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MANCKE, WAGNEFl. HERSHEY & TULLY,
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5. Since the entry of the Order, the plaintiff's work
schedule has changed in that he was originally working from 6:00
a.m. until 2:30 p.m., and will now be required to work from 10:30
a.m. until 7:00 p.m.
6. As a result of the aforementioned change, plaintiff
desires to change the April 4, 1997, Order in paragraph 2(A) and
2(8) to provide that the alternating weekends would be from
Saturday morning at 8:00 a.m. until Monday afternoon at 2:00 p.m.
and every Wednesday from 7:30 p.m. until Thursday at 2:00 p.m.
7. No other provisions of the Order need to be changed.
8. plaintiff believes it would be in the best interest of
the child to have the aforementioned changes occur to accomodate
the schedules of the respective parties.
WHEREFORE, plaintiff prays this Court to grant the relief as
requested.
Respectfully submitted,
MANCItB,
, TULLY
/
. R wagner, Esqu re
1. D 103
2233 North Front Street
Harrisburg, PA 17110
(717) 234-7051
Attorney for plaintiff
DATE: t/;5/qi
I /
3, The parties shall alternate the mttior holidays, those holidays being
defined as Easter, Memorial Day. Fourth of July, Labor Day, and New Year's
Day, These periods of partial eustody and visitation shall be from 8:00 a,m, until
8:00 p,m,
4. The Thanksgiving holiday will be broken into two segments. Segment
A shall be from Thanksgiving Day from 8:00 a.m, until 8:00 p,m" and Segment B
shall be on the Friday following Thanksgiving Day from 8:00 a.m. until 8:00 p,m.
Father shall have Segment A in 1999 and all odd-numbered years thereafter and
Segment B in 1998 and all even-numbered years thereafter, Mother shall have
Segment A in 1998 and all even-numbered years thereafter and Segment B in
1999 and all odd-numbered years thereafter.
5, The Christmas holiday will be broken into two segments, Segment A
shall be from December 23rd at 12:00 noon until Christmas Day at 12:00 noon,
and Segment B shall be from Christmas Day at 12:00 noon until December 27th
at 12:00 noon, Mother shall have Segment A in 1999 and all odd-numbered years
thereafter and Segment B in 1998 and all even-numbered years thereatler, Father
shall have Segment A in 1998 and all even-numbered years thereafter and
Segment B in 1999 and all odd-numbered years thereafter,
6. Eaeh party will be entitled to four (4) non-consecutive weeks of
summer vacation, The parties shall provide each other with thirty (30) days
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apart for approximately six (6) months.
6. During the six months time in 1996 that the parties
were living separate and apart, and since the parties have been
living separate and apart since January 3, 1997, the Mother has
had primary physical custody of the minor child and the Father
has had partial physical custody on alternating weekends and
occaisonally saw the minor child on Wednesdays.
7. Without Mother's permission, Father took minor child
from the custody of Mother stating that he was not bringing the
child back to Mother.
8. Father proceeded to transport the child to his
residence in Perry County without the aid of a car infant seat as
prescribed by statute, and has refused to return the minor child
to Mother.
8. Mother desires this Honorable Court to enter a
temporary order restoring the status quo of granting mother
primary physical custody and allowing father partial physical
custody every other weekend from Friday at 6:00 p.m. until Sunday
at 3:00 p.m. beginning on February 7, 1997, until further order
of court.
Brownawell at 104 Oak Hill Road, Carlisle, cumberland
County, Pennsylvania;
B. From October 1995 until December of 1995, with the
Plaintiff and Defendant at 403 Meadow Lanes, Shermans
Dale, Perry County, Pennsylvania;
C. From December of 1995 until July of 1996, with the
Plaintiff and the Defendant's parents at the address
contained in paragraph 2 above.
D. From July of 1996 until December of 1996, with the
Plaintiff and Defendant at the address contained in
paragraph 1 above.
E. From December 1996 until the present, with the
Defendant and Defendant's parents at the address
contained in paragraph 2 above.
5. There has been no other action for custody or partial
custody of this child, nor has any person kown to the Plaintiff
asserted a right to custody or partial custody of the child.
6. There is no current order in place.
7. Plaintiff believes and therefore avers that it is in the
best interest of the child, KAYLA A. WARNER, to grant partial
custody unto the Plaintiff herein in order to provide a schedule
of contacts between parent and child, it being in the best
interest of the child to provide a partial custody arrangement.
