Loading...
HomeMy WebLinkAbout03-5607 IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA WILLIAM TAYLOR, Plaintiff V. NATALIE A. TAYLOR ACRI, Defendant NO. 2003 CV 3890 CU CIVIL ACTION - LAW IN CUSTODY ORDER AND NOW, ay of , HEREBY ORDERED that: upon consideration of the within Peti 1~1on IT IS The Rule entered on September 22, 2003 is hereby made absolute. This Court declines to exercise jurisdiction over this custody case; The case shall be transferred to Cumberland County, PA to the custody case in that County docketed to No. 01-623.1~.~ ~hi J. Stephen E. Farina Prothonotary OFFICE OF ¥1 ,O fHONO TA/ y County of Dauphin Front & Market Streets Harrisburg, PA 17101 (717) 780-6520 Curtis R Long, Prothonotary Cumberland County Court House Hanover & High Streets Carlisle, Pa 17013 IN RE: William Taylor Vs Natalie A Taylor Acri Dauphin County Dkt No 2003 CV 3890 Cumberland County Dkt No. t~5~ - ..~, Oct 15, 2003 Dear Sir/Madam: By Order of October 8, 2003 by Hon Todd A. Hoover, Judge The above matter has been transferred to the Court of Common Please of Cumberland County. I am, accordingly, sending originals of all the papers herewith. I Will appreciate the return of the attached receipt address to the Attention: of Ms. Lisandra Garcia. Very truly yours, Stephen E. Farina Prothonotary .ate: 10/15/2003 Time: 03:09 PM Page 1 of 1 Dauphin County ROA Report Case: 2003-CV-3890-CU Current Judge: No Judge William Taylor vs. Natalie Taylor CustodyNisitation User: LGARCIA Date 9/9/2003 9/11/2003 9/15/2003 9/18/2003 9/22/2003 10/3/2003 10/8/2003 10/15/2003 New Civil Case Filed This Date. Filing: Custody Complaint Paid by: Mancke Wagner & Spreha Receipt number: 0041740 Dated: 9/9/2003 Amount: $220.00 (Check) Complaint in Custody, filed. Upon consideration of the Petition for Emergency Relief, the Court hereby DENIES the said Petition. The Court will schedule a prompt conciliation. See ORDER filed. Copies Mailed 9-12-03. Custody Pre-Hearing Conference Order: You are ordered to appear in person at the Dauphin County Courthouse, Front and Market Sts., 4th Floor, Harrisburg, PA. on September 19, 2003 at 12:00 PM for a Custody Conciliation Conference. At the conference an effort will be made to resolve the issues, and to enter into an agreement. Children need not be present unless their presence is requested by the Custody Conference Officer. if you fail to appear as provided by this Order, an Order for Custody may be entered against you or the Court may issue a warrant for your arrest. See ORDER, filed. Copies to Arty ........ Petition objecting to jurisdiction and requesting the transfer of the case to Cumberland County Pennsylvania, filed Upon consideretin of the within Petition, a Rule is entered upon the Respondent, William Taylor, to show cause, if any he has, why the relief requested in the within Petition should not be granted. Rule returnable five (5) days after service. Pending the hearing or decision by this Court all action or proceedings on the judgment entered in this matter shall be stayed. See RULE filed. Copies Mailed 9-23-03. Motion to Make Rule Absolute, filed Certificate of service of Rule entered on September 22, 2003 upon plaintiff's counsel, filed Upon consideration of the within Petition it is hereby ORDERED that: 1. The Rule entered on September 22, 2003 is hereby made absolute. 2. This Court declines to exercise jurisdiction over this custody case; 3. The case shall be transferred to Cumberland County, PA to the custody case in that County docketed to No. 01-623. Dauphin County Prothonotary's Office is directed to transfer Records to Cumberland County. The above case is hereby Transfer to the Court of Common Pleas of Cumberland County. .... NO MORE ENTRIES CASE TRANSFERRED**** TO COURT OF CUMBERLAND COUNTY Judge No Judge No Judge No Judge Todd A. Hoover No Judge No Judge Todd A. Hoover No Judge No Judge Todd A. Hoover No Judge No Judge I hereby cer~Jfy t!~t tile for~;~joing is a true ~d corr~ c~y,.o[ i:~ orioinal ~ed. IMAGED WILLIAM TAYLOR, Plaintiff VS. NATALIE TAYLOR, Defendant : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNS~Y~LV,ti~I~IA : NO. 3890 CV 2003 CU ..~ : CIVIL ACTION - CUSTODY ..< ORDER AND NOW, this 11th day of September 2003, upon consideration of the Petition for Emergency Relief, the Court hereby DENIES the said Petition. The Court will schedule a prompt conciliation. BY THE COURT: Todd A. Hoover, Judge Distribution: P. Richard Wager, Esquire, 2233 North Front Street, Harrisburg, PA 17110 Natalie a. Taylor Acri, 755 Temj Hall Road, Millersburg, PA WILLIAM TAYLOR, Petitioner, V. NATALIE TAYLOR, Respondent. : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYLVANIA :NO: (~OO.~.~ Q.XJ 3 :q0 d~ : CIVIL ACTION - LAW : IN CUSTODY ORDER AND NOW, this day of ,2003, upon Petition for Emergency Relief filed by the father, William Taylor, a hearing is set for the__day of ,2003, at o'clock m. in Courtroom No.__ of the Cumberland County Courthouse, One Courthouse Square, Carlisle, Cumberland County, Pennsylvania. In the interim, it is hereby DIRECTED that the Respondent shall return the children to the jurisdiction of this Court pending outcome of a hearing. BY THE COURT: WILLIAM TAYLOR, Petitioner, · IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYLVANIA Joo3 ecl J qO NATALIE A. TAYLOR ACRI, Respondent. : CIVIL ACTION - LAW : IN CUSTODY PETITION FOR EMERGENCY RELIEF AND NOW, comes your Petitioner, William Taylor, by and throu ~gh~s .~. attorneys, Mancke, Wagner & Spreha, and files the following Petition for Emergency Relief: 1. Your Petitioner, William Taylor, is an adult individual residing at 427 S. York Street, Mechanicsburg, C-mberland County, Pennsylvania. 2. Respondent, Natalie A. Taylor Acri, is an adult individual residing in Pottstown, Pennsylvania, at an address ,nknown to the Petitioner, having previously lived at 755 Terry Hall Road, Millersburg, Dauphin County, Pennsylvania. 3. Petitioner and Respondent were husband and wife, having since divorced, and the Respondent remarried Dr. Joseph Ach. 4. The parties are the natural parents of three (3) children, Katherine, bom September 14, 1990, Eden, born November 18, 1991, and Brooke, born June 2, 1996. 5. Petitioner is the natural father of the aforementioned children; Respondent is the natural mother. 6. The children were all born during wedlock. 7. During the last five (5) years, the children have resided at the following addresses with the following persons: A. During the previous five (5) years up until January 29, 2001, with the Petitioner and Respondent at 63 North 3 l~t Street, Camp Hill, Cumberland County, Pennsylvania; B. From January 29, 2001, until approximately the Summer of 2002, with the Respondent and her husband, Dr. Joseph Acri at 63 N. 31~ Street, Camp Hill, Cumberland County, Pennsylvania; C. From the Summer of 2002 until the end of August 2003, at 755 Terry Hall Road, Millersburg, Dauphin County, Pennsylvania, with the Respondent and her husband; D. From the end of August 2003 with the Respondent and her husband at an address unknown in Pottstown, Pennsylvania. 8. At the end of August 2003, during a period of partial custody with the Petitioner herein, the children confided in the Petitioner that the mother was removing them f~om school and moving somewhere in Pottstown. 9. Petitioner herein inquired of the Respondent where she was moving, and Respondent hn.~ refu.~d to di.qclose the location where they are livi~1~, refiz~l to di~lose the name of the school that the children are attending, and refused to provide the Petitioner with any contact whatsoever concerinng the move. 10. Petitioner believes and therefore avers that the move was not made in the best interests of the children, was self-serving to the Petitioner and her new husband, and is designed to maintain a strong relationship between the children and the Petitioner. 11. Petitioner's immediate family as well as Respondent' s immediate family live in the Central Pennsylvania Area, i.e., Camp Hill and Mechanicsburg area. 12. Petitioner believes the surreptitious conduct of the Respondent is designed to defeat the Petitioner's rights of custody and partial custody of his 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 unsworn falsification to authorities. Section 4904, relating to ~~~~ Pa.C.S. DATE: WILLIAM TAYLOR, Plaintiff : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYLVANIA vs. : NO. 2003 CV 3890 CU NATALIE TAYLOR ACRI, Defendant : CHILD CUSTODY ORDER You are ORDERED to appear in person at the Dauphin County Courthouse, Front & Market Streets, 4th Floor, Harrisburg, Pennsylvania on September 19, 2003 at noon for a Custody Conciliation Conference. At the conference an effort will be made to resolve the issues, and to enter into an agreement. Children need not be present unless their presence is requested by the Custody Conference Officer. If you fail to appear as provided by this Order, an Order for custody may be entered against you or the Court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR 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. Dated: Dauphin County Lawyer Referral 213 North Front Street Harrisburg, (717) Service Pennsylvania 17101 232-7536 09/11/2003 10:12 FAX 717 7~0 6463 COURT ADMINISTRATORS OFC ~001 CAROLYN C. THOMPSON, ESQ. Cour~ Admini~lta~0r (717) 780-6620 Fax - (717} 780-6463 E-Mail- c~hompson~da'uphinc.org Address: Dauphin County Coun House Fron~ & ~kct H~is burg, PA 17101 Dauphin COURT OF COMMON PLF. AS Twelfth Judicial Dis~'ict FAX COVER SHEET Deputy Court Admlnistralors