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HomeMy WebLinkAbout94-03939 :] ~ . -ft - ...fJ o C ~ t '-- ~ { I 0-. r{)i CJI (Y)I I &) ./ 01 ZI I * O~Y\ M. L IGwb I Plaint1ff V yv, "r/'CIf I T Y,'fib~efendant ,IN THE COURT OF COMMON PLEAS OF 'CUMBERLAND COUNTY, PENNSYLVANIA , 'CIVIL ACTION - LAW , :NO. q L/ CIVIL "'?(/"3', l!J ,CUSTODY/VISITATION * I ORDER OF COURT -l\,,\ \/ ( ,>' J f./r I AND NOW, this J (datl3) , 1 ( , upon consideration of the attached complaint, it is hereby directed tPat the partiesjanq their respective counsel appear before S, '" "I" I l, Ant r,'} (~ , , the concili~tor, at Q <,- fI( I:)~l\ )~, /r"hlyfll' on the ~day of Sl-i" . , 19 '1\1, at 'i P r'1 M., for a Prehearing custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard 'by the court, and to enter into a temporary order. Either party may bring the child who is the subject of this custody action to the conference, but the child/children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: 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. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, FOURTH FLOOR CARLISLE PA 17013 (717) 240-6200 . . , plaintiff IN TilE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO ,(1" ~ 1 Yt ( I ( ~; l ) ( ^ 11'- CIVIL ACTION - LAW CUSTODY vs. MICHAEL T. KNOBL, Defendant ORDBR OF COURT You, Michael T. Knobl, Defendant, have been susd in court to obtain custody, partial custody or visitation of ths child I Brik Michael Knobl. You are ord~-to-appear1:n"person-at'eumberlandCouiity Courthouse on 1994, at .m., for a conciliation or mediation conference. a pretrial conference. a hearing before the court. If you fail to appear as provided by this order, an order for custody, partial custody or visitation may be entered against you or the court may issue a warrant for your arrest. YOU SHOULD TAKE ~HIS 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 CUMBERLAND COUNTY COURTHOUSE, 4TII FLOOR 1 COURTHOUSE SQUARE CARLISLE, PA 17013-3387 (717) 240-6200 By The Court, DATED I BYI J. DONNA L. KNOBL, I IN THE COURT OF COMMON PLEAS Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I vs. I NO. S 1994 I MICHAEL T. KNOBL, I CIVIL ACTION - CUSTODY Defendant I COMPLAINT FOR CUSTODY 1. Plaintiff Donna L. Knobl is an adult individual residing at 1028 Hemlock Lane, Enola, Cumberland County, Pennsylvania. 2. Defendant Michael T, Knobl is an adult individual residing at 306 Shady Lane, Apt. B, Enola, Cumberland County, Pennsylvania. 3. Plaintiff sseks custody of the following childl .tffil:m PRESENT ADDRESS 1028 Hemlock Lane Enola, PA 17025 The child was not born out of wedlock. Mm. 2 Erik Michael Knobl The child is presently in the custody of Plaintiff who resides at 1028 Hemlock Lane, Enola, Cumberland County, Pennsylvania. Since the subject child's birth, he has resided with the following persons at the following addresses I PERSON ADDRESS J2MB. Donna & Michael 916 Green St. Apt. 3 2/92 - Knobl Harrisburg, PA 8/92 Donna & Michael 3549 N. 3rd st. 9/92 - Knobl Harrisburg, PA 10/92 Donna Knobl 1028 Hemlock Lane 11/92 - Enola, PA Present The mother of the child, Plaintiff Donna Knobl currently residing at 1028 Hemlock Lane, Enola, cumberland County, Pennsylvania. She is married to Defendant. The father of the child, Defendant Michael Knobl is currently residing at 3549 N. 3rd Street, Harrisburg, Dauphin County, Pennsylvania. He is married to Plaintiff. 4. The relationship of Plaintiff to the child is that of mother. The Plaintiff currently resides with the following persons I JWm Bonnis L. Farrell Eugene P. Farrell RELATIONSHIP Mother Step-father 5. The relationship of Defendant to the child is that of father. The Defendant currently resides with the following persons I lffiMg Katrina Lynn Martin RELATIONSHIP Half-sister 6. 