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HomeMy WebLinkAbout95-06000 DONALD W. HANLEY, JR., plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95 . (. UJO CIVIL TERM v. I I I I I I I CUSTODY LISA D. COONS, Defendant ORDER OF COURT AND NOW, upon consideration of the attached complaint, it is hereby direoted that the parties and their respective counsel appear before () f r I " 'J L ) . fl tv )../,,;, \~') <tH'fI \ ')\A,,,,,,t... , the conciliator, at 'j') I.. (I'/c.,,,:).,-),, on the 961~ day of ---1~C'",(l'",IFr , 1995, at LE- .m., for a Pre-Hearing cU8tody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be aocomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. By the court, j)""".j/1L11~- I,::,;, custody concilialtorW/J I 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. COURT ADMINISTRATOR, 4th FLOOR CUMBERLAND COUNTY COURTHOU6E CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER I (717) 240-6200 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of common Pleae of cumberland county is required by law to comply with the Amerioans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Ocr 2G 2 511'i1'95 nj -\, . !l" /()v(., 95 Qj. d,?/ /I~'i6 /5. ,f) of; . 9.{~ 71t."'lfu ~".Jj/ .1J ~ I{)'r;)ft; 9~ t~ /';;JJ! --;;. f)..J:;....I',. DONALD W. HANLEY, JR., : IN THE COURT OF COMMON PLEAS OF plaintiff I : CUMBERLAND COUNTY, PENNSYLVANIA v. : : NO. 95 CIVIL TERM LISA D. COONS, : Defendant I cUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Donald W. Hanley, Jr. residing at 302 Meadow Drive, Shippensburg, cumberland county, Pennsylvania, 17257. 2. The defendant is Lisa D. coons, residing at 33 South Wa.hington street, Shippensburg, Cumberland county, Pennsylvania, 17257. 3. The plaintiff seeks custody of the following child: Name Present Residence Age Jackie B. Hanley 33 South Washington st. Shippensburg, PA The child was born out of wedlock. 1 year old The child is presently in the custody of the defendant, Lisa D. coons, who resides at 33 South Washington street, Shippensburg, cumberland county, Pennsylvania. During the child's lifetime, she has resided with the following persons and at the following addresses: Name Address Date Li.a D. coons, Jack coons Barbara coons (Defendant's parents), and Brian coober 33 South Washington st. Shippensburg, PA Birth - present The mother of the child is Lisa D. coons, currently residing at 33 South Washington street, Shippensburg, cumberland county, Pennsylvania. She is single. The father of the child is Donald W. Hanley, Jr., currently residing at 302 Meadow Drive, Shippensburg, Cumberland county, Pennsylvania. He is single. ... The relationship of plaintiff to the child is that of father. The plaintiff currently is residing at 302 Meadow Drive, Shippensburg, Cumberland county, Pennsylvania. 5. The relationship of defendant to the child is that of Blother. The defendant currently resides with the following persons I Name Relationship Father Mother Son Daughter Jack Coons Barbara coons Brian coober Jaokie B. Hanley 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. 7. The plaintiff has no information of a custody proceeding concerning the child p~nding in a court of this commonwealth. 8. The plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have % }~ (,j . ,..., ::1":" ~'.." . If'> ~ :.' ...""'"1 ~ ,,:;.;.., .... u c.:J . DON^LD W. H^NLEY, JR., plaintiff IN THE COURT OF COMMON PLE^S OF CUMBERL^ND COUNTY, PENNSYLV^NI^ v. NO. 95- CUSTODY CIVIL TERM LIS^ D. COONS, Defendant MllllM'l'l'._llLJlJ1Pl'QR'LQf-.J>Il'lTI'l9N lQR.LE^VR'l'!LPRQQIIlP Hi f9.RHft.PAIJPIIUB 1. I am the plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: _tl2nAlJLlt!LJiAn1t.Y.......J.IL.. ---.----. Mdress: -.J.Q.LHuilQw.j)..ny!L---.-----".- ---- ' .-- flb1pptnliP\lIg,- PA __Jli)~L__ - ----- social Security Number: 353-llQ-6li7:L --- ..-'--' (b) If you are presently employed, state Employer: None -----..-. Mdress: ."fA _. ..__.__ . ..___n -'---~' -"- -_.._~-,._---~------ (c) Salary or wages per month: _JlfA Type of work: "f^ If you are presently unemployed, state Date of last employment I 1993 - .,---.