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Home My WebLink About95-03663 ~ :3 . -? ~ 3 f ~ f JI ("(') 11 (f) J~ -,.. ~ .:r-- ;a:J -;. ; tt ~J5 J! rf~ .", C71> :;~ - ~~ a ~~ ::co "f;': ""'" 1\1:: '.'~ ~~ I ...... r-- t..;.c" .: ..., "r 0,"" l-~ ~:: ." . . N, 0 , "') " ~ =<- .:;\ "l:\ ;':~ .~: bo.. .J r = , ," , , fJcL ~ " => .:> -. ~;:S ~ 0 ~~ !: '" .. :ll E ~ '" ~ ~ 15 ... p.en .. .., ;J ~ ~ ~ ~ffi l>l ;l Q Eo< .. en ~ ~ ~ ~ " '" 8 ~p. ;:l .... .. P. l'l <rl .c~",~ o -;'::>:0: ufSt1S - Ii: :llz"'I&l gj . C a:: 0( Go '" Eo< . gj 3g~~ 010( l>l III t o H H > l>l -;c~i: E-tuZ H ~ H ,.. ~ .. <rl 0 en ~ :J =>!,.. ,.. lE 01-<:> ~ ~ U U .... . l>l 0( ~ :0: ..: U i9l>l..:l 0 ~ ~,.. I-< j:l :> '1Il j:l Z ~OQ 0 H UZu Eo< . I.~ .... " . .. . " . t.' JUL 1 2 1995 Jp~ , '.. KAREN M. WALTERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 9l- 3t..{..'!; CIVIL TERM vs. TODD A. WALTERS, Defendant CUSTODY/VISITATION ORDER OF COURT AND NOW, -:)'''' I 'II ~ I 1'1 'if ,upon consideration of the attached Complaint, it is hereby directea that the parties and their respective counsel appear before O',w/1 '> $.""/,,,/ t.':~, , the Conciliator, at "'3'/ k /11'\'11 Sf-.. . 1"1, ',1-..',,,, ")Iv"<\ on the 1[4/, day of ((U~d~J- 1995, at IU;l',J 11. 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. All children age five or older 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: t " Custody Conciliator 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 ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 JUl It I 2 55 PH '95 , ; I!' ~ . < ~j'i .\ffl '"',:r . ',', ." 7.I'/,9s f!ed. (I~ .m~7b ~ !~ 1/'1. 9S 71~ ~~ ~~ .,. /I/'9j tdJlf IJI~ Z, .0 ~~ KAREN M. WALTERS, Plaintiff vs. TODD A. WALTERS, Defendant IN TilE COURT Ot' COMMON I'I,EAS at' CUMBERLAND COUNTY, l'I!NNSYI,vANIA CIVIL ACTION - LAW NO. ql,'-,~C.(,,~ CIVil. TERM CUSTODY/VISITATION COMPLAINT FOR CUSTODY 1. The Plaintiff is KAREN M. WALTERS, residing at 924 Thornton Ilrivo, Upper Allen Township, Cumberland County, Mechanicsburg, Pennsylvania 17055. 2. The Defendant is TODD A, WALTERS, residing at 1550 William Grove Rood, Monroe Township, Cumberland County, Mechanicsburg, Pennsylvania 17055. Name 3. Plaintiff seeks custody of the following child: Present Residence Kendra Marie Wolters Age 924 Thornton Drive Mechanicsburg, PA 17055 t'!ve (5) The child was born December 24, 1989. The child was not born out of wedlock. The child is presently in the custody of her mother, KARI!N M. WA1.TERS. who resides at 924 Thornton Drive, Mechanicsburg, PA 17055. at the following addresses: During the past five years. the child has resided with the follOWing persons A. Mother, Karen M. Walters and Mother's parents John W. Salter and Jenel1 M. Salter, his wife, B. Mother, Karen M. Walters and Father, Todd A. Walters C. Mother, Karen M. Walters and Mother's parents John W. Salter and Jenel1 M. Salter, his wife D. Mother, Karen M. Walters and Mother's parents John W. Salter and Jene11 M. Salter, his wife. 33 W. Factory Street Mechal1icsburg, I'A 17055 t'rom 12-24-89 to Aug. 1991 Petersburg Road, Carlisle, PA 17013 From Aug. 1991 to Oct. 1991 33 W. Factory Street Mechanicsburll, I'A 17055 From Oct. 1991 to .'uly 1993 924 