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'r)I' II/I , V. ,ill "'I "", J I' / "./1 :_,'-; fl,' ,'-"1"'1 ;Iii!, , 'I, "/f '(I,I}I; 'f'I" , I I , , , ' " I ,-']I ',' ,11 1 , 1,1.:"11 ,'I:i , It, ,[' I 'I. II" I, I.'!-) , " " , , 1',1' {,f,,\' 'Ii,! " '1 , ' "I. 11\' !,I ,(il,;"I_I".;! , " i j ~ _) )1 ; f - ~!- I.:>; I II '\ Hj; , 1,'1 ),1 '1,1' 'f,' 'i\_f' ii,l /,' I'" !' I' 'II .I"il " '1"1 , , , , :;. \ 111.1, ' I,! ,!, f' ~ I 'i" : ,-', 1'" .11 '_I"j ,I ;1 , " I ,,' Ii,!', ,; "II, 11'lii! U I' , 1;,1 ( , '! " 1"1 I 'J'I' ',I-ill ,:' ,I " , 'I, ,(,,oj j i,'! '-I'~ ,}I ' , ,'-I ',I' 1]1' I ,'/,). !, I 'I' '_;/_'\1: !_, I;" I" 'ii' ''1_! 1:1\ I-.-i." ,;'; ," ';11",' " " I, ;, ,I "i " ','j ., 11, ,I, i I'll 'i,;.!,I,! , " I " . " iI"I,I.\' I , "ii' "'('! ,,--! " ,'" I' 'I, '\:1' I ,"" I I ,I ! ;1' 'i ,ill) \":,' ~ I - i'-' .If I' '" , t(1 , " 'I "_I ;1 ,. ',:'/ " I"j ';' ii" 'jl': , i!-'J., \1 Ii "'I ,\' I" "Ill " -1;'1/( , i' Ji" ',"" Ii,!, " !:' 11, "';-~ ,11, I' H',-,-, " ,\ , "'\1"" '\ " , " " i -,'I I-"-'i "I'I",-r,j" ," I 'I" 'II " ,I", " ~,I\ . - I " ,[ "11 , , ". ,,' " 'I" ,t.' " .. ", "', ,\',,' .' " " d w IQ , I , , , "~I ;( " ',.j ',fA , -I\" '\ , -'~'., "f-. "Ii ',I) I:, ,'llil, ,I 'I 'I: I' I""J'"'' ':/,'1 ,~, f:' , , 'tl I '__IF j!\{) il.}-> 'l .($ ,I , , , " " , " " , , 'I ,,' " " , '. " " , " , , , " " . , , ., " , " rj'l r': ,- ,J; , , 1 'I' I" " . 1 I ";111 .I 'I 'I, " , \ , , I' , , ,; " I '-,', ' " 1.1 !, " ',; i l ,'~ ,i r, j, . ., Iii I i'I .. 1"1 " I I 11-, , " , ! " ,I . , 1 I , i , " , , , , , I , I. , I' , , I. . , , I) , , '" l, II, I" ',1, I' 1,,, " " "l " " 1,-'1 , , " (~ I 1.1.l' " I; I C/, h3 ..J1 LJ. I I', r,) , , I , , , , , , , I , , , , I :1 I,' I, "",~ fe' '. .... , , .. ~ I: " , , I , ,. j , , ;',1 " \;J. " ; , .I " U , I II I, " , , , l.t.) L\ .. __J I'~. 0:'.: t-... ,'.' .' ", ':, , " II , , , , " " ,-I 'i I" " ~"9 .... ......... - ," - ~ I, '1 I' I " . I , ~ " r I.' 'I' " , , ! " " " 'I I, ill " " ' " " " , , , , '\ I I', 3. On October 21, 1996, the Family Law Clinic filed a complaint In Custody on behalf of Myles Worthington, docketed to the above term and number. 4. In early January, 1997, Myles Worthington informed the Family Law Clinic that he had changed jobs, and subsequently that his income had increased. S. On January 27, 1997, the Family Law Clinic represented Myles WorthlnglUn in a custody conciliation. 6. At the conciliation, the parties were able to resolve all custody Issues except the terms of Mr. Worthington's summer period(s) of partial custody; a second custody conciliation conference Is 5(:hcduled for April 4, 1997, before Custody Conciliator Hubert Gilroy, to address that matter. 7. Despite repeated requests by the Family Law Clinic, both before and after the January custody conciliation, Myles Worthington has consistently refused to provide the Family Law Clinic with updated Income information for himself and his wife. 8. Myles Worthington has repeatedly been advised by letter and verbally that failure to dl5(:lose his updated Income information would result In the Family Law Clinic seeking the Court's permission to withdraw from his case. The Family Law Clinic's most recent letler to Myles Worthington gave February 24, 1997, as his last opportunity to provide the clinic with his updated Income information. He has not responded to that letler, 9. Mr. Worthington has been on formal notice since early January 1997, that the Family Law Clinic would not further represent him if he did not produce information demonstrating his continued financial eligibility for its free legal services. i,;i MYLES WORTHINGTON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. . . : CIVIL ACTION . LAW : IN CUSTODY STACY SEIBERT, Defendant : NO. 96- 5791 CIVIL TERM CERTIFICATE OF SERVICE I, Angela Montgomery, Certified Legallntem, Family Law Clinic, hereby certify that I am serving a true and correct copy of said Order February 27, 1997 on Myles Worthington, residing at 1584 Pine Road, Carlisle, PA 17013, by depositing a copy of the same in the United States mail, postage prepaid, this 11th day of March, 1997. ~~~ (1\ --- Ange Mo~tgOme '.......