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Home My WebLink About99-06744RICHARD C. PATIIIC, JR., Plaintiff VS. IN'1'III: COURTOP COMMON PLLAS Of CUMBERLAND COUNTY. PENNSYLVANIA ACTION - LAW CUSTODY/ VISITATION BETHANY ESVER, De6endant NO. Cil - ?: ;?L/L, Cuxt ORDER AND NOW. this day of A. D. 1999, upon motion of Paul S. Zimmerman, of the firm May and \,Ictz,,er, LLP. attorney for Richard C. Pathic, Jr., plaintiff, the Court having rc\,icwcd the agreement of the parties and having concluded said nucenient is in the best interest of the children. Jacqueline K. Pathic and Christian T. Pathic, the foregoing agrecntcnt is made an order of the Court as though there had been a hearing. The order shall remain in effect until further notice or until further proceedings are held. BV TI1E COURT ATTEST: RICHARD C. PATHIC',.IR., IN H H: COURT OF CMIMON PLEAS 1'Inintil'f OF CUMBERLAND C'OUN'TY, VS. PENNSYLVANIA CIVIL ACTION - LAW CUSTODY/ VISITATION B I'HANY ESPER, Defendant NO. ORDER OF COURT AND NOW. 1 I 1 1999, upon cosideretion olthe attached complaint, it is hereby directed that the parties and their respective counsel appear bcliire ???\,i 'f?l i 1 t i(1 t?thc concilator,atl r r• t t1 (%\ oil the 1-M-%clayof `o. ?2000 at ' M.,I'oraPre- Ilea ring Custody Conference. At such conference, an eftort will be made to resolve the issues in dispute: or if this cannot be accomplished, to define and narrow IItC 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 I'or entry ol'a temporary or permanent order. 1:0 It TI IE C'OUItT. Custody C'onC.ilialar •The Court of Common fleas ol'Cumbcdand County is required by law to comply with the American with Disabilities Act of 1990. For hil'onnation about acessible Iacilitics and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All anangments most be made at least 72 hours prior to any hearing or business before the court. )'oil must attend the scheduled conlcrcncc or hearing. YOU SFIOULD TAKE Th11S PAPER,rO POUR LAWYER AT ONCE. IF YOU DO NO'I I IAVE A LAWYER OR CANNOT AFFORD ONE, GO -1-0 OR TIiLEPI IONS I'l IF OFFICE SET FOWI-I I BELOW TO FIND OUT Wl IERE YOU CAN GET LEGAL I IELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Libcrty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 ? ?? ? ?? ('=[rip>.-.'l?? ?Yi t?? ?.Cr, ?.?r..l?c??c?zn il? ?y? ?;' ??, ? , //•?S? Vii' (k ,?. ?,, /!i %==_??., ?-%? RICIIARD C. PATI{IC, .IR., IN TI Ili COURT OI: COMMON PLEAS Plaintiff' 01: CLI IBERLAND COUNTY, VS. PENNSYLVANIA CIVIL ACTION -- LAW CUSTODY/ VISITA'T'ION BETHANY ESPER, Defendant NO. COMPLAINT FOR CUSTODY 1. The PlaintilT is Richard C. Pathic, .h•., residing at 155 Salon Church, I.ot "62, Mechmnicsburg, in the County ol'Cumberland. Pennsylvania, 17055. 2. '['lie Defendant is I3cthany Esper, residing al 155 Salem Church, Lot,162, Mechanicsburg, in the County of Cumberland, Pennsylvania, 17055. 3. The Plaintiff seeks custody of the following children: Jacquclinc K. Pathic; 155 Salem Church, Lot ;462; 11 months (D.O.B.: 11/4/99) Christian T. Pathic; 155 Salem Church, Lot 4462; 1 month; (D.O.B.: 9/15/99) The children were born out ol'\\•edlock. The children are in the custody of Richard C. Pathic, Jr., their father, who resides at 155 Salem Church, Lot „62, Mechanicsburg, Pennsylvania, 17055. During the past five years, the children have resided with the following persons and at the following addresses: Jacqueline K. Pathic: Diane It. and Jack N. Rowe, paternal grandmother and step-gr'andf'ather Richard C. Pathic and Bethany Esper S Sunset Court, Dillsburg, Pennsylvania, 17019 Novcntbcr4, 1998 through.lanuary3l, 1999 Richard C. Pathic and Bethany Esper 124 North Frederick Street, Mechanicsburg, Pennsylvania 17055 February I through September I, 1999 Richard C. Pathic and Bethany Esper 155 Salem Church, Lot 62, Mechanicsburg, Pennsylvania 17055 September I, 1999 to date Christian T. I'nthic: Rich:lyd C. Pathic and 9ethany Bsper 155 Snlenl Church. Lot N62. Mechculicsburg. Pennsylvania 17055 September 15. 1999 to date '1'hc mother of the Children is Bethany fsper, currently residing ill 155 Salem Church, Lot ,162. Mechanicsburg, PA 17055. She is single. The lather of the children is Richard C. Pathic. Jr.. currently residing at 155 Salem Church. Lot #62. Nlechanicsbur^. PA 17055, lie is single. 4. The relationship of Plaintiff Richard C. Pathic..h'. to the children is that of father. The PlaintilTcurrently resides with the following persons: Bethany f sper Jacqueline K. Pathic Christian T. Pathic companion daughter son 5. The relationship of Defendant Bethany Bsper to the children is tliat of \intltcr. The Delenclant currently resides with the following persons: Richard C. Pathic. Jr, Jacqueline K. Pathic / companion / daughter Christian I , . Pathic son 6. Plaintil"I'has not p;u-ticipated as a party or 1eiuless. or in another capacity. in other litiI-ation concerning the custody of"the children in this or another cotnt. Plaintiff has no illfol-111at1011 111 n C(ltilo(h' prUCee(ling ('OnWI'mng the children pending in it court of"this Commonwealth. PlaintilTdoes not know of a person not a party to the proceedings who has physical custody of the children or claims to have custo(ly or visiultion rights with respect to the children. 7. The best interest and permanent we llhre ol'the children will be served by granting the reliefl•equcstetl because the child will benefit from the stability that an Order granting custody of them to their Father will establish. S. Each parent whose parental ri,,,hts to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. All other persons. named below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency ol'this action and the right to intervene: NONE- Wl IEREFORE, it is requested that the Court grant custody of the children to Plaintiff. IJA.I - PAUL S. %1N4MER\4AN Attorney Por Plaintiff' Attorney I. D. # 78071 ?,phv Auu ?gcrrcrtt, t.t.r 49 North Duke Street Lancaster. PA 17602 (717) 299-1181 3 VERIFICATION 1 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. Sect. 4904 relating to unsworn falsification to authorities. JRIC C7-iftm - ,,tr Dated: '0 • ZI , 1999 RICHARD C. PATWC, JR., Plaintiff VS. BETHANY ESPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CUSTODY / VISITATION NO. CUSTODY AGREEMENT THIS AGREEMENT, made this -lie day of &A-%be ' , A. D. 1999, by and between Bethany Esper, hereinafter called "Mother", residing at 155 Salem Church, Lot 462, Mechanicsburg, Pennsylvania 17055, and Richard C. Pathic, Jr., hereinafter called "Father", residing at 155 Salem Church, Lot 462, Mechanicsburg, Pennsylvania 17055; WITNESSE:TH: WHEREAS, Mother and Father are the parents of unematicipated children, namely, Jacqueline K. Pathic and Christian T. Pathic; and WHEREAS, Father tiled a Complaint for Custody simultaneous with the presentation of this custody agreement; and WHEREAS, Mother suffers from and acknowledges mental health difficulties which have in the past prevented and may in the future prevent her from providing adequate care for the children; and WHEREAS, Father stands ready, willing and able to provide adequate care for the children; and NOW THEREFORE, it is agreed by the parties as follows: 1. Father shall have legal custody of both children and will thereby have sole discretion 1 in making major decisions affecting the best interests of said children, including but not limited to, medical, religious and educational decisions, and each parent shall have equal access to medical, dental and school records. 2. Father shall have primary physical custody of the children. 3. Mother shall have visitation as the parties may agree from time to time. 4. 'file parties hereby waive the requirement of Pa.R.CT 1915.7 requesting that they and their children be present before the Court to present this Agreement and fitrther intend this 4 creement to be entered as an Order of the Court of Common Pleas of Lancaster County, Pennsylvania, subject to modifications as provided by law. Father is represented by Paul S. Zimmerman of May and Metzger, LLP, and Mother has. specifically chosen not to be rewesented by counsel in these proeeedlnes. All parties understand the purpose of this Agreement and its legal effects and consequences. 