The URL can be used to link to this page

Home My WebLink About97-01934 ~ t-- o .., ....... \l ~ o ~ ~ '1)?0o.. ~ () 11 -.. \) ~ ~ ../ -,- / " . >- '" .":) '.J ~ Ct) (.).. " , , t-o.' ~ . . '~'~"*"~*'~'~'~*'~*'~'~~'~'**'~**-)'*'-*::**'~*'~ro*~ ~ ~ ,.~~..~.." ~_.."......- ~...,."., " ~ , ..,., .." ~--.. .,...... -,~. ..,,-. .~- . ,.... ,,-~-~- .--........ .....-,.-...-...... -,.~ . , ~--.. ..~~.~...---------....-...---,-...-----. ----.......".-.----... " 8 ~,',: ~ ',' ~ ~.' ~ ~ ~ s ,;, ~, $ w ',' ~ ',' ;i: ", ~ ~. ~ ~, $ " ~ ~ ',' IN THE COURT OF COMMON PLEAS ~I ',' S ~ ',' OF CUMBERLAND ~~~ STATE OF ;~~~: . ~ ... ~ " ~. ._~~,; ,"f PENNA, COUNTY s ~ ',' ~ ~ ',' ~ CRAIG A. VOGELSONG, P1ainti~~ ..,... I\) 97 i\.: ll. . 1934 ~ ',' ~ ',' \' t 'I';',II~; ~ JEANNE L. VOGELSONG, ~ De~endant ~ " ~ ~ ',' DECREE IN DIVORCE ANDNOW,~,g"""'" 19,<?!::,. it is ordered and ~ ~l ~ .. s decreed that, , , "C;:~,C\~g, !\,., ,V99,~1,.~PJ1.g , , ,', , " , , '" , " , , " , '. plaintiff, and, ,., ,J~~,~~~, ~,', .Y~9,~~S~~(L , .. , , .. , , .. , , .. . ,.. , , .. , , ", defendant, are divorced from the bonds of matrimony, " ~ The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; None ........................................... ..... .,..... ..... ... ........ .... """"",..""""""""/,j"""""""""",, / . /1 n y:ut;/I ^,:,,'';'''~_,(~ ,,~. /-""',?,,~ J -K,*.tY14' ,e M/rJ. W 1/ "1J1rothonot;uy ;{, ~ ~ ~ ~ -------.---------.. . . . . ..., . , '-' . ~~~**~******~.**~**** , ~ .:.;. .:.;. <+;. <~;. .:.;. .:.;. -:+;. .:..:. .:.;. .:.:.' ~ ',' ~ " $ ~ ',' $ ~ ',' ~ ',' $ ~ ',' ~ ',' .. ~ ~ ',' ~ ',' ~ " ~ ',' ~ ',' ~ f~ ..:' ~ ~ rt:. ',' ~ ~ ~ ~ ~ ,'.- I.. ) !I'. I: I~ I: i: I~ I::: ':!- '~ ~ ~ I' ;~ . . CRAIG A. VOGELSONG, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintifi. NO, 97-1934 v, CIVIL ACTION - LAW JEANNE L, VOGELSONG, Defendant IN DIVORCE, CUSTODY PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOT AR Y: Transmit the record, together with the following information, to the court for entry of a divorce decree: I. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code, 2, Date and manner of service of the complaint: by certified mail, return receipt requested, received by defendant on April 29, 1997, 3, Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintifT, November 7,1997; by defendant, November 3, 1997, 4, Related claims pending: none, 5, Waiver of notice of intention to request entry of a divorce decree under Section 3301(c) of the Divorce Code was executed by plaintifTon November 17, 1997, and by defendant on November 3, 1997. Date: November 23, 1997 ~ . t) .n () '. -1 , -, I .-, \~g , , .. .J ,1".1 (, C:-, .;::h, 'S .. 1 ~''-1 , " '"1, \--,- <J ,::l '. iTl " ,) :;-1 ::;j :./j ! -, r~ -< i I i Plaintiff NO, ql- IQ3t.J C.u.:.0 lee fl"\ CIVIL ACTION - LAW "j. I" I I I, I. I CRAIG A, VOGELSONG, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY , PENNSYLVANIA v, JEANNE L, VOGELSONG, Defendant IN DIVORCE, CUSTODY ORDER OF COIIRT AND NOW, this JB:' day of Aor'\ \ ,19911, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel a pear before ~.",;(\_ S" s.~t,.to.f:;!\( I"ii\:' ,the conciliator, at ~~l W. i , \J,f>c 1'\ \ ( c:. h on the --dl..:: f day of H 0.. '~ ' 1991Y, at q: ('f) AlA" for a Prehearing Custody Conference, At such confere ce, an effort WIll be made to resolve the Issues in dispute; or iflhis cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a temporary order, Either party may bring the child who is the subject of this custody action to the conference, but the child's attendance is not mandatory, Failure to appear at the conference may provide grounds for entry of a temporary or pennanent order, FOR THE COURT: By: J:sull.li\..J, ~'u1f'~' Custody ConciliatoJttt:>~ 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. OFFICE OF THE COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, FOURTH FLOOR CARLISLE, PA 17013 (717) 240-6200 CRAIG A, VOGELSONG, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PlaintilT NO, v, CIVIL ACTION - LAW JEANNE L. VOGELSONG, Defendant IN DIVORCE, CUSTODY NOTICE TO DEFEND You have been sued in court, If you wish to defend against the claims set forth in the following pages, you must take prompt action, You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court, A judb'1llent may also be entered against you for any other claim or relief requested in these papers by the plainti IT, You may lose money or property or other rights important to you, including custody or visitation of your children, When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling, A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 I .' , COlINT II- ctlSTODY ll, Paragraphs I through 7, above, arc incorporated herein by reference, I 9. PlaintilT seeks custody of the following child: liwnl: Present Residence ~ Casey A, Vogelsong I 14 Laurel Drive Enola, Pennsylvania 17025 14 The child was not born out of wedlock, The child is presently in the custody of Craig A. Vogelsong, who resides at 114 Laurel Drive, Enola, Cumberland County,Pennsylvania, During the past five years, the child has resided with the following persons and at the following addresses: Persons Addresses ~ Craig A. Vogelsong 114 Laurel Drive Enola, Pennsylvania 17025 1/97 - present Craig A. Vogelsong Jeanne L. Vogelsong I 14 Laurel Drive Enola, Pennsylvania 17025 12/88 - 1/97 The mother of the child is Jeanne L, Vogelsong, currently residing at 811 Brinn Drive, Apartment 304, Enola, Cumberland County, Pennsylvania, She is married, I , I I The father of the child is Craig A, Vogelsong, currently residing at 114 Laurel Drive, Enola, Cumberland County, Pennsylvania, He is married, ,; " 2 10, The relationship ofPlaintitTto the child is that of father, The PlaintitTcurrently resides with the following persons: ~ Relationship Casey A, Vogelsong Son 11. The relationship of Defendant to the child is that ot'mother, The Defendant ~ Relationship currently resides with the following persons: N/A 12, PlaintitThas not participated as a party or witness, or in another capacity. in other litigation concerning the custody of the child in this or another court, PlaintitThas no information ofa custody proceeding concerning the child pending in a court of this Commonwealth, PlaintitT does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child, 13, The best intcrest and permanent welfare of the child will be served by granting the relief requested because PlaintitThas been the primary caretaker of the child and has maintained a stable home for the child, i . , I I [ t 3 , !' v; ': . , ' VERIFICATION [ verify that the statements made in this Complaint are true and correct. [understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. ~ ~dTL7 Cmig A, V gel song ,. CRAIG A, VOGELSONG, IN THE COURT or COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO, 97-1934 v. CIVIL ACTION - LAW JEANNE L. VOGELSONG, Defendant IN DIVORCE, CUSTODY CERTIFICATE OF SERVICE I, Cindy E, Sheaffer, Attorney for the Plaintiff, hereby certify that I have served a true and correct copy of said Complaint Under Section 3301(c) of the Divorce Code on Defendant, Jeanne L. Vogelsong, 811 Brian Drive, Apartment 304, Enola, Pennsylvania 17025, by depositing a copy of the same in the United States mail, certified delivery, return receipt requested, postage prepaid, this 25th day of April, 1997, II your RETURN ADDRESS campl.1Id on th. r.v.... lid.? ~ ; i [ge~ i lilltHU~ ~ ..! I>>'lll' ~ ~~ i~ni:9 :" ~I ~ ~ ~ m i 1111 ~s-~ ,~ ~ :~. ff ~f i ti~ , 'I ~11(1) ~a:~'i . - i ~~ ~ ~g t · ~ ~~ ln~ ~ iI Q 1 i t::\ <1'(1) ~!giJ ~ . l;' =1 i i ~ ~ g ~i ! 