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MICHAEL GEISEL,
PETITIONER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
DEMETRIA GEISEL,
RESPONDENT
00-5697 CIVIL TERM
ORDER OF COURT
AND NOW, this ~
day of August, 2000, this matter having been
called this date and counsel for petitioner indicating that he does not believe the petition
has been served on respondent, the matter IS CONTINUED GENERALLY to be reset
at the request of either party.
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P. Richard Wagner, Esquire
For Petitioner
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MICHAEL GEISEL
PLAINTIFF
V.
DEMETRIA GEISEL
DEFENDANT
IN TIIE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V ANlA
00-5697 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 23rd day of August ,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, Snite 105, Camp Hill, PA 17011 on the 26th day of September ,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 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 groU1lds for entry of a temporary or permanent order.
FOR TIlE COURT,
By: Isl
Melissa P. Greevy. ES~\
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
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
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Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO,C)t, ~.::;-", 7' 7
MICHAEL GEISEL,
:
v.
CIVIL ACTION - LAW
DEMETRIA GEISEL,
IN CUSTODY/VISITATION
Defendant.
ORDER OF COURT
day of , 1990,
attached Complaint, it is hereby
and their respective counsel appear
, the Conciliator, at
, on
the day of , 19____, 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 shall also be present at
the conference. Failure to appear at the conference may provide
grounds for entry of a temporary or permanent Order.
AND NOW, this
upon consideration of the
directed that the parties
before
,
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.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, 4TH FLOOR
~LISLE, PA 17013
(717) 240-6200
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MICHAEL GEISEL,
Petitioner
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY COURTHOUSE
NO. 6)0 - S(..9,
DEMETRIA GEISEL,
Respondent
COMPLAINT IN CUSTODY
AND NOW comes Petitioner, Michael Geisel, by and through his attorneys, Mancke Wagner
Hershey & Tully, who files the following Complaint in Custody as follows:
1. Petitioner, Michael Geisel, is an adult individual residing at 601 Erford Road, Camp
Hill, Cumberland County, Pennsylvania.
2. Respondent, Demetria Geisel, is an adult individual having as a last known
temporary residence at the Travel lodge in New Cumberland, Cumberland County,
Pennsylvania.
3. The parties were married October 28, 1999 in New Cumberland, Cumberland
County, Pennsylvania.
4. The parties are the natural parents of Jacob Michael Geisel born May 6, 1999; child
was bom out of wedlock.
5. The Petitioner herein is the natural father of Jacob Michael Geisel; the Respondent
is the natural mother of the child.
6. Petitioner knows of no other party who has an interest in the custody or temporary
custody of the child.
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7. The parties resided together along with Jacob Michael at 601 Erford Road, Camp
Hill, Pennsylvania along with two other children: Airii-Aunn Coad, age six, and
Magnum Avery Morrison, age four, each of the children being the nephews of the
Respondent herein.
8. On or about August 10, 2000, the Respondent herein left the marital home and did
not tell Petitioner where she was going.
9. On the early morning hours of August 11, 2000, Petitioner learned that the
Respondent was in the Polyclinic Hospital having threatened to commit suicide.
10. On or about August 11, 2000, Petitioner went to the Polyclinic Hospital and found
the Respondent in the Emergency Room having in fact attempted to commit suicide
by taking an overdose of drugs.
11. The Respondent was released from the Psychiatric Ward of the Polyclinic Hospital
on August 15, 2000 and lives at an address unknown to the Petitioner but Petitioner
believes that she may be at the Travel Lodge in New Cumberland, Pennsylvania.
12. The Respondent has threatened to remove her child from the care and custody of
the Petitioner.
13. The aforementioned children, Airii Aunn, is in the temporary custody of the
Respondent's stepfather in Reading, Pennsylvania and the child, Magnum, is also
in Reading, Pennsylvania with Magnum's natural father.
14. Petitioner believes, and therefore avers, that the Respondent is on medication as
a result of the incident of the weekend of August 10, 2000.
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15. Petitioner believes, and therefore avers, that there is an emergency need to vest
temporary physical custody in the Petitioner herein pending an outcome of a
hearing for the following reasons:
a. There is no order in place at the present time which would permit the
Respondent to remove the child from this jurisdiction and go to places
unknown to the Petitioner;
b. The Respondent is unstable, emotionally distraught having attempted to
commit suicide by overdosing on or about August 10/11, 2000;
c. The Respondent herein was recently discharged from the Mental
Heath/Psychiatric Department of the Polyclinic Hospital having attempted to
commit suicide;
d. The Respondent has no residence in the Cumberland County area, has had
custody of at least two other children, i.e. her nephews, both of which now
are residing in Reading, Pennsylvania, because of her inability to care for
these children;
e. Respondent is not capable at the present time of caring for a minor child;
f. The Respondent has no gainful employment and otherwise has no contacts
or family in the Cumberland or Dauphin County area.
