HomeMy WebLinkAbout96-03606
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SAIDIS, GUIDO, I
SHUFF &
MASLAND i
l6 W, lhlh 5,=, I
Culblt,l'A
BOOtHE J. WRIGlrl' , I IN 'l11E CXXJRT OF ~ PLEAS O~"
Plaintiff I CUMBERLAND axJNTY, PmNSYLVANIA
I
vs. I 96 - i (.. () .... CIVIL TERM
JOHN A. WRIGllT , I
Defendant I IN OIVOJ{CE
AFFIDAVIT
I , Bonnie J. Wright
being duly sworn according
to law, depose and say'
(1) I have been advised of the availability of marriage
counselling and understand that I may request that the court
require that my spouse and I participate in counselling.
(2) I understand that the court maintains a list of
marriage counselors in the Prothonotary's Office, which list is
available to me upon request.
(3) Being so advised, I do not request that the cOI~rt
require that my spouse and I participate in counselling prior
to a divorce decree being handed down by the court,
I understand that false statements herein are made subject
to the penalties of 18 Pa. C,S, Section 4904 relating to
unsworn falsification to authorities.
Date:
b -,J.) 8&
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Bonnie J. Wrig t
t - 'l.k
~~iff
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SAII>IS, GUII>O,
SnUFF &
MASI.ANI>
26W, Iflllh!llrccl
Carib Ie, PA
BONNIE J. WRIGHT,
Plaint if f
IN THE COURT OF COMMON PL,~~AS OF
CUMBERLAND COUNTY, PENNSYlNAN LA
NO, 96-3606 Civil Term
v.
JOHN A. WRIGHT,
Defendant
IN DIVORCE
!lli.f);;N DANT ' S
AFJ?IDAVIT OF CONSENT. ACCEPTANCE OF SERVICE AND
lil1lYER OF NOTICE OF INTENTION TO REOUEST
ENTRY OJ? A DI~CE DECREE UNDER
SECTION 3301(cl OF THE DIVORCE CODE
1. A Complaint in divorce under Section 3301(c) of the
Divorce Code was filed on June 28, 1996,
2. Defendant acknowledges and accepts service of the
Complaint on July 5, 1996.
3. The marriage of Plaintiff and Defendant is irretrievabl
broken and ninety days have elapsed from the date of th~ filing
of the Complaint.
4. I consent to the entry of a final decree of divorce
without notice,
5. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not clai
them before a divorce is granted.
6. I understand that I will not be divorced until a divorc
decree is entered by the Court and that a copy of the decree wil
be sent to me immediately after it is filed with the
Prothonotary.
7. I have been advised of the availability of marriage
counselling and understand that I may request that the court
require counselling, I do not request that the court require
~()lll1se ) 1 in~.
I verify that the statements made in this affidavit are tru
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. Section 4904 relating t
unsworn falsification to authorities.
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6hn A. Wrig t
/' Defendant
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DIY, E..ter, Hemo.'lal DIY, July 4th, Llbor DIY Ind Thlnkl9lvlll9, It
the f.th.r 1. Ich.duled to work, the Hother .hlll hive cUltody of
the chlldren tor the hollddY, For Thlnkl9lvln9 1996, the f.ther
Ihlll h.ve the chl1dren,
C. ror Chrl.tm.., the father Ihlll have the chlldren fronl December 25,
1996 .t 10,00 I,m, to 9,00 p.m, December 26, 1996, each y..r,
0, The f.ther .hall alway. have the chlld 9,00 a.m, to 9,00 p,m, on
r.ther'. DIY' the mother Ihlll alwaYI have the chl1d on Hother'.
DIY, Thll 11 provld.d they Ire not workinq.
E. The p.rtlel Ihall each hllve a r.llonabl. period of tlme with the
chlldren on thelr pI rent '. blrthd.ye Ind on the child' I blrthd.y to
celeurate thel. eve~te,
r. The partle. ehall notlfy each other ln a tlmely faehlon, if lt 1.
nece...ry, due to an emerqency or unforeeeen clrcumetlnce for hlm or
h.r to be delayed It any of the timee eet out hereln.
It le
lntended, however, that tlme be of the e...nce, and that the p.rtl..
.. .trictly al poeelblo comply with the tlmee eot forth hereln.
0, Th. p.rtlee aqree thlt they wl11,
1. E.ch not ify the other parent when a chlld 1. away from the
chlld'. primary reeldence for more than two consecutlve n19hta
.nd will provlde an Iddree. and phone number where the chl1d
e.n be reaehed.
