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HomeMy WebLinkAbout01-5757JODY M. STAFFORD, Petitioner ROLAND D. STAFFORD, Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 2001-~'/5~]--- CIVIL TERM : IN CUSTODY PETITION FOR CUSTODY AND NOW, this 3rd day of October 2001, comes the Petitioner, Jody M. Stafford, by her attorneys, Irwin, McKnight and Hughes, and presents the following Petition for Custody. The petitioner is Jody M. Stafford, an adult individual residing at 102 Fifth Street, New Cumberland, Cumberland County, Pennsylvania 17070. The respondent is Roland D. Stafford, an adult individual residing at 102 Fifth Street, New Cumberland, Cumberland County, Pennsylvania 17070. The parties are the natural parents of four (4) minor children, namely George W. Stafford, bom July 5, 1984, Amanda L. Stafford, bom January 26, 1986, James R. Stafford, bom October 31, 1990, and Alexandra K. Stafford, bom July 19, 1992. Petitioner desires primary physical custody of the minor children, Amanda L. Stafford and Alexandra K. Stafford, and joint legal custody with periods of visitation of the girls to respondent as can be mutually arranged between the parties. The Petitioner also desires periods of regular physical custody of James R. Stafford and George W. Stafford. The best interest of the minor children, Amanda L. Stafford, Alexandra K. Stafford, James R. Stafford and George W. Stafford, requires that the court grant the petitioner's request as set forth above. WHEREFORE, petitioner respectfully seeks the entry of an Order of Court seeking primary physical custody of the minor children, Amanda L. Stafford and Alexandra K. Stafford, and joint legal custody with periods of visitation to respondent as can be mutually arranged between the parties. By: Respectfully submitted, IRWIN, McKly, IGHT & HUGHES l~a~-cus[A. Mc~t~t, III, Attorney for ~retitioner, Jody M. St~ord 60 West Pomfre~ Carlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court I. D. No. 25476 VERIFICATION The foregoing Petition for Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have head the statements made in this document and they are tree and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: October 3, 2001 JODY M. STAFFORD PLAINTIFF V. ROLAND D. STAFFORD DEFENDANT 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 01-5757 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, October 15, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , thc conciliator, at 4th Floor, Cumberland Count~ Courthouse, Carlisle on Wednesday, November 14, 2001 at 2:30 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot bc accomplished, to define and narrow thc issues to bc heard by thc court, and to enter into a temporary order. All children age five or older may also bc 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 parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THECOURT, By: /s/ .[acqueline M. Verney. Esq, 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 information about accessible facilities and reasonable accommodations available to disabled individuals having business before thc court, please contact our office. All arrangements must bc made at least 72 hours prior to any heating 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 HAVE 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 NOV' JODY M. STAFFORD, Plaintiff V. ROLAND D. STAFFORD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA ; : NO. 2001-5757 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT ANDNOW, this ~tb~k dayof ~/g~'~ ,2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. Mother, Jody M. Stafford and Father, Roland D. Stafford, shall have shared legal custody of George W. Stafford, bom July 5, 1984, Amanda L. Stafford, bom January 26, 1986, James R. Stafford, bom October 31, 1990, and Alexandra K. Stafford, born July 19, 1992. 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. 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. 2. The Mother shall have primary physical custody of Amanda L. Stafford and Alexandra K. Stafford. 3. The Father shall have primary physical custody of George W. Stafford. 4. The parents shall share physical custody of James R. Stafford on a week on week off basis from Sunday at 6:00 p.m. to Sunday at 6:00 p.m. 5. The parents shall have alternating weekend physical custody of George, Amanda and Alexandra from Friday at 6:00 p.m. to Sunday at 6:00 p.m. such that all of the children will spend weekends together. 