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HomeMy WebLinkAbout01-04342ISACC M. COLE : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA V. YVONNE A. COLE N0.2001- 4342 CIVIL TERM CIVIL ACTION -CUSTODY ORDER OF COURT AND NOW, this 20TH day of AUGUST 2001, the conciliator, Sheriff and/or the authorities at SCI-Albion are directed to make arrangements to allow Plaintiff to participate by telephone in the pre-hearing custody conference scheduled for FRIDAY, AUGUST 24, 2001, at 9:30 a.m. in COURTROOM # 5. Hubert X. Gilroy, Esquire Sheriff Thomas Kline SCI -Albion Albion, Pennsylvania 16475 By th urt, Edward E. Guido, J. g~, ~ y Q :sld ~. HiNH11~~lSNiv?c! ~'c :n; ~,u, vile :!1 ~.~r~.~t.r.~_ri,~.;~_~_ __ ~ _. . ~uGl ozooa~ ISAAC M. COLE, * IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PA * * vs. CIVIL ACTION - LAW * (RE: Visitation/Custody YVONNE A. COLE, * Defendant NO: 01-4342 * PETITION FOR TRANSFER FROM SCI-ALBION TO CUMBERLAND COUNTY FOR HEARING AND NOW, comes Plaintiff, Isaac M. Cole, pro se, bringing the following Petition For Transfer From SCI-Albion to Cumberland County For Hearing, averring in support as follows: 1. Plaintiff is currently incarcerated in the State Correctional Institution in Albion, Pennsylvania. 2. Plaintiff submitted a Complaint for Visitation and is Ordered to appear at the Cumberland County Courthouse before Hubert X. Gilroy, Esq., on Friday, August 24, 2001 at 9:30 a.m. for a Pre-Hearing Custody Conference (EXHIBIT A). 3. Plaintiff petitions this Court for an Order for the Cumberland County Sheriff's Department to transport Plaintiff to Cumberland County Prison in time to attend the August 24, 2001 hearing. WHEREFORE, Plaintiff prays for your Honorable Court to grant Petition and issue an appropriate order for transfer. -2- Respectfully submitted, ~~~ Isaac M. Cole ID # EM 8505 SCI - Albion 10745 Route 18 Albion, PA 16475-0002 DATE: August 1, 2001 CERTIFICATE OF SERVICE I, Isaac M. Cole, hereby certify that a true and correct copy of the foregoing Petition has been served this 1 day of August , 2001, by First Class Mail and deposited into SCI-Albion's mailbox, on the following: 1. Clerk of Court (Original) Cumberland County Courthouse Carlilse, PA 17013-3387 2. Office of Sheriff Cumberland County Courthouse Carlilse, PA 17013-3387 3. Hubert X. Gilroy, Esquire Cumberland County Courthouse Carlilse, PA 17013-3387 ~~ saac M. Cole ISAAC M. COLE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. YVONNE A. COLE • 01-4342 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, July 23, 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 Friday, August 24, 2001 at 9:30 a.m. for aPre-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: /s/ Hubert X. Gilro~„~sgY ~~ Custody Conciliator ~J 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 TRUE COPY FROAA RECORD ~X ~ b i ,~ ~J. In Testimony vehereof, I here unto set my hand ~~,~----"` Brad iioe sea[ of said Court a.'~t C//a''rlisle, Pa. This ...d...5....._ day ofG~~........., ~.1. Prothonotary ~, ~' ~ ~- ~. fir` e \~, ~. r ~; -' -' C ; ; „~, ,. wana+a.~ ~'aaaa~,u ~, °, ~,::. -.i:.rcr s+,- ~t~*.~a„a-ra^sm'~~r„ ~r~r~mi€,~u'~avz .~ `~UL Z 9204~~ ISAAC M. COLE, * IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PA * vs. * CIVIL ACTION - LAW * (RE: VISITATION) YVONNE A. COLE, * Defendant * NO: 4 ` , y3 ~ oC. C ~ (/ (~ PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS (AFFIDAVIT IN SUPPORT THEREOF) 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 of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct: (a) NAME: Isaac Matthew Cole ADDRESS: Inmate No: EM 8505, 10745 Route 18 SCI Albion, PA 16475-0002 SOCIAL SECURITY NUMBER: 119-56-8603 (b) I am presently unemployed. My last employment date