2. Both partles ehall promptly advlso eaeh other of the namee,
addresees nnd phone numbers at any babysltter. and the
.chedule at when the chlldren wlll be wlth the sitter.
3, The mother shall promptly provlde the father the name and
addre.a of any .chool the chl1dren are enrolled ln and the
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/lame <It thelr teachen and leader. tor any ectlvlty in which
the children are involued and keep him .dvi.ed ot .ny change.,
4. In the event the mother l. .cheduled to work any other d.y
which the father hu off, the mother .hall deliver to .nd pick
up the chlldren trom the t.ther'. and the tather .h.ll provide
childc.re whlle the mother la worklng,
H. The p.rtiea wlll notlfy .nd coneult wlth the other p.rty immedi.tely
in c..e. ot .....dical. III1lIIrgenclu th.t occur while the children .re in
their cUlltody.
I. Both p.rtlea agree to ..aure the chlldren attend .ctivitl.s
Bcheduled tor the chlldron durlnq thalr perlods ot ehsred cuetody,
euch .B but not limited to echool events, .ctivitiea .nd outingB,
BWimmlnq .nd other such lesaone, blrthd.y .nd other p.rtles to which
the children .re lnvited by thelr frlenda, Thll p.rties .gr"e to
keep e.ch other tlmely .dvlaed as to these evente .nd .ctlvitieB,
J. Neither p.rent eh.ll do .nythlng whlch m.y eatrange the children
trom the other p.rent or lnjure the opinlon ot the children a. to
the other parent, or whlch m.y h.mper the free .nd n.tur.l develop-
ment ot the chlldren love or .ffectlon for the other p.rent.
K. HUBband .nd wlte .cknowledge th.t It ls in the be.t interests ot the
children to h.ve ressonable .nd liber.l contsct with both parentB .0
st to malntain a norm.l p.rent-child rel.tionehlp with both parente,
L. The partles .qree th.t In m.klng thls Agreement, there h.. been no
traud, concealment, overro.chlng, coercion, or other untair de.ling
on the p.rt ot the other,
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JOIIII ~, WRIGHT,
Plaintiff, (in Quatody only,
Dafendant in divorQe)
IN THB COURT or COMMON PLB~B
cUMBERLAND COUNTY, FBNNBYLVAHI~
CIVIL ACTION - LAW
CUSTODY/VISITATION
va,
BONNIB J, WRIGHT,
Oahndant, (in Quatody only,
plaintiff in divorce)
AFFIDAVIT OF SERVICE BY HI\.l.W
MSUANT TO PA R,C,P. 1920.4 (a\lI)(111
96-3606
CIVIL TERM
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SB
I, RUBY D, WEEKS, ESQUIRE, Attorney for JOHN A. WRIGHT, bein9 duly aworn
accordin9 to law, depose and ssy that a true and correct copy of the CUSTODY
COMPLAINT AND CUSTODY STIPULATION, waa aerverl on BONNIE J, WRIGHT, at 233
REDTANK ROAD, BOILING SPRINGS, CUMBERLAND COUNTY, PENNSYLVANIA, by mailln9 the
same to her by certlfled mail, No, P 492 357 145, on July 19, 1996, Service
was accepted on July 20, 1996,
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V'(H!:."", \trl.J.....C-,..-
Ruby D. wee~s, Esquire
NOr""'^L III11<L --1
MARVl'YtI A. I )\1" I.. ro Nr-.l.:vy Puhlc
CiUil/',i' ( , . -:,:1,.. (:o.;nty
J.A~(j'''II!'I(.\, . 1,111'''1"' 1')("
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va,
IN THE COURT or COMMON PLEAS
CUMBERLAND COUNTY, PENNsYLVANIA
CIVIL ACTION - LAW
CUSTODY/VISITATION
JOHN A, WRIOHT,
Plaintiff, (in cuatody only,
Dafendant in d1vo~ce)
BONNIE J, WRIOHT,
Defendant, (in cuatody only,
Plaintiff in divo~ce)
96-3606
CIVIL TEIlM
!2.I!.IW\-Qr--~9U R'I:
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AND NOW, thl. j,~ day of Sf./kmkr _, 19 ~, upon conBl.de~ation of
the attached Complalnt, It ls horeby dlrected that the partles and thel~
resl'ectlve counsel al'pea~ before flu~}l1 Lt.. 6/1ro'f ,the concUlator,
at ~OUlJ~l~Ut IAWr,( t./Mf./ff,~ ths ~ day of
19~, at ~Cl--- ~.m., for a
Pre-Hearlng Custody Conference.
