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HomeMy WebLinkAbout00-07896 ,.-. \ THOMAS R. FORD, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUiJiBERLAND COUNTY, PENNSYLVANIA V. MARY C. FORD, DEFENDANT 00-7896 CIVIL TERM ORDER OF COURT AND NOW, this-9-\t.. day of November, 2000, a hearing on the within petition for emergency relief shall be conducted in Courtroom Number 4, Cumberland County Courthouse, Carlisle, Pennsylvania, Monday, November 27, 2000, at 2:30 p,m. ///} ./ /J/ By th~Court, // /;7 James D. Flower, Jr., EsqUire For Plaintiff :saa L . maJJ. ap..u.o' . \ 1'-f.OO R~ ~'.' ,_,w ,.."~-" _, ,_~o, "~ ,_."'.1, _, .,.__ T"I _ ,__H ~_ " ,",'" -. - ,~~~'oll~"l;01~_';~&~i&i>j;;fu_*,',"I,",~!j,Mficl.@;;"r..l>,~ru;"'J,"'.",'ilH~~iliill~lillIlilIii.lIi-, )W~ ,.. ..... .._ _. I ~~,~~ = _ 0' ^ .~ _ _,~"",~~"",,,,~~,,,,, "'_~ ~ w_ - '~~I!i:'lIIIiiIIl~~ PLED-OFFICE I"'''''''T''R\! OF . :',,,I!-.l\..~ ,,"\ I "0 t.ln\l -A 1.".1"'1 3: 15 u M~)!<"..J I CUMBdili'ND COUN1Y PENNSYLVANIA , ;1 it ;1 Ii II i~ p 1~ I" if il j~ ii L ;~ 'i i" ,i " I,! ii, II 1,1 J il !~ il II S~~WER ~ &UNlJSAY II ~.lAW I; 26 W. High street Ii Carlisle, PA i;' I;' i~' i:< :r " ., 'f "',- 'I' '_0" ,-_"_"_ !! I THOMAS R. FORD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 00- -r'?q~ Ct V; ( : IN CUSTODY v. MARY C. FORD, Defendant ORDER AND NOW, this day of ,2000, upon consideration of Plaintiffs Petition for Emergency Relief in the nature of a temporary order, primary physical custody of the children in question, Thomas R. Ford, age 16, Christopher Ford, age 16 and Cory J. Ford, age 12, is granted to Plaintiff subject to partial physical custody of Defendant on alternating weekends and half days on holidays, specifically to include, but not limited to, Thanksgiving, Christmas and New Year's, This is a temporary Order that shall remain in effect until further Order of Court. BY THE COURT: J. SAIDIS S~RDWER &UNIJSAY MIOIlNE\'SoAT'UW UW.Blghstroet Carlisle,PA I! THOMAS R. FORD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW :NO. v. MARY C. FORD, Defendant : IN CUSTODY PETITION FOR EMERGENCY RELIEF IN THE NATURE OF A TEMPORARY ORDER AND NOW comes Plaintiff, Thomas R. Ford, by and through his attorneys, Said is, Shuff, Flower & Lindsay and Petitions as follows: 1. Contemporaneously with this Petition Plaintiff has filed a Complaint for Custody of his two 16 year old sons, Thomas R. Ford, Christopher Ford, and his 12 year old son, Corey J. Ford. There is no formal Court Order awarding custody of the children in question. 2. The children in question, Thomas R. Ford, age 16, Christopher Ford, age 16, and Cory J. Ford, age 12, have resided with their father, Thomas R. Ford, since 1991, at which time they were found living with their mother in deplorable conditions. Their mother, Mary C. Ford, has since then seen them for about a month during summer vacation and every other weekend during school and the parties have divided custody on the holidays. 3. Defendant, Mary C. Ford, induced Christopher to leave and come to live with her the last week of August 2000, and induced Thomas R. Ford, to leave home to live with her in October 2000. Jl i :1 ':1 J j j i j 'J I I~ :~ U W. High street CarlisIe,PA ,~ , '<! II 4. Thomas R. Ford and Christopher Ford attend the South Middleton School District and are in the 10th grade attending Boiling Springs High School and Cumberland-Perry Vo-Tech School. A move to their mother's home would require them to shift to the Carlisle Area School District in the middle of the semester. The Plaintiff is concerned that the children's mother is not enforcing rules in the home or supervising the children appropriately. 