HomeMy WebLinkAbout00-05674
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LARRY ANDERSON,
Petitioner
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. oO-:Si;'1""/CIVILTERM
PATRICIA ANDERSON,
Respondent
: CUSTODY
ORDER OF COURT
ANDNOW ~t> 1(,
.2000, upon consideration of the attached Emergency Petition for
Special Relief, it is hereby directed that the parties and their respective counsel appear before this Honorable
Court, at a hearing scheduled for F r I .4_) 1 on the ~ day of J4 ..j (:)~..::. t
2000, at 2: S 0 o'clock, ~.m., Cumberland County Courthouse, Courtroom Number I
Carlisle, Pennsylvania. tL L /,' I J' D I t
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FURTH ORE, upon review of the attached EMERGENCY PETITION FOR SPECIAL
RELIEF, it is HERE Y DIRECTED that Petiti er, Larry Anderson, sha I have primary p sical custody
between now and the date of an future custody hearing u
ofCecilee Anderson, age leven years, granting to P itioner temporary, pri ary physical cust dy of the
child subject to temporary VI 'tation to Respondent,
HEARING is conducted. However, spondent is prohibited
Jurisdiction without further ORDER OF COURT.
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Larry Anderson,
Petitioner
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
: No. frV ,,'(. 7 'I ~ J-'-"'-
Patricia Anderson,
Respondent
: CIVIL ACTION" - LAW
: CUSTODY
PETITION FOR EMERGENCY RELIEF
AND NOW, comes the Petitioner, Larry Anderson, by and through his attorney, Paul
Bradford OIT, Esquire, and avers the following in support of this Petition for Emergency Relief:
1. The Petitioner, Larry Anderson, is an adult individual who currently resides at 15
East Street, Mt. Holly Springs, Cumberland County, Pennsylvania, 17065,
2. The Respondent, Patricia Anderson, is an adult individual who currently resides at
121 Tower Circle, Carlisle, Cumberland County, Pennsylvania 17013.
3. There is one dependent child of the parties, namely Cecilee Anderson, age 11, born
September 3, 1988.
4. The parents of the child are divorced and have the following informal custody
agreement. However, there is no custody court order in the Court of Common
Pleas of Cumberland County :
School Year:
The Mother it to have physical custody of the child
throughout the school year, except for Tuesdays and every
other weekend,
Summer:
The Father is to have physical custody of the child]
throughout the summer, except for every other weekend.
5. The Petitioner has reason to believe that the child is under imminent threat of
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removal from this jurisdiction by the Mother, Specifically, the Respondent and her boyfiiend have
announced their intention to remove the child from this jurisdiction today and move to the state of
Iowa.
6. In accordance with Brown v Cain, 351 Pa. Super. 130, 133, n.4, 505 A.2d 300,
302, n.4 (1986), this court should order the status quo to remain in effect pending the outcome of
any future custody proceeding
WHEREFORE, for all the aforesaid reasons, the Petitioner requests this Petition for
Emergency Relief be granted and that this court ORDER the Respondent not to remove the child
from this jurisdiction pending the outcome of a custody hearing.
11 lfoloo
Paul Bradfo Orr, Esquire
Attorney for Petitioner
The Law offices of Paul Bradford Orr
50 E. High Street
Carlisle, P A 17013
Supreme Court I.D. #71786
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VERIFICA nON
I, Larry Anderson, hereby verifY that the statements made in the foregoing petition are
true and correct to the best of my knowledge, information, and belief. 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: August 16, 2000
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LARRY ANDERSON
PLAINTIFF
V.
