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HomeMy WebLinkAbout03-5520CRAIG A. MORROW, Plaintiff VS. LISA A. RAYI-IART, Defendant * IN THE COURT OF COMMON PLEAS *CUMBERLAND COUNTY, PENNSYLVANIA ~ CIVIL ACTION - LAW * CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must make prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. YOU SHOULD TAKE THIS PAPER TO YOU LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CENTRAL PENNSYLVANIA LEGAL SERVICES 213A NORTH FRONT STREET HARRISBURG, PA 17~o~ (800) 930-0356 By: Respectfully, submitted, Bruce D} Forema~squ~ Harrisburg, Pennsylvania ~7~1o-~7o9 (717) 236-9391 Attorney for Plaintiff CRAIG A. MORROW, Plaintiff VS. LISA A. RAYHART, Defendant * IN THE COURT OF COMMON PLEAS *CUMBERLAND COUNTY, PENNSYLVANIA * NO. * CML ACTION - LAW * CUSTODY NOTICIA Le han demandado a Usted en la corte. Si Usted quiere defenderse de estas demandas expuestas en las paginas siguientes, Usted tiene viente (9o) dias de plazo al partir de la fecha de la demanda y la notification. Usted debe presentar una aparieneia escrita o en persona o por abogado y archivar en la torte en forma escrita sus defensas o sus objeciones a las demandas en contra de su personal. Sea avisado que si Usted no se defiende, la torte tomara medidas y puede entrar una orden contra Usted sin previo aviso o notification y por cualquier queja o alivio que es pedido en la petition de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para Usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CENTRAL PENNSYLVANIA LEGAL SERVICES 213A NORTH FRONT STREET HARRISBURG, PA 171oz (8oo) 932-o356 By: Respec~Srllly, submittesk~ B Pu~e~. Fol(erfi a~quir e Supr6me CL N~ 2~9~ 4409 No~ Front Street Harrisburg, Pennsylvania ~7~o-~7o9 (7~7) 236-939~ Attorney for Plaintiff CRAIG A. MORROW, Plaintiff VS. LISA A. RAYHART, Defendant * IN THE COURT OF COMMON PLEAS *CUMBERLAND COUNTY, PENNSYLVANIA *NO. * CML ACTION - LAW * CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, Craig A. Morrow, by and through his attorney, Bruce D. Foreman, Esquire and Foreman & Foreman, PC, and files the instant Petition and in support thereof, avers as follows: Plaintiff/Father, Craig A. Morrow, is an adult individual who currently resides at ~o6 Grant Street, Enola, Cumberland County, Pennsylvania, ~7o25. Defendant/Mother, Lisa A. Rayhart, formerly known as Lisa A. Beane, is an adult individual who currently resides at 4725 Enola Road, Newville, Cumberland County, Pennsylvania, ~724~. Plaintiff/Father seeks primary physical custody and shared legal custody of the minor child Craig A. Morrow, Jr., born December ~5, ~99o, now ~2 years of age, who currently resides with Defendant/Mother at 4725 Enola Road, Newville, Cumberland County, Pennsylvania, ~724~. The child was born out of wedlock. The relationship of Plaintiff to the child is that of Father. The Plaintiff currently resides with his wife and stepson. The relationship of the Defendant to the child is that of Mother. Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the minor child in this or any other court. Plaintiff has no information of a custody proceeding concerning the minor child pending in a court of this Commonwealth, or any other jurisdiction. 10. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or who claims they have custody or visitation rights with respect to the child. The best interest and permanent welfare of the minor child will be served by granting primary physical and joint legal custody to the Plaintiff/Father, and such visitation to the Defendant/Mother as may be mutually agreeable to the parties. WHEREFORE, Plaintiff respectfully requests this Honorable Court grant primary physical and joint legal custody of the minor child, Craig A. Morrow, Jr., to Plaintiff, and grant such other relief as this Honorable Court shall find to be just and fair and in the best interest of the child. Date: By: Respectf~, submitted, /~ FOR~A~ ~REMAN, PC y~ Bru~e D.