HomeMy WebLinkAbout96-05481
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OCT 2 6 199a ,p
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JEFFREY BRIAN CONLEY, SR.,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 96-5481 CIVIL TERM
CHRISTINA L. CONLEY,
Defendant
CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NCM, this .z r-
consideration of the attached
and directed as follows:
day of cijc ly..,. , 1998, upon
Custody Conciliation Report, it is ordered
1. The prior order of this Court dated June 11, 1998 is vacated and
replaced with this Order.
2. The Father, Jeffrey Brian Conley, Sr., and the Mother, Christina
L. Conley, shall have shared legal custody of Jeffrey Brian Conley, Jr.,
born August 3, 1993. Each parent shall have an equal right, to be
exercised jointly with the other parent, to make all major non-emergency
decisions affecting the Child's general well-being including, but not
limited to, all decisions regarding his health, education and religion.
Specifically with regard to the administration of ritalin during the
Father's periods of custody with the Child, the Father agrees to abide by
the advice of the Child's regular treating physician as to the necessary
dose and frequency of the medication.
3. The Mother shall have primary physical custody of the Child.
4. The Father shall have partial physical custody of the Child on
alternating weekends from 5:00 p.m. on Friday through 7:00 p.m. on Sunday,
and every week, beginning October 28, 1998, from Wednesday at 5:00 p.m.
through the following Thursday morning when the Father shall take the Child
to the Mother's residence by 7:30 a.m. or transport the Child directly to
school. The Father shall notify the Mother by the evening before as to the
Thursday morning arrangements. The Father shall have any additional
periods of custody with the Child as arranged by agreement of the parties.
5. Except as specifically provided in this paragraph, the parties
shall share or alternate having custody of the Child on holidays as
arranged by agreement of the parties. In 1998, the Mother shall have
custody of the Child over the Thanksgiving holiday/weekend if the Mother
travels to North Carolina to celebrate the holiday. If the Mother does not
go to North carolina for Thanksgiving in 1998, the parties shall share
custody of the Child over the Thanksgiving holiday. Over the Christmas
holiday in 1998 , the ~other shall have custody of the Child from Christmas
Eve at 3:00 p.m. through Christmas Day at 3:00 p.m. and the Father shall
have custody of the Child from Christmas Day at 3:00 p.m. through the end
of the holiday school break.
.
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MAR ] 8 1998 f;i7
JEFF BRIAN CONLEY, SR.,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:
V
:CIVIL ACTION - LAW
.
.
CHRISTINA L. CONLEY,
Defendant
:NO: 96-5481
:IN CUSTODY
COURT ORDER
AND NOW, this /ti<;' day of March, 1998, upon consideration of the
attached Custody Conciliation Report, it is ordered and directed as
follows:
1. A hearing is scheduled in court~oom No. ;tOf the Cumberland
County Courthouse on the /1 J day of Ckf /}1 '" _/ ,
1998, at 'i;jOr"m. at which time testimony willt1be taken in
this case. At this hearing, the Mother, Christina L. Conley,
shall be the moving party and shall proceed initially with
testimony. Counsel for the parties, or the parties themselves
if they do not have legal counsel, 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 who
will be called to testify and a summary of the anticipated
testimony of each witness. This memorandum shall be filed at
least ten days prior to the mentioned hearing date.
2. Pending further Order of this Court, the following temporary
Custody Order is entered:
A. This Court's Order of November 4, 1996 is vacated.
B. The Father, Jeff Brian Conley, Sr., and the Mother,
Christina L. Conley, shall enjoy shared legal custody of
the Jeff Brian Conley, Jr., born August 3, 1993,
C. The Father shall have physical custody of the minor child
on alternating weeks from Thursday at 5:00 p.m. until
Monday morning at 8:00 p.m. when he shall deliver the
child back to the Mother's custody. Father shall also
have custody at least one evening a week from 5:00 p.m.
until 8:30 p.m. upon Father giving Mother 24 hours notice
as to when he desires to exercise that one evening per
week.
D. Mother shall have physical custody of the minor child
when the child is not in the Father's custody.
~
JEFF BRIAN CONLEY, SR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:
v
:CIVIL ACTION - LAW
:
CHRISTINA L. CONLEY,
Defendant
:NO: 96-5481
: IN CUSTODY
Prior Judge: George E. Hoffer
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE
1915.3-8(bJ, the undersigned Custody Conciliator
following report:
1. The pertinent information pertaining to the child who is the
subject of this litigation is as follows:
OF PROCEDURE
submits the
Jeff Brian Conley, Jr., born August 3, 1993.
2. A Conciliation Conference was held on March 12, 1998, with the
following individuals in attendance:
The Father, Jeff Brian Conley, Sr., who appeared without
counsel, and the Mother, Christina L. Conley, who appeared
with her counsel, Jacqueline M. Verney, Esquire.
3. The parties had a prior Custody Order in November of 1996
whereby they agreed to the entry of an Order at a Conciliation
Conference. That Order provided for the Father to have
primary physical custody of the minor child with the Mother
having periods of temporary custody. Shortly after the entry
of that Order, the parties reconciled. The parties then again
separated in April 1997 at or around the time a protection
from abuse order was entered against the Father. Mother
suggests that she has had primary custody over the past year
and that Father has not exercised primary custody. Father
suggests that he has had a good amount of time with the child
and has been the primary custodian over the past year. He
further suggests that Mother has been in violation of the
November 4, 1996, Order.
4. Mother wants primary physical custody. Father wants primary
physical custody. The parties are unable to agree upon the
entry of a permanent order. A hearing is required and should
take no more than one day.
