Loading...
HomeMy WebLinkAbout98-00671 , ~ q! , :3 q, , J c.i :> j ~. , ... f:, c:.+ 3 q ~ <:.J " ( \. I~ :-.... .~ ~. - t-.. .....,. ~ ~' . R 'i, PATRICIA A. CRAWFORD, Plllintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA vs. NO, 98-0671 CIVIL TERM Dcfcndllnt CIVIL ACTION - LAW IN CUSTODY DAVID A. CRAWFORD, PRIOR JUDGE: Kcvln A. Hess CUSTODY CONCILIATION SUMMARY REl'Olrf IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, thc undcrsigncd Custody Conciliator submits thc following rcport: I. Thc pcrtincnt information conccming thc Childrcn who arc thc subjccts of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Ryan A, Crawford Kyle S. Crawford Eric D. Crawford Novcmbcr 10, 1984 August 9, 1988 May 19,1991 Mothcr Mothcr Mothcr 2, A Conciliation Confcrcnce was hcld on August 29. 2002, with thc following individuals in attendance: The Fathcr, David A. Crawford, with his counscl, Kathlccn Carcy Dalcy, Esquire, and thc Mother, Patricia A. Crawford, who appcarcd at thc Confercncc without her counscl of rccord, Howard Krug, Esquirc. 3. Thc Father filed this Pctition to cstablish a spccific schcdule for regular contact with thc parties' 14 year old son, Kylc and to mandate counscling, This has becn an cxtremcly difficult custody situation since 1998 involving unrcsolvcd hostilitics betwcen the parties which havc had a significant impact on the Childrcn, The parties have obtain cd the assistance of both Dr, Shienvold and Dr, Schneider in an cffort to resolvc the ongoing alienation betwecn Kylc and thc Father and bctwccn the parties as well. Howcver, thcse cfforts havc not bccn succcssful and it will bc neccssary to schcdule a Hearing. Thc Conciliator strongly rccommcndcd to the Mother that shc obtain the assistancc of Icgal counscl for the Hcaring particularly due to the extremcly volatile and complicated nature of thc matters involved, 4, The Father's position on custody is as follows: The Fathcr indicated that he has complicd with the rccommendations of Dr, Shicnvold and Dr. Schncidcr and has tried to recstablish a good relationship with Kylc. Howevcr, thc Fathcr bclicvcs that the failure of his cfforts is duc in largc part to thc Mothcr's intcrfcrencc with thc Fathcr-Child rclationship, Thc Fathcr allcges that thc Mothcr tapcs his tclcphonc conversations with thc Childrcn and rcfuscs to encouragc Kyle to havc contact with the Father. The Fathcr fcels thatthc only way hc will havc an opportunity to reestablish a rclationship v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. (If. G, '7/ Cl~ y;<-~ CIVIL ACTION - LAW IN CUSTODY PATRICIA A. CRAWFORD, PLAINTIFF DAVID A. CRAWFORD, DEFENDANT ORDER OF COURT You, David A. Crswford, Defendant, have been sued in Court to obtain custody, partial custody or visitation of the children: Ryan A. Crawford, Kyle S. Crawford and Eric D. Crawford. You are ordered to appear In person at ths Cumberland County Court House, One Courthouss Square, Carlisle, Pennsylvania, on the day of 1998, at o'clock _.m. You are further ordered to bring with you the children: Ryan A. Crawford, Kyle S. Crawford and Eric D. Crawford. If you fail to appear as provided by this Order or to bring the children, an Order for custody, partial custody or visitation 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Phone: (717) 249-3166 BY THE COURT: J. During tha past five years, the children have resided with the follOWing persons and at the following addresses: NAME RESIDENCE DATE Patricia A. Crawford David A. Crawford 1200 Musket Lane 1993 - Present Mechanlcsburg, Pennsylvania The mothar of the children Is Patricia A. Crawford, currently residing at 1200 Musket Lane, Mechanicsburg, Pennsylvania. She Is married. The father of tha children Is David A. Crawford, currently residing at 2432 Brookwood Street, Harrisburg, Pennsylvania. He Is married. 4. The relationship of Plaintiff to the children Is that of mother. The Plaintiff currently resides with the following persons: NAME RELATIONSHIP Ryan A. Crawford Son Kyle S. Crawford Son Eric D. Crawford Son 5. The relationship of Defendant to the children is that of father. The Defendant currently resides with the following persons: NAME RELATIONSHIP David L. and Virginia M. Crawford Parents 6. Plaintiff has not participated as a party or witness, or In another capacity, in other litigation concerning the custody of the children in this or another court. , ,-, , 0 n C ~\J 'n .... " r;: i , : ,0 " ;:-,:} :-1 on -, i~ <- ",,1--" " i>; , '-.' ,','':::> ,_~r..J) : -'~:I 1M ~11 . '~) :n ., , ".0 , r:~' om " {..:" , ~-.! .0' :.f1 .' 0"'\ - -- --~" - ---- " --. ~ ---........ . '"' PATRICIA A. CRAWFORD, Plaintiff . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : vs. NO. 98-671 CIVIL TERM . . DAVID A. CRAWFORD, Defendant : CIVIL ACTION - LAW : CUSTODY VISITATION OODER OF COORT AND N:lW, this -z. 0 . day of A" 'I consideration of the attached CUstody Concili~b(~n Report, directed as follows: , 1998, upon it is ordered and 1. ~e Mother, Patricia A. Crawford, and the Father, David A. Crawford, shall have shared legal custooy of Ryan A. Crawford, born November lO, 1984, Kyle S. Crawford, born August 19, 1988, and Eric D. Crawford, born May 9, 1991. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of this paragraph, each parent shall be entitled to all records and information pertaining to the Children inClUding, but not limited to, school and medical records and information. To the extent one parent has possession of any such records or information, that parent shall be required to share the same with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. The Mother shall have primary physical custody of the Children. 