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HomeMy WebLinkAbout01-03780 "';". ~~ , '; ,~, ., , , ) JACK R. KNIPE, III PLAINTIFF V. MANDY S. HEWLETT DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 01-3780 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, June 27, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thnrsday, Angust 02, 2001 at 8:30 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 defme 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.M 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 ATIORNEY AT ONCE. IF YOU DO NOT HAVE AN ATIORNEY 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 J ~;)'ff'cJl ~.,;)t-tJl do ;;)~.t)j , , I I ;. "=, ._~~~" ~ W~"'" ',",.' h" ,~,- .,-- ~,',' -~,; 'k'"",,~-,.t'lli'"Jlir'j-:1! '] ff'.1 "'iJ1' Ui ,HJ: 2e :',' , ',1: ,) ':1 , .1 , .~ "" nl.;'", ", . W 'I 'j:~,:'1 (-"'-"1 j',r- t ... -~;""'... \j,-,J..,,,,j\~ I Y Pt"Ni "'l'"'''' i ~ 'v) '/hi\fl-\ W % /I'l~ ~ 4- Obf ~~ lJ~- _ ~~~i/.~# ~ , " IlTt OI1'lII!!l"llliTr'. .~ir-"Tn ._~~i"'!.Wfm~/!fflt!"!!'I'W1II_W'~,'!!1fi'iG\l<l'Yil"'"''''W:'''.;HW',~l''!~1M<).O!!O",I$'1\'~'''--;''' '~;~""-)fT(T'< "'-'."""" '-'--''-';-''0;'>_'''llw*lta~nl-1t!1'V~1f'~1i1'!1fI''';:'1>'1~'''''-,:'''''i"''''_"J'fN"~I-~ml,_~tfll~~~~ "" >'--" .-"' . "_ '0 '" '" "',,. _,,',' ~ ," l" " ",~,;,:-,,~ JACK R. KNIPE, ill, Plaintiff v. :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION-LAW :CUSTODYMSITATION :No.: 01- 311CJ ORDER OF COURT CIVIL TERM MANDY S. HEWLETT, Defendant 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 o'clock, _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. It is ordered that physical custody is granted to the Plaintiff pending the hearing, (1), subject to such reasonable periods of supervised custody by Defendant as may be mutually agreed upon between the parties. 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 HA VB A LAWYER OR CANNOT AFFORO 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 (717) 249-3166 ~" ~, ~. ' ,.,.; <---'~J-~,,,,,,~" k ,': l ' __j:.:'j! JACK R. KNIPE, ill, Plaintiff v. :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION-LAW :CUSTODY MSITATION MANDY S. HEWLETT, Defendant :No.: 01- 3'llf1J CIVIL TERM COMPLAINT FOR CUSTODY 1. The Plaintiff is Jack R. Knipe, ill, residing at 164 Amy Drive, Carlisle, Pennsylvania, 17013 2. The Defendant is Mandy S. Hewlett, residing at The Cumberland County Prison, Carlisle, Pennsylvania, 17013 3, Plaintiff seeks custody of the following children: NAME RESIDENCE DOB AGE Kevin M. Knipe Alyssa N. Knipe 164 Amy Drive, Carlisle, P A 17013 1/5/99 164 Amy Dnve, Carlisle, P A 17013 11/3/00 2 yrs. 5 months o yrs. 8 months 4. The children were born out of wedlock. 5. The children are presently in the custody of Jack R. Knipe, ill, Father. 6. During their lives, the children have resided with the following persons at the following addresses: KEVIN M. KNIPE NAME ADDRESS DATES Mandy S. Hewlett 213 Plaza Drive, Boiling Springs Birth until January 2001 Jack R. Knipe, ill. 164 Amy Drive, Carlisle January 2001 until Present ALYSSA N. KNIPE NAME ADDRESS DATES '"" ~ " ,(" ;".",1, ,:_"! Jack R Knipe, III 164 Amy Drive, Carlisle Birth until Present 7. The mother of the children is Mandy S. Hewlett, currently residing at The Cumberland County Prison, Carlisle, Pennsylvania 17013. She is unmarried. 8. The father of the children is Jack R Knipe, III, currently residing at 164 Amy' Drive, Carlisle, Pennsylvania 17013. He is unmarried. 9. The relationship of the Plaintiff to the children is that of Father. The Plaintiff currently resides with the following persons: NI A 10. The relationship of the Defendant to the children is that of Mother. The Defendant currently resides with the following persons: NI A 11. 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. 12. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 13. 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. 14. The best interest and permanent welfare of the children will be served by granting the relief requested for the following reasons: A. Plaintiff has undertaken and performed the primary parental responsibilities for each of the children; and B. Plaintiff is best able to provide the care and nurture which the children need for healthy development; and C. Defendant is erratic and abusive behavior poses a threat of harm to the children; and D. Defendant frequently abuses alcohol and other illegal substances and is therefore " " " -_.1 "'- '-'(.;, unreliable as custodian of the children; and E. Defendant has left both children alone on numerous occasions; and F. Defendant is currently incarcerated in Cumberland County Prison and is also facing charges in other jurisdictions. 15. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children has been named as parties to this action. WHEREFORE, Plaintiff requests the Court to grant physical custody of the children to the Plaintiff pending the hearing, (1); subject to such reasonable periods of supervised custody by Defendant as may be mutually agreed upon between the parties Date: ~ ( I ~ lo , Paul Bradford , Esquire Attorney for Defendants 50 East High Street Carlisle, P A 17013 (717) 258-8558 Supreme Court J.D. #71786 , .'~.' ", '-c. ' ,- _'~'"l" """,' 'I, ....:' di~"". VERIFICATION I verify that I am the petitioner and that the statements made in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties of Pa. C.S. S 4904, relating to unsworn falsification to authorities. DATE: & / /j/(V / T~ ,e: <,~ - !~j~iJftiig.?;t,'Ml;rlt\~\i"'i,'",;lii"_DIi!;!!""';,~"""l<.tfklil.':<';''''O>:''e\.;'~ "Ii' ""tkd"'-"'):'k""",!,"'lf"_-;,""'Ji:<'~,:!L"";'-E,:.k'".lA,,,,,"",)fj!<l<Ii<!l!~~.Ill,W"f<!~~I!lll!llJ:lij~-- , LJ,,,,,.ll:iJ~I~}IJ_~J!I~, _J1I!JE~~L .~_,"'_ '_~T.~, "~o<"~"_""""'^_' _,._~'"' ._ " ,'"" -,' ,,",' " ? [:) \~ ~ ~ 8 (} <{ t:~L "",. ~ ,~.~ c;:. - ...J ~ -.J ~ f! ~ C) C) 0 C -11 <.'" , '"1.:' l: .' c= , n- r; .,'-' ,.- ["':-: t~ r-- . h 9 " 0 -<, '.:J : . ~ ,,~~C) no ;__r; :1j L c: ..,.,,, C' ,~'" () )> C :.v (~5rn ::-.:::: :,.) ~ :;:l C) :0 -< , JACK R. KNIPE, III, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION - LAW :CUSTODYIVISITATION MANDY S. HEWLETT, Defendant :No.:01-3780 CIVIL TERM AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) AND NOW, this 25th day of June, 2001, Irving Wallace, Pennsylvania State Constable, in the above-captioned action, served a true copy of the Complaint for Custody, executed by the Plaintiff in the above-captioned matter, upon the Defendant by hand delivery on June 19,2001, at 4:45 o'clock AM at the Cumberland County Prison located at 1101 Claremont Road Carlisle, PA 17013 (See attached and marked as Exhibit "A"). Dated: ~ )~S 0 I ~ - Paul Bradford Orr, Esquire ;~ I I I Irving Wallacf Pennsylvania State Cfnstable 5 East Louther Stfeet Carlisle, P A 17013 June 21,2001 ' Paul B. Orr, Esquire 50 East High Street Carlisle, PA 17013 .:..--- U: Jack R. Knipe, m vs Mandy S. Hewlett Civil Action Law No. 01-3780 .R.SM4RlCS: Serr1ed Jllandy s. Hewlett Cumberland County .Prison 06-19-01 at 4:45 PM P.H;!"SB REMIT FBB OF: $25.00 k ## 1706 06/19/01 ,A 11 '''6 WaJJoce Pe"nsylvtmia State Constable Slfast LoU/her Street Carlisle, PA 17013 -~, Phone 717~243.6778 Pager 717~241~7~S7 Fax 717-243~7937 EXHIBIT "A" . " ',,-~ , Cf) jili!i"l'i<~~~l'Iffik~~d~~dtm~WAi;V"-;iili'"",,,AldjN<&i<~"'-"i_"'~I.t~'tlJ'=" ~-'-'IIIIIIF -~~ ~~,J~j~"J~J~~JI,. :U,J![QJJ!.I!t!_LII,;_LLU....,,___,_< ~, ~ ~~L'__""","'~/_'_"e= ,,,~=~,,_,,,""; ^.., -"., '-Y:' "_" _^,.",~," ~',.",~ .,-^>~~ =~~ _ 'R_~ _ , o f; ~~f' ch -;~. ;:i" ;'~-, ~C., ~;~2 '- ;? ~:;? ~" c:' :\) "",'] ~~) ::;:i .,,~-=. :::'0 -..:;:- ::::> lO ~ "' "-,' ~'---<: -~ ,{"" '~- :, ~ "" "-.-,, ,- I" ;c-'~,_ \. ~ AUG 0 7 ZOOl{;# JACK R. KNIPE, III, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW MANDY S. HEWLETT, Defendillt NO. 01 - 3780 CIVIL IN CUSTODY COURT ORDER AND NOW, this 9' day of August, 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Jack R. Knipe, Ill, shall enjoy legal and physical custody of Kevin M. Knipe, born January 5, 1999 and Alyssa N. Knipe, bom November 3, 2000. 2. The Mother, Mandy S. Hewlett, shall enjoy periods of temporary custody with the minor children at such times as agreed to by the parties. 3. This order is entered in recognition of the fact that Mother did not attend the custody conciliation conference. In the event Mother desires to modifY this order, Mother may petition the court at which time another custody conciliation conference will be scheduled. BY THE COURT, ./J4. J. cc: Greg Cutler, Esquire jl~ L ~-9-0 f ~ ~ Mandy S. Hewlett 89 Spring Oarden Estates Carlisle, P A 17013 , I I I I ! i I I ,. . , ,~ ~ O f)lj:r 'F T' ".'.~,J-Ili:r^' "~'::- ,:-':':';/)~/..!(~~,~;F,-, 01 '- "'-)//1RY , Alje - G - cUI'! C '''I 'Ii UMBf/1 '. ,,' . '18 P.'I::- Lh"L' (" /'/''VS'rLI~' v\OUi'{r1' ~C'd (~ "I) jr ~ ""'"""""""_,_~~" ",m~r"JII' ..nror-i ,~ ~~!o/~l!IPffili~I1'..r.lQ~_tf~ nllf~III~~'P-w;;.'~f-'>V-ttitl$_""'']1-l^f''''f~<'!'-1i',Wi!i;;iI~ft~~~leQ~~~,-fl'-;^'~"':',,","~'~.tl~~~ I. ."-~' -,<",,. -. ... " " ," '-.'~'~-"Y"'_h:'_; , ,I _" ,,",-":',,0' . .. JACK R. KNIPE, III, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW MANDY S. HEWLETT, Defendant NO. 01 - 3780 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 tollowing report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Kevin M. Knipe, born January 5, 1999 and Alyssa N. Knipe, born November 3,2000. 2. A Conciliation Conference was held on August 2, 2001, with the following individuals in attendance: The Father, Jack R. Knipe, III, with his counsel, Greg Cutler, Esquire. The Mother did not appear. An affidavit of service has been filed indicating she was served with the Notice of the Conciliation Conference. Also, Father indicates that she acknowledged to him that she was aware of the conciliation conference. 