HomeMy WebLinkAbout01-03804
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JUL 2 0 2001
IN THE COURT OF COMMON PLEAS OF 6>>1
CUMBERLAND COUNTY,PENNSYLV ANIA
: NO. 2001-3804 CIVIL TERM
HEATHER R. HUNTER,
Plaintiff
CORBETT L. BAKER,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this ':1.? day of Jd., ,2001, upon
consideration of the attached Custody Conciliation Rep~it is ordered and directed as
follows:
1. The Mother, Heather R. Hunter, and the Father, Corbett 1. Baker, shall
have shared legal custody of Hailie R. Baker, born August 1, 1999. Each parent shall
have an equal right, to be exercised jointly with the other parent, to make all major non-
emergency decisions affecting the Child's general well-being including, but not limited
to, all decisions regarding her health, education and religion.
2. Mother shall have primary physical custody ofthe child.
3. Father shall have periods of supervised custody under the following
conditions:
A. Beginning August 5, 2001, provided Father can obtain a contact visit
from the Cumberland County Prison, for forty-five (45) minutes,
between the hours of 1 :00 p.m. to 4:00 p.m., and alternating Sundays
thereafter.
B. Father shall confirm with counsel for Mother that the contact visit is
authorized by the prison and at what time the visit should take place.
C. The supervisor shall be the child's paternal grandmother, Evelyn
Goodling. Father is responsible for contacting the Grandmother to
arrange the visit. Grandmother shall meet Mother at the prison and
supervise the contact visit.
D. In the event Grandmother is unwilling or unable to supervise said
visits, then an alternate supervisor, as agreed by the parties, shall
supervise the visits under the above conditions.
4. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control.
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cc: Michelle 1. Anderson, certified legal intern, for Mother
Teri 1. Henning, Esquire, Family Law Clinic
Corbett 1. Baker, pro se
Cumberland County Prison
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HEATHER R. HUNTER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYL VANIA
V.
: 2001-3804 CIVIL TERM
CORBETT L. BAKER,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
PRIOR JUDGE: None
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
Hailie R. Baker
August 1, 1999 Mother
2. A Conciliation Conference was held in this matter on July 18, 2001, with
the following individuals in attendance: Mother, Heather R. Hunter, was present with her
counsel, Michelle 1. Anderson, certified legal intern of the Family Law Clinic, and Teri
1. Henning, Esquire, supervising attorney. Father, Corbett 1. Baker, was present pro se.
3.
The parties agreed to an Order in the form as attached.
1-/9-01
Date
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acq line M. Verney, Esquire
Custody Conciliator
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HEATHER R. HUNTER
PLAINTIFF
V.
CORBETT L. BAKER
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
01-3804 CIVILACTIONLAW
IN CUSTODY
ORDER OF COURT
AND NOW,
Tuesday, June 26, 2001
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqneline M. Verney, Esq. ,the conciliator,
at 4tb Floor, Cumberland County Courthouse, Carlisle on Wednesday, July 18, 2001 at 2:30 p.m.
,
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to derme 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 herehy directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to tbe conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: Isl
Jacqueline M. VernlO'. Esq:&9
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabi1ites 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
HA VB 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
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HEATHER R. HUNTER,
Plaintiff
JUN 2 1 20~
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v
v.
: CNIL ACTION - LAW
: IN CUSTODY
: NO.OI-3~lj
CNIL TERM
CORBETT 1. BAKER,
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, , the conciliator, at on
the day of ,2001, at m.,foraPre-HearingCustody
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.
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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities 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.
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HEATHER R. HUNTER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CNIL ACTION - LAW
: IN CUSTODY
CORBETT L BAKER,
Defendant
: NO. tP/_ 3 fo '/ CNIL TERM
COMPLAINT FOR CUSTODY
The plaintiff, Heather R. Hunter, by her attorneys, the Family Law Clinic, sets forth the
following cause of action:
1. The plaintiff is Heather R. Hunter, residing at 72 "R" Winter Lane, Enola,
Cumberland County, Pennsylvania 17025.
