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Home My WebLink About95-01216 VI ~ cf) . -;P ~ p J --,1 -I c6j ~J lOt 0- . o <: TERESA A. STITT . IN THE COURT OF COMMON PLEAS . . CUMBERLAND COUNTY, PENNSYLVANIA . plaintiff . . . . e~-..:J 1.Lv""'- v. NO. 9ft. IJ 1(. . . RICHARD ROBERT BATES, . . . . Defendant . CIVIL ACTION - CUSTODY . ORDER 01' COURT AND NOW, this -' 6t" day of M~nh , 1995, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before-D""wl\ S. SlAnck..i b-6'"1. , the conciliator, at ~cl l.1), M<-~ i" S+. Mf-c-hl'''\'''''~ bl.1rJ on the --1..L.tb.... day of IJ {J r I I , 1995, at 11'.oo1m., for a Pre-Hearing custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older s~ (may) also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: "'-'1\ .),.iJ. <- custody Conc 1 ator 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 THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET. LEGAL HELP. OFFICE OF THE COURT AMNINISTRATOR COURTHOUSE, 4TH FLOOR ."- CARLISLE, PA 17013 TELEPHONE: (717) 240-6200 TERESA A. STITT IN THE COURT OF COMMON PLEAS . CUMBERLAND COUNTY, PENNSYLVANIA . plaintiff . . . . C,i,~(J U..-. v. NO. Qr'. I.) 1(, RICHARD ROBERT BATES, . . . . Defendant . CIVIL ACTION - CUSTODY . COMPLAINT POR CUSTODY 1. The Plaintiff is TERESA A. STITT, currently residing at 5316 Oxford CirCle, Apartment 12, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is RICHARD ROBERT BATES, currently residing at 185 South Main street, Manhiem, Pennsylvania, Lancaster County, Pennsylvania. 3. Plaintiff seeks custody of the following child: SAMANTHA STITT 5316 Oxford circle, Apartment 12 Mechanicsburg, PA 17055 date of birth: November 9, 1989 The child was born out of wedlock. The child is presently in the custody of the plaintiff, TERESA A. STITT, currently residing at 5316 Oxford circle, Apartment 12, Mechanicsburg, Cumberland County, Pennsylvania. Since the date of birth the child resided with the following persons and at the following addresses: (1) from 1989 to July, 1990, R.D. No.1, Box 151f, Newport, Pennsylvania with Plaintiff and family. (2) from July, 1990, to July, 1994 at 20 stephen Road, Camp Hill, Pennsylvania, with Plaintiff. (3) from July, 1994, to present at 5316 Oxford circle, Mechanicsburq, Pennsylvania, with Plaintiff and craiq Clouser. The mother of the child is the plaintiff, TERESA A. STITT, whose current address is 5316 Oxford Circle, Mechanicsburq, cumberland County, Pennsylvania. She is not presently married to Defendant. The father of the child is BATES, whose current address is Lancaster County, Pennsylvania. plaintiff. the Defendant, RICHARD ROBERT 185 South Main street, Manhiem, He is not presently married to 4. The relationship of Plaintiff to mother. The Plaintiff currently the child is that resides with her of bioloqical child. 5. The relationship of Defendant to father. The Defendant currently ~he child is that resides with his of bioloqical qirlfriend. 6. plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerninq the custody of the child in this or another court. VERFICATION I verify that the statements made in the attached Pleading are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.Cons.stat. sec. 4904 relating to unsworn falsification to authorities. ....,.:: <>- "d" An 6~ TERESA A. STI (';).":1 uJ ~~ VI ", ;!! fti , -- ',_,t." ~~ '). ,. <"1~ ~.., "'t1r~~ _,..., !.:''';''';': :t::O""n!"rl c......r;:-.Lt ~.I>~;J I ";';::':':-10 .-0;:;" V:nQ"'-1 .r,.-j~(o) J:f:~~~". ~~ ... ....'" -<..., ::0: ... "" = CD .... IV ~ ~ j eo <l ~ ~ ~ ...... ~ ~ '8 t ~ ~ ~ ~::: c, -C ::-1 rEHES,\ A. STiTT. PLA 1 NT I H' COUHT OF COMMUN PLEAS CUMBERLAND COUNTY PF,NNSYLVANIA v. NU. Y5-1~IH CIVIL III CHARD ROBERT BATES. DEFENDANT I'US'I'OIW IV fSf'l'A'l'fON C9UNTERCJ4\IM COMES NOW. the Defendant. hv Edward W. Harker. ESQ. and pursuant to PHCP. 1\115.(' lbl riles thls counterclaIm to Plaintiff's action: 1. Defendant. Hichard Hobert Bates. resides at 1~5 South Main Street. Manheim. Lancaster Countv. Pa. with his fiancee Alice R. McDivitt. 2. Plaintiff. Teresa A. Stitt. resides at 5~lij Oxford Circle. Apt. 12. Mechanicshllrll. Pa. with her boyfriend and Samantha Stitt. 3. Plaintiff commenced this action bv filinll a complaint for custodv on or about March 15. 1\195. Defendant has no objection to primarv custodv in favor of Plaintiff but asserts this counterclaim to secure rellularlv scheduled visitation and shared lellal custodv of his daullhter: Samantha Stitt - aile 5. DOB. ll-\l-~\I 4. Since birth the child has resided with the Plaintiff at the addresses set forth in the Complaint which p.Leadinll. to the extpnt relevant. is ineorporated herein. 5. Plaintiff is Samantha's natural mother. H. Defendant is Samantha's natural father. 