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HomeMy WebLinkAbout00-08052 f "..J '. " . ~~"-, -j'-- "' ,<_~ .j .-c r,-~_ , -, '" _ _ ":',l ; , f DONNA LAIRD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V CIVIL ACTION - LAW NO. 00-8052 CIVIL TERM JAMES J. BLASE, JR., and SHARON ANN SCHINER ECKERD, Defendants CUSTODY IN RE: PETITION FOR EMERGENCY RELIEF ORDER OF COURT AND NOW, this 20th day of November, 2000, the parties having appeared in open court with their counsel and reporting to the court that they have agreed to the entry of this order, we hereby order as follows: 1) Legal custody of the minor children, Crystal L. Blase, born February 10, 1988, and Scott A. Blase, born September 30, 1989, shall be shared by all three of the parties, their mother, Sharon Ann Schiner Eckerd, their father, James J. Blase, Jr., and their maternal great-aunt, Donna Laird. In the event of a medical or physical emergency, the party then having physical custody of the children is authorized to make decisions regarding the care of the children as long as they promptly report the situation to the other parties to this action as soon as practical thereafter. 2) Temporary primary physical custody of the minor children shall be with the plaintiff, Donna Laird, pending further agreement of the parties or order of this court. 3) When the mother, Sharon Ann Schiner Eckerd, relocates back to Cumberland County, and has an appropriate place to live in the East pennsboro School District and is employed, the parties expect that the custody arrangements set out in this order will change so that eventually primary ".=~-, -;_:J_, , "'''0 :_",-,.,,;---;, "'iilllmn", ) ) 00-8052 CIVIL TERM physical custody of the children will be with her. All of that, of course, depends upon the circumstances in effect at the time. And if the parties cannot agree, the court will have to resolve that matter in the future. 4) Pending further order of this court, the father and mother shall alternate periods of temporary custody on the weekends, from 5:00 p.m. on Friday until 8:00 p.m. on Sunday. The father shall commence his alternating weekends on Friday, November 24, 2000. The mother will commence her alternating weekends when she has returned to reside in the Cumberland County area, which the parties anticipate will be about December 12, 2000. 5) In addition to the above schedule, the parties may agree to additional periods of temporary custody for either of the parents, particularly in the event that the mother returns to Pennsylvania on a temporary or permanent basis prior to December 12, 2000. The Court Administrator is directed to assign this matter to a conciliator, and the parties' counsel will contact the conciliator to schedule a conference sometime in January of 2001 so that the parties have a forum to address these matters further if they have not resolved them by agreement by that time. ~ ~ DO C-~ \\; ,.~~ By the Court, ,1?J J. ~ '. . , , ," ~~~ -~ .. -"~ \':c~~~~cr}':~'{ r, Cl , .. ,- ., \:';\ ,"H '.. J ._,..\ rJ\j ,.C'\ \-";\! \---' " f\"i \"<i ,- ~\ \ "'-\, \ , ,~~ ,;,.~~~~i.\>;::~,,;,<!{;~~~l,~:: C\.J'N '';:,C\. \\~::J \ '-' ,) \'c.,"-\, ?""!...,jilllllJ,,.,.,.~~~, ~'r"", "'r'_J;R*~~~,J1_Wi!'~~~1M!,!>>n,JI ~ .. ,",. >,~; '''I, :rn,)1""rn\l\li~~l,fiL ... .::,,2 . r 00-8052 CIVIL TERM Lori K. Serratelli, Esquire For Donna Laird Samuel L. Andes, Esquire For James J. Blase, Jr. Mary Ann Murphy, Esquire Legal Services, Inc. For Sharon Ann Schiner Eckerd Court Administrator :bg I , -'~ ,;, ....."G "'"".~.- ,-.' "," . , "-F.' " ,. DONNA LAIRD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-8052 CIVIL CIVIL ACTION - LAW JAMES J. BLASE, JR., and SHARON ANN SHINER ECKERD, Defendants CUSTODY ORDER OF COURT AND NOW, this 15M day of ~~, 2000, upon consideration of the foregoing Petition for Emergency Relief, it is hereby ORDERED that a hearing is scheduled in this matter for the .;zo'1A day of '/1./V-tmiA..h)/ , 2000, at q,' 2...1 V va.. . m., in the # i , 1 Courthouse Cumberland County Courthouse, Court Room Square, Carlisle, Pennsylvania 17013. Further, it is ORDERED that the subject minor children be returned to Plaintiff's physical custody pending a hearing on the matter of custody. BY THE COURT: -;1/1 trrpJ"rl 1Y]JJJ. 11-/.5-00 RXS f II i ~ !I I! II Iii I'. " ,. I:.j,' i'I "I IV II',' l'i III i-t: :l~ I:, III :Ii iF Iii i ~.i..,:. " [' ,I, I' ! ' )~~ . r ~ ., .. '-= ,~~. 0,'" " ~ ""," "" "~r, - -,..',,'. ",-,~, ., ~~ -,-. FJd '" Qrn\'hDM~(A(Y oW;t.e.s f/-15~OD ,. I, IT "t"""'4I'if!iI!J~~.~'!,;,,.,. ~'. ~_ ,=,,.,=_;,,,,,~!!!lI:ijIWlt)1w,~!l1;W'i"'~!