The URL can be used to link to this page

Home My WebLink About96-01503 " , 4 j .......'"" ". , . i l. ' v ' , ::\! J c3 r'll <::) '"" ~ . ........",. , ~ \::)-- ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DAVID CARNES, CIVIL ACTION. CUSTODY Plaintiff v. CA No 96.1503 MECHELLE COLLEEN CARNES, Defendant RULE AND NOW,~, 1996, upon consideration of the within Petition for Leave to Withdraw as Counsel, a RULE is granted on David Carnes and R'QJI'J~Aad. Mechelle Colleen Carnes, to show cause why the Petition for Leave to Withdraw all Counsel should not be granted. "",\~,..,' Rule returnable lh. .1,'0 IS' d,...~.f$eJ"'cc.. B_J If 100"- !:It ~fgl\lgh .... Cuu.lnol'vuL rr.a. It "h_ rllmh,arlnnci COllnt f'nllrthnIlQp, ('!l..li~lp P.....-(j~,I..[l~;~ gal~~!. BYTHECOURT: J. ofj,n 1. >- ", [- " lJ.)' (,.; , . i:jn " .. l C ') '-' I -.. L... , 1--. .. ,.-; lL LJ '''': , j :~'") '"' UI ...1 0< w W IX '" 8 110 UI ...1 ... Qj.., << >- Ql l'l l'l '"' 0: "'" ~~ Q l'l ... Ql U ~ ~ .... ~ 0 ",'0 W Ie .... U l'l 0- ~j~~ rn .., 0 rn , p .... c ~ ~<s:li ~~ u .., Ql UI IX Ql Ql Ql 0 ~~ II -110 ....1>:: ~ iM Q rn .... ........ zo<z ral 0 :z ~~ <<"'0 :z u 0 ~~ o.lZ... IX '"' < !Xl Illl..:.... 0< Qj .... ~ w>u u . .... << ~>l0< > .... u .. Q Ql '"' 2: In,,] ... .., ...1 u~r:: > u 0- .. 0< Ql 0- J&.ral... 0 Q X 0< , <. . .' t j, ~ r)f . * o~"c\ :IN THE COURT OF COMMON PLEAS OF C.~II\ 1_> Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA . . V :CIVIL ACTION - LAW . * :NO. ttl IS(ij CIVIL 19 M<<L,.d, (,IIi\- (- ~ Defendant :CUSTODY/VISITATION ORDER OF COURT ~I\." < l. ;;;.J I'f/~ AND NOW, this (date)' , upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before II~ h.., r J-.. b /"", r- :c, the conciliator, at L I,'" (,'HI f t" (,",'. ,.....". on the ,t;th day of . I , 19 'it- , at ,NI H., for a Prehearing Custody Conference. At such conference, an errort will be made to resolve the issues in dispute; or ir this cannot be accomplished, to derine and narrow the issues to be beard by the court, and to enter into a temporary order. Either party may bring the child who is tbe subject or this custody action to the conferen.ce, but the cbild/children's attendance is not mandatory. Failure to appear at the conrerence may provide grounds ror entry of a temporary or permanent order. , FOR THE COURT: By: YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAIfYER 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 COURTHOUSE, FOURTH FLOOR CARLISLE PA 17013 (717)240-6200 i [' ~ v u -t ? ~- '~ - . ',~ , Cl ' ~ HI 0 r' 4, --r rf' '1' u J ~ c r' ~~ f"" u \{" 00 rr1 l." r. ~'l -:r r ) :..J r:- ::r- -:p .. .' L" ,- . "fi' -It :l '( .;) 0< W ~ 11- Z o . ~~ 8~ o r..o o E- SLoe llllO<I-< c~z OllllO< ow> we~ :ceCIl E-O~ zr..w 1-<011- z o I-< E- o 0< ...1 .... > . ....0 oz >- l::l o E- UI C o .... .... .... .... r:: .... .. .... .g., UI w z pr; 0< o l::l I-< > 0< l::l . > . CIl '" z.... llllC:: 0<.. 0'0 c:: ZQI "'.... WQl ~l::l ~ o o W ...1 ~ '" tE: o W X >- l::l o E- UI C o IX o r.. E- :z I-< .c ...1 g., X o o 1,,1. , r,,-d"1 .>- 1 , -,'-, 0: ~ ~ ~ !::: :;!.3~~ bi<~'ti . >'dl31 :s e .S ~~~] ~< ell ~ Z i!