DEBORAH S FREEMAN, ESQ. Civil Court 78{~6632 ROBERT P. HAWLEY 780-66a2 PHILIP M. INTR/EKI, ESQ. BARBARA A, LUNDGILEN 780-6635 To: Judy Calkin Company: Phone: Fax: From: Deb Freeman Company; Phone: Fax: Date: Pages including this cover page: Comments: 9/11/2003 AhY quest}ons, o~ problemsWithfax,.please call Ca;'olyn ThornPsOn at 780-6622. Thank You. 09/11/2003 10:12 FAX 717 780 6463 CO['RT ADMINISTRATORS OFC ~002 WILLIAM TAYLOR, Plaintiff vs. NATALIE TAYLOR, Defendant IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO, 38g0 CV 2003 CU CIVIL ACTION - CUSTODY ORDER AND NOW,'this 11 th day of September 2003, upon consideration of the Petition for Emergency Relief, the Court hereby DENIES the said Petition. The Court will s~clule a prompt conciliation, BY THE COURT: Todd A. Hoover, Judge Distribution: P. Richard Wager, Esquire, 2233 North Front StreeL Harrisburg, PA 17110 Natalie a. Taylor Acd, 755 Terry Hall Road, Millersburg, PA 09/11/2003 I0:13 FAX 717 780 6463 COURT ADMINISTRATORS OFC O03 W'ILLIAM TAYLOR, P~itioneq ¥. : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYLVANIA :NO: 3 qo : CIVIL ACTION - LAW NATALIE TAYLOR, : IN CUSTODY KeR~oadeat, : AND NOW, this .day of ,2003, upon Petition for Emergency Relief fried by the father, William Taylor, a hearing is set for the day of ,2003, at o'clock m. in Coumoom No. of the Cumberland County Courthouse, One Courthouse Square, Carlisle, Cumberland County, P~nn~ylvania. In the interim, it is hereby DIRECTED that the Respondent shall return the children to the jurisdiction of this Court pending ~e of a hearing. BY THE COURT: 09/i1/2003 10:13 FAX 717 ?80 8453 COURT ADHINISTRATOR$ OFC WH~.~AMTAYLO~ P~ NATALIE A. TAYLOR. ACP, I, THE COURT OF COMIVIOIg PLHAS DAUPPHN COUNTY, PE~S~V~ C~ AC~ON - LAW CUSTODY PETfFION FOR ElWlF.~,G~_,NCY RI~.Lll~.F ~ NOW, mines yo~ Pefifion~, aH~eys, Mnncke, W~er & Spreha, ~d ~cs ~e foHo~g P~fion for ~m~n~ 1. Yo~ P~, W~ Tay~, is ~ ~ ~u~ rasing ~ 427 S. Yo~ S~, M~c~g, Cum~ Co~, Penn~l~a. 2. Reset, N~ A. Taylor Ac~ is ~ ~ ~fl ~i~g m P~, P~~ ~ ~ a~ ~ ~ ~e Pefi~on~, ha~g ~sly ~d at 755 Te~ ~ Ro~ ~!~sb~g, Dauphin ~W, P~n~l~ 3. P~n~ ~d R~t were hus~d ~d ~e, ha~g sm~ ~vor~ 09/11/2003 10:13 FAX 717 780 6463 COURT ADMINISTRATORS 0FC ~005 4. The frarties are the natural parents ofthrce (3) children, Katherine, born September 14, 1990, Eden, born November 18, 1991, and Brooke, bom June 2, 1996. 5. Petitioner is the natural father of the aforementioned children; Respondent is the natural mother. 6. The children were all bom during wedlock. 7. During the last five (5) years, the children have resided at the following addresses with the following persons: A. During the previous five (5) years up until Sanual~ 29, 2001, with thc Petitioner and Respondent at 63 North 31't Slreet, Camp frill. Cumberland County, Pennsylvnnla; B. From Janua~ 29, 2001, mttfi approxim~lo, ly tile S~mmer of 2002, with the Respoadent and her husband, Dr. Joseph A~ri at 63 N. 31 ~ Street, Camp Hill, C~mberland County, Pennsylvania; C. From thc Snmmer of 2002 untiltho end of August 2003, at 755 Terry H~II Road, Mille~burg, Dauphin County, petmsylv~n~a, with the Respondent and he~ husband; 09/11/2003 10:13 FAX 717 780 6463 COURT ADMINISTRATORS OFC ~006 D. From lt~ end of August 2003 with the Respondgnt and her husband at an address unknown m Pottstown, Pennsylvania. 8. Atth¢ end of Augu~t 2003, during a pmiod ofpartial custody with the Petitioner h~rein, the children co_n_fid~ed in the P~i~oner that the mother was removing them from school and moving somewhere m Pott~own. 9. P~ti6oner hereto mquire~ of the Responde, nt wl~rc she was moving, and ~ has refused to ai~4,~ the location wi~ere they are I~viag, refused tO disclose the name of the school lhst *be ehildrell lire a14Ppdin~, and refused to provide the Petitione~ with any coo~t whatsoever concerning thc movc. ! O. Peti6oner believes and thcref~e avers that the move wa~ not made in the best interests of the children, was serf-serving to the Petitioner and her new husband, and is designed to ma~to~ a strong relationship between the children and the Petifoner. 11. Petitioner's immediate fmnily as well a~ R~spondent's immediate family live in the Central Pennsylvania Area, i.e., Camp Hill and Mew, hani¢$burg area. 12. Petitioner believes the surreptitious conduct of the Respondent is desigmxl to defeat the Petitioner's rights of custody and partial custody of his children which is further evidenced by the fact that as of the filing of thi.q Petition, Respondent has not disclosed to the Petitioner the location of the children, the address, the school and the name of the medical provider or any other information whatsoever. 13. P~Giioner has attempted to contact the Respondent, however, she has refused to di~lose the location of the Respondent and the children. WHERRgORE, Petitioner prays this Court to grant his emergency rellefin the form of awarding custody of the children to h/m immeatiately, pending a hearing to determine whether or not under Graber v. Graber, the move is in the best interests of the children. ate: Respectfully submitted, Mancke, Wagner & Spreha h ~7. Ric ~rd Wagner, Esquire I.D. #23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Petitioner 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. unsworn falsification to authorities. Section 4904, relating to ~~~ DATE: WILLIAM TAYLOR, Petitioner, V. NATALIE A. TAYLOR ACRI, Respondent. : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYLVANIA NO: CIVIL ACTION - LAW IN CUSTODY PETmON FOR EMERGENCY RELIEF AND NOW, comes your Petitioner, William Taylor, by and through his attorneys, Mancke, Wagner & Spreha, and files the following Petition for Emergency Relief: 1. Your Petitioner, William Taylor, is an adult individual residing at 427 S. York Street, Mechanicsburg, Cumberland County, Pennsylvania. 2. Respondent, Natalie A. Taylor Acri, is an adult individual residing in Pottstown, Pennsylvania, at an address unknown to the Petitioner, having previously lived at 755 Terry Hall Road, Millersburg, Dauphin County, Pennsylvania. 3. Petitioner and Respondent were husband and wife, having since divorced, and the Respondent remarried Dr. Joseph Ach. 4. The parties are the natural parents of three (3) children, Katherine, bom September 14, 1990, Eden, bom November 18, 1991, and Brooke, bom June 2, 1996. 5. Petitioner is the natural father of the aforementioned children; Respondent is the natural mother. 6. The children were all bom during wedlock. 7. During the last five (5) years, the children have resided at the following addresses with the following persons: A. During the previous five (5) years up until January 29, 2001, with the Petitioner and Respondent at 63 North 31~t Street, Camp Hill, Cumberland County, Pennsylvania; B. From January 29, 2001, until approximately the Summer of 2002, with the Respondent and her husband, Dr. Joseph Acri at 63 N. 31st Street, Camp Hill, Cumberland County, Pennsylvania; C. From the Summer of 2002 until the end of August 2003, at 755 Terry Hall Road, Millersburg, Dauphin County, Pennsylvania, with the Respondent and her husband; D. From the end of August 2003 with the Respondent and her husband at an address unknown in Pottstown, Pennsylvania. 8. At the end of August 2003, during a period of partial custody with the Petitioner herein, the children confided in the Petitioner that the mother was removing them fi.om school and moving somewhere in Pottstown. 9. Petitioner herein inquired of the Respondent where she was moving, and Respondent has refused to disclose the location where they are livinl~, refused to disclose the name of the school that the children are attending, and refused to provide the Petitioner with any contact whatsoever concerning the move. 10. Petitioner believes and therefore avers that the move was not made in the best interests of the children, was self-serving to the Petitioner and her new husband, and is designed to maintain a strong relationship between the children and the Petitioner. 11. Petitioner's immediate family as well as Respondent's immediate family live in the Central Pennsylvania Area, i.e., Camp Hill and Mechanicsburg area. 12. Petitioner believes the surreptitious conduct of the Respondent is designed to defeat the Petitioner's rights of custody and partial custody of his children which is further evidenced by the fact that as of the filing of this Petition, Respondent has not disclosed to the Petitioner the location of the children, the address, the school and the name of the medical provider or any other information whatsoever. 