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HomeMy WebLinkAbout99-06474 }r1 yy Yi {i ? ?v n V}Y t PE 3 ? F tiLf%t... r rR i F ? ? x yx i £ r? ww?,. F? it ?? t [ Ai? } yk ? vYY?S ll Fi?yrk. }}F: s t ?f yr r t / r r „ s N,` Ai d Qa Y P y.kK y .t #Rp??d lk :b p ? e ?d' FP r 5 r "` ?' 4?1?tx?rr ? k ? Y a sa ??? ?? ? ?` ? t }KKR Y i Ft Y rySXj? F _ ? E „Yj t? 9 I A f 'p ? a K V Wt kky' a s F K P vro c !i J ? g> A _ nj? i Y } ?x 3? iV A? ? .?Srt t s Y ? tr t } `/ s PN? j? of 31 } i a : } 4 r d s r w 4 } b? } I r } 4 ?x 4 it £ l'? ? ! ' ? „ , I 4t ?3 r' i v K 193,31,7 i F _ A i4 d .} ..? ? ?. b ?. lp ?? t f 4 r , 2 at S t, h, r ti :a i l ` l N ky' JOSEPH M.DEAVERS VS. VERONICA L. IIARTMAN IN'rijE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No. ?? - ?q7y &?tc Defendant CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, 11131X19 upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear bcforc the conciliator, I H tY h u i s day of M 19?, at t m., far a Prc-Hcaring Custody Confcrcnre. At such confcrcncc, an effort will be made to resolve the is ucs 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 tcmporarv order. All children age rive or older may also be present at the conference. Failure to appear at the confcrcncc may provide grounds for entry or n temporary or permanent order. FOR THE COURT, by: sztl?l i Custody Conciliator l 1 The Court of Common pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For inl'ommtion 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. 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 LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249.3166 BLED-041CE n,,ii: la7 ID MY v JOSEPH M. DEAVERS Vs. VERONICA L. HARTMAN Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 99. 6 "/VY C' ldu• CIVIL ACTION -- CUSTODY COMPLAINT FOR CUSTODY AND COMES NOW, JOSEPH M. DEAVERS, by his attorney, Timothy J. Colgan, Esq., and files the following Petition: 1. Plaintiff,, JOSEPH M. DEAVERS, resides at 618 Chestnut Grove Road, Dillsburg, York County, Pennsylvania since May 1999. 2. Defendant, VERONICA L. HARTMAN, resides at I Bungalow Road, Enola Cumberland County, Pennsylvania since May 1999. 3, Plaintiff and Defendant are the natural parents of one minor child, April Lynn Deavers, born 12/2/98. 4. The child was born out of wedlock. 5. The child is presently in the care and custody of the Defendant. 6. Since the birth of the child, the child resided with Plaintiff and Defendant at 312 Walnut Street, Apartment C, Lemoyne, Cumberland County, Pennsylvania from December 1998 to May 1999. From May 1999 until present, the child has resided with Defendant at I Bungalow Road, Enola, Cumberland County, Pennsylvania. 7. There are no court orders establishing custody or visitation. 8. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 9. 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 herein. WHEREFORE, Plaintiff requests the Court enter an Order granting primary physical custody and shared legal custody of the minor child to Plaintiff. Dated: LPIAZA 1-f Respectfully submitted, Timothy J. 1 . n, ire WILEY, LENOX & COLGAN, P.C. I South Baltimore Street Dillsburg, PA 17019 (717) 432-9666 I.D. #77944 Nd•rrF.MCOV A I,W)E4I VfS' Q%11'1a1S.. am VERIFICATION I, JOSEPH M. DEAVERS, verify that the statements made in this document are true and correct to the best of my knowledge, information, and belief. 1 understand that false statements herein arc made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: S: iCUFAT..ruts: MIL-IIP:HSru.ur/.4cv.IlrI) JOSEPH DEAVERS Plaintiff r S : 117 04 C v U a U !•C 3 0 T r 1999, JOSEPH M. DEAVERS, Plaintiff VS. VERONICA L. HARTMAN, Defendant : IN THE COURT OF OOMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6474 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this /9 day of T4"= , 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Joseph M. Deavers, and the Mother, Veronica L. Hartman, shall have shared legal custody of April Lynn Deavers, born December 2, 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 Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. 2. The Mother shall have primary physical custody of the Child. 