- Certified Legal Intern , " " , ," " 'J , ,. , ',' " ,tr MlfLES WOR'l'HING'1'ON, Plaintiff V S'l'ACY SEI8ER'l', Defendant :IN THE COUR'l' OF COHHON PLEAS OF :CUMBERLAND COUN'l'Y, PENNSlfLVANIA : :CIVIL AC'l'ION - LAW : :NO: 96 - 5791 : IN CUS'l'ODY PRIOR JUDGE: Edgar B. Bayley COURT ORDER AND NOW, this '2.~ day of \lAU.U_ , 1997, upon consideration of the attached custo~ ConCi1~ation Report, it is ordered and directed as follows, 1. This Court's Order of December 27, 1996 shall remain in effect subject to the following modifications, A. Paragraph 3(e) of the prior Order is modified whereby Father's period of temporary physical custody with the minor children on Wednesday shall be from 2,00 p.m. until 7,00 p.m. B. 'l'he non-custodial parent's time with the minor children on one of the children's birthdays shall be from noon until 4:00 p.m. This shall include both children. C. In the event Father intends to take the minor children out of the Commonwealth of Pennsylvania, he shall give Mother 48 hours notice of his intention to do so and shall also give the Mother a phone number and address as to where the Father will be located with the children. In the event the trip outside of the Conunonweal th is merely a day trip and not an overnight trip, Father will give Mother 24 hours notice and at that time indicate to the Mother where he shall be taking the children. D. Father shall be allo:.red a period of two weeks of vacation with the minor children during the summer months. The issue of whether these weeks shall be consecutive shall be continued to be negotiated between the parties or addressed at the custody conciliation conference as scheduled below. 2. The parties shall meet for another custody conciliation conference on Friday, April 4, 1997 at 8:30 a.m. ~ , , ('.', , '., j !I b" -, 1'0., .'.1.. .. >.. I, ~ UI~. .' _J J ".It " , , , q,., .". , , , r.." .l~j 'r t~) j,~j , , 1 , [1, C',,; I ;.;J 'i tl r~: I J " I ':L." " ~; t' I' r.. , LJ ~~ . 0 " w~ I.' ',(.It"'" MyleK Worthington. Plaintiff : IN THE COURT or COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW : IN CUSTODY : .J~' : NO, 96. ) CIVIL TERM Stacy Seibert, Defendant ORDER 011 CQ!!RT AND NOW, this?1,. lbay of Odl.*'o ,1996, Hpon consideration of the auached complaint, it is hereby directed Ihatthe partics and their respective counsel appear before, \-\ L\ lJ'-' i i,&< I'~ft~;~onciliator, at l t t h (I",,;, , Cumberland County Courthouse, on the 1-~I"day of O('(I~b-(, 1996, at jO,~"III11" for a Pl'e-Hearing Custody Conference, At such conference, an effort will be made to resolve the issues in diiipute; or if this cannot t.e 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(ren) who is the subject of this 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 tcmporary or permanent order, FOR THE COURT: By: _ --2/",L.f)<jb.~L~' (~ ~j-rfconciliator -~.9p11 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, OFrICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4th Floor CARLISLE, PA 17013 717/240-6200 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is requircd by law to comply with the Americans with Di:;abilities 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 alleast 72 hours prior to any hearing or business before the court. You must attend thc scheduled conference or hearing, MYLES WORTHINGTON, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :IN CUSTODY v, STACY SEIBERT, Defendant , , : ,,')'11 :NO, 96- 'J CIVIL TERM COMPLAINT FOR CUSTODY NOW COMES, the plaintiff, Myles