HomeMy WebLinkAbout00-03153
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HOLLY C. TREICHLER
PLAINTIFF
IN TIIE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
WILLIAM N. TREICHLER, SR.
DEFENDANT
00-3153 CMLACTIONLAW
IN CUSTODY
ORDER OF COURT
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AND NOW, this 23rd day of May ,2000, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear befordVIelissa P. Greevy, Esq. , the conciliator,
at 214 Senate Avenue, Suite 105, Camp HiD, PA 17011 on the 15th day of June ,2000, at 1:00 PM
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 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 TIIE COURT,
By: Isl
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE, IF YOU DO NOT
HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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HOLLY C. TREICHLER,
Plaintiff
vs.
: THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: No. 00 ~ ,JtS3 C't.) L'C ~~
WILLIAM N. TREICHLER, SR.,
Defendant
: CIVIL ACTION -AT LAW
: CUSTODY
ORDER OF COURT
And now, this day of , 2000, upon consideration of
the attached Complaint, it is hereby directed that the above parties and their respective counsel appear
before , Esquire, the conciliator, located at
, Pennsylvania, on the day of , 2000,
at .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 nalTOW the issues to be
heard by the court, and to enter into a temporary order. All children age five or older may be present
at the confurence. Failure to appear at the conference may provide grounds for the entry of a
temporary or permanent order.
FOR THE COURT:
By:
Custody Conciliator
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 BEWW TO FIND OtrrWHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Libert! Avenne
Carlisle, P A 17013
(717) 249-3166
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HOLLY C. TREICHLER,
Plaintiff
: THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No.
WILLIAMN. TREICHLER, SR.,
Defendant
: CIVIL ACTION - AT LAW
: CUSTODY
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our
office. All arrangements must be made at least 72 hours prior to any hearing or business before the
court. You must attend the scheduled conference or hearing.
BY THE COURT:
Date:
J.
.1.,-._
HOLLY C. TREICHLER,
Plaintiff
vs.
: THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: No. /J1) > .3/S3 Ct..x-e I~
WILLIAM N. TREICHLER, SR.,
Defendant
: CIVlLACTION -ATLAW
: CUSTODY
COMPLAINT IN CUSTODY
AND NOW, the Plaintiff, Holly C. TreicWer, by and through her attorney, Jeanne B.
Costopoulos, Esquire, makes the following Complaint in Custody:
1. The Plaintiff, Holly C. TreicWer, is an adult individual who currently resides at 411
W. North Street, Apt. 5, Carlisle, Cumberland County, Pennsylvania 17013.
2. The Defendant, William N. TreicWer, Sr., is an adult individual who is currently
residing at 7073 Carlisle Pike, Carlisle, Cumberland County, Pennsylvania 17013.
3. The parties have one dependent child, Renae Elizabeth TreicWer (DOH 9/15/92).
4. The Plaintiff seeks primary of the following child who has resided with both parents
since birth at 7073 Carlisle Pike until the past few months. The child now resides as follows:
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Present Residence
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(9/15/92)
Renae Elizabeth TreicWer
7073 Carlisle Pike
Carlisle, PA 17013
Every other weekend +
Sundays, Tuesdays and Thursdays
with Defendant
114 W. North Street
Carlisle, PA 17013
Every other weekend +
Mondays and Wednesdays
with Plaintiff
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The child is presently in the custody of Plaintiff every other weekend and also spends the night
Mondays and Wednesdays. The child is in the custody of Father every other weekend plus spends the
night Sundays, Tuesdays, and Thursdays>
Plaintiff is married to Defendant and no divorce action has yet been filed.
The child was not born out of wedlock.
S, The relationship of the Plaintiff to the child is that of natural mother. Plaintiff currently
resides at 411 W. North Street, Apt S, Carlisle, Cumberland County, P A 17013. The relationship of
the Defendant to the child is that of natural father. Defendant currently resides ~t 7073 Carlisle Pike,
Lot 14, Cumberland County, PA 17013,
6. 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.
