HomeMy WebLinkAbout00-06799
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DAVID L. WRIGHT
PLAINTIFF
V.
KIM L. WRIGHT
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERlAND COUNTY, PENNSYLVANIA
00-6799 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. Sunday, Esq.
at 39 West Main Street, Mechanicsburg, PA 170S5 on Monday, August 20, 2001
, the conciliator,
at 9:30 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,
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. EsqbP
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our office,
All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must
attend the scheduled conference or hearing.
YOU SHOULD TAKE TIllS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE SET
FORTIl BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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DAVID L. WRIGHT
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 00-6799 CIVIL TERM
Vs.
KIM L. WRIGHT
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW THIS _ day of , 2001, 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 , 2001 at_
A.M.lP.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.
BY THE COURT,
BY
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply
with the Americans with Disabilities Act of 1990. For information about accessible
facilities and reasonable accommodations available to disabled individuals having
business before the court, please contact our office. All arrangements must be made at
least 72 hours prior to any hearing or business before the court. You must attend the
scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OF CANNOT AFFORD ONE, GO TO ORTELEPHONE 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
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DAVID L. WRIGHT,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
NO. 00-6799
CIVIL TERM
KIM L. WRIGHT ,
Defendant/Petitioner
IN CUSTODY
PETITION FOR MODIFICATION OF AN
EXISTING CUSTODY ORDER
1) Petitioner is David L. Wright, Plaintiff in this custody action.
2) Since the parties separation the parties have had an equal shared
custody arrangement which was entered by agreement. A copy of the Order
implementing the agreement is attached hereto.
3) In order to facilitate this arrangement the Petitioner relocated his home to
live closer to the home where the Respondent moved with the child.
4) This Order should be modified because: The Petitioner can provide a
more stable and secure home for his daughter that would be in her best interest. The
Respondent has constantly attempted to interfere in the current arrangement and has
made it unworkable.
WHEREFORE, Petitioner through his attorney, Robert L. O'Brien,
Esquire, respectfully requests that the court set a hearing to modify the existing Order
and to grant Petitioner primary custody of Jessica Lynn Wright.
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Respectfully submitted,
O'BRIEN, BARIC & SCHERER
By:' ~~ IV-V--
Robert L. O'Brien, Esquire
1.0. # 28351
17 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
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VERIFICATION
I verify that statements made in the foregoing Petition are true and correct.
understand that false statements herein are made subject to the penalties of 18 PA.
C.S. Section 4904, relating to unsworn falsification to authorities.
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DAVID L. WRIGHT,
Plaintiff
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.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND CCUNTY, PENNSYLVANIA
:
:
vs.
.
.
NO. 00-6799
CIVIL TERM
.
.
KIM L. WRIGHT,
Defendant
:
CIVIL ACTION - LAW
IN CUSTODY
.
.
OODER OF CXXlRT
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upon consideration of the attached
ordered and directed as follows:
AND 1!ilCIi, this
day of ~lIem\e R. , 2000,
Custody conciliation Report, it is
1. The Father, David L. Wright, and the Mother, Kim L. Wright, shall
have shared legal custody of Jessica Lynn Wright, born November 13, 1992.
Each parent shall have an equal right, to be exercised jointly with the
other parent, to make all major non-emergency decisions affecting the
Child's general well-being including, but not limited to, all decisions
regarding her health, education, and religion.
2. Until such time as the Father relocates his residence to the
Middletown area, where the Mother resides, the custody arrangements set
forth in this Court's Order dated October 24, 2000 shall continue in
effect.
3. At such time as the Father relocates his residence to the
Middletown area, the parties shall share having physical custody of the
Child on an alternating weekly basis with the exchange of custody to take
place on Fridays. When the Father is receiving custody of the Child on
Friday, he shall pick up the Child at 6:00 p.m. at the Mother's residence.
When the Mother is receiving custody of the Child on Friday, the Child
shall take-the bus from school to the Mother's residence, as usual.
When the Father has to work during his period of custody and is
unable to provide care for the Child, the Father shall first contact the
Mother to offer her the opportunity to provide care for the Child before
contacting third party caregivers. The parties shall cooperate in
determining whether it is appropriate for the Child to attend certain car
shows and in making arrangements for care of the Child during car shows
when the Father has custody of the Child.
4. The parties shall share or alternate having custOdy of the Child
on holidays as follows:
A. CIIRIS'mAS: The Christmas holidQ.y shall be divided into
Segment A, which shall run from Christmas Eve at 12:00 noon
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through Christmas Day at 12:00 noon, and Segment B, which
shall run from Christmas Day at 12:00 noon through December 26
at 12:00 noon. In even numbered years, the Father shall have
custody of the Child during Segment A and the Mother shall
have custody during Segment B. In odd numbered years, the
Mother shall have custody of the Child during Segment A and
the Father shall have custOdy during Segment B. In every
year, the parties shall equally share having custody of the
Child during the remainder of the Christmas school break.
B. ,THANKSGIVING: In every year, the Father shall have custody of
the Child from the Wednesday before Thanksgiving at 6:00 p.m.
through Thanksgiving Day at 5:00 p.m. and the Mother shall
have custody from Thanksgiving Day at 5:00 p.m. through the
Friday after Thanksgiving at 6:00 p.m.
C. ALTERNATING HOLIDAYS: The Easter holiday shall run from the
,Saturday before Easter at 6:00 p.m. through Easter Sunday at
6:00 p.m. The Memorial Day and Labor Day holidays shall run
from 9:00 a.m. until 9:00 p.m. on the day of the holiday. The
July 4th holiday shall run from 9:00 a.m. until after the
fireworks on July 4th. In even numbered years, the Mother
shall have custody of the Child over the Memorial Day and
Labor Day holidays and the Father shall have custody over
Easter and July 4th. In odd numbered years, the Father shall
have custody of the Child on the Memorial Day and Labor Day
holidays and the Mother shall ,have custody on Easter and July
4th.
D. MOl'HER'S DAY/FATBER'S DAY: In every year, the Mother shall
have custody of the Child from 9:00 a.m. until 9:00 p.m. on
Mother's Day and the Father shall have custody from 9:00 a.m.
until 9:00 p.m. on Father's Day.
E. PARENTS' BIRTBIlAYS: Each party shall be entitled to have a
period of custody with the Child on that parent's birthday at
times to be arranged by agreement of the parties.
.
F. The holiday custody schedule shall supersede and take
- precedence over the regular custody schedule.
5. Each party shall advise the other party of his or her current
address and telephone number on an ongoing basis.
6. In the event either party intends to remove the Child from his or
her residence for an overnight period or longer, that party shall provide
the other party with advance notice of an address and telephone number
where the Child can be contacted.
7. Neither party shall co or say anything which may estrange the
Child from the other parent, injure the opinion of the Child as to the
other parent, or hamper the free and natural development of the Child's
love and respect for the other parent. Both parties shall take all
reasonable steps to ensure that third parties having contact with the Child
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comply with this provision.
8. 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,
/s/ JI H~ d. -tlJ\/\ J
Kevi~ess, - J.
cc: Robert L. O'Brien, Esquire - Counsel for Father
Joan Carey, Esquire - COunsel for Mother
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TRUE COpy FROM RECORD
In Testimony whereof, I here unto set my hnnd
and the,seaJ {If sai Court ~i t rli~le, Pa.
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, DAVID L. WRIGHT, . IN THE COURT OF COMMON PLEAS OF
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Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
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vs. . NO. 00-6799 CIVIL TERM
.
.
.
KIM L. WRIGHT, . CIVIL ACTION - LAW
.
Defendant . IN CUSTODY
.
PRICR JUDGE: Kevin A. Bess,
CUS'lOOY cx:6CILIATICI'I SUMMARY REPCRI.'
