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HomeMy WebLinkAbout03-1208KERI A. HARVEY, Plaintiff V. JOHN E. DELLINGER, II, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0-1- / A.9 $ CIVIL TERM CIVIL ACTION - LAW CUSTODY ACTION CUSTODY COMPLAINT TO THE HONORABLE JUDGES OF SAID COURT: 1. The Plaintiff is Keri A. Harvey residing at 48-B Old Stone House Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is John E. Dellinger, II who resides at 727 North Second Street, Steelton, Dauphin County, Pennsylvania 17113. 3. Plaintiff seeks legal custody and primary physical custody of the following child: NAME PRESENT RESIDENCE DOB Maraja Sky Dellinger 48-B Old Stone House Road 05/22/02 Carlisle, PA The child was not born in wedlock. The child is presently in the physical custody of Keri A. Harvey who resides at 48-B Old Stone House Road, Carlisle, Pennsylvania. The child has resided with the following persons and at the following addresses: Person Address Date Mother & 48-B Old Stone House Rd 02/26/03- Grandmother Carlisle, PA Present Mother & Father 48-B Old Stone House Rd 02/03 - 02/26 Grandmother Mother & 48-B Old Stone House Rd 12/02 - 02/03 Grandmother Mother, Grandmother 3228 Lisburn Rd 05/02 - 12/02 & Grandfather Mechanicsburg, PA F+. KERI A. HARVEY, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. : JOHN E. DELLINGER, II, DEFENDANT NO. 03-1208 CIVIL IN RE: CUSTODY HEARING ORDER OF COURT AND NOW, this 4th day of April, 2008, upon consideration of the Petition for Special Relief Seeking Emergency Custody or Civil Contempt filed by the Plaintiff, IT IS HEREBY ORDERED AND DIRECTED that a hearing on this matter will be held on Tuesday, April 8, 2008, at 3:00 p.m. in Courtroom No. 5 of the Cumberland County Courthouse, Carlisle, Pennsylvania. IT IS FURTHER ORDERED AND DIRECTED that the Defendant shall bring the child, Maraja Dellinger, born 5/22/03, with him to the hearing. By the Court, M. L. Ebert, Jr., J. Dianne Yacovone, CLI Megan Riesmeyer, Esquire - °P% Attorney for Mother John E. Dellinger, II, Pro Se - c„ p? Defendant bas /4LN, CI.,Ji F,t Lit •Z Wd h- ddb 88U xb17'ig,U iradd 3Hi 30 The mother of the child is Keri A. Harvey who currently resides at 48-B Old Stone House Road, Carlisle, PA 17013. She is not married. The father of the child is John E. Dellinger, II who lives at 727 North Second Street, Steelton, Pennsylvania 17113. He is not married. 4. The relationship of Plaintiff to the child is that of mother. The Plaintiff currently resides with the following persons: Name Relationship Maraja Sky Dellinger Daughter Susan Harvey Mother 5. The relationship of Defendant to the child is that of father. The Defendant currently resides with the following persons: Name John E. Dellinger Mary Dellinger Christopher Dellinger Krystal Dellinger Stan Amy Relationship Father Mother Brother Sister Sister's male friend Sister's female friend 6. Neither party has participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 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. 2 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: A. Plaintiff can properly care for her child. B. Plaintiff can provide a loving home. C. Defendant lacks the maturity to properly care for the child. D. Defendant lacks appropriate living accommodations for the child. E. Defendant has threatened Mother and the child. 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 this Honorable Court to grant her legal custody and primary physical custody of her child, subject to defendant's right to periods of supervised visitation. Respectfully submitted, Thomas D. Gould, Esquire ID #36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 3 VERIFICATION I, Keri A. Harvey, hereby certify that the foregoing CUSTODY COMPLAINT is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED:! -4 eri Harvey Plaintiff b1l 4 r\ ,\q W u, V Q V y^c- jz O O -10 vC l X60.. ? ; _ rI (..r C ?t? KERI A. HARVEY IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 03-1208 CIVIL ACTION LAW JOHN E. DELLINGER, II IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Monday, March 24, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, April 17, 2003 at 1:00 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 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 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 THE COURT, By: /s/ Dawn S. Sunday, EsM 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 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ,? yes v?'?? ` p' ?!;???,`??? ??? ?? .,; `? KERI A. HARVEY IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 03-1208 CIVIL ACTION LAW JOHN E. DELLINGER,II Defendant IN CUSTODY ORDER OF COURT AND NOW, this Z9' day of / ,l/ , 2003, upon consideration of the attached Custody Conciliation Report, iris ordered and directed as follows: 1. The Mother, Keri A. Harvey, and the Father, John E. Dellinger, II shall have shared legal custody of Maraja Sky Dellinger, born May 22, 2002. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 2. The parties shall have physical custody of the Child in accordance with the following schedule: A. The Father shall have custody of the Child on alternating weekends from Friday between 5:00 pm and 6:00 pm through Sunday at 6:00 pm and during the interim weeks from Sunday at 6:00 pm through Tuesday at 8:00 pm . B. The Mother shall have custody of the Child at all times not otherwise specified for the Father. 3. The parties shall share or alternate having custody of the Child on holidays in accordance with the following schedule: A. CHRISTMAS: The Christmas holiday shall be divided into Segment A which shall run from Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon, and Segment B which shall run from Christmas day at 12:00 noon through December 26 at 12:00 noon. In odd numbered years the Mother shall have custody of the Child during >- ZZ: : a Segment A and the Father shall have custody during Segment B. In even numbered years the Father shall have custody of the Child during Segment A and the Mother shall have custody during Segment B. B. NEW YEARS: The New Years holiday shall be divided into Segment A which shall run from New Years Eve at 12:00 noon through New Years Day at 12:00 noon and Segment B which shall run from New Years Day at 12:00 noon through January 2nd at 12:00 noon. In odd numbered years the Father shall have custody during Segment A and the Mother shall have custody during Segment B. In even numbered years, the Mother shall have custody during Segment A and the Father shall have custody during Segment B. For purposes of this Order, the entire New Years holiday shall be deemed to fall within the same year as New Years Eve. C. THANKSGIVING / EASTER: In every year, the Father shall have custody of the Child on Thanksgiving and Easter from 9:00 am until 3:00 pm and the Mother shall have custody from 3:00 pm until 9:00 pm. D. MEMORIAL DAY / JULY 4TH• In every year, the Mother shall have custody of the Child on Memorial Day from 10:00 am until 9:00 pm and the Father shall have custody of the Child on July 0' from 10:00 am until 9:00 pm. E. LABOR DAY: The parties shall alternate having custody of the Child on Labor Day from 10.00 am until 9:00 pm, with the Mother having custody in odd numbered years and the Father having custody in even numbered years. F. MOTHER'S DAY / FATHER'S DAY: In every year, the Mother shall have custody of the Child on Mother's day and the Father shall have custody of the Child on Father's Day from 9:00 am until 9:00 pm. G. The holiday custody schedule shall supercede and take precedence over the regular custody schedule. 4. Each party shall be entitled to have custody of the Child for two non-consecutive weeks each year upon providing at least thirty days advance notice to the other party. Each party shall schedule his or her weeks under this provision to include that party's regular weekend period of custody. 5. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Child comply with this provision. 6. 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, c/?maas D. Gould, Esquire - Counsel for Mother arey , Esquire - Counsel for Father I I S ??- 10ce ? KERI A. HARVEY , Plaintiff vs. JOHN E. DELLINGER,II Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-1208 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 concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Maraja Sky Dellinger May 22, 2003 Mother 2. A Conciliation Conference was held on April 17, 2003, with the following individuals in attendance: The Mother, Keri A. Harvey, with her counsel, Thomas D. Gould, Esquire and the Father, John E. Dellinger II, with his counsel, Joan Carey, Esquire. 3. The parties agreed to entry of an Order in the form as attached. &/2"? Qc" Date Dawn S. Sunday, Esquire Custody Conciliator KERI A. HARVEY, Plaintiff/Respondent W. JOHN E. DELLINGER, II Defendant/Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1208 CIVIL TERM IN CUSTODY PETITION FOR CONTEMPT Petitioner, John E. Dellinger, II, by and through his counsel, MidPenn Legal Services, states the following: 1. Defendant/Petitioner, hereinafter referred to as Father, resides at 506 Eschelman Road, Highspire, Dauphin County, Pennsylvania 17034. 2. Plaintiff/Respondent, hereinafter referred to as Mother, resides at 48-B Old Stone House Road, Carlisle, Cumberland County, Pennsylvania, 17013. 