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HomeMy WebLinkAbout97-02526 \ i I I on "7 I 4: 3 \ ,.,.'" \ ! J .' M.;! .....'. ~"" ..0'\. /~ ~ J &; * IY \ 0(-, G \....x\l \)Gr (" Plaintiff : IN TIlE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA . . V * \'X:bC:)f nh l ~o,j(d \.)Oc (" Defendant :CIVIL ACTION - LAr., . ;NO. )':,;~)(..::) CIVIL :CUSTODY/VISI-TATION 19'n ORDER OF COURT AND NOr." this (date) ~:~ J H WI 1, upon consideration of the attached complaint, it is hereby directed that the pa~ties and their respective counsel ,.appear ,iJefor:e -\ c' [, ,l r -,,' ( 'Q" the conciliator, at ';,',-' ,', \ ':,1 '\ ,:,1- ,i ( ';~ 1-' on the :.:,(" day of " k JC,("" ., 1 Cr] , at L, G p, M., for a Prehearing 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. Either party may bring the child who is the subject of this custody action to the conference, but the child/children's attendance is not mandatory. Failure to appear at the conference 'may provide grounds for entry of a temporary or pe:rmanent order. FOR THE COURT: By: JI,t:. hnl0.......J 'Frt I'q.:\(Nl"" Custody Conc~l~ator \ ~b, 'i ' YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 00 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 COURTHOUSE, FOURTH FLOOR CARLISLE PA 17013 (717)240-6200 F' --:;\ ,"'--,,,,- CO: '. ,I..:. '"< -::~':'~;I 1 , ,n( n7 ,.., I.' '". 'J I, .. I ',...') . - ,,; ,;. :~L ~'. j)L ,", ' " . . '.' ".1,_,', \, ... \ ..5:I?'~7 ad, t!~ m~$ 127/ ck6?~1 $,l?-o// ;/ Hc~ --n!ti4:! ~ 1#. ....1"/14) {~ :f2k~/";" 'J1/. yj7~ ~. I : BRIAN G. WALBORN, . IN THE COURT OF COMMON PLEAS OF . Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. . No. . . " . ., DEBORAH L. WALBORN, CIVIL ACTION - AT LAW I ;i Defendant CUSTODY , , AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by , flaw to comply with the Americans with Disabilities Act of 1990. i jFOr information about accessible facilities and reasonable ,iaccommodations available to disabled individuals having business " ;! before the court, please contact our office. All arrangements must ,'be made at least 72 hours prior to any hearing or business before 'the court. You must attend the scheduled conference or hearing. FOR THE COURT: Custody Conciliator DATED: :1 I I I IBRIAN G. WALBORN, Plaintiff I !I :,,'1' DEBORAH L. WALBORN, Defendant ~ I !I 'I ;1 :1 'I I I , , I attorney, Jeanne B. Wigbels, Esquire, files this Complaint for I "Custody against the Defendant, Deborah L. Walborn, and in support I thereof, avers the following: I I I , land the natural Father, who currently resides at 251 E. Crestwood I ,IDrive, Apt. B1, Camp Hill, Cumberland County, Pennsylvania 17011. . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : vs. No. : CIVIL ACTION - AT LAW CUSTODY COMPLAINT FOR CUSTODY AND NOW, the Plaintiff, Brian G. Walborn, by and through his 1. The Plaintiff is Brian G. Walborn, an adult individual 2. The Defendant is Deborah L. Walborn, an adult individual and the natural Mother, the current residence of whom is unknown. : Her last known mailing address was 10 Cumberland Estate Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The Plaintiff seeks custody, partial custody, and/or ,visitation of the following child: Na~ Present Address Aqe Erica Nicole Walborn 251 E. Crestwood Drive Apt. B1 Camp Hill, PA 17011 5 (12115/91 ) The child was not born out of wedlock. I I , I I I I I ,I I ! I Walborn, the child's natural Father, who currently reside I :!crestwood Drive, Apt. II Pennsylvania 17011. 'I ,I " 4. The child is presently in the custody of Brian G. at 251 E. B1, Hill, Camp Cumberland County, 5. Since birth, the child has resided with the following , persons at the following addresses: Name Address Dates Brian Walborn Deborah Walborn Deborah's boyfriend 251 E. Crestwood Drive Apt. BI Camp Hill, PA 17011 3401 Brightwood Lane 1/93 to 2/9/95 Woodbridge, VA 22193 (and other unknown addresses) 2/9/95 to present i: .Brian Walborn I i Deborah Walborn 'i 7483 Furnace Bridge Rd. 4/92 to 1/93 Apt. C Glen Burnie, Maryland ',Brian Walborn 'Deborah Walborn 19 Pheasant Court 12!15/91 to 3/92 Mechanicsburg, PA 17055 6. The natural Mother of the child is Deborah Walborn, Defendant, the current residence of whom is unknown. Her last known mailing address was 10 Cumberland Estate Road, Mechanicsburg, ,Cumberland County, Pennsylvania 17055. The Mother is divorced from the Father and is not believed to have remarried. 