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HomeMy WebLinkAbout01-2621 FX ... " fYl. .' , .. .. MAY 0 2 2o.0t~ IN THE COURT OF COMMON PLEAS OF -r- /. e :},,51";1 CUll'he Rvl , plaintiff . . v. CUMBERLAND COUNTY, PENNSYLVANIA NO. grIJ/tJ 01- dIP;) ( CIVIL TERM : ! J5e I) ./,,, fl,<< I , Defendant : CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at on the day of , 1996, 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. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. By the Court, 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. COURT A NISTRATOR, 4 LOOR CUMBERLAND UN URTHOUSE CARLISLE, VANIA 17013 TELEP NUMBER: 717) 240-6200 c..um'oe.'('\o,\I'\.d CDU(\~ ~'(" f\ssoc.. ~ Li 'oe..'('~ A\l-e.nv-e.... (A(" \\ s It..- ?A \ 'Ie 13 d4q -.3 \ lol.o 30 ;;"'". " 'J-; "" (, ~_ - 'I'T. ,"", I - ( -" f ;;'J')~~ 5j,.,,,,e d./ VS, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA , .& 11 4_ IL I : NO, CIVIL TERM NOTICE TO DEFEND TO THE RESPONDENTS NAMED HEREIN: You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Petition and Notice are served, by entering a written appearance personally or by attomey and filing in writing with the Court your defenses or objections to the claims set forth against you, You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Petition or for any other claim or relief requested by the Plaintiffs, You may lose money or property or other rights important to you, 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 Two Liberty Avenue Carlisle, P A 17013 (717)249-3166 Le han demandado a usted enla corte, Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partie de la fecha de la demanda y la notificacion, Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objectones alas demandas en contra de supersona. Sea avisado que si usted no se defiende, las corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda, Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted, :;;::,1~.[. ; . " ~"- , - .~ ,. .... ~ J' )",5 Tin 1- 0 I , Plaintiff L-"jene rc.~. v. : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, P~NNSYLVANIA : NO. 96- CIVIL TERM /3e#. ",{.... ~,j , Defendant CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is J;:d;. E...N'n<, J2~ I , residing at , #AI c"'~h/LJ 4' /707tJ. lilY 5// f/ Z,.,/ /6,1/ 2. The Defendant is lSt"// A.~ ~"'/ tp /./ ?I,/..~&~';' S/ jrf,d' ~ /7.yotY , residing at 3. Plaintiff seeks C9ustOdy) (-pal: tial slishay) ('.'isitatiel'l) of the following child(ren): NAME PRESENT ADDRESS AGE ~t'.....6,wk,c/ 5J.,-/6v EI.,;,,, ~.../ y/y .1',,/ S/ Z",./ r,%a/ ~ /707C) g / '//'1 3// S/ ?".ll%or #"'-' {'",_t.",.A_/ sI iZi:"k. &,("e"", B~/ ,0" /?O"'" n /L L / I? / //~ ~ , 5' /1. / ~/ 4/"".1 <:..,.,6",~4-./ 'I LAi /rtJ" "" r...~ . ", oJ/V r hd +;1"0-' /->", 17",70 The child(ren) "",;Cwas no born out of wedlock. The child(ren) is presently in the custody of 7:",/", ~~",....,q,~/ , who resides at 1//1/ :]',--/ 5~ ?,,/ .qY"""" MN t",.......fy,.-k;/ld /~ /7070 During the past five years, the child(ren) has resided with the following persons and at the following addresses: LIST ALL PERSONS :;;;5'k~ h"j t'n" ILl 8e/1 4,,,, ~""'/ ADDRESSES DATES fI'I.?/./ J'/ ?J,,,/ /;;ur' ftf", !;",,I,./,{,.,/ /0-.1',;- ';9'/-/1'; /~ /7070 tl.l ~ ?'/'~A&"a f/ /if",! .4 /7WY '1-1-11- /<:J -Jo-f The mother of the child (ren) is J.}e /,( 4." ;::: ~/ 26 :-~~-,- --~ . '".."- '111 r" 1 - 'I, ~ currently residing at t /3' /J ~_',4A.?4, ~ 5/ ft/L ~/7f/(1V She is (sing1e)(marrie~(divorced). The father of the child(ren) is J{J"~;" currently residing at f/!c; .7,--/ 5/. ?h/ /Yo",--. He is (single)~arrie~(divorced). 4. The relationship of Plaintiff to the chi1d(ren) is e",,,,,.,,,, /"~/ , / #r:w Cup? &erk,..