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HomeMy WebLinkAbout02-5986 NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ANDREW S. CLARK, Plaintiff v. : CIVIL ACTION - LAW BEVERLY S. CLARK, Defendant . ; NO. 02 - S 1''b0. : IN CUSTODY CIVIL TERM 0 c '\J l'~ f.])\ c-' \.. " ::-:::1 , .1 , -) (' ..-.... r:: " COMPLAINT FOR MODIFICATIONY::'~ OF CUSTODY .J.'-"- "'< -'~ -< : ~l I;:) :::q -~ NOW comes the plaintiff, Andrew S. Clark, by his attorney, Nathan C. Wolf, Esquire, and files this complaint and agreement for modification of custody, representing as follows: 1. The plaintiff, Andrew S. Clark, is an adult individual residing at 32 Lonesome Road, Newville, Cumberland County, Pennsylvania. 2. The defendant. Beverly S. Clark, is an adult individual residing at 312 Gettysburg Street, Dillsburg, York County, Pennsylvania. 3. The parties are the natural parents of a minor child, namely Ruth Ann Clark (born January 22, 1998, age 4 years). 4. The child resided with the parties from the birth of the child until the parties' separation in September, 2000. The child has resided with mother since the parties'separation. 5. The parties previously entered into an agreement as to custody of the child as part of divorce proceedings which was made an Order of Court issued February 7,2000, by the Honorable Angela Jewell, of the District Court of the State of New Mexico, County of Bernalillo, Second Judicial District, at docket number DM 99-04163. 6. The plaintiff has no information regarding any other custody proceeding concerning the child pending in a court of this Commonwealth. 7. The plaintiff does not know of a person not a party to the proceedings who as physical custody of the child or claims to have custody or visitation rights with respect to the child. 8. The plaintiff believes and therefore avers that the best interests and permanent welfare of the child require that the parties have joint legal custody of the child, that mother have primary physical custody and that father have periods of temporary custody and visitation with the child. 9. Plaintiff has sought an agreement from defendant to establish a regular schedule for plaintiff to enjoy period of physical and temporary custody of the child and has been unsuccessful to this point in achieving such a schedule. WHEREFORE, the plaintiff, Andrew S. Clark, respectfully requests that this Honorable Court enter an order granting plaintiffs claims to custody as aforesaid. December Ji, 2002 LF, S lainf 35 East HigH eet, Suites 201/202 Carlisle, Pennsylvania 17013-3052 (717) 243-6090 Supreme Court 1.0. No. 87380 VERIFICATION I do hereby verify that the acts set forth in this petition are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: I;;'/It.t /oz I I ~,Qa (SEAL) ANDREW S. CLARK PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA V. 02-5986 CIVIL ACTION LAW BEVERLY S. CLARK DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, December 20, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, January 02, 2003 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR TIIE COURT, By: /s/ YOU SHOULD TAKE THIS PAPER TO YOUR ATIORNEY AT ONCE. IF YOU DO NOT HAVE 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 I r . ~ ~.# ~ ~ ~ Ie?- oe.~/ ,#p ~ ~ ~ec? c?r:'. e/ ~ ~~~~.n l?r7'~'CI JAN 0 9 2003 Cr ANDREW S. CLARK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LA W BEVERL Y S. CLARK, Defendant NO. 02 - 5986 CIVIL IN CUSTODY COURT ORDER " AND NOW, this 10 day of January, 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Andrew S. Clark, and the Mother, Beverly S. Clark, shall enjoy shared legal custody of Ruth Ann Clark, born January 22, 1998. 2. The Mother shall enjoy primary physical custody of the minor child. 