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WILLIAM K, HUDSON
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V ANlA
v.
01-7238 CIVIL ACTION LAW
BRIANNE M, HUDSON
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW, Monday, Jannary 07. 2002 , 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, Cnmberland County Courthouse, Carlisle on Friday, January 25,2002 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 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.
The court hereby directs the parties to furnish any and all existing Protection from Abnse orders,
Special Rellef orders, and Cnstody orders to the conciliator 48 honrs prior to scheduled hearing.
FOR THE COURT.
By: /s/
Hubert X. Gilroy. 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 TIllS 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
FORTIl BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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,il WILLIAM K. HUDSON.
II Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
NO, 2001- 7;)..3f[ CIVIL TERM
CIVIL ACTION-LAW
IN CUSTODY
v.
BRIANNE M, HUDSON.
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
on the _ day of , 200_
at _ A.M.lP.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 also be present at the conference, Failure to
appear at the conference may provide grounds for entry of a temporary or permanent
order.
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BY THE COURT.
BY
Custody Conciliator
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OF 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
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WilLIAM K. HUDSON.
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001- I d 3~ CIVil TERM
BRIANNE M. HUDSON,
Defendant
CIVil ACTION-LAW
IN CUSTODY
COMPLAINT FOR CUSTODY
1. The Plaintiff is William K. Hudson. an adult individual residing at 625
Mountain Road, Boiling Springs. Cumberland County, Pennsylvania, 17007.
2. The Defendant is Brianne M. Hudson. an adult individual residing at 154
Beetem Hollow Road, Newville, Cumberland County, Pennsylvania 17241.
3, Plaintiff seeks custody of the following child:
Name
Present residence
AQe
William Taylor Hudson
154 Beetem Hollow Road
Newville, Pennsylvania 17241
2
The child's birthdate is June 3,1999.
The child was not born out of wedlock.
The child is presently in the custody of Defendant. who resides at 154
Beetem Hollow Road, Newville, Cumberland County, Pennsylvania.
During the past five years, the child has resided with the following persons
at the following addresses:
Persons
Residences
Dates
Brianne Hudson
Javette Kerr, grandmother
Jim Kerr, step-grandfather
154 Beetem Hollow Road
Newville. PA 17241
11/12/01 to
present
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Brianne Hudson
William Hudson
CMR 440
Box 413
APO AE 09175
06/03/99 to
11/12/01
The natural mother of the child is Brianne M. Hudson, currently residing at
154 Beetem Hollow Road, Newville. Cumberland County, Pennsylvania.
She is married to the Plaintiff.
The natural father of the child is William K. Hudson, currently residing at
625 Mountain Road, Boiling Springs, Cumberland County. Pennsylvania.
He is married to the Defendant.
4. The relationship of the Plaintiff to the child is that of natural father. The
plaintiff currently resides with the following persons:
Names
Relationshio
Roger Miller
Friend
Sherri Miller
Friend
5. The relationship of the Defendant to the child is that of natural mother.
The defendant currently resides with the following persons:
Names
Relationshio
Javette Kerr
Grandmother
Jim Kerr
Step-Grandfather
6. Plaintiff has not participated as a party or witness, or in any other capacity
in other litigation. concerning the custody of the child in this or in any other Court,
Plaintiff has no information of a custody proceeding concerning the child
pending in a court of this Commonwealth,
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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.
7, 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. All other persons, named below, who are known to have or claim a right to
custody or visitation of the child will be given notice of the pendency of this action and
the right to intervene.
WHEREFORE, Plaintiff requests your Honorable Court to grant him partial
physical custody of the child.
Respectfully submitted.
