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Home My WebLink About02-1660JILL A. C. TICHNELL, Plaintiff VS. MICHAEL R. TICHNELL, Defendant 1. The Plaintiff Cumberland County, PA. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA · NO. CIVIL TERM · CUSTODY COMPLAINT FOR CUSTODY is Jill Tichnell, residing at 152 Elm Street, Carlisle, Road, Gardner, PA. 3. The Plaintiff seeks custody of the following children: Name Present Residence Hershel M. Tichnell 152 Elm Street, Carlisle, PA The Defendant is Michael R. Tichnell, residing at 412 Pine Grove Date of Birth 8/24/95 Joyel R. Tichnell 152 Elm Street, Carlisle, PA 3/4/98 The children are presently in the custody of Jill Tichnell, who resides at 152 Elm Street, Carlisle, PA. The mother of the children is Jill Tichnell, currently residing at 1,52 Elm Street, Carlisle, PA. The father of the children is Michael R. Tichnell, currently residing at 412 Pine Grove Road, Gardner, PA 17342. 4. The relationship of Plaintiff to the children is that of Mother. 5. The relationship of Defendant to the children is that of Father. 6. The Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or any other court. 7. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 8. The Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 9. The best interest and permanent welfare of the children will be served by granting the relief requested. 10. Each parent whose parental rights to the children have not been terminated has been named as parties to this action. WHEREFORE, the Plaintiff requests that this Court grants full custody of the children to her. Respectfully submitted, Abom& Kutulakis, L.L. Po Date: ,2002 (~tlK~tulakis, Esquire 8 South Hanover Street, Suite 1204 Carlisle, PA 17013 717-249-0900 Attorney for Plaintiff Jill Tichnell, VSo Michael Tichnell, Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL TERM CUSTODY VERIFICATION I verify that the statements made in the foregoing Complaint for Custody are tree and correct. I understand that false statements herein are made subject to the penalties 18 Pa.C.S. ~4904, relating to unswom falsifications to authorities. Date JILL A.C. TICHNEIL Plaintiff VS. MICHAEL tL TICHNELL, Defendant IN THE COURT OF COMMON PLEAS, CUMBERI.AND COUNTY, PENNSYLVANIA NO ~//p~IVIL TERM CUSTODY PROOF OF SERVICE I, Jason P. Kutulakis, Esquire, hereby certify that on this 4th day of April, 2002, a true and correct copy of the CUSTODY COMPLAINT was served upon Defendant by United States Mail, First Class, postage pre-paid, addressed as follows: Mi'chael R. Tichnell 412 Pine Grove Road Gardner, PA 17342 Jast[~p. Kutulakis " JILL A. TICHNELL PLAINTIFF V. MICHAEL R. TICHNELL DEFENDANT : 02-1660 : IN CUSTODY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW AND NOW, Tuesday, April 09, 2002 , upon consideration of the attached Complaint, it is hereby directed that pm-tics and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, May 09, 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 bc accomplished, to define and narrow thc issues to be heard by thc court, and to enter into a temporary order. All children age five or older may also be present at thc conference. Failure to appear at thc conference may provide grounds for entry ora 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/ Hubert X. Gilroy. Esq. 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. 1F 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 JUN ~ 5 ~00~ ~ JILL A. TICHNELL, Plaintiff V MICHAEL IL TICHNELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 02 - 1660 CIVIL : IN CUSTODY COURTO~ER -. ~X { ~.,~. ~f ]~ c~,~.,g- ,2002, the conciliator being advised that AND NOW, this c~-__ ua~ ,, ........ n. the parties have reached an agreem(~ni, the conciliator relmqmshes junsdictio BY THE COURT, iq u~be~X.~Gil~y~squire Custody Conciliator I-ZPU LA TED CEI, TOD Y A G. REEA477NT r4r/~-~ the following stipulated custody agreement has be~n mutunlly agreed upon by the below signed parlies to be in the b~st interest of'Hcrshel M. Tichnell and $oyel R. Tichnell 1. Hershel M Tichndl is a minor who ,,vas born on August 24, 1995. 2. Joyel R. Tichnell is a minor who was born on March 4, 1998. 3. Hershel M Ticlmell and Joyel R. Tichnell (Hereinafter "Children") are the children oflill Tichnell (Hereinafter "Mother") and Michael R. Tichnell (Hereinafter "Father"). 4. lilt Tichnoll and Michael R. Tichnell have been divorced since November of 2001. 5. Custody of the Children is to remain with Mother. 