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Home My WebLink About01-03128 6~' " ~ "~, ,j; -1<I.lii!l~' . -, ~ Christina M. Norman, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 0/- dlJ"P CIVIL ACTION - LAW IN CUSTODY aUltT~ David A. Norman, Defendant ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before, Esquire, the Conciliator, on the day of , 2001, at A1P.M., in Pennsylvania, 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 shall also 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, Date of Order: By: Custody Conciliator 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. OFFICE OF THE COURT ADMINISTRATOR CUMBERLAND COUNTY COURT HOUSE FOURTH FLOOR CARLISLE, PA 17013 (717) 240-6200 - , , " ,~ ~' . J' _,i, '-, - -" .... 6 # Christina M. Norman, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. e>/- 3/.27 ~ J.t.A/I- David A. Norman, Defendant CIVIL ACTION - LAW IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Christina M. Norman residing at 351 North 69th STreet, Harrisburg, Dauphin County, Pennsylvania 17111. 2. The Defendant is David A. Norman, residing at 225 Roxbury Road, Newville, Cumberland County, Pennsylvania. 3. Plaintiff seeks to confirm primary physical custody of the following child: Date of Birth ~ Taylor J. Norman June 8, 1991 The child was not born out of wedlock and is in the custody of Defendant. During the past five years, the child has resided with the following persons and at the following addresses: NAME RESIDENCE DATES Christina M. Norman 225 Roxbury Road Newville, PA The mother of the child is Plaintiff, Christina M. Norman and is single. present The father of the child is David A. Norman and is single. 4. The relationship of Plaintiff to the child is that of mother. Plaintiff currently resides with James J. Breski, Jr, her fiance. 5. The relationship of Defendant to the child is that of father. The Defendant currently resides with the minor child and Barbara Snyder. .--- -.' ~~ ,-- J, ,- " ~ -'~'1 ~ .. ~ 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested. 8. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child has been named as parties to this action. All other persons, named below, 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: N/A WHEREFORE, Plaintiff requests the court to grant her custody of the minor child. Respectfully submitted, 'fC{~ iller, Esquire 2010 M et Street Ca ill,PA17011 717) 737-6400 ~"=~. ~ , '" ,~" J~ , i, ' iOO!lii.l:iI:',~!;:;_, ~ ~ ~ .. I VERIFICATION I verify that the statements made in this Complaint 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: 4/;7/xCOI , t &h40tUztc 11/. /J) 1n/l7?~I-// Christina M. Norman, Plaintiff , .... I ~m~~~~l<d9~~"li~~" '--- c"J:h.liII.'!Ji~.w.~d::M;~".Jifh;i!~~~~"":;' Z5 V .. -Oi.i!l- ' _,-.~-.J<.';""';"lli _~'d .- " -........- ... , ~ ~ ~ 0 0 0 C) C "- d - -". ~ "1:Jr-: :;::;,:> ..... z~~; ~ ..... ~~i'~ "-' "'<) ~ -J 1'....;, ) r ~~~ f " ') :;::c; L,"": .,..-c N C) ~ Z '" :?:;! -I :0 -< c:; -< '"'..u........, ~ ,," -.-llIIIIiIJI!t," I . b ~ '", l'~' " -.1 "'--............="'~-".'i,',_~'.,/,_ . .. CHRISTINA M. NORMAN PLAINTIFF V. DAVID A. NORMAN DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 01-3128 CIVlLACTIONLAW IN CUSTODY ORDER OF COURT AND NOW, Friday, June 01, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on Tuesday, July 03, 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. The court hereby directs the parties to furuish auy aud all existiug Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ 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 TillS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ,I I i I I ! I :':1 "'=_.",' 1 ~.t/t?/ ~ -001 ~ i/tJ( . '. , . RlEDcOj7FICE, OF Tr:l: FPOn-!ONO'fARY 01 JUIl-4 PM 3: 50 CUMBERLAND COUNTY PENNSYLVANIA (}:I ~~:it 4~ :: ;:;:;~~ .. <It ~,4<lffllllI~~ ~~1!\<,:U:;l ""'"'~""'~_ _" ~.,B'PIft!l~~~IIfi!l:hJi"',"",F~,illl5'\~"*1""~-'f";r"" F"E''''I''''*":r!1f'~''I~Wnr:~~,,,",;;C~1P'W:''_'_'1_\''i!RiJi*~fr!!i'1I~~,~ :po -.