O'BRIEN, BARIC & SCHERER
DATE:
l'l,z.g,(}\
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Michael A. Scherer, Esquire
1.0. # 61974
17 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
mas.dir/domestic/custody/hudson.com
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VERIFICATION
The statements in the foregoing Complaint For Custody are based upon
information which has been assembled by my attorney in this litigation. The language
of the statements is not my own, I have read the statements; and to the extent that
they are based upon information which I have given to my counsel. they are true and
correct to the best of my knowledge, information and belief, I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to
unsworn falsifications to authorities,
DATE: 27 DEe f'J/
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JAN 2 9 2002 (Jv
WILLIAM K. HUDSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
CIVIL ACTION - LAW
BRIANNE M. HUDSON,
Defendant
NO, 01 -7238 CIVIL
IN CUSTODY
COURT ORDER
AND NOW. this '?o day of ~CUl.( -""" . 2002. upon consideration of the
attached Custody Conciliation Report. it is ordered and directed as follows:
1. The Father. William K. Hudson. and the Mother. Brianne M. Hudson, shall enjoy
shared legal custody of William Taylor Hudson, born June 3. 1999.
2. The Mother shall enjoy primary physical custody of the minor child,
3. The Father shall enjoy periods of temporary physical custody with the minor child
as follows:
A, Pending the Father's relocation to the state of Washington. Father shall
have the following custody:
1. On January 27. 28. 29. and 30. 2002 from 9:00 a,m. until 6:00
p.m, each day. Also, from 9:00 a.m. on February I. 2002.
through February 6. 2002 at 6:00 p.m. When the father has
overnights. those overnights shall be at a location other than the
maternal grandmother's home. During this timeframe. Father
shall ensure that the minor child has reasonable telephone contact
with the Mother, with the Father to attempt daily contact if
possible,
4, Recognizing the Father is relocating to the state of Washington. Father may
exercise temporary custody with the minor child when he returns to the Carlisle
area, Father shall notify Mother at least thirty (30) days in advance when he
intends to exercise custody. such notification to be in writing. The parties shall
work out the timeframe between themselves. with the understanding that Father
will be entitled to a large portion of his vacation time with the minor child in light
of the fact that he is not exercising regular temporary custody, This will include
the Christmas holiday and. when the Father is home over Christmas. Christmas
shall be handled such that Christmas Day is at least shared.
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5, At any point in connection with arranging these exchanges of custody between the
parties. legal counsel for the parties may contact the custody conciliator if there is
any problem and the conciliator is authorized to conduct another custody
conciliation conference via telephone conference with the attorneys for the parties.
Along these lines. this order may be modified at any time by request of the parties.
with the request for modification first being submitted to the custody conciliator.
6. Father shall also enjoy reasonable telephone contact with the minor child when the
child is in the custody of the Mother.
7. While Father has custody of the minor child. he shall not consume alcohol or be
under the influence of alcohol.
BY THEJ~OURT.
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cc: ~in L. Markley, Esquire
~ichael A, Scherer. Esquire
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WILLIAM K. HUDSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v
CIVIL ACTION - LAW
BRlANNE M, HUDSON.
Defendant
NO, 01 -7238 CIVIL
IN CUSTODY
Prior Judge: Edgar B, Bayley
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 who is the subject of this litigation is as
follows:
William Taylor Hudson. born June 3. 1999,
2. A Conciliation Conference was held on January 25, 2002. with the following individuals
in attendance:
The Father, William K. Hudson. with his counsel, Michael A, Scherer. Esquire; and the
Mother. Brianne M. Hudson. with her counsel. Marlin 1. Markley. Esquire,
3, The parties reached an agreement in accordance with the attached proposed order.
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Hubert X.
Custody
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JUN 0 7 2002. ~
WILLlAM K. HUDSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v
CIVIL ACTION - LAW
NO. 01 -7238 CIVIL ./
IN CUSTODY
BRIANNE M. HUDSON,
Defendant
CYNTHIA ENCK,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v
WILLlAM KEITH HUDSON,
Defendant
: NO. 02-810
CIVIL ACTION - LAW
v
BRIANNE M. HUDSON,
Defendant
IN CUSTODY
COURT ORDER
AND NOW, this ,:0 day of June, 2002, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
1. This Court's prior order of January 30, 2002 shall remain in effect subject to
any modifications as set forth below.
