HomeMy WebLinkAbout00-02414
,.... "~~
_u
~ ..
[Um\
LISA CHRISTOPHER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYJLV ANIA
V.
CIVIL ACTION - LAW
J1J-o-v" ~4.r 4- ~
REBEKAH S. CHRISTOPHER,: NO.
JOHN CHRISTOPHER, III,
Defendants
: IN CUSTODY
ORDER OF COURT
ofL I/. ' I
AND NOW, this /1 day of ' ~' ,2000, upon
consideration ofthe attached Custody Complaint, it IS hereby direyted that the parties and
their respective counsel shall appear before I'IrJAl S. )v..d, ~ , the
Conciliator, at 3q IV JV!Au) >1" " c 5 {JA.<.A on the 13th
day of Jl.I!U... ,2000 at 3'.OD o'clockp. m., for a re-Hearing Custody
Conference. At such conference, an effort will be made to resolve the issues in dispute;
or if this cannot be accomplished, to define and narrow the issues to be heard by the
Court, and to enter into a Temporary Order. All children age five or older may also be
present at the Conference. Failure to appear at the Conference may provide grounds for
entry of a temporary or permanent order.
FOR ~ COURT,
BY: Y__J >. <2 ~- ~
Custody Conciliat~? ' {~
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 mU&t be made at least 72 hours
prior to any hearing or business before the court. You must attend the scheduled
conference or hearing,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, P A 17013
(717) 249-3166
,~^" "~ ~ --~
- "'~
,-"_,,,_ .-~ ~, ,-..-. .1
."""-
'_, 8.;'
, "-,,~
,,',:;"~ ,"", ">;'~''''"'~-'I~C1''I'i'i''~ .,,"',~ "'-1"1"'11>11" iii"" -",ru. i'"":"'{;(""~" -
';;.!,',""c,'---, ",~_"i;,-':',)'''-,'\'..tc~.;c~I__'-' ;. ,.~ .~.... II ._1.__ _
OF
:1
---'J,-'
.EJ'-CrT!~=:r:
'~'~i!'!~~Tl\H,{
~o -~"'"f'1; ,.., "'I
" r"'" "
L.' ';i 1\ (,(,..
p :.~; ""',": ? ~~
. .. ,~ '._v
C1 j'-~l-"": -' - ',' - ("_,--'" _->-/
IUJViL'":,'''r 'L'~',"! : , !U'i !'\~ J \,
'-- , " "'~-' '.~ wi.!
PEf\lNSYL\0'\i\lI/\
tf'Jo,C}:J &d. e~ ~ ~ if ~
JI--dC),C):;) 7!~ ~ ~ ~
4t-.;lZ) 'CJtJ ~ ~ ~ a1 ~~ ~
.......,"'...' .
,"".....
__?_~,..lf]~
"''''t'>>'-'''.
I ,-L,~1\Om~_!llhR'~f"'J'Jf'IID'ilW1lJ~~4f\1~m~!f!'il'lI!'l.'IIIl!
1" )1 Q,'____, ~~?;
.-
~o~~w"'"
]t"
LISA CHRISTOPHER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYLV ANIA
V.
REBEKAH S. CHRISTOPHER,
JOHN CHRISTOPHER, III,
Defendants
: CIVIL ACTION - LAW
: NO. 01;- ~ 'IN ~ I~
: IN CUSTODY
COMPLAINT FOR CUSTODY
AND NOW, comes the Plaintiff, Lisa Christopher, by and through her attorney,
Jacqueline M. Verney, Esquire and represents the following:
1. Plaintiff is Lisa Christopher, who resides at 430 S. Pitt Street, Carlisle,
Cumberland County, Pennsylvania, 17013. Plaintiff has standing to bring this complaint
based on 23 Pa.C.S.A. S 5313 (b) (1), (2), and (3). Plaintiff has acted in loco parentis of
the child for more than one year.
2. Defendants are Rebekah S. Christopher, natural mother, who resides at
2044 Green Street, Harrisburg, Dauphin County, Pennsylvania, 17..0 and John
Christopher, III, natural father, whose address is 3649 A. Derry Street, Harrisburg,
Dauphin County, Peunsylvania, 17111.
3. Plaintiff seeks custody of the following child:
NAME
PRESENT ADDRESS
AGE
Alleshia Christopher
430 S. Pitt St.
Carlisle, P A 17013
DOB 2/12/92
Age 8
The child was born out of wedlock.
