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HomeMy WebLinkAbout95-04564 '. . I ,""..,~'-' ;-.. " ~ Jolin Wesley Weigel Ill, Esquire Auarney A~Law SOElSt High S.r..l . Carlisle. FA 17013 Telephone (717) 2A3.1985 . Fax (717) 2A3.9766 I AUG J U '9956t^- ~; ._-,'" ---'-.., ~-"""*"""''''''''''''-'-r-~>-~.',- r-~ ..-...----~.."..,-"._..."""".;...VO,_~~,;H...;Q_...t~~UtL"J'...~*' I .\ ., , ~ SANDY DIONNE TAYLOR, IN THE COURT OF COMMON PLEAS petitioner OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW CUSTODY JAMIE LOWELL ARMSTRONG, Respondent 95- LJ5lP'-/- CIVIL TERM ORDER OF COURT AND NOW, this "6 I 05"/' day of AV,0lAS1 I e;qS- , upon consideration of the attached Petition to Modify custody Order, it is hereby directed halt the p,arties and their respective counsel appear befol;"e " u v(.rl . ("1 I f." C"'" ,..the conciU/lJ:ot;k1 on the - \(d~ day of IIc-n- , 199&, at 7F:<j' rL-.M., for conciliation 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. Either party may bring the child who is the subject of this custodr action to the conference, but the child/children's attendance s not mandatory. Failure to appear at the conference may provide grounds for entry of a,temP9rary or per~qnent order. I-Ic-,,"".? I S -I'" l>r h,.lc\ t>.. 1- L{Pj f/<'or (1A1>' b. Cb" 0....,1h.....s,. 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. Cumberland County court Administrator Cumberland county Courthouse Carlisle, PA 17013 (717) 240-6200 FOR THE COURT, SANDY DIONNE TAYLOR, . IN THE COURT OF COMMON PLEAS . Petitioner . OF CUMBERLAND COUNTY, . PENNSYLVANIA . . vs. . cIVIL ACTION - LAW . cUSTODY JAMIE LOWELL ARMSTRONG, 95- 1./ 5u't}. CIVIL TERM Respondent PETITTON FOR CUSTODY NOW COMES the petitioner, sandy Dionne Taylor, by her attorney, John wesley Weigel III, to petition the court and allege as follows: 1. petitioner Sandy Dionne Taylor is an adult individual residing at 1302 Pheasant Drive S., Carlisle, Cumberland county, pennsylvania. 2. Respondent Jamie Lowell Armstrong is an adult individual without an established residence but employed at Aladdin Mills, 13 Brenneman circle, Mechanicsburg, Cumberland county, Pennsylvania. 3 . The parties are the natural parents of Wosley paige Armstrong, age four, born February 15, 1991, and of Hayley Nicole Armstrong, age two, born June 21, 1993. The children have been born during the marriage of the parties to each other. 4. The parties were married on January 17, 1993, in Elkton, Maryland, and separated on August 23, 1995. 5. since the date of separation the children have resided with Petitioner at 1302 Pheasant Drive S., Carlisle, cumberland county, pennsylvania. 6. Petitioner is the primary caretaker of the children. 7. The best interest of the children requires that primary physical custody of the children remain with their mother, the ,-1. . .. -- - (:.: rr. ~.. ..;~ 1- " _oJ ... wQ en 8~: u- . [to ..;..: ~.l. ,-~~ r~~j ~f1 m :';:1;) i.i: N ..I?, rfV,1 jOr -" (-~ (i1lil F I.lJ l:~l~ c:;; ::~: II. If) :::> 0 c,-, (.J .. ,- ll.l:1lRlMRNT FOR ll.T.T.lV"J\.TIOH OF CUSTODY NOW COME sandy Dionne Taylor, by her attorney, John Wesley Weigel III, and Jamie Lowell Armstrong, pro se, to agree as folloWS: 1. sandy Dionne Taylor is the natural mother of the minor children, Wesley Paige Armstrong, born February 15, 1991, and Hayley Nicole Armstrong, born June 21, ,1993. 2. Jamie Lowell Armstrong is the natural father of the minor children, Wesley and Hayley. 3. The parties shall have joint legal custody of Wesley and Hayley. 4. sandy Taylor shall have primary physical custody of Wesley and Hayley. 5. Jamie Armstrong shall have partial custody of Wesley and Hayley the second saturday and sunday of each month from 9:00 a.m. to 6:00 ~.m. -' 6. Should Jamie Armstrong fail to pick up the minor children within thirty minutes of the starting time on any of his days for partial custody, he shall be considered to have waived his right to partial custody for'that day unless he contacts Sandy Taylor to request more time within which to pick up the children. 7. Jamie Armstrong shall promptly return the children to the custody of sandy Taylor by ths time scheduled, as set forth above. 8. The parties shall exchange the children at a location, not the residence or place of employment of either party, to be agreed upon between the parties. 9. During the time that he has partial custody of the " . . ,'. . . SAlOIS. SHUFF & MAS LAND A.~Nr.YI.AT.LAW 16 W. I\lSh SIr..1 Corll.I.,M 6. The parties further agree that the Petitioner, Jamie Armstrong shall have periods of partial physical custody of the children as follows: a. First and third weekend of each month, from Saturday at 12:00 p.m. until Sunday at 4:00 p.m.; b. One week in the summer, upon 30 days notice of an intention to exercise a period of visitation; c. Shared holidays, at times to be mutually agreed upon by the parties; d. Each ~ather's day from 8:00 a.m. until 8:00 p.m.; e. Any other tim~ frames as mutually agreed upon by the parties. 7. The parties desire that this agreement be evidenced by the Order of Court. 8. The parties agree that this Court shall retain jurisdiction of this matter. WHEREFORE, the parties hereto request Your Honorable Court to enter an Order awarding custody pursuant to the provisions of t~. to ;,; boA ----h. ,:,:::::.Q(,~~~U) Sandy Dio~--~(j- /1' 'A ,/,/("~' 1'20, Jamie Lowell ~rmstrong i// ~ c<) ?; v; '"== c.; 5-'" ("J w-- t.:,1~ Ql:'~' -=c U'''' II- " .;.. ~ t..:\:' (:l~.:i c')c. C1\ :,'r (yi: ~~ ,~\r.. \ {\! to ~ f.t ~;J cr. ~ .,c U.L>- ~, - .~ - ;:.. '" 0 .5 .,:- 0 0 U : ./ . . . . ...