3. The Father shall have partial physical custody of the Children on alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m., beginning April 24, 1998. In addition, the Father shall have custody of the Children on Tuesdays and Thursdays during the school year from after school until 8:00 p.m. and during the sumnler school break from 3:00 p.m. until 8:00 p.m. 4. The parties shall share or alternate having custody of the Children on holidays as follows: A. Christmas: The Christmas holiday shall be divided into Segment A, which shall begin on Christmas Eve at l2:00 noon and end on Christmas Day at 12:00 noon, and Segment B, which shall begin on Christmas Day at 12:00 noon and end on December 26 at l2:00 noon. The Mother shall have custody of the Children during Segment A in even numbered years and during Segment B in odd numbered years. The Father shall have custody of the Children during Segment A in odd numbered years and during Segment B in even numbered years. B. ALTERNATING HOLIDAYS: The parties shall alternate having custody of the Children on the following holidays beginning with the Father having custody of the Children on Easter in Thanksgiving. Under thio schedule, the Father shall have custody of the Children in even numbered years on Easter, July 4th and Thanksgiving and during odd numbered years on Memorial Day and Labor Day. The Mother shall have custody of the Children in even numbered years on Memorial Day and Labor Day and, during odd numbered years on Easter, July 4th and Thanksgiving. The period of custody on Thanksgiving shall run from the Wednesday before Thanksgiving at 6:00 p.m. until the Friday following Thanksgiving at 6:00 p.m. The period of custody for all other holidays under this paragraph shall begin at 7:00 p.m. on the evening before the holiday and shall end at 9:00 p.m. on the holiday. C. MOI'HER'S DAY/FATHER'S DAY: The Mother shall have custody of the Children every year on Mother's Day and the Father shall have custody of the Children every year on Father's Day from 7:00 p.m. the evening before the holiday until 9:00 p.m. on the holiday. D. The holiday custody schedule shall take precedence over the regular custody schedule. 5. During the surrmer school break each year, the Father shall be entitled to have custody of the Children for up to two uninterrupted weeks and the Mother shall be entitled to have custody of the Children for one uninterrupted weeks upon providing advance notice to the other party by April I of the specific week selected for surrmer vacation custody. The party providing notice first shall be given preference in his or her selection of vacation time. 6. Both parties shall review all homework assignments with the Children and shall ensure that the Children complete all homework assigned during his or her periods of custody. 7. This Order is entered pursuant to an agreement of the parties at a CUstody Conciliation Conference. The parties may modify the provisions of this Order by mutual agreement. In the absence of mutual agreement, the terms of this Order shall control. BY THE COURT, /f4- f,. . Hess J. cc: John J. Connelly, Jr., Esquire - Counsel for Mother Kathleen Carey Daley, Esquire - Counsel for Father {'~""~ '!-/ ~I /'13' --0 .sO.i'. PATRICIA A. CRAWFORD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN1Y, PENNSYLVANIA vs. : NO. 98-671 CIVIL TERM . . DAVID A. CRAWFORD, Defendant . . CIVIL ACTION - LAW CUSTODY VISITATION . . PRIm JlJDGE: Kevin A. Hess CUS'lmY c:xH::ILIATIOO SlMIARY REPmT IN ACXXJUlANCE WITH ClJoIBERLAND CXUll'Y RULE OF CIVIL ~ 19l5.3-8, the undersigned Custody Conciliator submits the following report: l. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUS'lmY OF Ryan A. Crawford Kyle S. Crawford Eric D. CraWford November 10, 1984 August 19, 1988 May 9, 1991 Mother Mother Mother 2. A Conciliation Conference was held on April 14, 1998, with the following individuals in attendance: The Mother, Patricia A. Crawford, with her counsel, John J. Connelly, Jr., Esquire, and the Father, David A. Crawford, with his counsel, Kathleen Carey Daley, Esquire. 3. 'l11e parties agreed to ~ Date Ill, /9 'iff . entry of an Order in the form as attached. la~'7 j~~ Dawn s. Sunday, Esquire Custody Conciliator ,". PATRICIA A. CRAWFORD, PlalntllT : IN TilE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 98-671 CIVIL TERM DAVID A. CRAWFORD, Defendant : CIVIL ACTION - LAW : IN CUSTODY CERTIFICATE OF SERVICE I, John J, Connelly, Jr., Esquirc, of Jamcs, Smith, Durkin & Connelly, attorncy for the Plaintiff, Patricia A. Crawford, hcrcby ccrtify that I havc scrvcd a copy of thc foregoing Answcr to Petition for Court Ordered Counscling on thc following on thc date and in thc manner indicatcd below: U.S. MAIL. FIRST CLASS. PRE-PAID Kathlcen Carcy Daley, Esquirc Dalcy Law Offices 1029 Sccnery Drivc Harrisburg, P A 17109 JAMES, SMITH, DURKIN & CONNELLY PATRICIA A. CRAWFORD, PLAINTIFF V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DAVID A. CRAWFORD, DEFENDANT 98.0671 CIVIL TERM ORDER OF COURT AND NOW, this 6th day of May, 1999, following a review of the petition for court ordered counseling and the answer filed thereto, and there being no custody Iitlgatfon before the court, the petition for court ordered counseling, IS DENIED. John J. Connelly, Jr., Esquire For Plaintiff Kathleen Carey Daley, Esquire For Defendant c....pU.v ~,.t, 5;' o/CJCJ . ij ".! .i'. :saa Ii II " " -'I , , I' , I I I i.' .......... . .J.-', :rc FII rl'.r', :i:1CE _" ~ ...,. I J OF 11:r r"cnH1:1OTNW 99 H^Y -"I AI'\ 9: 1\ CUMi:kKt.jj';U CQUi~1Y , PENNSYLWNt<\ I'" " " \ ._.. -::--1" .. ~. PATRICIA A. CRAWFORD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . . vs. : NO. 9B-Q671 CIVIL TERM : DAVID A. CRAWFORD, Defendant : CIVIL ACTION - LAW : IN CUSroDY CIU>ER OF <XXlRT AND tool, this 1'/" day of ~ consideration of the attached CUstody Concil at n and directed as follows: , 1999, upon Report, it is ordered I. The prior Order of this Court dated April 20, 1998, shall continue in effect as modified by this Order. 