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HomeMy WebLinkAbout95-01753 ~ ~ -7 ~ o E ~ J C'<) l!) r - I l() cr ~ '". ;,,', ,~i _"0' > >, ,~ . ," '. ~, ' "' ", FLOYD B. DEITCH and MILDRED E. DEITCH. Plaintiffs . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ?), J 7)3 ~ fL..-. . . . . Vs. : . . SEAN HUBER, CUSTODY/VISITATION Defendant ORDER AND NOW, this \2./i day of A pr: l , 1995, upon stipulation and consent of the parties it is ORDERED: 1. That Floyd B. Deitch and Mildred E. Deitch shall be and hereby are awarded primary physical and legal custody of the child, Andrew James Huber, born December 11, 19931 and 2. Sean Huber shall be entitled to visitation with the said child at such reasonable times and periods as the parties shall agree. BY THE COURT, , ~ ~~~ ('\ *'J '~ 1 ~ Edward W. Harker, Esquire Attorney for the Plaintiffs , . ~, . Sean Huber, Defendant 915 Sandbank Road Mount Holly Springs, PA 17065 !' . .:....."....'., " k " - ,.\ '.-1 1 ~ .... ~b, ~d \1t \ 1\ IU~ FLOYD B. DEITCH and MILDRED E. DEITCH, Plaintiffs . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Vs. SEAN HUBER, Defendant . . : NO. 9~'- J7,'j-J CIVIL TERM : IN CUSTODY In Re: Custody of ANDREW JAMES HUBER, Minor Child . . COMPLAINT POR CUSTODY COMES NOW, the Plaintiffs in the above matter by their attorney Edward W. Harker, Esquire, and represents as follows: 1. The Plaintiffs are Floyd B. Deitch and Mildred E. Deitch, 1135 Centerville Road, Newville, Cumberland County, Pennsylvania 17241. 2. The Defendant is Sean Huber, residing at 915 Sandbank Road, Mount Holly Springs, Cumberland County, Pennsylvania 17065. 3. Plaintiffs seek legal custody of the following child: NAME PRESENT RESIDENCE AGE Andrew James Huber 1135 Centervi11e Road Newville, PA 17241 15 months The Plaintiffs are the maternal grandparents of the said child. The Defendant is the natural father of the child. Stacey Lee Huber, the natural mother is deceased. Andrew James was born on December 11, 1993. " During the past five years, the child has resided with the following persons and at the following addresses: NAME ADDRESS DATES Defendant and Stacey Lee Huber 915 Sandbank Road Mt. Holly Springs 17065 3 weeks Plaintiffs 1135 Centervi11e Road Newville, PA 17241 January 1, 1994 to present 4. Plaintiffs are the maternal grandparents of the child. The Plaintiffs currently reside with the following persons: NAME RELATIONSHIP Andrew James Huber Grandson 5. The Defendant is the child's natural father. The Defendant currently resides with the following persons: NAME RELATIONSHIP None. 6. Plaintiffs have not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the said child in this or another Court. 7. Plaintiffs have no information concerning any custody proceeding concerning the said child pending in a court of this Commonwealth. 8. Plaintiffs do not know of a person not a party to the proceedings who has physical custody of the said child or claims to have custody or visitation rights with respect to the said child. J - VI e. 5 O. " ~ "'" ..., ''''; ... ;~ :, '.>0 '--I " ,. ~ if ..,." en - >-~ ,~ \>.. ....J .~ ~1>: !~~ ': ' :~ '.... :.~' ~C ;~D"" .,( '. "r." ~-.' -, . ,'... :.:t' ~. .' ~ ./) ~ ~ .... :' ;..." (,D i'.'~:~ ..~.'" ;.~ '" u... ~;_, ""'" 0: w ..!:! ~~i!: :t !(j.. ~ :c 5 a;i~ C~~.! 0:0 :f ~I:.. ;> < I:: U C 0 &II -, . , \.. . ; ',;; . r ',>, ... ~- ~ . :0- ",>- o' .... l,:-Z lu,...,.::i...t ~~;~;' , .~ -,' ..T ;'i" ":~~ " 7.:' :~ ~> '-' ~ iE .... .;z N <..0 "" .:c