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HomeMy WebLinkAbout07-3991MICHAEL BECHTEL, : 1N THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW HOLLI FETTERHOFF, : NO. ~ ~- 3 ~ `~ ~ ~ r'~'`'"' Defendant : IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Michael Bechtel, residing at 2137 Newville Road, Carlisle, Pennsylvania. 17013. 2. The defendant is Holli Fetterhoff, residing at 104 Kings Highway, Marysville, Pennsylvania 17053. 3. Plaintiff seeks custody of the following child: Name Present Residence DOB Age Justin M. Bechtel 104 Kings Highway 9/21 /06 9 months Marysville, PA The child was born out of wedlock. The child is presently in the custody of Holli Fetterhoff who resides at 104 Kings Highway, Perry County, Marysville, Pennsylvania. During the past five years, the children have resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Holli Fetterhoff 104 Kings Highway 9/21/06-Present Marysville, PA The mother of the child is Holli Fetterhoff, currently residing at 104 Kings Highway, Marysville, PA. She is not married. The father of the child is Michael Bechtel, currently residing at 2137 Newville Road, Carlisle, PA. He is not married. 4. The relationship of plaintiff to the child is that of father. The plaintiff currently resides with the following persons. Name Relationship William and Ellen Paulus Father and Mother 5. The relationship of defendant to the child is that of mother. The defendant currently resides with the following persons. Name Relationship Melanie Fetterhoff Mother 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child and 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 request because: Plaintiff has undertaken and performed the primary parental responsibilities for the child. Plaintiff is best able to provide the caze and nurture which the child needs for healthy development. 8. Each pazent whose pazental rights to the child have not been terminated and the person who has physical custody of the child have been named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim N/A WHEREFORE, Plaintiff requests this Court grant Plaintiff partial physical custody with visitation as outlined in the attached Stipulation. Respectfully submitted, Date: ~,Z'(. ~~-- ./ r,! Michael O. Palermo, Jr., squire 155 South Hanover Street Cazlisle, PA 17013 (717) 241-6070 Supreme Court ID # 93334 Attorney for Plaintiff ,~. MICHAEL BECHTEL And HOLLI FETTERHOFF And MELANIE FETTERHOFF as GUARDIAN FOR HOLLI FETTERHOFF STIPULATION REGARDING CUSTODY-VISITATION Plaintiff Michael Bechtel, hereinafter referenced as Father, and Defendant Holli Fetterhoff, hereinafter referred to as Mother, hereby agree to the entry of the following terms defining custody and partial custody rights and responsibilities in relation to the parties' minor child: Justin M. Bechtel, born September 21, 2006, hereinafter referenced as the "Child": (1) Shared legal custody as contemplated by the Act of November 5, 1984, P.S. §1001, et seq., is awarded to Mother and Father. (2) Physical custody of the child, Justin M. Bechtel, will be shared equally between Father and Mother. (a) The parties will alternate weeks, such as one week Father has child from Sunday at 7p.m. to the following Sunday at 7p.m. then mother has the child the next week from Sunday at 7p.m. to the following Sunday at 7p.m. (b) During the weeks that Father does not have the child, he will have the child Wednesday evenings after work until 8p.m. (c) During the weeks that Mother does not have the child, she will have the child on Wednesday's during the day while father is at work. (d) Holidays should alternate, that Mother has child on Christmas day on even years, from 1:OOp.m. Christmas Eve until 1:OOp.m. Christmas day. All other holidays shall follow this order as well, including Mother and Father's day. (e) Each party shall have an extended two weeks vacation each year with child on the condition that each parent provide the other parent at least one (1) month's notice of the desired time for the vacation. (~ Such other times as the parties may mutually agree. (3) The parties shall provide transportation for the children to and from each instance of visitation unless otherwise noted herein. Dater ~ y ~~ ~ Michael Bechtel Holli Fetterhoff Melanie Fetterhoff as Guardian ~~~~ Witness Witness VERIFICATION I verify that I am the petitioner and that the statements made in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904, relating to unsworn falsification to authorities. Date: (~~~~'~ f + is ae echtel t) eN~ ~ 70 ~ ==- ~ ~ T_ J 1-,.! ~ < C.._ t ~ < ; ``' v ~"'" ~~ -r~ 1 ~ ~ 00 Q ~o + r, .. 1 ~ -n f +) - : ~ OD o ° _ - r T, t y O ~ ~. ~_ ~ ~.. ~ rri ~ -~ w -~G 0 ~ 062007 MICHAEL BECHTEL, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW HOLLI FETTERHOFF, : NO. 07- 3481 eiv~ 1 Term Defendant : IN CUSTODY ORDER OF COURT t~- AND NOW, this ~ day of ~`',y , 2007, upon presentation and consideration of the within Complaint and the Stipulation and Agreement incorporated therein, and upon agreement of the parties, it is hereby ordered and decreed as follows: (1) Shared legal custody of the minor child, Justin M. Bechtel, born 9121 /06, as contemplated by the Act of November 5, 1984, P.S. § 1001, et seq., is awarded to Mother and Father. (2) Physical custody of the child, Justin M. Bechtel, will be shared equally between Father and Mother. (a) The parties will alternate weeks, such as one week Father has child from Sunday at 7p.m. to the following Sunday at 7p.m. then mother has the child the next week from Sunday at 7p.m. to the following Sunday at 7p.m. (b) During the weeks that Father does not have the child, he will have the child Wednesday evenings after work until 8p.m. (c) During the weeks that Mother does not have the child, she will have the child on Wednesday's during the day while father is at work. (d) Holidays should alternate, that Mother has child on Christmas day on even yeazs, J C V ~! , a.