2. Paragraph 3 of the April 20, 1998 Order is modified to delete the Father's Thursday evening periods of custody. The Father shall continue to have custody of the Children on Tuesdays as provided in paragraph 3 of the prior Order. In the event the Father is not available for a Tuesday period of custody, the Father shall notify the Mother directly by 8:00 p.m. on the preceding Sunday. The parties shall cooperate in scheduling a substitute period of custody for the Father. 3. The Father and the Children shall participate in a course of counseling with Arnold Shienvold, PhO. or other professional selected by agreement of the parties. The purpose of the counseling shall be to address problems that have arisen in the relationship between the Father and the Children. The Mother shall comply with the counselor's recommendations with respect to the Mother's involvement in the counseling. The Mother shall ensure that the Children are available and ready for each counseling session and the Father shall be responsible to provide transportation for the Children. The Father shall be responsible to pay all of the unreimbursed costs of the counseling. BY THE COURT, " Ke~~~e:!4. // J. cc: John J. Connelly, Jr., Esquire - Counsel for Mother Kathleen Carey Daley, Esquire - Counsel for Father - ~~ 7/II./r9. .,.g, P. PATRICIA A. CRAWFORD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 98-0671 CIVIL TERM DAVID A. CRAWFORD, Defendant CIVIL ACTION - LAW : IN CUSTODY '\ PRIm JUDGE: Kevin A. Hess CUS'lOOY aH::ILIATION Slft1ARY REPCm' IN AOCXlUlllNCE WITH cnmERIJ\ND CXXlNTY RULE OF CIVIL I'~ 19l5.3-8, the undersigned CUstody Conciliator submits the fOllowing report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENl'Ly IN CUS'lOOY OF Ryan A. crawford Kyle S. crawford Eric D. crawford November August May IO, 1984 19, 1988 9, 1991 Mother Mother Mother 2. A Conciliation Conference was held on July 7, 1999, with the fOllowing individuals in attendance: The Mother, Patricia A. Crawford, with her counsel, John J. Connelly, Jr., Esquire, and the Father, David A. Crawford, with his counsel, Kathleen Carey Daley, Esquire. Two of the parties' older Children, Ryan Crawford and Kyle crawford, also spoke with the Conciliator at the parties' request. 3. The parties agreed to entry of an Order in the form as attached. ~ fr,. /999 Date (()~oJ~.i Dawn s. sunday, Esqulr Custody Conciliator ,...." . fu\0oQ. ~ .CfcW\Ord, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, : PENNSYLVANIA v. . t>C).'^~ A..lro--l-\on:\ Defendant : CIVIL ACTION LAW . :' NO. 10 1 \ CIVIL 19 '1"6 : CUSTODY VISITATION ORDER OF COURT And now, this~, upon consideration of the attached complaint, it is hereby directed that the above parties and their res ective counsel appear before I'-.. Esquire. the conciliator, at -\.." " , Pennsylvania, on the ~ day of , 199 . at q'.. GO ,I P.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 may be present at the conference. Failure to appear at the conference may provide grounds for the entry of a temporary or penn anent order. FOR THE COURT: By: ~~.~_uN6~. Custody Conciliator l'"'Cb J 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, THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LffiERTY AVENUE CARLISLE, PA 17013 (7 I 7) 249-3 166 1-800-990-9108 o.~ F/Lrr), . '" '1 ,~. :.' ~~)"'I':I/"~ ".,"'\" ,.....c , :I-'(,i\'JTi:r~ 99 ~l'p , Y "C '9 -". pI! 'J. . ,]'?I CI.P'" -.1 ';"')'0;1 _, -...1/ ., ') PCN,ij,.'c'Z"I' ~'OUl"7)1 v, ,.j,,/., V a,,;} :,"\ ~t:/f?9~ 6d- tW ,4~~ ?Js df #- ~ fDJf ,~f 71d~ A~ ~ 4 ~~ ldf.f'y ~"/Ha./v z; ~ J&~7 -. '-' PATRICIA A. CRAWFORD , IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . vs. NO. 98-0671 CIVIL TERM : DAVID A. CRAWFORD , : CIVIL ACTION - LAW Defendant . IN CUSTODY . PRIOR JUDGE: Kevin A. Hess aJS'IODY a:H:ILIATIOO SUMMARY REPCRl' m ACCCIlDANCE WITH ~ CXJUolTY ROLE OF CIVIL PRO 'KI ".mE 1915.3-8, the undersigned CUstody Conciliator submits the following report: I. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRmrLY m CUSJ.uu:l OF Ryan A. Crawford Kyle S. Crawford Eric D. Crawford November August May IO, 1984 19, 1988 9, 1991 Mother Mother Mother 2. A conciliation Conference was held on July 7, 1999 , with the following individuals in attendance: The Mother, patricia A. Crawford, with her counsel, John J. Connelly, Jr., Esquire, and the Father, David A. Crawford, with his counsel, Kathleen Carey Daley, Esquire. Two of the parties' older Children, Ryan crawford and Kyle crawford, also spoke with the Conciliator at the parties' request. 3. The parties agreed to entry of an Order in the form as attached. ~ fr,. /999 Date ('(2...", LJ~.. aJ~';j Dawn S. Sunday, EsquJ.r CUstody Conciliator --- \ .'- -....... ..,.. ,..-...., ,;/..' ! . ' PATRICIA A. CRAWFORD, . IN TilE COURT OF OOMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . VS. . NO. 98-671 CIVIL TERM . DAVID A. CRAWFORD , . CIVIL ACTION - LAW . Defendant . IN CUSTODY . aIDER OF CXXJRT AND rDI, this 7~ consideration of the attached and directed as follows: day of 'lJ.. < " -kr , 1999; upon Custody Conciliation Report, it is ordered I. The prior Order of this Court dated July 14, 1999 shall continue in effect with the following modifications. 2. The parties shall participate in custody counseling with Arnold Shienvold, PhD. or other professional selected by agreement of the parties and their counsel. The purpose of the counseling shall be to assist the parties in developing communication and cooperation to enable the parties to effectively coparent the Children. The Father shall be responsible to pay the cost of the first 4 counseling sessions. The parties shall seek guidance from the counselor to assist them in working out arrangements for payment of further costs. 