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I. "8 ',' I'ETRIE
CHAR ',~' I..
ATIllKN1'V ~T lAW . ,.
STfH'EI
.1~2l) nRIS_I~~~\;1 VA'NIA 17111
IlARR IS IIUllO ,~.I~~~.:_..
717-~61.IIJJ')
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d~y of the hOliday, Se~ment "B" shall begin at noon on the holiday
itse1r and shall en~ at noon on the day rOllowing the holiday. tn
1994, Father shall have Re1ment "~" ror ThRnksgivin~ ~nd
Christmas, and Mother shall ~ave Segment "nO for these hOlidays.
tn 1995, Father shall ~ave Segment "~" for Easter, and Mother
shall have Regment "n." Mother shall have Segment "h" for
Thanksgiving and Christmas or 1995 and Father shall have Segment
"D" for these holidays. The parties shall continue to alternate
the holidays in a like manner in subsequent years.
2. The children shall spend Father's Day with Father
and Hother's Day with Mother each year, rogarn1ess of tho weekend
visitation sche~ule, from 9100 ~.M, until qlOO P.M.
3. The parties shall alternate the holidays of Memorial
Day, Fourth of July, and Labor Day, with Mother having the
children for Labor Day in 19941 Father ~aving Memorial Day in
1995, etc, Visitation shall be from 9100 h.M. until 9rOO P.M.
The ho1i~ay schedule shall always supersede the weekend schedule.
If a parent's holiday immediately precedes or immediately follows
that parent's custodial weekend, then the holiday shall be
incorporated into the weekend.
4. The parties shall share custody of the children
during the children's summer vacation with each pArty ~aving
custody of the children for alternate two-week periods commencing
with Father's having the children immediately after the children's
last day of schooL.
until May, 1994, with both parants at 416 East Main Street,
Sh1remanstown, Pennsylvan1a, from May, 1994, until the present,
with Plaintiff at 41R East Main street, Sh1rnmanstown,
PennsYlvania.
The mother of tho children ia DONNA K. nONNEY, who curront1y
res1des at 418 East Main Stroet, Shiremanstown, Pennsylvania. She
ls married,
The father of tho children is J'SON ,. AONNEY, who currently
res1des at 416 Fairway Drive, Mechanicsburg, Pennsylvania. He is
married.
4. The relationship of the Plaintiff to the children is th~t
of mother. The ~laintiff currently resides with the children.
5. The relationship of the Defendant to tho children is that
of father. He currently reoides with his parents.
6. The Plaintiff has not participated as a party or witness,
or in another capacity, in other litigation concerning the custody
of the children in this or in another court.
The Plaintiff has no information of a custody proceeding
concerning the children pending in a court of this Commonwealth.
Plaintiff does not know of a person not a party to these
proceedings who has physical custody of the children or who claims
to have custody or visitation rights with respect to the children.
7. The best intorest and permanent welfare of the children
will be servod by confirming in Plaintiff custody of the children
because Plaintiff can bettor care for the children and provide a
suitable environment for the children.
2. That their father, JASON A. BONNEY, shall have temporary
physical custody of the minor childron in accordance with tho
following scheduler
a. Every other weekend from Friday evening after
Father's work until Sunday evening at 7100 P.M.
b. One evening per week (said evening to be agreed upon
by the parties) from immediately after Father's work until 9rOO
P.M.
c. The holiday schedule shall be as followsr
1. The holidays of Easter, Thanksyiving, and Christmas
shall be divided into two segments. Segment "A" shall begin at
noon on the day preceding the holiday and shall end at noon on the
day of the holidaY1 Segment "n" shall begin at noon on the holiday
itself and shall end at noon on the day following the hOliday. In
1994, Father shall have Segment "A" for Thanksgiving and
Christmas, and Mother shall have Segment "B" for these holidays.
In 1995, Father shall have Segment "A" for Baster, and Mother
shall have Segment "B." Mother shall have Segment "A" for
Thanksgiving and Christmas of 1995 and Father shall have Segment
"B" for these holidays. The parties shall continue to alternate
the holidays in a like manner in subsequent years,
2. The children shall s~end Father's Day with Father
and Mother's Day with Mother each year, regardless of the weekend
visitation schedUle, from 9100 A.M. until 9rOO P.M.
