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HomeMy WebLinkAbout00-06047 1J'~""''''>- ~~- ~~ , ,-- --., _."-''f~ ~ . . . JOHN CHRISTOPHER, III, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO.00-6047 CIVIL TERM REBEKAH S. CHRISTOPHER, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this ~' day of +.......w- ,2001, upon consideration of the attached Custody Conciliation Report it is ordered and directed as follows: A Hearing is scheduled in Court Room No. .cf , of the Cumberland County Court House on the ;% day of f'),.h k'7 ,2001, at q; 3D o'clock, 1. M., at which time testimony will be taken. For purposes of the Hearing, the Mother, Rebekah S. Christopher, shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who are expected to testify at the Hearing" and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten (10) days prior to the Hearing date. BY THE COURT, cc: Samuel L. Andes, Esquire - Counsel for Father Marcus A.. McKnight, III, Esquire - Counsel for Mo /74 J. ~ ~ 9.0'l-O( ~. ~ '" -" -" ~~r" -,"," ~W"'\'f "'4'" .~ .,._Y ,; ('1:'-') -,; i U.~ so elf" Ui\/;;~:,;.:' , C..\"::; j:\'1'V l~cj\lr\,I(,)vL' \!/"'I~'.'--! \ 1 , . \. I ~1"11 \i/-\ ... . , , ~,-,~. ""_,=~ -r ")l!(~~~;m~J<iII!~~..",.,Jj.,~_. ~1.'~ > '..~c .. . JOHN CHRISTOPHER, III, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-6047 CIVIL TERM REBEKAH S. CHRISTOPHER, Defendant CIVIL ACTION - LAW IN CUSTODY PRIOR JUDGE: Kevin A. Hess 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 Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Alexandria R. Christopher Adrienne D. Christopher John Christopher, IV July 26, 1995 November 25, 1996 November 24, 1997 Father Father Father 2. A Conciliation Conference was held on August 21, 2001 in which the Father's counsel, Samuel L. Andes, Esquire and the Mother's counsel, Marcus J. McKnight, III, Esquire participated. 3. The most recent Order entered by this Court in this matter was dated January 31,2001, under which the Father has primary physical custody of the Children and the Mother has partial physical custody on alternating weekends and an overnight period each week. The Mother filed Petitions for Special Relief and Modification of the existing Order based on the fact that she has been denied all partial custody with the Children (not disputed) since the end of April, 2001. It became clear from counsels' statements early in the Conference that it will be necessary to schedule a Hearing in this matter. The Conciliator contacted the Court Administrator's office immediately following the Conference to request an expedited Hearing, both as to interim custody arrangements and resolution of the Mother's Petitions as the Mother has had no contact with the Children since April. 4. The Father's position on custody is as follows: The Father acknowledged, through counsel, that he suspended the Mother's partial custody with the Children as of early May 2001 until such time as the parties had resolved the Father's concerns regarding the safety of the Children. The Father's , .- ~ ~'.- .. . "" concerns arose from the reported murder of a man (with whom the Father alleges the Mother was living at least on a partial basis) in the Mother's vehicle at the end of April 2001 and the subsequent and ongoing drug related investigation. The Father expressed concern that the Mother had been associating with an individual who was engaged in drug trafficking and claimed that the Mother had been taking the Children to the murder victim's apartment thereby exposing the Children to potentially serious risk. Although the Mother now resides in Perry County with her Mother, the Father believes the Mother herself may be in danger due to her association with the murder victim. The Father's counsel stated that the Father will only permit contact between the Mother and the Children in an institutional setting, such as the Y.M.C.A., for the protection of the Children. 5. The Mother's position on custody is as follows: The Mother does not dispute that there is an ongoing investigation concerning the death of an individual who was found in the Mother's car. However, the Mother objects to the Father's conduct in unilaterally terminating her custody rights without following the required legal procedures. The Mother's counsel argued that the Mother is no longer living in Harrisburg but is currently residing with her mother in Perry County. The Mother proposed that she have periods of custody at either her mother's home in Perry County or her grandparent's home in Carlisle. On an interim basis, the Mother would agree to remain at her mother's or grandparent's home with the Children during her periods of custody to satisfy the Father's concerns regarding safety. The Mother denies the Father's allegations with respect to the Children's exposure to harm and requests that the current Order granting her partial custody be enforced. As she has not seen the Children since the end of April, the Mother seeks an expedited Hearing on her Petition. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing. It appears that, from the serious nature of the allegations and the Father's refusal to allow contact between the Mother and the Children outside of an institutional setting without a Court Order, it will be necessary for the Court to resolve both the issues conceming interim arrangements and ongoing custody arrangements by Hearing. As the Father's counsel indicated that he expects to present the testimony of officials involved in the murder investigation at Hearing, it is anticipated that the Hearing will require at least one full day. A~I- d iz ;:}oOI Date ~~ Dawn S. Sunday, EsqUIre Custody Conciliator ,- ,-",- . -~'_L_"_ '"",,'.C' -" -. - ." ,.oi>~' -, _ ,- :-., __ " -~ . -,>,'_, -_0_'''_ .,.,;.y ___ <~, ,~. :';~ -:"":.;,, -."-,,,:.-, .,";-_ ';;d'",,:";,,^h,),j,,;~~.~_ ',/' ", _._ _ ~ ,-- -'" JOHN CHRISTOPHER, III, Plaintiff /Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CML ACTION - LAW 2000-6047 CIVIL TERM REBEKAH S. CHRISTOPHER, Defendant/Petitioner IN CUSTODY ORDER OF COURT AND NOW, this /q1i/ day of j,pkA>?&/L' 2001, upon consideration of the attached Petition for Special Relief, IT IS HEREBY ORDERED that a hearing regarding this Petition for Special Relief is hereby scheduled for ~ :; ,2001, aU~o'clock t9 .m. in Courtroom Number ~ , Cumberland County Courthouse, Carlisle, Pennsylvania 17013 at which time the parties along with their legal counsel shall appear in person. Pending said hearing, the terms of the Order of Court dated January 31, 2001, will be obeyed by the parties. BY THE COURT, /1~ <.0\ '\.~ ~ '. '~'C_ .~ - ~-'- --< '^8. "'_.' - 0 c: ) c " -~ U> "!;.=- -0 CJ~' C'"l [11 f1 '. -0 7-::r -?' <-;;. c_ _ \D ~~) ~-r) d.:::';CJ ?-C' i;? '--~) 5e: --.;, ~ l',} "l":: (:0 ~ I~~~ ~,,,~-~,-_..,.g _A-",'') - -~'~ "' ,,~,.u~ vs. JOHN CHRISTOPHER, III, Plaintiff CIVIL ACTION - LA~ ~ u Cu' r~1 NO.m-C;;().I/?~~:!'" L.._1.- 1 ~},,> COMPLAINT IN CUSTODY ~~C -co )~r_ AND NOW comes the Plaintiff, JOHN CHRISTOPHER, III, by his att!~~, jw~L. =< :t:~ 32 Andes, and makes the following Complaint for Custody: REBEKAH S. CHRISTOPHER, Defendant :, 1. The Plaintiff is JOHN CHRISTOPHER, III, an adult individual who resides at 215 I :i West North Street in Carlisle, Cumberland County, Pennsylvania. II 2. The Defendant is REBEKAH S. CHRISTOPHER, an adult individual whose precise II address is not known with certainty to the Plaintiff but her last known address was 1823 Pearl Street in Alameda, California, 94501. 3. The parties are formerly husband and wife. 4. The Plaintiff and Defendant are the parents of four minor children: Alleshia Y.M. Christopher, born 12 February 1992; Alexandria R. Christopher, born 26 July 1995; Adrienne D. Christopher, born 25 November 1996; and John Christopher, IV, born 24 November 1997. The oldest child, Alleshia Y.M. Christopher is not the subject of this litigation. That child resides in the custody of Plaintiff's mother pursuant to an order of this court entered on 21 June 2000 to an action filed to No. 00-2414 Civil Term. The other three children currently reside with the Plaintiff and they are the subject of this litigation. , JOHN CHRISTOPHER, III, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. REBEKAH S. CHRISTOPHER, Defendant CIVIL ACTION - LAW _ NO. IZJ- /;0'/7 Cu,u/ ORDER AND NOW this I ~ day of .J:c,Afevo4cr , 2000, upon consideration of the attached Complaint in Custody, the Plaintiff, John Christopher, III, is hereby awarded legal and physical custody of the parties three minor children, Alexandria R. Christopher, born July 26, 1995, Adrienne D. Christopher, born 25 November 1996 and John Christopher, IV, born November 24, 1997, pending further order of this court. Further proceedings are hereby referred to the conciliator. BY THE cou; 1 J. Distribution: ~ Samuel L. Andes, Esquire (Attorney for Plaintiff) [\ ~ 525 North 12th Street, Lemoyne, Pa 17043 ~ ',; :-'~~ Rebekah S. Christopher (Plaintiff) << _,' 1823 Pearl Street, Alameda, CA 94501 ~" '~'" , \", " " II .. JOHN CHRISTOPHER, III, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA III I, II I REBEKAH S. CHRISTOPHER, ! Defendant vs. CIVIL ACTION - LAW NO. ORDER OF COURT 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 , Esquire, the conciliator at , Pennsylvania, on the day of , 2000, at 0' 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 hard by the court, and to enter into a temporary order. Either party may bring the child who is the subject of this custody action to the conference, but the chid's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. BY THE COURT, 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, PA 17013 (717) 249-3166 II .. JOHN CHRISTOPHER, III, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW REBEKAH S. CHRISTOPHER, Defendant NO. COMPLAINT IN CUSTODY AND NOW comes the Plaintiff, JOHN CHRISTOPHER, III, by his attorney, Samuel L. Andes, and makes the following Complaint for Custody: 1. The Plaintiff is JOHN CHRISTOPHER, III, an adult individual who resides at 215 West North Street in Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is REBEKAH S. CHRISTOPHER, an adult individual whose precise address is not known with certainty to the Plaintiff but her last known address was 1823 Pearl Street in Alameda, California, 94501. 