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HomeMy WebLinkAbout08-43964 C. WILSON, Plaintiff WILSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 0 f- ? 3 9L CIVIL ACTION - AT LAW - CUSTODY COMPLAINT FOR CUSTODY e Plaintiff, Robert C. Wilson, by and through his attorneys, the Law Offices of Patrick F. Lauer, J ., L.L.C., seeks to obtain custody of his minor children and makes the following averments in sum rt thereof: The Plaintiff is "Father", Robert C. Wilson and is an adult individual who resides at 119 North Sporting Hill Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. The Defendant is "Mother", Rhonda Wilson and is an adult individual who currently resides at 6777 North Main Street, Falmouth, Michigan. There are three dependent children, namely, Robert James Wilson, born February 17, 200 (age 6), Isaiah Michael Wilson, born April 19, 2003, and Clifford Jeremiah Wilson, born Fe ruary 27, 2005. The children were not born out of wedlock. The Plaintiff seeks primary physical custody of the children. The minor children are presently in the custody of the Defendant, who resides at 6777 North Main Street, Falmouth, Michigan. During the past five years, the children have resided at the following address with the folk wing persons: Dates: Addresses: List All Persons: Feb 2008 - June 2008 20 High Street Father, Robert Wilson & New Buffalo, PA Mother, Rhonda Wilson v Feld 2007 - Feb 2008 9590 S. Call Road McBain, MI 49657 FeO 2006 - Feb 2007 Alpena, Michigan - Feb 2006 Reed City, Michigan Father, Robert Wilson & Mother, Rhonda Wilson Father, Robert Wilson & Mother, Rhonda Wilson Father, Robert Wilson & Mother, Rhonda Wilson The relationship of Plaintiff to the children is that of natural father. He currently resides with his parents, Michael & Marcia Wilson. The relationship' of Defendant to the children is that of natural mother. She j resides with her paramour, Matthew Cole and his children and the Wilson children. The Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 0. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. 1. The Plaintiff does not know of a person not a parry to the proceedings who has physica custody of the children or claims to have custody or visitation rights with. respect to the 2. The best interest and permanent welfare of the children will be served by granting the reli f requested, because: a. Defendant currently does not allow Plaintiff to see the children; b. Defendant does not allow telephone contact between Plaintiff and his children; b. Plaintiff would accommodate the children developing a healthy relationship with both parents ; C. Plaintiff is willing to look out for the children's best interest. the 13. Each parent whose parental rights to the children have not been terminated and on who has physical custody of the children has been named as parties to this action. No V other p will be grant sons are known to have or claim a right to custody or visitation, and therefore no notice iven of the pendency of this action and the right to intervene, save as to the Defendant. THEREFORE, The Plaintiff respectfully requests this Honorable Court approve any it reached between the parties; or, in the event they are unable to reach a settlement, Plaintiff rights of legal and primary physical custody. Respectfully submitted, Date: ? 22/ z pp MarInrSOf ey, Esquire LawOfPatrick F. Lauer, Jr., L.L.C. 2108 M eet, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 C. WILSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA No. WILSON, CIVIL ACTION - AT LAW - CUSTODY Defendant VERIFICATION verify that the statements made in this Complaint are true and correct. I understand that false st tements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unswo falsification to authorities. Date: Z2--O 2 Robert C. Wilson (71 N 90. T7 c -a C { ROBERT C. WILSON, Plaintiff/Petitioner WILSON, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. CIVIL ACTION - AT LAW - CUSTODY PETITION FOR EMERGENCY EX PARTE CUSTODY RELIEF D NOW, Petitioner, by and through his attorneys, the Law Offices of Patrick F. Lauer, Jr., L.L. ., files this Petition for Emergency Ex Parte Custody Relief against Respondent, and in support hereof, avers as follows: Petitioner is "Father", Robert C. Wilson and is an