-,J ~ /7b"?O ~~'e~ The Plaintiff currently resides with: NAME RELATIONSHIP L"",/c< j(",7 041""'-'5 :;;51/" p O'"''''~ $ ~cob P O<->c/>5 /ltiy<U.,o<<y , /,"'--"'~"4r5- (h./~ ;t14Nuh"4A y s Ch_ 'l~ / 5. The relationship of Defendant to the child(ren) is AII#r The Defendant currently resides , with: NAME t;,/tam 4/.,,,./OVJn-> ,/ RELATIONSHIP /"=".., ..,It? 6. Plaintiff ek _) (has not) participated as a party or witness, or in another capacity, in other litigation concerning the custody of this minor child(ren) in this or another court. The court, term and number, and its relationship to this action is: Plaintiff (~(has no) information of a custody proceeding concerning the chi1d(ren) pending in a court of this 27 --~T_, , = I ' 1 ~ ""! c, ,"-' I ','I ~ ,. J ... I Commonwealth. The court, term and number, and its relationship to this action is: Plaintiff (J..__s) (does not know) of a person not a party to the proceedings who has physical custody of the child(ren) or claims to have custody or visitation rights with respect to the child(ren). The name and address of such person is: 7. The best interest and permanent welfare of the child (ren) will be served by granting the relief requested because:Jh~J(, IN''' e;"J "or"" 4e .;f?.r,;"'''',?, re:Y)f/t./PY,4'ki'J /.r41u';'/';-'J ., si,/~-Ioh' 8. Each parent whose parental rights to the child(ren) have not been terminated and the person who has physical custody of the child (ren) have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child(ren) will be given notice of the pendency of this action and the right to intervene: NAME ADDRESS BASIS OF CLAIM WHEREFORE, Plaintiff requests this court to grant (custody) (t:!'r'lll . -){ e'I.!!!1 1,)' . 8i '!<"Y.' --) of the child (ren) to the Plaintiff. Respectfully submitted, 5"'-2-2001 Date ~L ~f'/~ b /' Plaintiff 28 ,It". , ,.,,~ " , < ~ ~=I !' ,..c_ , . " , ' . 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. ,;/T~ ~ ~ Plaintiff 29 I"~"r'" ~., e ' "p," _~_, -', , 11' ., -~,' '-.~.. "i '" ~ c - '1- ~S~ ""',0.:"',-,,' _ <'..:-', ~" - '"We"''-,,,,"__, ""'. '." '~'~;,~';";;;;-'- ,-\-"; n~"""'''l'''"=r-Y~ - C) c;:, C ;?": "1J .... -:.... -- rng" " ~ .";:.. 0 ~:J,~~: .._.;: \t. a ~-c;.. I < F2;:~f "I r,,', "- C <l." " ec' :~" 0 '-'.,. ..", L. .' ,,~l-... '>J 'S),. >~~ "" ~ :z: ::<! ':.> B <-- ('> ^', VI ..:0--' I" )_.~ t~iY? -..1 .,.~ :-0 -< .-- .. f'TliillTr ., .. , , lJ 'f) --S:d p .~ ; +. ::;J, "--, , .iT1 ,~'~!:r? J-,_J '-,- ',- - ,. .." :'~~~~%~~'lliW~I"\;W;,r.tW'l;J'"W"'_!,~~~~"f4fW'!Wo'o;;-;'"~-,,,,:",;'<;,:""""",'"""'i;;(.o',-,,,,,'" """'r'''f~}'Vii;"j~2~,,'i'<;1!;,F'!'J,~'h1'"';j;'eJ'-'' 'f:''(iN'''i'illl':qlWJ~~,,+:;m!\ii)!1'''," .. mSTIN EUGENE PAUL PLAINTIFF V. BETH ANN PAUL DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-2621 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, May 09, 2001 , upon consideration of the attached Complaint, it is ,hereby directed that parties and their respective counsel appear before Melissa F. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp HiU, FA 17011 on Tuesday, May 22, 2001 at 11:00 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 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 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 Melissa P. Greevy. Esq.b? 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 THIS 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 ':;,'iM,l:1 JJ~! ;-. ~,< -, - -. 1-1 ii ~ ~." J__,~~" - ,r . - >>- ~<' ~io<',"_,,' ~,'h "-' -~- ^' '"'''';-Of'-,'-' Ok' .'" -w,)' ,,- :0";'- '-IC-"'_I~- ~ - -~'~llImJ][m-I:tl:lil.. "'~-"'~"-" ~-P-P~~ ~ -f2' ~'~}t', R -;2 ~w- ~? - r?? "- , " Y!