6. 'Ibis Agreement shall supersede any and all other Agreements or Stipulations concerting custody and visitation of said minor children which have been made heretoibre. WITNESS our hands and seals the day and year first above written. WITNESSES: Riichard C. Pathic, Jr. Be ny F. ter COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF LANCASTER ) On this, the /'6A day of 1999, before me a Notary Public, personally i appeared Richard C. Pathic, Jr., known tome to be the person whose nante is subscribed to the within instrument, who being duly swum according to law, acknowledged that lie executed it for the purposes therein contained and desired that the same be recorded as such. IN WITNESS WHEREOF, I have hercui? G set nd official seal. NOTARIAL SEAL SUSAN D YODEF. Notuy p,:hOc L rampoon rwp C-mbeilaw County MV, C ommission n Expa", S(„t ,e X; ; ;pt - - ?- Notary Public My commission expires: COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF LANCASTER ) On this, the V64 day oKa ", 1999, before me a Notary Public, personally appeared Bethany Esper, known to me to be the person whose name is subscribed to the within instrument, who being duly swom according to law, acknowledged that she executed it for the purposes therein contained and desired that the sank be reenrded as such. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. NOTARIAL SEAL SUSAN D YODER. Notary Public Hampder, Twp . Cumberland County M Commission.?zonnc Swnr , t+ noon "\A)o aty Public My commission expires: i ?'f" V, ..:: .. ..., ,. RICHARD C. PATHIC, JR., Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CUSTODY/ VISITATION BETHANY ESPER, Defendant &t c.E ORDER AND NOW, this 2 Y r day of Nrv'?+W A. D. 1999, upon motion of Paul S. Zimmerman, of the firm May and Metzger, LLP, attomey for Richard C. Pathic, Jr., plaintiff, the Court having reviewed the agreement of the parties and having concluded said agreement is in the best interest of the children, Jacqueline K. Pathic and Christian T. Pathic, the foregoing agreement is made an order of the Court as though there had been a hearing. The order shall remain in effect until further notice or until further proceedings are held. ATTEST: ?.. _ --?__-rr..`?.n.eern:_m^-+:x-asp ..r.?1 --=-•..fr+8?® BY THE COURT ?? ?: E? ,, :? rt RICHARD C. PATHIC, JR., IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, VS. PENNSYLVANIA CIVIL ACTION - LAW BETHANY ESPER, CUSTODY/ VISITATION Defendant NO. COMPLAINT FOR CUSTODY 1. The Plaintiff is Richard C. Pathic, Jr., residing at 155 Salem Church, Lot #62, Mechanicsburg, in the County of Cumberland, Pennsylvania, 17055. 2. The Defendant is Bethany Esper, residing at 155 Salem Church, Lot R62, Mechanicsburg, in the County of Cumberland, Pennsylvania, 17055. 3. The Plaintiff seeks custody of the following children: Jacqueline K. Pathic; 155 Salem Church, Lot n62; 11 months (D.O.B.: 11/4/98) Christian T. Pathic; 155 Salem Church, Lot #62; 1 month; (D.O.B.: 9/15/99) The children were bom out of wedlock. The children are in the custody of Richard C. Pathic, Jr., their father, who resides at 155 Salem Church, Lot R62, Mechanicsburg, Pennsylvania, 17055. During the past five years, the children have resided with the following persons and at the following addresses: Jacqueline K. Pathic: Diane R. and Jack N. Rowe, paternal grandmother and step-grandfather Richard C Pathic and Bethany Esper 8 Sunset Court, Dillsburg, Pennsylvania, 17019 November 4, 1998 through January 31, 1999 Richard C. Pathic and Bethany Esper 124 North Frederick Street, Mechanicsburg, Pennsylvania 17055 February 1 through September 1, 1999 Richard C. Pathic and Bethany Esper 155 Salem Church, Lot R62, Mechanicsburg, Pennsylvania 17055 September 1, 1999 to date 91-1 Christian T. Pathic: Richard C. Pathic and Bethany Esper 155 Salem Church, Lot P62, Mechanicsburg, Pennsylvania 17055 September 15, 1999 to date The mother of the children is Bethany Esper, currently residing at 155 Salem Church, Lot #62, Mechanicsburg, PA 17055. She is single. The father of the children is Richard C. Pathic, Jr., currently residing at 155 Salem Church, Lot 962, Mechanicsburg, PA 17055. He is single. 4. The relationship of Plaintiff Richard C. Pathic, Jr. to the children is that of Father. The Plaintiff currently resides with the following persons: Bethany Esper / companion Jacqueline K. Pathic / daughter Christian T. Pathic / son 5. The relationship of Defendant Bethany Esper to the children is that of Mother. The Defendant currently resides with the following persons: Richard C. Pathic, Jr. / companion Jacqueline K. Pathic / daughter Christian T. Pathic / son 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children 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 children or claims to have custody or visitation rights with respect to the children. 1) 7. The best interest and permanent welfare ofthe children will be served by Lrantina the relief requested because the child will benefit from the stability that an Order granting custody of them to their Father will establish. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to intervene: NONE WHEREFORE, it is requested that the Court grant custody of the children to Plaintiff. ,AI . PAUL S. ZININTERNIAN Attorney for Plaintiff Attorney 1. D. # 78071 MAYAND;vgerrcER t.t.P 49 North Duke Street Lancaster. PA 17602 (717) 299-1 181 3 id 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. Sect. 4904 relating to unworn falsification to authorities. 7 Richard C. ttr,?r Pl1intift Dated: '0. W , 1999 ¦. RICHARD C. PATIUC, JR., IN THE COURT OF COMMON PLEAS Plaintiff OF CUNMERLAND COUNTY, VS. PENNSYLVANIA CIVIL ACTION- LAW BETHAATY ESPER, CUSTODY I VISITATION Defendant NO. CUSTODY AGREEMENT THIS AGREEMENT, made this day of de? , A,?D• 1999, by and between Bethany Esper, hereinafter called "Mother% residing at 155 Salem Church, Lot #62, Mechanicsburg, Pennsylvania residing at 155 Salem Church, Lot #62, Mechanicsburg, Pennsylvania 17055; WITNESSETH: WHEREAS, Mother and Father are the parents of unemattcipated children, namely, Jacqueline K. Pathic and Christian T. Pathic; and WHEREAS, bather tiled a Complaint for Custody simultaneous with the presentation of this custody agreement; and WHEREAS, Mother suffers from and acknowledges mental health difficulties which have in the past prevented and may in the future prevent her from providing adequate care for the children; and WHEREAS, Father stands ready, willing and able to provide adequate care For the children; and NOW THEREFORE, it is agreed by the parties as follows: 1. Father shall have legal custody of both children and will thereby have sole discretion 17055, and Richard C. Pathic, )r., hereinafter called "Father", in making major decisions affecting the best interests of said children, including but not limited to, medical, religious and educational decisions, and each parent shall have equal access to medical, dental and school records. 2. Father shall have primary physical custody of the children. 3. Mother shall have visitation as the parties may agree from time to bite. 4. The parties hereby waive the requirement of Pa.R.C.P 1915.7 requesting that they and their children be present before the Court to present this Agreement and fttrtitcr intend this Agreement to be entered as an Order of the Court of Common Pleas of Lancaster County, Pennsylvania, subject to modifications as provided by law. 5. Father is represented by Paul S. Zimmerman of May and ivletzger, LLP, and Mother has specifically chosen not to be rcnresented by counsel in three proceedines. All parties understand the purpose of this Agreement and its legal effects attd consequences. b. 