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HomeMy WebLinkAbout01-06257 . , WILLIAM C. HOLSTINE, KATHIANN HOLSTINE, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. TIMOTHY RAYMOND GREENE, : NO. 2001-6257 CIVIL TERM Defendant : CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, this 9TH day of NOVEMBER, 2001, Jennifer O'Neil Stancil Greene, is added as a party defendant in this action. Plaintiff s counsel is directed to serve her with a copy of all pleadings and notice of the upcoming hearing. Jennifer O'Neil Stancil Greene 972 Bright Road White Plains, Virginia 23893 7 EdwomE GWdn/ ~ (\ 0./0\ \ ~ V CC: Steven C. Courtney, Esquire Timothy R. Greene 307B North Bedford Street Carlisle, Pa. 17013 :sld :~;:! '""'"^+:"'_"~:_'_'<,"'~~":~':""':-:"~",,~"S ,","" """" '.. 1'- "--" -" ~,., I iMB~mllM~~w..,jlir;t~-'t~~:~.;il\i'j.~j,!~!!'1,~~Ljj.ii-il~ThY~"d- o'~r' ,",,--~...m _.~"'V '__'.P:'~' """",,,' -,-,-,,--- ';"1 U"!I~lnH~oCI .,-', I ,1,,-,,' ... /,',j';, I: r;; PI >,i. (',: I), 'I':"""'" vUjV)tk:hL/-~,,'~,) {'ri!j;\[TV D-' - V,-" !~l I ! ti'4f\1SYLVAN:A - . , -~. WILLIAM HOLSTINE and KATHlANN HOLSTINE, Plaintiffs/Petitioners vs. TIMOTHY RAYMOND GREENE, Defendant/Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. al-&":<~7 C;u~CT~ Civil Action - Custody CONSENT ORDER PURSUANT TO PA.R.C.P. NO. 1915.7 AND NOW, this day of , 2001, upon review and consideration of the Custody Agreement of the parties hereto, a copy of which is attached hereto, said Agreement is hereby APPROVED, ADOPTED, MERGED and INCORPORATED herein as the Order of this Court. cc: Steven C. Courtney, Esquire Document #: 208229,] 'V~I\Q!~l~ _ITW] J _<' " J BY THE COURT: 1. 1" ~, .!II!!IIftI ...-m,,,,,,,,,,,,,,,,,,,,,,<<?, " WILLIAM HOLSTINE and KATHIANN HOLSTINE, Plaintiffs/Petitioners IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 0\ - fe,;}.-S7 Cu~l ~1i. TIM07 H Y RAYMOND GREENE, Civil Action - Custody DefendantlRespondent CUSTODY AGREEMENT AND NOW, this I day of tJ t j ber-' 2001 come the parties, William C. Holstine and Kathiann Holstine, by and through their counsel, Steven C. Courtney and Metzger, Wickersham, Knauss & Erb, P.C., and requests this Honorable Court enter the attached Order for the following reasons: WHEREAS, Timothy Raymond Greene is the natural father of Michael Ryan Greene (DOB 2/29/00); WHEREAS, Timothy Raymond Greene was given majority physical custody of Michael Ryan Greene as evidenced by the Custody Consent Decree attached hereto as Exhibit "A". WHEREAS, William C. Holstine, (hereinafter referred to as "GRAND-FATHER") and Kathiann Holstine, (hereinafter referred to as "GRAND-MOTHER") are the natural grand-parents of Michael Ryan Greene (DOB 2/29/00); and WHEREAS, Father, Grand-Father and Grand-Mother desire to make arrangements for the custody and visitation of the said minor child; and, WHEREAS, both parties have been advised by counselor have had the opportunity to be advised by counsel; and, Document #: 216625,1 "":'1:'\~~ij - 'I~ ~ ,., ~~ .~ 8 WHEREAS, the parties intend to submit this Custody Agreement to the Court of appropriate jurisdiction for incorporation and merger into a Court Order approving said Agreement; NOW, THEREFORE, it is hereby stipulated and agreed as follows: 1. The Petitioner, WILLIAM C. HOLSTINE, is an adult individual residing at 821 Bower Road, Shermansdale, Perry County, Pennsylvania 17090. 