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PAGE 02
HOWARD,D "Co
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^TrORNEYS ^T LAw
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Sumt 1~
SfATEN IslAND, NY 10314,
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February 28, 2000
Robert L, O'Brien, Esq.
O'Brien. Batic& Scherer
17 West South Street
Carlisle. PA 17013
Re: ,Hudson v. H;udSon
, Dear Mr. O'Brien; ,
, ' Please be $tvised that,I repres;,nt Wiliiam H~son i!l regard ~oa custOdy prOCeeding lie "
" has commenCed in Supreme Court, ~e\wiond County, City and Stale of-New York, ",'
. We haVe ~tly obtained a te~po~R,l<straininS Order'ban.1ng Cluistmil!'tudson
,from enforcing any Order that may have been issued!>y the CoUrt 9f Common PI~~ of ,
, ",' cumberllmd, PCllJUYlvaniil. (am' enclosing 'herewith a, courtesy ,copy: of bOth ~e ,
:' TeJn}'Orary Restrainil1l! Order ~ ~e petitioirforCustody. ' IfYQU woUkllike to .~~ '.,
, 'serVice of' these ~ on tiehidf of. ChriStina 'HudSon, 'pl\lllSC: advise , accordingly, .
. ..otherwise we will,amuige'to have b. seryed tbrougb the local Sheriffs Office. .
Sh~~ldyou~h to discuss this matter at 'greater length, please con~t the w1dersiinedat: ,
, , your earliest convenience. '
,-
Vi ARD M.FILE, ESQ. .
, Enclosures
Via Facsimile & Overnight Mail
ec: Rev. William Hudson '
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~~
At an ~ Part ~ ~f the Supreme
Court of the State of New York held
In and for the County of Richmond at
The Courthouse thereof located at the
Home Port, 355 Front Street, Staten
Island, New York on the ~~day of
February 2000. ----
PRE S E NT:
HON. PATRICIA M. DiMANGQ
JUSTICE.
--------------------------------------x
In the Matter of a Proceeding
For Custody
WILLIAM L. HUDSON,
ORDER TO
SHOW CAUSE
(Uniform Child
Custody
Jurisdiction
Act) 7
Index NO''8()64/dU
Petitioner,
-against-
CHRISTINA R. HUDSON,
Respondent.
---------------------------------------K
Upon the annexed Petition of WILLIAM L. HUDSON
verified the 25th day of February 2000, the Affidavit of
WILLIAM L. HUDSON sworn to the 25th day of February 2000.
the Affirmation of HOWARD M. fILE, ESQ, dat:ed February 25,
2000, and upon all the papers arid proceedings had
heretofore herein, let the responcent show cause befcre
. mi I I , f th'
Hon. Justioe patricia Dl.Mango at a .-n .Part ..LJ.- 0 1S
Court located at the Supreme Court, Richmond County, Horne
Port, 355 Front Street:, Staten Island, ~ew York on the ~
day of March 2000 at 9:30 a.m. in the forenoon of that day,
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or ac ooon thore~ftor ~e oounQQl ean b~ hA~rrl. why ~n nrnPT
should not be entered
(a) enjoining respondent frOlf,
prosecuting and/or enforcing any Order of Custody issued by
the
State of Pennsylvania pending
the hearing and
determination of this action,
(bi granting petitioner
temporary custody of the infant child 'Mary Clare Hudson;
and (c) for such other and further relief as to the Court
may deem just and proper under the circumstances.
ORDERED that pending the hearing and determination of
this action, it is hereby
ORDERED that any custody proceedings cOllUllenced by the
respondent in the Court of Common Pleas of Cumberland
County, Pennsylvania and any Orders issued therefrom be and
the same ,'are hereby stayed pursuant to the provisions of
Section 75-g of the Domestic Relations Law until further
'.
Order of this Court; and it is further
ORDERED that service of the within Order to Show Cause
and its supporting. papers, together with the Petition for
cus~~~P~4~' respondent,
~i~~if~ and requlAr ~r'l on or
CHRISTINA
R. HODSON,
by
,{^ day of
before the
2
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March 2000 at- l~ F.:lI~'" t"i...Jt't'a'Qd, ~a!'1~a1.9. pVAA8~.1.all':d lJv13
shall be deemed good and sufficient service.
E N T E R
\lJl!l~~
J.S.C.
HON. PATRICIA M. DiMANGO
JU~nCE OF THE SUPREME COURT
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SUPREME COORT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND
--------------------------------------K
In the Matter of a Proceeding
For Custody
.
AFfIDAVIT
WILLIAM L. HUDSON,
Petitioner,
(Uniform Chi ld
Custody
Jurisdiction
Act) ,
Index No. W{~CO
-against-
CHRISTINA R. HODSON,
Respondent.
---------------------------------------K
STATE OF NEW YORK )
55. :
COUNTY OF RICHMOND )
WILLIAM L. HUDSON, being dJly sworn, deposes and
swears:
1. Your deponent is the petitioner named in the
above captioned proceeding and, as such, I am fully
familiar with the facts and circumstances surrounding ~his
action.
I make this affidavit in support of the within
application for an Order enjoining the respondent from
enforcing any Custody Orders issued out of the State of
Pennsylvania related to my infant daughter Mary Clare
Hudson pending a hearing and determination of my within
Petition for Custody.
2. The respondent CHRISTINA R.' HUDSON and I were
married on January le, 1986 in the State of Pennsylvania.
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'.
3. Thereafter my wife and I were divorced in the
State of Ohio pursuant to a Oi vorce Decree annexed hereto
"
and marked hereof Exhibit "Au.
4. There were two (2) children born during our
mi;lrriage, to wi,t, Mary Clare Hudson born May ?, 198?, and
Charles William Hudson born July 29, 1988.
5. The Ohio Divorce Decree doe~ not address the
issues of custody, visitation, and child support.
6. I have been a resident of the St~te of New York
for over eight (8) months and am currently residing at 280
Bement Avenue, Staten Island, New York.
I am also the
Pastor of the Calvary Presbyterian Church located at 909
Castleton Avenue, Staten Island, New York.
7. .. I make this application and bring this Petition
for Custody due to the fact that my infant daughter Mary
Clare, who is now 12-1/2 years old, has resided with me for
approximately one (1) month and does not wish to return to
her mother because she has been total.ly neglected by the
respondent.