'Ibis Agreement shall supersede any and all other Agreements or Stipulations concerning custody and visitation of said minor children which have been made heretofore. WITNESS our hinds and seals the day and year first above written. WITNESSES: Richard C. Pathic, Jr. Be ny E, r CONLMONW)?ALTH OF PENNSYLVANIA ) ) SS: COUNTY OF LANCASTER ) On this, the 1'0 day ofQc 9 1999, before me a Notary Public, personally appeared Richard C. Pathic, Jr., known to me to be the person whose name is subscribed to the within instrument, who being duly swum according to law, acknowledged that he executed it for the purposes therein contained and desired that the saute be recorded as such. 1N WITNESS WHL•REOF,1 have hereu nd official seal. NOTARIAL SEAL 7SLU)SAN D YDDEF Nota?? Gublic on Twp cumderiana County mission E,,pu_s s,,;- • e 27p, Notary Public My commission expires: COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF LANCASTER ) On this, the VA day e ?u 1999, before me a Notary Public, personally appeared Bethany Esper, known to me to be the person whose name is subscribed to the within instrument, who being duly swom according to law, acknowledged that she executed it for the purposes therein contained and desired that the same be recorded as such. FNI WITNESS WHEREOF, I have hereunto set my hand and official seal. ., SUSAN D YODER._ Notary Public nampd6 Twp Cumberland Count I mY a.ommiss'pn,cmaa S-e ?" _Iv'otaty Public My commission expires: .g ; a 7 r C V It F RICHARD C. PA'I'L IIC.1R. PLAINTIFF V. BETI]ANY ESPER DEFENDANT IN TI I1: COURT01: C'ONI MON PLEAS OP . C'U\IBERLAND00UN"I"1', PENNSI'LVANIA 99-6744 CIVILACHO\ LAW IN C'US'fODI' ORDER OF COURT AND NOW, this 15th clay of Decemher , 2000, upon consideration of the attached Complaint. it is hereby directed that the parties and their respective counsel appear befnremelissa P. Greevy, Isy_, the conciliator, at 214 Senate Avenue, Suite 105. Camp IIill. PA 17011 on the 17th day of.lanuar• . 2001 at 3:00 p.nt. fora Pre•Ilearing Custody Conference. At such conference, an eftbrt will be made to resolve the issues in dispute; or if this cannot be accomplished, to dcline and nmTOw the issues to he 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 envy of a temporary or permanent order. FOR T HE COURT. By: /s/ hf?li?s L'._G_resv3, Est=? Custody Conciliator The Court of Common Pleas 0f Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For inl'ornmtion 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. 1'ou must attend the scheduled conlcrence or hearing. YOU SHOULD "TAKE "PHIS PAPER TO YOUR r\'ITORNEI' AT ONCE. IF YOU DO NOT I IAVL• AN A"ITORNEY OR CANNOT" AFFORD ONE. GO TO Olt TT LEPHONE "fI IE OFFICE SET FORTH BELOW TO FIND OUT WI IERE YOU CAN GF, f LL•GA1. I IELP. Cumberland County Bar Association 2 Libertv Avenue Carlisle. Pennsylvania 17013 Telephone (717) 249-3166 is i9 cG? c? <<;?? . f l 674') , t z", e I?? I c r?) r` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RICHARD C. PATHIC, JR., Plaintiff/Respondent: V. NO. 99-6744 Civil Term BETHANY ESPER, Defendant/Petitioner: IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before the Conciliator, at on the day of 2000, 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. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent Order. BY THE COURT: Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (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 the office set forth above. 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. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW RICHARD C. PATHIC, JR., Plaintiff/Respondent: V. NO. 99-6744 BETHANY ESPER, - Defendant/Petitioner: IN CUSTODY PENNSYLVANIA Civil Term PETITION FOR MODIFICATION OF CUSTODY ORDER AND NOW comes BETHANY ESPER by and through her attorney, Maryann Murphy, Esquire, and avers as follows: 1. Defendant/ Petitioner is BETHANY ESPER who resides at 1550 Williams Grove Road, Lot #136, Mechanicsburg, Cumberland County, Pennsylvania. 2. Plaintiff /Respondent is RICHARD C. PATHIC, JR. who resides at 13255 80`h Avenue, Mecosta, Michigan. 3. Petitioner and Respondent are the biological parents of two (2) minor children, namely: JACQUELINE K. PATHIC, born November 4, 1998; and CHRISTIAN T. PATHIC, born September 15, 1999. 5. A prior order dated November 24, 1999 granted Respondent primary physical and legal custody of the minor children with visitation in Petitioner as agreed by the parties. (a copy of said order is attached hereto, incorporated by reference herein, and marked as Exhibit "A")• 6. Respondent was suffering from post-partum depression at the time she agreed to the above order. She has since received therapy and is no longer suffering from depression. 7. The parties resided together, off and on, since the time of the November 24, 1999 order until November 12, 2000 when Respondent left the family and went to Michigan. g, while the parties were residing together, Petitioner had primary responsibility for the care of the minor children. Petitioner has had sole responsibility for the care of the children since Respondent left the residence and state. 9. Respondent is threatening to return to Pennsylvania and take the minor children to Michigan with him, which would prevent Petitioner from having contact with the minor children. 10. Petitioner believes that she is better able to care for the minor children than is Respondent. 11. Petitioner believes that the best interests and permanent welfare of the minor children will be served if she is granted primary physical custody of them, with partial custody in Respondent. WHEREFORE, Defendant/Petitioner requests this Honorable Court to modify the existing Custody Order and grant her primary physical custody of JACQUELINE and CHRISTIAN. Respectfully submitted, i Ma-ryanry Murphy, Esq i'e LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for Defendant/ Petitioner VERIFICATION I, BETHANY ESPER, verify that the statements made in the foregoing document 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. BETHANY ESP R V RICHARD C. PATHIC, JR., VS, Plaintiff . BETHANY ESPER, Defendant IN THE COURT OF COMMON PLEAS Or CUMBERLAND COUNVT% PENA1SYLVANI . CIVIL ACTION - LAW CUSTODY / VISITA'T'ION NO. ORDER AND NOW, this _. j?;tC day of 21 kt'f'"`-? " A. D. 1999, _pon motion of Paul S. Zimmerman, of the firm May and Metzger, LLP, attorney for Richard C. Pathic, Jr., plaintiff, the Court having reviewed the agreement of the parties and having concluded said agreement is in the best interest of the children, Jacqueline K Pathic and Christian T. Pathic, the foregoing agreement is made an order of the Court as though there had been a hearing. The order shall remain in effect until further notice or until further proceedings are held. BY THE COURT ATTEST: J. i? 1` I L I I t,,? RICHARD C. PATHIC, R, VS Plaintiff . BETHANY ESPEP, Defendant IN TI;E COURT OF CONV1 EON, PLEAS OF CUNWERLAND COL' ;Y, CrM C OANI-LAW CUSTODY/ VISITATION NO. CUSTCD AGREE'bIENT THIS AGREEMENT, made this day of e;,? -- Bethany Esper, hereinafter caked "Mother" ?J A. D. 1999, by and between residing at 155 Salem Church, Lot 962 Mechanicsburg, Pennsylvania 17055, and Richard C. Pathic, Jr., hereinafter called "Father", residing at 155 Salem Church, Lot 962, Mechanicsburg, Pennsylvania 17055; WTINESSETH: WHEREAS, Mother and Father are the parents of unemancipated children, namely, Jacqueline K. Pathic and Christian T. Pathic; and WFIEREAS, Father filed a Complaint for Custody simultaneous with the presentation of this custody agreement; and WHEREAS, Mother suffers from and acknowledges mental health difficulties which have in the past prevented and may in the future prevent her from providing adequate care for the children; and WHEREAS, Father stands ready, willing and able to provide adequate care for the children; and NOW THEREFORE it is agreed by the parties as follows: 1. Father shall have legal custody of both children and will thereby have sole discretion in making major decisions affecting the best interests of said children, including but not limited to, medical, religious and educational decisions, and each parent shall have equal access to medical, duntal and school records. 