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HomeMy WebLinkAbout01-0218 FX <<?~'''_ _ ,'>"'0 ~, ... '.", . DARRYL S. HENDERSON PLAINTIFF V. KATHY M. BISCUIT DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-218 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 12th day of January, 2001, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the 13th day of February ,2001, at 1:00 p.m. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to defme and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: Isl Melissa P. Greevy. ES~ Custody ConciliatoV\ 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 ;); '~' ,~T. .;=. '__ 'I < ~ -, " ~~ ,.J",- -*"'~~~'~>'~"~ """,_.",.1>- -,'(," -".j' fdY-'~!~(]~H :Tl1trtcr..ii";'.".I'~"~....i---' L', ,,,..,,,,. , i':":ll\( :~'li11i\ll(j'k cY;;~"\J'~'--}i~J , ! . ;z ~_~ -$ ~>if 4/@;, Y(;:~ ~ ~ ~J4. fL' .:7 ~ ~'n i.\ :'i ~) -.,:1 \ i 1" I I" \:'i~:r;';~~.;;.~I~t;:'r~-~i:JjffJO~Y'1r'{~J'':~'f;\ri}iiil~j~:":'j~";:~"::tif"~'~e!' ""fl%~ /c7' '1/-/ /r7' #J/-/ Jf7- 1/-/ >,~"""""'!"'~=~, ,'~ .~.~l~...,..,,~ "~_' "__~",,",..,..,l!ll!lill!l!'II'!'I)!'IIl\._~~ . ,.,,,,,,~~f1\lWil'~~"'"'''\~%~'''''f'''\~'''1!>"''i!''.''~.' 'T~R'~"J)!."I"'1Wi1\jl~ , '.", :;;~-'OIltJl__i!!\ljl~~r-N'm 0 - ~~.- ~..,_..-,-- c'''- v. IN THE COURT OF COMMON PLEAS OF THE 9TIl JUDICIAL DISTRICT OF PENNSYLVANIA, CUMBERLAND COUNTY No. O/-c;2/~ i;J CIVIL ACTION - CUSTODY DARRYL S. HENDERSON, Plaintiff KATHYM. BISCUIT, Defendant ORDER AND NOW, this of ,2001, upon consideration ofthe attached Custody Complaint, it is hereby ORDERED AND DIRECTED that the parties and their respective counsel appear before , the conciliator, at on the day of ,2001, at o'clock _.m. for a Pre-Hearing Custody Conference. At such Conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a temporary order. All children age five and 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: Is! Custody Conciliator The Court of Cornmon 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 TIllS 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 ""', -,~ -'I > " I, i I , v. IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA, CUMBERLAND COUNTY No. 01- 216' CIVIL ACTION - CUSTODY DARRYL S. HENDERSON, Plaintiff KATHY M. BISCUIT, Defendant NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgement may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICES SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. DAUPHIN COUNTY LAWYER REFERAL SERVICE 213 NORTH FRONT STREET HARRISBURG, PA 17101 (717) 232-7536 CENTRAL PENNSYLVANIA LEGAL SERVICES 213ANORTHFRONT STREET HARRISBURG,PA 17101 1-800-932-0356 ,,;: ".~<= , ~'~',! _0 "~_"'~>- ~, ~, I ." ~ ., ,., 1 , , v. IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYL VANIA, CUMBERLAND COUNTY No.&l. ;l/i" ~ I~ CIVIL ACTION - CUSTODY DARRYL S. HENDERSON, Plaintiff KATHY M. BISCUIT, Defendant CUSTODY COMPLAINT AND NOW, comes the Plaintiffs, DARRYL S. HENDERSON, by his attorney, Daniel McGuire, Esq., pursuant to 1915.1 et seq. of the Pennsylvania Rules of Civil Procedure to petition this Honorable Court for partial physical custody and shared legal custody of the within named children. In support of this request the Plaintiff asserts the following: 1. Plaintiff, DARRYL S. HENDERSON, is an adult individual residing at R.D. #2 Box 38, Loysville, Perry County, Pennsylvania. 2. Defendant, KATHY M. BISCUIT, is an adult individual residing at 118 Springfield Road, Newville, Cumberland County, Pennsylvania. 3. Plaintiff seeks partial physical custody and shared legal custody of the following children: NAME PRESENT RESIDENCE AGE Karen M. Henderson 118 Springfield Road, Newville Born 07-16-92 Cumberland County, Pennsylvania Katie M. Henderson 118 Springfield Road, Newville Born 11-04-95 Cumberland County, Pennsylvania 4. Over the past five (5) years the subject children have resided at the following addresses: 118 Springfield Road, Newville Cumberland County, Pennsylvania . 