HomeMy WebLinkAbout00-04749
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ROBERT ERNEST THOMSON
IN TIIE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
PLAINTIFF
V.
KELLY LEE THOMSON
00-4749 CIVIL ACTION LAW
DEFENDANT
IN CUSTODY
ORDER OF COURT
I
AND NOW, this 6TH day of , JOLY ,2000, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear before Dawn S. Snnday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsbnrg,PA 17055 onthe 6TH dayo1EPTEMBE~2000,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 defme 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
Dawn S. Sunday. Esq.tP
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 THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
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
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ROBERT ERNEST THOMSON,
Plaintiff
Vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYL VANIA
NO. 2000- 1/7t/(' Civil Term
KELLY LEE THOMSON,
Defendant
CIVIL ACTION-LAW
ORDER OF COURT
AND NOW, upon consideration of the attached Complaint, it is hereby directed
that the parties and their respective counsel appear before
the Conciliator, on , the day of
2000 at .m. in the office of said conciliator located at
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. Failure to
appear at the conference may provide grounds for the entry of a temporary or
permanent order.
FOR THE COURT:
Date:
BY:
Custody Conciliator
Cc
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.
Cpurt Administrator
Cumberland County Court House
I
One Court House Square
Carlisle, Pa. 17013
(717) 240-6200
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ROBERT ERNEST THOMSON,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
No. 2000 - 'f 7'19 c.wu -r~
KELLY LEE THOMSON,
Defendant
CUSTODY
COMPLAINT FOR CUSTODY
AND NOW, this 30th day of June, 2000, comes Robert Ernest Thomson, by
his attorney, Arthur K. Dils, Esquire, and respectfully requests the following:
1. The Plaintiff, Robert Ernest Thomson, is an adult individual, who currently
resides at 393 Cameron Road, Etters, York County, Pennsylvania.
2. The Defendant, Kelly Lee Thomson, is an adult individual, who currently resides
at 120 South Chestnut Street, Mechanicsburg, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant were married on October 10, 1992 in York County,
Pennsylvania.
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4. As a result of said marriage, three children were born; namely:
Montana Norell Thomson, born July 31, 1996 in Camp Hill;
Joshua Robert Thomson, born April 30, 1994 in Camp Hill; and
Zachary Mason Thomson, born April 26, 1993 in Camp Hill.
5. Plaintiff and Defendant have lived separate and apart since May 9, 2000.
6. Plaintiff has been denied the ~bility to see his children and enjoy partial custody
I
of his chHdren by the Defendant.
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7. Plaintiff believes that the best interest of his children will be served by granting
him primary physical custody of his children.
8. The minor children have resided in Cumberland County, pennsylvania since their
birth.
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9. The Court of Common Pleas of Cumberland County has jurisdiction in this matter
as the Defendant and the minor children reside in Cumberland County, Pennsylvania
and have so resided in said County for a period in excess of six months.
10. Plaintiff knows of no other person with interests in the minor children or hold
such a capacity that they should be a party to this action, other then himself and the
Defendant.
11. There has been no prior action for custody or visitation involving the minor
children herein.
WHEREFORE, Plaintiff respectfully requests your Honorable Court to
grant him primary physical custody of his children.
BY:
hur K. Dils, Esquire
1017 North Front Street
Harrisburg, Pa. 17102
(717) 232-9724
I.D. No. 07056
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VERIfICATION
I verify that the statements mad~ in this Comlj'laint
are true and correct. I understand that false statements h~r~in are made
subject to the penalties of 18 Pa. CS, S~ction 4'.>04 rdating to unsworn falsil-lcation
to authorities.
~..AX-G~ -
Robert Thomson
Date: June 29, 2000
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ROBERT ERNEST THOMSON,
Plaintiff
.
.
IN THE OJURT OF OJMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:
.
.
vs.
.
.
NO. 00-4749
CIVIL TERM
.
.
: CIVIL ACTION - LAW
KELLY LEE THOMSON,
Defendant
.
.
.
.
