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HomeMy WebLinkAbout01-06088 , CHAD WATSON PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. 01 "6088 CIVIL ACTION LAW LYNNR. WATSON DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, October 30, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueliue M. Verney, Esq. ,the conciliator, at 4th Floor, Cnmberland County Courthouse, Carlisle on Wednesday, November 28,2001 at 3:30 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. 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 TIIE COURT, By: Isl Jacqueline M. VernEO'. Esq. ~ Custody Conciliator The Court of Common Pleas of Cumberland County is requITed 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 ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE 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 "'-.~f-F.,.~."- ,_1 ....., ~i'I;_!J,.!i;",;;;;:ti-"j;",it,Ai),u..",A:t>bi",f<-~'-''''''JLj,;;~1Jl:-{~-;i;ii"X,\":-,~i,i.,-..,", '..' '".." ~).L",,^',;: "'~,'~~f0!"""<",;'.:_U'~'i:41,l;,;.;,lllI,"~"jl.liJ:;,,,~~.{;~i1!ili_~2_~J~ Jt'J:3/-C?1 /031-t)/ It? '3hPI o _~ "",~",.. " .. .. 0___ r] I 0JI'"';' ':i 1 . , ~- ~j I d i ""II . :"in : ;,:,3 CUi\';I-':;:::I:) .: ,'~', \.. ';'1..,,,- i:J\!+:'.j C01 n rry Pr-N!i\H'"\V!\ff. VI\I --h0' .'J/iN&\ W Ml71U~/;$ 4 ~ '71titd ~ ;$ ~. ~ ~~ df" ~yM . -~,' ,." .. ~-- ,., .- \II'!l!_ I!g )3 v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001" OOm? CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY CHAD WATSON, Plaintiff LYNNR. WATSON, Defendant ORDER OF COURT AND NOW, this day of , 2001 upon consideration of the attached Petition it is hereby directed that the parties and their respective counsel appear before Esquire, the conciliator, at , Pennsylvania, 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 ill 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 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 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 HELP. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 1 "800"990"91 08 ~l",.7" '''.' .'__~';"<-,;.v""."",..'_" c,,, _'~"."'_'"~."~I_ '.c,,"'_ _._ ',_._", ,. I '.' . ,- , , ',. '.. "!"'~, ,~ C">"~' ~~ v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 200dJR;'5. CIVIL TERM CHAD WATSON, Plaintiff LYNNR. WATSON, Defendant : CIVIL ACTION" LAW : IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Chad Watson, an adult individual currently residing at 55 SME, South Hollar Drive, Shippensburg, Cumberland County, Peunsylvania 17257. 2. Defendant is Lynn R. Watson, an adult individual currently residing at 321 Farmington Manor Drive, Shippensburg, Cumberland County, Pennsylvania 17257. 3. The Plaintiff is the natural father of the children, Kyle Avery Watson, born January 23,1996, aged 5; and Colton Riley Watson, born October 2, 1997, age 4. 4. The eldest child was born out of wedlock, while the youngest child was born in wedlock. 5. Since birth, the children have resided with the following persons at the following addresses for the following lengths of time: NAME Lynn Watson ADDRESS 321 Farmington Manor Drive Shippensburg, P A DA TES December 2000 to present Lynn Watson Vicki Mathna Larry Mathna (maternal grandparents) 1108 Kessler Drive Shippensburg, P A August 2000 to December 2000 t, .,~ _ , ',,,..' ;/:~:J,i~";'...~:::,;;:1 .' I .:1- . " : -;, , t:; 0":"_- _ h,/.",.:.,-",-"",t :,':";,~-;;i;.,,,"i:~r;;;':; -".:-,- ;L~;LJ,;:;:';:, NAME Lynn Watson ADDRESS 8916 McClays Mills Road Newburg, PA DATES July 2000 to August 2000 Chad Watson Lynn Watson 8916 McClays Mills Road Newburg, PA Birth to July 2000 6. The natural Father of the children is the Plaintiff, who resides as foresaid. He is married. 7. The natural Mother of the children is the Defendant, who resides as foresaid. She is married. 