3. The parties are formerly husband and wife. 4. The Plaintiff and Defendant are the parents of four minor children: Alleshia Y.M. Christopher, born 12 February 1992; Alexandria R. Christopher, born 26 July 1995; Adrienne D. Christopher, born 25 November 1996; and John Christopher, IV, born 24 November 1997. The oldest child, Alleshia Y.M. Christopher is not the subject of this litigation. That child I resides in the custody of Plaintiff's mother pursuant to an order of this court entered on 21 June 2000 to an action filed to No. 00-2414 Civil Term. The other three children currently reside with the Plaintiff and they are the subject of this litigation. II \;"-._~;" ~il:.' ~ 5. Plaintiff seeks custody of the said minor children, Alexandria R. Christopher, Adrienne D. Christopher and John Christopher, IV. 6. The children were not born out of wedlock and are presently in the custody of the Plaintiff . 7. During the past five years, the three children who are the subject of this action have resided with the following persons at the following addresses: 1/1995 to 3/1997 Carlisle, PA Plaintiff & Defendant 3/1997 to 10/1997 Greensboro, NC Plaintiff & Defendant 10/1997 to 3/1999 Carlisle, PA Plaintiff & Defendant 3/1999 to 5/2000 Carlisle, PA primarily with Plaintiff but also with Defendant for periods of temporary custody 5/2000 to present Carlisle, PA Plaintiff only 8. The father of the children is the Plaintiff who resides at the address set out above. 9. The mother of the children is the Defendant who resides at the address set out above. 10. The Plaintiff is the natural father of the children. Plaintiff currently resides with his present Wife, Jennifer J. Christopher, age 27, the three children who are the subject of this litigation, his wife's daughter by another marriage, Joyonna Pope, age 2 and, on a part time basis, with his wife's son, Nikolas Zulli, age 6. 11. The Defendant is the natural mother of the children. Defendant's precise living arrangements are not known but Plaintiff believes that Defendant is currently residing with a man who has a criminal record for violent criminal conduct and whose presence in Ii .. Defendant's home represents a risk of harm to the parties' minor children if the children are with the Defendant. 12. The Plaintiff has not participated as a party or in any other way in any litigation concerning the custody of the children in this or any other court. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of this or any other jurisdiction. Plaintiff knows of no other person not a party to this action already who has physical custody of or claims to have custody or visitation rights to the said children. 13. The best interests and permanent welfare of the children will be served by granting the relief requested by Plaintiff for the following reasons: A. Plaintiff is the parent better able to provide for the needs of the children and to provide them stability and security; and B. Defendant dropped the children off at Plaintiff's home and left them in his custody without adequate notice in May of 2000; and C. Except for one occasion when she returned to Carlisle and attempted 'I I, to abduct the children from Plaintiff, Defendant has had no contact with the children since May of 2000 and has not disclosed her address or whereabouts to Plaintiff or to the children since May of 2000; and D. Plaintiff has made clear her intentions to take the children from Plaintiff and conceal them from him, thereby disrupting their lives and endangering their well being. E. Plaintiff believes that, if this court does not enter an emergency order granting him legal and physical custody of the children, Defendant may abduct them and conceal them from him and from this court. Ii " ,-- ,-:,-0;' '~ . . 14. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff prays this court to take the following actions: A. Award Plaintiff temporary, legal and physical custody of the children on an emergency basis pending further order of this court; and B. Refer this matter to the conciliator for further proceedings as necessary. ~. ~r;p Samu L. Andes Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 II " ",'o_~ --" <'_0- COMMONWEALTH OF PENNSYLVANIA ) ( 55.: COUNTY OF CUMBERLAND ) JOHN CHRISTOPHER, III, being duly sworn according to law, deposes and says that the facts set forth in the foregoing Complaint for Custody are true and correct to the best of his knowledge, information, and belief. ~Jlr,.2 ~J"~,,,g;? J HN CH~TOPHE ,III ,I I Sworn to and sub~ribed before me thisJ'?'llclay ,I Of~ ,2000. 11m ~ Y17, Y{/QA 1 j .i.-- ,I Notar Public. ii ~ ~~I Ii - ~ ~ ~" ,~ '. '~ffiIt'lL~ r It JOHN CHRISTOPER, III PLAINTIFF V. REBEKAH S. CHRISTOPHER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 00-6047 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 9th day of November, 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on the 28thdayof November ,2000, at ~OO 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 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 Dawn S. Sunda 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 lHIS PAPER TO YOUR ATIORNEY 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 ~._ ,_, ,~_""_,^""""',,,"_""h.,m, ",~,^'V".,,, ._ ~, (~)F O ,- U I 'J, [) hl.h ...; I: 39 CU' ,,' " -" '-'{~' ''''TV '!iir~t;'iLf-J\~U I,,;UU!\j i J PENNSYLVANIA If. J3.,(JiJ W-~ ~-d;): s: '71~ ~;tr4~ (l~ ~ ~ aIj"~ J/'/J '&C:~ 11/3 tJtJ - ~~" '"- , Jf!i" ~~~ 'T!I,II'i!l,(!,"~H~~~~*m'1"'~~-l.0U~i)'!. "." ~, ~ , G.-~, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOHN CHRISTOPHER, III, Plaintiff : . . v. No. 2000 - 6047 Civil Ter.m REBEKAH S. CHRISTOPHER, Defendant . . . . IN CUSTODY ORDER OF COURT AND NOW, 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 ___.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. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent Order. BY THE COURT: 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, PA 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 the office set forth above. 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. ~ " - I" ---lw; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOHN CHRISTOPHER, III, Plaintiff . . v. REBEKAH S. CHRISTOPHER, Defendant No. 2000 - 6047 civil Term . . . . IN CUSTODY PETITION FOR CUSTODY CONCILIATION CONFERENCE NOW COMES, REBEKAH S. CHRISTOPHER, Defendant, by and through her attorney, Maryann Murphy, Esquire, of Legal Services, Inc., and avers as follows: 1. Defendant is REBEKAH S. CHRISTOPHER who resides at 744 West Penn Street, Carlisle, Cumberland County, Pennsylvania. 2. Plaintiff is JOHN CHRISTOPHER, III who resides at 215 West North Street, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant are the parents of four (4) minor children, three (3) of whom are involved in this action. The children are ALEXANDRIA R. CHRISTOPHER, born July 26, 1995; ADRIENNE D. CHRISTOPHER, born November 25, 1996; and JOHN CHRISTOPHER, IV, born November 24, 1997. 4. Plaintiff filed a Complaint for Custody docketed to the above number. An Order was entered pursuant to this Complaint on - - - -~ ".. ~ , . 'r.,tflliifuc;; September 1, 2000 granting legal and physical custody of the minor children to Plaintiff, pending further Order of Court. (a copy of this Complaint and the Order are attached hereto, incorporated by reference herein and marked as Exhibit "A"). 5. Plaintiff has not permitted Defendant to have contact with her children since June 1, 2000, despite her repeated attempts to see them. 6. Defendant seeks shared legal and partial physical custody of her minor children, and requests an expedited Custody Conciliation to address the custody matter. WHEREFORE, Defendant, through her counsel, requests a Custody conciliation Conference be scheduled. Respectfully submitted: By: ~~)~ Legal Services, Inc. a Irvine Row Carlisle, PA 17013 (717) 243-9400 Attorney I.D. #61900 Attorney for Defendant cdl' VERIFICATION I, the undersigned, do hereby verify that the statements made in the foregoing instrument are true and correct to the best of my knowledge, information and belief. I understand that statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn ritiry , flf-. ~...ml~ ~~ - ,~ -~ . ''''''""'"Iii\)!,_, " 'I I I ( ( I I II JOHN CHRISTOPHER, Ill, iI Plaintiff " " II I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. REBEKAH S. CHRISTOPHER, Defendant CIVIL ACTION - LAW NO. tlJ-ldJil7 ~;j 1st doy of :~"J".J of the attached Complaint in Custody, the Plaintiff, John Christopher, Ill, is hereby awarded AND NOW this , 2000, upon consideration legal and physical custody of the parties three minor children, Alexandria R. Christopher, born July 26, 1995, Adrienne D. Christopher, born 25 November 1996 and John Christopher, IV, born November 24, 1997, pending further order of this court. Further prQceedings are hereby referred to the conciliator. -, BY THE COURT, /5{ ~,,~;,d ~tI. MJ J. Distribution: Samuel L. Andes, Esquire (Attorney for Plaintiff) 525 North 12th Street, Lemoyne, Pa 17043 Rebekah S. Christopher (Plaintiff) 1823 Pearl Street, Alameda, CA 94501 l, 111\" f'lh';1)~" n . ~"'C' ~ , c< "", il~,-' ( II JOHN CHRISTOPHER, III, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW REBEKAH S. CHRISTOPHER, Defendant NO. COMPLAINT IN CUSTODY AND NOW comes the Plaintiff, JOHN CHRISTOPHER, III, by his attorney, Samuell. Andes, and makes the following Complaint for Custody: 1. The Plaintiff is JOHN CHRISTOPHER, III, an adult individual who resides at 215 West North Street in Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is REBEKAH S. CHRISTOPHER, an adult individual whose precise address is not known with certainty to the Plaintiff but her last known address was 1823 Pearl Street in Alameda, California, 94501. 