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Home My WebLink About97-04592 ..., ~ ~ ~ ~ ~ " ~ .~ ... ~ :-.. . " " II I I "tl " II.'U' , " " , , ,I ,Ii I' Ii " jl , "i 'I' , , " ,.) ,I ! I , " 'I " , 1 , 1 !i " , , 'J' " " , , ,) ," " i' I, , ',' Ii I' :', 1.1 Ii 1 " " " , .j , , , I, ,I ',1-'1 n 1.1. , " , I " I' I, id , I " ;'j I,' :' " I' " '," I I I! " 'I , , I, , , " , I, i' , " " " , , I, -,I , " j" 1'1 , , I , I " , , , " , I , I II iill " I' /'!' J , ' ,I " , I " , iI , , I it I , , , 1-' 1 , , d , I , , , " , , " il " , , H Iii ,I .. 'I " ,,-" I i] " , " " " , , 11;l; " '.j , '\'1 '; itl .Ii i'(' " " .. , 'I ., 1) ,I , ,,'I, " "i ,'I Ii, " 'L\CU'l\lcu"~lLr.Q.d RICHARD L. PAINTBR, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBBRLAND COUNTY I PBNNSYLVANIA I 97, t./1<)J.. L0-J..:::tI-W1 v. I NO. I CHERYL H. SIMMONS I I CIVIL ACTION CUSTODY Defendant I ORDIR or COURT AHD HOW, this ~ day of 1\J<jU~,:Y\ I 1997, upon consideration of the attached complaint I it is hereby directed that the parties and their respective counsel appear before l (I'..J!",-', '~ 1""\(.\'......\ ' l'{( , I the Concilia.tor, at ~ I,...J. i'-\(W, \'\ , \-\0:-1.1,,01'\\< . ,b , C}- on the --1- day of Cr kk.,(' ( , 199.l, at L)',(;G I A:M" for a Pre-Hearing Custody Conference. At such conference, an effort will be made to reeolve the issues in dispute I or if this cannot be accompliehed, to define and narrow the issues to be hsard by the court, and to enter into a temporary order. All children age five or older may also be preaent at the conference. Failure to appear at the conference may provide grounda for entry of a temporary or permanent order. FOR THE COURT, ~..... By: ,'" _,( Custody (n,:>, DO NOT OFFICI YOU SHOULD TAXI THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU BAVZ A LAWYIR OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE BET PORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse, 4th Floor Carlisle, PA 1701J Telephone: (717) 240-6200 'l\Qij.t\l~Uij.td~,nut RICHARD L. PAINTERt I IN THE COURT OF COMMON PLEAS OF Pla ntiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. I NO. I CHERYL M. SIMMONS I I CIVIL ACTION ~W Defendant I IN CUSTODY NOTtCE TO DEFBND TO THE DEFENDANT NAMED HEREI CHERYL M. SIMMONS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims aet forth in the following complaint, you must take action within twenty (20) days after the 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 caae may proceed against you and a judgment may be entered against you by the Court without further notice for any money claimed in the com- plaint 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 NO~ 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 Cumberland County Courthouse Fourth Floor Carlisle, PA 17013 Telephone: (717) 240-6200 '1 \':UWI.\II.lllt.' ,O:Il/tl\lf.ljl RICHARD L. PAINTER, I IN THB COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY I PENNSYLVANIA I v. I CIVIL ACTION CUSTODY I 'I"" '/ \",(.;. (lwd r,~.-, CHBRYL M. SIMMONS, I NO. Defendant I ~OR CUSTODY 1. The plaintiff is Riohard L. Painter, an adult individual, residing at 229 Second Street I Apartment 2, Highspire, Pennsylvania 17034. 2. The def.endant is Cheryl M. Simmons I an adult individual I reaiding at 7B Riehland Lane, Camp Hill, Pennsylvania 17011. 3. Plaintiff seeks custody of MATTHEW A. SIMMONS who residea at 78 Riohland Lane, Camp Hill, Pennsylvania 17011 and is eight (8) years of age having been born on December 21, 1988. The child was born out of wedlock. The child is presently in the custody of the defendant who resides at 78 Richland Lane, Camp Hill, Pennsylvania 17011. During the past five years, the child has resided with the following persons and at the following addresses I UA!:m ADDRESS DATES Cheryl M. Simmons 78 Richland Lane September 1994 Camp Hill, PA 17011 to present Cheryl M. Simmona Mechanicsburg, PA September 1992 to September 1994 -1- / RICHARO LEE PAINTER, Plaint:iff I IN THE COUPT OF COMMON PLEAS I DAUPHIN COUNTY I PENNSYLVANIA I I NO. 4359 S 1989 I I CIVIL ACTION - LAW I CUSTODY/VISITATION I VB. CHERYL M. SIMMONS I Oefendant: ORDER OF COURT >m AND NOW, to wit:, this '6 day of 'N\(\~\1 1990, the parties and their respective eounsel having appeared for a custody conciliation conferenee on March 5, 1990, and having reached an agreement wi t:h regard to the best interests and welfare of the minor child, Matthew, it iB hereby ORDERED AND DECREED as follows I 1. Primary physical eustody of the aforementioned minor child shall be in the Defendant, Cheryl M, Simmons. 2. The Plaintiff shall have visitation and partial custody in aecordanee with the following schedule: (01) For the four (4) Saturdays in March, from 9:00 a.m. through 6:00 p.m. (b) If the four Saturdays in Mareh have been eompleted, then the plaintiff shall have every weekend in April from Saturday at 9:00 a.m. through Sunday at 6:00 p.m. However, return on Easter Sunday shall be at 2:00 p,m. ~:XllIllI T A ~ .... '..' ,'~ ',II r ~,lJ'IIJri, Iq{QI/o'" .:J\'J, JlJ?'" 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" " , , ,l I 'I" 'I I', \ " I , " , , , 'J 11 " ' \ vs. I IN THE COUR'l' O~' C<t>IMON PLfJ\S O~' I CUNlIERLAND COlIN'rV, PEtlNSYLVANIA I I NO. 97-4592 CIVIL TERM I : CIVIL A~l'ION - LAW I IN CUSTODY RICHARD L. PAI~rER' Plaintiff CHERYL M. SIMMONS, Defendant ClU>BR OF CXJURT AND NaoI, thia ? . day of Oc.11l A..., , 1997, upon eonsideration of the attaehed Custody Conciliation Report, it is ordered and direeted as follows: 1. The Father, Riehard L. Painter, sifTJ1lOns, shall have shared legal eustody of Oeeember 21, 1988. and the Mother, Cheryl M. Matthew A. SifTJ1lOns, born 2. The Mother ahall have primary physical custody of the child. 