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IN THE: COUl\T OF COt"MON PLE:AS
CUMBE:RLAND COUNTY, PENNSYLVANIA
NO. 'If I. Jc'l (',pi -(~"'-
ANNE M. l\IEGLE,
Plaintiff
GREGORY M. CROSSWAIT,
Defendant
CIVIL ACTION - LAW
IN DIVOl\CE
COUNT I:
COMPLAINT UNDEl\ SECTION 3301(c)
OF THE DIVORCE CODE
1. Plaintiff is Anne M. Riegle, an adult individual
who is sui juris and resides at 7 N. East Street, Carlisle,
Cumberland County, Pennsylvania,
2.
Defendant is Gregory M, Crosswait,
an adult
indi vidual who is sui j uris and resides at 133 S, Wes t Street,
Carlisle, Cumberland County, Pennsylvania. The present whereabouts
of the Defendant, Gregory M. Crosswait, to the knowledge of the
Plaintiff, is the same.
3. Both Plaintiff and Defendant have been bona fide
residents in the Commonwealth of Pennsylvania for at least six (6)
months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on
November 27, 1985, in Lansing, Michigan.
5. Plaintiff avers that there are children of the
parties under the age of 18, namely, Zachary Riegle Crosswai t,
born October 4, 1996.
6. There have been no prior actions of divorce or for
annulment between the parties.
7. Plaintiff has been advised of the availability of
counseling and the riqht to requ(:st that the Court require the
parties to p~r::icip~lt:n in cOllnseling.
8, The Defendant is not a member of the Armed Services
of the United States or any of its Allies.
9. The Plaintiff avers that the grounds on which the
action is based is that the marriage is irretrievably broken,
COUNT II:
PETITION fOR CUSTODY
10, There was one child born of the marriage of
Plaintiff and Defendant, namely Zachary Riegle Crosswait, born
October 4, 1996.
11. The child is presently in the custody of the
Mother, who resides at 7 N, East Street, Carlisle, Pennsylvania.
12. During the past five years, the child has resided
with the following persons and at the following addresses:
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Anne M. Riegle
Gregory M. Crosswait
7 N. East Street
Carlisle, PA 17013
06-15-97 to present
Anne M. Riegle
Gregory M. Crosswait
5312 W. Foster Street
Chicago, IL 60630
10-04-96 to 06-15-97
13, Plaintiff has not participated as a party,
witness, or in any other capacity in any other litigation
concerning the custody of said child in this or any other court.
14, Plaintiff does not have any information of any
custody proceeding concerning said child pending in a court of
this or any other state.
15. Plaintiff knows of no person not a party to this
VEHI r'ICATION
1, AnIle N. Hie,])c, ackno',il.,dqr.' Lt,,,!. the facts stilted
in the within document are true ilIld correcl lo the best of my
knowledge, information ilnd belief.
I understand thilt ilny false statements herein are made
subj ect to the penalt ies of 18 Pa. C, S. Sect ion 4904 rela ting to
lk
unsworn falsification to authorities,
DATED:--.L1I~ J~)!
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HICl6 tl1 REV a.4IO
~"0If KNNSY\\NIIA
O[fWlTlollH1'Oif .v.Lflt
VITAL RECORDS
/
COUNTY
Cumberland
DIVORCE
~
RECORD OF
OR ANNULMENT
(CHECK ONE) 0
STATE ALE NUMBER
STATE FIle DATE
HUSBAND
1. NAMe
(FIrst)
f"flddltlJ
(llJSl) 2 DATE (Month} {Day} "",
bf 08 23 62
BIRTH
Stall . PlACE (St.,. 0( F<<elgn C4Unlty}
Of,. Illinois
DlRTH
1. USUAL OCCUPATION
133 S.
5. NUMBER
OfTlilS
MARRIAGE
West
M. Crosswait
Stroot Of R.O. City. Ooro. Ot ~ County
Street, Carlisle, Cumberland, PA
6. RACE
WHITE
:5!1
BLACK
Gre or
3. RESIDENCE
2
o
OTHER 15pocItyJ
o
WIFE
Engineer
City, Boto. Of '-P.
Riegle
Coo.",
(last) g, DATE
OF
BIRTH
St.,. n. pVoCe
OF
BIRTH
tol. USUAl OCCUPATION
(Mon/h)
02
(Day}
15
"'"
8. MAlDEN NAME
(FIrst}
Anne M.
SlfHlot'R.D.
