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HomeMy WebLinkAbout03-3790JEFFREY A. McNELLY, PLAINTIFF LINDA R. McNELLY, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLAVNIA : :NO. : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Jeffrey A. McNelly, residing at 1441 Hillerest Court, Apt. 201, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant is Linda R. McNelly, residing at 102 Haldeman Avenue, New Cumberland, Cumberland County, Pennsylvania 17070. 3. Pla'mtiffseeks partial custody of the following child: NAME Whimey E. McNelly PRESENT RESIDENCE D.O.B. 102 Haldeman Avenue 05-18-87 New Cumberland, Pennsylvania The child was not bom out of wedlock. The child is presently in the custody of Linda R. McNelly who resides at 102 Haldeman Avenue, New Cumberland, Pennsylvania. During the past five years, the child has resided with the following persons and at the following addresses: NAME Jeffrey A. McNelly (father) and Linda R. McNelly (mother) Linda R. McNelly RESIDENCE DATE 102 Haldeman Avenue 07/98-07/01/02 New Cumberland, Pennsylvarfia 102 Haldeman Avenue 07/01/02 - Present New Cumberland, Pennsylvania The mother of the child is Linda R. McNelly, currently residing at 102 Haldernan Avenue, New Cumberland, Pennsylvania. She is married. The father of the child is Jeffrey A. McNelly, currently residing at 1441 Hillerest Court, Apt. 201, Camp Hill, Pennsylvarda. He is married. 4. The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with no other person/persons: 5. The relationship of Defendant to the child is that of mother. The Defendant currently resides with the following person/persons: NAME RELATIONSHIP Whimey E. McNelly Daughter Ashley L. McNelly Daughter 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court with the exception of an Order regarding exclusive possession of the marital residence which also addressed the issue of custody of the minor child. Although the provisions regarding custody of Whimey E. McNelly have been addressed in the divorce action, the Plaintiff is requesting they be specifically provided for in a separate Order of Court regarding custody. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, the Plaintiff, Jeffi'ey A. McNelly, requests the court to grant parfml custody of the minor child, Whimey E. McNelly, to him. JAMES, SMITH, DURKIN & DIETTERICK LLP BY:Jo~nn ly, j~ Post Office Box 650 Hershey, PA 17033 (717) 533-3280 PA I.D. No. 15615 VERIFICATION I verify that the statement made in this Income and Expense Statement are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom falsification to authorities. JEFFREY A. MCNELLY : PLAINTIFF : : V. LINDA R. MCNELLY : DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-3790 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, August 11, 2003 , upon cortsideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Monday, September 08, 2003 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effi)rt 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 TIlE COURT, By: /s/ Melissa P. Greevy. 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 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 TELEPltONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 170.13 Telephone (717) 249-3166 JEFFREY A. MCNELLY, Plaintiff V, LINDA R. MCNELLY, Defendant / OF COMMON PLEAS O1~ IN THE COURT CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3790 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY INTERIM ORDER OF COURT AND NOW, this / ~ ~ day of October, 2003, upon consideration of the attache( Custody Conciliation Summary Report, it is hereby ordered and directed as foliows: 1. Leqal Custody. The parties, Jeffrey A. McNelly and Linda R. McNelly, shal have shared legal custody of the minor child, Whitney E. McNelly, born May 18, 1987. Eac~ parent shall have an equal right, to be exercised jointly with the other parent, to make al major non-emergency decisions affecting the child's general well-being including, but no' limited to, all decisions regarding her health, education and religion. Pursuant to the term.. of Pa. C. S. §5309, each parent shall be entitled to all reco~rds and information pertaining t¢ the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent ha.. possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Mother shall have primary physical custody subject to Father's rights of partial custody which shall be arranged as follows: A. To commence October 14, 2003, one (1) evening per week from 5:00 p.m. to 8:00 p.m. Unless otherwise agreed, the visits shall occur on Tuesdays. B. To commence October 24, 2003, on alternating weekends from Friday at 6:30 p.m. until Sunday at 6:30 p.m. 3. Transportation. During Father's periods of custody, Father shall provide transportation as necessary for the child to social and extracurricular activities as well as her part time job. 4. By agreement of the parties, the child shall have a midnight curfew. 