HomeMy WebLinkAbout96-04597
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of custody to takc placc cvcry Friday at 4:00 p.m. A copy of said Ordcr is attached hcrcto and
markcd Exhibit "A."
5. Thc abovc-rcfcrcnccd Ordcr notwithstanding providing sharcd physical custody,
Mothcr by agrccmcnt and by dcfault, provides primary physical custody approximatcly seventy-fivc
(75%) pcrcent ofthc time, with said schcdulc continuing until thc summer 1997 whcn a disputc
arosc as to whcrc the oldest minor child would attcnd first gradc, EIizabcthtown or Mcchanicsburg.
6. On August 27, 1997 this Honorablc Court cntcrcd an Order upon Father's Pctition
for emergency relief dirccting thc status quo of the Scptcmbcr I G, 1996 Ordcr be maintaincd with
the minor child Jacquie M. Moorc attending Northside Elcmentary School as a first grader in
Mechanicsburg.
7. A few months later, on Octobcr 15, 1997 upon consideration ofa Scptcmber 30, 1997
custody conciliation conference, an Order was entered providing the parties shall submit themselves,
their minor children and any other individuals dcemcd necessary by the evaluator to a custody
evaluation to be performcd by a professional sclectcd by agrcemcnt of the parties and counscl.
8. Thc partics agrccd upon Dr. Pauline Wallin, Ph.D., Liccnscd Psychologist, 201 South
32nd Strect, Camp Hill, PA 17011, as thc custody cvaluator.
9. Mother has complctcd and paid for her part ofthc cvaluation.
10. Fathcr has not complcted nor paid for his part of the evaluation. In fact, as rcccnt as
March 3, 1998, Dr. Wallin contacted Mr. Moorc and his thcn girlfricnd, Angcla Turncr, indicating
the psychological tcsting, which is part of the Court ordcrcd custody cvaluation had not bccn
completcd by him. A truc and corrcct copy of hcr Icttcr of March 3, 1998 is attach cd hercto and
marked Exhibit "B."
II. As ofthc filing of this Pctition, Mr. Moorc has still not dircctcd that his girlfricnd's
tcsting be complctcd.
12. Mothcr bclicvcs and thcrcforc avcrs Fathcr has not complctcd thc custody cvaluation
aftcr repcatcd dcmands being madc forcing Dr. Wallin to prcparc a rcport, which has not bcen
relcased and which is incomplctc bccausc of Fathcr's unwillingncss to participatc complctcly in thc
evaluation.
13. Mother belicvcs and thercforc avcrs as ofthc filing of this Pctition, Father has not
paid for his portion of the custody evaluation and Dr. Wallin will not relcasc thc said report until said
payment is madc.
14. Mothcr has paid in full her portion ofthc custody cvaluation as reflccted in the rcceipt
from Dr. Wallin's office attached hercto and marked Exhibit "C."
15. Mother believes and thcrcforc avers Fathcr's unwillingness to completc and pay for
the evaluation is simply a means of maintaining thc status quo Order whereby Jacquie Moore must
attend, under Order of Court the Northside Elcmcntary School.
16. During Mothcr's pcriods of physical custody she provides round-trip transportation
from Elizabethtown to thc Northsidc Elcmcntary School in Mcchanicsburg and participates fully in
Jacquic's education.
17. Mothcr bclicvcs and thcrcforc avcrs whcn the minor childrcn arc in the physical
custody of Fathcr, thc oldcst daughtcr, Jacquic stays with patcrnal grandmothcr bccause Fathcr is
fcarful of the bchavior of girlfriend's childrcn as against his own childrcn in his rcsidcnce.
18. Mothcr belicvcs and thcrcforc avcrs thc parties' son has suffcrcd human bitcs during
Fathcr's periods of partial physical custody as a rcsult of girlfricnd's childrcn in his houschold
VRRIFICATlON
I, Mclissa P. Moorc, vcrify that thc statements madc in this forcgoing Pctition arc truc and
corrcct. I understand that false statcmcnts hcrcin arc madc subject to thc pcnaltics of 18 Pa. C.S.
