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HomeMy WebLinkAbout99-02761 (2) I :J MAY 1 2 199~ , BARRY L. CAMPBELL, JR., a Minor, by SHEILA CAMPBELL, his Guardian, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. NO. 11- ';;)11'/ ~ti-Lt... ERIN MEYER, CIVIL ACTION - CUSTODY Defendant ORDER OF COURT '.. And now, this .~\c>19q ,upon consideration of the attached complaint, it is hereby directed that the above parties and their respective counsel appear before ~ ~"I..,,~ Esquire, the conciliator, at? '-.), \-'\0\ S. .' JIi . Pennsylvania, on the d~ day of r'\" 1999, at \.. C\( 1. A. . . ,for A Pre- Hearing Custody Conference. At such confcrence, 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 providc grounds for t he entry of a temporary or permanent order. FOR THE COURT: By: Custody Conciliator ~~ 1) . \'t\~ I YOU SHOULD TAKE TillS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT IlA VE A LA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WIIERE YOU CAN GET LEGAL HELl'. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLlSLE,I'A 17013 (717) 249-3166 1-800-990-910S . , , .' ' .: ' : . " ~ . \ ".. "." " -' ~ \ ~ , .. . ," . '; , " . ". vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO, 91. .:l7~1 ~/.u- BARRY L. CAMPBELL, JR., a Minor, by SHEILA CAMPBELL, his Guardian Plaintiff ERIN MEYER, CIVIL ACTION - CUSTODY Defendant COMPLAINT FOR CUSTODY I, The plaintiff is Barry L. Campbell, Jr., residing at RR 4 Box 643, Newport, Perry County, Pennsylvania, 2. The guardian, Sheila Campbell, residing at RR 4 Box 643, Newport, Perry County, Pennsylvania and is mother of petitioner. 3. The defendant is Erin Meyer, residing at 20 Sunset Drive, Mechanicsburg, Cumberland County, Pennsylvania. 4, Plaintiff seeks shared custody of the following child: Name Present Residence Age Kara Lynn Meyer 20 Sunset Drive Mechanicsburg, P A 7 1/2 months The child was born out of wedlock. The child is presently in the custody of defendant, who resides as stated in paragraph 2, During the past five years. the child has resided with thc following persons and at the following addresses: 20 Sunset Drivc Mcchanicshuf/;,PA mothcr, maternal grandfather, and 2 matcmal uncles , ,., ' , . ' ~, . ~ . ',' , ,,' ': J ~ ' ': .' I ' . . .' -. " .' , . , I verify that the statements made in this Custody Complaint are true and eorrect. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. *4904 relating to unsworn falsification to authorities. ,/} /~ / ~y/;( fJ :. '~, ,/: ,c:~C;c'~~;{(#/:j/~ Barry L. C nphell, plaintiff / ' >- ~~ ,-- t.J.I~.~} (\,./ R: ~~) <:;if' ~~ f6,~ ~ ii~.:. ~:; '-L <..) ~ Vl ~ IJ.l ....l I'l.. Z;... 01- ~~ 00 UU ~Cl OZ f-.~::; gj2~ O[.J.);> Ua:l....l 1J.l~;:.. :I::::>f{J f-.UI": Z!.L.it .....00... c'' [: ,. ::-;?{ :~ '} ~.j , v> . ! -,'~ !:;z <,'.U ~~-} :J.., .., (3 ~; c..C r- I >- .,,,' :.r.' m (1\ ~~\~ ~ ~ ,-0 "'i) ~ ~ ~ ~~ ~. 'i ~,~ . d S '" - c::'- ~ ~ ._ '<l ._ ~ 1il E '<l ;... ::l .- '" "'O..!'l ~ 0 =- Vl t:l. OJ 0 \0 cc: .- Cl f- ~ .......c Vl ....- ...s..J ;:J !-><i? ll:: ~ .....l.....l vi U 000 .....l IJ.lIJ.l ;> Z ~ ~l'- r-... V'';:: o::lo::l - ....l 0 - 00 G:l ,c: Z I'l..I'l.. f-. _I'l..~or- Ol 0;:" ~~ Z s: "I'l..~~o. ~~ - -... 0..... -, 0 ~ <rJ"jg~~c.8 f-.O uU ~ ....l ;:..'@,~~->, Uf-. .~ ~ ....l....l I'l.. ._ r--. U OJ ~Vl ~ ~::r:u;:::::g.E ::::;:J ;:..- IJ.l 0 ~~ ~ 0 l:;;iS'-'Vlg >U U z [JZ ~CI'l z .....0 ~ - c:o E' C2 ~ IJ.l , . BARRY L. CAMPBELL, JR., a mino~, by SHEILA CAMPBELL, his Guardian, Plaintiff IN THE <X>URT OF <X>MMON PLEAS OF : CUMBERLAND COUNTY, PEl\1NSYLVANIA , . vs. : NO. 99-2761 CIVIL TERM ERIN MEYER, : Defendant : CIVIL ACTION - LAW IN CUSTODY OODER OF 0XlRT AND NCW, this I~~ day of ,J ~ consideration of the attached Custody Conciliation Repo~t, and di~ected as follows: , 1999, upon it is o~de~ed 1. The Mother, Erin Meyer, and the Fathe~, Barry L. Campbell, J~., shall have sha~ed legal custody of Ka~a Lynn Meye~, born August 30, 1998. Each pa~ent shall have an equal right, to be exe~cised jointly with the othe~ pa~ent, to make all majo~ non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions ~ega~ding her health, education and religion. 2. The Mother. shall have p~imary physical custody of the Child. 3. The Fathe~ shall have visitation and pa~tial physical custody of the Child in acco~dance with the following schedule: A. Beginning Tuesday, November 16, 1999, the Fathe~ shall have visitation with the Child at the Mothe~'s ~esidence every Tuesday and Thursday from 6:00 p.m. until 8:00 p.m. fc~ 4 weeks. The parties shall coope~ate in making adjustments to the weekday schedule as necessary to accorranodate the parties' wo~k schedules. B. When the Fathe~ has exe~cised his periods of visitation unde~ pa~ag~aph A of this provision for 8 consecutive periodS (2 days pe~ week for 4 weeks), the Fathe~ shall begin having partial custody of the Child every Sunday f~an 12:00 noon until 4:00 p.m. and du~ing 1 evening pe~ week f~om 6:00 p.m. until 8:00 p.m. for an additional 4 weeks. The Fathe~ may exe~cise his ~ight to custody under this p~ovision eithe~ at the Mother's ~esidence or else,,'he~e at his option. The specific "'eekday evening pe~iod of custody shall be a~ranged by ag~eement of the pa~ties. C. l"hen the Fathe~ has exercised his right to pa~tial custody unde~ pa~agraph B of this provision for: 8 consecutive periods (2 times pC'r "'eek fo~ 4 ",eeks), the Father shall have pa~tial custody of the Child from 8:00 a.m. until 5:00 p.m. on either Saturday or Sunday of every week, with the specific day to be arranged by agreement between the parties, for 4 additional weeks. D. When the Father has exet'cised his right to partial custody under paragraph C of this provision for 4 consecutive weeks, the Father shall have partial custody of the Child on alternating weekends from Friday at 6:00 p,m. through Saturday at 7:00 p.m. and on 1 weekday evening per week, to be selected by agreement of the parties, from 6:00 p.m. until 8:00 p.m. for 8 weeks, E. When the Father has exercised his right to partial custody under paragraph D of this provisi,on, thereafter on an ongoing basis, the Father shall have partial physical custody of the Child on alternating weekends from Friday at 6:00 p.m. through Sunday at 6:00 p.m. and on 1 ,'eekday evening per week from 6:00 p.m. until 8:00 p.m., with the day to be selected by agreement of the parties. 