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ADAM W. BYRO, : IN THE COURT OF COMMON PLEAS OF
PlaintIMPetitioner : CUMBRELAND COUNTY, PENNSYLANIA
V. : NO. 99-5700
MELISSA S. FINKEY, : CIVIL ACTION-LAW
Defendant\Respondent : IN CUSTODY
PLAINTIFF'S SUPPLEMENTAL PRETRIAL MEMORANDUM
AND NOW, comes the PlaintifflPetitioner, Adam W. Byro, by and through his
attorney, Jacqueline M. Verney, Esquire, and hereby files this Supplemental Pretrial
Memorandum.
II. WITNESSES
Father expects to call the following additional witness:
1. Records custodian from the Carlisle Hospital will be called to introduce the child's
medical record.
Respectfully submitted,
Date: -0-0o
?. `14L
Japiludline M. Verney, EsquireU
Supreme Ct. ID 23167
44 South Hanover Street
Carlisle, PA 17013
(717) 243-9190
Attorney for PlaintifflPetitioner
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Pretrial
Memorandum was served on the following person by Facsimile transmission on the date
indicated:
Cindy A. Sheridan
Donald Marritz, Esquire
Family Law Clinic
45 North Pitt Street
Carlisle, Pa 17013
Date: d l l/L
J cq eline M. Verney, Esqutfk
44 South Hanover Street
Carlisle, PA 17013
(717) 243-9190
Attorney for Plaintiff/Petitioner
MV 011 f oI
.Iacyueliue M. Verney JAN 1 1 200?tf j
44 S. HANOVER Si CAR[iM I. PA 1 !011 •'.-IA21'"I IA[I11 Po', t'.Ix
ADAM W. BYRO, : IN THE COURT OF COMMON PLEAS OF
PlaintiMPetitioner : CUMBRELAND COUNTY, PENNSYLANIA
V. NO. 99-5700
MELISSA S. FINKEY, : CIVIL ACTION-LAW
DefendantUtespondent : IN CUSTODY
PLAINTIFF'S PRETRIAL MEMORANDUM
AND NOW, comes the PlaintifflPetitioner, Adam W. Byro, by and through his
attorney, Jacqueline M. Verney, Esquire, and hereby files this Pretrial Memorandum.
1. PROCEDURAL HISTORY
The child involved in this matter is Savannah Violet Byro, D/O/B August 27,
1999. Plaintiff filed an Emergency Petition on September 16, 1999 seeking primary
physical custody of the child. On the same day, Defendant filed a PFA and a temporary
Order was entered wherein Defendant/Mother had primary physical custody of the child
and Plaintiff/Father was not to have any contact with the child.
On September 24, 1999 the parties agreed to share legal custody of child, Mother
was to have primary physical custody of the child and Plaintiff/Father had overnight
supervised custody of the child from September 23 to September 25, 1999. On
September 28, 1999, the parties agreed to extend Father's periods of overnight supervised
custody from September 28 to October 30, 1999, allowing Father approximately 5
ovemights every two weeks. During this time, the PFA hearing was continued generally,
with the temporary order remaining in effect.
At the Conciliation conference of October 29,1999, the parties agreed to an
interim order pending this hearing, providing for Mother to continue with primary
physical custody of the child with Father having unsupervised overnight visitation
amounting to three overnights per week. The October 29, 1999 Order also provided for
holiday visitation.
On November 15, 1999, Mother discontinued the PFA and asked that the
temporary PFA Order be vacated.
Father seeks primary physical custody of the child and has requested the hearing
set for January 13, 2000 at 1:30 p.m. before the Honorable Kevin A. Hess.
II. WITNESSES
Father expects to call the following witnesses:
1. Adam Byro - Father will be called to testify to his periods of custody with the
child, his level of care of the child when she is in his custody, his responsibility
concerning the child's medical needs, his concerns over the care that Mother provides
and other relevant matters regarding the best interest of the child.
2. Thomas Byro - the child's paternal grandfather, will testify concerning the
level of care that father provides to the child and the periods of custody that Mother has
had with the child and other relevant matters regarding the best interest of the child.
3. Robin Stahr - the child's paternal step-grandmother, will testify concerning the
level of care that father and mother provide to the child and other relevant matters
regarding the best interest of the child.
4. Carol Dunkle - caseworker for Cumberland County Children & Youth
Services, will testify concerning her involvement with the parties and other relevant
matters regarding the best interest of the child.
5. Officer Michael Sweeney - Hampton Township Police officer will testify
concerning an incident that occurred on January 2,2000 during the transfer of custody at
Mother's home.
6. Officer O'Leary - Carlisle police department will testify concerning an
incident that occurred during a transfer of the child at Father's home.
III. FATHER'S POSITION ON CUSTODY
Father requests an Order be entered granting the parties shared legal custody of
the child with Father having primary physical custody of the child and Mother having
periods of partial custody as appropriate.
Respectfully submitted,
Date: - -a , ?7• (/
cq thine M. Verney, Esquire
Supreme Ct. ID 23167
44 South Hanover Street
Carlisle, PA 17013
(717) 243-9190
Attorney for Plaintifl\Petitioner
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Pretrial Memo was
served on the following person by personal service on the date indicated:
Cindy A. Sheridan
Donald Manitz, Esquire
Family Law Clinic
45 North Pitt Street
Carlisle, PA 17013
Date: - 7 - X
cq eline M. Verney, Esquire
44 South Hanover Street
Carlisle, PA 17013
(717) 243-9190
Attorney for Plaintiff
LAW 0HI(L or
Jacqueline M. Verney
44S HANOVER S7 •CANLISII, PA 1/011 plq hi1!?I9n 1.11 (Il /1: ?1111n J0 7?0110
, 1 #4
JAN 5 20,
ADAM W. BYRO,
Plaintiff
V.