Scction 4904 rclating to unsworn ialsification to authorities.
Date: ~..3 \ - 'Y6
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- ,Mclissa P. Moorc
IN HIE COURT OF COMMON PI.EAS OF CIJMRERI.AND COUNTY, PENNSYI ,V ANlA
CIVil, TERM
DOUGLAS P. MOORE,
Plainti ff
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No. 96-4597
I, Jcffrey S. Shank, Esquirc of Gingrich, Smith, Klingensmith & Dolan, attorney for the
Overnight Mail.
Philip H. Spare, Esquire
SNELBAKER, BRENNEMAN & SPARE
44 West Main Street
Mechanicsburg, P A 17055
Rcspectfully submitted,
above-named Defendant, hereby certify that I duly served the Petition for Emergency Relief
vs.
MELISSA P. MOORE,
Dcfcndant
CERTIFICA TE OF SERVICE
Requesting Modification of an Existing Custody Ordcr upon the following by Federal Express,
GlNGRJCH, SMITH, KLINGENSMITH & DOLAN
Byd/f{litmIV
cffrey S. Sank, Esquire, ID #74471
Attorney for Defendant
222 South Market Street, Suite 201
Elizabethtown, P A 17022
(717) 367-1370
Date: Gft~!
7
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Pauline Wallin, Ph.D.
Licenud Psycho/agist
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20 I Sou,h 320d 5"..,
Camp Hill, PA 17011
& Associl.l/es
(717) 761.1814
FAX (717) 761-1942
March 3, 1998
t~~1f
Douglas Moore
Angeln Turner
29 East Locust Street
Mechanicsburg, P A 17055
Dear Doug & Angela:
On February 16, 1998 I wrote to you, requesting that you complcte the psychological testing,
which is part of the court ordered custody evaluation. As of today you have not made
arrangements to complete the tests.
For the children's sake, it is important that this evaluation reach closure as soon as possible.
Therefore, if [ don't hear from you by March 12, 1998, I have no option but to write my report
without your test data. In that case I would have to note in the report that you refused to co-
opcrate with this part of the evaluation process.
I'm sure there is a good reason why you haven't contacted me. Pleasc call me at your earliest
convenience.
Sincerely,
'''0 .
C5L-j~~,--~ C{jc-JL~
Pauline Wallin, Ph.D.
Licensed Psychologist
PW/re
cc: Philip Spare, Esq.
John R. Beinhaur, Esq.
CONSULTATION' EVALUATION' PSYCIIOTlIERAPY
, -
GINGRICH. SMITH. KLINGENSMITH & DOLAN
ATTORNEYS AT LAW
222 SOuTH MARKET STREET, SUITE 201
P O. BOX 267
ELIZA8ETHTOWN. PA 17022.0267
(717) 367-1370
FAX (717) 367-3219
JOHN M. SMITH
THO,..AS G. KLINGENSMITH
KEVIN D. DOL.AN
HE:RBE.RT P. HENOERSON, II
JItl"I"REY S. SHANK
4!!5 EAST ORANCE STREET
L.ANCASTER, PA 17602
17171 393-3664
FAX I?'?i 393-06!!53
01'" COUN9l:L
HeNRY F. GINGRICH
August 28, 1998
Honorable Edward Guido, Judgc
Cumbcrland County Courthouse
One Courthouse Squarc
Carlisle, P A 17013
RE: Moore vs. Moorc 'f$11
Action in Custody 96~
Dear Judge Guido:
On behalf of my client and the above-named Defendant, Ms. Moore, 1 withdraw her Petition
for Emergency Relief. Please cancel the hearing scheduled for Monday, August 31,1998 at 8:30
a.m.
Mr. Spare and I have had discussions with your staff regarding how best to proceed to a
hearing on the merits of this custody action and I will await Your Honor's direction in that regard,
Thank you for your kind attention to this file.
