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HomeMy WebLinkAbout01-03497 ~ ANDREA L. STERNER PLAINTIFF V. TRAVIS L. STERNER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V AN1A 01-3497 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, Juue 14, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicshurg, PA 17055 on Tuesday, July 03, 2001 at 11:30 AM 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 fnrnish 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: /s/ Dawn S. Sunday. 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 TOYOURATIORNEY AT ONCE. IF YOU DO NOT HA VB AN ATIORNEY 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 >.,;~ail!~~ '~,' ~, - , . -, , "~ ,;j~~A~~,",,,,,,,,,,,,!i}''';;'';F;W,,,l~,~~~,,,,..1filiillt;$-I!,l!l!iil:b0;'iif:;It{~-''';I'_H(\;,M';:;;!\iI~l;i~,''~~.Mf .~_~~~U"""<~~"""-" -" ~!llidlllljjif'~""~"'" ~ fIliMid tiil ;W"'T"fO,."'a "_.~.. _ ~~~~~, _~<=".,"",'_^~,_,^,~__ ~ /'rlf,tJl b'H~/ U 71-01 . , ~- ,"'-I"r,v ',) hnr p: /Iii'll i1 f'il' 'l, I,'" .," ~- '-.: -; - "" I t:.~. 4';; CUiv1w'::;::'r'! '''''I'U'' CrU'lTY ' ... ,--,~j, U'~ PENNSYLVANfA ' Q' S'J cU'f~~~~4~ ~~~~crddl. t~t~~ aIf ~ ~ ll!i " . , v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 0\-dI.197 Ciut~~ ANDREA L. STERNER Plaintiff TRAVIS L. STERNER Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this day of , 2001, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at , on the , 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 the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: Custody Conciliator 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 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, PA 17013 (717) 249-3166 . . . ,_,,,.> .Co'.. r',"-''' ~ .., __" -, -'.' ,.. - .' v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 01-3'197 Ct;;;J ~ ANDREA L. STERNER Plaintiff TRAVIS L. STERNER Defendant CIVIL ACTION - LAW CUSTODY COMPLAINT AND NOW, comes Plaintiff, Andrea L. Sterner, by and through her attorney, James W. Abraham, Esquire, Abraham Law Offices, Harrisburg, Pennsylvania, and files the following: 1. Plaintiff, Andrea L. Sterner (hereinafter "Mother"), is an adult individual who currently resides at 6300 Souvenir Drive, Enola, Cumberland County, Pennsylvania, 17025. 2. Defendant, Travis L. Sterner (hereinafter "Father"), is an adult individual who currently resides at 175 Turtle Ridge, Shermans Dale, Pennsylvania, 17090. 3. Mother and Father are the natural parents of Levi Travis Sterner, born January 8, 1997, presently four (4) years old. 4. The child has resided with the following person(s) at the following addresses since birth: A. From January, 1997 through May, 1999 with Mother, Father and paternal grandparents in Shermans Dale, Pennsylvania. B. From May, 1999 through May 22, 2001 with Mother and Father in Newport, Pennsylvania. C. From May 22, 2001 to the present with Mother in Enola, Pennsylvania at Mother's aforesaid address. :'f--'" _ ~. . ",,,." ,~ - ,. , - , . .. , 5. Mother has not participated as a party or witness or in any other capacity or in any other litigation regarding the custody of the child in this or any other court. 6. Mother does not know of any person not a party to the proceedings who has physical custody of the child or claims to have custodial or visitation rights with respect to the child. 7. The bests interests and permanent welfare of the child will be served by the entry of an order for shared legal custody of the child and by the entry of an order for the following physical custody schedule: A. The child shall reside with Mother and Father shall have the following custodial time periods: (1) Every other weekend from Friday at 4:30 p.m. until Sunday at 7:00 p.m. (2) Every Wednesday overnight, from 4:30 p.m. until 7:30 a.m. on Thursday, during the week prior to Father's weekend. (3) Every Wednesday and Thursday overnight, from 4:30 p.m. until 7:30 a.m. the next day, during the week prior to Mother's weekend. B. The parties would each have two non-consecutive weeks of custody during the summer and would alternate holidays. C. During Father's time of military service, Mother shall have custody of the child. J~n] '" , - ~ - . ~ - .' " WHEREFORE, Mother, Andrea L. Sterner, respectfully requests Your Honorable Court to grant Mother the relief requested herein as to the custody of the parties' child. Respectfully submitted: James W. Abraham, Esq. Abraham Law Offices 513 North Second St. Harrisburg, PA 17101 (717) 232-7825 Attorney for Plaintiff, Andrea L. Sterner DATE: 6/4/01 . ~. 1J~" . _ 0 _ _ _~" ., ,'" . r ,-- -~,- r" .", ~--'CC: . " VERIFICATION I, t\w::i/\O-lA.. l. S+er (~, the undersigned, hereby verify and confirm that I have reviewed the foregoing document and the statements therein are true and correct to the best of my knowledge, information and belief. I further understand that any false statements made herein are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities, DATE: rJ."fl/O/ _~JL 21:':,.,., - ,.,c _-'1''''' ~r , ,.. . . CERTIFICATE OF SERVICE I, James W. Abraham, Esquire, the undersigned, do hereby certify that I have served a true and correct copy of the foregoing document, by certified mail, on the date indicated below, to the following person(s) : Travis L. Sterner 175 Turtle Ridge Shermans Dale, PA 17090 DATE: 6/4/01 ~ - James W. Abraham, Esquire , ~f"""'''''' ,~_ [J , "~ r "e' ,,) '"'" " .1 > ~ ~.. _ _~_. n ~ ~, .