3. The above-named parties are the natural parents of Maraja Sky Dellinger, born May 22, 2002. 4. The current Custody Order, attached as Exhibit "A" and incorporated herein by reference, is dated April 29, 2005. The Order, in pertinent part, grants the parties shared legal custody of the children. Mother has primary physical custody with Father having periods of temporary physical custody alternating weekends from Friday evening until Sunday evening and on the interim weeks, from Sunday evening until Tuesday evening. The Order also sets forth a holiday custody schedule and permits each party to have a two week period of uninterrupted custody. 5. Mother has willfully disobeyed the Order in ways including, but not limited to, the following: a. Refusing to permit Father to exercise his periods of temporary physical custody in accordance with the Order. Mother has arbitrarily decided if and when Father can see Maraja and has often forced Father to go months without seeing Maraja. b. Mother has failed to keep Father informed regarding information pertinent to his rights to shared legal custody. Father is not made aware of medical visits or problems, child care information, or any other information pertaining to Maraja. c. Mother interferes with Father's ability to have telephone contact with Maraja by changing her telephone number and refusing to provide the new information to Father. 6. Mother is not acting in Maraja's best interest for reasons including, but not limited to, the following: a. Mother has willfully denied Father his periods of partial physical custody of Maraj a in ways set forth in Paragraph Five of this Petition for Contempt. b. This is the third time that Mother has denied Father periods of partial custody since the April 2003 Order. Though Father has tried to work with Mother and negotiate a return to the April 2003, Order, this has become a pattern that Father realizes he cannot resolve without legal assistance. c. Creating a tense and negative atmosphere regarding custody causes stress for Maraja and does not serve her best interests. d. Mother's actions alienate Father which interferes with the appropriate and healthy father/daughter relationship that is imperative to Maraja's ongoing emotional development and well being. e. Father and his fiancee have an infant son, John Dellinger, III, and Maraja began to develop a relationship with her half-brother. Mother's interference with Father's custodial visits also interferes with Maraja's ability to develop and nurture a bond with her half-brother. f Mother's actions interfere with Father's ability to exercise his shared legal custody right to participate in major decisions regarding Maraja. 8. Defendant's counsel contacted Plaintiff's prior attorney, Thomas Gould, Esquire, to obtain concurrence and was advised that Attorney Gould no longer represents Plaintiff. WHEREFORE, Father respectfully requests the following: a. That this Court find Mother in contempt of the existing April 29, 2005, Court Order. b. That this matter be scheduled for a custody conciliation. c. That Mother and Father continue to share legal custody of Maraja. d. That Father be granted reasonable contact via telephone and written correspondence with Maraja when she is in Mother's custody. e. That if Mother moves or changes her telephone :number, she must advise Father within ten (10) days of the new contact information. f. That Mother immediately provide Father with all information relevant to legal custody to which he is entitled such as child care information, doctor's visits, etc., in a timely manner. g. Any other relief this Court finds just and proper. Respectfully Jessi H61st, Esquire Mi enn Legal Services 401 E. Louther Street Carlisle, PA 17013 (717) 243-9400 APR 2 8 2003 KERI A. HARVEY , Plaintiff VS. JOHN E. DELLINGER,II Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-1208 CIVIL ACTION LAW IN CUSTODY ORDER OF COU T AND NOW, this -4 9* day of 2003, upon consideration of the attached Custody Conciliation R ort, it is ordered and directed as follows: 1. The Mother, Keri A. Harvey, and the Father, John E. Dellinger, II shall have shared legal custody of Maraja Sky Dellinger, born May 22, 2002. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. schedule: The parties shall have physical custody of the Child in accordance with the following A. The Father shall have custody of the Child on alternating weekends from Friday between 5:00 pm and 6:00 pm through Sunday at 6:00 pm and during the interim weeks from Sunday at 6:00 pm through Tuesday at 8:00 pro. B. The Mother shall have custody of the Child at all times not otherwise specified for the Father. 3. The parties shall share or alternate having custody of the Child on holidays in accordance. with the following schedule: A. CHRISTMAS: The Christmas holiday shall be divided into Segment A which shall run from Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon, and Segment B which shall run from Christmas day at 12:00 noon through December 26 at 12:00 noon. In odd numbered years the Mother shall have custody of the Child during Segment A and the Father shall have custody during Segment B. In even numbered years the Father shall have custody of the Child during Segment A and the Mother shall have custody during Segment B. B. NEW YEARS: The New Years holiday shall be divided into Segment A which shall run from New Years Eve at 12:00 noon through New Years Day at 12:00 noon and Segment B which shall run from New Years Day at 12:00 noon through January 2nd at 12:00 noon. In odd numbered years the Father shall have custody during Segment A and the Mother shall have custody during Segment B. In even numbered years, the Mother shall have custody during Segment A and the Father shall have custody during Segment B. For purposes of this Order, the entire. New Years holiday shall be deemed to fall within the same year as New Years Eve. C. THANKSGIVING/ EASTER: In every year, the Father shall have custody of the Child on Thanksgiving and Easter from 9:00 am until 3:00 pm and the Mother shall have custody from 3:00 pm until 9:00 pm. D. MEMORIAL DAY / JULY 4TH: In every year, the Mother shall have custody of the Child on Memorial Day from 10:00 am until 9:00 pm and the Father shall have custody of the Child on July 4`h from 10:00 am until 9:00 pm. E. LABOR DAY: The parties shall alternate having custody of the Child on Labor Day from 10:00 am until 9:00 pm, with the Mother having custody in odd numbered years and the Father having custody in even numbered years. F. MOTHER'S DAY / FATHER'S DAY: In every year, the Mother shall have custody of the Child on Mother's day and the Father shall have custody of the Child on Father's Day from 9:00 am until 9:00 pm. G. The holiday custody schedule shall supercede and take precedence over the regular custody schedule. 4. Each party shall be entitled to have custody of the Child for two non-consecutive weeks each year upon providing at least thirty days advance notice to the other party. Each party shall schedule his or her weeks under this provision to include that party's regular weekend period of custody. 5. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Child comply with this provision. 6. 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, - - - 15)7 J J. cc: Thomas D. Gould, Esquire - Counsel for Mother Joan Carey, Esquire - Counsel for Father TRVt"ItOPY" FROM :RECORD in T tidy whereof, 11 here unto set my hand and se Lof said uri rhsle, Pa. ihi , _,. da r KERI A. HARVEY IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. JOHN E. DELLINGER,I1 Defendant 03-1208 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 concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Maraja Sky Dellinger May 22, 2003 Mother 2. A Conciliation Conference was held on April 17, 200.3, with the following individuals in attendance: The Mother, Keri A. Harvey, with her counsel, Thomas D. Gould, Esquire and the Father, John E. Dellinger II, with his counsel, Joan Carey, Esquire. 3. The parties agreed to entry of an Order in the form as attached. - a / _ ano.3 ?G d ? Date Dawn S. Sunday, Esquire Custody Conciliator VERIFICATION The above-named DEFENDANT, JOHN E. DELLINGER, II, verifies that the statements made in the above Petition for Contempt are true and correct. Defendant understands that false statements herein are made subject to the penalties of 18 Pa. C.s. §4904, relating to unsworn falsification to authorities. Date : 4 S Or John E. Delli er, II KERI A. HARVEY, Plaintiff/Respondent X. JOHN E. DELLINGER, II Defendant/Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1208 CIVIL TERM IN CUSTODY CERTIFICATE OF SERVICE I, Jessica Holst, Esquire, of MidPenn Legal Services, attorney for Petitioner, John E. Dellinger, III, hereby certify that I have served a copy of the forgoing Petition for Contempt and Modification on the following date and in the manner indicated below: U.S. First Class Certified Mail, Return Receipt, Restricted Delivery Keri A. Harvey 48-B Old Stone House Road Carlisle, PA 17013 Date: 10' 0' 0)1? Carlisle, PA 17013 (717)243-9400 MidPenn Legal Services 401 East Louther Street r? L7 i ? 