HomeMy WebLinkAbout00-03558
--, -,"'-
'X.:~,
~
H
~'s
~
"-',
~
~.~
~
I
~i~
~
,".
",i
.
~.~
~
~.'J
~
~-:~
~
~
~
~
I
~.~
N
*
~'S
~
'w.
~.;
~
t
y
~'s
~
~
M
i
a
i~~
~
,",
.'i'
~
N
~.'~
~
~'~
~
~'S
~
N
~
~'s
~
t~
S
I
i:~
~
~
#"<
~~
~
~
",
~
i
I
;.:~;
,
,I
~_ '_n' '"' -- - u"-', "' J
< ',.k'- ,",'- _"" _,c....n" ~',,~~~ ;;;L""'""m'u'"
-::I!lO
"'......';...,...:.~::!>.......,~1'1+--,;~_':-."~..4~%"......,,'~:w__","',..'''-'.<'''''~-'''A~''''''''fB,
"....._,',f'''O;>''.'''....~''''',',...___<O"'~__,~,,;'-........,,,.,'._::>i;''''!......i~';;";'!.....z""~.~:"._"X";,!~
5
t,'"
',,<
S
,,',"
.;'~
~
;~
I
i
".~
~.~
I
. ,
:~~>>>;:".:~~S&(:~~>>x~~~::.::~;::'::,~~:(,)::+>;::xc!;r~r:::~_:::~!::_:~:<c~~::)::+:~;;:-:,~~::<<{,x.:>;~':~!::c~;;:':~~~x<:~!::c~~::;!S&~
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
WAYNE D. WHITE
2000-3558
No,..................,...., ...............~
>.i
W
!Il'.~
~4~
.
:::1
~-:'l
~
~
~~~
*
~.~
~
~
~
)'.".
i
~."
~
~
~'s
.
~.~
I
~
~
~.:;
~
;-"0
~
il
~
~
'.'
i
!Il'.".
~
~-.~
~
J,
'-.,'
~
...
~.~
~
~
~.~
~
~.~
;~,
~
~
...
Versus
MARGARET ROSE D'ARCANGELO
DECREE IN
DIVORCE
11' :!d" 1/iY\ 2002 't' d d d
AND NOW, "".,'.'". nf~'"",."".,""7.,."" I IS or ere an
WAYNE D. WHITE I' 'ff
decreed that """"."",',.".,.".",..,.."",,.,.,',.,", p amtl ,
and "". . . . . . , , , ,~!\:I~<;i~~,~~ , !'~.~~. P.' .~~~!\-,N.q~~?, . , . , , , , , , , , '. 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;
,....,.. ..rl;1!",r:~, P:r,~ ,IJ9, .qvt13,t,Ql).<;i;Lng. ~,s.~V"'\3,.."..,.,.,....,.,...,.....
. . - . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
By
AIi
HHH4HH
~
~.'
~
~.~
~.~
,
~
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Prothonotary
'1.._ ~
~__ ',_, e",_
..."'-/'0.;:2
..JI t? c2
" -, "",,' ,,,~,,_, ,.-- ~,' ,C ;;, '
W-~~/~.~-<5~
77~~ ~ a:?!j ~
-~ :C"",~_, -"'~'-'=, f' .
~_ 1!Il,~' "_ ,
'~,-
r, ,~
'~"~~',-
, .
"",I
, .-
WAYNE D. WHITE
IN THE COURT OF COMMON PLEAS
VS,
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NO, 2000 - 3558
CIVIL TERM
MARGARET ROSE D'ARCANGELO
PRAECIPE 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 93301 (c)
~x~l<Ill:MRe:~
(Strike out inapplicable section).
2, Date and manner of service of the complaint: Acceptance of Service by Authorized
Agent signed by Donald T. Kissinger, Esquire, on June 22,2000.
3, Complete either paragraph (a) or (b),
(a) Date of execution of the affidavit of consent required by 93301 (c) of the Divorce Code:
by plaintiff 4/19/02 ; by defendant 4/15/02
(b) (1) Date of execution of the affidavit required by 93301 (d)
of the Divorce Code:
(2) Date of filing and service of the plaintiff's affidavit upon the respondent:
4, Related claims pending: There are no outstanding issues.