3. The parties agree that each party may record telephone conversations between the parties without the fUt'ther consent of either party for a period of 60 days from the date of this Order. Any telephone conversation recorded put'suant to this paragraph must be recorded in its entirety. The parties agree that any recordings taped pursuant to this provision shall be confidential and may be released only to the parties' counselor, Dr. Shienvold or the Mother's counselor, Edward Horan. The parties agree that recordings taped pursuant to this provision shall not be regarded as violations of the federal or state wit'etapping laws or similar laws. 4. The Father shall have custody of the Children on Tuesdays ft'om 3:30 p.m. until 8:00 p.m. In the event the Father is not available for a Tuesday period of custody, the Father shall notify the Mother directly by 8:00 p.m. on the pt'eceding Sunday. The parties shall cooperate in scheduling a substitute period of custody for the Father. 5. The Father's periods of alternating weekend custody shall run from Friday at 6:00 p.m. through Sunday at 6:30 p.m. In the event the Fathet' is not available for his regular period of weekend custody, the Father shall notify the Mothet' 7 days in advance. If the Father is not able to provide 7 days advance notice, the Father shall make al:'J:'angements fot' a thit'd party to provide care for the Children during his regularly scheduled weekend. ,.1 E!: C() ~ ;<1;, ~ 1-.' r-1;J~ 6; E1~ C;J ',. ;c (J";' u.: ~? or.: ~ ;.;;~~. '~- ::-"'~ a~:~' 0:1 '-3"" lo!..ll..:. I ,.z Ef!';f.. [j cr-~ IJJW j.:: r.r..JQ.. CJ '" u. C~ ~ <..) 0' PATRICIA A. CRAWFORD, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . . vs. NO. 9B-671 CIVIL TERM . . DAVID A. CRAWFORD, Defendant . . CIVIL ACTION - LAW IN CUSTODY . . PRIOO JUDGE: Kevin A. !less CUS'lOOY <X:NCILIATIOO SlMlARY REPCRr IN ACXDUll\NCE WITH ClJoIBERLAND CXUITY RULE OF CIVIL ~ 19I5.3-8, the undersigned CUstody Conciliator submits the following report: l. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NI\ME DATE OF BIRTH CURRml'Ly IN CUS'lOOY OF Ryan A. Crawford Kyle S. Crawford Eric D. Crawford November IO, 1984 August 19, 1988 May 9, 1991 Mother Mother Mother 2. A Conciliation Conference was held on November 18, 1999, with the following individuals in attendance: The Mother, Patricia A. Crawford, with her counsel, Howard B. Krug, Esquire, and the Father, David A. Crawford, with his counsel, Kathleen C. Daley, Esquire. 3. '!he parties agreed to entry of an Order in the form as attached. AJ~ OQ. /199 Date ' c-~L f!!=t Dawn S. Sunday, Esqulre CUstody Conciliator . , PATRICIA A, CRA WFORD PLAINTIFF V, DA VID A. CRA WFORD DEFENDANT IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 98-671 CIVIL ACTION LAW IN CUSTODY OIUlF.I{ OF COllIn AND NOW, this 171h day of November, 2000, Upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq, ,the conciliator, at 39 West MaIn Street, Meehanlcsbur2, PA 17055 on the --.!E!ldayof December ,2000, at ...!!:OO a.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 Ihe issues to be heard by the court. and to enter into a temporary order, All children age five or older may 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, i , I By: /5/ DaWI/ .'I, Sill/day. Esq. If' Custody Conciliator J I The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990, For inlormation about accessible facilities and reasonable accommodations 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. YOU SHOULD TAKE THIS PAPER TO YOUR ATrORNEY AT ONCE. IF YOU DO NOT HAVE AN A TIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. I ) If',:: 1", 'I, I Cumberland County Bar Association 2 Liberty A venue Carlisle. Pennsylvania 17013 Telephone (717) 249-3166 ;" ,~,':'" :' :" ..: .(. . :,',~~ .;':,:.=\:", :.:. ,.~. ':.,',:.,.. ,:.,~,',:' .:.'~ :"':";"~":" ,I'. ,~ " . . ... : .'. . . t .' ",.".1,1., ..".'~ .,. :,., \ ~ ~l.l '..,;',.,""....,"'..............."." , .,,~~".;:j..~ l'l,~,fi.~1;~ 't~'1~...., 'I"'''' . "", L , ,j . PATRICIA A. CRAWFORD, Plaintill'lRespondent : IN TIlE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LA W v. : NO 98-0671 CIVIL DA VID A. CRA WFORD, Defendant/Petitioner : IN CUSTODY ORDER OF COURT You, Patricia A. Crawford, Respondent, have been sued in court to modify custody of the children, Ryan A. Crawford, Kyle S. Crawford and Eric D. Crawford. You arc ordered to appear in person at Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013, on , at _.M.. for a conciliation or mediation conference. ') \ , 1 a pretrial conference. a hearing before the court. If you filii to appear as provided by this order, an order for custody, partial custody or visitation may be entered against you or the court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT If A VE A LA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR 4111 FLOOR, CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLlSLE,pA 170/3 (717) 240-6200 \, .~ .fI r Ii' , ' , ! , i t', I, PATRICIA A. CRAWFORD, Pluintill'lRcspondent : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LA W v. : NO 98-0671 CIVIL DA VID A. CRAWFORD, Defendant/Petitioner : IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY AND NOW comes Defendant/Petitioner, David A. Crawford, by his attorney, Kathleen Carey Daley, Esquirc, who files the following facts in support of his Petition for Modification of Custody to transfer primary physical and legal of the three minor children, Ryan A. Crawford (008 11/10/84), Kyle S. Crawford (008 08/09/88), and Eric D. Crawford (008 05//9191), to Father. The best interests of the children will be served by granting the relief requested because of the following: 1. The Plaintiff/Rcspondcnt is Patricia A. Crawford, residing at 1200 Musket Lane, Mechaniesburg, Cumberland County, Pennsylvania 17055. 