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HomeMy WebLinkAbout99-04420 ti Z ti h 2 2 1 6 4. G Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. Defendant CIVIL ACTION LAW NO. LAW CIVIL 19 91 CUSTODY VISITATION And now, this 11a ICA , upon consideration of the attached complaint, it is hereby directed )CCA X .GtlCQ\_ that the above parties and their respective counsel appear before - )y Esquire, the conciliator, at 16c 0 11 \n r' (lrn f %L)(A CC Cc 00S , Pennsylvania, on the C1 day of Sr o6=hr. E 1999, at 0 A) P.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 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: By: PiOtl??a >Q31bU? Custody Conciliator Cpl 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 -•? ?? . , C .a, :;i! ?'f:iA ?,??1 ??.',? ? ?. 8?1.9? l??! ?? ?r?L? ? ? i???-ico ?'yr'? ?? ?p?Q? JUL 2 3 "N` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA James Junkins, Plaintiff V. Civil Action Law 99- No. Janice Junkins, Defendant Custody CI LW 7e-,,M ORDER OF COURT AND DIRECTIVE FOR CONCILIATION NOW This day of 1999. This order will notify Janice Junkins, that you have been sued in Court to obtain custody of the child: James Lynn Junkins, Jr., Age 8 Jordan Junkins, Age 7 It is ordered and directed that Child Custody Conciliation Officer, is hereby directed to conduct a Conciliation Conference on 1999, at o'clock M, at the assigned room of the Cumberiand County Courthouse, Carlisle, Pennsylvania 17013. The anticipated length of the Conciliation Conference is one hour. The parties along with their legal counsel shall appear in person at the designated time for the Conciliation Conference. A memorandum shall re furnished to the Conciliator at least two days prior to the scheduled Conciliation Conference pursuant to 39th Judicial District Rule No. 1915.3 (b)(8). Failure to provide a Memorandum may result in the imposltion of sanctions. At the Conciliation Conference an effort will be made to see if the issues can be resolved by an agreement between the parties. If an agreement cannot be reached, the Conciliator will assist in defining and narrowing the issues to reduce the time required for hearing by the Court. At the conclusion of the Conference, the Conciliator will prepare a Conference Summary Report for further action by the Court. You have the right to be represented by an attorney who may attend the Conciliation Conference with you. If you have not secured an attorney by the date of the scheduled Conciliation Conference, you shall nevertheless personally appear at the time scheduled for the Conciliation Conference without an attorney. The Plaintiff has deposited the sum of $ 100 with the Prothonotary for the cost of the Conciliation Conference and the Court reserves the right to further assign or divide these costs. Janice Junkins, is notified that if you fail to appear as provided by this Order, an Order of Court for Custody, partial custody or visitation may be entered against you or the Court may Issue a warrant for your arrest. Pending the hearing, Defendant shall have primary physical custody of the children. Junkins v Junkins F.R. 1999- Page 2 The Defendant is hereby notified that if she disputes the Plaintiffs averments regarding the current status of the custody arrangements and this Order entered on the basis of these averments, she has the right to request a prompt conference with the Court. If the matter of temporary custody arrangements is not resolved at the conference, the Court may In atypical situations and at Its sole discretion schedule a brief hearing limited to the Issues of determining temporary custody arrangements pending the scheduled Conciliation Conference. The parties and their legal counsel, if applicable, are hereby directed to engage in meaningful negotiations to resolve this matter prior to the scheduled Conciliation Conference. 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. Pennsylvania Bar Association Lawyer Referral Service 1-800-692-7375 (PA only) or 1-717-238-6715 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 accomodations 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. By the Court, J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA James Junklns, CIVIL ACTION LAW Plaintiff 94- 4WIC) CL.,J Term V. : No. PR=O Janice Junklns, Defendant :CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is James Junkins whose address Is 17483 Amberson Rd., Spring Run, PA 17262. 2. The Defendant Is Janice Junkins whose address Is 230 Shippensburg Mobile Estates, Shippensburg, Cumberland County, PA 17257. 