8. In particular. my ex-wife has stated to me that
Mary Clare, while under her exclusive care, has become
sexually promiscuous, a truant from school, a~d her school
grades have deteriorated significantly.
Additio~a1ly. Mary
Clare has expressed to me that she does not feel sa fe in
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respondent's custody.
9. I verily believe that it would be in Mary Clare's
best interest if she remained in my custody since, as
Pastor of the Calvary Presbyterian Church, I can provide a
safer environment that hopefully will undue the harm that
h03 been CQuocd to her while in my 9x-wife's custody.
10. Upon information and belief, my ex-wife recently
made application to the Court of Common Pleas of Cumberland
County, Pennsylvania for temporary custody of Mary Clare,
however it appears that an Order of that Court was issued
on February 22 setting a hearing date for February 24,
without any advance notice to your del'onent. I thus was
unable to timely appear or contest my ex-wife's application
and the C'Ourt in Pennsylvania may have issued a temporary
order in my absence.
11. Insofar as Mary Clare is nOW residing with me in
the State of New York and has expressed a desire to remain
in my sole custody due to her mother's neglect, !
respectfully pray for the relief requested herein.
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PAGE a9
12. No previ,ous application has been made for the
relief requested herein.
vJ
WILLIAM
Sworn to before, me this
day of February 2000.
1Ze~.
IIAIllA Ilf.UJllER
Cono. .. aI Ooodf.
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PAGE lEi
SUPRBME COURT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND
--------------------------------------1(
In the Matter of a Proceeding
For Custody
AFFIRMATION
WILLIAM L. HUDSON,
Petitioner,
(Uniform Child
Custody
,1urisdiction
Act) / )
Index No.1a{,4;o~
,
-again9t-
CHRISTINA R. HUDSON,
Respondent.
---------------------------------------x
HOWARD M. FILE, ESQ., being an attorney duly admitted
to practice law in the State of New York, affirms the
following under the penal ties of perj ury,:
Your affirmant is the attorney for the petitioner
named in the above captioned proceeding and I make this
affirmation in' support of the wi thin application for
certain
injunctive
and
relief
pending
the
hearing
determination of the petitioner' 9 request for custody of
the infant child Mary Clare Hudson.
This application is
being made pursuant to Section 75-g of the Domestic
Relations Law, Article 5A of the Domestic Relations Law,
and the companion Family Court Acts, Sections 467, 549,
651, 652 and 654.
The infant child is now in the physical custody of the
petitioner in the State of New York and s.he has e><pressed
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PA3E 11
to me her desire to remain with her father since she fears
for her physical safety if left in the care of her mother.
It
that
while under
the
appears
of
care
the
respondent/mother, Mary Clare has been falsely accused of
being" sexually ,promiscuous, a truant from school, and her
school grades have suffered accordingly.
Based on my interview of the infant child, I verily
submit that it would be in the best interest of Mary Clare
to remain in the custody of her father" who is the Pastor
of calvary Presbyterian Church located at 909 Castel ton
Avenue, Staten Island, New York.
In this environment, the
infant child wi.ll certainly have the opportunity to feel
safe and free from unfounded amoral behavior and thus
achieve family morals and values that have been laCking for
several years.
In view of the foregoing, your affirmant respectfully
prays for the relief requested herein.
Dated.:
Staten Island, New York
February 25, 2000
,
~
H~ D M. FILE,
ESQ.
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PAGE 12
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND
--------------------------------------x
In the Matter of a Proceeding
For Custody
PETITION FOR
CUSTODY
WILLIAM L. HUDSON,
Petitioner,
(Uniform Child
Custody
Jurisdiction
Act) 1
Index No.s?D~/oO
-against-
CHRISTINA R. HUDSON,
Respondent.
--------------~-----------.------------x
The
undersigned
HUDSON.
petitioner,
WHLIlIM
L,
respectfully shows that:
1. Petitioner, WILLIAM L. HUDSON, is a resident of
the County of Richmond, City and State of New York,' and
resides at 280 Bement Avenue, Staten Island, New York.
2. Petitioner is the natural father of the infant
child, Mary Clare Hudson, born May 7, 1987.
3. The respondent, CHRISTINA R." HUDSON, is the ex-
wife of the petitioner and mother of the infant child Mary
Clare Hudson and currently resides at 14 East Oakwood,
Carlisle, Pennsylvania 17013.
4. This proceeding is being commenced for the
purpose of awarding physical custody of the infant child
Mary Clare Hudson to the petitioner.
5,
The name. present address.
ace and d~te of birth
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the child affected by this proceeding is as follows:
(a) Mary Clare Hudson
(b) Present Address: 2BO Bement Avenue, Staten
Island, New York;
(c Date of Birth: May 7, 19B7.
5. That peti tioner and respondent were divorced on
or about March 17, 1999 in the State of Ohio by a Divorce
Decree which did not address the parental rights,
responsibilities, child support and/cr visitation of the
infant children of the marriage, including the infant child
Mary Clare Hudson.
6. That since in or about February 18, 2000, the
infant child Mary Clare Hudson has resided with the
petitioner in the State of New York and has expressed a
desire to remain in petitioner's sole physical custody
because she is in fear of her safety if left in the care of
the respondent.
- 7. That upon information and belief, it would be in
the best interest of the infant child Mary Clare Hudson to
remain in the sole and exclusive physical custody of the
petitioner due to the fact that the respondent has
neglected said infant child,
infant child of being sexually
and has caused her schcol
has falsely accused said
promiscuolJs and a truant,
grades
to
deteriorate
2
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accordingly.
WHEREFORE, petitioner prays for an Order awarding
custody of the infant Mary Clare Hudson named herein to the
petitioner, and for such other and further relief as to the
Court may dete~roine just and proper.
Dated: Staten Island, New York
February 25, 2000
Yours, etc.
HOWARD M. fILE, ESQ., F.C,
~ttorney X Petitioner
BY:
HOWARD ESQ.
260 Christopher Lane
Suite 102
Staten Island, New York 10314
(718) 494-8800
3
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HOWARD M FILE ESQ PC
STATE Of NEW YORK
53. :
COUNTY OF RICHMOND
swear:
I I WILLIAM L. HUDSON, 'being duly 'sworn, depose and
I am the p~titioner named in the within action; r have
read the foregoing Petition for Custody and know the
contents thereof; the same, is true to my own knowledge,
except as to the matters therein stated to be alleged on
informCltion and belief, and as to those matters I believe
it to be true.
