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HomeMy WebLinkAbout94-06565 l co -:r ~ t j / ! I ~ I i ~ i J j \t) ~ ~ . ~ . STEPHANIE L. HALDERMAN, plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. STEPHEN D, HALDERMAN, Defendant. CIVIL ACTION--CUSTODY PETITION TO CONFIRM CUSTODY AND NOW, this 15th day of November 1994, comes the plaintiff, STEPHANIE L. HALDERMAN, by her attorney, Gerald S. Robinson, Esquire, and the law firm of ROBINSON & GERALDO and respectfully requests the following: 1. The Plaintiff is STEPHANIE L. HALDERMAN, an adult individual currently residing at 816 Belmont Avenue, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is STEPHEN D. HALDERMAN, an adult individual currently residing at 950 Orchard Avenue, Lot 13, Camp Hill, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following child: Cameron Isaiah Halderman, born November 12, 1992. 4. The minor child was born out of wedlock. S. The purpose of this Custody proceeding is that the mother desires to confirm custody in herself of the minor child, so as to alleviate any possible question in the mind of the Defendant as to the custody of the minor child. , 6. The Parties currently do not have a formal custody arrangement but do share physical custody of the child. Therefore, the child resides equally with his natural mother and father at the addresses listed above, and has been doing so for the duration of his life. 7. Plaintiff has not participated as a party or witness, or in another capacity in other litigation concerning the custody of the child in this or another Court. 8. 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. 9. It is in the best interest and welfare of the minor child to be placed in the custody of the mother, and custody should be confimred in the natural mother, the Plaintiff. WHEREFORE, Plaintiff requests the Court to grant her custody of the minor child. Respectfully submitted, By ~k~ Gerald S. Robinson, Esquire ROBINSON & GERALDO Attorney I.D. No. 27423 4407 North Front street Harrisburg, Pennsylvania 17110 (717) 232-8525 Attorney for Plaintiff ',~I -.' , (71(1) 28~:es25 " ROIlIrs.SON AND Gll'Hml A'ITORNW." ANU<'OUNS t ( - P.O. BOXH211. HARRISIIURG. PH "A INAt~ '\ G-'cRTII'IED TRUE AND CORRECT COPY STEPHANIE L. HALDERMAN, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, vs. NO. 94-6565 STEPHEN D. HALDERMAN, Defendant. CIVIL ACTION--CUSTODY PROOF OF SERVICE I, Gerald S. Robinson, Esquire do hereby certify that on the 23rd day of November 1994, I caused a true and correct copy of the Petition to Confirm Custody to be served upon the following person by d~positing same in the United States Mail, certified mail, restricted dulivery, return receipt requested, postage pre-paid, in Harrisburg, Pennsylvania. Proof of Service is evidenced by "Exhibit One" (attached) . Mr. Stephen D. Halderman 950 Orchard Avenue Lot 13 camp Hill, Pennsylvania 17011 Respectfully submitted, ~1. 'P/}f'. /. (J(,e.t~'" By, "- Gerald S. Robinson, Esquire ROBINS0N & GERALDO Attorney I.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110 (717) 232-8525 Attorney for Plaintiff " :.' . .,.....;:#... , ", (717) iJl~25 :... ~ ,_0. . , '. .. " ROlliNSON AND GERALDO '~1 2 19!1J CERTIFIED TRUE ArroRNEYS AND. COI1~SI;I.I.~~~I~. A' L ~ .CORRf.CT COpy Box mil, HARRI~)IJRG"~EN'Vm"IIN2 'tZ-P 1',0. ~ Plaintiff , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA c..~t.$ NO. 94-&5b-Civil STEPHANIE L. HALDERMAN, vs. STEPHEN D. HALDERMAN, Defendant. CIVIL ACTION--CUSTODY AND NON, thl. ~d'Y of the Parties, it is HEREBY ORDERED AND , 1995, upon stipulation of the terms, conditions and provisions of the December 7, 1994, Custody Consent Stipulation Agreement, attached hereto, are adopted as an order of court as if the same were set forth herein at length. BY THE COURT: " ll,.' ~ ., . Sbl HI; ~)) G l \ lI~r " ... STEPHANIE L. HALDERMAN, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, vs. NO. qt.J - (P5t, 5 - ~ I VI L STEPHEN D. HALDERMAN, Defendant. CIVIL ACTION--CUSTODY CUSTODY CONSENT STIPULATION AGREEMENT THIS AGREEMENT, made this ~ day of ~~ 1994, by and between STEPHANIE L, HALDERMAN, of Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as "Plaintiff," and STEPHEN D. HALDERMAN, of Camp Hill, Cumberland County, Pennsylvania, hereinafter referred to as "Defendant." WIT N E SSE T H: WHEREAS, Plaintiff and Defendant are the natural parents of Cameron Isaiah Halderman, a minor child born November 12, 19921,and WHEREAS, Plaintiff and Defendant desire to stipulate to an agreement relative to custody. NOW THEREFORE, Plaintiff and Defendant both intending to be legally bound hereby, stipulate and agree as follows: 1. Plaintiff and Defendant shall share legal custody of the minor child. 2. Plaintiff and Defendant shall share physical custody of the minor child as follows: - a. Plaintiff shall have custody of the minor child on Saturdays and Sundays; b. Plaintiff shall have custody of the minor child on Tuesdays from 12:30 o'clock p.m. until 3:35 o'clock p.m.; c. Plaintiff shall have custody of the minor child beginning on Thursday at 8:00 o'clock p.m. and continuing until Friday at 10:30 o'clock a.m.; and d. Defendant shall have physical custody of the child Monday through Friday with the exception of those times detailed above when the minor child is in Plaintiff's care. 3. Plaintiff and Defendant shall mutually agree upon any alterations to this custody schedule in advance of their occurrence. 4. Plaintiff and Defendant shall mutually agree upon custody arrangements for the holiday seasons and vacation periods. 5. Plaintiff and Defendant agree that each will notify the other of all medical care the minor child receives while in that parent's care. Each parent will notify the other immediately of medical emergencies which arise while the child are in that parent's care. 6. Plaintiff and Defendant realize that the minor child's well-being is paramount to any differences they might have between themselves. Therefore, neither Party shall do anything which may estrange the minor child from the other parent, or injure the opinions of the minor child as to the other parent, or which may hamper the free and natural development of the minor child's love or respect for the other parent. COUNTY OF DAUPHIN STATE OF PENNSYLVANIA ) l 55: On the ~~~ day of ~~~ 1994, before me a notary public, the unoersigned off1Cer:"personally appeared STEPHANIE D. HALDERMAN, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. In witness whereof, I hereunto set my hand and official seal. ~~a1~~ My commission expires: NotuI~11 Zoi"J TIm1 M, elm, NOlaI)' P\JJIc Hilrri.obJllj, OuuptJn County My ComrnissionF.>jiresAplI \01,1997 ,pgflOl iU'lIA ti(.IA STATE OF PENNSYLVANIA l COUNTY OF CUIYlBC~lIl"'tl ) SS: .a.t D On the 1- day of CC[m9cIl_ 1994, before me a notary public, the unoeraigned officer, personally appeared STEPHEN D. HALDERMAN, known to me (or satisfactorilv proven) to be the person whose name is subscribed to the withIn instrument and acknowledged that he executed the same for the purposes therein contained. In witness whereof, I hereunto set my hand and official seal. (1 fU.{ J ,AL-<~4 ~~ Notary PublIcI My commission expires: J/,LNC IG l"i"i 7 , I..