3. The Father shall enjoy periods of temporary physical custody with the minor child as follows: A. On three out of four weekends during the day on Saturday from 9:00 a.m. until 6:00 p.m. B. Father shall handle transportation fOJr exchange of custody during the Saturdays he has custody. Father shall ensure he has a driver's license before Father does the driving on this exchange of custody, with the understanding that Father may have a friend drive if Father does not have a license. Father shall also ensure that the appropriate child car seat is provided for transportation. C. If requested by Mother, Father will ~lllow Mother to do an inspection of Father's current living arrangements, upon reasonable notice provided by Mother. D. While Father has custody of the minor child, Father shall allow Mother reasonable telephone contact with the minor child with a short call at some point during the day on that Saturday. Correspondingly, Father shall also enjoy reasonable telephone contact with the minor child when the child is in the Mother's custody, those arrangements to be worked out between the parties. 'v'IN~/\i).8f\1N3d J H, 'n(y\ (i!^'~~i-):.J':JQ;A1n" I\.UV '-v.""" , ''',,' v L 1 :~ Hd 0 i N~r CO 4. Father shall not consume alcohol or be under the influence of alcohol when he has custody of the minor child. s. On the child's birthday, which is January :~2, 1998, Father shall have the opportunity to have custody of the child from Noon until 4:30 p.m. during the day. Father shall handle exchange of custody and deliver the child back to Mother's home on that date. 6. Legal counsel for the parties shall conduct a telephone custody conciliation conference call with the conciliator on Thursday, March 6, 2003 at 8:30 a.m. The purpose of this conference call shall be to address the progress of Father's periods of temporary custody with the minor child to ensure Father has been remaining sober and to determine if Father's periods of temporary custody should expand. The conciliator will also address at that time whether there are any reasons to cut back Father's time of custody depending upon how things are going. The parties shall also address Father's request that transportation for exchange of custody be shared rather than Father handling all of the transportation. In the event the parties are unable to reach an agreement at that time, this case may be scheduled for a hearing with the Court. Also, in the event any problems arise over the next two months, counsel for the Mother may contact the conciliator directly to schedule a expedited telephone custody conciliation conference. BY THE COURT, I /flcL J. cc: Nathan C. Wolf, Esquire Rebecca R. Hughes, Esquire ~ ~ ~~ /" /3 ,03 ANDREW S. CLARK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW BEVERLY S. CLARK, Defendant NO. 02 - 5986 CIVIL IN CUSTODY Prior Judge: 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 infonnation pertaining to the child who is the subject of this litigation is as follows: Ruth Ann Clark, born January 22, 1998. 2. A Conciliation Conference was held on January 2, 2003, with the following individuals in attendance: The Father, Andrew S. Clark, with his counsel, Nathan C. Wolf, Esquire; and the Mother, Beverly S. Clark, with her counsel, Rebecca R. Hughes, Esquire. 3. The parties agree to the entry of an order in the fonn as attached. -ti C({ D' DATE H~G~qWre Custody Con. . lutor FES 2 0 2003 (' ~' ANDREW S. CLARK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW BEVERLY S. CLARK, Defendant NO. 02 - 5986 CIVIL IN CUSTODY COURT ORDER l~ AND NOW, thisK day of February, 2002, the conciliator being advised the parties have reached an agreement, the conciliator relinquishes jurisdiction. BY THE COURT, Qtv Hubert X. GilroX Custody Conc' ator , , 'lflf',1\/lCU8N N3d "i"("',:"(',' "./",: ,:-",.., ','''11''''"\ I'-li'.ii :,f i -" .:~c~::::,~\~ h..J L Z =/1 HV -"7 -'] · ('''' U i.,,,..,, I v... ...J ....\,1 .!n -''''' FEB 1 9 Z003 Yr MICHAEL W. CROSS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-3449 CIVIL TERM WENDY L. MARPOE, CIVIL ACTION - LAW Defendant IN CUSTODY ORDER TO RELINQUISH JURISDICTION AND NOW, this 3rd day of February, 2003, the counsel for parties having requested a thirty (30) day continuance on January 3, 2003, and the Conciliator having received no further request for the Custody Conciliation Conference to reconvene, hereby relinquishes jurisdiction of the above captioned matter. :200401 VIN,,';\lASNN3d }Ji\Jr1()'') r'\r./-:;_'r-i8!f~Jn8 L Z : I f HV 02 83.:1 ro AtfV.LL:.