Loading...
HomeMy WebLinkAbout01-0984 FX "',,,"~ ~ - ,-d,__ _ ~. J"_' 1 -'1_ " , ~' -. ,,"'''^^'' c~,;-.;- . . FEa 2 2 ZOOl {/J TERRY L. RICHARDSON, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001. Wf ca;J CIVIL ACTION. LAW COURTNEY JOANN RICHARDSON, and JIMMY JAMES THOMAS McDONALD Defendants CUSTODY AND NOW, this day of , 2001, 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 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 at the request of either attorney or party, be present at the conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT, By: Custody Conciliator 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 THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OIR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Mechanicsburg, PA 17050 (717) 249-3166 'J_."_ " ' , ~I -j, I ,- u ~ FrO 1 . lO~ , , ' PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 5010 E. Trindle Road Mechanicsburg, PA 1705b (717) 591-1755 Attorney for Plaintiff TERRY L. RICHARDSON, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 - q l.Y c."" \ COURTNEY JOANN RICHARDSON, and JIMMY JAMES THOMAS McDONALD Defendants CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this day of February, 2001, upon consideration of the attached Petition for Special Relief Seeking Custody of the Minor Children, Petitioner's requested relief is hereby GRANTED. Petitioner is awarded temporary physical custody of the minor children, Trysten McDonald and TYSON STUMP until further Order of Court. Neither party shall remove the child from this Court's Jurisdiction until further Order of this Court. BY THE COURT, ,Judge -~,.., - '~-"~ , >,... - ~ .", .-,~-~ j;!~' TERRY L. RICHARDSON, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 . CIVIL ACTION - LAW COURTNEY JOANN RICHARDSON, and JIMMY JAMES THOMAS McDONALD Defendants CUSTODY AND NOW, this day of , 2001, 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 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 at the request of either attorney or party, be present at the conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT, By: Custody Conciliator 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 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. Cumberland County Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Mechanicsburg, PA 17050 (717) 249-3166 --'. , HL-I ~. ' ''"''', ~-~ ljf"l ,- i ! . . t PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 5010 E. Trindle Road Mechanicsburg, PA 17050 (717) 591-1755 Attorney for Plaintiff TERRY L. RICHARDSON, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 - q84 CIVIL ACTION - LAW COURTNEY JOANN RICHARDSON, and JIMMY JAMES THOMAS McDONALD Defendants CUSTODY COMPLAINT FOR CUSTODY AND NOW, COMES, the Plaintiff, TERRY L. RICHARDSON, by and through her attorney, Peter J. Russo, Esquire, and respectfully submits the following in support of Plaintitrs Complaint for Custody: 1. The Plaintiff is TERRY L. RICHARDSON, residing at 9 William Penn Drive, Camp Hill, Pennsylvania 17011. 2. The Defendant's are COURTNEY JOANN RICHARDSON residing at Cumberland County Prison and JIMMY JAMES THOMAS MCDONALD, whose last known residence is 424 Herr Street, Harrisburg Pennsylvania. 3. Plaintiff seeks custody of the following children: Name Present Residence TRYSTEN MCDONALD 9 WilLIAM PENN DR. CAMP Hill, PA 17011 TYSON STUMP 9 WilLIAM PENN DR. CAMP Hill, PA 17011 DOB MAY 6,1999 9 months old 0' ~ . ,_-'_ i j -,- , - ",__~', II I,,;" , , ~ ,,;-,,~.~;, . , 4. TRYSTEN MCDONALD and TYSON STUMP were born out of wedlock. 5. TYSON STUMP is presently in the custody of Plaintiff, and residing with the Plaintiff at 9 William Penn Drive, Camp Hill, Pennsylvania 17011. 6. TRYSTEN MCDONALD is presently in the custody of Defendant McDonald, whose last known residence is 424 Herr Street, Harrisburg Pennsylvania. 7. During the past five years, the children have resided with the following persons and at the following addresses: Persons Plaintiff, child's mother, & child's 2 siblings Child's mother, child's sibling, & friends, Ron Stump & Tammy Stump Plaintiff, child's mother & sibling, & child's aunt, Lindsay Child's mother & Ron Stump Plaintiff, child's mother & brothers, Ron Stump & child's aunt, Lindsay Address 9 William Penn Drive Camp Hill, PA 17011 Disbrow Street Harrisburg, PA Duration July 2000 to present May 2000-July 2000 9 William Penn Drive Camp Hill, PA 17011 1215 Derry Street 9 William Penn Drive Camp Hill, PA 17011 November '99-May 2000 Sept. '99 - November '99 May '99 - September '99 7. The mother of the children is Defendant, currently residing at Cumberland County Prison, Carlisle, Pennsylvania 17013. The mother is single. 8. The father of the children is Defendant, whose last known residence is 424 Herr Street, Harrisburg Pennsylvania. The father is single. 9. The relationship of plaintiff to the children is that of maternal grandmother. The plaintiff currently resides with the following persons: . " .. ~, , -' , .,"-"" -~"- ," ", "~~"', ';' ' - . Name Tyler Stump TYSON STUMP Relationship Grandson - brother to Trysten Grandson - brother to Trysten - Child of Both Defendants 10. The relationship of Defendant Richardson, to the children is that of mother. The Defendant currently resides with the following persons: Name Unknown Relationship 11. The relationship of Defendant McDonald, to the children is that of father. The Defendant currently resides with the following persons: Name Relationship Varies depending on location of residence 12. 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. The court, term and number, and its relationship to this action is: 13. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. The court, term and number, and its relationship to this action is: 14. 