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Home My WebLink About01-7165 FX ~- ~. L.' ,~~ - Todd W. Newhouse, Plaintiff vs, : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW ~ NO. 2001 - 7/1.U" C'u,L '7-~ : CUSTODY Jennie 1. Conrad, Defendant ORDER OF COURT AND NOW THIS ~n.,( day of ~ ..~_. / January, ~/ 2002, upon review of the attached Petiton for Special Relief, this Court sets a hearing in this matter for ,IfhJu.'dl!l-Y , the +;.d.- day of ~.m.L/.I'" ~_=i 2002, at I d ;0 0 It,In',f 1(4. in Courtroom # L of Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, Ifi J. Cdf'I ~ to ~~ 1/r1-JOJ.. ~ ~~.s 1~~'('b~~1 ~IWI'\- -[0 J::b.(!e/V.e. ~ 4-h2\/J La0 t;i/o~ ~w ~" o 0- ir~""';~f Todd W. Newhouse, Plaintiff vs. : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2001- Jennie 1. Conrad, Defendant : CUSTODY PETITION FOR SPECIAL RELIEF 1. Petitioner is Todd W. Newhouse, father of the child, Isaiah 1. Newhouse, and plaintiff in the above captioned matter; petitioner currently resides at 1806 Centerville Road., Newville, P A 17241. 2, Respondent is Jennie 1. Conrad, mother of the child, Isaiah 1. Newhouse, and defendant in the above captioned matter; respondent currently resides at 1808 Centerville Road, Newville, P A 17241, 3. The child, Isaiah 1. Newhouse, is 11 months of age and presently resides with his mother at 1808 Centerville Road, Newville, P A 17241. 4, Petitioner incorporates the pleadings as set forth in his Complaint for Custody herein. 5, Petitioner believes that the absence of a temporary order is contrary to the best interest of the child because it allows either parent to remove the child from the Jurisdiction of Cumberland County. 6, Petitioner believes that the Respondent is to going to a Rehabilitation Facility some where in Chester County, P A, for violation of her parole, 7. Petitioner believes that the Respondent will be leaving in January 2002 and Petitioner is trying to take the child to this Rehabilitation Facility with her. .~ ~ '""~~. li' WHEREFORE, Petitoner respectfully requests that Your Honorable Court set an emergency hearing so as to set the parties' rights herein in regard to custody of the parties' child, Isaiah 1. Newhouse, Respectfully Submitted, Date 1;( - eJI-O! ~ane,ff!t:a / /M!- Attorney for Plaintiff Attorney I.D. # 86898 ABELN LAW OFFICES 37 E, Pomfret Street Carlisle, P A 17013 717/245-2851 =~ ".=- :,t_ VERIFICATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. g 4904 relating to unsworn falsification to authorities. Date\f--l I-u\ ct LtY1J Todd W. Newhouse, Plaintiff L~ ~ " """'.,""'~^ ~''ii Todd W, Newhouse, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO, 2001 - Jennie 1. Conrad, Defendant : CUSTODY CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing PETITION FOR SPECIAL RELIEF by mailing a true and exact copy addressed to the following: Jennie 1. Conrad 1808 Centerville Road Newville, P A 17241 Respectfully submitted, Date /) -;2/- 01 , AJN LAW OFFICES ~7~ Darlene F, Cramer Legal Assistant 37 East Pomfret Street Carlisle, PA 17013-3313 717/245-2851 1""~,~:","&,'.$'''''.W'''',,,,,,";,;\;i..~,I;-,~';,!lli'~h''.>'ll',,,,lli~,>i.,")'''''',,",,',';;'".."'