IN ACXXm>ANCE WITH CDMBBRLAND CXXlN'lY RULE OF CIVIL PR.OCEOORE
1915.3-8, the undersigned Custody COnciliator submits the following report:
1. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
NAME
DATE OF BIRTH
CURRENrLY IN CUS-~UJY OF
Jessica Lynn wright
November 13, 1992
Mother
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2. A COnciliation Conference' was held on November 1, 2000, with the
following individuals in attendance: The Father, David L. wright, with his
counsel, Robert L. O'Brien, Esquire, and the Mother, Kim L. wright, with
her counsel, Joan Carey, Esquire and David Lopez.
3. The parties agreed to entry of an Order in the form as attached.
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DAVIDL. WRIGHT,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V ANlA
: NO. 00-6799
CIVIL TERM
KIM L. WRIGHT,
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this 10'" day of ~~~ ,2001, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The parties shall submit themselves, their minor Child, and any other individuals deemed
necessary to a Custody Evaluation to be performed by a professional selected by the Father. The
purpose of the evaluation shall be to obtain independent professional recommendations concerning
ongoing custody arrangements which will best serve the interests of the Child. The Father shall
initially be responsible to pay the costs of the evaluation but reserves the right to petition the Court for
an allocation of the costs between the parties. The parties shall sign all authorizations deeme:d
necessary by the evaluator in order to obtain additional information pertaining to the parties or the
Child.
2. Pending further Order of Court or agreement of the parties, the prior Order of this Court
dated November 7,2000 shall continue in effect.
3. Counsel for either party may contact the Conciliator within 60 days of receipt of the
evaluator's written recommendation, to schedule an additional Custody Conciliation Conference, if
necessary.
BY THE COURT,
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Robert L. O'Brien, Esquire - Counsel for Father
David Lopez, Esquire - Counsel for Mother
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DAVID L. WRIGHT,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: 00-6799
CIVIL ACTION LAW
KIM L. WRIGHT,
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 Child who is the subject of this litigation is as
follows:
'NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Jessica Lynn Wright
November 13, 1992
Mother
2. A Conciliation Conference was held on September 5, 2001, with the following individuals
in attendance. The Father, David L. Wright, with his counsel, Robert L. O'Brien, Esquire, and the
Mother, Kim L. Wright, with her counsel, David Lopez, Esquire.
3. The parties agree to entry of an Order in the form as attached.
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Dawn S. Sunday, Esquire
Custody Conciliator
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DAVID L. WRIGHT
Plaintiff
Vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000- fs, 71/ CIVIL TERM
KIM L. WRIGHT
Defendant
IN CUSTODY
ORDER OF COURT
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AND NOW THIS L/ -day otAfi'!il, 2000, upon review of the attached Petition for
Special Relief, this Court sets a hearing in this matter for /?lt1>?4"7
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,the 7
___ day of Ochb<.r
, 2000, at /l);co AM.lBiM, in Courtroom # i
of the Cumberland County Courthouse, Carlisle, Pennsylvania,
BY THE COURT,
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DAVID L. WRIGHT
Plaintiff
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000- &1'19 CIVIL TERM
IN CUSTODY
Vs.
KIM L. WRIGHT
PETITION FOR
SPECIAL RELIEF
1) Petitioner is David L. Wright, Plaintiff in the above-captioned action.
2) Respondent is Kim L. Wright, Defendant in the above-captioned action,
3) Petitioner incorporates the pleadings as set forth in his Complaint for
Custody herein,
4) Petitioner believes that the absence of a temporary order is contrary to
the best interest of the child because it allows either parent to withhold the child from
the other parent. Likewise, Petitioner believes that it is his daughter's best interest that
she remain in her current school and have regular and frequent contact with both
parents. He seeks to maintain the status quo as much as possible.
WHEREFORE, Petitioner respectfully requests that Your Honorable Court set
and emergency hearing so as to set the parties' rights herein in regard to custody of the
parties' child, Jessica Lynn Wright.
Respectfully submitted,
Date: I () /" Jrx>
( 201)1\A.J
Robert L. O'Brien, Esquire
O'BRIEN, BARIC & SCHERER
17 West South Street
Carlisle, PA 17013
(717) 249-6873
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I verify that the statements made in the foregoing Petition for
Special Relief are true and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S, S 4904, relating to unsworn falsification to
authorities.
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DAVID L. WRIGHT
DATE: /o~ .y- 0 cJ
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! DAVID L. WRIGHT
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000- CIVIL TERM
Vs.
I KIM L. WRIGHT
! Defendant
IN CUSTODY
I
j ORDER OF COURT
i
I AND NOW THIS _ day of , 2000, upon consideration of
II the attached complaint, it is hereby directed that the parties and their respective
I, counsel appear before " the conciliator, at
II on the_day of . ,2000 at_
I! AM.lP.M., for a Pre-Hearing Custody Conference. At such conference, an effort will be
,
I 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,
BY THE COURT,
BY
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply
with the Americans with Disabilities Act of 1990. For information about accessible
facilities and reasonable accommodations available to disabled individuals having
business before the court, please contact our office. All arrangements must be made at
least 72 hours prior to any hearing or business before the court. You must attend the
scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OF 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
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DAVID L. WRIGHT
Plaintiff
Vs,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000- CIVIL TERM
KIM L. WRIGHT
Defendant
IN CUSTODY
COMPLAINT FOR CUSTODY
1. Plaintiff is David L. Wright, an adult individual, currently residing at 1239
Spring Road, Carlisle, Cumberland County, Pennsylvania.
2. Defendant is Kim L. Wright, an adult individual, currently residing at 1239
Spring Road, Carlisle, Cumberland County, Pennsylvania.
3. Plaintiff seeks custody of the following child: Jessica Lynn Wright, age 7,
born November 13, 1992.
The child was not born out of wedlock.
The child is presently in the custody of both parties, but a separation is
soon expected.
During the past five years, or since the child's birth, she has resided with
the following persons at the following addresses:
(a) From birth to August 1998 with both parents at 110 Grimm Lane,
Middletown, PA.
(b) From August 1998 to the present with both parents.
4. The relationship of the Plaintiff to the child is that of natural father.
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5. The relationship of the Defendant to child is that of natural mother.
6. The parties have not participated as a party or witness, or in any other
capacity in other litigation, concerning the custody of the child in this or in any other
Court.
Plaintiff does not know of a person not a party to the proceedings who
has physical custody of the child or claims to have custody or visitation rights with
respect to the child.
7. The best interest and permanent welfare of the child will be served by
granting the relief requested because:
(a) The Father has been an active participant in raising his daughter, In
1998, when Jessica was five years old, her Mother was hospitalized for 110 days and
thereafter underwent a lengthy period of recovery. All during this period the Father
assumed and arranged for the care of Jessica.
(b) The Mother has stated that she intends to take the,child to
Middletown, thereby removing her from the school she has attended for the past two
years. The Father feels that a change in the school is not in Jessica's best interest.
The Father is willing to relocate to a home close by and in the Carlisle area so as to
permit both parents to arrange for shared custody while Jessica continues in school
and remains in her home with her Mother. Father seeks to maintain as much stability in
his daughter's life as possible while the parents undergo a period of trial separation.
( c) Father wants to be accommodating to permit "frequent and continuing
contact and physical contact" between Jessica and her Mother. 23 PACSA 5303 (a).
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8. 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. All other persons, named below, who are known to have or claim a right to
custody or visitation of the child will be given notice of the pendency of this action and
the right to intervene.
NAME
ADDRESS
BASIS OF CLAIM
None
WHEREFORE, Plaintiff requests your Honorable Court to:
A) grant equal shared custody of the child to the Father on a
Sunday to Sunday schedule.
B) grant such other relief as is just and in the best interest of the
child.
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C) set a court hearing to establish a temporary Order maintaining
the status quo until a resolution by conciliation or full custody hearing.
