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Home My WebLink About99-03661 Q V Z a Z 1 I 1 i t ti .y m r BRET A. DUNCAN, Petitioner, , v. JANET C. DUNCAN, Respondent. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. qq - 3/L 4, / CIVIL ACTION - LAW IN CUSTODY ORDER AND NOW, this& - A_day of19?, upon consideration of the attached Compla?nt,?t? hereby hYeby directe that the parties and their respective counsel appear , at before the ConW9; s?9 1„1. Mn'? ? rn ' the day o' o o'cloc _ 19 1'i9n co nference, aneffortt will beamade tosresolventheeissuesAinsuch 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 .V, ,,,: ?„ m.dnn ( nn Custody Conc17 iator - - 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. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 Gas •99 ?. ??? ? ? GaaAA? oe. BRET A. DUNCAN, Petitioner, V. JANET C. DUNCAN, Respondent. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99. 3GGl T1•'•"- CIVIL ACTION - LAW IN CUSTODY PETITION TO CONFTRx 9-8x Y AND NOW, comes the Petitioner, BRET A. DUNCAN, by and through his attorneys, MANCKE, WAGNER, HERSHEY & TULLY, and files the following Petition to Confirm Custody: 1. The Plaintiff, BRET A. DUNCAN, is an adult individual currently residing at 2634 North Rosegarden Blvd., Mechanicsburg, Cumberland County, Pennsylvania. 2. The Respondent, JANET C. DUNCAN, is an adult individual currently residing at 4412 Union Deposit Road, Harrisburg, Dauphin County, Pennsylvania. 3. The Petitioner and Respondent are the natural parents of Shane Duncan, born 11/17/91, and Emily Duncan, born 4/5/95. 4. The children were born during wedlock. 5. The parties were married August 27, 1991, in Mechanicsburg, Cumberland County, Pennsylvania, and separated on or about February 14, 1999, wherein the Respondent moved to the address contained in paragraph 2 above. 6. Since separation, the above-named children have been residing primarily with the Petitioner at 2634 North Rosegarden Blvd., Mechanicsburg, Cumberland County, Pennsylvania, along his parents, the paternal grandparents of the children. 7. Since separation, the children have also, from time to time, been residing with the Respondent at her address contained in paragraph 2 above, and also on occasion, have been residing on an overnight basis with the maternal mother, Kathy Jacobs, who resides at Elm Street, Mechanicsburg, Cumberland County, Pennsylvania. 8. There are no prior actions in custody or partial custody in this matter. 9. Petitioner knows of no other person who has an interest in the custody or partial custody of the children. 10. Petitioner believes and therefore avers that it is in the best interest of the children to confirm shared legal custody in the parties, with primary physical custody of the children in the Petitioner herein for the following reasons: A. The children have been primarily raised in the Mechanicsburg area; B. The children are enrolled in the Mechanicsburg School District where the Petitioner herein resides; and C. The Petitioner is able to provide for the day to day care and needs of the children. 11. Petitioner believes and therefore avers that primary physical custody should be confirmed herein in Petitioner with periods of reasonable partial custody in the Respondent herein. WHEREFORE, Petitioner prays this Honorable Court to grant the relief as requested. Respectfully submitted, NANCXE,,VRGNER, HERSHEY. i TULLY '?.D #23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorney for Petitioner ?0 8 9 9 DATE: VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to uthorities. DATE. Y 102- ?? 2Z } S Y = U Q w WE DO HEREBY CERTIFY 'NAT THE WITHIN 18 A TRUE AND COR• RECT COPY OF THE ORIGINAL FIM IN THIS ACTKKI rv ATr EY MANCKE, WAGNFH, FIFRSI 1[V & I(AI.Y '°'.-xrrau ..00.0noxu r 10 1.. Au Yxe r mN i wi aro Wi1xiN rWeNrV 10 :.Ye .IIOY M.l W exnNN 44We1 VM YeN' .. ' er _._NT2AFYP--? I U N 17 199! AUG - 2 1996, BRET A. DUNCAN, Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 99-3661 IN CUSTODY VS. JANET C. DUNCAN, Respondent, CRDER OF COURT AND NOW, this 28th day of July, 1999, the conciliator, being advised by Plaintiff's counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction in this case. The Custody Conciliation Conference scheduled for today, July 28, 1999, is canceled. FOR THE COURT, 4,- -e, Dawn S. Sunday, Esquire Custody Conciliator 1, SRET A. DUNCAN, Petitioner, V. JANET C. DUNCAN, Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3661 CIVIL ACTION - LAW IN CUSTODY ORDER AND NOW, this day of (S ?k , 1999, upon Stipulation by and between the parties, which is attached hereto and marked as Exhibit A, the terms of the Stipulation are hereby adopted and incorporated herein by reference as a Court order. FlLED-0rFK:E 99 OCT 2G 9: 08 CU^?pC I SMV NAB 0 `C fi cr >. Z J o Q F 5 Y W M U(=D?a z ? w ^ BRET A. DUNCAN, Petitioner, V. JANET C. DUNCAN, Respondent. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3661 CIVIL ACTION - LAW IN CUSTODY STIPULATION AND NOW, comes the undersigned, BRET A. DUNCAN, Petitioner, and JANET C. DUNCAN, Respondent, and do hereby stipulate, agree and confirm as follows: 1. The parties shall enjoy shared legal custody of their children, Shane A. Duncan, born 11/17/91, and Emily M. Duncan, born 4/5/95. 2. The parties shall have physical custody so that three days and three nights per week the children shall be with Mother, and four days and four nights per week the children shall be with Father. 3. The parties agree to reasonably cooperate to effectuate the aforementioned schedule, and further agree to cooperate in providing custody to either party as mutually agreed. 4. The parties agree that this matter shall be entered as a Stipulated Court order, since the matter had originally been scheduled for a custody conciliation on July 28, 1999, the parties having reached this agreement in anticipation of that j conciliation. 5. Each party has had the opportunity to review this agreement and each, intending to be legally bound, and each having had the opportunity to review the same with legal counsel, e4etA. tnto this tipulation. B u can J anet C. Duncan