2. The defendant is Corbett 1. Baker, currently incarcerated at Cumberland County
Prison, Carlisle, Cumberland County, Pennsylvania.
3. Plaintiff seeks sole legal and physical custody of the following child:
Name
Hailie R. Hunter
Present Residence
72 "R" Winter Lane
Enola, PA 17025
Date of Birth
8/01/99
The child was born out of wedlock.
The child is presently in the custody of Heather R. Hunter, who currently resides at 72
"R" Winter Lane, Enola, Pennsylvania.
During the past five years, the child has resided with the following persons and at the
following addresses:
Persons
Heather R. Hunter
Addresses
72 "R" Winter Lane
Enola, PA 17025
Dates
May 2001 to present
Heather R. Hunter,
Christy Hunter
113 S. Hanover Street
Carlisle, PA 17013
August 2000 to May 2001
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Heather R. Hunter,
Mary Louise Phenicie
Shippensburg, PA
July 2000 to August 2000
Heather R. Hunter,
Robin Harmon
Plainfield, P A
April 2000 to July 2000
Heather R. Hunter,
Ed and Daphne Brinkley
Hertford, NC
March 2000 to April 2000
Heather R. Hunter, 15 "C" Creekside Lane
Leanna Hoff, Michael Baker Carlisle, P A 17013
October 1999 to March 2000
Heather R. Hunter,
Corbett L. Baker
(for only two weeks
in August)
73 E. North Street
Carlisle, PA 17013
August 1999 to October 1999
The mother of the child is Heather R. Hunter, currently residing at 72 "R" Winter Lane,
Eno1a, Pennsylvania, 17025.
She is single.
The father of the child is Corbett 1. Baker, currently incarcerated at Cumberland County
Prison, Carlisle, Pennsylvania.
He is single.
4. The relationship of plaintiff to the child is that of mother. The plaintiff currently
resides with the following persons:
Name
Hailie R. Hunter
Relationshiu
Daughter
5. The relationship of defendant to the child is that of father. The defendant
currently resides with the following persons: Unknown
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 in this or
another court of this Commonwealth or any other state.
Plaintiff does not know of a person not a party to the proceedings who has physical
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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 because:
a) Plaintiff is the primary caretaker of the children;
b) Plaintiff provides the child with a stable home environment with adequate
moral, emotional, and physical surroundings as required to meet the child's needs;
c) Plaintiff is willing to accept custody of the child;
d) Plaintiff continues to perform the parental duties and enjoys the love and
affection of the child.
8. Bach parent whose parental rights to the child have not been terminated and the
person who has physical custody of the child have been named as parties to this action.
WHEREFORE, plaintiff requests the court to grant her sole physical and legal custody of
the child.
Respectfully Submitted,
Date: Jm 1C1 wi
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GMichelle 1. Anders
Certified Legal Intern
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Thomas M. Place
Robert B. Rains
Teri 1. Henning
Supervising Attorneys
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
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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. {}4904 relating to unsworn
falsification to authorities.
Date: ~~. 1'-1. () I
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HEATHER R HUNTER,
Plaintiff
JUN 2 1 2~
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION-LAW
CUSTODY
CORBETT 1. BAKER,
Defendant
: NO. 01- 380'1
CIVIL TERM
PRAECIPE TO PROCEED IN
FORMA PAUPERIS
To the Prothonotary:
Kindly allow Heather R Hunter, Plaintiff, to proceed in forma pauperis.
I, Michelle 1. Anderson, Certified Legal Intern in the Family Law Clinic, for the party
proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am
providing free legal service to the party. The party's affidavit showing inability to pay the costs of
litigation is attached hereto.
Date:~ to, t).061
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Certified Legal Intern
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RT E. RAINS
THOMAS M. PLACE
TERI 1. HENNING
Supervising Attorneys
THE FAMILY LAW CLIN1C
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
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HEATHER R. HUNTER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: CUSTODY
CORBETT 1. BAKER,
Defendant
: NO. 01-
CIVIL TERM
AFFIDAVIT SUPPORTING PRAECIPE FOR LEAVE
TO PROCEED IN FORMA PAUPERIS
1. I am the Plaintiff in the above matter and because of my financial condition am
unable to pay the fees and costs of prosecuting or defending the action or proceeding.