BRIDGET
J. CONRAD,
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97- ~80 CIVIL TERM
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JEFFREY A. WARNER,
D&l..RJ....t
RMfI,...;..,,,L / P/FI
ORDER OF COURT
AND NOW, this I+~ day of ~h:?1.({A... , 1997,
upon consideration of the attached Complaint, ~ is hereby
directed that the parties and their respective counsel shall
appear before "7V/(~!.t,~Jf,y' ,/i",...,., f~ , the Conciliator,
at I 5 <I? ,. /'.... '1}7)j! (/ ,on
the /1"1. day of , 1997 at I 4'i'iJ /' .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 narrow the issues to be heard by
the Court, and to enter into a Temporary Order. All children age
five or older shall also be present at the Conference. Failure
to appear at the Conference may provide grounds for entry of a
temporary or permanent Order.
CIVIL ACTION - CUSTODY
FOR THE COURT,
.
By: /5/ 'Ivl.<</C,J) ,y, \6h.....'" ~
Custody Conciliator /(/>JI'sjRL-
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 of business
before the court. You must attend the scheduled conference or
hearing.
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 AD~INISTRATOR
COURTHOUSE, 4TH FLOOR
CARLISLE, PA 17013
(717) 240-6200
C.~'t'CaGADW"(H."1lATJ<<lT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
BRIDGET J. CONRAD, .
I~I /I.L/I .
Plaintiff I
I CIVIL ACTION - LAW
v. : IN CUSTODY
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.
JEFFREY A. WARNER, kc"p jl):;{ NO. 97-
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NOTICE
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take action
within twenty (20) days after this complaint and notice are
served, by entering a written appearance personally or by
attorney and filing in writing with the court your defenses or
objections to the claims set forth against you. You are warned
that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the court without further
notice for any money claimed in the complaint or for any other
claim or relief requested by the plaintiff. You may lose money
or property or other rights important to you.
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
Fourth Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
HANFT & VOHS
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William C. Vohs, Esquire
Attorney 10 No. 65208
11 West Pomfret Street, Suite 2
Carlisle, PA 17013
(717)249-5373
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
BRIDGET J. CONRAD, I
Plaintiff .
.
. CIVIL ACTION - LAW
.
v. I IN CUSTODY
.
.
JEFFREY A. WARNER, . NO. 97-
.
Defendant .
.
COMPLAINT FOR PRIMARY PHYSICAL CUSTODY
AND NOW, this 30e day of 'J~,\U....)- , 1997, comes
Plaintiff, Bridget J. Conrad, by and through her attorneys, HANFT
& VOHS, and files the following Complaint for Primary Physical
Custody and in support thereof avers as follows:
1. The Plaintiff is Bridget J. Conrad, an adult individual
residing at 104 Oak Hill Road, Carlisle, Cumberland County,
Pennsylvania, 17013.
2. The Defendant is Jeffrey A. Warner, an adult individual
residing at 403 Meadow Lane, Shermans Dale, Perry County,
Pennsylvania, 17090.
3. The Plaintiff, Mother, seeks primary physical custody of
the following child:
Name
Present Residence
Aae
Kayla A. Warner
403 Meadow Lane,
Carlisle, PA 17013
Ii
5/7 /95
The child was born out of wedlock.
The mother of the children is the Plaintiff, who resides at
104 Oak Hill Road, Carlisle, Cumberland County, Pennsylvania.
She is not married.
C.~TCl>>lJ.ADIK'llItUDTCOW
The father of the children is Defendant, who resides at 403
Meadow Lane, Shermans Dale, Perry County, Pennsylvania. He is
not married.
4. The relationship of Plaintiff to the children is that of
natural mother. The plaintiff currently resides with the child
and her parents.
5. The relationship of Defendant to the children is that of
natural father.
6. plaintiff has not participated as a party or witness, or
in any other capacity, in other litigation concerning the custody
of the child in this or another court.
The plaintiff has no information of a custody proceeding
concerning the custody of the child in this or any other court.
The 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.
7. The best interests and permanent welfare of the child
will be served best by granting the relief requested because I
a) The plaintiff is the natural mother of the minor
children;
b) The Plaintiff has had primary physical custody of the
child since the parties separated on January 3, 1997;
c) The plaintiff is ready, willing, and able to provide the
child with a home with adequate moral and emotional and
physical surroundings as required to meet the child's needs
and best interest;
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d) The Defendant has demonstrated that he is not able to
care for the child on a primary or full time basis~
e) The Plaintiff is able provide the child with a more
stable and emotionally balanced home and home life than the
defendant~ and
f) The child's emotional, spiritual, and physical well
being are presently being maintained by the Plaintiff and
Plaintiff, due to her station in life and her love and
affection for her child, is in a better position to continue
to provide for these needs.
B. Each parent whose parental rights to the child have 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 or claim a right to custody
or visitation of the child.
WHEREFORE, Plaintiff, Bridget J. Conrad, respectfully
requests Your Honorable Court grant Plaintiff primary physical
custody of the minor child, Kayla A. Warner.