13. Petitioner has attempted to contact the Respondent, however, she has refused to disclose the location of the Respondent and the children. WHEREFORE, Petitioner prays this Court to grant his emergency relief in the form of awarding custody of the children to him immediately, pending a hearing to determine whether or not under Graber v. Crmber, the move is in the best interests of the children. ate.' Respectfully submitted, Mancke, Wagner & Spreha Wagner, Esquire I.D. #23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Petitioner 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. Section 4904, relating to unsworn falsification to authorities. DATE: 1N THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA WILLIAM TAYLOR, Plaintiff V. NATALIE A. TAYLOR ACRI, Defendant NO. 2003 CV 3890 CIVIL ACTION - LAW IN CUSTODY PETITION OBJECTING TO JURISDICTION AND REQUESTING THE TRANSFER OF THE CASE TO CUMBERLAND COUNTY PENNSYLVANIA AND NOW, this ~'~day of September, comes the Petitioner, Natalie A. Acri, by her attorney, Diane G. Radcliff, Esquire, and files the above referenced Petition Objecting to Jurisdiction and Requesting the Transfer of the Case to Cumberland County Pennsylvania and represents that: Your Petitioner is Natalie A. Acri an adult individual residing at 792 W. Pineford, Boyertown, Berks County, PA 19512 and is the Defendant in the above captioned case. Your Petitioner is hereafter referred to as "Mother". Your Respondent is William Taylor, an adult individual residing at 427 S. York Street, Mechanicsburg, Cumberland County, PA. And is the Plaintiff in the above captioned case. Your Respondent is hereafter referred to as "Father". The parties are the parents of three children, to wit: Katherine, born on 9/14/90; Eden, born on 11 / 18/91 and Brooke, bom on 6/2/96. The children have been in the primary custody of Mother since the parties' separation on January 29, 2001. On May 11,200, an Order of Court was entered by the Honorable Edward Guido, Judge of the Court of Common Pleas of Cumberland County, PA in the case captioned as follows: Natalie A. Taylor vs. William Taylor, Cumberland County Docket No. 01-623. A true an correct copy of the May I1, 2001 Order is attached hereto, marked Exhibit "A" and made a part hereof. The present action was initiated by the filing of a Petition for Emergency Relief by Father on or about September 9, 2003. A true and correct copy of that Petition for Emergency Relief is attached hereto, marked Exhibit "B" and made a part hereof. No mention was made in the aforementioned Petition for Emergency Relief as to the existence of the May 11, 2001 Cumberland County Custody Order. The Court of Dauphin County, PA should not exercise jurisdiction over this case and the case should be transferred to Cumberland County, PA because: Mother, Father and the children lived at 63 North 31st Street, Camp Hill, Cumberland County, PA from August 1996 until the parties' separation on or about January 29, 2001; Subsequent to the parties' separation Mother and the children continued to live at 63 North 31st Street, Camp Hill, Cumberland County, PA from Janum'y 18, 2001 until late August of 2002. In late August 2003, Mother and the children and her current husband, Dr. Joseph Acri, moved to 755 Tarry Hall Road, Dauphin County, PA where the continued to reside until August 18, 2003, a period of less than one (1) year. On August 18, 2003, as the result of a job change, which was and is of significant benefit to the children, Mother, the children and mother's current husband, Dr. Joseph Acri, moved to a temporary residence in Douglasville, PA and on September 17, 2003 to their permanent new home located at 792 W. Pineford, Boyertown, Berks County, PA 19512. There is no emergency as alleged by Father in that Mother has continued to provide Father with his allotted partial custody rights and has provided the transportation for the exercise of those rights even though not required to do so by the May t 1, 2003 Cumberland County, PA Order. The statements in Father's Emergency Petition that Mother did not provide Father with information regarding the children's residence address, school and other information are not true. 2 The children have had, have, and will continue to have, significant contacts with Cumberland County, PA in that: The children have lived in Cumberland Count, PA for all but one year of their lives; Father lives in Cumberland County, PA and exercises his custodial rights in that county. The children's maternal grandparents, with whom the children have a significant relationship, live in Camp Hill, Cumberland County, PA; 4. The children's paternal grandparents live in Cumberland County, PA; Most of the past and much of the current and future information regarding the children is in Cumberland County, PA; There is no current information, nor will there be any future information regarding the children in Dauphin County, PA. The children have no significant contacts with Dauphin County, PA as the children, the parents and none of the family members reside in that county. WHEREFORE, Petitioner/Mother requests this Honorable Court to enter an order declining jurisdiction in this case and transferring the case to Cumberland County, PA. Respectfully submitted, DCLIFF, ESQUIRE oad Cam3Ft-I/t't~A 17 011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 Attorney for Petitioner, Natalie A. Acri 3 VERIFICATION I, Diane g. Radcliff, Esquire, having been duly authorized by the Petitioner, and on behalf of the Petitioner, verify that the statements made in the foregoing Petition Objecting to Jurisdiction and Requesting the Transfer of the Case to Cumberland County Pennsylvania are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities bI~DCLIF~, ESQUIRE Dat~.' ~'~ [ ~' ] ~ '~ 09/17/2002 20:45 6109709370 COVENTRYCHRISTIANSCH PAGE 01 VERIFIC, ,," I verify that the staterr~n~s made in ~h~ foregoing Petition oW..etlng to ,~.c~elion and ] und~rstat~ that fals~ statements h~rein ~e ~c subject to thc p~l~es of l 8 Pa.C S. Se~ion ~904, relating to unswom f~lsification to authofiti=s. I fu~t authorize my AUomey, Diane ~cliff, Esquire, Io si~ ~ origi~l verification ~ my b~halE CERTIFICATE OF SERVICE I, DIANE G. RADCLIFF, ESQUIRE, hereby certify that on September 18, 2003 , I served a true and correct copy of the foregoing Petition upon Respondent~s Attorney, P. Richard Wagner, by faxing the same to him at (717) 234-7080 and by mailing same by first class mail, postage prepaid, addressed as follows: P. Richard Wagner, Esquire 2233 North Front Street Harrisburg, PA 17110 Respectfully submitted, ~CLIFF, ESQUIRE Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 EXHIBIT "A" 5/11/01 CUMBERLAND COUNTY CUSTODY ORDER NATALIE A. TAYLOR, VS. WILLIAM S. TAYLOR, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . NO. 01-623 : : CIVIL ACTION ~ LAW Defendant : CUSTODY Guido, J. ORDER OF COURT AND NOW, this tI ~ day o~.~ ,2001, upon consideration of the attached Custody Conciliat---~-on ~ummary Repor~lt is hereby ordered and directed as follows: 1. Legal Custody. The parties, Natalie A. Taylor and William S. Taylor, shall have shared legal custody of the minor Children, Katherine Taylor, born September 14, 1990, Eden Taylor, born November 18, 1991 and Brooke Taylor born June 6, 1996. 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. Pumuant to the terms of Pa. C. S. § 5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children 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. Father shall have partial physical custody arranged as follows: On the following dates, Father shall have physical custody from Friday at 5:00 p.m. until Sunday at 8:00 a.m. May 4, 2001 through May 6, 2001; May 18, 2001 through May 20, 2001; June 1, 2001 through June 3, 2001; July 6, 2001 through July 8, 2001. Additionally, Father shall ha~e custody from Noon until 7:00 p.m. on the Sundays of his custodial weekends and shall make the appropriate adjustments for the Children's soccer schedule. Father shall have physical custody each Tuesday evening from 5:00 p.m. until 8:00 p.m. each Tuesday in May, July 10, 2001, and August 28, 2001 Father shall have the following summer custody schedule: June 22, 2001, through July 1, 2001; July 28, 2001, through August 4, 2001; and August 19, 2001, through August 26, 2001. No. 01-$23 Civil Term Independence Day. Father shall have custody on Independence Day from 4:00 p.m. July 4, 2001, until 9:00 a.m. July 5, 2001. 3. Mother shall provide Father with copies of a schedule of the Children's activities. 4. This Order is temporary in nature. In the event that the parties are not able to resolve the issues of the custody by agreement within sixty days of the date of this Order, counsel for either party may contact the Conciliator to schedule an additional Custody Conciliation Conference. BY TH~ Edward E. Guido, J. Dist: P. Richard Wagner, Esquire, Mancke, Wagner, Hershey & Tully, 2233 N. Front Street, Harrisburg, PA 17110 Austin F. Grogan, Esquire, 24 N. 32r~ Street, Camp Hill, PA 17011 NATALIE A. TAYLOR, VS. WILLIAM S. TAYLOR, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-623 : : CIVIL ACTION - LAW Defendant : CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUME~ERLAND COUN'FY 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: DATE OF BIRTH CURRENTLYIN CUSTODY OF Katherine Taylor Eden Taylor Brooke Taylor September 14, 1990 November 18, 1991 June 6, 1996 Mother Mother Mother 2. A Custody Conciliation Conference was held on April 30, 2001, with the following individuals in attendance: the Mother, Natalie A. Taylor, and her counsel, Austin F. Grogan, Esquire; the Father, William S. Taylor, and his counsel, P. Richard Wagner, Esquire. 3. The parties were seen for a Custody Conciliation Conference and reached an agreement in the form of an Order as attached. Father's counsel shall prepare and file an executed stipulation modifying the terms of the PFA issued by Judge Guido on March 14, 2001, so that its terms will not conflict with the agreements the parties have made with regard to custody of their Children. Custody Conciliator EXHIBIT "B" PETITION FOR EMERGENCY RELIEF SEP-15-2003 02:54PU FROM-UANCKE ~Ai;NEt SP~EHA +Tl?