HomeMy WebLinkAbout01-0231 FX
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HEIDI M, WARNER,
Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
CML ACTION - LAW
2001- ;1,.31 CIVIL TERM
JEFFREY B, WARNER,
Respondent
IN CUSTODY
ORDER OF COURT
AND NOW, this day of . 2001, upon consideration of the
attached petition, it is hereby directed that the parties and their respective counsel appear
before Esquire, the conciliator, at
. on the day of .2001 at . 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 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 this conference may provide grounds for entry of
a temporary or permanent order.
By 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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
1-800-990-9108
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 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 scheduling conference or hearing.
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HEIDI M, WARNER,
Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION -LAW
2001-.'2J/ CIVIL TERM
JEFFREY B, WARNER,
Respondent
IN CUSTODY
PETITION FOR CUSTODY
1~
AND NOW, this ~ day of January 2001, comes the Petitioner, Heidi M. Warner, by
her attorneys, Irwin, McKnight and Hughes, and presents the following Petition for Custody.
1.
The petitioner is Heidi M. Warner, an adult individual who resides at 51 Blue Pond Road,
Newville, Cumberland County, Pennsylvania 17241.
2.
The respondent, Jeffrey B. Warner, is an adult individual who resides at 1840 Pine Road,
Newville, Cumberland County, Pennsylvania 17241.
3.
The parties are the natural parents of three minor children, namely, Zackary B. Warner,
born August 30, 1990, age ten (10) years; Jeffrey N. Warner, born September 3, 1992, age eight
(8) years; and Gregory S. Warner, born August 9, 1995, age five (5) years.
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4.
Petitioner desires primary physical custody of the child and joint legal custody with
periods of visitation to respondent as can be mutually arranged between the parties.
5.
The best interest of the children requires that the court grant the petitioner's request as set
forth above.
WHEREFORE, petitioner respectfully seeks the entry of an Order of Court seeking
primary physical custody of the children and joint legal custody with periods of visitation to
respondent as can be mutually arranged between the parties.
Respectfully submitted,
By:
'ZIGJIT & HUGHES
S;1Jw~
Mark D, Schwartz, Esquire
Attorney for Petitioner
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
717-249-2353
Supreme Court J.D. No: 70216
Date: January L, 2001
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VERIFICATION
The foregoing Petition for Custody is based upon information which has been gathered by
my counsel and me in the preparation of this action. I have read the statements made in this
Petition and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unsworn falsification to authorities.
J/;Yik:.rm. !Y a;u.e/U
HEIDI M, WARNER
Date: January 8, 2001
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HEIDI M. WARNER
PLAINTIFF
V,
JEFFREY B. WARNER
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-231
CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 19th day of January, 2001, upon consideration ofthe attached Complaint,
it is hereby directed that the parties and their respective counsel appear before Hubert X. Gilroy, Esq. ,the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on the 1st day of March, 200 I, at 9:30 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 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 TIllS 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
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HEIDI M. WARNER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V ANlA
v
CIVIL ACTION - LAW
JEFFREY B. WARNER,
Defendant
NO. 01 - 231 CIVIL
IN CUSTODY
Prior Judge:
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the following report:
1. The pertinent information pertaining to the children who are the subject of this litigation is
as follows:
Zachary B. Warner, born August 30,1990; JeffreyN. Warner, born September 3,1992; and
Gregory S. Warner, born August 9,1995.
2. A Conciliation Conference was held on March 1, 2001, with the following individuals in
attendance:
The Mother, Heidi M. Warner, with her counsel, Mark D. Schwartz, Esquire; and the
Father, Jeffrey B. Warner, with his counsel, Maria Cognetti, Esquire.
