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IN'1'I1E COURT OF CONINION PLEAS OF CU VIRERLAND C'OUN'I')', PENNSYLVANIA
CIVIL ACTION - LAW
MICHAEL MINAIIAN,
Plaintiff
V.
HEATHER EARLY,
Defendant
: No. 99-66111 Civil'I'erm
IN CUSTODY
ORDER OF COURT
AND NOW. this day of 2000, upon consideration of the
attached Custody Stipulation dated April 6.2000. IT IS HEREBY ORDERED AND DECREED
that the terms thereof are approved and that custody and partial custody are awarded asset forth in
the Stipulation with the same lorce and effect as if the terms had been decreed by the Court
following an Evidentiary I learing.
13Y 1'IIE COURT:
n
I lonorable Edward E. Guido ' , t( \1
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IN "1113 C'OUR'I' OF CO\4\-ION PI.1.,AS . AC'TIO\I-II?AW U COUNTY. PENNSYLVANIA
MICHAEL -IINAIIAN,
Plaintiff
V.
rlrA'rruat EARLY,
I)cfendant
No. 99-6640 Civil'1'er111
IN CUSTODY
CUS'rouY S'rnlUI.ATU)N
'fhc Plaintil land Dcli:nthant (hereinafterre(erred to as "Parents") arc the natural parents
of a two-year old daughter. Kadyn ltosc Minah:ut (hereinafter relcrred to as " Kalhyii').
2. 'fhc Parents stipulate that the)' both shall equally share legal custody of Katlyn and shall
consult and inform one another concerning the major decisions and developments in the child's life
including. but not limited to. decisions on religious upbringing. education. medical treatment.
discipline. and finure changes of address.
3. The Parents agree that \-lichael \Iinahan ("Father ) shall have primary physical custody
of Katlym and that heather I': trly (..\4othcr') shall have partial physical custody of Katlyn from noon
on Saturday until the liilla?eing Tuesday at 8:OO 11.111. Mother shall provide transportation for the
transfers ofcustody unless othemise agreed upon by the Parents.
-I. The Parents agree to share ntgjor holidays.
>. Katly? shall spend her birthdays equally with her Father and her Mother as agreed upon
by the Parents.
6. Mother's periods of partial physical custody shall remain Iron, noon on Saturday until
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the lollowing'fuesday at 5:00 p.m. alter Katlyn begins school.
This Stipulation shall be made an Order of Court.
S. Neither parent shat l do anything to estrange Katlyn from the other parent and both shat l
encourage the child's relationship with the other parent. Provisions of this paragraph shall apply
equally to any other adult who May now or hereafter co-habit with Father or Mother.
9. Neither parent shall use any controlled substances nor crntsume alcohol to the point of
intoxication while the child is in that parent's custody.
10. Both parents shall keep the other parent fully informed of phone numbers and places
of t-esidence where either party resides.
11. This Stipulation may be expanded or modified by mutual agreement of the parties.
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Witness Date Michael Mi han. Plaintiff
Witness Da e Heather Parly. Defendant
MICHAEL MINAHAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. $ 1999 - 6.6•y0 C'u
HEATHER EARLY, CIVIL ACTION - LAW
Defendant CUSTODY ACTION
ORDER OF COURT
AND NOW, \1? S 1999, upon consideration of the
attached Complaint, it is hereby direct gdthat.the parties and
their respective counsel appear, before Min t NC.\ L. Erm ? l_Yl•,
the Conciliator, at ),\U 1 1\ on
the 1`744-\ day of ? ?at : CY M., for a
Pre-Hearing Custody Conferen At Sikh 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: )M RcQr= . M-LmM ,W .
Custody Conciliat e l 1
The Court of Common Pleas of Cumberland County is required
by law to comply- with the Americans with Disabilities Act of
1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business
before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business
before the court. You must attend the scheduled conference or
hearing.
YOU SHOULD TAKE 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 170131
(717) 249-3166
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MICHAEL MINAHAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. N0, S 1999
HEATHER EARLY, CIVIL ACTION - LAW
Defendant CUSTODY ACTION
ORDER OF COURT
You, Heather Early, Defendant, have been sued in court to
obtain custody, partial custody or visitation of the child:
Katlyn Rose Minahan. You are ordered to appear in erson at
on the _ day
1999, at M. for
a conciliation or mediation conference.
a pretrial conference.
a hearing before the court.
If you fail to appear as provided by this order, an order
for custody, partial custody or visitation may be entered against
you or the court may issue a warrant for your arrest.
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 170131
(717) 249-3166
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.
BY THE COURT:
Dated:
MICHAEL MINAHAN,
Plaintiff
V.
HEATHER EARLY,
Defendant
COMPLAINT FOR CUSTODY
1. The plaintiff is Michael Minahan, residing at 6078,
Apt. 14, Geneva Dr., Mechanicsburg, Cumberland County, PA 17055.
2. The defendant is Heather Early, residing at 5 Adams
St., Apt. #8, East Pennsboro, Enola, Cumberland County, PA 17025.
3. Plaintiff seeks custody of the following child:
NAME PRESENT RESIDENCE AGE
Katlyn Rose Minahan 607B, Apt. 14, Geneva Dr. 2
Mechanicsburg, PA 17055
The child was born out of wedlock.
The child is presently in the custody of Michael Minahan,
who maintains a residence at 607B, Apt. 14, Geneva Dr.,
Mechanicsburg, PA 17055.
During the past five years, the child has resided with the
following persons and at the following addresses:
PERSONS
Michael Minahan and
Emily Saul
Heather Early
Heather Early and
Michael Minahan
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. S 1999-GG`/0Cc1-P %Lu
CIVIL ACTION - LAW
CUSTODY ACTION
ADDRESSES
607B, Apt. 14, Geneva Dr
Mechanicsburg, PA 17055
5 Adams St., Apt. #8
Enola, PA 17025
687 Gap Rd.
Lewisberry, PA
DATES
12/98-present
5/98-12/98
9/97-5/98
The mother of the child is Heather Early, currently
maintaining a residence at 5 Adams St., Apt. #8, Enola, PA 17025.
She is single.
The father of the child is Michael Minahan, currently
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residing at 607B, Apt. 14, Geneva Drive, Mechanicsburg, PA 17055.
He is single.
4. The relationship of plaintiff to the child is that of
father. The plaintiff currently resides with the following
persons:
NAME RELATIONSHIP
Emily Saul Friend
Katlyn Rose Minahan Daughter
5. The relationship of defendant to the child is that of
mother. The defendant currently resides with the following
persons:
NAME
RELATIONSHIP
NONE
6. 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 pending in a court of this Commonwealth.
The court, term an number, and its relationship to this action
is: N/A.
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. The
name and address of such person is: N/A.
7. The best interest and permanent welfare of the child
will be served by granting the relief requested because: The
Plaintiff maintains a stable loving environment for Katlyn and
has been her primary care giver for the past 11 months and will
continue to cooperate with providing appropriate vistation of
Katlyn with her mother.
8. 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
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pendency of this action and the right to intervene:
NAME ADDRESS BASIS OF CLAIM
N/A N/A N/A
Wherefore, plaintiff requests the court to grant custody of
the child.
Respectfully submitted,
Edward S. Finkelstein
Attorney for Plaintiff
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 unsworn
falsification to authorities.
W - ? ? W l? t!l??
Michael Minahan
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MICHAEL MINAHAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. S 1999
HEATHER EARLY, CIVIL ACTION - LAW
Defendant CUSTODY ACTION
NOTICE
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take action
within twenty (20) days after this Complaint and Notice are
served, by entering a written appearance personally or by
attorney and filing in writing with the court your defenses or
objections to the claims set forth against you. You are warned
that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the court without further
notice for any money claimed in the Complaint or for any other
claim or relief requested by the Plaintiff. You may lose money
or property or other rights important to you.
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
P
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-06640 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MINAHAN MICHAEL
VS.
EARLY HEATHER
SHANNON SUNDAY Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within ORDER OF COURT, NOTICE & was served
upon EARLY HEATHER the
defendant, at 9:22 HOURS, on the 22nd day of November
1999 at 5 ADAMS STREET APT 41r8
ENOLA, PA 17025 CUMBERLAND
County, Pennsylvania, by handing to HEATHER EARLY
a true and attested copy of the ORDER OF COURT, NOTICE &
together with COMPLAINT FOR CUSTODY
and at the same time directing Her attention to the contents thereof.
