HomeMy WebLinkAbout98-06583
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STEVEN U:ONARD.
Plaintiff
IN TilE C:OllRT m' COMMON PI.EAS m'
<:lJMUt:RI.AND C:OlIN'IY, Pt:NNSYIN ANIA
V.
CIVIL A<.TION -LAW
CRISTIE LEE LEONARI).
Defendant
NO,
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IN <:llSTODY
QIill,ER OF C:OlJRT
AND NOW, this \9 dayof ~hr("t')l'\ ,I998,upon
consideration ofthe attached Custody Complaint, it is hereby directed that the parties and
their respective counsel shall appear before _ ,:'" '. \c" - the
Conciliator. at~9 "-..\ ('-Iell \\ ~ -( 0 the 1\
day of \)-(' ,(\\\-,e r , 19~ at \'. ..J 0' c1ockf' m., for e-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 pcnnanent order.
FOR THE COURT,
BY: r}:SnDS'\\_ c1\. ';O~lL'VNn,A,(€,\I,
Custody Conciliator U ;~)
Tbe 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
2 Liberty Avenue
Carlisle, PA 17013
(7 17) 249-3166
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Plaintiff
: IN Hit: COURT OF (:()Mi\lON PU:AS OF
: Clli\lUt:RI,ANO (:OIIN"Y. Pt:Nl'iS\'J,VANIA
V.
: CIVIL ACI'JON - I.A W
CRISTU: Lt:t: U:ONARI).
Ocfendnnt
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IN (:USTOO\'
COMI'J,AINT FOR ClISTOOY
AND NOW, comes the plaintiff, Steven Leonard, by and through his allorney,
Jacqueline M. Verney, Esquire and represents the following:
I. Tbe PlaintilT is Steven Leonard, residing at 604 A. North Baltimore Street, Ml. Holly
Springs, Cumberland County, Pennsylvania 17065.
2. The Defendant is Cristie Lee Leonard, residing at 539 First Street, Carlisle,
Cumberland County, Pennsylvania, 17013.
3. PlaintilT seeks custody ofthe following child:
NAME PRESENT ADDRESS
AGE
Elizabeth Evelyn Leonard 539 First Street
Carlisle, Pennsylvania 17013
DOB J 2/29/97
The child was born in wedlock.
The child is presently in the custody of the defendant, Cristie Lee Leonard, who
resides at 539 First Street, Carlisle, Pennsylvania.
During the past five years, the child has resided with the following persons and at the
following addresses:
LIST ALL PERSONS
ADDRESSES
DATES
Cristie Lee Leonard
539 First Sl.
Carlisle, I'A 17013
10/10/98-prescnt
Cristie Lee Leonard
Steven Leonard
539 Firs1 St,
Carlisle, PA 17013
12/29/87-1011 0/98
The mother of the child is Cristie Lee Leonard currently residing at 539 First Street,
Carlisle, Pennsylvania, 17013,
She is married.
The father of the child is Steven Leonard currently residing at 604 A. North Baltimore
Street, MI. Holly Springs, Pennsylvania, 17065.
He is married.
4. The relationship of PlaintiJIto the child is filther, The Plaintiff currently resides with
NAME
RELATIONSHIP
Da.\lid.L r PQn!lr,l
Brother
Tracy Leonard
Sister-in-law
5, The relationship ofDefcndant ta the child is mother. The Defendant currently resides
with the child.
6. Plaintiff has not participated as a party or witness, or in another capacity, in other
litigation concerning the custody of this minor child in this or another court.
Plaintiffhas no informatioll of a custody proceeding,conceming the child pending in
a court of this Commonwealth.
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...
STEVEN LEONARD,
PLAINTIFF/PETITIONER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V,
CHRISTIE LEE LEONARD,
DEFENDAN~RESPONDENT
98-6583 CIVIL TERM
ORDER OF COURT
AND NOW, this 25th day af Navember, 1998, IT IS ORDERED that pending a
further order fallowing conciliatian:
(1) The mother, Christie Lee Leanard, shall have temparary primary physical
custady of Elizabeth Evelyn Leonard, born December 29, 1997.
(2) The father, Steven Leanard, shall have visitatian with Elizabeth every
Sunday from 9:00 a.m. until 6;00 p,m.
By the Court,
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Jacqueline Verney Esquire
Far Plaintiff/Petitianer
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Edgar B. Bayley, J, \
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Jaan Carey, Esquire
For Defendant/Respondent
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Steven Leonard
Plaintiff/Petitioner
: IN TilE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION., LA W
CHRISTIE LEE LEONARD
Defendant/Respondent
NO. q~ - (,,<::)33
IN CUSTODY
ORDER
BY THE COUR.T,
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AND NOW, this !Qtiday of '. IlWt>\J.,.e,,- ,1991., it is hereby ordered that
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a hearing shall be scheduled on the J.5U day of'~ / (~7.\L'l!I.j)fl , 199 Ji at
~', ~() o'clock in Courtroom # /~ of the Cumberland County Courthouse,
Carlisle, Pennsylvania, in the above captioned matter,
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Plaintiff/Petitioner
: IN 'I'm: C:OlIRT Ofo' C:OI\I1\10N P"US 0.'
