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HARRY LEIGH SMITH,
plaintiff
IN THE COURT OF COMMON PLEAS
OP CUMBERLAND COUN'ry
OP PENNSYLVANIA
CIVIL ACTION - LAW
No.9 'I- 0/ liSI (~, ,I ,{ '-7f~I' /I \
vs.
CYNTHIA ANN SMITH,
Detendant
COMPLAINT rOR CUSTODY
1. Plaintiff is Harry Leigh smith, residing at 517 Pront Street,
Marysville, Perry County, Pennsylvania.
2. Defendant is cynthia Ann smith, residing at 3 William Penn
Drive, Camp Hill, Cumberland County, pennaylvania.
3. Harry Leigh smith seeks joint legal and partial physical
custody of the following childl
Name
Brandon T. smith
Present Residence
8 William Penn Drive
Camp Hill, PA 17011
Age
5
4. The child was not born out of wedlock.
5. The child is presently ill the custody of cynthia Ann smith
who resides at 3 William Penn Drive, Camp Hill, Cumberland County,
Pennsylvania.
6. During the past five years, the child has resided with the
following persons at the following addresses:
Person Addresses Date
Harry Leigh smith 109 Summer Lane Birth to 7/93
cynthia Ann smith Enola, PA 17025
Joshua Irwin
Harry Leigh smith
Cynthia Ann smith
Joshua Irwin
3 William Penn Drive
Camp Hill, PA 17011
7/93 to 10/96
II
HARRY LEIGH SMITH,
Plaintiff
IN THE COUR'r OF COMMON Pl,EAS
OF CUMBERLAND COUNTY
OF PENNSYLVANIA
CIVIL ACTION - LAW
NO. 97-4751
vs.
CYNTHIA ANN SMITH/
DGfendant
ArrIDAVIT OF NAILING
COMMONWEALTH OF PENNSYLVANIA
ss t r
COUNTY OF CUMBERLAND
stephen G. Held, Esquire, the attorney for Pl~intiff, being
duly sworn according to law, !Jays that he mailed by certified,
restr icted ma ii, return rece ipt requested, a true and correct copy
of the Plaintiff's Complaint for custody in this action to the
Defendant at her residence, and that Defendant did receive same as
evldenced by the signed receipt attached hereto as Exhibit "A",
By:
Attorney for Plaintiff
Sworn to and subscribed
before me this 2nd day
of October, 1997.
i ~'k:-.!L~u c:=. '-5:>t:i-H-f'1""
Notary Public
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C. One addltlonel evening during the week for dinner or
other ectlvltles with Father from 4:30 p,m, until 7:00 p,m.
3. Father shall hava the child on Father's Day and Mother shall
have the child on Mother's Day, These periods of partial custody and
visitation shall occur from 9:00 o,m. until 7:00 p.m.
4. Mother shell always hove tho child on Christmas Eve until
Christmas Day at 10:00 a.m. Fathor sholl always have the child from
Christmas Day at 10:00 a.m. until December 26th at 10:00 a,m,
5. Each party 15 entitled to two uninterrupted weeks of
vacation with the child during the summer months. Father shall have
first preference as to the weeks in which he intends to exercise this
period of exclusive custody and shall notify Mother no later than April
1st of each year as to when he intends to exercise these periods of
visitation. Mother shall notify Father no later than April 15th of each
year as to when she intends to exercise these periods of custody.
6. Such other times as the parties may agr~Af.)
, /'
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BY Tt:tC'
J.
Stephen G. Held, Esquire - l'~""o")'~.(
Michael A. Scherer, Esquire -~,- "
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e. The Defendant's position on custody Is as followot Saa attached Ordar.
7. Need for saparoto counsel to represent chlld(renl I Neither party
raquested,
8. Nead for Indepandent psychological evaluation or counsallng: None
requested and tha Conciliator does not believe any Is necessary.
Datal October 22, 1997
Ich el L. Bangs
Custody Conciliator
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