5, Complete either (a) or (b).
(a) Date and manner of service of the notice of intention to file praecipe to transmit record, a
copy of which is attached:
(b) Date of plaintiff's Waiver of Notice in 93301 (c) Divorce was filed with
the Prothonotary: MAILED to Prothonotary on 4/23/02
Date defendant's Waiver of Notice in 93301 (c) Divorce was filed with
the Prothonotary: MAILED to Prothonotary on 4/23/02
~"^' --" .-:'i.: _K'lr' '_......-.- ~
'"
i!J th~"'"
,~~ " '
"';;'- ". ,',~ >
,,_:,...--,,-,...,.,.-""".'~.
"'."...;.;..,-~..,""""'=
-, < ""~'.'j
,'" '^
jJj ,,~'" " '- ---,,~ ,', ,,_ I
()
c:
s:
-om
cpn";
k-:L
~~
Zj"-)
>'C::
:z
:;!
0"" ~ ."'j
C)
1",)-
:<>>
-0
AJ
N
Ur
C)
"1'1
~;11
- ~ 'j''-=
:'~t3
::-) ~.!...,
_~'J~r",
I:~J(~
;::o::;;rn
~
-e,.
~~
"""
:x;
;:-
\"
- ~~ ~
~<M"O___ ^_",...,""',~__,~" '<^~,_,' -'~""~'T~- ~"'"' ^,_, _. ,-,__'_"
-, " .- ~I
WAYNE D. WHITE,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs,
MARGARET ROSE D' ARCANGELO,
Defendant
CIVIL ACTION - LAW
NO,2000- 3SS1> CIVIL TERM
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court, If you wish to defend against the claims set forth in the
foregoing 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 in 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 the 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 at:
Office of the Prothonotary
Cumberland County Court House
Carlisle, Pennsylvania 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF 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,
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
"~, , - '0'_," _~,.. ~~',__, ,,<""' _ ,,_._ _"'~""'>"_'_~""""~"'-"~~ ~'<"'__'~"...;' .'
WAYNE D, WHITE,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs,
MARGARET ROSE D' ARCANGELO,
Defendant
CIVIL ACTION - LAW
NO, 2000- 35!ir CIVIL TERM
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed in
the Court of Common Pleas of Cumberland County, This notice is to advise you that in
accordance with Section 3302( d) ofthe Divorce Code, you may request that the court require
you and your spouse to attend marriage counseling prior to a divorce being handed down by the
court, A list of professional marriage counselors is available at the Cumberland County Court
House, One Courthouse Square, Carlisle, Pennsylvania, You are advised that this list is kept as a
convenience to you and you are not bound to choose a counselor from this list. All necessary
arrangements and the cost of counseling sessions are to be borne by you and your spouse,
If you desire to pursue counseling, you must make your request for counseling within
twenty days of the date on which you receive this notice, Failure to do so will constitute a waiver
of your right to request counseling.
. "._~ <,,"~ ' "-
~~, , - , ,
, ,~',,' 0,'<>'--" '''',,",~,,'; "=;~;,,
'[)
WAYNE D, WHITE,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs,
MARGARET ROSE D' ARCANGELO,
Defendant
CIVIL ACTION - LAW
NO, 2000- 30'S!?' CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE
UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE
AND NOW comes the above-named Plaintiff, WAYNE D, WHITE, by his attorney,
Michael 1. Bangs, Esquire, and makes the following Complaint in Divorce:
1. The Plaintiff is WAYNE D, WHITE, an adult individual who currently resides at 512
Grant Drive, Camp Hill, Cumberland County, Pennsylvania,
2, The Defendant is MARGARET ROSE D' ARCANGELO, an adult individual who
currently resides at 29 Suniire Avenue, Camp Hill, Cumberland County, Pennsylvania,
3, Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth
of Pennsylvania for at least six months immediately previous to the filing of this Complaint.
4, The Plaintiff and Defendant were married on August 15, 1987, in Connecticut.
