The URL can be used to link to this page

Home My WebLink About98-01228 I ~ I I 0 i J I i , I If! :::- ~ o o cJ ~'l;'E~ :;',<\ i",- , \ \ \ \ r c.... ~ - ';) ~ ~ i~ ~ - . 0.. ~ ~ I', ,<,\,~; ri?,~~, " \~,".. )' ",.-,-", " . ,-fe-': ~.. co tt; C} ~~ ,; o ~~ UJh~ [f:~:: ~I'" ...,.,{..) (::J',. Ll:JC ft!.! :'C. i-' U" t;.) 'I j i,' :1::': 0"" ~~ :~i _T. I~J ;:.; \, "I ~.f .1 ~_j ....:, I ,-'-'t'r,) I ..~~. f '. >~. :-;'_1J )!':l.. I Cr:'; .-~ , .:L, e;r;, :S (;I~ () ';-, ;~~; , :p; " I , . '" :,. "'-I, _ , . . N' ~'<5 t; ~ ~ - -4 I'f) . 0(") /'f) 't- ~ "8 ~~ ~ ~ I"'l -- ~ ~@~ , , - - - l" - , m - " . - V.. ~, ... ... ~I '! , .l';\i fI:\ CHARLES E. PETRIE An(llNDY AT I.AW 3528 BRISBAN STREET HARRISBURO. PENNSYLVANIA 17111 , ,'i .I" &MAR 09 1998 , , '9- ...., j:1 ~ f .~ ~ 'rr ,'-' . must be mads, the party having physical custody of the child at the time of the emergency shall be permitted to make any immediate decisions necessitated th8reby. However, that party shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party. 2. The parties shall share physical custody of the subject minor child. Each party shall have custody of the child for seven consecutive day~, with the parties exchilllging the child on Sunday afternoon at 5:00 P.M. 3. The parties shall be entitled to three (03) consecutive weeks (21 days) a year of uninterrupted visitation with the minor child. Each party ,shall provide the other with thirty (30) c;lays' notice of their intent to utilize this period of visitation. 4. The pat0rnal grandparents shall be entitled to four (04) consecuti.ve weeks (28 days) of uninterrupted visitation each year with the minor child. The paternal grandparents will provide both parents with thirty (30) d6Ys' notice of their intent to utilize this period of visitation. It is understood that mother is not requesting that the paternal grandparents have thiB period of temporary physical custody with the minor child; however, mother will provide approval upon paternal grandparents' request. VIOLET D. COOK, Plaintiff IN THI:~ COURT Of COMMON PLl>AS OF CUMBERLAND COUNTY, PENNSYLVANIA CJVIL ACTION - LAW vs. I) S-I.l.l j' Cw<i T('..~ NUMBER: DAVID A. COOK, Defendant IN CUSTODY COMPLAIN~ FOR CUSTODY NOW COMES the Plaintiff, VIOLET D. COOK, by her attorney, Charles E. Petrie, and respectfully represents as follows: 1. Plaintiff is VIOLET D. COOK, who currently resides at. Springford Drive, Harrisburg, County of Dauphin, Pennsylvania. 2. Defendant. is DAVID A. COOK, who currently resides at. 4126 Kittatinny Drive, Mechanicsburg, County of Cumberland, Pennsylvania. 3. Plaintiff seeks to have rights of shared physical and legal custody with respect to DAKOTA DAVID COOK, born May 25, 1994. The child was not born out of wedlock. The child is presently in the custody of Defendant, DAVID A. COOK. Since birt.h the child has resided wit.h the following persons and at the following addresses: From birth until July, 1995, with both parents at 418 High Streett Mechanicsburg, Pennsylvania; from ,July, 1995/ until February 1/ 1998, with bot.h parents at 4126 Kittatinny Drive, Mechanicsburg, Pennsylvania; from February 1/ 1998/ until the present under a shared custody arrangement with both parents at their respective addresses. The mother of the child is VIOLET D. COOK, who currently resides at Spring ford Apartments, HarrIsburg, Pennsylvania. Sne is married. The father of the child is DAVID A. COOK, who currently resides at 4126 Kittatinny Drive, Mechanicsburg, Pennsylvania. He is married. 4. The relationship of the Plaintiff to the child is that of mother. The Plaintiff currently resides alone. S. The relationship of the Defendant to the child is that of father. He currently resides alone. 6. The 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 in another court. The Plaintiff has no information of a custody proceeding concerning the custody of the child in this or in another court. Plaintiff does not know of a person not a party to these proceedings who has physical custody of the child or who claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by confirming rights of shared physical and legal custody in Plaintiff. 8. Each parent whose parental rights to the child have not been terminated c1ncl the persons who have physical. custody of the child have been named as parties to this action. other, with a view toward obtaining and following a harmonious policy in the child's best interests. Each party agrees not to impair the other party's right to shared legal custody of the child. Each party agrees not to attempt to alienate the affections of the child from the other party nor to permit any third person to attempt to so alienate the affections of the child from the other party. Each party shall notify the other of any activity or circumstance concerning the child that could reasonably be expected to be of concern to the other. Day-to-day decisions shall be the responsibility of the party then having physical custody. With regard to any emergency decisions which must be made, the party having physical custody of the child at the time of the emel:gency shall be permitted to make any immediate decisions necessi.tated thereby. However, that party shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party. 2. The parties shall share physical custody of the subject minor child. Each party shall have custody of the child for seven consecutive days, with the parties exchanging the child on Sunday afternoon at 5:00 P.M. 3. Each party shall be entitled to three (03) consecutive weeks (21 days) a year of unintorrupted visitation with the minor child. Each party shall provide the other wit.h thirty (30) days' notice of th~ir intent t.o utilize this period of visit.ation. 4. The pat.ernal grandparent.s shall be entitled to four (04) consecutive weeks (28 days) of uninterrupted visitation each year with the minor child. The paternal grandparents will provide both parents with thirty (30) days' not.ice of t.heir intent to ut.ilize this period of visitat.ion. It is understood that mother is not requesting that the pat.ernal grandparents have. this period of temporary physical custody with the minor child; however, mother will provide approval upon paternal grandparents' request. 5. The parties shall alternate the major holidays (Memorial Day, Independence Day/Labor Day, Thanksgiving, and Christmas), with t.he exact details to be worked out by the parties. 6. Mother shall have the minor child each year on ESster morning. 7. The Christmas holiday shall be divided into two Segments: Segment A shall. begin December 24 at 12:00 P.M. through December 25 at 12:00 P.M. Segment B shall begin December 25 at 12:00 P.M. through De('ernber 26 at 12:00 P.M. Father shall have Segment A in 1998 and in all subsequent even numbered years. I I ~