HomeMy WebLinkAbout97-04346
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* Le~lIe. A.. I-\CILC: \
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
:CUHBERLAND COUNTY, PENUS1'LVANIA
v
* lCA'f L. \.Ie, \cc \
Defendant
.
.
:CIVIL ACTION - LAri
:NO. Lj~I..\G CIVIL
: CUSTODY /VISITATION
191:1,
ORDER OF COURT'
AND NOW, this (date) ',,(1 ~)/~7, upon consideration of the
attached complaint, it is hereby directed that the parties and
their respecti ve counsel appear before 1'-\ \ (. he} t" \ I . (';n::v) S . F',lj . ,
the conciliator, at \C'~~. \I<:~hl\\-, , (n,,~ I~i\ \)~
on the q day o:f Cz \Q~('> C , 19." , at \I', DO
A. 0 H., for a Prehearing Custody Conference. At 'such conference,
an effort will be made to resolve the issues in dispute; or i.f
this cannot be accOlDplished, to define and narrow the issues to be
heard 'by the court, and to enter into a teJDporazy order. Either
party llUIy bring the cbJ.ld who is the subject of this custody
acti.on to the conference, but the child/children's attendance is
not mandatory. Fallure to appear' at the conference 0 llUIy provide
grounds for entz:y of c1 teJllP<?rary or peZ1llalJent order.
FOR rIlE COURf':
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By: nUC\\nc k..:1' .,F\.,rHH:V\~
Cust:Od"y conciTIatdr;-;1.))
YOU SHOULD f'AD 'l'lUS PAPER ro YOUR LAmER Af' ONCE. IF rou DO NOf'
HAVB A LAHYER OR CANN02' AFFORD ORB, GO ro OR 'rBLBPHORB f'RE OFFICE
SEf' FOR'I'H RRtofl ro FIND OU!' fiHBRE YOU CAN GEt' LEGAL HELP.
OFFICE OF 'I'IIB COUR'I' ADHINISf'RAroR
COUR'I'HOUSE, FOURf'H FLOOR
CARLISLE PA 17013
(717)240-6200
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PADICk P. LAUER, JR.
Attora., at La""
21Q1 Mor\tI_ ~j'f fl 19iF
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. . , "
. ~ "III, I'A 11Il1I
I1lll 'Il>111iIl
vs.
I IN THE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I No, q7. J/. 3'1'"
I
I CIVIL ACTION - LAW
I IN CUSTODY
LESLIE A. HEIKEL1
P aintiff
CORY L. HEIKEL,
Defendant
ORDER
You, CORY L. HEIKEL, Defendant in the above-captioned custody
action, have been sued in court to obtain custody of the following
childl Sean B. Heikel,
You are ordered to appear in person at
on the day of 1997, at
a Conciliation or Mediation Conference.
a Pre-Trial Conference.
a Hearing before the Court.
If you fail to appear a. provided by this Order, an Order for
custody may be entered against you, or the Court may issue a
.M. for
warrant for your arre.t,
YOU SHOULD TAXE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OPFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
COUR'l' ADMIRS'rRA'l'OR
CUIIBBRLARD COUH'1'Y COURTBOUSB
OD COUR'l'BOUSB SQUARE, 4TH FLOOR
CARLISLE, PA 17013
(117) 240-6200
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law
to complr with the American. with Disabilities Act of 1990. For
informat on about acces.ible facilities and reasonable
.ccommod.tions .vail.ble to disabled individu.ls having bu.iness
before the court, pl.... cont.ct our offic.. All .rr.ngem.nts must
b. mad. .t l..st 72 hour. prior to any he.ring or bu.ines. before
the court. You mu.t attend the scheduled conf.rence or hearing,
FOR THE COURTI
DATE I
LESLIE A. HEIKEL, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. , No.
.
:
CORY L. HEIKEL, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
ORDBR
You have been ordered to attend a conference scheduled at the
Domestic Relations Office, 13 North Hanover Street, Carlisle,
Pennsylvania, before , a hearing
officer of the Domestic Relations Section on the
day
of
, 1997, at
.M. in which both
the Plaintiff and the Defendant must attend. After the hearing, an
order for support may be entered,
You must bring to the conference:
1. A true copy of your most recent Federal Income Tax
Return, as filed
2. Your pay stubs for the preceding six (6) months
3. A completed Income' Bxpense Statement in the form
attached to this notice
4. A statement from your employer of your earnings and
deductions on the enclosed Earnings Report
5. Health Insurance information: policy, numbers,
names of persons covered
6. Social Security Number of child(ren) named in
complaint
7. Verification of child care (babysitting) expenses
from provider.
Date:
For the Court
LESLIE A. HEIKEL, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I "
-
vs. I No. (/? " ., "'~ (.4...1 lu_
I
CORY L. HEUtEL, I CIVIL ACTION - LAW
Defendant , IN DIVORCE
,
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take prompt
action. You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be
entered against you by the court. A judgment may also be entered
against you for any other claim or relief requested in these papers
by the Plaintiff. You may lose money or property or other rights
important to you, including custody or visitation of your children.
When the ground for the divorce is indignities or
irretrievable breakdown of the marriage, you may request marriage
counseling,
A list of marriage counselors is available in the
Office of the Prothonotary at the York County Courthouse, 28 East
Main Street, York, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAltB THIS
PAPER '1'0 YOUR LAWYER AT OHCB. IF YOU DO HOT HAVB A LANYBR OR
CAHJIOT AFFORD ORB, GO TO OR TBLBPHORB 'l'BB OFFICE SET PORTH BBLON TO
FIND OUT WBBRB YOU CAN GET LEGAL BBLP.
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
ONE COURTHOUSE SQUARE, 4TH FLOOR
CARLISLE, PA 17013
(717) 240-6200
LESLIE A. HEIKEL, I IN THE COURT OF COMMON PLEAS OF
Plaintiff , CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs, I No.
,
.
CORY L. HEIKEL, , CIVIL ACTION -LAW
.
Defendant . IN DIVORCE
,
AVISO PARA DBFENDBR Y RECLAMAR DBRECBOS
USTBD BA SIOO DBHAHDADO EN LA CORTS. Si desea defenderse de
las quejas expuestas en las paginas siguientes, debe tomar accion
con prontitud, Se Ie avisa que si no se defiende, el caso puede
proceder sin usted y decreto de divorcio 0 anulamiento puede ser
emitido en su contra por la Corte. Una decision puede tambien ser
emitida en su contra por cualquier otra queja 0 compensacion
reclamados por el demandante. Usted puede perder dinero, 0
propiedades 0 otros derechos importantes para usted.
