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Home My WebLink About97-00115 \ o .... ... ~ ~ \. \l ~ ~ ~ ~ ~ ~ .~ ~ - ~ ,:> - ~ ~I l.- et- ~ ., 'I II 1 JOHN W. KICHMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF I CUMBERLAND C,9llNTY, PENNSYLVANIA ') /1 I No.1 CIVIL TERM vs. JENNIFER MERCURIO, Defendant CIVIL ACTION - AT LAW CUSTODY ORDER OF COURT AND NOW, this T'r1 ~If, /~'I7_, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before (VI" l..f / t. (;'"75/':';. , the conciliator, at ~ /'0;)'). /81/1 St. (e'ml 0,1), on the -1 "$ day of F e ~ 1991! at q: 00 cJ. .m., for a prehearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot 'I 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/children' s attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: By: .--I1;c./,'!?<l 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 BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, FOURTH FLOOR CARLISLE, PA 17013 (717)240-6200 ,/~ti nil' ~ ,. ( . JOHN W. KICHMAN, Plaintiff VB. , : JENNIFER MERCURIO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA .- "/ III NO. C(. CIVIL TERM CIVIL ACTION - AT LAW CUSTODY I! " , COMPLAINT FOR CUSTODY I I The Plaintiff, John W. Kichman, by and through hiB i, attorney, Jeanne B. Wigbels, Esquire, files this Complaint for " :: Custody against the Defendant, Jennifer Mercurio, and avers the ii , I following in support thereof: 1. The Plaintiff is John W. Kichman, an adult individual and the natural Father, who currently resides at 23 Acri Meadow Road, Enola, Cumberland County, Pennsylvania 17025. 2. The Defendant is Jennifer Mercurio, an adult individual and the natural Mother, who currently resides at 919- A Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania 17043. 3. The Defendant seeks custody of the following child: Name Present Address Aqe Pamela Summer Kichman 23 Acri Meadow Road 3 Enola, PA 17025 D.O.B. 7/7/93 The child was born out of wedlock. 4. The child is presently in the custody of John Kichman who currently resides at 23 Acri Meadow Road, Enola, Cumberland County, Pennsylvania 17025. 5. During the past five years, the child has resided with the following persons and at the following addresses: WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order granting custody, partial custody, or visitation of the children to the Plaintiff and natural Father, John Kichman. Respectfully submitted: 12 ,hI ! tit 10 (dt~, ne B. Wigbels, Esquire L Offices of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 PA Supreme Ct. ID No. 68735 Phone: (717) 763-1800 ATTORNEY FOR PLAINTIFF DATED: :i , I " I I ! j 'F I , JOHN W. KICHMAN, Plaintiff I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I I NO. CIVIL TERM I CIVIL ACTION - AT LAW CUSTODY vs. JENNIFER MERCURIO, Defendant CERTIFICATE OF SERVICE I, John W. Kichman, Esquire, do hereby certify that a true and correct copy of this COMPLAINT FOR CUSTODY was served upon Plaintiff by first class mail on the below date by placing same in the united States Mail at Camp Hill, Pennsylvania, certified, restricted delivery, return receipt requested, and addressed as follows: Jennifer Mercurio 919-A Hummel Avenue Lemoyne, PA 17043 BY: DATED: ( lfJ( Ire ( t. // ne B. Wigbels, Esquire L Offices of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 PA Supreme Ct. ID No. 68735 phone: (717) 763-1800 ATTORNEY FOR PLAINTIFF JOHN W. KICHMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 97-115 CIVIL TERM vs. JENNIFER MERCURIO, Defendant CIVIL ACTION - AT LAW CUSTODY AFFIDAVIT OF SERVICE I ;1 TO THE PROTHONOTARY: I, Jeanne B. Wigbels, Esquire, verify that the Complaint for Custody has been served upon the Defendant indicated above by first class, Certified Mail No. Z 138 527 321, postage prepaid, return i receipt requested, pursuant to the requirements of Pa. R.C.P. 1930.4. i I , & f 3. ArtIcI. Addr..sed 10: . ~' r:;r ~ w;:: 'kn;w,10. 