HomeMy WebLinkAbout01-6088CHAD WATSON,
Plaintiff
LYNN R. WATSON,
Defendant
: 1N THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO.
2001-{'~ '~' CIVIL TERM
: CIVIL ACTION - LAW
: IN CUSTODY
COMPLAINT FOR CUSTODY
1. Plaintiff is Chad Watson, an adult individual currently residing at 55 SME, South
Hollar Drive, Shippensburg, Cumberland County, Pennsylvania 17257.
2. Defendant is Lynn R. Watson, an adult individual currently residing at 321
Farmington Manor Drive, Shippensburg, Cumberland County, Pennsylvania 17257.
3. The Plaintiff is the natural father of the children, Kyle Avery Watson, bom
January 23, 1996, aged 5; and Colton Riley Watson, bom October 2, 1997, age 4.
4.
wedlock.
The eldest child was bom out of wedlock, while the youngest child was bom in
Since birth, the children have resided with the following persons at the following
addresses for the following lengths of time:
ADDRESS
321 Farmington Manor Drive
Shippensburg, PA
1108 Kessler Drive
Shippensburg, PA
NAME
Lynn Watson
Lynn Watson
Vicki Mathna
Larry Mathna
(maternal grandparents)
DATES
December 2000 to
present
August 2000 to
December 2000
NAMP
Lynn Watson
Chad Watson
Lynn Watson
ADDRI~SS
8916 McClays Mills Road
Newburg, PA
8916 McClays Mills Road
Newburg, PA
DATES
July 2000 to
August 2000
Birth to
July 2000
married.
7.
is married.
The natural Father of the children is the Plaintiff, who resides as foresaid. He is
The natural Mother of the children is the Defendant, who resides as foresaid. She
8. The relationship of the Plaintiff to the children is that of natural Father. The
Plaintiff currently resides with his girlfriend.
9. The relationship of the Defendant to the children is that of natural Mother. The
Defendant currently resides with the children and her boyfriend.
10. The Plaintiff has no information of a custody proceeding concerning the children
pending in any Court of this Commonwealth.
11. The best interest and permanent welfare of the children will be best served by
granting the relief requested.
12. The Plaintiff does not know of any person not a party to the proceedings who
claims to have custody or visitation rights with respect to the children.
WHEREFORE, the Plaintiff, Chad Watson, respectfully requests this Honorable Court to
enter an Order scheduling the Parties for a Custody Conciliation.
Date:
Respectfully submitted,
Attorney for the Plaintiff
One West High Street, Suite 208
Post Office Box 1290
Carlisle, Pennsylvania 17013
(717) 240-0833
VERIFICATION
I verify that the statements made in this Complaint are tree and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to
unswom falsification to authorities.
CHAD WATSON, Plaintiff
LAW OFFICES OF
MISLITSKY AND DIEHL
CHAD WATSON : PLAINTIFF
V.
: 01-6088
LYNN R. WATSON
DEFENDANT : IN CUSTODY
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
AND NOW, Tuesday, October 30, 2001 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, November 28, 2001 at 3:30 PM
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.
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 THE COURT,
By: /s/ ]acqueline M. Verney. . Esq.
Custody Conciliator
The Court of Common Pleas of Cumberlend County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
/ ¢~. /cc. ,~/
· ~ NOV ,e 8 2001
CHAD WATSON,
Plaintiff
LYNN R. WATSON,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 2001-6088 CIVIL TERM
: CIVIL ACTION - LAW
:
: IN CUSTODY
ORDER OF COURT
AND NOW, this ~ day of ~~, 2001, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. The Father, Chad Watson, and the Mother, Lynn R. Watson, shall have
shared legal custody of Kyle Avery Watson, bom January 23, 1996 and Colton Riley
Watson, born October 2, 1997. Each parent shall have an equal fight, to be exercised
jointly with the other parent, to make all major non-emergency decisions affecting the
Children's general well-being including, but not limited to, all decisions regarding their
health, education and religion.
