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Home My WebLink About01-03472 JOACHIM R. TOWNSEND, * IN THE COURT OF COMMON PLEAS Plaintiff, * CUMBERLAND COUNTY, * PENNSYLVANIA * VS. * NO. 01-3472 * DIANE K. TOWNSEND, * CIVIL ACTION - LAW Defendant. * CUSTODY CERTIFICATE OF SERVICE I, Misty D. Lehman, Legal Assistant to Edward 1. Weintraub, Esquire, hereby certify that on June 6, 200 I, I served a true and correct copy of a Custody Complaint and Petition for Emergency Injunctive Relief upon Austin Grogan, Esquire, counsel for the Defendant, by depositing same, postage pre-paid, in the United States Mail, Harrisburg, Pennsylvania, addressed as follows: Austin Grogan, Esquire 24 North 32nd Street Camp Hill, PA 17011 Date: CO' Lo----e:,\ ~~().~~ isty D~ Lehman 1'~r -,-"',~,", - ,,'-' . '>-', ,,< 'v'" ,",',__" .,-,,,~ -<_' -; .\!-, ,-',_~..-!,_1,_'_~"'_.,~,., ' l"-V1 ,:~~-, '._ ". - - _ ~,__ _0' ="-''>' - ~~ ,~ ',' _._ _ ,_,,~ 0 >^_~~~_, ~'_"~ ~' - 0' ~ <, C) 0 0 c .,., s: L.. .--1 -u OJ c: ~~:D rnm z 1"-- Z:lJ I c:3\? '2':1'- ill p. _1 2" ~~o :.:::0 ,; ~.,... "1"". (s ~c -!!~ ~~ -0 ~ :J>c ;t;! Z W ~() ::<! :::0 '0 '"' , !i f: , i! I' 'I ~; fi li II il f( , fj " II II 'I II 'I' r c,-:- - _ ...,._,~ C" _ _m":" t"-",.,..,.",~"'['j~"","~~_.""1 >__"!'~_~"~, F.IjIll-'!;~iP;W~~~<;)1.-ws~m;!;:H*h;"'1'-IQ.'Mtl'r~I!l'jWlll!f~_~~~~J~~l~~13jgr~~~J%U~:, '. JOACHIM R. TOWNSEND, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DIANE K. TOWNSEND, Defendant \...... NO. 01-3472 CIVIL TERM ORDER OF COURT AND NOW, this 11th day ofJune, 2001, upon consideration ofPlaintitTs Petition for Emergency Injunctive Relief, this matter is referred to the custody conciliation process pursuant to Cumberland County Rule of Procedure 1915.12-1, and the Court Administrator is requested to facilitate and expedite this referral. BY THE COURT, Edward J. Weintraub, Esq. 2650 North Third Street Harrisburg, P A 17110 Attorney for Plaintiff ~2 0 :=-. :::;; \1 -, r...~ :-;:2 n~. , c- "' ,....,::: ~l L f'-. :::. -;','-n u; "-. :;,0 -< l:~,:': c,~) r:::: CJ 1> -" ;'---Yl o' n :'::i': ~~:j~~ L C) "" 1'0 01"11 ..... C ~ -; .on >- :D (..) -< Austin F. Grogan, Esq. 24 N. 32nd Street Camp Hill, PA 17011 Attorney for Defendant Court Administrator - Au,;;( ~ 1/;1/&/ AL- :rc ;:f._" ' ,- - , -'0"" "~ , "'_"'~_ "-'"'' .'-' .' JOACIllM R. TOWNSEND, Plaintiff, * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, * .PENNSYLVANIA * vs. * NO. 01- 3tt7~ COlt ~ CIVIL ACTION - LAW CUSTODY * DIANE K. TOWNSEND, Defendant. * * ORDER AND NOW, this day of ,2001, upon consideration of Plaintiffs Petition for Emergency Injunctive Relief, it is hereby ORDERED preliminarily that: Defendant is . prohibited from removing the child from the Commonwealth of Pennsylvania to her residence in Maryland until such time as there can be a hearing to determine whether such a move would be in the child's best interests. BY THE COURT: 1. " , . _'"0'/___._ ,'~ "c~_, --, .,., , ",,~',' _, : ,_, ,'_' . ., "I' ':'~ ~"- ,-'- '. < JOACIllM R. TOWNSEND, Plaintiff, * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, * PENNSYL VANIA * vs. * NO. 0/. 