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Home My WebLink About94-05781 ~ \. c ~ .... l.. (... o c: . 7: ~ .~ V) ~ " '\ , I i i / / / , - 00 r- l{) I i Jj I ? . ' ~ 1; ~ .,. \') c , ~ .. C I"- ,,~ 0 .... ,. ') p ~ -:';)0- ~J ) . ... ., '", " '!C . ~ Q .. ....,., '~ .. J" >- '..... L' .. " ~ , , f -:""- . . ~ - '"' = ~ . ~~ ~~~ ~ ~uB ~ i; ~ ~} ~ r.l ~~~~ ~ ~'I ~~ ; ~ ~ Q Z j ... ~ t;j~~ 1il2~~<~ S:! ..~t;;~~ ~ gliS~~~ ~...oiu,j; j f5~:i~~ ",....IX 'Ii ....~o.. ... u Q ... < rIJ . ....l > ~ . OCT 06 1994- , .. 11 'l.'~ l i 4 ~ ~ d~ ,:l, ... r~ '4 \ . . VICKIE J. SMITH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 94- "f7/1 CIVIL TERM GEORGE L, MORRISON, Defendant CIVIL ACTION - CUSTODY COKPLAI.T rOR CUSTODY 1. The Plaintiff is Vickis J. Smith, residing at 249 Cumberland Road, Camp Hill, Cumberland County, Pennsylvania 11011. 2. The Defendant is George L. Morrison, residing at 249 Cumberland Road, Camp Hill, Cumberland County, Pennsylvania 11011. 3. Plaintiff seeks custody of the following child: ~ Present Residenc~ 249 Cumberland Road Camp Hill, PA 11011 D,O.B, lO-21-91 Andrew Christian Adolphus Smith The child was born out of wedlock. The child is presently in the custody of both parties, who reside at 249 Cumberland Road, Camp Hill, Pennsylvania l1011. During the past five years, the child has resided with the following persons and at the following addresses: is: Not ap~licable. plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. The name and address of such person is: Not applicable. 7. The best interest and p~rmanent welfare of the child will be served by granting primary physical custody of the child because he has lived with the Plaintiff all of his natural life; The Plaintiff is better to provide a more financially stable environment for the child; the Defendant must seek better residence, and has yet to do so; and the Plaintiff is able to provide a more stable home life through her regular employment and hours. B. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of ths pendency of this action and the right to intervene: N/A. WHEREFORE, Plaintiff requests the court to grant her custody of the child. SAJDIS, GUIDO, SHUFF &I; MASLAND 26 w. Hip S...... CMJulc. PA Respectfully submitted, SAIDIS, Dated: 10 ~ .01_ J ,,1' 7 c. '/ ~~ ~/ , ~ Q Z :s '"' rIJ - < t;jga ~ ~~~;~ _ ~ ~Z~ !:: )("'Z'" o SOf6Sg:f; ~ ci:cuiC :s ~~~~~ ~ ~ "':x: rIJ <(a.. Q " - < rIJ " . . . v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94-5781 CIVIL TERM VICKIE J. SMITH, Plaintiff GEORGE L. MORRISON, Defendant AND NOW, ORDER j.,.... of (1~ of the attached Stipulation M thisJ,lJ day , 1995, in for Custody, IT IS consideration HEREBY ORDERED AND DIRECTED that the parties shall share joint legal custody of said child, with periods of physical custody as shared per the Stipulation. BY THE COURT: J. SAlDIS, GUIDO, SHL'FF &: MASLAND 26 w, Hip Sum Carlitlc. PA . ~:.:... '-': r,. r-...;.) f.:.:~ /,' , " -.. ~.c-; v. SAlDlS. GUIOO, SHUFF &: MASLAND 26 W HiaJI Sueel C....lilJc, PA Friday, January 27, 1995 to be with Respondent. Beginning February 3, 1995, visitation will alternate with the Respondent having February 3, 1995 and alternate weeks thereafter; (d) Weekends will alternate between the parties, which shall be considered Saturday morning at 11:00 a.m. until Sunday evening at 5:00 p.m.; the first weekend of January 7 and 8, 1995, will be with Petitioner, and alternate thereafter; (e) Each Mother's Day shall be with Petitioner; (f) Each Father's Day shall be with Respondent. (6) This schedule will run from January to June of 1995, after which time the parties are free to renegotiate a schedule. (7) It is specifically understood that the parties desire this to be a flexible schedule in all events, and said schedule may be changed upon forty-eight (48) hours notice unless there is an emergency. (8) The parties further agree that petitioner will have periods of partial custody should Respondent have other commitments. (9) The parties shall share equally any and all non- covered medical expenses. (10) The parties desire this Agreement be evidenced by an Order of Court. i WHEREFORE, the par.ties hereto request Your Honorable Court to enter an Order affixing the custody schedule between the parties as stated above. Witness c#r George L. Morrison u ( " SAlDIS, GUIDO, SHUFF ... MASUND 26 W, Ifjp S...., Carlillc.PA LA'" OPI'ICI!S SAJPIS, GVIDO, s.HU1Y . lofASLAND ~ '1/, HIGI1 STllI!8T CAlU.ISLB. PI!NNA. \101l !'I<<JNIl(71~24J-6m JAN 2 5 niBV' '~ v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94-5781 CIVIL TERM VICKIE J. SMITH, Plaintiff GEORGE L. MORRISON, Defendant AND NOW, this ~<}~;.Of I 1995, in consideration IT IS HEREBY ORDERED ^~D DIRECTED "-hut the partieD shall share joint legal custody of said child, with periods of physical custody as shared per the Stipulation. BY THE COURT: J. SAlOIS, GUIDO, SHUFF '" MASLAND 26 w. Hi&h S..... Carhtle. PA (6) The parties further agree that all other periods of physical custody will be with the Petitioner, and each Mother'S Day will be with the petitioner regardless of the corresponding visitation schedule. (7) The parties agree that each shall have one week's uninterrupted vacation each summer, upon thirty (30) days notice to the other party, (8) The parties agree that they will set forth a mutually agreed upon schedule for a shared schedule on Holidays. (9) It is specifically understood that the parties desire this to be a flexible schedule in all events, and said schedule may be changed upon forty-eight (48) hours notice unless there is an emergency. (10) The parties further agree that Petitioner will have periods of physical custody ~hould Respondent have other commitments. (11) The parties shall share equally any and all non- covered medical expenses. (12) The parties desire this Agreement be evidenced by an Order of Cou rt. SAIDIS, GUIDO, SHUFF " MASLAND 26 w, Hiah SIr<<l Cad isle. PA WHEREFORE, the parties hereto request Your Honorable Court to enter an Order affixing the custody schedule between the parties as stated above. ~ '\~ Ifi ess I '.iMf'.~ Vickie J. Smith ~P( George L. Morrison ~ <~~c~-ft' "''"> '.... ,.. '-.. -111 -;!. " ~ t J f: @ ~ N ;- .' L:~J t- t--:': 9 /': ~~! j.).~ ..J .-) reo :'t"': CJ;,: t;> ~, ...... ,') ~ '. ,~r r . . ~, I L..i N . .. . . Lf: - , (j . . , - "- l. ,,,, ;,J L' ~\ U