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HomeMy WebLinkAbout99-076361 JOHN M. PARR Plaintiff VS ROVENA M. BRIDI Defendant ORDER OF COURT respective counsel appear before J? pay of 6 t\y,? (mkt r ? (6 0-o-b( , Pennsylvania, on the at y?'- Q_ Of./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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Q4 - 7L36 CIVIL ACTION -LAW IN CUSTODY AND NOW, this _?A_day of 2000, upon consideration of the attached complaint, it is hereby directed that the above parties and their U \,,. -N G„\ rrtil Esquire, the conciliator, at FORTIIE COURT: By' y Conciliator V C \i ) Custody C YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT TO oR. TELEPHONE SET FORTH BELOW TO FIND OUT WHERE YOU OC N GET LEGAL HELP.HC OFFICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-1 I?. i /G Zv fit / ?c<<? ?k .s/ ?Il?i? ice" 4, JOHN M. PARR VS IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO. 9 9 7G 3G CG T . ROVENA M. BRIDI Defendant CIVIL ACTION - LAW IN CUSTODY TO THE HONORABLE JUDGE OF SAID COURT: COMPLAINT F )R C USTODY 1. The Plaintiff is John M. Parr, residing at 6871 Huntingdon Street, Harrisburg, Dauphin County, Pennsylvania 17111. 2. The Defendant is Rovena M. Bridi, residing at 508 S. East Enola Road, Enola, Cumberland County, Pennsylvania 17025. 3. The Plaintiff seeks physical and legal custody of the following child: Name: Hannah N. Parr Ii i A -- Present Residence: 508 S. East Enola Road, Enola, Cumberland County, Pennsylvania 17025. Date of Birth: April 26, 1999 4. The child was born out of wedlock. 5. The child is presently in the custody of the Defendant. 6. Since birth, the child has resided with the following person at the following address: Name: Rovena M. Bridi, Mother. Address: 508 S. East Enola Road, Enola, Cumberland County, Pennsylvania 17025. Date: February 1999 to Present 7. The mother of the child is Rovena M. Bridi, Defendant. 8. The father of the child is John M. Parr, Plaintiff. 9. The relationship of the Plaintiff to the child is that of father. The Plaintiff currently resides with the following: Name: Mr. & Mrs. Parr Relationship: Mother & Father 10. The relationship of the Defendant to the child is that of Mother. The defendant currently resides with the following: Name: Austin Yadlosky, Relationship: Son, age 4 Name: Hannah N. Parr, Relationship: Daughter, age 19 months. 11. The Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning custody of the child in this or another court. 12. The 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. 13. The best interest and permanent welfare of the child will be served by granting primary physical custody to the Plaintiff, Tina Bridge. 14. 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 as parties to this action. WHEREFORE, the Plaintiff, John M. Parr, respectfully requests This Honorable Court to grant physical and legal custody of the minor child, Hannah N. Parr to him. Respectfully submitted, i Bryan S alk Atto y at Law 108-112 Walnut Street Harrisburg, PA 17101 (717) 238-5113 I.D. No. 63881 JOHN M. PARR Plaintiff VS ROVENA M. BRIDI Defendant : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN CUSTODY VERIFICATION I verify the statements made in this pleading are true and correct. I understand false statement herein are made subject to the penalties at 18 Pa.C.S.A., §409 relating to Unswom Falsification to Authorities. DATE: 1?42 21-4;7? John f. Parr, Plaintiff 11 JOHN M. PARR VS : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA ROVENA M. BRIDI Defendant NO. CIVIL ACTION - LAW IN CUSTODY CERTIFICATE OF SERVICE i I hereby certify that on the2,1af day of December, 1999, I served by first class mail, return receipt requested, a copy of the Plaintiffs Complaint upon the person named below, in accordance with the applicable Rules of Procedure, addressed as follows: Rovena M. Bridi 508 S. East Enola Road Enola, Pennsylvania 17025 ?On S. Walk Attorney ID No. 63881 108-112 Walnut Street Harrisburg, PA 17101 (717) 238-5113 Counsel for Plaintiff Bryan S. Walk ATTORNEY AT LAW DEc 23 108.112 Walnut Street 999 ?? Harrisburg, PA 17101 (717) 238-5113 e d J ? ro .r J M -w,_c; - Jet O ?' ? nc7 Li 0 0 ? ?i?r L: ?:Jl ? 