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 right with respect to the children. The name and address of such person is: 15. The best interest and permanent welfare of the children will be served by granting the relief requested because the Plaintiff has been the primary caretaker of this minor children when the natural mother was not available. The natural father has had limited ,--" ' ',- __~ ,J-'J..'I "-'-' ' ,,- -,-,- ., " <'-" ",~, ;,; ~ . . involvement with the minor children and is without the means to adequately support his children. 16. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim NONE WHEREFORE, Plaintiff requests this Honorable Court to order that primary physical and legal custody of the minor children, Trysten McDonald and TYSON STUMP be placed with Plaintiff. Respectfully submitted, @tC::jl. Peter J. Russo Attorney for Plaintiff - Date: ~/c;lOlo, - , . PETER J. RUSSO, ESQUIRE PA Supreme Court 10: 72897 5010 E. Trindle Road Mechanicsburg, PA 17050 (717) 591-1755 TERRY L. RICHARDSON, Plaintiff v. COURTNEY JOANN RICHARDSON, and JIMMY JAMES THOMAS McDONALD Defendants ,-. _J'l' '~ Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 - CIVIL ACTION - LAW CUSTODY VER~FICATION I, TERRY L. RICHARDSON, verify that the statements made in the foregoing document are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. 34904 relating to unsworn falsification to authorities. " ~&~ ~ \YAi[ . d.A. TERRY 1. ARDSO Date: J - UrO\ ,.'ciw~l~:M'''''WJt!ili!lilll~,~l;,)j;;Ji!!1.:;;ii!;;;;;iHHllriil~~>>ji;;4&<'''."k,''",~,';-';^-;''A~"~.'-i";-:""";;",,"'~im::l,;<;iill:~11~%~~.t:<,-,,,m';i_..J,i~,,,--JIli!l~~~liil\IIIiJl M< &1_ ~ ~ 'J ~ t; . .~ ~-~ . . o ~;: ~I~~ ...<, (- ;~'> l~ -.-1 -( -" ;-<1"1 :::t)' r-,'eJ C:) .'"':) r;;.1 OJ C) ') :--{ '" ~O -< ~ t1 .'.1 j-' ~ ,"'., "~ . TERRY RICHARDSON PLAINTIFF V. COURTNEY JOANN RICHARDSON, AND JIMMY JAMES THOMAS MCDONALD DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 01-984 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, February 23, 2001 , upon consideration ofthe attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite105, Camp HiU, PA 17011 on Monday, March 26, 2001 at 11:00 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. FOR THE COURT, By: Isl Melissa P. Greevy. ES~ Custody Conciliato~ 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 TIDS PAPER TO YOUR ATTORNEY AT ONCE. IFYOUDONOT 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 m '~ ~ ''1; - ~~ "." .~ , ~~, "' " ,-""-,~,~ ~ , r i """,Ti\'Ti l,t Ii ') 'j ~Y',,: ')' ''}f'! _ ;' (.~. \ J i L' .~; ,": C'u",,,,,;,, ' ""., ,~ lV:[.. n:l-l:.....,'.'!',~, , I .' Ii JI'I i I( , -" '.~"" '- ~. Pc~jNSYUl\[\j!A ," ,-~. "'~ ,<.>- ,."",,. c:?-d/'~/ tla'- ~ ~ ?f; aJ-.,e~ d',;l'/.CI ?1~ ~;t ~ y ;;-d).(J( 0r /~!:Ji;~'4 ~,~ yLt llIIH __~~,~_~__~''''",,'1"<M~_''''''~~Il!'~~'!l''f'''''''''''' ""'~"":-"-~""':''''-''''_''-'''!'J:''''R''-~_~'Jl!l'm''''P'l''''!lI'r1"'-"w~;rr;%""""~"""I!I;;1i""'li'_!-"'-"'""""l1'lf!ii~ ~" ' ., ._,;; >-,<,,1,1 1- ~'.i"';jb 1 IN THE COURT OF COMMON PLEAS OF r'1lTTlhPrlrmn PENNSYLVANIA COUNTY, CIVIL DIVISION 2001-984 Civil File No, Terry L. Richardson vs. Courtney Joann Richardson and Jirrmy James Thomas McDonald WRIT OF HABEAS CORPUS TO: Warden Dauphin County Frision WE COMMAND YOU, that the body of Jirrmy James Thomas McDonald under your custody, as it is said detained, by whatsoever name the said Jimnv James Thomas McDonald may be detained, together with the day and cause of his being taken and detained, you have before the Honorable J. Wesley Oler, Jr Judge of our Court of Common Pleas of (1nnhPrl"nn County, at the Courthouse, in the City of Carlisle Pennsylvania, Hearinq on March 1, 2001 at 3:00 p.m. in Courtroom No.1 _ then and there to do and be subject to whatsoever our said Judges shall consider in that behalf; and have you then and there this writ WITNESS, the Honorable J. Wesley Oler, Jr. Court, at Carlisle this , Judge of our said 28th day of March AD.2001 Curtis R. Long 'vision by: ,~ Deputy ATTORNEY: Peter J. Russo Esa. 5010 East Trindle Road Mechanicsburg Pa 17055 ~" ~. ~ "" ~. , ,- '--,,," ." ,-",~, -"" ~~< ," ", , -" '-'''-~;,L , ' I , TERRY L. RICHARDSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW COURlNEY JOANN RICHARDSON, and JIMMY JAMES THOMAS McDONALD, : Defendants NO. 01-984 CIVIL TERM ORDER OF COURT AND NOW, this 21st day of February, 2001, upon consideration of Plaintiff's Petition for Special Relief Seeking Custody of Minor Children, a hearing is scheduled for Thursday, March I, 2001, at 3:00 p.m., in Courtroom No. I, Cumberland County Courthouse, Carlisle, Pennsylvania. PENDING THE ABOVE HEARING, neither party shall remove the mmor children from the Commonwealth of Pennsylvania, nor secrete the children's whereabouts from the other party. BY THE COURT, .~ f\ ~D'\ t/ &~~ Peter J. Russo, Esq. 5010 E. Trindle Road Mechanicsburg, P A 17050 Attorney for Plaintiff Courtney Joarm Richardson Cumberland County Prison Defendant, Pro Se , , '" ___'n_,~, < , , Jimmy James Thomas McDonald 424 Herr Street Harrisburg, P A 17101 Defendant, Pro Se :rc , , . - , -. .. . - " ,_ 0' , ,_, '-' ,_ ",,," ".~ '___ ~ : I , i v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 - q '6\...\- Lh\ \ , CIVIL ACTION - LAW , :1 , :'1 II TERRY L. RICHARDSON, Plaintiff ;'-j ! COURTNEY JOANN RICHARDSON, and JIMMY JAMES THOMAS McDONALD Defendants i I' , " i il :,1 'j 1 CUSTODY i.-i 'I i; 1.1 !1 I ,1 " I' ,I ii l'i I, I, j'l II II " I ,I I j" 1,1 i'j ~,i I,'! 