HomeMy WebLinkAbout01-6599
?osr uA 3 S?,,, ?, `? IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
Ka-Q1 /? n1 it C/2AN Fa2D .
CIVIL ACTION IN CUSTODY
NO.(? (-?pv /C/
NOTICE TO DEFEND n c? 7
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TO THE RESPONDENTS NAMED HEREIN: G'
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You have been sued in Court. If you wish to defend against the claim&-4i jortWin tt?
following pages, you must take action within twenty (20) days after this Petition and No4je agser4d, 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 Petition or for any other claim or relief requested by the Plaintiffs. 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 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
Two Liberty Avenue
Carlisle, PA 17013
(717)249-3166
Le han demandado a usted enla corte. Si usted quiere defenderse de estas demandas expuestas en las
paginas siguientes, usted tiene viente (20) dial de plazo al partie de la fecha de la demanda y la
notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte
en forma escrita sus defensas o sus objectones a las demandas en contra de su persona. Sea avisado que si
usted no se defiende, ]as corte tomara medidas y puede entrar una orden contra usted sin previo aviso o
notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder
dinero o sus propiedades o otros derechos importantes para usted.
JOSNN/3 /3 S/,J6c2 : IN THE COURT OF COMMON PLEAS OF
VS. : CUMBERLAND COUNTY, PENNSYLVANIA
xeR? A otj C egW roQD
CIVIL ACTION IN CUSTODY
NO. 59 / -
--D
Mr-
COM PLAINT IN CUSTODY
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l• The plaintiffis _
JoSNUA B S„JcC,e , residing at 907 3 Ches+rr ?d cv `
?,votR PA
17-v 2S - V
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2. The defendant is KEe? ArN ?4qr r FoRp `c
residing e#/7 S4reek CQ,,p laid
PA
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1
4-C>1 1
3. Plaintiff seeks custody) (partial custody), (visitation) of the following child(ren):
NAME PRESENT ADDRESS
AGE
emy z3 S,..r6im ?l7 S J l `? S+
AM9 N Itt_ PA /BMOni{+QS
The child(ren) was was not) born out of wedlock.
The child(ren) is presently in the custody of K&,e, A.,,j CeAW4-0 D who resides at
*A S4r
Lf--PA )7611
During the past five years, the child(ren) has resided with the following persons at the following
addresses:
LIST OF PERSONS
JOSNuA a SiNC.?,Q
"Ne) ANN CAAw.Fo2p
$o? N Q Rov,.
ADDRESSES
9,1713 Che5>-dr e0j F,,,,A
9d73 C?rS?fR Jed e.JoLA
SAS" SGRSEMAr-? (Zd ?6W L,.,y?
DATES
1210 /10l
f OD - It 0 t
- l2 00
9/99
The mother of the child(ren) is /KE,e /IN r'* A, I Q O
currently residing at
A S. CAMP ?) 4e PA / -7-611
She is single (married)(divorced).
The father of the child(ren) is Jos oaA g S', ,??t e
currently residing at
90 3 CAes>er Rol CAJOtA
PA /-rozg
He is (single)(married) ivorced .
4. The relationship of the Plaintiff to the child(ren) is: rA714E,Q
. The Plaintiff currently
resides with :
NAME RELATIONSHIP
5. The relationship of the Defendant to the child(ren) is: Nb7 NE2
. The Defendant
currently resides with
NAME
RELATIONSHIP
KATNL eEA/ Pe PPE2MAN
DAY i D PeP,-C& 01.4 A
Jo,4-j S C.QAr..1FOQ A
CcCel4L PozemSki
21AQISSA P62-FMsK,
MOT l-I t R
5r: P - FASNCq
9.eo7HEQ
5-re P - S; 3TG P,
STeP - SISTC2
6. Plaintiff (has) has not participated as a party or witness, or in another capacity, in other litigation
concerning the custody of this minor child(ren) in this or another court. (if so)The court, term and
number, and its relationship to this action is:
Plaintiff (has) has no information of a custody proceeding concerning the child(ren)
pending in a court of this Commonwealth. (if so)The court, term and number and its relationship
to this action is:
1
M
Plaintiff (knows)(does not know) of a person not a party to the proceedings who has
7.
8.
physical custody of the child or claims to have custody or visitation rights with respect to the child.
The name and address of such a person
The best interest and permanent welfare of the child will be served by granting the relief requested
because: = F?e? He s ekf-c f
rA t_
c? o eC o? ; c 1 -? e+13
abase wl7;le 1n cart of Kc-ei ANN CaAwrroao
Each parent whose parental rights to the child have not been terminated and the person who has
physical custody of the child have been named as parties to this action. All other persons, named
below, who are known to have or claim a right to custody or visitation of the child will be given
notice of the pendency of this action and the right to intervene:
NAME
ADDRESS
BASIS OF CLAIM
O
WHEREFORE, Plaintiff requests this court to grant custody (temporary custody) (visitation) of the
child(ren) to the Plaintiff.
Respectfully submitted,
2& A/o? of
Date
JosN?/? 3
JOSHUA B. SINGER IN THE COURT OF COMMON PLEAS OF
PLAINTIFF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
• 01-6599 CIVIL ACTION LAW
KERI ANN CRAWFORD
DEFENDANT IN CUSTODY
AND NOW, Monday, November 26 2001 , 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, December 06, 2001 at 8:30 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: /s/ Dawn S, Sunday, . A)?
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
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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Adult affidavit of service
JOSHUA B. SINGER
Plaintiff
V.
KERI ANN CRAWFORD
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 01-6599 Civil Action Law
IN CUSTODY
AFFIDAVIT OF SERVICE
I, the undersigned, being duly affirmed according to law,
deposes and says:
1. I am over 18 years of age.
2. I am not related to either party to this action.
3. I served a true and correct copy of the Custody Complaint
properly endorsed with a Notice to Plead upon the
Defendant, Keri Ann Crawford, on November 29, 2001 by the
manner checked below:
(X) a. Handing a copy to Defendant at her residence
located at 25 N. 17t" Street, Camp Hill, PA
17011;
( ) b. Handing a copy to
the adult individual in charge of the
Defendant's residence located at
or
( ) c
Handing a copy to the Defendant at her place
of employment or other place located at
- 1 -
Printed Name
Adult affidavit of service
sworn to and subscribed before me
a Notary Public in and for
County, Pennsylvania
this day of Z2&1 2001.
ju4A a, A)
NOTARY PUBLIC
My commission expires:
Notarial Seal f
Ecamp orah L. Donley, Notary Public
Hill Wro, Cumberland County
missionExpires Sept. 23, 2003
Member, Pennsylvania Association of Notaries
- 2 -
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?Cti { ?
10. Neither party shall do or say anything which may estrange the Child from the other parent,
injure the opinion of the Child as to the other parent, or hamper the free and natural development of the
Child's love and respect for the other parent. Both parties shall ensure that third parties having contact
with the Child comply with this provision.
11. After following the custody schedule set forth in this Order for a period of at least three
months, counsel for either party may contact the Conciliator to schedule an additional Custody
Conciliation Conference to review the custody arrangements if necessary.
12. 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: Diane G. Radcliff, Esquire - Counsel for Father n„, ,L ??-<yoi
Jason McNicholl and Teri Henning, Esquire - Counsel for Mother G ?7
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JOSHUA B. SINGER,
Plaintiff
VS.
KERI ANN CRAWFORD,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-6599 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:
The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME DATE OF BIRTH
Clay B. Singer May 9, 2000
CURRENTLY IN CUSTODY OF
Mother
2. A Conciliation Conference was held on December 6, 2001, with the following individuals in
attendance. The Father, Joshua B. Singer, with his counsel, Diane Radcliff, Esquire, and the Mother,
Keri Ann Crawford, with her counsel, Jason McNicholl and Teri Henning, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
L /O, 40ol
Date Dawn S. Sunday, Esquire
Custody Conciliator
JOSHUA B. SINGER,
Plaintiff
VS.
KERI ANN CRAWFORD,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-6599
CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this /A(* day of 200 / ,
upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The parties shall participate in a course of parenting classes, with the provider to be selected
by agreement of the parties and counsel. The parties shall select and contact the agreed upon provider
within 15 days of the date of the Custody Conciliation Conference to schedule the initial sessions. The
parties shall also obtain information concerning the cost and availability of joint counseling for the
purpose of developing sufficient communications and cooperation to enable the parties to effectively
co-parent their Child.
2. The Father, Joshua B. Singer, and the Mother, Keri Ann Crawford, shall have shared legal
custody of Clay B. Singer, born May 9, 2000. Each parent shall have an equal right, to be exercised
jointly with the other parent, to make all major non-emergency decisions affecting the Child's general
well-being including, but not limited to, all decisions regarding his health, education and religion.
3. The parties shall share having physical custody of the Child on an alternating weekly basis,
with the exchange of custody to take place every Sunday at 5:00 p.m. The non-custodial parent shall
have a period of mid-week custody from Wednesday at 5:00 p.m. through the following Thursday
morning before work when that party shall return the Child to the caregiver. The shared custody
schedule shall begin with the Father having custody of the Child from Friday, December 7 at 3:00 p.m.
through Sunday, December 9, 2001 at 5:00 p.m. and the Mother beginning the first weekly period of
custody on December 9.
4. The Mother shall be responsible to make arrangements for the Child's care during the day
times on Mondays, Wednesdays and Fridays and the Father shall be responsible to make arrangements
for the Child's care during daytimes on Tuesdays and Thursdays. The parties agree that the Mother
may provide the care for the Child during the day on Tuesdays and Thursdays until her employment
begins. The Mother shall provide as much notice as possible to the Father of the date on which she
begins work. The parties acknowledge that the Mother has indicated her intention to enroll the Child
in the Chester Brook Academy Pre-School and the Father has indicated his intention to make
arrangements with his sister to provide care.
5. The parties shall share or alternate having custody of the Child on holidays as follows:
A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which
shall run from Christmas Eve at 2:00 p.m. through Christmas Day at 2:00 p.m. and
Segment B, which shall run from Christmas Day at 2:00 p.m. through December 26 at
2:00 p.m. The Mother shall have custody of the Child during Segment A in odd
numbered years and during Segment B in even numbered years. The Father shall have
custody of the Child during Segment A in even numbered years and during Segment B
in odd numbered years.
B. THAN The parent who has custody of the Child under the
regular custody schedule shall retain custody of the Child on Thanksgiving Day and
Easter Sunday until 2:00 p.m. and the other party shall have custody of the Child for the
remainder of the holiday beginning at 2:00 p.m.
C. MEMORIAL DAY/LABOR DAY: In every year, each party shall have custody of
the Child for either Memorial Day or Labor Day, with the specific schedule to be
arranged by agreement of the parties.
D. JULY 4TH: The Mother shall have custody of the Child over the July 0 holiday in
even numbered years and the Father shall have custody in odd numbered years. The
specific times for exchanges of custody shall be arranged by agreement of the parties.
E. MOTHER'S DAY/FATHER'S DAY: The Mother shall have custody of the Child
every year on Mother's Day and the Father shall have custody of the Child every year
on Father's Day from 9:00 a.m. until 5:00 p.m.
F. HALLOWEEN TRICK-OR-TREAT NIGHT: Each party shall be entitled to
have custody of the Child for a trick-or-treat night each year with the specific
arrangements to be made by agreement of the parties.
G. The holiday custody schedule shall supersede and take precedence over the regular
custody schedule.
6. Each party shall be entitled to have custody of the Child for one uninterrupted week each
year (during the summer school break after the Child starts school) upon providing at least 30 days
advance notice to the other party. All periods of custody under this provision shall be scheduled
during each party's regular alternating custody week, unless otherwise agreed.
7. In the event either party intends to remove the Child from his or her residence for an
overnight period or longer, that party shall provide the other party with advance notice of the address
and telephone number where the Child can be contacted.
8. The non-custodial parent shall be entitled to have reasonable liberal telephone contact with
the Child.
9. The party receiving custody shall be responsible to provide transportation for the exchange
of custody, unless a party is returning the Child to daycare, pre-school or a babysitter.
JOSHUA B. SINGER
Plaintiff
V.
KERI ANN CRAWFORD
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 01-6599 Civil Action Law
IN CUSTODY
ORDER OF COURT
AND NOW, this lq* day of , 2002, upon consideration
of the within Stipulation, IT IS HEREBY ORDERED AND DECREED that:
1. The December 14, 2001 Custody order entered in the above captioned
case shall be modified to include the following provision:
"Neither party may relocate with, or change the residence
of, the child outside of Cumberland County Pennsylvania
or York County, Pennsylvania without prior approval of
the Court."
2. In all other respects this Court's custody order dated December 14,
2001 is reaffirmed and shall continue in full force and effect
until further order of this Court.
3. This Order shall not be deemed to prevent either party from seeking
a modification of the December 14, 2001 Custody Order.
BY TU? COURT
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Distribution to:
Diane G. Radcliff, Esquire Lucy Johnston-Walsh, Esquire
3448 Trindle Road Megan Malone, Student Intern
Camp Hill, PA 17011 Family Law Clinic
Attorney for Plaintiff 45 North Pitt Street
Carlisle, PA 17013
Attorney for Defendant
- 2 -
nni10ino rPT nu•d6 FAX 2406460
CUMB/COUNTY COURTS
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TRANSMISSION OK
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CONNECTION TEL 99750697
CONNECTION ID
ST. TIME 07/19 09:44
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RESULT OK
JOSHUA B. SINGER
Plaintiff
v,
KERI ANN CRAWFORD
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 01-6599 Civil Action Taw
IN CUSTODY
ORDER OF COURT
AND NOW, this It- day of 2002, upon consideration
of the within Stipulation, IT IS HEREBY ORDERED AND DECREED that:
1- The December 14, 2001 Custody order entered in the above captioned
case shall be modified to include the following provision:
"Neither party may relocate with, or change the residence
of, the child outside of Cumberland County Pennsylvania
or York County, Pennsylvania without prior approval of
the Court.,,
2. In all other respects this Court's Custody Order dated December 14,
2001 is reaffirmed and shall continue in full force and effect
until further order of this Court.
3. This Order shall not be deemed to prevent either party from seeking
JOSHUA B. SINGER IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
01-6599 CIVIL ACTION LAW
KERI ANN CRAWFORD
DEFENDANT IN CUSTODY
AND NOW, Monday, July 22, 2002 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, August 15, 2002
at 10:00 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 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: /s/ Dam S, Sunda.y. 17
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.
must made least 72 hours prior to any hearing
scheduled conference or or hearing or business before the court. You must attend the
.
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
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
All arrangements
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Acceptance of Service by Atty.
JOSHUA B. SINGER
Plaintiff
v.
KERI ANN CRAWFORD
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 01-6599 Civil Action Law
IN CUSTODY
ACCEPTANCE OF SERVICE
It the undersigned attorney for the Defendant in the above
captioned action, being duly authorized by said Defendant, hereby
accept service of the Petition for Modification of Partial custody
or Visitation Order filed in the above captioned matter on July 18,
2002.
