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Home My WebLink About01-03820 " , , '~"","~-i i ~. ., ALISHA R. WAMBOLDT PLAINTIFF V. BRAD A. PRICE DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-3820 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tnesday, June 26, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Snite 105, Camp HUI, PA 17011 on Monday, Jnly30, 2001 at 1:00 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 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 fnrnish auy 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/ Melissa P. Greevy. Esq. 6P 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 ~ ~~ '""''''"''''_......,ISl:l!llilllllIIlRl'~ ~ ,~.- <-~. -,'" '.. ,~-,., ~"--,"'''''"',,"-.'''"'',,.-&',,'i'J'"'''~~'''~ ~'_-"'.'"' , iii" '"ICftml"o",IlO "<' ..'- ~ ".ifF'!? B ;:', :rJ' '::1'-' I ,; ~ j, . t' .' ~ C' "r'- l;j~;C~~t<-j:,'\;i') I \j ~,1 It, 11\/ !".", "r:,'~' <-.I\-'U!\Jll j-'r:I~hJb tLVAi\JiA ?'c2g:01 W-~_~ Za?{ ~ t;,2~-OI ~~ ~ ~o dff' tvc}$'-6!/ c:~ ~ t;4~ ,ft" - OJ ~~'m~~~flI:~~ti1til'~('IIW\"l<'j!l:'\-~!\"fGf'f"~~!V'1'T;:: "T"'-""''';''''''''' -"Y~fP""t'i?~~;-;;')\,~~fi-1""11'"~I;:<W'}!!if:'*JiM~!ij!IlliI~~'-w_1,l11.~f~~ .' , , . -",,'1 ,'. -.,',_0" ,~_,,~ , "'il ALISHA R. WAMBOLDT, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01- 3J'~ G~:C~ BRAD A. PRICE, Defendant : CIVIL ACTION - LAW : CHILD CUSTODY ORDER AND NOW, this _ day of ,2001, in consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel, shall appear before , the Conciliator, on the _ day of , 2001, at _.m., at 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 and older may also be present at the conference. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT: Date: By: Custody Conciliator YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 , J., ALISHA R. WAMBOLDT, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLANDCOUNTY, PENNSYLVANIA v. : NO. BRAD A. PRICE, : CIVIL ACTION - LAW : IN CUSTODY Defendant NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree in Divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. . IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO ANY OF THEM. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 Telephone: (717) 249-3166 . ";"^' .'A_'. [:1 . ". ~., ~~, ~ . "-.' ,'",'-:" '" < -''''j@, , . ALICIA R. WAMBOLDT, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLANDCOUNTY, PENNSYLVANIA : NO. BRAD A. PRICE, Defendant : CIVIL ACTION - LAW : CHILD CUSTODY COMPLAINT FOR CHILD CUSTODY AND NOW comes the Plaintiff, Alicia R. Wamboldt, by and through her attorney, Kristin R. Reinhold, Esquire, and respectfully requests this Honorable Court award her custody of the subject minor child, and in support thereto, avers the following: I. Plaintiff is Alisha R. Wamboldt, an adult individual residing at 623 Herrin Lane, Enola, Cumberland County, Pennsylvania. 17025. 2. Defendant is Brad A. Price, an adult individual residing at 149 Border Lane, Hershey, Dauphin County, Pennsylvania. 17033. 3. The subject child is Summer Rayne Price, born March 20, 2001. 4. The relationship of the Plaintiff to the subject minor child is that of natural mother. 5. The relationship of the Defendant to the subject minor child is that of natural father. .-'."" 6. The minor child has resided at the following addresses, in the custody of the following individuals: A. From March 20, 2001 to May 21, 2001, the subject minor child resided at 623 Herrin Lane, Enola, Cumberland County, Pennsylvania in the care and custody of both parents. B. From May 21,2001 to present, the subject minor child has resided at 623 Herrin Lane, Enola, Cumberland County, Pennsylvania in the care and custody of the Plaintiff/Mother. 7. There have been no prior actions for custody of the subject minor child in this or any other jurisdiction. 8. The Plaintiff is not aware of the existence of any other individuals who have any type of claim whatsoever regarding the custody of the subject minor child. 9. The Plaintiff believes and therefore avers that she is much better able to meet the needs of the subject minor child than the Defendant. 