2. The Father shall have custody ofthe minor child from Thursday, June 6,2002
at 2:00 p.m. until Saturday, June 8,2002 at 1:30 p.m.
3. The paternal grandmother, Cynthia Enck, shall enjoy periods of visitation
with the minor child on alternating Saturdays from 9:00 a.m. until 3:00 p.m.
or at such other times as agreed upon by the parties. This visitation shall
begin June 22, 2002. Upon the Father's relocation back to the Cumberland
County area, it is anticipated that the grandmother's visitation will be
exercised when the Father has custody.
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4. Paragraph 4 of the January 30, 2002 Order is modified such that Father shall
only be obligated to give Mother reasonable notice with respect to when he is
returning to Carlisle and desires to exercise temporary custody with the minor
child. The parties shall communicate with each other along these lines, and
both parties are encouraged to be flexible and acknowledge each others work
obligations and other family obligations in scheduling the periods of
temporary custody.
5. Similar to Paragraph 7 of the January 30, 2002 Order, the paternal
grandmother shall not consume alcohol or be under the influence of alcohol
when she has custody of the minor child.
6. With respect to the upcoming Christmas holiday, the parties shall
communicate between themselves with respect to a period of visitation Father
may be afforded over Christmas. If the parties are unable to reach an
agreement, legal counsel for the parties may contact the conciliator directly to
have a custody conciliation conference scheduled via telephone where only the
legal counsel for the parties would participate with the conciliator.
7. This Order is also entered recognizing the fact that Father is currently
residing in the state of Washington and that he will be ultimately relocating to
Pennsylvania. At that time, either party may petition the court to have this
order modified.
J.
cc:
Michael A. Scherer
Gary L. Kelley, Esquire
Lindsay Dare Baird, Esquire
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WILLIAM K. HUDSON,
,Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
CIVIL ACTION - LAW
BRIANNE M. HUDSON,
Defendant
NO. 01 -7238 CIVIL
IN CUSTODY
CYNTHIA ENCK,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v
WILLIAM KEITH HUDSON,
Defendant
: NO. 02-810
CIVIL ACTION - LAW
v
BRIANNE M. HUDSON,
Defendant
IN CUSTODY
Prior Judge: Edgar B. Bayley
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 who is the subject of this litigation
is as follows:
William Taylor Hudson, born June 3, 1999.
2. A Conciliation Conference was held on June 6, 2002, with the following individuals in
attendance:
The Father, William K. Hudson, with his counsel, Michael A. Scherer, Esquire; the
Mother, Brianne M. Hudson, with her counsel, Gary L. Kelley, Esqnire; and the
Paternal Grandmother, Cynthia Enck, with her counsel Lindsay Dare Baird.
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3. After strong recommendations from the custody conciliator, the parties agreed to the
entry of a court order in the form as attached.
(Plil o~
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Hubert X. Gilroy, Esquir
Custody Conciliator
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JUN 0 7 2002 '~
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WILLIAM K. HUDSON,
Plaintiff
v
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
BRIANNE M. HUDSON,
Defendant
NO. 01-7238 CIVIL
IN CUSTODY
CYNTHIA ENCK,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
WILLIAM KEITH HUDSON,
Defendant
:NO. 02 - 810'/ CIVIL ACTION - LAW
v
BRIANNE M. HUDSON,
Defendant
IN CUSTODY
COURT ORDER
AND NOW, this \-0 day of June, 2002, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
1. This Court's prior order of January 30, 2002 sball remain in effect subject to
any modifications as set forth below.
2. The Father sball have custody ofthe minor child from Thursday, June 6,2002
at 2:00 p.m. until Saturday, June 8,2002 at 1:30 p.m.
3. The paternal grandmother, Cynthia Enck, shall enjoy periods of visitation
with the minor child on alternating Saturdays from 9:00 a.m. until 3:00 p.m.
or at such other times as agreed upon by the parties. This visitation shall
begin June 22, 2002. Upon the Father's relocation back to the Cumberland
County area, it is alltkipat~d that the grandmother's visitation will be
exercised when the Father has custody.
