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Home My WebLink About98-00516 .t- " ~ "t ~ \j ~ '" .\l .. ~ ~~ ~ "'" u \'t ( '" ~ , ; 1 ...... .I , .. .::. . ~ <:J ~ .... \c) , MARY ELLEN CHARBONNIER, I'laintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY. PENNSYLVANIA v, NO, qB- stb JAMES R. GRAMLEY. Defendant CIVIL - CUSTODY ORDER AND NOW, this _ day of January. 1998, upon consideration of Plaintifrs Petition For Emergency Relief, it is hereby ORDERED and DECREED that Plaintifrs Petition is granted and custody of the minor child, Krystal Gramley, is returned to the status quo and the parties are directed to share custody on a week by week basis with Plaintiff having custody of the minor child immediately through February I, 1998 at 6:00 p,m, and Defendant having custody of the minor child from February I, 1998 at 6:00 p,m, through February 8, 1998, The parties shall alternate custody of the minor child on a week by week basis with Plaintiff having the next seven (7) day period and Defendant having the subsequent seven (7) day period with the parties alternating weekly thereafter in accordance with the aforementioned schedule, BY THE COURT: JUDGE v, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, l'ENNSYLVANlA NO. 9B-SIG CM;JI tv-- MAltY ELLEN CIIAltBONNIER, l'lllintiff JAMES R. GRAMLEY, Dcfcndllnt CIVIL. CUSTODY PETITION FOR EMERGENCY RELIEF AND NOW, comes the Plaintiff, Mary Ellen Charbonnier, by and through her attorney, Gary L, Kelley, and files this Petition for Emergency Relief and in support thereof respectfully avers as follows: 1. Plaintiff is Mary Ellen Charbonnier who resides at 440 Market Street, New Cumberland, Cumberland County, Pennsylvania 17070 with her minor child. Tommy Gilliland, DOB 8/25/86, 2. Defendant is James R, Gramley who resides at 748 Erford Road, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The parties are not married, 4, The parties are the parents of a minor child, Krystal Gramley, DOB 1/14/95, 5. The parties previously resided together, 6. The parties separated in June 1997 after having resided together for approximately l'our (4) years, 7, During this period, Plaintiff was forced to leave the residence on at least two (2) occasions because of domestic violence, 8, As a result, Plaintiff obtained a Protection From Abuse Order against Defendant wherein Defendant was granted supervised visitation of the minor child, 9, Plaintiff and Defendant ultimately attempted to reconcile and began residing together again, 10. The parties were unable to work out their differences and Plaintiff left the residence in June 1997 as previously stated, 1 I. Since the parties' separation, they have shared custody of the minor child on a week by week basis, 12, On or about January 17, 1998, Defendant called Plaintiff and informed her that he would no longer share custody with Plaintiff and has refused to allow her to see the child since this date, 13. Defendant alleged that the minor child had been abused by Plaintifrs son, Tommy, the minor child's half-brother, 14. The minor child has always been closely supervised by Plaintiff and Tommy has never had any inappropriate contact with the minor child, 15, Defendant previously threatened Plaintiff that she "would never see the child again" if she left him, 16, Plaintiff believes that Defendant has undertaken this course or conduct for the sole VERU'ICATION I hereby verify that the statements contained herein arc true and correct. J understand Ihal false statements made herein are subject to the penalties of 18 Pa,C,S, Section 4904 relating to unsworn falsification to authorities, Date:-L~ l.Jl~~Q tee, ,. \..H~'-'''''''fL~._( C' ,~ 1'-0 v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARY ELLEN CHARBONNIER, Plaintiff JAMES R. GRAMLEY, Defendant No. 98-0516 CIVIL TERM ORDER OF COURT AND NOW, this 3rd day of February, 1998, upon