PATRICIA ANDERSON
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
00-5674 CIVlLACTIONLAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 18th day of August ,2000, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear beforeMelissa P. Greevy, Esq. , the conciliator,
at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the 22ud day of August ,2000, at 3:00 p.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
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilites Act of ]990. 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
\ Carlis]e, Pennsylvania 17013
Te]ephone (717) 249-3166
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LARRY ANDERSON,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
PATRICIA ANDERSON,
Defendant
: NO, 00-5674
CIVIL TERM
: CUSTODY
ORDER OF COURT
AND NOW,
, 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
. 2000, at
o'clock,
_.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 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:
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 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,
Central Pennsylvania Legal Services
2 J3A North Front Street
Harrisburg, P A 1710 I
(800) 932-0356
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LARRY ANDERSON,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 00-!iZ.7YCIVIL TERM
PATRICIA ANDERSON,
Defendant
: CUSTODY
COMPLAINT FOR CUSTODY
I. The Plaintiff is Larry Anderson, residing at IS East Street ,M!. Holly Springs, Cumberland
County, Pennsylvania 17013..
2. The Defendant is Patricia Anderson, had been residing at 121 Tower Circle, Carlisle, Cumberland
County, Pennsylvania 17013.
3. Plaintiff seeks custody of the following child:
NAME
RESIDENCE
DOB
AGE
Cecilee Anderson
IS East Street
Mount Holly Springs
PA 17013
9/3/88
II
4. The child was not born out of wedlock.
5. The child is presently in the custody of Larry Anderson.
6. During his life, the child has resided with the following persons and at the following addresses:
NAME
Larry Anderson
ADDRESS
IS East Street
Mount Holly Springs, PA 17065
DATES
Since Birth
Patricia Anderson
121 Tower Circle
Carlisle, PA 17013
Since Birth
7. The mother of the child is Patricia Anderson, currently residing at 121 Tower Circle, Carlisle
Pennsylvania 17013. She is divorced.
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8. The father of the child is Larry Anderson, currently residing at 15 East Street, Mount Holly
Springs, Pennsylvania 17065. He is married.
9. The relationship of the Plaintiff to the child is that of Father. The Plaintiff currently resides with
the following persons: Larry Anderson
10. The relationship of the Defendant to the children is that of Mother. The Defendant currently
resides with the following persons: Nt A
II. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation
concerning the custody ofthe child in this or another court.
12, Plaintiff has no information of a custody proceeding concerning the children 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.
14. The best interest and permanent welfare of the children will be served by granting the relief
requested for the following reasons:
A. Plaintiff has undertaken and performed the primary parental responsibilities for the child;
and
B. Plaintiff is best able to provide the care and nurture which the child needs for healthy
development; and
Co A Court Order of custody and structured visitation is desired so that the Plaintiff and the
child may plan their schedules accordingly, and so that misunderstandings and unmet exceptions
regarding custody and visitation can be avoided, and als.o so that the child is not used in a
manipulative fashion
D. Plaintiff desires to maintain the family household which has been established, and the
continued stability of the household is in the best interest of the child.
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E. A Court Ordered determination of custody is required to avoid continuing conflict
between the parties regarding parental responsibility for custody and support.
15. Each parent whose parental rights to the child have not been terminated and the person who has
physical custody of the child has been named as parties to this action.
WHEREFORE, Plaintiff requests the Court to grant custody of the children to Plaintiff subject to
structured partial custody by the Defendant pending the hearing.
Date:
~II~
Paul Bradford Orr, squire
Attorney for Plaintiff
50 East High Street
Carlisle, P A 170 I3
Telephone: (717) 258-8558
Supreme Court ill No. 71786
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VERIFICA nON
I, Larry Anderson, hereby verifY that the statements made in the foregoing petition are
true and correct to the best of my knowledge, information, and belief. 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: August 16,2000
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LARRY ANDERSON, :
Plaintiff/Petitioner:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
PATRICIA ANDERSON, :
Defendant/Respondent: 00-5674 CIVIL TERM
ORDER OF COURT
AND NOW, this 18th day of August, 2000, upon
consideration of Plaintiff's petition for emergency relief with
respect to the parties' child, Cecilee Anderson (date of birth
September 3, 1988), and it appearing that the mother of the child
desires to relocate to the state of Iowa, and the father of the
child opposes the relocation, and it appearing further that there
is an existing custody order in effect from Cameron County, which
provides for primary physical custody of the child in the mother
and temporary or partial physical custody of the child in the
father, and counsel for the parties having agreed that this Court
should exercise jurisdiction with respect to the issue of the
proposed relocation, this matter is referred to the custody
conciliation process, and the parties are directed to appear at a
custody conciliation conference with Melissa Greevy, Esquire,
Cumberland County, Custody Conciliator, at 214 Senate Avenue, Camp
Hill, Cumberland County, Pennsylvania on Tuesday, August 22, 2000,
at 3:00 p.m.