-234-70BO T-727 P 002/002 F-270 WILLIAM TAYLOR,, Plaintiff : IN THE COURT OF COM)4ON PLEAS : DAUPHIN COUNTY, PENNSYLVANIA vs. : NO. 2003 CV 3890 CU NATALIE TAYLOR ACRI, Defendant CHILD CUSTODY ORDER -< ~o ' ', You are ORDERED to appear in person at the Dauphih County Courthouse, Front & Market Streets, 4th Floor, Harrisburg, , Perulsylvania on September 19, 2003 at noon for a Cllstody Conciliation Conference. At the conference an effort will be made to resolve the issues, and to enter into an agreement. Children need not be present unless their presence is requested by the Custody Conference Officer. If you fail to appear as provided by this Order, an Order for custody may be entered against you or the Court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR 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. Dated: Dauphin County Lawyer Referral 213 North Front Harri sburg, (7~7) Street Pennsylvania 232-7536 Service 17101 Custody Coneiliat~ 1 hereby certily that the (oregoi~§ is a tme..~d correct copy~o~ filed,: ' " Promonomy... ,_ ' ' WILLIAM TAYLOR, : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYLVANIA Petitioner, NATALIE A. TAYLOR ACRI, Respondent. CIVIL ACTION - LAW · : IN CUSTODY PETITION FOR EMERGEN~TY RELIEF -r c~ AND NOW, comes your Petitioner, Will/am Taylor, by and through'~'his ~ attorneys, Mancke, Wagner & Spreha, and files the following Petition for Emergency Relief'. 1. Your Petitioner, Will/am Taylor, is an adult ind/vidual residing at 427 S. York Street, Mechanicsburg, Cumberland County, Pennsylvania. 2. Respondent, Natalie A. Taylor Act/, is an adult individual residing in Pottstown, Permsylvan/a, at an address unknown to the Petitioner, having previously hved at 755 Terry Hall Road, Millersburg, Dauphin County, Pennsylvania. 3. Petitioner and Respondent were husband and wife, having since divorced, and the Respondent remarried Dr. Joseph Acri. 4. The par'des are the natura/parents o£three (3) children, Katherine, bom September 14, 1990, Eden, bom November 18, 1991, and Brooke, bom ,lune 2, 1996. 5. Petitioner is the natural father of the aforementioned children; Respondent is the natural mother. 6. The children were all bom during wedlock. 7. During the last five (5) years, the children have resided at the £ollowing addresses with the following persons: A. Dnrmg the previous five (5) years up until January 29, 200 I, w~th the Petitioner and Respondent at 63 North 31'~ Street, Camp Hill, Cumber]and County, Pennsylvania; B. From January 29, 2001, until approximately the Summer of 2002, with the Respondent and her husband, Dr. Joseph Act'/at 63 N. 31 ~* Street, Camp Hill, Cumberland County, Pennsylvania; C. From the Summer of 2002 until the end o£August 2003, at 755 Terry Hall Road, Mfllersburg, Dauphin County, Peunsylvania, with the Respondent and her husband; D. From the end of August 2003 with the Respondent and her husband at an address unknown in Pottstown, Pennsylvania. 8. At the end of August 2003, during a per/od of partial CUstody with the Petitioner hereto, the children confided in the Pefihoner that the mother was removing them from school and moving somewhere in Pottstown. 9. Petitioner herein inquired of the Respondent where she was movir~g, and Respondent has_refused to disclose the location where they are living, refused to disclose the name of the school that the chil0ren are attending, and refused to provide the Petitioner with any contact whatsoever concerning the move. 10. Petitioner beheves and therefore avers that the move was not made in the best interests of the children, was self-serving to the Petitioner and her new husband, and is designed to maintain a strong relationship between the children and the Petitioner. 11. Petitioner's immediate family as well as Respondent~s immediate family I/ve in the Central Permsylvan/a Area, i.e., Camp Hill and Mecbanicsburg area. 12. Petitioner beheves the surreptitious conduct of the Respondent is designed to defeat the Petitioner's fights of custody and partial custody of his SEP-I?-Z0O3 1Z:IgPM FROM-MANCKE WA~NER SPREHA +DT-Z34-70B0 T-735 P005/006 F-31Z children which is further evidenced by the fact that as of the filing of this Petition, Respondent has not disclosed to the Petitioner the location of the children, the address, the school and the name of the medical provider or any other information whatsoever. 13. Petitioner has attempted to contact the Respondent, however, she has refused to disclose the location of the Respondent and the children. WHEREFORE, Petitioner prays this Court to grant his emergency relief m the form of awarding custody of the children to him immediately, pending a hearing to determine whether or not under Graber v. Graber, the move is in the best interests of the children. ate: Respectfully submitted, Mancke, Wagner & Spreha I.D. #23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Petitioner 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.$. Section 4904, relating to unsworn falsification to authorities. DAT~: IMAGED WILLIAM TAYLOR, Plaintiff : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYLVANIA VS. NATALIE A. TAYLOR ACRI, Defendant : NO. 3890 CV 2003 CU : : : CIVIL ACTION - CUSTODY RULE r~: AND NOW, this 22nd day of September 2003, upon consideration of the within Petition, a Rule is entered upon the Respondent, William Taylor, to sh~wca~,u:se,~" if any he has, why the relief requested in the within Petition should not be granted. Rule returnable five ($) days after service. Pending the headng or decision by this Court all action or proceedings on the judgment entered in this matter shall be stayed. BY THE COURT: Todd A. Hoover, Judge Distribution: P. Richard Wager, Esquire, 2233 North Front Street, Harrisburg, PA 17110 Diane G. Radcliff, Esquire, 3448 Trindle Road, Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA WILLIAM TAYLOR, Plaintiff V. NATALIE A. TAYLOR ACRI, Defendant NO. 2003 CV 3890 CU CIVIL ACTION - LAW IN CUSTODY MOTION TO MAKE RULE ABSOLUTE AND NOW, this 3rd day of October , 2003, Diane g. Radcliff, Esquire, Attorney for Natalie A. Acri, moves this Honorable Court to make the Rule entered on September 22, 2003 Absolute and to enter the foregoing order and assigns the following reasons therefor: On September 18, 2003, Petitioner/Defendant, Natalie A. Acri, filed a Petition Objecting to Jurisdiction and Requesting Transfer of the Case to Cumberland County, Pennsylvania to the custody action filed in that County and docketed to No. 01-623 Civil Term. A true and correct copy of that Petition is attached hereto, marked Exhibit "A" and made a part hereof. As indicated on the Certificate of Service attached to that Petition, the Petition was served upon the PlaintifFs attorney, P. Richard Wagner by fax and mail on September 18, 2003. A true and correct copy of the cover letter with fax cover sheet is attached hereto, marked Exhibit "B" and made a part hereof. On September 22, 2003, thi's Honorable Court entered a Rule upon the Plaintiff, William Taylor to show cause if any he had why the relief requested in the Petition should not be granted. The Rule was returnable five (5) days after service. A true and correct copy of the 9/22/03 Rule is attached hereto, marked Exhibit "C" and made a part hereof. The Rule was served upon the Plaintiff's Attorney, P. Richard Wagner, Esquire, by fax and mail on September 25,200, as appears on the Certificate of Service filed of record in this case, and as appears on the cover letter for such service, a tree and correct copy of which is attached hereto, marked Exhibit "D" and made a part hereof. Based on the service of the Rule on September 25, 2003, the time period for answering the Rule expired on October 1, 2003. As of this date, October 3, 2003, Plaintiff/Respondent has not filed an Answer or other reply to the Rule. Wherefore, Petitioner/Defendant respectfully requests this Honorable Court to make the September 22, 2003 Rule Absolute and to enter the foregoing order. Respectfully submitted, Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 Attorney for Petitioner, Natalie A. Acri CERTIFICATE OF SERVICE I, DIANE G. RADCLIFF, ESQUIRE, hereby certify that on October 3, 2003, I served a true and correct copy of the foregoing Motion upon Respondent's Attorney, P. Richard Wagner, by faxing the same to him at (717) 234-7080 and by mailing same by first class mail, postage prepaid, addressed as follows: P. Richard Wagner, Esquire 2233 North Front Street Harrisburg, PA 17110 Respectfully submitted, ~DIANE GNRADCLIFF, ESQUIRD- ("'3~8 Trind)e Road ~,PA 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 EXHIBIT "A" IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA WILLIAM TAYLOR, Plaintiff V. NATALIE A. TAYLOR ACRI, Defendant NO. 2003 CV 3890 CU CIVIL ACTION - LAW iN CUSTODY RULE AND NOW, this __ day of ,2003, upon consideration of the within Petition, a Rule is entered upon the Respondent, William Taylor, to show cause, if any he has, why the relief requested in the within Petition should not be granted. Rule returnable at a hearing to be held on ,2003 at o'clock __.m. in Courtroom__ of the Dauphin County Courthouse, Harrisburg, PA. Pending the hearing or decision by this Court all action or proceedings on the judgment entered in this matter shall be stayed. BY THE COURT: IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA WILLIAM TAYLOR, Plaintiff V. NATALIE A. TAYLOR ACRI, Defendant NO. 2003 CV 3890 CU CIVIL ACTION - LAW IN CUSTODY AND NOW, this __ day of HEREBY ORDERED that: 1. 