~t;'lnASNN3d -"-Lilli ,C):; c}\!:;n,~!:::8;IVno gCi .:> "d I"v t'j,~, 1';'11 Jbil,} 10 ' ":Ow I JCI , 1r;7-W-/, II? -01)7 Iff' . (Z/;Y ~\M;~,M A,Ji~H'I-~". ... _=. 4"W'-".lm~!lJWijj:>j'~R'Jt%'f"if~';'~i""'O:_'0"'~'''W''''?_''f\''F'~''>:"0'W~-'1Y':"_"'''''P'''W''''~i'__,"~';;;&'!l'!"P)\''~[;~'~1<'_''-''h'",'R''''!'''i'li!F@!!fl'!'}TIi'''&BW1'i'1'l''l~~- J..s/'.-. E~J<~e ?<,,j v5, /1:17 ?, LOP} 8,,-I/' A",~ p"",/ p......"",,+ 0+ )e,/<.Hc<::, M. 0/_2&2 I (r.url lC.,....1<'1 ,,-.q/I. //,,,, / ..z- ,( c../<< "" ./"'<,L../ :5er-'t<PJ ;I 'B", /1. /tI"'7 :;:51_ 4.-.~ F~f"nc ILl ,P...~ I c".",/ r. ,,0/ a rl./}"./ Z.. 7oot' /,,' r' o....,,,,o/'.:;<:"'r ,(L/ 2<,,1<",// '" -",,{,o-f on . J. , .. '-, , J::S',!,:... E/~~e A,.I P- ~d/'. CJ ,..... -" M CJ CJ CJ ,..... 0013 02 Postmark , -.-Here. co ,.-" .M "... c ."- .Return ReceIpt Fee .-"I (E::ndorsementRequJred) ~ RastnctedOeliveryFee i (Endorsement Required) iIli (~ l , 1 ,~_,>,.",~" .,_ _ ~.< '"C"'"""",''C'""" " f"~ :1~l1!""., ",.. ., ,p 'i';l(j\~.r 111111 T11Urr ',"'m;n c' (') C:. ..e: --oce f'll'" Z'~' :z:C 0) ,", r~~: <- J;>oc ~(::: ,PC:: Z ~ -' :J!: $"" -"" ::ll). \ 1'0 --.., ::.~ o -\1 X~ C:;J -'; rC'") ,~ ::-\-~. ,'"., ~;;';"::{1 ;;? :~\ sS -<. 0) (.n ~'W~~\O:S;!>'2""" ",1.{\'",""" c,:. 'i'''N0"!",'",-,<,;,-~~,;;''''"';i'!''':'''';A'';''~'lJ'~''',W.'H'~l'c'f;,,;',"<1,0,_ ,"""i"4':;:;/lj!lfo';'~H"*:\~"!'ifMl~,,,- AVAILABLE 24 HOURS CONS~ABLES OFFICE 515 W. MARKET ST. YORK, PA., 17404 PHONE (717) 846-9863 QI,.(j(P')/ .(,., ,''',. ,,! i~ Kelly Deardorff Keith Deardorff RETURN OF SERVICE- I, Io~/ I. b-11f:IJOe#" , personally served a ,COPYJOf the attached /~uf '-'~..k' . on &rf/ ;:1/1/11/ 'tJi..ol by handing hi~ acbpy and leaving the copy with hi~on, the, fX.:j/V) day. of ~. ,~,at 5-'3/] ~ at the location of 3tjoQ (bMZJbl ti fIr' j2 )7</02 . served a copy of the attached for on the day of ~:~: at the location of . It was left with the above person I, on ~, W 199 at because that person was . . , I verify that the statements in this return. of service are true and correct. I understand that false statements herein are made Subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities.' Date ,?~p.'I-~/ ~,~ .. . gn re tf"''' . '"' ~'~~''4''''''''''m~ . n , - ~ ".~ ~",""",,-,,",,^ N", 1iW'~,-1 -",- 1.-' ,~" "~"~"'C-',,,,o,-,-,,_ ,-,--,,,"."d__-","d_,ot~;.'.,~~__,,,c'_ '''",''J'"'I~,,\Oj;.''J- ~"- ~,- ~-"--"'{"'-11'rT'fl' . f"'1~ !, ,I """ (') Cl 0 '0 C ." ~ ' -'j C- ~;:,j ",' -," "UC:O c::: ~i-:JJ ~m z .-- ~~ I ...,.."fll ""9 .c. ;;-< ~~-O KG -U :I:~ i~ ::ll: q(') W Om Si W ~ ..... ~ - V ~~~'~l'__'~"C"!"'."?O"ij~j'I~_'jlwgi,,"WI~;'l,>WlW'''''!al\'.I~~'!!I~,r:f8i';:k'-'''',~"''''''';i;'';;', ',F" ""If'("~~,,'~)b':"':;;-"':~'"~--]-::"" -;~";~""-q;J-:11:;;:,,~,'S,,,-q")iil',,!,,,"~.[i";1'W~1it\~~~j'i;!!i!I~J , " '\~," -' JUSTIN EUGENE PAUL. Plaintiff, IN THE COURT OF COMMON PL,EAS OF CUMBERLAND COUNTY, PENNSYLVANIA V, No. 01-2621 Civil Action - Law BETH ANN PAUL, IN CUSTODY Defendant. ORDER OF COURT AND NOW, this 22nd day of May 2001, it is hereby directed that the conference previously scbeduled for t.'lls date is rescheduled. The p'lrties and their respective counsel appe~ before Melissa Peel Greevy, Esq.,'the conciliator, at 214 Senate Avenue Suite 105 Camp Hill, PA 17011 on the 4th day of Jun~12001 at 1:00 p.m. to reconvene the Custody Conciliation Conference, At such conference, an effort will be made to resolve the issues in dispute, and to enter a temporary order, Failure to appear at the conference may provide grounds for entry of a 'C temporary or permanent order. 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 individual having business before the court, please contact our office, All arrangements must be made at least 72 hours prior to any hearing or business betore the court, You must attend the scheduled conference or hearing, YOU SHOULD TAKE THIS 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. 