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IIAltHISIIl1JHi. 1'1 "sYI \",':\1'\ 1711I1
In 1'1'1111\"111171 ~11.1l1l1l'
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NOV 17 199tU./
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JENNIFER WINTERS, I IN THE COURT OF COMMON PLEAS
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
I 0..UiI 71.-
v. I NO. 'N. (, '113
I
JODY DEAN WINTERS, CIVIL AC'l'ION - LAW
Defendant CflILD CUSTODY
NOT ICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend
against the claims set forth in the following pages, you must
take action within twenty (20) days after this Complaint and
Notice are served, by entering a written appearance peroonally or
by attorney and filing in writing with the Court your defenses or
objections to the claims set forth against you. You are warned
that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further
notice for any money claimed in the in the Complaint or for any
other claim or relief requested by the Plaintiff. You may lose
money or property, or other rights important to you, including
child custody, or child visitation.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER
AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE TilE
OFFICE SET FORTH BELOW TO FIND OUT WHERE
YOU CAN GET LEGAL HEI,P.
Court Administrator
Cumberland County Courthouse
Third Floor
CarliSle, PA 17013
(717) 240-6200
6. The minor child has resided at the following
addresscn, in the custody of the following individuals I
a) From the oirth until September, 1991 the
subject child resided with Plaintiff and maternal grandparents at
4422 pinewood Court, Harrisburg, Dauphin County, Pennsylvania.
bl From September, 1991 until September, 1992
the subject child resided with Plaintiff and Defendant at 6-B
Pennsylvania Avenue, Camp Hill, Cumberland County, Pennsylvania.
c) From September, 1992 until October 11, 1994-
the subject child resided with Plaintiff and Defendant at 1919
Princeton Avenue, Camp Hill, Cumberland County, Pennsylvania.
d) From October 11, 1994 until present the
subject minor child resides with Plaintiff only at 1919 Princeton
Avenue, Camp Hill, Cumberland County, Pennsylvania.
7. There have been no prior actiollE' fll[ "111'1'0'1'1' of the
subject minor child in this or any other jurisdiction.
8. The Plaintiff is not aware of the existence of any
other individuals who have any type of claim whatsoever regarding
the custody of the subject minor child.
- .
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MARK THOMAS SILUKER
AlTORNEY AT LAW
Z04 ST A TB STREBT
HAlUUSBURO. PBNNSYJ.VANIA 17101
TBLEPHONB (717) 1l1-llxlO
WI DO HI"IIV ""TII'V.. THAT
THI WITHIN II A QUI ANu CO'"
"lev COI'V 01' TNI O"'GINAL
PILlD IN TH" ACI'!'ION. .
IV
2199~
ATTO"NI'"
MAR
~
JENNIFER WINTERS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-6493 CIVIL TERM
v.
JODY DEAN WINTERS,
Defendant
CIVIL ACTION - LAW
CHILD CUSTODY
QBDE~F COURT
AND NOW, this ~ day of
1995, the parties having reached agreement
matter, as per the terms of the attached Stipulation, it is HEREBY
ORDERED AND DECREED as follows:
1. Plaintiff Jennifer Winters shall have primary legal
and physical custody of the subject minor child, Jared C. Winters,
born February 12, 1991.
2. Defendant Jody Dean Winters shall be entitled to
partial periods of physical custody, for purposss of visitation,
consisting of:
a. Father shall be entitled to every other
weekend, shared hOlidays, two (2) non-consecutive weeks during
the summer vacation, and other times to be agreed upon between
the parties.
BY THE COU
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