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HomeMy WebLinkAbout98-05101PIRRY It, HUDSON, #?inintiff V1 RBIMCCA 14, O'hONNIII-L, ' uPfendant 19l p .1199110 I IN 99111 COURT All COMMON MAW OF I CUMIIPRI.AN13 COUNTY, PIINNNYWANIA 1 I CIVI1. AC'T'ION - I7,AW t IN CUS'T'ODY I 1 NO, 94^ ?CIVII.'I'llitM oluli l ltl AND NOW, Oita Oily of , 1998, upon conal0milon of the attached colilplalnt, it Is hereby dlroctod glut IllP parties and their rospeotivo'counsol appear before, \ll,. 11`4\ l l` ?'" t ClII11hPr1nllt) CPNI1ty CPtlrthtlllHP, 1\-1x,r \ X, try \ I';Ity the OPIIeIAnIPr, to Oil the , I clay of 1998, at lo, M lm, I for A Pro•1-Icorlns Cuslody Conforonco, At stloh eollferonco, ml effort will be Made to re4Plvo the lamps In t114ptltoi of If this oaaaot be acoP111p114114d, to donae and harrow the Isstics to be hoilyd by th0 Wart, and to enter, Into a ' temporary Prcler, 1311hor early may bring the child who Is ale 50joct of 0118 0114tody notloll to the conforoom bill the child's attoildmiee Is act mandatory, Fallara to appear at tile ponforonco may provide gl'otinds for ontry of a temporary or pornlanoot order, Folk TI-I13 CoURT, 13 1 .. 11Utc? ?- ? Cuslody Conciliator (ta, You,.SHOULD TAKU TATS PAPER TO YOUR LAWYER AT ONCR, IF YOU DO NOT HAVE A LAWYHR OR CANNOT AFFORD ON131 00 TO OR TP.L13PIi0Nh TI.113 oFFICI3 SI;T PoRTIi 11131.OW TO FIND OUT WiiRit13 YOU CAN .013'I' L"GAL"i'LP, Cumberland County Bar Amoclatlon 2 Liberty Avenuo Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH UISABILITIMS ACT OF 1990 'I'Tlo.Coll rt'of Common Plons of Cumberland-County is rcqulrcd by law to comply with the Americans with Disabilities Act of 1990, For hiformation about acc0sible facilities mid reasonable accommodations available to disabled Indivlchlals having business before the court, please contact our offieo, All arrangemonts must be Bade at least 72 hours prlor,to nay hearing or business before the court,. You must attend illo scheduled conference or h4aring, ..c 1 ail IllllltY' Ii, FIPPSON, I IN 11111 COURT OP COMMON 1'I•i)AS pN t CUM111110,ANl3 COUNTY, I IINNNY14YANIA Plaintiff t v1 t CIVIL ACTION . LAW t IN CUS'I'OPY; j 1 RUMICCA-L, 01PONNI?I.1., t No, JA- CIVIT4 `l'I;RM laofpndant !. , . I 010*4 OIL COUIt'P You, Robocou I 0'001111011, ilpfondtmt, have bean Nnacl to court to obinln partial (AMO ly of tho ehlldrom Ashley Rae 1-hldson You are ordered to appear In parson at , on r at ---- -.4111, for a co ieillation or mediation conference, a pretrial conferenco, it 1lcaring l eforo tho court, if you fall to appear its provided by this order, an order for custody, partial custody or visilallon may be entered n811111st you or the court may Issue it warrant for your arrest, YOU SHOULD TAKE THIS PAPLIt TO YOUR LAWY131t AT ONCE, II? YOU 00 NOT HAVE A LAWYER Oil CANNOT AFFORD ONE, QO TO Oil T111.13PHONt3 THROPPICI3 SET POR'1'1-i I3PI.OW 'r0 FIND OUT WIi131113 YOU CAN QET LEGAL HELP, Cumberland County Bar Associatlon 2 Liberty Avonuo Carlisle, Pennsylvania 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OIL 1990 Tbo Court of Common pleas of Cumberland County Is required by law to comply with the Americans with Disabilities Act of 19904 For Information about uecessible,fnellitles and reasonable accommodations availnble to disabled individuals having business before ilia court, please contact our office, All arrangements must be made tit least 72 hoofs prior to any hearing or business before the court, You must attend the scheduled conference or hearing. JPRitY it, 1iUDSON, t IN 11'111: COURT OF COMMON PPIAS 017 Plaintiff . i CUM111110,01.) COUNTY,Ial1NNSYLVANIA t, V, i Civil. ACTION - LAW i IN CUSTODY R1:i1UCCA Ia, O'DONNiIi.l., , ; Pufendant t NO, 98- 00 Civil, IrvlltM COMPLAINT FOR PARTIAL CU TOPV I The ploinlIff, Jerry It, Fludson', Uy his oltornoys, the Family LAW Cihhie, sell ferlh the following Canso of 40110111 1 Tho plaintiff is Jerry It, Hudson, reslding at 19 Faith Clrelo, Carllslc, Cumborland county, Pennsylvania 17013, The defendant is RoWcon L, o'Donnoll, residing at 619 North West Street Carlisle, Cumberland County, Pennsylvania 17013, 3 Plaintiff sookS auslody of the following cllildl . )_`i111114 Presolt Residence Lat.4_S!f 1111111 Ashley Rae Hudson 619 North West St, 12IOg/96 Carlisle, PA 17013 The,ehild Is presently in the custody of Robcccn L, O'Donnell, During the past Ave years, the child has resided with tho following persons and at lllo following addresses; 1'tuwlu>? Atltl!•exsr? l?tttcs ?toheAAg Q'Uoniteil, 019 North West St, 12/o8196 -4/911 11PronAo Flakier, Carlisle, IIA 171113 Sandy Moller,.Alilson O'OPnnPli, ttratilor of 141=04 aPonllell Itobecon 01PPI1001 gild Florence 019 N, West 5t 7xlslier Carlisle, NA 17015 4/98- present 4, The relationship of the defendant to 1110 child Is 111n1 PC Mother, She Is s111010, She pilrroolly'rosidos with the followhig personsi l?nuul IielnWulsltip hloreape Plaher Qrandmolhor S, The relationship of plaintiff to the child Is that of father, Ho Is single, lie oarrpillly resides with the Following parsons) lYunitt li>sUllkuutWu May I„ Hudson Mother 6, Plnlatlff lips not participated as tt party or wllnoss, or In another capacity, In other litigation concornIng Iho custody of the clilld In this or another court, Plaintiff lips no Information of a custody proceeding concerning the child pending In it court of this Compicaiweallll, Plahlllff does not know of it person not it party to IN proceedings who lips physical custody of (lie child or claims to have custody or visllallotr rights with rospeet'lo the children, 7. The best interest and pormanent welfare of the child will be served by granting the relief requested beeausAt a) 1'Idlotiff has developed it close and loving relationship with his daughter which will 1. he mirhlrod by a onllslslolll vlsllalloo soilodlllo, 11) laafendanl has made known to Plaintiff 111m she 111MIOs to n{hvp to 1'lorida wllh the child, i ti, Paeh P11re111 Whose P1011110 r181114 ht (Ile Child have ilot Won tormlooml aml the parson who has physiool onsimly of the 011110 1111ye been limned 114 parllas to 111ls 11011011, W1113RIIPO111I, plaintiff rorltlosls the court to grant hlm partial custody of 1110 01111d, Whole M, w hers C lifled Laga n{ ro 'CIIOMA M, I' . CP, ROORIAT 1:, RAINS KA''1•II11t1NIJ C, I'PARSON Nuporylolno Mornay DONALD MARRPCZ Staff Attornoy IIAMIl.Y LAW CLINIC 45 North Pllt Strout Carlislo, PA 17011 717/243.2968 VURIPICATION I vorlfy'that l11e slalemonts made In Oils Complaint are I1'ua and correct, I undorsland that L false statements Itoroln are mode subject to ilia pone ltles (if 18 Pa,C,S, $4904 relating to unsworn j falallloation to nulhorilios, j I i Jgry'1t, Hudson I 11314tY at HOPSON, 1 IN TIM COURT' OF COMMON PLUM 0I7 171nintiff I CUMOMILANO COUNTY, M NNSYLVANIA V, I Civil, ACTION-LAW I IN CUSTODY 1tT;i313CCA L, Q'POMMILL, t „ i I)FPFI1dAl1t I ( 1 NO, 90- s" fir' / civil, TRRM I , ,. ,11t a .nm'ro PROCURD IN ' . 1 211MA PAUPERIS To tile 1317011l1011014ryl Kindly Allow Jerry It, Hudson, Plnhttiff, to prooFed In Comm pnuporls, It NI011ole M. WRltors, of the 174mily I,mw Cllnia, Cortlfic(I I-oglll Intarn for tha party proceeding In forum pauporis, certify that I IwIlove the party Is unablo to pRy the costs mid tlmt I am provi(Ilog free logo) service to the party, 'i'he party's nffidult showing inability to pay 1110, costs of 110811tion Is Altaahed hereto, Whole M, Wttllors i Corlined Logtd Intern - " F ItUlilar I , RAINS VYW THOMAS M. PLACID Sopotvlsing Attorney . i DONALD MARRI'' G Staff Attorney TIM 17AMILY LAW CLINIC. 45'North Pitt Street Carlisle, PA 17013 (717) 243.2968 Untot <l? ,?l ,., End J43Tt10' lip IMPSON, I IN TIM COURTAP COMMON PI.13AS OIL Ithlhlliff I CUMIII3I0,ANla'COUN`I'Y, PUNNSYI,VANIA i I I I V1 I CIVII. ACTION - LAW I i I IN C1-780'110Y ItuIltlCCA I., o?PCNNIILL, t]ofopdagt I No, 98"` OCIVIl"I'liltM r rl vpl sUhr RTI a PRAECIPH FOR LRAVra U ' I D IN FORMA PAUPERM 1, I pill the Pininllff in 1116 above nlpttur gild boomise of lily financial condition Apr tillable to pay the fees and costa of proseeotlnl; or defending tho Action or proeeoding, 2, 101-0 unable to obtain funds from aayono, including my family And aasoolataa, to pay the 90413 of litigation, 9, 1' represent that tho Information below relating to lily ability to pay the fees and costs is true and corrects (n) Wiwi Jorry R, Hudson Addresst 19 Pallh Circle, Carlisle, PA 17013 Social Security Novi 233-19.8556 (b) I illployl11oat If you are prosonlly employed, slate 13111ployori UI'S Addressi 1911i.Slreol, Harrisburg Salary or wages per months $363 (gross minus taxes and wage attachalent for child support) 'T'ypo of works general laborer (e) Other income within the past twelve months Business or profosslow u/a Other self•omploymonti n/n Iltteresti It/a Dlvldendsi n/n Ponsion and annultiesi On Social security beneilts: n/a Support paymentst n/a niNllhllily pllyntanlsi n/a ' UI1RIllpiPy111Qpt PPIllpcllsa{iPil alld NuppIP111P11111I NP114141 $13 awry two weeks if grass idly Is ulldpr $210,00 WPrknlPil1N PPillpailsa{ipm 11/0 NWIP ANsiNIa1lcPl Il/a Othorl n/a (d) Other oontriNlllloitN to llnliNPllold support (Wife)(iillshalld) N11111Pi n/a if your (WIfP)(ImsboII(l) I4,0111p1Pyed, s{ata Ilnlployori n/a Salary or mm or 111PI1{hl Il/a Typo of worki lift ContriN ithm frPrn chil(Irom Wit Contributions from parom.1; helps pity for car IllslirancP gild rPllt Other conlribinlmis1 Il/a (P) Pro??orty pWnad Castli $0 Chookhlg aaoomill $0 Savings accolmil $0 Cortificales of do pasln 11/11 Rcil) a?{ala (Including 110111P)i n/a Motor vohiolPi 96 Honda Accent Cost, Aniolnlt Owed $329/month Slocksi W114I31,)1/a. Other{ 11/0 (Q 9 Pouts aild PhligatlollN " Mortgagoi Il/a, Rontl $35,00 per mond) Loansi oar loan Olhorl Transportation • $15 per wookl Food = $40 per week (g) Persons dopolidellt lipml fvoll for support I. (Wife)(iluNUmtd) Nnntei n/a Children, if anyt spinal Ashley Ray I-Tudson Agol 2 years old Other porsonsi, n/a Namot n/a Itoladanshlpi n/a 41 I understood that I havo a eonlhluing obligation to Inforat the court of Improvement in my financial eirournsiolices which Would permit me to pay the costs incurred heroin, a Plaintiff ONE i UM1 411 1 COUR OF AMD COUNTY, I1 NNSYI.V.INIA I ( I CIVIL ACTION - LAW, I IN, CUSTOPY 1 I?IIIiI3CCA LI O'PANNtILt, i Pal'andant I NO, 95.5101 clVli r19111m C1WTIhICAT14 OF SIMVICR It herahy aortify that I have surved n true and corroot copy of 010 Custody Colnplnint Oil Me= L, O'Donnell, rosiding at 619 North Wast Slroct, Corlislo, PA 17013, by U,S, milli, cot-01104, rastriatad dolivory, relurn reculpt requested, posiago propnid, Service was coniplat0 upon rccolpt by Itebcaea O'honnoll on the 6th clay of Soptem0h0r, 19911 Q8 evidanacd by 1101' signature da 1110 01110 10(1 groan card, (",'AJ lflrp_P_,< N cholo K Walters Z lad 8116 7711 Cortined Legal Intern usPosl 1801000 FAMILY LAW,CLINIC f pt for Certlfled Mall Nn Insunlncn opyornpo 1110010d. 45 N, Pilt St, etl of ueP or In of n to lnl nil Soo roveran Cal•lisle PA 17013 1 I? r{l to ' Tt unol ?1 Plnln tq ? 1' ilA I'' non 9n;., -• '? e oaf-? Fol' 1(1 -- A IAIIY 0 I f61c IpoN 'oo ,, b"- hA 1 )AI 1 n ,Dace pYA, - r! n? pale aaa ' TOTAA pnalnpo A foes 14,1 $ 'A '0slmni olpAlo , 717.243.2968 10om elo I inu 1 An V 91 nr erMnbnA oMce PIBa WI6111U IPtlnIV91119 i Y :Pole Items Aa, and AU.. nlloW[llp eorvipoe (for am spl I ?Your ham And Addloss nil llle r0Y41l0e of 11111 lolm to Illative call 1011111,111,11? PMIrP oo RD ef11 p hAliiclj Il,li lomi In die hold 01 the mWlplacA. AI on tire 1;40 n'lpoce M? IM1Y!yy?tllmdlllolum Ilocd/pf 0700al0d'on Ihl mAllheon WIN Ilia Ail111A 11 1?F1, l`J1 C-Tr!' 1rf¦1'?-,' ?? - M7rN11011mi n0colpl WIII allow to Wlmm ins Oil cla Was llallYared and Ilia data deliYerod, .i1 dtlnsullpoBlmPetarfor too. tllcqo c c ro6Anc of 4P. 11 n o um or 1 C&l.?rj; l? I ?? MCI f 11 V IPUI' ; it (I't' ( 1h, (,l 1, l q Prv co ypa q NBpis?(lqI C l';,If I I` t\ L.IrYt ?p?+11 C h q? e>,prn II (J Wd q nUluln neoef t Inr r411andtii60 bd Poo .011 or onalVoc Up tint Name)_ 11 A(ldr ee (only tragdeat and too is I old) 0 aiglla da d roil To of f e Paml p , noonlpar pq m2ens m•n mra bIT1BB q 9 Utl) Ch p I1339Y It,1II)PNON, I IN TIM COU1t'1' 011 CDMMON I'MiAN Oil plainllff CUM111;ltLANla COUN`1'YtPUNNSYIWANIA I ' V, I CIVIL ACTION - LAW I IN CUS`I'OIaY I 11PRUCCA 1„ R'RONNI'LL, i potent;lt1111 I NO, 98, 5101 Civil, 11139M ClQ1TI ICATH OF $RRVICIu 11 Mob* M, W41lerN, Cerll(led 1.0841 Intern, hureby 0orlify thol I Nerved a Dopy of 111e order for Cnslody ConolliEttion on Mark W, Aiishouse, 13sq„ attorney for 1110 pofon;lant by pl4el4ll the spina in the U,S, mall,, first 01MS, poslago propalcl, on September 21, 1990, oddrossod to Marl; W, Allshouso, 13sq;, Salclis, Shuff 4mi MMlsland, 26, West 1llgh Street, c4rlislo, PA 17013, hatoi 9/21198 Mob* M, WOW$ Codified Legal Intorn , t Z x:aPti mu 7 1?)I) ). , JERRY R. Ill?l?i(aN, ? IN Till" ('t111Ir'I' (W COMMON P1,11A1+ OV Plliinlil'1' I G!t1MIWjfl,ANIa cn11N'I'Y1III'NN8)'I,VANIA I CIYII, ACTION I-A\Y i v; JN (:;11ti rom IWIWICOA la, O'I)ONNBI.d-, laul'undnnl , Nt1,. UH- 5101 civil, 11111W r. , OR1MMR AND NOW, this Z` ally of oclohul', 1998, thu nllnullud Ael'uunlulll In 11Ph1'iivud and unturml 118 till 01,41 of churl, Illy 11,111414 COVR . r It J111t1W l1, 11111)40N, I IN 'I'1113 COURTAlt COMMON PIXAS AP ir1n11141ff t CUMMIRLANIa Cf11-JN'1'Y,I'I3NNSYi,VAN1A I y CIVil, AC'T'ION - I.AW I IN CUSTODY I R1311'11CCA I., O'hONNfl1.I., t Defendant I NO, 98- 5101 CIVIL'I'I3RM M`_1:ODY AGREG,ly IM THIS AAIi1RYIEN't't 111ado this „a„ Lciay of Oclober, 19911, botweon Plaintiff, Jerry i1r lipdson (Patter), represented hy_ the Primily I,tlw C111110, and laofontla lt, Rehecca I., O'Donnoil (Mo0lor), roprosonled by Mark W, Allshauso, 13sq, of Santis, Shnff and Maslgnd, concerns the onslotly of lholr minor chlld Ashloy line Iludsoll, horn laccomtior H, 1996, Father and tvtothor desire to enter 111to an agreantont as to 1110 etislody of the minor 011114 and to have thla oRtcomont mudo an Order of Courl, supersoding aR prior orders, Motilor gild Patilor agree to tho followinat ' 11 UuttLQutnsly. The parties shall have shared legal vnstody of Ashloy Rap Hudson, 2, L>11y 1> ttLlitl thtttl3 Mother shall have primary physical oustody of Ashloy Rao Hudson, Pitt hor shall have parUtl custody ovary weekend front 12100 pa, Wordily until 60 poll, Sunday, except on holidays, as Indicated' below, 3 Ball l Fohaduta; Father shall hnvo partial oustody ovary Raster, Thanksgiving and Christmas Day front 3100 poll, ualil SO p,m, Whon the holiday Is on it Saturday,.Pnther's weekend custody slihll begin tit 3,00 p,m; Whon the holiday -Is oil Sunday, Mother shnll,plok tho mhtor child tip on Saturday evening tit a tittle mutually ngrecablo to both parllea, Rather shall than pick the child tip tit 3100 Imil, on Sunday, for his holiday visitation, h, JjUht. Father shall have partial custody on Ashloy's birthday ill it tale . mutually agreed upon by the partiav. Mulltar!a.may, Mohler Nhnll have the minor pimo on Mother'N Ply Ntorlins III 10100 11,111, h, TrnllauuUoliulh Trnnsporlatlon Nholl 110 provided by (lip porNnl raa0lvlna auNlody, 7, Uver luUl..Y.laltat In IN even( Ihpt either porly 8honlll hllto 1110 minor ahlld for till ovornlghl vialt to 11 p11100 other than I?ls or her home, {lint pnrly Nholl provido Iho other parent with u lelopholia mini0or whore IN ohlld vim he ranalt0d, H, .l'nlullltwlu minim(, RIM) pllronl 0101 havo tho r1oht to ronsonnhlo telepllotla aonhlot with 1110 minor ollild, while the ehlld Is In the eumoily of the atllar party, 9, bounuclu. Plah paront Nhall promptly notify the other party of Ally anlorgonay Involvlns,tho health, safoly or woifnro of tho OWN, IQ, The parlleN Intend to he IogAlly botllld by 1110 lor111N of 11118 Ilgroolllont illld ngreo that It Nllall by mado Iot Or(lor of Coort, orry I; udson RoheQ L, 01 Donnell PIAIAIiff Uormllant J 133 Allsl ou 0 irk W NI halo M, Walters , , , Cortlfled Legol Inlorll S IUIS,SI11.1h13 MASI. ND 6 West Itigll Street lorllslo, PA 17013 717) 243-r6222 1'110 AS M. I LAC?M ROBERT R, RAINS Supervlsing Attorney DONALD MARRITZ Staff Attorney FAMILY LAW CLINIC 45 North lilt Street Carlisle, PA 17013 (717) 243-2968 ¦ i r 1 ? ' ,. '?? r p III, ,1 r I U ir' .. C'j r t'?11.1 11? .. I .r. v r, . tlp•I' r. ? 1;11111 .`? dl?ItKYIt1IIIJI)NON, i IN'I'III1,cotlt'l'ol-TOMMON111,M8OI ' plninilil'' :'•t'l1Mlil?ItI.ANltc?flllN'I'Y,hI?NNNYI,VANIA RI1111ccA I,; O'PONNI0,I,, NR O 5101 clVll, ' I ?a01un(Iant 1 IN 0IMT DY coult'j, Qlippjlr AND NOW, thlo (Illy of, 00411101, 1999,1110 Gm0111t,tor hola(I adVI400 that IN pill-110H hllVO rua0hucl un at?r00nt0nt, thu cnaulllator r011agaiah0e JillimIkilloa , liah0rt X, Cllll'nyy, " ,' Gtletculy C'•c?aullhitol, 11 1 JRRRY 13,1•I1.1136oN, IN TI-IR COURT of COMMON PI-RA$ OF PI-AINTIFF CUMPPRI-AND COUNTY, PPNN$YI-VANIA , V. RRPRCCA I-, 011PoNNRI-1_, DRFRNDANT 00.6101 GIVll- TRRM AND NOW, thla Ito day of January, 2000, this matter having been oalled On a petition of Jerry R, Hudson seeking spepial relief, and Llpon agreement of the partles, the patillon to resolved with the following ardor; (1) No party Inoluding Ryan Ward shall drink to the point of intoxioatlon while In the presence of Ashloy Rao Hudson, (2) The merits of the otlstody complaint are forwarded to oonolllatlon, py the Court, f , rdgar'p, p I t" -- James K, ,!ones, GsqulrQ For Plaintiff -a G - d D Peter J, Rosso, Rsquire For Plaintiff Court Administrator 18aa 11 , , 14111V OMPu 111' ?f 111IIIIPN K,'1111108, VIN(Illive JAN 10 2000 7 I1-Y1110 1lalY CNrilalu, P,A 1701)•11119 (717) 240.02911 " : + b k , 'l Sp ` Sr?t .. ?1 ,S?f "rte ++{ '' 1 X1,5 ?1{1 , „ , ti, d , II?IaltY h, I'IUIytinN, IN'I'Ili' COUR'1 (V 101Y1MON NIXAS OF I'lliinlil'I' UUMIIVKI-ANI) CMJN'I'Y, I'I?NNNYI-VANIA Vs. t No, IM-5101 CIVII.'I'I?ItM 10011 cCA I.. rrlx)NNI;L,I,, I CIVII- A(1'ION--I,AW 1)ofunchllll (I ISTOI)Y OM Ali AND NOW, 11118 j d_ (Illy of Jillmilry, 2000 Illmll uons111urulinn of IN wIlhlll 11411oII (01. Sl)uulul R0110 tl 11onrlnl3 In IN Inpitur IB schullulo(1 Ibr IN _.