8. The relationship of the Plaintiff to the children is that of natural Father. The Plaintiff currently resides with his girlfriend. 9. The relationship of the Defendant to the children is that of natural Mother. The Defendant currently resides with the children and her boyfriend. 10. The Plaintiff has no information of a custody proceeding concerning the children pending in any Court of this Commonwealth. 11. The best interest and permanent welfare of the children will be best served by granting the relief requested. 12. The Plaintiff does not know of any person not a party to the proceedings who claims to have custody or visitation rights with respect to the children. !.--'I~(~, ~. ~' ,.~ - ~~'". ;c '.~-__f' :,,' .J:; i'-~k.(;-i'2!,,: ,'.- "A._' ,,".,-"-.' "-"~''':!C-'"'_ _".> _7.' ----~. ..<, I <i,::~'{,,;,- :t.,,'i,," :.; :-:,-"--:"~'.:,,,' -,".,' "':.-.' :,~'" ',';; "- ;;-1.1:-::.::;, ~ ',""" 1- I." I:' Ii: ,',.-,e.'<.\",w WHEREFORE, the Plaintiff, Chad Watson, respectfully requests this Honorable Court to enter an Order scheduling the Parties for a Custody Conciliation. Respectfully submitted, Date: /D -~ ~vD( omas S. Diehl, Esquire Attomey for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240"0833 1'-= ~" " '-,,'i,'~<-' ,., "-\'^-- ;,'-'.: ''''"''''';:-'''1' " :;;,_._",' ,:' '! ",:,,"i..:-, " I ;'~L~"~ ~M '",_' '~''';,,.\ ~;~, - , ~ , '-;-':'>,:,,,:,: 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. S 4904, relating to unswom falsification to authorities. ~/cd~- CHAD WATSON, Plaintiff ::- ::<.~~:~:~;'~;;-~~ ~ "-.'1''::J--.. -, -- --" -"~)::-.-:-',;:"i,;---_ ,~;. -.' .,.~,-':, ,': ; ",';;;.,iI~~v I l", :l , t "~, ,~., __,_ "~_".~'n"'__ ~ .> , ~',~ ",- "~j. ,~ - Tml11C -, - ',~ c,"," ~r-'flll'}mij'fj';t1fijfi:rf.:t+-~ '-"cCiiilr";'~"-~'-'-D":"'-'h';,~~'"'iTF:W'1:"""~":l;(\"lri'j1= o r.; ~tlf Z(; i2 ~~~'; ~C_' :E;c ~o c z =<' o ('-i '" :::::> i:") ._.j t-..) (.o..f , ~~ ~tJ -.;:;: (..,) ,~ """,'r'.'I:--:."j"~~>U,--~":',(P- x -'::~:;"-'1.fl!-:-~ ,~f~ -, P':,_. .,.}:t - .." "~- < .ii!!~m,..~,~~, ".,_",~""Ii'~p ,p,-' ,:,~.~,~1!;;~~~~:! R_J!,)ijrrI;~,~~'$~~,~-~~_}i!l~Q~;~g, 4i,b~' ~ ~ NOV 2 9 2001lfJ CHAD WATSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. LYNNR. WATSON, Defendant : NO. 2001-6088 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this --b- day of ~ ,2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Chad Watson, and the Mother, Lynn R. Watson, shall have shared legal custody of Kyle Avery Watson, born January 23,1996 and Colton Riley Watson, born October 2, 1997. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 2. Mother shall have primary physical custody ofthe child, with Father having periods of partial physical custody as follows: A. Alternating weekends from Friday at 7:00 p.m. to Sunday at 7:00 p.m. B. Every Wednesday from 5:00 p.m. to 7:00 p.m. C. Such other times as the parties agree. 3. The parties shall equitably divide all holidays. 4. The receiving party shall transport the children, except on Wednesdays when Father will be solely responsible for transportation. 5. Due to Colton's heart condition, neither party will smoke or permit anyone to smoke in the children's presence. In addition, the children will not be exposed to a home where smoking has occurred in the previous nine (9) hours. 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. V"5~ ~ ....~ :<~'~ -~ ~ - . ~ / cc: Thomas S. Diehl, Esquire, counsel for Father Thomas 1. Williams, Esquire, counsel for Mother cJiJ trspLw -f'tBYr J 2- {p -0 J ;'-"fA'1'~""'''' ~, . , J. ", Ir \-dl.ril~C:!lWi~~:it'lli~i;~';;"".'jf -. '~~~1~1i"*w"~W"'H&i'O:"\"""'o~i!M1'JH.i!!~J"-~~~".dI:dlLmW"\..';'.~~ilU.__~~;a; "If (rrr 'Ii; .i" L&IL ~ " I; "~I lJ DFt__r , 0 'J"/""'F! .. ','iY PI; ~1' r ..., . . 