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Home My WebLink About97-01200 '" :> . j1 ~i - - .. .:) . \, '" " \ i ) // ~ e ~; ~ . '01 ,<I I i CERTIFICATION OF PFA'S Case Number q7- 1200 ~ ~ Name 1<.~ Ii. 'fJ-tUA..L 111- 87(, fJ~ iP:rn~ ;;(W)..i.L1.A.tAAt!, fA 1733q Victim's Name: 1/~ ;(, 'fJMd Balance Due: $ 7(). !i() 170 State Surcharge 171 state Fine 260 Sheriff Cost ADD $ J..5.00 $ $ DELETE $ $ $ 502 Restitution $ $ Name ~~~ f}~ Address $ L/S; 50 .1 I. -pi :.v fh-': S"t'/97 , ek# 1/7B'7 d~cis. ~i-S/73'/:z. City State Zip Name Address $ City State Zip Name Address $ City . State ____ Zip Prothonotary Office Person Certifying Information f'j~t2. JY~ Date 3/25'1'17 f , Nancy L. Puu I. IN TilE COURT OF COMMON PLEAS OF Plaint iff and on bchalf of hcr minor chi ld: Robcrt Carcy Paul VB. Robert D. Paul, III, Dcfcndunt CUMBERLAND COUNTY, PENNSYLVANIA NO.<)7-12W~IVIL TERM PROT~~rION FROM ABUSE AND CUSTODY TEMPORARY PROTECT ION ORDER AND NOW, this ----3~ day of March, 1997, upon presentation and consideration of thc within Pctition, and upon finding that the plaintiff, Nancy L. Paul, now residing at an undiscloscd location, and the minor child, Robert Carcy Paul, now rcsiding at 876 Pinetown Road, Lewisberry, York County, Pcnnsylvania, are in immediate and prescnt dangcr of abusc from the defcndant, Robcrt D. Paul, III, the following Temporary Ordcr is entcrcd. Law cnforcement agencies, human scrvicc agencies and school districts shall not disclose thc prcsence of thc plaintiff in the jurisdiction or district or furnish any address, telephone number, or any other dcmographic information about thc plaintiff except by further Order of Court. The dcfendant, Robert D. Paul, III, (SSN: 194-56-5139 and date of birth: 7/19/60) now rcsiding at 876 Pinctown Road, Lewisberry, York County, Pcnnsylvaniu, is hereby enjoined from physically abusing the plaintiff, Nancy L. Paul, or the child, or placing them in fcar of abusc. The defcndant is ordered to stay away from the plaintiff's currcnt rcsidencc to which thc plaintiff moved to avoid abuse, und from any othcr rcsidcnce the plaintiff may establish. Thc dcfcndunt is ordcred to rcfruin from having any direct .. '. or indirect contllct with the plllintiff including, but not limited ri to, telephone Ilnd written comlllunications, except for the limited purpose of fllcilitllting custody Ilrrangelllents. ,. , I i I I i The defendllnt is enjoined from harassing Ilnd stlllking the plaintiff and fl'olll harassing the plllintiff's relatives. The defendant is enjoined frolll entering the plaintiff's place of elllployment. The defendant is enjoined from rellloving, damaging, .,,: destroying or selling any property owned jointly by the parties or owned solely by the plaintiff. ^ violation of this Order may subject the defendant to: i) arrest under 23 Pa.C.S. ~6113; ii) a private criminal complaint I I" i._ l~l i I I , under 23 Pa.C.S. ~6113.1; i i i) a charge of indirect criminal contempt under 23 Pa.C.S. ~6114, punishable by imprisonment up to six months and a fine of $100.00-$1,000.00; and iv) civil contempt under 23 Pa.C.S. ~6114.1. Resumption of co-residence on the part of the plaintiff and defendant shall not nullify the provisions of the court order. This Order shllll relllain in effect until modified or terminated by the Court and can be extended beyond its original expiration date if the Court finds that the defendant has committed another act of abuse or has engaged in a pattern or practice that indicates continued risk of harm to the plaintiff, upon abuse removed the min I' child from Ue care end cus oft he defendant is ordered to return thJl-~mmedinteIY t~ ----- ----- ~-#~ custody of the plnintifV1he Sh'Hiff's Depaftment shall assist the plaint i ff in the chi Id Temporary cus~ --- is hereby II th~...I~ff, Nllncy L. -t +...,...,,,, .... ~."? 1/16 day of of Court. Pa - , pending further 0 41.4 .....~ 4-~ A hearing shall be held on this matter~on the ,') ; j ('J :J- March, 1997, at -d_ [1 .m., in Courtroom No. , I County Courthouse, Carlisle, Pennsylvania. Cumberland The plaintiff may proceed without pre-payment of fees pending a further order after the hearing. The Cumberland County Sheriff's Department shall attempt to make service at the plaintiff's request and without pre-payment of fees, but service may be accomplished under any applicable rule of Civil Procedure. This Order shall be docketed in the office of the Prothonotary and forwarded to the Sheriff for service. The Prothonotary shall not send a copy of this Order to the defendant by mail. The appropriate police departments will be provided with certified copies of this Order by the plaintiff's attorney. This Order shall be enforced by any law enforcement agency where a violation occurs by arrest for indirect criminal contempt without warrant upon probable cause that this Order has been violated, whether or not the violation is committed in the presence of the police officer. In the event that an arrest is made under this section, the defendant shnl I be taken without unnecessary delay before the court thllt issued the order. When thllt court is unavailable. the defendllnt shllll be taken before the appropriate district justice. (23 Pa.C.S. M 611.1). Oy the Court, /i/~ Judge '-'-~-, r" "~l r' ""~I, ~I '''.' rJ7 :'... J .1-'j'l 'ih'~" ""i&) h.. .. {, ,.I!..I ,!. . ,.: "'0, . . ~ L\ " J '-, '" ..' I '_~ , . , ., - . Nllncy L. Pllul, I N Till': COlJRT OF COMMON PLEAS OF Pluintiff und on behlllf of her minor chi ld: Robert Carey Paul VR. Robert D. Puul, III, Defendllnt ClJMIIEIO.ANIl COUNTY. PENNSYLVANI A NO. CJ7- CIVIL TERM PROTECT ION FROM ABlJSE AND CUSTODY NOTICE You hllve been sued in court. If you wish to defend agllinst the clllims set forth in the following pllges, you must tllke IIction promptly lifter this Petition, Order and Notice arc served, by appearing personally or by attorney lit the hearing scheduled by the Court IInd presenting to the Court your defenses or objections to the claims set forth against you. You arc warned thut if you fai I to do so the Court may proceed without you, and a judgment muy be entered against you by the Court without further notice for any money cluimed in the Petition or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights importllnt to you. FEES AND COSTS If the case goes to hellring und the judge grllnts u Protection Order, a surcharge of $25.00 wil I be IIssessed against you. You mllY also be required to pay IIttorney fees to Legal Services, Inc. for their representation of the plaintiff. 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 cun get legal help. COURT ADMINISTRATOR, 4th FLOOR CUMDlmLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717) 240-6200 AMERICANS WIT" DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberlund County is required by lllw to comply with the Americans with Disabilities Act of 1990. For information about IIccessible facilities and rellsonllble accommodations aVllilable to disabled individullls having business before the court, please contact our office. All arrllngements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. . . fear of imminent serious bodi Iy injury, and knowingly engaMed in a course of conduct or repeatedly committed acts toward the plaintiff IInd the minor child, under circumstllnces which have plllced the plaint i ff and the chi Id in reasonllhle fellr of bodi Iy injury. This hils inc luded, hut is not I imi ted to, the following specific instllnces of ahuse: II. On or IIbout February 26, 1997, the defendant grabbcd the plllintiff's wrists IInd repelltcdly punched hcr in the chest causing hcr pain. Fearing for her safety, the plaint iff left the mllrital residencc and wcnt to IIn undisclosed location. Later that cvcning, thc defendant wcnt to thc rcsidcnce of thc plaintiff's friend, Anita Dcfibaugh, and threatencd that if hc found thc plaintiff, he would ki II her causing the plaintiff to fear for hcr lifc. b. In or ahout January 1997, thc dcfcndant repeatedly hit thc sevcn ycar old minor child with II mctlll splltula on his barc legs causing him Pllin IInd rcsulting in red welts which remllined for scverlll dllYs. For approximately the last two yellrs, at least oncc II month, on sevcrlll differcnt occasions, the defendllnt repeatcdly hit thc child on the buttocks with a woodcn Pllddle with holcs in it causing the child pain IInd leaving red marks. c. In or about Novembcr 1996, the dcfendant 5-/3-9/ J r&I/1;)' 'J/cttL ,f..] k LtlA~;7 (ii_ ;:3(' It'" I '(;;<)- Jtl-Ivtl if/l:' c 2 .' I , . 7, The plaintiff believes and therefore avers that she and , tbe minor child are in immediate and present danger of abuse from , j, ! ! the defendant, and that they are in need of protection from such /lbuse, 8. The plaintiff desires that the defendant be prohibited from having /lny direct or indirect contact with the plaintiff including, but not limited to, telephone and written communications, except for the limited purpose of facilitating custody arrangements. . 9. The plaintiff desires that the defendant be enjoined from harassing and st/llking the pl/lintiff, and from har/lssing the plaintiff's relatives. 10. The plaintiff desires that the defendant be restr/lined , ! i r' ~ i f I I from entering her place of employment. 11. The plaintiff desires that the defendant be enjoined from removing, damaging, destroying or selling any property owned jointly by the parties or owned solely by the plaintiff. n. EXCI.IISTVE POSSESSION 12, The home which the plaintiff is asking the Court to order the defendant to stay away from is not owned or rented in the defendant's name. 13. The defendant has recently moved into his parents' residence which is located at 876 Pinetown Road, Lewisberry, York County, Pennsylvania. C. REIMBURSEMENT FOR COST OF CASE 14. The plaintiff asks that the defendant be ordered to pay 4 $250.00 1.0 !'p.imburHe on" of Legal ServieeH, Inc. 'H funding SOllrceH for ttle cost. of ] it.i~nt,irlg t~his CUHe. D. TEMPORARY CUSTODY child: 15, The plaintiff seeks temporary custody of the following Name Present. Rp.sldence Robert Carey Paul 876 Plnetown Road Lewisberry, PA The child was not born out of wedlock, Alte 7 yrs. old DOB 6/6/89 The child Is presently in the custody of the defendant, Robert D. Paul, II, who resides at 876 Plnetown Road, Lewlsberry, Pennsylvania. During the past five years, the child has resided with the following persons and at the following addresses: Nume Addresses Plaintiff, defendant, Robert D. Paul, Jr, and Sharon Paul (defendant's parents) 876 Pinetown Rd. Lewisberry, PA Plaintiff and defendant York Haven, PA Plaintiff, defendant, Judy and Barry Myers (plaintiff's parents) 21 Plnehill Ave. Mechanlcsburg, PA Plaintiff and defendent 244 