3. Plaintiff seeks partial physical custody of the following children: NAME PRESENT ADDRESS AGE James Lynn Junkins, Jr. 230 S.M.E. 6 years Shippensburg, PA 17257 Jordan Junkins .. " 7 years The parties were married at the time of the childrens' birth. The children are presently in the custody of Janice Junkins, 230 Shippensburg Mobile Estates, Shippensburg, PA 17257. During the past five years, the children have resided with the following persons and at the following addresses: DATES PERSONS ADDRESS 1997-1999 Janice Junkins 230 S.M.E. Shippensburg, PA 17257 1996 - 1997 Janice Junkins Shed Rd. Newville, PA 17241 -1996 James Junkins & 1723 Dry Run Rd. Janice Junkins Dry Run, PA 17220 The mother of the child is Janice Junkins. Her address is 230 Shippensburg Mobile Estates, Shippensburg, PA 17257. The parties are still married. The father of the child is James Junkins. He resides at 17463 Amberson Rd., Spring Run, PA 17262. The relationship of Plaintiff to the child is that of natural father. He lives with his sister Tammy Junkins and her children John, Jessie, Josh & Adam. 5. The relationship of Defendant to the child is the natural mother. She lives with the children, as well as her daughter Jamie and son Robbie. 5. Plaintiff has not participated in any custody action regarding the custody of James Lynn Junkins, Jr. or Jordan Junkins In this or any other Commonwealth. To the best of Plaintiffs knowledge there have been no custody proceedings regarding the custody of James Lynn Junkins, Jr. and Jordan Junkins, in this or any other Commonwealth. Plaintiff does not know of any other 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. The relief requested Is in the best interests of the child in that: A. It is in the best Interests of the children to develop a relationship with both of their parents. b. Mrs. Junkins has made it difficult for Mr. Junkins to exercise custody in the absence of a court order. Each parent whose parental rights have not been terminated and the person who has physical custody of the children 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 children will be given notice of the pendency of this action and right to intervene: NONE. 9. To the best of the Plaintiffs knowledge the Defendant is not represented by counsel in this matter. WHEREFORE, Plaintiff respectfully requests that your Honorable Court enter an Order initially granting him supervised visitation and setting up a schedule of increased periods of partial custody, leading eventually to an alternating weekend partialMus)ody, schedule. Attorney for Plaf(f 318 E. King St. vv Shippensburg, PA 17257 (717) 530-8879 ID #74464 DATE: I `I 1,? I verify that the statements made In this Complaint are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Sec. 49D4, relating to unswom falsification to authorities. L EMSA NK NS °V -9 00 ?J ?7; o m is 1- '7 C.) u? U SEP 21 1999tH JAMES JUNKINS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JANICE JUNKINS, NO. 994420 CIVIL Defendant IN CUSTODY COURT ORDER ay of September, 1999, upon consideration of the attached Custody AND NOW, thisgAA IN Conciliation Report, it is ordered and directed as follows: This Court's prior Orders on Custody shall remain in effect 2. The Father is directed to work with the children's counselors at the Stevens Center in Carlisle by setting up an appointment with the counselor and, if requested by the counselor, becoming involved in any ongoing counseling or therapy relating to the children. It is the intent of this directive that the Father be given an opportunity to understand why the children are expressing a desire to not see the Father. It is also the intent of this directive that, hopefully, the counselors can facilitate some procedure to start at least some type of minimum contact between the children and the Father even if such contact would be supervised. It will be in the discretion of the counselors at Stevens to determine whether Mr. Junkins shall meet with the children's counselor personally or with some other professional at the Stevens Center to initiate this process. 3. The parties will meet again with the Custody Conciliator on Friday, November 19, 1999 at 8:30 a.m. for another Conciliation Conference. At that time and in the event the Father is dissatisfied with the progress of the counseling an,t his opportunities to see the children, Father may request that the Court schedule !searing on the case. BY THE OURT J. Edward E. Guido cc: Richard M. Moms, Jr., Esq. f" `',"° Q?13?99 Joan Carey, Esq. J? R-EC--C,':FICE QG - - }: !QTrAY °9 S!112 2 PH 3: 2b rENPNSYLw,,m.4 JAMES JUNKINS, Plaintiff JANICE JUNKINS, Defendant Prior Judge: Edward E. Guido IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 994420 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: I. The pertinent information pertaining to the children who are the subject of this litigation is as follows: James L. Junkins, Jr., born February 3, 1991; and Jordan Junkins, born December 19, 1991. 