~~~~~<<~~"""""'~,, t- ''''~-'''~ ~ "","""".,,...- I.. , ,;- "d~__~,.1. _ _.. '>'~' ' '-., . "~ ~~i:-;~ " " , DONNA LAIRD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-8052 CIVIL CIVIL ACTION - LAW JAMES J. BLASE, JR., and SHARON ANN SCHINER ECKERD, Defendants CUSTODY PETITION FOR EMERGENCY RELIEF TO THE HONORABLE, THE JUDGES OF SAID COURT: 1. The Plaintiff is Donna Laird, who currently resides at 305 North Third Street,Summerdale, Cumberland County, Pennsylvania 17093. 2. The Defendants are James J. Blase, Jr., who currently resides at 1248 Reese Street, Harrisburg, Dauphin County, Pennsylvania 17104, and Sharon Ann Schiner Eckerd, who currently resides at 24 Canna Court, Belton, Missouri 64012. 3. On November 14, 2000, Plaintiff filed a Custody Complaint. (Attached as Exhibit "A") 4. Plaintiff seeks primary physical custody and shared legal custody of the Defendants' two minor children, Crystal L. Blase, born February 10, 1988; and Scott A. Blase, born September 30, 1989. -,,;..- = ,;"'~ ~,J ~~'~"'If"'''' 5. The children were in the custody of their great-aunt, Donna Laird, Plaintiff, who resides at 305 North Third Street, Summerdale, Cumberland County, Pennsylvania until November 9, 2000. 6. Neither Mother, Sharon Ann Schiner Eckerd, nor father, James J. Blase, Jr., has shown any interest in their children's welfare in that neither had shown any interest in having custody of Scott or Crystal. 7. Neither child wishes to reside with either of their parents. 8. On November 9, 2000, Defendant Sharon Ann Schiner Eckerd appeared at the children's school and demanded they return to Missouri with her. The children both wish to return to Plaintiff's custody and to the schools they have attended last year and this academic year. 9. Defendant Sharon Ann Schiner Eckerd has not had suitable, operational transportation to return to Missouri since November 9, 2000 and has remained in the area. 10. Defendant Sharon Ann Schiner Eckerd has kept the children out of school for the past three days, for no purposeful reason. 11. The children have a stable environment while in Plaintiff's custody. 12. Primary physical custody and shared legal custody with Plaintiff will be in the best interest of the children as evidenced by Defendants' neglect and indifference toward their children. WHEREFORE, Plaintiff respectfully prays that Your Honorable Court award primary physical custody and shared legal custody of the children to the Plaintiff and order Defendant Sharon Ann Schiner Eckerd to return the minor children to Plaintiff's custody pending a hearing on the matter of custody. Respectfully submitted, ~~;d7 Melan e L. Erb, squire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, FA 17110 (717) 540-9170 Attorney for Plaintiff ,~ , ~ '~J', ~J-_ ~~'~, .~ ~ .~ .,ii,~,. VERIFICATION I verify that the statements made in the foregoing 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. Date: ~( \0. \ou .~~ ""L ~""""~ Donna Laird ,---.t\l . ,- 0,[ -I DONNA LAIRD, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. C6 -8'c~d. Q~\i-' \ CIVIL ACTION - LAW Plaintiff vs. JAMES J. BLASE, JR., and SHARON ANN SCHINER ECKERD, Defendants CUSTODY " L; ~;-- (~,-~., -' CUSTODY COMPLAINT AND REQUEST FOR EMERGENCY RELI~ TO THE HONORABLE, THE JUDGES OF SAID COURT: ~;~C\ ~r' , )>(.c_: L"; =< ::-----' 0"'1 r".,) 1. The Plaintiff is Donna Laird, who currently resides at 305 North Third Street,Summerdale, Cumberland County, Pennsylvania 17093. 2. The Defendants are James J. Blase, Jr., who currently resides at 1248 Reese Street, Harrisburg, Dauphin County, Pennsylvania 17104, and Sharon Ann Shiner Eckerd, who currently resides at 24 Canna Court, Belton, Missouri 64012. 3. Plaintiff seeks primary physical custody and shared legal custody of the Defendants' two minor children, Crystal L. Blase, born February 10, 1988; and Scott A. Blase, born September 30, 1989. 4. The children were not born out of wedlock. 5. The children were in the custody of their great-aunt, Donna Laird, Plaintiff, who resides at 305 North Third Street, ",","'-> '~"i ~:-J ::i~ .~ ""'I' - '-"" , ~~j Ie', ,~ -, ~ ~ i , ' . , Summerdale, Cumberland County, Pennsylvania until November 9, 2000. 