MELISSA S. FINKEY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN CUSTODY
NO. 99-5700 CIVIL TERM
DEFENDANT'S PRE-HEARING STATEMENT
This statement is submitted pursuant to Cumberland County Rule of Civil Procedure
1915.3-4.
This case involves the custody of Savannah Violet Byro, born August 27, 1999.
Savannah is the daughter of Melissa S. Finkey, defendant, and Adam W. Byro, plaintiff.
Savannah has resided primarily with her mother, Melissa S. Finkey, since her birth, and spends 3
overnights each week with her father, Adam W. Byro. The muther and father share legal custody
of Savannah. Ms. Finkey and Savannah live in Mechanicsburg with Ms. Finkey's grandmother,
Charlotte Bair. Mr. Byro lives alone in Camp Hill and is seeking to obtain primary physical
custody of Savannah.;
A. FACT WITNESSES
Melissa S. Finkey, defendant
Charlotte Bair, defendant's grandmother
B. EXPERT WITNESS
r
None,
T
C. ISSUE
Is it in the child's best interest to remove the child from the primary physical care of her
mother, Melissa S. Finkey, the primary care giver, with whom she has resided primary since her
birth?
D. ESTIMATED LENGTH OF TRIAL
%: day
E. REPORTS FROM APPROPRIATE AGENCIES
There are no reports from any agencies.
F. REPORTS OF EXPERTS INTENDED TO BE CALLED AS WITNESSES
None
Date: January 5, 2000
Supervising Attorneys
Donald Marritz
Staff Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717)243-2968
Counsel for Defendant
Thomas M. Place
ADAM W. BYRO, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
IN CUSTODY
MELISSA S. FINKEY,
Defendant NO. 99-5700 CIVIL TERM
CERTIFICATE OF SERVICE
I, Cindy A. Sheridan, hereby certify that I am serving a true and correct copy of the
Defendant's Pre-Hearing Statement on Jacqueline M. Verney, Esq., 44 South Hanover Street,
Carlisle, PA 17013 by hand delivery.
Date:
mAll
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Cindy A/ heridan
Certified) egal Intern
FAMILY LAW CLINIC
45 N. Pitt St.
Carlisle, PA 17013
717-243-2968
SUPREME COURT OF PENNSYLVANIA
WESTERN DISTRICT
AMY 4 CERASO, EscuIRE
DEPLI" PROTHONOTARY
PATRICIA A. HONARD
CHIEF CLERK
September 2, 1999
REGISTRATION UNDER RULES 321 6 322
(FSNNSYLVANiA BAR ADMISSION RULES)
OF ELIGIBLE LAW STUDENT
Cindy A Sheridan
250 S Pitt Street
Carlisle PA 17013
Thomas Place, Esquire
Robert Rains, Esquire
Donald Marritz, Esquire
Family Law Clinic - Dickinson
45 N Pitt Street
Carlisle PA 17013
801 CITYCOUNTy BUILOINO
PMTSBWWH. PA
1821"4x1
(412) SM2310
htIPYAY cwluWeaa
The above-named law student has been approved and certified
under Pa. B.A.R. 321 & 322 by:
Harvey Feldman, Associate Dean
The Dickinson School of Law
The Pennsylvania State University
150 South College Street
Carlisle, PA 17013
as a duly enrolled law student who has completed at least three
(3) semesters of legal studies, or the equivalent thereof, is of
good character, has been adequately trained and is of competent
legal ability to perform as a legal intern as of Sep 2, 1999.
Pursuant to such certification and in accordance with and
subject to the provisions of Pa. B.A.R. 321 & 322, the above
student has been registered and you have been approved to perform
the duties of supervising attorney.
WITNESS my signature and the seal of
this Court, September 2, 1999.
Patricia onar
Chief Clerk
/alf
ADAM W. BYRO, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
IN CUSTODY
MELISSA S. FINKEY,
Defendant NO. 99-5700
CONSENT AND APPROVAL FOR APPEARANCE UNDER Pa.B.A.R. 322
I hereby consent to the appearance of Cindy A. Sheridan, a Certified Legal Intern under
the supervision of an attorney, in the above-entitled custody proceeding before the Honorable
Judge Hess at 1:30 p.m. on January 13, 2000.
Date
? I. /
Melissa S. Finkey
As the supervising attorney for Cindy A. Sheridan, certified under Pa.B.A.R. 322, I
approve of her appearance on behalf of the above-named client in the above-named proceeding.
Date W
'wj
THOMAS M. PLACE
ROBERT E. RAINS
Supervising Attorney
DONALD MARRITZ
Staff Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/243-2968
ADAM W.BYRO,
Plaintiff/ Petitioner
V.
MELISSA FINKEY,
Defeadant/Respondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL ACTION-LAW
NO. "-5700 CIVIL
IN CUSTODY
ORDER OF COURT
AND NOW, this 2q4 day ofd ti, G 1999 upon
consideration of Petitioner's Emergency Petition, and after a conference in chambers with
Jacqueline M. Verney, Esquire for the Petitioner and Donald Marritz, Esquire, William J.