6. The parties shall share the Thanksgiving holiday such that Father will always have physical custody of the children from 9:00 a.m. to 2:00 p.m. and Mother shall always have physical custody of the children from 2:00 p.m. to 9:00 p.m. 7. The parties shall share the Christmas holiday such that Mother shall always have physical custody of the children from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Father shall always have physical custody of the children from 12:00 noon on Christmas Day to 12:00 noon on December 26. 8. Mother shall have physical custody of the children on Mother's Day; Father shall have physical custody of the children on Father's Day. 9. Mother shall always have physical custody of the children on July 4th. 10. Each parent shall be entitled to one week of uninterrupted physical custody of all of the children during the summer, provided they give the other parent 30 days prior notice. The parents shall also provide a destination and telephone number to the non-custodial parent. 11. The receiving party shall provide transportation, unless otherwise agreed by the parties. 12. While the children are in Father's custody, he shall spend overnights at 102 Fifth Street, New Cumberland, Pennsylvania. 13. 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 consent. In the absence of mutual consent, the terms of this Order shall control. cc: Marcus A. McKnight, III, Esquire, counsel for Mother Roland D. Stafford, pro se 102 Fifth Street New Cumberland, Pa 17070 JODY M. STAFFORD, Plaintiff V. ROLAND D. STAFFORD, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA : : 2001-5757 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY 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 conceming the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF George W. Stafford Amanda L. Stafford James R. Stafford Alexandra K. Stafford July 5, 1984 Father January 26, 1986 Mother October 31, 1990 Mother July 19, 1992 Mother 2. A Conciliation Conference was held in this matter on November 14, 2001. The Mother, Jody M. Stafford was present with her counsel, Marcus A. McKnight, III, Esquire. The Father, Roland D. Stafford, was present pro se. 3. The parties agreed to entry of an Order in the form as attached. Date cq~line M. Vemey, Esquire Custody Conciliator JODY M. STAFFORD, Petitioner Ve ROLAND D. STAFFORD, Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CML ACTION - LAW 2001-5757 CIVIL TERM : : IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY AND NOW, this 16th day of August 2002, comes the Petitioner, Jody M. Stafford, by her attorneys, Irwin, Mci(night and Hughes, and presents the following Petition for Custody. The Petitioner is Jody M. Stafford, an adult individual residing at 1105 Bridge Street, New Cumberland, Cumberland County, Pennsylvania 17070. The Respondent is Roland D. Stafford, an adult individual residing at 1258 North Brown's Dam Drive, New Oxford, Adams County, Pennsylvania 17350 The parties are the natural parents of four (4) minor children, namely George W. Stafford, born July 5, 1984, Amanda L. Stafford, born January 26, 1986, James R. Stafford, born October 31, 1990, and Alexandra K. Stafford, born July 19, 1992. The parties are governed by a custody Order of Court dated November 20, 2001, a copy of which is attached hereto and marked as Exhibit "A". 3 The Petitioner desires primary physical custody of the minor children, Amanda L. Stafford, Alexandra K. Stafford, James R. Stafford, and George W. Stafford, and joint legal custody with periods of visitation of the children to Respondent as can be mutually arranged between the parties. The best interest of the minor children, Amanda L. Stafford, Alexandra K. Stafford, James R. Stafford, and George W. Stafford, requires that the court grant the Petitioner's request as set forth above. WHEREFORE, Petitioner respectfully seeks the entry of an Order of Court seeking primary physical custody of the minor children, Amanda L. Stafford, Alexandra K. Stafford, James R. Stafford, and George W. Stafford, and joint legal custody with periods of visitation to Respondent as can be mutually arranged between the parties. Date: August 16, 2002 Respectfully submitted, IRWIN, M¢IO~GItT~}IUGHES /~M. arcusl A_. McI~~, ESquire Attorney for Pet'~ Jody M. Stafford 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 2494353 Supreme Court I. D. No. 25476 4 EXHIBIT A ]. $ 200' JODY M. STAFFORD, Plaintiff ROLAND D. STAFFORD, Defendant : IN THE COURT OF COMMON PLEAS OF : CI. J3~ERLAND COUNTY,PEI~SYLVANIA : NO. 2001-5757 CIVIL TERM : : CIVIL ACTION- LAW : : IN CUSTODY ORDER OF COURT AND NOW, this ~ o ~ day of ~ ,2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. Mother, $ody M. Stafford and Father, Roland D. Stafford, shall have shared legal custody of George W. Stafford, bom Suly $, 1984, Amanda L. Stafford, bom January 26, 1986, Sames R. Stafford, born October 31, 1990, and Alexandra K. Stafford, born Suly 19, 1992. 