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HomeMy WebLinkAbout00-03867 "- .. .. ,,-, ~, ~; ~ " "-~ ,- 'i<\l;;"2-' ~ , .' CHRISTOPHER S. EUTZY, ': IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff vs CIVIL ACTION - LAW NUMBER: 2000 - 3j'{p'l CIVIL TERM TRACEY E. GROVE, IN CUSTODY Defendant ORDER OF COURT AND NOW this, 22,1 day of June, 2000, upon consideration of the within Stipulation and Agreement and Motion of Sally 1. Winder, Esquire, counsel for Plaintiff, Christopher S. Eutzy, it is ORDERED AND DIRECTED as follows: L The parties, CHRISTOPHER S. EUTZY and TRACEY E. GROVE, shall exercise shared physical custody of the minor child, GAGE CHRISTOPHER EUTZY, born June 9, 1999, such that Father shall have physical custody of the child from Sunday, June 18,2000 at 6:00 o'clock p,m, until the following Sunday, June 25. 2000, at 6:00 o'clock p,m, when Mother shall pick him up and commence her period of physical custody from Sunday at 6:00 o'clock p,m, until the following Sunday, July 2,2000, at 6:00 o'clock p.m. and so the parties shall alternate custody of the child on a weekly basis. 2, The parites shall enjoy periods of partial custody with their minor child, Gage Christopher Eutzy for Thanksgiving and Christmas each year such that the parent in whose custody the child resides for that week shall have custody of the child in the morning until noon when the parent who is the non-residential custodian for that week shall pick up the child and enjoy custody of the child from noon until 6:00 o'clock p,m, that day, 3. Mother and Father shall enjoy rights of partial custody and visitation at such other times as the parties may mutually agree, 1. '^"<' , -" '=~' ,~ " J,;JIii.f ~1Jiikiil\~!OO"~~!MMWOOilhJi:iI!~..~if~_!ollMi~'-'''''' .... 89 CX>Oc l::'(' 4v2C ~""r~0? S O'J--~ jOol.I!JW 8()(JO) \ I:~" "1 ) {'I .,',,'11\7/\ )S\!~I::;~I '\ n,,~-. (1'- ,. . ' ~......'-' 'U.l.) I'_A) , I" "',,'!L3--:Ir'i:!\'n" ~-, ",,:-'-:,:,'; 1....; 1"11 .--' , J '0 ' 7 -':' 1":i(~I" 1'1, q "J (~ ;; I 'J'J ,.. .. _! Ii I II I I I I I I II ~ - " -"& ~" ~,:. ~ , CHRISTOPHER S. EUTZY, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PlaintitT vs CIVIL ACTION - LAW NUMBER: 2000 - .3 fl. 7 CIVIL TERM TRACEY E. GROVE, IN DIVORCE Defendant STIPULATION AND AGREEMENT COME NOW, the Plaintiff, CHRISTOPHER S. EUTZY, by and through his counsel, SALLY J, WINDER, ESQUIRE, and Defendant, TRACEY E. GROVE, and stipulate and agree as follows: L The parties hereto are the natural parents of a minor child, GAGE CHRISTOPHER EUTZY, born June 09, 1999, 2, The parties hereto and each of them agree that the mother and father, TRACEY E. GROVE and CHRISTOPHER S. EUTZY, are capable of caring for the minor child and that thay shall share and enjoy split custody of their son, GAGE CHRISTOPHER EUTZY, such that Father shall have physical and residential custody of the child from Sunday, June 18,2000 at 6:00 o'clock p,m, until Sunday, June 25,2000, at 6:00 o'clock p,m, when Mother shall pick him up and commence her period of physical and residential custody from Sunday at 6:00 o'clock p,m, until the following Sunday, July 2, 2~00, at 6:00 o'clock p,m, and so the parties shall alternate custody of the child on a weekly basis. 3, The mother, TRACEY E. GROVE and the father, CHRISTOPHER S. EUTZY, shall have certain rights of partial custody and visitation with the minor child as follows: a) for Thanksgiving and Christmas each year, both parents shall share the day with the child such that the parent in whose custody the child -,- - , " r '" c '^ - ~ resides for that week shall have custody of the child in the morning until noon when the parent who is the non-residential custodian for that week shall pick up the child and enjoy custody of the child from noon until 6:00 o'clock p,m, that day, 4, Mother and Father shall have certain rights of partial custody and visitation with the minor child at such other times as the parties may mutually agree, 5, Neither Mother, TRACEY E. GROVE, nor Father, CHRISTOPHER S. EUTZY, shall unreasonably withhold rights of partial custody and visitation as requested by the other parent. 