CUSTODY
~
OODER OF COORT
AND lUI, this -<]tJ\ _ day of _r?~
consideration of the attached CUstody ConcJ.liation Report,
and directed as follows:
, 2000, upon
it is ordered
1. The Father, Robert Ernest Thomson, and the Mother, Kelly Lee
Thomson, shall have shared legal custody of Montana Norell Thomson, born
July 31, 1996, Joshua Robert Thomson, born April 30, 1994, and Zachary
Mason Thomson, bomApril 26, 1993. Each parent shall have an equal right,
to be exercised jointly with the other parent, to make all major
non-emergency decisions affecting the Children's general well-being
including, but not limited to, all decisions regarding their health,
education and religion.
2. The Mother shall have primary J;ilysical custody of the Children.
3. The Father shall have partial physical custody of the Children on
Sunday, September 24, 2000 from 2:00 p.m. until 7:00 p.m., and on Friday,
September 29, 2000 from 4:00 p.m. until 8:00 p.m. Beginning Friday,
October 6, 2000, the Father shall have custody of the Children on
alternating weekends from Friday at 4:30 p.m. through Sunday at 7:00 p.m.
and on the Mondays following the Mother I s weekend periodS of custody, from
4:30 p.m. until 7:00 p.m.
4. On Thanksgiving Day in 2000, the Mother shall have custody of the
Children until 4:00 p.m. and the Father shall have custody of the Children
from 4:00 p.m. until 8:00 p.m. Over the Christmas holiday in 2000, the
Mother shall have custody of the Children from Christmas Eve at 4:00 p.m.
through Christmas Day at 1:00 p.m. and the Father shall have custody on
Christmas Day from 1:00 p.m. until 8:00 p.m.
5. The Mother shall transport the Children to the Father's residence
at the beginning of the first two periods of custody on September 24 and
September 29, 2000. The Father shall return the Children to the Mother's
residence. Thereafter, the parties shall share the responsibility for
providing transportation for exChanges of custody as arranged by agreement.
6. Counsel for either party may contact the Conciliator on or before
December 31, 2000 to schedule an additional CUstody Conciliation Conference
to discuss any necessary adjusrments to the custody arrangements after the
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parties have followed the custody schedule set forth in this Order for a
period of at least two months.
7. This Order is entered pursuant to an agreement of the parties at a
Custody Conciliation Conference. The parties may modify the provisions of
this Order by mutual consent. In the absence of mutual consent, the terms
of this Order shall control.
BY THE COuRT, / /
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cc: Arthur K. Dils, Esquire - Counsel for Father
James A. Miller, Esquire - COunsel for Mother
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ROBERT ERNEST THOMSON, . IN THE OOURT OF OOMMON PLEAS OF
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. . NO. 00-4749 CIVIL TERM
.
:
: CIVIL ACTION - LAW
KELLY LEE THOMSON, .
.
Defendant . CUSTODY
.
CUSTODY CCl!iICILIATIOO SUMMARY REPCRT
IN ACCORDANCE WITH CUMBERLAND COONTY RIlLE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the
subjects of this litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Montana Norell Thomson
Joshua Robert Thomson
Zachary Mason Thomson
July 31, 1996
April 30, 1994
April 26, 1993
Mother
Mother
Mother
2. A Conciliation Conference was held on September 19, 2000, with the
following individuals in attendance: The Father, Robert Ernest Thomson,
with his counsel, Arthur K. Dils, Esquire and the Mother, Kelly Lee
Thomson, with her counsel, James A. Miller, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
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Date
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Dawn S. SUnday, Esquire
Custody Conciliator
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ROBERT ERNEST THOMSON
PLAINTIFF
V.
KELLY LEE THOMSON
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
00-4749 CIVIL ACTION LAW
IN CUSTODY
OlRDER OF COURT
AND NOW, this 4th day of December, 2000, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on the 19th day of December, 2000 , at 3:00 p.m.
for a Pre-Hearing Custody Conference. At such ~onference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to defme 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 TIIE COURT,
By: Isl
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 THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HA VB AN ATIORNEY 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
FILfD-()f~lCE
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CUMBERLAND COUNlY
PENNSYLVANIA
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ROBERT ERNEST THOMSON,
Plaintiffs
Vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYL VANIA
NO. 2000-4749 Civil Term
KELLY LEE THOMSON,
Defendant
CIVIL ACTION-LAW
ORDER OF COURT
AND NOW, upon consideration of the attached Complaint, it is hereby directed
that the parties and their respective counsel appear before
the Conciliator, on , the day of
2000 at .m. in the office of said conciliator located at
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. Failure to
appear at the conference may provide grounds for the entry of a temporary or
permanent order.