7. The natural Father of the child is Brian Walborn, Plaintiff, who currently resides with the subject child at 251 E. Crestwood Drive, Apt. B1, Camp Hill, Cumberland County, Pennsylvania 17011. The Father is divorced from the Mother and has not remarried. B. An Agreed Order of Custody was previously entered by the Juvenile and Domestic Relations District Court of Prince william i County, Virginia, at Case No. J-51313. A copy of that Order is attached as Exhibit A. Other than the above, the Plaintiff has 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. 9. The Plaintiff has no information of a custody proceeding concerning the child currently pending in any court of this : Commonwealth. 10. The Plaintiff does not know of a person not a party to the proceedings, who has physical custody of the child or claims to I have physical custody or visitation rights with respect to the ,i child. " 11. The best interests and permanent welfare of the child I will be served by granting the relief requested becauRel a). The Plaintiff will continue to provide the child with a home with adequate moral, emotional, and physical surroundings as required to meet the child's needs; b). The Plaintiff is willing to continue custody of the child; c). The Plaintiff continues to exercise parental duties and enjoys the love and affection of the child. d). The Defendant does not have a permanent place of residence and cannot provide for the needs of the child. 12. Each parent whose parental rights to the child have not been terminated has been named as a party to this action. No othor persons are known to have or claim a right to custody or visitation I ~ of the child. WHEREFORE, the Plaintiff respectfully requests this Honorable . Court to enter an Order granting custody of the child to the I ,Plaintiff and natural Father, Brian Walborn, in accordance with any Stipulation of the parties, or in the event the parties are unable ,to execute such a Stipulation, to enter an Order granting custody, .' ipartial custody, or visitation of the child to the Plaintiff. Respectfully submitted: DATED: }ffN;z , r A /'.,(,' u J nne B. Wigbels, Esquire Law Offices of Patrick F. Lauer, Jr. 210B Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 PA Supreme Ct. ID No. 68735 Phone: (717) 763-1BOO ATTORNEY FOR PLAINTIFF $l.llo$(fLIQ.I.l,.6IJ"f'\.Y ~'!M1lJ:IO Exhibit A 110111 VIRGINI'A: IN THE JUVENILE AND DOMESTIC RELATIONS DISTRICT COURT OF PRINCE WILLIAM COUNTY INRE: Custody of ERICA NICOLE WALBORN ) AGREED ORDER OF CUSTODY CAME this 29th day of March 1995, the Petitioner, Brian G. Walborn, by counsel, upon his Petition for an Order granting him sole custody of his infant daughter, Erica Nicole Walborn; and it appearing to the Court that the Parties are in agreement as evidenced by the signatures of counsel hereto it is hereby ADJUDGED, ORDERED and DECREED that: (I) Petitioner and Respondent shall share joint legal custody of Erica, with \ Petitioner as the primary custodial parent and Erica principally residing with the Petitioner, Brian G, Walborn; PROVIDED, HOWEVER that in the event of either Party's death, custody shall automatically vest with the other. and in the event Petitioner sustains a significant and long-tenn disability rendering him incapable of caring for Erica, then custody shall automatically vest in Respondent, Deborah L Walborn. Although Petitioner has primary physical ;;Gi;t~ of Erica, and shall have \. g.. authority to make routine decisions regarding her welfare, he agrees to consult with Respondent on non routine decisions (to be defined as those decisions with a greater than a day to day effect, including but not limited to, such matters as surgery, major medical