Murlelte Dr, Mechanicsburg, PA Defendant, Robert D. Puul, Jr. and Sharon Paul 86 Pinet.own Rd, Lewlsberry, Pa Dates 1992 to app. 10/94 app. 10/94 to 12/94 1195 to 5/95 5/95 to 2/26/97 2/26/97 present The plaintiff, the mother of the child, currently resides at 5 an undisclosed location. She is married. The defendant. thc father of the child. currently rcsides at 876 pinctown Road. Lcwisbcrry. York County. Pennsylvania. lIc is married. The defendant currently residcs with thc following persons: Name Rclationship Robert Carey Paul Robert D. Paul. Jr. Sharon Paul son father mother 16. On March 4.1997. as thc plaintiff prcpared to file a Protection From Abuse action. Legal services' staff became awarc that the dcfendant had on thc same day filcd a Petition for Special Rclief and Complaint in thc Court of Common pleas of York County, Pennsylvania. No. 97-50-01037-03. An ex parte order was entcred awarding the dcfcndant primary physical custody of the child and providing that thc plaintiff have supcrvised visitation every other weekend from 1:00 p.m. to 5:00 p.m. at the home of thc paternal grandparents and under their supervision. A conciliation conferencc is scheduled for March 20. 1997, in York County. Lcgal Scrvices, Inc. has referrcd the plaintiff to Ccntral Pcnnsylvania Lcgal services. York County, Pro Bono Program for represcntation in chat lcngimg vcnue in York County und in having thc custody case transferred to Cumberland County, A copy of the York County Petition, complaint. and Orders are attached and marked Exhibit A. 6 The plaintiff desires that this court ordcr the dcfcndant to return custody to her pursuant to 23 Pu.C.S. ~6108(u)(4) for rcasons including thc fol lowing: R. The defendant is likely to inflict abuse upon thc child since he has a history of abusc as describcd in paragraph 5(b) of this petition. b. The defcndant has fraudulcntly removed the child from the carc and custody of the plaintiff in that he rcmoved the child from the residence where the parties and the child had resided sincc May 1995, took thc child from the school he had attcnded, and registered him in a school in York County. Furthermorc, the defendant in his petition for ex parte custody relief misrepresentcd the fact that the plaintiff has no home and intended to leave the Commonwealth of Pennsylvania. 18. The plaintiff docs not know of any person not a party to this action who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 19. The best interests and permanent welfare of the minor child will be met if custody is temporarily granted to the plaintiff pending a hearing in this matter for reasons including: a. The plaintiff is a responsible parent who can best take care of the minor child. b. The defendant has shown by his abuse of the 7 plnintiff thnt he is not nn njlproprinte role 1Il0del for the 111 i no I' chi I d . c. The defcndnnt '5 behnvior hns ndversely nffectcd thc chi Id. WHEREFORE, pursuant to the provisions of thc "Protection from Abusc Act" of October 7, 197/i, 23 Pa.C.S. g 6101 tl seQ., liS nmended, the plnintiff prnys this Honorable Court to grant the following rei ief: A. Grant II Tcmporary Order pursunnt to thc "Protcction from Abuse Act:" I. Ordering thc defcndant to rcfrain from Ilbusing the plaintiff and the minor child Ilnd placing them in fear of abuse. 2. Ordering the defendnnt to refrllin from hllving Ilny direct or indirect contnct with thc plaintiff including, but not limited to, telcphone and writtcn communications, cxccpt to facilitate custody arrangements. J. Ordering the defcndant to refrain from harassing Ilnd stalking the plaintiff and from harassing thc plaintiff's rcllltives. 4. Prohibiting the defendant from entering the plaintiff's placc of cmploymcnt. 5. Prohibiting the dcfcndant from removing, damaging, destroying or selling propcrty jointly 8 owned by the parties or owned solely by the plaint i ff, 6. Ordering the defendant to stay uwa~ from the plaintiff's current residence, and any other residence the plaintiff may establish. 7. Ordering the defendant to return the child immediately to the custody of the plaintiff and granting temporary custody of Robert Carey Paul to the plaintiff, Nancy L. Paul, pending further Order of Court. D. Schedule a hearing in accordance with the provisions of the .Protection from Abuse Act,. and, after such hearing, enter an order to be in effect for a period of one year: I. Ordering the defendant to refrain from abusing the plaintiff and the minor child and placing them in fear of abuse. 2. Ordering the defcndant to refrain from having any dircct or indirect contact with the plaintiff including, but not limited to, telephone and writtcn communications, except to facilitate custody arrangemcnts. 3. Ordcring thc defendant to refrain from harassing and stalking the plaintiff and from harassing the plaintiff's rclatives. 4. Prohibiting the defcndant from entering the 9 plaintiff'H place of employment. S. Prohihiting the defendant from removing, damaging, deHtroying or Helling property jointly owned hy the partieH or owned solely by the plaintiff. 6. Ordering the defendant to stay away from the plaintiff's currcnt residencc, and any othcr residencc the plaintiff may establish. 7. Granting custody of the minor child to the plaintiff. 