.~
5. Based upon the information presented to the Conciliator at the
Custody Conciliation Conference, the Conciliator reconunends an
interim Custody Order as set forth in the attached proposed
Order.
3117/ qr
DATE
{7? pf' (<J. ~
Hubert x. Gilroy, Esq
Custody Conciliator
. \
v,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION. LAW
: IN CUSTODY
JEFF BRIAN CONLEY, SR.,
PlaintifflRe~ondent
CHRISTINA L, CONLEY,
Respondent
: NO, 96-5481
ORDER OF COURT
AND NOW, this. \"1 day of 1)('( el-....hC I ,1997,
upon consideration oftbe attacbed petition to ModifY it is hereby directed tbat tbe parties and
their respective counsel shall appear before \'0\\ ( N:1\:" \ L. f'('()J '::, , E<.,C1,' ,
theConciliator,at <0~ " IS\" ,')\-, , ((1'\\(- \ \,\ \. \)/\ ontbe 1M
day of rt-'rr,JCl r '.j ,1997.Sat 1.-\. C)\)--f' ,01., for a Pre-Hearing Custody
Conference, At such corlference, an effort will be made to resolve tbe issues in dispute; or if
this cannot be accomplished, to define and narrow the issues to be beard by tbe Court, and to
enter into a Temporary Order, All children age five or older may also be present at tbe
Conference, Failure to appear at tbe Conference may provide grounds for entry of a temporary
or permanent order.
FOR THE COURT,
BY: lfll~()ndLd'Pilr)l~ -
Custody Conciliator ( (n,\
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 tbe 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
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JEFF BRIAN CONLEY, SR.,
PlaintifffRespondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V,
: CIVIL ACTION-LAW
: IN CUSTODY
CHRISTINA L, CONLEY,
DefendantlPetitioner
: NO. 96-5481
PETITION TO MODIFY CUSTODY
AND NOW, comes the Petitioner, Christina L. Conley, by and through her attorney,
Jacqueline M, Verney, Esquire, and requests a modification of custody as follows:
I. The Petitioner is Christina L. Conley, residing at 802 Bridge Street, Apartment 3, New
Cumberland, Cumberland County, Pennsylvania 17070,
2, The Respondent is Jeff Brian Conley, SI'" residing at 523 Bridge Street Rear Apartment,
New Cumberland, Cumberland County, Pennsylvania, 17070
3, Petitioner seeks a modification of the Custody Order dated November 4, 1996, a copy of
which is attached hereto and made a part hereof and marked as Exhibit "A."
4, The parties are the parents of Jeff Brian Conley, Jr., date of birth August 3, 1993,
5, The Custody Order of November 4, 1996 should be modified for the following reasons:
a, The parties have, by oral agreement, modified the Order of November 4, 1996,
providing for Petitioner to have primary physical custody of the child,
b, Petitioner has had primary physical custody of the child since July I, 1997,
c, Respondent has been unreasonable in making untimely demands for partial physical
custody of the child.
d, Petitioner has provided a loving, caring environment for the child almost exclusively
since July 1,1997,
e. Petitioner is a fit parent who is best suited to continue to provide a proper home for the
child,
6, The best interest and pennanent welfare oflhe child will be met if the custody order is
modified 10 grant Petitioner primary physical custody,
WHEREFORE, Petitioner requests this Court modify the Custody Order dated November
4, 1996, and grant her primary physical custody of the child,
Respectfully submitted,
Dated: /_1.-/;" /;7
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cq line M, Verney, Esquire
Attorney ill No, 23167
44 South Hanover Street
Carlisle, PA 17013
(717) 243-9190
Attorney for Petitioner
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up the child from day care until the following morning when
she will return the child to day care,
C, Father shall have the child at ell other times.
3. The parties understand that the child will be enrolled
immediately at the Learning and Sharing Day Care Center in New
Cumberland, The child shall remain in that day care facility unless the
parties agree to change the child's day care provider.
4. Mother shall have the child for Thanksgiving Day in 1996
from 9:00 a.m. until 7:30 p.m.
5. The parties shall share the Christmas holiday such that
Father shall have the child from 12:00 noon on December 24 until
12:00 noon on Christmas Day, and Mother shall have the child from
12:00 noon on Christmas Day until 12:00 noon on December 26.
6, The parties acknowledge that this is a temporary Order and
that they shall reconvene for another conciliation conference before
Michael L. Bangs, Esquire on Thursday. February 20, 1997, at 9:00
a.m.
BY THE COURT,
15/ Jie~f2..
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Barbara Sump Ie-Sullivan, Esquire
Robert J. Mulderig. Esquire
J,
nUE COpy FROM RECORD
Ir. Tnlt:r:-"I'w,v \",.h:r. ~f. I h~;.' 1.'!1tO set my hand
and the seai 0; 3did :ou~i at Carlisle, Pa,
This .....:~j. of....7.}gy::.,.. 19..9.~
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JEFF BRIAN CONLEY, SR"
Plaintiff
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CHRISTINA l. CONLEY, )
Defendant ) CUSTODY
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
NO. 96-5481 CIVil TERM
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AND NOW, this ~ day of () V. , 1996, upon receipt
of the Conciliator's Report, it appearing that the parties have reached a temporary
agreement, the terms and provisions of that temporary agreement which was
dictated in their presence and approved by them and their counsel, it is hereby
ordered and directed that:
1, The parties shall share legal custody of their minor child, Jeff
Brian Conley, Jr., d.o,b, August 3, 1993.