1'70'13 I also wllh 10 r_1ht following HMceI (lot an .xtra f..): 1. 0 Addr.....'. Addr... i 2. 0 R..,ricted D.llv./y .i ConSIliI po.Ima.'.r lor f.., I 40. Artlcl. Number J ~S!!c!T!J. 3;). j o R.gl.'.red ~rtJfled o Expr... Mail 0 In.ured f o R.lum Receipt for Merchandso 0 COD k 7. Dol olD.liv /y ~ - ~ - I 8, Addr....... Addr 55 rOnly /I '&qu.sted ~ 81ld I.. Is paid) ~ 'CompItf.lttmt1IflG1or 2 for additional MMcet. 'CompIeI.Itlml3, "a, and 4b. .PrtnI your rwne and add,... on the f......... 01 thl, form 10 thai WI can rMum IN, ..,., 10 "'U, -AnKh thItlorm to the front 01 the mailpiece, or on the bad! if spice don "01: '~R~ R~pt RIqUMI~' on the mailpieal be'ow the article number. 'The Altum RlCtipC willhow 10 whom the artldl WI' deliv.~ and 1M dalt doI,.,.,od, " , i! 5. Rec.lved By: (Print Name) , !l ~ .I ps Domestic RDlurn Receipt ~ 14u...~&_ Respectfully submitted, Date: zJ/3((( I l ) 'IJ'H.-~I /J. ,(/.~u t p. anne B. Wigbels, Esquire aw Offices of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ION 68735 Tel. (717) 763-1800 cc: Michael Bangs, Esquire, Custody Conciliator ~ 1" I I . >. Cl cr: ~c < 1:- c'.6 ' , , ~~' :;; . ~-::; '-, ~:J ~t- ,- -, ...,] I, :.; rEt. c...., ,\j ...., :::.J.. ,- l.L. ~ I'. r-- ,) 0 0' ~, t f JOHN W. KICHMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO, 97-115 CIVIL TERM JENNIFER MERCURIO, Defendant CIVIL ACTION - LAW CUSTODY ORDER AND NOW, this 7~ day of ""~ , 1997, upon receipt of the Conciliator's Report, it appearing that the Plaintiff and his counsel appeared at the conference, but that the Defendant did not appear although she was served with the Petition setting the conciliation, it is hereby ordered and directed as follows: Father shall have primary custody of the minor child, Pamela Summer Kichman, d.o,b, July 7, 1993, subject to periods of partial custody and visitation with Mother as agreed upon by the parties, In the event that Mother feels aggrieved by this Order, she may petition the court for another conciliation to set a more definitive schedule, BY THE COURT, 4- /IlL J, Jeanne' Wigbells, Esquire Ms. Jennifer Mercurio, pro se mlb _ Q.;..,{J.....,'>IA<:.(~<( ."I.'i/'i') -u .J f ...-: " Ii " , I , .. , , " L lJ j - " (--. j ll' ,~) ~ r I ~, , 5. The Plaintiff's position on custody is as follows: See attached Ordar. 6. The Defendant's position on custody is as follows: See attached Order. 7, Need for separate counsel to represent child(ren): Neither party requested. 8. Need for independent psychological evaluation or counseling: None requested and the Conciliator does not believe any is necessary. Date: February 25. 1997 , ... \ I' !. / Y-I/(, :;:, L,,;:..j j Michael L. Bangs I Custody Conciliator tl .,. c ~r;~~~'if;f{ ;~':~i"\-c . j',t:::'~-J,<"t(f: :~ ;;.-- ".; .. .y~ .. 0:) .' ;~'.-., . -~ ..;~; ri;~..' I I I , ! i l";-"; !" t ;.....,..~' _i._~-S 'i.; ,'" ,.,,-, '--, , - .. ,. MJ:OuAB:!:. L BANOS , Al'roRl:mY AT LA.'" .~. \-. "'" ',.'. CifI'TlFlCD rx>f"( , tf/o ' " ,:;:'rE~~~')~t<: ;.,' ,>-jj,. ;,';~.:;:i;::j\ -.-:",,,;. "~:,j.- '~".":' .~~~~~~fll~t~jif~};~~t~;ii: ,J- , _', _~'tlO~'l8Tn-~DBT CMlI' i!n.Li:l'.allNilVJ.v~1A ItO!! "'''.,- . ~- ,j.:. :";i;'~ , ;..~... >.i,;<:"t .. .',' ~ ..'el'" ~i! \"..., "'i,, A~Pllii. :"}',~".::~' - - ... ,n. 'F"<iC;, - , ,--\.~~ '\;/ <-~:. ~>. i'S"-i ,o.>i ,-"-...._~ ,,,' -.:; '<"~'" ": ,):.", ...Lu',.. .'," I I I t ........ ._~ .-.- ONE COURTHOUSE SOUARE CARLISLE, PA 17013 ,tu r' 'LfL (l ,.{ J// . ): ..(1, )J fl ,,::"'-"- (0) J-{ , 'f"J\ y' IjvU wJv {', ~(~U Thomas E, Cheffins, Esq, COURT ADMINISTRATOR Ms, Jennifer Mercurio 919-A Hummel Avenue Lemoyne. PA 17043 (~ /\ / \'\ C/\ \ \~OQ,:)-\~Q,"S OQ, I."III",III""I"J"/I",.III,/,,,I..I,),I,I,I.,,..II,II..I .. ,";..:~-...