Worthington, by his allorncys, the Family Law Clinic, and sets forth the following cause of uction: 1. The plaintiff, Myles Worthington, is the father of the subject minor children. He resides at 1584 Pine Road, Carlisle, Cumberland County. Pennsylvania 17013, 2, The defendant, Stacy Seibert, is the mother of the subject minor children, She resides at 1344 Grandview Court, Carlisle, Cumberland County, Pennsylvania 17013, 3, Father seeks purtial custody of the following children: ~ Brittany Worthington D.O.B. 01-23-95 All: I year, 8 months Katelynn Worthington D.O.B. 02-19-96 Au 7 months Present Residence 1344 Grandvlew Court Carlisle, PA 17013 1344 Grandvlew Court Carlisle, PA 17013 The children were born out of wedlock, During the past five years. the children have resided with the following persons and at the following addresses: Person Addresses Relationship DmlI Stacy Seibert Ashley Little Nicholas Little 1344 Grandvlew Court Carlisle, PA 17013 mother half sister half brother birth. present Mother is not married, She resides with the persons as noted above, . " " ~ ,... ". C\l ". " I~~ .. i-S , , - ..1', - ,l;j", " ij,:: :i;:~ ( 0,0 r~} I. I !' \~ ~; ': (I} . l .,IL'- '~'" t; '1 II. ,. '" Ll, 0' I) . , I , , , "" " ,,' ': I " ", 'II ," 1.1 , , , , ," , I " " ': , ' ,,, " I" , , , ,r! I" , " 'I ", " ", , , 11'1'1 '1.1 ", , ' ,Ii "' ,I. , I, " , II,. ,i I " " " ," " , , v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-5791 CIVIL TERM MYLES WORTHINGTON, plaintiff STACY SEIBERT, Defendant CUSTODY AND NOW, this ~f1 day of , 1996, upon G!1 consideration of the parties' Consent Agreement of December 26, ..,..-~ 1996, the following Order is entered with regard to custody of their children, Brittany Renee Worthington and Katelynn Marie Worthington: 1. The defendant, stacy seibert, hereinafter referred to as the mother, and the plaintiff, Myles Worthington, hereinafter referred to as the father, shall share legal custody of the children. 2. The mother shall have primary physical custody of the children. 3. The father shall begin his periods of custody through a gradual schedule aB follows: a) On Wednesday, December 11 and Saturday, December 14, 1996, the father shall visit with both children from 10:00 a.m. until noon in the presence of the mother at a neutral location mutually agreed upon by the parties. b) On Wednesday, December 18 and Saturday, December 21, 1996, the father shall have unsupervised visits with both children from 10:00 a.m. until noon. c) On Christmas Day, December 25, 1996, the father ,shall have partial custody of both children from 111 00 a.m. until 3:00 p.m. and on December 26, 1996, from 2:00 p.m. until 5100 p.m. d) On Saturday, December 28, 1996, and Saturday, January 11, 1997, the father shall have partial custody of both children overnight from 5:00 p.m. until 5100 p.m. e) As of January 8, 1997, the father shall have both children each Wednesday from 9:00 a.m. until 3:00 p.m. unless the father's work schedule necessitates a change to an alternate day and times mutually agreed upon by the parties. f) As of January 24, 1997, the father shall have both children on alternating weekends from Friday at 5:00 p.m. until sunday at 5:00 p.m. The father may have periods of partial custody at other times mutually agreed upon by the parties. g) The parties shall provide each other with ample notice if their work schedule changes if it is likely to affect the custody schedule. The parties shall offer each other the first option to care for the children if they are scheduled to work during their periods of custody, and they shall provide each other with comparable time with the children on days at times mutually agreed upon. h) The father shall provide transportation during periods of partial custody and shall remain in his vehicle at the curb on North West