Respectfully submitted,
Date:~
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Robert L. O'Brien, Esquire
O'BRIEN, BARIC & SCHERER
17 West South Street
Carlisle, PA 17013
(717) 249-6873
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I verify that the statements made in the foregoing Complaint for
Custody are true and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. CoSo S 4904, relating to unsworn falsification to
authorities,
4/<1110
DAVID L. WRIGHT
DATE: /0 - L; - 00
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DAVID L. WRIGHT
PLAINTIFF
V.
KIM L. WRIGHT
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
00-6799 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 9th day of October, 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 ~dayof November ,2000,at.--!!:00a.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 TIIE COURT,
By: Isl
Dawn S. Sunday, Eif
Custody Conciliato
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
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DAVID L. WRIGHT
Plaintiff
Vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO, 2000-10 1?1 CIVIL TERM
KIM L. WRIGHT
Defendant
IN CUSTODY
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 , the conciliator, at
on the _ day of , 2000 at_
A.M.lP.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.
BY THE COURT,
BY
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply
with the Americans with Disabilities Act of 1990. For information about accessible
facilities and reasonable accommodations available to disabled individuals having
business before the court, please contact our office. All arrangements must be made at
least 72 hours prior to any hearing or business before the court. You must attend the
scheduled conference or hearing,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OF 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
DAVID L. WRIGHT
Plaintiff
Vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO, 2000- (.1?? CIVIL TERM
KIM L. WRIGHT
Defendant
IN CUSTODY
COMPLAINT FOR CUSTODY
1, Plaintiff is David L. Wright, an adult individual, currently residing at 1239
Spring Road, Carlisle, Cumberland County, Pennsylvania.
2. Defendant is Kim L. Wright, an adult individual, currently residing at 1239
Spring Road, Carlisle, Cumberland County, Pennsylvania.
3. Plaintiff seeks custody of the following child: Jessica Lynn Wright, age 7,
born November 13, 1992.
The child was not born out of wedlock,
The child is presently in the custody of both parties, but a separation is
soon expected.
During the past five years, or since the child's birth, she has resided with
the following persons at the following addresses:
(a) From birth to August 1998 with both parents at 110 Grimm Lane,
Middletown, PA.
(b) From August 1998 to the present with both parents.
4, The relationship of the Plaintiff to the child is that of natural father.
II
5. The relationship of the Defendant to child is that of natural mother.
6. The parties have not participated as a party or witness, or in any other
capacity in other litigation, concerning the custody of the child in this or in any other
Court,
Plaintiff does not know of a person not a party to the proceedings who
has physical custody of the child or claims to have custody or visitation rights with
respect to the child,
7. The best interest and permanent welfare of the child will be served by
granting the relief requested because:
(a) The Father has been an active participant in raising his daughter. In
1998, when Jessica was five years old, her Mother was hospitalized for 110 days and
thereafter underwent a lengthy period of recovery. All during this period the Father
assumed and arranged for the care of Jessica.
(b) The Mother has stated that she intends to take the child to
Middletown, thereby removing her from the school she has attended for the past two
years. The Father feels that a change in the school is not in Jessica's best interest.
The Father is willing to relocate to a home close by and in the Carlisle area so as to
permit both parents to arrange for shared custody while Jessica continues in school
and remains in her home with her Mother. Father seeks to maintain as much stability in
his daughter's life as possible while the parents undergo a period of trial separation.
(c) Father wants to be accommodating to permit "frequent and continuing
contact and physical contact" between Jessica and her Mother. 23 PACSA 5303 (a).
II
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8. 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. All other persons, named below, who are known to have or claim a right to
custody or visitation of the child will be given notice of the pendency of this action and
the right to intervene.
NAME
ADDRESS
BASIS OF CLAIM
None
WHEREFORE, Plaintiff requests your Honorable Court to:
A) grant equal shared custody of the child to the Father on a
Sunday to Sunday schedule.
B) grant such other relief as is just and in the best interest of the
child,
C) set a court hearing to establish a temporary Order maintaining
the status quo until a resolution by conciliation or full custody hearing.
Respectfully submitted,
Date:~
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Robert L. O'Brien, Esquire
O'BRIEN, BARIC & SCHERER
17 West South Street
Carlisle, PA 17013
(717) 249-6873
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I verify that the statements made in the foregoing Complaint for
Custody are true and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. 34904, relating to unsworn falsification to
authorities.
,
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DAVID L. WRIGHT
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. IN THE COURT OF COMMON PLEAS OF
.
. CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
: NO. 00-6799 CIVIL TERM
:
. CIVIL ACTION - LAW
.
: IN CUSTODY
DAVID L. WRIGHT,
Plaintiff
KIM L. WRIGHT,
Defendant
ORDER OF CXXlRT
AND 1!ilCIi, this 1- .
upon consideration of the attached
ordered and directed as follows:
day of ..v. ..~ , 2000,
Custody Conciliation Report, it is
1. The Father, David L. Wright, and the Mother, Kim L. Wright, shall
have shared legal custody of Jessica Lynn Wright, born November 13, 1992.
Each parent shall have an equal right, to be exercised jointly with the
other parent, to make all major non-emergency decisions affecting the
Child's general well-being including, but not limited to, all decisions
regarding her health, education, and religion.
2. until such time as the Father relocates his residence to the
Middletown area, where the Mother resides, the custody arrangements set
forth in this Court's Order dated October 24, 2000 shall continue in
effect.
3. At such time as the Father relocates his residence to the
Middletown area, the parties shall share having physical custody of the
Child on an alternating weekly basis with the exchange of custody to take
place on Fridays. When the Father is receiving custody of the Child on
Friday, he shall pick up the Child at 6:00 p.m. at the Mother's residence.
When the Mother is receiving custody of the Child on Friday, the Child
shall take the bus from school to the Mother's residence, as usual.
When the Father has to work during his period of custody and is
unable to provide care for the Child, the Father shall first contact the
Mother to offer her the opportunity to provide care for the Child before
contacting third party caregivers. The parties shall cooperate in
determining whether it is appropriate for the Child to attend certain car
shows and in making arrangements for care of the Child during car shows
when the Father has custody of the Child.
4. The parties shall share or alternate having custody of the Child
on holidays as follows:
A. c:flRIS'mAS: The Christmas holiday shall be divided into
Segment A, which shall run from Christmas Eve at 12:00 noon
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through Christmas Day at 12:00 noon, and Segment B, which
shall run from Christmas Day at 12:00 noon through December 26
at 12:00 noon. In even numbered years, the Father shall have
custody of the Child during Segment A and the Mother shall
have custody during Segment B. In odd numbered years, the
Mother shall have custody of the Child during Segment A and
the Father shall have custody during Segment B. In every
year, the parties shall equally share having custody of the
Child during the remainder of the Christmas school break.
B. THANKSGIVING: In every year, the Father shall have custody of
the Child from the Wednesday before Thanksgiving at 6:00 p.m.
through Thanksgiving Day at 5:00 p.m. and the Mother shall
have custody from Thanksgiving Day at 5:00 p.m. through the
Friday after Thanksgiving at 6:00 p.m.
C. ALTERNATING HOLIDAYS: The Easter holiday shall run from the
Saturday before Easter at 6:00 p.m. through Easter Sunday at
6:00 p.m. The Memorial Day and Labor Day holidays shall run
from 9:00 a.m. until 9:00 p.m. on the day of the holiday. The
July 4th holiday shall run from 9:00 a.m. until after the
fireworks on July 4th. In even numbered years, the Mother
shall have custody of the Child over the Memorial Day and
Labor Day holidays and the Father shall have custody over
Easter and July 4th. In odd numbered years, the Father shall
have custody of the Child on the Memorial Day and Labor Day
holidays and the Mother shall have custody on Easter and July
4th.
D. MO:rIIER'S DAY/FATHER'S DAY: In every year, the Mother shall
have custody of the Child from 9:00 a.m. until 9:00 p.m. on
Mother's Day and the Father shall have custody from 9:00 a.m.
until 9:00 p.m. on Father's Day.