Sheriff 'sCosts: So ans•rers: ,
Docketing 18.00
Service 9.92 Affidavit .00
Surcharge 8.00nomas n ine, neri f-
$ ?S 1D WARD S - FINKELSTEIN
1/23/1999
by C
l Put eri
Sworn and subscribed to before me
this -/?)t, day of h l
19C, 01 A. D.
-FroEnon?ry "
MICHAEL MINAHAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 1999-6640 Civil
HEATHER EARLY, CIVIL ACTION - LAW
Defendant CUSTODY ACTION
ORDER OF COURT
AND NOW, , 1999, upon consideration of the
within Petition, it is hereby ORDERED that a hearing is hereby
scheduled for
Courtroom No
. 2000 at M. in
, Cumberland County Courthouse, Carlisle, PA.
BY THE COURT:
J.
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MICHAEL MINAHAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 1999-6640 Civil
HEATHER EARLY, CIVIL ACTION - LAW
Defendant CUSTODY ACTION
PETITION FOR EMERGENCY CUSTODY ORDER
1. The plaintiff is Michael Minahan, residing at 607B,
Apt. 14, Geneva Dr., Mechanicsburg, Cumberland County, PA 17055.
2. The defendant is Heather Early, whose last known
address is 5 Adams St., Apt. #8, East Pennsboro, Enola,
Cumberland County, PA 17025.
3. On November 18, 1999 the Plaintiff filed a Complaint
for Custody in this matter.
4. A Conciliation Conference has been scheduled before
Conciliator Michael L. Bangs on April 6, 2000.
5. Since the filing of the Complaint for Custody by the
Plaintiff, the Plaintiff has learned the following:
A. Where the child's mother was living the landlord had
sent the Defendant a notice regarding trash outside the
apartment. (See letter attached hereto as Exhibit "A")
Furthermore, on a recent visit by the Plaintiff to the apartment,
the inside of the apartment was as bad as the outside.
B. The Defendant has been evicted by her landlord from the
apartment at 5 Adams Street, #8, Enola, PA.
C. The Plaintiff has been advised that the Defendant does
not provide diapers for the child.
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D. The Defendant has used coffee filters rather than toilet
paper to wipe the child.
E. The Defendant uses drugs in front of the child.
F. The mother is currently pregnant with another child out
of wedlock.
G. The mothers current boyfriend, Jason Collins, is
incarcerated in the Cumberland County Prison on drug charges and
is due to be released the middle of June.
H. Upon a recent return from a two day visit with the
mother, the child, Katlyn, had a tatoo stenciled on her belly but
not actually burned into the skin.
6. All of the above allegations indicate that it would not
be in the best interests for the child to be in the presence of
the Defendant without some type of Court ordered supervision.
WHEREFORE, the Plaintiff prays the Court issue an Emergency
custody order granting him full custody until the Custody
Conciliation Conference on April 6, 2000 or such later date as
the conciliator may adjourn the conference to.
Respectfully submitted,
Edward S. Finkelstein
Attorney for Plaintiff
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I verify
and correct.
subject to the
falsification
that the statements made
I understand that false
penalties of 18 Pa.C.S.
to authorities.
in this Petition are true
statements herein are made
§4904 relating to unsworn
I -
Michael Minahan
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NOTICE OF UNSAFE/UNSANITARY CONDITIONS
February 22, 2000
Heather Early
5 Addams Street, 118
Enola, PA 17025
Dear Ms. Early:
I have recieved complaints of garbage being left in the hallway,
and an odor emerging from the garbage.
Please take your garbage directly to the dumpster. The hallway is
not an acceptable collection point.
Please respond immediately to these items. This is a problem I
regard as serious.
If you have questions, please call me at 761-3621.
Sincerely:
Timothy Hogg
EXHIBIT "A"
MICHAEL MINAHAN,
Plaintiff
V.
HEATHER EARLY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1999-6640 Civil
CIVIL ACTION - LAW
CUSTODY ACTION
CERTIFICATE OF SERVICE
I, Kathleen Smee Hirsch, Paralegal to Edward S. Finkelstein,
Esq., hereby certify that on the qQA- day of March, 2000, a
certified copy of the Petition for Emergency Custody order in the
above matter, was served on the following person by United States
First Class Mail, postage prepaid, addressed as follows:
Joan Carey, Esq. (Attorney for Defendant)
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17013
Dated: 31q/00
Kathleen Smee Hirsch
MAR 1 0 2001, IP
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MAR I 0 2000
MICHAEL MINAHAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 1999-6620 Civil
HEATHER EARLY, CIVIL ACTION - LAW
i. Defendant CUSTODY ACTION
ORDER OF COURT
AND NOW, , 1999, upon consideration of the
within Petition, it is hereby ORDERED that a hearing is hereby
scheduled for 2000 at M. in
Courtroom No. Cumberland County Courthouse, Carlisle, PA.
BY THE COURT:
14AR I 0 100tV)
MICHAEL MINAHAN,
Plaintiff
V.
HEATHER EARLY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1999-G6-10 Civil
CIVIL ACTION - LAW
CUSTODY ACTION
ORDER OF COURT
AND NOW,
1999, upon consideration of the
within Petition, it is hereby ORDERED that a hearing is hereby
scheduled for
Courtroom No.
2000 at M. in
Cumberland County Courthouse, Carlisle, PA.
BY THE COURT:
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MICHAEL MINAHAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 1999-6640 Civil
HEATHER EARLY, CIVIL ACTION - LAW
Defendant CUSTODY ACTION
ORDER OF COURT
AND NOW, , 1999, upon consideration of the
within Petition, it is hereby ORDERED that a hearing is hereby
scheduled for
2000 at M. in
Courtroom No. , Cumberland County Courthouse, Carlisle, PA.
BY THE COURT:
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MAR 1 0 2000d'
MICHAEL MINAHAN,
Plaintiff
V.
HEATHER EARLY,
Defendant
AND NOW,
1999, upon consideration of the
within Petition, it is hereby ORDERED that a hearing is hereby
scheduled for , 2000 at M. in
Courtroom No. , Cumberland County Courthouse, Carlisle, PA.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1999-6640 Civil
CIVIL ACTION - LAW
CUSTODY ACTION
ORDER OF COURT
BY THE COURT:
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IN I'I lli COUR"I' 01. COA-I?ION PI.IiAS 01:
\11C'IiAla. \11\ \I IAN. ; CU\-1131iRLAND COU\'rY. I)FNNSYI,VANIA
Plaintiff
NO.99-6630 CIArIL'I'GRX'I
V.
CIVIi. 1\C ,r ION - LAW
rIG'I'iii:R I :V2L : CUs"rODY
Dclco d:ult
•1 EN111ORARY CAST )DY ORDER
, this ?- dap of Warch. 2000. after telephone anll'erence kith counsel
and UpOll n collsideratioll Iis enteredt ?'ithlregard to the parties eh Id?Katl n Rose
AN D ?ONY I-or oll rot` he pntie "I'e
ill, a
Manahan, d.o.b. 9/26/9S.
I. Delendant. I leather Early, herein:dicr rel'ened to as file mother, and Plaintiff.
Michael \linahan. hereinarter relerred to as the tallier, shall sliarL` Ilgal custody or tile child.
The molhcr and rather shall share physical custoeh of the child aca?rcting to the
following schedule:
a.) 'rile mother shall have the child each week from Saturday at noon. until
lltesda)' ut 3:00 p.nl.
W The lather shall have the child each week from "1'ucstlay at 3:00 p.m. until
Saturday at noon.
Transportation liar the exchan-Lc of custody shall be as Billows:
a.) I he mother shall arrange B),. be child to be picket. up at the paternal
ar:uulparctus residence for her periods or custody.
b.) "file mother and lather shall make arrangements liar the pick up or return or
the child Im the father's periods of custody.
. "1'he mother and the father. by mutual agrcenlent, may van' from this schedule at
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any time. but the Order shall remain in elTcct until titrtha" Order of Court alter Conciliation
Con(crcnce scheduled [.or April 6. 20110•
. The mother and file father shall keep each other informed of that parent's current
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phone number and address.
6. Neither the mother nor the 1"alhu- shall drink to escess or use illegal drugs while
the child is in that parent's custociv.