•'rG (Illy of JAnnllry, 2000.111 Y-.'?_ +_,m, in ('(,urirnnm _ 1._. nl'thu clnllburlnn(I County Courth iuyu, BY 'f 111? C`OU R'I', jcletu'li.Ilpyluy,.I, ?_--------•--_--___._ 111111uµ K, Jollua, I?egt11113 Attornoy Im hlointil'1' 7 Irvlno Role Oe Carlisic, I'A 17013 IZuhoucill., O'Donnell 1)ululldnnl ?,v , 315 hI1111e1• 51 r'rN? l1C2L,tuL /./[ ?t Cnrlisio, VA 17011 / `? II?ItItY It, IitJDHON, IN'I'III? c 00010'1' Itl, t.xlrgtgnN I'I.I-Ati Itl' I'lalnllfl' nwil11',10 ANI) COUNTY, I'I?NNISYINANIA va, I NOM 5101 M1v11,'I'I?Illy) 1 10?111?MCA k O!PQNNI,I,1,, CIVII, ACTION--1 AW l lulundan( ('1! ~'1'0 01)1' 1'.L''1'I'I'IUN_li.talt Slllil'IAL Rl"11131'_ I, I'?lllinnur ly I'111111111'I' In lhv tlhnvu uupllnnud nlnllur, - 2, Itu»pundunt I» Pul'undanl In Ihu ahnl'u caplinn0d innuun , nwna'Ihu rOHMunuO, 1,. 1turlpundunl (11'0.4 ht n reHldunuu with 1101' buyl'rlund who ?1' on I)u0ulrlber'„2, 11?09 dul'Ing it dollte.4(l0 111turu11Uoll, bo wpun Ru»pondunl laid 1101' bnyl'rlutt(I, thu parilu»' uhlid AHhluy It1Iu I1udHUn WIVI hit IIt 1110 li,rehuwl wills it u1t11(11' boom wlii0li ' Hplllud Anwar her ulnthwH and halr, luring Aw alturuulh,n, A.4h1ey nh.4ervud the 11111'110.4 ultul' obtiuulliII08 and Haw her Illoll)el` thl'owll agnhlH( it Hu( o(' shill's 11114 lilt, by hur boyhrlI ild, Mothor'H boyl'riundlalor uallud Mliluy it "bitch, 5, on pecentbuP 27, 109%,Mother aall0d Ihlthur at npproNinta(uly I 1 tool p,nl;' »InOu tlnoth4r dnuwHlJO Inoldunt NO begun, Molher'» boyllvlund had Como hnntu 1111oxIcIllud find thurul'gru Vothur'wtty nlerlud (hul 110 may neud to pluk up Child, b, Mothur huts no o(ltur ruadlly avalloblo,plnuu to r091(Iu other thin with 1101• boyfr1011d, 7, TheHu IneldentH oklometi(le vlolonco Indleotu an InHhlbihty and dangor to AHhlcy,. Wi llilwl""olm, 11011llonel, regtleHO» 1111.4 C'hill'i to »ehedulu 11 prompt hU01911g o11 1110 Illalter and to 11101vallur grant primary phyHlcnl Custody of IN chll(I AHhluy Rau I ludmou to 1101' 1110101' pending n IN hearing on 0100 twmndy ewer, Re»peclfully »ubnt110ui1, is ----------- IgnS'i.4 K, J011r.4, f?»1101100 Altorrlcy Itu, I'clitloller 7 Irvine Row Cnr11.41u, PA 17011 ' (717) 2d0-02O6 .:...... I VC?KIFY'I'I IA'1" I'I IF hTATI"N I?N'I'h MADU IN TI IIti COMM AIN'I' AIW . I'It111± AND cxOKizl?c!'I', I UNPIsKHTAN1) TI IAT FS''A'I'I?M l?N'I'ti I IIsl?I'IN AKII MAPIi 181J101 TtII',1)1;NAIllI;S O 18 PAP, 8 §4904 KI?I.A'1'INCi TO UNSWO?RN FAINFICA'I'ION TO AU'I'I IORITIVS, ??KItY/(t, IIUhi'ON i 1 ' i ?. 1., 1 r r?1 b 1 r ?]tj ' 1p r 1 ,, 1 r Lmv AI'fluu of JAN 11 Ztluttl? 7 II'vlilu Rot v Cn1-11810, IIA 17013.1019 ' (717)240,0296 r « -N ' •711 ,1t d I ,. 1 ,1 ?'i if Il, l {{ fR 1 ? t 1 ... III I ? r r ' , II 1tItY It, IIt11?tI11N, i IN'I'Ill? COURT tl1+V01YI,-I(1N 111,MS (lf I"Inintll'I' "LtA'lMIRI.AN1) CM IN'I'Y, hl:NNSYI.VANIA vH, NO, IB-5101 CIVII,'ITRM RI1,I1FCCA I„ O1pt1NNFl,k ; CIVII, ACTl0N- l,A11' „ pufulldaniq ; ('U5'pOfll' . AND NOW, tllbl 211b11, upnn unnHldui'alilln of 1110 a11110hud voillnln1111 I1.1IH lionl1_v-(I11ooln,l hilt thu p11rlluH lutcl Iliuh' I'uspuullVU eolipol lippom, hul'o'10 ?I1 the 0nllulllll(t11', M ,K?y,` Cunlurunea At Haub conluluneu, 1111 01'Itu'1 fit a ? 1,111„ for 11 dire-NuAring Ovoid) Nv111 bu Illll`I? In I'uynlvu IN IHHUuH Ili dlyputu{ or 11' II114 uNmol hu 110complIHIJU11, to clullnu and mn'row IN I88t104 to bo 110111,(1 by Illu uota't, and to unter Into it tunlpormy order, All 01111drutl lip live or olclur 11111)' t11Hn bu prosolit 111 the 0olllurun0o,, 1'1111111'0 to tlppulll' tit 0110 0onl'urunt:u Hwy provldu groundH Ihr entry ol'a lumpnrnry or purnlnn0111 order. fly 'I'lili CoURTI ??llHlody CnIIuIIIIl1or ( 1?.?,? Thu Courl of Common Heim of Ctllllbul'Iall(I Coijoly IS r0qulrud by law to comply with the Amut'IeanH with I)IHnbilkluH Act 01' 1990, For Inlimnlmlon obout a4umlblo Ii10111008 aml I'ut unable IlocommodatlonH ovallablu to (11411blud 11101v1dual.4 1mving b11HInum below 1110 court, 1)1911110 contact our ol'lou. All arrmlgunlunt4 11141Ht be made lit least 72. houl'H prior to filly 11011ring of huHlncHH buftlru 1110 uolld. You must attend thu. S01100111ad coulbrun00 or hcaring, YOU SIIOUI.,D TAKI? ' HIS I'A11I?R'I'O YOU LAWY11R AT ONCIR, II? YOU DO NOT I IAVE A 1AWYER OR CANNOT AFFORD ON, CIO TO OR T4l,l?I'11QN13 1'111? 01TICE 81:111' 1'OIYI'11 11131,OW'I'O FIND OUT WI IRIM YOU CAN GKIIAXIA1. FII?1,11, CUMRI?RL.ANI7 COUNTY T'Y 11AR ASSC)CIAI'ION 2 I,Ibehy Avenu0 CorIIH1u, PA 17013 (717) 249-3166 11,'ItIty it, IJUDSON IN'I'IWCOUh'I'nl Clt)?4?1OIJ p1,1?ASO? I'llllntll'I' C'I1Ml1l'.R1,/\NI) COUNTY, VI-NNSYINANIA v, I , ; No,'08-5L)I C'IVII,'IT I M Iil lii?CuA L,, C)'hoNNI?i,l. r CIVIL. ACTION I'A\V hOI'Olldlllll C'l15'1'O?)Y COMPI-AIN'I' IN CUS'I'ORY I, The pinhltll'I'18 J1?RRY R, IIVhSON,1.081dingill 1,) 1'1111 01-01c, C'arIIH10, 1lennsylvlulill, 2, Thu pu1'undanl Is RI I1f ;cC'A L,, o9)ONKI,I,, rusldin8 tit 315 Junipul' 51.1 Carl181e, l'unneylvnlli(l, 3. Phdltlil'I HPAs o4lstody nl'thu 11111 Wing 0111101 NAME ITFSE;NT RESll)I?,NCI AUf? AHhloy lulu I III(IHoll 315 JlllllpOv Sty 3 yrs. ('111'115iu, cumhurland dot) 12/8/96 Coulltyi.I)A '1'110 uhll(I FV(IH hovel 0411 of, Nvatllnck l hu 011110 is Ill'09011tly 11111 10 UIIHIo(ly 0I'." During the past 111v0 yum's, file UIIII(I I)lIH I'0HI(IO(I 1YItI1 1110 IoIIo1VI11g perHollH Illl(I Ill fhu Ihllnwiltg II(I(h'OHHUHI . PERSONS ADPRF." DA'I V 11Ininfll'I', Mny IItldHoll,l 19 F11111 Circle 12/()6,2/97 Mlohaui Iludsolt CmllHlu, I'A hei'undnnl, floronce Fishur, 619 N. West St, 2/97.1998 Sandy l'ishur, I'Mrick Kist ler Carlislu, PA k Alison I'iHhul' 1)ol'endnitl Appnlnuhian Trall Motel I weck In 1998 Carlisle, PA . Uul'und11nt, hynlt L,NU 'H?R Np4hh l?r? It)'?N•?ununur l')')') ,? Ityun'n hm'un14 c'ttrlinlu; Pr\ pulandn4l,'Ity11lt l-NU Pttntl'rul tit, tiulltntur 1009.1 1/99 Cor1141u, PA I?elbild11nl,1141111 OU t 15 JI11tipu1, tilt I I/9o-111,0110111,. Ctn'11n10, PA Thu 110111101, (11'1110 uhlld In I?ulun411n1, She 14 41nr11u, The 1141101, ill '1hu uhlhf In 1'111111111'1' 110 In nhlltla, „ ?1, The 1,01otion4ltip 1 11'11I11 11101TIo the ellild la 111111 ol'1114tlr11l 1'110hur, 11101) 111111111'1' plll'I'elllly 1'041(104 With the 1olloNviny puPeon4; NAMI'. RI?1,n'I'ICNSIIIN „ M11v I Itld4olt Mother hjiuhnul I ludeoll llrttthur 5, 'fhuavlg11on11hlp o1'h01'01id11n? to the child I4lhttt (11,1(mi al olothul" 'file h401101111t currently 1-041404 W1111 Ih0 follotvhtg p0r4onA NAME RVIATIONSHIP Ry11n I,NIJ None (1, 1'111In111'1'111t4 not participated 114 it p111'ly (11 1, or In 11ny (111101' u11p11elly, III (111101' IIIIt11Ulolt concorttinl; ill 10 cuNtody ol'tile Child it) 11114 or nlt(1tltur court, I Imovul', the 11111-1104 did enter into n Cu4lndy Agreement wiliuh, wn4 hale till 01'dur ol'th14 Court on October 29, 1998, PI11h11111,11114 no in1b1'ntntion ol'a Custody procOW1116, conc0rning the Child pending lit 11 court ol'I1114 Commomvunllh, ' I11111101'I'dou4 not know o1'll 1101soll 00l 11 p111'ly to tlty provuvding4 who 11114 phyfliual utHody al' 1110 01110 ill, 011111114 to 1111vu uuµlud , m' vlellollon 1,100 NY101 1-u411uc1 to ..Ihu ehllc?, 7, '1'110 h041, 111101'041 (Mil 1101/111 unt N'011111.0 (11'1110 0hlld will bu 401'v0d h?' tlrlariln?l „ Iltu 1'01101' I'0ga041ud Ii11' Ih0 I'PII?IN'lI1B I'ull4(111y? 11, 11101(lows ol'donlcslic. vi(duneu bullveull MoIllur and 1101' lloyll'lulld lwvu 1111100( Ihu Child In 411111111011111 d11ngur; h. Mollm,11114 beun imilblu to inninndn 4111h1011o114111u w11110 Fillhur Ims 11vud in Ihu 4111110 lwidan0u Ii1r nppro?lnu}luly twvlv0 yuilr4; 0, MolhOr 11114 huun n1111h10 la m111n1111n 41011dy unlploymunt w11110 Vothur hlls worlml ill 1/111104 1111reul Sulwluu lilr 1110 last 41x year's; 11nd d, 1'Illllur 1,9 hutlor nblu to provldu IN I1e00441il'y 4nlblllly 1,61. IN Child, H, Va0h par0111 whose parunltil rights to Ilia Child hnvu not 110(11 turnlin11lud 1md Ihu her4all who has physical 0114lody nl'lllu Child 11114 110011 IwIllud aN portlu4 to 1111x, octioll, , w1II'1WFORI?., I'I111n111'I'lugtlusls 1110 Calll't to grunt 13114lady 01'1110 011114, I Rcsp00U'ully submillu(I, , In)?G4 K. Jolla4, 1"'splr Allornuy for I'IalntlIT 7'Irvlno Raw CarH41u, PA 17011-1019 (717) 2410.0296' 1 ?Iff I ;1 I VVItIV I'lIAT I I II? STATI'MIN I H n ADV,IN TI IIti CONIVI,AINT AIW TRUI' ANI) COitiOWT I I?NI?I:Rti'I'ANI?'I'I IA'I' I'AI-tif? ti'I'A'I'I'?41'N'I ti I II'ItI,IN ARlI MAhI? hUl3dl?r I'll'n'fIII?. PIsNA1,fll'N O IN VA,CrN141004 RIsIATINCI TO C? UNWORN FAI,tiIVICATION TO AUTHORI'I'lVS, F, : r _ lei, n I' I * ,1? t 1 ?.I . (? , ??,.\?c,(? 11N 9'LI13 COURT' OF COMMON P AIO'', Plehlll[i' op CUM111110,ANP CRUNTYI t 11I;NNSY1,YANIA v, t 1 CIVII. ACTION LAW (fit ` i P01?nthnri INCI,CIVll,lc9`1?z. I CUSTODY V1S1TATION .O13DIM Qll rQ[d1u. it is haloby c iruat6d And now, Ihia t Qc> , upon aonsidurntion 01 ,1110 illl0ahod 001111111111111 vo aollll 6 appur boforo'?mt,_ c' that 1110 nbovo ?tnr4laa !1110 Ih611' 1'usllootl n 1;a lih'o, the Monolll0tor, 11t _'' 4 1 lcC4 (511{-`14y <?? ?-- Pomisylvltllilh on tho. ?`1+, cloy of t?tc 2000, ql J10a_. IW' PiM'1 for 0 Pro-hattrillg Custody Collfaranoo, At shah aonl'orolloo, 011 offort will bo t?t0do to rosolvo tho Issl?ua III dlaplitot 01' If tills 011111101 ba 11000111111181100, to clanno 0110 narrow iho Isallos to bo hallyd, by the court, fund to 011161, Into it tolnpol'ary ordur, All ohildran ago flVo or oldor 11111y ho proaout it tllo oonforcllau, : Fullilro to uppoar it( tho aonforonoa ?luly prMVldo grounds for Ilto ant?y of it lolnpol'tlry or porn1011ont ol•(101' 1101011.113 COURT, Cuatocly Conciliator l_l ( sal YOU SHOULD TAKE THIS PAPER TO YOUR LAWY131t A'T' ONCH. III YOU DO NOT HAVE A LAWYRR OR CANNOT AFFORT) ONE, 001'0 OR'T'Lla1PL1ON11 111.ILI OFFICI? SLIT FOR'T'H 1113LOW '1'O FIND OUT WI113113 YOU CAN 013'1' LEGAL HELP. '171.113 CUMMIRLAND COUN'T'Y BAR ASSOCIA'T'ION 2 LIBERTY AVENUE CARI,I8Ia13 PA 17011 (717)249-3166 '`. 1-100.990-9108 JAN f' 11 lOtIQ X-RRY R. I-IUDSON, IN RIF COURT 01- COMMON I'I-F-AS OF AINTIF F CUMPI,I11•ANla OOUIJ rY, NFNNaYhVANIA I P4 f V, ; 1 R11PI:;GCA1•,O'PONNfi-1 omi01OIVll-TrRM nFrrNPANT AND NOW 4118 2? -day of January, 2000, thl maUor having been ) Called on a petition of Jerry IZ, I-IGldson seeking special relief, And upon agreement of the oartles, the petition la resolved with the fQllowing order; (1) No party Inoluding Ryan Ward shall drink to the point of Intoxlagtlon whlio In the presonoe of Aahloy line Hudson, (?) The merlts of the oustody complaint are forwarded to Conolllatlon, Dy tile 00cir t' C'doarG?,R I ,? James K. Jones, Rsgtllra ?I For Plaintiff peter J, Russo, Csguire For Plaintiff 5p?1 t Administrator T 1 O RRY lit 110080Nr I IN 1111IN COURT oG CnMMoN PI115AS or, Plaintifli, ; CUMnf.RGANp MONTY( PI:NN8YGVANTA I, Vag I Np, 96-61a.t. cnVIr, TPRM n I.lI'CCA rig 011ONNUr41, i cTVTT, ncrxoN - hnW Defendant ; CUS'e)DY 011*2 01,' COUNT 6996 1raw, t.llia day of ?: (,l.l \ consideration of the atl;Acled pual:ody and directed An fol.lolya; L-0110 1. At on Ropor?MG eaorda?cd . i6 D prior orders of this Court CIAtsd October' 29, .1996 and Janual;y 26i 20c>o Are VAaA(;ed,And replaced With this order, 2, Tile WaLller, Jerry lit' Iludson' and the MOtilev, liebecca r„ O'Donnell, 81141,1 114Ve shared legal custody of Ashley RAs lludoon, born pecember 61 19969 I14oll parent shall have an equal rigllL, to be exercised jointly lyitll the ohllgr parent, to make all major non-emergency decisions Affecting the Cflildla general Well-being including, but not limited to, all deciaigno regarding Ilea Ilealtllr edwitione and re.ligiont- 39 1'118 parties shall have pllyoical custody of tile Child in accordance' With the following sclledulel As '''Ile Pather allall Have custody of the Child every weekend from rriday After work until Sunday evening at 600 pop, D, III' the event the Gather works on Griday evening And cannot receive custody of the Child, tile Gal:11e06,peI7 of ctleLody' shall begin on Saturday morning at 9;00 Aim. and continue through Monday Lit G;00 p,m, 'Ilia Gather alial.l give the MoLller as much advance notice as poasi,ble if he llaa to work on Griday evening, In the event the raLllev works on a' Monday when he has custody, the Gather slla.il Lransport the Child to the residence of the babysiLter, Wendy Haney, " C, 11110 Gather "lay, have custody of the Child it any additional times agreed upon by the parties, D9 The Mother allall have custody of tile Child at all Limes not otherwiae specified for the Gather, 44 'Ilia t)arLies shall allave or Alternate IlaVillg custody of lane Child oil holidays as Arranged by agreement,,. The Mother ollail have custody of the Child every year oil Mother's Day beginning AL 10100 a.m, G, Tile Gather allall haVe custody of tile Child on the Child's birthday at a time to be arranged by agreement of the parties. I\ , 6, .. Tile party receiving custody of File child shall be responsible to provide FrAnatyortoFion for I:he eKOhanne of oual:ody, 79 In the event aithor pArt;y intends to remove the cllild from Ilia or liar reaidence for An overnight period or longer, that party a114ll provide the other t4rFY with A telephone Ilulllcer where the Cllild can be reached, a? WAP11 parlay PhAll promptly notify the other party of any emergency involving the ilaa.ltllr safety or wo.l.fare of the Child Arising during Ilia or her period of custody, p, Meitller of tile fxlrl:.leas nor Ryan Wardt a11A.l.l drink to tile point of, intoKioAtion While in the tJreaenoP of:, I he' Cllild, lo,. The non-custodial parent; allall be ent:iglad to have reasonable wlepllone contact with the Cllil4l, a.l,t This order is entered pursuant. to an agreement of the pArtiae At a Cast:ody conciliation conference. The parties may modify 1:11e provisions of this order by mutual consent, In the ahsenap.of: mutual conPente the 1:an11s of tlliP order allall control, nY lairs COUI1'11r lot Gddar n, nay ey?? ? J, , ? ? oa act James I(, Joneai 13squire Counsel for Gather, \t? Meter J, nuaaol. 9aquire Counsel for Mother „ 017RRY R, IIUDSON, i I:tV TillO COURT 01" CO(,1MON PT#WAy'CG plaint?if i puMD19t[,AND COUNTY( IIENNPY14VANTA i Vs, i N0, 011-8101 CIVIL, T1411M t 1iROXCA f,, 01DONNI"'I41„ 1 p1VTI, ACTION 1,AW Defendant i CUDIDDY p1i1011 AtiDaGi I;c$Iar It, ItgylPy CIIfYI(MY CCNCIILATION MUMMARY RGPO1'1' IN ACOMPANCW WITH CUM11GRLAND COMITY 11111,14 OIP CxVII, PRoOPINI G 1918,3-81 Lila undersigned Custody Conciliator submits the following report$ 1, Tile ?erti11 nt: Worillation concerning the Child who is the subject of this Iitigatipn is as follows; NAMH DAT11 0151 1111011 CURRwu IN'dimmy or Ashley Rae Hudson ' December 01 1996 Mother A Conciliation Conference was held on Maroh 71 2000, with the following individuals in a4ten0ancot' The rather, Jerry t2, Hudson, wi411 ilia counsel, James K, Jones ,"'1laquire, .and tllo Mother, Rebecca G,, 01Oonne.l,lI w4h.har counsel, Peter J Russo, llaquire, 3, 't'ile parties agreed to entry of an Order in Lilo form as attached, I" ?q.t.C.? U ? r}[3E.lc? t???cu-t : l?• c. tU?lC?t..? DaLe Dawn s, 8un.ay, 1Bsqu re ? Cuawdy Conciliator 'r' M1'tl ,11!1110' It. III)P ON 111-AIN'I'll'I' \ IWIII 'CA 1., O1DONNlil.l• 1tliMiNPAN't' I IN'I'lilt (VI II(T nip COMMON 111,liAS OF I Cl IMIlliItl.ANlt COUNTY, pI'`,NN8)TN/ANIA I 1 1*51(11 CIVII, ACTION (MY I IN (I ISTOPY w1orli-(JP' coula AN) udnei lomilcin 01'1114 pIIllVhud C'n111phllnl, It Is llorohy dll'0010d thin pln'110H null 111011' I'uhpuulivi; ennllHol 1111polll' holbro .- 1111\11{ h, ??IIIldllyil_Xih__-_.._, Ihu 0onvilllilor, nl_---..-- ?u\yur?A111111ti1fuu(GAluu{1111tIcsI111Ly?PA_1711l5... un __ \Ym1111?+)I(ly,?I)illuli?-alllll--•--? II( I1111111.._q,llh F01' it hnl•I10111-10l1 C 11sl0lly COnlurona4, AI mull Canfuronoo, nn 01'1101-1 will bo 1111100 to rosoIyo 1110188ous II) it IHplIto I o1- 11'1111H 01111110( lie I140ollipIAHhud, in ilunnu lulls nnrrnly Illy Mum In ho huurd by 1110 Churl, rind to onlor into ii 10nlpnrnry ordur. All ullihh'on ogu livp 01- oldor nwy u by hu pl'usulll III Illu 0011luronov, Vuilnr0 to 11p110111' lit IN m llpl'01loo Iliily provide groullde Im' Cully ol'll (0111pa1111'y of pe1'mnlloul ol'li4r. Thu eonrl huruby dh'uuls thu pnrllus to Ainiish nn,v nnll oll uxlsIhig I'I'nluullon from Allow ordurs, tipv0h111001101' ordursl mid C'nstody nrdin's In the MMUHWMV dN hum's prier in soludowd WOW, FOR '11I II( CC)tilt'I', .. 1. Ilyi. 0sV C_.U.(tttlll-d,- tl11 (0j,_Ea(jl. Custody Collullilllol, The Conn ofCninnnn Illuns ol'CUntherlnnd C'ouilly is rugnirud by low to Comply N;Ith (tic AlnurlonnH with I)11mbilhos Act of 1')110; For hililrmulinn About nuuusyiblu I'nuilldes lid ruusonoblo pu0untnxnlolionH ovnlluble to t11811bled hullvidunlH hnvbtg blWooss belilro the uool'i, pl0tlsu unltiliol out' or(iuu, All urrlingunionts 10111111 he nwdo lit luusl 72 hours prior in uny licurilg or bnslnums hulinro tho uolld, You must nUCml (lie H0ltudulCd u0nlurultao or livlil'htg,' YOU 811001,1) TAKI?'1'11111 VAI'IiR'f(.),)'Ol19 A'I'i'ORNI,,Y AT ONCli, 11, YOU DO NOT IAVR AN A'I'I'01INVY OR CANNOT A1,TORI) oNli, (u)'I°O Olt 11iL PHONti'11IU OPMC!V Hirt' FOR'I'll 11111WA) TO hINI) oU'I' \Yl111 is Y(AI CAN OFT 1.1MAl, I Ilii.l'. lit (Allilhodluld Counly I1nr Assuciutiou 2 I,ihorly Aveoou CnrllHlu, Pennsyha0do 1701,1 Telephone (717) 249-;116(, X11 i j( I Ir C I ; AEI ? ?'yA•g[ppry ??g ? 