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Home My WebLink About94-03460 ARLENE PORTER, Plaintiff v. CU~IREnLAND COUN'I'Y, I'li;NNllYI,vANIA NO. 94- ;I/(I"IICIVII. '1'IWH cuS'rODY ROBERT NAUSS, Defendant ORDER OF COUR'r AND NOW, upon consideration of the attached complaint, It Is hereby directed that the parties and their roapcctlvD oounsel appear before ~l~:.lJS:~t-J_!._-6:..~l[':t_t:,! ~ _ _.. _ _, thl' concil iator, a t_Ylh..tlq,~r._ _cJ~l fIJ J~~(_I~i:~~ tho ...-121_ _ .1l1lY ,. of ." (\ ".L.t 1994, at--.:..L:':'..L~m., for a Pre-lIear Inlj Cuatody Conference. At such conferenco, an effort will he made to resolve the issues in dlsputo, or If this cannot he accompllshod, to define and narrow the issues to he hOllrd hy tho oourt, and to enter into a temporary order. FlIlluro to Ilppoar at the conference may provide grounds for entry of a temporary or permanent order. \ly the Court, ~~~GJjhl n,~jj,dc;'~ , ~~onc~~ri~~ ~~ YOU SIIOULD TAKE 'rillS PAPER '1'0 voun I.A\~YI.;(l ^'I' ONCE. IF YOU DO NOT IIAVE A LAWYER OR CANNO'r ^1'1'01l0 ONB, 00 '1'0 Oil '1'~:(.F.1'1I0N~: 'rilE OFFICE SE'r FOR'1'Il BELOW '1'0 ~'INO OU'I' WIII,:nE YOU CAN @'I' 1.I~a^,. IIEI.P. COURT ADMINIUTHATOIl, 4th PLoon CUHDEnLAND COUN'I'Y COUH'I'1I0U8E CARLISLE, P~NNSYLV^NIA 17013 TELF;PIIONE NUHDI,n, (717) 240-6200 JUt I B ~ I AH '911 l ,,\ He is single. 4. The relationship of plaintiff to the child is that of mother. The plaintiff currently is reaiding 22028 Cedar Run Drive, Camp Hill, Pennsylvania. 5. The relationahip of defendant to the child is that of father. The defendant currently resides with the fOllowing personsl Relationship Name Mr. Nauss Mrs. Nauss Father Mother 6. The plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 7. The plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. B. The plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 9. The best interest and permanent welfare of the child will be served by granting the relief requested because the mother has been the primary caretaker and can both provide and care for the child. 10. Each parent whoso parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, the plaintiff requests this Court to grant primary physical custody of the child to her and poriods of partial custody in the defendant. Respectfully submitted, -0 l\.. H 0UUoA n Carey ttorney for Plaintiff LEGAL SERVICES, INC. a Irvine Row Carlisle, PA 17013 (717) 243-9400 Datel (p. /'-1. 9{ The above-named Plaintiff, ARLENE PORTER, verifies that the statements made in the above Pctition are true and correct. Plaintiff understands that falsc statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. ~ ;"lC:: .... 'l I-I i'l) " .,; . ,. i.< ,-~." ~ ~ <:) Q I.ri i)~ ARLENE PORTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94- :NIrO CIVIL TERM v. ROBERT NAUSS, Defendant PRAECIPe TO PROCEeD IN FORMA PAUPERIS To the Prothonotary: Kind 1 y a 11 ow, ARLENE PORTER, PI a 1 n t iff, to proceed in lQIJlll! R!lYP~r jl>. I, Philip C. Briganti, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation Is attached hereto. a~ (~.A' Phl1iP;C. Brlgan i Attorney for Def ndant LEGAL SERVICES, INC. B Irvine Row Carlisle, PA 17013 (717) 243-9400 AFFIDAVIT IN SUPPORT OF PETITION fOR LEAVE TO PROCEEQ-1H-EQBMA PAUPERIS 1. I am the plaintiff in the above matter and beoause of my finanoial oondition am unable to pay the fees and costs of prosecuting, defending. or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: Address: Arlene Porter 2202B Cedar Run Dr. Camo Hill .-EA.J-IQjJ Sooial seourity Number: __ 239-98-8649 (b) If you are presently employed, state Employer: _ Bur~AY-of Disabi1itv Address: _.______ll1..LRL_Q.Will!1:Qn~. .Ji{\r.rl ~.b!!rlL_ PA 171104 Salary or wages per month :_.....$.1 OQ.a&L. Type of work: _____.J!tlQr.!It.ML _ _.___________ If you are presently unemployed, etate Date of last employment: N/A Salary or wages per month: Type of work: (0) Other income within the past twelve months Business or profession: o o o o other self-employment: Interest: __un. Dividends: Pens i on and annu it i es : 0 Social Security benefits: 0 Support payments: ___ 0 Di sabi 1 i ty payments: ____. 