5. Over the past five (5) years the subj ect children have resided with the following individuals: a) From July 16, 1992 until, on or about, February I, 1999, with Plaintiff and Defendant. b) From, on or about, February 1, 1999, until present, with Defendant and Lou Biscuit. 6. The children were not born out of wedlock. 7. Plaintiff is the children's natural father. 8. Defendant is the children's natural mother. 9. The parties to this action divorced on September 20,1999, and are currently living separate and apart. 10. The only other action addressing custody rights to the within named minor children was the PFA action of Henderson v. Henderson, docketed at 97-2214 in the Cumberland County Court of Common Pleas. II. All persons having a claim of custody rights to Karen M. Henderson and Katie M. Henderson are named as parties to this action. 12. Plaintiff/Father desires to reestablish and maintain a relationship with the subject minor children. 13. Plaintiff/Father is able to provide a loving and safe environment to visit with and exercise partial physical custody of the within named subject minor children. 14. Plaintiff/Father requests partial physical custody rights that include a liberal visitation schedule, including overnight and holiday visitation, and liberal telephone communication with the subject minor children. 15. Plaintiff/Father requests shared legal custody of the subject minor children. 16. The best interest and permanent welfare of the within named subject minor children would be served by granting relief sought by the Plaintiff. ""'iIU" . WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant him partial physical <:ustody and shared legal custody of Karen M. Henderson and Katie M. Henderson. Respectfully submitted: ( {)~y/ Attorney fo Plaintiff Daniel McGuire, Esquire Supreme Court J.D. No. 81630 P.O. Box 61 Duncannon, PA 17020 (717) 834-5554 "._~___ "'" "'> ,~, r.,' -- " "'1--< . " '-,. .' \ !' -"_i_"'_'""'" DARRYL S. HENDERSON, Plaintiff IN THE COURT OF COMMON PLEAS OF THE 9TIl JUDIClALDISTRICT OF PENNSYLVANIA, CUMBERLAND COUNTY v. KATHYM. BISCUIT, Defendant No. CIVIL ACTION - CUSTODY VERIFICA nON I verifY that the statements made in the attached Custody Complaint 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: /- 02 -01 JkM1.f !t~M/01 ~ SIG 1\TURE) Darryl S. Henderson --',,>,," '-'.1 ':-<1'--,.<, -" i I v. IN THE COURT OF COMMON PLEAS OF THE 9TIl JUDICIAL DISTRICT OF PENNSYLVANIA, CUMBERLAND COUNTY DARRYL S. HENDERSON, Plaintiff KATHY M. BISCUIT, Defendant No. CIVIL ACTION - CUSTODY CERTIFICATE OF SERVICE I, Daniel McGuire, Esquire, hereby certify that, on this date, a true and correct copy of the foregoing Custody Complaint was served upon Kathy M. Biscuit, Defendant in the above-captioned matter, by mailing a copy of said Custody Complaint from the New Bloomfield Post Office via first class mail postage prepaid to the following address: Kathy M. Biscuit 118 Springfield Road Newville, PA 17241 DATE: S;.w 10 I ?co1 r:.~~1:f IZ Daniel McGuire, Esquire Supreme CourtI.D. No. 81630 P.O. Box 61 Duncannon, P A 17020 (717) 834-5554 \ AMERICANS WITH DISABILITIES ACT OF 1990 The Juniata County Branch of the Court of Common Pleas for the 41 st Judicial District 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 my 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. ".?1 r _ 11. I' ,. II _"~.~._>..,~ '_n' , .~_ ~ _"_"~ ,,_._,~ ~'", ~ . _ ~~JIlI!II";,~ ,~." ,r ~ ~~ ~ ~ "~,'~.~",. '. '.,", ','. "".",," -- .....lll.....--"l!r (") 0 c: ~ ~ , ~ -rJ(,Ci "-, - ~ rni-;'; '.. Z' ~ -" ~. ..