Patch, IV and Cindy A. Sheridan from the Family Law Clinic for Respondent it is hereby
ordered and decreed as follows:
1. That the parties shall share legal custody of the minor child, Savannah Violet Byro,
DOB August 27, 1999.
2. Mother shall have primary physical custody of the minor child, with Father having
partial physical custody on the following schedule and with the following conditions:
a. Petitioner shall have physical custody of the child from Thursday, September 23,
1999 at 8:00 a.m until Saturday, September 25, 1999 at 10:00 a.m.
b. Pending the resolution of the PFA filed against the Petitioner at 99-5701 Civil,
petitioner's periods of custody shall be supervised by, either his Father, Thomas
Byro or his Father's girlfriend, Robin Starr.
c. Pending the resolution of the PFA filed against the Petitioner at 99-5701 Civil,
Respondent shall drop off and pick up the child at Petitioner's residence at 129
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W. Pomfret Street, Carlisle, Pennsylvania, unless otherwise agreed by the parties
or the listed supervisors.
d. In order for Petitioner to care for the baby, Respondent shall provide adequate
formula, clothing, and the car seat for the baby.
3. Petitioner shall not have contact with Respondent except for matters concerning care
and custody of the child.
4. Paragraph 3, 4, and 5 of the Temporary PFA Order are hereby suspended to the extent
that they conflict with the terms of this Order. This order shall also be filed in the
PFA case docketed at 99-5701 Civil.
BY THE COURT,
Fes-- J.
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ADAM W. BYRO, : IN THE COURT OF COMMON PLEAS OF
Plaintiff/ Petitioner : CUMBERLAND COUNTY,PENNSYLVANIA
V. CIVIL ACTION - LAW
MELISSA FINKEY, : NO. qq- 5700cIVIL
Defendaut/Respondent
: IN CUSTODY
ORDER OF COURT
AND NOW, this day of , 1999 upon
consideration of Petitioner's Emergency Petition, it is hereby ordered and decreed that
the parties shall share legal custody of the minor child, Savannah Violet Byro, DOB
August 27, 1999 and that Petitioner shall have primary physical custody of the child with
Respondent having periods of partial physical custody as the parties agree.
BY THE COURT,
ADAM W. BYRO, : IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION -LAW
MELISSA FINKEY, : NO. CIVIL TERM
Defendant/Respoodent :
: IN CUSTODY
AND NOW, comes Petitioner, Adam W. gyro, by and through his attorney,
7acqueline M. Verney, Esquire and represents the following;
1. Petitioner is Adam W. Byro, who resides at 129 W. Pomfret Street, Carlisle,
Cumberland County, Pennsylvania.
2. Respondent is Melissa Finkey, residing at W. Church Avenue, Carlisle, Cumberland
County, Pennsylvania, 17013.
3. Petitioner and Respondent are the parents of Savannah Violet Byro, born on August
y
27, 1999.
4. Petitioner has filed a Custody Complaint contemporaneous with the filing of this
Emergency Petition.
5. Since the child was born on August 27, 1999, Mother has only permitted Father to see
the baby unsupervised on two occasions, on September 5, 1999 until September 6,
1999 and for one and one-half hour on September 7, 1999. Mother had agreed to
permit Father to visit with the baby on September 14, 1999 with Cumberland County
Children & Youth supervising the visit, but refused after CCC&Y agreed to
supervise. Father did see the baby on two occasions for short periods of time several
days after the baby was born with Mother supervising.
6. Mother has no permanent residence. Since the baby was bom, Mother has stayed at
various friends' apartments in the Carlisle area, including rooms 317 and 501 of the
Molly Pitcher Hotel, a two-bedroom apartment located at 65 W. Church Avenue, Apt
101, where eight people reside and at her boyfriend's parents' house at 166 E. Penn
Street. Mother does not have essential baby items to care for the baby. The baby
sleeps either on the floor on a blanket or in a car seat.
7. Father lives with his Father and his Father's girlfriend. Father has a full time job at
Carlisle Tire and Wheel. He has worked there since January 1999. Father has
purchased essential baby items and has made arrangements for day care.
8. A Conciliation conference on the Custody Complaint will not be scheduled for
approximately four weeks.
9. Father can provided a stable, caring, nurturing environment for the baby pending the
conciliation conference. Father is capable of caring for the baby. Father will permit
Mother to frequent and lengthy periods of custody pending the Conference.
10. Father fears that Mother will leave the area with the baby without notice.
11. Father seeks an emergency order to provide a stable home for the baby until Mother
locates permanent housing and a permanent Custody Order is entered.
WHEREFORE, Petitioner requests the Court, pending the Conciliation Conference
and until further Order of Court, to grant shared legal custody and primary physical
VERIFICATION
I verify that the statements made in the within Petition are true and coaect to the
best of my knowledge and belief I understand that false statements herein are made
subject to the penalties of 18 Pa. C. S.A. § 4904 relating to unworn falsification to
authorities.
Dated:
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ADAM W. GYRO, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION -LAW
MELISSA FINKEY, : NO. q9- 570O CIVIL TES
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this 4-3_ day of,
consideration of the attached Custody Con
their resoectlve enlmwa ar,all a..nae. %-e -.
rte, vvpe ( 1999, upon
is hereby directed that the parties and
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on we ;J b
day of f 1999 at C')(,) o'clockp m, r a Pre-Hearing Custody
Conference. At such conference, an effort will be n1ade to resolve the issues in dispute;
or ifthis cannot be accomplished, to define and namw 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 Conti:rence. Failure to appear at the Conference may provide grounds for
entry of a temporary or permanent order.