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4. Paragraph 4 of the January 30, 2002 Order is modified such that Father shall
only be obligated to give Mother reasonable notice with respect to when he is
returning to Carlisle and desires to exercise temporary custody with the minor
child. The parties shall communicate with each other along these lines, and
both parties are encouraged to be flexible and acknowledge each others work
obligations and other family obligations in scheduling the periods of
temporary custody.
5. Similar to Paragraph 7 of the January 30, 2002 Order, the paternal
grandmother shall not consume alcohol or be under the influence of alcohol
when she has custody of the minor child.
6. With respect to the Ilpcoming Christmas holiday, the parties shall
communicate between themselves with respect to a period of visitation Father
may be afforded over Christmas. If the parties are unable to reach an
agreement, legal counsel for the parties may contact the conciliator directly to
have a cnstody conciliation conference schednled via telephone where only the
legal counsel for the parties would participate with the conciliator.
7. This Order is also entered recognizing the fact that Father is currently
residing in the state of Washington and that he will be ultimately relocating to
Pennsylvania. At that time, either party may petition the court to have this
order modified.
J.
Edgar B. Bayley
cc:
Michael A. Scherer
Gary L. Kelley, Esquire
Lindsay Dare Baird, Esquire
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WILLIAM K. HUDSON,
Plaintiff
v
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
BRlANNE M. HUDSON,
Defendant
NO. 01 -7238 CIVIL
IN CUSTODY
CYNTHIA ENCK,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
WILLIAM KEITH HUDSON,
Defendant
: NO. 02-810
CIVIL ACTION - LAW
v
BRlANNE M. HUDSON,
Defendant
IN CUSTODY
Prior Judge: Edgar B. Bayley
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 infonnation pertaining to the child who is the subject of this litigation
is as follows:
William Taylor Hudson, born June 3, 1999.
2. A Conciliation Conference was held on June 6, 2002, with the following individuals in
attendance:
The Father, William K. Hudson, with his counsel, Michael A. Scherer, Esquire; the
Mother, Briaune M. Hudson, with her counsel, Gary L. Kelley, Esquire; and the
Paternal Grandmother, Cynthia Enck, with her counsel Lindsay Dare Baird.
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3. After strong recommendations from the custody conciliator, the parties agreed to the
entry of a court order in the fonn as attached.
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Hubert X. Gilroy, Esquir
Custody Conciliator
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CYNTHIA ENCK
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
01-7238 / 0 CIVIL ACTION LAW
WILLIAM KEITH HUDSON V, BRIANNE M.
HUDSON
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW. Friday, January 24, 2003 , 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, February 20, 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 auy and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinl!;.
FOR THE COURT,
By: /s/
Hubert X. Gilroy. Esq. fI
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
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WILLIAM KEITH HUDSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO: 01-7238 CIVIL TERM ..............
v.
BRlANNE M. HUDSON,
Defendant
IN CUSTODY
CYNTillA ENCK.
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: CIVIL ACTION - LAW
: CUSTODYIVISITATION
WILLIAM KEITH HUDSON.
Defendant
:NO.02-1810
CIVIL TERM
v
BRlANNE M. HUDSON.
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, ,20-, 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 .2003, 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 defme and narrow the issues to be heard by the Court. and to
enter into a temporary order. 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 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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle. PA 17013
Phone: (717) 249-3166
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WILLIAM KEITH HUDSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY. PENNSYLVANIA
: NO: 01-7238
CIVIL TERM
VI.
BRIANNE M, HUDSON,
Defendant
: IN CUSTODY
CYNTHIA ENCK,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: CIVIL ACTION - LAW
: CUSTODYNISITATION
WILLIAM KEITH HUDSON,
Defendant
: NO, 02-1810
CIVIL TERM
Vll.