--, (=, :::/-' ~~ ~ ~..,... ~=~~~: :-];~ ~,:'_ ,. '"._. I ~'-... \ ..i"'('-' ., 'J1 , ---{ --< (:;.: ;/ ~ ~j) H, ~ " ~~ ~ ,"'~_' "'''' ~ "<co, rHI!J~"W:";;'~~--"c;,-"ol\;';;:,>.,'WY')"~~~~~Q."-~~~~~ DARRYL S.IIENDERSON, PLAINTIFF : TIlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-218 CIVIL TERM KATHY M. BISCUIT, DEFENDANT CIVIL ACTION - LAW IN CUSTODY PRAECIPE TO ENTER APPEARANCE To Curtis R. Long, Prothonotary: Please enter my appearance on behalf of the defendant, Kathy M. Biscuit, in the above captioned case. Respectfully submitted, By: Marcus . McKnightj e 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Attorney for defendant, Kathy M. Biscuit Date February 14,2001 !':t_, ,- ,",'- . -~ - ~~ ,- - .," - ,-,- --,- ."", -~ -,,-~~---, - ,..,-,',.,.'" ";0,""'" .:.G.<,'1-".L.- ~'~r,--'''A(~<C-,",'",,'''''''''''''-"'''''''- --~l't'~ttll'~m":~"~ - (") ~:; -o~; nlr'h Z:U ~~t:. u. ~ <- ):>r--, Z-~"-"< );~; ~ -< ,-~ .- .",.......~~l!:1~~"" CJ "1 C'1 UJ' :r,,,, ~ ~il<!lIl1!l1l~!I,"_=,,,,"~~~ c::.::: ;:) 0;, 17 -< ': " i i , '.1"1 ,. DARRYL S. HENDERSON, PLAINTIFF : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. KATHY M. BISCUIT, DEFENDANT NO. 01-218 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certifY that a copy of attached Praecipe to Enter Appearance was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: Daniel McGuire, Esquire P. O. Box 61 Duncannon, P A 17020 Attorney for Plaintiff By: Date: February 14,2001 -''', ,. ~ -"-~.- - -~~--'''''-- ,., _.-~ """""" -~~~ -, '--'~'- .~-" ~- '''I'"^- c'"'" ~ ,-.- ~ ~ -~, " ',' , - , >~" .'~ " .-,' '~'"-' . w --~',..;,_'."..,,", .,','c,. ',' ,.",-,-;~',,,, ',,~" d0>C"'"''''-'~-''''l['.i''''-c",,'';'V-''(O~-li~'j"''~'':'- (") C < -nm n1r:'l ~[~'- (j) .--: -<. .c:::_ r:: ~:.~- :;;,-, 5~S! :2:: :::;:I '". C) '"T'l rT'l C'J ::::~~ (3 ~ ~. :::< C'') -"'?"'-'f"'!"7'~~~~~~~~ "'Ql:'l!lJ!ilIl!~!f_,,~2 , .'" MAR 2 2 2001!f) . . . ... vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-218 DARRELL S. HENDERSON, Plaintiff Defendant CIVIL ACTION - LAW CUSTODY KATHY M. BISCUIT, ORDER OF COURT AND NOW, this '2---1 day of March, 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Physical Custody. The Mother, Kathy M. Biscuit, shall have primary physical custody of the minor Children, Karen M. Henderson, born July 16, 1992, and Katie M. Henderson, born November 4, 1995. 2. Father, Darryl S. Henderson, shall have partial physical custody for the Easter holiday on April 14, 2001, from 10:00 a.m. until 7:00 p.m. 3. Father's periods of partial custody shall be on Saturdays at 10:00 a.m. until 7:00 p.m. and on Sundays from 9:00 a.m. until 5:00 p.m. Father shall provide notice to Mother by 5:00 p.m. on Monday preceding the weekend when he would like to exercise his periods of partial custody. It is contemplated by the parties that these visits will occur two weekends per month. In such periods of partial custody which Father may exercise on Sundays, the parties shall share transportation at the end of the Sunday visit by meeting at the agreed upon halfway point at Colonel Denning State Park. 4. An expansion of Father's partial custody to include overnight periods shall be agreed upon by Mother and Father conditioned upon the following: A. The Father shall have a psychiatric evaluation at his own expense. Father shall sign the appropriate forms to consent to release information so as to provide to his counsel a copy of the report. This report shall be provided to the opposing counsel. The referral questions shall include an assessment of whether or not the Father is presently in the need of psychiatric medication, and whether he is presently able to exercise overnight periods of partial custody with his minor Children. B. The Father shall follow the appropriate post-lice infestation