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Home My WebLink About99-03240,,`4 4''=, ;, ,;; ''! ;' ;; ;'';> ?`? lfN'Lllpll ', I DANNY H. POTTER and KAREN M. POTTER, PLAINTIFFS, V. CHRISTINA RODRIGUEZ, LARRY BOLLINGER and ALISON K. BOLLINGER, DEFENDANTS : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. KI. 3aeFD 6ua IN CUSTODY ORDER OF COURT AND NOW, this day of "a 1999, in consideration of the attached petition, it is hereby directed that the parties and their respectike counsel appear before Hubert X. Gilroy, Esquire, the conciliator, on the 4th Floor of the Cumberland County Courthouse on the 22nd day of June 1999, at 8:30 a.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 this conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: c J)d n(?o Rv? Hubert X. Gilroy, squire (> Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 240-3166 1-800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. r? , .,, ?, i f.: i;'r,' ?..?. I'r.;'. ,;? ? '. ? ? >, .sa?'?99 Cam/ ??,? ?u? 5? oz8 ?9? - ?? ?? .?- ,, :; ?? ???? DANNY H. POTTER and KAREN M. POTTER, PLAINTIFFS, V. CHRISTINA RODRIGUEZ, LARRY BOLLINGER and ALISON K. BOLLINGER, DEFENDANTS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 9q. 3a Yo Cur! IN CUSTODY PETITION FOR CUSTODY AND NOW, this 28th day of May, 1999, comes the Plaintiffs, Danny H. Potter and Karen M. Potter, and makes the following Petition for custody against the Defendants, Christina Rodriguez, Larry Bollinger and Alison K. Bollinger as follows: Plaintiffs are Danny H., Potter and Karen M. Potter, adult individuals, who reside at 343A Tourist Park Road, Halifax, Pennsylvania 17032. 2. Defendant is Christina Rodriguez, an adult individual who is currently residing at 20 Spring Garden Estates, Carlisle, Pennsylvania 17013. 3. The defendants are Larry Bollinger and Alison K. Bollinger, adult individuals who reside at 32 Lucinda Drive, Carlisle, Pennsylvania 17013. 2 4. The child is Brittany Reene Mellott, born March 8, 1994 (age 5), the natural daughter of defendant, Christine L. Rodriguez. 5. On October 7, 1998, defendant Rodriguez signed an agreement which gives custody of Brittany Reene Mellott to the plaintiffs. A copy of said document is attached hereto and marked as Exhibit "A". 6. This case should consolidate with the case docketed at 99-1456 Custody. 7. The plaintiffs currently enjoy primary custody of Brittany Reene Mellott and have done so since October of 1998. 8. The plaintiffs seek primary physical custody of Brittany Reene Mellott because the child's best interests require that she reside with them at this time. The natural parents concur. 3 WHEREFORE, the Plaintiffs, Danny H. Potter and Karen M. Potter, seek the relief stated above together with primary physical custody of the Brittany Reene Mellott. Respectfully submitted, IRWIN, McKNIGHT & HUGHES By: Marcu A. Mc i ht, II , Esquire 60 West Pomfret S ee Carlisle, PA 17013 (717) 249-2353 Supreme Court I.D. No: 25476 Attorney for the Plaintiffs, Danny H. Potter and Karen M. Potter Date: May 28, 1999 4 EXHIBIT "A" /t, .f&? 60mmon Wen,l4\ o?T,-,. i?nS jfUcth,\ GL L 1?Pc r P r'r{ 1. sno'} }. e c o ?' I C`?.;,CcJ C7 rn a 0.i cl 7 ?j f ? 1 I c? P\'/ I? ? C nti met-, -7% E prirr kry ?(.1,?','cc?Y lei II ?? Gfl I?1? K0.c Ht1 t?Gh?GEr Qq'f?e Tc Cc'rc fc r; ?CZn? /?jeeE Ike 11?t? 1v1?;1cJ Ci a ?5' I it 'F-re _ ?• ...?' 7f/7 e... %?"lcthe r CG1?.r ?5-?i n E ?cdr; • u e G ?a`: ? -?h Q- !?z1?hc1 f\\ o t i 5'i .?a\c? CAj Id . z?O i Lvi 1\ V• O? ,YN Q.rt C.JceE MeeY?S Fti.r 1qr?l%du/S. u -- . n ?c k?.ar?c? e 2 T?!=.I ?O LL?t-? ? ?) E S/G ? C Ct?? ? a LL'. ? 1 i ?`Ra (Yll.?; b = ?.1`, rn S PT rnE fT\c,--CZ-? MC. cnd l?? I1 J, 9 \n M Fat h -? o,;, d C1? d . oT1gk S zoo ??cst\ s?s/ c rs J ,dos . ?s r 5 , aW C\ • `?i7? y / r1 uS 'Slc? 1CC?; ?\\ 11 j YYar? ?K??x Yl ?r ( NP lzy ??.?c?11 c Q S,? nos S o ? ?bSP, ?a? Z?r?; or nc- 11 c;?p c?. rz),3Er ?c?nn ?c i1zc CtSld ?C'es If?T ?z5 i? c ; n --7 -- ?, b(//C J?Q m?lIC7 ir_7 -r's IJYt???Sr?J9? ?C?'n\o_c?l C,?S}??