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HomeMy WebLinkAbout95-01266 ,'t- " \i+ ;;;' '.' ~~~!:~;- ~-,;;l''''''-' ",c "j ~t~\;/~->_O,; ".,,0'" C' f:~L" Q) l~Wi~ ~~;&..,. ~~.. . ~\:~i;/:,:' ~rj;1' ;r(.,r:";. ~rg,:; ~.., > I~:;" ,> 't..'! -0,'_"-"'- _"'.,,.:::r; .'-' !_.~f):. .,>../ - 1- :,' ~ : 'f,.t':,' .- }1:\-'..-:;\' "'-.,,,- ;:,>,~-..\, , ~' , - ^ " . Y:~ " i~";d>" '.. ..-L," --, ' '<".' ,,'-.. '~~_~0~t ,~, '.:, :;;/: .~: .' '.: ,if_<'- ~-. . " ," , " ;'( " . ~ ...,i ,.,.~.' ~',- -' -- - . ,rg' ~I . - J J ~' g {!, . ,0 'Ii " ,. ~ .... .. u .. " I J\ c- .. ,.. ~ ~ - ' ~>>..' ..... h":';.:.~..~ ~ :.c~~'5 !~l:Jl...'~ '.~ :-1.'..-,:.. ~..._.~ '.. I'";: OJ '- ,'.', ",,' J ~ll , :;'" t{- J: "'.,lol,4l'; t... '_ '-'.Jlil t-....:;a.,.1. I. '" ciu " iE II'> .., C\J I::::) - .., ~ , ,; .,-/ d ~,~ ~ ~,;.~ ' . ~ ~ 0 ~ ~, III ~ ~' a " '. I>< III 0 d4 ~ ::l ~ ~ ~, ~. .... foo ~ I ~ ~ ~ @ III ~ <: B ~I>< ~ 0 'tl .... <: ~ .. .. o.to III .... .0 0: < ti II I ~i B '... 13 g. 0 j 0 ze .... p. ; 0: 0: 'lI ~& EO" I ~I>< Ii!: o ~ :! 88 0 ~ f .. ~ .... ~ 13' foo . H 0 H ~ 81 EJ . Cl t1 > III '.0: I>< ~. .::1 cif:< " " ..:. . . ... ;; STUN I':, lu\FA\'l':U &4\.' STUN)': ATTOflNtVU AT LAW .",,, U1l1UQC Drlu::r:r .. , NI';W {'U).IIII:ltI..\NII. ",\ ITUflI . ... ... fl\cu.t\_ull.ord\2." ~ .. -". ,. CAROL A, MULL, Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, (}.~~ I:J L. (. CL~ /'1,....... v, KENT E. GOCHENOUR, Respondent I CIVIL ACTION CUSTODY LAW o ROE R AND NOW, this / btA day of ~I),:\r.:" , 1995, on consid- ~~~~t~~ ~~dt~~ei;t~~~~~cii;~t~~~~s~i ~~p~:~e~~f~~~ec~~~~~r ~~jqM)PJ , , Esquire, the @nC\liator, on the -4l:h rleel:: , CWTlh.....la"d II 1.~la'taeuBe, on the /'It day of (VI",'/ , 1995, at -:+po... _ ,M. 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. Failure to appear at this conference may provide grounds for entry of a temporary or permanent order. By the Court, 4<j~.A.&~,~ C stody Conciliator __/~ ~ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO HOT 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. Court Administrator 4th Floor Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 H~R 20 II 00 PH '95 .3 'o>"l') .~!; (IF ..,' . ,!" tjillnll 'il[ " ,'1-00" r;If.~l,f':' ':./!/O.'I:n'\f,\ ,,,,,~.. "/'i;! /, ~' ~ J I.. .1,1 J. " J ~d tJy.p 1M,. .' 'c' '~~ ~~ I {~t/, ~ih(!J!~""fL .5. (/~4;4-ef 71c:.tfc.'e 111I1.~ ;0 <1..tj.' -'<3!~~,v.<'Vf J,-:)c'~s' -'3 'c.')O 7)' ." ~ .. .. ~ fl\cult\aul1,p.t\Z.,S . , . - .. CAROL A, MULL, : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. r; :,_ /,) (,. C. C,{<x.P "{;...,- petitioner v, KENT E. GOCHENOUR, Respondent CIVIL ACTION CUSTODY LAW PETITION FOR CUSTODY " AND NOW, comes the petitioner, Carol A. Mull, by and through her attorneys, Stone LaFaver & Stone, and files this petition for custody and in support thereof avers as follows: 1. The petitioner is Carol A. Mull, an adult individual residing at 5444 Oxford Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The respondent is Kent E. Gochenour, an adult individual residing at 521 Williams Grove Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. The petitioner seeks custody of the following child: Stepha- nie J. Gochenour, born September 1, 1986, age 8, The child was not born out of wedlock. 4. The mother of the child is Carol A. Mull, petitioner, and the father of the child is Kent E. Gochenour, the respondent. 5. During the last five (5) years, the child has resided at the following addresses: November 1989 to January 1994, 336 E. Meadow Dr., Mechanicsburg, PA with petitioner and respondent. -1- , II \1 U . , '. ", January 1994 to June 1994, 336 E. Meadow Dr" Mechanicsburg, PA with petitioner. June 1994 to present, 521 Williams Grove Rd., Mschancisburg, PA with respondent, 6, The petitioner has had regular visitation with the child, and now desires to be the primary custodian of the child, and believes it is in the child's best interest that she live with the petitioner. 7, The petitioner and respondent were divorced as of June 29, 1994, (No. 925 Civil 1994, Court of Common Pleas, Cumberland County, Pennsylvania) . 