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Home My WebLink About01-0093 FX . . JAM 0 5 2001fJ # ROSE M. PARKER, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - CUSTODY CLARENCE R, PARKER, Defendant. NO,OI- q3 CML 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, at , on the , day of ,2001, 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 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: Custody Conciliator AMERICANS WITH DISABILITIES ACT OF 1990 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 TIDS 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 '" _'00"'- "~""~ .' -, ,-, '"",,,,,"~ _ , ROSE M. PARKER, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY v, CNIL ACTION - CUSTODY CLARENCE R. PARKER, Defendant. NO. 0'- q3 CNIL COMPLAINT FOR CUSTODY 1. The Plaintiff is Rose Parker, residing at 408 Third Street, Apt. B, West Fairview, Cumberland County, Pennsylvania, 2, The Defendant is Clarence Parker, residing at 408 Third Street, Apt. B, West Fairview, Cumberland County, Pennsylvania, 3, Plaintiff seeks partial custody of the following children: Name Present Residence Age Crystal Ann Parker 408 Third Street West Fairview, PA 15 Mary Lou Parker 408 Third Street West Fairview, PA 14 The children were not born out of wedlock. The children are presently in the custody of Clarence Parker and Rose Parker, residing at 408 Third Street, West Fairview, Cumberland County, Pennsylvania, During the past five years, the children have resided with the following persons and at the following addresses: Person Address Date Clarence Parker Rose Parker Patricia Rice 408 Third Street, Apt. B West Fairview, PA August 1999- Present , ~lJ'I '-_',,~,~_,'_1 ,He ,'~- '_~" -. """'_"""','')-1'"'1,''' "''1' ",_,_.,.~,__,T_~'_,_;,,_ -;,__'_I_~'_ -, ,-~ .- -."" Clarence Parker Rose Parker 408 Third Street, Apt. C West Fairview, PA March 1999- August 1999 Rose Parker Linda Leonard Troy Grebinger 300 State Street West Fairview, PA 1998-August 1999 Clarence Parker Rose Parker Troy Grebinger 95 Fraley Street, Apt. 5 Kane, P A 1985-1998 The mother of the children is Rose Parker, currently residing at 408 Third Street, West Fairview, Cumberland County, Permsylvania, She is married to the Defendant. The father of the children is Clarence Parker, 408 Third Street, West Fairview, Cumberland County, Pennsylvania, He is married to the Plaintiff. 4, The relationship of the Plaintiff to the children is that of mother, The Plaintiff currently resides with the following persons: Name Relationship Clarence Parker Husband Pat Rice Husband's girlfriend Crystal Ann Parker Daughter Mary Lou Parker Daughter 5, The relationship of Defendant to the children is that of father, The Defendant currently resides with the following persons: Name Relationship Rose Parker Wife " - ".,'>' ,'_x1',]'-" .'c_'.'-_ ,'. ,,-' !", -,- -~- .. ,-" 1""'1 ~,,_, .-",",!"_! ~_- -, 0" M --,. .^ 1-'_ -_&- "-,--- . . Pat Rice Girlfriend Crystal Ann Parker Daughter Mary Lou Parker Daughter 6. 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, Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state, 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 these children, 7, The best interest and permanent welfare of the children will be served by granting the relief requested because: a) Plaintiff and Defendant have reached an agreement with respect to custody, which is attached to this complaint; b) Plaintiff currently resides with the children and exercises custody on a regular basis; c) Plaintiff enjoys a loving relationship with the children; d) Plaintiff plans to leave the family residence and secure housing in an assisted-living facility; e) Plaintiff is willing to grant the Defendant shared legal custody and primary physical custody of the children so they will not have to transfer schools and adjust to a new primary residence. 8, Bach parent whose parental rights to the children have not been terminated and the persons who have physical custody of the children have been named as parties to this action, ,-"'" .''"'''1''__, __ . r, ,,,",." 0,," ,~', _~ -', I~I-~_,~ ,-.< "." ',' ,-.e, --'.'" '--'. . WHEREFORE, Plaintiff requests the Court to enter an Order in the form attached hereto, granting Plaintiff partial custody of the children. Date: I /0 VIOl , , ~'.~ ' ie B, Mill~ Certified Legal Intem ~ ~' / A. Lj. T S M, PLACE ROBERT E. RAINS Facmty Advisors TERI L. HENNING Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 0+-09-611 ~ .".- ~- , p -~'''- ~'-':?"'--"'''~/~"''- ".,';" - ",.",. ---~-,' .-;- ,I~'l_ '" \"':'1 - -~ ~~ _," '_' - ,_,. j o o \ VERIFICATION I verify that the statements made in the Custody Complaint are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S, ~4904, relating to unsworn falsification to authorities, Date: /d.,,) Ii( / () rJ I?~'Y'I. (~ Rose Parker "'llI1'll: r I~' I '[ [I [I II,~ llUff _.~. I r ~ '. A'~ f ~"",^;,' , " "- o ~ 7J ~ f- l & 'IQ (3 8&~ I I ::f)~ P:t ~ "" J C-0 CIi ;-... o C. :<:-~' ~L-' 6~[ -< f;r--_ 2;~_ S>'~"";' 2: ::,:! ~s \(f I C:'::I -..!." ,,::-,,- " \C; ".:..'J ~- ~l!ItJI!!!ImI!"~wrl\lj'!1~4''"'~'-W<!'"--~'"<FM':''',tl)M\!'W1~HI.IiI!~~m~if~IlMffln.1; mil' !.f~)IiJi!_!iI\'jj.. ~~""""""'t""'l"~n,="",- ,uil!lfl ,,_ _,' ;_ ''l'l ", ~ .eSl.JP ROSE MARIE PARKER, PLAINTIFF :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v, :CNILACTION -LAW : CUSTODY CLARENCE RAY PARKER, DEFENDANT :NO,O/- 9J CNIL TERM CUSTODY AGREEMENT TillS AGREEMENT, made this 18-*- day of\:'\",~ "'- ~\:,<?.\ , 2000, between Rose Marie Parker, hereinafter Mother, and Clarence Ray Parker, hereinafter Father, concerns the custody of the parties' minor children: Crystal Parker, bom April 11, 1985 and Mary Parker, born February 21, 1986, Mother and Father desire to enter into an agreement as to the custody of their minor children and to have this agreement made an Order of the Court, Mother and father hereby agree to the following: 1, Mother and Father shall have shared legal custody of the children, 2. Father will have priruary physical custody of the children, 3, Mother will exercise periods of partial physical custody with the children every other weekend from Saturday at 8:00 a,m. until Sunday at 6:00 p,m., a, At Mother's option, Mother may exercise one custodial weekend each month at Father's residence, If she does so, she may stay at 1 I-~ I j .1 "'- V) C ;>- ::2: .~~~ ''':'1 ~:? ,,$ .:;:,-1 :_-- <..(1) L2:: :i!~ :'3 C.) ,~, ~.._- r"-. !II!)l!I!I'l'l ~"'~ ~_ , ,~ . ~ 'J'j!!,II!l, ~~ "-~~~, ~~- ~,-~ ""r -. _.~ -~"~ .~~ ,.~--"~~~- "..~~J!;6.!!W <.~">'1~_~'''I"~1!Wm'\~:''''''@,''fflWlll!''".. ~, '" IlllnillTirfi' ~ 1IJ'!1,I$~~~~~jil' Father's residence from 5:00 p,rn. Friday until 5:00 p.m. Sunday, b, If Mother's living situation does not allow her to keep the children overnight, her weekend custodial periods (except those exercised at Father's residence) shall be from 8 a,rn. to 8 p,m. on Saturday and Sunday, 4, Holidav Schedule, Mother and Father will exercise physical custody of the children during holidays in the following manner: a, Mother will have physical custody of the children on the following holidays in even-numbered years: Thanksgiving, Christmas Day (3 p,rn. - 8 p,m.), Easter, New Year's Day, and July 4th, b. Father will have physical custody of the children on the following holidays in even-numbered years: Christmas Eve (from 3 p.rn. on Christmas Eve until 3 p.rn. Christmas Day), Memorial Day, and Labor Day, c, Mother will have physical custody of the children on the following holidays in odd-numbered years: Christmas Eve (from 3 p,m, on Christmas Eve unti13 p,m, Christmas Day), Memorial Day, and Labor Day, d, Father will have physical custody of the children on the following holidays in odd-numbered years: Thanksgiving, Christmas Day (3 p.rn. - 8 p,rn.), Easter, New Year's Day, and July 4th 2 n:,;"" [-I ~ ,. e. Mother will have physical custody of the children on Mother's Day, f. Father will have physical custody of the children on Father's Day, If Father's Day falls during Mother's custodial weekend (and Mother is not exercising that weekend at Father's house), then Father's custodial period shall begin at 9 a,m. that Sunday, g, Mother will have physical custody of each child on the Saturday following their birthday each year, 5, Each child's communication with the non-custodial parent shall be kept open by way of telephone and mail, 6, Mother and Father will at all times inform the other parent of their current home telephone number and address, work telephone number and address and any emergency phone numbers, 7, Father and Mother will notify each other of all medical care either child receives while in that parent's care, Father and Mother will notify the other immediately of medical or other emergencies which arise while the children are in that parent's care, 8, Neither party will do anything which may estrange the children from the other parent, or injure the opinions of the children as to the other parent or may hamper the free and natural development of the children's love and respect for 3 ,,~ ." 'II the other parent. Both parties will actively promote such behavior in all other people with whom the children have contact. 9, Father has been informed and understands that the Family Law Clinic represents Mother in this matter, The Family Law Clinic has explained that it does not represent Father and cannot give him any legal advice, Father understands that if he wants legal advice on this matter, he must see his own attorney, Understanding this, Father has voluntarily waived his right to seek counsel regarding this matter. 4 '<,,"'~ " 1"1 '-, 1 10. The parties intend to be legally bound by the terms of this Agreement and intend that the agreement shall be made an order of the Court. r'~/7~4"L~'iI~ Clarence Ray Parke ",,~ -vvc. f~ Rose Marie Parker ~'t3~ 1 he Mlller Certified Legal Intern ~Ld- THOMAS M. PLACE ROBERT E. RAINS TERI L. HENNING Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 ORDER And now, this , r day of ~ "', , 200., the foregoing Agreement is approved and entered as an Order of the Court. J ,Jc.,,,,,", .- ,'-';~'- 'r..', rl J. t~~ 01-'1-01 -Rgg 5 -" I I 1-., ~n' 1.._. .1., - ,...,." _w,_ .,~ - 'H. .~.," ."''-'~~__~'''''u> ~ _" _ ., ^-~ nn c) .)-> , ~. " I.> '"' - ,~~~'''\.~:r~:'''~'''';-'';'''''''1'~=,R"~'i''o~,n:'1;1<f'@fil~f~m~~$jrt,",1!ffW',fIrJ!!!W.~Iil_~",_=,,_~ljljljjij (") c ;:x tr 2"" .-.:; ~ -.'- ' ...c- 1'- Cr:' -.;,. f:~::( )~~ ::~/ ~ . "'"'11"" , ~ SEP 0 6 ZOOIP' ROSE MARIE PARKER Plaintiff, Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CNIL ACTION - LAW IN CUSTODY CLARENCE RAY PARKER Defendant, Respondent NO, 01-93 CML TERM ORDER OF COURT AND NOW, this ~ day of J".J.c-I-', 2001, upon consideration of the attached Petition for Special Relief, it is hereby ORDERED as follows: 1, Defendanr, Clarence Kay Pa.lre'l';-1S ORDERED to f.de wun this Coun ana serve on cO'll'lsel fgr llgs~ Mllf'ie Parker by th,,~nd v[ th<o bu~iue~~ day ill whidl he i~ Sel . <oJ, t:h" -ten.. ond.rnrrprt address aHa pB-eftE nmn:.M "hcle he;-€rysta:! Padtel ana Mary Parker are residing, He is Ordered to allow Rose Marie Parker to Gt:a~i1.fQQ8P'lij telephone calls to and from their children, 2, Defendant, Clarence Ray Parker, is ORDERED to transport Crystal Parker and Mary C7>\ Parker to the residence of Rose Marie Parker at lUl9 a.HI., Saturday, ~tcnlbd 8,2001, and pick them up at that residence <*6,86 1'.111. on Sunday, ~Qflt6B3.€@I:" D, J991, a!'I4--shall-- ~ -du th~ o=u~ every, weekend t1J.~@after until further order of this Court, 1\ 3, Failure of Defendant, Clarence Ray Parker, to comply with the terms ofthis Order and the Court's Order of January 8, 2001, may result in fme and/or imprisonment pursuant to 23 Pa,C,S, S 4346, -! II I " '<I' I'''' , "N' 11.\:J,.1 \!!!\l\Jl\tt\01~\'1~,':~".\ r') ^lNnCC r:~,~\.{ i:";'-:h',I'.~nV ! ." .tt '" '''''""",'''"''''!'''' ,~ ,., ,~~ )1 '.:I'" ,.., . '-, ';"~ u ,J "~~.r-~,_ in ~ - ~- . >~~~ ,~ ^, > --, '.'1....... ,_, ~'.."IlI'm ~ # 1l!'fIIlWI~,,""~"'~.<1 .~,'JW!1'-"F~''''j:'l-1,'i'"'-<*-,!''".."':"o/'''';:,''"';'M''!'Ilr'IW@~l:F~,~W4li~RJll!i~"""~~., ~',_ ~ .. 4, s Pet tion for Special Relief is hereby scheduled for the _ day 00 um~r~ 17013, afwnich time the pbies appear m person, C"JtILII97'/MJ ,..,,,,, "B' I2G9u1rf'ilE1J "D'1 /l rf'Urz If. ,./If 1.1'~ BY THE COURT, ~v-'/-1d . / 1. ~ _~ ~;.., 9.t.-bf ',:W; . I c II . . ~ ROSE MARIE PARKER, Plaintiff, Petitioner :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v, :CNIL ACTION- LAW :IN CUSTODY CLARENCE RAY PARKER Defendant, Respondent :NO, 01-93 CNIL TERM PETITION FOR SPECIAL RELIEF PURSUANT TO PA R.C.P. 1915.13 AND NOW, this 6th day of September, 2001, pursuantto Ru1e 1915,13 of the Pennsylvania Rules of Civil Procedure, comes the Petitioner, Rose Marie Parker, by her attorneys, the Family Law Clinic, seeking emergency partial physical custody of the minor children, Crystal Parker and Mary Parker, presents the following Petition for Special Relief: 1, The petitioner is Rose Marie Parker, an adu1t individual who resides at 408 Third Street, Apt. B. West Fairview, Cumberland County, Pennsylvania, 2, The respondent, Clarence Ray Parker, is an adult individual who formerly resided at 408 Third Street, Apt. B, West Fairview, Cumberland County, Pennsylvania, and whose current address is unknown by petitioner, 3, The petitioner is the biological mother (the "Mother") of the minor children, Crystal Parker and Mary Parker, born April 11, 1985 and February 21, 1986, respectively (the "Children"), 4. The respondent is the biological father ( the "Father") of the Children, 5, On January 8, 2001, The Honorable Kevin A. Hess entered an Order awarding Rose Marie Parker and Clarence Ray Parker shared legal custody of the Children, and awarding the Father primary physical custody and the Mother partial physical custody, A true and correct copy of the Order is attached to this Petition as Exhibit "A", 6, Under the January 8, 2001 Order, the Mother was granted periods of partial physical custody, every other weekend from Saturday until Sunday, and certain holidays, 7, The January 8, 2001 Order further requires both parties to inform the other of their current telephone number and address, 8, The Father has refused to allow the Mother to visit or communicate in any way with the children since mid-August 2001, when he left the marital residence taking the children with him, 9, The Father refuses to provide the children's current address or telephone number to the Mother, 10, On information and belief, the Father has failed to enroll the children, both of whom are of compulsory school age, in school this year, Although the children attended East Pennsboro High School and Cumberland Valley Vo-Tech during the 2000-2001 school year, neither child has been in attendance at either school this school year, nor have the schools been asked to transfer their records to any other school. Father has not consulted Mother with regard to any change in the children's education. 11. The Mother believes and avers that it is in the best interest of the children that the Father immediately enroll the children in school and promptly notify Mother as to the school or schools that they are attending, 12, The Mother believes and avers that it is in the best interest of the children that she be allowed the partial physical custody provided under the Custody Order of January 8, 2001. 13, The Mother believes and avers that it is in the best interest of the children that she be allowed compensatory partial physical custody time EVERY weekend, beginning on September 8, 2001 and continuing thereafter until further order of the Court, ^", - ! ,-~ . WHEREFORE, the petitioner, Rose Marie Parker, respectfully requests that this Honorable Court enter an Order against the respondent, Clarence Ray Parker, and provide the relief set forth above, Respectfully submitted, i I~ 101 Dati: ~'-I+ Matthew p, Hughson Certified Legal Intern ROBERT E, RAINS THOMAS M. PLACE TERI L. HENNING Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013-2899 (717) 243-2968 VERIFICATION I verify that the statements made in the foregoing Petition for Special Relief are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C,S, ~4904, relating to unsworn falsification to authorities. Date: ff~ Yv1. f~ Rose Marie Parker ,.., 1"1- ,,-- - ~ .' ql\i 0 5 ZOOS t/) ROSE MARIE P A~KER, PLAINTIFF :IN THE COURT OF COMMON PLEAS OF . :CUMBERLAND COUNTY. PENNSYLVANIA v, :CNIL ACTION - LAW : CUSTODY CLARENCE RAY PARKER, DEFE~DA~T :NO.OI- qJ CNIL TERM CUSTODY AGREEMENT THIS AGRED,1ENT, made this I Q~\--- day of\\<,~" \,\,\., \" . :!l1)0. between , Rose Marie Parker. hereinafter Mother, and Clarence Ray Parker. h':l'l:inali.:r F;nh.:r. concerns the custody of the parties' minor children: Crystal Park.:r. 1>"111 .