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KATHY GROVE PRINSEN,
Plaintiff
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY. PENNSYLVANIA
vs.
NO. 0" - ~LI 'I 'I C....:.J ~-
ONNO R. PRINSEN,
Defendanl
IN CUSTODY
ORDER OF COURT
AND NOW, this \.~ day of \0:\-\en,hc( , 1997, upon consideration of the
Complaint filed in this matter, it is hereby directed that the parties and their respective counsel
appear before ~vJ(\ ~ ~c\o..1~Jle conr.i1iator, at ~q '<-->. MO.,,,,, ST , ,
kk-c..\\C'\f\\r ,<",'o-l; C) , pf'.... , Pennsylvania, on -r 'C'-..c\C..~r-' the q
day of \"'r\ (>I~'\h'l ,1997, al ~ o'clock .Q.,m. for a Pre-Hearing Custody
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 10 be heard by lhe Court, and to enter a
temporary order. All children aged five or older may also be presenl at lhe conference. Failure to
appear at the conference may provide grounds for entry of a lemporary or permanent order.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HA VE 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, FOURTH FLOOR
CUMBERLAND COUNTY COURT HOUSE
1 COURTHOUSE SQUARE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (7 I 7) 240-6200
FOR THE COURT,
BY_,~
CUSTODY CONCILIATOR
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KATHY GROVE PRINSEN,
Plaintiff
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
NO. 97. r. 0 '1'1 ~J -r;~
IN CUSTODY
vs.
ONNO R. PRINSEN,
Defendant
COMPLAINT FOR CUSTODY
AND NOW comes the Plainliff, Kathy Grove Prinsen, by her attorney, Samuel L.
Andes, and makes the following Complaint for Custody:
I. The Plaintiff is Kalhy Grove Prinsen, an adult individual who resides at 19 Windsor
Way in Camp Hill, Cumberland County, Pennsylvania.
2. The Defendant is Onno R. Prinsen, an adult individual who resides at ISI0 Spring
Knoll Court in Harrisburg, Dallphin County, Pennsylvania.
3. The Plaintiff and Defendant were husband and wife, having been married on 22
November 1992 and divorced on 19 December 1995,
4. The Plaintiff and Defendant are the nalural parents of one minor children, Daena
Kathryn Prinsen, born I I March 1993.
S. During the past five years, the minor child has resided with the following persons at
the following addresses:
July 1993 10 May 1996 123 November Drive
Camp Hill, PA 1701 I
Plaintiff
June 1996 to lhe present 19 Windsor Way
Camp Hill, PA 17011
Plaintiff
6, The falher of the child is the Defendant who resides at the address set out above. He is
married to the Plaintiff.
7. The mother oflhe child is lhe Plaintiff who resides at lhe address set out above. She is
married to the Defendant.
8. The Plaintiff is the natural mother of the child, Plaintiff currently resides with the child,
9. The Defendant is the nalural father of lhe child. Defendant currently resides alone.
10. The Plaintiff has not participated as a party or in any other way in any litigation
concerning the custody of the child in this or any olher Court.
The Plaintiff has no infonnation of a custody proceeding concerning the child in a
Court of this or any other jurisdiction,
Plaintiff knows of no other person not a party to this action already who has physical
custody of or claims 10 have custody or visitation rights with the said child.
11. Each parent whose parental rights to the child have nol been tenninated and the
person who has physical custody of the child have been named as parties to this action.
12. Plaintiff seeks an award of primary physical cuslody of the child to her. She seeks
such an award for the following reasons:
A. The child has resided in the primary physical cuslody of Plaintiff since the
child's birth.
B. The Plaintiff is better able to provide for alllhe needs of the child.
C. The child has bonded 10 lhe Plaintiff and is best served by remaining in the
Plaintiffs primary custody,
COMMONWEALTH OF PENNSYLVANIA )
( SS.:
COUNTY OF CUMBERLAND )
Kathy Grove Prinsen, being duly sworn according to law, deposes and says that the facts set
forth in lhe foregoing docurnent are true and correct to the best of her knowledge, information,
and belief.
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Kat y ve Prinsen
Sworn to and subscribed
before me this {).8f1) day
of &ftOP.,QA... . 1997.
NOTAIlK IiiAI.