--J?itr?jt?l'r.r ? ?y,.`"'?, c•._ - ?, s CkI c GA - ? -,,,? ' w ai?'l j f I er l7 j 1 L) 9// S 7 7-11 ?? hc7v? ?c ???? Cc -.5lia /,' 1714frr-L.l/ ?ZyS ys/l. C<3 PC r 'y o r /D- ren r y r VERIFICATION The foregoing Petition for Custody is based upon information which has been gathered by our counsel and us in the preparation of this action. We have read the statements made in this document, and it is true and correct to the best of our knowledge, information and belief. We understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unswom falsification to authorities. DANN K POTTER 'A Y1,'1 KARENM.. POTTER Dater May 28 1999 DANNY H. POTTER and KAREN M. POTTER, PLAINTIFFS, V. CHRISTINA RODRIGUEZ, LARRY BOLLINGER and ALISON K. BOLLINGER, DEFENDANTS : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN CUSTODY CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of the Petition for Custody was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania 17013, on the date referenced below and addressed as follows: James K. Jones, Esq. 7 Irvine Row Carlisle, PA 17013 IRWIN, McKNIGHT & HUGHES By: Marcu A. Mc Ight, III, Esquire 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court I.D. No. 25476 Date: May 28, 1999 JUN 2 4 1990 LARRY E. BOLLINGER and, ALISON K. BOLLINGER, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CHRISTINE RODRIGUEZ, Defendant DANNY H. POTTER, and KAREN M. POTTER Plaintiffs v CHRISTINE RODRIGUEZ, LARRY BOLLINGER and ALISON K. BOLLINGER, Defendants CIVIL ACTION - LAW NO. 99-1456 CIVIL IN CUSTODY : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3240 CIVIL ? IN CUSTODY COURT ORDER ?[ AND NOW, this S` day of ,tune, 1999, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: Danny H. Potter and Karen M. Potter shall enjoy primary legal and physical custody of Brittany R. Mellor, born March 8, 1994. 2. Lany Bollinger and Alison K. Bollinger shall enjoy periods of visitation with the minor child as follows: A. One Saturday every month from 9:00 a.m. until 6:00 p.m. B. At such other times as agreed upon by the parties. Exchange of custody between the Potters and the Bollingers shall be accomplished at Mautzabaughs Grocery Store in Duncannon unless agreed otherwise by the panics. 3. The Mother, Christina Rodriguez, shall enjoy periods of temporary custody of the minor child as the parties may agree. ,J??y ?, , ???? 4. In the event either party desires to have this order modified, that party may contact the Custody Conciliator directly for purposes of scheduling another Custody Conciliation Conference. cc: Marcus A. McKnight, III, Esq. James K. Jones, Esq. BY THE COURT, 4J44 Kevi A. Hess LARRY E. BOLLINGER and, ALISON K. BOLLINGER, Plaintiffs v CHRISTINE RODRIGUEZ, Defendant DANNY H. POTTER, and KAREN M. POTTER Plaintiffs v CHRISTINE RODRIGUEZ, LARRY BOLLINGER and ALISON K. BOLLINGER, Defendants Prior Judge: Kevin A. [less : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-1456 CIVIL IN CUSTODY : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3240 CIVIL IN CUSTODY 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: Brittany R. Mellot, born March 8, 1994. 2. A Conciliation Conference :;s held o n I e 23, 1999, with the following individuals in attendance: The natural Mother, Christine Rodriguez, with her counsel, Marcus A. McKnight, III, Esquire; the Potters who are unrelated and are represented by Attorney McKnight; and the Bollingers, who are unrelated and represented by Attorney James K. Jones. The Father has not been in the child's life for a number of years and has had no contact at all with the child; the Father was not at the Conference and has not been named as a party and, essentially, the parties do not know where he is. 3. The parties agree to the entry of an order in the form as attached. " - DATE Hubert X. Gilroy squire Custody Conc' ator