Very truly yours,
GINGRICH, SMITH, KLINGENSMITH & DOLAN
6b&#Y
JSS:tmr
pc: Ms. Mclissa P. Moore
Philip H. Spare, Esquire
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LAW OFFICI:"
SNELOAKfm.
BRENNEMA.N
& SPARE
DOUGLAS P. MOORE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL TERM
NO. 96-4597
MELISSA P. MOORE,
Defendant
CUSTODY OF MINOR CHILDREN
ORDER
AND NOW, this ..), dayof ",{"...)",,-- ,1997,upon
consideration of the attached petition~or Emergency Relief, it
is hereby directed that tpe parties and their respective counsel
appear before h~\\. JI' :-,. :',\...J\ .\('\C1....../--, Esquire, the conciliator,
at .
"Cf W. i~\-'\\"'\ ";\-, . tJ,["'( ~n" \', . \', ~(~ ' Pennsylvania, on
the 'f') day of ,,,,',,\('[\,\ (,.(', '1997, t Cl o'clock ..b.-.M.
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 also be present at the conference.
Failure to appear at the conference may provide grounds for entry
of a temporary or permanent order.
FOR THE COURT,
By: .,t,:\ \ \ : \s."\' '7\ n cJ'C'UJ (:.(6'
Custody conc1ll.ator C' \, )
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 made at least 72 hours prior to any hearing or business
before the court. You must attend the scheduled conference or
'1J1ear ing.
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
COURTHOUSE, 4TH FLOOR
CARLISLE, PA 17013
(717) 240-6200
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1.AW OFFICe!;
SNELBAKER,
BRENNEMAN
Be SPARE
5. A custody Conciliation Conference was held on September
11, 1996 with Dawn S. Sunday serving as conciliator.
6. An agreement was reached at the Conciliation Conference
resulting in the issuance of an Order of Court dated september
16, 1996, a copy of which is attached hereto as Exhibit A and
incorporated herein by reference thereto.
7. Pursuant to the September 16, 1996 Order of Court, the
parties share legal custody and share physical custody of the
children on a weekly basis.
8. During the 1996-97 school year, Jacquie attended
Northside Elementary School in Mechanicsburg.
9. In or about April, 1997 Mother relocated from the
Dillsburg area to her current address in Elizabethtown, Lancaster
county.
10. From in or about April, 1997 through the end of the
1996-1997 school year, Jacquie lived with Father in
Mechanicsburg.
11. During the summer vacation, the parties renewed the
"week on - week off" shared custody arrangement.
12. Jacquie enrolled for school at Northside Elementary
School in Mechanicsburg and began her first grade classes on
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Tuesday, August 26, 1997.
13. Mother is threatening to remove Jacquie from school in
Mechanicsburg and to place Jacquie in school in Elizabethtown,
Lancaster county, Pennsylvania against Father's wishes.
14. It is in Jacquie's best interest to remain in classes
at Northside Elementary School.
15. It would be impractical to have Jacquie live with
Mother in Elizabethtown during the school year while attending
Northside Elementary School in Mechanicsburg.
16. It is in Jacquie's best interest to have Father retain
primary physical custody of her during the school year.
WHEREFORE, Petitioner, Douglas P. Moore, respectfully
requests your Honorable Court to enter an order: 1) maintaining
the status quo with Jacquie N. Moore attending Northside
Elementary School; and 2) awarding primary physical custody of
said child to Father during the school year.
SNELBAKER, BRENNEMAN & SPARE, P. C.
By:
LAW OFFIces
SNELBAKER.
BRENNEMAN
Be SPAR!,;
Date: August 26, 1997
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DOUGLAS P. MooRE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 96-4597
CIVIL TERM
MELISSA P. MOORE,
Defendant
: CUSTODY OF MINOR CHILDREN
ORDER OF CXlURT
AND NCM, this flog, day
consideration of the attached Custody
and directed as follows:
:J ___ ,
of ,;xU.lll<'~"-'
Conciliation Report,
1996, upon
it is ordered
1. The Father, Douglas P. Moore, and the Mother, Melissa P. Moore,
shall have shared legal custody of Jacquie Nicole Moore, born December 24,
1990, and Weylin Kyle Moore, born June 20, 1994.