\pnl II. 1')85 and Mary Parker. born February 21,1986. :\1 other and Father desire to enter into an agreement as to th.: clIshld! "t"th"ir minor children and to have this agreement made an Order of the COUl1 \h'lh.:r ,lIhi Lnh.:r hereby agree to the following I. \lother and Father shall have shared legal custody "t" th.: "llIldr.:n , Father will have primary physical custody of the childr.:n 3, Mother will exercise periods of partial physical cllstl1dy \\Ilh th.: children every other weekend from Saturday at 8:00 a.m. until Sunday at {):OO p,m.. a, At Mother's option, Motherrnay exercise lme cusllldial weekend each month at Father's residence, If she does so. she may stay at I Exhibit "A" ;-i..... ~ ~-"'<<\'l~ 0, II .~ -~-~ . '\ .' Father's resi.drirt\ ,from 5:00 p.m. Friday until 3:00 p.m. Sunday. , . . b. If Mother's !;~ng situation does not allow her to keep the children overnight, her weekend custodial periods (except those exercised at Father's residence) shall be from 8 am. to 8 p.m. on Saturday and Sunday. 4. Holidav Schedule. Mother and Father will exercise physical custody of the children during holidays in the following manner: a Mother will have physical custody of the children on the following holidays in even-numbered years: Thanksgiving, Christmas Day (3 . p.m, - 8 p.m.), Easter, New Year's Day, and July 4th. b. Father will have physical custody of the children on the following holidays in even-numbered years: Christmas Eve (from 3 p,m. on Christmas Eve until 3 p.m. Christmas Day), Memorial Day, and Labor 'nay. c. Mother will have physical custody of the children on the following holidays in odd-numbered years: Christmas Eve (from 3 p.m. on Christmas Eve until 3 p.rn. Christmas Day), Memorial Day, and Labor Day. d. Father will have physical custody of the children on the following holidays in odd-numbered years: Thanksgiving, Christmas Day (3 p.m. - 8 p.m.), Easter, New Year's Day, and July 4th. 2 -~~-,.,~ ~ ',,,,,,,, l' . ~ ;~"I"! J e, Mother will have physical custody of the children.on Mother's Day. - f. Father will have physical custody of the children on Father's Day, If Father's Day falls during Mother's custodial weekend (and Mother is not exercising that weekend at Father's house), then' Father's custodial period shall begin at 9 a.m. that Sunday. g, Mother will have physical custody of each child on the Saturday following their birthday each year. 5, Each child's communication \vith the non-custodial parent shall be kept open by way of telephone and mail. 6. Mother and Father will at all times inform the other parent l't' their eUtTent home telephone number and address, work telephone numher and address and any emergency phone numbers. 7, Father and Mother will notify each other of all medical e'lre ell her ehilJ receives while in'that parent's care. Father and Mother \\'ll1nl'llt'y the "ther immediately of medical or other emergencies which arise \\hlk the ehildren are in that parent's care. 8, Neither party \vill do anything which may estrange the ehildren t'l"llIll the other parent, or injure the opinions ofthe children as to the Dther p;m:1ll llr may hamper the free and natural ,development of the children's Iene and respect for 3 ..... ,"" . '\ " the other parent. Both parties will actively promote such behavior in all other people with whom the children have contact 9, Father has been informed and understands that the Family Law Clinic represents Mother in this matter. The Family Law Clinic has explained that it does not represent Father and cannot give him any legal advice. Father understands that if he wants legal advice on this matter, he must see his own attorney. Understanding this, Father has voluntarily waived his right to seek counsel regarding this matter. 4 ~~..$ . -AR. , ... -.. " "t . 1 O. The p81ues intend to be legally bound by the terms of this Agree~!i:.,ti:nd intend that the agreement shall be made an order of the Court. /' ~/J/21-,-rt7_~c1~ Clarence Ray Park! . ir. ~ '}tv\ - f ~ Rose Marie Parker ~6~ Certified Legal lutein . ~ Lij- THOMAS M. PLACE ROBERT E. RAINS TERI L. HENNlNG Supervising Attorneys FAMll.. y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 ORDER And now, this gth day of. 3:uJ~r~-, 200f, the foregoing Agreement is approved d entered as an Order of the Court. J. TRUE C~py FROM RECORD In Teit!mony '"Iu~.()f, I here lonto set my hand and the seal 01 sa;d Court at Sarl~1 Pa. This. .....9........ d f ;I:cyL_ ;', . . , 5 ~: ..A.. . ROSE MARIE PARKER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CNIL ACTION - LAW IN CONTEMPT CLARENCE RAY PARKER Defendant NO, 01-93CNIL TERM CERTIFICATE OF SERVICE I, Teri L. Henning, hereby certifY that I am serving a true and correct copy of the Petition for Special Relief on Clarence Ray Parker, by hand delivery at the Cumberland County Courthouse, Carlisle, Pennsylvania, 17013, this 6th day of September, 2001, Date: '7 )./0 ) I I ;;JL cd- Ten L. Henning Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 ''''!iI, ,-,re 1'1 [I "' ROSE MARIE PARKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW IN DNORCE AND CUSTODY CLARENCE RAY PARKER, Defendant NO, 01-93 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Rose Marie Parker, Plaintiff, to proceed in forma pauperis. I, Teri L. Henning, of the Family Law Clinic, Staff Attorney, for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal service to the party, Date:* . J ~~ L 0"L . ennmg Staff Attorney .:> THE F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Attorneys for Plaintiff -f ,"- II " _.~~~. .::: CBFP ~_.L t~S- ,..c- [S; l.-.. ~t~~ ~~ I-'-~ J w1e'I;1l1.", ",' .~ ~~~.~~II@_~~''''~i!!1;~WIll~MPL~;W!,lJ;,'#)lf'~_<;1,~J!!~1FJt!.:;;rn~m;~ "- o C" .." IIIiIi!f on :~ '., G" :.n C:) (~ ~f fu1 ROSE MARIE PARKER PLAINTIFF V, CLARENCE RAY PARKER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA 01-93 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, September 10, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland County Courthonse, Carlisle on Thursday, October 18, 2001 . the conciliator, at 10:30 a.m. for a Pre-Hearing Custody Conference, At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to 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. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR TIlE COURT, By: Isl Hubert X. Gilroy. Esq./)tJ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990, For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE 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 ~ifT.i'l~ [' ," ,~. . '-, . ,..,.~ 1'""'1 , ~ 't ..- . . r- . "~''''~''';='~~^' , <<. _. "p~# ~ pr~ , '.~ z'~/?7a, ~ ~. ~ ~w- 4ritp .r; /(/-17/ J /(/-17/-6 /11-(1/ . /J 1fI~^lASNN3d ALNno'J ClNVli::J38Vl/m 1'1 :f; Hd 0 I d3S 10 )1::I\.IiOI'I"'"I;"'," '",. 'I . \ \/_ ,:. "l..1l .L'._.;'-1'J ':';;'~U. jO '''I.U'.' n",l", ,JJ ,~i_,....r'\,J:l jj .,., ~~~~ _~~ Il'J>!'!!!lIfl:'ji!1J~JIIl'llJ.V,M_'ll'jjlll".""""i''':''' ,=_,< ,.. ~_'l"l!ID'1l~~~'m!ilM\'t~",~Io/~\I"~",l':>1')""~" 1'~":1f.",:",-,_.'I"'"<,"""':'r4:W:_\_-'Iffl:~1iI'i11'\'lI",m-H11'1'1'\WIl'~~-H!f''tt{;"'lMW~~~:~ ~M . '!R ., ~ SEP 0 6 2001 f1> (] ROSE MARIE PARKER PlaintifflPetitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CML ACTION - LAW IN CONTEMPT v, CLARENCE RAY PARKER Defendant/Respondent NO, 01-93 CNIL TERM NOTICE AND ORDER TO APPEAR Legal proceedings have been brought against you alleging you have wilfully disobeyed an order of court for partial custody, If you wish to defend against the claim set forth in the following pages, you may, but are not required to file in writing with the court your defenses or objections, Whether or not you file in writing with the court your defenses or objections, you must appear in person in court on at _.M, in Courtroom (Tirue) (Day and Date) IF YOU DO NOT APPEAR IN PERSON, THE COURT MAY ISSUE A WARRANT FOR YOUR ARREST. If the court fmds that you have wilfully failed to comply with its order for partial custody, you may be found to be in contempt of court and committed to j ail, fined or both. YOU SHOULD TAKE TillS PAPER TO YOUR LA WYERAT ONCE, IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD ONE, GO TOOR 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: Date 1. AMERICANS WITH DISABILITIES ACT OF 1990 . The Court of Common Pleas of Cumberland County is required by law to comply with the Amencans with Disabilities Act of 1990, For information about accessible facilities andreasonable 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, I-I I .~'" - . .. ROSE MARIE PARKER Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CNIL ACTION - LAW IN CONTEMPT CLARENCE RAY PARKER DefendantlRespondent NO, 01-93 CIVIL TERM PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF PARTIAL CUSTODY ORDER Petitioner, Rose Marie Parker, hereby brings this Petition for Civil Contempt, and respectfully requests that this Court find Defendant/Respondent, Clarence Ray Parker, in contempt of the January 8, 2001, Court Order, In support of her petition, Petitioner states as follows: 1. On January 8, 2001, The Honorable Kevin A. Hess entered an Order awarding Rose Marie Parker ("Mother"), and Clarence Ray Parker ("Father") shared legal custody of their minor children, Crystal Parker and Mary Parker (the "Children"), and awarding the Father primary physical custody and the Mother periods of partial physical custody, A true and correct copy of the Order is attached to this Petition as Exhibit "A", 2, Under the January 8, 200 I, Order, Mother was granted periods of partial physical custody as follows: a, Mother was granted partial physical custody of the Children every other weekend from Saturday at 8:00 a,m. until Sunday at 6:00 p,m. i. At Mother's option, Mother may exercise one custodial weekend each month at Father's residence, If she does so, she may stay at Father's residence from 5:00 p,m. Friday until 5:00 p,m. Sunday, ii. If Mother's living conditions do not allow her to keep the Children overnight, her weekend custody periods shall be from 8 a,m. to 8 p.m. on Saturday and Sunday, II I "" - -"'''' - ~",.,." " _ H " b, The order also included a holiday schedule defiuing certain holidays when Mother would have partial physical custody of the Children, c, The Order required that each parent's communication with the non-custodial parent be kept open by way of telephone and mail. d, The Order required Mother and Father to inform the other of their current home telephone number and address, work telephone number and address, and any emergency telephone numbers, e, The Order prohibited either party from doing anything which may estrange the Children from the other parent, or injure the opinions of the Children as to the other parent or which may hamper the free and natural development of the Children's love and respect for the other parent. 3, Father has wilfully failed to abide by the Order in that: a, Father refuses to allow Mother to exercise her periods of partial physical custody, b, Father refuses to provide the children's current address or telephone number to Mother, c. Father refuses to allow Mother to communicate with the children by telephone, d, Father is estranging the children from the Mother and hampering the free and natural development of the Children's love and respect for the Mother, e, Upon information and belief, the Father has failed to enroll the children, both of whom are of compulsory school age, in school this year, Nor has Father consulted with Mother regarding any change in the children's education. WHEREFORE, Petitioner requests that: 1, Father be held in contempt of the Court's Order of Custody; 2, Father be ordered to comply with the January 8, 2001 Order; 3, Mother be awarded compensatory partial physical custody time every weekend until further Order of Court, to make up for the wrongful deprivation of custodial r r . time; 4, Father be assessed a $500 penalty for contempt of the Court's Custody Order pursuant to 23 Pa, C.S, 94346, 5, Mother be awarded such other relief that the Court deems appropriate, 6, Father shall immediately enroll the children in school and shall promptly notify Mother as to the school or schools that they are attending, 'i/~/Ol Respectfully Submitted, ;;$:.;.tfl Certified Legal Intern ~ ::J- L i;1 _ ~RT E, RAINS / THOMAS PLACE Supervising Attorney TERI L. HENNING Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 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, 94904 relating to unsworn falsification to authorities. ff(~M,f~ Petitioner Date: .""'11 .-, ',". I-I - . . JiN 0 5 ZDOi!!iJ ROSE MARIE P A~KER, PLAINTIFF :1N THE COURT OF COMMON PLEAS OF . :CUMBERLAND COUNTY. PENNSYLVANIA v, :CNIL AcnON - LAW : CUSTODY CLARENCE RAY PARKER, DEFENDANT :NO.o/- 9J CNILTERM CUSTODY AGREEMENT THIS AGREE.\IENT, made this IS"\- day of't)<,C,,<-; n,\.' (" . 21111U. br:rween , Rose Marie Parker. hereinafter Mother, and Clarence Ray Parker, h~r~il1ali~r Father. concerns the custody of the parties' minor children: Crystal Parker, b"1lI ..\pnl II. l'lS5 and Mary Parker, born February 21, 1986. :-'10ther and Father desire to enter into an agreement as to th~ <:lISh"I\ "fthr:ir minor . - . children and to have this agreement made an Order of the COU!1, \1,llhcr .1II,l fath<:r hr:reby agree to the following' ] \IOlher and Father shall have shart'd legal custody "f th~ .:hdJn:n ~ Father will have primary physical custody ofthe <:hiIJr~n 3. Mother will exercise periods of partial physical CllS!llJy \\ith the <:hildren every other weekend from Saturday at 8:00 a.m. until SunJay at 6:00 p,m.. a, At Mother's option, Mother may exercisr: one <:lIs!l,Jia/ weekend each month at Father's residence, If she does 50. she Imy stay at Exhibit "A" "'->iI'I ~ . Father's resmP,f:,Cr. ,from 5:00 p.rn. Friday until $:00 p.m Sunday. -' . , " b. If Mother's liVing situation does not allow.her to keep the children overnight, her weekend custodial periods (except those exercised at Father's residence) shall be from 8 am to 8 p.m. on Saturday and Sund:iy. 4. Holidav Schedule. Mother and Father will exercise physical custody of the children during holidays in the following manner: a Mother will have physical custody of the children on the following holidays in even-numbered years: Thanksgiving, Christmas Day (3 , p,m. - 8 p.m.), Easter, New Year's Day, and July 4th. b. Father will have physical custody of the children on the following holidays in even-numbered years: Christmas Eve (from 3 p.m. on Christmas Eve until 3 p.rn. Christmas Day), Mernorial Day, and Labor 'Day. c. Mother will have physical custody of the children on the following holidays in odd-numbered years: Christmas Eve (from 3 p.m, on Christmas Eve until 3 p.m. Christmas Day), Mernoiial Day, and Labor Day. d. Father will have physical custody of the children on the following holidays in odd-numbered years: Thanksgiving, Christmas Day (3 p,m. - 8 p.rn.), Easter, New Year's Day, and July 4th, 2 -'.'~, --- """..fl, " / ., . ' , .-,'j-"- " e, Mother will have physical custody of the children.on Mother's Day, . . f. Father will have physical custody of the children on Father's Day. If Father's Day falls during Mother's custodial weekend (and Mother is not exercising that weekend at Father's house), then' Father's custodial period shall begin at 9 am. that Sunday. g, Mother will have physical custody of each child on the Saturday following their birthday each year. 5. Each child's communication with the non-custodial parelll shall be kept open by way of telephone and mail. 6. Mother and Father will at all times inform the other parel\t \,1" their ,:ul1'ent home telephone number and address, work telephol1t: numb.:r and address and any emergency phone numbers. 