E. PAREI!lTS' BIRTHDAYS: Each party shall be entitled to have a
period of custody with the Child on that parent's birthday at
times to be arranged by agreement of the parties.
F. The holiday custody schedule shall supersede and take
precedence over the regular custody schedule.
5. Each party shall advise the other party of his or her current
address and telephone number on an ongoing basis.
6. In the event either party intends to remove the Child from his or
her residence for an overnight period or longer, that party shall provide
the other party with advance notice of an address and telephone number
where the Child can be contacted.
7. Neither party shall do or say anything which may estrange the
Child from the other parent, injure the opinion of the Child as to the
other parent, or hamper the free and natural development of the Child's
love and respect for the other parent. Both parties shall take all
reasonable steps to ensure that third parties having contact with the Child
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comply with this provision.
8. This Order is entered pursuant to an agreement of the perties at a
Custoqy 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,
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cc: Robert L. O'Brien, Esquire - Counsel for Father
Joan Carey, Esquire - Counsel for Mother
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DAVID L. WRIGHT, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. . NO. 00-6799 CIVIL TERM
.
.
.
KIM L. WRIGHT, : CIVIL ACTION - LAW
Defendant : IN CUSTODY
PRIOR JUDGE: Kevin A. Hess
CUSTODY cnICILIATICl\I SUMMARY REPCRT
IN ACOJRDANCE WITH CUMBERLAND COONTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
DATE OF BIRTH
CURRENTLY IN CUS'l'OOY OF
NAME
Jessica Lynn wright
November 13, 1992
Mother
2. A Conciliation Conference was held on November 1, 2000, with the
following individuals in attendance: The Father, David L. wright, with his
counsel, Robert L. O'Brien, Esquire, and the Mother, Kim L. wright, with
her counsel, Joan Carey, Esquire and David LOpez.
3. The parties agreed to entry of an Order in the form as attached.
Date
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DAVID 1. WRIGHT,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
00-6799 CIVIL
KIM 1. WRIGHT,
Defendant
IN CUSTODY
ORDER
AND NOW, this
z.. '-II" day of October, 2000, following hearing on the motion of
the plaintiff for a temporary order, pending conciliation and further order of court, primary
physical custody of the child, Jessica Lynn Wright, born November 13,19992, is temporarily
awarded to her mother, Kim Wright, with periods of partial custody in the father, David Wright,
as the parties shall agree, including at a minimum every other weekend from Friday evening to
Sunday evening and one evening every week on such day as the parties shall agree and, if they
cannot agree, on Wednesday. On the application of Gruber . Gruber, 583 A.2d 434 (Pa.Super.
1990) to this case, see Hurlev v. Hur1ev, 754 A.2d 1283 (pa.Super. 2000).
BY THE COURT,
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Robert 1. O'Brien, Esquire
For the Plaintiff
Joan Carey, Esquire
For the Defendant
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Pennsylvania Support Calculator
wysiwyg.//4/http.//www.pennglazier.comlsupportlsupport.html
Pennsylvania OnLine Support Calculator
Copyright 11.:11999,2000 Penn Glazier, Esq., 625 W. Chestnut St., Lancaster, PA
PLAINTIFF'!;
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Name of Case: david
Obligor's Gross Income per pay period is $1000, Obligor has 52 pay periods per year,
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Please send comments to penn@oennglazier.com
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. This Java Script is provided free of charge, "AS IS", for use by judges, divorce masters, law clerks, attorneys and paralegals. I assume no responsibility
whatsoever for errors. If you discover errors, please notifY me by email. Yau voluntarily assume all risks in connection with the use of this program.
This Java Script is designed for use by legal professionals only. It is not, and should not be regarded as legal advice.
If you are in need ortegal advice, please contact an attorney.
Pemsylvania law regarding spouse and child support is complicated. This Java Script is, hopefully, a useful tool in the hands of a competent professional. There
is, however, a risk that. for an untrained person. using this Java Script can produce misleading results.
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There is no warranty of any kind, including without limitation the warranties of merchantability, or fitness for a particular purpose.
Title, ownership rights, and intellectual property rights in the software code are and shall remain the property of Penn Glazier.
This software is Copyright@ 1999,2000 by Penn Glazier,
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-06799 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WRIGHT DAVID L
VS
WRIGHT KIM L
BRIAN BARRICK
, Sheriff or Deputy Sheriff of
Cumberland County,pennsylvania, who being duly sworn according to law,
says, the within ORDER OF COURT
was served upon
WRIGHT KIM
the
RESPONDANT
, at 0020:01 HOURS, on the 5th day of October ,2000
at 1239 SPRING ROAD
CARLISLE, PA 17013
by handing to
KIM WRIGHT
a true and attested copy of ORDER OF COURT
together with
IN CUSTODY, PETITION FOR SPECIAL RELIEF
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
3.10
.00
10.00
.00
31.10
~~Vf:~"
R. Thomas Kline
me this
c."
/0 ~ day of
10/06/2000
O'BRIEN: BARIC ~R, J
By. f!l.~A
Deputy Sheriff --
Sworn and Subscribed to before
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DAVID L. WRIGHT, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. . NO. 00-6799 CIVIL TERM
.
:
KIM L. WRIGHT , . CIVIL ACTION - LAW
.
Defendant : IN CUSTODY
PRIOR JUDGE: Kevin A. Hess
CUSTODY o:NCILIATICN SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COONTY RULE OF CIVIL PROCEOORE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Jessica Lynn Wright
November 13, 1992
Mother
2. A Conciliation Conference was held on January 30, 2001, with the
following individuals in attendance: The Father, David L. Wright, with his
counsel, Robert L. O'Brien, Esquire, and the Mother, Kim L. Wright, with
her counsel, Joan Carey, Esquire.
3. This Court previously entered an Order in this matter on November
7, 2000, after a Conciliation COnference on November 1, 2000. The Father
filed this petition for enforcement which resulted in the scheduling of an
additional Conference. Although it was determined at the COnference that
the entry of an additional Order is not necessary at this time, the parties
discussed several issues which have caused conflict in the implementation
of the Order since the prior Conference. Most importantly, the parties
agree to engage in a course of counseling in order to obtain assistance in
improving communications and cooperation in coparenting their Child. The
parties acknowledge the importance of selecting a counselor and initiating
the sessions as soon as possible following the Conference. In addition,
the parties agree to limit the non-custodial parent's telephone calls to
the Child to one call each day.
c/~~
Date
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Dawn S. sunday, Esquire
CUstody Conciliator
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cc: vRobert L. O'Brien, Esquire - Counsel for Father
,/Joan Carey, Esquire - Counsel for Mother
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DAVID 1. WRIGHT
PLAINTIFF
V,
KIM 1. WRIGHT
DEFENDANT
IN TIIE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
00-6799 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 3rd day of January, 2001, 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, Mechanicsburl(, PA 17055 onthe 17th day of January, 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.
FOR THE COURT,
By: Isl
'awn S. Sund'a 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 THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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DAVID L. WRIGHT
Plaintiff/Petitioner
Vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO, 2000-6799 CIVIL TERM
KIM L. WRIGHT
Defendant/Respondent
IN CUSTODY
ORDER OF COURT
AND NOW THIS _ day of , 2000, upon consideration of
the attached Petition, it is hereby directed that the parties and their respective counsel
appear before , the conciliator, at
on the _ day of , 200~ at_
A.M.lP.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.