Cuando la base para el divorcio es indignidades 0 rompimiento
irreparable del matrimonio, usted puede solicitar consejo
matrimonial. Una lista de consejeros matrimoniales esta disponible
en la oficina del Prothonotary, en la York County Court of Common
Pleas, 28 East Market Street, York, Pennsylvania.
SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL,
HONORARIOS DB ABOGADO 0 OTROS GASTOS ANTES DE QUE EL DECRETO FINAL
DE DIVORCIO 0 ANULAMIENTO SEA EMITIOO, USTED PUEDE PERDER EL
DERECBO A RECLAMAR CUALQUIERA DE ELLOS,
USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO
TIEHB 0 NO PUEDE PAGAR UN ABOGADO, VAYA 0 LLAME A LA OFICINA
INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTEHBR ASISTENCIA LEGAL.
Court Administrator
Cumberland County Courthouse
One Courthouse Square, 4th Floor
Carlisle, PA 17013
Telefono (717) 240-6200
LESLIE A. HEIKEL, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
: Y'/ " 1',(, Clo..l ~
vs. : No. /(.L_
.
.
CORY L. HEIKEL, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
COMPLAINT IN DIVORCB UNDBR SBCTIONS 330l(c) or 330l(d)
OF THE DIVORCB CODB
The Plaintiff, LESLIE A. HEIKEL, through her attorneys, The
Law Offices of Patrick F. Lauer, Jr., makes the following Complaint
in Divorce:
1. The Plaintiff, LESLIE A. HEIKEL, is an adult individual
who currently resides at 218 Rosemont Avenue, New Cumberland,
Cumberland County, Pennsylvania 17070.
2. The Defendant, CORY L. BEIKEL, is an adult individual who'
currently resides at 218 Rosemont Avenue, New Cumberland,
Cumberland County, Pennsylvania 17070.
3. The Defendant and the Plaintiff have been bona fide
residents of the COllllllOnwealth of Pennsylvania for at least six
months immediately prior to the filing of this Complaint.
4. The Plaintiff and the Defendant were married on June 14,
1992 in Camp Hill, Pennsylvania.
COUlft' I-DIVORCE
5. Paragraphs one ( 11 through four (41 are incorporated
herein by reference as if set forth specifically below.
6. There have been no prior actions of divorce or for
annulment between the parties.
7. The marriage is irretrievably broken.
8. The Plaintiff has been advised that counseling is
available and that the Plaintiff may have the right to request that
the court require the parties to participate in counseling.
9. This action is not collusive.
~RB, the Plaintiff respectfully requests this Honorable
Court grant the Plaintiff relief from the bonds of matrimony and
order a Decree in Divorce,
COUNT n-cusroDY
10. Paragraphs one (1) through nine (9) are incorporated
herein by reference as if set forth specifically below.
11.
There is one (1) dependent child by this marriage as i
;
I
SEAN B. HEIKEL; d.o.b. 12/18/93. i
The Plaintiff seeks primary physical custody of the child I
follows,
12.
born of this marriage as set forth in Paragraph Eleven (11).
13. The minor child is in the custody of both Plaintiff and
Defendant. I
14. The Father of the child is the Defendant, currently.
residing at the above referenced address, Paragraph Two (2).
15. The Mother of the child is the Plaintiff, currently
re.iding at the above referenced address, Paragraph One (1).
16. During the past five years, the child has resided at the
following address with the following persons:
Birth to
Present
218 Rosemont Avenue Plaintiff &
New Cumberland, PA 17070 Defendant
17. Plaintiff and Defendant both reside with the following.
persons: Sean B. Heikel.
18. Plaintiff has not participated as a party or witness, or
in another capacity, in other litigation concerning the custody of
the child in this or another court.
19. Plaintiff has no information of a custody proceeding.
concerning the child pending in a court of this Commonwealth.
20. 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.
21. The best interests and welfare of the minor child will be
served by granting the relief requested because:
a. Plaintiff can provide the child with adequate moral,
emotional, and physical surroundings as required to meet
the child's needs,
b. Plaintiff is willing to continue custody of the
child.
c. Plaintiff continues to exercise parental duties and
enjoys the love and affection of the child.
22. Bach parent whose parental rights to the child have not
been teralnated and the penon who haa physical custody of the
child have been named .s parties to this action.
WBBRBFORB, The Plaintiff respectfully requests this Honorable
Court grant the Plaintiff rights of majority physical custody and
grant the Defendant rights of visitation.
COUNT III-EOUITABLE DISTRIBUTION
23. Paragraphs one (1) through twenty-two (22) are
incorporated herein by reference as if set forth specifically
below.
24. The parties have legally and beneficially acquired
property, both real and personal, during their marriage.
25. The Plaintiff and the Defendant have been unable, as of
the date of this Complaint, to agree as to an equitable division of
said property.
WBBRBFORB, the Plaintiff, LESLIE A. HEII(J~L, respectfully
requests this Honorable Court to equitably divide all marital
property and to enjoin it from being removed, disposed of,
alienated, sold, or otherwise encumbered pending final hearing and
settlement of all claims.
COUNT IV - ALIJ<<>RY AND ALIMONY PBRDBH'l'B LI'l'B
26. Paragraphs one (11 through twenty-five (25) are
incorporated herein by reference.
27. The Plaintiff is the dependent spouse. The Plaintiff
lacks sufficient property to provide for her reasonable means is
unable to support herself cOllpletely through appropriate
employaent.
28. The plaintiff requires reasonable support to adequately
maintain herself in accordance with the standard of living
established during the marriage.
WBBRBFORB, the Plaintiff, LESLIE A. HEIKEL, respectfully
requests your Honorable Court to enter an award of reasonable
alimony upon final hearing and permanently thereafteri to permit
the Plaintiff an interim hearing before the Divorce Master in order
to determine whether an award of alimony pendente lite is
appropriate and, if so, in what amount.
COURT V - ATTORHBY'S FEBS AND COS'l'S
29. Paragraphs one (1) through twenty-eight (28) are
incorporated herein by reference,
30, The Plaintiff has entered into a fee agreement with her
attorney.
31. The Plaintiff may be in need of hiring an accountant, a
real estate appraiser, and other experts, and does not have the
funds required to pay the necessary and reasonable fees.