2. Mother shall have primary physical custody of the child, with Father
having periods of partial physical custody as follows:
A. Alternating weekends from Friday at 7:00 p.m. to Sunday at 7:00 p.m.
B. Every Wednesday from 5:00 p.m. to 7:00 p.m.
C. Such other times as the parties agree.
3. The parties shall equitably divide all holidays.
4. The receiving party shall transport the children, except on Wednesdays
when Father will be solely responsible for transportation.
5. Due to Colton's heart condition, neither party will smoke or permit anyone
to smoke in the children's presence. In addition, the children will not be exposed to a
home where smoking has occurred in the previous nine (9) hours.
4. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control.
BY THE COUp/
cc: Thomas S. Diehl, Esquire, counsel for Father
Thomas J. Williams, Esquire, counsel for Mother
t,,o-/.,,-o ~
CHAD WATSON,
Plaintiff
V.
LYNN R. WATSON,
Defendant
PRIOR JUDGE: None
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
_.
: 2001-6088 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 conceming the Children who are the subjects of
this litigation is as follows:
NAME
DATE OF BIRTH CURRENTLY IN CUSTODY OF
Kyle Avery Watson
Colton Riley Watson
January 23, 1996
October 2, 1997
Mother
Mother
2. A Conciliation Conference was held in this matter on November 28, 200 I,
with the following individuals in attendance: Father, Chad Watson, with his counsel,
Thomas S. Diehl, and the Mother, Lynn R. Watson, with her counsel, Thomas J.
Williams, Esquire.
3. A previous Order of Court had been entered in Franklin County dated,
November 19, 1998. Said Order, provided for mother to have primary physical custody.
4. The parties agreed to entry of an Order in the form as attached.
ll~P.') -o /
Date
~cqu{~line M. Vemey, ~s'quire~'
Custody Conciliator
CHAD WATSON,
Plaintiff/Petitioner
Vo
LYNN R. WATSON,
Defendant/Respondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 2001-6088 CIVIL TERM
;
: CIVIL ACTION - LAW
: IN CUSTODY
PETITION FOR MODIFICATION OF CUSTODY
currently residing at 55
Pennsylvania 17257.
Petitioner is Chad Watson (hereinafter referred to as "Father"), an adult individual
SME, South Hollar Drive, Shippensburg, Cumberland County,
5. There have been no additional actions relative to custody of the within named
children in any jurisdiction to the Petitioner's knowledge.
6. Since the entry of the Court's Order of December 6, 2001, the children have
primarily resided with Mother.
2. Respondent is Lynn R. Watson (hereinafter referred to as "Mother"), an adult
individual currently residing at 321 Farmington Manor Drive, Shippensburg, Cumberland
County, Pennsylvania 17257.
3. The parties are the natural parents of the children, Kyle Avery Watson, bom
January 23, 1996, aged 5; and Colton Riley Watson, bom October 2, 1997, age 4.
4. The parties are currently subject to a Custody Order dated December 6, 2001,
which was the result of an agreement reached at a Custody Conciliation Conference held on
November 28, 2001. A copy of said Order is attached hereto and incorporated herein by
reference as Exhibit "A."
Among the reason why Father desires to modify the existing Order are as follows:
(a) Father had previously desired to share more time with the parties' children
and accordingly filed a Custody Complaint on October 24, 2001, to pursue his
intent.
(b) A Custody Conciliation Conference was scheduled for November 28,
2001, to address the issue of expanding Father's time with children.
(c) On November 28, 2001, the day of the Custody Conciliation Conference,
Father was informed by Mother that a Children and Youth Services case was
pending against him due to recent allegations of abuse.
(d) The allegations stemmed from Mother taking one of the parties' children
to the Emergency Room for injuries the child sustained, which Mother believed to
have been caused by Father.
(e) Consequently, Cumberland County Children and Youth Services
investigated the matter, and ultimately determined that the allegations of abuse to
be unfounded.
(f) Now that there is no pending Children & Youth Services action, Father
still desires to exercise more time with the children, and accordingly brings this
action.
divorced.
The natural Father of the children is the Petitioner, who resides as foresaid. He is
9. The natural Mother of the children is the Respondent, who resides as foresaid.
She is divorced.
