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HomeMy WebLinkAbout00-02527 ,. , . I , "i i! I: , , I: i. , Ii 5' APR 2 7 2000.:\ : IN THE COURT OF COMMON PLEAS OF &f'l : CUMBERLAND COUNTY, PENNSYLVANIA Jody M, Perkey, Plaintiff v, : CIVIL ACTION - LAW : IN CUSTODY Dean M, Price, Defendant : NO, 00- .;/):l 1 CIVIL TERM MOTION FOR CUSTODY CONCILIATION The plaintiff, by and through her attorneys, the Family Law Clinic, moves the court pursuant to Rule 1915,3-I(b) to schedule a custody conciliation, Date: q ltg/CD i , i Ii ! i , I , , i I , i I i , i , I I I I I I Respectfully submitted, 9(l.~ Stacy arker Certified Legal Intern ~~9- THOMAS M, PLACE ROBERT E, RAINS Supervising Attorney DONALD MARRITZ Staff Attorney F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717/243-2968 i: '-';', J. '~ " Jody M, Perkey, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY Dean 1. Price, Defendant : NO, 00- .;I &.21 CIVIL TERM ORDER OF COURT AND NOW, this2-..J day of ~., 2000, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before, 1~'t:e4x: ' ~\\\o\ ' the conciliator, at'*c. j..\~ :t\e>of , ~[mcl. CM-vh Ca.-vrJ\,w;r-G on thel~ day of ~ ,2000, at 10:30 ~:, for a Pre-Hearing Custody Conference, At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Either party may bring the child who is the subject of this custody action to the conference, but the child's attendance is not mandatory, Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: By: \[, Custody Conciliator ~, ttn~ 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 AMERICANS WITH DISABILITIES ACT OF 1990 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, C,.. nu:n. r.". 1>- n..!r 'Ei~--VrR('!: 'n: I ,"~,'\7"I! oJ.... "'/hr."n " "'j"I.TAAY 00 NAY- .] ,oN '). C. d. 41 U'lO" . " ul:;IiLJj'I' PENNS}'L~IA COUNT', V/'INi,4 i I ~~:J -00 &d- ~ ffi..~ ~ c:5tfX .5''3'0 7(~ /U~ Z~. ,5-3-co ~~~ :i/-'~~ #- ' '- , !!lJ!!!'<!iI!I.I'~-M'fW'!ii1't~f.,.l(;WW!"!"I~""_~",, ~Sinfl1ll!t!I!Il\l~I!?_ "~~~ , ,-' ~--.~ ,-I ,- Jody M, Perkey, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW : IN CUSTODY Dean 1. Price, Defendant : NO, 00- ,;}!{':J 7 CIVIL TERM NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court, If you wish to defend against the claims set forth in the following pages, you must take prompt action. If you fail to appear as provided by this order, an order for custody, partial custody or visitation may be entered against you or the court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD ONE, GOTOOR 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 AMERICANS WITH DISABILITIES ACT OF 1990 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, , .-. ,,' ~;l,i I I , i ,. Jody M, Perkey, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW IN CUSTODY Dean 1. Price, Defendant NO,OO- .l:{,J. 7 CIVIL TERM COMPLAINT FOR CUSTODY The plaintiff, Jody M, Perkey, by her attorneys, the Family Law Clinic, sets forth the following cause of action: 1. The plaintiff is Jody M, Perkey, residing at The Stewart House, 20 E, Pomfret Street, Carlisle, Cumberland County, Pennsylvania 17013, 2, The defendant is Dean J, Price, residing at 4 E, Louther Street Apt. 3, Carlisle, Cumberland County, Pennsylvania 17013, 3, Plaintiff seeks partial custody of the following child: Name Present Residence Date of Birth Annette S, Price 4 E, Louther Street 11126/98 The child was born out of wedlock. The child is presently in the custody of Dean 1. Price, During the past five years, the child has resided with the following persons and at the following addresses: Persons Addresses Dates Dean 1. Price Edward Lauver Francine Lauver 4 E Louther Street Apt. 3 Carlisle, P A 17013 2/14/00 - present - ~ c__ , I '1 ~ Dean J, Price 408 S, Fayette Street Lot # 3 Shippensburg, P A 17257 4/9199 - 2/14/00 Jody M, Perkey 100 B Lincoln Street Carlisle, PA 17013 11/26/98 - 4/9199 4, The relationship of the plaintiff to the child is that of mother. She is single, She currently does not reside with any persons, 5, The relationship of defendant to the child is that of father, He is single, He currently resides with the following persons: Name Relationshin Edward Lauver father Francine Lauver mother Annette S, Price daughter 6, 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, Plaintiff has no information of a custody proceeding concerning the child 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 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) Plaintiff is willing to accept partial custody of the child; b) The re-establishing of the mother-daughter relationship forged during the child's first months would be in the child's best interest; c) Both parents having an active role in the child's development would be in the child's best .Jl , . "I-- ',~~ '" '.. --~i1::\~ ~ interest. 8, Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action, WHEREFORE, plaintiff requests the Court to grant to her partial custody and visitation of the child, Date: if / /8/00 d!o:1ar~r' &k Certified Legal Intern ~~~ THOMAS M, PLACE ROBERT E. RAINS Supervising Attorney DONALD MARRITZ Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17.013 717/243-2968 > ^ ", ~,,' .. 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. g 4904 relating to unsworn falsification to authorities, Date: April ,<( , 2000 J~Lf~ Plaintiff ~~~.~_'__I.""",:""",';";"~I"JiijI.~'&lH~j.#-~' ,y,,~~'"' " "^-,- "'~ - ~,' , 17~';::: n~;!;I, If!,~~ Gi,~::- i€~~) ::; -< (Q :v (...; ~ Co Co .. S:? (~-). t\) &-"'"1 ::.,) " J .. APR 27 , Jody M, Perkey, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW Dean J, Price, Defendant NO, 00- J,o.:l1 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Jody M, Perkey, Plaintiff, to proceed in forma pauperis. I, Stacy A. Barker, Certified Legal Intern in the Family Law Clinic, for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing-free legal service to the party, The party's affidavit showing inability to pay the costs oflitigation is attached hereto. ~~a.~ Stacy A. Barker Certified Legal Intern ~l1r ROB T E. RAINS THOMAS M, PLACE Supervising Attorney DONALD MARRlTZ Staff Attorney THE F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 HM~~JI"'~~I""'""'~ "Iioi.u,.i;~,"",,-,~,,- "Mi~~i!!w.~ .,-" o c: <" rilf~~; ~?:. 1-: <, 2::c' >~~:' ~ >' -, \, . '. C) ~. ') ,I ";".:."'" -,- ::::) J"'J C-.,) -:..) <? h , ""l. \ G. C ,',' ..1 L_." " .,/ " Jody M, Perkey, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW Dean 1. Price, Defendant : NO, 00- .25). ") CIVIL TERM AFFIDAVIT SUPPORTING PRAECIPE FOR LEAVE TO PROCEED IN FORMA PAUPERIS I, I am the plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting or defending the action or proceeding, 2, I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation, 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: Jody M, Perkey Address: The Stewart House, 20 E. Pomfret St., Carlisle, PA 17013 Social Security No,: 433-37-5235 (b) Employment If you are presently employed, state Employer: Address: Salary or wages per month: Type of work: If you are presently unemployed, state Date oflast employment: 10/99 Salary or wages per month: $6 / hour Type of work: labor (c) Other income within the past twelve months Business or profession: $0 Other self-employment: $0 Interest: $0 Dividends: $0 Pension and annuities: $0 Social security benefits: $0 ~-",-.-_'. - ~-,: J i " j I ~ 'I ~ ~ I' ,I I I I I , I I I I i ) , l ! " i I' ~ " , I " I " i I I , I I ! I .'w ,~. "---, - .,/ . , Support payments: $0 Disability payments: $0 Unemployment compensation and supplemental benefits: $0 Workman's compensation: $0 Public Assistance: $0 Other: $0 (d) Other contributions to household support Contributions from children: $0 Contributions from parents: $0 Other contributions: $0 (e) Property owned Cash: $0 Checking account: $0 Savings account: $0 Certificates of deposit: $0 Real estate (including home): $0 Motor Vehicle: none Stocks; bonds: $0 Other: $0 (f) Debts and obligations Mortgage: $0 Rent: $0 Loans: $0 Other: $0 (g) Persons dependent upon you for support Children, if any: Name: Age: Annette Price 16 months 4, I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein, 5, I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C,S, !l4904, relating to unsworn falsification to authorities. Date '-/ II rim , i!t!