7. Plaintiff does not know of a person not a party to the proceedings who has physical custody
of any of the child or claims to have physical custody or visitation rights with respect to the child.
8. The best interests and permanent welfare of the child will be served by granting the
relief requested because:
(a) Plaintiff is the natural mother of the child and has been the child's primary
caretaker since birth.
(b) plaintiff has established a relationship with the child, which should be
maintained.
(c) Plaintiff desires to exercise parental duties and to enjoy the love and affection
of the child.
(d) The child should be permitted to enjoy the love, affection, and emotional
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support which can be provided by her natural mother.
(e) The child would benefit from full custody with her natural mother.
9. Each parent whose parental rights to the child have not been terminated and the person who
has physical custody of the child have been named as parties to this action. No other persons are
known to have or claim a right to custody or visitation of the child to be given notice of the pendency
of this action and the right to intervene.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an order granting
to her full physical and shared legal custody of her daughter.
Respectfully submitted,
Dated:
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J. ~.. Costopoulos, Esquire
ATTORNEY FOR PLAINTIFF
1400 N. Second Street
Harrisburg, P A 17102
(717) 221-0900
Supreme Ct. ill No. 68735
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HOLLY C. TREICHLER,
Plaintiff
: THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No.
WILLIAMN. TREICHLER, SR.,
Defendant
: CIVIL ACTION - AT LAW
: CUSTODY
VERIFICATION
I, Holly C. Treichler, hereby verify that the statements made in the foregoing Custody
Complaint are true and correct to the best of my knowledge, information, and belief. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904, relating to
unsworn falsification to authorities.
Date: 5\ 18\ eo
s.._" ct:bHt' ~ \'" 0 u,LQ "-
Holly . Treichler
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JUL 1 8 20~
HOllY C TREICHLER,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-3153
WilLIAM N. TREICHLER, SR..
Defendant
CIVil ACTION - LAW
CUSTODY
INTERIM ORDER OF COURT
AND NOW, this I ff^ day of ~ ' 2000, upon consideration of
the attached Custody Conciliation Report, it is rdered and directed as follows:
1. The parties shall submit themselves and their minor Daughter to an evaluation
by Helen H. Stevens Center. This shall be an independent Custody Evaluation. The parties
shall sign all necessary releases and authorizations for the evaluators to obtain medical and
psychological information pertaining to the parties. Cost of this evaluation shall initially be
shared equally by the parties with the understanding that neither party has waived their right to
file the appropriate petition to request contribution in a greater percentage from the other
party. In the event that the Custody Evaluation cannot be done by the staff of the Helen H.
Stevens Mental Health Center in Carlisle, the parties have agreed that it shall be performed by
Dr. Arnold Shienvold>
2. Pending further order of this Court or agreement of the parties, the Father,
William N. Treichler, Sr., and the Mother, Holly C. Treichler, shall have shared legal custody of
their minor Daughter, Renae Elizabeth Treichler, born September 15,1992. Each parent shall
have an equal right, to be exercised jointly with the other parent, to make all major non-
emergency decisions affecting the Child's general well-being including, but not limited to, all
decisions regarding her health, education and religion. Pursuant to the terms of this
paragraph, each parent shall be entitled to all records and information pertaining to the Child
including, but not limited to, school and medical records. To the extent one parent has
possession of any such records or information, that parent shall be required to share the
same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent. They shall also, in a timely
fashion, share information with each other regarding the Child's extracurricular activities,
school schedule, homework. and parent-teacher conferences.
3. The parties shall share physical custody of their Daughter according to the
following schedule:
A. Commencing on July 12, 2000, Mother shall pick up the Child from the
babysitter and shall have physical custody of the Child from July 12 until
5:30 PM, July 16.