5. Defendant has attempted to circumvent a long-standing custody arrangement without a Court Order. Petitioner requests a temporary Order restoring the status quo pending the custody conciliation and/or hearing. 6. The undersigned is not aware of any attorney presently representing Defendant in this matter, but is advised that she may have consulted with the Domestic Law Clinic of the Dickinson School of Law. WHEREFORE, Petitioner prays this Honorable Court to enter a temporary Order granting primary physical custody to Plaintiff pending a custody conciliation. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Attorney for Plaintiff Date: \\ -I ~(')() , \;- \. 2 "-'c.' r I SAIDIS Ii S~rnJ60~ ii ~.IAW !I 26W.Bighstreet :i Carlisle, PA !; " " " ;'i :1 , , " ~1 i :1 'I ,I ,I ,:;1 II 1- VERIFICATION I verify that the statements made in this petition for Emergency Relief 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. Dated: -:/k~ R :ji1m~ Tnomas R. Ford ~----- THOMAS R. FORD PLAINTIFF V. MARY C. FORD DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-7896 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 9th day of November, 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Snnday, Esq. , the conciliator, at 39 West Main Street, Mechanicsbnrg, PA 17055 on the 28th day of November ,2000, at --.!!:OO a.m. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to defme and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: Isl Daw . Sunda Es 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 '0 ,~ , r~ -, ',!iil:1i1.11'.&l'..~~j""""~~B'I"";'.<!"""""1";:':-i'~"<""'~l.LIlli._W:,,,.,,.;.,4)'t.',ce',.,_._'_" ""-''''~'''-'-'c,''''' "-,,<,,.d /h3.m 1/.I.J.a;J /I- / J .otJ -,;':."'~;";-,i_'."',"~;~~~--'<il~*,,~~L~"'~.:o;..~~ . ~_l_ ~:-\I.c:C)'-O:~T\CF ,,- --.' c' '-'I-._;\-,(JTr\R\: \"0 "'''' 1" 0'1-' ,. ,) Q j! \.,;U;' 0 l : 1 ~ ., ~ CUMBthu\:\Jl) COUNTY PENNSYLVANIA &~~q44~~ '7!~ /n;:A/~ ~. ~ /t<d:Jl/~ 4~/fr ~J;;,~ ',,~, )..,;:,c ;:)1, '.'.". ~,Jjr. _.;IOl ,'"n,:t,",^,"_,,,",,,,~ ",:::;:,,_ ,;"C", _~, ,," , _. ,0 ....",___ ~~ "~ -~> " - ~ '!LlkiIilIlll~~ ~", to! I :i 'I , ,I I I , j ~ 'E " , il II 'I l' d {i '~l Ii 'Ii {j ':~: j!i " " ,,' \~ .ll~ .1' ' &UNIJ"n' ~I moRNEYS-m;~ ~!j 26 w. High sbeet I! Carlisle, P,\ ~:, ,'::1 " )Ii '::i ~i ,;;I " 'ii ;~:J '! 'I '" ~:i ;.:,:' !l THOMAS R. FORD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW ~NO. 60- 71>9ro C;o~1 : IN CUSTODY MARY C. FORD, Defendant 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 o'clock _.m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older shall also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: , Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 >,'F' , 'ii " .iI 11 i] :~ :~ ll..' j: j" I.; Iii H 1'1 i~ o ! . SAIDIS l~ S~RDWER II &UNIJSAY L1 A11OJlNEYSoNl'IAW ~'! ;; UW.BIgh_t 11 carlisIe,PA >i ':1 II THOMAS R. FORD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. v. MARY C. FORD, Defendant : IN CUSTODY ORDER OF COURT You, Mary C. Ford, Defendant, have been sued in court to obtain custody, of the children: Thomas R. Ford, Christopher Ford and Cory J. Ford You are ordered to appear in person at Court Room No. of the Cumberland County Courthouse, Carlisle, Pennsylvania, on