~
Sworn to before me this
of fl!ru:Y', 200~
,Q~
pu/, 'ic
MARIA BELLMIER
Com/llIIIlOMr of Deeds
,/ CI\lIof N..,Voric No. s-866
Ce/lWIcale RIM In Rlehmond CoVfIly,,/ftj I
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PAGE 16
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, IN THE COURT OF COMMON PLEAS
, OMSION OF DOMESTIC RELA nONS
STARK COUNTY, OHIO
--.1
. WILLIAM L. HUDSON }
: 71 West Summit Street }
! Alliance, Ohio 44601 }
! SSN: 434.98-5868 }
. 008: 01-14.55 }
, Employer: Sebring Presbyterian Church }
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Plaintiff
. vs.
CBRlSTINA R. HUDSON
14 East Oakwood
Carlisle, Pennsylvania 17013
SSN: 184.38.7293
OOB: OS-IS-56
Employer: Carlisle Area Schools
Defendant
CASE NO. 19\1S-DR.1206
JUDGE STUCKI
AGREED JUDGEMENT ENTRY
This malter came before the Court upon the Plaintift"s Complainl for divorce. The
Court finds that the parties stipulate as follows:
I. The parties were manied January 18,1986 in G81tOIl, PeMSylvania.
2. The parties separated on or aboUl October I, 1996 and have continuously lived
separate and apart without cohabitation since that date, for a period in eltcess of one year.
3. A parent child relationship exists in ac:cordance with Ohio Revised Code
~3l11.01lhrough g3111.19 with two cllildren;
MARY CLARE HUDSON
BORN: May 7,1987
and
CHARLES Wn.LIAM HUDSON
BORN: July 29, 1988
4, The children have conlinuously been residents of the Stale ofPeMsylvania
since the dale of the parties separation on or about October I, 1996.
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5, The panies have divided all personal property, furnishings, and bank aCCOUnts
to their full satisfaction,
6, The parties have divided all marital debt to lheir full satisfaction.
7, Neither pany makes any claim on any pension plan. IRA. Profit Sharing, 4011C,
or other qualified retirement accounts of the other party,
8, After consideration of the factors in Ohio Revised Code Section 3105.18 and
3105.171, neither pany makes any claim against the other for Spousal Support.
IT IS THEREFORE ORDERED. ADJUDGED AND DECREED, as follows:
I, Plaintiff is hereby granted an absolute and complete divorce from Defendant on
the grounds of incompatibility and living separate and apart fur a period in excess of one
year without cohabitation.
2. That all issues relating to the children such as Parental Rights and
Responsibilities, child support, and visitation are held for naught and not to be decided by
this Court due to the fact that the children have be residents of the State of Pennsylvania
for a period in excess ofsix (6) months removing jurisdiction over such matters from this
Court. Any action involving issues of the children such as parental rights and
responsibilities, child support, or visitation shall be taken up with the State of Pennsylvania
or through an appropriate UFISA action,
3. Each party shall retain any and all household goods, furnishings, personal
property, motor vehioles, or bank acoounts presently held in his or her name or possession.
free and olear of any claim of the other party, Each shall assume responsibility for any
liens, debts, or other obligations on said items they relain and hold the other party
harmless for same.
4. Each party shall assume responsibility for debts incurred in his or her name and
any debts incurred by them since the date of separation and hold the other party hannleS!,
5. Neither party shall be responsible for'llny payment of spousal support to the
other.
6. l::ach party shall retain as his or her own separate property any qualified
retirement accounts. including but not limited to, IRA. pension fund, 401K fund or profit
sharing fund. free and clear of any claim of the other party, Each party shall execute any
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ii documents necessary to facilitate this separation as required by the fund holder or plan
j
,
administrator.
7, Neither Plaintiffoor Defendant from the date of this eOlry shall incur any debts
; or obligations upon the credit of lhe other and each shall indemnify and save the other
:: absolutely harmless of any debts or obligations so charged or otherwise incurred,
"
"
IT IS SO ORDERED
Cost to deposit with any remainder to the Plaintiff herein,
DATE:
JUDGE DAVID STUCKI
MAGISTRATE
, APPROVED:
----.
G' T.YO
Attomey for P intift'
: 230 N. 15th Street
Sebring, Ohio 44672
, 'Pbone: (330)93&.2110
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CHRISTINA G. HUDSON
Plaintiff
Vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000- er?q CIVIL TERM
IN CUSTODY
WILLIAM L. HUDSON
Defendant
ORDER OF COURT
AND NOW THIS 2. '2 ~day of February, 2000, upon review of the attached
Petition for Special Relief, this Court sets a hearing in this matter for 1hVrl"'~ '
the 2-'1" day of lV1Jvu"-f ' 2000, at /D AM.lH- in Courtroom # 'I
_, of the Cumberland County Courthouse, Carlisle, Pennsylvania.
BY THE COURT,
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CHRISTINA G. HUDSON
Plaintiff
Vs,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000- CIVIL TERM
WILLIAM L. HUDSON
Defendant
IN CUSTODY
PETITION FOR
SPECIAL RELIEF
1) Petitioner is Christina G. Hudson, Plaintiff in the above-captioned action.
2) Respondent is William L. Hudson, Defendant in the above-captioned
action.
3) Petitioner incorporates the pleadings as set forth in her Complaint for
Custody herein.
4) Petitioner has been denied reasonable access to and custody of her child
and requests that the Court set an emergency hearing so as to set the parties' rights
herein in regard to custody of Mary Clare Hudson, age 12 years, born 5/7/87.
5) On February 18 the parties met halfway between their homes so Mary
Clare could have a visit with her Father. It was Petitioner's clear understanding with
Respondent the parties would meet halfway on Sunday so their daughter could attend
school on Monday the 21 st.