1 IprrY li, 1111(141111 IN'I'I II( t'( 101 W' c' It,•INI )N Illd':AS OF I'Inlmll'I' CI IM 111'.ItI.ANil ('OIJNTY, III '•NNNYI-VANIA ?', : CIVII, A("I'ION - I-A1V c?Ilti'I'OI)y/VI`;I'I'A'11c)N. , Ituhuuuii l„ ( )'I)onnull - I)01,01jd11nl ;No. 48.51111 C'IVII,TI?Itk4 , PRIM It tIIP.('(1!(I?'h AND NOW( 2-Q__, upon conHbluralloll it I' 1110 1111110110d Collill III lilt, 11 IN hpruby dlruclud 111111(110 parlicH and thulr Pu4puutlVP uollosol 1111P0111, 1101((1.0 ---- _ . - 1111 Ihu ............. dlq' ul'..___ 211111, al u'Clquk, _ dll„ 1,61. 11 I'1'u l lual'h18 ('nelndy Coalulvlluw M Huth untll01'011cu, 1111 01'11,1'( tvlll bu I1111du to I'uNnlYu Ihu IHHIIUN (Il tllHplllu; 01' II'IIIiN ollllllot 110 llvoolilplIN110(j, It) (101111t) 11111111111 'I'g11' 1110 18,110H.to 110 11011('(1 111' Ihu 01111.1, and to 011101, into it lumpor11ry order. All chlhhun Iwo Ilvu or older Clay also bu pru4u111 111 Illu coil l'u'l-ullcu, I'nllnrulo nppullr al file un111,01, 1100 iltny provldu µroandN for P1111, 1' ol'a lumpornry or purnl11nunl ordul, FOR 'I'l IF COI llt'11 l 111„ Cylslot t'nnulllntar t Thu Colu't plTolpmon I'luaH ol'Cuillburland Comity Is rudalrud by Imv lu.vonlply wllh Ilw ' AlllurlomIN wllll 01411hilIlluH Aul ol' HIM For Inlorlna11Pn Ilhoul acouNHlblu Ihulllllux IIII(I rell4ollltblo IWu(atllnodnllunH a1111111blu (o (1141111100 I11dlvlduHl-4 h11vhtt 1111H11tu4H holi(rc Iltu coarl, plull4u Contact o11r olfluu, All arranCtumumH must bu amdu al 101141 72 honrH prior to ant' Ilcal'IIIH or bn4hlCHH huI'orN Ihu court, Yon 11mHl allund Ihu nulludulud conl'urun0u or hunrlnlt, Y0 1I `iI10111,1)'I'AKI:'I'I 118 PAI'Vit'IO Y01Ilt I-AW)TIt AT ONCE, II' YOU DO NOT I IAVI'. A 1,AWYI?lt ()It CANNOT AVFOR1) ()Nil, (10 TO OR '1'I IMPIIONI;'I'l II? OVIll(T sil.1' 1'011'1'1,1 I)IiI.ON','1'O I'INI) OIIT \VI IFRI YOU CAN C1111' 11MAI, I lIll.,p, C'Innhdrland County 11111, ANNIII! lilt loll 2 I,Ihurly AYumnu CarlIHIu, l'A 17411 I'llolm (717) 2,19-3 166 Jul'ry It, II(Id4nll . ; IN'I'lll: COI nt'I'nl ccltgylnN PI-f???ti c11' NhlI11111T ; C UNIIiI'M AN11 COUNTY, NI'.NNSYINAN1k 1 t, . CIVII, ACTION r 1, W c'll5'I OPYNIKIATIc1N Ituhuc?un I„ c1'1?nnnull ; 1)ulundlnll ; No. 98-5101 C'IVII,'I'I?It?'I I . 'I 110 11111111111114 Jul'ly It, I Imiso11, 1'u41dlllg 111 118 Pop voOl l C'o111'I, ('111'11410, OutI11u1'il11(I fl C OM11y, PoIllivIvilllhl 17013, 2, 'I'llu I)g1PI1(II1111 I4 Itulwocil 1„ 0'1)1)1111011, FeSIC1111g'1116,12 North Wo41 Sow 1, Clln'1141u, ('1111111UI'hold Clonlll)u11114y11'lllllo 17013, 111nh1All'tluuk4,u1141odY 01'11lu Iilllowing uh111L i NAM!': !tl?S ) ;NC li .. !)(111 1(d 1)411Uy It V t [ 4( 032 'llt ? ,4 1 .. Nl,1 u. 4 'u ( _I I l I 1. mi 01 8, 1996 1 /l yum4 C'o1,11y10, PA 17013 I Thu 0111111 11'114 11(11'11 out 1)1' 1Vu111o0k, , 1110 UIIII(I 1.4 ht'U4UIlIIy III (110 0lislo(ly 1)1' 1J0IU11(111111i During 1101, 1110, Ulu 01111(1 11114 I'uylllud \011) 1110 Ii1IlolVil1g p01,4o114 !1111 l11 thu Ii11h11Vlllg „ NAMI r?l)I)I21',titi I_)i? I'I?ti ) „ Jerry It , Hudson and I (? VIIIII1 C'11'ylu 1111,111011111 f It(,h0cua 1„ (1'1)1)1111011, Cat'1141u, VA 17013 Spring 11)97 1 M11y Hudson and MI01t11UP Ii0d4on Itphuuun I„ O'hollIMI, 611) North 1Vp4181ruot 8llrlllll 11)9710 1'inl1uu 1'1,41101, ollcl CoIlI41u,'11A 17013 ypl'lltll 1 OOH tilnuly Railing, , Al14nn 11x41 1)1)1)10 unkitmvn -I:NU l " 1'ellI'mIJ Rultuuull'I" O'Doll11u11i \\hlhlllt liu0nnl Komi 5111-11111.11)I)H 10 loo RnIIIII8Illid Cm-11Nlu, 11A 171)1 1009 Sonny Roiling, AU4on IIaHI Illllllu llllknn\1'11 '-1,N11? 1'tlt ?LNuI ,. , Itohouuii I" O'I)onnull, 611) North Wo4( Strout 010'11' 1001) 01)1) 1 f'lorulwu I lahur Clirii4lu, PA 17011 1111)1) 1901) IZulluuull I„ O'I)(1111w11, H28 MINIM PrIvu 1001) 1111111 Ryllll W111'd 11110 '1t111111?' Cmiltilu, I'/A 17013 111101' 111.11)99 01, RyNIl word Ituheuull la, 0'1)01111011, I'Pnlll'QI 1` 11)114 Rircul 111101' 11)1)') III Ityall Ward Nod lilmlly Corlislu, I'r\ 17013 Novunthor I1)91) of Ry11t1 Wllrci Ruhuucll 14', O'Doollull, 315 ,I1111ipur Struul Nn\'ombor 11119 111 RYINI Worcl oltcl Folllily Carli4lu, 11A 17013 N'Iar111 2000 ul'R?mn Wnrcl ro , ltohucull 1„ O'IAUlooll, .. 39 Oluhu Avunuu Ngaruh ,O (1) Brutt cll'ougur Nuwvinu, PA 17241 N-1Hruh 2001 Kollecull L,, O'Donnell, 032 North West struol N1111,01 2001 In. 111,01t druugul' CarIINIu, PA 17013 pru4unl •I'110 mother ol'Ille C hllil IN Ruhuucll I„.O'1)onliell, Con-colly ruNlllloll111 032 NoNh WON( ' Strout, C al'1141u, PA' 17013, Sho IN III1l'I'la'riucl, i.A I'h? tillhul't,l'lltu 0111111 Im,lurr?' It, I IndmOn, ualrunlly rumwing lit 410 I10llT"d Culn'I, Cu'liylu, IlA 17013, flu iy nlau'rlurl, I, '1'110 1,01110tmmhip ol'Ihu Plnindl'I'lo the 011110 Is 111w ol'I., 1101ur, Thu IgnintIIT L,ul'r0III ly 1.041dus with thu lollowills pursollsl Kllnhurluy I hldson, him lvll'o 5? TlIV toI(illol mhIp (11' 1110 P01u11u111n1 to II IV 0111111 I.4 (Ilm of molllur, 'I'llu I)VIlbII(hllll ut11'fulllly ruAWN wllh`'thu Ifnving pumon41 Iirutl (hvug0r, hoyl ,1011(1, r,, Plainlifl'l om liin'liuipalud al4 11 11111,0" In (111101, Illi nlion uonoVl'ninu the unmanly, nl'Ihu uhud In thin nr anolliur 00(0.1 nl 11114 samu dnuk0! numhor, 111nin11l'Phn4 no Inlip'nuUloll ohl ulislody prneuuding uonuurnlnl; !hu Child pondlrl'g In n Court 01'1111.4 Conlln0nwonllh. 111a11nUl'I'dn0m not know ohl pursnn not ll porly, to the prouuudhiga who 1111.4 1)11y.4lu111 011910dy oI'Ilieu hlld of cIIi IIll m to Iwvo custody 0r 0.41111dol1,11611144 wllh ruspoot to ale oilIId, 7, Thu hum! inturomt 11nd purlnnllunl wollitly ol'Ilk child wpl he mupvud Q granting the rellul' ruquomt9d (in' 111(1 1i111n??'Ing 1.011.401141 A. A Cotn•I Order ol'utlslody 11m1.411'tlulurud v1shallnn 1.4 dumh'ud mo Ihnl I'1111nllff and IN 011110 wily pllin thulr 4uhodalgm accordingly, rind mo Ilmt nllmandur.4tnnding4 and unmet uspoClndons rugording Custody and 0.4hodon caul I, 10 tlvoldud,11110 also so Mot Ile 01111(h'oll nro not use(I in a 111rinlpolatlvu lilmhloo 11, Thu pardes helve hour 11arihlu to reach munml ugmem01t14 lvllh Ivgnnl to the divIsion of holldays, mlinu»ol' vac11Uoni and prohlonls 111wo hour Chronic wish regard to (lie heglnning of weokond Omits, R. lil)uh htu•unL??'hoHa pnrcnl+Il ritdllH m dlu 1'{Iild hn??u nnl boon Iurullnnlu,I lunl IhG? pw•HUn who buy phyHilad vuhtody nl Ihu Phlld Ilm'u huu)I nnmall on lunlik'N to Ihb+ III'lloll, 4 V1'llh-lil?h'411t1:, hlillnlll'I'ru,luuHlHIhu t'nu1,1 to It1,nnl pn1,11n1 uuHlnd?' nl`Ihi+ uhlhl 111 I'I,dnlil'I' ill n9uo1,dlmup with a llud Huhudllly, Ituripul'll'llll)' Hllhllllllud, ,. ANORVWS IV mI INh( IN Alldrowm, I?H,11111,u A 1q111o) 1,111, I'Ininlll'I' QVIIHlu, PA, 171111 'I'olu?,hnuur(717)?d1•u1?3 " 811111,umu Coll1i I I I No, 156,11 Cfi1vl1vInN\\!I?A1,TII (.)I1. NI?NNhYININNI!\ 1 „ i 1111, , lot)NTY OF CON111F IANO PO, I I v0rlly that tlw 8htluni0111; ntlldu irr 1110 I'nr0l3nin(i G'nmph11nt tlru'truu ImO con, midurmolid thAl 111180 8mmumunl81101.0111 ar011illdu 8111i,10o1 III IN putitlltluy n1' 19 I'll,(stir §ali)pf{, rulnlltiri In un8wnrn I'a181110atliin In nalh?iritlu8, 111!\'I'Isl_;^' ? ._ ? -,•.-"-?uI;I?' R, 1'IUll80?lr 1'IIIIIIIIII' ' Vill, d C? 1, r I 1 n i .r r , 6 I , ,71?I212Y I2, IIUpSON, Nlg illla t: l! Vs, It1s131X1cA [„ O11?NNI?t,fa, Defendant ! IN 1111M COUBT 0111 COMMQM 1314NAS ON I CUMM-114,AND CCUN'I'Y, PV;NNSYt,VANTA I I NO,. D!h!5,1,01 CTVTI, Tl IIM i c.TVZr, AC NI-TON f,AW I iN CUSUDDY 011M OR DIP ooau'l' ?tND NOW, this clay or:Q , 2001 t uton ,consideration of the gtLacled custody cons aL on Bogert, I: is ordered and directed as followsl 1. File prior order of this court dated March Ist ,2000 shall continue in effect: as modified by this order, 2, The parties shall allgre or a.lternaLe having custody of the Child on holidays as follows; A. CtislMMSt Tile Christmas holiday shall be divided into Segment. A, Which shall run from Christmas Rve at 2;00 p,m. through chriatmas pay at 2too p.m,, and segment Of which shall run from Christmas DAY at 2;00 p.m, through December 26 at 2100 p, m. The Pather sllall IlaVe custody of Lila Cllild during Segment' A in odd numbered years and clurinci segment p in even numbered years and the Mother allall.have custody during segment A in even numbered years andlduring Segment p in odd numbered years, u, !1'IIANKagIVINaI The 7.91ankagiving holiday @11411 be divided into Segment A, which shall run from the Wednesday before rhanksg.iving at 2100 p.m. Lllrougll Thanksgiving Day at 2100 p,m., and segment 13, which shall run from Thanksgiving Day At 2100 p.m. through the Priday after allanksgiving at 2100 p.m. Tile Father shall have custody of the child during Segment A in even numbered years and during Segment n in odd numbered years, and the MoLher shall have custody during Segment A in odd numbered years and during segment 13 in even numbered years, C. VIA M' I The Caster holiday shall be divided into Segment At which shall run from the Saturday,before Caster at 2'00 pp.10, through MaeL•er,Sunday at 2100 p.m„ and Segment D, which shall run from raster Sunday at 2:00 p,m, LI1roUgh the following " Monday at 2100 p.m, rile lather shall have custody during segment A in odd numbered years and during Segment u in evert numbered years and the Mother shall have custody during Segment A in eVen'numbered years slid during Segment 13 in odd numbered' years, U. AGTLMNA'1'xNC IIOGIDAYSI The period of custody on Llle following Altornatinq holidays shall ruts fron 9100 4,1119 until 11100 pone, in even n6inberod years, oho Mother ahn,ll have oustody of the Child on Now years Ix1y and '11.1.1y 4ill and vile t'Abler Shall have custody on MomoviAl PAY And (Inhor PAY? In ad numbered yearPl Lilo Father 1311411. 1141Ye cuaLa1y of 1,110 Child an' NOW Years pay and only 4th and tho Mother shall have cuat;ody an ManwriAl nay and 14phor DAy, 01 1 11a1 1a IA F 11,11:nI Yi ` In ovary year, tile Mother shall layo custa7y of t:1110 Cllild oil Motharls Pay from 0100 Alin, through vile following Monday morning when tile Child gcos to school, and the Pother ohn11 have custody of pile Cllld Oil GAthor,fs Pay from 9100 q',In, through the following morning when the Child goes to day carol la, HAGf kl ?111ICK-OR-UNIHAT Ic31p111 !tile Pilthojl Pha,ll have custody o Ch 1d for ttall.owaan '1'r olc-or-'1'rgat' night: fraf, 3100 piing through the following morning in odd numbered years and vile Mother shall have ollat+ody of Lila child for Lila Paine Lime ,period in ©ven'1lumbered years, at '1'he holiday custody schedule shall supersede and take precedence over tale regular custody schedule, 3, Each party Phall be entitled to have custody of the Child for two non-consecutive Weeks each supper# The Gather Phall provide notice to the Mother of file datea Which Ile, has selected for, vacation by May 1, of each year and after the VAther has selected, his datear the Mother shall provide notice to the GALher of her vacation weeks by May 15 of each year, Tile Mother's periodo of vacation custody shall include 7 full daya, The Patherto periods of vacation custody shall include 5 full Weekdays in addition to 'both the Weekend immediately preceding and the weekend following Lila vacation Weekdays, The GaLileris regular Weekend period of custody at' tile end of his vacation period shall conclude on Sunday evening. The Gather la periods of custody during the summer 2001 shell' run from duly 2, through July 6 and train August 13 through August 17. The.. Mother shall provide at least two Weeks advance notice of Lila weeks she selects for vacation in 2001. 4, Paragraphs 5 and 9 of this Courtia prior Order are Vacated. 5. This Order is entered pursuant to an agreement of Lila parties at a Custody Conciliation Conference, The parties my modify Lila provisions of this Order by mutual consent, in the absence of mutual consents the terms of this Order shall control. Ily '111110 RTC a, r oat 'Taylor P. Andrewsj Rsquive - Counsel for Gather 7 Rebecca, 4, O1bonnel.lf MotherY Jn?? PPIRY RT HUDSON? # IN ,`1y117 CoUR'l' OL' COMMON PLEAS pG ' Plaint Iff , C0M13PRLAND,C01)NTY( PPNNPY14VANIA , „vP, , NOT 98-5101 CIVIL TERM # RRpI7COA T, O1pONNUTTj # 01VIT ACPION TAW Defendant { IN CUSTODY PRIOR OWE; Edgar 11, Ilayloy CUSIDDY OCKITIA'1?ICN auMMARY IIGPOR'P IN A=1DANOw WITH CUM111311LAND COMITY RUIN Ob, CIVIL pROCNIIURW 1015,3-81 the undersigned Custody Conciliator submits the following report:, 1, Ph pertinent illforml:ion concerning Lila child who is tile stjLj 1eaL of 1:Ilia litigation is as follows, {JAMW DATE OL' BIRTH MIRED LY IN CUSTODY OL' AaI1leY Rae Hudson December 0, 1996 Mother 2, A Conciliation Conference was held on June 13f 2001, wiL11 Lila following individuals in'aLLendance, Tile Yathert Jerry ti, Hudson, with his counsel, Taylor P, Andrews, Require, and Lila MoL119rl Rebecca T, O'Donnell, who was not represented by counsel, 3, The parties agreed to entry of an order in the form as attacIled, Dal o Dm n 19 Sunday Esquire Custody Conciliator JERRY R. HUDSON, Plaintiff Vs. REBECCA L. GREEGER, formerly REBECCA L. O'DONNELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-5101 CIVIL TERM : IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff, Jerry R. Hudson, is an adult individual residing at 418 Dogwood Court, Carlisle, Cumberland County, PA 17013 2. The Defendant, Rebecca L. Greeger, is an adult individual residing at 17 South Baltimore Street, Mt. Holly Springs, Cumberland County, PA 17065. 3. Plaintiff seeks custody of the following child: NAME RESIDENCE DOB AGE Ashley Rae Hudson, 17 South Baltimore Street 12/8/1996 11 yrs 7 mos. Mt. Holly Springs, PA 17065 The child was born out of wedlock. In the past 5 years the child has resided with the following persons and at the following addresses: NAME ADDRESS Rebecca L. Greeger 17 South Baltimore Street Mt. Holly Springs, PA 17065 Rebecca L. Greeger Bedford Street Carlisle, PA 17013 DATES 2005 to present approximately 2003 to 2005 The mother of the child is Rebecca L. Greeger, formerly Rebecca L. O'Donnell who currently has an address at 17 South Baltimore Street, Mt. Holly Springs, Cumberland County, PA 17065. She is married, though recently separated. The father of the child is Jerry R. Hudson who currently resides at 418 Dogwood Court, Carlisle, PA 17013. He is married. 4. The relationship of the Plaintiff to the child is that of father. The Plaintiff currently resides with the following persons: Kimberley A. Hudson, wife; Daniel Lee Hudson, son (5 yrs); and RaeAnne Hudson, daughter (3 1/2 yrs). 5. The relationship of the Defendant to the child is that of mother. The Defendant currently resides with the following persons: Brett Greeger, husband (may have recently relocated); Garrett Greeger, stepson; Bailey Greeger, daughter; Evan Greeger, son. 6. Plaintiff has not participated as a party or witness, or in another capacity, in litigation concerning the custody of the child in this or another court at any docket number other than the above number. Copies of the last two custody orders in this case are attached as Exhibits 1 &2. 7. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth other than at this docket. 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. 8. The best interest and permanent welfare of the child will be served by granting the relief requested for the following reasons: A. Plaintiff is best able to provide the effective parenting and supervision that is needed by Ashley. B. Ashley has attended South Middleton Elementary School and the Defendant has now announced that she will enroll Ashley in a Middle School in the Carlisle Area School District. It is better for Ashley to stay in the South Middleton School District for Middle School with her known classmates. C. There have been numerous instances of questionable parenting of Ashley by Defendant, and Defendant's household is now destabalized by the separation of Defendant's husband from the household. D. Plaintiff and his wife have arranged for counseling for Ashley recommended by South Middleton School District staff, and Defendant has not become involved in the counseling though the opportunity to do so has been made available to her. 9. 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 the Court to modify the existing custody order by awarding primary physical custody of Ashley Rae Hudson to her father, the Plaintiff. Respectfully submitted, ANDREWS & JOHNSON By: T or P.'Andrews, Esq. orney for Plaintiffs 78 West Pomfret Street Carlisle, PA 17013 Telephone: (717) 243-0123 COMMONWEALTH OF PENNSYLVANIA ) . SS. COUNTY OF CUMBERLAND I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. DATE: -;7- Z / - 0 k- ?- Jerr A. dson, Plaintiff ' r JERRY R. HUDSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 98-5101 CIVIL TERM REBECCA L. O'DONNELL, CIVIL ACTION - LAW Defendant CUSTODY ORDER OF COURT AND NOW, this f?j +h day of C , 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of this Court dated October 29, 1998 and January 26, 2000 are vacated and replaced with this Order. 