~ua ~ It :ill'n '95
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DONNA 1<. BONNEY,
Plaintiff/Respondent
v.
IN THE COURT OF COMMON PLEAS
CUMBERLANP COUNTY, PENNSYLV^NIA
NO. 94-4422
CIVIL ACTION - LAW
CUSTODY/VISITATION
JASON A. BONNEY,
Defendant/Petitioner
COMPLAINT 'OR MODIFICATION or CUSTODY
1. The Plaintiff/Respondent is DONNA K. BONNEY, an adult
individual who resides at 44 West Main Street, New Kingstown,
Cumberland County, Pennsylvania.
2. The Defendant/Petitioner is JASON A. BONNEY, an adult
individual who resides at 404 Meadow Drive, Camp Hill, Cumberland
County, Pennsylvania.
3. The Defendant/Petitioner seeks It Modi fication of the
Custody Order of the following children:
liAllm
Date of Birth
August 4, 1985
July 28, 1987
A.g,g
Desiree' Kor.rin Bonney
Ory Lee Bonney
9
7
The children are presently in the physical custody of their
Mother, who resides at the address above. The children were born
in wedlock.
4. DurJ,ng the past five years the children have lived with
the following persons at the following addreBses:
a. Desiree Korrin Bonney, and Ory Lee Bonney, both with
Mother, 44 West Main Street, New Kingstown, Pennsylvania.
page 1 0 t 6
b.
Mother and
Pennsylvania.
c. Desiree Korrin Bonney with Mother, R.D. #1
Montoursville, Pennsylvania.
Ory Lee Bonney with Father and paternal Grandfather,
416 Fairway, Mechanicsburg, Pennsylvania.
d. Desiree Korrin Bonney, and ory Lee Bonney, both with
Mother and Father, Montoursville, Pennsylvania.
e. Desiree Korrin Bonney, and ory Lee BOlmey, both with
Mother and Father, R.D, #1 Muncy, Pennsylvania.
f, Desiree Korrin Bonney, and ory Lee Bonney, both with
Mother, R.D. #1 Muncy, Pennsylvania.
5, The Mother of the children is DONNA K. BONNEY, currently
residing at 44 West Main Street, New Kingstown, Cumberland County,
Pennsylvania. Her marital status is separated.
6. The Father of the children is JASON A. BONNEY, currently
residing at 404 Meadow Drive, Camp Hill, Cumberland County,
Pennsylvania. His marital status is separated.
7. The relationship of the Plaintif f/Respondent to the
children is that of Mother. Plaintiff/Respondent currently resides
with the following persons:
Desiree I<ord.n Bonney, and ory Lee Bonney, both with
Father, 418 East Main Street, Shiremanstown,
~
Desiree' Korrin Bonney
Ory Lee Bonney
Relat.ionship
daughter
son
page 2 0 t 6
8. The relationship of the Defendant/Petitioner to the
ohildren is that of Father. Defendant/Petitioner currently resides
with the following personsl
~~ ~elationship
Bill Bonney brother
A custody Order was entered in this case on August 10, 1994,
in this Honorable Court. Attached as Exhibit "A."
Defendant/Pet1tioner has no information of the custody
proceedings of the children pending in a Court of this
Commonwealth,
Defendant/Petitioner does not know of a person not a party to
the proceedings who has physical custody of the children or claims
to have custody or visitation rights with the children.
9. The best interest and permanent welfare of the children
will be served by granting the relief requested because:
a. Defendant/Peti tioner has shared in the caretaking of
the children and has provided the children with consistent and
loving care.
b. Defendant/Petitioner is willing and able to continue
to provide proper care and supervision of the children.
c. Defendant/Petitioner can provide a stable and loving
environment to the children.
10. Each parent whose parental rights of the children have
not been terminated and the person who has physical custody of the
children have been named as parties to th\s action. There are no
page 3 0 t 6
DONNA K. BONNEY,
Pla1nt:itt
VIII.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NUMBER 1!J.-- 4 4 ) l-(tJ C()....t _J L-~
JASON A. BONNEY,
Defendant
CUSTODY
ORDER
AND NOW, this IO~day of August, 1994, upon consideration of
the within Motion, Complaint, and Stipulation, it is hereby Ordered
as follows I
1. That primary physical custody of ORY LEE BONNEY, born
JUly 26, 19R7/ and IJBSIREE I{ORRIN BONNEY, horn I\ugust 4, 1965/
shall be and ramain in their mother, DONN/\ K. BONNEY. The parties
shall share legal custody.
