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HomeMy WebLinkAbout97-03997 ~ " ~ \) ~ ~ ~ ""=: vj ~ v cv Q } '..{ ! J J t'-- (J- 0"- "l , I t-i ~! ) { f f 1 <i '\ ';;j- '-U >- ,"':' ::t- o; u-: ..... 'j-. i'"~ ~ In .",,'".: (.~ \;) ~~ - ( 1 ~ a '0 ':) - ~;' '.l..., , .I ~ "0 -A ~ .. , ( (~ , , ~ el' N Old V, ~ ~ u;~..> _J1, .' .:::r t;:.. _ I ::1 ;.'J. ~- ~ ~ "' ...:It t"./ IJ. r- , .~ U 0' V . . . . . . .J",l * , . . . , ERIC M. LEPORE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No.Q7-31Q7 ~~9;r~NWV PLAINTIFF v. MICHELLE M. SOLLENBERGER DEFENDANT CIVIL ACTION - CUSTODY ORDER OF COURT \ "? . AND ROlf, I d'l '::.\ ,1997, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before D\,~ ll'\ ~~. ,\\. )''\c\u'-.{ , Esquire, the Conciliator, at ~,C'1 '..-J \'\C\\;" \,' M{'( I {I(\" ',iI i D TThe , Pennsylvania, on the .s day Of<JC'f ~",' x.",(" r , 1997, at J G CJ -fl-.m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a Temporary Order. All children age five or older shall also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent Order. FOR THE COURT: ~- By: r-.j::\f\I\J'f\ ~\ ~IA-n~ Custody conciliatot~ YOU SHOULD TAU THIS PAPER TO YOUR LAKYER AT ORCE. IF YOU DO ROT RAVJI: A LAKYER OR CANlfOT AFFORD on, 00 TO OR HLlPHOn THE OF'ICI: Sft FORTH 81LOM TO 'IRD OUT DERE YOU CAlI 01'1' LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR CUMBERLAND COUNTY COURT HOUSE FOURTH FLOOR CARLISLE. PA 17013 (717) 240-6200 " Robert Rudisill, stepfather Linda Rudisill, mother The relationship of Defendant to the child is that of natural mother. Defendant currently resides with the following persons: Name Relationship Christopher H. Zeigler, son Joseph H. Powley, son 4. 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. S. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 6. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or who claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: Plaintiff is a fit parent. The Plaintiff has been the primary care giver since birth. The child does not see Defendant as a source of love and affection. Placing custody with Plaintiff will provide continuity, stability and certainty to the child's life. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff requests this Court to grant legal and physical custody of the child to Plaintiff. Respectfully submitted, I~~~ . (\~ __~~- , r S. Fen ce, Bsqu re Attorney for Plaintiff 2917 North Front Street Harrisburg, PA 17110 (717) 234-2401 ID 121358 I hereby verify that the facts contained in the foregoing Petition are true and correct to the best of my knowledge, information and bellef. I understand that false statements contained herein are made subject to the penalties contained in 18 Pa, C, S. Section 4904 relating to unsworn falsification to authorities. " ! 1 \-<~..1 <...."],{ /, '-.>"('0).1(" \.' Eric H. Lepore Date: 1,6,3):; 7 i/ I .,... . ,,; c s:: i-' UJ~ ~ [..=.: u' (.1: ~ ~<)f:: -.....:; T' e,r'" In In, N a;' 1:.. Ii. .." ~ V, t:; ~ .', ~... - .. ....."""" -'. -.J o II " ~~ ~ ~~I . II ~I . ~ 0. ~~ I. r '" .., , ~~ii~1 I ~~ 'I .glJi~ II ... I ,,ft ,i :,.' t1; :; ... .,.,..! . ... . ~i I! 2l~ ~ 4J ~ ~"t'f 'oS ~ i.J~ B~ .C! :! j Ii : r lC ~I!~ ~:ll ~ ro'" I O\U . ~ . lC U ~ S ... i5 lC , . . " -.-----.-. -.,----., ) t ~ .. , (, ERIC M. LEPORE, . IN THE OOURT OF COOMCtl PLEAS OF . Plaintiff . CUMBERLAND CXXJNTY, PENNSYLVANIA . . . vs. : NO. 97-3997 CIVIL TERM . . MICHELLE M. SOLLENBERGER, . CIVIL ACTION - LAW . Defendant . IN CUsroDY . aulER OF cxxm AND lUf, this day of upon consideration of the attached Custody ordered and directed as follows: , 1997, Conciliation Report, it is .. 1. A Hearing is scheduled in Court Roan No. , of the CI.Iltlerland COUnty Court House, on the day of , 1997, at o'clock, .m., at which time testimony in this case will be taken. At the Hearing, the Father, Eric M. Lepore, shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be called to testify at the Hearing, and a sunrnary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten (10) days prior to the Hearing date. 2. The prior Order of this Court dated Septenber 5, 1997 and entered under Docket No. 97-4027, (Protection From Abuse and CUstody) shall continue in effect pending further Order of Court or agreement of the parties with the modifications and additions set forth below. 