HomeMy WebLinkAbout00-04619
BRENDA & DALLAS DRESSLER, WW
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
PLAINTIFF
V.
TIIOMAS BRIGGS AND TINA M. WOLF,
NATURAL PARENTS
DEFENDANT
00-4619 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 6th day of July ,2000, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear before Melissa P. Greevy, Esq. . the conciliator,
at 214 Seuate Avenue, Suite 105, Camp Hill, PA 17011 on the 26TH day of JULY ,2000, at 3:00 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. 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: Isl
Melissa P. Greev')'. Esq.tP
Custody Conciliator
The Court of Common Pleas of Cwnberland 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 THIS PAPER TO YOUR ATTORNEY AT ONCE. IFYOUDONOT
HAVE AN ATTORNEY 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, Pennsylvania 17013
Telephone (717) 249-3166
-~.~~
'"
.
!, ^-
~i""""";";''iliM&i~l;i>>t.lk!~~mig~~~~_''!;~'''~__>l!J'''_~,,"k~~'~liilUillliilldlij'ls r ---i: ~'"'"""""~liliiti'
'...Ma."
,,:,; 'iliL.
I. ~ ;:1
7. /11. &tJ
7./tJ . t?t:7
7./(J.tJd
JI,UL .L!L'~"~""_'~.."M.~~ ,..,...." .... .. d' ,. ~,.... ,,' '
F!~.i~[)-O~.f,:!ir:F
OF ''', fc.;...'I".,.,.:i,i;,T.,Oy
.' ;"I,c-->[l
00 JUl 10 Plj 3: 15
'''U'j'o;-''" '. ,.
v j\l t;L:liU,\t\U COUNN
PENNSYL'v~NIA
M&~I'~~4~
'71~ ~ ?b ~
~ /I1a<'jJ.-d' ~ q ~....~
~
m
'!1'~
ii
Ii
11
,
BRENDA DRESSLER AND,
DALLAS DRESSLER, husband and wife
Plaintiffs
IN THE COURT OF COMMON PLEAS
vs.
OF CUMBERLAND COUNTY, PA.
NO. 00-4L:.l'l Go~(~
THOMAS BRIGGS AND,
TINA M. WOLF, natural parents
Defendants
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this day of , 2000, upon
consideration of the attached complaint, it is hereby directed that the parties and their
respective counsel appear before
conciliator, at
the day of ,2000, 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. Either party may bring the child
who is subject of this custody action age 5 or older to the conference, but the
child's/children's attendance is not mandatory. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
, the
on
FOR THE COURT.
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
(717) 249-3166
-.
~,
'A'"'1' ~~
.
1\
RENDA DRESSLER, AND DALLAS : IN THE COURT OF COMMON PLEAS
RESSLER, HUSBAND AND WIFE : OF CUMBERLAND COUNTY, PENNA.
Plaintiff :
:
VS. : NO.
:
OMAS BRIGGS, AND TINA M. : CIVIL ACTION - LAW
OLF, NATURAL PARENTS : IN CUSTODY
Defendant ,
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wish to defend against
he claims set forth in the following pages, you must take prompt
ction. You are warned that if you fail to do so, the case may
roceed without you and a decree of divorce or annulment may be
ntered against you by the Court. A Judgment may also be entered
gainst you for any other claim or relief requested in these
apers by the Plaintiff. You may lose money or property or other
ights important to you, including custody or visitation of your
hildren.
When the ground for the divorce is indignities or irretriev-
ble breakdown of the marriage, you may request marriage counsel-
ng. A list of marriage counselors is available in the office of
he Prothonotary at the Cumberland County Court House, One
ourthouse Square, Carlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPER-
Y, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
RANTED YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
o NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
FFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
Cumberland County Court House
Fourth Floor
Carlisle, PA 17013
(717) 240-6222
-
." 1
II
II
BRENDA DRESSLER, AND DALLAS
RESSLER, HUSBAND AND WIFE
Plaintiff
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PENNA.
:
:
VS.
: NO.
OMAS BRIGGS, AND TINA M.
OLF, NATURAL PARENTS
Defendant
CIVIL ACTION - LAW
IN CUSTODY
:
NOTICIA
USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de
as quejas expuestas en las paginas siguientes, debe tamar accion
on prontitud. Se Ie avisa que si no se defiende, el caso puede
roceder sin usted y decreta de divorcio 0 anulamiento puede ser
mitido en su contra par la Corte. Una decision puede tambiem
er emitida en su contra par cualquier otra queja 0 compensacion
eclamados par el demandant. Usted puede perder dinero, 0
ropiedades u otros derechos importantes para usted.