10. The Plaintiff believes and therefore avers that it is in the best interest of the subject minor child that she be placed in her legal and physical custody. ~- ~ - i.. ",,"~.k-,; "~--'" '0 ~_;j , , WHEREFORE, Plaintiff requests this Honorable Court award her custody of the subject minor child. Respectfully submitted, THE LAW OFFICE OF SILLIKER & RE OLD I' _. Attorney for Plaintiff ." " . .. , . " ~MUl' - ~""l AFFIDA VIT I, (} \ \.-:.""''''' W",,~\-.c. ~ hereby certify that the aforegoing is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. 4909 relating to unsworn falsifications to authorities. Dated: :::-... A\(l, 'T\. 2.0Cl \ o..~~ . ;",j ..r ~" 'cC' -'..iit' Plaintiff AUG 0 2 2001 IN THE COURT OF COMMON PLEAS OF ~ CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3820 A J ALlSHA R. WAMBOLDT, vs. BRAD A. PRICE, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this , ~ day of August, 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal,Custody The parties, Alisha R. Wamboldt, and Brad A. Price, shall have shared legal custody of the minor Child, Summer Rayne Price, born March 20, 2001. 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 regilrding her health, education and religion. Pursuant to the terms of Pa. C. S. S 5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Mother shall have primary physical custody. Father shall have visitation at Mother's home at such times as the parties may agree during the month of August 2001. Effective August 31, 2001, Father shall begin the following schedule of partial custody: A. Alternate weekend time: Friday evenings from 5:00 p.m. until 8:00 p.m., Saturday and Sunday from 10:00 a.m. until 6:00 p.m. B. Other such times as the parties may agree. C. Effective January 4, 2002, Father's custodial time shall be changed to be alternate weekends from Friday at 5:00 p.m. until Sunday at 7:00 p.m. and at such other times as the parties may agree. 3. Holidays. A. Christmas 2001 shall be shared by the parties as they shall agree. Effective 2002, Christmas shall be shared on an AlB schedule. Segment A shall be from December 24th at 6:00 p.m. until December 25th at Noon. Segment B shall be from December 25th at Noon until December 26th at fj' , '~~'~"'U~ ~ ~~c ","' ',"" _", ..,',,_ _",;_",," ~ I~,._ ,~, v ="","" ~"'_ -. ..",~, "^' 'J,',,";" 1 Y If'''t ~:flii(h'Wtii@" 1f~~"'1f'~i~tt"hr~'J11~-,~~~~'-'-41~Tur mlr' J'r'~ ,]' 'lit~H~~'f,:tlc'\l O.~ - .F./LEL.i....Or:'P.Y'E ;- ; f..:t' Gn."'\"", v " ,. ,~u" i ;-F,'d'''''"AR' Y ',J";,.Ju 01 AUG -6 Mill: 35 CUMBJR1J\t',i) CQUlIJTY PeNNSYLVANIA ' I~~ ,~~" _""",,~";f1111 """"""jiI~N",Wt~;""YH"":!"""tI .:...:-,~~,;"',O'"-lf'~"ol'-'f"!"i"_"9,,,";,"',%f\#'''avjll~'I.'H)i\1W~~;;iff~m'il'<!ilij;,lj:%fI:'if''IJ:i!!1:ffl~ , , l"., -~. """ c , '" ~<' , " ~~~~"J, . . No. 01-3820 Civil Term 6:00 p.m. Effective 2002, in even-numbered years, Mother shall have Segment A and Father shall have Segment B. Effective Christmas 2003 and subsequent odd-numbered years, Father shall have Segment A and Mother shall have Segment B. B. Other holidays shall be shared by the parties as they may agree. 4. Father shall begin anger-management counseling and shall begin this process during the month of August 2001. 5. The parties shall follow the pediatrician's recommendations with regard to the appropriate sleeping arrangements, diet and care for the parties' Child. The parties shall endeavor that the physician's recommendation be followed by other such adults who may have temporary care of the minor Child. 6. Counsel for either party may request an additional Custody Conciliation Conference within sixty days of the date of this Order. BY THE COURT, J. Dis!: Kristin R. Reinhold, Esquire, 5922 Linglestown Road, rrlsburg, PA 17112 Max J. Smith, Jr., Esquire, PO Box 650, Hershey, PA 17033 .) ~~ 0-01 " I -~, ' '''' '" ,'. . --, "" '.: ~~ ,I I I : i I i Plaintiff AUG 0 2 200~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3820 . I AlISHA R. WAMBOLDT, vs. BRAD A. PRICE, Defendant CIVIL ACTION - LAW CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Summer Rayne Price March 20, 2001 Mother 2. A Custody Conciliation Conference was held on July 30, 2001, with the following individuals in attendance: the Mother, Alisha R. Wamboldt, and her counsel, Kristin R. Reinhold, Esquire; the Father, Brad A. Price, and his counsel, Max J. Smith, Jr., Esquire. 3. The part;e, ",,""ad B" a,rnemem ;" the Q Ome' a, alla,he'. 1f/0I/0! ~~,ei Custody Conciliator Date