8. Ordcring thc defendant to pay $250.00 to reimburse onc of Legal Services, Inc.'s funding sourccs for the cost of litigating this case. The plaintiff further asks that this Pctition be filed and served without payment of fecs and costs by thc plaintiff, pending a further order at the hearing, and that certified copies of this Petition and Order be delivered to the appropriate policc departments which have jurisdiction to enforce this Order. The plaintiff prays for such other relief as may be just and proper. COUNT II CUSTODY UNDER PENNSYLVANIA CUSTODY LAW 20. The allegations of Count I above are incorporated herein as if fully set forth. 21. Thc best interest and permanent welfare of the minor 10 chi Id wi II be served by grllnting custody in the plllint i ff liS set forth in pllragrllph 19 of the petition. WIIEREFORE, pursullnt to 23 I'II.C.S. M 5301 \'1 !je_'1., IInd other appliclIble rules IInd IIIW, the pi/lint i rr prllYs this 1I0nornble Court to IIward custody of the minor child to her. The plaintiff prays for such other relief liS mllY be just and prope r, I{cspect fu II y submi t tcd, , ~J @UtL(~/' ( JOlin Carey, At tod'lney for Plaint i 1'1' LEGAL SERVICES, INC. 8 Irvine Row Cllrlisle, I'A 17013 (717) 243-9400 1 1 , r I , The above-named plaintiff, Nancy L, Paul, verifies that the statements made in the above Petition are true and correct. The plaintiff understands that false statements herein are made subJect to the penalties of 18 Pa,C.S. ~ 4904 relating to unsworn Date: \.J JLI Jq-! / f rih 1)7(1 W '~'/~~ u1 Na cy L. ul, Plaintiff falsification to authorities. --'-.J~'.l '__ -.-- . IN'ITIE COURT OF COMMON PLEAS OF YORl{ COUNTY. PENNSYLVANIA PLAINTIFF : NO.q?..!;U-OJO~1" OJ ROBERT 0, PAUL, III, v. : CIVIL ACTION. LAW '" ,'", ...J " ';r. t.. :1,> NANCY L. PAUL, ..<: I DEFENDANT : CUSTODY c., ~. . -;" .\ .,' ~. . h- onpq ~. ~',; \~ :.:, AND NOW, to wit, this -.i day of \\1\ ~ 1997, upon conSidera:on '~f the , :'t! foregoing Petition, it is hereby ORDERED and DECREED that: 1. Physical Primary Custody. Appoint physical custody of the minor child, as that term is defined in the Custody Act of 1985, October 30th, P.L. 264, No. 66, g 1,23 Pa. C.S.A,~ 5301,~. shall be in Father until a Custody Conciliation Conference can be held. 2. Partlnl Custody. Partial physical custody as defined in the aforementioned Act shall be in Mother. 3. Partinl Custody Periods, Mother shall have the right to exercise partial physical custody as . follows: a. Supervised visitation at the paternal grandparent's home, located at 876 Pine Town Road, Lewisberry, York County, Pennsylvania. The paternal grandparents, Mr. and Mrs. Robert D. Paul, Jr. shall act as supervisors. b. Said supervised periods of partial physical custody shall occur from I :00 PM until 5 :00 PM every other Saturday and Sunday until further Order of Court, or agreement of parties. ~ O~'~~ u~~ (3;>...vL '\);~ ~~ (s: ~~-:) 8,~ Exhibit ^ OMl"'l.l:l~j~...... '. IN THE COURT OF COMMQli1l-EAS OF YORK COUNTY. PltNNSYLVANIA ROBERT D. PAUL, III : NO, PLAINTIFF v, : CIVIL ACTION. LAW NANCY L. PAUL, DEFENDANT : CUSTODY fLA.lliJ1FF'S PETI]:IONJ"OR SPECIAL RE~mf: AND NOW, TO WIT, this _ day of March 1991 comes Plaintiff, Robert Do Paul, III, by and through his counsel James Q, Keenan, Esquire and files this Petition for Special Relief, and in support thereof avers as follows: I. Plaintiff. Robert D. Paul, III, (hereinafter referred to as "Father"), is an adult individual who currently resides at 816 Pine Town Road, Lewisberry, York County, Pennsylvania 11339. 2. Defendant, Nancy L. Paul, (hereinafter referred to as "Mother"), is an adult individual whose present residence is unknown. Her previous address was 244 MarJette Drive, Mechanicsburg, Cumberland County, Pennsylv;lIlia. 3. Father and Mother were married on August 24, 1988 and are the parents of one (1) minor child, Robert Terry Paul, born June 6, 1989. 4, On or about February 21, 1991, Mother left the marital home without notice to Father and it is . believed that she has moved out of the State of Pennsylvania. I . , ..... . ' . 5. On March 3, 1997 Mother called Newberry Elementary School, the school where the child is enrolled in the second grade, and inquired as to whether or not there was an Order restIicting her flam removing the child from the school. 6. Father believes that Mother is planning to remOve the child from school and remove him from the State of Pennsylvania, 7. Mother has a very transient history. For example, she has held over fifty (50) jobs in the past eight (8) years, nearly all lasted no more than one (1) to three (3) weeks and nearly all were voluntary quits; Mother has no home, no job, and has not even contacted the Falher. child or Paternal Grandparents. 8. Father is filing a Custody Complaint and requesting that a Conciliation Conference be scheduled. A true copy of the Custody Complaint llnd Order and Directive for Conciliation arc auached hereto as. Exhibit II A" and incorporated herein by reference. 9. It is in the child's best interest that n temporary Custody Order be entered until the Conciliation Conference. 10. Since birth the child resided with the Paternal Grandparents and Father and Mother at 876 Pine Town Road, Lewisberry, York County, Pennsylvania 17339 until March 1995. Then the child resided with the Paternal Grandparents again from August 1995 until August 1996. 2 II. Father has been employed at New York Wire for the past four (4) years which is situated in York County, PeMsylvania. 