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Home My WebLink About00-02859 ""'I~~, . MAY 0 9 2000W Mary Jane Davis PlaintifflPetitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION ~ LAW : NO, DO - .:u>.sCf Co~tT~ Donald Davis Defendant/Respondent : IN CUSTODY ORDER AND NOW, this ~~ day of rv1 ~ ' 2000, it is hereby ordered that a hearing shall be scheduled on the qfk day of tv! ? ' 2000 at p."', ,.- ;}..: /)0 o'clock in Courtroom # ~ of the Cumberland County Courthouse, Carlisle, Pennsylvania, in the above captioned matter. ~~ ,..; ~;;~t.A~~~. 1. t-v"- rI1 ~ ~L~~> . I' II . __llI!!lIIlJ!III!~' " '. FlLED-Offi"E OF T',4t DD(')n~OiY..IO. TARY . 'c_ I "1....'.,,,.11, Ii 00 MAY -8 Pr1 3: 40 CUMBERLAND COUN7Y PENNSYLVANIA - ","_,~ "~-.-~ ._ ~."~~~,,,"'''">r.' '" ~1~_~_,"'. \: -. - ",_.," ,,_., ~-~~, ~~ .~ ,--""""'" l,,"liIllIIII!lIII"~:mIl'~~~~~~I!l!l'lQl~lI!l"~,!fI'IllIl~'a!.ltlll ~"","_1lIIl ," ~,'.' "",":"'_,,_,"_~-!,,,.,:,,_ - .~. ".'~"""C<' IN THE COURT OF COMMON PLEAS FOR THE COMMONWEALTH OF PENNSYLVANIA OF CUMBERLAND COUNTY MARY JANE DAVIS . 654 Charante Court Apt. T-2 Glen Burnie, MD. 21061 Plaintiff * 122 Herman Ave~043 Lemoyne, pa. 11 Vs. DONALD DAVIS Defendant . CASE NO, C97-38617 * . . ORDER This matter. having come before the court in Mo:y, 2000, a.a Plaintiff's Motion for Relief having been read and considered, it is on this' day of May, 2000 by the Court of Common Pleas of the CommonwealtH 0 Pennsylvania of Cumberland County, hereby: ORDERED. ADJUDGED AND DECREED, that the Judgment for Absolute Divorce in Case Number. C-97-38617, granted by the Circuit Court for Anne Arundel County, Maryland, be given full force and effect os if it were an order issued by this honorable court; AND IT IS FURTHER ORDERED, ADJUDGED AND DECREED, that DONALD E, DAVIS, shall comply with the order of the Circuit Court for Anne Arundel County. Maryland and return Physical custody of the minor child, TARA DAVIS, to MARY JANE DAVIS. pursuant to the Judgment tor Absolute Divorce, in case no. . C-97-38617, os granted by the Circuit Court for Anne Arundel County. Maryland; AND IT IS FURTHER ORDERED, ADJUDGED AND DECREED, that the local law enforcement authori1ies, be they state or county, shall assist MARY JANE DAVIS, in the enforcement of the custody provisions of the Judgment for Absolute Divorce in case no, . C-97-386 1 7 . as granted by the Circuit Court tor Anne Arundel County. S.d ..6B/.-SIS[0.,,) ..Ji1'4.....eJ ~pue:::; dL~:SC 00 so ~ew '. S'd .l.l~I;,,_, Maryland and ensure the return of the minor child, TARA DAVIS, to the physical custody of MARY JANE DAVIS, All subject to further order of this court. "BBI.-BI9(OB-) ...Ia':j....lil'J ;:;pue:] dse:so DO 90 Re~ ~"-,~, -- ~tIll ~",-..J_~f--= ~1~ml1~~'"i,",,"'iht;_g~!JJ;l',,~#J!I.o;~;>-~j'-'._'.; ""' -~ 1M tt" ~ .~~~" " , " ~ 41 0 a 0 c a :;::~.. 711 -ofi:1 :::;t ::::1 [~jrn "'" ...::_.::0 -< ;:~f1:n ;;:::-e 1 r- (0-"",> -r:']rl1 ~f5 'n :00 o~ -0 ---t p~c'. -r -- ~c5 ::J: ;e5:i:J i~ '?-O C Om Z ?5 :< '.-.> -<oJ -< ll' I < ~ . ~ ~ "'~ '~'""""hX IN THE COURT OF COMMON PLEAS FOR THE COMMONWEALTH OF PENNSYl V AN!A OF CUMBERLAND COUNTY MARY JANE DAVIS . 654 Charante Court Plaintiff Apt. T-2 . Glen Burnie, MD. 21061 122 Herman Ave. Lemoyne, Pa. 17043 Vs. DONALD DAVIS Defendant . CASE NO, C97-38617 . . . MonON FOR REliEF COMES NOW, MARY JANE DAVIS, Pro Se, and respectfully says: I, That she is a resident of the state of Maryland. 2. That she was married to the Defendant, Donald Davis, and that the parties had three children os a result of their marriage. 3, That the parties were granted an absolute divorce on October 14, 199 iJl the Circuit Court for Anne Arundel County, Case No. C-97-386 1 7, and a certified copy of said judgment for Absolute Divorce, is hereto attached, 4. Thai said Judgment for Absolute Divorce granted primary physical custody of the minor chnd of the parties, TARA DAVIS, to the Plaintiff. 