3. The Conciliator recommends the entry of an order in the form as attached. r;!~!OI DATE \'q;',gw":.:'it1~";;il-::&t)~flffii~ih'R:ij''.'-1~4~::'ft'f~JZ:wi\~~'IT&7:~~,;~:lR'z_ .. .J o i .. 01 ClI l!Is to) itl 1l' l\l to) - :;.. :::l - - :: l: l: m m ~ ~ r r m 0 -l ()l J:-l .(l o De< D mzm m -ll>tl -l" em e'l Drr DO zmm z.. -q W -l-l-l -lW 00 00 en~z 0 moO ffl';: ZDl> Z.. O~O 00- ml>tl mo DDD D.. Om en .. en W o ()l , .. .. , o .. - ::- - - - ., - 000:5:: Ql co Ql ~. (J) =' en ""C a. CD :::!.'< - ~ (/) -CCO. )>G)I ... Ql CD ..Ja.== :> CD CD ... ~ ::1: ., m lfr Cii en '._v._.. 0 z () m () () 0 :JJ ,. c o' JJ 0 JJ r- C -< :T u; JJ ,. III r- -< 0 ~ .m I ~ C- o ~ c z ~ (J) u; "U ~ m -< iii" c' " (J) JJ (') .,' 'P 0 '!; ~ C ..t;; c () 0 m ~7::, ~~ ~ ,. JJ "'00::, '::5: 92rn Ln ',11[',_ :0 nl ZC;;: i:~") ~S: c () ~O --U ." "':':C) ~~?- :?~ '(-"--1 r:? Co -.; ::- ~ -: ( .) Q. .......... \ ~ \j\l ~ ~ ~ \) t;; ....,,- " T -. ~ ..., ~ , ~ .... .". o co ~i o 1"--' - 7i ~~I~~')~ ooi;; ..~l~ ""ooi "~ .{..~ ~:;: r; w.,,~t ~ ~ [It E III ~ ..,.......,.*,...." -,~. .%;w.lf,:Q~&:;Z1';1;-!~\0.f.ii5{!{;~k~J!;~jtsH0'lii@I~~Bfp,'lR)'tf~ii ~'"~"~. .,,~ ~ ~ , " " ' I~' ""l ,-, t' AUG 0 7 200'&? JACK R. KNIPE, III, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW MANDY S. HEWLETT, Defendant NO. 01 - 3780 CIVIL IN CUSTODY COURT ORDER AND NOW, this ~ day of August, 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I. The Father, Jack R. Knipe, III, shall enjoy legal and physical custody of Kevin M. Knipe, born January 5, 1999 and Alyssa N. Knipe, bom November 3, 2000. 2. The Mother, Mandy S. Hewlett, shall enjoy periods of temporary custody with the minor children at such times as agreed to by the parties. 3. This order is entered in recognition of the fact that Mother did not attend the custody conciliation conference. In the event Mother desires to modifY this order, Mother may petition the court at which time another custody conciliation conference will be scheduled. J. cc: Greg Cutler, Esquire Mandy S. Hewlett 89 Spring Garden Estates Carlisle, PA 17013 !- >' ~ -..-- P lli R ,. JACK R. KNIPE, III, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW MANDY S. HEWLETT, Defendant NO. 01 - 3780 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: I. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Kevin M. Knipe, bom January 5, 1999 and Alyssa N. Knipe, born November 3, 2000. 2. A Conciliation Conference was held on August 2, 2001, with the following individuals in attendance: The Father, Jack R. Knipe, III, with his counsel, Greg Cutler, Esquire. The Mother did not appear. An affidavit of service has been filed indicating she was served with the Notice of the Conciliation Conference. Also, Father indicates that she acknowledged to him that she was aware of the conciliation conference. 3. The Conciliator recommends the entry of an order in the form as attached. YbJo / DATE ~,.,'.''''' .1,',-"" -~, ~~C""Y ," '_t-.''->._'.U '.''''',,'~. "",j,<,;;,-:J;,.,,:;' , l,'-,<',~~; ! JACK R. KNIPE, III, Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA i; ! v. : CIVIL ACTION - LAW i ~ ! MANDY S. HEWLETT (CLARK), Petitioner : NO. 01-3780 CNIL : IN CUSTODY CERTIFICATE OF SERVICE I, Tara M. Yutzy, Certified Legal Intern, the Family Law Clinic, hereby certify that I am serving a true and correct copy of a Petition to Modify Custody Order and Order of Court scheduling a conciliatiQn on the following person by first class U.S. Mail, postage prepaid, this Ztf'- day of ~ ,2006: Jack R. Knipe Cumberland County Prison 1101 Claremont Road Carlisle, P A 17013 . ~ ~ ',,;1, j,J~"J.i . ; MANDY S. CLARK PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA '<'" V. 01-3780 CIVIL ACTION LAW JACK R. KNIPE DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, April!2, 2006 , upon consideration ofthe attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X.Gilroy, Es'l' , the conciliator, at~th Floor, Cumberland County Courtbouse, Carlisle on Thursday, April 27, 2006 at 9:30 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 furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled heariRI!. FOR THE COURT. By: Isl Hubert X Gilro Es 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249.3166 "" . I' --",~ .,"__ '~"V' 7V1 ;// '-""'-'--""- ',,-""", ",,-' '"--'''''~.~ ' -"-, ~.,''''''~'~-'' :'''''J ,"if-'-] 'j'Qij'mrri'--nrJn'M"rr"n f 'iJ' - l r [ 1 ~, -. 0--1'''"' -'1';':'1" l-q\-lr:....;,..ii.J:. '~,.-,,,..,,..'_Ti _ir,t,_I(\O'il.RV O~. T.{~ C',""l i1,':_ ","" 1,,"\.1 );- 11 L. 1''- - ''', . 0 \W r" "8 ""I ," ,qji) f) I ~l'-j c'. (.:. 1 Ll ' :,11\ C .- ~, , '-" ~b2b-CJ~ Crd-~ ~?f ~L. ~~lJ'a~ ~~~ .7,~..;-~. tI'dO- Ok t.$~ ~c/ ~ 'j'/ .~)o yfh _ ~ (~>~ ~\ ) // ..\{'~ .\I'J"7- d (' \cAQ\\~\ r ~ ur-~ 'i)\J. 1)\'11 '1) ~q\/ ~\d/ ~-l1J0,-J r'~ ~ -ofuI1 ~ \lO ~~ - ~O j'J~)l1J a of'~ ~rl1 \\\0' \I)a,\\ I ___ d). ~1 -,\ M \~d51. -",~lo1J'"( -rO\'VV' \-1\ \VJv/" . ~"'d" '?