~ -' - ;;.' , \. ~, Jody M, Perkey, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW : IN CUSTODY Dean J, Price, Defendant : NO, 00-$0>--7 CIVIL TERM VERIFICATION OF SERVICE Understanding that the making of any false statement would subject me to the penalties of 18 Pa, C,S, !j4904 (relating to unsworn falsification to authorities), the undersigned verifies that Stacy Barker mailed a true copy of the Complaint for Custody, In Forma Pauperis Petition, and the Affidavit Supporting the In Forma Pauperis Petition on the Defendant by placing the same in the U.S, Mail, certified no, Z 33~ 7(.,.5' &:. 4--0, restricted delivery, return receipt requested, postage prepaid, on the 24th day of April, 2000 addressed as follows: Dean 1. Price 4 E Louther Street, Apt. 3 Carlisle, P A 17013 Sender's receipt no. Z- '33>'2> {(p'5"' (, If 0 is attached hereto and incorporated by reference, On the ~ day of (tp r i j ,2000, green return receipt no, 7. 32>2 7{,~ (,40 was delivered to the Family Law Clinic, bearing the signature uo..n J, Pn"ce and showing a date of service of '/ J OlS Ja; The return receipt is attached hereto and incorporated by reference, ~~ Dated: ~ I ;).~I 00 Certified Legal Intern F AMIL Y LAW CLINIC 45 N, Pitt St. Carlisle, PA 17013 717-243-2968 ~"~ ~ '..; ~iIillllliiilhlll""""" ,. '_~l ~-~,.._~~~~ gJL;"~ 2~ ;::S~ ~~; ).> ""- n r-'~ .--:- ;-'.J CD t'-.:J ~,O ~] " " \ ~ - "fl~~~.....i....~~1 ~" . _r.i, ~ l"~ Z 338 765 b4D J Certified Fee , \ Special Delivery Fee ...J-___ __ ,__,_,__~_,___,______~__ .,,- _ -' --,~- -'< '- :" '_---, _ _:,,, ,-' ".,'__,- _r_': ' ,-" ," ',,"I'" · CompletE! ile"," 1, 2; a~. 3. A"" complele item 4 if Restricted Delivery is desired. '. Print your name and address on the reverse so that we can return the' carel to you. . Attach this card to the ba~k of the mailpiece, or on the front if space permits. 1. Article Addressed to: :D~Y\ J P~lt , y ~, ~\d\ur~" ~3 CeLr1r?l{ 10\ Il D\? o Agent o Addressee D. Is deliver; add 0 Yes If VEs'C1RJlitfobeMA II No 3'.;'1'e ' '" . !to;. P. Express Mail ' . J!~:..,~;. eceipt for Marchandise Dlnsu~il "." 4. Restricted Delivery? ' ~ 2. Article Number (Copy from service labeQ c:. =3>3'(S -, (p S- U> 44) PS Form 3811 , July 1999 Domestic Return Receipt 102595-99-M-1789 ,,^ ~,.' -_' " ,I""",.' , k,'T",~~'- ",,',,-- ~. , .\ r " , SEP 2 0 200% ~ JODY M, PERKEY, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DEAN J. PRICE, Defendant NO, 2000 - 2527 CIVIL IN CUSTODY COURT ORDER AND NOW, this 3 '1" day of September, 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I, This Order shall be a temporary custody order subject to modification in the future after the next Custody Conciliation Conference, 2. The Father, Dean J. Price, shall enjoy primary physical custody of Annette S. Price, born November 26, 1998. 3, The Mother, Jody M. Perkey, shall enjoy periods of temporary physical custody with the minor child as follows: A. Starting the week of September 18th, on September 20th from Noon until 5:00 p,m, B, Starting the week of September 25th, for two afternoons agreed upon by the parties from Noon until 5:00 p,m, on each day, C, Starting the week of October 2nd, for two afternoons agreed upon by the parties from Noon until 5:00 p,m, on each day, D, Starting the week of October 9th, for two afternoons agreed upon by the parties from Noon until 5:00 p,m. on each day, 4, Mother's periods of temporary custody with the minor child shall be unsupervised, The parties shall work between each other to arrange for a satisfactory exchange of custody, 5, If there are any problems with Mother exercising unsupervised custody with the minor child, Father's counsel may contact the Conciliator directly to request a Conciliation Conference which will be scheduled forthwith and may be done by a telephone conference call between the Conciliator and legal counsel for the parties, ". '" ",'f' , '.' _ _ ~r ,r .~;c__ - -" , 6, The parties shall meet for another Custody Conciliation Conference on Friday, October 20, 2000 at 10:30 a,m, 7, Both parents shall keep the other parent advised with respect to their current address and phone number, Additionally, neither parent shall take the child out of the Commonwealth of Pennsylvania without giving the other parent notice as to where they will be going along with an address and phone number, this notice to be provided at least four (4) days in advance of any suggested trip. 8, Mother is directed to contact appropriate officials at Cumberland County Children's Services to determine if their ongoing Family Service Plan for this particular family has suggested the Mother complete any parenting classes or other instructional seminars, It is recommended that Mother follow through with any suggestions made by Children's Services in the Family Service Plan 9, Assuming all of Mother's times with the minor child go without incident, it is anticipated that the Conciliator can recommend to the Court after the next Custody Conciliation Conference that Mother initiate overnight visitation with the minor child, BY THE COURT, .f)J. cc: Joan Carey, Esquire Jennifer Jones Family Law Clinic , ~ "1\"';- " JODY M. PERKEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW DEAN J. PRICE, Defendant NO. 2000 - 2527 CIVIL IN CUSTODY Prior Judge: 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: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Annette S. Price, born November 26,1998, 2, A Conciliation Conference was held on September 19,2000, with the following individuals in attendance: The Mother, Jody M, Perkey, with her representative Jennifer Jones of the Dickinson School of Law Family Law Clinic; and the Father, Dean J. Price, with his counsel, Joan Carey, Esquire, 3, The Mother has not seen much of the child over the past year. Children Services is involved. Mother's visitation has been limited to supervised visitation, Mother is now seeking primary custody, The Conciliator feels we need to have an interim order put in place after which the parties should meet again to determine if we can work on a more permanent custody order. The Conciliator recommends the entry of an order in the form as attached. 9/19!fJb DATE ~ .' \ \ , . ., '",.,-.,-') ,--.- - C'..', ~tj JODY M" PERKEY, Plaintiff JUL 0 2 2001 JUN :2 9 20m ..$.9 : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY . v" : CIVIL ACTION - LAW : IN CUSTODY II ,I ., I' 'I II [-j ,I j! DEAN 1. PRICE, Defendant : NO. 00-2527 CIVIL TERM ORDER OF COURT FOR SPECIAL RELIEF PURSUANT TO RULE 1915.13 j: AND NOW, this day of .2001, based upon the petition of Jody M" Perkey, it is hereby ordered and decreed that: Jody M. Perkey shall have primary physical custody of her child, Annette S" Price, pending conciliation, currently scheduled for August 23,2001 at 8:30 a.ill. This Order shall remain in effect until modified by agreement of the parties or further Order of Court. BY THE COURT: I~ '-fU.!-;6 -Un # 1. ~ , l ,_ -,' '~._'~~ ,- JODY M" PERKEY, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY v" : CIVIL ACTION - LAW : IN CUSTODY DEAN J. PRICE, Defendant : NO. 00-2527 CIVIL TERM PETITION FOR SPECIAL RELIEF PURSUANT TO RULE 1915.13 Petitioner, Jody M" Perkey, by and through her attorneys, the Family Law Clinic, petitions this court for special relief pursuant to Pa.R c.p" 1915.13 for physical custody of the parties' child, Annette S, Price, pending conciliation, and avers in support thereof as follows: 1" Petitioner is Jody M. Perkey, plaintiff in this matter" 2" Respondent is Dean J Price, defendant in this matter" 3" Under the September 2000 Custody Order, a true and correct copy of which is attached, defendant was granted primary physical custody of the child. 4" Under the September 2000 Custody Order, plaintiff was granted periods of temporary physical custody. 5" On June 18,2001, defendant was incarcerated in CurnberlandCounty Prison and will remain incarcerated for six months or until he pays $5,000 for back child support. 6. Since June 18,2001, the child has been in the care of her paternal grandmother" 7" A custody conciliation has been scheduled in this matter for August 23, 2001 at 8:30 a"m. 8" On July 2, 2001, the Family Law Clinic contacted counsel for defendant, Joan Carrey, Esquire" She stated that she would not consent to this Petition. .~~_c,'~,i.~ ~,~~ '~ WHEREFORE, petitioner respectfully requests this court to grant petitioner's request for special relief by granting petitioner physical custody of the child pending conciliation" ~ 0 (1. 