2. I am unable to obtain funds from anyone, including my family and associates, to pay
the costs oflitigation.
3. I represent that the information below relating to my ability to pay the fees and costs
is true and correct.
(a) Name: Heather R. Hunter
Address: 72 "R" Winter Lane, Enola, P A 17025
Social Security No.: 196-68-3941
(b) Employment
If you are presently employed, state
Employer: Drexel Group
Address: 4815 Jonestown Road, Ste. 201, Harrisburg, P A 17109
Salary or wages per month: $9.00 per hour @ 20 hours per week
Type of work: Administrative Assistant I Temporary
If you are presently unemployed, state
Date oflast employment:
Salary or wages per month:
Type of work:
(c) Other income within the past twelve months
JFC Staffmg June2000 to November 2000
Business or profession:
Other self-employment:
Interest:
Dividends:
Pension and annuities:
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Social security benefits:
Support payments:
Disability payments:
Unemployment compensation and supplemental benefits:
Workman's compensation:
Public Assistance:
Other:
(d) Other contributions to household support
(Wife)(Husband) Name:
If your (wife)(husband) is employed, state
Employer:
Salary or wages per month:
Type of work:
Contributions from children:
Contributions from parents:
Other contributions:
Property owned
Cash:
Checking account: Commerce Bank $4.33
Savings account:
Certificates of deposit:
Real estate (including home):
Motor vehicle:
Cost, Amount Owed $
Stocks; bonds:
Other:
Debts and obligations
Mortgage:
Rent: $356 per month
Loans:
Other:
(e)
(f)
Food: $330 per month
Electric: $50 per month
Phone: $45 per month
Cable: $30 per month
Child Care: $40 per week
Medical Expenses:
Persons dependent upon you for support
(Wife)(Husband) Name:
Children, if any:
Name:
Hailie R. Hunter
Age:
22 months
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Name:
Relationship:
4. I understand that I have a continuing obligation to inform the court of improvement
in my fmancial circumstances which would permit me to pay the costs incurred herein.
5. I verify that the statements made in this affidavit are true and correct. I understand
that false statements herein are made subjectto the penalties of 18 Pa. C.S. 4904, relating to unsworn
falsification to authorities.
Date o~';in . 0 I
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He ther R. Hunte, Petitioner
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HEATEER R. HUNTER,
Plaintiff
: IN TEE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN CUSTODY
CORBETT 1. BAKER,
Defendant
: NO. 2001-3804
CIVIL TERM
ACCEPTANCE OF SERVICE
I accept service of the attached Complaint for Custody.
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HEATHER R. HUNTER,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLV ANlA
v.
: CIVIL ACTION - LAW
: IN CUSTODY
CORBETT 1. BAKER,
Defendant
: NO. 2001-3804
CIVIL TERM
CERTIFICATE OF SERVICE
I, Michelle 1. Anderson, hereby certify that I am serving a true and correct copy of the
Acceptance of Service on the following person by depositing a copy of the same in the United
States Mail, postage prepaid, this 10th day of July, 2001:
Corbett 1. Baker
Cumberland County Prison
11 0 1 Claremont Road
Carlisle, PA 17013
~ t &wJ})f: ~M1-
~ichelle 1. Andeb-6'n
Certified Legal Intern
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
717-243-2968
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September 13, 2001
Corbett L. Baker
Cumberland County Prison
1101 Claremont Road
Carlisle, PA 17013
RE: HUNTER V. BAKER, 01-3804 CIVIL TERM
Dear Mr. Baker:
I am responding to the letter of September 10, 2001, that you wrote to Judge
Bayley. The judge cannot give you legal advice. You should seek the advice of
counsel, or if you are unable to afford counsel, you should contact the Cumberland
County Bar Association, 2 Liberty Avenue, Carlisle, Pennsylvania 17013.
Very truly yours,
Taryn Dixon
Assistant Court Administrator
rD:saa
OF
FILED-OFFICE THE PROTHONUT?
