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Home My WebLink About01-0570 FX '~- . , .- .-;..~'-= ,_ _ : <-_~_~i -.' .-",~ - ~*": LISA L. RUSSELL Plaintiff v. IN THE COURT OF COMMON PLEAS CL~BERL~ COL~ITY, PENNA. No.or-510 ~ I~ CORY M. RANDALL Defendant CIVIL ACTION ~ LAW CUSTODY COMPLAINT IN CUSTODY AND tl0W, comes Plaintiff, Lisa L. Russell, by and through her attorney, James W. Abraham, Esquire, Abraham Law Offices, Harrisburg, Pennsylvania, and files the following: 1. Plaintiff, Lisa L. Russell ("Mother") is an adult individual who currently resides at 2508 Warren Way, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant, Cory M. Randall ("Father') ~s an adult individual who currently resides at 1233 North Mesa Drive, Apt. 1061, Mesa, Arizona, 85201. 3. Mother and Father are the natural parents of Skyler Olivia Russell, born August 30, 1998, age two (2). Mother and Father were never married. 4. The child has resided with the following person(s) at the stated addresses since birth: A. From August 30, 1998 through November, 2000 with Mother and maternal grandparents at 309 Deerfield Road, Camp Hill, PA. B. From November, 2000 to the present with Mother at 2508 Warren Way, Mechanicsburg, PA. 10 ; , , L_ '-' .---"-- 5. Mother has not participated as a party or witness, or in any other capacity or in any other litigation regarding the custody of the child in this or any other court. 6 . Mother does not know of any person not a party to the proceedings who as physical custody of the child or claims to have custodial or visitation rights with respect to the child. 7. The best interests and permanent welfare of the child will be served by granting Mother primary legal custody and primary physical custody, in that: A. Since birth and for the last 2 1/2 years, Mother, age 23, has been the sole, primary caretaker of the child. B. Since birth and for the last 2 1/2 years, Father, age 22, has not visited the child nor has Father made any significant contact with Mother as to the child; nor has Father made any significant attempt to do so. Only within the last few months has Father telephoned Mother requesting visitation. C. Since birth and for the last 2 1/2 years, Mother has provided for all of the child's physical, emotional and daily needs. D. Mother works full-time as a nurse and has provided all parenting duties for the child. E. Since birth and for 2 1/2 years, Mother has provided the only stable and secure family environment for the child. .1 , -I '. ' , "~, ~". .' '< F. In consideration of Father's lack of contact and/or concern for the child for 2 1/2 years, as well as Father's residence in Arizona and the child's young age: 1) Mother should be granted primary legal custody as well as primary physical custody; 2) Father's "visitation rights" should initially be restricted to limited and supervised contact with the child for a few hours, with Mother and a supervisor present; and cdntact/visitation thereafter should be contingent upon the child's reaction, response and comfort level, in conjunction with the availability of Father in view of his residence in Arizona; 3) Father, age 22, should be required to attend and complete a parenting class program and/or counseling prior to, or in conjunction with, any contact and/or visitation with the child. 