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SALLV J. WINDl-:R
Illlomry 01 Law
701 E."h:inll Suetl
ShipP<",hurg, I'A 172$7
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HARK W. KNABLE,
Plaintiff
IN THE COURT OF COHHON PLEAS OF
CUHBERLAND COUNTr, PENNSrLVANIA
vs,
LORI L. KNABLE,
CIVIL ACTION NO. 94 - 17<1'1 CIVIL
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Defendant
IN CUSTODY
AND NOW,
ORDER OF COURT
Apr I J J..)-, 1994, upon consideration of the attached
Complaint, it is hereby directed t~at the ?arties and their respective counsel I
appear bufore ..ll-6'\ht-rt i b-IJro/,r~e Conciliator, at 4th floCI'I
1_ I,," fTh 'oL,)~ i
~~~ 0; the _19i~ day of t''l'''''(, 1994, at 10: 3oAA"', '
.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 dufine and narrow the issues to be heard by the Court, and to
enter into a temporary Order. Atl children age five or older may also be
present at the conference. Failure to appear at the conference may provide
i grounds for entry of a temporary or permanent Order,
For the Court,
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By:
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO
FIND OUT WHERE rou CAN GET LEGAL HELP.
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OFFiCE OF THE COURT ADHINISTRATOR
COURTHOUSE, 4TH FLOOR
CARLISLE, PA 17013
(717) 240-6200
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IIARK W. KNABLE, I IN THE COURT OF COHMON PLEAS OF
Plaintiff I CUHBERLAND COUNTY, PENNSYLVANIA
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vs. I
I CIVIL ACTION NO. 94 - /1'1'( CIVIL
LORI L. KNABLE, ..,.~
Defendant IN CUSTODY
COMPLAINT FOR PARTIAL CUSTODY
COHES NOW, Plaintiff, Hark W. Knable, by and through his counsel,
Sally J. Winder, Esquire, and does petition the Court for primary
residential custody as follows:
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j, 1. The PlaintifF is Hark W. Knable, reaiding at 382 Rowe Road,
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I Shippensburg, Pennsylvania.
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I 2. The Defendant is Lori L. Knable, residing at 254 Goodhart Road,
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II Shipponsburg, Cumberland County, Pennsylvania.
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I' 3. Plaintiff seoks partial custody of the following child:
Andrew W. Knable, born October 22, 1991.
The child was not born out of wedlock. The child is presently in the
custody of Lori L. Knable, who resides at the address set forth above.
Since the birth of the child, the child has resided with both parents
at 16286 Cumberland Highway, Newburg, Pennsylvania from birth until August,
1992; with both parents at 382 Rowe Road, Shippensburg, Pennsylvania, from
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ugust 1992 until February, 26, 1994; with the mother at 254 Goodhart Road,
Shippensburg, Cumberland County, Pennsylvania; trom February 26, 1994 to the
present.
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The natural mother of the child is Lori L. Knabl>!, currently residing by
herself at address listed above.
The natural father of the child is the Plaintiff, who currently resides
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at the address listed above and is living with no other person at that
The parents are still married, although a divorce action is pending.
4.
The relationship of Plaintiff to child is that of natural father, and
as stated, he lives with no one at present.
5. The relationship of Defendant to child is that of natural mother.
She resides with no other persons.
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I Agreement entered as a Court Order in this matter previously docketed to No.
il FR 1994 - 135, a Stipulation and Agreement entered as an Order of Court for
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1'1 visitation in Franklin County, a copy of which is incorporated herein, marked
I, Exhibit "A" and attached hereto.
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II the child filed in a Court of this Commonwealth.
II Plaintiff does not know of a person not a party to the proceeding who
I, has physical custody of the child or claims to have custody or visitation
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II rights with respec t to t he child.
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:Knable, will be served by granting the relief requested because the mother of
6.
The Plaintiff has participated in the signing of a Stipulation and
Plaintiff has no information of any other custody proceeding concerning
7.
The best interests and permanent welfare of the child, Andrew W.
i the child has attempted to severely limit the contact between father and
'child. Father and mother discussed liberal visitation and providing of
:agreeable times for father to have the child other than the specified first
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Ii week-end of every month as is set forth in the attached Order of Court.
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II terminated and the person who has physical custody of the child have been
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At
the time the Order was entered, the parties lived together in an amicabla
fashion.
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Father believes that it is in the best 'I'
of the child to have consistent and
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Subsequent to the mother moving out of the marital home with the
child, mother has refused to allow father any contact with the child other
than the first week-end of each month.
interest and for the permanent welfare
regular contact with the father, including times on week-ends other than the
first week-end of every month as well as holidays and time that father has off
from work due to plant shut-downs.
Father is capable of caring and nurturing
his son and desires to spend these times with the child.
8.
Each parent whose parental rights to the child have not been
named as parties to this action.
WHEREFORE, Plaintiff requests the Court to grant partial custody of
Andrew W. Knable to him.
Respectfully submitted,
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VERIFICATION
I verify that the statements made in the foregoing Complaint are true
I unders tand
I and correct to the best of my personal knowledge and belief.
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that false statements herein are made subject to the penalties of 18 Pa. C.S.
section 4904 relating to unsworn falsification to authorities.
n.&JL. V 1t.Jk
HARK W. KNABl.E
Date: -=f-/k-Iil
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IN THE COURT OF COMMON PLEAS OF THE 39TH JUDICIAL DISTRICT
OF PENNSYLVANIA - FRANKLIN COUNTY BRANCH
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Lori L, Knable.
Plaintiff
Civil Action - Law
No, F,R,
vs.