4. The parties shall have custody of the Child on holidays as follows: A. CHRIS'llIAS: In 1999, the Father shall have custody of the Child on Christmas Day for a 4 hour period as arranged by agreement between the parties. 'll1e Father's period of custody on Christmas shall be considered to include his period of weekend custody under the regular custody schedule. B. THANKSGIVING: In 1999, the Mother shall bring the Child to the Father's residence fer a period of custody on Thanksgiving, with the specific times to be arranged by agreement of the parties. 'll1e Father's period of custody on Thanksgiving shall be considered to include his weekday period of custody under the regular custody schedule. C. <:>THm IJOLIDI\YS: custody of the Thanksgiving and mutual agreement. The parties shall share or alternate having Child on the remaining holidays and on Christmas in future years as arranged by 5. The party receiving custody of the Child shall be responsible to provide transportation for the exchange of custody. The Father shall cooperate in providing transportation for exchanges ,-'hen the Father is relinquishing custody and the Mother is working. 6. Neither party s1all use illegal drugs or drink alcohol before or during his or her periods of custody with the Child. 7. 'll1il" Order is entered pursuant to an agreement of the parties at a ""', ,: '; 'f:: f, . ,; ~~:'<.:: ' .,:' ;,"; ~\:,<">,,~'. .~; ,':'~';:i~;i~:',/", ':~ :.~l.,~,' :it~.~: .;.: ,\:y,;::, ;' ,,:i <'>"!:\ ~ . .:~,' - "') , : :<:' ': OJ' ~. f ,:-,' . ',', ,~", ',' i I I I I I ./ BARRY L. CAMPBELL, JR., a minor, by SHEILA CAMPBELL, his Guardian, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMDER[,IIND C<XJNl'Y, PENNSYLVIINIA : vs. : NO. 99-2761 CIVIL TERM ERIN MEYER, . . Defendant : CIVIL ACTION - LAW : IN CUSTODY ClJS'roOY ~ILIATIctI SlJ1MARY REPCRT rn A<XXlRDiINCE WITlI CUHrw.ru:.J\ND CXXM'Y RULE OF CIVIL PROCEIJURE 1915.3-8, the undersignQd L~flto<ly Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is ao follows: NAME DllTE OI! BInTfl aJRREm'Ly rn ClJS'la)y OF Kara Lynn Meyer AllgU13t 30, 1998 Mother 2. A Conciliation Conference was hold on November 9, 1999, with the following individual13 in attendance: The Father, Barry L. Campbell, Jr., with his counsei, Jerry A. Philpott, Esquire, and the Mother, Erin Meyer, with hot' counsel, Jacqueline M. Verney, Esquire. 3. 'I!1e partie.~ agreed to entry of an Order in the form as attached. ~)"' ~'( 1,.I.;t- I Date ,lL 10 / 'I 1 '7 . , C...... -'Dawn s. Sunday, Esqulre Custody Conciliator ~~ ~m ~~ffi c'... 'g '0 ii'l~E<:;: t;j.... "'B~ ..., ~r~ :3 ' ..., c , III C CO ~ ~p.EI~ F'5'...'... '0 '()15g ..c:'" ~ .... ~E< , ,p. .... 2l tJ~ "" '" ~ H~ '"''"' '" '" '" [) ....tJ8 ~~ , Q ej1.B ... 0 r<l<Xl g; ~: =.ora~r- \0<1: <Xlp. = = fio{ J::I- ~ r- Z ~~ ~,m~~~ r~~H ~I [;ll<Eii~~ lRH . :3 ~ r<l U E CoI.... .c ltt :::: E III ~ ::t: ' '"'H ~ -- .l3 0 ~ ,- ;~2 i~ S r,j:t:: a :;; ;:llmUl~g Z E H ::E fil '~ ' . . .. (' _ .,:. "f " <". ",,', \.\ ,~." . . .'. ,':'. '.: , . ~.', ,",,' ':' ',' '1 ,'..' , , . "'."'\!j"ht);"~:.:~l,,",,,,,,'~I.'O,~~~._~:::';;)_I"-~l' I"t " \~:" ,I',' ...:, ,',d'I'" ,"' ,., , ._,., "'" "..,...,~,,'''~'-/':t._', '... "',',,,: ",'" ",\ .',,' !,', '~-"'. ,'" .. . , I, '..., ' I' \ . \, ~ , . . V . ".' . , "/" , .' 1 . ~ ,", '. \ I ", ~. Fi~ Fr.>-G::~lC~ n~ ";'1,'" " .~.t:""\;:""'~^J'Y ~" ,..: . . .'. j I" 1 cgN'''~9 ....:1 6 :; -,' r t.' 1'" ," _ ..,.. -. .. ~ . r.. etl':", .; . .... . 'II' ~ ..... ...j\'o;:.::~ .:.,',,';_/ 1...(,.,",.)I~ IY 1"ci~"S')'I' \/..... I' _.J.<l,;-'::/_\ C;e;?~.tH tU'- !'~ /m~ z$ ~ #~ t/;;<tl.tJf 7~ /ff~ -t -rU -r ~. tlt/J./)f I~/I~~' ~~*? ." ,~, ' ':\' :'.'.' ',..' :',.: . .'.d', ,.),," " ,'.{ ,..., 1,.:\ '. i"::~': :~'~:T :;I::'\'~:~"~')~';:,t~":,',,~M~;'::'W':,~ ,''',:.'~; ::,' ~!J" ::T", ,::::,,."': . ':. Ie:' '';:://:'', l '. .. '.,: ,....'., ' > .:,'~ ,.... :;" ,: . '. BARRY L. CAMPBELL, JR, a minor, by SHEILA CAMPBELL, his Guardian, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA II I I i '" ...;. vs. NO. 99-2761 CIVIL ERIN MEYER, Defendant CIVIL ACTION - CUSTODY PRAECIPE To the Prothonotary: The parties, between their respective counsel at the time of their last scheduled conference, canceled the conference in attempt to negotiate a custody agreement. Since then defendant's counsel withdrew and defendant is no longer responding to attempts to negotiate, THEREFORE, please reappoint a conciliator and schedule a conference in attempt to resolve this matter. Dated: Cf-q-q, ,l ',' ',~' , " '[.':'1 .':' :, "/, '''. '1.' ,: ,I~~, ;,:. ~;.' :. ':./;:^" : ~:/~;;.,;,.:,<:::;<,;:~:;j:~:;'7~ >X;~.: ,,::;: ,,~::~\;.~ ;;~\~< :, ,~~ "l:" ~':' '..:' : ),,~: I. '.~ I ';'. ,::,:>:.,' ,/' .:,;': ,:1' ":.,~~ .:,' :.:,'" : .'.',: '~,~ ,", '. : f; .:'J ~ r j" L. ':~ -:.', . ~, ..'to ) C) ~ . -, BARRY L. CAMPBELL, JR., a Minor, by SHEILA ~lPBELL, his Guardian, Plaintiff vs. ERIN MEYER, Defendant JUL 1 2 1999~ ~ IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 99-2761 : IN CUSTODY aIDER OF COORT AND ~, this 6th day of July, 1999, the Conciliator, being of the parties, advised by counsel that all custody issues have been resolved by agreement hereby relinquishes jurisdicti.on in this case. The Custody Conciliation Conference scheduled for July 6, 1999 is canceled. FOR THE OOURT, /~>~ ~SUnday, Esqulr ~~~tody Conciliator FllFf.)--Q;':F!CE ()': T; ':: r.~ \~W~ :~.:.,\ ,:OTJ\8Y 99 JIJl 1 3 f'i1 3: I I C' JO ".. " , '. U' ITV Uh/ll.:;::t',lf'J,'U l",,'j 1\J11 PENI~SYL\~/'J\lt.