0, ~ l *- '--\'0A << \-tJL Debra Hart Munchel Certified Legal Intern JJ~ ~ ~ Tho as "Place Robert E. Rains Teri L. Henning Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 VERIFICATION Understanding that the making of any false statement would subject me to the penalties of 18 Pa.C.S !j 4904, I verify that I am the Plaintiff in the present action, and that the facts and statements contained in the above Petition are true and correct, to the best of my knowledge, information and belief D""P", Q J C; rJ. Wi ~ih~ k~~ ~ " .....1;..: Sf? 2 0 20f1}! JODY M, PERKEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW DEAN J. PRICE, Defendant NO. 2000 - 2527 CIVIL IN CUSTODY COURT ORDER AND NOW, this ;'7t~daY of September, 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I, This Order shall be a temporary custody order subject to modification in the future after the next Custody Conciliation Conference. 2, The Father, Dean J. Price, shall enjoy primary physical custody of Annette S. Price, born November 26, 1998, 3, The Mother, Jody M, Perkey, shall enjoy periods of temporary physical custody with the minor child as follows: A. Starting the week of September 18th, on September 20th from Noon until 5:00 p.m, B, Starting the week of September 25th, for two afternoons agreed upon by the parties from Noon until 5:00p,m. on each day, C, Starting the week of October 2nd, for two afternoons agreed upon by the parties from Noon until 5:00 p.rn, on each day, D. Starting the week of October 9th, for two afternoons agreed upon by the parties from Noon until 5:00 p.m. on each day, 4, Mother's periods of temporary custody with the minor child shall be unsupervised, The parties shall work between each other to arrange for a satisfactory exchange of custody, 5. If there are any problems with Mother exercising unsupervised custody with the minor child, Father's counsel may contact the Conciliator directly to request a Conciliation Conference which will be scheduled forthwith and may be done by a telephone conference call between the Conciliator and legal counsel for the parties, "->; 6, The parties shall meet for another Custody Conciliation Conference on Friday, October 20, 2000 at 10:30 a.m, 7, Both parents shall keep the other parent advised with respect to their current address and phone number. Additionally, neither parent shall take the child out of the Commonwealth of Pennsylvania without giving the other parent notice as to where they will be going along with an address and phone number, this notice to be provided at least four (4) days in advance of any suggested trip. 8, Mother is directed to contact appropriate officials at Cumberland County Children's Services to determine if their ongoing Family Service Plan for this particular family has suggested the Mother complete any parenting classes or other instructional seminars, It is recommended that Mother follow through with any suggestions made by Children's Services in the Family Service Plan 9. Assuming all of Mother's times with the minor child go without incident, it is anticipated that the Conciliator can recommend to the Court after the next Custody Conciliation Conference that Mother initiate overnight visitation with the minor child, cc: Joan Carey, Esquire Jennifer Jones Family Law Clinic ~<~"~ 'i JQDY M, PERKEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY DEAN 1. PRICE, Defendant : NO. 00-2527 CIVIL TERM CERTIFICATE OF SERVICE I, Debra Hart Munchel, Certified Legal Intern, the Family Law Clinic, hereby certify that I am serving a true and correct copy of a Petition for Special Relief Pursuantto Rille 1915.13 on the following person by hand delivery this 2nd day of July, 2001: Joan Carey MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 DOO.u). ~ 1~ -{Y) I Jf\~ Debra Hart Munchel Certified Legal Intern F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ~ ~_tiIilf" ~lililill~~~' '-. -"-.:-.,-~;,," -L~<~ia -.~ :....tilwt"""".L-i--- -. -,~.' "",,'l,\;..,;j,""l^"'-'" ""'." J' , _1 '., . ~" ~i ~ ~ ~, ~~. ,j " .' rl-) - - , I , ;'j-: !''-.) ':::J -' , -:-'1 C) ~-'-) "T. 'T, ... ( .' () .~' .-'--- ,- f._) iT] ::,~ ~ ---j "':- ::) _L> -'j -~ --< (;:) :< , Ji.: ~ JODY M. PERKEY, Plaintiff J U N.wl!. zent120G15> S; : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY v. : CIVIL ACTION - LAW : IN CUSTODY DEAN 1. PRICE, Defendant : NO" 00-2527 CIVIL TERM ORDER OF COURT FOR SPECIAL RELffiF PURSUANT TO RULE 1915.13 AND NOW, this day of .2001, based upon the petition of Jody M" Perkey, it is hereby ordered and decreed that: Jody M. Perkey shall have primary physical custody of her child, Annette S. Price, pending conciliation, currently scheduled for August 23,2001 at 8:30 a.ill. This Order shall remain in effect until modified by agreement of the parties or further Order of Court. BY THE COURT: J, ~ JODY M, PERKEY, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY v" : CIVIL ACTION - LAW : IN CUSTODY o C" ., '- c: ;- C) DEAN 1. PRICE, Defendant -rJ~'C : NO" 00-2527 CIVIL TERJI!':'" -;;"\'. ~:"._ c.., <!,~ c" : \ \'0 (:;~ ~:~ PETITION FOR SPECIAL RELIEF PURSUANT TO RULE 1915.l;t-;;, J>C z, Petitioner, Jody M. Perkey, by and through her attorneys, the Family Law Clinfd; -'"1) r. petitions this court for special relief pursuant to Pa.R.C.P. 1915" 13 for physical custody of the parties' child, Annette S. Price, pending conciliation, and avers in support thereof as follows: I. Petitioner is J ody M. Perkey, plaintiff in this matter" 2. Respondent is Dean 1. Price, defendant in this matter" 3. Under the September 2000 Custody Order, a true and correct copy of which is attached, defendant was granted primary physical custody of the child. 4" Under the September 2000 Custody Order, plaintiff was granted periods of temporary physical custody, 5" On June 18,2001, defendant was incarcerated in Cumberland County Prison and will remain incarcerated for six months or until he pays $5,000 for back child support" 6. Since June 18,2001, the child has been in the care of her pate mal grandmother. 7. A custody conciliation has been scheduled in this matter for August 23, 2001 at 8:30 a"ID. 8" On July 2, 2001, the Family Law Clinic contacted counsel for defendant, Joan Carrey, Esquire" She stated that she would not consent to this Petition" 1'- " , r.'} -"ij ,_-<'1 " , ---0", '-';'5, - '~ , ' '-'\ :::0 CO,_, -"- WHEREFORE, petitioner respectfully requests this court to grant petitioner's request for special relief by granting petitioner physical custody of the child pending conciliation. ~o(1".~ l+~A tN'\-JL Debra Hart Munchel Certified Legal Intern 0""'1 "'7 /L Tho M. Place - Robert E. Rains Teri L. Henning Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 VERIFICATION Understanding that the making of any false statement would subject me to the penalties of 18 Pa.C.S !j 4904, I verify that I am the Plaintiff in the present action, and that the facts and statements contained in the above Petition are true and correct, to the best of my knowledge, information and belief. """pm 0 d q rYfb I a 12 #(7- ~YM,{~y d=- ~" ,1 SEP 2 (I 20~1\ JODY M. PERKEY, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DEAN J. PRICE, Defendant NO, 2000 - 2527 CIVIL IN CUSTODY COURT ORDER AND NOW, this 17thdaY of September, 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I. This Order shall be a temporary anstody order subject to modification in the future after the next Custody Conciliation Conference, 2. The Father, Dean 1. Price, shall enjoy primary physical custody of Annette S, Price, born November 26, 1998. 