~. ~ ~"" ,> '" - ~> - ~ ',-'Wok- , . ~ ~ "'<l. 8 8 <::> G s: <-.. " {;; fRo:> c:: ::;:J t? ~ 8 29-] ~ - '-- ....... 2:c;:- I . ,,-};} ...... ~ (/) > _:gt.~f ~O -<...-~ CT\ )J f""":-'.~ ~::~ (:, ~ ;::::.:l.J -- ~C ....., ',---,.. 0 -c'i :::a: -:'5JJ ~.. \~ ~,.",c" c: om f 2 ~ =< i1 .::- ::n -< '-.( ~~~ -~. -~" ,~~~ .,1~~1iIi""",,,~_ ,,,~~~~~~~"ffl"'.~;nm~nf;!5j"'''f'~i7%i'''''~'';i'f\'';il~!I."~~~'/'i';'~IN'~I'jli;;i~j!~I~1%'~~'fli1!l:W::,,-~i!iiji',~~~~I~- ~~ ANDREA L. STERNER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. . NO. 01-3497 CIVIL TERM . : . CIVIL ACTION - LAW . TRAVIS L. STERNER, . . Defendant . CUSTODY . ORDER OF <XlURT AND IDIJ, this \ 2-1 ~ day of consideration of the attached Custody and directed as follows: , 2001, upon it is ordered 1. The Mother, Andrea L. Sterner, and the Father, Travis L. Sterner, shall have shared legal custody of Levi Travis Sterner, born January 8, 1997. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to all decisions regarding his health, education and religion. 2. The Mother shall have primary physical custody of the Child. 3. The Father shall have partial physical custody of the Child in accordance with the following schedule: A. AUGUST 2001: The Father shall have custody of the Child from August 12 through August 19 and August 26 through August 28, with the specific times to be arranged by agreement of the parties. B. SEPTI!MBER 2001: The Father shall have custody of the Child from August 31 through September 2, September 14 through September 16 and September 28 through September 30 from Friday evening through Sunday evening with the specific times to be arranged by agreement of the parties. In addition to the dates specified, the Father shall have custody of the Child for four other days in September to be selected by the Father with as much advance notice as possible to the Mother depending upon the Father's military service orders. C. 0C'l'0BER 2001: The Father shall from October 1 through October 5 October 31, with the specific agreement of the parties. have custody of the Child and from October 27 through times to be arranged by D. Thereafter, the Father shall be entitled to have custody of the Child for up to eleven days per month, depending upon the :-~ "~ -, , , ~ ,. , " ~ - -~ =- , \)~~til*la4~~"(ili;,~fffi'!*~~~r...i;k".~_;,;ii^t-i.~-""""':,._k<,,.;;.J,,,,W0li.'""{,,,,,W,.;&;&&i<i:1e~~~iliilI_:tPJ,,,,-~".l..,j:.o..,, , ,~_~o;,:!,_.J,":_h ,~J..JJ!lJl~~"','lf';'~"''-r,,1''''''_~''1_'_'1,'''''"''~o;-0'.,-_~,,_,_w",?~, <"", ~ ,"'~, ~.1" _.". ,,,'__.<_..;.~._"' ~ (', ~ j ~ I " if; :~5 I) [rJj "d'I'v '-,- ~., JI.j I I':');:,\P, '("1"/[,:' if' ;:,"- _I \11'\0 J V;-\)\J!t-\ ~"'''-'~M . II . Father's military service orders. The Father shall provide reasonable advance notice to the Mother of his selection of dates for custody under this provision. E. After overnight periods of partial custody under this Order, the Father shall return the Child to the Mother's custody in the morning for school or camp on weekdays. 4. The parties acknowledge that the Father expects to be stationed in Germany and Bosnia for an extended period in 2002 and also expects to have a 14 to 21 day leave from duty during his service in Germany. The parties shall continue their efforts to reach an agreement as to an extended period of custody for the Father while in Germany on leave. If the parties are unable to resolve this issue by agreement, counsel for either party or party Pro Se may contact the Conciliator to schedule an additional Custody Conciliation Conference. 5. Neither party shall do or say anything which may estrange the Child fran the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Child comply with this provision. 6. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, J. cc: James W. Abraham, Esquire - Counsel for Mother> fl.~... ~ '/-/:1.' (Jj Travis L. sterner, Father ~ 9- '.,,, -" I~_~""". _, 0 " . ANDREA L. STERNER, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. . NO. 01-3497 CIVIL TERM . : . CIVIL ACTION - LAW . TRAVIS L. STERNER, : Defendant . CUSTODY . CUS'l'ODY c:c:.I!JCILIATIU\/ SUMMARY REE'CRT IN AcxnIDANCE WITH CUMBERLAND COONTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned CUstody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CIlRRENTLY IN CUS'l'ODY OF Levi Travis Sterner 1/08/97 Mother 2. A Conciliation Conference was held on July 3, 2001, with the following individuals in attendance: The Mother, Andrea L. Sterner, with her counsel, James W. Abraham, Esquire, and the Father, Travis L. Sterner, who was not represented by counsel. 3. The parties agreed to entry of an Order in the form as attached. ~ 9/ ':+001 Date Da~ CUstody Conciliator }i.. -" ,~, '-' 'to '-1'_,_ < ~ '."! ~," ,-'~ , to'