HomeMy WebLinkAbout99-05399a
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ALBERT B. CARLSON,
Plaintiff
V.
ILONA A. CARLSON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-5399 CIVIL TERM
ORDER OF COURT
AND NOW, this j}? I?day of September, 1999, upon consideration of Plaintiff's
Petition for Special Relief, a hearing is scheduled for Friday, September 10, 1999, at 8:30
a.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania.
Richard S. Friedman, Esq.
600 N. Second Street
Penthouse Suite
P.O. Box 984
Harrisburg, PA 17108
Attorney for Plaintiff
Maria P. Cognetti, Esq.
200 North Third Street
Twelfth Floor
P.O. Box 689
Harrisburg, PA 17108-0689
Attorney for Defendant
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BY THE COURT,
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ALBERT B. CARLSON,
Plaintiff
V.
ILONA A. CARLSON,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5399 Civil
CIVIL ACTION - LAW
VISITATION
ORDER
AND NOW, this day of , 1999,
upon consideration of the Petition for Special Relief, and in
accordance with Rule 1915.13, it is hereby ORDERED and DECREED
that Plaintiff shall be entitled to temporary custody of Brett T.
Carlson on each Wednesday from 5:00 p.m. until 8:00 p.m., and
from Friday, September , 1999, at 5:00 p.m. until Sunday,
September , 1999, at 8:00 p.m., and alternate weekends
thereafter until further Order of Court.
BY THE COURT:
ALBERT B. CARLSON,
Plaintiff
V.
ILONA A. CARLSON,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5399 Civil
CIVIL ACTION - LAW
VISITATION
PETITION FOR SPECIAL RELIEF
1. The Plaintiff is Albert B. Carlson, who resides at
6160 Springford Drive C-2, Harrisburg, Dauphin County,
Pennsylvania 17111.
2. The Defendant is Ilona A. Carlson, who resides at
810 Riverview Rd., Lemoyne, Cumberland County, Pennsylvania
17043.
3. The Plaintiff and Defendant are the parents of
Brett T. Carlson, who is presently 15 years of age.
4. The child resides with the Defendant.
5. On September 2, 1999, a Complaint for Visitation
was filed, which is attached hereto, marked Exhibit "A", and
incorporated herein by reference.
6. This Petition for Special Relief is filed pursuant
to Rule 1915.13, since the Defendant has failed and refused to
allow the Plaintiff any contact by telephone or otherwise with
the child, and has refused visitation with the child for a period
of at least three (3) weeks.
7. The child suffers from chronic colitis, and his
medical history indicates that in the past, disagreements such as
this between his parents have caused exacerbation of his
symptoms.
WHEREFORE, Petitioner is requesting an Order of Special
Relief awarding of temporary custody on each Wednesday from 5:00
p.m. until 8:00 p.m., and on alternate weekends commencing with
the weekend following the signing of this order, from Friday at
5:00 p.m. until Sunday at 8:00 p.m., and further directing
Defendant to be brought before the Court for a hearing.
Respectfully submitted,
Date:
FRIEDMAN & KING, P.C.
uuru rricwnuu,
600 N. econd Street
Penthouse Suite
P. 0. Box 984
Harrisburg, PA 17108
(717) 236-8000
f/p:domestic\carlson.pet
VERIFICATION
I, Albert B. Carlson, hereby acknowledge that I am the
Plaintiff in the foregoing action; that I have read the foregoing
Petition for Special Relief; and the facts stated therein are
true and correct to the best of my knowledge, information and
belief.
I understand that any false statements herein are made
subject to penalties of 18 Pa. C.S. Section 4904, relating to
unsworn falsification to authorities.
Albert B. Carlson
Dated ----?" }?? j_h(X)7?? ??
rte.
?.
ALBERT B. CARLSON, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY,, PENNSYLVANIA
V. NO. 9F- S'3UN / 7 00, l
ILONA A. CARLSON, CIVIL ACTION - LAW
Defendant VISITATION
ORDER OF COURT
AND NOW, this , 1999, upon
consideration of the attached Complaint, it is hereby directed
that the above parties and their respective counsel appear before
Esquire, the conciliator,
at Pennsylvania,
on the day of , 1999, at
A.M./P.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. All children age five or older may be present
at the Conference. Failure to appear at the Conference may
provide grounds for the entry of a temporary or permanent order.