11 .' CU/V:/BL>:" -'--'''.,' -- Pr: L '". .. ~N/\r0;'I~" \.;~;/ ;f'/;-\/ U{ ,),~ \/' 'I """{"!I!,l "!'I , ,!t...J.t..... I LL1LLmq!rIM~ILIJ1,JU .....1.]1111 L~JL ,..... ._.. ... r~' CHAD WATSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2001-6088 CIVIL TERM LYNNR. WATSON, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 19l5.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information conceming the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kyle Avery Watson Colton Riley Watson January 23, 1996 October 2,1997 Mother Mother 2. A Conciliation Conference was held in this matter on November 28, 2001, with the following individuals in attendance: Father, Chad Watson, with his counsel, Thomas S. Diehl, and the Mother, Lynn R. Watson, with her counsel, Thomas J. Williams, Esquire. 3. A previous Order of Court had been entered in Franklin County dated, November 19, 1998. Said Order, provided for mother to have primary physical custody. 4. The parties agreed to entry of an Order in the form as attached. I/<P'J -0 I Date cq line M. Verney, Esquire Custody Conciliator / '-":~m)i'_v.. ,____ I' . . CHAD WATSON PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 01-6088 CIVIL ACTION LAW LYNNR. WATSON DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, August 14, 2002 , 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, Cnmberland County Courthonse, Carlisle on Tnesday, September 03, 2002 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 hearing. FOR THE COURT, By: Isl Jacqueline M. Verney, Esq. .rf'W 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 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 "'-''',!,-lffijl;!;1"__ , 1--' '.1,'1~ ""_,~~;,,,":';~'&1~1~~;Mjf';'"=L,,~ ^ ~.I 1f Pl-/.),;z 13' ;/ If' t!l ,;L 11 /If-tJ J !IWII~~~ii'~~!i~~if.it;-}~1Mi ~ . --, OF .~;,",~u~g :_0i~PCF '_'/.'\1';")'/;;)'1 , ..."1-\111' (3 Sf 0.) · ',- I-l.IJG 14 P:4 '). , '" , I. (",' L;,,,: CU"'L'~< ,- Jit,wr=:ri'-'''\I'~u tj")j If\n"y PcNNSYLVM[lt ' , . M.~~/t4~b c~ ~ ~MfAJ~-T~ ~~~-~ 4~#' . ~f4t~ kW~ ,~'~'f'^5~J~J~.~WM~/~~/.~J"~:__'1f,~~1IA.~,J!".,~:,;,:,,,k):lR~i;J::mSJf,~i:LllJ,,u~ ,,J " - --,- ,--,~~ .- _~, ,~>. -, ,"'-~_ '" ,~, v,,~,.~ CHAD WATSON, Plaintiff/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2001"6088 CIVIL TERM LYNNR. WATSON, Defendant/Respondent : CIVIL ACTION" LAW : IN CUSTODY ORDER OF COURT AND NOW, this day of , 2002 upon consideration of the attached Petition it is hereby directed that the parties and their respective counsel appear before Esquire, the conciliator, at , Pennsylvania, on the day of , 2002, 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 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 HELP. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249"3166 1 "800"990"9l 08 -,~ " I ' --~ , Ii p:;~'~ CHAD WATSON, PlaintifflPetitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 2001-6088 CIVIL TERM LYNNR. WATSON, Defendant/Respondent : CIVIL ACTION" LAW : IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY 1. Petitioner is Chad Watson (hereinafter referred to as "Father"), an adult individual currently residing at 55 SME, South Hollar Drive, Shippensburg, Cumberland County, Pennsylvania 17257. 2. Respondent is Lynn R. Watson (hereinafter referred to as "Mother"), an adult individual currently residing at 321 Fannington Manor Drive, Shippensburg, Cumberland County, Pennsylvania 17257. 3. The parties are the natural parents of the children, Kyle Avery Watson, born January 23, 1996, aged 5; and Colton Riley Watson, born October 2, 1997, age 4. 