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ROSELINE S. GASKINS,
Plaintiff
vs.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
~ No. :1000 -59&3 v~il
KEITH A. GASKINS,
Defendant
: ACTION IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wish to defend against the claims set forth in the
following pages, you must take prompt action. You are warned that if you fail to do so, the case
may proceed without you and a decree of divorce or annulment may be entered against you by the
Court. A judgment may also be entered against you for any other claim or relief requested in
these papers by the Plaintiff. You may lose money or property or other rights important to you,
including custody or visitation of your children.
Where the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is available at the
Office of the Prothonotary, Cumberland County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM THEM.
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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pa. 17013
(717) 249-3166
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ROSELINE S. GASKINS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 60. 5'1(.3 Ci;;J
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KEITH A. GASKINS,
Defendant
: ACTION IN DIVORCE
COMPLAINT IN DIVORCE
I. Plaintiff is Roseline Gaskins, an adult individual, who has resided at 26A Forbes Ave.,
Carlisle, Cumberland County, Pennsylvania, since 1999.
2. Defendant is Keith A. Gaskins, an adult individual, who has resided at 26A Forbes
Ave., Carlisle, Cumberland County, Pennsylvania, since 1999.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at
least 6 months immediately previous to the filing of this Complaint.
4. The Plaintiff and the Defendant were married on February 3, 1984 in San Antonio,
T~as. .
5. There have been no prior actions of divorce or for annulment between the parties.
6. Plaintiff has been advised that counseling is available and that plaintiff may have the
right to request that the court require the parties to participate in counseling.
7. Plaintiff and Defendant have 2 children together, namely, Keith Avery Gaskins JI.,
dob 3/19/86, and Kiara AJisha Gaskins, dob 6/23/92.
8. Plaintiff and Defendant are both citizens of the United States of America.
9. Plaintiff is a member of the Armed Forces; however, Defendant is not a member ofthe
Armed Forces of the United States of any of its allies.
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10. The Plaintiff avers that the grounds on which this action is based are: That the
marriage is irretrievably broken.
WHEREFORE, Plaintiff requests the court to enter a decree in divorce.
I verify that 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. 94904 relating to unsworn
falsification to authorities.
"~~
Roseline Gaskins, Plaintiff
Respectfully submitted,
Date: (3 . 7.00
e Adams, Esquire
J.D. No. 79465
117 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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ROSELINE S. GASKINS,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 00 - 5463 Civil Term
KEITH A. GASKINS,
Defendant
: ACTION IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wish to defend against the claims set forth in the
following pages, you must take prompt action. You are warned that if you fail to do so, the case
may proceed without you and a decree of divorce or annulment may be entered against you by the
Court. A judgment may also be entered against you for any other claim or relief requested in
these papers by the Plaintiff. You may lose money or property or other rights important to you,
including custody or visitation of your children.
Where the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is available at the
Office of the Prothonotary, Cumberland County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM THEM.
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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pa. 17013
(717) 249-3166
-
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ROSELINE S. GASKINS,
Plaintiff
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
vs.
No. 00 - 5463 Civil Term
KEITH A. GASKINS,
Defendant
: ACTION IN DIVORCE
COMPLAINT IN DIVORCE
COUNT I - DIVORCE
I. Plaintiff is Roseline Gaskins, an adult individual, who has resided at 26A Forbes Ave.,
Carlisle, Cumberland County, Pennsylvania, since 1999.
2. Defendant is Keith A. Gaskins, an adult individual, who has resided at 26A Forbes
Ave., Carlisle, Cumberland County, Pennsylvania, since 1999.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at
least 6 months immediately previous to the filing of this Complaint.
4. The Plaintiff and the Defendant were married on February 3, 1984 in San Antonio,
Texas.
5. There have been no prior actions of divorce or for annulment between the parties.
6. Plaintiff has been advised that counseling is available and that plaintiff may have the
right to request that the court require the parties to participate in counseling.
7. Plaintiff and Defendant have 2 children together, namely, Keith Avery Gaskins JI.,
dob 3/19/86, and Kiara AJisha Gaskins, dob 6/23/92.
8. Plaintiff and Defendant are both citizens of the United States of America.
9. Plaintiff is a member of the Armed Forces; however, Defendant is not a member of the
Armed Forces of the United States of any of its allies.
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10. The Plaintiff avers that the grounds on which this action is based are:
(a) That the marriage is irretrievably broken.
(b) The Defendant has offered such indignities to the Plaintiff, the innocent
and injured spouse, as to render her condition intolerable and life burdensome.
WHEREFORE, Plaintiff requests the court to enter a decree in divorce.
COUNT II - EOUITABLE DISTRIBUTION OF PROPERTY
AND POSSESSION OF MARITAL RESIDENCE.
11. Paragraph 1 through 10 of the Complaint are incorporated herein by reference as
though set forth in full.
12. Plaintiff and Defendant have acquired property, both real and personal, during their
marriage.
13. Plaintiff and Defendant have been unable to agree as to an equitable division of said
property.