1'1 I , PETITION FOR SPECIAL RELIEF SEEKING tUSTODYOF MINOR CHILDREN AND NOW, COMES, the Plaintiff, TERRY L. RICHARDSON, by and through his attorney, Peter J. Russo, Esquire, and respectfully submits the following in support of Plaintiff's Petition for Special Relief Seeking Custody: 1. The Plaintiff has filed a custody complaint which is attached hereto as Exhibit A. 2. Plaintiff seeks custody of the following children: Name Present Residence TRYSTEN MCDONALD 9 WilLIAM PENN DR. CAMP Hill, PA 17011 TYSON STUMP 9 WilLIAM PENN DR. CAMP Hill, PA 17011 DOB MAY 6,1999 9 months old 4. TRYSTEN MCDONALD and TYSON STUMP were born out of wedlock. 5. TYSON STUMP is presently in the custody of Plaintiff, and residing with the Plaintiff at 9 William Penn Drive, Camp Hill, Pennsylvania 17011. 6. TRYSTEN MCDONALD is presently in the custody of Defendant McDonald, whose last known residence is 424 Herr Street, Harrisburg Pennsylvania. 7. There is no existing Order of Court with respect to custody. 8. Plaintiff has no information of a custody proceeding concerning the child pending " '_" I .w, ~" J" . ''-Ifill.. in a court of this Commonwealth. 9. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 10. Plaintiff seeks an emergency custody order placing the subject minor children with the Plaintiff based on the foregoing: a) Plaintiff was asked by the natural mother to care for the subject minor child while in the natural mother is incarcerated. b) Natural mother has completed a notarized statement setting forth her desires which is attached hereto as Exhibit B. c) Once the natural mother was taken into custody, Defendant McDonald took Trysten out of daycare and separated Trysten from his brother Tyson. d) Defendant McDonald has never been an integral part of the lives of either children. e) Defendant McDonald is without a permanent residence and lives with friends and family. f) The temporary residences that Defendant McDonald utilizes are inappropriate for Trysten as it is believed that one residence, a 1 bedroom unit houses 3 children and two adults in addition to Trysten. The other residence is believed to be three bedrooms, housing five children and three adults, in addition to Trysten. g) Defendant McDonald has a criminal history that includes drug and weapon charges. It is believed therefore averred that Defendant McDonald may even - , ~ , ~ '. 'J,I--,I., , ;., ..L',j , -~. have active warrants for his arrest in Dauphin County. h) In the past, Defendant McDonald has been know to use drugs in the presence of Trysten. i) Since Defendant McDonald's abduction of Trysten, family members have seen Trysten in the company of unrelated adults noting the absence of Defendant McDonald. j) Both children have resided with the Plaintiff for the vast majority of their lives and have had limited contact with the natural father. 11. The aunt of the subject minor children has completed an affidavit detailing her experiences with Defendant McDonald which is attached hereto as Exhibit C. 12. The best interests of this child would further be seNed if Plaintiff were provided primary physical custody until Defendant Richardson is released from prison. 13. Counsel for Plaintiff has been advised that Defendant McDonald has not been represented by counsel in any other action. WHEREFORE, Defendant requests this Honorable Court to order that physical of the minor child be placed with Defendant and Plaintiff be enjoined from leaving this Court's jurisdiction pending further hearing on this matter. C:~~ Peter J. Russo Attorney for Plaintiff - Date:~ " . I,' ~ , , '-'l ,-~. 't PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 5010 E. Trindle Road Mechanicsburg, PA 17050 (717) 591-1755 Attorney for Plaintiff TERRY L. RICHARDSON, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 - CIVIL ACTION - LAW COURTNEY JOANN RICHARDSON, and JIMMY JAMES THOMAS McDONALD Defendants CUSTODY VERIFICATION I, TERRY L. RICHARDSON, verify that the statements made in the foregoing document are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. :. Date:d-/U-Ol ~ J " ,~. , 'oJ "~ "'_- PETER J. RUSSO, ESQUIRE PA Supreme Court 10: 72897 5010 E. Trindle Road Mechanicsburg, PA 17050 (717) 591-1755 Attorney for Plaintiff TERRY L. RICHARIDSON, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 - CIVIL ACTION - LAW COURTNEY JOANN RICHARDSON, and JIMMY JAMES THOMAS McDONALD Defendants CUSTODY COMPLAINT FOR CUSTODY AND NOW, COMES, the Plaintiff, TERRY L. RICHARDSON, by and through her attorney, Peter J. Russo, Esquire, and respectfully submits the following in support of Plaintiff's Complaint for Custody: 1. The Plaintiff is TERRY L. RICHARDSON, residing at 9 William Penn Drive, Camp Hill, Pennsylvania 17011. 2. The Defendant's are COURTNEY JOANN RICHARDSON residing at Cumberland County Prison and JIMMY JAMES THOMAS MCDONALD, whose last known residence is 424 Herr Street, Harrisburg Pennsylvania. 3. Plaintiff seeks custody of the following children: Name Present Residence TRYSTEN MCDONALD 9 WilLIAM PENN DR. CAMP Hill, PA 17011 TYSON STUMP 9 WilLIAM PENN DR. CAMP Hill, PA 17011 DOB MAY 6,1999 9 months old . . ." ".-, < , --" 'I j~ 4. TRYSTEN MCDONALD and TYSON STUMP were born out of wedlock, 5. TYSON STUMP is presently in the custody of Plaintiff, and residing with the Plaintiff at 9 William Penn Drive, Carnp Hill, Pennsylvania 17011, 6. TRYSTEN MCDONALD is presently in the custody of Defendant McDonald, whose last known residence is 424 Herr Street, Harrisburg Pennsylvania. 7. During the past five years, the children have resided with the following persons and at the following addresses: Persons Address Duration Plaintiff, child's mother, & 9 William Penn Drive July 2000 to present child's 2 siblings Camp Hill, PA 17011 Child's mother, child's sibling, Disbrow Street May 2000-July 2000 & friends, Ron Stump & Harrisburg, PA Tammy Stump Plaintiff, child's mother & 9 William Penn Drive November '99-May 2000 sibling, & child's aunt, Lindsay Camp Hill, PA 17011 Child's mother & Ron Stump 1215 Derry Street Sept. '99 - November '99 Plaintiff, child's mother & 9 William Penn Drive May '99 - September '99 brothers, Ron Stump Camp Hill, PA 17011 & child's aunt, Lindsay 7. The mother of the children is Defendant, currently residing at Cumberland County Prison, Carlisle, Pennsylvania 17013. The mother is single. 