the day of 2000, at o'clock _.m., for a hearing. You are further ordered to bring with you the children: Thomas R. Ford and Christopher Ford. If you fail to appear as provided by this order or to bring the children, an order for custody, partial custody or visitation may be entered against you or the court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 BY THE COURT: J. I i , 'I , ~J. ;1 ;1 ~ ,1 l , 'I i1 'i !,) ~ i SAIDIS '4i SHUFF FLOWER Ii :~~ ~.i &UNIJSAY " MI"J"'''~.LAW ~i , U W. High street CarJisle, PA , ;:1 I! THOMAS R. FORD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION. LAW :NO. v. MARY C. FORD, Defendant : IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Thomas R. Ford, residing at 167 Old Town Road, Gardners, Cumberland County, Pennsylvania 17324. 2. The Defendant is Mary C. Ford, residing at 147 Mulberry Avenue, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks custody of the following children: Name Present Residence Aqe Thomas R. Ford 147 Mulberry Avenue Carlisle, PA 17013 16 Christopher Ford 16 147 Mulberry Avenue Carlisle, PA 17013 Cory J. Ford 167 Old Town Road 12 Gardners, PA 17324 4. The children were not born out of wedlock. 5. Thomas R. Ford and Christopher Ford are presently in the custody of Mary C. Ford, who resides at 147 Mulberry Avenue, Carlisle, Pennsylvania 17013. Cory J. , J } :1 I :1 '" "if " ~~ ; 1;1 !-:i ~i '1 -~ ;i ~j " is; ~ :r: ;?i r k: \)j: ~i ~i " 'i! U w. High street carlisIe,PA ,.; ij ". :;:i )i i :,! -:~:! II Ford is presently in the custody of Thomas R. Ford, who resides at 167 Old Town Road, Gardners, Cumberland County, Pennsylvania 17324. 6. During the past five years, the children have resided with the following persons and at the following addresses: As of 1995, the children in question resided with Thomas R. Ford and Wendy S. Arnold-Ford, as well as her children, Roger Neidigh and Joseph Neidigh, at 98 Fairview Street, Lot 3, Carlisle, Pennsylvania. All of these individuals then moved to 167 Old Town Road, Gardners, Pennsylvania 17324, in 1997, where they resided together until the last week of August 2000, when Christopher left to live with his mother, Mary C. Ford, at 147 Mulberry Avenue, Carlisle, Pennsylvania and mid-October 2000, when Thomas left to live with his mother at 147 Mulberry Avenue, Carlisle, Pennsylvania. Cory J. Ford, age 12, continues to live with Thomas R. Ford and Wendy S. Ford. Others residing in the household of Plaintiff Thomas R. Ford are his wife, Wendy S. Arnold and her children, Roger Neidigh, age 14 and Joseph Neidigh, age 11. 7. The mother of the children is Mary C. Ford; currently residing at 147 Mulberry Avenue, Carlisle, Pennsylvania 17013. 8. She is married. 9. The father of the children is Thomas R. Ford, residing at 167 Old Town Road, Gardners, Pennsylvania 17324. 10. He is married. ~L J j 1 J ;j ~ Ij Ii ~ [1 ;1 Iii ?:. J u i;! ;,') :Y] ','1: ls~~ ~I !11 ATmIINE\'Soj(f.IAW UW.Blghstroet carlisle,PA :1: ;.i ::\1 '1 _.d , :'j >' :J rl 11. The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with the following persons: Name Relationship Wendy S. Arnold-Ford Wife Roger Neidigh Step-child Joseph Neidigh Step-child Cory J. Ford Son 12. The relationship of Defendant to the children is that of mother. The Defendant currently resides with the following persons: Name Relationship Christopher Ford son Thomas R. Ford son Michelle Nicole Ford daughter 13. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 14. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 15. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. SAIDIS SllU!'1 !!OWER . &UNUSAY ATImINEk~""'IAW 26 W. HIgh street Carlisle, PA I! 16. The best interest and permanent welfare of the children will be served by granting the relief requested because: a. Plaintiff has had custody of the children continuously from 1991 to very recently and is best able to care for them. b. Christopher Ford and Thomas R. Ford have been attending school in the South Middleton School District and would be required to change school districts in the middle of the semester if custody is granted to the mother and their individual educational programs will be disrupted by the change. c. The children's mother is not providing appropriate supervision or enforcing rules in the household. 17. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. No other persons are known to have or claim a right to custody or visitation of the children. WHEREFORE, Plaintiff requests the court to grant custody of the children to him. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Plaintiff , '-1 q 'I I '~ ';'j :j J ;1 ~ ') -:1 -I \1 J I SAIDIS ',.1 S~rnJ60~ , A11OIlNIl\'SoM.lAW .~ , :(. ,I uw.Hlghstroet Carlisle,PA 'J , , ~'i 1 ;~i II VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: -;4,tYMM R. ~fijJ Thomas R. Ford THOMAS R FORD, PLAINTIFF V. MARY C. FORD, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-7896 CIVIL TERM ORDER OF COURT '2.'\ AND NOW, this day of November, 2000, a hearing and disposition on the within petition for emergency relief is continued until the court receives a report from the custody conciliator scheduled to hear the case tomorrow. James D. Flower, Jr., Esquire For Plaintiff Teri Henning, Esquire Supervising Attorney Kim Sebring Student Intern Family Law Clinic For Defendant :saa '<"" ,/ - ,c' " -- ~. ~. ,", / By the/C"Ourt, /" [crplli> II -;I. <g-()O RJ{.s ..- "" I_-~~l!illl\!~~_ ,1lfO~r~ " ""'w' c C :;;:,.- 23P? >::::j-:'-:' O:j> -.,- ~~t:_, <_.,"j ::r;:r" --.:; > II lilt - i',) I::) ~ -~-) ~_1) co, ~~ _,~~~!:l!I''''''WO!I;:'f'N~~:1!~''''~'''fk!ll!<W1~'''''Jfl1_~l_!f.l>'~*''''~I'<,I~ ~i "'?""= e 1l!fIJ\f THOMAS R. FORD, : IN THE OOURT OF OOMMON PLEAS OF Plaintiff . CUMBERLAND OOUNTY, PENNSYLVANIA . : vs. . NO. 00-7896 CIVIL TERM . : MARY C. FORD, : CIVIL ACTION - LAW Defendant . IN CUSTODY . AND NOW, this ~ consideration of the attached and directed as follows: ORDER OF <XXlRT day oc~ CUstody Conci iation 1:\:, , 2000, upon it is ordered 1. The Father, Thomas R. Ford, and the Mother, Mary C. Ford, shall have shared legal custody of Thomas R. Ford, born March 18, 1984, Christopher Ford, born March 18, 1984, and cory J. Ford, born October 9, 1988. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 3. Pending further order of Court or agreement of the parties, the Father shall have primary physical custody of the parties' son, Cory, and the Mother shall have primary physical custody of the parties' sons, Thomas and Christopher. 4. The parties shall alternate having custody of all three Children together on weekends, beginning with the Father having custody of the Children on Friday, December I, 2000. The Father's periods of weekend custody Shall run from Friday after school, when the Children shall ride the bus to the Father's residence, through the following Monday morning when the Children shall ride the bus back to school. The Mother' s periods of weekend custody shall run from Friday at 4:30 p.m. when the Father shall transport Cory to the Mother's residence, through Sunday at 6:00 p.m., when the Mother shall return Cory to the Father's residence. 