\ , , ' ~ '. , . . " . '"'" ., ' ", . '. , ,. , , JAN 1 3 ZOO( Erin M, Meyer, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA vs, BARRY L, CAMPBELL, JR., Defendant CIVIL ACTION - CUSTODY NO, 99-2761 PETITION TO MODIFY CUSTODY 1, Plaintiff is Erin M, Meyer, mother of the child, residing at 20 Sunset Drive, Mechanicsburg, Cumberland County, Pennsylvania, 2, Defendant is residing at 815 Pennsylvania, Barry L, Campbell, Jr" father North Front Street, Newport, of the child, Perry County, 3 , Custody of t.he minor child, Kara L, Meyer, was awarded as follows: A, Shared legal custody to both parties, B, Primary physical custody was granted to mo'ther, with periods of partial physical custody granted to father by Order of Court dated November 18, 1999, (See copy of Order attached hereto as Exhibit "A",) 4. Plaintiff seeks to modify the current custody arrangement because: A, Mother can provide a more stable envi re>nment for the child. I I II II B, Father has placed child in danger by driving under the influence of alcohol while the child was in his vehicle, The child, who is six (6) years old, had to watch her II . ...., ,..,~, ~-'. ..: :.,', ':.. "" '..' ,': ., ,:",~.,. '. ~",'.. ,: -""" " ! I I I I ,I II I 'I Ii father be questioned by police and take a sobriety test after he picked her up for a weekend visit. C, During order, leaves the current Rather, he , . " '~ ,,".., "', ' .'. .'. I'....... .. :.... . , . ., '. . ,. ,":" ,:'. _.'. . " ,/w " father's periods of visitation under father does not care for the child, the child with his parents, D, Father has never exercised his weekday evening visitation under the current order, E, Father shows no interest in the child's schooling or activities and never calls to speak with the child, WHEREFORE, Plaintiff requests the Court to modify custody of the child as follows: A, Primary physical custody of minor child with mother, B. Supervised visitation with father at mother's residence until father has successfully completed drug and alcohol counseling and mother is satisfied that the minor child is safe in the care of father, Respectfully Submitted: DISSINGER AND DISSINGER '-I / - ,,' . /...) , By:,' ~AM1\ iY~I('-1)' ,,~ ren L, Koenigse Attorney for Plaintlff Supreme Court I,D. #85556 28 North 32nd Street Camp Hill, PA 17011 (717) 975-2840 ,""') " .....,1''\..' (\ I custody of the Child from 8:00 a,m. until 5:00 p.m. on either Saturday or Sunday of every week, with the specific day to be &:ranged by agreement between the parties, for 4 additional weeks. D. When the Fathel." has exercised his right to partial custody under paragraph C of this provision for 4 consecutive weeks, the Father shall have partial custody of the Child on alternating weekends from Friday at 6:00 p,m. through Saturday at 7:00 p,m. and on 1 weekday evening per week, to be selected by agreement of the parties, fran 6:00 p.m. until 8:00 p.m. for 8 weeks, E. When the Father has exercised his right to partial custody under paragraFh D of this provision, thereafter on an ongoing basis, the ,Father shall have partial Fhysical custody of the Child on alternating weekends from Friday at 6:00 p.m. through sunday at 6:00 p.m. and on 1 weekday evening per week from 6:00 p.m. until 8:00 p.m., with the day to be selected by agreement of the parties, 4. follows: The Parties shall have custody of the Child on holidays as ~., A.~: In 1999, the Father shall have custody of the Child on Christmas Day for, a 4 hour, period as arranged by agreement between the parties. 'lhe Father's period of custody on Christmas shall be considerl.'<i to' include his period of ' weekend custody under the regular custody schedule. B. TBJ\NKSGIVING: In 1999, the Mother shall bring the Child to the Father's residence .for a period of custody on Thanksgiving, with the sPecific tiines to be arranged by agreement of the parties. The Father',s period of custcx:rl on Thanksgiving shall be considered to include his weekday period of custody under the l."(..~ulal: cu:o;tody schedule, C. amER BOLIMYS: custody of the Thanksgiving and mutual agreement. The parties shall share or alternate having O1ild on the remaining holidays and on Christmas in future years as arranged by 5. The party receiving custody of the Child shall be responsible to provide transportation for the exchange of custody. The Father shall cocperate in providing transportation for exchanges ..11en the Father is relinquishing custody and the Mother is working. 6. Neither pllrty shall use illegal drugs or drink alcohol before or during his or her periods of (..~tody with the Child. 7. This Order is entered pursuant to an agreement of the pllrties at a " Erin M, Meyer, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA . . . ,', ~ ' .', " . ' . . '. '. ,. ,": ' .' \." .:' . . :. '.. r ',.' '; . '. .' "', . ,.. :., \' '. . . vs, BARRY L, CAMPBELL, JR" Defendant CIVIL ACTION - CUSTODY NO, 99-2761 CERTIFICATE OF SERVICE I, Karen L, Koenigsberg, hereby certify that on the date set forth below I served a true and correct copy of the Petition to Modify Custody upon Barry L, Campbel.l, Jr" Defendant, Jerry A. Philpott, Esquire, and Michael Schechterly, Esquire, by First Class United States mail addressed as follows: Barry L. Campbell, Jr, 815 North Front Street Newport, PA 17074 Jerry A, Philpott, Esquire 227 North High Street Duncannon, PA 17020 Michael Schechterly, Esquire 20 North 6th Street Newport, PA 17074 I / Date: lip leI/' .;/Hd I i I' 1/ ii II II I, II Ii J FE'B 1 7 2005 ~~ BARRY L. CAMPBELL, JR. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. <JCJ-276 I CIVIL ACTION LAW ERIN M. MEYER Defendant ! CUSTODY ORDER OF COURT .JI -~ AND NOW, this ;.,; day of f; , 2005, consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: upon I, The prior Order of this Court dated November 18, 1999 shall continue in effect as modified by this Order. 2. The Father shall participate in a Drug and Alcohol Evaluation and Program, including regular drug testing, at Holy Spirit Hospital. The Father shall follow all recommendations provided by the program. The Father shall ensure that all drug test results arc provided promptly to the Mother either directly or through counsel. 3, Pending completion of the Drug and Alcohol Program, the Father ~hall not drive a motor vehicle with the Child present and instead, shall arrange for either of the Father's parents to provide transportation for exchanges of custody and all transportation during the Father's periods of custody, 4. Re-initiation of the Father's weekend periods of custody, beginning Friday, February 18, 2005 shall be conditioned on the Father obtaining a negative drug test and providing the negative result to the Mother in advance. 