6. During the past five years Crystal Blase has resided with the following persons and at the following addresses: Persons Address Donna Laird Gary Schiner Scott Blase Paige Miller 305 North Third St. Summerdale, PA Sue Hutchens (aunt) 5 Marshall Drive Sharon Eckerd Tom Eckerd 803 North King St. Harrisonville, MO Dates Feb. 16, 2000 to Nov. 10, 2000 Dec. 3, 1999 to Feb. 16, 2000 1995 to Dec. 3, 1999 During the past five years Scott Blase has resided with the following persons and at the following addresses: Persons Address Donna Laird Gary Schiner Crystal Blase Paige Miller 305 North Third St. Summerdale, PA Donna Laird Gary Schiner Paige Miller 305 North Third St. Summerdale, PA Sharon Eckerd Tom Eckerd 803 N. King St. Harrisonville, MO Dates Feb. 16, 2000 to Nov. 10, 2000 Dec. 3, 1999 to Feb. 16, 2000 1995 to Dec. 3, 1999 ..- , ~- .- .-~. ~~ L . ( 7. The father of the children is James J. Blase, Jr., who currently resides at 1248 Reese Street, Harrisburg, Dauphin County, Pennsylvania. B. The mother of the children is Sharon Ann Schiner Eckerd, who currently resides at 24 Canna Court, Belton, Missouri. 9. The relationship of Plaintiff, Donna Laird, to the children is that of great aunt. The Plaintiff currently resides with Gary Shiner, her great nephew, Paige Miller, friend of Plaintiff, and the subject minor children herein. 10. The relationship of Defendant, James J. Blase, Jr., to the children is that of father. It is unknown with whom Father currently resides. The relationship of Defendant, Sharon Ann Schiner Eckerd, to the children is that of mother. Mother currently resides with Jimmy (last name unknown and relationship unknown) . 11. Plaintiff has not participated as a party, witness, or otherwise in litigation concerning the custody of the said children. 12. Plaintiff has no information of a custody proceeding concerning the children pending in a Court of this Commonwealth. .-~ <~~ ~ .-" , ,-~'" , '0' , "'&; L 1- 13. 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. 14. The best interests and permanent welfare of the children will be served by granting the relief requested because the children's mother and father have shown no interest in their children's welfare in that neither had shown any interest in having custody of Scott or Crystal. Further, neither child wishes to reside with either of their parents. However, on November 9, 2000, Defendant Sharon Ann Schiner Eckerd appeared at the children's school and demanded they return to Missouri with her. The children both wish to return to Plaintiff's custody and to the schools they have attended last year and this academic year. Primary physical custody and shared legal custody with plaintiff will be in the best interest of the children as evidenced by Defendants' neglect and indifference toward their children. 15. Each parent whose parental rights to the children has not been terminated and the person who has physical custody of the children has been named as parties to this action. WHEREFORE, Plaintiff respectfully prays that Your Honorable Court award primary physical custody and shared legal custody of . , i. . I the children to the Plaintiff and order Defendant Sharon Ann Schiner Eckerd to return the minor children to Plaintiff's custody pending a hearing on the matter of custody. Respectfully submitted, Lori Serratelli, Esquire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717)540-9170 Attorney for Plaintiff :"""'~~- " , , ~ -.' ;J:, . ' , . . L . . VERIFICATION I verify that the statements made in the foregoing 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. Date: ~\b\()'" . .~ <Z... ~~~ Donna Laird ~' ~ ~ , b ;J;;l-J DONNA LAIRD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. Ov- rrJs'.2- ~ ~ CIVIL ACTION - LAW JAMES J. BLASE, JR., and SHARON ANN SCHINER ECKERD, Defendants CUSTODY CUSTODY COMPLAINT AND REQUEST FOR EMERGENCY RELIEF TO THE HONORABLE, THE JUDGES OF SAID COURT: 1. The plaintiff is Donna Laird, who currently resides at 305 North Third Street,Summerdale, Cumberland County, Pennsylvania 17093. 2. The Defendants are James J. Blase, Jr., who currently resides at 1248 Reese Street, Harrisburg, Dauphin County, Pennsylvania 17104, and Sharon Ann Shiner Eckerd, who currently resides at 24 Canna Court, Belton, Missouri 64012. 3. plaintiff seeks primary physical custody and shared legal custody of the Defendants' two minor children, Crystal L. Blase, born February 10, 1988; and Scott A. Blase, born September 30, 1989. 4. The children were not born out of wedlock. 5. The children were in the custody of their great-aunt, Donna Laird, Plaintiff, who resides at 305 North Third Street, :"'<lj\'l\l1i~ L, , " ~ > .d~L'; Summerdale, Cumberland County, Pennsylvania until November 9, 2000. 