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Home My WebLink About96-02748 ~~ ). L. .,J ~ ~ r- ~ ~:., ,.,j I' - , <;'~ ~ ~ ':#.~ ::;- , ~~ ' ' ~ v, it ~ III e ... r.l ,.. :! '" ~. to '. .... < 'n .' Z ..l . $ ~ <~t-~ . d)C tIl ~ >- . ~. ... CA.I... ~ ...... 0 '" r.l =0 ~ 0.: l:o " II .. ~ f- 0 .. ): ~.. z < " ~ (/) ~ X .. ..l , , ., . . ~. W" "iJ mae. '/! !(' 5,..;JIIl~ f';)'1.ft S' -dllf ft. ,', r-':"'I; ....'.". i: ' oil , , "''' , , , : '. '." " , U d'",' :L.', J;I,,\ (~,J" (.~ /1f.~~ ~ altf ?t_f.:.:, '7%-ttu ,?'h.Jto:l ~ ,-ttf (';17 r1 l:'- 1H,kfJ/ ~ .~4/ D...$.~ " , ' ,. '.. '.i ,I , , , 1):,'.:'1'.';,(."" ~ I,',' \ , ,,'1' "., I' \, \ ',' " 8. The father of. the chi Id Is t.he De f tHlllcHl t who resiclel:l at the addres6 set Ollt above. He is mar'!' ip.d to th.. Plaint Iff. 9. The molher of the ch lid is t.he Plaillt.1 f f who resides at t.he Ilc\dr'8ss sot out. i1boVH. StH! is marT i <?cl t.o the Defp.ndant.. 10. 'rhe Plaintiff is the natunll mot.hel' of t.h,. chi 1<1. Pldintiff currently resides wlt.h hor llIother, Bet.ty Myers, dge 69. II. The Defendant. is the nat.ural fat.her of t.he child. Defendant currp.ntly resides with t.he child. 12. The Plfllnt.iff has not. partlcipflt.ed as fl part.y or in any ot.her , I " i way in any I it.iqation Ii othl!r court.. II concHrning t.he cust.ody of the child in this or any The Plilint.iff has no inEol'mation of a (!ustody procoH,Hng concerning the child pending In a court of tllis or any ot.hHI jurisdiction. Plaintiff knows of no othHr pRrBon not. a party to thi6 action illready who ha6 physi(~id custody of or claims to have custody or I 'viBitation rJyhts with the saiel child. 13. The best interests flnd permanent welfare of the child will be SIH'ved hy gr'anting t.he rellt~r t'f!que:,;t.,~d by' Plaintiff for the following reasons: A. Plaintiff hilS heen the primary earetilker for the child Hinel! hi rtt!; A. It Is in Uw lH!Bt lnl ~r<'BI',H of tht> child to be in the, primary custody of the PIa illt iff; 2 !I II Ii II I ! COMMONWEALTH OF PP.NNSYLVANIA I ICOUNTY OF CUMBP.RJ.AND I I ) ( SS.: ) DERRA ANN BROWN, being duly sworn according to law, deposes and says that the facts set fo~th in the foregoing Complalnt for Custody are true and correct to the hcst of her knowledge, information, and belief. {]ji{tt.lt^-^-_ &:.illY'- DEBRA ANN BROWN Sworn to and subscribed befoI'e lIIe t.his I("/~ day of Mfi'f ' ]996. I 11!;Jk .__~ "'f.I\,,,,.., ..fJ ' NotaM' Pub.lic NuwIiaJ StJaI ~~~ld~ !oIyClm......,ElpuOAug. ~ I " '" 4 " ~~ ~~I i~~1 ~ .... ~; fI1~~ ... t .- .... i ,. t, '. ~ ~ .... ... . c > 'il .. . i~~~ ~~ ~ ;1 tHH '2l ~ :3 ~ . . '" '6 ~;~ ~ !i: .' I! Yl ~ '" . I " ~ ~ ~ 1\ \' , " , " . . . * '. , . . . ..... .. ...," .1 U N ~~ i) 18 ~16 (ill:\ .. .j lHi,: ,S 1q9Gdl1 . DEBRA ANN BROWN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENl~SYLVANIA vs. NO. 96-2748 CIVIL TERM GARY J. BROON, . . Defendant IN CUSTODY amBR Of' CXXlRT AND NCM I consideration of the directed as follows: " this 7. /,,,,l day of '),i._CJ*/ attached Custody conciliation!~epo _' it , 1996, upon is ordered and 1. A Hearing is scheduled in Courtroom, No. ~, , of the Cumber~and County Court House on the_i", 1'. day of i(;j;t'i1,j; (2.. , 1996, at 'I ,<(' o'clock, nll.m., at which time test y wJ.ll be taken in this case. At this Hea~ the Mother, Debra Ann Brown shall be deEmed to 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 each party's position on custody and also setting forth a list of witnesses who will be called to testify at the Hearing along with Ii summary of the anticipated testimony of each witness. The memorandum shall be filed at least ten days prior to the Hearing date. 2. The parties shall submit then~elvas and their minor Child to a custody evaluation. This evaluation shall be an independent evaluation performed by a professional selected by legal counsel for the parties. The purpose of the evaluation shall be to obtain an opinion on the various custodial disputes that have arisen between the parties. parties, schedule: 3. Pending further Order of this Court or agreement of the the Mother shall have custody of the Child on the following From June 20, 1996 at 9:00 a.m. until June 21, 1996 at 2:30 p.m. From June 27, 1996 at 9:00 a.m. until June 30, 1996 at 6:00 p.m. From July 4, 1996 at 9:00 a.m. until July 9, 1996 at 6:00 p.m. From July 17, 1996 at 9:00 a.m. until July 18, 1996 at 6:00 p.m. From July 25, 1996 at 9:00 a.m. until July 28, 1996 at 6:00 p.m. From August 3, 1996 at 9:00 a.m. until August 6, 1996 at 6:00 p.m. From August 14, 1996 at 9:00 a.m. until August 15, 1996 at 6:00 p.m. From August 