Cuando la base para el divorcio es indignidades 0
ompimiento irreparable del matrimonio, usted puede solicitar
onsejo matrimonial. Una lista de consejeros matrimoniales esta
isponible en la oficina del Prothonotary, en la Cumberland
ounty Court house, One Courthouse Square, Carlisle,
ennsylvania.
SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL
ONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO
INAL DE DIVORCIO 0 ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER
L DERECHO ARECLAMAR CUALQUIERA DE ELLOS.
USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI
o TIENE 0 NO PUEDE PAGAR UN ABOGADO, VAYA 0 LLAME A LA OFICINA
NDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA
EGAL.
Court Administrator
Cumberland County Court House
Fourth Floor
Carlisle, PA 17013
( 717) 240-6222
111-
,
=~
II
I
i
['
DA DRESSLER, and DALLAS
RESSLER, husband and wife
Plaintiffs
:
IN THE COUKr OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNA.
:
:
vs.
CIVIL ACTION - LAW
OMAS BRIGGS, and TINA M.
OLF, natural parents
Defendants
:
IN CUS~UDY n -,A ~
NO. tJ() - 4t.1'1 ~ /JV.-
COMPLAINT FOR CUSTODY
AND NOW, TO WIT, this ~day
, 2000, come the
laintiffs, Brenda Dressler and Dalla
by and through
heir attorney, Jane M. Alexander, Esquire, and file this
omplaint of which the following is a statement:
1. The Plaintiffs are Brenda Dressler and Dallas Dressler,
dult individuals who currently reside at 40 Bayberry Drive,
echanicsburg, Silver Springs Township, County of Cumberland and
ommonwealth of Pennsylvania, 17055.
2. The Defendants are Thomas Briggs, an adult individual
esiding at 308 Union Street, Columbia, County of Lancaster and
ommonwealth of Pennsylvania, 17512, and Tina M. Wolf, an adult
individual residing at 40 Bayberry Drive, Mechanicsburg, Silver
prings Township, County of Cumberland and Commonwealth of
ennsylvania, 17055.
3. Plaintiffs seek primary physical and legal custody of
he following child:
Ashley Nicole Favinger, born March 19, 1989, age eleven.
Page 1
;f "1 '
, ''-
,-,.
,-" ,~~
.
I'
I,
The child was born out of wedlock. The parents were never
narried.
The child is presently in the physical custody, of the
laintiffs, Brenda Dressler and Dallas Dressler, who reside at 40
ayberry Drive, Mechanicsburg, PA 17055. The Defendant,
aughter, Tina M. Wolf, presently resides at the same address,
ut assumes no responsibility for the child, and Defendant
father, Thomas Briggs resides at 308 Union Street, Columbia,
Lancaster county, PA 17512, and has visitation with the child as
in an order of Penny Blackwell, Judge of the Court of
ommon Pleas of York County, Pennsylvania. Said order dated
ovember 7, 1997 is entered to No. 97-SU-05001-03. A copy of
said order marked Exhibit "A" is attached hereto and made a part
hereof.
During the past three years, the child has resided with the
following persons at the following addresses:
From March 1, 1999 to date with Plaintiffs at their home at
40 Bayberry Drive, Mechanicsburg, PA 17055.
The Plaintiffs and one of the Defendants, Tina Wolf, who has
rimary custody under the court order of November 7, 1997,
xecuted an agreement regarding custody of the child on May 28,
a copy of which, marked exhibit "B" is attached hereto and
ade a part hereof.
Since May 7, 2000 one of the Defendants, Tina M. Wolf, has
Page 2
>,,<
.' ,- -~-
~ --
lso been living there on a temporary basis.
Prior to March 1, 1999 with her mother at 2723 South Duke
treet, Lot 214, York, PA 17402.
4. The relationship of Plaintiffs to the child is that of
randparents. They were married October 10, 1981, and are
urrent1y residing at 40 Bayberry Drive, Mechanisburg, PA 17055.
5. The relationship of Defendants to the child is that of
atura1 mother and natural father. The Defendant's mother, Tina
Wolf, currently resides at 40 Bayberry Drive, Mechanicsburg,
A 17055 and the Defendant's father, Thomas Briggs, currently
esides at 308 Union Street, Columbia, PA 17512.
