)., . '" /):;: -',~;~-L],\ -"fil,,\' '<6;- .~ 1>~: "';';- ..:: 0./ '\l!lRl!II' , ~.', . "'.'." 'I.' ,;"~" ~'-L'""",,';".;f""",_ -~,,' ,.,,:.,~... ~,.,%,,;,j"-~_,-_.c:' Ulti:i- ..., RANDY L. GOSHORN, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VICTORIA E. GOSHORN, Defendant NO. 00-2463 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 child who is the subject of this litigation is as follows: Dustin Edward Goshorn, born January 29, 1999. 2. A Conciliation Conference was held on July 7, 2000, with the following individuals in attendance: The Father, Randy L. Goshorn, with his counsel, Michael Rentschler, Esquire; and the Mother, Victoria E. Goshorn, with her counsel, Jane Adams, Esquire. 3. The parties agree to the entry of an order in the form as attached. /]/11/00 DATE ~ , '<c ~ ,r'___ _," , ~ " ~:._"'_""_"h -- -- ,.,',; .,'_ ;'...' _'_0 '"_ ' d .. > AUG 3 1 2~ , RANDY 1. GOSHORN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW VICTORIA E. GOSHORN, Defendant NO. 00-2463 CIVIL IN CUSTODY COURT ORDER AND NOW, this I I-day of ~1eA-- , 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. This Court's prior Order ofJuly 13,2000 is vacated. 2. The Father, Randy 1. Goshorn, and the Mother, Victoria E. Goshorn, shall enjoy shared legal custody of Dustin Edward Goshorn, born January 29, 1999. 3. The Mother shall enjoy primary physical custody of the minor child. 4. The Father shall enjoy periods of temporary physical custody of the minor child as follows: A. On alternating weekends from Friday at 5:00 p.m. until Sunday at 5:00 p.m. The parties may modify the time of pick up and delivery of the child as they rnay agree. B. Every Tuesday evening from 5:00 p.m. until 8:30 p.m. C. At such other times as agreed upon by the parties. 5. The parties shall alternate or share major holidays as they work out between themselves. In the event the parties are unable to work out an agreement, either party may bring this case back to the Custody Conciliator to resolve the holiday issue. 6. The Mother shall always have custody of the minor child on Mother's Day and the Father shall always have custody on Father's Day. This provision shall supercede any other provision of this Order. 7. Father shall be entitled to at least two (2) weeks of vacation with the minor child during the summer months. Father shall give notice at least sixty (60) days in advance as to when he intends to exercise vacation time. =. --, " '~ ~ ' ~ -~" ,-,--,,-,,'....,,', -, Ii! .. , . 8. Both parties shall keep the other parent advised with respect to their phone number and address and shall keep the other parent advised with respect to where they will have the child in the event the child is out of the Cumberland County area for a period exceeding one overnight. 9. In the event either party is dissatisfied with this Order, that party may petition the Court to have the case again scheduled for a Conciliation Conference with the Custody Conciliator. BY THE CO / / / J. cc: Jane Adams, Esquire Michael Rentschler, Esquire "" ~ < c.' , . .. .. w .,< " ,~, " "--' ~ "0"""-'_' .'IIl!! e (') G ",,",- .....,,:ie,-. \~e f/:.C) ~1'" r~" %7~\ Y~;t, :1 C) :~:;;. t./1 -~ "0 .,:c-" '.- " ''I -' .~ ,0 ~,,~ ."'~ Il'!':( -,"' "~., _~~,I~RlI , , -.. '-,-'" k " '''''"''"'.' _ , __"_""'_'~""'C-J' ';_ J ',_ __,-,_, ~ . RANDY L. GOSHORN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW VICTORIA E. GOSHORN, Defendant NO. 00-2463 CIVIL IN CUSTODY Prior Judge: Edgar B. Bayley 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 child who is the subject of this litigation is as follows: Dustin Edward Goshorn, born January 29, 1999. 2. A Conciliation Conference was held on August 29, 2000, with the following individuals in attendance: The Father's counsel, Michael Rentschler, Esquire; and the Mother, Victoria E. Goshorn, with her counsel, Jane Adams, Esquire. 3. The parties agree to the entry of an order in the form as attached. <;?! ]fJ/ CO DATE'