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Home My WebLink About00-05185 ~." M ;,.,~ ~ ~~ lli ~ ~,- u___._ ~ . " ~ ''',_ ',' ,_.".. ~ "',',", ~ ,...._.."~,:.... ,"" ~:- ,.. _".", "",_ _,," ,.....,.., ,.,H,'''' ,",_ ,,'''' "'__~~""_." "'. "'~ ,.~. '.'" ~'_ ~~~~~~~~.~~~~~.~,,&~.~~&.&.&&. "'~ a ~.~ ~.~ ~ ~.S , ~.'~ ~ ~ l>.~ ~.~ " i !I'.~ ,:"s ~ ~.; ~ \\I:!. ~ ~.~ i ~.~ t~ ~ ~.~ ~l 8 ~t . ;:~ ~ ~:~ ~ t.~ ~ ~ ~ ~.~ ~ ~., ~ ~..~ ~ ~~; . ~ ~.'I. ~'.~ ~ ~.; ~ 'c " oj.. _~__ d'.-'- _,'" LL ~.';,-,..."' '"or''; ,,-,'>.-_.."_~ -,.c.' ,,'c ",.,__,0.' ' , -' ;:~:+::.: :::~::c~.: ':-!::C~~:'::o3;(::,.::.::<:..::.::()::.x::~.;3t~;:: ::~!::":'::;!::C~~;:"::.3t.:'>>>::0;>3::~': ":';::C.;" ;:.::+::.::"-.>>::.:" ::.::<<.:.>.::.::.~.: ::.::c.:::.);::'x.~of;')::~~;~>>}c:~::.::~:'~,~a.,!>;>::.~::.::~::'::.!3t~;::,,!3>;X:~!::."~"~!~ ~ ~ ~ ~ ~.~ ~ ~ ".". W !I'.~ IN THE COURT OF COMMON PLEAS t l'i ~.; ~ a !I'.'I. OF CUMBERLAND COUNTY STATE OF PENNA. TINA L. HARRISON H______________.. I II II I I Civil .................. N o. __.()'O':::?).~.5.__ ______Plai.n.tiH____. Versus R()N J<.L. D...'1:.,.. .11.~RI~ :rS() N... Defendant DECREE IN D I V 0 R C E o:t (.: I&A.Jfr. AND NOW,.... .~.~. ~............ .,~.I.., it is ordered and decreed that. . . . . . . . . " . .'l;'f~A.,I". .H.!\ij.~;r.S.QIi. . . .. .. . . . . . . . . . " plaintiff, and. . . . . .. .. .. . . .. . . . . .. . ~.o.l\!~J;.P. .~: .11.A,~l3-~~.ql'!. . . . . .. . . . .. " defendant, are divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; ~ONC . ................. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ... , ...........-........ ............ ................"........ By ____un uu__. .... Prothonotary __n..... du_ Attest:_____?l ~ ~ ::.::+:;;:-'::.::+::.-:: ::.::+::.: ':-.::+::.':' :::.::.::..:: :~.::.::.'. --"::.::'" "::.::":: ,,"::+::;-: >~::.::~:' - ,; ~ ~~~ ~':~ ~ ~ ~.~ N ~ ;..~ ~ '.,< ~ ~.~ ,'~ I ~~~ ~ ~.; ~ ~ ~ ~ ~ ,""; ; ~ " ~ ~'s . ""'. ....',. M !i'.<! t ~ ._.0,.; 8 ~ ';.'. W !i'.<! N ~ ~'s I ,..,' ~ M ~ ~i ,..,' ~ ~.~ ;.; ~ ~ ~.~ w ~.~ w. ~.~ ~ ~.~ ~ ~.' $. ~.~ J. ~ ... ~ '.' ~ '.' ~ ~.~ . . ~ .tf, .6'/ ~?t7f .. '",,' ,,"" ..... ~~_~. J~"""",,",,* . ". . f."~-' ca/ ~. ~ ~ ~ ~?~~~ ~ /U~ #' f' - ,~ '~>''7'~~'r.,L""<_~..,~"",,,=, .,. -" ~. )., L J- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . , TINA L. HARRISON, Plaintiff NO. a;- 5/f.5--- &tJ vs. CIVIL ACTION - LAW RONALD T. HARRISON, Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree of Divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you. When the grounds for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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 ASSISTANCE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 .< , . "...,.~" AVISO PARA DEFENDER Y RECLAMAR DERECHOS USED HA SIDO DEMANDADO EN LA CORTE. Si desea defederse de las quejuas expuestas en las paginas siquientes, debe tomar accion con prontitud. Se Ie avisa que si not se defiende, el caso puede proceder sin usted y decreto de divorcio 0 anulamiento puede ser emitido en su contra por la Corte. Una decision puede tambien ser emitida en su contra por cualquier otra queja 0 compensacion reclamados por el demandante. Usted puede perder dinero, 0 propiedades y otros derechos importantes para usted. Cuando la base para el divorcio es indignidades 0 rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Court House, Carlisle, Pennsylvania 17013. SI USTED NO RECLAMA PENSION ALIMENTlCIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO Y OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SEA EMITIDO, USED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUlERA DE ELLOS. USTED DEBE LLEVARESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE 0 NO PUEDE PAGAR UN ABOGADO, VAYA 0 LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telefano: (717) 249-3166 ", ,,..-=,,; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. /H)-5IrS' ~ I,M.A""- TINA 1. HARRISON, Plaintiff vs. CIVIL ACTION - LAW RONALD T HARRISON, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW, this 21.5~ay of July, 2000 , comes the Plaintiff, Tina 1. Harrison, by her attorney, G. Patrick O'Connor, Esquire, Office ofG. Patrick O'Connor, Esquire, and files the following Complaint in Divorce whereof the following is a statement: L The Plaintiff, Tina 1. Harrison, is an adult individual who currently resides at 113 3 Columbus Avenue, Apartment 1, Lemoyne, Cumberland County, PA 17043. 2. The Defendant, Ronald T. Harrison, is an adult individual who currently resides at 3131 Old Trail Road, York Haven, York County, PA 17370. 3. The Plaintiff and Defendant were married on or about February 14, 1990, and separated on or about April 22, 2000. 4. The Defendant has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint 5. There have been no prior actions of divorce or annulment between the parties. ~ --~"~ ~, . \' 6. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. Both the Plaintiff and Defendant are sui juris and are citizens of the United States. 8. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. WHEREFORE, the Plaintiff requests your Honorable Court to enter a decree divorcing the Plaintiff and Defendant absolutely. COUNT I - CUSTODY 9. The foregoing paragraphs of this Complaint are hereby incorporated herein by reference as though set forth in fulL 10. Plaintiff and Defendant are parents of the following unemancipated children: Courtney Harrison, a son, age 9; Nicole Harrison, a daughter, age 8; and William Harrison, a son, age 5. All children reside with the Plaintiff at 1133 Columbus Avenue, Apartment 1, Lemoyne, PA 17043. II. In the past five years, the parties' children have resided with the parties as follows: from January of 1995 until January of 1997 at 409 'h Fourth Street, New Cumberland, Cumberland County, Pennsylvania, 17070; from January of 1997 until January of2000 at 670 Kise Mill Road, York Haven, York County, Peunsylvania 17370; and since January of 2000 at 3131 Old Trail Road, York Haven, York County, Pennsylvania 17370. ,," - . " ,~ ).lj'~:, 12. Plaintiff has not participated as a party, witness or in any other capacity in any other litigation concerning the custody of the same children in this or any other state. 