1IBBRBFORB, the plaintiff, LESLIE A. HEIJtEL, respectfully
requests this Honorable Court to enter a decree of divorce in this
matteri and the Plaintiff further requests the Court to incorporate
any Stipulation reached by the parties regarding the division of
marital property, alimony, alimony pendente lite, attorneys fees,
or costs into the divorce decreei or, should the parties fail to
reach such an agreement, to equitably divide all marital property I
the Plaintiff further requests your Honorable Court to enter an
LESLIE A. BEIKEL, : IN TBE COURT OF COMMON PLEAS OF
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA .
.
:
vs. : No.
.
.
CORY L. BEIKEL, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
VERIFICATION
I verify that the statements made in this Complaint are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn
falsification to authorities.
Date: ~7 }q7
I
Signature:
Lea
RICHARD VANADIA,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V,
97-4347 CIVIL TERM
PENNY VANADIA,
Defendant CIVIL ACTION - CUSTODY
IN RE: CUSTODY STIPULATION
ORDER OF COURT
AND NOW, this 19th day of March, 1998, after hearing,
and it appearing to the Court that the parties have reached an
agreement on all but a few of the terms of the following order,
it is ordered and directed as follows:
1, Mother and Father shall have shared legal and
shared physical custody of their minor child, Mariah Vanadia,
age two (2), whose date of birth is April 18, 1995.
2, For purposes of this order, shared physical
custody is defined as assuring the child of frequent and
continuing contact with both parents. For purposes of this
order, shared legal custody shall be defined as an arrangement
whereby the parties shall consult with each other regarding any
and all major decisions in the minor child's life, including but
not limited to medical, educational, and religious decisions,
3, Father shall have partial custody with the minor
child as follows:
A, Alternating weeks from Wednesday at 7:00 p.m,
until Sunday at 1:30 p.m" beginning March 25, 1998.
8, Alternating weeks from Wednesday at 7:00 p.m.
until Friday at 7:00 p,m.. beginning April 1, 1998,
4. With respect to holidays, the parties shall share
custody of the minor child as follows:
A, In 1997 and all odd numbered years
.~"
thereafter, Mother shall have custody of the minor child on
Christmas Eve, Christmas Day and December 26, and Father shall
have custody of the minor child on December 27 and 28, In 1998
and all even numbered years thereafter, Father shall have
custody of the child on Christmas Eve, Christmas Day and
December 26, and Mother shall have custody of the child on
December 27 and 28, custodial periods shall begin at 10:00 a,m,
Father shall be entitled to keep the child overnight during his
custodial periods,
B, In 1997 and all odd numbered years
thereafter, Father shall have custody of the minor child on New
Years Eve Day, New Years Day and January 2, and Mother shall
have the child on January 3 and 4, In 1998 and all even
numbered years thereafter, Mother shall have the child on New
Years Eve Day, New Years Day and January 2, and Father shall
have the child on January 3 and 4, custodial periods shall
begin at 10:00 a,m, Father shall be entitled to keep the child
overnight during his custodial periods,
C, In 1997 and all odd numbered years
thereafter, Father shall have custody of the child on the day
before Thanksgiving, Thanksgiving Day, and the day after
Thanksgiving, and Mother shall have custody for the two
subsequent days, custodial periods shall be from 10:00 a,m.
until 7:00 p.m, and Father shall be entitled to keep the child
overnight, In 1998 and all even numbered years thereafter,
Mother shall have custody of the minor child on the day before
Thanksgiving, Thanksgiving Day, and the day after Thanksgiving,
and Father shall have custody for the two subsequent days,
Custodial periods shall begin at 10:00 a.m. Father shall be
entitled to keep the child overnight.
D. In 1999 and subsequent odd numbered years,
Mother shall have custody of the minor child on the day before
Easter, Easter Day and the day after Easter, and Father shall
have custody of the child for the two subsequent days. Father
shall be entitled to keep the child overnight and custodial
periods shall begin at 10:00 a,m. In 1998 and subsequent even
numbered years, Father shall have custody of the minor child on
the day before easter, Easter Day and the day after Easter, and
Mother shall have custody of the child for the following two
days, Father shall be entitled to keep the child overnight
during this period,
E, With respect to the 4th of July, Labor Day
and Memorial Day, the parties shall alternate those holidays
with Mother to have the child on Memorial Day 1998, Father to
have the child on the 4th of July 1998, and Mother to have the
child on Labor Day 1998, Father to have the child on Memorial
Day 1999, and so on. Father's periods shall run from 10:00 a,m.
to 7:00 p,m,
S. Mother shall provide all transportation in
connection with the partial custody as long as Father does not
have access to a vehicle. This provision does not apply to
public transportation, The specific arrangements regarding
pickup and drop off locations are to be mutually agreed upon by
the parties, Father agrees to use his best efforts to secure a
vehicle or access to a vehicle. and upon doing so agrees to
share the transportation responsibility with Mother, If father
has not obtained means of transportation within 6 months, this
matter will be reviewed by the Ccurt upon request of either
party,
6. Irrespective of any other period of partial
custody set forth herein, the father shall be entitled to
partial custody with the child on Father's Day weekend from
Saturday afternoon at 4:00 p,m. until Sunday afternoon at 4:00
p,m,
7. Each party shall be entitled to an uninterrupted
one (1) week period of summer vacation with the child upon at
least thirty (30) days notice to the other party, Each party
shall be required to notify the other of the vacation location,
provide a telephone number where the child can be reached to the
non-custodial parent, and ensure that the child places one
completed telephone call to the non-custodial parent during the
vacation week, at a time to be mutually agreed upon by the
parties.
8, In connection with the definition of shared legal
custody, the custodial parent shall be responsible at all times
for informing the non-custodial parent of school assignments,
special projects, or any extracurricular or scholastic special
events the child may be attending,
9, Mother shall be entitled to take the child to a
Christian church during Mother's custodial weekends and it is
understood that the child will be learning Christian teachings
as set forth in the Bible, Father will refrain from speaking
about the church attendance and teachings to the minor child in
a derogatory or unfavorable light, Mother will refrain from
speaking about race, gender, and/or ethnicity. to the child in a
derogatory or unfavorable light.
10. Father shall keep all pornographic materials away
from the child and shall not view or use any such materials
while the child is in his custody.
11, The parties shall make their respective
residences as "baby proof" as possible, and shall devote their
full attention to the child when she is in their custody.
Furthermore, the natural parent shall be the child's primary
caregiver and shall assume primary responsibility for the child
when in that parent's custody, This shall not be construed to
prevent either party from using daycare while employed or from
using a babysitter for occasional social engagements,
12, The parties shall promote and facilitate
reasonable telephone contact between the minor child and the
non-custodial parent and shall refrain from speaking about the
non-custodial parent in a derogatory, offensive. or unfavorable
light while in the presence of the minor child.