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
1-800-990-9108
FOR THE COURT:
By:
Custody Conciliator
ALBERT B. CARLSON,
Plaintiff
V.
ILONA A. CARLSON,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - LAW
VISITATION
COMPLAINT FOR VISITATION
1. The Plaintiff is Albert B. Carlson, residing at
6160 Springford Drive C-2, Harrisburg, Dauphin County,
Pennsylvania 17111.
c: -
2. The Defendant is Ilona A. Carlson, residing at 810
Riverview Rd., Lemoyne, Cumberland County, Pennsylvania .17043.
3. Plaintiff seeks custody of the following child:
NAME PRESENT RESIDENCE AGE'S
Brett T. Carlson 810 Riverview Rd. 15
Lemoyne, PA 17043
The child was born out of wedlock.
The child is presently in the custody of
Defendant, Ilona A. Carlson, who resides at 810 Riverview Rd.,
Lemoyne, Pennsylvania 17043.
During the past five (5) years, the child has resided
with the following persons and at the following addresses:
NAME RESIDENCE DATE
Albert Carlson, 810 Riverview Rd. 9/1/94 - 11/98
and Ilona Carlson Lemoyne, PA 17043
Ilona Carlson 810 Riverview Rd. 11/98 to present
Lemoyne, PA 17043
The mother of the child is Ilona A. Carlson, currently
residing at 810 Riverview Rd., Lemoyne, PA 17043. She is
married.
The father of the child is Albert B. Carlson, currently
residing at 6160 Springford Drive C-2, Harrisburg, PA 17111. He
is married.
4. The relationship of the Plaintiff to the child is
that of Father. The Plaintiff currently resides alone.
5. The relationship of the Defendant to the child is
that of,Mother. The Defendant currently resides with the
following persons:
NAME
Brett T. Carlson
Son
6. Plaintiff has not participated as a party or
witness, or in another capacity, in other litigation concerning
the custody of the child in this or another court.
Plaintiff has no information of a custody proceeding
concerning the child pending in another court of this
Commonwealth.
Plaintiff does not know of a person not a party to the
proceeding who has physical custody of the child or claims to
have custody or visitation rights with respect to the child.
7. The best interest and permanent welfare of the
child will be served by granting the relief requested because the
Defendant has refused any communication and visitation between
Plaintiff and his son, which is contrary to the best interest of
the child.
8. Each parent whose parental rights to the child have
not been terminated, and the person who has physical custody of
the child, has been named a party to this action. There are no
other parties who are known to have or claim a right to custody
or visitation of the child.
WHEREFORE, Plaintiff requests the Court to grant
visitation of the minor child, Brett T. Carlson.
Date: Respectfully submitted,
FRIEDMAN & KING, P.C.
600 N. S cond Street
Penthou a Suite
P.O. B 984
Harrisburg PA 17108
(73.7) 236-8000
f/p:domestic\carlson.vis
1. 1
VERIFICATION
I, Albert B. Carlson, hereby acknowledge that I am the
Plaintiff in the foregoing action; that I have read the foregoing
Complaint for Visitation; and the facts stated therein are true
and correct to the best of my knowledge, information and belief.
I understand that any false statements herein are made
subject to penalties of IS Pa. C.S. Section 4904, relating to
unsworn falsification to authorities.
ert B on
Dated: ' ( ???
ALBERT B. CARLSON,
Plaintiff
V.
ILONA A. CARLSON,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5399 Civil
CIVIL ACTION - LAW
VISITATION
CERTIFICATE OF SERVICE
I, Richard S. Friedman, Esquire, hereby certify that on
September 3, 1999, I served a copy of the within Petition for
Special Relief, by depositing same in the United States Mail,
first class, postage prepaid, addressed as follows:
Maria P. Cognetti, Esquire
200 N. Third Street
Twelfth Floor
P. 0. Box 689
Harrisburg, PA 17108-0689
FRIEDMAN & KING, P.C.
