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Home My WebLink About01-06360 '"..~"~ '-'" __~,'",".'I,"'."'ri',;",o'~'",, "'""F""',' ';,L-' I'~,;',,",",(' "n,J"i ..' "~""'"''''''''''''"''''' _ , ',-" . . -.. '" ..". "' '" II '... I . ... --, .~:',' ,"'i:,":; ,'';'', "',, ,-' """;:fi: t. NOV 2 0 2001 ,W ,. TIMOTHY ALEXANDER AND PATRICIA ALEXANDER, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CNIL ACTION - LAW : IN CUSTODY WAYNE D WICKARD AND LOIS L. HURRELL, Defendants : NO. 01- 63(;0 CNIL TERM CUSTODY AGREEMENT AND ORDER TillS AGREEMENT, made this 5'1A day of NDll'eMW ,2001, between Timothy Alexander and Patricia Alexander (hereinafter "the Alexanders") and Wayne D. Wickard (hereinafter "Father") and Lois L. Hurrell (hereinafter "Mother") concerns the custody of Father's and Mother's two children, Robin Wickard, born December 25, 1986, and Tina Wickard, born November 3, 1988 (hereinafter "the children"). The Alexanders and Father and Mother desire to enter into an agreement as to the custody of the children. The Alexanders and Father and Mother agree to the following: 1. The Alexanders shall have sole legal custody of the children. 2. The Alexanders shall have primary physical custody of the children. 3. Mother and Father shall have partial physical custody of the children as the parties agree. 1 , ~ ~." b '_ -'" ," --,' " _A""' _' '. "-" " ~'OJ ",:, ",I t" , ", ,', >$;"'; ,,- ',c,h.':,,;.,.j ,; ~"" " ". ,; ..,; ,;,;;;', ;X~ " ~ 4. No party to this Agreement and Order will do anything which may estrange the children from another party, or injure the opinion of the children as to the other party or which may hamper the free and natural development of the children's love and respect for the other party. 5. Mother and Father have the right to petition this Court to modify this Agreement and Order. 6. Father and Mother understand that the Family Law Clinic represents only the Alexanders' interests in this matter and has advised them that they should seek the advice of legal counsel. Father and Mother understand this and have chosen to proceed without counsel. 2 ".1 >>, , ~, ", , ' IC,",~' '" ' ,:',0;,:> c"~ ">'~';';""'&.:-""'''''' ,,j ':;;;ci,,; ";"':i:i , .... ,. 7. The parties intend to be bound by the terms of this Agreement and intend for this Agreement to be made an Order of Court. 'W~ (). '/,./~ Wayne D. Wickard, Defendant ~~/A ~- Timo y Alexander, Plaintiff :ttNA nf 7jJ/M~d Lois L. Hurrell, Defendant ~/; ~-t-) atricia Alexander, Plaintiff ~d?~.~__~ Lily L. Cheung Certified Legal Intern J?tkfK~~ THOMAS M. PLACE ROBERT E. RAINS TERI L. HENNING Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ORDER AND NOW this 7flfL day of ^J 1>\.11' "'? ~rJ ,2001, the above Custody , Agreement is approved and entered as an Order of Court. \ r - \ G>.w c.pn ~O(\C"J\y ~IJUI ;-01"0.""'( fYI 1 _I fb Lo ,"s /-Iwd / Oftd 1'1"" (Vl WayrU. iN, '(..kb. d 3 >- ?: b; ~ :z: "" :::)<C ,_. N UJ'q ()=- (:-,)2 ( ")-"'-;:- ~-C _. <C ~-( ) ':)3 i..2----T [,-- :':,5\::-, c' }~UJ ,o}L 0J :-::Jz ~~J ~:~ ' ;',I,: :z: ;::;-:<" cJ.JuJ .