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HomeMy WebLinkAbout00-06074 l~= ~~ OCT 1 9 ~ JOHN REEDER and PAM REEDER, Plaintiff . . IN THE OOURT OF COMMON PLEAS OF CUMBERLAND OOUNTY, PENNSYLVANIA : . . vs. : NO. 00-6074 CIVIL TERM . . : CIVIL AcrION - LAW AMY OOY: and SAM ROCK, Defendant : : IN CUSTODY ORDER OF OOORT AND~, this lOth day of October, 2000, the Conciliator, at the request of Plaintiff's counsel, hereby relinquishes jurisdiction in this case. FOR THE OOURT, M.~~_ Dawn S. Sunday, Esquire CUstody Conciliator ~~1O;1-Wl~:@'1~iJ..d\!;~~~J~!bI_~~~~:ilOOI;_:L~tf1rt ~ ,'~" ~~_"""", _, <__,.'<"j' 8 . ^,O?_,. "" .<~"'-" '-~ ~-< ., 8 7- 1:3(_: S;~ ~L 7(- (lJ,'- C::C ~2 z -,J ~. <-, -:::> p~ :~.,) '.~ , ,. (::;, ~ , ,m, 5,J :D -< -j ,- " '< -. ',_,',<'_l'^" " JOHN REEDER and PAM REEDER, husband and wife, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2000-6074 CIVIL vs. CIVIL ACTION - LAW AMY COY and SAM ROCK, Defendants CUSTODY IN RE: CROSS-PETITIONS FOR EMERGENCY RELIEF ORDER AND NOW, this ZO" day of September, 2000, the court declines to make a final ruling with regard to standing in this case and particularly whether the requirement of 23 Pa.C.S.A. 5313(b)(3) has or has not been met. Rather, and in part pursuant to the authority to issue temporary orders as set forth in the foregoing subsection, it is ordered and directed that, pending further proceedings, primary legal and physical custody of their child, Pierson Robert Rock, is awarded to Amy A. Coy and Samuel E. Rock, Jr. A condition of this order is that Samuel Rock continue his current course of alcohol treatment and refrain from the consumption of alcohol. BY THE COURT, Karl Rominger, Esquire For the Plaintiffs -A4 Family Law Cline For the Defendants :rlm ~? .~1 I ! - ~ _",_ ," ,,"u_~, '" ? r' ..., -TeE t"lU:U-Uh I ' (~.,rl' "c'("',T,,'r'J"'OTADY ~ ' ,1;,_ 'j ,l 1 ~ It \II GO SEP 2 j Al1 1: 58 CUlVI8EF!Lr'J\iD COUNTY PENNSYLVliNIA -; .1,_ , . - - -'.... , ~~"~~ --., ., "~'--~-"~'~=~~'~-~ -~-" ."~ ~._~ ~ ~, ,_;3F_'lI~~'~Ul'ItNl'@!;,,",,!,,,"'1',,,",,~~ < ,~,. """~ ~"""r-~k-L-~_~ '~2Ii" - '~ - 6.."" '" JOHN REEDER and PAM REEDER, Plaintiffs/Respondents : IN THE COURT ~'tbri~EAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2000-6074 AMY A. COY and SAMUEL E. ROCK, JR. DefendantsIPetitioners :CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this I qr:i/J day of ~iP~ jt..., 2000, upon consideration of the attached Petition for Special Relief, it is hereby Ordered as follows: 1. TBe IkfcfldimtS/-PetitivlllOI>, Amy A. coy and :samuel J::\. R.ock, Jr., shall have:: 0.ysie-aL.. .c.ll<tn<1y Qfthek child, Piel'O:gll. Rgbert R-eek, born Apd125, 2000. 2. Pl"':""'liffs'K-esflOnGlrl.ll5 shall retlllll PiersonRoterl Rock to Defendants/.Petitienocs immediately. 3. Thg gWllbc;r]-..IllIl C:udJ.Pj ~lu",riff"vl11 ~P1"tTe this 01=r:t~r -;R Plailltifrf.,/R,-,"pvuJ",.utJ anr eff@etu~~ tho - ~lM1J.\..JiaK lelulll of P~"'l;:).,)U. Rub"'l\. 1.'.u...k tU Delendanls;Pt:ddullta~. 4. A hearing regarding this Petition for Special Relief is hereby scheduled for the ,x.~'-c& day of df1ihnLw4. ,2000 at /I,' 3 () o'clock AM in Courtroom Number --Jf-, Cumberland County Courthouse, Carlisle, Pennsylvania 17013, at which the time the parties, along with their legal counsel, shall appear in person. BY THE COURT, J. ,- "'''("~'1~~1':"~'''.''J1k11;- ............ 1- ".-'hi<....~~~,.1 ~~~'ll!~~ <?c.py 'll'~-J-O );rh( (y L.~,-<-> eOf:Jy m~Js:~( tW-yi1n,('7'~ >~. -" ^" ~". ~- "'~. ". _ =''',~7'' "",,, , ~"-",~ .,," -"-, -"-" ..'...' ~ ~Jitl!' , .], "_'II: '. "~ 'VIMl/\1ASNN3d IJ.Nnoo Gi\r,il1f18fW10 fit::~ [>lei 61 dJS 01] i\.tNIC";",'" r, , , ", ,. j</:...,'I"'_!-I....<:,(: :,',;(1'1.10 ""1' I" rn>i:j' -- ::Jv.:r;'t./'"\.!::JI_ ?', . ,,~ ~- y", .~ ..,~ ,"- , " '"\ \. ('" ~ .i--- L f . -. " .' , "O~ ......~,'",_ JOHN REEDER and PAM REEDER, Plaintiffs/Respondents : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2000-6074 <::> o ~ ::.~ " AMY A. COY and SAMUEL E. ROCK, JR. Defendants/Petitioners o c :s:: ~("- . w~ :CIVIL ACTION - LA W CUSTOD~cB (f) r~, . ~Z . ~o >'0 zc, >c: .~ U) ,"T1 -0 .-" -1:) .....,,.. ~ :::3 'r- ., ~Jg -,:~ , <~~~ s~2(~ oti'n --; U1 d!" to ..~ 't? \.D PETITION FOR SPECIAL RELIEF UNDER RULE 1915.13 OF THE PENNSYL VANIA RULES OF CIVIL PROCEDURE AND NOW, this 19th day of September, 2000, pursuant to Rule 1915.13 of the Pennsylvania Rules of Civil Procedures, come the Defendants/Petitioners, Amy A. Coy and Samuel E. Rock, Jr., by and through their attorneys, the Family Law Clinic, seeking sole physical custody of Pierson Robert Rock and an emergency hearing. Petitioners state the following in support of their Petition for Special Relief: 1. Petitioners are Amy A. Coy and Samuel E. Rock, Jr., who reside at 534 Warm Spring Road, Apartment No.1, Chambersburg, Franklin County, Pennsylvania, 17201. 2. Respondents are John and Pam Reeder, who reside at 25 East Main Street, Walnut Bottom, Cumberland County, Pennsylvania 17266. 3. Petitioners are the biological parents of Pierson Robert Rock, a five-month-old baby boy, bom April 25, 2000. 4. Respondent, Pam Reeder, is the maternal grandmother of Pierson Robert Rock. Respondent, John Reeder, is not biologically related to Pierson. -- .~ '''.~ 5. Petitioners have been the primary caregivers for the child, having done the majority of the feeding, bathing, dressing and nurturing of the child since birth. 6. Pierson Rock has resided with Petitioners, Amy A. Coy and Samuel E. Rock, Jr., since birth, at 534 Warm Spring Road, Apartment No.1, Chambersburg, Franklin County, Pennsylvania, 17201. 7. On September 5, 2000, Respondents filed a Complaint for Custody and Petition for Special Relief. 8. On September 8, 2000, in an ex parte proceeding, without giving Arny A. Coy and Samuel E. Rock, Jr. an opportunity to be heard, an Order of Court was entered granting Respondents temporary custody of Pierson Rock. A copy of the September 8, 2000 Order is attached as Exhibit A. 9. Petitioner Amy A. Coy has seen Pierson Rock only once, under supervision, since September 8, 2000. Petitioner Samuel E. Rock, Jr. has not seen Pierson Rock since September 8, 2000. 