2, Physical custody of the minor child will be in accordance
with the following schedule:
A, The child will be with Mother from Thursday,
October 31, 1996, until Monday, November 4, 1996. Mother
shall pick the child up from day care and return the child to day
care. This schedule will continue on an alternating weekend
basis.
B, Mother shall have the child on alternating Tuesdays
beginning Tuesday, November 12, 1996, from when she picks
,
,
"
,
up the child from day care until the following morning when
she will return the child to day care,
C, Father shall have the child at all other times,
3. The parties understand that the child will be enrolled
immediately at the Learning and Sharing Day Care Center in New
Cumberland, The child shall remain in that day care facility unless the
parties agree to change the child's day care provider,
4, Mother shall have the child for Thanksgiving Day in 1996
from 9:00 a,m, until 7:30 p.m,
5. The parties shall share the Christmas holiday such that
Father shall have the child from 1 2:00 noon on December 24 until
12:00 noon on Christmas Day, and Mother shall have the child from
12:00 noon on Christmas Day until 12:00 noon on December 26.
6, The parties acknowledge that this is a temporary Order and
that they shall reconvene for another conciliation conference before
Michael L. Bangs, Esquire on Thursday, February 20, 1997, at 9:00
a,m,
BY THE COURT,
J.
Barbara Sumple-Sullivan, Esquire
Robert J. Mulderig, Esquire
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JEFF BRIAN CONLEY, SR"
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs,
NO. 96-5481 CIVIL TERM
CHRISTINA L. CONLEY,
Defendant
CUSTODY
JUDGE PREVIOUSLY ASSIGNED: None
CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8(bl. the undersigned Custody Conciliator submits the
following report:
1. The p<>rtinent information concerning the child(ren) who is(are) the
subject of this litigation is as follows:
NAME
BIRTHDATE
CURRENTLY IN
CUSTODY OF
Jeff Brian Conley, Jr.
August 3, 1993
Plaintiff
2, A Conciliation Conference was held on October 31, 1996, and the
following individuals were present: the Plaintiff and his attorney, Barbara Sumple-
Sullivan, Esquire; the Defendant appeared with her attorney, Robert J. Mulderig,
Esquire,
3, Items resolved by agreement: See attached Order.
4, Issues yet to be resolved: An ultimate custody schedule,
5. The Plaintiff's position on custody is as follows: See attached Order.
6, The Defendant's position on custody is as follows: See attached Order,
7, Need for separate counsel to represent children: Neither party requested.
8, Need for independent psychological evaluation or counseling: None
requested and the Conciliator does not believe any is necessary,
Date: November 1, 1996
Michael L Bangs
Custody Conciliator
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MAR 3 19~ff'
JEFF CONLEY. SR,.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY. PENNSYLVANIA
Plaintiff
NO, 96-5481 CIVIL TERM
V.
CHRISTINA L. CONLEY,
Defendant
CIVIL ACTION LAW
CUSTODY NO 94-SU-04920-03
N~ <h', b ~.Y Of/!!1).:~::: roM''''rn''oo of <h. m"'oo of ''''''0"''''
Petition to make Rule Absolute, leave is granted to withdraw the appearance of BARBARA
SUMPLE-SULLIVAN, ESQUIRE, as counsel for Jeff Conley Sr,
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. JEFF CONLE {, SR"
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYLVANIA
Plaintiff
v,
NO. 96-5481 CIVIL TERM
CHRISTINA L. CONLEY,
Defendant
CIVIL ACTION - CUSTODY
AFFIDAVIT OF SERVICE
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I. Barbara Sumple-Sullivan, Esquire. do hereby certify that I served a copy of the Order
of Court dated October 9, 1996 and Custody Complaint in the above-captioned matter by United
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i ~tates Mail. Restricted Delivery. Certified No, P 377 421 204, Return Receipt Requested, on
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; the above-named Defendant, Christina L. Conley. on October 16. 1996. at Defendant's last
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i known address: 104 Frederick Street. Mechanicsburg, Pennsylvania. 17055. The original
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! receipt and return receipt card number are attached hereto as Exhibit "A",
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Barbara Sumple-Sullivan, Esquire
. 549 Bridge Street
New Cumberland. P A 17070-1931
(717).774-1445
Supreme Court ID # 32317
; Dated: October 21. 1996
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JEFF CONLEY, SR.,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
CHRISTINA L. CONLEY,
Defendant
NO. 96-5481 CIVIL TERM
ORDER OF COURT
AND NOW, this lr~ay of October, 1996, upon consideration of
Petitioner's Petition for Emergency Relief, it is ORDERED and
DIRECTED that pending further order of court neither party shall
remove the child, Jeff Brian Conley, Jr., from the Commonwealth of
Pennsylvania nor conceal the location of the child from the other.
EITHER party may request an emergency hearing if the parties
are unable to agree upon a custody arrangement pending the
conciliation conference.
BY THE COURT,
J.
Barbara Sumple-Sullivan, Es ,~
549 Bridge Street /'/HO'1 ,-C ,} U II< I" /, OJ'
New Cumberland, PA 17070 .~ ~~ IU-~- ~p
Attorney for Petitioner/Plaintiff
Christine L. Conley
104 Frederick Street
Mechanicsburg, PA 17055
Defendant
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7, Most recently, Respondent was arrested and charged on September 27, 1996.
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: after further domestic altercation. for recklessly endangering another person and resisting arrest.
