HomeMy WebLinkAbout96-06045
~~:~'~~:~~!_;. ~,";';
~?t'<!; ,. :;:
~::,'i(.f~' ;.,
J"~ -, <"
J: ~ ,~ . '
(,.: "';''','
... iii ,"j:
~tlu~~t:;~~;:u~:, ,'; ,
',)1" 'w"," ;,",":' ,
~}i }:'~};: ',{, ::'; ..,
i;~'i;:::~,;;,:,' ."':.'
~>,:-,~,,::>- '-'J':-
:'r,','
'.' ",'
'~
I
..11
,1,
,'~. .
'!' a
I
" ~: '
It
;.;;.'
;';
.
.. :'.,
..
"
<
. .
.. .
, "
>.
1,
DEe 1 7 1990ef
..
""
Wi" '.if
, -.
'.
MARY ELIZABETH AMICO,
Plaintiff
: IN THE COURT OF WIMClN PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs.
: NO. 96-6045
CIVIL TERM
.
.
KRISTY HASLOCK and ALBERT AMICO,
Defendants
: CIVIL ACTION - LAW
: IN CUSTODY
aIDER 0Ii' COORT
AND tOi, this IS'
consideration of the attached
and directed as follows:
day of )it u-tc... I 1996, upon
Custody Conciliation Report, it is ordered
1. The Mother, Kristy Haslock, shall continue to have primary
physical custody of Alex Haslock, born December 18, 1994.
2. The paternal Grandmother, Mary Elizabeth Amico, shall have
visitation or partial custody of the Child on the fOllowing schedule:
A. The paternal Grandmother shall have periodS of visitation
with the Child on Monday and Thursday evenings from 6:00 p.m.
until 8:00 p.m. beginning on Thursday, December 12, 1996 and
endi'lg on Monday, December 23, 1996. These periodS of
visitation shall take place at either the Mother's residence
or the caregivers' residence as designated by the Mother.
B. The paternal Grandmother shall have partial custody of the
Child every Monday and Thursday evening from 6:00 p.m. until
9:00 p.m. beginning on Monday, January 6, 1997 and ending on
Monday, February 10, 1997, with the exception that the
Grandmother shall have custody of the Child on Wednesday,
January 22, 1997 rather than Monday, January 20, 1997.
C. The paternal Grandmother shall have partial custody of the
Child from Saturday, January 18, 1997 at 10:30 a.m. until
Sunday, January 19, 1997 at 10:30 a.m.
D. The paternal Grandmother shall have partial custody of the
Child from Friday, February 14, 1997 at 5:00 p.m. until
Monday, February 17, 1997 no later than 10:00 a.m.
E. Thereafter, the paternal Grandmother shall have partial
custody of the Child every Tuesday from 4:00 p.m. until 9:00
p.m. and one weekend per IOOnth from Friday at 5:00 p.m. until
the following Monday morning no later than 10:00 a.m. The
IOOnthly weekend periods of custody shall be scheduled by the
Mother and the paternal Grandmother to coincide with weekends
during which the Mother's daughter is in the custody of her
father.
3. 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.
BY THE axJRT,
--~I-' ~J 11-
/
cc: Austin F. Grogan, Esquire - Counsel for Plaintiff/Grandmother
Jan TerpeMirg, on behalf of Defendant/Mother
Albert Amico, Pro Sa
~,,~ 1a.)''1/cj~ '
....!\,f.
J.
, .
FllE(}.OFFlCE
OF ')1,/': r'WI'("nrA1V
SGnr:r./9 MIIlI "
CU~:21::'i.J.\u ,.,C;U;~fY
PENNS YLV:\J\,IA
MARY ELIZABETH AMICO,
plaintiff
IN THE COURT OF CCXolMON PLEAS OF
CUMBERLAND COONTY, PENNSYLVANIA
vs.
NO. 96-6045
CIVIL TERM
KRISTY HASLOCK and ALBERT AMICO,
Defennants
CIVIL ACTION - LAW
IN CUSTODY
aJS'roDY CXH:ILIATlOO 5tJlIIlARY REP(Rl'
IN ACXXlUlANCE HITII ClImERLAND 01Nl'Y RULE Ol" CIVIL PIO,....I{B
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
NAME
BIRl'IIDATE
aJRRBNl'LY IN CUS'1OOY Ol"
Alex Ilaslock
December 18, 1994
Defendant/Mother
2. A Conciliation Conference was held on December 10, 1996, with the
following individuals in attendance: the paternal grandmother, Mary
Elizabeth Amico, with her counsel, Austin L. Grogan, Esquire, the Mother,
Kristy Ilaslock, with her counsel, Jan Terpenning, Paralegal, and the
Father, Albert Amico, who was not represented by counsel at the Conference.
{)~lbnbu- Id., Jqq~
[),;jte '
3. The parties agreed to entry of an Order in the form as attached.
/-,
I~~ LJu~~
Dawn S. Sunday, Esqu re
Custody Conciliator
6. During the child's lifetime, he has resided with the following persons and at
the following addresses:
~
Kristy Haslock & Companion
(Unknown Male believe 10
named Dave
Sister - Brlllney Haslock
Address
82 York Road
Carlisle, PA 17013
~
Spring 1996
Present
Kristy Haslock
Brillney Haslock
York Road
Carlisle, PA 17013
December, 1994
Spring, 1996
7. The mother of the child is Kristy Haslock, currently residing at 82 York Road,
Carlisle, Pennsylvania. She is single.
