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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF ~l PENNA,
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LEE PAGI\.
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i\: II. 94-3909
PlaIntiff
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DEBRA ANN PAGE,
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DECREE IN
DIVORCE
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AND NOW, ,.." .. ..'???~,"~,,, ~J.~'" '. 19 ,~5..,. It Is ordered and
decreed that, .. .. .. ..l~~~. J?~ql~" .. .. " ".. ..,.. .." , .. ... , ..", plaintiff,
and, , . , , , , , , , , . , ' , llJ\llM ANN, J'NlJ\, , , , , , , , , , , , , ' , , . . . , , , " , . , '. defendant,
are divorced from the bonds of matrimony.
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The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered;
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LEE PAGE,
IN TilE COURT 01' COMMON PLEAS 01'
CUMBEI\LAND COUNTY
Plalntlfl'
: CIVIL ACTION - LAW
VI
NUMBEI\: 94.3909 CIVIL TERM
DEBRA ANN PAGE,
IN D1VOI\CE
Defendant
PRAECII'E TO TRANSMI1' I\ECORD
TO TilE PI\OTIIONOTARY:
Transmit Ihe record, together wilh the following information, to Ihe Court for entry of a
divorce decree:
1. Ground for divorce: irretrievable breakdown under Section 3301(C) oflhe Divorce
Code.
2. Date and manner ofselVice oflhe complaint: Personal SelVice on Debra Ann Page,
July 20, 1994, al3401 Ritner Highway, Newville, Cumberland County, PA.
3. (Complete either paragraph (a) or (b),)
, , (a) Dote of eKe cut ion of the amdavit of consent required by Section
3301(c) ofthe Divorce Code: by Ihe plaintiff, March 16, 1995; by the defendant,
March 16, 1995,
4. Related claims pending: NONE,
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Sally J. Wind r Esquire
Attorney for fend an!
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LEE PAGE
IN THB COUllT OF COHHON
PLEAS OF CUttBB\l.LAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
'14 ,. -3'1 /Yj
NO, . CIvlL Ie ^',t,
plaintiff
vs.
DESHA ANN PAGE
Defendant
ORDBIl OF OOUlT
AND NOW, 'Yl< ,,} I S-, 199Lj upon consideration of the attached complaint,
it is hereby directed that the parties and their respective counsel appear before
(",,..,c,~ll 1\"\'?Bsquire, the conciliator, at <, ~)l, IV I:,)) It (:,,1 I (thllly.
,
, Pennsylvania, on \tJ ([\/\1 ~Il,.( the -}j I, day of S:('l(Il1~~1 ,199~,
at '2- o'clock V .m., for a Pre-Hearing custody Conference. At such conference,
an effort will be made to rpsolve 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 children's attendance is not mandatory.
Pailure to appear at the conference may provide grounds for entry of a temporary or
permanent order.
POll THB COUllT,
By '-___, '-Sf'
cus ody conciliator . ~1
yOU SHOULD TAKE THIS PAPEIl TO YOUIl LAWYBR AT ONCB. IF YOU DO NOT HAVB A LAWYER Oil
CANNOT AFFORD ONE, GO TO OR TBLBPHONE THB OFFICB SET FORTH BBLOW TO FIND OUT WHBRB YOU
CAN GBT LBGAL HBLP.
OFFICB OF TIIB COUllT ADHINISTRATOIl
COUllTHOUSB, 4TII FLOOR
CARLISLB, PA 17013
(717) 240-6200
CUMDERLAND 36
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LII PAOI, I IN THI COURT OF COMMON PLIAS
Plaintiff I CUMBERLAND COUNTY, PBNNSYLVANIA
I
VB. I NO.
I
DBBRA ANN PAOE, I
Defendant I CIVIL ACTION - DIVORCE/CUSTODY
NOTICB TO DEFEND AND CLAIM RIGHTS
YOU HAVE BBEN SUED IN COURT. If you wish to defend
against the claims set forth in the following pages, you must
take prompt action. You ars warned that if you fail to do so,
the case may proceed without you and a decree of divorce or
annulment may be entered against you by the Court. A judgment
may also be entered against you for any other claim or relief or
property or other rights important to you, including custody or
visitation of your children.
When the ground for the divorce is indignitiss or
irretrisvable breakdown of the marriage, you may request marriage
counseling. A list of marriage counselors is available in the
Offics of the Prothonotary, Cumberland County Court House,
Cumberland County Courthouse, One Court House Square, Carlisle,
Pennsylvania.
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.
CUMBERLAND COUNTY COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE, rOURTH FLOOR
ONE COURT HOUSE SQUARE
CARLISLE, PENNSYLVANIA 17013
(717) 240-6200
LEE PAGI, I IN THE COURT OF COMMON PLEAS
plaintiff I CUMBERLAND COUNTY, PBNNSYLVANIA
I
va. I NO.
I
DEBRA ANN PAGB, I
Defendant I CIVIL ACTION - DIVORCE
COMPLAINT UNDER SECTION 330110\
OF THE DIVORCE CODE
COUNT NUMBER 1.
I. plaintiff is Lee Page, an adult individual residing
at 325 South Third Street, New Cumberland, Cumberland county,
Pennsylvania 17055.
2. Defendant is Debra Ann page, an adult individual
residing at an unknown address with a last known address of 3401
Ritnsr Highway, Newville, Pennsylvania.
3. Plaintiff has besn a bona fide resident of this
Commonwsalth for at least six months immediately previous to the
filing of this Complaint.
4. Plaintiff and Defendant were married on August 15,
1981, in Newville, Pennsylvania.
5. There have been no prior actions of divorcs or for
annulment between the parties.
6. Neither of the partiss in this action is presently
2
a member of the Armed Forces on active duty.
7. plaintiff has been advised of the availability of
marriage counseling and that hs may have the right to rsquest the
Court to require the parties to participats in such counseling.
Bsing so advised, plaintiff does not request that the Court
require ths parties to participate in counseling prior to a
Divorcs Decree being issued by ths Court,
B. plaintiff avers that the ground on which the action
is bassd is that ths marriage is irretrievably broken.
9. plaintiff requests the court to sntsr a Decree of
Divorce.
COUNT HUMBBR 2
23 Pa, C.S.A. 3301 (a)(6)
10. Avsrments one (1) through (10) abovs are herein
incorporated by reference thersto and made a part of this count.
11. The Defendant has offered such indignities to the
plaintiff, the innocent and injured spouse, as to render his
condition intolerable and his life burdensome.
12. Plaintiff requests the court to enter a Decree of
Divorce.
3
COUNT NUMBBR 3
CUSTODY
13. Averments ons (1) through (13) above are herein
incorporated by reference thsreto and made a part of this Count.
14. Plaintiff sesks primary physical and legal custody
of the following minur childrsn:
NAME
AGE
PRESENT ADDRESS
Rebecca Mae Page
9
Beaver Run Road, Lafayette, N.J.
Kurtis Lee Page
11
3403 Ritner Highway, Newville, PA
15. Ths childrsn wers born of the marriage of ths
Plaintiff and the Defendant.
16. Ths children are presently in the custody of the
dsfendant however as of on or about July 1, 1994, Rebecca Mae
Page has been staying with her paternal grandmother and hsr
husband, Darslyn and Nils Ericson, Beaver Run Road, Lafayette,
Nsw Jersey and Kurtis Lee Page has besn staying with his maternal
grandparents, shirley and George Stanbaugh, 3403 Ritner Highway,
Newville, Psnnsylvania bscauss the Defendant is unemployed and
without a residencs and therefore is unabls to provide for the
children.
17. During the last five ysars ths children have
resided with ths following persons at the following addrssses:
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a) From November, 1991 to February, 1993 with ths
Plaintiff and the Dsfsndant in Annville, Pennsylvania.
b) From March, 1993 to May 1, 1994 with the
Defendant at 3401 Ritner Highway, Newville, cumbsrland
county, Pennsylvania.
c) From May 1, 1994 to on or about July 1, 1994 with
the Dsfendant and an unknown femals at an unknown address
believed to be in the Deptford, New Jersey area.
e) From July 1, 1994 to the pressnt as statsd in
paragraph 16 above.
18. The plaintiff is the father of the children. He
resides at J25 South Third strset, New Cumberland, Cumberland,
Pennsylvania by himself.
19. The Defsndant is the mother of the children. She
rssidss at an unknown address with unknown person(s).
20. Plaintiff has not participated as a party or
witness, or in another capacity, in other litigation concerning
ths custody of the children in this or another court.
Plaintiff has no information of a custody procssding
concerning the children pending in a court of this commonwealth
or in anothsr state or commonwealth.
Plaintiff doss not know of a person not a party to the
proceedlngs who has physical custody of the children or claims to
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have custody or visitation rights with respect to ths children.
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21. Ths bsst interest and permansnt welfare of the
children will bs servsd by granting the relief rsquested because
Plaintiff is the fathsr of ths children and Defendant has failed
to provide adequately for their wslfars.
22. Each parent whose parental rights to ths children
have not been terminated and the person who has physical custody
of the children havs been named as partiss to this action.
Datsdl ,A
-tilf ' r
17112-0443
WHEREPORE/ Plaintiff rsquests the Court to sntsr a Decree:
(a) Dissolving the marriage bstwesn Plaintiff and
Dsfendant,
(b) Granting the Plaintiff primary custody of the
minor childrsn
(c) Such further relisf as the Court may determine
equitable and just.
Rsspectfully submittsd,
, I
6
VBRIPICATIOR
I, Lee Page verify that the statements made in the foregoing
complaint are true and correct to the bsst of my knowledgs,
information and belief. I undsrstand that the statements herein
are made subject to the psnalties of 18 Pa.C.B. Bection 4904
relating to unsworn falsification to authoritiss.