<C:;.. ,_1._!:~.;,~:, ~o 3:; !.i:,': C'i ANDREW S. CLARK, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLANH COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW 2002-5986 - CIVIL TERM BEVERLY S. (CLARK) ORNER, Defendant/Petitioner IN CUSTODY PETITION TO MOnIFY CUSTODY AND NOW comes the Defendant/Petitioner, Beverly S. (Clark) Orner, by his attorneys, Irwin & McKnight, and presents the following Petition to Modify Custody. 1. The Petitioner is Beverly S. (Clark) Orner, an adult individual residing at 310 Oakville Road, Shippensburg, Cumberland County, Pennsylvania 17257. 2. The Respondent is Andrew S. Clark, an adult individual residing at College Park Apartments, Carlisle, Cumberland County, Pennsylvania 17013.. 3. The parties are the natural parents of one (I) minor child, namely Ruth Ann Clark, born January 22, 1998, age 5. 4. The parties are currently governed by a custody Order of Court dated January 10, 2003, 2001, a copy of which is attached hereto and marked as Exhibit "A". 5. The Respondent has been out of prison and has not exerdsed his weekend custody of said minor child. He has begun drinking again and has suggested to the child that he will be taking her to live in New Mexico without the Petitioner's knowledge or consent. He does not have a valid driver's license. 6. The Petitioner desires that primary physical custody of said children remain with Petitioner, with joint legal custody and periods of temporary custody to Respondent as agreed to by the parties. 7. The best interests and permanent welfare of the minor children requires that the Court grant the Petitioner's request as set forth above. WHEREFORE, Petitioner, Beverly S. (Clark) Orm:r, respectfully requests that she retain primary physical custody and shared legal custody of Ruth Ann Clark as provided herein, with periods of temporary custody to Respondent as the parties agree is in the best interest of the child. By: Respectfully submitted, IRWIN &~lGHT G. Mcl<n;gbt, Attorney fiJr Plaintiff 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court 1. D. No. 25476 Date: October 13, 2003 EXHIBIT "A" JAN 0 9 2003 c.... ANDREW S. CLARK, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BEVERLY S. CLARK, Defendant NO. 02 - 5986 CIVIL IN CUSTODY COURT ORDER AND NOW, this JD -<::: day of January, 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Andrew S.Clark, and the Mother, Beverly S. Clark, shall enjoy shared legal custody of Ruth Ann Clark, born January 22, 1998. 2. The Mother shall el\ioy primary physical custody of the minor child. 3. The Father shall enjoy periods of temporary physical custody with the minor child as follows: A. On three out of four weekends during the day on Saturday from 9:00 a.m. until 6:00 p.m. B.' Father shall handle transportation for exchange of custody during the Saturdays he has custody. Father shall ensure he has a driver's license before Father does the driving on this exchange of custody, with the understanding that Father may have a friend drive if Father does not have a license. Father shall also ensure that the appropriate child car seat is provided for transportation. C. If requested by Mother, Father will :~llow Mother to do an inspection of Father's current living arrangfments, upon reasonable notice provided by Mother. D. While Father has custody of the minor child, Father shall allow Mother reasonable telephone contact with the minor child with a short call at some point during the day on that Saturday. Correspondingly, Father shall also el\ioy reasonable t,elephone contact with the minor child when the child is in the Mother"s custody, those arrangements to be worked out between the parties. 4. Father shall not consume alcohol or be under the influence of alcohol when he has custody of the minor child. 