2. The parties shall have shared physical custody of the Children on
a weekly basis, with the exchange of custody to take place every Friday at
4:00 p.m.
3. If the Mother, during her periods
the Children at the trailer located
Pennsylvania, the Mother shall insure that
also present in the trailer.
of custody, stays overnight with
on Red Bank Road in Dover,
Douglas Stone's children are not
4. Arrangements for custody of the Children over holidays and summer
vacations shall be made by mutual agreement of the parties.
5. This Order is entered pursuant to an agreement of the parties at a
Custody Conciliation Conference. . The parties may modify the provisions of
this Order by mutual agreement. In the absence of mutual agreement, the
terms of this Order shall control.
6. If, after following the weekly shared Gustody arrangements for a
two (2) month period, either party desires to modify this Order, that party
may Petition the Court to have the case again scheduled with the Custody
Conciliator for a Conference.
BY THE COURT,
/' / -;.f.-, u..eeL I:' ...lA'it;; J.
cc: Philip H. Spare, Esquire
John R. Beinhaur, Esquire
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A ,"it... Prot/;.jrJury
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EXHlon' A
VERIFICATION
I verify that the statements made in the foregoing Petition
are true and correct.
I understand that false statements herein
are made subject to the penalties of 18 Pa. C.S. S4904 relating
to unsworn falsification to authorities.
), //'..
I- <t"-7:'.o> / "';,/,-:O-{,./""-
. Douglas P. Moore
Date: August 26, 1997
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IN THE COIJRT OF COMMON PLEAS OLClJMRERL\ND COUNTY, PENNSYLVANIA
CIVIL TERM
DOUGLAS P. MOORE,
Plaintiff
)
)
)
)
)
)
)
Custody of Minor Childrcn
No. 96-4597
vs.
MELISSA P. MOORE,
Dcfcndant
PKAF\iPr.
TO THE PROTHONOTARY:
Please substitutc the appcarancc of Jcffrcy S. Shank, Esquirc, of Gingrich, Smith,
Klingcnsmith & Dolan for John R. Bcinhaur, Esquirc ofBcinhaur & Curcillo on bchalfofthe above-
namcd Dcfcndant in conncction with thc abovc-captioned matter.
Datc: ??/ut/qr;
fil!ig~~-
ID # ~<)h ::s I
Rcspcctfully submittcd,
Datc: Bps! rfJ
GINGRICH, SMITH, KLINGENSMITH & DOLAN
(~r{~'{-1/Z-1/'
cffrey S. Shank, EsqUlrc, 10 #74471
Attorncy for Dcfcndant
222 South Markct Strcet, Suitc 201
Elizabcthtown, P A 17022
(717) 367-1370
By:
10, Admitted with clarification, Thc pcriod rcferenced in paragraph 10 is a pcriod of
approximately four wceks, This pcriod oftimc was thc period oftimc during which Dcfcndant
was in the proccss of relocating to Elizabethtown, Pcnnsylvania. due to thc constant harassmcnt
of Plain tifT, Plaintilrs girlfriend and various ofPlaintitT's family mcmbcrs. During said
approximate four week period, mothcr maintaincd her sharcd custody outside of the kindergartcn
school hours. Thc parties did not make any agreement, oral or writtcn, for father to assume that
Jacquie would thereafter be in his full-time custody for each and every school year after
