HomeMy WebLinkAbout99-02053
g, The relationship of Defendnnt to the children is that of Mother, The Defendant
currently resides with the children, Maret Hench, Aliyah Hench. and Karis Hench, on a rotating basis
with Plaintiff,
9, Plaintiff 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,
Plaintiff has no information of a custody proceeding concerning the children pending
in a court of this Commonwealth,
Plaintiff 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,
10, The best interest and permanent welfare of the children will be served by granting the
relief requested because:
A, The emotional, physical and/or spiritual development of the children
would be enhanced by granting periods of shared physical custody of the children to
the Plaintiff,
B. The Defendant continuously involves the children in problems of the
parties in an inappropriate manner, Le" hitting the Plaintiff and screaming at the
Plaintiff in the presence of the children.
C, And other reasons which may fully appear at conference,
11, 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, There are
no other persons who are known to have a claim or right to custody or visitation in this matter,
WHEREFORE, Plaintiff requests the Court to grant custody of the children to the Plaintiff,
Blaine E, Hench,
Respectfully submitted,
DALEY LAW OFFICES
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Attorney No, 68736
1029 Scenery Drive
Harrisburg, P A 17109
(717) 657-4795
Attorney for Plaintiff
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DALEY LAW OFFICES
1029 SCENERY DRIVE
HARRISBURG, PENNSYLVANIA 17109
(717) 657-4795
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BLAINE E. HENCH,
Plaintiff
IN THE COURT OF CXIM/olOO PLEAS OF
: CUMBERLAND CCXlNTY, PENNSYLVANIA
vs.
NO. 99-2053 CIVIL TERM
HELEN T. HENCH,
Defendant
CIVIL ACTION - LAW
CUSIDDY
aIDER Of! CXlURT
AND ~,this I~.
consideration of the attached
and directed as follows:
day of 1'l7/t-'f , 1999, upon
CUstody Conciliation Report, it is ordered
1. ~le Father, Blaine E. Hench, and the Mother, Helen T. Hench, shall
have shared legal custody of Maret Hench, born September 21, 1994, Aliyah
Hench, born June 14, 1996, and Karis Hench, born July 14, 1998. 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 this
paragraph, each parent shall be entitled to all records and information
pertaining to the Children including, but not limited to, school and
medical records and information.
2. The Father shall have physical custody of the Children every
Monday and Wednesday from 5:30 p.m. until the following morning when the
Father shall take the Children to day care. The Father shall have custody
of the Children on alternating weekends, beginning May 15, 1999 on Saturday
from 8:30 a.m. until 5:00 p.m. and from Sunday at 12:00 noon until Monday
morning when the Father shall take the Children to day care. During the
interim weekends, the Father shall have custody of the Children from Friday
after work until Sunday at 8:30 a.m.
3. The Mother shall have physical custody of the Children during one
full weekend per month from Friday through Sunday when the Mother is off
work upon providing as much advance notice to the Father as possible, In
addition, the Mother shall have custody of the Children at all times not
otherwise specified for the Father under this Order.
4. The parties shall make arrangements for custody of the Children
over holidays and vacation periods by agreement.
5. This Order is entered pursuant to an agreement of the parties at a
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MAY 17 1Q99\
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Il Every Wedne!lday from S30 p,m, until Thur!lday morning before day eare;
C Alternating Saturdays from 8:30 a m until SOO p,m,;
D, Alternating Sundays from 12:00 noon until Monday morning before day
eare; and
E. Alternating interim weekends from Friday after work until Sunday morning
at 8:30 a,m,
S, Plaintiff/Petitioner believes that the shared physical eustody sehedule set forth in
the Order of Court, dated May 19, 1999, is too confusing and disruptive to the lives of the
parties' minor children,
6, Plaintiff/Petitioner believes that the children need a ml>re stable shared physical
custody arrangement,
7, PlaintifflPetitioner believes that the parties' minor children would benefit more
from a custody schedule which provides the children with larger blocks of time with each parent,
as opposed to the current custody schedule which provides the children with an almost daily
alternating physical custody schedule,
8, Plaintiff/Petitioner requests that an Order of Court be entered, amending the
existing Order of Court, dated May 19, 1999, which provides each party with larger periods of
physical custody with lhe minor children,
WHEREFORE, PlaintilTlPetitioner, Blaine E, Hench, respectfully requests this
Honorable Court to amend lhe existing Order of Court to provide each party with larger periods
.
