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they shall meet at the McDonald's off the Thurmont Exit of
Route 16 at 6:00 p.m.
3. Mother shall have the child on Thanksgiving in all odd-
numberad years and Father shall have the child on Thanksgiving In all
even-numbered years. The specific times are to be agreed upon by the
parties. The parties shall shere the transportation for this holiday
period as agreed upon.
4. Father shall be entitled to a Christmas vacation with the
child, In odd-numbered years, he shall have the child from December
26th until December 30th. In even-numbered years, he shall have the
child from December 26th until January 1st. The specific times are to
be agreed upon by the parties. The parties are to share the
transportation for these periods of partial custody with Father as
agread upon.
6. During the summer months, Father shall be entitled to four
(4) weeks of custodial time with the child in addition to the altarnating
weekend schedule. Two of these weeks may be consecutive. It is
envisioned that Father shall take two weeks in one month and one
waek In each of the remaining summer months. Father shall advise
Mother of the weeks in which he intends to exercise these periods no
later than April 1st of oach yoar. Mothor shall be entitled to two
uninterrupted weeks of summer vecetlon with the child, Mother shell
edvlse Father no later then April 16th of eech year as to tho two
weeks in which she intends to exercise her periods of custody. These
periods of time may be consecutive. The parties agree that they shall
shara the transportation to accomplish the transfer of the custody
during these summer months. In addition, the specific transfer times
shall be agreed upon by the parties as well. The parties recognize that
the summer schedule Is for 199B. In 1999 and all years thereafter. It
is envlsionad that Father may ba entitled to additional time with the
child and that he does Ilot have to show e change of circumstallces In
the event that he requests additional time and Mother does not
otherwise agree to the additional time requested.
6. While the child is in the custodial care of the Father, he
agrees that the child shall have no contact with tha maternal
grandmother, Dorothy Wilt.
BY THE COURT,
Matthew J. Eshelman. Esquire
-
Thomas J, Willi ems, Esquire
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F"ANCE8 H. DEL DUCA
ATTOANIV AT LAW
TIN WItt HIDH 1'''lar
QAIIUILI, ,lIlt4ftlyi-VANIA
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I: IN THE COURT OF COMMON PLEAS OF
: : CUMBERLAND COUNTY, PENNSYLVANIA
:: 94- '3-'15-(1 CIVIL TERM
DEANDRA F. KICHTA
SHAWN p, KICHTA
: I
II
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend
against the claima aet forth in the following pagea, you
must take prompt action. You are warned that if you fail to
do so, the case may proceed without you and a decree of
divorce or annulment may be entered againat you for any
other claim or relief requeated in these papers by the
Plaintiff. You may loae money or property or other rights
important to you, including custody or viaitation of your
children,
When the ground for the divorce is indignitiea or
irretrievable breakdown of the marriage, you may request
marriage counseling, A liat of marriage counaelors is
available in tho Office of the Prothonotary at the
CUMBERLAND COUNTY COURTHOUSE, CARLISLE. PENNSYLVANIA. 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR
ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF
THEM.
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 yOU
CAN GET LEGAL HELP,
COURT ^DMINISTRATOR
Cumberland County Courthouse
Fourth Floor
Carlisle, Pennsylvania, 17013
Telephone I 717-240-6200
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.__.....rances ,De Duca
10 West High st.
carlisle, PA 17013
DEANDRA F. KICHTA
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
94- 3.JSV CIVIL 1994
IN DIVORCE
SHAWN P. RICHTA
COMPLAINT UNDBR SBCTION 33011CI or THB DIVORCB COOl
1, Plaintiff is Deandra F, Richta, who resides at 134
College Ifill Road, Enola, Cumberland County, Pennsylvania,
2. Defendant is Shawn p, Kichta, who residea at 2885
Bowes Lane, Woodbridge, Virginia, 22193,
3. Plaintiff has been a bona fide resident in the
Commonwealth of Pennsylvania for at least six (6) months
immediately previoua to the filing of thia complaint and
defendant was a bona fide reaident until May 8, 1994,
4. The plaintiff and defendant were married October
17, 1992 in Camp Hill, pennaylvania.
5, There have been no prior actiona of divorce or for
annulment between the partiea.