5, That on Sunday, AprD 30, 2000, Tara Davis left the Plaintiff's residence without her permission and subsequently Plaintiff fDed a missing persons report with the Anne Arundel County Police Department in Maryland. 6. That on Tuesday, May 2, 2000 the Plaintiff received a telephone page from the minor child and was told the child had gone to the residence of the Defendant. Donald Davis, who resides in Cumberland County. Pennsylvania. E:'''' l>SSl.-61910tl>l "'il'~...e3 F:pue3 "'SE::90 00 so F:ew , ...",.....""""'""'-,' 7. That the Plaintiff demanded the retum of the minor child. but the Defendant has failed to comply. and in fact the Defendant has enrolled the minor child in public school in Cumberland County. Pennsylvania without fhe Plaintiff's permission or consent and contrary to the custody order of the Maryland Court. 8, That the Plaintiff contacted the lamoyne Police Deportment on Thursday, May 4.2000 to seek assistance with the entorcement of the custody order. however. the iocal authorities refused to assist the Plaintiff without a Pennsylvania Order, 9. That the Piaintiff seeks a Pennsylvania Order compelling the local authorities to assist her In Ine enforcement of her valid Maryiand custody order, WHEREFORE, Plaintiff respectfully requests; A. That this honorable court pass an order compelling DONALD DAVIS to relinquish the minor chfld, TARA DAVIS, to the custodial parent. MARY JANE DAVIS; B, That said order inciude an order compelling the local law enforcement authorities to assist the Plaintiff. MARY JANE DAVIS. in the enforcement of the Maryland Custody Order. C. That she be granted such other and further relief os the nature of her cause may require. \:;:Qo II. ~o.JN)~ MARY JANE VIS. Plaintiff .,,'d "S61.-61S(01"l ..Ja';l...le:) ~PU~J dSS'SO 00 so ~e~ ,~ .:: c_ = '-' ..' -'-'-~'" ,,<<-. '-~-' -"--, ,,' L ,-_,^, - rr -c", ~ ,,_ '_,'c,"",,_ , c-, , _ . . ,. _ ._ ,""~~' ",'_ , , i i I , , f., r; f, ( " i STATE OF MARYLAND, ANNE ARUNDEL COUNTY, SCT: I HEREBY CERTIFY, That the aforegoing is a true copy of the "S.xi<j;' men ~ if D l v Met: filed in the above entitled case, No. e~ \0Gl l- 3SCo n in the Circuit " i.: i:i ,>I ,~ ;'i i Court for Anne Arundel County. ~--------------- ~~~~ <<0l i~.'~"I- ,J.s ;-,1''01 ~,' 7fY""-~-==-~V"-'? ~,- ~0~,+/,p/-\.~%4;('~ / jll?/7\\:~,\5\'I~~-'~i/lrilJ'ii:;i'\\\r~'\\ ,/ ir~/! <0:."-\'\\ ;;J;};-. '\>S'?\.\ ,ili!'~2./i "" " \~:n\\ \, 'l'I:,!jwl" '_____ 1'(5/'I! \\I-!"(~\\';I'Ji'""-' J.i~il,'i!) \\'\-<-7'~ iY11,1,1 ~ !I?:,'i!! \'\'\,::,"'",\ O-__J~..':'" " //;:j..~ Ii \\,\~/~ 4~"; J!~'1j// \~~~~~~)f// .~ ~ -,~/.z :;~,~--:-_.-0 . Gen-21 (Rev, 11/99) IN TESTIMONY WHEREOF, I hereunto set my hand and --. ~ __, ~ 'd i,j~,~;-' ;' IN THE CIRCUIT COURT OF MARYLAND FOR ANNE ARUNDEL COUNTY * * * * * MARY JANE DAVIS Plaintiff v. DONALD E. DAVIS ;-' Defendant * * * * * * * * * * * * * * * * * Case No. C97-38617 JUDGMENT OF DIVORCE THIS case having come before the court for trial on the merit on August 17, 1998, the parties having been heard, it is this I~ day of 6;7 ~t./ '1998, by the Circuit Court for Anne 1"."::" 0;, Arundel County hereby: ORDERED, That the Plaintiff, MARY JANE DAVIS is granted a Divorce Absolute from the Defendant, DONALD E. DAVIS; ORDERED, That the Marital Separation and Property Settlement :::: n ~ Agreement between the parties dated June 25, 1996, is incorporated hereto but not merged; f') r,,: w ORDERED, That joint legal custody is granted to both parties with the physical and primary custody granted to the Plaintiff; ORDERED, That the Defendant, effective August 1, 1998, shall pay unto the