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. Plaintiff has no information of a custody proceeding concerning the child psnding in a court of this Commonwsalth. 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 said child. 7. The best interest and psrmanent welfare of the said child will be served by granting the relief requested bscause it was memorialized in the already existing relationship between Plaintiff the subject minor child and provide him with a stable nurturing environment. 8. Each parent whoee parental rights to the child have not been terminated and the psrson who have phyeical custody of the child have been namsd as parties to this action. WHEREFORE, Plaintiff requests the Court to grant oustody of the child. DATED I 7/13/94 Resp,sctfully Submitted. <" " Q J) ( HER HEL LOCK, ESQUIRE ATTORNEY FOR PLAINTIFF 3207 North Front Street Harrisburg, PA 17110 (717) 238-6661 (fl) JUl It/ 2 10 PH '9~ 'I f IL' Of I,'t ;:1('1' ':.'f1Y (iI"; _! iit _ (11' 'OY h.dli"Ur,'; :, 4oJ7l 5- ~6 sy CI- 4~ltf '" / 3toft; f11J d - ~ 3.3 , t l .,._._--,." " . ' . f . " " " , , , - \I.. , ~ . . ~ ..~ - , . ,. I ] , S E P 2 0 1994 I JL . DONNA L. KNOBL, ) IN TIIB COURT OF COMMON I'!aintift ) PLBAS OF CUHBBRLAND ) COUNTY, PBNNBYLVANIA VS. ) ) NO. 94"3939 CIVIL TBRH HICIIABL T. KNOBL, ) Defendant ) CUBTODY ODBI AKD NOlI, this z.l~i day of $(' p~d , 1994, upon receipt of the conciliator's report, it appearing that the parties have agreed upon the terlls and provisions of this order IIhich lias dictated in lheir presence and approvcd by theil, we hereby lIake the follolling order: 1. Legal cuslody and primary physical custody of lhe minor child, Brik Hichael Knobl, born May 10, 1992, is hereby allarded to and confirmed in his Mother, the Plaintiff, Donna L. Knobl. 3. Pcnding furthcr order of this court, the fathcr of lhe child, the Defendant, . Michael T. Knobl, shall have the follolling periods of temporary or partial custody II ith the chil d : A. Every other Sunday, commencin9 on Septcmber 18, 1994, from 1:00 p.m. until 5:00 p.m. D. Such othcr times as the parties may agree. Until the parties llIutually agree otherllise, the molher will accompany the (ather and the child so that the child is comfortable lIith the father during those sessions. Accordingly, the parties may vary the times and dates of these sossiol\s, but they may do 80 only by mutual consent. I i,j! SEP 21 3 33 I'M '9~ i,i. 'i'-, ,It~ ,d' I- 'A i"I',t )!..' 'HJhl1.\hY i"li\llf\'i '\;41,[~q~~h rY , I "h:,', ,,' ,,'C; :P' ilj' J.'i, Pi !i III 'i i Hi,;; '. ,11'; I.' . Ii I; i!- ti:. "i.;lid Ii ilk '''q'fid 11' I 'j, f' l' i,'l i!' lo' , , i ~ ,) , , I ,'.-1 11,.1 '-~I,H!q ; \ :I~l,:,f It} \; "'of ", ;' . _ i ~ I ;!f I' '~:if',' t l1A i:l-!f 'H:' );,i~ ;j I PI !Ut.tl-Tj !;i\Lf',,' 1,,1' 1'( '. i'li 1;-, t i j:; ~ ~:t :>" ~; .i Ii 'inL I ,jJ Hi", fH,,\ dill U".';p :jt , !' ! i Iq' II ,L~' l'fli',jll. H "'j Iii I!, :"'~"II~i,11''-1 ,l:~ Pi WdlPhl' 'i" !!>"_jfl{!'l ii-; iii.F' n. I ~ i. ;. ii' .j- : HI- iH'j;:,) 'iJq 1'1' , ' .' ;; )0;' ; ~i;! I' ,. t ~j i !!.H~f H\HH,~i,,~1 Of tf'-" !;j,j> i _;1 li'-!'1 .,' ;,1 _,J\ ~ ~ j ~ 'I; P ;1. !' 1" tilt IUl H!iliH i'1;i_, flit 1'._ iqliF,'L,ltHt'l! "'1 P' l"Hi ",", f{ih ;:1 , . WI! ,,1hI J' t \~; Li Ii ~ )~ " '! ! ! h _.I;; I, , .. ,. I' I I ! i I .1 " I' II II Ii Ii 3. This order is intended to provide tor the tether's telllporary or partial il Ii II custody schedule with tbe child on only a teMporary bauls and the parties are 'I !i , : encouraged to IIIOdity the terllls of thin order, to give the tether lIIore tiMe lIith the child in the near future. In tho event lhat the parties cannot agree upon any (urther IIIOdification of this order, lie lIil1 set an appropriate schedule ot teMporary or partial custody upon the request of either party. By the Court, J. lIerschel Lock, Rsquire Attorney tor Plaintiff - ~d>v. Q. (n<<~~(.