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HomeMy WebLinkAbout98-06059 ~ ':S !11 ~ 11\ """ ~~ -3, .. ~ ~ :- 5 iC) a-- '<) <::) " ~ ~ 'j~,.,'; ~- ':':~";"n>,:{;~~i; .; '-"'IJ-,' ~:Jt~b;~"\I'<Jl;:';;i'J ~!,_ -,I: ~,(:(:(~ " ,.""""..",e,...,,""""h~..,t'1, .':' ~'.\'~7;: V:';:'~';?:: ,:.{~1<~: ",., {,'~~'~~~i'l~i/ ....'>,'.i'. - -.... ....,-'_:'::~::..;,.'"j . -- .~.; '~ I .,"',.,..~\ ....~.~.~ "f2,,"~ ~ '.:~'.,'",.V) , ~~ '.', ".':!' ,-.' , , :;"-,::",1,":t,;.4";. '_,'.,1,',-'. _. ' 1'....';0. \' C. .<:,!,~~ ','.. , ,.', :"'''I',''I~~ ;3:S~::~ ""'''",;'''''''H:'ft1~ "':'~":\"{W,,-'tJi>.t-, ' :c-!~,..~.. }~~', : >~;j,)~~'~:";l...,~i;'l'~, ..,~ "." f\ '~ ,"" 1 ~ ~ ~ ~ ~ ," .'~", :'1 " '\Z-(\'j,C\ \ v-.):'d\ : IN Till: ('Of 'j{ I or ('0:>' 1:>' ION I'I.LAS or ('{ IMIlI:IU ,:\N/l ('( HINTY, : PENNSYLVANIA Plaintiff \' . '..I i.\ \ \) \ ('\' J ) : CIVil, i\( 'THIN I,A W Ikli:ndanl : NO, , " \ ('IVII. 1') (.', : ClISTO/lY VISITATION ORDER OF ('OlJRT And now, this ,f )1,)''''1'1'), upon consi,dl'ration of till' altach~d cOl1lplai,nt, it i,s hl'rl'by dirl'l'~ed that the abovc partlcs and thw rcspl'ctlVl' Cot1~lS~1 appear b,l'Iorl' ,\\1\ \ ( ,r' \ I ,h 1'\',) ) E 'I 'I' '- ' I'> \, \ ( \ ~sqUlrc, t lC conel lator, at . .~ ,A . '). ," ,') \ " ,l I (If' 1 ~\ \ , Pennsylvania, on the =~ day of \'),'\ r rn\,(- r ',1998, at ,C; '",', ~.I p,M" for a Pre-hearing Custody Conferencc, At such conferl'ncl', anl'fforl will bl' mad I.' to resolve the issues in dispute; or if this cannot be accomplished, to dclinc and narrow the issucs to be heard by the court, and to enter into a temporary order, All children age live or older may be present at the conference, Failure to appear at the conference may provide grounds for the entry of a temporary or pemlanent order, FOR THE COURT: By:j11 II',) n.~, ,~) , ,oj Custody Conciliator l' ," . 'iL i\L'V., , ~ ') - \. \:\>:) YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLlSLE,pA 17013 (717) 249-3166 1-800-990-9108 ,......,. r ! I '., " 'J )r)r}(/ i!yy /,'}'~ ;;/;{ j1f:~(/,.7'/f<""Jt /t f). ';'( '/ /i0.'" /.' ; ;,t1;/ .{: 'Jf:Lf 7)1 ~:17</.' ~./,.(: I /{' J..... - (.. / '5;f 1 -; ( (~Iy /Ijli'</~ ......}I YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF THE OFFICE SET FORTH BELOW TO FINO OUT WHERE YOU CAN GET LEGAL YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue CarliSle, PA 17013 (717) 249-3166 BY THE COURT: Date: Custody Conference Officer ;f I"~ I, I: TONYIA J. WOODS, a/k/a TONYIA J. FAUS, Plaintiff IN TilE COUHT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA v. NO. '1-,' (',0:, 'I I. ' Co,:) ~-' ,,' t..--' Defendant CIVIL ACTION - LAW CUSTODY t f, SCOTT D. FAUS, COMPLAINT FOR CUSTODY : I . f\ ! i 1. The Plaintiff is Tonyia J. Woods, a/k/a Tonyia J. Faus, residing at 20 Hillcrest Road, Enola, Cumberland county, NAME PRESENT RESIDENCE AGE Pennsylvania 17025. 2. The Defendant is Scott D, Faus, residing at 202 Runson Rd., Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff seeks custody of the following child: Ashley L. Faus 20 Hillcrest Rd. Enola, PA 17025 11 ~ I' I; .- i' The child was not born out of wedlock. "f The child is presently in the custody of Tonyia J. Woods, a/k/a Tonyia J. Faus, who resides at 20 Hillcrest Rd., Enola, Pennsylvania 17025. During the past five (5) years, the child has resided with the following persons and at the following addresses: NAME RESIDENCE DATE ! f', ill ~ ) Tonyia J. Woods, a/k/a Tonyia J. Faus 189 Ashford Dr. Enola, PA 17025 prior to 6/1/95 Tonyia J. Woods, a/k/a Tonyia J. Faus, and Daniel E. Gilham 20 Hillcrest Rd. Enola, PA 17025 , , ~. 6/1/95 - present , I, ~, I The mother of the child is Tonyia J. Woods, ajkfa Tonyia J. Faus, currently residing at 20 Hillcrest Rd., Enola, Pennsylvania 17025. She is unmarried. The father of the child is Scott D. Faus, currently residing at 202 Runson Rd., Camp Hill, pennsylvania 17011. He is unmarried. 