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Home My WebLink About94-05258 , , " { c c1 '\ " , , -j " ~ ~ 6 ....'''- ~'i \ ) / ,/' ./ ill ! J ()O \f) (0 \.() / " , ~__l t 1 tel r ..". . ~:tl 'l Ii ~ ,. '1 ,I ..,- " d ' ' .. 'I~ rt I. "I 0 , , ) ',1 UO ""/ ::f If) r- .3 .::3 ("::J (J- II~ '" 1(1 /.1_ ;. 11- ,,, ; l,.,'l -' ~-:L '-.J rr. q ~ ~ t 0 -: w !:: a:: $ ~ < ;'j ~ c($ r. ~ f- " ~ ,< ~ < 5 ;j II: ~ ~ ;.. ~ ~ C ~ ~ ~ " I" ~ '" ~ = d I" ,< '" 0 ~ . Co ..... " ~ 0 '" i < "" ~ "" " ;.. A " 0 ~ :>: ~ r.l .-.-: .. . . . SEP 14 1994 ,}~ . . , DONALD W, CHESBRO Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, TINA C. DONNELLY Defendant CIVIL ACTION - LAW NO. 94- .I)':;{ I) ','j CIVIL TERM AND now, this ORDBR Ql .~)I" \ day of COURT <:.;. I J\ ' ,,,L. I , 19 '1'{, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before Hubert X. Gilroy, Esquire, the conciliator, at '/Iii 0,,-,( ( "''''~ / ( ,') ( tJ , I \ '1" \ ',I ('0' \, \, I PIi on the ---.!::i!!.' day of 1'11>/,,,1, " 19 '1'1 at , -' I U : 1)( I) m" for the Pre-Hearing 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 children who are the subject of this custOdy action to the conference, but the childrens' attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, BY:_ ---1/ ,~.e:'/;{ Custody Cone 1, ~ild( v t "'1 (-'1,1/1 YOU SHOULD TAKE THIS PAPER TO YOUR T.AWYER 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 HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4~H FLOOR CARLISLE, PA 17013 (717) 240-6200 " I " Sf' ZZ 8 15 AH '9~ 'I, 'II; " ,;,) Ii ! " ! " I i fltj~ Qt : II,: I d !i1~"OJ A"'r el'/~Ii' ",Mill ("lJh/,Y !'likk 'i ([ ','./114 -I", , , " ,I, I' , I " ;, I ,.1 I', '" , , " I ," I, " , , '11 ,j,1 , 'I,l' , ,I . .....'''.....'h ....j. Jw.... ~ I\'/}/~ ".', '" I' ~ , ,II ,$ ~ " ," . . . .' .. , .. . ,..., .....,.- DONALD W. CHESBRO plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERI,AND COUNTY / PENNSYLVANIA VB, CIVIL ACTION - LAW NO, 94- "j,)'j\ CIVIL TERM TINA C. DONNELLY Defendant COMPLAINT lQB CUSTODY AND NOW comes the Plaintiff, DONALD W. CHESBRO/ by his attorneys/ Andes, Vaughn & Bangs, and makes the folluwing Complaint for custody: 1. The Plaintiff is Donald W. Chesbro, an adult individual who resides at 16 North second street, wormleysburg, Cumberland county, Pennsylvania. 2. The Defendant is Tina C. Donnelly, an adult individual who resides at 617 MMS/RGLMT, PSC 10/ Box 3205/ APO AE 09130, Germany. 3. The plaintiff and Defendant were formerly husband and wife, having been divorced on 18 March 1987. 4. The Plaintiff and Defendant are the natural parents of three children: Dana Jean Chesbro, d.o.b. 2 April 1982; David William Chesbro, d.o.b. 29 July 1983; and Devin William Chesbro, d.o.b. 6 January 1985. The said minor children reside with Defendant herein. 5. Plaintiff seeKS periods of visitation with the minor children, Dana Jean Chesbro, David william Chesbro and Devin William Chesbro. 1 . 6. The children were not born out of wedlock and are presently in the custody of the Defendant. 7, To the best of Plaintiff's knowledge, during the past five years, the minor children have resided with the following persons at the fOllowing addresses: september, 1988 to December, 1988 605 Bosler Avenue Lemoyne, PA Plaintiff and Defendant December, 1988 to September, 1990 september, 1990 to August, 1993 Sumter, se Defendant and her current husband McGuire AFB New Jersey Defendant and her current husband August, 1993 to the Present Germany Defendant and her current husband 8. The mother of the children is the Defendant who resides at the address set out above. 9. The father of the children is the Plaintiff who resides at the address set out above. 10. The Defendant is the natural mother of the children. Defendant currently resides with the following person(s): the children of this custody action, her current husband and their three children. 11. The Plaintiff is the natural father of the children. Plaintiff currently resides with the following person(s): himself and his girlfriend. 12. The Plaintiff has not participated as a party or in any other way in any litigation concerning the custody of the children in this or any other court. 2 The plaintiff has no information of a custody proceeding concerning the children pending in a court of this or any other jurisdiction. Plaintiff knows of no other person not a party to this action already who has physical custody of or claims to have custody or visitation rights with the said children. 13. The best interest and permanent welfare of the children will be served by granting the relief requested by Plaintiff because the children should have regular and consistent visitation with their father. 14. Each parent whose par.ental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHBRBFORB, Donald W. Chesbro requests this Court to grant him periods of visitation with the children, Dana Jean Chesbro, David William Chesbro, and Devin William Chesbro. ANDES, VAUGHN & BANGS r--- J BYVV\,-,('~.,- MICHAEL L. BANGS Attorney for Plai J 3 v 'IN THB COURT OF COMMON PLBAS OF ,CUMBBRLAND COUNTY, PBNNSYLVANIA , 'NO. 5258 - CIVIL - 1994 , , 'CIVIL ACTION - CUSTODY DONALD W. CHBSBRO, Plaintitf TINA C. DONNELH, Defendant CONCILIATION CONJi'ERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY 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, Dana Jean Chesbro, born April 2, 1982, David William Chesbro, born July 29, 1983, and Devin William Chesbro, born January 6, 1985. 2. The Conciliator held a telephone conference call on November 2, 1994, with legal counsel for the parties. The Father, Donald W. Chesbro, was represented by Michael Bangs, Esquire, and the Mother, Tina C, Donnelly, was represented by Michael Rundle, Esquire. 3. The Mother is currently residing in Germany with her new husband. The children are 9, 11, and 12 years of age. The Father has not seen the children for four or five years. The Mother's current husband is in the military. The Father has maintained contact with the children by letters and phone calls. The Father is seeking a Custody Order whereby he will be given an opportunity to have the children for an extended period of time over the summer mont/Is. The Mother relates that the children are reluctant to go to see the Father because of the long period of time during which the Father has had no contact at all with the children. 4. The Mother is available to return to the United States in April of 1995 along with the children. The Father is in agreement that a Hearing be scheduled in April of 1995 and the Father does not desire any custody pending the April Hearing. ~ - ~ ," J' c::-J ,~.,') ~"~.J , , , rr. C ~ ~ t -: ... 0:: ~ " ~ < ~ ~ ~ ~ '/: ~ i- S ~ ,< ~ < ;:j - J; ~ ,. - ~ ~ ~ 0 " ~ . ~ - ~ 0 ~ ,of, 0: ~ WJ C ~ .. ...- ~ ~ c " 'J! < ~ ~ ~ " ,. >: " c " ~ ~ ~ -' .... '- ..--