7. I he mother and the lather shall provide adeyuale provisions fill- the child.
including diapers and baby wipes. cehilc the child is in that parent's cuswcly.
8. Neither the mother nor the lather shall put temporerv or permanent lattoos on the
child %%ithout the consent ol'Ihe other parent.
9. The mother and the lather shall insurC that the child's environment is in clean and
sate condition while the child is in that pcu-cnl's custody.
10. The pcu-ties realize that their child's well being is paramount to any differences
they might have between themselves. Therelbre. neither party shal I do anything which mac
estrange the child from either parent. or injure the opinion ol'the child as to the other parent or
which may hamper the tree and natural development ol'the child's love and respect for the other
parent.
B\ the Court.
Edward EL Guido. Judge
Joan Carey
Attorney liar the Defendant
S Irvine Row >,. i, i l _ 1 c , l.cl
Carlisle. PA 1701 ; -I I
Ib ?c
Edward S. Finkelstein
Attorney fir the Plaintiff
700 Green St. U_
I larrisburg. PA 17102
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MICHAEL MINAI IAN. ) IN THE COURT OF COMMON PLEAS
Plaintiff ) OF CUMBERLAND COUN'rY.
PENNSYLVANIA
vs. )
NO. 99-6640 CIVII. TERM
HEATI IER EARLY. )
Defendant ) CfV(LACTION -LAW
ORDER
AND NO W this t? ! ?- day of /aft 4 2000, it being reported to the
Conciliator that the parties have reached an agreement which makes further proccedings
unnecessary, the undersigned Conciliator hereby relinquishes jurisdiction and returns the matter
to the Court Administrator. If either of the parties wishes further proccedings in this action, they
should petition the Court anew.
FOR TFIE COURT.
MICHAEL L. BANGS
Custody Conciliator
cc: Mary Ann Murphy, Esquire
Edward S. Finkelstein, Esquire
MICHAEL MINAHAN,
Plaintiff
vs.
HEATHER EARLY,
Defendant
IC }}?FTpF COMMON PLEAS APR 2 s r002D
Di ?t '8169 fY, PENNSYLVANIA
CIVIL ACTION - LAW
NO.: 99-6640 Civil Tern
CUSTODY/VISITATION
ORDER
AND NOW, this 36t
clay of M V 2002, upon consideration of
dle attached Motion end Stipulation, IT IS HEREBY ORDERED AS FOLLOWS:
1. That primary 1)11ySiCal CUStody of KATLYN ROSE MINAHAN shall be
and remain in het- father, MICHAEL MINAI-IAN.
2. That the parties shall have shared legal custody.
3. That the mother of the chilcl, HEATHER EARLY, shall have rights of
partial physical custocly as follows:
a. Every other weekend from Friday at 8:00 P.M. until Sunday at
7:00 13.M.
b. The parties shall share every other holiday, with the times
to be agreed upon by the parties. The holidays shall be New Years Day,
Memorial Day, Independence Day, Labor Day, Thanksgiving Day, Christmas,
Father's birehclay, Mother's birthday, and the child's birthday.
4. Mother shall provide all transportation for these periods of partial
CustO(KI, including both pick-up and drop-off.
5. Mothcr slhall have a working telephone at all times. Each parent shall
keep the other parent fully informed of telephone numbers and places of
residence where either party resides.
6. Neither parent shall do anything to csu-angc Kadyn from the other
parent, and both shall encourage the child's relationship with ehc other parent.
Provisions of this paragraph shall apply equally to any other adult who may
now or hcrcaftcr co-habit with Rather or Mother.
7. Neither parent shall use any controlled substances nor consume
alcohol to the point of intoxication while the child is in drat parent's custody.
8. This Stipulation may be expanded or modified by mutual agreement
of the parties.
J.
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MICHAEL MINAHAN,
Plaintiff
vs.
HEATHER EARLY,
Dcfcnclant
IN THI? COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL AC'T'ION - LAW
NO.: 99-6640 Civil Term
CUS'T'ODY/ VISI'T'ATION
PETITION TO MODIFY CUSTODY ORDER
NOW COMES the Plaintiff, MICHAEL MINAHAN, by and through his
auorncy, Chat•Ics E. Pctric, and respcctfullY rcprescnts as follows:
1. That Plaintiff is MICHAEL MINAFIAN, who currently resides at 10,59
Nanroc Drive, Mechanicsburg, County Of Cumberland, Pennsylvania.
2. That Defendant is HEATHER EARLY, who currently resides It 3312
Paxton Street, Apartment C-5, Harrisburg, County of Dauphin, Pennsylvania.
3. 'that the parties are the natural parents of a minor chilcl, KATLYN
ROSE MINAHAN, born September 26, 1997.
4. That on April 7, 2000, the Honorable Edward E. Guido entered an
Order of Custody granting primary physical custody to Plaintiff and granting
rights of temporary physical custody to Defendant. A copy of said Order is
atlachecl hereto.
.5. That the parties have reached an agreement concerning custody and
visitation with respect to tlzc said minor child and desire that this court's Order
of April 7, 2000, be amended in accordance with the attached Stipulation.
WHEREFORE, Plaintiff requests that Your Honorable Court timcnd the
Court's Order of April 7, 2000, in accordance with the attached Stipulation.
Respectfully submitted,
CHARLES E. PETRIE
3528 Brisban Strect
Flarrisbura, Pennsylvania 17111
(717) 561-1939
Attorney FOP Plaintiff
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
Upon information and belief, I verify that the statements in the foregoing
Petition are true and correct. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn
falsification to authorities.
DATE CHARLES E. PETRIE
ATTORNEY FOR PLAINTIFF
IN TI II COURT ()I: Co\I\4ON PLFAS OF C'Ll\1131iRI,AND COUNTY. T', I'IiN\Sl'LVt\NIA
C'IVII. ACTION LAW
1\110IAEL MINAl1AN,
Plaintiff
11EIATHER EARLY,
Defendant
Nu. 99-6640 Civil'I'crnt
!N CUSTODI'
ORDER OF coull,I
d'\
AND NOW, this da)'of 2000.,poll consideration of' the
?
attached Custody Stipulation dated April 6.2000. fl' IS iii'izEl3Y ORDERED AND DECREED
that the terms thereof arc approved and that custody and partial custody arc awarded as set forth in
the Stipulation with the same force and elTect as if the terms had been decreed by the Court
following an 6videntia y I learing.
BY THE COURT:
I lonorable Edward 1. Guido r1 L?
IN THE COURT OP COMMON PLEAS OP CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL ACTION - I.AW
I11C11AEL MINAIIAN,
Plaintiff No. 99-(640 Civil Term
V.
HEATHER EARLY, M CUSTODY
Defendant
CUSTODY STIPULATION
1. ThePlaintiffandDefendant(hercinafterreferredtoas"Parents") are the natural parents
of a two-year old daughter, Katlyn Rose Minahan (hereinafter referred to as "Katlyn").
2. The Parents stipulate that they both shall equally share legal custody of Katlyn and shall
consult and inform one another concerning the major decisions and developments in the child's life
including, but not limited to, decisions on religious upbringing, education, medical treatment,
discipline, and future changes ofaddress.
3. The Parents agree that Michael Minahan ("Father") shall have primary physical custody
of Katlyn; and that Heather Early ("Mother") shall have partial physical custody ofKadyn from noon
on Saturday until the following Tuesday at 8:00 p.m. Mother shall provide transportation for the
transfers of custody unless otherwise agreed upon by the Parents.
a. The Parents agree to share major holidays.
'. Katlyn shall spend her birthdays equally with her Father and her Mother as agreed upon
by the Parents.
(. Mother's periods of partial physical custody shall remain from noon on Saturday until
the following Tuesday at 5:00 p.m. alter Kallyn begins school.
This Stipulation shall be made an Order ol'Court.
5. Neither parent shall do anything to estrange KatIyn from the other parent and both shall
encourage the child's relationship with the other parent. Provisions of this paragraph shall apply
equally to any other adult who may now or hereafter co-habit with Father or Mother.
9. Neither parent shall use any controlled substances nor consume alcohol to the point of
intoxication while the child is in that parent's custody.
10. Both parents shall keep the other parent fully informed of phone numbers and places
of residence where either party resides.