5. The Father's weekday evening periods of custody shall be as arranged by agreement between the parties. 6. In the event a drug test in the Drug and Alcohol Program yiclds positive results, the Father's periods of custody shall be supervised by the Mother or another adult selected by agreement between the parties until such time as the Father's drug testing yields two consecutive negative results, at which time unsupervised periods of custody shall resume. 7. Upon successful completion of the Drug and Alcohol Program required by this Order, the Father may resume responsibility for providing transpOJ1ation for the Child during his periods of custody and for exchanges of custody. ..... . . ,'; .,..." -..... ~...,'-......._-.- .....,.;-_-.._'...''''~'~"...-...)',.-.~-"....--.'''"'-~,'~~.--'-.-"::',"~/_',""~;"Jn";,,_,,_,_,, 8. The parties shall share or altemale having custody of the Child on holidays as arranged by agreement, with the exception of Mother's Day on which the Mother shall have custody of the Child and Father's Day, on which the Father shall have custody of the Child. 9. Both parties shall ensure that the Child is not placed in the care of or left alone with the Father's sister, Nicole. 10. The Father shall not consume alcohol either before or during his periods of custody with the child. Neither party shall use illegal drugs. II. Within 60 days of the Father's completion of the Drug and Alcohol Program required by this Order, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference ifnecessary to address the custody issues. 12, 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 temlS of this Order shall control. J. cc: ~ael Schechterly, Esquire - Counscl for Father .)<arcn L. Koenigsberg, Esquire - Counsel for Mother , , " " " . ; . ';. ." , . , . , I " . " " .". ' ".:' , . '; ..' . " , . . ." ~ . ' BARRY L. CAMPBELL, JR., a Minor, by SHEILA CAMPBELL, his Guardian Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 9q - .2 7~ I ~ I..u- ERIN MEYER, CIVIL ACTION - CUSTODY Defendant COMPLAINT FOR CUSTODY 1. The plaintiff is Barry L. Campbell, Jr., residing at RR 4 Box 643, Newport, Perry County, Pennsylvania. 2. The guardian, Sheila Campbell, residing at RR 4 Box 643, Newport, Perry County, Pennsylvania and is mother of petitioner. 3. The defendant is Erin Meyer, residing at 20 Sunset Drive, Mechanicsburg, Cumberland County, Pennsylvania. 4. Plaintiff seeks shared custody of the following child: Name Present Residence Age Kara Lynn Meyer 20 Sunset Drive Mechanicsburg, P A 7 1/2 months The child was born out of wedlock. The child is presently in the custody of defendant, who resides as stated in paragraph 2. During the past five years, the child has resided with the following persons and at the following addresses: 20 Sunset Drive Mechanicsburg, P A mother, maternal grandfather, and 2 maternal uncles The mother of the child is defendant, currently residing as stated in paragraph 2. She is single. The father of the child is plaintiff, currently residing as stated in paragraph 1. He is single. 5. The relationship of plaintiff to the child is that of father. The plaintiff currently resides with the following persons: Name Relationship Barry and Sheila Campbell mother and father 6. The relationship of defendant to the child is that of mother. The defendant currently resides with the following persons: Name Relationship Kara Lynn Meyer Jerry E. Meyer Casey Meyer Courtney Meyer daughter father brother brother 7. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child in another court of the Commonwealth. 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. 8. The best interest and permanent welfare of the child will be served by granting the relief requested because father deserves and needs to be a part of his daughter's life to insure she grows into a secure adult. 9. Each parent whose parental custody 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: Name Address Basis of claim None WHEREFORE, plaintiff requests the court to grant hi custody of the child. d partial physical Dated: 5'- t.[- q 8 I verify that the statements made in this Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. ~4904 relating to unsworn falsification to authorities. pbell, plaintiff r. I verify that the statements in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904, relating to unsworn falsification to authorities. ~~ia~ eila Camp)ft:ll ~ 1-- wO C.)Z reO iJ.' i!~ ~ 6,;~ ~-- ._ WL,: , cr: ~-~~ .== lJ_ o <r: ifJ <r: ~ ...... "'-' Z>-- Of-< ~5 00 UU (..t...0 OZ<r: ~<r:z ;:J~<r: o~> uo::l...... ~~>-- ::r:;:JifJ f-<U~ z(..t...~ ......0"'-' ik \eo ~ ~~ "l") ... p ~ f'0 C") ~ ~ :z: S (") ::5:':1': .. (., ::!C (.-)~ ~ ri 0- -~ r- G1 ;:J ~ ",,'.- ~>- I <'(C,? ~ >- i'f!';Z ..-.: L,]7- :::r:. 'U"U '.c- 0.. m ...:.: en :::> 0 ^ ci ... ro ~ g .- 1t:: .-] .- ~ ::l .5 "0 >-- ~ roO~ ~ 0 ~ Ul "'-' <lJ 0 ~ .- 0 f-< .....,..<::: ifJ :s ...s...s ;:J <r: ............ u; U ...... ~~ ;;- Z o::lo::l ....... 5>-- "'-'"'-' f-< ~~ 6 .......0 cJu ci <r: f-<o ...... Uf-< .<r: ~ "'-' <r:ifJ ............ ~ ......;:J >--til ~ 0 0 >'U ~::r: U Z ......z <r:ifJ ~ u...... o::lE ~ \D ...... !::~~ \H 000 'H ,..,., ~ "",.- "'-'.......'-r--N- ...... 0 ...... 00 \D .8 E2",-,<r:~~~ "'-' ~"'-'..J. 'It:: p., _ ^M"'" ... ~ifJ8ooi:::l<E ..<:::s,-.->. >-- .~ ta r-- U <lJ ~::r: ur::: g.E ~~8~ifJ! N N , MAY 1 2 199~ BARRY L. CAMPBELL, JR., a Minor, by SHEILA CAMPBELL, his Guardian, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. NO. q1- d7~1 ~ ERIN MEYER, CIVIL ACTION - CUSTODY Defendant ORDER OF COURT And now, this Q!\e>l'lq , upon consideration of the attached complaint, it is hereby directed that the above parties and their respective counsel appear before ~ ~'-'u\c\o1 Esquire, the conciliator, at 3'1 u. \'b\~: ,s\--) ~\~ ' Pennsylvania, on the dd day of -J0\\ , 1999, at \ \()O . .