protocol as provided by a school nurse or the Pennsylvania Department of Health with regard to the cleaning of linens, etc. "', 'I ,.., ,~ "1_ '_'r - .1- - 'I - ~,' . . No. 01-218 4. The Custody Conciliation Conference shall reconvene on Monday, May 14, 2001, at 9:15 a.m., at the office of the Conciliator, Melissa Peel Greevy, Esquire, 214 Senate Avenue, Suite 105, Camp Hill, PA 17011. At that time it is expected that the psychiatric assessment which Father will obtain will have been completed and that a copy of the evaluator's report will be available by the time of the Custody Conciliation Conference. Dis!: Daniel McGuire, Esquire, PO Box 61, Duncannon, PA 17020 Marcus A. McKnight, III, Esquire, 60 W. Pomfret Street, Carlisle, PA 17013 I f\ ^JP <\,,0\ \)rr D?)~ ~ ~~ I' " ~ ,-."P- , ' . _, _,~ " " 1-'" , -',1 . ViH\iAlASNN3d , I ~!n(n (H"'o'lH:'Jt1i!\Jn:l 1\lJ, '~J _1" I ',. _ C r "-' 8'1 :01 IW SZ (JVW 10 AH\710:\]i',>t; t:,~<!:; :';,-':.1. :10 3~)L:LIO-(13-kl ^' """""",o,.~_~M...~ _~" ~ '."To."" '" , , ~ ,~~~-"' "0'.'-'1-', '_'- _'''''_m~"",,'_''_' ~.",~ .~~~__ '~"'''n~wUlir 1 ". ,.._~i~~!m!~:I%-<il-;J:~-W~~'lI'lF,'ll;;"fw,':~.!~<Vl~m~~,~"H_', ~ "~"1,_>J'f_~' "<, vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-218 DARRELL S. HENDERSON, Plaintiff Defendant CIVIL ACTION - LAW CUSTODY KATHY M. BISCUIT, CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Karen M. Henderson Katie M. Henderson July 16,1992 November 4, 1995 Mother Mother 2. A Custody Conciliation Conference was held on March 13, 2001, with the following individuals in attendance: the Father, Darrell S. Henderson, and his counsel, Daniel McGuire, Esquire; the Mother, Kathy M. Biscuit, and her counsel, Marcus McKnight, Esquire. Date 3. The parties reached an agreement in the form of an Order as attached. :i/d-!/~ ~~,~ Custody Conciliator '.1 ,I' " ~_ "._~. ~ - , I-T I" ,- " :ri6jJ~i'I:~;~~~~\';:J;" '.. r4; >Lc", JUN 1 8 200ft/} . vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-218 DARRELL S. HENDERSON, Plaintiff Defendant CIVIL ACTION - LAW CUSTODY KATHY M. BISCUIT, ORDER OF COURT AND NOW, this -vtJ day of June, 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. The physical and legal custody portions of the Order of March 23, 2001, shall remain in full force and effect. 2. Father shall arrange for a psychiatric evaluation as previously ordered in Paragraph 4 A. of the March 23, 2001, Order. Counsel shall share results of the evaluation prior to the next Custody Conciliation Conference. The Custody Conciliation Conference shall reconvene on August 20,2001, at 9:15 a.m. at the office of the Conciliator, Melissa Peel Greevy, Esquire, 214 Senate Avenue, Suite 105, Camp Hill, Pennsylva . 17011. Edgar B. Bayley, J. Dis!: Daniel McGuire, Esquire, PO Box 264, New Bloomfield, PA 17068 " C Marcus A. McKnight, III, Esquire, 60 W. Pomlret Street, Carlisle, PA 17013 J OF1 N I mal bL (P~I/OI ':::1:1r) I - ~. , . d" ~" ," ,-~ , I '>: I' 1-' ;--1 ' " VINV/\lASNN3d ALNnC'.O (]~!'rllt!j8illno Z (, :8 H\I i 2 nrw Ie AlNKi<,iiC TC., _ . .,~_. "q~ -, -'c..., ",<"!'_ ,~n -.~~n_ -~'C_^__'- ~ .....~ "~~ ,-,- . " " . - """' "'." ."."'~ " '.".'" . 1ll1llf'IIIT IIlIr "'Mli\ff&;j .... ~.. .'_ r-o-,.,,,. ',,0 "."T____ "_~~'fil').'l',-~:""W'!'1/!,1i~"'I'1~~1Ill!'ffi!'l1~ ___:~".~~rrrJ;Il~~~~' 'it'~:-:f,;d-t,ch* , . vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-218 DARRELL S. HENDERSON, Plaintiff Defendant CIVIL ACTION - LAW CUSTODY KATHY M. BISCUIT, CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Karen M. Henderson Katie M. Henderson July 16, 1992 November 4, 1995 Mother Mother 2. A second Custody Conciliation Conference was held on June 11, 2001, with the following individuals in attendance: the Father, Darrell S. Henderson, and his counsel, Daniel McGuire, Esquire; the Mother, Kathy M. Biscuit, and her counsel, Marcus McKnight, Esquire. 