adult individual who currently resides t 119 North Sporting Hill Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. Respondent is "Mother", Rhonda Wilson and is an adult individual who currently resides t 6777 North Main, Falmouth, Michigan. The parties are the parents of the following child(ren): Robert James Wilson, born February 17, 2002 (age 6), Isaiah Michael Wilson, born April 19, 2003, and Clifford Jeremiah Wilson, born February 27, 2005. The parties are current spouses having been married on June 20, 1998. Petitioner filed a Custody Complaint simultaneously with this petition. On or about June 26, 2008, Respondent moved from the residence in which Petitioner, Respondent and the children were residing. Petitioner only found out that Respondent and the children had moved after waking up in the morning finding Respondent and the children missing. Petitioner last saw the children on June 25, 2008, when Petitioner, Respondent and the children went to bed. Respondent has learned from a friend the current location of Respondent and the 0. Petitioner is concerned about the welfare and safety of the children. 1. Respondent has deprived Petitioner of his right to see the children. Respondent has Petitioner's legal and physical custody rights. Petitioner loves the children and has always had a lo, unconsc: I for Emei ( the child ( hearing; Preventii Respond children relationship with them. Respondent's conduct in removing the children clandestinely is ale and certainly contrary to the best interests of the children. EFORE, Petitioner respectfully requests that this Honorable Court grant the Petition Ex Parte Custody Relief and enter an Order as follows: Directing that Respondent immediately return to the jurisdiction of this Court with and issue a bench warrant for her arrest and return to the jurisdiction; Awarding Petitioner sole legal and physical custody of the children until further Pursuant to the Uniform Child Custody Jurisdiction Act and the Parental Kidnapping Act, the courts and law enforcement agencies in whatever jurisdiction in which and/or the children may be found are directed to enforce this Order to ensure that the returned to Pennsylvania and surrendered to Petitioner's custody; ( If Respondent and/or the children are found in another country that is a signatory to the H age Convention on International Child Abduction, the controlling authority for that jurisdiction shall be contacted to ensure that the children are returned to the jurisdiction of this Court; (I fees for to locate Civil Pri children; Directing Respondent to pay Father's counsel fees, costs and expenses, including investigators, that are the result of the efforts by Petitioner and Petitioner's counsel ndent and bring her and the children before the Court; Permitting Petitioner to engage in open discovery pursuant to Pennsylvania Rules of e 4001, et. seq., in order to determine the whereabouts of Respondent and the Granting any other relief deemed appropriate by the court. Date: Marti . M ley, Esquire Law Office of Patrick F. Lauer, Jr., L.L.C. 2108 Mar t Street, Aztec Building 2-?L) Z Jv p Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 T C. WILSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA is. No. )A WILSON, CIVIL ACTION - AT LAW - CUSTODY Defendant VERIFICATION verify that the statements made in this Complaint are true and correct. I understand that false herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to falsification to authorities. Date: 7f22- a4o???- Robert C. Wilson GJ 7 ?:.: ` r ' 1'til `.-T7 I ROBERT C. WILSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW RHONDA WILSON, : Defendant NO. 08-4396 CIVIL TERM IN RE: PLAINTIFF'S PETITION FOR EMERGENCY EX PARTE RELIEF AND NOW, this 29th day of July, 2008, upon consideration of Plaintiff's Petition for Emergency ex Parte Relief with respect to the parties' children, Robert James Wilson (d.o.b. February 17, 2002), Isaiah Michael Wilson (d.o.b. April 19, 2003), and Clifford Jeremiah Wilson (d.o.b. February 27, 2005), it is ordered and directed, pending the conciliation conference and further order of court, it is ordered and directed as follows: 1. Custody of the children shall be shared on an alternating weekly basis, from Saturday at 6:00 p.m. until