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DIANE G. RADcIJFF
ATtORNIlY AT LAw
,... Trlnd" \load
Camp Hill. PA 17011
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CHERYL L. JAMIESON
Plaintiff
NO. 97-57S6 Civil Term
V.
RICHARD D. JAMIESON
Defendant
CIVIL ACTION - LAW
IN CUSTODY
CERTIFICATE OF SERVICE
I hereby certify that a true 3nd correct copy of the Complaint
in Custody has been served upon the Defendant, RICHARD D. JAMIESON,
by Certified Mail, Restricted Delivery on the 30th day of October,
1997. The return receipt is attached hereto as Exhibit "AU and
made a part hereof.
DIANE G. RADCLIFF
3448 TRINDlE ROAD
CAMP Hill. PA 17011
1717) 737.0100
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EXHIBIT "An
DIANE G, RADCLIFF
3448 TRINDlE ROAD
CAMP Hill, PA 11011
11111131-0100
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COL~TY, PENNSYLV~lIA
CHERYL L. JAMIESON
Plaintiff
V.
RICHARD D. JAMIESON
Defendant
NO. q7 ~7g" t~Jd'h",
CIVIL ACTION - LAW
IN CUSTODY
ORDBR 01" COURT
AND NOW, THIS d~ day of 0<:. .lee) he r , 1997, upon
consideration of the attached Complaint, IT IS HEREBY DIRECTED that
the parties and heir respective legal counsel shall appear before
, \ (' ;: ( . , the conciliator, at
,\, on the ~ day
of \')(-( r"m'c,(' r , for a Pre-hearing
Custody Conference. At such conference an effort will be made to
resolve the issue 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 or
Children who are the subject of this custody action to the
conference, but the child's/children's attendance is not mandatory.
Failure to appear at the conference may provide grounds for entry
of a temporary or permanent order,
POR THB COURT I
~e6~~L~1TU~M\ft~.
X~lU SI0VH!.,iP8RT!!U..g~pn O~nY8~ x.alfl!~ AI ~tfC!PHOIP' X~i 8~F'8i
SiPFOR~"B LOW TQjI!W obt WHBRE YOU CAN SiT t~GAL ImLP.
OFFICE OF 1rcE COURT ADMINISTRATOR
CUMBER~~6liNt~og9URIHOUSE
~~i~rE~48~6~081
AMERICANS WITH DISABILITIBS ACT 01" 1990
The Court ofi Comll\.on Pleas of ~erlimdfPunfY ie reouired by taw
tOf comply w th bthe American w t D sap....1 o!s Actd Or 1990. or
in ormal :1:0 a ou ccess e a ~ t s a re so a le
gccommo~ltYons ava~labte to ~~sable~ 9t tvtauals Ravinq ~usYness
etore the court, piease contact our oft ce. . All a:z::ranl'le1nent.s must
~ m~de at least 72 hours Qr~Dr to any ear~ng or bus~ness betore
the court. You must attena the schedUled conterence or hearing.
DIANE Q, RADCLIFF
3448 TRINDlE ROAD
CAMP Hill, PA 17011
1717) 737.0100
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CHERYL L. JAMIESON
Plaintiff
V.
RICHARD D. JAMIESON
Defendant
NO : 1 ?- !J'? f'{~ LW' r:.-..
CIVIL ACTION - LAW
IN CUSTODY:
CUSTODY COMPLAINT
1. The Plaintiff is Cheryl L. Jamieson, residing at 1216
Way,
Mechanicsburg,
Cumberland
County,
Highlander
Pennsylvania.
2. The Defendant is Richard D. Jamieson, residing at 7996
Pleasant Court, Frederick, Maryland.
3. Plaintiff seeks custody of the following children:
NAME
PLACE OF RESIDENCE AGE D.O.B.
121S Highlander Way 13 6/16/64
Mechanicsburg, Pa 17055
Kelli Lynn Jamieson
The child was not born out of wedlock.
