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Home My WebLink About01-0231HEIDI M. WARNER, Petitioner JEFFREY B. WARNER, Respondent 1N THE COURT OF COMMON PLEAS OF .. : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW .. 2001-~31 CIVIL TERM .. IN CUSTODY PETITION FOR CUSTODY AND NOW, this '~ day of January 2001, comes the Petitioner, Heidi M. Warner, by her a~torneys, Irwin, McKnight and Hughes, and presents the following Petition for Custody. The petitioner is Heidi M. Warner, an adult individual who resides at 51 Blue Pond Road, Newville, Cumberland County, Pennsylvania 17241. The respondent, Jeffrey B. Warner, is an adult individual who resides at 1840 Pine Road, Newville, Cumberland County, Pe~msylvania 17241. The parties are the natural parents of three minor children, namely, Zackary B. Warner, bom August 30, 1990, age ten (10) years; Jeffrey N. Warner, bom September 3, 1992, age eight (8) years; and Gregory S. Warner, born August 9, 1995, age five (5) years. Petitioner desires primary physical custody of the child and joint legal custody with periods of visitation to respondent as can be mutually arranged between the parties. The best interest of the children requires that the court grant the petitioner's request as set forth above. WHEREFORE, petitioner respectfully seeks the entry of an Order of Court seeking primary physical custody of the children and joint legal custody with periods of visitation to respondent as can be mutually arranged between the parties. Date: January q~7 ,2001 By: Respectfully submitted, KNIGHT & HUGHES Mark D. Schwartz, Esquire Attorney for Petitioner 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 717-249-2353 Supreme Court I.D. No: 70216 VERIFICATION The foregoing Petition for Custody is based upon information which has been gathered by my counsel and me in the preparation of this action. I have read the statements made in this Petition and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unswom falsification to authorities. HEIDI M. WARNER Date: January 8, 2001 HEIDI M. WARNER PLAINTIFF V. JEFFREY B. WARNER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-231 CIVIL ACTION LAW iNCUSTODY ORDEROF COURT AND NOW, this 19th day of January ,2001, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on the 1st day of March ,2001, at 9:30 a.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 also be present at the conference. Fa/lure to appear at the ennference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: /si Hubert X. Gilroy, Esq_~ Custody Conciliatorf ~ 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 heating. YOU SHOULD TAKE rlTIIS 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 HEIDI M. WARNER, Plaintiff v JEFFREY B. WARNER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 01-231 CIVIL IN CUSTODY Prior Judge: CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the children who are the subject of this litigation is as follows: Zachary B. Warner, bom August 30, 1990; Jeffrey N. Warner, bom September 3, 1992; and Gregory S. Warner, bom August 9, 1995. A Conciliation Conference was held on March 1, 2001, with the following individuals in attendance: The Mother, Heidi M. Warner, with her counsel, Mark D. Schwartz, Esquire; and the Father, Jeffrey B. Warner, with his counsel, Maria Cognetti, Esquire. 3. The parties agree to the entry of an order in the form as attached. DATE Hubert X. GipSy, Esquire Custody G6nciliator MnR 0 HEIDI M. WARNER, Plaintiff V JEFFREY B. WARNER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01 - 231 CIVIL IN CUSTODY COURT ORDER AND NOW, thist ~,y~x day of March, 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: The Mother, Heidi M. Warner, and the Father, Jeffrey B. Warner, shall enjoy shared legal and shared physical custody of Zachary B. Warner, bom August 30, 1990; Jeffrey N. Warner, bom September 3, 1992; and Gregory S. Warner, bom August 9, 1995. Physical custody shall be