4) The child should not be removed from the Commonwealth of Pennsylvania or Mother's custody and no visitation shall take place in Arizona or elsewhere unless ordered by the court or otherwise agreed to in writing by Mother. WHEREFORE , Plaintiff/Mother, L. Russell, Lisa respectfully requests Your Honorable Court, to grant primary legal custody and primary physical custody of the parties' child, Skyler Olivia Russell, and provide Father visitation/contact with the child as stated hereto. Respectfully submitted: ~ DATE: 1/29/01 James W. Abraham, Esq. Abraham Law Offices 513 North Second St. Harrisburg, PA 17101 (717) 232-7825 Attorney for Plaintiff -~,-". I , 'I "I i~ : , ,:1 ',' I , I "'I ;1 " I.i 'j ~ iI 'I :: :1 fJ II [I Ii :1 'I 1 j , II I, " -'-' , ',"",- " ' -. ;,t,'", I, /UA VERIFICATION J, (Lj[GZ , the undersigned, hereby verify and confirm that I have reviewed the foregoing document and the statements therein are true and correct to the best of my knowledge, information and belief. I further understand that any fa{se statements made herein are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. DATE: l-dS~ 0 I , , 1,_ - '~~ ''''':~'' CERTIFICATE OF SERVICE I, James W. Abraham, Esquire, the undersigned, do hereby certify that I have served a true and correct copy of the foregoing document, by certified mail, on the date indicated below, to the following person(s) : Cory M. Randall 1233 North Mesa Drive Apt. 1061 Mesa, AZ 85201 DATE: 1/29/01 James W. Abraham, Esq. r. (j) 0_L~9>~9t'F~~~~ OF i! i, ; :l) L~uN-.Ji,h,RY 01 JMl29 AM 8: 01 C' UlV""'f:Gu' ',-'il) COUN1Y . Ie..... 1 '",~.. ! PENNSYLVANIA t -Y6.sO ..r. 60 ~CO- ~~-r- "-- ~.~O -Pcl-I*"f,!f Ck#- .1f17 R::tL lut.. pp,c; "1-. '" I,... ",~,,,,,' ~~ '- ~-" ~. ~ . 0' . LISA L. RUSSELL Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. OJ- ~...,o d'od ~~ CIVIL ACTION - LAW CUSTODY CORY M. RANDALL Defendant ORDER yOU, CORY M. RANDALL, have been sued in court for custody of the child, Skyler Olivia Russell. You are ordered to appear for a custody conciliation conference, at Cumberland County, Pennsylvania, on 2001, at o'clock, At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court and to enter into a Temporary Order. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent order. If you fail to appear as provided by this Order, an Order for custody may be entered against you or the Court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator 4th ~loor, CUmberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6200 DATE: . I , "',' LISA L. RUSSELL PLAINTIFF V. CORY M. RANDALL DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 01-570 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 31ST 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 conciliat at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the 7th day of March ,2001, at11:00 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. FOR THE COURT, By: Isl Melissa P. Greevy. Esq.fJt1 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 HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~T ~' -~" - ~~ ~__~"" ~''''C'-~..9_''''''~ 'M__ . . ,.. ., ~<~, '11 Fil"'n ~- OF /'-~~i:,"~;7:.t!:~~S 1 ",}!,i,JAAY 01 FED I) '-I 1'J11 >'I, 0: I':; Cuu- .., 1'V!bb~;! i,', c'_ PEI~i'iJSyfj'PIOUNTY Vfll\!A ;},/,tJ/ dd ~~ ?j- a$' ~ .:UN ~~Z'j//o/;t#. - d-/<1/ 4w~ ~~~ :~ . _ " ,_ "" ~ ,,!,:,?,,Yi1I_:'!l' , ,,~l~~!!OOl'1\w'i! I!W'!~ _,.L~!L.""IP,,~J~_,~ ,"'".. ~ ...... " . _ <iA'i1\'W'",~"''''~-m;;-"'<m~'''''' """j""'_"'j"-":",""l~"!i<ij:;j~!i'~_~"i~0:i'\'~"'~'i>y,~n;w~ ~!h, \ " ~_ "- ", _ L' ".)_ - -.