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Home My WebLink About96-04557 ] .e :cj~;: (.,;': "~ ~/i,ic ~'i".:/" ~~,:~ . ",['.,.' ~': :' "'Y;':'~,\, ',,1~ " :',-:,S', ,~:o,;' . ~UJ<,",>' ..- ! ':';,: ~~ ~Lt '.'I'~' ::;, . \;;:':. , ,,.. " "'",: ",,c.:"" .,,'.' ':.ii' " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTA K. EBERSOLE Plaintiff, No. yro- Iff1"1 I cf~L !\Us 1 5 1996 tf v. Civil Action - Custody CRAIG MORROW Defendant ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respectivy counsel appear before 1"'; t~rd.I,l, J\"'nS~(':? the Conciliator, on the -L5::l,-day of Sttlt-,..J.,rr . 19~ at l119.a..m at Q,iY.J r I ~j". Sf. (:~'" f I}, II \ '.', 1> 0 p, ,I'. , , for a Pre-Hearing Custody Conference. At such Conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a Temporary Order. All children age five or older may, at the request of either attorney or party, be present at the Conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT Date of Order: 'j?-I'i-"i? By: ~~~ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Court Administrator I Courthouse Square Carlisle, PA 17013 Telephone No. (717) 240-6200 QC -, F}.Lf'D-OFFICE , I r.- rp,~i"-'''''~"" ~ , '''/1 n.JlllnY 95 ~/JG 2!J r,,, ", j Ii .j' 09 CU"'" /"iC"j'lL' - i .','..1 l,'" '. T' PENNSYLVA!-!';;('" ( ,', ,~v &,j;)() .ft tit:!. cb~ lJt1~ ~ ~ ~. . -tCJ!'f~ ~~:e ;nJ/ -Z T . e\:)I.~1t> &17 ~/ ~ 1t1.?St~ ~ . AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be mace at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. B' Lee E. Oesterling, Esquire Attorney 1.0.# 71320 1002 Market Street South Mechanicsburg, PA 17055 (717) 790-0490 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTA K. EBERSOLE Plaintiff, No. v. Civil Action - Custody CRAIG MORROW Defendant COMPLAINT FOR CUSTODY 1. The plaintiff is Krista Ebersole, an adult individual, sui juris, who resides at 425 Duke Street, City of Enola, County of Cumberland, Commonwealth of Pennsylvania, 17025. 2. The defendant is Craig Morrow, an adult individual, sui juris, who resides at 221 Chester Road, City of Enola, County of Cumberlandr, Commonwealth of Pennsylvania, 17025. 3. Plaintiff seeks custody of the following child: Name Present Residence Age Logan Allen Ebersole 425 Duke Street Enola, PA 17025 4 mos. 4. The child was born out of wedlock. 5. The child is presently in the custody of Plaintiff. 6. During the past five years, the child has resided with the following persons and at the following addresses: Person Address Dates Krista K. Ebersole 425 Duke Street Enola, PA 17025 4-16-96 to present 7. The mother of the child is the plaintiff, Krista Ebersole. 8. She is single. 9. The father of the child is the defendant, Craig Morrow. 10. He is single. 11. The relationship of plaintiff to the child is that of biological mother. 12. The plaintiff currently resides with the following persons: Name Relationship NONE 13. The relationship of defendant to the child is that of hiological father. 14. The defendant currently resides with the following persons: Name Relationship It is believed and thcrefol'e averred that dcfendant residcs with his mothcl' und futhcr. 15. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 16. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 17. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 18. The best interest and permanent welfare of the child will be served by granting the relief requested because: a. Since the birth of the child, Plaintiff has provided and continues 0 provide a stable living environment. b. Plaintiff has been the sole custodian and caregiver of the child since birth. c. Plaintiff has maintained a relationship with the child that has provided a sound and stable environment for the physical, intellectual, emotional and spiritual well being of the child. d. Defendant has threatened to remove the child from the jurisdiction of this Court on at least two occassions in the last 30 days and has also attempted to remove the child from plaintiffs custody without her knowledge or consent. 19. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim NONE . WHEREFORE, plaintiff, Krista Ebersole, requests the court to grant custody of the child. Respectfully Submitted, HAZLETT OESTERLING Lee E. Oester ing, Esquire Attorney I.D.# 71320 1002 South Market Street Mechanicsburg, PA 17055 (717) 790-0490 Attorney for Plaintiff, Krista Ebersole . VERIFICATION I verify that upon personal knowledge or information and belief that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904, relating to unsworn falsification to authorities. ~~,\.rk~rh(l" (JJI Plaintiff Date: (J -1"1- - 96 ';! , , . , . p. \ . " .