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Home My WebLink About00-02615 ~-I' , ,,,"',,,~ 0""'1', > -~, _~__ ",' ~_'~" ,__ ...; -' ;, ~~ _.~ ' " " "_~ 'L' '" :,' ',-,.-,- t , JODIE L. LENKER, Plaintiff MAY ~ 1 200~\ IN THE COURT OF COMMON PLEAS OF \v CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN CUSTODY NO. OO-:u,!'S CIVIL TERM DAVID E. WILLIAMS, Defendant ORDER OF COURT )",^ M.A'I AND NOW, this day of ~, 2000, upon consideration of the attached complaint, it is hereby directed that th~ parties and their respective counsel appear before, f/./r/; 'I, t,J~"A ' 0(: 5,/' L ' the conciliator, at t..J#- n-'J t.."J....-t"......d [tn<.,.:f:i [~~ n.J <,/i , on the IL\+h day of ~ ' 2000, at 3:36 A.m., 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 (ren) who is the subject of this custody action to the conference, but the child/children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. , I I! I! \: , ~ I; I i: r I I !; BY THE COURT: ~\~h~~~,)j~ . Custody Conciliator (1)) 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, 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. [1j , . --, -'. OF T!j).[~FICE '- , "c)lilONOTARY OOHP.Y-3 PI13:/;J CUlv18EF!LAN'" 1'-' P""NN ' U ,,0UNTY C SYLVANIA Q:-3'Dt1 (!u;I'~;fI ~ .~ ~a< ~3C)O ~. ~ Z~. 5.J-bO ~~ ~ #-~t#'. ,~-"' ~ ~_ __ "",~~~rn"llll~~~~ Ill!JlII!!I!/H!!!rn(M;'I!!fJM~IOllIl~III~R J!I..,__ _, I =~-, '-" -""I ~_"__ '---Le :';H- -,- """0';(<0_"_.' "j' - - -,--,j,,,-"J'~.'_;,,t<,r.'~"'_~",,,_-__""M', "-,-<".-,,, --'-i/-"'-'.',. I: JODIE L. LENKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN CUSTODY DAVID E. WILLIAMS, Defendant / NO. 00- .;2'-15> CIVIL TERM COMPLAINT FOR CUSTODY The plaintiff, Jodie L. Lenker, by her attorneys, the Family Law Clinic, sets forth the following cause of action: 1. The plaintiff is Jodie L. Lenker, residing at 107 East Main Street, Apt. #4, Shiremanstown, Cumberland County, Pennsylvania 17011. 2. The defendant is David E. Williams, residing at 306 East Orange Stl:"eet, Apt. #1, Shippensburg, Cumberland County, Pennsylvania 17257. 3. Plaintiff seeks custody of the following children: Name Present Residence Date of Birth Paige Williams 107 East Main Street Apt #4 4/13/96 Shiremanstown, PA 17011 David J. Williams 107 East Main Street Apt #4 12/3/98 Shiremanstown, PA 17011 The children were born out of wedlock. The children are presently in the custody of Jodie L. Lenker. ""-,,, -.' '1--" .' > '.~- '-'-,,",'''i =--.- ,,,~- ,\'... ,-' """'~iil' During the past five years, the children have resided with the following persons and at the following addresses: Persons Jodie, Dave, & Paige Jodie, Dave, & Paige Jodie, Dave, & Paige Jodie, Dave, & Paige Jodie, Dave, & Paige Jodie, Dave, Paige, & DJ Jodie, Paige, & DJ Jodie, Paige, & DJ Addresses Dates 508 County Line Road Grantville, PA 17028 4/96-6/96 P.O. Box 34 Elizabethville, PA 17023 6/96-10/96 415 Bridge Street New Cumberland, PA 17070 10/96-11/96 119 Locust Street Palmyra, PA 17078 11/96-1/97 P.O. Box 134 Spring Glen, PA 17978 1/97-10/98 25 Evandale Court Carlisle, PA 17013 10/98-5/99 25 Evandale Court Carlisle, PA 17013 5/99-1/00 107 East Main St., Apt. #4 Shiremanstown, PA 17011 1/00-present 4. The relationship of the plaintiff to the children is that of mother. She is single. She currently resides with the following persons: Name Paige Williams David J. Williams Relationship Daughter Son 5. The relationship of defendant to the child is that of father. He is single. He currently resides with the following persons: Name Lynn Faylor Relationship Girlfriend I' "I. -,,- '"- k.",~, ,. ",- "' , 'C_J -",~ "," . L. "",. ..;w.