7. There have been no other or prlnr proeeedinlls tor custodv or visitation rellardinll said child. H. Defendant believes that COllrt Urdered rellutar visitation Rnd shared lellal cllstodv are in Samantha Stitt's best interest as follows: a. Defendant is enllalled to be married. maintains steadv emplovment. and reSIdes with his fiancee in a stable nurturinll relationship. b. [Ipfendant hn" "IRlt,.1t wIlh Snmantha. WIth th,.. Plaintiff's e(ln~p.nt. on Hllproximntf:'lv tl O('("n~l('ln8. e. Samantha ha~ (~xllrp~~(lod ntl'petlntl nnd love for 1J~I'~ndnnt nnd nn Intel'pst In ,'elllllnr visltntlon. rt. Det'f:andnut. 1I\1I4.t trnv~l l\llPJ~OXlmHtpL\' nn~ hOllr ~nch way to visit Snmnntha. ~. In th~ past. 1J~l'pndunt hns not been provid~d information concernlnll th~ child nnd hus had no opportllnitv to purticipnte In or consult with Plaintiff on matters affectlnll the chiid's welfare. . : j' f. Uefendant Wishes to participat~ in raisinll Samnnthu to a reasonable dellree and to have the opportunitv to establish a relationship betwe~n Samantha and his mother. th~ child's paternal Ilrnndmother. WHEREFORE. De fendant respec t I'll I I v l'eclll~sts the COil rt to ord~r shar~d lellal custody and rellular visitation as t'ollows: A. Visitation overnillht on alternatinll w~~k~nds commencinll Fridav eveninll at 7:UU P.M. until Sundav ev~ninll at 7:UU P.M. B. Visitation on alternatlnll holidavs. C. Visitation on an ~xtended hasis for two weeks durinll summer school vacatIon periods. D. such other reli~f as the Court deems proper. .: RESPECT FULL,' SUSH ITTED. '.~ I. . . / _ \ r / , /i:/(" I;, / / "f' I "" :,_.:, ,( l /' 11-.:.- I . ' .," Edward W. Harker. Esq. S,upreme Court III : ti3ti2 ( West Hillh Str~et Carlisle. Pa. 17013 17171 24:\-IUI:I3 '1 ,. , , "~\ " " " , VERIFICATION I ~ I, Richard Robert Bates, verify that the statements made in the attached Pleading are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. I :1 I. I Date: April 3, 1995 ~J /y:f'~ Richard Robert Bates .t, ~. CERTIFICATE OF SERVICE AND NOW, this 3rd day of April, 1995, I, Edward W. Harker Esquire, hereby certify that I have this day served the foregoing Counter-Claim by depositing a copy of the same in the united States Mail, postage preapid, at Carlisle, pennsylvania, addressed to: Thomas M. Kutz, Esquire 219 East Main Street Mechanicsburg, PA 17055 / ;" ,'ji / ,7 . 71/jp 1/# .. Edward W. Harker, Esqu re One ,West High Street Carlisle, PA 17013 (717)243-1083 ... ...~.""-""-'_. --'- .-:-....-"... - _._~ --.. .. " .. APR 3 "Q~ AM '95 It ~ICt, OF' ":', "IIO~:nA~Y (: , ", " J I ,~,. ',' 1 ' .vl " "-,,,'I' O',~ Y f'f~; It 5 T;. J..\.,! ~ EDWARD W. HARKER AnORNIY AT LAW 0.. W." HI,h St...t C.,U,'., r..... 17011 TERESA A. STI'l'T, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 95-1216 CIVIL TERM . . RICHARD ROBERT BATES, Defendant CIVIL ACTION - CUSTODY amIlR OF CXXJRT AND ~, this l"1 day of I J . A consideration of the attached Custody conci~tJtrc!n ordered and directed as follows: , 1995, upon Report, it is hereby 1. The Mother, Teresa A. Stitt, shall have legal custody and primary physical custody of the Child, Samantha Stitt, born November 9, 1989. 2. The Mother shall ccnsult with the Father and keep him advised of all major decisions, including educational, medical and religious decisions, affecting the Child. Upon request by the Father, the Mother shall provide written reports and other information concerning the Child's physical, academic and social development. 3. (a). The Father shall enjoy partial physical custody of the Child on the following Satucdays from 10:00 a.m. until 7:00 p.m.: April 22, 1995, May 6, 1995 and May 20, 1995. (b). The Father shall enjoy physical custody of the Child on the following four (4) alternating weekends from Saturday at 10:00 a.m. until Sunday at 3:00 p.m: June 3, 1995, June 17, 1995, July 1, 1995 and July 15, 1995. (c) . The Father shall enjoy physical custody of the Child beginning July 29, 1995 on alternating weekends from Friday at 7:00 p.m. until Sunday at 7:00 p.m. 4. The parties shall cooperate with each other in establishing mutually agreeable arrangements to share or alternate physical custody of the Child on holidays. 5. Beginning in the slllll11er of 1996, the Father shall enjoy extended periods of physical custody with the Child during the sunmer vacation as mutually agreed between the parties. 6. The parties may modify the foregoing custody schedule by mutual agreement. In the absence of mutual agreement, the terms of this Order shall control. ~H~ ~~~~ ~ ::1, .l'l ~~SB .... .... ~i "j'Jl ~:g .... ~~ ~ .:t~!: .... .... = a I v;< ~ () I c: ~~ t8t IJ~ 1; ,s ": .... , ~!\O~ III Ul ~i t. I" ~ ~M :- e-.~ i.t~ I ~ = ~"" ..... ... .0 ;;H:l H el ; ~:: .c ,g ~~~~ &J :.....a ::; ~ ::::: t:: C"o -5 . ~. m., tJ .., ~ ~ .~ ..: ~() i ~ ~~ ~ .. .. .. APR 1 7 jyg~I" ~