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Home My WebLink About98-06615 :!a. ~ .\)... ... VJ ~ ~ () ~, .~ \.1 t: '>. ~ ......... . ... .~ ~ ~, ~ ~I ~i ~i 1 LOUISE SIGNOR Plaintif f v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA, NO, (Ig-&~I!J- Cu~L CIVIL ACTION - LAW CUSTODY RANDY E. SIGNOR Defendant ORDER YOU, RANDY E, SIGNOR, are ordered to appear for a custody conciliation conference, in the Court of Common Pleas Cumberland County, pennsylvania, at ~"'jrl ''-,. \R"'\.\\. (~~ ,-nil n.laT r'~l-Ilf\L,P{l))),S'i\, on, \:.f','f$\'..I .:)\ , 1991f, at \0 o'clock, C\.m.," for a custody'conciliation conference, If you fail to appear as provided by this Order, an Order for custody may be entered against you or the Court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Court Administrator, 4th Floor Cumberland County Courthouse Carlisle, PA 17013 DATE: \ \ I ,:)L\ ICj~ . j\I~~A, ~~ ,~ (CJ\U \. qhr '. '\ C1$, I LOUISE SIGNOR Plaintiff IN THB COURT OF COMMON PI,BAS CUMBERLAND COUNTY, PENNA. v, NO. RANDY E. SIGNOR Defendant CIVIL ACTION - LAW CUSTODY COMPLAINT AND NOW, comes Plaintiff, Louise Signor, by and through her attorney, James W, Abraham, Esquire, Abraham Law Offices, Harrisburg, Pennsylvania, and files the following: 1, Plaintiff, Louise Signor (hereinafter "Mother") is an adult individual who currently resides at 2312 Penny Road Terrace, Baltimore, Maryland, 2. Defendant, Randy E, Signor, is an adul t individual who currently resides at 328 4th Street, New Cumberland, Cumberland County, Pennsylvania, 3. Father and Mother are the natural parents of Tyler A, Signor, born December 18, 1996, Mother is the natural parent of Amanda L, Amaker and Father is the st~p-father of said child, 4. On August II, 1998, an Order of Court was entered in the Court of Common Pleas of Dauphin County, which provided Father with primary physical custody of the parties' child, Tyler A, Signor, born December 18, 1996 and for Father's step-child and Mother's child, Amanda L, Amaker, born December 15, 1989, A true and correct copy of the Order is attached hereto as Exhibit "A", 5, The Dauphin County Order hereto was issued without the presence of Mother at the mediation conference and therefore was temporary in nature, 6, For the last two (2) years, Tyler Signor has been with Mother and Father intermittently, in the Central Pennsylvania area, and in New Cumberland since on or before March, 1998; and with Father since August 11, 1998, Amanda L, Amaker has been with Mother by court order (referenced below) since 1992 and until on or before March, 1998, and with Father since August II, 1998, 7. Paragraph 6 of The Dauphin County Order states that the children have resided in Cumberland County since March, 1998, and that proper jurisdiction is in Cumberland County, 8, As to Amanda L, Amaker, the Dauphin County Order is in direct conflict and/or viOlation of an existing custody order, issued by the Court of Common Please of York County, dated February 5, 1992, between Mother and the natural Father of Amanda, Bobby E. Amaker (hereinafter "Amaker"), which gives Mother primary physical custody and Amaker partial physical custody, and therefore the August 11, 1998 Order improperly provided Father custody of said child, A true and correct copy of the York County Order is attached hereto and made part hereof as Exhibit "B". 9, Amanda L, Amaker is ten (10) years of age and wishes to return to Mother's legal custody in Baltimore and Father has no legitimate legal or factual claim superior to Mother's right of primary physical custody of Amanda L, Amaker, ,. 10, In view of the York County Order, Mother submi ts that the Dauphin County order nhould be modiCied to delete Amanda L. Amaker, 11. Tyler J. Signor is two (2) years of age, and Mother submits that it is in the child's best interest for the Order to be modified to grant Mother primary physical custody of said child as Mother can provide a more loving and caring environment for the child, and can better care for a two (2) year old child, 12. Since the August II, 1998 Order, and since November I, 1998, Father is arbitrarily denying Mother "reasonable, liberal and frequent periodS of partial custody" of Tyler J, Signor, simply because Mother no longer wishes to reside with Father and is not returning to Father in Cumberland County, in wilfull violation of the Dauphin County Order. WHHRIlFORE, Plaintiff Louise Signor, respectfully requests Your Honorable Court, to grant the following relief: 1, Delete Amanda L, Amaker from the custody order(s) hereto and order the immediate return of said child to Mother in accordance with the York County order; 2. Grant Mother primary physical custody of Tyler R. Signor to Mother with visitation rights to Father; 3. Find Father in contempt of the Dauphin County Order for failure to provide Mother with frequent periods of partial custody, ~ 4, Order payment of reasonable attorney fees in the amount of $800,00, Respectfully submitted: ~(t~ DATE: 11/20/98 James W, Abraham, Esq, Abraham Law Offices 122 Locust St, Harrisburg, PA 17101 (717) 232-7825 " I~':i: ;;i? ~.E;:~,'~~T: "E 'r;:,. "..):" i.': ,., .... ........ J1C-~;;-~~~: '\........._l'-" ....1 - : whatever steps are necessary to ensure the ~ub]ect minor children reside 1n an environment free trom the use of alcohol and illegal narcotics, during their custodial periods, 5. This order Is temporary in nature, such that In tho event Defendant Louise Signor should desire custOdy or additional periods of partial custody, then she may request an additional custody mediation conference by tiling the appropriate motion with the Office of the Prothonotary, However, in the event that more than thirty days elapses after the date'of this Order, she will then be required to file a Petition in the county of appropriate venue, 6, It is specifically agreed by Plaintiff and his attorney that any additional matters relative to this custOdY case shall be filed in Cumberland County, because that has be'en the residence of the children for a period in excess of six months, as well as the residence of the Plaintiff, Likewise, it is further noted that the mother resides in Baltimore, Maryland, BY THE COURT: foi/I<C 0 -77/- 7e J / &\""~h ~ -K~f 110 11;C: lS9~ 1~:~~ .HC"'?:6"S':~: t.E';:;.u:.r: 't k'[f. p --:- ,"'\..- -..... .'..-.... .....'--......-............. . ....... "'" .....---- -.-- - --. .,. . . ;:. . ohUdnft w ....u.... tbe p&r'tiu do _ willl:a to 1II*C1ty I.~'. rltIabJ 0' I Rial CllIIt.od)' vitll -. owt.e1ntJ' but -"aU _a ~ ~ tWe w tiM a.. c1~ cllaftge. 'l'IUs Aow. 0- t. for oatollJ' and Pllrtl.al cut.o4v' Ia.. been be...a apon ~lhr'. reIIf~-~. 1" Paneyl-..Dl.a alld ra'dlu'.. reaidaAce in lIouth CU'oU... IIIould fat2Mlr "lcoat. to ~ m:at. or ......,h.IlU, tftn iD thlat ~. t!M> pIlZ'tia. agz.e to . 1 ~~Uate UN an. of: tftl.a 0lI11t1ody cmsv. It ....11 a1.-.ra .. t:IIe... J ...f.blUt)' Of tile r.tIa...... to pic:lt 1IIp .ad I 1.... tile ClIIU~ to t:IIe 110_ ~ tile IllOttutr who ~._ be _t..a bb l'it1lta tlll_...... ..itllw party ....11 1-' tlMI c:hUAren troll the 0(' :1I_wlaa of: l_u_,hwnU pIInIa'nelrt:l)' vlt:2lout tIloa prior Wl'U:tc1 _t or tbI ottlc or appzoopriau CoQrt order. 81' 1'8Z COUIl'l'. I I .l J ! ,1 1 " i j t ~ '. , . :/ " . .. .~ .1 ..... . 1 ~un~~ ClI~~m da re~om~e CO'JIt of Corti Pees. (l:-' tble day of f! A.O, 19 SlaCla N, QIIIeS, I'rothonollll)' . , . CERTIFICATE OF SERVICB I, James W. Abraham, Esquire, the undersigned, do hereby certify that I have served a true and correct copy of the foregoing document, by certified mail, on the date indicated below, to the following person(s) : Randy E, Signor 328 4th St. New Cumberland, PA 17070 DATE: 11/20/98 /!. ~ /vc7~ _=::/ James W, Abraham, Eag, .\' ,,':;, ,(. I,()( JlSE SI( iN( IR, 1'lailllifl)l'~titi'lII,'r 1:'\ I liE ('OIIRI OF COMt\loN PLEAS OF t'II:\IIlI;.RI.AND COIINTY,PI;NNSYI.V ANII\ \'S. 'IX.(,Il" CIVil. RANDY E, SI(iNOR, l)cr~llllall(/R~s(l(lIId~lIt ('IVII. ACTION -ClISTODY IN RE: PETITION FOR EMERCiENCY REI.IEF ORDER AND NOW. this 22nd day or D~~~mh~r, IlJlJR, upon consid~ralion or plaintil'[l(l~tilion~r's (l~tition li'r ~Ill~rg~ncy r~li~r, a hearing is seh~duled I()r Thursday, Decemher 31. IlJlJR. at 3:30 p.m. in Court roo III NUlllhcr I orthe Cumhcrland County Courthousc, Carlisle. PA. to estahlish a cuslody arrangcment pcnding thc custody conciliation conference scheduled in this matter. In the event that the parties are ahle to arrive at an agreed upon urrangement. counsel are requested to so notiry the court and the hearing will he canceled. BY THE COURT. James V:. .~?rah.a~l1. Esquire, ((:/71 Y;'k'" ''.Yr'/''Lg;: For 1'IamtllllPetllloner '1;- cY ;;}'.::I;) ,'/<;' Roger R, Laguna. Esquire,..I- /J r: r I (/ '11tJ:ltc'< /1t..J1i',d ,'or DClcll( an Respondent :rlm /.( II lIS/: SIC iNO/{, /'Iairllill' IN.,., IE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYL VANIA \" CIVIL M.TION - LA W j I I I j J I '{ANDY I,:. SI(jNOR. ()c/cndanl NO, 98-6615 CIVIL TERM ORDER OF COIIRT AND NOW. this '1 " day orJanuary. 1999. upon relation orJmnes W, Abraham, oj, Esq" nllorney lor Plaintin: thaI an agreement has been reached in the above matter. the hearing previously scheduled ror December 3 I, 1998. is cancelled, BY THE COURT, I .' I' .': I / ,.-' '.-'i.1; ( I . '" J. Wesley Oler,;Jr., J, . I .,Ii '~ ' .,' I . (..., James W, Abraham. Esq, 122 Locust Street Harrisburg, P A 17/0 I Attorney for Plaintiff - C~'-<2-0 n."a.~C<c 1/'1/99, r..&'~ Roger R, Laguna, Esq, 15 N, Front Street Stec/ton, PA 17113 Attorney for Defendant :rc (') \D 0 !;; \D -n ~. C- -l -r'~' c= ;F,~ ~. , :t'j :ZC I :~ ({.J.~':. CO ,SJ.' -......., - -:j';.I ~c:, ..., :l-~ ZQ =::: ,-)-- ~.~ .... yU ~ 0 "C: -I 7' U1 ?D ~ U1 -<