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HomeMy WebLinkAbout03-4033 v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003- <YoJ;] CIVIL TERM KAREN NEWELL and ROGER M. NEWELL, Plaintiffs JASON L. NEWELL and EMILY M. COPE, : IN CUSTODY Defendants COMPLAINT FOR CUSTODY 1. The plaintiffs are Karen and Roger L. Newell, residing at 31 Sheryl Drive, Newville, Cumberland County, Pennsylvania. 2. The defendants are Jason L. Newell, residing at 31 Sheryl Drive, Newville, Cumberland County, Pennsylvania, and Emily M. Cope, residing at 149 North East Street, Carlisle, Cumberland County, Pennsylvania, 3. Plaintiffs seek custody of the following children: ~ Present Residence Angel M. Newell 149 North East Street, Carlisle, PA Teresa L. Newell (Same) ~ 3 years 2 years The children were born out of wedlock. The children are presently in the custody of mother who resides at 149 North East Street, Carlisle, PA. During the past five years, the children have resided with the following person at the following addresses: Person Mother Address 149 North East Street, Carlisle, PA ~ 08/02/03- Present 10/10/01- 08/01/03 11/99- 1 0/09/01 Mother 152A West Penn Street, Carlisle, PA Mother 149 North East Street, Carlisle, PA The mother of the children is Emily M. Cope, currently residing at 149 North East Street, Carlisle, Pennsylvania. She is unmarried. The father of the children is Jason L. Newell, currently residing at 31 Sheryl Drive, Newville, Pennsylvania. He is unmarried. 4. The relationship of the plaintiffs to the children is that of paternal grandparents. The plaintiffs currently reside with the following persons: ~ Relationship Jason L. Newell Son 5. The relationship of the defendants to the children is that of biological parents. The defendant who is the biological father currently resides with the following persons: ~ Relationship Karen and Roger Newell Parents The defendant who is the biological mother currently resides with the following persons: ~ Relationship Angel and Teresa Newell subject children 6. Plaintiffs have not participated as parties or witnesses, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiffs have no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiffs do 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. 7. The parties agree the best interest and welfare of the children will be served by granting the relief requested because: a) Plaintiffs can provide the children with a home with adequate moral, emotional and physical surroundings as required to meet the children's needs; b) Plaintiffs are willing to accept custody of the children; c) Plaintiffs desire to exercise parental duties and enjoy the love and affection of the children. d) Defendants are in favor of this for their children until they can better provide for them in the near future. 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: ~ Address Basis of Claim NONE Wherefore, plaintiffs requests the court to grant them custody of the children. . .~4:Ja~(~ K1~J- ~dsay Dare B@;/j, Esquire 37 South Hanover Carlisle, PA 17013 Attorney for Plaintiffs I verify that to the best of my knowledge and belief, the statements in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 34904 relating to unsworn falsification to authorities, ~or...~) ~ >-)..)~_ Roger L. I'~ell, Plaintiff ~ /'17 - '?h ,~"*'u\"' Karen M. Newel, Plaintiff ~ J ~\\ ~ ~ -( 0 - - ).. I.' r ..f) ~ f'. - 'oJ j'-C ~; <i. - r ("; r:::: ( ,,~.; . J C~ 1::-. ,.-'-, (I I (J d KAREN M. NEWELL and ROGER L. NEWELL, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003- 4033 CIVIL TERM v. JASON L. NEWELL and EMILY M. COPE, : IN CUSTODY Defendants PETITION TO AMEND CAPTION Now comes the Plaintiffs, Karen M. Newell and Roger L. Newell, by and through their counsel, Lindsay Dare Baird, Esquire, and aver the following: 1. This custody action was filed August 18, 2003. 2. The Plaintiffs were incorrectly identified as Karen Newell and Roger M. Newell and seek to correct this error. WHEREFORE, The Plaintiffs respectfully request that the caption be amended as above written. I """" .,., \0 "" 'I'" 0' m, """"""go ",d b."1, '''' ,...._W " ." """,,'''' ",,"m"" ". W. "" ",,,,,,. I "",,,,,,,,, ,,,,, ",.. ,,,_,W """" ," mad' ",b,'" \0 '''' "'''',,''' ,,18 p,CS ,,904 "",II', \0 "",,,,m ",,_00 \0 ",."ml'" lai'- ~ ~ C) f;,:; " "'Of1') Sf19 2:( (/) "' -<;. k~c; P. ~(S~..; :::-:- - -< :" co <:> c..,) ~ c:: Ct'"'") '" N -0 ~. ~....... o -"1 h_! j;"lr:P ---,rn '? :>., , ,., ~.;:' ~:;? ifj :.;'-" :-1 ~ -, KAREN NEWELL and ROGER M. NEWELL, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003- 4033 . CIVIL TERM v. JASON L. NEWELL and EMILY M. COPE, : IN CUSTODY Defendants STIPULATION FOR CUSTOI)Y STIPULATION made this ;<2nrl day of (;;'h'Vl~f, 2003, between Karen Newell and Roger M. Newell known as paternal grandParents~M, COPE! and Jason L Newell, hereinafter referred to as parents. WHEREAS, the above-named parents had born to them the following children on the following dates: !'lAME Angel M. Newell Teresa L. Newell eIRTH DATE NIJvember 1 B, 1999 April 4, 2001 AND WHEREAS, the above-named biological parents desire to enter into a Stipulation as to the custody of the above-said children and to the partial custody rights of the non-custodial parents: NOW. THEREFORE, in order to effectuate the above purpose, the above-named biological parents hereby stipulate that: 1. The parties shall share legal custody of the childrEin. 2. The paternal grandparents shall have primary physical custody of the children. 3. The parents shall have periods of partial custody 13S agreed upon by the parties. TO THIS PURPOSE, The parties hereto intend to be leg911y bound by the terms of this Stipulation and desire to have the Stipulation entered as an Order of Court. f<...q---- Ird, Esquire fK~, m. '/Io,,1Jj Karen Newell, Paternal Grandmother "'-~3~ ~..."..\\ Roger L. ewell, Paternal Grandfather t:,~ ~. If)~~~~ ason L. NElwell, Father ~Ijt- ;Z~. EmilfM. C<Jpe, Mot er Witness: (') c $: :ym ~g:; Zr C/)) ~f K- ~C ;;;F .:::,..,.; -- --I -< C> (.J ;Do c:: ::;") N N o -" --i Pr'~p'Q :,~;8 ~'~5 cS ~-ri '-'-'n s:; t5 {j rTl ~ ~ -0 ::r: :.> CX) KAREN NEWELL AND ROGER M. NEWELL PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 03-4033 CIVIL ACTION LAW JASON L. NEWELL AND EMILY M, COPE DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, August 25, 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 Thursday, September 18, 2003 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 defme 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 hearin2. FOR THE COURT, By: Isl Jacqueline M. VerntO'. Esq. L 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 facilitks 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 32 South Bedford Stre,et Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 i -~~ ~ ~~~.l D;J'Ct'8- @ W <Z ;"t:l~V>1/ ~IL, D'J.(f'j. ~ f? '?!- ~t7:VlI-' ~ '-;m? w-Le.5 VlJ\I\f^1J-.SNN3d A.1.NnO'l "'!