was January 2000, and my monthly income was approximately $825.00, as a machine operator. (c) I have no other income within the past twelve (12) months. (d) I have no other contributions to household support. (e) I do not own any property. (f) My only debt is to the county of Cumberland in Criminal Y -2- Action Number 00-0469 in lieu of $141,000.00. (g) Persons dependent upon me for support: NAME: Yvonne A. Cole (Wife) Children: Shayna Cole AGE: Three years (07/03/98) Micaela Cole AGE: Two years (06/11/99) Other persons: Nathan Combs AGE: Nine years (03/39/92) Relationship: Step-son 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay costs incurred herein. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsification to authorities. Respectfully submitted: PLAINT FF/PETIT Isaac M. Cole ID No: EM 8505 10745 Route 18 Albion, PA 16475-0002 DATE: July 16, 2001 P' ~: ___ e~nmvueme.. a®~^i1N h* ~~r,z m.. .saf z ,.,,.y,ti__.s .:~zv~uaa+-rf s~'~mz~r"e~s;~ ISAAC M. COLE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. YVONNE A. COLE DEFENDANT 01-4342 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, July 23, 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 Friday, August 24, 2001 at 9:30 a.m. for aPre-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: /s/ Hubert X. Gilroy, Esr~ t!,~ 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 ,. __ , ,., ., ,,., _ ~. ' v~.e~--a,r xx,~+ ..,. ~z~ .•-r~,.~zirm ~'+. ,w~nrsa s_~'ry~'N~ ~Jll11 ~ 2~ai ~ ISAAC M. COLE, * IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA Plaintiff * * CIVIL ACTION - LAW vs. * (RE: VISITATION) * YVONNE A. COLE, * NO: ®` -y3 `l~ C f V 1 Defendant ORDER OF COURT You, Yvonne A. Cole, Defendant, have been sued in court to OBTAIN visitation of Nathan Combs, Shayna Cole, and Micaela Cole. You are ORDERED to appear in person at on , 200 at .M., for a conciliation or mediation conference. a pretrial conference. a hearing before the court. If you fail to appear as provided by this order, an order for visitation may be entered against you or the court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, CONTACT THE CUMBERLAND COUNTY BAR ASSOCIATION AT (717) 249-3166 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. ~` I , f -2- 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. Far information about accessible facilities and reasonable accomidations 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. BY THE COURT: J. DATE: ,m , ISAAC M. COLE, Plaintiff vs. YVONNE A. COLE, Defendant * IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA * * CIVIL ACTION - LAW * * (RE: VISITATION) * NO: * COMPLAINT FOR VISITATION 1. The plaintiff is Isaac M. Cole, I.D. Number EM 8505, residing at 10745 Route 18, Albion, PA 16475-0002, Erie County. 2. The defendant is Yvonne A. Cole, residing at 279 Plaza Drive, Boiling Springs, PA 17007, Cumberland County. 3. Plaintiff seeks visitation of the following children: (a) Nathan Combs Same address as Defendant Nine years (b) Shayna Cole Same as address as Defendant Three years (c) Micaela Cole Same address as Defendant Two years The children were not born out of wedlock. The children are presently in the custody of Defendant. The mother of the children is Defendant. She (Defendant) is married. The father of the children is Plaintiff. He (Plaintiff is married. 4. The relationship of Plaintiff to the children is that of their father; Plaintiff is step-father to Nathan Combs. 