~~ \',,) ',--,"01.00,.':,,,",.-,, ~i2'''''J,'',^'.J"'',':\:d,,,':k,:;;,,,",,,,~,li!f''''''!l~i.l!:''*!I'i:lM",,,,~,,;i/iIl8i-=-',ru,"lJ!,."'.....~;Ijl."L~_~_ft- ~ 0 0 c:l 0 ~ ~ " -OED 0 .-, t 0 mrrr "'1 X" Z::r:' n ~'1-~ ...... -- . z,.. N "oFn ~ -.J 0 (j'))> e<jy :::';7 (;, C> r: ('--""I ~~ ~... "'tJ ?fo ::r 'dR \l' ~ :'Pg w 6m ~ ~ ~ '0 ~ -< ftii!~\~~~_~~.~~":(~l~atk~,_,_;JJ:",,,llJ~l:.,,~Jl~~"-\\, .,J,JU.~;w;]~~[,,~~,,",,~,,_ '~~JtbJJ)JW\~~~r" UliA,," ~ _" ~, I __ '--..... ~..; ,_", ,1"_, . ' ".~ _._.L."~-~~'-<:I""_' ~""~""~,', ... .. .... TODD NEWHOUSE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. v, CIVIL ACTION - LAW NO, 2001 -7165 CIVIL TERM JENNIE CONRAD, Defendant CUSTODY CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing PRAECIPE TO WITDRA W REQUEST FOR CUSTODY CONCILlA TION by mailing a true and exact copy addressed to the following: Jennie Conrad 1808 Centerville Road Newville, P A 17241 Respectfully submitted, Date / - '-/~ () ( A ELN LAW OFFICES Itl/Luv -;! t!uv~ Darlene F. Cramer Legal Assistant 37 East Pomfret Street Carlisle, P A 17013-3313 717/245-2851 ,;~~>i;!!i~.!\!!_~~M1~~~"<~.:J.-J;J~~li'W!ik"j&"-k''-''',,c.'j''R",,'-~'"-j\, ". ",,,f,i,;,',,,,j:;j-;,,z ii'h"",-@&~l:}i~H"dRi1\;!Mwn.w-,'i1Hj{&.IWiIi!." ....:."""". j2i;l ;-," ~~.'~,'~-- _~ iL8i,-~[j ~l'b!t~1r :ii" ,.. ,. .. 0 0 (~ c: N -Tl ;? '- -oU~ ---, ~ ~~~ -:5'" " " " 7t;.: I '-,~; ~; ~,-~;:. .>" ; ~C:, . ~i~ """ ZG~ ::::0: 'i2 (") '.C 1'1"\ )>C '..f! ~~: z r:- ):; =<! ::0 ,=> -< ,li",IJI,lU. ,:"10 " ,,~. ~~~,' , " ,: ~ ~,,,,,,J~,<>~,o""",,,~~,, ',~P, __ ~ ",".' _""_d "'__ .~. _,0"_.""",,,,",_", "-"~_'-""'" .~.""."~_",,, "~"""'''",",,", CM' "'"'"' ~ ~ ~~~-"_. , ,_I."-~ ~~ . ~~ I.'_~~\\illili>ii"~' ... - TODD NEWHOUSE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. v, CIVIL ACTION - LAW NO, 2001-7165 CIVIL TERM JENNIE CONRAD, Defendant CUSTODY PRAECIPE TO WITHDRAW REQUEST FOR CUSTODY CONCILIATION TO THE PROTHONOTARY, CUMBERLAND COUNTY COURTHOUSE. Please mark this Request for Custody Conciliation as withdrawn. Respectfully submitted, ABELN LAW OFFICES Date '1 /-( /0 Z ~ Brian P. Raney, Esqurre ID #86898 Attorney for Plaintiff 37 East Pomfret Street Carlisle, PA 17013-3313 717/245-2851 - "'~-~-"~~ '~ .-' ~' -..- 'y-- "J.'~ ili-- . Todd Newhouse, Plaintiff v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA CIVIL ACTION - LAW NO. 2001-7165 CIVIL TERM Jennie Conrad, Deitmdant CUSTODY ORDER AND NOW, this ~ day of :I? nv 71 1-' 2002, upon presentation of the foregoing Agreement, said Agreement is hereby approved and entered as an Order of Court, 1. 1.:,;;ki,,'~'0';'---~o'W-,,;i'"''''~ktl::'',j.',,*,di.,C,)')h,;'''t, "'..'~ 'i&IJi_-\;'""","i;>,,,,,,.i;'i"-'-A,,~ ~,!",'i,'4. '~"">""',-;."-><"'-"",!OCilli:#~~j!il,,;rn:@i~.#iiMil'l%l,!Ml1illii~!kS....li~Ji,\lllf~_i_____ ~i ft n~ ~ \1IN'-I' ALN()o:-N}Y};:;,!~Q1 "', ,~I ,~t::,,:,;~-{,!;\I()" ""' . h.) [hI -7 "V,(. 1,1 I 1(1 Y/- NU{" 70 ~ ;I I..e' '(j!1~'..,','r'" 1\ I" '-.{-', I -'";6i;~:!-;~UT!d Ii ,- :}U lI[!ll[[ID_ rno 1 ~~&",,=_M'Ii'''''''',. _,..,,",,,~~~ ,~ ~ ~"'_ ~" '"~__~'"""".cJ':"',"-<'._"~;'''"~'_'-=''''''' '.,' _" d"-'l, .c.,'''''''' , ,,, -",,~~,"".. ""~,~_. ~.