FOR THE COURT:
Date:
BY:
Custody Conciliator
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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.
Court Administrator
Cumberland County Court House
One Court House Square
Carlisle, Pa. 17013
(717) 240-6200
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ROBERT ERNEST THOMSON,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYL VANIA
NO. 00-4749 Civil Term
KELLY LEE THOMSON,
CUSTODY
PETITION FOR CONTEMPT AND
MODIFICATION OF CUSTODY ORDER
'7 V '0V
AND NOW, '-' i ' Day of ;V U ,2000, comes Robert Ernest
Thomson, by his attorney, Arthur K. Dils, Esquire, and respectfully avers the
following:
1. The Plaintiff, your Petitioner, is Robert Ernest Thomson, an adult individual,
represented by Arthur K. Dils, Esquire, 1017 North Front Street, Harrisburg,
Pennsylvania.
2. The Defendant, the Respondent, is Kelly Lee Thomson, an adult individual,
represented by James A. Miller, Esquire, 513 N. Second Street, Harrisburg,
Pennsylvania.
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3. Attached hereto and marked Exhibit "A" is a copy of an Order of Court dated
October 3, 2000, wherein custody and partial custody is set forth.
4. The Defendant, Kelly Lee Thomson, the Respondent has previously failed to
comply with said Order of Court.
5. Your Petitioner respectfully requests that the Order of Court dated October 3,
2000 be modified to provide for make-up time in your Petitioner.
WHEREFORE, your Petitioner respectfully requests that the Respondent be
held in contempt of the Order of Court dated October 3, 2000 and that your Petitioner
be provided make-up time.
BY:
rthur K. Dils, Esquire
1017 N. Front Street
Harrisburg, P A. 17102
(717) 232-9724
J.D. No. 07056
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ROBERT ~ 'l!HClMSOO,
Plaintiff
: IN TIlE <XltlR'l! OF <X>>lMCl'l PLEAS OF
: CUMBERLAND COONTY, PENNSYLVANIA
.
.
vs.
: NO. 00-4749 CIVIL TERM
.
.
IELLY LEE ~,
Dlitferl;&ln!:
: ' . C:rrn.. AC'::j;~ ~ LAW
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, 2000, upon
it i~ordered
4. Ckl ihanksgi ving Day in 2000, the Mother shall have custoay of the
Children until 4:00 p.m. and the Father shall have custoay of the Children
fI:aa 4:00 p.llI. mtil 8:00 p.lII. C)ver the d1ristmas holiday in 2000, the
Motherehall have custody of the Children fran Christmas Eve at 4:00 P.III.
through Christmas Day at 1:00 p.m. and the Father shall have custoay on
d1ristmas Day fran 1:00 p.!\I. until 8:00 p.m.
5. The Mother shall transport the Children to the Father's residence
at the beginning of the first two periods of custody on September 24 and
September 29, 2000. The Father shall return the Children to the Mother's
residence. Thereafter, the parties shall share the resporisibility for
providing transportation for exchanges of custody as arranged by agreement.
6. Counsel for either party may CQntact the Conciliator on or before
oeCE!ldJer 31, 2000 to schedule an additiOl'lal. CUstoay Conciliation Conference
to discuss any necessary adjustments to the custody arrangements after the
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parties have followed the cua~,~.~ 'forth in this Order fora
period of at least two IQOl1ths. '~:-",.'~!"i"~~i>':'" ,
7. nus Order is entered ~suant to 'an ag..--nt of.the parties at a
Cus~ CClnci11aticn COnference. b parties may IIIodify the provisions of
this ~ by DUtual consent. In theftl:)senoe, of'JIUtualoonsent, the terms
of ,this ,OI:der shall centrol.