FOR THE COURT,
BY:
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 anvaget, a must be made at least 72 hours
prior to any hearing or business before the court. You must attend the scheduled
con*mnce or hearing.
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, PA 17013
(717) 249-3166
Custody Conciliator
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99 3FP 29 AH I I: g
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ADAM W. BYR%
Plaintiff
V.
MELISSA FINKEY,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. '?q- 5700 Cwm-fEkM
IN CUSTODY
COMPLAINT FOR CUSTODY
AND NOW, comes the plaintiff; Adam W. Byro, by and through his attorney,
Jacqueline M. Verney, Esquire and represents the following:
1. The Plaintiff is Adam W. Byro, residing 129 W. Pomfret Street, Carlisle, Cumberland
County, Pennsylvania, 17013,
2. The Defendant is Melissa Finkey, residing at 65 West Church Avenue, Apt
101,Carlisle, Cumberland County, Pennsylvania, 17013.
3. Plaintiff seeks custody of the following child:
NAi? PRESENT ADDRES AGE
Savannah Violet Byro 65 West Church Avenue, Apt 101 DOB 8127/99
Carlisle, Pennsylvania, 17013.
The child was bom out of wedlock.
The child is presently in the custody of the defendant, Melissa Finkey, who resides at
65 West Church Avenue, Apt 101, Carlisle, Pennsylvania.
During the past five Years, the child has resided with the following persons and at the
following addresses:
LIST ALL PERSONS ADDRESSES
Melissa Finney & her 2 children 317 Molly Pitcher Hotel
Joy Farber 501 Molly Pitcher Hotel
Mary Finney South Hanover St
John Finney
Don Finney .,
65 W. Church Ave. Apt 101, and
Steve Kunkel 166 E. Penn St.
Carlisle, PA
David Kunkel
Kunkel parents
Tina & William Marche%= & their 2 children
Michelle Esherman
Barry Glsa ter
Jeff Shap
DATES
various dates
from birth to
present
The mother of the child is Melissa Finney currently residing at 65 W. Church Avenue,
Apt 101, Carlisle, Pennsylvania, 17013.
She is married.
The father ofthe child is Adam W. BYro currently residing at 129 W. Pomfret Street,
Carlisle, Pennsylvania.
He is single.
4. The relationship of Plaintiff to the child is father. The Plaintiffcurrently resides
with the following persons:
NAME RELATIONSHIP
Thomas Byro Father
Robin Starr
Father's girlfriend ak
5. The relationship of Defendant to the child is mother. The Defendant currently resides
with the following persons:
ri. MI.
Tina Marchesano
William Marchesano
2 Marchesano children
Michelle Esherman
Steve Kunkel
Cheyenne Finkey
Savannah Byro
friend
friend
children of friends
friend
boyfriend
daughter
daughter
6. Plaintiff has not participated as a party or witness, or in another capacity, in other
litigation concerning the custody of this minor child in this or another court.
Plaintiff has no information of a custody proceeding concerning the child pending in
a court of this 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.
7. The best interest and permanent welftre of the child will be served by granting the
relief requested because:
a. Mother has no permanent residence and has been staying with various friends
since the baby was born, including two different rooms at the Molly Pitcher
Hotel, a two-bedroom apartment at 65 W. Church Avenue and 166 E. Penn St.
where her boyfriend lives, all in Carlisle. A total of eight (8) people live in the
two-bedroom apartment.
b. Mother has no essential baby items for the baby. The baby either sleeps on the
floor on a blanket or in a car seat.
c. Mother has two other children, both of whom live with their fathers because
Mother is unable to care form thern.
d. Mother is unable and unwilling to adequately care for the baby. Mother allowed
the baby to develop a severe diaper rash. Father provided medication to relieve
the diaper rash.
e. Father can provide a stable, healthy, loving, and nurturing environment for the
child. Father has baby items available to care for the baby, including a bassinet.
Father has arranged day care for the baby.
£ Mother has refined to allow father to visit with the child demonstrating a firm
intent not to promote communication and access to the child. Mother has
permitted Father to unsupervised visit with the child on two occasions since the
baby was born.
g. Mother instigated a dispute over the baby with the father and six of Mother's
friends resulting in Father having been charged with endangering the welfare of
the child when he refused to turn the baby over to Mother's friends. Father
vehemently denies that he endangered the welfve of the child. Mother actually
injured the child when she attempted to grab the baby around her neck from
Father's arms.
IL Father will promote communication and liberal access to the child by mother.
S. 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: NONE.
WHEREFORE, Plaintiff requests this court to grant shared legal and primary physical
custody to the child to Plaintiff.
Respectfully submitted,
Date: 9//v/S?
facqfieline M. Verney, Esqd
44 South Hanover Street
Carlisle, PA 17013
(717) 243-9190
Supreme Ct. ID 23167
Attorney for Plaintiff
VERIFICATION
I verify that the statements made in the within Complaint are true and correct to
the best of my knowledge and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C. S.A. § 4904 relating to unworn falsification to
authorities.
