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Home My WebLink About94-03940 I ~ -/1 ~ I ~ \, , .. i t I t.. ~ JI ~ a--- (YJ I ~ ; "'", " \ ; , / / I f. ':::1-, : >- , <r,~~ '" 10 ; ~~'~ ,.. - i ~ !.r, t: .. :0 ~,~ l; l~iZ C) .. ! :0 . ~l '",8 iE - , -/W , ~ N') , 0 0 ~~~ CO - I 0 II) 0 \ry c:r- I.t') ...s 1, ", 0 I.r) j:5 :' . . :r ':r ~ ~ . , ~l~ , w ~ ~ ;~ ~ N N I 5 I ~ ~ II~! i w - U It ~ ~I tl ~ J ~ ; J ~ al$ ~ ~ ~ ~~!~ ~I e f ~ . ~I ~~i!i i~ l> ; gE I llil i ~ ~ ~ I-t ~ . ,.j e~dj a ~ ~ 0 ~ ~ Ill" It ~ i ~ ~~ llil I-t ".. , ,. . . "" /l . ., 1.,11I' ()//i,.<!.~ mWJN. IHWIN & !\rcKNlOJJl' il . JUL 131994 ., JUl I J q 1'; PI! · 9~ ;lit . .-' ,',Ii : H.'~ ,-, l: ;-, .;, t' \ MAEDA KAY MARTIN DULL, Petitioner : IN TIlE COURT 0Jt" COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA I CIVIL ACTION . LAW CUSTODY /VISITATION ROBIN TODD MARTIN, Respondent NO, rET.!I!QN FOR CUSTODY AND NOW, comes the Petitioner, Maeda Kay Martin Dull, by her altomeys, Irwin, Irwin & McKnIght, and presents the following Petition for Custody: 1. The Petilloner Is Maeda Kay Martin Dull, an adult Individual residing at 174 Fieldstone Drive, Carlisle, Pennsylvanla, Cumberland County, Pennsylvania 17013. 2. The Respondent Is Robin Todd Martin, an adult Individual residing at 225 Hempt Road, Mechanlcsburg, Cumberland County, Pennsylvania 17013. 3. The parties are the natural parents of Jake Isaac Martin, age 5, born March 28, 1989, and Jase Samuel Martin, age 2, born November 12, 1992. 4. Petitioner desires primary physical custody of the children and shared legal custody with periods of visit all on to Respondent as can be mutunlly arranged between the parties. 2 5. The best Interests and pcnnanent weltire of the children requires that primary physical custody of the children be with the Petltloner, Maeda Kay Dull, due to the Respondents work schedule and responsibUilles and the significant lime the Petitioner Is able to spend with the children, WHEREFORE, Petitioner, Maeda Kay Martin Dull, respectfully requests that she be awarded primary physical custody of the children as provided herein. Respectfully submilted, IRWIN, I WIN & McKNIGHT 60 Welt Pomfret Street Carlisle, Pennsylvania 17013 (717) 249.2353 Supreme Court I,D, No, 25476 Date: June 23, 1994 J ~ I, MAEDA KAY MARTIN DULL, do hereby verilY that the facts set forth In tllls Petition are true and correct. I understand that false statements herein are made subject to the penaltles of 18 Pa, C. S, Sectlon 4904, relating to unsworn falsification to authoritles. 71/~ ~M'i dd MAEDA KAY ARTIN DULL Date: June 23, 1994 lJOC"fAMILVoCUlTllol.\l11lUlOC 4 UNI O"IC., ~(.Lw., J. ~~ ..., "*'"' ,..,,,................. 111 10 WIlT 'OM''''' 1"'11' CARL-IIU. '.HHIYt.VAHIA "011'''11 "". ......... FA. tPl" .......... I'\\!" ,. . ' MAEDA KAY MARTIN DULL, Petitioner : IN TilE COURT OF COMMON PLEAS 011 : CUMBERLAND COUNTY, PENNSYLVANIA v: CIVIL ACTION. LAW 94.3940 CIVIL TERM ROBIN TODD MARTIN, Respondent CUSTODY/vISITA TION AFFIDA VIT OF SERVICE OF PETITION FOR CUSTODY COMMONWEALTH OF PENNSYLVANIA: : SS: COUNTY OF CUMBERLAND AND NOW, Marcus A, McKnight, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and allomey for the petitioner in the captioned action In custody. 2. That he servied a certified copy of the Petition for Custody upon the respondent on September 3, 1994 by certified mail, "restricted delivery" addressed to him nt 225 Hempt Road, Mechanicsburg, Pennsylvania 17055, with Return Receipt No, P 282 342 360. 3, That the said receipt for certified mail is signed and is allached hereto and made a part hereof I verify that the statements made in this affidavit are true and correct. 1 understand that false statements herein made are subject to the penalties of 18 Pa. C, S, Section 4904, relating to unsworn falsification to authorities, Date: September 8, 1994 "- . ,}j.C; I "J Stt ~ 'l. 31 f~ '\~ ~ .\1\\' Of 'h,..1I0W)\M'~ C\lI\l' ",I.l,t> to' '1i\1 I'LHh', j\'.