The child is presently in the custody of the Plaintiff,
Cheryl L. Jamieson who resides at 1218 Highlander Court,
Mechanicsburg, Pa.
During the past five years, the child has resided with
the following persons and at the following addresses:
ADDRESSES DATES
121S Highlander Way 12/92-present
Mechanicsburg, Pa 17055
The mother of the child is Cheryl L. Jamieson currently
PERSONS
Cheryl L. Jamieson
residing at 1216 Highlander Way, Mechanicsburg, Pa. 17055.
She is divorced.
DIANE G, RADCLIFF
3448 TRINDlE ROAD
CAMP Hill, PA 17011
17171737.0100
The father of the child is Richard D. Jamieson currently
residing at 7996 Pleasant Court, Frederick, Maryland. 21701,
He is married.
4. The relationship of Plaintiff to the child is that of mother,
The Plaintiff currently resides with the following persons:
NAMES
Kelli Lynn Jamieson
RELATIONSHIP
Daughter
5. The relationship of Defendant to the child is that of father.
The Defendant currently resides with the following persons:
NAMES
RELATIONSHIP
Wife
Step-son
Melody Jamieson
Travis Young
6. 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.
The parties did,
however, enter into a Marital Agreement on November 7, 1987,
which contains provisions pertaining to custody which
agreement was not entered of ~ecord as part of the parties'
Cumberland County divorce action, docketed to No. 3301 civil
1967. A true and correct copy of said agreement is attached
hereto, marked ~xhibit "A" and made a part hereof.
Plaintiff has no information of a custody proceeding
concerning the child pending in a court of this Commonwealth.
Plaintiff 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.
DIANE G. RADCLIFF
3448 TRINDlE ROAD
CAMP Hill. PA 17011
(7171 737-01QO
,
DIANE G. RADCLIFF
3448 TRINDLE ROAD
CAMP HILL. PA 11011
17171 737.0100
7. The best interest and permanent welfare of the child will be
served by granting the relief requested because:
a. The daughter is engaged in school projects and
extracurricular activities which make it difficult to
visit her father in Maryland on a rigid schedule.
b. The father and child have a strained relationship, with
the Child being afraid of and angry with her father.
c. The Child desires to have more control over the times she
is to see her father so that she can accommodate her
increasing educational and social requirements.
d. The parties are unable to reach agreements on major
decisions affecting the child's physical and emotional
well-being.
8. 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 the Court to grant primary
physical sole legal custody of the child to the Plaintiff
subject to such partial custody rights for the Defendant as
may be desired by the Child at such times as may be directed
by the Child.
Respectfully submitted,
,
Road
Hi! A 17011
(71 737-0100
Supreme Court ID No. 32112
,
,
VERIPICATION
Cheryl L. Jamieson verifies that the statements made in this
complaint are true and correct. She understands that false
statements herein are made subject to the penalties of 1S Pa. C.S.
4904 relating to unsworn falsification to authorities.
"
Date:
Cheryl L, Jamieson, Plaintiff
I'
DIANE G. RADCLIFF
3448 TRINDlE ROAD
CAMP Hill. PA 17011
1717)737.0100
YBJlIPICATIO.
Cheryl L. Jamieson vorifies that the statements made in this
complaint are true and correct. She understands that false
statements herein are made subject to the penalties of IS Pa. C.S.
Date:
10/13 h7
r f
falsification to authorities.
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Ehery\ L::~~~~~~~.l$~fntiff
4904 relating to unsworn
DIANE G. RADCLIFF
3448 TRINDlE ROAD
CAMP Hill. PA 17011
(717) 737.0100
CHERYL L. JAMIESON,
Plaintiff
)
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) NO. 97.5786 CIVIL TERM
) IN CUSTODY
~
AND NOW, this L day Of~ ~997. upon receipt of the
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION. LAW
RICHARD D. JAMIESON,
Defendant
Conciliator's Report, it appearing thatlhe parties have reached an agreement as to an interim
order, the terms and provisions of which was dictated in their presence and approved by them
and their counsel, it is hereby ordered and directed as follows:
I. The parties shall share legal custody of their minor child, Kelli Lynn
Jamieson. d,o.b, August 16, 1984.
