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Home My WebLink About98-06625 N :- ~ ~ ~ L1 "" ~ ~i '" 3\.. .U '-, .... " < ' ,11\ ~ , ~ ~ - ' .... I .:) i ~ ' '-.Ji I V, I") '-9 ~! , ! . ! c..,: ~!! ! ~I I LINDSAY DARE BAIRD ' , ATI'ORNEY AT LAw 3180IITlIIlANOVRR STlIRJIT CARUHI.E, PENN'YLVANIA 11013.3301 (1111 :U3.5132 FAX (111) 243.8110 , : ,.-.- "';'~';f f ' .'N<iv 2'.~~'~':, . " "':.1- . . ..~ ~'~"'''''''$~~"t " .: A <IIi' . (~,.". ", ~ ~H ".' '. ',~>S~';" . ,',".,tf~,,~::t:~1 JENNIFER WISNIEWSI(I, l'laintiff IN TIlE COURT OF COMMON I'LEAS OF C:UMUERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION. LAW JAMES A. SALSUURY, II, Defendant No. 98 . (.,t,,;)) CUSTODY CIVIL TERM OJtJlEIt AND NOTICE AND NOW, \-J:).J ~:5 \ 1998, upon consideration of the auached complaint, it is hereby d!rected that the parties and their respective counsel appenr before I' - (" '" , the conciliator, . Q at I"'~ l on the de::> day of ,199'1, at Lf, )C'l ~. m., for a Pre. Hearing Custody Conference. At such conference, an effort will be nlude to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By:-Yl,~~'\.k 'f..~~ Custody Conciliator ('\i)~ The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must auend the scheduled conference or hearing. YOU SHOULD TAI<E 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249.3166 cc: James A. Salsbury, II Lindsay D. Baird Conciliator JENNIFEIl WISNIEWSI<I, l'laintiff IN TIlE COUIlT 01; COMMON PLEAS ()J' CUMJlEIUANIl COUNTY, I'ENNSVLVANIA v. CIVil. ACTION. LAW JAMES A, SALsnUIlV, II, I>cfl'ndant No,9!1. CIVIL TEIlM CUSTOI>V COMPLAINT Fon CUSTODY I, The plaintiff is Jennifer Wisniewski, residing at 21 East South Street, Carlisle, Cumberland County, I'ennsylvania. 2. The defendant is James A. Salsbury, II, residing at 3 Woodland Drive, Newville, Cumberland County, Pennsylvania. 3. The plaintiff seeks primary physieal eustody of the following child: Name Present Residence Bryttani E. Wisniewski 21 East South Street, Carlisle, PA 17013 Age I yellr 8 mo. The child is presently in the custody of the plaintiff. During the past 1 year 8 months, the child has residcd with the following person and at the following address: Person Mother Address 21 East South Street, Carlisle, PA 17013 Dates I 997.Present The mother of the child is plaintiff Jennifer Wisniewski, residing at 21 East South Street, Carlisle, Cumberland County, Pennsylvania 17013. She is single. The father of the child is defendant James A. Salsbury, 11, residing at 3 Woodland Drive, Newville, Cumberland County. Pennsylvania 17241. He is single. 4. The plaintifFs household includes: Name Craig E. Wisniewski Ruth F. Wisniewski Craig E. Wisniewsld, Jr. Christopher Wisniewski Cameron Wisniewsld Jennifer Wisniewsld Bryttani E. Wisniewski Relationship Maternal Grandfather Maternal Grandmother Maternal Uncle Maternal Uncle Maternal Uncle Mother Subject child S. TIll' d,'fl'ndanl, "lilies A. Snlshury. /I's household includ,'s: Nilml: ndntionshiv 'ames A, Snlsbllry, Sr. Paternal Grandfnth,'r Barbnra Salsbury I'nternal Grandmother Joy Salsbury Paternal Aunt James A, Salsbury. /I Father 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the cllstody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 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 visitntion righlS with respect to the child. 7, The best interest and permanent we/fare of the child will be served by granting the relief requesled because: a) Plaintiff can provide the child with a home with adequate moral, emotional and physical surroundings as required to meet the ehild's needs; b) Piaintiff is willing to accept custody of the child; c) Plaintiff continues to exerdse parental duties and enjoy the love and affection of the child. 