6. The Plaintiffs have not participated as parties of
itnesses, or in any other capacity, in other litigation
oncerning the custody of the child in this or another court.
7. The Plaintiffs have no information of a custody
roceeding concerning the child pending in any other court within
his Commonwealth.
8. The Plaintiffs do not know of a person not a party to
he proceedings who has physical custody of the child or clailns
o have cllstody'or visitation rights with respect to the child.
9. The best interests and permanent welfare of the child
ill be best served by granting the relief requested because the
laintiffs can and have provided a stable home life for the child
ince March 1, 1999. Defendant mother, because of the demands of
Page 3
", , ,~,
',' ,<~,~ . .
~- ~
II
II
II
er work and her many other activities does not have the time to
are for the child on a regular basis. Defendant father has
egularly scheduled visits with child under the court order and
laintiff's desire to continue said visits with some rninor
odifications to accommodate child's activity schedule.
WHEREFORE, Plaintiffs request your Honorable Court to grant
hem primary physical and legal custody of the subject child with
ights of visitation to the Defendants substantially in
onformity with the existing court order.
R spectfully submitted,
Page 4
"
e . Al ~
torney for laintiff
8 S. Baltimore Street
llsburg, PA 17019
torney I.D. #07355
Ii
Ii
II
Verification
I verify that the statements made in this petition for
ustody are true and correct. I understand that false statements
erein are made subject to the penalties of 18 Pa. C.S. section
904 relating to unsworn falsification to authorities.
ria l:J, ~ / DO
I I
~~~"'~~
Brenda Dressler
j)~ ~!l-,~.#
Dallas Dressler
OMMONWEALTH OF PENNSYLVANIA
S.S.
OUNTY OF CUMBERLAND
Before me, the undersigned officer, a Notary Public, in and
or the said Commonwealth and county, personally appeared Brenda
~essler and Dallas Dressler, who being affirmed according to
aw, deposes and says that the facts and matters set forth in the
oregoing Petition are true and correct to the best of his
nowledge, information and belief.
~~~
Brenda Dressler
~~4~
Dallas Dressler
worn to and subsc~Abed
efore me this~~ay
, 2000.
~
Notarial Seal .
Halvard E. Alexander, Notary Public
Diiisburp Bere, York County
My CommisSIon EXllires Apn123, 2001
Member, Pennsylvania Association of Notaries
;:' ",I~, _,
lII~c c
~
_1lIlIIII1l!IIl_fJr.'NAIIII!l
,-~-~~~~ ~
~~
"0 ~
::j ~
~ --J
",.,- .~ -
.....~_,r.__._;,"o"C'~, . ' '''~ "","'-".Jq,....,~+_,_,~.,~_'" .~...[~.~~"-"""h" -/[:,,;,<.:,g,
~ h f1 ~
~ B ~ ~
"1:)1
p:~
].1
o
~
"'Of':5
mrn
z..,-.
zs'"
~:2:
r;::O
J" -
2'(,-:
-'0
):0. c::
z
=<
o
o
L-
c:::
.-~
-
o
-n
..,-.r-r>
~\~
~ '\, n-..'
'::...,~ C)
~~rn
~J>
~J
~:
~~~,~q,;:.~,ml~''"'7l'''~,~!f!'f'f..,'%m''("~!l(;.if'!l>~I~~,w~I~'m-''i!j~~:o'"''~~,,~...~1f~
N
u:>
~
-..:'-"
'8
C-
.~
Cl ,
.C\t~-\
(
()6- l/{,/'I f!. T'
(
vs.
IN THE COURT OF COMMON PLEAS
OF YORK COUNTY, PENNSYLVANIA
NO. 97-SU-05001-03
CIVIL ACTION - LAW
CUSTODY
THOMAS BRIGGS
TINA M. WOLFE
APPEARANCES:
1. Christian Ness, Esquire
For the Father
None
For the Mother
, ~"':il
~: ,~
,
-
, ,
0
.0 --,
-.I -'1
Z co
CJ r~
<: r-~'
'-. ..
w '-. .,
'-,
-0 . .
,-- "
~ - ~,:...
~ -
-.
.
to) .
-
,-,
-< (-',l
C::'_":'
-... -.'
ORDER
. ~ 1 .
:;-;. ,_.n
Thomas Briggs and Tina Wolfe are the parents of AsWey Nicole Favirtger, born March 19,
1989. The parties never lived together and had a custody arrangement of an informal nature. The
child has remained in the majority physical custody of the Mother, with the Father exercising some
weekend rights.