2. The Father, Jerry R. Hudson and the Mother, Rebecca, L. O'Donnell, shall -have shared legal custody of Ashley Rae Hudson, born December 8, 1996. 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. 3. The parties shall have physical'custody of the Child in-accordance with the following schedule: A. The Father shall have custody of the Child every weekend from Friday after work until Sunday evening at 6:00 p.m. B. In the event the Father works on Friday evening and cannot receive custody of the Child, the Father's period of custody shall begin on Saturday morning at 9:00 a.m. and continue through Monday at 5:00 p.m. The Father shall give the mother as much advance notice as possible if he has to work on Friday evening. In the event the Father works on a Monday when he has custody! the Father zhall transport the Child to the residence of the babysitter, Wendy Haney. C. The Father may have custody of the Child at any additional times agreed upon by the parties. D,. The Mother shall have custody of the Gild. at all times not otherwise specified for the Father. 4. The parties shall share or alternate having custody of the Child on holidays as arranged by agreement. The mother shall have custody of the Child every year on Mother's Day beginning at 10:00 a.m. 5. The Father shall have custody of the Child on the Child's birthday at a time to be arranged by agreement of the parties. EXHIBIT t 6. The party receiving custody of the Child shall be responsible to provide transportation for the exchange of custody. 7. In the event either party intends to remove the Child from his or her residence for an overnight period or longer, that party shall provide the other party with a telephone number where the Gild can be reached. 8. Each party-shall promptly notify the other party of any emergency involving the health, safety or welfare of the Child arising during his or her period of custody. 9. Neither of the parties, nor Ryan Ward, shall drink to the point of intoxication while in the presence of the Child. 10. The non-custodial parent shall be entitled to have reasonable telephone contact with the Child. 11. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this order shall control. BY THE COURT, 9 I P,/" A-. I A .4 ? Edgar B/ Bayley, cc: James K. Jones, Esquire - Counsel for Father Peter J. Russo, Esquire - Counsel for Mother TRUE COPY FROM RECORD In Testimony v. h,.:-?of, I here unto set ray hand and t e seal of said Court at Carlisle Pa. Th' ...Ath y o .a.rCb O P othonotary JERRY R. HUDSON, Plaintiff VS. REBECCA L. O'DONNELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-5101 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this ----?--?- day of 11yea- , 2001, upon consideration of the attached Custody conciliation Report, it is ordered and directed as follows: 1. The prior order of this Court dated March 15, 2000 shall continue in effect as modified by this order. 2. The parties shall share or alternate having custody of the Child on holidays as follows: A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 2:00 p.m. through Christmas Day at 2:00 p.m., and Segment B, which shall run from Christmas Day at 2:00 p.m. through December 26 at 2:00 p.m. The Father shall have custody of the Child during Segment A in odd numbered years and during Segment B in even numbered years and the Mother shall have custody during Segment A in even numbered years and during Segment B in odd numbered years. B. THANKSGIVING: The Thanksgiving holiday shall be divided into Segment A, which shall run from the Wednesday before Thanksgiving at 2:00 p.m. through Thanksgiving Day at 2:00 p.m., and Segment B, which shall run from Thanksgiving Day at 2:00 p.m. through the Friday after Thanksgiving at 2:00 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, and the Mother shall have custody during Segment A in odd numbered years and during Segment B in even numbered years. C. EASTER: The Easter holiday shall be divided into Segment At which shall run from the Saturday before Easter at 2:00 p.m. through Easter Sunday at 2:00 p.m., and Segment B, which shall run from Easter Sunday at 2:00 p.m. through the following Monday at 2:00 p.m. The Father shall have custody during Segment A in odd numbered years and during Segment B in even numbered years and the Mother shall have custody during Segment A in even numbered years and during Segment B in odd numbered years. D. ALTERNATING HOLIDAYS: The period of custody on the foll ' EXHIBIT alternating holidays shall run from 9:00 a.m.,until 6:00 p.m. In even numbered years, the Mother shall have custody of the Child on New Years Day and July 4th and the Father shall have custody on Memorial Day and Labor Day. In odd numbered years, the Father shall have custody of the gild on New Years Day and July 4th and the mother shall have custody on Memorial Day and Labor Day. E. MOTHER'S DAY/FATHER'S DAY: I have custody of the Child a through the following Monday school, and the Father shall Father's Day from 9:00 a.m. morning when the Child goes to n every year, the Mother shall i Mother's Day from 9:00 a.m. morning when the Child goes to have custody of the Child on through the following Monday day care. F. HAL.LCIME TRICK-43t-II2EAT bIIGM: The Father shall have custody of the Child for Halloween Trick-or-Treat night from 3:00 p.m. through the following morning in odd numbered years and the Mother shall have custody of the Child for the same time period in even numbered years. G. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 3. Each party shall be entitled to have custody of the Child for two non-consecutive weeks each summer. The Father shall provide notice to the Mother of the dates which he has selected for vacation by May 1 of each year and after the Father has selected his dates, the mother shall provide notice to the Father of her vacation weeks by May 15 of each year. The Mother's periods of vacation custody shall include 7 full days. The Father's periods of vacation custody shall include 5 full weekdays in addition to both the weekend immediately preceding and the weekend following the vacation weekdays. The Father's regular weekend period of custody at the end of his vacation period shall conclude on Sunday evening. The Father's periods of custody during the summer 2001 shall run from July 2 through July 6 and from August 13 through August 17. The Mother shall provide at least two weeks advance notice of the weeks she selects for vacation in 2001. 4. Paragraphs 5 and 9 of this Court's prior Order are vacated. 5. This Order is entered pursuant to an Custody Conciliation Conference. The parties this order by mutual consent. In the absence of this Cider shall control. agreement of the parties at a may modify the provisions of of mutual consent, the terms BY THE COURT, cc: Taylor P. Andrews, Esquire - Counsel for Father Rebecca L. O'Donnell, Mother 'v S410 L r JERRY R. HUDSON, Plaintiff VS. REBECCA L. O'DONNELL, Defendant PRIOR JUDGE: Edgar B. Bayley : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-5101 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUNNARY REPORT IN AOOCRDANCE WITH CUMBERLAND CC)UNTr 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 C[RREMY IN CUSTODY OF Ashley Rae Hudson December 8, 1996 Mother 2. A Conciliation Conference was held on June 13, 2001, with the following individuals in attendance: The Father, Jerry R. Hudson, with his counsel, Taylor P. Andrews, Esquire, and the Mother, Rebecca L. O'Donnell, who was not represented by counsel. 3. The parties agreed to entry of an order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator JERRY R. HUDSON, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. : NO.98-5101 CIVIL TERM REBECCA L. GREEGOR, formerly REBECCA L. O'DONNELL, Defendant : IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that on this date, -'EJ 1 27- , 2008, I mailed a copy of Complaint for Custody to the following person at the following address by U.S. Mail, Certified mail, postage prepaid, return receipt requested, delivered to addressee only: Rebecca L. Greegor 17 South Baltimore Street Mt. Holly Springs, PA 17065 I verify that the statements made in the foregoing Certificate of Service 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. ANDREWS & JOHNSON By: 7'ayl P. Andrews, Esq. orneys for Plaintiff 78 W. Pomfret Street Carlisle, PA 17013 (717) 243-0123 n V sue` Ch 'V tv ?, C- J p ?4-- JERRY R. HUDSON, Vs. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA REBECCA L. GREEGER, formerly REBECCA L. O'DONNELL Defendant : NO. 98-5101 CIVIL TERM IN CUSTODY PETITION FOR EMERGENCY RELIEF IN THE FORM OF AN EXPEDITED CONCILIATION CONFERENCE Petitioner, Jerry R. Hudson, by his attorney, Taylor P. Andrews, Esq., respectfully avers as follows in support of this Petition for Emergency Relief 1. With this petition Petitioner has filed a Complaint for primary physical custody of his 11 year old daughter, Ashley Rae Hudson, who has lived during the weekdays with her Mother in Mt. Holly Springs, but, who, nevertheless, has attended South Middleton Township Schools in Elementary School. A copy of the Complaint [with existing custody orders] is attached hereto as Exhibit 1. 2. It is in the best interest of Ashley Rae Hudson that she continue in the South Middleton School District for Middle School, but Defendant, Mother, Rebecca Greeger has announced plans to enroll Ashley in the Carlisle Area School District Middle School. 3. The determination of Petitioner's Custody Complaint will determine the appropriate school for Ashley. 4. In the original custody proceedings in 2000 and 2001, the conciliator was Dawn Sunday, Esq., but she has had no contact with this case since 2001. 5. The order by agreement in 2000 was signed by the Hon. Edgar B. Bayley, and the order in 2001 was singed by the Hon. Edward E. Guido. Both orders were based upon agreements and there has never been a hearing regarding custody in this case. 6. In 2000, Defendant, Mother, Rebecca Greeger was represented by Peter Russo, Esq. In 2001 she appeared pro se. Petitioner believes that she is without counsel at this time. 7. Petitioner seeks to have a resolution of this issue before the beginning of the school year if at all possible, and an expedited conciliation is therefore required. WHEREFORE, Petitioner requests the Court to expedite the scheduling of the conciliation of Petitioner's custody complaint with the earliest available conciliator without regard to whether the conciliation is again assigned to the original conciliator. Respectfully submitted, ANDREWS & JOHNSON By COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND ) I verify that the statements made in the foregoing 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. DATE: ,,7" ?- 78 West Pomfret Street Carlisle, PA 17013 Supreme Ct. #: 15641 Telephone: (717) 243-0123 JERRY R. HUDSON, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. : NO. 98-5101 CIVIL TERM REBECCA L. GREEGER, formerly REBECCA L. O'DONNELL Defendant : IN CUSTODY ORDER OF COURT AND NOW, , 2008, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at 4t' Floor, Cumberland County Courthouse, Carlisle- on the _ day of , 2008, at -:00 o'clock, p.m., for a Pre- Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: By: Custody Conciliator 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. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 EXHIBIT I 1 ? JERRY R. HUDSON, Plaintiff Vs. REBECCA L. GREEGER, formerly REBECCA L. O'DONNELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-5101 CIVIL TERM IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff, Jerry R. Hudson, is an adult individual residing at 418 Dogwood Court, Carlisle, Cumberland County, PA 17013 2. The Defendant, Rebecca L. Greeger, is an adult individual residing at 17 South Baltimore Street, Mt. Holly Springs, Cumberland County, PA 17065. 3. Plaintiff seeks custody of the following child: NAME RESIDENCE DOB AGE Ashley Rae Hudson, 17 South Baltimore Street 12/8/1996 11 yrs 7 mos. Mt. Holly Springs, PA 17065 The child was born out of wedlock. In the past 5 years the child has resided with the following persons and at the following addresses: NAME ADDRESS Rebecca L. Greeger 17 South Baltimore Street Mt. Holly Springs, PA 17065 Rebecca L. Greeger Bedford Street Carlisle, PA 17013 DATES 2005 to present approximately 2003 to 2005 The mother of the child is Rebecca L. Greeger, formerly Rebecca L. O'Donnell who currently has an address at 17 South Baltimore Street, Mt. Holly Springs, Cumberland County, PA 17065. She is married, though recently separated. The father of the child is Jerry R. Hudson who currently resides at 418 Dogwood Court, Carlisle, PA 17013. He is married. 4. The relationship of the Plaintiff to the child is that of father. The Plaintiff currently resides with the following persons: Kimberley A. Hudson, wife; Daniel Lee Hudson, son (5 yrs); and RaeAnne Hudson, daughter (3 '/z yrs). 5. The relationship of the Defendant to the child is that of mother. The Defendant currently resides with the following persons: Brett Greeger, husband (may have recently relocated); Garrett Greeger, stepson; Bailey Greeger, daughter; Evan Greeger, son. 6. Plaintiff has not participated as a party or witness, or in another capacity, in litigation concerning the custody of the child in this or another court at any docket number other than the above number. Copies of the last two custody orders in this case are attached as Exhibits 1 &2. 7. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth other than at this docket. 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. 8. The best interest and permanent welfare of the child will be served by granting the relief requested for the following reasons: A. Plaintiff is best able to provide the effective parenting and supervision that is needed by Ashley. B. Ashley has attended South Middleton Elementary School and the Defendant has now announced that she will enroll Ashley in a Middle School in the Carlisle Area School District. It is better for Ashley to stay in the South Middleton School District for Middle School with her known classmates. C. There have been numerous instances of questionable parenting of Ashley by Defendant, and Defendant's household is now destabalized by the separation of Defendant's husband from the household. D. Plaintiff and his wife have arranged for counseling for Ashley recommended by South Middleton School District staff, and Defendant has not become involved in the counseling though the opportunity to do so has been made available to her. 9. 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 the Court to modify the existing custody order by awarding primary physical custody of Ashley Rae Hudson to her father, the Plaintiff. Respectfully submitted, ANDREWS & JOHNSON By: ,PV. 'Andrews, Esq. TaXo rney for Plaintiffs West Pomfret Street Carlisle, PA 17013 Telephone: (717) 243-0123 COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. DATE: 7 z / -od' Plaintiff JERRY R. HUDSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COMITY, PENNSYLVANIA VS. : NO. 98-5101 CIVIL TERM REBECCA L. O'DONNELLr CIVIL ACTION - LAW Defendant CUSTODY ORDER OF COMM AND NOWt this day of C ?r, 2000, upon consideration of the attached Custody Conciliation Report, It is ordered and directed as follows: 1. The prior Orders of this Court dated October 29, 1998 and January 26, 2000 are vacated and replaced with this order. 2. The Father, Jerry R. Hudson and the Mother, Rebecca - L. O 'Donnell, shall -have shared legal custody - of Ashley Rae Hudson, born December 81 .1996. 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. 3. The parties shall have physical-custody of the Child in-accordance with the following schedule: A. The Father shall.have custody of the Child every weekend from . Friday after, work until Sunday evening at 6:00 p.m. B. In the event the Father works on Friday evening and cannot receive custody of the Child, the Father's period of custody shall begin on Saturday morning at 9:00 a.m. and continue through. Monday at 5:00 p.m. The Father shall give the mother as much advance notice as possible if he has to work on Friday evening. In the event the Father works on a Monday when he has custody. the Father shall transport the Child to the residence of the babysitter, Wendy Haney. C. The Father may have custody of the Child at any additional times agreed upon by the parties. D,. The Mother shall have custody of the Child at all times not otherwise specified for the Father. 4. The parties shall share or alternate having custody of the Child on holidays as arranged by agreement. The Mother shall have custody of the gild every year on Mother's Day beginning at 10:00 a.m. 5. The Father shall have custody of the Child on the Child's birthday at a time to be arranged by agreement of the parties. EXHIBIT I 6. The party receiving custody of the Child shall be responsible to provide transportation for the exchange of custody. ?. In the event either party intends to remove the Child from his or her residence for an overnight period or longer, that party shall provide the other party with a telephone number where the Gild can be reached. 8. Each party shall promptly notify'the other party of any emergency involving the health, safety or welfare of the child arising during his or her period of custody. 9. Neither of the parties, nor Ryan Ward, shall drink to the point of intoxication while in the presence of the Child. 