7. Father and Mother will notify each other of all medical .:are enher .:IlilJ receives while in' that parent's care. Father and Mother \\'illlh>t1IY the <'I her immediately of medical or other emergencies which arise "hile the .:hilJren are in that parent's care. g, Neither party will do anything which may estrange the children li"<lm the other parent, or injure the opinions of the children as to the other p~lrent or may hamper the free and natural ,development of the children's iL1\'e' anJ respect for 3 I-I , ~, .. the other parent Both parties will actively promote such behavior in all other - people with whom the children have contact 9. Father has been informed and understands that the Family Law Clinic represents Mother in this matter. The Family Law Clinic has explained that it does not represent Father and cannot give him any legal advice. Father understands that ifhe wants legal advice on this matter, he must see his own attorney. Understanding this, Father has voluntarily waived his right to seek counsel regarding this matter. , 4 -" ""~,' ,.,"< 1'1 ~" "" "'" ^ ,'~~^,-c_"j _ "'!Il!V" - ., . 10. The pmnes intend to be legally bound by the terms <if this Agre~~~!ltind intend that the agreement shall be made an order of the Court. ~J~~L~fI~ Clarence Ray Park ' 1ft. ~)ov\. f~ Rose Marie Parker ~'13~ . e Miller Certified Legal Intern ~LJ- THOMAS M. PLACE ROBERT E. RAINS , TERI L. HENNlNG Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 ORDER And now, this 8th day of. 3uJu..o..rj--> 200f, the foregoing Agreement is approved d entered as an Order of the Court. , n . 1" 1. 5 , ----" , ' . , ,,~ = ~,. '" . ROSE MARIE PARKER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CNIL ACTION - LAW IN CONTEMPT CLARENCE RAY PARKER Defendant NO, 01-93CNIL TERM CERTIFICATE OF SERVICE I, Teri L. Henning, hereby certify that I am serving a true and correct copy of the petition for civil contempt for disobedience of a custody order on Clarence Ray Parker, by hand delivery at the Cumberland County Courthouse, Carlisle, PA 17013, this 6th day of September, 2001. Date:----=r h. r~ij I ~~![! Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 '.'" ..... . <'~ II' f', ~_.<, ->,,,," ",. ,"~J ,.~,'. '.,' _, """'.'.'h"" "'~-"0--_' o ,,:; .' "Cot' ~:,1,._: ~:- ~> \.~- '~;t--. --/ :-,::', -< mm l'"" Jlftllll, m 1"]11" c/) :~~:(1 Co" \ c;;) ztp , -.!IMI!JII!,. ,,~~..., ',""~'. ~~~~~!l!lll"''!'-'1';',,''~!1;'\W''\~'''I'''.~>:~~,~f\'fj't;''i>!jIi'1!)iL;~~~'!f'!f'f""';~"I:P;;,,,,,,,,"-,=,,,,,,,r,;;-'II~~~ ;" , '. ROSE MARIE PARKER Plaintiff, Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CNIL ACTION - LAW IN CUSTODY CLARENCE RAY PARKER Defendant, Respondent NO, 01-93 CML TERM PRAECIPE TO WITHDRAW PETITION FOR CONTEMPT To the Prothonotary: Please withdraw the Petition for Civil Contempt, filed by The Family Law Clinic, on behalf of Rose M, Parker, on September 6, 2001, in the above captioned matter. Date: September 14, 2001 ~ L tfJI' SM,PLA E ROBERT E. RAINS TERI L. HENNING Supervising Attorneys FAMlLYLAWCLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 '" ,. " -,."", ~_ ~ ;-:. rei . , ROSE MARIE PARKER Plaintiff, Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW IN CUSTODY CLARENCE RAY PARKER Defendant, Respondent NO, 01-93 CNIL TERM CERTIFICATE OF SERVICE I, Teri L. Henning, Family Law Clinic, hereby certify that I am serving a true and correct copy of the Praecipe to Withdraw the Petition for Civil Contempt filed on September 6, 2001 in the above captioned matter, by depositing a copy of the same in the United States mail, first class, postage prepaid, this 14th day of September 2001, addressed as follows: Clarence Ray Parker Bldg, C. Apt. 304 Bast Ridge Avenue Sellersville, P A 18960 September 14, 2001 ~c;J FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 ',c'~!IIl I ^' , ..,.,'- ,.-,,~' ~ ". .'':0, ." - ,,, .~ t"C, 0_- - _~_ -_F,'-':'-''",-' '''''1''','' ~=-",-"" ~~~ft,_ "JlII!t_~" _ ~" ---,-------~-,,~--'" '" '.~....~-~~--~-~~ '""' (") ~ t;?!-~-f; r;'1 " ~i~;' ;::;;6 '<: ?:o );:0 ~ -~ 111-.' ~f 111!Ull" TII'rnr~" , C) i....._-' '" U) '" "0 -j--~ ,~ :)I.:: - ,~~" k__i ~~~'(S ~~l; iSll1 '-, ~> 5::J -< 1~ 'D _u, ~_~_' lJ1!""",,,,,,~ _ . OCT 26W\ ROSE M. PARKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW CLARENCE R. PARKER, Defendant NO. 01 - 93 CIVIL IN CUSTODY COURT ORDER v~ AND NOW, this (<; day of October, 2001, the conciliator being advised the parties have reached an agreement, the conciliator relinquishes jurisdiction. BY THE COURT, '~,~,~ -J";,-~ _ oJ_'. - -, - ""-." ~ _,_ ,--T....I "r. - r !" . ,~ "'~ .,- " " '_' ,~ '0.0'''.'0._'''_' . ."." ~,. '..' ",~.__ () r'- ~ :-0 "' "7 q:' -;;:.. r.! <:'--'.1 ;2:--=:- V) S-~, ~(S :20 $"Q :? ~ ~f ,."",.-- "Jf'[i o () ';"1 -', <:::> :-, -< "-, Cr, ~,-~,';: .1.";1:" ::t': - - '5;-:"i , j- ',~IS_~) ;~} ~is' cjrrl ~ .:;:; -<: ,'\) (-0 ~, !J!l1P.l~~I'\I~_jl\''''''''I''f'f!f~!!'If''~l"_!,~,,,,,J'I!'jlpl~~m!i'i!OO!"l'm~~~,' ~ -'~'1';~ . , ROSE MARIE PARKER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 01-93 CIVIL ACTION LAW CLARENCE RAY PARKER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, November 21, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, December 14, 2001 , the conciliator, at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to defme and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and aU ensting Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Hubert X. Gilroy. Esq. 'ifY'^ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court, You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE 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:~,"' '~,! ,_ " ' -- . - ~~ , 1'1 -~~ " ~, I'" ~~.fI. ~ ~I#; # ~ ~lI1I ~?/h X'p$ r~ iwv.r;; \lIN\I^l^8NN::Jd }J.NnOCl Oi\i\Il}lj8if'1f\::J ^C 'Z\II J ~-;" "'I \. ~.:l'..J I,l} (I b<JI\Utif U AHVlq:\~;{:,i()...(]-j'';!::J .~ &. ,. .. ' ,.-,,,-^' -,'" -~ --- ~,~ ,~ ,. '"'''' rt . /O-.pt'- J/ Jt?-,}('-J! /(l'b'C'-J/ -~, _ " ~,~ I ,Ji;~I'I1""'J!lIIIiftIIl'III-.,_ ~~ 'lWt"''1!'....W.'l!''~'fl ~_IIllI!II'i!lif~' _ ~~Ol;l~'~1l'r"'i-"',.''fK,-1',''''' ''''''''"''':I'C'''_;',''''~';'J'W ''',''', :"'!f'-''''''m::J''"~~'~!~''''~f1,,"ffi'r.~,,",~.;ow-l'1R!'>1m~>JIl~1~'';' 'I lWJV 1 4. Z ~i},;, 'v..- i v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CONTEMPT ROSE MARIE PARKER Plaintiff/Petitioner CLARENCE RAY PARKER Defendant/Respondent NO, 01-93 CNIL TERM NOTICE AND ORDER TO APPEAR Legal proceedings have been brought against you alleging you have wilfully disobeyed an order of court for partial custody, If you wish to defend against the claim set forth in the following pages, you may, but are not required to file in writing with the court your defenses or objections, Whether or not you file in writing with the court your defenses or objections, you must appear in person in court on (DayaudDate) (Time) _,M, in Courtroom at IF YOU DO NOT APPEAR IN PERSON, THE COURT MAY ISSUE A WARRANT FOR YOUR ARREST. If the court finds that you have wilfully failed to comply with its order for partial custody, you may be found to be in contempt of court aud committed to j ail, fined or both, YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYERORCANNOT 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: Date 1. AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the AmeIicans with Disabilities Act of 1990. For information about accessible facilities andreasonable 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 auy hearing or business before the court, You must attend the scheduled conference or hearing, '" ~ ROSE MARIE PARKER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CNIL ACTION - LAW IN CONTEMPT CLARENCE RAY PARKER Defendant NO, 01-93 CNIL TERM ORDER OF COURT AND NOW, this day of , 2001, upon consideration of the attached Petition for Civil Contempt for Disobedience of Custody Order, it is hereby ordered as follows: 1 Defendant is held in contempt of the Court's January 8th and September 6th, 2001 Custody Orders. 2 Defendant is ordered to comply with both the January 8th and September 6th, 2001 Custody Orders, 3, Defendant, Clarence Ray Parker, is ORDERED to transport Crystal Parker and Mary Parker to the residence of Rose Marie Parker on Saturday, November ----" 2001, and shall pick them up at the residence on Sunday November ---' 2001, and shall do the same every weekend thereafter until further order of this Court, 4, Defendant is assessed a $500 penalty for acting in contempt of the Court's Custody Order pursuant to 23 Pa, C.S, g 4346, BY THE COURT, 1. , ~-'r_" -l ..~~~ r" ,"' n. ~. ~ - ~ ROSE MARIE PARKER Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CNIL ACTION - LAW IN CONTEMPT CLARENCE RAY PARKER Defendant/Respondent NO, 01-93 CNIL TERM PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF CUSTODY ORDER Plaintiff/Petitioner, Rose Marie Parker, hereby brings this Petition for Civil Contempt, and respectfully requests that this Court find Defendant/Respondent, Clarence Ray Parker, in contempt of the September 6, 2001 and January 8, 2001 Court Orders, In support of her petition, Petitioner states as follows: 1, Rose Marie Parker ("Mother") and Clarence Ray Parker ("Father") are the biological parents of Crystal Parker, born April 11, 1985 aud Mary Parker, born February 21,1986 ("the Children"), 2, On January 8, 2001, pursuaut to the consent of the parties, this Court entered an Order awarding the parties shared legal custody of the Children and awarding Father primary physical custody and Mother periods of partial physical custody, A true and correct copy of the January 8,2001 Order is attached to this Petition as Exhibit "A", 3, Under the January 8, 2001, Order, Mother was grauted periods of partial physical custody as follows: a, Mother was grauted partial physical custody of the Children every other weekend from Saturday at 8:00 a,m, until Sunday at 6:00 p,m. b, The Order also included a holiday schedule, c, The Order required that each child's communication with the non-custodial parent be kept open by way of telephone and mail. d, The Order required Mother aud Father to inform the other of their current home telephone number and address, work telephone number and address, and - i'" --''''1~" II , - " any emergency telephone numbers, e, The Order prohibited either party from doing anything which may estrange the Children from the other parent, or injure the opinions of the Children as to the other parent or which may hamper the free and natural development of the Children's love and respect for the other parent. 4, On September 6, 2001, the Family Law Clinic, on behalf of Mother, filed a Petition for Special Relief and a Petition for Contempt against Father, because Father: a) was refusing to allow mother to exercise her periods of partial custody; b) was refusing to provide mother with the children's address or telephone number; c) was refusing to allow Mother to communicate with the children by telephone and; d) had failed to enroll the Children, both of whom are compulsory school age, in school. 5, After a hearing on September 6, 2001, this Court entered an Order requiring Father to: a) allow Mother to make telephone calls to the children; and b) transport the children to Mother's residence every other Saturday and pick them up Sunday, The September 6,2001 Order further provided that failure of Father to comply with the terms of the September 6, 2001 order and the January 8, 2001 Order may result in fme and/or imprisonment pursuit to 23 Pa.C.S, {}4346, A true and correct copy of the September 6, 2001 Order is attached as Exhibit "B", 6, Father has wilfully failed to abide by the January 8, 2001 and September 6, 2001 Orders in that: a, Under the Orders Father was required to bring the Children to visit Mother on the following weekends: September 8lh to the 9th, September 22nd to the 23'd, October 6lh to the 7lh, October 20lh to the 21 'I, and November 3,d to the 4lh, Of those five weekends, he failed to bring the children for a visit on three of them, September 22nd to the 23'd ,October 20lh to the 21 ,t , and November 3'd to the 4th, a, Father has allowed the Children to speak to the Mother over the telephone on only one occasion, The call lasted only one to two minutes before Father made the Children end the call. b, Father is estranging the children from the Mother and hampering the free and natural development of the Children's love and respect for the Mother. d, Upon information and belief, the Father failed to enroll the children, both of whom are >""" i ,~. ". ~, ~ I-I --1Il!I!\I!lII'ft " of compulsory school age, in school until October 16, 2001, The Children were not enrolled in school for over a month's time, Moreover, Father has failed to consult with Mother regarding any change in the children's education, WHEREFORE, Petitioner requests that: 1. Father be held in contempt of the Court's January 8 and September 6, 2001 Orders of Custody; 2, Father be ordered to comply with the January 8 and September 6, 2001 Orders; 3, Mother be awarded compensatory partial physical custody time every weekend until further Order of Court, to make up for the wrongful deprivation of custodial time; 4, Father be assessed a $500 penalty for contempt of the Court's Custody Order pursuant to 23 Pa, C,S, g 4346; and 5, Mother be awarded such other relief that the Court deems appropriate, Respectfully submitted, \\- V-\-O\ Date uoO,,, ~A:k ~~ Debra Hart Munchel Certified Legal Intern ~L~/ , S M, PLACE ROBERT E, RAINS TERI L. HENNING Staff Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 f"!<,- ~>.I. ~ '0 _," II "I , ,~" ' ,~~~ 11", ~ "" _ ~ ~-:- 1J\l 11 5 ZOO; t!J ROSE MARIE PARKER, PLAINTIFF :IN THE COURT OF COMMON PLEASJF . :CUMBERLAND COUNTY, PENNSYLVANIA v, :CMLACTION -LAW : CUSTODY CLARENCE RAY PARKER, DEFE1'\DAl\T :NO,DI- qj CIVIL TERM CUSTODY AGREEMENT THIS AGREDIE'iT, made this I a'\- day of\:~\<,,,-,, 1"\" \ . 211110. bet\\een Rose Marie Parker. hereinafter Mother, and Clarence Ray Parker. h<:n:inalkr F'llh~r. concerns the custody of the p:uties' rninor children: Crystal Park<:r. b,'1ll ,\ pn I I I. l'IS5 and Mary Parker. born February 21,1986, \Iother and Father desire to enter into an agreement as to th<: eus!."ly ,,(their minor children and to ha\'e this agreement made an Order of the COU!1 \ I I ,t h~r .llhl ('Ilh,,' hereby agree to the following 1 \'Iother and Father shall have shared legal custody l'( the dnklr<:n , Father will have primary physical custody of the childr<:n 3 \Iother will exercise periods of partial physical custlldy \\ith th~ children every other weekend from Saturday at 8:00 a.m, ulllil Sunday at (J:OO p,m.. a, At Mother's option, Mother may exercise nnl: cUSIIldial weekend each month at Father's residence, If she does so. sh<: Illay stay at I 8 )L \,-,,\\0 ,t Ii\ f\ l^ _.e~. -~-''''-_. - , FTI 1-- . Father's r;:s;':"~'~ fh'm 5:00 p.rn. Friday until 5:00 p.m. Sunday. b. If Mother's FVing situation does not allow her to keep the children overnight, her weekend custodial periods (except those exercised at Father's residence) shall be from 8 a.m. to 8 p.m. on Saturday and Sunday. 4. Holiday Schedule. Mother and Father will exercise physical custody of the children during holidays in the following manner: a. Mother will have physical custody of the children on the following holidays in even-nmnbered years: Thanksgiving, Christmas Day (3 p.m. _ 8 p.m.), Easter, New Year's Day, andJu1y 4th. b. Father will have physical custody of the children on the following holidays in even-numbered years: Christmas Eve (from 3 p.m. on Christmas Eve until 3 p,m. Christmas Day), Memorial Day, and Labor 'nay, c. Mother will have physical custody of the children on the following holidays in odd-numbered years: Christmas Eve (from 3 p.m. on Christmas Eve until 3 p,m. Christmas Day), Memoiial Day, and Labor Day. d. Father will have physical custody of the children on the following holidays in odd-numbered years: Thanksgiving, Christmas Day (3 p.m. - 8 p.m.), Easter, New Year's Day, and July 4th, 2 --,~"'-- '1" . ~'-:.;- II " -tilL " ". Mother will have physical custody of the children on Mother's Day, f Father will have physical custody of the children on Father's Day, If Father's Day falls during Mother's custodial weekend (and Mother is not exercising that weekend at Father's house), then Father's custodial period shall begin at 9 a.m. that Sunday, g. Mother will have physical custody of each child on the Saturday following their birthday each year. 5. Each child's communication with the non-custodial parent shall be kept open by way of telephone and mail. 6. Mother and Father will at all times inform the other parent <,f their elltTent home telephone number and address, work telephone IllIl11ber ,md address and any emergency phone numbers. 