12. TIle Court possesses broad powers to fashion a remedy for special relief pursuant to Pa.R.C.P. ~ 2215.13 which provides that "...thc Court may, on application, or its own mercy, grant appropriate term or special relief. The relief may include...an award of temporary custody." WHEREFORE, Plaintiff respectfully requests your Honorable Court direct: 1. Physical Primary Custody. Appoint physical custody of the minor child, as that term is defined in the Custody Act of 1985, October 30th, P.L. 264, No. 66, ~ 1, 23 Pa. C.S.A.~ 5301,~. shall be in FaUm until a Custody Conciliation Conference can be held. . 2. Partial Custody. Partial physical custody as defined in the aforementioned Act shall be in Mother. 3. partial Custody Periods. Mother shall have the right to exercise partial physical custody as follows: a, Supervised visitation at the paternal grandparent's home, located at 876 Pine Town Road, Lewisberry, York County, PeMsylvania. The paternal grandparents, Mr. and Mrs. Robert D. Paul. Jr. shall act as supervisors. b. Said supervised periods of partial physical custody shall occur from I :00 PM until 5:00 PM every other Saturday and Sunday until further Order of Court, or agreement of parties. DATE: '3.- Jf-q1- BY: "- James. . Keenan, EsqUire Atto y for Plaintiff 30 North George Street York, PeMSylvania 17401 Telephone #: (717) 846.8846 Supreme Court #: 58287 3 IN THE COURT OF COMMON PLEAS OF VORK CO{)~TY. pENNSYLVANIA ROBERT D. PAUL, III, NO. q1}{l iJlot7~'05 \.P -.J PLAINTIFF V. - t" -- -. .' 'v .4. , C.' I ?,'" .. ," - . "T.l "T' -- :r.-' ,,, t:'r '" .., r.: ." ..... '. -. NANCY L. PAUL, DEFENDANT If applicable, name of conciliator previously appointed in this case: ORDER OF COURT AND OIRECTIVE You. NANCV L. PAUL, Defendant, have been sued in Court to obtain custody, partial custody or visitation of the child(ren): Robert Terry Paul, born June 6. 1989. It is hereby Ordered and Directed: 1. 1)1~ I~ .f1Jz.. , Esquire. is hereby assigned to conduct a Conciliation Conference. -vi 2. A Conciliation CjlnfeIence will be held before the assigned Conciliator on th~~1 day of 'r ,/w1A- . 1991.. at q: 00 .IL.M., in the Conference Room, Basement, Government Center, comer of Market and Beaver Streets, York, Pennsylvania. The anticipated length of the Conciliation Conference is one hour. 3. The parties shall appear in person at the Conciliation Conference and shall bring with them all CHILDREN AGE SEVEN (7) OR OLDER. 4. At the Conciliation Conference, an effort will be made to see if the custody and/or visitation situation can be resolved by an agreement between the parties; or if an agreement cannot be reached, to define and narrow the issues and to otherwise reduce the time required for hearing by the Court, then the Conciliator will prepare a Conference Summary Report for further action by the Court pending a hearing to be scheduled at a later date before Judge Penny L. Blackwell, without prejudice to the rights of the purties at such hearing, which all parties and the children shall be ordered to attend. 5. You have the right to be represented by an attorney who may attend the Conciliation Conference with you. If for some reason an attorney has not been secured by the time of the Conciliation Conference, you shall personally appear at the time scheduled for the Conciliation Conference without an attorney. I I i I C 6. If Children's Services is conducting an investigation, their representative shall be subpoenaed by the appropriate attorney to attend the Conciliation Conference. It shall be the responsibility of the attorney subpoenaing the representative to obtain a Court Order or releases from the parties prior to the release of information by the representative. IN THE-COURT UL<<:'OMMON .PLEAS-.9f_YORK COll:'/TY, PENNS\'J.V ANIA IWllERT L>. PAUL. 111, NO. Pl.AINTlFF v. CIVIL ACTION - LAW :>lANey L. PAl;!.. DEFENDANT CUSTODY COMI'LAINT FOR CUSTODY 1. Plaintiff. Robert D. Paul, 111, is an adult individual who currently rcsides ut 876 Pine Town Road, I.cwi~herry. Yurk County. PelIDsylv3nia 17339, 2. Defendant, Nancy L. Puul, is un adult individual whose whereabouts arc unknown. 1 Pluintiff ,ccks cuslUdy uf the following ehildrcn: NA~IE !:'.lY.iSENT ADDRESS DATF. OF RIRTH Rohcrt Terry Paul .... . Jun~ '6, 19!1? 876 Pine TtlWn RUlld Lel~isbel'ry, PA 17339 I .' " 4. '. ~ ;,' .. The child was nut horn out of wedlock. I. ., .. -..... .... 5. The child is presently in the emludy of Plaintiff who resides at 876 Pine Town Road, l.e~~i,berr). y,nk C"lIlll:. Penl1S: Ilani" 1733'), ';'.':.;1" ..':. " '.. _,U ", ;~. 0.;,. ___H... " ",' .. .- . . 6. Durin~ the past five (5) years, the child has resided with the fonowing persons and at the following addresses: PERSON ~ DATES Robert D. Paul, I1I . 