2. The Defendant/Pctitioner is David A. Crawford, residing at 121 Beacon Drive, Harrisburg, Dauphin County, Pennsylvania 171 12. 3. The Petitioner/Defcndant seeks primary legal and physical custody of the following children: Name Present Residence Date of Birth Ryan A. Crawford 1200 Musket Lane November 10,1984 Mechaniesburg, Pennsylvania 17055 Kyle S. Crawford Same as above August 19, 1988 .~ ~ 5. Thc rclationshill of Defcndllnt to the children is thllt of father. Thc Defendant currently resides alone. 6. Plaintill' hils pllrticipllted liS II pllrty ur witness, or in another capacity, in other litigation conccrning thc custody ol'the childrcn In this ur nnuthcr court. All prior orders are attached hercto as Exhibit "A," dlllcd Apr1120, 199M; Exhlhll "II," dlltcd July 14, 1999; and Exhibit "C," dated December 7,1999. Plaintiff does not know of II pcrson nut II pllrty to thc proceedings who has physical custody of the children or claims to hllvc custody ur vlsitnlion rights with respect to the children. 7. The hcst intcresllllld perlllllnent wellarc ofthc childrcn will be served by granting the relief requested. 8. Each parcnt whose pllrental rights to thc children have not been terminated and the person who has physical custody of the childrcn has bcen namcd as parties to this action. 9. Thc current status is insutlicient to providc for thc physical and emotional needs of the ehildrcn. Thc clliJrts 01' Dr. Arnold T. Shicnvold to rcmcdy these problems has not been successful as evidcnced by his lettcr aUllchcd as Exhibit "A." 10. The mothcr ofthese children rcfuses to conduct hersclfin conformance with the terms ofthc cxisting ordcrs or in II IIlllnner Ihllt con limns with standards of reasonable accepted behavior. This has rcsulted in clli1rts directcd tuwurd contelllpt and counscling, neither of which have brought about the neecssllry results, 3 vlm....ICA.I'IO/l! Upon Illy perSllnll1 knOlvlcdl!c, Inlhnllutlollund hclle/: I, David A. Crawford, do hereby verify that the fhets llverred und SlulclIlCllls lIludc In thc lorcl!olnl! "ctltiou lor Modification of Custody are true llnd eOITCct. I undcrstund thlll Ihlsc stlllclllcnts or IIVenl1ents therein made will subject me to the criminal pcnaltlcs of 1M "".C.S,A. ~ 4904 rclutinl! to unsworn fhlsitieation to authorities. Datc:-.!'~~ By: (1. //lij /' DA VID A. CRAWFORD - ~,.......-- '--.. -- ~M.hL'. ,~. .t:".,....,. , . , .~ '1"-', ... - ':_~'. :I --~... , I I I i I I PATRICIA A. CRAWFORD, Plaintiff . . IN THE aJURT OF OOMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : : Vs. NO. 98-671 : CIVIL TERM . . DAVID A. CRAWFORD, Defendant . . CIVIL ACTION - LAW IN CUSTODY . . aIDER OF CXXlRT AND t<<lW, this I ~... consideration of the attached and directed as follows: day of 7)"c..~ , 2000, upon CUstody Conciliation Report, it is ordered 1. The parties shall participate in a minimum of 8 counseling sessions with Stanley Schneider, EDD. The purpose of the counseling shall be to resolve underlying conflicts between the parties and establish sufficient communication and cooperation between the parties to enable them to effectively coparent their Children. '!he parties shall follow the recOl11llendations of the counselor with respect to the duration and frequency of the sessions. Each party shall sign all necessary releases to enable the counselor to review any and all medical and psychiatric records pertaining to both parties and the Children. The parties shall obtain a letter from the counselor by May 1, 2001 reporting the status of the counseling. The Father shall be responsible to pay 80% and the Mother shall be responsible to pay 20% of all costs of counseling which are not reimbursed by insurance coverage. 2. Within 60 days of receipt of the letter status report from the counselor, counsel for either party may contact the Conciliator to schedule an additional Custody Conciliation Conference, if necessary at that time. BY THE aJURT, .~d Hess, tapUnJ~aJJ / ;(-/5 -(JO RJ{S cc: Howard B. Krug, Esquire - Counsel for Mother Kathleen C. Daley, Esquire - Counsel for Father ..', -', , PATRICIA A. CRAWFORD , . IN THE COURT OF COMMON PLEAS OF . Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA . . vs. . NO. 98-671 CIVIL TERl>1 . : DAVID A. CRAWFORD, : CIVIL ACTION - LAW Defendant . IN CUSTODY . PRIOO JUDGE: Kevin A. lIeBS CUS'lOOY <D<<:ILIATIctl SlMlARY REPOOT IN ACXXIUll\NCE W1TfI ClJIIBERLAND cnNlY RULE OF crnL PROo "KIIIJRE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTfI ClJRRENrLY IN CUS'lOOY OF Ryan A. Crawford Kyle S. crawford Eric D. crawford November 10, 1984 August 9, 1988 May 19, 1991 Mother Mother Mother 2. A Conciliation Conference was held on December 12, 2000, with the fOllowing individuals in attendance: The Mother, Patricia A. Crawford, with her counsel, Howard B. Krug, Esquire, and the Father, David A. Crawford, with his counsel, Kathleen C. Daley, Esquire. 3. 