kindergarten,
11. Admitted.
12. Denied. It is denied that Jacquie enrolled in any school. To the contrary, father and
his family enrolled Jacquie at Northside for her first grade class after mother and father agreed
that they would abide by Jacquie's wishes as to which school she wanted to attend. Jacquie chose
Elizabethtown and father stated that he had to hear it from Jacquie. Jacquie confirmed this to
father and father became infuriated, stating that all agreements were ofT. Jacquie explained that
she wanted to go to school and stay with Mother but was concerned about making father, father's
girlfriend and father's family mad at her. Father stated that the Court would decide and Jacquie
would come to live with him and his girlfricnd. Additionally, Mother had informed father that she
was enrolling Jacquie in East High Elemcntary School across the strect from her home as the
parties had agrced to allow Jacquic to dccide for hersclf
13, Denied, Mothcr is not threatening anyonc. To the contrary, the only threats have
been from father and his girlfriend against Mother. Additionally, father and his girlfriend and
family are coaching Jacquie with false commcnts about Mothcr and her home. Finally, father's
wishes were consulted and it was hc who suggestcd that Jacquie dccide whcrc shc wished to go
to school, then reneged and had this emergency Order put in place to create funher emotional
turmoil in not only Mother but child.
14. Denied. Jacquie's best interests were considered as the panies attempted to resolve
the issue, however, after father did not receive the result he was expecting, he went into denial
and had an emergency Order placed. Jacquie's best interests are served by her attending school
where she wanted to go in the first place. However, with the delay created by the placing of an
emergency Order, Mother is greatly prejudiced and Jacquie has undoubtedly had much coaching
from father, father's girlfriend (someone who represents herselfas the child's mother) and father's
family.
15. Denied. This allegation assumes arguendo that the decision of Jacquie's school
attendance has already been decided by this Honorable Coun in favor of the party who reneged
on his agreement, to allow the child to decide, when the decision was not in his favor.
16. Denied. For all of the reasons set forth above and because this is a mere ploy to deny
Mother her custody rights, this allegation is denied.
WHEREFORE, DefendantlRespondent respectfully requests this Honorable Court award
primary physical custody of Jacquie N. Moore, as well as Weylin K. Moore, to Mother during the
school year and terminate the emergency Order in effect.
Date: September 2!L, 1997
Respectfully submitted
BEINHAUR & CURC~
By. ~ .L i&
Jo R. Beinhaur, Es uire
Supreme Court ID#5563I
4650 Fritchey Street
Harrisburg, P A 17109
(717) 651-9100
Attorneys for Defendant/ Respondent
LAW OFFICE!>
SNELOAKl;:R
8<
BRENNEMAN
DOUGLAS P. MOORE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
I v.
I MELISSA
P. MOORE,
Defendant
NO. (iL.LI~)(n CIVIL TERM
CUSTODY OF MINOR CHILDREN
ORDER
AND NOW, this /(,(J...- day of fi"4'i.1[' 1996, upon
consideration of the attached complaint,) it is hereby directed
that the parties and their respective counsel appear before
1.!r,,,-..~ .1.( (~.,.J.('-Lr ,Esquire,. the conciliator, at .
" - I ,- O. .V-d'I,;"r. -I).;. J I.' -t lI'H'':\ I pennsyl vanJ.a, on
the Il-toL day of .leo! ,1996, 1/.0(; o'clock ~.M.
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 also be present at the conference.
Failure to appear at the conference may provide grounds for entry
of a temporary or permanent order.
FOR THE COURT,
By: D(~.u'"" j) Jkl".) a tL /.
Custody ConciliatSt~
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 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 FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, 4TH FLOOR
CARLISLE, PA 17013
(717) 240-6200
LAW OFFICES
SNELBAKER
.
BRENNEMAN
";
4. During the last five (5) years, the children have
resided with the following persons and at the following
addresses:
PERSONS
ADDRESSES
DATES
Douglas P. Moore
Douglas P. Moore
Melissa P. Moore
Douglas P. Moore
Melissa P. Moore
820 Green Lane
Mechanicsburg, PA
July, 1996 to
present
820 Green Lane
Mechanicsburg, PA
1995 to
July, 1996
1991 to 1995
32 E. Locust st.
Mechanicsburg, PA
Note: Both parents and children temporarily resided in Alabama
for three months during the summer of 1995.
The mother of the children is Melissa P. Moore,
currently residing at the address set forth in Paragraph 2,
above.
