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HomeMy WebLinkAbout01-3032 FX " .. , 'r".1 [,j " , 2j,J, ,'~ v I"~':::. --11't,i), f DEBRA A. SMITH, Plaintiff/Petitioner :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYL VANIA v. :CNIL ACTION- LAW :IN CUSTODY ?J1.- :NO, 01- 30 CML TERM KENNETH A. SMITH, DefendantJRespondent PETITION FOR SPECIAL RELIEF PURSUANT TO PA R.C.P.1915.13 AND NOW, this 18th day of May, 2001, pursuant to Rule 1915,13 of the Pennsylvania Rules of Civil Procedure, comes the Petitioner, Debra A. Smith, by her attorneys, the Family Law Clinic, seeking emergency relief relating to her minor children, Kayla L. Smith, born April 11,1990, and Kenneth A. Smith, II, born February 16, 1993. Petitioner requests an Order granting temporary shared legal and physical custody of the children to both parties, and prohibiting either party from removing the children from the Commonwealth of Pennsylvania, and in support thereof, states the following: 1, The petitioner, Debra A. Smith, is an adult individual who resides at 64 Rustic Drive, Shippensburg, Cumberland County, Pennsylvania 17257, 2, The respondent, Kenneth A. Smith, is an adult individual who resides at 64 Rustic Drive, Shippensburg, Cumberland County, Pennsylvania 17257, 3. The petitioner is the biological mother (hereinafter "Mother") of the minor children, Kay1a 1. Smith, born April 11, 1990 (hereinafter Kay1a) and Kenneth A. Smith, II, born February 16, 1993 (hereinafter Kenneth, II), 4, The respondent is the biological father (hereinafter "Father") of Kayla and Kenneth, II. 5, Mother and Father currently live with the children, but on May 18,2001, Mother filed a .., I ,: J :;~ . i I ~ ,.;., ~ I 1'-- , . ;,,-r ~ Custody Complaint with this Court, Mother intends to fmd new housing for herself and the children. 6. On May 16,2001, when Mother informed Father that she intended to move out of the house with the children, Father threatened to take Kayla to live with him in Alabama or Georgia, 7, Father has not been gainfully employed since February 2001, and has no other family in the Commonwealth of Pennsylvania, 8. Father has family in both Georgia and Alabama, Specifically, Father's sister, Cheryl Evans, lives in Griffin,Georgia and Father's sister, Sandra Galloway, lives in Norcross, Georgia, Father's brother, Kevin Smith, lives in Jonesboro, Georgia, Father also has a sister, Debbie Botwell, who lives in Selma, Alabama. 9. Upon information and belief, Father has contacted one or more of his sisters about moving in with them, 10, Father has also informed Kay1a, in the presence of Mother, that he intends to take her to live with him out of state, 11, Because of these statements and actions, Mother fears that Father will take Kay1a and/or Kenneth, II, out ofthe Commonwealth of Pennsylvania, 12, Mother believes and avers that it is in the best interest of the minor children that neither Mother nor Father be permitted to take Kay1a 1. Smith or Kenneth A Smith, II, out of the Commonwealth of Pennsylvania until further Order of Court, so that this Court, which has jurisdiction over the parties and this matter, can adjudicate the present custody action, ",lIlOl I , . 1':1', j: ,~: ~ ~7 i,j ."1 WHEREFORE, the petitioner, Debra A Smith, respectfully requests that this Honorable Court enter an Order granting both parties shared legal and physical custody of the children and prohibiting both parties from removing either child from the Commonwealth of Pennsylvania until further Order of Court, Respectfully submitted, Date: May 18,2001 ~~~ nifer G son Certified Legal Intern ~L~ RT E. RAINS THOMAS M. PLACE TERI L HENNING Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013-2899 (717) 243-2968 .;c'_'- ,~ . i.