3. The parties are formerly husband and wife. 4. The Plaintiff and Defendant are the parents of four minor children: Alleshia Y.M. Christopher, born 12 February 1992; Alexandria R. Christopher, born 26 July 1995; Adrienne D. Christopher, born 25 November 1996; and John Christopher, IV, born 24 November 1997. The oldest child, Alleshia Y.M. Christopher is not the subject of this litigation. That child resides in the custody of Plaintiff's mother pursuant to an order of this court entered on 21 June 2000 to an action filed to No. 00-2414 Civil Term. The other three children currently reside with the Plaintiff and they are the subject of this litigation. , I' ..~ '"' ", ,.'.,-.... " II I I i I I I i , ..' .'..," >.-.--- ~ r \ 5. Plaintiff seeks custody of the said minor children, Alexandria R. Christopher, Adrienne D. Christopher and John Christopher, IV. 6. The children were not born out of wedlock and are presently in the custody of the Plaintiff . 7. During the past five years, the three children who are the subject of this action have resided with the following persons at the following addresses: 1/1995 to 3/1997 Carlisle, PA Plaintiff & Defendant 3/1997 to 10/1997 Greensboro, NC Plaintiff & Defendant 10/1997 to 3/1999 Carlisle, PA Plaintiff & Defendant 3/1999 to 5/2000 Carlisle, PA primarily with Plaintiff but also with Defendant for periods of temporary custody 5/2000 to present Carlisle, PA Plaintiff only 8. The father of the children is the Plaintiff who resides at the address set out above. 9. The mother of the children is the Defendant who resides at the address set out above. 10. The Plaintiff is the natural father of the children. Plaintiff currently resides with his present Wife, Jennifer J. Christopher, age 27, the three children who are the subject of this litigation, his wife's daughter by another marriage, Joyonna Pope, age 2 and, on a part time basis, with his wife's son, Nikolas Zulli, age 6. 11. The Defendant is the natural mother of the children. Defendant's precise living arrangements are not known but Plaintiff believes that Defendant is currently residing with a man who has a criminal record for violent criminal conduct and whose presence in l 'J _ .;,=,," ~. ,.-.1 "'.'. ....,;""--..oci r I I I I I , I I Defendant's home represents a risk of harm to the parties' minor children if the children are I , \ I I ( c with the Defendant. 12. The Plaintiff has not participated as a party or in any other way in any litigation __"_.J concerning the custody of the children in this or any other court. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of this or any other jurisdiction. Plaintiff knows of no other person not a party to this action already who has physical custody of or claims to have custody or visitation rights to the said children. 13. The best interests and permanent welfare of the children will be served by granting the relief requested by Plaintiff for the following reasons: A. Plaintiff is the parent better able to provide for the needs of the children and to provide them stability and security; and B. Defendant dropped the children off at Plaintiff's home and left them in his custody without adequate notice in May of 2000; and C. Except for one occasion when she returned to Carlisle and attempted to abduct the children from Plaintiff, Defendant has had no contact with the children since May of 2000 and has not disclosed her address or whereabouts to Plaintiff or to the children since May of 2000; and D. Plaintiff has made clear her intentions to take the children from Plaintiff and conceal them from him, thereby disrupting their lives and endangering their well being. E. Plaintiff believes that, if this court does not enter an emergency order granting him legal and physical custody of the children, Defendant may abduct them and conceal them from him and from this court. , .~ ~~ ~~~' j, i I I I I I' ; i ! ( , i I I I !' the person who has physical custody of the children have been named as parties to this i I action. i 14. Each parent whose parental rights to the children have not been terminated and WHEREFORE, Plaintiff prays this court to take the following actions: A. Award Plaintiff temporary, legal and physical custody of the children on an emergency basis pending further order of this court; and I 'I B. Refer this matter to the conciliator for further proceedings as necessary. a-~ Samue L. Andes Attorney for Plaintiff Supreme Court ID # 17225 525 North 1 Z'h Street Lemoyne, Pa 17043 (717) 761-5361 " '-[~~'1_f" , I ( i !I I II Ii COMMONWEALTH OF PENNSYLVANIA " ;J : COUNTY OF CUMBERLAND ) ( SS.: ) i I i :\ JOHN CHRISTOPHER, III, being duly Sworn according to law, deposes and says that ;1 the facts set forth in the foregoing Complaint for Custody are true and correct to the best of " :1 . db'. i! his knowledge, information, an -eoief. !I ., !I ii /'1, 11 j\ ii i i Sworn to and subscribed j befpre me thisJ~i'llday "O~ --'I' of (11 U1U/)l'" , 2000. 11/1 ,-.' II (Jl/... \fh \, ,'1)/1' l, il Notar Public. [/ II !i .j il I ,I II II : , i , ,(""~~--;~:";iV".~<",~,., ',.~. '." I -,[~;;Yjl'4lIlc I ~~<l!ll!3",!ItIOOt'o/lIlIl\V Po, _MJ~'"-':':~'~'!"!'I!!*",,:,~~:.~~j i ! , , I I 1 ,I I. II 'I Ii I j i I I I I , ^:o.,","" ~'~_'0; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOHN CHRISTOPHER, III, Plaintiff : v. REBEKAH S. CHRISTOPHER, Defendant No. 2000 - 6047 Civil Term IN CUSTODY CERTIFICATE OF SERVICE I, Maryann Murphy, Esquire, do hereby certify that on the day of , 2000 I served a true and correct copy of the foregoing petition on counsel for the Plaintiff, Samuel L. Andes, Esquire, at the address set forth below, by placing a copy of same in the United States Mail, first class, postage prepaid. Samuel L. Andes, Esquire 525 North Twelfth Street Lemoyne, PA 17043 Respectfully submitted, Maryann Murphy, Legal Services, 8 Irvine Row Carlisle, PA 17013 (717) 540-8600 LD. # 61900 ~ ,ar ~i;lft"",*iliiWBiHil!fi~,@<l!b1*,ciirlili!<<m!!'.1iJ:.;f~#;'!lkt!m~""~."""",,,&,t,,LiQ.*,'"~ ]riluiMl~-"""'''~-'~ ,- n - - .w.l~~~,,-' ." , --""."." " ~~ -<"-lIii!Ii!!IiIII1Jl o c: <'" -ot:6 fTl fll Z:T.J 65:; -<L I;~; <;; ~::. --4 -< -~ c::> o :;e c::J c<o I c:r> .-0 :X r;-? ~ 'D o " 0::1 ri-;::D - r -nrn :b? go ~>'T -c, ',3:D -,(') ~~m ~ <)> , :0 -< '"",,'" "oJ " _~. ~" '" '......a...,. ~,'" , . JOHN CHRISTOPHER, III, Plaintiff : IN THE <XlORT OF CDMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . . . . vs. : NO. 00-6047 CIVIL TERM : REBEKAH S. CHRISTOPHER, Defendant . . CIVIL ACTION - LAW IN CUSTODY : aIDER OF COURT AND NCIiI, this ~. consideration of the attached and directed as follows: day of )'LL I.., , 2000, upon CUstody Conciliation Report, it is ordered 1. The Father, John Christopher, III, shall have primary physical custody of Alexandria R. Christopher, bom July 26, 1995, Adrienne D. Christopher, bom November 25, 1996, and John Christopher IV, bom November 24, 1997. 2. The Mother, Rebekah S. Christopher, shall have supervised pedods of custody with the Children on altemating Saturdays, beginning December 2, 2000, from 10:00 a.m. until 4:00 p.m. and on every Monday and Wednesday fran 5:00 p.m. until 8:00 p.m. The parties agree that the supervision required by this Order shall be provided by the Mother's sister, Rachel Staub. For purposes of this Order, the requirement of supervision shall mean that all exchanges of custody shall take place at Rachel Staub's residence and, if the Mother intends to remove the Children from Ms. Staub's presence, the Mother shall ensure that Ms. Staub is aware of the Mother's whereabouts with the Children and the planned time of return to Ms. Staub's residence. The Mother shall also check in periodically with Ms. Staub to advise of any change in plans. The parties acknowledge that the purpose of the supervision requirement is to ensure that the Mother's compliance with the custody schedule is monitored on an ongoing basis by a responsible adult selected by agreement of the parties. 3. OVer the Christmas holiday in 2000, the Mother shall have periods of supervised custody with the Children on Christmas Eve from 12:00 noon until 6:00 p.m. and on Christmas Day fran 5:00 p.m. until 8:00 p.m. 4. The parties shall cooperate in making any necessary adjustments to the custody schedule to accommodate Rachel Staub's work and personal schedule in order to ensure her availability for supervision. 5. The Mother shall not remove the Children fran Cumberland county unless Rachel Staub is present at all times. 6. Each party shall notify the other of any medical problems, illnesses or injuries involving the Children during his or her periodS of cU$tody. 7. Neither party shall do or say anything which may estrange I~ ~'lii~!l<<tlil' .- . r -- ji 11 II 11 i ;;1 :;! ;~ ,;1 jl ,,~ , . IIIINIIlI'lIlfIm,f. "-'-,' 8 0 0 0 -ore 0 -n ~m ~ 'r 4; 1<'1,:n 65S: I ~i')m ;:$Z .r:- ag c5 $ -0 --I ~8 :x ~1: j;j <:J:-:..:.. ~ "'0 ~ am CJ'/ ~ 0 -< , , . . Jl!llII'~C'" .""."ryP....~ " "~?_,,"'"'>l..__~~~J'lJ1~~~II~mt,_m" " ,- ~ ,. -",~_"'"'!'~>", " ~ , , the Children from the other parent, injure the op1mon of the Children as to the other parent, or hamper the free and natural development of the Children's love and respect for the other parent. Both parties shall take all reasonable steps to ensure that third parties having contact with the Children comply with this provision. 8. The parties and their counsel shall attend a second Conciliation COnference in the office of the COnciliator, Dawn S. Sunday, on February 15, 2001 at 11:00 a.m. for the purpose of reviewing the custody arrangements and determining whether there is a continuing need for supervision. 