3'17,L ~ JLP- * DIANE K. TOWNSEND, Defendant. * CIVIL ACTION - LAW * CUSTODY PETITION FOR EMERGENCY INJUNCTIVE RELIEF Plaintiff, Joachim R. Townsend, by and through his attorney, Edward 1. Weintraub, Esquire, files this Petition for Emergency Injunctive Relief and avers as follows: 1. Plaintiff is Joachim R. Townsend, Father, who currently resides at 1103 Saffron Drive, Mechanicsburg, P A 17050, and plans to relocate to another residence owned by the parties at 5205 Tamarvvoods Court, Fairfax, Virginia 22032. 2. Defendant is Diane K. Townsend, Mother, who currently resides at Extended Stay America, 46565 Expedition Park Drive, Lexington Park, Maryland 20653. 3. The parties are the parents of the following minor child: Karl James Townsend, who currently resides at 1103 Saffron Drive, Mechanicsburg, P A 17050. 4. On June 6, 2001, Plaintiff filed a Custody Complaint, seeking joint legal custody primary physical custody. A copy of said Complaint is attached hereto as Exhibit "A." 5. Plaintiff believes that Defendant intends to relocate to Maryland with the child outside the jurisdiction of this Court. 6. Any move with Defendant, Mother, to Maryland or any other jurisdiction would be contrary to the child's best interests. 7. Any move with Defendant, Mother, to Maryland or any other jurisdiction would seriously impair Plaintiffs ability to be an active parent for the child and would impair Plaintiffs " ., '"",~,'~-' - c ~__ _. . ,,"e_, ~"~ __ ~___ '. relationship with the child. 8. Plaintiff is the child primary nurturing parent and believe it is in the child's best interest to reside primarily with Plaintiff whether in Pennsylvania or after June 18,2001, in Fairfax, Virginia. 9. Defendant does not have a valid basis for moving the child to Maryland or to any other jurisdiction. 10. Under Plowman v. Plowman, 409 Pa. Super. 143, 597 A.2d 701 (1991), prior to removal of the child from the jurisdiction, the Court must hold an evidentiary hearing on the proposed relocation to examine the factors set forth in Gruber v. Gruber, 400 Pa. Super. 174, 583 A.2d 434 (1990). WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an emergency injunction preventing Defendant from removing the child from the Commonwealth of Pennsylvania until such time as there can be a hearing to determine whether such a move is in the child's best interests. Date: / S 1 Edward J. Weintraub, Esquire 2650 North Third Street Harrisburg, PA 17110 ID#17441 ATTORNEY FOR PLAINTIFF , ~,~, - " .," :-,~,~ - "-" .J_; -''''_^'_''''~~'''''' _f,,-' ,-.'0' ~ _ ., \ ~"7~__ , "-~"" ,,~-", '. .~ VERIFICATION I, Joachim R. Townsend, hereby swear and affirm that the facts contained in the foregoing Petition for Emergency Injunctive Relief are true and correct and are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: (0 -')-DI R-~ oachim R. Townsend, Plaintiff '" -~, 'j ~~, EXHIBIT "A" ~~" c..,"~"'_' i'".,-,~ '."'"'):;.... ,';--"'_i_'~' '" '--' _Yo ",_"" ""c.,_-.._,",-.;,;,_:, :w_~,_C"'{,~__~, "1 _: ,_, _. "._ '. '. JOACHIM R. TOWNSEND, Plaintiff, * IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA * * * VS. * NO. CIVIL ACTION. LAW CUSTODY * DIANE K. TOWNSEND, Defendant. * * ORDER OF COURT 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 , Esquire, the Conciliator, at Pennsylvania, on the day of , 2001 at o'clock, _.m., for a Pre-Hearing 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 a temporary order. Either party may bring the child who is the subject of this custody action to the conference, but the children's attendance is not mandatory. 