-,[' Ill- II -, ,,- VERIF1CATION I verifY that the statements made in the foregoing Petition are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa,C.S. ~4904, relating to unsworn falsification to authorities. Date: 5/1 S 10 I f . ~ O.~~/~ ebra A. Illith it't:liJ~~aiJi""~m~:i.Ii<&\i"'ik'f1!'I'jl-)i"'V~,/(\M,ii1tjjM'~\!;iiM:j2:!!'iJI0.li~ni;r&,~~i';k.l'A'-"0,i"(-XjH-;;,l,j~,;"i'';.ioii~;:H_,%,-":-i;ji'@;~''''''''I,,,jH~t'li!l$ii,j:!i~!'''''.'"'i -""'~-lll.' Uti! ~.fi.~iJ] '. IlJ)l!I!lj'n J=""",~""",,,,,,, 'ww ~ ~,,',0~~_ __ ~~"M ,'~, _",,~",',r.,,~,~.,,",~" M- -~,-",",'"" -,.,-,- ,", ~~~ -,~=,~ ,= (') C <'" -uri5 n1(,1 fu~' ,- ~~~ ~:- -~ -< _iil ,-,~ ~,."- JIiJ - "Utt, i c.:) C)- '~r-I - -~- b> -( "-~ ~-l; -n _,:::;c: 'J :iI ,'~ C':) " : ~ (-1 ~ -' ," t. CD :;:;,.. 1'0 ,-' ,~~; c-j :'''--=-i''f') ,j ::,.--:1 ~O -< . " '" 1- I I', ". ~;~" j, ,J 'I ~ ","" ," ' .... DEBRA A SMITH, Plaintiff/Petitioner MAY 1 82001 :IN THE COURT OF COMMON PLEAS OF ~ :CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION- LAW :IN CUSTODY , ~ :NO. 01_!d> CIVIL TERM KENNETH A SMITH, Defendant/Respondent ORDER OF COURT AND NOW, this Ir day of m~ ,2001, upon consideration of the attached Petition for Special Relief, it is hereby Ordered as follows: 1, The Petitioner, Debra A Smith, and Respondent, Kenneth A Smith, shall share temporary legal and physical custody of their minor children, Kayla L Smith, born April 11,1990, and Kenneth A Smith, II, born February 16, 1993, until further Order of Court, 2, Neither Petitioner, Debra A Smith, nor Respondent, Kenneth A Smith, shall remove either of the minor children from the Commonwealth of Pennsylvania until further Order of Court, 3, The Cumberland County Sheriff shall serve this Order on Respondent. BY THE COURT, /1#-. J. ~) ~t C:'7(j L ~t.. ~, M j ~~~, r.-"'bC ."fj., ;r. ~ ~ '. I ,I! .~L~ L...'.,,:!: ,.... DEBRA A, SMI1H PLAINTIFF V. KENNE1H A SMI1H DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 01-3032 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday,~ay24,2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, June 21, 2001 , the conciliator, at 9:30 a.m. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Hubert X. Gilroy. Esq. tJ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990, For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing, YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTI! BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 r ,.... f'<lIfl -I!l ~~, "~~~, ,~ ~-- "< "'~, " ,~",,~, ~'=,~,."'....,,, ,,~'" - >" "' ,~. ~'.~"~"""" ~,,,,,",.",,,,,,, 'w,,[tl:<h~~~'~'~"' ...~,-- ~ ".i.l.""""-",,,,,",,,",,,;,,~",j'''''' L"'l! fr:'~,~ v ....' 'I n:~ iI"", j: '~7 ". C'I'''" t..{Vibci,.,:' L:',U-' r "'''II J!,!'ry .< .~I', '''-' \."'- .' I " PENi\JS)lVAr~lA: ' .5'cJ?I'cJl M. ~ ~ k5 4 d c.:6......;~<.) S:c/I/-C;I /~ ~~ ~ S'-Jlf?J1 {'t?J7p ~~, "it. _~ ~:ta . _,_",,!Il!'i'i~~~!!n!I,~~~\?I'i;fffi"i#!!~*1l,",,~~''',wn'''";'''';i;'''' ii" 1,1 ; I " , b.,"~"" . .. ~ . (} MAVQt;D1 DEBRA A SMITH, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN CUSTODY , ?