~"1'J=;8i^1no ~" -II i .'H '} "l'''i "0 01. I','i L~~...v AfiV.lCiJ., J...J>'!Jf,~ :10 :J8!,~AO">(]3lLj KAREN M, NEWELL and ROGER L. NEWELL, Plaintiffs : IN THE COUHT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2003- 40~i3 CIVIL TERM JASON L. NEWELL and EMILY M. COPE, Defendants : IN CUSTODY ORDER OF COURT AND NOW, this L 7 f ( day of f>. t..t.) , , 2003, upon consideration of the attached custody stipulation with respect to the children, tinge I M. Newell, born November 18, 1999, and Teresa L. Newell, born April 4, 2001, the terms of the stipulation are entered as an order of court. BY THE COURT, Lindsay Dare Baird, Esquire 37 South Hanover Street Carlisle, PA 17013 Attorney for Plaintiffs J. Jason L. Newell 31 Sheryl Drive Newville, PA 17241 ~ .~ 3'. J r~O-3 ~, Emily M. Cope 149 N. East Street Carlisle, PA 17013 \t1NVf\lASNN3d AINnO:) (ji',!l1:f38i1Vn:J is :2 \,!d 82 3flV SO AW10NOH1''':.:d _; 11 ~O 301:l~O-{13Id KAREN M. NEWELL and ROGER L. NEWELL, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2003- 4033 CIVIL TERM JASON L. NEWELL and EMILY M. COPE, : IN CUSTODY Defendants ORDER OF COURT AND NOW, this -4- day of ~, 2003, the caption in this matter is amended as above to reflect the correct middle initials of the Plaintiffs. By the Court, Cc: Lindsay Dare Baird, Esquire For the Plaintiffs Jason L. Newell Defendant ~ ~ ~. ,),1'.03 0.. Emily M. Cope Defendant VI!\i'\f^lASNN3d AJNnOJ C";\il838V'1n:) i I;; :Z ~IJ 9 Z :JflV 80 AtNlUi<0tiJ:JU.: li .:lO 3::JI~j(}-{ElII:J SEP U 9 2003 ~ KAREN NEWELL and ROGER M. NEWELL, : IN THE COURT OF COMMON PLEAS OF Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2003-4033 CIVIL TERM JASON L. NEWELL and EMILY M. COPE, : CIVIL ACTION - LAW Defendants : IN CUSTODY ORDER OF COURT AND NOW, this 8th day of September, 2003, the Conciliator being advised that the parties have signed a stipulation, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, /_.{ fk Conciliator 0 0 CJ C C,j -'-l < ':/1 ~p ;-"'~I -, [~,: , T) .-., (JJ ~ ~: ;:+1 -.. -c- (j-~ L~ .~-~ ( ) j;: :~5rn l ~~ ""--. :0 OJ -< KAREN M. NEWELL and ROGER L. NEWELL, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2003- 4033 CIVIL TERM JASON L. NEWELL and EMILY M. COPE (now NEWELL), Defendants : IN CUSTODY STIPULATION FOR CUSTODY STIPULATION made this ~ day of t)cJd 0eA-. ,2004, between Karen M. Newell and Roger L. Newell known asg;:andparents, and Emily M. Cope, now NI~well, and Jason L Newell, hereinafter referred to as parents. WHEREAS, the above-named parents had born to them the followin!~ children on the following dates: NAME BIRTH DATE Angel M. Newell November 18, 1999 Teresa L. Newell April 4, 2001 AND WHEREAS, the above-named grandparents and parents desirE~ to enter into a Stipulation as to the custody of the above-said children: NOW, THEREFORE, in order to effectuate the above purpose, the above-named grandparents and parents hereby stipulate that: 1. The parents shall have legal custody of the children, 2. The parents shall have primary physical custody of the chilldren. 3. The grandparents shall have periods of partial custody eVElry other weekend and other times as agreed upon by the parties. 4. The parents shall not relocate out of state with the children. TO THIS PURPOSE, The parties hereto intend to be legally bound by the terms of this Stipulation and desire to have the Stipulation entered as an Order of Court. I "~WJ~" -~I} Karen Newell, Grandmother ~::I~~~ ~~7 ason L. New~lI, Father C~ n~/ Emily M. (Cope) Newell, Mother Witness: ,....~.) ',~.~:'.') C:O) .J~- C':) (""J .;ch :-J -I f',) -1~1 (."~' r'-.:' Cq KAREN M. NEWELL and ROGER L. NEWELL, Plaintiffs : IN THE COUHT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA o v. : NO. 2003- 40:~3 CIVIL TERM JASON L. NEWELL and EMILY M. COPE, : IN CUSTODY Defendants ORDER OF COURT AND NOW, this '2 ar Ii day of b t:..- t. , 2004, upon consideration of the attached custody stipulation with respect to the children, Angel M. Newell, born November 18,1999, and Teresa L. Newell, born April 4, 2001, the terms ofthe stipulation are entered as an order of court. BY THE COUR:T, ~say Dare Baird, Esquire 37 South Hanover Street Carlisle, PA 17013 Attorney for Plaintiffs ~al J. .) ~) //-0/-01 ~son L. Newell 31 Sheryl Drive Newville, PA 17241 vEmily M. Cope 3' -5 It. -+'1"11 1J~ v"L ~11/( pfi'J /7,)<1/ V!N'vi\lASNN3d I Ildnor'\ (1' ,.,)"1~-;"'^Jnf\ I\JJ" -.. ....} -__' '.; ~f ;".):::J I" \wi 92 :2 Wd 62 130 ~OOZ I' l\.J10"';'\Uj 0' 'd "'1H' '0 AD\i j,'~i,Jn_ C' :1 1 :l 381::!::lQ-03l!:l KAREN M. NEWELL and ROGER L. NEWELL, Plaintiffs/Petitioners v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003- 4033 CIVIL TERM JASON L. NEWELL and EMILY M. (COPE) NEWELL, Defendants/Respondents : IN CUSTODY PETITION TO MODIFY CUSTODY ORDER 1. The petitioners are Karen M. and Roger L. Newell, Paternal Grandparents, residing at 31 Sheryl Drive, Newville, Cumberland County, Pennsylvania. 2. The respondents are Jason L. Newell, Father, residing at Cumberland County Prison, 1101 Claremont Road, Carlisle, Pennsylvania, and Emily M. (Cope) Newell, Mother, residing at 22 West Baltimore Avenue, Apt 2, Carlisle, Pennsylvania. . 3. A Custody Order was entered upon stipulation of the parties regarding the children Angel M. Newell (age 5) and Teresa L. Newell (age 4) on October 29, 2004 and is attached and marked as exhibit A. 4. The parties are not consistently able to agree on time,s that the grandparents may enjoy custody of the children and on whether or not the children may visit with Father at CCP. WHEREFORE, Petitioners request the court grant the ~lrandparents periods of partial custody every other weekend to include the following Monday should it be a holiday, one day during each week, specific time over Christmas, one week's vacation during the summer and at such other times as the parties may agree. Petitioners also request that they be able to have the children accompany them to visit Father one day in a month. In all other respects, the petitioners request the order remain the same. Respectfully submitted, I verify that to the best of my knowledge and belief, the statements in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS ~4904 relating to unsworn falsification to authorities. /)(~?Y\. :1\~ Karen M. Newell I verify that to the best of my knowledge and belief, the statements in the foregoing document are true and correct. I understand that false statements herein rare made subject to the penalties of 18 PaCS ~904 relating to unsworn falsification to authorities, ~~~ Roger L~ewell ~ ~ ~ Jr (\ ~~ - (i' ......... 0 ~ cr- <"\ --C. -...() \ ~ ~ o ~;~ '. ~>. =2 "" <= c."':::I 0 en .,., ~ :;j f":::.: fl;:!1 -e,r:;:; \D ;3? ---/('"-, :y :r .:;(i -:.: Q-r) c::. (') ,::jm ;g .1) ..< r:;> CJ1 -.J ~ KAREN M. NEWELL AND ROGER L. NEWELL IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYL VANIA V. 03-4033 CIVIL ACTION LA W JASON L NEWELL AND EMILY M. (COPE) NEWELL IN CUSTODY DEFENDANT ORDER OF COURT AND NOW. Friday, July 22, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the coneiliator, at 4th Floor, Cumberland Couuty Courthouse, Carlisle on Tuesday, Au!:ust 30, 2005 at 2:30 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 existinl: Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearin!:. FOR THE COURT. By: Isl Tacqueline M Vel71ey, Esq. Custody Concili ator yJYl The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 . p ~f' .... ~ ~ 5os....L @ 1'1"7" ~ ~ 0#'-'1 50 S'e- f... ~ ~ ~ ~.