BRIANNE M, HUDSON,
Defendant
: IN CUSTODY
COMPLAINT TO MODIFY CUSTODY ORDER
Petitioner/Defendant, Brianne M, Hudson, through her counsel. Taylor P. Andrews, Esquire, of
Andrews & Johnson respectfully represents as follows:
I. Petitioner incorporates paragraphs I through 5 of the Complaint for Custody filed at
number 02-1810 herein to establish the jurisdictional facts.
2. Petitioner resides at 154 Beetum Hollow Road, Newville. PA 17241, and she is
represented by Taylor p, Andrews, Esq., 78'W. Pomfret St.. Carlisle, PA 17013.
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3, Defendant, William Keith Hudson, resides at HHC 1/5 BN, MBN #160, Ft. Lewis,
Washington, He has been represented in this action by Michael A. Scherer, Esq, 17 W. South St.,
Carlisle, P A.
4. Respondent, Cynthia Enck, resides at 4238 Valley Road, Shermansdale, Perry County,
Pennsylvania, She has been represented in this action by Lindsay Dare Baird, Esq. 37 S, Hanover St.,
Carlisle, P A 17013,
5. On January 30, 2002 a Custody Order was entered in the custody action filed at 01-7238
defining the custody rights of Petitioner and her husband William K. Hudson with regard to their son
William Taylor Hudson, born June 3, 1999, (A copy of this Court Order is atta.ched hereto as Exhibit 1)
6. On June 10, 2002 an Order for Custody was entered at 01-7238 and at 02-1810 modifying
the above referenced Court Order to provide for rights of partial custody for visitation by the child's
paternal grandmother, Cynthia Enck. (A copy of this Order is attached hereto as Exhibit 2)
7. Paragraph 5 of the June 10, 2002 Court Order provides "the paternal grandmother shall
not consume alcohol or be under the influence of alcohol when she has custody of the minor child,"
8, Respondent, Cynthia Enck, has a history of alcohol abuse and she frequently drinks
alcohol to the point of intoxication, even in early daytime hours,
9. Respondent, Cynthia Enck, has recently violated section 5 ofthe June 10,2002 Court
Order referenced above by consuming alcohol and becoming intoxicated while she had custody of the
minor child referenced by the Order.
10. Petitioner fears for the safety of her minor child, William Taylor Hudson, due to the abuse
of alcohol by Cynthia Enck while Cynthia Enck has partial custody of William Taylor Hudson.
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11. Petitioner believes that Defendant, William Keith Hudson, concurs in this Complaint to
restrict the visitation of Cynthia Enck to supervised visitation only to be restored to unsupervised
visitation when Cynthia Enck has received an evaluation by a certified drug and alcohol abuse specialist
and when she has completed any and all treatment that should be recommended as a result of the
evaluation. It shall also be a condition that Cynthia Enck sign releases so that Petitioner and her attorney
may provide information to and receive information from the drug and alcohol specialist.
WHEREFORE, Petitioner prays your Honorable Court to ModifY the existing Custody Order as
suggested herein,
Respectfully submitted,
ANDREWS & JOHNSON
By:
aylo P. drews, Esq.
rney for Plaintiff
78 West Pomfret Street
Carlisle, PA 17013
Telephone: (717) 243-0123
I verifY that the statements made in the foregoing Complaint to ModifY Custody Order are true
and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S.
~ 4904, relating tounswom falsification to authorities,
DATE: \- 0,- 0:::'
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Brianne M, Hudson
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WILLIAM K. HUDSON,
plaintiff
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v
:
BRlANNE M. HUDSON,
Defendant
NO. 01- 7238 CIVIL
IN CUSTODY
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, AND NOW.Jhis .30 ...da)LOL~, ',n ,:~,~.2002, upon consideration of lhe-;W
attac:bed Custody CoilCiliation Report, it isonlered~ as follows: ' ~'" ~,:,{:, '
1. The Father, William K. Hudson, and the Mother, Brianne M. Hudson, sbaIl eujoy ~'.~i
sbaredlegal custody of William Taylor Hudson, born June 3, 1999. ..-
2. The Mother sbaIl eujoy primary physical custody of the minor child.
3. The Father sball eqjoy periods of temponuy physical custody with the minor cbild
as, follows:
A. Pending the Father's relocation to thesllde of Wasbington, Father sball
bavethe following custody:
- ....'.