--. : NO, 01- 303 CIVIL TERM KENNETH A SMITH, Defendant ORDER OF COURT AND NOW, this_ day of , 200 I, 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 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 YOU SHOULD TAKE TillS 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 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities andreasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court, You must attend the scheduled conference or hearing. ~~, "",'.,~ II , ,-,I '~ , _ ,",,,,, ,,, ~,. -' - \ DEBRA A. SMITH, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN CUSTODY KENNETH A. SMITH, Defendant : NO. 01- CIVIL TERM COMPLAINT FOR CUSTODY The plaintiff, Debra A. Smith, by her attorneys, the Family Law Clinic, sets forth the following cause of action in custody, requesting primary physical custody of her children, 1. The plaintiff is Debra A. Smith, residing at 64 Rustic Drive, Shippensburg, Cumberland County, Pennsylvania, 17257, 2. The defendant is Kenneth A, Smith, residing at 64 Rustic Drive, Shippensburg, Cumberland County, Pennsylvania, 17257, 3. Plaintiff seeks custody of the following children: Name Present Address Date of Birth Kayla Lynn Smith Kenneth Alan Smith, II 64 Rustic Drive, Shippensburg, PA 17257 64 Rustic Drive, Shippensburg, PA 17257 4/11190 2/16/93 The children were not born out of wedlock. The children are presently in the custody of both Debra A. Smith and Kenneth A, Smith, who reside at 64 Rustic Drive, Shippensburg, Cumberland County, Pennsylvania. During the past five years, the children have resided with the following persons at the following addresses: Persons Debra A. Smith & Kenneth A. Smith Addresses 64 Rustic Drive, Shippensburg, PA 17257 Dates Feburary 2000 - present Debra A. Smith Debra A, Smith & Kenneth A. Smith 64 Rustic Drive, Shippensburg, PA 17257 64 Rustic Drive, Shippensburg, PA 17257 July 1999 - February 2000 April 1997 - July 1999 Debra A. Smith & Kenneth A, Smith Roxbury Ridge Apartments, Apt 412, Shippensburg,PA 17257 1992 - April 1997 l,'~~~"' ,j,.", ',1 " , "I ,..j" ,,' 'i'1~ - . l The mother of the children is Debra A. Smith, who currently resides at 64 Rustic Drive, Shippensburg, Cumberland County, Pennsylvania. She is rnarried to the defendant. The father of the children is Kenneth A. Smith, who currently resides at 64 Rustic Drive, Shippensburg, Cumberland County, Pennsylvania. He is married to the plaintiff. 4. The relationship of the plaintiff to the children is that of mother. The plaintiff currently resides with the following persons: Name Relationship Kenneth A. Smith Husband Kayla L. Smith Daughter Kenneth A. Smith, II Son 5. The relationship of defendant to the children is that of father. The defendant currently resides with the following persons: Name Relationship Debra A. Smith Wife Kayla L Smith Daughter Kenneth A. Smith, II Son 6, The plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: a) Plaintiff has been primary caretaker of the children since birth. T,iii!l - 'j " i,l ,:1 '''. '~f:r'::'i "- ~ b) Plaintiff is better able to provide a home with adequate moral, emotional, and physical surroundings for the children, whose best interests would be served by an award of primary physical custody to the plaintiff. C) Plaintiff is willing to accept custody of the children. d) Plaintiff continues to perform the parental duties and enjoys the love and affection of the children. e) Plaintiff will encourage continuing contact between the Defendant and the children. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, plaintiff requests the court to grant her shared legal and primary physical custody of her children. Date WI.(L.,:, i'( ,lCCi 'j , , I , . <<- \.. "~CU\J\..,\"'~'i\ J nnifer Gison Certified Legal Intern ~ ' 0- ~ ~ PLi'dl - ROBERT E. RAINS Supervising Attorney TERI 1. HENNING Staff Attorney F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 ,,' - I, '~ ,I .1 I;;. _""j',-, "' 1.,":., ,,' ... VERIFICATION I verify that the staternents made in the foregoing Complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. J btc~ {'( J;J7/ ~ Debra A. Smith Date: -S -It-OJ i'''''-'~- I. :,1 ,~ ;1 .