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Home My WebLink About01-6902IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV CIVIL ACTION IN CUSTODY l-Gq 9- NOTICE TO DEFEND TO THE RESPONDENTS NAMED HEREIN: You have been sued in Court. If you wish to defend against the claims set following pages, you must take action within twenty (20) days after this Petition and Not! entering a written appearance personally or by attorney and filing in writing with the Cou or objections to the claims set forth against you. You are warned that if you fail to do so, proceed without you, and a judgment may be entered against you by the Court without fu any money claimed in the Petition or for any other claim or relief requested by the Plainti lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO N LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SE3 BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association Two Liberty Avenue Carlisle, PA 17013 (717)249-3166 Le han demandado a usted enla corte. Si usted quiere defenderse de estas demanda~, paginas siguientes, usted tiene viente (20) dias de plazo al partie de la fecha de notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y en forma escrita sus defensas o sus objectones a las demandas en contra de su persona. usted no se defiende, las corte tomara medidas y puede entrar una orden contra usted notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. 12 dinero o sus propiedades o otros derechos importantes para usted. OF fgrth in the c¢ are served, by rt lyour defenses t~e case may rtl~er notice for f~. You may D~r HAVE A 'FORTH expuestas en las la demanda y la rchivar en la corte ;~a avisado que si ;i¢ previo aviso o stud puede perder o IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV CIVIL ACTION IN CUSTODY COMPLAINT IN CUSTODY The plaintiffis~u[-r3. ~__k-~c¥-'~c',x~ , residing at The defend~t is ~ i ~] ~~ residing at Plaintiff se~~ial custody), (visitation) of the following child(ren): NAME PRESENT ADDRESS The child(ren) (was)~m out of wedlock. Thechild(ren) is presently in the custody of~.,~r Fwc~_.v~3~'Y3 whore During the past five years, the child(ren) has resided with the following persons addresses: LIST OF PERSONS ADDRESSES DF ANIA AGE sidles at :the following DATES - o She is (singl~~klivorced). The father of the child(ren)is ,~i~ ~-C~PCY&IQ~ . currently resi He is (sing~vorced). The relationship of the Plaintiff to the child(ren) is: ~(~k'J~ J~' . The resides with: NAME RELATIONSHIP The relationship of the Defendant to the child(ren) is: currently resides with: NAME RELATIONSHIP Plaintiff (has)~rticipated as a party or witness, or in another capacity, concerning the custody of this minor child(ren) in this or another court. (if so)Ti number, and its relationship to this action is: ( (ha~.~ormation of a custody proceeding concemi Plaintiff pending in a court of this Commonwealth. (if so)The court, term and number to this action is: ~ ling at. .ing at. 'laintiff currently The Defendant in other litigation ~ court, term and ng the child(ren) nd its relationship Plaintiff (knows t a person not a party to the proceec physical custody of the child or claims to have custody or visitation fights with respe The name and address of such a person is: The best interest and permanent welfare of the child will be served by granting the because: ~ ¥~¥~-4a~c> ~L~ C)~c~re~r~ Car ~ ~ 'q%e~ ings who has t to the child. elief requested ~'~aoar~ w~os%~'~entaf~ri~ht~tt~chi~-~'~a~ve not~'~ te~r~n?nated and ttt~e ~e4on WhO nas .... as parties to this action. All other ~etsons, named below, who are known to have or claim a right to custody or visitation of the chil ~will be given notice of the pendency of this action and the right to intervene: NAME ADDRESS BASIS WHEREFORE, Plaintiff requests this court to grant (custody)(temporary custody)0 child(ren) to the Plaintiff. Date Respectfully submitted, CLAIM 4~itation) of the RITA ERDMAN PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND coUNTY, PENNSYLVANIA : 01-6902 CIVIL ACTION LAW MICHAEL ERDMAN IN CUSTODY DEFENDANT : AND NOW, Monday, December 17, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, M°ehanicsbur$, PA 17055 on Tuesday, January 08, 2002 at 8:30 AM 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 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 dire~s 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, By: /s/ Dawn S. Sunda'v. Esa. ~jt 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 SHOULD 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 RZTA ERDMAN, Plaintiff VS. MICHAEL ERDMAN, Defendant 1N THE COURT OF COMMON PLEAS OF CLTMBERLAND COUNTY, PENNSYLVANIA 01-6902 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT \,..,.,, AND NOW, this ~1~ day of ~.~~ ,2002, upon consideration of the attached Custody Conciliation Report, it is ordered ~nd directed as follows: 1. The Mother, Rita Erdman, and the Father, Michael Erdman, shall have shared legal custody of Tylor Erdman, bom September 24, 1997, and Eric Erdman, bom November 28, 1999. Each parent shall have an equal fight, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 3. The Mother shall have primary physical custody of the Children. 4. The Father shall have partial physical custody of the Children every week from Saturday at 3:00 p.m. through Sunday at 3:00 p.m. and on two weekday evenings from 5:30 p.m. until 8:00 p.m. 5. The parties shall share having custody of the Children on holidays and over the summer vacation as arranged by agreement. 6. 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. cc: Rita Erdman - Mother Michael Erdman - Father RITA ERDMAN, Plaintiff VS. MICHAEL ERDMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-6902 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 Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Tylor Erdman September 24, 1997 Mother Eric Erdman November 28, 1999 Mother 2. A Conciliation Conference was held on January 8, 2002, with the following individuals in attendance: The Mother, Rita Erdman, and the Father, Michael Erdman. Neither party is represented by counsel in this matter. 3. The parties agreed to entry of an Order in the form as attached. Dat~ (-/ v Dax~n ~. Sunday, Esquire / Custody Conciliator