treatment and selection of schools) with a view to arriving at a hannonious policy calculated to promote the best interest of Erica, If a dispute arises as to any matters regarding Erica, then Petitioner may exercise final detennination subject to review of a court of competent jurisdiction, (2) In the event that the respondent resides within a four (4) hour radius (to be . l"e..i<~(e. defined as time of travel in an automobile from one reai~eRt to the other) of the Petitioner's residence, Respondent shall be entitled to exercise visitation with Erica subject to the following schedule and subject to respondent establishing a pennanent place of residence with adequate accommodations for the child lie: a residency established in the home of a I' Ii 'I b ~\..~I""'rl'\. ~..I-\}t\. r.".I....;f........~4" re alive or ann y mem er:'" ) A. Such rights of visitation shall include every other weekend; four: (4) weeks during the summer months and holidays according to the schedule set out below. B. The weekend visitation shall begin between 5:30 p,m. and 6:30 p,m, on Friday, at which time the Respondent shall pick up Erica from the Petitioner's residence; and the weekend visitation shalltenninate between 7:00 p,m, and 8:00 p,m, on Sunday, at . which time the Respondent shall transport Erica to the Petitioner's residence, C, En.skr - The Petitioner shall have Erica for Easter (to be defined as commencing at 7:00 p.m, on the last day of school before Easter Sunday and ending at 7:00 p,m. on the last day of vacation before school reconvenes) in even years and the Respondent shall have Erica for Easter in odd years. The vacation period shall be detennined by reference to the school calendar for the public school system in which Erica resides. Transportation shall be as agreed upon by the Parties. '=-)~ 4V 0, Thanks~ivin~ - The Respondent shall have Erica for Thanksgiving (to be defined as commencing at 7':00 p,m, on the last day of school before Thanksgiving ~ 2 Day and ending at 7:00 p,m, on the last day of vacation before school reconvenes) in even years and the Petitioner shall have Erica for Thanksgi ving in odd years, The vacation period shall be detennined by reference to the school calendar for the public school system in which Erica resides, Transportation shall be as agreed upon by the Parties, E, Christmas - The Parties shall equally divide the Christmas holiday (to be defined as the period of time during which Erica is on vacation from school). In even years, the respondent shall have Erica during the first half of the Christmas holiday and the Petitioner shall have Erica during the second half of the Christmas holiday, In odd years, the arrangement shall be reversed, The vacation period shall be detennined by reference to the school calendar for the public school system in which Erica resides, Transportation shall be as agreed upon by the Parties, F. Summer Vacation - In each year in which Respondent resides within , a four (4) hour radius of the Petitioner's residence, each Party shall be entitled to twenty- eight (28) days of uninterrupted time during the summer with Erica for the purpose of , exercising a vacation, The Parties agree that said period of time shall be taken in two (2) non-consecutive two-week periods, In odd years, the Respondent shall notify the Petitioner of her summer vacation on or before May I sl. On or before May 15th in odd years, the Petitioner shall notify the Respondent of his summer vacation. This arrangement shall be reversed in even years, Transportation shall be as agreed upon by the Parties, G. Notwithstanding the foregoing, in each year, the Respondent shall be entitled to have Erica on Mother's Day; and the Petitioner shall be entitled to have Erica on Father's Day, Transportation shall be as agreed upon by the Parties, 3 H. In each year, the Parties will make every reasonable effort to insure that each Party has time with the child for the purpose of celebrating her birthday. I. If the holiday/summer vacation schedule set forth in the paragraphs above conflicts with the weekend visitation schedule set forth above, then the holiday/summer vacation schedule shall control. (3) In the event that the Respondent resides outside ofa four (4) hour radius of the Petitioner's residence, Respondent shall be entitled to full and liberal visitation as agreed to between the Parties, Such visitation shall include but not be limited to the following, but commencement of visitation shall be subject to Respondent establishing a pennanent place of residence with adequate accommodations for the Childfl."