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 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 1 COURTHOUSE SQUARE, 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 < <,' "_ _c'" ~ "-,~-",-,, ~"-" ,-"--" " " - , '. '.- ,- ,-- -~ ," - I> '_ ~~__,,__ _~'U__~ '. '. JOACHIM R. TOWNSEND, * IN THE COURT OF COMMON PLEAS Plaintiff, * CUMBERLAND COUNTY, * PENNSYLVANIA * vs. * NO. * DIANE K. TOWNSEND, * CIVIL ACTION - LAW Defendant. * CUSTODY COMPLAINT FOR CUSTODY AND NOW, Plaintiff, Joachim R. Townsend, by and through his attorney, Edward J. Weintraub, Esquire, files a Complaint For Custody against Defendant, Diane K. Townsend, and in support thereof, avers the following: 1. Plaintiff is Joachim R. Townsend, Father, who currently resides at 1103 Saffron Drive, Mechanicsburg, PA 17050. 2. Defendant is Diane K. Townsend, Mother, who currently resides at Extended Stay America, 46565 Expedition Park Drive, Lexington Park, Maryland 20653. 3. Plaintiff seeks custody of the following child: r-lAME Present Address AGE Karl James Townsend 1103 Saffron Drive, Mechanicsburg, PA 17050 10 4. The child was not born out of wedlock. 5. The child, Karl James Townsend, is presently in the custody Father, Joachim Townsend, who currently reside at 1103 Saffron Drive, Mechanicsburg, PA 17050. 6. During the past five (5) years, the child, Karl James Townsend, has resided with the following persons at the following addresses: Eer.SQll5 Address Date. Father 1103 Saffron Drive, Mechanicsburg, PA 17050 4/01-present ',~:~~,! ",,' ,- ,_~"""",~",,_",- ~~," --,,~ "" ~ ~- ,', '-:-;'1' '." ,__w',"" ~,,_ - "",F_~". CO ." _ ,- ~-~< ~, - - : , " Mother & Father 1103 Saffron Drive, Mechanicsburg, PA 17050 1998-4/01 Mother & Father 5205 Tamar Woods Court, Fairfax, VA 22032 1990-1998 7. The Mother of the child is Diane Townsend, who currently resides primarily at Extended Stay America, 46565 Expedition Park Drive, Lexington Park, Maryland 20653, 8. The Father of the child is Joachim Townsend, who currently resides at 1103 Saffron Drive, Mechanicsburg, PA 17050. 9. The parties are married. 10. The relationship of Plaintiff to the child is that of Father. Plaintiff currently resides with the following people: Person Relationship Karl J. Townsend Son 11 . The relationship of Defendant to the child is that of Mother. Defendant currently resides with the following persons: Person Relationship None 12. Plaintiff and Defendant have 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. 13. Plaintiff and Defendant have no information of a custody proceeding concerning the child pending in a court of this Commonwealth, 14. Plaintiff and Defendant do 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. ''!; ""'0'" "'1:":<"'"_I~<"""""~'';'''~_ ,_,_'-' < ~~.~ - _,' _ .u ,oo_'___ ,., '" ." : , '. 15. The best interests and permanent welfare of the child, Karl J. Townsend, will be served by granting the relief requested, inter alia, because the Plaintiff Father has been one of the child's primary caretakers. 