BY THE COURT,
BY
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply
with the Americans with Disabilities Act of 1990, For information about accessible
facilities and reasonable accommodations available to disabled individuals having
business before the court, please contact our office, All arrangements must be made at
least 72 hours prior to any hearing or business before the court. You must attend the
scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OF 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
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DAVID L. WRIGHT
Plaintiff/Petitioner
Vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000-6799 CIVIL TERM
KIM L. WRIGHT
Defendant/Respondent
IN CUSTODY
PLAINTIFF'S PETITION FOR IMPLEMENTATION
OF CUSTODY ORDER UNDER
23 Pa, C,S.A & 5306
1. Petitioner is David L. Wright, the Plaintiff in the above-captioned action.
2, Respondent is Kim L. Wright, the Defendant in the above-captioned
action,
3. A copy of the custody order in reference to the parties' child, Jessica Lynn
Wright, age 7, is attached hereto as Exhibit "A" and is incorporated herein by reference,
4. On or about December 11, 2000, the Defendant/Respondent sent a
communication to the Plaintiff/Petitioner, in which she refused to discuss any matters
concerning their daughter, other than matters relating to an emergency concerning the
child. She has also threatened to have the Plaintiff/Petitioner charged with criminal
trespass, harassment and stalking and harassment by communication or address. A
copy of the communication is attached hereto as Exhibit "B" and is incorporated herein
by reference.
5. Pursuant to 23 Pa. C.S.A. 9 5303, one of the considerations the Court has
to make is which parent will permit and allow frequent and continuing contact between a
parent and their child. Additionally, one of the gravamen of a shared custody situation
is that the parents be able to communicate openly about their child,
II
The Plaintiff/Petitioner believes that the Defendant/Respondent is attempting to create
a climate which would effectively destroy the parties' shared custody which has been
court ordered.
WHEREFORE, the Plaintiff/Petitioner requests that psychological
evaluations be conducted of both parents to assist the court in determining which
parent is better able to care for the child, In the meantime, the Plaintiff/Petitioner
requests that the court convene a hearing to see what can be done to implement the
existing court order pursuant to 23 Pa. C.SA S 5303.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
By:
r ~ D~AJ-V-
Robert L. O'Brien, Esquire
Attorney for Plaintiff/Petitioner
1.0. # 28351
17 West South Street
Carlisle, Pennsylvania 17013
robrien@obslaw.com
rlo.dir/domestic/wright.imp
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VERIFICATION
I verify that the statements made in the foregoing Plaintiff's Request for
Implementation of Custody Order Under 23 Pa. C.SA 9 5303 are true and correct.
understand that false statements made herein are made subject to the penalties of 18
Pa, C,S. 94904, relating to unsworn falsification to authorities.
4~::t
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Date: /2..-/
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Praecipe -
Kim L. Wright
1..1,1. Of..
Enter Appearance
DAVID L. WRIGHT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-6799 CIVIL TERM
KIM L. WRIGHT,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
PRAECIPE TO WITHDRAW APPEARANCE
TO THE PROTHONOTARY OF THE SAID COURT:
Please withdraw the appearance of David Lopez, Esquire, as
attorney for the Defendant, Kim L. Wright.
D
PRAECIPE FOR ENTRY OF APPEARANCE
Please enter the appearance of Diane G. Radcliff, Esquire, as
attorney for the Defendant, Kim L. Wright, in the above captioned
matter.
Respectfully submitted,
\
G. F, ESQUI
3448 Trin e Road
amp Hill, 17011
HONE: (7 737-0100
Fax: (717) 975-0697
Attorney for Defendant
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DAVID 1. WRIGHT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
00-6799 CIVIL
CIVIL ACTION - LAW
KIM 1. WRIGHT,
Defendant
IN RE: PETITION FOR EMERGENCY RELIEF
ORDER
AND NOW, this L 'Z...J day of March, 2002, a rule is issued on the plaintiff to show
cause why the relief requested in the within petition ought not to be granted. This rule returnable
seven (7) days after service.
BY THE COURT,
Ropet1: 1. O'Brien, Esquire
ybr the Plaintiff
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.->>1ane G. Radcliff, Esquire
For the Defendant
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3.7.02. Kim L. Wright. Petition for Emergency Relief
DAVID L. WRIGHT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
NO. 00-6799 CIVIL TERM
KIM L. WRIGHT,
Defendant
CIVIL ACTION - LAW
CUSTODY
ORDER
AND NOW, this _ day of
2002, upon
consideration of the within Petition, IT IS HEREBY ORDERED THAT
father, David L. Wright, shall make immediate arrangements with
mother, Kim L. Wright, to provide her with the opportunity to
provide care for the child before contacting any third party
caregivers during any time period he has to work during his period
of custody and is unable to provide for the child. This Order is
made in accordance with the provisions of Paragraph 3 of the
November 7, 2000 Order of Court and it is specifically directed
that the parties comply therewith.
BY THE COURT:
J.
Distribution to:
Diane G. Radcliff, Esquire
3448 Trindle Road
Camp Hill, PA 17011
Attorney for Defendant
Robert L. O'Brien, Esquire
17 West South Street
Carlisle, PA 17013
Attorney for Plaintiff
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3.7.02. Kim L. Wright. Petition for Emergency Relief
. .
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DAVID L. WRIGHT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
NO. 00-6799 CIVIL TERM
KIM L. WRIGHT,
Defendant
CIVIL ACTION - LAW
CUSTODY
PETITION FOR EMERGENCY RELIEF
AND NOW,
this J~':thday of J''fI(\~
, 2002, comes the
Petitioner, Kim L. Wright, by her attorney, Diane G. Radcliff,
Esquire, and files this petition for Emergency Relief as follows:
1. Your Petitioner is Kim L. Wright, the Defendant in the
above-referenced matter, an adult individual residing at
2727
Foxianna
Road,
Middletown,
Dauphin
County,
Pennsylvania.
(The Petitioner is hereinafter referred to
as "Mother").
2. Your Respondent is David L. Wright, the Plaintiff in the
above-referenced matter, an adult individual residing at
4 Knollwood Building, Middletown,
Dauphin County,
Pennsylvania.
(The Defendant is hereinafter referred to
as "Father").
3. On November 7, 2000, an Order was entered by this Court
pertaining to the custodial arrangements between Mother
and Father regarding their child, Jessica Lynn Wright,
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3.7.02. Kim L. Wright. petition for Emergency Relief
born November 13, 1992.
(The child is hereinafter
referred to as "the Child"). A true and correct copy of
said Order is attached hereto, marked Exhibit "A" and
made a part hereof.
4. Pursuant to the provisions of Paragraph 3 of the November
7, 2000 Order, it was provided that "when the Father has
to work during his periods of custody and is unable to
provide care for the Child, the Father shall first
contact the Mother to offer her the opportunity to
provide care for the child before contacting third party
care givers".
5. This case is currently pending before the Court on a
subsequent petition for modification filed by Father
wherein both parties are seeking to have primary custody
of the Child. A hearing has been scheduled by this Court
for May 24, 2002 at 9:30 a.m. A true and correct copy of
the Order dated March 5, 2002 scheduling that hearing and
confirming that the existing custody order shall remain
in effect is attached hereto, marked Exhibit "B" and made
a part hereof.
6. Subsequent to the conciliation conference held in this
matter on Father's petition to Modify the custodial
- 3 -
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3.7.02. Kim L. Wright. Petition for Emergency Relief
arrangements, Mother had been providing day care services
for the Child after school during Father's custodial
weeks
since
Father
did
not
return
home
until
approximately 6:00 p.m. on the evenings during his
custodial weeks..
7. Based on advice Mother received from other individuals,
Mother felt that Father was taking advantage of her in
providing such after school day care and requested that
Father provide the day care for the Child, feeling that
he would rearrange his work schedule in order to provide
the care himself.
8. As it turns out, Father did not rearrange his work
schedule and instead secured the services of a babysitter
to watch the Child.
9. The Child has been distraught and emotionally upset with
these arrangements and wants to be in the custody of
Mother rather than with a third party care giver.
10. On March 4, 2002, Mother requested that she again be
permitted to watch the Child before and after school
during any time Father was unable to provide the care
directly, instead of using third party care givers, and
Father refused said request. True and correct copies of
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3.7.02. Kim L. Wright. Petition for Emergency Relief
the correspondence pertaining to the same is attached
hereto, collectively marked Exhibit "C" and made a part
hereof.