2. Father shall have primary physical custody of the children. 3. Mother shall have visitation as the parties may agree from time to time. 4. The parties hereby waive the requirement ofPa.R.C:.I' 1915.7 requesting that they and their children be present before the Court to present this Agreement and further intend this Agreement to be entered as an Order of the Court of Common Pleas of Lancaster County, Pennsylvania, subject to modifications as provided by law. 5. Father is represented by Paul S. Zimmerman of May and Metzger, LLP, and Mother - " occculn S. All parties understand the purpose of this Agreement and its legal effects and consequences. 6. This Agreement shall supersede any and all other Agreements or Stipulations conceming custody and visitation of said mirror children which have been made heretoibre. WITNFSS our hands and seals the day and year first above H,ritten. WITNESSES: Aiclar4dC- Pathic, Jr. ' B n5'F r COMMONWEALTH OF PENNSYLVANIA ; SS: COUNTY OF LANCASTER On this, the 110 day of r o 1999, before me a Notary Public, personally appeared Richard C. Pathic, Jr., known to me to be the person whose name is subscribed to the within instrument, who being duly Sworn according to law, acknowledged that he executed it for the purposes therein contained and desired that the same be recorded as such. iN WITNESS WHEREOF, I have here-M-'^ -'M" ; i o d official =eat. NOTARIAL SEAL SUSAN D YODEF Nota,y Fi•ylu: Mwpcen Twp . Coind66F na County M Commission Excuse S6: +e 2000 Notary Public My commission expires: COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF LANCASTER 1999, before me a Notary Public, personally On this, the 1A day o appeared Bethany' E$per, known to me to be. the person whose name is subscribed to the within instrument, who being duly sworn according to law, acknowledged that she cxc.:uted it for the purposes therein contained and desired that the same be recorded as such. c seal' IN WITNESS WHEREOF, I have hereunto set my hand and official SUSAN O YODE9_ Notary Public nampadii fwp , Cumberland Count totary Public My commission expires: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RICHARD C. PATHIC, JR., Plaintiff /Respondent: V. NO. 99-6744 Civil Term BETHANY ESPER, Defendant/Petitioner: IN CUSTODY CERTIFICATE OF SERVICE I, Maryann Murphy, Esquire, do hereby certify that on the day of 2000, I served a true and correct copy of the foregoing Petition for Modification of Custody order on the Plaintiff/Respondent, RICHARD C. PATHIC, JR., at the address set forth below, by placing a copy of the same in the United States mail, first class, certified/restricted delivery and certificate of mailing, postage prepaid: Richard C. Pathic, Jr. 13255 80th Avenue Mecosta, Michigan 49332 Respectfully submitted, Maryann qurphy, Esq irv LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for Defendant/Petitioner ?_ Q ? • r ?: i; u_ -? 'vl . J C.? ? ?': r': j `-' ?'? •J r- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RICHARD C. PATHIC, JR., Plaintiff/Respondent: V. NO. 99-6744 Civil Term BETHANY ESPER, Defendant/Petitioner: IN CUSTODY ORDER OF COURT AND NOW, this i8, day of , 2000, upon consideration of the within Petition for Special Relief, IT IS HEREBY ORDERED AND DECREED that the minor children shall not be removed from the Commonwealth of Pennsylvania pending the Custody Conciliation Conference and further Order of Court. The parents shall exchange current addresses and phone numbers, and shall permit reasonable contact with the children and the other parent pending the Conciliation. BY THE COURT: le Kevin A. Hess a V, Np_ A ?.f R C rn c - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RICHARD C. PATHIC, JR., Plaintiff /Respondent: V. BETHANY ESPER, Defendant/Petitioner: N0. 99-6744 Civil Term IN CUSTODY PETITION FOR SPECIAL RELIEF AND NOW comes BETHANY ESPER by and through her attorney, Maryann Murphy, Esquire, and avers as follows: 1. Defendant/Petitioner is BETHANY ESPER who resides at 1550 Williams Grove Road, Lot #136, Mechanicsburg, Cumberland County, Pennsylvania. 2. Plaintiff /Respondent is RICHARD C. PATHIC, JR. who resides at 13255 80c4 Avenue, Mecosta, Michigan. 3. Petitioner and Respondent are the biological parents of two (2) minor children, namely: JACQUELINE K. PATHIC, born November 4, 1998; and CHRISTIAN T. PATHIC, born September 15, 1999. 5. A prior Order dated November 24, 1999 granted Respondent primary physical and legal custody of the minor children with visitation in Petitioner as agreed by the parties. (a copy of said Order is attached hereto, incorporated by reference herein, and marked as Exhibit "All) . fflip Ai 6. Respondent was suffering from post-partum depression at the time she agreed to the above Order. She has since received therapy and is no longer suffering from depression. 7. The parties resided together, off and on, since the time of the November 24, 1999 Order until November 12, 2000 when Respondent left the family and went to Michigan. 8. While the parties were residing together, Petitioner had primary responsibility for the care of the minor children. Petitioner has had sole responsibility for the care of the children since Respondent left the residence and state. 9. Respondent is threatening to return to Pennsylvania and take the minor children to Michigan with him, which would prevent Petitioner from having contact with the minor children and would be detrimental to the well-being and stability of the children. 10. Simultaneously with the filing of this Petition, Petitioner has filed a Petition for Modification of Custody Order requesting primary physical custody of the minor children. 11. Respondent's mother, Diane Rowe, and stepfather, Jack Rowe, have been assisting Petitioner since Respondent left the family. They have been very supportive of Petitioner as is evidenced by the letter written to Petitioner's counsel. (a copy of said letter is attached hereto, incorporated by reference herein, and marked as Exhibit "B"). 12. Petitioner is fearful that Respondent will follow through with his threats to remove the children from the Commonwealth, and she respectfully requests that he be prohibited from doing so pending a Custody Conciliation Conference and further Order of Court. WHEREFORE, Defendant/Petitioner requests this Honorable Court to prohibit the removal of the minor children, JAQUELINE and CHRISTIAN, from the Commonwealth of Pennsylvania, and granting both parties reasonable contact with the minor children in Pennsylvania, pending a Custody Conciliation Conference and further order of Court. Respectfully submitted, /CIO' Maryann) Murphy, 6 qui e LEGAL SERVICES, INC. (( 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for Defendant/ Petitioner VERIFICATION I, BETHANY ESPER, verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unswo= falsification to authorities. BETHANY?ESP R i C RICHARD C. PATHIC, JR., Plaintiff VS. BETHANY ESPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CUSTODY / VISITATION NO. q q- b7N11 ORDER AND NOW, this ?'+;U day of_ 21 A. D. 1999, :Pon motion of Paul S. Zimmerman, of the firm May and Metzger, LLP, attorney for Richard C. Pathic, Jr., plaintiff, the Court having reviewed the agreement of the parties and having concluded said agreement is in the best interest of the children, Jacqueline K. Pathic and Christian T. Pathic, the foregoing agreement is made an order of the Court as though there had been a hearing. The order shall remain in effect until further notice or until further proceedings are held. BY THE COURT Ls1_ a ?. s Cl ? AY J. ATTEST: -44 V V ? ?. r / Q l J?,_y s:r,Ctpfr.n: RICHARD C. PATHIC, a, vs. Plaintiff . BETHANY ESPER, Defendant IN TEE COURT OF COMMON PLEAS OF CUkBERLAND COUAiY, PENNSYLVANIA CIVIL ACTION-LAW CUSTODY / VISITATION NO. CUSTODY AGREEMENT THIS AGREEMENT, made this I day of c,?bet , A. D. 1999, by and between Bethany Esper, hereinafter called "Mother", residing at 155 Salem Church, Lot R62, Mechanicsburg, Pennsylvania 17055, and Richard C. Pathic, )r., hereinafter called "Father", residing at 155 Salem Church, Lot 462, Mechanicsburg, Pennsylvania 17055; WITNESSETH: WHEREAS, Mother and Father are the parents of unemancipated children, namely, Jacqueline K. Pathic and Christian T. Pathic; and WHEREAS, rather tiled a Complaint for Custody simultaneous with the presentation of this custody agreement; and WHEREAS, Mother suffers from and acknowledges mental health difficulties which have in the past prevented and may in the future prevent her from providing adequate care for the children; and WHEREAS, Father stands ready, willing and able to provide adequate care for the children; and NOW THEREFORE, it is agreed by the parties as follows: 1. Father shall have legal custody of both children and will thereby have sole discretion in making major decisions affecting the best interests of said children, including but not limited to, medical, religious and educational decisions, and each parent shall have equal access to medical, dental and school records. 