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HomeMy WebLinkAbout99-06352 I C r ? i 41 '+y I l Y ?2t? i ?gg. I ?4 rk ? Q ,f VN` 1. J R +T r F 3 ? l i. ` t l F, O A Y i4 ?. +/r 144 F)^ ! j r Z k 5 +){! r 1 5„r r- a! e rrs c Fv- s,, r:f?C rs r Y.. ? M wK FFew. r- 4 , x cis x s h ??4? r K ?? r 4 Y ! y ` ' P ? .ty IV3 ? ¢ ?' IF, - Y rv ?. { T' N15'x c y ^^ ? .d? , ? W A4! it 1} ?} )? 5 • v i &OVA , xr+ 41i L t5 i1!` t Fr ; ?. F ? i t v r i I: Kt m2trnmel Min : IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, : PENNSYLVANIA V. CIVIL ACTION LAW . SkFk?c.tl M :Z.?,wm?cnan . Defendant :NO .6?Sa CIVIL 1999 : CUSTODY VISITATION ORDER OF COURT And now, this IU 191 cl , upon consideration of the attached complaint, it is hereby directed that the above parties and their respective counsel appear before Mir Inn r- 1 L. Rri\nS , Esquire, the conciliator, at J Pennsylvania, on the _=-L0_ day of , ;),=at k(1 pn--401P•M•, for a Pre-hearing Custody Conference. At such co ference, 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. FOR THE COURT: By; Custody Conciliator V (1?> 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. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800.990.9108 ria-OFFIC OTEAY 99 ort 20 PH 2: 23 CU4SF?NS`fLVANVN PIfY ? d r 1 f? r2 ;t I 4 1: d ? c, CO Pj ?LI? (• 1 v V ON °' u m 0 A v? t v ?v 1\ ?o ,y gj-,l r v 0 z 3g= WIGOELS dj WELCH I40Q North Second Sant Harrisburg, PA 17102 717/221-0900 OCTIiI ? r d n ??. s ri a U3 C-0 ] (• U lJ a% C11 0 ?. - PC a t r0 _ V N N 3g= WIG©EIS 1y WELCH I4011 Norlh Second Snrel la„lm,,,o, FA 17107 OCT 1 9 717/721-0900 KIM ZIMMERMAN, THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. Coq - 6-i `L STEPHEN M. ZIMMERMAN, : CIVIL ACTION - AT LAW Defendant : CUSTODY ORDER OF COURT You, Stephen M, Zimmerman, Defendant in the above-captioned custody action, have been sued in court to obtain custody, partial custody or visitation of the following children: Kristen Ann Zimmerman and Shawn Michael Zimmerman You are ordered to appear in person at , on , at _ _.M., for a conciliation or mediation conference. - a pretrial conference. _ a hearing before the court. If you fail to appear as provided by this Order, an Order for custody, partial custody or visitation may be entered against you or the Court may issue a warrant for your arrest. 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. LAWYER REFERAL SERVICE COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717)240.6200 BY THE COURT: Date: J. KIM ZIMMERMAN, Plaintiff V. STEPHEN M. ZIMMERMAN, Defendant THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. CIVIL ACTION - AT LAW CUSTODY AMERICANS WITH DISABILITIES ACT OF 1990 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. BY THE COURT: Date J. KIM ZIMMERMAN, THE COURT OF COMMON PLEAS OF Plaintiff' CUMBERLAND COUNTY, PENNSYLVANIA V. No. 99 - G 3 YJ- STEPHEN M. ZIMMERMAN, : CIVIL ACTION - AT LAW Defendant : CUSTODY COMPLAINT IN CUSTODY AND NOW, the Plaintiff, Kim Zimmerman, by and through her attorney, Jeann6 B. Wigbels, Esquire, makes the following Complaint in Custody: 1. The Plaintiff, Kim Zimmerman is an adult individual who currently resides at 6303 Brandy Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Defendant, Stephen M. Zimmerman, is an adult individual who currently resides at 15 Wayne Road, Camp Hill, Cumberland County, Pennsylvania, 17011. 3. There are two dependant children from this marriage, namely Kristen Ann Zimmerman, DOB April 24, 1987 and Shawn Michael Zimmerman, DOB January 23, 1989. 4. The Plaintiff seeks primary custody of the following children: Name Present Residence AU Kristen A. Zimmerman 15 Wayne Road 12 Camp Hill, PA 17011 DOB: 4/24/87 Y ac r rU? call Shawn M. Zimmerman 15 Wayne Road 10 Camp Hill, PA 17011 DOB: 1/23/89 5. The children were not bom out of wedlock. 6, The children, Kristen A. Zimmerman and Shawn M. Zimmerman, are presently in the custody of their father, Stephen M. Zimmerman, who resides at 15 Wayne Road, Camp Hill, Cumberland County, Pennsylvania, 17011. 7. During the past five years, the children resided with the following persons and at the following addresses: Name Stephen M. Zimmerman and Kim Zimmcmran 15 Wayne Road Camp Hill, PA 17011 Stephen M. Zimmerman 15 Wayne Road Camp Hill, PA 17011 Dates 1987 - June, 1999 June, 1999 - Present 8. The mother of the children is Kim Zimmerman, Plaintiff, currently residing at 6303 Brandy Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 9. The father of the children is Stephen M. Zimmerman, Defendant, currently residing at 15 Wayne Road, Camp Hill, Cumberland County, Pennsylvania, 17055. 