-"'1O , '. ~. C'.. ~";l~., ~-'" ;,;'-,j,.' 6. Plaintiff has not participated as a party or witness, or ~~,~ 11 11 I 'I " ;j 11 " II '1 [j f, i1 in another capacity, in other litigation concerning the custody of the children in this or another court. plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to 7. The best interest and permanent welfare of the children i \,1 'j " " Ij ii " Ii ~ I'i j , lj " 'i H u Ii Ii Ii " il !j t; have custody or visitation rights with respect to the children. will be served by granting the relief requested because: a) Plaintiff is the primary caretaker of the both children since their birth. b) Children will benefit from the continuity of care with the mother. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, plaintiff requests the court to grant to her legal and primary physical custody of the children. i-;:"- -, ,,-, 1",:,.- ,. _ "_'''~" _,_ Date 3 \dB\CD " -, _< . ' _. '-.-,_-,. __,-,",,"' ,~~- -"-- ~-1-";-',., - - -,,-' ". ";,,.,' ",,_'~ "c,__;__ ",_,,__'.' , ' ~~NV\QrJ ~f1~~D~~ a me L. Jabl ski Certified Lega Intern ~ pi., 'I- THO~S M. PLACE ROBERT E. RAINS Supervising Attorney DONALD MARRITZ Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 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. 4904 relating to unsworn falsification to authorities. Date A( ) ~;-I oc) I / . ,~, 1.I1illl - , ~~~"liIliI!flIIdI ~-"-"""""'-"""'-~,-JillFl' ~.. . B:~ . ,.. , . -~ . : ;j:tr : : s-..... . Jo:"\ : . --'a, 10- 2:=,v ;go -ip' O~l' -I~:' 1: ..,... .. ...... . ~ . 0; ;j Z -I: O. >,~ . -II ~ )!: er:J ~ ~ 8 _..~ __ ,__~ .___~__._ ~-,,___~J._.< -" ,,, p'_ .;:;p~-,k"'"j:;~"~:--",,-"'- -. ..""" . "Iii ... .~, n (~ ~; c.::.J '7] T"" j .- 00 ,. ~ -/ "'.) (J , Cj -j ~".- n ~:-, -"'-2;; n '---., n, "-: 00 ~'~'J r~':J , -. , :=:4 '.-' -< '0 t, ~~~ , -~) ; 'I"" --'~? -;(;. ii', . ' ::..--:_~ 'u "< G> ~ " ~ () . . ::~: '. . ~:~ "0: ...E...... ;0: . o :1\;0 ~ -I,' !!!: ~ ~~1~ O~~ . -I: m >, O. ~ " "". . -<: : . ., -,.-,-- ., H' _'10-:", ,_~-""" ",-~,:iL-"-"';';;""_f---"""";' c' <'''',,~~ ",,-' '~ -,-_;.1' , ~'"_,, ,. . " MAY - 1 20~ ,; JODIE 1. LENKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW DAVID E. WILLIAMS, Defendant ,,- NO.OO- ~&/~ CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Jodie 1. Lenker, Plaintiff, to proceed in forma pauperis. I, Jaime 1. Jablonski, 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 of litigation is attached hereto. ~()~M\Jl~~~J..ttJ)l~i ime 1. Jablo . Certified Legal Intern ~n,'If-" ROBERT E. RAINS THOMAS M. PLACE Supervising Attorney DONALD MARRlTZ Staff Attorney THE F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 I~......iililllllliiiillr--' ITllIlUIL ~_H~' _~~_,',' -_bll!I~1il _~_;~'" I o~_ .~ _c"," ..,c. " "_' 'J- "' () c: ~ ~~~F 2~i.{:'- r:~: E:~, 7'~) ~:::-\.- ~~~~ :;J -, "'-j- ,> '. '-:_~j ';-' ,'c) 0.:) ..' f0 j"'J ,-1:) . ,--- Ie - '.' .'__ _ ~,' ,...d-"'-- "~, ~~"," -""'''-:'1.:'",,,. - -.".