-- - C:J cD 0.. ~ """:;' r'-- ...~ L_ "::> 0 0 b "". to .~ '''''"-', '., --,~ "~ .'..,>^ OF ';1 ~,:'~~7H ,'::~~~~.~rt~~)TN;Y ,. P. \0 il'1. "J'i '1m} 20 ,i1 . ',h. l' I r,~.'" ct ndj;2t.'~~Ut.\rD COUNTi ""PENNSYLVAI\jIA ,'" ~.="...,,~,'",' --~ "-",,,,", --, ".--~ '" ."^.,,'<,," ,~,'-""-""- ~ .- --,,~-- .... 1- ~ . '^ ~, ~1'iIl1"U,H '<, "L"" ~.!I!'~~~'~Tifli'!\'~l'<iP'1'iI{~--f')'~1'n<;$.,~~~~~~W;i: -u..... , '1", ,,~ -';,". ' <> C _ ''-''~ . ,',:' ':,"", ", ,,", "">'""'~"'-'k3""~'.q~," l""""'~iiJ"Jj~~ TIMOTHY ALEXANDER AND P A TRlCIA ALEXANDER, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY WAYNED. WICKARD AND LOIS L. HURRELL, Defendants NO. 01- &3100 CIVIL TERM CERTIFICATE OF SERVICE I, Lily L. Cheung, of the Family Law Clinic, hereby certify that I have served a true and correct copy of the Custody Complaint to Wayne D. Wickard, at 13 North Hanover Street, Carlisle, Cumberland County, Pennsylvania, 17013. Service was complete upon receipt by Wayne Wickard on the 8th day of November, 2001. fflr4 Lily . Cheung Certified Legal Intern F AMIL Y LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243-2968 ",. ~__~~~_AWi~J-~~h'"':ID'l\w"id:lJ~!iit~:t1i:jli'jlil_ilr""';;'i;;j,.o~;'". t ~ - .' ",' ~u~<"-,, ~ ,.~, oo.j1 "'i~ () 0 ~.J C r: ~ ~ ue~:J 0 mfn ..c: -"'-,1 ,--' ..r.__,A ~~:' N 1----::'(; ~ <:::l ~ ''':C) , r;:::C -n :~j~) "0 1>C Z -c _.,,~ ;;~' --L' :~~f~ >c::' r" \,-"' Z ~ ~;; ::< a :.D --< ;lllJll>,,,u """"',^,,_ ~-" ,~_, ',,' E"," ,. A,,",,'. _"" ,,..~, "-",~,,~,,,", "~' ,"' ,^'~. ~, -~, "~ ",,- == -., ~",~ . ' ...~ " I';, , ,.,,,.1 ,',;', ,~", "..;:",2~,M,,",,"'<oi- " F0_tlblfr.b'i1 TIMOTHY ALEXANDER AND PATRICIA ALEXANDER, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA WAYNED. WICKARD AND LOIS L. HURRELL, Defendants () 0 C) C '" ~~ ~~' Z:C:- 0-.' CIVIL TERM <;:?"::,: c, , ~tj ,,' ~('-:-,' -,.. CERTIFICATE OF SERVICE ;;: 22 t:-? ,y z :..J =~~~ I, Lily L. Cheung, of the Family Law Clinic, hereby certify that I have serve~ tnte='and:2 : CIVIL ACTION - LAW : IN CUSTODY v. : NO. 01~ ~ 31.00 correct copy of the Custody Complaint to Lois L. Hurrell, at 13 North Hanover Street, Carlisle, Cumberland County, Pennsylvania, 17013. Service was complete upon receipt by Lois Hurrell on the 20th day of November, 2001. ~Af~~ Lily L. Cheung Certified Legal Intern FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, P A 17013 717~243-2968 ;~,;M'~!lM;!!l1\iiijll'l\!~~",.'!i~'4iliilil~-;j~~d~.tJ"'..i~l:;iW~~4",~'.wf,j'<ll1h,,~~;iA. ,""",. ..~" <,~ .~.. ""'~, ~ )'17 . () C') C) C "Ii s:: Z __~l rgUi C:::l IT, ~"~ Z"T' ~~~': f'V <::> ~C~ -C' J>C ::::i.: ~ Zr} 1''' )'>2: ;::) ~ Z :..:> ):;~ -. ::g -< -, .JI ~~. ~"_"''''''''--''''""''''' rd"~~'" """",~"",,,,. "., ,~.-'J',~ 'r.' ~ ~. ,,'~'.--"'"' "'''' .~ ~i:: ., 'l' ,", - liil ,-..ii--'jr;'" '~;1;~f1. ~ ,,",".