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: IN Till: ('Of 'j{ I or ('0:>' 1:>' ION I'I.LAS
or ('{ IMIlI:IU ,:\N/l ('( HINTY,
: PENNSYLVANIA
Plaintiff
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: 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
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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
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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
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TONYIA J. WOODS,
a/k/a TONYIA J. FAUS,
Plaintiff
IN TilE COUHT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYLVANIA
v.
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Defendant
CIVIL ACTION - LAW
CUSTODY
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SCOTT D. FAUS,
COMPLAINT FOR CUSTODY
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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
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The child was not born out of wedlock.
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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
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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
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6/1/95 - present
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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)(
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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
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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.
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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
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Tony~ '. Woods,
a/k/a Tonyia J. Faus
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Scott D. Faus
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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:
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Date:
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f/p:domestic\faus.stp