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Home My WebLink About00-03225 , -;4"~- i t , CHANTELL M. THOMAS AND MARK E. THOMAS, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO, 00-3225 RICHARD A. CULLISON, Defendant CIVIL ACTION - LAW CUSTODY AMENDED ORDER OF COURT AND NOW, this ~ 3 d day of J ~ ' 2000, upon consideration of the request of counsel for the plaintiff and the recommendation of the Custody Conciliation Conference Officer, it is ordered and directed that the Order of June 28, 2000, be amended to include the name of the minor child as follows: 1. Legal custody of the child, Michelle L Cullison, shall be in Chantell M. Thomas and Mark E. Thomas, sister and brother-in-law of the child, In this capacity they shall have the right and responsibility to make all decisions regarding her health, education and religious upbringing. They shall be entitled to all records and information pertaining to the child including, but not limited to, school and medical records and information. 2. Physical custody of the child, Michelle L. Cullison, shall be primarily in Chantell M. Thomas and Mark E. Thomas, Father, Richard A. Cullison, shall have periods of partial custody upon the request of the child at times and places if the parties shall agree, 3, The parties to this Order have agreed to follow this plan for a minimum of ninety days. The parties further agree that this Order shall be temporary in nature and that either party may petition the Court to return to Custody Conciliation for a modification of this Order. Edward E. Guido, Judge. Dis!: Counsel for the plaintiff: Jordan 0, Cunningham, Esquire, 2320 North 2nd Street, PO Box 60457, Harrisburg, PA 17106-0457 """"". -., ,,-. ~,.,," --.. '''Z:-O apW, ~ o.LL 7-;'1-/-00 RXs 'W ~~1t'M: ~ " , 1!Il'.. '--!If-!''':",,,,,,," C,ii' nn ,\ "I 2 c, ", 2: I " r' 'I " vv c, , " v CU' ,,', "..~, '''-'U'~-\f "1',""""0----;1".""" ; !' I I , Ui_. ,,_".,L_, ..)0 II PENNSYLVANIA ,_~1~~~~m~~1'R'!1~l:::J..~-rfWl\lllliJ!ll!l'i;~!J "~!I!!"''''.''I'1"='' ',,"., ~. ,,' -",,,, , , ' CHANTELL M. THOMAS & MARK E. THOMAS PLAINTIFF v, RICHARD A. CULLISON DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-3225 CIVIL ACTION LAW IN CUSTODY :'11 ORDER OF COURT AND NOW, this 26th day of May ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear befonMelissa P. Greevy, Esq. . the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the 19th day of June , 2000, at 1:15 PM 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. An children age five or older may also be present at the conference, Fai]ure to appear at the conference may provide grounds for entry of a temporary or permanent order, FOR TIIE COURT, By: Isl Melissa P. Gre v Custody Conciliator I'iii The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of ]990, For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. Al] arrangements must be made at least 72 hours prior to any hearing or business before the court, You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATIORNEY AT ONCE. IF YOU DO NOT HAVE AN ATIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlis]e, Pennsylvania 170]3 Te]ephone (7]7) 249-3166 il - .....~ "..'. . . ~, '. -.'" '''~ _ .__. .__ ~ ~ . -. '"'".v,, ~. w ~.~ '"~ -~. "". <-- " 1: _, eLf.D-{)FFJCE 0, I ,'iC :,';:;orHONOTN1Y 00 MAY 30 PH 3: 23 ~~~UMY 5-JCJ'CJcY W ~ ~ ~ ail ~ 5'3:J'tZJ 71~ /Yl~ ~~. .5"-20.a? {'~ M~ ~ a4 ~ 4 ~.~-4v. c ~.-~"r~-" ""'1""" pill" _ ""'r .~" ",IJ.W'F,,-.i!l1 ~~i'''''';,;''''''l~_~-''l!'oII1!!fM!i-''''''l'''''',,_~ftIlIIIlI_ .0 ,,- .~,\.- ", ',; I ~~'t; - ...--' - "',. CHANTELL M. THOMAS and MARK E. THOMAS, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00- .3~~S C;O<.