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Home My WebLink About04-6102 MICHAEL S. CONKLIN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW . . : 0 '1 ~ (p / ,;) L CIVIL TERM NICOLE M. DITRO, Defendant IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, Michael S. Conklin, by his attorneys, Irwin & McKnight, and presents the following Complaint for Custody. 1. The Plaintiff, Michael S. Conklin, is an adult individual with an address of 1815 Walnut Bottom Road, Newville, Cumberland County, Pennsylvania 17241. 2. The Defendant, Nicole M. Ditro, is an adult individual with an address of 233 Southside Drive, Newville, Cumberland County, Pennsylvania 17241. 3. The parties are the natural parents of one (1) child, namely, Logan Joseph Conklin, born November 20, 1998. 4. The Plaintiff desires that the parties have shared legal custody of the minor child, Logan Joseph Conklin. 5. The Plaintiff desires that primary physical custody of the minor child, Logan Joseph Conklin, remain with the Defendant, Nicole M. Ditro. 6. The Plaintiff desires that he be awarded temporary physical custody of the minor child, Logan Joseph Conklin, as follows: A. On alternate weeks when the Plaintiff is off work, from Tuesday evening at 4:30 p.m. until the next morning when said minor child is returned to the sitter prior to school. B. On alternate weeks when the Plaintiff is off work, from Saturday morning at 9:00 a.m. until Tuesday morning when said minor child is returned to the sitter prior to school. C. During Christmas, the Plaintiff will have custody of said minor child on December 24, 2004, at 9:00 a.m. until Christmas morning at 10:00 a.m. D. The parties will alternate custody of said minor child on the following holidays: Thanksgiving, Labor Day, Memorial Day and July 4th. The Plaintiff will have custody of said minor child on Thanksgiving and July 4th in even years and Labor Day and Memorial in odd numbered years. E. During the summer, the Plaintiff will be entitled to one week vacation with said minor child. The Plaintiff will provide Defendant with written notice at least thirty (30) days in advance of his period of vacation custody. 7. The best interests and permanent welfare of the minor child requires that the Court grant the Plaintiff s request as set forth above. WHEREFORE, Michael S. Conklin, respectfully requests that he be awarded temporary physical custody and shared legal custody of Logan Joseph Conklin, as provided herein. Respectfully submitted, By: 3-3222 Date: DECEMBER 6, 2004 , ,- VERIFICATION The foregoing Complaint for Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have head the statements made in this document 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 unsworn falsification to authorities. dis.~~c( Date: DECEMBER 6, 2004 ~ * ~ 0'\ ~ .~ ~. '^ I \ (p,' ~ ' "- \~ \\S ~~ '^ 'V \ ~ \ \ , ~ ~. ~ , ~ ~ "'. \ ,.'" , I.:"".. ,'j '. _. ~\ '\j p ;;; _ C:'C:> C) ..L- --n ---I T--n rn-.. /--. -0 III :....10 ( .1 .::;C) 32 ;-;~ :i~ >'.. (') ~) (.::;m !'..) ~~ 0""\ ---< I::::) r"'"1 l-) , 0-' ~ C ; I ( - t..I _~ A~ -~. " l) FES .1 1 2005 / ',;;\1 I MICHAEL S. CONKLIN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW NICOLE M. DITRO, Defendant NO. 04-6102 IN CUSTODY COURT ORDER AND NOW, this ')J;A. day of February, 2005, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. The Father, Michael S. Conklin, and the Mother, Nicole M. Ditro, shall enjoy shared legal custody of Logan Joseph Conklin, born November 20, 1998. 2. The Mother shall enjoy primary physical custody of the minor child. 3. The Father shall enjoy periods of temporary physical custody of the minor child as follows: a. On alternating weeks when the Father is off work from Tuesday evening at 4:30 p.m. until the next morning when the child is returned to the sitter prior to school or returned to the Mother after the Father has kept custody pursuant to an agreement of the parties. b. On alternating weeks when the Father is off work from Saturday morning at 9:00 a.m. until Tuesday morning when the child is returned to the sitter prior to school or to the Mother pursuant to other arrangements of the parties. c. At such other times as agreed upon by the parties. 4. The Christmas Holiday shall be divided into two segments, segment "A" being from December 24th at noon until December 25th at noon and segment "B" being from December 25th at noon until December 26th at noon. The parties shall alternate these segments each year with the Mother enjoying segment "A" in odd years and the Father having segment "A" in even years. 5. The parties will also alternate custody of the minor child on major holidays to include Thanksgiving, Labor Day, Memorial Day, and July 4th. The Father will have custody on Thanksgiving and July 4th in even years and Labor Day and Memorial Day in odd years, with the parties alternating thereafter. 6, During the summer, each parent shall enjoy at least two weeks of vacation with the minor child which shall be nonconsecutive. The parties shall notify each other at least thirty days in advance as to when they intend to exercise this vacation. 7. The parties may modify this Custody Order as they agree. Absent an agreement, this Order shall control. In the event either party desires to modify this Order, that party may petition the Court to have the case again scheduled with the Custody Conciliator for a conference. BY Judge cc:~us A. McKnight, Esquire "Nicole M. Ditro J~ LffW- ~ 0;). -~ -O~ tt\JJ~ 11€ ~Z Wd a 93JSOOl: MICHAEL S. CONKLIN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW NICOLE M. DITRO, Defendant NO. 04-6102 IN CUSTODY 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: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Logan Joseph Conklin, born November 20, 1998. 2. A Conciliation Conference was held on February 17, 2005, with the following individuals in attendance: The Father, Michael S. Conklin, with his attorney Marcus A. McKnight, and the Mother, Nicole M. Ditro, who appeared without counsel. 3. The parties agree to the entry of an order in the form as attached. Hubert X. Gilroy, Esquire Custody Conciliator ;l-ll- 0 S' DATE Q/;;f