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. 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. 2. The Mother shall have primary.physical custody of Amanda L. Stafford and Alexandra K. Stafford. 3. The Father shall have primary physical custody of George W. Stafford. 4. The parents shall share physical custody ofSames R. Stafford on a week on week offbasis from Sunday at 6:00 p.m, to Sunday at 6:00 p.m. $. The parents shall have alternating weekend physical custody of George, Amanda and Alexandra from Friday at 6:00 p.m. to Sunday at 6:00 p.m. such that all of the children will spend weekends together. 6. The parties shall share the Thanksgiving holiday such that Father will always have physical custody of the children from 9:00 a.m. to 2:00 p.m. and Mother shall always have physical custody of the children from 2:00 p.m. to 9:00 p.m. 7. The parties shall share the Christmas holiday such that Mother shall always have physical custody of the children from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Father shall always have physical custody of the children from 12:00 noon on Christmas Day to I2:00 noon on December 26. 8. Mother shall have physical custody of the children on Mother's Day; Father shall have physical custody of the children on Father's Day. 9. Mother shall always have physical custody of the children on :/uly 4th. 10. Each parent shall be entitled to one week of uninterrupted physical custody of all of the children during the summer, provided they give the other parent 30 days prior notice. The parents shall also provide a destination and telephone number to the non-custodial parent. 11. The receiving party shall provide transportation, unless otherwise agreed by the parties. 12. While the children are in Father's custody, he shall spend overnights at 102 Fifth Street, New Cumberland, Pennsylvania. 13. 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 consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, cc: Marcus A. McKnight, III, Esquire, counsel for Mother Roland D. Stafford, pro se 102 Fifth Street New Cumberland, Pa 17070 JODY M. STAFFORD, Plaintiff Vo ROLAND D. STAFFORD, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 2001-5757 CIVIL TERM : : CIVIL ACTION - LAW : IN CUSTODY 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 info~i~,ation concerning the Children who are the subject of this litigation is as follows: NAME George W. Stafford Amanda L. Stafford James R. Stafford Alexandra K. Stafford DATE OF BIRTH CURRENTLY IN CUSTODY OF July 5, 1984 Father January 26, 1986 Mother October 3 I, 1990. Mother July 19, 1992 Mother 2. A Conciliation Conference was held in this matter on November 14, 2001. The Mother, Jody M. Stafford was present with her counsel, Marcus A. McKnight, III, Esquire. The Father, Roland D. Stafford, was present pro se. 3. The parties agreed to entry of an Order in the form as attached. Date b"acq~line M. Verney, Esquire ~r Custody Conciliator .,VERIFICATION The foregoing Petition for Custody is based upon infom~ation which has been gathered by counsel and myself in the preparation of this action. I have head the statements made in this document and they are tree and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. D~e: AUGUST 16, 2002 ,~ Jt~Y M. STAFF~ ' JODY M. STAFFORD PLAINTIFF ROLAND D. STAFFORD DEFENDANT IN THE COURT OF COMMON PLEAS OF CU'MBERLAND COUNTY, PENNSYLVANIA : : 01-5757 CIVIL ACTION LAW : IN CUSTODY : ORDER OF COURT AND NOW, Wednesday, August 21, 2002 .... upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , thc conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, September 10, 2002 at 1:30 PM for a Pm-Hearing Custody Conference. At such conference, an effort will bc made to resolve thc issues in dispute; or if this cannot bc accomplished, to define and narrow thc issues to bc heard by thc court, and to enter into a temporary order. All children age five or older may also be present at thc conference. Failure to al~pcar at thc conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinlz. FOR THE COURT, By: Is~ Jacqueline M. Verney, Esq. 