.+ v v. raicuwa??,
600 N/Second Street
Penth se suite
P. 0. Box 984
Harrisburg, PA 17108
(717) 236-8000
ALBERT B. CARLSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
ILONA A. CARLSON, .
Defendant NO. 99-5399 CIVIL TERM
ORDER OF COURT
AND NOW, this jQk day of September, 1999, upon relation of Richard S,
Friedman, Esq., that the parties have signed a stipulation regarding the petition for special
relief, the hearing previously scheduled for September 10, 1999, is cancelled.
BY THE COURT,
Richard S. Friedman, Esq.
600 N. Second Street
Penthouse Suite
P.O. Box 984
Harrisburg, PA 17108
Attorney for Plaintiff
esley Oler,
0 n ?c L.?l 9/i o f 44,
Maria P. Cognetti, Esq.
200 North Third Street
Twelfth Floor
P.O. Box 689
Harrisburg, PA 17108-0689
Attorney for Defendant
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ALBERT B. CARLSON, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 9?- S.)?q C ut l
ILONA A. CARLSON, CIVIL ACTION - LAW
Defendant VISITATION
ORDER OF COURT
AND NOW, this Q11"9?1 1999, upon
consideration of the attached Complaint, 1-t is hereby directed
that the abov?e? r(a?rties and their respective counsel appear before
at S'? '?•:?` Esquire, the conciliator,
3e -6f ?4k? q Pennsylvania,
o the day f 1999,at
/P.M., for a Pre-hearing Custddy conference. At such
c2eerence, 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 be present
at the Conference. Failure to appear at the Conference may
provide grounds for the entry of a temporary or permanent order.
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
1-800-990-9108
FOR THE COURT:
By: _ w'sn- 6 X13 ?'i ? f'?ry?? ,
Custody Conciliator` V
ALBERT B. CARLSON,
Plaintiff
V.
ILONA A. CARLSON,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. f 9w C(..y ?i
CIVIL ACTION - LAW
VISITATION
COMPLAINT FOR VISITATION
1. The Plaintiff is Albert B. Carlson, residing at
6160 Springford Drive C-2, Harrisburg, Dauphin County,
Pennsylvania 17111.
2. The Defendant is Ilona A. Carlson, residing at 810
Riverview Rd., Lemoyne, Cumberland County, Pennsylvania 17043.
3. Plaintiff seeks custody of the following child:
NAME PRESENT RESIDENCE AGE
Brett T. Carlson 810 Riverview Rd. 15
Lemoyne, PA 17043
The child was born out of wedlock.
The child is presently in the custody of
Defendant, Ilona A. Carlson, who resides at 810 Riverview Rd.,
Lemoyne, Pennsylvania 17043.
During the past five (5) years, the child has resided
with the following persons and at the following addresses:
NAME
Albert Carlson,
and Ilona Carlson
RESIDENCE
810 Riverview Rd.
Lemoyne, PA 17043
DATE
9/1/94 - 11/98
Ilona Carlson 810 Riverview Rd. 11/98 to present
Lemoyne, PA 17043
I
The mother of the child is Ilona A. Carlson, currently
residing at 810 Riverview Rd., Lemoyne, PA 17043. She is
married.
The father of the child is Albert B. Carlson, currently
residing at 6160 Springford Drive C-2, Harrisburg, PA 17111. He
is married.
4. The relationship of the Plaintiff to the child is
that of Father. The Plaintiff currently resides alone.
5. The relationship of the Defendant to the child is
that of Mother. The Defendant currently resides with the
following persons:
NAME RELATIONSHIP
Brett T. Carlson Son
6. Plaintiff has not participated as a party or
witness, or in another capacity, in other litigation concerning
the custody of the child in this or another, court.
Plaintiff has no information of a custody proceeding
concerning the child pending in another court of this
Commonwealth.
Plaintiff does not know of a person not a party to the
proceeding who has physical custody of the child or claims to
have custody or visitation rights with respect to the child.
7. The best interest and permanent welfare of the
child will be served by granting the relief requested because the
Defendant has refused any communication and visitation between
Plaintiff and his son, which is contrary to the best interest of
the child.