3. The parties reached an agreement in the form of Melissa Peel Greevy, Esquire Custody Conciliator & /6/ DJ Date / / ~i - -, . "'~' '.- '"" ". I'" I~- , rll" OCT 3 0 ZOOl ff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-218 DARRYL S. HENDERSON, Plaintiff Defendant CIVIL ACTION - LAW CUSTODY KATHY M. BISCUIT, ORDER TO RELINQUISH JURISDICTION AND NOW, this 19th day of October, 2001, a Continuance having been requested by both parties on September 10, 2001, and the Conciliator having received no request for an additional Custody Conciliation Conference date, the Conciliator hereby relinquishes jurisdiction of the matter. el ssa Peel Greevy, Cus ody Conciliator !:'-',;rrr, 1_,_ t_,-;., -,'-'--' - I" . "'~I " " "1 ~ .~ ~ ~ ~.~ __~ . p-Vo/"""" ~ ~ ~.," r. ., ~.~,. , ~,'~ ~. ,H~ ~,~ _ _ _," ('") C .C' VerJ mL:;:~ Z.. -y,- 0:-'-)'";-<-, -<' ~:c: ~~.~ L..:, -<~ ..... C) ,'-'\ ~'j-l ::::::: r:_~~ -, 1::-0::. }-,~; i C) c~ 1"..) c) :::> (n C';",, -.< ~_"'i',.,~." . ,~If'1~!W'-j$'l!PI'il'.,~'[j'Mfi\-"II'~g;yp;.=1~~~''''ti!l~<lMIl;1'i1,f~J~$~'!}:wP~!J~i:~' JUN ~2 o v. IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA, CUMBERLAND COUNTY DARRELL S. HENDERSON, Plaintiff KATHY M. BISCUIT, Defendant No. 01-218 CIVIL ACTION - CUSTODY AND NOW, this RULE TO SHOW CAUSE ~day of ~ , 2002, a rule is hereby issued to " show cause why counsel for the Plaintiff should not be granted leave to withdraw his appearance from this action. This rule is returnable in /5 . days from the date of service. If no objection is raised within the allocated time period, Counsel for the Plaintiff shall be granted leave to withdraw his appearance from this action and this order shall be deemed self-executing. 1. 'v1i\iV/il,\Ci~I~'Prl \."rn~r .. '- "."" ~ l.1\.U kI. i ("!\:~t!t.:':-:'G:!'ll^ - ...."_.,) ,I..,._,<J~ ~I J z! :01 'It I r: - -'r'll"' 70 .');; (, i C. 1).1'."(,, """ 'I " AUVJ.. ii .!,',...'rn" (. ,1,c"_J -:,.ll' -'.0 '____J_',' '; I ' 3~;i.:bC"GJi;d.' - 'I . . ,'0- , . <'" . "f t t, ft\ ~'~ 'P~~ ~ ('> ..::. , '" ,:" " t" !.1j""'1 ~ -~, .",,,.,,...~llmlW11il!l_iii!i!l1illW~~i'1 .' ~ s, ~~ ~ .<-~c _,~,^ "'''~'~-;;-~'- "'"-"h~"".,V""....c',-"."p.8'''>''''''~--"'"' -,.~.~ ~- _ "UIBJlill . '3'"'' _ ,_"lm'~-.W";"FE"H'""f,"W.'W"'"""r-~; --;";'-Y;~"1r'-j~~"I1~\lj~1!!,'Jl~~Vl?""""';!;1J,'O(~!!lI'~~~,p.l1!ijlt.;~ ..~' . I v. IN THE COURT OF COMMON PLEAS OF THE 9TIl JUDICIAL DISTRICT OF PENNSYL VANIA, CUMBERLAND COUNTY DARRELL S. HENDERSON, Plaintiff KATHY M. BISCUIT, Defendant No. 01-218 CIVIL ACTION - CUSTODY PETITION TO WITHDRAW AND NOW, comes Counsel for the Plaintiff, Daniel McGuire, Esquire, (hereinafter the Petitioner) to petition this Honorable Court for leave to withdraw from the above-captioned action. In support of this petition it is hereby asserted: 1. Petitioner has left private practice and, due to new work related responsibilities, Petitioner is unable to continue representing the Plaintiff. 2. To the best of Petitioner's knowledge, information and belief, there are currently no other motions or petitions filed in this action that are currently pending before the Court. 3. On April 14, 2002, Petitioner and Plaintiff discussed Petitioner's need to withdraw his appearance from this action. At said meeting, Plaintiff raised no objection to Petitioner withdrawing from this action and agreed to execute a Praecipe to Withdraw. See Exhibit "A" 4. Subsequently, Petitioner attempted to filed the Praecipe to Withdraw with the Cumberland County Prothonotary but it was not accepted because there was no attorney simultaneously entering an appearance in place of Petitioner. 