/
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ACCEPTANCE 011 SERVICE
I, DEBRA ANN PAGE, do acknowledge that I received a true and correct copy oflhe
Complaint in Divorce and Notice and Plalntlfi's Affid8vit in the above-captioned divorce and
accept the service thereof on July 20, 1994 at 31t01 Ritner Highway, Newvillc, Pennsylvania,
I verify that the statements made in this Acceptance of Service are truc and correct. I
understand that false statements herein are made subJect to the penalties of 18 Pa,C.S, Section
4904 relating to unsworn falsification to authorities.
ldJjJl\(.\ G, e~ ;1-'
DEBRA ANN PAGE
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LEE PAGE,
IN TilE COUR'I' 011 COMMON PLEAS 011
CUMBERLAND COUNTY
1'lalntlfF
VI
CIVIL ACTION -l.AW
NUMBER: 94.3909 CIVIL TERM
DEBRA ANN PAGE,
IN DIVORCE
Defendant
AFFIDA VI'I' 011 CONSEN'I'
I. A complaint in divorce under Sectionno.c) of the Divorce Code wasllled on July] 3,
1994.
2. The marriage of plaintlO' and defendant is Irretrievably broken and ninety days have
elapsed from the date of I1Ilng the Complaint.
3. I consent 10 the enlry of a final decree of divorce,
4. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
I verify lhatthe statements made in this affidavit arc true and correct. I understand that
false slatements herein arc made subject to the penalties of 18 Pa. C.S. scctlon 4904 relating to
unsworn falsification to authorities,
Dale:
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LEE PAGE.
IN TilE COUIlT 011 COMMON PLEAS 011
CUMBERLAND COUNT\'
Plaintiff
VI
CIVIL ACTION. LAW
: NUMBEIl: 94.3909 CIVIL TEItM
DEBRA ANN PAGE.
IN OIVOItCE
Oerendant
AFFIDA VIT OF CONSENT
I. A complaint in divorce under Section330l(c) of the Divorce Code wIslUcd on July 13,
1994,
2. The marriage of plaintiff and defendant is irretrievably broken and ninety dsys have
elapsed from the date of l1Iing the Complaint.
3. I consent to the entry of a final decree of divorce,
." 4. I understand that 1 may lose rights concerning alimony, division ofproperty,lawyer's
fed!! ~r expenses if 1 do not claim them before a divorce is granted,
..
I verify thatlhe statements made in this affidavit are true and correct. I understand that
false statements herein arc made subject to the penalties of 18 Pa, C.S, secHon 4904 relating to
unsworn falsification to authorities,
Date:~ (.h j ~ r/Cf5
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DEBRA ANN PAGE CJ
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LEE PAGE,
PlalntllTlPetllloner
: IN THE COURT m' COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
VI.
: NO. 3909 S 94
DEBRA ANN PAGE,
DerendantlRelpondenl
: CIVIL ACTION. DlVORCE/CUSTODV
ORDER
AND NOW, Ihis I" If day of July, 1994, upon consideration of Ihe within
Pelilion for Special Relief il is hereby Ordered that Petitioner Lee Page is granted primary
phyical custody of the minor child Rebecca Mae (lage and Respondent Debra Ann Page is
directed to allow the minor child Kurtis Lee Page to remain with his maternal
grandpsrents, Shirley and George Stambaugh, fl8Rdi..t; 1\ '1llleiliati811 88Rferllllee, h""""" ~.~,
BY THE COURT:
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LEE PAGE,
Plaintiff/Petitioner
: IN TilE COlmT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
VI.
: NO. 3909 S 94
DEBRA ANN PAGE,
Defendant/Respondent
: CIVIL ACTION. I>IVORCE/CUSTODY
PETITION FOR SPECIAL RELIEF
AND NOW comes the Petitioner, Lee Page, by his allorney Diane S, Baker,
Esquire, and avers as follows:
\. Petitioner is Lee Page, an adult individual residing at 325 South Third
Street, New Cumberland, Cumberland County, Pennsylvania 17055,
2, Defendant is Debra Ann Page, an adult individual believed to be residing in
her car at an unknown location in the area of Delmont Correctional Facility, Delmont,
New Jersey with a last known address of 15 Pawnee Avenue, Clementon, New Jersey
where she had resided with the children from May I, 1994 until approximately July I,
1994 when the utilities were shut of1'lor failure to pay the renl
3, Petitioner and Respondent are the natural parents of the minor children
Rebecca Mae Page, age 9 and K1II1is Lee Page, age 11,
4, On or about July 12, 1994 Petitioner tiled a complaint for divorce and
custody of the minor children. A conciliation date has not been set as of the date of the
filing of this Pelition.
5, As set forth in the aforementioned custody complaint, paragraph 16, (a
copy of which is attached hereto as Exhibit A and incorporated herein by reference)
Respondent is unemployed and homeless and on July 4, 1994 leO the minor child Rebecca
in the care of her paternal grandparents, Darelyn and Nils Ericson in Lafayette, New
2
Jersey and the minor child Kurtis in the care of his matemal grandparents, Shirley and
George Stambaugh, Newville, Pennsylvania,
6, On Saturday, July 16, 1994, Respondent appcared at the home of Darelyn
and Nils Ericson at 6:00 aJll lind, in a screaming ragc took the minor child Rebecca with
her. According to Mrs, Ericson, Petitioner's mol her, Respondent behaved extremely
irrationally with "glazed over eyes" and was likely under the influence of drugs. Upon
leaving with the child, Respondent screamed at Mrs. Ericson that she had no home or job
and was going to "live in her car on the beach".
7, Respondent is romantically involved with Petitioner's brother, Michael
Page, who is incarcerated for manslaughter in Delmont, New Jersey, Respondent moved
to the area of Delmont Correctional Facility in MayoI' 1994 in order to be close to the
prison and takes the minor children to the prison for weekly visitations.
8, Petitioner seeks an emergency ordcr granting him custody of the minor
child, Rebecca, and directing that the minor child Kurtis remain with his matemal
grandparents pending a conciliation conlcrence bccausc of Respondent's homeless status
and obvious inability to provide propcrly for the children, Petitioner also fears that
Respondent has or will remove the child(renj from the jurisdiction of this court and is
hopeful that with the aid a custody order he can obtain the cooperation of New Jersey's
child wellnre agency when the Respondent brings the child to the prison to visit
Petitioner's brother or if she can bc located living in hcr car.
I} The best interests and wellnre of the childrcn will be scrvcd by granting the
requested reliefbccause Respondent is unable to provide lor the needs of the children and
is believed to be living in her car with Rebecca and taking the child to the prison on a
regular basis.
.1
WHEREFORE, Petitioner requests the Court enter an emergency order directing
that custody of the minor child Rebecca be granted to Petitioner and custody orthe minor
child Kurtis remain with his mateml\ grandparents pending a conciliation conference
Respectfully submlued,
Dated:
Pry
an S, Baker, Esquire
5440 Jonestown Road
P,O, Box 6443
Harrisburg, P A 17112-0443
(717) 671-9600
J.D, # 53200
4
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I, Lee I'age verifY that the statements made in the foregoing Petition are true and
correct to the best of my knowledge, information and beliet: I understand that the
statements herein are made subject to the penalties of 18 l'a,C,S, Section 4904 relating to
unsworn falsiOcation to authorities,
L1dt~Y.
,LH MOE
LEE PAGE,
Plaintiff
I IN THB COURT OF COMMON PLEAS
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I NO.
I
I
I CIVIL ACTION - DIVORCB/CUSTODY
VB.
DEBRA ANN PAGB,
Defendant
NOTICE TO DBFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. I f you wish to defend
against the claims set forth in the following pages, 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 against you by the Court. A judgment
may also be entered against you for any other claim or relisf or
property or other rights important to you, including custody or
vieitation of your children.
When the ground for the divorce is indignities or
irretrievable breakdown of the marriage, you may rsquest marriage
counseling. A list of marriags counselors is available in the
office of the prothonotary, Cumberland County Court HaUSS,
Cumberland County courthouse, One Court House Square, Carlisle,
Pennsylvania.
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.
CUMBERLAND COUNTY COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE, FOURTH FLOOR
ONE COURT HOUSE SQUARE
CARLISLE, PENNSYLVANIA 17013
(717) 240-6200
,
\ '
LEE PAGB, I IN THE COURT OF COMMON PLEAS
plaintiff I CUMBERLAND COUNTY, PBNNSYLVANIA
I
VB. NO.
I
DEBRA ANN PAGE, :
Defendant : CIVIL ACTION - DIVORCE
COMPLAINT UNDER SECTION 3301(0\
OF THE DIVORCE CODE
COUNT NUMBER 1.
I. Plaintiff is Lee Page, an adult individual residing
at 325 South Third Street, New Cumberland, Cumberland County,
Pennsylvania 17055.
2. Defendant is Debra Ann Page, an adult individual
residing at an unknown address with a last known address of 3401
Ritner Highway, Newville, Pennsylvania.
3. Plaintiff has been a bona fide resident of this
Commonwealth for at least six months immediately prsvious to the
filing of this complaint.
4. Plaintiff and Defendant wsre married on August 15,
1981, in Newville, Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. Neither of the parties in this action is presently
2
COUNT NUMBER 3
CUSTODY
13. Avermsl1ts one (1) through (13) abovs are hersin
incorporated by refsrence thereto and mads a part of this Count.
14. Plaintiff seeks primary physical and legal custody
of the following minor children:
NAME
AGE
PRESENT ADDRESS
Rebecca Mae Page
9
Beaver Run Road, Lafayette, N.J.
Kurtis Lee Page
11
3403 Ritner Highway, Nswville, PA
15. The children were born of the marriage of ths
Plaintiff and the Defsndant.
16. The children are presently in the custody of ths
defendant however as of on or about July 1, 1994, Rebecca Mae
Page has been staying with her paternal grandmother and her
husband, Darelyn and Nils Ericson, Beaver Run Road, Lafaystte,
New Jersey and Kurtis Lse Page has been staying with his maternal
grandparents, shirley and George Stanbaugh, 3403 Ritner Highway,
Newville, Pennsylvania because the Defendant is unemployed and
without a residence and therefore is unable to provide for ths
childrsn.