2. ORDER ,2003, upon consideration of the within Petition IT IS This Court declines to exercise jurisdiction over this custody case; The case shall be transferred to Cumberland County, PA to the case in that County docketed to no 01-623. BY THE COURT: IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA WILLIAM TAYLOR, Plaintiff V. NATALIE A. TAYLOR ACRI, Defendant NO 2003 CV 3890 CIVIL ACTION - LAW IN CUSTODY PETITION OBJECTING TO JURISDICTION AND REQUESTING THE TRANSFER OF THE CASE TO CUMBERLAND COUNTY PENNSYLVANIA AND NOW, this \c~q~day of September, comes the Petitioner, Natalie A. Acri, by her attorney, Diane G. Radcliff, Esquire, and files the above referenced Petition Objecting to Jurisdiction and Requesting the Transfer of the Case to Cumberland County Pennsylvania and represents that: Your Petitioner is Natalie A. Ach an adult individual residing at 792 W. Pineford, Boyertown, Berks County, PA 19512 and is the Defendant in the above captioned case. Your Petitioner is hereafter referred to as "Mother". Your Respondent is William Taylor, an adult individual residing at 427 S. York Street, Mechanicsburg, Cumberland County, PA. And is the Plaintiffin the above captioned case. Your Respondent is hereafter referred to as "Father". The parties are the parents of three children, to wit: Katherine, born on 9/14/90; Eden, born on 11/18/91 and Brooke, bom on 6/2/96. The children have been in the primary custody of Mother since the parties' separation on January 29, 2001. On May 11,200, an Order of Court was entered by the Honorable Edward Guido, Judge of the Com-t of Conm~on Pleas of Cumberland County, PA in the case captioned as follows: Natalie A. Taylor vs. William Taylor, Cumberland County Docket No. 01-623. A true an correct copy of the May 11, 2001 Order is attached hereto, marked Exhibit "A" and made a part hereof. The present action was initiated by the filing of a Petition for Emergency Relief by Father on or about September 9, 2003. A true and correct copy of that Petition for Emergency Relief is attached hereto, marked Exhibit "B" and made a part hereof. No mention was made in the aforementioned Petition for Emergency Relief as to the existence of the May 11,2001 Cumberland County Custody Order. The Court of Dauphin County, PA should not exercise jurisdiction over this case and the case should be transferred to Cumberland County, PA because: Mother, Father and the children lived at 63 North 31~t Street, Camp Hill, Cumberland County, PA from August 1996 until the parties' separation on or about January 29, 2001; Subsequent to the parties' separation Mother and the children continued to live at 63 North 31st Street, Can~p Hill, Cumberland County, PA from January 18, 2001 until late August of 2002. In late August 2003, Mother and the children and her current husband, Dr. Joseph Acri, moved to 755 Tarry Hall Road, Dauphin County, PA where the continued to reside until August 18, 2003, a period of less than one (1) year. On August 18, 2003, as the result of a job change, which was and is of significant benefit to the children, Mother, the children and mother's current husband, Dr. Joseph Acri, moved to a temporary residence in Douglasville, PA and on September 17, 2003 to their permanent new home located at 792 W. Pineford, Boyertown, Berks County, PA 19512. There is no emergency as alleged by Father in that Mother has continued to provide Father with his allotted partial custody rights and has provided the transportation for the exercise of those fights even though not required to do so by the May 11, 2003 Cumberland County, PA Order. The statements in Father's Emergency Petition that Mother did not provide Father with information regarding the children's residence address, school and other information are not true. 2 The children have had, have, and will continue to have, significant contacts with Cumberland County, PA in that: The children have lived in Cumberland Count, PA for all but one year of their lives; Father lives in Cumberland County, PA and exercises his custodial rights in that county. The children's maternal grandparents, with whom the children have a significant relationship, live in Camp Hill, Cumberland County, PA; 4. The children's paternal grandparents live in Cumberland County, PA; Most of the past and much of the current and future information regarding the children is in Cumberland County, PA; There is no current information, nor will there be any future information regarding the children in Dauphin County, PA. The children have no significant contacts with Dauphin County, PA as the children, the parents and none of the family members reside in that county. WHEREFORE, Petitioner/Mother requests this Honorable Court to enter an order declining jurisdiction in this case and transferring the case to Cumberland County, PA. Respectfully submitted, DIAfl~a~x~DCLIFF, ESQUIRE 34~ Trindl~Road Carn'p'~rt/t'I;'PA 17 011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 Attorney for Petitioner, Natalie A. Acri VERIFICATION I, Diane g. Radcliff, Esquire, having been duly authorized by the Petitioner, and on behalf of the Petitioner, verify that the statements made in the foregoing Pet/tion Objecting to Jurisdiction and Requesting the Transfer of the Case to Cumberland County Pennsylvania are trne and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities bi. CLIFF,, ESQUIRE 4 PaGE 01 VERIFIC/ .C', I veri~ that the staterl~nTs made in the foregoing Petition ouj~etlng to :,.r,~etion a=d R, 'q'l{ .,dug t ~e' 7rdn~ ;~. of the Care ~ L'ur.lberl~n~ C~A'~ ~, ,,1 ns ~'1 ~,,~ de C~ dn~ CC ~ ~ ;. I undcrstaL~ that false s~atee~nt~ h~rein ~e m~e subject 1o thc pc~lues of 18 P8.CS. Section 4904, relating to unawom falsification to authori~a. I furor authoriz~ my A~omey, Diane G. ~dcliff, Esquire, [o si~ ~ origi~l verification on my b~halE k].,: CERTIFICATE OF SERVICE I, DIANE G. RADCLIFF, ESQUIRE, hereby certify that on September 18~ 2003 , I served a true and correct copy of the foregoing Petition upon Respondent's Attorney, P. Richard Wagner, by faxing the same to him at (717) 234-7080 and by mailing same by first class mail, postage prepaid, addressed as follows: P. Richard Wagner, Esquire 2233 North Front Street Harrisburg, PA 17110 Respectfully submitted, C~m~ Hili~A 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 EXHIBIT "A" 5/11/01 CUMBERLAND COUNTY CUSTODY ORDER NATALIE A. TAYLOR, VS. WILLIAM S. TAYLOR, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-623 : : CIVIL ACTION - LAW Defendant : CUSTODY Guido, J. ORDER OF COURT AND NOW, this ]/'"" day of~/../~ ,2001, upon consideration of the attached Custody Conciliation Summary Repor(~t is hereby ordered and directed as follows: 1..Leqal Custody. The parties, Natalie A. Taylor and William S. Taylor, shall have shared legal custody of the minor Children, Katherine Taylor, born September 14, 1990, Eden Taylor, bom November 18, 1991 and Brooke Taylor born June 6, 1996. 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, alt decisions regarding their 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 Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children 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. Father shall have partial physical custody arranged as follows: On the following dates, Father shall have physical custody from Friday at 5:00 p.m. until Sunday at 8:00 a.m. May 4, 2001 through May 6, 2001; May 18, 2001 through May 20, 2001; June 1, 2001 through June 3, 2001; July 6, 2001 through July 8, 2001. Additionally, Father shall have custody from Noor~ until 7:00 p.m. on the Sundays of his custodial weekends and shall make the appropriate adjustments for the Children's soccer schedule. Father shall have physical custody each Tuesday evening from 5:00 p.m. until 8:00 p.m. each Tuesday in May, July 10, 2001, and August 28, 2001. Father shall have the following summer custody schedule: June 22, 2001, through July 1. 200 I; July 28, 2001, through August 4, 2001; and August 19, 2001, through August 26, 2001. No. 01-623 Civil Term independence Day. Father shall have custody on Independence Day from 4:00 p.m. July 4, 2001, until 9:00 a.m. July 5, 2001. 3. Mother shall provide Father with copies of a schedule of the Children's activities. 4. This Order is temporary in nature, in the event that the parties are not able to resolve the issues of the custody by agreement within sixty days of the date of this Order. counsel for either party may contact the Conciliator to schedule an additional Custody Conciliation Conference. Edward E. Guido, J. Dist: P. Richard Wagner. Esquire, Mancke, Wagner, Hershey & Tully. 2233 N. Front Slree(, Harrisburg, PA 17110 Austin F. Grogan, Esquire, 24 N. 3~'~ Street, Camp HilJ, PA 17011 NATALIE A. TAYLOR, VS. WILLIAM $. TAYLOR, .'IN THE COURT OF COMMON PLEAS OF Plaintiff ; CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-623 : ; CIVIL ACTION - LAW Defendant : CUSTODY CU,~TODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY' 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: N,AME DATE OF BIRTH CURRENTLYIN CUSTODY OF Katherine Taylor Eden Taylor Brooke Taylor September 14, 1990 November 18, 1991 June 6, 1996 Mother Mother Mother 2. A Custody Conciliation Conference was held on April 30, 2001, with the following individuals in attendance: the Mother, Natalie A; Taylor, and her counsel, Austin F. Grogan, Esquire; the Father, William S. Taylor, and his counsel, P. Richard Wagner, Esquire. 