13. Plaintiff has no information of any custody proceeding concerning the children pending in this or any other State. 14. Plaintiff does not know of any person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 15. The best interest of the children would be served by granting requested relief WHEREFORE, Plaintiff prays this Honorable Court to grant custody rights to Plaintiff. Respectfully submitted, G. Patrick O'Connor, Esquire 3105 Old Gettysburg Road Camp Hill, PA 17011 (717) 737-7760 ill No. 64720 Attorney for the Plaintiff .~. ~~ , = ~ "~ - ~ '1&",_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. O-t.> -$'/:1'5 ~ 1--,--,-- TINA L. HARRISON, Plaintiff vS. CIVIL ACTION - LAW RONALD T. HARRISON, Defendant IN DIVORCE AFFIDAVIT OF MARRIAGE COUNSELING Tina L. Harrisson, being dilly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. CoSo Section 4904, relating to unsworn falsification to authorities. Date: July 18,2000 C \~ ~~f'\I'rv-> Tina L. Harrison '"~ - VERIFICATION I, TINA L. HARRISON, state that I am the PLAINTIFF in the above-captioned case and that the facts set forth in the foregoing are true and correct to the best of my knowledge, information, and belief. I realize that false statements herein are subject to the penalties for unsworn falsification to authorities under 18 Pa.C.S. Sec. 4904. C \~r')\~ Tina L. Harrison Date: July 18, 2000 .. ..-1 " 1Itr.e_, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA L. HARRISON, Plaintiff NO. 00-5185 Civil vs. CIVIL ACTION - LAW RONALD T HARRISON, Defendant IN DIVORCE AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO PA. R. CIV.P. 1920.4 G. Patrick O'Connor, Esquire, being duly sworn according to law, deposes and says that he mailed a copy of the Complaint in Divorce filed in this matter by certified mail, return receipt requested, addressee only, to the Defendant at 3131 Old Trail Road, York Haven, PA 17370. The retnrn receipt signed by the Defendant is evidence of delivery to him and is attached as Exhibit "A". I verifY that the facts contained above are true and correct to the best of my knowledge, information and belief I understand that the facts herein are verified subject to the penalties for unsworn falsification to authorities under Crimes Code, Section 4904 (18 Pa.C.S. 94904). ~!J~ /G. Patrick O'Connor, Esquire LD. No. 64720 3105 Old Gettysburg Road Camp Hill, PA 17011 Phone 717-737-7760 Attorney for Plaintiff b!'L:"- "'.-"""""'!\!I">;W~A~~lil1:~-">~"~ ~ JIIiilifJiM'M~,.tl;"~ili<IIi~~~$!MtiC"~;4."ii1ll!l)j;i,.jl~I!Wtii\.bWiUIli!l""'>"" ""--" ~''''lfIIIitiI~'''Il!I!It'.l.,-,~,-;'' ( ''''.w~ ~-~ ~, o C 0~:~ ITit:" :2 f'; ~~:;~ ~C" L.:>< >E ~ .:::::) C,.) C:i :I;~ :n c:) 1;2, _3.At... ",,",piete . item 4 if; ,_ .DeJjVery is de$Jred. . Print yowr name and address on the reverse so that we can return the card to you. . Attach ttitis card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: C. ~nature _ _ ~. ~__'1 ~ Agent Addressee D. Is delivery address different from item 1? D Ves If YES. enter deJivery address below; 0 No ;?~ /,' II~/.J'ho.../ -2/31 tJ/d 7';-,,~~ Yrvi //~"PA 17370 3. Service Type ~Certified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) Yves 2. Article ~umbe~. (Copy from service label) .' ~.~~ gm~~...:iti~1 '-',~,_---"_:: ,,"'_,' ' '''' . '-'. ! :_i.4'~/,', i; PS Form . 8i'{ Jilly ." Doinestlcl%lurn R_pl "",. 102595-99-M-1789 ----_:i-,~-'~,[ EXlfMT "A" ~ ,~ - -"- ,.., ~ J ~~. ' -~L'€t,!(",,-' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA L. HARRISON, Plaintiff NO. 00-5185 Civil vs. CIVIL ACTION - LAW RONALD T HARRISON, Defendant IN DIVORCE AFFIDAVIT OF CONSENT L A Complaint in Divorce under Section 3301(c) ofthe Divorce Code was filed on July 24, 2000 and service made on the Defendant on August 10, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATE: 5 J I Y }61 C \~~ C\\~ Tina L. Harrison, Plaintiff Mil" ~ Jl!iIil'i~iliW.i;:"'E,JI""",'"!"",~iliklrlii~llfi~fu;1i.liJNg:,j;"""'"(",".2-,,t1Mii,"",",,",1::..,fu,;,i'&~!i~N&!i%ma!'lilli!~~~,,",,,~-~>' '1, _~~i1j[Ill~.~ilIi(r->~~, () C <:' ""ti tt~ fTlr" . Z::.l-' Li' C;) )- l~ ::'::: --< '"1,1 I I o ~;>' ~~::: ;;. -,:;: :~~) -C) en C) \._:;' ~ ~2 11 -","' "Illf_~;.oj IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA 1. HARRISON, Plaintiff NO. 00-5185 Civil vs. CIVIL ACTION - LAW RONALD T HARRISON, Defendant IN DIVORCE AFFIDAVIT OF CONSENT L A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 24, 2000 and service made on the Defendant on August 10, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATE: ~. H.D.D I ~'-i. Ronald T Harrison, Defendant W!II~~"''''''J''f,,,_-',!hiU"-..t~>>!N~~,Ii~''lh,,,,,,,,,,,k\!i,i,,:.,,,,,,,;~-l>':d,';\j",.,;11i..-'M6@'r;H-"w.-l.~.'1l'f.r~~j&'-i1-~lit'lrd~~~~~' _....~\i~4lf/.Jl1!ffii-~~ (') C-, c: '. ,. -n '-~,; , nl ['."1 - Z :',') L --., Cr) '- -~ - 3S ~.' ~:.=: .. - .2': > '....-' C) c: ---< :..n C' .. , ".~~. ,. '"""l!I.' ,1 i:'ij ii , ti ~:i II fJ f! II f,1 II Ii ,I II ! II I[ II II I I I I ~'.I '. <@,ak IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA L. HARRISON, Plaintiff NO. 00-5185 Civil vs. CIVIL ACTION - LAW RONALD T HARRISON, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me iunnediately after it is filed with the Prothonotary. I verifY that the statements made in the foregoing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S Section 4904, relating to unsworn falsification to authorities. DATE 3") I Y 10, C \~~.~~ Tina L. Harrison, Plaintiff '''~$4~~ ""'~,,- =~;;Jl,b.a,bi;;iili'~'l:iW;\l;.li;~i!;_~aJ~:J!I~fj;'jj~~-""",. ---~~~I-'"-' <~~ _.:t/r~.~ ._-~ o f'; -Vfl~ f11p: 2:-,'-, ...t2f, .~~'-"' .~~~ ~ .,1 II'i ~I I" '.....1..' I', ::' :~I 1.'.1 ,. i:i ,. " ~ c' ~~~) n ;:;;: .