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JOHN B. TAYLOR, JR.
Plaintiff
VB.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. C]p - "/11<';1/ C..,I k,n.\
CIVIL ACTION - AT LAW
CUSTODY
~I RONDA TAYLOR,
Defendant
COMPLAINT FOR CUSTODY
The Plaintiff, JOHN B. TAYLOR, JR., through his attorneys, The
Law Offices of Patrick F. Lauer, Jr., files this Complaint for
Custody against the Defendant, RONDA TAYLOR, and in support
thereof, avers the following:
l. The Plaintiff is JOHN B. TAYLOR, JR., an adult individual
and the natural Father, who currently resides at 808 pine Road,
Carlisle, Cumberland County, Pennsylvania l70l3.
2. The Defendant is RONDA TAYLOR I an adult individual and
the natural Mother, who currently resides at 808 pine Road,
Carlisle, Cumberland County, Pennsylvania l70l3.
3. The Plaintiff seeks custody, partial custody I andlor
visitation of the following child:
Name
Present Address
Aqe
Amanda N. Taylor
808 pine Road
Carlisle, PA l70l3
6
The child was not born out of wedlock.
4. The child is presently in the custody of JOHN B. TAYLOR I
who currently resides at 808 pine Road, Carlisle, Pennsylvania
170l3.
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5. During the past five years, the child resided with the
i following persons and at the following addresses:
Name
John B. Taylor, Jr.
and Rhonda Taylor
John B. Taylor, Jr.
and Rhonda Taylor
Address
Dates
808 pine Road
Carlisle, PA l70l3
8/95 - present
35 Buttonwood Lane
Carlisle, PA l70l3
Birth - 8/95
6. The Mother of the child is RONDA TAYLOR I who currently
resides at 808 pine Road, Carlisle, Cumberland County, Pennsylvania
l70l3, with the subject of this petition. The Mother is married to
the natural Father.
7. The Father of the child is JOHN B. TAYLOR I JR., who
currently resides at 808 pine Road, Carlisle, Cumberland County,
Pennsylvania l70l3. The Father is married to the natural Mother.
8. The Plaintiff has not participated as a party or witness,
or in another capacity I in other litigation concerning the custody
of the child in this or another court.
9. The Plaintiff has no information of a custody proceeding
concerning the child currently pending in any court of this
Commonwealth.
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WHEREFORE, the Plaintiff respectfully requests that this
Honorable Court enter an Order granting primary custody, partial
custody I or visitation of the child to the Petitioner and natural
Father, JOHN B. TAYLOR, JR, in accordance with any Stipulation of
the parties I or in the event the parties are unable to execute such
a Stipulation, to enter an Order granting custody, partial custody,
or visitation of the child to the Petitioner.
Respectf
[
o
D.'., ~.~
Mattliew shelman, Esquire
Law Offices of Patrick F. Lauer, Jr.
2l0B Market Street, Aztec Building
Camp Hill, Pennsylvania l70ll-4706
ID# 72655 Tel. (7l7) 763-lBOO
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1)
, JOHN B. TAYLOR I JR. I
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY I PENNSYLVANIA
vs.
No.
RONDA TAYLOR,
Defendant
CIVIL ACTION - AT LAW
CUSTODY
VERIFICATION
I, JOHN B. TAYLOR, JR., state that I am the Plaintiff in the
above-captioned case and that the facts set forth in the above
Complaint for Custody are true and correct to the best of my
knowledge, information I and belief.
I realize that false
statements herein are subject to the penalties for unsworn
falsification to authorities under le Pat C.S. S 4940.
Jr.
Date: 7/-?//,/'8"
JOliN B. TAYLOR, JR.,
Plaintiff
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 98-4494 CIVIL TERM
CIVIL ACTION - LAW
RONDA TAYLOR,
Defendant
IN CUSWDY
CRDER OF 0XlRT
1IND Na-/, this j>
consideration of the attached
and directed as follows:
day of ;;..., ~ , 1998, upon
Custody Conciiiation Report, it is ordered
1. The Father, John B. Taylor, Jr., and the Mother, Ronda Taylor,
shall have shared legal custody of Amanda N. Taylor, born September 11,
1991. Each parent shall have an equal right, to be exercised jointly with
the other parent, to make all majot" non-emergency decisions affecting the
Child's general well-being including, but not limited to, all decisions
regarding her health, education and religion.
