HomeMy WebLinkAbout03-1502Christopher W. Reed,
Plaintiff
Melissa A. Conrad,
Defendant
· IN THE COURT OF COMMON PLEAS
· CUMBERLAND COUNTY, PENNSYLVANIA
· NO. 03-/_~-~- CIVIL TERM
· CIVIL ACTION - CUSTODY
COMPLAINT FOR CUSTODY
1. Plaintiff is Christopher W. Reed, an adult individual whose residence is at
440 Fairground Avenue, Carlisle, Cumberland County, Pennsylvania 17013.
2. Defendant is Melissa A. Conrad, an adult individual whose residence is at
31 East Main Street, Plainfield, Cumberland County, Pennsylvania and whose mailing
address is P. O. Box 42, Plainfield, PA 17081.
3. Plaintiff seeks temporary custody of his child, Christopher Michael Reed,
born July 3, 1999, currently residing at 31 East Main Street, Plainfield, Cumberland
County, PA 17081.
4. The child is presently in the custody of Defendant.
5. Since the child's births, the child has resided at the following addresses:
Name Address Dates
Christopher VV. Reed & I Dranoel Drive, Carlisle, PA July 3, 1999 to
Melissa Conrad 17013 February 27, 2003
Melissa Conrad 31 East Main Street, Plainfield, PA February 27, 2003
17081 to Present
6. The relationship of the Plaintiff to the child is that of natural father.
7. The relationship of the Defendant to the child is that of natural mother.
8· The Plaintiff has not participated as a party or in any other capacity, in
other litigation concerning the custody of the child in this or any other Court.
9. Plaintiff has no information of a custody proceeding concerning the child
pending in a Court of this Commonwealth.
10. Plaintiff requests the following custody arrangement:
a. Plaintiff and Defendant shall have shared legal custody of the child.
b. Defendant shall have primary physical custody of the child, subject to
the following periods of temporary custody with the Plaintiff:
1. Every weekend from 4:00 PM Friday evening until 4:00 PM
Sunday evening.
2. During the summer school vacation, the parties shall alternate
custody of the child from 4:00 PM Sunday until 4:00 PM the next
Sunday. The mother shall have the first week after school has
terminated and said arrangement shall continue until the week
before school reopens.
11. 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. No other persons are known to have or claim to have any right to custody or
visitation of the child other than the parties to this action.
WHEREFORE, Plaintiff requests your Honorable Court to schedule a Custody
Conciliation and enter an Order reflecting the above proposed custody arrangement.
Respectfully Submitted
TURO LAW OFFICES
-2R~ ~eortutJi.; -p i1~1 ,~g;t E s q u i r~'-
Carlisle, PA 17013
(717) 245-9688
Attorney for Plaintiff
VERIFICATION
I verify that the statements made in the foregoing Custody Complaint are true
and correct. I understand that false statements made herein are subject to the penalties
of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities.
Date Christopher W. Reed
CHRISTOPHER W. REED
PLAINTIFF
MELISSA A. CONRAD
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
03-1502 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Tuesday, April 08, 2003 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hubert X. GilrOy, Esq. , the conciliator,
at 4th Floor, O_~mherland County Courthouse, Carlisle on Friday, May 02, 2003 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 fi'om Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT~
By: /s/
Hubert X. Gilroy, 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 ONCEi 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
MAY 0 5 2003
CHRISTOPHER REED,
Plaintiff
MELISSA CONRAD,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 03 - 1502 CIVIL ACTION - LAW
: IN CUSTODY
COURT ORDER
AND NOW, this ~/4 ~ day of April, 2003, the conciliator being advised that one of
the parties in the above matter is deceased and one of the parties is incarcerated, the
hearing scheduled for May 2, 2003 is cancelled. The conciliator relinquishes jurisdiction.
BY THE COURT,
Custody Conciliator
CHRISTOPHER W. REED,
Plaintiff/Respondent
V.
MELISSA A. CONRAD,
Defendant/Respondent
V.
MARY JANE KANTZ,
Petitioner
· IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 03-1502 CIVIL TERM
IN CUSTODY
PETITION FOR SPECIAL RELIEF
PURSUANT TO PA.R.C.P. § 1915.13
AND NOW, comes Petitioner, Mary Jane Kantz, by and through her counsel, Bradley L.
Griffie, Esquire, and Petitions the Court as follows:
Your Petitioner is an adult individual currently residing at 31 East Main Street,
Plainfield, Cumberland County, Pennsylvania.
Your Respondent, Christopher W. Reed, was the, Plaintiff in the above-captioned
action and is currently incarcerated in the Cumberland County Prison for reasons
hereinafter set forth.
o
Your Respondent, Melissa A. Conrad, is deceased having been murdered at the hands
of Christopher W. Reed.