~.-\- r01J\ " ';)\0\0" ~~~~~~!'ffio/~"!H"""J'~tw,_Wf.!"'!~i'''''.':'"'''V''~''-'''''>,'"' ",,- '\,":'-"'-l'~, "-""-",' ^O--_,,',(';o""'_~'p~,"",~f.,~,""~"'-'FmLW"'''''l'1ffl'',~~If~~ '"" ,,> ", ~'.- ''''-"''.:i -, ' ,"';'~-'"'.;," '-""~'i"-'->>,-,,, "I ~~ '-,,,' , RECEIVED APR 0 7 2006 (;r .. .. MANDY S. CLARK, Petitioner : IN THE COURT OF COMMO : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW JACK R. KNIPE, Respondent : NO. 01-3780 CIVIL : IN CUSTODY ORDER OF COURT AND NOW, this _ day of ,2006, 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 ,2006, 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. 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: 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 32 South Bedford Street Carlisle, P A 17013 ::t ~"",,~,~ ~~~",- "',4_"'''~'__,,-'J,'___;"' j ';";;,k ,,'.... .. MANDY S. CLARK, Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW JACK R. KNIPE, Respondent : NO. 01-3780 CIVIL : IN CUSTODY PETITION TO MODIFY CUSTODY ORDER 1. The petitioner, Mandy S. Clark, by her attorneys, the Family Law Clinic, respectfully represents that on August 9, 2001, an Order of Court was entered for Alyssa Knipe (child), born November 30, 2000. A true and correct copy of this order is attached as Exhibit A. 2. The order of August 9, 2001, grants Respondent (Father) legal and physical custody of the child and grants Petitioner (Mother) periods of temporary custody at times agreed upon by the parties. 3. On October I, 2001, the child was found to be dependent, as per Order of Court docketed at Juvenile No. 2001-224. On March 31, 2004, an Order of Court was entered terminating the dependency of the child. 4. As per the March 31, 2004 Order, Father was granted primary physical custody of the child. Mother was granted partial custody of the child. Mother is to have physical custody of the child on alternate weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m., on her other days off from work, from 9:00 a.m. until 5:00 p.m., and every other holiday. 5. The prior custody order should be modified because: a. Father is currently incarcerated at the Cumberland County Prison. b. Father gave custody of the child to Mother on or around October 17,2005. c. Mother is ready, willing, and able to accept primary physical custody of the "~'"' ~."~ ,>~" ~, ',-,-~ , " .h-C-" ":'-.i ~" ......'h., /; ., child. d. Mother is willing to encourage a relationship between the child and Father upon his release from prison. WHEREFORE, Petitioner asks that the Court modifY the existing Order for Custody and grant Petitioner primary physical custody as it reflects the current status quo and is in the best interest of the child. Date: .L/-/6-()ll ~ Certified Legal Iritern 'n~ , . PLACE ROBER E. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX WILLIAM G. MARTIN Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Fax: (717) 243-3639 .- "." ~-', ,-, ",', ,-, ">",, r _ .___, -,-' . , ,,;..J.~^ . 'Co:" .. - .. "r VERIFICATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities. .<:' lJClI ()1 ^ Date:~ ~-'\ , I ' '--", .,' ~,r~A<- M ,s. ql k *-~ . ~~,-" , ~f ~---:--. l~lJl3 I[i 120Dl{jJ JACK R. KNIPE, III, Plaintiff IN TIlE COURT OF COMM~LE5 gpy CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW MANDY S. HEWLETT, Defendant NO. 01 - 3780 CIVIL IN CUSTODY COURT ORDER AND NOW, this 9. day of August, 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Jack R. Knipe, III, shall enjoy legal and physical custody of Kevin M. Knipe, born January 5,1999 and Alyssa N. Knipe, born November 3, 2000. 2. The Mother, Mandy S. Hewlett, shall enjoy periods of temporary custody with the minor children at such times as agreed to by the parties. 3. This order is entered in recognition of the fact that Mother did not attend the custody conciliation conference. In the event Mother desires to modifY this order, Mother may petition the court at which time another custody conciliation conference will be scheduled. BY THE COURT, .44 J. cc: Greg Cutler, Esquire ~ L ~-9-01 ~ ~ Mandy S. Hewlett 89 Spring Garden Estates Carlisle, P A 17013 EXHIBI:I' i ~ ., c'" '" ~~ <" , H ~ -,'~ r . i ~l r " ;l, ':j ., ~ 0:; \' ',~. .. ,0 COpy JACK R. KNIPE, III, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ~' v CIVIL ACTION - LAW MANDY S. HEWLETT, Defendant NO. 01 - 3780 CNIL IN CUSTODY Prior Judge: CON CILIA TION 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: Kevin M. Knipe, born January 5, 1999 and Alyssa N. Knipe, born November 3, 2000. 2. A Conciliation Conference was held on August 2,2001, with the following individuals in attendance: The Father, Jack R. Knipe, III, with his counsel, Greg Cutler, Esquire. The Mother did not appear. An affidavit of service has been filed indicating she was served with the Notice of the Conciliation Conference. Also, Father indicates that she acknowledged to him that she was aware of the conciliation conference. 