5. On the child's birthday, which is January 22, 1998, Father shall have the opportunity to have custody of the child from Noon until 4:30 p.m. during the day. Father shall handle exchange of custody and deliver the child back to Mother's home on that date. 6. Legal counsel for the parties shall conduct a telephone custody conciliation conference call with the conciliator on Thu~sday, March 6, 2003 at 8:30 a.m. The purpose of this conference call shall be to address the progress of Father's periods of temporary custody with the minor child to ensure Father has been remaining sober and to determine if Father's periods of temporary custody should expand. The conciliator will also address at that time whether there are any reasons to cut back Father's time of custody depending upon how things are going. The parties shall also address Fa.ther's request that transportation for exchange of custody be shared rather than Father handling all of the transportation. In the event the parties are unable to reach an agreement at that time, this case may be scheduled for a hearing with the Court. Also, in the event any problems arise over the next two months, counsel for the Mother may contact the conciliator directly to schedule a expedited telephone custody conciliation conference. BY TIlE COURT, /s/;f~J 'u,-- (), 1~4A J. I I cc: Nathan C. Wolf, Esquire Rebecca R. Hughes. Esquire r,""~,':L ~" <; ,;" ~. 11 i " j!' "1 'i::.I ..h.; 'I.,' 1 il!~-t~f~, (L~""7 ,.;2t.'..;"l.. - -f~. . ~~::;~~--- ANDREW S. CLARK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW BEVERLY S. CLARK, Defendant NO. 02 - 5986 CIVIL IN CUSTODY Prior Judge: CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH TIlE CUMBERLAND COUNfY CIVIL RULE OF PROCEDURE 1915.3-8(b),. the undersigned Custody Conciliator submits the following report: 1. The pertinent infonnation pe~ining to the child who is the subject of this litigation is as follows: Ruth Ann Clark, born January 22, 1998. 2. A Conciliation Conference was held on Januliry . 2, 2003, with the following individuals in attendance: The Father, Andrew S. Clark, with his counsel, Nathan C. Wolf, Esquire; and the Mother, Beverly S. Clark, with her counsel, Rebecca R. Hughes, Esquire. 3. The parties agree to the entry of an order in the form as attached. ~[ cd (J ~ DATE Ht1 G~~sqnire Custody Com;mator VERIFICATION The foregoing Petition to Modify Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have head the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. ~jMA-ti J. (C{~~ BEVERL ~ . (CLARK) ORN Date: October 13, 2003 ~ P I' ~ ~ - ~ ~ ~ )-.J '\ ----., ~ ::;> ,... 1" ::> =-.1> ".-.- -<:fr 01 o 8 """"\ () .~; o "'~": o 71 "'~ j ~J' -, '..., .', t, ) ~ rn --I 51 ANDREW S. CLARK PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 02-5986 CIVIL ACTION LAW BEVERLY S. (CLARK) ORNER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, October 20, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, October 31,2003 , the concili tor, at 9:30 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 tempor order. All children age five or older may also be present at the conference. Failure to appear at the conference ma provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existilllg Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinl(. FOR THE COURT, By: Isl Hubert X. Gilmy, Esq. Custody Conciliator u The Court of Common Pleas of Cumberland County is required by law to comply with the America s with Disabilites Act of 1990. For information about accessible facilitit:s and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangement must be made at least 72 hours prior to any hearing or business before the court. You must attend the schedu ed conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORl'o[EY 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-:,166 ~ ~# ~~V'lz/~ ~~~ ~~l4 ~_:m/fP 7- ~ 4.;> /'? ('C7' C7r:' 0/ 87~ 0/ [?? ~ 17/ ~\iiN\I^1'\SNI\'3d A1N: ::Jrr ('\',,!'-""'I:.~r':~,'\ln"') . i'1",-., ry fl :}; IJd n"7 '. JI' r.." . "J. U f,) )\c:J'r/1L' < '.' .j'v' ANDREW S. CLARK, Plaintiff NO~ lDW IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW BEVERLY S. ORNER, Defendant NO. 2002 - 5986 CIVIL IN CUSTODY COURT ORDER ~ AND NOW, this ,.t day of J!llgyl!ftlher, 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that this court's order of January 10, 2003 is vacated and replaced with the following temporary order: 1. The Mother, Beverly S. Orner, shall enjoy legal and physical cnstody of Ruth Ann Clark, born January 22, 1998. 2. The Father, Andrew S. Clark, shall enjoy periods of temporary physical custody with the minor child at such times and under such circumstances as agreed upon by the parties. 