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Home My WebLink About01-05241,~ ~, ~C°f' 2 3 Z00~ JACOB M. HALL, FN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION -LAW CHRISTINA G. SWAVOLA, N0.01 - 5241 CIVIL Defendant IN CUSTODY COURT ORDER AND NOW, this 2G ` day of October, 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. This Court Order replaces the prior custody order entered by the Dauphin County Court at Docket No. 2001- 3819. 2. The Father, Jacob Michael Hall, and the Mother, Christina G. Swavola, shall enjoy shared legal custody of Jacob Michael-Ray Hall, Jr., born May 28, 1999. 3. The Mother shall enjoy primary physical custody of the minor child. 4. The Father shall enjoy periods of temporary physical custody with the minor child as follows: A. OD alternating weekends from Friday at 5:00 p.m. until Monday morning at 9:00 a.m. B. Every Wednesday night from 5:00 p.m. until Thursday morning at 9:00 a.m. C. At such other times as agreed upon by the parties. 5. Exchange of custody shall take place at the East Pennsboro Police Department unless agreed otherwise by the parties. 6. The parties shall work between themselves to ensure a shared custody arrangement for holidays. For the Christmas holiday, the parties agree the Father shall have custody of the minor child on Christmas Eve through Christmas Day at Noon, with the Mother having custody of the minor child from Christmas Day at Noon until Decembei 26`x' at Noon. ,~ ~ cc: 7. The parties shall submit themselves to a counseling session arranged by Father under circumstances where the costs of the session are paid for by Father or some social service agency. The sole purpose of these counseling sessions shall be for the parties to address custody/communication issues. 8. This order is entered pursuant to an agreement reached by the parties at a custody conciliation conference. In the event either party desires to modify this order, that party may petition the court to have the case again scheduled with the custody conciliator. BY THE COURT, ~\ Dauid Lopez, Esquire ~~ Austin F. Grogan, Esquire ~ \ O ~' \b`?! 4 JACOB M. HALL. Plaintiff v CHRISTINA G. SWAVOLA, Defendant Prior Judge: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO.O1 - 5241 CIVIL IN CUSTODY 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: 1. The pertinent information pertaining to the child/children who is/are the subject of this litigation is as follows: Jacob Michael-Ray Hall, Jr., born May 28, 1999. 2. A Conciliation Conference was held on October 18, 2001, with the following individuals in attendance: The Father, Jacob M. Hall, with his counsel, Austin F. Grogan, Esquire; and the Mother, Christina G. Swavola, with her counsel, David Lopez, Esquire. 3. The parties agree to the entry of an order in the form as attached. /G ~ o DATF, Hubert X. Gilr ,Esquire Custody Co iliator JACOB MICHAEL HALL IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTINA G. SWAVOLA DEFENDANT 01-5241 CIVIL ACTION LAW 1N CUSTODY ORDER OF COURT AND NOW, Monday, September 10, 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 Thursday, October 18, 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~Esa. ~! 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 ~~~~~~~ MNdr~II~SN (dd Z ~ ~~ 6{d 0 { d3S { 0 ~~.~,. ~ ia.o~~~ ~0~0~•6 ~'~'~~.~G~dl'~'i L~~Zii"~ i ;.. ~J i JACOB MICHAEL HALL, Plaintiff v. CHRISTINA G. SWAVOLA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSCYL~VA,NIA CIVIL ACTION -LAW CUSTODY ORDER OF COURT AND NOW, this day of 2001, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before ,the conciliator, at on the day of 2001, at .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 in to a temporary order. Either party may bring the child/children who is/are the subject of the custody action to the conference, but the child's/children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. For the Court, By: Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 ~a n ,.~ _ JACOB MICHAEL HALL, Plaintiff v. CHRISTINA G. SWAVOLA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,~~P..ENNSYLVANIA NO. Ot- sau( L.tUc~~£fL.~ CIVIL ACTION -LAW CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Jacob Michael Hall, who currently resides at 625 LeSenteir Lane, Harrisburg, PA 17112. 2. The Defendant is Christina G. Swavola, who currently resides at 5 Addams Street, Apt. 3, Enola, Pennsylvania 17025. 3. Plaintiff seeks custody of the minor child, Jacob Michael-Ray Hall, Jr. , born May 28, 1999, who currently resides at 5 Addams Street, Apt. 3, Enola, Pennsylvania 17025. 4. The child was born out of wedlock. 5. The child is presently in the custody of the Defendant, Christina G. Swavola. 6. During the child's lifetime the child has resided with the following persons and at the following addresses: Jacob M. Hall and Christina 625 Le Senteir Lane, May 28, 1999 -August 17, 2001 G. Swavola Harrisburg, PA 17112 7. The relationship of Plaintiff to the child is that of natural father. 8. The relationship of Defendant to the child is that of natural mother. 9. 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. 10. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. ~, 11. 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. 12. The Plaintiff/Father seeks primary custody for the following reasons: a. Mother is an unfit parent. b. Father has provided a stable home life for the child since the child's birth. 13. Each 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, the Plaintiff, Jacob Hall, respectfully requests this Court to grant primary physical and legal custody of the child to the Plaintiff. Respectfully submitted, ~~~~ Austin F. Grogan, Esquire // Attorney for Plaintiff (/ 24 North 32nd Street Camp Hill, PA 17011 (717) 737-1956 ID # 59020 ; VERIFICATION I, Jacob M. Hall, verify that the statements made in the foregoing Custody Complaint are true and correct to the best of my lo7owledge, information, and belief. 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 ~~ < ~~ Ja .Hall °""'°"'Ve'x151aCed:se~ire~~k 4ecka~o~k~zaw ~».wzF,-<, V 1 r ~' ~ ~' C) c i L7 ~i ~r ~~ ~1 try ~ 1 C* G, ~. r~ J ( _. y c_ .. ~ :,~ >_ ~;~