0 Unemployment compensation and supplemental benefits: 0 Workman's compensation: 0 Publ ic Assistance: _.l1.QJH!..OO/6 months orior to Jan. 94 Other: ----.-----.------- o (d) Other contributions to household support (Wife)(Husband) Name: N/A If your (husband) (wife) is employed, state Employer: Salary or wages per month: Type of work: "-. .. ---------_.._---*------- Contributions from children: (e) Property owned Cash: ..il.LOO Check i ng Account: .----$Q,.QCl_.___ Savings Account: Certificates of Deposit: Real Estate (including home): Motor vehicle: Make ._D~9iL Cost JJJOO.OO 13.00 JUA_ N/A Stocks; bonds: Other: (f) Debts and obligations Mortgage: N/A Rent: --tl~ubsidized 146.00 Loans: _____._ 0 Monthly Expenses: Groceries 12~LOD: TeleDhone 140,O~ Gas for heat/coollilliLlli.l_QQ: Electric 125.00: Insurance for car I~D:_~s for CaL-IeO.DO: Credit Car 135.00: QAYQAL~Jl1e~lOO: ClothinR 150.00: Misc. EXDenses 125.00 (g) Persons dependent upon you for support (Wife) (Husband) Name: N/A Children, if any: Name: Demarkes Nauss Age: 2 vears 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made sUbject to the penalties of 18 Pa. 0.8. 4904, relating to unsworn falsification to Datel tr/~/r;( ( authorities. . ;::j-" I / ~ - -~-- -'- ,it laintiff . I~ ($ ~ :a ~ ~ ::a c:.. , ,--\ , ,) ,. ..,~ ~t'" "~b ';:1- :,01.: ,l .il .I ~B f.1 SEP 14 199~ de.- v UN 'I'HB COUR'I' OF COMMON PLBAS OF ,CUHBBRLAND COUN'I'Y, PBNNSYLVANIA , ,NO. 3460 - CIVIL - 1994 , , 'CIVIL AC'I'ION - CUS'1'ODY ARLBNB POR'I'BR, Plaintitt ROBBR'I' NAUSS, Defendant v'1 COURT ORDER AND NOW, this I~v' day of ~ ,1994, the Conoiliator be1ng advised th'irtJie parties e reaohed an agreement, the Conoiliator relinquishes jurisdiotion. ARLENE PORTER, plaint iff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-3460 CIVIL TERM CUSTODY v. ROBERT NAUSS, Defendant ORDER OF COURT AND NOW, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before Hubert Gilroy. ESQuire , the~;ciliator, at -!th Floor. Cumberland County Courthouss on the I .~ day of ~OlJt7nbr' ,1994, at fL"~lll..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 define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. By the Court, .-;1jIL(;( . 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 ADMINISTRATOR, 4th FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717) 240-6200 .' '"" DEe 5 1994(/,,\ ARLBNB PORTBR, plalntlff ,IN THB COURT OF COMMON PLBAS OF ,CUMBBRLAND COUNTY, PBNNSYI,VANIA , ,NO. 3460 - CIVIL - 1994 , , ,CIVIL ACTION - CUSTODY v ROBBRT NAUSS, Defendant COURT ORDER AND NOW, this i,t ( day ofl]\'c,,,l\(-- , 1994, upon conslderaUon of the attache~stodY Conclliatlon Report, it is ordered and directed as follows' 1. The Mother, Arlene Porter, shall have legal and physical custody of Demarkes L. Nauss, born August 18, 1992. 2. The Father, Robert Nauss, shall enjoy temporary physical custody with the minor child as follows: A. On alternating weekends for a period of five hours. This shall normally be on Saturday from noon until 5 P.M. Where Father advises Mother by Wednesday preceding the Saturday he is scheduled to have custody that he is not available on Saturday, he may exercise temporary custody on Sunday from 2 P.M. until 7 P.M. This custody shall commence the weekend of November 18, 1994, with the Father to have custody that Sunday. The above Custody Order anticipates that the Father's custody time with the child will be expanded after a reasonable period of time. In the event the parties are unable to reach an agreement on expanding the custody, either party may petition the Court to have this case again scheduled with the Custody Conciliator for a conference. 3. 4. Father shall handle all transportation for exchange of custody, with the exchange to take place at the Maternal Grandmother's home. oc, BY THE COURT, '0.. emy .'"m,"'L.IJ,~/~~f~II"ff .,\ 1. ./ Robert Nauss-1412 Naudian Street, Harrisburg, PA 171Q4 (:l\"h Il...J,,\ I~I t, /'1'1; .J, ( ,. "