Thornton Drive Mechanicsburg. I'A 17055 From July 1993 to present It should be noted that the child has resided with her mother for her entire Ilfe. -2- Name Heidi Walters Austin Walters Allison Walters Relationship Wife Son (twin) Daughter (twin) The mother of the child is KAREN M. WALTERS, currently residing at 924 Thornton Drive, Mechanicsburg, Pennsylvania 17055. She is divorced and not remarried. The father of the child is TODD A. WALTERS, currently residing at 1550 William Grove Road, Mechanicsburg, Pennsylvania 17055. He is divorced and remarried with two minor children (twins approximately one year old).. 4. Relationship of the Plaintiff to the child is that of natural mother. Plaintiff resides with the child and her parents aforementioned. 5. Relationship of the child to the Defendant is that of natural father. The Defendant currently resides with the following persons: 6. The Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another Court. Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. Plaintiff does not know of a person not a party of the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: A. PLaintiff has had custody of her daughter, Kendra Marie Walters, for Kendra's entire life and has cared for her in a loving and parental fashion. -3- B. Plaintiff and her daughter live with Plaintiff's parents who are in agreement with that arrangement and are loving and caring grandparents who care for the child when Plaintiff is working or doing other activities. C. Plaintiff. her daughter and Plaintiff's parents currently reside in a five bedroom home with two bathrooms and a full busement playroom. kitchen. dining room, family room and a large fenced in yard with a swing set. D. Plaintiff has enrolled her daughter in Kinder Academy School and Kinder Camp for her formative education. E. The natural father of Kendra lives in a mobile home with two bedrooms. one bathroom with his wife and two minor children. F. The Defendant has been encouraged by the I'laintiff to seek visitation of the child which resulted in him visiting with her approximlltely once per month for a period of time. Subsequently Defendant remarried approximately one and a half years ago and has scheduled visiitation of the child by agreement of the parties, Plaintiff and Defendant, every other weekend but ho has frequontly failod to exercise this visitation which on occasion has caused Plaintiff to reschedule her work hours. G. The child has had physical and emotional problems after visitation in the past and on one occasion, received severe burns from paying with sparklers (fire- works) causing second and third degree burna for which ahe received no medical treatment until she was returned to the Plaintiff. However. conditions have im- proved since the Defendant has remarried. H. The child, while on visitation with the lleCendant, is allowed to play unsupervised. 