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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
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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
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SEP 21
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Ii 3. This order is intended to provide tor the tether's telllporary or partial
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II custody schedule with tbe child on only a teMporary bauls and the parties are
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: 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
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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
.
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