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i Pending hearing on October 3. 1996, Respondent. was released on bail but has been excluded
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: from the marital home at that time at the request of the District Justice, However, no fonnal
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~rotection From Abuse Order issued,
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imd flee the area with the child,
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Responder.t has repeatedly indicated that she was going to take the minor child
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: pn September 26, 1996 by riding past the alley behind their house, following them in the car,
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10, On October 3, 1996, Respondent followed the Petitioner to the parking lot at a
paint store and parked her car behind his car, The Petitioner had the child in a safety seat in his
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~ar, Respondent asked the Petitioner if she could speak to the child, to which he did agree,
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i However, when he looked away, she grabbed the child from the vehicle and attempted to flee
'with him.
11. Petitioner is fearful, in light of Respondent's instability, uncertainty of residence
: hnd expressed intention to flee with the child, in addition to her actual physical efforts to remove
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the child from his care, that further attempts to take the child will be successful.
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2
JEFF BRIAN CONLEY, SR" IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. 96-5481 CIVIL TERM
CIVIL ACTION - LAW
CHRISTINA L. CONLEY,
Defendant IN CUSTODY
IN RE: CUSTODY
ORDER OF COURT
AND NOW, this 11th day of June, 1998, this matter
having been called for hearing, and the Plaintiff/Respondent
having failed to appear, primary legal and physical custody of
the child, Jeff Brian Conley, Jr., born August 3rd, 1993, is
awarded to his mother, Christina L. Conley, subject to such
rights of partial custody in the father, Jeff Brian Conley, Sr.,
as the parties shall agree. Pending further order, said periods
of partial custody shall be supervised, again as the parties
shall agree.
Jacqueline Verney, Esquire
44 South Hanover Street
Carlisle, PA 17013
For Plaintiff
Jeff Brian Conley, Sr,
523 Bridge Street
Rear Apartment
New Cumberland, PA 17070
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
JEFFREY BRIAN CONLEY, SR"
Plaintiff
CIVIL ACTION .. LAW
!CHRlSTlNA L. CONLEY,
"
, Defendant
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NO, 96-5481 CIVIL TERM
IN CUSTODY
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I: ORDER OF COURT
ii AND NOW, this "I day of t--)y:* , 1998, upon consideration of the
ilPetition to Modify filed in this matter, it is hereby directed that the parties and their
!Irespective counsel appear before lnw(\ s., ~\, nr\cl'o-..../_' the conciliator, at
ilYi \J. \"'o.i(\,,* '] \"\.c-~ \"'\X-\\( <. h.s::> ,Pennsylvania, on \r,IP C\ , ,the
[1 ') day ofx&n"'h-c r, 1998, at \ o'clock ~,m, for a Pre-Hearing
i:Custody Conference, At such conference, an effort will be made to resolve the issues in
::
i'dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by
I~he Court, and to enter a temporary order, All children aged five or older may also be
Ibresent at the conference, Failure to appear at the conference may provide grounds for
!!entry of a temporary or permanent order,
I'
1\ 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
I
[FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
I COURT ADMINISTRATOR, FOURTH FLOOR
II CUMBERLAND COUNTY COURT HOUSE
,
:11 CARLISLE, PENNSYLVANIA 17013
il TELEPHONE: (717) 240-6200
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Ip1 Testin')('ny 1'Ii:: r.. , ' 1 h, ", u,::o s(1 my hand
irnd lnc sc,d of s(lid . at CJr!1.~!c, Pa.
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FOR THE COURT,
BY ~[)(Tl\~ \i\ ~, d\1~ Uv~
CUSTODY CONCILIATOR I
(\';\> ,)
,JEFFREY BRIAN CONLEY, SR..
i Plaintiff
\ vs,
ICHRISTINA L. CONLEY,
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
Defendant
NO. 96-5481 CIVIL TERM
IN CUSTODY
PETITION TO MODIFY
AND NOW comes the Plaintiff, Jeffrey Brian Conley, Sr" and makes the following Petition to
odify this Court's Order of 11 June 1998, based upon the following:
1. The Petitioner herein is the Plaintiff, an adult individual who currently resides at 5 Bridge
(Street in New Cumberland, Cumberland County, Pennsylvania,
2, The Respondent herein is the Defendant, an adult individual who currently resides at 825
Bridge Street in New Cumberland, Cumberland County, Pennsylvania,
\ 3, On 11 June 1998, this Court entered the attached Order granting primary physical custody of
~he child to the Defendant.
\1 4, The Order of 11 June 1998 was entered in the absence of the Plaintiff who did not attend the
earing because he had not received notice of the hearing.
5, The Order of 11 June 1998 should be modified because it does not set a regular schedule of
ime for the Plaintiff to see his child and because it unnecessarily restricts him to supervision when he has
he child with him,
WHEREFORE, Plaintiff prays this Court to modify its Order of 11 June 1998 to grant him
, rimary physical custody of the subject child or, in the alternative, to set a schedule of shared custody for
I
oth parents,
go' ~J)J)1
Samuel L. An~
Attorney for Plaintiff
Supreme Court JD # 17225
525 N, 12110 Street
Lemoyne, PA 17043
(717) 761-5361
II
!COMMONWEALTH OF PENNSYLVANIA )
I (SS.:
COUNTY OF CUMBERLAND )
Jeffrey Brian Conley, Sr., being duly sworn according 10 law, deposes and says thaI the
facls set forth in the foregoing Petition are lrue and correct to the best of his knowledge,
information, and belief.
Sworn to and subs;:rib;dd
before me this c2 3
of ~LL(;/_
LIYJ
lie,
day
, 1998,
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JEFF CONLEY. SR..
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 96-5481 CIVIL TERM
V,
CHRISTINA L. CONLEY,
Defendant CIVIL ACTION LAW
CUSTODY NO 94-SU-04920-03
AND NOW, this [~ay Of~. 1997, upon the consideration of the
. foregoing Motion, a Rule is issued upon the parties to this action to show cause. if any they
have, why the relief requested in said Motion should not be granted.