8, The best interest and permanent welfare of the child will be served by granting primary physical custody of the child to the petitioner with regular times of visitation to the respondent, WHEREFORE, the petitioner, Carol A, Mull, requests that primary physical custody of the children be awarded to her with regular periods of visitation to the respondent. Respectfully submitted, STONE LaFAVER & STONE (7/ . ,~, d 1? dw/ B~/"?~.......-c:// f/K('/(/t![;' Y Gerald ~,'Shekletski, Esquire Supreme Court 10 40466 414 Bridge Street, P.O. Box E New Cumberland, PA 17070 Telephone: (717) 774-7435 Attorneys for Petitioner Carol A. Mull Date: Jh/'/s- -2- I A' -' ,,- ,', , ' , ' .' , . , - . ' pdl.1oll-vor111..11 . , ~ V E R I FIe A T I 0 N Carol A. Mull states that she is the Petitioner named in the foregoing instrument and that she is acquainted with the facts set forth in the foregoing instrument~ that the same are true and correct to the best of her knowledge, information and belief~ and that this statement is made subject to the penalties of 18 Pa. C.S.A. S 4904 relating to unsworn falsification to authorities. \... ' It' ,,(,...'x ~ "''-\ ~~ CAROL A. MULL Date: ?), \ '=.~ \ C"\ "S \ , I- , L:,: ,j Il1J 1.1'95 MA yo.. 1995 /:",,) CAROL A. MULL, . Plaintiff , , IN TilE COURT OF COMHON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-1266 CIVIL TERM CUSTODY vs. ) ) ) ) ) ) ) ,; KBNT E. GOCHENOUR, Defendant \ " ORDBR AND NOW, this "'21/L day of M7 '1. , 1995, upoa review of the conciliator's report, it appearing that the parties have agreed to the terms and provisions of this order which was dictated in their presence and approved by them and their counsel, we hereby order as follows: 1. The parties will share legal custody of their minor child, Stephanie Jean Gochenour, born September 1, 1986. 2. Primary physical custody of the said IT.lnor child shall remain with her father, '1 the Defendant, Kent E. Gochenour. The mother of the child, the Plaintiff. Carol A. Hull, shall have the following periods of temporary or partial custody with the child: A. Alternating weekends from Friday at 4:30 p.m. until Sunday at 6:00 p.m. For these exchanges, the mother will be responsible to piCk up the child at the daycare center on Friday and return the child to the father's resideace on sunday evenings. The mother's alternating weekends shall commence on Friday, Hay 12, 1995. B. One overnight each week to commence at 4:30 p.m. oae evening, at which time the mother shall be responsible to pick up the child at the daycare provider, and the following morning at approximately 1:30 a.m., when the mother shall be responsible to return the child to the daycare provider. 1 \ '. The week overnights shall be on such nights as the parties may agree and, in the event the parties nhall not agree, it shall commence on Wednesday evening. C. For five weeks between the 1st of June and the end of August each summer, the specific weeks to be SUbject to the mutual agreement of the parties. The mother shall give the father written notice of the times she expects to exercise her vacation periods of temporary custody by the 15th of May each year. Bach week that the mother has the child during the summer vacations and is staying in the cumberland County area, the father shall have one weekly overnight, at the same times and on the same conditions as the mother has during the school year. In the event that the mother exercises her periods of temporary custody in the summer in blocks of three weeks or more, the father shall also have alternating weekends, cORlmencing with the second week of the mother's period of temporary custody, at the name times and on the same conditions as the mother has alternating weekends during the school year. 3. The parties shall share the custody of the child on the following holidays, on an alternatin<} basis: Easter, Memorial Day, Fourth of July, Labor Day, and Thanksgiving. The precise timen aad sehedulen of the holidays