- JOHN W. KICHMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO, 97-115 CIVIL TERM JENNIFER MERCURIO, Defendant CIVIL ACTION - LAW CUSTODY ORDER AND NOW, this j'-xL day of , 1997, upon receipt - 111'\ \( k, of the Conciliator's Report, it appearing that the Plaintiff and his counsel appeared at the conference, but that the Defendant did not appear although she was served with the Petition setting the conciliation, it is hereby ordered and directed as follows: Father shall have primary custody of the minor child, Pamela Summer Kichman, d.o.b. July 7, 1993, subject to periods of partial custody and visitation with Mother as agreed upon by the parties. In the event that Mother feels aggrieved by this Order, she may petition the court for another conciliation to set a more definitive schedule, BY THE COURT, I <; / 'iT; H ~ (/ ).k.4A/' Jeanne' Wigbells, Esquire Ms. Jennifer Mercurio, pro se mlb J, TRUE COpy FROM RECORD In T~,: lIl"n~' .:i', r of, I h',re unto set my hand allJ Ihe :,JI CO , '.J CnU:'1 at Carlisle Pa l ' . This 3~, ~ay of I.'l~", 19'0.. ..........,.",..../".'kJ(c. l"'<II' ' v . . ~,. .\.r......_._ ~, r It.J_ Prothonotary I i JOliN W. KICIIMAN IN TilE COURT OF COMMON PLEAS OF ('l IMBERLAND COUNTY. PENNSYLVANIA I'LAINTJFF v, 97-115 CIVil. ACTION LA W JENNIFER MERCURIO DEFENDANT IN CUSTODY ORnER OF COllIn AND NOW. Tuesday, February 12, 2002 . upon considcration of the attached Complaint, it is hereby directed that parties and their respective counsel appear berore Melissa 1', Greevy, Esq, al 301 Markel Street, Lemoyne,l'A 17043 on Tuesday, March 05, 2002 . the conciliator. at 1:00 PM ror a Pre-Hearing Custody Conference. At such conference. an enor! will be made to resolve the issues in dispute; or irtbis cannot be accomplished, to deline and narrow the issues 10 be heard by the court, and to enter into a temporary order. All children age live or older may also be present althe conference, Failure to appear at the conferencc may provide grounds for entry of a temporary or pennanenl ordcr, The court hereby directs the parties to furnish aoy and all exlstin!: Protection from Abuse orders, Special Relief orders, and Custody orders 10 the conclllator 48 honrs prior to scheduled hearln!:, FOR TilE COURT. By: /s/ Mellli,.l P. Greev)'.,ESfj, ))"" Custody Conciliator ~ The Court of Common Pleas of Cumberland County is rcquired by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable necommodations available to disabled individuals having business bclilre the court. please contact our office. All arrangements must be made at least 72 hours prior to nny hcaring or busincss beliJre the court. You must attend Ihe scheduled conference or hearing. YOU SIIOULD TAKE TillS PAPER TO YOUR AITORNEY AT ONCE. IF YOll DO NOT IIA VE AN AITORNEY OR CANNOT AFFORD ONE. GO TO OR TELEPIIONE TilE OFFICE SET FORTII BELOW TO FIND OUT WIIERE YOU CAN (iET LEOAL IIELI>, Cumberland Counly Bar Association 2 Liberty A venue Carlisle. Pennsylvania 17ll 13 Telephone (717) 249-3166 JOHN W. KICI/MAN. Plaintiff/Respondent IN TIlE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYI.V ANIA v. NO. 97-115 CIVIl. TERM JENNIFER MERCURIO, DefendanllPetitioner CIVIL ACTION - LA W CIIILD CUSTODY PETITION TO MODIFY CUSTODY ORDER AND NOW comes the Petitioner, Jennifer Mercurio, by and through her attorneys, the Law Offices ofSilliker and Reinhold. and respectfully reques1s this Honorable Court modify the Custody Order dated March 3, 1997, and in support thereof avers the following: 1. Petitioner is Jennifer Mercurio. hereinafier referred to as "Mother", an adult individual currently residing at 219 Wyoming Avenue, Enola. Cumberland County. Pennsylvania 17025, 2. Respondent is John W. Kichman, hereinafter referred to as "Fa1her", an adult individual currently residing at 260 North Enola Drive, Enola, Cumberland County. Pennsylvania 17025. 