9. This order is entered pursuant to an agreement of the parties at a CUstody Conciliation Conference. The parties may modify the provisions of this order by mutual consent. In the absence of mutual consent, the terms of this order shall control. BY THE COURT, i J. cc: Samuel L. Andes, Esquire - Counsel for Father Maryann Murphy, Esquire - Counsel for Mother ~~ 12-L/-OO ~S 'r-m.,.;'"" , , ,~ ""...,"'~_.... -" "=~d~"" . JOHN CIlRISTOPHER, III, : IN THE OOURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. : NO. 00-6047 CIVIL TERM : REBEKAIl S. CHRISTOPHER, . CIVIL ACTION - LAW . Defendant . IN CUSTODY . PRIOR JUDGE: Kevin A. Hess CUSTODY cnlCILIATICI!iI SUMMARY REPORT IN ACXXIIDANCE WITH CUMBERLAND ClOONTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUS'lWY OF Alexandria Christopher Adrienne D. Christopher John c. Christopher, IV July 26, 1995 November 25, 1996 November 24, 1997 Father Father Father 2. A Conciliation COnference was held on November 29, 2000, with the fOllowing individuals in attendance: The Father, John Christopher, III, with his counsel, Samuel L. Andes, Esquire, and the Mother, Rebekah S. Christopher, with her counsel, Maryann Murphy, Esquire. 3. The parties agreed to entry of an Order in the form as attached. A~ (5'CS' ~) Date Dafd~/Ms~ Custody Conciliator - ~- ~lh-'- , , JOHN CHRISTOPHER, III, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. : NO. 00-6047 CIVIL TERM . . REBEKAH S. CHRISTOPHER, . CIVIL ACTION - LAW . Defendant . IN CUSTODY . OODER OF COURT AND 1'iDIJ, this 3 J ... consideration of the attached and directed as follows: day of t ~ ~ ' 200t; upon Custody Conci iation Report, it is ordered 1. The prior Order of this COurt dated December 4, 2000, is vac:;ated and replaced with this Order. 2. The Father, John Christopher, III and the Mother, Rebekah S. Christopher, shall have shared legal custody of Alexandria R. Christopher, born July 26, 1995, Adrienne. D. Christopher, born November 25, 1996 and John Christopher IV, born November 24, 1997. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 3. The Father shall have primary physical custody of the Children. 4. The Mother shall have partial physical custody on alternating weekends from Friday at 5:00 p.m. through Sunday at 7:00 p.m., beginning February 2, 2001, and every week from Wednesday at 5:00 p.m. through Thursday at 10:00 a.m., beginning January 24, 2001. until such time as the Mother obtains her own residence, during her periods of custody, the Mother shall reside with the Children at the Mother's grandparents' home. 5. During the summer school break each year, each party shall be entitled to have custody of the Children for 3 uninterrupted weeks (to be scheduled non-consecutively unless agreed otherwise). Periods of custody under this provision shall include 7 full days and shall be scheduled from Friday through Friday, to begin on the custodial party's regular weekend period of custody. The parties shall notify each other of his or her selection of dates under this provision by May 1 of each year. The party providing notice first shall be entitled to preference on his or her selection of dates for custody. 6. The parties shall share having custody of the Children on Easter Sunday in 2001, with the Mother having custody of the Children under the regular alternating weekend schedule from Friday, April 13 through . . r~~"""'''''-'''''' .- ,-~ , .~ ~ ',~',~v,~ ~~ ) Fit cf)_.,.riJ.:-ev"lc OF or;. ,,~l. ,.l:~~__,.,'::'.i I ,i.,.... . ',C'- ,-., ""~"'A"'AAY " , . ",,-, ,IJ,'\;.';'I o I FrB -,' ", 8 HFi : /6 CUM~ERLNiO COUNTY I ENNSYLVANlA lP,' i . _ .~ _~~.!iI'lW,i!~~~~-:}~~!\!;~>~}~~ ~C"- "' -, ~ ~"" Easter Sunday at 3:00 p.m. and the Father having custody on Easter Sunday beginning at 3:00 p.m. The parties shall share or alternate having custody of the Children over the remaining holidays as arranged by agreement. In the event the parties are not able to establish an agreed upon holiday custody schedule by the end of August 2001, counsel for either party may contact the Conciliator to schedule an additional Conference to address the holiday issue. 7. with the exception of exchanges of custody on Thursdays at 10:00 a.m., the party receiving custody of the Children shall be responsible to provide transportation for the exchange of custody. The Mother shall provide transportation to the Father's residence for the return of custody on Thursdays, unless otherwise agreed between the parties. The parties shall conduct all exchanges of custody in a civil and cooperative manner to promote the best interests of the Children. Unless circumstances require otherwise, the parties agree that the party receiving custody shall remain in his or her residence and the party relinquishing custody shall remain in his or her vehicle. 8. During periods of custody with the Children, both parties shall refrain frcm using illegal drugs or drinking alcohol to excess. Both parties shall ensure that all third parties having contact with the Children comply with this provision. 9. Neither party shall do or say anything which may estrange the Children fran the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development of the Children's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Children comply with this provision. 10. This order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE CDURT, J. cc: Samuel L. Andes, Esquire - Counselor Father Maryann Murphy, Esquire - Counsel for Mother y l' ~,\ \) O'};'D~ , ~ , 'c__. ~.~ :0;-' JOHN CHRISTOPHER, III, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. : NO. 00-6047 CIVIL TERM : REBEKAH S. CHRISTOPHER, : CIVIL ACTION - LAW Defendant . IN CUSTODY . PRIm JUDGE: Kevin A. Hess CUSTODY CCNcrLIATION SUMMARY REPC4l.T IN ACCC4IDANCE WITH CUMBERLAND <XXlNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Alexandria Christopher Adrienne D. Christopher John C. Christopher, IV July 26, 1995 November 25, 1996 November 24, 1997 Father Father Father 2. A Conciliation Conference was held on January 23, 2001, with the following individuals in attendance: The Father, John Christopher, with his counsel, Samuel L. Andes, Esquire, and the Mother, Rebekah S. ChristOpher, with her counsel, Maryann Murphy, Esquire. 3. The parties agreed to entry of an order in the form as attached. Date J T'lA'I" /} ""1 --1- '-f. J-o () I f2A~~ Dawn S. Sunday, Esquire Custody Conciliator ~ , ,. ~""; . JOHN CHRISTOPHER, III PLAINTIFF V_ REBEKAHS.CHRISTOPHER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-6047 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, July 20, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Snnday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Monday, August 20,2001 at 1:00 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 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 THE COURT, By: Isl Dawn S. Sunday. Esq. tI) 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 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 r'~-'-~--"- . -, --~ '"-"'.< ku.-,'''." ___"~ '_'. "",..," .", , '-=- _~~~ '" - ~ , , -~~~- '.'''~="--' ';. ""'=" ~ ~ ~,,"> ."~ -" ""~" ,."', C'! I;P -) :-~),' I: :~1S~ CUJ\L,,_-, 7. ;J3-01 7;}3-tll 7,) , d.J -0 ( W &~ ~ -t; 4- frlt1~ 71~~Z~ 0~ ~i;;4~ . ~ "':'~~ _ilI~!"",""".~""" _ r~j ,'~ ."l#l'ifl"""!'II'i!!~"""~IlIli.,~"v:, ,_" "" ?,_''''e__ ~~'ll!IWf!*;m:il!!!~~~.'!fll.ffi, "." .. ...... ',,'.,'_'-4_ O' -~ - ;"... JOHN CHRISTOPHER, m, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLV ANlA v. CML ACTION - LAW 2000-6047 CIVIL TERM REBEKAH S. CHRISTOPHER, Defendant/Petitioner IN CUSTODY ORDER OF COURT AND NOW, this day of . 2001, upon consideration of the attached petition, it is hereby directed that the parties and their respective counsel appear before Esquire, the conciliator, at . on the day of ,2001 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. All children age five or older may also be present at the conference. Failure to appear at this conference may provide grounds for entry of a temporary or pennanent order. By 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, Pennsylvania 17013 (717) 249-3166 1-800-990-9108 "",",." "~':""-.-" ,~-~ :;~ . .,,' . '_.,~_.- "' ..,,,- ~"":.i. 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 scheduling conference or hearing. . - ,. . "' ~ ~,' _0"'-'-' . - '... - ,."~. -~ i . . -:r.", "~ . ,-;':','"-' - '_'_'"'c__' ., ~,~-' " -, -~f; JOHN CHRISTOPHER, III, PlaintifflRespondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2000-6047 CIVIL TERM REBEKAH S. CHRISTOPHER, DefendantJPetitioner IN CUSTODY PETITION FOR CUSTODY AND NOW, this 18th day of July 2001, comes the Petitioner, Rebekah S. Christopher, by her attorneys, Irwin, McKnight and Hughes, and presents the following Petition for Custody. 1. The Petitioner is Rebekah S. Christopher, an adult individual residing at R.D. #1, Box 310, New Bloomfield, Perry County, Pennsylvania 17068. 2. The Respondent is John Christopher, III, an adult individual residing in 215 West North Street, Carlisle, Pennsylvania 17013. 3. The parties are the natural parents of three (3) minor children, namely, Alexandria R. Christopher, bom July 26, 1995, age 5 years; Adrienne D. Christopher, born November 25, 1996, age 4 years; and John Christopher, IV, bom November 24,1997, age 3 years. -..fw- , ~,-~---, ",' -,",",,- ....,. "i'-: ~"--- "". '--- .~: . . 4. The children require more time with their mother in order to maintain a strong relationship. The Petitioner seeks shared physical custody of the children. 5. The best interest of the children requires that the Court grant the Petitioner's request as set forth above. A copy of the current Order of Court dated January 31, 2001 is attached hereto and incorporated by reference herein. WHEREFORE, Petitioner respectfully seeks the entry of an Order of Court seeking shared legal custody as set forth above. Respectfully submitted, Marcus . McKnight, 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court 1. D. No. 25476 T & HUGHES By: Date: July 18, 2001 ,~ .- ..l . I ~ ~, ,J I > _ " , , ~. '" ~ ,e ~., _ ......... oq ~ f JOHN CflRISTOPHER, III, : IN THE COURT OF OJMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-6047 CIVIL TERM : REBEKAH S. CHRISTOPHER, : CIVIL AcrION - LAW Defendant IN CUSTODY ORDER OF COURT AND Naol, this "3 I ... consideratioo of the attached and directed as follows: day of t ~ ~ ' 200t, upon Custody Conci iation Report, it is ordered 1. The prior order of this Court dated December 4, 2000, is vacated and replaced with this order. 