~, for A Pre- Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or, if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may be present at the conference. Failure to appear at the conference may provide grounds for t he entry of a temporary or permanent order. FOR THE COURT: By: ~\).~.Jj~\f{\~~ . Custody Conciliator (~l 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. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 ". - 4:~ ~ jZ" ~ ~ t!>6 1:'/.5' h-fZ.~ ~l( ~,? C"/:/, ~~?-~H/~-~ ~t?-e/-? 't//NVA7ASNN3d J.J.NnOJ OMr11:-E:18VVnQ CS:SHd 2/AVW66 ^ U\J1rli"j'(ILJ i ""', '..':'" -'0 0'1_........ VI j 'l",.F., I ~~'-<1. .:J 3JI::1:1O-(j~ni] , JUt 1 2 199W BARRY L. CAMPBELL, JR., a Minor, by SHEILA CAMPBELL, his Guardian, plaintiff IN THE COURT OF COMMOO PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 99-2761 ERIN MEYER, : Defendant IN CUSTODY CIIDER OF CXXJRT AND I<<Jf, this 6th day of July, 1999, the Conciliator, being advised by counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction in this case. The Custody Conciliation Conference scheduled for July 6, 1999 is canceled. FOR THE COURT, 12-- JL~ Da S. Sunday, Esquir Custody Conciliator vtNY^1ASNN3cJ AlNnoO OMiflf::i38VVno , I =e Wd C I lnr 66 Al.:JVlONOHlOod 3H1 :K) 3GI:H0-Q31l.:! SEP 1 6 199~ BARRY L. CAMPBELL, JR, a minor, by SHEILA CAMPBELL, his Guardian, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. NO. 99-2761 CIVIL ERIN MEYER, CIVIL ACTION - CUSTODY Defendant ORDER OF COURT AND NOW, this;::)iS day of ~,,?\. ,1999, it is hereby directed that the above parties and thei~ res ective co~sel appear beforefu-(\ S .~SqUire, the conciliator, at ~,~1\ ~ Pennsylvania, on the day of ~~~r , 1999, at \ \ ., P. . 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 the entry of a temporary or permanent order. // ~ FOR THE COURT: I BY:~)\.Th.~ J)}.Wr~ (:jr~'- . Custody Concihator ~-'J 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. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 ~. . ~~ ~~~ ,M-bl"17 .~~ JP' J- ~w ~ ~~-~~ ~ P -fZ ~ ~.? /1l pt;ai:'-tP VlNV^lASNN3d )J.NnO::> Gt\J\fl~J38l-^~n~ 9Z :(: Wd 6G d3S 66 Al:NlONOf-U.Odd :J:-I1 ::10 3JWo--0311.:l BARRY L. CAMPBELL, JR, a minor, by SHEILA CAMPBELL, his Guardian, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. NO.99-2761 CIVIL ERIN MEYER, CIVIL ACTION - CUSTODY Defendant PRAECIPE To the Prothonotary: The parties, between their respective counsel at the time of their last scheduled conference, canceled the conference in attempt to negotiate a custody agreement. Since then defendant's counsel withdrew and defendant is no longer responding to attempts to negotiate, THEREFORE, please reappoint a conciliator and schedule a conference in attempt to resolve this matter. Dated: q-q -q I (") c ~: ;:Q Ci".' c' 'I" ;?','. --.'.,,,." <~.' Cri, is ;.:.:" ::~c: "~r'} ~~;, !i . "^? l.O :/) ''"1 -0 (") -rj - -'fr.}} ''!/~i :~l C:) i.:' :r; :.'(~) ("jrn "1 ~ 0"; .1::~ S? .:.-.) 01 . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COONTY, PENNSYLVANIA BARRY L. CAMPBELL, JR., a minor, by SHEILA CAMPBELL, his Guardian, plaintiff : : : NO. 99-2761 CIVIL TERM vs. . . Defendant : CIVIL ACTION - LAW : IN CUSTODY ERIN MEYER, CUST<DY CXECILIATIC6 ~ REPCRT IN ACCXJIDANCE WITH cmBERLAND <rofl'!' RULE OF CIVIL PROCEOORE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIR'l'B CORRENrLy IN CUST<DY OF Kara Lynn Meyer August 30, 1998 Mother 2. A Conciliation Conference was held on November 9, 1999, with the following individuals in attendance: The Father, Barry L. Campbell, Jr., with his counsel, Jerry A. Philpott, Esquire, and the Mother, Erin Meyer, with her counsel, Jacqueline M. verney, Esquire. 3. The parties agreed to entry of an order in the form as attached. /LJo ~ /;;t/l Date /0, /1'i1 . !k~ Custody Conciliator , f:H~ ~m gori ~~~ og~~ .j.J 11"\ ~ ~ "" 11"\ ....:I~E-ts: ttlG:j '" fa'..8 .., l2 P.~....:Ij : U] .S ~~ ~.oa:l~- ~ =5~rn~ ~ ~ ~'ri ttl ~~ 'ijl.~ e.O ~P.I-II~ ..c:...... 2l ~~ ,u ~ ~ ,0. ~ 0 "':::E::I '....:I . a~ <<I ~_~ ~ I-!~ ....:ItJ ~ ~ = c r~ ~ ......~8 tJa:l ~! .- ..8 CO a:lp' = tl:S t:: ..d 8\O<z ~5 jl1!ll!lt~~ ~~~r , ~ . j 8 ....:II-! :.: Ii:J ~~~ Iffi z I-! ~ ~ - ., ... . :1(1\1 :~ 199~j BARRY L. CAMPBELL, JR., a minor, by SHEILA CAMPBELL, his Guardian, Plaintiff IN THE COURT OF <X>t1MOO PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : vs. NO. 99-2761 CIVIL TERM . . ERIN MEYER, . . CIVIL ACl'ION - LAW IN CUSTODY Defendant : aIDER OF <DJRT ~ AND 1Di, this If. consideration of the attached and directed as follows: daYOfY~ CUstody COnciliation Report, , 1999, upon it is ordered 1. The Mother, Erin Meyer, and the Father, Barry L. Campbell, Jr., shall have shared legal custody of Kara Lynn Meyer, born August 30, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. 2. The Mother shall have primary physical custody of the Child. 3. The Father shall have visitation and partial physical custody of the Child in accordance with the following schedule: A. Beginning Tuesday, November 16, 1999, the Father shall have visitation with the Child at the Mother's residence every Tuesday and Thursday fran 6:00 p.m. until 8:00 p.m. for 4 weeks. The parties shall cooperate in making adjustments to the weekday schedule as necessary to accommodate the parties' work schedules. B. When the Father has exercised his periods of visitation under paragraph A of this provision for 8 consecutive periods (2 days per week for 4 weeks), the Father shall begin having partial custody of the Child every Sunday fran 12:00 noon until 4:00 p.m. and during 1 evening per week from 6:00 p.m. until 8:00 p.m. for an additional 4 weeks. The Father may exercise his right to custody under this provision either at the Mother's residence or elsewhere at his option. The specific weekday evening period of custody shall be arranged by agreement of the parties. C. When the Father has exerciSed his right to partial custody under paragraph B of this provision for 8 consecutive periods (2 times per week for 4 weeks), the Father shall have partial custody of the Child from 8:00 a.m. until 5:00 p.m. on either Saturday or Sunday of every week, with the specific day to be arranged by agreement between the parties, for 4 additional weeks. D. When the Father has exercised his right to partial custody under paragrati"l C of this provision for 4 consecutive weeks, the Father shall have partial custody of the Child on alternating weekends from Friday at 6:00 p.m. through Saturday at 7:00 p.m. and on 1 weekday evening per week, to be selected by agreement of the parties, from 6:00 p.m. until 8:00 p.m. for 8 weeks. E. When the Father has exercised his right to partial custody under paragrati"l D of this provision, thereafter on an ongoing basis, the Father shall have partial ti"lysical custody of the Child on alternating weekends from Friday at 6:00 p.m. through sunday at 6:00 p.m. and on 1 weekday evening per week from 6:00 p.m. until 8:00 p.m., with the day to be selected by agreement of the parties. 