6, The parties agree that this stipulation shall be entered as an order by the Court without the necessity of their presence, IN WITNESS WHEREOF, the parties hereto and each of them have hereunto set their hands and seals intending to be legally bound hereby, WITNESS: (SEAL) (SEAL) " ~ i ."-' '0(\ 1.}3 -J ~' ~~ ~, ~ ~~ t}fI1 00 ~~ -~~~ ~ r ~ ~","~'~;'U<!l"", .~'-o \ \;\...~....../ r ('.~. /\.y...;:, _. ......O'.~.. f":' /~. ", _;',';7" \!..:"i\. .X.."'."" ,y' t~;~':"-"/J-'E~3 \(1'\1-./" ' ,,/v,! \f ?'.:;; . ..~.O b/ ../V-,.S"........~.'l-c., ... ........~;:.t.?....... I , t. ~~~ 1'~~ V\ ~''"'tJ J'l~' ~ fV\ :t>~ ~ ~~ C> ~ ~ ~ ITl \II ~ -- ...j ~ -......J "'-"l:0.;-. , r .......r~.;.u....... .... -0 \ ~.,....^.lY.~ r;... /;'\YJ-':~~' ....0.... t"-l:/~~' '" c" '\V'\ .X.."."> , "". :::tl1~ ,<>,."'-" "~~1 \~.:/'" :; "Em: \ '~<'b'" ,,-IVJ] ..(';::-".<s ....'0'; ,.,1;"" .,'0' ... -,.s>..~o."V"<~'l-c., ..< .....:~.:J.?........ >- ~ l-' lu"~ ~ ' fJ:t:c ,~ .'~!;J.{.:'t ~-'"fE;~-'-j --~>,-,-~,-_\,,-, -,""~~~--, --,-,. "'~" , .' CHRISTOPHER S. EUTZY, -. ,-" .,.,->- ~f ; ._'~. '_0 _ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW NUMBER: 2000 - 3rf, 7 CIVIL TERM vs TRACEY E. GROVE, IN CUSTODY Defendant ORDER OF COURT Jl Wl-vd, Lool, . AND NOW this I t,{L, day of @;tllllu, "'Aefl, upon consideration of the within Stipulation and Agreement and Motion of Sally J, Winder, Esquire, counsel for Plaintiff, Christopher S, Eutzy, it is ORDERED AND DIRECTED as follows: L The Father, CHRISTOPHER S. EUTZY and the Mother, TRACEY E. GROVE, shall have shared legal custody of the minor child, GAGE CHRISTOPHER EUTZY, born June 9, 1999, 2, The Father, CHRISTOPHER S. EUTZY, shall have primary residential custody of the child, GAGE CHRISTOPHER EUTZY, born June 9, 1999, 2, The Mother, TRACEY E. EUTZY, shall enjoy periods of partial custody with her minor child, Gage Christopher Eutzy on alternating weekends from Fiday at 6:00 o'clock p,m, until Sunday at 6:00 o'clock p.m, and for Thanksgiving and Christmas each year both parents shall share the day with the child spending the morning with his Father and from noon until 6:00 o'clock p,m, with Mother. 3, Mother shall enjoy rights of partial custody and visitation at such other times as the parties may mutually agree. c) '>- f- ) ;~~ ;',~~~ :~-i&) .-7 ~~ 5 c' () ('': <::'~-I c ~ .,;: ~,l_ '. ".",t' " ,il"ji', 1. "- ,0 Iv 01 \)'j'}~ , ' , "' ~ ~ - _d' ~ . ,,-~.',,~ ';"""'~4:'--' -~-,-~,_'~:C, -'.. ;-"," i',,-,'-'-i'_, -'~,__"'-"'-_ '--'~'c. CHRISTOPHER S, EUTZY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CNIL ACTION-LAW : IN CUSTODY : NO, 2000-3867 CNIL TERM V. TRACEY E. GROVE, Defendant CERTIFICATE OF SERVICE I, Suzanne H. Rhodes, Certified Legal Intern, the Family Law Clinic, hereby certify that I am serving a true and correct copy of the Petition for Modification of a Custody Order on the following by first class United States mail, postage prepaid, on this, the 16th day of January, 2003: Sally Winder, Esq, 9974 Molly Pitcher Hwy, Shippensburg, PA 17257 Date:~, lv, tloo 3 ~fl/2h~ Suzann H. Rhodes Certified Legal Intern ,'-,'~ ';'-~"i I I T '"",w "_ "c_ " ~i WiMfdi, "-' " -","."" ,c' ",,'~'<..-"'.;j' ~ ,f"'-_ ., .....dfiIi'~ " -,,~", , o c ""-- ~~~:~ 2:",) T~r--- ,_/ .c- ~~) ~\.