~ (;1,183, a residency ~ established in the home of a relative or family member.sa-Jkuml'l) "itk tkis retmpnt; . 0 5\......\\ 1..""1'\~ ,,";~4-I.i) ~"-'I.....,.o..J Easter - The Petitioner shall have Erica for Easter (to be defined as . commencing at 7~0 p.m, on the last day of school before Easter Sunday and ending at 7:00 A, ~ p,m. on the last day of vacation before school reconvenes) in even years and the Respondent shall have Erica for Easter in odd years, The vacation period shall be detennined by reference to the school calendar for the public school system in which Erica resides. The cost of transportation shall be borne by the Respondent and Respondent shall ensure that whatever arrangements are made for transportation of the child are made and paid for in advance, including specifically payment in advance for transportation to return the child to Petitioner following the end of the visitations period, i ~ ~ -~ r" ~ \... \.<".... ~ ~ -,'0 11~ "",-<........,> e.u....... ~"'-"'- "'~\....,.oM.C'\..\\~. '\ 4 , B, Thanksl:ivinl: " The Respondent shall have Erica for Thanksgiving (to be defined as commencing at 7:00 p,m. on the last day of school before Thanksgiving Day and ending at 7:00 p.m. on the last day of vacation before school reconvenes) in even years and the Petitioner shall have Erica for Thanksgiving in odd years. The vacation period shall be determined by reference to the school calendar for the public school system in which Erica resides The cost of transportation shall be borne by the Respondent and Respondent shall ensure that whatever arrangements are made for transportation of the ehild are made and paid for in advance, including specifically payment in advance for transportation to return the child to Petitioner following the end of the visitations period, i~ -4-.-~"fo(k\....;",\ ',\. \'1 ,,^-(..c...M.~ ,,:),..1.......4..........u......J........\.:?\~ C, Christmas" The Parties shall equally divide the Christmas holiday (to be defined as the period of time during which Erica is on vacation from school), In even years, the Respondent shall have Erica during the first half of the Christmas holiday and the Petitioner shall have Erica during the second half of the Christmas holiday, In odd years, , the arrangement shall be reversed, The vacation period shall be determined by reference to the school calendar for the public school system in which Erica resides. The cost of . transportation shall be borne by the Respondent and Respondent shall ensure that whatever arrangements are made for transportation of the child are made and paid for in advance, including specifically payment in advance for transportation to return the child to Petitioner following the end of the visitations period1',I: ~ "-- ,. f .. ( \. "- ~ 0",- '.s \, J ""'.......... ~ (\ t~....... d--t......... <<..........\..0 ",",-o\"'" \ ca . ~I\'.J 0, Summer Vacation" In each year in which the Respondent resides outside of a four (4) hour radius of the Petitioner's residence, the Respondent shall be entitled to five (5) weeks of swnmer visitation with Erica. The cost of transportation shall be borne by the Respondent and Respondent shall ensure that whatever arrangements are 5 if) BRIAN G. WALBORN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO, 97-2526 CIVIL TERM DEBORAH L. WALBORN. Defendant CIVIL ACTION - LAW CUSTODY /VISIT A TION JUDGE PREVIOUSLY ASSIGNED: None CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b). the undersigned Custody Conciliator submits the following report: 1, The pertinent information concerning the child(ren) who is(are) the subject of this litigation is as follows: NAME BIRTHDATE CURRENTLY IN CUSTODY OF Erica Nicole Walborn December 15, 1991 Plaintiff 2, A Conciliation Conference was held on July 24, 1997, and the following individuals were present: the Plaintiff and his attorney, Jeanne Wigbells, Esquire; the Defendant appeared with her attorney, Leslie Scherr, Esquire. 