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HomeMy WebLinkAbout00-07741 BRIGITTE M. B~OLDER PLAINTIFF V. STEVEN D. BURKHOLDER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 00-7741 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 3rd day of November, 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Maiu Street, Meehanicsburg, PA 17055 on the 16th day of November ,2000, at ~OO p.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 Disabilites 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 1HIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE 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 ~"''''"''-'"~'l I" "I ~~~/:lj<liOli;.;ji.k",~,,;""'IJ;'l,;'(~""""'''''''''''';;'''-';h'''':''''!~',",''d,"dJ"lli'b'''L'2_;~'"';~;'''4."~';;'b,;",,,<..",,,,,j,,,,~~IHJIl~!MiiiUi~~<o&I",,;!,;o;;!~''''''~0Ili~il&Il!ill.ol!U - ~~._' ~ -~ GO NO\} - "I Pi}.; 3: 3 j . I... CUIvI8ERLi'dD COUNlY PENNSYLVANIA k 7<OiJ M- &J:f ~~ //7,0::) /l~ ~ ~ //7'00 t~ ~ ~ . uL- ~ ~ BRIGITTE M. BURKHOLDER, plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 0-0 ~ 774 fA . ~.~. /J ~ STEVEN D. BURKHOLDER, Defendant CIVIL ACTION-LAW CUSTODY ORDER You, STEVEN D. BURKHOLDER, are ORDERED to appear in person at Pennsylvania on Mediation Conference. at o'clock a.m./p.m. for a Custody 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. 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 (71 7) 249-3166 Date: Custody Conference Officer - 2 - '" +'(,-~ ~I 'I ~ vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ~- 11'-11 .~ I~ BRIGITTE M. BURKHOLDER, Plaintiff STEVEN D. BURKHOLDER, Defendant CIVIL ACTION-LAW IN CUSTODY COMPLAINT IN CUSTODY AND NOW comes BRIGITTE M. BURKHOLDER, by and through her attorney, Judith A. Calkin, Esquire, and avers as follows: 1. The Plaintiff is BRIGITTE M. BURKHOLDER I an adult individual who resides at 326 Fairview Street, Carlisle, CUmberland County, Pennsylvania. 2. The Defendant is STEVEN D. BURKHOLDER, an adult individual whose current address is 326 Fairview Street, Carlisle, CUlnberland County, Pennsylvania. 3. Plaintiff seeks custody of the following minor child: Steven, born June 21, 1992 Ben, born February 17, 1994 Sean, born June 5, 1996 4. The children were not born out of wedlock. The children currently resides with Plaintiff and Defendant at 326 Fairview Street, Carlisle, CUmberland County, Pennsylvania. 5. During the lifetime of the children they have resided at 326 Fairview Street, Carlisle, Pennsylvania with the Plaintiff and Defendant. 6. The mother of the child is Plaintiff. ''']!I! ,~. .-, , 7. The father of the child is Defendant. S. 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. 9. The Plaintiff has no infonnation of a custody proceeding concerning the children pending in a Court of this Commonwealth. lO. The Plaintiff does not know of a person not 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. ll. Each parent whose parental rights to the child have not been terminated and the person who has 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 rioht to intervene shall be given, other than to the parties named herein. l2. The best interest and pennanent welfare of the children will be served by granting Plaintiff primary physical custody of the minor children with a liberal schedule of partial custody for Defendant because she has. been the primary caretaker and she can provide a loving and secure home. I.~'~~ ~ , ~ - WHEREFORE, Plaintiff requests the Court to grant her primary physical custody of the minor children. Respectfully submitted: I th A. Calkin, Esquire orney for Plaintiff 2201 North Second Street Harrisburg, PA 17110 (717) 238-2312 '-F~, '''l I "~ AFFIDAVIT I verify that the statements made in this Custody Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.Section 4904, relating to unsworn falsification to authorities. Date: ~~ B gitte M. ----- Burkholder Sworn and Subscribed ~ to me this" 30 day of 00(..-.0 b..u., 2000. qhArJWJ.~ Notary Public .l~1 e_ _~ , i- I' ~I i;q I;,,,,,", ~"'~- -- II (') ~, "--.~ :~ c: t..:::l z:,," ,,"""" -, "'(ryen ,~ t;l C=1 ;~i~;;~ .JI{~. .,)..1 - -\IT! ~~,~i :-:_-je.:J c:: r:, 9_6 ~~ ""t' -,o-'~,"i --.-.. :;;:..:..~ ---n z\.....' -~. '-.,):(") j;C! Zrn C 0 Z 1:'" ~ ~ Ul -< ."-!li1'i!A~_'~,,,J,~,~~"D.,_ ~, ~'"7" ..-J.ifu'~I!V<!~'!<W'''''''''Y~W''''_'',!,,'':Y_'r',,"w,wr-ilt1>''ll'~''-9''~;$.lifW~'llW~~ .~,,~R'lf,!M~1 DEe: 2 0 20~ BRIGITTE M. BURKHOLDER, plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-7741 CIVIL TERM . . . . CIVIL ACTION - LAW STEVEN D. BURKHOLDER. Defendant : . . IN CUSTODY OODER OF COORT AND NCM, this 19th day of December, 2000, the Conciliator, having received no request from counsel for either party to reschedule the canceled November 16, 2000 Custody Conciliation Conference, hereby relinqishes jurisdiction in this case. FOR THE COURT, D~~ Custody Conciliator ({ '~ "I' . ~- --,~,"'. '''-"' ,._>--, -~.., ,- -, '\ :ll;dfill~t:~","wi~1!lb";HliGI""!::k1U~\AAI,nib"collc.-;"J"""';"'~" ;',,,H",,"'_J,~___,,__",""k,,,:,1l;I,,~I'Ni\\'iHl..li~~ill1ii(-"""""W.1i1'~lil!lH!!I~~_~l'!i~~IIIiIlIB-~ C:f" ('~::;:'::"'\r .~' I I'",C:: ." 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