2. Mother shall have primary physical custody of the minor child subject
to periods of partial custody and visitation with Father as the parties agree upon.
3. The parties acknowledge that Father has not had any visitation with the
minor child and that the child is currently in counseling with Thomas Murray.
Father shall meet with Mr. Murray in an allemptto ascertain what has caused the
child not to visit with him and will try to work with Mr. Murray in re-establishing
his visitation schedule, In the event that Father is unable to work out an
appropriate re-establishment of his visitation through Mr. Murray, Father reserves
the right to have the parties seen by Stanley Schneider, Ed. D.. whose sole
respoll5ibility in this case is to meet with all parties and to re-ill5titute a regular
and consistent visitation schedule with Father.
4. The parties shall reconvene for another conciliation conference before
Michael L. Bangs, Esquire, on Thunday, February 26, 1998. at 9:00 a.m.
BY THE COURT.
J.
DianeO.Radcliff,Esquire row'. ",,~~1~/3,/q?
Jane M, Alexander, Esquire - ~. ~ U <LJ ' ..A }l.
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY.
PENNSYLVANIA
CHERYL L. JAMIESON,
Plaintiff
CIVIL ACTION - LAW
RICHARD D. JAMIESON,
Defendant
NO. 97-5786 CIVIL TERM
IN CUSTODY
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:
I. The pertinent ill formation concerning the child(ren) who is(are) the subject of this
litigation is as follows:
NAME
BIRTHDA TE.
CURRENTL Y IN
CUSTODY OF
Kelli Lynn Jamieson
August 16, 1984
Plaintiff
2. A Conciliation Conferencp. was held on December 18, 1997, and the following
individuals were present: the Plaintiff and her attorney, Diane G. Radcliff. Esquire; the
Defendant appeared with his attorney, Jane M. Alexander. Esquire.
3. Items resolved by agrep.mem: See attached Order.
4. Issues yet to be resolved: See auached Order.
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OCT 7 199h-
I
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CHERYL L. JAMIESON
Plaintiff
S7Pl..
NO. 97 978~ CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
RICHARD D. JAMIESON
Defendant
AND NOW, this
I'"J
ORDER OF
day of
COURT j _ J /J
OUt(fiP-.
, 1998, upon
consideration of a written Stipulation signed by Plaintiff, Cheryl
L. Jamieson, and her attorney, Diane G. Radcliff, Esquire, and
Defendant, Richard D. Jamieson. and his attorney. Jane M.
Alexander. Esquire. it is hereby ordered and decreed that the
within Stipulation is endorsed as a Court Order.
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DIANE G RADCLIFF
3448 TRJNOLE ROAO
CAMP HILL. PA 17011
PHONE 17I7j7J7.{)IOO
FAX (717)975.01')97
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DIANE G RAIX'I.IFF
3"8 TRINDLE ROAD
CAMP HILL, PA 17011
PHONE (717) 7J7<lIOO
FAX (717) 911"1.'7
10_ 32112
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CHERYL L. JAMIESON
Plaintiff
NO. 97-9786 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
RICHARD D. JAMIESON
Defendant
ST:IPULAT:ION
WHEREAS, Cheryl L. Jamieson, is the natural mother of Kelli
Lynn Jamieson, born August 16, 1984; and
WHEREAS, Richard D. Jamieson is the natural father of Kelli
Lynn Jamieson; and
WHEREAS, Cheryl L. Jamieson is represented by Diane G.