6. During the past five years Crystal Blase has resided with the following persons and at the following addresses: Persons Address Dates Donna Laird Gary Schiner Scott Blase Paige Miller 305 North Third St. Summerdale, PA Feb. 16, 2000 to Nov. 10, 2000 Sue Hutchens (aunt) 5 Marshall Drive Dec. 3, 1999 to Feb. 16/ 2000 Sharon Eckerd Tom Eckerd 803 North King St. Harrisonville, MO 1995 to Dec. 3, 1999 During the past five years Scott Blase has resided with the following persons and at the following addresses: Persons Address Dates Donna Laird Gary Schiner Crystal Blase Paige Miller 305 North Third St. Summerdale, PA Feb. 16, 2000 to Nov. 10, 2000 Donna Laird Gary Schiner Paige Miller 305 North Third St. Summerdale, PA Dec. 3, 1999 to Feb. 16/ 2000 Sharon Eckerd Tom Eckerd 803 N. King St. Harrisonville, MO 1995 to Dec. 3, 1999 o-,~"=~~ j_~ I ~ 'g. 7. The father of the children is James J. Blase, Jr., who currently resides at 1248 Reese Street, Harrisburg, Dauphin County, Pennsylvania. 8. The mother of the children is Sharon Ann Schiner Eckerd, who currently resides at 24 Canna Court, Belton, Missouri. 9. The relationship of Plaintiff, Donna Laird, to the children is that of great aunt. The Plaintiff currently resides with Gary Shiner, her great nephew, Paige Miller, friend of Plaintiff, and the subject minor children herein. 10. The relationship of Defendant, James J. Blase, Jr., to the children is that of father. It is unknown with whom Father currently resides. The relationship of Defendant, Sharon Ann Schiner Eckerd, to the children is that of mother. Mother currently resides with Jimmy (last name unknown and relationship unknown) . 11. Plaintiff has not participated as a party, witness, or otherwise in litigation concerning the custody of the said children. 12. Plaintiff has no information of a custody proceeding concerning the children pending in a Court of this Commonwealth. , , L. .-1-,_,.,__" v",-,__ 13. 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. 14. The best interests and permanent welfare of the children will be served by granting the relief requested because the children's mother and father have shown no interest in their children's welfare in that neither had shown any interest in having custody of Scott or Crystal. Further, neither child wishes to reside with either of their parents. However, on November 9, 2000, Defendant Sharon Ann Schiner Eckerd appeared at the children's school and demanded they return to Missouri with her. The children both wish to return to Plaintiff's custody and to the schools they have attended last year and this academic year. Primary physical custody and shared legal custody with Plaintiff will be in the best interest of the children as evidenced by Defendants' neglect and indifference toward their children. 15. Each parent whose parental rights to the children has not been terminated and the person who has physical custody of the children has been named as parties to this action. WHEREFORE, Plaintiff respectfully prays that Your Honorable Court award primary physical custody and shared legal custody of -^-"" .. -,' . , '. . --~ ~~ililff ~'- 'l1tllt,'--;. the children to the Plaintiff and order Defendant Sharon Ann Schiner Eckerd to return the minor children to Plaintiff's custody pending a hearing on the matter of custody. Respectfully submitted, Lori . Serratelli, Esquire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717)540-9170 Attorney for Plaintiff ',' j, ---, ,-< J . <'\., "C",,"-_ VERIFICATION I verify that the statements made in the foregoing 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. Date: _~_~..1\b\OO ~..^ ~ ~"...J. Donna Laird L""""'" . , , . ..1...., ,~ , " -,", "' I;]<.j .. , DONNA LAIRD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA thJ - rOO';' ~ NO. CIVIL ACTION - LAW vs. JAMES J. BLASE, JR., and SHARON ANN SCHINER ECKERD, Defendants CUSTODY VERIFICATION FOR PETITION FOR EMERGENCY RELIEF Lori K. Serratelli, Esquire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717)540-9170 Attorney for Plaintiff " -. ,~ ,~, ~ Ii Ii [I i I' II " II Ii I' Ii I,' I' , i' I ',j I; I: I:: 'I II ;i II : ~ 'I II I ! 1 ! :-! ~a~. ~ ,. "~ " ,~,.,< -> '. ~ ~.- ~" -;.;", .. 1]1Il_.~._~".=~_, :_,-"<" . ~~~ "^.~ :':G-o:,,:nCE -- ,1'": ,\ :!:~q;':~RY 00 ,IIml?'7 I~N /[;: n Iii CfJivU':,-i'<\L: COUNTY I')I-,\i)'\ IC;Vj \,/el r\!I/~ '-, 'Iv I.... J ,1\[" 1. . ~t'%W>'li"~"':'" ,,,,",,:r , _'.'"'~,~"r. r.r.J!Ii!l~ =-, ,'" ~e, ,1IIIII'f!! J -l ,-.1,. ., >"~--~:, VERIFICATION I verify that the statements made in the foregoing Petition 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. Date: ~l \~\oo -~- ~ ~~ Douna Laird .~.." I I 1 J ~ ~ ~ .~ I j ~ 1 i :k; .fj .j :(! - ""'''''''.'''>' " ~ ~~. ."'<^'" "~, O' "\<__.,, '"~, ... ~"'" l!l'W mil " ',"'" '.~--.-",i,""'. <"';:'_N"" .,,"-H w-.. , ,~ ' ."" . p.d'" _~ j)~~;!