10. The relationship of the Petitioner to the children is that of natural Father. The
Petitioner currently resides with his girlfriend, Kelly Short.
11. The relationship of the Respondent to the children is that of natural Mother. The
Respondent currently resides with the children and her boyfriend.
12. The Petitioner has no information of a custody proceeding concerning the children
pending in any Court of this Commonwealth.
13. The best interest and permanent welfare of the children will be best served by
extending Father's time with the children.
14. The Petitioner does not know of any person not a party to the proceedings who
claims to have custody or visitation rights with respect to the children.
WHEREFORE, the Petitioner, Chad Watson, respectfully requests this Honorable Court
to enter an Order scheduling the parties for a Custody Conciliation.
Date:
AU6 o 5 2002
ybmitted,
Thomas S. Diehl, Esquire
Attorney for the Petitioner
One West High Street, Suite 208
Post Office Box 1290
Carlisle, Pennsylvania 17013
(717) 240-0833
VERIFICATION
I verify that the statements made in this Petition are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to
unswom falsification to authorities.
CHAD WATSON, Petitioner
EXHIBIT A
CHAD WATSON,
Plaintiff
Ve
LYNN IL WATSON,
Dofendant
: NO. 2001-6088 CIVIL TERM
: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
consideration of the attached Custody Conciliation Report, it
follows:
1. The Father, Chad Watson, and the Mother
shared legal custody of Kyle Avery Watson, bom January 23, 1996
Watson, bom October 2, 1997. Each parent shall have an equal right, to
jointly with the other parent, to make all major non-emergency derisions!
.Children's general well-being including, but not limited to, all decisions
health, education and religion.
2. Mother shall have primary physical custody of the child,
having periods of partial physical custody as follows:
A. Alternating weekends from Friday at 7:00 p.m. to Sunday at 7:00 p.m.
B. Every Wednesday from 5:00 p.m. to 7:00 p.m.
C. Such other times as the parties agree.
3. The parties shall equitably divide all holidays.
4. The receiving party shall transport the children, except on Wednesdays
when Father will be solely responsible for transportation.
5. Due to Colton's heart condition, neither party will smoke or permit anyone
to smoke in the children's presence. In addition, the children will not be exposed to a
home where smoking has occurred in the previous nine (9) hours.
4. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control.
RECEIVED
BY THE COUI~T,
. Tho~,~ $. Willi~.F~ui~, ~um~l fmMoth~r
CHAD WATSON,
Plaintiff
Ve
LYNN R. WATSON'
PRIOR JUDGE: None,
: IN ~ COURT OF COMMON PLEAS OF .... ..
: Cl.rMBFIILAND COUNTY, PF.,I~SYLVANIA ,~"
Kyle Avery Watson.
Colton Riley Watson
January 23, 1996 Mother
October 2, 1997 Mother
2. A Conciliation Conference was held in this matter on November 28, 2001,
with the followin~ individ-~ls in attends~_ce: Father, Chad Watson, with his OOUlZ~Ol,
Thomas S. Diehl, and the Mother, Lynn R. Watson, with her'counsel, Thomas $.
Williams, Esquire.
3. A previous Order of Court had been entered in Franklin County dated,
November 19, 1998. Said Order, pwvided for mother to have primary physical custody.
4. The parties agreed to entry of an Order in the form as attached.
Date
CHAD WATSON
PLAINTIFF
LYNN R. WATSON
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:
: 01-6088 CIVIL ACTION LAW
:
IN CUSTODY
:
ORDER OF COURT
AND NOW, Wednesday, August 14, 2002 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear beforeJaequeline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland Count~ Courthouse, Carlisle on Tuesday, September 03, 2002 at 9:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The conrt 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 THE COURT,
By: /si
]acqueline M. Verney, Esq.
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our office.
All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must
attend the scheduled conference or heating.