<'l;: ..::""J <,::) ~~'. -'>r. '.:..11 (::J 'c. ~:.f ::-iJ ~;;'-~ _.~" ~ ~lil;'" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA L HARRISON, Plaintiff NO. 00-5185 Civil vs. CIVIL ACTION - LAW RONALD T HARRISON, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the de~ree will be sent to me immediately after it is filed with the Prothonotary. I verifY that the statements made in the foregoing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C S. Section 4904, relating to unsworn falsification to authorities. ~. Ronald T Harrison, Defendant c- .Ill .0\ D KrE: <> -;&jj~~ ~_-"'....- ~~~"-~..liiliilli.~~."''-'i-'"''-'' _:.~...l,~"'-_ '-1."""....".'~.'- Mia DI:I~lllV""""'--<1i'11rr-. (') ~- :> Itt] ,"" '~?c: ~?;~:' :!2 :.Ii c) C) c) -n -~ :.:;::.:r ,.~ (=.:;. '":-:; j ~ .~. ~~" - .1 , ~ _c. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA L. HARRISON, Plaintiff NO. 00-5185 Civil vs. CIVIL ACTION - LAW RONALD T. HARRISON, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Mailed July 25, 2000 bv certified mail and received by Defendant on August 1. 2000. 3. [Complete either paragraph (a) or (b).J (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by Plaintiff: Mav 14, 2001; by Defendant: Mav 16. 2001. (b) Date of execution of the Plaintiff's Affidavit required by Section 330l(d) of the Divorce Code: ,and, date of service of the Plaintiff's Affidavit upon the Defendant: 4. Related claims pending: None. All economic claims have been settled. 5. Date and manner of service of Notice ofIntention to file praecipe to transmit record, a copy of which is attached, if the decree is to be entered under Section 3301(d)(I) of the Divorce Code: 6. Date and manner of service of Notice ofIntention to file praecipe to transmit record, a copy of which is attached, if the decree is to be entered under section 3301 ( c) of the Divorce Code , or, date of execution of waiver of Notice ofIntent and date offiling: Plaintiff's Waiver of Notice was executed on Mav 14, 2001. and filed contemporaneously herewith. Defendant's Waiver of Notice was executed on May 16, 2001. and filed contemporaneously herewith. 7. The Plaintiff's Social Security number is 177-60-4398. The Defendant's Social Security number is 115-50-4557. . Patrick O'Connor, Attorney for Plaintiff ..~1m&i}.IifIti~if".-"q" f' .~ .*~'~'''"'''''''IIin!ll ,- ~, "'='ruBI"Jt.-",."..~ J'l'ilIru .'~~ '. - ~~ '" ~, ~ (') G; <- ~4~r z:.:, 0=:: ~~~.- ~g ~-=J -<; ~ , 1__~1~'~1 "', """'<'1 II II il I ,I I, 11 I , i I C,' r...,,) C, cn {=:- ..,-, -<.: ,,,,,..'"'.~~~ ~ - I ""0' "k I:iit'. .,,', IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA L. HARRISON, Plaintiff/Petitioner NO. 00-5185 Civil vs. CIVIL ACTION - LAW RONALD T HARRISON, DefendantlRespondent CUSTODY ORDER AND NOW, TO WIT, this (J,A day of tJ ~ , 2000, upon consideration of the attached Petition for Entry of Agreement, it is hereby dll,.,A ORDERED and DECREED the custody agreement dated the day of O~ , 2000, is adopted as an Order of Court and the parties are bound thereby. Judge t~~ 1/-3 -00 RKS . I i II II..': ~ , Ii I!.:. I 'I ili I " " ! ~ ! !Ii I, ,I Ii II Ii i! !i I", ~ 1l!IMIII'II.", ~,~~ ''W''i ,_~'. ,""'~,~ nTJ! ".' (-'lED-- OfF1CE Tr-:;: :-,!"U"''-{X\;01:AJiY 00 NO\! - J A/1 8: I 4 CUM8cRLi!J~O COUf\'TY PENNSYLVANiA .-.,..",~WJI os_ .~ ~.m~~_ ~,~."'___ - .- 1"f' ~- , .1., ~~ "" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA L. HARRISON, PlaintifIlPetitioner NO. 00-5185 Civil vs. CIVIL ACTION - LAW RONALD T HARRISON, Defendant/Respondent CUSTODY PETITION FOR ENTRY OF AGREEMENT AND NOW, this ~/~ay of tJ~ , 2000, come the parties, G. Patrick O'Connor, Esquire, on behalf of the Plaintiff, Tina L. Harrison, and the Defendant, Ronald T Harrison, pro se, and file their Petition for Entry of Agreement, the following being a statement: I. The petitioner is Tina L. Harrison, who resides at 1133 Columbus Avenue, Apartment I, Lemoyne, Cumberland County, Pennsylvania 17043. 2. The respondent is Ronald T Harrison, who resides at 3131 Old Trail Road, York Haven, York County, Pennsylvania, 17370. 3. The parties are the natural parents of Courtney Harrison, ten years old, birth date, September 21, 1990; Nicole Harrison, eight years old, birth date, February 7, 1992; and William Harrison, five years old, birth date, November 9, 1994. 4. On&~ ,4,/ , 2000, the parties entered into an agreement regarding custody, partial custody and visitation of the children, which is attached hereto and incorporated herein as Exhibit "A" '..1iI' ".'-'- < -' . , >~ - , ':~ 5. The best interest of the children will be served by the Court's entering said custody agreement as set forth as Exhibit "A" as an Order of Court. WHEREFORE, petitioner requests this Court to approve the foregoing agreement and make it an Order of Court. Respectfully submitted, ~~ ",G. Patrick O'Connor, Esquire 3105 Old Gettysburg Road Camp Hill, Pennsylvania 17011 Telephone: 717-737-7760 LD. No. 64720 Attorney for Petitioner ~- - ~-,. -,' :C,,, ,_ ..''j; EXHffiIT "A" CUSTODY AGREEMENT THIS AGREEMENT made and entered into this tR/,Srdayof {J~ 2000, by and between TINA L HARRISON, of 1133 Columbus Avenue, Apartment 1, Lemoyne, Cumberland County, Pennsylvania 17043, the MOTHER, and RONALD T HARRISON, of3131 Old Trail Road, York Haven, York County, Pennsylvania, 17370, the FATHER WHEREAS, the Mother and Father are desirous of providing for the custody of the minor children: COURTNEY HARRISON, ten years old, birth date, September 21, 1990; Nicole Harrison, eight years old, birth date, February 7, 1992; and William Harrison, five years old, birth date, November 9, 1994 (hereafter known as "Children"). NOW, THEREFORE, THIS AGREEMENT WITNESSETH that for and in consideration of the promises and covenants herein contained and intended to be legally bound hereby, it is agreed by and between the parties hereto as follows: L CUSTODY AND VISITATION A The parties hereby designate the Mother to have full legal custodial responsibility for the