HomeMy WebLinkAbout08-6085ANGELA R WILSON,
V5.
: IN THE COURT OF COMMON PLEAS
Plaintiff : OF CUMBERLAND COUNTY, PA
RANDY M. WILSON,
Defendant
NO. 0?- 0?7 tN:I -?e<M
: CIVIL ACTION - LAW
: IN DIVORCE AND CUSTODY
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 Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
ANGELA R. WILSON,
VS.
: IN THE COURT OF COMMON PLEAS
Plaintiff : OF CUMBERLAND COUNTY, PA
RANDY M. WILSON,
Defendant
NO. d ' ?p g G N,` I tff"
: CIVIL ACTION - LAW
IN DIVORCE AND CUSTODY
AVISO PARA DEFENDER Y RECLAMAR DERECHOS
USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las
quejas expuestas en las paginas siguientes, debe tomar acci6n con prontitud. Se le avisa que
si no se defiende, el caso puede proceder sin usted y decreto de divorcio o anulamiento puede
ser emitido en su contra por la Corte. Una decision puede tambien ser emitida en su contra
por cualquier otra queja o compensacion reclamados por el demandante. Usted puede perder
dinero, o propiedades u otros derechos importantes para usted.
Cuando la base para el divorcio es indignidades o rompimiento irreparable del
matrimonio, usted puede solicitar consejo matrimonial. Una lists de consejeros matrimoniales
esta disponible en la oficina del Prothonotary, en la Cumberland County Courthouse, One
Courthouse Square, Carlisle, Pennsylvania, 17013.
SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL
HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO
FINAL DE DIVORCIO O ANULAMIENTO SEA MEITIDO, USTED PUEDE PERDER EL
DERECHO A RECLAMAR CUALQUIERA DE ELLOS.
USTED DEBE LLEVAR ESTE PAREL A UN ABOGADO DE INMEDIATO. SI
NO TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA
INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA
LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities 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.
By the Court:
Date: ?ng?*C?
J.
ANGELA R WILSON,
VS.
Plaintiff
RANDY M. WILSON,
Defendant
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PA
NO. ON', 0? C.w-? /-
: CIVIL ACTION - LAW
IN DIVORCE AND CUSTODY
COMPLAINT UNDER SECTION 3301(c)OF THE DIVORCE CODE
COUNTI
AND NOW, this 8-` day of n 64-06t-r- , 2008, comes the Plaintiff,
Angela R. Wilson, by her attorney, Jane M. Alexander, Esquire, and files this Complaint upon
a cause of action of which the following is a statement.
1. Plaintiff is Angela R Wilson, 35 years of age, who currently resides at 23 East
Allen Street, Mechanicsburg, Borough of Mechanicsburg, Cumberland County, Pennsylvania
17055.
2. Defendant is Randy M. Wilson, 39 years of age who currently resides at 23 East
Allen Street, Mechanicsburg, Borough of Mechanicsburg, Cumberland County, Pennsylvania
17055.
3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months
immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on March 19, 2003 in Cumberland
County, Pennsylvania by a Judge.
5. There were three (3) children born between the parties during their marriage:
Mackenzie Wilson, age 5, born June 3, 2003, Miranda Wilson, age 2, born September 9,
2006, and Arthur Wilson, age 10 months, born November 14, 2007.
6. There have been no prior actions of divorce or for annulment between the parties.
7. The parties have not entered into a written agreement as to alimony, counsel fees,
costs and property division.
8. Plaintiff has been advised that counseling is available and that Plaintiff may have
the right to request that the court require the parties to participate in counseling.
9. While the parties were domiciled within the Commonwealth of Pennsylvania, and
through no fault of Plaintiff the innocent and injured spouse, the Defendant, in violation of
the marriage vows and the laws of the Commonwealth, has offered such indignities to the
person of the Plaintiff as to render his condition intolerable and life burdensome.
WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce
from the bonds of matrimony.
COUNT U
1.0. The allegations of Paragraph one (1) through nine (9) are incorporated herein by
reference and made a part hereof.
11. The marriage is irretrievably broken.
WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce
from the bonds of matrimony.
COUNT III
12. The allegations of Paragraph one (1) through eleven (11) are incorporated herein
by reference and made a part hereof.