16. Petitioner believes, and therefore avers, it would be in the best interest of Jacob
Michael to grant the emergency petition granting him temporary custody of Jacob
Michael pending the outcome of any custody hearing. Petitioner also believes it is
in the best interest to direct that the Respondent not be permitted to remove or
attempt to remove the child of the jurisdiction of Cumberland County.
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17. Petitioner believes, and therefore avers, it would be in the best interest of Jacob
Michael to grant Petitioner primary custody of said child.
WHEREFORE, Petitioner prays This Honorable Court to grant the relief requested.
Respectfully submitted,
Mancke Wagner Hershey & Tully
Date: 08/18/00
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VERIFICATION
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. S4904,
relating to unsworn falsification to authorities.
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Date:
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MICHAEL GEISEL,
IN THE COURT OF COMMON PLEAS
CtlMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
v.
NO. 60- 5(, '77
CIVIL ACTION - LAW
DEMETRIA GEISEL,
IN CUSTODY/VISITATION
Defendant.
ORDER OF COURT
day of , 1990,
attached Complaint, it is hereby
and their respective counsel appear
, the Conciliator, at
, on
the day of , 19_, 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 shall also be present at
the conference. Failure to appear at the conference may provide
grounds for entry of a temporary or permanent Order.
AND NOW, this
upon consideration of the
directed that the parties
before
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.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, 4TH FLOOR
CARLISLE, PA 17013
(717) 240-6200
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MICHAEL GEISEL,
Petitioner
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY COURTHOUSE
NO. &0 - 5(,9!
DEMETRIA GEISEL,
Respondent
COMPLAINT IN CUSTODY
AND NOW comes Petitioner, Michael Geisel, by and through his attorneys, Mancke Wagner
Hershey & Tully, who files the following Complaint in Custody as follows:
1. Petitioner, Michael Geisel, is an adult individual residing at 601 Erford Road, Camp
Hill, Cumberland County, Pennsylvania.
2. Respondent, Demetria Geisel, is an adult individual having as a last known
temporary residence at the Travel lodge in New Cumberland, Cumberland County,
Pennsylvania.
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3. The parties wer~ married October 28, 1999 in New Cumberland, Cumberland
County, Pennsylvania.
4. The parties are the natural parents of Jacob Michael Geisel born May 6, 1999; child
was born out of wedlock.
5. The Petitioner herein is the natural father of Jacob Michael Geisel; the Respondent
is the natural mother of the child.
6. Petitioner knows of no other party who has an interest in the custody or temporary
custody of the child.
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7. The parties resided together along with Jacob Michael at 601 Erford Road, Camp
Hill, Pennsylvania along with two other children: Airii-Aunn Coad, age six, and
Magnum Avery Morrison, age four, each of the children being the nephews of the
Respondent herein.
8. On or about August 10, 2000, the Respondent herein left the marital home and did
not tell Petitioner where she was going.
9. On the early morning hours of August 11, 2000, Petitioner learned that the
Respondent was in the Polyclinic Hospital having threatened to commit suicide.
10. On or about August 11, 2000, Petitioner went to the POlyclinic Hospital and found
the Respondent in the Emergency Room having in fact attempted to commit suicide
by taking an overdose of drugs.
11. The Respondent was released from the Psychiatric Ward of the Polyclinic Hospital
on August 15, 2000 and lives at an address unknown to the Petitioner but Petitioner
believes that she may be at the Travel Lodge in New Cumberland, Pennsylvania.
12. The Respondent has threatened to remove her child from the care and custody of
the Petitioner.
13. The aforementioned children, Airii Aunn, is in the temporary custody of the
Respondent's stepfather in Reading, Pennsylvania and the child, Magnum, is also
in Reading, Pennsylvania with Magnum's natural father.
14. Petitioner believes, and therefore avers, that the Respondent is on medication as
a result of the incident of the weekend of August 10, 2000.