-- ~J- ~ ~ ~ffij. 1 andIof' 2 for addftfonat \'_--~'i,~.,s ., elteffl$;3.iilRd4a6D. ~ "<- - ~1 your rtame end Addle.. on tha r&wH'se of this form so that we can . . m this card to you. li.:-._ . Attach thi'.:> form to the ~ront 'Of the mallpiec~1 01 on the tacl<. if space .;:_~ doe. not permit. ~-----wrtte "'Return Receipt Requested" on the mailpiece below ths article number. ~_ . The Return Receipt will show to whom tne article wa:; dillivered i1nd the date ~.!- o.livcred. Consult o$tmastBr for fee. ~~~ ~dreAed to: r00CrY'aAJ 4a. Mer. N:f4' ;1' ~ ~ru- Vcvcl 3Fl~;:;~;eJype 0 Insured ~..-.._.-.n_.IJ.lt0lJ'/lL .:;;>... \j /7"" l.(/ ~rtifi.d 0 coo , ' f OC 0 Express Mail 0 Return Receipt for Merchandise 7. Date of 0 ivery ~ lR L 8, Addresse '5 Ad and fee is paid) 1 also wish to rec:elve the tattowing silu""ices ffor an extra lee): 1. 0 Addressee's Address .~ ~. tI) w c. II Q . a: c !I' e1 a: "" .5 ~ " ~ o - 2. 0 Restricted Delivery " o >- ress /Only if requested .:l( c .2 >- ,'1-,......,...., OOMESTIC RETURN R1E"'. -" ~ ,-"~ ";i!k l ., p '" Christina M. Norman, Plaintiff In the Court of Common Pleas Cumberland County, Pennsylvania v. No: 01-3128 Civil Action - Law David A. Norman, Defendant In Custody AFFIDA VIT OF SERVICE OF CUSTODY COMPLA TNT I, James A. Miller, Esquire, hereby certifY that I served the Defendant, David A. Norman, with a certified copy of the custody complaint on June 12, 2001, as evidenced by the attached United States First Class Mail return receipt card number P 016 244 749. DATE: Saturday, June 16,2001 {/tIL-- . Miller, Esquire 20 arket Street amp Hill, PA 17011 (717) 737-6400 cc: Melissa P. Greevy, Esquire . . ~[t~~:1i~i~~t',j; ';':-:-0<_II~H~s1>:,~;~,;L:1J':L:,-;,i~i>j;Yfitr<J'~m~~~~--~" ,~.,. -, ';,>""i~';'-"'/i'~">,,,c- sS I(~ - .. . " "h~_<, _~ ., ,"'" "'<'",,,',,M~',,n"" . '''''..n.""" ' .... '.~ ..' ,C" '''''''',i ." ", o c z -0\5 ~~~': ~~{ cO ~ ec) ~~C) >c z ::2. o \:::::. . - " ';.~ \ - U:J --,'~! rjC;; ~i~~ 20 ',C-fn o ..-\ ..",. ::g -, -0 ~ r:? (J:J o ": "',~",,,'~"'" "I, ,~ ~ .." ""' .' -, , .~ ,t__, .'; liliiiiil_:i' .. JUL 1 7200ft;!) CHRISTINA M. NORMAN, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3128 DAVID A. NORMAN, Defendant CIVIL ACTION - LAW CUSTODY INTERIM ORDER OF COURT AND NOW, this J ~ day of July, 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Christina M. Norman and David A. Norman, shall have shared legal custody of the minor Child, Taylor J. Norman, born June 8, 1991. 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 her health, education and religion. Pursuant to the terms of Pa. C. S. 9 5309, 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. A. Summer. Mother shall have physical custody beginning at 5:00 p.m. on the last work day of her schedule until 6:00 p.m. on the next day she works. Mother's work schedule is included as an attachment to this Order with the highlighted areas indicating the days that Mother is not working. During such times that Mother is working, Father shall have physical custody. However, Father shall have physical custody of the Child one weekend in August for the purposes of attending a family reunion with the paternal side of the family. Father shall provide notice to Mother by July 30, 2001, which weekend this reunion shall occur. B. School Year Custody. Mother shall have physical custody from Friday at 3:45 p.m. until Sunday at 3:00 p.m. each weekend that she is off. Specifically, Mother is off the weekends of: September 7, 14,21 and 28, 2001 November 2, 9, 16 and 23, 2001 """'" - , I '~- I . --'~ ',c;. " m'<'; """~~'- ~<i ~ No. 01-3128 In addition, if the Child is out of school for school holidays or teacher-in- service days during the months of October 2001 or November 2001 during a time when Mother is not working, then the Child shall be in the custody of the Mother. 3. Holidays. The holiday schedule shall supercede the regular schedule. The Thanksgiving school break custody shall be arranged to be with Mother during odd-numbered years and with Father during even-numbered years. For Christmas 2001, Father shall have physical custody for December 24th through December 25th at 11 :00 a.m., and Mother shall have physical custody from December 25th at 11 :00 a.m. until December 29th at 8:00 p.m. 4. During any period of custody or visitation the parties to this Order shall not possess or use controlled substances, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise ensure, to the extent possible, that the other household members and/or house guests comply with this prohibition. 5. The parties shall ensure that the minor Child is not exposed to secondhand smoke, whether that be in a residence or a motor vehicle. 6. The parties shall submit themselves and their minor Child to an independent custody evaluation to be performed by Deb Salem. The parties shall sign all necessary releases and authorizations for the evaluation to obtain medical and psychological information pertaining to the parties. Additionally, the parties shall extend their full cooperation to complete this evaluation in a timely fashion so that its results may be used in a hearing prior to the end of August and the commencement of the 2001-2002 school year. The cost of the evaluation shall be shared equally by the parties. 7. Upon the completion of the custody evaluation and receipt of the report, counsel for Mother shall contact the Custody Conciliator to arrange an additional Custody Conciliation Conference for the purpose of allowing the parties to reach an amicable resolution and parenting agreement prior to pursuing custody litigation and a Court determination of the parenting plan. J. . _ I j1 UfV · 0 f1 a.J..uL L7-/g-01 0t Dist James A. Miller, Esquire, 2010 Market Street, Camp Hill, PA 17011 William L. Grubb, Esquire, 3105 Old Gettysburg Road, Camp Hill, PA 17011 , I I . .. " ~. ~. !I1IlI ",," ~,~,"r',-""C i.<'. ~ 'J" ',,j <,i( , PEt<t _f!"/ , '- '. j. ~;I . " _,""J~lg;_~~~-!lIM'll1jr']'''''1lf'l'-1i'Ii>\:''d'\1.'lJj'~~t\llii~''!llf~I~I1~'~~ ~'""'~ ~, , 1" "~, , (" - -~..l~--.k''':'''''N'_~~~_""_,,, &':i ~ . . CHRISTINA M. NORMAN, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3128 DAVID A. NORMAN, 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 Taylor J. Norman June 8, 1991 Father 2. A Custody Conciliation Conference was held on July 3, 2001, with the following individuals in attendance: the Mother, Christina M. Norman, and her counsel, James A. Miller, Esquire; the Father, David A. Norman, and his counsel, William L. Grubb, Esquire. 3. The parties reached an agreement as to an Interim Order in the form as attached. Date 1--/,,/()/ / ' Iissa Peel Greevy, ustody Conciliator I -~ -Iir"- --.fL. ^. SEP 0 72001tP CHRISTINA M. NORMAN, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3128 DAVID A. NORMAN, Defendant CIVIL ACTION - LAW CUSTODY INTERIM ORDER OF COURT Guido, J. _ AND NOW, this I O~ day of September 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Christina M. Norman and David A. Norman, shall have shared legal custody of the minor Child, Taylor J. Norman, born June 8, 1991. 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 her health, education and religion. Pursuant to the terms of Pa. C. s. 9 5309, 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. A. Summer. Mother shall have physical custody beginning at 5:00 p.m. on the last work day of her schedule until 6:00 p.m. on the next day she works. Mother's work schedule is included as an attachment to this Order with the highlighted areas indicating the days that Mother is not working. During such times that Mother is working on the summer schedule, Father shall have physical custody. However, Father shall have physical custody of the Child one weekend in August for the purposes of attending a family reunion with the paternal side of the family. Father shall provide notice to Mother by July 30, 2001, which weekend this reunion shall occur. B. School Year Custody. Mother shall have physical custody from Friday at 3:45 p.m. until Sunday at 3:00 p.m. each weekend that she is off. Specifically, Mother is off the weekends of: September 7, 14,21 and 28, 2001 November 2,9, 16 and 23,2001 '- ": , ,j ~~= -'-~-y: ,~ " No. 01-3128 Civil Term In addition, if the Child is out of school for school holidays or teacher-in- service days during the months of October 2001 or November 2001 during a time when Mother is not working, then the Child shall be in the custody of the Mother. 