2. The Mother shall have primary physical custody of the Child.
3. The Father shall have partial physical custody of the Child on
alternating weekends beginning September 11, 1998 from Friday when the
Fathet" shall pick up the Child aftet" school or at the childcare providet",
until Sunday at 7:30 p.m. In addition, the Father shall have custody of
the Child every Monday and Thursday from the afternoon when the Father
shall pick up the Child after school or at the childcare provider until
7:30 p.m. that evening.
4. The parties shall share or alternate having custody of the Child
on holidays as follows:
A. Christmas: In even numbered years, the Father shall have
custody of the Child from Christmas Eve at 8:00 a.m. until
Christmas Day at 11:00 a.m. and the Mother shall have custody
of the Child on Christmas Day from 11:00 a.m. until 7:30 p.m.
In odd numbered years, the Father shall have custody of the
Child on Christmas Eve from 8:00 a.m. until 11:00 p.m. and
the Mother shall have custody from Christmas Eve at 11:00
p.m. until Christmas Day at 7:30 p.m.
B. Thanksgiving: In even numbered years, the Mother shall have
custody of the Child from after school on the Wednesday
before Thanksgiving until the following Friday at 8:00 a.m.
and the Father shall have custody on the Friday after
Thanksgiving from 8:00 a.m. until 7:30 p.m. In odd numbered
years, the Father shall have custody of the Child from after
school on the Wednesday before Thanksgiving until the
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following FridilY at 8:00 a.m. and the Mother shall have
custody on the Friday after Thanksgiving from 8:00 a.m. until
7:30 p.m.
C. Alternating holidays: 'l'he parties shall alternate having
custody of the Child on the following holidays from 8:00 a.m.
until 7:30 p.m. beginning with the Father having custody on
New Years Day in 1999: New Years Day, Easter, Memorial DaYI
July 4th, and Labor Day.
D. Mother's Day/Father's Day: The Mother shall have custody of
the Child every year on Mother's Day from 8:00 a.m. until
7:30 p.m. and the Father shall have custody of the Child
every year on Father's Day from 8:00 a.m. until 7:30 p.m.
E. The holiday custody schedule shall supersede and take
precedence over the regular custody schedule.
5. The Father shall be entitled to have custody of the Child for
three non-consecutive weeks during each year upon providing thirty days
advance notice to the Mother. The Father ll'8y schedule these extended
periods of custody over the Child's school year breaks only as agreed
between the parties. If the Father elects to schedule a period of custody
under this provision during the school year when the Child has school, the
Child shall be returned to the Mother's custody for overnight periods.
The Mother shall be entitled to have custody of the Child
for two non-consecutive weeks each year during the Child's sumner school
vacation upon providing thirty days advance notice to the Father.
6. The party receiving custody of the Child shall be responsible to
provide transportation for all exchanges of custody under this Order.
7. This Order is entered pursuant to an agreement of the parties at a
CUstody Conciliation Conference. The parties may modify the provisions of
this Order by mutual consent. In the absence of mutual consent, the terms
of this Order shall control.
BY THE COURT,
, AIL
J.
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cc:
Matthew J. Eshelll'8n, Esquire - Counse for Father
Johnna J. Deily, Esquire - Counsel for Mother
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: CIVIL ACTION LAW
; NOJ~lW-\ CIVIL 19 1'C)
: CUSTODY VISIT AnON
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Plaintiff
: IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
: PENNSYLVANIA
. \:to<6(). \0,\\0\
Defendant
ORDER OF COURT
And now, this Oil >-.\'1Q ,upon consideration of the attached complaint, it is her~y dire~ted
that the above parties and th~ir respective counsel appear before (Y).,.. 111 S. ,~(l'-...I ,
Esquire, the conciliator, at .:,>'Cf \, ), \.A,(\\",:-'\-, ,~(~r\'-\r",\( ",\AXo.. \,
Pennsylvania, on the",\:) day of \.. \~\"("\\-~\:' r , 1999, at \-V'. no @.IP.M"
for a Pre-hearing Custody Conference, At such conference, an effort will be made to resolve the
issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard
by the court, and to enter into a temporary order, All children age five or older may be present at
the conference, Failure to appear at the conference may provide grounds for the entry of a
temporary or permanent order.