consideration of the Plaintiff's Petition for Emergency Relief with respect to the parties' child, Krystal Gramley (date of birth, January 14, 1995), and following a hearing, it is ordered and directed that, pending further Order of court, legal custody of the child shall be shared by the parties, and physical custody of the child shall be shared jointly, with Plaintiff having custody of the child for a period of one week on an alternating basis with Defendant. Pending further Order of court, Plaintiff is directed not to permit her minor child, Tommy Gilliland, to be alone with the subject of this proceeding. The Plaintiff shall have the first week of custody following the date of this Order. GARY L. KEf,LEY, ESQUIRE 132-134 Walnut Street Harrisburg, PA 17101 For the Plaintiff , THOMAS ZERBE, ESQUIRE 806 Lisburn Road Camp Hill, PA 17011 For the Defendant 4L.."J"""L~<L iJ.}cJIl/&,. ..J.;:>. wcy >- I.rJ ~ a; c:-.: :;:: i5 co :":1<", ~Q a'~ ....- ::::: ::.)~ 0 ...:::,: EErE < ~)~ @~ 0" 3,(J 'z I a:z I1:W CO tUtu ::1" lLJ mQ. l"= La.. -- -- u. CO B 0 0"1 \\ ......, v. IN TilE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 9 r - S' / ~ C2...:nx. r~___ MARY ELLEN CHARBONNIER, Plaintiff JAMES R. GRAMLEY, Defendant CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW. , 1998. upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , Esquire. the Conciliator, at the Fourth Floor Conference Room, Cumberland County Courthouse, Carlisle, Pennsylvania, on the day of , 1998, at _,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 enler inlo 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:. Custody Conciliator 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 COURT HOUSE FOURTH FLOOR CARLISLE, PA 17013 (717) 240-6200 ~ \!l ~~ J j ~ e '5 ~ G e, .:i l.? !ro' 0' ::r "'l ,-:l ,.. J) " .. Jf ~ f:i: ". ~ Cr, ~~ ~,-; .- I-c' ~ U.!r~ ?:,;:;. c..".(.c' ~..- () ;:~ (r~ l. ; -,- I- .'.- ,1-.>.: ;_1 t.!_ .. cr't. r..r' @L: C....! Ul!, ,^ u.: l,..l' .' . ~: ;~I l~ _.; ~)~- :'::~ ti- er U L;' C' .. : ~ >- C") cr; E s. c .- u,'Q M .t!... .;:J fE~? x O~ U? Ii: ~ ~2 a;:>' r-. .;i.j:! 0, C'\J ''S'.I) ff!UJ . ;,>' ;!.; a: ifJ 6j 1- "- IJ. "'" '0... 0:;, ~ 0 :::l 0'1 <.> MARY ELLEN CHARBONNIER, Plaintiff ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. CIVIL ACTION - LAW JAMES R. GRAMLEY, Defendant NO, 1998-516 CIVIL TERM JUDGE PREVIOUSLY ASSIGNED: The Honorable J. Wesley Oler, Jr. 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: J I. The pertinent infonnation concerning the child(ren) who is(are) the subject of this litigation is as follows: )1 , I NAME B1RTHDATE CURRENTLY IN CUSTODY OF j ( Krystal Ann Gramley January 14, 1995 Plaintiff '~ /. I I l ,"'1, : f !ii r) :", .', 1",1 I ~( '. r, ! ; I ~ U 2. A Conciliation Conference was held on April 9, 1998, and the following individuals were present: the Plaintiff and her attomey, Gary L. Kelley, Esquire; the Defendant appeared with his attorney, Thomas C. Zerbe, Jr" Esquire. 3. Items resolved by agreement: See attached Order. 4. Issues yet to be resolved: See attached Order. 5. The Plaintiffs position on custody is as follows: See attached Order. 6, The Defendant's position on custody is as follows: See attached Order. 7. Need for separate counsel to represent child(ren): Neither party requested, '"' 8. Need for independent psychological evaluation or counseling: None requested and the Conciliator does not believe any is necessary, 10. Other matters or comments: This case has been combined with an action filed to Docket No. 98-544 Civil Term, James Gramley vs. Mary Ellen Charbonnier. It is the intention of this report to consolidate these two actions and to have the case proceed under Docket No, 1998-0516 Civil Term, Mary Ellen Chnrbonnier vs. James R, Gramley. 7/; Mic ael L. Bangs Custody Conciliator Date: April 15, 1998 \ , I l , ! ~ '. !~ 1[ i I I I I i ! 11 l"" ;