10. Amy A. Coy and Samuel E. Rock, Jr. wish to be reconciled with their baby, Pierson Rock. 11. The best interests and permanent welfare of Pierson Rock will be served by returning him to his parents, Amy A. Coy and Samuel E. Rock, Jr., because: a. Petitioners, Amy A. Coy and Samuel E. Rock, Jr., have been the primary caregivers for Pierson Rock since birth; b. Pierson Rock, who is only five months old, needs the care and nurture of his parents, with whom he has lived since birth; c. Petitioners, Amy A. Coy and Samuel E. Rock, Jr., desire to keep their -.,--<~ ~"''""I!:JIllii,; family intact and provide stability for Pierson Rock, which is very important to Pierson's growth and development. d. Pam and John Reeder do not have standing to bring an action for custody of Pierson Rock under 23 PaC.SA g 5311-5313. e. Granting temporary custody to Pam and John Reeder interferes with the parent-child relationship and is not in the best interests of Pierson Rock. WHEREFORE Defendants/Petitioners request the court to return the child immediately to his parents, Amy A. Coy and Samuel E. Rock, Jr., and to grant an emergency hearing in this matter. September 19, 2000 R~;;;ld;~ mil Melinda A. Davis Certified Legal Intem '---:; '" ~~US THOMAS M. PLACE TERI 1. HENNING Supervising Attorneys Family Law Clinic 45 North Pitt St. Carlisle, PA 17013 (717)243-2968 , ~ ~ _L_', VERIFICATION I verifY that the statements made in the foregoing Petition for Special Relief are true and correct, to the best of my knowledge, information and belief. I understand that making any false statement would subject me to the penalties of 18 PaC.S. !}4904, relating to unsworn falsification to authorities, Date: 9/ J'{ Ido I I .~J~~L Sam Rock / "lIi1l_~ .... - "'""(--. -~ ~ ~"' .~"", .' JOHN REEDER AND PAM REEDER, husband and wife, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 0tXD- (PO 71/ AMY COY and SAM ROCK, Defendants CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this f.Ll.... day of Q~,.... Lm _ . 2000, upon consideration of Plaintiffs' Petition for Emergency Reliet; it is hereby ordered and decreed that temporary primary physical custody of the parties' minor grandchild, Pierson Robert ~ck, DOB 4/25/00, shall be GOI.X.r'lJ ';J.-J.,CAJ 'a,&X.L/1VL -1-~ ~ with grandparents pending lteeriag sSRoEiltlee fer lRI _ g~' sf . at ---=-- e'elesl[ is CS1:IftfS6Rt Me. ~ C~JJ",~l~ CuwuL) eUWdlUu:.~ C:Q.ll;~d~ F"uu~JI;ania BY THE COURT: /~/ ~A~;" /0.. ;jj1A-A ..J , . I Karl E. Rominger, Esquire for the Plaintiff Amy Coy, Defendant Sam Rock, Defendant TRUE COpy FROM RECORD In Testlmonywhereof.1 hilreuntDSltmy hind ~~~~~PL '-- :ibit ~ ~ ~ ~,;~ ~""_.' . rv - '. ,- . ~-- I.Il; ':'f:,'i'_, JOHN REEDER AND PAM REEDER PLAINTIFF V. AMY COY AND SAM ROCK DEFENDANT IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 00-6074 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 15tb day of September ,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,Mecbanicsburg,PA 17055 on the ~ day of October ,2000, at 11:00 a.m. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to defme and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: Isl 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 TIllS PAPER TO YOUR ATIORNEY AT ONCE. IF YOU DO NOT HA VB AN ATIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTIl BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 - .____'.. '.___W'_'M<_" ~, " ~.. ',;_. ,0." ,-~" --, ,-", --",',<,'" -' - . -. ">1",' ',; wc- -'" ''; ""-". ,"_.,0 .. -t ,,-' ~k ' -~ -- ., .~. -"_", c.-. -- -" " ,.','" -\1""1") "".-nl"--r: \-",\_l~L~vr!"ivt:.. , ('F -, j"" 1"". '{''\TU''''J~':!''''JI'AR'' j \''':'' ,-';",_.,:;;1;._'\:'-, ,\ I 00 SEP I 9 P;'1 3: I 0 CUMBERL4~D COUNTY P"'c:NNSYLVANIA 9'/f-tJtJ tV- ~~ 7J;4~ ~~ 7Z~~ ~~~4~;} ?!-/{.oo tf -It) ,ttJ tJ i I I I I i i ,J " I' II , ~~_l"" _,~~~~l__^ ~~~;W~IS.~"9'l~?!I'lJiW%mliil~l!'l~J,!\jIi~",,,,,,~~ 'I~:' "'-"_"!~~; .-- " , '-':"- " ,,', ,,:C/,-, ,,~,,: ~-"". -,;" _ --~ "' _ - - _" .;,," -, ':., .- '~ - . -"'-~3i .:/0'-"" ""tJ JOHN REEDER AND PAM REEDER, husband and wife, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA No. t2..600 -(P()7V AMY COY and SAM ROCK, Defendants CIVIL ACTION - LAW ORDER OF COURT AND NOW, , 20--, upon consideration of the attached Petition to Modif'y Custody, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at on the day of , 2000----, at o'clock, _.m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE TIDS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Office of the Court Administrator Cumberland County Court House, Fourth Floor Carlisle, P A 17013 (717) 240-6200 ,I" ' ~ '-'-,- -. "+, "'"'' ,,,,,-,,,'';''-'_,J "J>-,. '" 'i-v-;!,:",. _"~"~'_-''-'_;'_'''';:'. _"'~ '\;,'_'_. 1&, JOHN REEDER AND PAM REEDER, husband and wife, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA No. tKJ. {'O'7Y ~ r.u.- AMY COY and SAM ROCK, Defendants CIVIL ACTION - LAW CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiffs, John Reeder and Pam Reeder, by and through their attorney, Karl E. Rominger, Esquire, and avers the following in support of this Complaint for Custody: 1. The plaintiffs are John Reeder and Pam Reeder, residing at 25 East Main Street, Walnut Bottom, Cumberland County, PA 17266. 2. The defendant is Amy Coy, residing at 25 East Main Street, Walnut Bottom, Cumberland County, P A 17266. The second defendant is Sam Rock, residing at 534 Warm Spring Road, Apartment No.1, Chambersburg, Franklin County, Pennsylvania. 3. Plaintiff seeks custody of the following chilg: Name Pierson Robert Rock Present Residence 25 East Main Street Walnut Bottom, P A 17266 Age 4 months The child was born out of wedlock The child is presently in the custody of Amy Coy, who resides at 25 East Main Street, Walnut Bottom, P A 17266. - ,- " -, 'c',o-- "" ,;'.,;, ~,"~--c: C' '<~'~.