2. Father shall have primary physical custody of the children. 3. Mother shall have visitation as the parties may agree from time to time. 4. The parties hereby waive the requirement of Pa.R.C:.l' 1915.7 requesting that they and their children be present before the Court to present this Agreement and further intend this Agreement to be entered as an Order of the Cows of Common Pleas of Lancaster County, Pennsylvania, subject to modifications as provided by law. 5. Father is represented by Paul S. Zimmerman of May and Metzger, LLP, and Mother has specifically chosen not to be represented by counsel in these proceedings. All parties understand the purpose of this Agreement and its legal effects and consequences. 6. 'I'bis Agreement shall supersede any and all other Agreements or Stipulations eonceming custody and visitation of said minor children which have been made heretofore. WITNESS our hands and seals the day and year first above erittcn. WITNESSES: CRichar4dC. qPac!;Jr. /y Fsl er ?• . COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF LANCASTER ) On this, the IVA day of o 1999, before me a Notaz)'Public, personally appeared Richard C. Pathic, Jr., known to me to be the person whose name is subscribed to the within instrument, who being duly swum according to laws, acknowledged that he executed it for the purposes therein contained and desired that the same be recorded as such. iN WITNESS WHE_2J_OF, I have hercu ._ ^^ ^ nand end ofliicia! Neal. NOTARIAL SEAL r SUSAN D YODEP Nota? Public nampcon rwp C?mt5erlano County M Commission Ezcuas sec, ,e 2006 . Notary Public My commission expires: COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF LANCASTER ) On this, the va " day o LVL 1999, before me a Notary Public, personally appeared Bethany Esper, known to me to be the person whose name is subscribed to the within instrument, who being duly swom according to law, acknowledged that she executed it for the purposes therein contained and desired that the same be recorded as such. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. NOTARIAL SEAL -....SUSAN D YODER Notary Public rlampaeE fwp , Cumberland County My Comm,ss,on,F o,a?';, , P vnnn A r_?Ilotaty Public My commission expires: Jack & Diane Rowe 8 Sunset Ct Dillsburg, PA 17019 Home Phone 717-432.5975 December 04, 2000 Maryanne Murphy Esq. Legal Aide Attorney Services Carlisle, PA RE: Bethany Esper Vs Richard Pathic Jr Dear Ms Murphy; The mason for this letter is to let you know that my husband and I, have no custody case underway for our grandchildren, Jacqueline & Christian Pathic. My son, Richard Pathic left the family on Sunday November 12. He was to have returned that following Sunday. A round trip ticket was purchased providing for his return. To date, he has made no attempt to return, nor has he in anyway provided financially or emotionally for his children or Beth. He IeR them with no place to live, (they had been evicted from their trailer park), and with no money. My husband and i had the mobile home moved and set up in a new park, so they would have a place to live. We have provided Beth with a car to allow her to work a part time job to try and support them. Please call us if we can be of any assistance. Respectfully Yours, J A'?DianvRc4wc b 1. ?t1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RICHARD C. PATHIC, JR., Plaintiff/Respondent: V. NO. 99-6744 Civil Term BETHANY ESPER, Defendant/Petitioner: IN CUSTODY CERTIFICATE OF SERVICE I, Maryann Murphy, Esquire, do hereby certify that on the day of , 2000, I served a true and correct copy of the foregoing Petition for Modification of Custody order on the Pl aintiff/Respondent, RICHARD C. PATRIC, JR., at the address set forth below, by placing a copy of the same in the United States Mail, first class, certified/restricted delivery and certificate of mailing, postage prepaid: Richard C. Pathic, Jr. 13255 80th Avenue Mecosta, Michigan 49332 Respectfully submitted, II Cl Maryan Murphy, Esquire LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 •w G =i :? S RICHARD C. PA'fl-IIC,.IR Plainti tT/Petitioner vs. BETHANY ESPER Defendant/Respondent VS. DIANE R. ROWE and JACK N. ROWE Additional Defendants IN 'f111: COURTOP COMMON PLEAS 01: CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6744 CIVIL TERM CUS'T'ODY / VISITATION : CIVIL. ACTION - LAW STIPULATION AND AGREEMENT FOR CUSTODY AND PARTIAL CUSTODY COMES NOW. JACK AND DIANE ROWE. by an through their counsel, James J. Kayer, Esquire and RICHARD C. PATI-11C. M., by and through his counsel, Paul S. Zimmerman, Esquire, do Stipulate and Agree upon the following: WITNESSETFI: WHEREAS. RICHARD C. PA"fl-TIC, JR., and BETHANY ESPER, are the parents of two children, namely Jacqueline K. Pathic and Christian'r. Pathic; and WI-IEREAS, a mother and father have executed a custody agreement than has been made an Order of the Court of Common Pleas of Cumberland County, which confirms that the father was to have full legal custody of both children and primary physical custody of both children; and WHEREAS, Bethany Esper suffers from and acknowledges mental health difficulties which have in the past prevented and may in the future prevent her from providing adequate care for the children; and whereas, the paternal grandparents, JACK and DIANE ROWS. stand ready, willing and able to provide adequate care for the children. NOW THEREFORE, it is agreed by the parties as follows: Father and Paternal Grandparents shall share legal custody of both children and will therefore share in staking the major decisions affecting the best interests of the children. including bill not limited to, medical. religious and educational decisions. and Father and Paternal Grandparents shall have equal access to medical. dental and school records. Father and Paternal Grandparents shall have access to all individuals involved in the children's educational and religious and physical well being. 2. The Paternal Grandparents shall have primary physical custody of the children. 3. Father shall have rights of partial physical custody as the parties may agree from time to time. 4. Mother shall continue to enjoy visitation as the parties may agree from tine to time. 5. The Panics hereby waive the requirement of Pa. R. C. P. 1915.7 requiring that they and the children be present before the Court to present this agreement and they further intend this agreement be entered as an Order of Court of the Common Pleas of Cumberland County, Pennsylvania, subject to modifications as provided by the law. 6. Paternal Grandparents are represented by James J. Kaycr, Esquire. 'file Father is representing himself pro se and has been advised of his right to seek independent counsel. 'file Mother has removed herself front the Commonwealth of Pennsylvania and is unavailable to execute this Stipulation. All parties understand the purpose of this agreement and its legal effects and consequences. 7. Tbis agreement shall supercede any and all other Agreements or Stipulation concerning custody and visitation of said minor children which have been made heretofore. 