2. That their father, JASON 1\. BO~N~Y, shall have temporary
physical custody of the minor children ill accordance with the
rOllowing schedulel
a. Every other weekend from Friday evening after
Father's work until Sunday evening at 7100 P.M.
b. One evening per week (said evening to be agreed upon
by the parties) from immediately after Father's work until 9100
P.M.
c, The holiday schedule ahall be as fol10wsI
1. The holidays of Easter, Thanksgiving, and Christmas
shall be divided into two segments. Segment "1\" shall begin at
noon on the day preceding the holiday and shall end at noon on the
t. 1\" \,. ~ "~'
day of the holiday, Segment "B" shalL begin at noon on the holiday
itself and sholl end ot noon on the doy following the hoLiday. In
1994, Father shall have Segment "~" for Thanksgiving and
Christmas, and Mother shaLL bave Segment "0" for these bOlidays,
In 1995, Father shall have Segment "~" for Easter, and Nother
shall have Segment "0," Mother shall have Segment hh" for
Thanksgiving and Christmas of 1995 and Father shall have Segmont
"D" for these hOlidays. The parties shalL continue to alternate
the holidays in a like manner in subsequent years.
2. The children sholl spend Father's Day with Father
and Mother's Day with Nother each year, regardless of the weekend
visitation schedUle, from 9100 ~,N. until 9100 P.M.
3, The parties shall alternata the holidays of Memorial
Day, Fourth of JUly, and Labor Day, with Mother having the
children for Labor Day in 1994/ Father having Memorial Day in
1995/ etc. Visitation shall be from 9100 h,M, until 9100 P.M.
The holiday schedule shall always supersede the weekend schedule.
If a parent's holiday immediately precedes or immediatelY follows
that parent's custodial weekend, then the hoLiday ~hall be
incorporated into the weekend.
4. The parties shalL share custody of the children
during the children's summer vacation with each party having
custody of the children for alternate two-week periods commencin~
with Father's having the children immediately after the children's
last day of school.
DONNA K. nONNEY, I IN THE COURT OF COMMON PLEAS OF
Plointifr I CUMBERL~ND COUNTY, PENNSYLV~NI~
I CIVIL ~CTION - LAW
VI. I
I NUMnER
JASON A. BONNEY, I
Defendant I CUSTODY
HOTION
NOW COMES tho PLaintiff, DONN~ K. nONNEY, by her attorney,
CharlAs E, Petrie, and respectfUlly represents as followsl
1. That Plaintiff is DONN~ K. BONNEY, an adult individu~l
currently residing at 416 East Main Street, Shiremanstown, County
of Cumberland, PennsYlvania.
2. That Defendant is J~SON ~. BONNEY, who currentlY resides
at 416 Fair.way Drive, Mechanicsburg, County of Cumberland,
PennSYlvania.
3. That the parties are the natural parents of two minor
children, ORY LEE BONNEY, born JUly 20, 1967, and of DESIREE
KORRIN BONNEY, born ~ugust 4, 1985.
4, That the parties have entered into a StipUlation
concerning tho matters of cuatody and visitation with respect to
the minor children, and the said StipUlation is attached hereto.
5. That the parties desire that said StipUlation be ent~red
as an Order of Court.
until ~ay, 1994, with both parents at 418 East Main Street,
Shiremanstown, Pennsylvania/ from May, 1994, until the present,
with Plaintiff at 418 East Main street, Shirem8nstown,
PennSYlvania.
The mother of the children is DONNA K. BONNEY, who currontly
resides at 416 East Main Street, Shiremanstown, Pennsylvania. She
is married,
The father of the children is JASON A. nONNEY, who currently
resides at 416 Fairway Drive, Mechanicsburg, Pennsylvania. He is
married.
4. The relationship of the Plaintiff to the children is th~t
of mother. The Plaintiff curr.ently resi~es with the children.
5. The relationship of the Defendant to tho children is that
or father. He currently resides with his parents.
6. The Plaintiff has not participated as a party or witness,
or in another capacity, in other litigation concerning the custody
of the children in this or in another court,
The Plaintiff has no information of a custody proceeding
concerning the children pending in a court of this Commonwealth.