13. During the marriage, Plaintiff and Defendant have acquired various items of
marital property, both real and personal, which are subject to equitable distribution under
Chapter 35 of the Divorce Code.
14. Plaintiff and Defendant have been unable to agree as to an equitable division of
said property.
WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all
marital property of whatsoever kind and whosesoever situate and for such further relief as the
Court may deem equitable and just.
COUNT IV
COMPLAINT FOR CUSTODY
15. The Plaintiff seeks primary physical custody and joint legal custody with
reasonable visitation for the defendant of the following child, Mackenzie Wilson, age 5, born
June 3, 2003, Mimda Wilson, age 2, bona September 9, 2006, and Arthur Wilson, age 10
months, born November 14, 2007.
16. The children were born during this marriage.
17. The children are presently in the custody of Plaintiff.
18. The children have resided with the following persons at the following address
since date of birth:
From date of birth to February 29, 2008
From February 29, 2008 to present
with Plaintiff and Defendant at
Rolo Court, Mechanicsburg, PA
17019
with Plaintiff and Defendant at
23 East Allen Street,
Mechanicsburg, PA 17055
19. The relationship to the Plaintiff to the children is that of natural mother.
20. The relationship of the Defendant to the children is that of natural father.
21. The Plaintiff is seeking joint legal custody of the children and primary physical
custody for purpose of visitation schedule.
22. The Plaintiff has not participated as a party or witness, or in any other capacity, in
other lixiviation concerning the custody of these children in this or any other Court.
23. The Plaintiff has no information of a custody proceeding concerning the children
pending in any other court within this Commonwealth.
24. The Plaintiff knows of no other persons, not a party to these proceedings, who has
visitation or custody rights with respect to the children.
25. The best interest and permanent welfare of the children will be best served by
granting the Plaintiff primary physical custody and joint legal custody with reasonable
visitation scheduled to the Defendant.
WHEREFORE, the Plaintiff requests your Honorable Court to grant her primary
physical custody and joint legal custody of the subject children with reasonable rights of
visitation to the Defendant and that the Defendant shall not remove the children from the
jurisdiction of the Pennsylvania Courts.
Respectfully submitted,
A orney for Plaintiff
I . No. 07355
48 South Baltimore Street
Dillsburg, PA 17019
(717) 432-4514
Verification
I verify that the statements made in this Complaint in Divorce and Petition for custody
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 unworn falsification to authorities.
DATE: la 8_ 2008
jn(?t? /?! Z?.) ( /6?
la ilson
COMMONWEALTH OF-PENNSYLVANIA :
COUNTY OF YORK
S.S.
Before me, the undersigned officer, a Notary Public, in and for the said
Commonwealth and County, Personally appeared Angela R Wilson who, being affirmed
according to law, deposes and says that the facts and matters set forth in the foregoing
Complaint are true and correct to the best of her knowledge, information and belief.
Sworn to and subscribed
before me this day
of Oc -nlo. r , 2008.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Narumol Alexander, Notary Public
Dillsburg Boro, York County
My Commission Expires Apr. 7, 2010
Member, Pennsvlvania Association of Notaries
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ANGELA R. WILSON IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
RANDY M. WILSON
DEFENDANT
2008-6085 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Tuesday, October 14, 2008 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, November 13, 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: Is/ Dawn S. Sunday, 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 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
? ? =ZI did S ! 130 OOOZ
33_00--031H
ANGELA R. WILSON, : IN THE COURT OF COMMON PLEAS
Plaintiff : OF CUMBERLAND COUNTY, PA
VS.
RANDY M. WILSON,
Defendant
NO. 0&6035 Civil Term
: CIVIL ACTION -LAW
: IN DIVORCE AND CUSTODY
AFFIDAVIT OF SERVICE
AND NOW, this 71 S ? day of o.Ay ? , 2008 personally
appeared Jane M. Alexander, Esquire who swears according to law, that a true and correct
copy of a COMPLAINT IN DIVORCE was caused to be served by certified mail with return
receipt requested upon the said,
Randy M. Wilson
23 East Allen Street
Mechanicsburg, PA 17055
on October 10, 2008 by leaving the same at the Dillsburg Post Office with postage pre-paid
thereon as evidenced by the mailing receipt and return receipt hereto attached and made a part
hereof.