13, The parties are encouraged to be as flexible as
possible to assure that the child has the maximum possible
contact with both parents.
14. This Court shall retain jurisdiction of this
matter,
By the Court.
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Edward E. Guido, J.
Joan Carey, Esquire
8 Irvine Row
CarliSle, PA 17013
For the Plaintiff
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Melissa Peel Greevy,
214 Senate Avenue
Suite 602
Camp Hill. PA 17011
For the Defendant
Esquire
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Johnson, Duffie, Stewart & Weidner
By: Keirsten L, Walsh
I,D. No. 78243
301 Market Street
1'. O. Box 109
Lemoyne, Pennsylvania 17043.()109
(717) 761-4540
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RICHARD VANADIA,
IN THE COURT OF COMMON PlEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
t
Plri:ltiff
:
NO. 97-4347 C!VIL TERM
vs.
.
PENNY VANADIA.
CIVIL ACTION. CUSTODY
Dflfendant
CUSTODY STIPULATION
"
ANDNOW. this 1'1 dayof ",cpJct\t be.r ,1957.lllsagreedbyendbecweenRICHARD
VANADIA (hereinafter refened to as "father"' end PENNY VANADIA (hereinaft<< refened to as
"Mother"'. as follows:
1, Mother and Father shall have shared lagal end shared physical custod,. oi their minor child.
Marlah Vanedia. age two (21. whose date of blnh Is April 18. 1995. :.
I 2. For purposes of this Agreement, shared physletl custody ls~~efined .1; en agreement or
order assuring the child of frequent and continuing contact with both ~rents, For purposes of tNS
Agreement. shared lagal custody shall be defined as an arrangemflnt whereby the panles agree to consult
with each other regarding any and all major decision.'1 in the minor chik", Hli; ':'Chiding but not 6mitod to,
medical, educational. and reftglous tleclslons,
.
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3,
Father shall have partial cu~tody with tho minor child as follows:
A, Father shall have custody of the minor child on alternate weekends from 10:00 a.m.
on Saturday mornings until 6:00 p.m, on Sunday evenings,
ror example, It typical two (21 week cycle would run as follows: Monday - with Mother;
Tue$day _ with Fetner from 5:30-9:00 p,m,; Wednesday - with Mother; Thursda,! - wit~ Father from
5:30-&:00 p,rn.; Friday - with Mother; Saturday - with Father from 10:00 a.m.-6:00 ;I.m. Sunday;
t Mondar . with Mother; Tuesday.' with Father from 5:30 p.m, - 5:30 p,m. on Wednesdav;
l WednE'sdlif - with Mother from 6:30 p,m.; Thursday - with Mother; Friday - with Mother; &.turtlay -
f wit" 'J1oth6r: Sl'~tf...: - with MothE'r; with the two (21 week cycle to repeat.
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During thll wllek whlln Father has custody of the child on the wellke.ld, Fett,er
shall also have custody of the child on Tuesdays and T1,ursdays frolT, after
Mother'" work (approximately 5:30 p,m.1 until after Mether'l> activities
(appro.<imate.y ~:Oti ;,'.,,',,1, Should Mother sto:, .,artiCilleting in hllr Culrll:U
activities, or should those activities be cancelled on. a particular evenill~ 'or
whatever reason, Father's eustodial period shall run at lea~t until 8:00 p,m,
c,
.
During till! week when Father does not have custOd~' ei the child on the
weekent', ~8ther sha!l have custody of the r:llnor child on Tuesdays after
Mother's work (approximately 5:30 p.m,1 overnigh~ until Wednesdays after
Mothe;'s work (approximately 6:30 p.m,l.
With respect to holiday~. the parties agree to share custody of .the minor chik1 as fol\Owt:
A.
l,~ 1997 and 1\11 odd numbered years thereafter, Motheuhall have custody of the
mi.wr child on Christmas Eve, Christmas Day and December 26, anc; Father Ilhal1
have custody of the minor child on December 27 and 28. In 1998 lIIv.I aM even
numbered years thereafter. Father shall have custody of the child en ChriJtm8I Eve.
Chri!tmlS Day and December 26~a MO~~1 have cun:;;;cN:d on
"., a.t .
December 27 and 28, CIlstodill1 's s IMi f~ 10:00 .' .,
-eM Father shall be MtMNS to kNP the child overnight during his eustocfl8l periods.
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I
B, In 1997 and all odd numbered years thereafter. Father shall have custody of the
minor child on New Years Eve Day. New Years Day and January 2. and Mother
shall have the child Oil January 3 ane! 4, In 1998 and all even numbered years
thereafter. Mother shall have the child on New Yelirs Eve Day. New Years Day and
@{n~~. arid Father sha:I~~..[th;l~ or. Januar/ 3 Hod 4, Custodial periods
~d ~ ~
a I 1<.':00 lI.m. : ."': IQ ~Rll Fattlt: shall i,:. entitllld to koep the
child overnight.
C. In 1937 and all odd Ilumbf.ree years thereaftPr. Fathp' . :'all have custody of the
r.hild on the day befor~ Thankslliling. Tl'ol'nksg;v:n: Dli; and the day atter
Thal'ksgiving. and Mother shall ha\'" euSI'Xly for th.. lwa sUlAequent days,
Custodial IlE'rit'ds shall bll frMl 10:00 a,n. l'r. . 7:0\1 r.'~. and foather shall be
entitled to keep the child overnight. '99: ..nr. ill evtl'l nur.,bered years
thereafter. Mother shall have custody at' tne rnim.r child on the day before
Thanksgiving. ThanksQiving Dry and th* na~' afw :3' .~ Father Ilha!l
od . S^ o:t 00
have cust y for the two subsequent day., Cu"tccfll'l s II AlA frs", 10:
s,~ Fathu; shall be entitled to keep tll~.chiJd ovemirht,
D. In 1999 and subsequent cdI! nurr.berf!' ~~MS. Mathe' V.t:~ h..'"VO custody of the'
minor eh~d on the day l-eforP Easter, East"" Oil, and ,thE' day after Easttr, and
Fether shall have custody of the child for t.'It twl' ~i~ay~. Fath~ I shall be
I'Intitled to keep t!le chiki ovtrnillht and cust01ial J~ r~~",':: 10:00 a.r::.
