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HomeMy WebLinkAbout07-4653COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW STEPHANIE M. GODWIN, Plaintiff v. ) No. P.' 7 '~ ~ 5.3 Cu.~l ~, BENJAMIN K. GODWIN, Defendant COMPLAINT FOR CUSTODY Plaintiff is STEPHANIE M. GODWIN, who resides at 5465 Wentzville Rd, Enola, Cumberland County, PA 17025. 2. Defendant is BENJAMIN K. GODWIN, who resides at 904 Elm St, New Haven, CT 06511. 3. Plaintiff seeks custody of the following child: Name Age Was child born out of wedlock? Joelle M. Godwin 6 years Yes 4. The child is presently in the custody of Plaintiff who resides at 5465 Wentzville Rd, Enola, Cumberland County, PA 17025. During the past five years, the Child has resided with the following persons and at the following addresses: From To Address With whom JUN, 2006 (Still living there) 5465 Wentzville Rd Plaintiff, mother Enola, Pennsylvania 17025 MAY, 2005 JUN, 2006 2155 Cedar Lane Stephanie Godwin Enola, PA 17025 (Mother), Stephen Chadwick (Grandfather), Laurie Chadwick (Grandmother), Colleen Chadwick (Aunt), Ashlee Chadwick (Aunt) AUG, 2004 MAY, 2005 39 East 9Th St Stephanie Godwin Derby, CT 06418 (Mother), Benjamin Godwin (Father) Complaint Page 3 of 6 AUG, 2002 AUG, 2004 110 Sherman Ave Hamden , CT 06518 Stephanie Godwin (Mother), Benjamin Godwin (Father) 6. The mother of the child is currently residing at 5465 Wentzville Rd, Enola, PA 17025. she is separated. 7. The father of the child is currently residing at 904 Elm St, New Haven, CT 06511. He is separated. 8. The relationship of Plaintiff to the Child is mother. Plaintiff currently resides with the following persons: Name Relationship to Plaintiff Joelle M. Godwin child 9. The relationship of Defendant to the child is father. Defendant currently resides with the following persons: Name Sharon Whitley-Correa ltrparGregory Correa Relationship to Defendant Sister Brother-in-law 10. Plaintiff has participated as a party or witness, or in another capacity, in other litigation concerning the custody of the Child in this or another court. The court term and number and Its relationship to this action are: Name of court: New Haven Connecticut Family Court Docket number: NNH-FA-OS-4011070-5 Date of last order or hearing: Jurie 21st 2007 Type of case: DISSOLUTION OF MARRIAGE 11. Plaintiff has no information of a custody proceeding concerning the Child pending in a court of this Commonwealth or any other state. 12. 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. 13. The best interest and permanent welfare of the child will be served by granting the relief requested because I am Joelle Godwin's primary care giver, we have lived here in Pennsylvania with consent from her father Benjamin Godwin since May 1st 2005. We moved here for the support Complaint Page 4 of 6 of my family when I became aware of Benjamin Godwin's adultery in our marriage. I have no familial ties, as well as no support system in Connecticut. Benjamin Godwin has seen his child 8 times in over 2 years, despite my urging to come visit her here in Pennsylvania. He on numerous occasions has expressed his desire to terminate his parental responsibilities in regards to the child, and refused to pay child support for months at a time. He was finally court ordered to pay support in July 2006. He was ordered to participate in a family relations study and outright refused on numerous occasions. He became verbally abusive toward the court staff to the point they were concerned of my wellbeing leaving the court and had a court marshall escort me make sure I returned to my car safe. His first lawyer, Atty Michael E. Rizzo 2046 Whitney Avenue Hamden, Connecticut 06517, withdrew from the case. He was ordered by the court again to either participate in a family study for visitation or pay for Joelle Godwin to have a Guardian ad liteum. He finally agreed to participate as opposed to taking on the fees of another attourney for Joelle. Since then he has supposedly taken up residence with the girlfriend, whom was the other party involved in the adultery, due to the convicted felon status of his brother-in-law who resides with him. He is unstable mentally, physically and