FOR THE COURT:
By: ~~)\\. z\ >~~f\\~ )~ '
Custody Conciliator "'-
(I'S),)
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
THE ClJtv1BERLAND COUNTY BAR ASSOCIATION
2 LmERTY AVENUE
CARLISLE,pA 17013
(717) 249-3166
1-800-990-9108
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JOHN B. TAYLOR, JR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
vs. . No. 1998 - 4494 CIVIL TERM
.
.
.
RONDA TAYLOR I CIVIL ACTION - LAW - CUSTODY
Defendant PREVIOUSLY ASSIGNED TO: J. HESS
NOTICE AND ORDER TO APPEAR
Legal proceedings have been brought against you alleging you
have wilfully disobeyed an Order of Court for custody, partial
custody or visitation.
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 you 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 the
day of 1999, at o'clock _m., in
Courtroom No. of the Cumberland County Courthouse, One
Courthouse Square I Carlisle I Pennsylvania l70l3.
IF YOU DO NOT APPEAR IN PERSON, THE COURT MAY ISSUE A WARRANT
FOR YOUR ARREST.
If the Court finds that you have wilfully failed to comply
with its Order for custody, partial custody or visitation I you may
be found to be in contempt of court and committed to jail, fined or
both.
YOU SHOULD TAKE THIS PAPER TO YOUR LA\'1YER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE I GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
BY THE COURT:
DATE:
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE, PA l7013
(717) 249-3l66
JOHN B. TAYLOR, JR'I
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 1998 - 4494 CIVIL TERM
RONDA TAYLOR,
Defendant
CIVIL ACTION - LAW - CUSTODY
PREVIOUSLY ASSIGNED TO: J. HESS
PETITION FOR MODIFICATION OF A PARTIAL
CUSTODY OR VISITATION ORDER AND FOR FINDING OF CIVIL CONTEMPT
The Petitioner, John B. Taylor, Jr., through his attorneys,
The Law Offices of Patrick F. Lauer, Jr., files this Petition for
Modification of a Partial Custody or Visitation Order and for
Finding of Civil Contempt for disobedience of a custody order,
against the Respondent, Ronda M. Taylor, and in support thereof,
avers the following:
l. The petition of John B. Taylor, Jr., respectfully
represents that on September 8, 1998, an Order of Court was entered
for Partial Custody, a true and correct copy of which is attached.
2. The Respondent has wilfully failed to abide by the Order
in that:
a. The Respondent refuses to permit weekday visitation as
provided by paragraph 3 of the Order, and additionally
refuses to permit similar, makeup weekday visitation.
b. The Respondent refuses to provide her share of the
transportation responsibilities as provided by paragraph
6 of the Order.
c. The Respondent has directed the child's school to
prohibit Father's presence on school property, attempting
to prevent him from picking up the child I in violation of
paragraphs land 3 of the Order.
'~
3. This Order should be modified because:
a. The Respondent brought the child I age 7, to a
bachelorette party attended by a male stripper;
b. The Respondent has repeatedly engaged in, and exposed the
child to, the excessive consumption of alcohol; and
c. The Respondent has engaged in, and permitted others to
promote I disparaging remarks against the Father in the
presence of the child and conduct promoting the
deliberate alienation of the child's affection toward the
Father.
WHEREFORE, Petitioner requests that the Court (l) adjudge the
Respondent I Ronda M. Taylor, to be in contempt of this Court and
(2) modify the existing Order for Partial Custody to include
language restricting the use of alcohol, and prohibiting
disparaging remarks and conduct, in the presence of the child
because it will be in the best interest of the child.
ly
Date:
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Matthew J. Es lman, Esquire
2108 Market St eet, Aztec Building
Camp Hill, Pen sylvania l70ll-4706
10# 46430 Tel. (7l7) 763-l800
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JOHN B. TAYLOR, JR.,
Plaintiff
.