7, Father and Mother will notify each other of all medical care elther child receives while in'that parent's care, Father and Mother \\t1ln<'t1I\ the l,ther immediately of medical or other emergencies which arise \\hik the children are in that parent's care. 8. Neither party will do anything which may estrange the chilJren fl'<)111 the other parent, or injure the opinions of the children as to the other parent 01' may hamper the free and natural ,development of the children', k)\'e and respect for 3 ~,^-,,.,,., 0;':->1. ,- [-I -tiL I I r '-~....,.""'"""'=' the other parent. Both parties will actively prornote such behavior in all other people with whom the children have contact. 9. Father has been informed and understands that the Family Law Clinic represents Mother in this matter. The Family Law Clinic has explained that it does not represent Father and cannot give him any legal advice. Father understands that if he wants legal advice on this matter, he must see his own attorney. Understanding this, Father has voluntarily waived his right to seek counsel regarding this matter. 4 ......... ~ '-'."" ...' ,~ II "I"il!I~ ... 10. Theptitics intend to be legally bound by the terms cifthis Agleu. ~IlU' intend that the agreement shall be made an order of the Court. ~~I/J~4"L~ct~ Clarence Ray Park ~~'1N\-f~ Rose Marie Parker . \ . :/ YJ1~- Certified Legal Intem 0- Lx/- THOMAS M. PLACE ROBERT E. RAINS . TERI L. HENNING Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 ORDER 8th ,- r. And now, this day of _ .J:l..Nu.o..r1--> 200f, the foregoing Agreement is approved d entered as an Order of the Court. ~~'.. II J. 5 J .. " .. ",.~m ~"" "-,~ '. -""'ill~ _,~ . }{;\ '.' pu ROSE MARIE PARKER Plaintiff, Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CML ACTION - LAW IN CUSTODY CLARENCE RAY PARKER Defendant, Respondent NO. 01-93 CNIL TERM ORDER OF COURT AND NOW, this ~ day of ~~tr"\,....( 2001, upon consideration of the attached Petition for Special Relief, it is hereby ORDERED as follows: 1. Defena!ll.:it, Cl"'''llce ltay Falke!, i3 ORDBRED tel ilk w~i:h f:b.i~ Cuwl iilld seI ye un eOOfisllI. fer Rese M""1" ParKer by the elld uf the s'lsmess <;1;1;;' in which hI; is serv64, the tltlS aRQ ('Qrr"d ~c1c1re.... "nil ]'!heRe Rmnber where he, ClyslaiParker and Mary f ",,1.."1 "'C" _ noielffi.g. He is Ordered to allow Rose Marie Parker to send aB4-l'@6er;e telephone calls to and from their children, 2, Defendant, Clarence Ray Parker, is ORDERED to transport Crystal Parker and Mary .." Parker to the residence of Rose Marie Parker at g,eQ Q,m., Saturday, Sqstemsllr 2, ')01\,1, and pick them up at that residence at 6:eQ p,m. on Sunday, g"ptemsllf 9, 2901, llI'la.L 11- c1n th.. ~\Il;Re every weekend thersafter until further order of this Court. " ' cA~ 3, Failure of Defendant, Clarence Ray Parker, to comply with the terms of this Order and the Court's Order of January 8, 2001, may result in fine and/or imprisonment pursuant to 23 Pa,C,S. ~ 4346, " ~1- \,,)o.t "~ r I _~r :- " ,'r~~"'iI1:~_ :it 0'" ~ j 4, parties A day of all appear in person. U",___.\\c....,.Ic:,'-""' "'~\ ~ ~'\v<--c,~ \PI q-^.\:~ ,,?,,,,,,:t, . BY THE COURT, /s/ 'frL.,~ a ~ I I 1. \. f:P'!! H:'; t:"''''-"..'~,i':':...''',1 rt-""" _".., ~ t ~~ft[!.:"; ~\.,,~, ~;?-,,1.,r 1:""R"!i( ",~-I(' !i'."';f!'-"".l"";""....~H) ~~;,;:~~";J)~"~;'~):Jr;(;;, ; ;;~:'~~';;i~:',~;:.~:~;~ :,;';r:d adJ. ~1it~~ $C~\ 01 Sai~i t~i'1:'Hl'f '~;d' \...._.,,.I'~-~I.. ~~~',." r~'. -... ."" ", "~..~ .. ;:;,.." ,JfAi ~~-, kJ 1{1. ..," q d' ,. I j ,:.";)._ - I; :.fi-l t:~' ..",,~- - ...:;" ,,-'~ "1.L-<_ ,-, ,~i 't'<-t2. "'.'H ~-_ - ~...,..~ PmthonotiJfj 1'1 ---~---~ VERIFICATION I verifY that the statements made in this Petition for Civil Contempt for Disobedience of Custody Order are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C,S, ~ 4904 relating to unsworn falsification to authorities, Date: ;1 / ~f / !j J l} ,_ _ '\ 1_).) \... 11/1 C\ r' j C 1") {, r j< .;2_ },-., Rose Marie Parker I ,;''lill\ ~ i- ~ , I-I . ,. ROSE MARIE PARKER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CNIL ACTION - LAW IN CONTEMPT CLARENCE RAY PARKER Defendant NO, 01-93 CNIL TERM CERTIFICATE OF SERVICE I, Debra Hart Munchel, hereby certifY that I am serving a true and correct copy of the Petition for Civil Contempt on Clarence Ray Parker at Building C, Apartment 304, East Ridge Avenue, Sellersville, Pennsylvania, 18960, by depositing a copy of the same in the United States mail, this 14th Day of November, 2001. Date: \\- \4- D\ "\)~~I~1 ~ Debra Hart Munchel Certified Legal Intern F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 -r"~~ II ~ 4~ ~ ROSE MARIE PARKER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 01-93 CIVIL ACTION LAW CLARENCE RAY PARKER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, December 04, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland Connty Courthouse, Carlisle on Friday, December 14, 2001 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or ifthis 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. The court hereby directs the parties to furnish any aud all existing Protectiou from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearin!!. FOR THE COURT, By: Isl Hubert X Gilrov. Esq. Ql'V' 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 infomlation 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 VE 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 ! \,- II -," ~ ^'--~ '-'1""" --. _d-<~~ ""-',-,- u"-".," ,- "~M____' "'~, .~ _'H~=< kft~cwl-r ~l-r; ~ ~:# :~44p 71~' u~~ Z ~ ~)t, X~$~~oF9 VINVAlASNN3d JJ,NnC() CJP'!l!::8Vin:J I' ,:' .f.' !,J..! h,- 'J...I:10 10 v 'yo i~'~J I ' AH710>-j~>.:>~.'.:.,.-:',; - :K) :J:.::U.O-lI:u,I.:J "'llmlT' ;~ . ~il /17//- e/ I&? p- 0 /t?-fi-Cf _[~=:-_ .~~_,. 1"'~_"1"',~I!!!I!~WIW~!'-~$f_11,.__~.",.~'lI'I"",,~~Q!~~~;"'i"'j"""",~"-",m'~"n";",,.'p"n~'~"!';";i'l'f{",,jffl\';;~'"!Jf~5~iW:1-'F.l~!Vf;~ ItJ . ' :""'~ , - NOV 1 4 200l1)v ROSE MARIE PARKER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CML ACTION - LAW IN CUSTODY CLARENCE RAY PARKER Defendant NO, 01-93 CNIL TERM ORDER OF COURT AND NOW, this day of , 2001, upon consideration of the attached Petition for Special Relief, it is hereby ordered as follows: 1, The Cumberland County Sheriff is ordered to depqtize the Bucks County Sheriff to serve the Petition for Special Relief and this Order on the Defendant, Clarence Ray Parker, at the following address: Building C, Apartment 304 East Ridge Avenue Sellersville, P A 18960 2, A hearing regarding this Petition for Special Relief is hereby scheduled for the day of 0' clock m, III ,2001 at Courtroom Number , Cumberland County Courthouse, Carlisle, Pennsylvania 17013, at which time the parties along with their legal counsel shall appear in person, BY THE COURT, J '-", ",.'-1; -~[~ -, ,,, _" .,- "-I"'''^I,h'':<''--^_''':'',,'T ' -''I' ".,. .. ;~"~, ~" ",-"-, - .'C , > ROSE MARIE PARKER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CNIL ACTION - LAW IN CUSTODY CLARENCE RAY PARKER Defendant NO, 01-93 CNIL TERM ORDER OF COURT AND NOW, this day of .2001, upon consideration ofthe attached Petition for Special Relief, it is hereby ordered as follows: 1, Defendant is ordered to comply with both the January 8th and September 6th, 2001 Custody Orders, 2, Defendant, Clarence Ray Parker, is ORDERED to transport Crystal Parker and Mary Parker to the residence of Rose Marie Parker on Saturday, November ~ 2001, and shall pick them up at the residence on Sunday November --' 200 I, and shall do the same every weekend thereafter until further order of this Court, BY THE COURT, J, "'~ 1""~ " , "~ ., .~>,. _' T ~r"1 ' ~- . r 'c' ~c - _",0,"_.'_ ROSE MARIE PARKER, Plaintiff, Petitioner :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v, :CNIL ACTION- LAW :IN CUSTODY CLARENCE RAY PARKER Defendant, Respondent :NO, 01-93 CNIL TERM PETITION FOR SPECIAL RELIEF PURSUANT TO PA R.c.P. 1915.13 AND NOW, this 14th day of November, 2001, pursuant to Rule 1915,13 of the Pennsylvania Rules of Civil Procedure, comes the Petitioner, Rose Marie Parker, by her attorneys, the Family Law Clinic, seeking emergency partial physical custody of her minor children, Crystal Parker and Mary Parker, and presents the following Petition for Special Relief: 1, The petitioner is Rose Marie Parker, an adult individual who resides at 408 Third Street, Apt. B, West Fairview, Cumberland County, Pennsylvania. 2, The respondent, Clarence Ray Parker, is an adult individual who formerly resided at 408 Third Street, Apt. B, West Fairview, Cumberland County, Pennsylvania, and whose current address is Building C, Apartment 304, East Ridge Avenue, Sellersville, Bucks County, Pennsylvania, 18960, 3, The petitioner is the biological mother (the "Mother") of the minor children, Crystal Parker and Mary Parker, bom April 11, 1985 and February 21, 1986, respectively (the "Children") , 4, The respondent is the biological father ( the "Father") of the Children, 5, On January 8, 2001, The Honorable Kevin A. Hess entered an Order awarding Mother and Father shared legal custody of the Children, and awarding the Father primary physical custody and the Mother partial physical custody, A true and correct copy of the January 8, 2001 Order is attached to this Petition as Exhibit "A", 6, Under the January 8, 2001 Order, the Mother was granted periods of partial physical custody, including every other weekend from Saturday until Sunday, and certain holidays, V31""! " '''~--,~- "-^'~,1:"-0)~>', e._~' _ ^' ',"'_~ - , ' - : ~"'I"'1')". _7'_'~ 1-_".-" ~- , ,~-__ __ . " !' ,. ~ ,- .' ,~ 7, On September 6,2001, the Family Law Clinic, on behalf of Mother, filed a Petition for Special Relief and a Petition for Contempt against Father, because Father: a) refused to allow Mother to exercise her periods of partial custody; b) refused to provide Mother with the Children's address or telephone number; c) refused to allow Mother to communicate with the children by telephone and; d) had failed to enroll the Children, both of whom are compulsory school age, in school. 8, After a hearing on September 6,2001, this Court entered an Order requiring Father to: a) allow Mother to make telephone calls to the children; and b) transport the children to Mother's residence every other Saturday and pick them up on Sunday. The September 6, 2001 Order further provided that failure of Father to comply with the terms of the September 6, 2001 Order and the January 8, 2001 Order may result in fine and/or imprisonment pursuit to 23 Pa.C.S, S4346, A true and correct copy of the September 6, 2001 Order is attached as Exhibit "B", 9, Despite the Court's January 8, 2001 and September 6, 2001 Orders, Father has continued to violate the terms of both Orders, 10, Pursuant to the January 8, 2001 and the September 6,2001 Court Orders, Father was required to bring the children to Mother's residence beginning September 8,2001, and every other weekend after that. Iu violation of that Order, Father did not bring the Children to Mother's residence on September 22ftd to the 23'd ,October 20'" to the 21't , and November 3,d to the 4th Nor did he call to inform Mother that he would not bring the Children, Father did bring the children to see Mother on the weekend of September 8 and October 6, 2001 but has failed to bring them any other weekend, 11, On or about October 5, 2001, the Family Law Clinic contacted the Father to remind him of his obligations under the Orders, He refused to bring the children to visit with the Mother and became increasingly agitated during the conversation, 12, In violation of the September 6,2001 Order, the Father has refused to allow the Mother to make telephone calls to the children, To date, he has allowed one phone call, only one minute to two minutes in length, During the call, Mother heard him telling the Children what to say to the Mother, 13, The Mother believes and avers that it is in the best interest of the children that she be :, !I? -,. - r,~' -,M-"",", ..'.-' " <-<1',"1'11"--,"'_' ,-',' >1 " ~ r< allowed the partial physical custody provided under the Custody Orders of January 8, 2001 and September 6, 2001. 14, The Mother believes and avers that it is in the best interest of the children that she be allowed compensatory partial physical custody time every weekend, beginning on November 24'h, 2001 and continuing thereafter until further order ofthe Court, WHEREFORE, Petitioner, Rose Marie Parker, respectfully requests that: 1. Father be ordered to comply with the January 8 and September 6, 2001 Orders; 2, Mother be awarded compensatory partial physical custody time every weekend until further Order of Court, to make up for the wrongful deprivation of custodial time; 3, Mother be awarded such other relief that the Court deems appropriate, Respectfully submitted, \V\L-\-a\ Date Debra Hart Munchel Certified Legal Intem ~LIV MAS M, PLACE ROBERT E. RAINS TERI L. HENNING StaffAttomeys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013-2899 (717) 243-2968 I:w, ,.~,~,_, "'" ,'-" , ,_" . . ,_,,-, 0"'", '.,-~- ,~ -~_, i~-'- . _"~, ,. ~~,',':"'I",' ,_'_ _~, _ J c ,,~ .. ,,,. .."i...... 1!"il!lTr_ (In, (1 r:: ?tJ'f,i f/) ,~ d >>-'...0; i ROSE MARIE PARKER, PLAINTIFF :IN THE COURT OF COMMON PLEAS OF . :CUMBERLAND COUNTY, PENNSYL VANIA v, :CNIL ACTION - LAW : CUSTODY CLARENCE R.-\ Y PARKER, DEFE1\DA1\T :NO,OI- 9,3 CNIL TERM CUSTODY AGREEMENT THIS _-\GREE\IE~T. made this I 8-'\- day of~Q.~" ",\ -' \ . :::!lIiU. between Rose ~1arie Parker. hereinafter Mother. and Clarence Ray Parker. h':l'l:inalkr F'llher. concerns the custody of the parties' minor children: Crystal Park.:r. b, 'Ill ,\pl"ll II, 1 'lS5 and Mary Parker. born February 21,1986. \1 other and Father desire to enter into an agreement as ILl th.: elbl, ,,1\ "f their minor children and to have this agreement made an Order ofthe Coun. \h,th.:r .11],1 Lllher hereby agree to the following I \lother and Father shall have shared legal custody "f th.: \:IlIldren , Father will have primary physical custody of the chilJr.:n 3. Mother will exercise periods of partial physical CUSl\\Jy \lith th.: children evel)' other weekend from Saturday at 8:00 a,m, until SunJ:1Y 'll baa p,m.. a, At Mother's option, Mother may exercise nn.: cusIllJial \\'eekend each month at Father's residence, If she does so. sh.: may stay at y.. l\ [x.\-..,I,.,.-r A ...._-,-- . . -"II ~r r . Father's rp's;(:~rp jj'''ffi 5:00 p.m. Friday until 5:00 p.m. Sunday, b. If Mother's liVing situation does not allow her to keep the children overnight, her weekend custodial periods (except those exercised at Father's residence) shall be from 8 a.m. to 8 p.m. on Saturday and Sunday. 4. Holidav Schedule. Mother and Father will exercise physical custody of the r.hi!dre.n duringlioli4a,ys in the following manner: a Mother will have physical custody of the children on the following holidays in even-numbered years: Thanksgiving, Christmas Day (3 p.m, - 8 p.m.), Easter, New Year's Day, and July 4th. b. Father will have physical custody of the children on the following holidays in even-numbered years: Christmas Eve (from 3 p.m. on Christmas Eve until 3 p.m, Christmas Day), Memorial Day, and Labor 'nay. c. Mother will have physical custody of the children on the following holidays in odd-numbered years: Christmas Eve (from 3 p.m, on Christmas Eve until 3 p.m Christmas Day), Memonal Day, and Labor Day. d. Father will have physical custody of the children on the following holidays in odd-numbered years: Thanksgiving, Christmas Day (3 p.m. - 8 p.m.), Easter, New Year's Day, and July 4th, 2 ..--"'.... -tIiL --Wtlill:,~~ . I-I -', I' I ", Mother will have physical custody of the children on Mother's Day, f. Father will have physical custody ofthe children on Father's Day, If Father's Day falls during Mother's custodial weekend (and Mother is not exercising that weekend at Father's house), then Father's custodial period shall begin at 9 a.m. that Sunday, g, Mother will have physical custody of each child on the Saturday , following their birthday each year, 5. Each child's communication with the non-custodial parent shall be kept open by way of telephone and mail. 6, Mother and Father will at all times inform the other parent, ,f their clllTent home telephone nUffiberand address, work telephone numher ,me! ae!Jn:SS and any emergency phone numbers. 