~,~ . < . >~ lIIil.r::; ... . . .. Todd Newhouse, Plaintiff v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL ACTION - LAW NO, 2001 -7165 CIVIL TERM Jennie Conrad, Defendant CUSTODY TEMPORARY CUSTODY AGREEMENT THIS AGREEMENT, made this 4th day of January, 2002, between plaintiff, Todd Newhouse, (hereinafter "father"), and defendant, Jennie Conrad, (hereinafter "mother"), concerns the custody of the child: Isaiah 1. Newhouse (hereinafter "child"), born January 21, 2001. Father and mother desire to enter into an agreement as to the custody of the child and to have this agreement made an Order of Court. Mother and father agree to the following: 1. Father is an adult individual residing at 1806 Centerville Road, Newville, Pennsylvania 17241. 2. Mother is an adult individual residing at 1808 Centefville Road, Newville, Pennsylvania 17241. 3. The parties shall share legal custody of the child. 4. The parties shall share joint physical custody of the child, 5. Mother and child will be temporarily residing at Vantage Drug Rehabilitation Center beginning on January 6, 2002 for approximately 90 days. 6. The father shall have custody of the child every weekend during the period the mother remains in treatment at the aforementioned Drug Rehabilitation Center. 7, The parties agree that the father may have custody of the child at any time, which both parties mutually agree upon. 8. This is a temporary order that the parties intend to modify at the conclusion of the defendant's treatment. e-1JlM _ Todd Newhouse B~ Attorney for the Plaintiff ABELN LAW OFFICES 37 E. Pomfret Street Carlisle,PA 17013 ~~~ -. . J/bd.7 (~ ".~..' 0 ~ ~:j.,[;- , _.~ ~~ , _.d, '_ "~, - - .'0_.""-___" -1; ~ Todd Newhouse, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. v. CML ACTION - LAW NO. 2001-7165 CIVIL TERM Jennie Conrad, Defendant CUSTODY CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing TEMPORARY CUSTODY AGREEMENT by hand delivering a true and exact copy addressed to the following: Jennie Conrad 1808 Centerville Road Newville,PA 17241 Respectfully submitted, Date l- Y -{J I N LAW OFFICES , h.~/M~ Darlene F. Cramer Legal Assistant 37 East Pomfret Street Carlisle, PA 17013-3313 717/245-2851 ~"_M",1<;'-~i~'C;;,,~~-tJ:;i.;;;'*'~'iL"".fif,t~hWl3':;:'1billi!ffi\1~.~"1.''''"&)\!t"ji-""~"""',, J";'d!"<,'l;-;~,,~":;'~MlMj~""'-ii<',,"',~'};-I'li'~;lli~"~W..Jlii1Bc!i>~J.i;llliJll,,,,~~~--".~~~ !1...ill!.LJ.llUlIIJUUI U j " . .~ ,,~ .... .., .. '"~.. ,,,.~"~"~., . () c -ofi.~ IT1tt: ':;;-... Z t~~~' (fJ _,;-- -<' -~'- r:::c "'- " - ~ Z'o....:-' )::. C) C ~ =",~~~= 11I"___ N '::J ,J:- ~s (3f/ Cl N ? ,-,~... ~ ~g , ...- '-;-'1 'I' C\ -l'y :b !..) \, ;'i1 "" "'0-; SJ -< ~~. - . ,,- .,. ."-^-''''-~-=ili,,>:-'';, TODD W, NEWHOUSE PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 01-7165 CIVILACTIONLAW JENNlE L. CONRAD DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tnesday, Jannary 08, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqneline M. Verney, Esq. , the conciliator, at 4th Floor, Cnmberland Connty Courthouse, Carlisle on Wednesday, February 06, 2002 at 2:30 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 auy and all existing Protection from Abnse 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. ~ 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 A I ""f<,,~;C;"dc_C;"'i";';eor,~... ,:e",-d" i'-''' ;,<'~M",._<, ',ffi""'''-1,'>:;''''''"~'''-''lt.:~-,-",.;~"",,~ ,",,,~;,.j,,,,,--,,_,, ~ ;,'.