6) When the Petitioner called the Respondent to arrange a time she was told
that Mary Clare would not be returned. The Respondent refused further
communication with the Petitioner, The Petitioner was contacted by a children's
service worker from New York who stated that allegations had been made that she had
1-
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neglected her daughter. Petitioner has contacted Cumberland County CYS to report
this and to have them fully investigate the allegation which she adamantly denies,
Petitioner believes that her daughter is manipulating the fact of her parent's divorce so
as to avoid discipline in her Mother's home as well as school. Petitioner is employed
by the Carlisle school system as a licensed psychologist and believes that it is critical
that custody of her daughter be returned to her to permit her daughter to finish the
current school year and to deal with the responsibilties attendent with living with her
mother and schooling. Petitioner belives that her daughter is not and cannot attend
school at her Father's home due to the school records being in Carlisle, A change in
the custody of her daughter is better arranged at the conclusion of this school year,
WHEREFORE, Petitioner respectfully requests that Your Honorable Court set an
emergency hearing so as to set the parties' rights herein in regard to custody of the
parties' child, Mary Clare Hudson.
Respectfully submitted,
Date: z...12--2-l6'O
7Cl3/LV
Robert L. O'Brien, Esquire
O'BRIEN, BARIC & SCHERER
17 West South Street
Carlisle, PA 17013
(717) 249-6873
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I verify that the statements made in the foregoing Petition for
Special Relief are true and correct, I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to
authorities.
DATE:
. .
IN THE COURT OF COMMON PLEAS
DIVISION OF DOMESTIC RELATIONS
STARK COUNTY, OIDO
WILLIAM L. HUDSON }
71 West Summit Street }
Alliance, Ohio 44601 }
SSN: 434-98-5868 }
DOB: 01-24-55 }
Employer: Sebring Presbyterian Church }
CASE NO. 1998-DR-1206
JUDGE STUCKI
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Plaintiff
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GREED JUDGEMENT ENTRY
vs. '\
CHRISTINA R. HUDSJN
14 East Oakwood
Carlisle, Pennsylvania 17Q13_._,_,__' ",-
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SSN: 184-38-7293
DOB: 08-15-56
Employer: Carlisle Area Schools
Defendant
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This matter came before the Court upon the Plaintiff's Complaint for divorce. The
Court finds that the parties stipulate as follows:
1. The parties were married January 18, 1986 in Galton, Pennsylvania,
2, The parties separated on or about October 1, 1996 and have continuously lived
separate and apart without cohabitation since that date, for a period in excess of one year,
3, A parent child relationship exists in accordance with Ohio Revised Code
93111.01 through 93111.19 with two children:
MARY CLARE HUDSON
BORN: May 7,1987
and
CHARLES WILLIAM HUDSON
BORN: July 29,1988
4, The children have continuously been residents ofthe State of Pennsylvania
, since the date of the parties separation on or about October 1, 1996,
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5, The parties have divided all personal property, furnishings, and bank accounts
to their full satisfaction,
6. The parties have divided all marital debt to their full satisfaction.
7, Neither party makes any claim on any pension plan, IRA, Profit Sharing, 401K,
or other qualified retirement accounts of the other party.
8, After consideration of the factors in Ohio Revised Code Section 3105.18 and
3105,171, neither party makes any claim against the other for Spousal Support,
IT IS THEREFORE ORDERED, ADJUDGED AND DECREED as follows:
1, Plaintiff is hereby granted an absolute and complete divorce from Defendant on
the grounds of incompatibility and living separate and apart for a period in excess of one
year without cohabitation,
2, That all issues relating to the children such as Parental Rights and
Responsibilities, child support, and visitation are held for naught and not to be decided by
this Court due to the fact that the children have be residents of the State of Pennsylvania
for a period in excess of six (6) months removing jurisdiction over such matters from this
Court, Any action involving issues of the children such as parental rights and
responsibilities, child support, or visitation shall be taken up with the State of Pennsylvania
or through an appropriate UFISA action,
3, Each party shall retain any and all household goods, furnishings, personal
property, motor vehicles, or bank accounts presently held in his or her name or possession,
free and clear of any claim of the other party, Each shall assume responsibility for any
liens, debts, or other obligations on said items they retain and hold the other party
harmless for same,
4. Each party shall assume responsibility for debts incurred in his or her name and
any debts incurred by them since the date of separation and hold the other party harmless,
5, Neither party shall be responsible for'any payment of spousal support to the
, other,
6, Each party shall retain as his or her own separate property any qualified
retirement accounts, including but not limited to, IRA, pension fund, 40 lK fund or profit
sharing fund, free and clear of any claim of the other party, Each party shall execute any
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documents necessary to facilitate this separation as required by the fund holder or plan
administrator,
7, Neither Plaintiff nor Defendant from the date of this entry shall incur any debts
or obligations upon the credit of the other and each shall indemnifY and save the other
absolutely harmless of any debts or obligations so charged or otherwise incurred,
IT IS SO ORDERED
Cost to deposit with any remainder to the Plaintiff herein,
DATE:
JUDGE DAVID STUCKI
MAGISTRATE
APPROVED:
-----
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" Attorney for P intitT
'1230 N. 15th Street
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'Phone: (330)938-2110
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Subj: Re: 1 love you, Clare
Date: 7i2199 9:23:45 AMEastem Daylight Time
From: Dimof1d955
T.o: ~GH3
NO, Charles did not get a card from Sara. Did Sara send him one? Well, I am jus not haveing a good time here and I think dad
is going to get ride of 801 because he says" it's way to slowr So then 1 really can' talk to you anymore unless 1 call or you
call here. And I just wanna go home I miss all my friends and you and Dad sends all his time with jaque and I don' want him
to and jaque is mean and they lell us home alone one time! The store they went to was like a couple blocks but who cares, I
love you
Clare
, We:dneada)\ February:n. 200D' Arn..-foe Onllrir. -eRGHa Pete: 1
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Subj: mom
Date: 7/2/99 to:40:07 AMEastem Daylight Time
From: Dimofl!l955
To: CRGH3
Mom,
I would really like it if you please tell dad that I need to come home or come and get me because#1 I am not haveing fun!
#!21 get yelled at alol! and #31 just wanna be with you! Please
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Subj; Re; Hi moml
Date; 7/11ge4:29:15PM-Eastem DayJigbt/'Time
FI'OIl1: Def1a~1695
To: ~GH3
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Hey mom! I have another screeen name here it is Dimond955. So we can 1m each toher. I would very much like it if you were
to tell dad I don' want to Iiw with him not me because I don' want to hurt him. Well do you think I could come home or is that
out of the qeustion because I really would like to becvause #1 I am not h8\ing fun here and #2 I would like to talk to my mends
and be with you again. All he does is spend time with jaque g2g bye
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Wednesclay.FebruB,,-lI8.2000 AmeJloaOnllnr.-cRGHI Peael"
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Subj: MOlD ~ease
0ale:7ItJ$94:-45:20 PM Eastem DaylightTlme
From:DiJttoI1\l855
To: CRGH3
MOm this is Clare on my screen name dad gave me, well, I want to go home now!