minor Child. By custodial responsibility it is meant that the Mother shall make major decisions concerning education, medical care, and spiritual upbringing. B. The parties hereby designate Mother to be primary physical custodian of said Children, subject to the rights of partial custody in the Father, as stated below. As a result of such designation, Mother, alone shall have the right and duty to make all day-to-day parental decisions and act as the primary care parent to the Children. Therefore, Mother may, on her signature alone, authorize emergency medical care for the minor Children, authorize absences and special events for said Children in school, and authorize the physician, dentist or other medical person to care for said Children. C. During the period of time when Mother is the primary physical custodian, Father shall have visitation as follows: [a] Every Wednesday from 3:30 p.m. until 7:00 p.ll. and every weekend from Saturday at 5:30 p.m. until Sunday night at 7:30 p.m. [b] Father shall have custody on each Father's Day and Mother shall have custody on each Mother's Day, regardless of any other provisions of this Agreement [c] Father shall have custody on each of the following holidays: New Years Eve through New Year's Day, Easter Day after 1 :00 p.m., Memorial Day, 4th of July, Labor Day, Columbus Day, Halloween, Thanksgiving Day after 1 :00 p.ll., and Christmas Day after] :00 p.m. This schedule shall supersede paragraph [a] above [d] Mother shall have custody on each ofthe following holidays: Easter Day until 1:00 p.m., Thanksgiving Day until 1:00 p.ll., and Christmas Eve through Christmas Day until] :00 p.m. This schedule shall supersede paragraph [a 1 above. . " ~i,L [e] At all other times as mutually agreed upon by the parties. The parties shall consider the desires of the Children in making their decisions. 2. LEGAL COUNSEL The Mother is represented by the law office ofG. Patrick O'Counor, Esquire. The Father has been advised of his rightto seek legal counsel of his choice. Each of the parties agrees that he or she has entered into this Agreement with a complete under- standing of the contents thereof 3. ENFORCEMENT If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or to seek other remedies or relief as may be available to him or her, and the party breaching this Agreement shall be responsible for payment of reasonable legal fees and costs incurred by the other in enforcing his or her rights under this Agreement Failure to seek a remedy for one or more breaches shall not be deemed a waiver of any subsequent breach. 4. ORDER OF THE COURT The parties agree that this Agreement shall be entered as an Order of Court and shall continue in full force and effect until (a) further Order of Court, or (b) stipulation of the parties. <"- -:" 5. ADDITIONAL INSTRUMENTS Each of the parties shall from time to time, at the request of the other, execute, acknowledge, and deliver to the other any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. 6. APPLICABLE LAW The parties agree that, regardless of the children's residence or provisions of the Uniform Child Custody Jurisdiction Act, Pennsylvania shall retain jurisdiction over the custody of the minor Children as long as one or both parents reside with the Commonwealth. 7. BINDING EFFECT This Agreement shall be binding upon the respective parties, their heirs, executors, administrators, successors and assigns. 8. ENTIRE AGREEMENT This Agreement constitntes the entire understanding of the parties and supersedes any and all prior agreements or negotiations between them. IN WITNESS THEREOF, the parties have hereunto set their hands and seals on the day and year first above written. c\~~.~~ TINA L. HARRISON (SEAL) ~'-1.~AL) RONALD T HARRISON ./ . - - , ~ COMMONWEALTH OF PENNSYLVANIA) : SS. COUNTY OF CUMBERLAND ) On this, the /7H-o- day of ()~ ,2000, before me, a Notary Public in and for the state and county aforesaid, the undersigned officer, personally appeared TINA L. HARRISON, known to me (or satisfactorily proven) to be the person described in the foregoing instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. W~ .e~~ Notary Public (SEAL) Notarial Seal . William L. Grubb, Notary Public L wer Allen Twp.. Cumberland County ~ Commission Expires Aug. 13, 2001 COMMONWEALTH OF PENNSYLVANIA) ~ :SS. COUNTY OF CUMBE-RL\iID A~s ) On this, the .:2./ So, day of D:itJ~ , 2000, before me, a Notary Public in and for the state and county aforesaid, the undersigned officer, personally appeared RONALD T HARRISON, known to me (or satisfactorily proven) to be the person described in the foregoing instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. SEAL) ~a1 Seal Charles 1;. McGlIlly.Jr., Notary Public L.atimOIll1\vp.Adams CoUR4' My CorilRllselon~ree NOv. 6,2000 MSmber, I'elInSylvan!a AssochttIon 01 MlIariea . TINA L. HARRISON PlaiI1tifl7Respondent : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 00-5185 Civil RONALD T. HARRISON J)efendantlPetitioner : CIVIL ACTION - LAW :CUS'fODY ORDER OF rOTTRT AND NOW, this 'fAday-()f ~ .. 2001,. <.. J u.. ;:~ h~ ~ upon consideration of PlaiI1tifl's Emergency Petition for Special Relief, it iJ ~-)':' . EM -l"t:I tk ~ (,Ui:ttudy of du;, l1~H,;Il clWdr~ C<:'d1bK.Y IlauiJ01~ }li56le IItwRBe~ an~ '.'JII?om IIauiJBll, Be !nONted to PcddollCl penamg a ("Ub1;Ody COmCl~llce aIlOlUI ltt4'Uiu!S. - 1. ~ . ~/f0\ 'vii ()",,~ ~ ,-" .".'.. I' I' I i'l in: ", "~,_ L~!IlJJfII._" ._,' ~ -Y' ", ~T"- -~ - ~- '" .-- -~.1iIji/l! , "M" _ ,., '~, c_ ',_. ._~_ ~~. ,.,,~~ '"~ Or" FilED--OfFICE OF THE f'POTHONOTARY o I MAR I 2 AM II: 15 CUM8Eliu\ND COUN1Y PENNSYLVANIA" ~ < ,_ ,. ,~"~~__,,,",ry' _~"'~%"'l'c"'(~~!';:Flm)fi"",!