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HomeMy WebLinkAbout03-6365 CHERYL L. BUCHANAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs, : NO. 63- (p?f.p5' :CIVIL ACTION - CUSTODY SCOTT E. KING, Defendant NOTICE YOU HAVE BEEN SUED IN COURT, If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff, You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW, THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE Carlisle, PA (717) 240-6200 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas. debe tomar acci6n dentro de los pr6ximos veinte (20) dias despues de la notificaci6n de esta Demanda y Aviso radicando personalmente 0 par media de un abogado una comparecencia escrita y radicando en la Corte par escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya, Se Ie advierte de que si usted falla de tamar acci6n como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda 0 cualquier otra reclamaci6n 0 remedio solicitado par el demandante puede ser dictado en contra suya por la Corte sin mas avlso adlclonaL Usted puede perder dinero 0 propiedad u otros derechos importantes para usted, USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME 0 VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALlFICAN, CUMBERLAND COUNTY COURT ADMINISTRATOR 4TH Floor, Cumberland Court Courthouse Carlisle, PA 17013 (717) 240-6200 CHERYL 1. BUCHANAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA VS SCOTT E ,KING NO, CIVIL ACTION - LAW IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, Cheryl 1. Buchanan, by her attorney, Francis M, Socha, Esquire, and makes the following Complaint for Custody; I, The Plaintiff is Cheryl 1. Buchanan, an adult individual currently residing at 804 Swan Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055, 2, The Defendant is Scott E, King, an adult individual, who currently resides at 6939 Wertzville Road, Enola, Cumberland County, Pennsylvania 17025, 3, The Plaintiff and Defendant were never married and one (1) child were born out of wedlock as a result of this relationship and is the subject of this action, namely: Hunter Michael King DOB 8/16/98 4, Plaintiff seek primary physical custody of the minor child, 5. The minor child is presently in the custody of the Plaintiff. 6, During the past five (5) years, the minor child has resided at the following addresses: Birth until November 2003 - 6939 Wertzville Road, Enola 17025 November 2003 until present 804 Swan Drive, Mechanicsburg, P A 17055 7, The natural mother ofthe minor child is the Plaintiff. 8. The natural father of the minor child is the Defendant. 9, The Plaintiff has not participated as a party or in any other way in any litigation concerning the custody of the minor child in this or any other court, 10, The Plaintiff has no information of a custody proceeding concerning the minor child pending in a court of this or any other jurisdiction, 11, Plaintiff knows of no other person not a party to this action already who has physical custody of or claims to have custody or visitation with the said minor child, 12, P1aintiffbe1ieves that the best interest of the minor child would be served if primary physical custody is awarded to the mother, the Plaintiffherein, 13, Each parent whose parental rights to the child have not been terminated and the person who has the physical custody of the child have been named as parties to this action, WHEREFORE, Cheryl 1. Buchanan requests this Honorable Court to grant her primary physical custody of the minor child, Hunter Michael King, Respectfully submitted: /.. _-Pt/crL Fr is M, Socha, Esquire 01 North Second Street Harrisburg, PA 17110 (717) 233-4141 I.D, No 29101 Attorney for Plaintiff DATED: 1'?-'1-0:> domestic-buchannoll-pet VERIFICA'l'ION I, CHERYL L. BUCHANAN, hereby verify that the statements of fact made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the criminal penalties contained in 18 Pa. C,S. Section 4904, relating to unsworn falsification to authorities. )((I)u,j;f dU~rJ CHERY~~BUCBANAN DATE: /rl-R,0,1 CHERYL L. BUCHANAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS SCOTT E, KING, Defendant NO, CIVIL ACTION - LAW IN CUSTODY CERTIFICATE OF SERVICE I, Carrie E. Ragan, secretary to Francis M, Socha, Esquire, hereby certifY that a true and correct copy of the Complaint for Custody was delivered first class mail to the following: Mr. Scott E. King 6939 Wertzville Road Enola, P A 17025 DATED: \ Llq lo:s {Qfk)~a~ domestic-buchanan-cos en ('") 0 0 C (...1 -n """ ;:"..- ;7.) :J ~ 0 -0'-' " -, mT" -'-'" ~ 7' Z~ -- ;Z' I ~ <:::Y Ul \,., -<,:' ~ < ~~t 01 ::.-:. >'.r-- -? ~ 0 ~;-~. , ll] rp ___I \.}\ ~ v --, " '~) l: ).J Sl. -~ ~.g ~ -< I" -, V) 0 z-. CHERYLL.BUCHANAN PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 03-6365 CIVIL ACTION LA W SCOTT E. KING DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, December 12, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa p, Greevy, Esq. at 301 Market Street, Lemoyne, PA 17043 on Monday, Jannary 19, 2004 , the conciliator, at 11:00 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be prescnt at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinl(, FOR THE COURT, By; Isl Melissa p, Gree'l!Y. Esq, Custody Conciliator C/ The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For infonnation about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court, You must attend the scheduled conference or hearing. YOU SHOULD TAKE TIllS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE 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 (7] 7) 249-3166 ~-fp~ ~ 44v ,~~~ ~J4 ~p ~ ~~,7-):!i(} \liJ\h/,Yl! ("I; , ,-- , I 11\ 'r-,"'''' ,:" \ 1,1 \.