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Home My WebLink About07-3122HELAINE J. KREBS, Plaintiff vs. MARK C. KREBS, Defendant COMPLAINT IN CUSTODY AND NOW comes HELAINE J. KREBS, by her attorney, Samuel L. Andes, and makes the following Complaint for custody based upon the following: 1. The Plaintiff is HELAINE J. KREBS, who resides at 204 Summer Lane, Enola, Cumberland County, Pennsylvania. 2. The Defendant is MARK C. KREBS, who resides at 2 Laurel Drive, Enola, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant are formerly husband and wife and are the parents of one minor child, Zachary P. Krebs, now age 15, born 10 February 1992. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW p 7 x/,1.2. NO. CIVIL TERM IN CUSTODY 4. During the past five years, the minor child has resided with the following persons at the following addresses: 2002 to January 2006 2 Laurel Drive Enola, PA Plaintiff and Defendant January 2006 to the present 2 Laurel Drive Enola, PA Defendant 5. The Plaintiff is the natural mother of the child. Plaintiff currently resides alone. 1 6. The Defendant is the natural father of the child. Defendant currently resides with the child. 7. The Plaintiff has not participated as a party or in any other way in any litigation concerning the custody of the child in this or any other court. The Plaintiff has no information of a custody proceeding concerning the child pending in a court of this or any other jurisdiction. Plaintiff knows of no other person not a party to this action already who has physical custody of or claims to have custody or visitation rights with the said child. 8. Plaintiff seeks an award of shared legal custody and a schedule of temporary or partial custody with the child. She believes such an order will be in the best interest of the child for the following reasons: A. It will allow and enable her to maintain and preserve a close and affectionate relationship with her son; and B. It will allow her to be reasonably involved in her child's life and growth; and C. It will give her access to information regarding the child and allow her to participate in major decisions in the child's life. 9. Plaintiff believes an order of court is required because the parties have not been able to agree upon a schedule or adequate arrangements for shared legal custody which is fair to Plaintiff or to the child. 2 10. 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 prays this Court to grant her shared legal custody of the parties' minor son and to grant her a schedule temporary custody of the child. By el L. An s Attorney for Plaintiff Supreme Court ID 17225 P.O. Box 168 Lemoyne, PA 17043 3 I verify that the statements made that any false statements in this docu (unsworn falsification to authorities). DATE: ~ in this document are true and correct. I understand ment are subject to the penalties of 18 Pa. C.S. 4904 t H LAINE J. KR 4 CERTIFICATE OF SERVICE I hereby certify that I served a copy of the foregoing document upon the Defendant by regular mail, postage prepaid, addressed as follows: Mr. Mark C. Krebs 2 Laurel Drive Enola, Pa 17025 Date: 16 May 2007 Amy M arkins cretary for Samuel L. Andes c~ ~, ~ ~ i ~ v\ r~ r.~ "~ J ~~ , .. _ 4 4 '~ i 1 ~-- C J - , ~+~ ; : _ ;. .. ~._~ -~.-i .. ~ _. ? . ~ .JJ . ~ '" ti HELAINE J. KREBS PLAINTIFF V. MARK C. KREBS DI?FF.NDANT AND NOW, [N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • 07-3122 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT Friday, May 25, 2007 _______, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on __ _ Thursday, June 14, 2007 at 10:30 AM for aPre-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 aPe five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR. THE COURT, Bv: /s/ ac ueline M. Verne Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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. YOU SHOUI_.D TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~~~''~ ~ro ~ ~ ,~~°' '~ ~~'°~v ~ a T; i~ f , # -, ,{~, <~ -~'~ ~o ,,sue. ~' ~ ~, ~ ~ E~.~~ ~ ~~'.