Date : -729
Lucy J ston-Walsh, Esquire
Attorney for the Defendant
MegaYMalone, Student Intern
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JOSHUA B. SINGER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
KERI ANN CRAWFORD,
Defendant
PRIOR JUDGE: Edward E. Guido
NO. 01-6599 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Clay B. Singer May 9, 2000 Father
2. A Conciliation Conference was held on August 15, 2002, with the following individuals in
attendance. The Father, Joshua B. Singer, with his counsel, Diane G. Radcliff, Esquire, and the
Mother's counsel, Jennifer Heverly and Lucy Johnston-Walsh, Esquire. The Mother, Keri Ann
Crawford, currently resides in Florida and participated in the Conference by telephone.
3. The parties agreed to entry of an Order in the form as attached.
Date =-?t` aoco, 5
1-
Dawn S. Sunday, Esquire
Custody Conciliator
N(N 0 1 2002L/
JOSHUA B. SINGER,
Plaintiff
VS.
KERI ANN CRAWFORD,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-6599
CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this y day of 13 , 2002, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The prior Order of this Court dated August 24, 2002, is vacated and replaced with this
Order.
2. The Father, Joshua B. Singer, and the Mother, Keri Ann Crawford, shall have shared legal
custody of Clay B. Singer, born May 9, 2000. Each parent shall have an equal right, to be exercised
jointly with the other parent, to make all major non-emergency decisions affecting the Child's general
well-being including, but not limited to, all decisions regarding his health, education and religion.
Pursuant to the terms of this paragraph each parent shall be entitled to all records and information
pertaining to the Child including, but not limited to, school and medical records and information.
3. Pending further Order of Court or agreement of the parties, the Father shall have primary
physical custody of the Child and the Mother shall have partial custody for 3 weeks out of every 8
week cycle, 1 week of which shall take place at the maternal grandmother's residence in central
Pennsylvania. The Mother shall have custody of the Child from Friday, October 25, 2002 at 5:00 p.m.
through Friday, November 1, 2002, when the Father shall pick up the Child at the maternal
grandmother's home after work. During the foregoing week, the Father shall have a period of custody
with the Child on Thursday, October 31 from 4:30 p.m. until 8:00 p.m. The Mother's first 3 week
period of custody shall begin when the Father transports the Child to the Mother's residence in Florida
in November, the specific date of which the Father shall notify the Mother at least 2 weeks in advance.
Beginning on that date, the Mother shall have custody of the Child in Florida for 2 weeks (14 days)
and shall transport the Child to the maternal grandmother's residence in Pennsylvania for the
additional 1 week period. During the Mother's week of custody in Pennsylvania in November or
December, 2002, the Father shall have custody of the Child from 4:30 p.m. until 8:00 p.m. on the I't
and 4th evenings of the week. Thereafter, during the Mother's weeks in Pennsylvania, the Father shall
have a period of custody from 4:30 p.m. until 8:00 p.m. in the mid-week and on the evening before the
Mother leaves to take the Child to Florida for her remaining 2 weeks.
4. The Mother shall have custody of the Child over the Thanksgiving holiday in even
numbered years and over the Christmas holiday in odd numbered years. The Father shall have custody
of the Child over the Thanksgiving holiday in odd numbered years and over the Christmas holiday in
even numbered years. The parties shall adjust the ongoing 8 week cycle, if necessary, to ensure that
the Mother's holiday periods of custody fall during her regular custodial periods.
5. The parties agree that when the Child begins kindergarten, he shall attend school in
Pennsylvania.
6. Neither party may relocate with, or change the primary residence of the Child, outside of
Cumberland County, Pennsylvania or York County, Pennsylvania without prior approval of the Court.
7. After completing 2 full 8 week cycles under the custody schedule set forth in this Order,
counsel for either party may contact the Conciliator to schedule an additional Custody Conciliation
Conference, if necessary, to review the arrangements.
8. Neither party shall do or say anything which may estrange the Child from the other parent,
injure the opinion of the Child as to the other parent, or hamper the free and natural development of the
Child's love and respect for the other parent. Both parties shall ensure that third parties having contact
with the Child comply with this provision.
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 CO T,
Edward E. Guido, J.
cc: Diane G. Radcliff, Esquire - Counsel for Father -
Douglas Miltenberger and Lucy Johnston-Walsh, Esquire - Counsel for Mother
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JOSHUA B SINGER,
Plaintiff
vs.
KERI ANN CRA WFORD
Defendant
PRIOR JUDGE: Edward E. Guido
IN THE COURT OF MON P
CUMBERLAND CONYCOMPE LEAS OF
NNSYLVANIA
NO. 01-6599 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMM
.Rl' REPORT
PROCED ACCORDANCE
URE 915.3 8, WITH
undersigned CUMBERLAND COUNTY
Custody Conciliator RULE
1 The pertinent info submits the following report:
Ong the Child who is the subject of this litigation is as
AAME DATE OF
BIRTH
Clay B. Singer MaY 9, 2000 CURRENTLY IN CUSTODY OF
2. A Conciliation Conference was held on Father
attendance. The Father, Joshua
Mother, Keri B. Singer, October 25, 2002, with the followin
Ann
Esquire.
Crawford, with her ounsel with his counsel Diane g individuals in
, Dou las G• Radcliff, Es ire, and the
g Miltenberg qu
er and Lucy Johnston-
3• The parties agreed to entry Walsh,
of an order in the form as attached
Date a-
-dlz
Dawn S. Sunday, Esquire
Custody Conciliator
JOSHUA B. SINGER,
Plaintiff
VS.
KERI ANN CRAWFORD
Defendant
PRIOR JUDGE: Edward E. Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-6599
CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this a y day of 2003, upon
consideration of the attached Custody Conciliation eport, it is ordered and directed as follows:
Lo 9:1.5
1. A Hearing is scheduled in Courtroom No.
of he Cu berlan ount
Court House on the &I I S-t day of il
Y .1?1$QC. , 2003, at which time testimony will
be taken. For purposes of the Hearing, the Father shall be deemed to be the moving party and shall
proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel
a memorandum setting forth each party's position on custody, a list of witnesses who are expected to
testify at the Hearing, and a summary of the anticipated testimony of each witness. These memoranda
shall be filed at least ten days prior to the Hearing date.
2. Pending further Order of Court or agreement of the parties, the parties shall have shared
legal custody of Clay B. Singer, born May 9, 2000, the Father shall have primary physical custody, and
the Mother shall have partial physical custody of the Child. The Mother shall have continuous custody
of the Child through February 6, 2003 between 5:00 pm and 6:00 pin, when the Father shall pick up
the Child. Prior to February 6, the Father shall have an interim period of custody on one weekday
evening from between 5:00 and 6:00 pm until 8:00 pm, with the specific date to be arranged by
agreement of the parties. Thereafter, beginning on February 14, 2003, the Mother shall have custody
of the Child on alternating weekends from Friday between 5:00 and 6:00 pm through Sunday at 8:00
pm. During the interim weekends, the Mother shall have custody of the Child on Sunday from 1:00
pm until 8:00 pm with the exception that the Father shall have the option of preempting the Mother's
Sunday afternoon / evening period of custody two times pending the Hearing upon providing at least
one week advance notice to the Mother. In the event the Father exercises his right to custody on
Sunday, arrangements shall be made for a substitute period of custody for the Mother on either the
Wednesday immediately preceding or following the Sunday from between 5:00 and 6:00 pm through
8:00 pm. The Mother shall have custody of the Child on Easter Sunday from 1:00 pm until 8:00 pm.
I The party receiving custody shall be responsible to provide transportation for the exchange
of custody unless otherwise agreed.
4. The prior Order of this Court dated November 4, 2002 is vacated and replaced with this
Order.
cc: Diane G. Radcliff, Esquire, Counsel for Father
LO /C Y C? 3
Douglas Miltenberger & Lucy Johnston-Walsh, Esquire, Counsel for Mother
Edward E.Guido J.
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1 / ?. 'mss
JOSHUA B. SINGER,
Plaintiff
VS.
KERI ANN CRAWFORD
Defendant
PRIOR JUDGE: Edward E.Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-6599 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Clay B. Singer May 9, 2000 Father
2. A Conciliation Conference was held on January 23, 2003, with the following individuals in
attendance: The Father, Joshua B. Singer, with his counsel, Diane G. Radcliff, Esquire, and the
Mother, Keri Ann Crawford, with her counsel, Douglas Miltenberger, and Lucy Johnston-Walsh,
Esquire.
3. This Court previously entered an Order on November 4, 2002 following an agreement at a
conciliation conference under which the Father has primary physical custody of the Child and the
Mother, who had moved to Florida, had partial custody during three weeks out of every eight week
cycle, one week of which was to be spent at the maternal grandmother's residence in Pennsylvania.
The Mother has relocated back to Pennsylvania where she currently resides with her finance' in Camp
Hill. The Father resides in York Haven. The Mother originally moved to Florida with her finance' in
March 2002, and during a telephone conciliation conference, indicated that she had enrolled in classes
and was living temporarily with friends.
Subsequently, the Mother deferred her educational plans to work in her finance's family business in
Florida. In December 2002, the Mother moved back to Pennsylvania where she is employed and rents
an apartment.
The Father requested a review of the custody arrangements as permitted in the prior Order.
Each party raised many concerns regarding the other parent's ability to properly care for the Child. It
appears that both counseling for both parenting skills and development of a co-parenting relationship
would be beneficial to the parties. The parties agreed to investigate the availability of both types of
counseling, although they have limited financial resources.
4. The parties were not able to reach an agreement as to ongoing custody arrangements for the
Child and it will be necessary to schedule a Hearing. As the parties raised many issues concerning the
Child's safety, it is requested that the hearing be expedited if possible.
5. The Mother's position on custody is as follows: The Mother believes that it would be in the
best interest of the Child to share custody on an alternating weekly basis. As the Mother is currently in
the last two weeks of her three week period of custody under the existing Order, she does not believe
that it would be good for the Child to then be transferred to the Father's primary custody pending the
Hearing. The Mother does not feel it is appropriate for the Father to have an evening period of custody
during her two week period as, according to her the Father did not allow her to see the Child for
several weeks when she had returned to Pennsylvania. The Mother objects to the babysitter which the
Father employs while he is at work and stated that she was unwilling to take the Child to the babysitter
if she were to have overnight weekday periods of custody. The Mother expressed many concerns
about the Father's ability to care for the Child including concerns regarding the Child's diet, toilet
training, and injuries from what the Mother believes to have been pet attacks. The Mother indicated
that she contacted the police in Florida to look at a rash on the Child's shoulder after the Father
transported the Child to her residence for her period of custody.
6. The Father's position on the custody is as follows: The Father believes that it would be in the
Child's best interest for him to have primary custody as he did dining five weeks of the eight week
cycle while the Mother was living in Florida. The Father stated that the Mother has been very unstable
since last March and has shown little concern for the Child's well being. According to the Father, the
Mother did not even advise him that she was in Pennsylvania until Christmas Eve and has only
contacted him two times, regarding the Child since she has been in Pennsylvania. According to the
Father, when the Child returns from visiting the Mother, the Child exhibits defiant behavior and tells
the Father that the Mother fiance' hits him. The Father expressed concerns regarding the Child's toilet
training and eating habits. The Father indicated that he may be agreeable to increasing the Mother's
periods of custody with the Child after she has demonstrated a more stable lifestyle. The Father
proposed that the Mother have periods of custody with the Child on alternating weekends and one
evening per week.
7. It was very difficult at the conference to sort through the accusations, multiple concerns and
contradictions in an effort to establish temporary arrangements pending the hearing. However based
on representations made by the parties during this conference and prior conferences, the conciliator
recommends an Order in the form as attached scheduling the Hearing and establishing interim custody
arrangements. It should be noted that the Mother strongly objects to the interim recommendations and
may request further review by the Court pending the Hearing. The: Father also objected to portions of
the temporary arrangements, particularly the Sunday evening period of custody for the Mother.
The recommended arrangements appeared to be the best alternative to maintain some stability for the
Child in light of the Mother's recent frequent changes of circumstances and the steady schedule which
the Child has experienced during custodial periods with the Father under the prior Order.
?t,??.ur-? ?f,_,? X03 -?--?J??
Date Dawn S. Sunday, Esquire
Custody Conciliator
JOSHUA B. SINGER IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
KERI ANN CRAWFORD : NO. 2001-6599 CIVIL
ORDER OF COURT
AND NOW, this 10TH day of FEBRUARY, 2003, the custody hearing scheduled
for Friday, March 21, 2003, at 9:15 a.m. will be held at a later time on the same day. The
hearing is scheduled for FRIDAY, MARCH 21, 2003, at 11:00 a.m. in Courtroom # 5.
B e Cou
Edward E. Guido, J.
Diane G. Radcliff, Esquire
Douglas Miltenberger, Esquire
Lucy Johnston-Walsh, Esquire
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JOSHUA B. SINGER : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V. .
KERI A. CRAWFORD NO. 2001-6599 CIVIL TERM
ORDER OF COURT
AND NOW, this fH day of MARCH, 2003, a Rule is issued upon defendant
Keri A. Crawford to Show Cause why the Family Law Clinic should not be allowed
to withdraw as her counsel.
Said Rule is returnable twenty (20) days after service.
With the concurrence of Plaintiff's counsel, the hearing scheduled in this
matter for March 21, 2003, at 9:30 a.m. is continued to allow for the resolution
of this matter and to allow defendant to obtain alternate counsel, if necessary.
We will reschedule the hearing upon request of either party.
Edward E. Guido, J.
Diane Radcliff, Esquire -- C c P 1 ?YI( i 1 g a
Family Law Clinic
Lucy Johnston-Walsh, Esquire ?C?pl
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MAR 0 6 2003 $1
JOSHUA B. SINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION -LAW
IN CUSTODY
KERI A. CRAWFORD,
Defendant NO. 01 - 6599 CIVIL TERM
ORDER
AND NOW, this day of upon consideration of the
foregoing petition, it is hereby ordered that
(1) a rule is issued upon the respondent to show cause why the petitioner is not entitled to
the relief requested;
(2) the respondent shall file an answer to the petition within twenty days of service upon
the respondent;
(3) the petition shall be decided under Pa.R.C.P. No. 206.7;
(4) depositions shall be completed within days of this date;
(5) argument shall be held on in Courtroom of the
Cumberland County Courthouse; and
(6) notice of the entry of this order shall be provided to all parties by the petitioner.
BY THE COURT:
J.
MAR 0 6 2003
JOSHUA B. SINGER,
Plaintiff
V.