Petitioner is the maternal grandmother of the child, Christopher Michael Reed bom
July 3, 1999, (hereinafter referred to as the "Child").
o
The natural mother of the child was Melissa A. Cora'ad, deceased, who was murdered
at the hands of the child's natural father hereinafter named, a copy of the death
certificate is attached hereto and incorporated herein by reference as Exhibit "A."
Melissa A. Conrad passed away on April 14, 2003, as a result of injuries she received
at the hands of the child's natural father.
The child's natural father is Christopher W. Reed an adult individual who is currently
incarcerated for various charges and pending transfer to the Commonwealth of
Pennsylvania where homicide charges will be filed against him relative to the death
of the child's natural mother.
o
Melissa A. Conrad (hereinafter referred to as the "decedent") is also the natural
mother of Kayla Made Conrad, bom July 7, 1995.
Your Petitioner herein has primary physical and legal custody of the child, Kayla
Made Conrad, pursuant to Order of Court dated December 1, 1998, a copy of said
Order as well as the Stipulation which requested the entry of the Order is attached
hereto and incorporated herein by reference as Exhibit "B."
10. The child has been in the custody of Petitioner since the death of decedent.
11. Other than the two children named herein, decedent ,:lid not have other children.
12.
As Petitioner had custody of the child's half-sister, and as the child has previously
been residing with Petitioner and continues to reside with Petitioner, it is in the best
interest and permanent welfare of the child to have an Order
Petitioner with primary physical and legal custody of the child.
entered providing
13.
Petitioner does not know any other parties who have not been named in these
proceedings who has or claims to have any rights to visitation or custody with respect
to the child.
14.
Petitioner is now aware of any other proceedings of any nature relative to custody of
the child.
15.
The child has resided for his entire life in Cumberland County, Pennsylvania, at
various addresses with the decedent since the time of his birth.
16.
As indicated, the natural mother of the child is deceased and the natural father of the
child is incarcerated; thus, neither natural parent is; available to take custody of the
child.
WHEREFORE, Petitioner requests your Honorable Court to enter an Order providing her
with primary physical and legal custody of the child pending ~rther Order of Court.
Respectfully submitted,
~~Esqiff/p;i:t~.oner
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
VERIFICATION
I verify that the statements made in the foregoing document are tree and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section
4904, relating to unsworn falsifications to authorities.
MARY J&NE I~'I~Z, Plaintiff/~gt~]°~)
i"his is to certify that the information here given is cou-cctty .copict} i:}'on~ an origiual ccrtificat~ ,~f death duly filed with me as
[.(,cai Registrar. The original certificate will be forwarded t(, tt~c: 5it, re \/ilal Lecc rd,, ()t:ficc fb~ p,:rmar~e,t filiug.
WARNING: It is illegal to duplicate this copy by photostat or photograph.
Fee for this certificate, $2.00
P 9191091
No.
l.ocal kcg~stra~
APR 1 7 2003
Date.
IANENT
Melissa A Conrad
COMMONWEALTH OF PENNSYLVANIA - DEPARTMENT OF HEALTH · VITAL RECORDS
CERTIFICATE OF DEATH
(Coroner)
STATE FILE NUMBER
Female 188 - 62 - 9697
DATE OF DEATH (MOnth, Day,
I" April 14, 2003
~d.te
AGE Il. Iai Birlll~l~) UNDER 1 YEAR UNDER 1 DAY OATE OF BIRTH BIRTHPLACE {C.~y ami
26 v~,. 1976
Cumberland West Pennsboro 31 East Main Street
Cashier Stopping v., [] R, ~
12~;)
31 East Main Street ,E,mE<~
Plainfield, PA 17081 ~.~ Cumberland
Michael E. Conrad, Sr.
J. (Young) Kantz
Do.ilkm[] CXher {Specify)
[]1,,,. 4/18/2003
A. April 14, 2003
Multiple Cutting and Stabbing Wounds
West Peunsboro
Mary J. Young
31 East l~J.n Str~t; Plaqnfield, PA 17081
{2~st H~riskurg ~Cr~ ~}21d' ~is~g, PA' 17109
}~ing Bm~ers ~eral H~, ~rlisle, PA 17013
,.