~rem~.s~e /~ Supreme Ct. No. m~93 ~ ~ 44o9 NoRh Front Street Harrisburg, Pennsylvania ~7~m-~7o9 (7~7) ~36-939x Attorney for Plaintiff CRAIG A. MORROW, Plaintiff Va. LISA A. RAYHART, Defendant * IN THE COURT OF COMMON PLEAS *CUMBERLAND COUNTY, PENNSYLVANIA * NO. * CML ACTION - LAW * CUSTODY VERIFICATION I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of x8 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Craig A. MoI~ow, Plaintiff/Petitioner Date: J~)/Ic/jO~ CRAIG A. MORROW PLAINTIFF LISA A. KAYHART DEFENDANT AND NOW, TI it is hereby directed that parties at 301 Market Streel for a Pre-Hearing Custody Con if this cannot be accomplished, order. All children age five or provide grounds for entry of a' The court hereby dire Special Relief orders, and Cu The Court of Cc with Disabilites Act of 19' available to disabled indN must be made at least 72 conference or hearing. YOU SHOULi HAVE AN ATTORNEY FORTH BELOW TO Fib IN 'DIE COURT OF COMMON PLEAS OF CUMBERLAND COUN FY, PENNSYLVANIA 03-5520 CIVIL ACTION LAW : IN CUSTODY ORDER OF COURT ursday, October 23, 2003 , upon consideration of the attached Complaint, ind their respective counsel appear before Melissa P. Greevy, Esq. , the concili Lemoyne, PA 17043 on Monday, November 24, 2003 at 10:30 ,rence. At such conference, an effort will be made to resolve the issues in dispute; define and narrow the issues to be heard by the court, and to enter into a tempora lder may also be present at the conference. Failure to appear at the conference ma' emporary or permanent order. the parties to furnish any and all existing Protection from Abuse orders, ~tody orders to the conciliator 48 hours prior to scheduled hearing. FOR TIlE COURT. By: /s/ Melissa P. Greevy, Esq. Custody Conciliator mmon Pleas of Cumberland County is requited by law to comply with the Americm ~0. For information about accessible facilities and reasonable accommodations iduals having business before the court, please contact our office. All arrangements ours prior to any hearing or business before the court. You must attend the schedul TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT )R CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET D OUT WHERE YOU CAN GET LEGAL ttELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 M or CRAIG A. MORROW, Plaintiff VS. LISA A. RAYI-IART, Defendant * IN THE COURT OF COMMON PLEAS *CUMBE~D COUNrY, PENNSYLVANIA * NO. 03-5520 * CML ACTION - LAW * CUSTODY AFFIDAVIT OF SERVICE I, BRUCE D. FOREMAN, ESQUIRE, certify that service of the Complaint for Custody and Order of Court, dated October 23, 2003, filed to the above-captioned term and number was made on Defendant, Lisa A. Rayhart, 4725 Enola Road, Newville, PA, 17241, by first class mail, return receipt requested, postage prepaid, as evidenced by PS Form 381 l, attached hereto and made a part hereof. Bruc~e'-~. F'ore~an,~'~ire COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF DAUPHIN On the ~._.5-xJ'~y of /( /{)~.~Lff/./.,(.~ 2003, before me, a Notary Public in and for said County and State, the t~nd~rsign~d officer, personally appeared Bruce D. Foreman, Esquire, known to me (Or satisfactorily proven) to be the person whose name is subscribed to the within instnunent, and acknowledged that he executed the same for the purposes therein contained, and desired the same might be recorded as such. 1N WITNE2~S W~EOF, I hereunto set my hand and official seal. Not~3, Publi~" - r'-' t My Commission Expires: NOTAR1AL SEAL i MICHELE A. RENEKER, Notary Public Oity of Harrisburg, Dauphirt County M[Commiss~'~ Expires March 17, 2007 OF?;CtAL USE I so that we caf · Attach this ca~ or on the front · 1, 2, and 3. Al~o comlY, ete · Print your narrle and ~cldress on the reverse return the card to you. :1 to the back of the mailpiece, if space permits. PS F Received e of Delivery D. Is delivery e~ [] Yes if YES, E [] No Registered [] Return Receipt for Memhandise [] In~Jmd Mail [] C.O.D. 102595-02-M-1540 CRAIG A. MORROW, Plaintiff V. LISA A. RAYHART, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5520 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this ~g day of ~ ,2003, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The Father, Craig A. Morrow, and the Mother, Lisa A. Rayhart, shall have shared legal custody of the minor child, Craig A. Morrow, Jr., born December 15, 1990. 