3. Holidays. The holiday schedule shall supercede the regular schedule. The Thanksgiving school break custody shall be arranged to be with Mother during odd-numbered years and with Father during even-numbered years. For Christmas 2001, Father shall have physical custody for December 24th through December 25th at 11 :00 a.m., and Mother shall have physical custody from December 25th at 11 :00 a.m. until December 29th at 8:00 p.m. 4. During any period of custody or visitation the parties to this Order shall not possess or use controlled substances, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise ensure, to the extent possible, that the other household members and/or house guests comply with this prohibition. 5. The parties shall ensure that the minor Child is not exposed to secondhand smoke, whether that be in a residence or a motor vehicle. 6. The parties shall submit themselves and their minor Child to an independent custody evaluation to be performed by Arnold T. Sheinvold, Ph. D. The parties shall sign all necessary releases and authorizations for the evaluation to obtain medical and psychological information pertaining to the parties. Additionally, the parties shall extend their full cooperation to complete this evaluation in a timely fashion so that its results may be used in a hearing prior to the end of August and the commencement of the 2001-2002 school year. The cost of the evaluation shall be shared equally by the parties. 7. Upon the completion of the custody evaluation and receipt of the report, counsel for Mother shall contact the Custody Conciliator to arrange an additional Custody Conciliation Conference for the purpose of allowing the parties to reach an amicable resolution and parenting agreement prior to pursuing custody litigation and a Court determination of the parenting plan. J. Edward E. Guido Dist: James A. Miller, Esquire, 2010 Market Street, Camp Hill, PA 17011 William L. Grubb, Esquire, 3105 Old Gettysburg Road, Camp Hill, PA 17011 ~ ~ 9.10.01 Q-. ~ '. ~ . -~. ,~ ,~ - ,--~" - FF_ED-Of'F1CE (" " ,.. ""''''r~1'' "JTARY ,_n- i:,:': ;-'~':") ,',\..)1'\..... II o i SEP f 0 PI~ 2: l. 3 CUlVE~EHLAND COUNTY PENNS\lVANIA "J.!~""" ,-~ lllIm~;J~l!Ii!$l~WIfID".'-~~\il\~!I!I}~~I~~~"",:",,~~ - -"'-:-- .' -c '", -'F'-""~h--:' .;..~- ~t '''''.I!;<i .' .' vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3128 CHRISTINA M. NORMAN, Plaintiff Defendant CIVIL ACTION - LAW CUSTODY DAVID A. NORMAN, CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1 . The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Taylor J. Norman June 8, 1991 Father 2. A Custody Conciliation Conference was held on July 3, 2001, with the following individuals in attendance: the Mother, Christina M. Norman, and her counsel, James A. Miller, Esquire; the Father, David A. Norman, and his counsel, William L. Grubb, Esquire. 3. The parties reached an agreement as to an Interim Order in the form as attached at the conference. However, subsequent to the conference reached an agreement to use a different provider for the Custody Evaluation. Therefore, a new Interim Order of Court is provided to the Court. 9-6--0/ Date 'ssa Peel Greevy, Esquire Custody Conciliator I-'-~ . ~. .' . , .- i J I , ii I I 2001 CROMPTON SCHEDULE MTWTFSS, 123456-7 J 8 9 1~ 111>1'13 14 A 1516:P ~ 19 20 21 22 23 24 25 21'1'7 28 N293031 ,\ 1 2 ii 4' F 5 6;J 8 I.... 1011 E 1213~61718 B 19 20 21 22 3 24 25 26 27 2 1 2 3 .4 M 5 ~ 7 8 9. ;'0 11 A 12 13 ~~"5'16 171a 19 20 21 122 23 24 25 R 262728293031 MTWTFSS 1\ 1 A23'41,678 P 9 10 11'k.2113 14 15 161Ai118 191mJ21 22 R 23242526272829 30 123456 M 7 8 9 10 11 12 13 A 141516171S 19 20 Y 212223 212P 2~27 282930~r$ 4 5 6 ''<Ii J 1,:l1l'h2~1415 ;617 Ulfal1~ 2' 21 22 23 24 N 1951~Il!i 282930 2001 CROMPTON SCHEDULE M T W T F 5 5 M T Iw T F 5 5 1 ~. ,,,<I,i!l104 5 6 7 J '~'3. ~4;" 5 6 7 8 0 IIllI! :9111~ 11 12 13 14 U 9 1011 t~,lllili~fil c~. "18192021 16 17 18IwI2"l!.2111UiI ~ 26 2728 L 2324 25 ",,~~Iiiiil T 29 3031 3031 I I, 1 '2!1'3!I!1d~ ~!J, iI;;iiI A _<'" N. I~';O' 1 "'i:ib,'~i 9 101112 S 67 ,,,i,,,,'" U.it'l!1~1!16171819 0 121314'L~'I' G 2lI H223242526 V 1920212~'~2. 27, ~Q !ill 30 31 .~: ~~ llj: 29 30 1 2 I 1 2 5345 ",:.'.9. 6799 E 10 11 121{j;l.'.jI. ,"'l,'5),-".', 0 ~...1 13141.5.16 1718192!1\2ligt2' E ~9JI2m[02122~ p 2425262'29'29,3 C 24125126 .II.~ 31 . -',,, ..,,',~ ,'L ,-.-,~c ",;,-'" -" -"_:_~,,,,-,z\-,-,j;;':,.ti;~-_ ;::0' _ ."'__ --<i