Dated: q/isl9F
Adam W. o
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.Jacqueline M. Verney
, ,p1G1999Y"
44 5, HANOVEAA • (. AFL IS[ I, VA 11013 • f/Ip214-9190. (A%(/1/)2.111519
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ADAM W. BYRO, : IN THE COURT OF COMMON PLEAS OF
PlaibdW Petitioner : CUMBERLAND COUNTY,PENNSYLVANIA
V. : CIVIL ACTION -LAW
MELISSA FINKEY, : NO. 99-5700 CRU
DefendanVReapondent
IN CUSTODY
ORDER OF COURT
AND NOW, this 2 F' day of- _ 5EL4t±! 1999 upon
consideration of Petitioner's Emergency Petition, and after a conference in chambers with
Jacqueline K Verney, Esquire for the Petitioner and Donald Marritz, Esquire, William J.
Patch, IV and Cindy A. Sheridan from the Family Law Clinic for Respondent it is hereby
ordered and decreed as follows:
I. That the parties shall share legal custody of the minor child, Savannah Violet Byro,
DOB August 27,1999.
2. Mother shall have primary physical custody of the minor child, with Father having
Partial Physical custody on the following schedule and with the following conditions:
a. Petitioner shall have physical custody of the child
1. Tuesday, September 28, 1999 at 6:00 am. to Thursday, September 30, 1999 at
4:00 p.m.
2. Sunday, October 3, 1999 no later than 5:00 p.m. to Tuesday October 5,1999
at 6:00 p.m.
3. Friday, October 15, 1999 at 4:00 p.m. to Sunday, October 17, 1999 at 4:00
p.m
4. Monday, October 18,1999 at 6:00 Lm. to Wednesday October 20, 1999 at
4:00 p.m
5. Thursday, October 28, 1999 8t6:00 am, to Saturday, October 30, 1999 at
10:00 a.m.
b. Pending the resolution of the PFA filed against the Petitioner at 99-5701 Civil,
Petitioner's periods of custody shall be supervised by, either his Father, Thomas
Byro or his Father's girlfriend, Robin Starr.
c. Pending the resolution of the PFA filed against the Petitioner at 99-5701 Civil,
Respondent shall drop off and pick up the child at Petitioner's residence at 129
W. Pomfret Street, Carlisle, Pennsylvania, unless otherwise agreed by the parties
or the listed supervisors.
d. In order for Petitioner to care for the baby, Respondent shall provide adequate
clothing and the car seat for the baby.
3. Petitioner shall not have contact with Respondent except for matters concerning care
and custody of the child.
4. Paragraph 3, 4, and 5 ofthe Temporary PFA Order are hereby suspended to the extent
that they conflict with the terms of this Order. This order shall also be filed in the
PirA case docketed at 99_5701 Civil.
BY THE COURT,
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ADAM W. BYRO, : IN THE COURT OF COMMON PLEAS OF
PbdudW Petitioner : CUMBERLAND COUNTY,PENNSYLVANIA
V. : CIVIL ACTION-LAW C•7"
MELISSA FROMY, NO. 99-5700 CIVIL
Defendant/Respondent
IN CUSTODY
ORDER OF COURT
AND NOW, this 28' day of 1999 upon
consideration of Petitioner's Emergency Petition, and after a conference in chambers with
Jacqueline K Verney, Esquire for the Petitioner and Donald MAIMM, Esquire, William L
Patch, IV and Cindy A. Sheridan from the Family Law Clinic for Respondent it is hereby
ordered and decreed as follows:
1. That the parties shall share legal custody of the minor child, Savannah Violet Byro,
DOB August 27, 1999.
2. Mother shall have primary physical custody of the minor child, with Father having
partial physical custody on the following schedule and with the following conditions:
a. Petitioner shall have physical custody of the child
1. Tuesday, September 28, 1999 at 6:00 am. to Thursday, September 30, 1999 at
4:00 p.m.
2. Sunday, October 3,1999 no later than 5:00 p.m. to Tuesday October 5, 1999
at 6:00 p.m.
3. Friday, October 15,1999 at 4:00 p.m to Sunday, October 17,1999 at 4:00
P.m.
4. Monday, October 18, 1999 at 6:00 a.m, to Wednesday October 20, 1999 at
4:00 p.m.
5. Thursday, October 28, 1999 at 6:00 am to Saturday, October 30, 1999 at
10:00 a.m.
b. Pending the resolution of the PFA flied against the Petitioner at 99-5701 Civil,
petitioner's Periods of custody shall be supervised by, either his Father, Thomas
Byrn or his Father's girifiiend, Robin Starr.
c. Pending the resolution of the PFA filed against the Petitioner at 99-5701 Civil,
Respondent shall drop offend pick up the child at Petitioner's residence at 129
W. Pom6rot Street, Carlisle, Pennsylvania, unless otherwise agreed by the pasties
or the listed supervisors.
d. Li order for Petitioner to care for the baby, Respondent shall provide adequate
clothing and the car no for the baby.
3. Petitioner shall not have contact with Respondent except for matters cowmning care
and custody of the child.
4. Paragraph 3, 4, and S of the Temporary PFA Order are hereby suspended to the extent
that they conflkt with the term of this Order. This order shall also be filed in the
PtA care docketed at 99.3701 Civil.
BY THE COURT,
;,
ADAM W. GYRO, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. N0. 99-5700 CIVIL TERM
MELISSA FINKEY, CIVIL ACTION - LAW
Defendant IN CUSTODY
ME OF Omw
AND NOW, this Z q ' 'day of Q Lc f , 1999, n
consideration of the attached Cust upo
°' Conciliation Report, it is ordered
and directed as follows:
1. A Hearing is scheduled in Court Room No. , of the
Cumberland County Court House, on the day of
2000, at /;30 o'clock, .m., at which time testimo 7g A
will be en.