5. Father shall provide the child with a key to his apartment. NO. 03-3790 CIVIL TERM 6. Thanksqivin.q. For Thanksgiving in odd-numbered years, Mother will haw custody from the day before Thanksgiving after school until Thanksgiving Day at 3:00 p.m and Father will have custody from Thanksgiving Day at 3:00 p.m. through Friday at 6:31 p.m. In even-numbered years, Father will have custody from the day before Thanksgivin! after school until Thanksgiving Day at 3:00 p.m. and Mother will have custody fron Thanksgiving Day at 3:00 p.m. through Friday at 6:30 p.m. 7. Christmas. Christmas shall be divided into two segments, Segment A an( Segment B. Segment A shall be from December 24th at 9:00 a.m. until December 25 a~ 3:00 p.m. Segment B shall be from December 25th at 3:00 p.m. until December 26th at 6:361 p.m. In odd-numbered years, Mother will have Segment A and Father will have Segment B In even-numbered years, Father will have Segment A and Mother will have Segment B. 8. Other Holidays. For the holidays of Easter, Memorial Day, Independence Da~ and Labor Day, the parties shall share custodial time in accordance with the followin¢ schedule: In even-numbered years, Father will have custody for Easter and Independence Day and Mother will have custody for Memorial Day and Labor Day. In odd-numbered years, Mother will have custody for Easter and Independence Day and Father will have custody for Memorial Day and Labor Day. The custodial period for these holidays shall be from 6:00 p.m. the day before the holiday until 6:30 p.m. the day of the holiday. 9. It is noted that there is significant strain in the relation between the Father an the minor child. Therefore, Father and the child will enter therapeutic family counseling assist with the repair of their relationship. Father shall be responsible to n tiate contact withl a therapist, who, unless otherwise agreed, shall be Dr. Richard W ams The call to initiatel the counseling shall be made no later than the close of business on September 29, 2003.1 Father shall pay unreimbursed costs of the therapeutic family counseling to the extent that he and Whitney participate. However, in the event that the therapist believes that Mother should become involved in the counseling, Mother shall be responsible for unreimbursed fees associated with any session in which she participates. Dr. Williams will be provided with a copy of this Order by the Father. Any recommendations which Dr. Williams may have as to the physical custodial schedule should be included in a report to counsel. 10. Vacation. Each parent shall be entitled to two ,(2) weeks of vacation during the summer which shall be exercised consecutively or sepal'ately at the traveling parent's election, considering the child's scheduled activities and wishes, and shall include the parent's alternating weekend periods. NO. 03-3790 CIVIL TERM 11. A hearing is scheduled in C,,~:~rtroom Number 4 of the Cumberland Count~ Courthouse, on the /,,1~)'. day of ~, 2003, at /,'.30 o'cloc~ t~ .M, at which time testimony will be taken. For the purposes of the hearing, the Father Jeffrey A. McNelly, shall be deemed to be the moving party and shall proceed initially witl' testimony. Counsel for the parties or the parties pro se shall file with the Court an¢ opposing counsel/party a memorandum setting forth each party's position on custody, a lis' of witnesses who are expected to testify at the hearing, and a summary of the anticipate¢ testimony of each witness. These memoranda shall be filed at least ten days prior to the hearing date. Dist: BY THE COURT: /, ~,,ffShn J. Connelly, Jr., Esquire, P.O. Box 650, Hershey, PA 17033 ~,~amuel L. Andes, Esquire, P.O. Box 168, Lernoyne, PA 17043 JEFFREY A. MCNELLY, Plaintiff V. LINDA R. MCNELLY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA~ NO. 03-3790 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Whitney E. McNelly May 18, 1987 Mother 2. A Custody Conciliation Conference was held on September 29, 2003 ir response to Father's Complaint for Custody filed on August 5, 2003. Present for the conference were: the Father, Jeffrey A. McNelly, and his counsel, John J. Connelly, Jr. Esquire; the Mother, Linda R. McNelly, and her counsel, Samuel L. Andes, Esquire. 3. Father's position on custody is as follows: Father seeks an Order for a partia custody schedule because, despite language contained i,n a September 13, 2002 Ordel granting Father periods of partial custody, Father has not had contact with the child since around Spring of 2003. Father expressed concern that Mother is not taking the appropriate role in encouraging the relationship between the child and Father and may be playing a role in the estrangement between Father and the child. Father would agree to participate ir counseling with the child but would like contemporaneous implementation of a custodia Order. His counsel points out that there have been no allegations of imminent danger to th( child should an Order of partial custody be implemented. 