2. The Father, John Christopher, III and the Mother, Rebekah S. Christopher, shall have shared legal custody of Alexandria R. Christopher, born July 26, 1995, Adrienne D. Christopher, born November 25, 1996 and John Christopher IV, born November 24, 1997. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being inclUding, but not limited to, all decisions regarding their health, educatioo and religion. Children. 3. The Father shall have primary physical custody of the 4. The Mother shall have partial physical custody on alternating weekends from Friday at 5:00 p.m. through Sunday at 7:00 p.m., beginning February 2, 2001, and every week from Wednesday at 5:00 p.m. through Thursday at 10:00 a.m., beginning January 24, 2001. Until such time as the Mother obtains her own residence, during her periods of custody, the Mother shall reside with the Children at the Mother's grandparents I home. 5. During the summer school break each year, each party shall be entitled to have custody of the Children for 3 uninterrupted weeks (to be scheduled non-consecutively unless agreed otherwise). Periods of custody under this provision shall include 7 full days and shall be scheduled from Friday through Friday, to begin on the custodial party I S regular weekend period of custody. The parties shall notify each other of his or her selection of dates under this provision by May 1 of each year. The party providing notice first shall be entitled to preference on his or her selection of dates for custody. 6. The parties shall share having custody of the Children on Easter Sunday in 2001, with the Mother having custody of the Children under the regular alternating weekend. schedule from Friday, April 13 through ~" ,"" . '" e' '{ , , , \.. Easter Sunday at 3:00 p.m. and the Father having custody on Easter Sunday beginning at 3:00 p.m. The parties shall share or alternate having custody of the Children over the remaining holidays as arranged by agreement. In the event the parties are not able to establish an agreed upon holiday custody schedule by the end of August 2001, counsel for either party may contact the Conciliator to schedule an additional Conference to address the holiday issue. 7. with the exception of exchanges of custody on Thursdays at 10:00 a.m., the party receiving custody of the Children shall be responsible to provide transportation for the exchange of custody. The Mother shall provide transportation to the Father's residence for the return of custody on Thursdays, unless otherwise agreed between the parties. The parties shall conduct all exchanges of custody in a civil and cooperative rrenner to promote the best interests of the Children. Unless circumstances require otherwise, the parties agree that the party receiving custody shall remain in his or her residence and the party relinquishing custody shall remain in his or her vehicle. 8. During periods of custody with the Children, both parties shall refrain from using illegal drugs or drinking alcohol to excess. Both parties shall ensure that all third parties having contact with the Children comply with this provision. 9. Neither party shall do or say anything which may estrange the Childret1 from the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development of the Children's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Children comply with this provision. 10. This Order is entered pursuant to an agreement of the parties at a CUstody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE CDOOT, ~./IL Kevin f . Hess, / Samuel L. Andes, Esquire - Counsel {~r Father Maryann Murphy, Esquire - Counsel for Mother J. cc: .y ,('{ t~D\~ ccr~'.J r."' ) ".-.,' ..:~-~.... ~~. I~ ~ -.I...... . . i_ ';-;:;::;~_.;-: ':.;~;f)\ ! ':"SJ>:;:t'~, i;r~_ :::FJ ,r, ......'. > .,.~~' t ._,......~ I J., , ' l_,l,. :~~J: \ .: i ........" . . ..,. 'l:1;~~ lJ..-ti.1.. \;1 .':'I~.'~ ,.,J . ~.-L. ~:~,.---"-,<? (\2:; irt' (#- .1_.,-,.-:=AY?2 - . - ~ . -- Prot".":~,,rl~,:_~~ f I ~,n,' > "'.' . "'-,--,.",;,'_,_, '_'-"'_;""00 _ 'r,"'" ~."'; "",'.--,,,_. '-i - '<ii~,""',~,,_ _, ,_o__,_,'",",~ "." _ ~_~ ,_ ",'.:0 ,-CO,," _~",._i '-;:""'H"''-.:.k~''-' ","yO '~--h ;_'",;;,;,-,i;~_*;'-_,_o _ '__~, ,-'" " . VERIFICATION I have read the statements made in the foregoing Petition for Custody and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: Julv 18 .2001 ',,' .> ~ -.,~ "'fj -il.'''' <~, ~-it ",'-" , ;_~- h' "1:;"_,. ., ~ '" ~. "". .. G;)~~ ...t:- O 1>1\ ~ - ~ -- ~, B 0- D! ~. " , ~ ,~ ~, ., l! 2 "--c. J *~~ ,. . ,_,.~ 0 " - ~ " .-~_. ij II I :! I i II I C) i1 c:; ~.? " , 'Il (.--- " Co'" .~." -, " ~"'-li> r. JOHN CHRISTOPHER, III PLAINTIFF v. REBEKAH S. CHRISTOPHER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNfY, PENNSYL V ANlA 00-6047 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, July 26, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicshurg, PA 170~5 on Tuesday, August 21, 2001 at 2:00 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. The court hereby directs the parties to furnish auy and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Dawn S. SundaJl. Esq.M 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 ~ ~,' l--,... 7c2~-d1/ 7-d?~ -t!J/ 7';l~ '(~'I ",-:-;:r.;' ,1",1 ,,:, - (- '-~' , .1' ,'.- M-~~d;4 /H~ /t~~z~ /~/n~ ~4~ " " ~.r ~'1 ~ _ ~m!!'_ ,... ,__ rr~?,~~"i'\W1'1Iffi1""'~""-"'. )"""_,, ~"",,,,,,,,,.~~,,,:jlTnlll ,,_ _ _' ~ ,'''',c , . -' '.,~, - ,- ,,'~ JOHN CHRISTOPHER, III, PlaintiffIRespondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2000-6047 CML TERM REBEKAH S. CHRISTOPHER, Defendant/Petitioner IN CUSTODY ORDER OF COURT AND NOW, this day of ,2001, upon consideration of the attached Petition for Special Relief, IT IS HEREBY ORDERED that a hearing regarding this Petition for Special Relief is , hereby scheduled for , 2001, at _o'clock _.m. in Courtroom Number _ , Cumberland County Courthouse, Carlisle, Pennsylvania 17013 at which time the parties along with their legal counsel shall appear in person. Pending said hearing, the terms of the Order of Court dated January 31, 2001, will be obeyed by the parties. ~> ~ 7 J.~$("~ BY THE COURT, Kevin A. Hess, Judge JOHN CHRISTOPHER, III, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2000-6047 CIVIL TERM REBEKAH S. CHRISTOPHER, Defendant/Petitioner IN CUSTODY PETITION FOR SPECIAL RELIEF AND NOW, this 18th day of July 2001, comes the DefendantJPetitioner, Rebekah S. Christopher, by her attorneys, hwin, McKnight & Hughes, and makes the following Petition for Special Relief against the Plaintiff/Respondent, John Christopher, 1II: 1. The Petitioner is Rebekah S. Christopher, an adult individual who resides at R.D. #1, Box 31 0, New Bloomfield, Perry County, Pennsylvania 17068. 2. The Respondent is John Christopher, III, an adult individual who resides at 215 West North Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are the natural parents of three (3) minor children, namely, Alexandria R. Christopher, born July 26, 1995, age 5 years; Adrienne D. Christopher, born November 25, 1996, age 4 years; and John Christopher, IV, born November 24,1997, age 3 years. 2 - ." -~< '.'- --" --,,-- n" '. '" >' '_n'" _ ,~'",'" _.'_,,~_ C-"'--~~"~';~:"",_.:- ;c.'. . -- - 4. By Order of Court dated January 31, 2001, the rights of the parties regarding the custody of the above children were established. A copy of said Order of Court is incorporated by reference and made a part of this Petition. 5. Since June 2001, the Respondent has not permitted the children to be with the Petitioner. The Petitioner seeks that the terms of the Order of Court be complied with by the Respondent. 6. The best interest of the children requires that the Court grant the Petitioner's request as set forth above. WHEREFORE, the Petitioner, Rebekah S. Christopher, respectfully requests that this Honorable Court enter an Order granting Petitioner a hearing to enforce the existing Order of Court. Respectfully submitted, mWIN, Mc By: Marcus A. cKnight, II , E e Attorney for Petitioner, Re ekah S. Christopher West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 717-249-2353 Supreme Court 1.0. No. 25476 Date: July 18,2000 3 "' ,''I'' -"IE \J . ~ , Ii . _ , . ~ ...~.,..... .:.. _ .. l . JOHN CHRISTOPHER, III, : IN THE OOURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. QO-6047 CIVIL TERM REBEKAH S. CHRISTOPHER, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COORT AND NCW, this :3 J'" consideraticn of the attached and directed as follows: day of t ~ ' 200t', upon Custody Conci iaticn Report, it is ordered 1. The prior Order of this court dated December 4, 2000, is vaqated and replaced with this Order. 2. The Father, John Christopher, III and the Mother, Rebekah S. Christopher, shall have shared legal custody of Alexandria R. Christopher, born July 26, 1995, Adrienne D. Christopher, born November 25, 1996 and John Christopher IV, born November 24, 1997. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-ernergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, educaticn and religion. Children. 3. The Father shall have primary physical custody of the 4. The Mother shall have partial physical custody on alternating weekends from Friday at 5:00 p.m. through Sunday at 7:00 p.m., beginning February 2, 2001, and every week from Wednesday at 5:00 p.m. through Thursday at 10:00 a.m., beginning January 24, 2001. until such time as the Mother obtains her own residence, during her periods of custody, the Mother shall reside with the Children at the Mother's grandparents' home. 5. During the summer school break each year, each party shall be entitled to have custody of the Children for 3 uninterrupted weeks (to be scheduled non-consecutively unless agreed otherwise). Periods of custody under this provision shall include 7 full days and shall be scheduled from Friday through Friday, to begin on the custodial party's regular weekend period of custody. The parties shall notify each other of his or her selection of dates under this provision by May 1 of each year. The party providing notice first shall be entitled to preference on his or her selection of dates for custody. 