~~"\!( \r~!...j 1\.~I'j, :tr': C:"-,''''.'''''I~"J::~''f'' , "'-Hno 9 I :21 I!d 91 "]0 ' J [DOl 11''''0' ,,1"1 -,~;HlOod 3Hl :! :.h.d:!(}-0311:/ 0 [C'JJj' e! {c? "?/ .e/ CO'I?J/C'I rES 1 8 2004 if Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-6365 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CHERYL L BUCHANAN, v, SCOTT E. KING, Defendant ORDER TO RELINQUISH JURISDICTION AND NOW, this 11th day of February, 2004, courisel for the Plaintiff and the Defendant having requested a thirty (30) day continuance on January 9, 2004, and the Conciliator having received no further request for the Custody Conciliation Conference to reconvene, hereby relinquishes jurisdiction of the above captioned matter. Melissa Peel Greevy, Esquire Custody Conciliator :224285 C) ~-~; ( , ,-- ~ -, "-' CO> =0 -=- ~ :::1 f::"1:r r- 8? -:~-J~) ('j::] 8~~ ::6 -:.: -', r.-j co l" c> o w CHERYL L. BUCHANAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY I PENNSYLVANIA v. NO. 03-6365 SCOTT E. KING, Defendant CUSTODY DEFENDANT'S REOUEST FOR CUSTODY CONCILIATION 1. Plaintiff filed a custody complaint December 9, 2003 (copy attached). 2. The parties entered into an agreement (which was never made an Order of Court) prior to any conciliation taking place. 3. Defendant now wishes to change the parties' agreement and plaintiff is not permitting defendant to see his child whatsoever. WHEREFORE, Defendant/Father respectfully requests the Court to schedule a custody conciliation so he can pursue obtaining primary custody of the parties' child. Respectfully submitted, DATE: 2/1/05 KEN ETH F. LEWIS, ESQUIRE At orne for Petitioner/Defendant 1101 N. Front st. Harrisburg I PA 17102 (717) 234-3136 VERIFICATION I hereby verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. 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. Dated: 2)/05 C::" ) ,)(c~C ,~ SCOTT ~. KING' ,j CERTIFICATE OF SERVICE I certify that I have served a true and correct copy of the within document upon attorney for Plaintiff by mailing same, postage prepaid at Harrisburg, PA, on the filing date, at the following address: Francis M. Socha, Esq. THOMAS, THOMAS & HAFER 305 N. Front St. Harrisburg, PA 17101 DATED: 2/2/05 LEWIS, ESQUIRE for Defendant KEN Att CHERYL L BUCHANAN, Pia intiff : IN THE COURT OF COMMON PLEAS : CUM~ERLANO COUNiY, PENNSYLVANIA . ; NO. 03- (0 '3~s-' . e 5 ~ : . ::l :;J :CIVIL ACTION - CUSTODY ~~ ~ i"~ i~ ~ ;5\ ?-{. ~j1~ NOTICE l; ~ <Jf~ YOU HAVE BEEN SUED IN COURT. If you wish to def.nd asalnst the CJ81~~et ~h ~ In the following pages, you must take action within twenty (20) clays after this Complaint and Notice are served, by entering a written appearance personally or by attomey and flllng In writing with the Court your defenses or objections to the claims set forth against you. You are warned that If you fall to do so the case may proceed without you and a judgment may be entered against you by the Court without further notlce for any money claimed In the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights Important to you. I/S. SCOTT E. KING, Defendant YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 00 NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFiCe MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBI.E PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE Carlisle, PA (717) 240-6200 ~q:Avl SO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted dasea defenderse de las demandas que se presentan mas adelante en las slguientes paglnas, debe tomar accl6n dentro de los pr6xlmos velnte (20) dfas despu6s de la notfflcac/6n de esta Demanda y Aviso radicando personalmente 0 por medic cle un abogado una comparecencla escrlta y radlciando enla Corte por escrito sus defensas de, y obJecolones a, las demandas presentadas aqul en contra suya. Se Ie advlerte de que sl usted falls de tomar acci6n como se describe anterlormente, el caso puede proceder sin usted y un fallo por cualquler suma de dinero reclamada enla demanda 0 cualquier atrs reclamacl6n a remedlo sallcltado por 81 demandant. puede ser dletedo en contra suya por Is Corte sIn mas aI/Iso adlclona!. Usted puede perder dinero 0 propledad u otros derechos importantes para usted. LOO!200d 29~g 2BL LIL(XHJ) 515r90'OrOM~) O]1~r)055~ gS'LO []Ol)5002-IO-9]j CHERYL L. BPCHANAN, Plaintiff IN TIG COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No.03-t365 CIVIL ACTION . LAW IN CTJSTODY VS SCO'IT E .KING COM1>LAINT POR CUSTODY AND NOW, comes the Plaintift Cheryl L. Bucbatimi, by ber attorney, Francis M. Socha, Esquire, and makes the following Complaint for Custody: 1. The Plaintiffis Cheryl 1. Buehanlltl, an adult individual c:urrently residing at 804 Swan Drive, Mechanlcsburg, Cumberland County, Pennsylvania 17055. 2. The Defenc:lant is Scott Ii !<ins, lIll adult inclividua1,who CWTCI1tlyresides at 651351 Wcrt2VilIe Road, Enola, Cumbcrllllld County, Pennsylvania 17025. 3. The P1ainliffand Defendant were never married and one (1) child were born out of wedloclc as a result of this relntion.~hip and is the subject of this nction, munely: 4. 5. Hunter Michael King DOe 8/16198 Plaintiffseek primary pbysical custody ofthe minor child. The minor child is presently in the custody of the Plaintiff. During the past live (5)yClU'S, the minor ChiJdhas resided nt the following 6. uddresses: , '. Birth until November 2003. 6939 WertzVille Rood, Enola 17025 November 2003 until present 804 Swan Drive, Mecll1U1iesburg, P A 17055 7. The Datum! mother of the minor child Is the Plaintiff. 