: ClJI\1Bt:RI.AND COlIN1Y, Pt:NNSVI.vANIA
v,
: CIVil. ACI'ION -I.AW
CRISTIE LEE LEONARD, : NO. ( (~., ( c <., .~
Defendant/Respondent: ',.I' ~ ) u -
: IN ClJSTODV
ORDER
AND NOW, this
day of
, 1998, upon consideration of
the Emergency Pctition for Special Relief as filed by Petitioner, pending the Conciliation
Conference and until further Order of Court, it is hereby decreed and ordered that the
parties share legal and physical custody of the child, Elizabeth Evelyn Leonard on a week
on, week off basis beginning the
day of
, 1998. The parties
shall exchange the child at a mutually convenient public location.
BY THE COURT,
J,
8. Petitioner has made numerous re1luesls tu have contact with the child but MOlher has
refused.
9. Since the baby was born, Father has cared lor the baby by changing its diapers,
feeding her, dressing her. pUlling her to sleep and watching her alone lor extended
periods of time.
10, Father is presently living, with his brother and his brother's wife. If Pelitioner obtains
custody he will acquire all necessary items needed 10 care for and accommodate the
baby.
II. The withholding of Father 's access to the baby is unfounded and undeserved.
12. Mother has threatened and allempted suicide twice since the baby was born, once by
cUlling, her wrists and once by ing,esting, a larg,e q,uantitx of Tylenol. Both times
Father was present to prevent her /Tom causing death or grave harm to herself.
Mother h!lS not received any mental health counselin& for her suicidal tendencies.
13. Father has concerns about the baby's well being when she is in Mother's care.
14. It is not in the child's best interest to be away /Tom her Father.
15. Father is employed full time at Unicom in Mt, Holly Springs.
16. Father has taken steps to enter the child in. day care if shared custody is awarded.
17. There is no custody order in existence in this case, A Custody Complaint has been
filed contelllJloraneously with this Petition. A Custody Conciliation Conference will
not be scheduled for approximately one month, Extended delay in meaningful
eontact with. the child oflhis 8&e with one parent could caus.e irreparable harm to the
parent child relationship.
until the Custody conciliation conference. Falller is !>CcJ..ing primary physical custody
18. There is no reason why Father should not have shared physical custody of the child
of the child atthc Custody Conciliation conlcrencc hecau!>C of Mother's menIal health
condition,
19. Transportation should be shared and the transfer should occur at a mutually
convenient public place.
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WHEREFORE. Petitioncr rcCUlcsts the Court I1cnding,thc Conciliation Confercnce
t_~ -fh. 0.
and until further Order of Court, to grant shared legal custody and shared physical
custody orthe child on a wcek.on. wcck. olIbasis and shared holidays.
Respectfully submitted,
Date: "11'1(i1
acqu ine M. Verney, Esquire
44 South Hanover Street
Carlisle, PA 17013
(717) 243-9190
Supreme Cl. ID 23167
Attorney for Petitioner
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STEVEN LEXlNARD I
Plaintiff
IN 'fHE: a:xJRT Of" COMMON PLf".AS Of"
: CUMBERLAND COUNTY, PE:NNSYLVANIA
:
vs.
NO, 98-6583 CIVIL TE:RM
CHRISTIE LEE LEONARD,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
PRIOO JUDGE: Edgar B. Bayley
CUS'lOOY crncILIATIOO SlH'lARY REPOOT
IN ACCORDANCE WITH CllIIlERLAND CXUll'Y RULE OF CIVIL PROCEDURE
1915,3-B, 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
CURRENl'LY IN CUSTODY OF
Elizabeth Evelyn Leonard
December 29, 1997
Mother
2. A Conciliation Conference was held on January 6, 1999, with the
following individuals in attendance: The Father, Steven Leonard, with his
counsel, Jacqueline M. Verney, Esquire and the Mother, Christie Lee
Leonard, with her counsel, Joan Carey, Esquire and Martin Harter, law
student.
3. The parties agreed to entry of an order in the form as attached
reflecting temporary custody arrangements pending the outcome of each
party's evaluation/assessment and the second Conciliation Conference.
Jan.W'>A'<j J/ 111 "I
Date 0 I
LL.~~
Dawn S. Sunday, Esquire
Custody Conciliator