5. Circumstances require Petitioner to withdraw his appearance, the Plaintiff has cooperated in assisting Petitioner to withdraw from this case and the Plaintiff will suffer no pr~udice if this Court were to grant the relief requested by Petitioner. .," ~'-' .I ?~-,. -I ,. WHEREFORE, Petitioner respectfully requests that this Honorable Court issue a Rule to Show Cause why the relief sought by Petitioner should not be granted. Respectfully submitted: 0~/t, Attorney for Plaintiff! Petitioner Daniel McGuire, Esquire Supreme Court J.D. No. 81630 P.O. Box 264 New Bloomfield, P A 17068 (717) 582-8883 \,.- .-1-'".' t'l v. IN THE COURT OF COMMON PLEAS OF THE 9TIl JUDICIAL DISTRICT OF PENNSYLVANIA, CUMBERLAND COUNTY DARRELL S. HENDERSON, Plaintiff KATHY M. BISCUIT, Defendant No. 01-218 CIVIL ACTION - CUSTODY PRAECIPE TOWITHDRA W AND NOW, Counsel for the Plaintiff, Daniel McGuire, Esquire~ by agreement of Counsel and Defendanthereby withdraws his !\ppearance from the above-captioned action. e. I DATE: 4/)r()~ ~n:l4 fi4ff/j$U Darrell S. Henderson DATE: M4-l11 ~ ,2rJOL (j)pYl SIGNATURE Daniel McGuire, Esq. Ex HL~tT '\A l' . e'T'~,"""""""~l,""'1."",, ,. 'I __,J 1-< 'r - , r,~ , ' ' v. IN THE COURT OF COMMON PLEAS OF THE 9TIl JUDICIAL DISTRICT OF PENNSYL V ANlA, CUMBERLAND COUNTY DARRELL S. HENDERSON, Plaintiff KATHY M. BISCUIT, Defendant No. 01-218 CIVIL ACTION - CUSTODY CERTIFICATE OF SERVICE I, Daniel McGuire, Esquire, hereby certifY that, on this date, a true and correct copy of the foregoing PETITION TO WITHDRAW was served upon MARCUS A. McKNIGHT, III. Esq., Attorney for the Defendant, KATHY M. BISCUIT, and upon the Plaintiff, DARRELL S. HENDERSON, in the above-captioned action by mailing copies of said PETITION from the Harrisburg, Pennsylvania Post Office via first class mail postage prepaid to the following addresses: Marcus A. McKnight, Esq. Irwin, McKnight and Hughes 60 West Pomfret Street Carlisle, P A 17013 Mr. Darrell S. Henderson RR #1 Box 2090 Blain, P A 17006 DATE: -=:J'(,U.J6 2.(' 70{)2 I C;;;JdI/2- Attorney for Plaintiff I Petitioner Daniel McGuire, Esquire Supreme Court J.D. No. 81630 P.O. Box 264 New Bloomfield, P A 17068 (717) 582-8883 I.". , .,- II . , . ~ i I, _, 1R1IR..i..4 ..)lJ!!l" ,..",;~"'" _~ ~, .".~, ,. _, ] -0 - ,~ -,~,x _._.". .., ,,', . ,'-'"'''~'''''';. '.", - _.~ ~">W"..J",>-;w,- ," -= o c ~ vel.': D)r.-!:': ;;:~fu ~~: ~~ z -'I -<. ~ rr "frr" r- i;:':,:, c) -f... ~ 1;Z;::: '" c-'") -0 " , ......' (..:> :rJ --< ]I....,.,,,, ,_~,~" ~___,!jl!~~\"'l''''';"'<;~;''''11''''P'"_'t'''O'',^1T;;;''"1rl~j;'i!';1'-!!l.,.Wi;.~~j!i!fo'\'!'l"I!l',!;li~~~f-ill!i_I!IJ~~!'!II!l';;~\'illjl''''' . . DARRYL S. HENDERSON PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 01-218 CIVIL ACTION LAW KATHY M. BISCUIT DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, September 27, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before, Melissa P. Gree\')', Esq. , the conciliator, at MDJ Manlove, 1901 State St., Camp Hill, PA 17011 on Friday, November 10, 2006 at 8:30 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 and all existing Protection from Abuse orders, Special Relief orders. and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: Isl Melissa P. Greevy, Esq. Custody Conciliator jfr- 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 A TTORNEY 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 .%.,,,,,!~~ '~~"I -f.-' I' , II ~~ ~,""._~ ~M1:)i . n'w ~~,"'<'~ __"_,_","",,-,_,__,,~__,, _._~,."," _",,<~",,~_,~",~.,~,.~~.~.~~, ~ ">"''''_''"'~'I , . ~f/P .~~4kl /fr' ? ~ ~tt., ~~W ~ fl r ~? fJ1J #)G -61'- "I, 7rJ6't'-# 'P~Y?-b \fil\i~!J\lASNN3d AlNnC{li,~II:08i!'ln::J 6S : II W~ 6<:: d3S 900l ').liff IU"T'I-' I n';d :tHl :10 LI1 A..,'o'...!. I',U'I-'-''''..... -' pit{ 38l.:1jO,..Q31f::f i!, _~, _~!llW!'l___~~~~7IW<"1l';'"l'-*f&<y,''@P'o/;';'i'''-;,j'C3!;'''''''~'!"",",JfJ_i\'f~ll11'~_~~0';;;~~",,~I~"ffl"~iI.I1~~~ . ' RTC1'01'-""'!'" '":~":"I -'-r ~ J~~; '\, .!:_"-~". ~~...