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oc: Arthur K. Oils, Esquire - Counsel for Father
James A. ,)If ller, Esquire ,- ,~, for 'Mcltber
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and the seal of sa' Court at Carli$le, Pa.
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ROBERT ERNEST T~,
Plaintiff
: ~!!,'BE ,.CXXlRT OF ~ PLEAs OF
: CDlBERLAND CXXlNTY,' PENNsn.VANIA
vs.
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.
.
.
: NO.' 00-4749 CIVIL TERM
KELLY LEE 1'IDI.SC:N,
Defendant
:' CIVIL ACTICN - LAW
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1915.3-8, the mdersigned Cust:ody'(~~~Il~Submits the following report:
1. 1be pertinent infOX'l\latt'at 'concerning' the ali.ldren who are the
subjects of this litigation is as fo.llows:
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Montana Norell Thomson
Joshua Robert ihanson
Zachary Mason Thanson
July 31,1996
April 30,1994
Apdl ;26, 1~3
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alRRI!Im.y IN ~wr QI!'
Mothel;
Mother
Mother
2. A Conciliation Conferenoewas held em September 19, 2000, with the
following individuals in attendance:'" The 'Father, Robert Ernest Thomsem,
with his counsel, Arthur K. Oils, Esquire and the Mother, Kelly Lee
ihanson, with her counsel, James 1,. Miller, Esquire.
3. b parties agreed to entry of an Order in the form as attached.
&J/J~ d<' ~O
Date
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Dawn s. SUnday, Esqu re /
Custody Conciliator
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VERIfICATION
I verify that the statements made in this Ie? poJU HHL 0fVrer>1 P T
are true and correct. I understand that false statements herein are made subject
to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
~-~
ROBERT E. THOMSON
Date: 10 -/9-eJO
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ROBERT ERNEST THOMSON,
Plaintiff
:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
.
vs.
: NO. 00-4749 CIVIL TERM
:
KELLY LEE THOMSON,
Defendant
: CIVIL AcrION - LAW
: IN CUSTODY
ORDER OF OOURT
day of ~, 2000,
Custody Conciliation Report, it is
AND NCkl, this ---z....'l
upon consideratioon of the attached
ordered and directed as follows:
1. The prior Order of this Court dated October 3, 2000 shall continue
in effect as modified by this Order.
2. The parties shall engage in a course of counseling/mediation at
Inner Works for a minimum of six sessions. The purpose of the
counseling/mediation shall be to assist the parties in developing
sufficient comrmmication and cooperation to enable the parties to
effectively coparent their Children. The parties shall follow the
recorrnnendations of the counselor with regard to the frequency and duration
of the sessions. The Father shall be responsible for all costs of the
cOunseling/mediation. Both parties shall contact the counselor within 15
days of the date of this Order to schedule the first individual or joint
session.
3. In the event the Father obtains separate counseling for the Father
and the Children, the Mother shall cooperate in making the Children
available for the scheduled sessions.
4. Paragraph 3 of the Order dated October 3, 2000 shall be replaced
with the following provision:
The Father shall have partial physical custody of the Children on
alternating weekends from Friday at 4:30 p.m. through Sunday at 7:00 p.m.
and on every Wednesday from 4:30 p.m. until 7:00 p.m.
5. This Order is entered pursuant to an agreement of the parties at a
custody Conciliation Conference. The parties may modify the provisions of
this Order by mutual consent. In the absence of mutual consent, the terms
of this Order shall control.
cc: Arthur K. Dils, Esquire - Counsel for Father
Kelly Lee Thomson, Mother
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ROBERT ERNEST THOMSON, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs. . NO. 00-4749 CIVIL TERM
.
:
KELLY LEE THOMSON, . CIVIL ACTION - LAW
.