2. The Petitioner, KATIDANN HOLSTINE, is an adult individual residing at 821 Bower Road, Shermansdale, Perry County, Pennsylvania 17090. 3. The Respondent, TIMOTHY RAYMOND GREENE, is an adult individual residing at 307B North Bedford Street, Carlisle, Cumberland County, Pennsylvania 17013. 4. For the past five (5) years, the minor child has resided with the following persons at the following addresses: Name Address Dates Timothy Raymond Greene 307B North Bedford St. Carlisle, P A 17013 6/01 to present RR1 Landisburg, P A 2/01 to 6/01 Fort Stewart, Georgia 7/98 to 2/01 5. The Mother of the child is Jennifer O'Neil Stancil Greene who resides at 972 Bright "",A,'N. ' Road, Whiit: Plains, VA 23893. 6. The Father of the child is Timothy Raymond Greene, who resides at 307B North Bedford Street, Carlisle, Pennsylvania 17013. Document #: 216625.1 "~~u, -.'1 _..~"..,_<., ""1 -,...", .~ ~~, , ' " 7. The relationship of Petitioners to the minor child is that of Grand-Father and Grand- Mother. Petitioners currently resides with the following persons. Name Relationship William C. Holstine Self Kathiann Holstine Self 8. The relationship of Respondent to the minor child is that of Father. Respondent currently resides with the following persons: Name Relationship Timothy Raymond Greene self 9. Micheal Ryan Greene is presently in the custody of Grand-Father and Grand-Mother, who resides at 821 Bower Road, Shermansdale, Perry County, Pennsylvania 17090. 10. Grand-Father and Grand-Mother shall have majority physical custody of the minor child, and F ATHER shall have minority physical custody. l1. Grand-Father and Grand-Mother and Father will have shared legal custody of MICHAEL RYAN GREENE. Father shall have time with the minor child upon such date and times as agreed by the parties. 12. Both parties shall permit liberal telephone calls to the minor child from the non- custodial parent. 13. The parties agree to cooperate with one another in the implementation of the aforesaid Agreement and understand and agree that other changes or modifications in the aforesaid schedule and/or times specified may be necessary to enable both parents to continue to foster and develop a Document #: 216625.1 ,~~,,"!\lIi!!lI!'!jn,~ > -" ..-" -~ ~ " ~. ,- - good and healthy relationship with the children. To that end, the parties agree to cooperate with one another to encourage the relationship of the children with the other parent and agree to refrain from any and all conduct, activity, or communication which would adversely affect the children's relationship with either parent. 14. Upon the knowledge of pending relocation, temporary or permanent, of either parent, each parent must immediately inform the other of his/her new address and telephone number. 15. Both parties shall utilize child restraint seats and seat belts while transporting the child by automobile. 16. This Agreement shall be effective immediately upon signature by both parties and its validity is not contingent upon Court approval. ~~ c:::~y:b William c. Holstine, Plaintiff ~~~-~ Kathiann Holstine, lamtJff Date:/t' - / .... 0 I Date: 10 - 01 - 01 Date: If) - Of ~ of , tJ.4 t.,{/- lmothy Raymond Greene, Defendant Document #: 216625.1 '\i!Cl~,~ J" ~ "- ~ ,,__ T.''''''