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
CHAD WATSON,
Plaintiff
Ve
LYNN R. WATSON,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2001-6088 CIVIL TERM
: CIVIL ACTION - LAW
:
: IN CUSTODY
ORDER OF COURT
AND NOW, this b'~ day of ~1,~ . ,2002, upon
consideration of the attachec~ ~--~ody Conciliatior~ Report~, ~[is ordered and directed as
follows:
1. The prior Order of Court dated December 6, 2001 is hereby vacated.
2. The Father, Chad Watson, and the Mother, Lynn R. Watson, shall have
shared legal custody of Kyle Avery Watson, bom January 23, 1996 and Colton Riley
Watson, born October 2, 1997. Each parent shall have an equal right, to be exercised
jointly with the other parent, to make all major non-emergency decisions affecting the
Children's general well-being including, but not limited to, all decisions regarding their
health, education and religion.
3. Mother shall have primary physical custody of the children, with Father
having periods of partial physical custody as follows:
A. Alternating weekends from Friday at 5:00 p.m. to Sunday at 7:00 p.m.
B. Such other times as the parties agree.
4. Thanksgiving shall be shared from 9:00 a.m. to 3:00 p.m. and 3:00 p.m. to
9:00 p.m. as agreed by the parties once Mother knows her work schedule.
5. The Christmas holiday shall be divided into two Blocks. Block A shall be
from 12:00 noon Christmas Eve to 12:00 noon Christmas Day. Block B shall be from
12:00 noon Christmas Day to 12:00 noon December 26. The Christmas holiday shall be
split as agreed by the parties once Mother knows her work schedule.
6. The parties shall cooperate with a custody evaluation to be performed by a
psychologist chosen by the parties.
7. The parties shall share transportation by meeting at the McDonald's in
Shippensburg to exchange custody.
8. Due to Colton's heart condition, neither party will smoke or permit anyone
to smoke in the children's presence. In addition, the children will not be exposed to a
home where smoking has occurred in the previous nine (9) hours.
9. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control. Either
party may contact the Conciliator to schedule another conference upon completion of the
custody evaluation.
cc: Thomas S. Diehl, Esquire, counsel for Father
Thomas J. Williams, Esquire, counsel for Mother
CHAD WATSON,
Plaintiff
V.
LYNN R. WATSON,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: 2001-6088 CIVIL TERM
:
: CIVIL ACTION - LAW
:
: IN CUSTODY
PRIOR JUDGE: Edgar B. Bayley, J.
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 subjects of
this litigation is as follows:
NAME
DATE OF BIRTH CURRENTLY IN CUSTODY OF
Kyle Avery Watson January 23, 1996 Mother
Colton Riley Watson October 2, 1997 Mother
2. A Conciliation Conference was held in this matter on September 3, 2002,
with the following individuals in attendance: Father, Chad Watson, with his counsel,
Thomas S. Diehl, and the Mother, Lynn R. Watson, with her counsel, Thomas J.
Williams, Esquire.
3. A previous Order of Court had been entered by the Honorable Edgar B.
Bayley on December 6, 2001, providing for shared legal custody, Mother to have primary
physical custody and Father having alternating weekends.
4. The parties agreed to entry of an Order in the form as attached.
Date
Esquire
Custody Conciliator
F:\F1LESkDATAFILE\CreneralkDocuments\ 10505-1 .petkion/tde
Created: 01/28/02 08:29:24 AM
Revised: 06/02/03 11:55:39 AM
I O505. I
CHAD WATSON,
Plaintiff
V.
LYNN R. WATSON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001-6088-CIVIL ACTION LAW
IN CUSTODY
PETITION TO MODIFY CUSTODY
1. A Custody Order was entered on September 5, 2002, a copy of which is attached
hereto as Exhibit "A."
2. Mother, Lynn R. Watson, has secured employment out of state and will be relocating
on July 1, 2003.
3. The above noted relocation will necessitate a change in the custody arrangement.
Mother proposes to afford Father significant time during the school summer vacation and also during
holidays when Mother visits family in Pennsylvania. Mother will provide transportation as long as
the timing can be coordinated.
WHEREFORE, Mother, Lynn R. Watson, requests that the Custody Order of
September 5, 2002, be changed in accordance with the above.
