HomeMy WebLinkAbout97-00632
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
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CAROL A. REIDENBACH,
Plaintiff
v.
CIVIL ACTION - LAW
IN CUSTODY
NO. 97- (;>3;) [wJ\:!tU"
THOMAS W. REIDENdACH, SR.
Defendant
ORDER OF COURT
AND NOW, this ~ ~
day of February, 1997, upon
consideration of the attached complaint, it is hereby directed
that the parties and their respective counsel shall appear before
}l Jr, ~ X &;/IOtl, r~~ , the Conciliator, at (vnt, /..1 (:..//
. ;' (' Lf'1
((Jill':' ~111~" { U f' , ("t'I {Y'rir.q. on the
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day of
lip" I
,1997 at 7:~o <A.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/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,
...1 :
By: Fltl~.
custody
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, 4TH FLOOR
CARLISLE, PA 17013
(717) 240-6200
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CAROL A. REIDENBACH,
Plaintiff
v.
CIVIL ACTION - LAW
IN CUSTODY
NO. 97- (. ~..L- ~ T.:i.-
THOMAS W. REIDENBACH, SR.,
Defendant
COMPLAINT FOR PRIMARY CUSTODY AND VISITATION
AND NOW, this 6th day of February, 1997, comes Plaintiff,
CAROL A. REIDENBACH, by and through her attorney, Michael J.
Hanft, Esquire, and files the following Complaint for Primary
custody and Visitation and in support thereof avers as follows:
1. The Plaintiff is CAROL A. REIDENBACH, an adult
individual residing at 30 Bellaire Avenue, Carlisle, Cumberland
County, Pennsylvania.
2. The Defendant is THOMAS W. REIDENBACH, SR., an adult
individual residing at 1925 Esther Drive, Carlisle, Cumberland
County, Pennsylvania.
3. The Plaintiff seeks primary custody and visitation of
the following children:
.
i,.
5. The relationship of the Defendant to the children is
that of father. The Defendant currently resides alone.
6. Plaintiff has not participated as a party or witness,
or in any other capacity, in other litigation concerning the
custody of the children in this or another court.
The Plaintiff has no information of a custody proceeding
concerning the custody of the children 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 children or claims to
have custody or visitation rights with respect to the children.
7. The best interests and permanent welfare of the children
will be served best by granting the relief requested because:
a) The Plaintiff has had shared physical and legal custody
of the children since the children's birth;
b) The Plaintiff provides the children with a home with
adequate moral, emotional and physical surroundings as required
to meet the children's needs;
c) The Plaintiff is, and has always been, willing to accept
custody of the children; and
d) The Plaintiff continues to exercise parental duties and
responsibilities and enjoys the love and affection of the
children.
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1. The Parties agree that Wife shall have primary legal and
physical custody of the Children with Husband having frequent and
reasonable visitation. Except as provided hereinbelow, and
unless otherwise agreed by the Parties, Wife shall have primary
physical custody of the Children, subject to Husband's periods of
visitation.
Neither Party shall move his or her residence from
Cumberland County, Pennsylvania, without first giving sixty (60)
days' notice to the other Party. At that time, either Party can
petition the Court of Common Pleas of Cumberland County,
Pennsylvania for modification of custody, if necessary.
Each Party shall be responsible for the day-to-day decisions
while he or she has custody of the Children. It is agreed
between the Parties that any decisions regarding medical
treatment (other than emergency treatment) to be rendered to the
Children will be made jointly.
2. Each party agrees to keep the other apprised of any and
all matters relating to the Children's health, education,
welfare, and activities.
3. Custody
a. The Parties hereto agree that they will cooperate
and be as flexible as possible with regard to custody of the
Children at all times, but especially for any holiday or extended
vacation period.
C'MMI.u.dLYLAWOI\l>lrF.lJJDDi.....''''''ITI>DYAGII
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b. Husband and Wife shall discuss and agree on a
custody schedule for the Children at least two (2) weeks prior to
any holiday.
c. It is the intent of the Parties that transportation
of the Children between parents for all purposes, but especially
custody purposes, shall be as flexible and accommodating as
possible. It is recognized that transportation will obviously be
dependent upon each party's personal circumstances and
employment.
d. The Parties may agree to modify this schedule
without the necessity of a Court Order. It is specifically
agreed between the Parties that visitation shall be as
reasonable, liberal and frequent as possible.
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4. The Parties hereby agree that as long as there is no
cost involved, both Husband shall carry Wife and the Children on
his health insurance coverage as long as they are eligible for
said coverage. If and when health insurance becomes an out of
pocket expense, the Parties will equally share the costs of
providing the children with the same coverage as is currently in
effect as of the date of this Agreement.
a. The Parties agree that they will equally share in
any unreimbursed medical expenses incurred for the care of the
Children pursuant to subsection (d) above.
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