-.;';,j",,,, ",~ ,_ ,. , :i~-, During the past five years, the child has resided with the following persons and at the following addresses: Names Amy Coy John Reeder Pam Reeder Sam Rock All Addresses 25 East Main Street Walnut Bottom, P A 17266 Dates Apri125,2000 through present 534 Warm Spring Rd, Apt 1 Apri125,2000 Chambersburg, PA 17201 through 8/27/00 The child is four (4) months old, having been born on April 25, 2000 and has resided with John and Pam Reeder (maternal grandparents) at 25 East Main Street, Walnut Bottom, PA for from three (3) to five (5) days per week since birth. When not at this address, the child was with Amy Coy and Sam Rock at 534 Warm Spring Road, Apartment No.1, Chambersburg, PA, until approximately August 27th, 2000, when defendant Amy Coy moved to 25 East Main Street, Walnut Bottom, PA, with the child. The mother ofthe child is Amy Coy, currently residing at 25 East Main Street, Walnut Bottom, P A 17266. She is single. The father of the child is Sam Rock, currently residing at 534 Warm Spring Road, Apartment No.1, Chambersburg, PA 17201. He is single. 5. The relationship of plaintiff to the child is that of maternal grandparents. The plaintiffs currently resides with the following persons. ". ; '" .' ," '""~:':'~Eo! ,,' 0' .,[<~' ';~.'"., ';ii '_d"';', ;,:,. ,..~:'~Q",..:".,;;;S '.';:;/.:" . Name Amy Coy Pierson Robert Rock Relationship Daughter Grandson 6. The relationship of the frrst defendant to the child is that of mother. 10. The defendant currently resides with the following persons. Name John and Pam Reeder Relationshi\> Parents 11. The relationship of the second defendant to the child is that off ather. 12. The second defendant currently resides with the following person: Unknown 11. Plaintiffs have not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 12. Plaintiffs have no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 13. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. 14. The best interest and permanent welfare of the child will be served by granting the relief request because (set forth facts showing that the granting of the relief requested will be in the best interest and permanent welfare of the child): a) Plaintiff has undertaken and performed the primary parental responsibilities for the child; and, b) Plaintiff is best able to provide the care and nurture which the child needs i'"~~~~ ,...., .. "'-- '.':"';~""h , "",,,,,,"',, ",. . . for healthy development; and C) Plaintiff desires to maintain the family household which has been established, and the continued stability of the household is in the best interest of the child. d) Plaintiff continues to maintain the same family household for the child that has been maintained since birth. The defendant Rock never lived at 2S East Main Street, Walnut Bottom, P A. e) Defendant Sam Rock's erratic and abusive behavior to the mother poses a threat of harm to the children. f) Defendant Sam Rock frequently abuses alcohol and is therefore unreliable as custodian of the children. g) Currently there are charges pending before District Justice Carter in Franklin County against the father for underage drinking, simple assault, drug paraphernalia and harassment, the simple assault and harassment charges being brought for strangling and beating the defendant mother, Amy Coy. h) Defendant Amy Coy has indicated a desire to reconcile and move in with defendant Sam Rock. i) Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. , ',,,, '. -, - '~'-' -- ~-- .."",--.~;"; j;';~-'v"'_'"i> ',,--~- .o;,,,l',_ ;:.._,;".,,-; ~--" -.0"';-"':;:'"0<;;;;' '",,",C...,;,o' ';,'-' ~ '';'1_: WHEREFORE, plaintiffs requests the court to grant custody of the child, with supervised visitation of the natural parents. Respectfully submitted, ? "- ------ Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, P A 17013 (717) 241-6070 Supreme Court ill # 81924 Attorney for John & Pam Reeder Dated: September 5, 2000 >. " _fl_' "" ,___~'"",-, ._~~.-,;';-;-:,~j,,~,i-4" C-,,,-C'~'.:.-i "ill., JOHN REEDER AND PAM REEDER, husband and wife, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA No. AMY COY and SAM ROCK, Defendants CIVIL ACTION - LAW CUSTODY VERIFICATION I verif'y that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. ~ 4904 relating to unsworn falsification to authorities. Dated: ?-6-~ DH6.5.00 -" , ", <,<, ..-.~_._'" ,0,' ','." --",-; ;~, ,.-,,c_ -,~,"'" _~ ",":~ __i .'_o'.~ '-,-"c.-"?-_n t"~ JOHN REEDER AND PAM REEDER, husband and wife, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA No. JOOO - &,Otl( AMY COy and SAM ROCK, Defendants CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this r;'" d f ~ ayo ~"'e-..q , 2000, upon consideration of Plaintiffs' Petition for Emergency Relief, it is hereby ordered and decreed that temporary primary physical custody of the parties' minor grandchild, Pierson Robert Rock, DOB 4/25/00, shall be C#vtet7/~';" ....,,/,.. 6.~ "...w' with grandparents pending kellFieg i'("h\,.-lnl...-l fAr th~ _!lay sf , :lQgO at B'gleek ia CSllRrggQ1 }:Is. -' Cyfnbedmul CetJHty Ctnwthstltlti, Cftdiale, Peftfi9YF:ania. - BY THE COURT: /1/L J. KarlE.R~mi.nger,Esquire - Cof/~ 'j:)~~L1y G,b~ for the Plamtlff , 9/P lca (.'~., ..-. Amy Coy, Defendant Sam Rock, Defendant ;>~/~ rnatLuL 9/P/oO ~ o ~ -0 !,:..,- cn:~~, L.~-: ' /-'-- ((~ "'-',: ~~=-; ~\;-~";: ~c: ?~ ....; -<. ',~ "':1 '--J cc ."'; ;') ;:::-i ::> (p ,.' .:..I'J -< ~~ . ~ ~. - ." ,,~'~"''-~ ~'-""", '~"''''- "!I!I~ . ,. JOHN REEDER AND PAM REEDER, husband and wife, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA No. p.o. (.0'7 Y Cu;;t ~ AMY COY and SAM ROCK, Defendants CIVIL ACTION - LAW CUSTODY PETITION FOR EMERGENCY RELIEF AND NOW, comes the Plaintiffs, John Reeder and Pam Reeder, by and through their attorney, Karl E. Rominger, Esquire, and avers the following in support ofthis Petition for Emergency Relief 1. The plaintiffs are John Reeder and Pam Reeder, residing at 2S East Main Street, Walnut Bottom, Cumberland County, PA 17266. 2. The defendant is Amy Coy, residing at 25 East Main Street, Walnut Bottom, Cumberland County, P A 17266. The second defendant is Sam Rock, residing at 534 Warms Spring Road, Apartment No.1, Chambersburg, Franklin County, Pennsylvania. 