~~'~ CG LZ ,l~~~ti ~~~:~ ~~-~i. aG HELAINE J. KREBS, ) IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, PENNSYLVANIA vs. ) CML ACTION -LAW ) NO. 07-3122 CIVIL TERM MARK C. KREBS, ) Defendant ) IN CUSTODY ACCEPTANCE OF SERVICE I hereby accept service of the Complaint filed in this matter and acknowledge receipt of a copy of the same this day. Date: 6 / ~ l Ma C. Krebs a a ~'~ G ~- '~ G ~~, ~ ~~: ~~ ~ ~ ,.. ...~ ~~ ~ ~ ~ -.. HELAINE J. KREBS, Plaintiff vs. MARK C. KREBS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Defendant STIPULATION CIVIL ACTION -LAW No. 07,3122 IN CUSTODY AND NOW this ~~' Hay of ..St`~ 2007 the above parties mutually agree that the attached Or er shall be entered by the court to resolve the matters involving the custody of their minor child Zachary. Blaine J. Krebs Date : ~ Mark C. Krebs Date:~~y ~- , ~"'" a=rt ~.~ ..ni ~ ~~ :~ :~ .-r, ~ r: ~ _ ~3 , ~. s _~;. j '} ~_ -1 l . ~i1G ?!0 ~pDa ~-~' HELAINE J. KREBS, : IN THE COURT OF COMMON PLE AS O F Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : N0.2007-3122 CIVIL ACTION - LA~J MARK C. KREBS, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 20'h day of August, 2007, the parties having reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, N1. V.~ acq ine M. Verney, Esquire, Custod, Conciliator x.:.~`=' t ~t~ .. ~. ' yA ~J Y~~~:i.} ~ i,, ~~ t t.-.-F ..~- C..~',9 ~~ ,~~~ 21j20D7~ ~~ HELAINE J. KREBS, ) IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, PENNSYLVANIA vs. ) CIVIL ACTION -LAW MARK C. KREBS, ) NO~ p7,3122 Defendant ) IN CUSTODY ORDER OF COURT AND NOW, this J~.~day of ~ n , 2007, upon the Stipulation of the parties which is attached hereto, we hereby enter the following order in this matter: 1. Legal custody of the parties minor child, Zachary P. Krebs, born February 10, 1992, shall be shared by the parties, the Plaintiff Helaine J. Krebs ("Mother") and the Defendant Mark C. Krebs ("Father"). The parties shall cooperate to exchange information regarding the child and to make mutual decisions regarding the child's health care, education, religious training and other important decisions in the child's life. 2. Primary physical custody of the child shall be with Father. 3. Mother shall have temporary or partial physical custody of the child on the following schedule: A. One weekend every month, which shall commence on the final Friday of each month, from Friday at 6:00 p.m. until Sunday at 6:00 p.m. B. Four non-consecutive weeks of vacation each summer during the child's summer vacation from school. Mother shall give Father notice of the dates she proposes for the summer vacation no later than 31 May each year and the parties shall agree upon a schedule for those weeks no later than May 31 of each year. C. Such other times as the parties may mutually agree. 4. The parties shall divide custody of the child on holidays as follows: A. Father shall have the child each Christmas Day, Easter Day, Father's Day, and every other Thanksgiving at times to be mutually agreed upon by the parties. In addition, Father shall have such other holiday time as the parties mutually agree, considering the child's schedules, wishes, and preferences for those holidays. i h ,,~ '~ f ~'~1i1 fV ~4\ .u t ,1 ;•. ,~ . B. Mother shall have the child Mother's Days, and every other Thanksgiving and three hours each evening of Hanukkah. In addition, ~~', Mother shall have such other holiday time as the parties mutually agree, ~', considering the child's schedules, wishes, and preferences for those holidays. 5. This court shall retain jurisdiction over this matter for any future modification or li enforcement of this order. Distribution: .~3amuel L. Andes, Esquire (Attorney for PlaintifF) 525 North 12th Street, P.O. Box 168, Lemoyne, PA 17043 ark C. Krebs, pro se (Defendant) 2 Laurel Drive, Enola, PA 17025 RV T4.IG !"(ll IQT `" r ~ I r HELAINE J. KREBS, Plaintiff vs. MARK C. KREBS, CIVIL ACTION -LAW NO. 073122 IN CUSTODY Defendant STI PU LATIO N AND NOW this ~~~ay of st , 2007, the above parties mutually agree that the attached Or er shall be entered by the court to resolve the matters involving the custody of their minor child Zachary. Blaine J. Krebs Date : 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Mark C. Krebs Date: ~~s y t~ tiJ .~~ ~- ti ~ w. ~ ~., w {~,~i ' -~ l ._~ i`7t - ~ ? . ` ` ~ _, ;,~