'Il1e parties agreed to entry of an Order in the form as attached. {).1 (~'O\J-,/J<J Date / i :kJcx'> , ( O'.u~0j~----rc1o'i Dawn S. sunday, EsquJ.re Custody Conciliator '~. PATRICIA A. CRA WFORD IN TJ IE COURT OF COMMON PLEAS OF CUMBERI.ANDCOUNTY, PENNSYLVANIA PLAINTIFF V. 98-0671 CIVIL ACTION LAW DAVID A. CRAWFORD DEFENDANT IN CUSTODY ORDER OF COI1RT AND NOW, Friday, July 19, 2002 , upon consideration of the allached Complaint, it is hereby directed that parties and thcir respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Meehanle.burg, PA 17055 on Tue.day, August 13, 2002 at 1:00 PM for a Pre-Hearing Custody Conference. At such conference. an effort will be made 10 resolve the issues in dispute; or if this can no I be accomplished, to define and narrow the issues 10 be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a lemporary or permanent order. Thc court hcreby dlrcets the parties to furnish any and all cxlstlng Protcetion from Abuse ordcrs, Special Relicf ordcrs, and Custody ordcrs to the conciliator 48 hours prior to scllcduled hearing. FOR THE COURT, By: Isl DawlI S. SlIlIday. Esq. ,~ CUSlody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be macie at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR A'/TORNEY AT ONCE. IF YOU DO NOT HAVE AN A '/TORNEY OR 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 A venue Carlisle, Pennsylvania 17013 Telephone (7 I 7) 249-3166 HUT),,.,, I "": C...,.. ''0' ", . ," ',...... i}" I" r " ", '10".,.",( " ii/I 02 ,JUl. 19 Pi! '?:1:; CUM!i!:f!i",.;",,. 11"'1-" ... ..' ',-,/, i I'ENNS\1.W,;,!:.\' . 7./fCi,,;> ';1:/9' -t?..) ? ./,/ .~;;. &! - t'~ M44 7t ~ JCk5 n~r.u I,tadld ~ 4 ~ ~~ Ika"..aP/ $ 4 d~ ,,, i: ,'. '1 .,..... AMERICANS WITH DISABILITIES ACT OF 1990 The Court of COlllmon Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of I 990, For infollllation about accessible facilities and rCllsonable accommodations available to disabled individuals having business before the court, please contact our office. All arrllngcments must be made at least 72 hours prior to any hearing or busincss bcforc the court. You must attend the scheduled conference or hcaring. BY THE COURT: Date: J, \r 6. Despitc Father's efforts which as includcd professional counseling lilr this fllmily he rcmuins unahle 10 obtain reasonable access 10 his son Kyle, 7, The Petitioner secks to modi fy the current Order of Court, for the following reasons: A. Mother's conduct directly intcrfercs with FlIlher's rclationship with Ihe chi Idren, She acts in a disrcspeelful, condesccnding and inappropriatc manncr when speaking to Father, eithcr privately or in front of third partics. This has influenced the children's opinion of their fathcr in a negative fashion. B. Mothcr has interfcrcd with Father's ability to visit with Kylc S. Crawford by refusing to support Father in his efforts to spend time with Kyle. Mothcr has been uncoopcrative in dircct contacts and in contacts that were facilitated by professional counsc10rs. C. Mothcr's conduct constitutes cmotional abuse to the childrcn in that it requires the children to side with her, against their father, and to suffcr rctribution if they fail to follow her prescribcd coursc of conduct. THEREFORE, the Petitioner requests this Honorablc Court to modify the current custody order to provide as follows: A. immediatc implementation of partial custody of Kyle S. Crawford should be implemented such that Fathcr has at1cast twice weekly direct contact with his son; 8. Kyle S. Crawford be directed to participatc in counscling with his Father through the offices of Guidance Associates with the direction that Guidance Associates shall provide a report within 90 days of any fllrther recommendations that are advisable to reestablish and maintain rclationship with his Father; ! I J , " ~ ~~~ F- r D ~ } () ~ ~ (\t:J ('~r- )- 0 0 0 c: "oJ .:;:- a:-, -ort; '- --/ Q:I(n i.:;; ':li~ ~.l, ..-':",..... - -rrt." C,,?,'::;': 0 B(er; r::(:7 " -tJ ~jJ-r .~.~: C.J :z ,.;::tJ "!:-n .!;t.'J .:l"(..,:::, .,:-:, b'n ~ -, -- .,.. 5J (.n '"" ~j ;~' -',f "\' :,. ...y ~t~! ',0 ~ '!~~' ~'~ 'f " ',1 I '..... >- r-' '- c;: tn "-- ,::.: ..2:: (~J ~_.~ F. t~,~_B ~;~f";:' ..,- l~ ~ W- ':.~:~ C,>(".. 1"-' C',l :12 tu!.- -t::;:: G~~.. W ;tjL~J Ld r:. 0 :~~0_ w. '" 0 Cl (,) F-1~Er)"CI;F;cr~ 0" 11 ". I '~"'TI "," 'C" -, ",'J r ",:; -:"ld,'i"(".}U~r~[ 200~ OCT -G [Ji II: II a CL I ,;',,,,. ,: I, . --:J'11Y )1/......,.. '~e .. , I... ,\_, , j: F~ J,\:}"; 'LVi<..~-~_j\ /O'/p'()f/ M &Ph' I~~-;j; 4tf a~ /0'& ~f 71tJlta _ ~ 1ft, ~ .?7~K ~ ~ /IJ 'b vI( Co/iP ~ ~ aft c;,;SJ~ Ii " PATRICIA A. CRAWFORD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. DAVID A. CRAWFORD, Defendant NO. 98-0671 CIVIL TERM IN CUSTODY PETITION TO MODIFY AND NOW comes the Defendant, by his attorney, Samuel L. Andes, and petitions the court to modify its prior order or orders of custody in this matter, based upon the following: 1. The Petitioner herein is David A. Crawford, an adult individual who resides at 2428 Brookwood Street in Harrisburg, Pennsylvania and is hereinafter referred to as "Father. " 2. The Respondent herein is Patricia Crawford, an adult individual who resides at 1200 Musket Lane in Mechanicsburg, Cumberland County, Pennsylvania 17050. She is referred to hereinafter as "Mother." 3. The parties are formerly husband and wife and are the parents of three children, the oldest of which is an emancipated male who currently resides with Father and attends the Harrisburg Area Community College. In addition, the parties have two minor children, Kyle Crawford, age 16, born 9 August 1988, and Eric Crawford, age 13, born 19 May 1991. 4. The children are the subject of prior orders of custody entered in this court. Most recently, those orders awarded primary legal custody of both of the rninor children to Mother. 