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Home My WebLink About94-04934 I , . " il. 'I I I , i ,I , , , , , , ' 'I'j , . , c ' I '1\ ~ I, I, ~ , I, , ~ ' . I , 'i , , ~ I , , I;i \ ' , \ \, , , , \ , ) , I / . , ( " I ;'r I " ,. ., ~ ~ ~ ~ \, , , I . . I , . " , " " \' , / M '~ l) ... ~ . .~ J j i V7 ~~~ a; d"'; ... - ., :J' ~7~ , -. .. ~ ~ ~::.1 ~ th Vl ;0-' .~: > i ' ~ I 1'1 t~.1 ., ,'I ';, '. '., " , , " " '. , . . ~ "l ~ BEVERLY A. YOHN, I I Plaintiff I I v, I : KENNETH R. YOHN, : I Defendant I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSVLVANIA NO. ./ 'I, 'I 'f 1'1 Ct", I) r;'h CIVIL ACTION - CUSTODV COMPLAINT ~OR CUSTODY 1. The Plaintiff is BEVERLV A. VOHN, currently residing at 2230 Ritner Highway, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is KENNETH R. YOHN, whose last known residence was 2230 Ritner Highway, Carlisle, Cumberland county, Pennsylvania and whose employment address is 1225 South Market street, Mechanicsburg, Pennsylvania. 3. Plaintiff seeks custody of the following children: Ryan A. Vohn 2230 Ritner Highway Carlisle, Pennsylvania Age - 11 years Mathew S. Yohn 2230 Ritner Highway Carlisle, Pennsylvania Age - 9 years Kevin R. Vohn 2230 Ritner Highway Carlisle, Pennsylvania Age - 6 years Heather A. Vohn 2230 Ritner Highway Carlisle, Pennsylvania Age - 2 years The children were born during the marriage of Plaintiff and Defendant. . The children are presently in the custody of the Plaintiff, BEVERLY A. YOHN, who currently resides at 2230 Ritner Highway, Carlisle, Pennsylvania. During the past five years, the children resided with following per suns and at the following addresses I Beverly A. Vohn and Kenneth R. Vohn 319 Kerrsville Road Carlisle, Pennsylvania from 1984 to January, 1993 Beverly A. Vohn and Kenneth R. Vohn 2230 Ritner Highway Carlisle, Pennsylvania from January, 1993 to August, 1994 Beverly A. Yohn 2230 Ritner Highway CarliSle, Pennsylvania from August, 1993 to present The mother of the children is the Plaintiff, BEVERLY A. YOHN. She is presently married to the Defendant. The father of the children is the Defendant, KENNETH R. VOHN. He is presently married to the Plaintiff 4. The relationship of Plaintiff to the children is that of biological mother. The Plaintiff currently resides with the four children. 5. The relationship of Defendant to the children is that of biological father. The current residence of the Defendant is unknown; Defendant's employment address is 1225 South Market street, Mechanicsburg, Pennsylvania. 6. 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 another court. . ~ NOV 0 1199~ ~ i I BBVBIlLY A. YOHN, ) IN THB COURT OF COHMON Plaintiff ) PLBAS OP CUHBBIlLAND , ) COUNTY, PENNSYLVANIA , ) I' vs. I ) NO. 94-4934 CIVIL TBIlH 'KBNNBTH IL YOHN, ) Defendant ) CUSTODY II :' " " AND NOW, <hI. ~ ~y 0' /JW': . 1994, upon receipt of the Ii ,'conciliator's report, the parties havioq aqreed to the ter.s and provisions of this order which was dictated in their presence and approved by them and their attorneys, we I: hereby order as follows: 1. Leqal custody of the .inor children, Ryan A, Yohn. born October 17, 1982, , Matthew S. Yohn, born May 7, 198~, Kevin R. Yohn, born January 9, 1988, and Heather A. Yoho. born Dece.ber 9, 1991. shall be shared by their parents. the Plaintiff, Beverly A. Yohn, and the Defendant, Kevin R. Yohn. The .other shall have primary physical 'I custody of all four children pendinq further order of this court. I 2. Pendinq further order of this court, the father of the children, Kenneth R, ,Yohn, shall have and enjoy the followinq periods of temporary or partial custody: A. Every other weekend from 10:00 a.m, until S:OO p.m. on Saturday and fr~ 12:30 P,M, until 8:00 p,m, on Sunday. The alteroatinq weekends shall c~ence on Saturday, October 29, 1994. B. Alternatinq Mondays fr~ 5:30 p.m. until 8:00 p..., cOMlencinq on Monday, November 7, 1994, C. On Thanksqivinq Day in 1994 from 9:00 ..m, until 2:00 p.., 1 I' If II II I D. On Christmas Bve Day in 1994 froM 2:00 p,m. until 8:00 p... Tbe :' contemplate tbat, when the father has moved to another location wbere he can i,accOllOdate tbe children overnight, his time with the children will be expanded 'I I' accordingly, The parties are encouraged to agree upon those itels theMselves, as well " as any other provision for the expansion of the father's time with the children. If the parties cannot so agree, either one is free to petition the court to expand or otberwise adjust the schedule set forth herein, J. Tholas M, ~utz, Esquire Attorney for Plaintiff -, (' "f11.