6. Plaintiff avers that the grounda on which the
action is based ia that the marriage is irretrievably
broken,
WHEREFORE, plaintiff requesta the Court to enter a
deoree in divorce,
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~hoes H. Del ~uoa
Attorney for Plaintif
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I I IN TilE COURT OF COMMON PLEAS OF
:1 CUMBERLAND COUNTY, PENNSYLVANIA
II 94- 3;). SO CIVIL 1994
II
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DEANDRA F, I<ICIlTA
BHAWN P. KICIlTA
AND NOW,
ORDBR or COURT
this t,tfI~ay of June, 1994,
upon oonsideration
of the attaohed Petition, leave is granted to the plaintiff
to proceed in forma DauDeris,
BY THE COURT,
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I I IN TilE COUI\T or COMMON PLIAB 01"
II CUMlIERLMD COUNTY, UtlNSYLVAIUA
II 94- 3:.:lStl CIVtT, 19~4
II
II IN DIVORCE
v.
SHAWN P. ItICltTA
lJlJ\tcJ.".~
Dear l'rutlu.I/lo\:ary I
I. FRANCES H. DEL DUCA, otAte that % .~ provl~in9 free
1e9a1 .erYiee. to the above plaintiff, O..n4ra F, Kichta,
June 16 t 1994
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C--~DIl Du.:."
10 Weet High St.
Carllclo. P^ 17013
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DEANDRA F. t<ICIITA,
plaintiff,
Defendant.
I IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
I PENNSYLVANIA
94-3250 CIVIL ~ 1i=R ~
IN DIVORCE
v,
SHAWN P KICIITA,
ANSWBR TO COMPLAINT UNDER ~ 3301(01 or THB DIVORCE CODB
COMES NOW the Defendant and for his Answer to the
Complaint filed herein doe a repreaent aa followa:
1. Defendllnt admits the allegation at no, L
7., Defendant admits the allegation at no, 2.
3. Defendant admits the allegation at no, 3,
4, Defendant admita the allegation at no, 4 ,
5. Defendant admits the allegation at no. 5,
6. Defendant admita the allegation at no, 6,
WHEREFORE, Defendant joins in Plaintiff'a request
that this Court enter a Decree in Divorce in the above-
styled matter,
Reapectfully Submitted
s~.r.~lL
Defendant
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: : IN THE COURT OF COMMON PLEAS OF
II CUMBERLAND COUNTY, PENNSYLVANIA
II NO, 92-3250 CIVIL 1994
DEANDRA F. KICHTA
SHAWN p, KICIITA
: :
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IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under section 3301(c) of the
Divorce Code waa filed June 16, 1994,
2. The marriage of plaintiff and defendant ia irretrievably
broken and ninety days have elapsed from the date of filing the
complaint,
3. I consent to the entry of a final decree of divorce.
4, I have been advised of the availability of marriage
counaeling, that I may request that the Court require that my
apouae and I participate in counseling, and that the Court
maintaina a list of marriage counselors in the Prothonotary's
Office, which list ia available to me upon requeat, Being so
adviaed, I decline to requeat that the Court require that my
spouae and I participate in counseling,
5, I understand that I may lose rights concerning alimony,
diviaion of property, lawyer's fee a or expensea if I do not claim
them before a divorce is granted.
I verify that the statements made in thia affidavit are true
and correct. I understand that false atatementa herein are made
aubject to the penaltiea of 18 Pa.C.S. Sec. 4904 relating to
unaworn falaification to authorities.
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Dated: Sept. 20, 1994
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: I IN THE COURT OF COMMON PLEAS OF
:: CUMBERLAND COUNTY, PENNSYLVANI~
:: NO. 94-3250 CIVIL 1994 ~,
: : U~
DEANDRA F, KICHTA
SHAWN p, KICHTA
:1 IN DIVORCE
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AFFIDAVIT or CONSENT
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1. A complaint in divorce under section 3301 (c) 'of t~
Divorce code waa filed June 16, 1994.
2, The marriage of plaintiff and defendant ia irretrievably
broken and ninety days have elapsed from the date of filing the
complaint,
3, I conaent to the entry of a final decree of divorce,
4. I have been advised of the availability of marriage
counaeling, that I may request that the Court require that my
spouae and I participate in counseling, and that the Court
maintains a liat of marriage counselors in the Prothonotary's
Office, which liat ia available to me upon request. Deing so
adviaed, I decline to requeat that the Court require that my
spouae and I participate in counseling.