22, 1996 at 9:00 a.m. until August 25, 1996 at 6:00 p.m. From August 29, 1996 at 9:00 a.m. until September 3, 1996 at 6:00 p.m. From September II, 1996 at 9:00 a.m. until september 12, 1996 at 6:00 p.m. From September 19, 1996 at 9:00 a.m. until September 22, 1996 at 6:00 p.m. From September 28, 1996 at 9:00 a.m. until October 1, 1996 at 6:00 p.m. From October 9, 1996 at 9:00 a.m. until October 10, 1996 at 6:00 p.m. From October 17, 1996 at 9:00 a.m. until October 18, 1996 at 6:00 p.m. From October 23, 1996 at 9:00 a.m. until October 29, 1996 at 6:00 p.m. The parties shall continue on a similar schedule thereafter with the Mother having custody of the Child on all of her days off from work plus additional days when the Mother is working the 11:30 p.m. shift to insure .. DEBRA ANN BRa'IN, Plaintiff IN THE COURT OF COOlIION PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 96-2748 CIVIL TERM GARY J. BROWN, Defendant IN CUSTODY QlS'lOOlt' CDlCILlATIaf SlMtARY REP(Rl' IN AC.CDml\NCB WITH <nmBRLAND aumr RULE OF CIVIL PIll) 't'" IQRB 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The relevant information pertaining to the Child who is the subject of this litigation is as follows: NAME BIRTHDATE CURRENTLY IN CUSTODY OF Karla Nicole Brown October 25, 1984 Defendant/Father 2. A Conciliation Conference was held on June 19, 1996 with the following individuals in attendance: The Mother, Debt ~nn Brown, with her counsel, Samuel L. Andes, Esquire, and the Father, Gary J. Brown, with his counsel, Arthur K. Oils, Esquire. 3. After much heated debate mainly between the parties' counsel, the parties were still unable to agree with respect to a permanent Custody Order. Therefore a Hearing will be necessary in this matter. 4. The Mother believes that the best interests of the Child would be served by the Mother having primary physical custody. The Mother expressed concern that the Father has made disparaging remarks concerning her in front of the Child and is generally disrupting the Mother-Child relationship. The Mother currently lives with her Mother approximately one mile from the Father's residence. She believes that she can provide a stable home environment for the Child. The Mother feels that she should not be penalized for leaving the Child in the Father's custody in the marital residence during the difficult period of the parties' separation in an effort to avoid confrontation and resolve the custody issue through the legal process. 5. The Father believes that the best int~rests of the Child would be served by the Father having primary physical custody. The Father believes the Child should remain in the marital residence to maintain stability. Th~ Father stated that he has a very close relationship with the Child. The t'ather indicated his belief that the Mother does not have sufficient time to spend with the Child due to time constraints imposed by her employment as a police officer. The Father expressed concern that the Mother is improperly involving the Child in this custody dispute by speaking r@ , I, '. ~i~ .... .... ~ ! ,I! .... j :d ~ ~ ~~ ~~ ~ ;11 la ~~~ ~ . . ~ Ili!1 ~ g] I !,~ . j I"J ~ ~ ~ 1!':i ~ - - .-_. _. -, .... 9.- . ~"' - ... ~ ~ ~ ~. J DEBRA ANN BROWN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 96-2748 Civil Term vs. GARY J. BROWN, Defendant CIVIL ACTION - I,AW IN CUSTODY ORDER Q.F COURT AND NOW, ,r~aY of September, 1996, upon agreement this of counsel, Samuel L. Andes, F.squire, Attorney for Debra Ann Brown, and Arthur K. Oils, Esquire, Attorney for Gary J. Brown, it is hereby Ordered that the custody hearing scheduled for September 25, 1996 is hereby continued. The parties are currently participating in a psychological evaluation being conducted by Arnold T. Shienvold, Ph.D., and it is hereby agreed between the parties that, upon receipt of the recommendationn 0f Dr. Shienvold, should either party feel the necessi ty for a hearing, il request to schedule the hearing will be made at that time, or in the alternative, a stipulated and agreed Order of Court shall be submitted to this Court. BY THE COURT: ( I, '~ , , i:"') \~ , ,,'''i " . [ '" I , "J ),7..1 .. g - ." .C" ~ , .,~ '.5 .. ...-, , ~1 .," ~-...; i,q - ,~~,'t .. .:-::~ J oj;- :~ , '. ,.i"'~,w,r~~'<'{~;~'i"l;YJ J!,:,;; ',~:~B \~ .' ~)i :,I;\~~::;;'~'~' :~~::?i~31t~ri~l~:f':~:' .; , "c' -II !/(;,,':"'ll1-,'h.,'tl ~~',v;- \vl-:, . 'l_','(',;",c';_"~It;i'ij"/-!/i~\'D') ,'.1,,> """"'j .d,_,I,-. ". ,-,.' ,. _'..,."", ;..,., "h,.I,'-e'_. l.r, ,., W'''1~_':',,'' hi\'_ibl-~ l:jiL'I~/.ik\f!':l' -"~~I:,:;,,:I{I 'J' ,t\'ntnkU1it~~~1;~I"'\\{t!Hiid \'~ll'ii~-;i'VilH;:':':r.~I~I!