4. The parties shall have custody of the Child on holidays as follows: A. alRIS'lMAS: In 1999, the Father shall have custody of the Child on Christmas Day for a 4 hour period as arranged by agreement between the parties. The Father's period of custody on Christmas shall be considered to include his period of weekend custody under the regular custody schedule. B. THANKSGIVING: In 1999, the Mother shall bring the Child to the Father's residence for a period of custody on Thanksgiving, with the specific times to be arranged by agreement of the parties. The Father's period of custody on Thanksgiving shall be considered to include his weekday period of custody under the regular custody schedule. C. al'8ER HOLIDAYS: custody of the Thanksgiving and mutual agreement. The parties shall share or alternate having Child on the remaining holidays and on Christmas in future years as arranged by 5. The party receIvIng custody of the Child shall be responsible to provide transportation for the exchange of custody. The Father shall cooperate in providing transportation for exchanges when the Father is relinquishing custody and the Mother is working. 6. Nei ther party shall use illegal drugs or drink alcohol before or during his or her periods of custody with the Child. 7. 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. J. cc: Jerry A. Philpott, Esquire - Counsel for Father Jacqueline M. Verney, Esquire - Counsel for Mother- f'~~ 11/18 )qq. ~{J .-<d' f'. VIN\lA1ASi',JN3d I "N,nt'''{i r,~'.i~,.liH=-"li~jrVl /\Jj 1\....1."" \.....,' ",,_.,L.~r <11 Iv o I :6 I,Hf 9 I liON 66 A!:IVICNJHl.C;~d ::hl :.fO 38l:l.:10--G31!:J BARRY L. CAMPBELL, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYL VANIA v. : NO. 99-2761 CIVIL TERM ERIN MEYER, Defendant : CIVIL ACTION - LAW : IN CUSTODY CUSTODY STIPULATION AND NOW, this day of , 2000, between Barry L. Campbell, Plaintiff, hereinafter referred to as Father, and Erin Meyer, Defendant, hereinafter referred to as Mother. WHEREAS, a custody order was entered in the above captioned matter on November 18, 1999 providing for Mother to have primary physical custody of Kara Lynn Meyer, born August 30, 1998 and Father to have periods of visitation and partial custody; and WHEREAS, Mother wishes to enter the Anny Reserves requiring her to be away from the child; and WHEREAS, Mother wishes for her parents, Jerry and Kathy Meyer, (maternal grandparents) to have shared legal custody and primary physical custody of the child pending further stipulation or Order of Court; and WHEREAS, Father is in agreement with Mother that Jerry and Kathy Meyer have shared legal and primary physical custody of the child. NOW THEREFORE, Mother and Father agree as follows: I. The Order of November 18, 1999 shall remain in full force and effect as regards Father's rights to shared legal custody, visitation and partial physical custody. 2. Jerry and Kathy Meyer shall have shared legal and primary physical custody of the child. (Both Mother and Father shall continue to have shared legal custody of the child. ) 3. Mother shaH have periods of physical custody of the child as agreed by maternal grandparents and Mother. 4. The parties agree that this Stipulation shall be made an Order of Court. WIlNESS: f t'rktL. 25 ~~J5$i~j 6'u;" 'fT), 7l1.a r 1- Erin Meyer ~~ . Campbell ;..- -. 1 "'10 '>- b: ~:~ r'-') u' ~: ~;21::1 ~? ~:= L...' '. ! ;.: ;...,-~ 1-,---' lL (~) c: l""J ~ z 6~ o~ C~~ ..-;>- :,~,;t. (~4. --]~ \-~I:jm :=t~O- ~5 C> ~_.. -'- CL- L"~ ---'j ;a o C) LAW OFFICE OF Jacqueline M. Verney 'J 'AUf) 1 5 lUO~ 44 S. HANOVER ST. . CARLISLE, PA 17013 . (717) 243-9190 . FAX (717) 243-3S18 BARRY L. CAMPBELL, JR., Plaintiff v. ERIN MEYER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYL VANIA : NO. 99-2761 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT . II_~ AND NOW, this ,. of ~ ,2000, upon consideration of the attached Custody Stipulation, it is hereby ordered that the Stipulation shall be made an Order of Court. Edward E. Guido, 1. " t 'v'1N'v'AlASNN3d AlNnoo 0i\lVltG8VVnO Of1 :2 [.Id 91 tlnV 00 'f~ ~, ~ ~ IUW'C."..ln....:;I}.!C_i :"-IL .:lOr AClV..l I.L.......,I......'-,,~,; -II. 301:J:lO-'.U31d " Erin M. Meyer, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA vs. CIVIL ACTION - CUSTODY BARRY L. CAMPBELL, JR., Defendant NO. 99-2761 PETITION TO MODIFY CUSTODY 1. Plaintiff is Erin M. Meyer, mother of the child, residing at 20 Sunset Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant residing at Pennsylvania. is Barry L. Campbell, Jr., father of the child, 815 North Front Street, Newport, Perry County, 3. Custody of the minor child, Kara L. Meyer, was awarded as follows: A. Shared legal custody to both parties. B. Primary physical custody was granted to mother, with periods of partial physical custody granted to father by Order of Court dated November 18, 1999. (See copy of Order attached hereto as Exhibit "A".) 