~,,,:,;",,,."l\i>I>M',,--W'J;m.'ilal'fI@f___j!i_~_"-:f""""""_"'""""'~"""""_"""'"~~~=.._--"~.~-- , ~ ~A&l }J ~ ,~~ 7 ~~~-rP ~~ ~ IL"L.1L~J.Il..LL,., _.,,,___,,, '" '~'_'''''''_'''''''' ,~"__,,,. ",", """" VINVl\lASf\lN3d ) l~ln'~~1 r,"""" ""',"''''''(,; \,. ,\; ".).," ul ,,",,' "'~l:!;~jV'i)1 \v (1 i :(: t"~d qo> ,"..,,1[' 71'1, I"J \.. L,-W Ab\:~"L ~'~...H'<"'''''''~''_ .~.".^' ... ('e? ;. ( C'O',$. ( CrJ:P ./ , !Ai 'I -.m'-k:t', Todd W, Newhouse, Plaintiff vs, : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW ~ NO. 2001- 71~S Cio;{ YS'Lr[ : CUSTODY Jennie 1. Conrad, Defendant ORDER OF COURT AND NOW this _ day of ,200-, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , Esquire, the conciliator, at , Cwnberland County, Pennsylvania, on the _ day of , 200-, 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 issue to be heard by the Court, and to enter into a temporary Order. All children age five (5) 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 Cwnberland 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 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, Cwnberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 " . ~. .' ""'f'jjJlj'foi/: Todd W, Newhouse, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : CIVIL ACTION - LAW '"-- ~ NO. 2001- 7/t,S' C'oiL I~ : CUSTODY Jennie L. Conrad, Defendant COMPLAINT FOR CUSTODY 1. Plaintiff is Todd W. Newhouse, who resides at 1806 Centerville Road., Newville, PA 17241. 2. Defendant is Jennie L. Conrad, who currently resides at 1808 Centerville Road, Newville, P A 17241. 3, Plaintiff and Defendant are the natural parents of Isaiah L. Newhouse, born January 21,2001, Social Security Number - 167-80-6940. 4, Plaintiff is seeking custody of: Isaiah L. Newhouse 1808 Centerville Road Newville, P A 17241 1/21/01 167-80-6940 5, The child was born out of wedlock. 6. There is no current custody order, 7, During the past eleven months, Isaiah has resided with the following persons at the following addresses: a) Jennie L. Conrad Joanne Conrad Roger Conrad 1808 Centerville Road Newville, P A 17241 from December 1, 2001 until present b) Jennie L. Conrad Todd W. Newhouse Colby Newhouse 1806 Centerville Road Newville, P A 17241 from January 21, 2001 - December 1, 2001 ~- .~ ^- H' 1I1'Ar, 8, The Defendant is believed to have been on Parole fora Robbery Charge for approximately the past 2 years. 9, The Defendant is believed to have violated her Parole on numerous occasions because of Drug Use, 10. The Defendant is believed to be going to a Drug Rehabilitation Facility some where in Chester County, P A, for her most recent parole violation, sometime in January 2002. 