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HomeMy WebLinkAbout01-4920 Turo Law Offices Attorneys & Counselors At Law 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 JENNIFER R. WERT, Plaintiff V. ROBERT L. DEIHL, JR., Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01- ~/9;2(~3 CIVIL TERM : CIVIL ACTION - CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Jennifer R. Wert, an adult individual whose residence is at 6 Little Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Robert L. Delhi, Jr., an adult individual whose residence is at 503 Pizgah Road, Shermansdale, Perry County, Pennsylvania. 3. Plaintiff seeks custody of her children Robert M. Delhi, born September 22, 1999, currently residing at 6 Little Road, Carlisle, Cumberland County, Pennsylvania 4. On August 17, 2001, the parties entered into a written custody stipulation. A copy of which is attached and incorporated herein as Exhibit A. WHEREFORE, Plaintiff requests your Honorable Court to incorporate said stipulation as an order of court. Date Respectfully Submitted TURO LAW OFFICES Robert J. M~lderig, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff JENNIFER R. WERT, Plaintiff ROBERT L. DEIHL, JR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01- z)~2~:) CIVIL TERM CIVIL ACTION - CUSTODY CUSTODY STIPULATION AND NOW, this /~ ~ day of ~q~.~'f' ., 2001, it is hereby stipulated and agreed between the parties as follows: 1. The parties, Jennifer R. Wer~ and Robert L. Delhi, Jr., shall have shared legal custody of the minor Child, Robert M. Delhi, born September 22, 1999. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of Pa. C. S. § 5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other. 2. Primary physical custody of the child shall be in the mother subject to the following periods of partial custody with the father: Every other weekend from Friday at 6:00p.m. through Sunday at 6:00p.m. b. One full week, during summer school vacation. The parties shall give 30 days written notice of the week or chosen. 3. Alternating holidays from 8:00a.m. to 6:00p.m. The holidays shall be New Year's Day, Memorial Day, 4th of July, Labor Day and Thanksgiving Day, with the father having custody on Labor Day, 2001. 4. The parties shall alternate the Christmas holiday. The father shall have custody of the child from noon Christmas Eve until noon Christmas Day in odd numbered years and the mother shall have this period in even numbered years. The mother shall have custody of the child from noon Christmas Day until noon December 26 in odd numbered years and the father shall have this period in even numbered years. 5. Mother shall have physical custody from 8:00a.m. until 6:00p.m. on Mother's Day and Father shall have physical custody from 8:00a.m. until 6:00p.m. on Father's Day. 6. The party receiving custody shall provide transportation from the custodial parent's residence. 7. The exchange of custody shall occur at the custodial parent's residence, unless other arrangements are made and agreed to by both parties for an alternate place for the exchange of custody. 8. The custodial parent shall inform the non-custodial parent immediately of all medical appointments and problems pertaining to the child. 9. Neither parent shall do or say anything which may estrange the child from the other parent, injure the opinion of the child as to the other parent or hamper the free and natural development of the child's love and respect for the other parent. 10. Both parents shall have liberal and reasonable telephone contact with the child when the child is in the custody of the other parent. 11. Each parent shall notify the other parent if either child shall be away over night more than 100 miles from the child's normal residence. Such notification shall include the child's location and a means to be contacted in case of emergency. 12. Neither parent shall use alcohol or illicit drugs while the Child is in his or her custody. 13. The custodial parent shall provide copies of the child's report card and other reasonable papers affecting the child's education, medical condition, or welfare Date Jennifer R. ~ert JENNIFER R. WERT PLAINTIFF V. ROBERT L. DEIHL, JR. DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-4920 CIVIL ACTION LAW IN CUSTODY AND NOW, Friday, August 31, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jaequeltae M. Vcrney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, October 03, 2001 at 8:30 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. 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, By: /s/ _[acquelineM. Verney. Esq~ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disahilites 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 Turo Law Offices Attorneys & Co. unselors At Law 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 JENNIFER R. WERT, Plaintiff V. ROBERT L. DEIHL, JR., Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01- ,/¢~2/_.~ CIVIL TERM : CIVIL ACTION CUSTODY ORDER OF COURT AND NOW, this /~' day of ~ ,2001, upon consideration of the within Stipulation, it is hereby ordered that: 1. The parties, Jennifer R. Weft and Robert L. Deihl, Jr., shall have shared legal custody of the minor Child, Robert M. Deihl, born September 22, 1999. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of Pa. C. S. § 5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other. 2. Primary physical custody of the child shall be in the mother subject to the following periods of partial custody with the father: a. Every other weekend from Friday at 6:00p.m. through Sunday at 6:00p.m b. One full week, during summer school vacation. The parties shall give 30 days written notice of the week or chosen. 3. Alternating holidays from 8:00a.m. to 6:00p.m. The holidays shall be New Year's Day, Memorial Day, 4th of July, Labor Day and Thanksgiving Day, with the father having custody on Labor Day, 2001. 4. The parties shall alternate the Christmas holiday. The father shall have custody of the child from noon Christmas Eve until noon Christmas Day in odd numbered years and the mother shall have this pedod in even numbered years. The mother shall have custody of the child from noon Christmas Day until noon December 26 in odd numbered years and the father shall have this period in even numbered years. 5. Mother shall have physical custody from 8:00a.m. until 6:00p.m. on Mother's Day and Father shall have physical custody from 8:00a.m. until 6:00p.m. on Father's Day. 6. The party receiving custody shall provide transportation from the custodial parent's residence. 7. The exchange of custody shall occur at the custodial parent's residence, unless other arrangements are made and agreed to by both parties for an alternate place for the exchange of custody. 8. The custodial parent shall inform the non-custodial parent immediately of all medical appointments and problems pertaining to the child. 9, Neither parent shall do or say anything which may estrange the child from the other parent, injure the opinion of the child as to the other parent or hamper the free and natural development of the child's love and respect for the other parent. 10, Both parents shall have liberal and reasonable telephone contact with the child when the child is in the custody of the other parent. 11. Each parent shall notify the other parent if either child shall be away over night more than 100 miles from the child's normal residence. Such notification shall include the child's location and a means to be contacted in case of emergency. 12. Neither parent shall use alcohol or illicit drugs while the Child is in his or her custody. 13. The custodial parent shall provide copies of the child's report card and other reasonable papers affecting the child's education, medical condition, or welfare SHERIFF'S RETURN CASE NO: 2001-04950 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MYERS JULIE VS MYERS MICHAEL - REGULAR SHA/qNON SUNDAY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - DIVORCE was served upon MYERS MICHAEL the DEFENDANT , at 1630:00 HOURS, on the 23rd day of August at 67 SHERWOOD CIRCLE , 2001 ENOLA, PA 17025 MICHAEL MYERS a true and attested copy of COMPLAINT - by handing to DIVORCE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.40 Affidavit .00 Surcharge 10.00 .00 38.40 Sworn and Subscribed to before me this ~- day of ~,, m,. ~ ~! A.D. So Answers: R. Thomas Kline 08/24/2001 EDWARD WEINTRAUB Deputy Sheriff