4~ ~ Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 e;j)/f 4 ~ tP~ S-;J3-o{ 'o:,,_,,_~ -F ~ _.~--' I I 1 ' r-' , .- '",~. ~~ ... '" '~~ . , '.iI' . mSTIN EUGENE PAUL PLAINTIFF V. BETH ANN PAUL DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . 01-2621 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, May 09, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, FA 17011 on Tuesday, May 22, 2001 at 11:00 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 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 the conference may CO provide grounds for entry of a temporary or permanent order. The conrt 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 Melissa P. Greevy. Esq. ~ 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 THIS 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) 249-3166n.UE COi,~1 r~:r':\j l'\ICC',Rn In Testimony ',,:h,r:.oi, : here untJ set my hond and 1hG seal of soid Court at Curlisle, Pa. This ..A?.... day of.~......,... ~1.. ...............,~.....,1;~f1,;yW i;,,~ , o,~ _ ~ ~ I, 1 ~ I . ... f'; ~...... . .i . . ... "'t", . MAY 0 2 2001 ff' ) J !, , ,/~'Fh<' I..j VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . J /./ " II JN1 Ii,,, : NO. 0/ - ~&;) I CIVIl:, TERM NOTICE TO DEFE;ND TO THE RESPONDENTS NAMED HEREIN: 0"'" , "",." . . You have been sued in Court, If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Petition and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Petition or for any other claim or relief requested by the Plaintiffs, You may lose money or property or other rights important to you, 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 Two Liberty Avenue Carlisle, PA 17013 (717)249-3166 Le han demandado a usted enla corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partie de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objectones alas demandas en contra de su persona, Sea avisado que si usted no se defiende, las corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda, Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. r" '~\ ! ~ ~Jii!ll!~, -<', ' ,,' < _,_", ,_c , _ ,,,.,___ /'" '1'"( T ~ _.J_ . ,~ .,.. ~ "., IN THE COURT OF COMMON PLEAS OF .r,) /t," {'i"'" /;~,J , Plaintiff v. CUMBERLAND COUNTY, PENNSYLVANIA NO. __ CIVIL TERM i3, II, ,I." ./ ( J.. "'" , Defendant CUSTODY COMPLAINT FOR CUSTODY o f: ....., ~. ~:l: ~,-' ~-.- ~"? i- ,,' resid~'ii'g :."':: ~--, '"'' '~.IP " 1. The Plaintiff is ;::",1,. ["",,,,,,, (:?~ I / I ae',: "'''. / / /1/ . / . 1 .-:'? !fLy 5,.." .5'/ ,?"I /~,// /l1-nl ("".~<,,'k""<,1' /., /7070. 2. The Defendant is 6('/./ ,/!-", ~,,/ hI U ;/A, /'.~..1(c7/'C, S/ J(,/ L ;? / 7'7'0(/ 3. Plaintiff seeks (custody) (.)?tl.:ttia1 eustosy) (vi!3it~tion) ~"., ". >~:.; --- , resiJing~t S' of the following child(ren): ,~ W NAME 5J."/hv FI",;"" / /L/ PRESENT ADDRESS AGE ~ ~ (.......6r,t..'/"...o=.f flY ..$'",/ f/,?,j /j(,,,/ ~ /7070 g 1/1,/' 7"./ S/2'"./ 1-/0,.,.... 11.1'.,,--, <;.,,_6/r';<..,/ Ii 71 oJ. .. .P~ ..... 7cY7C' 7' 'ILYJ. /"'-//. /<'/ <v-;,./<:"~6..,.....,../ LU '_[was n~t'> b~~n-'~ut~t-;~dl~~k~70 / a k dd. & n'"" /Z ~./ Dc./f,.,,, L,,/ /~~/ The child(ren) The child (ren) is presently in the custody of 7:,,1.... c't.;/'.-n/;::;'" / , who resides at 9'1!I I.'c/ 5/' ;:,"'/ .t%",....- .;(..1-,..> /.,,~ 5',-,.-k; /Ie.! /?, JJD7iJ During the past five years, the child(ren) has resided with the following persons and at the following addresses: LIST ALL PERSONS k.>L. h..e;l"~f' ILl / 6c' /1 d,~ /Z"j ADDRESSES DATES JIll f"j.r//-,,.../ /,t"r./I1;vfu"'j,...,{,,/ /oJ,) 7'7;;:;1 /"4 /7(.)70 ell {!, ?1.J.