For purposes of this Hearinc, the Father, Adam Byro, shall be deemed to be
the moving party and shall proceed initially with testimony. Counsel for
the parties shall file with the Court and opposing counsel a Memorandum
setting forth each party's position on custody, a list of witnesses who are
expected to testify at the Hearing, and a summary of the anticipated
testimony of each witness. These Memoranda shall be filed with the Court
at least 10 days prior to the Hearing date.
2. The prior Order of this Court dated September 28, 1999 shall
continue in effect through October 30, 1999. Effective October 31, 19990
the prior Order is vacated and replaced with this order.
3. The Mother, Melissa Finkey, and the Father, Adam Byro, shall have
shared legal custody of Savannah Violet Byro, born August 27, 1999. 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.
4. The Mother shall have primary physical custody of the Child, with
the Father having partial physical custody for 3 overnights each week (with
each week to be defined as running from Sunday through Saturday). The
parties shall alternate having custody of the Child on weekends. The
Father's weekend overnight periods of custody shall be considered to be
included in his 3 overnight periods of custody per week. The Father shall
provide to the Mother as much advance notice as possible of the overnight
periods of custody which he selects.
5. The parties shall have custody of the Child on holidays in
accordance with the following schedule:
I.
A- THANKSGIVIM: In 1999, the Mother shall have custody of the
Child on Thanksgiving Day until 2:00 p.m. and the Father shall
have custody of the Child on Thanksgiving Day beginning at
2:00 p.m, n9
B. CMUSTW: In 1999, the Father shall have custody of the
C: dram 8:00 a.m. on Christmas Eve through 12:00 noon on
Christmas Day, and the Mother shall have custody from 12:00
noon on Christmas Day through December 26 at 12:00 noon.
C. NEW YBARS: In 1999, the Father shall have custody of the
Child rom 8:00 a.m. on New Years Eve through New Years Day at
12:00 noon.
6. Unless otherwise agreed between the parties, the Father shall be
responsible to provide transportation for all exchanges of custody at the
Mother's residence. Custody exchanges shall take place between the parties
only and both parties shall ensure that no third parties are present during
the exchange.
7. In the event either party requires care for the Child when he or
she is working during his or her periods of custody, that party shall first
contact the other party to provide the opportunity for that party to
provide care for the Child before contacting third party caregivers.
BY THE CDURT,
•?
Kevin A. Hess, ??yy??• J.
J
11-3-99
cc: Jacqueline M. Verney, Esquire - Counsel for Father AIX x
Cindy Sheridan and Donald Marritz, Esquire - Counsel for Mother
ADAM W. BYRO, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. a NO. 99-5700 CIVIL TERM
MELISSA FINREY, a CIVIL ACTION - LAW
Defendant IN CUSTODY
CUSTODY CONCILIATICN SUMMARY REPORT
PRIOR JUDGE: Kevin A. Heal
IN ACCCROANCE W TM CUPMERLAND COUNTY RULE OF CIVIL PROCEDURE
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 BIRTH CURRBNPLY IN CUSTODY OF
Savannah Violet Byro August 27, 1999 Mother
2. A Custody Conciliation Conference was held on October 26, 1999,
with the following individuals in attendance: The Father, Adam W. Byro,
with his counsel, Jacqueline M. Verney, Esquire, and the Mother, Melissa
Finkey, with her counsel, Donald Marritz, Esquire and Cindy Sheridan.
3. This Court previously entered an Emergency Order (by consent of
parties) on September 28, 1999 under which the Mother had primary physical
custody of the Child and the Father had partial physical custody for 2
overnights each week. A temporary Protection from Abuse Order is in effect
although the Mother's counsel stated that the PFA would be withdrawn next
week. The Father filed this Petition for primary physical custody of the
Child. Although the parties discussed various proposals at the Conference
for shared custody schedules, the Father viewed these as temporary
arrangements only and requested a Hearing of the issue of primary physical
custody. It will be necessary to schedule a Hearing in this matter.
4. The Father's position on custody is as follows: The Father
believes it would be in the Child's best interest to reside primarily with
him. The Father indicated that the mother has lived in 5 different
residences since the Child was born in August. According to the Father,
there are various people moving in and out of the Mother's current
residence on a temporary basis. The Father feels that he can provide
stability for the Child which is lacking in the Mother's living
environment. Although the Father was willing to consider a shared custody
arrangement on a temporary basis, he ultimately seeks primary physical
custody of the Child. Finally, the Father stated that he plans to move to
New York as early as next Spring.
5. The Mother's position on custody is as follows: The Mother
believes it would be in the Child's best interest to continue to reside
primarily with her. The Mother stated that she is signing a 1 year lease
on her apartment within the next few days. The apartment has 4 bedrooms
and is shared by the Mother with 2 adults. The Mother also has primary
physical custody of 1 of her other 2 children and that child also resides
with her in the apartment. The Mother indicated that she would be
agreeable to following the temporary custody schedule set forth in the
attached order on an ongoing basis.
6. The Conciliator recommends an Order in the form as attached
scheduling a Hearing on the issue of primary custody and providing
temporary custody arrangements pending the Hearing. It is expected that
the Hearing will require at least one-half day.
0JV ldtj flq2
Date Dawn S. Sunday, Esqui
Custody Conciliator
OCT 2 9 !999,
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ADAM W. BYRO IN THE COURT OF COMMON PLEAS OF
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
V.