~L;i~~ll;fl:lil~_<.,~"",ii!!l~~1~,JW;~"_,H", rUil, Ii!! --"d ,-" 'K'. TINA L. HARRISON Plaintifi7Respondent : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 00-5185 Civil RONALD T. HARRISON DefendantfPetitioner : CIVIL ACTION - LAW : -CUSrBDY EMRR(;ENC'V PETITION FOR "PEnAl, REI,TlU? AND NOW, the -Petitioner, Ronald T. -Harrison, by and through hisartomey, .Jeanne B. Costopoulos, Esquire, of Costopoulos & Welch, files this Emergency Petition for Special Relief simultaneously with-aPetitiGnforContemptand-aver-sasfollows: L The Petitioner, Ronald T. Harrison is an adult individual who currently resides at 3131 Old Trail Road, Y-OrkHaven, York County, -P-ennsylvania, 17370 and he isthenatural-fatherm'the minor children who are the subject of this Custody Action, whose names and dates of birth are as follows: Cowtney Harrison Born September 21, 1990 Nicole Harrison Born February 7, 1992 Wtlliam Harrison Born November 9, 1994 2. The Respondent, TinaL Harrison, is the natural mother of the subject minor {)hildren and is an adult individual who, until February 24,2001, resided at 1133 Columbus Avenue, Lemoyne, Cumberland County,-P-ennsylvania, 17043;hewever,sheleftherresidenceon that date with -the minor children and is currently residing at 3 Ashcreek Laguna Hills, California, 92653 with her paramour, Tony Loll. ,~= ,~ - lii'J~i 3. The minor cbildren had lived with their natural mother at 1133CelumOOs Avenue , Lemoyne, Cumberland County, Pennsylvania, 17043 since on or about July 22, 2000 until February, 24 2001, it is believ.ed they areresidingwiththeir-motherand her paramour, Tony Loll at ~ Ascbreek, Laguna Hills, California, 92653. 4. Petitionerhasootparticipared -as -a party or witness, or in another-capacity, m -other litigation concerning the custody of the children in this or another court. 5. Petitioner does notknow-of-a person nota party to the pmceedings who has physical custody of any of the children or claims to have physical custody or visitation rights with respect to the children. 6. The best interests and permanent welfare of the children will be served by granting the relief requested because: a. In or about January, 2001, Respondent informed Petitioner that she was moving to Califomia-t-o be withherpl\l'lUOOur,'I'ooyLoUand taking the three minorchiklrenwith her. See, letter dated January 7, 2001 from Respondent to Petitioner, provided herewith as Exhibit A b. Petitioner stated lIisOOjections to such amove several timesteRespondent verbally and by way ofletter dated January 23, 2001, a copy of which is provided herewith as Exlnbit B. c. Petitioner wants primary physical custody of the children pending a hearing before This HonorableCourt-to determineJf-Respertdent-may remove the childrentoCaIifumia. 7. It is not Petitioner's intention to alienate the children from their mother; Petitioner merely wants to ensure-that, -if-Respendent-is-t{}be~to remGvethechildr~ w-C-alifornia, it be -e!>,."_ - ~ L. .. ~ ~.~ done in accordance with the laws. ofthecCllmmollwealtlwfPennsylv.ania.andihat.an,a\ternate visitation scheduled be established prior to the children's removal. 8. Plaintiffhas the means, desire -and ability to Glfe forthe.childrenpending -.a-hearing on this matter. 9. Eachparentwhose parental.l'ights -to-thecl1ildren have not beentemlinated-and the person who has physical custody of the children have been named as parties to this action. No other persons are known-rohaveorclaim a righttocustOOy-{)l' visitation of the children to be given ootice of the pendency of this action and the right to intervene. WHEREFORE, due to the exigency -of the sitnation,the Plainti1f respectfully request-s Your Honorable Court will grant him temporary primary custody of Courtney Hanison, Nicole Hanison, and William Hao:iSOllpending -a full hearing ,in the matter and further order that any visitation by Defendant be supervised. Respectfully submitted, B. Costopoulos, Esquire CO OPOULOS & WEL-CH 1400 North Second Street Harrisburg, Pennsylvania 17102 Telephone: (717) 221-0900 Fax: (717) 22100904 Attorney I.D. No. 34962 ATTORNEY FOR PETITIONER Dated: 1/7 !d/ . " <~'- --",'~ _e - Januarv 7. 200 I Dear Ron. I have decided to write you this letter so that I can be sure I say everything I want to say. Emotions tend to run a little high when we talk face to face. and I wanted to make sure I explained myself completely. I don't want there to be any misunderstandings. First of all, I want to say how happy I am that you have started to date. I really do want you to be happy. The kids seem to like her. The best thing for our kids is for both of their parents to be happy. I know if we continue working together, we will always keep our kids happy. I do also want to mention something else. I want you to know that my leaving you had nothing to do with Tony. I know what you are thinking and you are wrong. As you know, Tony and I have been friends for over 12 years now. He is a very nice guy, and if the sitnation were different, you would probably like him The kids certainly do. I hope you know that I would never do anything that wasn't good for these kids. Tony is an excellent father. lfyou were to meet Summer, and see how wonderful she is, you would see the proof He was so terrific with our kids. He played with them, he taught them things, he was patient with them. When Nicole woke up crying with an ear ache in the middle of the night, he really stepped up and took care of her. But, I want to assure you that even though we have been friends for a long time, our relationship did not turn romantic until after I filed for divorce. " I know I told you that I wasn't interested in getting involved with another man because I wouldn't be able to trust anyone with the kids. Well, I was wrong. Knowing Tony the way I do, and for as long as I have, and seeing how awesome Summer is and how much she loves him and he loves her. And most of all, watching him interact with our three kids, has convinced me that he is most trustworthy. I want you to believe that so that you never have to worry about the kids. In fact, just the opposite. Tony would be a very stable, happy influence on them, and on me. He really is a great guy. I am telling you all of this because Tony and I have