3, Items resolved by agreement: None. 4, Issues yet to be resolved: An ultimate custody and visitation schedule, 5, The Plaintiff's position on custody is as follows: Plaintiff indicates that he has been operating under an agreed upon Order of Custody dated March 29, 1995, which was entered in Prince William County, Virginia, The child has resided in Cumberland County. He filed a custody action to confirm the jurisdiction of Pennsylvania and wanted to continue to proceed on the existing order. 6, The Defendant's position on custody is as follows: Defendant believes that the jurisdiction should remain in Virginia, She also alleged that Plaintiff has violated the prior order, Apparently there is an action filed in Virginia to modify the Order requesting a transfer of custody based upon this alleged contempt of the existing Order as well as a contempt proceeding against Plaintiff, 7, Need for separate counsel to represent child(renl: Neither party requested. 8. Need for independent psychological evaluation or counseling: None requested and the Conciliator does not believe any is necessary, 9. A hearing in this matter will take one,half day. 10. Other matters or comments: This is a case concerning jurisdiction. The basic facts are that the child has resided here for two years and that the parties have been operating under an Order that was entered in Virginia in 1995, The child, however, has resided primarily in Pennsylvania for the last two years, Date: August 1, 1997 r/ (~C , ./ ichael L. Bangs Custody Conciliator (jAUG 0 4 1997 ~IJ(:HAEL I.. RANGS A"I'OII:\El' AT I.AW August 1, 1997 :1112 SOI:1'II IHTII STIIH;r . CMtr 1111,1. I'A 171111 l'1I0:\E 717-7:\II.nlU FAX 717-7:\II-7:n.\ Richard J. Pierce, Court Administrator Cumberland County Court House One Courthouse Square Carlisle, PA 17013 RE: Walborn v. Walborn No. 97-2526 Civil Term Dear Rick: The above case involves an initial question of jurisdiction. Therefore, it needs to be assigned to a judge for disposition of that issue alone. If the court determines that Pennsylvania should assume jurisdiction, then it can be referred back through the conciliation process, I believe that there is a competing action filed in Virginia which is to be heard the first week of October. Therefore, it may be best to try to schedule a hearing on the jurisdiction issue as quickly as possible so that the parties can determine whether or not they need to litigate the enforcement issues that have been filed in Virginia. vv~~m Michael L. Bangs wsc Enclosure BRIAN G. WALBORN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DEBORAH L. WALBORN, Defendant NO. 97-2526 CIVIL TERM ORDER OF COURT AND NOW, this ~~ day of December, 1997, it appearing that the Virginia Court has declined jurisdiction in this case and that the above-captioned motion is being referred to the custody conciliation process, the hearing scheduled in this court for December 11, 1997, is CANCELLED. BY THE COURT, Jeanne B. Wigbels, Esq. Law Office of Patrick F. Lauer, Jr., Esq. 2108 Market Street Aztec Building Camp Hill, PA 17011 Attorney for Plaintiff Leslie Scherr, Esq. 815 Connecticut Avenue, N.W. Suite 500 Washington, D.C. 20006-4004 /Ouk..'t: m~1 l'<c/, duel G.'f,rs /{'I2.