3, The Mother, Jody M, Perkey, shall enjoy periods of temporary physical custody with the minor child as follows: A, Starting the week of September 18th, on September 20th from Noon until 5:00 p,m, B, Starting the week of September 25th, for two afternoons agreed upon by the parties from Noon until 5:00 p,m. on each day, C, Starting the week of October 2nd, for two afternoons agreed upon by the parties from Noon until 5:00 p.m. on each day, D, Starting the week of October 9th, for two afternoons agreed upon by the parties from Noon until 5:00 p,m. on each day. 4. Mother's periods of temporary custody with the minor child shall be unsupervised. The parties shall work between each other to arrange for a satisfactory exchange of custody, 5. If there are any problems with Mother exercising unsupervised custody with the minor child, Father's counsel may contact the Conciliator directly to request a Conciliation Conference which will be scheduled forthwith and may be done by a telephone conference call between the Conciliator and legal counsel for the parties, 6, The parties shall meet for another Custody Conciliation Conference on Friday, October 20,2000 at 10:30 a,m, 7, Both parents shall keep the other parent advised with respect to their current address and phone number, Additionally, neither parent shall take the child out of the Commonwealth of Pennsylvania without giving the other parent notice as to where they will be going along with an address and phone number, this notice to be provided at least four (4) days in advance of any suggested trip, 8, Mother is directed to contact appropriate officials at Cumberland County Children's Services to determine if their ongoing Family Service Plan for this particular family has suggested the Mother complete any parenting classes or other instructional seminars, It is recommended that Mother follow through with any suggestions made by Children's Services in the Family Service Plan 9, Assuming all of Mother's times with the minor child go without incident, it is anticipated that the Conciliator can recommend to the Court after the next Custody Conciliation Conference that Mother initiate overnight visitation with the minor child, BY THE COURT, ;sf t;" :I -iL J cc: Joan Carey, Esquire Jennifer Jones Family Law Clinic I, , . . . . JODY M" PERKEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY DEAN J PRICE, Defendant : NO. 00-2527 CML TERM CERTIFICATE OF SERVICE I, Debra Hart Munchel, Certified Legal Intern, the Family Law Clinic, hereby certify that I am serving a true and correct copy ofaPetition for Special Relief Pursuant to Rule 1915"13 on the following person by hand delivery this 2nd day of July, 2001: Joan Carey MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 \)QQA<>. ~'J.l'~ v\y') .ur~~ Debra Hart Munchel Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 - "",,' , '4 JODY M. PERKEY, Plaintiff Jl..#IUl90z ~o:1fJ.tll :5,9 : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY v. : CIVIL ACTION - LAW : IN CUSTODY DEAN 1. PRICE, Defendant : NO" 00-2527 CIVIL TERM ORDER OF COURT FOR SPECIAL RELmF PURSUANT TO RULE 1915.13 AND NOW, this day of .2001, based upon the petition of Jody M. Perkey, it is hereby ordered and decreed that: lody M" Perkey shall have primary physical custody of her child, Annette S. Price, pending conciliation, currently scheduled for August 23,2001 at 8:30 a.ill. This Order shall remain in effect until modified by agreement of the parties or further Order of Court. BY THE COURT: J. , , , -", ' . JQDY M. PERKEY, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY v. : CIVIL ACTION - LAW : IN CUSTODY ,- ".- ,~- ,- o o C :?:.'- DEAN J. PRICE, Defendant -OtJ.... C)L:-: CIVIL TERM:i:;: . Y:~ ~~"' \ rv : NO" 00-2527 ~<~,. --', "- ".' PETITION FOR SPECIAL RELIEF PURSUANT TO RULE 1915.d;;~; ~ Petitioner, Jody M. Perkey, by and through her attorneys, the Family Law Clinic, petitions this court for special relief pursuant to Pa,R.c.p" 1915.13 for physical custody of the parties' child, Annette S. Price, pending conciliation, and avers in support thereof as follows: I" Petitioner is Jody M" Perkey,:plaintiff in this matter" 2" Respondent is Dean J. Price, defendant in this matter. 3" Under the September 2000 Custody Order, a true and correct copy of which is attached, defendant was granted primary physical custody of the child" 4" Under the September 2000 Custody Order, plaintiff was granted periods of ternporary physical custody. 5" On June 18, 200 I, defendant was incarcerated in Cumberland County Prison and will remain incarcerated for six months or until he pays $5,000 for back child support" 6. Since June 18,2001, the child has been in the care of her paternal grandmother. 7. A custody conciliation has been scheduled in this matter for August 23, 200 I at 8:30 a.ill. 8" On July 2,2001, the Family Law Clinic contacted counsel for defendant, Joan Carrey, Esquire" She stated that she would not consent to this Petition. ~i n ~'1 " j(} ~.~,J ::::' ,- '~ WHEREFORE, petitioner respectfully requests this court to grant petitioner's request for special relief by granting petitioner physical custody of the child pending conciliation. \'J0Q{o.~~' l*-.J(\'").,{ <<~ Debra Hart Munchel Certified Legal Intern ,114/JFj "'1 !L ThotlIas M" Place Robert B. Rains Teri L. Henning Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 VERIFICATION Understanding that the making of any false statement would subject me to the penalties of 18 Pa"C.S 9 4904, I verifY that I am the Plaintiff in the present action, and that the facts and statements contained in the above Petition are true and correct, to the best of my knowledge, information and belief. D'''':f1 m Q J 9 ,:elf):} I a~ Ii le,,:}- ~yM" Pe y -'" ~~ , I SEP 2 (J 20Pj) , JODY M. PERKEY, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DEAN J. PRICE, Defendant NO, 2000 - 2527 CIVIL IN CUSTODY COURT ORDER AND NOW, this J..7thdaY of September, 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I, This Order shall be a temporary custody order subject to modification in the future after the next Custody Conciliation Conference. 2, The Father, Dean J. Price, shall enjoy primary physical custody of Annette S. Price, born November 26, 1998, 3. The Mother, Jody M, Perkey, shall enjoy periods of temporary physical custody with the minor child as follows: A, Starting the week of September 18th, on September 20th from Noon until 5:00 p.m, B. Starting the week of September 25th, for two afternoons agreed upon by the parties from Noon until 5:00 p,m, on each day, C, Starting the week of October 2nd, for two afternoons agreed upon by the parties from Noon until 5:00 p,m. on each day, 0, Starting the week of October 9"\ for two afternoons agreed upon by the parties from Noon until 5:00 p,m. on each day. 4, Mother's periods of temporary custody with the minor child shall be unsupervised, The parties shall work between each other to arrange for a satisfactory exchange of custody, 5. If there are any problems with Mother exercising unsupervised custody with the minor child, Father's counsel may contact the Conciliator directly to request a Conciliation Conference which will be scheduled forthwith and may be done by a telephone conference call between the Conciliator and legal counsel for the parties. 6, The parties shall meet for another Custody Conciliation Conference on Friday, October 20,2000 at 10:30 a,m, 7, Both parents shall keep the other parent advised with respect to their current address and phone number, Additionally, neither parent shall take the child out of the Commonwealth of Pennsylvania without giving the other parent notice as to where they will be going along with an address and phone number, this notice to be provided at leastfour (4) days in advance of any suggested trip, 8, Mother is directed to contact appropriate officials at Cumberland County Children's Services to detennine if their ongoing Family Service Plan for this particular family has suggested the Mother complete any parenting classes or other instructional seminars, It is recommended that Mother follow through with any suggestions made by Children's Services in the Family Service Plan 9, Assuming aU of Mother's times with the minor chiid go without incident, it is anticipated that the Conciliator can recommend to the Court after the next Custody Conciliation Conference that Mother initiate overnight visitation with the minor child, BY~URT' }Sf riff} 1. J/)~J ,. cc: Joan Carey, Esquire Jennifer Jones Family Law Clinic ~, ~ "~- . . JODY M. PERKEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v" : CIVIL ACTION - LAW : IN CUSTODY DEAN 1. PRICE, Defendant : NO" 00-2527 CIVIL TERM CERTIFICATE OF SERVICE I, Debra Hart Munchel, Certified Legal Intern, the Family Law Clinic, hereby certify that I am serving a true and correct copy of a Petition for Special Relief Pursuant to Rule 1915" 13 on the following person by hand delivery this 2nd day of July, 2001: Joan Carey MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 'DoO).(J. J~~ }:~. J\').ur~~UJl Debra Hart Munchel Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 --'-" T JODY M. PERKEY, Plaintiff JUL r i\ ?':I ..;Sf>. : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY '<i v. : CIVIL ACTION - LAW : IN CUSTODY DEAN 1. PRICE, Defendant : NO" 00-2527 CIVIL TERM ORDER OF COURT FOR SPECIAL RELIEF PURSUANT TO RULE 1915.13 AND NOW, this day of .2001, based upon the petition of Jody M" Perkey, it is hereby ordered and decreed that: Jody M. Perkey shall have primary physical custody of her child, Annette S. Price, pending conciliation, currently scheduled for August 23,2001 at 8:30 a.ill. This Order shall remain in effect until modified by agreement of the parties or further Order of Court" BY THE COURT: J, '-'!