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HomeMy WebLinkAbout94-06757 ~ .~ . -7 {; l; ~ I- JI I , j 1 ('. ; l() i ; ~ I ---- -jJ j -1" ( -r r 0 .... d i1 ~ '7i "R c.J -a. III '--" 6'; ;,-.- G? G I,) 0 () 0 cr - ., Ii) 0 to ':1"= ... r; <l 60 \6 L....~ ',.",,- . , - U.;x.:....- \J) It) <.J I() 6Q 0 ('() '11 .;..........0-0: .... .--t :h.l:.:"J" r- OO D ~ \;'! .~...... , (Y1 - -.... - -.... . "I '9 d.~" " ~ rn " : ~ "1 ~ '" ", ~ ... , ~ ' C' ;; Q I ~ ... ! I 8 ~~!~~ ~'" ffi~ ~~~ d d ~ Q~6l1.f: i ~ ~~~~~ ~I ~ i" :s t.:)l1.~~O . ~ ~~iE III . ~ ~ Q I > ~ ~ ~~ rIJ , . . ~. r SAlOIS, GUIDO, SnUFF & MASLAND 26 w, utah S.ree. Carll,t., PA " CYNTHIA M. FISH, Plaintiff IN THE COURT OF COMMON PLEAS OF C~MBERLAND COUNTY, PENNSYLVANIA v. 94- CIVIL TERM JEREMY B. FISH, Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(01 OR 3301(dl OF THE DIVORCE CODE 1. Plaintiff is Cynthia M. Fieh, who currently resides at 5C Richland Avenue, Apt. #209, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Jeremy B. Fish, who currently resides at pennswoods Apartments, 5301-C Manayunk Road, Harrisburg, Dauphin County, Pennsylvania 17109. 3. Plaintiff and Oefendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on March 28, 1992, in Greenville, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce. SAlDIS, GUIDO, SHUFF & MASLAND 26 W. HiSh Street c.rlillc, PA . CYNTHIA M. FISH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 94- CIVIL TERM JEREMY B. FISH, Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(0) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Cynthia M. Fish, who currently resides at 5C Richland Avenue, A[Dt. #209, Camp Hill, C.umberland County, Pennsylvania 17011. 2. Defsndant is Jeremy B. Fish, who currently resides at pennswoods Apartments, 5301-C Manayunk Road, Harrisburg, Dauphin County, Pennsylvania 17109. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on March 28, 1992, in Greenville, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce. , ~ FEB 1 0 \9911r-J CYNTHIA M. FISH, I IN TilE COURT OF COHMON Plaintiff I PLEAS OF CUMBERLAND I COUNTY, PENNSYLVANIA vs. I I NO. 94-6757 CIVIL TBRM JEREMY B. FISII, I Defendant I CUSTODY ORDBR AND NOW, rH this (5 day of r(../kl..l~/ ' 1995, upon recoillt of the that the parties have aqreod tu thu ter.. and conciliator's report, it appearing provisions of this order which was dictated in their presence and a\lproved by them and their counsel, we hereby order as follows: 1. Legal custody of the minor children, Jacob Lee Pish, born April 22, 1992, and Jessica Lynn Fish, born 10 April 1995, will be shared by their parenta, the Piaintiff, Cynthia M. Fish, and the Defendant, Jeremy B. Floh. 2. The mother of the children, Cynthia M. Pinh, In hereby nwarded prhlary phyoical custody at both children. 3. The father, Jeremy B. Fish, shall have the folluwln<J perlodo ot temporary or partial custody of the children, until further order of courtl A. Alternating weekends from Saturday at 9:00 lI.m. until Monday at 9:00 a.m., commencinl) un Saturday, February 11, 1995. The father's weekends are cundltlullod un hln lIut bnlng schnduled to work Saturday night or sunday night alld. In tho event he is ocheduled t.O work eilher ol thollo I.lmoll. he will give the mother at I , least forty-eight (4S1 hours' advance notice of that fact so that the parties call make other arrangements for the children during the time that the father is scheduled to work. B. Alternating weeks, from 10:00 a.m. on Wednesday until 9:00 a.m. on Thursday. commencing on Wednnsday. February 15. 1995. The parties may. by mutual agreement. change the days of the week or the houro of the day for each of these periods of temporary custody to accommodate each of their work ocheduleo. In the event that the father is not able to exercise any of these periodo of temporary custody because of his work schedule he will give the mother at least forty-eight (4S1 hours' advance notice of that and the parties will attempt. in good faith, to make other arrangements for him to have compensatory time with the children. 4. In addition to the above schedule. the parties will share time with the children on their birthdays, on national holidays, on their vacat.ions from work, and at such other times as the parties may agree. This order is intended by the parties to be temporary only and to recognize that, at the time this order is entered, the father is between permanent employment positions and the mother's employment situation is not final or permanent as yet either. As each of their employment situations become more regular and solid. the parties will try to agree upon the modification of this order to more properly adapt it to their work ochedules and the schedules and needo of the children. In the event that the partieo cannot agree. either of them may request further proceedingo before the conciliator or before this court at which time we will set forth a more detailed and complete order. 2 -. CYNTHIA M. FISH, I IN THE COURT OF COMMON Plaintiff I PLEAS OF CUMBBRLAND I COUNTY, PENNSYLVANIA vo. l I NO. 94-6757 CIVIL TERM JERBMY B. FISII, I Defendant I CUSTODY JUDGB PRBVIOUSLY ASSIGNED: None CONCILIATOR CONFERBNCE SUKKARY RBPORT IN ACCORDANCE WITII CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 19l5.3-S(bl, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the children who are the SUbject of thio litigation is as follows: NAME Jacob Lee Fioh Jesoica Lynn Pish BIRTHDATE CURRENTLY IN CUSTODY OF 22 April 1992 10 April 1994 Plaintiff/Mother Plaintiff/Mother 2. A Conciliation Conference was held on 9 February 1995 and the following individuals were present: the Plaintiff and her attorney, Johnna J. Deily, Esquire; t~e Defendant and his attorney, John R. Kachur, Esquire. 3. The partieD were able to reach agreement for the entry of at least a temporary order. Currently both partieo are in the process of either starting new jobS or looking for new jobs and we could not, therefore, work out the details of a long-term schedule. The attached order is intended to be temporary and to get the partieo through their current employment status until their work and living schedules become more regular. 4. With the entry of this order no further action is necessary at this time. 9 February 1995 &,~ Custody Conciliator ~ 5. Pending further order of court, the parties will share transportation equally. The details of those arrangements are left to the parties and we will not opacify a I'particular schedule for such transportation. I' I II I By the Court, J. Johooa J. Deily, Esquire Attorney for Plaintiff John R. Kachur, Bsquire Attorney for Defendant , . ;1 sla 3