17. During the last five years the children have
resided with ths following persons at the following addresses I
4
a) From Novembsr, 1991 to February, 1993 with the
Plaintiff and the Defsndant in Annvillu, Pennsylvania.
b) From March, 1993 to May I, 1994 with the
Defendant at 3401 Ritner Highway, Newvills, Cumberland
county, Pennsylvania.
c) From May I, 1994 to on or about July 1, 1994 with
the Dsfendant and an unknown female at an unknown addresB
bslieved to be in the Deptford, New Jersey arsa.
e) From July 1, 1994 to ths preBent as stated in
paragraph 16 above,
18. The Plaintiff is the father of the children. He
rssides at 325 South Third Street, Nsw Cumberland, Cumberland,
psnnBylvania by himsslf,
19, Ths Defendant is the mother of the children. She
resides at an unknown address with unknown person(s).
20. Plaintiff has not participated as a party or
witness, or in another capacity, in other litigation concsrning
the custody of the children in this or another court.
Plaintiff has no information of a custody procssding
concerning the children pending in a court of this Commonwsalth
or in another statu or commonwealth.
plaintiff does not know of a person not a party to the
proceedings who has physical custody of the children or claims to
5
have custody or visitation rights with rsspsct to the children.
21. The best interest and psrmanent welfare of the
children will bs ssrvsd by granting ths relief requssted bscause
Plaintiff is the father of the children and Defsndant has failed
to provide adequately for their welfare.
22. Each parsnt whose parental rights to the children
have not been terminated and the person who has physical custody
of the children have been named as parties to this action.
WHEREFORE, Plaintiff requests the Court to enter a Decree:
(a) Dissolving the marriage between Plaintiff and
Dsfendant;
(b) Granting ths Plaintiff primary custody of the
minor children
(c) Such furthsr relief as the Court may determine
squitable and just.
Respsctfully submitted,
-,
Dated:
/
/'
~. an: S. Ba er, Esquire
5440 Jonestown Road
P.O. Box 6443
Harrisburg, PA 17112-0443
(717) 671-9600
I.D. # 53200
6
VIRIPIClAnON
I, Lee Page verify that the etatemsnts made in the foregoing
complaint are true and correct to ths best of my knowledgs,
information and bslisf. .1 understand that ths statements herein
are made subject to the penaltiss of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
5,~,c'c( "'..., 'C. j"'" (
LEE PAGE
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rJUL 211994(/1
LEE PAGE,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 3909 S 94
CIVIL ACTION, DIVORCE/CUSTODY
v.
DEBRA ANN PAGE,
Defendant/Respondent
ORpmt <>I>' COURT
AND NOW, this
day of July, 1994, upon consideration of the
Respondent's Answer and New Maller to the previously filed Petition for Special Relief, it
is hereby ordered and decreed that the Order of Court previously entered on July 19, 1994,
is herewith rescinded and it is ordered and decreed that Respondent, DEBRA ANN PAGE,
is granted and awarded custody of Rebecca Mae Page and Kurtis Lee I'age pending the
custody conciliation scheduled for September 7, 1994 and/or fnrther order of this Court.
BY THE COURT
r
v.
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 3909 S 94
CIVIL ACTION - DIVORCE/CUSTODY
LEE PAGE,
I'ia I n t I WI'et I tione r
DEBRA ANN PAGE,
Defendant/Respondent
ORDER OF COURT
AND NOW, this ",,'1 ,at- day of .Iuly, 1994, upon consideration of the
Respondent's Answer and New Matter to the previously filed Petition for Special Relief, it
is hereby ordered and decreed that an emergency hcaring to determine the issues raised by
Petitioner's Petition for Special Relief aud Respondent's Answer and New Matter filed In
response thereto is herewith scheduled for the :26 ~ day of OAt I,_
-r u
1994, at /11 (J1) o'clock ~.M. in Courtroom Number 4 of the Cumberland County
Court House, Carlisle, Pennsylvania. Each party shall bring the child who currently resides
with them to said hearing.
BY THE COURT
. A i=L
JUl 21 2 ~I PH ..,
", I' UfrlOE
Vf 1,.1 ; ill'I"O"OU~~
nU"OlRll~O tCUIHY
~fkh&il 't.~1l
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I
LEE PAGE,
Plain tiff/Petitioner
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 3909 S 94
CIVIL ACTION - DIVORCE/CUSTODY
v.
DEBItA ANN PAGE,
lJefendanVRespondent
PIIJ1I~NllANT/R1~SI)ONJ)J~NT'S ANSWER AND NEW MA11'I~R
TO I'ETlT101'I JIOR SIJI~CIA1, lmJ,lIW
AND NOW, come the IJcfendanVRespondenl, I>EIlRA ANN IJAGE, by and through
their allorneys, Andrews & Johnson and Ronald E. Johnson, Esquire, and makes the
following answer to Petitioner's Petition for Special Relief.
1. Admitted.
2. It is admilled that Respondent is an adult individual, but it is specifically denied
that she is living in a car at ;;n unknown location. Respondent did reside at 15 Pawnec
Avenue, Clementon, New Jersey, and still has some of her belongings at that addrcss.
Respondent, however, is currently residing at 3401 I~itner Highway, Newvillc, Cumberland
County, Pcnnsylvania, with her parents, George and Shirley Stambaugh.
3. Admilled.
4. Admilled in part and denied in parI. It is admilled that on or about July 12,
1994, Petitioncr filed a Complaint for Divorce and Custody of the minor childrcn.
Howcver, a conciliation datc has now been set, said prc,hearing custody confercncc to be
held Wednesday. September 7, 1994.
5. It is admilled that Respondent is no longer employed by Hickory Farms and that
she just recently lost that job. It is specifically denicd, however. that Pctitioner is homeless
nor has ever been homeless, By way of further answer, the avel'lnents of Respondent's
Ncw Maller arc incorporated herein by reference thercto.
6. It is IIdmilled thllt Respondent wcntto the home of Darelyn and Nils Ericson on
Sunday. July 17, 1994, not on Saturday July 16, 1994. As to all of the other averments set
forlh in Petitioner's parngrllph 6, Respondcnt spcdfklllly dcnics said IIvcnncnts 115 stilted
IInd by WilY of further IInswer, the avennents of I~espondcnt's New Mnller lire incorpornted
herein by reference thereto,
7. It is specifically denied thllt Rcspondent is romanticlllly involved with 11etitioner's
brother, Micllllel Pllge, nor IIl1\t she movcd to thc IIrea of Dclmont Correctlonlll Facility in
order to be close to him. By WilY of further IInswer, Rcspondentmoved to Clemcnton,
New Jersey to tllke II new job lit II suhstllntilllincrellse in income. Respondent has taken
the minor children to the prison to visit their uncle IInd in fact these visitations started
while the parties were still living together liS a family and included the Petitioner. By way
of further answer, the averments of Respondent's New MillieI' lire incorporated herein by
reference thereto.
8. It is specifically denied that Respondent is homeless or unable to provide
properly for the children. It is further specifically denied that Respondent would remove
the children from the jurisdiction of this Conrt and that an emergency order which changed
the status quo of the existing custody arrangement was necessary at all. By way of further
answer, the averments of Respondent's New Maller arc incorpomted herein by reference
thereto.
9. It is speclficlllly denied that the best Interests and welfare of the children wlll be
served by granting the relief requested in the Petition for Special Relier. By way of further
answer, the IIverments of Respondent's New MillieI' lire incorpomted herein by reference
thereto.
NI~W MA1YI'lil!
10. Petitioner and Respondent separated In Fehrnllry 1993. Since that time, the
children who are the subject of this action have continuously resided with Respondent.
I J. Slncc Fehrullry 1993, II pcriod of IIpplOxillllltcly II YCllr IInd II hnlf, thc childrcn
hllvc only spcnt scvernl wcckcnds ovcrnlght with Pctitioncr. PctitionCl"s contnct with thc
childrcn hns bccn very sporndic nnd 1II0st of his l'ontllct with thc childrcn hils not Includcd
thc childrcn stnying ovcrnight with hilll.
12. From April 1993 through April 1994, thc childrcn rcsidcd continuously with
Rcspondcnt ntthc homc of hcr parcnts at 3401 Ritncr IIlghwllY, Nc\willc, Cumbcrland
Couuty, Pcnnsylvanin.
13. In May 1994 Rcspondcnt ohtaincd ncw cmployment in Ncw Jcrscy and movcd
with thc children and n fricnd IInd co-worker, Michcllc Stllrliper, to a rcsidcncc lit 15
Pawnec Avcnuc, Clelllcnton, New Jcrscy.
14. Atthc cnd of Junc 1994, Rcspondcntlost hcr job in Ncw Jcrsey with Hickory
Farms, pursucd ohtllining othcr employment in thc Ncw Jcrscy IIrClI, but concluded that thc
cost of living in the arca was too high and shc dccided thllt shc would 1II0VC back with hcr
parcnts at 3401 Ritncr HighwllY, Nc\willc, Cumbcrlllnd County, Pennsylvnnin.
15. Respondent is, cvcn at this timc, in thc proccss of rcmoving hcr rClllnining
belongings from thc rcsidcncc nt 15 Pnwncc Avcnuc, Clcmcnton, Ncw Jcrscy, to thc hOlllc
of hcr pnrcnts nt 3401 Ritner Highwny, Ncwvillc, CUlllbcrland County, Pcnnsylvanin.
16, On Sunday, July 3, 1994, Pctitioncr pickcd up the two childrcn from
Rcspondcnt from II locntion nt thc Deptford Mnll in Ncw Jcrscy so thnt hc could takc the
children to the wedding of his brother in upstnte Ncw Jersey. This hnd been prc-arranged
and donc wilh thc conscntof Rcspondcnt.
17. Thc nnangclllcnts ns undcrstood by Rcspondcnt whcnthc childrcn wcnt with
Pctitioner to Pctitloncr's hrothcr's wcdding wns IIl11t thcir dnughtcr would hc returned to
Respondcllt at the Dcptford MIIII in Ncw Jcrsey on Mondny, July 4th, and that Pctitioncr
would takc thcir son to the homc of her pnrents, George nnd Shirley Stambnugh, at 3401
Ritner Ilighwny, Ncwvillc, Pcnllsylvanill.
