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HomeMy WebLinkAbout97-02631 ~ ~ .... 3 ~ - q: c:Q \ ~ , ~/ - . - ::> -- - t't) ...) t1 ~ ~. . ~ .-- Co 1:'- f'. t:: I: f',J , - u.1 Ct. Ii.' 0', '. , - 0'. :_J Cl~ '0 r"' HI> t ~...l. ~'. , r. 0 L'. r'~ 1....) (S" ..0 . <.l 0: i 8 :s ~ olI n:;::;;; ~ ii!~~... ~~8~6:: o~~~~.... 3~"'~s~~ [:; ~i;::;:: i5 N~-- '" '" ~ I '" . . ~ rr; ~"': W~! (;tOJ' [-',' ..... 2~" 14.1(.; -' . L.:'" ;:~ 1:5 -. ". -', =-j ,... 0' ,.... , r-: c;:, ",'. . - H. .' :.:.- ^;. <::. C'; ,'(:--J] '._li.L ::~i u tJ '" i 0 0 3 '" ~ ol:I ~ ! <> ~ .. .. ~ L~ ~ ... I ~ '" '" <> <> o'"q ... ... '" '" 3~'" ~ ~ -- .. .. ... ... ~! ~ ~ 5 .. .. '" I '" - -. .__ __._..__n__._.._.____L._.___.___1__ > * We1l6'-1 L. Ba\d'-J~r, Plaintiff : IN THE COURT OF COMMON PLEAS OF :CUMBERLllND COUNTY, PENNSYLVANIA . . V * RDber\- A. Ba Icl"-Jif'\ Defendant :CIVIL ACTION - LAr'l ~NO. r)fo~ \ CIVIL :CUSTODY/VISI-TATION 19"1 '. ORDER OF COUR!!:' AND NOr'l, this (date) GI :so/ell , upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel a pear before l:::OWI\ ~"I." roo" . 2,,~, the conciliator, at , I I . I on the \ ~ day of I) , 19Q, ,. t -Ll ~ 0\'\ A, M., for a Prehearing Cus dy 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/children's attendance is not mandatory. Failure to appear at the conference'may provide grounds for entry of a temp,?rary or permanent order. FOR THE COURT: By: ~ llJi\ ~..sAJ 1Jl'\rl.avr I rMh....- Custody Conciliator ~.) cr 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 WENDY L. BALDWIN, . IN THE COURT OF COMMON PLEAS OF . plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : VB. : NO. 97-2631 CIVIL TERM CIVIL ACTION - LAW ROBERT A. BALDWIN, . . Defendant IN DIVORCE AMENDED COMPLAINT UNDER SECTION 3301(0) OR 3301(dl OF THE DIVORCE CODE AND NOW COMES the above-named Plaintiff, by Lori K. Serratelli, Esquire and the law firm of SERRATELLI, SCHIFFMAN, BROWN' CALHOON, P.C., and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: COUNT I 1. Plaintiff is Wendy L. Baldwin who previously resided at 6307 Valley Brook Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055, since October 1, 1996, and now resides at 945 South 31st street, Camp Hill, Cumberland County, Pennsylvania 17011, since June 6, 1997. 2. Defendant is Robert A. Baldwin, who currently resides at 6307 Valley Brook Drive, Mechanicsburg, cumberland county, Pennsylvania 17055, since october 1, 1996. 3. plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on July 15, 1993, in Ocean city, Maryland. 5. The Plaintiff has been advised of the availability of counseling and that she may have the right to request that the Court require the parties to participate in counseling. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. The Defendant is not a member of the Armed Services of the United states or any of its allies. 9. The Plaintiff and Defendant are both citizens of the United States. 10. Plaintiff avers that there is one child of the parties under the age of 18, namely Robert Charles Baldwin, born April 10,1 992. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony. COUNT II 11. Paragraphs one through ten are hereby incorporated by reference herein. 12. Plaintiff believes that the best interest of the parties' child, Robert Charles Baldwin, born April 10, 1992, . t'-~ ~1 00 ... ...... ~ 1 ~ 4 s: ..... r: ..- ,- ~! !' , .- , t ( , (' u '" :i :5 :i c:; '^ ~ ~ p::::: dc;l~;;:'^ atQN ~ 3 ~! ~ ~ ~J III ~ .... ... ... '^'^ ;:... ~~ ...::, .. Co ,~ ! III l-. . . , , , , '. " 3. with respect to holidays: A. Mother shall be entitled to have the child Mother's Day; Father shall be entitled to have the child Father's Day at times mutually agreed upon by the parties. B. The Christmas Holiday shall be divided in segments and alternated yearly with Mother having Segment A (December 24 at Noon to December 25 at noon) for 1997 and Father having Segement B (December 25 at noon to December 26 at noon). C. The parties shall alternate the following holidays: Easter, Memorial Day, Fourth of July, Labor Day, Thanksgiving and New Year's Eve. The pick up and drop off times shall be as mutually agreed to by the parties 4. Father shall be entitled to two (2) non-consecutive weeks of uninterrupted partial custody of the child without the other exercising visitation, unless the parties mutually agree to do so, during the summer with thirty (30) days notice to the other of the weeks each wishes. Mother shall be entitled to two (2) non- consecutive weeks of uninterrupted partial custody of the child without the other exercising visitation, unless the parties mutually agree to do so, during the summer with thirty (30) days notice to the other of the weeks each wishes. " 5. Father shall be responsible for picking up the child at the beginning of his periods of partial custody and returning the child at the end of his periods of partial custody. 