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Home My WebLink About00-05812 4l. .~ . _" -'N -~, < '- i" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW THRESSA A. WETTRICH, Plaintiff NO. (}lO-5~1::L ~~ v. JAMES A. WETTRICH, Defendant IN CUSTODY ORDER OF COURT AND NOW, this -z'-'\ day of ~2000, upon consideration of the attached Stipulation for Entry of a Custody Order, IT IS HEREBY ORDERED AND DECREED that custody and partial custody with respect to the minor children: LEANNE NICOLE WETTRICH, born June 29, 2988; and JAMES A WETTRICH, JR., born November 11, 1990, is awarded as follows: 1. The parents shall share legal custody of the minor children. Both parents shall discuss important issues with each other concerning the minor children'S development, including but not limited to, educational, religious and medical matters. 2. MOTHER shall have primary physical custody of the minor children. 3. FATHER shall have partial physical custody of the minor children on alternate weekends from Friday at 6: 00 p. m. until .' ~ -, " C'~~"~, Sunday at 6:00 p.m., on the weekends when MOTHER is working. 4. The following holidays shall be alternated between the parents from year to year; Easter, Memorial Day, the Fourth of July, Labor Day and Thanksgiving. FATHER shall have the minor children on the holidays when MOTHER is working; MOTHER shall have the minor children on the holidays when she is not working. Unless otherwise agreed by the parents, the hours shall be from 9:00 a.m. until 8:00 p.m. 5. The parents shall share the Christmas holiday with the minor children. Every year, FATHER shall have Christmas Eve until 9:00 p.m. and New Year's Day until 5:00 p.m.; and MOTHER shall have Christmas Day. 6. Both parents shall have the opportunity to see the minor children on their birthdays (June 29th and November 11th) and on each of the parent's birthdays. 7. MOTHER and FATHER shall each have two weeks of summer custody with the minor children. These weeks need not be consecutive, but every effort should be made to take these weeks in conjunction with that parent's regularly scheduled weekend. The parents shall give each other written notice by June 1st of each year, if possible, of their chosen weeks for summer custody. In the event that both parents choose the same week(s) for summer custody, ~-~~ .ilU"< the parent who gives first notice shall prevail. 8. FATHER shall have the child on Father's Day and MOTHER shall have the child on Mother I s Day, regardless of the usual schedule. Unless otherwise agreed by the parents, the hours shall be from 9:00 a.m. until 8:00 p.m. 9. If either parent plans to relocate more than sixty (60) miles from their current residences, the relocating parent shall notify the other at least ninety (90) days prior to the expected move in an attempt to negotiate an alternate custody schedule or, if that is unsuccessful, to file a Petition to Modify the Custody Order with the Court. 10. MOTHER and FATHER shall permit reasonable telephone access between the children and each of their parents. The children shall be permitted to place calls to both of their parents. 11. Neither parent shall make derogatory comments about the other in the presence or hearing of the children, and they shall not permit third parties to make derogatory comments about the other parent in the presence or hearing of the children. 12. MOTHER and FATHER shall encourage a close and loving relationship between the children and their parents. 13. MOTHER and FATHER shall communicate directly with one another concerning parenting issues. 14. By mutual consent of the parents, an expanded or altered ",',' schedule may be agreed upon between them for and in the best interests of the minor children. 15. This Order shall replace and supercede any and all prior Orders of Court or agreements between the parties. 16. This Order shall remain in full force and effect until further Order of Court. BY THE COURT: f I \ ,- t~o q;~ ~ J. [~j'n "V"~AM!t..Ll!m1bt'!ffi-aaM-~Mrdil~~~m~!~-,*,, "'<""'"'''''''-1>.''''''''''