8 ...Ill I~ t! it U D S ti iiii.i: i Ii II fill Btilil..... i ii 'Ii!i i!~"a!i I; i J ~"1 Ii ill i" ':'..., 0 0 ~ i'..' ~ ~' --?8~&l ~~~!l: \ o~g ~.;!a -;'"l ! & u Thonk ~Ior ullng R.tum R.celpt Sorvlce, - . - .,' < PS Fonn 3800, April 1995 (RewlSe) POSlAgo $ Certified F eo Speo~ 0cliveIy F.. l5' I. , /0 :D ~ 3 :D S '2 $ ;(,75 \ ~. I c (") .0 0 C -l ~n . :c :~ -0(::- ?-< O)(!~ .riFJ ?":l: I O~ 0' " ~:';:: .~ yL. ::>' -:,B ~~ ::s: qo ~;(. ---( - 15m '.P- --' - L, .. -I :r: :s; ..-! (ll -. '< \ ~ / J { ( 0 ..D 0 ~ -I -II O;~ ,-, -nut (:1 ': :~, rll{" , .,c ,I.-- :%: '.' '.l:~n 17(- (N J '~"J l;,' : ':~;7\ ;::(,: :,.. :\:( -, .''1'1 1"-- .' :.i; ':.~?) ~:.CJ ~ "j r', 1 ;..~:; :,-1 ,,> ~ :.n :.q N .... I I r t~.. .- ~:~} () ." ! , -n .~~\ ..,J ',':) ." :;::~ ,.)I-n ::~ ~) " '-. ,-, " ':!~~ .._~.) ~ 'J :<) C', .. ... I' , -'. r.:- \ . . CRAIG A. VOGELSONG, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 97-1934 v. CIVIL ACTION - LAW JEANNE L. VOGELSONG, Defendant IN DIVORCE, CUSTODY AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 14, 1997. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, division ofpropcrty, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: /I]~f/ .h".......~...._ I J y. n -.!J C) F _I ",I .Pl.; '.- D)I'~; I'::j ,.. r"~ : (':; !; ,,, f...: ...,..' ; .L ,~; \ ' 1: , :f;, :~: , ,.,1 , ,. :~- C' , ) ~. C) ; ,I ; I " ,~ ~ , :11 :..! -, (") \0 t~'l <:: -J . ~ I ;..: ~"': ".-J ~r:"": CJ ' ."T1 1]1'1- .C; "i;-4 Z.i .-; '1 E~C (..~ . j>:"J ..... ,~.) CJ ~.- r..C.i :r~ " J'h ~. -I' ~~( ., :,j.: (-)_... ~.. ( ) ~"n q;> urn ).'C ,=' -/ ~ 11 ~ .- -. ~~'( 2. 8 1991 CRAIG A. VOGELSONG, . IN THE COURT OF CXlMMON PLEAS . plaintiff CUMBERLAND COUNTY, PENNSYLVANIA . . vs. . NO. 97-1934 CIVIL TERM . . . JEANNE L. VOGELSONG, IN DIVORCE, CUSTODY Defendant . . ClIDER OF <nJRT AND tOi, this 20th day of May, 1997, the Conciliator being advised by plaintiff's counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction in this case. fl)"A\./l~L"~lrJo.-, Dawn S. sunday, Esquire 0 custody Conciliator P,LEO-0FFfCE CF T: '.: 1',-'n'r:"("::JTNlY 97 JU!11 G ;1;: 11: ~8 C' 'I',;'.';;; : ..I' r .', '.i\. Ul\........,..... ...' .._....,~I\I ( PEN,\!SYLW\:\,/\ i I I i I I ! i ! I. I I I , I I ... IN WITNESS WHEREOF, the parties hereto have placed their hands and seals to this Stipulation this 1111/ day of '/)I./I.I} ,1997. U WITNESS: I I I C;, (f f. Aiel i/~1 / . O~1cJi1 fiLial/" / / tt '. ,... ~ 2 . . CRAIG A. VOGELSONG, Plaintiff / Respondent IN TI-IE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 97 - 1934 CIVIL JEANNE L. VOGELSONG, Defendant / Petitioner CIVIL ACTION - LA W IN CUSTODY ORDER ANDNOW,this ID day of -1J.~_ ,1999,upon consideration of the attached Petition, it is hcrcby directed that the parties and their respective counsel appear beforc bcl.Jn .\ . ,,\ ~~ , Esquire, the Conciliator, at 3'l1.V. \\1.\1\ ~.. ~r~\( ~'n~ ,Pen~, on the 7 day of :Su \ ~' , 1999, at J , \ o'c1ock,~.m. for a Pre-Hearing Conference. At such a conference, an effort will be made to rcsolve the issues in dispute; or if this cannot be accomplished, to define and narrolV the issues to be heard by the Court, and to enter into a Temporary Order. All children five or older may, at the request of either attorney or party, be present at the Conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or pcrnlanent Order. FOR THE COURT: ~~~. Custody Officer l~) 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. OFFICE OF THE COURT ADMINISTRATOR 1 COURTHOUSE SQUARE, 4TH FLOOR CARLISLE, PA 17013 (717) 240.6200 ,..... -. n! Fn. (", ._,...,.... '_:' ." r. ::-=-. -;:-::'/"i.,;: . .0,...... '()T'!"'