16. Each parent whose parental rights to the child have not been terminated and the persons who have 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 respectfully request that this Honorable Court enter an Order granting him shared legal custody and primary physical custody, with Defendant Mother to have partial physical custody. ~_... By: Edward J. Weintraub, Esquire 2650 North Third Street Harrisburg, PA 17110 (717) 238-2200 Attorney ID. #17441 Dated: J S 0 ATTORNEY FOR PLAINTIFF ~<- . ." , .-0""\-' "', . __. ,,-"-,_~,V ~,"-,. ~ ,e: ; '...,- - _ "h, -co", I'" ,_~_T_ H_, ". _._ ... _ ,_,_~" . . ., '. , " VERI FICA TION I, Joachim R. Townsend, hereby swear and affirm that the facts contained in the foregoing Complaint for Custody are true and correct and are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: !aIel C> I {JI--J\.v<" e (ltW\v~. Jo him R. Townsend, Plaintiff '''-,"~_.,,~-- "'; ",.,-~-, ., ., . ,-. ~ ,- -~,~"-l_^'i,"-' ,-," -,." , . ~ , - e- . r .... I '. .>_' _...__ff. II ~, ~,.". ~ (") = 0 C ~!'l tt ;;: ~~= ...1 0 --U OJ "1"' } 52"; ;:t:: innF-"";; 1" ,..;..,J I .'f)~ D> Zj.:: C) (.n. 0' -'-,~ '--' ~ '<z lidc~ to , ~CJ 0 PC) ~v -c'--r' ...;,'" ( I ~..' CJ Zo .~.() f'.) ;'""~ rn ~ ;.t;c ~) ........ ~ ~ ........ ..() r D ~ tv ~ ...... ~ J -........: .' n~l~ _..,.~..!_" ,~"-_'~'_~1~___ _~q~'ffl!-~~:r:",~jff'JI;J!I~:11I,"'~;"(,"m"RI(f;~I1Wo/~~JiR."~~~~~~J!t1'l~ , . . ~ JOACHIM R. TOWNSEND PLAINTIFF V. DIANE K. TOWNSEND DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-3472 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, Juue 14, 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 Seuate Aveuue, Suite 105, Camp HiD, PA 17011 on Tuesday, July 03, 2001 at 9:15 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this carmot 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 conferenc~ 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 Melissa P. Greevy. Esq. '(j'i\ 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 '~1llill ~""., , -~. "~ -~." - '~mJlh,hl'lllli;i!,:&;H~l;._'ill,:Wjt.n;~~lil\f,'i~I~.I~j~,!m&1!Ji;""'i0.!l,;i';"I,,",_",~">"";',",'0~~;lli;l,;~s",;',,'i"k\l-';F;1;liM",,,,,~~~.&.~"'- '_1" 1.w J.-I f -/)I ~ /f,tJ/ J-/r-tJI ",-, _,_,,__'"~~w~_ '0 '<'_"''-''"'''''''''~'''''~ ,_., ,~ ....iIili[==L--. Di: '~i -., I " ,,,,,r-,,,'-:_~!"'~'I"-'i-' ;\ny -' -', ','.\,;,r\n o i JU~',J I 8 PH 2: :1 8 CU'V'II:;;:~L' /',:"U" ",." ',rrv I We...; I. Il. ~/JVj\tll PENNSYLV,b,NiA 01 53 w.~ ;n:Jv ~ a4 ~ '7Z~~~4~~ ttYJ2t ~ .g4~ c , ...,. - ~'I'l~.i/llIliiill&}J"ii I I ! I I I I I ~ ,<' ~. , .' " * *IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01- 31f7:J....... C'vJ~~ * JOACHIM R. TOWNSEND, Plaintiff, * VS. * * DIANE K. TOWNSEND, Defendant. * CIVIL ACTIO IN - LAW CUSTODY * ORDER OF COURT 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 , Esquire, the Conciliator, at Pennsylvania, on the day of , 2001 at o'clock, _.m., for a Pre-Hearing 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 a temporary order. Either party may bring the child who is the subject of this custody action to the conference, but the children's attendance is not mandatory. 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 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 1 COURTHOUSE SQUARE, 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 ~',o._' ~"~~'''-'''~-...~.-"o.~_,.,_,->.,.