~--',"';,~-,;;";j),!,,~.",.:;,~-;,,-~*,,'.", - --.,-~;,.,,- .,'" ""'_:~-_:,,,--j:;;'~~,~' ,;,,-,'~c; .,,_ I I, I r i i j '. JODIE L. LENKER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW DAVID E. WILLIAMS, Defendant : NO. 00- JI,I (CIVIL TERM AFFIDAVIT SUPPORTING PRAECIPE FOR LEAVE TO PROCEED IN FORMA PAUPERIS L I am the plaintiff in the above matter and because of my financial condition am ;j , " ~ 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 I'...';.' , , the costs of litigation. (a) Name: Jodie L. Lenker Address: 107 East Main Street, Apt. #4, Shiremanstown, PA 1701 I Social Security No.: 184-58-0479 (b) Employment If you are presently employed, state Employer: Cumberland Distribution Address: 4501 Westport Drive, Mechanicsburg, PA 17055 Salary or wages per month: $8.65/hour $1488.00/month Type of work: Returns Clerk If you are presently unemployed, state Date of last employment: Salary or wages per month: Type of work: (c) Other income within the past twelve months Business or profession: Other self-employment: Interest: Dividends: Pension and annuities: Social security benefits: J 1,.1 i~ , , I;; Ii Ii ,I 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. w, ^ 1,,- ,'''" -- __-_,:-. ^,o_ ~ j ,';'-.'~" ,>~" , ,; '-,,, oi~ ,- ,~',"' ~~, '. Support payments: $847.00/month Ms. Lenker has not received any support according to the Court Order. Disability payments: Unemployment compensation and supplemental benefits: Workman's compensation: Public Assistance: Food stamps$l IO.OO/month Other: (d) Other contributions to household support (Wife)(Husband) Name: If your (wife)(husband) is employed, state Employer: Salary or wages per month: Type of work: Contributions from children: Contributions from parents: Other contributions: (e) Property owned Cash: Checking account: Savings account: Certificates of deposit: Real estate (including home): Motor vehicle: Suburu GL 1984 Cost $300, Amount Owed $0 Stocks; bonds: Other: (t) Debts and obligations Mortgage: Rent: $326/month Loans: Student Loan PHEAA $50.00/month Other: Gas Electric Telephone: Cable: Food (above food stamps) Car Insurance: Transportation: Daycare: Dauphin County Restitution DJ Morrison Supervision Fee $39.00/month $150.00/month $69.00/month $45.00/month $IIO.OO/month $55.00/month $IOO.OO/month $IOO.OO/month $75.00/month $25.00/month $25.00/month < J _,<_, '._c:.. ",",,;,.I,"~,,,,___ ".L -"""'~ ";-'.k4~-<L ,~,v '0>'" ,-",.,-"".-, '.-_lo__,"~:--",_'~~A,__,,_i:';" iIiIIiii.it~:: I i' I;, ! Persons dependent upon you for support (Wife)(Husband) Name: Children, if any: Name: Paige Williams David 1. Williams Age: 4 I Other persons: Name: Relationship: 4. I understand that I have a continuing obligation to inform the court of improvement in my [mandai 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. '4904, relating to unsworn falsification to authorities. Date# __~IiiIl!IiiUIliliiII~oiIl <~"""""""'~ -"---","~,~ ~ ,- -"=-' , ~^ 1;_ "- '-, ~ ".'.ii.'- ',-,"'--< -~~', r--: >:~-; i~ ~~J -, -, ciJ ~ :':j """ f? <;;" '"", ~ ,-~~ j '--' ""r' " :"-"--.) <).:,. . I~-> C) .-.' -- j~";i -;-,-':::: ~n.:i ,.-, :c~ -< -"';' Ie ,-_""~"','':'~~k'''-'"'" - .,,- ,~-"", -<-";'~,,-"- '-< - ";o~~ - "'"-';"~-0";' ,_" ,";'c" _~_;,;.,,_-_,;,.- ,~,;,,_,_, ~ ,:'1 JODIE L. LENKER, Plaintiff v. :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYL VANIA :CIVlL ACTION- LAW :IN CUSTODY DAVID E. WILLIAMS, Defendant :NO.00-2615 CIVIL TERM PRAECIPE TO REINSTATE THE COMPLAINT To the Prothonotary: Please reinstate the complaint in the above-captioned case. J2:L~w~I{Q 1). 