HomeMy WebLinkAbout94-03090
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, IN THB COURT OF COMMON PLEAS OF
,CUMBERLAND COUNTY, PENNSYLVANIA
,
,CIVIL ACTION - LAW
~NO. '1 tl':~o'iu CIVIL
,CUSTODY/VISITATION
19
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ORDER or COURT
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AND NOW, this (aate) , upon consideration of the
attached complaint, it is hereby directed that the arties .pd
their respective counsel appfJ.ar before . , -" f '. ,\/0 1.
the con~il' ,at L t"- t lro( , 0, 6 I <>".)(
on the ' day of :Jlt " , 19 Cf'L{, at 0:5
M., for Prehearing 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. Bither
party may bring the child who is the subject of this custody
action to the conference, but the child/children's attendance is
not mandatory. Failure to appear at the conference may provide
grounds for entry of a temporary or permanent order.
FOR THE COURT:
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By: t 57.
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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 THB OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, FOURTH FLOOR
CARLISLE PA 17013
(717)240-6200
I
I
ROBERT P. KINDLER, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
v. I CIVIL ACTION - VISITATION
I
MARY ELLEN KINDLER I NO. OF 1994
Defendant I
COMPLAINT FOR VISITATION
1. The plaintiff is Robert P. Kindler, residing at 1925
Chatham Drive, Camp Hill, PA 17011.
2. The defendant is Mary Ellen Kindler, residing at 1603
Chatham Road, Camp Hill, PA 17011.
3. Plaintiff seeks visitation of the following children I
liAm!!
Franz Kindler
Carolyn Kindler
KaiUyn Kindler
Present Residence llim
1603 Chatham Road, Camp Hill, PA 17011 ll/3A5
1603 Chatham Road, Camp Hill, PA 17011 ll/3A5
1603 Chatham Road, Camp Hill, PA 17011 8/15/00
The children were born in wedlock.
4. A divorce action is currently pending between the
plaintiff and defendant which incorporatee provisions concerning
the children as follows I
a. custody of the minor children of the parties, above
named, shall be with the wife, Mary Ellen Kindler.
b. Husband, Robert P. Kindler, shall have and enjoy
visitation and temporary custody of the minor children of the
parties, above named, as the parties shall agree.
The children are presently in the physical custody of
defendant, Mary Ellen Kindler, who resides at 1603 Chatham Road,
Camp Hill, PA 17011.
5. The parties entered a verbal agreement regarding
visitation arrangements at the time of their eeparation. Due to an
ongoing dispute between the parties concerning settlement with
regards to their pending divorce, defendant has denied plaintiff
the right to visitation and temporary custody of the minor children
as originally agreed upon. The last time plaintiff had the
children for the weekend according to the parties verbal agreement
was May B, 1994.
6. The best interest and permanent welfare of the minor
children will be served by granting visitation and temporary
custody to plaintiff ae follows I
(a) Every Thursday evening from 5100 p.m. until BIOO a.m. on
Friday morning with the plaintiff both picking up and returning the
children.
(b) Alternating weekends with the plaintiff commencing on
Friday evening at 5100 p.m. until Sunday evening at 5100 p.m. with
the parties agreeing to a mutually agreeable place of transfer.
(c) From July 16 - 23, 1994 for a pre-planned, pre-paid trip
to the shore.
(d) From June 21 through July 12, 1994 for plaintiff's mother
to take Carolyn Kindler to Europe for vacation which was planned
and paid in advance.
(e) On Plaintiff's birthday.
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AUG 22 1994
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