Radcliff, Esquire, and Richard D. Jamieson is represented by Jane
M. Alexander, Esquire; and
WHEREAS, the parties have complied with the terms of the Order
of Court dated December 31, 1997, a copy of which is marked Exhibit
"A" attached hereto and made a part hereof; and
WHEREAS, said Order scheduled another Conciliation Conference
before Michael L. Bangs, Esquire on February 26, 1998; and
WHEREAS, prior to said date the parties reached an agreement
to continue said Conference, to give the Parties additional time to
resolve their problems; and
WHEREAS, the parties have, during the past several months, by
mutual agreement, attended a series of counseling and evaluation
sessions with Dr. Stanley E. Schneider of G~idance Associates of
Pennsylvania; and
WHEREAS, as a result of said sessions the parties have reached
an agreement for custody of the child.
NOW THEREFORE, in consideration of the best interest of the
- 2 ..
Child, the parties agree and stipulate as follows:
1. The parties shall share and have joint legal custody of the
Child.
DIANE G RADCl.IfF
3448 TRINDLE ROAD
CAMP HILL, PA 17011
PHONE (717) 737./lI,m
FAX (717) 975.0691
10.32112
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2.
The Father shall have primary physical custody of the Child,
subject to periods of partial custody and visitation with the
Mother as follows:
a. Effective as of August 7, 1998, Mother shall have custody
of the Child every other weekenj, said weekend to be from
4:30 p.m. on Friday until 5:00 p.m. on Sunday. The
weekend visitation may be rescheduled, adjusted or
modified at the request of the Child, if Child's school
related or other commitments and activities make it
advisab~e as to any particular weekend.
b. Mother shall have custody of the Child for a few days in
August, 1998 prior to her birthday. The child shall
return to Father on August 27, 1998 to begin preparation
for the school year.
c. Mother shall continue to monitor/schedule the Child's
orthodontists care. The next appointment being September
19,1998. Father and Mother shall equally share all
associated expenses.
d. Mother shall have custody of the child on Mother's Day
and Father on Father'S Day.
e. The Mother shall have custody of the child for such other
times as the parties shall mutually agree.
The Child shall remain with the Father for the next academic
year (1998 - 1999). In the Spring of 1999, the parties agree
to meet, if necessary, to discuss the custodial situation and
any changes that may be necp.ssary, including, but not limited
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3.
.3.
to, any change in custody necessary as a result of Kelli's
change of mind and wish to return to the Mother's custody. If
necessary, the parties will enlist the aid of Stanley E.
Schneider, Ed.D. for assistance in any such custodial changes.
4. Mother has requested that Child E-Mail her daily and call her
by phone at least twice a week.
5. Mother will be allowed to claim the Child aR a dependant on
the 1998 tax return.
6. Father will pay the child support until July 31, 1998 at which
Father also
time his obligation therefore will terminate.
agrees not to seek child support from Mother.
7. Child wi.ll call maternal Grandparents at least once a week.
WHEREFORE,
intending to be
, 1998.
the parties hereto set forth their signatures
1.gally bourn! 'hio ,L,,-/Aday ot.!f.b,;;.AW
WITNESS:
.t,It.v{, If}. avm~
HARD D. J IESON
,)
ER ESQUIRE
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, IESQUIRE (
(lJ...t~;A"" )
CHERYL ~ . ESON
31ANE G. RADCLIFF
'448 TRJNDLE ROAD
."AMP IiILL. PA 17011
'HONE (717) 737.0100
'AX (717) 97S'{)697
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DIANE G. RADCLIFF
3448 TRINDI.E ROAD
CAMP lULL, PA 17011
(7\1) 7JHJlllll
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CHERYL L. JAMIESON
plaintiff
NO. 97-5786
V.
RICHARD D. JAMIESON
Defendant
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW, THIS \;:+ day of Oc:\rJ'c:::e., , 1999, upon
consideration of the attached Custody Modification Petition, IT IS
HEREBY DIRECTED that the parties a~their rms ective legal counsel
shall appear before ~\.llY'i ~~ ~ " .
the conciliator, at 2O;;I.~, \ K ,"flITn' \ \ , P/"",-
on the II day of ~"-)Q r"-J , ~CbO at ~
0' clock ~. m., for a Pre-hearing cus~ody Conference. At such
conference an effort will be made to resolve the issue 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 or Children who are the subject of
this custody action to the conference, but the child's/children's
attendance is not mandatory. Failure to appear at the conference
may provide grounds for entry of a temporary or permanent order.