'O ?lL ?: L: :i7L V/ e? 1 o r? v 4 (a: `F? r FEB 2 9 2000''h JOHN M. PARR, IN THE COURT OF COMMON PLEAS Of Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW ROVENA M. BRIDI, NO. 99-7636 CIVIL Defendant IN CUSTODY COURT ORDER .?7 AND NOW, this a day of February, 2000, the Conciliator being advised that the parties have reached an agreement, the Conciliator relinquishesjurisdiction. BY THE COURT, Hubert X. Gilro A squire Custody Conciliator Lr) r N _ wC o S? it 1 G `_^ - u F = ua: O o U JOHN M. PARR VS : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA ROVENA M. BRIDI Defendant : NO. 99-7636 : CIVIL ACTION - LAW : IN CUSTODY ORDER AND NOW, to wit this 6i" day of U&IO '2000, the parties having reached an agreement with regards to the best interest of and welfare of their minor child, have agreed to the following stipulation and it is hereby ORDERED AND DECREED as follows: 1. It is the intention of the parties and the parties agree that they will share joint legal custody of Hannah N. Parr, born April 26, 1999. The parties agree that major decisions concerning their child, including but not necessarily limited to, the child's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the child's best interest. Each party agrees not to impair the other party's rights to shared legal custody of the child. Each party agrees not to attempt to alienate the affections of the child from the other party. Each party shall notify the other of any activity or circumstance concerning their child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the child at the time of the emergency shall be pennitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a parent. M. $ridi. 2. Primary physical custody of the minor child shall be with the Mother, Rovena 3. Father, John Parr M. Parr, shall have partial custody of the minor child in accordance with the following schedule: a. Alternating weekends from Saturday at 9:00 a.m. until Sunday at 7:30 p.m. b. Every Saturday on non alternating weekends from 9:00 a.m. to 6:00 p,m. The father will pick up the child in the morning and the mother will pick up the child at 6: p.m. c. Father shall have custody of the child every Thursday from 9:00 a.m. until 7:30 p.m, d. On the weeks when father has child from Saturday at 9:00 a.m. to 6:00 p.m., he shall have the child on Tuesdays from 9:00 a.m. to 7:30 p.m. 4. The parents will share the following major holidays: Easter, Memorial Day, Fourth of July, Labor Day, Thanksgiving, Christmas Day and New Years Eve. The exact periods of visitation will be determined by the parties. 5. The parties agree to alternate on a yearly basis the holidays of Christmas Eve and New Year's Eve. The father will have custody of the child for Christmas Eve for the year 2000- The mother will have custody of the child for New Years Eve of the year 2000. Those holidays will alternate thereafter. 6. Father shall have custody on Father's Day of the child & mother shall have custody of the minor child on Mother's Day. 7. Both parents are entitled to two (2) weeks of uninterrupted custody during the summer. It is understood that a week is defined as seven (7) days which must include the parent's regularly scheduled custodial weekend. Each parent shall provide the other with thirty (30) days notice of his/her intention to exercise the extended custody period. 8. The holiday schedule shall take precedence over the regular custody schedule. Oil 9. Each parent shall be entitled to reasonable telephone contact with the child while the child is in the custody of the other parent. 10. Moth parents shall refrain front making derogatory comments about the other parent in the presence of the child and to the extent possible shall prevent third parties from making such comments in the presence of the child. 11. During any periods of custody or visitation the parties to this Order shall not possess or use any controlled substance, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this prohibition. BY THE J. 3La0 R KS JOHN M. PARR Plaintiff VS ROVENA M. BRIDI Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7636 CIVIL ACTION - LAW IN CUSTODY CUSTODY STIPULATION AND NOW, to wit this 22nd day of Februaa , 2000, the parties having reached an agreement with regards to the best interest of and welfare of their minor child, have agreed to the following stipulation: It is the intention of the parties and the parties agree that they will share joint legal custody of Hannah N. Parr, bom April 26, 1999. The parties agree that major decisions concerning their child, including but not necessarily limited to, the child's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the child's best interest. Each party agrees not to impair the other party's rights to shared legal custody of the child. Each party agrees not to attempt to alienate the affections of the child from the other party. Each party shall notify the other of any activity or circumstance conceming their child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a parent. 