(Midd1f1)
Rie le,
10. RESIDENCE
63
(51.,. Of Fotolgn Country)
12. NUMBER
Of THIS
MARRIAGE
6. RACE
WHITE
1 ~
BlACK
o
OTHERISpoc;ltyl
o
Attorney
15. PiACE OF (County)
nil'
MARRIAGE
17A. NUMBER OF
CHILDREN T~~S
MARRIAGE 1
178. NUMBER OF DEPENDENT
CHILDREN UNDER 18
1
(5111. Of Frxelgn Country,
Michi an
18. PLAlNTlFF
HUSBAND WIFE
o ,JX]
OTHER ISpoclfyl
o
16. DATE OF (MOflfll) (DIIY' ()o.~
THIS 11 27 85
w.RRIAGE
". DECREE GRANTED 10
HUSBAND WIFE OTHER (Spoclty)
0 fjg 0
20. NUMBER OF HUSBAND WIFE SPlIT CUSTODY OTHER(SpocllyJ
CHIl.DREN TO 0 @ 0
[ CUSlOOV OF
22. DATE OF DECREE (MOIlfh' (DIlY' (lilli"
". SIGNATURE DF
TRANSCRIBING CLERK
21. LEGAL GROUNDS FOR
DIVOf\CE OR ANNULMENT .
Marr~age ~s ~rretr~evably broken
DATE REPORT SENT (Moo/II)
TO VITAL RECORDS
(Day)
('rbar)
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JAN 12 1999,~
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ANNE M. RIEGLE,
Plainti ((
IN TilE COURT OF COMMON PLEAS OF
CUMDERLAND COUNTY, PENNSYLVANIA
VB.
NO. 98-6304
CIVIL
GREGORY M. CROSSWAIT,
Defendant
CUSTODY
ORDER OF CXXIRT
AND NOW, this 4th day of January, 1999, the Conciliator, being
advised by Plaintiff's counsel that all custody issues have been resolved
by agreement of the parties, hereby relinquishes jurisdiction in this case.
The CUstody Conciliation Conference scheduled for January 5, 1999 is
canceled.
FOR THE COURT,
/J. "- J .dt.'4\.~
Dawn S. sunday, Esquire
CUstody Conciliator
ANNE M. RIEGLE,
Plaint if f
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 6304 CIVIL, 1998
v,
GREGORY M. CROSSWAIT,
Defendant
CIVIL ACTION - LAW
CUSTODY
o R D E R
AND NOW, this
day of
19____, pursuant to the Stipulation executed by the parties, which
is attached hereto, it is hereby ordered and decreed as follows:
1. The parents shall share legal custody of the child
and each parent shall consult with the other concerning all major
decisions affecting the child, including but not limited to,
health, education and religion.
2, Primary physical custody of Zachary shall be with
Mother, Anne M. Riegle.
3. Father. Gregory M, Crosswait, shall have partial
physical custody of Zachary at times mutually agreed upon.
4, The parents will share custody of Zachary on
holidays as they mutually agreed.
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ANNE M. RIEGLE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
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NO, 6304 CIVIL, 1998
GREGORY M. CROSSWAIT,
Defendant
CIVIL ACTION - LAW
CUSTODY
STIPULATION
AND NOW, this JA+l" day of fA,< (' IV. bel '199l,
Anne M. Riegle, Plaintiff (hereinafter referred to as "Mother"),
together with her attorney, Sandra L. Meilton, and Gregory M.
Crosswait, Defendant (hereinafter referred to as "Father"), hereby
inform your Honorable Court that they have amicably resolved to
their mutual satisfaction the issues of custody and visitation
regarding their son, Zachary Riegle Crosswait, born October 4,
1996, and do hereby stipulate that the following is the substance
of their agreement respectfully requesting that your Honorable
Court issue an appropriate Order of custody and visitation in
accordance with their agreement and stipulation.
The parties stipulate as follows:
1. The parents shall share legal custody of the child
and each parent shall consult with the other concerning all major
decisions affecting the child, including but not limited to,
health, education and religion.
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TUCKER ARENSBERG & SWARTZ
'" NORTlI FRONT STRm,r
I~O. BOX 889
'lAU,kISHlI1Hi,I'I:NNSn.Vt\NIA J7H1,l.j.IJX~N
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ANNE M. RIEGLE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 6304 CIVIL, 1998
v.
GREGORY M. CROSSWAIT,
Defendant
CIVIL ACTION - LAW
CUSTODY
~
o R D E R
AND NOW, this
day of
19 ,pursuant to the Stipulation executed by the parties, which
is attached hereto, it is hereby ordered and decreed as follows:
1, The parents shall share legal custody of the child
and each parent shall consult with the other concerning all major
decisions affecting the child, including but not limited to,
health, education and religion.
j
2, Primary physical custody of Zachary shall be with
Mother, Anne M. Riegle.
3. Father, Gregory M, Crosswait, shall have partial
physical custody of Zachary at times mutually agreed upon.
4. The parents will share custody of Zachary on
holidays as they mutually agreed.