KERI A. CRAWFORD,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN CUSTODY
NO. 01 - 6599 CIVIL TERM
PETITION FOR RULE TO SHOW CAUSE FOR ]LEAVE TO WITHDRAW
Petitioner, The Family Law Clinic, hereby petitions for a rule to show cause for leave to
withdraw from further representation of Keri A. Crawford, pursuant to Pennsylvania Rule of
Professional Conduct 1.16(b)(4) and (6), and Pa.R.C.P. 1012(b), and in support therefore avers
the following:
1. The Family Law Clinic began its representation of Ms. Crawford on November
26, 2001.
2. On November 27, 2002, Plaintiff filed a complaint for custody, naming Ms.
Crawford as Defendant.
3. On December 6, 2001, the parties attended a custody conciliation. An Order of
Court was issued on December 14, 2001, granting Ms. Crawford shared legal and shared
physical custody of her son. The initial Order of has been amended four times since
December 14, 2001.
4. Most recently, the parties attended a conciliation on January 23, 2003.
5. On January 29, 2003, an Order of Court was issued. Plaintiff was granted primary
physical custody, and Ms Crawford was granted partial physical custody every other
weekend. Ms. Crawford did not agree with this Order, and consequently, a hearing is
scheduled for March 21, 2003.
6. The Pre-Hearing Memorandum is due on March 11, 2003. The Family Law Clinic
has attempted to meet with Ms. Crawford to prepare the Pre-Hearing Memorandum.
7. Ms. Crawford consistently failed to maintain contact with the Family Law Clinic.
8. Ms. Crawford consistently failed to return telephone calls to the Family Law
Clinic.
9. Ms. Crawford consistently failed to respond to correspondences from the
Family Law Clinic.
10. Ms. Crawford missed meetings with the Family Law Clinic that prevented the
Family Law Clinic from being able to adequately prepare for her March 21, 2003 hearing.
11. The Family Law Clinic warned Ms. Crawford that continued lack of cooperation
would result in the Family Law Clinic filing a Petition to Withdraw.
12. Ms. Crawford failed to contact the Family Law Clinic following this warning.
13. Irreconcilable differences have arisen between the Family Law Clinic and Ms.
Crawford which have made further representation of her unreasonably difficult.
14. Pursuant to C.C.R.P. 206(2), concurrence from opposing counsel was obtained,
by telephone, on March 5, 2003. Opposing counsel stated that she does not oppose
rescheduling the hearing so that Ms. Crawford has an opportunity to seek new counsel.
r
WHEREFORE, the Family Law Clinic requests a rule to show cause for leave to
withdraw as counsel for Ms. Crawford in this matter.
Respectfully Submitted,
Date: 3-6 G 3
C", /' .,
-'Dou 1 s A. Miltenberger
g
Certified Legal Intern
THO PLACE
ROBERT E. RAINS
LUCY JOHNSTON-WALSH
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
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JOSHUA B. SINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION -LAW
IN CUSTODY
KERI A. CRAWFORD,
Defendant NO. 01 - 6599 CIVIL TERM
CERTIFICATE OF SERVICE
I, Douglas A. Miltenberger, hereby certify that I served a true and correct copy of the
Petition for Rule to Show Cause for Leave Withdraw Pursuant To Pa.R.C.P. 1.16(a) on Keri A.
Crawford at 3524 September Drive, #1, Camp Hill, PA 17011 by depositing a copy of the same
in the United States Mail, postage prepaid on the I Ofl' day of March, 2003.
Date i Douglas A. Miltenberger
Certified Legal Intern
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
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JOSHUA B. SINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION -LAW
IN CUSTODY
KERI A. CRAWFORD,
Defendant NO. 01 - 6599 CIVIL TERM
CERTIFICATE OF SERVICE
I, Douglas A. Miltenberger, hereby certify that I served a true and correct copy of the
Petition for Rule to Show Cause for Leave Withdraw Pursuant 'To Pa.R.C.P. 1.16(a) on Diane
Radcliff, Esq., at 3448 Trindle Road, Camp Hill, PA 17011 by depositing a copy of the same in
the United States Mail, postage prepaid on the 10`' day of March, 2003.
Date Douglas A. Miltenberger
Certified Legal Intern
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
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JOSHUA B. SINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION -LAW
IN CUSTODY
KERI A. CRAWFORD, :
Defendant NO. 01 - 6599 CIVIL TERM
PETITION TO MAKE RULE ABSOLUTE
AND NOW, comes petitioner, the Family Law Clinic, and petitions the court as follows:
1. Petitioner, the Family Law Clinic, is counsel of record for the above-named
Defendant, Keri A. Crawford.
2. Petitioner filed a Petition for Rule to Show Cause for Leave to Withdraw in this
matter on March 6, 2003. On March 7, 2003, this Court issued an Order of Court for Ms. Crawford
to show cause why the Family Law Clinic should not be permitted to withdraw.
A copy of the Petition for Rule to Show Cause for Leave to Withdraw and Order of Court are
attached.
3. The March 7, 2003 Order of Court permitted Ms. Crawford to object to the
Family Law Clinic's request to withdraw within twenty (20) days after service.
4. A true and correct copy of the Petition for Rule to Show Cause for Leave to Withdraw
and the Order of Court was served upon Defendant, Keri A. Crawford, by first class mail, postage
prepaid, at 3524 September Drive, #1, Camp Hill, PA 17011, on March 10, 2003.
5. A true and correct copy of the Petition for Rule to Show Cause for Leave to Withdraw
and the Order of Court was served upon Plaintiff's attorney, Diane Radcliff, by first class mail,
postage prepaid, at 3448 Trindle Road, Camp Hill, PA 17011 on March 10, 2003.
6. Twenty (20) days have passed since the Rule was served upon the Respondent
and Plaintiff's counsel, and no response or objection has been filed.
WHEREFORE, the Family Law Clinic requests this Court to enter an Order permitting the
Family Law Clinic to withdraw as counsel for Keri A. Crawford in this matter.
Date: a
14
ouglas'A. Miltenberger
Certified Legal Intern
THOM h LACE
ROBERT E. RAINS
LUCY JOHNSTON-WALSH
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
JOSHUA B. SINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION -LAW
IN CUSTODY
KERI A. CRAWFORD,
Defendant NO. 01 - 6599, CIVIL TERM
CERTIFICATE OF SERVICE
I, Jacinta Testa, hereby certify that I am serving a true and correct copy of the
Petition to Make Rule Absolute and Order of Court on the following persons by depositing a copy of
the same in the United States Mail, postage prepaid, on April 1, 2003:
Keri A. Crawford, Defendant
3524 September Drive, # 1
Camp Hill, PA 17011
Diane Radcliff, Esq., counsel for Plaintiff
3448 Trindle Road
Camp Hill, PA 17011
Testa
d :Legal Intern
FAMILY LAW CLINIC
45 North :Pitt Street
Carlisle, PA 17013
717-243-2968
JOSHUA B. SINGER : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
KERI A. CRAWFORD NO. 2001-6599 CIVIL TERM
ORDER OF COURT
AND NOW, this 7T" day of MARCH, 2003, a Rule is issued upon defendant
Keri A. Crawford to Show Cause why the Family Law Clinic should not be allowed
to withdraw as her counsel.
Said Rule is returnable twenty (20) days after service.
With the concurrence of Plaintiff's counsel, the hearing scheduled in this
matter for March 21, 2003, at 9:30 a.m. is continued to allow for the resolution
of this matter and to allow defendant to obtain alternate counsel, if necessary.
We will reschedule the hearing upon request of either party.
E=dward E. Guido, J.
Diane Radcliff, Esquire
Family Law Clinic
Lucy Johnston-Walsh, Esquire
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JOSHUA B. SINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION -LAW
IN CUSTODY
KERI A. CRAWFORD, :
Defendant NO. 01 - 6599 CIVIL TERM
PETITION FOR RULE TO SHOW CAUSE FOR LEAVE TO WITHDRAW
Petitioner, The Family Law Clinic, hereby petitions for a rule to show cause for leave to
withdraw from further representation of Keri A. Crawford, :pursuant to Pennsylvania Rule of
Professional Conduct 1.16(b)(4) and (6), and Pa.R.C.P. 1012(b), and in support therefore avers
the following:
1. The Family Law Clinic began its representation of Ms. Crawford on November
26, 2001.
2. On November 27, 2002, Plaintiff filed a complaint for custody, naming Ms.
Crawford as Defendant.
3. On December 6, 2001, the parties attended a custody conciliation. An Order of
Court was issued on December 14, 2001, granting Ms. Crawford shared legal and shared
physical custody of her son. The initial Order of has been amended four times since
December 14, 2001.
4. Most recently, the parties attended a conciliation on January 23, 2003.
5. On January 29, 2003, an Order of Court was issued. Plaintiff was granted primary
physical custody, and Ms Crawford was granted partial physical custody every other
weekend. Ms. Crawford did not agree with this Order, and consequently, a hearing is
scheduled for March 21, 2003.
6. The Pre-Hearing Memorandum is due on March 11, 2003. The Family Law Clinic
has attempted to meet with Ms. Crawford to prepare the Pre-Hearing Memorandum.
7. Ms. Crawford consistently failed to maintain contact with the Family Law Clinic.
8. Ms. Crawford consistently failed to return telephone calls to the Family Law
Clinic.
9. Ms. Crawford consistently failed to respond to correspondences from the
Family Law Clinic.
10. Ms. Crawford missed meetings with the Family Law Clinic that prevented the
Family Law Clinic from being able to adequately prepare for her March 21, 2003 hearing.
11. The Family Law Clinic warned Ms. Crawford that continued lack of cooperation
would result in the Family Law Clinic filing a Petition to Withdraw.
12. Ms. Crawford failed to contact the Family Law Clinic following this warning.
13. Irreconcilable differences have arisen between the Family Law Clinic and Ms.
Crawford which have made further representation of her unreasonably difficult.
14. Pursuant to C.C.R.P. 206(2), concurrence from opposing counsel was obtained,
by telephone, on March 5, 2003. Opposing counsel stated that she does not oppose
rescheduling the hearing so that Ms. Crawford has an opportunity to seek new counsel.
WHEREFORE, the Family Law Clinic requests a rule to show cause for leave to
withdraw as counsel for Ms. Crawford in this matter.
Date: S
Respectfully Submitted,
ougl s A. Miltenberger
Certified Legal Intern
THO . PLACE
ROBERT E. RAINS
LUCY JOHNSTON-WALSH
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
'717-243-2968
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APR 0 2 2003
JOSHUA B. SINGER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION -LAW
IN CUSTODY
KERI A. CRAWFORD,
Defendant
NO. 01 - 6599 CIVIL TERM
ORDER OF COURT
AND NOW, this
V 4
day of , 2003, upon presentation and
consideration of the within Petition to Make Rule Absolute, the Rule entered by Order on March 7,
2003, is hereby made ABSOLUTE and Petitioner, the Family Law Clinic, is permitted to
withdraw as counsel for Defendant, Keri A. Crawford.
J.
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4-463
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JOSHUA B. SINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION -LAW
IN CUSTODY
KERI A. CRAWFORD,
Defendant NO. 01 - 6599 CIVIL TERM
PETITION TO MAKE RULE ABSOLUTE
AND NOW, comes petitioner, the Family Law Clinic, and petitions the court as follows:
1. Petitioner, the Family Law Clinic, is counsel of record for the above-named
Defendant, Keri A. Crawford.
2. Petitioner filed a Petition for Rule to Show Cause for Leave to Withdraw in this
matter on March 6, 2003. On March 7, 2003, this Court issued. an Order of Court for Ms. Crawford
to show cause why the Family Law Clinic should not be permitted to withdraw.
A copy of the Petition for Rule to Show Cause for Leave to Withdraw and Order of Court are
attached.
3. The March 7, 2003 Order of Court permitted Ms. Crawford to object to the
Family Law Clinic's request to withdraw within twenty (20) days after service.
4. A true and correct copy of the Petition for Rule to Show Cause for Leave to Withdraw
and the Order of Court was served upon Defendant, Keri A. Crawford, by first class mail, postage
prepaid, at 3524 September Drive, #1, Camp Hill, PA 17011, on March 10, 2003.
5. A true and correct copy of the Petition for Rule to Show Cause for Leave to Withdraw
and the Order of Court was served upon Plaintiff s attorney, Diane Radcliff, by first class mail,
postage prepaid, at 3448 Trindle Road, Camp Hill, PA 17011 on March 10, 2003.
6. Twenty (20) days have passed since the Rule was served upon the Respondent
and Plaintiff's counsel, and no response or objection has been filed.
WHEREFORE, the Family Law Clinic requests this Court to enter an Order permitting the
Family Law Clinic to withdraw as counsel for Keri A. Crawford in this matter.
Date: a
ouglas"A. Miltenberger
Certified Legal Intern
THOM LACE
ROBERT E. RAINS
LUCY JOHNSTON-WALSH
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
JOSHUA B. SINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION -LAW
IN CUSTODY
KERI A. CRAWFORD,
Defendant NO. 01 - 6599 CIVIL TERM
CERTIFICATE OF SERVICE
I, Jacinta Testa, hereby certify that I am serving a true and correct copy of the
Petition to Make Rule Absolute and Order of Court on the following persons by depositing a copy of
the same in the United States Mail, postage prepaid, on April 1, 2003:
Keri A. Crawford, Defendant
3524 September Drive, # 1
Camp Hill, PA 17011
Diane Radcliff, Esq., counsel for Plaintiff
3448 Trindle Road
Camp Hill, PA 17011
Testa
d Legal Intern
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
JOSHUA B. SINGER : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,, PENNSYLVANIA
V.
KERI A. CRAWFORD NO. 2001-6599 CIVIL TERM
ORDER OF COURT
AND NOW, this 7T" day of MARCH, 2003, a Rule is issued upon defendant
Keri A. Crawford to Show Cause why the Family Law Clinic should not be allowed
to withdraw as her counsel.
Said Rule is returnable twenty (20) days after service.
With the concurrence of Plaintiff's counsel, the hearing scheduled in this
matter for March 21, 2003, at 9:30 a.m. is continued to allow for the resolution
of this matter and to allow defendant to obtain alternate counsel, if necessary.
We will reschedule the hearing upon request of either party.
Edward E. Guido, J.
Diane Radcliff, Esquire
Family Law Clinic
Lucy Johnston-Walsh, Esquire
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Prothonailr4y___
JOSHUA B. SINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
IN CUSTODY
KERI A. CRAWFORD,
Defendant NO. 01 - 6599 CIVIL TERM
PETITION FOR RULE TO SHOW CAUSE FOR LEAVE TO WITHDRAW
Petitioner, The Family Law Clinic, hereby petitions for a rule to show cause for leave to
withdraw from further representation of Keri A. Crawford, pursuant to Pennsylvania Rule of
Professional Conduct 1.16(b)(4) and (6), and Pa.R.C.P. 1012(b), and in support therefore avers
the following:
1. The Family Law Clinic began its representation of Ms. Crawford on November
26, 2001.