>lM'ill;!,!;0fu~1'-;~~~t1'__1&I4~iililii~ -1 "'<~~!1iiW~llillllii":i- .1.;, b ';1/.') ''lVL, i d;,,,: v/! '7t /" '""_1 ,-<>!S:~!~ "I ,,;',p. ',/1/' -2 (/ .. ' > ~'2~~~?;~~ ". ')') -,(...)1 .. .... \,;;),./ .l {~-"1 <,' /f~.(~'f.", """',in: ,y.:k~:i3~~ ,-". ,~ ~ ",~ -~,. ~ .. "'</,,_,1 ~""'''l ,~ L, ~', . ~~IU_['I! :h.d. ,"~V_ '",^,,'- l~ ~",," IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW THRESSA A. WETTRICH, Plaintiff : NO. () 0 - E5 ~ \ ~ ~~ . . v. JAMES A. WETTRICH, Defendant IN CUSTODY STIPULATION FOR ENTRY OF CUSTODY ORDER The parties to this action, JAMES A. WETTRICH (hereinafter referred to as "FATHER"), and THRESSA A. WETTRICH (hereinafter referred to as "MOTHER"), desiring to amicably settle and resolve all outstanding issues concerning custody and partial custody with respect to the minor children involved in this action: LEANNE NICOLE WETTRICH, born June 29, 1988; and JAMES A. WETTRICH, JR., November 11, 1990, hereby stipulate and agree to the entry of an Order of Court awarding custody and partial custody of LEANNE and JAMES as follows: 1. The parents agree that they shall share legal custody of the minor children. Both parents agree to discuss important issues wi th each other concerning the minor children's development, including but not limited to, educational, religious and medical matters. , "'",~,~ " - '~ .;.:' .:i.i'tolII,~;: .' 2. The parents agree that MOTHER shall have primary physical custody of the minor children. 3. The parents agree that FATHER shall have partial physical custody of the minor children on alternate weekends from Friday at 6: 00 p.m. until Sunday at 6: 00 p.m., on the weekends when MOTHER is working. 4. MOTHER and FATHER agree that the following holidays shall be alternated between them from year to year; Easter, Memorial Day, the Fourth of July, Labor Day and Thanksgiving. FATHER shall have the minor children on the holidays when MOTHER is working; MOTHER shall have the minor children on the holidays when she is not working. Unless otherwise agreed by the parents, the hours shall be from 9:00 a.m. until 8:00 p.m. 5. MOTHER and FATHER agree to share the Christmas holiday with the minor children. Every year, FATHER shall have Christmas Eve until 9:00 p.m. and New Year's Day until 5:00 p.m.; and MOTHER shall have Christmas Day. 6. MOTHER and FATHER agree that each shall have the opportunity to see the minor children on their birthdays (June 29th and November 11th) and on each of the parent's birthdays. 7. The parents agree that they shall each have two weeks of summer custody with the minor children. These weeks need not be .~'-'~. .'" ,~ .~ ~ -- . ",--- "~ ' , ,. ~'''~ .' consecutive, but every effort should be made to take these weeks in conjunction with that parent r s regularly scheduled weekend. The parents agree to give each other written notice by June 1st of each year, if possible, of their chosen weeks for summer custody. In the event that both parents choose the same week (s) for summer custody, the parent who gives first notice shall prevail. 8. The parents agree that FATHER shall have the child on Father's Day and MOTHER shall have the child on Mother's Day, regardless of the usual schedule. Unless otherwise agreed by the parents, the hours shall be from 9:00 a.m. until 8:00 p.m. 9. The parents agree that if either of them plans to relocate more than sixty (60) miles from their current residences, the relocating parent shall notify the other at least ninety (90) days prior to the expected move in an attempt to negotiate an alternate custody schedule or, if that is unsuccessful, to file a petition to Modify the Custody Order with the Court. 10. MOTHER and FATHER agree that they shall permit reasonable telephone access between the children and each of their parents. The children shall be permitted to place calls to both of their parents. 11. The parents agree neither shall make derogatory comments about the other parent in the presence or hearing of the children, and they shall not permit third parties to make derogatory comments about the other parent in the presence or hearing of the children. 