~ ~ ~l . ' ' t~. . Cut and stabbed by
~ ;_ _ . ~1~.-.,~ Ho~ I,J.Main Street, Plainfield, PA
................................. ~ ~,. ~~~ ~ ~oroner
*"~~'~'~"m~'~"'~'~"~')'~--"---~ ......................... ~-~, =,,. April 16, 2003
EXHIBIT
~tn27)TypeorPrlflt Michael L. Norris, Coroner
6375 Basehore Road, 5~uite
,. Mechanicsburg, Pa. 17050
MARY JANE KANTZ,
Plaintiff
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY-PENNSYLVANIA
MELISSA CONRAD and
SCOTT RAUDABAUGH
Defendant
:CIVIL ACTION~CUSTODY
ORDER OF COURT
AND NOW, this k[ day of /~ eP~fLW[Lt>~ , 1.998 upon presentation and
consideration of the within Custody Stipulation and Agreeme, nt it is hereby ORDERED
and DIRECTED that the aforementioned Stipulation and Agreement is made an Order of
Court and all prior orders in this case relative to custody are hereby vacated.
BY THE COURT,
Bradley L. Griffie, Esquire
Attorney for Plaintiff
Melissa Conrad, pro se
Scott Raudabaugh, pro se
MARY JANE KANTZ,
Plaintiff
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY-PENNSYLVANIA
MELISSA CON1La~ and
SCOTT RAUDABAUGH
Defendant
:CIVIL ACTION-CUS'rODY
CUSTODY STIPULATION AND AGREEMENT
THIS ST~ULATION AND AGREEMENT entered into the day
hereinafter written by and between MARY JANE KANTZ (hereinafter referred to as
"Grandmother") and MELISSA CONRAD (hereinafter referred to as "Mother"), and
SCOTT RAUDABAUGH (hereinaf[er referred to as "Father").
WHEREAS, Mother and Father are the natural parem:s of the child Kayla Marie
Conrad, bom July 7, 1995 (hereinat~er referred to as "Child");
WHEREAS, Grandmother is the natural maternal grandmother of the child;
WHEREAS, Mother and Father presently live separate and apart and neither
parent resides with Grandmother; and
WHEREAS, the parties wish to enter into a comprehensive agreement
establishing an arrangements relative to custody, temporary, and visitation of the child.
NOW, THEREFORE, in consideration of the mutual covenants, promises and
agreemems as hereinafter set forth the parties stipulate and agree as follows:
1. Grandmother shall have primary and physical and legal custody of the
child.
Mother and Father shall have periods of temporary or partial physical
custody with the child or periods of visitation, by mutual agreement
between them, individually, and the Grandmother. It is not intended
that these periods of temporary physical custody or visitation be
exercised jointly but rather that mother and father shall have
independent periods of time with the child, tn implementation of this
paragraph, it is intended that the periods of temporary and physical
custody or visitation as described herein ,,;hall be exercised in a
reasonable and liberal manner.
Mother or Father, respectively, shall be responsible for
transportation for the child for their periods of visitation or temporary
physical custody.
All parties shall keep the others advised irrm~ediately relative to any
medical emergencies concerning the child and shall, further, take any
necessary steps to insure that the health and well being of the child is
protected during sucl4 illness or medical emergencies. All parties
shall have the right to visit the child as often as he or she desires
consistent with proper medical care of the child.
None of the parties shall do anything which may estrange the child
from the other parties, or injure the opinion of the child as to the
other parties, or which may hamper the free a~d natural development
of the child's love and affection for the other parties.
The parties desire that the within stipulation ;and agreement made an
Order of the Court in the Court of Common Pleas of Cumberland
County and further acknowledge that the Court of Common Pleas of
Cumberland County does, in fact, have jurisdiction over the issue of
custody of the child in that the child has resiried for her entire life in
Cumberland County, Pennsylvania. Court of Common Pleas shall
retain jurisdiction should circumstances change and either party desire
or require modification of the Order resulting fi.om this Agreement.
Any modification or w~aiver of any of the provisions of this
Agreement on a permanent basis shall be effective only if made in
writing on the effects executed on the same formality as the
Stipulation and Agreement.
The parties agree in making this Agreemem there is no fi.aud,
concealment, overreaching, coercion, or any other unfair dealing on
the part of any of the parties.
The parties acknowledge they have read and understand the
provisions of this agreement. Each party acknowledges that the
agreement is fair and equitable and that it ils not the remit of any
undue influence or duress.
IN WITNESS WHEREOF the parties hereto imending: to be legally bound by the
terms hereof set forth their hand and seal the day and year hereinafter mentioned.
M~Y IIA_NE~T2
MELISSA CONRAD
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS.
On this the IL/ dayof ~0V,
1998, before me, the
undersigned officer, personally appeared MARY JANE ICtNTZ, known to me (or
satisfactorily proven) to be the person whose name is subscribed to the within Agreement
and acknowledged that she executed the same for the purposes therein contained.
IN WITNESS WI4F. REOF, I hereunto set my hand and official seal.