Saturday at 6:00 p.m., with Plaintiffs first period of custody to commence on Saturday, August 2, 2008, and responsibility for transportation of the children being that of the parent receiving custody; 2. Neither party shall secrete the location of the children from the other party, nor interfere with reasonable telephonic communications between the other parent and children. ,,Warlin L. Markley, Esq. 2108 Market Street Aztec Building Camp Hill, PA 17011-4706 Attorney for Plaintiff IvKonda Wilson 6777 North Main Street Falmouth, MI 49632 Defendant, pro Se BY THE COURT, ?r I le i.' J. ?esley Oler Jr., (, ,0 ce;.; OF -17 tifiiluZ ROBERT C. WILSON IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-4396 CIVIL ACTION LAW RHONDA WILSON IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, July 30, 2008 , upon consideration of the attached Complaint, the conciliator, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, September 02, 2008 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. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunda Esq.. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT WHERE YOU CORN , GO O OR HELP TELEPHONE THE OFFICE SET GET FORTH BELOW TO FIND O Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ROBERT C. WILSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION-LAW RHONDA WILSON, : NO. 2008-4396 Defendant : IN CUSTODY ANSWER TO COMPLAINT IN CUSTODY AND PRELIMINARY OBJECTIONS OF PLAINTIFF TO DEFENDANT'S COMPLAINT FOR CUSTODY AND NOW, comes Plaintiff, by and through her attorneys, MidPenn Legal Services, and files this Answer and files these Preliminary Objections to Defendant's Complaint for Custody. ANSWER TO COMPLAINT In response to Plaintiff s Complaint, Defendant, hereinafter referred to as "MOTHER," responds as follows to the Plaintiff's averments in the order in which they are raised: 1. Admitted. 2. Denied. MOTHER resides at 378 Thistlewood Drive, Cadillac, Wexford County, Michigan 49601. 3. Admitted. 4. Admitted. 5. Neither admitted nor denied. Children reside between Plaintiff and MOTHER pursuant to this Court's order July 29, 2008. 6. Admitted in part, denied in part. The children lived in continuously in Alpena, Michigan with the parties from the beginning of March 2005 through February 2007. By way of further answer, MOTHER points out that even according to Plaintiffs averments, the children never lived in Cumberland County prior to this Court's Order of July 29, 2008. 7. Admitted. 8. Denied. 9. Admitted. 10. Denied. The Plaintiff is well aware of investigations by Children and Youth agencies in Michigan and Pennsylvania that were the direct consequence of his abuse of his children on June 24, 2008. 11. MOTHER does not have sufficient information to admit or deny this averment. 12. Denied. By way of further answer, MOTHER avers that the best interest and permanent welfare of the children will be served by transferring the jurisdiction of this matter to the appropriate Michigan courts and granting MOTHER custody in the interim because: a. MOTHER is better able to provide the nurture, love and safety that the children need; b. Plaintiff is an alcoholic and in alcoholic rages has abused both MOTHER and his minor children; c. MOTHER is willing to accommodate the children in developing a healthy relationship with the Plaintiff. 13. Admitted. PRELIMINARY OBJECTIONS AND NOW, comes MOTHER, by and through her attorneys, MidPenn Legal Services, and files these Preliminary Objections to Plaintiff's' Complaint for Custody and in furtherance thereof states as follows: 14. Paragraphs 1 through 13 are hereby incorporated as if fully set forth herein. 15. Up until June 24, 2008, the parties and their children had only lived in Michigan or in Perry County, Pennsylvania. (See paragraph 6 of Plaintiff s Complaint in Custody) 16. On June 24, MOTHER fled the marital residence with her children in response to Plaintiff s abuse of herself and Plaintiff's attack of the children. 17. On June 24, 2008, the parties' three year old son, Clifford, was injured, and their five year old son, Isaiah suffered welts after Plaintiff hit them with a plastic spoon repeatedly and with enough force to break the ceramic top off of the spoon and splinter its handle. 