8. The father of the child is Albert Amico, currently residing at 906 1/2 Sheffield
Avenue, Mechanicsburg, Pennsylvania, He Is single,
9. The relationship of Plaintiff to the child is the paternal grandmother,
10, The Plaintiff currently Is residing 906 Sheffield Avenue, Mechanlcsburg,
Pennsylvania,
11, The relationship of Defendant Krlsty Haslock to the child is that of mother,
The Defendant currently resides with the following persons:
~
Dave
Relationshio
Companion
12, The relationship of Defendant Albert Amico to the child is the father. The
Defendant currently resides with no one,
13, Plaintiff has not participated as a party or witness, or In another capacity, In
,
other litigation concerning the custody of the child in this or another court.
14. Plaintiff has no Information of a custody proceeding concerning the child
pending In a court of this Commonwealth.
15. The Plaintiff seek partial custody/visitation with the minor child for the
following reasons:
a. The best interest of the child to have a loving relationship with
his family members;
b. The father has had minimal contact with the child since the child's
birth;
c. The Plaintiff/grandmother has recently been allow to establish a
relationship with the child which the natural mother is now interfering
with.
WHEREFORE, the Plaintiff requests this Court award shared legal custody and partial
physical custody every other weekend from Friday night at 5:00 p.m, until Monday evening
at 9:00 p,m. and on alternating weekends and then every Tuesday and Thursday evening
from 5:00 p.m, until 9:00 p.m.
Respectfully Submitted
VER IFICATION
I, Mary Elizabeth Amico, verifies that the statements made in the above
Custody Complaint are true and correct. I understands that false statements
herein are made subject to the penalties of 18 Pa. C.B, Section 4904, relating
to unsworn falsification to authorities.
Date.
d /, JI'/I~
.
FlLED-OFRCE
OF 11':'0 r-:'rn~':mmY
97 FEB 13 PH 8: 26
CU"t:\.d;' ,,'
r., ~'I.......\',l_. \...~.....I\I:)
PENNSYLVMl~\
u7 /3 ~n
d /3 ,~n
.;J '/3 .t'l)
~,:~ ''!JY ~~' ,~c?4 ;'1~/~\
7t.::dct' A(~ ~ ~'>1 &~
(~y Ma,b ii, ~t~ c~W'I/
MARY ELIZABETH AMICO,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v.
NO: 96-6045
KRISTY HASLOCK and
ALBERT AMICO
Defendants
IN CUSTODY
PETITION FOR MODIFICATION
AND now, this _ day of February, 1997 the Plaintiff, Mary Elizabeth Amico, by and
through her attorney, Austin F. Grogan, Esquire aver the following:
1. By Court Order dated December 18, 1996 this Honorable Court ordered
partial custody to the paternal grandmother on a regular scheduled basis;
2. Since the implementation of this Court Order some conflicts have arisen with
said Order;
3. The natural father, Albert Amico has indicated his desire to have expanded
partial custody wit!, his son;
4. Attempts to negotiate expanded custody have been unsuccessful.
WHEREFORE, the Plaintiff respectfully requests this Court to schedule a conciliation
conference to address the expanded partial custody for natural father and to resolve any
disputes as to the current schedule.
Respectfully Submitted
Date: 4",4 '/
f
Austin F. Grogan, E uire
24 North 32nd Street
Camp Hill, PA 17011
717-737-1956
Attorney ID#59020
Attorney for Plaintiff
l'
"
.,
1\ '
.;:;t,;;';:.,
'':"'-
.}:
\~~'i)~,:'",,,,,, <'
.~; ".. , "
'.'.'
,
-,:'
11
;
II
!";
,,_r
,"I .. ~
gl:e, .
:';' - '~,' ;".;
Jfi~ti'~~:~, .
:":"~::_' ~'l .." .:
(I,
".: ".
: "";" ~" "
. i
l . '. .
I iW\f( 1 7 1997t1"
.
.,. ..
MARl( ELIZABETH AMICO, . IN THE COURT OF CC\'lMON PLEAS OF
.
Plaintiff CUMBERLAND COlJNTl(, PENNSl(LVANIA
vs. NO. 96-6045 CIVIL TERM
.
.
KRISTY HASLOCK and . CIVIL ACTION - LAW
.
ALBERT AMIOO, . IN CUSTOCY
.
Defendant .
.
ClU>I!'R OF <XXJRT
AND fOi, this Zo - day of
upon consideration of the attached Custody
ordered and directed as follows:
"7"11~ , 1997 I
Conciliation Report, it is
1. The Mother, Kristy Haslock, shall have primary physical
custody of Alex Haslock, born December 18, 1994.
2. The paternal grandmother, Mary Elizabeth Amico, shall have
partial custody of the Child every Wednesday f~om 4:00 p.m. until 9:00 p.m.
and during one weekend per month as followa:
A. March 8, 1997 through March 10, 1997.
B. April 4, 1997 at 5:00 p.m. until April 7, 1997 at 10:00
a.m.
C. May 2, 1997 at 5:00 p.m. until May 5, 1997 at 10:00 a.m.
The exchanges of custody under this paragraph shall take
place at the Mother's residence unless other arrangements
are made by mutual agreement of the parties.
3. The parties and their counsel shall meet with the Custody
Conciliator, Dawn S. Sunday, Esquire, for a third Conference on May 27,
1997, at 3:00 p.m.
4. 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 Orjer shall control.