~ -P9 5(J..5'(>_{.. ~ H\ii;(',. :.., , ~';~ '=-:/,,:n8 /".u-;, " L S : I lid SZ -irlrsooz "" '" ,,', " ",i C1i..ll:lO At] '? J..lI; -'J-,...h l,;..',)~-":: ::II :-CJ!1::>OcJl!,1 KAREN NEWELL AND ROGER M, NEWELL, Plaintiffs/Respondents : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : 03-4033 CIVIL ACTION LAW JASON 1. NEWELL AND EMILY M. NEWELL, DefendantslPetitioner : IN CUSTODY PETITION TO MODIFY CUSTODY ORDER I. DefendantlPetitioner, Emily M. Newell, by and through her counsel, the Family Law Clinic, respectfully represents that on October 29, 2005 an Order of Court was entered upon stipulation of the parties for custody of Angel M. Newell (age 5) and Teresa 1. Newell (age 4), a true and correct copy of which is attached as Exhibit A. 2. Under the existing order, Defendants have primalY legal and physical custody of the children. Plaintiffs have periods of partial custody every other weekend and other times as agreed upon by the parties. 3. This Order should be modified because the Petitioner/Defendant avers the following: a, Defendants, Jason 1. Newell and Emily M. Newell, have been separated and living apart since November 2003. b. The Defendant, Jason 1. Newell, is currently incarcerated at the Cumberland County Prison. c. DefendantlPetitioner, Emily M. Newell (hereinafter "Mother"), has been the primary caretaker of the children sincf: October 2004. d. Mother is capable of meeting the children's needs. e. Mother is willing to encourage and support an ongoing relationship between the children and their grandparents. WHEREFORE, Petitioner asks that the Court modifY thf: existing Order for Custody, granting Petitioner, Emily 1. Newell, primary physical custody Oind sole legal custody and allowing Plaintiff /Respondent periods of partial physical custody, as it will be in the best interests of the children. Respectfully submitted, Date FJ!lk(Cb ~/JJJ {Nrv/J{L ~IJ. PLACE ROBERT RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me tot he penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. Date ~l/c lor ~. /U'() Emily M. Newell, Petitioner/Defendant r\ -':'\ \ '-\:7 .....< Q ~"~ r':" I' ',' ," ' ' s?, .;;:;:;1 <f' ~ c:.- G") - c:P r- :;1;: - S' c ~:. ~,.y /~-, --) ~ q, '1- (11~ "'oCJ :J'-( (),o 7~':D C'Y'?f, ("5 ..4 .~ "0 ;~ l'-' s:- ..' T ....,oJ. $,.... 'vI/, f.ct" ,." 1.:1..it 'i" . 4: !lit., J ~J?, If ;;;r'!l!t I. .MO:_ i...7~ "'~~ ,...~ CfJ.,C":: f!. . Ofj ~~"'O'" '-....bj, ~ Ii ~!p/ .0.." rfl~ '''. -1'1l1p. '''.n :::;:~ .".11 ~ , !?C, , ""'e If 4) ?t/fle, r'.liaIt f ~ , ~ ~ .............. $Ii, --- ~ KAREN M. NEWELL. and ROGER L. NEWELL. PIaIntiff8 v. JASON L. NEWELl. and EMILY M. COPE. Defandants . . : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA . . : NO. 2003- 4033 CIVIL TERM . , : IN CUSTODY ORDER OF COURT ~ ((O"~)\~, ':::::Y1f:- AND NOW, thill '2..' Ii.. day of ~, 2004. upon consideration of the attached cuatody I!Itipulatlon with respect: to the chlldren, Angel M. NeweR. born November 18.1999, and Teresa L. NeweR, bom AprR 4. 2001, the termsofthe stipulation are entered 88 an order of court. BY THE COURT, rJ/-to;( . J. &ley Dare Baird. Esquire 37 South Hanover Street Cartlsle, PA 17013 Attomey for Plalnllff$ ~n L. Newell 31 Sheryl Drive Ne\WIne, PA 11241 ~I\y M. Cope ~I :5J........, I b.-tV'(. ~11( I'M 11.,01// .) ~ 1/-0/-01 ..... ..,~ .,." .~~ .....,.-l 1.1: ~ J";' 3. J"~ ~ 1b 9;l;~ ~f~""~ 4tj ~ V".,C:(I.fA.. ~..~. 8~:' - "'"""\ . . KAREN M. NEWELL and ROGER L.. NEWELL, Plaintltf8 : IN THE COUR"r OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA c v. . . : NO. 2003- 403:3 CIVIL TERM JASON L" NEWELL and EMILY M. COPE. . : IN CUSTODY Defendants I ( \. ,._-..... ORDER OF COURT ~ (Q) /fi;~> AND NOW, thi8~dayof~, 2004, ~Ipon consideration of the attached custody stipulation with respect to the children, ,Angel M. Newell, born November 18.1999, and Teresa L. Newell, bom April 4, :2001, the termsofthe stlpulatlon are entered ae an order of court. BY THE COURT, J. J o:t::htsay Dare Baird, Esquire 37 South Hanover Street Carlisle, PA 17013 Attorney for Plaln1tff$ ~80n L. Newell 31 Sheryl Drive Newville, PA 11241 ~11y M. Cope ~I .5t....."'1 I b-t v"c. ~11( 1'/11 /'1"~1 ) ~) 11-01-0 ~I . . KAREN M, Ne;,WEL.1.. Ind ROGER L., NEWELL, PI8.intilf'll : 111I THE COURT OF COMMOi'l PLEAS OF : CUMBeRLANO COUNTY. PENNSYLVANIA v. , , : ""'0, 20~- 4033 eM L TERM JASON L. Nf1III'I::LL .Il:t EMILY M, COP!:. (r'IO\II NEWEIJ.). O~I'ld.nts STIPUL.All0N FOR OUSTODY S11P\JL.ATION rn.,cle !fllI --'!11h. d.., of tJr:./4 ~_, 2004, tleMrtiln KIII'II'I fit, Newelllnd Flog.r l., NItWeIl known u ~5rMm, and Emty M. copoe. now Newell, and Juon L. Nawll, t1l1l'Oinafl.r ,.r.rtd to II pIIfTilnll. , , : It.! CUSTODY WHERE.lB, fha lIIbow./Vlmd p.III'8nll hllod ban ta thlllrllh/l fOlfowlng children on h fallowlng dalell; NAME B!RiI-l CATF Angel M, Ne'w&1 No....." tier 19, 1"'9 TlIl'eu L. NlIwl ~rI1 4, ~1l01 AN'D W'tI!IlI!M, fhllbowl-narn,d grantlpiir'tntl .1100 pllNlr'1tS aellll'tl ta llr0t8r Into . BIll'ullU~n _10 thll autlogy "" th. ab~11Id chlldl'll'l: NOW. T'Hll:lIl.l!"O~!, In on:Nir la IfIectu."lhtl lbovtl purpoM, Ihlt ..I,~nameod gr.andlll',.ntI and p8ren!l fwl'llb)ll'lipulile !hilt 1, The s:l1iUt~ 8r,eUI\IlvlJ IlI!ilal ouad)' atth. children, 2. Th. parer\t$ 'h.lllf f1a.... primary ph)'llcl\ CUll.ody 01 tn. ahllclren. 3. The gl1lnaplllW1~ ,hill haw pel10dt of !)t1l1,1 cutl{Od~ ......'Y ether w.e~n.d and othIr 11m. a. IIlI1R Upl:l'l'l b>' thliP pllti... 4, TIwl ~rll'lfll .hlll no! reloCllm oul af I'IIM wtIh the; t:I11ldren, 10 TH1& PURPOSE, Tho partin hlImeJ inlen<:l. to 1)$1(t(l1ll1l~ llQund ll)' :tn.I.rm, ofthl' ItlPUIlt\on ,nt:l dM111I to hlVIIIhI BtIl'uldDn .nll~d U In Crtllr elf Court. ,.' ~ i((U1'..t... - KElrer'l Newell. Grandmotl\er ~~~.~ Roger ,Newell, Grandfather ~4~~/ on L.. Newell. father .-..~ 5.mlly M.~ NIW811, Mother d . squire ka.d .t'JId KAREN NEWELL AND ROGER M. NEWELL, Plaintiffs/Respondents : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : 03-4033 CIVIL ACTION LAW JASON 1. NEWELL AND EMIL Y M. NEWELL, Defendants/Petitioner : IN CUSTODY CERTIFICATE OF SERVIC]~ I, Rene M. Gornall, hereby certify that on the 18th day of August, 2005, I served a true and correct copy of the Petition to Modify Custody Ordf:r filed August I8, 2005 by hand delivering same to the Defendant, Jason 1. Newell, at the Cumberland County Prison, 1101 Claremont Road, Carlisle, PA 17013. Date: August 19,2005 '~~/ ~.--'~. ~// , ---..- .--'----. "-'" e 11:' Gornall ertified Legal Inte FAMILY LAW CLINIC 45 North Pitt Street Carlisle, JP A 17013 0 "." 0 = c: = -., "-" .. :r! -'-"" ". \:..~ (,:' c:: :rJ n: f~ "'r:;:; ~:f C'') ",.. , ;'~6 ~) U) '. --, -1' ... -0 T-iJ ('^ .....,'~ t_;;('') ~:.:- " -"- -:.-m ;to: .... U ~~ ...... :"::j 0 13 "'. -< ..... ...