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Home My WebLink About97-03699 I, :1 I: " CLooO; II I 01-< ~~ffi 'I ~ (I " ..J~E-l.... .., I, ! :' ::1 t: _ :s ..... - c II I-< n ::: ;; " ~ ..... E-lb1 . - iffi~~> il :; ~ iol - .... ~~ .n< .., I .j, ,j, ~ _ 0. - c II ";; e!- a.1-< e i~ tl[;l :1 , _ u ~ ~ pi "i e, ~ = . F;UJ ~! II " tJJ _ C - 0 ~ I-<~ a. " = ... = c ,_ [) ",~8 :> il i: ~ - - " c f;l CLI :; .g ~ " " ..J Ii O::Ot.1'; "'-5 '" z a. ..J i! ~ . ~ ~..JI-< CLI " ~Ul 'I ~ ::; gs '. e . I-< :I: :1 B " ~r-> ~ U ",I-< I-< 'I u z f;J ffi . i ~ I e:;<Il~ I-< :1 ~e ~ . . _...L -- .'1('_ , , 4 AARON CAMUS PETERSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 97-3699 CIVIL TERM TRINA MICHELLE PETERSON, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER OFaxJRT AND ocw, this \/d-- day of ''Y?A1/n / , 1997, upon consideration of the attached Custody concilia't'fo~~, it is ordered and directed as follows: 1. The Father, Aaron C. Peterson, and the Mother, Trina M. Peterson, shall have shared legal custody of Nicholas Darby Peterson, born October 8, 1986, and Alyssia Nichole Peterson, born February 2, 1989. 2. The Mother shall have primary physical custody of the Children. 3. The Father shall have partial physical custody of the Children on alternating weekends, beginning September 5, 1997, from Friday through Sunday at times to be arranged by mutual agreement of the parties. During the soccer season, when a Child or the Children have a soccer game on Saturday, the Father's weekend periods of custody shall begin on Saturday rather than Friday. During the summer school vacation each year, the Father shall have custody of the Children for an additional two weeks (to be taken consecutively or nonconsecutively) upon providing thirty (30) days advance notice to the Mother. 4. The parties shall share or alternate custody of the Children on holidays as follows: A. Christmas - The Christmas holiday shall be divided into segment A, which shall run from the beginning of the Christmas holiday school break until December 26, and Segment B, which shall run from December 26 until January 1st. The Mother shall have custody of the Children during Segment A in odd numbered years and during Segment B in even numbered years. The Father shall have custody of the Children during Segment A in even numbered years and during Segment B in odd numbered years. B. Thanksgiving - The Thanksgiving holiday shall begin after school on the \vednesday before Thanksgiving and shall end on the following Sunday evening. The Father shall have custody of the Children over the Thanksgiving holiday in odd numbered years and the Mother shall have custody of the Children over the Thanksgiving holiday in even numbered years. C. July 4th - The July 4th holiday shall begin in the evening on AARON CMlUS PETERSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 97-3699 CIVIL TERM TRINA MICHELLE PETERSON, Defendant CIVIL ACTION - LAW IN CUSTODY ClJS'l'OOY Cl:fiCILIATIOO &MIARY REPOOT IN AcaJRDANCE WITH a.tIBERLAND axmy RULE OF CIVIL PROCEDURE 19l5.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning thp. Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENrLY IN ClJS'l'OOY OF Nicholas Darby Peterson Alyssia Nichole Peterson October 8, 1986 February 2, 1989 Defendant/Mother Defendant/Mother 2. A Conciliation Conference was held on August 26, 1997, with the following individuals in attendance: The Father, Aaron Camus Peterson, with his counsel, Thomas J. Williams, Esquire, and the ~lother, Trina M. Peterson, with her counsel, James J. Kayer, Esquire. 3. The parties agree to entry of an Order in the form as attached. l1vc.'u..U- c:>l ir, /99 7 S WL Dawn S. SUnday~re Custody Conciliator \:~' ,-.J t);:S U)~ i5> o-lo-l "'~ i~~ u;;~ ",~::J o!:;U e..8Z SOH U~ ""o-l :x: a: ...g] z5 HU . " .' ~ ,\ . 'l:'\ ~' , " \ " , , . \ , " ,( ,; , ,~ , " '"" .\'. ') \ .- , <- .,> i ;,. I , .