<:.'; -~ .. JODY M" PERKEY, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY v. : CIVIL ACTION - LAW : IN CUSTODY (') C ;;>'k :- ,- '~.' DEAN J PRICE, Defendant -uf~:" : NO. 00-2527 CIVIL TERM!~c :~~ \~--- ~~ ~J' '...,.... PETITION FOR SPECIAL RELIEF PURSUANT TO RULE 191#j~P, 10- >~ :::) Petitioner, Jody M. Perkey, by and through her attorneys, the Family Law Climb, petitions this court for special relief pursuant to Pa"R. C.P" 1915.13 for physical custody of the parties' child, Annette S. Price, pending conciliation, and avers in support thereof as follows: I. Petitioner is Jody M" Perkey, plaintiff in this matter, 2" Respondent is Dean J. Price, defendant in this matter. 3. Under the September 2000 Custody Order, a true and correct copy of which is attached, defendant was granted primary physical custody of the child. 4. Under the September 2000 Custody Order, plaintiff was granted periods of temporary physical custody" 5" On June 18,2001, defendant was incarcerated in Cumberland County Prison and will remain incarcerated for six months or until he pays $5,000 for back child support. 6" Since June 18,2001, the child has been in the care of her paternal grandmother" 7, A custody conciliation has been scheduled in this matter for August 23,2001 at 8:30 a.m. 8" On July 2, 2001, the Family Law Clinic contacted counsel for defendant, Joan Carrey, Esquire" She stated that she would not consent to this Petition. 1 r,,) ._':, ~, r; :ri ,,~ ..,.-, ~-'-' ~,.":~; '-' I:) \-..:.; ~~;:.l, " "..L~ "", ~-~ ::_'-; ~'J -< " WHEREFORE, petitioner respectfully requests this court to grant petitioner's request for special relief by granting petitioner physical custody of the child pending conciliation" ~ 0 Q"\,, '-'\\C" ... *:.. ~^ "''-{' ~ Debra Hart Munchel Certified Legal Intern n IL ThO!" ~'lPlice"" . Robert E. Rains Teri L. Henning Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 VERIFICATION Understanding that the making of any false statement would subject me to the penalties of 18 Pa,C.S Ii 4904, I verifY that I am the Plaintiff in the present action, and that the facts and statements contained in the above Petition are true and correct, to the best of my knowledge, information and belief D"~m 0 c2Cfa(J)1 a~1Z /t~<1J p ~YM"Pe 0- ~ ~ " SE? 2 0 20[1J) , JODY M, PERKEY, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DEAN J. PRICE, Defendant NO, 2000 - 2527 CIVIL IN CUSTODY COURT ORDER AND NOW, this ).7t~daY of September, 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I, This Order shall be a temporary custody order subject to modification in the future after the next Custody Conciliation Conference. 2, The Father, Dean J. Price, shall enjoy primary physical custody of Annette S, Price, born November 26, 1998, 3, The Mother, Jody M, Perkey, shall enjoy periods of temporary physical custody with the minor child as follows: A, Starting the week of September 18th, on September 20th from Noon until 5:00 p,m, B, Starting the week of September 25th, for two afternoons agreed upon by the parties from Noon until 5:00 p,m, on each day, C, Starting the week of October 2nd, for two afternoons agreed upon by the parties from Noon until 5:00 p.m. on each day, D, Starting the week of October 9ih, for two afternoons agreed upon by the parties from Noon until 5:00 p,m. on each day, 4, Mother's periods of temporary custody with the minor child shall be unsupervised. The parties shall work between each other to arrange for a satisfactory exchange of custody, 5. If there are any problems with Mother exercising unsupervised custody with the minor child, Father's counsel may contact the Conciliator directly to request a Conciliation Conference which will be scheduled forthwith and may be done by a telephone conference call between the Conciliator and legal counsel for the parties, 6, The parties shall meet for another Custody Conciliation Conference on Friday, October 20, 2000 at 10:30 a,m, 7. Both parents shall keep the other parent advised with respect to their current address and phone number. Additionally, neither parent shall take the child out of the Commonwealth of Pennsylvania without giving the other parent notice as to where they will be going along with an address and phone number, this notice to be provided at least four (4) days in advance of any suggested trip, 8, Mother is directed to contact appropriate officials at Cumberland County Children's Services to determine if their ongoing Family Service Plan for this particular family has suggested the Mother complete any parenting classes or other instructional seminars, It is recommended that Mother follow through with any suggestions made by Children's Services in the Family Service Plan 9. As~uming ail of Mother's times with the minor child go without incident, it is anticipated that the Conciliator can recommend to the Court after the next Custody Conciliation Conference that Mother initiate overnight visitation with the minor child, cc: Joan Carey, Esquire Jennifer Jones Family Law Clinic __ I ,--, .. .. JODY M" PERKEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v" : CIVIL ACTION - LAW : IN CUSTODY DEAN 1. PRICE, Defendant : NO. 00-2527 CIVIL TERM CERTIFICATE OF SERVICE I, Debra Hart Munchel, Certified Legal Intern, the Family Law Clinic, hereby certify that I am serving a true and correct copy of a Petition for Special Relief Pursuant to Rule 1915.13 on the following person by hand delivery this 2nd day of July, 2001: Joan Carey MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 T'JOOA(), v~~ l.~ v\'f"~.uf\~. Debra Hart Munchel Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 -..,~, ~~ 1 ~I: '-1 1'1 Ii 'i JODY M. PERKEY, Plaintiff JUL 02 2001 JI.:lN 2 9 ZOOl ,s; : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY .. v. : CIVIL ACTION - LAW : IN CUSTODY DEAN J. PRICE, Defendant : NO. 00-2527 CIVIL TERM ORDER OF COURT FOR SPECIAL RELIEF PURSUANT TO RULE 1915.13 AND NOW, this day of . 2001, based upon the petition ofJ ody M" Perkey, it is hereby ordered and decreed that: Jody M. Perkey shall have primary physical custody of her child, Annette S" Price, pending conciliation, currently scheduled for August 23,2001 at 8:30 a.ill. This Order shall remain in effect until modified by agreement of the parties or further Order of Court. BY THE COURT: 1. - i. .21 " Ii , l: JODY M" PERKEY, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY v. : CIVIL ACTION - LAW : IN CUSTODY o S o -- n '::1\ DEAN 1. PRICE, Defendant : NO" 00-2527 CIVIL TERN?,";' -?--"I} 7i~ - U.-!.;:"', 2':t-, PETITION FOR SPECIAL RELIEF PURSUANT TO RULE 1915.t,~\ -'" L.._ Petitioner, Jody M" Perkey, by and through her attorneys, the Family Law Clinib '-- c::: ,- \ r....,) -Y':; c ::::) .- petitions this court for special relief pursuant to Pa"R. C.P" 1915" 13 for physical custody of the parties' child, Annette S. Price, pending conciliation, and avers in support thereof as follows: I" Petitioner is Jody M" Perkey, plaintiff in this matter. 2. Respondent is Dean 1. Price, defendant in this matter. 3" Under the September 2000 Custody Order, a true and correct copy of which is attached, defendant was granted primary physical custody of the child. 4. Under the September 2000 Custody Order, plaintiff was granted periods of temporary physical custody. 5" On June 18,2001, defendant was incarcerated in Cumberland County Prison and will remain incarcerated for six months or until he pays $5,000 for back child support" 6" Since June 18, 2001, the child has been in the care of her paternal grandmother. 