8. The father of the children is Defendant, whose last known residence is 424 Herr Street, Harrisburg Pennsylvania. The father is single. 9. The relationship of plaintiff to the children is that of maternal grandmother. The plaintiff currently resides with the following persons: . ".., '"",,' - ~~'-,,,' ^' '^; Name Tyler Stump TYSON STUMP Relationship Grandson - brother to Trysten Grandson - brother to Trysten - Child of Both Defendants 10. The relationship of Defendant Richardson, to the children is that of mother. The Defendant currently resides with the following persons: Name Unknown Relationship 11. The relationship of Defendant McDonald, to the children is that of father. The Defendant currently resides with the following persons: Name Relatoonship VarieS depending on location of residence 12. 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. The court, term and number, and its relationship to this action is: 13. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. The court, term and number, and its relationship to this action is: 14. 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 right with respect to the children. The name and address of such person is: 15. The best interest and permanent welfare of the children will be served by granting the relief requested because the Plaintiff has been the primary caretaker of this minor children when the natural mother was not available. The natural father has had limited '-" - ,~, " '..~ '-;;," " -~, " '-;"';.. involvement with the minor children and is without the means to adequately support his children. 16. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim NONE WHEREFORE, Plaintiff requests this Honorable Court to order that primary physical and legal custody of the minor children, Trysten McDonald and TYSON STUMP be placed with Plaintiff. Respectfully submitted, @tC~ ~ Peter J. Russo Attomey for Plaintiff - Date: _/~olo, " '-',"" , ,~ . "_~'-'--'"H " PETER J. RUSSO, !ESQUIRE PA Supreme Court 10: 72897 5010 E. Trindle Road Mechanicsburg, PA 17050 (717) 591-1755 Attorney for Plaintiff TERRY L. RICHARDSON, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 - CIVIL ACTION - LAW COURTNEY JOANN RICHARDSON, and JIMMY JAMES THOMAS McDONALD Defendants CUSTODY VERIFICATION I, TERRY L. RICHARDSON, verify that the statements made in the foregoing document are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities, D,te) I~Oi llli lidcMhYJ- TERRYL. C AROSON - "' ~ ' I I _......L. .~__ i I II ~ ,-, ",'," " , "" ~'" ~, vi} 'tm ~ WV7A.i.JUL , ~ (!mu~ilwa 8 oflJlfL fPil f7tVdMYU I/O ' , " " . IJPJY1Ij- I~ 0--/ YL BfMYn:::~;:tm<f" Off- iP, r I f1{f :2/.mu ll/LA J1 fm~ rUle /> - ~J ttnd.. . r ) - () .'-1 ~nY/Jm:f Yl.A---' . '7~ · --.!l.. W IU..J.LUffL P LYY~Y/YJlUJ1.J1.P JL P () I 7 () Lf ' -0111,) !J;u 1 H (l L!LIYY1 F'u , ../)--1 YlA~__t )-Jru.uu I:i1. .".=-- ~)Jf -f-!' fYi'1PIA" Jd flLV JJ (J J(I1.!.Jtf · J)1LYrn.4L i L 'Vl1J f},oJJ.J<c!,on-/;/liru f.!/Ia.. · ~ ._L'" M/I' C4 1211 ' . w.J1o.A t) Mf'Y'-.-,,~ . Af r:n JlV7 M.. :, ~ ~fI~L0j Tho Y\..J( U(Jlj M/I ' () r;r-- I 7f Ji lj\ JtJl J.J1 rL IIt/! (10 Notarial Seal , Public Middlesex Twp.. Cumberland County My Commission Expires June 24. 2002 Member, pennsy vama ~~~ dJ-IL/- 01 .- . ~.;-~, f.:~H ie' . .... . - J' ..~)..., '. ,t "~,/( IJ, I \, r',," il;:...~ , ~,,) 1 I ,,~ ~.l' '.~...;.;~~'!}" ~' ,- III ~~ ~.~.. ~. "1-1 ,-~ '~ir r_ AFFIDAVIT OF LINDSAY RICHARDSON I, Lindsay Richardson being duly sworn according to law, state under oath: 1. I am the maternal aunt of Trysten McDonald and Tyson McDonald. 2. The children have always been cared for by either my mother, Terry Richardson or my sister, Courtney Richardson. 3. Mr. McDonald has had limited contact with his children until now. 4. I have been witnessed behavior of Mr. McDonald which raises concerns for me when I consider he is caring for my nephew. 5. I have witnessed the following: a) When my sister was shopping one day she left Trysten with Jimmy, and when I came home from work, I came home to a house filled with smoke. My six year old nephew, Tyler, said to me that Jimmy was smoking a cigar. I knew then that Jimmy was smoking weed in the house while watching my nephews. b)Jimmy was watching Trysten when he was a baby while my sister and I went to the store really quick. When we came back we saw Jimmy's one friend holding a beer bottle to Trysten's mouth and Jimmy and his friend were both laughing about it. My sister and I both yelled at him. c)When Jimmy said he would watch the kids. My sister and I would go to pick them up and Jimmy was never around. One time when we went go to pick Trysten up he was in a house filled with smoke from weed, and he would was crying. Then when we took him home he was always really hungry. Even though we would buy food for all of the kids that live in the house where Jimmy lived before we dropped him off. So we think one of the other kids must of ate his food. Cause we were only gone for two and half hours. So my sister stopped asking Jimmy to watch the kids. 6. I believe the children will be best served if they were permitted to , continue to reside with Terry Richardson. a1/1chay IJclUAAdo~ Lindsay Richardson - Sworn to and Subscribed before me this 20th day of February, 2001 Notarial Seal Suzette R. SiMs, Notary Public Ca. mp HW Botn, CUf[-:J-8:iGnj County COmmtBl3i~m Ex -'ire:; Feb. '16, 2004 ~/J ~ Menmer, PenA8ylvaniaAs8ocialionotNOtsrtes P b ic ,/ '-!, ',-, ,,-, ~< ~, ~WlllP~j~~mm!il!iil:!lliil~~""l1!.""",:-j,,,,,,-,,::,~,,"',i""""""';h;'"~__"I",,~~lilI!illl<~-~-'~--'-~ 'it ~- h ""ill..",,,,,,,", ,", .,'., ''''f=''''_~~ ~ ~ _, ._,_,,~,_ ._.'h" .