5. I underatand that I may lose rights concerning alimony,
diviaion of property, lawyer's fees or expenaea if I do not claim
them before a divorce ia granted.
I verify that the atatements made in this affidavit are true
and correct. I understand that false statementa herein are made
subject to the penaltiea of 18 Pa.C.S. Sec, 4904 relating to
unaworn falaification to authoritiea.
Datedl f) l'J'i h j I
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DeANDRA L. FERBER,
Plaintiff
IN Tim COURT OF COMMON I'LEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 94-3250
SHA WN I' KICHTA,
Defendant
. IN CUSTODY
DEFENDANT'S COMPLAINT TO CONFIRM CUSTODY
I. Defendant is Shawn 1'. Kichta, on adult individual currently residing at 2885 Bowes
Lone, Woodbridge, Prince William County, V A 22193.
2. I'laintifl' is DeAndro L Ferber, on adult individual currently residing at 390 I Park
Circle, Camp Hill, Cumberland County, I' A 170 II.
3 _ Defendant ~eeks shored custody of the child, Vivian Chantcl Kichta, who was born
on April 9, 1993.
The child was not born out of wedlock_
Since the child's birth, the child has resided with the following persons at the following
addresses for the following periods of time.
The child resided with Plaintiff and Defendant from her birth, April 9, 1993, until the dote
of Iheir separation, sometime in 1994. Since their separation in 1994, the parties have shared
custody of the child. The Defendant has resided at the above address, bUlthe I'laintilrhas lived at
various addresses, the most recent address being 3901 Park Circle, Camp Hill, I'A
The natural mother of the child is I'laintill' who resides as aforesaid. She is divorced and
living separately
The natural father of the child is Defendant who resides as aforesaid. He is divorced and
living separately.
4. The rellltionship of the Defendllnt to the child is thllt of Fllther The I'llIintifl'
currently resides with the 1l,lIowing.
~
&:llluntWlill
Rebecca Miller
Defendant's Mother
~. The rclalillllshlllofthe I'luilllll1'lolhc child I" Ilmllll' MOlhl'1 Thc Illnlntll1' cUl/cnlly
rcsides wilh lhe following
t:Ww: 1\lllnlluU5111~
Uarold Felllcl I'lnilllll1's FlIlhcl
KlIlhy M FClhcr PllIiulill's Sll'Jlltlolhcl
Tcrry Dlldcl)' PllIllllill's hlllll'l'l'
Cl. Thc pallics hlll'c IllllpllllklplllCl1 illPll'lillllSlilillllllllll nllll'l'lllilllllhc n15lody ol'lhe
child in Ihis clIllIl III IIIlY CIIIIII
The Dclclldlllll has Illl illlhllllllliollllf II l'IIShllh' III lll'l'l'lhllll \'lllIl'I'llIIlllllhc l~hild pcndillg ill
IIIlY III her cOllll
7 Thc hcsl illlCICSlllllllpl'lII11llll'lll wdlilll' Ill' I Ill' dllhl will hc sCII'cd hy 1!IlIIllillg shared
cllstody 10 Delcndalll hCCIIIISC Ill' I Ill' illlPlllllllll'l' Ill' hlll'llllllIllllllll"illllll'llllillllship wilh hCI falhcr
In Ihis rcgald, 1>Clcndllnt is willilllllll Shllll' 1I1111S1IlIIIII1l1I1I \1'lIh Phlllllill ill IIldcl 10 Itlllhcr lhe
relaliollship wilh his child
II Delclldlllll dllcs 11111 ~Iltlll IIfllll\' 111'1"1111111111 JI"II\' 11I11ll'sC 11'111'cl'dillllS whll c1aillls
10 have clIslody III \'isillllilllllillhh wilh ICSpl'l'\ IlIlhc dllhl
WIIEllEFOltF, Ill'lL'1ll11l1l1 ICII"l'sIS \'11111 1Il11llllllhll' 1'1II111 10 scl II lillle IIlld plncc Ihr II
hcarillg III whkh Delcllllalllll~llIeKI"lhc 1'lI111tllllllllllllldi'IIIIlIIIl 11ll' ('IISI111I\' Olllcl I'cllding KlIid
hcaling, DclcndallllcljllCKISICIllIIOIIU)' l'IIShllly
MAlliSON, Ilh\lmOIU+, WII.LlAMS & OTTO
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