11. This Stipulation may be expanded or modified by mutual agreement of the parties.
1,,4 L4 1?loo
/I'vil
Witness Date Michael Mt .ham, Plaintiff
J
Witness Da e Heather Early. Defendant
MICHAEL MINAFIAN, IN TI lI Ct7URT OF CUMYION PLEAS
Maintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL AC'T'ION - LAW
vs.
NUiNIBE'R: ()y-6640 Civil'I'erm
HEATHER EARLY,
Dcl%:ndant IN CUS'T'ODY
STIPULATION
APl-, /
AGREEMENT, treacle this /„) clay ol'2002, by and between
MICHAEL MINAI-IAN, hereinafter referred as "Father;" and HEATHER
EARLY, hereinafter referred to as "Mother;"
WITNESSETH:
WHEREAS, the parties Ileretn arc the natural parents of a minor
child, KATLYN ROSI; MINAI [AN, horn September 26, 1997; and
WHEREAS, an ()Tact' of Court was entered by the Honorable
Edlvslyd E. Guido on April 7, 3000, it copy of which is attached hereto;
and
WHEREAS, the parties clesirc to amend said Orclcr and have
Cntered into an Agreement concerning the issues of custody, and desire
Thad this Stipulation be entered ns an Amended Order of Court;
NOW, THEREFORE, intCnding to be ICgally bound, it is hereby
ngreed as follows:
I' .
I. That primary physical custody of KATLYN ROSE MINAHAN
shall be and remain in her father, MICHAEL MINAFIAN.
3. That the parties shall have shared Icgal custody.
3. That the mother of the child, HEATHER EARLY, shall have
rights of partial physical ct[Siody as follows:
a. Ever-, other weekend from Friday at 3:00 P.M. until
Sunday at 7:00 P.M.
b. One weekday per week, with the exact cletails to be agreed
upon by the parties.
c. The parties shall share every other holiday, with the times
to be agreed upon by the parties. The holiclays shall be New Years Day,
Memorial Day, Inclepencience Day, Labor Day, Thanksgiving Day,
Christmas, Father's birthday, Mother's birthday, and the child's
birthday.
4. Mother shall provicle all transportation for these periods of
partial custody, inclUdalg both pick-up and drop-off.
5. Mother shall have a working telephone at all times. Each
parent shall keep the other parent fully informed of tclephonc numbers
tuul places of resiclencc where either party resides.
A
(i• Ncilhcr prurnt shall do :mything to estrange Katlyn from the
olhcr p+o•enl, rind hollt shall encour•iige the child's relationship with the
olhcr' parcnl• 111.00siorts of this prrr:rgraph shall aPPly equally to any
other adult irho rnrrt' HOW or hcrcnl'ler co-habit with gather or Mother.
7. Ncilhcr pnrcrlt shall use nn)' controlled substances nor
r''rr,sumc alcohol to the paint of intoxication while the child is in that
Prl l'CIII ,S L'1I51 nrh',
t. 'I'bis tilipulnllrrn nurl' Dr' aspandcd or modified by mutual
ngr•r'crnclu of the pan
IN WI'I'Nis'SR 1VI IIsRl301', the parties have hereunto set their hands
and seals the (Illy and ye+u' fit:tit above written.
MICHAEL M IN NN 1
1VI'I'NI'stiti - - H' ? - ?
ATHER EARLY
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MICHAEL NIINAHAN, IN THE COURT OF COi]Mo,%l PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NOV
CIVIL ACTION - LA%V ? ?
vs.
HEATHER EARLY, NUNIBER: 99-6640 Civil Term
Defendant IN CUSTODY
ORD R
AND NOW, this day of )? 2002, upon
consideration of the within Petition, it is hereby Ordered that this Court's Order
of May 3, 2002, is modified to state that Defendant's visitation with the subject
minor child shall take place out of the presence of ROBERT YOUNG until
further Order of this Court.
BY THE COURT:
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MICHAEL MINAHAN, IN THE COURT OR COMMOM PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
vs.
NUNIBER: 99-6640 Civil Term
HEATHER EARLY,
Defendant IN CUSTODY
PETITION FOR EMERGENCY CUSTODY RELIEF
NOW COMES the Plaintiff, MICHAEL R. MINAHAN, by his attorney,
Charles E. Petrie, and respectfully represents as follows:
1. Plaintiff is MICHAEL R. MINAHAN, who currently resides at 1059
Nanroc Drive, Mechanicsburg, County of Cumberland, Pennsylvania. .
2. Defendant is HEATHER EARLY, who currently resides at 1632 Derry
Street, Harrisburg, County of Dauphin, Pennsylvania.
3. Plaintiff and Defendant are the natural parents of a minor child,
KATLYN ROSE MINAHAN, born September 26, 1997.
4. That on May 3, 2002, a Custody Order was entered by the Honorable
Edward E_ Guido granting primary physical custody to Plaintiff, and rights of
temporary physical custody to Defendant. A copy of said Order is attached
hereto as Exhibit "A."
5. On May S, 2002, Defendant relocated to the state of Arizona, and
remained a resident there until September 7, 2002, when she returned to the
Harrisburg area.
6. Defendant currently resides with her boyfriend, ROBERT YOUNG.
7. That the minor child, age 5, has reported the following incidents:
a. On October 14, 2002, the child cried and did not want to visit
with her mother and boyfriend. She stated that Mr. Young picked her up, spun
her around, and then dragged her across the carpeting. She said she had to
kick continuously in order for Mr. Young to stop this activity.
b. On October 27, 2002, Mr. Young made unkind remarks about
Plaintiff to the child, and said he was going to "kick his (Plaintiff's) butt." The
child was upset by these remarks and was unable to eat. Mr. Young picked
her up from the table by her armpits and shoved her into the wall, with her
head hitting the wall. She wiggled out of his grasp and dropped to the floor to
get away. She has a bruise on her head as a result of this incident. Mr. Young
proceeded to' tell the child that she was never returning to his home.
8. As a result of these incidents, the minor child is terrified to return to
Defendant's home.
9. The Order requires that Defendant maintain a working telephone at
all times. She presently has no telephone.
10. Plaintiff has filed a Motion to Modify Order contemporaneously with
the filing of this Petition to amend the Order.
.. -I
WHEREFORE, Plaintiff respectfully requests that Your Honorable Court
immediately modify the Order to state that Mother's visitation shall occur
outside the presence of her boyfriend until further Order of this Court.
Respectfully submitted,
5/v0
CHARLES E. PETRIE
3528 Brisban Street
Harrisburg, PA 17111
(717) 561-1939
Attorney for Plaintiff
i
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
I verify that the statements in the foregoing Petition are true and correct.
I understand that false statements herein are made subject to the penalties of
18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities
IO 12- ?,/OZ 21
DATE MICHAEL R. MINAHAN
,,
06-2002 00:24
MINAHAN,
plaintiff
vs.
EARLY,
Defendant
I TH C%R?TTUi- COMMON PLEAS
?TY, PENNSYLVANIA
CIVIL ACTION - LAW
NO.: 99-6640 Civil Term
CUSTODY /V1SI.1•AnON
APR 2 9 2002
ORDER
?L
AND NOW, thie: 3 ? day 2002, upon consideration of
i the attached Motion and Stipulation, IT I$ HEREBY ORDERED AS FOLLOWS:
s g:.
1. That primary physical custody of KATLYN R0 RR MINAHAN shall he
"`tid remain in her father, MICHAEL MINAHAN.
2. Th1t The parties shall have shared legal custody.
the mother of the child. HEATHER EARLY, shall have rights of l
3. That:
i..partial physical custody as follows:
a. Every other weekend from Friday at S:on P.M. until Sunday at }}?
1
;. .7:00 P.M.
?.'
h. The parries shall share ever} other holidaS with the times
to be agreed upon by the parties. The holidays shall be New Years Day, f
`' Memorial Day, Independence ay, LaSor Tray. Thanksgiving Day, Christmas;
D
Father's birthday, Mothcr's birthday, and the child's birrhday.
4. Mother shall provide all transportation for these periods of Partial
1.
.: custody, including. both pick-up and strop-off.
5. Mothcr shall have a working telephone at all times. Each parent shall
keep the other parent fully informed 10f telephone numbers and places of (.;
i
i
-2002 00:26
1.
tesidence where either party resides.
