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Home My WebLink About98-00834 HEATHER SMITH, : IN THE COURT OF COMMON PLEAS Plalnttff/Petltloner : CUMBERLAND COUNTY, PA Y. CIVIL ACTION - LAW BRADLEY W. SMITH, CUSTODYIVISITATlON Defendant/Respondent NO.'H . f3'lCIVIL TERM ORDER AND NOW, thls.Jcl... doy of reL\.n r,! , I 99B, upon conslderotton of the ottoched Compl111nt, 1t Is hereby dIrected thot the partIes and their respectIve counsel oppeor before tD.. r'\_\, ~l',b'1) L-rCh the Conclllotor ot ::SCf~.). Hc."'~\-'l_ \ \ \-'\t'rhy-iI(\'h.AJl (V.~, on the...LL doy of Hrrr \'\ , 19q{ at.LLD f.m" for 0 Pre-HeOr1ng Custody Conference, At such Conference, an effort wfll be mode to resoll'e the Issues In dispute; or 1f this cannot be accomplfshed, to define ond narrow the Issues to be heord by the Court, and to enter Into a temporory order, Either party moy br1ng the Child who Is the subject of th1s custody action to the conference, but the Chlld!Chlldren's attendance Is not mandatory. Fallure to appear at the Conference, may provide grounds for the entry of a temporary or permanent Order. . J 1 , I . I FOR THE COURT, I , I I I ~ " . \..; .,. i i . . i' ., Date of Order: ') II ~Iq X By~~~\\Y\J\.J\~!(}u1 Custody Conc1l1ator llb)U t- YOU SHOULD TAKE THIS PAPER TO YOUR LAWVER AT ONCE, IF YOU DO NOT HAVE A LAWVER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. :"i Orrtce of the Court AdminIstrator Courthouse, Fourth Floor Carl1sle, Pa 17013 (717) 240-6200 \1 . ,. I , " " I. \ I . it...... I Fllr:o.mlCE Oc -",.. 1"""""-"f)TA"'Y I' ".'\i'\, I\n 98 FEf3 13 Pi\ i~: 5 ! ('Li""';:'" :i.'. .....I...'M J .\h.. .~j I.' " ,\. ",'~. \~ I ,! l PE;-'!i{)Yi."/'~ ,j.\ ;; '1..1 . f!r C) x] -9{ d-/J.~f &(;-(. ~/f-t;j.~ ~r.l# ~~ ("''-''- /~tbc:W ,..;.... 7..4:.) 7'b:i;~ {Hrtfij z: d:/,:' {~ /11a$ 7i. 4# cd~,.~ ! ,I,r. ::~ HEATHER SMITH. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PA PIa' nt Iff y, CIVIL ACTlU" CUSTODY ....,- NO, <N'. f3'1 Clvd IA'- BRADLEV W. SMITH. Defendant COMPLAINT FOR CUSTODY AND NOW. comes Plolntlff. HEATHER SMITH. throuoh her ottomeu. The Low Office of Dorrell C, Dethlefs. ond oilers the followlna: 1. The Plolntlff Is Heother Smith. on odult lndMduol current14 resIdIng ot 519 South West street Aot, D. Corllsle. PennslJlllonlo 17013. 2, The Defendont Is Brodleu W. SmIth. on odult lndMdUol. currentlu resldlntl ot 14 Ll!newood Bul1dtna. Middletown, DouOhln Count!,!. Pennsl!lvonlo. 3. Plolntlff seeks orlmoru ohuslcol ond joint letlol custodU of Zochor\) R, Smith. born June 12. t 995, 4. Zocooru R. Smith wos born durtna the oortles' marrloge. 5. Zochoru R. Smith ts oresentlu In the custodlJ of the Platntlff. who Is his notural mother. end currentlu resIdes with Plelntlff at 519 South West Street, Ccrl1s1e. cumberlcnd Countu. Pennsulvenle. 6. SInce the chlld's birth. Zacharu R. Smith has resided at the followlno rest dence: ResIded with Locatl on Dates (ll PIAlnl Iff Anrl Defendant 700 SAlAm RnArI Etters. PA fi/l?/q~ tn ~/qri ,i (?1 PIAlnllff 40A? RAW1Alnh SIrAAI Harrlsbura, PA ~/qri In 1/1/qA (31 PI 111 nWf 51 q Soul h WAsI SI reAl. AnI () Carllsle. PA l/1/qA 10 PrAsAnl 7. Neither oartu has oartlcloated as a oartu or witness In anu other '\ , I oroceedlna Involvlna the custodu of the chlld. 6. Plalnt1ff has no Information of a custodu oroceedlna concernlna the ch11d oendlno In a Court of this Commonwealth. 9. PlaIntiff does not know of a Gerson not a oortu to the oroceedlnos who has otKislcal custodu of the child or claims to have custodu or vls1tatlon rl9hts with resoect to the child. 