4. The parties are currently subject to a Custody Order dated December 6, 2001, which was the result of an agreement reached at a Custody Conciliation Conference held on November 28, 2001. A copy of said Order is attached hereto and incorporated herein by reference as Exhibit "A." 5. There have been no additional actions relative to custody of the within named children in any jurisdiction to the Petitioner's knowledge. 6. Since the entry of the Court's Order of December 6, 2001, the children have primarily resided with Mother. ,__^,S"""~01!"7 ., """ ....,.,~ -,. I' ~ ~~ [" "" 7. Among the reason why Father desires to modify the existing Order are as follows: (a) Father had previously desired to share more time with the parties' children and accordingly filed a Custody Complaint on. October 24, 2001, to pursue his intent. (b) A Custody Conciliation Conference was scheduled for November 28, 2001, to address the issue of expanding Father's time with children. (c) On November 28, 2001, the day of the Custody Conciliation Conference, Father was informed by Mother that a Children and Youth Services case was pending against him due to recent allegations of abuse. (d) The allegations steInnIed from Mother taking one of the parties' children to the Emergency Room for injuries the child sustained, which Mother believed to have been caused by Father. (e) Consequently, Cumberland County Children and Youth Services investigated the matter, and ultimately determined that the allegations of abuse to be unfounded. (f) Now that there is no pending Children & Youth Services action, Father still desires to exercise more time with the children, and accordingly brings this action. 8. The natural Father of the children is the Petitioner, who resides as foresaid. He is divorced. 9. The natural Mother of the children is the Respondent, who resides as foresaid. She is divorced. "'""f-~"'~~~,~"", ,,~'_ ~~-~ ~,.,",O 10. The relationship of the Petitioner to the children is that of natural Father. The Petitioner currently resides with his girlfriend, Kelly Short. II. The relationship of the Respondent to the children is that of natural Mother. The Respondent currently resides with the children and her boyfriend. 12. The Petitioner has no information of a custody proceeding concerning the children pending in any Court of this Commonwealth. 13. The best interest and pennanent welfare of the children will be best served by extending Father's time with the children. 14. The Petitioner does not know of any person not a party to the proceedings who claims to have custody or visitation rights with respect to the children. WHEREFORE, the Petitioner, Chad Watson, respectfully requests this Honorable Court to enter an Order scheduling the parties for a Custody Conciliation. AUG 0 5 2002 Date: Thomas S. Diehl, Esquire Attorney for the Petitioner One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 ";:-r-"l:<!W_lIl,~lJ~ ~ I, ~ - i;- - ,~"'"-- , ,"~-~ -" ~ VERIFICATION 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 18 Pa.C.S. S 4904, relating to unsworn falsification to authorities. 4/W~- CHAD WATSON, Petitioner ,;--..; ..., II, 0':"'<" '"i",,',~ ""w"'''' ", ,~.~ EXHIBIT A '-'rJ!."';l', ~ ~~ -, ~ CHAD WATSON, Plaintiff . . i; .>~,,;;i}i .. '11' . . 'i. i\..]NQ~~~i"~l ""', ."!,,;,,,' - ,,",. " "~:~,*fn~:;:~~rl? " : IN THE COURT OF COMMON puMOr : CUMBERLAND COUNTY, PENNS~Y~ : - .: - '::;~":':r~_:~"':;:L, :::,:,:;,. ,-~.;; ~,- : NO. 2001-6088 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY V. LYNNR. WATSON, Defendant ORDER OF COURT AND NOW, this M day of tel"P IYI he R . 20()!~;' consideration of the attached Custody Conciliation Report, it is ordered. .f. follows: ." . 