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Home My WebLink About96-01548 ~ 3. ''"'~'''''''"''''''''''''~ '-- / / \ i-' ,. .. , \ :4. rJ - " , ~ ,..: ,., .. " ,... ~ .... ~"l ,.., ~~ ~I . :;J ~ en ~ .~~ >< iii .. ~ ~ .. ~l <( ~ = ~ .... U1 - ~ ..." i!~t ~~ :;J U .j!/l- ~ ~ t.l o , II ~ .. en ... WI - 014:; .~ ~ fJ) ~ ~ <( 1ft z 3:.1 <( III ~.. 1ft - . r.:~ w oC ~ C . ..:I ::l '" ~ cij z X ~ ~In . , - z . c.l ~ j II Z III ::l.. :2 ~ 1.&1 0 ... - !/Ill ~ II ~ U1 _ 0 II 0" H fjj I&. 0( Z .. Z · ~ 5~~ ~ I&. U .. ~ ~ - 8 - Z Il: N U Cl . v. IN THE COURT Of COMMON PLIAS or CUMBERLANO COUNT~, PENNS~LVANIA CIVIL ACTION - LAW DENNIS E. WILSON, PlaintiU CHlUSTINE P. WILSON GRABAU, Detendant NO. I.- ", 'I ,. CIVIL TERM IN CUSTODY OROER OF COURT AND NOW, f"'\ ,. ,I )) I I i upon coneid.ration ot the attached complaint, it ie hereby direoted that the parties and their raspective counsel appear betore 11,\1,., t '" (",\iL/ t'~1 , the conciliator, at '1Ih I"k-., (, ",h (,' (,. ,,\"".. on the ,95'lh day ot Ill: . I 1996 at 10 'J,,' rt .m., for a pre-Hearinq CUstody Conterence. At such conference, an effort will be made to resolve the issues in dispute; or if this oannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children aqe five or older may also be present at the conference. Failure to appear at the conference may provide qrounds for entry of a temporary or permanent order. FOR THE COURT, A J /",,- , ",/", 1 ../ - 7 .. (-- 1,''/ y.." By: ;l/ ~jl vi, ), lJi(;/J (:&/, custody concil!ator ~-~;1J YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 00 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 Fourth Floor Carlisle, PA 17013 (717) 240-6200 DENNIS E. WILSON, PlaintiU IN ~HE COURT 0' COMMON PLEAS 0' CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW CHRISTINE r. WILSON GRABAU, Defendant NO. 'n /, I i CIVIL TERM IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Dennis E. Wilson, an adult individual currently residing at R.D. 1, Box 223, New Bloomfisld, Perry County, Pennsylvania, and who has a mailing address of P.O. Box 456, New Bloomfield, Pennsylvania, 17068, 2. Defendant is Christine F. wilson Grabau, an adult individual currently residing at Building 4, Apartment 227, Long Meadow Estates, Camp Hill, Cumberland County, Pennsylvania. 3. The parties are the natural parents of Amanda F. Wilson, born November 25, 1986. 4. The parties are subj~ct to an Order of Court entered in the Court of Common Pleas of the 41st Judicial District of Pennsylvania - Perry County Branch, said Order being attached hereto and incorporated herein by reference as Exhibit "A". 5. Plaintiff has had physical custody of the child for extended periods of time beyond the times provided for in the Order which is attached heret.o as Exhibit "A". 6. Since the entry of the aforementioned Order, which was entered by agreement, circumstances of the parties have changed to the point where it is in the best interest of the child to reside in the Plaintiff's primary physical custody. 1. The child had resided wlth the Detendant in Perry County, Pennsylvania, until approximately June 11, 1995. 8. Defendant moved to her present residence in CUmberland county, Pennsylvania, on approximately June 17, 1995, at a time when .he began re.iding with Robert Grabau, to whom ahe i. pre.ently married. 9. The Plaintitf resides with his fiance, Christine M. Barri~k, and hi. fiance's son, Ryan Barrick. 10. The Plaintiff is divorced. 