Bl( THE COURT,
~./f/L
cc: Austin F. Grogan, Esquire - Couns for Plaintiff/Grandmother and
Defendant/Father
Joan Carey, Esquire - Counsel for Defendant/Mother
~..... r>~",~(...( .31.:11 ('/'1
~,'rl,
MARY ELIZABETH AMIOO,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 96-6045
CIVIL TERM
KRISTY HASLOCK and
ALBERT AMIOO,
: IN CUSTODY
Defendant
PRIm JUDGE: Kevin A. IIe88
aJSTOOY aH:ILIATIOO SlMW<< REPOOT
IN llaXIlDANCB WI'l'II CUIIlERLAND CXXm'Y RIlLE OF CIVIL PROCBOORE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
NAME
DATE OF BIRTH
aJRRFBl'Ly IN aJSTOOY OF
Alex Haslock
December 18, 1994
Defendant/Mother
2. An initial Conciliation Conference was held in this matter on
December 10, 1996. The agreement reached at the Conference was reflected
in an Order by this Court dated December 18, 1996. The paternal
grandmother petitioned for modification and a second Conciliation was held
on March 6, 1997 with the following individuals in attendance: The
paternal grandmother, Mary Elizabeth Amico, with her counsel, Austin F.
Grogan, Esquire, the Mother, Kristy Haslock, with her counsel, Joan Carey,
Esquire, and the Father, Albert Amico, who was also represented by Austin
F. Grogan, Esquire.
3. The parties agreed to entry of an
~c.A
Date
/3 / '/<}7
,
<.<-,-
Dawn S. Sunday, Esqu e
Custody Conciliator
.,~i'C.;(f ,:. ~':,'/
~~!a ~ el,}
.{,-,;.-j, ,"",'"''
IFI'~;:< \ "
f~ ',:~." ~~ :'",
"';1' -
"
t, _, :~.
!
''"'11
,r;.",
,
.;
Ij
.?i;,'
.....,..
..,.
.",..' "
>",'.' ;:.
" ".
~> . ", '.."
,',
.~ ' '.' '
"
."
-,p-"
~ !:
,i.
_.i"
.";:
.",,.;..
. ~':~:\
".' ,
:\1 ; ~<:'. "
.,>,', ,'\.-: "",I
'< ;<,,'
"
. "
",'
."
.,".
',',':'
:;.
c..:-
, .
!
'i,< . '. .
.
"
".p't"
\"
1 ~U~ 0'3 1997
.,
MARY ELIZABETH AMICO,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COONT'l, PENNSYLVANIA
1 NO. 96-6045
CIVIL TERM
vs.
KRIST'l HASLOCK and ALBERT
AMICO, Defendant
CIVIL ACTION - LAW
IN DIVORCE/CUSTODY
au>ER OF CXXJRT
AND tOi, this 'J'" day of ()......... '
upon consideration of the attached custody --contiliation
ordered and directed as follows:
, 1997,
Report I it is
1. This Court's prior order dated March 20, 1997 is vacated and
replaced with this Order.
2. The Mother, Kristy Haslock, shall have primary physical
custody of Alex Haslock, born December lB, 1994.
3. The Father shall participate with the Child in a parenting
program at the Children'S playroan in Harrisburg. It is the parties
understanding that the parenting class will be held one night per week for
approximately two (2) hours for a series of six (6) sessions. The Father
shall be responsible to pay all costs associated with the parenting
program.
4. The paternal grandmother, Mary Elizabeth Amico, shall have
partial custody of the Child every Wednesday from 4:00 p.m. until 9:00 p.m.
and during every fourth (4th) weekend (beginning Friday, May 30, 1997) from
Friday at 5:00 p.m. untj,l the following Monday at 10:00 a.m.
5. The Father shall have partial custody ot the Child on every
fourth (4th) Saturday frCAll 10:00 a.m. until 7:00 p.m., beginning June 14,
1997 provided that the Father has had at least one parenting class prior to
that date. If the Father has not participated in a parenting class prior
to June 14, 1997, the Mother shall have custody of the Child on that date.
The Father's periods of custody on Saturdays under this paragraph shall not
commence until the Father begins the parenting program.
The Fathor shall have custody of the Child on Father's Day,
June 15, 1997, from 12:00 noon until 7:00 p.m. regardless of whether the
Father has had a prior parenting class.
In the event the Father has attended at least one parenting
class prior to June 14, 1997, the Father shall have custody of the Child
from Saturday Juno 14, 1997 at 10100 a.m. until sunday, June 15, 1997
(Father'S Day) at 3:00 p.m., and this paragraph shall supersede the prior
provision regarding Father's Day.
6. The Mother shall have custody of the Child on alternating
weokends beginning June 6, 1997 and at all other times not otherwise
specified for the Father or paternal grandmother in this Order.
7. In the event the Father's parenting classes are scheduled for
Wednesday evenings and involve the attendance of the Child, the parenting
classes shall supersede the paternal grandmother'S periods of Wednesday
custody.
8. upon completion by Father of the six week parenting program,
and in the event the parties are not able at that time to reach an
agreement as to ongoing custody arrangements, either party may contact the
Custody Conciliator, Dawn S. Sunday, Esquire, to schedule an additional
Conference.
9. All exchanges of custody in this Order shall take place at
the Mother's residence unless other arrangements are made by mutual
agreement of tho parties.
10. 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.
BY THE OOURT,
* '.1..4-
cc: Austin F. Grogan, Esquire - Counsel for paternal grandmother -
Jan Terpenning - for Mother - c.~... ~A
Michael D. Rentschler, Esquire - Counsel for Father "/-1-1'11
.-J, -t',
,
MARY ELIZABETH AMICO,
plaintiff
IN THE COURT OF COOMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO. 96-6045
CIVIL TERM
.
.
KRISTY HASLOCK and ALBERT
AMICO, Defendant
: CIVIL ACTION - LAW
: IN DIVORCE/CUSTODY
l'RIm JUDGE: Kevin A. Ile88
QlS10lY CXH:ILIATIOO StHIARY REPCRl
IN ACXXlUlANCB WITII ClJlBEIUJ\ND c:x:xHfi RIlLE a.> CIVIL PIlOCEOORB
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
~
tWrE a.> OIRm
aIRRPNl'Ly IN CUSTOOY Of!