FOR THE COURT:
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~~t~A ~ifH~LH )~is~u~IE ~~o8~~~l\9~~o~
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OFFICE OF THE COURT ADMINISTRATOR
FOURTH FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLEA PA 17013
(717) ,,40-6200
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of, Common Pleas of Cumberl~nd ~p~nty is req~red by law
t;.ofcomP1Y wlth bthe Amerlcan .~t.th D~saPtPtl~S Actd Ct 1990. For
ln ormal !o~ a ou ccess 4 e acl ltl sa, re so~able
gccommo~ltlons ava~labfe to alsable f~n lVlaU~ls RaVlnq guslness
etore the court, ptease conti;lct our 0 tlce. , All ax:ranqelnents I])ust
~ made at least 72 hours RrlPr to any hearlnq or busrness betore
the Court. You must atten~ the schedfiled conrerence or hearlng.
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wherein the child was to be in the primary custody of the
father through the academic school year 1998-1999 at which
time the parties were to discuss the custodial arrangements if
the child desired to return to the mother's custody and if
necessary to enlist the aid of Dr. Schneider for that purpose.
A true and correct copy of the October 7, 1998 Order and
Stipulation are attached hereto, marked ~hibit "A" and made
a part hereof.
)
13. The child expressed a desirp. to reside with Mother and the
parties have enlisted the assistance of Dr. Schneider who has
recommended that the child return to the mother's primary
custody. A true and correct copy of Dr. Schneider's report is
attached hereto, marked Exhibit "B" and made a part hereof.
plaintiff has no information of a custody proceeding
concerning the child pending in a court of this Commonwealth.
Plaintiff 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.
14. The best interest and permanent welfare of the child will be
served by granting the relief requested because:
a. The child now age 15 has expressed a desire to live in
the primary custody of her mother.
b. Dr. Schneider has recommended that the child be in the
primary cllstody of the mother.
c. The child's experience in living with the father was
emotionally detrimental to her and has resulted in a
DIANE G. RADCLIFF
3448 TRlNDLE ROAD
CAMP HILL. PA 17011
(717) 737-ll100
strained relationship between them.
15. The Child joins in thi~ request herein stated as evidenced by
her Joinder, attached hereto, marked Exhibit "C" and made a
part hereof.
16. 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 the Court to modify the October 7,
1998 Order or Court and to grant primary physical custody of the
child to the Plaintiff subject to such partial custody rights for
the Defendant as may be desired by the Child at such times as may
be directed by the Child.
Respectfully submitted,
,
ndle Road
pill, PA 17011
Phone: (717) 737-0100
Fax: (717) 975-0697
Supreme Court ID No. 32112
DIANE G. RADCLIFF
3448 TRJNDLE ROAD
CAMP HILL. PA 17011
(717) 7J7.{)IOO
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EXHIBIT "A"
DIANE O. RADCLIFF
J448 TRlNDLE ROAD
CMfP HILL. PA 17011
(717) 7J7~1I00
IN THE COL'R'! CF C::JMI<lON PLEAS OF
CUMBERLAND CCL"NT"{, PENNSYLVAN!A
CHERYL L. JA.."l!ESCN
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$7?l:.
NO. 97~Sl76G CIVIL TER!1
CIVIL ACTION - LAW
DI CUSTODY
RICHARD D. JAM:ESCN
Defendant
AND NOW, th:.s 1 r,;.
ORDER OF COURT
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, 1998, upon
cons~ciera:ion cf a wrltte~ 5ti~~:;ti~n signed by Plaintiff, Cherfl
L. Jam:.eson, and her at:tc:-ney, D:.ane G. Radcliff, Esquire, and
Defendant, Richard D. Jam:.esor., and his at:t:orney, Jane ~l.