8. Each parent whose parental rights to the child have
not been terminated, and the person who has physical custody of
the child, has been named a party to this action. There are no
other parties who are known to have or claim a right to custody
or visitation of the child.
WHEREFORE, Plaintiff requests the Court to grant
visitation of the minor child, Brett T. Carlson.
Date:
Respectfully submitted,
FRIEDMAN & KING, P.C.
f\1F.11Q14 • L'11G.IlIlQ 11,
600 N. S cond Street
Penthou a Suite
P.O. B 984
Harrisburg PA 17108
(717) 236-8000
f/p:domestic\carlson.vis
I, Albert B. Carlson, hereby acknowledge that I am the
Plaintiff in the foregoing action; that I have read the foregoing
complaint for Visitation; and the facts stated therein are true
and correct to the best of my knowledge, information and belief.
I understand that any false statements herein are made
subject to penalties of IS Pa. C.S. Section 4904, relating to
unsworn falsification to authorities.
L?
ert B. Carlson
Dated: ' 9" q
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ALBERT B. CARLSON, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
NO.
Q9- s2 27
ILONA A. CARLSON, CIVIL ACTION - LAW
Defendant VISITATION
ORDER OF COURT
AND NOW, this , 1999, upon
consideration of the attached Complaint H is hereby directed
that the above parties and their respective counsel appear before
Esquire, the conciliator,
at , Pennsylvania,
on the day of 1999, at
A.M./P.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. All children age five or older may be present
at the Conference. Failure to appear at the Conference may
provide grounds for the entry of a temporary or permanent order.
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
1-800-990-9108
FOR THE COURT:
By:
Custody Conciliator
ALBERT B. CARLSON,
Plaintiff
V.
ILONA A. CARLSON,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - LAW
VISITATION
COMPLAINT FOR VISITATION
1. The Plaintiff is Albert B. Carlson, residing at
6160 Springford Drive C-2, Harrisburg, Dauphin County,
Pennsylvania 17111.
2. The Defendant is Ilona A. Carlson, residing at 810
Riverview Rd., Lemoyne, Cumberland County, Pennsylvania 17043.
3. Plaintiff seeks custody of the following child:
NAME PRESENT RESIDENCE AGE
Brett T. Carlson 810 Riverview Rd. 15
Lemoyne, PA 17043
The child was born out of wedlock.
The child is presently in the custody of
Defendant, Ilona A. Carlson, who resides at 810 Riverview Rd.,
Lemoyne, Pennsylvania 17043.
During the past five (5) years, the child has resided
with the following persons and at the following addresses:
NAME
Albert Carlson,
and Ilona Carlson
RESIDENCE
810 Riverview Rd.
Lemoyne, PA 17043
DATE
9/1/94 - 11/98
Ilona Carlson 810 Riverview Rd. 11/98 to present
Lemoyne, PA 17043
The mother of the child is Ilona A. Carlson, currently
residing at 810 Riverview Rd., Lemoyne, PA 17043. she is
married.
The father of the child is Albert B. Carlson, currently
residing at 6160 Springford Drive C-2, Harrisburg, PA 17111. He
is married.
4. The relationship of the Plaintiff to the child is
that of Father. The Plaintiff currently resides alone.
5. The relationship of the Defendant to the child is
that of.Mother. The Defendant currently resides with the
following persons:
NAME RELATIONSHIP
Brett T. Carlson Son
6. Plaintiff has not participated as a party or
witness, or in another capacity, in other litigation concerning
the custody of the child in this or another court.
Plaintiff has no information of a custody proceeding
concerning the child pending in another court of this
Commonwealth.
Plaintiff does not know of a person not a party to the
proceeding who has physical custody of the child or claims to
have custody or visitation rights with respect to the child.
7. The best interest and permanent welfare of the
child will be served by granting the relief requested because the
Defendant has refused any communication and visitation between
Plaintiff and his son, which is contrary to the best interest of
the child.
8. Each parent whose parental rights to the child have
not been terminated, and the person who has physical custody of
the child, has been named a party to this action. There are no
other parties who are known to have or claim a right to custody
or visitation of the child.
