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Home My WebLink About06-1371 JENNIFER L. BAKER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Defendant : CIVIL ACTION - LAW : NO. 0(./3'71 : IN CUSTODY CIVIL TERM v. JOHN D. BAKER, COMPLAINT FOR CUSTODY 1. Plaintiff is Jennifer L. Baker, an adult individual currently residing at 2097 Ritner Highway, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is John D. Baker, an adult individual currently residing at 212 Overfield Drive, Carlisle, Cumberland County, Pennsylvania. 3. The parties are the natural parents of two (2) children, namely, Ethan Quinn Baker, born February 9, 1995, and David Owen Baker, born June 24, 1998. The children were not born out of wedlock. 4. Since the children's birth, the children have resided with the following persons at the following addresses for the following periods of time: NAME ADDRESS DATES John D, Baker 212 Overfield Drive February 18, 2006 Carlisle, P A to present Jennifer L. Baker 212 Overfield Drive December 10, 2004 John D. Baker Carlisle, P A to February 18,2006 NAME ADDRESS DATES Jennifer L. Baker 36 South Steeple Chase 1999 John D. Baker Gettysburg, P A to December 10,2004 Jennifer L. Baker 320 North Stratton Street November 1994 John D, Baker Gettysburg, P A to 1999 The natural mother of the children is Jennifer L. Baker who resides as aforesaid. She is married. The natural father of the children is John D. Baker who resides as aforesaid. He is married. 5. The relationship of the Plaintiff to the children is that of natural mother. The Plaintiff currently resides with her paramour, William Bucher. 6. The relationship of the Defendant to the child is that of natural father. Defendant currently resides with the children. 7, Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning custody ofthe children. 8. Plaintiff has no information of any custody proceedings concerning the children pending in any Court of this Commonwealth. 9. It is in the best interest and permanent welfare of the children to grant the relief requested because: a) Plaintiff has been very involved in the children's day to day lives and care from the time of their birth through present; and b) Defendant is currently restricting Plaintiff's access to the children. 10. Plaintiff does not know any person not a party to these proceedings who claims to have custody or visitation rights with respect to the children, WHEREFORE, Plaintiff requests your Honorable Court to schedule Custody Conciliation Conference followed by a hearing at which time she should be granted partial physical custody of the children. Respectfully submitted, ~(~J\.C\h. '\\'~""'QI\ "().I1\Jtb" Hannah Herman-Snyder, Esq 're Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I veriry that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: \~ - {j - () (j J~AKE;f:l}Jn re, e" ~ r--- ! ''-'",'....J l..l. ~._,_ ~.\ ~ ;::.-. , . , , '~ ~~ ~'t-, ~1 ~~ ---, :~~~ , ----- ---- '-' ~ d . JENNIFER L. BAKER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 06-1371 CIVIL ACTION LAW JOHN C. BAKER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, __\Vednesday, March 15,2006 ,_, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberlaud County Courthouse, Carlisle on ,_"-.l'r!!,aY,,Apr:iI..!h..~006 ,,,__,,,,__ at 8:3~AM for a Pre-Hearing Custody Conference. At sueh 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 Itlr 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: ..EL..__Hubert X Gilroy,Esq.,,_ 11111 Custody Conciliator ----p 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 thc 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 HA VE AN A HORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHO'JE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 - ~ ~'/.I. -..... /?~ ~/ ~c?"J/ r . '.~ :z ~171:V ~..r?j(9V' Y ~~ ~.. "?:?ht?b!: jzP :2 /"frVnI~} p~7 "Yc7'7/I '~Ir"",qd \iil\j"~{/\ I^.~)~! ~;~,--.. nl'"\ 'n'''',"\ "'~. '"j ".<--r.....l.lldl IV I~U", j':,'. "',. ",,,".'j o Z : II \~~ 9 I HVW 9DOZ - ""'J :iHl:lO ^bVLOhU,LLU~Q ... , . -'''''-1(',-0311:1 :,;-...'l..,.......- ~ JENNIFER L. BAKER, Plaintiff iT51:r-' '-." . 1r'\'4 \ APR 2 1 2006 i lBY.