2. On November 27, 2002, Plaintiff filed a complaint for custody, naming Ms.
Crawford as Defendant.
3. On December 6, 2001, the parties attended a custody conciliation. An Order of
Court was issued on December 14, 2001, granting Ms. Crawford shared legal and shared
physical custody of her son. The initial Order of has been amended four times since
December 14, 2001.
4. Most recently, the parties attended a conciliation on January 23, 2003.
5. On January 29, 2003, an Order of Court was issued. Plaintiff was granted primary
physical custody, and Ms Crawford was granted partial physical custody every other
weekend. Ms. Crawford did not agree with this Order, and consequently, a hearing is
scheduled for March 21, 2003.
6. The Pre-Hearing Memorandum is due on March 11, 2003. The Family Law Clinic
has attempted to meet with Ms. Crawford to prepare the Pre-Hearing Memorandum.
7. Ms. Crawford consistently failed to maintain contact with the Family Law Clinic.
8. Ms. Crawford consistently failed to return telephone calls to the Family Law
Clinic.
9. Ms. Crawford consistently failed to respond to correspondences from the
Family Law Clinic.
10. Ms: Crawford missed meetings with the Family Law Clinic that prevented the
Family Law Clinic from being able to adequately prepare for her March 21, 2003 hearing.
11. The Family Law Clinic warned Ms. Crawford that continued lack of cooperation
would result in the Family Law Clinic filing a Petition to Withdraw.
12. Ms. Crawford failed to contact the Family Law Clinic following this warning.
13. Irreconcilable differences have arisen between the Family Law Clinic and Ms.
Crawford which have made further representation of her unreasonably difficult.
14. Pursuant to C.C.R.P. 206(2), concurrence from opposing counsel was obtained,
by telephone, on March 5, 2003. Opposing counsel stated that she does not oppose
rescheduling the hearing so that Ms. Crawford has an opportunity to seek new counsel.
WHEREFORE, the Family Law Clinic requests a rule to show cause for leave to
withdraw as counsel for Ms. Crawford in this matter.
Date:
Respectfully Submitted,
ouglzfs A. Miltenberger
Certified Legal Intern
THO PLACE
ROBERT E. RAINS
LUCY JOHNSTON-WALSH
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
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JOSHUA B. SINGER,
PLAINTIFF
V.
KERI ANN CRAWFORD,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 01 - 6599
CIVIL ACTION - CUSTODY
PRAECIPE TO ENTER APPEARANCE AS PLAINTIFF'S COUNSEL
TO THE PROTHONOTARY:
Please enter the appearance of Steven Howell, Esquire on behalf of the Plaintiff Joshua B.
Singer.
Respectfully submitted,
BY:
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court I.D. 62063
Attorney for Plaintiff
Certificate of Service
I hereby certify that on the date set forth below a true and correct copy of the foregoing
document was served upon all counsel of record via postage prepaid, first class United States
Mail addressed as follows:
Keri A. Crawford
25 North 17th Street
Camp Hill, PA 17011
Date: June 11, 2003
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JOSHUA B. SINGER : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
KERI ANN CRAWFORD : NO. 2001-6599 CIVIL
ORDER OF COURT
AND NOW, this 12TH day of JUNE, 2003, a hearing on Father's Petition for
Special Relief is scheduled for MONDAY JUNE 16, 2003 at 1:30 a.m. in
Courtroom # 5 of the Cumberland County, Courthouse, Carlisle, Pa. Pending
said hearing the child may remain in the custody of Mother.
Provided, however, the child shall not be removed from this Court's
jurisdiction by any person without further order of the Court.
By
Edward E.
1.
Steven Howell, Esquire
For the Plaintiff
Keri A. Crawford
25 North 17`h Street
Camp Hill, Pa. 17011"'?
Cathy Lyman (York CYS Caseworker)
P.O. Box 114
Rossville, Pa. 17358
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JOSHUA B. SINGER,
Plaintiff
V.
KERI ANN CRAWFORD,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-6599
CIVIL ACTION
:CUSTODY
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY OF SAID COURT:
Please enter the appearance of Patricia J. Romano, Esquire on behalf of the Defendant
in the above referenced matter.
Respectfully Submitted,
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Dated:
4711 Locust Lane /
Harrisburg, PA 717109
(717) 657-0632
Id. No.
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IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENNSYLVANIA
JOSHUA B. SINGER
Plaintiff
V.
NO. 01-6599 CIVIL TERM
KERI ANN CRAWFORD
Defendant
IN CUSTODY
PRAECIPE TO WITHDRAW APPEARANCE OF LEGAL COUNSEL
TO THE PROTHONOTARY OF THE SAID COURT:
Please withdraw the appearance of Diane G. Radcliff, Esquire, as attorney for the Plaintiff in the
above captioned case.
Respectfully submitted,
CLIFF, ESQUIRE
3448 Trindle 'Road
6aa?p-HtH?F',4 17011
Phone: (717) 737-0100
Fax: (717) 975-0697
Supreme Court ID # 32112
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JOSHUA B. SINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
KERI ANN CRAWFORD,
Defendant 01-6599 CIVIL TERM
ORDER OF COURT
AND NOW, this 16th day of June, 2003, after hearing,
we enter the following temporary order:
1. Mother shall have primary physical custody of the
child pending the completion of the Children and Youth
investigation into the allegation of sexual abuse.
2. The father may visit with the child every Tuesday
and Thursday from 4:00 o'clock p.m. until 8:00 o'clock p.m.
provided, however, that said visitation shall be exercised in the
continuous presence of the maternal grandmother. The maternal
grandmother must be present when the child is picked up and may
not allow the child to leave her sight.
3. Upon completion of the Children and Youth
investigation in connection with the allegation of sexual abuse,
if the investigation is unfounded, the child shall be returned to
the father and the terms of our order of January 29, 2003, shall
remain in effect until further order of Court.
If the results of the investigation are anything
other than "unfounded", this order shall remain in full force and
effect pending further order of court.
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Steven Howell, Esquire
619 Bridge Street
New Cumberland, PA 17070
For the Plaintiff /? ?fJU3
Patricia J. Romano, Esquire
4711 Locust Lane IA `°k lia{
Harrisburg, PA 17109
For the Defendant
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JOSHUA B. SINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
KERI ANN CRAWFORD,
Defendant 01-6599 CIVIL TERM
ORDER OF COURT
AND NOW, this 16th day of June, 2003, after hearing,
the Petition for Contempt is dismissed.
By e Court,
Steven Howell, Esquire
619 Bridge Street
New Cumberland, PA 17070
For the Plaintiff G oLf d3
Patricia J. Romano, Esquire
4711 Locust Lane /N u? 4+C
Harrisburg, PA 17109
For the Defendant
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JOSHUA B. SINGER,
PLAINTIFF
V.
KERI ANN CRAWFORD,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 01 - 6599
CIVIL ACTION - CUSTODY
PRAECIPE
TO THE PROTHONOTARY:
In accordance with a verbal directive from the Honorable Edward E. Guido on June 16,
2003 and 13 of this Court's June 16, 2003 Order, please record the original letter from York
County Children & Youth Services dated June 20, 2003 which determined that the report of
suspected abuse was "unfounded". This letter automatically reinstates this Court's January 29,
2003 Custody Order.
Respectfully submitted,
BY:
Xeven Howell, E
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court I.D. 62063
Attorney for Plaintiff
Certificate of Service
I hereby certify that on the date set forth below a true and correct copy of the foregoing
document was served upon all counsel of record via postage prepaid, first class United States
Mail addressed as follows:
Patricia J. Romano, Esquire
4711 Locust Lane
Harrisburg, PA 17109
Date: June 24, 2003
THE COUNTY COMMISSIONERS OF YORK COUNTY
BOARD OF COMMISSIONERS
Robert A. Minnich, President
Christopher B. Reilly
Shirley L. Glass
Charles R. Noll
Administrator-Chief Clerk
David S. Craun
Solicitor
Children and Youth Services
MARY DANIELS LEVY
EXECUTIVE DIRECTOR
June 20, 2003
Mr. Joshua Singer
101 Stevens Road
York Haven, PA 17370
Dear Mr. Singer:
Re: Clay Singer
This is to notify you that on June 20, 2003, the undersigned Child Protective
Services investigator determined the report of suspected abuse, in which you were
named as a perpetrator, was unfounded.
All records of the report will be destroyed within one year of the date on
which it was received and upon notification from Childline.
If you have any questions regarding this, please contact me.
Sincerely,
dsh
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Cathy S. an
C.P.S. Investigator
P q"X 114 • 7501 CARLISLE ROAD • ROSSVILLE, PA 17358 • PH. M (717) 432-3095 • FAX # (717) 432-0842
"EQUAL OPPORTUNITY EMPLOYER"
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JOSHUA B. SINGER,
Plaintiff/Respondent
V.
KERI ANN CRAWFORD,
Defendant/Petitioner
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-6599
: CIVIL ACTION
:CUSTODY
PETITION FOR MODIFICATION OF CUSTODY
AND RELOCATION
AND NOW, comes the Defendant/Petitioner, Keri Ann Crawford, nka Keri Ann
Torrent, by and through her attorney, Patricia J. Romano, Esquire, and respectfully files the
following Petition for Modification of Custody and Relocation:
1. Defendant/Petitioner, Keri Crawford Torrent (Mother), is an adult individual
temporarily residing at 25 N. 171h St. Camp Hill, in Cumberland County, Pennsylvania. Her
permanent address is 6460 South East 174`h Place, Summerfield, Florida.
2. Plaintiff/Respondent, Joshua B. Singer (Father) is an adult individual residing
at 3050 Old Trail Road, York Haven, York County, Pennsylvania. He is represented by
Steven Howell, Esquire.
3. The parties are the parents of the natural child, Clay B. Singer, born May 9,
2003.
4. A Custody Order was entered by the Honorable Edward E. Guido on January
29, 2003. A copy is attached hereto as Exhibit A.
a. The Order was intended to be temporary in nature until the issue of the
minor child's custody could be heard on March 21", 2003. (Custody
Conciliation Summary Report (Exhibit B) at # 6)
b. Mother did not receive notice of the scheduled hearing and the custody
issue has not been heard by this Honorable Court.
Petitioner has married and permanently relocated to Florida and believes and
avers that relocation with Mother is in the best interest of the minor child.
a. Mother's life has stabilized and she can now provide a loving, nurturing
environment for Clay that would greatly improve his quality of life.
b. Mother has grave concerns about Father's ability to care for the child.
C. Mother does not act now nor has she ever acted to impede Father's
relationship with Clay. Father, however, has routinely deprived Mother
of access to their son.
d. A visitation schedule can be developed that fosters the current
father/son relationship. Mother proposes that child spend one week per
month with Father, with holidays alternated between the parties.
6. Because the matter of custody between the parties has not been heard by the
Court nor has a permanent custody arrangement ever been emplaced (Exhibit B), Mother
believes that the competing custodial environments should be scrutinized at hearing.
2
7. Because Petitioner is presently visiting her parents in Camp Hill and will
remain there until her Petition is decided, she believes that the best interest of the child will
be served if the parties alternate custody on a weekly basis during this time.
8. Because the relationship between the parties is unchanged since the 1/29/03
Order, Petitioner believes that further attempts at a conciliation conference would be
fruitless.
WHEREFORE, Petitioner prays that this Honorable Court promptly schedule a
hearing on the matter of custody and relocation and direct that the parties alternate custody
of the minor child on a weekly basis until the matter is decided.
Respectfully Submitted,
C
Dated: 02 ' 6
Patricia J. Ro , Esquire
4711 Locust LbAc
Harrisburg, PA 17109
(717) 657-0632
Id. No. 88161
JOSHUA B. SINGER, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 01-6599
KERI ANN CRAWFORD, : CIVIL ACTION
Defendant :CUSTODY
VERIFICATION
I verify that the statements made in the foregoing are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904
relating to unsworn falsification to authorities.
By
Keri ACrawford, kna
Keri Ann Torrent
Date: 63
Exhibit A
JOSHUA B. SINGER,
Plaintiff
vs.
KERI ANN CRAWFORD
Defendant
PRIOR JUDGE: Edward E. Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-6599
CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this a 5 day of 2003, upon
consideration of the attached Custody Conciliation eport?ered and directed as follows:
Ga 9h CK .5 u er
1. A Hearing is scheduled in Courtroom No. _ oft he Cumberland County
Court House on the 2,/ t-' day of M8/CG?003, at which time testimony will
be taken. For purposes of the Hearing, the Father shall be deemed to be the moving party and shall
proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel
a memorandum setting forth each party's position on custody, a list: of witnesses who are expected to
testify at the Hearing, and a summary of the anticipated testimony of each witness. These memoranda
shall be filed at least ten days prior to the Hearing date.
2. Pending further Order of Court or agreement of the parties, the parties shall have shared
legal custody of Clay B. Singer, born May 9, 2000, the Father shall have primary physical custody, and
the Mother shall have partial physical custody of the Child. The Mother shall have continuous custody
of the Child through February 6, 2003 between 5:00 pm and 6:00 pm, when the Father shall pick up
the Child. Prior to February 6, the Father shall have an interim period of custody on one weekday
evening from between 5:00 and 6:00 pm until 8:00 pm, with the specific date to be arranged by
agreement of the parties. Thereafter, beginning on February 14, 2003, the Mother shall have custody
of the Child on alternating weekends from Friday between 5:00 and 6:00 pm through Sunday at 8:00
pm. During the interim weekends, the Mother shall have custody of the Child on Sunday from 1:00
pm until 8:00 pm with the exception that the Father shall have the option of preempting the Mother's
Sunday afternoon / evening period of custody two times pending the Hearing upon providing at least
one week advance notice to the Mother. In the event the Father exercises his right to custody on
Sunday, arrangements shall be made for a substitute period of custody for the Mother on either the
Wednesday immediately preceding or following the Sunday from between 5:00 and 6:00 pm through
8:00 pm. The Mother shall have custody of the Child on Easter Sunday from 1:00 pm until 8:00 pm.
3. The party receiving custody shall be responsible to provide transportation for the exchange
of custody unless otherwise agreed.
Order. The prior Order of this Court dated November 4, 2002 is vacated and replaced with this
BY THE COURT,
Edward E.Guido
cc: Diane G. Radcliff, Esquire, Counsel for Father
Douglas Miltenberger & Lucy Johnston-Walsh, Esquire, Counsel for Mother
J.
Exhibit B
JOSHUA B. SINGER,
Plaintiff
vs.
KERI ANN CRA WFORD
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-6599 CIVIL ACTION LAW
IN CUSTODY'
PRIOR JUDGE: Edward E.Guido
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE
PROCEDURE WITH CUMB
1915 3 8
I
follows..