5 T .r{ i i":11:: _ l? a ? < __3 KERI A. HARVEY, : IN THE COURT OF COMMON PLEAS Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA y. :NO. 03-1208 CIVIL TERM JOHN E. DELLINGER, II DefendantfPetitioner : IN CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, John E. Dellinger, II, Petitioner, to proceed in forma ap opens. I, Jessica Holst, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Jessi Holst, Esquire Mi enn Legal Services 401 E. Louther Street Carlisle, PA 17013 (717) 243-9400 KERI A. HARVEY IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND C'OUN"1 Y, PENNSYLVANIA V. 03-1208 CIVIL ACTION LAW JOHN E. DELLINGER, II IN CUSTODY DEFENDANT ORDER OF COURT AND NOW. __.Thursdayl October 2-0,2005-__..-. upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on _ Tuesday November 22, 2005 at 10:00 AM for a Pre-Fieatmg 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 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 hearin(. FOR THE COURT. By; /s/ Dawn S. Sunday, 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 most 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 HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL IIELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 f n L l'C_ ?•,ti„ _ ^ ' ?, CS y ..?`.l) ` N7 KERI A. HARVEY VS. Plaintiff NCV 2 S 2005 m? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-1208 CIVIL ACTION LAW JOHN E. DELLINGER, II Defendant Prior Judge: Kevin A. Hess 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 concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Maraja Sky Dellinger May 22, 2002 Mother 2. A custody conciliation conference was held on November 22, 2005, with the following individuals in attendance: The Mother, Keri A. Harvey, who is not represented by counsel in this matter, and the Father, John E. Dellinger, II, with his counsel, Jessica Holst, Esquire. 3. The Father filed this Petition for Contempt alleging that the Mother had failed to make the Child available for periods of custody and also failed to keep the Father informed of important developments concerning the Child, both of which are required by the prior Order of this Court dated April 29, 2003. The parties were able to discuss and resolve their concerns at the conference without the necessity of an additional Court Order. 7 4( N?V?l9G2 ,??z? Date Dawn S. Sunday, Esquire Custody Conciliator cc ica Holst, Esquire - Counsel for Father 7A. Harvey, Mother C? \N CJ LI: I1 cr> - KERI A. HARVEY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-1208 JOHN E. DELLINGER, II, : CIVIL ACTION - LAW Defendant : IN CUSTODY NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are serve, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. 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 COUNT BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Se usted desea defenderse de las demandas que se prsentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted fallade tomar accion Como se describe anteriormente, el caso puede proceder sin usted y un fall por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Used puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME O VAYA A LA SIGUIENTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. CUMBERLAND COUNT BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about assessable facilities and reasonable accommodations available to disable 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. CUMBERLAND COUNT BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 KERI A. HARVEY, Plaintiff v. JOHN E. DELLINGER, II, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-1208 CIVIL ACTION - LAW IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY ORDER 1. The Plaintiff/Respondent is Keri A. Harvey, hereinafter referred to as Mother, an adult individual who resides at 611 Mallard Road, Apt. A2, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. The Defendant/Petitioner is John E. Dellinger, 11, hereinafter referred to as Father, an adult individual who resides at 506 Eshelman Street, Highspire, Dauphin County, Pennsylvania, 17034. 3. The parties are the natural parents of Maraja Sky Dellinger, born 5/22/02. 4. On April 29, 2003, a Custody Order was entered granting shared legal custody of the child to the parties and a shared physical custody arrangement was implemented. Said Order is attached hereto as Exhibit A. 5. Father believes and therefore avers, that the best interest of the child would be served if he had primary physical custody of the child. WHEREFORE, Father requests the Court to grant primary physical of the child to the him with liberal partial physical custody to Mother. Respectfully Submitted, eQ dc - Marianne E. Rudebusch, Esquire 4711 Locust Lane Harrisburg, PA 17109 (717) 657-0632 Id. No. 63522 Dated: L46-04? KERI A. HARVEY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 03-1208 JOHN E. DELLINGER, II, : CIVIL ACTION - LAW Defendant : IN CUSTODY VERIFICATION I verify that the statements made in the foregoing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. By: Job E. Dellinger, II Date: J O(n ge EXHIBIT A NNK L 0 LUU.1 KERJ A. HARVEY V5. Plaintiff JOHN E. DELLINGER,II Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-1208 CIVIL ACTION LAW IN CUSTODY ORDER OF COUlkT AND NOW, this _aq4k day of (j ?) (24?_ , 2003, upon consideration of the attached Custody Conciliation Rleport, it is ordered and directed as follows: 1. The Mother, Keri A. Harvey, and the Father, John E. Dellinger, II shall have shared legal custody of Maraj a Sky Dellinger, bom May 22, 2002. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 2. The parties shall have physical custody of the Child in accordance with the following schedule: A. The Father shall have custody of the Child on alternating weekends from Friday between 5:00 pm and 6:00 pm through Sunday at 6:00 pm and during the interim weeks from Sunday at 6:00 pm through Tuesday at 8:00 pm . B. The Mother shall have custody of the Child at all times not otherwise specified for the Father. 3. The parties shall share or alternate having custody of the Child on holidays in accordance. with the following schedule: A. CHRISTMAS: The Christmas holiday shall be divided into Segment A which shall run from Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon, and Segment B which shall run from Christmas day at 12:00 noon through December 26 at 12:00 noon. In odd numbered years the Mother shall have custody of the Child during Segment A and the Father shall have custody during Segment B. In even numbered years the Father shall have custody of the Child during Segment A and the Mother shall have custody during Segment B. B. NEW YEARS: The New Years holiday shall be divided into Segment A which shall run from New Years Eve at 12:00 noon through New Years Day at 12:00 noon and Segment B which shall run from New Years Day at 12:00 noon through January 2'd at 12:00 noon. In odd numbered years the Father shall have custody during Segment A and the Mother shall have custody during Segment B. In even numbered years, the Mother shall have custody during Segment A and the Father shall have custody during Segment B. For purposes of this Order, the entire New Years holiday shall be deemed to fall within the same year as New Years Eve. C. THANKSGIVING /EASTER: In every year, the Father shall have custody of the Child on Thanksgiving and Easter from 9:00 am until 3:00 pm and the Mother shall have custody from 3:00 pm until 9:00 pm. D. MEMORIAL DAY / JULY 4TH: In every year, the Mother shall have custody of the Child on Memorial Day from 10:00 am until 9:00 pm and the Father shall have custody of the Child on July 4'h from 10:00 am until 9:00 pm. E. LABOR DAY: The parties shall alternate having custody of the Child on Labor Day from 10:00 am until 9:00 pm, with the Mother having custody in odd numbered years and the Father having custody in even numbered years. F. MOTHER'S DAY / FATHER'S DAY: In every year, the Mother shall have custody of the Child on Mother's day and the Father shall have custody of the Child on Father's Day from 9:00 am until 9:00 pm. G. The holiday custody schedule shall supercede and take precedence over the regular custody schedule. 4. Each party shall be entitled to have custody of the Child for two non-consecutive weeks each year upon providing at least thirty days advance notice to the other party. Each party shall schedule his or her weeks under this provision to include that party's regular weekend period of custody. 5. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall ensure that third parties liaving contact with the Child comply with this provision 6. 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, 1S -- - J. cc: Thomas D. Gould, Esquire - Counsel for Mother Joan Carey , Esquire - Counsel for Father 1'RQIE DOPY-"FROM RECORD Jb. Tes ' . 6ny whereof, )l here unto set my hand and se I, of said urtri?isl?e,Pa. Thi I-- da .... KERI A. HARVEY , Plaintiff vs. JOHN E. DELLINGER,II Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-1208 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 concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Maraja Sky Dellinger May 22, 2003 Mother 2. A Conciliation Conference was held on April 17, 2003, with the following individuals in attendance: The Mother, Keri A. Harvey, with her counsel, Thomas D. Gould, Esquire and the Father, John E. Dellinger II, with his counsel, Joan Carey, Esquire. 