She is married to Plaintiff.
The father of the children is Douglas P. Moore,
currently residing at the address set forth in Paragraph 1,
above.
He is married to Defendant.
5. The relationship of Plaintiff to the children is that
of father. The Plaintiff currently resides with the following
persons:
NAME
RELATIONSHIP
Jacquie Nicole Moore
daughter
Weylin Kyle Moore
son
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DOuGLAS P. MOORE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND ooUNTY, PENNSYL VANIA
vs.
NO. 96-4597
CIVIL TERM
MELISSA P. MOORE,
Defendant
CUSTODY OF MINOR CHILDREN
ORDER OF COORT
this g,r~y of.f!Y/~
consideration of the attached Custody Conciliation Report,
and directed as follows:
AND
NCW,
1996, upon
it is ordered
cc:
1. The Father, Douglas P. Moore, and the Mother, Melissa P. Moore,
shall have shared legal custody of Jacquie Nicole Moore, born December 24,
1990, and Weylin Kyle Moore, born June 20, 1994.
2. The parties shall have shared physical custody of the Children on
a weekly basis, with the exchange of custody to take place every Friday at
4:00 p.m.
3. If the Mother, during her periods
the Children at the trailer located
Pennsylvania, the Mother shall insure that
also present in the trailer.
of custody, stays overnight with
on Red Bank Road in Dover,
Douglas Stone's children are not
4. Arrangements for custody of the Children over holidays and summer
vacations shall be made by mutual agreement of the parties.
5. This Order is entered pursuant to an agreement of the parties at a
Custody Conciliation Conference. The parties may modify the provisions of
this Order by mutual agreement. In the absence of mutual agreement, the
terms of this Order shall control.
6. If, after following the weekly shared custody arrangements for a
two (2) month periOd, either party desires to modify this Order, that party
may Petition the Court to have the case again scheduled with the Custody
Conciliator for a Conference.
BY THE ooURT,
II~/:=-~
Philip H. Spare, Esquire
John R. Beinhaur, Esquire
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SNELBAKER, BRENNEMAN & SPARE
44 West Maill Street
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Douetas p, Moore VS, M,'li""" I' MOllf"
No, 96.4597 - Acti"" ill Custudy ),
Dear Mr, Spare: ., /
This letter will c""firm nUl cIl"velsati\J" a felV minules ago wherehy I inulcaled Ms. Moore
has alllhonzed me 10 withdraw her P,:/i/io" ror Frnl"f.""cy Relief alld cancel the hearing t.chedulcd
for Monday morning, August 31, 1998 al 8,:lO a,m. in Cumbcrland COUllll'.
Thank you f," yuur a~:;i'Ii1I1Cc IcganlillL; sclledulinr, proceedings in Cumberland County,
Vcry truly yours,
~
CirNGRJCII. S1I11HI, KI.INUENS\f1TH 8: DOT.,\~
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I.. Je~ey $, Shank
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pc: Ms, M,~li,sa p, MOM"
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1I0no',,0Ic Edward Guido (hy j"acsimile to Chambers 24IJ-6462) /
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Plaintiff
: IN TilE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
: PENNSYLVANIA
v.
. \"\1:\\ S2,C:\ fl. t-Aoo ~
Dcfcndant
: CIVIL ACTION LAW
: No.Y'::/ll CIVIL 19%
: CUSTODY VISITATION
ORDER or COURT
And now, this ~ \ \<::; 1't3 upon consideration of the attachcd complaint, it is hercby directed
that the abovc parties and thcir rcspective counsel appcar bcforc f"r,,,,In ,\. :)...,.'\r\~f ,
Esquire, thc conciliator, at :<"9 \..1, Mo.\S' ~') \--\e( 1r-rY\\C \'v>.f~ I ,
Pennsylvania, on the ,~\ day of ('K \ r;hr- r , 1998, at \', \') A.MJ~
for a Pre-hearing Custody Confcrcnce. At such confcrencc, an effort will be made to resolve t e
issues in dispute; or if this cannot bc accomplished, to dcfine and narrow thc issucs to be heard
by the court, and to enter into a temporary ordcr. All children age five or older may be present at
the conference. Failure to appear at the conferencc may provide grounds for the entry of a
temporary or permanent order.
