The URL can be used to link to this page

Home My WebLink About01-1940 FX " ' __ _ ',. '-"d ",-~ t__ " ,:,"'_,;_ "" ,,,,,l,;'; ,--- -'-_:'~~--k-,-, .,'\.- , C"_,'_'._ -- "_:; JUSTIN S, TAPPAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO. 2001- f1'fO CIVIL TERM JENNIFER L. T APP AN, Defendant : CIVIL ACTION - LAW : 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 , Pennsylvania, on the day of , 2001, 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 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 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: 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 HELP. THE CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 , . - ~-I ' ..j. -,'i ,._i'__, .' ~,-}<. ' : --'-'-""", ~i~i JUSTIN S, TAPPAN, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 2001- /9'/D CIVIL TERM JENNIFER L. T APP AN, Defendant : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Justin S, Tappan, an adult individual currently residing at 106 South 27th Street, Camp Hill, Cumberland County, Pennsylvania 17011, 2. Defendant is Jennifer L. Tappan, an adult individual currently residing at 300 North Arch Street, Mechanicsburg, Cumberland County, Pennsylvania 17055, 3, The Plaintiff is the natural father of the child, Paige Skye Tappan, born November 12,1991. 4. The child was born in wedlock. 5, Since birth, the child has resided with the following persons at the following addresses for the following lengths of time: NAME Jennifer L. Tappan ADDRFSS 300 N, Arch Street Mechanicsburg, P A DATES May 1993 to present Justin S. Tappan Jennifer L. Tappan New Cumberland, PA November 1991 to May 1993 6. The natural Mother of the child is the Defendant, who resides as foresaid. She is single, 7, The natural Father of the children is the Plaintiff, who resides as foresaid. He is married. , ~ -. -.- ':-";~',h,,''''"- '", , " ,~ - . ._'-'. ~'1.C'""n-~' ~, ,"" 'r--r'"---':';".,<:: 8. The relationship of the Plaintiff to the child is that of natural Father. The Plaintiff currently resides with Adrienne Tappan, wife. 9, The relationship of the Defendant to the child is that of natural Mother. The Defendant currently resides with the child and Mark Douglas, her fiance, 10. The Plaintiff has no information of a custody proceeding concerning the child pending in any Court of this Commonwealth. II. The Plaintiff does not know of any person not a party to the proceedings who claims to have custody or visitation rights with respect to the child. WHEREFORE, the Plaintiff, Justin S. Tappan, respectfully requests this Honorable Court to enter an Order scheduling the Parties for a Custody Conciliation. Respectfully submitted, Date: 4- 1-01 omas S. iehl, Esquire Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 ;- <, " it j.,._- ~". ,',H""--_' .,H~ ,~_.." ,--,,,,. "'"~. -, VERIFICATION 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. ~ 4904, relating to unsworn falsification to authorities, ~<-- .....---- ~PPAN, Plaintiff ~, ~- ~ '" 1:, J - ~- -\~i ~ JUSTINS. TAPPAN PLAINTIFF V. JENNIFERL. TAPPAN DEFENDANT IN TIIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 01-1940 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, April 05, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tbursday, May 03, 2001 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. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Hubert X. Gilroy. Esq. fI Custody Conciliator 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 1HE OFFICE SET FOR1H BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 "'it. 7. /f!#N 1/-& C( f1"6/)/ .,.. ,~, '1 - .- n= -j-' \\JT/\fiY "I !'i f'~ '") 1- JJ ['1" ',; ....0 , ' t'., < ,~ P;1 2: ~O CUj\~~~:HLr\;"~U CCU[\JTY PENl\!SYLV/\NL:\ ~ twf ~ ~ ~ a:It aJ1 ~ ~ ~~~- ~~~#-~~- , '=- , ,_ ~__._, .;l!J:TI ~ .,~"..Mfm!ll!!!Mll~!1IilItlI'ff~f'l~"'1I"''f!j'i'i''!Ii~~I~,;q'''''I&'''''''~W'''';O:~~1ffi!!1rn:~~~~~~~j ,.di- ~-...-." , ",[ 'J~ - ~ ~',-- , '~ .~ j~J~)j\ > JUSTIN S. TAPPAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001- 19rt CIVIL TERM v. JENNIFER 1. TAPPAN, Defendant : CIVIL ACTION - LAW : IN CUSTODY CUSTODY STIPULATION AND AGREEMENT THIS AGREEMENT AND STIPULATION entered into on the day and year hereinafter set forth, by and between JUSTIN S. TAPPAN, hereinafter referred to as "Father" and JENNIFER L. T APP AN, hereinafter referred to as "Mother". WHEREAS, the parties are the natural parents of Paige S. Tappan, born November 12, 1991. WHEREAS, the parties wish to enter into an agreement relative to custody and partial custody of the child. NOW THEREFORE, III consideration of the mutual covenants, promises, and agreements as hereinafter set forth, the parties agree as follows: 1. The Mother and Father shall have shared legal custody of the child. 2. Mother shall maintain primary physical custody of the child with periods of temporary physical custody belonging to the Father on alternating weekends, from 6:00 p.m. on Fridays through 7:30 p.m. Sunday. 3. In addition to alternating weekends, Father will receive custody of the child one weekday-evening every other week from after school until 7:30 p.m. during the school year, and 3:00 p.m. until 9:00 p.m. during the child's summer vacation. Father's weekday-evening of custody shall be decided by mutual agreement between the parties. 