Date: June 2, 2003
Respectfully submitted,
MARTSON DEARDORFF WILLIAMS & OTTO
Thomas J. ~30l~liams, Esquire
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorney for Defendant Lynn R. Watson
,SEP 0 3
CHAD WATSON,
Plaintiff
LYNN R. WATSON,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2001-6088 CIVIL TERM
: CIVIL ACTION- LAW
:
: IN CUSTODY
ORDER OF COURT
AND NOW, this $? day of ~,~,'T~,~,,o.~ ,2002, upon
consideration of the attached Custody Concili6tion Report, it is ordered and directed as
follows:
1. The prior Order of Court dated December 6, 2001 is hereby vacated.
2. The Father, Chad Watson, and the Mother, Lynn R. Watson, shall have
shared legal custody of Kyle Avery Watson, bom January 23, 1996 and Colton Riley
Watson, born October 2, 1997. Each parent shall have an equal right, to be exercised
jointly xvith the other parent, to make all major non-emergency decisions affecting the
Children's general well-being including, but not limited to, all decisions regarding their
health, education and religion.
3. Mother shall have primary physical custody of the children, with Father
having periods of partial physical custody as follows:
A. Alternating weekends from Friday at 5:00 p.m. to Sunday at 7:00 p.m.
B. Such other times as the parties agree.
4. Thanksgiving shall be shared from 9:00 a.m. to 3:00 p.m. and 3:00 p.m. to
9:00 p.m. as agreed by the parties once Mother knows her work schedule.
5. The Christmas holiday shall be divided into two Blocks. Block A shall be
from 12:00 noon Christmas Eve to 12:00 noon Christmas Day. Block B shall be from
12:00 noon Christmas Day to 12:00 noon December 26. The Christmas holiday shall be
split as agreed by the parties once Mother knows her work schedule.
6. The parties shall cooperate with a custody evaluation to be performed by a
psychologist chosen by the parties.
7. The parties shall share transportation by meeting at the McDonald's in
Shippensburg to exchange custody.
EXHIBIT "A"
8. Due to Colton's heart condition, neither party will smoke or permit anyone
to smoke in the children's presence. In addition, the children will not be exposed to a
home where smoking has occurred in the previous nine (9) hours.
9. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control. Either
party may contact the Conciliator to schedule another conference upon completion of the
custody evaluation.
BY THE COURT,
Jo
cc: Thomas S. Diehl, Esquire, counsel for Father
Thomas J. Williams, Esquire, counsel for Mother
VERIFICATION
Thomas J. Williams, Esquire, of the firm of MARTSON DEARDORFF
WILLIAMS & OTTO, attorneys for Defendant Lynn Watson in the within action, certifies that the
statements made in the foregoing Petition are true and correct to the best of his knowledge,
information and belief. He understands that false statements herein are made subject to the penalties
of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities.
Thomas J. Willi~
CERTIFICATE OF SERVICE
I, Tricia D. Eckenroad, an authorized agent for Martson DeardorffWilliams & Otto, hereby
certify that a copy of the foregoing Petition to Modify Custody was served this date by depositing
same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows:
Thomas S. Diehl, Esquire
MISLITSKY AND DIEHL
One West High Street
Suite 208
Carlisle, PA 17013
MARTSON DEARDORFF WILLIAMS & OTTO
~ ' Tri~'~a D. Eck-erT_ro-a~ '~"~
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: June 2, 2003
CHAD WATSON
PLAINTIFF
V.
LYNN R. WATSON
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: 01-6088 CIVIL ACTION LAW
: iN CUSTODY
ORDER OF CO[JRT
AND NOW, _ Friday, June 06, 2003 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, June 25, 2003 at 8:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
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 hearinl~.
FOR TIlE COURT,
By: /s/ ]acqueline M. Verney. Esq.
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law t0 comply with the
Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our office.
All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must
attend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
JUN 2 b 2003
CHAD WATSON,
Plaintiff
V.
LYNN R. WATSON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
2001-6088 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 25th day of June, 2003, the Conciliator being advised that the
parties have reached an Agreement, the Conciliator hereby relinquishes jurisdiction in
this matter.
FOR THE COURT,
~acqubline M. Vemey, Esquire
Custody Conciliator
5.-