----.. Salary or wages per month: _1.!l.Q.. QO_ ---- ------------- Type of work: m111(;!!Uan'Q\l,!!.,------- Other income within the past twelve months Business or profession: None other self-employment: Non!! (f) Debts and obliQations Mortgage I _JiQM___~____ Rent I~_O_L___ Loans: NomL ________ -.-- Monthly Bxpensesl_Ju.!ctt:j.lL=-UQQ...Q.Q..~le - 110, OQ....._ Mastercard - 1100. OQ..~.Jirocera!L__-'l.Q.Q-,-QO . _Gllllol1ne _=--'40.1.oQ, _Clothing..::. ~U6. 00. extra - 120.00 (g) Persons dependent upon you for support (Wife) (Husband) Name: None Children, if any: Name: Jacki,-IlJ._~nl!LL.__ n"'" Age: 1 1/2 YrB. 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C.8. 4904, relating to unsworn falsification to authorities. Date: lo-Its> - ~.2.______ 1~:"-1_~ .. Donald W. Hanley, DONALD W. HANLEY, JR., I IN THE COURT OF COMMON PLEAS OF plaintiff I I CUMBERLAND COUNTY, PENNSYLVANIA v. I I NO. 95-6000 CIVIL TERM LISA D. COONS, I Defendant I CUSTODY CERTIFICATE OF SERVICE I, Traci Lederer, served the defendant, LISA D. COONS, with an order of court and Complaint for custody in the above-captioned case by sendinq them certified mail, restricted delivery, return receipt requested to the followinq address I JJ South Washinqton street, Shippensburq, Pennsylvania 17:157. ((~i i1 r ),"-;, /.(1!) . Date / ~~'l ;~ti;l ,- Leqal Intern LEGAL SERVICES, INc. DONALD W. HANLEY, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 95-6000 CIVIL TERM LISA D. COONS, Defendant CUSTODY AND NOW, CUSTODf ORDER 6 f II . r".' \(""1 (. this. day of. - . ,1991, upon consideration of the parties' Consent Agreement, the following Order is entered with regard to custody of Jackie B. Hanley, hereinafter referred to as the child. 1. The plaintiff, hereinafter referred to as the father, and the defendant, hereinafter referred to as the mother, shall share legal custody of the child. 2. The mother shall have primary physical custody of the child. 3. The father shall have partial physical custody of the child according to the following schedule: a. For the weeks of December 3rd and December loth, the father shall visit with the child at the Shippensburg McDonald's on Tuesdays and Thursdays from 5:45 p.m. to 7:45 p.m. b. From December 17th until further Order after a conciliation conference, the father shall have custody of the child at his brother's home each Tuesday and Thursday from 4:45 to 7:45. c. Other times agreed upon by the parties. v. I I I 1 I I 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONALD W. HANLEY, JR., plaintiff LISA D. COONS, Defendant NO. 95-6000 CUSTODY CIVIL TERM CONSENT AGREEMENT This Agreement is entered on this ~ day of December 1995, by the plaintiff, DONALD W. HANLEY, JR., and the defendant, LISA D. COONS. The plaintiff is represented by Joan carey, of Legal Services, Ino./ the defendant is represented by Mark, Weigle, and Perkins. The plaintiff, hereinafter referred to as the father, and the defendant, hereinafter referred to as the mother, agree to the entry of the following order regarding custody of Jackie B. Hanley, hereinafter referred to as the childl 1. The parties will share legal custody of the child. 2. The mother will have primary physioal oustody of the ohild. 3. The father will have partial oustody of the child according to the following schedulel a. For the weeks of December 3rd and December loth, the father will visit with the child at the Shippensburg MoDonald's on Tuesdays and Thursdays from 5145 p.m. to 7145 p.m. b. From December 17th until further order after a Conci 1 iat ion COnferA/ICe, the father wi 11 have custody of the child at his brother's homo oach Tuesday and Thursday from 4:45 to 7:45. c. Other times agreed upon hy the parties. 4. The mother and father, by mutual agreement, may vary from this schedule at any time. 5. The parties will notify each other of all medical care the child receives while in that pllrent's care. Each parent will notifY the other immediately of medical emergencies which arise while the child is in that parent's care. 6. It is expected that the part las will gradually expand the father's partial custody schedule to inclUde full day visits for several weeks, and eventually overnight periods every other weekend. A Conciliation Conference is scheduled for Jllnuary 4, 1996. WHEREFORE. the pa 1'1 i es requast t hilt an Order of Court be entered to reflect the above terms. 