-:' I SEP 2, fi,,2,:J06 BY: '. '\^ IN THE COURT OF COMMON PLEAS OF DARRYL S. HENDERSON, PlaintiffJRespondent : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2001-218 - CIVIL TERM KATHY M. BISCUIT, Defendant/Petitioner IN CUSTODY ORDER OF COURT AND NOW, this day of , 2006, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before Esquire, the conciliator, at , on the _ day of , 2006 at _ . M. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at this conference may provide grounds for entry of a temporary or permanent order. By the Court, By: Custody Conciliator 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 32 North Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 1-800-990-9108 rr__"',~~r' , - ~,'d"'".,...,.,-~_,.~<"___",,..___~u_~,,_", ~_=_~"__ ~I" '" -~ --, I :;'~-_-"_'I .'7. - . ~ , . 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 acconunodations 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 scheduling conference or hearing. ^""'~",~~, ," ,. , ~ ~ _~__._ '-'F''''_~' '" -';1-. "',,, ,'_"_"_~, "'0_ ,or. _n_"."'__'_" '"'H' ,., ,<. ,'"" ,~ .. - : IN THE COURT OF COMMON PLEAS OF DARRYL S. HENDERSON, Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2001-218 - CIVIL TERM KATHY M. BISCUIT, DefendantJPetitioner IN CUSTODY PETITION TO MODIFY CUSTODY AND NOW comes the Petitioner, Kathy M. Biscuit, by her attorneys, Irwin & McKnight, and presents the following Petition to Modify Custody. 1. The Petitioner is Kathy M. Biscuit, an adult individual residing at 112 Fish Hatchery Road, Newville, Cumberland County, Pennsylvania 17241. 2. The Respondent is Darryl S. Henderson, an adult individual residing at RR #1, Box 221- A, Loysville, Perry County, Pennsylvania 17047 3. The parties are the natural parents of two (2) mmor children, namely Karen M. Henderson, born July 16, 1992, and Katie M. Henderson, born November 4, 1995. 4. The parties are currently governed by a custody Order of Court dated March 23, 2001, a copy of which is attached hereto and marked as Exhibit "A". 5. The Respondent has had a roommate, Robert Lee Moyer, residing at his residence, who has recently been charged with rape of a 13 year old girl. The Respondent has permitted the minor children, Karen M. Henderson and Katie M. Henderson, to be in Mr. Moyer's presence during his periods of partial custody. Ik ",. " ~"',;""~~,~" O,,"_,",~ .'. _..'_' _ '_,',I",~__~_, . _~ ~__" ,~~__ ,. ,0 .". . ., 6. The Petitioner desires that primary physical custody of said children remain with Petitioner, with joint legal custody and periods of supervised custody to Respondent. Under no circumstances should said minor children be permitted to be in the presence of Robert Lee Moyer. 7. The best interests and permanent welfare of the minor children requires that the Court grant the Petitioner's request as set forth above. WHEREFORE, Petitioner, Kathy M. Biscuit, respectfully requests that she retain primary physical custody and shared legal custody of Karen M. Henderson and Katie M. Henderson, as provided herein, with periods of supervised custody to Respondent. Respectfully submitted, By: Date: September 22, 2006 (1.0''''1 - c', ,~,~ _~ .,C_"~i_~_""____T'_~,,,,_,,_ ,',,""^~~_~__ >'~I,~"_"_. ~.,- '. -. --,,- j','I\R" ,J .."1". d; \I!M \ L' ~.. ,'1 I .11' vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA /~\ NO, 01-218 ~',~'" ~, Lj " ',,> DARRELL S. HENDERSON. Plaintiff Defendant CIVIL ACTION - LAW CUSTODY {/ KATHY M. BISCUIT, ORDER OF COURT AND NOW. this J 3 day of March, 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1, Physical Custody. The Mother, Kathy M. Biscuit, shall have primary physical custody of the minor Children, Karen M. Henderson, born July 16, 1992, and Katie M. Henderson, born November 4, 1995. 