3. The Conciliator recommends the entry of an order in the form as attached. P!7/0/ DATE ' J di~'"-~ ._ i~_!9~~iUi_~~~,!t,~'iF"""",;(~~Wlli:lliI[,q!;!&j,1iiW!.,_~lIM'<~m..-~'~ '('\O) ~, ~ ,'~, ~= ft4l ,,'~ ,< ,,~_~ ~~",.'">l~",~' liHilI- ,="=, II' ~, G! ~ 0 = ~:;:. C,;) -n c-~ ~. "' , :r_~ -l d; -,,:;. :J':-n m- ::0 , -'0 fTi , ::'1:) Y cr> ,~, ::-.::.::( Cl I 'Ti -a -r, _1:'- C) n , 1~jm ~:7:. r:? -"\ "~ ;J> ~.~1 U1 :n ---<: -< ",,,.,_..,-,,,,,,,,,o-,,,,'f,~,,,,,,,,,,,"~,,.,,J.mJ_l~;, ."L ",~j'~,f;- ~~ ,-- O' r , -", ,,- " ""," 1"',<'.,,',,,",-'-.., """,; J'_~'-",,, ~-,''' -, ~'. '-',';';: :-,<''''~-''-~'.;-;:-:~,-':~::';,:,:;.,_.. '.:.0_, . D;'; ;, MANDY S. CLARK, Petitioner t- ~ v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW JACK R. KNIPE, Respondent : NO. 01-3780 CIVIL : IN CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Mandy S. Clark, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date L{(rOf.t ~.?J~ ROBERTE THOMAS . PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ~~ 'ii~-~;;\ilii!lW~m_u"'-;'l.o~i~~~~illt'""=""'''''ilj\i;#'-'i~,h&;1ft$i%'~~-~~~;,,.il.' '"-"' .."~ '~~ 'u -- " ., - co -"~ , ~- '""'" '''j'l , L~J,O-C{o Ca.lled Lindo. Lhrver tor:;' fi'Lm i I ~ laLlD Clu0,L - f\le~j lDi II fY\CL~~ the -r\lDLDi n') c'nzu1'(fs CR- c~lA.r-~, doc.LLm€.yd's. '. .i II.',:" .' , :; Jcu;lRkoipeJIt - piN M~.X'cl.L\ S I-Iel&t\ - 6ef\- \>tco Cl r--' 0 = c: C:? " CY'> " -t """ :C-n -0 :;v [l1p -Cl fJJ , "Ue} 0" (.~(L't =r~ ~I~ io..- (~??, ......... r:-? "" U1 "n <..c t'-) ::< t$L .,v., "'''_"'~~',,,"," ~, -~,'-~~., ,,~, ,~, ~"--""=..',,,,~,, .,~ m "" -' '~ "0 _, '~-"_ . ~ " _ ;00 _0, , _, ~*__, ~,_l' _-_l~' . ""='.'(;,.;.,-\, ;' ,','^' ,,-~ ,I ,', <,;,:? Jack R. Knipe, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION-LAW IN : CUSTODY Mandy S. Clark (Hewlett) , Defendant : NO. 01 - 3780 CIVIL TERM CERTIFICATE OF SERVICE I, Lauren McHale, Certified Legal Intern, Family Law Clinic, hereby certifY that I served a true and correct copy ofthe Praecipe to Withdraw Petition to ModifY Custody on Mr. Jack Knipe, residing at Cumberland County Prison, 1101 Claremont Road, Carlisle, PA 17013, by depositing a copy of the same in the United States mail, postage prepaid. ~! J J114ki~ I!auren11cfIale Certified Legal Intern F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle,PA 17013 (717) 243-2968 Fax: (717) 243-3639 i'~~i~~;mI'..roill!1IiJirEil:llli!,1;j~.~.;tf~.aw!lwW!a""",!-~c:;lW~'i'-!~"'h:k';iI>i"(lllJili'mailkilrool~1J!~--'-'-"~" - - "",,~, ~" ,~^, "_,"0, " _~~, v.- ".-~-,~~- ~~\; "'" ,.- r:-? ,,",~,,,, '" t t-':' , ~~ : ~: I:,,' j ~ i ii,:," " . Ii I I I '''' C:) '.-::::;' '_:-:.r-, C) 'TI ~-:! :J""Ti rn r~~1 ~C5t?] -,- '--"f"'-' ,- ,..; ~,~,' -:,~, ~) 25 ~jrn -,' ~, :Xi -< ---<:.. en - ,.:C." -'C' --^',"'- '''d'' ~ ' i;:;'_,-' '<"I' .< '--<,cO;; f '--cr', Jack R. Knipe, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. DOMESTIC RELATIONS SECTION CNIL ACTION - CUSTODY Mandy S. Clark (Hewlett), Defendant DOCKET # 01-3780 PRAECIPE TO WITHDRAW PETITION TO MODIFY CUSTODY To the Prothonotary: Please allow Mandy Clark (Hewlett) to withdraw the Petition to ModifY Custody filed with the court on April 24, 2006, 'DcJeol: MaJ I} 1.DOb ~ fJ~n , 0f01 IW !tl I;auren McHale Certified Legal Intern <Kd4-~ ~ THOMAS M. PLACE ROBERT E. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX WILLIAM G. MARTIN Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Fax: (717) 243-3639 )' :JI.;-" '~'r~";';;->o""'~ .\lljti~Ii!Wh1~1iti~~iiiPJC-"'*~it:iilU"""lI!l!i~f~:J.~~~"""""'~l'L.~ ~ ltilJ - _0. ".-",-,-' ~- ;"" ,;",.,.,,-,,> " :d I I I ! t i ! ~ ! I I ,.....:l ~~:-.J 0" l.~) ',1 ::'; f~ldJ -:-;C0 '--,,",,..1 '';0 , ..j(~, ~ ,__--r-i ;: ~; :(~:. ;:.~. rn ~;~ ~ ~ (i\ ~ , " ~ ',",',' ' ,,",.","' -, h...~ "'-"""',:",,,.C- ',,,-." ""'~-'1i,"',_j,^-h_'~'- ",'," ,,,-~.~" ' ,~~~ REf:~i'c'~;-~"\"'~\/ :;'I,fL..- MANDY S. CLARK, Plaintiff MAV (I , )IJUb c, "'" _. "". ..--'i. .. IN THE COURT OF COMMO .J CUMBERLAND COUNTY, PENNSYLVANIA v CML ACTION - LAW JACK R. KNIPE, Defendant NO. 01-3780 IN CUSTODY COURT ORDER ./4- AND NOW, this ~ day of May, 2006, The Conciliator being advised that the Petition to Modify Custody has been withdrawn, the Conciliator relinquishes jurisdiction. >'i ~,&qw. Custody Conciliator j"," '". " :~' ;; i;; ~- 1,-: :" ", ": ,; ~, r r,' >, w ,- <,"_',;,C ,,~, "5-""'~ ",__'~n ~_O" ' ~=~"""',":"" " ,'qlrnUIi, r n,rmf'j'Jrrml'l?'!ll"EI"Ii"T""",; " ("'\~icr~ ....v-v'r'r ~ L. F~LFf,n"IHCh\\01NW OF 1\-\;;. ,,,., ' U;\'O' 03 2nn~ l'\~ ~ i 0 fill \ . ...~,'JH1Y '_', ", _'; ",', \ !l,j\.." \ . CU\'~b~~ ~~<;:~I\ \1 ~.\\\\/\ Pt.t ,),\',i~ \ _~J '.- (', '~1q <;g y i I . . , ! r Ii i 'I' " Ii :1 II ,I; fi " q lr " d ~ ''''";-" ~,~~ , Iii; -- 7-'-".c'~"'T',""'11l.:,."