-, TIMOTIIY ALEXANDER AND PATRICIA ALEXANDERLAINTIFF IN TIIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, 01-6360 CIVIL ACTION LAW WAYNE D. WICKARD AND LOIS L HURRELL DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, November 26, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and theirrespective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland Connty Conrthonse, Carlisle on Tuesday, December 18, 2001 at 10:30 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 TIIE COURT, By: Isl Jacqueline M. Verney. Esq. ()lM- 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 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 ....., ;"6j,';w,.,:ie>4:,iii.il!i1li~~1iiii,i~!l~J~;;:!1Hh'1',~"~,i,fMi\;Ii&,t;l~i!;';';';;&lifl'#.>,";!,k, ",~,~I'~ ' - - ---- ).> ; 1-~ r ",'--_'c"o""..' ~G;-'>> "!;",',",,i!~'i':'Il!U~'~ill3lIij(lttl!Ii!~"W"""'"'E' ';;i!ot'lS<f>t\lo\~~_'lI"l~lj~~- ~',;""~,)",,,,,,,,,,",,"~,,,=,,~,,,~.,,,,~, ", ~ =O~ ,_ ~,"'_"<",, ,',""~,"~''!-<:k ,,,', v"" ~." _ ,_ .,,", ",'~" ,_~ '. " <,".. g 3 ~ 1 iP & ~ 11, t' ~ 1 ~~~ ~, ~ ql ~ , ~cr. r 1;r> fJ t ' ~ ~ ~t'r'. - 1" c4~..:J . ~. €" _" ,,,"'~ ." .;, '..,~ ..~ ""O""~"","" ,. CJ ~~ ""00" P}LT ~~~ r;:c; ~ :PC' Zb PC: 7' ::;\ ,="~ .,-y, ~ '"' ~ '- .-'-, ~~~ N -....J ""D :1\: r;? N (n 'F '''1-, . '1~=-1 "::~si ~~ i..-; --; ~ '< , I ~- ~" ~, . '^'~ ", , '" -c. ,." ,,..... < ' , ',,~ ",," "",.:,;.L,'~"';-i'.~.-;O-"",~'~",,< ,,',:., "f-'~01'~, .' , I v NOV 15 2001jlL TIMOTHY ALEXANDER AND PATRICIA ALEXANDER, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CNIL ACTION - LAW : IN CUSTODY WAYNED. WICKARD AND LOIS L. HURRELL, Defendants : NO. 01-(P3~ CNILTERM ORDER OF COURT AND NOW, this_ day of ,2001, upon consideration ofthe 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 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. 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. .~ ^ "-->,', ~", ",> "l,""' J.c',,,,",,,,,,; '", '" ,~,',: "'I'~':,--~",,,, ',';.' "",'<,~,,~. ':"'~, ,:-.~ ".",~,'; ",':',--';" . ,,,.+ 'I TIMOTHY ALEXANDER AND PATRICIA ALEXANDER, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY WAYNED. WICKARD AND LOIS L. HURRELL, Defendants : NO. 01- &3l.RO CIVIL TERM COMPLAINT FOR CUSTODY The plaintiffs, Timothy Alexander and Patricia Alexander, by their attorneys, the Family Law Clinic, set forth the following cause of action in custody: 1. The plaintiffs are Timothy and Patricia Alexander (the Alexanders), residing at 7 Kutz Road, Carlisle, PA 17013. 2. The defendants are Wayne D. Wickard (Father), residing at 5 Kutz Road, Carlisle, PA 17013, and Lois L. Hurrell (Mother), with a last known address of 110 EastMainSt., Newburg, PA 17240. 3. Plaintiffs seek custody of the following children: Name Present Residence Date of Birth Robin Wickard 7 Kutz Road, Carlisle, PA 17013 December 25, 1986 Tina Wickard 7 Kutz Road, Carlisle, P A 17013 November 3, 1988 The children were born out-of-wedlock. The children are presently in the custody of the Alexanders, who reside at 7 Kutz Road, Carlisle, P A 17013. "" ---'" .'" ,. '.",'do'~"" . "'~.'" ,~.