emotionally, there are longstanding anger issues in reguards to Benjamin Godwin which involve altercations resulting in a police record and altercations at his place of employment resulting in suspension from work on numerous occasions. He has an alcohol addiction which is apparent even to Joelle and has affected time spent with her. I have consistently displayed fitness as her primary caregiver by caring for Joelle on a daily basis, working to support our household, as well as going back to school for my RN so I can give my daughter a good life. During the relationship he was physically, verbally and emotionally abusive on a consistent basis and continues to be verbally and emotionally abusive still. He has spoken ill will of me in the presence of Joelle Godwin. His girlfriend, whom was the other party involved in the adultery, has made physical threats of harm towards me in the presence of Benjamin Godwin as well as for Joelle to hear. The children of the girlfriend have also become involved when they told Joelle that she has a "bad mother" due to hearing their mother and Benjamin Godwin speak maliciously in regurds to myself and the situation. Joelle has expressed her desire to not have visitation in Connecticut with her father. Joelle had seen a Child Psychologist a year ago who recommended that Joelle not be forced to visit her father in Ct, that it would do more harm than good since she does not have a consistent relationship with him and does not feel comfortable with him. Benjamin Godwin has had Complaint Page 5 of 6 numerous opportunities for visitation with Joelle, he does not work on weekends and has had time off of work in which he could have visited with her. I have made it clear to him that he can come here to see her at any time including holidays. It is in Joelle's best interests to remain in my primary custody with visitation by her father here in Pennsylvania where she feels most comfortable. The ability is greater for Benjamin Godwin to make the trip to Pennsylvania to see Joelle rather than for Joelle to visit in Connecticut. It is unreasonable for me as the primary caregiver, head of household, and student to take time off work to bring Joelle for visitation. It would have adverse effects on Joelle emotionally, as well as have adverse effects on my ability to maintain the household with taking time off work. Joelle will be entering the first grade in the fall and taking weekend trips, which consist of at least 10 hours of driving, have the potential to affect her education. It is more reasonable in this situation for Benjamin Godwin to schedule weekend trips to visit Joelle here where she is more comfortable, in a safer environment and would have a less traumatic effect on her. 14. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the Child have been named as parties to this action. WHEREFORE, Plaintiff requests the Court to grant custody of the child to Plaintiff. t ST HANIE M. GODWIN, Plaintiff Verification I, STEPHANIE M. GODWIN, Plaintiff, verify that the facts stated in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. Petitioner understands that false statements therein are subject to the penalties of 18 Pa. C.S.A.'4904 relating to unsworn falsification to authorities. Date: 4 5 07 S~ Q~,te IM . Csodw tvI STE HANIE M. GODWIN, Plaintiff Complaint Page 6 of 6 ~ Q ~_ `> c ° ~ - ~ ~~f c_ -~~ ~~ .~ COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION -LAW STEPHANIE M. GODWIN, ) Plaintiff ) v. ) BENJAMIN K. GODWIN, ) Defendant ) No. C1 ~ YG S3 ~( ~~,~. Petition For Waiver Of Costs 1. I am the Plaintiff in the above matter and because of my financial condition, I am unable to pay the fees and costs of prosecuting or defending this action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. I represent that the information below relating to my ability to pay the fees and costs is true and correct: (A) NAME: STEPHANIE M. GODWIN ADDRESS: 5465 Wentzville Rd, Enola, PA 17025 (B) EMPLOYMENT: If you are presently employed, state: EMPLOYER: Tavern On The Hill ADDRESS: 109 Howard St, Enola, Pa 17025 SALARY OR WAGES PER MONTH: $ 1,075 TYPE OF WORK: Waitress If you are presently unemployed, state: DATE OF LAST EMPLOYMENT: SALARY OR WAGES PER MONTH: TYPE OF WORK: (C) OTHER MONTHLY INCOME WITHIN THE LAST TWELVE (12) MONTHS: BUSINESS OR SELF-EMPLOYMENT: $ 0 INTEREST OR DIVIDENDS: $ 0 PENSION OR ANNUITIES: $ 0 Petition for Waiver of Costs Page 2 of 4 .