12. MOTHER and FATHER agree that they shall encourage a close and loving relationship between the children and their parents. 13. MOTHER and FATHER agree that they shall communicate directly with one another concerning parenting issues. 14. Both parents agree that, by their mutual consent, an expanded or altered schedule may be agreed upon between them for and in the best interests of the minor children. 15. The parents agree that this Agreement shall be submitted to the Court of Common Pleas of Cumberland County, Pennsylvania for approval and for entry of an Order awarding custody and partial custody as set forth herein, and the parents hereby request the Court to enter such an Order. IN WITNESS WHEREOF, the parties have executed this Custody Stipulation on the date(s) indicated below. ~'--wf,Q~ Witness fl' / b .CD Date CCfl/lftM) 4.l1) ~ JAMES A. WETTRICH ~f:E~' f! ~ ;J3 c(j; \~f)~QPr1 0, ll-M:h;('j~ THRESSA A. WETTRICH Date ,,,-,,,- if'i~Biw.I~!ilic~lll'!8illW'.~a:&;IJi!i!l;l:i'll'';'''~-4,~:W,';,-j'"''''-'',h'>i,m!;iIlii':;_<<iriM~*~~Jllli;!;d :.1 "~ "= .'- .. ,-", ,"- " ~ - ,~ ~, ..,,' "ilL I, " .i In;:M!lli;:'1j~oliil" ~ 'HW-~' (') 0:":) C) c: w' .. < ~ u ~ I'll I' ~'\ ;",") z_ ~"'<~ ;~': (f::J C,;, -< f":. -" ~!?: I'~' :::K ) L.. (~) "/" ::D- ~'" ,-", r". ::.:.:~ 2: ,.~"" -.\ :.J) :J:J -<. \0 -< """ ,.. .. ',"'~~ -""",' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW THRESSA A. WETTRICH, Plaintiff v. NO. Co- s-PI'J..... Civil Term JAMES A. WETTRICH, Defendant . . IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, THRESSA A. WETTRICH, by and through her attorney, Maryann Murphy, Esquire, of Legal Services, Inc., and respectfully files this Complaint for Custody, and in support thereof avers as follows: 1. The Plaintiff is THRESSA A. WETTRICH who currently resides at 92 A Fairview Street, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is JAMES A. WETTRICH who currently resides at 5 Mill Road, Site 2, Mount Holly Springs, Cumberland County, Pennsylvania. 3. The Plaintiff seeks primary physical and shared legal custody of the following children: LEANNE NICOLE WETTRICH, born June 29, 1988 and JAMES A. WETTRICH, JR., born November 11, 1990 4. The children were born in wedlock. They currently reside :& ;iji~cl with Plaintiff. 5. During the lifetime of the children, they have resided at the following addresses with the following persons: Time Address with Whom birth-1989 Waynesburg, PA Plaintiff/Defendant 1989-1993 Boiling Springs, PA Plaintiff/Defendant 1993-1997 Mt. Pleasant, PA Plaintiff/Defendant 1997-6/00 92A Fairview St. Carlisle, PA Plaintiff/Defendant 6/00-present 92A Fairview St. Carlisle, PA Plaintiff 6. The father of the children is JAMES A. WETTRICH. He is married to Plaintiff. 7. The mother of the children is THRESSA A. WETTRICH. She is married to Defendant. 8. The children currently reside with Plaintiff. 9. The Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the children in this or any other Court, except as set forth above. 10. The Plaintiff has no information of a custody proceeding concerning the children 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 children, or claims ,,' '" ~ ""'"~""-1 to have custody or visitation rights with respect to the children. 12. Each parent whose parental rights to the children have not been terminated, and the persons who have physical custody of the children, 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 children and therefore, no further notice of the pendency of this action and the right to intervene shall be given, other than to the parties named herein. 