3. In the event Father desires to modify this order and obtain a more specific visitation schedule and obtain an order specifying that he has shared legal custody, Father may either petition the court to have the case again referred to the conciliator or legal counsel for the Father may contact the conciliator directly via a letter and request that a cu~tody conciliation conference be scheduled. BY TIlE COURT, 79/ J. cc: Marcus A. McKnight, III, Esquire Nathan C. Wolf, Esquire Andrew S. Clark P.O. Box 248 Plainfield, PA 17081 ~r~"'- /;1 ,0 I ,(}3 Cf-. . . '. , lJN~drm La :11 \oIV ,- 330 to J..W.l.ONONGl:ld3ru :lO 3:)I~1~ ..~ . - . ' ANDREW S. CLARK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW BEVERLY S. ORNER, Defendant NO. 2002 - 5986 CIVIL IN CUSTODY Prior Judge: Kevin A. Hess 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 infonnation pertaining to the child who is the subject of this litigation is as follows: Ruth Ann Clark, born January 22, 1998. 2. A Conciliation Conference was held on November 14, 2003, with the following individuals in attendance: The Mother, Beverly S. Orner, with her counsel, Marcus A. McKnight, Esquire; and Attorney Nathan Wolf who appeared on behalf of the Father. 3. Mother asserts that Father has not seen the child since June of this year and that he has not had any contact at all with the Mother or child. Attorney Wolf attended the conference because he is attorney of record, but indicated that the Father had not been in contact with him since at least June. The Mother is merely seeking a temporary order confinning physical and legal custody in her subject, however, to future modification, in the event Father comes back into the picture. 4. The conciliator recommends the entry of an order in the fonn as attached. ~iko/ ~7 ANDREW S. CLARK, Plaintiff '" l' fl1 ?J)O~/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW s'i~ NO.2002-l9fl(f IN CUSTODY BEVERLY S. ORNER, Defendant COURT ORDER AND NOW, this z ..; day of "",..,.,J., , 2005, upon consideration of the attached Custody Conciliation report, it is ordered that this Court's prior Order of December 1, 2003 shall remain in effect subject to the following modifications: 1. The father shall participate in counseling with the Family Counseling Clinic where the minor child is currently participating in counseling. The goal of this counseling shall be for the father and child to be reunited with the intent that the counselor will facilitate contact between the father and the minor child and that this contact shall be progressive in nature such that father will ultimately be able to spend some meaningful visitation with the minor child in an unsupervised situation. The parties shall cooperate between themselves with respect to the scheduling of these counseling sessions and it is the desire that the counselor facilitate father getting involved with the child on a weekly basis for counseling initially in order to address any concerns the minor child may have and in order to facilitate a reunion of the father and the daughter. 2. After this counseling has continued for approximately sixty days and in the event that the parties are unable to reach an agreement on a more expanded visitation Order for the father, counsel for the parties or the parties themselves may contact the Conciliator in writing requesting that another Custody Conciliation Conference be scheduled. BY THE COURT, CC~cl(mght, Esquire ~drew S. Clark ~ n3-~5 Oll "1 !,LJ "- 11\1/1 on07 .,J ....... ,~, (,., G... R :J";:\A Ftc ....,'!. :;i11. ~{J::~,:.nJT:! ANDREW S. CLARK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW BEVERLY S. ORNER, Defendant 'J'n\.o NO. 2002-~ IN 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 child who is the subject of this litigation is as follows: Ruth Ann Clark, born January 22, 1998. 2. A Conciliation Conference was held on February 24, 2005, with the following individuals in attendance: The Mother, Beverly S. Orner, with her counsel, Marcus A. McKnight, Esquire, and the Father, Andrew S. Clark, who appeared without counsel. 3. On tbe Conciliator's recommendation, the parties agree to the entry of an Order in the form as attached. :J.d g~ OS DATE c:;!f vA Hubert X. Gilroy, squire Custody Conc" or ANDREW S. CLARK, Plaintiff v BEVERL Y S. ORNER, Defendant CUMBERLAND COUNTY COUHT ADMINISTRATOR ONE COURTHOUSE SOUARE CARLISLE, PA 17013 NOV 2. 