3. The subject minor child is Pamela Summer Kichman, born July 7, 1993. 4. A Custody Order was entered on Murch 3. 1997, wherein Father was enlitled to primary custody of the suhject minor child with periods of partial custody and visita1ion with Mother as agreed upon by the parties. At the lime of the Custody Conciliation which resulted in the entry of the Order duted March 3. 1997. the pm.ties were in the process of reconciling and Futher requested thut Mother nol uppeur IiII' Ihe hearing so as to simplify the process. 5. Since the entry of the Court's previous Order, the child hus resi,k'd lit the following residences in the custody of the following people: a, From March. 1997 to September. 1997 - the subject minor dlild resided with her Father and paternul grandmother und grandlilther at 21 Aeri Mcadow Road, Enola. Cumberland County. Pennsylvuniu, b, From September. 1997 to August. 1998 - the subject minor child resided with her Mother und Father ut II Roosevelt Streel, bllllu, Cumberland County. Pennsylvaniu. c. From August, 1998 to September, 1998 - the suhjectminor child resided with her paternal grandmolher and grandlil\her III 21 Ani Mcadow Road. Enola. Cumberlund County, Pennsylvunia, d. From September. 1998 to Deccmher. 1<)98 Ihe suhjcclmiuor child resided with her paternal aunt. Brendu Kooney. in Meehanieshllll!. Cumberland County. Pennsylvuniu e. From December. 1998 to OCloher. 111<)'1 Ihe suhjeelmiuor child resided with her Mother und Futher ut II Roos"ldt SIr,.,.t. I'nola. Cumberland County. Pennsylvuniu, t: From October. 19<)<) to August. 2000 the suhieclminor child resided with her Father ut 11 Roosevelt Slre,.t. blllla. ( 'umherlallll County. Pennsylvaniu. I), Molh~r fi:urs thut Futher will ull~mpltll snuteh despite the child's desire l ~ to remain in the euslody of her Mother, I 0, Th~ child hus thrived in the primary care of her Mother ovcr the pust 18monlhs, The suhj~ct child's grades huve improved tremendously ovcr thut period of time and she is psychologic.llly well udjusted in h~r pr~sent situution, 11. Mother bclicves und therelllre uvers that il is in the best intercsts of thc subjcct minor child lhut she continuc to rcmain in hcr primary cure. Datc: ;;"'/7 !r\J.. Resp~clfully submined. TilE LAW OFFICES OF 7~~ Kristin R, Reinhold. Esquire 5922 Linglcstown Road Harrisburg. P A 17112 (717) 671-1500 I.D. No, 57911 - Allorl1ey Il)r J~nnifi:r Mercurio ~~t; H 711[1) t ~ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 97-115 CIVIL TERM CIVIL ACTION - LAW " JOHN W, KICHMAN, v, JENNIFER MERCURIO, IN CUSTODY Defendant Hess, J, - ORDER OF COURT AND NOW, this :1 ~ ~ day of March, 2002, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1, Legal Custody. The parties, John W. Kichman and Jennifer Mercurio, shall have shared legal custody of the minor child, Pamela Summer Kichman, born July 7,1993, 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 Pa,C,S, 95309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent, 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. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational records, attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, IEP meetings, extracurricular activities, child's parties, musical presentations, back-to-school night, and the like, 2. Physical Custody. Physical custody shall be arranged as follows: Mother shall have primary physical custody. Father shall have partial physical custody which shall be arranged as follows: A. Effective March 8, 2002, on alternating weekends from Friday at 5:00 p.m. until Sunday at 5:00 p.m. However, in the event that one of the alternating weekends is Father's weekend for guard