11. The Defendant resides with the child at the aforesaid residence with her husband, Robert Grabau, 13. It is in the best interest and permanent welfare of the child to provide tne Plaintiff with primary physical custOdy of the child for the following reasons: (a) Plaintiff is better able to provide the child with the necessary care, custody and control in raising her in an appropriate environment: (b) Defendant has exhibited an appropriately care for the child and provide necessary guidance: (c) The child has expressed desires to be in the Plaintiff's primary physical custody: (d) Defendant has been physically, mentally verbally abusive toward the child: and (e) Defendant's present husband has been physically, mentally and verbally abusive toward the child. inability the child to with and I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING COMPLAINT AU TRUE AND CORRECT. I UNDERSTAND THAT rAl,sE STATEMENTS KAUIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DA'l'E;3-..J.\ -"" ~""N ( \Y~" DENNIS E. WILSON DENNIS E. WILSON, PlaintiH IN 'tHE COURT OF COMMON ?t.ZA3 or THE ~lST J~DICIAL OI3T~ICT. P!RR~ COUNT~ 3RANCH VS. NO. 94-121 CHRISTINE L. WILSON D.t.ndallt CIVIL ACTION - CUSTODY AGR!~ CONCERNING CUSTODY 'rh. wICS.rsiqn.d D.nnis E. wilson and cnristin. to. Wilson, father and .other r..pectively ot uanda r. Wilson, the subject of the aboVe r.t.r.nc:..s custody proc...sinq, h.r.by .91''' that the best inter..u and w.ltar. ~f A1Nnd. vouleS be s.rvec1 by the parti.. sharing legal custody .nd by vasting pri..ry physic.l c:ustodY in Cbristin. L. WUson, det.neS.nt, with riCJhta ot parti.l custody in Denni. E. wilson, pl.intiff, as follows: 1. Alt.rnating w.ek.nds beqinning S.turday .t 10:00 .... ancS .ndinq Sund.y at 6:00 p... eurinCJ the in .betw..n w..~.nd fath.r - -~ ..y bave a tew hours that coordinate with the child's sc:hec1ule. ,.. - , Z. Sh.rec1 ..jor holic14ys being Rew Years Day, East.r, Mamorial Cay, 4th of July, Labor Day, and=Tha~sgivin9' - 3. 'rh. chileS's birthday will be s~ed .-:.. ..... .. 4. ChristJllas to be split, alternating troll y.ar to year, on. part being Christmas Eve through Christmas Morning with the othar part being Christmas 1I0rninq through the rest at the day. Also, ona halt of Christmas vacation from school. 5. Two wee~s summer vacation with 3 weeks advanc. notice. 6. rath.r will have tne child Father's Oay and Moth.r will have the child Mother'S Day. ;/ J;l,h ,.~ ';'/ DENNIS E. WILSON, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUHBERLANDCOUNTY,PENNSYLVANIA . : v. . CIVIL ACTION - LAW . : CHRISTINE F. WILSON GRABAU, . NO. 96 - 1548 CIVIL TERM . Defendant : : CIVIL ACTION - CUSTODY , (1\. .., '1 AND NOW, this "" day of consideration of the attauhed Custo ordered and directed as follows: COUR , 1996, upon cilidtion Report, it is 1 . g is s~heduled in the abqye case on the 7 ~ day of'l< ,1996, at '1,JiJ,jY.m.inCourtroom',.".;L. of the Cu . erland County Courthouse at Carlisle, Pennsylvania. At this hearing, the Father, Dennis E. Wilson, shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the court and opposing counsel a memorandum setting forth the history of custody in this case, the issues currently before the Court, each party's position on the custody issues, a list of witnesses who will be called at the hearing, along with a summary of the anticipated testimony of each witness. This memorandum shall be filed at least ten (10) days prior to the hearing date. 2. All parties are directed to cooperate in an independent professional evaluation to be performed by an evaluator selected by legal counsel for the parties. Costs of the evaluation that are not covered by any insurance shall be split equally between the parties. 3. The parties shall meet again with the Custody Conciliator for a conference on July 18, 1996 at 10:30 a.m. cc: Bradley L. Griffie, Esquire R. Scott Cramer, Esquire Cu-fu.... .""'