~ -. ""i_'1 MAR 2 2 2001 tP , LISA L. RUSSELL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-570 vs. CORY M. RANDALL, Defendant CIVIL ACTION - LAW CUSTODY 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. Legal Custody. The Mother, Lisa L. Russell, shall have primary legal custody of the minor Child, Skylar Olivia Russell, born August 30, 1998. Each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Mother shall have primary physical custody. Father shall have visitation according to the following plan: A. The afternoon of March 8, 2001, Father shall have visitation with the minor Child at a location to be agreed upon within the Camp Hill Shopping Mall. Mother shall be present for this visitation. B. Father shall contact Mother with regard to proposed visitation to be arranged by the parties as they may agree. Mother will not unreasonably deny periods of visitation for Father. Father shall provide Mother with a 30 day or more notice of anticipated visits. It is anticipated that the time for the next visitation shall occur within the next 90 days. 3. Within 30 days of the date of this Order Mother shall arrange for counseling regarding the introduction of the Father to the minor Child. During Father's visits to Pennsylvania, he may participate in the counseling. The goal shall be to gradually increase the periods of visitation to include periods of partial custody for Father. 4. It shall be permissible for Father to contact the Mother once a week for the purpose of talking with her regarding the health and well-being of the minor Child. .k r.~N. \ " J .'J ;,'0 '. :fI;f: . . No. 01-570 5. Father shall not remove the Child from the Commonwealth of Pennsylvania unless permitted to do so pursuant to Order of Court. Dis!: James W. Abraham, Esquire, 513 N, Second Street, Harrisburg, PA 17101 Elizabeth B. Stone, Esquire, 414 Bridge Street, New Cumberland, PA 17070 J. !~~ 03 -02 7-0 J R){s , . , I I I , , r~~ I ,,'~"'~ """"''''''!~ ,~.""'" 4- " , ~,"~~'....."" ~ I"" -' " ",.~~." .~~-. -, -.~ . ,~'.""~ '"," C'<c" ('"'' ),~ O.r~~I-.'jC.: ':-"""'I1'y ',,,,' 'i',Ji;\h "I U !:"J02" itj,\ .J CGI'K"', ilI'lX"';,,'! '1_':' ... ;::..: I...ri '~L; .' '('I u PtiVNS\'L\iAN~'-i!\jTY /"> 'J r-{j"f ff: L~ " "~ c, '"n-', ~"S-,:j , ~.. , ~,:lfl'~"Mt!lm'~!Hf'!~:Na'l1~T'1llJt'~~~~~f"'J'Ii\!'l';;"f~~j ~,~. " .J I. , ' '.." J '.' . - > . ~':::.!,; .\ ,l LISA L RUSSELL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-570 vs. CORY M. RANDALL, Defendant CIVIL ACTION - LAW CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Skylar Olivia Russell August 30,1998 Mother 2. A Custody Conciliation Summary Conference was held on March 7, 2001, with the following individuals in attendance: the Mother, Lisa L. Russell, and her counsel, James W. Abraham, Esquire; the Father, Cory M. Randall, and his counsel, Elizabeth Stone, Esquire. ,. The p,rt;.. ...,hed '" ",eemem ;, 'heQ' 0"'"" etteohed Date4/o/ ~~~uire Custody Conciliator I,,,'" . ,~~.- j ,:'" ,'," "","~"", ,-, ,-: ~.> ' " " " -. -,,," _-"-",:,-,\k" ^",-~" ,,~,:;,:~-_, . -(-~', ':" \; Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V AN1A i , I i I ... SHAWN SWINTOSKY, v. NO. 01-570 WEIS MARKETS, INC., CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant certifies that: 1. Plaintiff does not object to the subpoena and waives the Notice of Intent to Service a Subpoena to Produce Documents and Things for Discovery Pursuant to Rille 4009.21; 2. A copy of a letter dated April 3, 2003, and executed by Plaintiffs counsel, Leah B. Graff, indicating no objections and waiver of the notice of intent is attached to this Certificate; 3. A copy ofthe proposed subpoena is attached to this certificate; and 4. The subpoena which will be served is identical to the subpoena which is attached to this certificate. THOMAS, THOMAS & HAFER, LLP Date: 'l)z/~ k:ZG'mV)~ Kevin C. McNamara, Esquire Identification Number: 72668 Thomas, Thomas & Hafer, LLP Post Office Box 999 Harrisburg, P A 17108-0999 Telephone: (717) 237-7132 ~..k.....