NOTARIAL SEAL
~ WENI]Y M, BURKHi~LDER, Notary Public
~ Carlisle, Cumberland County.
My Commission Expires June 7,1999
COMMONWEALTH OF PENNSYLVANIA'
COUNTY OF CUMBERLAND
SS.
On this the / ~ day of ~OV' , 1998, before me, the
undersigned officer, personally appeared MELISSA CONRAD, known to me (or
satisfactorily proven) to be the person whose name is subscribed to the within Agreement
and acknowledged that she executed the same for the purposes; therein contained.
IN WITNESS WHEREOF, I hereu~et rny h/
NOTARIAL SEAL
[ WENDY M"URgH0i-DE,~, No~,a~ Public
,,GarliC,Cumber and Coun~
My Commission Expires June 7,'1999
d"'~c[ official seal.
COMMONWEALTH OF PENNSYLVANIA'
COUNTY OF CUMBERLAND
On this the [ 9r
SS.
, 1998, before me, the
day of /k30~
undersigned officer, personally appeared SCOTT RAUDABAUGH, known to me (or
satisfactorily proven) to be the person whose name is subscribed to the within Agreement
and acknowledged that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
NOTARIAL SEAL
DAWN M. 8HUGHAFr~, Nota~j Public
, _Carlisle, Cumberland County
r~y commission Expires Nov. 28,
CHRISTOPHER W. REED,
PLAINTIFF/RESPONDENT
V.
MELISSA A. CONRAD,
DEFENDANT/RESPONDENT
V.
MARY JANE KANTZ,
PETITIONER
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
· 03-1502 CIVIL TERM
AND NOW, this
ORDER OF COURT
~ day of June, 2003, pending further order of
court, Mary Jane Kantz, shall have legal custody and primary physical custody of her
grandson, Christopher Michael Reed, born July 3, 1999.
By,he C6'u rt
Edg~ ~. I~a
Bradley L. Griffie, Esquire
For Petitioner
Christopher William Reed, Pro se
Cumberland County Prison
1101 Claremont Road
Carlisle, PA 17013
:sal
'VlNV^q,,LSNN~cJ
CHRISTOPHER W. REED,
Plaintiff/Petitioner
MARY JANE KANTZ,
Defendant/Respondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
: IN CUSTODY
:
: NO. 03-1502 CIVIL TERM
PRAECIPE
To the Prothonotary:
I hereby withdraw my appearance previously entered on behalf of the Christopher W.
Reed, in the above captioned case.
Respectfully submitted,
Robert J. Mtlld&ig, Esquire
28 South Pitt Street
Carlisle, PA 17013
(717) 245-9688
To the Prothonotary:
I hereby enter my appearance in the above captioned matter on behalf of the Christopher
W. Reed.
Respectfully submitted,
Tayls~ ?. Andrews, Esquire
78 ~ : Pomfret Street
Carlis PA 17013
(717) 243-0123
CHRISTOPHER REED,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
MELISSA CONRAD,
Defendant
NO. 03-1502 CIVIL TERM
ORDER OF COURT
AND NOW, this 14th day of January, 2004, upon consideration of Plaintiff's
Petition for Special Relief Pursuant to Pa. R.C.P. Section 1915.13, and following a
conference in chambers with counsel for Plaintiff, Taylor P. Andrews, Esq., and counsel
for Defendant, Bradley L. Griffie, Esq., the petition is granted to the extent that Plaintiff
shall be permitted to have a five-minute supervised visit at the Cumberland County
Prison with his son Christopher Michael Reed; provided, that Plaintiff shall not discuss
the death of the child's mother in any way; that he shall not have any physical contact
with the child; that Defendant's counsel shall be in attendance at the visit; and that any
persons requested by Defendant, including herself, may also be present.
IT IS UNDERSTOOD that the purpose of the visit will be to permit Plaintiff to
tell the child that he will be going away and that he is sorry. To the extent that this
purpose is deviated from, the visit shall be terminated.
BY THE COURT,
,,~aylor P. Andrews, Esq.
Attorney for Plaintiff
~radley L. Griffie, Esq.
Attorney for Defendant
:rc
CHRISTOPHER REED, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
v. : CIVIL ACTION - LAW
MARY JANE KANTZ, :
Defendant : No. 03-1502 CIVIL TERM
AMENDED ORDER OF COURT
AND NOW, this 14th day of January, 2004, the
Order of Court dated this date is hereby amended to reflect
the caption as indicated above.
In all other respects, the Order of Court
dated this date shall remain in full force and effect.
By the Court,
Taylor P.
For the Plaintiff
~radley L. Griffie,
For the Defendant
wcy
Andrews, Esquir~
Esquire