18. MOTHER fled to Michigan with her children in order to protect them and for her own safety. 19. MOTHER stayed in a shelter for victims of domestic violence in Michigan for three days after fleeing Perry County. 20. MOTHER went to Michigan not because of its distance but because she had not been in the Commonwealth long enough to establish supports or friendships that were deep or sustained enough to help her in this situation. 21. MOTHER sought and received a protection order in Michigan a copy of which is attached hereto. 22. Plaintiff filed a Petition for Emergency ExParte Custody Relief and a Complaint in Custody on July 22, 2008. 23. This Court issued an ExParte Order sending the matter to conciliation. The Order is dated July 30, 2008, and the conciliation is scheduled before Dawn Sunday for September 4, 2008. 24. MOTHER has abided by the terms of this Court's ExParte Order and has assumed the attendant stress, expense, and inconvenience. 25. Pursuant to the Uniform Child Custody Jurisdiction Enforcement Act 23 Pa.C.S. §5421, this Court is not the "home state" and Cumberland County is not the appropriate forum for the litigation of this matter. 26. Plaintiff, MOTHER, and children have lived in Pennsylvania less than six months. 27. Prior to the parties move to Perry County in February of 2008 (See Plaintiff's Complaint, Paragraph 6), the parties lived continuously in Michigan. 28. The only court in the Commonwealth that has even arguable jurisdiction is in Perry County. 29. The parties still have significant ties to Michigan including many family members and friends. 30. MOTHER entered a program for victims of domestic abuse called OASIS in Michigan which provides transitional housing and other services for herself and the children. 31. MOTHER is prepared to enroll the children in the public school system in Cadillac, Michigan. 32. MOTHER has already secured part-time employment at Home Depot in Michigan. 33. MOTHER has enrolled in an education program to complete the requirements for a registered nursing degree. 34. MOTHER has been a home maker and stay at home spouse for the last five years. The children have not been continuously out of their MOTHER's care for more than a day before this Court's Order of July 30, 2008. 35. The children's best interests are best served by staying primarily with their MOTHER pending resolution of this custody dispute. 36. Under 23 Pa.C.S. §5427(b)(1-4), the Court must consider the following factors in determining jurisdiction in child custody cases: • whether domestic violence has occurred; • the length of time the child has resided outside the Commonwealth; • the distance between the court in this Commonwealth and the court in the state that would assume jurisdiction; • the relative financial circumstances of the parties. 37. MOTHER and children are victims of domestic violence, suffered at the hands of the Plaintiff. 38. The children have lived all of their lives in Michigan except for four and a half months in the Commonwealth. 39. The distance between the Commonwealth and Michigan is significant and transportation back and forth under this Court's Order of July 30 is stressful and exposes the children to unnecessary risks. 40. This Court is an inconvenient forum for MOTHER. 41. MOTHER has engaged counsel in Wexford County, Michigan, and anticipates that an action will be filed shortly. 42. This Court's Order of July 30 precludes the children from entering school in either Michigan or Pennsylvania. 43. It is in the children's best interests to attend school in Michigan. 44. MOTHER's financial circumstances relatively make it more difficult for her to come to Pennsylvania to litigate a custody matter than it would be for Plaintiff to repair to his former home of Michigan. 45. Under the Uniform Child Custody Jurisdiction and Enforcement Act as cited above, Wexford County, Michigan, is the more appropriate forum for this custody action. WHEREFORE, the Defendant seeks the following relief: 1. Issue a Rule to Show Cause why this Court should not relinquish jurisdiction of this custody case to the appropriate court in Wexford County, Michigan; 2. Vacate this Court's earlier Order of July 29, 2008; 3. Enter a temporary Order granting MOTHER primary physical custody, Plaintiff with liberal phone contact, in order that the children may attend school and be in a safe, loving and familiar environment. 