10. The best Interests and oermanent welfare of Zacharu R. Smith w111 be served by orantlno the rellef reouested because the Plaintiff Is better able to orovlde a stable. secure environment In which to raise the child. i I 11. PlaIntiff Is reouestlno lolnt leoal custodu and orlmary ohyslcal custodlJ of the aforementioned chlld. wIth visitation rlohts to be awarded to Defendant. 12, Plaintiff oroooses a VisitatIon schedule os follows: Defendant Is to have vIsitatIon every ottler weekend, from Frldllu Evenlno untll Sundau EvenIng and one Evenlno durlno each week from 5:00o.m. untIl 6:30o.m. I : . ~ ! \ .' WHEREFORE, Plolntfff resoectrullu reouests thIs Court to O~nt faInt leool custOdu ond orlmoru ohuslcol custodu of Zochol1J R, SmIth to PIOlntlff. sUblect to Defendont.s temoo~ru custodu of the child for the ouroose of YIsltotlon. ResoectfullU SUbmItted, Dote: ;;"/(0 J 9 r 'A" ;.' ,/ 8U:-L' .1a; Mlchoel J. PUkosh, Esou e Attorneu 10- 58651 Woaner 8ulldlno - SUIte 204 355 North 21 st Street Camo Hili. PA 17011 (717) 975-9446 Attorneu for PlaIntIff ~ ~ HEATHER SMITH, Plaintiff/Petitione~ IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : vs. NO. 98-834 CIVIL TERM CIVIL ACTION - LAW . . BRADLEY W. SMITH, Defendant/Respondent . . : IN CUSTODY OODER OF COORT AND ~, this \ l. tl. day of ~ 7 ~ L.~ consideration of the attached Custody ConcllJ.ation Repo~t, and directed as follows: , 1998, upon it is orde~ed 1. The Mother, Heather Smith, and the Fathe~, Bradley W. Smith, shall have sha~ed legal custody of Zachary R. Smith, born June 12, 1995. 2. The Mother shall have p~imary physical custody of the child. 3. The Father shall have partial physical custody of the Child on alternating weekends, beginning March 13, 1998, from Friday between 5:00 p.m. and 6:00 p.m. until Sunday at 5:00 p.m. The Father shall also have custody of the Child on alternating Mondays, fOllowing the Mothe~'s weekend periods of custody, from between 5:00 p.m. and 6:00 p.m. until 8:30 p.m. The Fathe~ shall have additional periods of custody with the Child as arranged by mutual agreement of the parties. 4. The parties shall alternate o~ sha~e having custody of the child on holidays as follows: A. Christmas: In every year, the Father shall have custody of the Child from after work (o~ beginning at 2:00 p.m. if the Fathe~ is not wo~king) on Christmas Eve until 11:00 p.m. The Mothe~ shall have custody of the Child f~om Ch~istmas Eve at 11:00 p.m. until Christmas Day at 2:00 p.m. and the Fathe~ shall have custody of the Child on Christmas Day at 2:00 p.m. until 8:00 p.m., unless Christmas Day falls on the Father's period of custody unde~ the regular schedule in which case the Father shall ~etain custody until termination of the regular period. B. Thanksgiving: In even numbered yea~s, the Mother shall have custody of the Child on Thanksgiving Day. In odd numbered years, the Fathe~ shall have custody of the Child on Thanksgiving Day f~om 9:00 a.m. until 8:00 p.m. C. The parties shall make arrangements to sha~e or alternate having custody of the Child on the ~emainder of the holidays, including the Child's birthday, by mutual agreement. D. For exchanges of custody on holidays, the Father shall pick up the Child f~om the Mothe~' s residence and the parties shall alternate o~ otherwise sha~e the responsibility for p~oviding transportation for retu~n of custody to the I' /i " , .. J ') '\ , I Ih , I . OJ'! ~A.o".