~ _'............." ~ . . -~.~ -. - ,,'~'" ....Ii'i~h 04/0312003 15: 05 7178457431 APR-12I3 1213 14:19 FROM:THOMAS THOMAS DALE E ANSTINE PC 717237711215 TO: 7178457431 PAGE 02/02 PAGE: 1212 ~ THOMAS, THOMAS & HAFER LLP ^TT01:N~\"S AT LAW ~~""~:] . .. .'.' I I' .. . '. ", .. ;,_.1.' www.tl:hlaw,'~;;n 305 North Fro"l Street. P.O. Box 999, Harrisburg, PA 17108 Phone: (71'7) 237-7100 Fa., (717) 237-7105 Peggy M Dugas, Paralegal (717)237-7100 pmd@rthlaw.cOfn April 3,2003 Leah B. Graff, Esquire LAW QFFICES OF DALE E. ANSTINE, P.c. P.O. Box 952 York,PA 17405 ilE: Swintoal<y Y. Wels Mark"t!I, Inc. Our File: 1 00-11391 Dear Ms. Graff We inlen4 to gervea subpoena on Sylvania Lighting for the purpose of obtaining a copy ofMr, Swintosky's worker's compensation fi.le. Specifically. we will request transcripts, lien infomlation, anti nledica[ records. If you have no objeqion to the subpoenaing ofthese records 8T1d are willing to waive the notice of intent, please sign were indicated and. return this correspondence to us via . facsimile. If you have any questions, please do not h.esitate to contact me. Thank you for your assistance in this matter. With best wishes, I am I, Leah B. Graff. oounael for . Plaintiff have no objection to the serving of subpoena as oUtlined above.. and waive the no.tice;t2 ~h~. ~ Leah B. Graff, Esquire / / Dated: t.j:3 0 ') 179342.9 --...--' Leh.igh Valley Offlce: 3400 Bath Pike. Suite 201. lIethl.he"" PA "1B017 . Phone, (61.0) 868-1675' Fax: (610) 868-1702 j i. ~~, - -, ...' ".'.. -.J._',~ .... SHAWN SWINTOSKY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.01-&& S'1J6 v. CIVIL ACTION - LAW WEIS MARKETS, INC., JURY TRIAL DEMANDED Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Sylvania Lighting c/o Paul Dellasega, Esquire (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete COpy of the worker's compensation file of Shawn Swintosky. includinG transcripts. lien information and medical records at: Thomas. Thomas & Hafer. LLP.;,305 N. Front St.. P.O. Box 999. Harrisbura. PA 17108- 0999 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance. to the party making this request at the address listed above. You have the right to seek in advance. the reasonable cost of preparing the copies or producing the things soughl. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to compiy with il. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Kevin C. McNamara, Esquire . ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7132 SUPREME COURT ID#: 72688 ATTORNEY FOR: Defendant BY THE COURT: DATE:-IktL\L J...f~ ,';2o~ e I of the Cou Prothonotary/Clerk, Civil ion '----- An--. () ,P .7'l?("I'",y, f Deputy ,-" ,>, ,-..! . " -~ , ," " :,..i...,',..-,,-, '0).''''_, ., ,-.;;~ CERTIFICATE OF SERVICE I, Peggy M. Morcom, Paralegal, hereby state that a true and correct copy of the foregoing document was served upon all counsel of record by fIrst class United States mail, postage prepaid, addressed as follows, on the date set forth below: Leah B. Graff, Esquire Law Offices of Dale E. Anstine, P.C. P.O. Box 952 York, PA 17405 THOMAS, THOMAS & HAFER, LLP Date: if fr'#/tJ 3 ~:\L,ED--OfF1CE 0- ...., [, ,...,-,1"\--;,., <''''', l........"... 1"'Iy \.~ 11- ,.-- ;--' ~,! !' ,-~, I',,, t i rl,h I "" - ".."",-.,-",,,,,. 03APR24 ',1'\11: I! CUMbLhUXL: CUUI;Ji! P5\ji'lSYLVANIA ~~