The Father filed the iostant petition seeking a specific Court-ordered schedule of rights. His
petition included a request for very normal rights of partial custody. Nevertheless, the parties were
unable to reach an agreement at the conciliation conference before Glenn C. Vaughn on October 31,
1997.
Accordingly, the parties were given information sheets relating to custody mediation by the
Conciliator and were instructed to contact the Mediator, Judy Shopp, by November 10, 1997, to
schedule a mediation session to occur by December 1, 1997. The parties shall split the cost of
mediation, each paying $75.00.
In the event that the parties are able to resolve the case in mediation, a proposed Order shall
be submitted to the Court for entry as the final resolution of this petition. If not, either party may
request a pre-trial conference, at which time a trial could be scheduled.
\.'i....
\ ,~ 1/ ;(1.
C;>.-J bJ f-1- '
~/
"otl '3r"lr:~' r
I) I, tit .Llt~
-'Ll
r
(
In the interim, the parties shall share legal custody. Majority physical custody shall remain
with the Mother.
The Father shall have the following rights of partial physical custody:
1. From 6 p.m. on Friday to 6 p.m. on Sunday on alternating weekends beginning October
31, 1997.
2. From 9 a.m. to 7 p.m. on alternating holidays beginning with Thanksgiving Day, 1997.
Other holidays in the alternating schedule are New Year's Day, Memorial Day, the Fourth of July and
Labor Day.
3. From noon on December 25 to noon on December 26, 1997, and from noon on December
24 to noon on December 25, 1998. The Mother shall have the reciprocal of this schedule so that she
shall have custody from noon on December 24 to noon on December 25, 1997, and from noon on
December 25 to noon on December 26, 1998, and the parties shall alternate annually these 24 hour
periods thereafter.
4. During the swnmer of 1998, the Father will have three weeks of summer vacation custody.
The weeks shall be taken as follows: The first weekend after the end of school will be a normal
weekend in the Father's schedule. The next weekend will commence his first week of summer
vacation rights. He shall then follow this schedule for the next eight weeks so that his summer
schedule would be a weekend, then an alternating week, then a weekend, then an alternating week,
then a weekend, then another alternating week and that would complete his three weeks of summer
vacation.
5. In 1999, and in summers thereafter, the Father's rights shall be alternating weeks. His first
alternating week will commence at 6 p.m. on the first Friday on which he would have an alternating
weekend according to the normal schedule.
.~ 70Q 13nrln,/.:
\_,' '",) "" J lR "J...~!(~
~~4'JAh '
7;;l~ ;)-
"'1
~~
" ,
'-
.~
The Father shall provide all transportation when custody is exchanged between the parties.
The Mother shall have the child ready for him when he arrives to pick her up, and be prepared to
receive her when returned. The Father is required to provide the transportation, but he is not
required to personally transport the child on each occasion. He may have some other person who is
known to the Mother provide this transportation for him, but it would be wise for him to alert the
Mother that this other person would be providing the transportation so that there is no confusion
about it.
In every custody case in this County, the parties are required to attend a four hour child
custody workshop. The Conciliator gave the parties information sheets and brochures for the
workshop and directed them to contact a workshop provider by November 10, 1997, to schedule
attendance at a workshop by January 15, 1998. A Certificate of Attendance at such a workshop shall
be filed on the record in this case by January 15, 1998.
A copy of this Order shall be transmitted to Attorney J. Christian Ness, and a copy shall be
transmitted to Defendant, Tina M. Wolfe, at 550 Robin Hill Circle, York, PA 17402.
BY THE COURT:
Date: N'\)~~ 7, \'l"1?-
~5 ~~kp~~
", C:.~ ./ ',?, -# '1::1
(0 '"-;1U--.t-.--r /-,
rr5'
,
'^"-,"",....
- .,~
" ~~
Page 1
1
custody
Temporary Custody
I Tina Wolf give my parents, Dallas R. and Brenda L.
Dressler temporary custody of my daughter, Ashley N. Favinger.
Ashley will reside with them until a future time. They
have my permission to act on my behalf on the best interest for
my daughter.
Tina M. Wolf
Sign \~ U\o...~Q~ Date.. 5~Jrscn
DallallR. Dressler
sign!Ja4~/l~
Date S-2,f- ;;: Y
Brenda L. Dressler
Sign~JN!.._ct .~..........