become more serious than I had anticipated. Over the holidays, he asked me to marry him. I said yes, and the kids are very happy about it Obviously, with the situation being what it is, that won't happen any time soon. But, I would like to move out there with the kids when the ,school year is over. That will give us plenty of time to spend together before we get married. This way, all 6 of us will know it's the right thing, I assure you that I am not trying to take the kids from you. You will always be their father, and they will always love you. I will make sure that they still get to see you. In fact, we were hoping that you too may want to re-locate yourself to California and start a new life. I know you have always wanted to move somewhere warmer. If you did that, we could keep the same custody arrangements. If you decide not to move, we will have to work out other arrangements. I. _~ _d ,'-"' m . I already have a very good job lined up, working from home. I \\i.ill have the flexibility of going into the kids classes and being home on their days off I will be doing administrative work, which means no more dirty diapers. I will be making more money, working less hours, and have much more time for the kids. Which, you know is very important to me. I have sat down with the kids on numerous occasions to discuss this with them. And they are very excited about the move. Of course, they would love it if you were to move there too. They truly loved Tony and Summer. And they are truly excited about living in California and making new friends. There are tons of children for them to play with and make friends with. They will be going to a very good school, in a very safe area. You have told me on numerous occasions that you still love me, and that you always \\'ill. Well, if you meant it, you will love me enough to let me go and fet me be happy. Love me enough to allow me to have the happiness I need and deserve. Love your kids enough to re-Iocate yourself to California too. What would be keeping you in PA? I want so much for us to be able to get past all of this and become mends down the road. I know that we both want what is best for our kids. And I have done everything in my power to support your new life with your new girlfriend. I have only had positive things to say about her to the kids. I hope, for the kids' sake, that you will do the same for me. You would only be hurting them by putting down our move and our new life. They need to feel happy and secure about the whole thing. And you can help with that. And maybe, we really will be friends, working together to raise happy kids. , I am very sorry if this letter upsets you. I truly don't want that to happen. Like I said before, I would love for you to end up as happy as I am right now. If after reading this letter, you have any questions, please feel free to write or calL I would be glad to help ease your mind any way I can. Take care of yourself, Tina ~ - = _ r. -~, ,~', _ , - , ,-.-~ -, , "1& . '. , ~~~ I . J 2-.d {; I n\~~~ ~~~~~ ~ ~ '7,2.-<'01. di:J. \ ~ tp ~~ 'Cr^- ~~~~ \. ~~ ~ ~~~~( ~, ~I ~) ~/~J ~-~)F~~l ~~l ~. . .~~ ~?~~~~ ~!t ',~~~ ~~lyci ~t~ ~ ,I ~.~.~~ ,. \ .~J ~ ~~ ~~,~ 1ML~ - ,- .__'0"" .." .~-~~ I ~ ~ ~ ~~( d", ~ ~~W-~) . CI\ ~ ~ cA-A>! (1\ ~ ~ \~i~ ~ '. c1 ~ ~ 0---:" . ~ ~~ ~ 'z..-..,..- ~'~'~,~ ~ ""Is I <'/ ~ LJ-.P t" ~ ,(7\ M>L ' ~~U1 , (;~~ ~~ ~ ~ ~vLo.y~ ~ ~+t M..' ;::1 ~ ~ ~~I~ ~~u. ~< O~1~.~t. ~ ~ (L ~~ oU>'~ ~ ~ ~ ~ II-- . '-1~ ~'l.(J ~c}. ~ . ~ ~ ~. \j .-/ ~ --.::::::---- ,. ..,", " " - ""'''t TINA L. HARRISON PlaintiflYRespondent : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 00-5185 Civil RONALD T H:ARRfSON DefendantJPetitioner : -CIVIL A.GfION - LAW : CUSTODY VERffiTC'A.TUlN I, Ronald T. Harrison, hereby verifY that the statements made in the foregoing Custody Complaint are trueand-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. Pate: ".. . ,....., . (J! Signature: ~. -RunaldT. Harrison ~i ' TINA L. HARRISON P1aintifJ7Respondent : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 00-5185 Civil RONALD T. HARRISON .DetelldanllPelitiotlel : CIVIL ACTION -LAW :C-UST-DDY rnRTTFJrA TF, OF sERvrrn I, Jeanne B. Costopoulos,hereby-ceFtilYtbat lam this day serving acopy-ef-the foregoing document upon the person, and in the manner, indicated below, which service satisfies the requirements ofthePARulesofCivil Procedure, -by-depositing a copy of the samewith-theUnited States Post Office at Harrisburg, Pennsylvania, through first class mail, prepaid, and addressed as follows: G. Patrick O'Connor, Esquire 3105 Old Gettysburg Road Camp Hill, Pennsylvania 17011 Tina Harrison c/o Tony Loll 3 Ashcreek Laguna Hills, CA 92653 and ~ '~,' Date: Y7/r; J ,-, "'- ,,'- - - ~-, ": Tina Harrison 27881 LaPaz.Road Suite 0156 . Laguna Niguel, CA 92677 BY: Jeanne ~stoPoulos, E~utre COSTQPOULOS &WELCH 1400 North Second Street Harrisburg, Pennsylvania 17102 Telephone: (717) 221-0900 Fax: (717)221,0904 Attorney LD. No. 34962 ATTORNEY FOR PETITIONER -. ~ "~~ ~1; . - TINA L. HARRISON PLAINTIFF V. RONALD T. HARRISON DEFENDANT IN TIIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA 00-5185 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, March 12, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on Monday, April 09, 2001 at 11:00 a.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, tq 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. FOR THE COURT, By: Isl Melissa P. Greevy. Esq. t/7 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 HA VB 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~ ^ -~ - -~ -. " ~:"Jt ;~r-\ ~ ',,-, ("'" I , .Cl.r'Ui-!-!r'c 'r- :-,''';".,_ ' "-'l. - _, -"','-"" liL,:("':-\if)';."'t;,U"~ . ; ;:....h\ !t\hr (lJ I'MR 15 PH I: 1~6 CUMBEF1!J;NO COUN7Y PENNSYLVANIA \ 3.JS~-?J/ y~~ ;d4~~ 3/~tJ/ ~ ~ :t~ 4 CJ~ 3/S-t1/ ~ ~:d; ~ ~ / - I 1'''lWRI ., < -~ . .....,.,." ~~ - .~'"~ r~~ ~ '"'~=,- ~ '!ftl!1!P!lfO:rt-"_~""'" ="~ ~~-.