18. On MondllY evening, July .1, 1994, Respondent wuited in the p/lrking lot of Ihe
Deptford Mllllunlilllpproxim/llely 9:45 PM, hnl no one delivered her dllughter to her III
Ihnl lime. Petitioner did follow through IInd IlIke Iheir son to Ihe home of Respondenl's
pnrents in Newville.
19. 'Illerellfter, Respondenl spoke with Petitioner's mother, Darelyn Ericson, nnd
wilh her dllughter, and il WIIS decided thllt her dnughter would stny al the home of Dllrelyn
Ericson for the purpose of taking riding lessons which hlld previonsly been planned for a
week later. This /lrrangement was also with the l'onsent of Respondent.
20. While the children were visiting with their grandpnrents, her son at the home of
her parents and her dllughter at the home of Petitioner's parents, Respondent anticipated
moving the remaining he longings from her home in New Jersey to her pnrents home in
Newville and believed tllIIt to do so without the children would be beneficial to her and
would not crellte an inconvenience for them.
2\. lllereafter, and up to IInd until Snnday, July 17, 1994, Respondent spoke to
ench of the children every other day by telephone.
22. During this period and as a result of a nUll1ber of phone calls with her daughter
and II call which Petitioner's mother m/lde to Respondent's mother, Respondent became
uneasy as to whether Petitioner's mother would relul'll her daughter to her voluntarily as
previously planned.
23. On Sunday, January 17, 1994, Respondent went to the home of Petitioner's
mother /It IIpproximately 6:45 ^M, hllving previously been advised by her daughter thllt
they all awoke llround 6:00 ^M to feed the horses loc/lted on the premises. ^t tllllt time,
she tnlked to her dllughter who indicllted to her Ihat she wanted to leave and retul'll with
Respondent. Respondent submits thllt she did not behave extremely irration/llly, her eyes
were not glazed over, IInd she WIIS not under the influence of drugs, nor did she scre/lm /It
Petitioner's mother or indicate that she W/lS going to "live on her car on the beach."
Rcspondcnt docs notnsc drugs nnlllllll'ly ('nnSnlllCS IIkohnl. Whilc Rcspondcnt wns IItthc
homc of Pctitioncr's lIlothcr llnd llllcmpting tn rctricvc hcr dllughtcr fmm thc homc,
Pctitioncr's mothcr ycllcd llnd scrcllmcd lit Rcspondcnt, Prior tn ICllving thc homc of
Pctitioncr's mothcr, hcr dllughtcr sllid goodhyc 10 thc pcoplc lltthc horllc, llnd if
Rcspondcnt sllid llnything upon ICllving, shc indiclltcd thlltthcy wcrc going cllmping, which
in fllctthcy llnticiplltcd doing.
24, Following thc rcmovlll of Rcspondcnt's dllnghtcr from Pctitioncr's mothcr's
homc, Rcspondcntllnd hcr daughtcr rcturncd to thc homc of Rcspondcnt's parcnts at 3401
Ritncr Highway, Ncwvillc, Pcnnsylvanill, whcrc shc was sClVcd with Pctitioncr's Pctition for
Spccial Rclicf and Conrt Orllcr.
25. Rcspondcnt rcitcl'lltcs IIl11t shc is not and ncvcr has bccn homclcss, that shc has
always providcd for thc childrcn in spitc of thc fact that Pctitioncr is approximatcly
$2,000.00 in arrears in his paymcnt of support for the childrcn, would not nec the
jurisdiction of thc Courl with thc childrcn, and lit Icnstuntil shc finds furthcr employment
will be residing nlthe homc of hcr parcnts at 3401 Ritncr Highwny, Ncwvillc, Cumbcrland
County, Pcnnsylvanin, jnst as shc hlld hctwccn April 1993 and April 1994.
26. l11C childrcn havc continuously rcsidcd with Respondent since February 1993
and have also always lived with cach othcr,
21. The effcct of thc cmcrgcncy order changes thc prcvious status (lUll regarding
custody, rcmovcs thc Rcspondent's daughtcr fmlll thc custody of Rcspondcnt with whom
shc has residcd continuously sincc Fchruary 1993, and fuuhcr scpal'lltcs thc two children
from cach othcr.
2B. HcspondcntllvclS thllt thcrc was ahsolutcly no nccd or nCl'cssity for nn
cmcrgcncy cx pllrtc court order IIltcring thl' cxisting custody aHllngcmcnt which hlld existed
sincc Fchmllry 1993.
WIIERIWORE, Hcspondcnt rcspc(.tfully rCllucsts thc Conrtto cither:
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-
LEE PAGE,
Plaintiff
IN 'rHE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v,
DEBRA ANN PAGE,
Defendant
NO, 94-3909 CIVIL
IN CUSTODY
ORDBR
AND NOW, this l, ~ day of :rvlJ ' 1994, in
consideration of the attached Stipulation Regarding custody and
Visitation, it is hereby ordered that:
(1) Shared legal custody of Kurtis Lee Page and Rebecca Mae
Page as contemplated by the Act of November 5, 1984, P,S, ~1001,
et seq., is awarded to Mother and Father,
(2) Physical custody of the Children, Kurtis Lee Page and
Rebecca Mae Page, is awarded to Mother subject to partial custody
by Father as follows I
(a) On alternate weekends from 5130 o'clock p.m.
Friday until Sunday at 7100 o'clock p,m, Provided further
that the first four weekend visits shall cummence on
Saturday at 4100 o'clock p,m. rather than Friday at 5100
o'clock p,m.
(bl Each Wednesday evening from 6:00 o'clock p,m.
until 8: 00 0' clock p, m., and Father shall provide the
evening meal for the children during this visit.
(c) Commencing in 1995, for two (2) consecutive weeks
each summer to coincide with Father's vacation which need
not be of the entire two weeks' duration. For the remainder
of 1994, the summer vacation shall be from Sunday, July 31st
through Monday, August 8th to include a horse show in New
Jersey where Rebecca Mae Page is expected to participate.
(d) On the following holidays on an alternating basis
beginning Thanksgiving 1994: New Year's Day, Memorial Day,
July 4th, Labor Day, and Thanksgiving. This holiday
visitation shall include an adjacent weekend and shall
supersede the alternate weekend visitation, so a parent
shall have custody during any weekend which contains his or
her turn for the designated holiday,
(e) Each Christmas from Christmas Day at 3130 o'clock
p,m. until December 26th at 7100 o'clock p.m. Mother shall
retain custody each Christmas from Christmas Eve through
Christmas Day at 3:30 o'clock p,m,
(f) Each Father's Day weekend from Friday
o'clock p.m. until Sunday at 7100 o'clock p.m.
retain custody of the children on each Mother's
at 5100
Mother shall
Day weekend,
(g) Such other times as the parties may mutually
agree,
(3 )
and from
herein.
Father shall provide transportation for the children to
each instance of visitation unless otherwise noted
(4) Each party shall provide the other with an accurate
address of residence which shall include a street address or
sufficient instructions so that the residence may be located,
The address shall not be limited to a mailing address. Addresses
shall be provided to the other party as soon as such a residence
is established.
(5) Each party shall allow reasonable telephone contact by
the other parent with the child or children in their custody,
(6) Mother shall not take the children for visitations with
Michael Page at the Southern State Correctional Facility in New
Jersey without the consent of Father,
(7) Mother and Father agree to cooperate in the enrollment
of both children into a counseling program with a counselor which
is mutually agreeable to the parties. The duration of counseling
and the involvement of each parent and other adults deemed
significant by the counselor shall be determined by the
counselor. Each party shall pay one-half the costs of such
counseling,
BY THE COURT I
JJ;L
n A, Hess, J,
LEE PAGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v,
DEBRA ANN PAGE,
Defendant
NO, 94-3909 CIVIL
IN CUSTODY
STIPULATION REGARDING CUSTODY-VISITATION
Plaintiff, LEE PAGE, hereinafter referenced as husband, and
Defendant, DEBRA ANN PAGE, hereinafter referred to as mother,
hereby agree to the entry by the Honorable Kevin A. Hess of the
following terms in a Court Order defining custody and partial
custody rights and responsibilities in relation to the parties'
minor children: Kurtis Lee Page born October 12, 1982, and
Rebecca Mae Page born December 31, 1984, hereinafter referenced
as Childrenl
(1) Shared legal custody of Kurtis Lee Page and Rebecca Mae
Page as contemplated by the Act of November 5, 1984, P.S, ~1001,
et seq., is awarded to Mother and Father.
(2) Physical custody of the Children, Kurtis Lee Page and
Rebecca Mae Page, is awarded to Mother subject to partial custody
by Father as follows:
(a) On alternate weekends from 5:30 o'clock p,m,
Friday until Sunday at 7100 o'clock p,m, Provided further
that the first four weekend visits shall commence on
Saturday at 4100 o'clock p.m, rather than Friday at 5:00
o'clock p,m,
(b) Each Wednesday evening from 6100 o'clock p,m,
until 8100 o'clock p,m" and Father shall provide the
evening meal for the children during this visit,
(c) Commencing in 1995, for two (2) consecutive weeks
each summer to coincide with Father'S vacation which need
not be of the entire two weeks' duration, For the remainder
of 1994, the summer vacation shall be from Sunday, July 31st
through Monday, August 8th to include a horse show in New
Jersey where Rebecca Mae Page is expected to participate,
(d) On the following holidays on an alternating basis
beginning Thanksgiving 1994: New Year's Day, Memorial Day,
July 4th, Labor Day, and Thanksgiving. This holiday
visitation shall include an adjacent weekend and shall
supersede the alternate weekend visitation, so a parent
shall have custody during any weekend which contains his or
her turn for the designated holiday,
(e) Each Christmas from Christmas Day at 3130 o'clock
p,m, until December 26th at 7100 o'clock p,m. Mother shall
retain custody each Christmas from Christmas Eve through
Christmas Day at 3:30 o'clock p.m,
(f) Each Father'S Day weekend from Friday at 5100
o'clock p.m, until Sunday at 7100 o'clock p.m. Mother shall
retain custody of the children on each Mother'S Day weekend.
