HomeMy WebLinkAbout96-00904
"
'"..,
~
~
Q.I
E
...... .
on
7'
~
ifJi
~ .
-fJ
oJ
?
"
"
'l
, -
",
')
/
I
,
.J'
./
/
n
~
~
J
-r
o
CT
3
u,
.1
JOYCE METZGERo
Plaintiff
vs.
RONALD METZGERo
Defendant
AND NOW, this
lfo
day of
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION. LAW
NO. 96,904 CIVIL TERM
CUSTODY /VISIT A TION
ORDER
o 1996, upon receipt 0'
ths ConciliatorOs Reporto it appearing that the parties ave agreed to the terms and
provisions of this Order which was dictated in their preaence and approved by them
and their counselo it is hereby ordered and directed as follc,ws:
.
t
r
j
I
!
1
',I
r
1. The parties shall share legal custody of the minor childo
Dustin A. Metzgero d.o,b. 9 December 1993.
2. Mothsr shall have primary physical custody of the minor
child subject to periods of partial custody and visitation with Father as
follows:
A. On alternating weekends beginning on Friday at 1 :00
~
p.m. until Sunday at 1 :00 p,m. This alternating weekend
schedule will begin on 17 May 1996.
I
t:
f
! I
3. The partids shall alternate the major holidays, those holidays
being defined as Eastero Memorial Day, Fourth of July, Labor Dayo and
f'
.
, .
Thanksgiving. The alternating schedule will begin at 9:00 a,m. and
end et 8:00 p.m. This alternating schedule will begin with Father
having Memorial Day in 1996 and the schedule will alternate
thereafter. These holiday periods of custody and visitation will take
~
I
precedence over the other schedule.
4. The parties shall share the Christmas holiday. Mother shall
have custody of the child from Christmas Eve until 10:00 a.m. on
Christmas day. Father shall have the child from 10:00 a.m. on
Christmas day until 26 December at 10:00 a,m.
5. Mother shall have the child on Motheros Day, and Father
6, Each party will be entitled to two non-consecutive weeks of
shall have the child on Father's Day. These periods of partial custody
and visitation shall occur from 9:00 a.m. until 8:00 p,m. and will take
precedence over any other schedule.
vacation with the child during the summer months. Fathsr shall
provide Mother with his weeks no later than April 1 st of each year,
and Mother thereafter will provide Father with thirty (30) days notice
as to the weeks in which she intends to exercise her periods of
summer vacation with the child. In 1996 alone Father shall provide
Mother with his wseks by 15 May 1996, The parties understand that
these weeks are to bs utilized if they actually have vacations 80 that
they can be with the child exclusively on vacation.
7. Such other times as the parties may agree./
BY THE COURT. /
,
/'
I
J.
4
~~
Jeanne Bereznickio Esquire
A ttorney for Plaintiff
Harold S. Irwino 11I0 Esquire
Attorney for Defendant
mlb
\!
--
vs.
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
JOYCE METZGERo
Plaintiff
RONALD METZGER,
Defendant
CIVIL ACTION. LAW
NO. 96-904 CIVIL TERM
CUSTODY /VISIT A nON
JUDGE PREVIOUSLY ASSIGNED: None (No Judicial Conflicts)
CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915,3-8(b)0 the undersigned Custody Conciliator submits the
following report:
1. The pertinent information concerning the child(ren) who is(are) the
subject of this litigation is as follows:
NAME
BIRTHDA TE
CURRENTLY IN
CUSTODY OF
Dustin A. Metzger
9 December 1993
Plaintiff
2, A Conciliation Conference was held on 9 May 19960 and the following
individuals were present: the Plaintiff and her attorney, Jeanne Bereznicki, Esquire;
the Defendant appeared with his attorneyo Harold S. Irwino 1110 Esquire.
3, Items resolved by agreement: See attached Order.
4, Issues yet to be resolved: See attached Order.
1
5. The Plaintiff's position on custody is as follows: Plaintiff was reluctant to
allow overnight visitation because of her perceived problems with the cleanliness of
DefendantOs residenceo but she did ultimately agree to the alternating weekend
schedule.
6. The DefendantOs position on custody is as follows: See attached Order.
7. Need for separate counsel to represent child: None requested.
8. Need for independent psychological evaluation or counseling: Neither
party requested and the Conciliator does not believe any is necessary.
Date: 10 May 1996
~;J 1 J!:' ;;J
Mic ael L. Bangs 1-
Custody Conciliator
2
. r~
'"''
I:n
.
,
I~." ...1,',.........,.\
, '
i ,
( :
I;
\
f.'
I'
".
,.
\'
~
I
.
'J
I,
,
I ~i
I
, '
. "
.
~
. )
\..)
,
~
...,.
,
.~\
,:.J
~
"'t
~! I: ~ ~
<II! ill i~~~
.:I ~ :I =,....
'""1.it:~:E
:Ill ! < ~':;
C.) ~ U
; <II!