4. Any other relief this Court feels is just and equitable. Respectfully Submitted, Grace D'Alo MidPenn Legal Services 401 E. Louther Street Carlisle, PA 17013 (717)243-9400 Original - Court 3rd copy - Petitioner (pink) 1 st copy - Judge/Assignment derk (green) 4th copy - Return (yellow) Approved, SCAO 2nd copy - Respondent (blue) STATE OF MICHIGAN PETITION FOR CASE NO. ROTECTION ORD WEXFORDH JUDICIALCOCIRCUIT UNTY PE(DOMESTRSONAL RELATIONSH P)ER d - a3a ` P? Court address Court telephone no. 437 E DIVISION STREET, CADILLAC, III 49601 231-779-9450 ® P ' ' nets name Age ?ndent's name, address, and telephone no. Age o .Z g KD?O? e . W?? SS??? X ddress and telephone no. ere cNd can reach petitioner -41-4 -qc>3 - 2-u33 -4-4s--43310 "V11L) lCaAjAgp2M,IfiRL"61 ®1. The petitioner and respondent: Deare husband and wife. ? were husband and wife. have a child in common. ? have or had a dating relationship. ? reside or resided in the same ho sehold. ©2. ? The respon nt is required to carry a firearm in the course of his/her employment ? Unknown. O 3. a. There re ? are not other pending actions in this or any other court regarding the parties. Case number Name of court and county Name of judge b. There . ? are ? are not . orders/judgments entered by this or any otAycourt, reggd t®parties. Case number Name of court and county Name of judge EO4. 1 need a personal protection order because: Explain what has happened (attach ad?' rtksheets) ?. L) [UU6 OR DD COON Y ®5. I a k the court to grant a personal protection order prohibiting the respondent from: GL? a. entering onto the property where I live. I state that either I have a property Interest in the premises, I am-rtidrd to the respondent, or the respondent has no property interest in the premises. 9b. entering onto the property at -FX ' assaulting, attacking, beating, molesting, or wounding 11k.-g,.0ta- %, &sn , h\QXA , - u->„k<br ? ;a-Lci, name(s) Gl, WAS&V\ L' U4C,Y, W-?Ssv. ? d. removing the minor children from the petitioner who has legal custody, except as allowed by a custody or parenting time order as long as removal of the children does not violate other conditions of the personal protection order. ? e. stalking as defined under MCL 750.411 h and MCL 750.411 i which includes but is not limited to: ? following me or appearing within my sight. ? appearing at my workplace or residence. f ending mail or other communications to me. ? contacting me by telephone. pproaching or confronting me in a public place or on private property. entering onto or remaining on property owned, leased, or occupied by me. ? placing an object on or delivering an object to property owned, leased, or occupied by me. interfering with efforts to remove my c ildren/ personal property from premises solely owned/leased by the respondent. threatening to kill or physically injure tc51 & k A.-> IN with me at my place of employment or education or engaging in conduct that impairs my employment or educational relationship or environment. ? i. having access to information in records concerning a minor child of mine and the respondent that will reveal my address, telephone number, or employment address or that will reveal the child's address or telephone number. purchasing or possessing a firearm. k. other. ?6. t ake this petition under authority of MCL 600.2950/MCL 600.2950a and ask the court to grant a personal protection order. ! request an ex parte order because immediate and irreparable injury, loss, or damage will occur between now and a hearing or because notice itself will cause irreparable injury, loss, or damage before the order can be entered. Q ? 7. 1 have a next friend petitioning for me. I certify that the next friend is not disqualified by statute and is an adult. 