Defendant : IN CUSTODY
PRIOR JUDGE: Edgar B. Bayley
CUS'.l'ODY <X:tiCILIATICN SUMMARY REPCRr
IN ACCmDJ\NCE WITH CUMBERLAND COON'l.'Y RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the
subjects of this litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUS'.l'ODY OF
zachary Mason Thomson
Joshua Robert Thomson
Montana Norell Thomson
April 26, 1993
April 30, 1994
July 31, 1996
Mother
Mother
Mother
2. A Conciliation Conference was held on December 19, 2000, with the
following individuals in attendance: The Father, Robert Ernest Thomson,
with his counsel, Arthur K. Dils, Esquire, and the Mother, Kelly Lee
Thomson, who is not represented by counsel in this matter.
3.
The parties agreed to entry of an Order in the form as attached.
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Custody Conciliator
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Robert Ernest Thomson,
Plaintiff
IN THE COURT OF COMMON PLEAS
Cumberland COUNTY, PENNSYLVANIA
vs.
NO: 2000-4749 Civil Term
Kelly Lee Thomson,
Defendant
Civil Action - Law
In CUSTODY
PRAECIPE
PROTHONOTARY:
Please withdraw the appearance of James A. Miller, Esquire, as counsel for the
Defendant in the above matter.
Dated: ') fi.-( I /J I t~
. er, Esquire
2010Ma et Street
C '1l,PAI7011
(717) 737-6400
Please enter the appearance of Jane Alexander, Esquire, as counsel for Defendant
in the above matter.
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ROBERT ERNEST THOMSON
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
00-4749 CIVIL ACTION LAW
KELLY LEE THOMSON
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW, Monday, April 22, 2002 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, May 15,2002 at 10:00 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 defme 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 COllrt hereby directs the parties to furnish auy and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: Isl
Dawn S. Sunday. Esq.
Custody Conciliator
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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 THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HA VB 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
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ROBERT ERNEST THOMSON
PLAINTIFF
) IN THE COURT OF COMMON PLEAS OF
) CUMBERLAND COUNTY
)
)
)
) 00-4749 CIVIL ACTION LAW
)
)
) IN CUSTODY
v.
KELLY LEE THOMSON
DEFENDANT
ORDER OF COURT
You, Kelly L. Thomson, Defendant, have been sued in court to modifY custody, of the
following children:
ZacharyM. Thomson, born April 28,1993, Joshua R. Thomson, born April 30, 1994
and Montana N. Thomson, born July 31,1996
You are ordered to appear in person at
, on , 2002, at
.M., for
o a conciliation and mediation conference.
o a pretrial couference
o a hearing before the court.
If you fail to appear as provided by this order, an order for custody, partial custody or
visitation may be entered against you or the court may issue a warrant for your arrest.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HA VB 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, P A 17013
Telephone (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.
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Michael S. Travis
Attorney at Law
4076 Market Street, Suite 209
Camp Hill, PA 17011
(717) 731-9502
ROBERT ERNEST THOMSON
PLAINTIFF
) IN THE COURT OF COMMON PLEAS OF
) CUMBERLAND COUNTY
)
)
)
) 00-4749 CIVIL ACTION LAW
)
)
) IN CUSTODY
V.
KELLY LEE THOMSON
DEFENDANT
PETITION FOR MODIFICATION OF PARTIAL CUSTODY
I. The petition of Robert E. Thomson respectfully represents that on December 27,
2000, an Order of Court was entered for partial custody, a true and correct copy of which is
attached.
2. This Order should be modified because:
Works.
a) Plaintiff has completed the six week counseling/mediation course at Inner
b) Plaintiff wishes to spend more time with his three children, Zachary M.
Thomson, Joshua R. Thomson and Montana N.Thomson born April 28, 1993, April 30, 1994 and
July 31,1996.
3. Plaintiff would like to have several overnight periods of visitation with his
children each week.
WHEREFORE, Petitioner requests that the Court modify the existing Order for partial
custody because it will be in the best interest ofth~
e . raVlS
Attorney for Petitioner
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section
4904 relating to unsworn falsification to authorities.
Dated: 4-/7- 0 1...
ifti{ t~~
obert . Thomson
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llOBERT ERNEST THQ\1SCN,
Plaintiff
: IN THE 0XlRT OF CXXo!MON PLEAS OF
: alMBERLAND OOONTY, PENNSYLVANIA
.