Stplfrrt1Jf.r
At such
conference, an effort will be made to re.olve the lssues In dlspute/ or If
thls cannot be accompllahed, to deflne and narrow tho lssues to be heard by
the Court, and to snter lnto s temporary Ordor. All chlldren age flve or
older may also be present st the conference. FaUure to appear at the
conference may provlde grounds for entry of a temporary or permanent Order.
FOR THE COURT,
/a ' .k"~." ~ . .
By. . Cl[ (~{/I. ~..f2L{;ly-C'"
Culftody Conel la1:or -Pzi;'f
The Court of Common Pleas of Cumb"rland County ls requlred by law to comply
with the l\merlcans wlth Disabillties Act of 1990. For information about
acceesible facilitles and reasonable accommodations avallable to disabled
individuals havlng 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 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 f'ORTH BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Admlnistrator
Fourth Floor
One Courthouse Square
Cumberland County Courthouse
carlisle, Pennsylvania 17013
Telephone I (717) 240-6200
VI,
IN THE COURT or CONNON 'LIAS
CUMBERLAND COUNTY, 'ENNSYLVANIA
CIVIL ACTION - LAW
CUSTODY/VISITATION
JOIlH A. WRIGHT,
'lai~tiff, (in cUltody only,
Defe~de~t in divorce)
BONNII J, WRIGNT,
Defl~da~t, (in cUltody only,
'laintiff in divorce)
96-3606
CIVIL TllIM
90MPLAINT FOR JOINT AND SHARED CUSTODY
TO THI NONORAlLI, THE JUDGES or SAID COURT.
1. The Plaintlft is JOHN 1\, WRIGHT, hereatter reterred to as the natural
father, reeidin9 at Bi9 Sprin9 Terrace, Lot 146, Newville, Cumberland
County, Penneylvania, 1'1241
2. The Oetendant ie BONNIE J, WRIGHT, hereafter referred to ae the natural
mother, reeidin9 at 233 Redtank Road, BoiHn\) Sprin9s, Cumberland
County, Pennsyluania 17007 .
3. Plaintitf eeeks joint and ehared cuotody of the tollowin9 children.
a. IWu freeent Reoidence I19.ll
Cecelia linn Wr i9ht 233 Redtank Road 8
Bolling Springs, P1\
Billie Jean Wr ight 233 R~dtank Road l~
Boiling Springs, '1\
b. The children wore not born out of wedlock, the parents were
married December 24, 1985 in Cumberland County, Penneylvania.
They eeparated lIugust 8, 1995.
c. Tho children are presently in the custody ot the natural mother,
who resides at 233 Redtank Road, Boiling Springs, Cumberland
County, 'enneylvania 17007,
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d, The chlldren haue rulded wlth the followlnlJ persons and at the
followlnlJ addreaees,
Person 1 0 I Addreoo P.n.u
(ceceHa)
John & Bonnle Wrlght Lot 37 Blg 5prll1g Terrace Blrth to 1992
Newvlllll, P/\ 17241
Bonnle Wrlght 7B Plne Knob Ro.d 1992 to 1995
Newv llle, PA 17241
Bonnle Wrlght 233 Redtank Road 1995 to present
Bolllng 5prlngs, 1."/\ 17007
(BllHe)
John & Bonnie Wright 78 Plne Knob Road IHrth to 1995
NewuLlle, P/\ 17241
Bonnlll Wrlght 2JJ Redtank Road 1995 to preeent
Bolllng 5prlngs, PA 17007
4,
a.
Plalntlff has not participated as a party or witness, or in
another capacity, in other litigation concernlng the custody of
the children in this or another Court.
b, Plaintiff has no information of a custody proceeding concerning
the chlldren pending in a COIJrt of thi. commonwealth,
c. Plaintiff does not know of a person not s party to the proceedinlJs
who has physical custody of the children or claims to have custody
or visitation rights with respect to the children,
5. Each parent whose parental rights to the children hsve not been
terminated and the person who has physical custody of the children have
been named as parties to this action. There are no other persons who
are known to have or claim a right to custody or visitation of the
children, so none will ~e given notice of the pendency of this action
and the right to intervene.