~ ", i . " " ~l " ,,',.. , t '" \ ,I \,~ , \ " , \,( \ , , , , " ~i Iv " '-~-\~- j " . I~, '\\ ,,' . \ , '\ -{' V' , '\ '>.. \f' \ 'v 'l. _v , " J , 'I I ~ i fj '" U) ::J 5 ~ a: ~ --- -- ---- ~._---- :> "" o-l o-l "" :x: U H :E: <1: Z H ~ ~ s "" fj a. ~ ~ ~ z...J ;~ "'l Ci I- ~ ~ 0( .~ < ~ ~ ~ ,~ ~ 0 uJZ ~ ~ j~:< ~ E:;' .",-; u ;. ;;;; ':~:;! 6 ~:Il ~'; ~. z ~ 0 CJ 7,z " :J: Z :or::..:J ~ ;iJ 0( ~ '": ::)I-&.'j,/.;.:J (" :.J;" w...J \...t ;( uJ .....'fl l:.. Z ..... <~ t2 ~ ~ < ~ 0( U ~ ~ ''" ~ H <1: o-l '" 5 U >< ~ U) ::J U AARON CAMUS PETERSON. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA v, NO, 97- 11, fj', [if;., ( I,'"'' CIVIL ACTION - LAW TRINA MICHELLE PETERSON. Defendant IN CUSTODY PLAINTIFF'S COMPLAINT TO CONFIRM CUSTODY I. Plaintiff is Aaron Camus Peterson. an adult individual currently residing at 6028-1 New Forest Coun. Waldorl: Maryland ~0603, ~, Defendant is an adult individual currently residing at 580 Boxwood Lane, Carlisle. Cumberland County. Pennsylvania, 3, Plaintiff seeks custody of the children, Nicholas Darby Peterson and Alyssia Nichole Peterson. who were born on October 8. 1986 and February~, 1989. respectively, The children were not born out of wedlock. Since the children's birth. the children have resided with the following persons at the following addresses for the following periods of time: Nicholas resided with both panies from the time of his binh untilmid-1988, From that time on, he resided with Defendant and her parents Alyssia resided with Defendant and her parents from the time of her binh until the present, The natural mother of the children is Defendant who resides as aforesaid, She is divorced and living separately The natural father of the children is Plaintiff who resides as aforesaid He is remarried, 4 The relationship of the Plaintiff to the children is that of father, The Plaintiff currently resides with the following' Rachel Peterson Relationship Wife ~ 5, Thc rclationship of thc Dcfcndant to thc childrcn is that of mothcr, Thc Dcfcndant currently rcsidcs with thc tollowing ~ Arlcnc Stcts Frank Stcts Rclationship Mothcr Fathcr Nicholas Darby Pctcrson Son Alyssia Nicholc Pctcrson Daughtcr 6, Thc panics havc not panicipatcd in prcvious litigation conccrning thc custody ofthc childrcn in this court or any court, Thc Plaintiff has no information of a custody procccding conccrning thc childrcn pcnding in any othcr court, 7. Thc bcst intcrcst and pcrmancnt wclfarc of thc childrcn will bc scrvcd by granting partial custody to Plaintiff bccausc of thc imponancc of having an ongoing rclationship with thcir fathcr. In this rcgard. Plaintiff is willing to sharc transportation with Dcfcndant in ordcr to furthcr thc rclationship with his childrcn, 8 Plaintiff docs not know of any pcrson not a party to thcsc procccdings who claims to havc custody or visitation rights with rcspect to thc childrcn, WHEREFORE. Plaintiffrcqucsts your Honorablc Coun to sct a timc and placc for a hcaring at which Plaintiffrequcsts thc Coun to grant him thc Custody Ordcr. Pcnding said hcaring. Plaintiff rcqucsts tcmporary custody, MARTWN. DEARDOR~F. WILLIAMS & OTTO ~i iAIJt-- Bv Thnmas J Wi lams. EsqUlrc Tcn East lIigh Strect Carli sic. PA 17013 (717) 243-.\341 Allornevs fi.)r Plaintitr Datc July 9, 1997 VERIFICATION Thc forcgoing Complaint to Confirm Custody is based upon information which has bccn gathcrcd by my counscl in thc prcparation of the lawsuit. Thc language ofthc documcnt is that of counscl and not my own. I havc rcad thc Complaint and to thc cxtcnt that thc documcnt is bascd upon information which I havc givcn to my counscl. it is true and corrcct to thc best of my knowlcdgc, information and belicf To thc cxtcnt that the contcnt ofthc documcnt is that ofcounscl. I havc rclicd upon counscl in making this vcrification, This statcmcnt and vcrification arc made subject to thc pcnalties of 18 Pa, C,S, Section 4904 relating to unsworn falsification to authoritics. which providcs that if I makc knowingly falsc avcrments. I may bc subject to criminal penalties, /$JlL-;/---4~ Aaron Camus Pctcrson