-, ,'-'--~"'" _ -":--,,'-_=. ~"::"_e ,0 ,-, - - -,_~ f __T_ ~ ,. I" ., " JOACHIM R. TOWNSEND, * IN THE COURT OF COMMON PLEAS Plaintiff, * CUMBERLAND COUNTY, * PENNSYLVANIA * ~ I~ NO. 0/- 3'11:2.. vs. * * DIANE K. TOWNSEND, * CIVIL ACTION. LAW Defendant. * CUSTODY COMPLAINT FOR CUSTODY AND NOW, Plaintiff, Joachim R. Townsend, by and through his attorney, Edward J. Weintraub, Esquire, files a Complaint For Custody against Defendant, Diane K. Townsend, and in support thereof, avers the following: 1. Plaintiff is Joachim R. Townsend, Father, who currently resides at 1103 Saffron Drive, Mechanicsburg, PA 17050. 2. Defendant is Diane K. Townsend, Mother, who currently resides at Extended Stay America, 46565 Expedition Park Drive, Lexington Park, Maryland 20653. 3. Plaintiff seeks custody of the following child: NAME Present Address AGE Karl James Townsend 1103 Saffron Drive, Mechanicsburg, PA 17050 10 4. The child was not born out of wedlock. 5. The child, Karl James Townsend, is presently in the custody Father, Joachim Townsend, who currently reside at 1103 Saffron Drive, Mechanicsburg, PA 17050. 6. During the past five (5) years, the child, Karl James Townsend, has resided with the following persons at the following addresses: Persons Address Date Father 1103 Saffron Drive, Mechanicsburg, PA 17050 4/01-present -_CO, , ~, " -,",,'-? ',',','"., , r ,-" ",-c.'--' , r ~T ,,,, ., , ., ,. Mother & Father 1103 Saffron Drive, Mechanicsburg, PA 17050 1998-4/01 1990-1998 Mother & Father 5205 Tamar Woods Court, Fairfax, VA 22032 7. The Mother of the child is Diane Townsend, who currently resides primarily at Extended Stay America, 46565 Expedition Park Drive, Lexington Park, Maryland 20653. 8. The Father of the child is Joachim Townsend, who currently resides at 1103 Saffron Drive, Mechanicsburg, PA 17050. 9. The parties are married. 10. The relationship of Plaintiff to the child is that of Father. Plaintiff currently resides with the following people: Person Relationship Karl J. Townsend Son 11. The relationship of Defendant to the child is that of Mother. Defendant currently resides with the following persons: Person Relationship None 12. Plaintiff and Defendant have not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another cou rt. 13. Plaintiff and Defendant have no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 14. Plaintiff and Defendant do 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. '"d"_,,~i, "_~,.-,,.. 'h",' ~--, ":''''.,- _,=__ - ._,c.,> ---- '" ,~ " 15. The best interests and permanent welfare of the child, Karl J. Townsend, will be served by granting the relief requested, inter alia, because the Plaintiff Father has been one of the child's primary caretakers. 16. Each parent whose parental rights to the child have not been terminated and the persons who have 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 respectfully request that this Honorable Court enter an Order granting him shared legal custody and primary physical custody, with Defendant Mother to have partial physical custody. By: Edward J. Weintraub, Esquire 2650 North Third Street Harrisburg, PA 17110 (717) 238-2200 Attorney 10. #17441 Dated: J S 0 ATTORNEY FOR PLAINTIFF 'S'"",,,., .'