~ SOCIAL SECURITY OR S.S.L: $ 0 SUPPORT: $ 598 (since july 2006) UNEMPLOYMENT COMPENSATION: $ 0 WORKER'S COMPENSATION: $ 0 WELFARE: $ 0 OTHER (Please specify): $ 0 (D) OTHER MONTHLY CONTRIBUTIONS TO HOUSEHOLD SUPPORT: SPOUSE'S NAME (if living together): (Not applicable) If your spouse is employed, state: EMPLOYER: SALARY OR WAGES PER MONTH: TYPE OF WORK: CONTRIBUTIONS FROM CHILDREN: CONTRIBUTIONS FROM PARENTS: (None) OTHER CONTRIBUTIONS: (None) (E) PROPERTY OWNED: CASH: $ 8 CHECKING ACCOUNT: $ 30 SAVINGS ACCOUNT: (None) CERTIFICATES OF DEPOSIT, STOCKS, BONDS: (None) REAL ESTATE /HOME: (None) MOTOR VEHICLE: (None) OTHER: (None) (F) DEBTS AND OBLIGATIONS PER MONTH: MORTGAGE/RENT: $ 700 WATER/SEWER: $ 0 ELECTRIC: $ 100 TELEPHONE: $ 100 OIL/GAS/HEAT: $ 100 CABLE: $ 50 FOOD: $ 300 CLOTHING: $ 50 CHILD SUPPORT: $ 0 CHILD CARE: $ p TRANSPORTATION: $ 300 MEDICAL EXPENSES: $ 50 LOAN PAYMENTS: $ 0 CREDIT CARD PAYMENTS: $ 200 INSURANCE: $ 0 MISCELLANEOUS: $ 50 (G) PERSONS DEPENDENT UPON YOU FOR SUPPORT: CHILDREN (STATE NAMES AND AGES): Petition for Waiver of Costs Page 3 of 4 .~ Name Age Joelle M. Godwin 6 years OTHERS (STATE NAME, AGE AND RELATIONSHIP): Name Age Relationship (None) 3. I understand that I have a continuing obligation to inform the court of any improvement in my financial circumstances which would permit me to pay the cost incurred with this case. 4. I verify that the facts stated in the foregoing Petition are true and correct to the best of my knowledge, information and belief. Petitioner understands that false statements therein are subject to the penalties of 18 Pa. C.S.A. '4904 relating to unsworn falsification to authorities. Date: 8 5 0'1 ~~~kat~ie ~ .Eo~W ~h STEPHANIE M. GODWIN, Plaintiff Petition for Waiver of Costs Page 4 of 4 v C , ~ ~~ ~` ~"' i ' ~ ~ i__ ~ a ~~ ~ .. ' :'r_~ ~ ~ ~ ,F~.Y ~ ~ r~~:, i ~~ STEPHANIE M. GODWIN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 07-4653 CIVIL ACTION LAW BENJAMIN K. GODWIN IN CUSTODY DF,FF..,NDANT ORDER OF COURT AND NOW, Monday, August 13, 2007 ,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 06, 2007 at 8:30 AM for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished., to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ ac ueline M. Verne Es . 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 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 7 _ / ~ ax,~y a~~c~l{, CO~h/ ~ ~ ~ ~ ~ 1_* t { /~ 'fi~~~~ ate` ~ :~~~f •. t a+ `` ~ .. 1-1 ~ ~ ~ 4 -y ~ , ~,.s ~~r,~ ai , t:~ ~~,,.:: . SEP 10 2001 STEPHANIE M. GODWIN, Plaintiff V. BENJAMIN K. GODWIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2007-4653 CIVIL ACTION -LAW IN CUSTODY ORDER OF COURT AND NOW, this ~O~ day of s t~~Cc.~be,~' , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Stephanie M. Godwin and the Father, Benjamin K. Godwin, shall have shared legal custody of Joelle M. Godwin, born April 28, 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 Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of 23 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 the other pazent. 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. Both parents shall be entitled to full participation in all educational and medicaUtreatment planning meetings and evaluations with regazd to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regazd to .school pictures, extracumculaz activities, children's parties, musical presentations, back-to-school nights, and the like. 2. Mother shall have primary physical custody of the child 3. Father shall have the following periods of partial physical custody: A. The three day weekends of Columbus Day, Martin Luther King, Jr. Day; President's Day, Memorial Day, one weekend in August at Father's discretion, and Labor Day from Saturday at 10:00 a.m. to Monday at 10:00 a.m. B. One week in the summer in which July 4~' falls. C. Thanksgiving from Wednesday at 4:00 p.m. to Sunday at 4:00 p.m. D. A block of time azound the child's birthday E. A block of time on Christmas Eve. 4. The parties shall have liberal telephone contact with the child. 