!, "'. 11~,y 99 111'11 - ~'.i Up',:.,. I. .,.41 CL'" . "~':.f.J(.,., , ,_. (-EN!\ '0:;\ ':~',:....'..)Ui\"l\' \\.,: I L~f..'I'~ I , .;'/1 "./CJ'f'~ &d. ~ ~er -64 ~ ,~"//J'flf' ~~ 4~ ~ .-J/../ ?'/CJ'9~ 4-;7 -r~ z,4/~ existing Custody Order so that it accurately reflects the status quo. Respectfully Submitted, ~J6;:;L;~ 126 Locust Street Harrisburg, PA 17101 (717) 260-0545 Atty J.D. # 60731 , Verification I, Jcannc L. Vogelsong, hcrcby swcar and uffirm thatthc facts contained in thc foregoing Petition are true and correct and arc made subject to thc penalties of 18 Pa. C.S.A. Scc.4904 relating to unsworn falsification to authoritics. Date: ~-f-91 I ! ~' , ~ ... CRAIG A. VOGELSONG, IN THE COURT OF COMMON PLEAS OF plaintiff/Respondent . CUNBERLAND COUNTY, PENNSYLVANIA . . . vs. . NO. 97-1934 CIVIL TERM . . . JEANNE L. VOGELSONG, CIVIL ACTION - LAW Defendant/Petitioner . . . CUSTODY . ; , i ~ I' I I I I i I f I aIDER OF CXXJRT AND tOi, this fr consideration of the attached and directed as follows: day of J~ CUstody ConciliatJ.on R~port, , 1999, upon it is ordered 1. The prior order of this Court dated June 16, 1997 is vacated and replaced with this order. 2. The Father, craig A. Vogelsong, and the Mother, Jeanne L. Vogelsong, shall have shared legal custody of Casey A. Vogelsong, born March 19, 1983. Each parent shall have an equal right, to be exerciSed jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 3. The Mother shall have primary physical custody of the Child. 4. The Father shall have partial physical custody of the Child as arranged by mutual agreement of the parties. i I ii 5. The Father may appeal the provisions of this order within 30 days of its entry date. r, J/ BY I THE CJ:)URd ?' J. cc: Barbara J. Patton, Esquire - COunsel for Mother craig A. Vogelsong - Father ~ ~l '1/1't/9'1. >&.iP. CRAIG A. VOGELSONG, . IN THE COURT OF COMMON PLEAS OF . Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA . . vs. . NO. 97-1934 CIVIL TERM . . . JEANNE L. VOGELSONG, . CIVIL ACTION - LAW . Defendant/Petitioner . . . CUSTODY . ! , I I 1'...... CUSTOOY cx:NCILIATIOO SlMlARY REPCm' IN ACXXlIDANCE WITH ClJoIBERLAND CXXNlY RULE OF CIVIL p~ 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME Dl\TE OF BIRTH aJRRml'Ly IN CUSTOOY OF Casey A. Vogelsong March 19, 1983 Mother 2. A Conciliation Conference was held on July 7, 1999, with the following individual in attendance: The Mother's counsel, Barbara J. Patton, Esquire. 3. The Mother's counsel represented that she had been in contact with the Father, who advised her that he does not oppose the Mother's Petition to Modify the existing Custody Order to reflect the Mother currently has primary physical custody of the Child, who is 16 years old. 4. Based upon the representation of the Mother through counsel, the Conciliator recommends an Order in the form as attached. L./ ~ 199,9 Date""' ........, "; tf2,.,.LiA" ,~ Dawn S. Sunday, ESqu e Custody Conciliator PllIintifl: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CRAIG A. VOGELSONG, v. NO. <)7.1934 CIVIL JEANNE L. VOGELSONG, Dctendllnt. CIVIL ACTION- CUSTODY NOTICE TO DEFEND You havc been sucd in court. If you wish to dctend against the claims set forth in the ti.Jllowing pages, you must tllkc lIction within twcnty dllYs allcr this complaint and notice are servcd, by cntering a written lIppcarance personlllly or by lIttomey and tiling in writing with the court your dcfcnses or objcctions to the claims sct forth against you. Your are wamed that if you tail to do so thc case mllY procccd without you and a judgmcnt may be entered against you by the court without lilrther noticc ti.lr lIny moncy c1aimcd in thc complaint of for any other claim or relicf rcqucstcd by thc plaintilI Y oumay losc money or property or other rights important to you. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OF CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE PA 17013 (717) 249 3166 or 1 BOO 990 9l0B . " .. CRAIG A. VOGELSONG, Plaintiff. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO, 97-1934 CIVIL JEANNE L. VOGELSONG, Dcfendnnt. CIVIL ACTION- CUSTODY ORDER OF COURT AND NOW, upon eonsideration oflhe attachcd Petition, it is hereby directed that thc parties and their respective counsel appear before the Custody Confcrence Officcr, at . on thc __ day of , at a Pre- Hearing Custody Confcrence. At such Confercncc, an cffort will be madc to resolve the issues in dispute; or if this cannot be nccomplished, to dcfine and narrow thc issues to bc heard by the Court, nnd to entcr into a Temporary Order. All children agc five or older~also be present at thc Conferencc. Failure to appenr at the Conference may providc grounds for cntry of a temporury or permanent Ordcr. r' I r: FOR THE COURT: Date: By: Custody Conference Officer YOU SHOULD TAKE TlIIS 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. ;,' '.,j.'. ." ~:- ;-:i~ ',,' "'It i';/ .,"jt. :;..:, ,\^ ,~~ <:,.$' Dauphin County Lawyer Rcferral Service 213 North Front Street Harrisburg, PA 17101 (717) 232-7536 .' 5. From birth to prcscnt, thc child hus rcsided at thc following addrcsscs with thc following pcrsons: Person(s) Addresses Dotes Plaintilf 114 Laurel Drivc Enola,PA 17025 Birth to February 1999 Defendant 13 Glcnwood Drive Camp Hill, PA 17011 February 1999 to March 20, 2000 Plaintiff 114 Laurcl Drive Enola, PA 17025 March 20, 2000 to Present 6. Petitioner does not know of a pcrson not a party to the proceedings who has physical custody of the child or elaims to have custody or visitation rights with respect to thc child. 7. There is an existing Custody Order entcred into effect on July 13, 1999, a copy of which is attached hcreto as Exhibit A. 2 If 8. The bcst interest and pcnnanent welfarc ofthc ehild will bc scrvcd by modifying I,. II I i I f I thc Custody Ordcr bccause: a) Mothcr has thrclltcncd to commit suicidc numcrous timcs in front of thc minor child; b) Father has becn contacted by thc counselor and tcacher from the minor child's school to pick up thc child because he hlls received phonc calls from Mothcr threatening suicide; c) Mothcr eontactcd the minor child at school and informed him that "I can't afford to pay support and want nothing to do with you." 9. Each parent whosc parcntlll rights to thc child have not been tcrminated and the pcrson who has physical custody of the child hllve bccn namcd as a pllrty to this action. All othcr persons, named bclow, who are known to have or claim a right to custody or visitation of the child will bc givcn notice of the pcndcncy of this action and thc right to intcrvene: None. 3 .' WHEREFORE, the Petitioner respectfully requests this Honorable Court to modify thc currcnt custody ordcr granting primary physical custody to Petitioner subjcct to supervised visits with Respondent. Respectfully submitted, By: G;;rald S. Robinson, Esquire Attorney J.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, P A 17110 (717) 232-8525 Attorncy for Petitioner 4 I I I i I Respectfully SubmiUed, ~J1.