7" A custody conciliation has been scheduled in this matter for August 23, 200 I at 8:30 a.ill. 8" On July 2, 2001, the Family Law Clinic contacted counsel for defendant, Joan Carrey, Esquire" She stated that she would not consent to this Petition" WHEREFORE, petitioner respectfully requests this court to grant petitioner's request for special relief by granting petitioner physical custody of the child pending conciliation" 'D 0~ ~ ~ l*.. '-0'1." M'f ~ Debra Hart Munchel Certified Legal Intem J:~ n, !L Tho as M. Place Robert E. Rains Teri L. Henning Supervising Attorneys FAMILYLAWCLINlC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 VERIFICATION Understanding that the making of any false statement would subject me to the penalties of 18 Pa"C.S !j 4904, I verify that I am the Plaintiff in the present action, and that the facts and statements contained in the above Petition are true and correct, to the best of my knowledge, information and belief D."Jlmo,}Cj ;}(b/ a~ iJ, le~d= ~y M" P ey - -j . I, ~" -, SEP 2 0 2a~) 'I I'i I, I'-~ Ii :] JODY M. PERKEY, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DEAN J. PRICE, Defendant NO, 2000 - 2527 CIVIL IN CUSTODY COURT ORDER , I I I I , I II I Ii 'I I, AND NOW, this ;.7thday of September, 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I. This Order shall be a temporary custody order subject to modification in the future after the next Custody Conciliation Conference. 2. The Father, Dean J. Price, shall enjoy primary physical custody of Annette S. Price, born November 26, 1998. 3, The Mother, Jody M, Perkey, shall enjoy periods of temporary physical custody with the minor child as follows: A, Starting the week of September 18th, on September 20th from Noon until 5:00 p,m. i ~ j:J 'I , j j II I :1 'I \ I i I I 1 , B. Starting the week of September 25th, for two afternoons agreed upon by the parties from Noon until 5:00 p.m, on each day, C. Starting the week of October 2nd, for two afternoons agreed upon by the parties from Noon until 5:00 p,m, on each day, D, Starting the week of October 9ih, for two afternoons agreed upon by the parties from Noon until 5:00 p.m, on each day, 4. Mother's periods of temporary custody with the minor child shall be unsupervised, The parties shall work between each other to arrange for a satisfactory exchange of custody, 5, If there are any problems with Mother exercising unsupervised custody with the minor child, Father's counsel may contact the Conciliator directly to request a Conciliation Conference which will be scheduled forthwith and may be done by a telephone conference call between the Conciliator and legal counsel for the parties, . ..J 6, The parties shall meet for another Custody Conciliation Conference on Friday, October 20, 2000 at 10:30 a,m, 7, Both parents shall keep the other parent advised with respect to their current address and phone number, Additionally, neither parentshall take the child out of the Commonwealth of Pennsylvania without giving the other parent notice as to where they will be going along with an address and phone number, this notice to be provided at least four (4) days in advance of any suggested trip, 8, Mother is directed to contact appropriate officials at Cumberland County Children's Services to determine if their ongoing Family Service Plan for this particular family has suggested the Mother complete any parenting classes or other instructional seminars, It is recommended that Mother foUow through with any suggestions made by Children's Services in the Family Service Plan 9, Assuming ail of Mother's times with the minor child go without incident, it is anticipated that the Conciliator can recommend to the Court after the next Custody Conciliation Conference that Mother initiate overnight visitation with the minor child, BY,?URT. jS/ ~;q:j iFl'!J cc: Joan Carey, Esquire Jennifer Jones Family Law Clinic , I" , JODY M. PERKEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v" : CIVIL ACTION - LAW : IN CUSTODY DEAN 1. PRICE, Defendant : NO. 00-2527 CIVIL TERM CERTIFICATE OF SERVICE I, Debra Hart Munchel, Certified Legal Intern, the Family Law Clinic, hereby certify that I am serving a true and correct copy ofa Petition for Special ReliefPursuantto Rille 1915,13 on the following person by hand delivery this 2nd day of July, 2001: Joan Carey MidPenn Legal Services 8 lrvine Row Carlisle, P A 17013 '000A(). 1J~1 l'*:; ",\y') Uf:\e.\JJl. Debra Hart Munchel Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ,. "~"-" ~, JODY M. PERKEY, Plaintiff JUl 0 2 2001 J~1 :Sq : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY v. : CNIL ACTION - LAW : IN CUSTODY DEAN 1. PRICE, Defendant : NO. 00-2527 CNIL TERM ORDER OF COURT FOR SPECIAL RELIEF PURSUANT TO RULE 1915.13 AND NOW, this day of .2001, based upon the petition of lody M. Perkey, it is hereby ordered and decreed that: Jody M. Perkey shall have primary physical custody of her child, Annette S. Price, pending conciliation, currently scheduled for August 23,2001 at 8:30 a.ill. This Order shall remain in effect until modified by agreement of the parties or further Order of Court. BY THE COURT: J. ...~ , I JODY M. PERKEY, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY v. : CNIL ACTION - LAW : IN CUSTODY o 'F <- ,- \~- o - DEAN J. PRICE, Defendant : NO. 00-2527 -nti-' CNIL TEMi'~i, L.- '.~ en...-.- ~~.t"~-; PETITION FOR SPECIAL RELIEF PURSUANT TO RULE 1915:~j;~' :S-\ Petitioner, Jody M. Perkey, by and through her attorneys, the Family Law Clinic~- petitions this court for special relief pursuant to Pa.R.C.P. 1915.13 for physical custody of the parties' child, Annette S. Price, pending conciliation, and avers in support thereof as follows: 1. Petitioner is Jody M. Perkey, plaintiff in this matter. 2. Respondent is Dean 1. Price, defendant in this matter. 3. Under the September 2000 Custody Order, a true and correct copy of which is attached, defendant was granted primary physical custody of the child. 4. Under the September 2000 Custody Order, plaintiff was granted periods of temporary physical custody. 5. On June 18,2001, defendant was incarcerated in Cumberland Connty Prison and will remain incarcerated for six months or until he pays $5,000 for back child support. 6. Since June 18,2001, the child has been in the care of her paternal grandmother. 7. A custody conciliation has been scheduled in this matter for August 23,2001 at 8:30 a.m. 8. On July 2, 2001, the Family Law Clinic contacted counsel for defendant, Joan Carrey, Esquire. She stated that she would not consent to this Petition. I r-.) .~"-' o -1'1 C' ? .- L' , ['; !1 ,.I ..- WHEREFORE, petitioner respectfully requests this court to grant petitioner's request for special relief by granting petitioner physical custody of the child pending conciliation. ~ 0 G.t p. '-\\'. ,*- ~'<).A If'" ~ Debra Hart Munchel Certified Legal Intern I:.: ,,:; i'_i Jl~ ~ !L Tho as M. Place Robert E. Rains Ten L. Henning Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 I:. , li VERIFICATION " , Understanding that the making of any false statement would subject me to the penalties of 18 Pa.C.S ~ 4904, I verify that I am the Plaintiff in the present action, and that the facts and statements contained in the above Petition are true and correct, to the best of my knowledge, information and belief. -1 Date: ( "/J? 0 ;2 q (~Co f :;7 a/~ i2/e,,-;}- ~yM.P y . ~~ SEP 2 0 20!1Jf) JODY M. PERKEY, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DEAN J. PRICE, Defendant NO. 2000 - 2527 CIVIL IN CUSTODY COURT ORDER AND NOW, this ).7thday of September, 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. This Order shall be a temporary cnstody order subject to modification in the future after the next Custody Conciliation Conference. ;i 2. The Father, Dean J. Price, shall enjoy primary physical custody of Annette S. Price, born November 26, 1998. 3. The Mother, Jody M. Perkey, shall enjoy periods of temporary physical custody with the minor child as follows: A. Starting the week of September 18th, on September 20th from Noon until 5:00 p.m. ;: , , I I"~ Starting the week of September 25th, for two afternoons agreed upon by the parties from Noon until 5:00 p.m. on each day. Starting the week of October 2nd, for two afternoons agreed upon by the parties from Noon until 5:00 p.m. on each day. D. Starting the week of October 9;h, for two afternoons agreed upon by the parties from Noon until 5:00 p.m. on each day. B. C. " [ i~ I ii 4. Mother's periods of temporary custody with the minor child shall be unsupervised. The parties shall work between each other to arrange for a satisfactory exchange of custody. 5. If there are any problems with Mother exercising unsupervised custody with the minor child, Father's counsel may contact the Conciliator directly to request a Conciliation Conference which will be scheduled forthwith and may be done by a telephone conference call between the Conciliator and legal counsel for the parties. 