11. Mother is ready, willing and able to provide the care for
the Child during any time period Father has custody and
has to work and does not want the Child watched by third
party care givers.
12. Father has refused to permit Mother to care for the Child
and instead has placed the Child with third party care
givers and has refused to provide Mother with any
information pertaining to the names, addresses, or phone
numbers for said care givers.
13. Mother feels that an emergency exists and that she should
be permitted to care for the Child during any time period
Father is unable to watch the Child in accordance with
the provisions of Paragraph 3 of the attached November 7,
2000 Order of Court.
14. The only Judge who has been assigned in this case has
been the Honorable Kevin A. Hess, who is the Judge who
entered the custody orders attached to this Petition.
15. Mother's legal counsel, Diane G. Radcliff, Esquire, has
contacted Father's legal counsel, Robert L. 0' Brien,
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3.7.02. Kim L. Wright. Petition for Emergency Relief
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Esquire, to inquire as to whether Father would agree with
this Petition and has been advised that he disagrees.
WHEREFORE, Mother respectfully requests this Honorable Court
to enter an Order requiring Father to immediately provide Mother
with the right to watch the Child any time he has to work, rather
than placing the child with third party care givers, and to require
the parties hereafter to comply with the terms and provisions of
the November 7, 2000 Order of Court until further Order of Court
entered as the result of the hearing scheduled in this matter for
May 24, 2002.
Respectfully submitted,
, ESQUIRE
Road
Hi ,PA 17011
Phone: (717) 737 - 0100
Fax: (717) 975-0697
Supreme Court ID # 32112
Attorney for Plaintiff
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3.7.02. Kim L. Wright. petition for Emergency Relief
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VERIFICATION
I verify that the statements made in the foregoing document
are true and correct.
I understand that false statements herein
are made subject to the penalties of 18 Pa.C.S. Section 4904,
relating to unsworn falsification to authorities.
J<,~ ~ "1., <.. .~'
KIM L. WRIGHT
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3.7.02. Kim L. Wright. Petition for Emergency Relief
CERTIFICATE OF SERVICE
AND NOW, this I~day of -J~[Y\W_A..~--^ ,2002, I, Diane G.
Radcliff, Esquire, hereby certify that I have this day served a
true and correct copy of the foregoing document upon the following
named person, by mailing the same by first class mail, postage
prepaid, addressed as follows:
Robert L. O'Brien, Esquire
17 West South Street
Carlisle, PA 17013
Respectfully submitted,
CLIFF, ESQUIR
Trin le Road
, PA 17011
Phone: (717) 737-0100
Fax: (717) 975-0697
Supreme Court ID# 32112
- 8 -
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3.7.02. Kim L. Wright. petition for Emergency Relief
EXHIBIT "A"
11/7/00 CUSTODY ORDER
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pAvID L'; WRIGHT,
Plaintiff
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.
IN THE COURT OF ON PLEAS OF
CUMBERLAND CCUNTY , PENNSYLVANIA
.
.
:
vs.
: NO. 00-6799 CIVI TEPM
:
KIM L. WRIGHT,
Defendant
:
CIVIL ACTION - LAW
IN CUSTODY
.
.
OODER OF CXXlRT
']+.h
upon consideration of the attached
ordered and directed as follows:
AND 1!ilCIi, this
day of , 2000,
Custody Conciliation Report, it is
1. The Father, David L. Wright, and the Mother, Kim . Wright, shall
have shared legal custody of Jessica Lynn Wright, born No r 13, 1992.
Each parent shall have an equal right, to be exercised j intly with the
other parent, to make all major non-emergency decisions affecting the
Child's general well-being including, but not limited to, all decisions
regarding her health, education, and ~'eligion.
2. Until such time as the Father relocates his r sidence to the
Middletown area, where the Mother resides, the custody angements set
forth in this Court's Order dated October 24, 2000 sha 1 continue in
effect.
3. At such time as the Father relocates his re idence to the
Middletown area, the parties shall share having physical tOdy of the
Child on an alternating weekly basis with the exchange of tody to take
place on Fridays. When the Father is receiving custody f the Child on
Friday, he shall pick up the Child at 6:00 p.m. at the Moth r's residence.
When the Mother is receiving custody of the Child on Fri y, the Child
shall take-the bus from schcol to the Mother's residence, as usual.
When the Father has to work during his period of custody and is
unable to provide care for the Child, the Father shall fi st contact the
Mother to offer her the opportunity to' provide care for e Child before
contacting third party caregivers., The parties shall cooperate in
determining whether it is appropriate for the Child to att nd certain car
shows and in making arrangements for care of the Child ing car shows
when the Father has custOdy of the Child.
4. The parties shall share or alternate having cust' of the Child
on holidays as follows:
A. CBRISTMAS: The Christmas holid<lY shall be divided into
Segment A, which shall run from Christmas Eve at 12:00 noon
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3: 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,
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Kevi::ff: ~ess, - J.
cc: Robert L. O'Brien, Esquire - Counsel for Father
Joan Carey, Esquire - counsel for Mother
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TRUE COpy FROM RECORD
In Testimony whueof, I here unto set my handl
and the seal of sai Court 'Ak' t rli~le, Pa. '
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3.7.02. Kim L. Wright. Petition for Emergency Relief
EXHIBIT "B"
3/5/02 CUSTODY HEARING ORDER
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KIM L. WRIGHT,
Plaintiff
v
DAVID L. WRIGHT,
Defendant
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MAR 0 1 2002 l,!-.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW'
NO. 00 - 7982 CIVIL
IN CUSTODY
COURT ORDER
f0a..rch
AND NOW, this ~~__ day of ~ill3mllry, 2002, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as foIl s:
A hearing islscheduled i ourtr m No.4 ofthe Cumberland County Courthouse
on the i!Ltbday of ,2002, at 93{) 110M. at
which time testimony wi! be aken in the above case. At this hearing, the Father,
David L. Wright, shall 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 the history of custody in this case, the issues currently
before the court, a summary of each parties position on these issues, a list of
witnesses who will be called to testify and a summary of the anticipated testimony
of each witnesses. This m~morandum shall be filed at least five (5) days prior to
the mentioned hearing date.
1.
2.
Pending further order of this court, the existing custody order shall remain in
effect.
cc: Robert L. O'Brien, Esquire
Diane G. Radcliff, Esquire
J.
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tnonotary' ,
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EXHIBIT "c"
ATTORNEYS' COMMUNICATION
REGARDING DAYCARE ISSUE
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DIANE G. RADCLIFF, ESQUIRE
AUomey at Law
3448 Trindle Road
Camp Hill, Pennsylvania 17011
Phone: (717) 737-0100
Facsimile: (717) 975-0697
February 27, 2002
Robert L. O'Brien, Esquire
17 West South Street
Carlisle, PA 17013
VIA FAX: 249-5775
RE: Wright v. Wright
Dear Rob:
As you are aware, in the past my client has been providing the
baby-sitting services before and after school for the parties'
child due to the fact that the father worked and was not able to be
with the child. This arrangement was in accordance with paragraph
3 of the Order dated November 7, 2001.
I received a telephone call from my client on February 27,
2002, advising me that her husband has now made arrangements for
the child to take the school bus after school to a sitter. He is
also having the child watched by a third party in the morning.
Additionally, he has refused to provide my client with a name or
telephone number of the sitter.
This arrangement is in direct contradiction to paragraph 3 of
the November 7, 2001 Order, which still remains in effect. Please
advise him that he must immediately permit my client to care for
the child during his work hours and may not secure the services of
a third party sitter to thwart the terms of the Order.
If he does not comply with the terms of this letter I will
file an immediate contempt action against him. Please contact me
upon receipt of this letter so we may discuss this matter further.