1. The Father, Chad Watson, and the Mother, Lynn R. W. shared legal custody of Kyle Avery Watson, born January 23, 1996 and. , Watson, born October 2,'1997, Each parent shall have an equal right, to', jointly with the other parent, to make all major non-emergency decisions; .Children's general well-being including, but not limited to, all decisions, health, education and religion, .' "', 2. Mother shall have primary physical custody of the child, wtth' F~er _; having periods of partial physical custody as follows: ,:' .,. " A. Alternating weekends from Friday at 7:00 p.m. to Sunday at 7:00 p.m. . B. Every Wednesday from 5:00 p.m. to 7:00 p.m. C. Such other times as the parties agree. '0 3. The parties shall equitably divide all holidays. 4. The receiving party shall transport the children, except on Wednesdays when Father will be solely responsible for transportation. 5. Due to Colton's heart condition, neither party will smoke or permit anyone to smoke in the children's presence. In addition, the children will not be exposed to a home where smoking has occurred in the previous nine (9) hours. 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 tenus of this Order shall control. RECEIVED .' "''''Ii-.''''",1 , " __," "I -I ~ _ ~ ,!" I - ,,,-.,,,,,,,...~. .( ( -.,> BY THE COURT, - . '",'"/',, ., ,:-:,'".'..:- ',':: '_, ," ,"'_:,_ . ,/:"<..-.,?:,, ,.C..",:,:_:._ " .,..'):;;;:~~::.,:"",?:,~,>:,.: .cc: Thomas s; Dtehl,c~silu4e~CQ~l fo~~F~i;<;.... . Thomas). Willil\DlS;J~sq~, counse1fQ{Motber , " . ',' . " .' :'\ "':," . :;,,, ,."':~' ::; '" :~_: !"" "'I"'n'lU: <",-,,",."'If~ ,~,~"" 'I ' ' " ~, " " '2'" ( ( 'j" . V. '~,C"'.-.,:- . . : INTBE COURT OF COMMON fLEA$ OF' . :C~COUNTY.f~~YLY~> \ : . ,__:;~,.: :};':".,:<,'" : '" ' """;. ,>/~ ~ ',: - ---'. i :20.01-6083 ClVIL TERM . " ',~ ....;.,:. ".",.' '.;' ' " ;~,,~. ;".'":. CHAD WATSON. Plaintiff l~. . . -....~. '. .(:;,::~,,:<:' '" ~':;-'.:',-~,:. :r: '-~~:5~~1, LYNNR. WATSON. . .. . . ........ >>d."ut[.: ,~<'<: :.:{.~~~~f.,~?~~.-:t:':..... "", ~~' :';'r':., f~OB. JUDGE: NCI.ne./ . -'.".'. ' . ~ "~~'. .': .-..-~". .' '.", ':'J~,:~ .:> ,',~~i:.~'--: ': :~"'.'- 't."..,. :;~;~;~.~;~::::; :,t..< '. . '~,', .c' ';:~:~:," '?f~~' '" i,' ;;-1 !,,! '-,->' Kyle AveryWatson Colton Riley Watson 2. A Conciliation Conference was held in this matter on November 28,2001, with the following individuals in attendance: Father, Chad Watson, with hisco~,' . '. Thomas S.Diehl, and the Mother, Lynn R. Watson, with her C()lJI1iiel, Thomas J. . . Williams, Esquire. . . .' ..... . - . . Mother . . Mother '. "\'" . :.,i-.\~'.:i-":' -..'r ," .n" 3. A previous Order of Court had been entered in Franklin County dated, November 19, 1998. Said Order, provided for mother to have primary physical custody. 4. The parties agreed to entry of an Order in the form as attached. " -- ;;>. " -0 I Date q line M, Verney, Esquire Custody Conciliator , '':>~''4''':i ,(Hi. , ,\ ,e.' r""""'" ',P ,,~~ "'" ,- ',~'V_~.. ,_n~t1f!~ -, -~~ -- 6 R/Lt.> .~~~ -~- .'..'" -- '~'"?'-.",'''';'''"'~ ~'--'/,",:,j'>~", ,';2'->:0","''1' -Ft'.M;j;'ry. 'rlml(~ll{'~fDY'~--':-h'''-''f'f4 A ~ 0 C:J C' P\..;- c:) "1:' t;: "'" -Tj u.. n-L',--, c.-:: .......... ...... ;k! t~} ~ 0 z-::-t:, c-....) e' (/)5 0<< ',-, " ~.,,?'" ~~ )... \) ;:;~t.) ._"'~, C_) ~~ W " --;.. C-'f -~ ;;?f~ 8 $c5 -.([=. () C ;~) -;;<' <C, ::< :-'1 :~I en ~ --<: ~ J _~"""i"<,rrlll!~~~~~~~W'~~!~ '-'r'-",--'t"~?,'"""_'u,,,--q"" \1:'~-- -- ""'~>-"!'P~Vf;-i'!!i')'''if~7i~>l)'~,\JF1i~''j)1fB1-~f,t;;{H;:-t!!;r~f!fl~]:('' "~,.. . .. SEP 0 3 2002 CHAD WATSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. LYNNR. WATSON, Defendant : NO. ~OOl-6088 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this ')'U.. day of consideration of the attached Custody Conciliatio follows: , 2002, upon , i is ordered and directed as 1. The prior Order of Court dat~d December 6, 2001 is hereby vacated. 2. The Father, Chad Watson, and the Mother, Lynn R. Watson, shall have shared legal custody of Kyle Avery Watson, born January 23,1996 and Colton Riley Watson, born October 2, 1997. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non"emergency decisions affecting the Children's general well"being including, but not limited to, all decisions regarding their health, education and religion. 3. Mother shall have primary physical custody of the children, with Father having periods of partial physical custody as follows: A. Alternating weekends from Friday at 5:00 p.m. to Sunday at 7:00 p.m. B. Such other times as the parties agree. 4. Thanksgiving shall be shared from 9:00 a.m. to 3:00 p.m. and 3:00 p.m. to 9:00 p.m. as agreed by the parties once Mother knows her work schedule. 5. The Christmas holiday shall be divided into two Blocks. Block A shall be from 12:00 noon Christmas Eve to 12:00 noon Christmas Day. Block B shall be from 12:00 noon Christmas Day to 12:00 noon December 26. The Christmas holiday shall be split as agreed by the parties once Mother knows her work schedule. 6. The parties shall cooperate with a custody evaluation to be performed by a psychOlogist chosen by the parties. 7. The parties shall share transportation by meeting at the McDonald's ill Shippensburg to exchange custody. ",1'_=-, IT, L ~_ ,I ", ~ ''''~'I ~- ,,~ " ~ .,,,~ L 8. Due to Colton's heart condition, neither party will smoke or permit anyone to smoke in the children's presence. In addition, the children will not be exposed to a home where smoking has occurred ill the previous nine (9) hours. 9. 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. Either party may contact the Conciliator to schedule another conference upon completion of the custody evaluation. ' BY TJ;E COURT, \ J. , cc: Thomas S. Diehl, Esquire, counsel for Father ~ ~ 9-05'{}.2J Thomas J. Williams, Esquire, counsel for Mother . I ~ ,'__V!''''''"~I:~"""", , 1 1,' ,- .- ~_~~;JijJ'M1ie*'f1k~.~J~_hl~",i#lllii~jq';!!;!h"'~V';'-" ,,~;He,00:\','i\;!'''''L'',',_;i",li';t!:!~!fil. ,,:Jl,L~L_d,UlIJ JlIlIL _,""~ """'~"" "" '" ,",___,_ ""1r.!!ii~~,~;fu;<!I~"""",,,,,,,>" ~~JI'-' () c" "'"" :tJ --" nil?:) j;-;9 05S. !::!i-<' ~c.' ""() ;&i,(", ..1._" J f;; $ "-~ ~ R1 t:f -0 , (Fj o " -C' -v~ ~.'" ::;1 i';r:;Q ,~8PJ ':) I,' :::;:f'~;..J 51(1/ (Jrr, j;! ;:0 "'" - " 07 (0<) "- .~ CHAD WATSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . V. : 2001-6088 CIVIL TERM LYNNR. WATSON, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edgar B. Bayley, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3"8, the undersigned Custody Conciliator submits the following report: I 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kyle Avery Watson Colton Riley Watson January 23, 1996 October 2, 1997 , Mother Mother 2. A Conciliation Conference was held in this matter on September 3, 2002, with the following individuals in attendance: Father, Chad Watson, with his counsel, Thomas S. Diehl, and the Mother, Lynn R. Watson, with her counsel, Thomas 1. Williams, Esquire. 3. A previous Order of Court had been entered by the Honorable Edgar B. Bayley on December 6, 2001, providing for shared legal custody, Mother to have primary physical custody and Father having alternating weekends. 4. , The parties agreed to entry of an Order in the form as attached. 9-3 -02- Date ~l ac eline M. Verney, Esquire Custody Conciliator .",o-!~'"~. .' J - ^' '~=--1'"- ~~~..~~.~ ~~ '-1-" , I - - r-r~~ "~ '.~ " CHAD WATSON PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN1Y, PENNSYL VANIA V. 01-6088 CIVILACTIONLAW LYNNR. WATSON DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, June 06, 2003 , 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 Wednesday, June 25, 2003 at 8:30 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 hearing. FOR THE COURT, By: Isl Jacqueline M. Verntry, Esq. v Custody Conciliator Ii , 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 TIllS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE 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'''f!