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 information 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 heating. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 SEP 1 1 JODY M. STAFFORD, Plaintiff V. ROLAND D. STAFFORD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001-5757 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT J_~?[/~ ~ 2002, upon AND NOW, this dayof- i-.. , consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated November 20, 2001 is hereby vacated. 2. Mother, Jody M. Stafford and Father, Roland D. Stafford, shall have shared legal custody of George W. Stafford, bom July 5, 1984, Amanda L. Stafford, born January 26, 1986, James R. Stafford, bom October 31, 1990, and Alexandra K. Stafford, born July 19, 1992. Each parent shall have an equal right, to be exemised 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. 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. 3. The Mother shall have primary physical custody of the Children. 4. The Father shall have periods of partial physical custody as follows: A. With regard to George and Amanda, who are 18 and 16 years of age, as the parties and George and Amanda agree. B. With regard to James and Alexandra, beginning September 20, 2002, at the option of the Children, Father shall partial physical custody on the first weekend of every month with Amanda and the third weekend of every month with James from Friday at 6:00 p.m. to Sunday at 6:00 p.m. C. Father shall have partial physical custody of James and Amanda, at the Children's option, on the fourth weekend of every month from Friday at 6:00 p.m. to Sunday at 6:00 p.m. D. In the event that Father's weekend coincides with a Monday holiday, Father's weekend visit shall be extended to Monday at 6:00 p.m. 5. The parties shall share the Thanksgiving holiday such that Father will always have physical custody of the children from 9:00 a.m. to 2:00 p.m. and Mother shall always have physical custody of the children from 2:00 p.m. to 9:00 p.m. 6. The Christmas holiday shall be divided into two Blocks. Block A shall be from 12:00 noon Christmas Eve to 12:00 noon Christmas Day; Block B shall be from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Father shall have Block A in even numbered years and Block B in odd numbered years. Mother shall have Block A in odd numbered years and block B in even numbered years. 7. Mother shall have physical custody of the children on Mother's Day; Father shall have physical custody of the children on Father's Day. 8. Mother shall always have physical custody of the children on July 4th. 9. Each parent shall be entitled to one week of uninterrupted physical custody of all of the children during the summer, provided they give the other parent 30 days prior notice. The parents shall also provide a destination and telephone number to the non-custodial parent. 10. Father shall be responsible for all transportation unless otherwise agreed by the parties. 11. 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 consent. In the absence of mutual consent, the terms of this Order shall control. cc: Marcus A. McKnight, III, Esquire, counsel for Mother Kara W. Haggerty, Esquire, counsel for Father JODY M. STAFFORD, Plaintiff ROLAND D. STAFFORD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 2001-5757 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. 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 Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF George W. Stafford Amanda L. Stafford James R. Stafford Alexandra K. Stafford July 5, 1984 Father January 26, 1986 Mother October 31, 1990 Mother July 19, 1992 Mother 2. A Conciliation Conference was held in this matter on September 10, 2002. The Mother, Jody M. Stafford was present with her counsel, Marcus A. McKnight, III, Esquire. The Father, Roland D. Stafford, was present pro se, however indicated that Kara W. Haggerty, Esquire represented him. 3. The Honorable Edward E. Guido entered a prior Order dated November 20, 2001 providing for shared legal, Mother having primary physical custody of the girls, Father having primary physical custody of George and the parties having shared physical custody of James. The parties agreed to entry of an Order in the form as attached. Date gttcquoune xvt. v ~ y, quire ' Custody Conciliator