~' In 1998 an1 subsequen( even numberlll,' yaars, Fathet shall have
~t~f the minor child on the aay befoltr Easter. Easter Day and the day after
Easter. and Mother shall have custody t'f the chilt. fof-1t!e followlr,g two days,
Father shall be entitled to keep ttoe child I!Vflrnig". 'luring till, DtlrtOO.
E, With respect to the 4" of July. laoor Day lIlY. MemOna! Day. the ,Jerties shall
alternate those holiday, with Mothf" to hue the child' on Mern'Jrial Day 1938.
Father to have the child 'lIl the 4" 0; July 1998, Pnd Mother to haVll the child on
labor Day 1998. Fatha: to have tho chi". on Memorial Day 1999. and 10 I'll,
Father's periods sha!; run f/'l'fll to:OO a,/1"" . 7:t'O p,m.
I
~ 6. n.e parties agree that Mother shaD Ilrovide all transportation in connection with this
I agreement as long as Father does not have access to a vehicle, This provision does not apply to public
transportation. The specific arrangements regarding pickup and drop off locations are to be mutually
agreed upon by the parties, Father agrees to use his best efforts to secure means of transponation and
upon doing so, "grefls !I) shAre 'h" transportation responsibility wit"" Mother,
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Both \Hlrents shall be flntitl~d to spend time with the minor,child within two 121 days
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Wnol,' Father', birthday falls on a Monday through Friday, Father shall have custody
C'~ the child fron: when Mother leaves for work in the morning until Mother returns
i>oIM frOl" work il' the evening, When Fathe~s birthday falls on a Saturday or
';unday, Fati-,:.r shaft have cu~tody from 10:00 a,m, until 7:00 p.m,
C. If Motha'.; birthday falls during one of Fatne(s custodial periods, Father shall
fl'~ nis custodial period II? that the child can spend time with Mother.
7. Tne child shall be entitled to s~ Mother's Da~ with Mother and Father's Day with
Father, from 10:()(.\ ';,M. unti' 7:00 P,ITl.
a Each party wll be entitldd to an uninterruptec! one 111 week period of lummer vacation
. with,l\f" child c!:o" l" bast t....'rtV 130; days notice to the other party. Each party.shaII be required to
~ . notify the other of th.t "Icatior, location. provide a telephone number where the child can be reached to
~ the non-custodilll pare01, and ensur'!' .that the child places one cOf11tlleted telephone call to the n0D-
I custodial pl'rent durlna tile vacation wet'lk, at II tlm'!' to be mutUally agreed upon by the parties,
I
&. Ir connection with the defmitlon of sI\are(J leoaJ custody, the custodlal parent shall be
responsible at an times f')r informing the non-custodlal parent of IChool assignments, :apec:lal projects, or
any extracurricula! ow s~mlastlc sp8\.'ial events tM c....ild may be attending,
10, Motller shal. be entitled to take the child to a Christian chuI'ch during MothI(l custudIaI
weekends and It is understood thllt the cMd will b't lu""nq Christian teachings as sat forth In thIIllbIe,
.'
Father agrees that he will refrain from speaking about the church attendance and teachings to the minor
child in a derogatory or unfavorable light. Mother agrees that she will refrain from speaking about race,
gendllr, and/or ethnicity, to the child in a derogatory or unfavorable light,
11, The parties agree that there shall not be any public displays of affection between.
themselves and any other person, excepting immediate relatives, while in the presence of the mi'lor child.
The parties further agree that persons whom the parties are dating or are romantically involved with shall
~ not De pres en: during periods of custody. It is contemplated by the parties that at some point in the
· futu~e the\, may enter a long-term romant!.: relationship with another and want the minor child to me!:t
that persor.. In the event that a party has dated a partner for a substantial period of time, and there is a
commitment to a pennanent, monogamous relationship, the parties agree that they will inform each other
of tha> .0 that the~' may I'rranpe for the minor child to interact with that persor:. A substa~ial period of
time shall be defineo as one III year, unless after a good faith examination of the situation, the parties
i agree t~a: ': would b6 appropriate to introduce the minor child to that person. However, in no event shall
either oi the parties introauce the minor child to a person with whom they have a permenent,
monogamous relationship of less than nine (9) months, The parties specifically agree not to expose the
t IT';no~ chil1 tl\ r.ASUS: romantic partners, or people they are casually dating,
1 ~ Father agrees to consolidata any and all pornographic materials including, but not limited
to, mdgazin"s, bOOks and/or videotapes, In one central location, and to keep such materials out of the
reach 01 the chila. F~'hfor fl'rther agrees to refrain from viewing and/or utilizing such material~ while the
~ child is in hi.. custod,..
I
1<-. The partler agree to make their respective residences as "baby proof" as possible, and '0
devotll th~r full attention to the child when she is in their custody. Furthermore, the nelUral parent shall
be the child's Drimary caregiver and shall assume primary responsibility for the child when in that parent's
custody. this shall not be construed to prevent Mother from use of a babysitter for occasional social
engagements tll't mry exten1 b!lyond the child's bedtime, however, Father shall be given the right of
first refullll'.
.14. Neither party shall remove the child from the Harrisburg area without giving re6sonatde
notice to the non-custodialpatent.
." ~ ...
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15, The parties agree to promote and fLcilitate reasonable teiephone contact between the
millor child and the non-custodial parent and egree to retrain from speaking about the non-custodial
~ parent in a derogatory, offensive, or unfavorable light while in the presence of the minor child, Mother
specific""." agrees to refrain from speaking about Father's sexulIl orientation, In connection with Father,
in a derogatory or offensive light to the minor child. It is contemplated bV the parties that at some point
in thl. future Father's sexual orientation will be addressed witt. th, I:hi'~. When Ihzt tima arises and
when the chi:d Is capable of thoughtful understanding, the pa:::,,', agra.. '\0 wt'rl<. together In ,.reIer to
!ddress t"le !ituatlon. and may enlist the Eervices 0: an exrert in o:clllr ,(.I pr:llnot., the welfare and best
i irl"reMs (If :I:e child.
I.
I
I
16 During any period of custody. the custodial oarent agr~J to ,eltai:, ',om u,:ng drugs or
alcohol t\) the point of intoxieation or impairment in the prasence of the child and shall "1'I.ure to every
I
I extent possible that no guests use drugs or alcohol to Ih':l poin' ('f Int( . ',.~~j,)n '., I~e -:lIII:I's presence
either.