The child is presently in the custody of Lisa Christopher, who resides at 430 S,
Pitt Street, Carlisle, Cumberland County, Pennsylvania.
-
". ~
~"" i1L"-'"
During the past five years, the child has resided with the following persons and at
the following addresses:
LIST ALL PERSONS
Lisa Christopher,
Jameson Christopher
John Christopher, III, Rebekah
Christopher, Alexandria
Christopher, Adrienne Christopher,
and John Christopher, IV
Same as above
Same as above
John Christopher, III, Rebekah
Christopher, Alexandria
Christopher
ADDRESSES
430 S. Pitt St
Carlisle, P A 17013
Ronca St.
Carlisle, PA 17013
Allen Drive
Carlisle, PA 17013
North Carolina
West & K. Streets
Carlisle, PA 17013
DATES
March 1999-
Present
1998-3/1999
1998-1997
1997
1997-1995
The mother of the child is Rebekah Christopher, currently residing at 2044 Green
St, Harrisburg, Pennsylvania.
She is divorced.
The father of the child is John Christopher, III, currently residing at 3649 A.
Derry St, Harrisburg, Pennsylvania.
He is divorced
4. The relationship of Plaintiff to the child is grandmother. The Plaintiff
currently resides with:
NAME
Jameson Christopher
Alleshia Christopher
RELATIONSHIP
son
granddaughter
- ~~
".~
, ~Ik~-:
5. The relationship of the defendant, Rebekah Christopher, to the child is
mother. The defendant, Rebekah Christopher, currently resides with:
NAME
RELATIONSHIP
Alexandria Christopher
AdrielU1e Christopher
John Christopher, IV
daughter
daughter
son
The relationship of defendant, John Christopher, III to the child is Father. The
Defendant, John Christopher, III, currently resides with:
NAME
RELATIONSHIP
Jennifer Zulli
JayolU1a Pope
girlfriend
girlfriend's daughter
6. Plaintiff has not participated as a party or witness, or in another capacity, in
other litigation concerning the custody ofthis rninor child in this or another court.
Plaintiff has information of a custody proceeding concerning the child in the
Court of Common Pleas of Cumberland County, PelU1sylvania at No. 99-2084. A copy
of the Stipulation For Custody, dated May 19, 1999, is attached hereto as Exhibit "A".
Plaintiff does not know of a person not a party to the proceedings who has
physical custody of the child or claims to have custody or visitation rights with respect to
the child.
7. The best interest and permanent welfare of the child will be served by
granting the relief requested because:
a. The plaintiff has been the primary caregiver ofthe child since March, 1999.
_.~.~-
~ "
,~~
- ~~~. ~--" ~, '"
, ~3,
b. The plaintiff has acted in loco parentis of the child since March, 1999.
c. The child has attended Carlisle school since living in the home of Plaintiff and
to remove her now would be detrimental.
d. Plaintiff has genuine care and concern for the child.
e. Both parents consented to the plaintiff having care and custody of the child
since March, 1999.
f. Mother has visited with the child only four times in one year.
g. Plaintiff can provide a loving, nurturing, safe, environment and home for the
child.
8. Each parent whose parental rights to the child have not been terminated and
the persons who have physical custody of the child have been named as parties to this
action.
WHEREFORE, plaintiff, paternal grandmother of the child requests the court to
grant legal and primary physical custody ofthe child to plaintiff.
Date: if-I 1./ -0 0
Respectfully submitted,
~e~:~
44 South Hanover Street
Carlisle, P A 17013
Supreme Ct. ID 23167
Attorney for Plaintiff
VERIFICATION
I verify that the statements made in this Complaint are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904 relating to unsworn falsification to authorities.
Dated:
4 -( L( -(j()
-
-,.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTYPENN&YL~
. c
. ~ ~ ~
: NO. 99- 2084 CIVIL ~ ~ i,~Fn
: ~~ 'D 3~
: IN CUSTODY ~t.:I -0 j~";
~O :x g~
~g ~ S?
, STIPULATION FOR CUSTODY ~ r;; ~
STIPULATION made this /9':i. day of May, 1999, between Rebekah S. Christopher,
hereinafter referred to as Mothe , and John Christopher, III, hereinafter referred to as Father.
REBEKAH S. CHRISTOPHER,
Plaintiff
v.