are to be agreed upon mutually by the parties. If the parties cannot otherwise agree, the holiday time shall commence at 8:00 a.m. and conclude at 8:00 p.m. and, when a holiday falls adjacent to a weekend that the parent is scheduled to have the child. the weekend will expand into the holiday so that the child is with that pare at continuousLy through the weekend and holiday. The holidays will commence with the father having the child on Memorial Day, 1995. In addition, notwithatanding the other provinionn of thin schedule, tho child , I 2 " , \ \. shall be with the mother on Mother's Day each year and with the father on Father's Day each year at times to be mutually agreed UPOII by the parties. Finally, the parties shall alternate custody of the child over the Christmas vacation so that, in odd- numbered years, the father will have custody ol the child from noon on the 23rd of December until noon on the 25th of December and the mother will have the child from noon on the 25th of December until noon on the 27th of December and, in even-numbered years, the mother will have the child from noon on the 23rd of December until noon 011 the 25th of December and the father will have the child from noon on the 25th of December until noon on the 27th of December. The Christmas holiday schedule will prevail over all other provisions of this schedule. 4. During the periods of the mother's temporary custody of the child, if the child has a regularly scheduled activity and the father gives the mother adequate notice of that activity, the mother shall be responsible to either arrange the child's attendance at the activity or permit the father to arrange that participation. By the Court, J. Gerald J. Shekletski, Esquire 414 Bridge Street New Cumberland, FA 17070 Attorney for plaintiff _ ~",.:vJ n,..,~S.<,L S/9/'1~' .>>,1', Rebecca R. Hughes, Esquire 60 West Pomfret street Carlisle, PA 17013 Attorney for Defendant Isla I !II ~ ~ -: ~ !: ~ ~ I" < ~ ~ Iii :;, ~ ~ 5 ~ ~ :r:: III '" I< ~ Cl ~ " 0 III ;;l !" ~ 01 i': -: ~ ~ d ~ ;;- 0 Iii .. ll, III ~ ~ .!'f III ~ A ~ 0 iI " :r. < ~ . . .' . , . i 0" .... 'i' 't MAY 0 5 ,g~}J,l . , . . . , I CAROL A. HULL, l IN THB COURT OF COMHON Plaintiff l PLEAS OF CUMBERLAND ) COUNTY, PBNNSYLVANIA vs. l ) NO. 95-1266 CIVIL TBRM KBNT E. GOCHBNOUR, l Defendant ) CUSTODY ,I JUDGE PREVIOUSLY ASSIGNEDI None QONCILIATOR CONPBRBNCB SUHHARY RBPORT " IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 19l5.3-8(bl, the undersigned Custody Conciliat~r bubmits the following report: .J,i 1. The pertinent information concerning the child who is the sUbject of this litigation is as follows: NAHE BIRTIIDATB CURRENTLY IN CUSTODY OF stephanie Jean Gochenour 1 September 1986 Defendant/Pather 2. A Conciliation Conference wan held on 2 Hay 1995 and the following individuals were present: the Plaintiff and her attorney, Gerald J. Shekletski, Bnquire; the Defendant and his attorney, Rebecca R. Hughes, Esquire. 3. The parties appeared at the conference well prepared to settle the case. After some negotiation through their attorneyn, they were able to reach agreement to resolve all of the isnues raised in the petition. 4. The attached order wan dictated in the presence of the parties and approved by both of them. With the entry of this order, no further action is necessary at the prenent time. 4 Hay 1995 ~x~Jh Samuel~ Anden Custody Conciliator , I , . -"; ., "CAROL A. MULL, ) IN THE COURT OP COMMON Plaintiff ) PLEAS OF CUMBERLAND ) COUNTY, PENNSYLVANIA vs. ) Ii ) NO. 95-1266 CIVIL TERM ,KENT E. GOCHENOUR, ) Defendant ) CUSTODY ORDBR AND NOW, this day of , 1995, upon review ~f the conciliator's report, it appearing that the parties have agreed to the terms and provisions of this order which was dictated in their presence and approved by them and their counsel, we hereby order as follows: 1. Thc parties will share legal custody of their minor child, Stephanie Jean Gochenour, born September 1, 1986. 