(gl such other times as the parties may mutually
agree.
(3) Father shall provide transportation for the children to
and from each instance of visitation unless otherwise noted
herein.
(4) Each party shall provide the other with an accurate
address of residence which shall include a street address or
sufficient instructions so that the residence may be located.
The address shall not be limited to a mailing address. Addresses
shall be provided to the other party as soon as such a residence
is established,
(5) Each party shall allow reasonable telephone contact by
the other parent with the child or children in their custody,
(6) Mother shall not take the children for visitations with
Michael Page at the Southern State Correctional Facility in New
Jersey without the consent of Father.
(7) Mother and Father agree to cooperate in the enrollment
of both children into a counseling program with a counselor which
is mutually agreeable to the parties, The duration of counseling
and the involvement of each parent and other adults deemed
significant by the counselor shall be determined by the
counselor, Each party shall pay one-half the costs of such
counseling.
\
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I. Lee Page, Plaint f
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Esq,
Plaintiff
. ;
.
"
SAI.LV J, WIN!)..:1t
A lIunll',I' ut /,UII'
711I r. t\lll(! SUn'!
"ll1PPl'l1\hlll~1 II,". P2~" t
JIll: ' ., "1,:,r{h\,
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LEE MGE
: IN THE COURT OF COMMON PLEAS OF
: CUMIlERLAND COUNTY PENNSYLVANIA
Plaintiff.
: CIVIL ACTION - LAW
-vs.
: NUMIlER: 94-3909,Clvil Term
DEIlRA ANN PAGE
: IN CUSTODY
Defendant,
ORIJER OF COURT
AND NOW. this ~ day of January, 1995, upon consideration ofthe attached
Petillon, it Is hereby directed that the parties and their respective counsel appear before
~rt 'to G. (('1 t;""':on the ~ day of fV\'-nh , 1995. ali?'~" for a
Ci\ I ~~"'f"/cwr L,~b (0, (L>..l~'...
Conci iators Confetence, At such conference, on eflort will be made to resolve the issues in
dispute; or if Ihis can no I be accomplished. 10 define and narrow the issues to be heard by
Ihe Court, and to enler inlo a lemporary Order. All children age five or older sii<~tso be present
at the conference. Failure to appear at Ihe conference may provide grounds for entry for a
temporary or permanent Order.
For the Court,
8Y~A,
Cuslo y Concil lor ~I
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO
NOT HAVE A LAWYER OF CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
OFFICE OF THE COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE,
4th Floor
Carlisle, Pennsylvania 17013
(717) 240,6200
JtH Z,j It 43 fn 195
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LEE PAGE
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY IIENNSYL VANIA
Plaintiff,
: CIVIL ACTION - LAW
-vs-
: NUMBER: 94 . 3909 Civil Teml
DEBRA ANN PAGE
: IN CUSTODY
Defendant,
PETITION FOR MOIJIFlCA TION OF CUSTOIJY
COM/iS NOW the Defendant, DEBRA ANN PAGE, by and through her counsel, Sally J,
Winder, Esquire, and does represent as lollows:
I, Debra Ann Page, is Ihe Defendant in the above-captioned mSller residing at 3401
Ritner Highway, Newville, Cumberland County, Pennsylvania,
2, Plaintin: Lee Page, resides al 325 South Third Street, New Cumberland,
Cumberland County, I'ennsylvania,
3. The parties entered into a Stipulation and Agreement for Custody and Visitation of
lhere two (2) minor children, KURTIS LEE PAGE, bom on Oclober 12, 1982, and REBECCA
MAE PAGE bom December 31, 1984, MOlher was awarded primary physical cuslody subjecllo
partial custody of the father as setlorth in the Order ofCourl daled July 26, 1994, S copy of
which iSlllarked "Exhibit A", aUached herelo and incorporated herein by reference,
4, The children have continued to reside with mother from time of entry of the
Stipulation and Order of Court July 26, 1994,
5, Father has exercised only sporadic visitation totallin!ltwclve (12) hours since July
26, 1994,
6, Father lives in New Cumberland, Pennsylvania, with severalullrelaled persons and
has told 1II0ther Ihat he has no place for Ihe children to stay over nl!lhL
7. MOlher believes and therefore alledges that it is in the children's best interests and
Ibr lhelr wollhre thnt the July 26, 1994, Order of Court be modil1ed to provide for alternate week
end vlsltalion during day hours only and that there be no provision for evening visitation during
Ihe week, MOlher lurther requests a modil1catlon such that Thnnksgiving Day will always be
"1lont wilh Molher. Mother Ilu1her requests that special arrangements with respect to holidays be
olhninllted If Father does not regularly exercise his visitation on alternate weekends,
8, Further, Mother desires that paragraph six ofthe July 26, 1994, Order be
c1hninated,
Wlllil/li/oi)I/I~', the Defendant requests the Court to schedule a Custody Conciliation
Conlerenee In the above-captioned mailer and for modil1cation of the existing order.
Respectfully submilled,
afL'J.:lUJ:.J>-.
Sally J. nder
Allomey for Defendant
"
VERIFICATION
J VEIUFYthat the statements made in this PETITION FOR MODIFICATION OF
CUSTODY are true and correct to the best of my personal knowledge and belief. I understand
that false statements herein are made subject 10 Ihe penallies of 18 Pa. C.S. Section 4904, relating
to unsworn falsil1cation 10 authorities,
Dat-C\(,,-- '~-,\g 3 )'lQ5
~O')
'1\" LII\(i, arl\.'Y\ Po. gJU
~ANNPAOE 0
Defendant
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1.1-:1: I'N :1';,
III TilE COUI\'I' 01' COMMON l'I,El\fl OF'
L'I'f.lI\IlHIJI\ND COUNTY, PENNSYLVI\NII\
1'1 11111 I I I
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1'..1 "lIdill1L
1l0. ~4-390~ CIVIL
III CUSTODY
9 !ill.Illi
AND NOli, Lhln ..Jhi':: day 01. (\. e.~J... , 1994, ill
r,
clJlloiuel'atiol1 uf l.h,~ al.LachlHi [il.q,JlJiHLioll Regarding Custody fwd
Vlllil.otiOl1, iL in h')jr,iJy order..d Lhat,
(1) Shared lelJll1 custody or KurUs Lee Page and Ilebecca Milp.
l'oye nn cllntcl11plaL'lu by the I\cl 01' Novel\1ber !;, 1904, 1'.8, ~]OOl,
et ne4" is aWardl!U to Holher ,lIld Father,
(2) Phynill,d llU8l:0J~t' 01' l.he Childl-en, IturLill Lee Page and
n!!becca Mae Page, ilJ aW1l1'ued L t) Huthur uubj et:t to pa1-t.i al custody
by Father all folluWll1
(a) On nILl'l'nH.;e \'le.:kcJI(.ls [cum 5130 o'clc:::1t P,I\1,
Friday until sunday at 7100 0' clock p, m, Provided fUl-that"
that tho fJruL fOUl' wcekclld visits ehall COl\1mOIl'~e on
liatunioi' al. 'I,OU o'clock 1'.1\1. 1'0l.he1' than FriulIY at !;:OO
(J'clod\ p,lII.
(hI Ililch l~eunesdllY evenin~J (rom 6100 o'clock p.lII,
until 0:00 o'clock P,II\., onu Father shall provide lhe
evening l\1eal fill' the chUdr!1n during thin vinit.
(c) cOIIHlIl'ndng.\n 1"9'>, (or two (2) consecutive WO!!kB
each flUI\1I1\>:lr Lo coLncldn \~Hh l'aLlwr' u vilcat!on II/hidl nf'ecl
not be of the ulltil'e twu weuku' dU1uLion, For Ute rOlllailldel'
o[ 1994, th(~ I3UtllllICr vacation shall be from Sunday, July Hat:
throuHh MO!l<]uy. /\u~lunL Oth Lo indude a h01'se show in New
Jernoy whu)'! 1(l!\Jllc<.:u I.loe Page iB expected to participaLe.
(Ii) on Lhu 10] lowin~l holhlnys on 'ail alterni1t1 nl) bnnie
lmginnlllg 'I'hflnku~ILving 19941 New Yea1"'O Dny, r~elll<Jl ial lJilY,
Ju1i' 4th. Lallul LJny, and 'I'hunkogiving, 'fhis holidui'
viBitat:lun Ilhill1 Include un adjacent weekend and I1ho11
uuperllfHln LlII' il J telnnte weekend viol tat ion, ao i\ I\,'nont
llhall !1i1VI' clIfJlody d\Jdn~1 ilny weekend \'Ihich contains his or
het. turn I Ill' Lhe dcsignalud holida}'.
(1') 1:1<'11 l"lIrJfJtllliHl 11'<;111 Chrintlllaa !Jay at J I)() ll'dock
1',11\,11111 il 1',,,',,11I1'1'1' (',I;t,11 ill '/100 u'clodt p.m. r~uth(jl BIII\11
retu111 I..:UuLoLl}' 0.o<:h L'hdllLl1Iill1 from t:hdotl1lilo li:ve thrlluuh
Chriutl1l11u lJiI}' 011: )130 o'elock p,m,
([) I';,\,'h 1',11 her'lJ DiI}' wceklJnu (1'011\ Friday
o'c1od\ p,l1I. 1I11til Hunday at 7100 o'l.:lock p.m.
retain l:UOLot!\' uf the chil urcn on e,lch Mother's
at ~; 100
Mother uhClll
Day weekend.
(~J) Sudl othor lllllOU 110 the pal'ticll may mutually
ayrell,
(3 )
anu [rom
hel'ein.
I.'i\thlll: Ilha11 pl'ovlulJ Lt'1I1l0pol'tntion (01' the I.:hlld1'on to
each 111ut1\1\1..:0 ')[ visiLation unloss otherwise noted
(4) Each party uhall proviue the other with an accurate
address o( residence which shall include a etreet address or
sufficient instruct iOlls so that the residence may be located.