JOHN CHRISTOPHER, ill,
Defendant
WHEREAS, the above-named Mother and Father had born to them the following children on the
following dates:
NAME
Alleshia Christopher
Alexandria Christopher
Adrienne Christopher
John Christopher, IV
BIRTH DATE
February 12, 1992
July 26, 1995
November 25, 1996
November 24, 1997
AND WHEREAS, the above-named Mother and Father desire tdenter into a Stipulation as to
the custody of the above-said children and to the visitation rights of the non-custodiai parent
NOW, THEREFORE, in order to effectuate the above purpose, the above-named Mother and
Father hereby stipulate that:
1. The Mother and Father shall have shared legal custody of the children.
2. The Mother shall have primary physical custody of the children.
3. The Father shall have periods of partial physical custody:
a. The Father shall pick-up the children at daycare each Wednesday at 5:30 p.m.
and retum them to daycare on Friday at 8:30 a.m..
b. The Mother shall deliver the children to the Father's residence at 10:00 a.m. .
every other Saturday, and Father shall retum the childran to de:yoars at 8:30 a.m. the following
.
Monday.
4. Mother and Father will arrange for custody of the children on HolidayS by mutual
agreement.
TO THIS PURPOSE, The parties hereto intenl;! to, be legaIlY/bOU~~~'Y e tjlrms of this
Stipulation and desire to have the Stipulation eIItet'efas1n O,ttler Coort. .--l
, / I I. If t i "j,
, . ! ,1/ j ,,:/ h I / /1
r;I" ~'/ '/ ,I.' " . l ~
Witness: i r./~ " Ii, i l
Rebeka S. cnri~topher, Mot r
.1, ~: .' ._.....-...-/
. /. ,., / .,'./...;..: --~-- ..,
,..?JLl'A1~~ ." /' .0'
L.if{dsay Dare Baird, Esq. John Clyist er, III, Fat
I -'
o
or:: " .4 II
/C.-)(
~-
,
LISA CHRISTOPHER,
PetitionerlPlaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYL VANIA
V.
: CIVIL ACTION - LAW
REBEKAH S. CHRISTOPHER, : NO. 2000- 2414 CIVIL TERM
JOHN CHRISTOPHER, III,
Respondent/Defendant
: IN CUSTODY
ORDER OF COURT
AND NOW, this / ~ ~ of..d~. L , 2000, following consideration of
,
Petitioner's Emergency Petition, it is hereby ordered that a hearing is scheduled for the
~'I~ day of L!y1L/ '- ,2000, at": DO A . m. in Courtroom No.
S of the Cumberland County Courthouse, fourth floor, Carlisle, Pennsylvania.
J.
GI4HI44I $. t: 14" tltJ~ .;;:
~'~-:.<)"""~~,,I
,
<- - ._~
"'0
!D',-~ ".,.lU.....~
~, ,~
, ,'~ n
.J_~:J!I_
,~
. - '-'~
,
~" , -<f
~" -~
--~- -'"'~~=
. ..-~~< = -" '- -,'"
I ",!:~~:r:i,..RY
nrJ fn:~ 1 ')
.- l... " i ,', I t.~
, n I
,1-):1 U; I.' I
'.
C' 11,<,:". , .' ",
U,vlUl ",1 "I"',' ,,',I 'Nrrv. .
.. '~J \ ,'- u'}l 'j i/ r
PEiI!NSYL\I/V~iK
p..w.~ ~ !n:, ~'J~~
~ N.u~ -\0 Reb~~ <rd j.,h~
CJ.\~'L-;'~
."
]. - ~ ~~..,
_ _J.).,JI,\I~~~~'~'!!j(~~i!ll~~~ ._,. ~'~"', ",~
-
,
,-: - " ,~" -.~-I
LISA CHRISTOPHER,
Petitioner/Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLV ANIA
V.
CIVIL ACTION - LAW
REBEKAH S. CHRISTOPHER, : NO. 2000- d. '11'1 CIVIL
JOHN CHRISTOPHER, III,
Respondent/Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this ~ of APL4' L , 2000, following consideration of
.
the Emergency Petition and pending the conciliation conference, it is hereby ordered as
follows:
I. The parties, Lisa Christopher, Rebekah Christopher and John Christopher, III, shall
have shared legal custody of Alleshia Christopher, DOB 2/12/92.
2. Petitioner, Lisa Christopher, shall have primary physical custody ofthe child. John
Christopher, III is ordered to return the child to Petitioner immediately.
3. Respondents shall have periods of partial physical custody of the child on alternating
weekends if requested.