3. The parties agree to the entry of an order in the form as attached.
]18..101
DATE
Hubert X. G' y, Esquire
Custody nciliator
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MAR 0 6 ZOOI fi!7
HEIDI M. WARNER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
CIVIL ACTION - LAW
JEFFREYB. WARNER,
Defendant
NO. 01 - 231 CIVIL
IN CUSTODY
COURT ORDER
AND NOW, this l.~ day of March, 2001, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
1. The Mother, Heidi M. Warner, and the Father, Jeffrey B. Warner, shall enjoy shared
legal and shared physical custody of Zachary B. Warner, born August 30, 1990;
Jeffrey N. Warner, born September 3, 1992; and Gregory S. Warner, born August 9,
1995.
2. Physical custody shall be handled pursuant to a schedule that allows for both parents
to have equal time with the minor children. Unless agreed otherwise between the
parties, the children shall be with Father on Mondays and Tuesdays of each week
and the children will be with Mother on Wednesdays and Thursdays of each week.
The parties will alternate the weekends that will include Friday, Saturday and
Sunday. This schedule can be modified in any manner as agreed upon by the parties
as long as the parties work out an amicable schedule that achieves a 50/50 custody
arrangement.
3. In the event a custodial parent is unavailable to care for the children during a
significant period of time of at least four (4) hours, that parent shall be required to
contact the other parent to offer them the first opportunity to provide daycare for the
minor children.
4. Both parents shall enjoy reasonable telephone contact with the minor children when
they are in the other parent's custody.
5. This order is a temporary order and entered with the understanding that either party
may advance a different position on a permanent custody order at a subsequent
Custody Conciliation Conference or at a hearing on this case. The parties shall meet
again with the Custody Conciliator for a second Conciliation Conference on
Thursday, May 17, 2001 at 9:30 a.m.
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6. The parties will share custody on the Easter holiday with the timeframe to be
arranged between the parties.
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cc:
Mark D. Schwartz, Esquire
Maria P. Cognetti, Esquire
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JUN 0 5200tfJ
HEIDI M. WARNER,
Plaintiff
v
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 01- 231 CIVIL ACTION - LAW
JEFFREY B. WARNER,
Defendant
: IN CUSTODY
COURT ORDER
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AND NOW, this day oJ;:M:tY, 2001, the Conciliator being advised that the parties have
reconciled, the Conciliator relinquishes jurisdiction.
BY THE COURT,
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Hubert X. Gilroy, Esquire
Custody Conciliator
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HEIDI M. WARNER,
Plaintiff
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CIVIL ACTION - LAW
IN CUSTODY
v.
NO. 01-231 CIVIL ACTION
JEFFREY B. WARNER,
Defendant
ORDER
AND NOW, this I ,J1to..daY of :r ~
, 2001 it is hereby ORDERED and
DECREED that the attached Stipulation is hereby entered as an Order of this Court.
BY THE COURT:
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
v.
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NO. 01-231 CIVIL ACTION
HEIDI M. WARNER,
Plaintiff
JEFFREY B. WARNER,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
--.--
THIS STIPULATION is entered into this I!> day of :J tJn~, 2001, by
STIPULATION
and between Donald T. Kissinger, Esquire, counsel for Plaintiff Heidi M. Warner, and Maria P.
Cognetti, Esquire, counsel for Defendant Jeffrey B. Warner;
WITNESSETH:
WHEREAS, the parties to the above-captioned action have reconciled;
WHEREAS, the parties and their counsel agree that the Court Order of March 6, 2001
entered by the Honorable Edward E. Guido is no longer necessary and desire that it shall
hereafter be deemed to be null and void.
NOW, THEREFORE, in consideration of these premises and of the mutual promises,
covenants and undertakings set forth herein, and intending to be legally bound hereby, the parties
hereto agree as follows:
1. The Court Order dated March 6, 2001 docketed to the above term and number
shall be vacated and the underlying action dismissed.
2. The terms of this Stipulation shall be incorporated into an Order of Court in the
form attached hereto.
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IN WITNESS WHEREOF, counsel for the parties hereto have affixed their hands and
seals the day and date first written above.
Ire
Jeffrey B. Warner
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