'rhe addresu uhall lIot be llmiLud to a lIIailing address, ^ddresseu
shall be llroviucd to the other !Jill'l}' ns I.JOon as such a l'esidence
is establiohed.
(5) EClch pClt'ty uhall allow reasonable telephone contact by
the other parent \11th the child or children in their custody.
(6) ~ll)thllr nhidl 1I0L take the chilu1'en for visitatiolls with
Michael Paye at Lhe Southern State COl'i'edional Facility 1n New
Jersey without tho cOlluont of Father, .
(7) Mother ilml Father agree to cooperate in tho enrollment
of both childrell into a counseling pl'ogn"n with a counselor which
io mutually ngroeilblo to the Plll'tioB, 'rhe duration of crJulIscllnH
and the involvement of each parent and other adults deemed
significant by Ll\f~ cOLlnselor shall be determined by the
counselor, Each party shall pay one-half the costs of such
counseling,
BY THE COUll'r I
H.I()-t.',,-,, d. '1'~
Kevln A, HeuD, J.
TRUE COpy FROM RECOHO
III T8litlmony whereof. I hero Ulllo SOl my h~lId
.nd lh~ Selll 01 GaldiD rlo\l Ca, r"~, Pa.
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I'rolhonolary II
MAR 3 1 /!i[iS
I,'
LEB PAGE,
Plaintiff
IIN 'l'HB COUR'l' OF COMMON PLEAS OF
ICUMBERLAND COUN'l'Y, PENNSYLVANIA
I
INO. 3909 - CIVIL - 1994
I
I
'CIVIL ACTION - CUSTODY
v
DEBRA ANN PAGE,
Defendant
COURT ORDER
AND NOW, this 'I day of 11"",'( , 1995, upon consideration
of the attached Custody ConcIliation Report, it is ordered and
directed as followsI
1. A Hearing is scheduled in Courtroom No.4 of the Cumberland
County Courthouse on the 1/JrI day of ,):, /I, c. , 1995, at
(/,' ,1(',/ M. at which time testImony in the above case will be
taken. At this Hearing, the Mother, Debra Ann Page, shall
be the moving party and shall proceed initially with
testimony. Counsel for the parties shall file with the
Court and opposing counsel a Memorandum setting forth a
history of the custody in this case, a summary of the
disputed issues, a summary of sach respective party's
position on these disputed issues, a list of witnesses
that will be called to testify at the Hearing along with a
summary of the anticipated testimony of each witness. 'l'his
Memorandum shall be filed at least ten days prior to the
mentioned nearing date.
2. Pending further Order of this Court, thi s Court's prior Order
of July 26, 1994, shall remain in effect subject to the
following modificationsl
A. Paragraph (2)(b) of the Order providing Father with
Wednesday evening visitation is removed.
B. Both parties shall give the other party written notice
on or before April 15 of each year es to when they
intend to exercise tJIO two week SIJlIUIlc'lr vacation wi th
the minor children. In conjunction with Father's two
weaks, Mother shall also be afforded ~ standard two
week summ()r vacadon wi thout intt'rruption.
B1' rHE COUR'l',
-?(~ ;::), /L
Judge ,'tevin A. Hess
"
cc, BlIlly J. Winder, Esquire _ /'C..dU:w (>~.J,.l +1 5/9 !i.
Hr. Lee Page / A ,1'.
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v
'IN 'l'HB COUR'l' OF COMMON PLBAS OF
,CUMBBRLAND COUNTY, PBNNSYLVANIA
,
'NO. 3909 - CIVIL - 1994
,
:
,CIVIL AC'l'ION - CUSTODY
LEE PAGE,
Plaintiff
DEBRA ANN PAGE,
Defendant
PRIOR JUDGE' KEVIN A. HESS
CONCILIA'l'ION CONFERENCE SUMMARY REPOR'l'
IN ACCORDANCE WI'l'H CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the
following report:
1. 'l'he pertinent information pertaining to the children who are
the subject of this litigation is as follows:
Kurtis Lee Page, born October 12, 1982, and Rebecca Mae
Page, born December 31, 1984.
2. A Conciliation Conference was held on March 16, 1995, with
the following individuals in attendance:
'l'he Mother, Debra Ann Page, with her counsel, Sally J.
Winder, Esquire, and the Father, Lee Page, who appeared
without legal counsel.
3. 'l'here is an existing Order from July of 1994. Mother
desirsd a number of modifications in connection with this
Order, with the position of the parties being as follows:
A. Mother requested that weekend visitation be
eliminated as far as overnights with the Father.
Mother's primary concern appeared to be Father's
laok of an appropriate living arrangement. It
appeara that the Father currently has an appropriate
living arrangement, and that issue seems to be
resolved.
B. 'l'he parties are in agreement that the Order would be
modified suoh that each party shall give the other
party written notice by April 15 of each year as to
when they will exercise the two weeks vacation in
the summer.
VS.
IN THE COURT OF COMMON PWAS OF
CUMBERLAND COlJNTY,l'ENNSYLVANIA
NO. 31)1l1) CIVIL 11)1)4
LEE PAGE,
Plaintiff
DEBRA ANN PAGE,
Defendant
CIVIL AcrlON . CUSTODY
ORDER
AND NOW, this ;l'"'
duy of June, 11)1)5, following hearing, the petition of the
defemlllnt for mmlil1eation of our order of July 26, 11)1)4, is GRANTED, in part, to provide that
the provisions fnr overnight visitution, therein contnined, lire SUSPENDED until such timc as
the falher resumes regular alternating weekend visitution during the duy on SUlurday or Sunday
or both for u period of four eonseeutiJe months, und provided further thut his dwelling is suitable
for such overnight visitation.
Parugrnphs 2(b) nnd 6 of our order of July 26, )l)1)4, are VACATED.
The mother shall have exclusive custody of the children, for the purposes of her vacation,
from August I to August 15,191)5.
BY THE COURT,
Lee Pagc, Pro Se
12 Wnrwiek Cirelc
Meehnnlesburg,l'A 171155
Snlly Wlnller, Esquire
For the Defenllnnt
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LAWHENCE E WElKER
PtIQltmNll',t,IH'
Qj)fffce uf tile 'ruUlullutaru
Illlllnbrrlunb u; 11I1111U
COURT HOUSE, CMlLlSLf. PA 11013
March 13, 1997
Lee W. Page
12 Warrick Circle
Mechanicsburg, Pa. 17055
Jj
Dear Sirl
^ check for $0.50 for insufficient funds has been returned to our
office. The check was for copy of Order 94-3909 Civil Tel1n. A fee of
S20.00 is charged for checks returned for insufficient: fUnd9. Please
ssend cash or money order $20.50 to our office upon return rmil or other
action rmy be taken.
Sincerely
/Lu-~ f' /Ju.Jeu., 0"
Lawrence F.. Welker
Prothonotary
JOHN E. SUKE
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GLJIIJA lAW OFFICES
rlOI :~liKlll hi ;",1 ~Iklll
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jJJ
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LEE PAGE
PLAINTI....
VS
I IN TilE COURT at' COMMON I'I.EAS
: CUMUERI,AND COUNTV, PENNSYLVANIA
I
: CIVil, ACTION, LAW
I
: CUSTODY
DEBRA ANN PAm:,
DEFENDANT
I NO,l)~,Jl)lll)
ORD.:R
AND NOW,lUil, ullon consideration of the attached com~laint,1111 hereby
directed that the partlfl.!,od Iheir,rCJllectlve coullsel appear bdore IU,>,:,c 'X G\ ~- .
1n( '.,:~ \ \ ,~....,,' ) ".:J,ri-..
theconclllator, allp...\II,,\l., l\1 \\<,,{ on the (" day of \''Y'~ ' 199 ,
at ....:1'. ,)() Q ,m., for a Pre,ltearlnll Custody Conference, Al such con erence, an elTort
will be made to resolve the Inues in disputel or If this cannol be accomplished, to deline and
narrow the Inues to be heard by the court, and to enter into a temporary order. All children
age live or older may be present allhe conference, .'allure to appear at the conference may
provide IIrounds entry of a temporary or permanent order,
"'or 111e Court:
Date t//~/fjf
Dy _).h\w~J.\: ,)-~~^ ,~..)h-
Custody Conference Officer ) (Iu.\
The Court ofCommou Plells of Cllmberlllud County is required by law
to comply with the Americllns with Disabilities Act of 1990, I,'or informatioll about
accessible facilities aud rt'asonable accommodatious available to disabled individuals
having business before the conrt, please contact our office. All arrangements must be
made lit lellst 72 hours prior to III1Y heariug or buslllt'ss before the court, You must
attend tht' scheduled conference or hell ring,
YOl! SItOlILl) TAKE TillS l'AI'm TO YOIllt LA Wym AT ONCE, .... YOl! DO
NOT itA VE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFI,'ICE SKI' limnH m:ww TO lilNU 011'1' WHEIU: YOII CAN GET
LEGAL HELP
ClJMDtRLAND COIINT liAR ASSOCIATION
2 Uberty Avt'Ulle
Carllsle,I'A 17013
(717) 249.3166
3'n.'l~
3 'I> 4f
.],/').?t)
riLED'('trICE
OF 11 ': i' """OIi)TI.,tlY
991t.~~ 17 MilOt fiB
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-~.-
VS
I IN 'I'm: fOIlKT en' fOMMON I'I.US
I fUMDt:KI.ANU ('OllNTV, Pt:NNSYI.vANIA
I
I {'IVII. AniON - I.A W
I
: (,1I51'OII\'
:
: NO, 9~,J909
:
IU: PAm:
l'I.AINl'l....