~,"-- "",','- ,.I,c '~ ,O__:';','l,'" h'.,,-;', '.-- J.~':o-"-"'-----"2"",',~) -- -- ~ -- "''iiiilll&M,; .' . During the past five years, the children have resided with the following persons and at the following addresses: Persons Addresses Dates Timothy Alexander and, Patricia Alexander, and their children 7 Kutz Road Carlisle, PA 17013 9/17/0 I-current Lois L. Hurrell, 110 E. Main St. 1/01-9/01 Dusty, Bill Nailor, Newburg, P A 17240 Jessica Hench, Melvin Hench, Katlin Nailor, Sierra Nailor Timothy Alexander and, 7 Kutz Road 10/00-1/01 Patricia Alexander, Carlisle, PA 17013 and their children Lois L. Hurrell, 40 W. Yellow Breaches Rd. 01/00-9/00 Dusty, Bill Nailor, Carlisle, PA 17013 Jessica Hench, Katlin Nailor, Sierra Nailor Lois L. Hurrell, 217 Kutz Rd. 01/97-12/99 George, Jessica Hench, Carlisle, PA 17013 Katlin Nailor, Bill Nailor, Dusty Lois L. Hurrell, Betty Nelson Trailer Park 01/95-12/96 George, Jessica Carlisle, P A 17013 Hench The mother of the children is Lois L. Hurrell. Her current address is unknown. Her last known address is 110 East Main St., Newburg, P A 17240. She is single. The father of the children is Wayne D. Wickard, currently residing at 5 Kutz Road, Carlisle, PA 17013. He is single. l =~= . , .." ,-. ~' ""--~''''-'' ,I ", - ^<, <'i,;.,"'1;',;,;-"',,;'(d,;;.\"";1.''_, ~ "<'!;'~f'~"'T .' " 4. The Plaintiffs are standing in loco parentis to the children. They are married. They currently reside with the following persons: Name Relationshin Corey Alexander Rebecca Alexander Tenley Alexander Thomas Alexander Timothy Alexander, Jr. Kaley Alexander Robin Wickard Tina Wickard daughter daughter daughter son son daughter 5. The relationship of defendant, Wayne D. Wickard, to the children is that of father. He currently lives by himself. 6. The relationship of defendant, Lois L. Hurrell is that of mother. She currently resides with the following persons: Unknown 7. Plaintiffs have not participated as parties or witnesses, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiffs have no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. Plaintiffs do 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. 8. The best interest and permanent welfare of the children will be served by granting the relief requested because: a) Plaintiffs are the primary caretakers of the children. b) Plaintiffs provide the children with a stable home environment with adequate moral, emotional, and physical surroundings as required to meet the children's needs. c) Plaintiffs are willing to accept custody of the children. d) Mother and Father have indicated that they wish for Plaintiffs to raise the children. e) The children have lived with the Plaintiffs in the past. .1:: ." , ',,"',., ~J..~' _,' ~, ,',", ., ,h ,~'^ '" " c.__' h'.k" ",'" c.",,< .,"',;;""',-,, k'"r"'~-'i!>l:';'~,i'--,i"1i'iilir~[]I~if; '. . ~ 9. 