8. Each parent whose parental rights to the child have not been terminated has been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim NONE Wherefore, plaintiff requests the court to grant her primary physical custody of the child. Date: 11'1'1. 9 Y I verify that to best of my knowledge and belief, the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.~4904 relating to unsworn falsification to authorities. \ ~ ( (~ , 'ennifer Wisniewski, Plaintiff f~ JENNIFER WISNIEWSI(I, l'lulllliff IN TilE COURT OF COMMON PLEAS OF CUMIlElUANJ> COUNTY, l'ENNSYlVANIA v. c.lVIL ACTION. LAW JAMES A. SALSIIURY, 1/, J>cfemlalll Nu. 9H . (,(,2S CIVIL TERM C:USTOJ>Y STIPULATION FOR CUSTOJ>Y STIPULATION made Ihis ~ ,~t, duyof "- Wisniewski, hereinafter referred to as Mother, 1111 referred to as Father. WHEREAS above named Mother IInd Father had born to them the following child on the following date: , I 9911 between Jennifer Isbury, II, hereinafter NAME Bryttanl E. Wisniewski IIIRTHOATE March 20, 1997 AND WHEREAS the above.named parents desire to enter into u Stipullltion as to the custody and visitation of the above. named ehild. NOW THEREFORE, in order to effeetuate the above purpose, the parties hereby stipulate that: 1. The parents shall share legal custody of the child. 2. The Mother shall have primary physleal custody of the child. 3. The Father shall enjoy visitation every other weekend from between 6:00 and 6:30 p.m, Friday through Sunday between I :00 and 4:30p.m.. 4. Any other visitation and the schedule for the holidays shall be by agreement of the parties with at least 48 hours notiee. TO THIS PURPOSE, the parties hereto, having been advised of their right to legal counsel, Intend to be bound by the terms of this Stipulation and desire to have the Stipulation entered as an Order of Court. <-(.,\ dsay Dare Baird, Esquire \~ (' ,-^,)-- . /e";nifer isnlewsl<1 gm ('0 A xSttif!7 JjL . James A. Salsbury, II . J t. (I' f I n , ') (") ....) , , -. '7) ," - ,) i-11 " ? \ () - -" , , 'n ~') -rn .. j _.,1 , ." :,j ., , I;) -, I ~.!, ',I j , ,tP .IENNIFER WISNIEWSKI. Plainlill' IN TilE ('OlIRT OF (,()M~f( 1:-.1 PLEAS OF ClJt\IBERI.ANIl (,OlINTY, PI'NNSYI.V ANIA v CIVIL A('lION . 1.,\ \\' .lAMES A. SAI.ISIlURY.II, Ikfcndant NO. 'IX . 6625 CIVIL IN CUSTODY COllRT OIU>ER AND NOW. this (r day or P- J..r . 191)1). the Conciliator bcing advised that the panics have reached an agreement, the Conciliator relinquishes jurisdiction. BY TilE COURT. , 15/-i? tl~ Huber! X. Gilroy. Es c Custody Conciliat " . LINllIlAY DARE BAIRD ATI'OIIHEY AT LAw 37 80Iml HANoVER llTlI8kT CAllLI8LE,l'EHNBYLVAHIA 17013-3307 (717) 243-ll732 FAX ('117) 2.3.8110 JENNIFER WISNIEWSI(I, Pllllnurf IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW JAMES A. SAlISBURY, H, Defendllnt No. 98. 6625 CIVIL TERM CUSTODY ORDER OF COURt AND NOW, 9/;)9 1999, upon considerntion of the IIttached petltlon, It !s hereby directed thllt t~e J!lIrties IInd their respective coun~el ~Pfear " before tp.v-J'"",.s. ~D'itA \ ~<:.,'-\ . , the concililltor, at _...9...., ~ \ (\ ~\- . ~~ \ ~ _ on the \0 dllyof '-JOJL""tt\'1999, lit q'.\J,,"i ~ m" for a Pre-Hcltring Custody Conference. At such conference, IIn effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference, Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By:_~cw.."f\.. ~"' ~~ "-I D-l. Custody Conciliator " , - (j l.J-\ l . The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabied individuals having business before the court, please contact our office, All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. 1 r<; ". .., ".., i,> YOU SHOUtD TAI<E 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 cc: Lindsay Dare Baird, Esquire James A. Salisbury, II Conciliator " ~( c.,.", . , !I'~c.' Y'~. (}(/ ~ /?It;g:d 7i. ",.if .-'.:kkt/ (- 3c ~~ Y/~l'tce /f-,;',g,,,, ~ /-4'//, 7".3c>~f /l ..' ,J ~/ -" . j l~ /M...