1-Irlh Certified Legal Intern ~ d Thomas M. Place Robert E. Rains SUPERVISING ATTORNEYS Donald Marritz STAFF ATTORNEY F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PAl 70 I3 (717) 243-2968 Fax: (717) 243-3639 Dated: :5 /c;(P !a(JOn / / Attorneys for Plaintiff i"',111 - -'- ___I.iMW_'~~ ~,-~- -, " ,. l~",_==~ _, _0 -1I~15ir""'" - ~ I ~ M'" .,,="..,~", ,'".". "" ""'"'''- . ',- . ,." ~, .. .. .. n. 0 0 ~ C 0 ~ ::Jl: :;;1 .i8m ):00 z~ -< j"liJJ N r- '~oJn !o en 3'? ;;:: -0 :r!~ i~ ::Jl: - --::0 .r:- g?fl ~ .. ~ .r:- :l'i -< .. ~ J, -- 1"'<1 SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2000-02615 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LENKER JODIE L VS WILLIAMS DAVID E R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: WILLIAMS DAVID E but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT - CUSTODY, ORDE On June 13th , 2000 , this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge Dep. Franklin Co Not Found Return 18.00 9.00 10.00 59.32 5.00 101. 32 06/13/2000 ~~~~ R. Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this .zo l:" day of ~ 2.u-vV A . D . 0'1"- C. fi,,,j,,_ Ar{:r' prothono1::a - ~~ ~- ~~ SHERIFF'S RETURN - NOT FOUND CASE' NO: 2000-02615 T COMMONTWEALTH OF PENNSYLVANIA COUNTY OF FRANKLIN LENKER JODIE L VS WILLIAMS DAVID E THEODORE L KONCSOL-DEPUTY , Deputy Sheriff, diligent who being duly sworn search and inquiry for according to law, the within named says, that he made a DEFENDANT , to wit: WILLIAMS DAVID E but was unable to locate Him in his bailiwick. He therefore returns the ORDER OF COURT , NOT FOUND , as to the within named DEFENDANT , WILLIAMS DAVID E RESIDENT AT ABOVE ADDRESS, BARBARA WHISTLER, STATE D THAT DAVID MOVED TO FORTWORTH TEXAS Sheriff's Costs: Docketing Service Affidavit Surcharge Mileage So answers: 9.00 5.00 4.00 10.00 27.84 ~;I..;:< /~~~ ~ er 0 yung, rl COSTS DUE 06/05/2000 Sworn and subscribed to before me of .~ U N ARIAL SEAL PATRICIA A. STRINE. N?1ary Public Ch.::\';\berst:I".~.' F~ankhn County M Com1~,;~:':':,.....;.' Lx Ires Nov. 4. 2000 1IiIIIlIlIII_ ~ , ~\ ... " In The Court of Common Pleas of Cumberland County, Pennsylvania . . Jodie L. Lenker VS, David E. ."Williams No. 20-2165 Civil Now, 5/24/00 , 20 0 () , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff, . r~~1! Sheriff of Cumberland County, PA Affidavit of Service Now, , 20_, at o'clock M. served the within upon at by handing to a copy ofthe original and made known to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of 20 '- COSTS SERVICE MILEAGE AFFIDAVIT $ $ , I. _.~ ~ .. In The Court of Common Pleas of Cumberland County, Pennsylvania Jodie L. Lenker VS. David E. Williams No. 20-2615 Civil Now, 5/30/00 , 20 0 I) , I, SHERIFF OF CUMBERLAND COUNTY, P A, do . hereby deputize the Sheriff of Franklin County to exe.cute this Writ,this deputation being made at the request and risk of the Plaintiff. .. . r~~t:~-~ . Sheriff of CumbWljnd County, PA **Reinstated Notice & Compla~nt for Custody, Order of-Court Please return expired copy with affidavit of service, Thank You Affidavit of Service Now, ,20_,at o'clock M. served the within upon at by handing to a copy ofthe original and made known to the contents thereof. So answers, Sberiff of County, P A Swom and subscribed before me this _ day of 20 '- COSTS SERV1CE MILEAGE AFFIDA VIT $ $ 01-_ ~ FAMILY LAW CLINIC A service to the community by students from The Dickinson School of Law of The Pennsylvania State University