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TUCKER ARENSBERG & SWARTZ
III NORTH FRONT STREET
1'.0. BOX KK9
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ANNE M, RIEGLE,
Plaintiff
IN THE COUll'!' OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
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NO, 6304 CIVil" 1998
GREGORY M. CROSSWAIT,
Defendant
CIVIL ACTION - LAW
CUSTODY
o R D E R
AND NOW, this
day of
19____, pursuant to the Stipulation executed by the parties, which
is attached hereto, it is hereby ordered and decreed as follows:
1. The parents shall share legal custody of the child
and each parent shall consult with the other concerning all major
decisions affecting the child, inClUding but not limited to,
health, education and religion.
2, Primary physical custody of Zachary shall be with
Mother, Anne M, Riegle.
3, Father, Gregory M. Crosswait, shall have partial
physical custody of Zachary at times mutually agreed upon.
4. The parents will share custody of Zachary
hOlidays as they mutually agreed.
on
5, It i.s understood and sti.pulated by the parents
that, upon their mutual agreement, an expanded or altered schedule
may be agreed between the parents for and in the best interests of
Zachary,
BY THE COURT:
J.
11621.1
UE t..OPY FROM RECORD
TR _ 1 \ here unto Mt my 1\,."11(1
In T'ilmlrron~ Y1n~:.c '., ,., Carlisle. Pa.
d t"" 0.' " ,.,1 q.a (}....I at
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ANNE M, RIEGLE,
Plaintiff
IN TilE COURT OF COMMON PLEAS
CUMBERIJlND COUNTY, PENNSYIJVl\NIA
v,
NO. 6304 CIVIL, 1998
GREGORY M. CROSSWAIT,
Defendant
CIVIL ACTION - LAW
CUSTODY
'.'
STIPULATION
, .
AND NOW, this ;ZHl... day of DUll, i/(J1
19~~
Anne M. Riegle, Plaintiff (hereinafter referred to as "Mot!1~er"L
"
together with her attorney, Sandra L. Meilton, and Gregory M.
Crosswait, Defendant (hereinafter referred to as "Father"), hereby
inform your Honorable Court that they have amicably resolved to
their mutual satisfaction the issues of custody and visitation
regarding their son, Zachary Riegle Crosswait, born October 4,
1996, and do hereby stipulate that the following is the substance
of their agreement respectfully requesting that your Honorable
Court issue an appropriate Order of custody and visitation in
accordance with their agreement and stipulation.
The parties stipulate as follows:
1, The parents shall share legal custody of the child
and each parent shall consult with the other concerning all major
decisions affecting the child, including but not limited to,
health, education and religion.
....
.
TUCKER ARENSBERG & SWARTZ
III NClRTlIl'RONT STRE"f
P.O. BOX HK9
lIAHRISnlll{ti.I'ENSSY1.\,AN1J\ \7111l\OHKII
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ANNE M. RIEGLE.
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 6304 CIVIL, 1998
v.
GREGORY M. CROSSWAIT,
Defendant
CIVIL ACTION - LAW
CUSTODY
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o R D E R
AND NOW, this
day of
19 ,pursuant to the Stipulation executed by the parties, which
is attached hereto, it is hereby ordered and decreed as follows:
1. The parents shall share legal custody of the child
and each parent shall consult with the other concerning all major
.1
decisions affecting the child, including but not limited to,
health, education and religion.
2. Primary physical custody of Zachary shall be with
Mother, Anne M. Riegle.
3. Father, Gregory M. Crosswait, shall have partial
physical custody of Zachary at times mutually agreed upon.
4. The parents will share custody of Zachary on
holidays as they mutually agreed.
'",
2. Primary physical custody of Zachary shall be with
Mother, Anne M. Riegle.
3. Father. Gregory M. Crosswait, shall have partial
physical custody of Zachary at times mutually agreed upon.
4. The parents will share custody of Zachary on
holidays as they mutually agreed.
5. It is understood and stipulated by the parents
that, upon their mutual agreement, an expanded or altered schedule
may be agreed between the parents for and in the best interests of
Zachary.
IN WITNESS WHEREOF, the parties have hereunto set their
hands and seals.
Witness
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Anne M.
(SEAL)
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Riegle L
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(SEAL)
Witness
Grego
. Crosswait
ANNE M. RIEGLE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 6304 CIVIL, 1998
v.
GREGORY M. CROSSWAIT,
Defendant
CIVIL ACTION - LAW
CUSTODY
ORDER
AND NOW, this
J~ J
day of r~
19q~ , pursuant to the Stipulation executed by the parties, which
is attached hereto, it is hereby ordered and decreed as follows:
1. The parents shall share legal custody of the child
and each parent shall consult with the other concerning all major
decisions affecting the child, including but not limited to,
health, education and religion.
2. Primary physical custody of Zachary shall be with
Mother, Anne M. Riegle.
3. Father, Gregory M. Crosswait, shall have partial
physical custody of Zachary at times mutually agreed upon.
4. The parents will share custody of Zachary on
holidays as they mutually agreed.
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