~&h.Ci.5/ /(,/.! /}17Wy 1/-/-7l_/,).k; ,~, ~ , The mother of the child(ren) is J}{,//, ~n f?~/ 26 . '-'.- . ~,"" . c -,J'~~ I _ ~ . cunently residing at tiS U //,,/;/:'/'''.1,. c: 5." /(~:/ I 4 / /yv y She is (single) [rnarried) (divorced) . The father of the child(ren) is .7:,/". cunently residing at 1//'1 h.l J/ 7,,,/ //0.". He is (sing1e)~arrie~(divorced). 4. The relationship of Plaintiff to the chi1d(ren) is ;:;'I/'~,.' The Plaintiff currently resides with: C:'.'S'<'"", /"{" / , ~ . " /' / /l;.'.~<j (U/f:l t~'1 k.,.")c ( .;:; /h'/" NAME RELATIONSHIP Le:~"'f"r:t l/ ^(.,<../ . C.1t""C"')j ./J t: """'{ rl) (oJ i-t /~ ;::; /, :- /C? c/ P.~L" r' S; '/,/ "/,, .,.. r /, ./c,/ L.1.:"i "<c., 0'7' c.t , Y :k" c,j, P U>-..>('ny Pt;/':;/'h,:I."T 5 , 5. The relationship of Defendant to the child(ren) is ,/Itll{?/ The Defendant currently resides , with: NAME 0'//'0'" /.../".j uv~" / RELATIONSHIP rc:t:),;I-1 c;.Jt? 6. Plaintiff (h~b) (has not) participated as a party or witness, or in another capacity, in other litigation concerning the custody of this minor chi1d(ren) in this or another court. The court, term and number, and its relationship to this action is: Plaintiff (~(has no) information of a custody proceeding concerning the child(ren) pending in a court of this 27 ]~-,-,-,- I ~.."- --"I , <,-.." I ~ ~ e J ,~)f^^, . Commonwealth. The court, term and number, and its relationship to this action is: , Plaintiff (JL"~5) (does not know) of a person.not a party to the proceedings who has physical custody of the child(ren) or claims to have custody or visitation rights with respect to the chi1d(ren). The name and address of such person is: 7. The best interest and permanent welfare of the child(ren) will be served by granting the relief requested because:J-4"~I' iN" <ole.! ':;0" //" .?'/. ~<>/v /c;, <"<",./f",,./,'/.;t) //~!urt,,,,, . ',.,. .,/ ") 5"'//10 -1~, 8. Each parent whose parental rights to the child(ren) have not been terminated and the person who has physical custody of the child (ren.) have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child (ren) will be given notice of the pendency of this action and the right to intervene: NAME ADDRESS BASIS OF CLAIM WHEREFORE, Plaintiff requests this court to grant (custody) (tallJilill~!H'Y S'.lllt;c.d}) ( i3i'tAtiBR) of the child(ren) to the Plaintiff. Respectfully submitted, o--Z', 7, /,,' j' .ct/vl Date ZL Q . / / t" . " ,,-, -'.-r-,.;7L.hf'" ~ ./ ,/ Plaintiff 28 .--''': i"" , " ,'~ J ,1 -" ,. , "to- .-, ; !' o ,~, w '": ~, . . I ve~ify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subj.ect to the penalties of 18 Pa.C.S. ~4904 re1at;ing to unsworn falsification to authorities. ,1!~ ~?~.? ~/ /' ... Plaintiff 29 "1' ,- "1'-', I, " I =~ ~ JUN 1 4. 2tJOJ bP ttr . I Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 01-2621 JUSTIN EUGENE PAUL, vs, Defendant CIVIL ACTION -LAW CUSTODY BETH ANN PAUL, TEMPORARY ORDER OF COURT AND NOW, this t ~ ~ day of ~ ' 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. LeQal Custody, The parties, Justin Eugene Paul and Beth Ann Paul, shall have shared legal custody of the minor Children, Shelby Elaine Paul, born August 23, 1992; Dakota Eugene Paul, born June 6, 1996; Dalton Lee Paul, born June 6, 1996. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion, Pursuant to the terms of Pa, C, S, S 5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. 