5, There have been no prior actions of divorce or annulment between the parties,
6, This marriage is irretrievably broken,
7, Plaintiff has been advised of the availability of marriage counseling and the Plaintiff
may have the right to request that the Court require the parties to participate in counseling,
8, The Plaintiff requests this Court to enter a Decree of Divorce in this matter pursuant to
Section 3301(c) ofthe Divorce Code,
-" ,- _0'" ~, _ .', ",1','_" CO:, ", "'-~ .';_'.', , '" '
WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to
Section 3301(c) of the Divorce Code,
I verify that the statements made in this Complaint are true and correct, I understand that
any false statements in this Complaint are subject to the penalties of 18 Pa, C,S, Section 4904
(unsworn falsification to authorities),
(o.,;-o l)
Date
Lu~ ,,) , w .....-t. MCl
WAYNED, ITE
~~~k~
Attorney for Plaintiff
302 South 18th Street
Camp Hill, PA 17011
(717) 730-7310
Supreme Court ID #41263
, .~,. ~ ~ --", ~ -,~""","",,'~~ ..,,,,~,'~,-,~,",,,,,,,, ,.,~,~"--~~,,~---,""b="':?'~,,U,','-""',~- "'",",
WAYNE D, WHITE,
Plaintiff
v,
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYL VANIA
CIVIL ACTION - LAW
MARGARET ROSE D' ARCANGELO,
Defendant
NO. 2000-3558 CIVIL TERM
IN DIVORCE
DEFENDANT'S ACCEPTANCE OF SERVICE
BY AUTHORIZED AGENT
I hereby accept service of the Complaint in Divorce in this matter on behalf of the
Defendant and certifY that, as the Defendant's attorney, I am authorized to do so,
BY.
DATED:
Donald T, Kissinger, Esq ,
Howett, Kissinger & Conley
Post Office Box 810
Harrisburg, P A 17108
(") <=1 0
c: <=1 "n
g, . ,'"'
"'Ow C ::}:-n
f293 % 1\1r."
I'V .~o.'n
&'is.:; -.l ~'Cl'O
0<2 (;:.6
!;20 ""0 -r--tt
---n
:x 0---
~o :;;~O
0 W ""rf1
5>c .' ~
~ I'V ~
r~
.' -~~ -"~'""'-- -, " '~,'q "':"_'< ,,'r~' ",.'
",,',"J'
"'I
WAYNED, WHITE,
Plaintiff
vs,
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYL VANIA
NO, 2000-3558 CIVIL TERM
MARGARET ROSE D' ARCANGELO,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
Pursuant to Pa. R.C,P, Rule 1920.72
I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June
12, 2000,
2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint,
3, I consent to the entry of a final Decree in Divorce either after service of a Notice of
Intention to Request Entry of the Decree.
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 ofl8 Pa. C.S, Section 4904 relating to
unsworn falsification to authorities.
.-4-/'1-0).
w~ ,:). LOt..1r M.6
WAYNED. WHITE
Date
~'jj
""-
0..
"
,-'-
- ~"; ," "", ",,;; .
~,
~^,',' ~
, "
o
,,:;
-<-:"""
'-C-i':~1
Pity,
!~\
~'>:;
PC:
:z
:<1
,"
o
r,,)
''''''
~)
~'"
N
<.j'l
C)
'--'11
:;p.
:2I:
..,..,
;::::::
- ;.~t~l
.-,~~)
--,- "
:-:)~
/'... "
~5rn
---\
"-
'5:J
-<
r:-
"..j
_t
''''" '~.'~ -,',"<t-___< '._,~',~'"_ ,~,,',~'. "'_'_"'-_,'"~"o:~,,,,,_"",<.-..,,,, ,,,,"~,-~O"'o' ~""".>-.-",_,,-., '_""""j
WAYNED, WHITE,
Plaintiff
vs,
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO, 2000-3558 CIVIL TERM
MARGARET ROSE D' ARCANGELO,
Defendant
CIVIL ACTION - LAW
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 in 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, Section 4904 relating to
unSworn falsification to authorities,
-f-11-/)2
Dated
lu~ U "w "",1. fV\./)
WAYNED. WHITE
~ .'~O '
I,
"",-",-
,,~, ;'. "~~~="
,
'""",,
",,~< ',"-~.