5. Transportation shall be shazed such that the parties shall meet at Exit 22 off of Route 287 in Bedminister, New Jersey, except for Thanksgiving when Father will pick up the child in Pennsylvania and Mother will retrieve the child from Father in Connecticut at Exit 42 in Longwharf. 6. Neither parry shall do or say anything nor permit a third party to do or say anything that may estrange the child from the other party, or injure the opinion of the child as to the other party, or may hamper the free and natural development of the child's love and affection for the other party. Neither party may discuss this custody matter with the child. 7. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, cc: d[ephanie M. Godwin, pro se 5465 Wertzville Road Enola, PA 17025 ,~enjamin K. Godwin, pro se 259 Shagbazk Street Derby, CT 06418 y ~ ~~.3, ~l1l~'la~ '~~•~"'" .iilYd ~ 0 i8 NV t I d3S !Q~ ~~~~ ~ STEPHANIE M. GODWIN, Plaintiff V. BENJAMIN K. GODWIN, Defendant PRIOR JUDGE: None IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2007-4653 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 CUSTODY OF Joelle M. Godwin Apri128, 2001 Mother 2. A Conciliation Conference was held in this matter on September 6, 2007, with the following in attendance: The Mother, Stephanie M. Godwin, pro se and the Father, Benjamin K. Godwin, pro se. 3. The parties agreed to an Order in the form as attached. Date acq line M. Verney, Esquire Custody Conciliator COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW STEPHANIE M. LANE, ) Plaintiff ) ) c~ ~ ~ ~, ~ ~ v. ) No. 07-4653 ~ `~'~ rte'; ~ '{~ _ ) ~ ~ ~ ~~- ) BENJAMIN K. GODWIN ~ ..~, , Defendant ) '"` ~ ~ ,~,. =_: -n ~ ~~ ~ ~ .. ~~ ==~ - n ~ Petition for Contempt and Modification ~ ~ '' ~, 1. Petitioner is Plaintiff, STEPHANIE M. LANE, who currently resides at 5465 Wertzville Rd, Enola, Cumberland County, PA 17025. 2. Respondent is Defendant, BENJAMIN K. GODWIN, who currently resides at 904 Elm St, New Haven, New Haven County, CT 06511. 3. Petitioner and Respondent aze the natural pazents of the following child: Name JOELLE M. GODWIN Age 9 yeazs 4. A custody order was entered on September 10th 2007, in the Cumberland County Court of Common Pleas. A copy of the custody order is attached. 5. Respondent has willfully violated the custody order, as follows: Mr Godwin has willfully violated the order on uncountable occasions in many ways. He has not followed the visitation order in any way since the order was put in place. He did not maintain visitation with Joelle, aside from one visit to Connecticut in October 2007 in which he refused to allow her to contact me without him monitoring her, caused her to be feazful of him evidenced by bystanders, he continually told her I am a bad mother, I do not caze about her and that she is going to live with him. He caused a great deal of emotional distress in which she has had nightmares for yeazs and continues to have these nightmazes and feazs concerning his actions. He has also violated the agreement by doing and saying things in an effort to estrange me from Joelle, injure her opinion of 70.0 Pd .,~ e~ ~ ~2r~9 ~" me and hamper the free and natural development of Joelle's love and affection for me. I have not discussed specifics of custody with Joelle, however she confided in me that he told her he was going to "take her" from me, and also scared her into saying what she knew "he wanted to hear so he wouldn't get even more mad". He has not seen Joelle since October 2009, in which he spent a few hours with her, then left the next day without notice despite my urging for him to see her before he left. Before that visit it had been over a year and a half that he went without seeing her, he visited once in April of 2008, spent about one hour with her and left. He has consistently violated the order and consistently caused emotional and mental distress not only to Joelle but also to me and my family. He has threatened my life on numerous occasions, harassed me and my family and written derogatory statements about me on social networking sites in which he allowed others to comment. He has caused Joelle and I along with my husband and family to fear for our safety due to his erratic irrational behavior and past experience. In addition he has also willfully withheld child support at his discretion since ordered to pay $139.00 per week in 2006, as of April 2010 he ceased all child support payments which has put him over $3,300.00 in arrears. He has made it evident that he has failed to maintain reasonable efforts to foster a relationship, failed to maintain contact, failed to provide child support, and failed to take into account what is in Joelle's best interests. 