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Home My WebLink About98-03494 i ~ 'It f '" :> ~ ~ let j~ i i i i I i I I i , i I , I I 1 , I 1 I I ! i I~ I~ I I I=-- . .. I .~ '<0 I , I~ i , I o..i ~{ lV\! I , , \ .: ~j ~l i ,j ~l j -[ \' r: ~ ; ;(' '\ ".' {" . .: 't,,:! It'l ,. F /, ' ,\: it! , I ~:) ,," :JJ ."'0 o -n I " -.., .;1..... . :Fl:~ . r:J :\(S ., -):}) . ~ ': ") ;.~ii'n ~~! ~{ 1 i el " :;: ro":", ;->-J '_",I ....~ I() ~ ?--'.l rf y., $ , ~ , " ~ '-. ~ I' (' ""1 "'- cl " c,. 0 i (> . , ~ r; ~ v '- d 12 r ~. .... r ,. " The parties had separated on several occasions for very brief periods of time in the Spring of 1998 and therefore there were brief periods of time that the child resided solely with the Defendant and not with the PlaintilT. The natural mother of the child is Carrie L. March, who resides as aforesaid. She is married to the Plaintiff. The natural father of the child has not been determined at this time, although PlaintilTbelieves based upon Defendant's statements, that he may be the natural father and therefore, he has requested that the Cumberland County Domestic Relations Office perform paternity testing to determine the child's true parentage. Plaintiff is married to the Defendant. 4. The relationship of the Plaintiff to the child has been described above. The Plaintiff currently resides with a male roommate. 5. The relationship of the Defendant to the child is that of natural mother. The Plaintiff currently resides with her Father, Mother, and two brothers. 6. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning custody of the child. 7. Plaintiff has no information of a custody proceeding concerning the child pending in any Court of this Commonwealth. 8. It is in the best interest and permanent welfare of the child to grant the relief requested because: a) The PlaintilT has been actively involved and been a shared caretaker attending to the physical and legal needs of the child since the child's birth; b) The Plaintiff has provided for the physical, material, social and morale needs of the child since the child's birlh; and c) The Plaintiff wishes to maintain a strong and close attachment to the child; 9. The Plaintiff believes and therefore avers that since he has been the only father figure in the child's life it is appropriate, pending the result of paternity testing, to provide the Plaintiff with extensive contact with the child. Respectfully submitted, WHEREFORE, Plaintiff requests your Honorable Court to enter an Order providing him with shared legal and physical custody of the child. GRIFFIE & ASSOCIATES -~') / B ,vGriffie, Esquire torney for Plaintiff 200 North Hanover Street Carlisle, P A 17013 (717) 243-555\ (800) 347-5552 :\: I: I Il. f' " .../t ,."'if ~:I )) f ,~\ ,I 10 I'". I 1-' , c> ,0 () ~.- . 'i) n , : - -11 I.: .. \ r:~ , - ;-.....'l , !n L. , '7 . , . I) .-'j ) -:, ; . (~) . '. ')i.l ., ,- - r:- :"U -c .1-- ..:. \j ..)". j't ,. -I i' 'It I )1 i I'. I i , '. . . , .' . . i,t" SEP R 1998,.~< STEPHEN RA Y MARCil. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ./ V CIVIL ACTION. LA W CARRIE LYNN MARCI I, Defendant NO. 98.3494 CIVIL IN CUSTODY CovIn ORDER *'" AND NOW, this I 0 day of September, 1998, upon consideration of the atIaehed Custody Conciliation Report. it is ordered and directed as follows: I. The mother Carrie Lynn March shall have legal and physical custody of Kiera Nicole March, born December 21, 1996. 2. The luthcr shall have temporal)' custody of the minor child on ahernating weekends as follows: A. On the first weekend, for periods of 4 hours each on Saturday and Sunday. I3. On the second alternating weekend, for a period of 6 hours each on both Saturday and Sunday. C. On the third alternating weekend and thereafter, for a period of 8 hours a day on both Saturday and Sunday. 3. Father's period of temporal)' physical custody with the minor child shall be subject 10 supervision by Father's mother or by some other person agreed to by the mother. Upon father completing a evaluation and that evaluation being furnished to counsel for the mother and the evaluation verit)ring that the father does not pose a risk to the child if the father has unsupervised custody, the requirement with respect to supervision of the Father shall be removed fTOm this Order. Mother shall have the option of petilioning the Court at that time if she is in disagreement with any recommendation made by a counselor. STEPHEN RA Y MARCil, I'laintirl. IN TilE COURT OF COMMON PLEAS or CUMBERLAND COUNTY. PENNSYLVANIA v CIVIL ACTION - LA W CARRIE LYNN MARCil, Dclcndant NO. 98-3494 CIVIL TERM IN CUSTODY CONCILIATION CONFERENCE SUMMARY REI'ORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent infol111ation pertaining to the child who is the subject of this litigation is as follows: Kiera Nicole March, born December 21, 1996 2. A Conciliation Conference was held on Seplcmber I, 1998, with the following individuals in attendance: The father, Stephen Ray March, with his counsel Bradley L. Griflie. Esquire; and the mother, Carrie Lynn March, with her counsel Thomas D. Gould, Esquire. 3. The parties reached an agreement in the f0l111 as attached. 9/ u/ yB DATE Hubert X. Gilroy, Esquire Custody Conciliator Petitioner believes it is necessary to withdraw as counsel for the Respondent in the abovc- captioned action. WHERErORE, Petitioncr requests your Honorable Court to issue a Rule upon Respondent, Stephen R. March, to show cause, if any he has, as to why Petitioner should not be permitted to withdraw as counsel for the Respondent. Respectfully submitted by, / . Ie, Esquire an over Street rlisle, PA 17013 (717) 243-555 I (800) 347-5552 (~ "., () ,",'.J -I" ~:J '~j _..1 "'I ~~:' ... ~ -) " 'T) ;-= '. ,-'J -,r"il (./1 p../ "IC::-J , , ; :.; (") .-;:, '1'. -n ...~ .-> () , C ....... , ,........, C.. ITl ~ ~-j => 1j .[7'" -< , '. el , .} \:"'j I I ~':] ;'"1 ,"} , :.,01 On , :- ..., ",(I ., ., '.'1 '. j,) r '.) ~< \ i I \ I ..1 i Petitioner believes it is necessary to withdraw as counsel for the Respondent in the above- captioned action. WHEREFORE, Petitioner requests your Honorable Court to issue a Rule upon Respondent, Stephen R. March, to show cause. if any he has, as to why Petitioner should not be pennitted to withdraw as counsel for the Respondent. Respectful!y submitted by, , Esquire over Street Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 ~ ,,' I ' , ~ !' ',,~ . . , f~-~' ~ " ~;\ ) , \\, . , l () <.D 0 '.~ \..(.) -n -'1 --1 -~-.' '-'1 -~i:n [1=, ;::~ GJ " :L' r- :::.: N --~rTI Co -;:! C;J Sf r'J '::J(:, ~~:.:- i :-: ::? -ri ~: , , ..l~ ~~~~ ?3 j~: ~~; N (3rTl :::.:..-( ~ (,;) ~j -< :1 " ~ STEPHEN RAY MARCI-I. Plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW CARRIE LYNN MARCH, Defendant :NO. 98.3494 CIVIL TERM : CUSTODYNISITATIONIDIVORCE PRAECIPE Please withdraw my appearance previously entered on behalf of the Plaintiff in the above captioned action. Respectfully submitted,