WHEREFORE, Plaintiff requests the Court to grant
visitation of the minor child, Brett T. Carlson.
Date:
Respectfully submitted,
FRIEDMAN & KING, P.C.
600 N. S cond Street
Penthou a Suite
P.O. B 984
Harrisburg PA 17108
(717) 236-8000
f/p:domestic\carlson.vis
VERIFICATION
I, Albert B. Carlson, hereby acknowledge that I am the
Plaintiff in the foregoing action; that I have read the foregoing
Complaint for Visitation; and the facts stated therein are true
and correct to the best of my knowledge, information and belief.
I understand that any false statements herein are made
subject to penalties of 18 Pa. C.S. Section 4904, relating to
unsworn falsification to authorities.
ert B. Carlson
Dated: ??'?7 ?
FRIEDMAN & KIN(3. P.C.
ATTORNEYS AT LAW
600 N. SECOND ST.
PENTHOUSE SUITE
P.O. Box 884
HARRISBURG, PENNSYLVANIA 17108
MARIA P COGNETTI ESQUIRE
200 N THIRD STREET
TWELFTH FLOOR
P O BOX 689
HARRISBURG PA 17108-0689
SEP - 3 1999
ALBERT B. CARLSON, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 99- S39 q
Lrvi c 1?.? 1
ILONA A. CARLSON, CIVIL ACTION - LAW
Defendant VISITATION
ORDER OF COURT
AND NOW, this 1999, upon
consideration of the attached Complaint, it is hereby directed
that the above parties and their respective counsel appear before
Esquire, the conciliator,
at , Pennsylvania,
on the day of , 1999, at
A.M./P.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. All children age five or older may be present
at the Conference. Failure to appear at the Conference may
provide grounds for the entry of a temporary or permanent order.
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
1-800-990-9108
FOR THE COURT:
By:
Custody Conciliator
ALBERT B. CARLSON SEP - 3 1999
, IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. T ( _
ILONA U F?i l( ?v?
A. CARLSON, CIVIL ACTION - LAW l
Defendant VISITATION
ORDER OF COURT
AND NOW, this , 1999, upon
consideration of the attached Complaint, 1t is hereby directed
that the above parties and their respective counsel appear before
Esquire, the conciliator,
at , Pennsylvania,
on the day of , 1999, at
A.M./P.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. All children age five or older may be present
at the Conference. Failure to appear at the Conference may
provide grounds for the entry of a temporary or permanent order.
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
1-800-990-9108
FOR THE COURT:
By:
Custody Conciliator
ALBERT B. CARLSON, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 99- S'? 9T ouc (
ILONA A. CARLSON, CIVIL ACTION - LAW
Defendant VISITATION
ORDER OF COURT
AND NOW, this , 1999, upon
consideration of the attached Complaint, it is hereby directed
that the above parties and their respective counsel appear before
Esquire, the conciliator,
at , Pennsylvania,
on the day of , 1999, at
A.M./P.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. All children age five or older may be present
at the Conference. Failure to appear at the Conference may
provide grounds for the entry of a temporary or permanent order.
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
1-800-990-9108
FOR THE COURT:
By:
Custody Conciliator
1
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FRIEDMAN & KING, P.C.
A7"PORNEYS Al I.AW
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PE-Nl9RJUSe Sore
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?ANHiSDURO. PENNSYLVANIA 171011
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ALBERT B. CARLSON,
Plaintiff
V.
ILONA A. CARLSON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
No. 99-5399 Civil
CIVIL ACTION - LAW
VISITATION
r I
AND NOW, this ?`) `day of 1999, upon
consideration of the within stipulation, it is hereby
ORDERED AND DECREED that the custody of Brett T. Carlson be
according to the terms of the within stipulation.
BY THE COURT:
I
ALBERT B. CARLSON, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. No. 99-5399 Civil
ILONA A. CARLSON, CIVIL ACTION - LAW
Defendant VISITATION
WHEREAS, the parties are married but separated; and
WHEREAS, the parties are the parents of Brett T. Carlson,
age 15; and
WHEREAS, the parties have come to an agreement regarding the
custody and visitation of their minor child, and wish to set
forth said agreement in writing, understanding that they will be
legally bound thereby;
NOW THEREFORE, it is hereby stipulated by and between the
parties as follows:
1. Plaintiff, Albert B. Carlson, hereinafter referred to as
Father, is represented by Richard S. Friedman, Esquire.
