HomeMy WebLinkAbout94-06757
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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
, .
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