8. The natu.ra1 futhcr of the Tllinor cbi1d is the Dofeadllllt LOO/POO d 2999 2eL LtL(XHj) SlS[9010rO~HJ 031HIJOSSH eS'LO (3nl)S002-IO-B3j 9. The Plaintiffhasllot participated as a party or in uny other way in any litigation concerning the custody of the minor child in this or IIny other court. 10. The PJaintiffhas no information ofa custody proc:eedingcoocemlng the minor c:bIld pending in a court of this or any other jurisdictioll. 11. Plaintiff knows of no other person net a party to this action already who has physic:al custody of or c:lllims to hllve cuStody or visitation with the said minor c:b1ld. 12. Plaintiffbelieves that the best interest of the minor chlld would be. served if prlmBlY physic:al custody Is awarded to the mother, the Plaintiff herein. 13. Each parent whose parental rights to the c:bIld have not been terminated and the person who has the phy!lea1 custody of the child have been named IlS parties to this action. WHEREFORE. Cheryl L. Buchanan relJ.uests this Honorable Court to grant her prlmBlY physical custody of the minor child, Hunter Mlc:hllel King. :R.cspcc:t:fully ll'.1bmltted: P 'sM. Socha, Esquire 01 North Second Street Harrisburg, PA 17110 (717) 233-4141 1.0. No 29101 Attorney for Plaintiff OATSO: i;-r.()). 1!1IllMM1eo'f.eItnrarrr. LOu/SOOd 29V9 29L LIL(XHj) 5J51901010~HJ 03JHlJ055H 95'LO (301)5002-10-93j VERrn~.~OY' I, CHERYL L. aUCHAN~, hereby verify that the statements of fact made in the foreqoinq Complaint are true and correct to the best of my knowledqe, information and belief. I understand that any false statements therein are subject to the criminal penalties contained in 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. ~~ du-(,.A"~~7--/ CaeRYL L BUCHANAN DATE: I~ $', (s))' 100/900 d 28~9 281 LII(X~j) 5151901010ij~J 031~I]055~ 65:10 (]nIlS002-IO-83j C) :,:) " to' c '"T1 rn ~ co r f 1 N -:, -.".:.. ~'" " -",- - -',~ ..... ""- III " ' '2 ~ 1'1 )>~; '" ...... "" ~:':I C:' "" -< f" <::> ~ 0 CHERYL L. BUCHANAN PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 03-6365 CIVIL ACTION LAW SCOTT E. KING DEFENDANT IN CUSTODY ORDER OF COURT AND NOW. Friday, February 04, 2005 , upon consideration ofthe attached Complaint. it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. . the conciliator, at DJ Manlove's, 1901 State St., Camp Hill, PA 17011 on Mouday, February 21, 2005 at 11:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court. and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: Isl Melissa P. Greevy, Esq. Custody Conciliator .J f- The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For infonnation about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE, IF YOU DO NOT HA VE AN ATTORNEY OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 .t~ f;v -:z /'c1'r:W~{,7 ->> /1- e ~ ~ ~ /"1T1?J1/ ~ 5(}.h. t ~ ~.&- ~~) ~ .5?/.h.~ )JJ'.J:":'--' C~\~ :? 1.1._1 ~l._ 0.:rJ :01"~n7 -- ! "-J ."d ; <'..~..-J ::JU(..o , , '_ -~.; I' ;_: _~> '__I,-~ :.;, oil , CHERYL L. BUCHANAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-6365 SCOTT E. KING, Defendant CUSTODY CUSTODY STIPULATION AND NOW, this 23rd day of Februcu;::L, 2005, the parties enter into the following stipulation, intending to be legally bound and having these provisions be made into an Order of Court. 1. The parties shall share le:gal custody of their child, Hunter Michael King (born 8/16/98). The parties agree that major decisions concerning their child, inclUding his health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the child's best interests. Each party agrees not to impair the other's rights to shared legal custody. Each party agrees not to attempt to alienate the affections of th,a child for the other parent. Each party shall notify the other of any activity or circumstance concerning their child that: could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. with regard to any emergency decisions which must be made, the parent having physical custody of the child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. S5309, each party shall be entitled to complete information from any doctor, dentist, teacher or professional and to have copies of any reports or information given to either party as a parent as authorized by statute. 2. FATHER shall have primary physical custody of the child with MOTHER having periods of physical custody as described below. 3. MOTHER shall have periods of physical custody with the child as follows: a) alternating weekends from Friday at 5:00 p.m. to Sunday at 7:00 p.m. b) should FATHER be scheduled to work on the Saturday of his weekend, MOTHER shall also have the chi.ld that weekend from Friday evening at 7:30 p.m. through 1:00 p.m. on Saturday. c) FATHER shall have the child each weekend he is not scheduled to work (as long as he continues 1:0 work at least one- half the weekends). If that weekend would normally be MOTHER'S weekend, the parties shall trade weekends and MOTHER shall get the following weekend. d) each Wednesday, MOTHER shall have the child from after school (or 4:00 p.m. should there be no school) through 7:30 p.m. 4. During MOTHER'S periods of physical custody, the child shall not be permitted to be in the presence of Ron Cameron. Additionally, MOTHER may not bring the child to any home where Ron Cameron is residing, even if he is not present (unless he is incarcerated). Moreover, if either party will not be available to personally supervise the child for a period of more than 2 hours, they shall notify each other and give the other the right of first refusal for taking the child during such time, except that FATHER'S morning time shall not apply. 