N_ AME
L110 undersigned Custody Con zuLAND COUNTY T YRULE OF CIVIL
following report:
The pertinent information concerning the Child who is the subject of this litigation is as
Clay B. Singer
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
May 9, 2000
Father
2• A Conciliation
attendanc Conference was held on January
e: The Father, Joshua B. Singer, with his co
Mother, Keri Ann Crawford,
Esquire. With her counsel, Douglas Miltenbergller . Radcliff, Esquire
er,Diane and G.
Lucy Johnston-Walsh,
3• This Court previously entered an Order on November
conciliation conference under which the Father has
Mother, who had 4, 2002 followin
cycle, one week of moved to Florida, had primary physical custod g he agreement at a
which was to b' s peal custody during three y of the Child and the
The Mother has relocated back to pe pent at the maternal Weeks out of eve
Hill. The Father resides in York nnsylvania where grandmother's residence ' P eight week
March 2002, Haven. The she currently resides with her n Pennsylvania.
and was living and during a telephone conciliatio?noctonher fere nleathat she had finance' ance' in Camp
g temporarily with friends. indicated with her finance' in
enrolled in classes
Subsequently, the Mother deferred her educational plans to work in her finance's family business in
Florida. In December 2002, the Mother moved back to Pennsylvania where she is employed and rents
an apartment.
The Father requested a review of the custody arrangements as permitted in the prior Order.
Each party raised many concerns regarding the other parent's ability to properly care for the Child. It
appears that both counseling for both parenting skills and development of a co-parenting relationship
would be beneficial to the parties. The parties agreed to investigate the availability of both types of
counseling, although they have limited financial resources.
4. The parties were not able to reach an agreement as to ongoing custody arrangements for the
Child and it will be necessary to schedule a Hearing. As the parties raised many issues concerning the
Child's safety, it is requested that the hearing be expedited if possible.
5. The Mother's position on custody is as follows: The Mother believes that it would be in the
best interest of the Child to share custody on an alternating weekly basis. As the Mother is currently in
the last two weeks of her three week period of custody under the existing Order, she does not believe
that it would be good for the Child to then be transferred to the Father's primary custody pending the
Hearing. The Mother does not feel it is appropriate for the Father to have an evening period of custody
during her two week period as, according to her the Father did not allow her to see the Child for
several weeks when she had returned to Pennsylvania. The Mother objects to the babysitter which the
Father employs while he is at work and stated that she was unwilling to take the Child to the babysitter
if she were to have overnight weekday periods of custody. The Mother expressed many concerns
about the Father's ability to care for the Child including concerns regarding the Child's diet, toilet
training, and injuries from what the Mother believes to have been pet attacks. The Mother indicated
that she contacted the police in Florida to look at a rash on the Child's shoulder after the Father
transported the Child to her residence for her period of custody.
6. The Father's position on the custody is as follows: The Father believes that it would be in the
Child's best interest for him to have primary custody as he did during five weeks of the eight week
cycle while the Mother was living in Florida. The Father stated that the Mother has been very unstable
since last March and has shown little concern for the Child's well being. According to the Father, the
Mother did not even advise him that she was in Pennsylvania until Christmas Eve and has only
contacted him two times, regarding the Child since she has been in Pennsylvania. According to the
Father, when the Child returns from visiting the Mother, the Child exhibits defiant behavior and tells
the Father that the Mother fiance' hits him. The Father expressed concerns regarding the Child's toilet
training and eating habits. The Father indicated that he may be agreeable to increasing the Mother's
periods of custody with the Child after she has demonstrated a more stable lifestyle. The Father
proposed that the Mother have periods of custody with the Child on alternating weekends and one
evening per week.
7. It was very difficult at the conference to sort through the accusations, multiple concerns and
contradictions in an effort to establish temporary arrangements pending the hearing. However based
on representations made by the parties during this conference and prior conferences, the conciliator
recommends an Order in the form as attached scheduling the Hearing and establishing interim custody
arrangements. It should be noted that the Mother strongly objects to the interim recommendations and
may request further review by the Court pending the Hearing. The Father also objected to portions of
the temporary arrangements, particularly the Sunday evening period of custody for the Mother.
The recommended arrangements appeared to be the best alternative to maintain some stability for the
Child in light of the Mother's recent frequent changes of circumstances and the steady schedule which
the Child has experienced during custodial periods with the Father under the prior Order.
Date
Dawn S. Sunday, Esquire
Custody Conciliator
JOSHUA B. SINGER,
Plaintiff
V.
KERI ANN CRAWFORD,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-6599
CIVIL ACTION
:CUSTODY
CERTIFICATE OF SERVICE
AND NOW, this deday of 2003, I, Katherine A. Frey,
secretary to Patricia J. Romano, Esquire, Attorney for the Defendant, hereby certifies that a
copy of the within document has been served upon Steven Howell, Esquire, attorney for the
Plaintiff, by depositing a copy of the same in the United States mail, first class, postage
prepaid, at Harrisburg, Pennsylvania, to the following addressee:
Steven Howell, Esquire
619 Bridge Street
New Cumberland, PA 17070
By:
Katherine A. Frey
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JOSHUA B. SINGER,
PLAINTIFF
V.
KERI ANN CRAWFORD,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 01 - 6599
CIVIL ACTION - CUSTODY
PRELIMINARY OBJECTION TO DEFENDANT'S PETITION TO
MODIFY CUSTODY
TO: Defendant Keri Ann Crawford
c/o Patricia J. Romano, Esquire
4711 Locust Lane
Harrisburg, PA 17109
NOTICE TO PLEAD
YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RES13ONSE TO THE ENCLOSED
PRELIMINARY OBJECTIONS WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF
OR A JUDGMENT MAY BE ENTERED AGAINST YOU.
On or about June 26, 2003 the Defendant filed a Petition to Modify and Relocate.
2. Defendant failed to include the latest Child Custody Order dated June 16, 2003
which is attached hereto as Exhibit "A". In accordance with Pa. R.C.P. 1915.15 the current
custody order must be attached to any Petition to Modify.
3. Defendant was served with this Order by ordinary mail and by fax on June 24,
2003 as shown on Exhibit "B".
4. Defendant's proposed Court Order seeks to unilaterally change the current custody
Order in effect which grants Father primary physical custody to a week on/week off arrangement.
See Exhibit "C" at ¶2 Line 2.
Defendant also failed to mention in her Petition to Modify filed June 26, 2003 that
a hearing was held on June 16, 2003 before the Honorable Edward E. Guido and that he
specifically directed Defendant's counsel in chambers to file a Petition to Modify if she sought to
change the existing custody arrangement granting Father primary physical custody.
6. The hearing was held because Defendant refused to return the child due to sexual
abuse allegations which York County Children & Youth determined on June 20, 2003 to be
"unfounded". See Exhibit "D".
a. By way of further explanation, Defendant moved to Florida in March 2003
and did not exercise any visitation until Friday, June 6, 2003 when she asked for a weekend
visitation while in Pennsylvania. Within five (5) hours of picking the child up for the visit
Defendant had the child at Holy Spirit Hospital claiming he was sexually abused. Defendant
called York Children & Youth Services (YCYS) at 9:55 PM on Friday, June 6, 2003 after
picking the child up at 5:30 PM on the same day.
b. It should be noted that this allegation followed a complaint by Defendant
to York CYS on June 4, 2003 that Father's yard was messy and another complaint on June 5,
2003 that the child was "emaciated" to Detective Martz of the York County District Attorney's
Office. Defendant also sought a Protection from Abuse (PFA) Order from York County during
this same period of time. She was not granted any temporary PFA Order. When neither
complaint achieved Defendant's purposes of immediate custody of the child, the allegation of
sexual abuse was made on June 6, 2003.
7. It should be noted that Father brought to court on June 16, 2003 the Children &
Youth caseworker and the investigating office from Newberry Township Police Department to
testify on his behalf that the allegations were unfounded.
8. Without legal authority or a factual basis, Defendant seeks to bypass the normal
conciliation route. See 18 of Defendant's Petition to Modify.
9. Cumberland County Local Rule 1915.3-5 requires all Petitions to Modify to be
scheduled for a Conciliation Conference. There is no reason for this case to proceed in any other
manner.
WHEREFORE, Defendant's Petition to Modify should be stricken since it fails to
conform to Rule of Court governing the latest Custody Order being attached and seeks to
unilaterally change Father's primary custodial care to alternating; weeks without a conciliation
conference or hearing on the matter.
Respectfully
BY:
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court I.D. 62063
Attorney for Plaintiff
Certificate of Service
I hereby certify that on the date set forth below a true and correct copy of the foregoing
document was served upon all interested parties via postage prepaid, first class United States
Mail addressed as follows:
Patricia J. Romano, Esquire (Via Telecopier 657-1512)
4711 Locust Lane
Harrisburg, PA 17109
Date: June 27, 2003
?.;N 24. 2.47 COURTS
JOSHUA B. SINGER,
Plaintiff
v.
KERI ANN CRAWFORD,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
01-6599 CIVIL TERM
ORUR OF COURT
-ACc ;
AND NOW, this 16th day of June, 2003, after hearing,
we enter the following temporary order:
1. Mother shall have primary physical custody of the
child pending the completion of the Children and Youth
investigation into the allegation of sexual abuse.
2. The father may visit with the child every Tuesday
and Thursday from 4:00 o'clock p.m. until 8:00 o'clock p.m.
provided, however, that said visitation shall be exercised in the
continuous presence of the maternal grandmother. The maternal
grandmother must be present when the child is picked up and may
not allow the child to leave her sight.
3. Upon completion of the Children and Youth
investigation in connection with the allegation of sexual abuse,
if the investigation is unfounded, the child shall be returned to
the father and the terms of our order of January 29, 2003, shall
remain in effect until further order of court.
if the results of the investigation are anything
other than ^unfounded'l, this order shall remain in full force and
effect pending further order of court.
T ^
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- - - - - - -------------------------
--------------------------------
^.24 2C03(7GE; ?2:48 cJ. 8 FAGS 2
Steven Howell, Esquire
619 Bridge Street
New Cumberland, PA 17070
For the Plaintiff
Patricia J. Romano, Esquire
4711 Locust Lane
Harrisburg, PA 17109
For the Defendant
Qcb
Steven Howell
Attorney At Law
619 Bridge Street
New Cumberland, Pennsylvania 17070
717-770-1277
717-770-1278 Telecopier
**** VIA TELECOPIER 657-1512 ****
June 24, 2003
Patricia J. Romano, Esquire
4711 Locust Lane
Harrisburg, PA 17109
RE: Singer v. Crawford, No. 01-6599 (Cumberland County - Custody)
Dear Patty:
Enclosed please find a copy of the Order of Court regarding custody and the petition for
contempt. In addition, I have enclosed the Children and Youth Services letter dated June 20,
2003 which determined the complaint to be "unfounded".
Therefore, once the child is picked up today at 4:00 PM the child shall remain in Father's
primary custody in accordance with Judge Guido's January 29, 2003 Order. Obviously, this
entire weekend (Saturday and Sunday) shall be Father's and the July 4th holiday is his period of
custody under the alternating arrangement as well. I have also enclosed a Praecipe as suggested
by the Court to trigger the automatic reinstatement of the January 29, 2003 Order. Please contact
me if you have any questions.
Very truly
SH/bth
Enclosure
cc:
Joshua B. Singer (w/encl.)
Box E-7
3050 Old Trail Road
York Haven, PA 17370
Esquire
-------------
*:* +'..*:Y*** *****:*****:+:'*•****:**:#:********:******** ********:#:*********:*****?:*%!
*
TRANSACTION REPORT
JUN-24-03 TUE 04:15 PM
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*
FOR: STEVEN HOWELL ESQUIRE
717 770 1278
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JOSHUA B. SINGER,
Plaintiff
vs.
KERI ANN CRAWFORD
Defendant
PRIOR JUDGE: Edward E. Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-6599
CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 9 1 *`I?_ day of , 2003, upon
consideration of the attached Custody Conciliation epo •dered and directed as follows:
@ 9- ?s A
1. A Hearing is scheduled in Courtroom No. of the Cumberland?County
Court House on the 11 ST day of MAiCG?-2003, at which time testimony will
be taken. For purposes of the Hearing, the Father shall be deemed to be the moving party and shall
proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel
a memorandum setting forth each party's position on custody, a list of witnesses who are expected to
testify at the Hearing, and a summary of the anticipated testimony of each witness. These memoranda
shall be filed at least ten days prior to the Hearing date.
2. Pending further Order of Court or agreement of the parties, the parties shall have shared
legal custody of Clay B. Singer, born May 9, 2000, the Father shall have primary physical custody, and
the Mother shall have partial physical custody of the Child. The Mother shall have continuous custody
of the Child through February 6, 2003 between 5:00 pm and 6:00 pm, when the Father shall pick up
the Child. Prior to February 6, the Father shall have an interim period of custody on one weekday
evening from between 5:00 and 6:00 pm until 8:00 pm, with the specific date to be arranged by
agreement of the parties. Thereafter, beginning on February 14, 2003, the Mother shall have custody
of the Child on alternating weekends from Friday between 5:00 and 6:00 pm through Sunday at 8:00
pm. During the interim weekends, the Mother shall have custody of the Child on Sunday from 1:00
pm until 8:00 pm with the exception that the Father shall have the option of preempting the Mother's
Sunday afternoon / evening period of custody two times pending the Hearing upon providing at least
one week advance notice to the Mother. In the event the Father exercises his right to custody on
Sunday, arrangements shall be made for a substitute period of custody for the Mother on either the
Wednesday immediately preceding or following the Sunday from between 5:00 and 6:00 pm through
8:00 pm. The Mother shall have custody of the Child on Easter Sunday from 1:00 pm until 8:00 pm.
3. The party receiving custody shall be responsible to provide transportation for the exchange
of custody unless otherwise agreed.
4. The prior Order of this Court dated November 4, 2002 is vacated and replaced with this
Order.
BY THE (jOURT,
Edward E.Guido J.
cc: Diane G. Radcliff, Esquire, Counsel for Father 0 /- of
Douglas Miltenberger & Lucy Johnston-Walsh, Esquire, Counsel for Mother ?4!`u?
THE COUNTY COMMISSIONERS OF YORK COUNTY
BOARD OF COMMISSIONE
Robert A. Minnich, President
Christopher B. Reilly
Shirley L. Glass
Charles R. Noll
Administrator-Chief Clerk
David S. Craun
Solicitor
Children and Youth Services
MARY DANIELS LEVY
EXECUTIVE DIRECTOR
)une 20, 2003
Mr. ]oshua Singer
101 Stevens Road
York Haven, PA 17370
Dear Mr. Singer:
Re: Clay Singer
This is to notify you that on Tune 20, 2003, the undersigned Child Protective
Services investigator determined the report of suspected abuse, in which you were
named as a perpetrator, was unfounded.
All records of the report will be destroyed within one year of the date on
which it was received and upon notification from Childline.