3. Plaintiff seeks custody of the following child: Name Pierson Robert Rock Present Residence 25 East Main Street Walnut Bottom, P A 17266 Age 4 months The child was born out of wedlock The child is presently in the custody of Amy Coy, who resides at 25 East Main Street, Walnut Bottom, PA 17266. ~" "'" --"" ,~,N_~.,_.-, "",;1',~,,""k;;;"',._'^,,' ''';.' " ' . I During the past five years, the child has resided with the following persons and at the following addresses: Names Amy Coy John Reeder Pam Reeder Sam Rock All Addresses 25 East Main Street Walnut Bottom, P A 17266 Dates April 25, 2000 through present 534 Warm Spring Rd, Apt 1 April 25, 2000 Chambersburg, P A. 17201 The child is four (4) months old, having been born on April 25, 2000 and has resided with John and Pam Reeder (maternal grandparents) at 25 East Main Street, Walnut Bottom, PA for from three (3) to five (5) days per week since birth. When not at this address, the child was with Amy Coy and Sam Rock at 534 Warm Spring Road, Apt. No I, Chambersburg, PA, until approximately August 27,2000, when defendant Amy Coy moved to 25 East Main Street, Walnut Bottom, P A, with the child. The mother of the child is Amy Coy, currently residing at 25 East Main Street, Walnut Bottom, PA 17266. She is single. The father of the child is Sam Rock, currently residing at S34 Warm Springs Road, Apartment No.1, Chambersburg, P A. He is single. 3. The relationship of plaintiff to the child is that of maternal grandparents. The plaintiffs currently resides with the following persons. - ,~~.., .-~-" -"" "--),,,',' ,,- ,~~"b"bi_ -_,;,,", "'''_ """j . ,. Name Amy Coy Pierson Robert Rock Relationshio Daughter Grandson 4. The relationship of the first defendant to the child is that of mother. 10. The first defendant currently resides with the following persons. Name John and Pam Reeder Relationshio Parents 11. The relationship of the second defendant to the child is that off ather. 12. The second defendant currently resides with the following person: Unknown. 11. Plaintiffs have not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 12. Plaintiffs have no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 13 . Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. 14. The best interest and permanent welfare of the child will be served by granting the relief request because (set forth facts showing that the granting of the relief requested will be in the best interest and permanent welfare of the child): a) Plaintiff has undertaken and performed the primary parental responsibilities for the child; and, b) Plaintiff is best able to provide the care and nurture which the child needs for healthy development; and ~, " ~',.-",-,',,-"~..'~ :~,L';'i ""_"-""'.0"''-' o,'"C';;)'"" ~< ,>..;; _ ~, .' c) Plaintiff desires to maintain the family household which has been established, and the continued stability ofthe household is in the best interest of the child. d) Plaintiff continues to maintain the same family household for the child that has been maintained since birth. The defendant Rock never lived at 25 East Main Street, Walnut Bottom, P A. e) Defendant Sam Rock's erratic and abusive behavior to the mother poses a threat of harm to the children. f) Defendant Sam Rock frequently abuses alcohol and is therefore unreliable as custodian of the children. g) Currently there are charges pending before District Justice Carter in Franklin County against the father for underage drinking, simple assault, drug paraphernalia and harassment, the simple assault and harassment charges being brought for strangling and beating the defendant mother, Amy Coy. h) Defendant Amy Coy has indicated a desire to reconcile and move in with defendant Sam Rock. i) Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. ,-- ,- -~ .0-., " " -, ~ '.~ ',-C-, ""'< ,,- . , -,..._,"',;,,+,-- ',.- -ia\o; .. WHEREFORE, plaintiffs requests the court to grant custody of the child, with supervised visitation of the natural parents. Respectfully submitted, '~7~~ Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ill # 81924 Attorney for John & Pam Reeder ~ Dated: September 5, 2000 . ,~, ,-,",'- ..",' -'-'00" _'-~"",,'""<h~ ';,,,," ;;,~. , ,'~ .... " I> .~ JOHN REEDER AND PAM REEDER, husband and wife, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA No. AMY COY and SAM ROCK, Defendants CIVIL ACTION - LAW CUSTODY VERIFICATION I verif'y that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. 9 4904 relating to unsworn falsification to authorities. JOhn~~ 0(J~~ _ Pam Reeder, P 'ntiff Dated: 9-s -,rO DH6.5.00 H ~ .", ,', ., '"""';;"'--.' '~','" ~" ~"'.,L""!",, " 2__!- .J:",,,,,",' ." ~, JOHN REEDER AND PAM REEDER, husband and wife, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA No. /)cJco-(,,(q~ clv;j AMY COY and SAM ROCK, Defendants CIVIL ACTION - LAW CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTHOFPENNSYLVANIA ) COUNTY OF CUMBERLAND ) I Aaron D. Rossiter, hereby swear that I have served true copies of the Petition for Emergency Relief and the Complaint for Custody, executed by the Plaintiffs in the above- captioned matter, with a Court Order granting temporary physical custody of the parties' minor grandchild in the Plaintiffs and a Court Order directing that the parties and their respective counsel appear before the conciliator for a Pre-Hearing Custody Complaint, upon the Defendants by personal service September 6, 2000, at approximately I :00 P.M. by handing separate copies to each Defendant identif'ying themselves as Sam Rock and Amy Coy, at Sam Rock's parents' residence at 3548 Orrstown Road, Orrstown, Franklin County, Pennsylvania 17247. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating unsworn falsification to authorities. Dated: 1'- b - j. 0 d 0 By:~b~~ Aaron D. Rossiter o' _,L,:: ~,~" "?,__,~.~,"_,_,, ,"" ' c', _r"""_" ""~,_ w.......'\Ii.~ _<" 0 ,;,....""IIiil8Il!tlfj''"'''iiiMe,.'- . ~,,, ,",'^ "-' . . ~ ,c' '.. ~~ . 'TJF;:':' Q)h'~; ~.-- ~i~, ~~~,I ~. Z ::< ,.- f.? ,_. ~ c::::; (.~") ':'1') """1 o (". '.' ::?i.. _.~ - - ,'V ,~~..-- ~ '" , -- \! i I I I -". ..