MELISSA S. FINKEY 99-5700 CIVIL ACTION LAW
DEFENDANT
. IN CUSTODY
AND NOW, this 1st day of June , 2000, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. the conciliator,
at 39 West Main Street Mechanicsburg PA 17055 on the 22nd day of June , 2000, 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.
FOR THE COURT,
By: /s/ Dawn C_ Caadd y fsq.0
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
CO JUP! _ 2 Pro 2: 0 7
CUN,E.?r?iri\J CO
PcNNSYLVATA M
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ADAM W. BYRO, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
IN CUSTODY
MELISSA S. FINKEY,
Defendant NO. 99-5700 CIVIL TERM
PETITION FOR CIVIL CONTEMPT
FOR DISOBEDIENCE OF CUSTODY ORDER
AND SANCTIONS UNDER 23 Pa.C.S. § 4346
And now, this 2nd day of May 2000, comes the Defendant/Petitioner, Melissa S. Finkey, by
her attorneys, the Family Law Clinic, and makes the following Petition for Civil Contempt for
Disobedience of a Custody Order against the Plaintiff/Respondent, Adam W. Byro under 23
Pa.C.S.§4346. Petitioner respectfully represents:
1. The petitioner is Melissa S. Finkey, an adult individual who resides at Safe Harbor,
102 West High Street, Carlisle, Pennsylvania 17013.
2. The respondent is Adam W. Byro, an adult individual whose last known address was
129 West Pomfret Street, Carlisle, Pennsylvania 17013.
3. The parties are the natural parents of Savannah Violet Byro, born August 27, 1999,
age 8 months.
4. The parties are subject to a Custody Order entered by Judge Hess on January 27,
2000, a copy of which is attached to this petition.
5. Since early March 2000, the respondent, Adam W. Byro, has refused to deliver the
child to the petitioner at the required times in accordance with paragraphs 2(a) and
(b) of the Order.
6. Respondent, Adam W. Byro, has refused to allow the petitioner, Melissa S. Finkey,
to babysit the child while respondent is at work in accordance with paragraph 4 of the
Order.
7. Respondent, Adam W. Byro, refused to split the Easter holiday with petitioner,
Melissa S. Finkey, in accordance with paragraph 5(d) of the Order.
8. The petitioner has a strong desire to maintain a relationship with her child and the
respondent's refusal to comply with the Custody Order has interfered with the
petitioner's ability to maintain this relationship.
9. The petitioner seeks enforcement of her custody rights to her child in strict
compliance with the existing Custody Order.
10. The best interests of the child require that the court grant the petitioner's requests.
11. The petitioner's counsel has contacted Jacqueline Verney, respondent's counsel,
seeking concurrence in the relief requested in this action. Ms. Verney did not
respond to this request.
WHEREFORE, Petitioner requests that this Honorable Court:
a. hold the respondent, Adam W. Byro, in contempt of court for violating the
Custody Order of January 27, 2000;
b. require the respondent to make the child available to the petitioner for
compensatory time to make up for the time she has lost;
C. enter an Order against respondent requiring him to pay a fine of $500.00 as
is set forth in 23 Pa.C.S. §4346 (a) (2); and
d. such other relief as the court deems proper.
Respectfully,
Family Law Clinic
45 North Pitt Street
Carlisle, Pennsylvania 17013
(717) 243-2968
Staff Attorney
VERIFICATION
I verify that the statements made 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 unswom
falsificati n to authorities.
Dater .
Me issa S. Tinkey, Petitioq r
ADAM W. BYRO, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
IN CUSTODY
MELISSA S. FINKEY,
Defendant NO. 99-5700 CIVIL TERM
CERTIFICATE OF SERVICE
I, Cindy A. Sheridan, hereby certify that I am serving a true and correct copy of the petition
for civil contempt for disobedience of custody order and sanctions under 23 Pa.C.S. § 4346 on
Jacqueline M. Verney, Esq., 44 South Hanover Street, Carlisle, PA 17013 by first class United States
mail.
Date: ? ?(I (lU
Midi -410A 1/f A?'
Cindy hendan
Certifi d egal Intern
FAMILY LAW CLINIC
45 N. Pitt St.
Carlisle, PA 17013
717-243-2968
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ADAM W. BYRD, . IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99-5700 CIVIL TERM
MELISSA S. FINKEY, CIVIL ACTION - LAW
Defendant IN CUSTODY
ORDER OF COURT
AMID ROW, this 7'V day of qis- , 2000, upon
consideration of the attached Custody Conciliation Reort, it is ordered
and directed as follows:
1. The parties shall obtain the assistance of Children and Youth
Services to visit the Mother's place of residence to evaluate and, if
appropriate make recommendations, regarding the adequacy of the environment
for the Child's safety. The parties shall obtain from Children and Youth
Services a letter to counsel outlining the findings. The parties shall
sign all necessary releases required by Children and Youth Services.
2. The parties shall cooperate in adjusting the partial custody
schedule by agreement based on both parties' new work schedules.
3. After the evaluation by Children and Youth Services, but within 6
months of the date of this order, counsel for either party may contact the
Conciliator to schedule an additional Custody Conciliation Conference if
necessary.
V
BY THE COURT,
Kev A. Hess, J.
cc: Jennifer Jones and Donald Marritz, Esquire - Counsel for Mother
Jacqueline M. Verney, Esquire - Counsel for Father
der.( - -\ P r-Ao A A?l OFF,""
ADAM W. BYRD,
Plaintiff
Vs.