;:.:'rtilljo arl' ..ncouraged
17. This is the minimum amount of partial custody for F. (100'. ..nd.tht.
f to ellpand upon this schedule, '
I
1 S. The parties agree that this
accordance with the laws of Pennsylvania,
Custody Stip'Jlation cllan L.. suh't""
,nodificarion in
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19, The parties intend that this Stipulation be madl! intu 1'1 010"' (Of ~ '
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9111/99
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Date: C\ \ \C\ \q"')
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6. On February 12, 1998 Respondent's attorney contacted Petitioner's attorney and
suggested that the focus in pending litigation be first on the custody plan. in light of
Respondent's upcoming move and the neL'Ilto resolve that issue promptly.
7. Respondent's new position will be a promotion within her company which will
provide greater job security, a small annual increase with the move and is expected to be
accompanied by an additional increase in salaJ) following a satisfactory performance review
which is expected to take place in the next three to six months, thus providing an improved
quality oflife.
8. Respondent's current position in Harrisburg is expected to be eliminat~'Il in the
next six to twelve months.
9. Respondent has been with her employer for three y'ears and there is no opportunity
lor a promotion in the local area with Respondent's employer.
10. Petitioner collects disability for chronic fatigue syndrome or chronic immune
deficiency syndrome and therefore lacks the physical capacity to function as primary custodial
parent of a healthy active three year old.
II. Petitioner is unemploy.ed and pays no child support.
12. Respondent's promotion is of great imponance to the Respondent and minor
child's economic future and stabilil)' as it seems likely she will remain the primary provider for
the minor child until the Petitioner is recovered.
13. Since December 1998 Petitioner has sporadically refused available visitation on
weekday.s claiming that he had no money lor Ii.xxi or diapers. He has made some weekend visits
contingent upon Respondent providing food and diapers.
14. On I'ebnwy 23.199811 proposal f('r modification of the custody order by
stipulation was faxed to Petitioner's attorney. See "Exhibit U" incorporated herein by rclcrence.
15. Said proposed stipulation provides Petitioner more time with the minor ehild than
the prior stipulation and order uf September 25, 1997 and is thus a realistic substitute visitatiun
arrangement whieh will adequately foster an ungoing relationship between the minor child and
('etitioner.
16. The approximate driving time to ReslXlDdent"s new residence is ninety minutes.
17. Said proposed stipulation prO\ides that Respondent will provide all transportation
If.lr the first six months at\er the move and will then equally share the transportation after the first
six months. See Exhibit B. ~ 5.
18. As of February 27,1998 Ms. Walsh had no response fmm Petitioner tu
Respondent"s proposal.
19. Althuugh the Petitioner's verification un his present petition is dated February 24,
1998. it was March 2, 1998 when Respondent"s attomey was lirst notitied that Petitioner had
l1atly rejected the proposed stipulation with no offer of an alternative plan other than his demand
to have Respondent leave the minor child with Petitioner.
20. Respondent believes it is in the best interest and permanent welfare uf the minor
child to remain primarily in her care for reasons including but not limited to the following:
a. There would be more stablility for the minor child to remain with her
mother as the same primary caregiver, while maintaining regular contact with both parents.
b. Respondent is health) and has sullieient energy to eare tllr the minor
child.
b. The Petitiom:r has a histol') of at lea~t one suicide attempt, threats of
suicide. psydliatrk hospitalit.3tion and is ~ie\'ed to haw diSl.'wltinued medi\:ation and
tr~atment.
c. Petitioner has threatened to "take away" the minor child from the
Respondent.
d. Despite their differences, Respondent has demonstrated a commitment to
maintaining the minor child's relationship with her father.
WHEREFORE. the Respondent requests that this Court deny Petitioner's request lor a
Temporary Order enjoining Respondent from removing the child from the jurisdiction of this
Court and requests the Court to schedule a Plowman hearing as suggested by Petitioner's
counsel.
The following verification is being provided because of the short time deadline as a result
of the Petitioner's filings. The undersigned attomey for Respondent Penny Vanadia respectfully
avers and othen\ise affirms that the information contained herein is true and correct based on
information provided by Respondent Penny Vanadia and understands that false statements herein
made are subject to th.: penalties of 18 PI. C. S. S 4904, relating to unsworn falsification to
authorities.
Respectfully- submitted,
l1at-?[MGff~
Dated; 2/3/98
Melissa Pccl Greev}, Esquire
1.0. No. 77950
214 Senate Avenue Suite 602
Camp Hill, PA 17011.2336
(717) 763-8995
Attorney lor the Respondent
B. Father shall have partial custody from Thursday night at 7:00 until
Saturday at I o:oo~. or Friday night 8:00 p.m.
4. With respect to holidays, the parties agree to share custody of the minor child as
til\l\lWS:
A. In 1997 and all odd numbered years thereafter, Mother shall have custody
of the minor child on Christmas Eve, Christmas Day and December 26,
and Father shall have custody or the minor child on December 27 and
December 28. In 1998 and all even numbered years thereafter, Father
shall have custody ofth~hild on Christmas Eve, Christmas Day and
December 26, and Mother shall have custody of the child on December 27,
and 28. Custodial periods shall begin no later than 10:00 a.m., and Father
shall be entitled to keep the child overnight during his custodial periods.
B. In 1997 and all odd numbered years thereafter, Father shall have custody
of the child on the day before Thanksgiving, Thanksgiving Day and the
day after Thanksgi,'ing, and Mother shall have custody' for the two
subsequent days. Father shall be entitled to keep the child overnight
during this period. In 1998 and all even numbered years thereafter,
Mother shall have custody' or the minor child on the day before
Thanksgiving. Thanksgiving Day and the day after Thanksgiving. and
Father shall have custody for the two subsequent days. Custodial periods
~.
shall begin no later than 10:00 n.m., and Father shall be entitled to keep
the child overnight during his custodial periods.
C. Father shall have custody Easter weekend every y-ear from 8:00 Lm.
3. Father shall have partial custody with the minor child as follows:
A. Father shall have custody of the minor child on alternate weekends from 10:00 a.m.
on Saturday mornings until 6:00 p.m. on Sunday evenings.
B. During the week when Father has custody of the child on the weekend, Father
shall also have custody of the child on Tuesdays and ThurSdays from after
Mother's work (approximately 5:30 p.m.) until after Mother's activities
(approximately 9:00 p.m.l. Should Mother stop participating in her current
activities, or should those activities be cancelled on a particular evening for
whatever reason, Father's custodial period shall run at least until 8:00 p.m.