- <I-.J.J. s I J. cd q to ' ,.S t', f lid Fr~e, ]. DENNIS E. WILSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : v. : CIVIL ACTION - LAW : CHRISTINE F. WILSON GRABAU, I NO. 96 - 1548 CIVIL TERM Defendant I I CIVIL ACTION - CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The information pertaining to the child who is subject of this litigation is as follows: Amanda F. Wilson, born November 25, 1986 2. A Conciliation Conference was held on May 16, 1996, with the following individuals in attendance: The Father, Dennis E. Wilson, with his attorney, Bradley L. Griffie, and the Mother, Christine F. Grabau, with her attorney, R. Scott Cramer. 3. This case was originally in Perry County where there is an existing court order. However, Mother moved to Cumberland County and the parties are satisfied that Cumberland County is the appropriate location to litigate the matter. 4. Father is suggesting that the minor child has expressed a desire to live with Father. Also, Father feels it would be in the best interests of the minor child to come to live with him at this time. 5. The parties requested a hearing be scheduled in August in order to given them enough time to get an evaluation done in advance of the hearing, and also have a second conciliation conference in advance of the hearing. 6. The Conciliator recommends an order in the form as attached. ~/1~ I r~ Date . . DENNIS E. WILSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW : CHRISTINE F. WILSON GRABAU, : NO. 96 - 1548 CIVIL TERN Defendant : : CIVIL ACTION - CUSTODY ~t gm AND NOW, thi~ consideration of the attached Custody , 1996, upon Report, it is ordered and directed that the hearing scheduled in the above case for August 7, 1996 is cancelled and rescheduled until August 21, 1996 at 10:00 a.m. BY THE COURT, . Hoffer eel Bradley L. Griffie, Esquire R. Scott Cramer, Esquire i!..~ '?)t~ ]-). -90 ' "'~.'-' ,~ 1 I~Jti tr ! I .J ) j j ,il ..c-\ " DENNIS E. WILSON, . IN THE COURT OF COMMON PLEAS OF . Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW : CHRISTINE F. WILSON GRABAU, : NO. 96 - 1548 CIVIL TERM Defendant : . CIVIL ACTION - CUSTODY . PRIOR JUDGE: HONORABLE GEORGE E. HOFFER CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The information pertaining to the child who is subject of this litigation is as follows: Amanda F. Wilson, born November 25, 1986 2. A Conciliation Conference was held on July 29, 1996, with the following individuals in attendance: The Father, Dennis E. Wilson, with his attorney, Bradley L. Griffie, Esquire, and the Mother, Christine F. Grabau, with her attorney, R. Scott Cramer, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. 113t/tt.k Date . Gilroy, Esquire Conciliator DONIS E. ,tILSON, I Plaintiff I I V. I I CHRISTINJ: P. WILSON GRABAU, I Defendant I IN THB COURT OP COMMON PLZAS OP CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-1548 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY IN REI AGREDIBNT ORDER OF COURT AND NOW, this ~lst day of August. 1996, the perties appea~ing in open court with their private counsel, it is ordered and directed that joint legal custody of the parties' daughter, ~da, shall be vested in both parties. The Plaintiff, Dennis E. Wilson, shall hereafter have primary physical custody of the child. The parties are fU1'ther ordered and directed to prepare and submit to the Court a comprehensivs stipulation agreement providing for times of temporary physical custody for ~nda to be with her mother, Ms. Grabau. By the Court, Bradley L. Griffie, Esquir~ Counsel for Plaintiff t~~~ / .,.:~ Scott R. Cramer, Esquire ~/~/4p Counsel for Defendant .-t/J.I(,- n t :J 0 (-- C\ ',. ; ~ ~I -. -;1 [.:1 ',"J ".~'] i, , j,'J ,c;3 '''.-' ;, " . ;() -; :y ,.. ',,"') ; ..,rn .. j ~:) :.u f..j -< ~~ Islr