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Home My WebLink About01-1227 FX "~ n ",", '''-' ,~ '~'~= :1, . ," LISA M. SMITH, plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TIMOTHY RAY PARRISH, Defendant 01 - /{).{)..7 ORDER OF COURT AND NOW, , 2001 , upon consideration of the attached Custody Complaint, it is hereby directed that the parties and their respective counsel appear before conciliator, at , the on the day of , 2001 , at o'clock .m., for a Pre-Hearing Custody Conference. At such conference~n 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: 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 Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 ""'- ~ - . . ~~ ,I. , cl.. '.;,,~,- " .' LISA M. SMITH, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 01 - fJ-.;J'7 ~ 1.?fAY' TIMOTHY RAY PARRISH, Defendant COMPLAINT FOR CUSTODY ORDER TO THE HONORABLE, THE JUDGES OF THE SAID COURT: 1. Plaintiff is Lisa M. Smith, an adult individual thirty - two years of age who currently resides at 12 Midland Drive, Mt. Holly Springs, Cumberland County, Pennsylvania. 2. Defendant is Timothy Ray parrish, an adult individual thirty-five (35) years of age who currently resides at 537 First Street, College Park Apts., Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff seeks a custody order involving the minor child, Bailey Austin parrish, d.o.b. March 25, 1999. 4. The natural mother of the child is Plaintiff and Defendant is the natural father of the child. 5. The child who is the subject of the instant custody petition has resided with Plaintiff and Defendant since birth and has primarily resided with plaintiff since January 2001. 6. Plaintiff and Defendant were never married and are currently separated. 7. No custody agreement has been reached by the parties concerning the minor child and Defendant has recently threatened to ~-.~ ~- -'- - ..--.~ ~- ~""'i C"""~l':' ,. 8. Plaintiff does not know of a person not a party to the proceedings who has legal or physical custody of the child or claims to have custody or visitation rights with respect to the child. 9. An Order of Court is necessary to develop a routine period of custody along with holiday schedules and terms which address other important dates for custodial purposes. 10. The best interests and permanent welfare of the child will be served by ordering that both parties share legal custody of the child and directing that Plaintiff/Mother shall have primary physical custody of the child and that Defendant/Father shall have periods of partial physical custody activities for the following reasons: (A) Plaintiff is a fit parent who can take care of the child and who can provide her with a supportive, safe and healthy environment on a regular basis; and (B) Plaintiff is capable of insuring a supportive and loving environment for the child, a home with appropriate lodging and insuring that the child is properly cared for, including making arrangements for day care when both parents are working; and (C) Plaintiff has consistently raised the child since birth. (D) Defendant's threats of moving from the Cumberland County region and taking the child is not in the child's best interest. 11. An Order of Court is necessary so as to address important events such as holidays, summer vacations, extra-curricular 2 1tl ^ J. ='= "',,-, -, ~ , ~<. "'''''f\; r activities and other events for which the parties have been unable to agree. 12. An Order of Court is necessary to identify pick-up and drop-off times, transportation issues and legal custody issues. WHEREFORE, Lisa M. Smith, Plaintiff, respectfully requests that your Honorable Court enter a Custody Order which grants Plaintiff and Defendant joint legal custody, and which grants Plaintiff primary physical custody with periods of partial physical custody to Defendant. Respectfully submitted, Date: March 2. , 2001 Andrew C. Shee y, E uire Attorney for Plaintiff Pa. I.D. No. 62469 127 S. Market Street, P.O. Box 95 Mechanicsburg, PA 17055 (717) 697-7050 3 ~~"" , ~ -,,,'"~ 1'1;" . " VERIFICATION I verify that the statements made in this petition for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: March Z , 2001 G:7;~t /j4(~& ~ ~ LJ.sa M. SffiJ.th '7/ c1 / .,~,~j~;,1J6.'iE-4~J'i;j!!!:;;l;'i!H-*'i~*"1~<lj~,,*~lfHt~~mjJJ_il"-~,W~"fl~cij~;,{",/",lWlJ"',,"~-,~,W<-"!I!1P5Micl(@I.'