7, Father and Mother will notify each other of all medical care either chilJ receives while in'that parent's care, Father and Mother \\dln,'t1I\ the "ther immediately of medical or other emergencies which arise \\ hile the chilJren are in that parent's care. 8. Neither party will do anything which may estrange the ehilJren fn)1l1 the other parent, or injure the opinions of the children as to the other parent vI' may hamper the free and natural.development of the children's kn'e anJ respect for 3 .;':~ ~ :""<'lijl~! II ~. ~ the other parent. Both parties will actively promote such behavior in all other people with whom the children have contact. 9. Father has been informed and understands that the Family Law Clinic represents Mother in this matter. The Family Law Clinic has explained that it does not represent Father and cannot give him any legal advice. Father understands that if he wants legal advice on this matter, he must see his own attorney. Understandingthis,Father has voluntarily waived his right to seek counsel regarding this matter. 4 ..~~ -tk.:- :','4\1>1' I r 1 ' ~ ~." , . : : -"~' "~"'''''''' ~ 10. Theplitics intend to be legally bound by the terms cifthis Aglen, , ',;~Q.U: intend that the agreement shall be made an order of the Court. ~~~4"L~'I~ Clarence Ray Park j, ~ '}'V\ - 'f ~ Rose Marie Parker , \ ~\;j YJ1~- ~e'lVlllier- "',' " , , " " , '" ',..,' ,_u.. Certified Legal Intern ~LJ- THOMAS M. PLACE ROBERT E. RAINS TERI L, HENNING Supervising Attorneys FAMTI.. y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 ORDER And now, this gth day of. ~u.o..r~ 200~, the foregoing Agreement is approved d entered as an Order of the Court. r I l' 1. 5 , ~ "/ , ,Y,,,.) jl,iJ. )1: . 8 Z[JOi I/{/ ROSE MARJE P ARKBR Plaintiff, Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CNIL ACTION - LAW IN CUSTODY CLARENCE RAY PARKER Defendant, Respondent NO. 01-93 CNIL TERM ORDER OF COURT AND NOW, this ~ day of ~tr"~ 2001, upon consideration of the attached Petition for Special Relief, it is hereby ORDERED as follows: 1, DBfetldu.....l, Cld.l"uce Kay fil11..Cl, is ORDERED t6 fik w~th !hi, Cuwl and s,,-, v" un effiHlslll fer Rsae .1;1"";,, Parker by (1\" "ud u[!:he B>1~iness day if! '.~".IliCR RIl is SElf'.'IlEl, the tHle aJl.Q en"",,) adc1ress ong pB.l3Re =10", where he, Cly.la:! rarker and Mary F ""1.",, <11" _ F6BiBiBg, He is Ordered to allow Rose Marie Parker to send afla rBeeY-.'8 telephone calls to and from their children, \ 1 2, Defendant, Clarence Ray Parker, is ORDERED to transport Crystal Parker and Mary " d^ Parker to the residence ofRo~e Marie Parker !It 8.89 a.m., Saturday, S~t_ellf 11, 'JOn..l, and pick them up at that residence at 6: ee jl,m. on Sunday, -S"pt.emeer 9, 2991, lII\.8 .hJ R ..1" th" ~a'lile every weekend th",e!liiiGf until further order of this Court. /\ ,. ok\-.tf 3, Failure of Defendant, Clarence Ray Parker, to comply with the terms of this Order and the Court's Order of January 8, 2001, may result in fine and/or imprisonrnent pursuant to 23 Pa,C,S, ~ 4346, ',< ~ ". f\(,\--..,\,,\- " ... ~ - 1- ., " ~ ,"'" '<,' r I ~ ~~<~~ . I ,o'l . . 4, ~ C parti~ along with their legal co all appear in person. ~<.:---.\\.,J;\", "''''"'\ ~ ,,\~..k.o}. \,pI <!--\~\-.....-- '?-'.tl. BY THE COURT, /5/ iJm"'; 0 ~ J / 1. \ \ \ . !R~JE Copy FROM RECORD In ,e"'t/'"n'lU \' . f I ' . "~" "<<,,, ,1I1er~()., . neff, iHlto Sfit l11y' h;M1d illl"d ,ne seal 01 smd Court at C ""F~l" l:'~ TI1'. 1 '" ~.:...:. -"'~""'''' r". ""'- ) ,:~ay (Jf~.M1;::'!,~ ~ 'j t/ ~#~_ ProtholllJtarf ,( '.,!W~~~ ~. """; 1"1 , l' ~ , . VERIFICATION I verifY that the statements made in the foregoing Petition for Special Relief are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S, 94904, relating to unsworn falsification to authorities, Date: /1/ '1 / () I ~ cse.;i1 " y- '1 e p <; Y' 1< <<.-y- Rose Marie Parker }VliI '" ,u",:,"",;"",",,,,,~.~.,," ,~ '.-_~, 'i " 1"1'1' __'__7"U '":-t''' ' ,,-"~ ~1 'I.' <- " ROSE MARIE PARKER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW IN CUSTODY CLARENCE RAY PARKER Defendant NO, 01-93 CNIL TERM CERTIFICATE OF SERVICE I, Debra Hart Munchel, hereby certify that I am serving a true and correct copy of the Petition for Special Relief on Clarence Ray Parker at Building C, Apartment 304, East Ridge Avenue, Sellersville, Pennsylvania, 18960, by depositing a copy of the same in the United States mail, this 14th. Day of November, 2001, Date: \\:- \1...\- 0\ DOO"'~~JI*"~~ Debra Hart Munchel Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717/243-2968 " 1 f ~, , > ,0 ,. - .. ~ ,,~ -.". - ~ rl ' - --1-' or'" - "~,W",""o_,-.",.,~ ,"~_~' ~",,, .. -"ii, '''''"':~~~'' (") c- <'" "'tJcf; gJni ~--. :,1..1 2'~- (j).':t-. :<-' r=:c:'j j;: --' ,"":;0' l) i~~ -( S-.J c- (J') a - o "1'1 ::;j 1~'-;"i.l1 ;;e c.:> <<:: .s.:."~ /~23 jJ~~ 2:~~~ i.:! ~ -"\J ~"'>-" f) l(J ~l _,",I'!'_~~)~f1!I!MjlI'If.Iil ~,!1J!I!l!li,_.~ ll~ .. ~~""': . ~I'::>r '" ~~j;:? SHERIFF'S RETURN - OUT OF COUNTY .CASE NO: 2001-00093 P , COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PARKER ROSE M VS PARKER CLARENCE R R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named RESPONDANT , to wit: PARKER CLARENCE R but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of BUCKS County, Pennsylvania, to serve the within ORDER OF COURT On December 27th, 2001 , this office was in receipt of the attached return from BUCKS Sheriff's Costs: Docketing Out of County Surcharge 18.00 9.00 10.00 .00 .00 37.00 12/27/2001 FAMILY LAW ~ So answe . '. R. homas Kline Sheriff of Cumberland County Sworn and subscribed to before me this :J~ day of h ,2{)O;0 A.D. ~uQ'huh~~ ~. Prothonotary '~'~f1[,_ 1 _ " , " ~ 1- I....~. ~ s ~ (' 201 DATE~ 12/18/2001 TH4E: 1'1:58 , SH~~Ie~s OFFICE - lAW~ENCE R4 ..DMINISTRATlJ"l :ll DO YL EST'JWN. P A 18' Action Plaintiff Civil - Custody RnQp M~r;e Par~~r ~UCK~ MISC DOCKET # 2001 33316 LDCATION: CUT 01 vs Delendant Clareflee Ray Parker Duildlu5 C, Al'l. J04 &::; l IU<.1ge Avenue Sellersvllle, ~a 18960 Address Served il Different ***** SHERIFF'S RETURN OF SI SHERIFF'S OFFICE CUMBERLAND COUNTY 1 COURTHOUS E SQUARE CARLISLE PA ATTN:CLINIC THE FAMILY 17013 LAW Served under Pa,R.C,P, #402 ~A) (i) Delendant personally served ~A) (2) (i) Family Member ~A) (2) (i) Adult in Charge 01 Residence ~A) (2) (ii) Manager/Clerk at Defts, Lodging ~A) (2) (iii) Person in Charge 01 Business By Handing to Bv ~ting ~S9r~ _ 30 Days Ran Out _ Delendant Not Home _ Delendant Moved _ Address Vacant _ Del, Unknown _ Dep, Needs Better Add, _ Checked Post Oflice -A- No For~arding SU III - FOfYvarging Mdr<;.ss rce;:v""" - ~ f~~ EASTI -A ~, lleu'1tJ I'A/61S /2./1 0_ SEll' . / - ~ 'I( ~BOro ~~ · . IJ~ All: THE F ILY LAW CLINIC Witness 11292001 RECEIVED I' SHERIFF'S OFFICE FOR SERVI~ At ?.J.,O o'Clock(@PM)onJ.l.tLY;~ 12132001 SHERIFF' R TURN, UNDER OATH, NOT FOUNDI The above document was served/~ve1:l,on the DEFENDANT CLARENCE RAY PARKER. RETURN~ dele,n,dant,.aS!(erinIOrmatl,i,'JI'O,~ lissJ' dab~,mlfleCOunty 14/01. 01 B~dfij'monwea,.ltJl:':~,'} nrnsylvA'rlia,," 12172001 INVOICE MAILED TO CUMBERLAND COUNTY SHB soa~~"vij~..~faj'4;;;l' /P a ATT: FAMILY LAW CLINIC END D F CAS E Lawrence R. Michaels. Sheriff of Bucks Cou y II~ I ffir ed and subscribed belore me on this day 01 1m PLAINTIFF PARKER ROSE MARIE L~ VS. 11142001 7 Prothonotary .. N" ~~ and s'libs ribed before me on this d y ~lf.7 Notary Public My Com. Exp. i'~""! In The Court of Common Pleas of Cumberland County, Pennsylvania Rose Marie Parker VS. Clarence Ray Parker ~ Serve: Clarence Ray Parker No. 01 93 civil Now, fp("'Pmhpr 1 ,20--.UL, I, SHERlFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Bucks County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. , ,~~~~1f!~(I Sheriff of Cum berland County, P A Affidavit of Service Now, ,20_, at o'clock M. served the within upon at by handing to copy of the original a and made lmown to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this __ day of ,20_ COSTS SERVICE MILEAGE AFFIDA VIT $ $ ,~". .~ ~ , ",' I [' ~- ~~ "",-{,C ,- :-;":""',"- ,-, .- '-", ,--'--" ','-'"<-,,' ,,-, ROSE MAR.IE PARKER, Plaintiff IN THE c:ch5~fb~'~MktSN,it~~6i, CUMBERLAND COUNTY, PENNSYLVANIA v, CNIL ACTION-LAW IN DNORCE AND CUSTODY ~ ~. . ~-f) ~t~ ~~'" . ,"j '.1 CLARENCE RAY PARKER, Defendant NO. 01-93 CNIL TERM .,-'- ::~ " c' '- /:~ {..-., g;~ (~..~ c_~ :~ ~:-; c ''1 {L~ PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Rose Marie Parker, Plaintiff, to proceed in forma pauperis. I, Teri L. Henning, of the Family Law Clinic, Staff Attorney, for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am pro-\riding free legal service to the party. \ Date: '1 &, 0 l . J ~J--. L A../ . ennmg Staff Attorney -, THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Attorneys for Plaintiff ,'<"~"""i.- II' " --r - ".' . . " ."" "',',", ,,'-~- , ROSE MARIE PARKER, Plaintiff, Peti~ioner :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION- LAW :IN CUSTODY (") c: s: "'D en mrTl ~~;:! (J, _' -::::2": ~CI J>r'1, Z"'" ,,-0 '-c ~ z o ~: o o -q :.:;'! F1'1~ ~F8 "-" ; ~=;C) :::L:::D /~);;~ .--;;-! 1 ~=)f"li ~ -< CLARENCE RAY PARKER Defendant, Respondent :NO, 01-93 CIVIL TERM .r:- -u -,.,. _''''4 w PETITION FOR SPECIAL RELIEF PURSUANT TO PA R.c.P. 1915.13 " 0:> AND NOW, this 14th day of November, 2001, pursuant to Rule 1915.13 of the Pennsylvania Rules of Civil Procedure, comes the Petitioner, Rose Marie Parker, by her attorneys, the Family Law Clinic, seeking emergen>:ypartial physical custody of her minor children, Crystal Parker and Mary Parker, and presents the following Petition for Special Relief: 1, The petitioner is Rose Marie Parker, an adult individual who resides at 408 Third Street, Apt. B. West Fairview, Cumberland County, Pennsylvania, 2, The respondent, Clarence Ray Parker, is an adult individual who formerly resided at 408 Third Street, Apt. B, West Fairview, Cumberland County, Pennsylvania, and whose current address is Building C, Apartment 304, East Ridge Avenue, Sellersville, Bucks County, Pennsylvania, 18960, 3, The petitioner is the biological mother (the "Mother") of the minor children, Crystal Parker and Mary Parker, born April 11, 1985 and February 21, 1986, respectively (the "Children"), 4, The respondent is the biological father ( the "Father") of the Children, 5, On January 8, 2001, The Honorable Kevin A Hess entered an Order awarding Mother and Father shared legal custody of the Children, and awarding the Father primary physical custody and the Mother partial physical custody, A true and correct copy of the January 8, 2001 Order is attached to this Petition as Exhibit "A", 6, Under the January 8, 2001 Order, the Mother was granted periods of partial physical custody, including every other weekend from Saturday until Sunday, and certain holidays, " " .. 7, On September 6,2001, the Family Law Clinic, on behalf of Mother, filed a Petition for Special Relief and a Petition for Contempt against Father, because Father: a) refused to allow Mother to exercise her periods of partial custody; b) refused to provide Mother with the Children's address or telephone number; c) refused to allow Mother to communicate with the children by telephone and; d) had failed to enroll the Children, both of whom are compulsory school age, in school. 8, After a hearing on September 6, 2001, this Court entered an Order requiring Father to: a) allow Mother to make telephone calls to the children; and b) transport the children to Mother's residence every other Saturday and pick them up on Sunday, The September 6, 2001 Order further provided that failure of Father to comply with the terms of the September 6, 2001 Order and the January 8, 2001 Order may result in fine and/or imprisonment pursuit to 23 Pa,C.S. ~4346, A true and correct copy of the September 6, 2001 Order is attached as Exhibit "B", 9, Despite the Court's January 8, 2001 and September 6,2001 Orders, Father has continued to violate the terms of both Orders, 10, Pursuant to the January 8, 2001 and the September 6,2001 Court Orders, Father was required to bring the children to Mother's residence beginning September 8, 2001, and every other weekend after that. In violation of that Order, Father did not bring the Children to Mother's residence on September 22nd to the 23rd ,October 20th to the 21't, and November 3rd to the 4th, Nor did he call to inform Mother that he would not bring the Children, Father did bring the children to see Mother on the weekend of September 8 and October 6, 2001 but has failed to bring them any other weekend, 11, On or about October 5,2001, the Family Law Clinic contacted the Father to remind him of his obligations under the Orders, He refused to bring the children to visit with the Mother and became increasingly agitated during the conversation, 12. In violation of the September 6,2001 Order, the Father has refused to allow the Mother to make telephone calls to the children, To date, he has allowed one phone call, only one minute to two minutes in length, During the call, Mother heard him telling the Children what to say to the Mother. 13, The Mother believes and avers that it is in the best interest of the children that she be '~,..... '[ . . ~" r'l I' ~~~ I ' ~ Ii;;;~ ,- allowed the pmiial physical custody provided under the Custody Orders of January 8, 200 I and September 6, 2001. 14, The Mother believes and avers that it is in the best interest of the children that she be allowed compensatory partial physical custody time every weekend, beginning on November 24'h, 200 I and continuing thereafter until further order of the Court, WHEREFORE, Petitioner, Rose Marie Parker, respectfully requests that: 1, Father be ordered to comply with the January 8 and September 6, 2001 Orders; 2, Mother be awarded compensatory partial physical custody time every weekend until further Order of Court, to make up for the wrongful deprivation of custodial time; 3, Mother be awarded such other relief that the Court deems appropriate, Respectfully submitted, \V\l\-a\ Date Debra Hart Munchel Certified Legal Intern ~L!V . MAS M. PLACE ROBERT E. RAINS TERl L. HENNING Staff Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013-2899 (717) 243-2968 . 1"'"I"""""""1~~ II 1'- .~ .__',._',",oh, .,,, ~~ . - ~ ., W 1J11 j) 5 21][j; t/) ROSE MARIE PARKER, PLAINTIFF :IN THE COURT OF COMMON PLEASJF : CUMBERLAND COUNTY, PENNSYLVANIA v, :CNILACTION -LAW : CUSTODY CLARENCE RAY PARKER, DEFE!\D:\l\T :NO.D/- 9J CIVIL TERM CUSTODY AGREEMENT THIS .-\GREE\IE~T, made this I a''- day of't\pc-~ \,\,\., \ . 2!1110. bet\\'een Rose Marie Parker. hereinafter Mother, and Clarence Ray Parker. hen:inalh:r bther. concerns the custody of the parties' minor children: Crystal Parker. b, '111 .\1'1"1 I II. \'>S5 and Man Parker. born February 21,1986. \Iother and Father desire to enter into an agreement as to the cush"h "f th<:ir minor children and to haw this agreement made an Order of the COUl1, \I, ,ther .In,! Llthcr hereby agree to the following 1 \Iother and Father shall have shart'd legal custody "f the "hd,lren , Father will have primary physical custody of the childrcn 3, Mother will exercise periods of partial physical cuslc)dy \\ith the children every other weekend from Saturday at 8:00 a,m, until Sunday at 0:00 p,m.. a. At Mother's option, Mother may exercise l)ne ulstl)dial \\'eekend each month at Father's residence. If she does so. she may stay at ---T<. _ l .._ v\ '\ T~, L\~,-\- (). . ~~ r r I' I '" ., .. Father's rp,s;'!I!;'" thm 5:00 p.m. Friday until 5:00 p.m. Sunday, . b. If Mother's .EYing situation does not allow her to keep the children overnight, her weekend custodial periods (except those exercised at Father's residence) shall be from 8 a.m. to 8 p.m. on Saturday and Sunday. 