., ,:"+~'Ifi^"'~:~~~~;;;~-~'~~~~~~~~~l!i'WlW*\";:~, JACK R. KNIPE, III, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA VS. DEFENDANT CIVIL ACTION - LAW CUSTODY/VISITATION c r- _ C r'l c' `ma c? ) -a o rs C -u x- > C- rv (D 71 MANDY S. CLARK, NO. 01-3780 CIVIL TERM PETITION FOR CONTEMPT OF CUSTODY ORDER 1. Petitioner is Mandy Clark who resides at 310 Roby Avenue, East Syracuse, New York 13057. 2. Respondent is Jack Knipe who resides at 232 W. Locust Street, Apartment A, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. On March 31, 2004, the Honorable Edward E. Guido entered the following order: a. Primary physical custody of Alyssa Knipe to father, subject to periods of partial physical custody with mother as follows: every other weekend to correspond with mother's days off from work, from Friday at 6:00 p.m. until Sunday at 6:00 p.m. b. On her other days off from 9:00 a.m. until 5:00 p.m., so long as mother gives at least seven (7) days notice of her intention to exercise said visitation. c. On holidays as agreed by the parties, and absent agreement, every other holiday to be shared by the parties. d. Such other times as the parties may agree. C'&OZ 4. Since the entry of said order, the respondent has willfully failed to obey said order as follows: a. Respondent kept Alyssa Knipe from Petitioner for five (5) years without notifying Petitioner of the whereabouts of the child. b. Respondent agreed in May, 2010, for Petitioner to call Alyssa Knipe every Friday at 9:00 p.m. for three (3) months, after which time he would think about a visitation. When Petitioner's work schedule changed, Respondent agreed to allow Petitioner to call Alyssa Knipe every Thursday at 6:00 p.m. and every Sunday at 8:30 p.m. Petitioner has never missed a phone call with Alyssa Knipe; however, Respondent has still failed to allow contact between Petitioner and Alyssa Knipe. c. Respondent agreed to allow a weekend visitation with Petitioner from Friday, August 20, 2010, until Sunday, August 22, 2010, then sent Alyssa Knipe to a friend's house for the weekend. On Saturday, August 21, 2010, Petitioner tried to contact Respondent about the visitation, but Respondent refused to answer his phone. Petitioner drove to Respondent's house in Harrisburg, Dauphin County, Pennsylvania, and Respondent started screaming at Petitioner and threatened to keep Alyssa Knipe away from her forever. Petitioner called the Harrisburg Police and Officer Olivier responded to her call. Officer Olivier contacted Respondent and Petitioner finally got to see Alyssa for the first time in five (5) years on Monday, August 23, 2010, from 10:00 a.m. until 7:00 p.m. d. Petitioner gave Alyssa Knipe a laptop computer so they could keep in touch with each other. Respondent uses the computer as his own and does not allow Alyssa Knipe to access her email account. e. Petitioner gave Alyssa Knipe a cellular phone which Petitioner pays for so they could call and text each other due to father's inability to keep a home telephone. Respondent took the phone from Alyssa Knipe and will not allow her to use it to contact Petitioner. f. Petitioner has repeatedly asked Respondent for visitation during holidays. Respondent refuses to give a definite answer regarding such visitation. Petitioner has not had custody of Alyssa Knipe for any holiday in the past five (5) years. 5. Because Petitioner now lives outside Pennsylvania, Petitioner asks this court to modify the custody order with mother having physical custody one weekend per month from Friday at 6:00 p.m. until Sunday at 6:00 p.m. and be allowed to take Alyssa Knipe to her home in New York for said weekends. Petitioner further requests this court to allow her primary physical custody during the summer months when Alyssa Knipe is not in school. WHEREFORE, Petitioner prays this court to adjudge the respondent in contempt of court and order appropriate sanctions. h 2Ce ro,btr 2UI O DATE PETITIONER I verify that the statements made in this petition are true and correct. I understand that false statements herein are made subject to the penalties of PA. C.S.A. Section 4904 relating to sworn falsification to authorities. De.C wkff 5, uir) DATE PETITIONER JACK R. KNIPE, III, PLAINTIFF VS. MANDY S. CLARK, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CUSTODY/VISITATION NO. 01-3780 CIVIL TERM CERTIFICATE OF SERVICE I, Mandy S. Clark, Petitioner, certify that I am serving a true and correct copy of a Petition for Contempt of Custody Order on the following person by first class, postage prepaid, this 5 day of b 0 C1tyu'Lze, '2010. Jack R. Knipe, III 232-A W. Locust Street Mechanicsburg, Pennsylvania 17055 MANDY . C 310 Roby Avenue East Syracuse, NY 13057 315-706-4284 JACK R. KNIPE, III, PLAINTIFF VS. MANDY S. CLARK, DEFENDANT IN THE COURT OF COMMON PLE ` j CUMBERLAND COUNTY, PENNSUVA39A --i to xm ? r - - r ,, rnn CIVIL ACTION - LAW -<> ° SCc ?a CUSTODY/VISITATION ? =CJ rv Dr _r r_n NO. 01-3780 CIVIL TERM PETITION TO MODIFY CUSTODY ORDER 1. The Petitioner, Mandy S. Clark, respectfully represents that on March 4, 2004, an Order of Court was entered for Alyssa Knipe (child), born November 3, 2000. A true and correct copy of this Order is attached as Exhibit A. 2. The Order grants Respondent (Father) legal and physical custody of the child and grants Petitioner (Mother) periods of temporary custody at times agreed upon by the parties. 