4. Mother's position on custody is as follows: Mother believes that prior t( implementing any custodial Order that Father and the child should participate in counseling She believes that the child's preferences to attend social activities should be given mot( leeway than does Father. She reports the child did not have a good time during her visit., with Father. She also claims that Father has refused to give the child a key to thc apartment in the past and that for some of his custodial periods he was not present at all leaving the child alone in his apartment for hours at a time with nothing to do. Counsel fo Mother predicts that the child, if prematurely forced to comply with the Order, will likely resis NO. 05-3790 CIVIL TERM compliance which would then ultimately do more harm than good to the parent-child relationship. 5. The parties agreed on a custodial Order, but not on the issue of whether it should be implemented immediate y. Mother would not agree to the implementation of an Order until and unless it is endorsed by a counselor who would see the child and the Father and who would guide the implementation of the Order through ongoing therapeutic contact for a period of weeks. to the Court by the Conciliator. Melis,sa Peel Greevy, Esquire Custody Conciliator :219168 JEFFREY A. McNELLY, Plaintiff VS, LINDA R. McNELLY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-3790 CIVIL TERM IN CUSTODY PETITION FOR EMERGENCY RELIEF AND NOW comes the above-named Defendant, by her attorney, Samuel L. An( and petitions the court for emergency relief, based upon the following: 1. The moving party herein is the Defendant. The responding party herein is t Plaintiff. 2. This action involves the custody of the parties' minor daughter, Whitney E. McNelly, born 18 May 1987. The custody of the child is not contested or disputed, the terms of the Plaintiff's schedule of temporary custody with the child, and the implementation of such a schedule, is a matter of serious dispute between the partie~ 3. A conciliation conference was held in this matter before Melissa Greevy, Esquire, on 29 September 2003. A copy of the conciliator's report, and the interim of court entered on the basis of the conciliator's report and recommendation is attac hereto and marked as Exhibit A. 4. The conciliator inaccurately reported to the court that the parties had agree upon a schedule. Although the Plaintiff wanted a schedule for his periods of tempor~ custody with the child, the Defendant did not agree to the schedule but only indicate would agree to such a schedule if it could be implemented and approved with the guidance of a counselor for the child. The Defendant/Mother made her position cleal the conciliator that she did not want lengthy periods of temporary custody, including overnight periods, to commence until a counselor had the opportunity to work with ! Plaintiff and the child to introduce them to longer periods of custody. Les, 3e )ut der ~ed d ~ry she IO he I 5. The Mother's opposition to an immediate commencement of lengthy period~ of temporary custody is based upon difficulties between the child and the Plaintiff and tt~e child's refusal to spend lengthy periods of time with her father. The Mother believes :hat the only way to overcome that problem is with counseling and cooperation between he Father and the child with the guidance of a counselor. 6. The conciliator misinterpreted the clear intentions and statements of the M ther and her counsel and incorrectly determined that the Mother would agree to a schedul, and that the only question was when it would be implemented and when it would comme me. Mother made her position clear that she would not agree to a schedule without the guidance and approval of the counselor selected by the parties. 7. The Defendant believes that forcing the child to spend periods of time with her Father, including overnight periods, without the assistance of a counselor will do irreparable harm and that it will seriously damage the child's already-strained relation,' hip with her Father, will cause the child to defy her father and may cause the child to del y this court's order. 8. Defendant seeks the involvement of a counselor to organize, oversee, and control the developing relationship between the Plaintiff and the child and to take appropriate steps to see that the child's periods of temporary custody with her Fathe productive for all parties. WHEREFORE, Defendant prays this court to suspend its interim order of 13 O( 2003 and direct the parties to proceed immediately with counseling by Dr. Richard Williams and to give the Plaintiff such periods of temporary custody as Dr. Williams directs and organized. S'~mu~l L. Andes Attorney for Defendant Supreme Court: ID # 17225 525 North 12t~' Street Lemoyne, Pa 17043 (717) 761-5361 are :ober VERIFICATION I verify that the statements made in this document are true and correct. I understand that any false statements in this document are subject to the penalties of Pa. C.S. 4904 (unsworn falsification to authorities). LINDA R.'McNI~LLY ~ / 18 CERTIFICATE OF SERVICE I hereby certify that I served a copy of the foregoing document upon counsel f¢ the Plaintiff herein by regular mail, postage prepaid, addressed as follows: John J. Connelly, Jr., Esquire P.O. Box 650 Hershey, PA 17033 Date: 21 October 2003 Amy M. H~kins Secretary for Samuel L. Andes JEFFREY A. MCNELLY, Plaintiff V. LINDA R. MCNELLY, Defendant OCT 0§ 2O0 , IN THE COURT OF COMMON PLEA8 OF i CUMBERLAND COUNTY, PENNSYLVANI/~ NO. 03-3790 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY INTERIM ORDER OF COURI' AND NOW, this ~.'