~7L{y G,u",..u 1~J.j/92 Deborah L. Walborn 10 Cumberland Estate Road Mechanicsburg, PA 17055 Defendant, Pro Se :rc I: BRIAN G. WALBORN, Plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . . VS. : No. 97-2526 CIVIL TERM DEBORAH L. WALBORN, Defendant CIVIL ACTION - LAW CUSTODY/VISITATION ORDER You, Deborah L. Walborn, Defendant in the above-captioned custody action, have been sued in court to obtain custody of the following child: Erica Nicole Walborn. You are ordered to appear in person at on the day of 1997, at .M. for a Conciliation or Mediation Conference. a Pre-Trial Conference. a Hearing before the Court. If you fail to appear as provided by this Order, an Order for custody may be entered against you, or the Court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT 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 COUNi'Y COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PENNSYLVANIA 170lJ (717) 240-6200 BRIAN G. WALBORN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 97-2526 CIVIL TERM vs. DEBORAH L. WALBORN, Defendant CIVIL ACTION - LAW CUSTODY/VISITATION MEMORANDUM OF LAW REGARDING JURISDICTION AND NOW, the Plaintiff, Brian G. Walborn, by and through his attorney, Jeanne B. Wigbels, Esquire, files this Memorandum I. FACTUAL BACKGROUND On March 25, 1995, an agreed Order of Custody was entered in Prin-:e Williams County, Virginia. The Virginia Order granted primary physical custody to Brian G. Walborn, Plaintiff in the instant action, who resided in Pennsylvania at the time the order was entered. Since that time, the child has continued to reside with Plaintiff in Pennsylvania. On May 12, 1997, Plaintiff filed a Complaint for Custody in Cumberland County at the above term and docket. A conciliation conference was held on July 24, 1997 before Michael L. Bangs, Custody Conciliator. Since the Defendant opposed jurisdiction in Pennsylvania, an order was entered on August 5, 1997, directing a hearing to be echeduled on December 11, 1997. Since that time, the Juvenile and Domestic Relations Court of Prince William County, Virginia, entered an order dismissing a custody petition filed by Deborah L. Walborn, Plaintiff in the instant action, for lack of jurisdiction. See Exhibit A. II. ISSUE IjOI.~-1l-:~9,;" 11:5':0 (QiFTCII ::. WLIIICi 703494 2103 P,C2-03 VIRGINIA: IN THE JUVENILE AND DOMESTIC RELA nONS COURT OF PRINCE WILLIAM COUNTY TN RE: Erica Nicole Walborn ) ) Case ~o_ J51313 ORDER OF DISMISSAL FOR LACK OF JURISDICTION THIS CAUSE came before the Court upon the motion of Respondent. Brian Walborn, by counsel, requesUllg this Court dismiss the pefition for custody of lite minor child at issue herein since a petition relatir.!l to the custody of this child i. 1\ml was previously pcndine before an appropriate court in Pennsylvania where Respondent resides \\llb the minor child. or in the lIllernafive, for the Court to !IIake a finding that the 'I Pennsylvania court is the more appropriate forum to detennine the cu~tody uf said child; -' and IT APPEARING TO the Court lh"1 respondent l~ had custody of said child pursuant to " consent decree entered by this Court on March 29. 1995 lInd has resided Wilh 111~ chil,I in the state ofP~nnsylvarja since that time and that Clll action rciatini: to the custody 0: said child is presently pendius in the state of Pennsylvania, and upon the Court's inquiries to the Court in Pennsylvania where the custody actiull is pending, that Pennsylvania is the more convenient forum to detennine the custody of the child at issue; it is therefore ADJUDGED, ORDERED AND DECREED, that th:s Court declines jurisdiction to hear this matter 011 lh: basis of the maner being pendin~ before n coun of competent ,'...."''''...- BRIAN 0. WALBORN. Plaintiff IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYL VANIA ) ) ) ) ) DEBORAH L. WIMBERLY (WALBORN) ) Delcndant ) ) vs. NO. 97-2526 CIVIL TERM CIVIL ACTION - LA W CUSTODYIVISIT ATION JUDGE PREVIOUSLY ASSIGNED: The Ilonorable J. Wesley Oler. Jr. CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE I9l5.3-8(b).the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child(ren) who is(are) the subject of this litigation is as follows: NAME BIRTHDATE CURRENTLY IN CUSTODY OF Erica Nicole Walborn December 15. 1991 Plaintiff 2. A Conciliation Conference was held on January 22. 1998. and the following individuals were present: the PlaintitTand his attorney. Jeanne' Wigbells. Esquire; the Defendant appeared with her attorney. Cindy Koser. Esquire. 