3. The parties agreed to entry of an Order in the form as attached. 4,0-1 J _a 10a3_ Date Dawn S. Sunday, Esquire Custody Conciliator ? d ?-. n >' o ?.: ?=_ ?. ? - a ?,,.- w ? ?a :??? ? u? ? ,; ? ` /Q? ? ? ??? t - ;..? W ?.3 n. -}- N ??? KERI A. HARVEY IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY. PENNSYLVANIA V. JOHN E. DELLINGER, 11 DEFENDANT 03-1208 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, -- Friday, February 03, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. the conciliator, at 39 West Main Street, Mechanicsburg, PA I7055 on Tuesday, March 07, 2006 at 8:30 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 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 THE COURT, By: lsl Dawn S. Sunday, Esq. hn, 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 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 r Ne,J 0,14" 0Z Marianne E. Rudebusch, Esquire 4711 Locust Lane Harrisburg, PA 17109 717-657-0632 Id. No. 63522 Attorney for Defendant KERI A. HARVEY, Plaintiff V. JOHN E. DELLINGER, II, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-1208 : CIVIL ACTION - LAW : IN CUSTODY STIPULATION FOR CUSTODY THIS AGREEMENT, is made and entered into between the parties, JOHN E. DELLINGER, II and KERI A. HARVEY, hereinafter referred to as Father and Mother. The parties are the natural parents of Maraja S. Dellinger, born 5/22/02. The parties desire to enter into an agreement modifying the Custody Order issued 4/29/03. The parties agree to equally share physical and legal custody of the child. 2. The child shall be with each parent seven full days every other week. 3. Beginning on Sunday 2/26/06, the child shall be with Father from 9:00 a.m. until the following Sunday at 9:00 a.m. 4. The parties shall have the child on her birthday such that Father shall have her from 9:00 a.m. until 3:00 p.m. in even years and Mother shall have the child from 9:00 a.m. until 3:00 p.m. in odd years. At the end of his/her period of physical custody, the child shall be dropped off at the party's residence who is beginning their period of physical custody. All other provisions of the existing custody order shall remain in effect. IN WITNESS WHEREOF, and intending to be bound hereby, the parties have signed and sealed this Agreement on the day of 2006, at Harrisburg, Pennsylvania.( In thje?prbsence of. A. Harvey (SEAL) Job' E. Dellinger, 11 R'. _, v , u r,NH u 6 2ui Marianne E. Rudebusch, Esquire 4711 Locust Lane Harrisburg, PA 17109 717-657-0632 Id. No. 63522 Attorney for Defendant KERI A. HARVEY, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 03-1208 JOHN E. DELLINGER, II, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, this S"- day of p,ac.4 _, 2006, it is hereby ORDERED that the attached Stipulation for Custody is made and entered as an Order of this Court. BY THE COURT: J. ? ?? ?, 4\ J G r, ? r ,?r J ?_, R...IVED MAR 0 0 h KERI A. HARVEY Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. JOHN E. DELLINGER, II Defendant 03-1208 CIVIL ACTION LAW IN CUSTODY ORDER AND NOW, this 7`h day of March, 2006 , the conciliator, being advised by counsel that all custody issues have been resolved by agreement between the parties, hereby relinquishes jurisdiction. The custody conciliation conference scheduled for today, is cancelled. FOR THE COURT, /Par4zP 7 r a co& Date Dawn S. Sunday, Esquire Custody Conciliator f, . r. .1 KERI A. HARVEY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 03-1208 JOHN E. DELLINGER, II, : CIVIL ACTION - LAW Defendant : IN CUSTODY NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are serve, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. 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 COUNT BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Se usted desea defenderse de las demandas que se prsentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notification de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objections a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fall por cuatquier suma de dinero reclamada en la demanda o cualquier otra reclamation o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Used puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME O VAYA A LA SIGUIENTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. CUMBERLAND COUNT BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about assessable facilities and reasonable accommodations available to disable 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. CUMBERLAND COUNT BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 KERI A. HARVEY, Plaintiff V. JOHN E. DELLINGER, II, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-1208 : CIVIL ACTION - LAW : IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY ORDER The Plaintiff/Respondent is Keri A. Harvey, hereinafter referred to as Mother, an adult individual who resides at 611 Mallard Road, Apt. A2, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. The Defendant/Petitioner is John E. Dellinger, II, hereinafter referred to as Father, an adult individual who resides at 506 Eshelman Street, Highspire, Dauphin County, Pennsylvania, 17034. 3. The parties are the natural parents of Maraja Sky Dellinger, born 5/22/02. 4. On March 8, 2006, the parties entered into a Stipulation for Custody and was made an Order of Court. Said Stipulation granted the parties equal physical and legal custody of the child on a week on/week off basis. Said Order is attached hereto as Exhibit A. 5. Father believes and therefore avers, that the best interest of the child would be served if he had primary physical custody of the child. WHEREFORE, Father requests the Court to grant primary physical of the child to the him with liberal partial physical custody to Mother. Respectfully Submitted, Marianne E. Rudebusch, Esquire 4711 Locust Lane Harrisburg, PA 17109 (717) 657-0632 Id. No. 63522 Dated: '' ?-0? KERI A. HARVEY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 03-1208 JOHN E. DELLINGER, II, : CIVIL ACTION - LAW Defendant : IN CUSTODY VERIFICATION I verify that the statements made in the foregoing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. By: _ Jo E. Dellinger, Date: S f o EXHIBIT A k Marianne E. Rudebusch, Esquire 4711 Locust Lane Harrisburg, PA 17109 717-657-0632 Id. No. 63522 Attorney for Defendant KERI A. HARVEY, Plaintiff V. JOHN E. DELLINGER, H, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1208 CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this y V, day of 7k&, r A , 2006, it is hereby ORDERED that the attached Stipulation for Custody is made and entered as an Order of this Court. BY THE COURT: J. E`r UIE: COPY M-01A RECOP,0 in Tl liwq wind, ! horn unto sat ray k,; :141 a^.d 'the shad of said Court at Carlkw' , Pa. 0(2a4d?A. 02006 ProthoneWv' Marianne E. Rudebusch, Esquire 4711 Locust Lane Harrisburg, PA 17109 717-657-0632 Id. No. 63522 Attorney for Defendant KERI A. HARVEY, Plaintiff V. JOHN E. DELLINGER, II, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1208 : CIVIL ACTION - LAW : IN CUSTODY r-> a u w '-7 ?n a t7' STIPULATION FOR CUSTODY THIS AGREEMENT, is made and entered into between the parties, JOHN E. DELLINGER, II and KERI A. HARVEY, hereinafter referred to as Father and Mother. The parties are the natural parents of Maraja S. Dellinger, born 5/22/02. The parties desire to enter into an agreement modifying the Custody Order issued 4/29/03. I . The parties agree to equally share physical and legal custody of the child. 2. The child shall be with each parent seven full days every other week. 3. Beginning on Sunday 2/26/06, the child shall be with Father from 9:00 a.m. until the following Sunday at 9:00 a.m. r 4. The parties shall have the child on her birthday such that Father shall have her from 9:00 a.m. until 3:00 p.m. in even years and Mother shall have the child from 9:00 a.m. until 3:00 p.m. in odd years. At the end of his/her period of physical custody, the child shall be dropped off at the party's residence who is beginning their period of physical custody. 6. All other provisions of the existing custody order shall remain in effect. IN WITNESS WHEREOF, and intending to be bound hereby, the parties have signed and sealed this Agreement on the 2a day of? Yj . 2006, at Harrisburg, Pennsylvania. I In tWr)v6sence of. A. Harvey (SEAL) Jo E. Dellinger, 11 KERI A. HARVEY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 03-1208 JOHN E. DELLINGER, II, : CIVIL ACTION - LAW Defendant : IN CUSTODY CERTIFICATE OF SERVICE AND NOW, this day of 2006, I, Katherine A. Frey, Secretary to Marianne E. Rudebusch, Esquire, Attorney for the Defendant, hereby certify that a copy of the within document has been served, by depositing a copy of the same in the United States mail, first class, postage prepaid, delivery at Harrisburg, Pennsylvania, to the following addressee: Keith Hickman Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 By: A ", A - i ? Katherine A. Frey C C G 7J r - Z) KERI A. HARVEY IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY. PENNSYLVANIA V. JOHN E. DELLINGER, II DEFENDANT 03-1208 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, May 11, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, June 01, 2006 at 10:00 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 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 THE COURT, By: /s/ Dawn S. Sunda Es q. 