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When the plaintiff yelled for her oldest son, Charles, to call 911 for help, the defendant pulled the telephone cord from the wall, grabbed the telephone from the child, and threw the telephone to the Ooor. The plaintiff was able to get the telephone to work and called the Newville Police, but the defendant grabbed the telephone rrom her and hung It up. The plaintiff and the children ran from the house, got Into the car and locked the doors. The defendant came out, kicked the front of the car and yelled at her threatening that he would hunt her down no matter where she went, and that he would Ond her and kill her. The police arrested the defendant, charged him with simple assault, terroristic threats, assault with a deadly weapon, and recklessly endangering another person, and committed him 10 the Cumberland County Prison. A preliminary hearing was held on the charges on July 11, 1996, before District Justice Shulenberger. The matter was bound over for hearing. The defendant was released on his own recognizance, wilh one of his conditions of ball being that he have no contact with the plaintiff. b) On or about June 2, 1996, the defendant gmbbed the plaintiff by her shoulders, took her car keys, got a steak knife from the kitchen and threatened to slash the car tires. The plaintiff took the children and went to the Newville Police Department. Chief Hershey went back to the house with the plaintiff to 2 try to let the defendant to live the plaintiff her car keys, but he told Chief Hershey that he nushed them down the toilet. The plaintiff and her children slayed with her sister for 2.) days to avoid further abuse from the defendant. c) On or about May 30, t996, the defendant yelled in the plalntifrs face and threatened to kill her If she left him and tried to take the children. The plaintiff telephoned the Newville Police and requested assistance from Officer Wiser to stand by so she could safely leave with her children to avoid further abuse. d) In or about March, 1996, the defendant got a butcher knife and waved il in a menacing fashion in front of the plalntifrs face as she held the parties' 11- month-old son in her arms. The plaintiff feared for the safety of herself and the baby. e) Since approximately March, 1995, the defendant has abused the plaintiff in ways including, but not limited to, grabbing her arms, slapping her about the head, restraining her so she cannot leave the home, and disabling her car. The defendant has threatened to kill the plaintiff on a number of occasions. 5. The plaintiff believes and therefore avers that she is In Immediate and present danger of abuse from the defendant should she remain in the home without the defendant's exclusion and that she Is in need of protection from such abuse. 6. The plaintiff desires that the defendant be prohibited from having any direct or indirect contact with the plaintiff including, but not limited to, telephone and written communications. 3 7. The plaintiff desires thatlhe defendant be enjoined from harassing and stalking the plaintiff, and from harassing her relatives or the minor children. 8. The plaintiff desires that the defendant be restmined from entering her place of employment, the school of her child, Charles R. Hancock, Jr., and day care facilities of the parties' minor chUdren. 9. The plaintiff desires that the defendant be enjoined from removing, damaging, destroying or selling any property owned jointly by the parties or owned by the plaintiff. B. EXCLUSIVE POSSESSION 10. The home from which the plaintiff is asking the Court to exclude the defendant Is rented in the names of Tina Marie Culhane and Robert Duke Walker, Sr. 11. The plaintiff currently has no place to stay with her children except the home at 36 West Glebe Street, Newville, Cumberland County, Pennsylvania. The defendant not been back to the residence since he was arrested on July 6, 1996, and a condition of his ball is not to have contact with the plaintiff. 12. The plaintiff desires possession of the home so as to give the greatest degree of continuity to the lives of the children. (;. SUPPORT 13. The defendant has a duty to support the parties' two minor children. 14. The plaintiff is In need of financial support from the defendant including, but not limited to: health insurance covemge, payment of unreimbursed medical expenses for the minor 4 Tho defendant, the father of the parties' two children, is Robert Duke Walker, Sr., whose curren1 whereabouts are unknown to the plaintiff. He is Ilnlle. 20. The plaIntiff has not previously participated in any litigation concerning custody of tile above mentioned children in this or any other Court. 21. The plaintiff has no knowledge of any custody proceedings concerning these children pending before a court in this or any other jurisdiction. 