3. Items resolved by agreement: None. 4. Issues yet to be resolved: An ultimate custody schedule. 5. The Plaintin's position on custody is as lil110WS: Father has been the primary custodial parent of the parties' minor child. Erica. who is now six years old. since February of 1995. Thc partics Imvc bccn opcrating undcr an (lrdcr that thcy agrccd upon in Virginia which csscntially providcs Mothcr with cvcry othcr wcckcnd and cxtcndcd timc over thc summer. He belicvcs that schcdulc is in thc bcst intcrcst of his daughtcr and should rcmain. 6. Thc Dcfcndant's position on custody is as lill1ows: Mothcr bclicves that the existing schedule should bc changcd bccausc shc has a changc in circumstanccs. Shc is rcmarried and now is not working outsidc of thc homc. This is not duc to an additional child under her care but beeause of the economic circumstances that exist bctwecn hcr and hcr ncw husband. She believes that it is bctter for Erica to bc with her in Fairfax County primarily sincc she is able to be at home for Erica. She believes that Erica is bounced around too much in the existing schedulc because of Father's work schedule which occasionally rcquires him to work on the wcekcnds and the evenings. When Father is working. thc child's grandparents watch her. 7. Need for separate counsel to represcnt child(ren): Ncither party requested. 8. Need for independent psychological cvaluation or counseling: None rcquested and the Conciliator docs not belicve any is ncccssary. 9. A hearing in this mattcr will take onc day. 10. Other matters or commcnts: Thc Court originally rcvicwed this casc on the basis of jurisdiction. Howcvcr, thc Court waitcd until Virginia madc a dccision as to whcther or not they would retain jurisdiction. Virginia dctcnllincd that thc jurisdiction should bc in Pcnnsylvania as a rcsult ofthc fact that thc child has lived hcrc ti,r somc timc. Thc partics have bccn opcrating undcr an Ordcr lrom Virginia whcrcby Fathcr has primary physical custody and r-.lothcr has thc child cvery othcr \\cckcnd and lilr lilur wccks 0\'Cr vs No. 97 - 2526 Civil Term BRIAN G WALBORN. Plaintifr IN THE COURT OF COMMON PLEAS OF CUMBERl.AND COUNTY. PENNSYLVANIA DEBORAH WIMBERLY tka DEBORAH L WALBOR:'\. Defendant . CIVIL ACTION - LAW . CUSTODYIVISIT A TlON AND NOW, this upon consideration ORDER 2.. CJ H., ~!~y of _~~, 1998, of the attached Petition, this matter is continued generally, T~e heari~g scheduled fcc April 30, 1998 is canceled. Upon written request of either party, withi~ thirty (30) days of the date of this o~der, this ~atter ~ay again he presented for consideration. BY TEE COU~l: 1JiL'?U~ f.;I::')<~,-i'!C':: CO: "'" -. "':"'Rf C'1 'c-' "':1 ,~; !:J' I Q .\;}. '.. Ii.. H' .. CUI"..,. .' ~:'::Y r[\':: .<....:" ~~ \3'" ' ~'1 ut "t 4 F= ,- .:") L- r:: / to::: " &- tJJc. i~ .~ --' ..' ( I ~.::: l.j ~:~ r~';.' .1 .J..' - - ~j';' 0.. c. ~-j 2~;~ rr:;) . '" '1 . -' (. ~. cr.!';: c--: . '\<-, .L L. t' 00:. p.i: w. -. 0 ro ::-, '" 0 BRIAN G. WALBORN. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA vs No, 97 - 2526 Civil Term DEBORAH WIMBERLY tka DEBORAH L WALBORN, Defendant . CIVIL ACTION - LAW , CUSTODYIVISITATION ORDER AND NOW, this _.?tl.,day of .:r\.Vll"" , 1998, upon consideration of the attached STI?U~ATION FOR AN AGREED ORDER OF CUSTODY, it is hereby ORDERED that the terms and conditions of the attached StlPuia:ion are adopted in their entirety and incorporated herein by reference as if set forth at length and are ha~eby ~ade a~ c~d~~ ~~ ~his ::~r:. ,.,.,..-. ..... J.:-!:" " BRIAN G. WALBORN. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA VS, No 97 - 2526 Civil Term DEBORAH WIMBERLY tka DEBORAH L. WALBORN. Defendal:t , CIVIL ACTION - LAW . cUSTODYIVISITATION STIPULATION FOR AN AGREED ORDER OF CUSTODY AND NOW, the parties, having reached agreement as to the best interest of their daughter, Erica Nicole Walborn, hereby stipulate and agree as follows: 1. The parties shall continue to share joint legal custody of Erica, consul:ing with one another on all major decisions affecting their daughter. If a dispute arises as to any matters regarding Erica, the primary custodial parent may exercise final determination subject to review of a court of competent jurisdiction. 