Date 5 I-J- ~ /99
I
Sworn to and subscribed before
me 3 Notary Public thls';>% day
.J ----
~-~~
---------------- --- -----.
NOTARY PUBLIC-YORK, PA
My commission expires;
---;:~~;;~;;.:,;:,;.,:;;[..._-----_.].,
""mlCl"<l \"" ".', .
rn l~; . _'hLf:\ I, I,.,:, ;':LT_t,q".' Pl J;:)I /'"
YOf\\(, 'i'UF";;< C. ~::.::".,;'i '/ : 'J, .'...". v
MY COMMI('~~;IOI'.i j~y"-:J~!~'F"-" ~w\i,' "... .- ~{O
~-~-~._-~~~,~::~:.",2:~~'~~::._
;,~ Yr
-
f <
!!
.'
RENDA DRESSLER AND : IN THE COURT OF COMMON PLEAS
ALLAS DRESSLER, husband & wife:
PLAINTIFFS : OF CUMBERLAND COUNTY, PENNA.
~
VS.
: NO. 00-4619 CIVIL TERM
:
OMAS BRIGGS AND
INA M. WOLF, natural parents
DEFENDANTS
: CIVIL ACTION - LAW
:
: IN CUSTODY
AFFIDAVIT OF SERVI
AND NOW, this .a...~ of
ppeared Jane M. Alexander, Esq
, 2000 personally
according to law,
hat a true and correct copy of
COMPLAINT IN CUSTODY was caused
o be served by certified mail with return receipt requested upon
he said,
Thomas Briggs
308 Union Street
Columbia, PA 17512
n Julv 12. 2000 by leaving the same at the Dillsburg Post
ffice with postage pre-paid thereon as evidenced by the mailing
eceipt and return receipt hereto attached and made a part
ereof.
worn and
e this
subscribed before
\1~ day of
, 2000.
-l'l
Notary Public
cl&
':,
{~~~
Notarial Seal
Halvard E. Alexander, Notary Public
Ditlsburg Bcra, York County
My Commission Expires April 23, 2001
Member, Pennsylvania Association of Notaries
.'" ",~,~ _0_,>'7"',,,", :n
.
i~
"
i
"
n
'i!
1:1
I,')'
,
"
j!
Ji[
"I
Ii,
"
II
ii
III
i,',~
!:l
!:j
!:j
II
:;1
i;~
i:~
lil
P"
ji]
"I
i'f
,
'S
i:!
j:j
1'1
ii(
'I'
I,:,
::1
:::i
j:1
i:~
I,:!
I,::
i!~
1?T
,1.'_", ~
II
IN THE COURT OF COMMON PLEAS
BRENDA DRESSLER AND :
ALLAS DRESSLER, husband & wife:
PLAINTIFFS ,
:
OF CUMBERLAND COUNTY, PENNA.
VS.
NO.
00-4619 CIVIL TERM
,'"'1 ii I also wish to receive the
om s 1.and/or.2"for additional services. following services (for an
II) . Com~ms 3; 4a, and 41;1. '
CIt . i'>rinfyoLii7fame and address on the reverse of this form so that we can return this extra fee}:
e ~ardtoyou. 0
CP . A.ttach-this form 10 the front of the mailpiece, or on the back if space does not 1. Addressee's Address
; '1
- . ei~~l ~Retum Receipt Requested" on the mailpiece below the article number. ' 2. 8J Restricted Delivery
! _,he Return Receipt will show to whom the article was delivered and the date Consult postmaster for fee.
- (jelivered. '
5 3. Article Addressed to: '4a. Article Number
i Thorro66riW
~. oaa UniOn otreeJ
Columbia, PIT 110t 61.
:
:
OMAS BRIGGS AND
INA M. WOLF, natural parents
DEFENDANTS
CIVIL ACTION - LAW
:
:
:
IN CUSTODY
.. -." "",.._,-"..",,",.~I".~'._---_._---,._,,--
''''~l 1;-"",
a;
"
'i!:
Gl
<J)
1i
'il
"
Gl
a:
c
~
::l
a Certified i
o Insured g'
o COD .~
l;
-
::l
g,
'"
C
Gl
~
4b. Service Type
:0 Registered
:0 Express Mail
!D Return Recei t for M chandise
17. Date of Deli ry.s
I
i8. Addressee's ddre s (Only if requested
a.nd fee is pai ~
\;1
..1102~ 5 iBiD22' IlJ)dnbll~tic\ll$turn Receipt
~\,- ~"'n',
.. r ~ t. :: ' -,' ..
