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Home My WebLink About00-06882 -'~-"~~ -' -""" ll.liI~ '~},: BRIAN R, ROWE PLAINTIFF V. JEANNETTE M, GRIBLEY DEFENDANT IN TIIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-6882 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 13th day of October, 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Melissa F. Greevy, Esq. . the conciliator, at 214 Senate Avenne, Suite 105, Camp Hill, FA 17011 on the 14th day of November ,2000, at ~15 a.m. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to 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 grOlUlds for entry of a temporary or permanent order. FOR TIIE COURT, By: /s/ Melissa P. Greevy. Es~ Custody Conciliator 61 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court, You must attend the scheduled conference or hearing, YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ,1 f,'> "',.,..,-"""", ~I~'~" I' - {1;"' V" n~'~ -.. "IL! f (: v . ,j .'i': :;,] Cu"'" 1\1)'.) '-.', "',..~,si"'iL/)~,'\j,' j (,,,., t r::Nt,l~i/"Ll ,;.,c,'UN'-'( 'VII ""1\'1' ' ,,) 'iJ " J~/v<a;J Ii/. ~ ~ ~)4~ J()-4.aJ ~ ~ ~ ~ J~'/v'~~~ 2S4~ " ~ 1-: , ,.,_~.<..,,~EfWJ'~ffi:; _ ,_,_ ':-:;" ,...t;!1!lj.,*,p,:!iI!"li;'irHW!;mc~~I~!!1'"UW'l~;!ir'i~,,~-,;?mJSi'~. , "_'f",,~mI ~ lOU.. "cH r ","--.;1.; -"-_,- ~- ,~-,,,,,--,-<>,~I ;,,> :c:~,,' "_-_'_-:cr_ ,"""= "{;j fl\cust\rowecust.ord\10-00 . ," (j OCT 1 0 200n~ BRIAN R. ROWE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. tt) -ffrf:J 6io; I JEANNETTE M. GRIBLEY, Defendant CIVIL ACTION - 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 , ___.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 YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 II I ,,,-I.;; ','.'~ -'--<'-;"-0-' ,; .- . -,!~:> :0" "'-',,,,,';-:i~::{,,<--,-_, !, --,' "rIIIlIIiifmi! fl\cust\rowecust.not\lO-OO BRIAN R. ROWE, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. fHJ-t.,UZ ~ r~ JEANNETTE M. GRIBLEY, Defendant CIVIL ACTION - CUSTODY NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following complaint, you must take action within twenty (20) days after the complaint and notice are served, by entering a written appearance personally or by attorney and filing in writ~ng with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed against you and a judgment may be entered against you by the Court without further notice for any money claimed in the com- plaint or for any other claim or relief requested by the plaintiff. You may lose money or property, or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 :ll I c-l,_~"- - -',. ". _ :0', - ".:,>>'..1, h"-,-,"-,>'~_:>""j.', . ---..,;.,L'-",' ""'" '-, "~j fl\cust\rowecust.pet\10-00 BRIAN R. ROWE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. {)O, ~ Pi'.2. Cw..-e -{ ~ v. JEANNETTE M. GRIBLEY, Defendant CIVIL ACTION - CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Brian R. Rowe, an adult individual, residing at 513 Terrace Drive, New Cumberland, Cumberland County, Pennsylvania 17070. 2. The defendant is Jeannette M. Gribley, an adult individual, residing at 700 Nailor Drive, Apt. 103, Camp Hill, Cumberland County, Pennsylvania, 17011. 3. Plaintiff seeks shared legal custody and partial physical custody and visitation rights of Ashleigh Elizabeth Nicole Rowe, who resides with the Defendant, her mother. Ashleigh is eight (8) years and ten (10) months of age, having been born on December 3, 1991. I' I. I: The child was born during the marriage and the parties are now divorced. The child is presently in the custody of the defendant, Jeannette M. Gribley. -1- J .,1,,- i ,'" I '--);I",,:-,-,~''- - '_..,,~_ -",__ {-~ _;'';''_,C"..___ .. During the past five years, the child has resided with the following persons and at the following addresses: NAME ADDRESS DATES Plaintiff 700 Nailor Drive, Apt. 103 Since 10/95 Camp Hill, PA Plaintiff and Defendant 5086 Lilac Lane 6/91-10/95 Harrisburg, PA The mother of the child is Jeannette M. Gribley, currently residing at 700 Nailor Drive, Apt. 103, Camp Hill, Cumberland County, Pennsylvania, 17011. The plaintiff and the defendant were married on October 20, 1990 and have been divorced since January, 1997. The father of the child is Brian R. Rowe, currently residing at 513 Terrace Drive, New Cumberland, Cumberland County, Pennsylvania, 17070. He is divorced from the defendant. 