- .".... ~ --~; 5J -( ,;: 1 '''r JOHN REEDER AND PAM REEDER, husband and wife, AUG 2 0 2~/1 " . : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. : NO. 00.6074 AMY COY AND SAM ROCK, Defendants : CNIL ACTION - LAW : CUSTODY RULE TO SHOW CAUSE AND NOW, this 2 z ~ day of ~..v ,2001, upon consideration of the Petition for Leave to Withdraw filed by the Family Law Clinic: (1) A rule is issued upon the Plaintiffs, John Reeder and Pam Reeder, and Defendants, Amy Coy and Sam Rock, to show cause why the Family Law Clinic should not be granted leave to withdraw as counsel of record. (2) Any party desiring to file an answer to the Petition for Leave to Withdraw must do so within twenty (20) days of service of this Rule to Show Cause. (3) Notice of the entry of this order shall be provided to all parties by the Family law Clinic. BY THE COURT: 1. ~ ~ a.~-OIfI(~s I . , "" .. ,,,"eo;. .,.. ........ ' .. w ~ ,- . ~ ~ ,>, - " '>>"""'." '= ,"'-~"= 'L"..c", ""0. _.. CTi'D,:-"F-;t:/:: , ", ,",. '\'OTlii9Y '7J t"i; 22 ?: ro,:;: .,. ,.J-... t", !A /:. ~.' .', ,..'., .V"-'''''('!',_I, . " d " ""'Iy "'''''-''t-,-" \".JU'\II FCiVNSYU~t1iJ!A I." .".. '..""-,., ...Y ,.,....... "'7""~ ~ , "ih-.l ~~I"'.,~ ,'[g"".~,,H .-..". . ',~, '. _,,I:':':" ',--,~::, -:--: '.." -' "~'<', ,'" ,,-,'....';; "'-"-" cc: Family Law Clinic Karl E. Rominger, Esq., Counsel for Plaintiffs 155 South Hanover Street Carlisle, P A 17013 Amy Coy, Defendant 25 East Main Street Walnut Bottom, PA 17266 Sam Rock, Defendant 534 Warm Springs Road Apartment 1 Chambers burg, P A 17021 -i.-.... <',_s.:J -~ ' ,,~' ~, ,__,,' C--"C'''' - - .. ", _ _ ~"- ~"~,, "':'"-"j JOHN REEDER AND PAM REEDER, husband and wife, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLV ANlA Plaintiffs v. : NO. 00-6074 AMY COY AND SAM ROCK, Defendants : CML ACTION - LAW : CUSTODY ORDER OF COURT AND NOW, this day of ,2001, upon consideration of the attached Petition for Leave to Withdraw filed by the Family Law Clinic, it is hereby ordered and directed that the Family Law Clinic is permitted to withdraw as counsel for Defendants. BY THE COURT: J. cc: Family Law Clinic Karl E. Rominger, Esq. (Counsel for Plaintiffs) 155 South Hanover Street Carlisle,PA 17013 Amy Coy, Defendant 25 East Main Street Walnut Bottom, P A 17266 Sam Rock, Defendant 534 Warm Springs Road Apartment 1 Chambersburg, P A 17021 , "', .'. ~:. - >,'",;~",d, "~,,,'~"~ ".,,--O~ ,~~ liii JOHN REEDER AND PAM REEDER, husband and wife, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. : NO. 00-6074 AMY COY AND SAM ROCK, Defendants : CIVIL ACTION - LAW : CUSTODY PETITION FOR LEAVE TO WITHDRAW Petitioner, the Family Law Clinic, hereby petitions to withdraw from further representation of Amy Coy (Mother) and Sam Rock (Father) , pursuant to Rules 1.9( a) and 1.16 (a)(3) of the Pennsylvania Rules of Professional Conduct and Pa.R.C.P. 1012, and in support thereof avers the following: 1. On September 5, 2000, Mr. and Mrs. Reeder (Step-Grandfather and Grandmother) filed a Complaint for Custody of Mother and Father's minor child. 2. Also on September 5, 2000, Step-Grandfather and Grandmother filed a Petition for Emergency Relief. 3. On September 8, 2000, upon consideration of the Step-Grandfather's and Grandmother's Petition for Special Relief, this Court granted Step-Grandfather and Grandmother temporary primary physical custody of the minor child pending conciliation and/or further Order of Court. 4. After a hearing on September 20,2000, custody of the minor child was returned to Mother and Father, pending conciliation and/or further Order of Court. 5. At that time, a conciliation was scheduled for October 4, 2000. ~' ,..; ,,' _ ~o. ~ '<._ " ,;,:, ~ ~ ,,,,--,, 6. Step-Grandfather and Grandmother later cancelled the conciliation, and custody of the child remained with Mother and Father. 7. Some time thereafter, Mother informed the Family Law Clinic that Mother and Father had separated, and Mother and child were residing with Step-Grandfather and Grandmother. 8. On July 5, 2001, the Family Law Clinic received a draft custody agreement and order from Step-Grandfather and Grandmother's attorney, Karl Rominger, relating to the minor child. 9. The Family Law Clinic immediately contacted Mother by telephone. 10. Step-Grandfather informed the Family Law Clinic that Mother is now being represented by Karl Rominger as well. 11. On July 6, 2001, The Family Law Clinic sent a letter to Mother and a letter to Father, asking Mother to inform the Clinic if Mr. Rominger was not representing her, explaining to both Mother and Father that the Clinic could not represent them in an action against one another, and asking them both to contact the Clinic if they had any questions, or needed assistance in locating other representation. 12. Neither Mother nor Father has contacted the Clinic. 13. The Family Law Clinic is unable to represent either party in this matter, as such representation would violate Rule 1.9(a) of the Pennsylvania Rules of Professional Responsibility. 14. On August 16,2001, The Family Law Clinic contacted Karl Rominger, Esquire, to ask whether he contests this Petition to Withdraw. Mr. Rominger informed the Family Law Clinic that he does not contest this Petition to Withdraw. e . ". ~" "'.',,iC_<,:-,,_' '~~ WHEREFORE, the Family Law Clinic requests permission to withdraw as counsel for Amy Coy and Sam Rock in this matter. D",~ rz 1!xJ I Respectfully submitted, /JM: laUL ytJ ()AfdtJ M - VMichelle L. Anders~P Certified Legal Intern ~PLA~U ROBERT E. RAINS TERI L. HENNING Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ~'~' c,', 'r__', - . """;';' JOHN REEDER AND PAM REEDER, husband and wife, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. : NO. 00-6074 AMY COY AND SAM ROCK, Defendants : CIVIL ACTION - LAW : CUSTODY CERTIFICATE OF SERVICE I, Michelle L. Anderson, Certified Legal Intern, the Family Law Clinic, hereby certif'y that I am serving a true and correct copy of a Petition for Leave to Withdraw on the following persons by frrst class United States mail, postage prepaid, the 17th day of August, 2001: Amy Coy, Defendant 25 East Main Street Walnut Bottom, P A 17266 Sam Rock, Defendant 534 Warm Springs Road Apartment 1 Chambersburg,PA 17021 Karl E. Rominger, Esq. (Counsel for Plaintiffs) 155 South Hanover Street Carlisle, PA 17013 .