6. Neither parent :;hall do anythi:
parent, and both shall encourage the ch
?revisions of this paragraph shall apply
P.02
to estrange Katlyn from the cidiar
relationship with the other parent.
Lily to an y other adult who may
iow or hereafter co-habit with Father or Mother.
- I
7. Neither parent shall use any controlled substances nor rnnciime
1cohol to the point of intoxication while the child is in that parent's cusLUdy.
.: I
l S. This Stipulation may be expanded or modified by mutual agreement
if the parties.
i
BY THE COURT:
I
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J.
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TRUE COPY FROM RECORD
In Testimonywheieol, l here unto set my hand
antl ,Inc seal of said Court at Carlisle. Patio?
Thi ? da OC2?-?-•
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/?1 p? . ProtltoratarY
TOTAL P.02
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MICHAEL MINAIIAN IN'I'I I li C'OUR'I' OF C'OMN40N PLHAS OI'
PLAINTIFF CUMBERLAND COUNTY. PENNSYLVANIA
V. 99-660 CIVIL ACTION LAW
IIEATHER EARLY IN CUSTODY
DEFENDANT
r)IIDER OF COUIVI'
AND NOW, Wednesday, November 06, 2002 _. upon consideration of the attached Complaint.
it is hereby directed that parties and their respective counsel appear before NIcIissa 1'. Greev)" Fsq_, the conciliator.
al 301 Market Street, Lemoyne, PA 17043 on Monday, December 09, 2002 at 10:30 ADI
for a Pre-Bearing Custody Conference. At such conference. an cfti>rt will be made to resolve the issues in dispute: or
if this cannot be accomplished. to define and narrow the issues to he heard by the court, and to enter into it 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 bereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearim,,.
FOR TI N'. COURT.
By: ls/ M?(J3FCLL' GzC?v_ya Ess/ o
Custody Conciliator
The Court of Conmton Pleas of Cumberland County is required by law to comply with the
Americans with Disabilites Act of 1990. For information about accessible I'acilities and reasonable
accommodations available to disabled individuals having business bel''ore 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'f1IIS 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 OUI' WITERE YOU CAN GE 1' LEGAL IIELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle. Pennsylvania 17013
'telephone (717) 219-3166
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NOV 0 1 2002
MICHAEL MINAHAN, : IN THE COURT OF COMMON PLEAS OF L
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : CIVIL ACTION -LAW
HEATHER EARLY
Defendant
NO.: 99-6640 CIVIL TERM
CUSTODY/ VISITATION
ORDER OF COURT
AND NOW, upon consideration of the attached Petition, it is hereby
directed that the parties and their respective counsel appear before
the conciliator, at
on the _ day of , 2002, at _ _.M., for a
Pre-Hearing Custody Conference. At such conference, an effort will be made to
resolve the issues in dispute; or if this cannot be accomplished, to define and
narrow the issues to be heard by the Court, and to enter into a temporary
order. All children age five or older may also be present at the conference.
Failure to appear at the conference may provide grounds for entry of a
temporary or permanent order.
BY THE COURT:
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.
COURT ADMINISTRATOR, 4th Floor
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240-6200
MICHAEL MINAHAN, : IN THE COURT OF COMMOM PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
VS.
NUMBER: 99-6640 Civil Term
HEATHER EARLY,
Defendant IN CUSTODY
MOTION TO MODIFY CUSTODY ORDER
NOW COMES the Plaintiff, MICHAEL R. MINAHAN, by his attorney,
Charles E. Petrie, and respectfully represents as follows:
1. Plaintiff is MICHAEL R. MINAHAN, who currently resides at 1059
Nanroc Drive, Mechanicsburg, County of Cumberland, Pennsylvania.
2. Defendant is HEATHER EARLY, who currently resides at 1632 Derry
Street, Harrisburg, County of Dauphin, Pennsylvania.
3. Plaintiff and Defendant are the natural parents of a minor child,
KATLYN ROSE MINAHAN, born September 26, 1997.
4. That on May 3, 2002, a Custody Order was entered by the Honorable
Edward E. Guido granting primary physical custody to Plaintiff, and rights of
temporary physical custody in Defendant. A copy of said Order is attached
hereto as Exhibit "A."
5. On May 8, 2002, Defendant relocated to the state of Arizona, and
remained a resident there until September 7, 2002, when she returned to the
Harrisburg area.
6. Defendant currently resides with her boyfriend, ROBERT YOUNG.
7. That the minor child, age 5, has reported the following incidents:
a. On October 14, 2002, the child cried and did not want to visit
with her mother and boyfriend. She stated that Mr. Young picked her up, spun
her around, and then dragged her across the carpeting. She said she had to
kick continuously in order for Mr. Young to stop this activity.
b. On October 27, 2002, Mr. Young made unkind remarks about
Plaintiff to the child, and said he was going to "kick his (Plaintiff's) butt." The
child was upset by these remarks and was unable to eat. Mr. Young picked
her up from the table by her armpits and shoved her into the wall, with her
head hitting the wall. She wiggled out of his grasp and dropped to the floor to
get away. She has a bruise on her head as a result of this incident. Mr. Young
proceeded to tell the child that she was never returning to his home.
8. As a result of these incidents, the minor child is terrified to return to
Defendant's home.
9. The Order requires that Defendant maintain a working telephone at
all times. She presently has no telephone.
10. Plaintiff has filed a Motion to Modify Order contemporaneously with
the filing of this Petition to amend the Order.
WHEREFORE, Plaintiff respcctfull}' requests that Your 1-ionor,,iblc Court
modify the Order to state that Mother-'s visitation shall occur outside the
presence of her boyfriend until further Order of this Court.
Respectfully submitlcd,
CHARLES E. PETRIE
3528 Brisban Street
1-larrisburg, PA 1711.1
(717) 561-1939
Attorney for Plaintiff
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
Upon information and belief, I verify that the statements in the foregoing
Motion are true and correct. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn
falsification to authoritics.
mod/ ar4 4??
DATE CHARLES E. PETRIE
ATTORNEY FOR PLAINTIFF
-art' Yl 2002
MICHAEL MINAHAN, IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 99-6640 CIVIL TERM
V.
CIVIL ACTION - LAW
HEATHER EARLY,
IN CUSTODY
Defendant
ORDER OF COURT
AND NOW, this 10"i day of December, 2002, based upon Mother's unopposed
request for continuance, the Pre-Hearing Custody Conference previously scheduled for
December 9, 2002 is continued. It is hereby directed that the parties and their respective
counsel appear before Melissa Peel Greevy, Esquire, the Conciliator, at 301 Market
Street, Lemoyne, Pennsylvania 17043 on the 14•t" day of January, 2003 at 11:00 a.m.
for a Custody Conciliation 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 a temporary order. Failure to appear at the
conference may provide grounds for entry of a temporary or permanent order.
from
hours
to furnish any and all existing Protection
and Custody Orders to the Conciliator 48
FOR TC, EW COU T:
Melissa Peel Greevy, Esquire
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the
court, please contact our office. All arrangements must be made at least 72 hours prior to
any hearing or business before the court. You must attend the scheduled conference or
hearing.
YOU SHOULD TAKE 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
The court hereby directs the parties
Abuse Orders, Special Relief Orders
prior to scheduled hearing.
Dist - Charles E. Petrie, Esq.. 3528 Brisban Street, Harrisburg, PA 17111
Hcalher Early, 1632 Derry Street, Harrisburg, PA 17104
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fl[EG 2 2002
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MICHAEL MINAHAN, IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff NO. 99-6640 CIVIL TERM
V. CIVIL ACTION - LAW
HEATHER EARLY, IN CUSTODY
Defendant
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 BIRTH CURRENTLY IN THE CUSTODY
Father
Katlyn Rose Minahan September 26, 1997
2. Father filed a Petition for Emergency Custody Relief contemporaneously with
his Motion to Modify Custody Order on October 30, 2002. The Petition for Emergency
Custody Relief was addressed by Judge Hoffer and an Order was signed on November 5,
2002 modifying Judge Guido's May 3, 2002 Custody Order to state that the Defendant's
visitation with the child shall take place outside of the presence of Robert Young until further
Order of Court. The May 3, 2002 Order provides for Father to have primary physical
custody and Mother to have partial physical custody on alternate weekends, shared
holidays and transportation to be provided by Mother. The Order provides, inter alia, that
Mother maintain a working telephone at all times.