MELISSA S. FINKEY,
Defendant
PRICK JUDGE: Kevin A. Hess
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND CCUNTY, PENNSYLVANIA
NO. 99-5700 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
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 BMH CURRENTLY IN CUSTODY OF
Savannah Violet Byro August 27, 1999 Father
2. A Conciliation Conference was held on June 22, 2000, with the
following individuals in attendance: The Father, Adam W. Byro, with his
counsel, Jacqueline M. Verney, Esquire, and the Mother's counsel, Jennifer
Jones, Legal Intern and Donald Marritz, Esquire. The Mother, Melissa S.
Finkey, did not attend the Conference or participate by telephone.
3. The parties agreed (the Mother, through counsel) to entry of an
Order in the form as attached.
qua ? ??
Date Dawn LSSunday, Esqu:r
Custody Conciliator
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JUN a
ADAM W.BYRO,
Plaintiff/Petitioner
VS.
MELISSA S. FINKEY,
Defendant/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
99-5700 CIVIL
IN CUSTODY
ORDER
AND NOW, this
following order:
21' day of January, 2000, after hearing, we enter the
1. The parties shall have shared legal custody of their minor daughter, Savannah Violet
Byro, born August 27, 1999. This means that the parties shall jointly make, after discussion and
consultation with each other, all major decisions affecting the child's growth and development
including, but not limited to, choice of day-care provider, medical and dental treatment, and
education (both secular and religious).
2. Father shall have primary physical custody of the child with mother having periods of
partial physical custody as follows:
a. When father is working the second shift (2:30 p.m. - 10:30 p.m.), mother shall
have the child from Friday at 4:00 p.m. to Monday at 6:00 a.m., or as early as 6:00 a.m.
if necessary to accommodate the work schedules of the parties and/or day-care, for two
consecutive weekends.
b. Mother has the option of six (6) additional days per month, with forty-eight (48)
hours notice to the father, from 9:00 a.m. to the following 9:00 a.m., or as early as 6:00
13
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a.m. if necessary to accommodate the work schedules of the parties and/or day-care.
There shall not be more than six (6) consecutive overnights in any given month and the
father shall have at least one full weekend (Friday evening through Monday
morning) each month.
c. The parties will attempt to spend one day a month together with the
child, at a time arranged by the parties.
d. Such other times as the parties agree.
3. Each parent will be permitted two (2) nonconsecutive weeks of vacation with their
daughter throughout the year. The party desiring vacation will notify the other party at least
thirty (30) days in advance in writing of their desire to use a vacation period. These periods shall
not take preference over a holiday period.
4. The parties will contact each other and give the opportunity for additional time with
the child when times arise during their scheduled periods of custody that a babysitter is needed
for the child. The parties must agree on day-care services for the child. Father's father and
stepmother are acceptable day-care providers.
5. Holidays:
a. Thanksgiving. The parties agree to split the Thanksgiving holiday with one
party having the child from 8:00 a.m. to 2:00 p.m. and the other party having the
child from 2:00 p.m. to 8:00 p.m.
b. Christmas. The Christmas holiday shall be broken into two segments.
Segment A shall be from Christmas Eve at 8:00 a..m. until Christmas Day at
12:00 noon. Segment B shall be from Christmas Day at 12:00 noon until December 26
at 2:00 p.m. Father shall have Segment A in 2000 and all even years thereafter.
Mother shall have Segment B in 2001 and all odd year thereafter.
c. Unless otherwise agreed upon between the parties, for the New Year's holiday,
father shall have physical custody of Savannah from 8:00 a.m. on New Year's Eve
through New Year's Day at 12:00 noon. Mother shall have physical custody of
Savannah from 12:00 noon New Year's Day until January 2"d at 2:00 p.m.
d. The parties agree to split Easter Day, Memorial Day, July 4d', and Labor
Day with one party having the child from 8:00 a.m. to 2:00 p.m. and the
other party having the child from 2:00 p.m. to 8:00 p.m.
e. Father shall have the child on Father's Day and mother shall have the child
on Mother's Day.
f. Each party shall have access to the child on the child's birthday for a
minimum of four (4) hours.
6. Both parties shall refrain from making derogatory comments about the other party in
the presence or hearing of the child and shall prevent third parties from making such comments
in the presence or hearing of the child.
7. The parties shall share transportation, with the party receiving the child having the
responsibility for picking up the child. The party receiving the child shall notify the other party
in the event that they will be more than fifteen minutes late for pick-up. Mother shall notify
father in advance of any cancellation of her custcdy period.
8. The father shall provide mother with his monthly work schedule as soon as it becomes
available to him.
9. Each party is encouraged to maintain telephone contact with the other while Savannah
is in the other's care and each shall cooperate with the other in permitting such contact.
10. Unless otherwise agreed upon between the parties, each party will be responsible for
providing diapers, formula, clothing and all other necessary items to care for Savannah while
Savannah is in that party's physical custody.
11. This court shall retain jurisdiction in this matter and father is not permitted to
relocate to a location that would necessitate a change in this custody order without first
petitioning this court.
12. Mother shall immediately obtain and fill out the appropriate documents for the
issuance of a birth certificate for the child and submit the same to the appropriate state office.
Mother shall provide a certified copy of said birth certificate to father.
13. The parties may modify this order by mutual consent.
BY THE COURT,
Jacqueline M. Verney, Esquire
For the Plaintiff/Petitioner
Family Law Clinic
For the Defendant/Respondent
Kev' A. Hess, J. /
,cofzual ?rrta?ed
Am