Plaintiff child support in the monthly amount of Two Hundred Fifty-Nine Dollars ($259.00). The said amount shall be paid via an Earning Withholding Order directed to the Defendant's employer and shall continue and be renewable until the children ~, U1 0;,. reach the age of eighteen (18) years; ORDERED, That the Defendant's child support obligation is currently based upon part-time employment. The parties are ordered to revisit and determine child support as soon as the . .' . ""''Ii_",lflj;,loii!fdi''',,, . Defendant is employed full time. The Defendant is provided a period of one (1) year from the date of this Order to obtain full- time employment. Thereafter, child support shall be based upon full-time employment adjusted and modified accordingly; ORDERED, That the Defendant as of August 1, 1998, is currently in arrears for child support in the amount of One Thousand Sixty-Four Dollars ($1,064.00). The said arrearage will be repaid in the amount of Ten Dollars ($10.00) per week until fully paid; ORDERED, That Defendant's current child support shall be paid directly to Plaintiff starting August 21, 1998, and shall maintain until the Earnings Withholding Order has been established; ORDERED, That the Defendant is granted visitation with the children at the following times and/or dates: A. Every other holiday: Thanksgiving, Christmas, Easter, 4th of July, and children's birthday. Husband's first (1 st) holiday visitation shall be Thanksgiving 1998. B. One (1) weekend per month - beginning Saturday at 9:00 A.M. to Sunday at 6:00 P.M. Husband to provide two (2) weeks notice in advance of his chosen weekend. C. To effectuate all visitations, the parties are to meet each time at a location approximately halfway the distance between their current residence. Currently, the parties will meet in Shrewsbury, Pennsylvania. ORDERED, That the Defendant shall provide health insurance coverage for the minor children so long as it is available at a reasonable cost; 2 II"~ ~ ~ . " 'oII,,,,bJ.,,,,~:.'i,,c c' ~ ,.' , ORDERED; That all medical expense not covered by health insurance shall be split eyenly between the parties. Defendant is to reimburse Plaintiff the sum of Three Hundred Sixty-Two Dollars and Fifty Cents ($362.50) for current uncovered medical expense. The said sum to be paid directly to Plaintiff within three (3) months from August 17, 1998; ORDERED; That the Defendant is to procure and provide life insurance pursuant to the referenced Marital Agreement dated June 25, 1996; ORDERED; That' the parties shall split equally all court costs. The Defendant owes to Plaintiff the sum of Fifty Dollars ($50.00) for court costs to date; ORDERED; The Defendant, DONALD E. DAVIS is required to notify the Court wi thin ten (10) days of any change of address or employment so long as this Order is in effect, and failure to do so will subject him to a penalty not to exceed Two Hundred Fifty Dollars ($250.00), and may result in him not receiving notice of proceedings for earnings withholding; and ORDERED; The Defendant, DONALD E. DAVIS accumulates support payment's arrears amounting to more than thirty (30) days of support, he shall be subject to earnings withholding. ORDERED; All other aspects of the Court's prior Order nqt in conflict with this Order shall remain in full force and effect. This Order shall control any such conflict. 3 'If,,,-',?,, ",",'!::,_ ,~"".t"'i"""<.!ill~~lll!liiilll. '1--~~-.fi'i.1l\~-~'_~ -ra;.!lI~~_~ ~""~'=~^i~~-II<''''11 ...~'"...........,"""'N-" ~ ~~ .~ Jl. ~~ - --..jj ~ _ .~n.~J~~ - 7V ~ .~h ~ f p a ~6 C -a f2 , I ~ ~f J v cs 1S () c.,';) n ~ C:J C'1 ',.- ",i ~,~ lit',;,-t '::,-"" ;<<~ rnf-, - -<: z~ I v;." (/) ""' 0:> 86 -<L. ---j ~o -u :r:=R r)_ ~o :::;r,: '".(^) ~-m ~-o ~ 0 Pc ~ z :n :< (X) ~