handled pursuant to a schedule that allows for both parents to have equal time with the minor children. Unless agreed otherwise between the parties, the children shall be with Father on Mondays and Tuesdays of each week and the children will be with Mother on Wednesdays and Thursdays of each week. The parties will alternate the weekends that will include Friday, Saturday and Sunday. This schedule can be modified in any manner as agreed upon by the parties as long as the parties work out an amicable schedule that achieves a 50/50 custody arrangement. In the event a custodial parent is unavailable to care for the children during a significant period of time of at least four (4) hours, that parent shall be required to contact the other parent to offer them the first opportunity to provide daycare for the minor children. Both parents shall enjoy reasonable telephone contact with the minor children when they are in the other parent's custody. This order is a temporary order and entered with the understanding that either party may advance a different position on a permanent custody order at a subsequent Custody Conciliation Conference or at a hearing on this case. The parties shall meet again with the Custody Conciliator for a second Conciliation Conference on Thursday, May 17, 2001 at 9:30 a.m. 6. The parties will share custody on the Easter holiday with the timeframe to be arranged between the parties. ce; Mark D. Schwartz, Esquire Maria P. Cognetti, Esquire HEIDI M. WARNER, Plaintiff V JEFFREY B. WARNER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01 - 231 CIVIL ACTION - LAW : IN CUSTODY COURT ORDER AND NOW, this day oJLM~, 2001, the Conciliator being advised that the parties have reconciled, the Conciliator relinquishes jurisdiction. BY THE COURT, Hubert X. Gilroy, Esquire Custody Conciliator IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HEIDI M. WARNER, Plaintiff JEFFREY B. WARNER, Defendant NO. 01-231 CIVIL ACTION CIVIL ACTION - LAW IN CUSTODY ORDER AND NOW, this ] 9J~day of ,2001 it is hereby ORDERED and DECREED that the attached Stipulation is hereby entered as an Order of this Court. BY THE COURT: 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HEIDI M. WARNER, Plaintiff JEFFREY B. WARNER, Defendant NO. 01-231 CIVIL ACTION CIVIL ACTION - LAW IN CUSTODY STIPULATION THIS STIPULATION is entered into this t~ day of ~-~, v'/t~_..~, 2001, by ~d be~een Donald T. ~ssinger, Esquire, co.scl for PlhntiffHcidi M. Wmer, ~d M~a P. Co.ertl, Esquire, co~sel for Dcfend~t Jeffiey B. W~er; ~T~SSETH: ~E~AS, the p~ies to the above~aptioned action have reconciled; WHE~AS, O~e p~es ~d ~eir counsel a~ee that the Co~ Order of M~ch 6, 2001 ~ter~ by ~e Honorable Edw~d E. Guido is no longer necess~ ~d desire that it shall herea~ be deemed to be null ~d void. NOW, THE~FO~, in consideration of these premises ~d of the mural promises, coven~ts ~d ~d~ings set fo~h herein, ~d int~ding to be legally bo~d hereby, the p~ies h~eto a~ee as follows: 1. The Co~ Order dated M~ch 6, 2001 docketed to ~e above tern ~d nmb~ shall be vacmed ~d ~e ~derlying action dismissed. 2. The te~s of~is Stipulation sh~l be inco~orated into ~ ~der of Co~ in the fo~ a~hed her~o. IN WITNESS W/./EREOi~, cOUnsel for the parttes hereto have a~xed their hands and seals the day and t/ate first written ' above. aox s~o ~lll~l~YI.V~& I710~ ' L^v/Omens OF-' HOWETT~ KISSINGER & CONLEY, P.C. 130 WALNUT $TI~EET POST OFFICE BOX 810 IN THE COURT OF COMMON PLEAS OE CtlMBEP, I~AND ('()lINTY, PENNSYI.\",\NIA ItEIDI M. WARNER, Plaintiff JEFFREY B. WARNER, De£cndanI NO. 01-__~1 ('IVII A(?TION CIVIL A('TION - l/kW IN ( [~S I PRAECIPE TO TIlE PROTHONOTARY; As tile p~ulics to the above-captioned divorce action haxe reconciled, please dJscontmt~e lhis divorce action. Respcctfidly submitted. Donald T. Kissin, gcr, Esqm]-c ~ HOWETT, KISSINGER & CO~FY, PX~. 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2610 Counsel Ibr PlaintilTHcidi M, Warner