M R
2011 SEP - I Ph 3: 52
CUMBERLAND COUNTY
PENNSYLVANIA
HEATHER R. HUNTER
PLAINTIFF
V.
CORBETT L. BAKER
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-3804 CIVIL ACTION LAW
IN CUSTODY
MOTION TO MODIFY CUSTODY AND MOTON FOR CONTEMPT OF COURT ORDER
AND NOW, comes Defendant, Corbett L. Baker, and files the following Defendant's Motion to Modify
Custody and Motion for Contempt of Court Order and in support thereof avers as follows:
On or about July 23, 2001, this Court issued an Order which granted Heather R. Hunter (hereinafter
referred to as "Mother") primary Physical Custody of the minor child Hailie R. Baker (DOB 8/1/1999)
and granted Corbett L. Baker (hereinafter referred to as "Father") periods of temporary physical
custody whereby Mother was to meet paternal grandmother at the Cumberland County Prison
every other Sunday. Paternal grandmother was to supervise said visits. No such visits ever took
place.
2. In the same Order of Court, Mother and Father were granted Joint Legal Custody of said child.
3. To date, Father does not know anything about the child's health, schooling, and religion.
4. Father does not have an address or telephone number to contact said child.
5. Father has not heard anything from the Mother or child since 2001 when this Order was issued. ?.
4-70.00 PQ
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6. Father is now stable and living in Carlisle which is an appropriate place for said child to visit and
stay for visitation periods.
7. Mother refuses to allow Father to know anything about the child or to communicate with Father
about the child.
8. Father believes it is in the best interest of the child to modify the current Custody Order.
WHEREFORE, Father requests that a new Order be issued granting him periods of visitation with
said child.
MOTION FOR CONTEMPT OF COURT ORDER
9. Paragraphs 1 through 8 above as contained in their entirety.
10. According to the current custody order, Mother and Father are to have shared Legal Custody of
said minor child.
11. Mother refuses to contact Father with any School information regarding said minor child.
12. Mother refuses to contact Father with any Medical information regarding said minor child.
13. Mother refuses to contact Father with any Religion information regarding said minor child.
14. Mother refuses to notify Father of a current home address or telephone number.
WHEREFORE, Father respectfully requests that this Honorable Court:
a. Find Mother in Contempt of the current custody order;
b. Assess Mother a $500.00 penalty for contempt of the Court's Custody Order pursuant to 23
Pa.C.S. §4346;
c. Father's Motion for Contempt of Court Order should be addressed at a hearing before this
Honorable Court;
d. Other relief as this Court deems to be just and proper.
Respectfully Submitted,
Corbett L. Baker, pro se
150 D. Street
Carlisle, PA 17013
(717) 386-5778
HEATHER R. HUNTER IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
CORMT-T L. ISAKā¬R 01-2804 CIVIL ACTION LAw
DEFENDANT IN CUSTODY
VERIFICATION
I, Corbett L. Baker, hereby verify that I have reviewed the foregoing Motion to Modify Custody and for
Contempt of Court Order and verify that the facts contained herein are true and correct to the best of my
knowledge, information and belief. I understand that I can be liable under Pennsylvania and Federal Law both
civilly and criminally for any false statements contained therein.
Corbett L. Baker
HEATHER R. HUNTER IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
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2001-3804 CIVIL ACTION LAW zm M F
CORBETT L. BAKER
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IN CUSTODY
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DEFENDANT zo .
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ORDER OF COURT
AND NOW, _ _Wednesday, September 07, 2011 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, October 11, 2011 at 2:30 PM
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/ jacqueline M. VemeV, Esq. 0-
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
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HEATHER R. HUNTER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2001-3804 CIVIL ACTION - LAW
CORBETT L. BAKER
,
Defendant
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IN CUSTODY -.- -y 7,
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ORDER OF COURT
AND NOW, this 5th day of June, 2012, the Petitioner, having failed to properly
serve the Respondent and more than 180 days have passed since the first Conciliation
Conference was scheduled, the Conciliator hereby relinquishes jurisdiction in this matter.
FOR THE COURT,
V
Jac eline M. ?Veme?y,Esquire, Custody C nciliator