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Date: 71tm 7:14:49PMSastem Daylight Time
From: Oimol1!l955
To: ~GH3
Mom,
I want you to tell him now me! And also New Y or!< doesn~ have 4th of July, I mean you can buy anything cool here. I
wanna come home because you can~ buy fire crackers or anything and I don~ really want to go to church here and I just want
to go home now! Please let me Bye
Clare
Wednescf~Februllry2l.2QOO AmerfoeOnUne:-cRGHS 'Claw. 1
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CHRISTINA G. HUDSON,
Plaintiff
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IN THE COURT OF COMMON PLEAS OF
V.
CUMBERLAND COUNTY, PENNSYLVANIA
WILLIAM L. HUDSON,
Defendant
CIVIL ACTION - LAW
2000-0979 CIVIL TERM
IN CUSTODY
IN RE: PETITION FOR SPECIAL RELIEF
ORDER OF COURT
AND NOW, this 24th day of February, 2000, after
hearing, the court finds that the Commonwealth of Pennsylvania
is the home state of the subject child and that this court has
jurisdiction of this case. The court finds further that the
child has been wrongfully removed from the Commonwealth of
Pennsylvania.
Pending conciliation and further order of court,
primary physical and legal custody of the child, Mary Clare
Hudson, is awarded to her mother, Christina G. Hudson, subject
to such rights of partial custody in the father as the parties
shall agree. Appropriate law enforcement officials are
authorized to assist in the enforcement of this order.
By the Court,
Robert L. O'Brien, Esquire
For the Plaintiff
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William L. Hudson
280 Bement Avenue
Staten Island, NY 10310
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CHRISTINA G. HUDSON
Plaintiff
Vs,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000- q,q CIVIL TERM
IN CUSTODY
WILLIAM L. HUDSON
Defendant
ORDER OF COURT
AND NOW THIS SiS:" day of ~ ~~ , 2000, upon consideration of
the attached complaint, it is hereby directed that the parties and their respective
counsel appear before \\ ff r-\- '1-, (''), \ \0:{ ) ~ ' , the conciliator, at
~' I~--<:"" onthe.Q:)dayof 0\ ,2000atUO
. ,1P.M., for a Pre-Hearing Custody Conference. At suc 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.
BY THE COURT,
The Court of Common Pleas of Cumberland County is required by law to comply
with the Americans with Disabilities Act of 1990. For information about accessible
facilities and reasonable accommodations available to disabled individuals having
business before the court, please contact our office. All arrangements must be made at
least 72 hours prior to any hearing or business before the court. You must attend the
scheduled conference or hearing,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OF 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
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
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CHRISTINA G. HUDSON
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Vs.
CIVIL ACTION - LAW
NO.2000-97'1 CIVIL TERM
IN CUSTODY
WILLIAM L. HUDSON
Defendant
COMPLAINT FOR CUSTODY
1, Plaintiff is Christina G. Hudson, an adult individual, currently residing
at 14 East Oakwood Drive, Carlisle, Cumberland County, Pennsylvania, 17013.
2, Defendant is William L. Hudson,' an adult individual, currently residing
at 280 Bement Ave., Staten Island, NY 10310.
3. Plaintiff seeks custody of the following children: Mary Clare Hudson,
born May 7, 1987 and Charles William Hudson, born July 29, 1988.
The children were not born out of wedlock.
The children had been in the custody of the Mother, and Charles remains
with the Mother. Mary Clare went to visit her Father on February 18, 2000 and now is
being kept by the Father despite the fact it was understood by the parents that she
would be returned for school on February 21.
During the past five years, or since the children's births, they have
resided with the following persons at the following addresses:
(a) from November 30,1995 to the present with the Mother at 14 East
Oakwood Drive, Carlisle PA.
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(b) Prior to November, 1995 the children resided with the both parents in
Ohio.
The natural mother of the children is Christina G, Hudson.
She is divorced and single,
The natural father of the children is William L. Hudson,
He is married.
4, The relationship of the Plaintiff to the children is that of natural mother.
The Plaintiff currently resides with the children.
5. The relationship of the Defendant to children is that of natural father.
6. Plaintiff has not participated as a party or witness, or in any other
capacity in other litigation, concerning the custody of the children in this or in any other
Court.
Plaintiff has no information of a custody proceeding concerning the
children pending in a court of this Commonwealth,
Plaintiff does not know of a person not a party to the proceedings who
has physical custody of the children or claims to have custody or visitation rights with
respect to the children.
7. The best interest and permanent welfare of the children will be served
by granting the relief requested because:
(a) The mother has been the primary caretaker of the children since their
birth and is capable of providing the care the children need. The daughter is
manipulating the situation of her parent's .divorce so as to avoid dealing with her school
.
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studies and discipline matters in her Mother's home,
(b) The mother needs to have a Court Order as Father has taken custody
of Mary Clare without discussing the situation and circumstances with the Mother.
(C) In the parties divorce the Father acknowledged that the children had
been in the primary care of the Mother and that the Pennsylvania Courts had
jurisdiction over the custody of the children.
8, Each parent whose parental rights to the children have not been
terminated and the person who has physical custody of the children have been named
as parties to this action. All other persons, named below, who are known to have or
claim a right to custody or visitation of the children will be given notice of the pendency
of this action and the right to intervene.
NAME
None
ADDRESS
BASIS OF CLAIM
WHEREFORE, Plaintiff requests your Honorable Court to:
A) grant custody of the children to the plaintiff;
B) set an emergency hearing in order to set the parties rights until
such time as there can be a full hearing in this matter;
C) grant such other relief as is just and in the best interest of the
children.
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,
Respectfully submitted,
Date: 2} z.e..-l n
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Robert L. O'Brien, Esquire
O'BRIEN, BARIC & SCHERER
17 West South Street
Carlisle, PA 17013
(717) 249-6873
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I verify that the statements made in the foregoing Complaint for
Custody 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.