~L;~ 126 Locust Street Harrisburg, PA 17101 (717) 260-0545 AUy 1.0. /I 6073\ existing Custody Order so that it accurately reflects the status quo. t~. '.,;" . Verification I, Jeanne L. Vogelsong, hereby swear and affinll that the facts contained in the foregoing Petition are true and correct and are made subject to the penalties of 18 Pa. C.S.A. Sec. 4904 relating to unsworn falsification to authorities. Date: "%-f~9f ,t.-,. - - r.u:I ,:..,.'i.-.... .' VERIFICATION I verify that the statements made in this Complaint urc truc and corrcct. I undcrstand that false statements hcrcin arc mudc subjcctto thc pcnaltics of 18 Pa. C.S. Scction 4904, relating to unswom falsification to authoritics. .. " CERTIFICATE OF SERVICE I, Gcrald S. Robinson, Esquire, do hcreby ccrtify that on thc 25th day of April, 2000, ( causcd a truc and correct copy of the Pctition to be scrved upon the following individual by ccrtificd mail, rctum rcceipt requcstcd, rcstrictcd delivery by depositing samc in thc United Statcs mail, postage prcpaid, in Harrisburg, Pennsylvania. Jeanne L. Vogelsong 13 Glenwood Drive Camp Hill, PA 17011 Respectfully submitted, N & GERALDO By: raid S. Robinson, Esquire Attomcy J.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, P A 17110 (717) 232-8525 ,'""'\ ,-. . . . CRAIG A. VOGELSONG, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 97.1934 CIVIL Plninti ff, v. JEANNE L. VOGELSONG, Defendant. CIVIL ACTION- CUSTODY ACCEPTANCE OF SERVICE I, Jeanne L. Vogelsong, certify that I accepted service ofthc Petition to Modify Custody filcd on or about May 10, 2000. Date 5/1 'i'IC6 Exhibit 'JUL 11 20~ I,' ! f. i CRAIG A. VOGELSONG, Plaintiff : IN THE roURT OF COMMOO PLEAS OF : CUMBERLAND CCUNTY', PENNSYLVANIA . . vs. : NO. 97-1934 CIVIL TERM . . : CIVIL ACTION - LAW JEANNE L. VOGELSONG, Defendant . . : IN CUSTODY aIDER a? CXXJRT AND fOi, this 5th day of July, 2000, the Conciliator, being advised by Plaintiff's counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction in this case. The CUstody Conciliation Conference scheduled for July 6, 2000 is canceled. FOR THE: CXXJRT, Da~S;d~e~ CUstody Conciliator . I, CRAIG A. VOGELSONG, PllIintit1~ : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 97-1934 CIVIL JEANNE L. VOGELSONG, Dcfcndant. CIVIL ACTlON- CUSTODY ORDER OF COURT AND NOW, upon consideration ofthc attached Petition, it is hereby directed that the partics and thcir respcctivc counsel appcar before the Custody Confcrcnce Officer, at , on the day of , at a Pre- Hcaring Custody Confercnce. At such Confercnce, an effort will bc made to resolve the issues in disputc; or if this cannot bc accomplished, to dcfinc and narrow thc issucs to be heard by thc Court, and to entcr into a Temporary Order. All children age five or older shall also be prescnt at the Confcrencc. Failure to appcar at the Confcrcnce may provide grounds for entry of a temporary or pcnnancnt Order. FOR THE COURT: Date: By: Custody Confcrence Officer YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawycr Referral Scrvice Cumbcrland County Bar Association 2 Libcrty A venue Carlisle, PA 17013 (717) 249-3166 WHEREFORE, the Pctitioncr respcctfully requests this Honorable Court to modify the ~ II t current custody order granting primary physical custody to Petitioner subjcct to supcrviscd visits with Respondent. fl Rcspectfully submitted, By: {;k J I~~ v ~L~tL:~.~~~ Gcrald S. Robinson, Esquirc Attorney J.D. No. 27423 4407 North Front Strect P.O. Box 5320 Harrisburg, P A 17110 (717) 232-8525 I i I f I i , , ROBINSON & GERALDO Attorncy for Petitioncr 4 , I VERIFICATION I verify that the statemcnts madc in this Complaint are true and correel. I undcrstand that falsc statcmcnts hcrein are madc subject to thc penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. , .