..;
<..
OCT 2 5 2/JlJr/
IN THE GOURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-4619
BRENDA & DALLAS DRESSLER, HIW,
Plaintiffs
vs.
THOMAS BRIGGS & TINA M. WOLF,
Natural Parents,
Defendants
CIVIL ACTION - LAW
CUSTODY
ORDER OF COURT
AND NOW, this <>0 day of D~, 2000, upon consideration
of the attached Custody Conciliation Summary Report, it is ordered and directed as follows:
,
1. Legal Custody. The Mother, Tina M. Wolf, and the Maternal Grandparents, Brenda
and Dallas Dressler, shall share legal custody of the mil10r Child, Ashley Nicole Favinger, born
March 11, 1989. The Maternal Grand parents and Mother shall have an equal right, to be
exercised jointly with the others, to make all major non-E:jmergency decisions affecting the
Child's general well-being including, but not limited to, all decisions regarding her health,
education and religion. In the event that the parties cantlot agree, the right and responsibility
of making the final decisions shall be in Brenda and Dallas Dressler. Pursuant to the terms of
this paragraph, each Maternal Grandparent and Mother shall be entitled to all records and
information pertaining to the Child including, but not limited to, school and medical records and
information. To the extent the Maternal Grandparent and Mother have possession of any such
records or information, that party shall be required to share the same, or copies thereof, with
the other parent within such reasonable time as to make the records and information of
reasonable use to the other party.
2. Physical Custody. Primary physical custody of the minor Child, Ashley Nicole
Favinger, born March 11, 1989, shall be in the Maternal Grandparents, Brenda and Dallas
Dressler. Mother shall have partial custody at such times as the parties shall mutually agree.
Father shall have periods of partial custody at such times as the parties shall mutually agree.
3. This Order is temporary in nature and supercedes all previous Orders of Court with
regard to custody of the minor Child. This Order shall be modifiable upon proper petition filed
with the Court.
Dis!:
~
~#"~ "
Jane M. Alexander, Esquire, 148 S. Baltimore Street, PO Box 421, Dillsburg, P
J. Christian Ness, Esquire, 43 N. Duke Street, York, PA 17401
Tina M. Wolf, 40 Bayberry Drive, Mechanicsburg, PA 17050
~-,
',-'"
"
",
",
- "
J [\~
17019-0421 \' ~,O
~? \D' ~
,'~illr"
..~
,,'~.".-
~~~~.IMliiIIiiI_~
1~J~'
~....".._~_~;;I
,~.p.
_ '~'" . ~.. "J ~
*iIIIo~1!iiII
t. .' ,~;
,~ ~
rILt'DcOfF1CE
^,_ 'P ,~ rl"r\"" '^NOTADV
lj:-' ! (T \^,:",.,~,; !"1,U ttMr\l
00 OCT 3 0 M~ 10: I 0
CUMBERLAND COUNT'<
PENNSYLVANIA
" .-
-..,
III
~,,;
;
i
,
II
:1
:i
, 'c ~ ,
..
.
BRENDA & DALLAS DRESSLER, H/W,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-4619
vs.
THOMAS BRIGGS & TINA M. WOLF,
Natural Parents,
Defendants
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
Ashley Nicole Favinger
March 11, 1989
Mother, and Maternal
Grandparents
2. A Conciliation Conference was held on October 10, 2000, with the following
individuals in attendance: Brenda & Dallas Dressler, the Maternal Grandparents, and their
counsel, Jane M. Alexander, Esquire. The Mother, Tina M. Wolf, appeared pro se. The
Defendant, Thomas Briggs, did not appear. Although the Custody Conciliator has
correspondence from J. Christian Ness, Esquire indicating that he represented Mr. Briggs, His
counsel, did not appear. The Conciliation was rescheduled from a date on July 26, 2000, at
the request of the Plaintiff and the new time was coordinated with counsel for Mr. Briggs and
the Dresslers. A copy of the Order scheduling the Conciliation Conference for October 10,
2000, was sent to counsel by the Conciliator on August 22, 2000.
3. The parties in attendance reached an agreement in the form of an Order as
attached.
Date
)V!J4/l-nrD
.
~[ ~(jJ~ @---c
Melissa PeeYGreevy, Esquire
Custody Conciliator
, [ ~
,