6. Petitioner seeks to modify the custody order because: Joelle deserves to have emotional, physical and mental stability in her life.. It is unfair for a child to be placed at risk of possible physical, emotional or mental harm. Joelle has a stable family life, she deserves the stability my husband and I have provide her. Joelle's needs are met with regard to understanding split families, and she participates in a group at school for children in families such as this. She has participated in the group since it started 2 years ago and has been a valuable member of the group helping her peers through separation and divorce. I have encouraged Benjamin Godwin to visit Joelle on many occasions however he refused. Mr. Godwin has an unstable living situation and a lifestyle not conducive to a 9 year old girls well being. Joelle should feel comfortable in her environment without what she perceives as the threat of being "taken away". I have done everything I can in regard to fostering a healthy relationship with Joelle and her father however his actions have proven he is unwilling to do the same. 7. Petitioner believes the custody order should be changed as follows: I am asking for Joelle to be in my sole physical custody with supervised visitations for Mr. Godwin at his discretion, as often as he would like including holidays. I am also willing to assist with the expenses incurred by traveling from Connecticut to Pennsylvania for visitation by relieving Mr. Godwin of his support obligation for that particular week, which totals $139.00, that would cover gas and hotel expenses if needed. However Mr. Godwin has chosen to deny child support since April 2010 and owes back child support totaling over $3,300.00. WHEREFORE, Petitioner respectfully requests that this Court find Respondent in contempt of Court and modify the Order as requested. Date: ~ ~ f '((((~ ~~ ~.~~- . S EPHANIE M. LANE, Plaintiff ...._,a~ ~.,~.,~ .me.e..u „_..~~_ __.. ~,. E ?. Verification I, STEPHANIE M. LANE, Plaintiff, verify that the facts stated in the foregoing Petition aze true and correct to the best of my knowledge, information and belief. Petitioner understands that false statements therein are subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. : Date: s ~(~1~" " " ' , ~~ZWI~' ~ O ~ ~ I ~ ~ ANIE M. LANE Plaintiff ST PH , SEP ~ p 2pp~ STEPHANIE M. GODWIN, Plaintiff V. BENJAMIN IG GODWIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2007-4653 CML ACTION -LAW ItN CUSTODY ORDER OF COURT AND NOW, this ~~~ day of .S t~~t,w~`p t~' , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Stephanie M. Godwin and the Father, Benjamin K. Godwin, shall have shared legal custody of Joelle M. Godwin, born Apri128, 2001. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency dxisions 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 23 PaC,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 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. Both parents shall be entitled to full participation in all educational and medicaUtreatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 2. Mother shall have primary physical custody of the child 3. Father shall have the following periods of partial physical custody: A. The three day weekends of Columbus Day, Martin Luther King, Jr. Day; President's Day, Memorial Day, one weekend in August at Father's discretion, and Labor Day from Saturday at 10:00 am. to Monday at 10:00 am. B. One week in the summer in which July 4`~ falls. C. Thanksgiving from Wednesday at 4:00 p.m. to Sunday at 4:00 p.m. D. A block of time around the child's birthday E. A block of time on Christmas Eve. 4. The parties shall have liberal telephone contact with the child. 