<, ,""X-"i_" .--~.< _ .""'h ,~_~.>, ,-,",;.._~>.", "'." _ e, '_'~~ .., ",.~ ill"!! . ~-~ .~ ~'. ~= c::~ J,.i " ~~~ z :< c.'. -C)" .:..-.;,. -~, ~ ....., m:'1 "" ':"'1 :'.~;;l ; C..) o ~"(i \~) --='_;,-J ,1"1 :::=1 S~ -< .:.,) ,~ ~~ , II.'" ,,: , TERRY L. RICHARDSON, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 - 984 CIVIL ACTION - LAW CUSTODY J. WESLEY OLER, JUDGE COURTNEY JOANN RICHARDSON, and JIMMY JAMES THOMAS McDONALD Defendants ORDER OF COURT AND NOW, this 7_1) t~ day of February, 2001, upon consideration of the attached Petition for Special Relief Seeking Custody of the Minor Children, Petitioner's requested relief is hereby GRANTED. Petitioner is awarded temporary physical custody of the minor children, Trysten McDonald and Tyson McDonald until further Order of Court. ,:::=~ :::~~~~e "~:;;:r::'::': -~::::,:":: All other provisions of this Court's Order dated February 21, 2001 shall remain in full force and effect. ~e..; . Peter J. Russo, Esquire' 'pe{jQf\"'\\Y j' V~[) Counsel for Plaintiff Courtney Joann Richardson Cumberland County Prison Defendant, Pro Se Jimmy James Thomas McDonald Dauphin County Prison Defendant, Pro Se . n < ()100.tld Co(cv TERRY L. RICHARDSON, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 - 984 CIVIL ACTION - LAW CUSTODY J. WESLEY OLER, JUDGE COURTNEY JOANN RICHARDSON, and JIMMY JAMES THOMAS McDONALD Defendants PETITION FOR, SPECIAL RELIEF SEEKING CUSTOD'1~' OF MINOR CHILDREN AND NOW, COMES, the Plaintiff, TERRY L. RICHARDSON, by and through her attorney, Peter J. Russo, Esquire, and respectfully submits the following in support of Plaintiffs Petition for Special Relief Seeking Custody: 1. The Plaintiff has filed a custody complaint which has been docketed at the above listed number. 2. The Plaintiff has also filed a prior Petition for Special Relief seeking custody of the subject minor children which has also been docketed at the above listed number. 3. A hearing on the Petition for Special Relief seeking custody of the subject minor is to be held before the Honorable J. Wesley Oler, Jr. on Thursday, March 1,2001 at 10:00 a.m. 4. Plaintiff seeks custody of the following children: Name Present Residence TRYSTEN MCDONALD Unknown. DOB MAY 6, 1999 TYSON MCDONALD 9 WilLIAM PENN DR. CAMP Hill, PA 17011 9 months old .' ~ i IJ ,~, . 4. The natural mother of the subject minor children, COURTNEY JOANN RICHARDSON, is presently incarcerated in Cumberland County Prison for a parole violation. 5. Upon the natural mother's arrest, the natural Father, JIMMY JAMES THOMAS MCDONAL.,D, removed Trysten McDonald from the home of his daycare provider and separated him from his brother. 6. Trysten's brother continues to reside with the Plaintiff. 7. Plaintiff's alleged in the prior Petition that Plaintiff was seeking an emergency custody order placing the subject minor children with the Plaintiff based on the foregoing: a) Plaintiff was asked by the natural mother to care for the subject minor child while in the natural mother is incarcerated. b) Natural mother has completed a notarized statement setting forth her desire to place the children with the plaintiff. c) Once the natural mother was taken into custody, Defendant McDonald took Trysten out of daycare and separated Trysten from his brother Tyson. d) Defendant McDonald has never been an integral part of the lives of either children. e) Defendant McDonald is without a permanent residence and lives with friends and family. f) The temporary residences that Defendant McDonald utilizes are inappropriate for Trysten as it is believed that one residence, a 1 bedroom unit houses 3 children and two adults in addition to Trysten. The other resident is believed to be a three bedroom residence housing five children, three adults in addition to Trysten. g) Defendant McDonald has a criminal' history that includes drug and weapon charges. It is believed therefore averred that Defendant McDonald may even ..' , " M"II , * f have active warrants for his arrest in Dauphin County. h) In the past, Defendant McDonald has been know to use drugs in the presence of Trysten. i) Since Defendant McDonald's abduction of Trysten, family members have seen Trysten in the company of unrelated adults noting the absence of Defendant McDonald. j) Both children have resided with the Plaintiff for the vast majority of their lives and have had limited contact with the natural father. 11. Today JIMMY JAMES THOMAS MCDONALD was arrested for criminal trespass and false reporting to police and is presently in the custody of the Dauphin County Prison. 12. Counsel for the Plaintiff has confirmed JIMMY JAMES THOMAS MCDONALD's incarceration in Dauphin County. 13. While Plaintiff is currently unaware of the physical well-being of the child and the actual location of Trysten McDonald, Plaintiff believes the child may be with one of the paternal family members and believes she can gain custody of Trysten with a Court Order. 14. The best interests of this child would be served if Plaintiff were provided physical custody until the March 1, 2001 hearing. 