(~~ RICHARD A. CULLISON, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER OF COlffiT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Esauire, the Conciliator, on the day of , 2000, at .m., in the Attorney's Conference Room, 4th Floor, Cumberland County Courthouse, Square, Carlisle, Pennsylvania, 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. All children aae five and older shall also be present at the Conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. 'i FOR THE COURT, Date of Order: By: Custody Conciliator 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 Telephone: (717) 249-3166 Ii "-- "IlIMriImJ~~ CHANTELL M. THOMAS and MARK E. THOMAS, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. Po ~ .3.<02!{ Ce.:x; -,;,- RICHARD A. CULLISON, Defendant CIVIL ACTION - LAW IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiffs are Chantell M. Thomas and Mark E. Thomas, husband and wife, residing at 1397 Silvercreek Drive, Mechanicsburg, Cumberland County, pennsylvania 17055. 2. The Defendant is Richard A. Cullison, residing at 121 East Main Street, Emmitsburg, Maryland 21727. 3. The Plaintiffs seek custody of the following child: NAME PRESENT RESIDENCE AGE Michelle L. Cullison 11981 Creek Road Fannettsburg, PAl 15 years The child was not born out of wedlock. IThe child intends to reside at this address until the end of the academic year and then relocate to 1397 Silvercreek Road, Mechanicsburg, Pennsylvania. II - ~" _.' , ~--~~ The child is presently in the custody of Barbara J. Yeager, who resides at 11981 Creek Road, Fannettsburg, Franklin County, Pennsylvania. During the past five (5) years, the child had resided with the following persons and at the following addresses: (LIST ALL PERSONS) (LIST ALL ADDRESSES) (DATES) 3/00 to Present Barbara J. Yeager 11981 Creek Road Fannettsburg, PA patricia Cullison 17776 Springtown Road Fannettsburg, PA 2/00 to 3/00 9/99 to 2/00 9/98 to 9/99 patricia Cullison 302 York Street Gettysburg, PA 301 Baltimore Street Gettysburg, PA 227 Highland Avenue Gettysburg, PA 1996 to 9/98 Patricia Cullison Patricia Cullison and Richard Cullison The mother of the child, Patricia Cullison, died on May 16, 2000. The father of the child is Richard Cullison, currently residing at 121 East Main Street, Emmitsburg, Maryland. He is single. 2 II _.,~- '~.'- -.. lll\lIiIIlrlIiI,~".", , : ~ 4. The relationship of Plaintiffs to the child is sister and brother-in-law. The Plaintiffs currently reside with the following persons: NAME RELATIONSHIP Sophia Thomas Daughter 5. The relationship of Defendant to the child is that of natural father. The Defendant currently resides with the following persons: NAME RELATIONSHIP Velma Copenhaver None Cathy Copenhaver None 6. Plaintiffs have 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. Plaintiffs have no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. Plaintiffs do not know of a person not a party to these proceedings who has physical custody of the child or 3 I I II , " '~f_~,"' , claims to have custody or visitation rights with respect to I' the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because the Plaintiffs have, during the course of the natural mother's death, been caretakers for the child and provided for the child's emotional, psychological and spiritual needs and can provide a stable, safe, and secure environment. Further, the plaintiffs, in the future, can provide for the child's emotional, psychological and spiritual needs. The child and her natural father are estranged and the child has expressed a desire to live with her older sister. Further, the child views the Plaintiffs as a source of stability, a source of love, and a source of emotional support. 8. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child has 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 has been given notice of the pendency of this action and the right to intervene: None. 4 II ;<'~' . '~ 1lIlIlMtl......_: WHEREFORE, Plaintiffs request the Court to grant custody of the child to the Plaintiffs. Date: ~/ff~ Respectfully submitted, ';7 C~~~GHJIl,1,//YH/OFF , / ,,' ,//;/ I . ~ I' /,,/' P.C. By: , rda 0,;:' unningham, Esquire ~ I.D. #2ZH4 2320 North Second Street P. O. Box 60457 Harrisburg, PA 17106-0457 Telephone: (717) 238-6570 (Attorneys for Plaintiff) 5 II , . I , ".'~~~hll" -" VERIFICATION I, CHANTELL M. THOMAS, verify that the statements made in the foregoing COMPLAINT FOR CUSTODY are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. !i4904, relating to unsworn falsification to authorities. f1~tP~ C TELL M. THOMAS Date: c:; -;) 3 - d(J?50 Ii ,~ , , ~.~""':'II JU/l26 2~ CHANTELL M. THOMAS & MARK E. THOMAS, Plaintiffs, v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA No. 00-3225 CIVIL ACTION - LAW RICHARD A. CULLISON, Defendant. In Custody ORDER OF COURT AND NOW, this _~~__ day of -.t~-~-----, 2000, upon consideration of the attached Custody Conciliation Report, and agreement of the parties, it is ordered and directed as follows: 1. Legal custody of the child shall be in Chantell M.Thomas and Mark E. Thomas, sister and brother in law of the child. In this capacity they shall have the right and responsibility to make all decisions regarding her health, education and religious upbringing. They shall be entitled to all records and information pertaining to the child including, but not limited to , school and medical records and information. 2. PhYSical custody of the child shall be primarily in Chantell M. Thomas and Mark E. Thomas. Father, Richard A. Cullison, shall have periods of partial custody upon the request of the child at times and places as the parties shall agree. 3. The parties to this Order have agreed to follow this plan for minimum of ninety days. The parties further agreed that this Order shall be temporary in nature and that either party may petition the Court to return to Custody Conciliation for a Modification of this Order. , '" . By the Court: ~ --------------------------___J. Distribution: Counsel for Plaintiff: Jordan D. Cunningham, Esquire 2320 North Second Street P.O, Box 604S7 Harrisburg, PA 17106. 0457 Defendant: Richard A. Cullison P,O. Box 4703 Gettysburg, PA 17325 tgplw -ffIull l,-2,8.tJO RKS ~ -. ..."""~~ .~, . ".,,~ - - -', .- - "' I' ~' __ n _'.'., .~,'- _ ~ J ~'. _ _" ~. '" " ,fILhTI-DfFICE 'OF' T~'f-' nr>'"\,u".J^lOTM'Y I .,1'__ 1"'..,I;i;' j" il"\f1 DO JUN ;~8 Ai1 8: 29 CUMBERi..AND COUNTY PENNSYLVANIA "<,Il!!l.U.'!l"f~I"lk _~ _ ., "~,~.. _ IT]"~".~ ~,.~4~ ~ ,-It""1'l'l%!'!i$~~'''!F'~'!'''1!~~.i!!!''''~ ~~,. .~~, .~,1~;~'I!~ , , .~- , ....... .~ ~ "- ~'.L CHANTELL M. THOMAS and MARK E. THOMAS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs, vs, NO, 00-3225 RICHARD A. CULLISON, Defendant CIVIL ACTION - LAW CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915,3-8. the undersigned Custody Conciliator submits the following report: 1, The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Michelle L Cullison July 13,1984 Sister and Brother-in-law 2. A Conciliation Conference was held on June 19, 2000, with the following individuals in attendance: The Sister, Chantell, and Thomas, her Husband, Mark E, Thomas, their counsel, Jordan D, Cunningham, Esquire, and the Father, Richard A Cullison, Pro Se, 3. The parties agreed to the entry of an Order in the form as attached. ~LL o/7-irt70 Dfite Melis Peel Greevy, Esquire Custody Conciliator