3. The Father shall have additional periods of partial custody of the Olild during alternate weeks following the Mother's periods of weekend custody, fran Monday at 7:30 p.m. until Tuesday at 7:30 a.m. 4. paragraph 7 of the Septenber 5, 1997 Order is vacated and replaced with the following provision: Upon providing at least two (2) weeks advance notice to the other party, each party ehall have the right to have custody of the Olild for one (1) week durilliJ each sunmer to include two (2) wekend.s. 5. Each party allall keep the other party appriHd of his or her current addreas and telephone nunCer. 6. The parties and their counsel ehall _t with the custody \-\\', ~--^-'(' e. \ \\,')~tc- r ", l 'Jel''\')' ~.) \, I ,\, " , , ., .\" (\ ,\.\("'th"\("] '. .\..\' \ ,\ '. '- , ' \ \.,'\ \ !.\, ~ It' C' "\Y 'el \ . . ' \ . (J"\h'lTlY e . \ (" ':.('\(, \\.-.-,' \ f' l., \, r iI( e.. , (q '\ . , ' r-\ h \ .. . \ I.....'\;' ,-," 1 ERIC M. LEPORE, . IN THE CXlURT OF CCX>lMOO PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. . NO. 97-3997 CIVIL TERl'I . MICHELLE M. SOLLENBERGER, . CIVIL ACTION - LAW . Defendant : IN CUSTODY PRIOO JUDGB: GeclI:ge E. Hoffer ama:JY <DlCILIATIOO SlJMARY REP(Rl' IN AaDUlANCE wrm aJlBBRLAND o.:umc RIlLE CP CIVIL m- ...-- 1915.3-8, the undersigned CUstody Conciliator submits the following report: 1. '!he pertinent information concerning the Child who is the subject of this litigation is as follows: NAME twl'E CP BIRTH amm!'Ly IN ama:JY CP Thanas A. Lepore March 12, 1997 Plaintiff/Mother 2. A Conciliation Conference was held on SepteaDer 3, 1997, with the following individuals in attendance: the Father, Eric M. Lepore, with his counsel, Mark S. Fenice, Esquire, and the Mother, Michelle M. Sollenberger, with her counsel, Jan Terpening, paralegal and Lisa Neeber, legal intern. 3. Prior to the Conciliation Conference, the parties signed a COnsent Agreement in Protection Fran Abuse proceedings under Docket No. 97-4027. This Court adopted the provisions of the COnsent Agreement as a separate CUstody Order on SepteaDer 5, 1997. The SepteaDer 5, 1997 Order reflects the parties' agreement on custody arrangements to be in effect pending Hearing or further agreement of the parties in this matter. Although there were discussions concerning a IOOre shared custody arrangement at the Conciliation Conference, each party continues to seek primary filysical custody of the Child and therefore it will be necessary to schedule a Hearing. On the other hand, it was apparent at the Conference that the parties are in the midst of a transition period (having recently separated) and it was determined that a second Conciliation Conference would be useful to assist the parties in their ongoing custody negotiations in the hope that the Hearing will not ultimately be necessary. Pending the second Conciliation Conference, the parties agreed to continue the custody arrangements set forth in the SepteaDer 5, 1997 Order with certain lOOdifications as reflected in the attached proposed Order. a~~,-~ Dawn S. Sunday, E8qu CUstody Conciliator ~fJ6nW' ~ /997 Dat ~ ERIC M. LEPORE, . IN THE COURT OF CCX>1MON PLEAS OF . Plaintiff . CUMBERLAND COONTY, PENNSYLVANIA . . . VS. . NO. 97-3997 CIVIL TERM . . . MICHELLE M. SOLLENBERGER, . CIVIL ACTION - LAW . Defendant . IN cusrooy . aIDER OP cnm l\IlD !Of, this day of upon conaideratiCXl of the attached CUstody ordered and directed as follows: , 1997, eonciliatiCXl Report, it is 1. A Hearing is scheduled in Court Roan No. , of the CtIltlerland County Court House, CXl the day of ' , 1997, at o'clock, .m., at which time testiroony in this case will be taken. At the Hearing, the Father, Eric M. Lepore, shall be deemed to be the moving party and shall proceed initially with testilOOlly. Counsel for the parties shall file with the Court and opposing counsel a Metrorandun setting forth each party's positiCXl CXl custody, a list of witnesses who will be called to testify at the Hearing, and a BUIlIllary of the anticipated testillDny of each witness. These Memoranda shall be filed at least ten (IO) days prior to the Hearing date. 2. The prior Order of this Court dated SepteriJer 5, 1997 and entered under Docket No. 97-4027, (protectiCXl Fran Abuse and CUstody) shall continue in effect pending further Order of Court or agreement of the parties with the modifications and additiCXls set forth below. 