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 his health, education and religion. Pursuant to the terms of Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Mother shall have primary physical custody subject to Father's rights of partial custody which shall be arranged as follows: A. To commence December 5, 2003, on alternating weekends from Friday at 5:30 p.m. to Sunday at 4:00 p.m. B. At such other times as the parties agree. 3. Transportation. Transportation incident to the custodial exchanges shall be shared by the parties with the parent obtaining custody providing transportation. 4. The parent enjoying custody shall be responsible for providing adequate supervision for the child's various sporting activities. NO. 03-5520 CIVIL TERM 5. Vacation. Each parent shall be entitled to three (3) non-consecutive blocks of time, consisting of eight (8) days each, for vacation to occur during the summer school recess· These vacation times shall run from Friday to Friday, to commence with the at least thirty traveling parent custodial weekend· The parties will provide each other with (30) days notice of their intended vacation plans. In the event that the parties have scheduled conflicting or overlapping vacations, the party first providing written notice shall have choice of the vacation time. 6. Holidays. The holiday schedule shall take precedence over the ordinary schedule· Holidays shall be shared in accordance with the following arrangements: A. Christmas. Christmas shall be arranged in an NB schedule· Segment A shall be from December 24th at Noon until Christmas Da~ at Noon· Segment B shall be from December 25th at Noon until December 26"' at Noon· In odd-numbered years, Mother shall have Segment A and Father shall have Segment B. In even-numbered years, Father shall have Segment A and Mother shall have Segment B. B. Thanksqiving. The parties will alternate the Thanksgiving holiday which shall be defined as that period from Wednesday before Thanksgiving at 6:30 p.m. until Thanksgiving Day at 6:30 p.m. Father shall have the Thanksgiving holiday in odd-numbered years and Mother shall have the Thanksgiving holiday in even-numbered years. C. Three-~. Mother shall have Memorial Day weekend and Labor Day weekend each year. The custodial period for these holidays shall be from Friday at 5:30 p.m. until Monday at 4:00 p.m. Father shall have Martin Luther King weekend and Columbus Day (observed) weekend each year. The custodial period for these holidays shall be from Friday at 5:30 p.m. until Monday at 4:00 p.m. In the event that either the child or a parent is not off work or school on one of these Monday holidays, that parent shall be entitled to choose an alternate three-day holiday weekend. D. Easter and Independence Day. In odd-numbered years, Father will have custody for Easter and Mother will have custody for Independence Day. In even-numbered years, Mother will have custody for Easter and Father will have custody for Independence Day. The custodial period for Easter shall be from 10:00 a.m. to 4:00 p.m. The custodial period for Independence Day shall be from July 3rd at 5:30 p.m. until July 5th at 4:30 p.m. NO. 03-5520 CIVIL TERM 7. Both parents will endeavor to have the child arrive at his various activities and sports in a timely fashion during their custodial periods. 8. In the event that the parties need or want to trade custodial weekends, the parent who has agreed to trade weekends shall be entitled to a make-up weekend. 