6. The parties shall, at all times, foster a positive, meaningful and loving relationship between the child and the other parent, and neither parent shall say or do anything which would cast the other parent in an unfavorable or negative light to the child, it being specifically agreed that neither parent shall make any detrimental or disparaging comments about the other parent to the child or in the presence of the child that would in any way denigrate the other parent. 7. Both parents shall attempt, by all possible means, to foster the child's relationship with the other parent. Both parents realize and appreciate that it is critical for the child's health and development that the child feels good about and loving towards both parents and that both parents play a major role in helping to achieve this goal. 8. Plaintiff and Defendant shall communicate directly concerning the child or the visitation schedule and will nut communicate through third parties unless there is an emergency necessitating such communication. 9. Both parties shall keep the other informed of their current telephone number and address. ~;.;, c.... "'~.J" ~ ( : -, 'i ! '.. I .-: C' ". '''-, I I C, I. . " " 3. with respect to holidays: A. Mother shall be entitled to have the child Mother's Day; Father shall be entitled to have the child Father's Day at times mutually agreed upon by the parties. B. The Christmas Holiday shall be divided in segments and alternated yearly with Mother having Segment A (December 24 at Noon to December 25 at noon) for 1997 and Father having segement B (December 25 at noon to December 26 at noon). C. The parties shall alternate the following holidays: Easter, Memorial Day, Fourth of July, Labor Day, Thanksgiving and New Year's Eve. The pick up and drop off times shall be as mutually agreed to by the parties 4. Father shall be entitled to two (2) non-consecutive weeks of uninterrupted partial custody of the child without the other exercising visitation, unless the parties mutually agree to do so, during the summer with thirty (30) days notice to the other of the weeks each wishes. Mother shall be entitled to two (2) non- consecutive weeks of uninterrupted partial custody of the child without the other exercising visitation, unless the parties mutually agree to do so, during the summer with thirty (30) days notice to the other of the weeks each wishes. 5. Father shall be responsible for picking up the child at the beginning of his periods of partial custody and returning the child at the end of his periods of partial custody. 6. The parties shall, at all times, foster a positive, meaningful and loving relationship between the child and the other parent, and neither parent shall say or do anything which would cast the other parent in an unfavorable or negative light to the child, it being specifically agreed that neither parent shall make any detrimental or disparaging comments about the other parent to the child or in the presence of the child that would in any way denigrate the other parent. 7. Both parents will attempt, by all possible means, to foster the child's relationship with the other parent. Both parents realize and appreciate that it is critical for the child's health and development that the child feels good about and loving towards both parents and that both parents play a major role in helping to achieve this goal. 8. Plaintiff and Defendant agree that they shall communicate directly concerning the child or the visitation schedule and will not communicate through third parties unless there is an emergency necessitating such communication. 9. Both parties shall keep the other informed of their current telephone number and address.