<L".~ ,-1w.ll.,j..i;,(, Esquire 11/-1/1'1 ' ....\ ;1), ,.,'"l -- 'L"- ~ Marcus A. Mc~night, III, Attorney for Defeodant I"~, '''-' 1 ~ . .cs; 'I::> 'W I .. ~'I .,' " ,'-.' -", " " " ;1 I,.,:.:.", :'," 'J' ......., . ~ !iii: I sla I ii i' 2 , I BBVBRLY A. YOHN, ) IN THB COURT OF COMMON Plaintiff ) PLBAS OF CUMBBRLAND ) COUNTY, PBNNBYLVANIA vs. ) ) NO. 94-4934 CIVIL TERM IKBNNETH R. YOHN, ) Defendant ) CUSTODY ,JUDGE PRBVIOUBLY ASSIGNED: None CONCIJJATOR CONF~CE BmtIAIlY RBPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), tbe undersigned Custody Conciliator submits tbe fOllowing report: 1, The pertinent informatioo concerning the children who are the SUbject of this I litigation is as folloys: I " , NAME !1IRTHDATE 17 October 1982 7 May 1985 9 January 1988 9 December 1991 CURRENTLY IN CUSTODY OF , " Ryan A. Yobn Matthew S. Yohn 'Kevin Yohn 'I i. Heather Yohn Plaintiff/Mother Plaintiff/Hother Plaintiff/Motber Plaintiff/Hotber 2. A Conciliation Conference was held on 26 October 1994 and tbe following ,individuals were present: the Plaintiff and her attorney, Thomas H. Kutz, Esquire; the " I Defendant and his attorney, Harcus A. HcKnight, III, Esquire. 3, Items resolved bJ agreement: A temporary order. 4. Issues yet to be resolved: Nothing at this time. 5. The parties separated in August of 1994 and the father has not yet made arrangements for permanent housing, As a result, he does not have the facilities he needs to have the cbildren overnight. The parties, therefore, agreed upon a temporary order givin~ the father access to the children on a regular basis, without overnight time. BBVBRLY A. YOHN, ) IN THB COURT Of COHMON Plaintiff ) PLBAS Of CUMBERLAND ) COUNTY, PENNSYLVANIA vs. ) ) NO. 94-4934 CIVIL TBRM KENNETH R. YOHN, ) Defendant ) CUSTODY ORDBR AND NOW, this day of , 1994, upon receipt of the j,conclliator's report, the parties having agreed to the terms and provisions of this order which was dictated in their presence and approved by them and their attorneys, we hereby order as follows: 1. Legal custody of the minor children, Ryan A, Yohn, born October 17, 1982, ,~Hatthew 8. Yohn, born Hay 7, 1985. Kevin R. Yohn, born January 9, 1988, and Heather A. Yohn, born December 9, 1991. shall be shared by their parents, the Plaintiff, Beverly A. Yohn, and the Defendant. Kevin R. Yohn. The mother shall have primary physical custody of all four children pending further order of this court. 2. Pending further order of this court, the father of the children, Kenneth R. Yohn, shall have and enjoy the folJ.owing periods of temporary or partial custody: A. Every other weekend from 10:00 a.m. until 8:00 p.m. on Saturday and from 12:30 p.m. until 8:00 p,m, on Sunday. The alternating weekends shall co..ence on Saturday, October 29, 1994. 8. Alternating Hondays from 5:30 p,m. until 8:00 p,m.. commencing on Honday, November 7, 1994. C. On Thanksgiving Day in 1994 from 9:00 a.m, until 2:00 p.m. 1 BEVElRLY A. YOHN, I IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSVLVANIA plaintiff I I v. I NO. 94-4934 CIVIL TERM I KENNETH R. YOHN, : I Defendant I CIVIL ACTION - CUSTODV ACCIPTlUICI O. SlaVICI I hereby accept service of the custody complaint and Order dated September 8th, 1994! the same being filed to the above captioned court number. Datel ~pr 1.2. /T Y'I k~I"h~zt /, 'It-!v., Kennet R. Yohn I' e; ," ~ .. ., :1. ~ n .:, u , ,." .. .;'] in , . " <'-\ " /..:.-, ''I Jf '.' ".1 ., , , 'I, "