5. Transportation shall be shared such that the parties shall meet at Exit 22 off of Route 28? in Bedminister, New Jersey, except for Thanksgiving when Father will pick up the child in Pennsylvania and Mother will retrieve the child from Father in Connecticut at Exit 42 in Longwharf. b. Neither party shall do or say anything nor permit a third party to do or say anything that may estrange the child from the other party, or injure the opinion of the child as to the other party, or may hamper the free and natural development of the child's love and affection for the other party. Neither party may discuss this custody matter with the child. 7. This Order is entered pursuant to an agi~eement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, cc: ~ephanie M. Godwin, pro se 5465 Wertzville Road Enola, PA 17025 ,~enjamin K. Godwin, pro se 259- Shagbark Street Derby, CT 06418 y STEPHANIE M. GODWIN, Plaintiff V. BENJAIVIIN K. GODWIN, Defendant PRIOR JUDGE: None IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2007-4653 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 CUSTODY OF Jcelle M. Godwin April 28, 2001 Mother 2. A Conciliation Conference was held in this matter on September 6, 2007, with the following in attendance: The Mother, Stephanie M. Godwin, pm se and the Father, Benjamin K. Godwin, pro se. 3. The parties agreed to an Order in the form as attached. -lo -y') f"\ v Date acq line M. Verney, Esquire Custody Conciliator STEPHANIE M. LANE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA v' 2007-4653 CIVIL ACTION LAW BENJAMIN K. GODWIN IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, October 15, 2010 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verne, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, November 16, 2010 at 8:30 AM for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR. THE COURT, By: /s/ Jacqueline M. Verney, Esq. (1~lrJ Custody Conciliator ~T_ 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. Q'/~ Cumberland County Bar Association ~O /~ /O ~ ~~ ~~ ~ ~`e ~7w 32 South Bedford Street ~-~ Carlisle, Pennsylvania 17013 --.. Telephone (717) 249-3166 ~~ ~ ~~ ~c,~ _~~ d ~;.. ~~ ~ ~ ;DTI ;::3~~"--, ~ Corn --~1 ^~ C7 =~7 '-C NOV 17 2010 STEPHANIE M. GODWIN, Plaintiff V. BENJAMIN K. GODWIN, Defendant .--L : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2007-4653 : IN CUSTODY ORDER OF COURT CIVIL ACTION -V rn cu M C:3 cn r"' - > ao ? "C ° z -v o -r cn a n z rn r -OCD M 00 =° C oh CO AND NOW, this kb day of N 0? tm\4t,r , 2010, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated September 10, 2007 shall remain in full force and effect with the following modifications. 2. Mother shall have sole physical custody of the child. 3. Father shall have periods of supervised visitation at his discretion. The supervisor shall be agreed to by the parties and may include Mother and friends or family of Father. 4. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, c : Stephanie M. Lane, pro se 5465 Wertzville Road / Enola, PA 17025 Benjamin K. Godwin, pro se 47 Walter Street West Haven, CT 06516 Co t ex rYr3t LL !C?) W .-'`. STEPHANIE M. (GODWIN) LANE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-4653 CIVIL ACTION - LAW BENJAMIN K. GODWIN, Defendant : IN CUSTODY PRIOR JUDGE: M. L. Ebert, 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 Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Joelle M. Godwin April 28, 2001 Mother 2. A Conciliation Conference was held in this matter on November 16, 2010, with the following in attendance: The Mother, Stephanie M. (Godwin) Lane, pro se and the Father, Benjamin K. Godwin, pro se, by telephone. 3. The Honorable M. L. Ebert, Jr. previously entered an Order of Court dated September 10, 2007 providing for shared legal custody with Mother having primary physical custody and Father having periods of partial physical custody on weekends and holidays and one week in the summer. 4. The parties agreed to an Order in the form as attached. //- & -16 ?L-" --.4! I t U Date acq line M. Verney, Esquire Custody Conciliator