Alex Haslock
December 18, 1994
Defendant/Mother
2. A third Conciliation Conference was held on May 27, 1997 with the
following individuals in attendance: The paternal grandmother, Mary
Elizabeth Arnico, with her counsel, Austin F. Grogan, Esquire, the Mother,
Kristy Haslock, with her counsel, Jan TerpeMing, and the Father, Albert
Amico, with his counsel, Michael D. Rentschler, Esquire.
3. The May 27, 1997 Conciliation Conference was scheduled as part of
the most recent Order entered by this Court on March 20, 1997. Although
the Father was named as a Defendant in the paternal grandmother's Petition
for Custody and attended the March 6, 1997 Conciliation Conference, the
Father did not seek partial custody or visitation with the Child at that
time. Subsequent to that Conference, the Father filed a Petition for
CUstody in his own right and the Conference on his Petition was scheduled
for the same date as the Conference in the paternal grandmother's action
which is docketed at No. 96-6045. During the May 27, 1997 Conference, the
Father's counsel agreed to have the Father's Petition (Docket No. 97-2043)
consolidated with the above-captioned proceeding.
4. Tho parties agreed to entry of an Order in the form as attached.
d1Ad>~r;( ~
Dawn S. sunday, Esqu r
custody Conciliator
J~
Date
o1flyr7
.
~~
J,
.
~N 1 3 1997
MARY ELIZABETH AMICO,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
, ~
: No, 96-6045 Civil Term ..,/
KRISTY HAS LOCK and
ALBERT AMICO,
: CIVIL ACTION - LAW
Dcfendants
: IN CUSTODY
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
ALBERT AMICO, JR"
vs.
: No. 97-2043 Civil Term
KRISTY HAS LOCK,
: CIVIL ACTION - LAW
Defendant
: IN CUSTODY
RULE
AND NOW, this ~ day of ~ 1)vJ2..
, 1997, upon consideration of the
within Motion lor Consolidation, a Rule is hereby issued upon Kristy Huslock and Mary
EIiZllbeth Amico to show causc why the above two cases should not be consolidated to Term No.
96-6045 Civil Term. Rule returnable --1- S days from datc of service,
'> \,\,tAU ~
CJM~ C>>WJ ~
~vvL ~~
Jtk&-Iv~
-I~ (\t.D~
BY THE COURT,,..-,/
/
MARY ELIZABETH AMICO,
Plaintil1'
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
vs,
: No. 96-6045 Civil Term
KRISTY HAS LOCK and
ALBERT AMICO,
: CIVIL ACTION - LAW
Defendants
: IN CUSTODY
ALBeRT AMICO, JR"
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
vs,
: No. 97-2043 Civil Term
KRlSTY HASLOCK,
: CIVIL ACTION - LAW
Defendant
: IN CUSTODY
ORDER
AND NOW, this _ day of
, 1997, upon consideration of the
within Motion for Consolidation, said motion is hereby granted, The above cases are hereby
consolidated to Case No, 96-6045 Civil Term.
BY THE COURT,
J.
.':. "
<:i> .
~.':.:,> .....,
<.} i"'.:::,"',';, '; ':' ,
. ::,~.
';:' " '. ,
,::.' ":';" ,
:'~~~J'i:: '{::~-g ~,:( . .
.:_' . ~'\;.," ,.
.:" -
,,:.' ,
, .' -' ':' . " .
i';;"~:'< ",;'
,'. .,.' -- '"." '"
"~ <', '.. ' " "'. .-<,
',,:" " , .. '
:,C:' ,'c." '.. " . ., , . '
," '>", .... , " '", ,/C/'i
:h.,""'" " :. ,., :,'
.:; .,. i'/,'" ..', ':., ",..'.... . ,"}.i~~\:~:;"'~
;.' -,:, .", ", ".. .... -' ", " '., ..", :"., ',;
, """:,':\:' "",', ',:,,' ".' , ' ' " "~';';;f.~,")::':':"
.{..~ , ': ,... . . ' ;'< '.:
!", ',':;';'~:'<;,~~,,:'.~'" . .'. .,..' ,',...\:L
',:,; .~... ,","". :;<~:' ','.':
j ',::,.,."\: " :::"','" ;';?:;')
: :..,:,.,; 'if\",:,.(. . ..".'.. ..., ";':':': ";;:: . ..:^. :'..:;\'
.: ,~:". ." < ,:."',,~?:'.: >, '. ,",':,:.
,':'( :' .....,.<.:" """:,:,,,.:,.;,--, . ":';",' ..
'.",~: :, ~ . /:,.-.'i ~ .<, ''';: ',' ~.:; s(,
J~{.:,.::;; i~:-:,:\.":~ ~\ "" ;:~ ;;.
.,'~':t,~ "','< ;. .;- ".; ,
,:,.::' E :;:~ , ;;~'.}:(?r, :};",'::
YfGj g;;>.y .::) ;::~. ;,'!' ,:< ;
,~:?", i . ,1:,,"': :c;/.
." ;;: '::"';\ "j ::, ;';,<:;h:,";C;:
'",. - ,'; ';.' ., ,
5 ~:;: .:.,'" <.i,;.'<::,' ': :".
,: :>::,:' ," .<,,'i;", <::> :::;.:: <i;)~
",'. >, .' , C'"
.~;:"" :;,:.ti)
'l;.;, .., ;.'t<:". ;:~r;L,
,...
" ;/,..' ". :;:.
',,!ilt,:, ,;J,.:/': :;\~C,<, . ,';:;;:.