>c."""" ,..,'C'" - KAREN NEWELL AND ROGER M, NEWELL PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 03-4033 CIVIL ACTION LAW JASON L. NEWELL AND EMILY M, NEWELL IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, VVednesday,August24,2005 , 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 Thursday, September I5, 2005 at 10:30 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 hearing. FOR THE COURT. By: Isl lacqueline M. Verney. Esq.Y Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Aet 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 32 South Bedford Street Carlisle. Pennsylvania 17013 Telephone (717) 249-3166 .~ ~ ~;~~ 5C?~t> ~~-.~ ~ ~ A}J'&..v ~jL, 5?/'k$ . . 7 ';;f :? ~ ~ Y'17 Jr? SC"'p VII~VtilASNfHd I 'f 'n,~.'; n' "r. ,-q;f!,!iJ .1\.1.\11\..."'" ",' " ." tj S :8 fJd SZ 80V SOuZ At.NIO~,OHlCdd 3H1 :l0 3JI;J::1Cr0311::J KAREN NEWELL AND ROGER M. NEWELL, PlaintiffslRespondents : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : 03-4033 CIVIL ACTION LAW JASON 1. NEWELL AND EMILY M. NEWELL, DefendantslPetitioner : IN CUSTODY CERTIFICATE OF SERVICE I, Rene M. Gornall, hereby certify that I served a true and correct copy of the Order of Court, dated August 24, 2005, on Jason Newell, at 31 Sheryl Drive, Newville, Pennsylvania, 17421, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested on September 2, 2005. Service was complete upon receipt by Jason Newell on September 6, 2005, as evidenced by the attached green card. e M. rtifie Legal Intern Date: September 13, 2005 F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PAl 70 13 SENDER COMPLETE THIS SECTION COMPLETE THIS SECTION ON DELIVERY . Complete items 1, 2, and 3. Also complete il1lm 4 ~ Restricted Delivery Is desired. . Print your name and address on the reverse 80 that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front If space pennits. 1. ArtIcle Addressed to: To.'::>un Newell :Sl Shu''1 \ Dr\\Je ;,~zw\!\\\e\ 7r~ \lc:JY\ :....... A. Signature ClAgen! X Cl Add.._ c. ,te of Delivery -{,-cS c, D. Is delIvery address different from Item 1? 0 Yes If YES, enter delivery address below: 0 No '" 3. Selv)<:e Type iia' CertIfIed Mall Cl "- Mall o Registered t:lJ1!fetum Recelpt for Merchandlee o Insured Mall 0 C.O.D. 4. Restricted Delivery? (Extra Fee) as z. 7005 0390 0003 2632 4778 I . PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 C) -n :;~. i-I'" e, ..~- 0', r.f' , ", , cr, ~E.CEIVED SEP 191005 t/ KAREN NEWELL and ROGER M. NEWELL, PIaintiffs V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003-4033 CIVIL TERM JASON L. NEWELL and EMILY M. NEWELL, Defendants : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this MiL day of ~ rn 1. , 2005, upon consideration of the attached Custody Conciliation Report, It tS ordered and dtrected as follows: 1. The prior Order of Court dated October 29, 2004 is hereby vacated. 2, The Mother, Emily M. Newell and the Father, Jason 1. Newell shall have shared legal custody of Angel M. Newell, born November 18, 1999 and Teresa 1. Newell, born April 4, 2001. 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. 4. custody: Paternal Grandparents shall have the following periods of partial physical A. Alternating weekends, from Saturday at 9:00-10:00 a.m. to Sunday at 7:00-7:30 p.m. In the event that the grandparents' weekend coincides with a Monday holiday, their weekend shall extend to Monday at 12:00 noon. B. Every Wednesday from 9:30 a.m. to 11 :00 a.m., unless the children are attending school. C. One week in the summer provided they give parents 30 days prior notice. D. Time at Christmas which will coincide with Father's partial physical custody at Christmas. Mother may provide another day during the Christmas break from school when Grandmother is not working. 5. Father shall have periods of partial physical custody as follows: ~ b l.1Jz 9q U...-f '-'-f':: ~@ ::':lD... a: if \5 r- U"'> ::i: ...: ('oJ 0... W (/) ..... = ~ i=- S,S: (~:~~~ ~ "'(.1.' ~', ':7 -;~ ~:~ ::~7t ':5 (.) - A. While he is living with paternal grandparents, one Saturday per month at times agreed by the grandparents and F ather during the periods that grandparents have partial physical custody. B. When Father obtains his own housing, one Saturday per month at times agreed by the grandparents and Father during the periods that grandparents have partial physical custody, provided Grandparents supply Mother with photographs of Father's home and the condition is satisfactory to Mother. Father shall have two such Saturdays of custody before going to overnights. C. One Saturday overnight per month at times agreed by the grandparents and Father during Grandparents' periods of partial physical custody. In the event Mother has no plans for one of her weekends per month, she may offer Father an additional weekend per month. 6. Thanksgiving shall be shared and alternated. Father shall have physical custody of the children from 9:00 a.m. to 3:00 p.m. in odd numbered years and 3:00 p.m. to 9:00 p.m. in even numbered years. Mother shall have physical custody of the children from 9:00 a.m. to 3:00 p.m. in even numbered years and 3:00 p.m. to 9:00 p.m. in odd numbered years. 7. Christmas shall be divided into two Blocks. Block A shall run from Christmas Eve at 12:00 noon to Christmas Day at I2:00 noon and Block B shall run from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. 8. Mother shall have physical custody of the children on Mother's Day. Father shall have physical custody ofthe children on Father's Day. 9, Easter shall be shared and alternated. Mother shall have physical custody of the children from 9:00 a.m. to 3:00 p.m. in even numbered years and from 3:00 p.m. to 9:00 p.m. in odd numbered years. Father shall have physical custody of the children from 9:00 a.m. to 3:00 p.m. in odd numbered years and from 3:00 p.m. to 9:00 p.m. in even numbered years. 10. Mother and Father shall alternate Memorial Day, July 4th and Labor Day with Mother having Memorial Day 2006, except that ifthe Monday holiday coincides with the grandparents' weekend, the grandparents shall return the children at 12:00 noon to the parent entitled to exercise physical custody pursuant to this paragraph. 11. agreed. Grandparents shall be responsible for all transportation unless otherwise 12. No party may partake in intoxicating alcohol to the point of intoxication or illegal drug use immediately before and during their periods of physical custody. 13. The parties shall enjoy reasonable telephone contact with the children. 14. No party shall do or say anything or permit any other person to say or do anything that may estrange the children from the other party, injure the opinion of the children as to the other party, or hamper the free and natural development of the children's love and respect for the other party. 15. 