15. The best interests of this child would further be served if Plaintiff were provided primary physical custody until Defendant Richardson is released from prison. WHEREFORE, Defendant requests this Honorable Court to order that physical of the minor child be placed with Plaintiff until further hearing on this matter. Date:~ ~~~ Peter J. Russo Attorney for Plaintiff ,'_ ~'cJ""ld~. . ,- , . .iiliiilf~\,: . PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 5010 E. Trindle Road Mechanicsburg, PA 17050 (717) 591-1755 Attorney for Plaintiff TERRY L. RICHARDSON, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 - 984 CIVIL ACTION - LAW CUSTODY J. WESLEY OLER, JUDGE COURTNEY JOANN RICHARDSON, and JIMMY JAMES THOMAS McDONALD Defendants VERIFICATION I, Peter J. Russo, counsel for Terry L. Richardson, being familiar with the fact and circumstances of this matter verify that the statements made in the foregoing document are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: 'do] ;;r1 J 0 \ ~~c~ Peter J. Russo 0l~tI1~~,\"";;~,iilib'Dl!ltt&.if,";~'@,I,Qllik;it.i;'!l1~ii!il)l#v",M-,-<f!!'''-,@i'''''';'';;!H_r"~{~,~rd,,,-''';_L.,,,--,i;)''',wi~~~'"~~~~~,,"M.,,,,J:..I&- I!OOP ~\li'~'~mlllillllt_'-= ~ ~\\ . r -.\) C:> ...... m,_. ."O,'"rr. """,o_.."""'~',"~'n,~~,"., y ~ ,-,~". ,~ -~",,' .', ~ ~~ ", ", --"~" E- ,,- ,~ ~__" l ,.""'- ~- <>-~ ~--~ " (') ~ _ _~_. . ~~ > "M --!. f f - 1It,i;~ f C:J: -n i-'r; c:J r0 .-1 !", ," <c? r:- __-n 1--::' ,.....' ;::jCn " j ',-" ::0 -< ...1 ~ ~ ~ if - ,',' - _.- , TERRY L. RICHARDSON, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 - 984 CIVIL ACTION - LAW CUSTODY J. WESLEY OLER, JUDGE COURTNEY JOANN RICHARDSON, and JIMMY JAMES THOMAS McDONALD Defendants ORDER OF COURT AND NOW, this day of February, 2001, upon consideration of the attached Petition for Special Relief Seeking Custody of the Minor Children, Petitioner's requested relief is hereby GRANTED. Petitioner is awarded temporary physical custody of the minor children, Trysten McDonald and Tyson McDonald until further Order of Court. Petitioner shall be entitled to utilize the services of the local police or sheriff's department in order to obtain and retain custody of the subject minor children until further Order of Court All other provisions of this Court's Order dated February 21, 2001 shall remain in full force and effect. BY THE COURT, J. Wesley Oler, Jr., Judge Peter J. Russo, Esquire Counsel for Plaintiff Courtney Joann Richardson Cumberland County Prison Defendant, Pro Se Jimmy James Thomas McDonald Dauphin County Prison Defendant, Pro Se - .. .1 -'," 0"" ~- (~,\<. f TERRY L. RICHARDSON, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 - 984 CIVIL ACTION - LAW COURTNEY JOANN RICHARDSON, and JIMMY JAMES THOMAS McDONALD Defendants o C.J c,':! CUSTODY ~:~ "'"'1-" J. WESLEY OLER, JUDGEiliH ;J L -" tv ~~~'," 2f:...:: -.::\ ..- ~'-" -' ~;~ ~1 ~ -7 ~ ~~ ,~< OJ --- AND NOW, COMES, the Plaintiff, TERRY L. RICHARDSON, by and through her PETITION FOR SPECIAL RELIEF SEEKING CUSTODY OF MINOR CHILDREN attorney, Peter J. Russo, Esquire, and respectfully submits the following in support of Plaintiff's Petition for Special Relief Seeking Custody: 1. The Plaintiff has filed a custody complaint which has been docketed at the above listed number. 2. The Plaintiff has also filed a prior Petition for Special Relief seeking custody of the subject minor children which has also been docketed at the above listed number. 3. A hearing on the Petition for Special Relief seeking custody of the subject minor is to be held before the Honorable J. Wesley Oler, Jr. on Thursday, March 1, 2001 at 10:00 a.m. 4. Plaintiff seeks custody of the following children: Name Present Residence TRYSTEN MCDONALD Unknown. DOB MAY 6, 1999 TYSON MCDONALD 9 WILLIAM PENN DR. CAMP HILL, PA 17011 9 months old tJ., ^ ,-">-" ~ ~,. .<-.....,,~; . 4. The natural mother of the subject minor children, COURTNEY JOANN RICHARDSON, is presently incarcerated in Cumberland County Prison for a parole violation. 5. Upon the natural mother's arrest, the natural Father, JIMMY JAMES THOMAS MCDONALD, removed Trysten McDonald from the home of his daycare provider and separated him from his brother. 6. Trysten's brother continues to reside with the Plaintiff. 7. Plaintiffs alleged in the prior Petition that Plaintiff was seeking an emergency custody order placing the subject minor children with the Plaintiff based on the foregoing: a) Plaintiff was asked by the natural mother to care for the subject minor child while in the natural mother is incarcerated. b) Natural mother has completed a notarized statement setting forth her desire to place the children with the plaintiff. c) Once the natural mother was taken into custody, Defendant McDonald took Trysten out of daycare and separated Trysten from his brother Tyson. d) Defendant McDonald has never been an integral part of the lives of either children. e) Defendant McDonald is without a permanent residence and lives with friends and family. f) The temporary residences that Defendant McDonald utilizes are inappropriate for Trysten as it is believed that one residence, a 1 bedroom unit houses 3 children and two adults in addition to Trysten. The other resident is believed to be a three bedroom residence housing five children, three adults in addition to Trysten. g) Defendant McDonald has a criminal history that includes drug and weapon charges. It is believed therefore averred that Defendant McDonald may even - ~-. ~-" .' _l~ ." ' -" _, " _ ;"-'_ll i" ';1-' have active warrants for his arrest in Dauphin County. h) In the past, Defendant McDonald has been know to use drugs in the presence of Trysten. i) Since Defendant McDonald's abduction of Trysten, family members have seen Trysten in the company of unrelated adults noting the absence of Defendant McDonald. j) Both children have resided with the Plaintiff for the vast majority of their lives and have had limited contact with the natural father. 11. Today JIMMY JAMES THOMAS MCDONALD was arrested for criminal trespass and false reporting to police and is presently in the custody of the Dauphin County Prison. 