Pending the custody conciliation conference, the
existing order of Court shall remain in effect and neither partle,
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shall remove the child from Pennsylvania.
By the Court,
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Gregory L. Cutler, Esquire
For the Plaintiff/Petitioner
Thomas Diehl, Esquire
For the Defendant/Respondent
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SEP 01 ZOOOttJ
PATRICIA A. ANDERSON,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-5674
LARRY L. ANDERSON,
Defendant
CIVIL ACTION - LAW
CUSTODY
ORDER OF COURT
AND NOW, this h -{t, day of c -.. , 2000, upon consideration
of the attached Custody Conciliation Summary Re ort and the agreement of the parties, it is
ordered and directed as follows:
1. The parties shall have shared legal custody of the minor Child, Cecilee
Anderson, born September 3,1988. Each parent shall have an equal right, to be exercised
jointly with the other parent, 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.
2. Mother shall have primary physical custody during the school year. Father shall
have partial physical custody during the school year from Friday after school until Sunday at
8:00 PM on alternating weekends. Additionally, he shall have partial physical custody on the
alternate Friday in addition to alternate Friday evenings of Mother's weekend from after school
until 8:00 PM.
Father shall have majority custody in the summer subject to alternating
weekends of partial custody with Mother.
3. Mother shall have two consecutive weeks of vacation time during the first two
weeks of July each year.
4. The parties shall share holidays in the fashion upon which they shall agree.
5. In the event that either party shall desire to relocate outside the greater Carlisle
area, that party shall be required to petition the Court and provide the other party with a 90 day
notice of their intent to relocate with the Child.
6. Each party shall give notice to the other party if they have plans to take the
minor Child out of state. At that time the parties shall exchange telephone numbers and
addresses where they can be located during the period of time that the Child is out of the state
of Pennsylvania.
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Docket No. 00-5674
7. This Order is temporary in nature and subject to modification. The parties may
return to Conciliation upon proper petition by either party.
BY THE COURT,
cc: Thomas Diehl, Esquire
Gregory L. Cutler, Esquire
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SEP 0 1 2000tp
PATRICIA A. ANDERSON,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-5674
LARRY L. ANDERSON,
Defendant
CIVIL ACTION - LAW
CUSTODY
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 . The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF~
Cecilee Anderson
September 3,1988
Father
2. A Custody Conciliation Conference was held on August 22, 2000, with the
following individuals in attendance: The Mother, Patricia A. Anderson, and her counsel,
Thomas Diehl, Esquire; the Father, Larry L. Anderson, and his counsel, Gregory L. Cutler,
Esquire.
3. An Order was agreed upon in the form as attached.
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~lissa Peel Greevy, Esquire
Custody Conciliator
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PATRICIA A. ANDERSON
PLAINTIFF
V.
LARRY L. ANDERSON
DEFENDANT
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
00-5674 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Friday, June 01, 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 Avenne, Suite 105, Camp Hill, PA 17011 on Tuesday, July 10, 2001 at 9:15 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 from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR TIlE COURT,
By: Isl
Melissa P. Greevy. Esq. '\)\'f"\
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 TIllS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTIl BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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PENNSYlVANIA
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PATRICIA A. ANDERSON.