8. "file parties in reaching this agreement recognize that the Paternal Grandparents have sufficient standing to be included as parties in this custody action and have agreed to amend the caption of this action to include the Paternal Grandparents as additional defendants. ±nt'By: Kayer and Brown; 2430946; Jan-12-00 4:36PM; Pace 414 IN WITNESS WHEREOF, the Parties hereto and each of them have hereunto set their hands and seals intending to be legally bound hereby this day of January, 2000. A RICHARD C PATHIC. JR. ROWS JAC N. ROWE JAN-12-2000 16:45 2430946 P.04 I a 'o C > o o 3?ar , co C%f m m o,j n U > 'O LO O=? C N Q) a •x° C Ay-.o m •?., J .. Q "..cz, .+.' -Tj n i n ( ? r JAN G 4 [aup S' RICHARD C. PATIIIC, -lit Plainti ff/Petitio tier VS. BETHANY ESPER Defendant/Respondent %IS. DIANE R. ROWE and .TACK N. ROWS Additional Defendants IN "1'H I? COUR-r OP COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6744 CIVIL TERM CUSTODY / VISITATION CIVIL ACTION - LAW ORDER OF COURT AND NOW, this day of 2000, upon motion or James J. Kayer, Esquire, attorney for Diane R. Rowe and Jack N. Rowe, the Court having reviewed the agreement of the parties and having concluded set agreement is in the best interest of the children, Jacqueline K. Pathic and Christian T. Pathic, although foregoing agreement is mad an order of court as though there had been a hearing. The Order shall remain in effect until further notice or until further proceedings are held. By the Court, cc: James J. Kayer, Esquire Richard C. Pathic, Jr., pro se Bethany Esper, pro se SAN z `I 2UUU RICIIARD C. PATI IIC, JR P lain ti fl%Pcli t inner vs. BETHANY ESPER Detendant/Respondent VS. IN THE COURT OP COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6744 CIVIL"TERM CUSTODY / VISITATION DIANE R. ROWS and JACK N. ROWE Additional Defendants CIVIL ACTION - LAW ORDER OP COURT AND NOW, this day of , 2000, upon motion of James J. Kaycr, Esquire, attorney for Diane R. Rowe and Jack N. Rowe, the Court having reviewed the agreement of the parties and having concluded set agreement is in the best interest of the children, Jacqueline K. Pathic and Christian T. Pathic, although foregoing agreement is mad an order of court as tbough there had been a hearing. 'I'hc Order shall remain in effect until further notice or until further proceedings are held. By the Court, J. cc: James J. Kaycr, Esquire Richard C. Pathic, Jr., pro se Bethany Espcr, pm se JAN 2 4 2000` RICHARD C. PA HIC, Jit Plaintiff/Petitioner vs. BETHANY ESPER DefendmlURespondent vs. DIANE R. IZOWIE and JACK N. ROWE Additional Defendants IN THE COUR'f OP COMMON PLEAS OF CUMBEItLAND COUN'T'Y, PIiNNSYLVANIA NO. 99-6744 CIVILTERM CUSTODY It VISITNI'ION CIVIL ACTION - LAW ORDER OF COURT' 2000, upon motion of AND NOW, this day of James J. Kaycr, Esquire, attorney for Diane R. Rowe and Jack N. Rowc, the Court having reviewed the agreement of the parties and having Concluded set agreement is in the best interest of the children, Jacqueline K. Pathic and Christian T. Pathic, although foregoing agreement is mad an order of court as though there had been a hearing. The Order shall remain in effect until further notice or until further proceedings are held. By the Court, J. cc: James J. Kaycr, Esquire Richard C. Pathic, Jr., pro se Bethany Esper, prose I ..r ^C 1 r1 rY ?J T ^ rr 1T IT, O m 0 C 3 O J Q c m 4 U ? ¢ > '6 Ul ?q C y C N i p a n v C JJ ?. L . .. fN c> O 0 W y o f0 Q a) ? n Y CL U ?I , L sq? U') LO O r L Q ?a L Z O, C r to U .o W E N ? N U C N (6 C L_ L O O U.) N m J , c O M O '? o J 3 3 O J CL C R m O > QU ?¢> v N ? ? a T N C O a s c L W J J N Co Q c y a Q , i 4 . ?t M1" t C O o C ip O m a Q] O i ? C T ? C C C uT m C f6 a) C O y n n C ` N 0 d aN IL m Q Q N Y a Q v to 0 cti a r a C-) .O N 'o N C L co cu m co U 0 Lr) CD c .J JAN 2,,4 RICHARD C. PATHIC, JR., Plaintiff vs. BETHANY ESPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6744 CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this z y - day of January, 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. The December 18, 2000, Order of this Court shall continue in full force and effect. 2. Mother shall have primary physical and legal custody of the minor Children. Father shall have partial physical custody of the minor Children with the specific times and days to be mutually agreed upon by the parties. 3. Jurisdiction of this matter shall remain with the Cumberland County Court of Common Pleas in Cumberland County, Pennsylvania. 4. Counsel for the Petitioner shall continue to endeavor to serve Father at last known work and residential addresses in addition to the post office box address last known to be used by the Respondent's father. At such time as Father is served with the Order or counsel for the Petitioner is able to confirm that service has, in fact, been completed counsel for the Father shall file a Certificate of Service with this Court. 5. In the event that Father is aggrieved by the terms of this Order, Father may petition the Court for modification thereof. BY THE COURT, Kevi A. Hess, J. Dist: Marianne Murphy, Esquire, Legal Services Inc., 8 Irvine Row, Carlisle, PA 17013 Richard C. Pathic, Jr., c/o Richard Palhic, Sr., PO Box 19675, Kalamazoo, M1 49019 \ Lo : NA RICHARD C. PATHIC, JR., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 99-6744 BETHANY ESPER, CIVIL ACTION - LAW Defendant 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 Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Jacqueline K. Pathic November 4, 1998 Mother Christian T. Pathic September 15, 1999 Mother 2. A Custody Conciliation Conference was held on January 17, 2001, at 3:00 p.m. with the following individuals in attendance: the Mother/Petitioner, Bethany Esper, and her counsel, Marianne Murphy, Esquire. 3. The Father did not attend the Conference. No counsel appeared representing the Father. The Plaintiffs counsel reports that she has attempted service at the Respondent/Father's last known address where he is believed to reside with his father. The Petitioner's counsel reports that she has attempted service there by return receipt restricted delivery mail on several occasions and has had the mail returned marked "undeliverable as addressed, no forwarding order on file." The Petitioner/Mother reports that she spoke with the Respondent by telephone in recent weeks and he has informed her that he would sign the agreement which she had proposed; however, he claimed that he had not received anything. Counsel for the Petitioner reports that the proposed stipulation for the modification of the most recent custody order was mailed to the Respondent at a P.O. Box 19675 in Kalamazoo, Michigan. This was mailed on January 4, 2001. As of the date of the Conference, January 17, 2001, counsel had not received the letter returned unopened nor had the executed stipulation been received. Petitioner reports that she spoke to the Respondent on the date of the Conference to remind him of the Conference and to suggest that he call the Conciliator's office around 3:15 p.m. so that he would be able to participate in the Conference. She states that the Respondent was provided with the telephone number to call. The Conference was delayed in beginning until 3:40 p.m. and no telephone call was received from the Respondent. .. _... ._.._.eras.?r?r?N?eti'nrsxrraa?s..•.•?2=-?-'---..^??__.? .:rd2i9iClr• No. 99-6744 4. Petitioner reports that Father left the family on November 12, 2000, to reside in Michigan. Since that time, he has not returned and the Children have been in her care. Therefore, counsel for the Petitioner requests stipulation proposed to the Respondent be entered as a Temporary Order of Court. 5. The Conciliator recommends an Interim Order of Court as attached which provides Father with the option of petitioning for a modification if he feels aggrieved by the Order. /-aa- 61 (?i Date Melissa Peel Greevy, Esquire Custody Conciliator f1EC 151999N, . 