(/y 7f. /I?j ~(.(7J " :'''. #~q... I' I'""p ;\',!"", :o~~r/;;o:;:, '.' "" "",,:':,' ~ ~'r.:;. ~ l~'.~~; ":~'''';~(''I/ }-fI ~.r.. .J.f "~$,;~,~/~~::~~Ih<:~'~ ,,';~ .:;.' ::'.".:': '. ::/~.~. :':. ,.~,'..' ..':':;;":::)Yf!.~~;~t,~;~~1jt~~~~~tFiF' ~w"'''''...:.....:..':., .....:....,.. ""." ....^<..;..,'w:,...j",",..; l~ -c,.,.";",.)..".\.I':;I..., h; .,,;.: < ....... "'; ...." '. "";'..,., ;~"":'<''''!:;:''''h':', '" ,... 'v~,,,,.,,.,. . '..'...."n..,., '., ..... '. .' """"""".,(''''''1',".,.,,,,. .. e' !:!",l'+';;;'::"':''':'',''';:l,i ?,:.../.':.'::'>~~>.-:.;, ...'.;'\.:",'::.J.;;:.!:i~i".;i'.;i;&;.~~ '. . ". ,!.:.'Ilf"""-:';o).>,', .....hll " .:' :,i"",!,,"J .,~ ....... . <:' ';,." ,- ,'. ~_,~,>~ ",,: , "1 If . '. f...-V r:.V<.o;"if:t"-"~"'~:"ll' '1'" ;~"~"f:"~~"".", """".I,.._..c.~, '~. ~'. ,,~. ...-ld\.'c.?......#."7~r<'..;<')f.'r fjv;r..;'>,:'''!'~~~i{!.~!~;~}~:~..~''..~..3~:rf....:l,'~.>. ~".~;~~::,: , ::'-' :;,__'~ -.--" ':;, : .~' I:: > ,'~ ,~(-;;."o/. ~.i:j;~-F.~ :4..,.'.... S ~.. .... t;'.:',"t~~ 'fi,'j.!I,~,...,\".r.J,''''...~,.::,...:: '~, ';.~ "... < 1'.. 'l " ~ ,. < .. ,_ ;i..A11f~~l;i:'f~.tt;'t"'.1 >;;-".' ::\~... ..oJ". .. , , . . ... .~ 'ENNIFER WISNIEWSI<I, l'lalntlff IN TIlE (;()URT OF COMMON I'LEAS OF CUMIIEItLANI> COUNTY, I'ENNSYLVANIA v. CIVIL ACTION. LAW 'AMES A. SALISIIUItY, II, Defendant No. 9H. 6625 CIVIL TEItM CUSTODY PETITION TO AMENI> CUSTODY STII'ULATION AND NOW, I'etitioner, 'ennifer Wisniewski, by nnd through her nltorney, Lindsny Dare lIaird, Esquire, nvers the following fncts: J. Petitioner resides at21 EIIst South Street, Carlisle, 1'/\ J7013 and is the nntural mother of Bryttani E, Wisniewski, born Mareh 20, 1997. 2. Respondent, 'ames A. Salisbury, II, until recently resided with his parents at 3 Woodland Drive, Newville, PA 17241, and is the natural father of Bryttani E. Wisniewski. 3. A Stipulation For Custody was entered as an Order of Court by the Honorabie Edward E. Guido on 'anuary 28, 1999 and is attached and marked as Exhibit "A". 4. Respondent is no longer living with his parents at the above address, nor has he provided Petitioner with an address with appropriate accommodations for weekend periods of partial custody for Bryttan!. 5. Petitioner respectfully requests that the Stipulation be amended to provide that Respondent's periods of partial custody take place at his parents' home until he obtains an appropriate place of permanent residence. 6. Petitioner does not sed< to keep the child from Respondent. WHEREFORE, Petitioner respectfully requests that the Stipulation For Custody be amended to reflect that Respondent's periods of partial custody tal<e place at the home of the paternal grandparents until an appropriate residence is established by Respondent. lteSpeCtf~"y ~ed, I ~~~~ckfs:\ ;~:ndsay Dar~Ba~rd, Esquire Attorney for Petitioner 37 South Hanover Street Carlisle, PA 17013 (717) 243.5732 (') '() (") c.~ '''' .;1 ;- U) ,., "1'J.-, ,.." 'j" ni,; "u ,: ;n %.'. N .",rT1 ;;:-:1 'ir-) (n,".- ')(1) -, :.::~: -.... ,1,;, ~c~ :.i: )7""] '''C) '''0 '2 {:;in J-o.f;; '1 ~- ;:; ::< '-V -<; "., \ . . ",.~ '\ JENNIFER WISNIEWSKI, : IN TilE COURT OF COMMON PLEAS OF Plaintit f : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : CIVIL ACTION - LAW : NO. 98-6625 : JAMES A. SALISBURY, II, : Defendant : IN CUSTODY OODER OF CXXlRT AND OCW, this 10th day of November, 1999, the Conciliator relinquishes jurisdiction in this case based on the fact that neither the parties nor counsel appeared or contacted the Conciliator for the CUstody Conciliation Conference scheduled for November 10, 1999. The Conciliator was subsequently advised by Plaintiff's counsel that all issues had been resolved by agreement of the parties. FOR THE COURT, Da~~i~ Custody Conciliator