12. Counsel for the Plaintiff has confirmed JIMMY JAMES THOMAS MCDONALD's incarceration in Dauphin County. 13. While Plaintiff is currently unaware of the physical well-being of the child and the actual location of Trysten McDonald, Plaintiff believes the child may be with one of the paternal family members and believes she can gain custody of Trysten with a Court Order. 14. The best interests of this child would be served if Plaintiff were provided physical custody until the March 1, 2001 hearing. 15. The best interests of this child would further be served if Plaintiff were provided primary physical custody until Defendant Richardson is released from prison. WHEREFORE, Defendant requests this Honorable Court to order that physical of the minor child be placed with Plaintiff until further hearing on this matter. ftespeCtfuIIY.submitte~ ~ -,\;-~ ~ Peter J. Russo Attorney for Plaintiff Date:~ , I - t', '" - ,_h',I'" 'i, _'n'" ~<; PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 5010 E. Trindle Road Mechanicsburg, PA 17050 (717) 591-1755 Attorney for Plaintiff TERRY L. RICHARDSON, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 - 984 CIVIL ACTION - LAW CUSTODY J. WESLEY OLER, JUDGE COURTNEY JOANN RICHARDSON, and JIMMY JAMES THOMAS McDONALD Defendants VERIFICATION I, Peter J. Russo, counsel for Terry L. Richardson, being familiar with the fact and circumstances of this matter verify that the statements made in the foregoing document are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. 34904 relating to unsworn falsification to authorities. Date: 'd.1;;11} 0 \ C~~~~~ Peter J. Russo , <~- ~ - ~"""I" -'--" ,~ -"y .~< - --' , --,< "'-<"": , TERRY L. RICHARDSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW COURTNEY JOANN RICHARDSON, and TIMMY JAMES THOMAS McDONALD, : Defendants NO. 01-984 CIVIL TERM ORDER OF COURT AND NOW, this 2nd day of March, 2001, upon consideration of Plaintiffs Petition for Special Relief Seeking Custody of Minor Children, with respect to the children of Defendant Courtney Joann Richardson and Defendant Jimmy James Thomas McDonald (Trysten McDonald and Tyson Stump), and following a hearing held on March 1, 200 I, it is ordered and directed as following pending a custody conciliation conference and further order of court: 1. The parties shall share legal custody of the children. 2. Primary physical custody of the children shall be in the Plaintiff, Terry L. Richardson, the children's maternal grandmother. 3. Defendant Jimmy James Thomas McDonald shall have rights of visitation with the children in Plaintiffs home each Saturday, from 1:00 p.m. until 6:00 p.m. 4. Defendant Courtney Joann Richardson shall have rights of temporary or partial custody at such times as she and Plaintiff mutually agree. BY THE COURT, ;> {\ ~<< ~.~~~.!IOO~~_I';~H"k"gr,n<h.;j,"d~ilr.MiJ!l\':Ol,;IA;;';"'b'Ili~~~l!ilIllilllbillf~m.!ll<"" jlj.!lllll~ '-"'""~-l~ I \/F'I~//"l tn" I ..... ,...11';1"\".,......,1,,',,:\)\,,..\1..1,..) ',"-- ~',' ,': ",I 'J._'-,.u~.:~:?>Vn.'J h.~) .',:',',,' v i ir.; ~ '::>- , ~-,v:, _ "~'",~, ~ ~., .,. ""__''''~~~'''"_" ,~~ . ' . "'-'. -.~,"'",.'"'--" - ~,. ~ -"'" ". ",l ~ n . ~/ - .. - '.' , " il II I !) { , ,,' , _'h " ,~ , ~> ~ Peter J. Russo, Esq. 5010 E. Trindle Road Mechanicsburg, P A 17050 Attorney for Plaintiff Courtney Joann Richardson Cumberland County Prison Defendant, Pro Se Jimmy James Thomas McDonald 423 Cumberland Courts Harrisburg, P A 17102 Defendant, Pro Se :rc ;';,~ 'n _, ...;U;,.~ ';'''ji~''--'"i.<, , "-, L._L".k-.I., ~_ ,_ o ~ 0' _'_ ~ '. -,; -', ,.,>' '~ TERRY RICHARDSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LA W v. COURTNEY JOANN RICHARDSON, AND JIMMY JAMES THOMAS MCDONALD, Defendants NO. 01-984 CIVIL : IN CUSTODY ORDER OF COURT AND NOW, this 1st day of March, 2001, upon consideration of the Plaintiff's motion for special relief seeking custody of minor children, and following a hearing, the record is declared closed, and the matter is taken under advisement. BY THE COURT, Peter J. Russo, Esquire For the Plaintiff Courtney Joann Richardson, Defendant Pro Se Cumberland County Prison 1101 Claremont Road Carlise, PA 17013 \ .0(0 t)'J ~ ~ Jimmy James Thomas McDonald, Defendant Pro Se 423 Cumberland Courts Harrisburg, PA 17102 tit pbc i1I.~It.~'II~~iIWl~lifIfJlO~~'ti!!ilU",",,:i\';A'i,,~~,i1f!J'c";;'"'ki"ir,"';;J!'1i;i~iUi!~~lifi~~~oIi!IiIil~~I--...~.;"",,,~,-,~~ "", _~.'N.. .,. .. ." ..~~ '0,., _ ~,. ,,,",,,, ~~,'~"~.' "-"~.,,',f -~-' - , .:\}".'~,~ ,.\'>r::k\ 'l'" .; 'l.-,j , ~ ; ~. ;:","j ',:~ - ~ "",.. , ~-. .0 __,- " ,-? 1';1 . =; APR 0 9 2D01 fJJ 'TERRY L. RICHARDSON, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01,984 COURTNEY JOANN RICHARDSON AND JIMMY JAMES THOMAS MCDONALD, Defendants CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this Il tL day of the attached Custody Conciliation Summary follows: , 2001, upon consideration of , it is hereby ordered and directed as 1. Legal Custody. The parties shall have shared legal custody of the minor Children, Trysten McDonald, born May 6, 1999, and Tyson Stump, born May 8,2000. 2. Physical Custody. Primary physical custody of the Children shall be in the Plaintiff, Terry L. Richardson, the Children's Maternal Grandmother. 3. The Defendant, Jimmy James Thomas McDonald, shall have rights of visitation with the Children in Plaintiff's home each Saturday from 1 :00 p.m. until 6:00 p.m. 4. The Defendant, Courtney Joann Richardson, shall have rights of temporary or partial custody at such times as she and Plaintiff may mutually agree. 