i. On Jaouary 27,28,29, and 30, 2002 from 9:00 a.m. 1IIIIil6:00
p.m. each day. Also, from 9:00 a.m. on February I, 2llO2,
1brougb. FebrWuy 6, 2002 at 6:00 p.m. When the liIther, bas
ovemigbts, diose ovemigbIs sball be at a location other tban the
maternal graudmother's home. During Ibis timeftame, F;ither
sbalI eiJsUle 1bat the minot child bas J'l"'wnable teIephoDe CODIad
wiIh the Mother, wiIh the Father to attempt daily CODIad if
possible.
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4.
Recognizing the Father is relocating to the sllde of Wasbington, Father may
exercise tem{Iomy custody wiIh the minor child when be returns to the Carlisle
area. Father sball notify Mother at 1east lbirty (30) days, in advam:e when he
intends to exercise CllStocly, such notification, to be in writing.' The parties sball
work out the timeftame between themselves. wiIh the UDderstaDdiDg !bat Father
will be enritI"" to a 1arge portion ofbis vacation time wiIh the minor child in light
of the tiii:t !bat be is not exercising regular tempomy custody. ,This will include
the aVistmas holiday and. when the Father is home over Christmas, Christmas
sball be handled such !bat Christmas Day is at least shared.
EXHIBIT
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S. At any point in aJODeClion with arranging these el'("~ of custody between the
parties, legal c:ouoseI for the parties may oontact lhe custody conciliator if there is
any problem and the conciliator is authorized to c:ooduct another custody
conciliation conferem:e via ~Hoe conference with the attorneys for the parties.
Along these lines, this cmIet may be modified at any lime by request of the parties,
with the request for modification first being submitted to the custody conciliator.
6. Father shall also eujoy reasonable te1ephooe oontact with the minor c:hiId when the
cbild is in the custody of the Mother.
7.
Whi1e Father has custody of the minor cbild, he shall not CODSUl1le alcohol or be
UDl1er the influence of alcoboI.
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BY THE COURT,
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Marlin L. Markley, Esquire
MicbaeI A. Scherer, Esquire
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WILLIAM K. HUDSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:
v
CIVIL ACflON - LAW
:
BIUANNE M. HUDSON,
Defendant
: NO.OI-7Z38 CIVIL
: IN CUSTODY
CYNTIDA ENCK.
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v
~
:
WILLIAM KEITH HUDSON,
Defendant
: NO. 02-810
CIVIL ACflON - LAW
:
v
:
BIUANNE M. HUDSON,
Defendant
: IN CUSTODY
COURT ORDER
AND NOW, this 10 day of June, 2002, npon COIISidendion of the aUadIed Custody
Con,.,,;..fimt Report, it is ordered and dLedlod as follows:
,
I. 'This Court's prior 0I"d!!l' of January 30, 2001 sbaI reIJIlIin in efIl'ect subject to
any IIlOdi6tati9ns as set forth below.
1.
De Father sbaI bave cusIody of the minor cbildfrom Thursday, June 6, 2001
at 1:00 p.IIL until Saturday, June 8, 2001 at 1:30 p.m.
3.
De patemaI grandmother, Cynthia Enek, sbaI eiVoy periods of visitation
willi the minor cbiId !Ill aItenIating Saturdays from 9:00 a.m. U111ti13:OO, p.m.
or at such other times as agreed upon by the parties. , 'This visiI!Ition sbaI
begin June n. 2002. UpoII the Father's reIoQdion back to the CUmberland
Comdy area, it is anticipated that the grandmother's visitation wiD be
exercist!d when the Father has u..tudy.