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. Any party may contact the Conciliator to schedule another Conference before December 31, 2005. BY THE COURT, J. cc~ndsay D. Baird, Esquire, Counsel for Paternal Grandparents ..Kene M. Gornall, certified legal intern, Counsel for Mother Lucy Johnston-Walsh, Esquire, Family Law Clinic vE. Ralph Godfrey, Esquire, Counsel for Father yo~ ~ O~d-\ ' KAREN NEWELL and ROGER M. NEWELL, Plaintiffs V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 2003-4033 CIVIL TERM JASON L. NEWELL and EMILY: CIVIL ACTION - LAW M. NEWELL, Defendants : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., 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 subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Angel M. Newell Teresa 1. Newell November I8, I999 April 4, 2001 Mother Mother 2. A Conciliation Conference was held in this matter on September 15, 2005, with the following individuals in attendance: The paternal grandparents, Karen Newell and Roger M. Newell, with their counsel, Lindsay D. Baird, Esquire, Mother, Emily M. Newell, with her counsel, Rene M. Gornall, certified legal intern, Lucy Johnston-Walsh, Esquire, Family Law Clinic, and Father, Jason 1. Newell, with his counsel, E. Ralph Godfrey, Esquire. 3. A prior Order of Court dated October 29,2004 was entered by the Honorable 1. Wesley Oler, Jr. Said Order provided for shared legal and physical custody for the parents with the paternal grandparents having alternating weekends. 4. The parties agreed to the entry of an Order in the form as attached. q-/&-06 Date .~~[.~~/ 6'acq line M. Verney, Esquire Custody Conciliator K ~ C ~ I V ED MAR 0 8 L Y KAREN NEWELL and ROGER M. NEWELL, Plaintiffs V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 2003-4033 CIVIL ACTION - LAW JASON L. NEWELL and EMILY M. NEWELL Defendants : IN CUSTODY ORDER OF COURT AND NOW, this 8th day of March, 2006, not being contacted before December 31,2005 to schedule another conference, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, M. Verney, Esquire, Custody Conci . tor KAREN M. NEWELL and ROGER L. NEWELL, Pia intiffs/Petitione rs v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003- 4033 CIVIL TERM JASON L. NEWELL and EMILY M. (COPE) NEWELL, Defendants/Respondents : IN CUSTODY PETITION TO MODIFY CUSTODY ORDER AND TO KEEP CHILDREN IN PENNSYLVANIA 1. The petitioners are Karen M. Newell, Paternal Grandmother, residing at 31 Sheryl Drive, Newville, Cumberland County, Pennsylvania and Jason L. Newell, Father, residing at 429 Potato Road, Carlisle, Pennsylvania. 2. The respondent is Emily M. (Cope) Newell, Mother, residing at 149 North East Street, Carlisle, Pennsylvania. 3. A Custody Order was entered upon stipulation of the parties regarding the children Angel M. Newell (age 5) and Teresa L. Newell (age 4) on October 29, 2004 and is attached and marked as Exhibit A. It provided, inter alia, that the parents were not to relocate with the children out of state. 4. On July 19, 2005, Plaintiffs petitioned to modify the order as to times of partial custody. In all other respects, they requested the order remain the same. 5. A Custody Order was entered on September 20, 2005, following a conciliation. The paragraph concerning relocation out of state was inadvertently left out. Order attached and marked Exhibit B. 6. Mother is making plans to move to Oklahoma. WHEREFORE, Petitioners request the court modify the current order to include the prohibition of moving the children out of state and to not allow Mother to take the children out of state as she is planning. Respectfully submitted, ): (/~- l/I("";' c;- ..Lindsay Dare ird, Esquire '/ 37 South Hanover Carlisle, PA 17013 (717) 243-5732 Attorney for Petitioners 'l )t: ,eY I verify that to the best of my knowledge and belief, the statements in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 34904 relating to unsworn falsification to authorities. 'j/ J)~ '1c\, II"L"& Karen M. Newell, Petitioner I verify that to the best of my knowledge and belief, the statements in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 34904 relating to unsworn falsification to authorities. Cf~ ason L. Newell, Petitioner OCl 2 5 7D04 f:: KAREN M. NEWELL and ROGER L NEWELL, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2003- 4033 CIVIL TERM JASON L NEWELL and EMILYM. COPE, : IN CUSTODY Defendants ORDER OF COURT AND NOW, this ,~9fh day of ([).d. ' , 20ot, upon consideration of the attached custody stipulation with respect to the children, Angel M. Newell, born November 18,1999, and Teresa L. Newell, born April 4, 2001, the tenns ofthe stipulation are entered as an order of court. BY THE COURT, Lindsay Dare Baird, Esquire 37 South Hanover Street Carlisle, PA 17013 Attorney for Plaintiffs Jason L. Newell 31 Sheryl Drive Newville, PA 17241 Emily M. Cope 31 Sheryl Drive Newville, PA 17241 EXHIBIT "A" KAREN M. NEWELL and ROGER L. NEWELL, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2003- 4033 CIVIL TERM JASON L. NEWELL and EMILY M. COPE (now NEWELL), Defendants : IN CUSTODY STIPULATION FOR CUSTODY STIPULATION made this i"i~ day of (e/t llxL ,2004, between Karen M. Newell and Roger L. Newell known as gran parents, and Emily M. Cope, now Newell, and Jason L Newell, hereinafter referred to as parents. WHEREAS, the above-named parents had born to them the following children on the following dates: NAME BIRTH DATE Angel M. Newell November 18, 1999 Teresa L. Newell April 4, 2001 AND WHEREAS, the above-named grandparents and parents desire to enter into a Stipulation as to the custody of the above-said children: NOW, THEREFORE, in order to effectuate the above purpose, the above-named grandparents and parents hereby stipulate that: 1. The parents shall have legal custody of the children. 2. The parents shall have primary physical custody of the children. 3. The grandparents shall have periods of partial custody every other weekend and other times as agreed upon by the parties. 4. The parents shall not relocate out of state with the children. TO THIS PURPOSE, The parties hereto intend to be legally bound by the terms of this Stipulation and desire to have the Stipulation entered as an Order of Court. ~~tv/i (..Ki:,af //f'ndSay D. ~, Itsqu~re C);.J Ie <<-t/ i\ . . . " )1 \ (J-,-....."'!/\ f'~'&./"./',_.A:./' Karen Newell, Grandmother ~ "-L"" .~":-. ~ '" '~"~ Roger . Newell, Grandfather ~~ ason L. Newell, Father ?M~ Emily M, (Cope) Newell, Mother Witness: ----~..........., )RECEIVED SEP 19 2fi95 KAREN NEWELL and ROGER M. NEWELL, Plaintiffs V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003-4033 CIVIL TERM JASON L. NEWELL and EMILY M. NEWELL, Defendants : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this m~ day of L1J .2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated October 29, 2004 is hereby vacated. 2. The Mother, Emily M. Newell and the Father, Jason L. Newell shall have shared legal custody of Angel M. Newell, born November 18, 1999 and Teresa L. Newell, born April 4, 2001. 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. 4. custody: Paternal Grandparents shall have the following periods of partial physical A. Alternating weekends, from Saturday at 9:00-10:00 a.m. to Sunday at 7:00-7:30 p.m. In the event that the grandparents' weekend coincides with a Monday holiday. their weekend shall extend to Monday at 12:00 noon. B. Every Wednesday from 9:30 a.m, to 11 :00 a.m.. unless the children are attending school. C. One week in the summer provided they give parents 30 days prior notice, D. Time at Christmas which will coincide with Father's partial physical custody at Christmas. Mother may provide another day during the Christmas break from school when Grandmother is not working. 