__l y'::"- ~- -/ 2 ,~~ Cl vJ c_ ~,--':;1 - '" '-,' C) ,-~ :,~ -'.~ tf: 'J'I s:- -'. -~ ; S?tL'-"~ --,..,; 5:, -< '''~' - 1IU .',. . ,",",,"- "" - ~~LI..:1Ii",-;-:' " .. CHRISTOPHER S, EUTZY PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, 00-3867 CIVIL ACTION LAW TRACEY E, GROVE DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, January 24, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carliste on Thursday, February 20, 2003 at 9:30 AM 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 age five or older may also be present at the conference, Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 honrs prior to scheduled hearing. FOR THE COURT, By: Isl Hubert X. Gilroy, Esq, Custody Conciliator (/ The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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, YOU SHOULD TAKE TillS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE OFFICE SET FORTH BELOW TO FIND OlJT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 .. .. . . - ~~ N_" _.',_ "" ,n;HCI: , "V t,\F ",' "1,.\.,-,-\1\\'\\ ;.:~--'r,; ~:-',\"I\ .\--~ Of Q \"\ ": \ , ~\, - 1; ~] 03 j~}\ l,\\ ." ccutn'l C\J\lA~~~~~t'iA\-\\!\ Id(/~ W-~ ~ ~ 4' <$I.~ 1;2If' t70' '7l~ ~ ~ 4 ~ J;;;v'C(j ~ ~ ~ J'rl,~ ~ _ - ~ ~" '~""'~_'''"'''''f-.;i~,~~~~II'I''III~.T Plllifiqm~I'L.t _~ ".".-, " I i I'll'" '_L , " '-" ~-- -. ' -, ," "' , 0'" :' - ",-. ",",,"-' _'u'-,",,'- -~_, _', -l<_ -' ",,"' "';'d'"" ','__ - -.i . ,;Cd .. " JAN~3 8- CHRISTOPHER S, EUTZY, Plaintiff V. TRACEY E. GROVE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN CUSTODY NO, 2000-3867 CIVIL TERM ORDER OF COURT AND NOW, this day of ,2003, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before, , the conciliator, at , on the day of , 2003, at 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. All children age five or older may also be present at the conference, Failure to appear at the conference may provide grounds for entry of a temporary or permanent order, FOR THE COURT: By: Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IFYOUDO 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, ~..i.~~~,il.....U . .I;-ii.':',: - ",~ ";l:c"^ ;.," ~',,,. _c'.'".. "", ._'" -,. " "-'-"'-:\.k " CHRISTOPHER S, EUTZY, Plaintiff V, TRACEY E. GROVE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN CUSTODY NO. 2000-3867 CIVIL TERM PETITION FOR MODIFICATION OF OF CUSTODY ORDER I, The petition of Tracey E, Grove (hereinafter "Mother"), respectfully represents that on March 16, 200 I an Order of Court was entered for custody of Gage Christopher Eutzy, a true and correct copy of this order is attached, 2, The Order should be modified because: a, While Christopher Eutzy (hereinafter "Father") works, the child is sent to a babysitter. Often the child goes to the babysitter on Father's days off from work. Mother does not work and is home and able to care for the child during Father's work hours, Mother believes that it would be in the child's best interest to be with her rather than with the babysitter, b, Under the current order, Mother has the child alternating weekends and from noon until 6:00 P,M, on Thanksgiving day and Christmas day, Mother has requested additional time with the child; Father and Father's parents are very reluctant to deviate from the alternating weekend schedule in order to allow the Mother additional time with the child. c, The child should develop a strong parent/child relationship with both parents and it would be beneficial for the child to spend additional time with his mother in order to strengthen this bond, d, Mother is concerned that the child's development is behind other children his age, e, The child has medical problems but Father is reluctant