11. The Defendant is trying to take Isaiah to this Drug Rehabilitation Facility with her. 12. The best interest and permanent welfare of the child will be served by granting the Plaintiff PRIMARY PHYSICAL and LEGAL CUSTODY because: a, Plaintiff is a good father to his son, Isaiah L. Newhouse. b. Plaintiff is very close to his son. c. Plaintiff does not want Isaiah to be taken to a Drug Rehabilitation Facility, d, Plaintiff helps out with all of Isaiah's needs. e. Plaintiff has a good home environment for Isaiah , f. Plaintiff has been employed full time with the same employer for about the past two and a half years, g. Plaintiff's employment schedule would allow him to spend a lot of time with Isaiah . h, Plaintiff currently cares for his other son, Isaiah's half brother, Colby Newhouse, i. Isaiah resided with his half brother during the past 11 months. 13, Plaintiff is not trying to remove the Defendant from the child's life. ~ .. ~"~ ~~ ~ , e~ " ~ i' f~iL'1 VERIFICATION I verify that the statements made in this petition are, true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities. ~YlL Date 12.-~I-oI Todd W. Newhouse, Plaintiff ~ '" ~ , . , ._, --",^,_,~ 0., C-".d ,"" ' WHEREFORE, Petitoner respectfully requests that Your Honorable Court set an emergency hearing so as to set the parties' rights herein in regard to custody of the parties' child, Isaiah L. Newhouse. . Date~l Respectfully Submitted, ~.!J!!~:y //~ Attorney for Plaint};:; U Attorney J.D. # 86898 ABELN LAW OFFICES 37 E, Pomfret Street Carlisle, P A 17013 717/245-2851 -~~ I ~ "'" , , '" ~ ~1,,~ Todd W. Newhouse, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs, : CIVIL ACTION - LAW : NO. 2001- Jennie L. Conrad, Defendant : CUSTODY CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing COMPLAINT FOR CUSTODY by mailing a true and exact copy addressed to the following: Jennie L. Conrad 1808 Centerville Road Newville,PA 17241 Respectfully submitted, Date# AB LN LAW OFFICES 7 Darlene F. Cramer Legal Assistant 37 East Pomfret Street Carlisle, PA 17013-3313 717/245-2851 ,.li8~W"""-w..,""~"""~.J1;:~",",M,*.,,,~,,C~,,,..ti.'1{:(l;r..tllU~,ij~~"H:;t,,"m,,h4,";:;"'~N ",""c~~..d:h.,~'---ti;::.o,'J1"u"",""-,,(!.;':W-fflfMll~~i.,jll!,.!ill!lllHj"..illtij(~~'""_""";'''''-w<'''-'ll_jl,_ t ~~~,4.';'~L~,~~~,:W,~".~Al~tlltJ~~,~~~~~i1fY;1'~~~>:i:h~1!J!;;~",J",,,"^.~.",,JL[[ .~,!lA.J11L,<J2;;~.1.J,LL,,,,,~=",,, "'-'''"' ~ f::1 R ~ ~ ~ ~ v, ;::; " C> 8 ~ ~ ~ ~ '-.:(- (') c ~ "1JCD mrr1 Z:rJ zc en d.:-.': -<-"- r-::.---' ~\.~ )- -~ zV <;:::U -c z :< ,,,,__,,_,,~,"~, """"~'''''''___'' .~ ,~'" ~~~,_~.~~.. ","m~~~ o o f"1 n N o 'Tl :-;1 i'-~':;, 'Tl , , -"Om -~:,Q ,=>'1 ~"lO .'1- -r-, B::D ",;>,0 Om ~ ~ -0 :x ~ (,... -~ ~ .......~ - I 1-1 l' "'~'~"'"~'ijJt:1 JAN 1 II 2002 y.. TODD W. NEWHOUSE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2001-7165 CIVIL TERM JENNIE L. CONRAD, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT , AND NOW, this 10th of January, 2002, 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, 9h. dy Conciliator ,;<.> _til.~!Mfili*~ill<U~g;;tiiM,b-"",,,v,;,'r,"'~'-'--"'c~,;)-,-"-""-'i.1i>"~"~;;~'-,,,,,,".;,,1iJ,,~ :-~l+""" c,'"';_.;d,.""_wlc,,,,':.,,..;,fu,!~/,W-"'iil;*,~'Wifh&1~.j\'t'lOi;,,-ijfill:i!V!~l<<tlli%Wj~t!!_"'"Mt~!(i_Y""" ~. w- \/!i\IV;'\.'!AS!' A.LNr:C() N3d i-~'('i.:"",--.,') ~," , '," ,! ':! I, ~ '1 .r ~ ': fl ; :J \' , . ~: , 'J i , ~, :;J Es I3H qr-,:' l\>.1'7.:"", !IJl\I.LJU ,.=,,'" ~.~ ,~J,~ ^.'~. .."" ~,~ ."