10. The non-custodial parent shall be entitled to have reasonable telephone contact with the Child. 11. This order is entered pursuant to an agreement of the parties at a Custody Conciliation conference. The parties may modify the provisions of this order by mutual consent. In the absence of mutual consent, the terms of this order shall control. BY THE OODRT, 9 Edgar . Bayley, J. cc: James K. Jones, Esquire - Counsel for Father Peter J. Russo, Esquire - Counsel for Mother TRUE COPY FPO,,M RFC. RD In Testimony I here unto set r.y hand and t e seal of said Court at Carlisle Pa. Th' ...1(0...... y o Q.G? D othonotary r JERRY R. HUDSON, Plaintiff VS. REBECCA L. O'DONNELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-5101 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY DO- • •, •• ^d AMID NOW, this day of , 2001, upon -k (to- consideration of the attaed Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated March 15, 2000 shall continue in effect as modified by this order. 2. The parties shall share or alternate having custody of the gild on holidays as follows: A. CER S.LW: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 2:00 p.m. through Christmas Day at 2:00 p.m., and Segment B, which shall run from Christmas Day at 2:00 p.m. through December 26 at 2:00 p.m. The Father shall have custody of the Child during Segment A in odd numbered years and during Segment B in even numbered years and the Mother shall have custody during Segment A in even numbered years and during Segment B in odd numbered years. B. NWaSGIVING: The Thanksgiving holiday shall be divided into Segment A, which shall run from the Wednesday before Thanksgiving at 2:00 p.m. through Thanksgiving Day at 2:00 p.m., and Segment B, which shall run from Thanksgiving Day at 2:00 p.m. through the Friday after Thanksgiving at 2:00 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, and the Mother shall have custody during segment A in odd numbered years and during Segment B in even numbered years. C. EASIER: The Easter holiday shall be divided into Segment A, which shall run from the Saturday before Easter at 2:00 p.m. through Easter Sunday at 2:00 p.m., and Segment B, which shall run from Easter Sunday at 2:00 p.m. through the following Monday at 2:00 p.m. The Father shall have custody during Segment A in odd numbered years and during Segment B in even numbered years and the Mother shall have custody during Segment A in even numbered years and during Segment B in odd numbered years. D. ALTEmaTING 90LIDAYS: The period of custody on the foll EXHIBIT alternating holidays shall run from 9:00 a.m.,until 8:00 p.m. In even numbered years, the Mother shall have custody of the Child on New Years Day and July 4th and the Father shall have custody on memorial Day and Labor Day. In odd numbered years, the Father shall have custody of the Child on New Years Dray and July 4th and the mother shall have custody on Memorial Day and Labor Day. E. MK ZMIS DAY/FATEER'S DAY: I have custody of the Child a through the following Monday school, and the Father shall Father's Day from 9:00 a.m. morning when the Child goes to n every year, the mother shall i Mother's Day from 9:00 a.m. morning when the Child goes to have custody of the Child on through the following Monday day care. F. gALLONEE:R TRICK-CR-MM NIGHT: The Father shall have custody of the Child for Halloween -Trick-or-Treat night from 3:00 p.m. through the following morning in odd numbered years and the Mother shall have custody of the Child for the same time period in even numbered years. G. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 3. Each party shall be entitled to have custody of the Child for two non-consecutive weeks each summer. The Father shall provide notice to the Mother of the dates which he has selected for vacation by May 1 of each year and after the Father has selected his dates, the mother shall provide notice to the Father of her vacation weeks by May 15 of each year. The Mother's periods of vacation custody shall include 7 full days. The Father's periods of vacation custody shall include 5 full weekdays in addition to both the weekend immediately preceding and the weekend following the vacation weekdays. The Father's regular weekend period of custody at the end of his vacation period shall conclude on Sunday evening. The Father's periods of custody during the summer 2001 shall run from July 2 through July 6 and from August 13 through August 17. The Mother shall provide at least two weeks advance notice of the weeks she selects for vacation in 2001. 4. paragraphs 5 and 9 of this Court's.prior order are vacated. 5. 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, js/ • a cc: Taylor P. Andrews, Esquire - Counsel for Father Rebecca L. O'Donnell, Mother p m C w? (-4 E; 0 g cv ,f3 a JERRY R. HUDSON, Plaintiff VS. REBECCA L. O' DONNELL, Defendant pRICR JU=: Edgar B. Bayley : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-5101 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY CUSTODY CONCILIATION SUNKARr REPORT IN ACCORDANCE WITH CLT48ERLAND COONTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Gild who is the subject of this litigation is as follows: MME DATE OF BIM [ORRERMY IN CamDY OF Ashley Rae Hudson December 8, 1996 Mother 2. A Conciliation Conference was held on June 13, 2001, with the following individuals in attendance: The Father, Jerry R. Hudson, with his counsel, Taylor P. Andrews, Esquire, and the Mother, Rebecca L. O'Donnell, who was not represented by counsel. 3. The parties agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator JERRY R. HUDSON, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. : NO.98-5101 CIVIL TERM REBECCA L. GREEGOR, formerly REBECCA L. O'DONNELL, Defendant : IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that on this date, J Z Z 2008, I mailed a copy of Complaint for Custody to the following person at the following address by U.S. Mail, Certified mail, postage prepaid, return receipt requested, delivered to addressee only: Rebecca L. Greegor 17 South Baltimore Street Mt. Holly Springs, PA 17065 I verify that the statements made in the foregoing Certificate of Service 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. ANDREWS & JOHNSON By: Ivor P. Andrews, Esq. Attorneys for Plaintiff 78 W. Pomfret Street Carlisle, PA 17013 (717)243-0123 JERRY R. HUDSON, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. : NO.98-5101 CIVIL TERM REBECCA L. GREEGOR, formerly REBECCA L. O'DONNELL, Defendant IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that on this date, -._ O ?2" 2008, 1 mailed a copy of Petition for Special Relief to the following person at the following address by U.S. Mail, Certified mail, postage prepaid, return receipt requested, delivered to addressee only: Rebecca L. Greegor 17 South Baltimore Street Mt. Holly Springs, PA 17065 I verify that the statements made in the foregoing Certificate of Service 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. ANDREWS & JOHNSON By: G< or P. Andrews, Esq. Attorneys for Plaintiff 78 W. Pomfret Street Carlisle, PA 17013 (717) 243-0123 Y' l r ? f JUL 2 2 2008 JERRY R. HUDSON, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO.98-5101 CIVIL TERM REBECCA L. GREEGER, formerly REBECCA L. O'DONNELL Defendant IN CUSTODY ORDER OF COURT AND NOW, this d day of July, 2008, upon consideration of the attached Petition for Emergency Relief in the Form of an Expedited Conciliation, the Petition is granted as is reflected by the Order for Conciliation that is entered in this case. By: Taylor P. Andrews, Esq. for Petitioner Rebecca L. Greeger, Defendant, pro se I 5 ? ?---- ?_ ? ? v c> ? 3 o "?' ? -?- a ? ? d `?-- JERRY R. HUDSON IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. REBECCA L. GREEGER DEFENDANT 1998-5101 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, July 28, 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 Tuesday, August 05, 2008 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: /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 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 Ul 3HI i JERRY R. HUDSON, PLAINTIFF VS. REBECCA L. GREEGER, DEFENDANT : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1998-5101 : CIVIL ACTION -LAW : ACTION FOR CUSTODY ANSWER TO COMPLAINT FOR CUSTODY AND NOW, comes Respondent, Rebecca L. Greeger, (hereinafter "Mother"), by and through her counsel, Linda A. Clotfelter, Esquire, who files this Answer to Complaint for Custody, respectfully stating as follows: 1. through 7. Admitted. 8. Denied. The allegations of paragraph eight and its subparts are specifically denied. In further answer herein, it is not in the best interest and permanent welfare of the Child to grant Father primary custody. A. Denied. The implication in this paragraph that Father can more effectively parent and supervise the Child is specifically denied. In fact, in Father's home environment the Child has been hit in the face by her step-mother which is clearly not in her best interest. B. Admitted in part denied in part. It is admitted that Ashley has attended South Middleton Elementary School but it is denied that Mother made the decision to change the Child's school enrolment. Both parties were informed in early 2008 by the school district that the Child is not currently eligible for attendance in the South Middleton Elementary School. They were later informed by correspondence from the School District dated June 4, 2008, that the Child's residency required that she attend Carlisle area School District. In lite of the fact that the Child will be starting in a new school, the middle school, a change in school districts to the proper district would not be significant. In most certainly not justify a complete change in the status quo that has been in place for more than eight years. C. The allegations of this paragraph are specifically denied and any implication that Mother is unable to properly parent the Child is also denied. The Child who is of pre-teen age has been acting out on various occasions and appears to be playing the parent against one another. Due to her conduct she has at times had to be disciplined and in an attempt to assist her with these issues Mother has discussed V'Y r the matters with a School District Social Worker and despite discussions with Father that a counsellor would be mutual chosen for counselling for the Child, Father unilaterally notified and chose a counsellor without Mother's consent. Mother also made efforts to seek assistance for the Child with a gentleman at the YMCA and she has also spoken to representatives at the School District. Any destabilization within Mother's home is also denied. All married do at times have issues and given the fact that the Child's maternal grandmother died June 25, 2008, after a lengthy illness and the Child had a new brother born in July, there has been some changes within the home that appear to have motivated the Child to act out improperly as she has most recently. These are not reoccurring events within the household and Mother anticipates that she can effectively work through any issues related to them with the Child and her Father through family counselling or otherwise. D. Admitted in part and denied in part. It is admitted that Father and his wife unilaterally decided on the counselling arrangements for the Child, but is denied that this is the manner in which the counselling must be handled. In further answer hereof, upon the recommendations of South Middleton School District staff it was agreed that both parents would work together to choose and effectuate counselling for the Child. Father failed to do so and unilaterally chose a counsellor without first consulting Mother and simply had the counsellor send notice to Mother of the fact of the counselling. The Child reacted very badly when she learned of the counselling scheduled by Father and indicated to Mother that she was uncomfortable with it. As a result of the Father's conduct and making arrangements without Mother's consent and given the fact that the Child did not want to be seen by that specific counsellor, Mother did not consent. Mother does agree that the Child needs counselling and she wishes to obtain family counselling mutually agreed upon as initially discussed. 9. Admitted. WHEREFORE, Mother respectfully requests that this Honorable Court deny any request by Father to change any of the terms of the existing status quo that has been in place for more than eight years. Respectfully submitted, Date: 8 D ° LAW FIRM OF LINDA A. CLOTFELTER L da A. Clotfelter, Esquire orney I.D. No. 72963 021 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 Attorney for Defendant (717) 796-1930 Telephone (717) 796-1933 Facsimile JERRY R. HUDSON, : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 1998-5101 REBECCA L. GREEGER, CIVIL ACTION -LAW DEFENDANT ACTION FOR CUSTODY VERIFICATION I, REBECCA L. GREEGER, verify that the statements in the foregoing document are 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. § 4904, relating to unsworn falsification to authorities. Date: ( A wOo r 1 REBECCA L. GREEGER JERRY R. HUDSON, PLAINTIFF VS. REBECCA L. GREEGER, DEFENDANT : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1998-5101 CIVIL ACTION -LAW ACTION FOR CUSTODY CERTIFICATE OF SERVICE AND NOW, on this 1 fday of August, 2008, the undersigned hereby certifies that a true and correct copy of the foregoing ANSWER TO COMPLAINT FOR CUSTODY was served upon the interested parties by Facsimile and United States First Class Mail, postage prepaid and addressed as follows: Taylor P. Andrews, Esquire 78 W. Pomfret Street Carlisle, PA 17013 Respectfully Submitted, LAW FIRM OF LINDA A. CLOTFELTER Mechanicsburg, PA 17050 (717) 796-1930 telephone (717) 796-1933 facsimile °? =v ?? tom„ -,7 ,. . -? ,: C=..? i't7 ?7 -?.. 7'?- n? >':?` 1 ...... r. `t- i ^ ?, G?4 ::? JERRY R. HUDSON, PLAINTIFF VS. REBECCA L. GREEGER, DEFENDANT : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1998-5101 CIVIL ACTION -LAW ACTION FOR CUSTODY ANSWER TO PETITION FOR EMERGENCY RELIEF AND NOW, comes Respondent, Rebecca L. Greeger, by and through her counsel, Linda A. Clotfelter, Esquire, who respectfully responds to Petitioner's Petition for Emergency Relief in a form of an expedited Conciliation Conference as follows: 1. Admitted in part and denied in part. It is admitted that a Complaint for Custody was filed but it is denied that the Complaint was necessary. And in further answer hereof, upon information and belief the proper request for the facts of this case should have been made in a Petition to Modify the prior Order of Custody. Any remaining allegations of the paragraph are admitted except that the Complaint and its exhibits are documents that speak for themselves. 2. Denied. It is denied that Mother took any steps to change the Child's School District. In further answer hereof, the parties were notified in early in 2008 that the residency requirements for the Districts mandated that the Child attend Carlisle area School District. This directive was confirmed in correspondence from the South Middleton School District dated June 4, 2008, a copy of which is attached. This correspondence was received by both parties and gave them more than adequate notice of the potential issue. It is further denied that the change in school districts as mandated by school district policies would be negative for the Child. The Child was scheduled to begin attending a new school in the fall due to a change in the middle school and the Child will be attending with many friends she knows from her own neighbourhood. Any allegation that Father's request is an emergency is adamantly denied. The C parties both had several months notice of the issue and as such the court should not have to deal with it as a last minute effort in an attempt to coheres Mother to change status quo that has been in place for more than eight years. 3. Denied. It is denied that a Custody Complaint is proper under the situation and any implication therein that the Carlisle School District is in any way inappropriate for the Child is also denied. Please see response to paragraph two, above. 4. Admitted. 5. Admitted. 6. Admitted in part and denied in part. It is admitted that Mother had prior counsel but it is denied that she is pro se at this time. As is evident from Mother's answer to the Complaint and answer to this Emergency Petition she is now represented by Linda A. Clotfelter, Esquire. 7. Denied. It is denied that this matter is a true emergency. Both parties had notice of the issue early in 2008 and it was confirmed in correspondence from the school district to both parties in early June, 2008. Father is now attempting to make this matter an emergency request when in fact he should have filed a Petition to Modify Custody earlier in the year when he had notice of this issue. Thus, the parties should comply with state regulations and school district policies such that under the terms of the current Order of Court and the status quo that has been in place since 2000, the Child must attend Carlisle Area School District until the court can hear this matter and determine a custody situation that is in the best interest of the Child. WHEREFORE, Respondent respectfully requests that this Honorable Court deny Father's Emergency Petition. Date: NiAlat- Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER ---- --- _..