RULE RETURNABLE within, ~aYs from the date of service hereof.
"
LAW OFFICES
BARBARA SUMPLE-SULLIVAN
~49 BRIDGE STREET
}lEW CUMBERL..h.'lD. PESNSYLV1\..'lL\ 17070~1931
PIJO~~ (717) 7701,-1441)
FAX (7lll 77...701)0
TO MY CLIENTS: POLICY REGARDING SERVICE, FEES & RETAINER
Quality legal service requires skill and time. My skill and time is my "stock in trade" -- and
generally my fees are based on skill and time expended,
It is always proper for you. my client, to discuss fee arrangements, progress in the matter or
details of a particular bill. It will help you and I if you would read this explanation and discuss
any questions you may have,
TYPES OF FEES
CONSULTATION: For an initial consultation, charges primarily will be based on the time I
spend with you, If my consultation reveals that I need to study the law or facts of your case
further before I decide to take it, I will discuss this further step, and the fee, if any. with you.
STANDARD FEES: I will quote a fixed fee for some standardized services such as the
drafting of routine deeds and wills,
CONTINGENT FEES: In some situations involving lawsuits for recovery of a sum of
money [personal injury suits, for example] I will receive a fixed percentage of the total recovery
as compensation for handling the case, However, all expenses must be paid by you and kept
current on a monthly basis, . .
VARIABLE OR HOURLY FEES: In most matters I will charge an hourly rate of
$100.00, I shall be pleased, however, to furnish yo.u with an idea of the approximate time I will
spend on the matter: However. this figure can only be a rough estimate.
RETAINERS: This office requests a $500,00 retainer fee, The fee is generally a deposit
for costs and expenses which I expect to incur when I agree to proceed with your matter, The
ret?iner is non-refundable,
CHARGING: My office will keep accurate records of the time expended and services
performed on your matter, When I send you my bill, I will specify the time spent on your
matter, how it was spent, and the charge for that time, In addition, you will be billed for actual
disbursements I make on your behalf.
BILLING: You will be billed through the 15th of each month, I expect payment within 30
days, Balances will!>e charged interest at the rate of 1 % per month, Payment in full with each
bill received will avoid the interest charge.
MOST IMPORTANT, IF YOU HAVE ANY QUESTIONS, PLEASE ASK THEM!!
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:JEFF CONLEY. SR..
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYLVANIA
,
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: CHRISTINA L. CONLEY.
Defendant
v.
CIVIL ACTION - CUSTODY
NO, 'il.
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CUSTODY COMPLAINT
i:
1. The Plaintiff is JEFF CONLEY. SR, (hereinafter referred to as ("Father"). who
,
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i burrently resides at 414 Third Street. Apartment 2. New Cumberland. Cumberland County.
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i pennsylvania. 17070,
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2.
The Defendant is CHRISTINA L. CONLEY (hereinafter referred to as "Mother").
I.vho currently resides at 104 Frederick Street. Mechanicsburg. Cumberland County.
:
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Pennsylvania. 17055.
\
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, 3.
,
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,NAME
Plaintiff seeks primary custody of the following child:
PRESENT RESIDENCE DATE OF BIRTH
I:
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,JEFF BRIAN CONLEY. JR.
,
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414 Third St.
New Cumberland
August 3. 1993
1 I 4,
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The child is presently in the custody of the Father who resides at 414 Third
i Street. New Cumberland. Cumberland County. 17070,
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, 13. The best interest and permanent welfare of the child will be served by granting
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I/he relief requested because Plaintiff can provide a stable. loving environment for his child.
befendant is psychologically unstable and has acted with violent and erratic behavior which has
esulted in reckless endangering the life of the Plaintiff and the child.
14. Each parent whose parental rights to the child have not been terminated and the
~erson who has physical custody of the child have been named as parties to this action.
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I fo the Plaintiff.
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I bATE: October 4. 1996
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WHEREFORE, the Plaintiff requests the Court to grant primary custody of the child
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.I Barbara Sumple-Sullivan. Esquire
! 549 Bridge Street
New Cumberland. PA 17070-1931
(717) 774-1445
Supreme Court 1. D. 32317
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iEFF CONLEY. SR.,
Plaintiff
I
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lifHRISTINA L. CONLEY.
Defendant
I
II
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - CUSTODY
NO.
VERIFICATION
I I. JEFF CONLEY, SR.. hereby certify that the facts set forth in the foregoing
!
CUSTODY COMPLAINT are true and correct to the best of my knowledge. information and
I
~elief. I understand that any false statements made herein are subject to penalties of 18 Pa.
I
C.S.A. Section 4904 relating to unsworn falsification to authorities.
!
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DATE: /,;.1 '7 ,) (/,
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0,49 BRIDGE STREET
NEw CUMBERLAND. PENNSYLVANIA 17070~lgOl
POONE (717) 774.14415
FAX (717) 77....7009
February 12. 1997
Robert J. Mulderig. Esquire
32 S. Bedford St.
Carlisle. P A 17013
Jeff Conley. Sr.
414 Third St. Apt. 2
New Cumberland, PA 17070
Dear Mr. Conley and Mr. Mulderig:
Enclosed, constituting service upon you, is the Rule signed by Judge Hoffer in the above-
referenced case on February 8, 1997.
./ \~..
Barbara Sumple-Sullivan
BSS:gkd
Enclosure
c:/conley/service.lIr
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JEFF CONLEY. SR"
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 96-5481 CIVIL TERM
V.