2. A Conciliation Conference was held on September 17, 1999, with the following individuals in attendance: The Father, James Junkins, with his counsel, Richard Morris, Jr., Esquire; and the Mother, Janice Junkins, with her counsel, Joan Carey, Esquire. 3. The parties agree to the entry of an order in the form as attached. 77 , DATE Hubert X. Gilroy, squire Custody Conc? for rr,T J 1 t?g?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA JAMES JUNKINS, : CIVIL ACTION - LAW Plaintiff v. : No. 99 - 4420 JANICE JUNKINS, : IN CUSTODY Defendant ORDER AND NOW, this 2,,, I day of October, 1999, upon the motion of Richard M. Morris, Jr., Attorney for James Junkins, it is hereby ordered that the hearing scheduled before Hubert X. Gilroy, conciliator, in the above captioned case is continued from November 19, 1999 at 8:30 A.M. until November 18, 1999, at 8:30 A.M. 1 - f r.. U¢ ?? n (,? ?r 1` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA JAMES JUNKINS : CIVIL ACTION - LAW Plaintiff V. : No. 99 - 4420 JANICE JUNKINS, : IN CUSTODY Defendant Piaintifre Motion to Continue NOW COMES, James Junkins, by and through his attorney Richard M. Mons, Jr., and moves the court as follows: WHEREAS: 1. Defendant James Junkins has moved the court to modify his partial custody in this case; and 2. A conciliation in this case is scheduled before conciliator Hubert X. Gilroy on November 19, 1999, at 8:30 A.M.; and 3. Mr. Junkins has hired Atty. Morris to represent him in this case; and 4. This time is In conflict with an arbitration hearing Mr. Moms had previously scheduled in Adams County; and 5. Janice Junkins is represented by Joan Carey of Legal Services, who has consented to this continuance; and 8. The conciliator's office has given us November 18, 1999, at 8:30 A.M. as an alternate date. WHEREFORE, James Junkins respectfully requests that this court continue the above captioned case to November 18, 1999, at 8:30 A.M. r, VERIFICATION 1, RICHARD M. MORRIS, JR., hereby verify that the averments of fact set forth in this document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. 4904 71SUng to unswom falsification to authorities. . ! A a ti O U rn w cV ? ?- c E NOV 3 0 199, JAMES JUNKINS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW JANICE JUNKINS, : NO. 994420 CIVIL Defendant : IN CUSTODY COURT ORDER r AND NOW, this 3_ day of November, 1999, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: This Court's prior Orders on Custody shall remain in effect. 2. The counselors for the Mother and Father in this case are hereby authorized to communicate with each other and to communicate with legal counsel for the parties in an effort to allow an exchange of information and, hopefully, develop a plan that will facilitate a procedure to at least start some type of minimum contact between the children and the Father, even if such contact would be supervised. The parties are directed to sign any necessary releases for the exchange of this information. 3. The parties shall meet for another Custody Conciliation Conference on Thursday, February 17, 2000 at 9:30 a.m. BY THE *?I?j J. Edward E. Guido cc: Richard M. Morris, Jr., Esquire ?a/ , /94, Joan Carey, Esquire - Cam`" s .61. ••?%i4Y e9D f -? Ail $: C$ JAMES JUNKINS, Plaintiff JANICE JUNKINS, Defendant Prior Judge: Edward E. Guido M THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 994420 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: I. The pertinent information pertaining to the children who are the subject of this litigation is as follows: James L. Junkins, Jr., born February 3,1991; and Jordan Junkins, bom December 19, 1991. 2. A Conciliation Conference was held on November 18, 1999, with the following individuals in attendance: The Father, James Junkins, with his counsel, Richard M. Morris, Jr., Esquire; and the Mother, Janice Junkins, with her counsel, Joan Carey, Esquire. 3. The Conciliator recommends the entry of an order in the form as attached. DATE Hubert X. Gi oy, Esquire Custody nciliator APR o f me) JAMES JUNKINS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JANICE JUNKINS, Defendant NO. 99-4420 CIVIL IN CUSTODY COURT ORDER AND NOW, this 31 s day of March, 2000, the Conciliator being advised that the parties have reached a stipulation and that a Conciliation Conference is not necessary, the Conciliator relinquishes jurisdiction. BY THE COURT, Hubert X. Gilroy, Esquf Custody Conciliator r? ? i= : J ?. `(i C,? :c_ •?J ? i.: • ??? iiil u c:_ r ?_, C)