3. A Custody Conciliation Conference was scheduled for December 9, 2002.
sehan, and his counsel, Charles E.
Attending thee•onferenc Mother, Heather Early attended proMina
Petrie,
4• At the time of the conference, the Lower Allen Township Police appeared with
a warrant for Mother's arrest. Therefore, the conference was abbreviated. Mother indicated
that she had planned to seek a continuance because she had not been able to get in
contact with counsel who had previously represented her at another Conciliation
Conference. Mother's request was unopposed by Plaintiff. The Defendant was informed
that the conciliator would grant a continuance to allow her to obtain counsel prior to the next
conciliation date. However, the Defendant was advised that it would not be continued again
for this purpose. The Defendant indicated that the counsel that she had used in another
Custody Conciliation was Joan Carey from Mid Penn Legal Services.
5. When the conciliator's office contacted Mid Penn Legal Services, it was
learned that Ms. Early did not have a file opened for this matter. Therefore, the conference
was rescheduled in accordance with a time available in the schedule for Plaintiff's counsel.
?r
M
?r
NO. 99-6670 CIVIL TERM
However, a courtesy copy of the Scheduling Order was forwarded to Mid Penn Legal
Services.
6. No changes were made to the Orders of May 3, 2002 and November 5, 2002.
1'Yi0(a 1,
Date
Melissa Peel Greevy, Esquire
Custody Conciliator
L
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:166004
JAN 21 2003'(
MICHAEL MINAHAN,
Plaintiff
V.
HEATHER EARLY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6640 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 BIRTH CURRENTLY IN THE CUSTODY OF
Katlyn Rose Minahan September 26, 1997 Father
2. A Custody Conciliation Conference was held on January 14, 2003 with the
following individuals in attendance: the Father, Michael Minahan, and his counsel, Charles
E. Petrie, Esquire; the Mother, Heather Early attended pro se. The Conference had been
continued from its prior date of December 9, 2002 because Mother requested a continuance
at the time of the Conference due to her wish to obtain counsel. Additionally, the December
9, 2002 was abbreviated due to Mother's arrest on harassment charges. The parties
reached an agreement for some periods of partial custody outside of the presence of Mr.
Young. The parties also agreed that Mother could visit with the child in the context of her
preschool program at St. John's Lutheran Church in Shiremanstown, Pennsylvania. Mother
was provided with the telephone number and address of the preschool. Mother was also
provided with the name of the elementary school where the child attends morning
Kindergarten. Father agreed to provide some transportation or assistance by taking the
child on a visit with Mother on Saturday, January 18, 2003.
3. At the time of the Conference, Mother was undecided as to whether she would
want a hearing to modify the Order allowing her to have periods of partial custody without
regard to whether Mr. Robert Young would be present during those periods of custody. In
the event that Mother decides to pursue a change in the terms of the present Order she has
been advised it will be necessary for her to petition the Court and that she may contact Mid
Penn Legal Services for representation in that rpa er. Therefore, a hearing was not
scheduled at this time.
r?
Date Melissa Peel Greevy, Esquire
Custody Conciliator
Dist: Charles E. Petrie, Esq., 3528 Brisban Street, Harrisburg, PA 17111 - g
Heather Early. 1632 Derry Street, Harrisburg, PA 17104 10??'c?r .yvan..lc cL. ?'
:167057
L
MICIIAEL MINAIIAN IN 'I'i II: COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY. PENNSYLVANIA
V. 99-6640 CIVILACr1ON LAW
FIEA•rBER EARLY IN CUSTODY
1)Ii1'-liNDAN'I'
ORDRR OF COIIR•1'
AND NOW, WednesdayApril 07 2004 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before . Melissa P. Greevy, Fsq.the conciliator.
at 301 Market Street, Lemoyne, PA 17043 on Thursday, April 29, 2004 at 1:00 PDT
for a Pre-Ilcaring 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 in the conference. Failure to appear at the conference may
provide grounds for entry ol'a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR "111I: COUR•f.
mhc
By: r+r Mellssnl._Grrr-v_y,-Est
Custody Conciliator
The Court of Common pleas ol'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 SFIOULD TAKE'I•111S PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN A'170RNFY OR CANNOT AFFORD ONE. GO'I'O OR'I'ELEPIIONL THE OFFICE SI I'
FOR7111 BELOW TO FIND OUTWIIERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 1701:
Telephone (717) 249-3166
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MICHAEL MINAHAN, : IN THE COURT OF COJIJION PLEAS OF
Plaintiff/Respondent CUMBERLAND COUN7\' PENNSYLVANIA
vs. No. 99-6640 CIVIL TERM
HEATHER EARLY,
Defendant/Petitioner . INCUSTODY
ORDER OF COURT
AND NOW, this _ day of upon consideration of the Petition for
Contempt and Modification, the following Order is entered:
1. The Respondent is in contempt of the existing May 3, 2003, Court Order.
2. This matter shall be scheduled for a conciliation to establish terms for a modified order
establishing a visitation schedule for Petitioner.
3. Petitioner is granted periods of visitation at the YWCA in Harrisburg on Saturdays from
9:00 a.m. until 4:00 p.m., until the conciliation can be scheduled. The parties shall
immediately contact the Harrisburg YWCA to schedule their orientations and begin the
visitation schedule.
4. Respondent shall allow Petitioner reasonable telephone contact with the child.
By the Court,
J.
Jessica Diamondstone, Attorney at Law
MidPenn Legal Services
S Irvine Row
Carlisle, PA 17013
Charles Petrie, Esquire
3525 Brisban Street
Harrisburg, PA 171 11
r°
MICHAEL MINAIIAN,
Respondent/Plaintiff
VS.
IN 'rnt.. Coum or comMON PLEAS OF
CUMBERLAND COU\TY ITNNS 'L\'ANIA
No. 99-6610 CIVIL TERM
IIEATIIER EAKLY,
PetitionerMefendant
IN CUSTODY
Il
PET'IT'ION FORCONTE.-NiPTAND.-MODIFICATION'
Petitioner, Heather Early, by and through her counsel, Jessica Dianhondstone of
MidPenn Legal Smices, states the following:
1. Petitioner/Defendant, hcrcinafter referred to as the mother, resides at 120 Dauphin
Street, Enola, Cumberland County, Pennsylvania 17025.
2. Respondent/Plaintiff, hcrcinafter referred to as the father, resides at 115 Sixth
Street, New Cumberland, Cumberland County, Pennsylvania.
3. The above-named parties are the natural parents of Katlyn Rose Minahan, born
September 26, 1997.
4. The current Custody Order, attached as Exhibit "A" and incorporated herein by
reference, is dated May 3, 2002. The Order, in pertinent part. grants the mother
periods of partial custody on alternating weekends from Friday at 5:00 p.m.
through Sunday at 7:00 p.m.
5. The father has willfully disobeyed the Order in ways including. but not limited, to
the following:
a. Refusing to permit the mother to exercise her periods of partial
custody in accordance with the Court Order.
b. Unilaterally limiting the mother's telephone and physical contact to
i
the conditions he drafted in Exhibit D. Although the mother signed
Exhibit B, she was unlawfully and arbitrarily coerced in that her only
alternative was to have no contact with the child.
c. Despite Exhibit B, the father has unlawfully denied mother all contact
with the child since December 25, 2003.
6. The father is not acting in the child's best interest for reasons including, but not
limited to, the following:
a. The father has willfully denied the mother both physical and phone
contact with the child in ways set forth in paragraph five of this Petition
For Contempt and Modification.
b. The father is trying to alienate the child from her mother.
7. The mother is entitled to periods of visitation with the child for reasons including,
but not limited to, the following:
a. The mother has demonstrated her commitment to pursuing a sober and
healthy life and to provide for the child.
b. The mother has been sober for three months.
c. The mother wants to re-enter the child's life gradually and agrees to
periods of visitation without overnights, initially, to re-establish a
relationship with the child and demonstrate her commitment to providing a
safe and nurturing environment for the child.
d. The mother is gainfully employed.
e. The mother is active in AA and NA and attends meetings at least two
times each week.
C without this Court's intervention, the child is at risk of being hamied front
being denied contact with her mother.