5, Father will have visitation with thc Children as follows: a. Father will have one overnight visitation with the Children per week. These visits will end when Father delivers the Children to daycare or scho~l the following morning. b. Father will have visitation with the Children every other weekend, starting on Friday at 4:30 p.m. aid ending when Father delivers the children to daycare or school on Monday mornings 7. On all dates the children are to be in daycare, the Father will deliver the Children to daycare by %30 a.m. 8. Two weeks, consiaing of sev~n days for each week, of vacation will occur (non-consecutively) for each parent over the summer months 9. Mother's and Father's Days will be spent with the respective parties. 10. Each parent shall provide thirty (30) days written notice to the non.custodial parem when they intend to remove the children from 'the Commonwealth of Pennsylvana for vacationing purposes A,$ZNDICATF. D BY TI~$IGNATURt~BFJr. OW' each par~y affirms that they have read this agreement carefully and agrees to abide by e~h and every term contained in the agreement. Date l~lichael KX~l'ichnell, Dat~ ~/~C~elJ, ~vlot SEP 20D2 JILL A.C. TICHNEIJ,, Plaintiff V. MICHAEL R~ TICHNEI J,, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02- 1660 CIVIL TERM CUSTODY ORDER OF COURT AND NOW, this /~_~_~ day of.. ~ vt,~,6~ ,2002, upon consideration of the attached Stipulated Custody Agreement, it is ordered and directed as follows: 1. Custody of the Children, Hershel M. Tichnell, born August 24, 1995, and Joyel tL Tichnell, born March 4, 1998, is to remain with Mother, Jill A.C. Tichnell. follows: Father, Michael R. Tichnell, will have visitation with the Children as a. Father will have one overnight visitation with the Children per week. These visits will end when Father delivers the Children to daycare or school the following morning. b. Father will have visitation with the Children every other weekend, starting on Friday at 4:30 p.m. and ending when Father delivers the children to daycare or school on Monday mornings. 3. On all dates the Children are to be in daycare, the Father will deliver the Children to daycare by 7:30 a.m. 4. Two weeks, consisting of seven days for each week, of vacation will occur (non-consecutively) for each parent over the summer months. 5. Mother's and F ' ather s Days will be spent with the respective parties. 6. Each parent Shall provide thirty (30) days written notice to the non- custodial parent when they intend to remove the Children from the Commonwealth of Pennsylvania for vacationing purposes. 7. This Order is entered pursuant to a Stipulated Custody Agreement signed by each party. 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. BY THE COURT, Kara W. Haggerty, Esquire ABOM & KUTULAKIS, L.L.P. 8 South Hanover Street, Suite 204 Carlisle, PA 17013 Attomej for Mother /Michael A. Scherer, Esquire O'BRIEN, BARIC & SCHERER 17 West South Street Carlisle, PA 17013 ~lttorne~ for Father Jo Fit..ED-..OFFiCE OF -r'...-~': .'T , ¥.,T,-,r,'r' 02 SEP I 5 Pi,! ,':.t: ~ 2 PENNSYi%'-¢,J A ,5'TI LILA TED CUSTODy A GREE_/1/IENT ~ the following stipulated custody agreement ha~ been mutually agreed upon by the below signed parties to be in the besI interest of Hershei M. Tichnell and $oyel R Tichnell. 1. Hershel M. Tichnell is a minor who was born on August 24, 1995. 2. Joyel R. Tichnell is a minor who was born on March 4, 1998. 3. Hershel M. Tichn¢ll and Joyel R, Tichnell (Hereinafter "Children") are the children o£Jill Tichnell (Hereinafter "Mother") and Michael R. Tichnell (HereinaFter "Father"). 4. Jill TichneI] and Michael R Tichnell have been divorced since November of 2001. 5. Custody of thc Children is to remain with Mother. 6. Fmher will have visitation with the Children as follows: a. Father will have one overnight visitation with the Children per week. These visits will end when Father delivers the Children to dayoare or school the following morning. b. Father will have visitation with the Children every other weekend, starting on Friday at 4:30 p.m. and ending when Father delivers the childn~n to dayeare or school on Monday mornings 7. On all dates the children are to be in daycare, the Father will deliver the Children to daycare by 7.30 a.m. ~ 8. Two weeks, consisting of seven days for each week, ofvacati0n will occur (non-consecutively) for each parent over the summer months 9. Mother's and Father's Days will be spent with the respective parties. 10. Each parent shall provide thirty (30) days written notice to the non-custodial parem when they intend to remove the children front the Commonwealth of Pennsylvania for vacationing purposes .4,f IAIDI'CA TED BY TIlE 32~NA TLr/L~BELOI4~, each party affirms that they have read this agreement carefully and agrees to abide by each and every term contained in the agreement. Date .. Father L/ -- Date ..~'-./~c'finel], ~Vlot --