~'~ day of October, 2003, upon consideration o~f the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Le.qal Custody. The parties, Jeffrey A. McNelly and Linda R. McNelly, shall have shared legal custody of the minor child, Whitney E. McNelly, born May 18, 1987. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Mother shall have primary physical custody subject to Father's rights of partial custody which shall be arranged as follows: A. To commence October 14, 2003, one (1) evening per week from 5:00 p.m. to 8:00 p.m. Unless otherwise agreed, the visits shall occur on Tuesdays. B. To commence October 24, 2003, on alternating weekends from Friday at 6:30 p.m. until Sunday at 6:30 p.m. 3. Transportation. During Father's periods of custody, Father shall provide transportation as necessary for the child to social and extracurricular activities as well as her part time job. 4. By agreement of the parties, the child shall havre a midnight curfew. 5. Father shall provide the child with a key to his apartment. NO. 03-3790 CIVIL TERM 6. Thanksqivinq. For Thanksgiving in odd-numbered years, Mother will havr custody from the day before Thanksgiving after school until Thanksgiving Day at 3:00 p.m and Father will have custody from Thanksgiving Day at 3:00 p.m. through Friday at 6:3( p.m. In even-numbered years, Father will have custody from the day before Thanksgivin! after school until Thanksgiving Day at 3:00 p.m. and Mother will have custody fron Thanksgiving Day at 3:00 p.m. through Friday at 6:30 p.m. 7. ChriStmas. Christmas shall be divided into two segments, Segment A an( Segment B. Segment A shall be from December 24th at 9:00 a.m. until December 25 a 3:00 p.m. Segment B shall be from December 25th at 3:00 p.m. until December 26th at 6:3( p.m. In odd-numbered years, Mother will have Segment A and Father will have Segment B In even-numbered years, Father will have Segment A and Mother will have Segment B. 8. Other Holidays. For the holidays of Easter, Memorial Day, Independence Da~ and Labor Day, the parties shall share custodial time ir~ accordance with the followinc schedule: In even-numbered years, Father will have custody for Easter and Independence Day and Mother will have custody for Memorial Day and Labor Day. In odd-numbered years, Mother will have custody for Easter and Independence Day and Father will have custody for Memorial Day and Labor Day. The custodial period for these holidays shall be from 6:00 p.m. the day before the holiday until 6:30 p.m. the day of the holiday. 9. It is noted that there is significant strain in the relation between the Father a the minor child. Therefore, Father and the child will enter therapeutic family counseling tc assist with the repair of their relationship. Father shall be responsible to initiate contact with a therapist, who, unless otherwise agreed, shall be Dr. Richard Williams. The call to initiate the counseling shall be made no later than the close of business on September 29, 2003. Father shall pay unreimbursed costs of the therapeutic family counseling to the extent that he and Whitney participate. However, in the event that the therapist believes that Mother should become involved in the counseling, Mother shall be responsible for unreimbursed fees associated with any session in which she participate.,;. Dr. Williams will be provided with a copy of this Order by the Father. Any recommendations which Dr. Williams may have as to the physical custodial schedule should be included in a report to counsel. 