5. Over the Christmas holiday in 2000, the Mother shall retain custody of the Children after her regular period of alternating weekend custody on the weekend before Christmas, through Christmas Day at 12:00 noon. The Father shall have custody of the Children for the remainder of Christmas Day beginning at 12:00 noon and the parties shall equally share having custody of all three Children during the remainder of the Christmas school break, with the specific times and dates for exchanges to be arranged by agreement between the parties. 6. Children holidays The parties shall share over the Christmas holiday as arranged by agreement. or alternate having custody of the in future years and on the remaining I'",.. ,~ """'1 , 7. During the sumtner school break each year, the Father shall have custody of all three Children for one full month and the Mother shall have custody of all three Children for one full month. For the remainder of the summer, the parties shall have custody of the Children in accordance with the regular school year schedule with alternating periods of weekend custody for all three Children, unless otherwise agreed between the parties. 8. The parties acknowledge that it is necessary to their Children's best interests that the Children remain enrolled in their =rent school district. The Mother agrees to continue her efforts to transfer her residence to the South Middleton School District. 9. The parties agree that it is necessary to the Children's best interests that the parties communicate directly with each other, without interference by third parties, with regard to the custody arrangements and any issues which arise concerning the Children. 10. The parties agree to cooperate in obtaining counseling for the Children. The parties shall follow the recommendations of the counselor with respect to expanding the counseling to include additional family members. 11. The parties and their counsel shall attend a second Custody Conciliation Conference in the office of the Conciliator, Dawn S. Sunday, on January 30, 2001, at 9:30 a.m. 12. 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 mutu consent, the terms of this Order shall control. cc: James D. Flower, Jr., Esquire - COunsel for Father Kim Sebring and Teri H. Henning, Esquire - Counsel for Mother / '1'1( '_0_ '" . . , ),l~~il~illili:&"o~<~~<w~,,,,,_~~,,,,.,",,,~_<!j!"i,"!ll,'~l:O;"":'i-"-'["':,f",,,'?-";';"G':;J"""""",,~l";'>''-'_,''~I'd'''.i'I<'M<MO'~~lti!ll'~'W'1~~ili'<>",j,~IMl,~,Wi4lIj~inj'liI!l"""Y--'--',jtj" Il~ .~ ;R~ f1J ;::..~ ;j;:Ci l:.~' ~. ~~ ~ .f:- Co c::. fiq C"") I .r::- :.;:! ,,,:~ ::u r-' ,.~I~m -i.J'"' {'" r _-~C ;J;;-r-i v='"' a~ ~ ~ ~ ."C;1,j'k,.J.LW! ~LJ!,.:j,J,l~l\!J!I.lJU.1'!L . ",.". , ~,,' .,,,"',....,,,.'