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HomeMy WebLinkAbout95-07097 - ~ .;) 0J ., -~ -0 .~ o ~ J I' ~ . ~;:! "c.;..,~.'t ,~,....\"~,y,J\i}W\"':~;'1()~~~;::",,l,i'3_"';'i'.-' i:UG 2 2 1996tr 1CJIRBN BLIZABBTH GEIDEL Petitioner , IN THE COURT OF COMMON PLEAS OF ,CUMBERLAND COUNTY, PBNNSYLVANIA , 'CIVIL ACTION - LAW , , ,95 - 7097 CIVIL TBRM 'CIVIL ACTION - CUSTODY V VIRGIL BVBRETT GBIDBL Defendant OfCO~.~ AND NOW, this 2 cS" day ~, 1996, the Conciliator being advised that no conciliation hearing is at this time rescheduled, the Conciliator relinquishes jurisdiction. The parties may file another petition to have a conciliation scheduled. re VlNV,\1). t:NN?d JY"~-- ,., :';':-i~!"5~"'n" . , .-~:/i v Gl:1/ 1:1 LZ :;fl~ 96 ,\UV~li .J, l:.vjj i-u :iO ,i" .:lOI:b'O-0311:J oil , . . KAREN ELIZABETH GEIDEL Petitioner v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION - LAW 95- 7097 CIVILTERM IN CUSTODY VIRGIL EVERETI GEIDEL Respondent ORDER m: COURT AND NOW. this \4-th day of lXl 'mn~,... . 1995, upon consideration of the att~hed petition, it is hereby direc1ed that the parties and their respec1ive counsel ap ear before _ ~~~; ~~~~ . Esquire, the conciliator, at Lv . , G C J ~rn, on the.~"'day of 7wlI...",rt., 199 , at lS!.s..J/7.~' _ . 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 this conference may provide grounds for entry of a temporary or permanent order. The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodation 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, YOU SHOULD TAKE mls 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 Cumberland County Courthouse, 4TH Floor Carlisle, PA 17013 (717) 240-6200 OF TH~~TAAY 95 DEe, 8 PH 3: 29 CUMpsgAIAND COUNTY ENNSYlW-N1A ,,-I{-<15' !!Pi t4f1. m;.J,! -tP';;:/; 'p1C~ I~ 'It .t1,5' t. ~ ~ dt/;!. Ii). 'It,t)S' ~ ~ .#.. ~. ~ f& . KAREN ELIZABETH GEIDEL Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . . v. . . CIVIL ACI'ION - LAW . . VIRGIL EVERE'IT GEIDEL Respondent . . 95- CIVIL TERM IN CUSTODY PETITION FOR CUSTODY AND NOW, comes the Petitioner, Karen Elizabeth Geidel, by and through her attorneys, Irwin, McKnight & Hughes, and files this Petition for Custody, making the foUowing statement: 1. The Petitioner is Karel. Elizabeth Geidel, an adult individual currently at 178 Red Tank Road, Boiling Springs, Cumberland County, Pennsylvania 17007, 2, The Respondent is Virgil Everett Geide~ an adult individual residing 178 Red Tank Road, Boiling Springs, Cumberland County, Pennsylvania 17007. 3. The parties were married on September 20, 1986, and three children were born to this marriage: Joshua Paul Geidel, born 9/14/87; Kaila Elizabeth Geidel, born 6/20/89; Katlyn Noel Geidel, born 6/9/91. : 4. On or about September 4, 1995, the Respondent moved out of the marital residence located at 178 Red Tank Road, Boiling Springs, Pennsylvania. 5. The Respondent remained out of the marital residence until Thursday, September 28, 1995 when he moved back into the marital residence, 6. Although the parties are currently residing together, the Petitioner will be relocating to a separate residence within the next couple weeks, and is desirous of beginning this custody action to resolve any disputes regarding custody as soon after the ultimate parties' separation as possible. 7. The Petitioner has been the primary caretaker of the children since their birth, and it is within the children's best interests for the Petitioner to have primary physical custody of the children, with periods of partial physical custody to the Respondent. WHEREFORE, Petitioner Karen Elizabeth Geidel, respectfully requests that she be granted primary physical custody of the parties' minor children, with periods of temporary physical custody to the Respondent. ",""'C'l;,'""',', Respectfully submitted, IRWIN, McKNIGHT & HUGHES Date: December 11, 1995 VERIFICATION The foregoing Petition is based upon information which has been gathcred by my counsel and myself In the preparation of this action. The language of the Petition may In part be the language of my counsel and not my own. I have read thc statcments made in this Petition and to the extcnt that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledgc, information and bclief. To the extent that the contents of the statements are that of counsel, I have rclied upon counsel in making this vcrification. I understand that false statcmcnts herein made arc subject to the penalties of 18 Pa,C.S.A Section 4904, relating to unsworn falsification to authoritics, ~cuwn ~a.bL~ ~cl-J KAREN E ETR GEIDEL t~ Datc: 1)eceaber II . 1995