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Mark W, Knable,
Defendant
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ORDER OF COURT
J~bKU.U I'.. 1
1'1 , 1994, the 'iJithin stipulation having' ,
been presented, read. considered and ordered to be filed, it is
hereby ordered that:
1, Lori L, Knable and Mark W, Knable are awarded joint
legal custody of the minor child Andrew W. Knable, born October 22,
1991.
2. Lori L. Knable shall have primary residential custody of
the minor child,
3, Mark W, Knable shall have partial residential custody of
the child as provided in this paragraph:
a. Beginning on the month following the entry of this Order,
on the first weekend of every month, from 6:00 P,M. on Friday until
6:00 P,M. on SundaYI
b, On the weekend following the child's birthday, from 6:00
P,M, on Friday until 6:00 P.M, on Sunday.
c. At such other times as mutually agreed upon by the parties.
4. The Defendant shall be responsible for all transportation
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relating to the exchange of custody.
5, The Plaintiff having filed an affidavit of poverty, the
costs of this proceeding are waived,
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Knable vs, Knable
Custody
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IN THE COURT OF COMMON ~LEAS OF THE 39TH JUDICIAL DISTRICT
OF PENNSYLVANIA . FRANKLIN COUNTY BRANCH
Lori L. Knable, Civil Action - Law
Plaintiff
No, F,R,
VB.
Custody
Mark W. Knable,
Defendant
STIPULATION AND AGREEMENT
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This stipulation and agreement is made r~6.._...., It,
1994, between the ~laintiff, Lori L, Knable, residing at 382 Rowe
Road, Shippensburg, Franklin County, Pennsylvania, and the
Defendant, Mark W. Knable, residing at 382 Rowe Road, Shippensburg,
Franklin County, ~ennsylvania,
1, Lori Knable and Mark Knable are the natural parents of the
minor child, Andrew W, Knable, born October 22, 1991,
2. Lori Knable and Mark Knable are married but living separate
and apart in same residence, Lori Knable will be moving to her own
residence at 254 Goodhart Road, Shippensburg, Cumberland County,
~ennsylvania,
3. The minor child was born in wedlock.
4. The Plaintiff presently exercises primary residential
custody of the minor child,
5. During the past five years, the child has resided at
the following addresses with the following people:
a, at 16286 Cumberland Highway, Newburg, Pennsyl....,;,;... . -.,
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from birth till August of 1992 with the Plaintiff and the
Defendant;
b. at 382 Rowe Road, Shippensburg, Franklin County,
Pennsylvania from August of 1992 until the present with the
parties.
6, The parties have not participated in other litigation
concerning the custody of the child,
7. The parties have no information of any other custody
proceeding concerning the child pending in the courts of this
Commonwealth or any other jurisdiction,
8. The parties do not know of any person not a party to this'
proceeding who has physical custody of the child or claims to
have custody or visitation rights with respect to the child.
9. The parties have reached an agreement with regards to
custody of the children and desire to reduce their agreement to an
order of court,
NOW THEREFORE, the parties, intending to be legally bound and
waiving their right to be present when this agreement and order are
presented and executed, hereby stipulate and agree that the Court
may enter the following Order of Court in the above-captioned case:
ORDER OF COURT
, 1994, the within
stipulation having been presented, read,
considered and ordered to be filed, it is
hereby ordered that:
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1. Lori L. Knable and Mark W, Knable are
awarded joint legal custody of the minor child
Andrew W. Knable, born October 22, 1991,
2. Lori L. Knable shall have primary
residential custody of the minor child.
3 . Mark W, Knable shall have partial
residential custody of the child as provided
in this paragraph:
a, Beginning on the month following the
entry of this Order, on the first weekend of
every month, from 6:00 P.M. on Friday until
6:00 P,M. on Sunday;
b, On the weekend following the child'S
birthday, from 6:00 P,M, on Friday until 6:00
P,M, on Sunday.
c, At such other times as mutually agreed
upon by the parties.
4, The Defendant shall be responsible for
all transportation related to the exchange of
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custody,
4. The Plaintiff having filed an
affidavit of poverty, the costs of this
proceeding are waived.
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The parties further agree that in the procuring c."': l:.~l.i...;
agreement there has been no fraud. concealment, ovel:" ",..:: ':'1,
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coercion or other unfair dealing by either party,
IN WITNESS WHEREOF, the parties hereto, intending to be
hereunto set their hands and affixed their
legally bound, have
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day of r~ "~-"'7
, 3.9.!2-,
seals this
WITNESS:
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lainti f)
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(Defendant)
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I verify that the statements made in this Stipulation and "
Agreement are true and correct, I understand that false statements
herein are made subject to the penalties of 18 Pa.e,S, Sec. 4904
relating to unsworn falsification to authorities.
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I verify that the statements made in this Stipulation and
Agreement are true and correct. I understand that false statements
herein are made subject to the penalties of 18 Pa.e.s. Sec, 4904
relating to unsworn falsification to authorities.
~/:r.1 vat
(Defendant)
Knable vs, Knable
Custody StipUlation
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HARK W. KNABLE,
PlaintiU
: IN 'l'HE COUR'l' OF COMMON PLEAS OF
:CUMBERLAND COUN'l'Y, PENNSYLVANIA
v
:
:NO. 1744 - CIVIL - 1994
:
LORI L. KNABLE,
Defendant
:
:CIVIL AC'l'ION - CUS'l'ODY
COUR'l' ORDBR
4-'1
AND NOW, this c;l"{ day of /'1..4:i; , 1994, the Conciliator
being advised that the parties h e reached an agreement in the
above case, the Conciliator relinquishes jurisdiction.
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