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - CUSTODY
: NO. 00-5674 CIVIL TERM
LARRY 1. ANDERSON,
DefenQantlRespondent
: IN CUSTODY
ORDER OF COURT
AND NOW, this _ day of 2001, upon presentation
and consideration of the attached Petition, it is hereby directed that the parties and their
respective counsel appear before , Esquire, the
conciliator, at,
Cumberland County,
Pennsylvania 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 a temporary Order. Either party may bring the
child(REN) who is subject to this custody action to the conference, but .the child/children's
attendance is not mandatory. Failure to appear at the conference may provide grounds for entry
of a temporary or pennanent Order.
FOR THE COURT:
By:
Custody Conciliator
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, P A 17013
(717) 249-3166
.............
AMERICANS WITH DISABILITIES ACT OF 1990
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 least 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing.
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PATRICIA A. ANDERSON,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - CUSTODY
: NO. 00-5674 CIVIL TERM
LARRY L. ANDERSON,
Defendant/Respondent
: IN CUSTODY
PETITION FOR MODIFICATION OF CUSTODY
1. The Petitioner is the above-named Plaintiff, Patricia A. Anderson, an adult
individual currently residing at 121 Tower Circle, Carlisle, Cumberland County, Pennsylvania
17013.
2. The Respondent is the above-named Defendant, Larry L. Anderson, an adult
individual currently residing at 15 East Street, Mount Holly Springs, Cumberland County,
Pennsylvania 17065.
3. The parties are the natural parents of the child Cecilee Anderson, born September
3 1988. The child was born in wedlock.
,
4. The parties are currently subject to a Custody Order dated September 6, 2000,
which was the result of an agreement reached at a Custody Conciliation Conference held on
August 22, 2000. A copy of the resulting Order is attached hereto and incorporated herein by
reference as Exhibit "A."
5. There have been no additional actions relative to custody of the within named
child in any jurisdiction to the Petitioner's knowledge.
6. Since the entry of the Court's Order of September 6, 2000, the child has primarily
resided with the Petitioner.
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7. The Petitioner desires and is requesting permission of the Court to relocate with
child to establish residence in the state ofIowa.
8. Among the reasons why the Petitioner desires to relocate are that the Petitioner
has employment opportunities in Iowa, which would economically benefit both her and the child.
9. The natural mother of the child is Patricia A. Anderson. She is single.
10, The natural father ofthe child is Larry 1. Anderson. He is married.
II. The relationship of the Petitioner to the child is that of natural mother. The
natural mother currently resides with the child and Adam Church.
12. The relationship of the Respondent to the child is that of natural father. The
natural father currently resides with his wife, stepdaughter and daughter,
13. The Petitioner has not participated as a party or a witness in any other capacity in
litigation concerning the child.
14. Petitioner has no information of any custody proceeding concerning the child
pending in any Court of this Commonwealth.
15. The child's best interest and permanent welfare would be improved by modifying
the existing Custody Order as Petitioner is better suited to foster child's emotional and
educational development, and child would further benefit financially through Petitioner's
relocation to Iowa.
16. Petitioner does not know of any person not a party to these proceedings who
claims to have custody or visitation rights with respect to the child.
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WHEREFORE, Petitioner requests your Honorable Court to grant her request to enter an
Order scheduling a Custody Conciliation regarding the custody modification.
Respectfully submitted,
Dated: ~-~'i ~ul
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omas S. Diehl, Esquire
Attorney for Plaintiff/Petitioner
One West High Street
Carlisle, Pennsylvania 17013
(717) 240-0833
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VERIFICATION
I verify that the statements made in this Petition 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.
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PATRICIA A. ANDERSON
Plaintiff/Petitioner
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EXHIBIT A
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PATRICIAA. ANDERSON,
Plaintiff
vs.
.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-5674
LARRY L. ANDERSON,
Defendant
CIVIL ACTION - LAW
CUSTODY
ORDER OF COURT
AND NOW, this Iol;i day of si~f'mLJ ,2000, upon consideration
of the attached Custody Conciliation Summary port and the agreement of the parties, it is
ordered and directed as follows:
1. The parties shall have shared legal custody of the minor Child, Cecilee
Anderson, born September 3, 1988. Each parent shall have an equal right, to be exercised
jointly with the other parent, 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.