14. Plaintiff and Defendant currently share a residence at 26 Forbes Road, Carlisle, Pa.
which is located at the Army War College.
15. During the pendency ofthis action, there has been much animosity between the
parties.
16. Defendant has verbally harrassed and insulted Plaintiff and purposely engaged in a
cause of conduct designed to harrass Plaintiff.
17. The Court maintains the power to award exclusive occupancy of the marital
residence pursuant to the Divorce Code. (23 Pa.C.S.A. 91101 et.seq.).
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WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital
property, and grant exclusive possession of the couple's home to Plaintiff.
I verify that 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. 94904 relating to unsworn
falsification to authorities.
Date: 1'~' 00
Respectfully submitted,
~~
J.D. No. 79465
117 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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ROSELINE S. GASKINS
PLAINTIFF
V.
KEITH A. GASKINS
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
00-5463 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 15th day of September ,2000, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator,
at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the 18th day of Oetober ,2000, at 10:15 a.m.
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to defme 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: Isl
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Dlsabilites 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
attend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HA VB AN ATTORNEY 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
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ROSELINE S. GASKINS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 00 - 5463 Civil Term
KEITH A. GASKINS,
Defendant
ACTION IN DIVORCE
ORDER OF COURT
AND NOW, this
day of
, 2000, upon
consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear
before
, Esquire, the conciliator, at
, Pennsylvania, on
, the
day of
, 2000, at
o'clock .m. for a Pre-Hearing Custody Conference. At such
conference, an effort will be made to resolve the issues in dispute; or ifthis cannot be accomplished, to defme and
narrow the issues to be heard by the court, and to enter into a temporary order. Either party may bring the child who
is the subject of this custody action to the conference, but the child's attendance is not mandatory. Failure to appear
at the conference may provide grounds for entry of a temporary or pennanent order.
FOR THE COURT,
By
Custody Conciliator
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.
OFFICE OF THE COURT ADMINISTATOR
CUMBERLAND COUNTY COURTHOUSE, 4TH FLOOR
CARLISLE, PA. 17013
(717) 240-6200
AMERICANS WITH DISABILITIES ACT OF 1990
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 accomodations 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 attend the scheduled conference or
hearing.
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ROSELINE S. GASKINS,
Plaintiff
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 00 - 5463 Civil Term
KEITH A. GASKINS,
Defendant
: ACTION IN DIVORCE
COMPLAINT FOR CUSTODY
1. Plaintiff is Roseline Gaskins, who currently resides at the Carlisle Barracks, Carlisle,
Pa. 17013.
2. Defendant is Keith Gaskins, who currently resides at 26 Forbes Ave., Carlisle, Pa.
17013.
3. Plaintiff seeks full custody of the following children:
NAME
ADDRESS
AGE
Keith Avery Gaskins
26 Forbes Ave.
Carlisle, Pa. 17013
14
Kiara Alisha Gaskins
26 Forbes Ave.
Carlisle, Pa. 17013
8
The children were not born out of wedlock.
The children are in the custody of: Keith Gaskins, FATHER, as of September 7, 2000.
Before this time, children lived with MOTHER and F ATHER since birth.
During the past five years, the children have resided with the following persons and at the
following addresses:
NAME
ADDRESSES
DATES
Roseline and Keith Gaskins 2 Forbes Ave.
Carlisle, Pa. 17013
7/15/99 to present.
Roseline and Keith Gaskins 206 Marion Ave.
Carlisle, Pa. 17013
7/15/98 to 7/15/99
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Roseline and Keith Gaskins Germany
1995 to 7/15/99
The mother of the children is: Roseline Gaskins, currently residing at: Carlisle Barracks,
Carlisle, Pa.
She is married to Keith Gaskins, however a divorce action is pending.
The father of the children is: Keith Gaskins, currently residing at: 26 Forbes Ave.,
Carlisle, Pa. 17013.
He is married to Roseline Gaskins, however a divorce action is pending.
4. The relationship of plaintiff to the children is that of MOTHER. The plaintiff
currently resides alone in the Carlisle Barracks.
5. The relationship of defendant to the children is that of FATHER. The persons that the
defendant currently resides with are: Keith Gaskins, Jr., and Kiara Gaskins.
6. Plaintiff has not participated as a party or witness, or in another capacity, in other
litigation concerning the custody of the children in this or another court.
Plaintiff has no information of a custody proceeding concerning the children pending
in a court of this Commonwealth.
Plaintiff does not know of a party to the proceedings who has physical custody of the
children or claims to have custody or visitation rights with respect to the children.
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7. The best interest and permanent welfare of the children will be served by granting the
relief requested because: MOTHER has been the primary caretaker of the children since birth and
seeks primary physical and legal custody of the children now that a divorce with FATHER is
imminent. The best interest of the children would be served by granting this request because the
children have and will benefit from MOTHER's constant attention and care. MOTHER is better
suited to provide a secure. stable. and loving atmosphere for the children and oversee their
schooling and care.
8. Each parent whose parental rights to the child have not been terminated and the person
who has physical custody of the child have been named as parties to this action.