UUKA ANN PAGE,
Ut:nNUANl'
Nonn: 1'0 In:n:NU
You hur brrn lurd In I'oun, If lOU "hh to ddend a~alnlt the dalmllrl fol1h In the
follo"lnlll'allel"ou mUlt tlke aellon "Ithln l"enll (20) dlllaflrr Ihll eomplllntand notice Ire
llen'ed. bl rntrrinlll "rillen 1111'rarlnee Ilenoulll or bl Illomellnd nllnllln "rillnll "Ith thr
eoun ,oor ddrnllel orobJrellonllo lhe e1llml let fonh 11Ialnll 'IHl, YIHl Ire nmrd Ihlllf "OU fill to
do IIlthr fIlIe OIl' Ilmered "ltllllulloU Ind I dl'frer of dhurer or Innulment mal be enlrred IlIalnll
lou b" lhe coul1. A JudKmenl mil 1110 hr enlrred allllmllOll for an, other e1llm or relld requellrd
In Ihelle Ilallen h, thr 1llllnllfT, You mallcnr monel or 11/'Ollen, or olher riKblllmllOnant to )00,
IncludlnK cUltod, or Illltlllon of )oor children,
Whrn Ihr llmund for dhon:r Illndl~nllln or Irrelrinlhle hreakdo"n of the
mlrriaKe, )011 mil requClI marriaKr l'ounlellnK' A 1111 of marril~r CIIunliClorl II al allablr In thr
omcr uf Ihe l'rolhonoll'1 II the nnl Ooor In lhe Oaullhln foul1 founhoulC, .'rnnt and Market
Slreell, IIlrrilbulll, Prnnl) hanla,
It' YOU UO NOT "'U: A fUIM .'OK AUMONY, U1VISION o.'I'KOPEK1'Y,
L.AWYEK'S .'ns OK EXI'l:NSl:S UnOKt: A IlIVOKCl: OK ANNUL.Ml:Nl'IS GKANTED. YOll
MA Y !.OSE TIlE KIGIIT TO f!.AIM ANY o.'nU:M.
YOll SIIOUL.D TAKE TillS l'AI'EIl1'O \'OUIl UWYEK AT ONCl:, It' YOII DO NOT IIAVE A
I,AWYEK OK CANNOT ,\t'.'OKU ONt:, GO TO OK n:L.HIIONE TilE o.'.'ICE SET FORTII
UE!.OW TO "'ND OUT WIIl:IlE YOll CAN GKI'l.ECiAl.IIEU',
CUMBERLAND COIlNT\' OAR ASSOCIATION
2 L1bet1). Avellue
Cnrlllle,I'A 17013
(717) 249-3166
LEIi PAGIi
pl.AINl'ln'
VS
I IN rilE COVRl' m' COMMON PLIiAS
I CUMBIiRLAND COUNl'V, PENNSYLVANIA
I
I CIVIL ACTION. tAW
I
I CUSl'ODV
I
: NO, 94,J9119
I
DURA ANN PAm:,
DEFIiNDANl'
PETITION TO MODIFY A PARTIAl, ClISTODY ORDE~
PlalnUlT, by his aUorney Gnll "'. Guidn, respeclfully avers lhe following counls
Ihrough Civil Procedure Rule 1915,15 (a):
I. I'elilioner Is Ihe falher residing III 100 I'rlnceloll Arms, North I. Cranbury.
New Jersey 08512,
2. Respondenlls Ihe mol her residing al 3401 Rilller IIIghway, Newville,
Pennsylvania 17241.
3, The parties were divorced on Mardi 21, 1995,
4. During Ihe marriage, Ihey gllve birlh 10 Ihe following children: Kurtis Lee
Page, d,o,b, 10-12-82 and Rebecrn Mae Page, d,o,b, 12-31-84,
5, On Jnly 26, 1994, an Order of Court WIts enlered for pnrthtl physlral and
shared legal cUSlody for bolh children, a Irue and correcl COl'Y of which Is aUnched.
6, The Order should he 1Il0dlned becnuse:
II. nebecca Mile I'age, age fonrteen, has Indlcaled 10 I'elilloner Ihat Ihe
would like 10 live wilh him on n full'lime hasis,
I I
b. Petllloner Is capable of providing an environment that Is more lafe
and secure.
c. Petllloner Is beller able to provide for the child emollonally and
physleally.
WHEREFORE, Pelllloner requests that the Court modify the edstlng Order for
primary phYlleal cUltody and shared legal custody of Rebecca Mae Page because II
would be In the best Intertst of the child,
~
Allorney for PlalnlllT
Guida Law Offices
503 North Front Street
Harrisburg, PA 17101
717.236.6440
Supreme Court lD 1# 68740
I vrrlfy Ihallhr Ilalrmrllh mRdr IlIlhll Complallll Rrr Irllr Rlld forrrrl, I
undrnland Ihal fain Ilalrmrllll hmlll Rrr madr IlIbJrrllo thr prn.lllrl of 18
Pa,C,S, g 4904, rrlallng 10 IlIllworn fRlllnfAllon 10 alllhorlllrl,
1
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DATEd1 fttb9f
l
FEB 23 '99 10'00
FPOI H!CiHTSW,'1 IllS DEPT
TO 917172369599
PAGE,006'OO8
1.1::(,; PAGE,
IN THE COURT OF COMMON PLEAS OF
CUMDERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION . LAW
NO, 94 3909 ClVIL
IN CUSTODY
l'lainutf
v.
DEBRA ANN PAGE,
Detendant
STIPULATION REGARDING CUSTODY-VISITATION
Plaintiff, LII PAGE, hereinafter referenced as hueband, and
Defendant, blBRA ANN PAGE, hereinafter referred to a8 mother,
hereby aGree to the entry by the Honorable Kevin A. Hess uf the
(ollowing term" in a Court Order defining CUGtody and partial
custody rights and reAponllblllties in relation to the parties'
minor children: Kurtis Lu page born October l~, 1982, and
Rebecca Mae Page born Uecember 31, 1984. hereinafter referenced
as Children:
(1) Shared legal cuatody of Kurtis Lee Page and Rebecca Mae
Page as contemplated by the Act of November 5, 1904. P.S. S1001.
et seq., is awarded to Mother and Father.
(2) Physical custody of the Children, Kurtis Lee Page and
Rebecca Mae Page, is awarded to Mother oubject to partial cuatody
by Father as followA:
(a) ~n altp.rnate weekends from 5:30 o'~lock p.m.
Friday until Sunday at 1:00 o'clock p.m. Provided further
that the first [our weekend vi.its shall. commence on
Saturday at 4100 o'clock p.m. rather than Friday at 5100
o'clock p.m,
!
FEB 23 '99 10'00
FPOfl HIGHTSTOIolI filS ~PT
TO 917172369599
PAGE. 007/lXl8
(hI Each Wedncoday evcning from 6.00 o'clock p,m.
uneil 0100 o'clock p.m., and Father ahall provide the
evening meal for the children durinQ this v1sit.
(e) commencing 10 1995. for tWO (21 consecutive weeks
each lIummer to coinc1de with Fathflr's vacation which need
noe be of the ent1re tWO weeks' duration. For the remainder
of 1994, the summer vacation !Ihall be from SunddY, July nat
through MondilY, ',ugust 8th to incl ude a hor!;" show in New
Jersey where Rebecca Mae Page is expected Lo participate.
(dl On the follow1ng holidays on an alternating basis
beginnlng Thanksgivlng 1994: New Year's Day, ~emorial Day,
July 4th, Labor Day, and Thanksgiving. This holiday
visitation shall includa an adjacent weekend and shall
supersede the alternate weekend visitation. so a parent
shall have custody durlng any weekend which contains hill or
her turn for the desiQnated holiday.
Ie) Each Christmas from christmas Day at 3,30 O'clock
p.m, until December 26th at 7:00 o'clock p.m, Mother shall
retain cUltody each Chrlstmas from Chr1stmaS Eve through
Christmas Day at 3:30 o'clock p.m.
If) Each father's Day weekend (rom Friday at 5100
o'clock p.m. untll sunday at 7:00 O'clock p.m. Mothar .hall
retain cUltody of the children on each Mother's Oay weekend,
(g) Such other tlmes as the parties may mutually
agree,
FED 23 '99 10lOl
FPOIl ffIGffT5T01,11 J1I5 lo[PT
TO 917172369~99
rilGE. 008008
(31 Father nha11 proviaecraniportation'Ior'tne cn110ren to
and from each instance o[ visitatlon unlesn otherwise noted
herein,
(4) Each party shall provide the other with an accurate
address of residence which shall lnclude a street address or
sufficiont inatructlOns no that the residence may be located,
The addre.. shall not be limlted to a malling addrenn. Addresnes
oha1l be provided to the other party as soon as such a residence
in establishad.
(5) Each party shall allow reasonable telephone contact by
the other parent with the child or children in their custody.
(6) Mother shall not take the chlldren tor Vls1tatlons wlth
Michael Page at the Southern State Correctional Facility in New
Jersey Without the consent ot Father.
(7) Mother and Father agree to cooperate 1n the enrollment
of both children into a counsellng program with a counnelor which
is mutually agreeable to the partles, The duration of counseling
and the invol'.'ement of each parent and other adul tll deemed
significant by the counselor ohall be determined by the
counselor, Each party shall pay one-half the coots 01 ouch
counseling,
~
,
t'ews, Esq.
Defendant
ant
//~ k tir~
(:::'1) llne' Be er~--EBq.
Attorney tor Plaintiff
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LEE PAGE,
Plunurc
IN ';'IIE COURT OF COMMON I'LEAS CF
:".:UMUERLANU COUNTY, I'!;NNSYINI\N1A
v.
CIVIL ACTION - LAW
NO. ~4-39o~ CIVIL
IN CUSTODY
DEBRA ANN PAGE,
Defend.lnt
ORDER
AND NOW, thu ,;/t,1I.,day of ~r ______ ' 1994, in
con8iderat~on ot the attached Stipulation Regarding Custody and
Visitation, 1t lS hereby ordered toat:
(1) Shared legal custody of Kurtis Lee Page and Rebecca Mae
Page as contemplated by the Act oC November 5, 1~04, P.S. 51001,
et seq., i8 awarded to Mother and Father.
(21 Physical custody ot the Children, Kurtis Lee Page and
Rebecca Mae Page, 1S awarded to Mother Dubject to part1al custody
by Father as tollows:
(a) On alternate weekends from 5130 o'clock p,m,
Friday until Sunday at 7:00 o'clock p.m, Provided further
that the first four weekend via~tll shall commence on
saturday at 4,00 o'clock p,m. rather than Friday at 5:00
o'clock p.m.