8. Each parent whose parental rightR to the child have not been terminated and the person who has physical custody oC the child has been named as parties to this action. There are no other perHona known to have a claim or right to the custody of visitation of said child. -4- WHEREFORE, Plaintiff requests the Court to grant custody of the said child of Plaintiff. p,~';/, ~~" tf'. ~/"",A William A. Yocum, A~orney for Plaintiff 3001 Market Street Camp Hill, PA 17011 (717) 761-5041 VERIFICATION I verify that the statements msde in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA C.S. 14904 relating to unsworn falsification to authorities. O)~ ~. O\~ Karen M. Walters, Plaintiff Date: J,,/~ '7, /11t -5- \ ~ SENDER: ... . Com".. h,"" I tnd/CN' 2 for ~tional IIrvfc... I .110 With to recelvl th, i ., COl'fIptttl h,,", 3. and 41 · b. following I.,vle.. ('or In IIlU, j , . Print your name and Md,... on the rive'.. fI' IN, form to Ihlt WI un '"I: ' "turn ttN, card 10 you. , An.... '10. 'Ofm to tho I,on, 01 tho ........... Of on 'ho bock II ..... 1, 0 Add'.....'. Addl... . : ... not PtmMt. I . · . Wri" "".tum"~ "equefled" on the meitp6Ke ~w thl'ltIde nurnbet 2. 0 nllulcted Oellvery " 'ti . The"eu.n Aee.., w.lhow to whom'M ante.. WI' ..ltvtted end lht dl'l . 8 delvet.. Cantult altm...., for f... 3. Anlcl. Add,.._ ID: 40, Anlcl. Numbel TODD A. WALTERS Z 324 521 141 j :,. 1550 WILLIAMS GROVE ROAD 4b. S.rvlc. Typo MECHANICS BURG PA 17055 0 Regl.t.r.d Oln.ur.d 1:" . IllI C.nlflod 0 coo .: (C. P Exp,... M.II IX R,'u,n R.c.lpl fDI t t, : O'7!ir. ~ t 8. Add'.....'. Add,... COnly If ,.qu,.,.d 1 .nd f.. I. p.ld) . , ....1 . J ~ ~ I . S n.lut. fAg.nll : lPs FD,," · ;! .Oocombe, 1881 ~,",*,lQ -.. .0... GPO: '___.'14 --.; DOMESTIC RETURN RECEIPT'- """,'r'M"'~~ Z 324 521, 141 ......... Receipt for . A"- Certified Mail _ No Insurance Covorage Pro,"ded ~:::.1'=-\ 00 not use tor International MOIl (See Reverlel . E """'10 ~ I "'''i's'SO''WILLIAMS GROVE RD ci "MicHANicSBURG PA 17055 ~ P<I".J'J" $ C.~ '" -' l ,~".,'~ //0 ~ <;1)lO{"..tI["""_f'.... 1111\."dt"IO'.',...,.I.... - Ht'",." fI"c""OI Sn"...,,;~ IO....."omllr fl"..O..i.......d R"'!"..,H..("f><llt~!'J...''"'9NW\r''(''" 0,11" .1"" AI111"W.'~"""tU'. TlJtAI f'(}r~" . "'tit', / PM'''''''~ //0 ~ $ .~ ,/'. ,. Ii' F ..;....c.-:.~~_.-':'__..._._..: '~~.no_,~_~ 1'."' .III~ k--::U' '. : . \\iIr:.oTflibl'8'i1r...a.7 \ 7.CI ~~e'!l\,rtl7;: Cj/~~TY FOR PRIVATE " , '} l USE TO AVOID PAYMENT ,~ OF POSTAGE. 1300 ,>.~!)' 1 I I i I I '-I' ',~, Print your nsme, address end ZIP Code here · WILLIAM A. YOCUM, ESQUIRE · 3001 MARKET ST CAMP HILL PA 17011 2(, 1.1111I11.1/1..111111.1111.1..1.1011111111I.1111.1111,11.11..1 .",--~..--~.----~_.'-'-"-'-' -- (O~Ji.MiJU) C661 lPH!~"4 'oose WlO:J Sd . . o 00 . " . . << ...., &:1? c i . ~'! i= - . !!~ 11:: ;8. i: 6.~ ~o - . t~ " - ~~~ ~~5 ';l- A: E ;;;!'" . .." f t ~ 'I: ,~ ~ g, 2 :~ ; ~ ~; e- ~~ ~~ aU ~;; ~E ~~ :s~ ue ~. ~~ -~ ~a Ea ~~ >~ au u~ aO: ~~ ~. ~. !.!e ;~ e~ a~ ~~ ~~ ~E ",e e;5 :;;~ tile e.; ~~ ~- a~ ~- e ~'" -a ~~ ~:;: ;: ::; u .,. .~>- <o~Q.. :~8 ~ "'1,1.I :g~a: ....:z 000: li,...:;:) ~:t:i !.Ea: c:; '--e g-: - ~.~ . "E~"f; :2 jj ~;;" 01..~ - . -... E:~ ~~~ . ~ 0 ;:~~ <>~ _ u C ... . " ~~ ~~; ~'M ~ ;: ~ ~ i ~:n m : ;g :~8 . ~:ii ,--.W ." ~;.~; a .~ iJ >i.l M ~a: ;;. ~ . ",~ o . - . 1l" . . o E l~ wn f; ~ .!! ~; f:~ o "'^ o. ~~ +~ ... , : -;J . ~ ~~ ! . . .,. . ~ o , ~~ :; ~ ;ii '2 ~- . 0 ~& ~~ ~~ , c !i; ~, a: w 1:~ tg o ~~ S!::? ""cr -.. l;i\ll 'w ,0: ~ C ~ 11 - . = . " c m ~ ~ ~ ~ , f . ,; 0", "';;, OM !!