WHEREFORE, Plaintiff requests the court to grant her primary legal and physical
custody of the children.
I verify that 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. 94904 relating to unsworn
falsification to authorities.
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Plaintiff
Date: q, . g-. oD
Respectfully submitted,
CJ?Ch
J e Adams, Esquire
.D. No. 79465
117 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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ROSELINE S. GASKINS,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
vs.
: No. 00 - 5463 Civil Term
KEITH A. GASKINS,
Defendant
: ACTION IN DIVORCE
AFFIDAVIT OF SERVICE REGARDING PLAINTIFF'S
NOTICE TO DEFEND. AMENDED COMPLAINT AND PETITION FOR CUSTODY
AND NOW, thi~:Jl'taYOf~ 2000, I, First Sergeant Stockdell, an adult
individual over the age of 18, on Friday, September 8, 2000 at appoximately 5:25 p.m.
personally handed KEITH GASKINS, Defendant, in the above-captioned matter a true and
correct copy of Plaintiff' s NOTICE TO DEFEND, AMENDED COMPLAINT, AND PETITION
FOR CUSTODY, after personally locating him at his residence, which has an address of:
Keith Gaskins
26A Forbes Ave
Carlisle, Pa. 17013
Respectfully Submitted:
ADDRESS: .'
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PHONE: "77{P - 3lnf 1
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ROSELINE S. GASKINS,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 00 - 5463 Civil Term
KEITH A. GASKINS,
Defendant
: ACTION IN DIVORCE
AFFIDAVIT OF SERVICE REGARDING PLAINTIFF'S
NOTICE TO DEFEND. COMPLAINT IN DIVORCE PURSUANT TO Pa.R.C.P. 1930.4
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AND NOW, this~ day of Oufo(!.~ 2000, I, Jane Adams, Esquire, hereby certify
that on August 9, 2000 I sent a true and correct copy of Plaintiff s Notice to Defend and
Complaint in Divorce (which was filed with the Prothonotary on August 7. 2000), via regular
mail, and this regular mail was not returned to me and therefore service may be deemed complete
pursuant to Pa.R.C.P. 1930.4. The regular mail I sent was addressed to:
Keith Gaskins
26A Forbes Ave
Carlisle, Pa. 17013
DEFENDANT
Respectfully Submitted:
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Jane Adams, Esquire
I.D. No. 79465
117 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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ROSELINE S. GASKINS,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-5463
KEITH A. GASKINS,
Defendant
CIVIL ACTION - LAW
CUSTODY
ORDER OF COURT
AND NOW, this 2. S-- day of OchJ.-r , 2000, upon consideration
of the attached Custody Conciliation Summary Report and agreement of the parties, it is
hereby directed as follows:
1. Legal Custody. The parties, Roseline S. Gaskins and Keith A. Gaskins, shall have
shared legal custody of the minor Children, Keith Avery Gaskins, Jr., born March 19, 1986,
and Kiara Alicia Gaskins, born June 23,1992. Each parent shall have an equal right, to be
exercised jointly with the other parent, to make all major non-emergency decisions affecting
the Child's general well-being including, but not limited to, all decisions regarding her health,
education and religion. Pursuant to the terms of this paragraph, each parent shall be entitled
to all records and information pertaining to the Child including, but not limited to, school and
medical records and information. To the extent one parent has possession of any such
records or information, that parent shall be required to share the same, or copies thereof, with
the other parent within such reasonable time as to make the records and information of
reasonable use to the other parent.
2. Physical Custody. The Children shall be in the primary physical custody of Mother,
subject to partial physical custody with Father at such times as the parties may agree.
3. Holidays. Holidays shall be shared as agreect by the parties.
4. In the event that Mother's duty in the military requires her relocation outside of the
Commonwealth of Pennsylvania, Mother shall provide Father with at least a ninety-day (90)
notice of the assignment and location. At that time, the parties will attempt to reach a modified
agreement with regard to the custodial arrangements for their Children. If, however, the
parties cannot reach an agreement, either party may file a petition to modify the present
Custody Order and the case shall be assigned to a Custody Conciliation Conference.
BY THE COURT,
J.
Dist:
Jane Adams, Esquire, 117 S. HanoverStree1, Carlisle, P 17013
Keith A. Gaskins, 26-A Forbes Avenue, Carlisle, PA 17 13
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Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-5463
KEITH A. GASKINS,
Defendant
CIVIL ACTION - LAW
CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the fOllowing report:
1. The pertinent information concerning the Children who the subject of this litigation
is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Keith Avery Gaskins, Jr.
Kiara Alicia Gaskins
March 19, 1986
June 23, 1992
Mother
Mother
2. A Conciliation Conference was held on October 18, 2000, with the following
individuals in attendance: The Mother, Roseline S. Gaskins, and her counsel, Jane Adams,
Esquire; and the Father, Keith A. Gaskins, pro se.
3. The parties reached an agreement in the form of an Order as attached.
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I
Melissa eel reevy, Esquire
Custody Conciliator
Date