Ale:<3.nder, Esqui:'e, it is he:'e=:y ordered and decreed tha: the
w:t~:n se:?~:atio~ is e~dc~sed as a Co~~t Crde~.
By the Court:,
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Tili "'~::'1 'J . . 19 Iff
DIANE (j, R.\DCUFF
JoUS TRJNDLE ROAD
C\MP HILL. P' 1-011
rHO~jG l~li) "J~...I}Wf)
IN THE: COURT O. COMMON PLEAS OF
CUMBE~~ COL~TY. PENNSYLVANIA
CHERY!.. L. JAM:E:SCN
Pla.:.::c::f
~O.
97-9786 CIVIL TE~1
I - -,.."~.,,, D
:<'-'-.--'-' .
CIVIL ACTION - LAW
IN CUSTODY
JA.'oI:ESCN
Cefendanc
ST:IPULATTON
WERJ::AS, Che::yl L. J.3.mi'!lscr., is. the natural mother of Kell i
L~~ ~amiescr., ccr~ Augusc 15, ~9a4; and
WHEREAS, Ri~~ard :. ~a~iescn is the natural father of Kelli
t~~ Jami~scr.; a~d
WHEREAS,
C:-.e :,yl
,
:3.m:;s~r:. :5
r~p=ese~ted by Diane G.
Radcliff, Es~ire, and Richard :. ~amieson is represented cy Jane
M. Alexa::ce~1 Es~~i~e; a~d
WHEREAS, c~e par~ies ha~e ccmplied with the terms of the Order
of Ccurc da"ed :ecemeer 3:, :99i, a copy of which is marked ~xhibit
"A/ accac::ed hereco a:'loc made a ;a:::. ::e=eof; and
WHER~, 3a:= Cr=e:: s=::edu:~d a~othe= c~~ciliation Con:s=e~ce
cefore Mic~ael L. Bangs, Es~~ire en February 26, 1998; and
.-
WHEREAS, ;ricr to saii da:e t~e parties reached an agree~enc
to cc~tinue sai1 Con:e=e~ce, ~~ g:ve the Parties additional time to
resc:?e c::e:::, ~r::bj"ems; a::.c
WHEREAS, cne parci'!ls ha'/e, during the past several months. by
mutual agreemer.t, attar.ded a series of counseling and evaluation
sessions w:~~ ~~. Sta~ley E. Sc~neider of Guidance Associates of
I
,
t'
?e~~S'l:'la~iai a4c
WHEREAS, as a r~sul: c: sa:':: sessions the parties have reached
~
an agreeme~: :~~ c~s~=dy c: :~e c~:ld.
NOW THEREFORE, :~ c=r.s:de=~:i~n c: the ces: i~~erest of the
DIANE G. RADCUFF
J.u8 TRINOlE ROAD
C..\MP HILL. P.-\ l-CI1 i
?HONE (71i) :-}:..)\oo
Child.
Child, t~e parci9~ agre~ a~d s~:~u:a:e as follows:
1. The parcies sha~~ share and have joint legal custody of che
.,
. .
T~e F~cher s~a~~ have ~ri~a~f ~hysical cuscody of the Child,
subjecc co ~eriods of carti~l custody and visitation with the
Mother as fellcws:
a. E::=,:~i?e as c: .~.'..:.~t.:.:3: 7, :'398, ~!othe:; s~all hav13 c~:3t:cdy
cf the C~ild e~/e~f oc~e~ weeke~j, said we~kend to ce fr~m
~:30 p.m. en Fr:day '.:.r:.:i= 5:00 !=.m. on Sunday. :"he
weeke~d visitacicn ~ay ce reschedu~ed, adjusted or
~cdified at the re~~e5t of the Child, if Child's school
r~lated cr
. .
cc::e:- c::rr.!il:' ::ne:1t:3
and
activities
make
it
ac'/i$a:C:e as c.: 3.:,.y ~a:::'":.i:u:..a:.- weeke::c.
b. Mecher sha~l have custody of the Child for a few days in
.~:..J.gust, :'39a r:ri:::- t: l-:er birchday.