6, Pursuant to the Custody and Grandparents Visitstion Act, the father
requests this Court to grant an award of joint and ehared legal custody
in both parties and to allow periods of partial custody by the father
with the children as set out below.
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7, Th. lathe... ....qu..t. "joint and shared iegal custody" .0 that .ach pa....nt
.hall have input and the equal I.gal ~ight to make majo... d.cisionl
att.cting the boat internet a ot ths mino... child...em, including, but not
limited to m.dical, ....Ugiou., and Sdllc.tional decisions,
8, Th. tath.... ...sqUQsts ehared-physic.t custody of the child...en in that he
to is able to provide con.i.tent and .table c.re fo... the child...en and h.
i. the pa...ent mo...e likely to assure that the children have a ...elatlon-
.hip with both pa...ents, The father reque.ts joint and .h....ed physical
and legal custody be aw.rded the parente .. set out below,
9, The best interests and permanent welfare of the child...on and their
phy.ical, .piritual, emotional and moral well-being will be ee...ved by
g...anting the relief requested of joint and .hared phyeical and legal
custody with both the mother and fathe~.
10. Plaintift, tather pray. for an Order awarding joint and .h.red phy.ical
legal custody of the minor children, Cecelia Ann Wright born 10-30-87
and Billie Jean Wright born 9-22-94 to both parent. Be followe.
1\. The tathe... who ie employed at ~'ry Communications, Inc., works
eeven days on t...om Tuesday to Tuesday, and seven days ott from
Tuesday to Tue.day, The father shall have .harl!d phyeical
cu.tody at the children during his seven dsys off tram work
starting July 23, 1996 to Augu.t 27, 1996 alternating eve...y at-he...
week and because of a shift chJngo starting on September 3...d, the
tather .hall have .hared phy.ical cu.tody of the children during
hie seven days off from work starti.l\! Septembe... 10, 1996 and
alte...nating week. after that date at the.e .ame time.. The mother
shall have .hared phy.ical cu.tody during the seven days the
tather i. working. When the children ar.e in .chool during the
father'. period. of .hared cu.tody, the father .hall be
respon.ible tor tr.an.porting the children to and tram .chool since
the parent. live in different .chool di.trict.. The father ehall
pick up the children at the mother'. Monday. at 6.30 p,m, on his
way home tram work and ahall return them to to the mother'e at
6.00 a,m, on the following Monday.
3
B, The parente aQree the father .hall have the children for the day
of the followinQ holidays from 9,00 a,m, to 9100 p,m, if the
father is no~ schedulsd to work, New Year's Eve, President's Day/
Balter, Memorial Day, Juty 4th, Labor Day and Thank.llivinQ, If
the father is .cheduled to work, the Mother sh.ll have custody of
the children for the holiday.
C. Since the ch~ldren were with tho mother for Christma., 1995, the
father sh.ll have the children from Dscember 24/ 1996 at 9.00 a.m,
to 9.00 p,m. December 31, 1996/ hi. pllrLod oft work, Howllver, the
Mother shall have the children on Chri.tma. Day trom 2,00 p.m, to
9.00 p,m, It is intended that each p.rent shall alternate having
the children one year ChrLstlnBS morning untLl 2.00 p.m. alld trom
2100 p,m. to 9,00 p.m, tho next year on Christmas Day.
0, The father oh"ll always have the children 9,00 a.m. to 9,00 p.m.
on Father'e DaYI the mother shall alway. have the children at
there timee on Mother's Day, Thi. is provided they are not
working,
E, The parties shall each have a rea.ollable period of time with the
children on the birthdays at each parent, and on the children's
birthday to celebrate these euents/ as lonll as that does not
interfere with the children's schoolinll,
F. The partie. shall notify each other in s timely fa.hion, it it is
necessary, due to an emergency or unforeseen circumstance for him
or her to be delsyed at any of the times set out herein, It is
intended, however, that time be at the e.sence/ and that the
parties as .trictly a. possible comply with the timss set forth
here in,
Q, The parties agree that they will.
1, Each notify the other parent when children are sway from the
child's primary residence for more than two consecutive
nillhts and wl.ll provide an address and phone number where
the children can be reached.
4
~, Both pa~tiea ahall p~omptly adviae each othe~ of the namea,
add~eaaea and phone numbers of any babysitte~D and the
aahedule of when the children will be with the aitte~,
3, The mothe~ shall p~omptly provide the father the name and
add~eee of any school ths chlld~en are enrolled in and the
name of their teachers and leaders for any activity in which
the child~en a~e Involved and keep h~n advised of any
changes,
H, The pa~tiee will notify and consult with the othe~ pa~ty
immediately in cases of medical emergencies that occu~ while the
child~en a~e In their custody.