9. Cumberland County Court of Common Pleas shall retain jurisdiction of this matter. Dist: BY THE COURT: ~¢'ruce D. Foreman, Esquire, 4409 N. Front Street, Harrisburg, PA 17110 ~zindsay Gingrich Maclay, Esquire, 26W. High Street, Carlisle, PA 17013 \%. o CRAIG A. MORROW, Plaintiff LISA A. RAYHART, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5520 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody COnciliator submits the following report: 1. The pertinent information concerning the child who is the subject of this litigation is as follows: NAME. Craig A. Morrow, Jr. DATE OF BIRTH December 15, 1990 CURRENTLY IN THE CUSTODY OF, Mother 2. A Custody Complaint was filed on October 17, 2003 by Father. A Custody Conciliation Conference was held on November 24, 2003 with the following individuals in attendance: the Father, Craig A. Morrow, and his counsel, Bruce D. Foreman, Esquire; the Mother, Lisa A. Rayhart, and her counsel, Lindsay Gingdch Maclay, Esquire. 3. The parties reached an agreement in the f~Order as attached. / ~ ! M'~lissa Peel Greevy, Esquif'e Date~ \ Custody Conciliator :221380 CRAIG A. MORROW, Plaintiff VS. LISA A. RAYHART, Defendant * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, PENNSYLVANIA * NO. 03-5520 CIVIL TERM * CIVIL ACTION -. LAW * CUSTODY PETITION FOR IMMEDIATE HEARING AND MODIFICATION OF CUSTODY ORDER AND NOW, comes Plaintiff, CRAIG A. MORROW, by and through his attorney, Bruce D. Foreman, Esquire and FOREMAN & FOREMAN, PC, and respectfully represent as follows: 1. Plaintiff, Craig A. Morrow, (hereinafter "Father") is an adult individual sui juris, residing at 106 Grant Street, Enola, Cumberland, County, Pennsylvania, 17025. 2. Defendant, Lisa A. Rayhart, (hereinafter "Mother") is an adult individual suni juris, residing at 4725 Enola Road, Newville, Cumberland County, Pennsylvania, 17241. 3. Father, Mother and child, Craig A. Morrow, Jr., born December 15, 199o, now ~3 years of age, have been bonafide residents of this Commonwealth for at least six (6) months immediately previous to the filing of this Petition. 4. Plaintiff is the Father of the minor child, Craig A. Morrow, Jr. 5. Defendant is the Mother of the minor child, Craig A. Morrow, Jr. 6. An Order of Court was issued by the Honorable Kevin J. Hess on December 3, 2003 with attached Custody Conciliation Summary Report of Melissa P. Greevy, Esquire, granting shared legal custody of the minor child, Craig A. Morrow, Jr. A true and correct copy is attached hereto as Exhibit "A' and made a part hereof. 7. Father requests primary physical custody of the minor child, Craig A. Morrow, Jr., as follows: a. Father requests that custody be modified to grant Father primary physical custody based upon the expressed desire of the minor child to reside primarily with him; b. Father believes and therefore avers that the best interest, physical, mental, and permanent welfare of the child will be served by granting the requests because Father is able to provide a be~ter stable environment for the child; c. Father believes numerous benefits to the child would result from this ongoing stable relationship and the care and love that would be provided to him; d. Father believes and therefore avers that he is better able to facilitate Mother's periods of partial physical custody with the child; e. Father believes and therefore avers that Father would nurture the relationship between child and mother. 8. The child is presently in the physical custody of the Defendant. 9. At birth, the minor child resided for the first (lst) year of his life with Plaintiff and Defendant; thereafter, the minor child resided with Defendant and currently resides with Defendant/Mother, stepfather and two minor stepbrothers at 4725 Enola Road, Newville, WHEREFORE, Plaintiff requests this Honorable Court to enter an Order granting primary physical custody of the said child, Craig A. Morrow, ~r., to Plaintiff, Father, Craig A. Morrow. By: Respectfull,~.~mit~ed, FOR~EMAN, PC Attbrn'~ID 21193 4409 North Front S~reet Harrisburg, PA 17110 (717) 236-9391 Attorney for Plaintiff CRAIG A. MORROW, Plaintiff VS. LISA A. RAYI-IART, Defendant * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, PENNSYLVANIA * NO. O3'55:~o CML TERM * CIVIL ACTION ,- LAW * CUSTODY VERIFICATION 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. CRAIG A. I¥iORROW CRAIG'A. MO'RROW, Plaintiff V. LISA A. RAYHART, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5520 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this 3f'& b f~% day of P-O.