,
EXHIBIT
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4. Paragraph 4 of the January 30, 2002 Order is modified such that Father shaD
oaIy be ............. to give Mother reasqnAhle uotice with respect to when be is
returning to CartisIe and desires to ex~ temporary custody with the mioor
cbiId. The parties shaD c:c:>mlllllllicatA.' with each other along these Iinfs, and
both parties are enmuraged to be ~e and acknowledge each others work
obligations and other family obligations in scbNlll1iqg the periods of
temporary custody.
Similar to Paragraph 7 of the January 30, 2002 Order, the pateroal
grandmother sbaD not ............... aloolIoI or be under the influence of alc0hoi
when she has custody of the mioor..
5.
6.
With l~ to the """'-;l\g <;hrlstmas holiday, the parties sbaD
C:C:>llIIIllmio:ate between themselves ~ reSpect to a period of l'isifation Father
may be atTorded over Cbristu!as. ,If the parties are unable to reach an
agreenrent, legal COUDSel for the partij!s IDllJ C04tad the conciIilItor diId., to
have a custody conc:iliation conf~ ~ed via telephone where only the
legal COUDSel for the parties would .~ with the conciliator.
..
7.
'Ihis Order is also entered recogo.M.og. the fact that Father is Cua 1 tillly
residing in the state of WAdriqgfon ~ that be wiD be IllfimAt.eIy ...........fi1lg to
Pennsylvania. At that time, either P1lr1Y. may petition the amrt to have this
order modified.
BY TIlE COURT,
fi.f' Jr" ~ A,"<t
B.Bllyley
J.
tt: MicbaeI A. Scherer
Gary L. Kelley. Esquire
Lindsay Dare Baird, Esquire
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In T~whereof, ~ befll unto _'my IlaPd
and tIiIl seal of said ~ at CartIsIe. Pa.
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WILLIAM KEITH HUDSON,
Plaintiff
: IN TIlE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO: 01-7238
CIVIL TERM ~
v,
BRIANNE M, HUDSON,
Defendant
: IN CUSTODY
Plaintiff
: IN THE COURT OF COMMON-PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CYNTHIA ENCK,
v,
: CNIL ACTION - LAW
: CUSTODYNISITATION
WILLIAM KEITH HUDSON,
Defendant
: NO, 02-1810
CNIL TERM
Vi.
BRlANNE M. HUDSON,
Defendant
: IN CUSTODY
PRAECIPE TO PROCEED IN FORMA PAUPERIS
TO THE PROTHONOTARY:
Kindly allow, Brianne M. Hudson, PetitionerlDefendant, to proceed in forma pauperis,
I, Taylor P. Andrews, Esq., attorney for the party proceeding in forma pauperis, certify that I
believe the party is unable to pay the costs and that I am prov' ,
d hereto.
The party's affidavit showing inability to pay the costs of 1ti 11
.
drews, Attorney for PetitionerlDefendant
WILLIAM KEITH HUDSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO: 01-7238
CIVIL TERM
vii.
BRIANNE M, HUDSON,
Defendant
IN CUSTODY
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CYNTHIA ENCK,
v,
: CIVIL ACTION - LAW
: CUSTODYNISITATION
WILLIAM KEITH HUDSON,
Defendant
: NO, 02-1810
CIVIL TERM
viii.
BRIANNE M, HUDSON,
Defendant
: IN CUSTODY
AFFIDAVIT IN SUPPORT OF PETITION
FOR LEAVE TO PROCEED IN FORMA PAUPERIS
1. I am the Plaintiff in the above matter and because of my fmancial condition am
unable to pay the fees and costs of prosecuting, defending, or appealing 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 representthat the information below relating to my ability to pay the fees and costs
is true and correct.
a,
Name:
Address:
Brianne Hudson
154 Beetum Hollow Rd" Newville, PA 17241
b, Social Security No: 165-66-9696
If you are presently employed, state:
Employer: None
Address:
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Salary or wages per month: none
Type of work: unemployed, I am mother of a young child and a student.