~.... ~cd~ CRAIG VOGELSONd, PLAINTIFF CRAIG A. VOGELSONG, Plaintiff; IN HIE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 97-1934 CIVIL JEANNE L. VOGELSONG, Defendant. CIVIL ACTION--LA W IN CUSTODY PROOF OF SERVICE The undersigned makes the following retum ofserviee: the Petition to Modify Custody was served upon Jcanne L. Vogelsong, the Defendant, on or about July 28,2000 at 13 Glenwood Drive, Camp Hill, Cumberland County, Pennsylvania. The signed acccptance of service is attached hereto as Exhibit 1. SIGNATURE AND AFFIDAVIT I, Gerald S. Robinson, Esquire, certify that I am a competent adult not a party to this action. I verify that the statements made in this affidavit and retum of service are true and correct. I undcrstand that false statcmcnts herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsfication to authorities. Respectfully submitted, ROBINSON & GERALDO Dated: 'is I ILl /6l'J By:r;yAa,~cl0,~dX~ Gerald S. Robinson, Esquire Attomey \.D. No. 27423 4407 North Front Strect P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attomey for Plaintiff :"t'. CRAIG A. VOGELSONG, : IN THE COURT OF CXlMMON PLEAS OF plaintiff/Respondent . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. . NO. 97-1934 CIVIL TERM . JEANNE L. VOGELSONG, CIVIL ACTIOO - LAW Defendant/Petitioner IN CUSTODY aIDER rR <nJRT AND tOi, this '?1) upon consideratioon of the attached ordered and directed as follows: '~ ~ _, 2000, Conc at on Report, it is day of CUstody 1. The prior Order of this Court dated July 13, 1999 is vacated and replaced with this Order. 2. The Father, craig A. Vogelsong, and the Mother, Jeanne L. Vogelsong, shall have shared legal custody of Casey A. Vogelsong, born March 19, 1983. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health/ education and religion. 3. The Father shall have primary P1ysical custody of the Child. 4. The Mother shall have partial physical custody of the Child beginning in cctober 2000, every Thursday fran after school when the Child shall take the bus to the Mother's residence until 10:00 p.m., when the Mother shall transport the Child to the Father's residence. 5. Neither party shall do or say anything which may estrange the Child frcm the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural developnE!nt of the Child's love and respect for the other parent. Both parties shall take all reasonable steps to ensure that third parties having contact with the Child comply with this provision. I BY TIlE cctJRT, /.' 'L j,/{ Edgar B. ey, ~ J.e-. ~ , ~ ~OO V o;1>~ co: Barbara J. Patton, Esquire - Counsel for Mother Gerald S. Robinson, Esquire - COunsel for Father ......."'~...--- . CRAIG A. VOGELSONG, . IN THE a::URT OF CXX>IMON PLEAS OF . plaintiff/Respondent . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. . NO. 97-1934 CIVIL TERM . . . JEANNE L. VOGELSONG, . CIVIL ACTION - LAW . Defendant/petitioner . IN CUSTOD~ . .'~' ! I I i P!U(]{ JUDGE: Edgar B. Bayley aJS'lOOY CX:U:ILIATICN SUlMI\RY REPCm.' IN ACXXlUlANCE WI'l'II cnmERLAND CXXNlY RIlLE 01." CIVIL PilC'"1<I fJRE 1915.3-8, the undersigned Custody COnciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: Casey A. Vogelsong March 19, 1983 Father , I.. 1.- j': I I I tWlE DATE OF BIRl'II CURRmrLY IN CUSTCIJY 01." 2. A Conciliation Conference was held on September 14, 2000, with the following individuals in attendance: 'I11e Father, craig A. Vogelsong, with his counsel, Gerald S. Robinson, Esquire, and the Mother's counsel, Barbara J. Patton, Esquire. 'I11e Mother, Jeanne L. Vogelsong did not attend the Conference or contact the Conciliator. 3. 'I11e parties agreed (the Mother through counsel) to entry of an Order in the fotm as attached. s;: f)k~ / If.. ;)a.,t) Date' [~~.~ Dawn S. sunday, Esqu re CUstody Conciliator