5. Father shall have periods of partial physical custody as follows: EXHIBIT"B" A. While he is living with paternal grandparents, one Saturday per month at times agreed by the grandparents and Father during the periods that grandparents have partial physical custody. B. When Father obtains his 0"111 housing, one Saturday per month at times agreed by the grandparents and Father during the periods that grandparents have partial physical custody, provided Grandparents supply Mother with photographs of Father's home and the condition is satisfactory to Mother. Father shall have two such Saturdays of custody before going to overnights. C. One Saturday overnight per month at times agreed by the grandparents and Father during Grandparents' periods of partial physical custody. In the event Mother has no plans for one of her weekends per month, she may offer Father an additional weekend per month. 6. Thanksgiving shall be shared and alternated, Father shall have physical custody of the children from 9;00 a.m. to 3:00 p.m. in odd numbered years and 3:00 p.m. to 9;00 p.m. in even numbered years. Mother shall have physical custody of the children from 9:00 a.m. to 3:00 p.m. in even numbered years and 3:00 p.m. to 9:00 p.m. in odd numbered years. 7. Christmas shall be divided into two Blocks. Block A shall run from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon and Block B shall run from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. 8. Mother shall have physical custody of the children on Mother's Day. Father shall have physical custody ofthe children on Father's Day. 9. Easter shall be shared and alternated. Mother shall have physical custody of the children from 9:00 a.m. to 3:00 p,m. in even numbered years and from 3:00 p.m. to 9:00 p.m. in odd numbered years, Father shall have physical custody of the children from 9:00 a.m. to 3:00 p.m. in odd numbered years and from 3;00 p.m. to 9:00 p.m. in even numbered years. 10. Mother and Father shall alternate Memorial Day, July 4th and Labor Day with Mother having Memorial Day 2006, except that if the Monday holiday coincides with the grandparents' weekend, the grandparents shall return the children at 12:00 noon to the parent entitled to exercise physical custody pursuant to this paragraph. II. agreed. Grandparents shall be responsible for all transportation unless otherwise 12. No party may partake in intoxicating alcohol to the point of intoxication or illegal drug use immediately before and during their periods of physical custody. 13. The parties shall enjoy reasonable telephone contact with the children. 14. No party shall do or say anything or permit any other person to say or do anything that may estrange the children from the other party, injure the opinion of the children as to the other party, or hamper the free and natural development of the children's love and respect for the other party. 15. 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. Any party may contact the Conciliator to schedule another Conference before December 31, 2005. BY THE COURT, cc: Lindsay D. Baird, Esquire, Counsel for Paternal Grandparents Rene M. Gornall, certified legal intern, Counsel for Mother Lucy Johnston-Walsh, Esquire, Family Law Clinic E. Ralph Godfrey, Esquire, Counsel for Father KAREN NEWELL and ROGER M. NEWELL, Plaintiffs V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 2003-4033 CIVIL TERM JASON L. NEWELL and EMILY: CIVIL ACTION - LAW M. NEWELL, Defendants : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COlINTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: I. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BlRTH CURRENTL Y IN CUSTODY OF Angel M. Ncwell Teresa 1. Newell November 18, 1999 April 4. 2001 Mother Mother 2. A Conciliation Conference was held in this matter on September 15,2005. with the following individuals in attendance: The paternal grandparents. Karen Newell and Roger M. Newell, with their counsel, Lindsay D. Baird, Esquire, Mother. Emily M. Newell, with her counsel, Rene M. Gornall, certified legal intern, Lucy Johnston-Walsh. Esquire, Family Law Clinic. and Father, Jason 1. Newell, with his counsel, E. Ralph Godfrey, Esquire. 3. A prior Order of Court dated October 29,2004 was entered by the Honorable J. Wesley Oler, Jr. Said Order provided for shared legal and physical custody for the parents with the paternal grandparents having alternating weekends, 4. The parties agreed to the entry of an Order in the form as attached. - () S- 7 . L _ Ii, Date / vi . t L'~'-<j (Jiacq line M. Verney, Esquire Custody Conciliator C) 1"-.-' 10 (J -{,g, C ,.':'.;' ~ (~:':::o <;;."-" t ~ S =': ::? :.t.. ~- ." :::0 rl1p f" ----r;n~ \) ~ . ~D.r! --- -- -'Ie:,' ~ '^--' \)- 2::: :;.~~.~ 0< ~ -0 -~.. ~ CO ,~-) I ' I ~ ~;~ ....:( .~< 1"-.) "'::J 1.0 .-< ----- b +- -f-- r --- . KAREN M. NEWELL AND ROGER L. NEWELL IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY. PENNSYL VANIA v. 03-4033 CIVIL ACTION LAW JASON L. NEWELL AND EMILY M. (COPE) NEWELL IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Monday, Mareh 27, 2006 _, 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 Cou~ourthouse, Carlisle on __Thur~day, May II, 200L __ at ~:30 AM for a Pre-I learing Custody Conference. At such conference, an elTort will be made to resolve the issues in dispute; or if this cannot bc accomplished, to deline and narrow the issues to be heard by the court. and to entcr into a temporary order. All children age live or older may also be present at the conference. Failure to appear at thc conference may provide grounds for entry of a temporary or permanent order. The court hereby direcls 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/ Tacqu(:lineM. Verne!:', 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 seheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VE 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 32 South Bedf'lrd Street Carlisle, Pennsylvania 17013 Telephone (7 I 7) 249-3 166 - ~ .h~7-'?"Jl('Zt7 .~ ~c;/.J'? 0t?/ ?.6-) ,,~' , ? - (/ '70 I 0 c. --<.-, C. )'-;JvC/ - ~7tf' $t7 $ /~7?J1/ ?~?'~ JO-CE- F ~?;)> ~??~:Z ~~ -7~?7 9c7-(c.c'- , , ",)1l8 I S :2 Hd LZ ~i'Jv! seaz , ; "'-'., ',"','; I ".";( ,. 1('; Atb~.,~",:,';,,-,:.',.k'(J:J :iil.l .:1~, :,'~I,!:/j--CEn\:1 KAREN M. NEWELL and ROGER L. NEWELL, Plaintiffs v. JASON L. NEWELL and EMILY M. COPE (now NEWELL), Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003- 4033 CIVIL TERM : IN CUSTODY STIPULATION FOR CUSTODY STIPULATION made this If-I) day of ",;j A( - ,2006, between Karen M. Newell and Roger L. Newell known as paternal grand~mily M. Cope, now Newell, and Jason L Newell, hereinafter referred to as parents. WHEREAS, the above-named parents had born to them the following children on the following dates: NAME BIRTH DATE Angel M. Newell November 18, 1999 Teresa L. Newell April 4, 2001 AND WHEREAS, the above-named grandparents and parents desire to enter into a Stipulation as to the custody of the above-said children: NOW, THEREFORE, in order to effectuate the above purpose, the above-named grandparents and parents hereby stipulate that: 1. The paternal grandparents and parents shall share legal custody of the children. 