Plaintiff does not know of a person not a party to these
proceedings who has physical custody of the children or who claims
to have custody or visitation rights with reepect to the children.
7. The best interest and permanent welfare of the children
will be servod by confirming in Plaintiff custody of the children
becauso Plaintiff can better care for tho children and provide a
suitable environment for the children.
.
.
.
DONNh K. BONNllY, I IN THE COURT OF COMMON PLE~S OF
Plllint:l.H I CUHBERL~NO COUNTY, PENNSYLV~NII\
I CIVIL ACTtON - L'W
VB. I
I NUM13J;:R
JASON A. BONNllY, I
Defendant r CUSTODY
I:lTIPlJJ,ATION
~GRJ;:EMENT, made this 29th day of JUly, 1994, by and between
JASON A. 130NNJ;:Y, hereinafter referred to as "Father," and DONNA
K. BONNJ;:Y. hereinafter referred to as "Mother."
WITNESSETH I
WHJ;:RJ;:AS, the parties hereto are husband and wife, and Mother
is the natural mother of, and Father is the adoptive father of,
two childrenl ORY LJ;:E BONNEY, born JUly 2B, 19B7, and DESIREE
KonRIN HONNJ;:Y, born August 4, 19B5, an~
WHJ;:REAS, the parties have reached an Agreement concerning the
matters of custody,
NOW THEREFORJ;:, intending to be legally bound, and intending
that this Stipulation be entered as an Order of Court by the Court
of Common Pleas of Cumberland County, Pennsylvania, it is hereby
agreed as folloWSI
1. That primary physical custody of ORY LEE BONNEY, born
JUly 2B, 19B7, and DESIREE KORRIN HONNEY, born August 4, 19B5,
shall be and remain in their mother, DONNA K. BONNEY. The parties
shall share legal custody.
I
.
.
2. That their fathur, JASON ~. nONNEY, shall have temporary
physical oustody of thu minor children in acoordance with the
following schedulur
n. Every other weekend from Friday evening after
Father's work until Hund~y uvoning ~t 7rOO P.M.
b. One uvening pur woek (said evening to'be agreed upon
by the parties) frum immediately after Father's work until 9100
P.M.
c. Tho holiday Hchodule shall bo as followsr
1. The hulid~YH of Easter, Thanksgiving, and Christmas
Ihllll be divided into two Mooments. Sagment "A" shall begin at
noon on tho day procodillg tho holiday and shall end at noon on the
day of tho holidaYI Sogmont "nO shall begin at noon on tho holiday
iteelf and shall end ~t noon on the day following the holiday. In
1994, Father uhal1 hovo Segmnnt "A" for Thanksgiv~ng and
ChriatmaQ, and Mother u~atl havo Segment "8" for these holidays.
In 1995, Father shall havo Segment "A" for Easter, and Mother
shall havo Sogment "D." Mothar shall have Segment "A" for
Thankagiving nnd ChristmnR of 1995 and Fathor shall have Segment
"B" for thoso hOlidays. The parties shall continue to alternate
the holidays in a like mannor in subsequent years.
2. Tho childron shall spend Father's Day with Father
and Mothor's Day with Mother each year, regardless of the weekend
Visitation schodulo, from 9100 A.M. until 9rOO P.M.
,
,
.
.
3. The parties shall alternate the holidays Of Memorial
Day, Fourth of JUly, and Labor Day, with Mother having the
children for Labor Day in 19941 ~ather having Memorial Day in
1995, etc. Visitation shall be from 9100 A.M. until 9100 P.M.
The hoLiday schedule shall always sup~rsede the weekond schedule.
If a parent's holiday immediately precedes or immddiately follows
that parent's custodial weekend, then the holiday shall be
incorporated into the weekend.
4. The parties shall share custody of the children
during the children's summer vacation with oach party having
custody of the children for alternate two-week periods comme~cing
with Father's having the childron immediately after the children's
last day of schOOl.
5. Father shall have such other rights of temporary
phy~ical custody as the parties shall from time to time agree.
IN WITNESS WHEREOF, the parties have hereunto set their hands
and seals the day and year first above written.
~-L t;.~'
WITNESS
~ ~. 15 V'nrtltfr-
tfASON A. BONNEY,'
k", ;{J3Jj~7r-
nONN~ K. BONNEY
~c,~,
WITNESS