CHRISTINA L. CONLEY,
Defendant
CIVIL ACTION LAW
CUSTODY NO 94-SU-04920-03
AND NOW, this J!!:day of ;.1t.....!r.
, 1997. upon the consideration of the
foregoing Motion, a Rule is issued upon the parties to this action to show cause. if any they
have, why the relief requested in said Motion should not be granted.
RULE RETURNABLE within. S' days from the date of service hereof.
1st' 4~ 1:. l~
J
TRUE COpy FROM RECORD
In T::'~!:l:"~'i1';' I:.i~'r'~of, ! 11',r:: t!!i~' set my hand
and ihe :;:a: of ;ilid Cwrt at Carlisle, Pa.
This ..:l.g,"!!::,. day of.~A,:". 19..9..:7.
.......".._..~~.:~.~~~.t;:t;,.~_....
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JEFF BRIAN CONLEY.
PlaintiJf,
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
CIVIL ACTION. LAW
NO. 96.3385
CHRISTINA HEIKEL,
Defendant
IN CUSTODY
ORDER OF COURT
/J,1Ii 'I J. /
AND NOW, this 7 day of /Jr. ~( , 1996, upon consideration of
the attached Complaint, it is hereby directed that the parties and their respective cOWlSel appear before
'711,~jJ y. Nt"Y' t'1 ' the conciliator, at 30,) .-<1 It r. * '(b/7' ~
onthe3/51 dayof (kti&A ,1996,at.9.'Ct! /l 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 defme and narrow the issues to be heard by the Court,
and to enter into a temporary order. All children age five or older shall 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: 8/ tpu//J Y J63CJr ~
Custody Conciliator ( 12vp) /,12 L
The Court of Common Pleas of Cumberland County is required by Jaw 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 TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW
TO FIND OUT WHERE YOU CAN GET LEGAL HELP. TRUE COpy FP-CM RECORD
Office of the Court Adminisdtnilil!5limony whereof, I here Uolo set my h nd
Cumberland County Court~ahil seal of said (ourl ai, Carhsle, Pa. ,
Fourth Floor 11' 4# day of /,(;/.." 19.~.
Carlisle, PA 17013 liS ,7"..., . t/.d_
(717) 240.6200 .,.dr~'~~'
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Page 3
8, The best interests and permanent welfare of the child requires that primary physical and legal custody
of the child be granted to the Plaintiff/Father, JetI' B, Conley,
Wherefore, Plaintiff, Jeff B. Conley, respectfully requests that he be awarded primary physical and legal
custody of the subject minor child as provided herein,
Respectfully submitted,
DeArmond & DeArmond
DATE:
(n(;b~
I'
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Keith B, D mond, Esquire
Attorney ID Number 58878
2800 Market Street
Camp Hill, PA 17011
(717) 730-9394
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JEFF BRIAN CONLEY,
Plaintiff,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 96-3385
v.
CHRISTINA HEIKEL,
Defendant
IN CUSTODY
QQMPLAINT FOR CUSTODY
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1. Plaintiff is JeITBrian Conley, an adult individual whose residence is at 414 3rd Street, New
Cumberland, Cumberland CoWlty, Pennsylvania.
2. Defendant is Christina Lynn Heikel Conley, an adult individual whose residence is at 104
South Frederick Street, Mechanicsburg, Cumberland COWlty, Pennsylvania.
Street, New Cumberland, Cumberland COWlty, Pennsylvania, whose date of birth is August 3, 1993.
3. Defendant seeks custody of her child, JeITBrian Conley, Jr., currently residing at 414 3rd
4. The child is presently in the custody of the Plaintiff.
5. Since the child's birth, the child has resided with the following over the past five years:
Name Address Date
JeITBrian Conley 322 3rd Street August, 1993 to
Christina Lynn Heikel Conley New Cumberland, P A November, 1993
JeITBrian Conley 1825 Potts Hill Road November, 1993 to
Christina Lynn Heike! Conley Etters, P A February, 1994
.JeIT Brian Conley 310A Ross Avenue February, 1994 to
Christina Lynn Heikel Conley New Cumberland, PA December, 1994
JeIT Brian Conley 310B Ross Avenue December, 1994 to
Christina Lynn Heikel Conley New Cumberland, PA May, 1995
JeIT Brian Conley Fishing Creek Valley Road May, 1995 to
Christina Lynn Heikel Conley Grantville, P A September, 1995
J eIT Brian Conley 316 East Lime Kiln Road September, 1995 to
Christina Lynn Heikel Conley New Cumberland, P A March, 1996
J eIT Brian Conley 414 3rd Street March, 199~ to
Christina Heikel Conley WltU 9/26/96 New Cumberland, PA Present
~ -.. ~
'-
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION
BUREAU OF DRIVER LICENSING
HARRISBURG, PA 17123
10/24/96
UPPER ALLEN TWP PO
CPL SPOTTS
100 GETTYSBURG PIKE
MECHANICSBURG PA 17055
962986645213236 001
- .~. ~ '"': Fr,') I. <ll' . r. .
JEFF CONLEY. SR..
Plaintiff
V.
CHRISTINA L. CONLEY.
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY. PENNSYLVANIA
NO. 96-5481 CIVIL TERM
CIVIL ACTION LAW
CUSTODY NO 94-SU-04920-03
. )
I
,
I
"
,
"
MOTION TO WITHDRAW AS COUNSEL
IJI
.,
And noW. to wit. this 27," day of January. 1997. comes Barbara Sumple-Sullivan, Esquire.
and files the within Motion to withdraw for the following reasons:
I. On or about October 3. 1996. Jeff Conley. Plaintiff contracted with the law firm
of Barbara Sumple-Sullivan. Esquire in connection with the above-referenced
custody action. A copy of said agreement is attached hereto as Exhibit A.