B, Every Wedne5day from 5:30 p,m, until Thur5day morning before day care;
C, Alternating Saturdays from 8:30 a,m, until 5:00 p,m,;
D. Alternating Sundays from 12:00 noon until Monday moming before day
care; and
E, Alternating interim weekends from Friday aner work until Sunday morning
at 8:30 a,m,
5, PlaintifflPetitioner believes that the shared physical custody schedule set forth in
the Order of Court, dated May 19, 1999, is too confusing and disruptive to the lives of the
parties' minor children,
6, PlaintifflPetilioner believes that the children need a more stable shared physical
custody arrangement.
7, PlaintifflPetitioner believes that the parties' minor children would benefit more
from a custody schedule which provides the children with larger blocks of time with each parent,
as opposed to the current custody schedule which provides the children with an almost daily
alternating physical custody schedule,
8, PlaintifflPetitioner requests that an Order of Court be entered, amending the
existing Order of Court, dated May 19, 1999, which provides each party with larger periods of
physical custody with the minor children.
WHEREFORE, PlaintifflPetitioner, Blaine E, Hench, respectfully requests this
Honorable Court to amend the existing Order of Court to provide each party with larger periods
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DALEY LAW OFFICES
1029 SCENERY DRIVE
HARRISBURG. PENNSYLVANIA 17109
(717) 657.4795
/'\PR 2 5 200~
BLAINE E. HENCH, . IN THE CXlURT OF CXJMMaol PLEAS OF
.
Plaintiff/petitioner . CUMBERLAND CCUN'l'Y, PENNSYLVANIA
.
.
.
VS. . NO. 99-2053 CIVIL TERM
.
:
HELEN T. HENCH, . CIVIL ACTION - LAW
.
Defendant/Respondent : IN CUSTODY
CllDER CF CXXlRT
AND NCW, this z-<j-
consideratioo of the attached
and directed as follows:
day of \Tv......... , 2000, upon
Custody Conciliation Report, it is ordered
1. The Father, Blaine E. Hench, and the Moth~r, Helen T. Hench, shall
have shared legal custody of Maret Hench, born Septell'ber 21, 1994, Aliyah
Hench, born ,June 14, 1996, and Karis Hench, born July 14, 1998. Fach
parent shall have an equal right, to be exerciSed jointly with the other
parent, to nake all najor 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 this
paragraph, each parent shall be entitled to all records and information
pertaining to the Children including, but not limited to, school and
medical records and information.
2. The parties shall share having physical custody of the Children in
accordance with the following bi-weekly schedule:
A. WEEK I:
Father shall have custody from Monday IIIOrning through Tuesday
IIIOrning .
Mother shall have custody from Tuesday IltOrning through Thursday
morning .
Father shall have custody from Thursday IIIOrning through Monday
IltOrning.
B. WEEK II:
Mother shall have custody from Monday lIXlrning through Wednesday
morning .
Father shall have custody from Wednesday IIIOrning through Friday
IIIOrning
Mother shall have custody from Friday morning through Monday
morning .
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3. The parties shall make arrangementa for custody of the Olildren
over holidays and vacation periods by agreement.
4. 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 nutual consent. In the absence of mutual consent, the terms
of this order shall control.
BY THE CXXlRT,
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cc: Cara A. Boyanowski, Esquire - Counsel for Father
Helen T. Hench, Mother
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