~ s; :- . . ft~ ~ 1i [] "n ".. 2<1 - " <:g 0, ~~ ~] . .. ~] : ~ ! ~ i < ~ ~ ~ . . . 5 ~ i~ . .. '" ( ., .. " ::~ , ....... '-;.,,:..~-- ..--:---- ..~ ."; \ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 95-3663 CIVIL TERM KAREN M. WALTERS, v. TODD A. WALTERS, Defendant CUSTODY/VISITATION CERTIFICATE OF SERVICE I, WILLIAM A. YOCUM, attorney for the Plaintiff, do hereby certify to the service of a true and correct copy of the Plaintiff's Complaint for Custody which was deposited in the United States Main, Certified, return receipt requested, addressed to TODD A. WALTERS, on July 18, 1995 and received by the Defendant on July 19, 1995, through his wife, HEIDI WALTERS. Date: J,./,,? /, I VI})' I I 9~11;.?... ' 11 &r'Ii"-. William A. Yocum.~ - '- ." ~ ...... c . . (J.) N .. .. .... . - '" l~\ -:> " ;::s:; ~""'~ . ... ~- ~ -' ~~ ~~~ ~I~~ ~ :c.JI .t': H ~ '" ti :g ~~~I :::l .... ~; l' g ~ ,()~>< OM ~ fit I ~ < .... ~~~~~ ' C . 11 .5 ~ !~ ~ ' Iii ;1 iilt'':lC ~~ D iII'l -:: ~ ~ :8~ t .Co- , ' c - ., ,. ~~~ 3: ~ la.m,uil] . .. :E: . :~~ ~ .0: ~ ... ;'). _.. '" . , #1" , ' .' '. ;.. &< t1'\~'6\O: 'tlv i hl"llJ KAREN M. WALTERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COllNTY, PENNSYLVANIA , '_.' l vs. NO. 95-3663 CIVIL TERM TODD A. WALTERS, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF AND NOW, this 2.-,' day of JIJ the attached Custody Conciliation Report, as follows: ~~ 1995, upon consideration of it is hereby ordered and directed 1. The Mother, Karen M. Walters, and the Father, Todd A. Walters, shall have shared legal custody of Kendra Marie Walters, born December 24, 1989. 2. The Mother shall have primary physical custody of the Child. 3. The Father shall enjoy partial physical custody of the Child on alternating weekends from Friday at 4:00 p.m. until the fOllowing Sunday at 6:00 p.m. The Father shall also have partial physical custody of the Child for two weeks, not necessarily consecutive weeks, during each SUlll11er upon thirty (30) days advance notice to Mother. 4. The parties shall share or alternate physical custody of the Child on holidays and the Child's birthday as mutually agreed by the parties. 5. The Father shall provide transportation fO~XChange of custody of the Child unless agreed otherwise by the parties. / cc: Joseph J. Dixon, Esquire William A. Yocum, Esquire J . l""r- );:1:J.1 h,-' ..><:~._-~.:... , --. '. - ,. ." KAREN M. WALTERS, P13intiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 95-3663 CIVIL TERM TODD A. WALTERS, Defendant CIVIL ACTION - LAW CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Child who is the subject of this litigation is as follows: NAME BIRTHDATE CURRENTLY IN CUSTODY OF Kendra Marie Walters December 24, 1989 Plaintiff/Mother 2. A Conciliation Conference was held on August 17, 1995, with the following individuals in attendance: The Mother, Karen M. Walters, with her counsel, William Yocum, Esquire, and the Father, Todd A. Walters, with his counsel, Joseph J. Dixon, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date (}v~'}f ,:J3, J () '1.,- c{';l<L I'---.LJ <-n d l1(;k Dawn S. Sunday, Esqui Custody Conciliator . . . . ", Lr> en r .,' ~.r: .- ~':-~~'-'~--'f"l,:.-, ~_-=...::.-~ \