-9 1VV Mechanicsburg, PA 17050 Attorney for Defendant (717) 796-1930 Telephone (717) 796-1933 Facsimile JERRY R. HUDSON, : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 1998-5101 REBECCA L. GREEGER, : CIVIL ACTION -LAW DEFENDANT ACTION FOR CUSTODY VERIFICATION I, REBECCA L. GREEGER, verify that the statements in the foregoing document are 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. § 4904, relating to unsworn falsification to authorities. Date: ( Ab- 6?od 0 R&wa x - REBECCA L. GREEGER JERRY R. HUDSON, PLAINTIFF VS. REBECCA L. GREEGER, DEFENDANT : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1998-5101 CIVIL ACTION -LAW ACTION FOR CUSTODY CERTIFICATE OF SERVICE 4+4 day of August, 2008, the undersigned hereby certifies that a true AND NOW, on this I p and correct copy of the foregoing ANSWER TO PETITION FOR EMERGENCY RELIEF was served upon the interested parties by Facsimile and United States First Class Mail, postage prepaid and addressed as follows: Taylor P. Andrews, Esquire 200 North Hanover Street Carlisle, PA 17013 B Respectfully Submitted, LAW FIRM OF LINDA A. CLOTFELTER Li a A. Clotfelter, Esquire Attrney ID No. 72963 X50 1 East Trindle Road, Suite 1 Mechanicsburg, PA 17050 (717) 796-1930 telephone (717) 796-1933 facsimile -.? f ?.3 t ?? „Z _ C„ S e?7 r .:? "T'7 . , ? ; ? t?`? f ?.,.. ? ? ?.??:? `Ti Zs - ^' n°. 1"°x.1 „' _ _ t.° ?;? AUG 18 2008 JERRY R. HUDSON IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 98-5101 CIVIL ACTION LAW REBECCA L. GREEGER, formerly REBECCA L. O'DONNELL Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of 2008, upon consideration of the attached Custody Conciliation Report, it is ordered 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 between the parties. The purpose of the evaluation shall be to obtain independent professional recommendations concerning ongoing custody arrangements which will best meet the needs of the Child. The parties shall sign any authorizations deemed necessary by the evaluator in order to obtain additional information pertaining to the parties or the Child. All costs of the evaluation shall be shared equally between the parties. 2. Pending completion of the evaluation and further Order of Court or agreement of the parties, the prior Orders of this Court in this matter shall continue in effect. 3. Within sixty (60) days of receipt of the written custody recommendations, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference, if necessary. cc /aylor P. Andrews, Esquire - Counsel for Father ,/inda A. Clotfelter, Esquire - Counsel for Mother, A 3 Edward E. Guido J. VINVt11ASNN'4d ,mno ?' :Ol WV OZ 5nv goon 10 H.- O-031(.3 W JERRY R.14UDSON Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. REBECCA L. GREEGER, formerly REBECCA L. O'DONNELL Defendant Prior Judge: Edward E. Guido 98-5101 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 Ashley Rae Hudson December 8, 1996 Mother/Father 2. A custody conciliation conference was held on August 13, 2008, with the following individuals in attendance: the Father, Jerry R. Hudson, with his counsel, Taylor P. Andrews, Esquire, and the Mother, Rebecca L. Greeger, with her counsel, Linda A. Clotfelter, Esquire. 3. The parties agreed to entry of an Order in the form as attached. f /-7 oo?P' Date Dawn S. Sunday, Esquire Custody Conciliator JUL 2 7 2009 (1 JERRY R. HUDSON Plaintiff vs. REBECCA L. GREEGER, formerly REBECCA L. O'DONNELL Defendant IN THE COURT OF COMMON PLEAS OF `-? CUMBERLAND COUNTY, PENNSYLVANIA 98-5101 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this ?0 day of %7m?? , 2009, upon consideration of the attached Custody Conciliation eport, it is ordered and directed as follows: A hearing is scheduled in Court Room No. 3 in the Cumberland County Court House on the 3d day of , 2009, at/,'00 o'clock J m., at which time testimony will be taken. For purposes of the hearing, the Father, Jerry R. Hudson, shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who are expected to testify and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least 10 days prior to the hearing date. BY THE , Edward E. Guido J. cc: ? for P. Andrews, Esquire - Counsel for Father LiYnda A. Clotfelter, Esquire - Counsel for Mother yes LL 7 31/0Q ",afq j-E F,? tE i?r OF TH 20 09 "t-IL 3 I A'°'i ;. 1 JERRY R. HUDSON Plaintiff VS. REBECCA L. GREEGER, formerly REBECCA L. O'DONNELL Defendant Prior Judge: Edward E. Guido IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 98-5101 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 Ashley Rae Hudson December 8, 1996 Mother/Father 2. A custody conciliation conference was held on July 22, 2009, with the following individuals in attendance: the Father, Jerry R. Hudson, with his counsel, Taylor P. Andrews, Esquire, and the Mother, Rebecca L. Greeger, with her counsel, Linda A. Clotfelter, Esquire. 3. The Father previously filed a Petition for Custody and a Petition for Emergency Relief on which a custody conciliation conference was held in August 2008. The emergency relief was sought because the Child had been attending South Middleton school and, as she was residing with the Mother during the week, the Mother planned to enroll her in the Carlisle school at the beginning of the 2008- 2009 school year. The Father sought to prevent the change of school districts for the Child. At that time the Father sought primary physical custody of the Child. As a result of the conference, the parties agreed to obtain a custody evaluation from Stanley Schneider, PhD. The custody evaluation was completed in June 2009 and the follow-up custody conciliation conference was held on July 22, 2009. The Father continues to seek primary physical custody as recommended by the custody evaluator. The parties were not able to reach an agreement at the conference and it will be necessary to schedule a hearing. 4. The Father's position on custody is as follows: The Father believes it is in the best interests of the Child to reside primarily with him and to return to the South Middleton School District where she was enrolled prior to the last school year. The Father believes that he is better able to parent the Child and to meet her current emotional and educational needs. The Father alleged that the Child spends much of her time providing care for her half siblings in the Mother's household while the Mother is working. The Father believes the Child should have more free time at her age and not be required to have that much responsibility. The Father indicated that the Child has expressed a strong desire to reside in the Father's household and return to the South Middleton School District. 5. The Mother's position on custody is as follows: The Mother feels it would be best for the Child to alternate weeks with the parties so that she is spending as much time as possible with each of them. The Mother believes that the Child has a preference to reside with each of them on an equal basis. The Mother feels it is best for the Child to remain in the Carlisle School District as she was beginning to adjust to the new school and has made some new friends. The Mother believes that the Child is being influenced inappropriately by the Father and his wife to express a preference to live with them. The Mother did not feel that she had an opportunity to adequately express her views on the Child's interests with the custody evaluator. 6. The conciliator recommends an Order in the form as attached scheduling a hearing in this matter. It should be noted that an expedited hearing is requested due to the school issue. The custody evaluation was initiated in July 2008 but was not completed until last month due to various issues which had arisen. It is anticipated that the hearing will require at least a half day and the Father's counsel indicated that he does plan to present the testimony of the custody evaluator and possibly the Child's counselor. The Mother's counsel has not identified expert witnesses at this time but may do so prior to the hearing. Date Dawn S. Sunday, Esquire Custody Conciliator JERRY R. HUDSON, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO.98-5101 CIVIL TERM REBECCA L. GREEGER, Defendant : IN CUSTODY PETITION FOR EMERGENCY RELIEF IN THE FORM OF A TEMPORARY AWARD OF PRMARY CUSTODY TO PETITIONER PENDING FINAL HEARING Petitioner, Jerry R. Hudson, by his attorney, Taylor P. Andrews, Esq., respectfully avers as follows in support of this Petition for Emergency Relief: 1. On July 22, 2008 Petitioner filed a Complaint for primary physical custody of his 12 year old daughter, Ashley Rae Hudson. 2. This Complaint was in response to the announcement by Rebecca Greeger that she would enroll Ashley Rae Hudson in the Carlisle Schools for the 2008-09 school year rather than the South Middleton Schools that Ashley had been attending. 3. A Petition for Special Relief was also filed with the Custody Complaint in July 2008 in an effort to expedite the process to get a decision in time for the commencement of school. The relief requested in the 2008 Petition for Special Relief was an expedited conciliation. 4. The 2008 complaint was conciliated by Dawn Sunday, Esq. on August 13, 2008, and it was then agreed by the parties that there would be a custody evaluation with a return to conciliation after completion of the evaluation. Primary custody remained with Rebecca Greeger and Ashley Rae Hudson was enrolled in the Carlisle Schools in September 2008. 5. Dr. Stanley Schneider was retained by the parties to perform the custody evaluation. He distributed his 13 page report dated June 4, 2009 in June 2009. Petitioner immediately sought conciliation and a conciliation conference was held with Dawn Sunday, Esq. on July 22, 2009. [a copy of Dr. Schneider's report is attached hereto] 6. Despite Dr. Schneider's recommendation that Ashley Rae Hudson live primarily with her Father, the Petitioner, and thereby attend the South Middleton schools, no agreement was reached at the conciliation. Mother, Rebecca Greeger contended that Ashley no longer wanted to live primarily with her father and attend South Middleton Schools. 7. Conciliator Dawn Sunday, Esq. filed her conciliator's report on July 22"d and recommended a Court date as early as possible because of the school issue and the imminence of the beginning of the school year. 8. The Court has scheduled a hearing on Petitioner's complaint for September 3, 2009 at 1:00 PM. 9. Petitioner has determined that Dr. Stanley Schneider is out of town and unavailable to attend a hearing on September 3`a, and that he will not return to the area until September 10, 2009. He would be available for testimony by telephone on September 3`a 10. Mother, by her attorney, Linda A. Clotfelter, Esq., does not agree to proceed with testimony from Dr. Schneider by telephone. 11. The first day of school for students in the South Middleton School District for 2009-10 is Tuesday, August 25, 2009. The first day of school for students in the Carlisle Area School District for 2009-10 is August 31, 2009. 12. In order for Petitioner to enroll Ashley Rae Hudson in the South Middleton Schools, Petitioner must have primary physical custody of Ashley and Petitioner must live in the school district. Petitioner does live in the school district. 13. To reduce the risk of the need to change schools after the school year has started, Petitioner seeks a temporary and interim order giving primary physical custody of Ashley Rae Hudson to Father/Petitioner pending a rescheduled hearing where Dr. Schneider will be available to testify. 14. Petitioner invites the Court to schedule a very brief hearing on this Petition for Special Relief where the Court could investigate whether Ashley Rae Hudson still wants to live with her Father and attend the South Middleton Schools by interviewing Ashley Rae Hudson. 15. Defendant, through her counsel, Linda A. Clotfelter, Esq. does not concur in this requested relief. WHEREFORE, Petitioner requests the Court to continue the custody hearing scheduled for September to a date when Dr. Schneider will be available, and, furthermore, to grant primary physical custody of Ashley Rae Hudson to Father/Petitioner pending a final hearing so that her enrollment in the South Middleton Schools may be facilitated. Respectfully submitted, ANDREWS & JOHNSO By: Ta P. Andrews, Esq. Attorney for Plaintiffs 78 West Pomfret Street Carlisle, PA 17013 Supreme Ct. #: 15641 Telephone: (717) 243-0123 GUIDANCE ASSOCIATES OF PENNSYLVANIA 412 Erford Road, Camp Hill, PA 17011 (717) 732-2917; FAX: (717) 732-5375 Stanley E. Schneider, Ed.D. 20 Briarcrest Square, Suite 205, Hershey, PA 17033 (717) 533-4312 Director June 4, 2009 Taylor T. Andrews, Esquire 78 West Pomfret Street Carlisle, PA 17013 Linda A. Clodelter, Esquire 5021 East Trindle Road Suite 100 Mechanicsburg, PA 17050 RE: HUDSON V. GREEGER Cumberland County #: 98-5101 Dear Attorneys: I am sending my findings and recommendations regarding Ashley, D.O.B. December 8, 1996, age 12 Y2. Jerry Hudson, father, was seen on the following dates: November 4, 2008, November 11, 2008 and March 5, 2009. He was administered a number of custody related instruments including a life history questionnaire; parents' interview form; two personality inventories, the MMPI-2 and the MCMI-III. Rebecca Greeger was seen October 28, 2008, January 27, 2009,; February 26, 2009, March 11, 2009 (telephone call), March 19, 2009 and March 26, 2009 (telephone call). She completed custody related instruments. Kim Hudson, stepmother, was seen on November 4, 2008; November 24, 2008 and March 5, 2009. She also completed custody related instruments. Ashley was seen on separate occasions when brought in by each parent. She was seen with her father on November 11, 2008 and March 26, 2009. She was seen with her mother on November 13, 2008, January 13, 2009 and March 19, 2009. Brett Greeger was interview on January 29, 2009. In addition to the above, I reviewed the following: RE: Hudson v. Greeger ATTORNEY CORRESPONDENCE: Page 2 • August through September - emails between Attorney Clotfelter and Attorney Andrews. • September 10, 2008 - letter from Attorney Andrews to Attorney Sunday. • September 11, 2008 - email from Attorney Sunday (conciliated) to Attorney Andrews. • September 16, 2008 - letter from Attorney Andrews to Dr. Schneider. • September 23, 2008 - letter from Attorney Clotfelter to Dr. Schneider. POLICE REPORT: • October 4, 2008 - Carlisle Police report regarding sexual touching at school. • November 15, 2008 - Mt. Holly Springs Police report. PLEADINGS: • July 22, 2008 - Jerry's petition for emergency relief. • July 22, 2008 - Jerry's custody complaint with copies of the March 15, 2000 court order June 14, 2001 conciliation summary June 19, 2001 court order. • July 28, 2008 - court order • August 12, 2008 - Rebecca's answer to custody complaint. • August 12, 2008 - Rebecca's answer to Jerry's petition for emergency relief. • August 13, 2008 - custody conciliation summary report. • August 20, 2008 - court order. OTHER INFORMATION: • June 4, 2008 - letter from South Middleton School District to Rebecca which noted that since Rebecca was identified as the primary custodian and lives in Carlisle, Ashley must be enrolled in the Carlisle Area School District. • March 2, 2008 - letter from Cumberland County Children and Youth to Jerry and Rebecca - the agency suggested that Rebecca follow the safety plan (requested, not received) and not use physical discipline on her children. • November 16, 2008 - letter from Brenda Garland, Ashley's former Sunday school teacher at Otterbein United Methodist Church. • November 21, 2008 - Alleghany Optical, LLC - Ashley covered by Jerry's insurance (2007). • November 18, 2008 -William J. Phelan, M.D. -Ashley has appointments for immunizations and has been a patient of Phelan's since 2000. RE: Hudson v. Greeger Page 3 • November 17, 2008 - J. Aaron Mowery, DMD - Ashley's dentist since March, 2001. • March 18, 2009 - seven page fax from Jerry. • December 15, 2008 - letter from Rev. Fr. Donald L. March, rector in support of his niece and Goddaughter, Rebecca. • March 16, 2009 - letter from Heidi Carbaugh in support of Rebecca. • March 30, 2009 - fax from Rebecca to Dr. Schneider with copies of attorney's correspondence of March 25, 2009 and March 27, 2009. • September 2007 through August 2008 - Kim's calendar. • November 16, 2008 - Jerry's file notes. • December 12, 2008 - receipt for Pepcid (for Ashley). • 2007 - 2009 - Kim's journal (38 pages). • January 2007 through May 2008 -12 checks signed by Kim on Ashley's behalf. • February 27, 2009 - receipt from Dr. Phelan's office regarding immunizations for Ashley. • Letters from Carolyn Kuntz and Bill and Linda Pipp in support of Rebecca. • November 11, 2008 - Kim's response to "why you and Jerry want custody now" (8 pages). • November 24, 2008 - Jefrs concerns regarding Rebecca (3 pages). With respect to Ashley, I reviewed the following: LETTERS / EMAILS: • February 24, 2009 - letters and emails between Rebecca and Jamie Morrow, Ashley's reading and math teacher. • December 16, 2008 - Ms. Morrow's email to Rebecca expressing concerns regarding Ashley's incomplete homework assignments. • February 23, 2009 - Rebecca's response to Ms. Morrow's email of December - (NOTE: Ashley involved in homework club with Rebecca monitoring homework completion). • February 25, 2009 and March 24, 2009 - Power School attendance sheet / grades. • February 3, 2009 - letter from Ms. Morrow to Jerry Hudson (NOTE: although Ms. Morrow commented about a drop in Ashley's grades, she described Ashley as very well behaved, participates in class discussion and is liked by peers). • February 25, 2009 - letter from Attorney Andrews to Dr. Schneider with copy of the February 23, 2009 letter. • May 27, 2008 - email from Ashley to Kim. • July 6, 2008 - email from Ashley to Kayla (friend). • Letter from Lamberton Middle School indicating that Jerry and Kim attended the Back to School night on September 18, 2009. RE: Hudson v. Greeger TELEPHONE CONTACTS: Page 4 • July 14, 2008 and January 9, 2009 - with Elmer Barrick, school counselor. Mr. Barrick was familiar with Ashley in the 4th and 5th grades. He described Ashley as a good kid, a good student, responsible kid with no behavior problems. She was very vocal expressing her negativity toward her mother. Mr. Barrick related that he suggested family counseling. Ashley was referred to the school social worker. He further noted that in grades 1-3, Ashley was "not high on the radar." In my conversation with Mr. Barrick on January 9, 2009, he clarified that his recommendation for counseling was not necessarily to be ongoing treatment but that a therapist could provide a safety net on an as needed basis, especially during the summer between her transfer from South Middleton to Carlisle School District. • November 14, 2008 - telephone call from Ann Shover, guidance counselor, for the 6th graders at Lamberton. She sees Ashley as a normal 6th grader who fit in with her peers, has socially acclimated and is no behavior problem, but makes it known that she does not want to be at Lamberton. Ms. Shover further related that Rebecca has not attended parent conferences, which occur typically during the day with a small section occurring at night. Ms. Shover did indicate that Rebecca did respond identifying that she did not want to attend the conference. • January 13, 2009 and June 1, 2009 - with Sue Heath, LCSW, DCSW, RPT-S, Ashley's therapist. Ms. Heath sees Ashley as an insightful, mature, well-spoken 12 year old. She has been helping Ashley deal with parental tension, the reported sexual incident by a peer at school and Ashley's change in school placement. Ms. Heath has had no contact with Rebecca but invited her to contact Ms. Heath. With consistency, Ashley sees her father and stepmother allowing her to be a kid and further, that Ashley feels safe in their home. Other information reflects Ashley presenting a number of reasons supporting her strong and continuing preference to live with her father and stepmother. Ashley also shared concerns about her mother. Ashley really wants to return to South Middleton School District to be closer to her long-standing friends. Ashley, of late, pays closer attention to her school work so that she can be in good standing if she returns to South Middleton next year for the 7th grade. Ms. Heath also noted that Ashley is involved with the youth group at her father's church and is active in the group on her father's weekend time. She further related that Ashley is very comfortable confiding in Kim (stepmother). • November 7, 2008 - report card, first marking period from Lamberton. Teacher comments: pleasure to have in class, participates readily in class, cooperates with others. • February 27, 2009 - interim report. • Explanation of Benefits (EOB) from Mock Mays Associates - September, 2008. RE: Hudson v. Greeger Page 5 • Nine photographs reportedly of rooms in Rebecca's home. JERRY (ISSUES AND CONCERNS): Jerry is a 34 year old dock worker with ABF. He has flex hours. Jerry presented as very concerned about Ashley's welfare. However, he was more comfortable deferring to Kim to present his case. Jerry presents his and Kim's household and their relationship to be very stable. He and Kim have been married eight years and have a good relationship. He says that Rebecca has a history of multiple men in her life, noting himself, Justin, Ryan, Brett and now Josh. Jerry expressed concern about Rebecca reportedly allowing Ashley to drink alcohol - however minimal it may be. He further noted Rebecca residing in ten different places, reflecting in his opinion her instability in the last approximate decade. He reports that Rebecca will reportedly tell Ashley to go live with him and Kim and if Ashley does do so, that Rebecca would relinquish her parenting rights should Jerry file for child support. Jerry wants to shield Ashley from Rebecca's relationship with her next door neighbor. Ashley is aware of the intimate relationship her mother and this neighbor man have. She has seen both in bed (clothed). Jerry reported that Rebecca is spending time at the neighbor's house, leaving Ashley to babysit / supervise her younger half-siblings. Jerry would like to provide relief from the mother/daughter tensions and arguments. He sees Ashley relating more calmly with him and with Kim (stepmother). He wishes to allow Kim to return to South Middleton School District where she has spent the majority of her school historically. He and Kim provide for Ashley's medical and dental care and further questions Rebecca's disciplinary methods being appropriate. Given Ashley's age, he sees Rebecca using threats, being verbally abusive and threatening as inappropriate. Jerry sees himself as a responsible, dedicated, caring and dependable father who, in his opinion, is better able to meet Ashley's needs as she matures into adolescence. Jerry presents his family of origin as a very loving and supportive family. There is no evidence of any dysfunction, abuse, neglect or substance abuse. Jerry has a good work ethic. He struggled academically and continues to do so. He may have some kind of reading problem so that his personality inventories are questionable in terms of their results. Concerning his family, he was able confide in both parents and, in retrospect, would change nothing regarding how his parents raised him. Jerry's validity scales on his MMPI reflect his denying minor character flaw symptoms or any negative traits or attitudes. It is typical for those involved in child custody RE: Hudson v. Greeger Page 6 evaluation to have elevated scores in the validity section for purposes of impression management. However, Jerry's scores are more elevated than the norm. This suggests naivet6, a lack of sophistication on his part or problems understanding the questions. As a result of his validity scale pattern, his clinical scales and other scales are suppressed and are therefore likely to be compromised. However, no one involved in this evaluation reports any concerns about Jerry's emotional functioning or mental health status. His MCMI-III responses suggest the need for social approval and/or naivete about psychological matters. His profile is suggestive of a man who can be over-reactive, unreflective and immature but who sees himself as a socially stimulating and charming person. There are no diagnoses associated with either personality inventory. Jerry wrote that he does not feel that Rebecca has ever been a good role model in many ways. In addition to her lifestyle of many jobs, homes and relationships, he believes that Rebecca does not put Ashley's school work as a priority. He criticises Rebecca for not attending Ashley's back to school nights or parent-teacher conferences. He notes that Rebecca dropped out of high school, later obtained her GED but does not believe that she provides a good attitude towards the importance of school for Ashley. REBECCA (ISSUES AND CONCERNS): Rebecca is a 31 year old office manager at a local radio station. She works for and with her maternal grandmother. Rebecca was open, honest and very aware of Ashley's feelings and Jerry's and Kim's concerns. In the summer of 2008, Rebecca dealt with a number of significant life events. Her biological mother died in June; Rebecca was her primary caretaker. This set of events impacted her relationship with Brett Greeger, resulting in their separation, which Rebecca is also dealing with. They separated after approximately 16 months of marriage. Further, Rebecca was advised by the South Middleton School District that Ashley needed to transfer to the Carlisle School District because Rebecca was identified as the primary physical custodian. Rebecca is fully aware of Ashley's continued preference to return to South Middleton School District. She admitted that Ashley can be mildly oppositional and/or openly defiant toward her, challenging Rebecca with some increasing consistency over the months. Ashley was becoming more uncooperative and noncompliant with Rebecca, who "swatted her on her butt." This resulted in a report to Children and Youth by the school counselor. Ashley reported this to school personnel. A second Children and RE: Hudson v. Greeger Page 7 Youth involvement occurred when Ashley reported changed clothing in front of Brett. Both incidents were unfounded by the agency. Historically, Rebecca was the primary physical custodian on weekdays with Jerry having partial custody every weekend. Once Ashley began school, Rebecca would drop Ashley at Jerry's, whose address was used so that she could attend South Middleton School District. Rebecca admits to a number of moves, living with Jerry and his parents, her maternal grandmother, subsequently having a number of short-term leases. In addition, she admits engaging in a number of serial monogamous relationships until she met Brett in the spring of 2000, marrying him in 2007. She and Brett moved to Carlisle. She has not moved in a number of years. Ashley continued to attend her school in the South Middleton School District. Jerry requested to become the primary physical custodian, which Rebecca attributes to his being upset with Ashley's school change. Rebecca is quick to admit the challenges she has dealing with four children, two of whom are involved with the Carlisle School District, with her baby still at home. Ashley attended Rice Elementary School from kindergarten through 3`d, 4th and 5th grade at Iron Forge, with her now completing her 6th grade at Lamberton. During this current 6th grade year, Ashley struggled academically because of her not completing homework. As of late, according to Sue Heath, Ashley's counselor, Ashley has focused more on improving her grades with her full intent of wanting to transfer back to South Middleton. Rebecca has attempted to work with school personnel at Lamberton, monitoring Ashley's grades closely and supporting Ashley's involvement in a homework group. In spite of all this, Rebecca knows that Ashley continues to want to live full time with her father and stepmother. She is aware that Ashley wants to return to South Middleton where her friends are. She is aware that Ashley has maintained close contact and communication with her long-standing friends. Although Ashley has acclimated to Lamberton, Ashley continues to be challenging and disrespectful toward Rebecca. Rebecca is very aware that she is in a bind - if she disciplines Ashley, Rebecca believes that Ashley will embellish and report back to Jerry and Kim that she is a mean mother. She may also report whatever may occur to school personnel. If Rebecca does not discipline, she runs the risk of being described as too lenient. Rebecca is aware of Ashley's discomfort with her (Rebecca's) relationship with the next door neighbor, age 21-22. Rebecca admits to open displays of affection with her male friend in front of the children, including Ashley. Rebecca believes that both Jerry and Kim are manipulating Ashley. She further indicated that her relationship with Ashley was very good until Rebecca's mother RE: Hudson v. Greeger Page 8 became ill with cancer. The birth of Rebecca's youngest child, Evan, also impacted Rebecca, as did the separation between Rebecca and Brett. Ashley has to deal with these stressors and was also upset with the school change. Rebecca made other statements and assertions and was asked to elaborate or explain, as part of her homework, areas related to her statement that she needs to protect Ashley; and was asked to identify more comprehensively her perception of Ashley's strong preference to live with her father and stepmother. She was also going to further elaborate the impact of the separation between her and Brett had on Ashley, what led to that, as well as the relationship that Rebecca has with her next door neighbor / friend. In my telephone conversation with her on March 11, 2009, Rebecca admitted that she did not have time to complete her homework assignments. In March of 2009, Rebecca described Ashley as more deceitful regarding her homework completion. Rebecca's personality test results showed a distinct tendency toward avoiding self disclosure. Her profile is reflective of two groups of patients - a well functioning "normal" person without any major personality disturbance, who is experiencing psychosocial stressors, or a person with evidence of personality dysfunction. Regardless, results are suggestive of Rebecca having characteristics consistent with obsessive compulsive traits and features; however, Rebecca presents to this clinician as more of a procrastinator. Rebecca was raised by her mother and maternal grandmother. Her biological father died when Rebecca was a child. Her mother married four times and divorced four times. Rebecca lived in California, Pennsylvania and lived primarily with her maternal grandmother during her school years. She became pregnant in high school and had a number of relationships with males. Rebecca's "mainstay" is her maternal grandmother with whom she works. Rebecca noted that neither her mother or her maternal grandmother were affectionate as Rebecca was growing up. Her biological mother was not involved highly in Rebecca's life. Rebecca believes that the current custodial arrangement is working well and that Ashley is being emotionally manipulated by Jerry and Kim. She acknowledges, however, that Ashley is upset about Rebecca's separation from Brett, her involvement with the next door neighbor, and believes that Ashley's strength is her being "very mature for her age." As a parent, she identified struggling to balance work and family and found discipline versus punishment as challenging concerning the children. KIM (ISSUES AND CONCERNS): Kim presents as the more able partner in presenting and explaining, as well as elaborating hers and Jerry's position regarding why they believe Ashley should reside RE: Hudson v. Greeger Page 9 primarily with them. She presents both of their concerns with some repetition which I paraphrase below. Her issues are somewhat repetitive of Jerry's and are: • Rebecca has allowed Ashley to drink alcohol on several occasions through the summer (2008). • Rebecca leaves Ashley alone overnight to care for her two younger half-siblings so that she (Rebecca) can be with her boyfriend, go to a bar, work or go shopping. • Rebecca has no stable home life; she has a history of multiple relationships. • Rebecca tells Ashley she does not want her and calls her name (e.g. liar, bitch). • Rebecca is a poor role model, having a relationship outside of her marriage. • Rebecca burdens Ashley with numerous chores. • Rebecca has taken Ashley's cell phone. • Rebecca threatens Ashley with reducing time and/or partial custody with Jerry if Ashley's room is cluttered. • Rebecca has reportedly said to Jerry, in front of Ashley, that she (Rebecca) was signing her rights off if Jerry sought child support. • Rebecca abuses alcohol. • Rebecca mentioned relocating to Florida if she maintains primary physical custody, which has unsettled Ashley. • Rebecca does not allow Ashley to participate in extracurricular activities. • Rebecca does not attend parent-teacher meetings. • Rebecca refused to participate in family counseling recommended by the school and Mock Mays. • Ashley is aware of her mother's ongoing relationship with a next door neighbor. • Historically, Ashley had to adjust to new environments because of Rebecca's multiple moves over the years. Kim is unaware of any concerns Rebecca may have of her as a stepparent. Kim has been in Ashley's life for 11 of Ashley's 12+ years. Kim makes clear the boundaries between herself as a stepmother and tries generally to be respectful of Rebecca's role and rights as Ashley's mother. Kim's experiences in her family of origin were positive. She received lots of love and support being the youngest of three. She wrote very positively about her parents and they were there for her on an ongoing basis. Academically, she was an average student with no pattern of detentions. There is no evidence of any substance abuse. Her credit is good and she has a positive work history. Kim received her Bachelor of Science in Sociology and has been working in the day care field since 1998 and has been a director of a day care center since 2000, currently supervising 10 people. She and Jerry coordinate in getting their son on the bus in the morning and their daughter RE: Hudson v. Greeger Page 10 goes to daycare with Kim. Kim works from 6:15 AM to 2:50 PM and is home after work. Kim says that Ashley has developed a close, trusting relationship with her over the