6. The parties shall share having custody of the Children on Easter Sunday in 2001, with the Mother having custody of the Children under the regular alternating weekend. schedule from Friday, April 13 through I > ,-:" ~'_ .L .i:-~I ," " Easter Sunday at 3:00 p.m. and the Father having custody on Easter Sunday beginning at 3:00 p.m. The parties shall share or alternate having custody of the Children over the remaining holidays as arranged by agreement. In the event the parties are not able to establish an agreed upon holiday custody schedule by the end of August 2001, counsel for either party may contact the Conciliator to schedule an additional Conference to address the holiday issue. . 7. With the exception of exchanges of custody on Thursdays at 10:00 a.m., the party receiving custody of the Children shall be responsible to provide transportation for the exchange of custody. The Mother shall provide transportation to the Father's residence for the return of custody on Thursdays, unless otherwise agreed between the parties. The parties shall conduct all exchanges of custody in a civil and cooperative manner to promote the best interests of the Children. Unless circumstances require otherwise, the parties agree that the party receiving custody shall remain in his or her residence and the party relinquishing custody shall remain in his or her vehicle. 8. During periods of custody with the Children, both parties shall refrain frem using illegal drugs or drinking alcohol to excess. Both parties shall ensure that all third parties having contact with the Children comply with this provision. 9. Neither party shall do or say anything which may estrange the Childre.'1 frem the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development of the Children I s love and respect for the other parent. Both parties shall ensure that third parties having contact with the Children comply with this provision. 10. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE CDORT, ;t2l,~l Kevin/ . Hess, Samuel L. Andes, Esquire - Counsel ~ Father Maryann Murphy, Esquire - Counsel for Mother J. cc: .oY t . ~'\ ~ ,0 O~D\~ r . >. ',.,>/ C'[";L', ~:. ~ ~C:C.\:-.:) i ..J~',.... ., '....~. , .". .~, ...,.,' :,,\".:'1:, . ,,' I ~' ., "L' t.Jr-' .; I.' ,...... '..... ';:.' ..:,,~~:.";;',; -N;~~':':'f)1.: f',\i.JfL '..l:~"'~'.;".~.' (')., ;r; ..... ',,""', ", ~~ I ~i11"'~ I J. I J' ,J ...1 ; :~t~: "." ~.....:. ' ' . . ..,. l'~,~1!'l: ~~~ ~:" ..,~,.A '.'''' . ~-L '~.;"~~;~.".~~" at) ~ ;" ft1-- ",'u _ ~ _. . ..,. PrO!\'I.,,-,r,:;', ' "I~,;\,r . ~ . ..,,-~ . 'I, ' <'~-. '- . ~ . . VERIFICATION I have read the statements made in the foregoing Petition for Special Relief and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: .TIlLY 18 .2001 nIB- ~=-- - ~ ' . ~ " --. -' "-''''DIi~"U ~--,~- '^ .~--~,",,'''''-'~'- ~"- ,'~-,- .""","-,. ,,< ~,. --', ~-'--~:: "'--",,., >< " .,." .~,",,-- -. .,,' .",- , ". -.-,.-.-.:. '," ',-. ,-.,.-- ,-,;- " ~ 1- ~ ~ C) & ~- '.') <:~o :-." , -- . -- - - 8 0() -- - .l:: "\l t{::- ~ --..J C~ f! <,-, -t; ::. -~ ~ :., ..-- ,..~ l:.:J . ,', -' .- ""~ ~."'"' .~ <<" ,- d .' ~' - " JOHN CHRISTOPHER III, Plaintiff/Respondent vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-6047 CIVIL CIVIL ACTION - LAW REBEKAH S. CHRISTOPHER, Defendant/Petitioner ORDER AND NOW, this 9~ day of October, 2001, on agreement of the parties and pending further order of court, it is ordered and directed that, beginning on Saturday, October 13, 2001, at 10:00 a.m. and going to Sunday at 5:00 p.m., the petitioner, Rebekah S. Christopher, will have temporary custody of the three children named in her petition. She shall have a similar period of partial custody on alternating weekends thereafter. Said custody shall be at the home of her mother, Margie Grove, at R. D. #1, Box 310, New Bloomfield, Pennsylvania. At all times during said periods of custody, the maternal grandmother will be present with the petitioner at that home. At no time will strangers who are not members of the family be permitted to come to the home while the petitioner has custody. Neither party shall disparage the other in the presence of the children. Moreover, the petitioner will assure that the children attend any previously scheduled activities. BY THE COURT, Samuel 1. Andes, Esquire For the PlaintifJ:/Respondent *H~~ jJ~ L }()-/()-o I Marcus McKnight, III, Esquire For the Defendant/Petitioner """,",.,,.'~ ah ~ -> ".. ..- ,'~~ .'--'-"'t'_lP"-~ ~"lllll~""'''''''''"<i~;~~w/;tl~~'':'''';' -', (-'I~:T ; .., ;-" Ej~ ,-,[, - , CUI\;PEi:MSYL\(~K~~\)N1Y ~-'-" '.,"-- %" .~ <. ., r -;>.~,." - -~"'- ~.- ~- ~ " <- , 0.': i~i ir~ r: " " -_.-' ..J ~ .- _>< - ,.J. """ "" .d'e'_ . JOHN CHRISTOPHER, III, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V, REBEKAH S. CHRISTOPHER, Defendant 00-6047 CIVIL TERM IN RE: CUSTODY AGREEMENT Proceedings were held before the HONORABLE KEVIN A. HESS, J., Cumberland County Courhtouse, Carlisle, Pennsylvania, Courtroom Number 4, October 5, 2001. APPEARANCES: SAMUEL ANDES, ESQUIRE For - the Plaintiff MARCUS McKNIGHT, ESQUIRE For - the Defendant 'Ol . '"'-. c" ..~fil ~~ ,,~ ~y < ;_J . -~, CU'\i:"'~;r::.i :;,..,.,," (:C':tINTY r- 1- , \ 'jr\ ! c~ \.I! \ ,I ,\ r I" , .....' \' ,...... i Li/'\. \:/\ -.~. .,,_, 'C~" ," , .,.,,~~~~IlJ!~~~~~..;Jl ;lIW!l'fo r>l!lr:1Mf /,,.-, ~ - , _.I ~ L ~, ,.;, . ""'~ , "''' 1 October 5, 2001 2 Carlisle, Pennsylvania 3 4 (Whereupon, the following proceedings were held 5 at 3:28 p.m.) 6 MR. ANDES: Good afternoon. 7 THE COURT: Good afternoon. I understand there is 8 a resolution of the matter, and one of you can tell me what it 9 is, and I will have it transcribed, and turn it into an order 10 of Court, which would begin: AND NOW, this date on agreement 11 of the parties, pending further Order of Court -- we 12 understand this is only temporary -- 13 MR. ANDES: That's correct, Your Honor. 14 MR. McKNIGHT: Right. 15 THE COURT: it is ordered and directed that -- 16 MR. McKNIGHT: Beginning on Saturday, October the 17 13th at 10:00 a.m., and going to Sunday at 5:00 p.m., the 18 Petitioner, or the Defendant in this case, Rebecca S. 19 Christopher, will have temporary custody of the three named 20 children in the petition. 21 And that period of custody will be held at her 22 mother's home, Margie Grove, located at R.D. 1, Box 310, New 23 Bloomfield, Pennsylvania. And at all times during this period 24 of custody, the maternal grandmother will be present with the 25 petitioner in that home. 2 11KU' ~ 'J' ".' ~" 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Furthermore, that the Petitioner agrees that at no time will any strangers come to the home who are not members of the family while she has that period of custody. Furthermore, that this is a temporary order, and that either Petitioner has the right to go back before the custody conciliator to attempt to modify it or seek more time in the case of the Petitioner. And finally, that neither would disparage the other party in the presence of the children. MR. ANDES: THE COURT: MR. ANDES: One other point, Your Honor. Certainly. During the periods of time that the mother is exercising the temporary custody in the presence of her mother, they will see to it that the children attend regularly any previously scheduled activities. And for the record -- this doesn't have to be in the order. But at this point the activities of which we are aware, the two of the children are involved in cheer leading for midget football games on Saturday afternoons. And my client will be happy to provide information about the times and locations of those games. MR. McKNIGHT: That will be acceptable to us, and it is understood that after the 13th this period of visitation will be every other weekend alternatively. MR. ANDES: Yes, alternating weekends. 3 c -,. l'~ c . -, - ,'- -. ~-L p .'.' '__-~ 1,5_" 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: Okay. Thank you. MR. ANDES: Thank you, Your Honor. (Whereupon, the recitation of the agreement concluded. ) 4 ."~ ~- i -~- l..:' .J:llrlll,;i';l;," 1 2 CERTIFICATE 3 4 5 I hereby certify that the proceedings are contained 6 fully and accurately in the notes taken by me on the above 7 cause and 8 9 10 11 12 13 14 that this is a correct transcript of the same. do~1Ad~tM~ rraine K. Troutman, RPR 15 The foregoing record of the proceedings on the hearing 16 of the within matter is hereby approved and directed to be 17 filed. 18 19 20 ():Je/w fa 1:44 Date 21 22 23 24 25 A. Hess, J. Judicial District 5 - -- -' ~'li"i JOHN CHRISTOPHER, III PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 00-6047 CIVIL ACTION LAW REBEKAHS.CHRISTOPHER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, December 04, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawu S. Suuday, Esq. , the conciliator, at 39 West Maiu Street, Mechauicsburg, FA 17055 on Wednesday, January 02, 2002 at 1:00 PM 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 THE COURT, By: Isl Dawn S. SundaJ'. Esq. QVVI 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 TIUS 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 ~ - -~ "- - - .' ,-_.~"-- '"-,,, _,.', ~. ". .~ _~"~~_o,"_,;_'r."_"_~_"~C ~.,,~__ ~~" ~~ ~~ Ic;J -s .tJ ( /0} -5'iJi /:2 ;).0/ (11 Dr,> -, ul )c.L~-J Pi',; '".:)''111 . OJ d. <,:J CUi<!:;:~'::_::;i -,."J"- ,- i'""':l..j iL!"U\' i'l "!'-.JU-' i~'V Pr-N n ~ --',,)' ;\/ i Ci N::'YLVlWY\ f1r:/ t~ ~ ~ 4' /I1C~ '1'l~ ~ ~. ~- ~ 6>;~ f;1-a..w ~ ~ ~ , ~1 ~- -, ~","" ~M~II!lIlJ!lIII"""''''~~"- ". .~ .-.p,~~~!0~4i'_~~~Wl';~"-'llI_~i\!i~i'#,'ftm!'lfll~,. - , -- ~-"=--- ~"',"- -,-~" ~ >. ,'""-d,,,, r,-",J,.;:<i.C'-""'-""";';. ,;~" .'d ,_i' ,-"L,--,-,,---,;':~-ili':~"","<~,~_ ",~ JOHN CHRISTOPHER, III, Plaintiff/Respondent NOV 2 I} Z001 Lf IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2000-6047 CML TERM REBEKAH S. CHRISTOPHER, Defendant/Petitioner IN CUSTODY ORDER OF COURT AND NOW, this day of , 2001, upon consideration of the attached petition, it is hereby directed that the parties and their respective counsel appear before Dawn W. Sunday, Esquire, the conciliator, at 39 West Main Street, Mechanicsburg, Pennsylvania 17055, 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. All children age five or older may also be present at the conference. Failure to appear at this conference may provide grounds for entry of a temporary or permanent order. By 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, Pennsylvania 17013 (717) 249-3166 1-800-990-9108 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 scheduling conference or hearing. ~, "~" <,. ~".