2. Mother shall have primary physical custody during the school year. Father shall
have partial physical custody during the school year from Friday after school until Sunday at
8:00 PM on alternating weekends. Additionally, he shall have partial physical custody on the
alternate Friday in addition to alternate Friday evenings of Mother's weekend from after school
until 8:00 PM.
Father shall have majority custody in the summer subject to alternating
weekends of partial custody with Mother.
3. Mother shall have two consecutive weeks of vacation time during the first two
weeks of July each year.
4. The parties shall share holidays in the fashion upon which they shall agree.
5. In the event that either party shall desire to relocate outside the greater Carlisle
area, that party shall be required to petition the Court and provide the other party with a 90 day
notice of their intent to relocate with the Child.
6. Each party shall give notice to the other party if they have plans to take the
minor Child out of state. At that time the parties shall exchange telephone numbers and
addresses where they can be located during the period of time that the Child is out of the state
of Pennsylvania.
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Docket No. 00-5674
7. This Order is temporary in nature and subject to modification. The parties may
return to Conciliation upon proper petition by either party.
BY THE COURT,
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J.
cc: Thomas Diehl, Esquire
Gregory L. Cutler, Esquire
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PATRICIA A. ANDERSON,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS 'OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-5674
LARRY L. ANDERSON,
Defendant
CIVIL ACTION - LAW
CUSTODY
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. The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Cecilee Anderson
September 3, 1988
Father
2. A Custody Conciliation Conference was held on August 22, 2000, with the
following individuals in attendance: The Mother, Patricia A. Anderson, and her counsel,
Thomas Diehl, Esquire; the Father, Larry L. Anderson, and his counsel, Gregory L. Cutler,
Esquire.
3. An Order was agreed upon in the form as attached.
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~elissa Peel Greevy, Esquire
Custody Conciliator
J
Date
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PATRICIA A. ANDERSON,
Plaintiff
AUG 2 g~
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
,
vs.
NO. 00-5674
LARRY L. ANDERSON,
Defendant
CIVIL ACTION - LAW
CUSTODY
ORDER OF COURT
Oler, J. -
AND NOW, this ~ \cd day of ''i l\~ So 1 ' 2001, upon
consideration of the attached Custody Conciliation Su ary Report, it is hereby ordered and
directed as follows:
1. The previous Order of this Court dated September 6, 2000, shall remain in full force
and effect.
2. The parties shall arrange for the Daughter to participate in an assessment with
Deborah Salem, MHS, CAC related to the narrow issue concerning the Child's feelings related
to a potential move away from her home community with Mother to Iowa. The cost of the
evaluation shall be born by Mother in its entirety. Upon the completion of the assessment by
Ms. Salem, if the parties are not able to resolve this matter, counsel for either party may
request an additional Conference within sixty days of the receipt of Ms. Salem's report.
BY THE COURT,
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Dis!:
Thomas S. Diehl, Esquire. One W. High Street, Carlisle, PA 17013 6..IQill ~
Gregory L. Cutler, Esquire, 50 E. High Street, Carlisle, PA 17013 - -,-- -
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PATRICIA A. ANDERSON,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-5674
LARRY L. ANDERSON,
Defendant
CIVIL ACTION - LAW
CUSTODY
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. The pertinent information concerning the Child who is the subject of this litigation is
as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Cecilee Anderson
September 3, 1988
Mother
2. The parties were seen for their second Custody Conciliation Conference on July 23,
2001, because Mother is contemplating a move to Iowa. The Conference was attended by
counsel for the Mother, Thomas S. Diehl, Esquire; the Father, Larry L. Anderson, and his
counsel, Greg Cutler, Esquire. Mother did not attend.
3. The parties reached an agreement in the form of an Order as attached.
f/J.1/D/
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Melissa Peel Greevy, Esquire
Custody Conciliator
Date