Sworn and subscribed before
me this a I Sr day of
?c?o6gr- , 2008.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Narumol Alexander, Notary Public
D7lsburg Boro, York County
W Commission Expires Apr. 7, 2010
Attorney I.D. #07355
148 S. Baltimore Street
Dillsburg, PA 17019-0421
(717) 432-4514
Member. Pennsvivanis 4cSnciation of Notaries
4?-
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ANGELA R. WILSON, .
Plaintiff
VS.
RANDY M. WILSON,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
NO. 03-6095 Civil Term
CIVII. ACTION - LAW
IN DIVORCE AND CUSTODY
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NOV 7 2008
ANGELA R. WILSON IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. 2008-6085 CIVIL ACTION LAW
RANDY M. WILSON
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this 0 day of , 2008, upon _ () consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The Mother, Angela R. Wilson, and the Father, Randy M. Wilson, shall have shared legal
custody of Mackenzie Wilson, born June 3, 2003, Miranda Wilson, born September 9, 2006, and
Arthur Wilson, born November 14, 2007. Major decisions concerning the Children including, but not
necessarily limited to, their health, welfare, education, religious training and upbringing shall be made
jointly by the parties after discussion and consultation with a view toward obtaining and following a
harmonious policy in each Child's best interest. Neither party shall impair the other party's rights to
shared legal custody of the Children. Neither party shall attempt to alienate the affections of the
Children from the other party. Each party shall notify the other of any activity or circumstance
concerning the Children 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. §5309, each party shall be entitled to complete and full information from
any doctor, dentist, teacher, professional or authority and to have copies of any reports or information
given to either party as a parent as authorized by statute.
2. The Mother shall have primary physical custody of the Children.
3. The Father shall have partial physical custody of the Children every week on Mondays,
Wednesdays and Thursdays from 8:30 a.m. until 5:15 p.m. and on Saturdays from 8:30 a.m. until 7:00
p.m. The Father shall pick up Mackenzie at her bus stop after school during the Father's periods of
custody. The Father's partial custody schedule shall begin on Saturday, November 15, 2008.
4. The parties shall share having custody of the Children on Thanksgiving Day in 2008, with
the Father having custody from 8:30 a.m. until 2:00 p.m. and the Mother having custody beginning at
2:00 p.m.
5. Unless otherwise agreed, the parent receiving custody of the Children shall be responsible to
provide transportation for the exchange of custody.
6. Neither party shall do or say anything which may estrange the Children from the other
parent, injure the opinion of the Children as to the other parent, or hamper the free and natural
development of the Children's love and respect for the other parent. Both parties shall ensure that third
parties having contact with the Children comply with this provision.
7. The Father shall not consume alcohol during his periods of custody.
8. The parties and counsel shall attend a follow-up custody conciliation conference, in the
office of the conciliator, Dawn S. Sunday, on Monday, December 1, 2008 at 1:00 p.m. for the purpose
of reviewing the custodial arrangements and establishing an ongoing schedule.
9. This Order is entered pursuant to an agreement of the parties at a custody conciliation
conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
BY THE COURT
(t- /
J.
cc: J Jane M. Alexander, Esquire - Counsel for Mother
.Marcus A. McKnight, III, Esquire - Counsel for Father
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ANGELA R. WILSON
Plaintiff
VS.
RANDY M. WILSON
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:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
2008-6085 CIVIL ACTION LAW
IN CUSTODY
1. The pertinent information concerning the Children who are the subjects of this litigation is as
follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Mackenzie Wilson
Miranda Wilson
Arthur Wilson
June 3, 2003
September 9, 2006
November 14, 2007
Mother
Mother
Mother
2. A custody conciliation conference was held on November 13, 2008, with the following
individuals in attendance: the Mother, Angela R. Wilson, with her counsel, Jane M. Alexander,
Esquire, and the Father, Randy M. Wilson, with his counsel, Marcus A. McKnight, III, Esquire.
3. The parties agreed to entry of an Order in the form as attached pending a follow-up custody
conciliation conference scheduled in the Order.
rl
Date T Dawn S. Sunday, Esquire
Custody Conciliator
A.
ANGELA R. WILSON IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. 2008-6085 CIVIL ACTION LAW
RANDY M. WILSON
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this '2?L. day of ?^ t , 2008, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The prior Order of this Court dated November 17, 2008 is vacated and replaced with this
Order.