If you are presently unemployed, state:
Date oflast employment: 1998
Salary or wages per month: $6.30 per hour [this was in Germany]
Type of work: Cashier
c. Other income with the past twelve months
Business or profession:
Other self-employment:'
Interest:
Dividends:
Pension and annuities:
Social Security benefits:
Support payments: $887 per month assured, additional $300 occassional1y
Disability payments:
Unemployment compensation and supplement benefits:
Workman's compensation:
Public Assistance:
Other:
d. Other contributions to household support
(Wife)(Husband) Name:
If your (husband)(wife) is employed, state
Employer:
Salary or wages per month:
Type of work:
Contributions from children:
e, Property owned
Cash:
Checking account: $500
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Savings account:
Certificates of Deposit:
Real Estate (including home):
Motor vehicle: Make Year
Cost Amount owed
Stocks; bonds:
Other:
f. Debts and obligations
Mortgage:
Rent: . I contribute to household expenses
Loans:
MontWyexpenses: approx $550 per month
g. Persons dependent upon you for support
(Husband) Name:
Children, if any:
Name: William Taylor Hudson Age 3 11, years
4. I understand that I have a continuing obligation to inform the court of improvements in
my financial circumstances that would permit me to pay the costs incurred herein.
5. I verifY that the statements made in this affidavit are true and correct. I understand
that false statements herein are made subjectto the penalties of18 Pa, C, S, 4904, relating to unsworn
falsification to authorities.
Date:
1-10-03
(}yAf./'{IMQ 1n'~A.f\.l~f/},
Brianne M. Hudson
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WILLIAM KEITH HUDSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v
CIVIL ACTION - LAW
.,/
BRIANNE M. HUDSON,
Defendant
NO. 01 - 7238
IN CUSTODY
CIVIL
CYNTHIA ENCK,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
WILLIAM KEITH HUDSON,
Defendant
CIVIL ACTION - LAW
v
BRIANNE M. HUDSON,
Defendant
NO. 02 - 1810
IN CUSTODY
CIVIL
COURT ORDER
AND NOW, this I t day of March, 2003, upon consideration of the attached Custody
Conciliation Report, it is ordered as follows:
1. The rights of the Paternal Grandmother to have temporary custody of the minor
child are suspended. In all other respects, the prior Orders of Court shall remain
in effect.
2. In the event the parties work out an arrangement that the Paternal Grandmother
may exercise temporary physical custody with the minor child, the parties are
free to proceed with that arrangement.
3. In the event the Paternal Grandmother desires to modify this Order, she may
petition the court to have the case scheduled before the conciliator.
BY THE COURT,
~s/ f;J~(J" 13. J3~ J.
d'gar B. ayley
cc:
Lindsay D. Baird, Esquire
Michael A. Scherer, Esquire (l..tdJ J;"
Taylor P. Andrews, Esquire --,--
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WILLIAM KEITH HUDSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v
CIVIL ACTION - LAW
BRIANNE M. HUDSON,
Defendant
NO. 01- 7238
IN CUSTODY
CIVIL
CYNTHIA ENCK,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
WILLIAM KEITH HUDSON,
Defendant
CIVIL ACTION - LAW
v
BRIANNE M. HUDSON,
Defendant
NO. 02 - 1810
IN CUSTODY
CIVIL
Prior Judge: Edgar B. Bayley
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 infonnation pertaining to the child who is the subject of this litigation
is as follows:
William Taylor Hudson, born June 3, 1999.
2. A Conciliation Conference was held on March 6, 2003, with the following individuals
in attendance:
The Mother, Brianne M. Hudson, with her counsel, Taylor P. Andrews, Esquire;
and the Maternal Grandmother, Cynthia Enck, with her counsel, Lindsay Baird.
The Father, William Keith Hudson, was not present.
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3. Based upon an agreement of the parties, the conciliator recommends the entry of an
order in the fonn as attached.
J (ff I {;>
DATE
Hubert X. Gilroy, Esq
Custody Conciliator