~ld )"" t: ~; . C.,.,n". ~ - ...., , i " " , " ,- " . r --- MAEDA KAY MARTIN DULL, Petldoner v, RODIN TODD MARTIN Respondent I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION . LAW CUSTODY/vISIT A TION NO, 94.3940 CIVIL TERM ~ IRWIN, McKNIGHT & HUGHES TO: Lawrence E. Welker, Prothonotary Please reinstate the petition in the above-referenced mailer flied on July 15, 1994. October 13, 1994 BY: Marcus A, McKnight, III, Es ulre Allomey for Petitioner 60 West Pomfret Street Carlisle, PA 17013 (717) 249-2353 Supreme Court J.D,N 25476 . .. _ ._.~~, ,~..,."'........."'-O<.;""".; ."'..-. ,,-. ,..,;;,:gv,'" ,ry.".:t~."",,,"r,, r,_-,,-'~'~; OCT 13 01 cu.' Ii"~ ~ 10 PH '9~ )}1 ~u ;: I i!I;~--lAI\l ~,.1 h L' f' -., r~ i ~ ' ~'~!. __. __ ~_~,.~__",~"~_~"_,,,_..,~.,_~_,_._,.___j\ i'~, J' - 'II, . , , . ,; " . , ",':". ,~~. - 'fti',o - pN'" I , \ \ ! " -I')... () , I! j) 'li MAEDA KAY MARTIN DULL, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA . . ,/ v : NOS , 94-3940 AND 93-74 : ROBIN TODD MARTIN, : Defendant :CIVIL ACTION - CUSTODY ~ ~TO AND NOW, this~ day of . , 1994, upon consideration of the attached Custody C nciliation Report, it is ordered and directed as follows: 1. The Mother, Maeda Kay Martin Dull, and the Father, Robin Todd Martin, shall have shared legal custody of Jake I. Martin, born March 28, 1989 and Jase Samuel Martin, born November 12, 1991. 2. The parties shall also enjoy shared physical custody of both minor children. 3. Physical custody shall be handled as follows: A. Until November 28, 1994, the current Order dated June 24, 1993, shall control with respect to physical custody. B. Starting on November 28, 1994, physical custody shall be handled on a weekly schedule as follows: In the first week, the Father shall have custody from Tuesday through Wednesday, and from Thursday through Saturday morning. On the second week time frame, Father shall have custody Monday through Tuesday, and Friday through Monday morning. The Mother shall have physical custody when the children are not with the Father. The times for exchange of custody shall be arranged between the parties. 4. The parties shall also be entitled to at least one week of vacation during the summer, with the parties to give each other reasonable notice as to when they intend to exercise vacation. 5. Both parties shall use the other parent to provide extensive babysitting in the event the party has custody of the ..... ohildren but is not available to oare for the ohildren beoause of work or other oommitments. There is an understanding that when Father has coaohing or other commitments after school and he is unable to piok the ohildren up on his designated day of custody by 6130 P.M., the children will on that day remain with the Mother. 7. The parties may modify this schedule as agreed upon by the parties and as they deem appropriate in the best welfare and interest of the children. 6. BY THE COURT, CCI Marous A. MoKnight, III, Esquire - ~ ,p.'.L.l.._ Lynn 1'. MoBride, Esquire _ ".....,~ "",,-..ul. 1I1/1J,/'/'J' ~In .~ r, J :1~_ II/Ib/fit, t .11". if C f"l-:j "-~..l __ ""J J;'~ 1.1'. c:;) t-'lr~;"; -', ~~;- '. :!, f: ~ . ~ ...., MAEDA KAY MARTIN DULL, Plaintiff IIN THE COURT OF COMMON PLEAS OF ICUMBERLAND COUNTY, PENNSYLVANIA I INO. 94-3940 AND 93-74 I , 'CIVIL ACTION - CUSTODY v ROBIN TODD MARTIN, Defendant PRIOR JUDGE' JUDGE GEORGE E. HOFFER CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY CIVIL RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows, Jake I. Martin, born March 28, 1989, and Jase Samuel Martin, born November 12, 1991. 2. A Conciliation Conference was held on October 21, 1994, with the following individuals in attendance' The Mother, Maeda Kay Martin Dull, with her attorney, Marcus A. McKnight, III, Esquire, and the Father, Robin Todd Martin, with his attorney, Lynn Y. McBride, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. 1013.1 q" ~