2. Pursuant to that representation. the litigation involving this case is continuing, and
further custody consultation is scheduled before Michael Bangs on February 20.
1997.
3. Despite numerouS requests, Jeffrey Conley has refused to make payment t,
counsel as agreed or otherwise contact counsel regarding this matter.
4. Plaintiff has not fulfilled his obligations to movant and it would be a hardship fc
-movant to incur additional time and expense inciaent to this representation.
2
JEFF BRIAN CONLEY, SR.,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
NO. 96-5481 CIVIL TERM
CHRISTINA L. CONLEY,
Defendant
CUSTODY
ORDER
AND NOW, this
4-:tJ- day of
, 1996, upon receipt
"1.6lo- .
of the Conciliator's Report, it appearing that the parties have reached a temporary
agreement, the terrns and provisions of that temporary agreernent which was
dictated in their presence and approved by them and their counsel, it is hereby
ordered and directed that:
1. The parties shall share legal custody of their minor child, Jeff
Brian Conley, Jr., d.o.b. August 3, 1993.
2. Physical custody of the minor child will be in accordance
with the following schedule:
A. The child will be with Mother from Thursday,
October 31, 1996, until Monday, November 4, 1996. Mother
shall pick the child up frorn day care and return the child to day
care. This schedule will continue on an alternating weekend
basis.
B. Mother shall have the child on alternating Tuesdays
beginning Tuesday, Novernber 12, 1996, from when she picks
4. Issues yet to be resolved: An ultimate custody schedule.
5. The Plaintiff's position on custody is as follows: See attached Order.
6. The Defendant's position on custody is as follows: See attached Order.
7. Need for separate counsel to represent children: Neither party requested.
8. Need for independent psychological evaluation or counseling: None
requested and the Conciliator does not believe any is necessary.
Date: November 1, 1996
I:JJ ,lltQ.llfCU'. l,
Michael L. Bangs
Custody Conciliator
,
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All Filings before
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Have not been scanned!
C",,-,btrIMd
IN THE COURT OF COMMON PLEAS OF ~ COUNTY, PENNSYLVANIA
Q..hr ts\\oo... L Cov\\ey
too l Re..o ~K. ~d NO. 1<1'1(0 - '5yg I
VS.
YeW ~rfa{\ ~~S('.
CIVIL ACTION - LAW
PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS
AND NOW, come the Petitioner, c.hrlS~i()a. L {If'JflJ II' , and
alleges as follows: ""'"'1
1. Pet.iti.oner, (lbr~<::'+)rfil. L lhY1tw , is an adult individual
resldmgatT~4:::l1 ~W,.. ~
York County, Pennsylvania.
2. Petitioner is indigent and financially unable to pay the costs and fees
necessary for filing and serving this action.
3. Petitioner's financial circumstances are more fully set forth in the attached In
Fonna Pauperis Questionnaire.
4. Petitioner has a meritorious cause of action and will be denied access to the
court and due process of lawlfnol alluw~u loproceed In l'onna-t'aupens:.
1-
WHEREFORE, Petitioner prays that the Honorable Court enter an Order allowing
this action to proceed In Forma Pauperis, without prepayment of costs or fees.
~
I understand that the statements in the foregoing Petition for Leave to Proceed In Forma
Pauperis are made under the penalties provided by 18 Pa. C.S.A. 4904 (relating to
unsworn falsification to authorities).
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ADDRESS BaJ} f&D &iJj( RJ l/J-J
tJve.r, P:l 17:11S-
TELEPHONE # fIJ?) -~"d -t../Qt.Ja
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CIVIL ACTION LAW
FINANCIAL AFFIDAVIT
1. I am the (Plaintiff) (Defendant) in the above matter and because of my financial
condition am unable to pay the fees and costs of prosecuting or defending the action or
proceeding.
2. I am unable to obtain funds from anyone, including my family and associates, to pay the
costs of litigation.
3. I represent that the information below relating to my ability to pay the fees and costs is
true and correct:
Address:
l
Social Security No.: /{na -5'8.aloS
Prisoner ID# (if applicable): \::)') Y
. Employment
If you are presently employed, state:
Employer: none..
Address: ()()ne
Wages or salary per month: ()(Jf\.L
Type of work: (\Gf\e'_
Ifvou are oresently unemoloyed state:
Date oflast employment: _l q q '1
Wages or salary per month: va(ie.~,.a
Type of work: Se\revY1~
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~ , Year: oct i('lrn~ (\QV~J...-+np:A
Amo nt owed: &50().00
Stocks; bonds: ~
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Debts and obligations
Mortg e: [l()rlL
Rent: 00
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Loans:
f I CiJ/1'5
70.00
Other:
. Persons dependant upon YOU for support
(Wife) (Husband) Name: ()()'A.J.-
Children, ifany:
Name: <f'fff 6 cq~ J r
JO~uo..~l--lusW
Age: (~
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Other persons:
Name: (bl\Jl
Relationship: (\~
. Expenses
Item To Whom Paid
Rent/Mortgage C',..sP .ffbfv1qtmutt
:~:C::iC ~ p~
Gas nOr'l.J-.
Heating Oil .---J----nlG../\ 0: 1
Water (let\. 0
Sewer (\00-
Trash (1o~
Property Insurance fa r-€fY10~-t
Telephone creo
Car Loan lD.rC.C1... ~r ~
Car Insurance &)(::OyY)fXA9i~
Gasoline/Oil/Repairs ~l ~S
MedicalIDental ~_LA.".J..
