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HomeMy WebLinkAbout00-05670 ,""" ' ~' ,~, - ... ETHEL E. CASSEL , Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V$. NO. 00-5670 RONALD G. WRIGHT, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this & ~ day of (5 ~ , 2000, upon consideration of the attached Custody Conciliation Summary Report, it appearing that the parties have reached an agreement, it is hereby directed as follows: 1. Legal Custody, The parties, Ethel E, Cassel and Ronald G. Wright, shall have shared legal custody of the minor Child, Ashley N. Wright, born April 4, 1986, Each party shall have an equal right, to be exercised jointly with the other, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of this paragraph, each party shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. To the extent one party has possession of any such records or information, that party shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other. 2. Physical Custody. Primary physical custody shall be in the Maternal Grandmother, Ethel E. Cassel, subject to liberal periods of partial physical custody in the Father, Ronald G. Wright. Father's periods of partial physical custody shall be at such times as the parties shall mutually agree. ;>- . ~ 00 ~, $> 1\' l<< \O'~ J. BY THE COURT, '-'~l~'" "' ." ,~~v '~f.!~~1i~j~:oi'~!!l~'Ui$,j \liNV^lASNN3d , 'N'n('"~' n:\'\r!\Qmlln'l f\l. . ~ ..)0.,) ',~"" ".', ""," ..... - "'001' "'u' .,. PH tJ.. iJld G -0 ,",;'i; AtN 1(~1'~X~~\2;., .;i"l ,..I'.,' , ~,~ - -^ ,U " ~. ,~ __~" ~ 'v, '"-'" ",~",- " _, H" ~ '" --,-- '~~'~': -' '" " =:r'~ No. 00-5670 Dist: StefanieA. Morrison, Esquire, Keefer, Wood, Allen & Rahal, PO Box 11963, Harrisburg, PA 17108 Ethel E. Cassel, 605 S. Market Street, Mechanlcsburg, PA 17050 Ronald G. Wright, 14 F Street, Carlisle, PA 17013 Tammy A. Cassel 48 Thompson Creek Drive, Shippensburg, PA 17257 r " ~ { . .~ ~-! OCT 0 3 2000JiJ . . ETHEL E. CASSEL, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00"5670 RONALD G. WRIGHT, Defendant CIVIL ACTION - LAW CUSTODY il Ii CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: ;,1 I ~,l !'; II 'i I, ", i1 ., i ;1 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Ashley N. Wright April 4, 1986 Maternal Grandmother 2. A Conciliation Conference was held on September 25, 2000, with the following individuals in attendance: Ethel E. Cassel, the Maternal Grandmother; Ronald G. Wright, the Father; and Stefanie A. Morrison, Esquire. Mother did not appear. 3. Although the pleadings would indicate that Ms. Morrison was representing Plaintiff, in fact both Mrs. Cassel and Mr. Wright believed that Ms. Morrison was representing the Defendant, Mr. Wright. The Child's Mother, Tammy A. Cassel, was served with a copy of the Complaint for Custody Order attached thereto. Ms. Morrison has provided a notarized statement indicating that Mother, Tammy A. Cassel, has consented to the Order proposed in the documents of which she acknowledges receipt. Mother did not attend the Conference. 4. The parties have reached an agreement with regard to custody as indicated in the Order attached hereto, ~jo9 fzo-v-v Da UJd;2~ Melissa Peel Greevy, Esquire Custody Conciliator ..."'=~~ , ," , ~ ,J. ~,~', ID.'L .' ETIIEL E. CASSEL PLAINTIFF V, RONALD G. WRIGHT DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 00-5670 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 22nd day of Au~ust , 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Melissa P. Greevy, Esq. . the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the 25th day of Sel'tember ,2000, at 9:15 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, to defme 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 elissa P. Greev s 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 ONq:. 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 . "..> 0'"" '"_,""""'~"~~";'""" '"'<V~' ",_ -".., '-'~"'J"'"'''''''''._'~'~:_>'''''''r''''"l'it'''.'_"'1",,"'''''''- f':: U:f}{}i:f~::E OF L'I-{i'n'~C}\!DTl\riY N' ~,,<" ~2 ['0.1 3'" I u:; HU'~'I' i. (n . ,) . CUMGt:di.},I',U COUWY PENNSYLVANiA ~OQm !AI ~ ~ ~ ~ '7?J~ "007';:>,4;/ 7l~ ~ -d; dJ;I. 'IJ'O)d.t?tJ ~~p 4f~ ~,,~ " ". ' . ~ J\,~~,__, ~.. ,r , ~lJi ~ ~' ~"~-,..,~. "I" ~,)~"l,,,".