If you have any questions regarding this, please contact me.
Sincerely,
dsh
G/-4,4 t
Y?t
Cathy San
C.P.S. Investigator
P q)WX 114 • 7501 CARLISLE ROAD • ROSSVH.LE, PA 17358 • PH. N (717) 432-3095 • FAX # (717) 432-0842
"EQUAL OPPORTUNITY EMPLOYER"
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JOSHUA B. SINGER IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V. 01-6599 CIVIL ACTION LAW
KERI ANN CRAWFORD IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Wednesday July 02 2003 , 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 Tuesday, August 12, 2003 at 2:30 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. 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: /s/ Dawn S. Sunday. &q
Custody Conciliator
The Court of Common Pleas of Cumberland County is requi:red 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
WITInvil(SNA13,
of,
ALJi,?I(,,Y,.
JOSHUA B. SINGER, : IN THE COURT OF' COMMON PLEAS
Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 01-6599
KERI ANN CRAWFORD, : CIVIL ACTION
Defendant/Petitioner :CUSTODY
PETITION FOR SPECIAL RELIEF
AND NOW, comes the Defendant/Petitioner, Keri Ann Crawford, nka Keri Ann
Torrent, by and through her attorney, Patricia J. Romano, Esquire, and respectfully files the
following Petition for Special Relief:
1. Petitioner, Keri Crawford Torrent (Mother), is an adult individual temporarily
residing at 25 North 17°i St. Camp Hill, in Cumberland County, Pennsylvania. Her
permanent address is 6460 South East 174`h Place, Summerfield, Florida.
2. Respondent, Joshua B. Singer (Father) is an adult individual residing at 3050
Old Trail Road, York Haven, in York County, Pennsylvania. He is represented by Steven
Howell, Esquire.
3. The parties are the parents of the natural child, Clay B. Singer, born May 9,
2003.
11. Mother believes that the best interest of the child are served by the parents'
sharing physical custody.
WHEREFORE, Defendant requests this Honorable Court direct that the parties
immediately begin sharing physical custody of the minor child on an alternating week basis
and specifically permit a single daily phone contact between the child and whichever parent
is non-custodial that week.
Respectfully Submitted,
C
Dated: Z
Patricia J. Romar
4711 Locust Lard
Harrisburg, PA 1
(717) 657-0632
Id. No. 88161
3
JOSHUA B. SINGER, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 01-6599
KERI ANN CRAWFORD, : CIVIL ACTION
Defendant :CUSTODY
VERIFICATION
I verify that the statements made in the foregoing are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904
relating to unsworn falsification to authorities.
By -
Keri n Crawford, kn
Keri Ann Torrent
Date:27?//).?
Exhibit A
JOSHUA B. SINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
KERI ANN CRAWFORD,
Defendant 01-6599 CIVIL TERM
ORDER OF COURT
AND NOW, this 16th day of June:, 2003, after hearing,
we enter the following temporary order:
1. Mother shall have primary physical custody of the
child pending the completion of the Children and Youth
investigation into the allegation of sexual abuse.
2. The father may visit with the child every Tuesday
and Thursday from 4:00 o'clock p.m. until 8:00 o'clock p.m.
provided, however, that said visitation shall be exercised in the
continuous presence of the maternal grandmother. The maternal
grandmother must be present when the child is picked up and may
not allow the child to leave her sight.
3. Upon completion of the Children and Youth
investigation in connection with the allegation of sexual abuse,
if the investigation is unfounded, the child shall be returned to
the father and the terms of our order of January 29, 2003, shall
remain in effect until further order of Court.
If the results of the investigation are anything
other than "unfounded", this order shall remain in full force and
effect pending further order of court.
WWE 4..ORY FROM RECOM
tactimoay wl wed, ; here unto set my UN
3 tt° i 1 of $a a ;;:i atC IIso PIL ?
?` y
Steven Howell, Esquire
619 Bridge Street
New Cumberland, PA 17070
For the Plaintiff
Patricia J. Romano, Esquire
4711 Locust Lane
Harrisburg, PA 17109 /
For the Defendant
pcb
Exhibit B
JOSHUA B. SINGER,
Plaintiff
vs.
KERI ANN CRAWFORD
Defendant
PRIOR JUDGE: Edward E. Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLA]VD COUNTY, PENNSYLVANIA
01-6599
CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this day of k!jA
2003, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
@
1. A Hearing is scheduled in Courtroom No. 9" 1.5 A _ of the Cumberland-County
Court House on the !-LL t-' day of /)' A CG 2003, at which time testimony will
be taken. For purposes of the Hearing, the Father shall be deemed to be the moving party and shall
proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel
a memorandum setting forth each party's position on custody, a list: of witnesses who are expected to
testify at the Hearing, and a summary of the anticipated testimony of each witness. These memoranda
shall be filed at least ten days prior to the Hearing date.
2. Pending further Order of Court or agreement of the parties, the parties shall have shared
legal custody of Clay B. Singer, born May 9, 2000, the Father shall have primary physical custody, and
the Mother shall have partial physical custody of the Child. The Mother shall have continuous custody
of the Child through February 6, 2003 between 5:00 pm and 6:00 pm, when the Father shall pick up
the Child. Prior to February 6, the Father shall have an interim period of custody on one weekday
evening from between 5:00 and 6:00 pm until 8:00 pm, with the specific date to be arranged by
agreement of the parties. Thereafter, beginning on February 14, 2003, the Mother shall have custody
of the Child on alternating weekends from Friday between 5:00 and 6:00 pm through Sunday at 8:00
pm. During the interim weekends, the Mother shall have custody of the Child on Sunday from 1:00
pm until 8:00 pm with the exception that the Father shall have the option of preempting the Mother's
Sunday afternoon / evening period of custody two times pending the Hearing upon providing at least
one week advance notice to the Mother. In the event the Father exercises his right to custody on
Sunday, arrangements shall be made for a substitute period of custody for the Mother on either the
Wednesday immediately preceding or following the Sunday from between 5:00 and 6:00 pm through
8:00 pm. The Mother shall have custody of the Child on Easter Sunday from 1:00 pm until 8:00 pm.
3. The party receiving custody shall be responsible to provide transportation for the exchange
of custody unless otherwise agreed.
4. The prior Order of this Court dated November 4, 2002 is vacated and replaced with this
Order.
BY THE COURT,
Edward E.Guido
cc: Diane G. Radcliff, Esquire, Counsel for Father
Douglas Miltenberger & Lucy Johnston-Walsh, Esquire, Counsel for Mother
J.
JOSHUA B. SINGER,
Plaintiff
vs.
KERI ANN CRA WFORD
Defendant
PRIOR JUDGE: Edward E.Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-6599 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY' R,PORT
PROCEDU IN ACCORDANCE WITH CUMBERLAND
RE 1915.3-8 the undersigned Custody Conciliator submits the foYo rig rep OF CIWL
follows: 1, The pertinent information concerning the Child who is the subject of this litigation
NAME is as
DATE OF BIRTH
Clay B. Singer U-RREN1 LY IN CUSTODY OF
May 9, 2000
Father
2. A Conciliation
attendance: Conference was held on January 23, 2003, with the following i
The Father, Joshua B.
M other, Keri Ann C Singer, with his rawford, with her counsel, Douglas counsel, Miltenberger, U.
Y ndividuals in
Esquire. Radcliff Esquire, ndi
and LucJo and the
hnston-Walsh,
3. This Court previously
conciliation conference under which entered an Order November 4
Mother, who had moved n Florida, hathe d 2002 following an
cycle, one week of which was to be spent at the maternal physical cnstod agreement at a y of he
Partial custody during three weeks out ofteveChild and the
The Mother has relocated back to Pennsylia where she currently resides with her fin
Hill. The Father resides i n with Haven. van grandmother',; residence to ry Pennsyleightvaniaweek
Ma
.
arch 2002 and during a temporarily telephone
The Mother originally moved to Florida finance' in
Camp
and was living and during phone conciliation conference, indicated that she with her finance' in
friends. had enrolled in classes
Subsequently, the Mother deferred her educational plans to work in her finance's family business in
Florida. In December 2002, the Mother moved back to Pennsylvania where she is employed and rents
an apartment.
The Father requested a review of the custody arrangements as permitted in the prior Order.
Each party raised many concerns regarding the other parent's ability to properly care for the Child. It
appears that both counseling for both parenting skills and development of a co-parenting relationship
would be beneficial to the parties. The parties agreed to investigate the availability of both types of
counseling, although they have limited financial resources.
4. The parties were not able to reach an agreement as to ongoing custody arrangements for the
Child and it will be necessary to schedule a Hearing. As the parties raised many issues concerning the
Child's safety, it is requested that the hearing be expedited if possible.
5. The Mother's position on custody is as follows: The Mother believes that it would be in the
best interest of the Child to share custody on an alternating weekly basis. As the Mother is currently in
the last two weeks of her three week period of custody under the existing Order, she does not believe
that it would be good for the Child to then be transferred to the Father's primary custody pending the
Hearing. The Mother does not feel it is appropriate for the Father to have an evening period of custody
during her two week period as, according to her the Father did not allow her to see the Child for
several weeks when she had returned to Pennsylvania. The Mother objects to the babysitter which the
Father employs while he is at work and stated that she was unwilling to take the Child to the babysitter
if she were to have overnight weekday periods of custody. The Mother expressed many concerns
about the Father's ability to care for the Child including concerns regarding the Child's diet, toilet
training, and injuries from what the Mother believes to have been pet attacks. The Mother indicated
that she contacted the police in Florida to look at a rash on the Child's shoulder after the Father
transported the Child to her residence for her period of custody.
6. The Father's position on the custody is as follows: The Father believes that it would be in the
Child's best interest for him to have primary custody as he did dining five weeks of the eight week
cycle while the Mother was living in Florida. The Father stated that the Mother has been very unstable
since last March and has shown little concern for the Child's well being. According to the Father, the
Mother did not even advise him that she was in Pennsylvania until Christmas Eve and has only
contacted him two times, regarding the Child since she has been in Pennsylvania. According to the
Father, when the Child returns from visiting the Mother, the Child exhibits defiant behavior and tells
the Father that the Mother fiance' hits him. The Father expressed concerns regarding the Child's toilet
training and eating habits. The Father indicated that he may be agreeable to increasing the Mother's
periods of custody with the Child after she has demonstrated a more stable lifestyle. The Father
proposed that the Mother have periods of custody with the Child on alternating weekends and one
evening per week.
7. It was very difficult at the conference to sort through the accusations, multiple concerns and
contradictions in an effort to establish temporary arrangements pending the hearing. However based
on representations made by the parties during this conference and prior conferences, the conciliator
recommends an Order in the form as attached scheduling the Hearing and establishing interim custody
arrangements. It should be noted that the Mother strongly objects to the interim recommendations and
may request further review by the Court pending the Hearing. The Father also objected to portions of
the temporary arrangements, particularly the Sunday evening period of custody for the Mother.
The recommended arrangements appeared to be the best alternative to maintain some stability for the
Child in light of the Mother's recent frequent changes of circumstances and the steady schedule which
the Child has experienced during custodial periods with the Father under the prior Order.
?rvwu? -)q, C)03
Date
Dawn S. Sunday, Esquire
Custody Conciliator
Exhibit C
JOSHUA B. SINGER, : IN THE COURT OF COMMON PLEAS
Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 01-6599
KERI ANN CRAWFORD, : CIVIL ACTION
Defendant/Petitioner : CUSTODY
ORDER OF COURT
AND NOW, this day of , 2003, upon review of the
attached Petition for Modification of Custody and Relocation, it is hereby ORDERED and
DECREED that a hearing be held on the day of
2003 at
o'clock m. in Courtroom No. - of the Cumberland County
Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania.. It is further ORDERED and
that the parties shall alternate custody of the child on a weekly basis beginning
with July 4`h weekend with Mother until further Order of Court.
BY THE COURT:
J.
.JOSHUA B. SINGER, : IN THE COURT OF COMMON PLEAS
Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 01-6599
KERI ANN CRAWFORD, : CIVIL ACTION
Defendant/Petitioner :CUSTODY
PETITION FOR MODIFICATION F CUSTODY
AND RELOCATION
AND NOW, comes the Defendant/Petitioner, Keri Ann Crawford, nka Keri Ann
Torrent, by and through her attorney, Patricia J. Romano, Esquire, and respectfully files the
following Petition for Modification of Custody and Relocation:
1. Defendant/Petitioner, Keri Crawford Torrent (Mother), is an adult individual
temporarily residing at 25 N. 17`" St. Camp Hill, in Cumberland County, Pennsylvania. Her
permanent address is 6460 South East 174`h Place, Summerfield, Florida.
2. Plaintiff/Respondent, Joshua B. Singer (Father) is an adult individual residing
at 3050 Old Trail Road, York Haven, York County, Pennsylvania. He is represented by
Steven Howell, Esquire.
3. The parties are the parents of the natural child, Clay B. Singer, born May 9,
2003.
4. A Custody Order was entered by the Honorable Edward E. Guido on January
29, 2003. A copy is attached hereto as Exhibit A.
a. The Order was intended to be temporary in nature until the issue of the
minor child's custody could be heard on March 2Is', 2003. (Custody
Conciliation Summary Report (Exhibit B) at # 6)
b. Mother did not receive notice of the scheduled hearing and the custody
issue has not been heard by this Honorable Court.
5. Petitioner has married and permanently relocated to Florida and believes and
avers that relocation with Mother is in the best interest of the minor child.
a. Mother's life has stabilized and she can now provide a loving, nurturing
environment for Clay that would greatly improve his quality of life.
b. Mother has grave concerns about Father's ability to care for the child.
C. Mother does not act now nor has she ever acted to impede Father's
relationship with Clay. Father, however, has routinely deprived Mother
of access to their son.
d. A visitation schedule can be developed that fosters the current
father/son relationship. Mother proposes that child spend one week per
month with Father, with holidays alternated between the parties.
6. Because the matter of custody between the parties has not been heard by the
Court nor has a permanent custody arrangement ever been emplaced (Exhibit B), Mother
believes that the competing custodial environments should be scrutinized at hearing.
7. Because Petitioner is presently visiting her parents in Camp Hill and will
remain there until her Petition is decided, she believes that the best interest of the child will
be served if the parties alternate custody on a weekly basis during this time.
8. Because the relationship between the parties is unchanged since the 1/29/03
Order, Petitioner believes that further attempts at a conciliation conference would be
fruitless.
WHEREFORE, Petitioner prays that this Honorable Court promptly schedule a
hearing on the matter of custody and relocation and direct that the parties alternate custody
of the minor child on a weekly basis until the matter is decided.
Respectfully Submitted,
Patricia J. Konb, E:
4711 Locust L e
Harrisburg, PA 17109
(717) 657-0632
Id. No. 88161
Dated: (j
JOSHUA B. SINGER,
Plaintiff
V.
