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Home My WebLink About01-05862 . . STEVEN B. CLARK PLAINTIFF IN TIIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 01-5862 CIVIL ACTION LAW KRIST! J. CLARK DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, October 15, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqneline M. Verney, Esq. , the conciliator, at 4th Floor, Cnmberland Connty Courthouse, Carlisle on Wednesday, November 14, 2001 at 9:30 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 furnish any aud all existing Protection from Abnse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to schednled hearing. FOR THE COURT, By: Isl Jacqueline M. Verney. Esq. ~6t\ 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 HA VB 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 ~C~W~r;! r ~~. " - '~I- '1 .~ i '~'7 T~ ~~-~ 1;:"~~",i;~H;;:",Il;"!""-..y_,, "~-~,j,k(;,'",_,~,",,,,&'Ii;.,,",,,, ,;..,"_,,"'~~'h~.,'i"""'N)"~,.,j -'._. -"_",_,,,,'o'>_~"'$-,,,,"";!'.;:~~,,LHhA"<lif.,;;;1,'T1~~i.j~ll~l!!jb-U,l.l""("r"';;#!~~.~;~.~'!:lllIftlli.I:!<;l~~~~....~ - . "WI!;:lllilI"-<~" ,"""""'''' 'i/; ~~ /tI,)~ .~/ /cJ;1j .?1/ }/J /~-t?1 ~j~1J;#,!~.~jf~;{~~;~~:fu~1~PJ&t-:t't/zg~~,;~L;l.,1JI_~# l"c~.,-,"L!~w,,,[~,,lMtt-.,_.~,,_*,,,. _~_,,, ,,~_~ '1;-' \,i,~ -,- ~""I('E FiLEU-'-Urr" v "N-T' '''I''OTAlRY : " : -'_', } ~ ~-', i~/, '\ ' I.'"\i 01 OCT 15 PI'! L: 02 CUMBE.HLAI~O COUNTY PENNSYLV/\~llll. tb/- ~ ~ :$ -4 .fC1V 7!~~$4~tw ~~~4~1# !!i , STEVEN B. CLARK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2001.5Z~02- CIVIL TERM KRISTI J. CLARK, Defendant : IN CUSTODY ORDER OF COURT AND NOW, 200I,upon consideration, of the attached petition, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at on the day of ,2001, at m., for a Pre-Hearing Custody Conference. At such conference, ail 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 LAWYER AT ONCE. IF YOU no 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 TELEPHONE: (717) 249-3166 cc: Lindsay Dare Baird, Esquire Jane Adams, Esquire '-""'f'fI'; -ij, , ~~ ",,,,,,,,"1 ""'1 r ~ r I ""I=~ ~. ~""" - r- '~r ~ !!IlI'lIl'l I " v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COuNTY, PENNSYLVANIA ; No. 2001-58&:). CIVIL TERM STEVENB. CLARK, Plaintiff KRISTI J. CLARK, Defend.ant IN CUSTODY COMPLAINT FOR CUSTODY I. The plaintiff is Steven B. Clark, residing at 25334 Beantree Court, Moreno ' Valley, Califorrua. 2. The defendant isKristi J. Clark, residing at 53 Brian Drive, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff seeks periods of partial custody of the following children:, ~ Present Residence Age Joshua B. Clark 53 Brian Drive, Carlisle, PA. 16 Jordan S. Clark 53 Brian Drive, Carlisle, PA. 14 The children were not born out of wedlock. The children are currently in the custody of mother who resides at 53 Brian Drive, Carlisle, P A. I>uring the past five years, the children have resided with the following persons and at the following addresses: Person I<risti J. Clark Address 53 Brian Dr., Carlisle, PA Dates Aug 2001-Present I<risti J. Clark & Harold & Phyllis Smith 401 Garland Dr., Carlisle, PA Mar2001-JuIy, 2001 Mar 1999-Feb 2001 1996-March 1999 The mother of the children is Kristi J. Clark, currently residing at 53 Brian Drive, Carlisle, PA. ' She is married. The father of the children is, Steven B. Clark, currently residing at 25334 Beantree Court, Moreno Valley, CA. <-r$?f,-~,Wli!iAA-___ "'I I~' ~ - I 1 ~ "'1". ,~ j lIe is married. 4. The relationship of plaintiff to the child is that of father. The plaintiff currently resides with the following person: NaIIle Relationship Marilyn Daretzes ParaIllour s. The relationship of defendant to the child is that of mother. The defendant currently resides with the following persons: NaIIle Relationship Joshua B., Clark Subject child Jordan S. Clark Subject child 6. Plaintiff has not participated as a party or witne.ss, or in another capacity, in other iitigationconcerningthe custody of the children in this or another court. J.>laintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. J.>laintiff 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. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: a) Plaintiff can provide the chlldren with a home with adequate moral, emotional and physical surroundings as required to meet the children's needs; b) Plaintiff is willing to accept periods of partial custody of the children; c) Plaintiff continues to exercise parental duties and enjoys the love and affection of the children. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. All other persons, naIlled below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action' and the right to intervene: NaIIle Address Basis of Claim NONE Wherefore, plaintiff requests the court to grant him periods of partial custody of the children. '~(~H ,.,"1" -~ , I - ~,.- -j ~ I""'l'" I I verify that to best of my knowledge and belief, ,the statemeIlts 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.!i4904 relating to unsworn falsification to authorities. ~-,~ Steve, . lark, Plainti - ---- I-"_'c"li_"i!;'~~_,,_ , .~~~ ...:~ . I ~ ~ ~~"M"","""'~""'~'''''''''''''''' ~ ~ ~' ~ .A:::>~ ~x i\-- .,., ~ - - -J CJ) ~ - - '1 -....c ~~~ ... " "..,....,,'W"'I!r' lll" ''''illiilr'n~lI'lI'M'' ~ ~ ~ ~ ~ , , t",J :-,,) en ---I -,< ~q p~.mIJ!lIl!ll~,iUf41~~il!~~~~"i~'V!~.,'~'.\ljj{i'~""'""'"''''"''''''''-'""'"'>"'''''','-t',''1'-1mWfn'''~'~l'if''!fm)jiWFi\'f''f!''J''''~'''';;<:llijmjlll-~~~3~ i STEVEN B. CLARK, Plaintiff v. KRISTI J. CLARK, Defendant . : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2001- 5862 IN CUSTODY ORDER OF. COURT CIVIL TERM ~'^' ' AND NOW, this V'" day of November, 2001, upon consideration of the attached custody stipulation with respect to the parties' children, Joshua B. Clark, born June 17, 1985, and Jordan S. Clark, born August 19,1987, the terms of the stipulation are entered as an order of court. Lindsay Dare Baird, Esquire 37 South Hanover Street Carlisle, PA 17013 Attorney for the Plaintiff Jane Adams, Esquire 117 South Hanover Street Carlisle, PA 17013 Attorney for the Defendant 't~""~~N..'"" :" ' I BY THE COURT, ~ ~~ 1/_.JIJ-tJ J C)-. . J. -1' ~ :~M~~d~'!i'2i~U\\;d1;~iH~JrthJ-'~i'hi,;t""<?-...ttd;,Jf.\f;-bYtikHI'~A<i;o-'I~.' ,,,,,,k .'1' ""'~",,,:d.,,,,,rg,w,M~~!iilI~'<a-l '1~1!,ti'~~ (p"'':''''''';~'-~I!!l~~ i' "j JililU nl:' '_'I " 'I'.','........'..'E. '..c.,, ',)j'J",t.. . ,- :"'i-- -- ,,,..,: -) ... " "... '",~r 14R.\I """;\" ,,'lI o i Nn\l 2 U" l'i'l '0' e'l '... ~ ~ 'II J .::],; CUMuC(!=r:" I'",''' ("C)'UNTY ' l....!1L. '\i~U ,.....l I PENNSYL\(AN1A 1 ~ , !",!L""""".""....",.... " ~'O__M'-" ". __.~"""'-""'" " ~~" " . STEVEN B. CLARK, Plaintiff v. KRISTI J. CLARK, Defendant . '1'" : IN THE COURT OF COMMONI"LEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL TERM : No. 2001.. 5862 IN CUSTODY STIPULATION FOR CUSTODY STIPULATION made this day of November, 2001, between Kristi J. Clark, hereinafter, referred toas Mother, and Steven B. Clark, hereinafter referred to as Father. WHEREAS, the above-named Mother and Father had born to them the following children on the following dates: NAME Joshua B. Clark Jordan S. Clark BIRTH DATE 6-17-85 8-19-87 AND WHEREAS, the above-named Mother and Father desire to enter into a Stipulation as to the custody of the above-said children and to the partial custody rights of the non-custodial parent: <,.,",'nl1i<~'l'!_...., ,-, 'I ~ M\~~ ""'" J. CI , . Moth"_~~,' ~V. ~, Ste . Clark, Father "I ~ III_.-~~"" ~, ~, I' 'I' .. . '\lIl7"",",,_ .. _)ii_,...<_,_,~,~"J _ ~ ,~_, -, "_~,'_e"_~,,,___,~~ ~.. ~li~r~!]f1J"r:r:-l"t~fifYfr~ji<"'-oJwJ'~lY"n-''1\pxt1~~'~it~ftifr~1t'~nj'~tn~"~~;:if '. o C -:-~-- ri'~?-' z:; ~~:~- ~:.--: ,.--,.. ~.;:-::. \ .-'-( " .' ~,--~ =.:2 (:'-) ~5 ? yL . . .-<--? ~:) c~ ,,,,!,,"l"'"',_~~'~~~~l1l<~~;ml"!R-'jij1,,,",,i'K~f?-!i1;f."-':r''''''.'>' -?'ff,'!'-'hf!''-~;~'q""-"",,_,_,,q~=;'"r,'-;ill-);'''~'fni-, ;1!~;f'~;""'lvf'l'r1!'{t!:l.:Wj,l!~~~~If 1 NOV 2 9 2001 ,,0 V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLV ANIA : NO. 2001-5862 CIVIL TERM STEVEN B. CLARK, Plaintiff KRISTI J. CLARK, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 29th day of November, 2001, the Conciliator being notified that the parties have reached an agreement in the above captioned matter, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, /h.i stody Conciliator ""-ff'!''"_ ~~ ~- I" >,."""'" --- ~ 1- 11 "I," , "~ J:lIJ, ur,__ ',' ,-, -"_.,,~~, '"'... '" ""H.""'''''''''''i'llllz''~''vrfl]r'tr'''' ''1 T if'~'(, 'ifi"'c' o C ;?-- S11ff 7"1'- ~C :'?i=': ~>- C2i =< C:J C:J ---:<, CJ ; ,fJ-:-' c~"'\ l... ~.,n f,<'! ~' fJlf _~~~-If'!; _ tm~_",,=![,tll~IlJIiJ~~1J)\f~m\~!'!''"-'%t'''''-'''''''''''>::!1~<:' ';;".w";;ffi"!'O-;il~ji~~'J!~.~~~~I~'I\~~r::r:_.M