}''<:, '_....'. ".<~< ,':'-, ,e,
i.",~ ", ,": .: ':;"" "':' -- ',":,':'. :':," :';'\ ,
~\ /';'." c:. ':,,' :':,; :,! '. ::,,' ,,'. ~ " '.'1-
,~(,,'C':::r~":d, ":;';":1'" ,.5
;?:",:.:'~::'. ", ,";,.' .'.. ,,' :: .... ..... .:,~::~' ;;:'::'~,; ~:, ~,'
.;,;!,.,;,..~:"",-:", ..., . '.., :: ::: ,;,':"::J.
,,:c';>>>' " " ; ",11_: ...','.::.
;,,-::~;;. '.: "; . . " ': ',' ;::/ ,::~. ;;".
C;-,,":" " - , . ,","_'::;",:
(', " ,,::,<<:-
, .. .",c.,"...,..,.':
'., .... J'.'<',
., !'. ,., -W,\;,;::'f,";~::;,:;
, -. ";"'.',;
p".'
';, ."i
. ,....:' <y....;,. .?;\,\;','
, . :,: .;
, ; "':',:
: ' ;':" ,i
.' , . , ,"'.,;:, ,,:
,
"
.,~
. ..
'.~.,
" ':,"C;
,,'. ~
MARY ELIZABETH AMICO,
Plaintiff
: IN TilE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs,
: No. 96-6045 Civil Term
KRISTY HAS LOCK and
ALBERT AMICO,
: CIVIL ACTION - LAW
Defendants
: IN CUSTODY
Plaintiff
: IN TilE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
ALBERT AMICO, JR"
vs,
: No. 97.2043 Civil Term
KRlSTY HASLOCK,
: CIVIL ACTION - LAW
Defendant
: IN CUSTODY
MOTION FOR CONSOLIDATION
AND NOW, this ~day of r ' 1997, comes Michael D, Rentschler,
attorney for Plaintiff, Albert Amico, Jr., who files the within Motion for Consolidation of which
the following is a statement:
I. On November 4, 1996, Mary Elizabeth Amico filed a Pctition in Custody against
Kristy Haslock and Albert Amico docketed at No, 96-6045. Thereafler, on April 18, 1997,
Albert Amico, Jr. filed a Petition in Custody against Kristy Has\ock docketed at No. 97-2043.
2, Kristy Haslock is the natural mother of the child Alex Haslock who was born on
December 18, 1994 and prescntly rcsides with his mothcr at 82 York Road, Carlisle, P A.
3, Albcrt Amico, Jr" is the natural father of Alcx Haslock.
4, Mary Elizabcth Amico is thc matcrnal grandmother of the child Alex Haslock,
5. Mary Elizabcth Amico sceks partial custody of Alex Haslock in hcr Complaint for
Custody. Albcrt Amico, Jr., sceks partial cllstody Gfhis son Alex Haslock,
1\ .. '" ..., ""........"
rHloX. U,,"
, ,.
.
6. On May 27, I 'J'J7, the parties in the two above-capUoned cases attended a Custody
Conciliation Hearing beforc Dawn S. Sunday, Esquire, tho custody conciliator.
7. Mary Elizabeth Amico and Albert Arnico,1r., live at the same address, but Albcrt
Amico, 1r., rents a portion of the dwelling.
8. Sincc both of the above.referenced actions invoivc a Petition for Custody for the Bame
child; the parties to the respective actions constitute the natural mother, thc lIatural fathcr. and the
maternal grandmother of the child; and further since many of the same iuues apply to both cascs,
it is requested thai thc two cases be consolidated.
9. It is requested Ihat both of the above-captioned cases be consolidated into onc casc
utilizing docket No. 96-6045.
WHEREFORE, It Is respectfully requested that this Honorablc Court grant thc within
Motion and consolidate the Ilbov,: two cases to Casc No. 96-6045 consistcnt with the statements
contained herein.
Respectfully submitted,
".-.'-.
S/..J .... --;/ ,
/ ~?~=-./"~~ ""../..---:=::::-"
Michael 0, Rentschler, Esquirc
Supreme Court 1.0. No. 45836
28 North 32" Street
CampHiII,rA 17011
(717) 975-9129
MARY ELlZABETII AMICO, : IN TilE COURT OF COMMON PLEAS OF
Pluintill' : CUMBERLAND COUNTY, PENNSYLVANIA
vs. : No. 96-6045 Civil Temt
KRlSTY HASLOCK and : CIVIL ACTION - LA W
ALBERT AMICO,
Defendants : IN CUSTODY
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
ALBERT AMICO, JR.,
vs.
: No, 97-2043 Civil Term
KRISTY HASLOCK,
: CIVIL ACTION - LAW
Defendant
: IN CUSTODY
CERTIFICATE OF SERVICE
I, MICHAEL D, RENTSCHLER, ESQUIRE, hereby certify that on C.- ~ // /}<;"7, I
c::/ '
mailed by first-class mail, postage prepaid, a copy of the document to which this Certificate of
Service is attached, to:
Austin Grogan
24 North 32nd Street
Camp Hill, PA 17011
AI/Oriley for Mary Elizabeth Amico
Jan Terpenning
Legal Services
8 Irvine Row
Carlisle, PA 17013
for Kr;sty Has/ock
.___-,/.::/:;;.)/~~7-
MICHAEL D, RENTSCHLER, ESQUIRE
28 North 32nd Street
Camp Hiil, PA 17011
(717) 975-9129
MARY ELlZA13ETII AMICO,
Pluintitl'
V9.
KRISTY liAS LOCK and
ALBERT AMICO,
Defendants
ALBERT AMICO, JR"
Plaintiff
vs.