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, Primary physical custody of the minor Children shall be with the Father. Mother shall have partial physical custody arranged as follows: A. Alternating weekends from Friday at 6:00 p,m, until Sunday at 6:00 p.m, to commence on June 9, 2001, The weekend schedule may be altered to include Father's National Guard duty weekend, B, Father shall provide a copy of his National Guard schedule to the Mother by June 7, 2001, and annually within seventy-two hours of receipt thereof, 3. TransDortation, The parent whose custodial period is beginning shall be responsible for providing transportation. 4. Holidays, Holiday custody shall be arranged as follows: A. Christmas, Mother shall have custody on December 24th at 10:00 p,m. through New Year's Day 11 :00 a,m, each year. i'- I ~,' , I' 1_' I' No. 01-2621 B, Independence Day, Mother shall have custody for Independence Day at such times as the parties may agree, C, Easter. Father shall have custody for Easter in odd-numbered years and Mother shall have custody for Easter in even-numbered years. The custodial period for Easter shall be from 9:00 a,m, until 9:00 p,m. D, Thanksgivinr;l, Father shall have custody for Thanksgiving in even- numbered years and Mother shall have custody for Thanksgiving in odd- numbered years, In odd-numbered years, if Mother's custodial weekend begins the Friday after Thanksgiving, she shall have the custodial weekend from Thanksgiving Day at 10:00 a,m, until the Sunday following Thanksgiving at 6:00 p,m, 5, Vacation, Each party shall be entitled to up to three weeks for the purpose of summer vacation, not more than two of which shall be taken consecutively, unless otherwise agreed, Two of Mother's vacation weeks shall include Father's two-week annual training with the National Guard, Mother shall have custody from June 13, 2001, through June 30, 2001, while Father is on National Guard duty, The parties shall provide no less than a thirty-day notice to each other with regard to any vacation time which they may plan to take, 6, Whenever possible, the parties shall give each other at least a seventy-two hour notice of any changes needed to the we.ekend schedule. 7, Father shall file a Proof of Service with the Prothonotary's office indicating that Mother has received notice of the Custody Conciliation Conference which was held on June 4, 2001, 8, This Order is temporary in nature, If Mother is aggrieved by the terms of this Order, she may petition the Court for modification and an additional Custody Conciliation Conference will be scheduled. J, Dist: Justin Eugene Paul, 414 Third Street, 2" Floor, New Cumberland, PA 17070 r\\~ Beth Ann Paul, 613 W. Philadelphia Street, York, PA 17404 -;.0 \ \.~ ~\".O\ <'11"'" .."',- ~-- --- ",.=- -, , -I-?,' ~ ~ -, L r ::;. '"" ". "-' r",' ,~ "~ " 1f\N':!i\lt\S~~N3d , },lI'-lnCO C1\,\cf1t':];;W'h I:) .. ,. \ ,vW In _, \, <:; I I U ,-e.\ \'^O ., I,ll ~J;J' . \1.., ,-, J) IIMI'O"I!"..'d,:,. _,Ill f\O'i,J;. 'i\v-j L,-;.:' ,;-.-.'\iJ -1",\.....,11 \~\ tJ ~:J ~J\.J ~1_..... ' ~ <: I - - ~ .,w_ "-4~--' "',,,,,,,-,,- .,.'",',..,- '':'- '''^J>"j{;\",,".,~,,;. ,."'~""'~'"'*">--<" -'-"~"''''"''''''Jlnl''-''-H'''-'>-'1t4r '. _~._~."" r.,~~~~~[;f-W~'-1\1"'l:>~'i'Wi'nlE+Wll'fl!'!1-I1~q\'t~'~1'!~~Ifi.l\1lill~~_ ~__._,", ..~F__"_,, ,,~ ". . .' . Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 01-2621 JUSTIN EUGENE PAUL, vs. Defendant CIVIL ACTION - LAW CUSTODY BETH ANN PAUL, 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 are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Shelby Elaine Paul Dakota Eugene Paul Dalton Lee Paul August 23, 1992 June 6, 1996 June 6, 1996 Father Father Father 2. A Custody Conciliation Conference was held on June 4, 2001, with the following individuals in attendance: the Father, Justin Eugene Paul, who appeared pro se. Mr. Paul appeared at the Conference and provided the Custody Conciliator with a copy of a Return of Service executed