MEMORANDUM The Dale F. Shughart Community Law Center 45 North Pitt Street Carlisle, PA 17013-2899 (717) 243-2968 Fax: (717) 243-3639 TO: Cumberland County Sheriffs Office Franklin County Sheriffs Office CC: Hubert X. Gilroy, Esq. Jodie L. Lenker vefunberland County Prothonotary's Office File, Docket No. 00-2615 FROM: Melanie D. Walz, Certified Legal Intern, Family Law Clinic RE: Jodie L. Lenker v. David E. Williams, Civil Action in Custody, Cumberland County Docket No. 00-2615. Service on David E. Williams. DATE: June 21, 2000 At the end of May, 2000, I requested that the Cumberland County Sheriffs Office try to serve David Williams with Jodie L. Lenker's Custody Complaint and In Forma Pauperis request. Cumberland County Sheriff's Office attempted to serve Mr. Williams but discovered that he was not living in Cumberland County. Cumberland County Sheriff's Office found a possible address for Mr. Williams at 16687 Cumberland Highway, Newburg, Franklin County, PA. The Cumberland County Sheriff's Office forwarded all ofthe information to the Franklin County Sheriff's Office and Theodore L. Koncsol, Deputy Sheriff, attempted to serve Mr. Williams at that address. Deputy Sheriff Koncsol spoke with Barbara Whistler at that address. She told him that David Williams had moved to Fort Worth, Texas. Barbara Whistler is the mother of David Williams' new girlfriend, Lynn Saylor. Yesterday, June 20, 2000, I had a conversation with my client, Jodie L. Lenker. She told me that David Williams showed up at her house at 107 E. Main Street, Apt. #4, Shiremanstown, PA 17011, this weekend on Friday, June 16, and Sunday, June 18. Mr. Williams wanted to see the children but Jodie Lenker would not allow him to see them. Ms. Lenker and Mr. Williams do not have any custody arrangement worked out. Ms. Lenker told me that Mr. Williams "just shows up occasionally." Jodie Lenker believes that David Williams has not moved to Fort Worth, Texas, because he was here this past weekend. She believes that Barbara Whistler lied to Deputy Sheriff Koncsol in order to protect David Williams. According to Jodie Lenker, there are two warrants out for the arrest of David Williams for non-support. Jodie Lenker said that Mr. Williams has been "hiding" for over a year. PENNSrATE .. The Dickinson School of Law An Equal Opportunity University "' IL. .1), , ',". __";~,,...'. " ,:: '-, - '. ,'i'"-,,,-,~, ,.- -'~"";:,;,'l-,,,;;,~',:_:,;i,,l:,;~_ci~" -' -'",,'_-"_ '^'m ~'o___::\~','-;';,;, . ,'"-' ...,. .... Jodie Lenker believes that Mr. Williams is not working. She believes that he and his new girlfriend, Lynn Saylor, share a teal green MR3 car. She believes that Mr. Williams and Ms. Saylor are living with Brenda Whistler at the above-mentioned address and that Mr. Williams is only there from 12:00 AM until 6 AM, so that he cannot be easily found. Jodie Lenker is willing to do anything she can to help you fmd and serve Mr. Williams. Her phone numbers are: (h) (717) 612-0277 and (0) (717) 691-2806. Ms. Lenker told me that David Williams' mother lives in the area and she thinks that his mother sees him occasionally. His mother's name is Janet Smith. Her number is (717) 469- 1758. I filed a praecipe to reinstate the Complaint again today. I have enclosed copies of the complete file from the Prothonotary's Office for both Sheriff's Offices. The Custody Conciliation is currently scheduled for Friday, July 14, 2000, at 8:30 AM, before Hubert X. Gilroy, Esq. I have sent Mr. Gilroy a copy of this Memorandum so that he understands the service problems that we have been facing. Thank you for your time and effort on this matter. ~ , JODIE L. LENKER, Plaintiff v. DAVID E. WILLIAMS, Defendant 1-:, "_ '-,' ;-"L-'.