''''0
(")
C
.:.:..';'""
tJtT~
r-nrT;
;Z"~
'7f-'-
0~~
2e
~._~
~~2
:::.:.
:<
o
1"\.),
J'>
'-,:)
';l:J
".:J
(f~
o
~n
~Xi
'-l-;tl:!
~~] ~~;
, ' ~"
::~) ;~
~5;:f/
~
_D
-<
~
c:-
,-J
\'"
~. ~ - "~,
_~~_"___,, ",',""" ',0. ~ '_~"___ ,"__ '"'~,~'". ~. '^__~
WAYNED. WHITE,
Plaintiff
vs.
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYL VANIA
NO, 2000-3558 CIVIL TERM
MARGARET ROSE D' ARCANGELO,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
Pursuant to Pa, R,C.P, Rule 1920,72
I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June
12,2000,
2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint,
3, I consent to the entry of a [mal Decree in Divorce either after service of a Notice of
Intention to Request Entry of the Decree,
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, Section 4904 relating to
unsworn falsification to authorities,
~d 15) f).OVd-_
D e
1ll~ I/~ j)r}LJ~j)
MARG T ROSE D' ARCANGELO
L '~'"
"I
^,"."
~-'~,,"""'=
" ,~
,"
--~
;;;.
(')
c:
U~
nln-:
Z:::C
~g
~8
'7
~
I
o
1'....)
"'"
..'Cl
~U
o
'''1'1
.:.-:;J
;-';--;:lj
,,,
('"
.-"
,1~~
(lB
(~s(r;
-I
'""
~
~,.
~
r;:.-
(D
r
- ~, --~ ,
, " ri'''_ _,,_.,~ ~' ~'_~__~'^
<-O"~.'_ '. "'"'''''_~'''
~:
~
WAYNE D, WHITE,
Plaintiff
vs,
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO, 2000-3558 CIVIL TERM
MARGARET ROSE D' ARCANGELO,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE
1, I consent to the entry of a final decree in divorce without notice,
2, I understand that I may lose rights concerning alimony, division of property, lawyer's
fees, or expenses if I 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. Section 4904 relating to
unsworn falsification to authorities.
~ 15) c20~
~~, jg~~~
MARG T ROSE D' ARCANGEO
~' ~ ~;oi.; '-'-'
.~
--~
0 a C}
C f'v -of;
~ ~
""TJG.. "0 '-n
n1I"I": ::.u ~'":=
:z: :;c r,,) n\~?i
~}:~ u'~
-<-,: ~-~';~~:
r::::c) ~.:! "
'- 'T;
~8 -- ') ('")
~'..~ rn
~~
C -"
"7' r. -1:""
:-=i 'J:J
-< {D -<
It>
WAYNE D. WlllTE
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
V.
00-3558 CNIL ACTION LAW
MARGARET ROSE D'ARCANGELO
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW, Thursday, June 03, 2004 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, June 30, 2004 at 8:30 AM
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 defme 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,
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearin~.
FOR THE COURT,
By: Isl
Dawn S. Sunday. Esq.
Custody Conciliator
mho
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 ATIORNEY AT ONCE, IF YOU DO NOT
HAVE AN ATIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTIl BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
.
,
~ ~ '," ~~~,~, --, - ~
~ -'^"
'" "",,~'< '~,
__ ='~~,,<", ~_~ ~~,c- __~",H"'~~'<"" ~ ,
"..c.C ,
o,;,,,\vc. :'f" n\t
\'\l...tD...10~~\O\~() 'r~;"
''l'\..l': j1P, .
or H'\... . 2' c,'5
'("\ . v
J"il! -t\ r
'/.~\\1;\J'\
.., '\\-!'~
"<"'1' II
", ,;\ 1,\JV
"c.,,-IJ ;~~'hJ ;""\"1\
rlJ\,,^\j~~ :~,~-",r<,'~10fi\\{il
.J PCi'lN:)
?'VOi/ dd.t~, ~ -;J 4 ~
If; -VCf/ ~~ /l-1I'~ i5 ~., ~
t.'1:O'!' ~ ~~ 'df ~ ~,
"""'"
.~JIIf'~
",~"'~"""~ '", ,<
J!i'l!N, ~"
.~ ,.,
,. :m:rlilil'."..,.~RI1' '
,~~
j:1
I'
r
~"
i'i
t;
~i}\Y 25 I~Y:: { II
7 I',~
i'
i,
j!:
!i
r"
p
Ii
I'
"
"
!