5. The relationship of Defendant to the children in that of their mother. The children reside with Defendant. -2- 6. Plaintiff has not participated as a party or witness, or in another capacity, or in other litigation concerning the visitation or custody of the children in this or another court, with the exception of Nathan Combs of who I have partial custody of. I do not know the term and number; but the court was ~a_~ K`~n l ~sc3n-~v ~ ~ ~~ This has no relationship to this action. Plaintiff has no information of a custody proceeding concerning the children pending in a court in this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because I love my Children and they love me. We communicate by letter. However, visitation would maintain and strengthen the parent-child relationship and ease the emotional impact of not having plaintiff physically present by both child and Plaintiff watching one another grow and mature. The children express a sincere desire to visit with Plaintiff as well. Therefore, the granting of the relief requested will be in the best interest and permanent welfare of the children. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named to this action. k -3- Wherefore, Plaintiff requests the court to grant visitation of the children. 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.A. § 4904 relating to urtsworn falsification to authorities. Respectfully submitted: PLAINTIFF Isaac M. Cole I.D. No: EM 8505 10745 Route 18 Albion, PA 16475-0002 DATE: July 16, 2001 ~ ~.~~ _ ~. ISAAC M. COLE, * IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PA * v vs. * CIVIL ACTION - LAW * (RE: Visitation/Custody) YVONNE A. COLE, * Defendant N0: 01-4342 * AFFIDAVIT OF SERVICE I, Megan Quigley; an the ~ day of August 2001, did personally serve Defendants with a copy of the Complaint For Visitation at ~ r .M., pursuant to the Pennsylvania Rules of Civil Procedure Rule 1930.4(a)(1). I verify that I am over 18 years of age and the statements made herein are true and correction and are made to the provisions of 18 Pa.C.S.A. §4904 relating to unsworn statements to authorities. Served on and at: Yvonne A. Cole 279 Plaza Drive Boiling Springs, PA 17007 n uigley 15AAC M. COLE, vs. * IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PA * * CIVIL ACTION - LAW * (RE: Visitation/Custody) YVONNE A. COLE, Defendant * NO: 01-4342 * CERTIFICATE OF SERVICE OF COMPLAINT I, Isaac M. Cole, hereby certify that a true and correct copy of Complaint For Visitation was served pursuant to Pennsylvania Rules of Civil Procedure Rule 19.30.4(a)(1) by Megan Quigley of 283 Plaza Drive, Boiling Springs, PA 17007 upon Defendant at Defendant's residence on the ,,s ~` da of Y August , 2001. See attached Affidavit of Service. r ~, ` Isaac M. Cole ,; IR?h'45~p.y rc ,-;..~:.„ ;y: w.tsift ~„ttp9iYFlF rc~~3"1~'"'9:mal-"'.?~Y!-~,tV• ISACC M. COLE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. YVONNE A. COLE N0.2001- 4342 CIVIL TERM CNIL ACTION -CUSTODY ORDER OF COURT AND NOW, this 20TH day of AUGUST 2001, the conciliator, Sheriff and/or the authorities at SCI-Albion are directed to make arrangements to allow Plaintiff to participate by telephone in the pre-hearing custody conference scheduled for FRIDAY, AUGUST 24, 2001, at 9:30 a.m. in COURTROOM # 5. By the urt, Edward E. Guido, J. Hubert X. Gilroy, Esquire Sheriff Thomas Kline SCI -Albion Albion, Pennsylvania 16475 :sld t~,~~dn~,~sn1r~~~~ ,.. ;. ~::,_ „ pEC ®~ 2003 ISAAC M. COLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW YVONNE A. COLE, NO.Oi - 4342 CIVIL Defendant IN CUSTODY COURT ORDER AND NOW, this ~~ day of December, 2003, the conciliator previously Report with counsel for the parties in this case but no specific order relinquish jurisdiction, the conciliator now relinquishes jurisdiction. BY THE COURT, having a filed a being issued to ~M1 Hubert X. ' roy Custody nciliator _,~ ~;'i - ' T I ~~ ni "~: V31_ (__-' ~~ i J ^ ~.S ~'~ ,~ ry C ~..:~ ~ alter 'l .° . ~r~~ ~ ` J ~ 4 s ~ '.-ae IGR?a-+~P+~LH4R'm.^q~~mx 4.w :ess.~MVm+yd"A,.~4M1R _,k .. ...