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 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 Cn'X ?.? ? ? ?0.f? s ViNOMSNN-d ) N` o-) 7 a %nnvino h£ :£ bid 51 Ow 90oz XMONOHiOed 3Ni dfl r4, 111:0-OTT KERI A. HARVEY Plaintiff VS. JOHN E. DELLINGER Defendant REPEIVED JIUL 0 7 ".006 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-1208 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this /0 day of IUA, , 2006, upon consideration of the attached Custody Conciliation Report, it is rdered and directed as follows: 1. The parties shall submit themselves, their minor Child, and any other individuals deemed necessary by the evaluator, to a custody evaluation to be performed by a professional selected by agreement. The purpose of the evaluation shall be to obtain independent professional recommendations concerning ongoing custody arrangements which will best meet the needs and interests of the Child. The parties shall sign any authorizations deemed necessary by the evaluator to obtain additional information pertaining to the Child or the parties. Unless otherwise agreed, the parties shall share all costs of the evaluation. 2. Pending completion of the custody evaluation and further Order of Court or agreement of the parties, the prior Order of this Court dated March 8, 2006 shall continue in effect. In addition, both parties shall ensure that the Child attends her current childcare (Colorful Future) at least two days during each party's weeks of custody, unless otherwise agreed between the parties. 3. Within 60 days following receipt of the evaluator's written custody recommendations, counsel for either party may contact the conciliator to schedule an additional conference, if necessary to address outstanding issues. BY THE COURT, cc: Marianne E. Rudebusch, Esquire - Counsel for Father .7„ j0 , o6 Keith Hickman and Lucy Johnston Walsh, Esquire - Counsel for Mother CIL, Keri A. Harvey, : IN THE COURT OF COMMON PLEAS OF Plaintiff/ Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY John E. Dellinger, II , Defendant/ Respondent : NO. 03-1208 CIVIL TERM PETITION TO MODIFY CUSTODY ORDER 1. The Petitioner, Keri A. Harvey (Mother), by her attorneys, the Family Law Clinic, respectfully represents that on March 8, 2006 an Order of Court was entered for custody of minor child, Maraja Sky Dellinger, born 5/22/02, a true and correct copy of which is attached. Under the existing Order, Mother and Father share physical and legal custody of the child. The parents alternate custody on a weekly basis. 2. This Order should be modified because: a. Mother is willing to undergo a custody evaluation as per order of the court dated July 10, 2006, however Father indicated he will not cooperate in the evaluation. b. Mother does not feel safe dropping child off at Father's home as she has been threatened by Father's paramour, and consequently has arranged for other people to transport the child for the custody exchanges. c. Mother has arranged for all transportation during custody exchanges so as to avoid any confrontation between Mother, Father and his paramour at Mother's current residence. d. The Respondent/Father has threatened Mother on several occasions that he will not return the child. e. On October 29, 2006, Mother's aunt went to retrieve the child on behalf of Mother. Maternal aunt called the police because child was not made available as per the current custody order. The child was then transferred to the Mother with police assistance. WHEREFORE, Petitioner asks that the Court modify the existing Order for Custody and grant Mother primary physical custody as it will be in the best interest of the child. Date: f i o v oV` Andrea Zook Certified Legal InternCL? O S LACE ROBER .RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 1A FAKubai 9 Marianne E. Rudebusch, Esquire 4711 Locust Lane Harrisburg, PA 17109 717-657-0632 Id. No. 63522 Attorney for Defendant KERI A. HARVEY, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 03-1208 JOHN E. DELLINGER, II, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, this - 0&4- day of /-tA•&• 2006, it is hereby 13, ORDERED that the attached Stipulation for Custody is made and entered as an Order of this Court. BY THE COURT: J. V., .,n n E?IgIT A Marianne E. Rudebusch, Esquire 4711 Locust Lane Harrisburg, PA 17109 717-657-0632 Id. No. 63522 Attorney for Defendant KERI A. HARVEY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 03-1208 JOHN E. DELLINGER, II, : CIVIL ACTION - LAW Defendant : IN CUSTODY STIPULATION FOR CUSTODY THIS AGREEMENT, is made and entered into between the parties, JOHN E. DELLINGER, H and KERI A. HARVEY, hereinafter referred to as Father and Mother. The parties are the natural parents of Maraja S. Dellinger, born 5/22/02. The parties desire to enter into an agreement modifying the Custody Order issued 4/29/03. 1. The parties agree to equally share physical and legal custody of the child. 2. The child shall be with each parent seven full days every other week. 3. Beginning on Sunday 2/26/06, the child shall be with Father from 9:00 a.m. until the following Sunday at 9:00 a.m. 4. The parties shall have the child on her birthday such that Father shall have her from 9:00 a.m. until 3:00 p.m. in even years and Mother shall have the child from 9:00 a.m. until 3:00 p.m. in odd years. 5. At the end of his/her period of physical custody, the child shall be dropped off at the party's residence who is beginning their period of physical custody. 6. All other provisions of the existing custody order shall remain in effect. IN WITNESS WHEREOF, and intending to be bound hereby, the parties have signed and sealed this Agreement on the ? day of , 2006, at Harrisburg, Pennsylvania. .1 (SEAL) VERIFICATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date:. JM - VV A-X*- Z& Ms. Keri A. Harvey CERTIFICATE OF SERVICE I, Andrea Zook, Certified Legal Intern, the Family Law Clinic, hereby certify that I am serving a true and correct copy of a Petition to Modify Custody Order on the following person by first class U.S. Mail, postage prepaid, this c7 day of-VC?1hkyr- , 2006: Marianne Rudebusch, Esquire 45 N Pitt Street Carlisle, PA 17013 a4 ':::? /-C r4- Andrea Zook Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 r-. .?? C`7 s-_ _? --? . J ? ? ~r?? r ? ??' ?. 4 ? 3 , KERI A. HARVEY IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JOHN E. DELLINGER, II 03-1208 CIVIL ACTION LAW . IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, November 16, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, December 13, 2006 at 10:30 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 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 hearinp.. FOR THE COURT. By: /s/ Dawn S. Sunda Es q. 1110 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 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 2 ?J 9O' l i' ?/ 90• I e•N f L I If 7''M ALI 6 1 :01 VV I Z !"ON 90"N may; ;...._... t1 0 ", LL , -l e' l1 01 KERI A. HARVY VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff 03-1208 CIVIL ACTION LAW JOHN E. DELLINGER, II Defendant IN CUSTODY ORDER OF COURT AND NOW, this Zo day of ??-?-- , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The parties shall proceed with the custody evaluation in accordance with the prior Order of this Court dated July 10, 2006, with the Father contacting Kasey Shienvold's office promptly to schedule his first appointment. 2. Pending further Order of Court or agreement of the parties, the parties shall share having physical custody on alternating weeks with the exchange of custody to take place every Sunday morning at 10:00 a.m. 3. The parent who has custody of the Child under the alternating weekly schedule shall contact the other parent on Sunday at 5:00 p.m. to discuss issues pertaining to the Child only and exchange information pertaining to the Child. 4. The Father shall be entitled to contact the Child at any time during the Mother's period of custody on the Child's cell phone, the number for which shall be provided by the Mother. The Mother shall be entitled to contact the Child during the Father's periods of custody at reasonable times and, in addition, the Father shall ensure that the Child contacts the Mother by telephone on Wednesdays at 5:00 p.m. during the Father's periods of custody. 5. The parties shall have custody of the Child over the Christmas holiday in 2006 with the Mother having custody from Christmas Eve at 9:00 a.m. through Christmas Day at 12:00 noon, and the Father having custody from Christmas Day at 12:00 noon through December 26 at 12:00 noon. 6. The Father shall make the Child available to be with the Mother around the time of the anticipated birth of the Mother's child in the Spring of 2007. 7. Within 60 days of receipt of the evaluator's written custody recommendations, counsel for either party or a party pro se may contact the conciliator to schedule an additional custody conciliation conference, if necessary. 8. The parties shall cooperate with each other in establishing sufficient communication and cooperation to enable them to effectively co-parent their Child. 9. 