KRlSTY HASLOCK,
Defendant
AND NOW, this -9- day of
,~I\I 1181997
: IN TIlE COURT or COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: No, 96-6045 Civil Term /
: CIVIL ACTION - LAW
: IN CUSTODY
: IN TIlE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: No. 97-2043 Civil Term
: CIVIL ACTION - LAW
: IN CUSTODY
, 1997, upon consideration of the
within Motion to Make Rule Absolute, pertuining to the Motion for Consolidation of the above
two cases, and further thut there was no answer filed by either Mary Elizabeth Amico or Kristy
Haslock, objecting to the consolidution ofthe two cases to docket number 96-6045, Civil Term,
IT IS HEREBY ORDERED AND DECREED, that the above two cases are consolidated to term
number 96-6045 Civil Term.
BY THE c:OURT,
/
J,
- ~~-
C.r
~ ~1
\...:. ,4 r
IJ:r:l
OJ ,
f-J.~<:j
J.
',",
_..I I)
"
"
""
,
'"
,
..
"
.',1
,:: _I
,',I
l)
,
I' )
;:;:1
. ,.[-}
:111
.,.j
~rl' i
,""
"
(.;J
.
~~\~" ' "" . ",' '<<" .:i:
',:. .,,'..' , " ;J';l
.:. :'y: " . , ' .;,
:,.,..:_", ,:-': c, ','. , " , " :,': "'.
'.:, . " , " ','
<,c",' , .'~ :,'f
, , , .:,;;,
i ,'... ',., :, " ,\ . ,':., .', ;';;;
..,ii:i:',; '. . ,. , ' '.' ',<::/:
J~;:',';'.;":_:;' .-',",;:::. :,>
":i, > ' , " '. .,.",>:,'~/
, '--, ' , ,
:;,../':' ',' " ", ';r";":,
:X.:",:' ' ~: ' ", ,,>: ,," " ','/:;(':;.;:{~;;,.~;<t:.!
;,(,,'> ,',', " ' " ,,' ,.'" "':'" ,;'.:'.,
:C'~'~'::":'T':; "o"}';"': '" :<:,,:: 'C\,':,'.',::;: ':i; " ,i' ';
;,;,J,,: '" '.., ..:,',: '".,,';',,:\,';:\r
,".: :',' ',',',' " . " ,,", ": r":;,;,/,,.: ; ":" '! ,': ,',' ',:' ",' '.'
,.' : <::.' ',,', . .',.', ,".' '.,.:,. :,~"\ :.\.;,;
': ,:,:::'C:,i:.,:::""
;"/';';:;':<',:,;,','::,'.' " ': ,:>\:~.,'-.,>:,:;'::, '..,
'" ;:~:(:~i>;, " ".\;,.<,;.,;.(.".:,:.,:,,~:<~ !':?:;,>~f~' ~,
",. ," ',: '. :""::":':,'.'::?,:(~ '/ ..;; . i;,"J;';';.
, ''':'"::::,,
y...:'-'.. ';;a;,::':;' :,,; ,
'."',:h;:Jt':,,:, ;,::V;c:."\'~' '. ," ;,< ,::
>, .:'::::) :<:: :;<~:'>":,.' ' ,.i;,., ,r'
"<'.>~",:::/ ':""'i:, \"," " :.:, "!"i'/: ",;,...,.
'" -'" :':;','.';;"':':'- >,':":',.'
C,;:,,: .',' , ,; '~' ~ ::~.'::
',; ':, .;,:.....' - : ;,,,
.." , ',". : ': ;:}, '",
.:" ;,:;~,:.:.. ;', ,': :.-,;:
:' ':,.'; '" . ,'< .',,:,". ,~;
~; i': ,;>;.' . . .'. : '.
, ,', .....:. . , ... .
i.,:," ..' . '.'; .::~,::)'
':~::',' ..' ,":/:'j
. .'..,.... . . .-'\',:.
':>;,"..., ....;~;
,: " ; ~ . .':
i,: ,:. '. 1. I '1 . ~ ',"<
~d
----,
,- / //,~,..../
. ," -~'.' :/,::,.,.:,:~/-- ,--
.... ,-;;> /~:/~/>~~~<'~-
Michael D, Rentschler, Esquire
Supreme Court I.D, No. 45836
28 North 32nd Street
Camp Hill, PA 17011
(717) 975-9129
correct copy of said Rule is incorporated herein, made a part hercof, and attached as Exhibit "A".
5, Morc than lit\ccn (15) days have elapsed sincc the date of scrvice of thc Rulc upon
Krlsty llaslock and Mary E1iZllbcth Amico and no answer has been liIcd by eithcr Kristy Haslock
or Mary E1izubcth Amico objcctinllto thc consolidation of thc two cascs,
6, Sincc no objcctlon to thc Albcrt Amico, Jr.'s Motion for Consolidation has been liIcd
by cithcr Kristy Ilaslock or Mary E1i7.11bcth Amico, it is hcreby rcqucstcd that the abovc-
referenced Rule be made absolutc and that the cases bc consolidated to term number 96.6045,
Civil Term. A true and correct copy of Alberl Amico, Jr.'s Motion for Consolidation is
incorporated herein, made a part hereof, and attached as Exhibit "B",
WHEREFORE, it is respectfully requested that this Honorable Court grant the within
Motion to Make Rule Absolute and order that the above two cases arc consolidated to term
number 96-6045, Civil Term.
Respectfully submitted,
, ~ ~UN 1 3 1997
I\Ii\IlY I ,I.IZi\ II Ell I AI\III'C I,
I'laintiff
: IN TilE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
\":-;.
: No, 1}(,.6045 Civil Tcrm
KIUSTY IIi\SI.l)( 'K and
AI.IIEIlT AI\IIl'O,
: CIVIl. ACTION. LA W
I klCndants
: IN CIJSTOJ>Y
AI.IIEKI' i\l\lICO, m,
: IN TIlE COURT UF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
I'laintiff
\'S,
: No, 97-2043 Civil Tcrm
KRISTY IIi\SLOCK,
: CIVIL ACTlUN - LA W
I lcfcndant
: IN CUSTODY
RULE
AND NU\\', Ihis U.,- day of
~Uh~
, 1997, upon consideration ofthe
within MOlion for ('onslllidalion, a Rulc is hercby issucd upon Kristy lIaslock and Mary
Eliz<lbelh AmiclI tll shllw callsc why thc above two cascs should not be consolidated to Term No.