3. The Father shall have partial physieal custody of the Child every Sunday, beginning October 5, 1997 from 11:00 a.m. until 7:00 p.m., with the exeeption of the seeond weeJlend in october when the Father shall hllve eustody of the Child on Saturday, October ll, 1997 rather than Sunday. 4. The parties aeknowledge that the Milton Hershey School, in which the Child is eurrently enrolled, permits parents to seleet five weekends during eaeh school year whieh the Child may spend with the parents from Friday through Sunday. The parties also acknowledge that the Mother has eleeted to have eustody of the child for the weekend from October 10, 1997 through October 12, 1997. Beginning in 1998 and extending through the remainder of the sehool year, each party shall be entitled to seleet two weekend periods of custody with the Child from Friday at 7:00 p,m. through Sunday at 7:00 p.m., upon providing two weeks advance notiee to the other party. Beginning with the 1998 - 1999 school year, the Mother shall be entitled to seleet three weekend periods of custody during even numbered yeara (defined by the year in whieh the sehool year begi~) and two weekend periods of eustody in odd numbered years. The FatherBhall be entitled to seleet two weekend periods of eustody in even numbered years and three weekend periods of euatody in odd numbered years. Each party shall provide the other with at least two weeks advance notiee of his or her seleeted weekends. 5. The Father shall have custody of the Child during the summer sehool vaeation for three (3) noneonseeutive weeks and two (2) additional weekends from Friday at 7:00 p,m, until Sunday at 7:00 p.m" upon providing thirty (30) days advance notice to the Mother. 6. The parties shall share or alternllte having custody of the Child on holidays as follows: A. Thanksgiv~ During the Thanksgivin~, sehool break, the Father ahall have euatody of the Child from Saturday/ November 22, 1997, at 11 tOO a.m. until sunday/ November 23, 1997/ at 7100 p.m. ond on '\'hankBgiving Day from 3130 p.m. until 6too p.m. '1'he Mother shall have custody of the Child during the remainder of his 'l'hanksgiving Behool break. In future yenrs over the Thanksgiving holiday/ the partiea shall cooperate in making compar.able arrangements for the Father to have periods of cUBtody over the 'l'hanksgiving school break based upon tho school schedule. a. Christmaa - During the 1997 Christmas school break/ the Father shall have euatody of the child fr.om Christmas Day at 3t30 p.m. until the following sunday at 7100 p.m. The Mother shall have eustody of the Child during the remainder of his ChriBtmas Behool br.esk, In future yearB ovor the Christmas holiday/ the parties shall cooperate in making comparable arrangements for the Fathel:' to have periods of custody over the Christmaa school br~ak based upon the school schedule. C. Easter S rin Break - During the Eaater and Spring break/ the Fat er a a laVO custody of the child from April 17, 1)98 at 7tOO p.m, until April 19/ 1998 at 7:00 p.m. The Mother shall have eustody of the child during the remsinder of his Easter and Spring break. In future years over the Easter/Spring break/ the parties shall cooperate inmsking comparable arrangements for the Father to have periods of custody over the Easter/Spring sehool break based upon the school schedule. D. J~~r 4th - The parties shall alternate having custody of the C d on JUly 4th/ beginning with the Father having eustody of the Child in 1998. The times for the period of eustody over the July 4th holiday shall be arranged by mutual egreement of the parties. E. - The Father shall have eustody of t e C ld every year on Father's Day at times permitted by the school visitation sehedule and the ~lother shall have eustody of the Child every year on Mother's Day as permitted by the school visitation sehedule. During the weekend when the Mother has eustody of the Child on Mother's Day, the FlIther shall have cUlltody of the Child on the preeeding Saturday. F. In the event of a confliet between the regular and holiday eustody Ilchedules / the holiday custody sehedule shall take preeedence, 7. The parties agree that the Child shall remain at the Milton Hershey Sehool through the remainder of the 1997 - 1998 sehool year unless the Child desires otherwise, 8. Neither party shall use illegal drugs or consume alcohol imnediately before or during his or her periods of custody with the Child. 9. EBeh pBrty shall notify the other promptly of any medical emergencies involving the Child whieh oceur during his or her periods of custody. La. Neither party shall do or say anything whieh may estrange the Child from the other parent, injure the opinion of the Child aa to the other parent at' hamper the free and natural development of the Child's love and respeet for the other parent. ll. This Order is entered pursuant to an agreement of the parties at 4 Custody Coneiliation Conference. The pBrties may modify the provisions of this Order by mutual agreement. In the absence of mutusl agre~nent, the terms of this Order shall eontrol. BY THE COURT, J. eel Gerald J. Shekletski, Esquire - C nsel for Father ~'.....b.LW :..J.i. 10/9/'7. Gary J. Imblum, Esquire - Counsel for Mother - ~v- m<<: ..J . "f. , I