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HomeMy WebLinkAbout95-06213 1. ""~ : " ,-; _:~ 'i,,-" :;;:-:-:,,::,-. .:,{:;i.2::,' ;",' ..,.. ,.' f~~~JJ~:;~'r~- ,~--,~'- -'c ~t ,:n~;;_:,i~: ~_i:l., '. _,'_ I : f:\ , ~',c. ' '\-,,';- ...j;." "", ,- ;: i';,',;;-"'; ,,'.:, .:,~,:":;::i;. ,';;, :,y,'_": ,':\ ..' .- .- '<':1 'c. '.: ',' '"..' ,. ' "j",:t: -::, }'c..> ; ,:: ,/ ;,:,:/i1 \;:~I'Y~,';';' ',e '.' /:;-;>:/;?~; ;:i- ." :'ii, ; .. ,,:::' ;:;;':.. ::'. - , ",'.' ',' _:-: . ., - . '.': - ' .; ".' ' -' ,- " <:'/-': ,,," . ".,,>:::.,::': -. ,:-,:-, ., -, ,. - -. <;,,::.',.':.-'. j.,; ;: ';\-~,/', . ,,,' '~,:;: "i ,:' :,:-,::', :' -,'n ", '.. , -.: ,,',; :', :i~ ,; -;.', ,.., l~'~ ~i:~,;t!LI;',".:'::': , , , : _ ' ::'i:'.',;:':,':"',-~'",\", \ '. '" " ':\,~:: ,: ....'..,: " , ,-<. ";_c ::-: ,'.', ,'.",;;,;, ' ,";:-, :;~ ':>', :;'.:'" :1:,~v:.n:,:,,;-; ':,-; ,.. '-,'.:," :"';:j::, ":~; :}\',~:,~__>: ._', -- .. :. ;'(-':,; , , .' :.: r' . _ ,.', ;_, . ' ,_ ,. ,,;, :i[': 'J _,~_:, . '. 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M. ~rlohtfendant . . :CIVIL AC~ION - LAW : (,dJ3 :NO. qs:- CIVIL :CUSXODY/VISI-TATION 19 * " ORDER or CODR!' 1'\011 . ~ ,c;c,S- AND NOW, this (daU) , upon consideration attached complaint, it is hereby directed their respective counsel appear before :t1'k , the concil.iator, at DO-. \ h 51 on the ~day of r-rn rr , 19 q , at :otP,. H., for a Prehear.ing Custo y Conference. At such conference, an effort w.ill be made to resolve the .issues .in d.ispute; or if this cannot be accompl.ished, to define and narrow the issues to be heard 'by the court, and to enter into a teJDPorary order. Bither party may bring the child who is the subject of th.is custody action to the conference, but the ch.ild/children's attendance i. not .andatory. Fa.ilure to appear at the conference may provide grounds for entry of a tempC?rary or penunent order. FOR ~HB COUR~: By: ~ A ;"1. - ~ p,f Ii.. - - I-'&:,., ~c;;;;~ncili~ pP~ / rou SHOULD ~AICB ~HIS PAPER XO YOUR LAHl'BR A~ ONCB. IF YOU DO NO~ HAVB A LAHl'BR OR CANNO~ AFFORD ONE, GO ro OR ~BLEPHONE THE OFFICB SB~ FORTH BELOW ro FIND OU~ WHERE YOU CAN GB~ LEGAL HELP. OFFICE OF THB COUR~ ADNINIS~RAroR COURTHOUSB, FOUR~H FLOOR CARLISLE PA 17013 (717)240-6200 II Nov 3 3 3/ PH '95 . !LE II' OFFtC~ IJ.; . d.t r"1TW'w T~h' CU~L";..'~~ ';%NTt ~lNN~ rlVMllt 11'315 (lei . CiJofi /ltJ/ $ at; ~ 1I'3.f1S 7?;:tu ~ ~ dft If' 3,9.5 6f1 i11t!-4; ~ /11. &..p " '" , I I . .".-..t...... ,~ .- . . . CORBETT S. SMITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION . LAW NO. 1~{ (0;)./3 () ~L,)L-Vrr- PAMELA M. ANGELOFF, Defendant CUSTODY ORDSR OF COURT You, Pamela M. Angeloff, Defendant, have been sued in court to obtain partial custody of the child: Felicia Marie Angeloff. You are ordered to appear in person at on , at .m., for a conciliation conference. If you fail to appear as provided by this order, an order for custody, partial custody or visitation may be entered against you. 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 Courthouse Carlisle, PA 17013 (717) 240.6200 . . . CORBETT S. SMITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. PAMELA M. ANGELOFF, Defendant CUSTODY COMPLAINT IN CUSTODY The Plaintiff, Corbett S. Smith, by his attorney, Cindy E. Sheaffer, sets forth the fOllowing cause of action: 1. Plaintiff seeks partial custody of the following child: Felicia Marie Angeloff, currently residing at 401 Boyer Street, Summerdale, Cumberland County, Pennsylvania, age 9 months. The child was born out of wedlock. The child is presently in the custody of Pamela M. Angeloff, who resides at 401 Boyer Street, Summerdale, Cumberland County, Pennsylvania. During the past nine months, the child has resided with the fOllowing persons and at the following addresses: Peraons Address ~ Pamela M. Angeloff 401 Boyer Street Summerdale, PA birth-present Fran Angeloff 401 Boyer Street Summerdale, PA birth-present The mother of the child is Pamela M. Angeloff, currently residing at 401 Boyer Street, Summerdale, Cumberland County, Pennsylvania. She is single. . ; The father of the child is Corbett S. Smith, currently residing at 96 Regency Woods North, Carlisle, Cumberland County, Pennsylvania. He is single. 