Respectfully submitted,
HANFT & VOHS
tvW1 U&Z-
William C. Vohs, Esquire
Attorney 1D No. 6520B
11 W. Pomfret Street, Suite 2
Carlisle, PA 17013
(717) 249-5373
Attorney for Plaintiff
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C. On Wednesday preceding Father's weekend
visitation from after work until 8:00 p.m.
3, The parties shall alternate the major holidays, those hulidays
being defined as Easter, Memorial Day, Fourth of July, Labor Day, and
New Year's Day, These periods of partial custody and visitation will
be from 8:00 a,m, until 8:00 p.m,
4, The Thanksgiving holiday will be broken into two segments,
Segment A shall be from Thanksgiving Day from 8:00 a,m, until 8:00
p,m" while Segment 8 shall be on the Friday following Thanksgiving
Day from 8:00 a,m, until 8:00 p,m, Father shall have Segment A in
1 997 and all odd-numbered years thereafter and Segment 8 in 1998
and all even-numbered years thereafter, Mother shall have Segment 8
in 1997 and all odd-numbered years thereafter and Segment A in
1998 and all even-numbered years thereafter,
5, The Christmas holiday will be broken into two segments,
Segment A shall be from December 23rd at 12:00 noon at Christmas
Day at 12:00 noon, and Segment 8 shall be from Christmas Day at
12:00 noon until December 27th at 12:00 noon, Mother shall have
Segment A in 1997 and all odd-numbered years thereafter and
Segment 8 in 1998 and all even-numbered years thereafter, Father
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MANCtcB. VVAONBA. HERSHEY &.. TULLY
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JEFFREY A. WARNER,
Plaintiff
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYL VANIA
vs,
NO, 97-486 CIVIL TERM
BRIDGET j, CONRAD,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
AND NOW, this
ORDER
day of ..At>-t:::.t-.!.....,
.
. 1998, upon receipt of the
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Conciliator's Report. it appearing that the parties have agreed to the tenns and provisions of this
Order which was dictated in their presence and approved by them, it is hereby ordered and
directed as follows:
I. The parties shall share legal custody of their minor child. Kayla A.
Warner. d,o,b, May 7,1995,
2, Mother shall have primary physical custody of the minor child subject
to periods of partial custody and visi':llion with Father as follows:
A. On alternating weekends from Thursday after Father gets off
from work unul Sunday at 8:00 p.m, This alternating weekend schedule
shall commence on September 3, 1998.
B, On alternating Wednesdays beginning when Father picks up
the child after work until Thursday at which time Father will drop the
child ofT at the appropriate day care provider. This alternating
Wednesday schedule shall commence on September 9,1998,
3, The parties shall alternate the major holidays, those holidays being
defined as Easter. Memorial Day, Fourth of July, Labor Day. and New Year's
Day. These periods of partial custody and visitation shall be from 8:00 a,m, until
8:00 p,m.
4, The Thanksgiving holiday will be broken into two segments, Segment
A shall be from Thanksgiving Day from 8:00 a,m, until 8:00 p,m., and Segment B
shall be 011 the Friday following Thanksgiving Day from 8:00 a,m, until 8:00 p,m.
Father shall have Segment A in 1999 and all odd-numbered years thereafter and
Segment B in 1998 and all even-numbered years thereafter, Mother shall have
Segment A in 1998 and all even-numbered years thereafter and Segment B in
1999 and all odd-numbered years thereafter,
5. The Christmas holiday will be broken into two segments, Segment A
shall be from December 23rd at 12:00 noon until Christmas Day at 12:00 noon,
and Segment B shall be from Christmas Day at 12:00 noon until December 27th
at 12:00 noon, Mother shall have Segment A in 1999 and all odd-numbered years
thereafter and Segment B in 1998 and all even-numbered years thereafter. Father
shall have Segment A in 1998 and all even-numbered years thereafter and
Segment B in 1999 and all odd-numbered years thereafter,
6. Each party will be entitled to four (4) non-consecutive weeks of
summer vacation, The parties shall provide each other with thirty (30) days
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JEFFREY A. WARNER,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
NO. 97-486 CIVIL TERM
BRIDGET J. CONRAD,
Defendant
CIVIL ACTION - LAW
CUSTODY
ORDER
AND NOW, this ~ day of
, ) (>It i
-- ~ --......
, 1999,
upon review of the Conciliator's Report, it appearing that the
parties have agreed to the terms and provisions of this Order which
was dictated in their pres2r,c", and approved by them and their
counsel, it is hereby ordered and directed as follows:
1. The Order of September 14, 1998 shall remain in full
force and effect except for the following modifications:
A. Paragraph 2 (A) shall be modified such that on
alternating weekends Father shall have the child
from Thursday at 3: 30 p. m., at which time Father
shall pick up the child at the daycare provider,
until Sunday at 7:30 p.m., at which time he shall
drop the child off at the Mother's residence. This
alternating weekend
schedule
shall
conunence
September 2, 1999.
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