22. The plaintiff does not know of any person not a party to this action who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 23. The best interests and permanent wclfare of the minor children will be met If custody Is temporarily granted to the plaintiff pending a hearing in this matter for reasons includina: a. The plaintiff Is a responsible parent who can best lake care of the minor children and she has provided for the emotional and physical needs of the childrcn since their births. b. The defendant has shown by his abuse of the plalnti ff that he is not an appropriate role model for the minor children. c. The defendant's behavior has adversely affected the children. 7 WHEREFORE, pursuant to the provisions of the "pro~tion from Abuse Act" of October 7, 1976,23 P.S. 16101 s:t RQ., as amended, the plaintiff prays this Honorable Court to grant the following relief: A. Grant a Temporary Order pursuant to the "Protection from Abuse Act:. 1. Ordering the defendant to refrain from abusing the plaintiff and from placing her in fear of abuse; 2. Ordering the defendant to refrain frolll having any direct or indirect contact with the plalntiff Including, but not limited to, telephone and written communications; 3. Ordering the defendant to refrain from harassing and stalking the plaintiff and from harassing her relatives and the minor children; 4. Prohibiting the defendant from entering the plalntlfrs place of employment, the school of Charles R. Hancock, Jr., the plaintifrs son by a previous relationship, and the day care facilities of the minor children; 5. Prohibiting the defendant from removing, damaging, destroying or selling property Jointly owned by the parties or owned by the plaintiff; 6. Granting possession of the home located at 36 West Glebe Street, Newv\1le, Cumherland County, Pennsylvania, to the plaintiff to the exclusion of the defendant, and ordering the defendant to slay away from any residence the plaintiff may establish for herself pending a nnal order in this matter, and 8 7. Orantlng temporary custody of the parties' minor children, Robert Duke Walker, Ir. and Edward Dean Walker, II, lO the plaintiff, 8, Schedule a hearing in accordance with the provisions of the "Protection from Abuse Act," and, after such hearing, enter an order to be In effect for a period of one year: 1. Ordering the defendant to refrain from abusing the plaintiff and from placing her In fear of abuse. 2. Ordering the defendant to refrain from having any direct or Indirect contact with the plaintiff including, but not limited to, telephone and written communications. 3. Ordering the defcndantto refrain from harassing and stalking the plaintiff and from harassing her relatives and the minor childrp.n. 4. Prohibiting the defendant from entering the plaintiff's place of employment,the school of Charles R. Hancock,lr., the plaintifrs son by a previous relationship, and the day care facilities of the minor children. S. Prohibiting the defendant from removing, damaging, destroying or selling property jointly owned by the parties or owned by the plaintiff. 6. Granting possession of the home located at 36 West Glebe Street, Newville, Cumberland County, Pennsylvania, 10 the plaintiff to the exclusion of the defendant, and ordering the defendant to stay away from any residence the plaintiff may establish for herself pending a final order In this mailer. 9 7, Orantlnl5upport to the plaintiff for the parties' two minor children In the amount of SSO.OO per week payable to the plaintiff In the form of a check or money order, mailed to her residence, and ordering the defendant to provide health coverage to the parties' two minor children, pay all of the uJlrelmbursed medical expenses of the parties' two minor children to the provider or to the plaintiff when she has paid for the medical treatment, and make or continue to make rent payments on the residence of the plaintiff. 8. Ordering the defendant to pay $250.00 to Cumberland County, one of Legal Services, Inc. 's funding sources, In lieu of attorneys' fees, as reimbursement for the cost of litigating this case and assessing the $25.00 surcharge and court costs to the defendant if the case goes to hearing. The plaintiff further asks that this Petition be filed and served without payment of fees and costs by the plaintiff, pending a further order at the hearing, and that certified copies of this Petition and Order be delivered to the Pennsylvania State Pollee, and the Newville and Carlisle Police Departments which have jurisdiction to enforce this Order. The plaintiff prays for such other relief as may be just and proper. COUNT II CUSTODY UNDER PENNSYLVANIA CUSTODY LAW 24. The allegations of Count I above are Incorporclted herein as if fully set forth. 10 "1 I' , , " I I ~, ~ ~ I, ~: 1;/1 I'.