5. Counsel for the Plaintiff shall serve copies of this Order upon both Defendants and shall file the appropriate return of service with the Court. This Order is temporary in nature. In the event that either Defendant is aggrieved by the terms of this Order, it may be modified by proper petition by the Court and shall be scheduled for a Custody Conciliation Conference in due Court. BY THE COURT, G. 0\ ~ 4'1~\ ( o ~~ Dist: PeterJ. Russo, Esquire, 5010 E. Trindle Road,Mechanicsburg, PA 17050 Courtney Joann Richardson, Cumberland County Prison Jimmy James Thomas McDonald, 423 Cumberla~d Courts, Harrisburg, PA 17102 ..~ ^-^ -, -, -~ ,-- ' '-.-- "--'-"--~ -. .,' -k:"~ , TERRY L. RICHARDSON, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-984 COURTNEY JOANN RICHARDSON AND JIMMY JAMES THOMAS MCDONALD, Defendants CIVIL ACTION - LAW CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Trysten McDonald Tyson Stump May 6, 1999 May 8, 2000 Maternal Grandmother Maternal Grandmother 2. A Custody Conciliation Conference was held on March 26, 2001, with the following individuals in attendance: the Maternal Grandmother, Terry L. Richardson, and her counsel, Peter J. Russo, Esquire. 3. The Defendant, Courtney Joann Richardson, is the biological Mother of the Children and is presently incarcerated in Cumberland County Prison. The Defendant, Jimmy James Thomas McDonald, was recently incarcerated as well. However, it is believed that he is not presently incarcerated. He did not attend the Custody Conciliation Conference. However, the Maternal Grandmother reports that she spoke with him after he received notice of the Custody Conciliation Conference and encouraged him to attend the Conference today. Father did not attend. Maternal Grandmother reports that subsequent to the March 1, 2001, hearing with Judge Oler, Father has had no contact with the minor Children. 4. Counsel for Mother reports that they have no proof of service of the Order scheduling the Custody Conciliation Conference for March 26, 2001. Maternal Grandmother has no desire to change the contentof the present Order. The Order will remain intact, subject to Petition for Modification by either parent and with additional requirement upon counsel for Plaintiff to serve the Defendants and file a Return of Service. G.btl-Q~ (ff,-c; Melissa Peel Greevy, Esquir Custody Conciliator Date ~Io//)/ -^~~ . -,.~...... "',' '-~"H'.""'-, '0'0 ..~~ .~.- -- ..---.C--"-.;.-'-''l,~ t I . APR 0 9 zootfP TERRY L. RICHARDSON, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-984 COURTNEY JOANN RICHARDSON AND JIMMY JAMES THOMAS MCDONALD, Defendants CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this I \ +h day of '{\ ife R. , 2001, upon consideration of the attached Custody Conciliation Summary eport, it is hereby ordered and directed as follows: 1. LeQal Custody. The parties shall have shared legal custody of the minor Children, Trysten McDonald, born May 6, 1999, and Tyson Stump, born May 8,2000. 2. Physical Custody. Primary physical custody of the Children shall be in the Plaintiff, Terry L. Richardson, the Children's Maternal Grandmother. 3. The Defendant, Jimmy James Thomas McDonald, shall have rights of visitation with the Children in Plaintiff's home each Saturday from 1 :00 p.m. until 6:00 p.m. 4. The Defendant, Courtney Joann Richardson, shall have rights of temporary or partial custody at such times as she and Plaintiff may mutually agree. 5. Counsel for the Plaintiff shall serve copies of this Order upon both Defendants and shall file the appropriate return of service with the Court. This Order is temporary in nature. In the event that either Defendant is aggrieved by the terms of this Order, it may be modified by proper petition by the Court and shall be scheduled for a Custody Conciliation Conference in due Court. BY THE COURT, Dis!: Peter J. Russo, Esquire, 5010 E. Trindle Road, Mechanicsburg, PA 17050 Courtney Joann Richardson, Cumberland County Prison, . Jimmy James Thomas McDonald, 423 Cumberland Courts, Harrisburg, PA17102 .' TRUE COPY fROM RECORD In T estl any where f, I here unto set my hand end t seal of sai Court fiCarlis'e, Pa. :rhi .....}2... f.......:...P.}.;. ..,.~. .l. .. .. . . ......~... ... . froili900M~ . ... "--,~" -,-." -. "--";i , ~ .: TERRY L. RICHARDSON, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-984 COURTNEY JOANN RICHARDSON AND JIMMY JAMES THOMAS MCDONALD, Defendants CIVIL ACTION - LAW CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Trysten McDonald Tyson Stump May 6,1999 May 8, 2000 Maternal Grandmother Maternal Grandmother 2. A Custody Conciliation Conference was held on March 26, 2001, with the following individuals in attendance: the Maternal Grandmother, Terry L. Richardson, and her counsel, Peter J. Russo, Esquire. 3. The Defendant, Courtney Joann Richardson, is the biological Mother of the Children and is presently incarcerated in Cumberland County Prison. The Defendant, Jimmy James Thomas McDonald, was recently incarcerated as well. However, it is believed that he is not presently incarcerated. He did not attend the Custody Conciliation Conference. However, the Maternal Grandmother reports that she spoke with him after he received notice of the Custody Conciliation Conference and encouraged him to attend the Conference today. Father did not attend. Maternal Grandmother reports that subsequent to the March 1, 2001, hearing with Judge Oler, Father has had no contact with the minor Children. 4. Counsel for Mother reports that they have no proof of service of the Order scheduling the Custody Conciliation Conference for March 26, 2001. Maternal Grandmother has no desire to change the content of the present Order. The Order will remain intact, subject to Petition for Modification by either parent and with i;ldditional requirement upon counsel for Plaintiff to serve the Defendants and file a Return of Service. Wtl-~~ fff,-~ Melissa Peel Greevy, Esquir Custody Conciliator 11h//)/ Date <