5. The parent with physical custody during any given period of time shall communicate in a prompt fashion with the other parent concerning the well-being of their child, and shall appropriately notify the other parent of any changes in health or educational progress. Each parent shall execute any and all legal authorizations so the other parent may obtain information from the child's schools, physicians, psychologists, or other individuals concerning their progress and welfare. 6. HOLIDAYS: a) THANKSGIVING: In even-number.~d years. MOTHER shall have the child on Thanksgiving from the prior wednesday at 3: 30 p.m. to Sunday at 6:00 p.m., alternating with FATHER on odd- numbered years. b) CHRISTMAS/NEW YEARS: The winter break from school shall be divided into two equal sections. In even-numbered years, FATHER will have the child for Segment A (beginning the last day of school before the holiday break) and MOTHER will have the child for Segment B (the second half of the school break). The reverse will occur in odd-numbered years. c) MOTHER will have physical custody of the child on Mother's Day weekend and FATHER will have physical custody of the child of Father's Day weekend. d) MOTHER will have custody of the child on even- numbered years and FATHER will have custody of the child on odd- numbered years for the following holidays: J~emorial Day holiday and weekend; and Labor Day holiday and weekend. e) The holiday provisions above shall take priority over any other physical custody paragraphs of this Agreement. 7. The parties shall share transportation equally. Unless otherwise agreed upon by the parties, the person beginning his/her period of physical custody will be responsible for retrieving the child. 8. During any period of custody, 'the parties shall not possess or use any controlled substance (other than legally prescribed medicines), nor shall they consume, alcoholic beverages to the point of intoxication. The parties shall assure, to the extent possible, that others in the presence of the child comply with this prohibition. 9. Each parent shall be entitled to reasonable phone contact with the child when in the custody of the other parent. Neither party shall use a speaker phone. 10. Each parent agrees not to attempt to alienate the affections of the child from the other and will make a special conscious effort not to do so. Both parents shall establish a no- conflict zone for their child and refrain from making derogatory comments about the other in the presence of the child and, to the extent possible, shall not permit third parties from making such comments in the presence of the child. 11. Communication should always take place directly between parents, without using the children as an intermediary. 12. The parties are entering into this Agreement pending a custody conciliation. The parties agree to be bound by this Agreement in the absence of any further Order of Court. DATED: ~~d 3-0S- ~lLL~ CHERY L. BUCHANAN :5~r ~/ SCOT'r E. KING 6 DATED: ;J-;) ') - Q 5' ;~f5 ~ l' ,~ yl CHERYL L. BUCHANAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-6365 SCOTT E. KING, Defendant CUSTODY ORDER AND NOW, this ,. / day of h}~ , 2005, it is Ordered and Decreed that the attached Custody Stipulation entered into between the parties is hereby made an Order of Court. BY THE COURT: J. fvJ~ 01 ;l! vJ\! \-~~W5'Q'% RECEIVED APR 21200SJf 4 CHERYL L. BUCHANAN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 03-6365 CIVIL TERM v. CIVIL ACTION - LAW SCOTT E. KING, IN CUSTODY Defendant ORDER OF COURT AND NOW, this z. I - day of April, 2005, upon consideration of the attached Custody Conciliation Summary Report, the attached Custody Stipulation dated February 23, 2005 is adopted and incorporated into this Order of Court with the following additional provisions: 1. Mother's weekend periods of custody shall be supervised by another competent adult until such time as Mother has provided written verification from a licensed mental health professional regarding her ability to provide adequate care and supervision for the parties' six (6) year old son. 2. Either party may make a fax request to the Custody Conciliation to return to the Conciliation process if such request is made between day 30 and day 90 following the date of this Order. Requests for modification outside that time frame shall be made in accordance with the local process for scheduling of Custody Conciliation Conferences. BYTHE COUR~J.. J. Dis!: ~a F. Blair, Esquire, 5440 Jonestown Road. Ha 'sburg, PA 17112 ~nne 8. Costopo0os, Esquire, 5000 Ritter Road, Suite 202. Mechanicsburg. PA 17055 " 2 I 'j Hd I Z ~idV Slul J0 _v , . CHERYL L. BUCHANAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-6365 SCOTT E. KING, Defendant CUSTODY CUSTODY STIPULATION .'. AND NOW, this 23rd day of Februarv, 2005, the parties enter into the following stipulation, intending to be legally bound and having these provisions be made into an Order of Court. 1. The parties shall share legal custody of their child, Hunter Michael King (born 8/16/98). The parties agree that major decisions concerning their child, including his health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the child's best interests. Each party agrees not to impair the other's rights to shared legal custody. Each party agrees not to attempt to alienate the affections of the child for the other parent. Each party shall notify the other of any activity or circumstance concerning their child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. with regard to any emergency decisions which must be made, the parent having physical custody of the child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the "other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. S5309, each party shall be entitled to complete information from any doctor, dentist, teacher or professional and to have copies of any reports or information given to either party as a parent as authorized by statute. . . 