~~:~~T:i\tP:'/ \:n" ~(j [':1\ In: (It! (" .. .".", ('(~" ,\,1'''1 { V\..."(\i;:~:,,-;"\\ !",,~\} ".J'Ju;'\\ J "\:JE~\~~S\0!F-,H\i\ .... _~'_~~_ WJ 1lI.!1~_ -~~ ~U~lr ",.,,<, ...""..~""'~~~-"~ ~~ - ,'I " '." - ,""fiLd:J --'- ~;~ / DONNALAIRD PLAINTIFF v. JAMES J. BLASE, JR. AND SHARON ANN SCHINER ECKERD DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-8052 CNIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 21st day of November, 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the 23rd 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 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 Melissa P. Greevy. E~\ CU5tody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with DisabilitesAct 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 ,,_.-- - ,- I I II I ~ ~ I i .~! , \ " " '.1 'I i , 'I ;J I'~ ,1 :'1 ill 'i '~ j lij " !-:t " ::Ii ~-;:; ~~i ".' '., . ~ ~, );),1,00 JC}./tlO /19 -j-CiC' l!NM!1_" ^",.". , '- "~' '>- -'~', ,""'-' "- .,.''' '.._--,~~-..".'"-'''' --," ,>-,-. w . nI.ED-f)Fpi"'r: IJ- T. ,r' C""' ;.." - 1....,1.. '. ,',:;:, 'dJl;,!A'J'~T.'A1.R''( ..1..0 "i\.it'V f'\-l 00 DEe - I PH 2: ld CU ". Ma~O OOI.lNTY PENNSYLVANIA ,-,,---.~ .- .'.' -.' , .. . '"-,~~ ,-, - - ^'" ~'-,'"~' ,.,.. taI-~~~a4 ~, 71~M~Z4~ ~ ~ ~ 4~ m:"",^ ~~IIM_ ""= """.".~.~, >~~!!'1f,*~'\>"~'~"l!I;~'r.-""'@<j_''''I!!'~Jl1I!ll!II!l!~Fl\!I'J!~- ~4<~~=, ~~~~~ . ~ I . . ,-" ~.-" "!iIliLr CUMBERLAND COUNTY COURT ADMINISTRATOR FACSIMILE TRANSMITTAL SHEET TO, FROM: Margie A. Wevodau DATE: 11/27/00 Melissa Greevy, Esquire FAX NUMBER, RE, Laird v & Eckerd TOTAL NO. OF PAGES INCLUDING COVER: 16 o URGENT ~ FOR REVIEW 0 PLEASE COMMENT DLEASE REPLY DPLEASE RECYCLE NOTES/COMMENTS, This is the file we talked about last week. I had trouble tracking down the file on this case to get you copies. I thought I would fax it to you now because of the delay in getting it mailed. If you have any questions, please call. CUMBERLAND COUNTY COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE PA 17013 PHONE,717-240-6200 FAX, 717_240_{-,4{-,2 - .~, 'J I' - -.< !lj;r -'- "i i: DONNA LAIRD, ,Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V CIVIL ACTION - LAW NO. 00-8052 CIVIL TERM JAMES J. BLASE, JR., and SHARON ANN SCHINER ECKERD, Defendants CUSTODY IN RE: PETITION FOR EMERGENCY RELIEF ORDER OF COURT AND NOW, this 20th day of November, 2000, the parties having appeared in open court with their counsel and reporting to the court that they have agreed to the entry of this order, we hereby order as follows: 1) Legal custody of the minor children, Crystal L. Blase, born February 10, 1988, and Scott A. Blase, born September 30, 1989, shall be shared by all three of the parties, their mother, Sharon Ann Schiner Eckerd, their father, James J. Blase, Jr., and their maternal great-aunt, Donna Laird. In the - event of a medical or physical emergency, the party then having physical custody of the children is authorized to make decisions regarding the care of the children as long as they promptly report the situation to the other parties to this action as soon as practical thereafter. 2) Temporary primary physical custody of the minor children shall be with the plaintiff, Donna Laird, pending further agreement of the parties or order of this court. 3) When the mother, Sharon Ann Schiner Eckerd, relocates back to Cumberland County, and has an appropriate place to live in the East Pennsboro School District and is employed, the parties expect that the custody arrangements set out in this order will change so that eventually primary ~, 1=- --" ~. " .~ 00-8052 CIVIL TERM physical custody of the children will be with her. All of that, of course, depends upon the circumstances in effect at the time. And if the parties cannot agree, the court will have to resolve that matter in the future. 4) Pending further order of this court, the father and mother shall alternate periods of temporary custody on the weekends, from 5:00 p.m. on Friday until 8:00 p.m. on Sunday. The father shall commence his alternating weekends on Friday, November 24, 2000. The mother will commence her alternating weekends when she has returned to reside in the Cumberland County area, which the parties anticipate will be about December 12, 2000. 