3. As per the March 31, 2004 Order, Father was granted primary physical custody of the child. Mother was granted partial custody of the child. Mother is to have physical custody of the child on alternate weekends from Friday at 6:00 p.m. to Sunday at 6:00 p.m., on her other days off from work from 9:00 a.m. until 5:00 p.m., and every other holiday. 4. The prior Custody Order should be modified because: a. Child's hygiene is not kept up with. Father does not allow her to bathe every day, and only when the Child asks. A school official called Children & Youth Services due to her clothing smelling like dog urine and being damp. b. A second call was made to Children & Youth Services because there was no running water in the residence they lived in at the time. c. Petitioner gave Child a Gateway laptop and set up an email account so Child and Petitioner and her family could communicate via email. Respondent does not allow Child to use said laptop, but Respondent and his girlfriend use the laptop at their discretion. d. Petitioner gave Child a cellular phone which Petitioner is paying for so Child and Petitioner and Petitioner's family could communicate via cell phone. Respondent has accused Petitioner of disrupting his life because she calls Child. Respondent has further accused Petitioner of tying up his phone line during calls to Child. Respondent has taken the cell phone from Child and uses it at his discretion, calling the same number between 10:00 p.m. and 3:00 a.m. e. Respondent refuses to allow Petitioner access to Child. f. Respondent does not update Petitioner on Child's medical and academic records. g. Respondent is not following current Custody Order. Respondent informed Petitioner the current Custody Order is no longer valid because it is too old. h. Respondent does not provide medication to Child when she is sick. L Respondent belongs to a "biker gang" and is sergeant of said gang. j. Obscenities are yelled in the presence of Child. k. Respondent allows Child to watch detrimental shows. 1. Respondent allows Child to stay up later than 10:00 p.m. on school nights. m. Respondent does not provide clothing that fits Child. Child only had clothing to wear that was given to her; however, said clothing did not fit Child. n. Child's dinners are served late at night, at 8:00 p.m. or later. o. Petitioner has paid child support for Child since 2002. p. Child broke her glasses five (5) years ago. The glasses were recently replaced by Respondent's mother. q. Respondent lives in a one-bedroom apartment with Child, Respondent's girlfriend, and her son. r. Petitioner lives in a four (4) bedroom house. s. Petitioner has sent Child money and Respondent has taken it for his own use. t Respondent is currently on probation in two (2) separate counties, and is behind in his payments. u. Respondent and guests smoke in the Child's presence. 5. It is understood that if the Child is placed in Mother's primary physical custody that all of Child's clothing and belongings, including toys, drawing supplies, laptop and cell phone stay with the Child. 6. Petitioner begs the Court to take the Child into an office without either parent present and ask the Child who she wants to reside with. WHEREFORE, the Petitioner prays this Honorable Court will give full primary physical custody of said Child to Petitioner. MAN S. 4CRK, Petitioner JACK R. KNIPE, III, PLAINTIFF VS. MANDY S. CLARK, DEFENDANT . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CUSTODY/VISITATION NO. 01-3780 CIVIL TERM CERTIFICATE OF SERVICE I, Mandy S. Clark, Petitioner, certify that I am serving a true and correct copy of a Petition to Modify Custody Order on the following person by first class, postage prepaid, this 5 day of '1N0 C0,M QX'- -------,2010. Jack R. Knipe, III 232-A W. Locust Street Mechanicsburg, Pennsylvania 17055 MAND S. C K 310 Roby Avenue East Syracuse, NY 13057 315-706-4284 III KNIPE JACK R IN THE COURT OF COMMON PLEAS OF r-) c ? , . INTIFF tOl? PENNSYLVA CUMBERLAND COUNTY PLA M , M ° rn_ r~ c -urn V. 2001-3780 CIVIL ACTION LAW ?3> a' °Q sa o MANDY S. CLARK USTODY IN C DEFENDANT ? p ? ORDER OF COURT AND NOW, Thursday, December 16, 2010 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on _ Friday, January 14, 2011 at 10:30 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. 