- - ,,". '" "''C',''"''';'," --, --, v,,, _ ',', ",~ 1, ,,'~.1_'," ""<"0.'" ~_~,'-c '''1 .' ~ -', . - . " ~, - , _~n VERI FICA liON I, Joachim R. Townsend, hereby swear and affirm that the facts contained in the foregoing Complaint for Custody are true and correct and are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: ~/r1 D I e~ ,__ '. u : ~,,' _ ,,~_"""_ _"_ , ,-,-"-,1 ,-' , _ ," ."'7'~ d., #j , 'cn c ~ c . CCc..",,""'" ,_. Jl , .,"".."., +"~~'1>; - I!.ll~~- ?"'""~, ~-- -'""'0" '~~'"~,",,,., 0 C) r' (J c: -l';~ tJ ~ <'" , ~ -Om s ~ ~r" :'!p It. X' Zt;, I -"J ~'J: , ~:Z~ Ci ::~] r.j (;., ,::~i~ --- 0 ~CJ -;J ~ ~ ~8 ='-' f~~~ V, ] )>c ~ c5r-n ..--i < ~ 0 )> ~ ,,,) ~ IJ~flI!!'l~,~"'!;!;'IJf'~'*,h""?4i"';":"~f~~'m'W~}~)t~~~ST~~:L ~;".~~n,~ JOACHIM R. TOWNSEND, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACtION - LAW DIANE K. TOWNSEND, Defendant NO. 01~3472 CIVIL TERM ORDER OF COURT AND NOW, this 11th day ofJune, 2001, upon consideration of Plaintiffs Petition for Emergency IIUunctive Relief, this matter is referred to the custody conciliation process pursuant to Cumberland County Rule of Procedure 1915.12-1, and the Court Administrator is requested to facilitate and expedite this referral. BY THE COURT, Edward J. Weintraub, Esq. 2650 North Third Street Harrisburg, PA 17110 Attorney for Plaintiff Austin F. Grogan, Esq. 24 N. 32nd Street Camp Hill, PA 17011 Attorney for Defendant ~ Administrator :rc .. fJ - -., - ", '., ,<<_:- _ r.", 1-' "~ ,- !yl.t,;:J' ~" ~', ..;" n~! AUG 1. S l001 r\ # vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3472 JOACHIM R. TOWNSEND, Plaintiff Defendant CIVIL ACTION ~ LAW CUSTODY DIANE K. TOWNSEND, ORDER TO RELINQUISH JURISDICTION AND NOW, this 6th day of August, 2001, the Conciliator, having received notice that on July 3, 2001, that it appeared that the parties have reached an agreement which they intended to finalize via stipulation, hereby relinquishes jurisdiction of the above-referenced Custody matter. FOR THE COURT, i::: ;P.. Melissa Pee Greevy, Esquire Custody Concilator 'C'''I~. " ~'-'. ,. ,-,,'- ~ , ,~ - ~. - -.' "'. - -,^ . ',d." ~~" ~ . ., ~ . -- " t? to () c: "U"; fllF~:: ;;;-~,' <,_r- ~,:- kC' t€[3 .2 =< ." '.-' ~ '-~.~ ~'~~ ."""~^' ,.. .'';, c' :~ s:S: 1 ~ " c"", ~~.J ,:::) <.n ; J _~.:~{:(i: i~~- Fri ~' 55 -< - 'k _~ -",-~""" 1!_,_~ I ~ _ . "" ~.~~!fJj~H~"~Wif!1'1;~~!:~!\f!!;Hl,~~.$!~I!IJL~" _...~~~_Jl~)~, . o' '. . .' JOACHIM R. TOWNSEND, Plaintiff, * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, * PENNSYLVANIA * VS. * NO. 01-3472 * DIANE K. TOWNSEND, Defendant. * CIVIL ACTIOIII . LAW * CUSTODY PRAECIPE FOR WITHDRAW OF APPEARANCE Please withdraw my appearance on behalf of Plaintiff, Joachim R. Townsend, in the above captioned matter without prejudice. . Date: ;>-/00'- , squire PRAECIPE TO ENTER APPEARANCE Please enter my appearance on behalf of Plaintiff, Joachim R. Townsend, . in the above captioned matter. Date: f~/tlr jfJ~~ /Patrick O'Conner, Esquire '"~-q" __,,~, -/ _~ '~', < ,cP'i;" - -" ",,-, - ". ~ - '1'_ ,- >'N' .~-" ~ ~- ,- "J f,<'-'+/,';' -' -;. ,'",w'~'~',. ;;.-",~~,...".. '~" '_'~',-" --hili'o':;r; ;>"~'-; (. . a Cl ~ C f'.) $: ...., --1 c;:...S "UlJ] ,"'1 ::C:;1l ~rn co '<;F::::: :D ~ ZS;'. N -,-:fil .:]0 (f) .c, A' ~~~ 2' 0 '<: ~ ~o --- j~("') 5>g ;? om '~-l ?i )> (10 :D -( -< , _~ ._.IIIiI!llIJillllI'iRIS!!i 1 _,~~~__ CIif! _ ~JF~~~~tf'-~"';""1~~~~~~~~IlWll_ ,.,.~~,