5) In addition to the above schedule, the parties may agree to additional periods of temporary custody for either of the parents, particularly in the event that the mother returns to Pennsylvania on a temporary or permanent basis prior / to December 12, 2000. The Court Administrator is directed to assign this matter to a conciliator, and the parties' counsel will contact the conciliator to schedule a conference sometime in January of 2001 so that the parties have a forum to address these matters further if they have not resolved them by agreement by that time. ~ >f'{ 00 l~ \V~~~ By the Court, ,r?J J. 00-8052 CIVIL TERM Lori K. Serratelli, Esquire For Donna Laird Samuel L. Andes, Esquire For James J. Blase, Jr. Mary Ann Murphy, Esquire Legal Services, Inc. For Sharon Ann Schiner Eckerd Court Administrator :bg . "'~~ -,I' ~-, , , -~'-,~-. {J"':! DONNA LAIRD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-8052 CIVIL CIVIL ACTION - LAW JAMES J. BLASE, JR., and SHARON ANN SHINER ECKERD, Defendants CUSTODY ORDER OF COURT AND NOW, this / eM v')/I "BM_ I. n J '" day of >l/flM/rr~/I./, 2000, upon consideration of the foregoing Petition for Emergency Relief, it is hereby ORDERED that a hearing is scheduled in this matter for the ,20-U day of /1~/)/ , 2000, at q " :2 fll vV ct..m., in the # i , 1 Courthouse Cumberland County Courthouse, Court Room Square, Carlisle, Pennsylvania 17013. Further, it is ORDERED that the subject minor children be returned to Plaintiff's physical custody pending a hearing on the matter of custody. BY THE COURT: ./9/1 !rrpJ'DO {()cJuLJ. }}-/5-00 RXS . "'- "~ .' ",-' '" ~" --'-'j DONNA LAIRD, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-8052 CIVIL CIVIL ACTION - LAW JAMES J. BLASE, JR., and SHARON ANN SCHINER ECKERD, Defendants CUSTODY PETITION FOR EMERGENCY RELIEF TO THE HONORABLE, THE JUDGES OF SAID COURT: 1. The Plaintiff is Donna Laird, who currently resides at 305 North Third Street,Summerdale, Cumberland County, Pennsylvania 17093. 2. The Defendants are James J. Blase, Jr., who currently resides at 1248 Reese Street, Harrisburg, Dauphin County, ~ Pennsylvania 17104, and Sharon Ann Schiner Eckerd, who currently resides at 24 Canna Court, Belton, Missouri 64012. 3. On November 14, 2000, Plaintiff filed a Custody Complaint. (Attached as Exhibit "AU) 4. Plaintiff seeks primary physical custody and shared legal custody of the Defendants' two minor children, Crystal L. Blase, born February 10, 1988; and Scott A. Blase, born September 30, 1989. ,~, - 1,.l.'J~;.... I ", hi':":___.,; 5. The children were in the custody of their great-aunt, Donna Laird, Plaintiff, who resides at 305 North Third Street, Summerdale, Cumberland County, Pennsylvania until November 9, 2000. 6. Neither Mother, Sharon Ann Schiner Eckerd, nor father, James J. Blase, Jr., has shown any interest in their children's welfare in that neither had shown any interest in having custody of Scott or Crystal. 7. Neither child wishes to reside with either of their parents. 8. On November 9, 2000, Defendant Sharon Ann Schiner Eckerd appeared at the children's school and demanded they return to Missouri with her. The children both wish to return to / Plaintiff's custody and to the schools they have attended last year and this academic year. 9. Defendant Sharon Ann Schiner Eckerd has not had suitable, operational transportation to return to Missouri since November 9, 2000 and has remained in the area. 10. Defendant Sharon Ann Schiner Eckerd has kept the children out of school for the past three days, for no purposeful reason. " " ~I .. . ~-, "''->-; 11. The children have a stable environment while in Plaintiff's custody. 12. Primary physical custody and shared legal custody with Plaintiff will be in the best interest of the children as evidenced by Defendants' neglect and indifference toward their children. WHEREFORE, Plaintiff respectfully prays that Your Honorable Court award primary physical custody and shared legal custody of the children to the plaintiff and order Defendant Sharon Ann Schiner Eckerd to return the minor children to Plaintiff's custody pending a hearing on the matter of custody. - Respectfully submitted, ~~;df Melan e L. Erb, squire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717)540-9170 Attorney for Plaintiff - .._, .."..,,' 10< .... -'" .- ~i ~RIFICATION I verify that the statements made in the foregoing 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. Date: ~\c\c'-' '~ "Z- ~~~ Donna Laird - ~_, L " ' " " ~",-" DONNA LAIRD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. C:6 -8'c,~;d Q ~ ". \ CIVIL ACTION - LAW vs. JAMES J. BLASE, JR., and SHARON ANN SCHINER ECKERD, Defendants " CUSTODY CUSTODY COMPLAINT AND REQUEST FOR EMERGENCY RELIEt ...--, TO THE HONORABLE, THE JUDGES OF SAID COURT: ~<:. {i) 1. The Plaintiff is Donna Laird, who currently resides at 305 North Third Street,Summerdale, Cumberland County, pennsylvania 17093. 