3. The Father shall have additional periods of partial custody of the Olild during alternate weeks following the Mother's periods of weekend custody, fran Monday at 7:30 p.m. until Tuesday at 7:30 a.m. 4. Paragraph 7 of the SepteriJer 5, 1997 Order is vacated and replaced with the following provisiCXl: Upon providing at least two (2) weeks advance notice to the other party, each party shall have the right to have custody of the Olild for one (I) week during each slIIIlIl!r to include two (2) weekends. 5. Each party shall keep the other party apprised of his or herÿC""Tent address and telephone nll1ber. 6. The parties and their counsel shall meet with the CUstody ERIC M. LEPORE, : IN THE CXXlRT OF WIMON PLEAS OF Plaintiff : CUMBERLAND COONTY, PENNSYLVANIA : vs. . NO. 97-3997 CIVIL TERM . . . MICHELLE M. SOLLENBERGER, . CIVIL ACTIOO - LAW . Defendant . IN CUS'roDY . PRIOO JUDGE: GeoI:ge B. Hoffer cumDr CXH:ILIATI~ stIlMARY REPCRT IN ACa:RIlANCB WI'l'8 aJoIBBRLAND CXlmY RIlLE a;' CIVIL PW:...... "..lIB 1915.3-8, the undersigned CUstody Conciliator sutxnits the follOlling report: 1. 7he pertinent information concerning the Child who is the subject of this litigation is as follOlls: NA/IIB DATE a;' BIRTB C1IUU!NB.Y IN Cu:uun' a;' ThaIIas A. Lepore March 12, 1997 Plaintiff/Mother 2. A Conciliation Conference was held on SeptE!lltler 3, 1997, with the follOlling individuals in attendance: the Father, Eric M. Lepore, \lith his counsel, Mark S. Fenice, Esquire, and the Mother, Michelle M. Sollenberger, with her counsel, Jan Terpening, paralegal and Lisa Neeber, legal intern. 3. Prior to the Conciliation Conference, the parties signed a Consent Agreement in Protection From Abuse proceedings under Docket No. 97-4027. This Court adopted the provisions of the COl'lsent Agreement as a separate CUstody Order on SeptE!lliJer 5, 1997. The SeptE!lltler 5, 1997 Order reflect.s the parties' agreement on custody arrangements to be in effect pending Hearing or further agreement of the parties in this matter. Although there were discussions concerning a more shared custody arrangement at the Conciliation Conference, each party continues to seek primary lXlysical custody of the Child and therefore it will be necessary to schedule a Hearing. On the other hand, it was apparent at the Conference that the partil!8 are in the midst of a transition period (having recently separated) and it was determined that a second Conciliation Conference \/Ould be useful to assist the parties in their ongoing custody negotiations in the hope that the Hearing will not ultimately be necessary, Pending the second Conciliation Conference, the parties agreed to continue the custody arrangements set forth in the SeptE!lltler 5, 1997 Order with certain modifications as reflected in the attached proposed Order. .c;~~/rr~~f Dawn S. 5 y, Esqul CUstody Conciliator 5V 17H'.in WI ~ If 9 7 Dat' ERIC M. LEPORE, Plaintiff IN THE OOURT OF COMMON PLEAS OF : CUMBERLAND CCXJNTY, PENNSYLVANIA . . vs. NO. 97-3997 CIVIL TERM . . MICHELLE M. SOLLENBERGER, Defendant : CIVIL ACTION - LAW : IN CUS'lOOY mDER <P <nR1' AND 1Of, this day of upon COIlllideration of the attached CUstody ordered and directed as follows: , 1997, Conciliation Report, it is 1. A Hearin;! is scheduled in Court Roan No. , of the ClIItlerland County Court House, on the day of ' , 1997, at o'clock, .m., at which time testimony in this case will be taken. At the Hearing, the Father, Eric M. Lepore, shall be deemed to be the movin;! party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be called to testify at the Hearing, and a st.mnary of the anticipated testimony of each witness. These MenDranda shall be filed at least ten (10) days pdor to the Hearing date. 2. The prior Order of this Court dated Septentler 5, 1997 and entered under Docket No. 97-4027, (Protection Fran Abuse and CUstody) shall continue in effect pending further Order of Court or agreement of the parties with the modifications and additions set forth below. 