4. Plaintiff seeks to modify the current custody arrangement because: A. Mother can provide a more stable environment for the child. B. Father has placed child in danger by driving under the influence of alcohol while the child was in his vehicle. The child, who is six (6) years old, had to watch her " father be questioned by police and take a sobriety test after he picked her up for a weekend visit. C. During father's periods of visitation under the current order, father does not care for the child. Rather, he leaves the child with his parents. D. Father has never exercised his weekday evening visitation under the current order. E. Father shows no interest in the child's schooling or activities and never calls to speak with the child. WHEREFORE, Plaintiff requests the Court to modify custody of the child as follows: A. Primary physical custody of minor child with mother. B. Supervised visitation with father at mother's residence until father has successfully completed drug and alcohol counseling and mother is satisfied that the minor child is safe in the care of father. Respectfully Submitted: DISSINGER AND DISSINGER BY/)~:;!c ;~bQ"t ~ren L. K~~' Attorney for Plaintiff Supreme Court I.D. #85556 28 North 32nd Street Camp Hill, PA 17011 (717) 975-2840 " VERIFICATION I, Erin M. Meyer, verify that the statements made in the petition to Modify Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. t/)~ 1>1. n'~ Erin M. Me~r, PllAn~ff . BARRY L. CAMPBELL, JR., a minor, by SHEILA CAMPBELL, his Guardian, Plaintiff : . IN THE OOURT OF cn1MOO PLEAS OF CUMBERLAND COONTY, PENNSYLVANIA . . . . vs. : NO. 99-2761 CIVIL TERM . . ERIN MEYER, Defendant : CIVIL ACTION - LAW : IN CUS'IODY aIDER OF CXXlRT ~ AND~, this If.. consideration of the attached and directed as follows: day of ,J ~ ,1999, upon CUstody Conciliation . Report, it.is ordered 1. The Mother, Erin Meyer, and the Father, Barry L. Campbell, Jr., shall have shared legal custody of Kara LYnn Meyer, born August 30, 1998. . Each parent shall have an equal, right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general' well-being including, but not limite<,i to, all decisions regarding her health; education and religion. 2. '!be Mother shall have primary P1ysical custody of the Child. ... ." 3. The Father shall have visitation and partial P1ysical custody of the Child in accordance with the following schedule:', " , -~ !.' ..~ , A. Beginning Tuesday, November 16, 1999,' 'the Father shall have visitation with the Child at the MotJ)er's residence every Tuesday and Thursday fran 6:00 p.m.. until. 8:00 p.m. for 4 weeks. - The parties shall cooperate in Raking adjustments. to the weekday schedule as necessary to accorrmodate the parties' work schedules. . B. When the Father has exercised his periods of visitation under paragraP1 A of this provision. for 8 consecutive periods (2 days per week for 4 weeks), the Father shall begin having partial custody of the Child every Sunday fran 12:00 noon until 4:00 p.m. and during 1 evening per week fran 6:00 p.m. until 8:00 p.m. for an additional 4 weeks. The' Father may exercise his right to custody under this provision either at the Mother's residence or elsewhere at his option. The specific weekday evening period of custody shall be arranged by agreement of the parties. c. When the Father has exercised his right to partial custody under paragraph B of this provision for 8 consecutive periods (2 times per week for 4 weeks), the Father shall have partial EXHIBIT I A ,~ ',,) '.' 0) custody of the Child from 8:00 a.m. until 5:00 p.m. on either Saturday or Sunday of every week, with the specific day to be arranged by agreement between the parties, for 4 additional weeks. D. When the Father has exercised his right to partial custody under paragratx'1 C of this provision for 4 consecutive weeks, the Father shall have partial custody of the Child on alternating weekends from Friday at 6:00 p.m. through Saturday at 7:00 p.m. and on I weekday evening per week, to be selected by agreement of the parties, fran 6:00 p.m. until 8:00 p.m. for 8 weeks. E. When the Father has exercised his right to partial custody under paragratx'1 D of this provision, thereafter on an ongoing basis, the ,Father shall have partial physical custody of the Child on alternating weekends from Friday at 6:00 p.m. through sunday at 6:00 p.m. and on I weekday evening per week from 6:00 p.m. until 8:00 p.m., with the day to be selected by agreement of the parties. 4. The Parties shall have custody of the Child on holidays as follows: , . ;..' , .,"'" A.~: In 1999, the Father shall have custody of the Child on Christmas Day for. a 4 hour. period as arranged by agreement between the parties. '!he Father's period of custody on Christmas shall be considered to. include his period of weekend custody under the regular custody., schedule. B. THANKSGIVING: In 1999, the Mother shall bring the Child to the Father f s residence .for a period of custody on Thanksgiving, with the sPecific tijnesto be arranged by agreement of the parties. The Father', s period of custody on , Thanksgiving shall be considered to include his weekday period of custody under the regular custody schedule. C. CYl'HER fl)[,IDAYS: The parties shall share or alternate having custody of the Child on the remaining holidays and on Thanksgiving and Christmas in future years as arranged by mutual agreement. 5. The party receiving custody of the Child shall be responsible to provide transportation for the exchange of custody. The Father shall cooperate in providing transportation for exchanges when the Father is relinquishing custody and the Mother is working. 6. Neither party shall use illegal drugs or drink alcohol before or during his or her periods of custody with the Child. 7. This order is entered pursuant to an agreement of the parties at a :- ~::: '-::'''j~~~' ~'n::..~"'::'~"-< .::-:':.:~- .'?) : '- , ~' ------, > . ,- CUStody Conciliation ~nference. 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. J. cc: Jerry A. Philpott, Esquire - Counsel for Father f'~ ~ Jill a )qq . Jacqueline M. Verney, Esquire - COunsel for Mother - -if . -s.c:!' 'P. ~~~: .. " Erin M. Meyer, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA vs. CIVIL ACTION - CUSTODY BARRY L. CAMPBELL, JR., Defendant NO. 99-2761 CERTIFICATE OF SERVICE I, Karen L. Koenigsberg, hereby certify that on the date set forth below I served a true and correct copy of the Petition to Modify Custody upon Barry L. Campbell, Jr., Defendant, Jerry A. Philpott, Esquire, and Michael Schechterly, Esquire, by First Class United States mail addressed as follows: Barry L. Campbell, Jr. 815 North Front Street Newport, PA 17074 Jerry A. Philpott, Esquire 227 North High Street Duncannon, PA 17020 Michael Schechterly, Esquire 20 North 6th Street Newport, PA 17074 Date: II(~/o? ~ (fl~/ , / a.J'.lUV,,-- r::J0. ~'-"" ~ J Ka en L. Koeni sberg J ~ f~'. '1:. ': ~ ~ "" ~ C? L..