~ ~~ """'_""''''~'''''' ~, ~ ~, ,--;\,'~"""'__'~ ,_,_,U .~ -~ 1-" ~, ~ . I-~. ." " '~." . ~ ' ,','~ ~ " ~ ... JENNIE CONRAD, Plaintiff IN THE COURT OF COMMON PLE:4~ 2004 CUMBERLAND COUNTY, PENNSvI~~ v CIVIL ACTION TODD NEWHOUSE, Defendant NO. 04-265 IN CUSTODY TODD NEWHOUSE, Plaintiff IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION NO.2001-7165 ./' IN CUSTODY JENNIE CONRAD, Defendant COURT ORDER AND NOW, this d- day of March, 2004, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. The order of court dated January 4, 2002 entered at Docket No. 2001-7165 is vacated. 2. The father, Todd Newhouse, shall enjoy legal and physical custody of Isaiah Newhouse, born January 25, 2001. 3. The mother, Jennie Conrad, shall enjoy temporary custody with the minor child at such times and under such circumstances as the parties agree. 4. In the event the mother desires to modify this order, the mother may petition the court to have the case again scheduled for a conciliation conference with the Custody Conciliator. cc: Todd Newhouse Jennie Conrad ~ ~ 3_00.0'1 ~ ~- .. _.' ",~- ~ . . ',;' " - I""",.~ , .. ,. k ~~i ...., . JENNIE CONRAD, Plaintiff MAR 0 3 2004 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION TODD NEWHOUSE, Defendant NO. 04-265 IN CUSTODY TODD NEWHOUSE, Plaintiff IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION JENNIE CONRAD, Defendant NO. 2001-7165 IN CUSTODY Prior Judge: J. Wesley OIer, Jr. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-S(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Isaiah Newhouse, born January 25, 2001. 2. A Conciliation Conference was held on February 26, 2004, with the following individuals in attendance: The father, Todd Newhouse. Mr. Newhouse indicates that the mother, Jennie Corurad, is currently incarcerated. It appears from the petition that she filed the complaint for visitation at a time when she was incarcerated at SCI Cambridge Springs. 3. The child is 3 years old. The mother has not seen the child for approximately one year, and the mother has been in and out of prison throughout the child's entire life. 4. Although mother fIled the complaint for custody, she did not attend the hearing nor did she take any action to contact the Conciliator. , - J"". '" I.,'.",L .. ""'-', 5. There was a temporary custody order between the parties at the above captioned action 2001-7165. Mother did not in her complaint for custody make any reference to that prior action. It was brought to the Conciliator's attention by the father. 6. Based upon the above, the Conciliator recommends an order in the form as attached. 3;(! 0 <f DATE "-;1<J.'~!i f~P~-;~..-\'J:.",j-";F~~,,",b ,l-'''' -i);O~1 ",;.,,'t-h ;',~ "',:,-'i-ct",~>i""",<;&i"",--W;;,i'jX-.";-;",,,:..,~1.,..,.,,,-'_ ",;, ""',,,-,-;,:;i;!;gjN':r;~#k'lJf~_'..,m~;mM"'.-'W{offi~!JjiIi$4~~,,~~,ijii;;;t,,~~~ !IJ,,t,J,MtilRUI ~ .~~. !lj ,,,,,~',',',,,",,,,,"'''''''' ~~ r.' _ _c _~.~--,' , ,_"J" _~_ .~"'" . . ~ '- ~<>'-~-" "'"'.'" ,.-<>~- ~ - -~>~ .' ..'.... 0 '" = 0 C = .) " ..c- -r l?i - -< ~.~.. 1"'1 , L.! ::..-~ _L-n -'",- :;-", m- ;:::- [-- r- en :- I -09 -< :~. 01 80 r'" c, ., -, :1 -0 ... ~"-i ( r'5:JJ ~; c) ~ .=.".() C.: S' om -::;> ~-i 4~ ;?- =~ .Xl \OJ -<