.
vs.
: NO. ClO-4749 CIVIL TERM
.
.
KELLY LEE T!DISOO,
Defendant
: CIVIL AcrICN - LAW
:INCUS'l'ODY
(
amER OJ! CXXIRI.'
AND 1Of, this . 02'1!-' day of ~ , 2000,
upon consideraticon of the attached CUstody Conciliation Report, it is
ordered and directed as follows:
1. ~ prior Order of this Court dated October 3, 2000 shall continue
in effect as llDdified by tIns Order.
2. The parties shall engage in a course of counseling/mediatioo at
Inner Works for a minimum of six sessions. ihe purpose of the
counseling/mediation shall be to assist the parties in developing
sufficient carmunication and cooperatioo to enable the parties to
effectively coparent th:eir, Children. 111e parties shall follow the
recarmendations of the lor with regard to the frequency and duration
of the sessions. The Fa ershall be responsible for all costs of the
counseling/mediation. Both parties shall contact the counselor within 15
days of the date of this Order to schedule the first individual or joint
session. " .
3. In the event the Father obtains separate counseling for the Father
and the Children, the Mother shall cooperate in making the Children
available for the scheduled sessions.
4.' ParagraP'i 3 of the Order dated October 3, 2000 shall be replaced
with the following provision:
'!he Father shall have partial {ilysical custody of the Children on
alternating weekends fran Friday ,at 4:30 p.m. through Sunday at 7:00 p.m.
and 00 every Weanesday fran 4:30 p.m. until 7:00 p.m.
5. This Order is entered pursuant to an agreement, of the parties at a
CUstody Conciliation Conference. ihe parties may ncdify the provisions of
this order by mutual consent. In the absence of mutual consent, the terms
of this order shall control.
BY THE CXXlRT,
cc:
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.. . TRUE COPY FROM RECORD
Arthur K. Oils, Esquire - Counsel for Father In Testimony whereof. I hare unto ~t my hand
Kelly Lee 111anson, Mother and thll ~ of said CO<l=' it .1 Carlisle. POd.
This .;t~y ot_ ,!).mji)
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ROBERT ERNEST THOMSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:
vs.
: NO. 00-4749 CIVIL TERM
:
: CIVIL ACTION - LAW
KELLY LEE THOMSON,
Defendant
:
CUSTODY
OODER. OF CXXJRT
AND r;oi, this 3r1 day of 10ckheR
consideration of the attached Custody Concil1ation Report,
and directed as follows:
, 2000, upon
it is ordered
1. The Father, Robert Ernest Thomson, and the Mother, Kelly Lee
Thomson, shall have shared legal custody of Montana Norell Thomson, born
July 31, 1996, Joshua Robert Thomson, born April 30, 1994, and Zachary
Mason Thomson, born April 26, 1993, Each parent shall have an equal right,
to be exercised jointly with the other parent, to make all major
non-emergency decisions affecting the Children's general well-being
including, but not limited to, all decisions regarding their health,
education and religion.
2. The Mother shall have primary physical custody of the Children.
3. The Father shall have partial physical custody of the Children on
Sunday, September 24, 2000 from 2:00 p.m. until 7:00 p.m., and on Friday,
September 29, 2000 frexn 4:00 p.m. until 8:00 p.m. Beginning Friday,
October 6, 2000, the Father shall have custody of the Children on
alternating weekends frexn Friday at 4:30 p.m. through Sunday at 7:00 p.m.
and on the Mondays following the Mother I s weekend periods of CllstO<'ly' frexn
4:30 p.m. until 7:00 p.m. u__ - -----,--
4. On Thanksgiving Day in 2000, the Mother shall have custody of the
Children until 4:00. p.m. and the Father shall....have custpdy of the Children
from 4:00 p.m. until 8:00 p.m. Over the Christmas holiday in 2000, the
Mother shall have custody of the Children fran Christmas Eve aL 4:00 p.m.
through Christmas Day at 1:00 p.m. and the Father shall have custody on
Christmas Day frexn 1:00 p.m. until 8:00 p.m.
5. The Mother shall transport the Children to the Father I s residence
at the beginning of the first two periods of custody on September 24 and
September 29, 2000. The Father shall return the Children to the Mother's
residence. Thereafter, the parties shall share the responsibility for
providing transportation for exchanges of custody as arranged by agreement.
6. Counsel for either party may contact the Conciliator on or before
December 31, 2000 to schedule an additional Custody Conciliation Conference
to discuss any necessary adjustments to the custody arrangements after the
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part~~f.1~e~e9! lithe custody schedule set forth in this Order for a
peri r--at l""lst ~;'qJmonths.
7. 'Ihis Order is entered pursuant to an agreement of the parties at a
CUstody Conciliation Conference. The parties may modify the provisions of
this order by mutual consent. In the absence of mutual consent, the terms
of this Order shall control.
BY THE COURT,
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cc: Arthur K. Dils, Esquire - Counsel for Father
James A. Miller, Esquire - Counsel for Mother
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and the seat of sai Court at Cajsle, Pa.
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ROBERT ERNEST THOMSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
00-4749
CIVIL ACTION LAW
KELLY LEE THOMSON,
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this 'l..- \ day of .JA~ , 2002,
upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
L The prior Order of this Court dated December 27,2000 shall continue in effect as modified
by this Order.
2, The parties shall participate in a course of counseling with Deborah L. Salem, MHS, CAC,
or other professional selected by agreement. The purpose of the counseling shall be to assist the
parties in developing sufficient communication and cooperation to enable them to effectively co-parent
their Children and to resolve conflicts concerning the custody arrangements. The parties shall attend a
minimum of 4 joint sessions. All costs of counseling which are not covered by insurance shall be
shared equally between the parties.
3, During the summer school break in 2002, the Father's periods of partial custody shall be
extended as follows: The Father shall have custody of the Children on alternating weekends from
Friday at 4:30 p.m. through Monday before work at 7:30 a.m. and during every week from Wednesday
at 4:30 p,m. through Thursday before work at 7:30 a.m.
4, Each party shall be entitled to have custody of the Children for two non-consecutive weeks
during the summer school break each year upon providing at least 60 days advance notice to the other
party. The party providing notice first shall be entitled to preference on his or her selection of vacation
dates. In 2002, the parties agree that the Mother shall have her first period of vacation custody from
June IS through June 22 and the Father shall have his first period of vacation custody from June 28
through July 7.
5, Both parties shall ensure that the Children attend their regularly scheduled activities during
his or her periods of custody.
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6. Neither party shall seek a modification of the current Child Support Order based on the
expansion of the Father's periods of partial custody set forth in this Order.
7. Within 60 days of completion of the co-parenting counseling, in the event the parties have
not resolved all outstanding custody issues by agreement, counsel for either party may contact the
Conciliator to schedule an additional Custody Conciliation Conference.
8. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation
Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control._" .//l
BY THE couRT \:>i/
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Edgar B. Bayley,
J.
cc~ichael S. Travis, Esquire - Counsel for Father /
Aane M. Alexander, Esquire - Counsel for Mother
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ROBERT ERNEST THOMSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
00-4749
CNIL ACTION LAW
KELLY LEE THOMSON,
Defendant
IN CUSTODY
PRIOR JUDGE: Edgar B. Bayley
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
I. The pertinent information concerning the Children who are the subjects of this litigation is
as follows:
NAME
DATE OF JlURTH
CURRENTLY IN CUSTODY OF
Zachary M. Thomson
Joshua R. Thomson
Montana N. Thomson
April 28, 1993
April 30, 1994
July 31,1996
Mother
Mother
Mother
2. A Conciliation Conference was held on May 15, 2002, with the following individuals in
attendance: The Father, Robert Ernest Thomson, with his counsel, Michael S. Travis, Esquire, and the
Mother, Kelly Lee Thomson, with her counsel, Jane M. Alexander, Esquire.
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Date
3. The parties agreed to entry of an Order in the form as attached.
rQ,~d~
Dawn S. Sunday, EsqUIre
Custody Conciliator
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