- ~-~~ CO~ONWEALTHOFPENNSYLVAN1A SS COUNTY OF Personally appeared before me, a notary public in and for said Commonwealth and County, the undersigned, WILLIAM C. HOLSTINE and KATHIANN HOLSTINE, Plaintiffs, who, being duly sworn according to law, deposes and says that they are the GRANDPARENTS and that the facts set forth in the within Custody Agreement are true and correct to the best of his knowledge, information, and belief. ~~~c~ William C. Holstine, Plaintiff ~d~7p. x;J:L: K thlann Holstlne, Plamtiff Sworn to and subscribed before me this L day ,2001. NOTARIAL SEAL . DAWN M. SHUGHART, Notary Public Garlisle, Cumberland County My CommissIOn Expires NO"; 28, 2002 Document #: 208229, J ,':'.~~.~. ~Jl<q ../""" ,__ _'C .., ""I' ""., ~ 1!I - ~ ~ "~-_. , COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF Personally appeared before me, a notary public in and for said Commonwealth and County, the undersigned, TIMOTHY RAYMOND GREENE, Defendant, who, being duly sworn according to law, deposes and says that he is the FATHER and that the facts set forth in the within Custody Agreement are true and correct to the best of her knowledge, information, and belief. -t~JA,41'&^ (0' ______ Timothy Raymond Greene, Defendant Sworn to and sul]scribed before 1this L day ~ ,2001. NOTARIAL SEAL AWN M SHUGHART, Notary public D Carlisle, cumberian~ co~~ 2002 My Commission Expires ov. , Document #: 208229.1 I,~,~, - ""..,,_. >-~I '""1"'" ~ , ~,. --, ^'- "~: "~, .,~,~ ~ "-,,~,- ~r~ . . ? N ~ ~ f(;) jt 1[ a 0 C":,\ C) C ~; j 8 "':.._- z ....... -on.:: ,-:-] "'-l rTlI'l^! ,~^'~ '- ;:;';L "- t LI. ~ r u: ,~:~. -<..,' c.:.::c ~Tl ;>..., , _~L ~ ~~~ ~~;? ':-_'~:: ~ .<.:::- -:.<1 :~~) :;! CJ -< --( ,;-.- -!Ill .IW1lJ.~~~ _"~,...,o,,.,~, .",,-,~, _~..,1~~1',tffi'Jt'@)0!'J\'Wf"'~H1" ,.""", n'l',;t'F\l\~;'!'F1i'il~~:m"'\:.~;;;-:;f;~l!f,,,,;r;'W"';':-"+-;"%'i"';W';"'~w''''''(f,1'(~~1l'WW~G ",\,,';:,;;', ~5;1"'F; . 6 November 200l SINCE 1888 3211 North Front Street PO. Box 5300 Harrisburg, FA 17110-0300 717-238-8187 Fax: 717-234-9478 The Honorable Judge Edward Guido Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Other Offices Colonial Park 717.652.7020 Mechanicsburg 717-691.5577 Shippensburg 717.530.7515 Re: WiIIiam and Kathiann Holstine v. Timothy Raymond Greene Dear Judge Guido: Pursuant to your request, enclosed herein please find an Order relative to the above referenced matter. Please contact the undersigned with any questions or concerns upon your receipt and review of this letter and enclosure. Very truly yours, \, SCClkan Enclosure ^~,~L .,~, -"""l~C",~},,:, --"'J'.-r;" ,'" ,-!,> "~"'_ ,>'./, ;I.'~;;"",--" ,)!"_",~c,,,' ,-,'''',~,,>_,_, ,.' I , ",,"~- ,. -,~ .~ ."~. James F. Carl Edward E. Knauss, IV* Jered L. Hock ..~j;R..HiIdaprand' Steven P. J\.1iller Clark DeVere E. Ralph Godfrey Steven C, Courtney Francis J. Lafferty, IV David H. Martineau Andrew W. Norfleet Steven C. Skoff Melissa L. Stickel '" Board Certified in civil tria/law and advocacy by the National Board a/Trilll Advocacy -- .., .- ,~ Document #: 2/8222,1 WILLIAM C. HOLSTINE, KATHIANN HOLSTINE, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW vs. : NO. AOtJ/_ 64.17 TIMOTHY RAYMOND GREENE, Defendant ORDEROFCOURT A Custody Agreement has been filed in the Court of Common Pleas of Cumberland County concerning custody, partial custody and visitation of Michael Ryan Greene. The Court has learned you may have a legal interest in custody, partial custody or visitation ofthe child named. 