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: /s/ Hubert X. Gilroy, Esg. A? Custody Conciliator r- 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 32 South Bedford Street ?l Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 r s ,?3 JACK R. KNIPE III, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW 1011 A 20 Pfd I 45 MANDY S. CLARK, NO. 2001-3780 Defendant IN CUSTODY COURT ORDER NOW,this O" 114rday of January, 2011, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that this Court's prior Order of March 31, 2004, shall remain in place subject to the following additional provisions: Mother shall have custody of the minor child Alyssa N. Knipe on the weekend of January 14, 2011, from 6:00 p.m. on Friday until 6:00 p.m. on Sunday. 2. Starting February and continuing for February, March, April and May, Mother shall have custody of the minor child on the first weekend of every month unless the parties agree between themselves for a different weekend. The time shall be from Friday at 6:00 p.m. until Sunday at 6:00 p.m. 3. Mother's periods of custody outlined above shall be exercised at the Maternal Grandmother's home in Dillsburg. It is specifically directed that for the time being, the Mother shall not take the child out of state. However, assuming the custody schedule set forth in this Order proceeds without problems, it is anticipated that Mother's period of temporary custody will be expanded subject to further proceedings. 4. Mother shall have reasonable telephone access with the minor child to speak with the child at least one time per day subject, however., to the phone calls not being after 9:00 p.m. in the evening. 5. Mother shall enjoy email access with the minor child on the laptop computer which Mother has provided to the minor child subject to the ability of the minor child to gain access to the internet at her current home. 6. The parties shall meet again for a custody conciliation conference on Thursday, May 5, 2011, at 8:30 a.m. a ? c BY T RT,? Zrn z rn -0m r ? F-A N ©C o-n Edward E.. Guido, Judge v ? a cc: Paul B. Orr, Esquire t I ll ?? Nm /Ms. Mandy S. Clark n f I/ 1 JACK R. KNIPE III, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW MANDY S. CLARK, NO. 2001-3780 Defendant IN CUSTODY Prior Judge: The Honorable Edward E. Guido CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Alyssa N. Knipe, born November 3, 2000 2. A Conciliation Conference was held on January 14, 2011, with the following individuals in attendance: the father, Jack R. Knipe, III, with his counsel, Paul B. Orr, Esquire, and the mother, Mandy S. Clark, who appeared without counsel. 3. Based upon the recommendation of the custody Conciliator, the parties agreed to the entry of an Order in the form as attached. Date: January , 2011 Hubert X. G' oy, Esquire Custody C ciliator J JACK R. KNIPE III, Plaintiff vs. MANDY S. CLARK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENN&'L-1i:&NR = CIVIL ACTION - LAW xm 3:0- -+ mrF: "K r- ro -vm Mm ° NO. 2001-3780 -'<3'' --+ca IN CUSTODY *c' -? -mn w rn COURT ORDER r- NOW, this C day of May, 2011, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that this Court's prior Orders of March 31, 2004 and January 21, 2011 are reaffirmed subject to the following modifications: 1. Mother's alternating weekends pursuant to paragraph 2 of the January 21, 2011, order may be exercised in New York State where the mother lives. 2. Mother shall have custody of the minor child during the upcoming summer from June 19 to July 17 and, assuming there are no problems with mother's first period of custody during the summer, she shall also have custody from August 14 through August 21. Mother shall handle transportation for exchange of custody. 3. The parties and their legal counsel shall conduct a telephone conference with the Custody Conciliator on Thursday, September 1, 2011, at 8:00 a.m. The matter to be resolved at this conference is a holiday schedule for the upcoming school year. BY a?le? cc: ? Paul B. Orr, Esquire 'GMs. Mandy S. Clark CpP,? a}??? 5? Edward E. Guido, Judge N 90 JACK R. KNIPE III, Plaintiff VS. MANDY S. CLARK, Defendant NO. 2001-3780 IN CUSTODY Prior Judge: The Honorable Edward E. Guido IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Alyssa N. Knipe, born November 3, 2000 2. A Conciliation Conference was held on May 11, 2011, with the following individuals in attendance: The father, Jack R. Knipe, III, with his counsel, Paul B. Orr, Esquire, and the mother, Mandy S. Clark, who appeared without counsel. 3. The parties agree to the entry of an Order in the form as attached. Date: May 2011 ?-h Hubert X. Gilroy, Es ire Custody Conciliat JACK R. KNIPE III, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND CONY, PENNSYLVANIA CIVIL ACTION - LAW vs. MANDY S. CLARK, NO. 2001-3780 IN CUSTODY Defendant ORDER AND NOW, this ?1 L day of October, 2011, the Conciliator being advised the parties , have reached an agreement, the Conciliator relinquishes jurisdiction. Hubert X. C/Iroy, Esquire Custody nciliator M o ' r- cn -e' > -- w m C5m r -z: rt .fir Y" may, ......