876 Pine Town Road 2/27/97 . Present Robert D. Paul, Jr. Lewisberry, PA 17339 Mrs. Robert D. Paul, Jr. Robert D. Paul, III 244 Marlette Drive March 1996 to Nancy L. Paul Mcchanicsburg, P A 2/27/97 Robert D. Paul, I1I 876 Pine Town Road August 1995 .. Nancy L, Paul Lewisberry, PA 17339 to March 1996 Robert D. Paul, Jr. Mrs. Robert D. Paul, Jr. Robert D. Paul, 1Il York County, PA March 1995 to Nancy L. Paul August 1995 Robert D. Paul, III 876 Pine Town Road June 6, 1989 Nancy L. Paul Lewisberry, PA 17339 to March 1995 Robert D. Paul, Jr. Mrs. Robert 0, Paul, Jr. 7. The relationship of Plaintiff to the child is that of Father. Plaintiff currently resides with the following persons: NAME Rf;LA TIONSHIP Robert D, Paul, Jr. Mrs. Robert D. Paul, Jr. Robert Terry Paul Father Mother Son : . d. Presently the child is residing with the Father and his Paternal Grandparents with whom he has resided the majority of his life. Tilis situation provides the stability that the child needs. Further, he has been enrolled in the second grade at Newberry Elementary School. e. Father has been told by the Maternal Grandmother that the Mother has moved out of the Commonwealth of PeIU1sylvania. f. Mother does not have a stable residence. g. Mother does not have any employment. h, The child is familiar with his present neighborhood and has friends with whom he plays. 13. Each parent whose parental rights to the child have not terminated, and any person who has physical custody of the child has been named as a party to this action. WHEREFORE, Plaintiff requests the court to enter an Order as follows: A. Lel!@1 Custody. Joint legal custody of the minor child, as that term is defined in the Custody Act 1985, October 3D, P.L. 264, No 66, Section 1,23 Pa.C.S.A. 5301 ~ ~ is awarded to both Mother and Father. Joint legal custody means the right of both parents to share in making decisions of importance in the lives of their children, including educational, medical and religious decisions. Both parents shall be entitled to equal access to the children's school, medical and dental records. The parties further agree that in the event they are unable to reach an agreement upon a matter of importance in the child's life, then the decision of Father shall be final, as majority physical custodian. B, Wmary Physical Custody, Primary physical custody of the minor child, as that term is defined in the Custody Act 1985, October 3D, P.L. 264, No 66, Section 1, 23 Pa.C.S.A. 5301 ~ ~ shall be in Father. C. Partlnl Custody, Partial physical custody as defined in the aforementioned act shall be: in Mother. D. ,Partlnl Custody Pcriods~ Mother shall have the right to exercise partial physical custody as follows: (1) Sunervlscd VI~ltation. Until Mother has n permanent address she shall have partial physical custody with supervision at the home of the Paternal Grandparents, 876 Pine Town Road, Lewisberry, Pennsylvania 17339. The periods of supervised partial physical custody shall be as follows: -".-. '- ..~ -~-- . From 1 :00 PM until 5:00 PM Saturday and Sunday on alternate weekends. Aller such permanency hIlS been established, Mother's periods of partial physical custody shall be as follows: (a)' ~ Alternating weekends from Friday at 6:00 PM through Sunday at 6:00 PM. (b) ~ Alternating holidays from 9:00 AM through 7:00 PM, which holidays include: Thanksgiving, New Year's Day, Memorial Day, Fourth of July and Labor Day, and Easter. Mother's holiday visitation shall begin July 4th, ] 997 when her lifestyle is considered by the Court to be stable. .. (d) Christmas, Mother shaH have the right of partial custody during Christmas seasons from December 25 at 1 :00 PM through December 26 at I :00 PM in even years and from December 24 at I :00 PM through December 25 at I :00 PM in odd numbered years. (e) Summer. Two (2) weeks during the summer school vacation upon thirty (30) days advance written notice to Father. These weeks of partial custody shall be exercised in a non-consecutive manner. (C) Notlte. In the event Mother is unable to exercise custody at anyone of "the aforesaid times, she agree.~ to provide Father with at least forty-eight (48) hours advance notice. (g) TransDortatlon, Mother shaH provide aH transportation in exercising the rights of partial custody. (h) Ch\ld'~ Acllvltlcs. Mother shall pennit the child to attend his various extt'acurricular activities while she is exercising her rights of partial custody. If Mother is unable to provide transportation for the child to attend the various extracurricular activities, then Mother shall permit Father to pIovide transportation for the child to and' from the various extracurricular activities. (i) ~ In odd numbered years, Mother shall have rights of partial custody with the child on his birthday between 5:00 PM and 7:00 PM If the birthday falls on a weekday and between 9:00 AM and 1:00 PM If the birthday falls on a weekend. (j) Mother/Father's Dav. Mother shall always have the right of partial custody on Mothe.'s Day, Father ohall always have the right of partial custody on Father's Day, which date shall supersede the standard partial custody schedule, Visitation shall be from 9:00 AM to 5:00 PM. i' ( DATED: E. Bespnnslbllltv of Care Provider, The child care provisions of this Order arc an obligation of the pnrent to provide care for the child while the other parent works. This is not just a convenience to allow the parent to have more time with the child and should not be taken lightly. Failure to provide care for the child because it is not convenient to a parent on a particular day is a failure to meet his or her obligations lIS a parent. Additionally, it places unexpected and unnecessary hardship on the other parent who may have to find someone to care for the child on short notice. Barring any emergency, the parent who Is to be the childcare provider for the child shall give the other parent a minimum of twelve (12) hours notice if he or she Is not