3. The Father shall have partial physical custody of the Child during alternating weeks, beginning January 20, 2000, from Thursday between 4:30 and 5:00 p.m. when the Father shall pick up the Child at the babysitter through the following Monday morning when the Father shall return the Child to the babysitter before work. During the interim weeks, the Father shall have custody of the Child on Thursdays, beginning January 13, 2000 between 4:30 and 5:00 p.m. when the Father shall pick up the Child at the babysitter until 8:30 p.m. 4. The parties shall alternate having custody of the Child on holidays as follows: A. CHRISIVW: The Christmas holiday shall be divided into Segment At which shall run from 1:00 p.m. on Christmas Eve through 1:00 p.m. on Christmas Day and Segment B, which shall run from Christmas Day at 1:00 p.m. through December 26 at 1:00 p.m. The Father shall have custody of the Child during Segment A in even numbered years and during Segment B in odd numbered years. The Mother shall have custody of the Child during Segment A in odd numbered years and during Segment B in even numbered years. B. THANKSGIVING: The Thanksgiving holiday shall be divided into Segment At which shall run from the Wednesday before Thanksgiving at 1:00 p.m. through Thanksgiving Day at 1:00 p.m., and Segment B, which shall run from Thanksgiving Day at 1:00 p.m. through the Friday after Thanksgiving at 1:00 p.m. The Father shall have custody of the Child during Segment A in odd numbered years and during Segment B in even numbered years. The Mother shall have custody of the Child during Segment A in even numbered years and during Segment B in odd numbered years. C. ALTERNATING HOLIDAYS: In even numbered years# the Father shall have custody of the Child on Easter and July 4th from 9:00 a.m. until 9:00 p.m. and the Mother shall have custody of the Child on Memorial Day and Labor Day from 9:00 a.m. until 9:00 P.M. In odd numbered years, the Father shall have custody of the Child on Memorial Day and Labor Day from 9:00 a.m. until 9:00 p.m. and the Mother shall have custody of the Child on Easter and July 4th from 9:00 a.m. until 9:00 p.m. D. MOTH R'S DAY/FATHER'S DAY: The Mother shall have custody of the Child every year on Mother's Day from 9:00 a.m. until 9:00 p.m. and the Father shall have custody of the Child every year on Father's Day from 9:00 a.m. until 9:00 p.m.. E. The holilday custody schedule shall supersede and take precedence over the regular custody schedule. 5. Each party shall be entitled to have uninterrupted custody of the Child for 2 non-consecutive weeks each year upon providing 30 days advance notice to the other party. The party providing notice first shall be given preference on his or her selected dates for vacation under this provision. 6. Unless otherwise agreed between the parties, the party receiving custody of the Child shall be responsible to provide transportation for the exchange of custody. 7. The parties agree that the child shall be cared for by the Child's regular babysitter Mondays through Fridays when the Mother is working. In the event the Mother is unavailable at any other time to personally provide care for the Child for 1 hour or more during her periods of custody, the Mother shall offer the Father the opportunity to provide care for the Child before contacting other family members or third parties to provide the care. 8. 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 mutual consent. In the absence of mutual consent, the terms of this order shall control. BY THE cc: Timothy J. Colgan, Esquire - Counsel for Father Paul Taneff, Esquire - Counsel for Mother lwp4CD A714u- /-l8 -00 W r;4rCi-t;,? c c )Nfly 00 JAN 18 AH I0: L 3 CUMBEnu':;J C*JNTY PENNXVANA K? JOSEPH M. DEAVERS, Plaintiff vs. VERONICA L. HARTMAN# Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6474 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF April Lynn Deavers December 2, 1998 Mother 2. A Conciliation Conference was held on January 11, 2000, with the following individuals in attendance: The Father, Joseph M. Deavers, with his counsel, Timothy J. Colgan, Esquire, and the Mother, Veronica L. Hartman, with her counsel, Paul Taneff, Esquire. 3. The parties agreed to entry of an order in the form as attached. J n,n.u,... 15 - a??9 ??._?_ I- Dawn S. Sunday, Esquire Custody Conciliator 8 ?.7 W L of My I W , 'JH ¢ :F77 pp a ?g C O H a V ? W ? J ? © y 0. S ? a r ° N ? E n p o • l ? ? ? ? w ? V V l ? Q K 6 fi V JAN 14 znup`