2. FATHER shall have primary physical custody of the child with MOTHER having periods of physical custody as described below. 3. MOTHER shall have periods of physical custody with the child as follows: a) alternating weekends from Friday at 5:00 p.m. to Sunday at 7:00 p.m. b) should FATHER be scheduled to work on the Saturday of his weekend, MOTHER shall also have the child that weekend from Friday evening at 7:30 p.m. through 1:00 p.m. on Saturday. c) FATHER shall have the child each weekend he is not scheduled to work (as long as he continues to work at least one- half the weekends). If that weekend would normally be MOTHER'S weekend, the parties shall trade weekends and MOTHER shall get the following weekend. d) each Wednesday, MOTHER shall have the child from after school (or 4:00 p.m. should there be no school) through 7:30 p.m. 4. During MOTHER'S periods of physical custody, the child shall not be permitted to be in the presence of Ron Cameron. Additionally, MOTHER may not bring the child to any home where Ron Cameron is residing, even if he is not present (unless he is incarcerated). Moreover, if either party will not be available to personally supervise the child for a period of more than 2 hours, they shall notify each other and give the other the right of first refusal for taking the child during such time, except that FATHER'S morning time shall not apply. 5. The parent with physical custody during any given period of time shall communicate in a prompt fashion with the other parent concerning the well-being of their child, and shall appropriately notify the other parent of any changes in health or educational progress. Each parent shall execute any and all legal authorizations so the other parent may obtain information from the child's schools, physicians, psychologists, or other individuals concerning their progress and welfare. . ~. 6. HOLIDAYS: a) THANKSGIVING: In even-numbered years, MOTHER shall have the child on Thanksgiving from the prior Wednesday at 3:30 p.m. to Sunday at 6:00 p.m., alternating with FATHER on odd- numbered years. b) CHRISTMAS/NEW YEARS: The winter break from school shall be divided into two equal sections. In even-numbered years, FATHER will have the child for Segment A (beginning the last day of school before the holiday break) and MOTHER will have the child for Segment B (the second half of the school break). The reverse will occur in odd-numbered years. c) MOTHER will have physical custody of the child on Mother's Day weekend and FATHER will have physical custody of the child of Father's Day weekend. d) MOTHER will have custody of the child on even- numbered years and FATHER will have custody of the child on odd- numbered years for the following holidays: Memorial Day holiday and weekend; and Labor Day holiday and weekend. e) The holiday provisions above shall take priority over any other physical custody paragraphs of this Agreement. 7. The parties shall share transportation equally. Unless otherwise agreed upon by the parties, the person beginning his/her period of physical custody will be ,responsible for retrieving the child. 8. During any period of custody, the parties shall not possess or use any controlled substance (other than legally prescribed medicines), nor shall they consume alcoholic beverages to the point of intoxication. The parties shall assure, to the extent possible, that others in the presence of the child comply with this prohibition. 9. Each parent shall be entitled to reasonable phone contact with the child when in the custody of the other parent. Neither party shall use a speaker phone. 10. Each parent agrees not to attempt to alienate the affections of the child from the other and will make a special .-' . - conscious effort not to do so. Both parents shall establish a no- conflict zone for their child and refrain from making derogatory comments about the other in the presence of the child and, to the extent possible, shall not permit third parties from making such comments in the presence of the child. 11. communication should always take place directly between parents, without using the children as an intermediary. 12. The parties are entering into this Agreement pending a custody conciliation. The parties agree to be bound by this Agreement in the absence of any further Order of Court. DATED: Q- d '3 - o~ CJQ'L~gf-JvJ~rL6~ CHERY L. BUCHANAN DATED: .;J- '} ) - Q '5' --< ./ VeR'GLi: ~ SCOTT E. KING ~ RECEIVED APR 212005Y CHERYL L. BUCHANAN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 03-6365 CIVIL TERM v. CIVIL ACTION - LAW SCOTT E. KING, IN CUSTODY Defendant 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: DATE OF BIRTH CURRENTLY IN THE CUSTODY OF NAME Hunter Michael King August 16.1998 Father 2. A Custody Conciliation Conference was held on April 8. 2005 in response to Father's filing of a Request for Custody Conciliation on February 2, 2005. Present for the conference were: the Mother, Cheryl L. Buchanan. and her counsel, Nora F. Blair. Esquire; the Father, Scott E. King, and his counsel, Jeanne B. Costopoulos, Esquire. 