2. The paternal grandparents shall have primary physical custody of the children and shall allow the maternal grandparents time with the children as agreed. 3. Mother shall have periods of partial custody during the summer and shall provide for the transportation and shall return the children no later than one week before school begins. 4. Mother shall pay paternal grandparents $200.00 each month for the support of the children and therefore paternal grandparents will not formally file for support. TO THIS PURPOSE, The parties hereto intend to be legally bound by the terms of this Stipulation and desire to have the Stipulation entered as an Order of Court. Witness: 1Z~~ - Karen Newell, Grandmother ~ Roger Newell, Grandfather ~ ? fla<.rt?fl Jason L. Newell Father r.J'~, (.i'~ f)/ KAREN M. NEWELL and ROGER L. NEWELL, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2003- 4033 CIVIL TERM JASON L. NEWELL and EMILY M. COPE, : IN CUSTODY Defendants ORDER OF COURT AND NOW, this <{[~ day of ~ '"' ,2006, upon consideration of the \ attached custody stipulation with respect to the children, Angel M. Newell, born November 18, 1999, and Teresa L. Newell, born April 4, 2001, the terms of the stipulation are entered as an order of court. BY THE COURT, , J. vldhdsay Dare Baird, Esquire 37 South Hanover Street Carlisle, PA 17013 Attorney for Plaintiffs yJeson L. Newell \ 31 Sheryl Drive ~ Newville, PA 17241 ~mily M. Cope ~ ~rve// 149 North East Street Carlisle, PA 17013 'VIN\I^1ASNN3d AlNnD:! OIN"Ij:tfj~f'\O Z I :Z Wd S- AVW 900l AtN.lOOOruoo;t .3Hl. :Kl ~ RI" ---."'7--' , -~I_,' KAREN M. NEWELL and ROGER L. NEWELL Plaintiffs MAY 1 9. lOO~ : IN THE COURT OF COMM ~LiAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003-4033 CIVIL ACTION - LAW v. JASON L. NEWELL and EMILY M. (COPE) NEWELL, : IN CUSTODY Defendants ORDER OF COURT AND NOW, this 12th day of May, 2006, being advised that the parties have reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, Jv\..- ~ y Conciliator VINVS1ASNN3d J "In,," r',rq~o'^'n" J\..U" h..-'" , .', ",:j,.J~V V LS :21 Wd S I AVW 900l AtlIJ10NOHlOOd 3Hl :Kl 3Q1:J:lO-Q311:l Karen M. Newell and Roger L. Newell, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY Jason L. Newell and Emily M. Cope (now Newell), Defendants : No. 03-4033 CIVIL TERM PETITION FOR LEAVE TO WITHDRAW Petitioner, The Family Law Clinic, hereby petitions to withdraw from further representation of Defendant Emily M. Cope, now known as Emily Newell, pursuant to Rule I.I6(b)(1) and (5) of the Pennsylvania Rules of Professional Conduct and P A. R. CIv. P. 10 12, and in support therefore avers the following: 1. On August 18, 2005, The Family Law Clinic filed a Petition to Modify Custody on behalf of Ms. Newell. 2. On September 15,2005, a custody conciliation was held. 3. On September 20, 2005, a Custody Order was entered granting the parties shared legal and physical custody. 4. On March 21, 2006, Paternal Grandparents, Karen and Roger Newell, and Father, Jason Newell, filed a Petition to Modify the Custody Order and To Keep the Children in Pennsylvania. 5. A custody conciliation was scheduled for May 11,2006. 6. On May 3, 2006, Emily Newell and Paternal Grandparents settled the issue of custody by agreement. The Family Law Clinic did not participate in the negotiations that led to that settlement agreement. 7. During the course of the Family Law Clinic's representation of Emily Newell, irreconcilable differences have arisen between The Family Law Clinic and Emily Newell, which have made further representation of her unreasonably difficult. 8. As there is currently no litigation pending, withdrawal can be accomplished without material adverse effect on the interests of Emily Newell. 9. Pursuant to C.C.R.P. 208.2(d), the concurrence of opposing counsel, Linda Baird, Esq., was sought and obtained. WHEREFORE, The Family Law Clinic requests permission to withdraw as counsel for Defendant Emily Newell (formerly Emily M. Cope) in this matter. Respectfully submitted, Date 'J?~'l / f fk- ;;~) c/ C, / ,--/ ' /<t[~ ec c. c Valerie J. Ja Certified Legal Intern ~ ~ ~ ThO~'~ Robert E. Rains Anne MacDonald-Fox Lucy Johnston-Walsh Supervising Attorneys F AMIL Y LA W CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 Karen M. Newell and Roger L. Newell, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LA W : IN CUSTODY Jason L. Newell and Emily M. Cope (now Newell), Defendants : No. 03-4033 CIVIL TERM CERTIFICATE OF SERVICE I, Valerie J. Jackson, Certified Legal Intern, The Family Law Clinic, hereby certify that I am serving a true and correct copy of a Petition for Leave to Withdraw on the following persons by first class United States mail, postage prepaid, the 18th day of May, 2006: Emily Newell (formerly Emily M. Cope) residing at 31 Sheryl Drive, Newville, Pennsylvania 17241, and Lindsey Baird, Esq., at 37 South Hanover Street, Carlisle, Pennsylvania 17013 (counsel for Karen and Roger Newell and Jason Newell). ~~~~0 Certified Legal Intern ~~ ONALD-FOX . LUC OHNSTON- WALSH THOMAS M. PLACE ROBERT E. RAINS Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, Pa 17013 717/243-2968 n ~; \,,;) c::::> = c:r- :x :D"" --<. o -n ..... :r:..,., rl1p -clJ.1 -"Y J_ ,-j , '-:J~', ~:::u , 'C) )~m (~) ::.::., -;::-- ~ co -0 :;::: w r'-' KAREN M. NEWELL And ROGER L. NEWELL, : Plaintiffs v. JASON L. NEWELL and EMIL Y M. COPE (now NEWELL), Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NO. 03-4033 CIVIL TERM ORDER OF COURT AND NOW, this 19th day of May, 2006, upon consideration of the Petition for Leave To Withdraw, a Rule is hereby issued upon all parties to show cause why the relief requested should not be granted. RULE RETURNABLE within 10 days of service. ftmily Law Clinic 45 North Pitt Street Carlisle, PA 17013 Attorney for Emily M. Cope (now Newell) ~ily Newell 31 Sheryl Drive Newville, PA 17241 AIndsay D. Baird, Esq. 37 South Hanover Street Carlisle, P A 17013 :rc BY THE COURT, 4 ~o~ Dt> r- 'Vi,N\f/\1},SNN3d I "N()lV, ,-" '"' '-"''''n'' I\JJ 'l P,i' ","; ,":"~:-:Y~ iu 6 I :2 HeI 22 A V~l 900l Ai:NLOfU:i,Oi3d 3Hl :JO :DH:.!(i-{l3ll:J Karen M. Newell, Roger L. Newell Plaintiff IN THE COURT OF COM ON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. CIVIL ACTION-LAW DIVORCE Jason L. Newell Emily M. Cope (now Newell) Defendants NO. 03 - 4033 CIVIL TE CERTIFICATE OF SERVICE I, Gillian Woodward, Certified Legal Intern, Family Law CI nic, hereby certify that I served a true and correct copy of the Order of Court - Rule to Show ause on the following persons by first class United States mail, postage prepaid, the 30th d Y of May, 2006: Emily Newell (formerly Emily Cope) residing at 31 Sheryl Drive, Newvill , Pennsylvania 17241, ane Lindsay Baird, Esq., at 37 South Hanover Street, Carlisle, Pennsylv 'a 17013 (counsel for Karen and Roger Newell and Jason Newell). Anne d-Fox, Esq. Lucy Johnston- alsh Thomas M. PI ce Robert E. Rai Supervising A omeys FAMILY LA 45 North Pitt reet Carlisle, PA 1 013 (717) 243-296 Fax: (717) 24 -3639 o ~ -at}':. O)~; 2-'; Uj 1.:--;: "" "'" = cr ::ll: ~ ~<( c.,.) ~ -I ::r:-n In? -0 tr2, ~--)C.... '.' L ::~~S:r\, J:,-) :~J \:...