4. The relationship of the Plaintiff to the child is that of Mother. The Plaintiff currently resides with the following persons: NAME RELATIONSHIP Ashley L. Faus Daughter Daniel E. Gilham Friend 5. The relationship of the Defendant to the child is that of Father. The Defendant currently resides alone. 6. 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 another court. Plaintiff has no information of a custody proceeding concerning the child pending in another court of this Commonwealth. Plaintiff does not know of a person not a party to the proceeding who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent wellare 01 the child will be served by granting the relief requested because the parties are in need of a determination as to primary physical custody, and also a court ordered schedule of visitation. 8. Each parent whose parental rights to the child have not been terminated, and the person who has physical custody of Date (Y-r~,-_d( , I CJC)( / ND I the child, has been named a party to this action. There are no other parties who are known to have or claim a right to custody or visitation of the child. WHEREFORE, Plaintiff requests the Court to grant her custody of the minor child, Ashley L. Faus, Respectfully submitted, / Rich rd . Friedman, Esq. 600 econd street Pe house Su i te P. . 80x 984 Harrisburg PA 17108 (717) 236-8000 .~ f/p:domestic\faus.cus , \ ~ : , ~ ': ~ ~, \, ; :." TONYIA J. WOODS, a/k/a TONYIA J. FAUS, Plaintiet III TilE Couln OF COMMON PLEAS ClllolllEH!.ArlD COUNTY. PENNSYLVAN IA v. NO. 6059 CIVIL 1998 SCOTT D. FAUS, CIVIL ACTION - LAW CUSTODY Defendant ORDER AND NOvl, this ~ day or 1)... Cc. -4 U ,1998, it is hereby ORDERED, ADJUDGED and DECREED that the Plaintiff is awarded primary physical custody of Ashley Lynn Faus, with Defendant having temporary physical custody for purposes of visitation as indicated in the attached Stipulation. BY THE COURT: dLi!8-1/ J. , , B. Two weeks during the child's summer vacation, said weeks to be taken either consecutively or in two one week periods. Father Ghall give 30 ddYS written notice to Mother of said periods of visitation. C. Easter Sunday may be spent with whichever parent would ordinarily have custody of the child on that weekend. D. The parties will share Thanksgiving day and will mutually agree upon reasonable times to be afforded the opportunity to share the holiday with his or her respective families. E. Mother shall have custody on Christmas Eve until 11:00 a.m. Christmas Day, at which time Father shall have custody for the remainder of Christmas Day. F. Father shall always have custody on Father's Day, from 9:00 a.m. until 8:00 p.m. regardless of which parent has custody of the child that weekend. Likewise, Mother shall always have custody of the child on Mother's Day during the same hours. G. Father shall always have custody of the child on Father's birthday from 9:00 a.m. or from the time the child is released from school, whichever shall later occur, until 8:00 p.m., and Mother shall always have custody of the child on Mother's birthday. n. The p~rties will nh~re custody o[ the child on her birthday, February 10. In the event her birthduy is on a weekend, Father shall have the right to visit the child from 2:00 p.m. until 6:00 p.m. In the event the child's birthday is on a weekday, Father will have the right to visit with the child from ! ). , " \::hl{' ,\ \ "YH\-I -, Tony~ '. Woods, a/k/a Tonyia J. Faus -'. 'I' Ir '-\" ) ("...... '._,) Scott D. Faus I .' . r U,l/J...--- 6:00 p.m. until 7:30 p.m. I. In the event of a conflict between the scheduled weekend period of custody and any scheduled holiday, holidays shall be deemed to override weekends. J. Father shall be responsible for all transportation of the child (i.e. picking the child up at the commencement of his visitation, and returning the child to her home at the termination of his visitation). 2. The parties have agreed to terms for custody and visitation of the child, which terms are incorporated in this stipulation by reference. 3. The parties do request this Honorable Court to issue the attached Order. Date: \ ~;. J\ C\~\ Date: } i I . " ,!I', .)! I I f/p:domestic\faus.stp