... , ~ THOMAS R. FORD, : IN THE COURT OF COMMON PLEAS OF plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. . NO. 00-7896 CIVIL TERM . : MARY C. FORD, . CIVIL ACTION - LAW . Defendant . IN CUSTODY . PRIOR JUDGE: Edgar B. Bayley CUSTODY COOCILIATIOO SUMMARY REPORT IN ACOJRDANCE WITH CUMBERLAND <XXJm'Y RIlLE OF CIVIL PROCIIDORE 1915.3-8, the undersigned CUstody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CIJS'lWY OF Thomas R. Ford Christopher Ford Cory J. Ford March 18, 1984 March 18, 1984 October 9, 1988 Mother Mother Father 2. A Conciliation Conference was held on November 28, 2000, with the following individuals in attendance: The Father, Thomas R. Ford, with his counsel, James D. Flower, Jr., Esquire, and the Mother, Mary C. Ford, with her counsel, Kim Sebring and Teri H. Henning, Esquire. Due to the specific circumstances of this case, the Conciliator spoke separately with Thomas Ford, age 16, Christopher Ford, age 16, and Michelle Ford, (adult sister), age 19, with counsel for both parties present at all times. 3. To their credit, the parties were able to establish custody arrangements by agreement at the Conference, at least through the end of January when an additional Conciliation Conference is scheduled to review the situation. It is expected that, after following the custody schedule set forth in the agreed order through January, the parties will be able to improve their communications and make any necessary adjustments to the schedule without the additional Conference. 4. The parties agreed to entry of an order in the form as attached. f'JliMrNbeA cJ9j d&ti) t2,,~ Dawn S. Sunday, Esquire CUstody Conciliator Date I.f " ~ . " .>, ""1'"1'1 v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION - LAW IN CUSTODY NO. 2000-7896 PRAECIPE TO ENTER APPEARANCE THOMAS R. FORD, PLAINTIFF MARY C. FORD, DEFENDANT To the Prothonotary: Please enter the appearance ofthe Family Law Clinic on behalf of Mary C. Ford, the Defendant in the above captioned matter. November 21,2000 K~A S ~ ' Kimberly A. Seb . ~ Certified Legal Intem ~~.~S k/- THOMAS M. PLACE Supervising Attorney TERI HENNING Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 717/243-3639 :-i'",~,,,,,, '_," ''''."'f,r'",_''~'',,. ,_''''M, "'I_",,\^;'_,~,V_<'_~ "'_'.__ ," ~__';"p _"_~~" 'r,r_,.., ..___~,_," ^ ,",,,,.,t-.' .y. "".--" , " ~r__. _~, '1 ., _" ~ W" """ ~. ,-~ ^. ,,~ ".. "'~"".~"~" ,"'~..~~"' n T nriT' (') ~~~ ~ C,:) -" " 0-' " rr-: ~2 , :'^,,) , ~~! 1'_' .. ~~ , ,~ ~'-" (-" )> E~ CO .c:::' ,:.,"1 ~~ -; -< .. -' ,. -< -,<" ~..,.,.". ~,~,"""",.T,!l' _~~,,~,..~ "~_.!JIfiJ'll~~t1"1i~~I\o1ll'!'Mr,,",,~~II!~~_-:~ " ~_~JlJl'IWW<j -, .. v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY NO. 2000-7896 THOMAS R. FORD, PLAINTIFF MARY C. FORD, DEFENDANT CERTIFICATE OF SERVICE I, Kimberly A. Sebring, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving a true and correct copy of Praecipe to Enter Appearance on James Flower, attorney for Thomas R. Ford, of Saidis, Shuff, Flower and Lindsay, at 26 West High Street, Carlisle, Pennsylvania, 17013, by depositing a copy of the same in the United States mail, First Class, postage prepaid, this 22nd day of November, 2000. THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 ;';.~ '~"-', '-''Z~ -,.,.". L-"",,--.B,'0 I' - '"'"'n' ";'Y__~_, -" > . -'['T-", ~o ,_ <" ~_"_"__" _I"~' _,~_ '.-. -",'-' ,~ ;L". JII!lI~" - .~~",~ .... " ~".~,- '"~~''''' " ., .0 ...~.. ,.... 'N...~' '.~ . -~.'-11'lm( ]1 (") s:; <' rt:r~ :;:.::::; ~.)-" 2,=::" .".' ~:t-:" -~> c~- L~_ --3 -<., .,-_J """'~~~I~rll'l~Jijl-~!ilW!.~~~1II!'l '-',r, "~'"f"~ i"_:r r',_'. C(: :.11 ,--., ,. """ ",,->-(r!!j THOMAS R. FORD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : va. . NO. 00-7896 CIVIL TERM . : MARY C. FORD, : CIVIL ACTION - LAW Defendant . IN CUSTODY . ORDER OF COlJRT AND Nai, this ,:{-I-- consideration of the attached and directed as follows: day of CUstody , 2001, upon it is ordered 1. The prior Order of this Court dated December 4, 2000 is vacated and replaced with this Order. 