~. cB I~(' u-; .. IS 'r~ " ~ ' '\ ~ .,. >;1; .., J::,'.1 'r. ,,"'- 'j .;' ')~- , t~. '(;i ,. ~' ! ,."J .1~. F 0:./ i'~ 'I 'II . ~ tJ) ..: o. d , ' " , "I I' ", " " I , ., , , , I;, ~ I. I I , " , " , I , I ) " ""I ," " II I, " I' I. , I " II , I'il' I, '11 " " fl', , I '" I, I " , The defendant is enjoined from entering the plalntlfrs place of employment and the school of Charles R. Hancock, Jr., the plalntlfrs son by a previous relationship, and the day care facilities of the parties' minor children. The defendant Is enjoined from removing, damaging, destroying or selling any property owned jointly by the parties or owned by the plalntlff. A violation or this Order may subject the derendant tOll) IIrrest under 23 PI.C.S. 16113111) a private criminal complaint under 23 Pa.C.S. 16113.1;111) a charlie or Indirect criminal contempt under 23 Pa.C.S. 16114, punishable by Imprisonment up to six months and a nne or $100.00-$1,000.00; and Iv) civil contempt under 23 Po.C.S. 16114.1. This Order shall remain in effect until modified or terminated by the Court and can be extended beyond Its original expimtion date if the Court finds that the defendant has committed an act of abuse or has engaged in a pattern or practice that indicates risk of harm to the plaintiff. Temporary custody of Robert Duke Walker, Jr. and Edward Dean Walker, II, Is hereby awarded to the plaintiff, Tina Marie Culhane. 11.1 A HEARING SHALL BE HELD ON THIS MATTER ON THE:)J DAY OF JULY, 1996, AT 11,1) /I.M., IN COURTROOM NO...;:'..., CUMBERLAND COUNTY COURmOUSE, CARLISLE, PENNSYLVANIA. The plaintiff may proceed without pre-payment of fees pending a further order after the hearing. The Cumberland County Sherifrs Department shall allempt to make service at the plalntifrs request and without pre-payment of fees, but service may be accomplished under any applicable rule of Civil Procedure. the front door, and when shLltumed to face lhe defendant, he backed her against the door with his left hand on her chest and held the knife in his right hand In a stabbing position. When the plaintiff ydled for her oldest son, Charles, to can 911 for help, the defendant pulled the lelephone cord frol11 the wall, grabbed the telephone from the child, and threw the telcphone to thc Iloor. The plaintiff was able to get the telephonc 10 work and called the Newville Police, but the defendant grabbed the Ielcphonc frul11 hcr and hung II up. Thc plaintiff and the children ran from thc house, got Inlo thc car and locked thc doors. The defendant came out, kicked the front of the car and yelled at her threatening that he would hunt her down no matter where she wcnt, and that he would find her and kill her. The pollcc arresled the defcndant, charged him with simple assault, terroristic threats, assault with a de:ldly we<lpon, and recklessly endangering another person, and commllled him 10 Ihc Curnl;erland County Prison. A preliminary hearing was held on thc charges on July II, 1996, before District Justice Shulenberger. The maller was bound over for hearing. The defendant was released on his own rccognil.l1nCe, with one of his conditions of bail being that he have no contact with the plaintiff. b) On or abOUI June 2, 1996, thc defendant grabbed the plainltif by her sh.,ulders, took her car keys, got a steak knife from the kitchen and threalened to slash the car tires. The plaintiff took the children and went to the Newville Police Department. Chief Hershey went back to the house with the plaintiff to 2 try to let the defendant to live the plaintiff her car keys, but he told Chief Hershey thllt he flushed them down the toilet. The plaintiff and her children stayed with her sister for 2-3 days to avoid further abuse from the defendant. c) On or about May 30, 1996, the defendant yelled In the plalntlfrs face and threatened to kill her if she len him and tried to take the children. The plaintiff telephoned the Newville Police and requested assistance from Officer Wiser to stand by so she could safely leave with her children to avoid further abuse. d) In or about March, 1996, the defendant got a butcher knife and waved It In a menacing fashion In front of the plalntlfrs face as 5he held the parties' II- month-old son In her arms. The plaintiff feared for the safety of herself and the baby. e) Since approximately March, 1995, the defendant has abused the plaintiff in ways including, but not limited to, gmbbing her arn15, slapping her about the head, restraining her so she cannot leave the home, and disabling her car. The defendant has threatened to kiilthe plaintiff on a number of occasions. 5. The plaintiff believes and therefore avers that she Is In immediate and present danger of abuse from the defendant should she remain In the home without the defendant's exclusion and that she is In need of protection from such abuse. 6. The plaintiff desires that the defendant be prohibited from having any direct or indirect contact with the plaintiff Including, but not limited to, telephone and written communications. 3 7. The plaintiff desires that the defendant be enjoined from hlll'llsslng and stalking the plalntlff, and from harusinl her relatives or the minor children. 8. The plaintiff desires that the defendant be restrained from entering her place of employment, the school of her child, Charles R. Hancock, Jr., and day care facilities of the parties' minor children. 