1 declare that the statements above are true to the best of my information, knowledge, and belief. Date et ho ers signature MCL 600.2950, MCL 600.2950a. MCR 3.703 CC 375 (6/04) PETITION FOR PERSONAL PROTECTION ORDER (Domestic Relationship) Personal Protection Order PROOF OF SERVICE Case No. TO PROCESS SERVER: You must serve the personal protection order and file proof of service with the court clerk. If you are unable to complete service, you must return this original and all copies to the court clerk. I CERTIFICATE/ AFFIDAVIT OF SERVICE/ NONSERVICE ? OFFICER CERTIFICATE OR ? AFFIDAVIT OF PROCESS SERVER I certify that I am a sheriff, deputy sheriff, bailiff, appointed Being first duly sworn, I state that I am a legally competent court officer, orattomey for a party [MCR 2.104(A)(2)J, and adultwho is nota party oran officerofa corporate party, and that. (notarization not required) that: (notarization required) ? I served a copy of the personal protection order by: ? personal service ? registered mail, delivery restricted to the respondent (return receipt attached) on: Name of respondent Complete address of service Day, date, time Law enforcement agency Complete address of service Day, date, time ? 1 have personally attempted to serve a copy of the personal protection order on the following respondent and have been unable to complete service. Respondenrs name Complete address of service I declare that the statements above are true to the best of my information, knowledge, and belief. Service fee Miles traveled Mileage fee Total fee $ $ $ Name (type or print) signature Subscribed and sworn to before me on Date My commission expires: Date Notary public, State of Michigan, County of County, Michigan. Signature: Deputy court derk/Notary public ACKNOWLEDGMENT OF SERVICE I acknowledge that I have received a copy of the personal protection order on Day, date, time Signature o respondent MCR 2.105(A) ROBERT C. WILSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION-LAW RHONDA WILSON, : NO. 2008-4396 Defendant : IN CUSTODY VERIFICATION I verify that I am the designated as the Defendant in the above-captioned matter and that the facts and statements contained in the attached: .,ANSWER TO COMPLAINT IN CUSTODY AND PRELIMINARY OBJECTIONS OF PLAINTIFF TO DEFENDANT'S COMPLAINT FOR CUSTODY AND PETITION FOR EXPARTE RELIEF are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Dated: nda R. Wilson, Defendant ROBERT C. WILSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION-LAW RHONDA WILSON, Defendant NO. 2008-4396 IN CUSTODY AFFIDAVIT OF SERVICE The undersigned certifies that a true and correct copy of the within was served this day by U. S. First Class Mail, postage pre-paid, upon the following: Marlin L. Markley, Esquire Attorney for Plaintiff Law Office of Patrick F. Lauer, Jr. L.L.C. 2108 Market Street, Aztec Building Camp Hill, PA 17011A706 Dat 20C?_ I- POF E. D'Alo M Penn Legal Services 1 E. Louther Street Carlisle, PA 17013 (717)243-9400 cy fi.?__ -,yF? At' ,??. ?? ? `a ? Ti ROBERT C. WILSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW RHONDA WILSON, Defendant NO. 08-4396 CIVIL TERM IN RE: PRELIMINARY OBJECTIONS OF DEFENDANT TO PLAINTIFF'S CUSTODY COMPLAINT AND NOW, this 15`h day of September, 2008, upon consideration of the Preliminary Objections filed by Defendant to Plaintiffs Custody Complaint based upon subject matter jurisdiction and venue in the form of forum-non-conveniens, and it being related to the court by the Custody Conciliator that the parties have agreed as to a Michigan school enrollment in this case and, through their counsel, have requested that proceedings in this case be stayed for the time being, no action will be taken at this time on Defendant's preliminary objections and counsel are requested to motion the court at such time as further action on the preliminary objections is desired. BY THE COUNT, ZMarlin L. Markley, Esq. 2108 Market Street Aztec Building Camp Hill, PA 17011-4706 Attorney for Plaintiff Grace D'Alo, Esq. MidPenn Legal Services 401 East Louther Street Carlisle, PA 17013 Attorney for Defendant (20P c'F-s r^a t LICL 9/! -r/o8 /y, Vi= V`A'I SNN3d A1.NNf1C"' ?r<<,?.???W?13 L Z :Z bid S ! J 8OZ MAO . tNC>j--6W ?O JAN ? 6 2009 6 ROBERT C. WILSON IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2008-4396 CIVIL ACTION LAW RHONDA WILSON Defendant IN CUSTODY ORDER AND NOW, this 22°d day of January, 2009, the conciliator, having been advised by Plaintiff's counsel that no information from Defendant's counsel has been forthcoming since the last conciliation conference on September 4, 2008, hereby relinquishes jurisdiction. FOR THE COURT, 1 -,4, ?=,? Dawn S. Sunday, Esquire Custody Conciliator ?r c ' _ f ti y D