3. The parties were seen for a Custody Conciliation Conference and reached an agreement in the form of an Order as attached. Father's counsel shall prepare and file an executed stipulation modifying the terms of the PFA issued by Judge Guido on March 14, 2001, so that its terms will not conflict with the agreements the parties have made with regard to custody of their Children. Custody Conciliator EXHIBIT "B" PETITION FOR EMERGENCY RELIEF WILLIAM TAYLOR, Plaintiff : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYLVANIA vs. NATALIE TAYLOR ACRI, Dafendan~ : NO. 2003 CV 3890 CU CHILD CUSTODY ORDER YOu are ORDERED to appear in person at the Dauphi~ County Courthouse, Front & Market Streets, 4th Floor, Harrisburg] Pennsylvania on September 19, 2003 at noon for a Custody Conciliation Conference. At the conference an effort will be made to resolve the issues, a~d to enter into an agreement. Children need not be present unless their presence is requested by the Custody Conference Officer. If you fail to appear as provided by this Order, an Order for custody may be entered against you or the Court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR 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. Dated: Harrisburg, (7Z7) Dauphin County Lawyer Referral Service 213 North Front Street Pennsylvania 17101 232-7536 · .t I hu'eby certify that me loregeihg Is a ~e,.~d correct copy~of t~e orlOInal flled~: ' " .I ~ : W'ILLLAM TAYLOR, P~tition~r, : IN THE COURT OF COMMON PLEAS : DALYPH~ COUNTY, PENNSYLVANIA NATALIE A. TAYLOR ACRI, Kespondent. : CIVIL ACTION - LAW : IN CUSTODY PETITION FOR EMERGENCY RELIEF AND NOW, comes your Petitioner, William Taylor, by and through<his attorneys, Mancke, Wagner & Spreha, and fries the following Petition for Emergency Relief.' 1. Your Petitioner, William Taylor, is an adult/nd/vidual residing at 427 S. York Street, Mechan/csburg, Cumberland County, Pennsylvania. 2. Respondent, Natalie A. Taylor Aeri, is an adult indiv/dual residing in Pottstown, Pennsylvan/a, at an address unknown to the Petitioner, having previously lived at 755 Terry Hall Road,Millersburg, Dauphin County, Pennsylvania, 3. Petitioner and Respondent were husband and wife, having since divorced, and the Respondent remarried Dr. Joseph Acri. 4. The part/es are the natural parents of three (3) children, Katherine, bom September 14, 1990, Eden, bom November 18, 1991, and Brooke, born June 2, 1996. 5. Petitioner is the natural father of the aforementioned children; Respondent is the natural mother. 6. The ch/ldren were all born during wedlock. 7, Dining the last five (5) years, the children have resided at the following addresses w/th the following persons: A. During the previous five (5) years up until January 29, 200 I, with the Petitioner and Respondent at 63 North 31'~ Street, Camp H/Il, Cumberland County, Pennsylvania; B. From January 29, 2001, until approximately the Summer of 2002, with the Respondent and her husband, Dr. Joseph Acr/at 63 iq. 3 l't Street, Camp Hill, Cumberland County, Pennsylvania; C. From the Summer of 2002 until the end of August 2003, at 755 Terry Hall Road, Millersburg, Dauphin County, Pennsylvart/a, with the Respondent and her husband; D. From the end of August 2003 w/th the Respondent and her husband at an address unknown/n Pottstown, Pennsylvania. 8. At the end of August 2003, during a per/od of partial custody with the Petitioner hereto, the children confided in the Petitioner that the mother was removing them fi.om school and moving somewhere in Pottstown. 9. Petitioner herein inquired of the Respondent where she was mov/ng, and Respondent hasrefused to disclose the location where they are living, refused to disclose the~name of the school that the children a re attending, and refused to provide the Petitioner with any contact whatsoever concerning the move. I0. Petitioner beheves and therefore avers that the move was not made in the best interests of the children, was self-serving to the Petitioner and her new husband, and is designed to mafiatain a strong relationship between the children and the Petitioner. I 1. Petitioner's immediate family as well as Respondenffs knmed/ate family hve in the Central Permsylvan/a Area, i.e., Camp H/il and Mecbanicsburg area. 12. Petitioner believes the surreptitious conduct of the Respondent is designed to defeat the Petitioner's fights of custody and partial custody of his children which is farther ev/denced by the faot that as of the filing of this Petition, Respondent has not disclosed to the Petitioner the location o£the children, the address, the school and the name of the medical provider or any other information whatsoever. 13. Petitioner has attempted to contact the Respondent, however, she has refused to disclose the Iocation of the Respondent and the children. WHEREFORE, Petitioner prays th/s Court to grant his emergency relief in the form of awarding custody of the ck/Idren to him immediately, pending a heating to determine whether or not under Gnlber v. Graber, the move is in the best interests of the children. ate: Respectfully submitIed, Mancke, Wagner & Spreha I.D. #231O3 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Petitioner VERIFIC. ATION 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. Section 4904, relating to unsworn falsification to aut~Aorities. DATE: EXHIBIT DIANE G. RADCLIFF, ESQUIRE Attorney at Law 3448 Trindle Road Camp Hill, Pennsylvania 17011 Phone: (717) 737-0100 Facsimile: (717) 975-069 September 18, 2003 P. Richard Wagner, Esquire 2233 North Front Street Harrisburg, PA 17110 Re: Natalie Anne Taylor vs. William Taylor Cumberland CounO~ Divorce Action No. 01-3601 Civil Term Dear Rich: I am enclosing with this letter a copy of the revised Petition regarding jurisdiction which I have filed with the Court today. I am also advising you that Natalie, her husband and the children moved into their new residence on September 17, 2003. That address is 792 West Pineford Road, Boyertown, PA 19512. As soon as their home phone number has been established, I will provide that information to you as well Contraw to the representations in your Emergency Relief Petition, Bill was advised of Natalie's former address and the school information. In fact, he was invited to come to or call the school if he needed further information.: In case he did not inform you, the school is the Coventry Christian School. I believe Bill has the address, but can provide you with that address if needed for your files. Bill has been harassing Natalie by his incessant phone, sometime 4 to 5 times per day. A few of these calls have been made when he was intoxicated. Please inform him that he is not to call Natalie during work hours on her cell phone or otherwise unless it is an emergency. She has a job to do and cannot be interrupted with his inappropriate communication. He is also not to call her when he has been drinking, nor to harass her. He should limit his communication to issues that require her attention and not to berate or belittle her. He is, of course, fi'ce to call the children at any time. Page 2 September 18, 2003 As set forth in my prior letter to you, I also have been infom~ed that Bill has been discussing custody issues with the children and has been making derogatory statements about Natalie, Joe and her parents to the children. This must stop immediately! DGR/dr Enclosures: Petition cc: Natalie Taylor File 28-02D Transmitted by Fax and Mail Very truly yours, D~_~CLIFF, ESQUIRE I1E._,.=,HGE CONF I Rr"I~T I ON ID=DIANE G RADCLIFF DATE O'9,'18 S,R-TIP1E DISTANT STATION ID MODE PAGES 06'01" +?17 234 ?080 CALLIIqG 22 RESULT OK 0000 09/18/03 11:32 DIANE G RADCLIFF a 234?080 N0.060 FAX COVER SHEET TO FAX NUMBER: 717-234-7080 FROM: TO: DATE: MATTER: Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, PA 17011 Phone: 717-737-0100 I-'z~x: 71%975-0697 P. Richard Wagner, Esquire 2233 North Front Street Harrisburg, PA 17110 Phone: (717) 234-7051 l"a'.: 4'T17) 234-71}80 September 18 2003 Taylor vs. Ach DESCRIPTION OF DOCUMENT(S) Cover Sheet Sep?_mber ~_8, 2003 Letter .... Petition NO, OF PAGES 1 .... 19 FAX COVER SHEET TO FAX NUMBER: .... "' FROM: TO: DATE: ] September 18, 2003 MATTER: Taylor vs. Acri Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, PA 17011 Phone: 717-737-0100 P. Richard Wagner, Esquire 2233 North Front Street Harrisburg, PA 17110 Phone: (717) 234-7051 DESCRIPTION OF DOCUMENT(S) Cover Sheet S~ptember 18~ 2003 letter Petition TOTAI, PAGES NO. OF PAGES 1 2 19 22 MESSAGE OR COMMENTS The copy °f'the P~iition~ent by fax has not yet been filed. I am on my way to the ~ourthouse now to file this document and will include a time starroed copy in the original mailed letter. MAILING/RECEIPT INFORMATION x , 0rigina! will follow b~ mail~. ............ i. '~- ]- 0rigjnal will qo~ ~01~low by mail. IF YOU DO NOT RECEIVE ALL PAGES, PLEASE TELEPHONE ME IMMEDIATELY AT (717) 737-0100 The information contained in this facsimile message is information protected by attorney-client and/or the attorney/work product privilege. It is intended only for the use of the individual named above and the privileges are not waived by virtue of this having been sent by facsimile. If the person actually receiving this facsimile or any other reader of the facsimile is not the named recipient or the employee or agent responsible to deliver it to the named recipient, any use, dissemination, distribution, or copying of the communication is strictly prohibited. If you have received this communication in error, please immediately notify us by telephone and return the original message to us at the above address via U.S. Postal Service. EXHIBIT "C" WILLIAM TAYLOR, Plaintiff VS. NATALIE A. TAYLOR ACRI, Defendant : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYLVANIA : NO. 3890 CV 2003 CU ::" : CIVIL ACTION - CUSTODY RULE AND NOW, this 22"d day of September 2003, upon consideration of the within Petition, a Rule is entered upon the Respondent, William Taylor, to show cause, if any he has, why the relief requested in the within Petition should not be granted. Rule returnable five (5) days after service. Pending the headng or decision by this Court all action or proceedings on the judgment entered in this matter shall be stayed. ~'roth'onotaq/ BYTHE COURT: Todd A. Hoover, Judge Distribution: P. Richard Wager, Esquire, 2233 North Front Street, Harrisburg, PA 17110 Diane G. Radcliff, Esquire, 3448 Trindle Road~ Camp Hill, PA EXHIBIT "D" DIANE G. RADCLIFF, ES '--- Attorney at Law 3448 Trindle Road Camp Hill, Pennsylvania 17011 Phone: (717) 737-0100 Facsimile: (717) 975-069 September 25, 2003 P. Richard Wagner, Esquire 2233 North Front Street Harrisburg, PA 17110 Dear Rich: Re: Natalie ~4nne Taylor vs. 14/illiam Taylor Dauphin County Custody Action No. 3890 CV2003 CU I am enclosing a copy of the Rule entered by Judge Hoover on my Petition Objecting to Jurisdict/on and Requesting the Transfer of the Case to Cumberland County Pennsylvania. This rule is returnable five days after the date of service. The Petition underlying this Rule was faxed and mailed to you on September 18, 2003 and, therefore, is not included in this letter. DGR/dr Enclosures: September 22, 2003 Rule cc: Natalie Taylor File 28~02D Transmitted by Fax and Mail Very truly yours, DIANE G. t~D, CLIFF, ESQUIRE MESSAGE CONF I RI'lilT, ' '-' I FiN ID--DIANE G RWD.LIFF DATE S,R-T1ME DISTANT STATION ID MODE PAGES ~l 85 +?17 234 9080 CALLING 03 RESULT N0.018 IP~]i FROM: TO: DATE: _~ATTER: FAX COVER SHEET TO FAX NUMBER: 717-234-7080 Diane G. Radcliff, Esquire 3448 Trindlc Road Camp Hill. PA 17011 Phone: 717Q37-0100 Fax: 717-075-0697 P. ,Richard Wagner, Esquire 2233 North Front Street Harrisburg, PA 171 l0 Phone: (717) 234-7051 Fax: {717) 234-7080 September 25, 2003 Taylor vs. Acri DESCRIPTION OF DOCUMENT(S) ~er Shcct [e..m_b.er 25., 2003 leuer /03 Rule ent)md_ b._y_.Judge Hoover 'Al, PAGES No. oF }'Aais II FAX COVER SHEET TO FAX NUMBER: FROM: TO: DATE: MATTER: Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, PA 17011 Phone: 717-737-0100 P. Richard Wagner, Esquire 2233 North Front Street Harrisburg, PA 17110 Phone: (717) 234-7051 1; ~x: ~ 717) 234-71180 September 25, 2003 Taylor vs. Acri DESCRIPTION OF DOCUMENT(S) Cover Sheet Se~p_t.~_mber 25,_2__003 letter 9/22/03 Rule entered by Judge Hoover TOTAl, PAGES NO. OF PAGES 1 1 MESSAGE OR COMMENTS MAILING/RECEIPT INFORMATION . ~ X i Original_will follow by mail _Original..~!l_l.not follow by mail. IF YOU DO NOT RECEIVE ALL PAGES, PLEASE TELEPHONE ME IMMEDIATELY AT (717) 737-0100 The information contained in this facsimile message is information protected by attorney-client and/or the attorney/work product privilege. It is intended only for the use of the individual named above and the privileges are not waived by virtue of this having been sent by facsimile. If the person actually receiving this facsimile or any other reader of the facsimile is not the named recipient or the employee or agent responsible to deliver it to the named recipient, any use, dissemination, distribution, or copying of the communication is strictlyprohibited. If you have received this communication in error, please immediately notify us by telephone and return the original message to us at the above address via U.S. Postal Service. WILLIAM TAYLOR, Plaintiff NATALIE A. TAYLOR Defendant 1N THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. 3890 CV 2003 CU CIVIL ACTION - CUSTODY CERTIFICATE OF SERVICE I, DIANE G. RADCLIFF, ESQUIRE, hereby certify that on September 25, 2003, I served a tree and correct copy of the Rule entered on September 22, 2003 upon P. Richard Wagner, Esquire, Attomey for Plaintiff, by mailing same by first class mail, postage prepaid, addressed as follows: P. Richard Wagner, Esquire 2233 North Front Street Harrisburg, PA 17110 Respectfully submitted, ~-~48 Trindle~oad Camp I~'ilI,~PA 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA WILLIAM TAYLOR, Plaintiff V. NATALIE A. TAYLOR ACRI, Defendant NO. 2003 CV 3890 CU CIVIL ACTION - LAW IN CUSTODY PETITION OBJECTING TO JURISDICTION AND REQUESTING THE TRANSFER OF THE CASE TO CUMBERLAND COUNTY PENNSYLVANIA AND NOW, this [ ~'~day of September, comes the Petitioner, Natalie A. Acri, by her attorney, Diane G. Radcliff, Esquire, and files the above referenced Petition Objecting to Jurisdiction and Requesting the Transfer of the Case to Cumberland County Pennsylvania and represents that: Your Petitioner is Natalie A. Acri an adult individual residing at 792 W. Pineford, Boyertown, Berks County, PA 19512 and is the Defendant in the above captioned case. Your Petitioner is hereafter referred to as "Mother". Your Respondent is William Taylor, an adult individual residing at 427 S. York Street, Mechanicsburg, Cumberland County, PA. And is the Plaintiff in the above captioned case. Your Respondent is hereafter referred to as "Father". The parties are the parents of three children, to wit: Katherine, born on 9/14/90; Eden, born on 11/18/91 and Brooke, born on 6/2/96. The children have been in the primary custody of Mother since the parties' separation on January 29, 2001. On May 1 l, 200, an Order of Court was entered by the Honorable Edward Guido, Judge of the Court of Common Pleas of Cumberland County, PA in the case captioned as follows: Natalie A. Taylor vs. William Taylor, Cumberland County Docket No. 01-623. A true an correct copy of the May 11, 2001 Order is attached hereto, marked Exhibit "A" and made a part hereof. The present action was initiated by the filing of a Petition for Emergency Relief by Father on or about September 9, 2003. A true and correct copy of that Petition for Emergency Relief is attached hereto, marked Exhibit "B" and made a part hereof. No mention was made in the aforementioned Petition for Emergency Relief as to the existence of the May 11,2001 Cumberland County Custody Order. The Court of Dauphin County, PA should not exercise jurisdiction over this case and the case should be transferred to Cumberland County, PA because: Mother, Father and the children lived at 63 North 31st Street, Camp Hill, Cumberland County, PA from August 1996 until the parties' separation on or about January 29, 2001; Subsequent to the parties' separation Mother and the children continued to live at 63 North 31st Street, Camp Hill, Cumberland County, PA from January 18, 2001 until late August of 2002. In late August 2003, Mother and the children and her current husband, Dr. Joseph Acri, moved to 755 Tarry Hall Road, Dauphin County, PA where the continued to reside until August 18, 2003, a period of less than one (1) year. On August 18, 2003, as the result of a job change, which was and is of significant benefit to the children, Mother, the children and mother's current husband, Dr. Joseph Acri, moved to a temporary residence in Douglasville, PA and on September 17, 2003 to their permanent new home located at 792 W. Pineford, Boyertown, Berks County, PA 19512. There is no emergency as alleged by Father in that Mother has continued to provide Father with his allotted partial custody rights and has provided the transportation for the exercise of those rights even though not required to do so by the May 11, 2003 Cumberland County, PA Order. The statements in Father's Emergency Petition that Mother did not provide Father with information regarding the children's residence address, school and other information are not tree. 2 The children have had, have, and will continue to have, significant contacts with Cumberland County, PA in that: The children have lived in Cumberland Count, PA for all but one year of their lives; Father lives in Cumberland County, PA and exercises his custodial rights in that county. The children's maternal grandparents, with whom the children have a significant relationship, live in Camp Hill, Cumberland County, PA; 4. The children's paternal grandparents live in Cumberland County, PA; Most of the past and much of the current and future information regarding the children is in Cumberland County, PA; There is no current information, nor will there be any future information regarding the children in Dauphin County, PA. The children have no significant contacts with Dauphin County, PA as the children, the parents and none of the family members reside in that county. WHEREFORE, Petitioner/Mother requests this Honorable Court to enter an order declining jurisdiction in this case and transferring the case to Cumberland County, PA. Respectfully submitted, DIA~DCLIFF, ESQUIRE 344~ Trindl~ Road Cam'i~Hit-t~A 17 011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 Attorney for Petitioner, Natalie A. Acri 3 VERIFICATION I, Diane g. Radcliff, Esquire, having been duly authorized by the Petitioner, and on behalf of the Petitioner, verify that the statements made in the foregoing Petition Objecting to Jurisdiction and Requesting the Transfer of the Case to Cumberland County Pennsylvania are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities blANE G.~RADCLIFE, ESQUIRE 6109789~78 09/17/2~02 20~45 6109789370 · COVENTRYCHRISTIANSCH PAGE 81 VERIFIC/ ,C', I verit~ t~at the 8taterpgnts made in the fOrego,ag Petition ovj~etlnl{ to ,.~rla~etion and R, ?'