2. The Father, Thomas R. Ford, and the Mother, Mary C. Ford, shall have shared legal custody of Thomas R. Ford, born March 18, 1984, Christopher Ford, born March 18, 1984, and Cory J. Ford, born October 9, 1988. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 3. The Father shall have primary physical custody of the Children. 4. The Mother shall have partial physical custody of the Children on alternating weekends, beginning February 2, 2001, from Friday at 4:30 p.m., when the Father shall transport the Children to the Mother's residence, through Sunday at 6:00 p.m., when the Mother shall return the Children to the Father's residence. 5. The parties shall share having custody of the Children over holidays as arranged by agreement. 6. During the summer school break each year, the Father shall have custody of all three Children for one full month and the Mother shall have custody of all three Children for one full month. For the remainder of the summer, the parties shall have custody of the Children in accordance with the regular school year schedule. 7. The parties agree to obtain counseling for the Children through pennsylvania Counseling Services. By February 12, 2001, the parties shall contact pennaylvania Counseling Services to schedule the first session. The parties shall follow the recommendations of the counselor with respect to expanding the counseling to include additional family members. 8. The parties agree that it is necessary to the Children's best interests that the parties communicate directly with each other, without interference by third parties, with regard to the custody arrangements and '.,~",!", ~ any issues which arise concerning the Children. 9. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation COnference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent I the terms of this Order shall control. cc: Edgar James D. Flower I Jr. I Esquire - Counsel steven Beell and Thomas Placey I Esquire for Father - Counsel f r Moth~y . ~ .0\ [~?-'O~o 't.{? li:,._"""",",," ,.,,_'r_ ~ J. :'~~~~&","J""&k!,~"'&i'''''cl",."~~i;,''''d,",~'",,<,j'IMl>''~'-,i;''.0J..:l'l<>'"""".U".i"'-d.,d,,,,,,,,,,.";ltj~i1o~~_~<lliiirJI.~~~$~..:Ji,,",,,ru.,,,,..,_"'''<ili1lJ~I~",W'J<l!I;ijl>l~~IlllIIYiiiII..... .~.,.- ~~- r,\ ":~-'_\.ir\C,E r' ,\ \( ,-.,j.._J,,'''''-'''':'' ,II\\; ";1,'_,.\_..,.... ("t;: ',_'I Pi\ \.;,: ?Z \)\ ft.\)-:) , .., '''J COUN1'1 C\.lM~E~NS~\)/N'l\1\ ,ljI,JUU!I,",",.. .n.._.. ,~, ~-'-.~,' ,~ "',',",'''~'''< ,~,-~~ ^,~ . THOMAS R. FORD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-7896 CIVIL TERM . . MARY C. FORD, : CIVIL ACTION - LAW Defendant : IN CUSTODY PRIOR JUDGE: Edgar B. Bayley CUSTODY CXliICILIATICN SUMMARY REPCRT IN ACCORDANCE WITH CUMBERLAND CXXlNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned CUstody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Thomas R. Ford Christopher Ford Cory J. Ford March 18, 1984 March 18, 1984 October 9, 1988 Mother Mother Father 2. A Conciliation Conference was held on January 30, 2001, with the following individuals in attendance: The Father, Thomas R. Ford, with his counsel, James D. Flower, Jr., Esquire, and the Mother, Mary C. Ford, with her counsel, Thomas Placey, Esquire and Steven Beell. 3. The parties agreed to J~ ]0 ;)00/ Date ,. entry of Dawn S. Sunday, Esqui Custody Conciliator ~, -'. ~