Life/Health Insurance w.be'("
Food (Food Stamps of$ J l.o5.'ffIus additional
Household Supplies/Laundry G'I f\/).+
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TOT AL MONTHLY EXPENSES
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Information Concerning Spouse in Divorce Cases
(Answer Only In Divorce Cases)
Name of spouse
Address of spouse
When did you last live wit
Is spouse employed?
Where and at what rate of pay?
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What other income does spouse have? 4
What assets does spouse have? n lA-
I understand that I have a continuing lbligation to inform the Court of improvement
in my financial circumstances which would permit me to pay the costs incurred
herein.
. I verifY that the statements in this affidavit 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. which upon conviction provides for a fine not
to exceed $2500.00 or for imprisonment for a term not to exceed one year.
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Petitioner
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In The Court Of Common Pleas Of Yj/rk County, Pennsylvania
Petitioner
Christina Lynn Conley
2001 Red Bank Road # 421
Dover Pa. 17315
No. Agio -54<6/
v.
Civil Action Law
Respondent
Jeff Brian Conley Sr.
219 Brookside Drive
Middletown Pa. 17057
mcdj\ie.a:FiC}VI orCustodlj
1. A prior order was entered in June of 1996 Approximately
2. Copy of said Order is attached
3. A modification is requested because on August 30, 2006 at 9:00 am said
respondent choose not to appear to court for a Domestic Relations contempt
. hearing.
4. A bench warrant has been issued for his arrest by the York County courts.
5. Therefore Petitioner Request sole legal and physical custody of Jeff Brian
Conley Jr. be awarded to the mother. With no visitation in place, left to
mother's discretion, said child is 13-years of age.
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DIRECTIVE
Conciliator Previously Assil!Ded To This Case: .1Cf11o -13481
You, ']""e.+-r 'Br\ OJ\ ~~~Defendant, have been sued in Court to obtain custody,
partial custody, or visitation of the child(ren):
It is hereby Ordered and Directed:
Conference.
, ~=; is hereby assigned to. conduct a Conciliation
1.
2. A Conciliation Conference will be held before the assigned Conciliator on the _ day of
, 2006, at .M., in Hearing Room 7, 4t1l Floor, York
County Judicial Center, 45 North George Street, York, Pennsylvania 17401. The anticipated
length of the Conciliation Conference is one hour.
3. The parties shall app!lar in person at the Conciliation Conference and shall bring with them
all CHILDREN AGE SEVEN (7) AND OLDER.
4. At the Conciliation Conference, an effort will be made to see if the custody and/or visitation
situation can be resolved by an agreement between the parties; or if an agreement cannot be
reached, to define and narrow the issues and to otherwise reduce the time required for
hearing by the Court, then the Conciliator will prepare a Conference Summary Report for
further action by the Court pending a hearing to be scheduled at a later date before Judge
Richard K. Renn, without prejudice to the rights of the parties at such hearing, which all
parties and the child(ren) shall be ordered to attend.
5. You have the right to be represented by an attorney who may attend the Conciliation
Conference with you. If for some reason an attomey has not been secured by the time of the
Conciliation Conference, you shall personally appear at the time scheduled for the
Conciliation Conference without an attorney.
6. If Children's Services is conducting an investigation, their representative shall be subpoenaed
by the appropriate attorney to attend the Conciliation Conference. It shall be the
responsibility of the attorney subpoenaing the representative to obtain a Court Order or
releases from the parties prior to the release of information by the representative.
7. If you fail to appear as provided by this Order or to bring the child(ren), an Order for
custody, partial custody, or visitation may be entered against you, or the Court may issue a
warrant for your arrest.
8. The parties and their counsel, if applicable, are hereby directed to engage in meaningful
negotiations to resolve this matter prior to the Conciliation Conference.
'",I ......
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.
Lawyer Referral Service of the
York County Bar Association
137 East Market Street
YorkPA 17401
Telephone: (717) 854-8755
BY THE COURT:
FOR THE COURT
Judge
District Court Administrator
, ,
}......
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of York County, Pennsylvania is required by law to
comply with the Americans with Disabilities Act of 1990. For infonnation about
accessible facilities and reasonable accommodations available to disabled individuals
having business before the Court, please contact the county at (717) 771-9099.
For those with a hearing impainnent, please contact the DEAF CENTER
at (717) 848-6765 TDD. 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.
FOR THE COURT:
Date:
District Court Administrator
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CHRISTINA LYNN CONLEY
PLA INTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
96-5481
CIVIL ACTION LAW
JEFF BRIAN CONLEY, SR.
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Wednesday, September 06, 2006
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq.
at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, October 05,2006
, the conciliator,
at 10:00 AM
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.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearin2.
FOR THE COURT.
By: /s/
Dawn S. Sunday. Esq.
Custody Conciliator
.~
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites 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 ATTORNEY AT ONCE. IF YOU DO NOT
HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania J 7013
Telephone (717) 249-3166
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NOV 15 2006rl
CHRISTINA LYNN CONLEY
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
96-5481
CNIL ACTION LAW
JEFF BRIAN CONLEY, SR.
Defendant
IN CUSTODY
ORDER
AND NOW, this 14th day of November.2006 , the conciliator, hereby relinquishes
jurisdiction based on the fact that neither party appeared for the conciliation conference or contacted
the conciliator. The custody conciliation conference initially scheduled for October 5,2006 and
rescheduled to November 14, 2006 is cancelled.
FOR THE COURT,
Dawn S. Sunday, Esquire
Custody Conciliator
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