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Home My WebLink About00-08360 ~ '" ',_ "-=,--".:1,' ""~'- ',," :-, . ADAM C. VAUGHN PLAINTIFF V. MARGARET RUSSELL DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-8360 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 4th day of Deeember, 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 3rd day of January, 2001 , at 3:00 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 TIIE COURT, By: Isl Melissa . Greev '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 arrllllgements 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 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 ~"'"' '" '. ",,~.__~ n~ H.'_. _'-, .",;,,~ , ,,'_" "-> __~ '-, .0. . /J. -s~ . co /0< .[;.aJ /01 . 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IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000 - PJt..D Co~L y~ MARGARET RUSSELL, Defendant CIVIL ACTION-LAW ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before the Conciliator, on , the day of 2000 at .m. in the office of said conciliator located at 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. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent order. FOR THE COURT: Date: 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. Court Administrator Cumberland County Court House One Court House Square Carlisle, Pa. 17013 (717) 240-6200 ,,,><' " J. ' ,,~- " '" ~'~~ .,~-, ." ADAM C. VAUGHN, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA No. 2000- ~3<..o tu..J T 1-<-- MARGARET RUSSELL, Defendant CUSTODY COMPLAINT FOR LEGAL AND PARTIAL PHYSICAL CUSTODY AND NOW, this J~Day of November, 2000, comes the Plaintiff, Adam C. Vaughn, by his attorney, Diane M. Rupich, Esquire, and respectfully requests the following: 1. The Plaintiff, Adam C. Vaughn, is an adult individual, who currently resides at 3838 Peters Mountain Road, Halifax, Dauphin County, Pennsylvania 17032. 2. The Defendant, Margaret Russell, is an adult individual, who currently resides at 670 Walnut Bottom Road, Shippensburg, Cumberland County, Pennsylvania. -1- .- . ;-, c;-_ 0"__" ,-,,, "-0.--' "'il:; 3. Plaintiff and Defendant were never married; however, they are the parents of one child; namely: Tammy Jo Russell, born April 3, 1997. 4. The Plaintiff is unaware ofthe whereabouts of the minor child since birth, and is unable to provide the same. 5. There has been no prior action for custody or visitation involving the minor child in this or any other jurisdiction. 6. The Court of Common Pleas of Cumberland County has jurisdiction in this matter as the Plaintiff believes the Defendant and the minor child have resided in Cumberland County for a period of at least six months. 7. The minor child currently resides with Defendant, a half sister, her grandmother, grandmother's boyfriend, an Aunt and her boyfriend and their children, and another -2- ." . liI~' Aunt and her boyfriend and their child at the residence set forth in Paragraph two above. 8. The Plaintiff currently resides with his mother, his wife and his two stepchildren. 9. It is averred that the best interests of the minor child will be served by granting the Plaintiff shared legal and partial physical custody. WHEREFORE, Plaintiff, Adam C. Vaughn, by his attorney, Diane M. Rupich, Esquire, respectfully prays your Honorable Court to grant his request. Respectfully submitted, BY: . -~--. Esquire 1017 . Front eet Harrisburg, PA. 17102 (717) 232-9724 I.D. No. 71873 -3- .- - . I, >_ ~ i' V F. RI FIe A T I 0 ~ " \.'., I . I verify that the statements made in this U;rn .f?~)9/ N-I- - i ~' ," " . 1<.." are true and correct. I understand that tillse statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relatinl,\ to unswom falsitication to authorities. . Dale: ~ V; c2 f; Mtt5 /2/7, . t/lf'U fl.DPm t2, tft:v , I ~ ',.-. I ~ "" LWiLl JAN 3 0 20~ ADAM C. VAUGHN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-8360 MARGARET RUSSELL, Defendant CIVIL ACTION - LAW CUSTODY ORDER QF COURT AND NOW, this S\ daYOf:J ~ , 2001, upon consideration of the attached Custody Conciliation Summary Report, it is t\ereby ordered and directed as follows: 1. Legal Custody. The parties, Adam C. Vaughn and Margaret Russell, shall have shared legal custody of the minor Child, Tammy Jo Russell, born April 3, 1997. 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. Father shall have liberal partial custody arranged as follows: A. Each Sunday evening after work until Wednesday morning when the Child shall be returned home by 1 :00 p.m. In the event that there is a delay in her return, a telephone call will be made to inform Mother or the child's caregiver. 3. Holidays. Holidays shall be shared as the parties may agree. 4. Vacation. Each party is entitled to one continuous seven-day period of vacation time each year, subject to a thirty-day notice to the other parent. In the event that both parents have chosen the same vacation week, the party first providing written notice to either party shall be entitled to that week. . , i., ." No. 00-8360 5. 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. Each parent shall ensure that third parties also comply with this provision during his or her periods of custody. Dis!: Diane M. Rupich, Esquire, 1017 N. Front Street, Harrisburg, PA 17102 Dirk E. Berry, Esquire, 7 Irvine Row, Carlisle, PA 17013-3019 J. m~l-L'i2C-C 0 I/O I ~ ~, ~. "" ''1'',-''''''~'~'''~' '~" "~"-. "'l' "~" >,,~ ~,-~ '"P-."-~"' ~~_ "= ~ .. or: "!-. .~~l:('?~~?t~fCr: \n7A9Y OJ .f,?[V ", -<-{ 1> d CUi,,'>:,. ~~t.Jc:.r// ,; ", ". Pr::^;l..../""'o'!'l;- (-'""I '-1 \r~r::,/;, >o'LUiV'(1,' '~/I L.J/iJ},JI1 f J I '"I1iJ\ p/,J '. I: (j ,; " ""'"'~.. lJ.,_~.~~:O;[I1",,~p,"}rr,""I@W-'!!"V~""-';"'~I~''}f~~~~ - >. '.,1. . ~= . __, - 'C . . "q-(:,'I ~~~)~ " ADAM C. VAUGHN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA NO. 00-8360 vs. MARGARET RUSSELL, 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 OF Tammy Jo Russell April 3, 1997 Mother 2. A Custody Conciliation Conference was held on January 22, 2001, with the following individuals in attendance: the Father, Adam Vaughn, and his counsel, Diane M. Rupich, Esquire; the Mother, Margaret Russell, and her counsel, Dirk E. Berry, Esquire. 3. The parties reached an agreement in the form of an Order as attached. J~ J.. b ~ (f ( elissa Peel Greevy, Esquire Custody Conciliator Date