10. Plaintiff is presently married to Defendant, although they have been separated since June, 1999. 11. The relationship of the Plaintiff to the children is that of natural mother. 12. The relationship of the Defendant to the children is that of natural father. To Plaintiffs knowledge, Defendant currently resides with Kristen A. Zimmerman (daughter) and Shawn M. Zimmerman (son). However, it is not known if Defendant is residing with anyone else. 13. 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. 14. Plaintiff does not know of a person not a party to the proceedings who has physical custody of any of the children or claims to have physical custody or visitation rights with respect to the children. 15. The best interests and permanent welfare of the child will be served by granting the relief requested because: (a) Plaintiff is the natural mother of the children. (b) Plaintiff has established a relationship with the children. (c) Plaintiff desires to continue exercising parental duties and enjoys the love and affection of the children. (d) The children should be permitted to enjoy the love, affection, and emotional support which can be provided by their natural mother. (e) The children would benefit from continued custody with their natural mother. 16. Each parent whose parental tights 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. No other persons are known to have or claim a right to custody or visitation of the children to be given notice of the pendency of this action and the right to intervene. WHEREFORE, Plaintiff respectfully requests that he be granted primary physical custody of her children subject to periods of visitation with Defendant. Respectfully submitted, , Jcgdnd B. Wigbels, Esquire 4TTORNEY FOR PLAINTIFF 1400 N. Second Street Harrisburg, PA 17102 (717) 221-0900 // Supreme Ct. ID No. 68735 Date: Q h3( l KIM ZIMMERMAN, THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. STEPHEN M. ZIMMERMAN, : CIVIL ACTION - AT LAW Defendant CUSTODY VERIFICATION I, Kim Zimmerman, hereby verify that the statements made in the foregoing Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities. Date: Signature: / KIM ZIMMERMAN z yf, t[ li M N WI 7 ? 1a II ` ? aCl C KIM ZIMMERMAN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. No. 99.6352 Civil STEPHEN M, ZIMMERMAN, CIVIL ACTION -LAW Defendant CUSTODY PRAECIPE TO DISCONTINUE To the Prothonotary: Please mark the above-referenced custody action discontinued and dismissed. BY: DATED: 11 4 4 ]eann B. Costopoulos, Esquire CO OPOULOS & WELCH 1400 North Second Street Harrisburg, PA 17102 (717) 221-0900 PA Supreme Ct. ID No. 68735 ATTORNEY FOR PLAINTIFF I KIM ZIMMERMAN, Plaintifr V. STEPHEN M. ZIMMERMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99-6352 Civil CIVIL ACTION -LAW CUSTODY CERTIFICATE OF SERVICE 1, )eannd B. Costopoulos, Esquire, hereby certify that I am this day serving a copy of the foregoing Praecipe to Discontinue upon the person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of the same in the United States Mail, at Harrisburg, Pennsylvania, through first class certified mail, prepaid and addressed as follows: Stephen M. Zimmerman 15 Wayne Road Camp Hill, PA 17011 Michael Bangs, Esquire 302 S. 18a' Street Camp Hill, PA 17011 BY: #6BS & WELCH 1400 North Second Street Harrisburg, PA 17102 ID4 68735 Tel. (717) 221-0900 ATTORNEY FOR PLAINTIFF Date: l X. KIM ZIMMERMAN, ) Plaintiff ) VS. ) STEPHEN M. ZIMMERMAN, ) Defendant ) NOV s z t? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6352 CIVIL TERM CIVIL ACTION - CUSTODY ORDER AND NOW this /ff^ day of/ ?'o , 1999, it being reported to the Conciliator that the parties have reached an agreement which makes further proceedings unnecessary, the undersigned Conciliator hereby relinquishes jurisdiction and returns the matter to the Court Administrator. If either of the parties wishes further proceedings in this action, they should petition the Court anew. FOR THE COURT, _ &aj Z /z, MICHAEL L. BAN Custody Conciliator cc: Jeanne B. Costopoulos, Esquire Mr. Stephen M. Zimmerman r: r f+7 CC b? O. M q? ` ? s m