~ . W~. dJll)}L ~chelle L. Anders n Certified Legal Intern ~I_ c - ',' "'. " , :1IiiIiiii'"~""'" .,~~ ,~w ", ,., 'C',.--..,... ,,,,."".'.,,j;,. c: :2:"~ cC',~.~ . .' . .. .. . . , ,;:,' " ~ ~.- '"', .. ......h. ..:.... ".. . "lil " n C) ,.-'"" c- . "'" -,: -0-'" ;r" n'IR~;, ;;') :;:} <:' ,./,;, 2F en .;:~ "-.! FSoC C-;:::::'-----, ." ;g.- 4:'.:"- () ;;SO ~.~ >;::. \.~.i <: 5;'1 ~ &:- -< :.:0 -< . "--'''' " ".."," .". , ""'~ ," ,,' ' "~,'; - 'i,'__, ,~,,~,:,-, , "'^' JOHN REEDER AND PAM REEDER, husband and wife, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2000-6074 AMY COY and SAM ROCK, Defendants CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this v'" dayof ~I'~ , 200 I, it is ordered that the within Stipulation and Stipulated Order as to Custody is entered as an Order of Court. STIPULATION AND STIPULATED ORDER AS TO CUSTODY AND NOW, comes John and Pam Reeder by and through their attorney, Karl E. Rominger, Esquire and proposes the following Stipulation which was agreed to by the parties as evidenced by their signatures at the end and requests that the Court enter an Order in conformance with said Stipulations. Said Stipulations being: I. Legal custody will be shared by all of the parties. 2. Primary physical custody of the minor child, Pierson Robert Rock, born April25, 2000 is to be with John and Pam Reeder, the maternal grandparents. 3. The child shall reside with the grandparents at 25 East Main Street, Walnut Bottom, PA 17266. 4. The child's mother, Amy A. Coy, a Defendant to this action resides with said parents, -.. 1_,.- ""I ;~J! cr~ <..Ii_: ""j ij;" lJ Clh\!~~<~;'''.iL;",.,.{" ,>:i .'.\~T\. jJcNt;Jc:y; \!" ;' ;:-,.l_ I .. i { V L.//\i\f/i I ~.,~ - 'm "0'_ , _"",~II!iil,"", . ~~ ",' ,- ] ld- <:> , ". <S- ~",~. -IW .'0" ~"~ _---- ."--~-'>' ,",,"~" """"'".~,,,-,",,C,,-";' "-' __~~--"" ,~C .. ~,,' and so long as she resides at 25 East Main Street, Walnut Bottom, P A 17266, she will have unlimited access to the child. 5. In the event that mother ceases to reside at 25 East Main Street, Walnut Bottom, PA, her periods of visitation will be as agreed to by the parties. 6. The father, Samuel E. Rock, Jr., is to have periods of visitation commencing every Sunday at 12:00 p.m. and ending Monday morning as agreed by the parties. In the event no agreement can be reached, the child shall be returned no later than 2:00 p.m. on Monday. 7. It is agreed that Samuel E. Rock, Jr., shall not have exclusive control over the child, and instead his visits will be supervised by his mother, Connie Rock. In the event that Connie Rock, is not available, Samuel E. Rock, Jr., agrees to notif'y the parties for a rescheduled visitation. 8. Holidays are to be split as decided by the parties, and as agreed, on a holiday by holiday basis. 9. John Reeder and Pam Reeeder the maternal grandparents, agree to foster the relationship with the child with both natural parents. 10. The parties agree to refrain and desist from disparaging comments about any of the other parties in the presence of the child. 11. The parties mutually agree to keep each other informed of any medical appointments, educational needs or opportunities, schooling, and any and all other matters concerning the child. 12. Additional visitation times may be arranged by agreement of the parties. In the absence of my""",",'" -,. th, """' ofth;, """moll f upo;hzm J. -__IiU. JOHN REEDER AND PAM REEDER, husband and wife, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2000-6074 AMY COY and SAM ROCK, Defendants CIVIL ACTION - LAW CUSTODY STIPULATION AND STIPULATED ORDER AS TO CUSTODY AND NOW, comes John and Pam Reeder by and through their attorney, Karl E. Rominger, Esquire and proposes the following Stipulation which was agreed to by the parties as evidenced by their signatures at the end and requests that the Court enter an Order in conformance with said Stipulations. Said Stipulations being: 1. Legal custody will be shared by all of the parties. 2. Primary physical custody of the minor child, Pierson Robert Rock, born April 25, 2000 is to be with John and Pam Reeder, the maternal grandparents. 3. The child shall reside with the grandparents at 25 East Main Street, Walnut Bottom, PA 17266. 4. The child's mother, Amy A. Coy, a Defendant to this action resides with said parents, and so long as she resides at 25 East Main Street, Walnut Bottom, P A 17266, she will have unlimited access to the child. 5. In the event that mother ceases to reside at 25 East Main Street, Walnut Bottom, P A, her periods of visitation will be as agreed to by the parties. 6. The father, Samuel E. Rock, Jr., is to have periods of visitation commencing every 1 .'- ..," -'- - J' "h', Sunday at 12:00 p.m. and ending Monday morning as agreed by the parties. In the event no agreement can be reached, the child shall be returned no later than 2:00 p.m. on Monday. 7. It is agreed that Samuel E. Rock, Jr., shall not have exclusive control over the child, and instead his visits will be supervised by his mother, Connie Rock. In the event that Connie Rock, is not available, Samuel E. Rock, Jr., agrees to notif'y the parties for a rescheduled visitation. 8. Holidays are to be split as decided by the parties, and as agreed, on a holiday by holiday basis. 9. John Reeder and Pam Reeeder the maternal grandparents, agree to foster the relationship with the child with both natural parents. 10. The parties agree to refrain and desist from disparaging comments about any of the other parties in the presence of the child. 11. The parties mutually agree to keep each other informed of any medical appointments, educational needs or opportunities, schooling, and any and all other matters concerning the child. 12. Additional visitation times may be arranged by agreement of the parties. In the absence of l' any agreement other.wis~,~ terms of this agreement are binding upon the parties. ~P.