Very truly yours,
DIANE G. RADCLIFF, ESQUIRE
DGR/rzg
cc: Kim L. Wright
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02/28/2002 15:57
7172495755
71 72495?~5
(
OBS LAW OFFICE"
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Law Offices
PAGE III
O'BRIEN, BARIC & SCHERER
17 West South Streel
Carlisle, Pennsylvania 170 JJ
Robert L O'Brien
David A, Baric
~ichaelA,Scherer
(717) 2-19-687 J
Fax (7I7) 2-19-5755
E-mail: obs@obslaw.com
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DATE:
TO:
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FROM:
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RE:
Number of pages to follow this transmittal page:
IF YOU DO NOT RECEIVE ALL PAGES OR IF COPIES ARE
NOT LEGIBLE PLEASE TELEPHONE: (717) 249-6873
IMPORTANT. THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY
TO WHICH IT IS ADDRESSED. AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED,
CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW IF THE READER
OF THIS MESSAGE IS NOT THE INiENDED RECIPIENT. YOU ARE HEREBY NOTIFIED THAT
READING, DISSEMINATING. DISTRIBUTING OR COPYING THIS COMMUNICATION IS STRICTLY
PROHIBITED, IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE
IMMEDIATELY NOTIFY US BY TELEPHONE, AND RETURN THE ORIGINAL MESSAGE TO US AT
THE ABOVE ADDRESS VIA THE U.S. POSTAL SERVICE, THANK YOU,
Memo:
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DIANE G, RADCLIFF, ESQUIRE
AUomey at Law
3448 Trindle Road
Camp Hill, Pennsylvania 17011
Phone: (717) 737-0100
Facsimile: (717) 975-0697
March 4, 2002
Robert L. O'Brien, Esquire
17 West South Street
Carlisle, PA 17013
VIA FAX: 249-5755
RE: Wright v. Wright
Dear Rob:
I have recently spoken with my client pertaining to the
babysitting of Jessica, both before and after school. It was her
understanding from the e-mails sent back and forth between the
parties that Mr. Wright would be providing the day care for the
child and not a third party. Since it appears that he is unable to
do so, she is willing to watch the child. Please advise your
client of this change and confirm that he will provide her with
custody of the child during the times he is at work and unable to
provide said care.
I assume that you will not have sufficient time in which to
reach him and make these arrangements by today's date, being March
4, 2002, and therefore these arrangements will not take affect
until tomorrow, March 5, 2002. I do require, however, that you
confirm these arrangements with my office so that I may advise my
client accordingly.
Thank you for your attention in this matter.
Very truly yours,
DIANE G. RADCLIFF, ESQUIRE
DGR/rzg
cc: Kim Wright
, , 'L~il
03/05/2002 13:49
71 7249575~.,
(
oBS LAW oFFI CE
PAGE 01
Law Offices
O'BRIEN, BARIC & SC.HKR/:;.K
17 West South Street
Carlisle, Pennsylvania 17013
Robert L O'Brien
David A. Baric
NfichaelA Scherer
(7/7) 149.6873
Fax (717) 249.5755
E-mail: obs(~1obslaw.com
FAX COVER SHEET
DATE:March 5. 2002
TO: Diane G. Radcliff, Esq.
FAX NUMBER: 975-0697
FROM: Rob O'Brien
RE: Child care
PAGES FOLLOWING THIS SHEET: 0
Dear Diane:
Your client set this new arrangement in motion. It is patently ridiculous for your
client to think that Dave Wright could modify his work schedule to his daughter's school
schedule. Her email was initiated by a vengeful motive. Further, my cfientintends to
keep the current child care arrangements in place, accordingly please advise your client
not to interfere with the current arrangement.
Rob
IF YOU DO NOT RECEIVE ALL PAGES CLEARLY, PLEASE CALL (717) 249-6873
The information contained in this facsimile is transmitted by an attorney, It is privileged and confidential,
intended only for the use of the individual or entity named above, If the reader of this message is not the
intended recipient. you are hereby notified that any dissemination, distribution or copying Of the
communication is strictly prohibited, If this communication has been received in error, please immediately
notify us by telephone. collect if necessary, and return the original message to us at the above address via
the United Swtes Postal Service (we will reimburse post"ge), Thank you.
L .
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DIANE G. RADCLIFF, ESQUIRE
AUomey lilt LlIlw
3448 Trindle Road
Camp Hill, Pennsylvania 17011
Phone: (717) 737-0100
Facsimile: (717) 975-0697
March 6, 2002
Robert L. O'Brien, Esquire
17 West South Street
Carlisle, PA 17013
VIA FAX: 249-5755
RE: Wright v. Wright
Dear Rob:
I am in receipt of your fax dated March 5, 2002. I would like
to remind you that the Court Order clearly indicates that before
your client can have someone else watch the child, he must first
offer the right for my client to care for the child. While she may
have indicated in the past that she was not going to provide this
service, she is indicating now that she is willing to do so.
Therefore, if your client continues to refuse he is in violation of
the Court Order. It seems to me that his actions are vengeful, as
well as being a violation of the Court Order. I ask you to
reconsider his position. If not we will file the appropriate
contempt motion, or in the alternative, emergency order for further
direction by the Court.
I will anticipate hearing from you by tomorrow, March 7, 2002.
Very truly yours,
DIANE G. RADCLIFF, ESQUIRE
DGR/rzg
cc: Kim L. Wright (with enclosure)
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.
DIANE G. RADCLIFFl ESQUIRE
AUomey at Law
3448 Trindle Road
Camp Hill, Pennsylvania 17011
Phone: (717) 737-0100
Facsimile: (717) 975-0697
March 7, 2002
Robert L. O'Brien, Esquire
17 West South Street
Carlisle, PA 17013
VIA FAX: 249-5755
RE: Wright v. Wright
Dear Rob:
In as much as you have not advised me that Mr. Wright is not
willing to allow my client to watch the child when he is working,
I have prepared the enclosed Petition for Emergency Relief which I
intend on filing with the Court on or after March 11, 2002. In
accordance with the local Rules of Court, I am providing you with
a copy of this petition in advance of filing so you are aware of
the action I intend to take. I would, therefore, request that you
advise me whether or not your client is willing to consent to the
relief requested in this Petition. If I do not hear from you by
March 8, 2002, I will assume that your client continues to be
unwilling to allow his wife to be with the child during his work
hours, and will proceed with the filing of this petition advising
the Court of his non-consent.
Very truly yours,
DIANE G. RADCLIFF, ESQUIRE
DGR/rzg
Enclosure
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cc: Kim L. Wright
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DAVID L. WRIGHT
Plaintiff
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000- ~7~'1 CIVIL TERM
IN CUSTODY
Vs.
KIM L. WRIGHT
ANSWER TO PETITION FOR EMERGENCY RELIEF
1. Admitted
2. Admitted
3. Admitted
4. Admitted
5. Admitted
6. Admitted
7 During the parties marriage the mother was well aware of the father's work, and
the work scheduling that the father had. She knew that there was no opportunity for
him to arrange his work schedule so that he could pick his daughter up after school.
The mother precipitated this problem by suddenly e-mailing the father and informing
him that she would no longer provide the care for the parties child during the weeks that
she was with the father. On February 17, 2002 the mother e-mailed the father the
following message:
"Dave, as of February 25th when you have Jessica for your week you will
be picking her up on the weeks you have her; bye".
After receiving that message the father e-mailed the following response:
"It's hard to understand you. Do you mean pick Jessica up from school on
my weeks?".
The mother responded bye-mailing the father the fOllowing:
" You will have to pick her up on the weeks you have her from school, will
that be a problem for you" .
Copies of the e-mails are attached as exhibits.
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8. The father could not risk his daughter being left alone and so made
arrangements to pay for child care for his daughter after school until such time as he
could drive and pick her up. The father envisions that the mother would call him at work
and say that she was not going to pick Jessica up on any particularly day thereby
requiring him to drop his duties at work to rush over and pick Jessica up at school. The
father does not wish to expose himself to the risk of the loss of employment and more
importantly, the risk of his daughter being unattended.