2. Primary physical custody of the minor child shall be with the Mother, Rovena M. Bridi. Father, John Parr M. Parr, shall have partial custody of the minor child in accordance with the following schedule: a. Alternating weekends from Saturday at 9:00 a.m. until Sunday at 7:30 p.m. b. Every Saturday on non alternating weekends from 9:00 a.m. to 6:00 p.m. The father will pick up the child in the morning and the mother will pick up the child at 6: p.m. c. Father shall have custody of the child every Thursday from 9:00 a.m. until 7:30 p.m. d. On the weeks when father has child from Saturday at 9:00 a.m. to 6:00 p.m., he shall have the child on Tuesdays from 9:00 a.m. to 7:30 p.m. 4. The parents will share the following major holidays: Easter, Memorial Day, Fourth of July, Labor Day, Thanksgiving, Christmas Day and New Years Eve. The exact periods of visitation will be determined by the parties. 5. The parties agree to alternate on a yearly basis the holidays of Christmas Eve and New Year's Eve. The father will have custody of the child for Christmas Eve for the year 2000. The mother will have custody of the child for New Years Eve of the year 2000. Those holidays will alternate thereafter. 6. Father shall have custody on Father's Day of the child & mother shall have custody of the minor child on Mother's Day. 7. Both parents are entitled to two (2) weeks of uninterrupted custody during the summer. It is understood that a week is defined as seven (7) days which must include the parent's regularly scheduled custodial weekend. Each parent shall provide the other with thirty (30) days notice of his/her intention to exercise the extended custody period. 8. The holiday schedule shall take precedence over the regular custody schedule. 9. Each parent shall be entitled to reasonable telephone contact with the child while the child is in the custody of the other parent. 10. Both parents shall refrain from making derogatory comments about the other parent in the presence of the child and to the extent possible shall prevent third parties from making such comments in the presence of the child. 11. During any periods of custody or visitation the parties to this Order shall not possess or use any controlled substance, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this prohibition. RespectfulIg Submitted; Bryan S. Walk, Esquire JOHN M. PARR Plaintiff VS ROVENA M. BRIDI Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7636 : CIVIL ACTION -LAW : IN CUSTODY VERIFICATION I verify that I have read the statements made in this Custody Stipulation and the agreement as set forth in the stipulation is agreed upon. I understand false statement herein are made subject to the penalties at 18 Pa.C.S.A., §409 relating to Unswom Falsification to Authorities. DATE: A'tit_- John Y. Parr, Plaintiff JOHN M. PARR VS Plaintiff ROVENA M. BRIDI Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO. 99-7636 : CIVIL ACTION - LAW : IN CUSTODY VERIFICATION I verify that I have read the statements made in this Custody Stipulation and the agreement as set forth in the stipulation is agreed upon, I understand false statement herein are made subject to the penalties at 18 Pa.C.S.A., §409 relating to Unswom Falsification to Authorities. DATE; o? as d? C? R vena M. Bridi, Defendant BY SIGNING THIS STIPULATION, EACH PARTY ACKNOWLEDGES HAVING READ AND UNDERSTOOD THE ENTIRE AGREEMENT, AND EACH PARTY ACKNOWLEDGES THAT THE PROVISIONS OF THIS AGREEMENT SHALL BE AS BINDING UPON THE PARTIES AS IF THEY WERE ORDERED BY THE COURT AFTER A FULL HEARING. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby have hereunto set their hands and seals the day and year bove en. Joh . Parr R vena M. Sridi COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN day of 2000, before me, a On this, the A?fli Notary Public, the undersigned officer, personally appeared John M. Parr, known to me or satisfactorily proven to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. Notarial Sot! o Flasomary L. Dablar, Notary Pu. !!41, Hmtlsnurg Dmphin County My Commission Expires ... _„ zc MLmcer, l'emuyiVama Y\scC]I:an ut Notary Publc•.: COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN On this, the l r" day of -, 2000, before me, a Notary Public, the undersigned officer, personally appeared Rovena M. Bridi, known to me or satisfactorily proven to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. ubli Notarialblor, Scal Notary P _L // Acsam?ry L. c // My Commission Expi es Do; _ rs,.. ,. r,- • ,,, coanrv I:Sy C' r," !nn cxpms Novi 29, e6D2 bt.;a M:r, Pe nnSyt..... AS:caali0n 01 NGlanes Notary Public 0 i zz? C?j L1_ CIS:" Ci•'• C\ W