&O"14 -= 'fJa..- ~ John Reeder Pam Re der \ sO D~, 1j 2 &/ Loll ~({t.iT .I.. ~~~r;.;o;i1<""""",,",!l<_~~~'),.Oi!lb;;~i'I~;ll:i!i*,jllH~,t::1.ltilMJi;\"'''''''''''" ~" '" '~," .,~' -, .'~'" ...............!lliIiIIIi "M(AlllliIlrl -~- " l'- - () L'~P rrl[! -"r, 7=i2-. ~~,. ~&,-. ~(' " ~~l ~ , ('" C _J ,.". ::.-s c..J c:) I:~ I':" ~~~ \:? \..~) ,iJ ::v ~~ f , i 1 t I ! --- ,J.;o j"~ .,.->..\ L''', ", '"o'~ ,"L . "~ "C.::":.__",,,,; "J, '".,.- ;-".- ,'~./'- ,',,' --,- '^<,;" " . , JOHN REEDER AND PAM REEDER, husband and wife, SfP27~ : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLV ANlA Plaintiffs v. : NO. 00-6074 AMY COY AND SAM ROCK, Defendants : CNIL ACTION - LAW : CUSTODY ORDER OF COURT AND NOW, this L day of OcJo b- , 2001, upon presentation and consideration of the within Petition to Make Rule Absolute, the Rille entered by Order on August 23,2001, is hereby made ABSOLUTE and Petitioner, the Family Law Clinic, is permitted to withdraw as counsel for the Defendants, Amy Coy and Sam Rock. BY THE m;i Ilo~, J. aJl ... ..,...."."" .;"''''''" .". .. ...........,"'..,.... ... ,.... ." " ~,.:.'.:~.J.,"" '1' or'l' " U! ,'';,' ~~ ~ ...,',......~,"',....". ",...."..' -.j. /Iii . I .", ~ .of ("'\1 I~ ':;:.,;'::.::"; :''-,: ' ('(;; j,\nry Jl."ibJ1_i......; h...J-', 'i;...i ~''''~''.-'I\, PENNSYLi/;'\NfA ji"'l" '0 , .....,......'"',,' T'"' I I , :' ~, " . ~' --, ,~_ 'd' ~ ~ ,,~, ',_:', _;".;:;; F -to'-,""..'., ,;"";;.,, -',.;""'::r,..o,.2,...i;.>,'J~"""-~-j~.~.",, . "~;""-'W;c JOHN REEDER AND PAM REEDER, husband and wife, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. : NO. 00-6074 AMY COY AND SAM ROCK, Defendants : CIVIL ACTION - LAW : CUSTODY PETITION TO MAKE RULE ABSOLUTE AND NOW, comes petitioner, the Family Law Clinic, and petitions the court as follows: 1. Petitioner, the Family Law Clinic, is counsel of record for the above-named Defendants, Amy Coy and Sam Rock. 2. Petitioner filed a Petition for Leave to Withdraw in this matter on August 17, 2001. On August 23, 2001, this Court issued a Rule to Show Cause why the Family Law Clinic should not be permitted to withdraw. A copy of the Petition and Rule to Show Cause are attached hereto and incorporated herein by reference as Exhibit "A". 3. The August 23,2001 Rule to Show Cause permitted the parties to object to the Family Law Clinic's request to withdraw as counsel for Amy Coy and Sam Rock, within twenty (20) days after service. 4. A true and correct copy of the Petition was served upon Respondent, Amy Coy, by frrst class mail, postage prepaid, at 25 East Main Street, Walnut Bottom, P A 17266 on August 17, 2001. A true and correct copy of the Petition was served upon Respondent, Sam Rock, by fIrst class mail, postage prepaid, at 534 Warm Springs Road, Apartment 1, Chambersburg, PA 17021 on August 17, 2001. A true and correct copy of the Petition was served upon counsel for Plaintiffs on the same date. ;.JJi ,.' ,;".' '" '_"~,<-,-,,, ",i.).' '.I',L:L :"L, - ::",:;',';:," ':~":;l"''<i>'~;;';;':'>~';'' "'';;';~'!' 5. A true and correct copy of the August 23,2001 Rule to Show Cause was served upon Respondent, Amy Coy, by first class mail, postage prepaid, at 25 East Main Street, Walnut Bottom, PA 17266 on August 31,2001. A true and correct copy of the August 23, 2001 Rule to Show Cause was served upon Respondent, Sam Rock, by first class mail, postage prepaid, at 534 Warm Springs Road, Apartment 1, Chambersburg, PA 17021 on August 31, 2001. A true and correct copy of the August 23,2001 Rule to Show Cause was served upon counsel for Plaintiffs on the same date. 6. Twenty (20) days have passed since the Rule was served upon Respondents and Plaintiffs' counsel, and no response or objection has been filed. WHEREFORE, the Family Law Clinic requests this Court to enter an Order permitting it to withdraw as counsel for Amy Coy and Sam Rock in this matter. I verif'y that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904, relating to unsworn falsification to authorities. Date:~.1tJ(2..t?OI I lA. ;) ().. Ai, . AlA ~~Wf'L ~certified Legal Intern.. J _I:c Iv- S M. PLACE ROBERT E. RAINS TERI L. HENNING Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 o -.,,' "~~~ ~ 'm' - '="""''''<:~' "' -%, ~ IIIUF 2 0 20~..,~. 1\ iII\ I Y iJi JOHN REEDER AND PAM REEDER, husband and wife, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. : NO. 00-6074 AMY COY AND SAM ROCK, Defendants : CIVIL ACTION - LAW : CUSTODY RULE TO SHOW CAUSE AND NOW, this ~ day Of~' 2001, upon consideration of the Petition for Leave to Withdraw filed by the Family Law Clinic: (1) A rule is issued upon the Plaintiffs, John Reeder and Pam Reeder, and Defendants, Amy Coy and Sam Rock, to show cause why the Family Law Clinic should not be granted leave to withdraw as counsel of record. (2) Any party desiring to file an answer to the Petition for Leave to Withdraw must do so within twenty (20) days of service of this Rule to Show Cause. (3) Notice of the entry of this order shall be provided to all parties by the Family law Clinic. 1. ;'''~" . " ~ ,~' ,--. ~1:;!-' '! ...: JOHN REEDER AND PAM REEDER, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-6074 AMY COY AND SAM ROCK, Defendants : CIVIL ACTION - LAW : CUSTODY CERTIFICATE OF SERVICE I, Michelle L. Anderson, hereby certify that I am serving a true and correct copy of the Rule to Show Cause on the following persons by depositing a copy of the same in the United States mail, postage prepaid, this 31 ,t day of August, 2001: Karl E. Rominger, Esquire, Counsel for Plaintiffs 155 South Hanover Street Carlisle, PA 17013 Amy Coy, Defendant 25 East Main Street Walnut Bottom, P A 17266 Sam Rock, Defendant 534 Warm Springs Road Apartment 1 Chambersburg, PA 17021 , ~~~ l/ Michelle L. Ande~ Certified Legal Intern F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 - .i_""-- . --~ ~. ".~ .'~. .f .