DATE:
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JUSTICES' CHAMBERS
RICHMOND COUNTY SUPREME COURT
HOMEPORT COURT FACILITY
355 FRONT STREET
STATEN ISLAND, NY 10304
March 1, 2000
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PATRICIA M, DiMANGO
ACTING JUSTICE
The Honorable Kevin Hess
Court of Common Pleas of Cumberland County
1 Courthouse Square
Carlisle, P A 17013
Re: William L. Hudson v. Christina R. Hudson
Index # 8064/2000
",-,,:
Dear Judge Hess:
Enclosed please find a copy of an order I issued following our t~lephone conversation on
February 29, 2000. As you can see, I stayed the pioceedirigs before me and directed the plaintiff-
father to comply with your order. I, additionally, advised his attorney that Mr. Hudson should
voluntarily return the minor child to your jurisdiction immediately in order to avoid the
inevitable intervention oflaw enforcement officials to effectuate her return,
Thank you for taking the time to assist me in making this determination. Unfortunately, as often
is the case with ex parte applications, the recounting of events relayed to me was inconsistent
with what actually transpired. Hopefully, this new order will facilitate the expeditious resolution
of this matter. IfI can be of further assistance, I can be reached in chambers at (718) 876-8250.
Very truly yours,
~ln.)~
Patricia M. Di Mango, lS,C. ,
Enclosure
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND
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WILLIAM L. HUDSON
IAS PART 11
Index # 8064/2000
Plaintiff,
-against.
SHORTFORM
ORDER
CHRISTINA R. HUDSON
Defendant.
Present:
Hon. Patricia M. Di Mango
---------------
IT IS HEREBY ORDERED, that the Order issued by this court on February 25,2000
staying the proceedings commenced by the defendant, herein, in the Court of Common Pleas of
Cumberland County, Pennsylvania and any Orders issued therefrom concerning the custody of
the minor child ofthe parties, Mary Clare Hudson, is hereby rescinded. Accordingly, any and
all orders previously issued by the Pennsylvania Court shall remain in full force and effect. The
plaintiff, herein, is directed to comply, with any and all such Orders.
The evidence presented in this application reveals that the defendant's action for custody
in Cumberland County preceded the action brought by the plaintiff herein, In addition, inquiry
by this court of the court in Pennsylvania reveals that a proper jurisdictional basis for a
determination of this issue lies with the Cumberland County Court and that Cumberland County
is, at this time, the more appropriate forum for the resolution of this issue. Accordingly, pursuant
to the Domestic Relations Law g75-g the action pending before this court shall be stayed pending
a final determination on the issue of custody by the Pennsylvania court.
The plaintiff is directed to serve, forthwith, a certified copy of this order on the defendant,
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and to file, forthwith, a certified copy of this order with the Clerk of the Court of Cumberland
" County where the custody action is pending.
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ENTER,
-Irvrr
rTRlCIA M. Di MANGO
],S.c.
Dated: February 29, 2000
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND
--------------------------------------------------------------------
IAS PART 11
Index # 8064/2000
WILLIAM L. HUDSON
Plaintiff,
~006- 97<j CtOl{ '-z~
SHORT FORM
ORDER
-against-
CHRISTINA R. HUDSON
Defendant.
Present:
Hon. Patricia M. Di Mango
-------------------------------------------------------------------
IT IS HEREBY ORDERED, that the Order issued by this court on February 25, 2000
staying the proceedings commenced by the defendant, herein, in th>: Court of Common Rleas of
Cumberland County, Pennsylvania and any Orders issued therefrom concerning the custody of
the minor child of the parties, Mary ClareHudson, is hereby rescinded: Accordingly, any and
all orders previously issued by the Pennsylvania Court shall remain in full force and effect. The
plainliff,_herein, is directed to comply, with any and all such Orders.
The evidence presented in this application reveals that the defendant's action for custody
in Cumberland County preceded the action brought by the plaintiff herein. In addition, inquiry
by this court of the court in Pennsylvania reveals that a proper jurisdictional basis for a
determination ofthis issue lies with the Cumberland County Court and that Cumberland County
is, at this time, the more appropriate forum for the resolution of this issue, Accordingly, pursuant
to the Domestic Relations Law ~75-g the action pending before this court shall be stayed pending
a final determination on the issue of custody by the Pennsylvania court.
The plaintiff is directed to serve, forthwith, a certified copy of this order on the defendant,
'~
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and to file, forthwith, a certified copy of this order with the Clerk of the Court of Cumberland
County where the ,custody action is pending.
GRANTED
ENTER,
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Dated: February 29, 2000
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pet far special relief
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March 9, 2000
,
CHRISTINA G. HUDSON,
Plaintiff/Respondent
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000-979-CIVIL TERM
WILLIAM L. HUDSON,
. Defendant/Petitioner
IN CUSTODY
ORDER OF COURT
NOW, this
day of
, 2000, upon
consideration of the within Petition for Special Relief, a Rule is issued upon the Respondent to
show cause why the relief requested should not be granted.
RULE returnable at a hearing set for the
day of
,2000,
in Court Room NO.4 of the Court House at Carlisle, Pennsylvania at
o'clock . m.
By the Court,
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hudson
pel for special relief
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March 9, 2000
CHRISTINA G. HUDSON,
Plaintiff/Respondent
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000.979-CIVIL TERM
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WILLIAM L. HUDSON,
Defendant/Petitioner
IN CUSTODY
PETITION FOR SPECIAL RELIEF
NOW COME WILLIAM L. HUDSON, Defendant above, Flower, Flower and Lindsay, and
petitions this Honorable Court as follows:
~.
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1, The parties hereto are parents of two children: Mary Clare Hudson, age 12 years;
and Charles Hudson, age 11 years.
,
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2. Petitioner is a Presbyterian Minister with a church on Staten Island, New York.
3. Respondent filed a Complaint for Custody and a Petition for Special Relief on
February 22, 2000. Prior to the filing, there had been no Custody Order.
4. In response to the Petition for Special Relief, this Honorable Court set a hearing two
days hence on February 24,2000 at 10:00 a.m.
5, Petitioner was advised by Respondent's counsel on February 23, 2000 that a
hearing was scheduled for the following day, but Petitioner was not served with the Order of
Court setting the hearing until the afternoon of February 24, 2000.