2, Father, Darryl S, Henderson, shall have partial physical custody for the Easter holiday on April 14, 2001, from 10:00 a.m. until 7:00 p.m. 3. Father's periods of partial custody shall be on Saturdays at 10:00 am. until 7:00 p,m. and on Sundays from 9:00 a,m. until 5:00 p.m. Father shall provide notice to Mother by 5:00 p,m. on Monday preceding the weekend when he would like to exercise his periods of partial custody. It is contemplated by the parties that these visits will occur two weekends per month, In such periods of partial custody which Father may exercise on Sundays, the parties shall share transportation at the end of the Sunday visit by meeting at the agreed upon halfway point at Colonel Denning State Park. 4, An expansion of Father's partial custody to include overnight periods shall be agreed upon by Mother and Father conditioned upon the following: A. The Father shall have a psychiatric evaluation at his own expense. Father shaH sign the appropriate forms to consent to release information so as to provide to his counsel a copy of the report. This report shall be provided to the opposing counsel. The referral questions shall include an assessment of whether or not the Father is presently in the need of pSYChiatric medication, and whether he is presently able to exercise overnight periods of partial custody with his minor Children. B, The Father shall follow the appropriate post-lice infestation protocol as provided by a school nurse or the Pennsylvania Department of Health with regard to the cleaning of linens, etc. No 01-218 4. The Custody Conciliation Conference shall reconvene on Monday, May 14, 2001, at 9:15 a.m., at the office of the Conciliator, Melissa Peel Greevy, Esquire, 214 Senate Avenue, Suite 105, Camp Hill, PA 17011. At that time it is expected that the psychiatric assessment which Father will obtain will have been completed and that a copy of the evaluator's report will be available by the time of the Custody Conciliation Conference, BY THE COURT, D"t Daniel McGUire, EsqUire, PO Box 61, Duncannon, PA 17020 MarcllS A. McKnight, III, Esquire, 60 W. Pomlret Street, Carlisle. PA 17013 ~ ~.~(l~~~) , ",y hond ~;} ~ ~';., / ~ ) fY10.R: "'~I... id>>~n.. . I') ,~rliol~ofary ~~;"P--, ;~ . ~~ 1-'"'" _ ..F_ ""'! 1-1 DARRELL S. HENDERSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01-218 KATHY M. BISCUIT, Defendant CIVIL ACTION - LAW CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH July 16,1992 November 4, 1995 CURRENTLY IN CUSTODY OF Karen M. Henderson Katie M. Henderson Mother Mother 2. A Custody Conciliation Conference was held on March 13, 2001, with the following individuals in attendance: the Father, Darrell S. Henderson, and his counsel, Daniel McGuire, Esquire; the Mother, Kathy M. Biscuit, and her counsel, Marcus McKnight, Esquire. Date 3. The parties reached an agreement in the form of an Order as attached. :1/21107 ~~ 8-7 Melissa Peel Greevy, Esquire Custody Conciliator i:",. ~l . ._ ,_ ~ ~ ." I t ,~ L, r. , , . ~ VERIFICATION The foregoing Petition to ModifY Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have head the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. . C.S.A. Section 4904, relating to unsworn falsification to authorities. ~'11J~ T M. BISCUIT Date: SEPTEMBER 22. 2006 '""",-.- __r,'"". _""'~.I' _"~' '. ~ "~,, ___ ... ._ _oeM '-. - ~^'''''''' ._"^ . >"'~- 'ttt> ,. -'~'~<_',",,-__...-.d' ''''_''<~'"_''' '_~-"'~" _'w'" __,_';"~,,,,-." -:'~'_ ,\,5 .",c..-,- '" ,'~' <J'.. ,'~O' '" ,,~ ... ~_~M"" """..>,., d~"_~' "" .,_ ~, '_ -.'" p~ .~ '0 '" ..., -..; ~ l!J G (v <:) > H '_c<, . "". } -~ ~ .r .. 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