~~ ~ ." ..,t DEBRA A. SMITH, Plaintiff MAYl~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA .... ~.. .lIo. v. CIVIL ACTION-LAW IN CUSTODY KENNETH A. SMITH, Defendant NO, 01- 363;)-- CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Debra A. Smith, Plaintiff, to proceed in forma pauperis, I, Jennifer Garrison, Certified Legal Intern in the Family Law Clinic, for the party proceeding in forma pauperis, certifY that I believe the party is unable to pay the costs and that I am providing free legal service to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto, ~.~ ' ~\J\J4c<\ J fer Gam on Certified Legal Intern ~~ L*1 R E E. RAINS THOMAS M. PLACE TERI 1. HENNING Supervising Attorneys May 18,2001 THE F AMlL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 ~.-. , ' l..I , ^- '<:..;: . . - DEBRA A. SMITH, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY KENNETH A. SMITH, Defendant : NO, 01- CIVIL TERM AFFIDAVIT SUPPORTING PRAECIPE FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1, I am the Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting or defending the action or proceeding, 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs oflitigation. 3, I represent that the information below relating to my ability to pay the fees and costs is true and correct (a) Name: DebraA. Smith Address: 64 Rustic Drive, Shippensburg, P A 17257 Social Security No,: 182-52-5761 (b) Employment If you are presently employed, state Employer: Squires Parts Company Address: 201 W. Neff Avenue, Shippensburg, PA 17257 Salary or wages per month: $1256,00 (gross) Type of work: Data Entry If you are presently unemployed, state Date of last employment: Salary or wages per month: Type of work: (c) Other income within the past twelve months Business or profession: N Other self-employment: N Interest: N Dividends: N Pension and annuities: N Social security benefits: N , c ,I.., 1'1 :1 . "'u_,~'~ Support payments: N Disability payments: N Unemployment compensation and supplemental benefits: N Workman's compensation: N Public Assistance: N Other: (d) Other contributions to household support (Husband) Name: Kenneth A. Smith If your husband is employed, state Employer: Unemployed Salary or wages per month: $0 Type of work: Contributions from children: N/A Contributions from parents: N Other contributions: ( e) Property owned: House - foreclosure action pending Cash: Checking account: Y, $15,00 Savings account: N Certificates of deposit: Real estate (including home): Y, foreclosure action pending on home Motor vehicle: 1976 Nova Cost: $500,00, Amount Owed: $0 1992 Dodge Caravan Cost: $6,000,00, Amount Owed: $6,000,00, $220/mo, Stocks; bonds: N Other: (f) Debts and obligations Mortgage: $465,00/mo. Rent: Lot rent, $210,00/mo, Loans: $600,00 from Orrstown Bank Other: Credit Card Debt: $3,000,00 Gas: $92.00/mos Outstanding: $300,00 Outstanding Electic: $2,000,00 Medical Expenses: $2,000,00 Food: $217,00/mo, Braces: $140,00/mo, Phone: $25,00/mo, Cable: $30,00/mo, Persons dependent upon you for support Children, if any: Name: Kay1a 1. Smith Kenneth A. Smith, n Age: 11 years 8 years tCi''];" -~ " "I': " , ,I J ~ <,~ ~ < ^ _l " ~ I 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein, 5, I verifY that the statements made in this affidavit are true and correct I understand that false statements herein are made subjectto the penalties of 18 Pa, C, S, 4904, relating to unsworn falsification to authorities. Date ')- /6"- 0 / Uba a,Sml% - Debra A. Smith ,r,~~,"'*;JIi~i1~IWr!,"'ti"'H'iJIl~CIj~1""h'llil~i~M!1i;;.ii!"1l!i;,"i';~r.,'~M";'<.-i" ,,>,,,, ,~,j'oi,<';i" ,,0, '''''~''''d'~'''.JL~Il.