6. Although Petitioner contacted chambers advising that he could not obtain counsel in
time to appear the following day, the Court held a hearing on the issue of jurisdiction, and found,
furthermore, that the "child had been wrongfully removed from the Commonwealth of
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pel for special relief
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March 9, 2000
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Pennsylvania". The Court's Order of February 24, 2000 also called for a physical and legal
custody of Mary Clare Hudson to be awarded to the Respondent, subject to the rights of partial
custody in Petitioner herein as the parties could agree. Upon receipt of the Court Order and
clarification 'on the issue of jurisdiction, Petitioner, through his counsel, arranged for the return of
the child. A copy of the March 1, 2000 letter conforming the date and time of the transfer is
attached hereto as Exhibit "A".
7. At the time arrangements were made for the transfer, Petitioner's counsel sought
from Respondent's counsel a stipulation that the parties would share legal custody of the children
pending a hearing, and that Petitioner would have rights of partial custody on alternating
weekends and unimpeded telephone access.
8. The request for legal custody and partial custody were not a condition of the return of
the child and counsel for Respondent advised that within a day or two he would provide a
response to the request.
9. On March 6, 2000, counsel for Petitioner again requested a stipulation to set an
interim Order. A copy of the request is attached hereto as Exhibit "B". No response to this
request has been received to date.
1 O. Petitioner acknowledges that this Honorable Court has jurisdiction of this case,
Although he was not properly served before the hearing, Petitioner does not seek to challenge
jurisdiction.
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pel for special relief
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March 9, 2000
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11. Petitioner avers that he did not wrongfully remove the child from the Commonwealth
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of Pennsylvania, but rather removed her in response to Respondent's request, and in light of
allegations of parental misconduct provided to him by the child, Mary Clare.
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12. Petitioner continues concern for the well-being of his child in light of her return to the
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Respondent's primary physical custody.
13. Petitioner seeks a schedule of alternating weekend custody pending the hearing in
14. Petitioner seeks unimpeded telephone contact with the child so that he can monitor
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,this case and legal custody so that he may obtain the child's medical, psychological and school
records in preparation for the hearing.
her wellbeing while being in Respondent's primary custody.
WHEREFORE, Petitioner prays this Honorable Court to issue a Rule upon Respondent to
show cause why he should not be provided legal custody, alternating weekends of physical
custody, and unimpeded telephone contact with the child pending a hearing in this matter.
FLOWER, FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
By:
MAR-09-00 09:53 AM
'.-
P~01
FROM 1 Fl..OWEIt FLOWFI a. L!NllSl'I'r
1/ hlJ(I.~ 1'" for e~i.1 relief
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~b March 9. 20M
Mar. 09 ~e (l9:41w' ~
WBiElCA~
I, the undertl'gned. hereby verify thil! the statements mede herein are true and eOITed.
understand thol raise lltal~nts herein ere made llubJscllo the penalt~s of 18 Pa. C.S, i 4904,
relating to unsworn ftll_iflCation to authorities.
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hudsan
pet far special relief
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March 9, 2000
CHRISTINA G. HUDSON,
Plaintiff/Respondent
, '--'::,~;~' ~,O"
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000-979-CIVIL TERM
vs.
WILLIAM L HUDSON,
Defendant/Petitioner
IN CUSTODY
AND now, this
If)
day of
RVICE
, 2000, I, Carol J,
Lindsay, Esquire, of the law firm of FLOWER, FLOWER & LINDSAY, P.C., Attorneys, hereby certify
that I served the within Petition for Special Relief this day by depositing same in the United States
Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to:
Robert L. O'Brien, Esquire
O'Brien, Baric & Scherer
17 West South Street
Carlisle, PA 17013
FLOWER, FLOWER & LINDSAY
Attorneys for Defendant/Petitioner
By:
Carol J. L ndsay, Esquire
ID # 44693
11 East H ig h Street
Carlisle, PA 17013
(717) 243-5513
-
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1"llllilllliilni'Illi'I,;
LAW OFPlCES
FLOWER. FLOWER .& LINDSAY
A PROFESSIONAL CORPORATION
11 EAST HIGH STREET
CARliSLE, PENNSYLVANIA 17013-3016
JAMES D, FLOWER
JAMESD. FLOWER,JR.
CAROLJ. UNDSAY
mQMAS E. FLOWER
(717) 243-5513
FAX, (717) 243-6510
FFLEsq@aol.com
March 1, 2000
Robert L. O'Brien, Esquire
O'Brien, Baric & Scherer
17 West South Street
Carlisle, PA 17013
via FAX ONLY: 249-5755
Re: Hudson v. Hudson
Dear Rob:
Reverend Hudson will exchange custody of Mary Clare tonight at 1-78, Exit 13, at
7:30 p.m.
I appreciate your willingness to get back to me within the next couple of days
regarding partial custody and telephone contacts stipulation pending the conciliation
conference.
Very truly yours,
FLOWER, FLOWER & LINDSAY, P,C.
Carol J. Lindsay
CJUtjb
cc: William L. Hudson
EXHIBIT
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LAW OFFICES
FLOWER, FLOWER & LINDSA.Y
A PROFESSIONAL CORPORATION
11 EAST HIGH STREET
CARliSLE, PENNSYLVANIA 17013-3016
JAMES D. FLOWER
JAMES D. FLOWER,JR.
CAROLJ. UNDSAY
THOMAS E. FLOWER
(717) 243,5513
FAX: (717)243-6510
FFLEsq@aoI.com
March 6, 2000
Robert L. O'Brien, Esquire
O'Brien, Baric & Scherer
17 West South Street
Carlisle, PA 17013
Re: Hudson v. Hudson
Dear Rob:
Has your client agreed that my client may share legal custody so that we can
prepare for the upcoming hearing, that he may have alternating weekends commencing
this coming Friday, and that he may have unimpaired telephone contact with his children?
Thank you for getting back to me on these points.
Very truly yours,
FLOWER, FLOWER & LINDSAY, P.C.
fiLE COpy
Carol J. Lindsay
CJUljb
cc: Rev. William L. Hudson
EXHIBIT
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hudson
pelfor special relief
tjb
March 9, 2000
CHRISTINA G. HUDSON,
Plaintiff/Respondent
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000-979-CIVIL TERM
WILLIAM L. HUDSON,
, Defendant/Petitioner
IN CUSTODY
ORDER OF COURT
NOW, this
day of
, 2000, upon
consideration of the within Petition for Special Relief, a Rule is issued upon the Respondent to
show cause why the relief requested should not be granted.