Defendant, Ilona A. Carlson, hereinafter referred to as Mother,
was previously represented by Maria P. Cognetti, Esquire. Mr.
Friedman has been advised by personnel at the office of Ms.
Cognetti, and by Mother, that Ms. Cognetti no longer represents
Mother. Mr. Friedman has explained to Mother that she has the
absolute right to sole and independent counsel to advise her in
the within matter. Mother understands that Mr. Friedman only
represents Father. Mother acknowledges that Mr. Friedman
prepared the within Stipulation based on the agreement of the
parties as it was related to him. Mother affirms, by execution
of the within Stipulation, that she has chosen not to retain
other counsel, that she fully understands the intent and legal
effect of the within Stipulation, and that she hereby waives any
claim for conflict of interest which she could otherwise assert
against Mr. Friedman by virtue of his preparation of the within
Stipulation.
2. The parties agree to share legal custody of Brett
Carlson.
3. Primary physical custody of Brett Carlson shall be with
Mother, subject to the following visitation by Father:
A. Every other weekend from Friday at 5:00 p.m. until
Sunday at 9:00 p.m., commencing the weekend of Friday, September
10, 1999. In the event any said weekend is a holiday weekend,
Father's visitation shall extend until Monday at 8:00 p.m. or
shall commence Thursday at 5:00 p.m., whichever date shall
legally be celebrated as a holiday.
B. Alternating holidays (Thanksgiving, New Year's Day,
Easter, Memorial Day, July 4, and Labor Day) from 10:00 a.m.
until 9:00 p.m., commencing Thanksgiving, 1999.
C. Two (2) two (2) week uninterrupted periods during
each summer, subject to thirty (30) days written notice to
Mother.
D. Every Wednesday from 5:00 p.m. until 9:00 p.m. In
the event of conflicting school activities, or in the event
Father's work schedule conflicts with said visitation, Father and
Brett shall be allowed to change said visitation to any other
time mutually agreeable to them, without the consent of Mother.
E. Every Father's Day from 10:00 a.m. until 9:00 p.m.
4. The parties further agree as follows:
A. Mother shall enjoy two (2) two (2) week
uninterrupted periods during each summer, subject to thirty (30)
days written notice to Father.
B. Mother shall have physical custody of Brett every
Mother's Day commencing 10:00 a.m.
5. Regarding the Christmas holiday, the parties shall from
year to year alternate the two portions of the holiday, with
Mother receiving portion A in 1999 and Father receiving portion
B:
A. From the end of the last day of school prior to
Christmas until 10:00 a.m. Christmas Day.
B. From 10:00 a.m. Christmas Day until 9:00 p.m. on
the last day prior to Brett returning to school.
6. In the event of a conflict between the custody dictated
by a weekend or by a holiday, the holiday schedule shall prevail.
7. The party presently enjoying physical custody of Brett
shall allow such telephone access to the other party as Brett
desires.
8. Neither party shall malign or disparage the other party
in the presence of Brett. Each party shall take such actions as
are necessary to encourage a continued warm and loving
relationship between Brett and the other party, both parties
acknowledging that loving relationships with both parents are
essential to their son's physical and emotional health.
9. In the event Brett becomes seriously ill while in the
custody of one party, such that medical intervention is required,
said party shall immediately notify the other party of said
illness and allow all reasonable access to Brett.
10. The parties shall cooperate in trading periods of
physical custody, as such trading may be necessitated by their
schedules or other circumstances. In the event Brett determines
that he wants to alter this schedule at any time, his decision
shall be binding.
11. The parties consent to the entry of an Order
incorporating all the terms of the within Stipulation, and
understand that they will be bound hereby.
IN WITNESS WHEREOF, the parties hereto have hereunto set
their hands and seals the day and year first above written.
WITNESS: DDy
QQ?11 N??
Ilona A. Carlson
?klbert B. Carlson
RSF:ka:dompld:carlson.sti