2. The Mother, Angela R. Wilson, and the Father, Randy M. Wilson, shall have shared legal
custody of Mackenzie Wilson, born June 3, 2003, Miranda Wilson, born September 9, 2006, and
Arthur Wilson, born November 14, 2007. Major decisions concerning the Children including, but not
necessarily limited to, their health, welfare, education, religious training and upbringing shall be made
jointly by the parties after discussion and consultation with a view toward obtaining and following a
harmonious policy in each Child's best interest. Neither party shall impair the other party's rights to
shared legal custody of the Children. Neither party shall attempt to alienate the affections of the
Children from the other party. Each party shall notify the other of any activity or circumstance
concerning the Children 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. §5309, each party shall be entitled to complete and full information from
any doctor, dentist, teacher, professional or authority and to have copies of any reports or information
given to either party as a parent as authorized by statute.
3. The Mother shall have primary physical custody of the Children.
4. The Father shall have partial physical custody of the Children on alternating weekends,
beginning December 12, 2008, from Friday at 6:00 p.m. through Sunday at 6:00 p.m. and, during
weeks following the Father's weekend periods of custody, on Thursday from 8:30 a.m. until 5:15 p.m.
The Father shall pick up Mackenzie at her bus stop after school during the Father's periods of custody
on alternating Thursdays. Until such time as the Father's alternating weekend periods of custody
begin, the Father shall have custody of the Children on Wednesday, December 3 and Thursday,
December 4, 2008 from 8:30 a.m. until 5:15 p.m.
.A.
5. The parties shall share or alternate having custody of the Children on holidays as follows:
A. Christmas: In 2008, the Father shall have custody of the Children on Christmas Eve
from 8:30 a.m. until 8:00 p.m, and the Mother shall have custody from Christmas Eve at 8:00 p.m.
through Christmas Day. In future years, the parties shall share having custody of the Children over the
Christmas holiday as arranged by agreement.
B. Thanks giving/Easter: In every year, the Father shall have custody of the Children
on Thanksgiving Day and Easter from 8:30 a.m. until 2:00 p.m. and the Mother shall have custody for
the holiday beginning at 2:00 p.m.
C. Memorial Day/July Fourth/Labor Day: In odd-numbered years, the Father shall
have custody of the Children on Memorial Day and Labor Day and the Mother shall have custody on
July Fourth. In even-numbered years, the Mother shall have custody of the Children for Memorial Day
and Labor Day and the Father shall have custody on July Fourth. Unless otherwise agreed, the period
of custody on the holiday shall run from 8:30 a.m. until 7:30 p.m., with an extension of time on July
Fourth for the fireworks.
D. Mother's Day./Father's Day: In every year, the Mother shall have custody of the
Children on Mother's Day and the Father shall have custody on Father's Day from 8:30 a.m. until 7:30
p.m.
E. The holiday custody schedule shall supersede and take precedence over the regular
custody schedule and the vacation schedule.
6. Each party shall be entitled to have custody of the Children for one (1) full week each
summer for vacation upon providing at least thirty (30) days advance notice to the other parent, which
notice shall be provided on or before June 10 of each year. The parent providing notice first shall be
entitled to preference on his or her selection of vacation dates. Each party shall schedule periods of
custody to include his or her regular periods of custody without interrupting the other party's periods
of custody as much as possible. In the event either party intends to remove the Children from his or
her residence for a vacation period of custody for an overnight period or longer, that parent shall
provide the other parent with advance notice of the address and telephone number where the Children
can be contacted.
7. Unless otherwise agreed, the parent receiving custody of the Children shall be responsible to
provide transportation for the exchange of custody.
8. Neither party shall do or say anything which may estrange the Children from the other
parent, injure the opinion of the Children as to the other parent, or hamper the free and natural
development of the Children's love and respect for the other parent. Both parties shall ensure that third
parties having contact with the Children comply with this provision.
9. The Father shall not consume alcohol during his periods of custody.
10. Within ninety (90) days of the date of this Order, counsel for either party may contact the
conciliator to schedule an additional custody conciliation conference, if necessary due to conflicts in
the custody arrangements caused by the Father obtaining a new employment schedule.