\ ~ ~ ~ v .J 0-\ (1\ \ '-l r, C-.:C -'.j .....,-, r-....~ C7:"l c:=> c.n <- ::;: -.- o -n -l ~~~ N r--)r"'-) -n T.~: :.I~ :}( ~. .--) ;: :::., ~~fT1 ?~? .....;.. (.....) a w ERIN M. MEYER PLA INTI FF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 99-2761 CIVIL ACTION LAW BARRY L. CAMPBELL, JR. DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, January 19, 2005 __, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. at 39 West Main Street, Mechanicsburg, PA 17055 on TuesdaJ', February 15, 2005 , the conciliator, 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 exjstin:~ Protection from Abuse orders, Special Relief orders, and CustodJ' orders to the conciliator 48 hours prior to scheduled hearin2. FOR THE COURT. By: /s/ Dawn S. Sunday, Esq. Custody Conciliator ..JIC-"" The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For infonnation 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 VE 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 ~ :fW 4 ~ 4:f-V R7-/C'./ - ~.?:z- --h ~/'i7 ~'~ f)n.? ;! p;7~n,- ~~ 2z/(='/ . ~ fi.v2~nu' ~-r<-/ 50-/e'.! -",., II,:. r ,~~ :; ! f:: ! ~:: i'.~'.,'r S--i J fTB 111005 r BARRY L. CAMPBELL, JR. Plainliff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 99-2761 CNIL ACTION LAW ERIN M. MEYER Defendant i CUSTODY ORDER OF COURT ., ')",A (:-J ~..... AND NOW, this,-' day of ~ ' 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated November 18, 1999 shall continue in effect as modified by this Order. 2. The Father shall participate in a Drug and Alcohol Evaluation and Program, including regular drug testing, at Holy Spirit Hospital. The Father shall follow all recommendations provided by the program. The Father shall ensure that all drug test results are provided promptly to the Mother either directly or through counsel. 3. Pending completion of the Drug and Alcohol Program, the Father shall not drive a motor vehicle with the Child present and instead, shall arrange for either ofthe Father's parents to provide transportation for exchanges of custody and all transportation during the Father's periods of custody. 4. Re-initiation of the Father's weekend periods of custody, beginning Friday, February 18, 2005 shall be conditioned on the Father obtaining a negative drug test and providing the negalive resulI to the Mother in advance. 5. The Father's weekday evening periods of custody shall be as arranged by agreemenl between the parties. 6. In the event a drug tesl in the Drug and Alcohol Program yields positive resulIs, the Father's periods of custody shall be supervised by the Mother or another adult selecled by agreement between the parties until such time as the Father's drug lesting yields two consecutive negative resulIs, at which time unsupervised periods of custody shall resume. 7. Upon successful completion of the Drug and Alcohol Program required by this Order, the Father may resume responsibility for providing transportation for the Child during his periods of cuslodyand for exchanges of custody. 8. The parties shall share or altemale having custody ofthe Child on holidays as arranged by agreemenl, with the exception of Mother's Day on which the Mother shall have custody of the Child and Father's Day, on which the Father shall have custody of the Child. 9. Both parties shall ensure that the Child is not placed in the care of or left alone with the Father's siSler, Nicole. 10. The Father shall not consume alcohol either before or during his periods of custody with the child. Neither party shall use illegal drugs. 11. Wilhin 60 days of the Father's completion of the Drug and Alcohol Program required by this Order, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference if necessary to address the custody issues. 12. 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, Ihe terms of this Order shall control. J. cc: >>ael Schechlerly, Esquire - Counsel for Father ~aren 1. Koenigsberg, Esquire - Counsel for Mother o~-.2.3 -0.5 .....,. ~: ~; , j ... BARRY L. CAMPBELL, JR. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 99-2761 CNIL ACTION LAW ERIN M. MEYER Defendant IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLANU COUNTY RULE OF CIVIL PROCEUURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning Ihe Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kara L. Meyer August 30,1998 MOlher 2. A conciliation conference was held on February 15, 2005, with the following individuals in attendance: The Mother, Erin M. Meyer, with her counsel, Karen L. Koenigsberg, Esquire, and the Father, Barry L. Campbell, Jr., with his counsel, Michael Schechterly, Esquire. 3. The parties agreed to entry of an Order in the form as attached. H);uuo-.-y / k, ;;;1..od)" Date · tJ . 4.. ~'i Dawn S. Sunday, Esqui Custody Conciliator BARRY L. CAMPBELL, JR. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 99-2761 CIVIL ACTION - LAW ERIN M. MEYER Defendant CUSTODY PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter my appearance as attorney in Ihe above-mentioned action for the Plaintiff, BARRY L. CAMPBELL, JR. Respectfully submitted, *41,(l&~ Michael E. Schechterly Supreme Court I.D. No. 90163 20 N. 6th Street Newport, PA 17074 (717) 567-0157 DATE: J - j- c/s- t-.;:' ~<:; ;::....<1 ~~'i'~ ~. ......" , ,,-, :~) (,') -';1 ~Jll' :i: C) c..' - ERIN M. MEYER, PbiJl~iff ..L Ve-(C.,A.....' vs. BARRY L. CAMPBELL, JR., B...f_. d Rt PI","j,tr IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA NO: 99-2761 CIVIL ACTION - IN CUSTODY PRAECIPE r, Jerry A. Philpott, upon representation that Mike Schecltterly is going to take over the representation of BARRY CAMPBELL, hereby withdraw as his counsel. Dated: February 14, 2005 il itt, Esquire urt ID 227 o. igh Street, PO Box 116 on, PA 17020 r-,' f";;) (,",',':;:;') cfl :-;1:"' ;7" 70 -~ I \") ~~: <r::\ C:) -----