HomeMy WebLinkAbout95-07097
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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.
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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
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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,
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KAREN E ETR GEIDEL
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Datc: 1)eceaber II . 1995