11. This Order is entered pursuant to an agreement of the parties at a custody conciliation
conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
cc:
Jae M. Alexander, Esquire - Counsel for Mother
j'Marcus A. McKnight, III, Esquire - Counsel for Father
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DEC 0 5 2093
ANGELA R. WILSON
Plaintiff
vs.
RANDY M. WILSON
Defendant
Prior Judge: Edgar B. Bayley
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
2008-6085 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the subjects of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Mackenzie Wilson June 3, 2003 Mother
Miranda Wilson September 9, 2006 Mother
Arthur Wilson November 14, 2007 Mother
2. A custody conciliation conference was held on December 1, 2008, with the following
individuals in attendance: the Mother, Angela R. Wilson, with her counsel, Jane M. Alexander,
Esquire, and the Father, Randy M. Wilson, with his counsel, Marcus A. McKnight, III, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
.--Cpo
Date Dawn S. Sunday, Esquire
Custody Conciliator
9-
ANGELA R. WILSON IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA2 "
l-
V.
2008-6085 CIVIL ACTION LAW
RANDY M. WILSON
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Tuesday, February 19, 2013 upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, March 13, 2013 2:00 PM
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/ Dawm S. Sunday, Esq.jv
Custody Conciliator il
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 1.7013
Telephone (717) 249-3166
a
10
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PST l
ANGELA R. WILSON IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. 2008-6085 CIVIL ACTION LAW
RANDY M. WILSON
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this 2 h day of M 4,1A , 2013, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The prior Order of this Court dated December 8, 2008 shall continue in effect as modified
by this Order.
2. The Father shall have physical custody of the Children on alternating weekends, beginning
March 14, 2013, from Thursday at 6:00 p.m. through the following Monday at 9:00 a.m. if it is a
school day or at 6:00 p.m. if there is no school. Prior to exchanging custody of Arthur and Miranda at
9:00 a.m. on Monday,the Father shall transport Mackenzie directly to school.
3. The parties shall exchange custody of the Children at the Giant in Dillsburg unless the
parties agree to a different location.
4. Each parent shall be entitled to have periods of vacation custody with the Children for two
weeks each year, (which may be scheduled consecutively or nonconsecutively) upon providing at least
45 days advance notice to the other parent. The parent providing notice first shall be entitled to
preference on his or her selection of vacation days. In the event either parent intends to remove the
Children from the local area for vacation, that parent shall provide the other parent with the address
and telephone number where the Children can be contacted in advance.
5. After following the schedule set forth in this Order for at least a period of three months, the
parties shall cooperate in continuing discussions to consider the Father's request for further expansion
of his time with the Children.
6. Neither party shall do or say anything which may estrange the Children from the other
parent, injure the opinion of the Children as to the other parent, or hamper the free and natural
development of the Children's love and respect for the other parent. Both parties shall ensure that third
parties having contact with the Children comply with this provision.
7. Neither parent shall permanently relocate if the relocation would necessitate a change in the
custody schedule, would result in a change of school for the Children or would exceed a fifty(50)mile
radius without a minimum notice of ninety (90)days to the other parent. The ninety(90)day notice is
designed to afford the parents an opportunity to renegotiate the custodial arrangements or to have the
matter resolved through the legal process.
8. This Order is entered pursuant to an agreement of the parties at a custody conciliation
conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
BY THE COURT,
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cc: ✓Lam D. Truong Esquire—Counsel for Mother
✓ Marcus A. McKnight III Esquire—Counsel for Father
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ANGELA R. WILSON IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. 2008-6085 CIVIL ACTION LAW
RANDY M. WILSON
Defendant IN CUSTODY
Prior Judge: Edgar B. Bayley
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 subjects of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Mackenzie Wilson June 3, 2003 Mother
Miranda Wilson September 9, 2006 Mother
Arthur Wilson November 14, 2007 Mother
2. A custody conciliation conference was held on March 13, 2013, with the following
individuals in attendance: the Mother, Angela R. Wilson, with her counsel, Lam D. Truong Esquire,
and the Father, Randy M. Wilson, with his counsel, Marcus A. McKnight III Esquire.
3. The parties agreed to entry of an Order in the form as attached.
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Date Dawn S. Sunday, Esquire
Custody Conciliator