>---i-=~J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA , " v NO. 06-1371 CIVIL ACTION - LAW JOHN D. BAKER, Defendant IN CUSTODY COURT ORDER ,.... AND NOW, this 1.~ day of ~~..\\ , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Jennifer L. Baker, and the Father, John D. Baker, shall enjoy shared legal custody of Ethan Quinn Baker, born February 9, 1995 and David Owen Baker, born June 24,1998. 2. The Father shall enjoy primary physical custody with the minor children except for Mother's periods oftemporary custody as set forth below. 3. Mother shall enjoy periods oftemporary custody as follows: A. During the school year, on alternating weekends from Friday at 6:00 p.m. untiI Sunday at 6:00 p.m. Additionally, on one of the Father's weekends, Mother shall have temporary custody from 5:00 p.m. to 9:00 p.m. on Friday or at another time as agreed upon by the parties. Mother shall also enjoy temporary custody one evening per week during the weekdays at a time to be agreed upon by the parties, with Mother having two evenings on the week preceding Father's weekend where he has exclusive custody on that weekend. B. During the summer months, Mother shall continue alternating weekends but it shall be from Thursday evening at 6:00 p.m. untiI Sunday evening at 6:00 p.m. Additionally, Mother shall have time in the evenings and on Fridays as set forth in subparagraph A above, except that Mother's Friday will be a full day. 4. For the Christmas holiday, the holiday shall be divided into two segments: Christmas eve at noon until Christmas day at noon, and Christmas day at noon until December 26th at noon. The parties shall alternate custody on those two segments with the Mother having the first segment in 2006. The rest of the Christmas break shall be shared equally between the parties pursuant to a schedule the parties shall arrange. 5. Thanksgiving shall be shared each year such that Father has Thanksgiving day to 7:00 p.m. and Mother shall have from 7:00 p.m. on Thanksgiving day thru Sunday at 6:00 p.m. 6. Each parent shall enjoy two non-consecutive weeks of vacation with the minor children, with the parents giving the other party sufficient notice so that plans can be made and adjust their schedules. 7. Unless agreed otherwise between the parties, the parent receiving custody shall pick up at the children at the other parent's home. 8. If Mother is off work on a Monday and the children are also off school, Mother's weekend visitation shall extend thru Monday for that weekend. 9. The parties shall arrange their schedules such that Mother's Day shall always be handled with Mother having custody of the minor children, and Father's Day be handled such that Father has custody of the minor children. 10. The parties shall work out a schedule to either share or alternate other major holidays pursuant to their own agreement. 11. The non-custodial parent shall have a three (3) hour period of time with the children on their birthday if their birthday falls on a weekday and a five (5) hour period of time if their birthday falls on a weekend. 12. This Order is entered pursuant to an agreement reached by the parties at a custody conciliation conference. In the event either of the parties desires to modify this Order and is unable to reach an agreement with the other party, that parent may petition the Court to have the case again scheduled for a conference with the Custody Conciliator. BY THE COURT, '-i~5 Judge ~ Cc: ~istoPher T. Smull, Esquire vlfannah Herman-Snyder, Esquire r nj ( ~ I 'J ' ! ~ JENNIFER L. BAKER, PIaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 06-1371 CIVIL ACTION - LAW JOHN D. BAKER, Defendant 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 children who are the subject of this litigation is as follows: Ethan Quinn Baker, born February 9, 1995 David Owen Baker, born June 24,1998 2. A Conciliation Conference was held on April 21, 2006 with the following individuals in attendance: The Mother, Jennifer L. Baker, with her counsel, Hannah Herman-Snyder, Esquire The Father, John D. Baker, with his counsel, Kristopher T. Smull, Esquire 3. The parties agreed to the entry of an Order in the form as attached. r Date: April;{ t , 2006