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: , Hammill and Lucy ohn E. Dellinger, II - 4 Johnston-Walsh, Esquire - Counsel for Mother Father BY THE COURT, --, KERI A. HARVEY IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. JOHN E. DELLINGER, II Defendant Prior Judge: Kevin A. Hess 03-1208 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 concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Maraja Sky Dellinger May 22, 2002 Mother/Father 2. A custody conciliation conference was held on December 13, 2006, with the following individuals in attendance: the Mother, Keri A. Harvey, with her counsel, Jill Hammill and Lucy Johnston-Walsh, Esquire, and the Father, John E. Dellinger, II, who was not represented by counsel in this matter. 3. The parties agreed to entry of an Order in the form as attached, with the exception of minor details recommended by the conciliator. sr Date Dawn S. Sunday, Esquire Custody Conciliator Keri A. Harvey, Plaintiff/Petitioner John E. Dellinger, II, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION-LAW IN CONTEMPT : NO. 03-1208- CIVIL TERM NOTICE AND ORDER TO APPEAR Legal proceedings have been brought against you alleging you have willfully disobeyed an order of court for Custody. If you wish to defend against the claim set forth in the following pages, you may, but are not required to file in writing with the court your defenses or objections. Whether or not you file in writing with the court your defenses or objections, you must appear in person in court on at _.M. in Courtroom , in the Cumberland County Courthouse, Carlisle, Pennsylvania, 17013. IF YOU DO NOT APPEAR IN PERSON, THE COURT MAY ISSUE A WARRANT FOR YOUR ARREST If the court finds that you have willfully failed to comply with its order for partial custody, you may be found to be in contempt of court and committed to jail, fined or both. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford St. Carlisle, PA 17013 (717) 249-3166 BY THE COURT: J. AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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 hearing. Keri A. Harvey, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION-LAW IN CONTEMPT John E. Dellinger, II, Defendant/Respondent NO. 03-1208- CIVIL TERM ORDER OF COURT AND NOW, this day of , 2008, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before, , the conciliator, at , on the day of 2008, 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 enter into a temporary order. 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 THE COURT: By: Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford St. Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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 hearing. Keri A. Harvey, Plaintiff/Petitioner V. John E. Dellinger, 11, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION-LAW IN CONTEMPT : NO. 03-1208 CIVIL TERM PETITION FOR SPECIAL RELIEF SEEKING EMERGENCY CUSTODY PURSUANT TO Pa. RCP 1915.13 OR IN THE ALTERNATIVE CIVIL CONTEMPT FOR DISOBEDIENCE OF CUSTODY ORDER PURSUANT TO 23 Pa. C.S. 4346 The Petitioner, Keri A. Harvey ("Mother"), by counsel, hereby brings this Petition for Special Relief or in the alternative Civil Contempt, and respectfully requests that this Court order the immediate return of the minor child, Maraja Sky Dellinger, born May 22, 2003, to Mother and find Defendant/Respondent, John E. Dellinger, II, in contempt of the December 20, 2006 Court Order. Maraja shall stay in Mother's custody beginning immediately and continuing until the next exchange time on April 20, 2008 or at such other time as this court deems just. In support of her Petition, Petitioner states as follows: 2. 3. 4 The petitioner is Keri Harvey ("Mother"), an adult individual who resides at 3 East Main Street, Shiremanstown, Cumberland County, PA 17011 The respondent is John E. Dellinger, II., ("Father") an adult individual who resides at 506 Eshelman Street, Highspire, Dauphin County, PA 17034 The parties are the natural parents of Maraja Sky Dellinger, born May 22, 2003. On December 20, 2006, the Honorable Kevin A. Hess entered an Order awarding Mother and Father shared physical custody of their minor child. Each parent has custody on alternating weeks with the exchange to take place every Sunday morning at 10:00 a.m. A true and correct copy of this order is attached to this petition as exhibit A. Father has willfully failed to abide by the Order in that he refused to return child to Mother on Sunday, March 30, 2008, at the regular exchange time. To date Father has not allowed any physical contact between Mother and child. 6. Father contacted Mother on Saturday March 29, 2008 to inform her that he would not be returning child on Sunday March 30, 2008 as scheduled in the Custody Order. Mother contacted Shiremanstown Police Department and Highspire Police Department to enforce the Custody Order. Both Police Departments refused to enforce the order. 7. On Monday March 31, 2008, the below-signed legal intern contacted the Shiremanstown Police Department and the Highspire Police Department to enforce the Custody Order. Officer Barnes of the Shiremanstown Police Department stated that since the child was being kept by Father in Highspire, Highspire Police Department is primarily responsible for enforcing the Custody Order. The below-signed legal intern spoke with Officer Webber with Highspire Police Department on Monday March 31, 2008. Officer Webber stated that the Police Department dealt in criminal law not civil law and did not enforce custody orders in this situation. The below signed legal intern offered both Police Departments a copy of the Custody Order and both stated it was not necessary. 8. Respondent is unrepresented and therefore concurrence under Pa. RCP 208.2(d) is not required. The below-signed legal intern contacted Respondent on Monday March 31, 2008 to inform him that he was in violation of the custody order. Respondent stated that he was well aware of that and had no intention of returning the child. Father challenged Mother's counsel to bring action in court. 9. The Honorable Kevin A. Hess previously ruled on matters in this case. WHEREFORE, Petitioner requests that this Court: a. Find Father in contempt of the Court's December 20, 2006 Custody Order, and, pursuant to 23 Pa. C.S. 4346, punish by any one or more of the following: i. Imprisonment for a period not to exceed six months; ii. A fine not to exceed $500; iii. Probation for a period not to exceed six months; iv. An order for nonrenewal, suspension, or denial of operating privilege pursuant to section 4355. iv. An order for nonrenewal, suspension, or denial of operating privilege pursuant to section 4355. b. Order Father to immediately comply with the December 20, 2006 Order and return the child to Mother's care and custody. C. Award Mother additional custody time to compensate for the wrongful deprivation of custodial time; d. Allow the child to finish the school year at Elmwood Elementary School, where she is currently enrolled. e. Award Mother such other relief as the Court deems appropriate. f. Schedule a hearing on this matter to address the Petition for Special Relief. Date: l Respectfully submitted, ianne Yacovone Certified Legal Intern M Aft? -??11 Meg Riesmeyer Supervising Attorney THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 VERIFICATION I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Ker A. Harvey Plaintiff/Petitioner CERTIFICATE OF SERVICE I, Dianne Yacovone, hereby certify that I am serving a true and correct copy of the petition for Special Relief or in the alternative Civil Contempt for Disobedience of Custody Order on John E. Dellinger, II by first class United States Mail, addressed as follows: 506 Eshelman Street, Highspire PA, 17034. Date: Dianne Yacovone Certified Legal Intern Exhibit A KERI A. HARVY VS. Plaintiff JOHN E. DELLINGER, II Defendant .sIle IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-1208 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT C 1W AND NOW, this AU7[1 day of 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The parties shall proceed with the custody evaluation in accordance with the prior Order of this Court dated July 10, 2006, with the Father contacting Kasey Shienvold's office promptly to schedule his first appointment. 2. Pending further Order of Court or agreement of the parties, the parties shall share having physical custody on alternating weeks with the exchange of custody to take place every Sunday morning at 10:00 a.m. 3. The parent who has custody of the Child under the alternating weekly schedule shall contact the other parent on Sunday at 5:00 p.m. to discuss issues pertaining to the Child only and exchange information pertaining to the Child. 4. The Father shall be entitled to contact the Child at any time during the Mother's period of custody on the Child's cell phone, the number for which shall be provided by the Mother. The Mother shall be entitled to contact the Child during the Father's periods of custody at reasonable times and, in addition, the Father shall ensure that the Child contacts the Mother by telephone on Wednesdays at 5:00 p.m. during the Father's periods of custody. 