C. During the week when Father does not have custody of the child on the
weekend, Father shall have custody of the minor child on Tuesdays after
Mother's work (approximately 5:30 p.m.) overnight until Wednesdays after
Mother's work (approximately 5:30 p.m.).
For example, a typical two (2) week cycle would run as follows: Monday - with Mother;
Tuesday - with Father from 5:30,9:00 p.m.; Wednesday - with Mother; Thursday - with Father from
5:30,9:00 p.m.; Friday - with Mother; Saturday - with Father from 10:00 a.m..6:oo p.m. Sunday;
Monday - with Mother; Tuesday - with Father from 5:30 p.m. - 5:30 p.m. on Wednesday;
Wednesday - with Mother from 5:30 p.m.; Thursday - with Mother; Friday - with Mother; Saturday _
with Mother; Sunday - with Mother; with the two 121 week cycle to repeat.
4. With respect to holidays, the parties agree to share custody of the minor child as follows:
A. In 1997 and all odd numbered years thereafter, Mother shall have custody of the
minor child on Christmas Eve, Christmas Day and December 26, and Father shall
have custody of the minor child on December 27 end 28. In 1998 and all even
numbered years thereafter, Father shall have custody of the child on Christmas Eve,
Christmas Day and December 26, ~,Mot".<<.u~~.~l :::ve cu~ ~f, the child on
December 27 and 28. Custodial per~s s~ 1M f~ 10:ooia~<'\f(t~ 7:00 lI.m.,
.... Father shell be entitled to keep the child overnight during his custodial periods.
B. In 1997 and all odd numbered years thereafter, Father shall have custody of the
minor child on New Years Eve Dey, New Years Day and January 2, and Mother
shall have the child on January 3 and 4. In 1998 and all even numbered years
thereafter, Mother shall have the child on New Years Eve Day, New Years Day and
tm.n~2, ~~Jather shall. have ~hild on January 3 and 4. Custodial periods
l~ait,",~ 10:00 a.m. 1IMi1 :;r:~P'" aRG Father shall be entitled to keep the
child overnight.
C. In 1997 and all odd numbered years thereafter, Father shall have custody of the
child on the day before Thanksgiving, Thanksgiving Day and the day after
Thanksgiving, and Mother shall have custody for the two subsequent days.
Custodial periods shall be from 10:00 a.m, until 7:00 p.m. and Father shall be
entitled to keep the child ovemight. In 1998 and all even numbered years
thereafter, Mother shall have custody of the minor child on the day before
Thanksgiving, Thanksgiving Day and the day after Tha~'fl..\,!nd ,Father shall
have custody for the two subsequent days. Custodial ~" sl~ii~1r~ 10:00
a'm)~ ".",_and Father shall be entitled to keep the child overnight.
D. In 1999 and subsequent odd numbered years, Mother shall have custody of the
minor child on the day before Easter. Easter Day and the day after Easter, and
Father shall have custody of the child for the two s'lt'"u'r~ 1ays. Father shall be
entitled to keep the child overnight and custodial ~s stWf ~ 10:00 a.m.
~. In 1998 and subsequent even numbered years, Father shall have
l ~~t;;&f~f the minor child on the day before Easter, Easter Day and the day after
Easter. and Mother shall have custody of the child for the following two days.
Father shall be entitled to keep the child overnight during this period.
E, With respect to the 4" of July. Labor Day and Memori81 Day, the parties shall
alternate those holidays with Mother to have the child on Memorial Day 1998,
Father to have the child on the 4" of July 1998. and Mother to have the child on
Labor Day 1998. Father to have the child on Memorial Day 1999. and so on.
Father's periods shalt Nn from 10:00 a.m. to 7:00 p.m.
.1
5. The parties agree that Mother shall provide all transportation in connection with this
agreement as long as Father does not have access to a vehicle. This provision does not apply to public
transportation. The specific arrangements regarding pickup and drop off locations are to be mutually
agreed upon by the parties. Father agrees to use his best efforts to secure means of transportation and
upon doing so, agrees to share the transportation responsibility with Mother.
6.
A.
Both parents shall be entitled to spend time with the minor child within two (2) days
of the child's birthday.
B. When Father's birthday falls on a Monday through Friday, Father shall have custody
of the child from when Mother leaves for work in the morning until Mother returns
home from work in the evening. When Father's birthday falls on a Saturday or
Sunday, Father shall have custody from 10:00 a.m. until 7:00 p.m.
C. If Mother's birthday falls during one of Father's custodial periods, Father shall
fOlego his custodial period so that the child can spend time with Mother.
7. The child shall be entitled to spend Mother's Day with Mother and Father's Day with
Father, from 10:00 a.m. until 7:00 p.m.
8. Each party shall be entitled to an uninterrupted one (1) week period of summer vacation
with the child upon at least thirty 1301 days notice to the other party. Each party shall be required to
notify the other of the vacation location, provide a telephone number where the child can be reached to
the non-custodial parent, and ensure that the child places one completed telephone call to the non-
custodial parent during the vacation week, at a time to be mutually agreed upon by the Pilrties.
9. In connection with the definition of shared legal custody, the custodial parent shall be
responsible at all times for informing the non-eustodial parent of school assignments, special projects, 01
any extracurricular 01 scholastic special events the child may be attending.
10. Mother shaH be entitled to take the child to a Christian church during Mother's custodial
weekends and it is understood that the ehild will be Ieaming Christian teachings as set fOlth in the Bible.
Father agrees that he will refrain from speaking about the church attendance and teachings to the minor
child in a derogatory or unfavorable light. Mother agrees that she will refrain from speaking about race,
gender, and/or ethnicity, to the child in a derogatory or unfavorable light.
11, The parties agree that there shall not be any public displays of affection between
themselves and any other person, excepting Immediate relatives, while in the presence of the minor child.
The parties further agree that persons whom the parties are dating or are romantically involved with shall
not be present during periods of custody. It is contemplated by the pertias that at some point in the
future they may enter a Iong,term romantic relationship with another and want the minor child to meet
that person. In the event that a party has dated a partner for a substantial period of time. and there is a
commitment to a permanent, monogamous relationship. the parties agree that they will inform each other
of that so that they may arrange for the minor child to interact with that person. A substantial period of
time shall be defined as one (11 year. unless after a good faith examination of the situation, the parties
agree that it would be appropriate to introduce the minor child to that person. However. in no event shall
either of the parties introduce the minor child to a person with whom they have a permanent.
monogamous relationship of less than nine (91 months. The parties specifically agree not to expose the
minor child to casual romantic partners, or people they are casually dating.