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Docket No. 00-3153
B. On July 16 at 5:30 PM, Father shall pick up the child and have physical
custody of her until he delivers her to the babysitter the morning of
July 19, 2000. The parties shall continue in this fashion with the Mother
having custody of the Child from Wednesdays after work until Sundays
at 5:30, and Father having physical custody from Sunday evenings
at 5:30 PM until Wednesday mornings, when he shall deliver the child to
either a babysitter or to school.
4. Holidays shall be shared by the parties as follows:
A. Labor Day: The party having custody of the Child for the Holiday
weekend shall maintain custody until noon on Labor Day. The parent who
did not have the Child for the Labor Day weekend shall have the child>
from noon Labor Day until 8:00 PM.
B. Thanksgiving: Thanksgiving shall be divided into two segments.
Segment A shall be from 4:00 PM, the day before Thanksgiving, until 4:00
PM Thanksgiving Day. Segment B shall be from 4:00 PM Thanksgiving
Day until 8:00 PM, the day after Thanksgiving. In the year 2000, Mother
shall have Segment A; Father shall have Segment B.
C. Christmas: Christmas shall be broken into two segments. Segment A
shall be from December 24 at 1 :00 PM until December 25 at 1 :00 PM.
Segment B shall be from December 25 at 1 :00 PM until December 27 at
8:00 PM. In the year 2000, Father shall have Segment A; Mother shall
have Segment B.
5. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this agreement by mutual
consent. In the absence of mutual consent, the terms of this Order shall control.
6. It is noted that great tensions exist between the parties of this Order. Neither
party shall do or say anything which may estrange the Child from the other Parent, injure the
opinion of the Child as to the other Parent, or hamper the free and natural development of the
Child's love and respect for the other Parent. The parties are specifically prohibited from
discussing the Custody litigation with the minor Child. Each Parent shall insure that third
parties also comply with the provision during his or her periods of custody.
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cc: Jeanne' B. Costopoulos, Esquire, counsel for Mother
Karl E. Rominger, Esquire, counsel for Father
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HOLLY C. TREICHLER,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-3153
WILLIAM N. TREICHLER, SR.,
Defendant
CIVIL ACTION - LAW
CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation
is as follows:
NAME
DATE OF BIRTH CURRENTLY IN CUSTODY OF
Renae Elizabeth Treichler
September 15, 1992 Father
2. A Conciliation Conference was held on July 10, 2000, with the following
individuals in attendance: The Mother, Holly C. Treichler, with her counsel, Jeanne' B.
Costopoulos, Esquire; and the Father, William M. Treichler, Sr., with his counsel, Karl E.
Rominger, Esquire.
3. The parties agreed to an interim Order in the form as attached with the
understanding that a Custody Evaluation would be completed.
4. The parties are advised that if necessary they may return to Conciliation
rol~;":: I:~::'"' m ~e C~,dy Q"
Date Meli s Peel Greevy, Esquire
Cus ody Conciliator
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JUL 3 1 20W
HOllY C. TREICHLER,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-3153
WilLIAM N. TREICHLER, SR.,
Defendant
CIVil ACTION - LAW
CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation
is as follows:
NAME
DATE OF BIRTH CURRENTLY IN CUSTODY OF
Renae Elizabeth Treichler
September 15, 1992 Father
2. A Conciliation Conference was held on July 10, 2000, with the following
individuals in attendance: The Mother, Holly C. Treichler, with her counsel, Jeanne' B.
Costopoulos, Esquire; and the Father, William M. Treichler, Sr., with his counsel, Karl E.
Rominger, Esquire.
3. The parties agreed to a temporary Order in the form as attached with the
understanding that a Custody Evaluation would be completed.
4. The parties are advised that if necessary they may return to Conciliation
following the recommendations of the Custody Evaluation.
7-11-~
Date
~)i~~~.d C~fi.---t
elissa Peel Greevy, Esquire
Custody Conciliator
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