13 . The best interest and permanent welfare of the minor children will be served by granting Plaintiff primary physical and shared legal custody. WHEREFORE, Plaintiff requests this Honorable Court to grant her primary physical and shared legal custody of LEANNE NICOLE WETTRICH and JAMES A. WETTRICH, JR. Respectfully submitted, I~ Maryann urphy, Legal Services, 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 LD. # 61900 Attorney for Plaintiff ,~ ~\t" VERIFICATION I, THRESSA A. WETTRICH, verify that the statements made in the foregoing Custody 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. \..iIn OJY'\I"\ 01' ~ THRESSA A. WETTRICH , " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW THRESSA A. WETTRICH, Plaintiff vs. NO. JAMES A. WETTRICH, Defendant IN CUSTODY CERTIFICATE OF SERVICE civil Term I, Maryann Murphy, Esquire, do hereby certify that on the day of , 2000 I served a true and correct copy of the foregoing Custody Complaint on the Defendant, JAMES A. WETTRICH at the address set forth below, by placing a copy of same in the United States Mail, postage prepaid, certified/restricted delivery. James A. Wettrich 5 Mill Road, Site 2 Mt. Holly springs, PA 17065 Respectfully submitted, Maryann urphy, Legal Services, 8 Irvine Row Carlisle, PA 17013 (717) 540-8600 LD. # 61900 ,&a , .. "".<"",....1 'I I .. "';":"">":t~~ll!ll~;~~~iml~l.'r4Mt"!Ii.MI~~Mit""di;";'l<'W~,i~~~~~im~~&lliIW<l'1~ --'.4!ii1~U~ ' " - ~,-~" --~'. ,'c. "'-','-<'" '^ A ~ "' ri;;d'~ J!:;\~'~~' >-- ~ . 0 0 ,,-~ C (::l " 7 ~g1 "'" ~,;) Z~., r..., ~:~~': c.....:: ~C] .'0 ~('') ..,.,.. L.. '~'. --- ~2:: ~ C) 2: > =< :., en :0 -< T , ' . < - - '... ..'~ J~ ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW THRESSA A. WETTRICH, Plaintiff v. : NO. OO-Sp,:J... Gc:,lC-r~ : IN CUSTODY JAMES A. WETTRICH, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, THRESSA A. WETTRICH, Plaintiff, to proceed in forma pauperis. I, Maryann Murphy, Esquire, of Legal Services, Inc., attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. ~j ~4.M- Maryann rphy, Esquire Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 (717) 243,9400 J.D. # 61900 Attorney for Plaintiff ';_. ..- ~ ," , " -'0' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW THRESSA A. WETTRICH, Plaintiff :NO. v. : IN CUSTODY JAMES A. WETTRICH, Defendant AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS I. I am THRESSA A. WETTRICH, Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting. defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: THRESSA A. WETTRICH Address: 92 A Fairview Street. Carlisle. PA 17013 (b) Social Security Number: 178-54-6338 If you are presently employed, state Employer: Chapel Pointe Address: 770 Hanover Street. Carlisle. PA 17013 Salary or wages per month: N/A Type of work; Nursing assistant If you are presently unemployed, state NIA Date of last employment: N/A Salary or wages per month: NIA Type of work: NIA (c) Other income within the past twelve months Business or profession: -0- Other self-employment: -0- Interest: -0- Dividends: -0- Pension and annuities: -0- Social Security benefits: ,0, Support payments: -0- Disability payments: -0- Unemployment compensation and supplemental benefits: -0- Workman's compensation: -0- Public Assistance: -0- Other: -0- (d) Other contributions to household support (Wife)(Husband) Name: NI A (the parties are seoarated) If your (husband) (wife) is employed, state Employer: N/A ;:. ~ -,~- '~,,-J ~,-" ~ "k=' " 0' " _ ~. '~',~ ~lLflb;" Salary or wages per month: N/A Type of work: N/A Contributions from children: -0- (e) Property owned Cash: $5.00 Checking Account: $100.00 Savings Account: $25.00 Certificates of Deposit: -O- Real Estate (including home): -0- Motor vehicle: Make Dodge Caravan Year 1986 Cost $650.00 - a1;>proximate value Amount owed -0- Stocks; bonds: Other: (f) Debts and obligations Mortgage: Rent: -0- -0- -0- $600.00 Loans: $130.00 per month Monthly Expenses: $1.700.00 (g) Persons dependent upon you for support (Wife) (Husband) Name: N/A -, < "~ ,""1 I I Children, if any: Name: Leanne Age: 11 Name: James Age: 9 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Date:C:,/J~Jt8 . THRESSA A. WETTRICH L ~~~~~Ulloi~mf~"'-ffi",.j;~"~"<I!l~~[,lt4i!1il~!$;j"iW!1",*l"~,w.A --. -", . .It JU !l1-l~',"""~,m 11."1, o~-- CU, ''''<' ~,~~, ,,- ,~" "",,",,,. -w.e ",1,"- ~'ell: I - c:. ,.,..i e-- ~~~ \:J , r,-\ , 2.:- ", ;;,,": r ;. <i en ., L ; -' L:: l. "(.J '1:-; '^',. ~~; (:1 :-1 ,~ r. )> ;,.-> ~J C , Z ,;....) ~ =< c_ t" _U -< ,^" ~~~~ ~