4. Holidav Schedule. Mother and Father will exercise physical custody of the children during holidays in the following manner: a. Mother will have physical custody of the children on the following holidays in even-numbered years: Thanksgiving, Christmas Day (3 p,m, - 8 p.m.), Easter, New Year's Day, and July 41h, b. Father will have physical custody of the children on the following holidays in even-numbered years: Christmas Eve (from 3 p.m. on Christmas Eve until 3 p.m. Christmas Day), Memorial Day, and LaborDay. c. Mother will have physical custody of the children on the following holidays in odd-numbered years: Christmas Eve (from 3 p.m. on Christmas Eve until 3 p,m. Christmas Day), Memoiial Day, and Labor Day. d, Father will have physical custody of the children on the following holidays in odd-numbered years: Thanksgiving, Christmas Day (3 p.m. - 8 p,m.), Easter, New Year's Day, and July 4th. 2 '<i>illli.~~~'1 "II A.. -~"-'."''''''''"'' . ".. , ,. .^~ , ~ ""l"<~ ~ W '" ". Mother will have physical custody of the childrl:'l1 on Mother's Day, f. Father will have physical custody of the children on Father's Day, If Father's Day falls during Mother's custodial weekend (and Mother is not exercising that weekend at Father's house), then Father's custodial period shall begin at 9 a,m. that Sunday, g, Mother will have physical custody of each child on the Saturday following their birthday each year, 5. Each child's communication with the non-custodial parent shall be kept open by way of telephone and mail. 6, Mother and Father will at all times infonn the other parent ,)t" their ,;ulTent home telephone number and address, work telephone number and ;idJress and any emergency phone numbers. 7, Father and Mother will notify each other of all medical ';;Ire ellher chilJ receives while in'that parent's care. Father and Mother \\IJlI1<'lIt"y the l)ther immediately of medical or other emergencies which arise "hile the chilJren are in that parent's care. &, Neither party will do anything which may estrange the chilJren t"1'l)m the other parent, or injure the opinions of the children as to the L1ther parent or may hamper the free and natural development of the children's !c)"e anJ respect for 3 ,., -, ~- ~ -",,), . . the other parent Both parties will actively promote such behavior in all other people with whom the children have contact. 9. Father has been informed and understands that the Family Law Clinic represents Mother in this matter. The Family Law Clinic has explained that it does not represent Father and cannot give him any legal advice. Father understands that ifhe wants legal advice on this matter, he must see his own attorney. Understanding this, Father has voluntarily waived his right to seek counsel regarding this matter. 4 I I 'il~,"'l~ _ ,~~ 1'1 I' , " ~~ ~~ , ''''j1h",.,. j ~'" ., " ... " ., 10. The piitics intend to be legally bound by the terms rifthis Aglcn, i flU intend that the agreement shall be made an order of the Court. r'~/J~AZ_1l:f~~ Clarence Ray Park ' fr.~1M-f~ Rose Marie Parker , \ ~';j YJ1~- JlUie Miller ' , ,., . . Certified Legal Intern ~ LiyJ- THOMAS M. PLACE ROBERT E. RAINS TERI L. HENNING Supervising Attorneys FAMlL y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 ORDER And now, this gth day of. :hJu..a.f ..'1--' 200f, the foregoing Agreement is approved d entered as an Order of the Court. I I~ J. 5 , ~ "~ " -" -^ '~',". " ...., 0'<<,.", ~ ! .'^', -- r. ),.,',.,>,.".,;l.<: .' v"' i 1i' t 1/'/ ROSE MARIE PARKER Plaintiff, Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V AN1A v. CNIL ACTION - LAW IN CUSTODY CLARENCE RAY PARKER Defendant, Respondent NO. 01-93 CNIL TERM ORDER OF COURT AND NOW, this lo -I'\.-- day of ~f.rl\\..<.( 2001, upon consideration of the attached Petition for Special Relief, it is hereby ORDERED as follows: 1, DefoJ'l<:L..l, Cl".lCalc" }tay P athl, is ORDERED t6 fik vv ~th. I::lll, Cuw l and sti y" on Be'lHlSlll fer Rese M",~" ParKer by the "ud uf the llY~iness day in which. at:: is Btl!'Ved, the true and cn"."ct adrlre.. ~nA phslle1'l'!l1'llberwhere he, Cly~l<l1 Parker and Mary 1''''}.,''1 aIt,- _ fSaiaffig, He is Ordered to allow Rose Marie Parker to send aH4-:t=eeei . 8 telephone calls to and from their children, 2, Defendant, Clarence Ray Parker, is ORDERED to transport Crystal Parker and Mary .,^ Parker to the residence of Rose Marie Parker !It 8.eg a.m., Saturday, SetltllHlll€ll" ll, ?nn.,1, and pick them up at that residence at 6:99 l',m. on Sunday, -ScptemtJ€lI" 9,2991,!lIlt!.Jl 11 rln thp "aIRe every weekend taelea4l;llr until further order of this Court. " cA'~ 3. Failure of Defendant, Clarence Ray Parker, to comply with the terms of this Order and the Court's Order of January 8, 2001, may result in fine and/or imprisonment pursuant to 23 Pa.C,S, 9 4346. ,- f:l.. h,\,_~ "'6 " - r I "I ~~ -,.'" "''lI''!'Wli~A>, ~ -\~ !~ 4. along with their legal coun ~,--"\,,JN-""''^'<>-\ r.1 ;'\.' I~ ~o -1 ~ day parties all appear in person, \;.<.- '''\V-<--<,~ BY THE COURT, \:', ~k~,,?.,,.....-.t--l' I sl id~ 0 J..b." I I J. 'li"!t1!J H::: ~~:>~4.;_'t.',":-,1 <...,.....~... U t "J!.;i~",. "'~'~".,j-"r~ ': k~"'5 ",~,-~ ~"')~<--1''''''''''''Rf) ~~zi";;~~~j~:~~~;~ ~~J~~'~;;~L~;~'-:;'i::,~;;~,;~ii~;~~f}i~;r.d Ihil.' I l2,.. ," ~~ -~.,. -J("'H...'~'\JI, ii,:.L Ij..,";.l._J.e - (,'~~I "f r;:;',:,'." ," _?~- ".. "=.<t.L - " .a 7ud.&"'7J<.jv.ii- ProthDl1ot"ri , ' " f~~ I. ., . VERIFICATION I verity that the statements made in the foregoing Petition for Special Relief are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C,S, 94904, relating to unsworn falsification to authorities. Date: / / J 1 / (/ I .p ,,, e" ,." . _: j ;\ ~. j c... ..-"1\ !:i ~" I -t:~. () l\ }.-. -<:: ~.:J("- Rose Marie Parker I F'I ) ~,.'.' ~ ~ ROSE MARIE PARKER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CNIL ACTION - LAW IN CUSTODY CLARENCE RAY PARKER Defendant NO, 01-93 CNIL TERM CERTIFICATE OF SERVICE I, Debra Hart Munche1, hereby certify that I am serving a true and correct copy of the Petition for Special Relief on Clarence Ray Parker at Building C, Apartment 304, East Ridge Avenue, Sellersville, Pennsylvania, 18960, by depositing a copy of the same in the United States mail, this 14th bay of November, 2001. Date: \\- \1...\- 0\ ~O~~~'I~~~)~ Debra Hart Munchel Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 ~'-W1I_f'" 1""1 , 1 J - ~~~~ ~_" 0-- . ~ .. ~. 1!!I!'iIJ1l!'_~i_iI"J~iJ'III ~'"~:.^-"- ,'.. I"':'''' -, -~~- -". _4 ~ "---<~~, _-,-'-h,,,,_,'~"~dh'";'"^",""', -",. - ~'<=-1i11"1' --"'~~liir~"r~'''TdfY!J)Jrr:'H't '<;I\N\!f\l,\StJ.~3d -1-'1 c: ~ 1 ):l'f1'\} :::0 \ ~., ' \t\. ~d os 1\ ~f. Ml" \"'~3B"no wH1OSO ~~~ ~o 3~\~;lO, ;1.:11\13\-\ " Tf"!lll_ !\II!Iq!Il~I!I!~I~~'lFJ!,,!~l"!lOtf<W'''."'l'''''''-,,"-''~i'',:';'''''H'','\y,!"<wW~~~~I"\!MWI~lF"""'~!'j~'l\!lil!!;O,l_ ~ ,.~ ,",,,,, i?];b~}i;" \\ - ROSE MARIE PARKER PLAINTIFF INTHECOURTOFCO~ONPLEASOF CUMBERLAND COUNTY, PENNSYLVANIA V, 01-93 CIVIL ACTION LAW CLARENCE RAY PARKER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, November 21, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4tb Floor, Cumberland County Courthouse, Carlisle on Friday, December 14, 2001 , the conciliator, at 10:30 AM 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. The court hereby directs the parties to fnrnish any and all existing Protection from Abnse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Hubert X. Gilroy. Esq. ~ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court, You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATIORNEY AT ONCE. IF YOU DO NOT HAVE AN ATIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, REC~IVED "QV 3 0 2001 , ,,'~>l Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 TRUE COpy FROM REeO' In T est/mony h f RD and the I wf e~eo, I here unto set my hand sea 0 said Court at Carlisle Pa Thi ~'if.: ' . s hhh' h.hh'. day OL>.1~hh'hh' ;;J.Q::J! h'hhhhh~fkhh.r ~ Iii ,.., ,P;othon~t~~'~"r' ~,'\I~W'l I I , ~ rl - ~ ~ '~I ~,._" '~ . NOV 1 4 2001 ~ v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW IN CONTEMPT ROSE MARIE PARKER Plaintiff/Petitioner CLARENCE RAY PARKER Defendant/Respondent NO. 01-93 CNIL TERM NOTICE AND ORDER TO APPEAR Legal proceedings have been brought against you alleging you have wilfully disobeyed an order of court for partial custody, If you wish to defend against the claim set forth in the following pages, you may, but are not required to file in writing with the court your defenses or objections, Whether or not you file in writing with the court your defenses or objections, you must appear in pers on in court on at _,M, in Courtroom (Time) (Day and Date) IF YOU DO NOT APPEAR IN PERSON, THE COURT MAY ISSUE A WARRANT FOR YOUR ARREST. If the court finds that you have wilfully failed to comply with its order for partial custody, you may be found to be in contempt of court and committed to jail, fined or both, YOU SHOULD TAKE TillS PAPER TO YOUR LA WYERA T ONCE, IF YOU DO NOT HAVE ALA WYERORCANNOT AFFORD ONE, GOTOOR 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: Date J AMERICANS WITH DISABILITIES ACT OF 1990 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 andreasonable 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. ''''"'~-'''~,!l'f., ~r-I I' -~. '. ROSE MARIE PARKER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CNIL ACTION - LAW IN CONTEMPT CLARENCE RAY PARKER Defendant NO. 01-93 CNIL TERM ORDER OF COURT AND NOW, this day of .2001, upon consideration ofthe attached Petition for Civil Contempt for Disobedience of Custody Order, it is hereby ordered as follows: 1. Defendant is held in contempt of the Court's January 8th and September 6th, 2001 Custody Orders. 2. Defendant is ordered to comply with both the January 8th and September 6th, 2001 Custody Orders. 3. Defendant, Clarence Ray Parker, is ORDERED to transport Crystal Parker and Mary Patkerto the residence of Rose Marie Parker on Saturday, November ---,2001, and shall pick them up at the residence on Sunday November ~ 2001, and shall do the same every weekend thereafter until further order of this Court. 4. Defendant is assessed a $500 penalty for acting in contempt of the Court's Custody Order pursuant to 23 Pa. C.S. ~ 4346. BY THE COURT, J '- . II ~ ~"_~-,,,",,,,," ROSE MARIE PARKER Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CNIL ACTION - LAW IN CONTEMPT CLARENCE RAY PARKER DefendantJRespondent NO. 01-93 CNIL TERM PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF CUSTODY ORDER Plaintiff/Petitioner, Rose Marie Parker, hereby brings this Petition for Civil Contempt, and respectfully requests that this Court fmd Defendant/Respondent, Clarence Ray Parker, in contempt of the September 6,2001 and January 8, 2001 Court Orders. In support of her petition, Petitioner states as follows: 1. Rose Marie Parker ("Mother") and Clarence Ray Parker ("Father") are the biological parents of Crystal Parker, born April 11, 1985 and Mary Parker, born February 21, 1986 ("the Children"). 2. On January 8, 2001, pursuant to the consent of the parties, this Court entered an Order awarding the parties shared legal custody of the Children and awarding Father primary physical custody and Mother periods of partial physical custody. A true and correct copy of the January 8, 2001 Order is attached to this Petition as Exhibit "A". 3. Under the January 8, 2001, Order, Mother was granted periods of partial physical custody as follows: a. Mother was granted partial physical custody of the Children every other weekend from Saturday at 8:00 a.m. until Sunday at 6:00 p.rn. b. The Order also included a holiday schedule. c. The Order required that each child's communication with the non-custodial parent be kept open by way of telephone and mail. d. The Order required Mother and Father to inform the other of their current home telephone number and address, work telephone number and address, and any emergency telephone numbers. e. The Order prohibited either party from doing anything which may estrange the Children from the other parent, or injure the opinions of the Children as to the other parent or which may hamper the free and natural development of the Children's love and respect for the other parent. 4. On September 6,2001, the Family Law Clinic, on behalf of Mother, filed a Petition for Special Relief and a Petition for Contempt against Father, because Father: a) was refusing to allow mother to exercise her periods of partial custody; b) was refusing to provide mother with the children's address or telephone number; c) was refusing to allow Mother to communicate with the children by telephone and; d) had failed to enroll the Children, both of whom are compulsory school age, in school. 5. After a hearing on September 6, 2001, this Court entered an Order requiring Father to : a) allow Mother to make telephone calls to the children; and b) transport the children to Mother's residence every other Saturday and pick them up Sunday. The September 6,2001 Order further provided that failure of Father to comply with the terms of the September 6, 2001 . order and the January 8, 2001 Order may result in fine and/or imprisonment pursuit to 23 Pa.C.S. ~4346. A true and correct copy of the September 6, 2001 Order is attached as Exhibit "B". 6. Father has wilfully failed to abide by the January 8, 2001 and September 6,2001 Orders in that: a. Under the Orders Father was required to bring the Children to visit Mother on the following weekends: September 8th to the 9th, September 22nd to the 23rd, October 6th to the 7t\ October 20th to the 21 't, and November 3rd to the 4th. Of those five weekends, he failed to bring the children for a visit on three of them, September 22nd to the 23rd ,October 20th to the 21 ,t , and November 3m to the 4th. a. Father has allowed the Children to speak to the Mother over the telephone on only one occasion. The call lasted only one to two minutes before Father made the Children end the call. b. Father is estranging the children from the Mother and hampering the free and natural development of the Children's love and respect for the Mother. d. Upon information and belief, the Father failed to enroll the children, both of whom are Y*'l~ 10 1"1 I ' " ..,. of compulsory school age, in school until October 16, 2001. The Children were not enrolled in school for over a month's time. Moreover, Father has failed to consult with Mother regarding any change in the children's education. WHEREFORE, Petitioner requests that: 1. Father be held in contempt of the Court's January 8 and September 6, 2001 Orders of Custody; 2. Father be ordered to comply with the January 8 and September 6, 2001 Orders; 3. Mother be awarded compensatory partial physical custody time every weekend until further Order of Court, to make up for the wrongful deprivation of custodial time; 4. Father be assessed a $500 penalty for contempt of the Court's Custody Order pursuant to 23 Pa. C.S. ~ 4346; and 5. Mother be awarded such other relief that the Court deems appropriate. Respectfully submitted, \\- \1..\-0\ Date '\)JO.n~J.:k~~ Debra Hart Munchel Certified Legal Intern ~ '/ _ L/\j . S M. PLACE ROBERT E. RAINS TERI L. HENNING Staff Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 -jC"~"''''''''''''l''ll ["I - "~ 1 h~ fi t:: .;.,Jr' IW1 'UY, t'" r.U'/' W " , ROSE MARIE PARKER, PLAINTIFF :IN THE COURT OF COMMON PLEAS uF . :CUMBERLAND COUNTY, PENNSYLVANIA v. :CMLACTION -LAW : CUSTODY CLARENCE RAY PARKER, DEFE1'\DA1'\T :NO.DI- qJ CNIL TERM CUSTODY AGREEMENT THIS AGREE\IE~T. made this I ~,\- day of~<,,,-,,, ,,,\.. (' . :!lIiO. b~t\\een Rose Marie Parker. heremafter Mother, and Clarence Ray Parker. hen:inatkr Fath.:r. concerns the custody of the parties' minor children: Crystal Park.:r. b,'1ll .\ pn 1 II. l'lS5 and Mary Parker. born February 21, 1986. \Iother and Father desire to enter into an agreement as tothe ellst,.,i\ "t'th~lr minor children and to ha\'e this agreement rnade an Order of the Coun \ I, .tl1.:r .m,l t'~lth.:r hereby agree to the following 1 \lolher and Father shall have sharc.'d legal custody ,.f th.: .:I1Ildr.:n " Father will have primary physical custody ofthe ehildr.:n 3 Mother will exercise periods of partial physical cush\dy I\nh th.: children e\'ery other weekend from Saturday at 8:00 a.rn. until Sunday at 0:00 p.m.. a. At Mother's option, Mother may exercise nne cUSh\dial weekend each rnonth at Father's residence. If she does so. she may stay at ,""'i..~ . ;'L_~,'l"I ,_~,"__, 6 1- 'v,\\;> ,\; \II f\" ....