KERI ANN CRAWFORD,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-6599
CIVIL ACTION
CUSTODY
VERIFICATION
I verify that the statements made in the foregoing are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904
relating to unsworn falsification to authorities.
BY QjiI??l 2c(
Keri n Crawford, kna
Keri Ann Torrent
Date: ?3 4
Exhibit A
3. The party receiving custody shall be responsible to provide transportation for the exchange
of custody unless otherwise agreed.
4. The prior Order of this Court dated November 4, 2002 is vacated and replaced with this
Order.
BY THE COURT,
ice!
Edward E.Guido J.
cc: Diane G. Radcliff, Esquire, Counsel for Father ` "7? ,, o x.02
Douglas Miltenberger & Lucy Johnston-Walsh, Esquire, Counsel for Mother GdI
Exhibit B
JOSHUA B. SINGER,
Plaintiff
vs.
KERI ANN CRAWFORD
Defendant
PRIOR JUDGE: Edward E.Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-6599 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION S
U?ARY'REPORT
PROCEDURE ACCORDANCE WITH CUMBERLAND COUNTY RULE 1915.3-8, the undersigned Custody Conciliator submits the following report`
1
follows:
NAME
The pertinent information concerning the Child who is the subject of this litigation is as
Clay B. Singer
DATE OF BIRTg
CURRENTLY IN CUSTODY OF
May 9, 2000
Father
2. A Conciliation Conference was held on January
attendance: The Father, Joshua B. 23, 2003, with the following individuals in Singer,
with hi counsel, Mother, Keri Ann Crawford, with her counsel, Douglas - Radcliff, Esquire, and the
?ftltenbe gern
Esquire. and Lucy Johnston-Walsh,
3. This Court previousl
conciliation conference under y entered an Order on November 4, 200
Mother, w which the Father has following agreement at a
who had moved to Florida, had Primary physical custody
cycle, one week of which was to be spent aattl he custody during Y of the Child and the
The Mother , three weeks out of e
has relocated back to Pe maternal grandmother very eight week
's residence in
Hill. The Father resides in York ansYlvania where she currently resides with Pennsylvania.
March 2-002, and during Haven. The Mother originall her finance' in Camp
and was living temporarily
with telephone conciliation conference, indicated dthto Florida with at she had enrolled her finance' in
friends. in classes
Subsequently, the Mother deferred her educational plans to work in her finance's family business in
Florida. In December 2002, the Mother moved back to Pennsylvania where she is employed and rents
an apartment.
The Father requested a review of the custody arrangements as permitted in the prior Order.
Each party raised many concerns regarding the other parent's abiL:ty to properly care for the Child. It
appears that both counseling for both parenting skills and development of a co-parenting relationship
would be beneficial to the parties. The parties agreed to investigate the availability of both types of
counseling, although they have limited financial resources.
4. The parties were not able to reach an agreement as to ongoing custody arrangements for the
Child and it will be necessary to schedule a Hearing. As the parties raised manv issues concerning the
Child's safety, it is requested that the hearing be expedited if possible.
5. The Mother's position on custody is as follows: The Mother believes that it would be in the
best interest of the Child to share custody on an alternating weekly basis. As the Mother is currently in
the last two weeks of her three week period of custody under the existing Order, she does not believe
that it would be good for the Child to then be transferred to the Father's primary custody pending the
Hearing. The Mother does not feel it is appropriate for the Father to have an evening period of custody
during her two week period as, according to her the Father did not allow her to see the Child for
several weeks when she had returned to Pennsylvania. The Mother objects to the babysitter which the
Father employs while he is at work and stated that she was unwilling to take the Child to the babysitter
if she were to have overnight weekday periods of custody. The Mother expressed many concerns
about the Father's ability to care for the Child including concerns regarding the Child's diet, toilet
training, and injuries from what the Mother believes to have been pet attacks. The Mother indicated
that she contacted the police in Florida to look at a rash on the Child's shoulder after the Father
transported the Child to her residence for her period of custody.
6. The Father's position on the custody is as follows: The Father believes that it would be in the
Child's best interest for him to have primary custody as he did daring five weeks of the eight week
cycle while the Mother was living in Florida. The Father stated that the Mother has been very unstable
since last March and has shown little concern for the Child's well being. According to the Father, the
Mother did not even advise him that she was in Pennsylvania until Christmas Eve and has only
contacted him two times, regarding the Child since she has been in Pennsylvania. According to the
Father, when the Child returns from visiting the Mother, the Child exhibits defiant behavior and tells
the Father that the Mother fiance' hits him. The Father expressed concerns regarding the Child's toilet
training and eating habits. The Father indicated that he may be ageeable to increasing the Mother's
periods of custody with the Child after she has demonstrated a ore stable lifestyle. The Father
proposed that the Mother have periods of custody with the Child on alternating weekends and one
evening per week.
i. It was very difficult at the conference to sort through the accusations, multiple concerns and
contradictions in an effort to establish temporary arrangements pending the hearing. However based
on representations made by the parties during, this conference and prior conferences, the conciliator
recommends an Order in the form as attacced scheduling the Hearin, and establishing interim custody
arrangements. It should be noted that the Mother strongly objects to the interim recommendations and
may request further review by the Court pending the Hearing. The Father also objected to portions of
the temporary arrangements, particularly the Sunday evening period of custody for the Mother.
The recommended arrangements appeared to be the best alternative to maintain some stability for the
Child in light of the Mother's recent frequent changes of circumstances and the steady schedule which
the Child has experienced during custodial periods with the Father under the prior Order.
Date
Dawn S. Sunday, Esquire
Custody Conciliator
JOSHUA B. SINGER, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 01-6599
KERI ANN CRAWFORD, : CIVIL ACTION
Defendant :CUSTODY
CERTIFICATE OF SERVICE
AND NOW, this ilid- day of _, 2003, I, Katherine A. Frey,
V (j
secretary to Patricia J. Romano, Esquire, Attorney for the Defendant, hereby certifies that a
copy of the within document has been served upon Steven Howell, Esquire, attorney for the
Plaintiff, by depositing a copy of the same in the United States mail, first class, postage
prepaid, at Harrisburg, Pennsylvania, to the following addressee:
Steven Howell, Esquire
619 Bridge Street
New Cumberland, PA 17070
By:
Katherine A. Frey
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JOSHUA B. SINGER,
Plaintiff
V.
KERI ANN CRAWFORD,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-6599
: CIVIL ACTION
:CUSTODY
ANSWER TO PLAINTIFF'S
PRELIMINARY OBJECTION TO
DEFENDANT'S PETITION TO MODIFY CUSTODY
AND NOW, comes the Defendant, Keri Ann Crawford, nka Keri Ann Torrent, by and
through her attorney, Patricia J. Romano, Esquire, and respectfully files the following
Answer to Plaintiff's Preliminary Objections:
1. Admitted.
2. Denied. The Order of June 16, 2003 (Plaintiff's Exhibit A), reinstates the
Order of January 29, 2003, making the Order of January 29, 2003 the existing Custody
Order. The January 29, 2003 Order was attached to the Petition to Modify and Relocate as
Exhibit A.
3. Admitted.
4. Admitted. Both 23 Pa.C.S. §§ 5304 & 5310, authorize this Honorable Court,
in its discretion, to modify a custody order at any time to an order for shared custody in order
to serve the best interests of the child.
5. Denied. As requested by the Honorable Judge Guido and as legally required
to change an existing custody order, Defendant has filed a Petition to Modify and Relocate.
6. Admitted.
a. Defendant is without sufficient knowledge as to the truth to this
averment, and therefore it is neither admitted nor denied.
b. Defendant is without sufficient knowledge as to the truth to this
averment, and therefore, it is neither admitted nor denied.
7. Defendant is without sufficient knowledge as to the truth to this averment, and
therefore, it is neither admitted nor denied. Defendant notes that no such testimony was
heard.
8. Denied. Legally, Pa. R.C.P. 125 requires that all rules be "liberally construed
to secure just, speedy and inexpensive determination of every action." Factually, in the
Custody Conciliation Summary Report dated January 24, 2003 (Exhibit B of Defendant's
Petition to Modify and Relocate), Conciliator Dawn Sunday recommended that an expedited
hearing be scheduled to determine custody because the parties could not agree on custody
arrangements through conciliation. Therefore, proceeding to hearing absent additional
conciliation is factually and legally supported. Further, Plowman v. Plowman, 597 A.2d
701, 706 (Pa. Super. 1991) requires a hearing pursuant to a petition to relocate.
9. Denied. As outlined above, proceeding to hearing without further conciliation
is factually and legally justified and serves the best interests of the minor child by promptly
determining the appropriate custodial environment for him.
WHEREFORE, Defendant's Petition to Modify should be granted, promptly
scheduling a custody hearing and directing that the parties alternate custody on a weekly
basis until further order of this Honorable Court.
Respectfully Submitted,
J. Rom?gb, Esquire
4711 Locust Lade
Harrisburg, PA 17109
(717) 657-0632
Id. No. 88161
Dated:
JOSHUA B. SINGER, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 01-6599
KERI ANN CRAWFORD, : CIVIL ACTION
Defendant : CUSTODY
CERTIFICATE OF SERVICE
AND NOW, this day of 2003, I, Katherine A. Frey,
secretary to Patricia J. Romano, Esquire, Attorney for the Defendant, hereby certifies that a
copy of the within document has been served upon Steven Howell, Esquire, attorney for the
Plaintiff, by depositing a copy of the same in the United States mail, first class, postage
prepaid, at Harrisburg, Pennsylvania, to the following addressee:
Steven Howell, Esquire
619 Bridge Street
New Cumberland, PA 17070
By:
Katherine A. Frey
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JOSHUA B. SINGER, : IN THE COURT OF COMMON PLEAS
Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 01-6599
KERI ANN CRAWFORD, : CIVIL ACTION
Defendant/Petitioner :CUSTODY
ORDER OF COURT
AND NOW, this /VA day of 2003, upon review of the
attached Petition for Special Relief, it is heieby 091H Eft"a TIECREEMMs
HIMMatu-Mstudy ut [lie Mittel till 11 ppeemj' basis begiliffifir, plith kll? A d,
r e . It is further ORDERED and
DECREED that the non-custodial parent shall have liberal phone contact with the minor
child. 1 Ik 0'* 4.0,0 Aw- C.4-4c? e.# CCr
?+ 1 BY THE C RT:
J.
i VINVAIASNN-3d
85 :B RV 01 ifif CO
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JOSHUA B. SINGER, : IN THE COURT OF COMMON PLEAS
Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 01-6599
KERI ANN CRAWFORD, : CIVIL ACTION
Defendant/Petitioner :CUSTODY
PETITION FOR HEARING
AND NOW, comes the Defendant/Petitioner, Keri Ann Crawford, by and through her
attorney, Patricia J. Romano, Esquire, and respectfully avers as follows:
1. On 8/12/03, a Custody Conciliation Conference: was held before the Conciliator,
Dawn S. Sunday, Esquire. This Conciliation Conference was held pursuant to Defendant's Petition
for Modification of Custody and Relocation dated 6/27/03. A copy of said Petition for Modification
is attached hereto as Exhibit A.
2. At said Conciliation Conference, the parties were unable to come to an agreement
concerning the parties' minor son, Clay B. Singer, bom 5/9/00.
3. As per this Court's Order dated 3/7103, attached hereto as Exhibit B, the Court will
reschedule a hearing upon request of either party.
WHEREFORE, Defendant/Petitioner respectfully requests that this Honorable Court
schedule a hearing in this matter.
Respectfully
c
Patricia J. Romp
4711 Locust La
Harrisburg, PA
(717) 657-0632
Id. No. 88161
Dated: G?
JOSHUA B. SINGER, : IN THE COURT OF COMMON PLEAS
Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 01-6599
KERI ANN CRAWFORD, : CIVIL ACTION
Defendant/Petitioner : CUSTODY
ORDER OF COURT
AND NOW, this day of
2003, upon review of the
attached Petition for Modification of Custody and Relocation, it is hereby ORDERED and
that a hearing be held on the day of
o'clock m. in Courtroom No.
2003 at
of the Cumberland County
Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. It is further ORDERED and
DECREED that the parties shall alternate custody of the child on a weekly basis beginning
with July 4th weekend with Mother until further Order of Court.
BY THE COURT:
J.
JOSHUA B. SINGER,
Plaintiff/Respondent
V.
KERI ANN CRAWFORD,
Defendant/Petitioner
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 01-6599
: CIVIL ACTION
: CUSTODY
PETITION FOR MODIFICATION OF CUSTODY
AND RELOCATION
T - -
AND NOW, comes the Defendant/Petitioner, Keri Ann Crawford, nka Keri Ann
Torrent, by and through her attorney, Patricia J. Romano, Esquire, and respectfully files the
following Petition for Modification of Custody and Relocation:
1. Defendant/Petitioner, Keri Crawford Torrent (Mother), is an adult individual
temporarily residing at 25 N. 17" St. Camp Hill, in Cumberland County, Pennsylvania. Her
permanent address is 6460 South East 174" Place, Summerfield, Florida.
2. Plaintiff/Respondent, Joshua B. Singer (Father) is an adult individual residing
at 3050 Old Trail Road, York Haven, York County, Pennsylvania. He is represented by
Steven Howell, Esquire.
3. The parties are the parents of the natural child, Clay B. Singer, born May 9,
2003.
4. A Custody Order was entered by the Honorable Edward E. Guido on January
29, 2003. A copy is attached hereto as Exhibit A.
a. The Order was intended to be temporary in nature until the issue of the
minor child's custody could be heard on March 21", 2003. (Custody
Conciliation Summary Report (Exhibit B) at # 6)
b. Mother did not receive notice of the scheduled hearing and the custody
issue has not been heard by this Honorable Court.
5. Petitioner has married and permanently relocated to Florida and believes and
avers that relocation with Mother is in the best interest of the minor child.
a. Mother's life has stabilized and she can now provide a loving, nurturing
environment for Clay that would greatly improve his quality of life.
b. Mother has grave concerns about Father's ability to care for the child.
C. Mother does not act now nor has she ever acted to impede Father's
relationship with Clay. Father, however, has routinely deprived Mother
of access to their son.
d. A visitation schedule can be developed that fosters the current
father/son relationship. Mother proposes that child spend one week per
month with Father, with holidays alternated between the parties.
6. Because the matter of custody between the parties has not been heard by the
Court nor has a permanent custody arrangement ever been emplaced (Exhibit B), Mother
believes that the competing custodial environments should be scrutinized at hearing.
1)
7. Because Petitioner is presently visiting her parents in Camp Hill and will
remain there until her Petition is decided, she believes that the best interest of the child will
be served if the parties alternate custody on a weekly basis during this time.
8. Because the relationship between the parties is unchanged since the 1/29/03
Order, Petitioner believes that further attempts at a conciliation conference would be
fruitless.