6. The parties shall meet for another Custody Conciliation Conference on Friday, October 20, 2000 at 10:30 a.m. 'i. " , , 7. Both parents shall keep the other parent advised with respect to their current address and phone number. Additionally, neither parent' shall take the child out of the Commonwealth of Pennsylvania without giving the other parent notice as to where they will be going along with an address and phone number, this notice to be provided at least four (4) days in advance of any suggested trip. 8. Mother is directed to contact appropriate officials at Cumberland County Children's Services to detennine if their ongoing Family Service Plan for this particular family has suggested the Mother complete any parenting classes or other instructional seminars. It is recommended that Mother follow through with any suggestions made by Children's Services in the Family Service Plan 9. Assuming aU of Mother's times with the minor child go without incident, it is anticipated that the Conciliator can recommend to the Court after the next Custody Conciliation Conference that Mother initiate overnight visitation with the minor child. cc: Joan Carey, Esquire Jennifer Jones Family Law Clinic )- ~ . JODY M. PERKEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY DEAN 1. PRICE, Defendant : NO. 00-2527 CIVIL TERM CERTIFICATE OF SERVICE I, Debra Hart Munchel, Certified Legal Intern, the Family Law Clinic, hereby certify that I am serving a true and correct copy of a Petition for Special Relief Pursuant to Rule 1915.13 on the following person by hand delivery this 2nd day of July, 2001: Joan Carey MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 'D00)..(). ~~ 1'~ ~ d~~il Debra Hart Munchel Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 FAMILY LAW CLINIC The Dickinson School of Law The Pennsylvania State University The Dale F. Shughart Community Law Center 45 North Pitt Street Carlisle, PA 17013-2899 Joan Carey, Esquire 8 Irvine Row Carlisle, PA 17013 ',_ i :;,~\;{"'_,,_~, -'\\') .I ~-) ,:-'. /-,,/~ ,-",-, ,'i: i " 1;, f! lJ i', ~r j u.s, FG::TJ:..:::'::' ": ,.. ,. , ~;~ ::-:T~:~ :~ S L, ' 1 4 FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 Debra Hart Munchel Family Law Cinic 45 North Pitt Street Carlisle, PA 17013 Lf (.:5, rC~li~':C C C,'~-: ..:' ',-, ',,,- JODY M PERKEY, :IN THE COURT OF COMMON PLEAS Plaintiff :OF CUMBERLAND COUNTY, PENNSYLVANIA vs. :NO. 00-2527 CIVIL TERM DEAN J. PRICE, Defendant : CUSTODY PRAECIPE TO WITHDRAW APPEARANCE I, Joan Carey, withdraw my appearance as attorney of record for, Dean Price, the defendant in the above-captioned case. 7/;//01 Dafe / ~~ MidPenn Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 PRAECIPE TO ENTER APPEARANCE I, Michael Scherer, enter my appearance as attorney of record for, Dean Price, the defendant in the above-captioned case. 7.17.<>, Date ~~cfk Michael Scherer O'Brien, Baric & Scherer 17 West South Street Carlisle, PA 17013 ".. , JODY M. PERKEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-2527 CIVIL TERM v. DEAN J. PRICE, CIVIL ACTION-LAW CUSTODY Defendant PETITION FOR CUSTODY 1. The Plaintiff is Jody M. Perkey, an adult individual, who is believed to reside at the Salvation Army, 114 South Hanover Street, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is Dean J. Price, an adult individual whose permanent address is 3101 Spring Road, Lot #5, Carlisle, Cumberland County, Pennsylvania. 3. Petitioner is Francine L. Lauver, an adult individual residing at 3101 Spring Road, Lot #5, Carlisle, Cumberland County, Pennsylvania. 4. Petitioner is the paternal grandmother of the child, and petitioner stands in loco parentis to the child. 5. The name of the child is: Name Present residence Aae Annette Price 3101 Spring Road, Lot # 5 Carlisle, PA 17103 2 years The child was born on November 26, 1998. The child was born out of wedlock. The child is presently in the custody of Petitioner, Francine Lauver, who resides at 3101 Spring Road, Lot #5, Carlisle, Cumberland County, Pennsylvania. ~, _;CO,_, ' "'j ~ '1 I ~ ~ 1 '1 < 1aMi' i i _. I" I II I II I :: Since birth, the child has resided with the following persons at the following addresses: Ii " Persons Residences Dates Francine Lauver Edward Lauver Dean Price 3101 Spring Road 11/00 to present Lot # 5 Carlisle, PA 17013 Francine Lauver Edward Lauver Dean Price 4 East Louther Street 11/99 to 11/00 Carlisle, PA 17013 Francine Lauver Edward Lauver Dean Price 408 East Fayette Street 11/98 to 11/99 Lot#4 Shippensburg, PA 17257 The natural mother of the child is Jody M. Perkey, currently residing at the Salvation Army, 114 South Hanover Street, Carlisle, Cumberland County, Pennsylvania. She is not married. The natural father of the child is Dean Price, currently residing at 1101 Claremont Road, Carlisle, Cumberland County, Pennsylvania. He is not married. 6. The relationship of the Petitioner to the child is that of paternal grandmother. 7. The relationship of the Plaintiff to the child is that of natural mother. 8. The relationship of the Defendant to the child is that of natural father. I i 9. Petitioner has participated in this action as a person who stands in loco parentis to the child. II I , ,~ "" -" , ~'. ", -- ",,-,. .:- ~'-,-< ">-~"<' - ~-'-"'-". ,"~"-- '., I .'I~: I I - . Petitioner has no information of a custody proceeding, other than this , , I , ! action, concerning the child pending in a court of this Commonwealth. Petitioner 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. 10. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child 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 child will be given notice of the pendency of this action and " II I I I " I , I i I I I, II Ii I I, 'I !, II ,i the right to intervene. NONE. WHEREFORE, Petitioner requests your Honorable Court to grant her physical custody of the child. Respectfully submitted, O'BRIEN, BARIC & SCHERER Date: 7.31.0 I 7Iktd ~ Michael A. Scherer, Esquire 17 West South Street Carlisle, PA 17013 (717) 249-6873 mas.dir/domestic/custody/lauver.com VERIFICATION ! ii I, i] . II I' ,i 'I II Ii /1 II Ii ii I' Ii I' ,I i. II II ,I il Ii ',j I verify that the statements made in the foregoing Petition for Custody are true and correct to the best of my knowledge, information and belief, This verification is signed by Michael A. Scherer, Esquire, Attorney for Petitioner and is based upon the statements provided by Francine Lauver, as well as documents reviewed by the undersigned as attorney for Francine Lauver. This verification will be substituted and ratified by a verification signed by Francine Lauver who is presently unavailable to sign said verification. I undersigned that false statements herein are made subject to Date: 7.11.091 ~~ Michael A. Scherer, Esquire Ii I' II Ii II " I' Ii " I " :1 I I , ,I Ii 1 I penalties of 18 Pa.C.S. 94904, relating to unsworn falsifications to authorities. il il "--> ....,-, .",~.,,-. c_, ,", ~'. ,.","",~ '.->~. . .'" ,^..", "'-~1 CERTIFICATE OF SERVICE I hereby certify that on July 31, 2001, I, Michael A. Scherer, Esquire of O'Brien, Baric & Scherer, did serve a copy ofthe Petition For Custody, via hand delivery to the party listed below, as follows: Debra Hart Munchel, Esquire Family Law Clinic 45 North Pitt Street Carlisle, Pennsylvania 17013 ~ Michae A. Scherer I', " ,I I' ,I II il :i II - . "=-~.II II I' , " i\ I' 'il I' il II f ( ,I H n il 'I I Ii II II 'I II I' II [I II " Ii 'I I I L JODY M. PERKEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-2527 CIVIL TERM CIVIL ACTION-LAW CUSTODY v. DEAN J. PRICE, Defendant " '~.' (~~ ',') PETITION FOR CUSTODY '-'.,- ("~ +- 1. The Plaintiff is Jody M. Perkey, an adult individual, who is beli~ to:,: ::-:) reside at the Salvation Army, 114 South Hanover Street,' Carlisle, Cumberland<Collrity, c< Pennsylvania. 2. The Defendant is Dean J. Price, an adult individual whose permanent address is 3101 Spring Road, Lot #5, Carlisle, Cumberland County, Pennsylvania. 3. Petitioner is Francine L. Lauver, an adult individual residing at 3101 ! Spring Road, Lot #5, Carlisle, Cumberland County, Pennsylvania. 4. Petitioner is the patemal grandmother of the child, and petitioner stands in loco parentis to the child. 5. The name of the child is: . Name Present residence Aae Annette Price 3101 Spring Road, Lot # 5 Carlisle, PA 17103 2 years The child was born on November 26, 1998. The child was born out of wedlock. The child is presently in the custody of Petitioner, Francine Lauver, who resides at 3101 Spring Road, Lot #5, Carlisle, Cumberland County, Pennsylvania. ''/<_ _",i: t .1, , . "".....'