(bl Each Wednesday evening from 6;00 O'clock p.m.
untIL 0.00 o'clock p,m., and Father shall prOVIde the
even1ng meal for the ch1ldren during thi. visit.
(c) Commenc1ng.n 1995, Cor two (2) consecutive weeks
each Bummer to c01ncide With rather's vacation which need
not be of the ~nt1r~ two weeks' curation. For the remainder
ot J994, the summer vacation shall be from Sunday, July 31st
through Monday, August Oth to include a horse show in New
Jersey where Rebecca Mae Page lS expected to participate.
(d) On the followi ng holidays on an a1 tllrnatlng uuis
beginning Thanksglving 1994: New Year's Day, Memorial Day,
July 4th, Labor Day, and Thanksg1ving, This holiday
visitation shaH include an adjacent weekend and shall
supersede the alternate weekend visitation, 10 a parent
ahall have custody during any w~ekend which contains hiu or
her turn tor the deaigr.ated holiday,
(A) Each Chr1llmaa from Chri.tmas Uay at 3130 o'clock
p.m, until December 26th at 7100 o'clock p.m. Mother ,hall
FED 23 '99 10100
PAGE. 005,'008
FPOII HIGHTSTC)I.II IllS [EPT
TO 917172369599
retain custody each Christmas tram Chnstmas Eve through
Christm., Day at 3:30 o'clock p.m.
(f) ~ach rather'. Day weekend trom friday at 5.00
o'clock p.m, until Sunday at 7,00 o'clock p.m. Mother shall
retain cu'tody ot th. chlldrpn on each Mother's nay weekend.
(g) Such ocher tlmeB liB thp. partip.B mllY mutllally
agree,
(31 Father shall provide transportation fat the children to
and tram each instance of visitation unleel otherwise noted
henin,
(4) Each party shall provide the other with an ac:c:ur.\te
address of reSidence which shall include a Btreer. address or
sufficient instructions so chllt the residence may be located.
The addres8 Ihall not be limited to a mailing address. Addresses
shall be provided to the other party as liIoon u .uch a residence
ill established.
(51 Each party shall allow rea80nable telephone contact by
the other parent With the child or children in their custody.
(6) Mother shall not take the children for Visitations with
Michael fage at the Southern State Correctional Facility In New
Jersey without the consent of Father,
(7) Mother and Father agree to cooperate in the enrollment
of both children into a cOllnsel1ng program with a counselor which
is mutually agreeable to the part i es. The durat ion of counseling
and the involvement of each parpnt and other adults deemed
significant by the counselor shall be determined by the
counselor. Each party shall pay one-halt the costs of such
counseling.
BY THE COURTt
/'f 6f.tl{~~ tl f~dAL
Xev n A. HeRR, J.
TRUE COPY FROM RECORD
In T estlmony wtMIreol, I here llIIIIO eel fff11l1nd
",d 11lI.. '" saki ~/I., PI.
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ProtllorlOwy
l.EE PAGE
PLAINTIFF
I IN TilE COURT OF COMMON PLEAS
I CUMBERI,AND COUNTY, PENNSY1.vANIA
I
I CIVil. ACTION - LAW
I
I CUSTODY
I
I NO, 9...J909
I
VS
DEBRA ANN PAGE,
DEFENDANT
ORDF.R OF COURT
AND NOW, Ihl8_da) or
,1999, AFTF.R IIF.ARING, IT IS
IIEKEBY ORDERED AND DF.CRF.ED TIIA T PRIMARY CUSTODY AND JOINT LEGAL
CUSTODY Rrb<<u Mar Pal\c IS AWARDED TO I.tt Pagt. IT IS FURTIIER ORDERED TIIAT
Dtbra Ann Pagt SIIAU. 1104 VF. PARTIAL CUSTODY AND JOINT LEGAl. CUSTODY AS
FOLLOWS:
BY TilE COURTI
J,
DIIlrlbullonl
GAIL F. GUIDA, F.SQUlRF., !IliJ NORTII FRONT STRF.F.T,IIARRISBURG, PA 171111
Dcbra Ann Pal\c, ..Jill Rltncr IIIllhlla) , NCI\\lIIc. PA 172..1
I'ROTIIONOTARY'S OFFlCF.
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LA WHENCE E, WEI.KER
P'IlOlIICJNn,,,at
CUMBERLAND COUNTY
CARLISLE, PA 170ll
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COURT HOUSE, CM1L1SLF, PA 11013
March 13, 1997
Lee W. Page
324 South Third street
New cumberland, Pa, 17070-2114
Dear Sirl
A check for $0.50 for insufficient funds has been returned to our
office. The check was for copy of Order 94-3909 civil Term. A fee of
$20.00 is charged for checks returned for insufficient funds. Please
send cash or money oroer $20.50 to our office upon return mail or other
action may be taken.
Sincer.ely,
.f~..... r W.JJJe..v, r'
Lawrence E. Welker
Prothonotary
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LEE W. PAGE ".....n... .'-,~LI - " dd"'l1,~,
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IIN TilE COURT m' COMMON PLEAS
ICVMRERI.ANIl, PENNSYLVANIA
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I CIVil, ACTION, CUSTODY
I
I NO. 94,3909
I
VS
HERRA ANN PAGE
TO TilE 1l0NORABLE ,IlIDGES OF SAID (,OlIRTI
CERTIFICA n: OF SERVICE
1 hereby certifiy that 011 March 6. 1999 1 served the foreaolna document upon
the persons and In the manner indicated below. which service satilfies the requirements of
Pe.R.Civ.P.4031
Service by certified malltol
Debra Ann Page
3401 Ritner IfIghway
Newville, PA 17241
./t~c{
Gall F. Guida-
Guida I.aw Offices
503 North Front Street
lIarrllburll. PA 17101
717,236,6440
Deledl April 9, 1999
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APR 1 :1 1999
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VS
IN THE COURT OF COMMON PI.EAS
CUMBERLAND, PENNSYLVANIA
CIVIL ACTION. CUSTODY
I.EE PAGE.
DEBRA ANN PAGE
NO. 94-3909
ORDER OF COURT
ANP NOW, thll /,(da)' or /y"J ,t999, AFfER HEARING, IT IS
HEREBV ORDEREP AND DECREED THAT the Stipulation For Child CUltod)'llgned b)'the
plrtlel on April 7, 1999 will rePlle~ the pre\'lool order dated on Feblllll")' 24, 1997
BV THE COURTI
,1/4-
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Dlltribullonl
GAIL F. GUIDA, EQUlRE, S03 NORTH FRONT STREET, HARRISBURG, PA 17101 (j' .)'7....~~~(
Pebra Ann Page. 3401 R1l1ner IfIghluy, NCI\\'lIIc, PA 17241 - IJ"" I IV"
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P1.AINTlFF
I IN THE COURT OF COMMUN I'U:AS
: CUMBERLAND COUNTY, I'ENNllYLVANIA
VS
.
.
: CIVIL ACTION - LAW
DEBRA ANN MGE,
DEFlNDANT
I CUSTODY
I
I NO. 94-J9Il'J
I
STIPULATION FOR CHILD CUS'I'ODY
t. Both putlft IgrH th.t thl. Stlpulltlon i. to be trelted IS a coun
order.
2. The p.nia shall hive .hlred 1'111 custody of tht subject minor
children, Kunis Lee Plge, d.o.b lo-lZ-82, Ind RebecCl Mae PI.t, d.o.b. 11-
31-14. Th,y .h.11 consuU with ,arh other reI.tive to IlIlmponlnt decision
concerning the lubjf('t minor children, including .uch mall,n ., h.IUh,
educltion, and rdl.ion.
3. Primlry physlClI custody of Rebrc:cI Mae P..e sh.1I be with the
Fltber, Lee P.g,.
4. Primlry physlClI custody of Kunls l,ft P.ge shill be wllh the
Mother, Debra Ann Page.
S. ....ther Ihlll h.ve liberal villtltion with Kunis Lee PI.e Ind Mother
shill hive liberal visltltion wllh Rebecc. Mae P.ge.
6. Tr.nsportatlon:
A. Mother sh.1I be raponslble for trlnspon.tlon durin. her
villls with child, Rebrc:c. Mae P.gt.
B. F.ther shall be mponllble for transport.tion durin. his villll
wllh child, Kurtis Lee P.ge.
7. Elch pi rent shill be entitled to re'lon.ble tdephone contlct with
the child when he or Ihe II In the cUIlody of the other pi rent.
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8. Either plrty mlY drvllte from the custody arhedule, upon
llreement of both partla.
9. Each party leknowledle. lhat he or she his rfCelved independent
lepladvlce from counad of hi. or her Idectlon, Ind thlt eacb fully undentand. the
facti and hiS been fully lnfonnrd as 10 his or her Iqal rights Ind obllgltlons, Ind
eacb plrty ac:knowlrdga and accepts thll Agrrementll, In the clrcumltlnea, fair
and equitable. and tblt it is briug entered Into freely and voluntlrily. Iner hiving
rfCelved luch advice Ind with such knowledle, Ind thlt the necullon of this
Alreement Is not the mult of Iny durell or undue InRueuce, Ind thltit I. not the
mull of 10Y Improp,r or lIIegll llIreement or Igreemenll.
Date: ---Y - 11 ~ C{9'
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MAY 1 3 1999 \
,I
IllalntllT
IN TIlE COURT OF COMMON Pl.EAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL ACTION .l.A W
NO. 94.39()9 CIVIL
IN CUSTODY
LEE PAOE.
v
DEBItA ANN (lAGE.
Defendant
Qll!ftI..QRI!Ii
.,}
AND NOW, this ~ day of May, 1999, the Conciliator being advised thntthe parties have
!'Cached 11I1 agreement, the Conciliator relinquishes Jurisdiction.
BY THE COURT,
(<J
Hubert X, Gilroy, E
Custody Conciliator