II'
Ii
''II
0:i
~I
(tl
III
"
,II
If!
!1i
f~1
[,:j
~~ I'~-
_ M'~ ~.'" ,," .__ ,-'_
'_"',-",',"~-, ",~,~,~cli-',"~",'. "-_''"',.. - ._ ",10
I>,,~ .' ,"'<'_ "~-",'.."-~ __ ~ ., '""",,_, -,,,, ,,,,',.." o,'c ,,~""" ,e ',,,,,~~,,~_';,,____,,' ~"^","-"""" oL'-'~"-.;,;-
WAYNE D, WHITE,
Plaintiff
)
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs,
CIVIL ACTION - LAW
NO, 2000-3558 CIVIL TERM
MARGARET ROSE D' ARCANGELO,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW, this
day of
, 2004, upon
consideration of the attached Complaint, it is hereby directed that the parties and their respective
counsel appear before
, Esquire, the conciliator at
, Pennsylvania, on
the
day of
o'clock _,m"
, 2004, at
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. Either party may bring the child who is
the subject of this custody action to the conference, but the child's attendance is not mandatory,
Failure to appear at the conference may provide grounds for entry of a temporary or permanent
order.
BY THE COURT,
Custody Conciliator
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO
NOT HAVE A LA WYEROR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
CUMBERLAND COUNTY BAR f?,SSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
-"~':
i'l'
y"
&1
~i
ri
"I
~I
,'ri
gl
~I
II
I',
"
JI
[,'I
"
"
~i
'r'
~!
iii
I~:
*1
l'
,
I
[
J
, '", '~.-'"'",-_' G:c~,~.: ,-,_' ~'_
- '- '; 1_ ": .' - ,; 1 0,' ~ " ,:,,"';;:' '-:-'-
-
". "_ ~ ", 0<,"
~t,~
1;\
m
!
~'
CIVIL ACTION - LAW
~;
(!'
);-
~'
I,
r
f
,
[
I
[;,
1
~,
[
1
k
r"
l
,
t
WAYNE D, WHITE,
Plaintiff
vs.
)
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY,PENNSYLVA}ITA
NO, 2000-3558 CIVIL TERM
MARGARET ROSE D' ARCANGELO,
Defendant
IN DIVORCE
COMPLAINT IN CUSTODY
~'
I'
I
I
I
~
~
~i
~'
AND NOW comes the Plaintiff, WAYNE D, WHITE, by his attorney, Michael 1. Bangs,
and makes the following Complaint for Custody:
1, The Plaintiff is WAYNE D, WHITE, an adult individual who resides at 497 Sample
Bridge Road, Enola, Cumberland County, Pennsylvania,
2, The Defendant is MARGARET ROSE D' ARCANGELO, an adult individual who
resides at 5159 Kylock Road, Mechanicsburg, Cumberland County, Pennsylvania,
3, The Plaintiff and Defendant were formerly husband and wife, having been divorced
on April 30, 2002,
4, The Plaintiff and Defendant are the parents ofthree minor children: Monica R. White
(d,o,b, 3/2/90); Daniel S, White (d,o,b, 2/16/92), and Cassandra M, White (d,o,b, 6/8/98),
5, Plaintiff seeks an award of periods of partial custody and visitation with the children.
6, The children were not born out of wedlock.
7, During the past five years, the minor children have resided with the following persons
at the following addresses:
1
-0
"'-""[-' I'"
,'.-< -''"''''-", ,,-," ~,,",' ".. '" -
- -~
01
f
,
,
t
A. From March, 1990 until
January, 2000
Plaintiff and Defendant
29 Sunfire Avenue, Camp Hill
B, From January, 2000 until
August, 2001
Defendant
29 Sunfire Avenue, Camp Hill
C, From August, 2001 until
December, 2002
Defendant
234 Skyline Drive, Mechanicsburg
D. From December, 2002 until
June, 2003
Defendant
71 Johns Drive, Enola
E. From June, 2003
to present
Defendant
5159 Kylock Road, Mechanicsburg
8. The father of the children is the Plaintiff who resides at the address set out above, He
is divorced from the Defendant.