10. Vacation. Each parent shall be entitled to two (2) weeks of vacation during the summer which shall be exercised consecutively or separately at the traveling parent's election, considering the child's scheduled activities and wishes, and shall include the parent's alternating weekend periods. NO. 03-3790 CIVIL TERM 11. A hearing is scheduled ir~k,,Courtrocjm Number 4 of the Cumberland C.ounty Courthouse, on the J~tl day of J_J~C~c~;~, 2003, at ~:,~O oclock ~3 .M, at which time testimony will be taken. For the purposes of the hearing, the Father, Jeffrey A. McNelly, shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties or the parties pro se shall file with the Court and opposing counsel/party a memorandum setting forth each party's position on custody, a st of witnesses who are expected to testify at the hearing, and a summary of the anticipated testimony of each witness. These memoranda shall be filed at least ten days prior to the hearing date. BY THE COURT: Dist: John J. Connelly, Jr., Esquire, P.O. Box 650, Hershey, PA 17033 Samuel L. Andes, Esquire, P.O. Box 168, Lemoyne, PA 17043 TRUE COPY FROM RECORD In Testimony whereof, I her~ unto set my hand and the setal of s~jid Court at.F..arJisJe, Pa. JEFFREY A. MCNELLY, Plaintiff V. LINDA R. MCNELLY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANI,~ NO. 03-3790 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child who is the subject of this litigation is as follows: NAME Whitney E. McNelly DATE OF BIRTH CURRENTLY IN THE CUSTODY OF May 18, 1987 Mother 2. A Custody Conciliation Conference was held on September 29, 2003 in response to Father's Complaint for Custody filed on August 5, 2003. Present for the conference were: the Father, Jeffrey A. McNelly, and his counsel, John J. Connelly, Jr., Esquire; the Mother, Linda R. McNelly, and her counsel, Samuel L. Andes, Esquire. 3. Father's position on custody is as follows: Fati~er seeks an Order for a partial custody schedule because, despite language contained in a September 13, 2002 Order granting Father periods of partial custody, Father has not had contact with the child since around Spring of 2003. Father expressed concern that Mother is not taking the appropriate role in encouraging the relationship between the child and Father and may be playing a role in the estrangement between Father and the child. Father would agree to participate in counseling with the child but would like contemporaneous implementation of a custodial Order. His counsel points out that there have been no allega~tions of imminent danger to the child should an Order of partial custody be implemented. 4. Mother's position on custody is as follows: Mother believes that prior to implementing any custodial Order that Father and the child should participate in counseling. She believes that the child's preferences to attend social activities should be given more leeway than does Father. She reports the child did not have a good time during her visits with Father. She also claims that Father has refused te give the child a key to the apartment in the past and that for some of his custodial periods he was not present at all, leaving the child alone in his apartment for hours at a time with nothing to do. Counsel for Mother predicts that the child, if prematurely forced to comply with the Order, will likely resist NO. 03-3790 CIVIL TERM compliance which would then ultimately do more harm than good to the parent-child relationship. 5. The parties agreed on a custodial Order, but not on the issue of whether it should be implemented immediately. Mother would not agree to the implementation of an Order until and unless it is endorsed by a counselor who would see the child and the Father and who would guide the implementation of the Order through ongoing therapeutic contact for a period of weeks. to the Court by the Conciliator. Melissa Peel Greevy, Esquire Custody Conciliator :219168 JEFFREY A. McNE VS, LINDA R. McNELL AND NOW t~ consideration of the scheduled in the ch. o'clock ~ .m. on Distribution: ~John J. Conn, P,O, Be v,Samuel L. An~ P,O. B LLY, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-3790 CIVIL TERM IN CUSTODY ORDER OF COURT is ~/ day of C'~c~'~.t.) , 2003, upon Defendant's Petition for Emergency Relief, a conference is hereby imbers of the undersigned, for counsel for both parties, for ~-' ~ '~')~.v/TZC:~(t~ the ,-~7~r/~ day of (/.~Z~7~-~/~_? 2( BY THE COURT, f / ,"lly, Jr., Esquire (Attorney for Plaintiff) x 650, Hershey, PA 17033 les, Esquire (Attorney for Defendant) )x 168, Lemoyne, PA 17043 JEFFREY A. MCNELi Plaintiff VS. LINDA R. MCNELL~ Defendant AND NOW, th chambers, the petition requested to use his el~ that both parents shoul ,,/J~ohn J. Connelly, Jr., ] For the Plaintiff i/Samuel L. Andes, Es~ For the Defendant :rim JY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-3790 CIVIL CIVIL ACTION - LAW IN CUSTODY ORDER day of October, 2003, following meeting with counsel in ['the defendant for emergency relief is DENIED. Dr. Williams is 6rts to implement the order of October 13, 2003, with the understanding :1 be guided by his input. ;,squire wire BY THE COURT, /~A. Hess, J. JEFFREY A. MCNELLY, Plaintiff VS. LINDA R. MCNELLY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-3790 CIVIL CIVIL ACTION - LAW IN CUSTODY ORDER AND NOW, this /2.*' day of December, 2003, hearing herein is continued generally to permit the parties the opportunity to resolve this matter amicably. The matter to be relisted at the request of counsel. BY THECOURT, ,/John J. Connelly, Jr., Esquire For the Plaintiff · ~Samuel L. Andes, Esquire For the Defendant :dm · Hess, J.