8. The father is represented by Attorney Charles Petrie.
9. The mother's counsel has contacted Attorney Petrie, who does not concur Nvith
the relief requested in this Petition.
WHEREFORE, Petitioner respectfully requests the following:
a. That this Court find the Respondent in contempt of the existing
May 3, 2002 Court Order.
b. That this matter be scheduled for a conciliation to establish terms
for a modified order establishing a visitation schedule for
Petitioner.
c. That the Court immediately grant Petitioner periods of visitation
at the YWCA in Harrisburg on Saturdays from 9:00 a.m. until
4:00 p.m., until a conciliation can be scheduled and order the
parties to immediately contact the Harrisburg YWCA to
scheduled their orientations and begin the visitation schedule.
d. That the Court order Respondent to allow Petitioner reasonable
telephone contact with the child.
c. Any other relief this court deems just and proper.
Respectfully sufittted,?-
Jessica 9 mo stone
Attorney for Petitioner/Defendant
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
M1CI-IAEL MINAHAN, IyN,??T.,FIErCOURT OF CO\INION PLEAS APR y 'l.0i12
Plaintiff ?,}1`??L6UNTY. PENNSYLVANIA
VS. CIVIL ACTION - LAW
HEATHER EARLY, NO.: 99-6640 Civil Term
Defendant CUSTODY/VISITATION
ORDER
AND NOW, this 3,uL clay of 2002, upon consideration of
the attached Motion and Stipulation, IT IS HEREBY ORDERED AS FOLLOWS:
1. That primary physical custody of KATLYN ROSE MINAHAN shall be
and remain in her father, N41CHAEL MINAHAN.
2. That the parties shall have shared legal custody.
3. That the mother of the child, HEATHER EARLY, shall have rights of
partial physical custody as follows:
a. Every other weekend from Friday at 5:00 P.%4. until Sunday at
7:00 P.M.
b. The parties shall share every other holiday, with the times
to be agreed upon by the parties. The holidays shall be New Years Day,
Memorial Day, Independence Day, Labor Day, Thanksgiving Day, Christmas,
Father's birthday, Mother's birthday, and the child's birthday.
4. Mother shall provide all transportation for these periods of partial
custody, including both pick-up and drop-off.
5. Mother shall have a working telephone at all times. Each parent shall
keep the other parent fully informed of telephone numbers and places of
X liii; 1 7 '.A"
,
residence where either par:y resides.
6. Neither parent shall do anything to estrange Katlyn from the other
parent, and both shall encourage the child's relationship with die other parent.
Provisions of this paragraph shall apply equally to any other adult who may
now or hereafter co-habit with rather or Mother.
7. Neither parent sha11 use any controlled substances nor consume
alcohol to the point of intoxication while the child is in that parent's custody.
S. This Stipulation may be expanded or modified by mutual agreement
of the parties.
BY THE COURT:
_/Sl erd?en.?tl ?((
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J.
TRUE COPY FROM RECORD
In Testimony whereof, I here unto set my hane
and the seal of said Court at Carlisle, Pa.
This. 3 day of?dA,o?-
C' ' . Pmthonotary
MICHAEL MINAI-IAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION - LAW
HEATHER EARLY, NO.: 99-6640 Civil Term
Defendant CUSTODY/VISITATION
PETITION TO MODIFY CUSTODY ORDER
NOW COMES the Plaintiff, MICHAEL MINAHAN, by and through his
attorney, Charles E. Petrie, and respectfully represents as follows:
1. That Plaintiff is MICHAEL MINAHAN, who currently resides at 1059
Nanroc Drive, Mechanicsburg, Countv of Cumberland, Pennsylvania.
2. That Defendant is HEATHER EARLY, who currently resides at 3312
Paxton Street, Apartment C-5, Harrisburg, County of Dauphin, Pennsylvania.
3. That the parties are the natural parents of a minor child, IiATLYN
ROSE MINAHAN, born September 26, 1997.
4. That on April 7, 2000, the Honorable Edward E. Guido entered an
Order of Custody granting primary physical custody to Plaintiff and granting
rights of temporary physical custody to Defendant. A copy of said Order is
attached hereto.
5. That the parties have reached an agreement concerning custody and
visitation with respect to the said minor child and desire that this court's Order
of April 7, 2000, be amended in accordance with the attached Stipulation.
WHEREFORE, Plaintiff requests that Your Honorable Court amend the
Court's Order of April 7. 2000, in accordance with the attached Stipulation.
Respecdully submitted,
CHARLES E. PETRIE
352S Brisban Street
Harrisburg, Pennsylvania 17111
(717) 561-1939
Attorney for Plaintiff
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
Upon information and belief, f verify that the statements in the foregoing
Petition are true and correct. I understand that false statements herein are
made subject to the penalties of IS Pa.C.S. Section 4904, relating to unsworn
falsification to authorities.
DATE CHARLES E. PETRIE
ATTORNEY FOR PLAINTIFF
IN THE COURT OF COiNIMON PL6:\S OF CU?I(3GRLAND COUNTY. PEINSYLVANIA
CIVIL ACTION - LA\V
MICHA171. iNIINAIIAtN.
Plaintiff
V.
HEATHER EARLY,
Defendant
: No. 99-6640 Civil Term
: IN CUSTODY
CUSmnY SrIPIrLATION
The Plain tiffand Defendant (hereina[terreferred to as "Parents") are the natural parents
of a two-year old daughter, Kath it Rose Minahan (hereinafter referred to as "Katlyn").
2. The Parents stipulate that they, both shall equally share legal custody of Katlyn and shall
consult and inform one another concerning the major decisions and developments in the child's life
including, but not limited to, decisions on religious upbringing, education, medical treatment,
discipline, and future changes of address.
3. The Parents agree that Ndichael Nfinahan ("Father') shall have primary physical custody
ofKatlyn; and that Heather Carly(" Nlo(her") shall have partial physical custody ofKatlyn from noon
on Saturday until the following Tuesday at 5:00 p.m. \dother shall provide transportation for the
transfers of custody unless otherwise agreed upon by the Parents.
4. The Parents agree to share major holidays.
5. Katlyn shall spend her birthdays equally with her Father and her Mother as agreed upon
by the Parents.
6. Mother's periods of partial physical custody shall remain from noon on Saturday until
V ..,A
6. Neither parent shall do anything to estrange hatlyn from the
other parent, and both shall encourage the child's relationship with the
other parent. Provisions of this paragraph shall apply equally to any
other adult who may now or hereafter co-habit with Father or Mother.
7. Neither parent shall use any controlled substances nor
consume alcohol to the point of intoxication while the child is in that
parent's custody.
3. This Stipulation may be expanded or modified by mutual
agreement of the parties.
IN WITNESS WHEREOF, the parties have hereunto set their hands
and seals the day and year first above written.
JA <1
WITNESS MICHAEL MINAHAN
6Lv`-t(? _
WITNESS
HEhTHER EARLY
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- .....r.nr.
CONTACTACRLE MEN'T
Folz
1CATLYN HOSE IEINAHAN
Phone Contact:
• There arc to not be more than 2 phone calls per week.
• Phone calls are to be made between (i pm and S pm Monday through f-riday. Calls can be
nude at any tine during the day on weekends, but not after S pm.
• Massages can he left for Katlyrt and will be played for her, provided there is clothing no_ ative.
or obscenities in flu: message. Ifyou need to discus specifics regarding visiU, or Oliver
contents, either leave a separate niussag:, or asl: t'nr a return call without leaving specifics for
die reason the call bael: is needed.
• Do not discuss future visits on the phone unless the visit has been confirnttd (see below).
• Do not mention your other children in the phnnc calls. Keep duo call specific to Kalyn,
unless she brings up one of the other children.
• Do nor contact usher members of our family rcgardie, Katlyn, visitation, or to Lind out wditte
we are if you cannot reach us.
Visits:
• There will be a special visit scheduled for Nuvcrnbef 9, 2003.
Visits will be scheduled for every other Sunday allefno011 startin_ with November 16, 2003,
for a minimurn of I hour per visit. These visit< will be supervised, but we will try to provide
you as little interference as possible. They will he scheduled for public places.
• Al the visits, do not bring up due next visit or when you will sec hay again.
• Do not mention Robert, Devon or other family members he is not familiar with.
• Transportation to and from the visits for f atlyn will be provided by us. You arc respuusible
for your own transportation to and from visits.