5. In late August of 2004, fOllowing a dispute between Mother and Kyle, Kyle left Mother's home and came to stay with Father. Father encouraged Kyle to return to resume living with Mother but, when Kyle first attempted to do that, Mother directed Kyle to leave her home. Kyle has not returned to Mother's residence since that time and has lived with Father. ," 6. Father believes that the orders In this matter should be modified to award him primary physical custody of Kyle and Eric for the following reasons: A. Mother is no longer able to provide for the boys and provide them the proper home, supervision. and parenting for them to succeed; and B. The relationship between Mother and Kyle has deteriorated to the point that she does not want Kyle with her and he does not want to reside in her home; and C. Father is better able to provide for the emotional and personal needs of both sons; and D. Father believes it will be in the best Interest of both boys to spend substantial time in his custody and substantial time together. WHEREFORE, Defendant prays this court to modify Its prior orders to award him primary physical custody of both of his sons. ~~An~-~- Attorney for Defendant Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 . ~ ~ ~ f ~ ....... ~ ~ Cl ...., ~ \. = ~ '^' c:: = ;'<.. .z;- ""> W i.'cl'j Cl -J \J ~ !..1)L;-; <, :1. -1] ~, .~- .~ -< Jllr__ "\\ ~~; 1 -om 66 ~.. ::::: ::;1 -rj 'i: () ';""f ::'-,-Cl - 80 ....,.C: S' "-'rn ?j 8 ..... N :n 0' ..:: 0 ...., f-; '= 0 '= ~.lr, """ -.-, ~l :, Cl .." " , r;-) :r: -fl " ~-.... i' -; 11'.... (.II -n1Ti -- c.., ':-111::':' [:; !;'~Cl) -.,..: -0 i~~? ;(:. :r~ =l: ...1-. ;.:.:$) ~~ - ()I' I ~' ~"I I~ .~ :;::- -.J .< '~' the Father's residence in Hummelstown, The Futher proposed tllllt he huve expunded periods of custody over lhe weekend, during the week, over holiduys und in the summer. The Futher seeks custody of Eric ror upproximutely hulr of the time with the mujority of the Futher's time to be scheduled in the summer and on holiduys due to the Child's school enrollment in Mecllllnicsburg, 5. The Mother's position on custody is as follows: The Mother agreed thut it would be in Kyle's best interest to remain in the Futher's primury care at this time und did not feci it was necessary to establish a purtiul custody schedule until the Child is rcady to rcsume contact. The Mother further agreed that Kyle be enrolled in the Lower Dauphin School District. The Mother does not believe it would be in Eric's best interest to spend the majority of his summer school break and holiday breuks with the Father. The Mother proposed tlmt if the Father wunted to llUve u more shared custodial arrangement for Eric he should have expanded time during the school ycar and provide the transportation between Hummelstown und the Child's school in Mcchanicsburg. The Mother did not believe it was fair for the Fathcr to have the majority of his custodial time during vacation time in the summer while the Mother would have the more regimented time during the school year. 6. The conciliator recommends an Order in the form as uttached scheduling a hearing. It is expected that the hearing will require at least one-halfday. ~w_ .'f" :Jnoi Date 7 /2." -J. a~" Duwn S. Sunday, Esqui~ Custody Conciliator 1 vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW , PATRICIA A. CRAWFORD, Plaintiff ; , I NO. 98-671 CIVIL TERM I .1 DAVID A. CRAWFORD, Defendant IN CUSTODY PRAECIPE TO THE PROTHONOTARY: , Please withdraw the remaining claims in the Defendant's Petition to Modify which was filed in this matter on 1 October 2004. 11 February 2005 ~Qt Attorney for Defendant Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 j I , i , r'~ ~. !' :'1 fL; ',I 0 I" "~; ,-; C:.J 0 ~:;i l.':' I:,,, -I") <::"t , "T1 X-n .V 1;1 ii' I ''::;' nJp: ,1 -r1rn ~i~ CJ/ ,,, t:;'J , , {I$, "n x ;::':,. i' :.:.: ".? . ."-1 '-0.' "', ,~'>., -< ..0 - - AS OF IO~ CASE# 'JB -la1I HAS BEEN SCANNED. ALL EARLIER FILINGS TO THIS CASE HAVE BEEN MICROFILMED. " PATRICIAA. CRAWFORD, Plaintiff vs. ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 98-0671 CIVIL TERM DAVIDA. CRAWFORD, Defendant IN CUSTODY PETITION TO MODIFY AND NOW comes the above-named Defendant, by his attorney, Samuel 1. Andes, and asks the court to modify its prior orders of court in this matter, based upon the following: 1. The Petitioner herein is David A. Crawford who resides at 2428 Brookwood Street in Harrisburg, Dauphin County, Pennsylvania. 2. The Respondent herein is Patricia A. Crawford who resides at 86 Keefer Way in Mechanicsburg, Cumberland County, Pennsylvania. 3. The parties are the parents of three children, two of whom are now emancipated and the third, Eric D. Crawford, is still a minor, having been born on 9 May 1991. 4. Prior orders of this court awarded primary physical custody of the child Eric to his mother. Petitioner seeks a modification of that order, and believes a modification would be in Eric's best interests, for several reasons which include: A. The relationship between Eric and his mother has deteriorated seriously and they frequently disagree and argue; and B. The mother has become abusive, verbally and emotionally and, on some occasions, physically in her conduct toward the child; and C. The mother fails to adequately supervise and control Eric and the father believes he can better provide a stable measure of control and supervision for the child; and D. The child has expressed a strong desire to reside with the father. The parties' second child, Kyle S. Crawford, now age 18, although technically an adult still resides with Petitioner and attends school from Petitioner's home. Petitioner believes that reuniting the two brothers to reside together will be beneficial to Eric and to Kyle. " WHEREFORE, Petitioner prays this court to modify its prior orders of custody to award him primary physical custody of the minor child, Eric S. Crawford, born 9 May 1991. ~~~~ Samuel L. Andes Attorney for Defendant Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 II I; I . I verify that the statements made in this document are true and correct. I understand that any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: /tJ - 3-()~ DA~~ II l CERTIFICATE OF SERVICE I hereby certify that I served a copy of the foregoing document upon counsel for the Plaintiff by regular mail, postage prepaid, addressed as follows: Patricia A. Crawford 86 Keefer Way Mechanicsburg, PA 17055 Date: q ~ ~OOU> lliYLL~!1Lul:uD (11), Amy M. arkins Secretary for Samuel L. Andes ~ ~ o 1 ~ -: - ~ ~ "\\1.