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15. Petitioner believes, and therefore avers, that there is an emergency need to vest
temporary physical custody in the Petitioner herein pending an outcome of a
hearing for the following reasons:
a. There is no order in place at the present time which would permit the
Respondent to remove the child from this jurisdiction and go to places
unknown to the Petitioner;
b. The Respondent is unstable, emotionally distraught having attempted to
commit suicide by overdosing on or about August 10/11, 2000;
c. The Respondent herein was recently discharged from the Mental
Heath/Psychiatric Department of the Polyclinic Hospital having attempted to
commit suicide;
d. The Respondent has no residence in the Cumberland County area, has had
custody of at least two other children, Le. her nephews, both of which now
are residing in Reading, Pennsylvania, because of her inability to care for
these children;
e. Respondent is not capable at the present time of caring for a minor child;
f. The Respondent has no gainful employment and otherwise has no contacts
or family in the Cumberland or Dauphin County area.
16. . Petitioner believes, and therefore avers, it would be in the best interest of Jacob
Michael to grant the emergency petition granting him temporary custody of Jacob
Michael pending the outcome of any custody hearing. Petitioner also believes it is
in the best interest to direct that the Respondent not be permitted to remove or
attempt to remove the child of the jurisdiction of Cumberland County.
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17. Petitioner believes, and therefore avers, it would be in the best interest of Jacob
Michael to grant Petitioner primary custody of said child.
WHEREFORE, Petitioner prays This Honorable Court to grant the relief requested.
Respectfully submitted,
Date: 08/18/00
Mancke Wagner Hershey & Tully
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;Po Richard W~er, Esquire
i 223~NoFlt(Front Street
Harrisburg, PA 17110
717/234-7051
VERIFICATION
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. 94904,
relating to unsworn falsification to authorities.
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Date:
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MICHAEL GEISEL,
Petitioner
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY COURTHOUSE
NO. 00-5&>9'/ -CJAJJ
DEMETRIA GEISEL,
Respondent
ORDER
AND NOW, this 1f:L. day of C1J. e'fJ, ,2000, upon petition of Michael Geisel, natural
father of Jacob Michael Geisel, an emergency hearing is set for the g'/ day of ~,
2000 at '7y,115 o'clock in Courtroom # L of the Cumberland County Courthouse.
Pending outcome of said hearing, temporary custody of Jacob Michael Geisel is vested with
the Petitioner herein.
Respondent is directed not to remove the child from the jurisdiction of Cumberland County.
BY THE''COU
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Prothonotary's Office
p, Richard Wagner, Esquire, 2233 N, Front St., Harrisburg, PA 17110
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MICHAEL GEISEL,
Petitioner
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY COURTHOUSE
v.
NO.
DEMETRIA GEISEL,
Respondent
PETITION FOR EMERGENCY RELIEF
AND NOW comes Petitioner, Michael Geisel, by and through his attorneys, Mancke Wagner
Hershey & Tully, who files the following Petition for Emergency Relief as follows:
1. Petitioner, Michael Geisel, is an adult individual residing at 601 Erford Road, Camp
Hill, Cumberland County, Pennsylvania.
2. Respondent, Demetria Geisel, is an adult individual having as a last known
temporary residence at the Travel lodge in New Cumberland, Cumberland County,
Pennsylvania.
3. The parties were married October 28, 1999 in New Cumberland, Cumberland
County, Pennsylvania.
4. The parties are the natural parents of Jacob Michael Geisel bom May 6, 1999; child
was born out of wedlock.
5. The Petitioner herein is the natural father of Jacob Michael Geisel; the Respondent
is the natural mother of the child.
6. Petitioner knows of no other party who has an interest in the custody or temporary
custody of the child.
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7. The parties resided together along with Jacob Michael at 601 Erford Road, Camp
Hill, Pennsylvania along with two other children: Airii-Aunn Coad, age six, and
Magnum Avery Morrison, age four, each of the children being the nephews of the
Respondent herein.
8. On or about August 10, 2000, the Respondent herein left the marital home and did
not tell Petitioner where she was going.
9. On the early morning hours of August 11, 2000, Petitioner learned that the
Respondent was in the Polyclinic Hospital having threatened to commit suicide.
10. On or about August 11, 2000, Petitioner went to the Polyclinic Hospital and found
the Respondent in the Emergency Room having in fact attempted to commit suicide
by taking an overdose of drugs.
11. The Respondent was released from the Psychiatric Ward of the Polyclinic Hospital
on August 15, 2000 and lives at an address unknown to the Petitioner but Petitioner
believes that she may be at the Travel Lodge in New Cumberland, Pennsylvania.
12. The Respondent has threatened to remove her child from the care and custody of
the Petitioner.