- II' I-I . Father's rp.s;{:~'P: 6'0,'115:00 p.m. Friday until 5:00 p.rn. Sunday, b. If Mother's l:Ving situation does not allow her to keep the children overnight, her weekend custodial periods (except those exercised at Father's residence) shall be from 8 am. to 8 p.m. on Saturday and Sunday. 4. Holidav Schedule. Mother and Father will exercise physical custody of the children during h()lidaYs in the following manner: a. Mother will have physical custody of the children on the following holidays in even-numbered years: Thanksgiving, Christmas Day (3 p.m. - 8 p.m.), Easter, New Year's Day, and July 4th. b. Father will have physical custody of the children on the following holidays in even-numbered years: Christmas Eve (from 3 p.m. on Christmas Eve until 3 p.m. Christmas Day), Mernorial Day, and Labor'oay. c. Mother will have physical custody of the children on the following holidays in odd-numbered years: Christmas Eve (from 3 p.rn. on Christmas Eve until 3 p.m. Christmas Day), Mernonal Day, and Labor Day. d Father will have physical custody of the children on the following holidays in odd-numbered years: Thanksgiving, Christmas Day (3 p.m. - 8 p.m.), Easter, New Year's Day, and July 4th. 2 , 1'1 r' I~ , -tIlL ,l'~!~ v-"';- -.'~-"~'-l ,- ~~" - ~ 1'1 3 ,I 4IiL the other parent. Both parties will actively promote such behavior in all other people with whorn the children have contact. 9. Father has been informed and understands that the Family Law Clinic represents Mother in this matter. The Family Law Clinic has explained that it does not represent Father and cannot give him any legal advice. Father understands that ifhe wants legal advice on this matter, he rnust see his own attorney. Understanding this, Father has voluntarily waived his right to seek counsel regarding this matter. 4 . I I i :--~ ..--...:'"' ~. .' . ;"',- ~! . ...,. 10. The ptitics intend to be legally bound by the terms cifthis Agleo. 1 '1(1 intend that the agreement shall be made an order of the Court. ~ ~/J/21A/tZ-1l:f-~~ Clarence Ray Park ~ ~ '}'V\. 'f~ Rose Marie Parker . \ . (J YJ1~- J' eIvillier .. Certified Legal Intern ~ Li:;J- THOMAS M. PLACE ROBERT E. RAINS TERI L. HENNING Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717/243-2968 ORDER And now, this gth day of. :b.Ju.o..r.1--- 200f, the foregoing Agreement is approved d entered as an Order of the Court. .;"'.;c""! . "-, . I-I 1. 5 , .. ~ "~ " _._~ , ., ;,if. 'ii ?nniJlI/ ROSE MARIE PARKER Plaintiff, Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CNIL ACTION - LAW IN CUSTODY CLARENCE RAY PARKER Defendant, Respondent NO. 01-93 CNIL TERM ORDER OF COURT AND NOW, this ~ day of ~f1'I\\,...( 2001, upon consideration of the attached Petition for Special Relief, it is hereby ORDERED as follows: 1. D6J'Clicl=l, Cl",cn.:e ltay Pmka, is ORDERED t6 fll" w;th I:h;~ Cuwl aud selVe un 6ffiHlsel fer Rase Mat;" Parker by the eud uf the BY~meSS aa:,' ift '1.<hicR he is s~e trtle fll:lQ ,orrp.r.t addu,"" ond phoBe _bel where he, Clyslai ]>arker and Nlary P",k"l "''' _ r6sieliftg. He is Ordered to allow Rose Marie Parker to send a1id new.'8 telephone calIs to and frorn their children. \ 2. Defendant, Clarence Ray Parker, is ORDERED to transport Crystal Parker and Mary .,^ Parker to the residence of Rose Marie Parker at 8.e9 a.m., Saturday, Sefltemeer g, ?Oll..l, and pick them up at that residence at 6.99 l'.m. on Sunday, ~L!'teHl.ber 9, 2991, lIfl.6 _' ,l!- no th{- ~~t"~ every weekend t:heles.fter until further order of this Court. ;~ 3. Failure of Defendant, Clarence Ray Parker, to comply with the terms of this Order and the Court's Order of January 8, 2001, may result in fine and/or irnprisonrnent pursuant to 23 Pa.C.S. ~ 4346. f'fl "', \, ,-t 0--'\ " \.....J --,"""",,k ,_ rl . ", -"'"~~""'f_ . ~- ~ " 0':, , I 4. parties A day of ,2001 at C berland County all appear in person. C-or--~\,J,"'" "'-'''"\ \:;.<...- ~,\v<--c,~ \PI <?.A\-\.......s- .?.....r.\---l. BY THE COURT, /s/ ftdvu: 0 ~ I I J. T:t,':'iG G ~:: C"<\.r~, ;~""'f -~" _ p." ~ ~ ~'"JL,. ~~",!;~~}<,1'i r~.,t:'?j ',J\~ h....FI\~.f"'",...~"PI/") ;:i!l"~:~;;!'~~'"J'~;;:;;r~()~, i ;::~~r;i:;":.I~;",~:;;t~;; ;,;;;;;1 ,. '-..-vil .~.1 .""d.hJ ~,,$:..~(~~ ~:j1j 1 ~"'I';i." 1..-, ,'f" 'th'. . c;z", o",.<."l~ ;;I'.t '"H,~iH,'~~il;:;1 l'd;'~ ''''iLt)y.:.:,e'i' (,f Jl-:.....~..... '.. "--"'~3 "~ ~ -t2~, "P'~' - Pro!hlli1Qtaf;' rl .." . , '"-,m~ VERIFICATION I verify that the statements made in this Petition for Civil Contempt for Disobedience of Custody Order are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. Date: J/ / 7' / (; ! -0 "~ )<"1'-- , \ u.5 C Iv I Ci r j (:_ /\ (, r ~ ~ Rose Marie Parker I r 1- , . "",,~ -~~-1 L~ .. ROSE MARIE PARKER Plaintiff v. CLARENCE RAY PARKER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION - LAW IN CONTEMPT NO. 01-93 CNIL TERM CERTIFICATE OF SERVICE I, Debra Hart Munchel, hereby certify that I am serving a true and correct copy of the Petition for Civil Contempt on Clarence Ray Parker at Building C, Apartment 304, East Ridge Avenue, Sellersville, Pennsylvania, 18960, by depositing a copy of the same in the United States mail, this 14th Day of November, 2001. Date: \\- \1.\- D\ .- ,-~ , "~ I -I \)oC1cL~ I~' ~ Debra Hart Munche1 Certified Legal Intern PAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 "~, ~ W.&If ~~ - - ~,,- i;l1~V'^lASNN3d ,n('n~\jf\ , t! 1 J 10. Md OS ZI oe 4ifH! N..uIIim1Oo G'~iIIJ~WilG' .rM:Ull.sn:s 3Hl j'O :ml::i!:lij; ~nll'!'l'~ "'" ~lllt_ - ~. ., '. "'d' .."...... ..~.__.'...~.~ 111 f~f , ' ."....Ill..rf".'.1"~ . , . _ !"rr~~_WlI~~~~W!'F"',!i'1'+T'-m"J'~"'7"';""''''-H!f-'''I0I''Jl'!-:''~'''-1lIll'1!')''''''''"""i'i"'-"N'!,,"~~~l'OI!l"~,,! .," ~ t' ! ~'I n " DE~001 ROSE MARIE PARKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW CLARENCE RAY PARKER, Defendant NO. 01 - 093 CIVIL IN CUSTODY COURT ORDER AND NOW, this '2-i~ day of December, 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father shall immediately begin delivering the children to the Mother for her time of physical custody in accordance with the prior custody orders entered in this case. 2. When the Mother has custody of the minor children, the Mother shall under no circumstances allow Troy Grebinger to be at her home or have any contact whatsoever with the minor children. 3. Mother's petition to hold Father in contempt is withdrawn without prejudice to raise the allegations contained therein in a future petition in the event Father violates this order. It is noted that Father has indicated at the custody conciliation conference an agreement to reinstate visitation without any restrictions subject only to the provision above relating to Mr. Grebinger, and it is anticipated that Father shall abide by that order or be subject to appropriate sanctions of this court upon the proper filing of a new petition for contempt. 4. In all other respects, the prior custody orders entered in this case shall remain in effect including, but not limited to, the scheduled holiday visitation. BY THE COURT, cc: Gina Carnes Dickinson School of Law Family Law Clinic J. Clarence Parker C-304 East Ridge Avenue Sellersville, PA 18960 f1 ap-U-01f' W-3/-01 1\ S - ;,",- O~,_. .", , ,". _. ,,-' ", _ -_~ I ~_ , ' ., - -.'. , ',,~ - ., _h__ ] , ~ fC ("') Si <C I.!: >-- ::::><( ~~?~: o~ ~r:: r,.)~ ::1:':::1": a.. CJ?1 yl~~;, ~~ ~ . C0 \.L~ .. ;---'.....- c...:; urn Ld "~.JO- r'u W ~ L.. ::::> 0 Cl (.) -:w-.,," " ,~ 0> .~_ .-. -, ','<-" =, , .' ~- ~'- ~ ""~- ,- """',,,' "'''..' ,. ... .. , .1J!PlI"'!!l!","""",,,,":,~_"_~,,.~~-/lr~"'-,"~Il\ViI'?n?~f.'t:~"'9'l~~~~'~"ll~ - I'~" v ROSE MARIE PARKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CNIL ACTION - LAW CLARENCE RAY PARKER, Defendant NO. 0 I - 093 CNIL IN CUSTODY Prior Judge: Kevin A. Hess CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CNIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Crystal Parker, born April 11, 1985; and Mary Parker born February 21, 1986. 2. A Conciliation Conference was held on December 14, 2001, with the following individuals in attendance: The Mother, Rose Marie Parker, with her representative, Gina Carnes of the Dickinson School of Law Family Law Clinic; and the Father, Clarence Ray Parker, who appeared without counsel. 3. The parties agree to the entry of an order in the form as attached. O( 0fd .w , . , ~" "".~-.,"- .',,' . ~- ,,_.d_,r . .'>t'.,,,,,;~:'; ,_''? _~ .. .lEe; 2 8 ZOO'i ~O ROSE MARIE PARKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CNIL ACTION - LAW CLARENCE RAY PARKER, Defendant NO. 0 I - 093 CIVIL IN CUSTODY COURT ORDER AND NOW, this C}r1tA day Of~ 200Jl. upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Courtroom No.4 of the Cumberland County Courthouse on the OW n.d. day of J11A A' AI L , 2002 at I J .3 C) .EM. At this hearing, testimony will be taken on Mother's Petition to hold Father in contempt. Counsel for the parties, or the parties if they do not have counsel, shall file with the court and opposing counsel a memorandum setting forth the history of custody in this case, the issues currently before the court, a list of witnesses who will be called to testifY at this hearing and a summary of the anticipated testimony of each witness. This memorandum shall be filed with the court in chambers at least five (5) days prior to the mentioned hearing date. 2. Pending further order of this court, this court's prior order shall remain in effect. BY THE COURT, ,4/ . Hess cc: Gina Carnes Dickinson School of Law Family Law Clinic J. Clarence Parker C-304 East Ridge Avenue Sellersville, PA 18960 ~ ~ 1_03-0b C)-, , , ,~~ -, ,- -, -. '" -'., - ,-'_"'-.I,~ - -,,,...-,.-, .,= "'1.1'- ,or ",', -, _.. - ,_., -,_.~ - , -, "" c "'~ - "--~, VINV^lASNN3d AlNn08 OHillFJ8;^inCl 9D :Olll'li S-lllJf' 20 IL\.iI()"'", .". ,in uj'!.\ ,\,{ .,"C,' _ _'. ',," ~'..- . ." .:~i~)\jj6-{l:nu - u!_~n",~ .~ - .' ~"e~ ,,-o,~~~'1'''~~ --~-,~ - ~-, ., ,. .""-"""',""'" c' M~ . ~ "~. ~i']),i;fi'1~~ " ".L;c _...lM!I'lM!<IIffl'i!ilI~I.'lf@~,"_"I"lmlFWli\1~!OOlm:lIII~il!l:!liJ!l'!'l'1li_~_W~~ ,_1:+ ~\;. '" '. ROSE MARIE PARKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW CLARENCE RAY PARKER, Defendant NO. 01-093 CIVIL IN CUSTODY Prior Judge: Kevin A. Hess CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CNIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: I. Although the conciliator was able to resolve the issues with respect to Mother's petition to hold Father in contempt, Mother's counsel now indicates that Father again deliberately violated the custody order only a few days after the custody conciliation conference (See attached letter from Mother's counsel). Accordingly, a hearing is necessary and the conciliator recommends an order in the form as attached. ~(,( DA E 'fJ4 '"". (' 'c, -H: " ,-)';'~""<,;- ..--, '~_-'" '-:""., - I-I "I , !.,~ . " IIi: """j11'N 02' (12 '. 10: 03 No.C02 P .b2 . FAMILY LAW CLiNIC--~. .~ ....... ., A-lervlcc totlUI oommtinlts"tt.Y.lll1dcnll from 1"he Diokinllotf Sohool of lAw of lb.- rtrlni)'lvania SiAle Univenit)' ~ The 'o&I~ p, Sbudwt Conuu\mlty Law Center , ~5 NOlth rill &'tn:ot Caditl., PI, 17013,2899 \717)143.1968 Fftx: (717) 143.3639 November 30, 200 I )j( Huben Gill'<lY, Esquire 4 North Hanover Street Carlisle, PA 17013 Re: Rose Parker v. Clarence Parker / Conciliation Dear MI'. Gilroy: I am writing to ask for a hearing 011 Ollr contelllpt ilnd special relief petitions filed in this case. On December 14, 2001, we altcnded the conciliation inthi~ matter, At that conciliation Clarence Parkerllgreed to bring both daughters, Mary u11d Crystal, to Rose Parker's residence every other weekend as it is outlined .in t.he cllstody order, The visitation was to begin on December 151h. Clarence agreed to i1. Huwevcr, he failed to bring the girls on the J 5!h. As a result, we renew our Pctition for Contempt. 1l1ld our Petition for Special Relief and a.~k thaI. you set this matter for a cow1 hearing, Sincerely, Gina M. Carnes 61q/~/9'l!P co: Clarence Parker * 1>(ea,s.e" ho+u"fN, d..a.tt- ~ is itlCO'(fect. Ihis. le.+t-e.r wq; ~o.\ly sent- &Vi'" CfY\.:-~,err oJae;uf ~cem?er rq~C1'N.- \)Jtejt... -fOlIOWll1~ ~ tusro~ Con~t1M.) PENN~ . The Dlckmson School of Law 1\'1 Equ"1 Opportunity tJnivcnli1y r:~~~~ 1- _,-, ' , , . . VICTOR CRUZ, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 01-0907 CIVIL CIVIL ACTION - LAW MELINDA A. WHITZEL, Defendant ORDER AND NOW, this z..! day of January, 2002, it appearing that the undersigned has a scheduling conflict, hearing in the above captioned matter set for February 22, 2002, is continued to Thursday, March 21,2002, at 9:00 a.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, P A. BY THE COURT, Jeanne B. Costopoulos, Esquire For the Plaintiff Family Law Clinic, Esquire For the Defendant ~~ /-6J~(J.J:> 9- :rlrn - "..,' ,- ~-~.,'-," 1'-'1 1'- - ',' ~ I. i Ii I".' ., 'I " 1;1 1.:'7;:, _"""llR'lI!': '.' ~. " '-~,-. -~. -~'~ ~',,~",-"'" -',-.' VINvti'1\SNN3d },lNn08 O!+Ilt-El\:1~"1no r:- Hvno '.. \1" 8U .01 "~ PciV.LC>:C:-\,L~_- I'~ ~o ":\:)l::lJC) {}~rH:~j - ,"""",,,"'''-~'''' ~- ';. ~-~ ,<, "^'~',"' ~~~~~~" _"O!II"""~JII!I.l!",,"," ,c" _ ~'~', ," .;;' -"c~''''''/''-'<_" .<,." ,..J..IJ_..' ~_.'~..~",~<_... . ~ .', Cr.~f IF ]1)oli'~~'!l.'l'!1!'Wi"MWlll1"o,\bV'W1,,~~,~~~i!il~~!'H!!~~1l!'1l!~~,~\," -"~~"l4 II '- . ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 7>Kt. fI/-I)..';? (}/~/L. State Commonwealth of Pennsylvania I'JI1er'[5 () 7110 C/o 'I 0 Co./City/Dist. of CUMBERLAND ,. Date of Order/Notice 12/31/01 ~Il.. 3/~tlt/ Court/Case Number (See Addendum for case summary) o Original Order/Notice o Amended Order/Notice @ Terminate Order/Notice ) RE: LEHMAN, WENDELL B. I Employee/Obligor's Name (Last, First, Mil I 197 -40 -7208 ) Employee/Obligor's Social Security Number i 9769100885 ) Employee/Obligor's Case Identifier i (See Addendum for plaintiff names assodated with cases on attachment) ) Custodial Parent's Name (Last, First, Mil ) EmployerlWithholder's Federal EIN Number ALTON OCHSNER MEDICAL FOUNDATI EmployerlWithholder's Name C/O PAYROLL DEPARTMENT Employer/Withholder's Address 1516 JEFFERSON HWY NEW ORLSANS LA 70121-2429 See Addendum for dependent names and birth dates assodated with cases on attachment. ORDER INFORMA TlON: This Is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to dedud these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 0.00 per month In current support $ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes <Xl no $ 0.00 per month in medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 0 .00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 0.00 per weekly pay period. $ 0.00 per biweekly pay period (every two weeks). $ 0 00 per semimonthly pay period (twice a month). $ 0.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to dedud a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the the allowable amount. The total withheid amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Colledions and Disbursement Unit (SCDU) Employer Customer Service at 1-B77-676-9580 for instrudions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: Date of Order: JM'1 ~ ~~~ MAILED U,f.>1I1€. ()I"\ OMB No.: 0970-0154 I-:J... ,... ~y"'iration Date: 12/31/00 Form EN- 28" Worker ID $IATT Service Type M ;i%n,"I'''L ,. -1'"'" ... ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If checked you are required to provide a copy of this form to your employee. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3. * Repol1;hg fLoe Payclate/Date of'Nitl.l.oldil,g. 'tot! Jlltl3t It~polt tLe l->ayJate!J~tb vf n;U.I,vIJ;1I5 vvllel, sehdihg tLe paylllult. TI,(. payJeth:ddate of yvitl.l.oldil,g is tile date 011 vvl,id. 8.IIIOtlht vvA5 vvitl,l,eld fl011l tll~ elllployee's ~HI5e5. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.' Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state ofemployee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S ID: 6778100165 EMPLOYEE'S/OBLlGOR'S NAME: LEHMAN, WENDELL B. EMPLOYEE'S CASE IDENTIFIER: 9769100885 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disdplinary action against any employee/obligor because of a support withholding. Pennsylvania Stale law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. * Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (1 5 U.S.c. 91673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 10. 