going to fulfill their obligati')n lIS child care provider. F, fQ!ltive Rel3tlonshl1l3, Each of the parties and any third party in the presence of the child and the party shnll take all measures deemed advisable to foster a feeling of affectio;;t between the child and the other party and neither will do anything which may estrange the child from the other party or impair the child's high regard for the other party. Neither party shall do anything which may estrange the child from the other party or injure the child's opinion the parent or which may hamper the free and natural development of the child's love and respect for the other parent. G, ~ Both parties shall utilize child restraint scats and/or seat belts when transporting the child by motor vehicle. H. Ak2..hQ.h Mother shall nol consume alcoholic beverages for a period of twelve (12) hours prior to exercising her rights of partial cust(ldy, nor shall she consume alcoholic beverages at, any time during her period of physical custody, whether the child is In her presence or in the presence of a third party. I. Non-Prescrwtion DrulZs. Mother shall not take any drugs for a period of twelve (12) hours prior to exercising her rights of partial custody, nor shall she take any drugs at any time during her period of physical custody, whether the child is in her presence or in the presence of a third party. BY: ( James. Keenan, EsqUire Attorney for Plaintiff 30 North George Street York, PeMsylvania 17401 Telephone #: (717) 846.8846 Supreme Court #: 58287 . " . '.. _...___.':. 1_, AFFIDA:VIT , COMMONWEALTH OF PENNSYLVANIA COUNTY OF yoRK : ss.: The foregoing Complaint for Custody is based upon information which has been gathered by illY counsel in order to represent me in the lawsuit. The language contained in the pleading is that of counsel ': I and not my own. 1 have read the Complaint for Custody and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, , information and belief. To the extent that the content of the document is that of counsel, 1 have relied upon counsel in making this verification. ,. This statement and verification ale made subject to the penalties of 18 Pa.C.S. Section 4904 relating ~ to unsworn falsification to authorities, which provides that ifl knowingly make false averments, 1 may be subject to criminal penalties. Date: ROBERT D. PAUL, III SWORN and SUBSCRIBED to before me, a Notary Public, this _ day of , 1997. Notary Public My Commission Expires: IN TilE COURT OF: COMMON PLEAS OF YOms: COUNTY. PErft/SYLVANIA ROBERT D. PAUL, III. : NO. PLAINTIFF v. : CIVIL ACTION - LAW NANCY L. PAUL, : CUSTODY DEFENDANT CERTIFICATE OF SERVICE I hereby certify that I have on this date served the Plaintiffs Petition for Special Relief on the person and in the manner indicated below, which satisfies the requiIements of Pa.R.C.P. 440. Service by first class, postage paid, United States mail addles sed as follows: Nancy L. Paul 244 Marlette Drive Mechanicsburg, Pennsylvania DATE: ] -Jf .. err . B ny'; . James G. Keenan, Esquire Ado ney for Plaintiff 30 North George Street York, Pennsylvania 17401 Telephone #: (717) 846.8846 SupIeme Court #: 58287 n':t~8::S8~r.:. W THE COURT OF COMMON PLEAS OF YORK COUNJ'Y.~YLVANIA ROBERT D. PAUL, \11, :NO, PLAINTIFF v. : CIVIL ACTION . LAW : CUSTODY NANCY L. PAUL, DEFENDANT ~ERTIFICATE OF SERVICE I hereby certify that 1 have on this date served the Complaint for Custody on the person and in the manner indicated below, which satisfies the requirements of Pa.R.C.P. 440. Service by first class, postage paid, United States mail addressed as fol1ows: Nancy L. Paul 244 Marlelle Drive Mechanicsburg, Pennsylvania DATE: " '4 /' BY:(' .. J/ :' Jam s . Keenan, Esquire Attorney for Plaintiff 30 North George Street York, Pennsylvania 17401 Telephone #: (717) 846-8846 Supreme Court #: 58287 , . . ". ROBERT D. PAUL, III, NO. PLAINTIFF V. NANCY L. PAUL, DEFENDANT If applicable, name of concillator previously appointed in this case: ORDER OF COURT AND D1REC"(IVE , , You, NANCY L. PAUL, Defendant, have been sued in Court to obtain custody, partial custody or visitation of the child(ren): Robert Terry Paul, born June 6, 1989. It is hereby Ordered and Directed: 1. I Esquire, is hereby assigned to conduct a Conciliation Conference. 2. A Conciliation Conference will be held before the assigned Conciliator on the _ day of . 199-, at , _.M., in the Conference Room, Basement, Government Center, comer of Market and Beaver Streets, York, Pennsylvania. The anticipated length of the Conciliation Conference is one hour. 3. The parties shall appear in perEon at the Conciliation Conference and shall bring with them all CHILDREN AGE SEVEN (7) OR OLDER. 4. At the Conciliation Conference, an effort will be made to Bee if the custody andlor visitation situation can be resolved by .an agreement between the parties; or if an agreement cannot be reached, to define and narrow the issues and to otherwise reduce the time required for hearing by tho Court, then the Conciliator will prepare a Conference Summary Report for further action by the Court pending a hearing to be scheduled at a later date before Judge Penny L. Blackwell, without prejudice to the rights of the parties lit such hearing, which all parties and the children shall be ordered to attend. 