HomeMy WebLinkAbout98-03417
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ANGELA MARl MILLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
RODNEY A. MILLER,
Defendant
No. 98-3417 Civil Term
CERTIFICATE OF SERVICE
I, CONSTANCE p, BRUNT, ESQUIRE, do hereby certify that:
1. On June 19, 1998, a Complaint For Custody, properly
endorsed with a Notice to Defend and Claim Rights, was filed on
behalf of Plaintiff and against Defendant in the above matter.
2. On June 19, 1998, I forwarded, by certified mail,
return receipt requested, restricted delivery, a copy of the
Complaint For Custody to Defendant Rodney A. Miller, addressed to
312 Blacklatch Lane, Camp Hill, PA 17011, as evidenced by the
sender's receipt attached hereto,
3. The aforesaid copy of the Complaint For Custody sent to
the Defendant, RODNEY A. MILLER, was delivered on June 23, 1998,
as evidenced by the return receipt card signed by the Defendant
and attached hereto,
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To the best of my information and belief, the signature
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on Part 5 of the return receipt card is, in fact, the signature
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of the Defendant, RODNEY A, MILLER.
DATE:
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CONSTANCE P. BRUNT, ESQUIRE
WHEREFORE, Plaintiff requests the entry of an Order of Court
granting her primary legal and physical custody of the subject
minor children.
DATED: !d(ll(ff
Respectfully submitted,
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CONSTANCE P. BRUNT, ESQUIRE
Supreme Court I.D. #29933
2941 North Front Street
Harrisburg, PA 17110
(717) 232-7200
Attorney for Plaintiff
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(b,) Plaintiff, ANGELA MARl MILLER, shall have primary
physical custody of the subject minor children.
(c.) Defendant, RODNEY A. MILLER, shall have partial
physical custody of the subject minor children as
follows:
(1.) Each Sunday from 8:00 a,m, through Tuesday at
8:00 p,m.
(2.) At such other times as the parties shall from
time to time mutually agree.
(d,) The parties shall alternate the holidays of New
Year's Day, Easter, Memorial Day, 4th of July, Labor
Day, and Thanksgiving, with Defendant having New
Year's Day, Memorial Day and Labor Day in 1998 and
all subsequent even-numbered years and Easter, 4th
of July and Thanksgiving in 1999 and all subsequent
odd-numbered years. The holiday custody period
shall be from 9:00 a.m. through 8:00 p.m, on the
holiday itself, except that any holiday falling on a
weekend or on a Friday or Monday adjacent to a
weekend shall include the entire holiday weekend.
(e,) The Christmas holiday shall be divided into 2
segments as follows:
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(i.) Unless othcrwifJc ugt'eed by the purtics, the party
who is obtuining clIfJtody of the children at any
specific time shall be responsible for picking the
children up ut the other parent's home or other
mutually-agreeable location,
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(j.) The schedule of custody set forth herein shall not
entitle Defendant to any adjustment in his support
obligation pursuant to the guidelines set forth in
the Rules of Civil Procedure, This provision shall
not prevent the Defendant from asserting entitlement
to an adjustment in his regular guideline support
obligation in the event that the proposed Order of
Court for custody is subsequently modified.
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ANGELA MARl MILLER
Plaintiff
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CONSTANCE P. BRUNT, ESQUIRE
Attorney For Plaintiff
HOWETT, KISSINGER & MILES, P,C,
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RODNEy(jA, MILLER
Defendant
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DONALD T. KISSING R, ESQUIRE
Attorney For Defendant
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