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STUN I':, lu\FA\'l':U &4\.' STUN)':
ATTOflNtVU AT LAW
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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
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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.
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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/ .
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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-
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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:
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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.
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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
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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
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Rebecca R. Hughes, Esquire
60 West Pomfret street
Carlisle, PA 17013
Attorney for Defendant
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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
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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
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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
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the 25th of December and the father\' '11 have the child from noon on the 25th of
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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