- _'ri" - -,~ """C_"""'~;;' __ - ;' :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION- LAW :IN CUSTODY :NO.00-2615 CIVIL TERM PRAECIPE TO REINSTATE THE COMPLAINT To the Prothonotary: Please reinstate the complaint in the above-captioned case. Dated: (p IdO/C:XO I f ~~oD Mel ie D. Walz Certified Legal Intern Thomas . Place Robert E. Rains SUPERVISING ATTORNEYS Donald Marritz STAFF ATTORNEY F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Fax: (717) 243-3639 Attorneys for Plaintiff - ':'-',',-- "--,, ;. -"~ '>'--.~'" . "'~u~_~~"1Ilil*- ...-~=" ~=!ltllWillltiDmll:![ijJ'li. ~ll' '.""""'"","" L~_~",~~~~.___ 'w~_ ~~.~.9, . """ '~_Y'_"-'" _ ',' ,0,'__"'.;,- " . ~"', "-"u, .....",......- 0". ''''~ '"~,- , ,,~, ~ '. ,-~ o c Z '''0(,'_: '~~, \2C ~~~~:, )>c= ~ -< C-' C::J L- S; .-- r-,) .--,~J (.,,) ,'V .- -' '.J ."0 ;.t~ <:; r\ .,(, ,'-r-. ::_:~'~~; --:-:\ -..". ~ " - ,- '"., " ,- ~." ' "'- ,-"","- '.'-;', '" '",,0_ L. __,~'i" " -' .,,~,"_ "C_'"" ' _-. ,-. "".1,",,_, ~- JUl 3 1 zooltJP JODIE 1. LENKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW DAVID E. WILLIAMS, Defendant NO. 2000 - 2615 CIVIL IN CUSTODY COURT ORDER AND NOW, this qk day of J~'~COnSideratiOn Conciliation Report, it is ordered and directed as follows: of the attached Custody I. The Mother, Jodie 1. Lenker shall enjoy legal and physical custody of Paige E. 1. Williams, born April 13, 1996 and David 1. Williams, born December3, 1998. 2. The Father, David E. Williams, shall enjoy periods of visitation with the minor children at such times and under such circumstances as agreed to by the Mother. 3. In the event Father desires to have this custody order modified to provide him with a more specific visitation schedule, Father may petition the Court at which time the case will again be scheduled for a Conference with the Custody Conciliator. ~ 4. Counsel for the Mother shall serve the Father with a copy of this Order by mailing the Order to Father's most recent address by regular mail. / BY Hm COURT,// / / , .~. .' J~ . f'Zr:P V%\~ cc: Melanie Walz Dickinson School of Law Family Law Clinic ~, c ,.~,.,_ ~ , , M',. __. =~".'- - ~"__"c"."? '"~~t_ < ~~" "- ~.. -."~ , , ~~. "'" (") ~ > ~~, m2:; ~t) i;.o bO :;P-C ~ ~ -. -= Cl C:::' "" c.:. t>.' ~ ~,--, *' -- C) -.\ "-::\ ',.',_-'\1 ';~L\; ~j2~ Qc"i i:)ni 0-, 5'.i 0< (:;l ." :3';; - .- -' 0> "",~~.Il\'!~_~" i ,~Nl!'~fllli'l'fM';t!'lI!i'll~M"_Nl!~il -"__',,'-"e I ,__ ','_ ",~,"_._ ---- __ ,,,,,"~ ,-'," >', .' ';~""." .' ,__. >_'_'~.'" -~,--, oi - -- ~__, ~1 . JODIE 1. LENKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW DAVID E. WILLIAMS, Defendant NO. 2000 - 2615 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 children who are the subj ect of this litigation is as follows: Paige E. 1. Williams, born April13, 1996 and David J. Williams, born December 3, 1998. 2. A Conciliation Conference was held on July 14, 2000, with the following individuals in attendance: The Mother, Jodie 1. Lenker, with her counsel, Melanie Walz of the Dickinson School of Law Family Law Clinic. 