\ \N t ~ ~~ ~ \J c_", ,...........) \.~ \:;:;--1 <":J',", C) -n -t :-r.: -n 1'11-- -05 ;:'~'~( . , C"l C) --; :? "-~~q :5 ;-n :,'--1 J;' :-AJ .-< (:J.) C) c..r, PATRICIA A. CRAWFORD PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 98-0671 CIVIL ACTION LAW DA VID A. CRAWFORD DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, October 13, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. at 39 West Main Street, Mechanicsburg, P A 17055 on Thursday, November 16, 2006 , the conciliator, at 9:00 AM 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 may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the pnrties to furnish nny nnd nil existing Protection from Abuse orders, Specinl Relief orders, nnd Custody orders to the conciliator 48 hours prior to scheduled hearine. FOR THE COURT. By: /s/ Dawn S. Sunday, Esq. ffl Y Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990, For infonnation about accessible facilities and reasonable accommodations available to disabled individuals having business before the cOUli, 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. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VE AN ATTORNEY OR 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 32 South Bedford Street Carlisle, Pennsylvania 170 I 3 Telephone (717) 249-3166 ~r-F . JtP 'I- r,' "". ~J 'l(I t.J 111 I!frI ~~~~ ~'(j-JI ~ fty ~ ~ ~'P9 'l(J-L.I.01 O ~ "h II] . ~ . J .1:...l t I I r- :-.\f\l .._ __ --.;~u A'ci\llC~< PATRICIA A. CRAWFORD Plaintiff G 1 5 200?, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 98-0671 CIVIL ACTION LA W DAVID A. CRAWFORD Defendant IN CUSTODY ORDER OF COURT AND NOW, this c;;<.tf ti day of [J;A'~ , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Courtroom Number i of the Cumberland County Courthouse on the <Jd1 day of ;)1..1 M A.. ' 2001> at .L-::3Q,a.m., at which time testimony will be taken. For purposes of the hearing, the Father shall be deemedko be the moving party and shall proceed initially with testimony. Counsel for the parties, or a party pro se, shall file with the Court and opposing counsel a memorandum setting forth each party's position on custody, a list of witnesses who are expected to testify at the hearing, and a summary of the anticipated testimony of each witness. These memoranda shall be filed at least 10 days prior to the hearing date. 2. On a temporary basis pending the hearing and determination by the Court of the best interests of the Child, the existing custodial arrangement shall continue in effect with the Child residing primarily with the Father. The Mother shall have liberal periods of custody with the Child as arranged by agreement between the parties, in which both parties shall be reasonable and cooperative. BY THE COURT, ./lJ J. ~.,jl , ". PATRICIAA. CRAWFORD Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 98-0671 CIVIL ACTION LA W DAVID A. CRAWFORD Defendant IN CUSTODY Prior Judge: Kevin A. Hess CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 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 DATE OF BIRTH CURRENTL Y IN CUSTODY OF Eric Crawford May 19, 1991 Mother 2. A custody conciliation conference was originally scheduled for November 16, 2006, on the Father's Petition to Modify. However, the Father's counsel submitted a request for re-scheduling, along with a request to the Mother (who is not represented by counsel) that she contact the conciliator's office to participate in selecting an alternative date. As no response had been received from the Mother, the conference was re-scheduled for December 6, three weeks in advance. However, the Mother contacted the conciliator's office in December to advise that she was unavailable to attend The December 6 conference or any conference before 4 p.m. because she was working. The Mother did not notify the Father's counsel. 3. The Father and his counsel, Samuel L. Andes, Esquire, appeared for the December 6, 2006 conference and requested that a hearing be scheduled at the earliest possible date. The Father seeks modification of existing Order of this Court under which the Mother has primary physical custody of the Child. According to the Father, the Child has been living with him since early November 2006 with the Mother's consent. The Father seeks to confirm the actual existing arrangements. 4. Based upon the Father's representations at the conference and the Mother's inability or unwillingness to participate in conciliation without further substantial delay, the conciliator submits an Order in the form as attached scheduling a hearing in this matter and temporarily confirming the existing arrangements to prevent further disruption to the Child before the Court resolves this matter at hearing. It is expected that the hearing will require up to one-half day. De~ /;2, d.-aJ~ Date Da~ Custody Conciliator PATRICIA A. CRAWFORD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 98-0671 CIVIL DAVID A. CRAWFORD, Defendant IN CUSTODY ORDER AND NOW, this I~I day of January, 2007, the hearing in the above matter set for March 8, 2007, is continued to Wednesday, May 2, 2007, at 1 :30 p.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, P A. BY THE COURT, ~cia A. Crawford 86 Keefer Way Mechanicsburg, P A 17055 ~uel Andes, Esquire F or the Defendant :rlm ~ t 8 :8 IIJd 6 I Nvr [GOl IUW.C',',"..' .,"," I ::JUI -10 f\UVl. 'j l~\..ii 'l.jJ...j,~::(.. ...,fnJ. .:l 3Ji:!:!CI-03ll:l