10 RICHARD C. PATHIC. JR., Plaintil'1' `VS. BETHANY ESPER. Dclendant AND NOW this I Y" day of IN THE COURT OF CONIMON PLEAS Of CUMBLRLAND COUNTY. PENNSYLVANIA NO. 99-6744 CIVIL TERM CIVIL AC'T'ION - CUS'T'ODY ORDER Z-2h- , 1999, it being reported to the Conciliator that the parties have reached an agreement which makes further proceedings unnecessary, the undersigned Conciliator hereby relinquishes,jurisdiction and returns the matter to the Court Administrator. If either of the parties wishes Further proceedings in this action, they should petition the Court anew. FOR THE COUR'T'. cc: Paul S. Zimmerman. Esquire 'r MICIIALL L.'BANGS j/ Custody Coneiiiator 61 Bethany Esper, pro se 155 Salem Church. Lot 1162 Mechanicsburg. PA 17055 pLFp + r'ONOTARY g? pFC 28 RH 10' i 7 CU Pl,PCn1N5YLVAU?p COUNITY . • i 'y l^J IN RE: THE MATTER OF . IN THE COURT OF COMMON.~LEOF, ' RICHARl) C. PATHIC, JR. . CUMBERLAND COUNTY, PE~ 1 NMY1~gANtk 4 Plaintiff C-- VS . CIVIL ACTION - LAW BETHANY ESPER . CUSTODY/VISITATION c~ ~ Defendant . NO. 99-6744 Civil Term . -_n . - PETITION TO INTERVENE AND SEEK CHANGE OF VENUE ~ i TO THE HONORABLE, THEJUDGES OF SAID COURT, the undersigiied doc5 hereby petition the Court for Change of Venue of the above-captioned actioii froin Cumberland Counly, Pcnnsylvania to Davie County, Nortli Carolina, and sets lorlh herealier the rcasoils therefor: 1. Petitioiicrs are Jack N. Rowe and Diane L. Rowe, liusband and wilc, who currently resicle at. 164 Meadows Edge Drivc, Advaiicc (Davie County) N.C. 27006. 2. "I`hey have resided in North Carolina since July of 2005. 3. '1'he Plaintiff and Delendant are the biological parenls o1'Jacqueline K. Pathic, born Novembcr 4, 1998 and Christian 'l'. Pathic born Seplembcr 15, 1999, at which limc the parcrits and the narned children residcd in Cumberland County, Pennsylvania. I4. '1'he fatller of the children is ltie biological son of Petitioner Diaiie L. Rowc. '1'lic biolo9ical parcnts scparatcd, and [athcr inovcd Ii-oni Cumberland Counly, Pcnnsylvania to scvcral addresscs in Michigan with his last known address bcing 9805 ) W. Pickard Road, Remus, Mictiigan 49340 in November 2000, aiicl has not rcturrie(l to Petnisylvaiiia since tl?at date. 6. A lhird child, Jonallian Isaiah Pathic was born on January 22, 2001. [.Aw oFFIcE oF 7• "I'he biologrical mother moved Irom Cumberland County, Pcnnsylvauia to an uuknown WM. D. SCHRACK III address in Michigan on Febi-uary 14, 2001 wilh the threc children aiid thcii reconcile(i with the fathcr. S. A Iourtli child, Kimberly Pathic, was born on August 13, 2002. 9. Because of ciiscord in the home, and the threat of Michigan's Protective Serviccs removing the children from the biological parents care, custody and conlrol, the I~ biological parents called the Petitioner on March 31, 2003 and asked thal they pick up the children and keep theni. 10. Petitioncr Diane L. Rowe did travel to Michigan to pick upJacqueline Palliic and i Christian Pathic, mid Jonathan Pathic and returned to Pennsylvania wilh thc children on May 1, 2003 with a"Power of Attorney" sigtied by bot}i parents. 11. "I'he Petitioners took the children to Dr. Katlileen ,Jaxlseii, a child Psychiatrist, immediatcly aftcr thcir rclurn to Pcnnsylvania. (sec Exhibit "A") 12. L1pon returning to Pennsylvania, therc were occasional calls during May 2003 from biological mother to Diarie. In,June of 2003 the biological parents separaCc(i w)d all ca(ls stopped. 13, 13iologieal rYiother sulfcrs from, and ackiiowledges, menlal hcaltli issues which have in the pasl, arid tYlay in ttie fulure, prevent her froril providing adequale carc Ior llic cliildren. 14. "I,lie Petitioners filed with the York Counry Court a Petition for custody of the subject children in 2005, and custody was awarded to t}iem by the Honorable Richard K. Rein, Judge of the Court ot'Common Plcase of York County, Pcnnsylvania on April 26, 2005. '1'hal Order also graiitcd permission to the Petitioners to relocatc to North Carolina with custody of the three children (sec Exhibit "B"). 15. Pelitioners relocaled from the PeYinsylvania to the SCatc oi Nor(h Caroliiia in July <>l' Lnw orFIcEOF 2005 and havc rcr7iaiiied in North Carolina sincc lhat timc. WM. D. $CHRACK III 16. 'l,hc rights o1 thc biological parcnts in Jonathan Isaiah Pathic wcrc tcrininatcd by Page -2- i Order of Court in,june of 2007, and thc child was adoptcd by Robcrt and Mclanic Watis who are [iicnds of lhc Pctitioncrs. 17. 'I'he rights of the biological parents in Kimberly Pathic were terrninated by Order ol' II Court in Michigan in January of 2006, and that child was adopted by Jaxnes and Staccy ~ ~ j Sprau. S[acey is the half sister of the father. i . . ~ 18. Petihoners atternpted to terinmate thc Parental Rights ot thc Biological ParcnGS of thcir grandchildren who havc resided with them since May t, 2003 but were advised by tlic I i Davie County, Norlh Carolina Courts lhat it was necessary to have Veziue ol'the c<LSe i translerred from Cumbcrland County, Pennsylvania to Davie County, Norlh Carolina. 19. Pctitioncrs scck a changc of vciluc in lhc abovc-caplioncd rnattcr [roin Cumbcrland Counly, Pcnnsylvania to Davie Counry, Nortli Carolina, so tliat lhcy can Pclition tc> terminate tlle Parental Riglits of tlie Biologieal Parents in their ~,~raidchildren, whicli have resided wilh tlicro since May 1, 2003, and have had uc> contacl witli llicir biological parents since,June, 2003. 20. i lpon achieving a Change of Venue for d1e Custody Proceeding, Petitioners intcncl [o adopt their grandchildren who have resided with thein Ior the past cight ycars. WHEREFORE, the Petitioners pray your Honorable Court will change venue ol'thc abovc- captioiied action Erom Curnberland Court, Peiirisylvania to Davie Counry, North Carolina, and tliey will cver pray. Rcspcctfully submitted, ~ LAW OFFICE OF Wht. D. SCt-txnCx III . . Schrack III, Esquire (15893) Attorney for Petitioners 124 W. Harrisburg Street Dillsburg, PA 17019-1 Z68 '1'elephonc: 717-432-9733 Page -3- JAN-01-1900 00:01 P•01 CPUld S AcioVescent Strvic:en ~ Meadawfands 3542 Conc:orci Road York, PA 17402 i 17.Ary ,6350 Tpl . . . t300.F38ti.1 b67 7.85,.3372 Fax . ~TELLSPA~T ~Nww.weilspan.ort7 kchaviora! i-I<:alth Octobcr 6, 2003 Mrs. Diane itowe 8 Sunset C01131 Uillsburg, PA 17019 L)ear MrS. Rowe, In accordanee- W11I1:ntI3• conversation during Jacyueline's cuunseling appoiniment on September 25, 2003, it is my rec;<immendation that plionc ccmiact with h4r biolog[ca1 rtiothe-r not he perrriittcd at this time. 'I As yau are aware, Jacquelinc is being treated for an .Acijustmestt Ditiorder, with Disturbance oFEmoticm and C'unduet, based on her traumatic history and recent rclocaticrn tO yvu17 home. Hcr emolional staic and conduct havc both signifiicantly ilnproved sincc thc:.relocation_ Reccnt phane crnitact with hcr 6iologicui muther, howevor, appears tci be impedinb hir ability to adjust, You have report(A thal she bci:on3es upses not otily during xnci immediatcly follnwing the convcrsation, hLrt her behsvior worct-ns f6r some period of timc after those ccinversations. Her emotional outbursts and umcluLt di5turbane;es aisa appear to he F?aving a cleleterious effcet on Chnslian, whn eiti*r .ntimlcs her ix;havior ar resposld5 lu her upset emotional state hy beconiing upsct as welt, anci hoth tiis daytitYie behavior and lus nichtmares worsen. tt is my understaniling ihai termination ofparcntai righl5 and adaption nre being purstted #ur the5e children. In that llbht, any polenlially beneficial cfyccts ol'having contact with tlieir mother is far aXjiwcighe;d by the emotional ancl behaviural disturbances it is crc:ating, and. the inictfcreneG it is presenll} causing with thcir succtSSFuI adjustment to theu new invironment_ Tt i, possible that at:soinc point in the luture the children may wish uo pursue conta.ct with their mnther, but al this time it is clearly not in thcir besl interest and L vvuuld strongly recommend that it ~ot be permittcd. If you have any actditional que5tions, plcasi; feel Free to COni3Ct mc:. Sincerely, KathICCIl M. 3a11S1'`i];-PM.S. c0ct, 24. 2011: 5:41 PN~71z$sY~,RO HOFFltYER & sE~a~aN ~uo, ~ i~; w~J07/013 ~ , ~ . ; - : .r.