T!1e child sha~l
recurn co Facher cn A~:~st 2i, 1998 to begin preparacion
for the school year.
c. Methe:: shall ccr:tin'..:e to mcni:or/schedule the Child's
er:hoder:ciscs care. T~e next appoi~tment cei~g Septemeer
, -
-~ ,
1998.
Fac:-.e:: a:'.c. :-!cche:- sha!l equally share a.l:
asscciated expe~ses.
;:1.
Mcche~ sta:: ~a~; C~3:~Cl
_c
'--
t~e C~ild O~ Mother's Say
and Fache:- en Fa=he::'s Cay.
e. The Mecher shall have custody of the Child fcr such other
cimes as the parties 5~all mutually agree.
3. ~he Child shal: remain Wl:~ che Father fer the nexc academic
~le3.:; (:'998 - :39~).
:~ t~e =~ri~g of 1999, the ~arties agree
to mee~, if necessar/, :0 d:s~uss the custodial situation and
a~l c~a~ge5 t~a~ may =e ~e~eS3a~j, lncl~di~g, cut nee li~ited
DIANE G. R.^DClIFF
1....8 TRINDLE ROAD
CA.\IP HILL, Po\. [401 i
?HONE(:I-:') 7'}...}IOO
to, any change in custod, necessary as a result of Kell;.' s
change of mind and wish to return to the Mother's custody. If
r.ecessar'l, t!:e par<::ies will enlist the aid of Stanley E.
ScrJ:eider, Ed.D. for assi~tance in any such custodial changes.
4. Mother has requested that Child E-Mail her daily and call her
by phone at least twice a week.
5.
Mothe::- will
',... ,., .
_e a_~cwe,=-
'== =lai.:n
t!:e Child as a dependant er.
the 1998 tax return.
6. Father will ~ay the child support u..til July 31, 1998 at which
time his obligation therefore will terminate.
agrees not to seek child support from Mother.
7. Child will call maternal Grandparents at least once a week.
Father also
WHEREFORE ,
t::e ~arties hereto set forth their signatures
'.g.lly '0=< 'hi, /i'Ad.y 0'1/'~
intending to be
__, 1998.
WITNESS:
.;;-.
E M. A1.....
,
.-
(71.L~;M" )
CHERYL . J~ESON
>lANE G. RADCLIFF
448 TRll<DLE ROAD
.,....P HILL. P.~ 17011
'HONE ,717}737 -)100
MAIN OFFICE
411 Erford Road
Camp Hili, PA 17011
Stanley E. Schneider. Ed.D.
Director
~GUIDANCE
ASSOCIATES
OF
'PENNSYLVANIA
Camp Hill: (717) 732.1917
Henhey: (717) 5]3-4312
Carlisle: (717) 145-1109
Chambersburg: (717) 263-9391
FAX: (717) 731.5375
August 18, 1 999
Richard Jamieson
7996 Pleasant Court
Frederick, MD 21701
Cheri Jamieson
1218 Highlander Way
Mechanlcsburg, PA 17055
Dear Cheri and Dick:
This letter will confirm my recommendation that Kelll return to live with her natural
mother for the current academic year (1999-2000). Kelll understands that there
will be no further changes In her school placement until she graduates high school.
I wish to refresh your memory of Information In my letter of August 3, 1998,
wherein I indicated that "sometimes an adolescent changes his/her mind and
wishes to return to the original parent". For reasons discussed with each of you
on August 1 7. 1999, I believe that Kelli's experiences In Maryland were mixed;
that Is, she did acceptably well academically but there were more personal-related
issues that were Identified as troublesome to her.
My recommendation Is made in what I believe to be in Kelly's best interest. To
that end. I met with Cheri and discussed with hsr the need to provide appropriate
structure, supervision, and discipline, when Indicated and needed, to Kelll.