~- --, "~ TINA L. HARRISON P1aintiIDRespondent : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 00-5185 Civil RONALD T HARRISON J)erendantJpetitioner : CIVIL ACTION - LAW :CUSI-0DY NOTICE AND ORDER TO APPEAR Legal proceedings have been brought against you alleging you have willfully disobeyed an order of court for -QIstody. If you wish to defend against the claim set forth in the following pages, you may but are not required to file in writing with the court your defenses or objections. Whether or not you file in writing with the court your defenses or objections, you must appear in personia court-on ,at .m., in Courtroom , Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT APPEAR IN PERSON, THE COURT MAY ISSUE A WARRANT FOR YOUR ARRESI. If the court finds that you have willfully failed to comply with its order for custody, you may be found to be in contempt of court and committed to jail, fined or both. YOU SHOULD TAKE TIDSPAPER TO YOUR LAWYER AT ONCE. IFYOUDO 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 Telephone: 800-990-9108 BY THE COURT: Date: Edward E. Guido, J. A,o<U'/' ~. TINA L. HARRISON Plaintifl7Respondent THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 00-5185 Civil RONALD T. HARRISON DefundantJPetitioner : CIVIL ACTION -LAW ~ -{::USTODY TO THE HONORABLE EDWARD E. GUIDO, JUDGE OF SAID COURT: PETITION FOR CIVIL CONTEMPT FOR DlSOBEDIENC-E-OFC-USTODY ORDER AND NOW COMES the DefendantJPetitioner, Ronald T. Harrison, by and through his attorney, JeanneB.Costopoulos,Esquire, -of -Costopoulos and Welch, and files the .following Petition Regarding Custody, respectfully representing as follows: I. That on November 2, 2000, Judge Guido signed an Order to adopting a custody agreement dated October 21, 2000 as an Order of Court, awarding Petitioner temporary physical custody/visitatio.n-oftheminorchildren,{;oortney--Harri.son, date of birth September 21 , .1990; Nicole Harrison, date of birth February 7, 1992; and William Harrison, date of birth November 9, 1994. A true andoorrect-GoPY o.fthe Order and Custody Agreement is attached to this-petition. 2. Respondent willfully failed to abide by that Order in that on or about February 24, 2001, she remov.edtheminor childrentoCaliffimia,without petitioning This Honorable Court for modification of the Order of Court and with complete disregard for Petitioner's stated objections to said move. 3. Defendant has incurred lawyers fees in the amount of$350.00 in the preparation and presentat~-efthis-Petition. -<.,- WHEREFORE, Defendant prays this-Honorable Court will find Plaintiff to be in contempt, impose appropriate sanctions, and order reimbursement of attorney's fees in the amount of$350.00. Respectfully submitted: aniV---- - Je . Costopoulos, Esquire COSTOPOUL08& WEtCH 1400 North Second Street Harrisburg, Pennsylvania 17102 Telephone: (717) 221-0900 Fax: (717) 221-0904 Attorney ID. No. 34962 ATTORNEY FOR PETITIONER Dated: -;/7 ftl ~." . - ,t~ OCT 3 1 200CP? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA L HARRISON, PlaintifflPetitioner NO. 00-5185 Civil vs. CIVIL ACTION - LAW RONALD T HARRISON, DefendantlRespondent CUSTODY ORDER AND NOW, TO WIT, this /(nJ. day of ~vernbe R, , 2000, upon consideration of the attached Petition for Entry of Agreement, it is hereby ORDERED and DECREED the custody agreement dated the ),/ ~t day of 2000, is adopted as an Order of Court and the parties are , bound thereby. BY THE COURT IS; &/Jf1AJ t. adll.1n Judge TRUE COpy fROM RECCRD tn Testimony whereof, I hoFe u;,to 'c, --.1'{ hand and the seal of sa'd Court a.t fariis!2. Pa. Th; .....3...... Ha f~....E.J.O". 41. -P" . , .. . . -1"-- ,.. " rothonotarf '.". ", -~ ,-, ~~ . :~ ~:" EXHIBIT "A" CUSTODY AGREEMENT TI-llS AGREEMENT made and entered into this :?/ Jr day of ~gz;;zbr' 2000, by and between TINA L. HARRISON, of 1133 Columbus Avenue, Apartment I, Lemoyne, Cumberland County, Pennsylvania 17043, the MOTHER, and RONALD T HARRISON, of3131 Old Trail Road, York Haven, York COUI)ty, Pennsylvania, 17370, the FATHER. WHEREAS, the Mother and Father are desirous of providing for the custody of the minor children: COURTNEY HARRISON, ten years old, birth date, September 21, 1990; Nicole Harrison, eight years old, birth date, February 7, 1992; and William Harrison, five years old, birth date, November 9, 1994 (hereafter known as "Children"). , NOW, THEREFORE, TI-llS AGREEMENT WITNESSETH that for and in consideration of the promises and covenants herein contained and intended to be legally bound hereby, it is agreed by and between the parties hereto as follows: I. CUSTODY AND VISITATION A The parties hereby designate the Mother to have full legal custodial responsibility for the minor Child. By custodial responsibility it is meant that the Mother shall make major decisions concerning education, medical care, and spiritnal upbringing. B. The parties hereby designate Mother to be primary physical custodian of said Children, subject to the rights of partial custody in the Father, as stated below As a result of such designation, Mother, alone shall have the right and duty to I l - - ~ "~ '1 make all day-to-day parental decisions and act as the primary care parent to the Children. Therefore, Mother may, on her signature alone, authorize emergency medical care for the minor Children, authorize absences and special events for said Children in school, and authorize the physician, dentist or other medical person to care for said Children. C. During the period of time when Mother is the primary physical custodian, Father shall have visitation as follows: [a] Every Wednesday from 3:30 p.m. until 7:00 p.m. and every weekend from Saturday at 5:30 p.m. until Sunday night at 7:30 p.rn. . Father shall have custody on each Father's Day and Mother shall have custody on each Mother's Day, regardless of any other provisions of this Agreement [c] Father shall have custody on each of the following holidays: New [b] -Years Eve through New Year's Day, Easter Day after 1 :00 p.m., Memorial Day, 4th of July, Labor Day, Columbus Day, Halloween, Thanksgiving Day after 1 :00 p.m., and Christmas Day after 1 :00 p.m. This schedule shall supersede paragraph [a] above. [d] Mother shall have custody on each of the following holidays: Easter Day until 1 :00 p.rn., Thanksgiving Day until 1:00 p.m., and Christmas Eve through Christmas Day until 1 :00 p.m. This schedule shall supersede paragraph [a] above. [e] At all other times as mutually agreed upon by the parties. The parties shall consider the desires of the Children in making their decisions. 