/BI!Y * -iliidllllWilDi}j-- ll:lfi<\- ~~;!'l!_,~o.i~'_w;.i' " ~0 -r -0 <J ,;s- (Q SLD . o .:j!: iT lJl - ~JlO a (p ::r' f{) ~ '--'= ,0'~_' " -''-. -" - -~ -.<< ",.','> -<- " -. Mo,'__ o ;:;J z"; 21: u> -, ~ ..J> r-. ~~~~: :z: =2 =] '."~ l' .. . C) -'\r' -::J f'_' i'""-) "", Cr'l ~;::; ~~ 90 - - -~ -~ "';<~ . ,,'., " t LISA M. SMIill PLAINTIFF V. TIMOTHY RAY PARRISH DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-1227 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, March 12, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, FA 17055 on Tuesday, April 10, 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, aud 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 tJJ Dawn S. Sunday. Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR 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 ;-,l;,;,!(M:~"".9.h;';'\Ib1L,14~f:0,!i-"'r.;,,~t-1..~~rn-ii!\J~,"4illlh<iJJID[,-"'-,i"',':;'~.,,,'ii:<<~~;:;.'-,,;,,j,:;!t,.~,,"~'''':tI.,.,,,.,,,~~l"W~~!,6ill,l&;imJr~~1l1lliilll/iliU'lilimi!!l]l<:t "1iJllr~"" I': , I' 4~p ~ ~U( MJ,J /rJ-5/. f.' -6 t:-~ ~~ /(/-,y! [' ~?~. ~ ~-n /(/'YI-E Vl~~1I1~8NN3d AlNnc)c' 0i~\!1tn8V11n() L'l:j [,Id S I ~VH 10 ),tJVF)i',(':.:~; 1(','.,' , . 3cj~j;'b:',(j~ '0 ~' ,',,~~_~^. ~M_ . _ _ _ 0' _ ,'". __",,' _ ~"," ." ". .. ~~,~ -', ':., .~ t ..:;-.. . . LISA SMITH, . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . . : vs. . . NO. 01-1227 CIVIL TERM : TIMarHY RAY PARRISH, Defendant . . CIVIL ACTION - LAW IN CUSTODY : OODER OF COORT AND NCfi, this 'i I- day of ~.. '/ consideration of the attached Custody Concili tion and directed as follows: , 2001, upon Report, it is ordered 1. The Mother, Lisa M. Smith, and the Father, Timothy Ray Parrish, shall have shared legal custody of Bailey Austin Parrish, born March 25, 1999. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. The parties shall share having fhysical custody of the Child, with the specific arrangements to be established by agreement of the parties with a goal of maximizing each parent's non-working time with the Child on an equal basis. 3. The parties shall equally share or alternate having custody of the Child on holidays as arranged by agreement. 4. Each party shall be entitled to have custody of the Child for two uninterrupted {non-consecutive} weeks each year upon providing at least 30 days advance notice to the other party. 5. In the event either party intends to relocate his or her residence outside of Cumberland county, that party shall notify the other party at least 60 days in advance to allow the parties an opportunity to modify the custody arrangements by agreement or obtain a resolution through the legal process. The parties shall also provide reasonable notice to each other of any intention to relocate his or her residence within Cumberland County. 6. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation COnference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms , .< , "T"" _,'. "' ' . ~ _ ""Jr , of this Order shall control. BY THE COURT, .Ad J. cc: Andrew C. Sheely, Esquire - Counsel for Mother J. 'oul """Yo _rn. - """"""1 f~ "''her t~. 1,!;/ I l"JY " ~,' '" , ~ ""\ . LISA SMITH, : IN THE COURT OF OOMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. . NO. 01-1227 CIVIL TERM . . . TIMarHY RAY PARRISH, . CIVIL ACTION - LAW . Defendant . IN CUSTODY . CUSTODY cx:NCILIATICN SUMMARY REPOOT IN AexmDANCE WITH CUMBERLAND COONTY RULE OF CIVIL PROCEOORB 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: ~ DATE OF BIRTH CURRENTLY IN CUSTODY OF Bailey Austin Parrish March 25, 1999 Mother/Father 2. A Custody Conciliation Conference was held on April 10, 2001, with. the following individuals in attendance: The Mother, Lisa M. Smith, with her counsel, Andrew C. Sheely, Esquire, and the Father, Timothy Ray Parrish, with his counsel, J. Paul Helvy, Esquire. 3. 1he parties agreed to entry of an Order in the form as attached. ~:J 10 dMI Date · (.0&. _M~ ..J- Dawn S. Sunday, Esquire/ Custody Conciliator