5 A hearing will be held in Courtroom of the Court of Common Pleas, One Courthouse Square, Carlisle, Pennsylvania 17013 on.bfL. Ad -.4.t ~Jf you wish to have custody, partial custody or visitation of the child tr wish to present evidence to the Court on those matters, you should appear at the place and time and on the date above. If you have the child in your possession or control, you must appear and bring them to the Courthouse with you. If you wish to claim the right of custody, partial custody or visitation, you may file a counterclaim. If you fail to appear as provided by this Order or to bring the child, an Order for custody, partial custody or visitation may be entered against you or the Court may issue a warrant for your arrest. 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 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. ~ ~ _\VJ CUMBERLAND COUNTY BAR ASSOCIATION .~ ~ 2 Liberty Avenue ~ Carlisle, Pennsylvania 17013-3387 VJ "'" PHONE: (717) 249-3 166 . .g; ~ V~ rr; >' ~ "" J. Date:~ Document#: 2199/3.1 """",,*,,,,,,,,,,,","1"1; .^."",~ ~~ 1" ~ PI". ~"~ ~ IIIU[ -~ ~, ~;1i~~'lltiftlW~~1Mhilli~'4' ;H~''iJ-'ic~'',:ie,:_'i!_~'h~~;;)'''');H&dr$.~~II'''''' 41 ~ "~"~t"CI!JJ~IU,.,,_,,,,",, " '". ~'~~.' ,~ >.~I~, ~~, 5~4 _1ti,giii~'ll!~~lH.l1...'W'''''''~l'''\JJ!lm[ f &."j '-;;~"""'-",*JiiiHl "" .",c., ''T' r 1',j " '-Of o i NP\f - 9 P.ii Ii: :1? ('! Jil.ii~i\:f,:.:i J"!",1i'; (":rJ~"IJ't.rr\/ V'-oi"i,~'-,I ,_, 1,.1.... -..," l1;j J PEi\!f~SYl!II\NI/\ ~ 0-"- WILLIAM C. HOLSTINE, KATHlANN HOLSTINE, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW vs. : NO. 2001-6257 TIMOTHY RAYMOND GREENE, Defendant AFFIDAVIT OF SERVICE I, Steven C. Courtney, counsel for Plaintiff, hereby certify that a true and correct copy of the Complaint for Custody and Order was served upon the following, by certified mail, return receipt and regular mail on November 19, 2001. Jennifer O'Neil Stancil 972 Bright Road White Plains, VA 23893 Timothy Greene 307B North Bedford Street Carlisle, Pennsylvania 17013 METZGER, WICKE SHAM, KNAUSS & ERB, P.C. Date: ~ ( ?&fC( . Steven C. 0 LD. No. ] 9 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiff Do~ment#: 221591.1 <.;;~- , ! ~ .~, '~".' , -"~' ,".,~,- '"' 'k'l"-"'"'''''J~" . ~,,~,,-- ~ ,,,>,'""~" '$I' t,,~;;,.'u;'i'N'il'flt"'~""f'I~T.."~'~f~~~'::bF11~j>:';~il:,:;""t'f (") c.: ;;? ""OG'J OJ rr'~. ~~. \;2:C ;p.~, Zc' :Pc -7 ~ %1 Q o '-n ;,;e g '- ,--1 ;-7<2 ~-'i'!t~ (;-,~~ ,:~:;~.-~ c)' -., ~ -< f'~ <.0 -0 -- ...-''C" 1....,) f;:J ,~.~~ lY~,'Il._ ~,T_IfU:f!'l!T" ~=_.'~" ., ","'!!IVI[5! ,. ,_ ~~~~1t"it'f;'?'f':"':@.'.'<';5"':\.fi-:~""-"'$C;\"'''''.'N;,'':'r':W"''''';F<'i'Ef'~~-''~11~~~~Jli!~i1f\t~~(l ,j~-I. , WILLIAM C. HOLSTINE, KATHIANN HOLSTINE, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001-6257 CIVIL TERM TIMOTHY RAYMOND GREENE, Defendant CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, this 20th day of December, 2001, after hearing, the parties are granted shared legal custody of Michael Ryan Greene. Primary physical custody is awarded to the paternal grandparents, William C. Holstine and Kathiann Holstine. Mother and Father shall be entitled to partial physical custody and/or visitation as agreed upon. By the Court, E. Guido, J. Steven C. Courtney, Esquire Attorney for Plaintiffs . C\ \ Jennifer 0' Neil Stancil Greenel atWDfGcu.1o..d 972 Bright Road - r White Plains, VA 23893 ~3 Timothy R. Greene ) 2 - :U' () I '} '\ 307-B North Bedford Street Carlisle, PA 17013 srs ','n~.,_ '> ~ ,.,- L -~ , w ~~....... ,......." ~,_, """~" _1J!lI,_"," u ~, - Po ' -, 'h" ,~. "", - -'- H M, . ";"'. 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