~-~• . , . r,,_ , ~ , J j ~f . t -r'. , x ~f ' . - , ' , . ~ . ' . • ~ - . ~ ' ~ ' ~r ~ ~ ~ ~ . ~ . ~ • , . , ' ~ . . , : ' , ' ` ~ . ~ • • _ ~ , , :YIY: T~E COUtT OF C011M0N PLEAS~ OF YOR.K.COY7M3 ?MNSY~, ~'ATyYA FAlYMY DTY'ISION - ~ ~ • . ~ ~ ~ . . ~ :'Jack.N. and:'Diane~L..R~v~ie; - . ~ ~ ~ . ; -:No: 034 . . _ . _ , . _ . . C-078-Y03. . , . • ~~y /.~r~ ~ . . , . ~ • . , ~ • , , _ ~ s . . - - •''~=•1,;;'-:' - - - . : , - . ' ~ . ~ 'Action in Gtiictody . - :_E - . ' . . ; • ~ , • ~ • . _ - • . - . ~ _ ~ - . ,:.'!'4`,j- ~ - • . _ ' ' ' • , , : ~ . ' ' • • ' • " . . • . , ~ :-BetSsay.E~per • . . . . . . . . . - . . . , ' - , . . . , ~ . ' ~ ` R1Ci~ta ~~t~?1C, yr, • , ~ • ' . ; . . , ' ~ , • • ~ , , ' ' , ~ ~ . _ • . ,-i : ' •'r. ' i. ' ' ~ 5 ' " . : ' _.1;' ~ •,5,; ' • • . . fbfidaAZ-= ' ' ; • , . ~ , . ~r, . ' , , . . - , _ . ' ~L . • - . ~ - CA' ? ~Y'1\ • ~ ~ , , • , ~ ~ • ~ ~ 1~ a •{1, ~1 ~ r• . , - . - . . . , . : • • . ' • . , _ ~ Co. -13 : ~ ` ~APpLA.RANCES: ~ . ~ - , . , _ - _ . - ,Ct~. ~ ,,,R . . . . . - . . . . . - . . . , . :;.1 . . , - ~ _ . . ~ • . ; , . :C3;: ..~'c .FoT the-Pl~aintiff•_ ; Dawli.Cutsia-Watcbiua,EsquircY`~„ .~~.-.~Q. - ; • ''~s . _ ~ Far th~ Defcndaaa;C: ; ~7obn'J. lvioran, ~1, Fsquiie' • , „ • . : - ~ . , ~ . - ~ ~ • - - • . - • ~ : , ' ° ..s . _I°.,', . : , • . , . • ~ ~ - . . ' . ~ . • ~ ' 4M'1 A• ~ • ' .~~-~~•'I. • ri~_~a i v . ~ • ~'1 • . . ' . ' ' r , . • . • ' • r;', G CUS'' byT1RrAY"~2 - ' - , •,r 1, '~41~ ' . ,,,••"V Eli l7'• . + n.d AW IlY ODY.:"_ : - _ . . . ' : • y' , • . 1*°,-.`--"!v"1'-~-, j, ; _ • . ~17 ~NO W, thi.~•1Stl~ c~y of Apn1,.7005, aeither the ~efcntlants~nor their. ~ , ~ _ : - ~'-i'-~' .-r •r ~;1~ 1u1$G~` . B~dfC . . , . i = - ; . ; ',~;r •f; .s;.. ;;•CO . QpP x -4kie -trial c6afct6c,e.~ ~ 'They ara the uw!iu?g Parties.. '~l'e ha.ve reccived ~ . a;, ' ; f o; : . . . . , . . • . . , - ti . 516 in,dir.ation,0~ tb;eir positivns{rvazid no pre- ~uial .~norandum, Wes f led o~p. ~e~r y~half.~. . ~ ; yj, a ':~aJ ~ 'r• - . - • . , . . . . ~ ~ ~ ~ ` ~r~ C~ • , - • - - ' ' - - +~Y ? _ •~t., y ~I~•. •~j., ~ , ' • . . • .1• • . ~ ~ ~ ~ '~.i ' • . . . OF CASE: ~ ~ ~ - ' ~ - ' . . . , ; - : : . ~ ~ - ~ . ~~y~ --1"~f • •4:' , ' - ~ . : ' ` ' ~ ' . ~~7 `y'~~.3.f"~ '1r ..M ' . t.~ . ~ . , -1 - - . ' ~it3 ir-atter cauie tn Yhd Couut on thr, petition oi B"y r'-sper, (MOthcr) a?adr ~.~1ard Patluc, Jr, ~(Fat~h~r) seelang p1narY physicsl Gustody.. ~ Y .4~^- c ~ . - - -r.'. • • ~ . , ' - . - _ . • . ' . . . . ~ .Ci ••(r ~~rY~ r , • • . • , . • ; - . ' : R_ • . - ' This matfr-r cancems the cuso(iy of ~ _ . , - • ~ : _ . F-CHIL1) AGE 0.OrB. - . . . ~ . . : _ - ,~f :+'r • ~ - • , - . • , . - . . , • , - Ja,cqueline lKara Pathic . . - 6 • •I ll4l98 . . . ` :~,,~r, ' - - ' . ' • ' . .-~Chfi~n Thoma$ P~~ ~ . ~ 1 raso ~~~$r ~ ~ ~ -9,15«9 f ,~r' . ~ ~ , • . J4nethsn IsaiahPathi,c , - ~ , ~ ~ ~ ' . ~ . ~ . ' ~ , ~ - ~ , : ~ ~ - ' - . ° . . . _ • , 4 ' ,•1 .r'~~ r ~ ' .i` ~ ~ ` ' • ~ , ' . ' ~ ; •F~ . - v, ~ ~D~ tbe reoords a~k~fic ~idit3'ome~oa~s af oekC~urit~t.l~eitr~_ ~t ~ ~aayoe*Lza--juk,s°5- - • , ~ ; • . ~ , . • • Pamelt .Y., Prat~som cQct. 24. 2011.. 5:41 PM.fii7$szs?AO aoFFMR & sEMMEr.VArr No . 7 8 9 ~ : • . • ' : . ~ - i. . . . . ' . , , . ~ . . . _ ~ _ ~ • ~ . - - , - . . . . ' _ ~ . . ~ , • , .'Th& current custody situation .Legai custody: Legal custotciy•is with Patemal - . . , . . . . - ~ , . - ~ • • . . . • ; •Grsn,dpsrents; Physicril custoc~y: Prinzery with Pateraal Grandpn'reri'ts,and parents have rights - . : . : . . . , _ ~ y ~..p.f s,npetviseti visitation. " 'L~~.r~ • r~~' 1 ' ~f. , ~•.r ~ . • • ~ ~ . ' ~ . 1' - ~i~ ' . . _ , ~ . I i ' . . . ~ . . , . ' _ •'f' •+.7•Y'.~~ . - . _ ~ • ~ :i., • ' : ~ ; ' ~ • ' , : ,ACaaxdingly,.upon failure 'of the'mavw.g parties,16 proce ~ed ia this m$tter; we, • . . . _ `~~,~si;: - :5;:~:.,`~:.__;~., , , ~ . . - : _ ' . .l~~t ~ ~ - • ~ ~hereb~rD~.SIv~SS the~r-petihau for custody_.. .VVe ~h~ieb~r award Sd~E~LEGAL 'custody and _ 't~;.:~ - ~ • , . : : : : ~.5~~'~~Y'~IC~?I,.custody of the r,hUdren16PlairitifFs, subjecf to whatever rights.afpmtial~ ' - ;'i•' . „ . - • • ~ . . • - _ _ , r~:• _ .''cugtcdq:~o Deftdarits.as the paYi.fesmay ~agree ftiu:tinie:W timz. . • _ . . ~ - ' • . r t~_ , ' " . ' - ~ • plai~tif£s are h~.granted permission to RELOCATE to N0IkTH . . ~ . - ~ , ~t~•~: - ' • . , . ~ ; - . . , . ; . . ~ . - :,C . c3,L- ]NA vh ~ustody'of r,e'childrem. ~ : ~ : •w:~ - . : . . . . . . - w, ,t ~ _ • ~ • - ~ . ~ . : , . 't _ ,~•+11•~~. } ~ ~ ~ • . i • ~ • . ~ 5 1 ` I "~."~i ~ ' 'I• ~ IW " • • ~ _ t ' . i 1 • ' . . I ~ •'t ' ~ . .1~._ ...~'i~•" L! . ~~1.' •1• ' . 'r : . _ ~ ~ ~ • . : . . ' " I!~ S.`- . " • " ~ ~ '•1 • - ~ : , h:; ~1 ~ - ~ ~ ~`,Dp1~S'Of 5 O (Yww d4YCIEd t4 ` • ' ' - ' ' - ~ - • i•,~,:;''~.._~ . '-r ,'v„ :'v, ~ ';G` •:.a-: ~ : , _ , , . . . v'f' . • . a . ~ . . . i ' . . . . ' ~ . . , . . . , . - -t . . . . ~q , a•. - , . . . . y- . . . . ~ . Ji• . . , . . . ~ - r•. . . . . . • . . . ~ .7 t . ~ , . . . .4. .L . . . 1 ,~i•~ ,'1 ~ . • . " . . . w . - • . . v _ r . . . . . . . . , I - . ~ . . . , :'q f.v' ~ '.:1' ~ ':r ' • ' . ~ 1,~ i . ~ + I `1~'•- ~n~•~+:..~t;,~ _i~ r ota.nsct~for Plaw,tifEs• . ~r: , ~ - ' ' . • • ~ v •~r, ~ ~~5';•~:: ~ _ : - , _ - _ , _ , . . - ~ti~ , - - ..i:• }~4;: _ . ~d ,L . , - t~.•:~'"•:.~,:' . ~ . 'sh$1L.6'=ntto,cowasn'1Defeudanta ~r{)~r~. '~~l.{•y - ' , . . . P. . . ti • . _ ~ • _ • ` . ' .I . - , ' . ` ,'.`,j~•~.~~~~! Y'~~ ,d7~~~ • F.~t' o . . : • i, . . • . - ' ' . - . ' , - ~~aGr~.~' v,~fi"~'c;?"~~~':' r+~ • ~ . ' ' ~;i.~ - - .f..~! '~~.'~°'•__t _ • I, • . '~x . . ~ T~ ~ T • ~ ' . ~i • ~ ~ ' S•~ `~y1(. ~ ~ ~'4: • ; f: . . . B cO~JIt'b~ r~ ' ~ ~t• r ti ~ ,.i. ~4.'~.01 ~ ~ ~r ~ . . • . : • . r ~~.['~7 ~GI•~~. ~.j~.~,.~, _l~_ _ ' . ,.~i•• ~I ~ ~~;:4` ! .1 i{ '.ti.k~: ' r• ~ ~ ' • t~6~ ~ . ~~4~.. •l"ni~~• ' : .1 ' • . • . ~ _ ' ' • , t~'''~. ,'ti . -s - ~ ~ . . • i ~ ' . ~ t ; ~ -n- • + ~~1 ' . , , . ~ , , , ~ . . ~ . . : , ' } . . - ~ '•PJCFiARD K. ItENN, ~1DGE . . . ~ . ~ • - . . , - - :ti~' ~ . . . ' _ . ' . ' ; ' ~ • • - , , • . . ~ '7 - . • . iti4{-` • . ~ • ' • ~ . . . ~ `iT ~ , - • ~ - . . " , ' . • " } J . ' I ~ • . ~ i . . • ~ , . 1: *~Ii~.~v.T' , ' - ~ . • . • , , r ' • ' ~ ~ - , K ~ _ ~ . ~ ; . - ~ . ~ . 91149Q600~~1- : - _ ~ . , . , . - : . , . ~ . . _ ~ . . " . , ~ r ~ ' • - • ' 1 , . • . I. r , • . , ' . . ~ ~ - : ~ - Yo Cous~cf?, r~c~ di/lwdni~ tk ..C~.KTII''~D froln the records efttaa Court ot CAmmoaPleul . . . ~ A.D. ~ ~ . , P'nwela e. X.ea~ Pcotbnndtar9 : IN RE: THE MATTER OF . IN THE COURT OF COMMON PLEAS OF I RICHARD C. PATHIC, JR. . CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . VS . CIVIL ACTION - LAW BETHANY ESPER . CUSTODY/VISITATION Defendant . NO. 99-6744 Civil Term VERIFICATION We, JACK N. ROWE and DIANE L. ROWE, tlie witFiin Petitioners, verify that the Iacts set Iorth in this instrument arc true and correct to the best of our knowledgc, iiiformation, and belicf. "l'liis vcrilication is madc subjcct Lo tlic pcnallics oC Seclion 4904 ol'thc Cririies Code (18 Pa. C.S. §4904) relating to unsworn falsification to audiorities. -~'~/C.. • ~ - - J CK ROWE DIANE L. ROWE LAW OFFICF, OF VVM. D. SCHR4CK III H IN RE: THE MATTER OF RICHARD C. PATHIC, JR. Plaintiff VS BETHANY ESPER Defendant ORDER AND NOW, this IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CUSTODY/VISITATION NO. 99-6744 Civil Term ----- day of---!V? ---------- 2011, upon ?M'o4<m ol'\N'ru. D. Schrack, III, attorney for Pei t ionerJack N. Rowe and Diane L. Rowe, husband and wile, the Court having; reviewed the Petition el'the Parties and concluded that such transfer of Venuc is in the best interest of the children, Jaequelil ie K. Patliic and Christian T. Pathic, Venuc of the captioned case is vacated by Cumberland County, - 'cnnsylvania Courts, and transferred to the Courts of Davic County, North Carolina. By the C rt: Z --------------------- J• LAw OFFICE OF Wit. D. SCHRACK III v ?m D . SChra???, ?j ? ?1 ?ehard C •?.'I?lue,? Cp?tPS M -t r ?- rI' - F a,c, Page -5- R ,. ai ?'j;°? ?` „- ? ... ,. C. ??,`