3. attached. The parties reached an agreement for a Temporary Order in the form as Date elissa Peel Greevy, Esquire Custody Conciliator :?uv & !fIlii tf :248836 v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : fA3J,~ : No. 03-~CIVIL TERM CHERYL 1. BUCHANAN, Plaintiff Defendant CIVIL ACTION-LAW IN CUSTODY SCOTT E. KING, DEFENDANT'S EMERGENCY PETITION TO MODIFY CUSTODY AND NOW, the Defendant, Scott E. King, by and through his attorney, Jeanne B. Costopoulos, Esquire, makes the following Petition for Emergency Relief: 1. The Petitioner, Defendant above, Scott E. King (hereinafter referred to as Father), is an adult individual who currently resides at 6939 Wertzville Road, Enola, Cumberland County, Pennsylvania, 17025. 2. The Respondent, Plaintiff above, Cheryl 1. Buchanan (hereinafter referred to as Mother), is an adult individual who is believed to be currently residing at 812 Swan Drive, Creekview Mobile Home Park, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Father seeks sole iegal and physical custody of his son, Hunter Michaei King, born August 16, 1998, subject to periods of supervised visitation with Mother pending Mother obtaining a psychological and drug and alcohol evaluations. 4. Previously, Mother iost her job a custody conference was held before Melissa P. Greevy, Esquire, on April 8, 2005 and an Order of Court was signed on April 21, 2005 adopting a stipulation signed by the parties on February 23, 2005 with some additional provisions set forth in the order. Said order with attached stipulation and conciliator report is attached as Exhibit A. 5. The April 21, 2005 Order required Mother's weekend periods of custody to be supervised by another competent adult individual until such time as she provided written verification from a licensed mental health professional regarding her ability to provide adequate care and supervision for the parties' child. 6. Mother has not provided written verification from a licensed mental health professional regarding her ability to provide adequate care and supervision for the parties' child. 7. Mother's behavior has grown increasing erratic. 8. Since implementation of the April 21, 2005 Order, the child's maternal grandmother, Joyce Buchanan (hereinafter referred to as "Joyce") has regularly provided supervision of Mother's periods of partial custody. According to the child, on August 6, 2005, Mother snuck out of Joyce's house with the child at 3:30 a.m. The child informed Father that Mother told him she was taking him "to a 7/11 in Harrisburg to get a slushy". The child fell asleep in the car and does not know where Mother took him or when he returned to his grandmother's house. 9. On Thursday, August 5, 2005, the child's paternal grandmother, Sandy Murlatt (hereinafter referred to as "Sandy"), received a phone call from Joyce, regarding Mother's increasingly disturbing behavior. Sandy suggested that Joyce attempt to get a "302 commitment court order" of her daughter. Joyce called Sandy back later indicating that she'd talked with an attorney and that she would have to go through crisis intervention. Joyce took Mother to Harrisburg Hospital but Mother checked herself out within an hour. Joyce told Sandy that Mother said if she lost custody of the child to Father she would kill the child and then herself. This statement concerned Joyce such that she told Sandy not to let Mother take the child and to watch him ifhe had to get on the bus for school. Sandy immediately wrote a statement regarding the phone caiI. Said statement is attached as Exhibit B. 10. The current custody order specifically provides that the child is not to be in the presence of Ron Karnaron as a result of a drug raid on his house while Mother was living there with the child. Mr. Karnaron is currently incarcerated in the Cumberland County Prison for DUI charges and he also has pending drug charges in Dauphin County. Father recently received a letter dated August 5, 2005 signed by Mr. Karnaron informing him that Mother is addicted to crack cocaine and that the child shouid not be permitted around her. Said letter is attached as Exhibit C. He noted that Mother had sold the furniture out of house to support her drug habit. 11. Mother's appearance and behavior is consistent with a person with a serious drug problem and Father believes that if the court would simply see and speak to Mother that Father's concerns would be evident. WHEREFORE, the Father respectfully requests this Honorable court to grant him sole legal and physical custody of his son subject to supervised visitation with Defendant pending the results of a drug evaluation and psychological evaluation then periods of reasonable partial custody thereafter as determined by the person conducting the psychological evaluation. DATED: r !r1!c5 BY: Respectfully submitted, /-2' J~ B. Costopoulos, Esquire ATTORNEY FOR DEFENDANT 5000 Ritter Road, Suite 202 Mechanicsburg, P A 17055 Phone: (717) 790-9546 PA Supreme Ct.lD No. 68735 CHERYL L. BUCHANAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 03-6353 CIVIL TERM Defendant : CIVIL ACTION-LAW : IN CUSTODY SCOTT E. KING, VERIFICATION I, Scott E. King, hereby verifY and state that the statements made in the foregoing petition are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. g4904, relating to unsworn faisification to authorities. Date: '6-li- '0 ~ Signature: L".7 C){~f: Scott E. King 1<- ,;, (j CHERYL L. BUCHANAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : No. 03-6353 CIVIL TERM SCOTT E. KING, Defendant : CIVIL ACTION-LAW : IN CUSTODY CERTIFICATE OF SERVICE I, Jeanne B. Costopoulos, Esquire, hereby certifY