4. Transportation shall be provided by the Respondents.
BY THE COURT:
J.
. "
II
~,
LISA CHRISTOPHER,
Petitioner/Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLV ANIA
V.
CIVIL ACTION - LAW
REBEKAH S. CHRISTOPHER, : NO. 2000- .2'11Y
JOHN CHRISTOPHER, III,
RespondentJDefendant
CIVIL
: IN CUSTODY
EMERGENCY PETITION FOR SPECIAL RELIEF PURSUANT TO RULE
1915.13
AND NOW, comes the petitioner, Lisa Christopher, by and through her attorney,
Jacqueline M. Verney, Esquire, and represents the following in support of her Emergency
Petition for Special Relief Pursuant to Rule 1915.13:
I. The Petitioner is Lisa Christopher, who resides at 430 S. Pitt Street,
Carlisle, Cumberland County, Pennsylvania.
2. Petitioner has standing to bring this Petition based on 23 Pa.C.S.A. S 5313
(b) (I), (2), and (3).
3. The Respondents are Rebekah S. Christopher, who resides at 2044 Green
Street, Harrisburg, Dauphin County, Pennsylvania and John Christopher, III, who resides
at 3649 A. Derry Street, Harrisburg, Dauphin County, Pennsylvania.
4. The Respondents are the natural parents of Alleshia Christopher, DOB
2/12/92.
5. Petitioner is the grandmother of Alleshia Christopher, the subject of this
Emergency Petition, who has had physical custody of the child and has acted in loco
parentis of the child since March, 1999.
"
"""
~ ~
~~~H
~
6. On April 9, 2000, Respondent, John Christopher, III, removed the child
from Petitioner and has refused to return the child to Petitioner.
7. The child attends school in the Carlisle School District. Father failed to
take the child to school on Monday, April I 0, 2000, but has transported the child to
school the remainder ofthe days.
8. The removal of the child from the home of the Petitioner has disrupted the
child's education and caused an emotional trauma to the child. Petitioner has been the
sole contact with the child's school since March, 1999.
9. The child has lived with Petitioner since the Respondents separated in
March, 1999. The Respondents, however, executed a Custody Stipulation providing for
Rebekah Christopher to have primary physical custody of the child. Said Custody
Stipulation is attached hereto as Exhibit "A".
10. Respondent Rebekah Christopher has not had physical custody of the child
since March, 1999 and has only visited with the child approximately four times in the
past year.
II. Neither parent has shown an interest in the physical, emotional, religious,
medical or educational needs of the child since March, 1999.
12. Petitioner has filed, contemporaneous with this Emergency Petition, a
Complaint For Custody. A custody conciliation conference has not been scheduled
pursuant to the Custody Complaint and may not be scheduled for approximately four
weeks.
~
<-~
9',"
13. Petitioner believes it is critical to the physical, emotional, and educational
well-being of the child that the child be returned to Petitioner pending the resolution of
the Custody Complaint.
14. Petitioner has provided a loving, nurturing, stable, safe environment and
home for the child for the past year.
15. The child has friends and relatives in Carlisle and removing her from the
home of Petitioner has adversely affected her emotional well-being.
16. It is in the best interests of the child to remain with Petitioner pending the
conciliation conference.
17. It is unknown whether Respondents are represented by counsel. A draft of
this Petition has been sent to the parties prior to filing.
Wherefore, Petitioner requests this Honorable Court enter an order granting
shared legal custody to the parties and primary physical custody of the child to Petitioner
with periods of partial physical custody as requested by Respondents on alternating
weekends.
Respectfully submitted,
i.f -I <{ -() d
Ih,
c eline M. Verney, Esquire # 2 67
44 S. Hanover Street
Carlisle, PA 17013
(717) 243-9190
Attorney for Petitioner
.--. -
-- ." "a::r.~~i'i
'.
VERIFICATION
I verify that the statements made in this Emergency Petition are true and correct.
I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904 relating to unsworn falsification to authorities.
Dated: /1 -{ If -(f1)
~a/ 4/.. !~il5ky;h /J
LI A CHRIST PHER
-
,-- ,
~ -- -
'.
REBEKAH S. CHRISTOPHER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY PENN~YLW.~
: z ~ .~
: NO. 99-2084 CIVIL T~ ~ ?~~~
&5 5:. \..0 .~3 L
,,<:.;:.,"",9
c: Ci -0 :I::, ~
~ '",J"
:2: 0- :::r: '::..~ C)
6:0 _..'\ brn
)>r-. ..... ._1
Z .,- ~
=< W -<
STIPULATION made this /<1:; day of May, 1999, between Rebekah S. Christopher,
hereinafter referred to as Mothe , and John Christopher, III, hereinafter referred to as Father.
v.
