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Home My WebLink About94-05554 ~f .r - :3 . '7 -+J .~ ~ 3 c::- $ f! J '":]- \() \() \() 0: <::' " " r: . " r~J ,) , / , IN THI COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA DIANA L. WINGERT, PLAINTIFF CIVIL ACTION - LAW v. NO. 94- s~Si CIVIL TERM RONALD L. WINGERT, DEFENDANT IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOS~ THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN AT ONCE. IF YOU OR TELEPHONE THE GET LEGAL HELP. ~~ -~+ fYlJ..v.- .$J1w Avp~ - 'S4~.# Court Administrator Cumberland County Courthouse I Courthouse Square Carlisle, Pennsylvania 17013 Phone (717) 240-6200 IN THE COURT OF COMMON PLEAS FOR CUMBBRLAND COUNTY. PENNSYLVANIA DIANA L. WINGERT. PLAINTIFF CIVIL ACTION - LAW v. NO. 94- CIVIL TERM RONALD L. WINGERT. DEFENDANT IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF DIVORCE CODE 1. Plaintiff is Diana L. Wingert, who currently resides at 154 Bullshead Road, Newville, Pennsylvania, since July 1994. 2. Defendant is Ronald L. Wingert, who currently resides at 3690 Spring Road, Carlisle. Pennsylvania, since 1989. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on December 13, 1986 in Newville, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is and that Plaintiff may have the right to request that require the parties to participate in counseling. available the court 8. Neither Plaintiff nor Defendant is in the naval service of the United States or its allies provisions of the Soldiers' & Sailors' Civil Relief Congress of 1940 and its amendments. military or within the Act of the 9. Plaintiff requests the court to enter a decree of divorce. .. I verify that the statements made in this Complaint are true and correct. I underatand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: 5. (lL _'J~. leVI"\ \.\li. f\ W'l.C". ~ \. .--, . >r1.~'\ ~ Diana L. Wingert, Plaintiff Richard L. Webber, J Attorney for Plaintiff 11 West Big Spring Avenue P.O. Box 40 Newville, PA 17241 (717) 776-6566 )' , ~ . ~ l ~ ,..... ~ "'-..J '\" 'i- ~ ~ ~ \v, l't'\ en >. . .~ >- ... :z:: " . ~~ .__ 00 ~ a.- ..I' '." en ~ ~ 0 . ... " , , e~ ~ ~-:r ~ -;.. 1'-'-' ~ %, ~ , ~~ ,.... OL.-\ ~ <>- - ..... .., ~ " V1 ,. ....... ~ " --p? p c; -;:;<, '., " IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA DIANA L. WINGERT, PETITIONER CIVIL ACTION - LAW V. NO. 94- 5SSf CIVIL TERM RONALD L. WINGERT, RESPONDENT CUSTODY ORDER OF COURT NOW. ..0+,1~v~/\..... ~~, 1994, the within St1pulation and Agr ement, it follows: upon consideration of is hereby ORDERED as 1. Petitioner and Respondent shall share iegal custody of their .inor children. JESSE WINGERT and MIRANDA WINGERT and pursuant to this grant of shared legal custody, each parent shall have equal access to all pertihent information and reports that may be generated by medical, educational, psychological and other professionals who may work with their children. Each parent shall discuss major decisions effecting the children's well being in the areas of medical, educational, emotional, spiritual, social, and material needs with the opposite parent. 2. Petitioner shall exercise primary residential custody of said minor children. 3. Respondent shall exercise partial custody as csn be agreed by the parties. Respondent shall provide 72 hours notice prior to exercising visitation. Petitioner shall not unreasonably withhold her consent to visitation, as the purpose of this Agreement is to allow each party to maintain strong and meaningful relationships with the children. 4. On holidays, the parties shall exercise shared physical custody of the child as can be mutually agreed. 5. Such other exercises of partial custody may be scheduled hereafter as the parties may agree upon with due deference and respect to the child's interest, schedule and ultimate welfare. 6. Neither party shall do anything which may estrange children from the other parent, or injure the opinion of children as to the other parent or which may hamper the free natural development of the children's love or respect for other parent. the the and the ''B CO"",, , - Ci cr-! f-, cfl/ J. ... [ SfP 30 IZ 112 .H t9~ ~ !. . ,'L;~ ""!' lftl ~I'; '>1' 1': ;,-j'- j' '/,~n.\ " DIANA L. WINGERT. PETITIONER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA v. : 94- 5-fTi CIVIL TERM RONALD L. WINGERT, RESPONDENT CUSTODY PETITION FOR ENTRY OF AGREEMENT AND NOW come the through her attorney, Petition pursuant to following: Petitioner, DIANA L. Richard L. Webber, Jr., Pa.R.C.P. No. 1915.7, WINGERT, by and files averring and this the 1. Petitioner is DIANA L. WINGERT, who resides in Cumberland County, Pennsylvania, at 154 Bullshcad Road, Newville. 2. Respondent is RONALD L. WINGERT, who resides in Cumberland County, Pennsylvania, at 3690 Spring Road, Carlisle. 3. The Petitioner and Respondent are natural parents of JESSE WINGERT, born November 2, 1986 and MIRANDA WINGERT, born May 5, 1991. 4. On or about September 23, 1994, the parties entered into an Agreement regarding custody of the child. Said Agreement is attached hereto and incorporated by reference herein. 