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Home My WebLink About98-03334 ..." ,.., n:<.<:;F \. -' I.~ ,- ...-' ", ;-:.. 'r, 1\'( C-.... ..-;',. ~:".~, .,'Il. , C," 7.: SG on 11','1 I':! n: .. Ii ~.... ' ',~'" -:r.~:'~',i;, ~~'?, ,::", :"-,/ ~ ': .',~,.,';"r/'::,:;:t;:' "l~,,,;;\,.~'.\I~''';~:~''~''''-;.'':';;:''~'\':''~''',''^I,~'~"(J<~'~,~"~~-'I,',~..j::-'M-'..";- _'<', ,.:~..... :4,., ,"':\~, . ""'. ' '. --'--'-',","::::;'7;;;;';~:.;~,. - --"'~.'~~'" "'-~~~"'~.;t;;; , . ';\\1'( C,I',: 11\.: ,'.! :,0'; ..)I .,. q. "'.., '.'j: \\:>:: -.'~) ~ \. ,'I " ~;tl,tJ9 {W-~ /H~~ d/6 ~ If; Fl. ~ 7l#ZU ~/ -&3 cI~ (p.jlj./# ~ ~.4... flit. ~ ~ _ 0.<:";;:,:' '" , " . " : ". , ' '" , -- .. . -.. .~' ,,J \ " ~ ',' 10 >.', , t'.. "", -- "~(:< ,"' ~'~"~ , , ~.' "f . " . . l 'f..)~ it ~'" <; " '.. A" I lr~~~(. "'ii:' 'I:~.~r: ..\':....r!.' .~~ ,', ",.(1 ,. . . ." /. :1,,~, 1" ',' .- " 1:;"~'Ii",k...... '\9 . '" ." .: ~~:';;':":_."~~. , " '.:;.r~ ( '~ ,~.""'r ~\ j~ '.t'~ . 't~'.;~ 1 ~ .,~;;..~tf': , :.~ '-"t f'." "., 'j;?-'.', ~.~ ".' .......{.'(..'t. J., : ~J'.,"',' .. Ji'l' .' .. ~, " , \ ,..' j " "'. V-I"'. . j.'.' ':,\~'~" ........ ,- .,',: '~.~, ~"fl ~,,~. . ,,,,,,.11,' " i.." ~("!'j' : ,i';? hi is:.1\ ,f. :,>>, , '~"\"Kt'. ., . .'.-... .' ".' \.~ ""j~l . -' "',,~' v" oi ~'t 1:' ,":-' ....,,1. "1 'dl' . )~ ;; ''P'b''f;'"'' r.,.. ../. Jot' , ~ ," ;', ., "" l' "~ " :,0( , ~ I;' .'.;. . ...- , '. ~ .. . .. . , -' .' , " ,. ',./ ~ \; I. . t....... I J' 1 r..~ tj '/ ' i ;: I)' ;,0' it C:\ WPWIN60\ WPDOCS\DOtylESTIC\F AERBER\CUSTODY.CMP June II, 1998 . . "o>"_..<".~...-;-_,,;r''''''''''''''''''''_':tl'''''''..~,",,,"~~ '-.' r. f( , , 00 .0 DAWN M, FAERBER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. QS' 3331.0/ LAMONT B. WEBB, CIVIL ACTION. LAW IN CUSTODY Defendant COMPLAINT FOR CUSTODY I. The Plaintiff is Dawn M, Faerber, residing at 1708 Lincoln Drive, Camp HilI, Cumberland County, Pennsylvania, 17011. 2. The Defendant is Lamont B. Webb, residing at 1319 N. 15th Street, Harrisburg, Dauphin County, Pennsylvania, 17103. 3. Plaintiff seeks custody of Myles L, Webb, a minor child, born August 1, 1995, presently residing at 1708 Lincoln Street, Camp Hill, Cumberland County, Pennsylvania, 17011. 4, The child was born out of wedlock. 5. The child is presently in the custody of his mother, Dawn M. Faerber, who resides at 1708 Lincoln Drive, Camp Hill, Cumberland County, Pennsylvania, 17011. C:\ WPWIN60\ WPDO~S\DOMESTIC\F AERBER\CUSTODY.CMP Junc I 1,1998 15. Each parcnt whose parcntaI rights to thc child havc not bcen terminatcd and the person who has physical custody of the child have been named as parties to this action, All other persons, named below, who arc known to havc or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: NOT APPLICABLE Wherefore, Plaintiff requests the court to grant custody of the child to the Plaintiff, Dawn M. Faerber, the mother of the minor child. Date: G ;;l/7~ I . RUPP& glKLE (_ By II- ~ /4- Richard C. Rupp, Esquire Attorney 1.0.# 34832 355 North 21st Street, Suite 303 Camp Hill, P A 17011 (717) 761-3459 Attorneys for Plaintiff 4 ! -a. .3 .:1 .-'=l 0 % rfJ Cl -- r- 'f; ; .;j !-;: 1.0 (lS ~ :3~s; .:; s CiJ rfl uJ.:. l): ':: 0 gtj .,. --. -=;J. -:tl U-.,-' "'" , .". - l l0 u_-_. '. '-;,- ~ ~~jj '0 :.,\ ~) .::S Wl..I- ,~-. "':'~ ~ c:.J reV.j ::-ICil :c. -,' :.~~lL 1- -, :'j u. c:: a (;\ u + \:)::w\\ 10. f"~c.r\:::'e.\ Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, : PENNSYLVANIA v, + Lar<lC\'l \- IS, Webb Defendant : CIVIL ACTION LAW :'NO, 3~L.