~~fil~:~'!'i'/I;j,'lJIl'!lf'~~~~~"~_~ ^" ~:c' ',~'~<\',;,'i"'-"~ ,-~"~,__;,,, 00' " '<;0,'"'' ;'" '" "c"O " '," ",' ,'-", "" ,o;",~",,--,-- , , _ T , " " <<,~"" "__,c. ;':,,~;., <I AUG 1 B 2~ II ETHEL E. CASSEL, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW CUSTODY NO.2000- S"t,76 (]::':'l(T02.YY") RONALD G. WRIGHT, Defendant ORDER AND NOW, this day of , 2000, upon consideration of . the attached complaint, it is hereby Ordered that Ethel E. Cassel shall have primary physical custody of Ashley N. Wright and shared legal custody of Ashley N. Wright. BY THE COURT: Date: J. 0; '," ,"., ^',,-" ",.~~. ""-'>,00","-, ~., :Ie' ""C..;' ,>" ," ,n ,.',-, _ ,,'C',> " _ "'~";': ,~,,,"'>f. "c;,,,;,,~,;,: ~'; ,,",""' ',L '-,", ,', ;,,>" ETHEL E. CASSEL, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW CUSTODY NO. 2000- s':: 70 cw.:.e I~ RONALD G. WRIGHT, Defendant ORDER AND NOW, this day of , 2000, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at on the day of , at m., for a Pre- Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into an 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 Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans With Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at , "'. '.-J;"""""'~','~O,:".~ '"oC_',,",,"'.,L',.., 0, ,\,o~' ,>,';;cc,l ,.", ,D,",.,_',C,','." ' , ",.- ';,'"'~~'~,',;,, , -',;:,,-',, " '~ 'T.' " ~' ;. ,,:,j 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 (717) 249-3166 . ""'" "L,__ " "" ,,-,,,'-'~,",'''''",, ,," ,--~,' ", '<"',':";'< ' ' ,,' be,'; ~',~, " ,'.'~:.o""{O"",;" ' ,,'I . '~ ! I :i i ~ :1 II I' 11 d '.i .' I !I :1 , I j ~ 'I fI 11 ,1 Ii ~J " II H iJ ,I " , : ETHEL E. CASSEL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. CUSTODY RONALD G. WRIGHT, NO. 2000- Defendant This matter relates to the custody of Ashley N. Wright, the minor child of the Defendant and Tammy A. Cassel. NOTICE If you wish to defend, you must enter a written appearance personally or by attorney and file your defenses or objections in writing with the court. You are warned that if you fail to do so the case may proceed without you and an order or judgment may be entered against you without further notice for the relief requested by the plaintiff. You may lose money or property or other rights important to you, including custody of children. 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 (717) 249-3166 ,'"",--->-,'"," "','","^, ;'.,r'J',. '_',C,''; "',",", '..-', ." ,:~, "':"'"",,,"":.,; . ,"< ,.---,--, .c,,',''j ,'I "~, ETHEL E. CASSEL, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD G. WRIGHT, Defendant CIVIL ACTION - LAW NO. 2000- SV70 ~1 tv-- COMPLAINT FOR CUSTODY 1. The plaintiff is Ethel E. Cassel, residing at 605 South Market Street, Mechanicsburg, PA 17050. 2. 17013. The defendant is Ronald G. Wright, residing at 14 F Street, Carlisle, PA 3. Plaintiff seeks custody of the following child: Ashley N. Wright 14 F Street Carlisle, PA 17013 Age 14 4. The child was not born out of wedlock. 5. The child is presently in the custody of Ronald G. Wright, who resides at 14 F Street, Carlisle, PA 17013. 6. During the past five years, the child has resided with the following persons and at the following addresses: Ronald G. Wright 14 F Street Carlisle, PA 17013 Since 1990 7. The mother of the child is Tammy A. Cassel, currently residing at 48 Thompson Creek Drive, Shippensburg, Cumberland County, Pennsylvania 17257. The child has had no contact with her mother since 1990. 8. She is divorced. 9. The relationship of plaintiff to the child is that of maternal grandmother. The plaintiff currently resides with the following persons: Matthew J. Cassel Grandson -- '.,~ '>";,',',,,~,~ ."' ,.,',,' '" ,',,';", '.:',"''0.':'-",' ";ii,,,';' -" ' " . , , '. ,"" . "",;';'. -';;' ,'. "ifl'1t I 1 O. The relationship of defendant to the child is that of father. The defendant currently resides with the following persons: Zina K. Wright Wife Brooke E. Wright Daughter Trevor J. Wright Son 11. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 12. Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. 13. 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. The mother of the child is being provided notification of this proceeding in the event she desires to contest this custody arrangement. 