that this day I served a copy of the foregoing document upon the person and in the manner, indicated below, which service satisfies the requirements of the PA Rules of Civil Procedure, by depositing a copy of the same with the United States Post Office at Mechanicsburg, Pennsylvania, through first class mail, prepaid, and addressed as follows: Nora F. Blair, Esquire 5440 Jonestown Road P.O. Box 6216 Harrisburg, PA 17112-0216 BY: ~ ~ ------ DATED: Jln /c;- Jeanne B. Costopoulos, Esquire ATTORNEY FOR DEFENDANT 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Phone: (717) 790-9546 P A Supreme Ct. ill No. 68735 RECEIVED APR 2120# CHERYL L. BUCHANAN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 03-6365 CIVIL TERM v. CIVIL ACTION - LAW SCOTT E. KING, IN CUSTODY Defendant $1 AND NOW, this J J day of April, 2005, upon consideration of the attached Custody Conciliation Summary Report, the attached Custody Stipulation dated February 23, 2005 is adopted and incorporated into this Order of Court with the following additional provisions: ORDER OF COURT 1. Mother's weekend periods of custody shall be supervised by another competent adult until such time as Mother has provided written verification from a licensed mental health professional regarding her ability to provide adequate care and supervision for the parties' six (6) year old son. 2. Either party mali make a fax request to the Custody Conciliation to return to the Conciliation process if such request is made between day 30 and day 90 following the date of this Order. Requests for modification outside that time frame shall be made in accordance with the local process for scheduling of Custody Conciliation Conferences. J. Dis!: Nora F. 8lair. Esquire. 5440 Jonestown Road, Harrisburg, PA 17112 Jeanne 8. Costopoulos, Esquire, 5000 Ritter Road. Suite 202. Mechanicsburg. PA 17055 .~ TRUE C(lI>Y ~';'(~I,.I i"'...""..... I T ' hjJ.,! "1:,> ,ln' .., n estimony wf,''''''of fL"~ '- ,C, ' G 'b!" ere vn' 0 Set my haRd ~I~ 2seal~ said Co t at ,., k18, P~. TJlI ~ f 'JfJAI Q. r- ............ y. '. .../~., . .1ft'"- ,..,..il. . ~ J).!'1Yl.l . .... .. "'" Pro~;o~ro;;; ~.'....._- CHERYL L. BUCHANAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-6365 SCOTT E. KING, Defendant CUSTODY CUSTODY STIPULATION ..,'. AND NOW, this 23rcf day of February, 2005, the parties enter into the following Stipulation, intending to be legally bound and having these provisions be made into an Order of Court. 1. The parties shall share legal custody of their child, Hunter Michael King (born 8/16/98). The parties agree that major decisions concerning their child, including his health, welfare, education, religious training and upbringing shall be made by them jointly, after. discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the child's best interests. Each party agrees not to impair the other's rights to shared legal custody. Each party agrees not to attempt to 'alienate the affections of the child for the other parent. Each party shall notify the other of any activity or circumstance concerning their child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the "other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. S5309, each party shall be entitled to complete information from any doctor, dentist, teacher or professional and to have copies of any reports or information given to either party as a parent as authorized by statute. 2. FATHER shall have primary physical custody of the child with MOTHER having periods of physical custody as described below. 3. MOTHER shall have periods of physical custody with the child as follows: a) alternating weekends from Friday at 5:00 p.m. to Sunday at 7:00 p.m. b) should FATHER be scheduled to work on the saturday of his weekend, MOTHER shall also have the child that weekend from Friday evening at 7:30 p.m. through 1:00 p.m. on Saturday. c) FATHER shall have the child each weekend he is not scheduled to work (as long as he continues to work at least one- half the weekends). If that weekend would normally be MOTHER'S weekend, the parties shall trade weekends and MOTHER shall get the following weekend. d) each Wednesday, MOTHER shall have the child from after school (or 4:00 p.m. should there be no school) through 7:30 p.m. 4. During- MOTHER'S periods of physical custody, the child shall not be permitted to be in the presence of Ron Cameron. Additionally, MOTHER may not bring the child to any home where Ron Cameron is .residing, even if he is not present (unless he is incarcerated). Moreover, if either party will not be available to personally supervise the child for a period of more than 2 hours, they shall notify each other and give the other the right of first refusal for taking the child during such time, except that FATHER'S morning time shall not apply. 5. The parent with physical custody during any given period of time shall communicate in a prompt fashion with the other parent concerning the well-being of their child, and shall appropriately notify the other ~arent of any changes in health or educational progress. Each parent shall execute any and all legal auth6rizations so the other parent may obtain information from the child's schools, physicians, psychologists, or other individuals concerning their progress and welfare. 