'NOTE: If you or your agent are seNed with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Requesting Agency: DOMESTIC RELATIONS SECTION 13 N. HA~OVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by Internet @ Page 2 of 2 Form EN-028 Worker ID $IATT SeNice Type M OMB No.: 0970-0154 Expiration Date: t2l31!OO ~"'!';~ !' , ~ ,-, ~ -"""'''''="~''', ,~,', I II I II Ii Ii II I, )' 1 I Ii Ii I' Ii II I, ,,',~ ',ok,.. -~- ,-..'..--,",,'<J<,~'" ,',," - '--'-,'.'-,.. ,. _-'. '~'~~""I'< ,,~,'0" .,' M~""~'_""__~""~'_''''-''~~_~_ .". '. (") c.: <:> "1:Jrr: rrlr"' ~~:. r:: (~; ~ P'C-' Z~ ~CJ .Pc Z ~ o 1'.) () ....'''1 ,~ ~~ =-,Q I W ,,,l, ,C_', ! ~: -"0 _ii,~ ~;~~ S! :J:J -< ~? <....., J:" ~if 1',- _~~~~-~~~~tlli_~~f1"'ffi""-"'-:t'-;,;""-""~ "'_'}~C'_W';'c_'\"f'~'"j"",_;;_,,,m2gt'l!!I\'~;r,.f-'l''''''-'''"C;-:;;;:'C"V"'~'ir-:!"~':'1!!^~PJ!)!l~ mIi83~.t lili 1 H4.1i~ itl r n PARKeR CRYStAL A Ai. t6 lum lioomml PATIENTNIl.ME _ 121U1U lium. licon A. N.II. ~~~ ~" " " "U'~' ". .~ _.. _. .JiI1E~DCHINlIf IPATIlElNll HINIS11R!II.DC1HiOINI SIHIEIE1 111e care you have received in \he Emergency Dept. has been rendered on an emelge/1CY basis only. n is importanlthal you contact your own family doctor c recommended specialist for follow-up care because n is impossible to recognize and _ aU etemenls of injury or illness in a single Emergency Dep!. visi' Meanwhile. FOLLOW THE INSTRUCTIONS BELOW as indicaled for you. WOUND CARE (cuIs, abrasions. bums, ek:.l ~ Keep wound clean, dry. & covered. May shower in _ hours. ~ Remove dressing & redress in _ hours and _ times per day thereafter. Apply antibiotic ointment with each redressing. ~ Cleanse wound with ~ ff signs of infection develop (increasing redness. swelling, pain, appearance of pus, lever, foul odor. or red streaks in skin) see your family doctor or return to ED. _ See your family doctor/return to ED in _ days for wound check. _ See your family doctor/return to ED for suture/staple removal in _ days. _ Bums: Do not break bliste!s lhal may form! _ Tetanus given: The injectiOn sne may devatop slight sweUing, redness, or soreness. Retum to EO for any signs of hives. difficulty breathing, or severe sweliing or redness. _ Do not drive a car or operate machinery wUh eye palched! _ Use eye drops/ointment as indicated: _ dropsfointment evel1 _ hours _ Return demonstration of patching/drops SPRAINS & FRACTURES, SEVERE BRUISES _ Elevate the injured part to reduce swelling. _ Ice packs should be applied to injured parl 4 times a day, 20 to 30 minutes at a lime; for _ days. Place ice in Plastic or rubber bag and cover with cloth before placing on skin. Then. apply moist heat 4 x daily. _ Rewrap ace bandage iI \00 tight or loose. Do not remove plaster splint until seen by physician! _ Use ace bandage/sling/splint until _ Use crutches for _ days. Do not 1~ on crutches with underarms. Remove all throw rugs from area to be traveled on crutches. Climb stairs on buttocks. /i - All xrays are re-read by a radiologist within 24 hours. We will +~ Cl vtu conlacl you illllere Is any change from the original reading. 'l'--- Return demonstration $ _ ke wrap _ Crutch walking IIIIEDICATlONS MISCELLANEOUS t. LNOU\lJ, ~ _~I!-~~ ~ e~~.,~ .t-~ -0 '.5',,;;,', ; ~. r';" s tr". "'" k ; f, < F ..... \ HSAD INJURY INSTIlUCTIONS _ If any of \he following occur . call your doc1or or return to the ED: A. Unusual drowsiness-and/or difficulty in awakening (patient should be awakened every 2 to 3 hours during the tilSl 24 hours aIler injury) B. Repeated vomiting (once or twice is nonnal. especially in children) C. ConwIsions. severe headache, unequal pupils. staggering. or abnormal behavior. BACK & NECK INJURY INSTIlIlCTIQNS _ Use heal or cold on the injured area-whichever seems to help the most or as instructed. _ Wear soft collar for _ days. Collar may/may not be removed for sleep. _ No heavy tilting! Nothing heavier than _ pounds. _ Avoid positions and movements thai make \he pain WOrse. _ Sleep on a firm mattress. A board between mattress and box springs can be used if necessary. ~ Avoid riding in a car for long periods. OTIiER --r'i You may relum I ~ Follow-up with: _ Sel up appointment for the following swdy/studles: _ If you have not done so: notify your HMO physician of your visil to the ED. day!! JANO 9 ZOO2: ~ GIRAlNIlO VIEW HOSI>UTAl 700 Lawn Avenue Sellersville. PA 18960 (215) 453-4674 G~u..INSTiIIJC11ONS 4.f a.t:?z-v~ ~ing by mouth lor _ hours. . ~esl as much as possible! ~e only clear liquids by mouth such jljl bJ;ol~. 7-up. gingerale. decaf lea. Jello. Gatorade for \he nexf~ iours. Avoid caffeine dairy products. & aIcohollc_erages. Advance 10 soft bland diet as tol"",ted. _ Increase fluid intake! ~ Your medication may cause drowsiness! Avoid aH alCOholic beverages while taking medicine. Do not drive a car or operate dangerous machinelYJ _ For painlfeverlheadache take _ Medication Prescribed: EYE INJUIlY INSTRUCTIONS _ Remove eye patch in _ hours. _ Follow-up with family doctor or eye doctor as indicated: .~---, . .." I hereby acknOWledge receipt and understanding of \he instructions indicated above. /2_/;;,(/1 l;IfO g~tp.. tf~, Dale 11me Palienfs Signawre . NursB'l; Signature I~IIIIIII 78.10 YourplJysi:ian was: S.5Jagel. M~~..., q,...o,1,_' li/lP, S.M._.~~._ rA;.. \:,;S\IliIa,Mll J. Ferry. MD Ffancist<l.lanas. PM: Olher j~~ "~~ co DEPARTMENT OF EMERGENCY MEDICINE ~,.. , ~ ~r I (Rev. 12100\ .f )fI y"", ~5 ~_ t/y;, :;,- JAN I) I) 2002 ~L..- ~111- '5 IT ca f y ~ Hu..,bert GiJ,roY Esquire 4 NO{lh Hanover Stroot Dee 26,2001 Carlise, Pa 11013 Re: Rose Parker v. Clarence Parker/Conciliation Dear M~ rulroy, *1 am ~t~ you to ask you to recoosider the false and illegal Contempt order that is going to allow Gina C~es's client rights to continue the child endangerment and molestation and sexually ~tted dease ring to continue*. The IS1h I have a drs. note that you will get a copy of and from -\lPw on the girls will have one every time they are sick per orders of children and youth. If this fWse contempt goes tbru amd her client is allowed to continue to have known felons ~tt; :::t~~ey will be working very close with the states attorney the district attorney and possibly the It ,ovemor of this state. This false contempt is getting to be Gina's clients favorite because shtl cant and will never tell the truth to her lawyer about this past holiday (24th December ~O;;) I was in contact with east pennsboro po. lice. "Officer. Mr. Nipple whom had a complaint fro a neighbor that one felon by the name of nick cromely whom is well known for beating and pted homicide on women that won't give into to his Sexual needs_ The officer whom I contacted because of a phone call from a neighbor had told me that the officer WlIl1ted to talk to me alloUi the girls being there wiJilhim in the house. The ot1ieer then informed me that he wanted e ' . Is removed from the house for t eir own sati and that if Gina's client wanted to e!me arrested he wasn'1 going to do it because her dient along with the above mentioned fllIon was in the house and is now living there along with mr. Troy grebinger full time so he wil1~ thr: when the girls are there therefore the officer doesn't want them th. ere and they have had ~ts on the felon being there by several neighbors and. has in the past called the police to havF him removed and then she lets him back in every time. Also because of the is incident Childnpl and youth have been notified of the client's lawyer not wanting to stop the molestation \Illd cbjld endangerment to continue until the judge is allowed to hear the children side of the sfpry 8lI well as mine. Also Gina's client said because the girls are on birth control pills it is :tiIl4 for them to be sexually active with thier brother and mr. Nick cromley whom are , both adults, lind tfe girls are IS and 16. There fore a copy of this letter will be sent to the states attomey,the di~ct attorney as wen as the federal district attorneys office and if need be I will have to get a fodi:ral attorney and have the case heard the state supreme court to over ride the order that iS$.lo/wing.._. child endangerment of Crystal and Mary Parker by their mom not fonowing h Ianers request to keep troy grebinger also you have signed a paer telling her to follow that v : strictly off the property. Gina's client allowing a know women beater and attempted m FfeIon in the house knowing that he is bad (Uld the police have known and that they we called ause the neighbor had called for the pro~on of the girls. Gina's client has '. and thinks its funny that this is going on and lies to children and youth every time they go there. and there fore for the safety of the girls Gina and Terri Henning need to be notified by you that children ~d youth are going to be doing an extensive investigation into why they are allowing this to ~. Everybody involved in the allowance of this will be getting a letter to inform them that the ~s uppn children and youths request are going to .have a lawyer because they are in danger every ~e they go to the house and because Gina and Terri have been lied to and wont listen to what the girls have to say. There is a full report of what happened at the Harrisburg office of ~<Jren and youth as of 12125/Cl for this on going allowance by my ex and her attorneys whpjn haven't been told the truth and that is clearly documented in the report at children mil yputh in HarrisbUrg and the CUMBERLAND county office. Also Bucks county children and youth are being notified of this last incident as well as the icendents of the past that mr nic~ crof1e1~ has do~e t~ my yo~est daughter Mary. Also I might add that from now ~ everytime the E are sick. 1 am gomg to have a doctors note 'from the emergency room stating why they can't.travel. And if Gina's client really cares for her kids health and well being then she should have ~ove for them an. d not call the lawyer everytime this happens and by no means has she been, with the lawyer at anytime tbru this and also the the pfa doesn"t need a sepecail no~ has sold of disposed of everything on IDeeann newhouses orders the federal government.isgoing after Gina's client for improper use of mail supplies registered to my postal meter which, i fJave with the the postal service and Gina's client is also going to have to answer to why she opJnsl other peoples mail boxes to see what they have. And as i stated if Gina's client really cared for girls she would respect their illness and follow what the doctor says. Also enclosed ;~i cOpy of the doctors report from the hospital as requested by the Harrisburg Office of children ~uth and i was told that if the lawyer doesn't care as well as the mother that things should be c. . ed so that the girls can have a good healthy life. Please pay attention to the underlined on this letter. copies to the ti lowing offices and people involed. Hubert . y States Atto Cumberlan copnty district attorney Bucks coun qhildren and youth Bucks county district attorney ~QlO/~ Clarence Parker -- - -_~.~-1 "\1$" .. .._ .- . ROSE MARIE PARKER, PLAINTIFF/ PETITIONER :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :CMLACTION -LAW : CUSTODY CLARENCE RAY PARKER DEFENDANT/ RESPONDENT :NO.01-93 CNIL TERM PETITION FOR GENERAL CONTINUANCE The Petitioner, Rose Marie Parker, by her attorneys, the Family Law Clinic, hereby petitions this Honorable Court to grant a general continuance of the hearing in this rnatter, currently scheduled for March 22,2002 at 1:30 p.m. In support of her petition, Petitioner represents the following: 1. The Petitioner is Rose Marie Parker (hereinafter "Mother"), who lives at 408 Third Street, West Fairview, Cumberland County, Pennsylvania, 17025. 2. The Defendant is Clarence Ray Parker (hereinafter "Father"), who lives at C-304 East Ridge Avenue, Sellersville, Bucks County, Pennsylvania, 18960. 3. On January 8, 2001,the Court entered a Custody Order, pursuant to the parties' agreement, granting Father primary physical custody of the parties' minor children, Crystal Parker, born April 11, 1985, and Mary Parker, born February 21, 1986, and granting the Mother periods of partial physical custody with the children. 4. Father repeatedly failed to deliver the children for their scheduled visits with Mother in violation of the Custody Agreement. 5. Mother filed for conternpt on September 6, 2001, and the matter was resolved. 6. Mother again filed for contempt on Novernber 14, 2001 after Father violated the order, and the matter was resolved in Conciliation. '! - .. ',", "-N,',"~""H '_,_-,.'~"!,__^, ,~__ ~--.I';"r_ -.c"", ,_'I" , ---,-. ~- ," ~;,," .__c ",p~,_ , 7. On January 3, 2002, this Court granted a hearing on Mother's Petition to hold Father in contempt, the hearing being scheduled for March 22, 2002. 8. It is the understanding of Mother's counsel that Father no longer has custody of the children, who now reside in foster care in Bucks County pursuant to a dependency proceeding in Bucks County. 9. The current Petition for Contempt resulted frorn Father's failure to deliver the children to Mother. 10. However, the children are now in foster care, not in the custody of Father, therefore, Father is not currently in a position to produce the children according to this Court's Order for Mother to exercise her periods of pretrial custody. 11. Therefore, this Court would not be able to order prospective relief at this time to vindicate Mother's rights. WHEREFORE, Petitioner respectfully requests that this Court grant a general continuance in this matter until such time as the children are returned to the custody of Father. Respectfully submitted, Date: .." I,,, I b ? r I ,~ --?~ B n R. Kaster Certified Legal Intern tJrPAt t: ~ ROBERT E. RAINS THOMAS M. PLACE LUCY JOHANSTON- WALSH Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 )i~ _ _~ _ ~. '-",,,~^-,' -.""-< -.',- - - ^,- . "~_ -';'1"'1''< -1!, j. -j .-, ~ - ~, , -- " -," ~~ ~---- " , - ,. - -- ~. . ,~,_ """'~"'1'~"" ,~~, ~<^', .,. 'I' .~=~ .,- "~ .~',~' ^"'~. ..""--~,"~', _0 ~ _[r. -"n ~ '"" (') C) 0 C f".) -n ~:. - U 1,n rn ["1'-, ;00 "22 ~ r ;"n (7) C,.:- =J -< ~ ..; ,''', [:::: c' u :-\; --'-I , - 'T' , ,) (5 - .. ." _I:...... Ci ':...., , , , ., ~ ~,..; _:~ ,,-, j"~ :rJ -:( \ 0 -< , "",pI!~""-!1"'''''''~'' "'''''!I!<W!lI''t'1tI~~~~~~. _~ "~~,. ~ ~ -~T~ \ , MAR 1 4 2002) ROSE MARIE PARKER, PLAINTIFF/PETITIONER :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :CML ACTION - LAW : CUSTODY CLARENCE RAY PARKER DEFENDANT/ RESPONDENT :NO.01-93 CIVIL TERM ORDER OF COURT AND NOW, this IF day of ,.,,~ , 2002, upon consideration of Petitioner's Petition for a General Continuance, it is ordered and directed that the hearing on this matter scheduled for March 22, 2002, at 1 :30 p.m. shall be generally continued. BY THE COURT, f}~ &3-1.1-0 /:.0: ~e:ft. -,F{lyil; L.J LCUJ 4/1 J. Kevin A. Hess C I ,.tJ"i C. . '-.,. -,,-, I'!"'I - . - '~"~,I ','- ,-x! ' (-,-,0,,-,- _ ~_ _ " , - . I .~ 7~"'T"~..' ".",\~",~,"" ,n,_,.'?_"'r_'___ ~.. ~" 1 'm," 'v -- ~ " -- .". ", - - ,. "0"' VINV/\lASNN3d ,\tNnO;) ::J" ".r;:r'17/",Jn8 Z l :~ !\J 11 I ~\t;-j ?iJ AU\;/lC:"- - - ""~ '" ., _ '7 _~_ _ wi'." t,S) \iJ ',-. ". '~""'"~,-~-,_"-,,."V'~__~~,,",'J~~_"~ .- ,,- U lliE' m') ~~~~~~~ _14_ \) ROSE MARIE PARKER, PLAINTIFF/ PETITIONER v. :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CMLACTION -LAW : CUSTODY CLARENCE RA Y PARKER DEFENDANT/ RESPONDENT :NO.01-93 CNIL TERM CERTWICATEOFSERVICE I, Bryon R. Kaster, hereby certify that on this 13th day of March, 2002, I am serving a true and correct copy of the Petition For General Continuance on the following individual, by fIrst class mail, postage prepaid: Mr. Clarence Ray Parker C-304 East Ridge Avenue Sellersville, P A 18960 FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243-2968 (') CJ c: l>.> C) $': ~ hn Hire ~r:::-... . ; 2rn _ ~r' ~'J i " z~' (j) , .. r~", ;::;;?: c.,) c;.:;' ~,,-. .. ~~: ;t... ~, ~",.. '.. . z,l_: '';-'''- , ~... )';0 ~~5'F;f c: y? 2; ~ ~ :;:J ~: , ID :0 -< Date -~ //:>. l, 7 I I mic ^c ,,',," ,~" I _I -I' -" .... -, '" i ~. "'~. ., ~". ""',,,' ,--~-..,,-- .<--.--"Tar;;.'" -"," -.J'",,~"_~" -,,-,.' ""~"v' ,- , ~ , ,,~ - ",.~"' "" -'-'~ "~ . <. '1Jlmll"" i~",'h"'l. ~,' J!!f:~';P"" "'!'r"Ti""iii"ilrr':Y"II" n_h.'~ '] .........nr C) [.~ ""'r1 :f,:~ r-''1C:-'i it -.- ~-::;t:. ",...-:-- ~~,r:, ~~f:~" -;:: 00 c::J ;\J ,.:"it .i~,," .-:::y ::';-1 -- C_, :;.) (".J <::.") ~~~_m~mll;lI"'"'._"~~"<ftif.P ,~m~f;_,. '~_ ., ~_ ""t,JI