9. The child enjoys the child care arrangements that the father has arranged for her
and she is not distraught or emotionally upset with the arrangements.
1 O. Due to the uncertainty generated by the mother's statement of March 17th, the
father has reason to believe that the mother will call and say that she will not provide
care for the child on any particular day or week.
11 -13. The father has made adequate care for his daughter and does not want the
mother to interfere with those arrangements and desires for the safety and security of
his daughter. He wishes that the child remain with the child care arrangements that the
father has put in place due to the mothers decision that she would not provided that
care.
WHEREFORE, father respectfully requests that the mothers petition be dismissed and
that the prior court order be modified, that only when he needs child care during the
hours he is not at work, that he would contact the mother to see if she is available to
provide the care.
Date:~
Respectfully submitted,
'I<D~ ~ .
Robert L. O'Brien, Esquire
O'BRIEN, BARIC & SCHERER
17 West South Street
Carlisle, PA 17013
(717) 249-6873
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jess
2/17/02 8:20:57 PM Eastern Standard Time
KssLeather
DLWRIGHT55
dave, as of february 25th when you have jessica for your week you will be
picking her up on the weeks you have her ;bye
Sunday, February 17,2002 America Online: DL WRIGHT55
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Re: jess
2/17/029:31:04 PM Eastern Standard Time
DLWRIGHT55
KssLeather
It's hard to understand you. Do you mean pick Jessica up from school on my weeks?
Sunday, February 17, 2002
America Online: DLWRIGHT55
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2/18/021:24:24 PM Eastern Standard Time
KssLeather
DLWRIGHT55
you will have to pick her up on the weeks you have her .from school. will that be a problem for you;
Monday, February 18, 2002 America Online: DL WRIGHT55
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I verify that the statements made in the foregoing Answer to Petition For
Emergency Relief are true and correct. I understand that false statements herein are
made subject to the penalties of 18 Pa. CoSo Section 4904, relating to unsworn
falsification to authorities.
~1//~4
Da d L. Wri
Date: J - Z - 0 2-
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DAVID L. WRIGHT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
NO. 00-6799 CIVIL TERM
KIM L. WRIGHT,
Defendant
CIVIL ACTION - LAW
CUSTODY
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the petition
for Emergency Relief and March 22, 2002 Order has been served upon
the Defendant by Facsimile Transmission and by Regular United
States Mail, Postage Prepaid, on the 29th day of March, 2002. The
transmittal letter for said faxing and mailing is attached hereto,
collectively marked Exhibit "A" and made a part hereof.
Respectfully submitted,
CLIFF, ESQUIRE
e Road
Camp Hill, PA 17011
Phone: (717) 737-0100
Fax: (717) 975-0697
Supreme Court ID # 32112
Attorney for Defendant
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EXHIBIT "A"
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. DIANE G. RADCLIFF, ESQUI~ F-ll'E
Attorney at Law
3448 Trindle Road
Camp Hill, Pennsylvania 17011
Phone: (717) 737-0100
Facsimile: (717) 975-0697
March 29, 2002
Robert L. O'Brien, Esquire
17 West South.Street
Carlisle, PA 17013
RE: Wright v. Wright
Dear Rob:
I am enclosing with this letter a copy of the Petition for
Emergency Relief together with the order entered on March 22, 2002.
In accordance with the order you have seven (7) days in which to
show cause why the relief requested in the Petition should not be
granted.
Very truly yours,
DIANE G. RADCLIFF, ESQUIRE
DGR/rzg
Enclosure
~~~:~~i~~~~~i~~R~~~~~J~~~~~~,~~r~:~:
Via Fax: 249-5755 and by Mail
cc: Kim L. Wright
EXHIBIT "A"
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Diane G. Radcliff, Esquire
3448 Trindle Road
Camp Hill, PA 17011
Phone: (717) 737-0100
Fax: (717) 975-0697
FAX COVER SHEET
TO FAX NUMBER: 249-5755
March 29, 2002
To:
From:
Client/Matter:
Date:
Robert L. O'Brien, Esquire
Diane G. Radcliff, Esquire
Wright
March 29, 2002
Cover Sheet
1
1
1
20
23
March 29, 2002 letter
March 22, 2002 Order
Petition for Emergency Relief
Total Pages
ADDITIONAL COMMENTS:
Original will follow by US Mail.
IF YOU DO NOT RECEIVE ALL PAGES, PLEASE TELEPHONE US IMMEDIATELY AT (717) 737-0100
The information contained in this facsimile message is information protected by attorney-client and/or the
attorney/work product privilege. It is intended only for the use of the individual named above and the privileges
are not waived by virtue of this having been sent by facsimile. If the person actually receiving this facsimile or
any other reader of the facsimile is not the named recipient or the employee or agent responsible to deliver it to
the named recipient, any use, dissemination, distribution, or copying of the communication is strictly
prohibited. If you have received this communication in error, please immediately notifY us by telephone and
return the original message to us at the above address via Us. Postal Service.
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MESSAGE CONFIRMATION
03/29/02 11 : 09
ID=DIANE G RADCLIFF
DATE
S,R-TIME DISTANT STATION ID, MODE
PAGES RESULT
03/29
12'20" 7172495755
CALLING
23
OK
0000
03/29/02
10:54
DIANE G RADCLIFF ~ 2495755
NO.064 [;l01
Diane G. Radcliff, Esquire
3448 Trind1e Road
Camp Hill, PA 17011
Phone; (717)737-0100
Fax: (717) 975-0697
FAX COVER SHEET
TO FAX NUMBER: 249-5755
March 29, 2002
To:
From:
ClientJMatter:
Date:
Robert L. O'Brien, Esquire
Diane G. Radclift~ Esquire
Wright
March 29, 2002
I MESSACE OR COMMENTS
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DAVID L. WRIGHT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
00-6799 CIVIL TERM
KIM L. WRIGHT,
Defendant
IN CUSTODY
IN RE: MODIFICATIONS TO PRIOR ORDER
ORDER OF COURT
AND NOW, this 30th day of May, 2002, upon
agreement of the parties as announced in open court and in their
presence, the order of November 7, 2000, is modified as follows:
1. Paragraph 3 of the November 7, 2000, order
is modified to delete the reference that the shared physical
custody will commence once father relocates his residence to the
Middletown area since he has already relocated.
2. The second paragraph of paragraph 3 of the
order is deleted to the extent it requires father to first
contact mother before securing alternative baby-sitting
arrangements.
Father shall be free to provide those third
party arrangements without first providing mother with that
opportunity.
3. The second paragraph of paragraph 3 of the
order is also modified to indicate that the child shall have the
right to determine whether or not she attends any car shows or
all of them, and will have such determination made by
communication directly between father and child.
4. B of the order pertaining to Thanksgiving
shall be modified to reflect that the Thanksgiving Holiday is
going to be divided into two segments.
Segment A shall be the
period of time from Wednesday before Thanksgiving at 6:00 p.m.
through Thanksgiving Day at 5:00 p.m.
Segment B shall be from
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Thanksgiving Day at 5:00 p.m. through the Friday after
Thanksgiving at 6:00 p.m.
In even numbered years mother shall have segment
A and father shall have segment B.
In odd numbered years
father shall have segment A and mother shall have segment B.
5. The parties shall participate in counseling
to assist them with improving communications and dealing with
other parenting issues.
The counselor shall be selected upon
mutual agreement of the parties, considering any restrictions or
conditions contained in father's insurance.
The counseling selection shall be made within 30
days of the date of this order, and arrangements for the first
appointment shall be made as soon thereafter as can be done in
cooperation with the counselor.
By the Court,
o//,d
Hess, J.
Robert O'Brien, Esquire
For the Plaintiff
Diane Radcliff, Esquire
For the Defendant
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