9. The mother of the children is the Defendant who resides at the address set out above,
She is divorced from the Plaintiff,
10, The Plaintiff is the natural father of the children, Plaintiff currently resides with his
wife,
11, The Defendant is the natural mother of the children, Defendant currently resides
with the minor children,
12, The Plaintiff and Defendant had previously resolved their custody issues by entering
into a Stipulation dated November 30, 2000, which is attached hereto as Exhibit A.
The Plaintiff has no information of a custody proceeding concerning the children pending
in a court of this or any other jurisdiction.
2
- "1 , I~'--- ,---
'.~,," -
'" '
- ~-
. '~',,"
Ii
".
1''-
,
~'
13, The best interests and permanent welfare of the children will be served by granting
Ii,:
:
I,
~.
I,
I
['
I
Plaintiff knows of no other person not a party to this action already who has physical
custody of or claims to have custody or visitation rights to the said children,
the relief requested by Plaintiff for the following reasons: Plaintiff is relocating out of state due
to job opportunity and the parties have been unable to reach an appropriate custody and visitation
::J
schedule.
14, Each parent whose parental rights to the children have not been terminated and the
I~'~'
j
l~
person who has physical custody of the children have been named as parties to this action,
~J:t)
MICHAEL L. BANGS
Attorney for Plaintiff
429 South 18th Street
Camp Hill, P A 17011
(717) 730-7310
Supreme Court ID #41263
~i:
f:
I~
Ii:
1';
~.
I:'
f
i'
F,'
I
I
I
i~
WHEREFORE, WAYNE D, WHITE, requests this Honorable Court enter an Order
granting him periods of partial custody and visitation with the children Monica R, White, Daniel
S, White, and Cassandra M, White,
~;
I'
~
~:
3
<I
I_~ -, 'I
,^,- --'-<'-"-
c-_, -P' ;"",' ~ .-,\,
:' '.:.. .,-:-;;'~ -. ',; -" '~ '
i"
'.,,'1"
VERIFICATION
If
I:
I,
I'
I,
I
,
"
)1
1
I
r
I;
I
I verify that the statements made in this document are true and correct. I understand that
ii'
any false statements in this document are subject to the penalties of 18 Pa, C.S. 4904 (unsworn
falsification to authorities),
i:
,
~'i
i!
!i:
Date:
lY\"'1 20, 'l.Oo'!
w~ J). u..,k-t; M-
WAYNED, WHI
r
~
r
~,
I;
r
h
f:'
f
~'
~.
I
t>
t
t
i
I"
fi,
~:
I
~
\\
I;
4
:r:
WAYNED, WHITE,
Plaintiff '
vs,
)
)
)
)
)
)
)
)
CIVIL ACTION - LAW
IN DIVORCE
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO, 2000-3558 CIVIL TERM
MARGARET ROSE D' ARCANGELO,
Defendant
STIPULATION
AND NOW, this .JoN~
day of IJ~v
, 2000, the parties hereto,
Plaintiff/Father being represented by Michael L. Bangs, Esquire, and Defendant/Mother being
represented by Donald T. Kissinger, Esquire, have entered into the following Stipulation:
1, The parties shall share legal custody of their minor children, Monica R. White, d,o, b.
March 2,1990; Daniel S, White, d,o,b, February 16, 1992, and Cassandra M, White, d,o,b, June
8, 1998,
2, During the school year, the custodial arrangement shall be as follows:
A. Father shall have the children on alternating weekends beginning on
Friday at 5 :00 p,m, until Sunday at 9:00 p,m. at which time he shall return the
children to Mother's residence.
B, On the Tuesday preceding Father's weekend, from 5:00 p,m" until the
following morning at which time he shall take the children to their school or to
Mother's residence,
C, On the Thursday following Father's weekend, at which time he shall
pick Cassandra up at 6:30 a,m" and shall pick up Monica and Daniel from school
1
~ "
- ~ ~'Ii,Ii!-~'-,
^
.J
i.
and have them until the following morning at which time he shall take the
children to their school or Mother's residence.