~ cc: Family Law Clinic Karl E. Rominger, Esq., Counsel for Plaintiffs 155 South Hanover Street Carlisle, PA 17013 Amy Coy, Defendant 25 East Main Street Walnut Bottom, PA 17266 Sam Rock, Defendant 534 Wann Springs Road Apartment 1 Chambersburg, PA 17021 101-..0 ~, "\ - -: JOHN REEDER AND PAM REEDER, husband and wife, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. : NO. 00-6074 AMY COY AND SAM ROCK, Defendants : CML ACTION. LAW : CUSTODY ORDER OF COURT AND NOW, this day of ,2001, upon consideration of the attached Petition for Leave to Withdraw filed by the Family Law Clinic, it is hereby ordered and directed that the Family Law Clinic is permitted to withdraw as counsel for Defendants. BY THE COURT: 1. cc: Family Law Clinic Karl E. Rominger, Esq. (Counsel for Plaintiffs) 155 South Hanover Street Carlisle, PA 17013 Amy Coy, Defendant 25 East Main Street Walnut Bottom, PAl 7266 Sam Rock, Defendant 534 Warm Springs Road Apartment 1 Chambersburg, PA 17021 '""IIi ...-. . ~ ., ' - """"",>~",C . " JOHN REEDER AND PAM REEDER, husband and wife, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. : NO. 00-6074 0 n 0 ^'n c: ._-l , ~ -0 (:;j .~:==) rn C" ~ '-:-, -/ ";', - 7 i~";::' , C) ~'~~~', ._1 , ) !..) ~CJ "'"\-") C~~ -.' '!:;C) \'1-' L-Ci r;? ..._~ P'c: --.\ -t'~ ~ ,- <'T-1 ::<: AMY COY AND SAM ROCK, Defendants : CNIL ACTION - LAW : CUSTODY PETITION FOR LEAVE TO WITHDRAW Petitioner, the Family Law Clinic, hereby petitions to withdraw from further representation of Amy Coy (Mother) and Sam Rock (Father) , pursuant to Rules 1.9( a) and 1.16 (a)(3) of the Pennsylvania Rules of Professional Conduct and Pa.R.C.P. 10 12, and in support thereof avers the following: 1. On September 5, 2000, Mr. and Mrs. Reeder (Step-Grandfather and Grandmother) filed a Complaint for Custody of Mother and Father's minor child. 2. Also on September 5, 2000, Step-Grandfather and Grandmother filed a Petition for Emergency Relief. 3. On September 8, 2000, upon consideration of the Step-Grandfather's and Grandmother's Petition for Special Relief, this Court granted Step-Grandfather and Grandmother temporary primary physical custody of the minor child pending conciliation and/or further Order of Court. 4. After a hearing on September 20, 2000, custody of the minor child was returned to Mother and Father, pending conciliation and/or further Order of Court. 5. At that time, a conciliation was scheduled for October 4, 2000. "' ..~ ~ ." . ~ " .'" .~l~, " -!. 6. Step-Grandfather and Grandmother later cancelled the conciliation, and custody of the child remained with Mother and Father. 7. Some time thereafter, Mother informed the Family Law Clinic that Mother and Father had separated, and Mother and child were residing with Step-Grandfather and Grandmother. 8. On July 5, 2001, the Family Law Clinic received a draft custody agreement and order from Step-Grandfather and Grandmother's attomey, Karl Rominger, relating to the minor child. 9. The Family Law Clinic immediately contacted Mother by telephone. 10. Step-Grandfather informed the Family Law Clinic that Mother is now being represented by Karl Rominger as well. 11. On July 6, 2001, The Family Law Clinic sent a letter to Mother and a letter to Father, asking Mother to inform the Clinic if Mr. Rominger was not representing her, explaining to both Mother lIl1d Father that the Clinic could not represent them in an action against one another, and asking them both to contact the Clinic if they had any questions, or needed assistance in locating other representation. 12. Neither Mother nor Father has contacted the Clinic. 13. The Family Law Clinic is unable to represent either party in this matter, as such representation would violate Rule 1.9( a) of the Pennsylvania Rules of Professional Responsibility. 14. On August 16,2001, The Family Law Clinic contacted Karl Rominger, Esquire, to ask whether he contests this Petition to Withdraw. Mr. Rominger informed the Family Law Clinic that he does not contest this Petition to Withdraw. :Iil!~ . , "" .."'... i "' .t I WHEREFORE, the Family Law Clinic requests permission to withdraw as counsel for Amy Coy and Sam Rock in this matter. Dore.~ n,1m I Respectfully submitted, ( 1LU1 irJllL 'CYAfdl AM _ '-/Michelle L. Anderso Certified Legal Intern ~2:.PLA~ Jj ROBERT E. RAINS TERI L. HENNING Supervising Attorneys FAMll., Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 . '. "' ~ ~b"c ~ JOHN REEDER AND PAM REEDER, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-6074 AMY COY AND SAM ROCK, Defendants : CNIL ACTION - LAW : CUSTODY CERTIFICATE OF SERVICE I, Michelle L. Anderson, Certified Legal Intern, the Family Law Clinic, hereby certif'y that I am serving a true and correct copy of a Petition for Leave to Withdraw on the following persons by first class United States mail, postage prepaid, the 17th day of August, 2001: Amy Coy, Defendant 25 East Main Street Walnut Bottom, P A 17266 Sam Rock, Defendant 534 Warm Springs Road Apartment 1 Chambersburg, PA 17021 Karl E. Rominger, Esq. (Counsel for Plaintiffs) 155 South Hanover Street Carlisle, PA 17013 .~ . ~J!Ul1l1./., dMtL- ~i"'cl1' L. ImMEr Certified Legal Intern tii ,'~"'_ ' ,,,-,,,,'O~," . ".' ',' . ~__~;<'-;"':;;C,";'., .;...,~;.; ''',-.',';,' '-~_'~__"':-"S, " " "' ,<",J,~ """ '" " ~___"'';'.'",,; ,- ......., '. .. JOHN REEDER AND PAM REEDER, husband and wife, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. : NO. 00-6074 AMY COY AND SAM ROCK, Defendants : CNILACTION -LAW : CUSTODY CERTIFICATE OF SERVICE I, Michelle L. Anderson, hereby certif'y that I am serving a true and correct copy of the Petition to Make Rille Absolute on the following persons by depositing a copy of the same in the United States Mail, postage prepaid, this 26lh day of September, 2001: Amy Coy 25 East Main Street Walnut Bottom, P A 17266 Sam Rock 534 Warm Springs Road Apartment 1 Chambersburg, PA 17021 Karl E. Rominger, Esquire, Counsel for Plaintiffs 155 South Hanover Street Carlisle, PA 17013 ~cf~ Micheltt(L. Anderson Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ~ <.." ~ ~ !ill.rn~ "'~~.'~ii.1*1Ii ..J ~,l<lij~~_-~ ~"~ - c",'l, ;";'" ~- ~..~ """"""w ~ k_ .~ o c <~" ;:gri..! ~~~~ ~~; ~;@ 2: -, -< ,. iJj ~~~ o. 'I I ~ . , c> C) ~='-1 ':/) -" -.~ " "-~~ <J [".) cr., .-'-, "i-"i :.Fl .l'""" :'> () Or-'ll S :'D -< "