4. The relationship of plaintiff to the child is that of father. The plaintiff currently resides with the following persons: NAME RELATIONSHIP Elizabeth Kohr Aunt -2- -11, .'-- ,.;- Ie -~,"~ -. ~O_ --.,,". J_' ~ -~~_ ',: -. .'.~'_'-' '-. \.;"/,7 .0 _ . "- .~- '->-. -.-., .-, - "~;;: -;"'''1'1 5. The relationship of defendant to the child is that of mother. The defendant currently resides with the following persons: NAME RELATIONSHIP Defendant and minor child mother and daughter 6. Plaintiff has no information of any custody proceeding concerning the child pending in a Court of this Commonwealth. Plaintiff does not know of a person not a party to the proceed- ings 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 it would allow the child an opportunity to spend time with the child's father consistent with a visitation schedule as requested by the plaintiff which will serve to promote and foster a loving and caring relationship between father and daughter. 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. 9. Plaintiff, the father of the minor child, requests the following custody and visitation schedule: -3- 1llf1~ -1\1,-, ""I - - ',-, --..~ - "'>,< --'> --.- " '"" ",-,--~-.~ < ,:,,-,'- ", (-,--,_:,~ 'i _ ";U'j'i~ " Mother and Father shall rotate every other weekend with the period of visitation beginning on Friday night at 7:30 p.m. and ending on Sunday at 6:00 p.m. Father shall have custody two (2) nights during the week in which the upcoming weekend is not his weekend. Mother and Father shall rotate every other holiday, those holidays being New Year's Eve, Easter, Memorial Day, Fourth of July, Labor Day, Thanksgiving, and Christmas Eve and Christmas Day. Either party may take the child out of state during each of their periods of custody so long as the other party is informed in a timely manner. Father shall have the minor child for at least two weeks of vacation during the school summer vacation. These two weeks may be consecutive. Father agrees to let mother know by June 1 of each year which two weeks he would like to have. If he has notified her of which weeks he would like to have the child, then the mother shall have first pick of the weeks for her vacation. If the two weeks interrupts the weekend rotation of the regular periods of custody, the parties agree to accommodate the other so as to return the rotation to a normal schedule and to allow the other party to make up for any lost weekends with their child. Christmas Eve and Christmas Day shall be rotated every other year with the mother enjoying the even numbered years and the father having -4- Ii li - ~,I "' -~- - - _ 0.'_ ~ _ __d , ~;' .' I I:F' .< '~ '--:i J,'i~,,2>--;,,:;,_,,;," "';c~ _< 'd-'~" ,~",,'__,._" "Ii:,-t ~ his custody during the odd numbered years. For the year 2000, father would like to have Christmas Eve until 6:00 p.m. at which time he will return the child to the mother. Mother agrees to be as flexible as possible during the Christmas holiday so as to allow the child to see as much as her father as possible when school is out of session. WHEREFORE, plaintiff requests the court to grant him partial physical custody of the child and joint legal custody of the child with the child's mother as per the relief requested. / E -5- I. II - II- .-",; .1'. ,-,,:_;,:-t,:,.--c,. ""'",',. ,'.' " --'"--';".,'I~'-", ,.,..-,,,,.kO,,2----":,,;.., "'_--;':"_':i._ Idllll~! fl \mis\l-verifi VERIFICATION BRIAN R. ROWE, states that he is the Plaintiff named in the foregoing instrument and that he is acquainted with the facts set forth in the foregoing instrument; that the same are true and correct to the best of his knowledge, information and belief; and that this statement is made subject to the penalties of 18 Pa. C.S.A. ~ 4904 relating to unsworn falsification to authorities. ;f/~ /BRIAN R. ROWE Date: /1)/3/00 . I'." .1 ,1.-"-. [-- ~ 'f~, ... DEe 1 4 2000 . BRIAN R. ROWE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-6882 vs. JEANETTE M. GRIBLEY, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this l ~ day of December, 2000, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1, Legal Custody: The parties, Brian R. Rowe and Jeanette M, Gribley, shall have shared legal custody of the minor Child, Ashleigh Elizabeth Nicole Rowe, born December 3, 1991. 