~. ~.~ ,2003, upon consideration of the attached Custody Conciliation Summary Report, it is~'hereby ordered and directed as follows: 1. Legal Custody. The Father, Craig A. Morrow, and the Mother, Lisa A. Rayhart, shall have shared legal custody of the minor child, Craig A. Morrow, Jr., born December 15, 1990. Each parent shall have an equal dght, 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 his health, education and religion. Pursuant to the terms of Pa. C. S. {}5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Mother shall have primary physical custody subject to Father's rights of partial custody which shall be arranged as follows: A. To commence December 5, 2003, on alternating weekends from Friday at 5:30 p.m. to Sunday at 4:00 p.m. B. At such other times as the parties agree. 3. Transportation. Transportation incident to the custodial exchanges shall be shared by the parties with the parent obtaining custody providing transportation. 4. The parent enjoying custody shall be responsible for providing adequate supervision for the child's various sporting activities. EXHIBIT "A" NO. 03'5520 'CIVIL TERM 5. Vacation. Each parent shall be entitled to three (3) non-consecutive blocks of time, consisting of eight (8) days each, for vacation to occur during the summer school recess. These vacation times shall run from Friday to, Friday, to commence with the traveling parent's custodial weekend. The parties will provide each other with at least thirty (30) days notice of their intended vacation plans. In '[he event that the parties have scheduled conflicting or overlapping vacations, the party first providing written notice shall have choice of the vacation time. 6. Holidays. The holiday schedule shall take precedence over the ordinary schedule. Holidays shall be shared in accordance with the following arrangements: A. Christmas. Christmas shall be arranged in an NB schedule. Segment A shall be from December 24t~ at Noon until Christmas D~at~ at Noon. Segment B shall be from December 25th at Noon until December 26 at Noon. In odd-numbered years, Mother shall have Segment A and Father shall have Segment B. In even-numbered years, Father shall have Segment A and Mother shall have Segment B. B. Thanks,qivinq. The parties will alternate the Thanksgiving holiday which shall be defined as that period from Wednesday before Thanksgiving at 6:30 p.m. until Thanksgiving Day at 6:30 p.m. Father shall have the Thanksgiving holiday in odd-numbered years and Mother shall have the Thanksgiving holiday in even-numbered years. C. Three-Day Holidays. Mother shall have Memorial Day weekend and Labor Day weekend each year. The custodial period for these holidays shall be from Friday at 5:30 p.m. until Monday at 4:,00 p.m. Father shall have Martin Luther King weekend and Columbus Day f, observed) weekend each year. The custodial period for these holidays shall be from Friday at 5:30 p.m. until Monday at 4:00 p.m. tn the event that either the child or a parent is not off work or school on one of these Monday holidays, that parent shall be entitled to choose an alternate three-day holiday weekend. D. Easter and independence Day. In odd-numbered years, Father will have custody for Easter and Mother will have custody for Independence Day. In even-numbered years, Mother will have custody for Easter and Father will have custody for Independence Day. The custodial period for Easter shall be from 10:00 a.m. to 4:00 p.m. The custodial period for Independence Day shall be from July 3rd at 5;30 p.m. until July 5th at 4:30 p.m. NO. 03'-5520 CIVIL TERM 7. Both parents will endeavor to have the child ardve at his various activities and sports in a timely fashion during their custodial periods. 