5 1003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NO. 2002 - 5986 CIVIL IN CUSTODY r(lTTRT (lRDF.R U.S. PI Andrew S. Clark P.O. Box 248 Plainfield, PA 17081 CLAR2~e* i708i370i i305 16 03/ RETURN TO SENDER CLARK 'ANDREW BOX CLOSED UNABLE TO FORWARD RETURN TO SENDER i 7;) e 11i~'i=s.:',..ffi::':'2.~. i",il\,,,Jii,,,,,,j\,,i\,,,II,,,i1,,,i.i,,I\,i,\,,i,j,,i,i,,\ (') , ........ ANDREW S. CLARK Plaintiff, vs. : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA p), 51~ NO. 92 1986 CIVIL TERM BEVERLY S. ORNER Defendant, IN CUSTODY PRAECIPE FOR ENTRY OF APPEARANCE To Curtis R, Long, Prothonotary: Please enter my appearance on behalf of the Plaintiff, Andrew S. Clark, in the above captioned case. Respectfully submitted, essica iamondstone, Esquire MidB un Legal Services 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 Date: :5',,) 0 . V';- . . . ANDREW S. CLARK Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 02-1986 CIVIL TERM BEVERLYS.ORNER Defendant, IN CUSTODY CERTIFICATE OF SERVICE I, Jessica Diamondstone, Esquire, of Mid Penn Legal Services, attorney for the Plaintiff, Andrew S. Clark, hereby certify that I have served a copy of the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following date and in the manner indicated below: U.S. First Class Mail. Postage Pre-Paid Marcus A. McKnight, III, Esquire 60 West Pomfret Street Carlisle, PAl 7013 MidPenn Legal Services, Inc. ~ 1 )....- Date: ) , "" 0 . , ) .~.../ .,...,."./' // // ~/ / // . J essi9fl Diamondstone, Esquire MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 - c:~ ^-\ '" ') c;.: o - j'RECEIVED JUL 212005l\ ANDREW S. CLARK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW BEVERLY S. ORNER, Defendant NO. 2002-6986 IN CUSTODY COURT ORDER AND NOW, this zr day of July, 2005, upon consideration of the attached Cnstody Conciliation report, it is ordered and directed as follows: 1. This Court's Order of March 2, 2005 shall remain in 'effect subject to the modifications as set forth below: a. The parties and the minor child shall continue counseling with the Strickler and Whitcomb Associates. The counseling shall be consistent with the counseling program that has been in place siince March and shall be designed to achieve a resolution by late August whereby the father will be able to achieve some type of contact unsupervised (:ustody with his minor child. The counselor is requested to me a report with tlile attorneys for the parties prior to the Conciliation Conference scheduled below in order to update the attorneys with respect to the progress of the counseling sessions. b. The parties shall meet again with the Cu~tody Conciliator on Wednesday, August 17,2005 at 8:30 a.m. c. Father shall enjoy reasonable telephone contact with the minor child. FiLED DfHCE Ot: -rue DPC'TrY'Jf,np[:l'l f trh_ I \ I . (, '"" '".1 ,t'.."" Z005 JUL 25 f\!i II: 0 I - d. Mother is encouraged to schedule times with the father whereby mother, father and child may jointly go out to lunch or dinner in order to help facilitate the child becoming more comfortable with the father. e. In the event any issues arise prior to the mentioned Custody Conciliation Conference, the attorneys for either party may contact the Custody Conciliator directly to schedule an emergency telephone conference. BY THE COURT, cc: Jessica Diamondstone, Esquire Marcus A. McKnight, III, Esquire -/liL ~ ~-ld- ?,::J. s-of Q-, ANDREW S. CLARK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAJ"fD COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW BEVERLY S. ORNER, Defendant NO. 2002.JtJ815 IN CUSTODY PRIOR JUDGE: Kevin A. Hess 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 child who is the subject of this litigation is as follows: Ruth Ann Clark, born January 22, 1998. 2. A Conciliation Conference was held on July 7, 200S, with the following individuals in attendance: The mother, Beverly S. Orner, with her counsel, Marcus A. McKnight, III, Esquire, and the father, Andrew S. Clark, who appt:ared with his counsel, Jessica Diamondstone, Esquire. 3. The parties agree to the entry of an Order in the form as attached. ')- ;).O-oS-- DATE