5. The parties shall have custody of the Child over the Christmas holiday in 2006 with the Mother having custody from Christmas Eve at 9:00 a.m. through Christmas Day at 12:00 noon, and the Father having custody from Christmas Day at 12:00 noon through December 26 at 12:00 noon. 6. The Father shall make the Child available to be with the Mother around the time of the anticipated birth of the Mother's child in the Spring of 2007. 7. Within 60 days of receipt of the evaluator's written custody recommendations, counsel for either party or a party pro se may contact the conciliator to schedule an additional custody conciliation conference, if necessary. 8. The parties shall cooperate with each other in establishing sufficient communication and cooperation to enable them to effectively co-parent their Child. 9. 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, Kevin . Hess J. cc: Jill Hammill and Lucy Johnston-Walsh, Esquire - Counsel for Mother John E. Dellinger, H - Father 11 bond `? 'b .?_ ?; 7 ` E- `s .::' r ?? " ? ' ? ?: ??{ .?_ A N Ms. Keri A. Harvey, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY Mr. John E. Dellinger, II Defendant/Respondent NO. 03-1208 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To The Prothonotary: Kindly allow Keri A. Harvey, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date Respectfully submitted, ianne Yacovone Certified Legal Intern Meg Riesmeyer Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 a, Cl VS. To In the Court of Common Pleas of Cumberland County, Pennsylvania No. ( S - - 2-0 Civil. 19 Prothonotary 19 Attorney for Plaintiff Term, 19 vs. P R A E C I P E Filed Atty. r- ? v ? r L. ^ L KERI A. HARVEY IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JOHN E. DELLINGER, II DEFENDANT 2003-1208 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, April 16, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, April 24, 2008 at 10:00 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. 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 THE COURT. By: /s/ Dawn S. Sunda Es q. 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 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 OF THE 2T,19 APR 16 A? 10: `?d a ?l . KERI A. HARVEY VS. Plaintiff JOHN E. DELLINGER, II Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2003-1208 CIVIL ACTION LAW IN CUSTODY ORDER AND NOW, this 23rd day of April, 2008 , the conciliator, being advised by Plaintiff s counsel (and confirmed by Defendant's counsel) that all custody issues have been resolved by agreement between the parties, hereby relinquishes jurisdiction. The custody conciliation conference scheduled for Thursday, April 24, 2008, is cancelled. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator no 9c : I Wd 92 adv € 001 d1 ?kUIV' (il. L-I'd,, 3 EV 301=40, --aTU Keri A. Harvey, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY John E. Dellinger, II, Defendant : NO. 03-1208 CIVIL TERM PETITION TO MODIFY CUSTODY ORDER 1. The petition of Ms. Keri A. Harvey, by her attorneys, the Family Law Clinic, respectfully represents that on December 20, 2006, an Order of Court was entered for custody of Maraja Sky Dellinger, born May 22, 2003 a true and correct copy of which is attached. Under the existing Order, Mother and Father have shared legal and physical custody of the child. Mother is to have physical custody of the child on alternating weeks beginning Sunday at 10 a.m. 2. By Order of Court dated April 8, 2008, the child was to remain enrolled in the Steelton Highspire Elementary School until the end of the 2007-2008 school year. 3. This Order should be modified because: a. The school district in which Mother resides, Mechanicsburg School District, consistently performs much better in Pennsylvania Adequate Yearly Progress Reports than the Steelton Highspire school district in which father resides and in which the child is currently enrolled. b. Father has not participated in extracurricular activities with the child in his own school district, while Mother has traveled to Father's school district to assist in extracurricular activities with the child. c. Father's fiancee does not have a driver's license and therefore, Father is the only party in his household available to provide transportation to or from school in emergencies. In Mother's household, however, Mother, her mother, and her fiancee are all available to transport the child to and from school. 4. The opposing party is unrepresented by counsel, therefore no concurrence was sought. 5. Judges Hess and Ebert have previously ruled on this matter. WHEREFORE, Petitioner respectfully requests that this Honorable Court modify the existing Order for Custody and order that Father allow Mother to enroll the child in Mother's School District, Mechanicsburg School District, and specifically West Elm Elementary School. Date: r$ ? CHAEL LIGHTF T Certified Legal Intern r CDONALD-F X MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. § 4904 relating to unworn falsification to authorities. Date: h?p a U 0 erA. Harvey 9 CERTIFICATE OF SERVICE I, Michael Lightfoot, Certified Legal Intern, the Family Law Clinic, hereby certify that I am serving a true and correct copy of a Petition to Modify Custody Order on the following person by first class U.S. Mail, postage prepaid, this 26 h day of June, 2008: John E. Dellinger, II 506 Eshelman Street Highspire, PA 17034 r , i Michael Lightfoot Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 r- CID ,. 3 KERI A. HARVEY IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 2003-1208 CIVIL ACTION LAW JOHN E. DELLINGER, II IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Monday, June 30, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Friday, August 01, 2008 at 12:00 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 be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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 THE COURT, By: /s/ Dawn S. Sunda Es q. I.A 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 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 11t ? d "' ?\a n 'I ! ,1 tier ocaz Keri A. Harvey, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 03-1208 CIVIL TERM John E. Dellinger II, : Defendant : IN CUSTODY PRAECIPE TO WITHDRAW PETITION To the Prothonotary: Please withdraw the Petition to Modify Custody Order filed on June 26, 2008 by Plaintiff Keri Harvey in the above captioned matter. Date sC t Uj x ( k-1 MICHAEL LIGHT O Certified Legal Intern ANNE NALD-FO MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 r°`? +?, t` ?: c?v? i-7 ?- ? ' j??- . .?'..? ?'?.,7 -.c"7 .,.. ? AUG 0 8 2008 KERI A. HARVEY VS. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2003-1208 CIVIL ACTION LAW JOHN E. DELLINGER, II Defendant . IN CUSTODY ORDER AND NOW, this 7th day of August, 2008 , the conciliator, being advised by both parties that all custody issues have been resolved by agreement between the parties, hereby relinquishes jurisdiction. The custody conciliation conference scheduled for August 1, 2008, is cancelled. FOR THE COURT, 4L-41'? Dawn S. Sunday, Esquire Custody Conciliator ? 0 ar O e ? C rr' C: cn _I-- ?j co ?? KERI A. HARVEY, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003 - 1208 CIVIL TERM JOHN E. DELLINGER, II, CIVIL ACTION - LAW Defendant CUSTODY ACTION PETITION TO MODIFY CUSTODY ORDER 1. The Petitioner (Mother) is Keri A. Harvey residing at 3 East Main Street, Shiremanstown, Cumberland County, Pennsylvania 17011. 2. The Defendant/Respondent (Father) is John E. Dellinger, II who resides at 727 North Second Street, Steelton, Dauphin County, Pennsylvania 17113. 3. Father and Mother are the biological parents of Maraja Sky Dellinger, born May 22, 2002. 4. Mother seeks to Modify the Order of Court dated December 20, 2006, by continuing to have joint legal custody and by modified the currently alternating weekly custody schedule and granting her primary physical custody of Maraja. A copy of the Order is attached as exhibit A. 5. Maraja's best interest will be served if Mother's request is granted because: A. Mother will place the interest of Maraja before her own. B. Mother can provide a more stable and consistent environment for Maraja. D. Mother is committed to encouraging a positive relationship between Maraja and each parent and their extended family. WHEREFORE, Mother requests that this honorable court grant her joint legal custody and primary physical custody of Maraja subject to liberal periods of partial physical custody to Father. Respectfully submitted, Thomas D. Gould, Esquire ID #36508 2 East Main Street Shiremanstown., PA 17011 (717) 731-1461 VERIFICATION I, Keri A. Harvey, hereby certify that the foregoing PETITION TO MODIFY CUSTODY ORDER is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalt=ies of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: ?? IJAVA ?Keri A. Harvey Plaintiff KERI A. HARVY vs. Plaintiff JOHN E. DELLINGER, H Defendant 03-1208 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT C -?j -)e1leA)e0l?z 1W AND NOW, this 2a day of 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The parties shall proceed with the custody evaluation in accordance with the prior Order of this Court dated July 10, 2006, with the Father contacting Kasey Shienvold's office promptly to schedule his first appointment. 