3. The Father was not served with this Petition despite numerous attempts to accomplish service by the Cumberland County Sheriff's Department and the Franklin County Sheriff's Department. Mother relates that she has been separated from the Father for approximately I year and that the Father has had sporadic visitation with the children. His last contact was June 18th when he saw the children for two hours. 4. In light of the Father's minimal contact with the children, the Conciliator recommends the entry of an order in the form as attached. 7/;)..)'1 (JO DATE Hubert X. Gilroy, Esquir Custody Conciliator J ~ .<" ,~ ~ --~, < SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2000-02615 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LENKER JODIE L VS WILLIAMS DAVID E R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: WILLIAMS DAVID E but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, pennsylvania, to serve the within COMPLAINT - CUSTODY REIN On August 18th , 2000 , this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: Docketing Out of county Surcharge Dep. Franklin Co 18.00 9.00 10.00 27.70 .00 64.70 08/18/2000 ~~ R. Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this 3tJ '==' day of ~nJ.f' 2C A.D. _l~ f2 7u ./"),.> JOr? ProthonotaJiy -,^~. ",,-~~-~'" ~,=~-,' 1~~ -, ~" ,,~ SHERIFF'S RETURN - REGULAR , CASE NO: 2000-02615 T COMMONWEALTH OF PENNSYLVANIA: COUNTY OF FRANKLIN LENKER JODIE L VS WILLIAMS DAVID E Amended THEODORE L KONCSOL , Deputy Sheriff of FRANKLIN County, Pensylvania, who being duly sworn according to law, says, the within ORDER OF COURT was served upon WILLIAMS DAVID E DEFENDANT , at 1200:30 Hour, on the 11th day of July at FRANKLIN COUNTY PRISON the 2000 by handing to DAVID E. WILLIAMS a true and attested copy of ORDER OF COURT together with and at the same time directing His attention to the contents thereof. Additional Comments IN FORMA PAUPERIS Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: .00 .00 .00 .00 .00 .uu ~;~U:~~ epu y erl OO/OO/OODO Sworn and before of qubt A.D. NOTARIAL SEAL PA Tf;,C:A A. ."TRINE, Notary Public Cbl.:,,;,;)ersburg. Franklin County My Carnf;\isslon - Ires Nov. 4. 2000 --" M~r~Jio~ '. ~".. JODIE L. LENKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW DAVID E WILLIAMS, Defendant ,.- NO.OO- ';)l./~ CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Jodie L. Lenker, Plaintiff, to proceed in forma pauperis. I, Jaime L. Jablonski, 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 p~. The party's affidavit showing inability to pay the costs of litigation is attached hereto. ~d ~,^N. Q,~~ ~.4n>l ~ ~. ime L. Jablo . Certified Legal Intern ~ ,.., 1-' ROBERT E. RAINS THOMAS M. PLACE Supervising Attorney DONALD MARRITZ Staff Attorney THE F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 ~, 'I 1iIlIliiIit&.. , J In The Court of Common Pleas of Cumberland County, Pennsylvania No. 20~2615 Civil Now, 6/22/00 , 20 0 () , I, SHERIFF OF CU1v.IBERLAND COUNTY, P A, do hereby deputize the Sheriff of Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. . .. ~t)d:~~t:~' *Order of Court, Reinstated Complaint ~ for Custody, expires 7/21/00 Sheriff of Cumberland County, PA Affidavit of Service Now, , 20_, at 0' clock M. served the within upon at by handing to a copy of the original and made Imown to the contents thereof So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of 20 '- COSTS SERVICE MILEAGE AFFIDA VIT $ $