D, On the Thursday preceding Father's weekend and the Tuesday
following his weekend, Father shall have the children from 5:00 p,m, until 9:00
p,m, at which time he shall return the children to Mother's residence,
E, Mother shall have the children at all other times,
3. During the summer months, Father shall have the children from Friday at 5 :00 p,m"
until Monday morning at which time he shall deliver the children to Mother's residence; every
Tuesday from 5:00 p,m" until the following morning at which time he shall deliver the children
to Mother's residence; and every Thursday from 6:45 a,m" until the following morning at which
time he shall deliver the children to Mother's residence,
4, The parties shall alternate the major holidays, those holidays being defined as
Thanksgiving, Easter, Memorial Day, Fourth of July, and Labor Day, This schedule shall
commence with Mother having Thanksgiving in 2000, and shall alternate thereafter. These
periods of partial custody shall be from 9:00 a,m, until 9:00 p,m,
5, Father shall have the children every year, commencing with their release from school
at which time Father shall pick them up either after school or when he is first available after
work, until Christmas Eve at 10:00 p,m" at which time he shall deliver the children to Mother's
residence, Mother shall have the children every Christmas Eve at 1 0:00 p,m, through Christmas
Day, The parties shall evenly divide the remainder of the children's Christmas holiday in such a
way that both parties shall have the children for an equal amount of time over their entire
2
,,~
= '#~,.;-
,J
-
"""~I;!~,,
, ,
Christmas holiday, The dates and times of the division of this period of the Christmas holiday
shall be agreed upon by the parties,
6, Such other times as the parties may agree,
LU&LU tv... Q;' 1>1..1
WAYNED, ITE
~
1It~ ~j)~~
MAR ARET ROSE D' ARCANGEL
DONALD T, KISSING
3
~~ '
lIci.'" '-~. 1Il.'.;@!iY""l~iIII]I.~~'
Jl
.Iiltir L~ '~~~~;1\1!ir JwniL
="
.'
>~.~ "
", ,.
,
\ ..u;). ""
'P ~ (') "'" ~
~~ =
"- ..c-
""t'Q} ::J: ~:!l
rn\";1 "".
() ;:;:::::.=:.:: -< ~.M;
....... ~ 0 &;S~:'. N :uy
Vl r;:C~; ;- 00
- ~ -4'-r'
llV ~ ~~C) '"'" X,i
~" 0-
d.- '-l -. ~()
~ ~ 3>-:~ GJ e'"
'-~ -l
t z d?;
~ _J :',<
"-
. - " ,~~
,
-, ".,
'1',:' ~^ c '^ ,;>;,~ ::,~:,___:"'. ".".','" ,c-" '.J':^"
-"~"--,~.,,, ),.c>-i;;'.';,- ,~ ~"'<-~'1i:'j,
,~.
\(/
I
WAYNED, WHITE
Plaintiff
SEP 0 2 2004 c:.
IN THE COURT OF COMMON PLEAS Or
CUMBERLAND COUNTY, PENNSYLVANIA
vs,
00-3558
CIVIL ACTION LAW
MARGARET ROSE D' ARCANGELO
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this q ~ day of s."J-~ , 2004, upon
consideration ofthe attached Custody Conciliation Report, it is ordered and directed as follows:
1, The Father, Wayne D, White, and the Mother, Margaret Rose D' Arcangelo, shall have
shared legal custody of Monica R. White, born March 2, 1990, Daniel S, White, born February 16,
1992, and Cassandra M, White, born June 8,1998. Each parent shall have an equal right, to be
exercised jointly with the other parent, to make all major non-emergency decisions affecting the
Children's general well-being including, but not limited to, all decisions regarding their health,
education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all
records and information pertaining to the Children including, but not limited to, school and medical
records and information.
l!,
if
2. The Mother shall have primary physical custody of the Children,
3, The Father shall have partial physical custody of the Children during the school year for one
weekend each month in Peunsylvania from Friday through Sunday (or Monday if there is no school
and the Father is not working), with the specific times to be arranged by agreement between the
parties, For the remainder of2004, the Father's weekend periods of custody shall take place on the
weekends beginning October 1 and November 19, The Father shall not have a period of weekend
custody in December 2004, due to his extended holiday period of custody, The Father shall provide at
least 30 days advance notice to the Mother of the dates on which he plans to schedule his weekend
periods of custody under this provision,
4, Each party shall be entitled to have custody of the Children for one-half of the total summer
school break to be scheduled as follows:
A. The Father shall have custody of the Children for two consecutive weeks beginning on the
first Saturday after the last day of the school year.