2. Pending further Order of Court or agreement of the parties, the parties shajl share having physical custody on alternating weeks with the exchange of custody to take place ev6ry Sunday morning at 10:00 a.m. 3. The parent who has custody of the Child under the alternating weekly schedule shall contact the other parent on Sunday at 5:00 p.m. to discuss issues pertaining to the Child only and exchange information pertaining to the Child. 4. The Father shall be entitled to contact the Child at any time during the Mother's period of custody on the Child's cell phone, the number for which shall be provided by the Mother. The Mother shall be entitled to contact the Child during the Father's periods of custody at reasonable times and, in addition, the Father shall ensure that the Child contacts the Mother by telephone on Wednesdays at 5:00 p.m. during the Father's periods of custody. 5. The parties shall have custody of the Child over the Christmas holiday in 2006 with the Mother having custody from Christmas Eve at 9:00 a.m. through Christmas Day at 12:00 noon, and the Father having custody from Christmas Day at 12:00 noon through December 26 at 12:00 noon. 6. The Father shall make the Child available to be with the Mother around the time of the anticipated birth of the Mother's child in the Spring of 2007. 7. Within 60 days of receipt of the evaluator's written custody recommendations, counsel for either party or a party pro se may contact the conciliator to schedule an additional custody conciliation conference, if necessary. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EXHIBIT A 8. The parties shall cooperate with each other in establishing sufficient communication and cooperation to enable them to effectively co-parent their Child. 9. 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, Kevin . Hess J. cc: Jill Haminill and Lucy Johnston-Walsh, Esquire - Counsel for Mother John E. Dellinger, lI - Father - ^RD 77-11 hand F'iLED- TILE OF THE PROTHONOTARY 2069 APR -3 AM 10: 13 ?vtildk? _ r'.; L1i? f f ?'??"i??tiJ???.l??+l girt ? 4 1 6 7? KERI A. HARVEY IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2003-1208 CIVIL ACTION LAW JOHN E. DELLINGER, II IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, April 08, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, May 07, 2009 at 1:30 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 be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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 THE COURT, By: /s/ Dawn S. Sunday, Es T. 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 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 FILED--L-l- FICE THE 2009 APR --8 PM 3: 16 'ry MAY 0 8 2009 ti KERI A. HARVEY vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff 2003-1208 CIVIL ACTION LAW JOHN E. DELLINGER, II Defendant IN CUSTODY ORDER OF COURT AND NOW, this 12 ` day of V%1 , 2009, upon consideration of the attached Custody Conciliation Report, i is ordered and directed as follows: 1. The prior Order of this Court dated December 20, 2006 shall continue in effect as modified by this Order. 2. The exchange time for the alternating weekly periods of custody shall be changed to Sunday at 12:00 noon. 3. The Mother shall have a period of custody with the Child on the Child's birthday, May 22, 2009 from Friday after school until between 9:00 and 10:00 p.m. 4. The Mother shall have custody of the Child for Mother's Day on May 10, 2009, for which the Mother shall pick up the Child at 9:30 a.m. 5. The regular custody schedule shall be adjusted as follows to accommodate the Mother's scheduled vacation in 2009: The Mother shall have custody of the Child from June 28 through July 2 in the morning and the Father shall have custody from July 2 in the morning through July 9, when the Mother shall pick up the Child in the morning. 6. The Father shall take the Child to Karate lessons at the Hampden Center during his weeks of custody for at least two (2) out of the three (3) sessions each week. 7. The parties agree that the Child shall continue in her current school and the Father shall provide assistance with transportation of the Child to school during the Mother's weeks as arranged by agreement between the parties. 8. The Father shall be entitled to claim the Child for tax purposes in even-numbered years and the Mother shall be entitled to claim the Child for tax purposes in odd-numbered years. 9. 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, Z4 - Kevin A./Hess J. cc: mas D. Gould, Esquire - Counsel for Mother n E. Dellinger, II - Father J 'C0 f I ies ms,f?(. s/1z/6r tzv) c? ?,'?? :? ? ? .. ...} R. .. ?+r?r' ? ? 'r t1 .?. ?.? ?._ `'1? ? .. 3?? 4 .: qTr? r?. i ?I?.++gaa 1. ^ Y. , N 1'?t l t - _'111 1 ? r' 1 ? ? {?y... 33 ?Ya rr lf- ? ?/ © G' KERI A. HARVEY IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. JOHN E. DELLINGER, II Defendant Prior Judge: Kevin A. Hess 2003-1208 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 concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Maraja Sky Dellinger May 22, 2002 Mother/Father 2. A custody conciliation conference was held on May 7, 2009, with the following individuals in attendance: the Mother, Keri A. Harvey, with her counsel, Thomas D. Gould, Esquire, and the Father, John E. Dellinger, who is not represented by counsel and participated in the conference by telephone. 3. The parties agreed to entry of an Order in the form as attached. _ '71uy Date Dawn S. Sunday, Esquire Custody Conciliator IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA KERI A. HARVEY, Civil Action At Law-Custod? N CJ l..l C? i l Plaintiff/ Petitioner, Case No. 03-1208 VS. r - JOHN E. DELLINGER, II, Defendant/Respondent - -? PETITION TO MODIFY CHILD CUSTODY ORDER 1. Petitioner, is Keri A. Harvey, who currently resides at 3 East Main St. Shirmanstown, PA. 17011 in the County of Cumberland, Commonwealth of Pennsylvania. 2. Respondent is John E. Dellinger, II, who currently resides at 727 North 2nd St. Steelton, PA. 17025 in the County of Dauphin, Commonwealth of Pennsylvania. 3. On the 8`" day of September 2006 a Court Order for custody was entered which granted Joint Physical Custody of the child, Maraja S. Dellinger, to each parent respectively. 4. The Court Order granted Shared Legal Custody as between the parties. 5. Since the entry of said Order, there has been a significant change in circumstances for the following reasons as hereinafter outlined. P10-00 Pr) Arr/ No* «-o'tga12916 0,139&170 (a) Respondent, father has neglected to exercise his periods of custody with the child for the last five months. (b) Respondent, father, has had no physical, telephonic, or written communications with the child pursuant to the Order of Court allowing him Joint periods of custody. (c) Respondent has had a transient lifestyle, moving frequently from residence to residence coupled with financial instability which has been both the cause and the effect of his frequent relocations. (d) Respondent father has caused psychological trauma to the child in that he has made several promises to exercise his custodial periods and has on numerous occasions failed to exercise those promised visits with the child. (e) The child has been emotionally upset and disturbed by her father's failure to fulfill his stated intentions to visit the child and share periods of custody with her as promised. The child will continue to suffer psychological harm if the father is permitted to sporadically and inconsistently make representations to the child and mother that he will exercise his periods of custody and default relative to the same. (f) The petitioner mother has been and continues to be the primary caretaker and caregiver to the child since the inception of the Court Order and continues to provide for the child's emotional, physical, and financial welfare. 5. The best interest of the child will be served by the Court in modifying said Order for the aforementioned reasons and granting to mother, Keri A. Harvey, Primary Physical Custody of the child. WHEREFORE, Petitioner prays this Court to allow the modification of the Custody Order to grant Primary Physical Custody of the child to Petitioner, Mother for the reasons as cited herein. Respectfully submitted, VERIFICATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. 4904 relating to unsworn falsification to authorities. Date 1 d Ke ' A. Harvey, Petitioner Mechanicsburg, PA. 17055 Phone: 717-790-5500 KERI A. HARVEY IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JOHN E. DELLINGER, II DEFENDANT 2003-1208 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, i Wednesday, April 07, 2010 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at_____ 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, May 06, 2010 at 12:00 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 be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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 THE COURT. By: /s/ Dawn S. Sunda Es . 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 hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DQ NC>' HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICI?',SETz "n FORTII BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, x?„ x*- r s M ??•``? Cumberland County Bar Association 4.8'•!O CIA cry 32 South Bedford Street °o «r Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 y • $'• 10 /VOii « nW4 ke? ,c-c cr, -c St?rtc? f • $• !O CQyt? tea.; led 4P