9. The plaintiff desires that the defendant be enjoined from removing, damaging, destroying or selling any property owned jointly by the parties or owned by the plaintiff. B. EXCLUSIVE POSSF..liSION 10. The home from which the plaintiff Is asking the Court to exclude the defendant is rented in the names of Tina Marie Culhane and Robert Duke Walker, Sr. 11. The plaintiff currently has no place to stay with her children except the home at 36 West Olebe Street, Newville, Cumberland County, Pennsylvania. The defendant not been back to the residence since he was arrested on July 6, 1996, and a condition of his bail is not to have contact with the plaintiff. 12. The plaintiff desires possession of the home so as to give the greatest degree of continuity to the lives of the children. C. SUPPORT 13. The defendant has a duty to support the parties' two minor children. 14. The plaintiff is in need of financial support from the defendant including, but not limited to: health Insurance covemge, payment of unreimbursed medical e~penses for the minor 4 WHEREFORE, pursuant to the provisions of the "Protection from Abuse Act" of October 7, 1976, 23 P,S. '6101 ~ AIlll., as amended, the plaintiff prays this Honorable Court 10 grant the following relief: A, Grant a Temporary Order pursuant to the "Protection from Abuse Act:" 1. Ordering the defendant to refrain from abusing the plaintiff and from placing her In fear of abuse; 2. Ordering the defendant to refrain from having any direct or Indirect contact with the plaintiff Including, but not limited to, telephone and written communications; 3. Ordering the defendant to refrain from hllTllsslng and stalking the plaintiff and from harassing her relatives and the minor children; 4. Prohibiting the defendant from entering the plaintlfrs place of employment, the school of Charles R. Hancock, Jr., the plalntlfrs son by a previous relationship, and the day care facillties of the minor childrenj 5. Prohibiting the defendant from removing, damaging, destroying or selling property jointly owned by the parties or owned by the plaintiffj 6. Granting possession of the home located at 36 West Glebe Street, Newville, Cumberland County, Pennsylvania, to the plaintiff to the exclusion of the defendant, and ordering the defendant to stay away from any residence the plaintiff may establish for herself pending a final order in this matter, and 8 7. Orantinl temporary custody of the parties' minor children, Robert Duke Walker, Jr. and Edward Dean Walker, 11, to the plaintiff. B. Schedule a hearing In accordance with the provisions of the "Protection from Abuse Act," and, after such hwing, enter an order to be In effect for a period of one year: 1. Ordering the defendant to refrain from abusing the plaintiff and from placing her In fear of abuse. 2. Ordering the defendant to refrain from having any direct or Indirect conlact with the plaintiff Includinll, but not limited to, telephone and written communications. 3. Ordering the defendant 10 refrain from harassing and stalking the plaintiff and from harassing her relatives and the minor children. 4. Prohibiting the defendant from entering the plaintifrs place of employment, the school of Charles R. Hancock, Jr., the plaintifrs son by a previous relationship, and the day care facilities of the minor children. S. Prohibiting the defendant from removing, damaging, destroying or selling property jointly owned by the parties or owned by the plaintiff. 6. Granting possession of the home located at 36 West Glebe Street, Newville, Cumberland County, Pennsylvania, to the plaintiff to the exclusion of the defendant, and ordering the defendant to stay away from any residence the plaintiff may establish for herself pending a final order in this matter. 9 7. Ol'8lltlnS support to the plaintiff for the parties' two minor children In the amount of 5S0.00 per week' payable to the plaintiff In the form of a check or money order, mailed. to her residence, and ordering the defendant to provide health coverage to the parties' tWQ minor children, pay all of the unreimbursed medical expenses of the parties' two minor children to the provider or to the plaintiff when she has paid for the medical treatment, and make or continue to make rent payments on thr. residence of the plaintiff. 8. Ordering the defendant to pay 5250.00 to Cumberland County, one of Legal Services, Inc. 's funding sources, In lieu of allomeys' fees, as reimbursement for the cost of litigating this case and assessing the 525.00 surcharge and court costs to the defendant if the case goes to hearing. The plaintiff further asks that this Petition be tiled and served without payment of fees and costs by the plaintiff, pending a further order at the h.-Ming, and that certified copies of this Petition and Order be delivered to the Pennsylvania State Police, and the Newville and Carlisle Police Departments which have jurisdiction to enforce this Order. The plaintiff prays for such other relief as may be just and proper. COUNT II <;USTODY UNDER PENN&YLVANIA CUSTODY LAW 24. The allegations of Count I above are Incorporated herein as if fully set forth. 10 " , " , " , " " I ;1 " " " , I, , " , , , , " ... Jt '" I~ I.... III . , 'j /II :)~ " ,i, t~- ~<: ..Ir3 ? ,~. ,\&. (:- '0 i~ ", N LI j' , l" "5 'l1 " f'-. ~ " q ~ If) ,. 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