B, The Father shall also have custody ofthe Children for the remainder ofthe Father's one-half
share of the summer school break beginning on the first Saturday after the swim team program
ends,
liiI
'\
...".....
,..",..'..' '.... "..c'......',..." ,... ...",,,
"~>""- ~:'::.",-~" ,,,,""~,~'.,, ",
~ILEI''i,':CI'''C:
I V-"",Il Vl...
OF ,THE PROTHONOTAPY
.
zao~ SEP -9 P!1 3: 04
C' :', :;:"",..ii..., (","'1 'N1Y
UI'/,-,"<'-'i....!"".' ,....JUi
PEi\Jf\,ISYLV/:\f\!LA
,
,ffl!&!lj!i < ,
.",-.~
,-, ~~,=
CI~'~'~I_'"
'11;:-"
_____I
-0"-' _'"
-~
-.ct."".'C ."
" <,,' ~o,,,,,,
~' "" "'<';i)
--
C, The Mother shall have custody ofthe Children during the remaining weeks of the summer
vacation not otherwise specified for the Father in this provision.
5. The parties shall share or alternate having custody of the Children on holidays as follows:
A. Christmas: In 2004, the Father shall have custody ofthe Children over the Christmas school
break from December 26 through December 29 or December 30, with the specific
arrangements to be made by agreement between the parties, The parties agree that in 2004, the
Father will be taking the Children to Florida for his period of Christmas holiday custody and
shall accompany the Children on flights between Harrisburg and Orlando, Florida, Beginning
in 2005 and continuing thereafter in odd numbered years, the Mother shall have custody of the
Children for the first part of the Christmas school break and the Father shall have custody from
December 26 through the last day before school resumes after the school holiday break,
Beginning in 2006 and continuing in even numbered years thereafter, the Father shall have
custody of the Children from the last day of school before the holiday break through
December 29 and the Mother shall have custody for the remainder of the holiday school break,
B, Thanksgiving/Easter: The Mother shall have custody of the Children for the entire school
break over Thanksgiving and Easter in even numbered years and the Father shall have custody
of the Children for the entire school break over Thanksgiving and Easter in odd numbered
years,
6, With the exception of the monthly weekend periods of custody for which the Father shall
travel to and from Pennsylvania, the parties shall equally share transportation for all exchanges of
custody, Unless otherwise agreed, the parties shall exchange custody of the Children in Newburg,
New York, the half-way point between their residences.
7, Neither party shall do or say anything which may estrange the Children from the other
parent, injure the opinion ofthe Children as to the other parent, or hamper the free and natural
development of the Children's love and respect for the other parent. Both parties shall ensure that third
parties having contact with the Children comply with this provision.
8, This Order is entered pursuant to an agreement ofthe parties at a custody conciliation
conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
BY THE COURT,
./lJ
J.
J^J()~
oq~u
1
:--r
-"I; '1-
:--":..,;;.;; ~,-;
_ '-c "'it_", ,~' -,
'-":1l:'
~
.,
WAYNED, WHITE
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs,
00-3558
CNIL ACTION LAW
MARGARET ROSE D' ARCANGELO
Defendant
IN 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 Children who are the subjects of this litigation is
as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Monica R, White
Daniel S, White
Cassandra M, White
March 2, 1990
February 16, 1992
June 8, 1998
Mother
Mother
Mother
2, A conciliation conference was held on August 24, 2004, with the following individuals in
attendance: The Father, Wayne D. White, with his counsel, Michael L. Bangs, Esquire, and the
Mother, Margaret Rose D' Arcangelo, with her counsel, Donald T, Kissinger, Esquire,
3, The parties agreed to entry of an Order in the form as attached,
Av~f- JOj a-ovif
Date
Da~
Custody Conciliator