street in front of the Grandview Court housing development in an area visible to the mother from her home or at any mutually agreed upon location. The mother shall bring the children to the defendant. If the father does not have access to car seats, the mother shall lend them to him during his periods of custody and the father shall return them to her at the end of each period. i) The parties shall alternate the following holidays with the father having the children from 9:00 a.m. until 2:00 p,m. and the mother shall have the children from 2:00 p.m.: New Year's Day, Easter, Memorial Day, July 4th, and Labor Day. The father shall begin the schedule having the children on New Year's Day, January 1, 1997. The holiday schedule will always supersede the Wednesday and alternating weekend Bchedule. j) The parties shall share the Thanksgiving Day holiday with the father having the children from 9:00 a.m. until 2:00 p.m. k) The Christmas holiday shall be shared by the parties on an alternating basis each year, one parent having the children on Christmas Eve from noon until Christmas Day at noon and the other parent having the children on Christmas Day from noon until December 26th at noon. The father shall have the children on ChristmaB Eve in 1997. 1) The father shall have the children from 11:00 a.m. .. ......... "- untU 6100 p.m. on Father's Day and the mother shall have the children trom 11100 a.m. on Mother's Day. m) The parties shall have both children on their respective birthdays tor a tour-hour period at times to be mutually agr$ed upon by the parties. n) The tather shall not remove the children from the state of Pennsylvania without 48-hour notice to the mother. 0) The partieB shall not use illegal drugs, or use alcohol in excess immediately prior to or during their periods ot custody with the children. 4. The mother and father, by mutual agreement, may vary from this Bchedule at any time, but the Order will remain in ettect pending further Order of Court. 5. The mother and father shall notify the other of all medical care the children receive while in that parent's care. Each parent shall notify the other immediately of medical emergencies which arise while the children are in that parent's care. 6. The parties realize that their children's well being is paramount to any differences they might have between themselves. Therefore, they will not do anything which may estrange the children trom the other parent, or injure the opinion ot the children as to the other parent or which may hamper the free and . ,..,........- - a) On Wednesday, December II and Saturday, December 14, 1996, the father will visit with both children tram 10:00 a,m, umil noon in the presence of the mother at a neutral location mutually agreed upon by the parties, b) On Wednesday, December 18 and Saturday, December 21, 1996, the father will have unsupervised visits with both children from 10:00 a,m, until noon, c) On Christmas Day, Decemher 25. 1996, the father will have partial custody of both children Irom II :00 a,m, until 3:0() p,m, and on December 26, 1996, tram 2:00 p,m, until 5:00 p,m, d) On Saturday, December 28, 1996, and Saturday, January II, 1997, the father will have partial custody of both children overnight from 5:00 p,m, until 5:00 p,m, e) As of January 8. 1997, the father will have both children each Wednesday from 9:00 a,m. until 3:00 p.m, unless the lillher's work schedule necessitates a change to an alternate day and times mutually agreed upon by the parties, I) As of January 24, 1997, the father will have both children on alternating weekends from Friday at 5:00 p,m, until Sunday at 5:00 p,m, The father may have periods of partial custody at other times mutually agreed upon by the parties, g) The parties agree to provide each other with ample notice if their work schedule changes if it is likely to allect the custody schedule, The parties agree to offer each other the first option to care for the children if they are sched41ed to work during their periods of custody, and they agree to provide each other with comparable time with the children on days at times mutually agr"ed upon, " .