~. --"-~ --~ ^" ~~" -""~.r"-r ~.-'--^-A~' --"1 JOHN CHRISTOPHER, III, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2000-6047 CML TERM REBEKAH S. CHRISTOPHER, Defendant/Petitioner IN CUSTODY PETITION FOR CUSTODY AND NOW, this 27th day of November 2001, comes the Petitioner, Rebekah S. Christopher, by her attorneys, Irwin, McKnight and Hughes, and presents the following Petition for Custody. 1. The Petitioner is Rebekah S. Christopher, an adult individual residing at R.D. #1, Box 310, New Bloomfield, Perry County, Pennsylvania 17068. 2. The Respondent is John Christopher, III, an adult individual currently residing at Lot 10, 10 Betty Nelson Court, Carlisle, Pennsylvania 17013. 3. The parties are the natural parents of three (3) minor children, namely, Alexandria R. Christopher, born July 26, 1995, age 5 years; Adrienne D. Christopher, born November 25, 1996, age 4 years; and John Christopher, N, born November 24, 1997, age 3 years. ,.,,,-,",, -''- -."''"'''''" ';.,-,,- ~ "-_.tt,~,""t """'_ ,,_ ,,,_;)2-,,,, ~'"." '_',;: - '"'"'"" 4. By Order of Court dated October 9, 2001, the custody of the above children was set by Judge Kevin A. Hess. A copy of said Order of Court is incorporated by reference and made a part of this Petition and is marked as Exhibit "A". 5. In light of recent changed circumstances, the children require more time with their mother in order to maintain a strong relationship. The Petitioner seeks shared physical custody or primary physical custody of the children. 5. The best interest of the children requires that the Court grant the Petitioner's request as set forth above. WHEREFORE, Petitioner respectfully seeks the entry of an Order of Court seeking shared legal custody as set forth above. Respectfully submitted, By: 2? Date: November 27, 2001 JOHN CHRlSTOPHER III, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. 00-6047 CIVIL CIVIL ACTION - LAW REBEKAH S. CHRlSTOPHER, Defendant/Petitioner ORDER AND NOW, this 'i~ day of October, 2001, on agreement of the parties and pending further order of court, it is ordered and directed that, beginning on Saturday, October 13, 2001, at 10:00 a.m. and going to Sunday at 5:00 p.m., the petitioner, Rebekah S. Christopher, will have temporary custody of the three children named in her petition. She shall have a similar period of partial custody on alternating weekends thereafter. Said custody shall be at the home of her mother, Margie Grove, at R. D. #1, Box 310, New Bloomfield, Pennsylvania. At all times during said periods of custody, the maternal grandmother will be present with the petitioner at that home. At no time will strangers who are not members of the family be permitted to come to the home while the petitioner has custody. Neither party shall disparage the other in the presence of the children. Moreover, the petitioner will assure that the children attend any previously scheduled activities. BY THE COURT, K,1tI;'~~ Samuel 1. Andes, Esquire For the Plaintiff/Respondent Marcus McKnight, III, Esquire For the DefendantlPetitioner .,. - -., ~, ^ .'~ ~", & -4l~; JOHN CHRISTOPHER, Ill, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. REBEKAH S. CHRISTOPHER, Defendant 00-6047 CIVIL TERM IN RE: CUSTODY AGREEMENT Proceedings were held before the HONORABLE KEVIN A. HESS, J., Cumberland County Courhtouse, Carlisle, Pennsylvania, Courtroom Number 4, October 5, 2001. ~J;r';>' r;;:, F.,"' ''I ''01l' \? r::liffi~ Iii';'. ',,' , or. ,J; .1 "..'''. \,:L.,L:>i,J;, ".'..... '''. If ,OJ '"" ~ '-",' !";:~":1 ~~' ~ iIT '1', ;'001 .,. ',,j Y....'-' APPEARANCES: itr,"lrl'Wr c:- i;,. /~\Ir'S IRWIN/ Mu\\\liuiil o.lluJii( SAMUEL ANDES, ESQUIRE For - the Plaintiff MARCUS McKNIGHT, ESQUIRE For - the Defendant ,- - ,- ,--, >. ~ '-'" ,-.' , -.._.'.i,'; 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 October 5, 2001 Carlisle, Pennsylvania (Whereupon, the following proceedings were held at 3:28 p.m.) MR. ANDES: Good afternoon. THE COURT: Good afternoon. I understand there is a resolution of the matter, and one of you can tell me what it is, and I will have it transcribed, and turn it into an order of Court, which would begin: AND NOW, this date on agreement of the parties, pending further Order of Court -- we understand this is only temporary -- MR. ANDES: That's correct, Your Honor. MR. McKNIGHT: THE COURT: MR. McKNIGHT: Right. it is ordered and directed that -- Beginning on Saturday, October the 13th at 10:00 a.m., and going to Sunday at 5:00 p.m., the Petitioner, or the Defendant in this case, Rebecca S. Christopher, will have temporary custody of the three named children in the petition. And that period of custody will be held at her mother's home, Margie Grove, located at R.D. 1, Box 310, New Bloomfield, Pennsylvania. And at all times during this period of custody, the maternal grandmother will be present with the Petitioner in that home. 2 ,. _, w~ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Furthermore, that the petitioner agrees that at no time will any strangers come to the home who are not members of the family while she has that period of custody. Furthermore, that this is a temporary order, and that either Petitioner has the right to go back before the custody conciliator to attempt to modify it or seek more time in the case of the Petitioner. And finally, that neither would disparage the other party in the presence of the children. MR. ANDES: THE COURT: MR. ANDES: One other point, Your Honor. Certainly. During the periods of time that the mother is exercising the temporary custody in the presence of her mother, they will see to it that the children attend regularly any previously scheduled activities. And for the record -- this doesn't have to be in the order. But at this point the activities of which we are aware, the two of the children are involved in cheerleading for midget football games on Saturday afternoons. And my client will be happy to provide information about the times and locations of those games. MR. McKNIGHT: That will be acceptable to us, and it is understood that after the 13th this period of visitation will be every other weekend alternatively. MR. ANDES: Yes, alternating weekends. 3 = ~ ; c ,"' )': . - - '-~ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I THE COURT: Okay. Thank you. MR. ANDES: Thank you, Your Honor. (Whereupon, the recitation of the agreement concluded. ) 4 . ",..---.(:' ' ","' 1 2 CERTIFICATE 3 4 5 I hereby certify that the proceedings are contained 6 fully and accurately in the notes taken by me on the above 7 cause and that this is a correct transcript of the same. 8 9 10 do~1Ad~tM~ rra~ne K. Troutman, RPR 11 12 13 14 15 The foregoing record of the proceedings on the hearing 16 of the within matter is hereby approved and directed to be 17 filed. 18 19 20 ():Jeb", fo 1:44 Date 21 22 23 24 25 J. District 5 .- -~ " ~~-~",,"" ,.-", ~ --"'-'"-~ '..'" ",,",,'''_'~''''-'''''c;.--'''''7,'~,--.__ _'-""__'._ ~';,_; VERIFICATION The foregoing Petition for Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: November 27,2001 ~. -'--;.;",,~ ~. .. '"'" ."- -"-~". .' I r !i '-., ;,i, ,...... p ." , ~::.? ~ Ji' n'"i -T/ '~... 2. to,,) .~~;b 7t. CIJ _'?:"; -.; ,- l" -, .~~? (~) ~ r r'::CJ "~""I-i l.. ~ -0 -..s. ..... '" .I:{I ~..,.() .-. S:;;'() .... ::::-,::;C) <::)rn ~ ):."c :;;- ~ -c-i :2: :::> ?iJ ::< rv -< " ,~,_. -~- ",*,;- , JOHN CHRISTOPHER, III PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 00-6047 CIVIL ACTION LAW REBEKJUiS.CFrnUSTOPHER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, December 10, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Maiu Street, Mechauicsburg, PA 17055 on Wednesday, Jauuary 02, 2002 at 1:00 PM 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 Protectiou from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Dawn S. SundaJ'. Esq. QY'^ 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 nus 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 l, " ~- < ~,_ .,^, ~_M " _.~-,-~,.. -,--. ,,"," "",~' -", ~."- --. .,-". . -~ OF ':'[_1. ',,' ,. (} I DEe I 1 Fu'.'j 11: 1:,''-~ . ~ CUiv;Sc:"';_../\\iU (-'1-'\' i:\nv PEi'J;\IC::'y'i1 u,~"';.<'--" \ j ~ .r,,,.: t..:iJ'\;\!r/-\ 1.;7/I'CJf M.~~-i; Icl-lh11 7~ ~ 'd, I;) j/-c/ t~ ~ z- 4 lilli!liii!l_ _ll /I'lC~ ~ _In!IlI~ " , '1-j!;l:" JOHN CHRISTOPHER, III, PlaintifflRespondent NOV 2 9 20011fJ IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2000-6047 CIVIL TERM REBEKAH S. CHRISTOPHER, Defendant/Petitioner IN CUSTODY ORDER OF COURT AND NOW, this Petition for Special Relief, day of , 200 I, upon consideration of the attached IT IS HEREBY ORDERED that a hearing regarding this Petition for Special Relief is hereby scheduled for , at o'clock _.m. in Courtroom Number _ , Cumberland County Courthouse, Carlisle, Pennsylvania 17013 at which time the parties along with their legal counsel shall appear in person. Pending said hearing, the terms of the Order of Court dated October 9, 2001, will be obeyed by the parties. BY THE COURT, Kevin A. Hess, Judge JOHN CHRISTOPHER, III, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2000-6047 CIVIL TERM REBEKAH S. CHRISTOPHER, Defendant/Petitioner IN CUSTODY PETITION FOR SPECIAL RELIEF AND NOW, this 27th day of November 2001, comes the DefendantJPetitioner, Rebekah S. Christopher, by her attorneys, Irwin, McKnight & Hughes, and makes the following Petition for Special Relief against the Plaintiffi'Respondent, John Christopher, III: 1. The Petitioner is Rebekah S. Christopher, an adult individual who resides at R.D. #1, Box 310, New Bloomfield, Perry County, Pennsylvania 17068. 