HomeMy WebLinkAbout95-04601
12:00 noon until December 26 at 12:00 noon, Thanksgiving,
Memorial Day and Labor Day.
3. In every year - Mother's Day.
c. on the child's birthday in every year, the party who does not
otherwise have custody on that day shall have a period of
partial custody from 3:00 p.m. until 7:00 p.m.
5. The Father shall not consume alcoholic beverages during periods of
partial custody of the child.
6. The Father shall attend a minimum of six (6) counseling sessions
with an alcoholism counseling program. The Father shall make arrangements
within thirty (30) days of the date of this Order for the counseling.
7. This Order is ,entered pursuant to an agreement of the parties at a
Custody conciliation Conference. The parties may modify this Order by
mutual agreement. In the absence of mutual agreement, the provisions of
this Order shall control.
BY THE COURT,
ec: Keith O. Brenneman, Esquire
Jonathan M. McGuire
Ad-
J.
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LAW o,P1CU
SNELOAKER
.
BRENNEMAN
MATTI A. MCGUIRE, IN THE COURT OF COMMON PLEAS OF
. CUMBERLAND COUNTY, PENNSYLVANIA
.
plaintiff .
.
v. . NO. 95 -
.
.
.
JONATHAN M. MCGUIRE, .
.
. CIVIL ACTION - CUSTODY
.
Defendant :
COMPLAINT FOR CUSTODY OF MINOR CHILD
AND NOW, comes the plaintiff, Matti A. McGuire, by her
attorneys, Snelbaker & Brenneman, P. C., and avers the following:
1. plaintiff Matti A. McGuire is an adult individual
residing at 1268 W. Lisburn Road, Mechanicsbur9, cumberland
County, pennsylvania 17055.
2. Defendant Jonathan M. McGuire is an adult individual
presentlY residing at 29 S. East street, Carlisle, cumberland
county, Pennsylvania 17013.
3. plaintiff seeks custody of the following child:
libME
PRESENT RESIDENCE
1268 West Lisburn Road
Mechanicsburg, PA
Mlli
Tyler Martin
McGuire
2 years,
10 months
The child was born in wedlock.
The child is presentlY in custody of the plaintiff at
her residence as indicated in paragraph 1, above.
LAW O,P1CU
SNELDAKER
.
BRENNEMAN
5. The relationship of Defendant to the child is that of
father. The Defendant currently resides with the following
persons:
HAME
RELATIONSHIP
Lori Bender
sister
6. plaintiff has not participated as a party or a witness,
or in any other capacity, in other ligation concerning the
custody of the child in this or any other 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 to
these 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 Plaintiff
has, since the child's birth, been the primary caretaker of the
child and can provide a clean, safe and emotionally stable home
and environment for the child.
8. Each parent whose parental rights to the child have not
been terminated and the person who has physical custody of the
child have been named as parties to this action. All other
persons, named below, who are known to have or claim a right to
custody or visitation of the child will be given notice of the
-J-
LAW O.Plcn
SNELOAKER
.
BRttlNtMAN
MATTI A. MCGUIRE,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95 - 4601 CIVIL TERM
v.
JONATHAN M. MCGUIRE,
CIVIL ACTION - CUSTODY
Defendant
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA)
COUNTY
OF
: 55.
CUMBERLAND)
Keith O. Brenneman, Esquire, being duly sworn according to
law deposes and says: that he is a principal in the law firm of
Snelbaker & Brenneman, P. C., being the attorneys for Matti A.
McGuire, the plaintiff in the above captioned action for custody;
that on September 6, 1995, he did send to Defendant Jonathan M.
McGuire by certified mail, return receipt requested, restricted
delivery, a duly certified copy of the Order scheduling the
custody conciliation for september 19, 1995 at 12:00 P.M. and the
complaint for custody which was filed in the above captioned
action as evidenced by the attached cover letter of the same date
and Receipt for certified Mail No. Z 115 697 404; that both the
Order and complaint and cover letter were duly received by
Jonathan M. McGuire, the Defendant herein, as evidenced by the
return receipt card for said certified mail dated september 11,
1995; that a copy of the aforementioned cover letter dated
September 6, 1995 is attached hereto and incorporated by
reference herein as "Exhibit A" and that the copies of the
Receipt for certified Mail and the Domestic Return Receipt
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