\ CIVIL,l9gg : CUSTODY VISIT A nON ORDER OF COURT And now, this G,\&\q~ ,upon consideration of the attached co~la.int, it!s here~ directed that the above parties and their respective counsel appear before \cho. e \ L, Chj\ , Esquire, the conciliator, at , . ,\~'\ . . C ' \ " Pennsylvania, on the \"?-- day of I , 1998, at q, (') () A,M.I ,M. \ for a Pre-hearing Custody Conference, At s conference, an effort will be made to resolve t Ie issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order, All children age five or older may be present at the conference. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent order, FOR THE COURT: By: Y~o~.::1 &mab'&~J' Custody Conciliator , Cn~.) YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO 9R TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE .. CARLISLE, PA 17013 T~UE COpy FROM RECORD (717) 249-3166 In Testnnony whe;eof, livre unto set my hand and the seal of said Court at Carlisle Pa 1-800-990-9 I 08 t) , . This .../.r.......... day oL/Z' - A 19;oJ('/' _ ~~"'I .;,..',l':.a """""'~~." """t:.." IA'/ eLL . ,.~~..~...... Prothonotary t ~' I (I I " ~ 0' ~ "", ;::: C-:I , UJB ,~ ' 0", 9".' ) ~;:: iI"." D_ -", Ll_ _'" .::;.: 9"" c. (') 0'.\/, or.:,: C'o' ..':l>< wL. ....f" -1t, , " lj"C, iI-,- :::::.: (UrL F ---) ::.~ tJ_, CO ::l 0 0"\ U '. ..... DA WN M, FAERBER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, vs. No, 3334 Civil 1998 LAMONT B, WEBB, Defendant. CIVIL ACTION - LAW IN CUSTODY CONSENT AGREEMENT FOR CUSTODY day of~JUl by and between Lamont B, Webb (hereinafter, "Father") of Dauphin County, Pennsylvania. This Agreement. made Ihis ~D1n , 1998, and Dawn M, Faerber (hereinafter, "Mother"), of Cumberland County, Pennsylvania. WHEREAS, the parties are the natuml parents of Myles L. We,bb, age 2, date of birth August I, 1995; WHEREAS, on or aboUl June 18, 1998, Mother filed a Complaint in Custody seeking custody of the minor child; WHEREAS, upon Father's request for visilation rights, and without waiving any righls that the parties may have in Ihe underlying cuslody action, the parties have now reached a temporary custody agreemenJ with regard to the minor child; NOW THEREFORE, intending to be legally bound, the parties hereto agree as follows: I, The parties shall have joint legal custody of the minor child, 2, Mother shall have primary physical custody of Ihe minor child, 3. Father shall have partial custody of the minor child as follows: ..'- <., -.."~.:"'..-:' - .,'."o~,~_,~'":;~:':.':;~;;';';:,;;-r;;ifP;;::;':";~.' '. , IN WITNESS WHEREOF, the panies have executed this Consent Agreement the day and year first above written. / ' 1;&/ / /1/1 ,~ /~;?:f7/~ /( Witness ~ ?f ~k) Witness ( WI( /iv), .;[01/(J02.-- &\ WN M. FAERBER -3- tJE (IN ~\1j)~ the child when the parcnts were together and she belicves that the schedule as it eurrcntly exists is the most appropriate for the child's well being, She was willing, however. to modify the Order in accordance with the Conciliator's suggestion which will be outlined bclow. Mother suggests that Father's motivation in trying to get primary physical custody at this point is primarily related to support, She suggests that the Father originally denied paternity and that after he learned that he would be required to pay for any tests that he then acknowledged paternity but that his sole focus has been how this custodial situation relates to support, 6. The Defendant's position on custody is as follows: Father wants to have primary physical custody of the child, He was insistent