FOR THE COURT:
By: N:$O\\\'(\ ~, JjH~J~'
Custody Conciliator l 'i'W.)
YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER 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,
-.'
THE CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
1-800-990-9108
FEO'C:;'F'CF
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NOV 0 2 1995tP
.
DOUGLAS P. MOORE
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 96-4597 CIVIL TERM
CIVIL ACTION - LAW
MELISSA P. MOORE,
Defendant
IN CUSTODY
ORDER OF caJRT
AND NCW, this 1(.j4..
consideration of the attached
and directed as follows:
day Of,J~ ,
Custody Conciliation Report, it
1998, upon
is ordered
1. The prior orders of this Court dated September 16, 1996, August 27,
1997, and OCtober 15, 1997 are vacated and replaced by this order.
2. The Father, Douglas P. Moore, and the Mother, Melissa P. Moore,
shall have shared legal custody of Jacquie Nicole Moore, born December 24,
1990, and Weylin Kyle Moore, born June 20, 1994. Each parent shall have an
equal right, to be exercised jointly with the other parent, to make all
major non-emergency decisions affecting the Children's general well-being
inclucJing, but not limited to, all decisions regarding their health,
education and religion.
3. The Mother shall have primary physical custody of the ChilcJren.
4. The Father shall have partial physical custody of the Children on
alternating weekends from Friday at 5:00 p.m. until Sunday at 6:00 p.m. (or
at such time other times as the parties may agree) and on weekday evenings
as arranged by agreement of the parties. The parties agree to continue to
be flexible in making arrangements for weekend periods of custody which
best suit the parties' work schedules and needs and both parties agree not
to unreasonably withholcJ consent for a change in the custody arrangements
on weekends as requested by the other party.
5. The parties shall have custody of the Children on holidays as
follows:
A. Thanksgiving: In 1998, the Mother shall have custody of the
Children over the Thanksgiving holiday.
B. Christmas: In 1998, the Father shall nave custody of the Children
from Christmas Eve at 6:00 p.m. (when the Father shall pick up the
Children from the Mother's residence) until Christmas Day at 2:00
p.m. and from December 26 at 2:00 p.m. until New Years Day at 2:00
p.m. In 1998, the Mother shall have custody of the Children from
Christmas Day at 2:00 p.m. (when the Mother shall pick up the
Children at the Father's residence) until December 26 at 2:00 p.m.
and again, beginning on New Years Day at 2:00 p.m.
C. Easter: In 1999, the Father shall have custody of the Children on
DOUGLAS P. MCORE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
I
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vs.
: NO. 96-4597 CIVIL TERM
MELISSA P. MOORE,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
PRICR JUDGE: Edward Qlldo
CUS'J.'CXJY CXH:ILIATICN SlHIARY REPCRl'
IN Aco:JlDANCE WITH a.tIBERLAND <XXm'Y RULE OF CIVIL PROCEllURE
1915.3-8, the undersigned CUstody Conciliator submits the fOllowing report:
1. The pertinent information concerning the Children who are the
subjects of this litigation is as follows:
Jacquie NiCOle Moore
Weylin Kyle Moore
12/24/90
6/20/94
Mother
Mother
NAME
DATE OF BIRTH
aJRRFm'Ly IN CUS'J.'CXJY OF
2. A Conciliation Conference was held on October 27, 1998, with the
following individuals in attendance: The Father, Douglas P. Moore, with
his counsel, Philip H. Spare, Esquire, and the Mother, Melissa P. Moore,
with her counsel, Jeffrey S. Shank, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
I) c.J-v Iv /I
Date
d [, /79,f
,
,(J~o~~
Dawn S. Sunday, Esquire
CUstody Conciliator