.
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 1998 - 4494 CIVIL TERM
CIVIL ACTION - LAW - CUSTODY
PREVIOUSLY ASSIGNED TO: J. HESS
vs.
RONDA TAYLOR,
Defendant
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 l8 Pa. C.S. S 4904, relating to unsworn
falsification to authorities.
Date: -LO///f7
Signature:
Jr.
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JOliN fl. TMLOR,
IN 'I'IIE COUR'I' 0/0' CDr>lMON P[,"",S 01"
CUMBEIlLNJD COUNTY, PENNSYLVANIA
pl,lintiff
va.
NO. 98-4494
CIVIL ~'ERM
RONDA TAYLOIl,
CIVIL A~I'ION - LAW
IN CUSTODY
Defendant
ORDER OF <XlURT
AND NCTi/, this I "J. day of :T1/rI1J I'r7'- ~
upon consider-ation of the attached Custody Conciliation Report,
or-der-ed and dir-ected as follows:
, 2000,
it is
1. The prior Order- of this Cour-t dated September- 8, 1998 shall
continue in effect as modified by this Order-.
2. The Father shall have partial physical custody of the Child on
alter-nating weekends fr-om Friday when the Father shall pick up the Child
after- school or- at the child care provider, until Sunday at 7:30 p.m. In
addition, the Father- shall have custody of the Child ever-y Wednesday from
after- school until 7:30 p.m. During weeks following the Mother's weekend
periods of custody the Father- shall have custody of the Child on Monday
fr-om after- school until 7:30 p.m. and dudng weeks following the Father-'s
weekend pedods of custody the Father- shall have custody of the Child on
Thursday fr-om after school until 7:30 p.m.
3. Dur-ing the school year-, the Father- shall have custody of the Child
on any weekday the Child has off fr-om school and the Mother- is working. If
the Child has a day off school under this par-agr-aph on a Monday immediately
fOllowing the Father's regular weekend per-iod of custody, the Father- shall
r-etain custody of the Child continuously until Monday at 5:00 p.m. In the
event the Child has off school on a Monday which follows the ~lother' s
r-egular weekend period of custody, the Father- shall have custody of the
Child from 8:00 a.m. until 7:30 p.m. In the event the Child has off school
on a day other than Monday when the Father- would not r-egulady have
custody, the pedod of custody shall run fr-om 8:00 a.m. until 5:00 p.m.,
unless otherwise agreed between the par-ties. The Father- shall have custody
of the Child under this pr-ovision if the Child is ill and the Mother- is
wor-king.
4. The Chr-istmas holiday shall be divided into Segment A, which shall
r-un from Chdstmas Eve at 1:30 p.m. thr-ough Chdstmas Day at 1:30 p.m., and
Segment 8, which shall run fr-om Chr-istmas Day at 1:30 p.m. thr-ough December-
26 atl:30 p.m. The Father- shall have custody of the Child during Segment
A in even numbered years and during Segment B in odd numbered years. The
Mother- shall have custody of the Child dudng Segment A in odd number-ed
year-s and during Segment B in even number-ed years.
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IN 'I'IlE COUR'I' OF WIMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
JOliN B. 'I'AYLOR,
vs.
NO. 98-4494
CIVIL 'I'ERM
Defendant
CIVIL ACTION - LAl'i
IN CUSTODY
RONDA TAYLOR,
PRIOR JUDGE: Kevin A. Hess
CUSTODY COOCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
19l5.3-8, 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
CllRRENrLY IN CUSTODY OF
Amanda N. Taylor
September 11, 1991
Mother
2. A Conciliation Conference was held on January ll, 2000, with the
following individuals in attendance: The Father, John B. Taylor, with his
counsel, Matthew Eshelman, Esquire, and the Mother, Ronda Taylor, with her
counsel, Johnna J. Deily, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
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DaCe I'
aLA~d/J'
Dawn S. Sunday, Esquire jr
Custody Conciliator