1 - , '~~ ."' "''!tit 4. Mother shall have custody of the child each Christmas holiday from noon Christmas Eve until Christmas Day. Father shall enjoy custody of the child from noon on Christmas Day until noon the following day. Father shall enjoy custody of child on the Thanksgiving holiday from 4:00 p.m. on the Wednesday evening prior to Thanksgiving, until 2:00 p.m. on Thanksgiving Day. Mother shall enjoy custody of the child on Thanksgiving Day from 2:00 p.m. throughout the rest of the day. 5. The parties shall have physical custody of the child on each parent's respective birthdays, from 8:00 a.m. until 8:00 p.m. 6. Mother shall enjoy custody of the child on each Mother's Day. 7. Father shall enjoy custody of the child on each Father's Day, and shall maintain custody of the child until the following Sunda.y after the Father's Day holiday, which would provide Father with one week of consecutive custody. 8. The parties shall alternate the holidays of New Year's Day, Memorial Day, Easter, Fourth of July, and Labor Day every other year. 9. Transportation of the child shall be shared by the parties. 10. In the event Mother relocates more than thirty (30) miles away from Father's residence, Father's periods of physical custody provided for above shall be extended by one (I) hour to accommodate the added travel time. The additional hour will be added to the end of Father's period of partial custody. II. Mother shall petition the Court for approval prior to relocating with the child at a distance greater than fifty (50) miles from Father's residence. 2 10_1 . -,,, '~ii'lli;j; 12. The parties will keep each other advised immediately in the event of serious illness or medical emergency concerning the child, and shall take any necessary steps to ensure that the health and well-being of the child are protected. During such illness or medical emergency, both parties shall have the right to visit the child as often as he or she desires consistent with the proper medical care of the child. 13. The parties shaH not do anything that may estrange the child from the other party, or injure the opinion of the child as to the other party, or hamper the free and natural development of the child's love and affection for the other party. 14. The parties may make such alternate arrangements regarding the physical custody of the child so long as they may mutually agree. The parties anticipate regularly varying from the terms of this Stipulation in order to accommodate the schedules of each other and the child. However, if the parties cannot reach a mutual agreement, the terms of this Stipulation and Order shall control. 15. Any modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and only if executed with the same formality as this Stipulation and Agreerilent. 16. The parties desire that this Stipulation and Agreement be made an Order of the Court of the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over the issue of custody of the parties' minor child who has resided in Cumberland County for more than six IIlonths and shall retain such jurisdiction should circumstances change and either party desires or requires modification of said Order. 3 j'~~ -' i -'1",1 ~' ~-' - ~ . -----,,"'~' i'~~ 17. The parties acknowledge that they have read and understand the provisions of this Agreement. Each party acknowledges that the Agreement is fair and equitable, and that it is not the result of duress or undue influence. IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms hereof set forth their signatures the day and year herein mentioned. {;iP Thomas S. Diehl, Esquire ..--;::::=> {o-r5'O 1_ ~ @ ~ DATE ~stin S. T an, Fat r, ~J lpJDl DATE AND NOW, this 21, day of ORDER OF COURT ~\J~ , 2001, upon presentation and consideration of the above Custody Stipulation and Agrcement it is hereby ordered and directed that it be entered as an Order of Court. BY THE COURT, J. 4 ~ !~!il~~~~m~liiifUliMMi~~\l1!lw..'ii'Jll;':li~1o'1i~I~l€;"-";'-fr:i""''':'Ws=lL$Mliii~"" ~~,l ~i> :-\ ' H " \.1 ~\\ c.,0~\\E;d \.,',tl.t\ 1\.'..--- ' ,..."--,,,\('\/'j 'J \~ ,.... r: '-,,('.\'-; ,'~" \i 1\ IV 'Nnf'r" .- ).,1\ ., \'.'oJ ~.(' '11 Gv' \ ~ }B\j 'GJ, ~~ ,- ~-" -"".,~ \ '(, '" \,"j . ~ \ ;: -,' ", ~_. .i_~1tlldii.~-~"" =, .. , -~_... "-! ;. I '-- ~ .liI " - -<~~,' . ' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS On this LS-P-!day of h...ve- , 2001, before me, the undersigned officer, personally appeared JUSTIN S. {rAPPAN known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement and acknowledge that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~/ '. ublic . Notarial Seal Kimberly L. Diehl-Hough, Nolery Public CarlISle BOlO, Cumberland County M Commission expires M 5, 2003 COMMONWEALTH OF PENNSYLVANIA COUNTY OF G(.lV\A.j,LtA P /1~ : SS On this ~ day of ~ ,2001, before me, the undersigned officer, personally appeared JENNIFER . TAPPAN known to me (or satisfactonly proven) to be the person whose name is subscribed to the within Agreement and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. NOTARIAL SEAL . MARJORiE A. DeLUCA, Notary Public ; South Middleton Twp., Cumberiand.Co. M Commission Ex ires Nov. 1,2003 5