that the child be with him overnights, Father suggested that he is better able to take care of the child because he asserts that Mother has not been taking care of the child ovemight but rather the grandmother has been taking care of the , child and the mother has been spending time with her boyfriend instead, 7. Need for separate counsel to represent child(ren): Neither party requested, 8, Need for independent psychological evaluation or counseling: None requested and the Conciliator does not believe any is necessary, 9, A hearing in this matter will take one,half day, 10, Other matters or comments: We are dealing with a three year old child, The parties resided together until March, Apparently the Mother was home for a period of time taking care of the child full time, Now both parties are working outside the home, Mother intends to be married in November and this appears to be an issue as far as Father is concerned. The Conciliator tried to work out an appropriate arrangement with the parties based upon their work schedules, Apparcntly Mother is working 8;30 a,m. to 4:30 p,m, at a local bank. The child is in day care during this period of time. Fathcr works for Federal Exprcss and reported at the conciliation that his schedule is going to change so that he is going to be working 7:00 a,m, until 12;00 p.m, Thc Conciliator suggested that the Father be given additional time with the child when the Mothcr is at work and when he is availablc such that he would return the child to Mother when shc gets home from work, In other words, the existing schedule under the Order would remain in effcct but Father would bc given extended times from when he got off from work until when Mother gets offfrom work, Mother was willing to work on this type of arrangement but Father was adamant that the child be at his house primarily, Father would not articulate a specific schedule for Mother other than to say that he would agree to "liberal" visitation, Based upon their proposed work schedules, this is clearly a case that should be resolved since the child is currently not in school and there is an ability for both parents to have time with the child during each work day that will not conflict with each other. Currently, Father has every other weekend at his house and one evening during the week overnight. Assuming the child is otherwise doing well in this arrangement, the Father will have to show the court why a switch to having the child at his house every evening except for alternating weekends with Mother and some other times that he proposes is in the best interest of the child. For some reason, the Father is more interested in where the child sleeps than making sure that both parents have thc child for extended periods while he is awake, ". .. . DAWN M. FAERBER, IN TilE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, vs. No, 98.3334 CIVIL TERM LAMONT B, WEBB, Dcfcndan!. CIVIL ACTION - LAW IN CUSTODY ORDER AI'!'ROVING CONSEI'!T AGRE,MENT AND NOW, this _I '" dnyof \ ,fCAv1...... .1998, upon \ consideration of thc Conscnt Agrccmcnt attachcd hcrcto, thc following ORDER is hereby ENTERED: 1, The Conscnt Agrccmcntas cxccutcd by the parties awarding primary physical custody of Myles L. Wcbb, datc of birth August I, 1995, to Lamont B, Webb, is hereby Approved, 2, The Consent Agrecmcnt as cxccutcd by the parties is hereby incorporated into this Order, 3, The partics arc hcrcby dircctcd to comply with the terms and conditions of the Consent Agreement. DY TII~ COUll / "":./C ~A/~ I I ( . J. , .I