~t *,;~R t ~e' 7ran~ ~- of the Ca~e ~ Cur Jberltnd C¢~n;~ P,~,~n~ ~1 ~i,,~ cc b~ and cc ~ ~ ~. I undcrstat~ that falsr statements herein ~e m~c subject to thc ~l~es of 18 Pa.CS. Section 4904. relating to unswom falsification to luthoriti~. I fu~ef authorize my Auomey, Diane G. ~dcliff, Esquire, Io si~ ~ ofigi~l verification on my behnlt~ CERTIFICATE OF SERVICE I, DIANE G. RADCLIFF, ESQUIRE, hereby certify that on September 18, 2003 , I served a true and correct copy of the foregoing Petition upon Respondent's Attorney, P. Richard Wagner, by faxing the same to him at (717) 234-7080 and by mailing same by first class mail, postage prepaid, addressed as follows: P. Richard Wagner, Esquire 2233 North Front Street Harrisburg, PA 17110 Respectfully submitted, Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 EXHIBIT "A" 5/11/01 CUMBERLAND COUNTY CUSTODY ORDER 09/17/03 WED 10:58 FAX 717 240 6573 CUMB CO PROTHONOTARY ~]002 NATALIE A. TAYLOR, VS. WILLIAM S. TAYLOR, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA ., : NO. 01-623 : : CIVIL ACTION - LAW Defendant : CUSTODY Guido, J. ORDER OF COURT AND NOW, this ] day ot~//3,~(,.~ ,2001, upon consideration of the atlached Custody Conciliation Summary Repor~t is hereby ordered and directed as follows: 1. Legal Custody. The parties, Natalie A. Taylor and William S. Taylor, shall have shared legal custody of the minor Children, Katherine Taylor, born September 14, 1990, Eden Taylor, born November 18, 1991 and Brooke Taylor born June 6, 1996. 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. Pursuant to the terms of Pa. C S. § 5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children 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 primar7 physical custody. Father shall have partial physical custody arranged as follows: On the following dates, Father shall have physical custody from Friday at 5:00 p.m. until Sunday at 8:00 a.m. May 4, 2001 through May 6, 2001; May 18, 2001 through May20, 2001; June 1, 2001 through June 3, 2001 July 6, 2001 through July 8, 2001. Additionally, Father shall have custody from Noon until 7:00 p.m. on the Sundays of his custodial weekends and shall make the appropriate adjustments for the Children's soccer schedule. Father shall have physical custody each Tuesday evening from 5:00 p.m. until 8:00 p.m. each Tuesday in May, July 10, 2001, and August 28, 2001 Father shall have the following summer custody schedule: June 22, 2001, through July 1, 2001; July 28, 2001, through August 4, 2001; and August 19, 2001, through August 26, 2001. ~003 C* WED 10:59 FAX 717 240 6573 ~[MB CO pROTHONOTARY 09/17/03 No. 01-623 Civil Term !ndependence Day. Father shall have custody on Independence Day from 4;00 p.m. July 4, 2001, until 9:00 a.m. July 5, 2001. 3. Mother shall provide Father with copies of a schedule of the Children's activities. 4. This Order is temporary in nature. In the event that the parties are not able to resolve the issues of the custody by agreement within sixty days of the date of this Order, counsel for either party may contact the Conciliator to schedule an additional Custody Conciliation Conference. Edward E. Guido, J. Dist P. Richard Wagner. Esquire. Mancke. Wagner. Hershey & Tully. 2233 N, Front Street. Harrisburg, PA 17110 Austin F. Grogan. Esquire. 24 N, 32"d Street. Camp Hill. PA 17011 09/17/03 WED 10:59 FAX 717 240 6573 CUMB CO PROTHONOTARY ~004 NATALIE A. TAYLOR, VS. WILLIAM S. TAYLOR, : IN THE COURT OF COMMON PLEAS OF Plaintiff ; CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-623 : ; CIVIL ACTION - LAW Defendant : 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 Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Katherine Taylor September 14, 1990 Mother Eden Taylor November 18, 1991 Mother Brooke Taylor June 6, 1996 Mother 2. A Custody Conciliation Conference was held on April 30, 2001, with the following individuals in attendance: the Mother. Natalie A. Taylor, and her counsel, Austin F. Grogan, Esquire; the Father, William S. Taylor, and his counsel, P. Richard Wagner, Esquire. 3. The parties were seen for a Custody Conciliation Conference and reached an agreement in the form of an Order as attached. Father's counsel shall prepare and file an executed stipulation modifying the terms of the PFA issued by Judge Guido on March 14, 2001, so that its terms will not conflict with the agreements the parties have made with regard to custody of their Children. Custody Conciliator EXHIBIT "B" PETITION FOR EMERGENCY RELIEF SEP-15-2003 OZ:E4PM ~ROM-MANCKE WAGNER SPREHA WILLIAM TAYLOR, Plaintiff : IN THE COURT OF COMMON Ph~AS : DAUPHIN COUNTY, PENNSYLVANIA vs. NATALIE TAYLOR ACRI, Defendant : NO. 2003 CV $890 CU You Courthouse, Front & Market Streets, 4th Floor, Harrisburg, . Pennsylvania on September 19, 2003 at noon £or a Custody Conciliation Conference. are ORDERED to appear in person at the Dauphih County At the conference an effort will be made to resolve the issues, and to enter into an agreement. children need not be present unless their pre~ence is requested by the Custody Conference officer. If you ~ail to appear as provided by this Order, an Order for custody may be entered against you or the Court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR 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 CAi~ GET LEGAL HELP. Dated: Harrisburg, (717) Dauphin County Lawyer Referral Service 213 North Front Street Pennsylvania 17101 232-7536 I hereby certify tlmt tt~e ~oregoi~o is a ~e.~d correct co~ef the orig~al filed,; ' " ,f ~ : ~h~nomry. _ ._ ' SEP-17-ZO03 1Z:I9PM FROM-MANCKE WAGNER SPREHA +71T~Z34'7080 T-735 P OOZ/OOB F-31Z WILLIAM TAYLOK, Petitioner, IN TH~ COURT OF COMMON PLEAS DAUPItlN COUNTY, PENNSYLVANIA NATAL1E A. TAYLOR ACRI, Respondent. CIVIL ACTION - LAW : IN CUSTODY PETITION FOR EMERGENCY RELIEF :z: ~ AND NOW, comes your Petitioner, Will/am Taylor, by and through"ehis ~ attorneys, Mancke, Wagner & Spreha, and ~es the following Petition for Emergency Relief.' 1. Your Petitioner, William Taylor, is an adult individual residing at 427 S. York Street, Mechamcsbarg, Cumberland County, Pennsylvania. 2. Respondent, Natalie A. Taylor Acd, is an adult individual residing m Pottstown, Pennsylvan/a, at an address unknown m the Petitioner, having previously hved at 755 Terry Hall Road, Millersburg, Dauphin County, Pennsylvania. 3. Petitioner and Respondent were husband and wife, having since divorced, and the Respondent remarried Dr. Joseph Acri. SEP-1T-2003 12:18PM FROM-MANCKE WAGNER SPREHA +71T-~34-TO80 T-T35 P 003/005 F-31~ 4. The parties are the natural parents of three (3) children, Katherine, bom September 14, 1990, Eden, bom Igovember 18, 1991, and Brooke, bom June 2, 1996. 5. Petitioner is the natural father of the aforementioned children; Respondent is tho natural mother. 6. The children were all bom during wedlock. 7. During the last five (5) years, the children have resided at the following addresses w/th the following persons: A. During the previous five (5) ye, ars up until January 29, 200 I, with the Petitioner and Respondent at 63 North 31st Street, Camp Hill, Cumberland County, pennsylvania; B. From January 29, 2001, until approximately the Summer of 2002, with the Respondent and her husband, Dr. Joseph Acri at 63 N. 3 l"t Street, Camp Hill, Cumberland County, Pennsylvauia; C. From the Summer of 2002 until the end of August 2003, at 755 Terry Hall Road, Millersburg, Dauphin County, Pennsylvania, with the Respondent and her husband; SEP-17-ZO03 12:15PM ~ROM-MANCKE WAGNER SPREHA +717-Z34-70BO T-735 P 004/0~S F-312 D. From the end of August 2003 with the Respondent and her husband at an address uaknowa in Pottstown, Pennsylvania. 8. At the end of August 2003, during a period of partial custody with the Petitioner herein, the children confided in the Petitioner that the mother was removing them 15om school and moving somewhere in Pottstown. 9. Petitioner herein inquired of the Respondent where she was mov/rtg, and Respondent has_refused to disclose the location where they are living, refused to disclose the name of the school that the chil~lren are atteuding, and refused to provide the Petitioner with any contact whatsoever concerning the move. 10. Petitioner believes and therefore avers that the move was not made in the best interests of the children, was self-serving to the Pet/honer and her new husband, and is designed to maintain a slxong relationship between the children and the Petitioner. 11. Petitioner's immediate family as well as Respondent's immediate family live in the Central Pennsylvania Area, i.e., Camp Hill and Mechanicsburg area. 12. Petitioner believes the surreptitious conduct of the Respondent is designed to defeat the Petitioner's rights of custody and partial custody of his SEP-I?-ZO03 1Z:lgPM FROt,~"~NCKE WAGNER SPREHA +71T-Z34-7080 T-~3§ P 005/006 F-31Z children which is further evidenced by the fact that as of the filing of this Petition, Respondent has not disclosed to the Petit/oncr the location of the children, the address, the school and the name of thc medical provider or any other information whatsoever. 13. Petitioner has attempted to contact the Respondent, however~ she has refused to disclose the location of the Respondent and the children. WHEREFORE, Petitioner prays this Court to grant his emergency relief m the form of awarding custody of the children to him immediately, pending a hearing to determine whether or not under Grnber v..Gmber~ the move is in the best interests of the children. Respectfully submitted, Mancke, Wagner & Spreha I.D. #23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Petitioner SEP-17-ZO03 IZ:ZOPM FROM-MANCKE WAGNER SPREHA +?17-Z34-7080 T-735 P 006/0~6 F-31Z VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements hereln are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. DAT~;