~".[_."l ~, ,~, ~"~-!"'''''''''''''I ~~ "f"!"!"'l'"~-_ ",Or' ';')_i_~I&lf.,':''J&';t", .-,~".i'",.<,~'';:::)i,';h;,;)-:;"j''-<-L,.""'";._;,,i./'_'"";''' " 0~ ~ !.> W . tJ3 b -fp .tU iF k -?J3 ~:-"__.~"' ,~'J-",,, ""h'~". ,-,:,"'3-4:r,l.hlj,,4>>I!\,,\-i6: il"';"'~,E'.\2i;Y.'tlM,,,,,'l@ili~""""Wihiilt?J<M~OO~ - ~.-..'" , ..~ " i':' ',_ \ 'D ~,c\.T\CE. __,'-', ," "-"."l"'i~.O\( o;~ ' ',- .-'! ,; .';r\i' 03 J\J,'\ - G ".1'\ 10: S h ^U' or," 'l .' ,,', ("-,, 'NeT\! V iV\!:i::r.: j\r,lU ......uUl', i I PENNSYLVANIA cd &;;r.'~ ;j, 4' ~ ~ _~.v ~ ~ A9".d/ ~ /14(/, f)/ Z;' 4 ~ :,~6 ,~'~0~~PJ:~,,~~--:~ll&{J,:I~,1(~!,~J\b1k~,;;!j:A~;;\:;,!~J_ i,~.,,!it,LI!!~~~~.~;';;~!,~~~!~;;,-,hC- ,_.,;L. ,l!iilllLllflJ_., -"C." '""."p" ,'",.,' " "" ,~,' ",.. ~.,~ ~ ~., ,-~--",,-~, J CHAD WATSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001"6088-CIVIL ACTION LAW LYNN R. WATSON, Defendant IN CUSTODY ORDER OF COURT AND NOW, this _ day of , 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 , , at .m. for a Pre"Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or ifthis 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. 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 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,, "-,'",-.,-".,.."",, ""1'"",-," ,_ ,? II,-.,~~.,.""", F:\FILES\DA l'AflLE\Genera1\Documents\ I 0505-1.petitionltde Created: OI/21S/0208:29:24AM Revised: 0610~f0311:55:39AM 10505,1 CHAD WATSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA v. NO. 2001 "6088-ClVIL ACTION LAW LYNNR. WATSON, Defendant IN CUSTODY PETITION TO MODIFY CUSTODY 1. A Custody Order was entered on September 5, 2002, a copy of which is attached hereto as Exhibit "A." 2. Mother, Lynn R. Watson, has secured employment out of state and will be relocating on July 1, 2003. 3. The above noted relocation will necessitate a change in the custody arrangement. Mother proposes to afford Father significant time during the school summer vacation and also during holidays when Mother visits family in Pennsylvania. Mother will provide transportation as long as the timing can be coordinated. WHEREFORE, Mother, Lynn R. Watson, requests that the Custody Order of September 5, 2002, be changed in accordance with the above. Respectfully submitted, MARTS ON DEARDORFF WILLIAMS & OTTO BYT::~~i~E~~ Ten East High Street Carlisle, PA 17013 (717) 243"3341 Attorney for Defendant Lynn R. Watson Date: June 2, 2003 ," -,. ~"~l ~ SFP 0 3 ZOOl CHAD WATSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. LYNNR. WATSON, Defendant : NO. 2001-6088 CIVIIL TERM : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT ~ ~ AND NOW, this 5~ day of 1Ah.....JJ.-V.-/ , 2002, upon consideration of the attached Custody Concil' tion Report, it is ordered and directed as follows: 1. The prior Order of Court dated December 6, 2001 is hereby vacated. 2. The Father, Chad Watson, and the Mother, Lynn R. Watson, shall have shared legal custody of Kyle Avery Watson, bom January 23, 1996 and Colton Riley Watson, born October 2, 1997. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 3. Mother shall have primary physical custody of the children, with Father having periods of partial physical custody as follows: A. Alternating weekends from Friday at 5:00 p.m. to Sunday at 7:00 p.m. B. Such other times as the parties agree. 4. Thanksgiving shall be shared from 9:00 a.m. to 3:00 p.m. and 3:00 p.m. to 9:00 p.m. as agreed by the parties once Mother knows her work schedule. 