2. LEGAL COUNSEL The Mother is represented by the law office ofG. Patrick O'Connor, Esquire. The Father has been advised of his right to seek legal counsel of his choice. Each of the parties agrees that he or she has entered into this Agreement with a complete under- standing of the contents thereof 3. ENFORCEMENT , If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or to seek other remedies or relief as may be available to him or her, and the party breaching this Agreement shall be responsible for payment of reasonable legal fees and costs incurred by the other in enforcing his or her rights under this Agreement. Failure to seek a remedy for one or more breaches shall not be deemed a waiver of any subsequent breach. 4. ORDER OF THE COURT The parties agree that this Agreement shall be entered as an Order of Court and shall continue in full force and effect until (a) further Order of Court, or (b) stipulation of the parties. "'-'c. c' '~"""'-, , ),-~ -~. 5. ADDITIONAL INSTRillvIENTS Each of the parties shall from time to time, at the request of the other, execute, acknowledge, and deliver to the other any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. 6. APPLICABLE LAW The parties agree that, regardless ofthe children's residence or provisions of the Uniform Child Custody Jurisdiction Act, Pennsylvania shall retain jurisdiction over the custody of the minor Children as long as one or both parents reside with the Commonwealth. 7. BINDING EFFECT This Agreement shall be binding upon the respective parties, their heirs, executors, . administrators, successors and assigns. 8. ENTIRE AGREEMENT This Agreement constitntes the entire understanding of the parties and supersedes any and all prior agreements or negotiations between them IN WITNESS THEREOF, the parties have h\lreunto set their hands and seals on the day and year first above written. c\~ ~.f)~A)U~ TINA L. HARRISON (SEAL) ~J.-'--i. ~AL) RONALD T HARRISON ./ 0"' ~, COMMONWEALTH OF PENNSYLVANIA) : SS. COUNTY OF CUMBERLAND ) On this, the /1 f'k- day of oet;iv,/ ,2000, before me, a Notary Public in and for the state and county aforesaid, the undersigned officer, personally appeared TINA L. HARRISON, known to me (or satisfactorily proven) to be the person described in the foregoing instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. W~L /~Jl Notary Public \ (SEAL) COMMONWEALTH OF PENNSYLVANIA) ~ :SS. COUNTY OF .cUMDERLAlID Jtbllms ) Notarial Seal . William L. Grubb, Notary Public Lower Allen Twp__ Cumberland Coun~ My commission Expires Aug. 13,200 On this, the ,;2., !,I day of ~~ , 2000, before me, a Notary Public in and for the state and county aforesaid, the undersigned officer, personally appeared RONALD T. HARRISON, known to me (or satisfactorily proven) to be the person described in the foregoing instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ubli NoIarIaI Seal Charles E. McGinty Jr., Notary Public LaUmore Twp. Adams County My Comnllselon EXpltell Nov. 6, 2000 Memcer, PennsylvanIa Association 01 NOIlIl1es ,. " TINA L. HARRISON Plaintiff7Respondent v. RONALD T. HARRISON DefendantJPetitioner ~ ~ : TIIE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 00-5185 Civil : CIVIL ACTION - LAW : -CUS'f-0l}y VERIFICATION I, Ronald T. Harrisen,hereby..vemy.that the statements. madeinthe,for-egoingP-etitien for Petition for Civil Contempt for Disobedience of Custody Order are true and correct. I understand that false statemem:-s her-ein are made subject-te-the-penaltiesof 18Pa,C. S.~904, relatingt-o unsworn falsification to authorities. Date: 2. ''V1 .0 I Signature: ~~.~ -Ronald 'f. Harrillon ---, /. ./ ", -"'"'-', TINAL. HARRISON Plaintifl7Respondent : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 00-5185 Civil RONALD T. HARRISON DefendantfPetitoner : CIVIL ACTION - LAW : --CUS'f-oDY CERTIFICATE OF, SERVICE I, Jeanne B. Costopoolos, Esquire,her-ebycertifYthat I am this day serving a copy .of-the foregoing document upon the person, and in the manner, indicated below, which service satisfies the requirements of the PA Rules of Civil Procedure, -by depositing a copy of the same with.the United States Post Office at Harrisburg, Pennsylvania, through first class mail, prepaid, and addressed as follows: G. Patrick O'Counor, Esquire 3105 Old Gettysburg Road Camp Hill, Pennsylvania 17011 Tina Harrison 27881 La Paz Road Suite 0156 Laguna Nignel, .CA 92677 and .,_ _0 - .' .> ~ . -- . ~,,;. , Tina Harrison c/o Tony Loll 3 Ashcreek Laguna Hills, CA 92653 DaWd: . ) Iliff I ;it.- . Janp/1 e e B. Costopoulos, Esquire -~.~ " '~.- ' MAY2~ TINA L. HARRISON, Plaintiff, :IN THE COURT OF COMMON PLEAS :OF CUMBERLAND COUNTY, PENNSYLVANIA v. No. 00-5185 CIVIL ACTION - LAW RONALD T. HARRISON, Defendant. IN CUSTODY ORDER OF COURT AND NOW, this 23'd day of May, 2001, the Conciliator, being advised by counsel for both parties that the Defendant wishes to withdraw his Petition for Contemp and Emergency Petition for Special Relief, hereby relinquishes jurisdiction in this case. The Custody Conciliation Conference scheduled for June 18,2001 is canceled. Me is Peel Greevy, Custody Conciliator ie' ~ I''''; ,'" ~rr'lJn~Z fl1il;r'-"~~~m.lili:rjjo':~~'tJi:.tb ,.,-,~ "'" b.::: CI> ~ i"S LD wQ c') 6-< 'z O"-~ "T" U;<: --c! ~c~-t CL- 0::3 (?f~, :?;&5 C1Q-= ::Jz LL~ : eez o::~: z uJW ::=; 0::10.... ;---- OJ :::;; u.- :::> (.; .0 U ", '., '. _:;,~~"-,-,--~~ -- ....'l i i I , I I I I I ,