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY. PENNSYLVANIA
KATHY GROVE PRINSEN,
Plaintiff
NO. <1 'I -10 0'14
ONNO R. PRINSEN,
. Defendant
IN CUSTODY
AND NOW,this "2-1
ORDER OF COURT
day of ~~I997. upon the Slipulation of the parties
expressed in writing, we hereby Order and Decree as follows:
I. Legal cuslody of lhe minor child, Daena Prinsen, born March 11, 1993, shall be shared
by her parents, lhe Plaintiff, Kathy Grove Prinsen and the Defendanl, Onno R. Prinsen.
2. The mother of the child, Kathy Grove Prinsen, is hereby awarded primary physical
custody of the child.
3. The falher of the child, Onno R. Prinsen, shall have the following periods of temporary
or partial cuslody of lhe child.
a. Alternating weekends from Friday at 7:00 p,m. until Sunday at 7:00 p.m.,
commencing on a date to be mutually selected by the parties.
b. Every Wednesday evening from 5:30 p.m. until 8:30 p.m.
4. The parties shall share cuslody of lhe said child on 1he following holidays. on a
alternaling basis, from 9:00 a,m, until 7:00 p.m.; Easter Sunday; Memorial Day; July 4th; Labor
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Day; Thanksgiving. The alternating schedule sha1\ commence with the father having the child on
Memorial Day, 1997.
5. The parties shall share custody of the child on Christmas each year so that mother sha1\
have the child from the morning of December 24lh unti13:00 p,m. on December 25lh each year and
the father shall then have the child from 3:00 p.m, on December 25lh until 7:00 p.m. on December
26lh each year.
6, The schedule for holidays sel forth in lhe preceding two paragraphs shall prevail over the
other provisions of this Order regarding temporary or partial custody,
7. Each party shall have the child for four weeks of va cali on during the surnmer months
uninterrupted by periods of custody or visitation with the other parent (bullhe other parent shall
have telephone contacl as provided in Paragraph I 1 during lhaltime). The periods shall be
exercised so that no more than two weeks shall be consecutive, Father shall notify mother of the
specific weeks in which he intends to exercise his summer vacation by the first of February
preceding lhe summer months and mother shall provide falher with the weeks she intends 10
exercise her summer vacation by the first of April preceding the summer months.
8. For any period of time when lhe father shall have the child for overnight periods of
partial or temporary cuslody at a location olher lhan his primary place ofresidence, he sha1\ advise
mother, at least forty-eight hours in advance, of the location and telephone number where the child
will spend the night. In the eventlhat either party takes the child away from the primary residence
during any of the periods of summer vacation, lhey will provide the other parent with the address
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:i and telephone number where the child will be staying at least forty-eight hours prior to taking the
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II regardless of which parent the child is then with at the time of such scheduled aClivity or event.
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9. The parties shall make every effort to lake the child to any scheduled activity or evenl,
Such scheduled events will include, but are not limited to, school evenls, church activities, social
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10, Each parent will give lhe other parenl alleast ninety days advance notice in lhe event
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I I, Each parent shall have reasonable contacl wilh the child, including telephone conlacl,
during the periods when the child is with the other parent or in the cuslody, temporary custody, or
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Ii the child is not then available, the parent having the child with them shall be responsible to notify
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Ii the child of lhe call and assist her in returning the lelephone call on a timely basis, Each of the
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Ii parties hereto shall keep lhe other advised of the telephone number at their primary residence and
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
NO, 11J - Cuol4
KATHY GROVE PRINSEN,
Plaintiff
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IN CUSTODY
vs.
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II ONNO R. PRINSEN,
!I Defendant
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STIPULATION
The above-named parties hereby slipulate and agree that the attached Order shall be entered
as the Order of custody in the above-captioned matter.
IN WITNESS WHEREOF, they have set their hands and seals this z.a.
day of
Odt.bv 1997.
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il Samuel L. Andes
II Attorney for Plai~liff
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colt Moore
Attorney for Defendant
~fC 1 1 1997
vs.
IN THE COORT OF roIMal PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
I
I NO. 97-6044 CIVIL TERM
I
I CI1IL ACTION - LAW
I IN ClJS'IX)DY
KATHY GROVE PRINSEN,
Plaintiff
ONNO R. PRINSEN,
Defendant
(IUD at cxxm
AND NON, this 9th day of December, 1997, the Conciliator, being
advised by Plaintiff's counsel that all issues have been resolved by
agreement of the parties, hereby relinquishes jurisdiction in this matter.
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FOR THE COURT,
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D!lwn S. Sunday, Esquir
CUstody COnciliator
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