~
Ai
,
11
i ! JOYCE
it
II
I RONALD
A METZGER,
Plaintiff
I IN THE COURT OF COMMON PLEAS
I OF CUMBERLAND COUNTY, PENNSYLVANIA
I
) ...,.-
: NO. 'h~ tie I (l'i"I:( /."._
I
I CIVIL ACTION - LAW
I IN DIVORCE
V8.
METZGER,
Defendant
,OTICE TO DEPEND AND CLAIM RIGHTS
I You have been sued in court. If you wish to defend against
,
the claims set forth in the following pages, you must take prompt
action. You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be
,entered against you by the court. A judgment may also be entered
lagainst you for any other claim or relief requested in these papers
IbY the Plaintiff. You may lOBe money or property or other rights
!important to you, incLuding custody or visitation of your children.
I
II When the ground for the divorce is indignities or
I irretrievable breakdown of the marriage, you may request marriage
counseling.
A list of marriage counselors is available in the
Office of the Prothonotary at the Cumberland County Courthouse,
Carlisle, Pennsylvania.
II
II
II
II
II
"
I
'I IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYERoS FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCn. IF YOU 00
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE T8B
OFFICE SET FORTH BELOW TO FIND OUT WHBRE YOU CAN GET LEGAL 8BLP.
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
ONE COURTHOUSE SQUARE, 4TH FLR
CARLISLE, PA 17013
(717) 240-6200
!i,
-,
/:
I:
JOYCE A METZGER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PENNSYLVANIA
vs.
:
I
I
I
I
CIVIL ACTION - LAW
IN DIVORCE
NO. tJ(,. ... '),) '1 CLl".;i
/." (..4"_
RONALD METZGER,
Defendant
COMPLAINT IN DIVORCB UNDBR SBCTIONS 3301(c) or 3301(d)
OF THB DIVORCB CODB
The Plaintiff, Joyce A Metzger, by and through his attorneys,
The Law Offices of Patrick F. Lauer, Jr., makes the following
Complaint in Divorce:
1. The Plaintiff, Joyce A Metzger, is an adult individual who
currently resides at Lot 3, Box 23, Evandale Court, Carlisle,
Cumberland County, Pennsylvania 17013.
2. The Defendant, Ronald Metzger, is an adult individual who
currently resides at 299 Greason Road, Apartment 2, Carlisle,
Cumberland County, Pennsylvania 170130
3. The parties have been bona fide residents of the
Commonwealth of Pennsylvania for at least six months immediately
prior to the filing of this Complaint.
COURT I - DIVORCB
4. Plaintiff incorporates by reference Paragraphs 1 through
3 above as if fully set forth herein.
5. The Plaintiff and the Defendant were married on December 3,
1993 in Carlisle, Pennsylvania.
6. There have been no prior actions of divorce or for
annulment between the parties.
7. The marriage is irretrievably br.oken.
B. The Plaintiff has been adviBed that counseling is
available and that the Pl_intiff may have the right to request that
the court require the parties to participate in counseling,
COURT II - CUSTODY
9. Plaintiff incorporates by reference Paragraphs 1 through 3
above a* if fully set forth herein.
10. Plaintiff and Defendant are the parents of Dustin A
Metzger, born December 9, 1993.
11. From his birth until early September 1995, when the
parties separated, Dustin has resided with his mother, Plaintiff
Joyce A Metzger, and his father, Defendant Ronald Metzger.
12. After early September 1995, Dustin has resided with his
mother, Plaintiff Joyce A Metzger.
13. Plaintiff believes that it would be in the best interest
of Dustin if Plaintiff is granted custody of Dustin with limited
rights of visitation to Defendant.
I
,
r
i
r
I"
.,
,
,
,
'.
WHEREFORE, the Plaintiff requests the court to enter a decree
of divorce, and the Plaintiff further requests the court to
incorporate any Stipulation reached by the parties regarding the
custody of Dustin Metzger into the divorce decree, or, should the
parties fail to reach such an agreement, to enter an order of
custody which the court finds to be in the best interests of the
minor child.
ly submitted,
Date I 2.//thL
B 'an J puhala, Sr.
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011
lOll 52677 Tel. (717) 763-1800
......- .
VERIFICATION
I, V;v<:.1I. A /Y6'T"fL"8~ , state that I am the Pl,4loU'/,AjI'::
in the above-captioned case and that the facts set forth in the
above Co,., lfJ"'A~ 'ate true and correct to the best of DIY
knowledge, information, and belief.
I realize that false
statements herein are subject to the penalties for unsworn
falsification to authorities under 18 Pa. CoSo S 49400
~ ' i}""", ~t ...1
.
.
Date I z.//? / p~
"."
,..
llIl
...
cl~ =
!l~M2!'~~
:s...cn~,!(7
.. ~'3"''''
,... cc-:re
"GI ~it:'
~~~~F.
~~ N U
~
". ,
I IN THE COURT OF COMMON PLEAS
I OF CUMBERLAND COUNTY, PENNSYLVANIA
I
I CIVIL ACTION - LAW
I
I NO. 96-904 CIVIL ACTION
I CUSTODY/VISITATION
ORDER OF COURT
AND NOW, this _Mt.,( I,d?' len' , upon consideration of the
JOYCE ~tETZGER,
Plaintiff
vs.