2. The Defendants are James J. Blase, Jr., who currently resides at 1248 Reese Street, Harrisburg, Dauphin County, Pennsylvania 17104, and Sharon Ann Shiner Eckerd, who currently resides at 24 Canna Court, Belton, Missouri 64012. 3. Plaintiff seeks primary physical custody and shared legal custody of the Defendants' two minor children, Crystal L. Blase, born February 10, 1988; and Scott A. Blase, born September 30, 1989. 4. The children were not born out of wedlock. 5. The children were in the custody of their great-aunt, Donna Laird, Plaintiff, who resides at 305 North Third Street, " "-- -" "-"-""'":1'r-:; Summerdale, Cumberland County, Pennsylvania until November 9, 2000. 6. During the past five years Crystal Blase has resided with the following persons and at the following addresses: Persons Address Dates Donna Laird Gary Schiner Scott Blase Paige Miller 305 North Third St. Summerdale, PA Feb. 16, 2000 to Nov. 10, 2000 Sue Hutchens (aunt) 5 Marshall Drive Dec. 3, 1999 to Feb. 16, 2000 Sharon Eckerd Tom Eckerd 803 North King St. Harrisonville, MO 1995 to Dec. 3, 1999 During the past five years Scott Blase has resided with the / following persons and at the following addresses: Persons Address Dates Donna Laird Gary Schiner Crystal Blase Paige Miller 305 North Third St. Summerdale, PA Feb. 16, 2000 to Nov. 10, 2000 Donna Laird Gary Schiner Paige Miller 305 North Third St. Summerdale, PA Dec. 3, 1999 to Feb. 16, 2000 Sharon Eckerd Tom Eckerd 803 N. King st. Harrisonville, MO 1995 to Dec. 3, 1999 . "'~'_<" 1-- I' '_~ ,',~ -, jo j;:' 7. The father of the children is James J. Blase, Jr., who currently resides at 1248 Reese Street, Harrisburg, Dauphin County, Pennsylvania. 8. The mother of the children is Sharon Ann Schiner Eckerd, who currently resides at 24 Canna Court, Belton, Missouri. 9. The relationship of Plaintiff, Donna Laird, to the children is that of great aunt. The Plaintiff currently resides with Gary Shiner, her great nephew, Paige Miller, friend of Plaintiff, and the subject minor children herein. 10. The relationship of Defendant, James J. Blase, Jr., to the children is that of father. It is unknown with whom Father currently resides. _ The relationship of Defendant, Sharon Ann Schiner Eckerd, to the children is that of mother. Mother currently resides with Jimmy (last name unknown and relationship unknown) . 11. Plaintiff has not participated as a party, witness, or otherwise in litigation concerning the custody of the said children. 12. Plaintiff has no information of a custody proceeding concerning the children pending in a Court of this Commonwealth. . .- . ~=' -.~' "i):j 13. 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. 14. The best interests and permanent welfare of the children will be served by granting the relief requested because the children's mother and father have shown no interest in their children's welfare in that neither had shown any interest in having custody of Scott or Crystal. Further, neither child wishes to reside with either of their parents. However, on November 9, 2000, Defendant Sharon Ann Schiner Eckerd appeared at the children's school and demanded they return to Missouri with her. The children both wish to return to Plaintiff's custody and to the schools they have attended last year and this academic year. Primary physical custody and shared legal custody with Plaintiff will be in the best interest of the children as evidenced by Defendants' neglect and indifference toward their children. 15. Each parent whose parental rights to the children has not been terminated and the person who has physical custody of the children has been named as parties to this action. WHEREFORE, plaintiff respectfully prays that Your Honorable Court award primary physical custody and shared legal custody of - ,-j ,. -I. ~-, -~ , ^' ~ the children to the Plaintiff and order Defendant Sharon Ann Schiner Eckerd to return the minor children to Plaintiff's custody pending a hearing on the matter of custody. Respectfully submitted, /} , I Lori . Serratelli, Esquire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717)540-9170 Attorney for Plaintiff - .\;',~ ."_' '0 "_ ~,' ~"'-~',i VERIFICATION I verify that the statements made in the foregoing 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. Date: ~ \0 \cu . ~~~ Ci... ~~-\ Donna Laird / - - T__'-." em ~, - 'I:G~, JAN 3 0 20' ~ DONNA LAIRD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-8052 vs. JAMES J. BLASE, JR., AND SHARON ANN SCHINER ECKERD, Defendants CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this "3''''' day of ~a....-..