2. The Respondent is John Christopher, III, an adult individual who resides at Lot #10, 10 Betty Nelson Court, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are the natural parents of three (3) minor children, namely, Alexandria R. Christopher, born July 26, 1995, age 5 years; Adrienne D. Christopher, born November 25, 1996, age 4 years; and John Christopher, IV, born November 24, 1997, age 3 years. 2 J:,~ -" 4. By Order of Court dated October 9,2001, custody of the above children was set by Judge Kevin A. Hess. A copy of said Order of Court is incoIporated by reference and made a part of this Petition and marked as Exhibit "A". 5. On or about Thanksgiving 2001, the Respondent was evicted from his apartment and moved without notifying the Petitioner. The Petitioner was denied custody of the children on November 24, 200 I. The Petitioner desires that she be awarded additional time with the children and that the Order of Court be enforced. 6. The best interest of the children requires that the Court grant the Petitioner's request as set forth above, and that she be awarded legal fees for the costs of filing this Petition. WHEREFORE, the Petitioner, Rebekah S. Christopher, respectfully requests that a hearing be scheduled before this Honorable Court. Respectfully submitted, Marcus . McKn Attorney for Peti 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 717-249-2353 Supreme Court J.D. No. 25476 By: Date: November 27,2001 3 , JOHN CHRISTOPHER III, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. 00-6047 CIVIL CIVIL ACTION - LAW REBEKAH S. CHRISTOPHER, Defendant/Petitioner ORDER AND NOW, this CJ~ day of October, 200 I, on agreement of the parties and pending further order of court, it is ordered and directed that, beginning on Saturday, October 13, 2001, at 10:00 a.m. and going to Sunday at 5:00 p.m., the petitioner, Rebekah S. Christopher, will have temporary custody of the three children named in her petition. She shall have a similar period of partial custody on alternating weekends thereafter. Said custody shall be at the home of her mother, Margie Grove, at R. D. #1, Box 310, New Bloomfield, Pennsylvania. At all times during said periods of custody, the maternal grandmother will be present with the petitioner at that home. At no time will strangers who are not members of the family be permitted to come to the home while the petitioner has custody. Neither party shall disparage the other in the presence of the children. Moreover, the petitioner will assure h'1at the children attend any previously scheduled activities. BY THE COURT, K,~,;,~4 Samuel L. Andes, Esquire For the Plaintifti'Respondent Marcus McKnight, III, Esquire F or the Defendant/Petitioner , ,-- ~. JOHN CHRISTOPHER, III, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. REBEKAH S. CHRISTOPHER, Defendant 00-6047 CIVIL TERM IN RE: CUSTODY AGREEMENT Proceedings were held before the HONORABLE KEVIN A. HESS, J., Cumberland County Courhtouse, Carlisle, Pennsylvania, Courtroom Number 4, October 5, 2001. ~ ,~.- ._-. \-. n ("1'" P'~" , !,~! ,"'''i'''''"'' : ;".' ,r' . "'1 ~~;'Ii-:'_ b. ,. [-:'~'..., ~,~ \,.:,- ;,,;-t j p. ,"Al'-' '~~I',""."_', ,_,~ r~", iJI fl!" ~ ~~~ ~ "'-'"' .~- \_~ ~'~;:" I J l~""" ~'~, ", "T '1'" "00', l....J,; i j i.t ~ APPEARANCES: " ^"',' . ." 'r(' Il"H^!H\ ~1,..lhq! ',.:! ;. :,"':_1..;,1'''1,. rIV~H\, fJ\U\i~iUHI G, \ iu''';ia..J SAMUEL ANDES, ESQUIRE For - the Plaintiff MARCUS McKNIGHT, ESQUIRE For - the Defendant .. J'." ">, ~ , ~,#W 1 2 3 4 5 6 7 .8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 October 5, 2001 Carlisle, Pennsylvania (Whereupon, the following proceedings were held at 3 :28 p.m.) MR. ANDES: Good afternoon. THE COURT: Good afternoon. I understand there is a.resolution of. the matter, and one of you can tell me what it. is, and I will have it transcribed, and turn it into an order of Court, which would begin: AND NOW, this date on agreement of the parties, pending further Order of Court -- we understand this is only temporary -- MR. ANDES: That's correct, Your Honor. MR. McKNIGHT: THE COURT: MR. McKNIGHT: Right. it is ordered and directed that -- Beginning on Saturday, October the 13th at 10:00 a.m., and going to Sunday at 5:00 p.m., the Petitioner, or the Defendant in this case, Rebecca S. Christopher, will have temporary custody of the three named children in the petition. And that period of custody will be held at her mother's home, Margie Grove, located at R.D. 1, Box 310, New Bloomfield, Pennsylvania. And at all times during this period of custody, the maternal grandmother will be present with the Petitioner in that home. 2 ~ 'cc_ _ - . '., ",J ;,." '"~ - <^ T~. 1 Furthermore, that the Petitioner agrees that at no 2 time will any strangers come to the home who are not members 3 of the family while she has that period of custody. 4 Furthermore, that this is a temporary order, and 5 that either Petitioner has the right to go back before the 6 custody conciliator to attempt to modify it or seek more time 7 in the case of the Petitioner. And finally, that neither .8 would disparage the other party in the presence of the 9 children. 10 MR. ANDES: One other point, Your Honor. 11 THE COURT: Certainly. 12 MR. ANDES: During the periods of time that the 13 mother is exercising the temporary custody in the presence of 14 her mother, they will see to it that the children attend 15 regularly any previously scheduled activities. 16 And for the record -- this doesn't have to be in 17 the order. But at this point the activities of which we are 18 aware, the two of the children are involved in cheerleading 19 for midget football games on Saturday afternoons. And my 20 client will be happy to provide information about the times 21 and locations of those games. 22 MR. McKNIGHT: That will be acceptable to us, and 23 it is understood that after the 13th this period of visitation 24 will be every other weekend alternatively. 25 MR. ANDES: Yes, alternating weekends. 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ,,-. .~~,~ J;; THE COURT: Okay. Thank you. MR. ANDES: Thank you, Your Honor. (Whereupon, the recitation of the agreement concluded. ) 4 "'. ~......b m:..:"i 1 2 CERTIFICATE 3 4 5 I hereby certify that the proceedings are contained 6 fully and accurately in the notes taken by me on the above 7 cause and that this is a correct transcript of the same. 8 9 10 do~1Ad~tM~ rraine K. Troutman, RPR 11 12 13 14 15 The foregoing record of the proceedings on the hearing 16 of the within matter is hereby approved and directed to be 17 filed. 18 19 20 ():Jeb'" (()1:44 Date 21 22 23 24 25 J. District 5 ,. -~, VERIFICATION The foregoing Petition for Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: November 27, 2001 . ,-~" " '"~, "=<">~=~--'^,,' -"" ~ ",,',~;; VERIFICATION The foregoing Petition for Special Relief is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this docwnent and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: November 27,2001 b,", , ~", ~. "'" ,,,' . '<--' ".. - 0 c) (J C 'T} ~ ~"''"' ~ L:'r.:- '';'J 2J ~ LrJ C~. .,,".~ .,-J'G ~ ""-- --~ ,'-, $ ~;;,S::' -, ...~~~ \., ~(s -l.'J :~~~) ~ - l;'o ;r.,O :31: ~ ..... ~ '~r~, c5rn '" -<. ~:c: c- - g o-l ~ Z :::> S'j =< (:J -< -,-., J: " -'~ ,"'.'~' ~~.. "..' . > """" ... ~-- ," "'" . JOHN CHRISTOPHER, III, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 00-6047 CIVIL ACTION LAW REBEKAH S. CHRISTOPHER, Defendant IN CUSTODY ORDER OF COURT AND NOW, this '3c.' day of . ~.1/Jf. '1 , 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated October 9, 2001 shall continue in effect as modified by this Order. 2. Beginning on February 1,2002, the Mother's alternating weekend periods of custody shall be expanded to nm from Friday at 6:00 p.m. through Sunday at 5:00 p.m. 3. Until such time as the requirement of supervision is terminated pursuant to the terms of this Order, the Mother's periods of custody may be supervised by either the materual grandmother, Matjorie Grove, or her husband, Ralph Grove. 4. The requirement that the Mother's periods of custody be supervised at all times shall continue in effect until such time as (1) The Mother has been sentenced on current charges, and (2) Written verification has been obtained from the United States Attorney's Office confirming that the Mother's cooperation in the homicide investigation and the Mother's testimony are complete. 5. Upon satisfaction of the requirements in the preceding provision of this Order, the requirement of supervision during the Mother's periods of custody shall terminate. However, the Mother shall not take the Children to Dauphin County or expose the Children, in any way, to the presence of drug users, drug traffickers or criminal activity. BY THE COURT, cc~uel L. Andes, Esquire ~arcus A. McKnight, III, Esquire ) 19 J [apWv ~ 01-30-021 ~'X-9 1] I I I ,I II I' I 'I I 1 I[ " Ii " Ii Ii il_ II. I' I, I'i I"~ ~~ . ~ - ;'~ '<--^. ~--, -, ~-~, , " - .~. , .- ~, .. f"'-"-~" ~, ~- , "' ..". Cf-!-E-O--OFFICE OF T,eT ,-" iT/-:rJNOTJlRY 02 .j,qi'{ 30 PM J::W CI '''cr--" !' i'-'~,_,U' ~I UlViu-t:f'1t...r'Y' W...I L~..) r~ i i PENNSYLVANIA lll~nk._,.,~ !!l!ill~I!i[~-W:_o ~~, ~,_F,*~ -- . ~~,' ~-- ^," ,-" . . ":; JOHN CHRISTOPHER, III, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 00-6047 CIVIL ACTION LAW REBEKAH S. CHRISTOPHER, Defendant IN CUSTODY PRIOR JUDGE: Kevin A. Hess 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 Children who are the subjects of this litigation is as follows: CURRENTLY IN CUSTODY OF NAME DATE OF BIRTH Alexandria Christopher Adrienne Christopher John Christopher, IV July 26, 1995 November 26,1996 November 24,1997 Father F !!ther Father 2. A Conciliation Conference was held on January 15, 2002, with the following individuals in attendance: The Father, John Christopher, III, with his counsel, Samuel L. Andes, Esquire, and the Mother, Rebekah S. Christopher, with her counsel, Marcus A. McKnight, III, Esquire. Date 3. The parties agreed to entry of an Order in the form as attached. Da~ Custody Conciliator , J.Yt\, , 00 lIB ;Hy)~ f