6. HOLIDAYS: a) THANKSGIVING: In even-numbered years, MOTHER shall have the child on Thanksgiving from the prior Wednesday at 3:30 p.m. to Sunday at 6:00 p.m., alternating with FATHER on odd- numbered years. b) CHRISTMAS/NEW YEARS: The winter break from school shall be divided into two equal sections. In even-numbered years, FATHER will have the child for Segment A (beginning the last day of school before the holiday break) and MOTHER will have the child for Segment B (the second half of the school break). The reverse will occur in odd-numbered years. c) MOTHER will have physical Mother's Day weekend and FATHER will have child of Father's Day weekend. d) MOTHER will have custody of the child on even- numbered years and FATHER will have custody of the child on odd- numbered years for the following holidays: Memorial Day holiday and weekend; and Labor Day holiday and weekend. e) The hbliday provisions above shall take priority over any other physical custody paragraphs of this Agreement. 7. The parties shall share transportation equally. Unless otherwise agreed upon by the parties, the person beginning his/her period ~f physical custody will be .responsible for retrieving the child. custody physical of the child on custody of the 8. During any period of custody, the parties shall not possess or use any controlled substance (other than legally prescribed medicines), nor shall they consume alcoholic beverages to the point of intoxication. The parties shall assure, to the extent possible, that others in the presence of the child comply with this prohibition. 9. Each parent shall be entitled to reasonable phone , contact with the child when in the custody of the other parent. Neither party shall use a speaker phone. 10. Each parent agrees not to attempt to alienate the affections of the child from the other and will make a special conscious effort not to do so. Both parents shall establish a no- conflict zone for their child and refrain from making derogatory comments about the other in the presence of the child and, to the extent possible, shall not permit third parties from making such comments in the presence of the child. 11. Communication should always take place directly between parents, without using the children as an intermediary. 12. The parties are entering into this Agreement pending a custody conciliation. The parties agree to be bound by this Agreement in the absence of any further Order of Court. DATED: rO.- d '3 - O~ CJQ'L~;f~JvJ~~ CHERY L. BUCHANAN DATED: .;J-. J ') - <'5 <) :5e~tL'~ ~/ SCOTT E. KING ~ ,. CHERYLL.BUCHANAN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 03-6365 CIVIL TERM v. CIVIL ACTION - LAW SCOTT E. KING, IN CUSTODY Defendant 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: DATE OF BIRTH CURRENTLY IN THE CUSTODY OF NAME Hunter Michael King August 16,1998 Father 2. A Custody Conciliation Conference was held on April 8, 2005 in response to Father's filing of a Request for Custody Conciliation on February 2, 2005. Present for the conference were: the Mother, Cheryl L. Buchanan, and her counsel, Nora F. Blair, Esquire; the Father, Scott E. King, and his counsel, Jeanne B. Costopoulos, Esquire. 3. attached. The parties reached an agreement for a Temporary Order in the form as l{/I~rP Date elissa Peel Greevy, Esquire Custody Conciliator :248836 ~,l.tur tL-1 s, ).00' /v:>5;;"" JIo-d. "- ~ iJtYJ- ~ tJ-<f"'-- ~ ~/lJ'I.,.aw tv"- ~ ~ ~ '(tJ '-MJ ~~' j. ~ ~ ~ 'l"'; a. 30>-.- " '. - ~ '. CJIf'-'-- ~ /I"-"- ~~~~~~ a- ~ fl.--0 '-M-~ ~ ~ td~ ~;ff<}, ~ &U~~. '1....... {.o.. ~ U.,"tLjD /Lv ~ :1:I.<-~~~~ ~ ;td . 1IyC~ v.u ~;;t/-d ~~~fth.kd~~ ~~~~~M' (}i-tj~. {lh;1J~~. . ~.~ ~ C}d' m< ft.u ~ 'fv':' ~ ft. ~~'P~~,;t:LP Of" ~ ~.-..w... ~;b ~ ~.' " '/~ -("~ J G ,e.n-+t)JU7.5 S <:"0 it 1It-//o; l' ;(fJouJ ~u dorOt 6.)fl}t.Jf ~ A e'/;~ H",~ /"16-) ~tJ t-J- Eu/:.-)!. .f V~- 7ll- SoP/r --/J.//Vl, /,{;4! ~(.4 s).~LL/cI br /ltLM.ee, 0 I! cC Itc-Z( r 5. ~v'd<!~{( -;S C~;(c):' COCA/)'t/C: :.I doN r , ,.L) /JJ l: /Ij A ?I)CJ('/ r %JJ fl Jc-l--- ,)c-E /J/4V~ /~lJulb-R /'11 /11(/ : S C c5J 11 Uu (2.,f;J SeWd ~'nC:: r 1 Jt.;/i!rC 106 L wr /;Jv;, /1 4,vcl' ..r/r tf/Ot/6'" Ae'-f:! /l- >/;?-~-,4fb7f./~J G ' :, -5c-O-rt -IA41 G>~-,vc/~ J/,V;C--- .5~~.? liuI!1~. CI1t-~/ "K)~c1 -SW1CJk'('~<J {'/6/NI' '-"150 / i /Yu.5 S c- () j? y:' d I r:vf}~r<t .fi! Cc7" YiB(}-ci' -,?/, ,0., 41s0, ~ c-o -;,L /1/;, I~ /Vd va ~ CJ, CR1/ ;2/1S b-v~""-N -5'~)cl ; /l1 ~-/JN/!-tla- ..;D /~-c/ jt-'lf!... , !/I;f)/I-: '. fr MV5 f-- CoJ41~ -m /!v c:'fv/ \/{CJlt/-6-c/~X G T/vt If OJ'V GAj?(/.'IA fL-'~1 ': (1NJLJ+; f~ ''.501() 7f'e pt 51 M U.,L _ , 1100 ShC') w/ld EllicK /?udl:- AlVei 1/;4 //ow ~L/~ /II /;uc/ IcJ 7P ~;<t y~ b7 ~ ~/,uc.I:./2.t /OV# JcI ~lJ't.4IeCf..... !,oc'O-ffJD u~rf "oo!<}Lj} ht~/ c,tvtcl( It//!h12 'WJ<fY 1 f"~ V (') (~. , .-' ",? c:"'~ .0., r:.. G~ -- cP .,-. / ~? (J (;.~-- I-. ~.,'1 ...( Q, ~-" p'i f.:: -:'J'd ."),).. C~\~) ~." ~,.., > ~'f'\ '(2.C) /~ rO (~~ ~;;O ::;<. u> ...l [) RECEIVED AUG 18 2005 r CHERYL L. BUCHANAN, Piaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA 03- 6'3{ps : No. "'H.II~'CIVIL TERM SCOTT E. KING, Defendant : CIVIL ACTION-LAW : IN CUSTODY ORDER OF COURT AND NOW, this 18' dayof AfV' v , 2005, upon consideration of Defendant's Emergency Petition to Modify Custody, a RuIe is hereby issued on Plaintiff, Cheryl L. Buchanan, to show cause why the requested relief shouId not be granted. RuIe returnable zo days from service. In the meantime, untii further Order of Court, ali contact between the Piaintiff, Cheryl L. Buchanan, and the chiid, Hunter Michaei King, bom August 16, 1998, shall be supervised by an agency unless otherwise agreed by Defendant, Scott E. King. BY THE COURT: d. 1. ~ Jt V;N\iI'\_11(;,:,)~,!'.'lcl I I '111[""" ;.;:.'~ c;. :':-.'. ~""II" i\.l.1'I1 I'_)_i . " "-:',Y oj, IV I 0 :01 loll! B I 5f1V SOUl AtlV10NOHlOod 3H1 :10 3:ll:H(}{j31I::l