I, Both parties agree to assU~e the children attend actlvitiee
scheduled for the children during their pedoda of sha~ed custody,
auah aa but not Limited to school events, activities and outinga,
Iwimmlng and othe~ such lessons, birthday and othe~ pa~tiee to
which the children a~e invited by their friends, The pa~tiea
a9~ee to keep each other timely advised as to theae event a and
activitlea.
J. Neithe~ pa~ent shall do anything which may estrange the child~en
from the other parent or Injure the opinion of the chlld~en as to
the othe~ parent, or which may hamper the f~ee and natu~.l
development of the chLldren love 0" affection for the othe~
parent,
K, Husband and wife acknowledge that it Is In the best Inte~ests of
the children to have reasonable and liberal Gontact with both
parents so ae to maintain a normal parent-children relationship
with both parents.
L. The parties agree that In making this Agreement, there has been no
fraud, concealment, ove~reaching, coercion, or. other unfair
dealing on the part of the other,
H. Any modification or waive~ of any of the provisions of this
Agreement shall be effective only it made in writl.ng and only if
executed with the same formality as thia Agreement,
5
N, The partiee aqua they ahall consu It each other regardinq any
electlve medical or dental ~rocedures which it may be neceslary
tor ths children to undergo, and that each is entltled to receive
copiee ot and to coneult w~h teachers, physicians, or any other
per eon involved in caring for, educating, treating or conlultinq
with one or both ot the children. Neither parent may prevent the
other from euch access to information about the children,
WHEREFORB, Plsintitf, father praya for an order awarding joint and
ehared leq&l custody of the minor children, Cecelia Ann Wright born 10-30-87
and Billie Jean Wright born 9-22-94 to both parents ae follows.
A. The tether who is employed at Fry Communications, Inc" worke
eeven days on from Tueaday to Tuesday, and seven days off from
Tueeday to Tueeday. The father shsll have shared physical
custody of the children during his seven days off from work
etarting July 23, 1996 to August 27, 1996 alternating every other
week and because of a shift change BtBrting on September 3rd, the
tather shall have Bhared phyaical cUBtody of the children during
hie seuen daYB off from work starting September 10, 1996 and
alternating weeke after that date at theBe Bame timeB, The mother
shall have ehftrBd phYBical custody during the Beven days the
tather is working. When the children are In school during the
tather'l periods of shared cUBtody, the father Bhall be
responeible for tranBporting the children to and from Bchool Bince
the parente live In dLfferent Bchool diBtrictB. The father shall
pick up the children at the mother's Mondays at 6.30 p.m. on his
way home from work and shall return them to to the mother' e at
6.00 a.m. on the following Monday,
B, The parents agree the father Bhall have the children for the day
ot the following holidaya from 9/00 a,m. to 9.00 p,m, if the
tather Ls not scheduled to work. New Year'B Eve, president'e Day,
Easter, Memorial Day, July 4th, Labor Day and Thanksgiving. It
the father ie Bcheduled to work, the Mother Bhall have cUBtody of
the children for the hoLLday.
C. Since the children were wLth the mother for ChriBtmas, 1995, the
father ehall have the children from December 24, 1996 at 9.00 a,m.
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to 9100 p,m. Pecember 31, 1996, hie period ott work, Howeuer, the
Hother ehall have the children on Chrietmae Pay tram 2100 p,m, to
9100 p,m, It is intended that each parent shall alternata having
the children one year Chriotmao morning until 2.00 p,m, and tram
2.00 p,m, to 9.00 p,m, the neKt year on Christmas Pay,
p, The tether ahall alwaye have the children 9,00 a,m. to 9.00 p,m.
on Father'a Pay; the mother shall always have the children on
Hother'e Oay, This is provided they are not workin",
E, The I?artiee ehall each have a rea.onable period of time with the
children on their parent'e birthdays and on the childrem'e
birthdsy to nelebrate these evente.
F, The partiee ehall notify each other in s timely faehion, it it ie
necessary, due to An C!mergency or unforeBeon circumstance for him
or her to be delayed at any of the timee eet out herein. It ia
intendad, howeuer, that tLme be of the e.sence, and that the
parties as strictly 66 possibie comply with the timee set forth
herein.