by Kelly Deardorff of the Constable's office in York, Pennsylvania, The Return of Service indicated that the Defendant was personally served with the copy of papers provided which included the Order scheduling the Conference and the Custody Complaint on the Defendant on May 23, 2001, The Custody Conciliation Conference was delayed in beginning and Mr. Paul remained at the Conciliator's office until an hour and one half following the designated starting time of the Custody Conciliation Conference, During that period of time the Defendant did not call or attend the Conference. Neither did she send a designated representative to the Conference, In as much as the Conciliator is satisfied that the Defendant has been served and has not attended the Conference, a Temporary Order is attached. uli2L&Y-\ Melissa Peel Greevy, Esquire ' Custody Conciliator 0//J/0 ( Date f ."i~ , ~ "_~~'_>;C,~' '__ ,~ ". -'-'< ".,. " 1" ,-.-- .. I '-1 .~ Sf?14 Modification of Current Custody Agreement ,4,h) ? c21--Z-6Z-1 Cumberland County Court, PA NO. 01-2621 Dated June 14, 2001, Justin Eugene Paul vs. Beth Ann Paul Modification of current custody agreement is signed and notarized by both parties concerning children: Shelby Elaine Paul, is now 18 as of Aug 23, 2010 Dakota Eugene Paul, 15 residing with Justin Eugene Paul Dalton Lee Paul, 15 residing with Beth Ann Paul Please review attached documents for Modification. Beth Ann Paul / Jus ' Eugene Paul i _J F, Y1// COMMONWEALTH OF PENNSYLVANIA NOTARIAL. SEAL William H Hostler, Notary Public Stewartstown Borough, York County My commission expires December 04, ZOl1 Agreement for Custody and Child Support Agreement for Custody and Child Support between Beth A. Paul and Justin E. Paul concerning the following children: Dakota Eugene Paul, age 15 Dalton Lee Paul, age 15 Considering the best interests of our children, we agree to the following Custody arrangement: 1. Both parties agree to joint legal custody of both children. 2. Physical Custody agreed as follows: a. Dakota Eugene Paul shall reside with Justin E. Paul at 2676 Laurel Run Road, Landisburg, PA 17040 b. Dalton Lee Paul shall reside with Beth A. Paul at 31 Highland Manor Drive, Stewartstown, PA 17363 3. Visitation will be liberal in nature. 4. Both parents have the right to make major decisions affecting the children, including but not limited to; authorization for major medical or psychiatric care, educational placement. Each parent has the right to receive and inspect all school and medical records. The parent having physical custody will be responsible for taking the child to any regularly scheduled medical or dental appointments, and handling any emergencies. In an emergency situation, the permissions of both parents are unnecessary. Concerning Child Support: Each parent having responsibility for a child, both parties agree on the following: a. Justin E. Paul will maintain health, dental and vision on both children. b. Beth A. Paul will maintain Medical Assistance for Dalton L. Paul c. Both parties have agreed on child support in the amount of $30.00 per week to be paid to Beth A. Paul. Both parties agree to withdraw from Domestic Relations services, to include any arrears owed. d. Justin Paul will claim Dakota, Beth Paul will claim Dalton for income tax purposes. e. Any medical, dental, vision, or psychiatric bills not covered by insurance will be shared 50/50 between the two parties. f. Any expenses not provided above will be discussed and agreed upon. g. We agree to review the support needs of our children annually. This agreement between Beth A. Paul and Justin E. Paul is effective August 1, 2011. COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL William H Hostler, Notary Public Stewartstown Borough, York County / A My commission expires December 04, 2011 Beth A. Paul Justin E. Paul JUN 14 700fr -f JUSTIN EUGENE PAUL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01-2621 BETH ANN PAUL, : CIVIL ACTION - LAW Defendant : CUSTODY TEMPORARY ORDER OF COURT AND NOW, this +h day of 'J ?? , 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. L=al Custody. The parties, Justin Eugene Paul and Beth Ann Paul, shall have shared legal custody of the minor Children, Shelby Elaine Paul, bom August 23, 1992; Dakota Eugene Paul, bom June 6, 1996; Dalton Lee Paul, born June 6, 1996. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terns of Pa. C. S. § 5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. 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, wlth the other parent within such reasonable tide as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Primary physical custody of the minor Children shall be with the Father. Mother shall have partial physical custody arranged as follows: A. Alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m. to commence on June 9, 2001. The weekend schedule may be altered to include Father's National Guam duty weekend. B. Father shall provide a copy of his National Guard schedule to the Mother by June 7, 2001, and annually within seventy-two hours of receipt thereof. 3. Trans lion. The parent whose custodial period is beginning shall be responsible for providing transportation. 4. Holidays. Holiday custody shall be arranged as follows: A. Christmas. Mother shall have custody on December 24"' at 10:00 p.m. through New Year's Day 11:00 a.m. each year. No. 01-2621- B. Independence Day. Mother shall have custody for Independence Day at such times as the parties may agree. C. Easte - Father shall have custody for Easter in odd-numbered years and Mother shall have custody for Easter in even-numbered years. The custodial period for Easter shall be from 9:00 a.m. until 9:00 p.m. D. Thanksgiving. Father shall have custody for Thanksgiving in even- numbered years and Mother shall have custody for Thanksgiving in odd- numbered years. In odd-numbered years, if Mother's custodial weekend begins the Friday after Thanksgiving, she shall have the custodial weekend from Thanksgiving Day at 10:00 a.m. until the Sunday following Thanksgiving at 6:00 p.m. 5. Vacation. Each party shall be entitled to up to three weeks for the purpose of summer vacation, not more than two of which shall be taken consecutively, unless otherwise agreed. Two of Mother's vacation weeks shall include Father's two-week annual training with the National Guard. Mother shall have custody from June 13, 2001, through June 30, 2001, while Father is on National Guard duty. The parties shall provide no less than a thirty-day notice to each other with regard to any vacation time which they may plan to take. 6. Whenever possible, the parties shall give each other at least a seventy-two hour notice of any changes needed to the weekend schedule. 7. Father shall file a Proof of Service with the Prothonotary's office indicating that Mother has received notice of the Custody Conciliation Conference which was held on June 4, 2001. 8. This Order is temporary in nature. If Mother is aggrieved by the terms of this Order, she may petition the Court for modification and an additional Custody Conciliation Conference will be scheduled. BY THE COURT, Dist: Justin Eugene Paul, 414 Third Street, 2nd Floor, New Cumberland, PA 17070 Beth Ann Paul, 613 W. Philadelphia Street, York, PA 17404 TRUE COPY FROM RFC10RD In Test' ny whereof, I here tinla sti my hand end t e I of said ©u at Carr e, Pa. This .....C..