~ !r"r~, t ~.it..~t ";, a, 1~%.Pdr'~ . 'j'J~~ ~~ ~~ ~" ~~~ ~~QZ from l :00p.m. Christmas Eve until 1:OOp.m. Christmas day. All other holidays shall follow this order as well, including Mother and Father's day. (e) Each party shall have an extended two weeks vacation each year with child on the condition that each parent provide the other parent at least one (1) month's notice of the desired time for the vacation. (f) Such other times as the parties may mutually agree. (3) The parties shall provide transportation for the children to and from each instance of visitation unless otherwise noted herein. By the Court: ~~ J. MICHAEL BECHTEL, Plaintiff v. HOLLI FETTERHOFF, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Michael Bechtel, residing at 2137 Newville Road, Carlisle, Pennsylvania. 17013. 2. The defendant is Holli Fetterhoff, residing at 104 Kings Highway, Marysville, Pennsylvania 17053. 3. Plaintiff seeks custody of the following child: Name Present Residence DOB Age Justin M. Bechtel 104 Kings Highway 9/21/06 9 months Marysville, PA The child was born out of wedlock. The child is presently in the custody of Holli Fetterhoff who resides at 104 Kings Highway, Perry County, Marysville, Pennsylvania. During the past five years, the children have resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Holli Fetterhoff 104 Kings Highway 9/21 /06-Present Marysville, PA The mother of the child is Holli Fetterhoff, currently residing at 104 Kings Highway, Marysville, PA. She is not married. The father of the child is Michael Bechtel, currently residing at 2137 Newville Road, Carlisle, PA. He is not married. 4. The relationship of plaintiff to the child is that of father. The plaintiff currently resides with the following persons. Name Relationship William and Ellen Paulus Father and Mother 5. The relationship of defendant to the child is that of mother. The defendant currently resides with the following persons. Name Relationship Melanie Fetterhoff Mother 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfaze of the child will be served by granting the relief request because: Plaintiff has undertaken and performed the primary parental responsibilities for the child. Plaintiff is best able to provide the care and nurture which the child needs for healthy development. 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 below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim N/A WHEREFORE, Plaintiff requests this Court grant Plaintiff partial physical custody with visitation as outlined in the attached Stipulation. Respectfully submitted, Date: f~, y'(. a~ /~ ~-~_ Michael O. Palermo, Jr., squire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 93334 Attorney for Plaintiff ,c MICHAEL BECHTEL And HOLLI FETTERHOFF And MELANIE FETTERHOFF as GUARDIAN FOR HOLLI FETTERHOFF STIPULATION REGARDING CUSTODY-VISITATION Plaintiff Michael Bechtel, hereinafter referenced as Father, and Defendant Holli Fetterhoff, hereinafter referred to as Mother, hereby agree to the entry of the following terms defining custody and partial custody rights and responsibilities in relation to the parties' minor child: Justin M. Bechtel, born September 21, 2006, hereinafter referenced as the "Child": (1) Shared legal custody as contemplated by the Act of November 5, 1484, P.S. §1001, et seq., is awarded to Mother and Father. (2) Physical custody of the child, Justin M. Bechtel, will be shared equally between Father and Mother. (a) The parties will alternate weeks, such as one week Father has child from Sunday at 7p.m. to the following Sunday at 7p.m. then mother has the child the next week from .Sunday at 7p.m. to the following Sunday at 7p.m. (b) During the weeks that Father does. not have the child, he will have the child Wednesday evenings after work until 8p.m. (c) During the weeks that Mother does not have the child, she will have the child on Wednesday's during the day while father is at work. (d) Holidays should alternate, that Mother has child on Christmas day on even years, from 1:OOp.m. Christmas Eve until 1:OOp.m. Christmas day. All other holidays shall follow this order as well, including Mother and Father's day. (e) Each party shall have an extended two weeks vacation each year with child on the condition that each parent provide the other parent at least one (1 }month's notice, of the desired time for the vacation. (f) Such other times as the parties may mutually agree. (3) The parties shall provide transportation for the children to and from each instance of visitation unless otherwise noted herein. Date: ~ / ~ / ~ ~ Michael Bechtel Holli Fetterhoff Melanie Fetterhoff as Guardian ~~~ Witness Witness VERIFICATION I verify that I am the petitioner and that the statements made in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904, relating to unsworn falsification to authorities. Date: ~ _!~~ ~ ~f is ae echtel r? ~ v --r~ fig -''` ~ ~ ~` ~ ~, ~ t ~~~ `Z .ooo~ V ~~.1 ~- ~_~ " --'°" ~ =. ~ ..7 f~ ~_ l (.~ ~' ..-~ ~ } ~-;: ~- _~ ~ ~ ~