years. Currently, either she or Jerry would be home daily after school to ensure Ashley's homework is completed. Kim's child management techniques reflect consistency, openness and a democratic style. She would tend to listen to what children have to say, evidences a fairness and empathy with using natural rewards and consequences as disciplinary techniques. She presents with a good understanding of child growth and developmental needs. Kim's personality profile validity scales were all within normal limits with an acceptable level of defensiveness (self-protectiveness). There is an appropriate balance between self-protectiveness and self-disclosure. Kimberly endorsed items reflecting a positive perception in human goodness, patience and contentment with life. There were no elevations on her clinical scales. Her pattern is consistent with an individual who has concerns about and toward family members, which are often rationalized. All content scales were also within normal limits reflecting no debilitating fears, anxieties, depression or health concerns, which would impact her ability to parent. She may tend to repress strong feelings and emotions. She has good ego strength to meet the needs and typical demands of living, including the pressures and responsibilities of work and parenting. She presents as a responsible person who may also have difficulty expressing anger, annoyances and irritations. She may have health concerns and converts some symptoms into physical areas; however, she did not note any physical problems in her personal medical history completed upon intake. BRETT: Brett Greeger was seen on January 29, 2009. He is not involved with Ashley having separated from Rebecca. Brett related that he has filed for divorce, wanting equal 50/50 custody of his and Rebecca's two children. He related that he and Rebecca met in April of 2000, were together two years, had one child, broke up, reconciled and married in 2007. Asked what happened to the marriage, he related that Rebecca became 'other - directed' in that she cared for her mother on a daily basis, running back and forth between work, home, Hershey Medical Center and Harrisburg Hospital. He RE: Hudson v. Greeger Page 11 recognizes this put a strain on the marriage. He presented himself as being patient, understanding and supportive of Rebecca during this time. Brett also indicated that Ashley is aware of her mother's inappropriate behavior with the next door neighbor and is bothered by it. He related that he moved out with his son, Garrett (age 9), and relocated to his parents' home. He reported that three days after he left, Rebecca admitted to sleeping with the next door neighbor, which is something she had not admitted to previously. Brett came to Rebecca's defense indicating that "she is not a bad mother ...she is not a pushover... she is usually not physical but there was one incident where she used a belt." Brett also related that prior to more recent events, Ashley expressed feelings of not wanting to live with her father. I asked Brett why Ashley, in his opinion, is so adamant wanting to live with her father and stepmother, he replied that "the stability is not there now that I am not there." He further related that Ashley is disgusted with her mother because of the next door neighbor, but also indicated that Ashley "will tell each parent different things." Regarding the incident where Ashley allegedly had to change clothing in front of Brett, he believes that Ashley was "put up to it." Brett also related that Rebecca "does not get the big picture." He sees Rebecca as seeing a loss should Ashley live with her father and not recognizing that Ashley may want to live with her father and stepmother at this time with a possible eventual return to Rebecca. He is aware that Ashley has basically known both families for most of her years. From his knowledge, he sees both homes as adequate for Ashley. Brett also noted that Rebecca has not moved in the last five years. Prior to Brett and Rebecca becoming involved, she did live in a number of places. Asked if he observed any conflict or confrontation between mother and daughter, he said "some... normal stuff." He knows nothing about Rebecca serving Ashley any beer but referred to a Memorial Day where Ashley might have sneaked a sip of someone else's beer. Regarding Rebecca's posture toward parenting, Brett said "if you don't like my rules and don't follow them, you're free to go live with your father." Brett related that he heard Rebecca say this to Ashley. He described her parenting as a "no nonsense, tough-love type approach (with her parenting) with good motives." Brett indicated that Rebecca has been the primary physical custodian but also noted that Ashley's attitude changed about one year ago, somewhat consistent with the major changes which occurred in Rebecca's household. RE: Hudson v. Greeger ASHLEY: Page 12 Regardless of who brought Ashley to the office, she reported feeling burdened with the caretaking responsibility of her younger half-siblings in her mother's home. She wants her mother to be more responsible for what her mother does. She reports being unsettled by her mother's relationship with the younger next door neighbor. She reports that mother may abuse alcohol "sometimes." She related that her mother does not promote Ashley's involvement in sports (e.g. volleyball) or other activities. She alleges that her mother becomes so frustrated that she calls Ashley names. She also reported that her mother has said that she is done with Ashley and will sign her parental rights away if Ashley lives with her father and stepmother and he seeks child support. She sees her dad and Kim as more supportive, available and stable, who can provide a structured, predictable, routinized day to day lifestyle. She sees them as more able to address her needs as a 12 year old. Further, Ashley does not like sharing her bedroom with her half-sister in her mother's home. She sees herself as an inconvenience to her mother. She wants to return to South Middleton to be with her friends, whom she continues to text and instant message frequently. She is upset that her mother has taken away her cell phone. She identified her father as the parent who allows her to be herself and she feels respected in her father's home. As Ashley matures, she feels less respected by her mother and displaced somewhat by Rebecca's focus on the two younger children and her new male friend. Finally, Ashley views her mother more like a peer than as an adult parental figure. Reportedly, Rebecca has made statements about relocating which further influences Ashley to align with her father and stepmother. Ashley is under a lot of pressure and identifies her father's home as providing relief. In terms of commentary, Rebecca has done a good job raising Ashley with Jerry and Kim's support in spite of all the concerns that Jerry and Kim have. Ashley however is unsettled with the many changes she has had to deal with and identifies her father and stepmother as the parental household more able to provide a protective structured life. Ashley is at an age where she thrives on structure, predictability and routine. Consistent with early adolescents, she is aware of same sex and opposite sex relationships, and also is beginning to question parental behaviors, standards and values. Her social group is expanding and she is learning to deal with social rules and behaviors. In that regard, she sees her mother as violating what Ashley believes to be the right way. Ashley appears to be using alignment with her dad and Kim to help her develop her self-perception and self-esteem. At a basic level, she is aware that she is at risk for parentified behaviors - caring for her mother (which she perceives) and her haff- siblings in her mother's home - and seeks relief from this responsibility. She RE: Hudson v. Greeger Page 13 presents as more emotionally vulnerable with her mother and seeks relief by her preference for her father and Kim, whom she sees as better equipped to deal with her age and to address her continuing developmental needs. She identifies her father and Kim as better able to exhibit empathy, consistency and support, maintain appropriate boundaries between Ashley and between themselves as adults. Ashley exhibits understandable ambivalence, she loves both parents but sees her dad and stepmother as better able to promote her individuation (self-identity). Ashley needs adults who can handle her resistance, at time rebelliousness, as she continues to form her identity. Typical of her age range, she would question parental behavior; judge that behavior; adopt, adapt or reject parental standards as she continues into adolescence. Relative to one another, Jerry and Kim are better equipped, based on my findings, to meet Ashley's current and emerging developmental needs. Ashley, consistent with her chronological age, is standing on the threshold of adolescence and also typical of her age, identifies parental figures in a clear, consistent fashion as her preference to help her deal with her ambivalence. RECOMMENDATIONS: Based on all the information collected and reviewed, I am recommending that Ashley live primarily with her father and stepmother. Ashley loves her mother but does not see her mother, at this point in time in her growth, as the parent who is able to address her turmoil and her needs. Regarding partial custody, I am recommending that Ashley be with her mother two weeknights, overnight, assuming that Rebecca can get Ashley to school on a timely basis in the morning given her other responsibilities. In addition, I am recommending an every other weekend partial custody between Rebecca and Ashley. The usual alternating holiday schedule with appropriate consecutive weeks in the summer for vacation, is also recommended. Respectfully, ?Q? Stanley E. Schneider, Ed.D. Psychologist SES/dk COMMONWEALTH OF PENNSYLVANIA ) . SS. COUNTY OF CUMBERLAND ) I verify that the statements made in the foregoing 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. DATE: 9 -N-69 JERRY R. HUDSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. REBECCA L. GREEGER, Defendant NO.98-5101 CIVIL TERM IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that on this date, August 14, 2009, I faxed and mailed a copy of this Petition for Special Relief to the following person at the following fax number and address by U.S. Mail, Certified mail, postage prepaid, return receipt requested, delivered to addressee only: Linda A. Clotfelter, Esq. 5021 E. Trindle Rd., Suite 100 Mechanicsburg, PA 17050 Fax: 796-1933 I verify that the statements made in the foregoing Certificate of Service 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. ANDREWS & JOHNSON By: Tay r . Andrews, Esq. A o eys for Plaintiff 78-W. Pomfret Street Carlisle, PA 17013 (717) 243-0123 OF Ive ta? 4UG Q9 00 WAM, TA 0, 0 In q aqo AUG 17 2009 JERRY R. HUDSON, Plaintiff Vs. REBECCA L. GREEGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-5101 CIVIL TERM : IN CUSTODY AND NOW, this I f* ORDER OF COURT day of August, 2009, upon consideration of the attached Petition for Emergency Relief, primary physical custody of Ashley Rae Hudson is awarde to ,?,?_ ov rat-s At 1w `' 6L c._, ? f?..e S?$ Af c.t.L? ex ? her Father, Jerry Hudson, pending a final healing on the pending complaint in this matter which shall be conducted on the 3f day of 2009 at ! ' ;?6 ?l M. in Courtroom Number 3 in the Cumberland County Court House, Carlisle, PA. The prior order with regard to burden of proof and prehearing memoranda still applies. ?&, • Sf (;;U?a /V? 61114?- FO HE COU T: By: Ta?for P. Andrews, Esq. for Petitioner Linda A. Clotfelter,Esq. for Defendant 06Pi ks rn? cl?c-l, FJLED--4D,,-? ICE OF THE PP! 7'-Imo . 'OTARY 2099 AUG 19 Fri 2' ? 8 Get ...?_ r JERRY R. HUDSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 98-5101 CIVIL TERM REBECCA L. GREEGER, Defendant IN CUSTODY ORDER OF COURT AND NOW, this 31st day of August, 2009, all prior orders are vacated, and we enter the following Order: 1. The Father, Jerry R. Hudson, and the Mother, Rebecca L. Greeger, shall have shared legal custody of Ashley Rae Hudson, born December 8, 1996. 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, welfare, and religion. 2. The parties shall share primary physical custody of the child as follows: A. During the school year Father shall have primary physical custody of the child, subject to periods of partial physical custody with Mother as follows: (i) Every other weekend from Thursday after school until Monday at the commencement of school, unless there is no school on Monday, then until Tuesday at the commencement of school. Mother shall be responsible to get the child to and from school and to all extracurricular activities while she is in her care. Said weekend visits are to correspond with the weekends that Mother's other children are in the home. (ii) Such other times as the parties agree. B. During the summer months the Mother shall have primary physical custody of the child, subject to periods of partial physical custody with Father as follows: (i) Every Sunday at 9:00 a.m. until Tuesday at 3:00 p.m. (ii) Such other times as the parties agree. 3. The parties shall share custody of the child on holidays according to the following schedule, which shall supersede the custody arrangements set forth in No. 2 above: A. Christmas: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 3:00 p.m. through Christmas Day at 3:00 p.m., and Segment B, which shall run from Christmas Day at 3:00 p.m. through December 26 at 3:00 p.m. The Father shall have custody of the child during Segment A in odd-numbered years and during Segment B in even- numbered years, and the Mother shall have custody during Segment A in even-numbered years and during Segment B in odd-numbered years. B. Thanksgiving: The Thanksgiving holiday shall be divided into Segment A, which shall run from the Wednesday before Thanksgiving at 3:00 p.m. through Thanksgiving Day at 3:00 p.m., and Segment B, which shall run from Thanksgiving Day at 3:00 p.m. through the Friday after Thanksgiving at 3:00 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, and the Mother shall have custody during Segment A in odd-numbered years and during Segment B in even-numbered years. C. Easter: The Easter holiday shall be divided into Segment A, which shall run from the Saturday before Easter at 3:00 p.m. through Easter Sunday at 3:00 p.m., and Segment B, which shall run from Easter Sunday at 3:00 p.m. through the following Monday at 3:00 p.m. The Father shall have custody during Segment A in odd-numbered years and during Segment B in even-numbered years, and the Mother shall have custody during Segment A in even-numbered years and during Segment B in odd-numbered years. D. Alternating Holidays: The period of custody on the following alternating holidays shall run from 9:00 a.m. until 8:00 p.m., unless the following day is a school day, in which case the child shall be returned by 5:00 p.m. In even-numbered years, the Mother shall have custody of the child on New Years Day and July 4th and the Father shall have custody on Memorial Day and Labor Day. In odd-numbered years, the Father shall have custody of the child on New Years Day and July 4th and the Mother shall have custody on Memorial Day and Labor Day. E. Mother' Day/Father's Day: In every year, the Mother shall have custody of the child on Mother's Day from 9:00 a.m. through the following Monday morning when the child goes to school, and the Father shall have custody of the child on Father's Day from 9:00 a.m. through the following Monday morning when the child goes to daycare. 4. Each party shall be entitled to have custody of the child for two non-consecutive weeks each summer. The Father shall provide notice to the Mother of the dates which he has selected for vacation by May 1 of each year; and after the Father has selected his dates, the Mother shall provide notice to the Father of her vacation weeks by May 15 of each year. The parties' periods of vacation custody shall include 7 full days. 5. Except as provided above, the party receiving custody of the child shall be responsible to provide transportation for the exchange of custody. 6. In the event either party intends to remove the child from his or her residence for an overnight period or longer, that party shall provide the other party with a telephone number where the child can be reached. 7. Each party shall promptly notify the other party of any emergency involving the health, safety or welfare of the child arising during his or her period of custody. 8. The parties shall e-mail each other on a daily basis to discuss some aspect of their child. The custodial parent shall initiate the e-mail, and the non-custodial parent shall respond. This shall be done for at least 90 days. Copies of all e-mails are to be retained and to be presented as an exhibit in the next court hearing. 9. The non-custodial parent shall be entitled to have reasonable telephone contact with the child. Daily telephone contact is reasonable. 10. The parties may modify this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. By the Court, ?Taylor P. Andrews, Esquire Attorney for Plaintiff ?Linda A. Clotfelter, Esquire Attorney for Defendant srs (20fIES maALCL OF THE RcC`r' f; "T RY 2009SEP -2 Ah S. 34- Cu iv, , JINII!'i