JOHN CHRISTOPHER, III,
Defendant
: IN CUSTODY
STIPULATION FOR CUSTODY
WHEREAS, the above-named Mother and Father had born to them the following children on the
following dates:
NAME
Alleshia Christopher
Alexandria Christopher
Adrienne Christopher
John Christopher, IV
BIRTH DATE
February 12, 1992
July 26, 1995
November 25,1996
November 24, 1997
AND WHEREAS, the above-named Mother and Father desire to enter into a Stipulation as to
the custody of the above-said children and to the visitation rights of the non-custodial parent:
NOW, THEREFORE, in order to effectuate the above purpose, the above-named Mother and
Father hereby stipulate that:
1. The Mother and Father shall have shared legal custody of the children.
2. The Mother shall have primary physical custody of the children.
3. The Father shall have periOds of partial physical custody:
a. The Father shall pick-up the children at daycare each Wednesday at 5:30 p.m.
and return them to daycare on Friday at 8:30 a.m..
b. The Mother shall deliver the children to the Father's residence at 10:00 a.m.
Q,\/Q,nl nthp... ~"::Iturd~y '.:3in.... I=,=,'thl=llr" eh~" "-Cl"U"" 'h.o r-hilrlro!'"t f..... d..':'''.....o:-e ~t p..~o ... n"! thn -f.....!I"'V!ir"lrc
-'-'J .....~-._, '-''-'. , ~', ........ . ......_, ....:_,. l,-"t .., ...-..... ,-"".."" ........-..; Co:.............. 0.. ""...... 0..... ...1... ,V.,... ~...~
Monday.
4. Mother and Father will arrange for custody of the children on Holidays by mutual
agreement.
...
TO THIS PURPOSE, The parties hereto in, tend t~. be. legallY, !bOUP~Y.- ~ e t, erms of this
Stipulation and desire to have the Stipulation ~rltete~fas ~n Offjer ff Co,~rt. .~.
. h' I /'!~ /; ., .' /' "
, ! t,l ,I! ,0/ /"., / ,/')
) , ! 1/ j f/'. 1"1 ct'/;'.
I 'J :. "( aL' '_ ' - ':
Witness: i /t;vtlJ1/ I>v 4 iI.YJ I j ~
Rebekah'S( christopher, Mot~r
/1 i ;:.>
/ L i '~4'"
',/iVl ~~
John Christ her, III, Fato.er-';'
/ _/ --:
. /-..,-'~ /]
/;?),t[/Mt:.~~
\.if1dsay Dare Baird, Esq.
'.~'~.:.~/7
!/i-x "4: Ii
"'-"i
. -...
LISA CHRISTOPHER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
REBEKAH S. CHRISTOPHER,
JOHN CHRISTOPHER, III,
Defendants
CIVIL TERM - LAW
NO. 2000-2414 CIVIL TERM
IN RE:
CUSTODY
ORDER OF COURT
./
AND NOW, this 24th day of Apri~, 2000, the
Respondents having failed to appear, it being related to
the Court that the child is back in the custody of the
Petitioner, it is ordered and directed as follows:
1. The parties, Lisa Christopher, Rebekah
Christophe~, and John Christopher, III, shall have shared
legal custody of Alleshia Christopher, DOB: 2/12/92.
2. Petitioner, Lisa Christopher, shall have
primary physical custody of the child.
3. Respondents shall have periods of partial
custody as agreed upon between the parties.
This is a temporary order which we will review on
an emergency basis upon petition by any party. This matter
By
~ ~\JY DO
\j( ~,~~~
is to proceed through the conciliation process for the
entry of a permanent order.
Edward E. Guido, J.
,
.,.
,~lI'I
~ -~-
-~-
~" , ,''','''''"'.J"',
, ~ ~-
'I
c-" ,
-J-.i
':; ")
Cf
I"~ ,'\ \ i; ~ ,1 .1
\-\':\
\c~\;'i:\0;j~J \{~j}~i<i,(
~rv,'Iil'IllII~_
........../
IHI_ ~
~~--
, ..~
Jacqueline M. Verney, Esquire
For the Plaintiff
:lfh
-~
<'l!"