5. The Christmas holiday shall be divided into two Blocks. Block A shall be from 12:00 noon Christmas Eve to 12:00 noon Christmas Day. Block B shall be from 12:00 noon Christmas Day to 12:00 noon December 26. The Christmas holiday shall be split as agreed by the parties once Mother knows her work schedule. 6. The parties shall cooperate with a custody evaluation to be performed by a psychologist chosen by the parties. 7. The parties shall share transportation by meeting at the McDonald's in Shippensburg to exchange custody. EXHIBIT "A" "j"""""""".''''-.,.I - ,~~= , "" I"" ~~ ~ ""'.'",,,,,","~~"~ 8. Due to Colton's heart condition, neither party will smoke or permit anyone to smoke in the children's presence. In addition, the children will not be exposed to a home where smoking has occurred in the previous nine (9) hours. 9. 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. Either party may contact the Conciliator to schedule another conference upon completion of the custody evaluation. BY THE COURT, Js) fJ .A. 13. ;;1,,)t.,. I~ ~ J; J. cc: Thomas S. Diehl, Esquire, counsel for Father Thomas J. Williams, Esquire, counsel for Mother r.t~'t ~ g:'~ .,r-'> ,'"'''';. I'-~,,,,~. U'. """ " . ,.~,'Jr:; t,i~~.i~.; V f~' ~-."t'(':Rfi! -i'':: ~::::'(:~i!"l:':~f'''i\., ~. 'I,.", , . _ .' ,f" (, ~ f,,,,_,~ . ".,,1' ~ fo,-i\' In I ~~!{ii~'i'O\';:i \ii~11j!.{K\~, ! b). {" j :',,,~< ;]i"'" ..-,. " ;i::~i ,i"i /t...i ,il :>Jitli;j~IiCJ}~;~:<i~:.'~"J fHjL..1-(~ .day M. ~<-. ~.u , t'-)./,-,-< a.~, ~ # ~ f'lllmonmar</ - ,~~ ,l!!W:lIil'!I! ~, , - " , , I "~ ~ =~ 1\;":'"' '"~'_~r.M' ~'" > :; H , I:"~'. ,!. ~,JJj: 1. ~,~ '"'"'1 VERIFICATION Thomas J. Williams, Esquire, of the firm of MARTSON DEARDORFF WILLIAMS & OTTO, attorneys for Defendant Lynn Watson in the within action, certifies that the statements made in the foregoing Petition are true and correct to the best of his knowledge, information and belief. He understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 4'"!....#I--~ IN~ Thomas J. Willi -r""""'l'''.~' 'ie- 1'1 CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Petition to Modify Custody was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Thomas S. Diehl, Esquire MISLITSKY AND DIEHL One West High Street Suite 208 Carlisle, P A 17013 MARTSON DEARDORFF WILLIAMS & OTTO By Tricia D. Eckenroad Ten East High Street Carlisle, P A 17013 (717) 243"3341 Dated: June 2, 2003 "~I':.,_n,," , ,,.. --, - ~. ~,~ "~'" " ,1'Ill, ~ fl' ... ~ '''''''~',," [~- ,JI.,.,~""",_~,,'i\''''_)'''"''!'' ~. .w=~" '" ~, -~ ' ,~ ::" 'C.l- '-<,- ," ~"_."j--' " ~"'- ;;-;""&'" ""'':-.''''~''''"'i"0::tf't)~,,':,;;;'.,;':,c'''';bttl~B ":tlll,;frli/"'......"~'.<;nr~;;,11~1_f~'i!~f-:'HX~4)1t'\~!~~,-: (") c: co c '-' _(4) 1 ~ ~; c~. ~ -0(' 'Z~t .-;, -:7 [ , CJ ~, ~ y.;~: r<' (> r::;t- , ,. ....,-' -,-'! -- ~~_fA '"" ~ ?ZC) W ....... _0 :,,) :<>~, -~ 0(\ - ~ -.~,,. '.Jl :0 --.J ~ '2 ("F\ -< ~ 't.l ~ '0 ~ ~06{J '!'f_~~~'ffi imJ ~f!I!lI!!lliH~:I\"!'1lPii;ffl\"'";p,.'"""'ir-'"t;;"P.'4l.1l,~Hj;'.-'''Ifi'i..,-l'ifi$!~Wljl\l!~~mi!!)il~,k.,~,"~"'~~~~~ :<;"''''i'''.'-'''''''''''''-',*, JUN 2 ~ 2003 ~ CHADWA'fSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2001-6088 CIVIL TERM LYNNR. WATSON, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 2S1h day of June, 2003, the Conciliator being advised that the parties have reached an Agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, fl;L,i- acq ine M. Verney, Esquire Custody Conciliator <"~--"'"'''''~ ,~ ~ ~ , . - 1 _!'II ,,-,~ , ~ifJ!lIUJl:_~ifi~ilWt~ --- . "'''_-''"H''"''_~''''''d''" """jltT'~W~'nr r t"1l1"fTi'fil111r"jj{I"#1."lr1l11nnl' (') 0 0 ~ w ., , _-4 -oO:J e -..,'~ ~93 z j-'i1;;t zc N :,;1 ~.q (Q2~ cr, 'l ~c:; ;~ .) "'0 :j;:::fi ~r ::r. '.>'0 :J>@ N brn ~ ;;! +- ~ {5>~ B ~,,~ 'klr~-$li!!'ZllfMi:;l'!M"."':fI~"~",.~""_"F'''1~1.",, .,:, ,!m:;;'WnF''''!NiC-''''~'''''-'''~~;''~-_'!-\ "'--'>"".l~r'?f>'~Nm'-~._~j'H~~llf~~i!lJ!~~!~;'