~~~ x ~D >- C!' is wQ U"'-- EE? ~i~ u-,u, ff!~.! '>=: U, o . C", C'.: ~\)\~ ~ ~ ",- n: -, ~-~ '. <!" .)"/ . .} ~:i: '.-': :':.1 ,-;- "('l .:i% ,eZ i:'Ste :s U .. ~... "'" 1.0 0-.. r-- ^f\~ ~~ ~ cJ~X IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTA K, EBERSOLE Plainti ff, No. 96,4557 v. Civil Action - Custody CRAIG MORROW Defendant ORDER OF COURT AND NOW, this ~)'.J- day of tJ~ , 19l{ ~upon presentation and consideration of the attached stipulation and agreement and upon agreement of the parties, it is hereby ordered and decreed that the attached agreement is made an Order of Court. / BY\~,7! J I I J. ( r;Lr:O-OFr1~E c:: r ,'-' ,"( . ""-\ 'I\.(;'~t'{ ss Cr.T - t h.1 !I: ~Q (}..;:.,...... .~;..c..: . .: I p Lt<>.Sl"~'/.',~ .::,:', " , . KRISTA K. EBERSOLE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 96-4557 plaintiff, v. CIVIL ACTION - CUSTODY CRAIG MORROW Defendant STIPULATION FOR ENTRY OF AN AGREED ORDER OF CUSTODY AND NOW, the parties by and through their attorney, stipulate and agree that it is in the best interest of their minor child, LOGAN ALLEN EBERSOLE, born 4-16-96 (hereinafter "Child") to enter into the following custody arrangement which shall be entered as an Order of Court. 1. The parties will share legal custody of the minor child. 2. Krista k. Ebersole (hereinafter "mother"), residing at 425 Duke Street, Enola, PA 17025, shall have primary physical custody of the Child, subject to the Father's right of visitation as follows: 3. Starting on September 16, 1996 and for the first one hundred and sixty (160) days thereafter, Craig Morrow (hereinafter "Father"), residing at 221 Chester Road, Enola, pa 17025, shall have supervised visitation with the child at his parents home every Monday and Tuesday from 6pm to 9pm. Vistation shall be supervised by the paternal grandparents. After one hundred and sixty (160) days father shall have partial custody every Tuesday and Thursday from 6:00 p.m. to 9:00 p.m. 4. With respect to holidays, Father shall have child on Christmas Eve from 6pm to 9pm. Father shall have child from 3pm to 7pm every Christmas Day, Easter, and Thanksgiving. Father shall have the Child on Father's Day and Mother shall have the Ghild on Mother's Day (Hours of visitation will be at parties mutual agreement) . Mother and Father will alternate spending child's birthday, beginning 4-16-97 with the Mother. All other holidays will follow normal visitation days. 5. Each of the parties agree to advise the other of any changes in their residence or telephone numbers or addresses within five (5) days. 6. Father shall have complete access to all academic, medical and counseling records for the Child. In addition and when the Child is of school age, the Child's school shall directly provide duplicate copies of all correspondence, updates, evaluations, and report cards to Father. Father shall be responsible for providing his address to the Child's school. 7. Father shall have reasonable telephone (between lOam and 10pm) and mail access to the Child. 8. While in the presence of the Child, neither of the parties shall make any remarks or do anything which can in any way be construed as to be derogatory or uncomplimentary to the other and it shall be the duty of each parent to uphold the other parent as someone whom the Child should respect and love. 9. Any modification or waiver of any of the provisions of this agreement shall be effective only if made in writing and only if executed with the same formality of this agreement. 10. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 11. The parties hereby stipulate to the entry of the above as an order of court and waive their right to appear before the court for the presentation of this stipulation and its incorporation as an order. The parties further acknowledge that the Court of Common Pleas of Cumberland County has jurisdiction over the issue of custody of the parties' minor child and shall retain such jurisdiction should circumstances change and should either party desire further or require further modification of said Order. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound by the terms hereof, set forth their hands and seals the day and year herein set forth. ~i~I',~\l\.;r.-~ (r.h, (,".,,(, KRISTA K.'EBERSOLE nVl~.' fYl c.'''" 0'1" CRAIG ORROW COMMONWEALTH OF PENNSYLVANIA :ss: COUNTY OF CUMBERLAND BE IT REMEMBERED, that on this / (j day of SC.,}?T-i,~{~" ___' 199~, personally appeared before me the Subscriber, a Notary Public for the State and County aforesaid, Krista K. Ebersole party to this Agreement, kno,wn to me personally to be such, and she acknowledged the act of signin~\fh~s Agree~ent. .::zl~\L\'\c'" y" (: I" " "U't 'KRISTA K: EBERSOLE Sworn to and subscribed before me the day, month and year aforesaid Notarial Seal Wendy J. Oesle,ling. Nolary Public Silver Spong Twp., Cumberland Counly My Commission expire. Sept. 27, 1999 em er. ennsylvan a soc at on at ola ea ,,,,")I/j/,'~ 9. to 5f?".