1,) C'1'\.O.~ 'lL} l/A:Y) I/.; '1J ()~ Donald W. Hanloy, .Jr. PIW'iMiff ~/&L{fib.lUJ ~___________ / olin Cllrey 7--- Attorney for Plaintiff LEGAL SERVICER, INC. a Irvine Row Carlisle, Pa 17013 (717) 243-9400 ~;(; ~L,~.P2rL.:J ~~ D. Coons, Defendant ~q:Cv~__ David Perkins Attorney for Defendant 126 Eaet King Street Shippensburg, PA 17257 c. BCllinninll Murch 2, 19%, cvcry olhcr wcckcnd from 10:1l0 u.m. on Sulurduy until 6:00 p.m. on Sunduy. d. BCllinnlnll Muy Ill, 1996, cvcry olhcr wcekcnd from 6:011 p.m. on Friduy unlil 6:00 p.m. on Sunduy. c. Other limes ullrccd upon by Ihc purtics. 4. The lalher und mothcr will ulternutc Chrislmus Evc und Chrislmus Duy cuch yeur, with one purty huvinll Ihc child on Christmus Evc ul 8:00 p.m. until Christmus Duy ul 2:00 p.m. und Ihc olher purty huvinll thc child on Chrislmus Duy uI2:110 p.m. until 8:00 p.m. on Dceember 26. The fulher will huvc Chrislmus Evc, 1996. 5. The purtlcs will ulternulc Ihc followinll holiduys: Euslcr, Thunkslliving, Memoriul Ouy, the Fourth of July, und Lubor Duy, from 10:00 u.m. until 8:00 p.m. The falher will huve Euslcr, 1996. 6. The futhcr will huve thc rillhllo scc Ihc child on hcr birthduy ul u Ilmc 10 be rnutuully ullrecd upon by Ihc purtics. 7. The fUlhcr will huvc Ihe rillhtlo Iwo wccks vuculion cuch summcr, 10 include Iwo udditionul weekcnds. Thc mol her will huve Ihe righllo Iwo wccks vuculion cuch summcr which will include u muxlmum of two wcckcnds. Thc vuculion wccks muy bc conscculivc If Ihe parties ugree. Each purcnl wlllllivc Ihc olhcr purcnlnoticc of his or hcr pcriods ofsummcr vucullonon or bclorc Mcmoriul Duy of 111lI1 summcr. Ncilhcr purcnl shull rcmovc Ihc minor child Ihllll Ihc Commonwculth of I'cnnsylvunlulilr summcr vucution during culcndur ycur 19%. In subscqucnl ycurs, ncllhcr purent shull rcmovc Ihc child Ihull lhc Commonwculth of Pcnnsylvuniu tilr summcr vucullon wllhoutlhc prior wrillcl1 conscnt of thc olhcr purcnt. MAnK, WtlCit_t ANU flrUKlN5 _ All0llNlV5 AI lAW, l.ilb t:A!JI KINO SllHLl 5IUI'l'rNsutJllO. flA 17267 r:T'I CiTiC~ (., '" : ' ",1'" '.',!f''''( II ..j...1 ~,'j n.i~ -:~ ;,:; 1/: /I. Cl ,.,. , . ' (,.., 1'1Y , ,.I.. ,..~ ,. J -"'_'U;', I' ,,' ,', :"L"""'\ .'t. h.1 "\,olj C. BCl!illllillg Murch 2, 1996, cvcry othcr WCCkClldlhllll 10:00 u.m. 011 Suturduy uIIIII 6:00 p.lII. 011 SUllduy. d. Bel!illuilll! Muy 10, 19l)(), cvcry othcr wcekelld from 6:00 p.m. 011 Friduy ullliI 6:00 p.m. 011 SUllduy. c. Olher limcs ugrced UpOIl hy Ihc purties. 4. The fulher und 1II0lher willullcmulc Chrisllllus Evc ulld Chrislmus Duy cuch ycur, wilh olle party huving Ihe child 011 Chrislmas Eve ul 8:00 p.m. unlil Chrislmus Dayal 2:00 p.m. nnd Ihe olher party havilll! Ihe child on Christmas Dayal 2:00 p.m. until 8:00 p.m. on December 26. The father will huve Christmas Eve, 1996. 5. The parties will allenlllle Ihe followillg holiduys: Easter. Thunksgivillg, Memorial Day. Ihe Fourth of July, alld Labor Day. from 10:00 a.m. ulllil 8:00 p.m. The falher will have Euster. 1996. 6. The falher wlll huve the ril!hlto see Ihe child 011 her hirthday at a time to be mutually ul!rced UpOIl hy thc partics. 7. The falher will have Ihc ril!htto two wccks vacalioll cach summer, to include two addltiollal weckcnds. The 1II0lher wlll have thc righllo Iwo wccks vacatioll each summer which wl1llllclude a lIIaxltllum oflwo wcckellds. The vacalioll wccks may hc cOllsccUlive If Ihe parties agree. Each parclIl wllll!lve Ihe olhcr purelllllollcc of his or her pcriods of summcr vacalloll 011 or before MCllloriul Duy ol'lhul sumlllcr. Ncilhcr purcllt shull rcmovc Ihe minor child fromlhc COlllmollwcullh of PCllnsylvulllu tilr SUlllmcr vucutlon during culcndur ycur 1996. In suhscl\ucnt ycurs, ncilhcr purclIl shull rcmovc Ihc child from thc Commonwculth or PCllnsylvuniu for summcr vucullon wlthoutlhc prior wrillcn conscnlor Ihc othcr purcn\. MAl1K. Wflfill' ANI) 'JFftKIN~ _ ^11CIIlNI;YS Al lAW '''Ii I-AS1 KINel SfRl'tl 6IU....t:NSnUlUl, .'A, 17267 ~ M E= b; . lo!, .. ~c.. ~.~ - r .., - .\~,; - .- , U' :"i; I ~r tf) " ~,.') ~r_ ) -.-. I I:~ ~~~: , rfl: r.-:, "', j 1.1' ~!LL f' L... !'..' it. \D -',) C' (1'1 (.)