• Visits are to be confined tilt Friday before the visit. You will need to call and cunfirm the
tirnt, place and your ability to keep the visit. After the visit is confirmed, you may discuss it
with Katlyri.
• You are not to discuss future plans for visitation and/tar custody with Kallyn.
This agreement will apply until at ]cast January, al which time the situation will be reevaluated and chances
can be made. This will depend on the effect the visits have on Katlyw and you progress in the program.
if you arc asked to leave, or voluntarily leave the current program without completing the program, all
visits will httnicdiately cease. Phone contact will only continue if you arc respecnid.
By signing below you are ageeing to Ill- nuts of this sereeuicnt for visitation and contact with Kallyn
Rose Minnhan.
HcathtrEarly Date Wimess I
\5'imess 2
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pale
hate
TOO •d Wc29O:ZO r0J9T/TO rear=r=e93T a?aea•t?rua
VERIFICATION
The above-named Plaintiff, Heather Early, verifies that the statements made in the above
Petition for Contempt and Modification are true and correct. Plaintiff understands that false
statements herein are made subject to the penalties of IS Pa. C.S. §4904, relating to unswom
falsification to authorities.
Date: , t
MICHAEL iIMINAIIAN, IN THE COURT OF CO,MIMON PLEAS
Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA
VS. : NO. 99-6640 CIVIL TERM
HEATHER EARLY,
Defendant/Petitioner CUSTODY
CERTIFICATE 017 SERVICE
1, Jessica Diamondstone, Esquire, of MidPenn Legal Services, attorney for the
Petitioner, Heather Farly, hereby certify that 1 have served a copy of the foregoing
Petition for Special Relief on the following date and in the manner indicated below:
U.S. First Class Mail. Postace Pre-Paid
Charles E. Petrie. Esquire
3525 Brisban Street
Harrisburg, PA 171 11
Date: 111 CL
MidPenn Legal Services, Inc.
j
Jessica Diamondstone, Esquire
MidPenn Legal Services
S Irvine Row
Carlisle. PA 17013
MAY 0 4 2004
MICHAEL MINAHAN, IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V.
HEATHER EARLY,
Defendant
NO. 99-6640 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
GUIDO, J. ---
INTERIM ORDER OF COURT
AND NOW, this s day of May, 2004, upon consideration of the Custody
Conciliation Summary Report, it is hereby ordered and directed as follows:
1. The parties, Michael Minahan and Heather Early, shall have shared legal
custody of the minor child, Katlyn Rose Minahan, born September 26, 1997.
2. Physical Custody. Father shall have primary physical custody subject to
Mother's rights of supervised visitation. It is expected that the supervised visitation will
increase in frequency. By May 7, 2004, Father will contact the Harrisburg YWCA visitation
program to arrange the first two hour Saturday visitation which shall occur by May 27, 2004.
These visits will continue on a monthly basis and shall be subject to increased frequency
upon recommendation of the child's therapist.
3. Transportation. Father shall provide all transportation for these periods of
supervised visitation.
4. Each parent shall keep the other informed of their telephone numbers and
places of residence and employment.
5. Neither party shall do or say anything which may estrange the child from the
other parent, injure the opinion of the child as to the other parent, or hamper the free and
natural development of the child's love and respect for the other parent. Each parent shall
ensure that third parties also comply with this provision during his or her periods of custody.
6. Neither parent shall use or consume alcohol or controlled substances during
any period of custody.
7. Mother shall remain abstinent from the use of alcohol and shall attend AA or
NA meetings not less than two times per week. Mother is advised that the provisions of this
Order which require her sobriety shall be strictly construed.
NO. 99-6640 CIVIL TERM
8. Counsel for the parties shall work cooperatively to identify a participating
provider with Father's health insurance to arrange for the child to participate in therapeutic
counseling with Mother to address the child's emotional reaction to Mother's absences and
behaviors related to her chemical dependency. The parents will participate with the
counseling as deemed clinically necessary by the therapist. As a function of the counseling,
it is anticipated that the child's developmental and emotional needs will be addressed and
that the counselor will guide the family in selecting the appropriate arrangements for the
child to resume a normalized relationship with the Mother and make recommendations with
regard to when the child will be benefited by unsupervised periods of partial custody,
recommendations as to the frequency of contact between the Mother and child, as well as
any other recommendations which the therapist may have regarding the child's emotional
well-being.
9. By mutual agreement of the parties, the Custody Conciliation Conference
shall reconvene on July 22, 2004, at 8:30 a.m. at the office of the Custody Conciliator,
Melissa Peel Greevy, Esquire, 301 Market Street, Lem,_qyne.PA 17043.
BY
Dist:
/ Edward E. Guido, J.
?Gharles Patric, Esquire, 3528 Brisban Street, Harrisburg, PA 17111
„Gessica Diamondslone, Esquire, 8 Irvine Row, Carlisle, PA 17013
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II
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MICHAEL MINAHAN,
Plaintiff
V.
HEATHER EARLY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6640 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 BIRTH CURRENTLY IN THE CUSTODY OF
Katlyn Rose Minahan September 26, 1997 Father
2. A Custody Conciliation Conference was held on April 29, 2004 following
Mother's filing of a Petition for Contempt and Modification on March 12, 2004. Attending the
Custody Conciliation Conference were: the Father, Michael Minahan, and his counsel,
Charles E. Petrie, Esquire; the Mother, Heather Early, and her counsel, Jessica
Diamondstone, Esquire.
3. The parties reached some agreements with regard to the resumption of
contact between the child and Mother. However, they did not reach agreements regarding
telephone contact and the frequency of the supervised visits with Mother.
4. Mother's position on custody is as follows: Mother reports that Father
unilaterally discontinued contact between Mother and the child on December 25, 2003.
Mother has apparently had significant problems with chemical dependency. She reports
that she is presently working step three of a twelve step program, attending AA and NA
twice per week and is maintaining her sobriety. Mother recognizes the impact of her
conduct on the relationship with the child to some extent and therefore is willing to
participate in supervised visits at the Harrisburg YWCA. She requests the frequency be on
alternating Saturdays, initially for two hours. She hopes that she will be able to work toward
a more normalized schedule of custody which will be unsupervised and to have an
opportunity to reestablish her relationship with the child and demonstrate her commitment to
providing a safe and nurturing environment for her. Mother reports that Father has
•t .
NO. 99-6640 CIVIL TERM
discontinued telephone contact with the child. She requests that she be able to have
reasonable telephone contact and have her calls returned within twenty-four hours if she
does not connect with the child when she calls.
5. Father's position on custody is as follows: Father reports that Mother's
inconsistent presence in the child's life has caused the child significant emotional harm in
that she is very upset after she speaks with her mother on the telephone. Accordingly, he
seeks to limit her contact with Mother to one two-hour block per month and to have a
professional counselor assist them in evaluating when it is appropriate to increase the
frequency of the contact between the child and the Mother. Additionally, he does not wish
to have any telephone contact between the child and her Mother until after the parties have
begun counseling.
6. The Order attached reflects the Conciliator's recommended Interim Order.
The areas upon which they do not agree are the frequency of Mother's supervised contacts
at this stage and when reasonable telephone contact will resume. For that purpose,
counsel will need a telephone conference or brief hearinc fore Judge Guido.
ate
Melissa Peel Greev
Custody Conciliator
:228163
JUG! 1 4 2004 f
MICHAEL MINAHAN, IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 99-6640 CIVIL TERM
V.
HEATHER EARLY,
CIVIL ACTION - LAW
Defendant
IN CUSTODY
ORDER TO RELINQUISH JURISDICTION
AND NOW, this day of June, 2004, counsel for the Defendant notifying the
Conciliator and opposing counsel that Defendant has relinquished all parental rights to the
subject minor child, the Custody Conciliation Conference scheduled for July 22, 2004 is
CANCELED and the Conciliator hereby relinquishes jurisdiction of the above captioned
matter.
FOR THE COU
BY: ?S
elissa Peel Greevy, Esquire
Custody Conciliator
Dist: Charles Petrie, Esquire, 3528 Brisban Street, Harrisburg, PA 17111 _ ._ _ _• n,??t (o -/S.V q
Jessica Diamondstone, Esquire, 8 Irvine Row, Carlisle, PA 17013 '`-Or"'`'??
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