~ Notary P bc BE IT REMEMBERED, that on this If day of ~,.,;:;tz,.,JJJ-") ___' 19941, personally appeared before me the Subscriber, a Notary Public for the State and County aforesaid, Craig Morrow party to this Agreement, known to me personally to be such, and she acknowledged the act of signing th~~ A~re~~ent. bli ~ ~~ ,L!!LO..--fA.. t91..l J CRAIG MOrROW Sworn to and subscribed before me the day, month and year aforesaid Notarial Seal ,WcndyJ, oesterling, NOlary Public Silver Spring Tw~" Gumber1and County My Commission explra. Sept. 27. 19G9 Member, ennsylvama ssoclatloll of Notanes .J/.$-It,~,~) .o.E;hd:~ ' Notary u l~c J \~ -.g, ~"<./ "-. '" ..... " ~ .~ ~ s: :>- :~~ ,'-. ,,>- ,. lJ..!C' -" $.J' ct:!.<. L.:...,. c.. 91 C~r '.::1 li:j,.. (".' -' Ci: !! C', F~ c, , L :;,- t'_. " L> '.:') :j C', l.) ."i';" '1", : U./ , ,U- KRIST A K. EBERSOLE, Plaintiff ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 96-4557 CIVIL TERM CRAIG MORROW, CUSTODY /VISIT A TION Defendant ORDER OF COURT AND NOW this JofL. day of J,pfrv....JQ/'- , 1996, it being reported to the Conciliator that the parties have reached an agreement which makes further proceedings unnecessary, the undersigned Conciliator hereby relinquishes jurisdiction and returns the matter to the Court Administrator. If either of the parties wishes further proceedings in this action, they should petition the Court anew. FOR THE COURT, C", JI'/ /) /VIrJI- -'/ ,0"// MICHAEL L. BANGgl Custody Conciliatoil' cc: Lee E. Osterling, Esquire Mr. Craig Morrow, pro se ~t.y CA'< ~ F\'Lt:IJ-O~~'lC~ c:: i' 1 < _,...(<,.tj,,'r' ';'~\rrr~{ ~') r:r.'~ ' 0" ~': '. n I" -..., .......'.,.,1',' n'., F\:;<\ .:'~f~t.r/_:-;'/ \ , , CRAIG A. MORROW, Defendant NO. 4557 CIVIL 1996 CUSTODY/VISIT A TION KRISTA K. EBERSOLE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW ORDER OF COURT AND NOW, this (date) \;::)\ 1,\\(1', , upon consideration of the attached complaint, it is hereby directed .t~at the parties a~d thei,r ~~spective counsel appear before M, the\': \ L, &rv~., the conclhator, at ,1::'.'4 ::'" \ R\' ,,->" Jrmp \-~\ \ on th..: \ ~ day of R' \---, ,I 9~, at ~.M., for a Prehearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Either party may bring the child who is the subject of the custody action to the conference, but the child/children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. For the Court, By: '~loitd.'H~,~ Custody Conciliator tll>)j 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 FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, OFFICE OF THE COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, FOURTH FLOOR CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717) 240,6200 . .... . . ", : : '.': , - c , >....- p ;'1-7; ~,a# /?y?td.-1 h <'t~ ~...... /,;J./fl.fl) ~M.(' /"d~/ .6 y;./f' /c) ./1 ,1) ,4ij ~c,;;/ -'k- 7n, &1~ yt!. , ' KRISTA K. EBERSOLE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 96-4557 CRAIG A. MORROW, Defendant CIVIL ACTION - CUSTODY TO THE HONORABLE JUDGE EDGAR B. BAYLEY; PETITION FOR MODIFICATION AND NOW, comes the Defendant, Craig A. Morrow, by and through his Attorney, Austin F. Grogan, Esq.. aver the following: 1. The parties are the natural parents of Logan Allen Ebersole, born April 16, 1996; 2. The parties entered into a agreement dated September 18, 1996 which is incorporated with this Petition; 3. The parties can not agree as to what expanded time the Defendant should have with his son, Logan. WHEREFORE, the Defendant respectfully requests this Court to schedule a Custody Conference in order to refine and expand the partial custody for the natural father. Respectfully Submitted, -I< MAY 1 8 1998/b vs. ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTA K. EBERSOLE, Plaintiff NO. 4557 CIVIL 1996 CRAIG A. MORROW, Defendant CUSTODYNISIT A TION ORDER OF COURT AND NOW this / !:J-fi-. day of , 1998, having not heard from the parties for some time, the undersigned Concilia or assumes the matter has been resolved and hereby relinquishes jurisdiction of the case. If either of the parties wishes further proceedings in this action, they should petition the Court anew. FOR THE COURT, MICHAEL L. BAN Custody Conciliator Lee Osterling, Esquire Mr. Craig A. Morrow F,t FQ-C:T,C',:: C~ ,-. ,," f, 'I.'" ":\:..S,{ (l',11,j?' 't 2 \j n~, q: h Z CU:\/.,;:';'~ - p:!:', '\1'.1 , ...,,;,,-".' '_ _,..::-:f'(