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Home My WebLink About98-06145 i :'\r I ~ l~ !~ c;r ~ I~ '"'f ~ ~ ~ c ~ ~ \~ ""- . .. .'::) ~ \n ':>.. ..... ~ , ~ ~ ~. J " TIFFANY M. WEAKLAND, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA \ v. (/5 No, 7, L, ILl S (II ('l,( , .. I \ " MARK M. WEAKLAND, Defendllnt CIVIL ACTION - LAW ;" IN CUSTODY 1, , j,'\' ;! ORDER You, MARK M, WEAKLAND, ar{ ORDERED to appear in person at ::Dd ,,\~I\"'I...\-"l\.I~) ~\\\\, VI\ IX' rc \-\\~\;(\r\ I f1:l'M~h,{-'4~' Pennsylva~na on - . " 1998, at II' o'clock ~,m,/p,m, for a Custody Conciliation Conference, -_/ 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, If you fail to appear as provided by this Order, an Order for custody may be entered against you or the Court may issue a warrant for your arrest, Dated: ..~ I; } ) ~: I J , I 1 I I Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013 (717) 249-3166 ~ . ~ TIFFANY M, WEAKLAND, Plaint if C IN ':'IlE COURT OF COMMON Pl,EAS CUMBERLAND COUNTY, PENNSYLVANIA vs, NO. 'i'l (..1'/', ' it ((' i /.... MARK M, WEAKLAND, Defendant CIVIL ACTION-LAW IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes TIFFANY M. WEAKLAND, by and through her attorney, Judith A, Calkin, Esquire, and avers as follows: 1, The Plaintiff is TIFFANY M, WEAKLAND, an adult individual who resides at 6009 Mockingbird Drive, Mechanicsburg, Cumberland County, Pennsylvania, 2, The Defendant is MARK M, WEAKLAND, an adult individual whose current address is 39 Westfield Drive, Mechanicsburg, Cumberland County, Pennsylvania, 3. Plaintiff seeks custody of the following minor child: Elani Weakland, born April 9, 1993 4. The child was born out of wedlock but subsequently the parents mdrried, The child currently resides with Plaintiff at 6009 Mockingbird Drive, Mechanicsburg, Cumberland County, Pennsylvania. 5, For the last five years the child has resided at the following addresses with the following persons: Birth to 1/1994 6009 Mockingbird Drive Mechanicsburg, PA 1/1994 to 3/1995 6009 Mockingbird Drive Mechanicsburg, PA Plaintiff & Defendant Plaintiff Plaintiff & Defendant Plaintiff 3/1995 to 10/1998 6009 Mockingbird Drive Mechanicsburg, Pa 10/4/98 to present 6009 Mechanicsburg Drive Mechanicsburg, PA 6, The mothel' of the chi ld 1fi 1'1,1 int i If. Tiffilny M, Weakland, 7, The filther of the chi 1<1 j(' Defendant, Mark M, " Weakland, 8, The mother currently resides with the minor child, 9, The father currently resides with his grandmother, 10, The Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth, 11. The Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child, or claims to have custody or visitation rights with respect to the child, 12. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the . I , child have been named as parties to this action, There are no other persons known to have or claim a right to custody or visitation of the child and therefore, no further notice of the pendency of this action and the right to intervene shall be given, other than to the I! I parties named herein, ~ 13, The beBt inte'-PBt <lnd permanent welfare of tile child will be served by aWilrding prim,"y c\wtody t.o Plaintiff with a schedule of partial custody fOl' the purpose of visitation with " defendant, Respectfully submitted: L ~l If , ?,/ll // (~//" Judith A, Calkin, Esquire Attorney for Plaintiff 2201 North Second Street Harrisburg, PA 17110 (717) 238-23121 ,. '" i " .' . 1\ I, CERTIFICATE OF SERVICE I' !, I , , ~, ~I; If, I, Judith A, Calkin, Esquire, do hereby certify that a true and correct copy of the Custody Complaint has been sent by , 1 i United States Mail, postage pre-paid. certified-restricted delivery Date: / .. I ,. / C/~ Calkin, ~~squire ~ to the following person: Mark Weakland 39 westfield Drive Mechanicsburg, PA 17055 / " .... ~"\ ; ! , I I , i . , :.i ~ ! . , , ,.'" f: " ~ V') j r : , ~'') \ /~ --.::. ," "\'"~ " , "- ''0- - '" v...... E ~ ....... "'..... '\) t' .