~
. .,
LISA CHRISTOPHER, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. . NO. 00-2414 CIVIL TERM
.
:
REBEKAH S. CHRISTOPHER, . CIVIL ACTION - LAW
.
JOHN CHRISTOPHER, III, :
Defendants . IN CUSTODY
.
ORDER OF COURT
AND NCIIJ, this J,,;r day of ~
upon consideration of the attached CustOdy Conciliation
ordered and directed as follows:
, 2000,
Report, it is
1. The prior order of this Court dated April 24, 2000 is vacated and
replaced with this order.
2. The Paternal Grandmother, Lisa Christopher, shall have legal
custody and primary physical custody of Alleshia Christopher, born February
12, 1992.
3. The Mother, Rebekah S. Christopher, and the Father, John
Christopher, III, shall have partial physical custody of the child as
arranged by agreement of the parties.
4. Lisa Christopher shall make a reasonable effort to keep the Father
and Mother informed as to any significant medical, educational and social
developments concerning the Child.
cc:
Jacqueline M. Verney, Esquire - Counsel
John Christopher, III, Father
Rebekah S. Christopher, Mother
for Paternal Grandmother
J. ~~
t~.~1-DO
~(?
Edward E. Guido,
ill
I
,
I
i'-t. ._
I
..
,-~=
~''''''- I=~ ~~
~,'
,~
~~
26 j:\;; ~i: II~
(':Ur' j',"C, , t,,' !\ITV
.....- \"..."._lll_'"'., --_',.JL", I
i}EI~t\:SYLVAr~IA
.
~
~~~llftl.~'"'I7,)c,_",1!!!l
-~~,.~-
.,__.." _'" ,JIIlIIll;
--'-'
..
.' '
'.
. ~
LISA CHRISTOPHER, : IN THE mURT OF OOMMON PLEAS OF
Plaintiff : CUMBERLAND COlJNTY, PENNSYLVANIA
.
.
vs. . NO. 00-2414 CIVIL TERM
.
:
REBEKAH S. CHRISTOPHER, . CIVIL ACTION - LAW
.
JOHN CHRISTOPHER, III, :
Defendants . IN CUSTODY
.
PRIeR JUDGE: Edward E. Guido
CUSTODY CD!lCILIATIOO SUMMARY REPORT
IN Aco::m>ANCE WITH CUMBERLAND COONTY 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:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Alleshia Christopher
February 12, 1992
plaintiff/Paternal
Grandmother
2. A Conciliation Conference was held on June 13, 2000, with the
following individuals in attendance: The plaintiff/Paternal Grandmother,
Lisa Christopher, with her counsel, Jacqueline M. Verney, Esquire. The
Mother, Rebekah S. Christopher, who currently lives in California, did not
attend the Conference or contact the Conciliator. The Father, John
Christopher, III, who currently resides in Carlisle, Pennsylvania, did not
attend the Conference or contact the Conciliator.
3. The Grandmother's counsel indicated that both Defendant parents
were served with notice of the Conciliation Conference. The Paternal
Grandmother advised the Conciliator that she spoke to both the Mother and
the Father prior to the Conference and was advised by both parents that
they did not intend to attend.
4. This Court previously entered a Temporary Order on April 24, 2000
granting the Paternal Grandmother primary physical custody of the Child
with periods of partial physical custody to both parents as agreed upon
between the parties. The Court also ordered that the matter should proceed
through the Conciliation process for the entry of a permanent Order.
5. The Paternal Grandmother stated that the Child has resided with
the Grandmother since March 1999 by agreement of both parents and the
."~-.
..
."
. ~
. ,
Grandmother. The Grandmother indicated that the Mother has visited with
the Child 4 times since March 1999 and the Father, who has custody of the
parent's 3 other children, contacts the Grandmother on a more regular basis
to make arrangements for partial custody.
6. Based upon the representations of the Grandmother at the
Conciliation Conference, the events leading up to the entry of the
Emergency Temporary Order on April 24, 2000, and the fact that neither the
Mother nor the Father attended the Conference or contacted the Conciliator,
the Conciliator recommends an Order in the form as attached.
7. It should be noted that as the Mother has not provided her address
in California and the Paternal Grandmother has not been able to obtain her
address, it will be necessary to forward the Order to the Mother at her
last known address in Harrisburg, pennsylvania.
~ IU/,J..oOr:i
O~~, i!=1
Dawn S. Sunday I Esquire
Custody Conciliator
Date