2. Primary custody shall be with Mother, Deborah L. Wimberly, effective the end of the 1997-98 school year. If the first weekend following the last day of the school year is Mother's regularly scheduled weekend, primary custody will transfer to Mother on Friday evening when she picks up Erica. If the first weekeni following the last day of the school year is Father's weekend. Father will deliver Srica tc Mother's residence on Sunday evening between 7:00 p.m. and 8:00 p,m. 3. Father, Brian G. \~alborn, is entitled to partial custody every other weekend from 5:30 p.m. on Friday until 8:00 p.m. on Sunday. .. 4. The parties agree to the following schedule for holidays and vacations, and further agree that this schedule takes precedence over the regular weekend schedule. (a) Easter - Easter vacation, commencing at 7:00 p.m. on the last day of school before Easter Sunday and ending at 7:00 p.m. on the last day of vacation before school reconven~s, shall be with Father every year. (b) Mother's Day - Mother shall be entitled to have Erica every year on Mother's Day. (c) Father's Day - Father shall be entitled to have Erica every year on Father's Day. (d) Thanksgiving - Thanksaiving vacation, commencing at 7:00 p.m. on the last day of school before Thanksgiving Day and ending at 7:00 p.m. on the last day of vacation before school reconvenes, shall be with Father in all even years and with Mother in all odd years, (e) Erica's birthday - The parties will make every reasonable effort to insure that each party has time with Erica for the purpose of celebrating her birthday. (f) Christmas - Christmas vacation, commencing the last day of school before Christmas Day and ending at 7:00 p.m. on the last day of vacation before school reconvenes, will be divided equally between the parties. Mother shall have the first half and Father shall have the second half in all even years. Father shall have the first half and Mother shall have the second half in all odd years. (g) Summer Vacation - t~other is entitled to twenty-eight days of t:ninterrupted t imp \-lith Erica during the summer for the purpose of vacation. The parties agree that this time shall be taken in two (2) non-consecutive two-week periods. Father shall be entitled to forty-two days of uninterrupted time wit!: Erica during the summer for the purpose of vacation. The parties agree that this time may be taken as Father's wo~k schedule permits, provided that no period exceeds two weeks, and sufficient time remains fo~ Mother to enjoy her two (2) two-week periods. In all even years, Father may notify Mother of his vacation plans on or before May 1 ' and Mother shall notify Father of her vacation plans on or before May 15". In all odd years, Mother shall notify Father of her vacation plans on or hefore May l' . Once Mother's vacation schedule has been determined, Father is free to schedule his vacation time with Erica as his work schedule permits. Mother will make every effort to accommodate Father's schedule. However, if Mother has made prior plans, such plans prevail unless Father provides a minimum of t~o weeks notice of his vacation plans. 5. Transportation - The responsibility for transportation shall be shared by the parties with Mother providing transportation for every third trip and Father providing the balance of the transportation. 6. When Erica has schoolwork or nrojects she is working on for school or ex~ra-curric~ldr activities, she will take the necessary books and supplies with her when visiting Father in order that Father may participntP in sllch nctivities with he~. 7. \'1hen EricE! is "it!! nL? penty, the other party shall have the ri'Jht to teleplwne dnli s"ea~: \1ith Erica at all i I i i '. VI ~ I .' .-) . -J . - ..=t: 11J' J.. '1 ' ,. :,,2 f€) ., - -:--1: I'... '-,,\-j t ]l; .'s:: .1' "(I) r,~' )" .'. 1..J r'z , .;11J,J Le. , '" , j Ll. 4 . .:> m ::l <.. m 0 F