-^ ''/ I u/ 'It- I _~.f, Hichael T. Knobl, pro se 3549 Nortb Tbird street lIarrisburg, PA 17110 Ria III ~ E ~ j:Q ~ p: < ~ ~ Iii z ~ ~ ~ ~ E ~ ~ ~ 2 ~ >J ~ d ~ .< 0 E ~ Ilo .... ~ 0 ro1 ~ < ~ ~ ~ II 0 . ): ,.. ~ ~ . . i t f .t . . . , . . SEP 20 188'1 I" I ' DONNA L. KNOBL, ) IN THB COURT OF COMHON Plaintiff ) PLBAB OF CUHBBRLAND ) COUNTY, PBNNSYLVANIA vs. ) ) NO. 94-3939 CIVIL TBRH HICIlABL T. KNOBL, ) Delondant ) CUSTODY JUDGE PRBVIOUBI,Y ABBIGNEDI None CONCUIATOR CONFHRIlNCH BmtlARY RllPOIf ] N ACCORDANCE WIT/I CUMBBRLAND COUNTY RULE OF CIVIL PROCEDURB 1915. 3-S lbl. the undersigned CUBtody Conciliator BublllltR the following report I 1. The pertinent inforllation concerning the child who 10 the subject ol th10 litigation is as followsl CURRENTLY IN CUSTODY OF NAME BIRTHDA1'B 10 Hay 1992 Plaintilf/Hother Erik Hlchael Knobl 2. A Conciliation Conlerence waR held on 13 SepteMber 1994 and the fallowing individualn were prescntl the I'lainllll and her attorney, /lerRchel Lock, Bsquire: the Delendant appcared without counscl. 3, The partieB appcared at the conciliation conference having discuBsed thc utter privately and with the mothcr's attorney. They were able to quickly rcach an agrccllcnt which providcd lor at least a teMpurary schcdule of the father'B contacts with the child. Thc attached order, which was dlctatcd in their IJresence and approved by both parlies, iu Intended tu get theM lhruuyh the next several IIOnths until they are cOMlortable wilh a schedule ul teMporary custody which they can then IIOdi1y as they agree. With the entry of thiB order no further actlun is necessary at this time. 19 SepteMbcr 1994 ~~ Custudy ConcIliator , DONNA L. KNOBL, ) IN TIIB COURT OF COMMON l'la1ntitf ) PLBAS OF CUMBBRLAND ) COUNTY, PBNNSYLVANIA vs. ) ) NO, 94-3939 CIVIL TERM MICIIABL T. KNOBL, ) Defendant ) CUBTODY ORDBR AND NOll, this day of , 1994, upon receipt of the conciliator's report, it appearing that the parties have agreed upon the ter.s and provisions of this order which was dictated in their presence and approved by theM, we hereby .ake the following order: 1. Legal custody and primary physical custody of the minor child, Brik Michael Knobl, born May 10, 1992, is hereby awarded to and confirmed in his mother, the Plaintiff, Donna L. Knobl. 2. Pending further order of this court, the father of the child, the Defendant, . Michael T. Knobl. shall have the following periods of temporary or partial custody wi th the child: 10. Every other Sunday, commencing on September 18, 1994, from 1:00 p.m, until 5:00 p.m. B. Such other times as the parties may agree. Until the parties mutually agree otherwise, the mother will accompany the father and the child so that the child is comfortable with the father during those sessions. Accordingly, the parties may vary the timeo and dates of these sessions, but they may do so only by mutual consent. 1 - 3. This order is intended to provide for the father I s tomporary or partial custody schedule vith the child on only a tomporary buh and the partie8 are encouraged to IIIOdi1y the terms of this order, to give tbe (ather more time \lith tbe child in the near tuture. In the event that the parties cannot agree upon any further MOdUication of tbis order, \Ie \1111 set an appropriate schedule ot temporary or partial custody upon the request ot either party, By the Court, J. Herschel Lock, Esqui re Attorney tor Plaintiff Hichael T. Knobl, pro 8e 3549 Nortb Tbird Street Harrisburg, PA 17110 . sla 2