I understand that Kelil will remain in counseling. I would hope to receive periodic
reports from the counselor so that I can monitor Kelli's adjustment and progress. I
would also like to meet with Kelli shortly after the first marking period in 1999 to
assess her adjustment.
C'. U Sincerely,
-', 51
Stanley . Sctinel r, Ed. D., R.C.E.
Psychologist
Registered Custody Evaluator
SES/cs
Comprehensive Psychological Services
.
Drug and AlCohol Treatment
JOINDER
Kelli Lynn Jamieson, the subject child, being age 15, hereby joins
in the petition of her mother, Cheryl L. Jamieson and requests this
Honorable Courc to modify the October 7, 1999 Order of Court and
grant her mother primary custody.
~~.
KEL 1\ ~
.
.
'.,
, ,
l
.'
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3]~
d ~l;
~h!
- .. :.
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.,
oj". i 1000
(
IN TH3 COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CHERYL L. .JAMIESON ~~
Plaintiff NO. 97-~ CIVIL TERM
CIVIL A~'ION - LAW
IN CUSTODY
RICHARD D. JAMIESON
Defendant
,
AND NOW, this '~'day cflL'/ .'t ,~croo, upon consideration of
the within Stipulated Custody Agreement executed by the Plaintiff,
Cheryl L. Jamieson, ("Mother") and the Defendant, Richard D.
Jamieson, ("Father") (sometimes individually "Parent" and
collectively "Parents") pertaining to their minor child, Kelli Lynn
Jamieson, born August 16, 1984("the Child"), IT IS HBREBY ORDBRED
AND DBCREBD as follows:
1. The Parents shall have joint legal custody of the Child and
each parent shall have the right of access to all information,
documents and persons pertaining to the general well being of
the Child.
2. Mother shall have primary physical custody of the Child
subject to Father's rights of partial custody hereafter set
forth.
3.
Father shall have rights of partial physical custody of the
Child at such times and places as the parties shall hereafter
mutually agree.
This order shall supercede all prior orders entered by ~h~
Court in this case. , / ~~
. '/ '\ CO
if qj\O~
4.
BY THE COURT,'
/
I
/
I
,
J.
/
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CHERYL L. JAMIESON
Plaintiff
NO. 97-9786 CIVIL TERM
v.
CIVIL ACTION - LAW
IN CUSTODY
RICHARD D. JAMIESON
Defendant
"'lc,4f /
AND NOW This .~~ day of (, .
Cheryl L. Jamieson, ("Mother")
2000, the Plaintiff,
Defendant, Richard D.
Jamieson, ("Father") hereby sti
Custody Order pertaining to
Jamieson, born August 16, 1984,
the above captioned matter.
agree that the foregoing
their minor child, Kelli Lynn
shall be entered by the Court in
IN WITNESS WHEREOF the Parents, intending to be legally bound
hereby, have set their hands and seals the day and year below
written.
WITNESS:
AhAil~,r-f! ,tIrnh,
{SEAL }
{SEAL}
Date:
-2-
I
I
I
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,~
AUG II 2000)
I
CHER YL L. JAMIESON.
Plaintill'
vs,
)
)
)
)
)
)
)
)
IN THE COllRT OF COMMON PLEAS
OF CUMBERLAND COUNTY.
PENNSYL VANIA
..
NO. 97.5786 CIVIL
RICHARD D. JAMIESON.
Defendant
C/VIL ACTION - LA W
IN CUSTODY
ORDER
AND NOW, this q {L day of ~_, 2000, it being reported to the
Conciliator that the parties have reached an agreement which makes further proceedings
unnecessary, the Conciliator hereby relinquishes his jurisdiction and returns the file to the CO\Y,..
Ii'
,
FOR THE COURT,
~!
.1
M CHAEL L. ANGS
Custody Conciliator
Diane G. Radcliff, Esquire
Jane Alexander. Esquire
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