~ ' 2001, upon consideration of the attached Custody Conciliation Summary R port, it i hereby ordered and directed as follows: 1. Legal Custody. Legal custody of the minor Children, Crystal L. Blase, born February 10,1988, and Scott A. Blase, born September 30,1989, shall be shared by all three of the parties, their Mother, Sharon Ann Shiner Eckert, their Father, James J. Blase, Jr., and their Maternal Great-Aunt, Donna Laird. In the event of a medical or physical emergency, the party then having physical custody of the Children is authorized to make decisions regarding the care of the Children as long as they promptly report the situation to the other parties to this action as soon practical thereafter. 2. Physical Custody. Primary physical custody of the minor Children shall be with the plaintiff, Donna Laird, pending further agreement of the parties or Order of this Court. In as much as the Children will be primarily in the physical custody of Donna Laird, Ms. Laird will be providing health insurance benefits for the Children of this Order. 3. When the Mother, Sharon Ann SchinerEckerd, relocates to appropriate housing in the East Pennsboro School District and is employed, the parties expect the custody arrangements set at this Order will change so that eventually primary physical custody of the Children will be with her. All that, of course, depends on the circumstances and effect at the time, and if the parties cannot agree the Court will have to resolve that matter in the future. At the parties' option, and per agreement of the counsel, the parties may return to the Custody Conciliator in the event that the parties are not able to resolve this matter through their counsel. 4. Pending further Order of this Court, the Father and the Mother shall continue to alternate periods of temporary custody on the weekends from 5:00 p.m. on Friday until 8:00 p.m. on Sunday. 5. In addition to the above schedule, the parties shall share holidays and school breaks. '" , "W FiLED""OfFiCE OF Th[~ ~: rt.':T~-:CNOTAHY o I FES - I tiN 8: I 6 CUfVI3EFiLN~D COUNTY PENNSYLVANIA !:i , to: ~i 1,1 i !,j ..... 1:1 iii il f-j ii, ",~ n'!R,nll!R,_",,~ ,. 'If'i~b\'''!iW!',\~,.,,,,,k,.,.j\l-tI1Rlll!lfi~tJ5iT "' _ 'f1]T~1f~m>l-'jj"'ii<r-"Olt:(f! , ,~_' " _ ~~ ,'- -~ , No. 00-8052 6. Summer. Each of the parties is entitled to up to two weeks of custody for the purposes of vacation. Additionally, the parents shall make arrangements in consideration of their work schedules to share in the summertime care of their Children. It is presently anticipated that Mother will have the Children for the first half of the day until approximately 1 :30 p.m. and that Father will have the time from approximately 1 :30 p.m. until late evening when, unless otherwise agreed, he shall return the Children to the care of their Maternal Great-Aunt, Donna Laird. 7. The parties agree that on a regular basis the Children shall attend Church activities on Sundays. The parents will return the Children early on either Saturday evening or Sunday morning for Church if the parent with custody opts not to go with the Children to Church. 8. The parties recognize that in the future the Children will want to participate in sports and various social activities. Donna Laird shall be authorized to sign them up for these sports and activities. The parties shall cooperate to see to it that the Children can participate in such activities. 9. In addition to the above schedule, the parties may agree to additional periods of temporary custody for either of the parents. BY THE COURT, Dis!: Lori K. Serratelli, Esquire, 2080 Linglestown Ro~d, Suite 201. Harrisburg, PA 17110 ~ Marianne Murphy, Esquire, Legal Se/Vlces, 8 I/Vlne Row, Carlisle, PA 17013 . Samuel L Andes, Esquire, 525 N. 12th Street, Lemoyne, PA 17043 rf\l \ ~" ,0 t~ ()~()~ , ~- '-;~ = ~ ~ ~ ~- 0 ",- f{;' ,< '" DONNA LAIRD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-8052 vs. JAMES J. BLASE, JR., AND SHARON ANN SCHINER ECKERD, Defendants 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 Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Crystal L. Blase Scott A. Blase February 10, 1988 September 30,1989 Donna Laird Donna Laird 2. A Custody Conciliation Conference was held on January 23, 2001, with the following individuals in attendance: the Maternal Great-Aunt, Donna Laird, and her counsel, Lori K. Serratelli, Esquire; the Father, James J. Blase, Jr., and his counsel, Samuel L. Andes, Esquire; the Mother, Sharon Ann Schiner Eckerd, and her counsel, Marianne Murphy, Esquire. 3. The parties reached an agreement in the form j-/ d-b -6l Date