13. The aforementioned children, Airii Aunn, is in the temporary custOdy of the
Respondent's stepfather in Reading, Pennsylvania and the child, Magnum, is also
in Reading, Pennsylvania with Magnum's natural father.
14. Petitioner believes, and therefore avers, that the Respondent is on medication as
a result of the incident of the weekend of August 10, 2000.
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15. Petitioner believes, and therefore avers, that there is an emergency need to vest
temporary physical custody in the Petitioner herein pending an outcome of a
hearing for the following reasons:
a. There is no order in place at the present time which would permit the
Respondent to remove the child from this jurisdiction and go to places
unknown to the Petitioner;
b. The Respondent is unstable, emotionally distraught having attempted to
commit suicide by overdosing on or about August 10/11, 2000;
c. The Respondent herein was recently discharged from the Mental
Heath/Psychiatric Department of the Polyclinic Hospital having attempted to
commit suicide;
d. The Respondent has no residence in the Cumberland County area, has had
custody of at least two other children, i.e. her nephews, both of which now
are residing in Reading, Pennsylvania, because of her inability to care for
these children;
e. Respondent is not capable at the present time of caring for a minor child;
f. The Respondent has no gainful employment and otherwise has no contacts
or family in the Cumberland or Dauphin County area.
16. Petitioner believes, and therefore avers, it would be in the best interest of Jacob
Michael to grant the emergency petition granting him temporary custody of Jacob
Michael pending the outcome of any custody hearing. Petitioner also believes it is
in the best interest to direct that the Respondent not be permitted to remove or
attempt to remove the child of the jurisdiction of Cumberland County.
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WHEREFORE, Petitioner prays This Honorable Court to grant the relief requested.
Respectfully submitted,
Mancke Wagner Hershey & Tully
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Date: 08/17/00
gner, Esquire
Front Street
Harrisburg, PA 17110
717/234-7051
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VERIFICATION
I verify that the statements made in the foregoing
document 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.
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DATE:
0/r7/00
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MICHAEL GEISEL,
Plaintiff
OCT 2 0 200at/J
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00-5697
DEMETRIA GEISEL,
Defendant
CIVIL ACTION - LAW
CUSTODY
INTERIM ORDER OF COURT
AND NOW, this {...'J day of 0 M-. ,2000, the parties having
reached an agreement as to a temporary Order for custody, it is hereby ordered and directed
as follows:
1. The parties agree to participate and submit themselves and their minor Child to a
custody evaluation to be performed by Dr. Sheinvold. This shall be an independent custody
evaluation. The parties shall sign all necessary releases and authorizations for the evaluator to
obtain medical and psychological information pertaining to the parties. The cost of this
evaluation shall be shared equally by the parties. It shall be necessary for the parties to extend
their complete cooperation to Dr. Sheinvold in scheduling the appointments for the evaluation
and participation in that process.
2. Pending further Order of Court or an agreement of the parties, the Father, Michael
Geisel, and the Mother, Demetria Geisel, shall have shared legal custody of their minor son,
Jacob Michael Geisel, born May 6,1999.
3. Father shall have primary physical custody of the minor Child. Mother shall have
supervised visitation on Saturday of each week at either the homo of the paternal grandparents
or through an arrangement made by counsel for supervision in Cumberland County,
Pennsylvania.
4. The Defendant Mother shall not be permitted to remove the minor Child from the
location of the supervised visitation.
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No. 00-5697
5. Following the conclusion of the custody evaluation the parties shall return to Custody
Conciliator to work out the details of a modified custody plan. In the event that the custody
evaluator has recommendations for interim changes to this Order prior to the conclusion of the
evaluation and receipt of the Custody Evaluation Report, the evaluator shall forward that
recommendation to counsel for the parties and to the Custody Conciliator. At that time, a new
Conciliation Conference to address these recommendations shall be promptl convened.
Edgar B. Bayley, J.
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MICHAEL GEISEL,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-5697
DEMETRIA GEISEL,
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
Jacob Michael Geisel
May 6, 1999
Father
2. A Conciliation Conference was held on September 26, 2000, with the following
individuals in attendance: Michael Geisel, Father, and his counsel, P. Richard Wagner,
Esquire; and Demetria Geisel, Mother, and her counsel, Marianne Murphy, Esquire.
3. The parties agreed to the entry of a temporary Order in the form as attached.
fO/;r1"orrJ u~av '- j
Me a Peel Greevy, EsqUire
Custody Conciliator
Date