-r"--""""~'I Since birth, the child has resided with the following persons at the following addresses: Persons Residences Dates Francine Lauver Edward Lauver Dean Price Francine Lauver Edward Lauver Dean Price 3101 Spring Road 11/00 to present Lot # 5 Carlisle, PA 17013 4 East Louther Street 11/99 to 11/00 Carlisle, PA 17013 Francine Lauver Edward Lauver Dean Price 408 East Fayette Street 11/98 to 11/99 Lot#4 Shippensburg, PA 17257 The natural mother of the child is Jody M. Perkey, currently residing at the Salvation Army, 114 South Hanover Street, Carlisle, Cumberland County, Pennsylvania. She is not married. I " The natural father of the child is Dean Price, currently residing at 1101 Claremont Road, Carlisle, Cumberland County, Pennsylvania. . He is not married. 6. The relationship of the Petitioner to the child is that of paternal grandmother. 7. The relationship of the Plaintiff to the child is that of natural mother. 8. The relationship of the Defendant to the child is that of natural father. 9. Petitioner has participated in this action as a person who stands in loco parentis to the child. - 11 Ii '1 I .'--r' , I Petitioner has no information of a custody proceeding, other than this action, concerning the child pending in a court of this Commonwealth. Petitioner 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. 10. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child 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 child will be given notice of the pendency of this action and the right to intervene. NONE. WHEREFORE, Petitioner requests your Honorable Court to grant her physical custody of the child. Respectfully submitted, O'BRIEN, BARIC & SCHERER Date: 7.3/. () , ~dY/L Michael A. Scherer, Esquire 17 West South Street Carlisle, PA 17013 (717) 249-6873 il Ii mas.dir/domestic/custodynauver.com II 'I :1 " Ii VERI FICA TION " I verify that the statements made in the foregoing Petition for Custody are true ':, \:: Ii i I ~ and correct to the best of my knowledge, information and belief. This verification is signed by Michael A. Scherer, Esquire, Attorney for Petitioner and is based upon the undersigned as attorney for Francine Lauver. This verification will be substituted and !:i I;i I: i~ ::i :1 'Ii , statements provided by Francine Lauver, as well as documents reviewed by the ratified by a verification signed by Francine Lauver who is presently unavailable to sign said verification. I undersigned that false statements herein are made subject to penalties of 18 Pa.C.S. ~4904, relating to unsworn falsifications to authorities. Date: 7. $I..P/ ~s;h Michael A. Scherer, Esquire ,: . " ""'" 11 I: i. i' .) i , I I I Ii '. Ii " II II I, II Ii II Ii II II ;: Ii . , , il n j' ;I I' Ii II Ii II i -'. ,~ '~~ri . CERTIFICATE OF SERVICE I hereby certify that on July 31, 2001, I, Michael A. Scherer, Esquire of O'Brien, Baric & Scherer, did serve a copy of the Petition For Custody, via hand delivery to the party fisted below, as follows: Debra Hart Munchel, Esquire Family Law Clinic 45 North Pitt Street Carlisle, Pennsylvania 17013 ~ Michae A. Scherer ;i Ii II 'I II " Ii ]1 Ii ii I , I I I , I il 1i " " d i '! I! AUG 0 7 2001VO JODY M. PERKEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW DEAN 1. PRICE, Defendant NO. 00 - 2527 CIVIL IN CUSTODY COURT ORDER AND NOW, this '1 r day of August, 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. This court's prior order of September 27, 2000 is vacated and the following temporary custody order is entered: A. The Maternal Grandmother, Francine Lauver, shall continue to have physical custody of the minor child Annette S. Price, bom November 26, 1998. B. The Mother, Jodie M. Perkey, shall enjoy physical custody with the minor child on the following times: 1. Friday, August 3, 2001 at 9:00 a.m. until Saturday, August 4, 2001 at 6:00 p.m. 2. Friday, August 10, 2001 at 9:00 a.m. until Saturday, August 11,2001 at 6:00 p.m. 3. Friday, August 17,2001 at 9:00 a.m. until Sunday, August 19,2001 at 6:00 p.m.; and every weekend thereafter at the same times until the next custody conciliation conference. 2. A second conciliation conference is scheduled for September 7,2001 at 8:30 a.m. 3. It is noted that Mother reserves the right to contest whether the Maternal Grandmother has standing to make any claim for custody or visitation of the minor child, and that that issue may be raised at any point in the future in the event the parties are unable to reach an agreement. o:l:i~ 4. In the event of any problems occurring with respect to the above outlined periods of custody allotted to the Mother, either party may contact the conciliator directly to have a custody conciliation conference held over the phone to address any emergency type issues. BY THE COURT, -#tL cc: Debra Hart Munchel Family Law Clinic Michael Scherer, Esquire ~d( 9\0\ Vf\' lllliliiiiiIiIi ~ ,,~...,;~~~il I , ~ '-.^,'", _""~>'~""""~' , ^ ,",) i ."0 .",,~~,;""'" ,""~~~__ ~ :<t~ , VINV/17J,StVf'EJd l!A!l]n'l n\'L'i' ,_ /'-L.f\/ !',j~/ I. ,-, ,1'7 '-'. 'r:J'IlIt"i", "-,., '\"'-'1"'-;'YUr..) 8U :t/,W 5-{j1ll/ fa J..l:J't;J,G\i:"'\,.J';"" '. ~;,';';-'; .;~,. ''::::... ~ i ::/0 ~-:;.~ '''-':dO "Uj '~'.:J , , Ire ., " :d :~ I~ (0 r~ " I', (ii JODY M. PERKEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA l? ti i~ ~~ :~ L~ v CIVIL ACTION - LAW DEAN 1. PRICE, Defendant NO. 00 - 2527 CIVIL IN CUSTODY I'i,' " ~ !i !~ i~ CONCILIATION CONFERENCE SUMMARY REPORT f ~ " , ~ ! ~ ~ ~ 'i 11 !! I' Ii' I " , Prior Judge: Kevin A. Hess 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 child who is the subject of this litigation is as follows: if, Annette S. Price, bom November 26, 1998. 2. A Conciliation Conference was held on August 1,2001, with the following individuals in attendance: The Mother, Jody M. Perkey, with her representative, Debra Hart Munchel, of the Dickinson School of Law Family Law Clinic; and the Maternal Grandmother, Francine Lauver, with her counsel, Michael Scherer, Esquire. Attorney Scherer also attended on behalf ofthe Father, Dean 1. Price, who is currently incarcerated. 3. The parties agreed to the entry of a temporary order in the form as attached. 7/ Ct! (}f DATE Hubert X. Gilroy, squire Custody Concir tor -~l-: , '\ SEP 1 8200f)'J ii i! '" JODY M. PERKEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW DEAN 1. PRICE, Defendant NO. 00 - 2527 CIVIL IN CUSTODY COURT ORDER AND NOW, this z.,"~ day of September, 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. This Court's Order of August 9, 2001 shall remain in effect subject to an understanding that Mother's periods of temporary custody with the minor child shall be from every Thursday at 9:00 a.m. until Sunday at 9:00 a.m. 2. Upon the Father's release from prison, counsel for the parties may contact the custody conciliator's office directly to initiate another custody conciliation conference. 3. Mother shall keep the Maternal Grandmother advised with respect to her residence, and Mother shall allow the Maternal Grandmother an opportunity to observe her home to ensure that it is appropriate. In the event there is any problem with respect to the Mother maintain housing, counsel for the Maternal Grandmother may contact the conciliator directly and ask for a telephone conference conciliation between legal counsel for the parties and the custody conciliator. BY THE COURT, cc: Michael A. Scherer, Esquire 1. Steve Boell Dickinson School of Law Family Law Clinic 6i:-'~J ~ I~::'." ,- ..,;'~ ,j.i " ~- \iINVA1ASNN3d ALNn08 c~r,nln8V'lnO L 0 :9 H~ j Z d3S ! 0 ^H\ilONO:-~lC:(;'d " :10 381.:HO--O::nu : 'iO':"(<VYJ ,. " . "- ,.", .oM_,' . "itU . " JODY M. PERKEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW DEAN J. PRICE, Defendant NO. 00 - 2527 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: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Annette S. Price, born November 26, 1998. 2. A Conciliation Conference was held on September 18, 2001, with the following individuals in attendance: The Mother, Jodie M. Perkey, with her representative, Steve BoeIl, of the Dickinson School of Law Family Law Clinic; and the Maternal Grandmother, Francine Lauver, with her counsel, Michael Scherer, Esquire. Attorney Scherer also attended on behalf of the Father. 3. The parties agree to the entry of a temporary order in the form as attached. n!k~/d( DA E or