%-6045 Civil TCrln, I(ule rcturnable /S duys from dutc ofscrvice. ~~ 'f3r;:IIur>wt;;'(J
,_\~.. at"I....." "( ",)0.;\. Q.,~<u~
,_tJu.:L ''''(':1 I" ,t"lc.l Jc- UYTlIECOURT,
l~ (\.A...,J. { '-,}
L.:J. t<0Jr1-L 73. a.~JJ.J--
nUl: r.i.lpy mOIA RECORD
III it' rill' 'i',' . L I j-f. 11;',1 ,_, 0'110 !;r.t my hand
"lid III'J scJI of ',lid (uuiI ;:, Cilrlislc, Pa,
Ihi; J i,:tA. d"y of ,~..,~, 19,~(.1.
..."""'....~,hij~~~,,~;~~~1t~~,.._,.....
J,
~ n''!~:'r~:1\~},''fi''~t.~..r:'''.i~(!f~' ,-j .''''II:;I:;j~~~'fr'~t;:r.,""':~-,...JtT',!I~'''''''''''1'''''''":J'''''!''7J1!'',~" " ..":'".....rlF;--
'. :...~.";I-}I...''': r,:}'/1~'~';(':';j'~:'\ ; , ' i\,"~"'" .,,':.,', '. ,j'\:'~,
,..'~~..,~",,:\{,r-.....~,),,tti.~':~':"''',\,, '.' . t. 1.';,.-\,1', ' ,.,.:', " ,I"..,.
: .... ';'1' ~ .i.:,~',.,' ,:.".,. '.-";tL:i!."~~"~l. ;~,:~~'~,i"..,~',!i ""
T,' . ~.~ ".. -",., ,
,
"
.,.;
MARY ELlZABETII AMIl'( I,
I'I00inlilT
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
\'S,
: Nu, %-(.ll45 Civil Term
I' (lISTY IIASI.OCK IInd
AI.IIEI(T AMICO,
CIVIL ACTION - LA W
Ild"ndilnls
IN ellSTO!>Y
AI.IIERT AMICO, JI{..
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
n
!:~'
"'"ro:".
llii
"
;: ,
I'laintiff
\'S.
: No, <)7-2043 Civil Tenn
".,
.....
!-:
KRlsn' "ASLOCK,
: CIVIL ACTION - LA W
IlclclUJant
, '
','
'.;
.'.1
: IN CUSTODY
~'.:'
:"'1
..,
!\lOTION FOR CONSOLIDATION
AND NOW, Ihis ; "'Zdllyof Ji.,. -<--- ,1997, comes Michael D, Rentschler,
,'-- V
attorncy for Plaintill: Alhcrl Amico, Jr., who liIes thc within Motion for Consolidation of which
the fullowing is n slalcmcnl:
I, On No\'cmhcr 4, 1<)<)6, Mary Elizabeth Amico liIed a Petition in Custody against
Kristy lIaslock uml i\lhl'ft Amico docketed at No. 96-6045. l11ereafier, on April 18, 1997,
Albcrt Amico, Jr. Iikd IIPctition in Custody ngainst Kristy lIaslock docketed at No, 97-2043,
2. Kristy Ililsllll'k is thc nut ural mother of the child Alex I-Iaslock who was bom on
I >Cccmbcr Ill, )1)1).1 ilnd prcscnlly rcsidcs with his mother at1l2 York Rond, Carlisle, P A,
), AlIll'll/\mil'll. Jr.. is Ihc Ililturnl fnthcr of Alex Ilaslock,
4, t<lary Fli/ahclh Amico is thc malcrnul grandmothcr of the child Alcx lIaslock,
), ~'ilIY I'li/ilhcth Amicn sccks partial custody of Alex I Ius lock in hcr Complaint for
Cuslody, Allwlll\mil'll, Jr.. sceks parliul cuslody of his son Alcx lIuslock,
..."..
(')
'q
,)
l;fJ
'")
,1-
, ,
" ,
, ')
'--'.
. )..
.',)
, ,In
':'1
,lJ
..;,;
i
I
I
i
I
i
I
i
i
I
I
I
I
i
-"1
. i
i
\
6. On May 27, 1997, the parties in !he two above-caplloned CllSCS altcnded a Custody
Conciliation HearinG before DaWll S, Sunday, Esquire, !ho custody conciliator.
7, Mary Elizabeth Amico and Albert Amico, Jr"live at!ho sallie address, but Albcrt
Amico, Jr,. rents a portiulIlIllhe .Jwellinll.
8. Since bollt of the Ilhllve.referenced IIctions Involve al'ctition for Custody for the samo
child; the parties to the rC5I'cd"..e actions conslitute the natural mothcr, the natural fathcr. and thc
matclllalllrandmothcr of the child; and funhcr sincc many of !he same Issucs apply to both cases,
it is rllljuc!ilcd that the 1"" lilIes be consolidated,
9, It is requcstc,lthat both oCthc above-captioned cascs bc consolidated Into onc case
utilizinG docket No. 96.6045.
WHEREFORE, II 15 respectfully requested that this Honorable Court grant !he: within
Motion and consolidate the nhovc two cases to Case No. 96-6045 consistent with the statements
contained herein,
Respectfully submitted,
~---~~~~
Michael 0, Rentschler, Esquire
Suprcmc Court I.D, No. 45836
28 North 32" SUcet
Camp Hill, PA 17011
(717) 975-9129
":~
\,i
"
li
~w~l\~;W "
, "If"
;i~ (it
1
, ,
'il':;'
c;.."