2. Primary physical custody of the said minor child shall remain with her father, I the Defendant, Kent E. Gochenour. The mother of the child, the Plaintiff, Carol A. Mull, shall have the following periods of temporary or partial custody with the child: A. Alternating weekends from Priday at 4:30 p.m. until Sunday at 6:00 p,m. Por these exchanges, the mother will be responsible to pick up the child at the daycare center on Priday and return the child to the father's residence on sunday evenings. The mother's alternating weekends shall commence on Friday, Hay 12, 1995. B. One overnight each week to commence at 4:30 p.m. oae evening, at which time the mother shall be responsible to pick up the child at the daycare provider, and the following morning at approximately 7:30 a.m., when the mother shall be responsible to return the child to the daycare provider. 1 -~ . i " The week overnights shall be on such nights as the parties may agree and, in the event the parties shall not agree, it shall commence on Wednesday evening. C. For five weeks between the 1st of June and the end of August each summer, the specific weeks to be subject to the mutual agreement of the parties. The mother shall give the father written notice of the times she expects to exercise her vacation periods of temporary custody by the 15th of Hay each year. Bach week that the mother has the child during the summer I I l I' I I, vacations and is staying in the Cumberland County area, the father shall have one weekly overnight, at the same times and on the same conditions as the mother has during the school year. In the event that the mother exercises her periods of temporary custody in the summer in blocks of three weeks or more, the father shall also haVe alternating weekends, commencing with the second week of the mother's period of temporary custody, at the same times and on the same conditions as the mother has alternating weekends during the school year. 3. The parties shall share the custody of the child on the following holidays, on an alternating basis: Easter, Hemorial Day, Fourth of July, Labor Day, and Thanksgiving. The precise times aad schedules of the holidays are to be agreed upon mutually by the parties. If the parties cannot otherwise agree, the hOliday time shall commence at 8:00 a.m. and conclude at 8:00 p.m. and, when a holiday falls adjacent to a weekend that the parent is scheduled to have the child, the weekend will expand into the holiday so that the child is with that parent continuously through the weekend and holiday. The holidays will commence with the father having the child on Hemorial Day, 1995. In addition, notwithstanding the other provisions of thin schedule, the child 2 ,. , ( _.-~, '. :.., 1 , . .., '. , . . .. shall he with the mother on Hother's Day each year and with the father on Father's Day ,each year at times to be mutually agreed upon by the parties. Finally, the parties "shall alternate custody of the child over the Christmas vacation so that, in odd- 'numbered years, the father will have custody of the child from noon on the 23rd of December until noon on the 25th of December and the mother will have the child from "noon on the 25th of December until noon on tbe 27th of December and, in evea-numbered years, the mother will have the child from noon on the 23rd of December until noon on , ,~ ' the 25th of December and the father\' '11 have the child from noon on the 25th of . " '\ '", \ December until noon on the 27th of December. The Christmas holiday schedule will prevail over all other provisions of this schedule. 4. During the periods of the mother's temporary custody of the child, it the -/ child has a regularly scheduled activity and the father gives the mother adequate notice of that activity, the mother shall be responsible to either arrange the child's attendance at the activity or permit the father to arrange that participation. By the Court, J. Gerald J. Shekletski, Esquire 414 Bridge street New Cumberland, PA 17070 Attorney for Plaintiff Rebecca R. Hughes, Esquire 60 West Pomfret Street Carlisle, PA 17013 Attorney for Defendant sla