-.) ,~ ,~ r'{ '" "'" " t:' , " u !K \i \ ~ ~' - ~ '0 .:J C:. , tll' ( " f' ' ( " .,' \ C' l.d l.'" I: LL U c... IX' (,: I- e C' co ()', ~ <: ..... ~~ o..rn i!5ffi ~o.. . f-< o . z ~~ !~ ..... ... ::i " 5: ~~ . co 0 ~-g ~u 0 u ~! 0.. ~~ >< , '" :;: 0 ~ :?; f-< p::", rn ,~~ . ::> <<- en :;: U .....u ~~ > ~ ..... H ~ 2 Z ~ g 1::: ....J :::J~ <: :ii= ~ u OIl> ~ "':J-l :::i ,<~i;;lob <: ~gii :l =~~~ ~ t-< 2 z~ ;: _ t:: .:: ~ Cl <=~ :J ~~ ~ = ~ i ~ , , i 8 . . i II -.- '" Z nH ~ H 0 ~: '" ." '" ." n .. "'''' :;: c: :;: :;! "" "'''' '- In ~ If &:n ~ '" 'n . =.:> C 0 :;: :;: '" ZO ~!> C '" '" ~ <::lC: ! ~-~ - In", .. - '" '" - ~ ,..J '" '" '" '" n'" ! .1 ~ /, , H.. :?&: ~~ 0 - .' ~ "'0 n ~;J ..,. "I:J.~_ ~~ "'Z ...' 1 ~ I \:1Si:J:> In <::l ~' ~ ~ ~n ~ . ...' ! ~ ~~~ 0 "'~ Co '" . H . 0 , 8~ ~ ...' <::l "7' I ~ <~!;:> ~ "'. .,,02 I to ~ ~ t'""" z'" '" '" "'0 ~ '" :j1z >~ is In'" :l Z "''''' t"'''' C ~~ Z H '" 4, The parents will share the holidays as follows: a, Father will have the minor child every year on December 24th from 2:00 p,m, until 9:00 p,m, Mother will have the minor child for the balance of December 24th and all of December 25th, b, Mother will have the minor child every year on Easter, Memorial Day, July 4th and Labor Day until 4:00 p,m, Father will have the minor child from 4:00 p,lO, until 9:00 p,m, on these days. c, For a portion of the child's birthday at times mutually agreed upon by the parties, d, Father will have the minor child every Thanksgiving 10:00 a.m, to 4:00 p,m, Mother will have the child for the balance of the day. 5, Father shall have custody of Father'S Day from 9:00 a,m, to 5:30 p,m, and Mother shall have custody on Mother's Day beginning at 9:00 a.m, 6. The holiday schedule shall take precedence over the regular custody schedule. 7. During any period of custody or visitation the parties to this order shall not possess or use any controlled substance, neither shall they consume alcoholic beverages, The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this prohibition. 8. Each parent shall be entitled to reasonable telephone contact with the child when she is in the custody of the other parent, 9, Both parf'nu; shall ref rain f rom making derogatory comments about the other parent in the presence of the child and to the extent possible shall prevent third parties from making such comments in the presence of the child, /{((( (/" /I , Witness (a ( ", '- ./'~ /:ti'f{a-;';y < M ~' we~kland dCI eLl ( II Witness 61/ ,r' (I /J! / '1;/1/ /''/ ~/,,.. ---/ Mark M, Weak' and COMMONWEALTH OF PENNSYLVANIA: {-~ I/"Ix,-{II; I COUNTY ss. ", On this, the; I ' day of /,1-:, , 1998, before me, a Notary Public, the undersigned officer, persOnally appeared TIFFANY M, WEAKLAND (or satisfactorily pt-oven to be) the person whose name is subscribed to the within instrument, and aCknowledged that she executed the sam!:' for the purpose therein contained, IN WITNESS WHEREOF, I hereunto set my hand and ,..(' . (SEAL) /'I.0CI'( N6tary p. My Commission expires: /'1.' 1'7 .7 ':"C/i r.i/.t~ " ~," Ii UUllf);'jl ','1',' ";J rJo:aryPubl,C 'V.Ir ~I)[:"~ r .'.,' I .,.t'!;Oltrtittld County .1./C(j....'i'Tl.~;.". ,'. r'Jr.OIlC.17,:mOI COMMONWEALTH OF PENNSYLVANIA: Lilt 11" (.)( r- kL n(! COUNTY On this, the Ii ii'day od" ,I. , 1998, before me, a Notary Public, the undersigned office~rsonally appeared MARK M. W~LAND(or satisfactorily proven to be) the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purpose therein contained, .....I"j".-'. . .....l\cllaC'AfIO" III ~/.lI,*'iAq ss. IN WITNESS WHEREOF, I hereunto set my hand and official seal, (SEAL) .~ /I II ,,( .~ /--1\ (j:; ,'>~ ' ,fl, I Notary PlibU.c ;'/ \ / ' I '\ ", '." My Commission expires: _()( (! I I ,:Jr<); fj,'!,J,'1,1150,11 c' uur'rll" t M.Jylll','d. Notary Public ~'tl('r SPflPq r '\P.. ClIrnberland Counl -; Comnll'iSklTl hp,ros Dec. 17. 200t Mm'"lbs,' Pfinn"YI' '. "~,l"lo1 Aasocl.,r:on 0' fJollJflttl / I, : I