<....
,'..
:F;'~':,
"" '~
"" J{~a Po '
rL )::.,~I.
>. ,.,"
~F' ,
.~' l~~;.: ::;. >.'.
"',Ii, ,
':',',
''-,
."~
,
i
i.
i
'-,'
;,;
,r.,
,~;':-:.' .. ,. :
,'-
.1,1
.B~
]1
,'i.
"l" . ., tt'
, ".itIll.~l~I;I'
;, '~]ittlJ~': ,. ....
:i,,::,::,...,;;,..lL"1
.";;;t:~~
"
"
.,. . "
.. . . . .
, .
" dO
r .., .
" (
\ .
...
,
MARY ELIZABETH AMICO,
: IN THE COURT OF WIMON PLEAS OF
CUMBERLM~D COUNTY, PENNSYLVANIA
Plaintiff
.
.
vs.
NO. 96-6045 CIVIL TERM
,
.
KRISTY HASLOCK and ALBERT NUCO,
Defendants
CIVIL ACTION - LAW
DIVORCE/CUSTODY
OODER OF <XXlRT
AND ~, this /?-U; day of It tbtltU
consideration of the attached Custody concil1~tion Report,
and directed as follows:
, 1997, upon
it is ordered
L This Court's prior Order dated June 3, 1997 is vacated and
replaced with this Order.
2. A Hearing is scheduled in Court Room # L( of the
CumbeJ:land County Court House, on the .;;1G. ,Ij day of
~,'l'UuL/\..l-j.. , 19'7'{. at q:.~C>o'clock, a... .m., at which time
test:lfnony will ~ taken in th s case. At the Hearing, the Father, Albert
Amico, shall be deemed to be the moving party and shall proceed initially
with testimony. Counsel for the parties shall file a Memorandum with the
Court and opposing counsel setting forth each party'o position on custody,
a list of wi tnesses who will be called to testify at the Hearing and a
sunmary of the anticipated testimony of each witness. These Memoranda
shall be filed at least ten (10) days prior to the Hearing.
3. The Mother, Kristy Haslock, shall have primary physical
custody of Alex Haslock, born December 18, 1994.
4. Pending further Order of Court or agreement of the parties,
the Father, Albert Amico, shall have partial physical custody of the Child
every week from Wednesday at 6:30 a.m. when the Father shall pick up the
Child at the Mother's residence, through the fOllowing Thursday at 3:30
p.m.
5. Pending further Order of Court or agreement of the parties,
the paternal grandmother, Mary Elizabeth Amico, shall have partial physical
custody of the Child on every fourth weekend from Friday at 5:00 p.m. until
the following Monday at 10:00 a.m.
6. The parties shall follow the regular custody schedule set
forth in this Order over the Thanksgiving and Christmas holidays in 1997.
Accordingly, the Father shall have custody of the Child until 3:30 p.m. on
Thanksgiving Day and on Christmas Eve through Christmas Day at 3:30 p.m.
The paternal grandmother's regular weekend period of custody will begin on
December 26 at 5:00 p.m.
7. In the event the Mother decides to obtain a professional
custody evaluation, at her sole cost, prior to Hearing in this matter, the
Father and the paternal grandmother shall cooperate in participating in the
evaluation as deemed necessary by the evaluator.
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MARY ELIZABETH AMICO,
vs.
NO. 96-6045 CIVIL TERM
KRISTY HASLOCK and ALBERT AMICO,
Defendants
CIVIL ACTION - LAW
DIVORCE/CUSTODY
PRIOO JUDGE: Kevin A. /less
cusrooy CDlCILIATIOO stM<IARY REl'(Rl'
IN ACIDUlANCE wrm ctJ1BERLAND CXJ{Hl'l( RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned CUstody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the
subject of this litigation is as follows:
NAI1E
DATE OF BIRTH CURREm'LY IN CUS'lOOY OF
Alex Haslock
December 18, 1994 plaintiff/Mother
2. A fourth Conciliation Conference was held on October 7, 1997,
with the following individuals in attendance: The paternal grandmother,
Mary Elizabeth Amico, with her counsel, Austin F. Grogan, Esquire, the
Mother, Kristy Haslock, with her counsel, Joan Carey, Esquire ana Jan
Terpening, and the Father, Albert Amico, with his counsel, Michael D.
Rentschler, Esquire.
3. As the parties were not able to reach an c:greement at the
Conference as to a partial physical custody schedule for the Father, it
will be necessary to schedule a Hearing. The parties were able to agree on
partial custody arrangements pending Hearing which are reflected in the
attached Order. Neither the Father nor paternal grandmother believed that
a custody evaluation is necessary, but agreed to cooperate fully in an
evaluation if the Mother decided to obtain one at her sole cost.
4. The Father's position on custody is as follows: The Father
seeks to have periods of alternating weekend custody with the Child in
addition to regular periods of weekday custody. The Father believes the
existing partial custody schedule should be expanded in light of the fact
that he cooperated and completed the parenting program lit the Children' e
Playroom as requested by the Mother at the last conciliation Conference.
The FatheL' believes that any problem the Child (2 years of age) may be
experiencing during exchanges of custody is due to the fact that the Child
does not see his Father enough and that this anxiety would be resolved by
more frequent contact between the Father and the Child.
5. The paternal grandmother's position on custody is as follows:
The grandmother believes that it is the Mother's influence that causes the
Child to be anxious during exchanges of custody, The paternal grandmother
agrees with the Father that any anxiety the Child may be experiencing
during exchanges of custody are due to the fact that the Child does not