G. The parties agree that they will.
1, Each notify the other parent when the children are away tram
the children's primary residence for more than two
consecutive nights and will provide an addrese and phone
number where the children can be reached,
2, Both partiee shall promptly advise each other at the namee,
addreseea and phone numbere of any babyeittere end the
schedule of when the children will be with the sitter,
3, The mother sholl prornptly provide the father the name and
address of any school the children are enrolled in and the
name at their teachers and leaders for any activity in which
the children are involved and keep him adviaed at any
changes,
II, The parties will notify and conoult with the other party
immediately in cases of medical emergencies that occur while the
children are in their custody,
t, Both parties agree to assure the children attend activities
scheduled tor the children during their periods of shared custody,
such ae but not limited to ochool events, activities and outinge,
swimming and othcar such lessons, birthday and other parties to
which the children are invited by their friends, The partiee
agree to keep each other timely aduised as to theee evente and
activities.
J. Neither parent shall do snything which may estrange the children
from the other parent or injure the opinion of the children ae to
the other parent, or which may hamper the free and natural
development of the children love or affection for the other
parent.
7
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JOHN A. WRIGHT,
Plaintiff
v
I IN THE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I 96-3606 CIVIL TERM
I
I
I CIVIL ACTION - CUSTODY
BONNIE J. WRIGHT,
Defendant
COURT ORDBR
AND NOW, this rylt.t day of U oy'''''' bt"r , 1996,
oonsideration of the attached Custody Conciliation Report,
ordered and directed as followsl
1. A Hearing is scheduled in Courtroom No. J of the
Cumberland County Courthouse on the Na day of :L:!d~1.u,"'"1 ~ ,
199.:L, at <!:()tJ ,A.M., at which tlme testimony n tfie above
case will be heard. At this hearing, the Father, John A. Wright,
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 those issues, a list of witnesses that will be called
to testify at the hearing, and a summary of the anticipated
testimony of each witness. Thl.s Memorandum shall be filed at least
ten (10) days prior to the mentioned hearing date,
upon
it is
2. Pending further Order of this Court, the following temporary
custody Order is entered:
A. The Father, John A. Wright, and the Mother, Bonnie J.
Wright, shall enjoy shared legal and physical custody of
Cecelia Ann Wright, born October 30, 1987, and Billie Jean
Wright, born September 22, 1994,
3. Physical custody of the minor children shall be handled as
followsl
A. The Fat.her shall enjoy physical custody on alternating
weekends from Thursday, at 9100 A.M" until Sunday evening at
9:00 P.M.
B. The Mother, Bonnie J. Wright, shall enjoy physical
custody of the minor children at other times that they are not
with the Father, as set forth above.
JOHN A. WRIGHT, I IN TilE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUN'ry, PENNSYLVANIA I
I
V I NO. 96-3606 CIVIL 'l'ERM
I
BONNIE J. WRIGHT, I CIVIL ACTION - CUSTODY
Defendant I
CONCILIATION CONFERENCE SUMMARY RE~
IN ACCORDANCE WITH CUMBERLAND COUN'l'Y CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersi9ned Custody Conciliator submits the
following reportl
1. The pertinent information pertaining to the children who are
the subject of this litigation is as followsl
Cecelia Ann Wright, born October. 30, 1987, and Billie Jean
Wright, born September 22, 1994.
2. A Conciliation Conference was held on October 24, 1996, with
the following individuals in attendance I
The Father, John A. Wright, with his counsel, Ruby O. Weeks,
Esquire, and the Mother, Bonnie J. Wright, with her counsel
Johnna J. Deily, Esquire.
3. The parties separated in September of 1995. Mother has had
primary custody since that time.
4. Mother is not employed. Father is employed with Fry
Communications and has a week on/week off work schedule where he
works eeven days a week and is off seven days a week.
5. During the past sllmmer months, the parties for a short period
of time worked out between themselves an arrangements whereby they
alternated custody on a week-to-week basis, Prior to that time and
subsequent to that time, Mother suggested Father has not made great
efforts to see the children, and over the past few months the
parties agree that the Father has seen the children on an
alternating week basis. Father's position is that Mother has
denied him access to the children and that he has attempted to see
the children but has been frustrated by the Mother.
6. Father now seeks a week on/week off custody arrangement
similar to what the par.ties had worked out for the summer months.
Mother suggested that such an alternating week basis is fine for
the summer but that she feels the children should remain with her
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