to share the child's medical information with Mother. "'-"" ~'; ~ . '- :;" ;~i' ' '" .,~,-,- ' . ~".' " ~ f. Mother is concerned that child will not be ready to attend school because of the developmental issues and medical problems, Mother requests more time with the child in order to address her concerns regarding the child's development and she believes that spending more time with her is in the child's best interests, Mother also requests the opportunity to be more involved in making important decisions involving the child, g~ Mother requests that child stay with her during the day when the father is working, and that Father share information on all major medical and educational decisions, WHEREFORE, Petitioner asks that the Court modify the existing Order for Custody, granting Mother additional visitation, because it will be in the best interest of the child, Date: Q(J. n. )( 0: 01003 \ J~ H. Rhtd14/ Suzan H, Rhodes Certified Legal Intern ~~GJa9-0- R BER S LUCY J HNSTON-WALSH Supervising Attorneys F AMIL Y LAW CLINIC 45 N, Pitt, St. Carlisle, P A 17013 717243-2968 ,i~ ' -,._-F ,~,,-. :.,~---" - - -'---1,' 0' -J",." , VERIFICATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa, C,S, ~ 4904 relating to unsworn falsification to authorities, Date: /- /~ - 0 1 ~ ~oYC Tracey E~ove ^"~- ~ - "~ -. "--< -, ~, > CHRISTOPHER S. EUTZY, Plaintiff vs TRACEY E. GROVE, Defendant . ~ ,~ " '!l~lll~! IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . , . CIVIL ACTION - LAW NUMBER: 2000 - "?i?07 CIVIL TERM IN CUSTODY ORDER OF COURT fY\l1.,Q,h, 2.00 I, ANDNOW this JJ,,~' day of "BrAt. r, :""", upon consideration of the within Stipulation and Agreement' and Motion of Sally J, Winder, Esquire, counsel for Plaintiff, Christopher S, Eutzy, it is ORDERED AND DIRECTED as follows: L The Father, CHRISTOPHER S. EUT~Y and the Mother, TRACEY E. GROVE. sh,a1l have shared legal custody of the minor I;hild, GAGE CIJRISTOPHER EUTZY, born June 9, 1999, , 2, Tl1eFather, CHRISTOPHER S. EUTZY, shall have primary residential custody ofthe child, GAGE CHRISTOPIJER EUTZY, born June 9, 1999, . 2, TheMother, TRACEY E. EUTZY, shall enjoy periods of partial custody with her minor child, Gage Christopher Eutzy on alternating weekends from Fiday at 6:00 o'clock p,m, until Sunday at 6:00 o'clock p.m, and for Thanksgivin,g and Christmas each year bow parents shall share the day with the child spending the morning with his Father and from noon until 6:00 o'clock p,m, with Mother. 3, Mother shall enjoy rights of partial custody and visitation at such other times as the parties may mutuallyagiee, . c', 'L ,"'~, < <~lil&~~_j~~,,-"'%J!Ji~;,iifjitJ~~~~iIr. ^ '&i" '~"~U iilIi. "." ~,' ; " " o'i_ .........." '. 0 0 c: t."j t\ $: c_ -u F' t~ IJ;J L' , ..,.,;;...... Z --'./ ::1\ r" s: cr, -< ", - ,-. r:-~ l:, -'rJ .--- J~ ='> )::; -. -,,' , , ' ;?;C) , ,. '-:? (j , , ):"(:: z "-11 ::::,-;~ ~ jJ c'" -< 1 .- -.;.'--. . . ~,'- "i,"'c'-'" ,'",,'" -"",,;:;;,', -,"__'e-'_' ..; , , ,-,," r'o:' "~;i lAN 1 7 2003 CHRISTOPHER S, BUTZY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CNILACTION-LAW : IN CUSTODY TRACEY E, GROVE, Defendant : NO, 2000-3867 CNIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Tracey E. Grove, Defendant, to proceed in forma pauperis, The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date {jln, /tfl /~()03 Respectfully submitted, ~Ww,YlL rf-I, /2h~ Suzanne H. Rhodes Certified Legal Intern F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ~1Ilo.J:l ~ ~ "' _,k~_".,~~~__ - ~.!. ",.\"L ~'~- ~"" ~ , , , , O.,.,.S~" (') c -of,;" cpq.: t;jS,~:, -"~ / r:::: l::' '- "1'0> .~t:)_ ~c ~ Cl c..0 7-:;:;. r v~~.,,' ~", cr. -v C>) --_-J-r\ ::.::'t :,0;> :D -< :.n f'-' "