The URL can be used to link to this page

Home My WebLink About99-07321a I;zt 1-1 VIRGINIA 1. ANDERSON, Plaintiff V. WILLIAM M. ANDERSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 73- I CIVIL TERM CIVIL ACTION - LAW CUSTODY ACTION ORDER OF COURT AND NOW, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before Esquire, the Conciliator, at on the Q day of y (1 Q??? ?-, at an`= Q•N• 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. Either party may bring the child who is the subject of this custody action to the conference, but the child's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. For the Court, 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) 240-3166 r . -,?) .1 11 •1? 1 -r 11 • •I JJ ? ? ?' ? is ?/ 9? ?? ?? ?.?? ? ?sF??? is iy• ?? ??a ? ?? . /a // 9J lam, ???? ? G=? ?"?? VIRGINIA 1. ANDERSON, Plaintiff V. WILLIAM M. ANDERSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0. 99 - 7311 CIVIL TERM CIVIL ACTION - LAW CUSTODY ACTION CUSTODY COMPLAINT TO THE HONORABLE JUDGES OF SAID COURT: 1. The Plaintiff is Virginia L. Anderson residing at 323 Old Stone House Road, Boiling Springs, Cumberland County, Pennsylvania 17007. 2. The Defendant is William M. Anderson who resides at 1330 Indian Peg Road, Boiling Springs, Cumberland County, Pennsylvania 17007. 3. Plaintiff seeks joint legal custody and primary physical custody of the following child: PRESENT RESIDENT DOB Michaela Leslie Anderson 323 Old Stone House Rd 05/02/95 The child was born in wedlock. The child is presently in the physical custody of Virginia L. Anderson who resides at 323 Old Stone House Road, Boiling Springs, Pennsylvania. During the past five years, the child has resided with the following persons and at the following addresses: Persons Addresses Dates Mother 223 Old Stone House Rd 12/99 - present Boiling Springs, PA 17007 Mother & 1330 Indian Peg Road 1995 - 12/99 Father Boiling Springs, PA The mother of the child is Virginia L:. Anderson who currently resides at 223 Old Stone House Road, Boiling Springs, PA 17007. She is married. The father of the child is William M. Anderson who lives at 1330 Indian Peg Road, Boiling Springs, Pennsylvania 17007. He is married. 9. The relationship of Plaintiff to the child is that of mother. The Plaintiff currently resides with the following persons: Name Relationship Michaela Leslie Anderson Daughter 5. The relationship of Defendant to the child is that of father. The Defendant currently resides with the following persons: None 6. Neither party has participated as a party or witness, or in another capacity, in other litigation concerning the custody of 2 E ?i in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff does not know of a person not a party to the proceedings 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: A. Plaintiff can provide a structured home environment for the child. B. Plaintiff can properly care for her child. C. Plaintiff can provide a loving home. D. Plaintiff will place the child's interest before her own. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff requests this Honorable Court to grant her joint legal custody and primary physical custody of her child, subject to defendant's right to liberal periods of partial custody. Respectfully submitted, Thomas D. Gould, Esquire ID #36508 2 E. Main Street Shiremanstown, PA 17011 (717) 731-1461 3 I, Virginia L. Anderson, hereby certify that the foregoing CUSTODY COMPLAINT is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: )a (099 ci( Via L. Anderson Plaintiff 4 ti U _ C 'f r cn :D< zc _ 1 .l v 2,, ( ? IIIIU ? {?_/ G' cn .7 VIRGINIA L. ANDERSON, Plaintiff vs. WILLIAM M. ANDERSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7321 CIVIL TERM CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this 2_ day of Fe? CQ y 7 consideration of the attached Custody Conciliation eport, it and directed as follows: Ct C? r'7 c_J 2000, upon :D is ordered 1. The Mother, Virginia L. Anderson, and the Father, William M. Anderson, shall have shared legal custody of Mica la Leslie be Anderson, born may 2, 1995. Each parent shall have an equal 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 on alternating weekends from Friday after work through Sunday at 9:30 p.m., beginning February 4, 2000. In the event the Father has off from work on a Monday following his regular weekend period of custody, the Father shall retain custody of the Child through Monday until 7:00 p.m. During weeks following the Father's weekend periods of custody, the Father shall have custody of the Child on Tuesday from after work until 9:30 p.m. and on Thursday from after work until Friday morning, when the Father shall transport the Child to the Mother's residence before work. During weeks following the Mother's periods of weekend custody, the Father shall have custody of the Child on Monday from after work until 9:30 p.m. and from Wednesday after work through Thursday morning, when the Father shall transport the Child to the Mother's residence before work. 4. The parties shall share or alternate having custody of the Child on holidays as follows: A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon, and Segment B which shall run from Christmas Day at 12:00 noon through December 26 at 12:00 noon. The Mother shall have custody of the Child every year during Segment A and the Father shall have custody of the Child every year during Segment B. B. THANKSGIVING: The Father shall have custody of the Child every year on Thanksgiving at times to be arranged by agreement of the parties. C. EASTER: The Father shall have custody of the Child every year on Easter from 12:00 noon through 9:30 p.m. D. NEW YEARS DAY: The Father shall have custody of the Child every year on New Years Day at times to be arranged by agreement of the parties. E. MEMORIAL DAY: The Mother shall have custody of the Child every year on Memorial Day at times to be arranged by agreement of the parties. F. JULY 4TH: The Father shall have custody of the Child on July 4th in even numbered years from 9:00 a.m. until after the fireworks. The Mother shall have custody of the Child on July 4th in odd numbered years from 9:00 a.m. until after the fireworks. G. LABOR DAY: The Father shall have custody of the Child every year on Labor Day at times to be arranged by agreement of the parties. H. FATHER'S B1I=AY/MO1HER1S BIRTHDAY: The Father shall have custody of the Child every year on the Father's birthday and the Mother shall have custody of the Child every year on the Mother's birthday at times to be arranged by agreement of the parties. I. MOT'HER'S DAY/FATHER'S DAY: The Mother shall have custody of the Child every year on Mother's Day and the Father shall have custody of the Child every year on Father's Day at times to be arranged by agreement of the parties. J. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. K. In the event the Father's period of holiday custody falls either immediately before or after his period of weekend custody, the period of custody shall run continuously without interruption. 5. The Father shall be entitled to have custody of the Child each year for an additional 14 days, with no more than 7 days to be scheduled consecutively. The Mother shall be entitled to have custody of the Child for an additional 7 days each year. Each party shall provide at least 30 days advance notice to the other party of the dates which he or she has selected under this provision. 6. Unless agreed otherwise between the parties, the Father shall be responsible to provide transportation for all exchanges of custody under this Order. 7. This order is entered pursuant to an agreement of the parties at a 4 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 COURT, U cc: Thomas D. Gould, Esquire -Counsel for Mother Jacqueline M. Verney, Esquire - Counsel for Father 2 -3 --00 R k3 VIRGINIA L. ANDERSON, Plaintiff Vs. WILLIAM M. ANDERSON, Defendant IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7321 CIVIL TERM CIVIL ACTION - LAW 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 Michaela Leslie Anderson May 2, 1995 Mother 2. A Conciliation Conference was held on January 26, 2000, with the following individuals in attendance: The Mother, Virginia L. Anderson, with her counsel, Thomas D. Gould, Esquire, and the Father, William M. Anderson, with his counsel, Jacqueline M. Verney, Esquire. 3. The parties agree to entry of an order in the form as attached. L I aaoq ?7f r3-OdA :L' A.il ?w0 6 A. Date- Dawn S. Sunday, Esquire Custody Conciliator