5. You have the right to be represented by an attorney who may attend the Conciliation Conference with you. If for some reason an attorney has not been secured by the time of the Conciliation Conference, you shall personally appear at the lime scheduled for the Conciliation Conference without an attorney, 6. If Children' s Services is conducting an investigation, theirrepresentative shall be subpoenaed by the appropriate attorney to attend the Conciliation Conference. It shall be the responsibility of the attorney subpoenaing the representative to obtain a Court Order or releases from the parties prior to the release of Information by the representative. Exhibit A . . ! . . 7. If you fail to appear as provided by this Order or to bring the child(ren), an Order for custody, pnrtiaJ custody or visitation may be entered against you, or the Court may issue a warrant for your arrest. 8. The parties and their counsel, if applicable, arc hereby directed to engage in meaningful negotiations to resolve this matter prior to the Conciliation Conference. . YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER 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. AMERICANS WITH OlSAJJlLlTIES ACT OF 1990 THE COURT OF COMMON PLEAS OF YORK 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 THE COUNTY AT (717) 771-9099. FOR THOSE WITH A HEARING IMPAIRMENT, PLEASE CONTACT THE DEAF CENTER AT (717) 848-2585 EXT 329. or EXT. 342 TOO. 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. FOR THE COURT: J. ROBERT CHUK DISTRICT COURT ADMINISTRATOR Lawyer Referral Service of the York County Bar Association York County Bar Center 137 East Market Street York, Pennsylvania 17401 Telephone No. (717) 854-8755 BY THE COURT, Judge .. n ,,:I , . -. ~-f I - j "T:'i ',.' ;n I)}' .J .' I {g ;...:\ (.fl. -.l " ,( ~ ;, -":. ,:iJ , , -- .C) . , "In ~.,' .-:-i " r::- of". ~ . 1..J " ". f, r ., l.., .", ~ c., , , I 1\ I , , olI I '\J I , NANCY L. PAUL VB NO. 97-1200 CIVIL TERM ANSWER' ./ ;,.,,, \ (, lr~'':'" c.l:, (/ l h/) (,;;.,;;.ij ,,.. , I',., ,/') ~ J' I J i, ' '. I .r ..<.. I~ . I( , ~ .. I J, ~(, :.( -;'1 //(-;{t( ,........_J('tj:7 (~ ) "1 / . .. , './' . '(,)(, J.l"..lt;'v,..... 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Mc;u 0/V-f'.70'..W Rei J{tV1 r.,{j(>(('{2 ~ . . .. /lPfi-L 'f'R r. --p 1lJ~ fi oCJeR. \ fl~1f:;t~~"',.n-, ~Jor' tBIlt:f.'f. _;1Ir~t'.!> (PJ. Tt /AjTiFf~..,.{"U?""'}~:/,. /JJJI'-.-<;> :XI fiNe 1l\1\ nve 11\oc~ I p#, /1 nln(t'~ I (, tu pfr,/. . r . -.- ----~ i '! .... .-_..._... - _..... 'H .. .... ~~1 miJ.IeLe-lI-e 1J1~' 111ed,'ft'f/lCsk~,('? !//.}.I Jlf'IlL I 9<jC, ;10 ~(, / <;'. i I ~ j defe~Ij.N:L (..fbr/o'J"tI 'FF defe,JdAoVT'F ,.fo&>RT'I>.PRUL/.::t{?, 5h t.f1~, Pbl.uL.,. ..~_C(rI"'r;o,z/ <t?(, r;nJe~l\J~~ LelAh.,be.cg ~ .;7 .~ 6: 7 it> /1l-s fl',.'/ . . . --. ......- -.." ........- . -. '. .. '. .--. ..... " ..~..._._-..__..-.._.... . -,. ......- j..... . . . "..4. , ,. " .. NANCY L. PAUL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND couNTY, PENNSYLVANIA and on bchalf of hcr minor child: Robcrt Carcy Paul 97-1200 CIVIL VS, PROTECfION FROM ABUSE AND CUSTODY ROBERT D. PAUL, \I1. Dcfendant ORDER AND NOW, this ,,)/ J t day of March, 1997. following hcaring. and careful considcration of thc tcstimony adduced, it is ordcred and direetcd that the defendant, Robcrt D, Paul, \I1. (SSN: 194-56-5139 and datc of birth: 7/19/60) is hereby cnjoined from physically abusing thc plaintiff, Nancy L. Paul, or placing hcr in fear of abuse, A violation of this of this ordcr may subjcct the dcfcndantto: i) arrcst under 23 Pa,C,S. Section 6113; ii) a private criminal complaint undcr 3 Pa.C,S, Section 6113.1; iii) a chargc of indircct criminal contempt under 23 Pa,C.S. Section 6114, punishablc by imprisonmcnt up to six months and a fine of $100,00- $1,000,00; and iv) civil contempt undcr 23 Pa,C.S. Scction 6114,\, Rcsumption of co-rcsidcnce on thc part of thc plaintiff and dcfcndant shall not nullify thc provisions of thc court ordcr, This ordcr shall rcmain in effcct for a pcriod of onc ycar, It is furthcr ordcrcd and dirccted that thc dcfendant pay thc costs of this action togcther with a surchargc of $25.00. Thc appropriatc poliec dcpartmcnts will hc providcd with a copy of this ordcr hy thc plaintifrs atlorncy. This ordcr shall he cnforccd by any law cnforcemcnt agcn~'Y whcrc a violation occurs by arrcst for indircct criminal contcmpt without warrant upon probablc cauSC r I ~ . ~ . , ,. .,. ., ::";_::.'':;--:.J:;-j ~ J I k .: , Dale 3/ 1 . . . Hour To W /1' WJj. ILE you WERE OUT M ,--,.-CnnU Of I:t fj dLJ J:,-14~' (1.17 /) Phone ...,.. coo. PhMt, FAX Ar.. coo. Phon., Telephoned Please Call Will Call aln -: 'ju;~~_J;fi: ~ /m t1..JAfl~ Signed <OAVERY REORDER NO. "me * Made Wilh Recycled Paper ,. NANCY L. PAUL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA and on bchalf of hcr minor child: Robcrt Carcy Paul 97-1200 CIVIL VS. PROTECfION FROM ABUSE AND CUSTODY ROBERT D. PAUL, III, Dcfcndant ORDER AND NOW, this I/"~ day of March, 1997, hcaring hcrcin is continucd and thc partics ordcrcd and dircctcd to appcar for f'uthcr procccdings on Thursday. March 13,1997, at 1:30 p.m, in Courtroom Numbcr 4, Cumbcrland County Courthousc, Carlislc, PA. Pcnding samc, thc tcmporary protcctivc ordcr hcrctoforc cntcrcd shall rcmain in full force and cffcct. BY THE COURT. Joan Carcy, Esquire For thc Plaintiff e-f...... r.,"~cl<.L '3{n I '1'1. ..!. {>, Jamcs Kcenan, Esquirc For thc Dcfcndant :rlm