14. The best interest and permanent welfare of the child will be served by granting the relief requested because all parties to this action are in agreement that Ashley does not get along with her stepmother, Zina K. Wright, and permitting Ashley to move in and live with her maternal grandmother, who can and will provide an amicable, stable and pleasant living environment, is in the best interest and permanent welfare of the child. 15. The person who has physical custody of the child has been named as a party in this action. While the child's mother has not been named as a party to this action, she will be provided notification of this proceeding in the event she desires to contest this custody arrangement. The child's mother has not had contact with the child since 1986. However, her parental rights to the child have not been terminated. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Tammy A. Cassel 48 Thompson Creek Drive Shippensburg, PA 17257 Mother of child 16. All parties to this Complaint, as well as the mother of the minor child, consent to Ethel E. Cassel being given custody of Ashley N. Wright. Each party has signed/ will be asked to sign a consent evidencing their agreement to this custody arrangement. These consent are attached to this Complaint as Exhibit "A" and incorporated by this reference thereto. Wherefore, plaintiff requests the court to grant custody of the child. By: Stefanie A. 0 ISO Attorney for Plaintiff ~ ,o_,_",;',j:,,;,,',,''-:''} VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. ~~/!'L/ ? ~~ Ethel E. Cassel , ,"',",'c~ ""," ~,"" "~",,,.' , ',~ ',,,~~~';";~, :" '.," ,', ~'::'~:.'~,-,'..i~"-- ~"1 CERTIFICATE OF SERVICE I, Stefanie A. Morrison, Esquire, the attorney for Plaintiff, hereby certify that I have served the foregoing paper upon Defendant this date by depositing a true and correct copy of the same in the United States mail, first-class postage prepaid, addressed as follows: 14 F. Street Carlisle, PA 17013 Dated: August \6 ,2000 ~ ,-'- ,,,",1;,,',</,;, " ,',"C ,",,~ '_,..,',"__'. :i--,.';." .'''. "M , ;,'"," ',..' '~ ,. ",.f ,<,.:--"'~ 'J". ,. >". .',c,,',',' --,,-'< " . ",.' ,- '--" , ,'" ~.' ,", ,0 ;. __', \, ", ~. " CERTIFICATE OF SERVICE I, Stefanie A. Morrison, Esquire, the attorney for Plaintiff, hereby certify that I have served the foregoing paper upon Tammy A. Cassel, this date by depositing a true and correct copy of the same in the United States mail, first-class postage prepaid, addressed as follows: 48 Thompson Creek Drive Shippensburg, PA 17257 ~ Dated: August ~, 2000 ..,",,'" -- " .I~ ''';;'h-i "-';' '-.i'"",~ ^,,'.' ',' ,~ ~c ~, '."" ;C'~ ,;,~ ..<'< ; ,,' "" --, ,-- '~ ",,-' CONSENT TO THE CUSTODY ARRANGEMENT FOR ASHLEY N. WRIGHT THE UNDERSIGNED, ETHEL E. CASSEL, Plaintiff to the Complaint for Custody of Ashley N. Wright, hereby consents to the custody arrangement proposed in the Complaint for Custody and Order attached thereto. The undersigned further acknowledges receipt of a copy of the Complaint and Order. ~ ;E" ~ ETHEL E. CASSEL STATE OF PENNSYLVANIA COUNTY OF CLlnLbVW On this, the I S~ay of SS ~ , 2000, before me, the undersigned officer, personally appeared ETHEL E. CASSEL, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledges that she executed the same as her free and voluntary act for the purpose expressed therein. IN WITNESS WHEREOF, I have hereunder set my hand and official seal. *}~ NOTARIAL SEAL C CYNTHIA J. RULE, Notary Public 8!!lP HIH Boro.. ClJ.mberland County .1 ,.24, 2004 "". ,,,~~,--, , L '__ .~"";'i_ "''-'~'-<;;."""""o.":,u:'<:'-,y,'~",..,:.,~,',,:-;,, '~", __ "_"', ~'," "," ~"', '.' ~ '" CONSENT TO THE CUSTODY ARRANGEMENT FOR ASHLEY N. WRIGHT THE UNDERSIGNED, RONALD G. WRIGHT, Defendant to the Complaint for Custody of Ashley N. Wright, hereby consents to the custody arrangement proposed in the Complaint for Custody and Order attached thereto. The undersigned further "kn=I""g~ roce1pt of a oopy of th, ComPla~ OJ~- RONALD G. WRIGHT STATE OF PENNSYLVANIA SS COUNTY OF CL.c~U-~: On this, the I Sf1..day of /~ ,2000, before me, the u~derSig~ed officer, personally appeared RONALD G. WRIGHT, known to me (or satlsfactonly proven) to be the person whose name is subscribed to the within instrument, and acknowledges that he executed the same as his free and voluntary act for the purpose expressed therein. IN WITNESS WHEREOF, I have hereunder set my hand and official seal. ~?f2L NOTARIAL SEAL CYNTHIA J. 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