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 as parties to this action. WHEREFORE, plaintiffs request the court to grant them sole legal and primary physical custody of the two children. Date: /1/ '6/<=>1 4U1~~ Lily L. Cheung Certified Legal Intern ~E~ THOMAS M. PLACE TERI L. HENNING Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 'j . " ,.'~ ','" '.' '~,<, ',,-<.,, ,'. 'c'", "~"~'" ,,'--, '" .1, '" >o""'"",'~_s,~~,',;";;:",.&""L;,,,,i::-~,i'~' ,;- ';;'-e.-'-'.:i:': . 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. Section 4904 relating to unsworn falsification to authorities. Date: II )7/"/ v J~ &L- Timothy Alexander, P aintiff Date: 11/1/0/ / &L~" ~: ';);;;'~"&WI,"'~lm'l~tiWllMJlIIl~~~~~,mAAt.m~~,~,,~i,t,,-,*~~:';~MfI~__P' .H II ::-'\J ~ tl 3. ~ h E". G - -< ~A (\ 0!.JJD>""~,,,,,, ,.~ . """""=.~ "..A'~,C~="~"<"'''''' ~",^-""">.",, ,,""'"'^,"'~=,',E" ..,,,,",,~,> ~~ liiilllilil "--~~,.,, " ,,,~,,, ~~. '- ~~ ~, -",' ~~: c/; r: ";,, ,>,_-. S;f: z -, -< - c:.:;, [":1 f :) ~ 'b --< (,0 . ,,",' 0' O' ,--"", __ .~,;^'"' ,I,\.~ "" ",' ';"t,.."""""!,..,',i;j,~,:~,jf""",;,5,..,,,,";-<, ''''C:'''/;';,I . NOV 1 5 2001tJ.. TIMOTHY ALEXANDER AND PATRICIA ALEXANDER, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY WAYNED. WICKARD AND LOIS L. HURRELL, Defendants ; NO. 01- tJ;3CoD CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Timothy Alexander and Patricia Alexander, Plaintiffs, to proceed in forma paupens. I, Lily L. Cheung, 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. Date: f I I >J /v ) ~cJ1~~ Lily . Cheung C'\. Certified Legal~tern ~ ~E.RAlNS THOMAS M. PLACE TERI L. HENNING Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 ,,'i ;~:J:"",",~;j;JIiti.~~Jl'",,,j!;.:.iiEilil'm~~~ll~.!i;j*'ilt-.--l:,..U;-,8&.li,,!M.Jjj-~~'Ill~~_J~"'" '~ .h""- :,in ~","'" ,', () F'"' '~,...' C~, -'"," ~:~ E~''- ~:_) :~~f' I ; (f~ (;7,) -""-'::--",:' ~ C,: Z c:' -" ';:::::"() ~::? ~ .-'~?r Z ~ =< ~,.. (" ~""~ "r "' -< "",1~,'" ,~,.~ . ,~ ,~= ~ ^~, ,= ", ~, ..,---,~ . ~, --, ~ . TIMOTHY ALEXANDER and, PATRICIA ALEXANDER . Plaintiff V. WAYNE D. WICKARD and LOIS L. HURRELL, Defendant ~' = ,. ~ .........1........,"""-', ~ ~ [' ~, ~ ~ "'~, ~ l~' O-'<"""'iA'd DEe 1 0 20~ : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001-6360 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 10th day of December, 2001, the Conciliator being notified that the parties have signed a Custody Stipulation in the above matter, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, tft1.i tody Conciliator "" ~ ,-",'ow ",..~,'"'~. ~ tfd 53 w~ ~~,,"", , n "~" ""~~,, ~"',~' _. ':\,I.r);(.,f:\'~qhi'RY "( r; "1 P k~ ? ~ L. \ Ollk.:'o. .1, . o . ,-.y,\ 'NTi CUMF\l:.KL..r\j'~L.} liV...JI ?ENNSYLV/\NtA ,....-" ..'~'" ~" "' 0.... --," ,"-' ~~"..,,~ '~ ......_llI'l~,~I~.."'t','"\''','''''''l''l.;-'i'.,,!,,\lttp".I!!fl...'';-u0F~ffi'FIifF",Pffl~.1li\;j'\~~..""'''1"""",.",~,~;I!I~'.., '....', ,,~""",~""2,~