3. The Father shall have additional periods of partial custody of the Olild durin;! alternate weeks following the Mother's periods of weekend custody, fran Monday at 7:30 p.m. until Tuesday at 7:30 a.m. 4. Paragraph 7 of the Septentler 5, 1997 Order is vacated and replaced with the following provision: Upon providing at least two (2) weeks advance notice to the other party, each party shall have the right to have custody of the Child for one (1) week durin;! each sumner to include two (2) weekends. 5. Each party shall keep the other party apprised of his or her current address and telephone n1.llber. 6. The parties and their counsel shall meet with the CUstody ERIC M. LEPORE, Plaintiff IN THE CXlURT OF c:ooMON PLEAS OF : CUMBERLAND COONTY, PENNSYLVANIA . . vs. : NO. 97-3997 CIVIL TERM . . MICHELLE M. SOLLENBERGER, Defendant : CIVIL ACTIOO - LAW : IN CUSTODY PRIClt JUDGE: George E. IIoffer ~'.1<&J1' CXH:ILIATICN ~ REPCRl.' IN Aa:XlUlAlCE WI'l'B cumERLllND anmr RULE a! CIVIL PllO"" .JRE 1915.3-8, the undersigned CUstody Conciliator sul:xrlts the follOlling report: 1. '!he pertinent information concerning the Child who is the subject of this litigation is as follOlls: tWlE DM.'E a! BlRl'H CUlREtll'Ly IN eu:.~UJi a! 'lhanas A. Lepore March 12, 1997 plaintiff/Mother 2. A Conciliation Conference was held on 5eptentJer 3, 1997, with the following individuals in attendance: the Father, Eric M. Lepore, with his counsel, Mark S. Fenice, Esquire, and the Mother, Michelle M. Sollenberger, with her counsel, Jan Terpening, paralegal and Lisa Neeber, legal intern. 3. Prior to the Conciliation Conference, the parties signed II Consent Agreement in Protection Fran Abuse proceedings under rxx:ket No. 97-4027. 1'l1is Court adopted the proviSions of the Consent Agreement as a separate CUstody Order en 5eptentJer 5, 1997. '!he SeptentJer 5, 1997 Order reflects the parties' ag.e.:u...nt on custody arrangements to be in effect pending Hearing or further agreement of the parties in this matter. Although there were discussions concerning a lllOre shared custody arrangement at the Ccnciliatien Conference, each party continues to seek primary physical custody of the Child and therefore it will be necessary to schedule a Hearing. Q'l the other hand, it was apparent at the Conference that the parties are in the midst of a transitien period (having recently separated) and it was determined that a second Conciliation Conference would be useful to assist the parties in their ongoing custody negotiations in the hope that the Hearing will not ultimately be necessary. Pending the second Conciliatien Conference, the parties agreed to continue the custody arrangements set forth in the Septerrtler 5, 1997 Order with certain lIo:Uficaticns as reflected in the attached proposed Order. ~"~.i~/H;, 't: /f97 a.- .Jj,~ Date Dawn S. ~Esquire' CUstody Conciliator e IJ~ 1II~ .. ~s~ .f at: ~ uiz~ ..,r-..- ...... t:: ~~:! : ! w << !i f IH~ ::>M .... 5H~ GI<< ,- ... w- Oo", <g~ '2 f ...~ 2... 'Eo( ...... tit[ II:!!! ;)...J a!i tf@ ",0 z 0 .._-- ~... . . . .. 1 ~ ~ , R JE~; ~ ~ ! ~ ft1 ~ e :: J ~ : ~ i~ ~ c ~~ ...~ " Q.." ... .z ~; "5 ~: ....l;f'J B:;J u~ a:6 v .... u ~ ~ ..;,..;-- ...- . . vJOEC 091997 ERIC M. LEPORE, . IN THE CXlURT OF ca-IMON PLEAS OF . Plaintiff . CUMBERLAND CCXJNTY, PENNSYLVANIA . . . vs. . NO. 97-3997 CIVIL TERM . . . MICHELLE M. SOLLENBERGER, . CIVIL ACTION - LAW . Defendant . IN aJSTOOY . aulBR <P <XlRT AND tDf. this 5th day of lle<:eni)er, 1997, the Conciliator, having not received a request by counsel for either party to reschedule the Conciliation Conference originally set for November 6, 1997, hereby relinquishes jurisdiction in this matter. FOR THE CXlURT, '"~~ CUstody Conciliator ~.