RULE returnable at a hearing set for the
day of
,2000,
in Court Room NO.4 of the Court House at Carlisle, Pennsylvania at
o'clock . m.
By the Court,
J.
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hudson
pet for special relief
ijb
March 9, 2000
CHRISTINA G. HUDSON,
Plaintiff/Respondent
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000-979-CIVIL TERM
IN CUSTODY
WILLIAM L. HUDSON,
, Defendant/Petitioner
ORDER OF COURT
NOW, this
day of
, 2000, upon
consideration of the within Petition for Special Relief, a Rule is issued upon the Respondent to
show cause why the relief requested should not be granted.
RULE returnable at a hearing set for the
day of
,2000,
in Court Room No.4 of the Court House at Carlisle, Pennsylvania at
o'clock . m.
By the Court,
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CHRISTINA G. HUDSON,
Plaintiff
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IN TIffi COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
WILLIAM 1. HUDSON,
Defendant
NO. 00-979 CML
IN CUSTODY
COURT ORDER
AND NOW, this I r- day of April, 2000, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
1. This Court's prior Order of February 24,2000 is vacated.
2. The Mother, Christina G. Hudson, and the Father, William 1. Hudson shall enjoy
shared legal custody of Mary Clare Hudson, born May 7, 1987 and Charles William
Hudson, born July 29, 1988.
3. The Mother shall enjoy primary physical custody of both minor children until June
15, 2000. At that time, primary physical custody of Mary Clare Hudson shall be
delivered to Father after which the parties will then have custody with the Father
maintaining primary custody of Mary Clare Hudson and Mother maintaining
primary custody of Charles William Hudson.
4. Once the custody situation is implemented and effective on June 15, 2000, the
parties will alternate custody of the minor children over the weekends so the children
are together on the weekends. The schedule.' will be Friday at 6:00 p.m. until
Sunday at 3:30 p.m. or 4:00 p.m., depending upon Charles' track schedule. The
parties reserve the right between themselves to reach an agreement to modifY this
schedule such that they could take a weekend off on occasion and no parent or child
will be traveling. Unless otherwise agreed to between the parties, the point of
exchange for custody shall be at exit 13 on Interstate 78.
5. Each party shall be entitled to have two (2) weeks of summer vacation with both
children. The parties should endeavor to advise the other party as soon as possible
when they anticipate to exercise summer vacation.
6. When the children are both off school on a Monday, the alternating weekend
custody with that parents shall continue through Monday as long as there is no
interference with social or other activities for the children that the parents are unable
to agree upon.
7. The parties shall alternate the Thanksgiving weekend from Wednesday after school
through that Sunday evening with Father having Thanksgiving in 2000.
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The Christmas holiday shall be alternated between two timeframes, the fIrst being
from the day after the children are released from school until Christmas Day at 3 :00
p.m. and the second timeframe being from Christmas Day at 3:00 p.m. until 3:30 the
day before the children return to school. The Mother shall have the first portion of
Christmas in 2000 with the parties alternating thereafter.
9. Other m~or holidays such as Labor Day, July 4th and Memorial Day shall
correspond with the weekends of custody.
8.
10. Both parents shall enjoy opportunities to communicate with the children when they
are in the custody of the other parent, this communication to include reasonable
telephone contact and e-mail contact.
11. Neither parent shall make disparaging remarks concerning the other parent to any of
the children.
12. This order is entered pursuant to an agreement reached by the parties at a Custody
Conciliation Conference. The parties may modify this order if they both agree.
Absent an agreement, this order shall control. In the event either party desires to
modify this order, that party may petition the court to have the case again scheduled
with the Custody Conciliator for a Conference.
BY THE COURT,
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cc: Robert 1. O'Brien, Esquire
Carol 1. Lindsay, Esquire
CHRISTINA G. HUDSON,
Plaintiff
v
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
WILLIAM 1. HUDSON,
Defendant
NO. 00-979 CIVIL
IN CUSTODY
Prior Judge: Kevin A. Hess
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the following report:
I. The pertinent information pertaining to the children who are the subject of this litigation is
as follows:
Mary Clare Hudson, born May 7,1987 and Charles William Hudson, born July 29,1988.
2. A Conciliation Conference was held on April 4, 2000, with the following individuals in
,
attendance: '
The Mother, Christina G. Hudson, with her counsel, Robert 1. O'Brien, Esquire; and the
Father, William 1. Hudson, with his counsel, Carol 1. Lindsay, Esquire.
3. The parties agree to the entry of an order in the form as attached.
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CHRISTINA G. HUDSON
Plaintiff
Vs.
WILLIAM L. HUDSON
Defendant
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 2000-979 CIVIL TERM
: IN CUSTODY
ORDER
AND NOW THIS L ~ day of ty. ",'J , 2001, the attached agreement
is hereby made an Order of Court.
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CHRISTINA G. HUDSON
Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000-979 CIVIL TERM
WILLIAM L. HUDSON
Defendant
IN CUSTODY
CUSTODY AGREEMENT
The parties hereto, Christina G. Hudson and William L. Hudson, are the parents
of Mary Clare Hudson, born May 7,1987 and Charles William Hudson, born July 29,
1988. The parties agree that they will share legal custody of the children and that they
will apprise one another of all significant matters pertaining to the children. The Mother
shall also have primary physical custody of the children, subject to visitation or partial
custody with the Father as the parties may agree from time to time.
The parties agree that they 'will not disparage or speak unkindly of one another in
the children's presence and will make it their goal to cultivate the children's love and
respect for each parent.
The Father acknowledges that he is aware that the Mother may accept a job in
Europe and relocate the children for the summer of 2001 thru 2002. He agrees that
this is an important opportunity for the children and he supports that relocation. The
parties agree that they will work together to arrange appropriate travel arrangements for
the children to spend time with Father, which may include Father and his Wife coming
to Europe to stay with Mother and the children.
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The parties agree that this Custody Agreement shall be entered as an Order of
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Court and that the prior custody Order shall be of no effect.
In witness whereof, the undersigned parties have executed this Agreement this
.3 day of /III..ar~, 2001.
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CHRIS INA G. HUDSON
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