12. Father agrees to consolidate any and aU pornographic materials including, but not limited
to, magazines, books and/or videotapes, in one central location, and to keep such materials out of the
reach of the child. Fether further agrees to refrain from viewing and/or utilizing such materials while the
child is in his custody.
13. The parties agree to make their respective residences as "baby proof" as possible. and to
devote their full attention to the child when she is in their custody. Furthermore. the natural parent shall
be the child's primary caregiver and shell assume primary responSibility for the child when in thet parent's
custody. This shall not be construed to prevant Mother from use of . babysitter for occasional social
engagements that may extend beyond the child's bedtime, however. Father shall be givan the right of
first refusal,
14. Neither party shall remove the child from the Harrisburg artI without giving reuonabIe
notice to the non-c:ustodial parent.
16. The parties agree to promote and facilitate reasonable telephone contact between the
minor child and the non,custodial parent and agree to refrain from speaking about the non-custodial
parent in a derogatory, offensive, or unfavorable light while in tha presence of the minor child. Mother
specifically agrees to refrain from speaking about Father's sexual orientation. in connection with Father,
in a derogatory or offensive light to the minor child. It is contemplated by the parties that at some point
in the future Father's sexual orientation will be addressed with the child. When that time arises and
when the child is capable of thoughtful understanding, the parties agree to work together in order to
address the situation. and may enlist the services of an expert in order to promote the welfare end best
interests of the child.
16. During any period of custody, the custodial parent agrees to refrain from using drugs or
alcohol to the point of intoxication or impairment in the presence of the child and shall ensure to every
extent possible that no guests use drugs or alcohol to the point of intoxication in the child's presence
either.
17, This is the minimum amount of partial custody for Father. and the parties are encouraged
to expand upon this schedule.
1 B. The parties agree that this Custody Stipulation shall be subject to modification in
accordance with the laws of Pennsylvania,
19. The parties intend that this Stipulation be made into an Order of Court.
I
Date: 9/1 f / ') 9
I ,
Iu)~ la~) t/~tntltlJ
Richard Vanadia
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ISSEP 2 9 1997
RICHARD VANADIA, . IN THE COURT OF C01MClol PLEAS OF
.
Plaintiff . CUMBERLAND CXllJNTY, PENNSYLVANIA
.
.
.
vs. , NO. 97-4347 CIVIL TERM
.
,
.
PENNY VANADIA, . CIVIL ACTIOO - LAW
,
Defendant . IN CtlS'roOy
.
<lUlI!R tP <XJ.m
All) tDf, this 23rd day of SeptentJer, 1997, the Conciliator, being
advised by Plaintiff's counsel that all custody ill8Ue8 have been resolved
by ~I::-...nt of the parties, hereby relinquishes jurisdiction in this case.
~a'A jL~
wn s. SUnday, Esqu
CUstody Conciliator
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:IN TIfE COURT OF COMMON PLEIIS OF
:CClHDERLlIND COUNTY, PENNSYLVANIA
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Defendant
.
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:CIVIL ACTION - LAri
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: CUSTODY /VISI-TATION
19Cfl
.
ORDER OF COURT'
AND NOW, this (date) 'is I (::x.:, I ell, upon consideration of the
attached complaint, it is hereby directed that the arties and
their respective counsel appear before ,
the conciliator, at ( , r.'. I '
on the ;:)~ day of ~9W('.\ht' r , 19C11 , a I ' (;(')
p. He, for a Prehearing Custody Conference. At such conference,
an errort will be made to resolve the issues in dispute; or ir
this cannot be accomplished, to derine and narrow the issues to be
heard -by the court, and to enter into a temporazy order. Either
party.may bring the child who is the subject or this custody
action to the conference, but the child/children's attendance is
not .mandatory. Failure to appear' at the conrerence' Jll4Y provide
grounds ror entry of a te.mp<?rary or .Penuanent order.
FOR %'HE COURT:
By:.)-jn l\l'I1 .J ~')..Al!)',da~. (~.
CUstOd~ciliator J(Ie)
rou SHOULD TAKB THIS PAPER TO roUR LAmER AT ONCE. IF rou DO NOT
HAVE A LAfiYER OR CANNOT AFFORD ORB, GO TO OR DLBPHONB %'HE OFFICE
SET FORTH BELOW TO FIND OUT WHERE roo CAN GET LE:GAL HELP.
OFFICE OF THE COURT ADNINIS'l'RATOR
COURTHOUSE, FOURTH FLOOR
CARLISLE PA 17013
(717)240-6200
~
",,*
099999~OIAullullll. 19971MCDIPARl654U
(el The Defendant has eSSlntiaUy denied Plaintiff extendad contact with the
minor child.
8. each parent whose parental rights to the child have not been terminated and the person who
has physical custody of the child have been named IS parties to this action.
WHEREFORE. Plaintiff requests tha Court to grant joint. physicalllegal custody of the child to the
Plaintiff .
Respectfully submitted.
JOHNSON. DUFFIE. STEWART. WEIDNER
DATE:~. 1997
By:~t~l 'Jim Jtltt:i-l
Keirsten L. Walsh. esquire
Attorney 1.0. No. 78243
301 Market Street
p, O. Box 109
Lemovne. PA 17043-0109
Telephone (717) 761-4540
Attorneys for Plaintiff
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adhered to. The IXfendant will then be able to consistently
move, in order to thwart objectionable items in any court order.
WHEREFORE, Father requesl~ that the court order the policies to facilitate the
enforcement of it's order so that the Father has the child pursuant to March 19th. 1998
Cumberland county Order or Plaintiff's re-modified order, beginning , 1999,
as the week he has the child from: to
Petitioner also requests that the Court find the IXfendant in contempt of court and
sentence her to imprisonment for a period of six months and a fine ofSSOO.OO.
Petition further requests that. pursuant to the Uniform Child Custody Custody
Jurisdiction Act, 23, Pa.C.S.A. Sub S347 (c), the court communicate with the Court in
Chester County regardinlljurisdiction of the Petition(s) for modification, the
TEMPORAR Y CUSTODY ORDER. and Contempt and. keep jurisdiction in
Cumberland County.
Lastly, the Plaintiff requests strongly. that the Defendant be placed on custodial probation
either through Domestic Relations. or the appropriate monitoring agency.
Petitioner also requests any other relief that the court deems just and proper.
Respectfully Submitted,
JJ4Ju
Richard Vanadia
4621 - S South Salem Church Road
Dover.PA 1731S4243
(717) 308-1049
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