2. The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with the following persons I Cathy Smith Relationship Mother ~ 3. The relationship of Defendant to the child is that of mother. The Defendant currently resides with the following persons I Felicia M. Angeloff Fran Angeloff Relationshio Daughter Mother ~ 4. 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 to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 5. The best interest and permanent welfare of the child will be served by granting the relief requested because Plaintiff wishes to establish a relationship with his daughter and have regularly scheduled contact with her. 2 I~ . . ~ 6. 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. WHEREFORE, plaintiff requests the Court to qrant him partial custody of the child. ~li CINDY E. Attorney .D. No. P. O. Box 267 Enola, PA 17025 (717) 732-7971 Attorney for plaintiff Date: October ~~, 1995 3 . , CORBETT S. SMITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 95-6213 PAMELA M. ANGELOFF, Defendant CUSTODY/VISITATION .... NOW, th" h~ of 199~ the parties having stipulated to the entry of an Order of Custody, it is hereby ORDERED AND DECREED that the attached Custody Agreement regarding the custody of the minor child, Felicia Marie Angeloff, shall be entered as an Order of Court. J. i'r. C) f.. r .. ~!:i! , I ; r:i , . ,. ~f, l.:_~ I ",i - , ., , :~ "'. ~l. , . . fO' , J c_ ". ' , 0 . l .. . ~ CORBETT S. SMITH, plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 95-6213 PAMELA M. ANGELOFF, Defendant CUSTODY/VISITATION I THIS AGREEMENT, CUSTODY AGREBMBNT made this ~ I p..f day of lLu-(~A./, 1995, by and between plaintiff (hereinafter "Father"), and the Defendant (hereinafter "Mother"), concerns the custody and visitation of the minor child born to them, Felicia Marie Angeloff. WHEREAS, Mother and Father desire to enter into an Agreement as to the custody of the child, Felicia Marie Angeloff, and to have this Agreement made an Order of Court by the Court of common Pleas of Cumberland County, Mother and Father agree as follows: 1. Mother and Father shall have joint legal custody of the minor child. 2. Mother shall have primary physical custody of the minor child subject to visitation by Father. 3. Father shall have visitation at the following times: a. every Wednesday evening for one and one half (1- 1/2) hours, the specific times to be agreed upon by the parties/ b. alternating Saturday afternoons for three (3) hours, the specific times to be agreed upon by the parties/ c. any other times which shall be mutually agreed upon by the parties at a later date. . , . 4. Mother and Father agree to notify each other if there is any change to the schedule outlined above. 5. Father will visit the child at the Mother's residence. Father will corne alone for visitation at the Mother's residence. 6. Mother agrees that Father shall be given private time with the child during his visitation. 7. Mother and Father agree to cooperate to create an environment during the visitation which will promote a healthy and loving relationship between Father and the child. B. Mother and Father agree to consult with each other and to each have equal input with regard to any major decisions which will impact upon the child's academic progress and/or physical or mental health. 9. Mother and Father acknowledge that it is in the best interest of the minor child that she have the benefit of each parent's parental guidance and each agrees to refrain from allowing the child to be exposed to the personal animosities that may exist Letween each other. 10. The parties understand that this Agreement is structured in order to accommodate the needs of the child as an infant. At a time in the future when the child is older, Father may wish to alter this arrangement for more liberal visitation or partial custody of the child. If the parties are unable to agree on alternative arrangements, either party may petition the Court to amend this Agreement. .2.