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HomeMy WebLinkAbout99-01473 6. Petitioner has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court, Petitioner has no information of a custody proceeding concerning the children pending in a court of this Commonwealth, Petitioner 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. t r f t I ! I I I I 7, The best interests and permanent welfare of the children require that the parties have joint legal custody of the children, that petitioner have primary physical custody and that respondent have specified periods of temporary custody and visitation with the children in accordance with a schedule which may be agreed upon at a conciliation or directed by the court in a hearing to be held in this matter, 8, Each parent whose parental rights to the children have not been terminated and the persons who have physical custody of the children have been named as parties to this action, WHEREFORE, petitioner respectfuily requests that the court enter an order providing for the legal and physical custody of the children as aforesaid, March 15, 1999 HAROLD S. IRWI I Attorney for petitioner 35 East High Street Carlisle, Pennsylvania 17013 (717) 243.6090 Supreme Court I,D. No, 29920 j ~ ~~ ,~;, ',: " . , ~ ~. <Il ,q; e '"" J.< ,-'l . ClJ :::: 'I>. >< Eo< oW ... Eo< :J: '" c: .... ~ 22: ..; ..... '" Ci , . .00 ...1 '... . '... '0 <:t Wi 'i0"; :> =.... c: ::-0 U....I '... >< u c: . 0 ~ ~~ .0 Z U 0 ....'... =0- I!::.; I~ uo,,;z 0 Z III UIIl Ill;! ~:>o Eo< z..... , .... ClJ ~ ...." ~~ :~ ...1.... Ul ....e.. > ZC<: '" (,jlU '0...1 >< Eo< 0 ~ z o '2: C<:UlU U .... :t Qtl: lii~ ~, E-oI>lZ"; , ~ ~ o...l ~ ~~ "c.: ~z Z I>l 'luj :::>~I>l...1 .... , Ooq lU... o ::;:,tl,H c.: ...1 ~!!! uu :> I>l l:l:: ii! .... ...1 .... ~ I>l~ U 0 Eo< ~ :<:0 Z Ul Eo< , ..:; .... 0 = C<: Z Z U ::0:: .... , '. :.~ I :.,.: f / /':,',' ;f /)." :'! HMOLD ., IRWIN, III, .aQUIIII AnGlINIV 10 NO, 2"20 21 uaT HIOH aTll11T CAIILIILI'A 17013 (7171 243oe011O AnOIlNIV POll PLAINT." CHANDLeR e, MINNICH, Petitioner IIN THe COURT 01' COMMON PLUS OF I CUM8tlRLAND COUNTY, PtlNNSYLVANtA I :NO. tJr;,/'/H C.~/T...... y, KRtSTI L MINNICH, Re.pondent : tN CUSTODY ORDER OF COURT NOW, this day of March, 1999, in consideration of the attached petition, it is hereby directed that the parties and their respective counsel appear before Hubert X. Gilroy, Esquire, the conciliator, on the 4th Floor, Cumberland County Courthouse, on the day of , 1999, 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 this conference may provide grounds for entry of a temporary or permanent order. By 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 LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 CHANDLIIR II, MtNNICH, Petitioner v. I IN THII COURT 01' COMI,IION PLUS 01' I CUMBIIRLAND COUNTY, PIINNSVLVANIA I : NO. qq. N 7} C,'vJ -r;.- .--.... ,.1 ,: . " . <.. ,( " -'( " , .n " ,! ell ,d . KRISTI L. MINNICH, Re.pondent : IN CUSTODY PETITION FOR CUSTODY NOW comes the petitioner, Chandler E, Minnich, his attomey, Harold S. Irwin, III, Esquire, and presents this petition for custody, representing as follows: 1, The petitioner is Chandler E, Minnich, an adult individual residing at 321 Garland Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2, The respondent is Kristi L. Minnich, an adult individual residing at 6 Mellwood Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055, 3, The parties and are the parents of two children, namely Logan A. Minnich (age 2, born September 11, 1996) and Evan X. Minnich (age 2, born September 11, 1996), both born just prior to the marriage of the parties, 4. Both children resided with both parties from the time of the birth of the children until March 13, 1999, when the parties separated, 5, Both children are presently residing with the petitioner at 321 Garland Drive, Carlisle, Cumberland County, Pennsylvania 17013, CHANDLI!R I!. MtNNICH, PetItioner I IN THI! COURT OF COMMON PLI!AS OF ,-, ,,) I CUMBI!RLAND COUNTY, PI!NNSYLVANi~ : .~ v, : NO, Q9. /'1'13 C~ I.J.<- KRtSTI L. MtNNICH, Re.pondent . . : tN CUSTODY PETITION FOR CUSTODY NOW comes the petitioner, Chandler E. Minnich, his attorney, Harold S, Irwin, III, Esquire, and presents this petition for custody, representing as follows: 1. The petitioner is Chandler E. Minnich, an adult individual residing at 321 Garland Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2, The respondent is Krisli L. Minnich, an adult individual residing at 6 Mellwood Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055, 3, The parties and are the parents of two children, namely Logan A. Minnich (age 2, born September 11, 1996) and Evan X. Minnich (age 2, born September 11, 1996), both born just prior to the marriage of the parties, 4, Both children resided with both parties from the time of the birth of the children until March 13, 1999, when the parties separated, 5, Both children are presently residing with the petitioner at 321 Garland Drive, Carlisle, Cumberland County, Pennsylvania 17013, ') ., .. , r t r ., ..} 'n 1.-_; '.-n ,:) ~ l:) . ~ - ~-l 2(; t. ~ f f 1 ., :==! ". (}; -. ,,", ,- en -- t:) ;~ 1',-: (': - 1:: r , UJ . ( ).' ~~ (1_ ~\ tn C-', 1..'.1" C~': C.' .... .-.;" 1--:": "- '.- IL Cf'> ":s 0 Cf\ (J