~Iila~1lI~''''"''-~i<.-hof''l\I!ilIl1!_I~:lt'l-\-*",~I~..1iI!'';:''~~ """"".~H!l~J11 -~, o C ? ;gfr; z:...;-~ o.~ ~,~. ~~:~; z,~..., ;;:;:{:) s " =< - ~~,~, -~"""'~"",~C~"'r -~, , CJ ,'~ , , '-I :-/ :--: ::-;-:;... ~-_.. 0) 2~ N en c5 ::.;::.:-1 5.1 -< ..a ;~_.-"~' <,,_ "-. I ~ ~ - .'" .J I," - _","'M" ...2ll.U_~!" . SHERIFF'S RETURN - REGULAR , CASE NO: 2001-03032 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SMITH DEBRA VS SMITH KENNETH A DEP SHANNON SUNDAY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within ORDER OF COURT, was served upon SMITH KENNETH A the RESPONDENT , at 1940:00 HOURS, on the 24th day of May , 2001 at 64 RUSTIC DRIVE SHIPPENSBURG, PA 17257 by handing to KENNETH SMITH a true and attested copy of ORDER OF COURT, together with COMPLAINT FOR CUSTODY,PETITION FOR SPECIAL RELIEF and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 11.78 .00 10.00 .00 39.78 So Answers: r~~~t:~~ R. Thomas Kline 00/00/0000 me this .30 !be day of By:sL m.~ Deputy Sheriff~ Sworn and Subscribed to before =a 02~/ A.D. o.~l# ~thonotary . "~ ' -, "" I J..." . ",Co,'~' -," ",'.. --i, ';"1' ,'"~,,,;, <~"L'b-:''''" '~'~~"""c""';''''U'~'G''' ", _ '''"~''-'-;'''''''_''''':''I , D 2 82001,1 DEBRA A. SMITH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW KENNETH A. SMITH, Defendant NO. 01 - 3032 CIVIL IN CUSTODY COURT ORDER AND NOW, this %'1- day of June, 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Debra A. Smith, shall enjoy legal and physical custody of Kayla Lynn Smith, born April 11, 1990; and Kenneth Alan Smith, II, born February 16, 1993. 2. The Father, Kenneth A. Smith. shall enjoy periods of visitation with the minor children at such times and under such circumstances as agreed to by the Mother. 3. In the event Father is dissatisfied with the periods of temporary custody provided to him by Mother, Father may petition the court to have the case again scheduled before the Custody Conciliator. 4. Upon Mother learning of an address of where Father may be served, Mother shall advise her counsel of that address and counsel for the Mother shall serve a copy of this order and the accompanying Custody Conciliation Report on the Father by regular and certified mail. BY THE COURT, cc: Jennifer Garrison Dickinson School of Law Family Law Clinic ~ f\~f@ {)-3 l. , 'mil ~" "~. - Of '}l,l! ~) .i;) E: ,"';2 CUh ,:~~<,I, ,_, ",i ,..1 , ,", i:\ rr\J 1""",/,\ 1\ ,',/ , , -" I Y :"'.1 '11'\:)'[ ,,-,,< ,1'1", ' " ~\""" ',-!,I/) rlT1~11lii~!-~~_~~1l""~''''',,~ ~:l;lfJit!!Jl~~..~p'(\',~ " '~l\I'!"!r!!'" _"C _"',l --. ,"'_.<.,n",~ ~" _:,h_"I~'''""",,, "">'\i,;"~h,C~"'"~'-,"",i~';cS;" ,'", ,-,,~ '.'cJ,;,;,:,.,_,; . . . DEBRA A. SMITH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW KENNETH A. SMITH, Defendant NO. 01 - 3032 CIVIL IN CUSTODY Prior Judge: CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Kayla Lynn Smith, born April 11, 1990; and Kenneth Alan Smith, II, born February 16,1993. 2. A Conciliation Conference was held on June 21, 2001, with the following individuals in attendance: The Mother, Debra A. Smith, with her representative, Jennifer Garrison of the Dickinson School of Law Family Law Clinic, The Father did not attend. Filed of record in this case is a Sheriffs service indicating the Father was served with notice of this Conciliation Conference. Mother relates that the Father has not seen the children for approximately three weeks and that she does not know his current address or even where he is working. Mother believes that the Defendant Father may have even left the Commonwealth. 3. The Conciliator recommends the entry of an order in the form as attached. Ct (:L~( tl DATE '