~ l!Z ~~ F:'F:' -- '""'"" -- ~~ wr'otp t.o n.t,torney St.llllpf' H"i to thp !..:;.t,l\t:lI~ or his rt~prf'~{'ntf\t.ion. S~e corl'Pspnndencl' att'J\chpd HH E,\.hibit D which i~ incol'poratpd by refe,'ence, 4. When t.hE' mot.h..r WII~ se,'vpd wit.h the Rule of September 4, 1996, whirh WIIS grllnt.ed on her IInd t.h.. father t.o show cause why Attorney St.1I1ler's Pet.ition for Leave t.o Wlthdrllw as Counsel should not be granted, she did the following: a) Showed t.he fllther the Rule, Proposed Order, IInd Petit.ion for Leave t.o Wit.hdraw as Counsel. bl Asked the father to put his response in writ.ing; on September 15, 1996, he wrot.e a statement that he no longer wanted Scott St.aller to represent him in t.he above captioned cu~tody cnse. See Exhibit E attached and incorporated by reference. cl Explained to the father that her attorney, Joan Carey of Legal Services, Inc., would negotiat..e with him directly to finalize the Custody case; the mother understood that., Scott Staller would no longer repr'esent the plaintiff and thRt she and her IIttorney would negotiate directly with him. See Exhibit E and F att.ached Rnd incorporat.ed by reference. 5, The mot.he,' is nut oppos..d t.o this Court's granting Scot.t Stall..r, nt.t.ul'll<'Y of record for t.he plaint.iff, permis~lon to withdraw as Counsel for t.he fat.her. WHEREFORE, t.h.. def..ndllnt/re~pondent requests t.hat the Court DAVID CARNES, Plaintitt IN TliE COURT OF COMMON PLEAS OF CUMBERLAND COUNT V , PENNSVLVANIA v. NO. 96-1503 CIVIL TERM MECHELLE COLLEEN CARNES, Defendant CUSTODY CUSTODY ORDER AND NOW, this c.tt. day 01' lt~, 1996, upon consideration 01' the parties' Consent Agreement, the following Order is entered with regard to custody 01' the parties' children, Joshua Eugene Carnes (DOB:5/15/89) and James Robert Carnes (DOB:10/3/91). 1. The detendant, hereinafter referred to as the mother, and the plaintiff, hereinafter referred to as the father, shall share legal custody. 2. The mother shall have primary physical custody. 3. The father shall have partial custody 01' the children, according to the following schedule: a. One week vacation during the summer at a time he has 01'1' from work and upon reasonable notice to the mother. b. Four weekends during the children's summer vacation at times agreed upon by the parties. c. Other times agreed upon by the parties. 4. The father and mother shall alternate custody on holidays according to the following schedule: a. The mother shall have Easter, Fourth of July, and Thanksgiving Day in even numbered years and the DAVID CARNES, PlaintiH IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 96-1503 CIVIL TERM MECHELLE COLLEEN CARNES, Defendant CUSTODY CONSENT AGREEMENT fA .., 1 This Agreement is entered on this 'I day of . .J:J,y,.. f,zy 1996, by the defendant, Mechelle Colleen Carnes, and the plaintiff, David Carnes. The defendant is represented by Joan Carey of Legal Services, Inc.; the plaintiff is unrepresented but is aware of his right to have an attorney. The defendant, hereinafter referred to as mother, and the plaintiff, hereinafter referred to as father, agree to the entry of the following regarding custody of their children, Joshua Eugene Carnes (DOB:5/15/89) and James Robert Carnes (DOB:10/3/91). 1. The defendant, hereinafter referred to as the mother, and the plaintiff, hereinafter referred to as the father, shall share legal custody. 2. The mother shall have primary physical custody. 3. The father shall have partial custody of the children, according to the following schedule: a. At times when he has vacation from work during the summer months of June, July, and August and upon reasonable notice to the mother. b. Other times agreed upon by the parties. 4. The father and mother shall alternate custody on holidays according to the following schedule: