HomeMy WebLinkAbout97-00567
/"1\
JOAN HARRISON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
.
.
V
:CIVIL ACTION - LAW
.
.
RICHELLE A. HARRISON,
and BYRON HALL,
Defendants
:
:NO: 97 - 567 CIVIL TERM
: CUSTODY
COURT ORDER
AND NOW, this II. tit day of April, 1997,
attached Custody Conciliation Report, it
follows:
upon consideration of the
is ordered and directed as
The Mother, Richelle A. Harrison,
Grandmother, Joan Harrison, shall enjoy
of Janee A. Harrison, born March 16,
Harrison, born May 29, 1992.
2. The parties shall meet again with the Custody Conciliator for
a conference on July 10, 1997. At this Conference the parties
will review the Order above which is to be considered a
temporary Custody Order. The parties retain all rights to
litigate any matters pertaining to custody of the two children
at a hearing if the parties are unable to reach an agreement
on a permanent Order at the next Conciliation Conference.
1.
and the Maternal
shared legal custody
1980 and Aileen J.
BY THE
cc: Robert G. Frey, Esquire
. h 11 . ~~l
R~c e e A. Harr~son ,,/ ,/
5 Carter Place ""18/47
Carlisle, PA 17013 ~
J.
JOAN HARRISON,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
.
.
V
:CIVIL ACTION - LAW
.
.
RICHELLE A. HARRISON,
and BYRON HALL,
Defendants
.
.
:NO: 97 - 567 CIVIL TERM
: CUSTODY
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the
following report:
1. The pertinent information pertaining to the children who are
the subject of this litigation is as follows:
Aileen J. Harrison, born May 29, 1992 and Janee A. Harrison,
born March 16, 1980.
2. A Conciliation Conf13rence was held on April 10, 1997, with the
following individuals in attendance:
The Maternal Grandmother, Joan Harrison, with her counsel,
Robert G. Frey, Esquire. The Mother, Richelle A. Harrison,
who appeared without counsel. The Father of Janee A.
Harrison, Byron Hall, did not appear although he was served
with notice of the hearing and we understand from Richelle A.
Harrison that Mr. Hall knew about the hearing. The Father for
Aileen J. Harrison is unknown.
3. The parties agreed to the entry of an Order in the form as
attached.
t/jvlr7
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACfION - LAW
NO. 97- q '7 - S'l. 7 CIVIL TERM
CUSTODY
Joan Harrison,
Plaintiff
Rlchelle A. Harrison,
and Byron Hall,
Defendants
ORDER OF COURT
AND NOW, this 1../' ( ~ 1 d~8numy<--[.9Ij-1-
upon consideration of the allached complaint, it is hereby directed thUlthe parties and their
respective counsel appear before ~v ~"~ 'f.., (,.; I" 1/ t' fq, ,the conciliator. at <1, (".... ~ " I..J
(.,o~1 (c.,Hc.\~ I lin Fl.", ,D. fN~", fI,'''' C b'l' d C t
L . urn er an oun y.
, r1\ A' I
Pennsylvaniaonthe \0 day of I'r, ,I997,at g:...O o'c1ock~,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 pennunent order,
FOR THE COURT,
By: J!~I j( ,g!~# PSf' /'11.{
Custody Conciliator I
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990, For information abouot accessible facilities and
reasonable accomodations available to disabled individuals having business before the court,
please contact our office (Sec Court Administrator Office listed below), All arrangemcnts must be
made at least 72 hours prior to any hearing or business beforc the court. You must allend the
scheduled conference or hearing,
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
COURTHOUSE, FOURTH FLOOR
CARLISLE, PENNSYLVANIA 17013
(717) 240-6200
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
Joan HarrIson,
Plaintiff
Rlchelle A. HarrIson,
and Byron Hall,
Defendants
NO. 97- S't.?
CUSTODY
CIVIL TERM
COMPLAINT FOR CUSTODY PURSUANT TO 23 Pa.C.S.A, II 5313 Ihl
AND NOW comes Joan Harrison, by and through her attorneys, Frey & Tiley, and states
as follows:
I. Plaintiff is Joan Harrison, an aduh individual. currently residing at 5 Carter Place,
Carlisle, Cumberland County, Pennsylvania.
2. Defendant Richelle A. Harrison, is an adult individual, currently residing at
Cumberland County Prison. Middlesex Township. Cumberland County, Pennsylvania. Plaintiff
is unaware of Defendant Richelle A. Harrison having any permanent address or residence.
3. DefenduntByron Hall is an adult individual whose last known domicile was the City
of Harrisburg. Dauphin County. Pennsylvania. Plaintiff is unaware of Defendant Byron Hall's
address but believes it to be 2122 Susquehanna. Harrisburg. Pennsylvania.
4. Defendant Richelle A. Harrison is the natural parent of Janee A. Harrison. born March
16, 1980. and Aileen J. Harrison. born May 29. 1992. Defendant Byron Hall is the natural parent
of Janeee A. Harrison, born as aforesaid.
The children were born out of wedlock.
The children are presently in the custody of Joan Harrison. the maternal grandmother
and Plaintiff herein. who resides as aforesaid.
During the past five years. or since the children's birth. the children have resided
with the following persons at the following addresses for the following periods of time:
NAME
Joan Harrison
Janee A. Harrison
Aileen J. Harrison
ADDRESS
5 Carter Place
Carlisle. PA
DATE
all of the
past 5 years
The natural mother of the children is Richelle A. Harrison. whose current residence is
Cumberland County Prison. but is not known to have a permanent residence. She is
believed to be unmarried.
The natural father of Aileen J. Harrison is unknown. No male person purporting to
be the father of Aileen J. Harrison has ever contacted Plaintiff or seen her while she has
been in the physical custody of Plaintiff. Plaintiff is unaware of any person paying child
support for either child.
The natural father of Janee A. Harrison is Byron Hall. Plaintiff is unaware of Byron
Hall's address but believes it may be 2122 Susquehanna Road, Harrisburg. Dauphin County
Pennsylvania.
5. The relationship of the Plaintiff to the child is that of maternal grandmother. The Plaintiff
resides with the following persons:
NAME RELATIONSHiP
Janee A. Harrison
Aileen J. Harrison
granddaughter
granddaughter
6. The relationship of the Dcfendantto the child is that of Mother. The Defendant resides
with the following persons:
NAME RELATIONSHIP
Unknown
7. Plaintiff has not participated as a party or witness, or in any other capacity in other
litigation. concerning the custody of the child in this or in any other Court.
Plaintiff has no information of a custody proceeding concerning the child pending in a Court
of this Commonwealth.
8. The best interest and permanent welfare of the children will be served by granting the
relief requested because:
(a) Plaintiff can provide a more stable homc for the children and has provided thcrn
with a stable home;
(b) During the life of the children. Plaintiff has provided the primary care. custody,
and control of the children;
(c) During the life of the children, Plaintiff has provided the primary physical,
mental, and emotional guidance and the primary physical. mental. and emotional care for the
children;
(d) Plaintiff is a grandparent of the children who has genuine eare and concern for
the children;
(e) Plaintiff's rclationship with thc childrcn. bcing thc pcrson responsiblc for acting
as parcnt for the children, having custody of the childrcn, and being rcsponsiblc for all of
their physical, medical, financial and cmotional needs, began with the conscnt of Defendant
Richelle A. Harrison. mother of the children, and
(f) Plaintiff, for a period cxceeding 12 months, has assumed thc role and
responsibilities of parent providing for the physical, emotional and social nceds of the
children and Plaintiff believes it is neccssary to continue this role because of the substantial
risk to the children due to parental neglect and drug or alcohol abuse if the children were
permilled to be in the custody of their mother, Richelle A. Harrison.
9. Each parent whose parental rights to the child have not been terminated and the person
who has physical custody of the child have been named parties to this action. No other pcrsons
are known to have or to claim any right to custody or visitation of the child other than the partics
to this action.
WHEREFORE, Plaintiff requests your Honorable Court to set a time and place for a
hearing at which Plaintiff requests the Court to grant her custody of her grandchildren, Janee A.
Harrison and Aileen 1. Harrison, pursuant to 23 Pa.C.S.A. ~ 53l3(b).
Respectfully sub milled,
Frey & Tilcy
r " < Ii
By: ': ,,~-LJ_
Robert G. Frey ,
5 South Hanover Street
Carlisle, Pennsylvania 17013
(717) 243-5838
7
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I verify that the statements made herein are true and correct and understand that false
statements herein are made subject to the penalties of 18 Pa. C. S. A. ~ 4904 relating to unsworn
falsification to authorities.
Dated: January 10, 1997
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JOAN HARRISON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
.
.
V
:CIVIL ACTION - LAW
:
RICHELLE A. HARRISON,
and BYRON HALL,
Defendants
.
.
:NO: 97 - 567 CIVIL TERM
: CUSTODY
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the
following report:
1. The pertinent information pertaining to the children who are
the subject of this litigation is as follows:
Aileen J. Harrison, born May 29, 1992 and Janee A. Harrison,
born March 16, 1980.
2. A Conciliation Conference was held on April 10, 1997, with the
following individuals in attendance:
The Maternal Grandmother, Joan Harrison, with her counsel,
Robert G. Frey, Esquire. The Mother, Richelle A. Harrison,
who appeared without counsel. The Father of Janee A.
Harrison, Byron Hall, did not appear although he was served
with notice of the hearing and we understand from Richelle A.
Harrison that Mr. Hall knew about the hearing. The Father for
Aileen J. Harrison is unknown.
3. The parties agreed to the entry of an Order in the form as
attached.
<I fiV /(7
DA E
l
J
JAN ~ ./ 199ab{?
Joan Harrison,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL ACTION - LAW
NO. 97-567 CIVIL TERM
v.
Rlchcllc A. Harrison,
and Byron Hall,
Defcndants
CUSTODY
AND NOW. this
ORDER OF COURT
','(1 \"
'-.I. day of} l.l"..:C\ ('I
. 1998
upon consideration of thc attached complaint, it is hereby direclcd that the partics and thcir
respectivc counsel appear before \ \3b\."c \ 'f-. G \ \\ c1.l:'<L thc conciliator. at -\h~ ,-\1-"
n (q"~>ILri.C. Q~ I ,Cumbcrland
County, Pennsylvania on thc \ ~ day of Fe}", r~_, 1998. at \0 : 00 o'c1ock
G.-. m. for a Prc-Hearing Custody Conferencc. At such confcrcnce an effort will bc made to
resolvc the issues in dispute; or if this cannot bc accomplishcd, to definc and narrow thc issues to
be heard by thc court. and to cntcr into a tcmporary ordcr. All children age five or oldcr may also
be present at thc confcrencc. Failurc to appear at the confcrcncc may providc grounds for entry of
a temporary or permanent order.
FOR THE COURT,
By:~~ ^-'~1.0\lOOC~
Custody Conciliator l\b. ') )
The Court of Common Pleas of Cumbcrland County is requircd by law to comply with thc
Amcricans with Disabilities Act of 1990. For information abouot accessible facilities and
reasonable accomodations available to disabled individuals having business beforc the court.
please contact our office (Sce Court Administrator Officc listed below). All arrangcments must be
made at least 72 hours prior to any hearing or business bcfore the court. You must attend thc
schedulcd conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AI<'FORD 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
,~
.
Joan Harrison,
Plaintiff
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 97-567 CIVIL TERM
v.
Rlchelle A. Harrison,
and Byron Hall,
Defcndants
CUSTODY
COMPLAINT FOR CUSTODY PURSUANT TO 23 Pll.C.S,A. II 5313 Ihl
AND NOW comes Joan Harrison. by and through hcr attorncys, Frey & Tilcy. and statcs
as follows:
I. Plaintiff is Joan Harrison, an adult individual, currently rcsiding at 5 Cartcr Plucc.
Carlislc, Cumberland County, Pcnnsylvania.
2. Dcfcndant Richclle A. Harrison, is an adult individuul. whosc mailing addrcss is P.
O. Box 1147, Carlisle, Pennsylvania. Plaintiff is unawarc of Defcndant Richellc A. Harrison
having any permanent address or rcsidcncc. Fromtimc to timc. Dcfendant Richclle A. Harrison
has lived in Plaintiffs home for a period of scveral days. but not on a pcrmancnt basis.
3. Defendant Byron Hall is an adult individual whose Ia.~t known domicilc was thc City
of Harrisburg. Dauphin County. Pennsylvaniu, Plaintiff is unaware of Dcfendant Byron Hall's
address but believes it to be 2122 Susquchanna, Harrisburg. Pennsylv,mia.
4. Defendant Richelle A. Harrison is the natural parcnt of Jancc A. Harrison. born March
16,1980. and Aileen J. Harrison. born Muy 29. 1992. Dcfcndant Byron Hall is thc natural parcnt
of Janee A. Harrison, born as aforesaid.
The children were born out of wcdlock.
The childrcn are presently in the custody of Joan Harrison. the maternal grandmother
and Plaintiff herein, who resides as aforesaid,
During thc past five years. or sincc thc childrcn's birth. the children have residcd
with the following persons at the following uddresses for the following periods of time:
NAME
ADDRESS
nAJ:E
Joan Harrison
Janee A. Harrison
Ailcen J. Harrison
5 Cartcr Placc
Carlislc, PA
all of the
past 5 years
From time to timc. Defendant Richellc A, Harrison has lived in Plaintiffs homc for a period
of several days, but never on il pcrmancnt basis during thc past 5 ycars.
Thc naturalmothcr of thc children is Richcllc A. Harrison, who is not known to havc
a pemlanent rcsidcncc. Shc is unmarried.
Thc natural fathcr of Ailccn 1. Harrison is unknown. No malc pcrson purporting to
be the father of Ailccn J. Harrison has cvcr contactcd Plaintiff or sccn her whilc shc has
been in thc physical custody of Plaintiff. Plaintiff is unawUfC of any pcrson paying child
support for Aileen J. Harrison.
The natural father of Jancc A. Harrison is Byron Hall. Plaillliff is unaware of Byron
Hall's addrcss but belicves it may bc 2122 Susquchanna Road, Harrisburg, Dauphin County
Pcnnsylvania.
5. The relationship of the Plaintiff to thc child is that of maternal grandmothcr. The Plaintiff
resides with the following persons:
NAME RELATIONSHIP
Janee A. Harrison
Aileen J. Harrison
granddaughtcr
granddaughter
From time to time, Defendant Richellc A. Harrison has livcd in Plaintiffs home for a pcriod of
several days, but not on a permanent basis.
6. Thc rclationship of the Dcfendant to thc child is that of Mothcr, Thc Defcndant residcs
with the following persons:
NAME RELATIONSHIP
Unknown
7. A Complaint for Custody was filcd hy Plaintiff to thc above-captioned term and number
on February 4. 1997 to which. after a Conciliation Confcrcncc. an Order of Court was entcred
granting shared custody to Plaintiff and Defendant Richcllc Harrison,
Plaintiff has no information of a custody procccding conccrning the child pending in any
other Court of this Commonwcalth.
8. Thc bcst intercst and pcrmancnt welfare of the children will he scrl'ed hy granting thc
relief requested becausc:
(a) Plaintiff can providc ,I more stable home for thc childrcn and has provitlcd thcm
with a stable home;
(b) During the Iifc of thc children, Plaintiff has providcd thc primary carc. cllstody.
and control of thc children;
(c) During thc life of thc children. Plaintiff has providcd thc primary physical.
mental. and emotional guidancc and the primary physical. mental. and cmotional care for thc
children;
(d) Plaintiff is a grandparent of the children who has gcnuine carc and concern for
the childrcn;
(e) Plaintiffs rclationship with the children. bcing thc pcrson responsible for acting
as parent for the children, having custody of thc childrcn. and being rcsponsible for all of
their physical, medical. financial and emotional needs, began with the conscnt of Dcfcndant
Richelle A. Harrison, mothcr of Ihe childrcn, and
(f) Plaintiff. for a period cxcccding 12 months, in fact for a period cxcecding 6
years, has assumcd the role and rcsponsibilitics of parent providing for thc physical.
emotional and social needs of the childrcn and Plaintiff belicvcs it is necessary to continuc
this role becausc of the substantial risk 10 thc children duc to parcntal neglect and drug or
alcohol abuse if the children werc pcrmillcd to be in thc custody of their mother. Richellc A,
Harrison.
(g) Defendant Byron Hall has not had any contact with his child in the past year and
ha~ not participated in any of the proceedings filcd to the abovc term and number.
(h) Defendant Richellc A. Harrison's contacts with the children have been sporadic.
evcn after the Order of Court granting shared legal custody to her. and have bcen sources of
disruption for the childrcn rathcr than sources of nurturing and care for them.
9. Each parent whose parcntal rights to the child have not been terminatcd and the person
who has physical custody of the child have becn namcd partics to this action. No other persons
are known to have or to claim any right to custody or visitation of thc child other than the partics
to this action.
WHEREto'ORE, Plaintiff rcqucsts your Honorable Court to set a timc and plucc for u
hcaring at which Plaintiff requcsts thc Court to grant hcr custody of hcr grandchildrcn. Jancc A.
Harrison and Ailecn 1. Harrison, pUrSUanllO 23 Pa.C.S.A. ~ 5313(b).
Rcspcctfully submillcd,
Frey & Tilcy
r
r~ _/1.
By:
Robert G. Frcy
5 South Hanovcr Strcct
Carli sic, Pennsylvania 17013
(717) 243-5838
I verify that thc statemcnts made herein are truc and correct and undcrstand that falsc
statements herein are made subject to the pcnaltics of 18 Pa. C. S. A. ~ 4904 relating to unsworn
falsification to authorities.
Dated: January 21. 1998
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JOAN HARRISON,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
.
.
V
:CIVIL ACTION - LAW
.
.
RICHELLE A. HARRISON,
and BYRON HALL,
Defendants
:NO: 97-567
CIVIL TERM
.
.
:IN CUSTODY
Prior Judge: J. Wesley Oler, Jr.
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the
following report:
1. The pertinent information pertaining to the children who are
the subject of this litigation is as follows:
Janee A. Harrison, born March 16, 1980, and Aileen J.
Harrison, born May 29, 1992.
2. A Conciliation Conference was held on February 13, 1998, with
the following individuals in attendance:
The Maternal Grandmother, Joan Harrison, with her counsel,
Robert G. Frey, Esquire.
3. The Mother, Richelle A. Harrison, and the Father, Byron Hall,
did not attend the Conference. The Mother and Father have not
be exercising custody with the children. The Grandmother is
providing the primary custody. There was a prior Order from
April 1997 that granted the Mother shared custody with the
Grandmother. However, the Mother is no longer living with the
Grandmother on a regular basis and she has very little contact
with the children. This information is related by the
Grandmother and her attorney. The Mother and the Father were
not present at the hearing even though notice was provided to
them.
4. The Conciliator recommends an Order in the form as attached.
:.?!lv/f{R
DATE l
Hubert X. Gilroy,
Custody Conciliat
I