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, Pursuant to the terms of Pa.C,S. S 5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2, Physical Custody: Mother shall have primary physical custody subject to Father's rights of partial physical custody which shall be arranged as follows: A. Weekends: Father shall have a gradually-increasing schedule of partial physical custody, Effective December 16, 2000, Father shall have custody on alternating Saturdays from 11 :00 a,m, until 5:00 p.m. and alternating Sundays of that same weekend from 1 :00 p,m. until 7:00 p,m. This schedule shall continue through the months of December 2000 and January 2001. To commence February 10, 2001, Father shall have . alternating weekends from Saturday at 8:00 a.m. until Sunday at Noon, To commence March 9, 2001, Father shall have alternating weekends from Friday at 7:00 p,m, until Sunday at Noon, B, Weekday Visits: To commence February 15, 2001, and February 20, 2001, Father shall have physical custody from 6:30 p,m, until 8:30 p.m, on the Tuesday preceding his weekend and the Thursday following his custodial weekend, 'M ,..'I, ! ~. ~ ~- -- ~ .. No, 00-6882 3. Holidays: A. Father shall have custody on Father's Day from Noon to 7:00 p.m, Mother shall have custody on Mother's Day from Noon to 7:00 p,m. 8, Father shall have physical custody for the following holidays: Thanksgiving, Christmas, Independence Day, Memorial Day and Labor Day, In the event that Father's custodial weekend coincides with a Monday holiday, Father shall return the Child on the Monday holiday at 7:00 p.m" unless otherwise agreed, C, Mother shall have physical custody for periods of time associated with her religious meetings and observances, Mother shall provide Father with a schedule of her religious meetings as they become available to her, approximately 3 months in advance. Father shall be entitled to compensatory time in the event that his weekend schedule is modified to accommodate Mother's religious observances, It is expected that Father's compensatory time shall take place within a week of the modified schedule. However, in no event shall Father's compensatory time be scheduled more than 30 days following the modified schedule, The holiday schedule shall take precedence over the regular custody schedule. 4, Vacation: Each party shall be entitled to a 7-day period of uninterrupted vacation time upon a 30-day notice to the other party. Vacation may be combined with the party's custodial weekend. In the event of a conflict in scheduling vacation, the party first providing written notice to the other parent shall have the right to choose their choice of vacation custody time. 5, Transportation: Father shall provide all transportation incident to periods of custody with the following exception: in the event that Father's period of partial custody is interrupted by Mother's religious observances or meetings, Mother shall provide all transportation for those changes in Father's periods of custody. 6, The parties shall not consume alcohol on any days when they shall have physical custody ofthe minor Child. 7, This Order is temporary in nature. The parties, by mutual agreement, may modify the terms of this Order, In the event that the parties cannot agree, the terms of this Order shall control. .~ ~"'- ~r""c ~- ';0'1 -'---_m__"__ ,'" "~,i .. No, 00-6882 BY THE COURT~----- //-- J, Dis!: Robert 8. Macintyre, Esquire, 6000 Linglestown Road, PO Box 6656, Harrisburg, PA 171 Elizabeth Stone, Esquire, PO Box E, New Cumberland, PA 17070 t"P~u, 1fF21 I;{ - ).!5-{)O R)(.j .. "_. ~ -- . It, . _w I^ ~ '"-. ""'"" .<,,~ ..c c:. ~:f~~L:~D'-{)!_::~i,0"~'r^ ,,",-\\) .,.lJiY fir! n~0 I"' '~u,::. I J I~;'j 8: 50 CUivIF~ '" "'n . '-''-['I...'''\;LJ )~'(\' PENNSYLVANlAUN1Y - ~___'''l'''I,~'~~I~!'J!l)f$$lll>-m~~"~''7'_''1'''''"~~il~~. .~ "~M!IlJ c - ..~- ,- . +0 ,-.' ,-~ ,~ , ,- -',,~u BRIAN R. ROWE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-6882 vs. JEANETTE M. GRIBLEY, Defendant CIVIL ACTION - LAW CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915,3-8, the undersigned Custody Conciliator submits the following report: 1, The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY 01:: Ashleigh Elizabeth Nicole Rowe December 3,1991 Mother 2, A Custody Conciliation Conference was held on December 11, 2000, with the following individuals in attendance: the Father, Brian R. Rowe, and his counsel, Elizabeth Stone, Esquire; the Mother, Jeanette M. Gribley, and her counsel, Robert B, Macintyre, Esquire, 3, The parties reached an agreement in the form of an Order as attached, /DL/J;J /JJrtnJ Date Melissa Peel Greevy, Esquir Custody Conciliator