8. In the event that the parties need or want 1:o trade custodial weekends, the parent who has agreed to trade weekends shall be entitled to a make-up weekend. 9. Cumberland County Court of Common Pleas shall retain jurisdiction of this matter. Dist: Bruce D. Foreman, Esquire, 4409 N. Front Street, Harrisburg, PA 17110 Lindsay Gingdch Maclay, Esquire, 26W. High Street, Carlisle, PA 17013 ~;.L,E COPY F,,.' In ~hc~of, "'t~ s~t nly hand afl,the s~al or s(~ Court ~ Carlisle, Pa. CRAIG A. MORROW, Plaintiff V. LISA A. RAYHART, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5520 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Craig A. Morrow, Jr. December 15, 1990 Mother 2. A Custody Complaint was filed on October 17, 2003 by Father. A Custody Conciliation Conference was held on November 24, 2003 with the following individuals in attendance: the Father, Craig A. Morrow, and his counsel, Bruce D. Foreman, Esquire; the Mother, Lisa A. Rayhart, and her counsel, Lindsay Gingrich Maclay, Esquire. 3. The parties reached an agreement in the f~'of an-')Order as attached. Da ' Custody Conciliator :221380 CRAIG A. MORROW PLAINTIFF V. LISA A. RAYHART DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 03-5520 CIVIL ACTION LAW : : IN CUSTODY ORDER OF COURT AND NOW, Tuesday, May 04, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq.___, the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Monday, June 07, 2004 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an eflbrt 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 l~resent at the conference. Fa/lure to apl~ear 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/ Melissa P. Greevy. Esq. mhc 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 befbre the court. You must attend the scheduled conference or heating. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CRAIG A. MORROW, Plaintiff LISA A. RAYHART, Defendant CIVIL ACTION - LAW No. 2003 - 5520 (In Custody) PRAECIPE OF WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Upon mutual consent of the undersigned, please Withdraw my Appearance on behalf of Defendant,/Lisa A. Lis;-A~. Rayhart, ~ef~.~tn~ Date: ~//~L/_/~ ¢ Rayhart' in the ab~~~-~~ ,.~ ( yi-~dsay Oix~ri(e-h I~aclay, Esqui~ ~ A(tomey I.D. 87954 SAIDIS, SHUFF, FLOWER & L1NDSAY 26 West High Street Carlisle, Pennsylvania 17013 (717) 243-6222 PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please Enter my Appearance, Pro Se, in the above-captioned matter. Lisa A.Y'Rayha~,~e fern t PRO SE ~ 4725 Enola Road Newville, Pennsylvania 17241 cc: Melissa Peel Greevy, Esquire Brace D. Foreman, Esquire CRAIG A. MORROW, Plaintiff LISA A. RAYHART, Defendant JUN ]. 4= 2004 ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5520 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY HESS, J.--- ORDER OFCOURT AND NOW, this ~?' day of June, 2004, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: This Court's Order of December 3, 2003 shall remain in full force and effect with the following additions: 1. Disciplinary techniques other than those of physical discipline will be used at times when CJ is in need of discipline. 2. Father will contact the child's therapist and participate in his mental health care as recommended by the therapist. Dist: BY THE COURT: evin A. Hess, J. Bruce D. Foreman, Esquire, 4409 N. Front Street, Harrisburg, PA 17110 Lisa A. Rayhart, 4725 Enola Road, Newville, PA 17241 CRAIG a. MORROW, LISA A. RAYHART, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 03-5520 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Craig A. Morrow, Jr. December 15, 1990 Mother 2. Father filed a Petition for Immediate Hearing and Modification of Custody on April 27, 2004. A Custody Conciliation Conference was held on June 7, 2004 with the following individuals in attendance: the Father, Craig A. Morrow, and his counsel, Bruce D. Foreman, Esquire; the Mother, Lisa A. Rayhart, appeared p~) se. 3. The parties reached an agreement in the form of,~as attached. Melissa Peel Greew, Esquire Custody Conciliator :230390