5. The best interest of the child would be aerved by the entry of an Order of Court reflecting the terms of the Agreement. WHEREFORE, Petitioner requests your Honorable Court to approve the attached Agreement and enter it as an Order of Court. Respectfully submitted, Dated: ~plt:.... ty. " J. 7 .I "'r, "/ J tdd~!ij Richard L. Webber, Jr. Attorney for Petitioner 11 West Big Spring Avenue P.O. Box 40 Newville, PA 17241-0040 (717) 776-6566 IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA DIANA L. WINGERT, PETITIONER CIVIL ACTION - LAW V. NO. 94- CIVIL TERM RONALD L. WINGERT, RESPONDENT CUSTODY THIS STIPULATION AND AGREEMENT is made this 11";/ day of September, 1994, by and between DIANA L. WINGERT, of 164 Bullshead Road, Newville, Cumberland County, Pennsylvania, hereinafter referred to as "Petitioner," and RONALD L. WINGERT, of 3690 Spring Road, Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as "Respondent." 1. Petitioner and Respondent are the natural parents of the following children: ~ Date of Birth JESSE WINGERT MIRANDA WINGERT November 2, 1986 May 5, 1991 2. Petitioner and Respondent were married on December 13, 1986, at Newville, Cumberland County, Pennsylvania, and separated on or about July 24, 1994. 3. With the exception of this action, neither party has participated as a party in other litigation concerning the custody of the child in this or any other court. 4. None of the parties has information proceeding concerning the children pending in a outside this Commonwealth. of a custody court within or 5. None of the parties knows of any person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 6. During the resided with the addresses: past five (51 years, following persons and the at ch ildren have the follow ing Ronald L. Wingert and Diana L. Wingert ADDRESS ~ 3690 Spring Road 1989 - July 24, 1994 Carliyle, PA 17013 ~ Diana L. Wingert 154 Bull.head Road July 1994 to pre.ent Newville, PA 17241 7. The pa~ties have reached an agreement with the custody of their minor children and desire to incorporate their agreement to an order of court. respect to reduce and 8. The parties further agree that, in procuring thia Agreement, there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. NOW, THEREFORE, the parties intend to be legally bound and waiving their right to be present when thia Agreement and Order are presented and executed, hereby stipulate and agree that the Court may enter the following Order of Court in the above captioned cas~: ORDER OF COURT ~w, consideration of the it is hereby ordered , 1994, upon within Stipulation and Agreement, as follows: 1. Petitioner and Respondent shall share legal custody of their minor children, JESSE WINGERT and MIRANDA WINGERT and pursuant to this grant of shared legal custody, each parent shall have equal access to all pertinent information and reports that may be generated by medical. educational, psychological and other professionals who may work with their children. Each parent shall discuss major decisions effecting the children's well being in the areas of medical, educational, emotional, spiritual, social, and material needs with the opposite parent. 2. Petitioner shall exercise primary residential custody of said minor children. 3. Respondent shall exercise partial custody as can be agreed by the parties. Respondent shsll provide 72 hours notice prior to exercising visitation. Petitioner shall not unreasonably withhold her cons~nt to visitation, as the purpose of this Agreement is to allow each party to maintain strong and meaningful relationships with the children. 4. On holidays, the parties shall exercise shared t ? ( " , physical custody of the child as can be mutually a,reed. 5. Such other exercises of partial custody may be scheduled hereafter as the parties may agree upon with due deference and respect to the child'a interest, schedule and ultimate welfare. 6. Neither party shall do anything which may estrange the children from the other parent, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children's love or respect for the other parent. By the Court, J. IN WITNESS WHEREOF, the parties hereto, intendin. to be legally bound hereby, do execute this Stipulation and Agreement. WITNESS: a1J/1.vJ!i ~t e, (~W~ I verify that the statements made in this Stipulation are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa.C.S.A. Section 4904 rel&tin. to unsworn falsification to authorities. Date: ~'0 , a~ C\4 ~\l\fY\. '-n \\J.or~~J DIANA L. WINGERT I verify that the statements made in this Stipulation are true and correct. I understand that false state.ents herein are subject to the penalties of 18 Pa.C.S.A. Section 4904 relatin, to unsworn falsification to authorities. Date: }}/z .$/9.9' / IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY. PENNSYLVANIA DIANA L. WINGERT. PLAINTU'F CIVIL ACTION - LAW V. RONALD L. WINGERT. DEFENDANT NO. 94-5554 CIVIL TERM IN DIVORCE PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please discontinue the above-captioned matter. ,/2JA~ Richard L. Webber. Jr. Attorney for Plaintiff 366 Oreen Spring Road P.O. Box 40 Newville. PA 17241-0040 Phone (7171 776-6566