RONALD METZGER,
Defendant
attached complaint, it is hereby directed that the parties and
their respective counsel appear before ~ j (L.". I I 15,",0'" \ r ~I ,
the conciliator, at 3<'" ~. IOS 11, ')./ (c,,"y 0; II , on
the ~ 11.
M"./
.
1996 at
q;ctJ/l .M., for
day of
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 iesues to be heard by the
court, and to enter into a temporary order. Either party may bring
the child who is the subject of this custody action to the
conference, but the child/children's attendance is not mandatory.
Failure to appear at the conference may provide grounds for entry
of a temporary or permanent order.
r,;;;,
~
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 W!lERE YOU CAN GET LEGAL HELP.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, FOURTH FLOOR
CARLISLE, PA 17013
(717)240-6200
i
t
1
i
, ,
!
!
i
I
,
,
;
.
,
1
"
,
\
v..
I
I
I
I
I
I
I
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
NO.
9(, _ 90.," ('LJ~ 7.i.-
n
r;
JOYCE A METZGER,
plaintiff
RONALD METZGER,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
-""
C:i.: .
,()
c'
.,.,
~,.,
I;J
l"
Cl
r.: ~:.
NOTICB TO DBFEND AND CLAIM RIGHTS f~~.
; ." ~ .
If you wish to~defena
.:.-: c..)
- -
claim. set forth in the following pages, you must take
~
o
'Il \
,-,
':'I~
,]~
;.T~;J
.-;. (I')
"- "
aliainst
:q
.....
prompt
You have been sued in court.
the
action. You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be
entered against you by the court. A judgment may also be entered
against you for any other claim or relief requested in these papers
by the Plaintiff. You may lose money or property or other rights
important to you, including custody or visitation of your children.
When the ground for the divorce is indignities or
irretrievablA breakdown of the marriage, you may request marriage
counseling. A list of marriage counselors is available in the
Office of the Prothonotary at the Cumberland County Courthouse,
Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPBR TO YOUR LAWYER AT ONCB. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BBLOW TO FIND OUT WBBRB YOU CAN GBT LEGAL BBLP.
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
ONE COURTHOUSE SQUARE, 4TH FLR
CARLISLE, PA 17013
(717) 240-6200
\
I
,
I
I
\
I
t
JOYC! A MBTZGBR,
plaintiff
I IN TBB COURT or COMMON PLBAS
I OF CUMBERLAND COUNTY, PBHNSYLVANIA
I
I NO.
I
I CIVIL ACTION - LAW
I IN DIVORCE
v..
ROllALD MBTZGER,
Defendant
COMPLAINT IR DIVORCB UNDBR SBCTIORS 3301(0) or 3301(d)
OP 'l'BB DIVORCB COOl!!
The plaintiff, Joyce A Metzger, by and through ni. attorneys,
The Law Offioes of Patrick F. Lauer, Jr., III&kes the following
Complaint in Divorce I
1. The Plaintiff, Joyce A Metzger, is an adult individual who
currently resides at Lot 3, Box 23, Bvandale Court, Carlisle,
Cumberland County, pennsylvania 17013.
2. The Defendant, Ronald Metzger, is an adult individual who
currently resides at 299 Greason Road, Apartment 2, Carlisle,
Cumberland County, pennsylvania 17013.
3. The parties have been bona fide residents of the
Commonwealth of Pennsylvania for at least six months immediately
prior to the filing of this Complaint.
COURT I - DIVORCB
4. plaintiff incorporates by reference Paragraphs 1 through
3 above as if fully set forth herein.
5. The Plaintiff and the Defendant were III&rried on December 3,
1993 in Carlisle, pennsylvania.
6. There have been no prior action. of divorce or for
annulmant between the parties.
7. The marriage is irretrievably broken.
8. The plaintiff has been advised that counseling is
available and that the plaintiff may have the right to reque.t that
the court require the parties to participate in counseling.
COURT II - COSTODY
9. Plaintiff incorporates by reference Paragraphs 1 through 3
above as if fully set forth herein.
10. Plaintiff and Defendant are the parents of Dustin A
Metzger, born December 9, 1993.
11. From hiB birth until early September 1995, when the
parties separated, Dustin has resided with his mother, plaintiff
Joyce A Metzger, and his father, Defendant Ronald Metzger.
12. After early September 1995, Dustin has resided with his
mother, plaintiff Joyce A Metzger.
13. Plaintiff believes that it would be in the best interest
~
of Dustin if plaintiff is granted custody of Dustin with limited
rights of visitation to Defendant.
""
VBRIPICA'1'10H
I, V:Y<:'~ A /'IAT"tL'4__ , .tate that I AlII the jOl.4l,."r/~~
in the above-captioned case and that the fact. set forth in the
above ~1It ~I..A~ -a.t~ true and correct to the be.t ot my
knowledge, information,' and belief.
I realize that false
.tatements herein are .ubject to the penalti.. tor unsworn
falsification to authoriti.8 under 18 Pa. C.S. S 4940.
~.il~~.~
Datel z.//.,/p~
.'
.
'.).