-Cn) ",---f <.-;:; -;;... ~ - -0 ::;:: '-:-: .e:- N KAREN M. NEWELL, And ROGER L. NEWELL Plaintiffs, : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03 - 4033 CIVIL TERM JASON L. NEWELL and EMILY M. COPE (now NEWELL), Defendants : IN CUSTODY PETITION TO MAKE RULE ABSOLUTE AND NOW, comes Petitioner, the Family Law Clinic, and petitions the court as follows: 1. Petitioner, the Family Law Clinic, is counsel of record for the above-named Defendant, Emily Newel!. 2. Petitioner filed a Petition to Withdraw in this matter on May 18, 2006. On May 19,2006, this Court issued an Order with a Rule to Show Cause why the Family Law Clinic should not be permitted to withdraw. A copy ofthe Petition and the Order for Rule to Show Cause are attached hereto and incorporated herein by reference as Exhibit "A". 3. The May 19, 2006 Order of Court for Rule to Show Cause permitted any party to object to the Family Law Clinic's request to withdraw as Emily Newell's counsel within ten (10) days after service. 4. A true and correct copy of the May 19, 2006 Order of Court for Rule to Show Cause was served upon Respondent, Emily Newell, by first class mail, postage prepaid, at 31 Sheryl Drive, Newville, Pennsylvania, 17241 on May 30,2006. A true and correct copy of the May 19, 2006 Order of Court for Rule to Show Cause was served upon counsel for Plaintiff on May 30, 2006. 5. Ten (10) days have passed since the Rule was served upon the Respondent and Plaintiff's counsel, and no response or objection has been filed. WHEREFORE, the Family Law Clinic requests this court to enter an Order permitting it to withdraw as counsel for Emily Newell in this matter. I 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. Date: (b I' '-I { 0<0 ~(~w Gillian Woodward Certified Legal Intern THO ROB T E. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 (~.'..-- (/ \ '-/7 ~.. KAREN M. NEWELL And ROGER L. NEWELL, : Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW JASON L. NEWELL and EMIL Y M. COPE (now NEWELL ), Defendants NO. 03-4033 CIVIL TERM ORDER OF COURT AND NOW, this 19th day of May, 2006, upon consideration of the Petition for Leave To Withdraw, a Rule is hereby issued upon all parties to show cause why the relief requested should not be granted. RULE RETURNABLE within 10 days of service. BY THE COURT, Family Law Clinie 45 North Pitt Street Carlisle, P A 17013 Attorney for Emily M. Cope (now Newell) Emily Newell 31 Sheryl Drive Newville, PAl 7241 :rc eYIT j~ Lindsay D. Baird, Esq. 37 South Hanover Street Carlisle, P A 1701 J . r Karen M. Newell and Roger L. Newell, Plaintiffs v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW : IN CUSTODY Jason L. Newell and Emily M. Cope (now Newell), Defendants : No. 03-4033 CIVIL TERM ORDER OF COURT-RULE TO SHOW CAUSE AND NOW, this _ day of 2006, upon consideration of the foregoing petition, it is hereby ordered that (1) a rule is issued upon Emily Newell (formerly Emily M. Cope) to show cause why The Family Law Clinic should not be granted leave to withdraw as counsel of record; (2) Defendcu"1t Emily Newell (formerly Emily Ivt Cope) shall file an 8_nS"I)lJ.';T to the petition within twenty days of service upon her; (3) the petition shall be decided under PA. R. Cry. P. 206.7; (4) notice of the entry of this order shall be provided to all parties by The Family Law Clinic. BY THE COURT: J. . . Karen M. Newell and Roger L. Newell, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY Jason L. Newell and Emily M. Cope (now Newell), Defendants : No. 03-4033 CIVIL TERM r--.......) C) If ..-f ,- _~c.. I"';" -11 PETITION FOR LEAVE TO WITHDRAW -< " r= ;.:> co J31:.9 Petitioner, The Family Law Clinic, hereby petitions to withdraw from furtheiiepreseritatio~c:'; ~.;:-> ;i~ :'<2 (;~ of Defendant Emily M. Cope, now known as Emily Newell, pursuant to Rule 1. 16(lJ)q) an~.(5) ~ ;':1 m_~: ;_~ the Pennsylvania Rules of Professional Conduct and PA. R. CN. P. 1012, and in supp-6rt the~fo~ ...;::) ~l"'" avers the following: 1. On August 18,2005, The Family Law Clinic filed a Petition to Modify Custody on behalf of Ms. Newell. 2. On September 15,2005, a custody conciliation was held. 3. On September 20, 2005, a Custody Order was entered granting the parties shared legal and physical custody. 4. On March 21, 2006, Paternal Grandparents, Karen and Roger Newell, and Father, Jason Newell, filed a Petition to Modify the Custody Order and To Keep the Children in Pennsylvania. 5. A custody conciliation was scheduled for May 11,2006. 6. On May 3, 2006, Emily Newell and Paternal Grandparents settled the issue of custody by agreement. The Family Law Clinic did not participate in the negotiations that led to that settlement agreement. 7. During the course of the Family Law Clinic's representation of Emily Newell, irreconcilable differences have arisen between The Family Law Clinic and ~"\~'r~-;~.cor::;=;r;'r:;:r .--;":-, - - -.. - - - --- ."-..--. - _.- difficult. .. ........ 8. As there is currently no litigation pending, withdrawal can be accomplished without material adverse effect on the interests of Emily Newell. 9. Pursuant to C.C.R.P. 208.2(d), the concurrence of opposing counsel, Linda Baird, Esq., was sought and obtained. WHEREFORE, The Family Law Clinic requests permission to withdraw as counsel for Defendant Emily Newell (formerly Emily M. Cope) in this matter. Respectfully submitted, Date Valerie J. Jaek!!oIl Certified Legal Intern Thomas M. Place Roberi' E. Rains Anne MacDonald-Fox Lucy Johnston-Walsh Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Fax: (717) 243-3639 ~,~") ~~ f:;':,;J =-' c,fl :.::i ell C0 U', KAREN M. NEWELL, And ROGER L. NEWELL Plaintiffs, : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03 - 4033 CIVIL TERM JASON L. NEWELL and EMILY M. COPE (now NEWELL), Defendants : IN CUSTODY CERTIFICATE OF SERVICE I, Gillian Woodward, hereby certify that I am serving a true and correct copy of the Petition to Make Rule Absolute on the following persons by depositing a copy of the same in the United States Mail, postage prepaid, this 14th day of June, 2006: Emily Newell 31 Sheryl Drive Newville, Pa 17241 Lindsay D. Baird 37 South Hanover Street Carlisle, P A 17013 0ilk~k ~ Gillian Woodward ~~-.J&Z HO S . PLACE ROB T E. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ~:; C) ,;;'.> -1'1 "'~ (_. ~~~~ ",1 -'Cl -""" r;? <J'\ ,-,0 c . . JUN 1 ij lUUD , l.. ~I ! ""::::0.', _-==.J KAREN M. NEWELL, And ROGER L. NEWELL Plaintiffs, : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03 - 4033 CIVIL TERM JASON L. NEWELL and EMILY M. COPE (now NEWELL), Defendants : IN CUSTODY ORDER OF COURT AND NOW, this tl tL day of ~l")' , 2006, upon presentation and consideration ofthe Petition to Make Rule Absolute, the Rule entered by Order of Court on May 19, 2006, is hereby made ABSOLUTE and Petitioner, the Family Law Clinic, is permitted to withdraw as counsel for the Defendant, Emily Newell (formerly Emily Cope). BY THE COURT: J. ~--Iq/"oc, ~ ~ :yJs- 0 ....::r c'? C:- u:) f:= ,,~':: "-..o::J /.1- c:::.::. ::.::> (:) \'::;::) U ,.....,