- ., ' ., h) The father will provide transportation during periods of partial custody and will remain in his vehicle at the curb on North West Street in front of the Grandview Court housing development in an area visible 10 the mother from her home or at any mutually agreed upon location, The mother will bring the children to the delendant If the lather does not have access to car seats, the mother will lend them to him during his periods of custody and the !Juher will return them to her at the end of each period. i) The parties will alternate the lollowing holidays with the father having the children rrom 9:00 a,m, until 2:00 p,m" and the mother will have the children from 2:00 p,m,: New Year's Day, Easter, Memorial Day, July 4th, and Labor Day, The father will begin the schedule having the children on New Year's Day, January I, '1997, The holiday schedule will always supercede the Wednesday and alternating weekend schedule, j) The parties will shareJhe Tha.nksgiving Day holiday with theJather having the children from 9:00 a,m, until 2:00 p,m, k) The Christmas holiday will be shared by the parties on an alternating basis each year, one parent having the children on Christmas Eve from noon until Christmas Day at noon and the other panmt having the children on Christmas Day from noon until December 26th at noon, The I1lther will have the children on Christmas Eve in 1997, " " " ", j! , , ,., j ." ii , ~ ,... >- " (;:, ,., ;'# "" M (,I.... " ~~; ~ ;);~ . :,_1 . ~I: 4..1 f~~) 1:'0 t.. '.' -, l, r- :'''{'J ~I~; "J ,)(; " , w i1/1'iJ , L<J (., u: [:,: c;;, a 15 \b 1;1. I , , 1'1 , , , , , 1',1 , i' It ," " ii I -.I' ,Ii .,' , I 'Ii " ii , ;1 " ,I' , , , " I, "II , , ;r , , " " 'J , , " I I " '\ " , " " I.,' " , " I' , " " ,>, .I\U ". " " ~. C"l /... -, ..... " ,", I.." -, 11' ~~;! - "J"' 0- j~~! HOc HI.... 0" ~j~ ". ~ r\" 1'~,J 2) - .,~ 1:':._ , (f) ..l,: 1':'; L'I- [f:l: . (): 'V'1 CJ_ ;:..(;1",: r.'"' "'" 1.1. i'""' ~~ U' O"l -JI ," " ., I t,i " " , " "l " " " I', " ." MYLES WORTHINGTON, Plaintiff V STACY SEIBERT, Defendant Prior Judgel Edgar B. Bayley CONCILIATION CONJ"JlRlllNCIl SUMMARY' RlCPORT I IN THE COURT OF COMMON PLEAS OF ICUMBERLAND COUNTY, PENNSYLVANIA I ICIVIL ACTION - LAW I INOI 96 - 5791 IIN CUSTODY IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following reportl 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows I Brittany Worthington, born January 23, 1995 and ICatelynn Worthington, born February 19, 1996. 2. A Conciliation Conference was held on April 4, 1997, with the following individuals in attend~ncBI The Mother Stacy Seibert, with her counsel Jan Terpening of Legal Services. The Father did not appear, Notice of the Conference was given in the prior Court Order issued in this oase on January 28, 1997. The Father was represented by the Dickinson School of Law Family Law Clinic, but the Law Clinic has since withdrawn their representation of the Father. 3. Mother indicated to the Conciliator that the Father is not following through on all of his scheduled visitations. Specifically, Mother stated that Father related to her that he does not desire to exercise the Wedneaday temporary custody time as provided in paragraph 1(A) of the January 28, 1997 Order. Also, Mother indicates that she wants any summer vacation of two weeks to be non-consecutive. Mother also has some concern about Father notifying hez' in a reasonable amount of time before exercising a summer vacation. 4. The Conciliator recommends an order in the form as attached. ~111/?7 D TE