WHEREFORE, Petitioner prays that this Honorable Court promptly schedule a
hearing on the matter of custody and relocation and direct that the parties alternate custody
of the minor child on a weekly basis until the matter is decided.
Respectfully Submitted,
Dated: (J
Patricia J. Ro t)6, Esquire
4711 Locust Lbde
Harrisburg, PA 17109
(717) 657-0632
Id. No. 88161
JOSHUA B. SINGER, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 01-6599
KERI ANN CRAWFORD, : CIVIL ACTION
Defendant : CUSTODY
D i_.I KI V
I verify that the statements made in the foregoing are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904
relating to unworn falsification to authorities.
KeriXnn Crawford, kna
Keri Ann Torrent
i
Date:
' ?3?
Exhibit A
JOSHUA B. SINGER,
Plaintiff
vs.
KERI ANN CRAWFORD
Defendant
PRIOR JUDGE: Edward E. Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PEN-NSYLVANIA
01-6590
CIVIL ACTION LAW
[N CUSTODY
ORDER OF COURT
AND NOW, this a 5 *A day of ? 2003, upon
consideration of the attached Custody Conciliation eport'R , it is ordered and directed as follows:
jr- Go 9. /.5 A /yj
1. A Hearing is scheduled in Courtroom No. _ of the Cumberland County
Court House on the day of /YIAi00003, at which time testimony will
be taken. For purposes of the Hearing, the Father shall be deemed to be the moving party and shall
proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel
a memorandum setting forth each party's position on custody, a list of witnesses who are expected to
testify at the Hearing, and a summary of the anticipated testimony of each witness. These memoranda
shall be filed at least ten days prior to the Hearing date.
2. Pending further Order of Court or agreement of the parties, the parties shall have shared
legal custody of Clay B. Singer, bom May 9, 2000, the Father shall have primary physical custody, and
the Mother shall have partial physical custody of the Child. The Mother shall have continuous custody
of the Child through February 6, 2003 between 5:00 pm and 6:00 pm, when the Father shall pick up
the Child. Prior to February 6, the Father shall have an interim period of custody on one weekday
evening from between 5:00 and 6:00 pm until 8:00 pm, with the specific date to be arranged by
agreement of the parties. Thereafter, beginning on February 14, 2003, the Mother shall have custody
of the Child on altemating weekends from Friday between 5:00 and 6:00 pm through Sunday at 8:00
pm. During the interim weekends, the Mother shall have custody of the Child on Sunday from 1:00
pm until 8:00 pm with the exception that the Father shall have the option of preempting the Mother's
Sunday afternoon ! evening period of custody two times pending the Hearing upon providing at least
one week advance notice to the Mother. In the event the Father exercises his right to custody on
Sunday, arrangements shall be made for a substitute period of custody for the Mother on either the
Wednesday immediately preceding or following the Sunday from between 5:00 and 6:00 pm through
8:00 pm. The Mother shall have custody of the Child on Easter Sunday from 1:00 pm until 8:00 pm.
3. The party receiving custody shall be responsible to provide transportation for the exchange
of custody unless otherwise agreed.
4. The prior Order of this Court dated November 4, 2002 is vacated and replaced with this
Order.
BY THE"COURT,-
Edward E.Guido J.
cc: Diane G. Radcliff, Esquire, Counsel for Father • ? ? 1. o y. 02
Douglas Miltenberger & Lucy Johnston-Walsh, Esquire, Counsel for Mother ?'
Exhibit B
JOSHUA B. SINGER,
Plaintiff
vs.
KERI ANN CRA WFOP
Defendant
PRIOR JUDGE: Edward E.Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PEN i SYLVANLa
01-6599 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUM1?Ry REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVII,
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
follows: !' The pertinent information concerning the Child who is the subject of
J this litigation is as
NAME
DATE OF BIRTH CURRENTLY IN CUSTODY OF
Clay B. Singer
May 9, 2000
Father
2. A Conciliation Conference was held on January 23, 2003, with the following individuals in
attendance: The Father, Joshua B. Singer, with his counsel, Diane G. Mother, Keri Ann Crawford, with her counsel, Douglas ounseber?
Radcliff, Esquire, and the
Esquire. Miltenberger, and Lucy Johnston-Walsh,
3. This Court previously entered an Order on November 4
conciliation conference under which the Father has
Mother, w 00_ following an agreement at a
who had moved to Florida, had Primary physical custody
cycle, one week of Partial custod during
three Out of Y of [eChild and the
The Mother has relocated back to Pe very eight week
which was to be spent at the maternal grandmother'slres denceinPennsylvania.
Hill. The Father resides in York Hnnsylvanta where she currently resides witfinance' in Camp
(arch 2002, and during Haven The h her originally moved to Florida with her finance' in
and was living a telephone conciliation conference, indicated that she had
temporarily with friends. enrolled in classes
Subsequently, the Mother deferred her educational plans to work to her finance's family business in
Florida. In December 2003, the Mother moved back to Pennsylvania where she is employed and rents
an apartment.
The Father requested a review of the custody arrangements as permitted in the prior Order.
Each party raised many concerns regarding the other parent's ability to properly care for the Child. It
appears that both counseling for both parenting skills and development of a co-parenting relationship
would be beneficial to the parties. The parties agreed to investigate the availability of both types of
counseling, although they have limited financial resources.
4. The parties were not able to reach an agreement as to ongoing custody arrangements for the
Child and it will be necessary to schedule a Hearing. As the parties raised many issues concerning the
Child's safety, it is requested that the hearing be expedited if possible.
5. The Mother's position on custody is as follows: The Mother believes that it would be in the
best interest of the Child to share custody on an alternating weekly basis. As the Mother is currently in
the last two weeks of her three week period of custody under the existing Order, she does not believe
that it would be good for the Child to then be transferred to the Father's primary custody pending the
Hearing. The Mother does not feel it is appropriate for the Father to have an evening period of custody
during her two week period as, according to her the Father did not allow her to see the Child for
several weeks when she had returned to Pennsylvania. The Mother objects to the babysitter which the
Father employs while he is at work and stated that she was unwilling to take the Child to the babysitter
if she were to have overnight weekday periods of custody. The Mother expressed many concerns
about the Father's ability to care for the Child including concerns regarding the Child's diet, toilet
training, and injuries from what the Mother believes to have been pet attacks. The Mother indicated
that she contacted the police in Florida to look at a rash on the Child's shoulder after the Father
transported the Child to her residence for her period of custody.
6. The Father's position on the custody is as follows: The Father believes that it would be in the
Child's best interest for him to have primary custody as he did during five weeks of the eight week
cycle while the Mother was living in Florida. The Father stated that the Mother has been very unstable
since last March and has shown little concern for the Child's well being. According to the Father, the
Mother did not even advise him that she was in Pennsylvania until Christmas Eve and has only
contacted him two times, regarding the Child since she has been in Pennsylvania. According to. the
Father, when the Child returns from visiting the Mother, the Child exhibits defiant behavior and tells
the Father that the Mother fiance' hits him. The Father expressed concems regarding the Child's toilet
training and eating habits. The Father indicated that he may be agreeable to increasing the Mother's
periods of custody with the Child after she has demonstrated a more stable lifestyle. The Father
proposed that the Mother have periods of custody with the Child on alternating weekends and one
evening per week.
7. It was very difficult at the conference to sort through the accusations, multiple concerns and
contradictions in an effort to establish temporary arrangements pending the hearing. However based
on representations made by the parties during this conference and prior conferences, the conciliator
recommends an Order in the form as attached scheduling the Hearing and establishing, interim custociv
arrangements. It should be noted that the Mother strongly objects to the interim recommendations and
may request further review by the Court pending the Hearing. The Father also objected to portions of
the temporary arrangements, particularly the Sunday evening period of custody for the Mother.
The recommended arrangements appeared to be the best alternative to maintain some stability for the
Child in light of the Mother's recent frequent changes of circumstances and the steady schedule which
the Child has experienced during custodial periods with the Father under the prior Order.
; FCy3
Date
Dawn S. Sunday, Esquire
Custody Conciliator
JOSHUA B. SINGER,
Plaintiff
V.
KERI ANN CRAWFORD,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-6599
: CIVIL ACTION
:CUSTODY
CERTIFICATE OF SERVICE
AND NOW, this R??day of 2003, I, Katherine A. Frey,
61
secretary to Patricia J. Romano, Esquire, Attorney for the Defendant, hereby certifies that a
copy of the within document has been served upon Steven Howell, Esquire, attorney for the
Plaintiff, by depositing a copy of the same in the United States mail, first class, postage
prepaid, at Harrisburg, Pennsylvania, to the following addressee:
Steven Howell, Esquire
619 Bridge Street
New Cumberland, PA 17070
By: J
Katherine A. Frey
Exhibit B
JOSHUA B. SINGER IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
KERI A. CRAWFORD NO, 2001-6599 CIVIL TERM
ORDER OF CO JLRT
AND NOW, this n day of MARCH, 2003, a Rule is Issued upon defendant
Keri A. Crawford to Show Cause why the Family Law Clinic should not be allowed
to withdraw as her counsel.
Said Rule is returnable twenty (20) days after service.
With the concurrence of Plaintiff's counsel, the hearing scheduled in this
matter for March 21, 2003, at 9:30 a.m. is continued to allow for the resolution
of this matter and to allow defendant to obtain alternate counsel, if necessary.
We will reschedule the hearing upon request of either party.
Diane Radcliff, Esquire
Family Law Clinic
Lucy Johnston-Walsh, Esquire
:sid
t SUIE GQrsY {r ;.,,.;u ; my Lana
le i3. l
nd the t al w-• h
of-A? day
Mot',^•?c'".'w
Edward E. Guido, J.
JOSHUA B. SINGER, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 01-6599
KERI ANN CRAWFORD, : CIVIL ACTION
Defendant :CUSTODY
CERTIFICATE OF SERVICE
AND NOW, this day of 2003, I, Katherine A. Frey,
secretary to Patricia J. Romano, Esquire, Attorney for the Defendant, hereby certifies that a
copy of the within document has been served upon Steven Howell, Esquire, attorney for the
Plaintiff, by depositing a copy of the same in the United States mail, first class, postage
prepaid, at Harrisburg, Pennsylvania, to the following addressee:
Steven Howell, Esquire
619 Bridge Street
New Cumberland, PA 17070
By.-`
Katherine A. Frey
1
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:f CD -G
JOSHUA B. SINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. 01-6599 CIVIL ACTION LAW
KERI ANN CRAWFORD
Defendant IN CUSTODY
PRIOR JUDGE: Edward E. Guido
ORDER OF COURT
AND NOW, this ?? day of At-y? , 2003, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. Pending further Order of Court or agreement of the parties, the parties shall have shared
legal custody of Clay B. Singer, born May 9, 2000, the Father shall have primary physical custody, and
the Mother shall have partial physical custody for one full week each month, which shall be scheduled
to accommodate the Mother's work schedule as much as possible. The Mother shall not remove the
Child from the Commonwealth of Pennsylvania during her periods of custody.
2. The Father shall ensure that the Child is available to receive telephone calls from the Mother
every Wednesday and Sunday at 7:00 pm. The Mother shall be entitled to have liberal and reasonable
telephone contact with the Child at other times when the Child is available.
3. The Father shall cooperate in making the Child available for any appointments scheduled by
the Mother for the Child with a counselor, physician or other professional to assess the Mother's
concerns regarding care of the Child. The Mother may make arrangements for the maternal
grandparents to provide transportation ,for scheduled appointments. Tie
Edward E.Guido J.
cc: Patricia Romano Esquire, Counsel for Mother 8 1 G 3
Steven Howell, Esquire, Counsel for Father
U.,?, ??birZ1S?UNjd,rtlJ
81 .? k??rsZ 9(J? £?
d?? ? .,, : , yp
3J'a t
C ? I:,
JOSHUA B. SINGER,
Plaintiff
VS.
KERI ANN CRAWFORD
Defendant
PRIOR JUDGE: Edward E.Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-6599 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Clay B. Singer
May 9, 2000
Father
2. A Conciliation Conference was held on August 12, 2003, with the following individuals in
attendance: The Father, Joshua B. Singer, with his counsel, Steven Howell, Esquire, and the Mother's
counsel, Patricia Romano, Esquire. The Mother, Keri Ann Crawford, currently resides in Florida and
participated in the conference by telephone.
3. This Court previously entered an Order on November 4, 2002 based on the parties'
agreement at a conciliation conference under which the Father had primary physical custody of the
Child and the Mother, who had moved to Florida, had partial custody during three weeks out of every
eight week cycle, one week of which was to be spent at the maternal grandmother's residence in
Pennsylvania. A subsequent conciliation conference was held on January 23, 2003, by which time the
Mother had relocated back to Pennsylvania where she was residing with her fianc6 in Camp Hill. The
Father has continued to reside in York Haven throughout these proceedings.
The parties were not able to reach an agreement as to ongoing custody arrangements at the
January conference and a hearing was scheduled for March 21, 2003. The Mother's counsel, the
Family Law Clinic, withdrew from representation with approval of the Court and the March hearing
was continued by this Court's Order dated March 17, 2003 to allow the Mother to obtain alternate
counsel. The Order provided that the hearing would be rescheduled upon the request of either party.
The Mother subsequently filed a Petition for Modification / Relocation and a Petition for
Special Relief for interim arrangements pending a hearing, all of which were the subjects of the
conciliation conference on August 12, 2003.
4. As the Court previously continued the March 21, 2003 hearing and expressly provided that it
was to be re-scheduled upon the request of either party, it was determined at the conference that the
Mother's counsel would contact the Court to obtain the rescheduled hearing. The issues for
determination continue to be primary physical custody of the Child and partial custody arrangements
for the non custodial parent. The only new development is that the Mother has again moved to Florida
and has married her fiance.
5. The Mother's position on custody is as follows: The Mother believes that it would be in the
best interest of the Child to share custody on an alternating monthly basis as the Mother currently
resides in Florida and the Father resides in Pennsylvania. The Mother expressed many concerns about
the Father's ability to care for the Child, including concerns regarding the Child's diet and overall care.
The Mother allegesthat the Child indicated the Father has touched him inappropriately. Although
Children and Youth Services conducted an investigation at the Mother's request on the allegations
which resulted in a finding that the allegations were unfounded, the Mother believes that a more
thorough examination of the Child by a physician or therapist is necessary. At the time of the prior
conference in January 2003, the Mother expressed concern that the Child had received injuries from
what the Mother believed to have been pet attacks at the Father's residence. Also in January the
Mother indicated that she contacted the police in Florida to investigate a rash on the Child's shoulder
after the Father's period of custody. During June 2003, when the Mother was temporarily in
Pennsylvania, the Mother notified local authorities of her concerns that the Child was inadequately
nourished and exposed to unclean conditions at the Father's residence. For all the forgoing reasons,
the Mother believes that she is the parent who is better able to provide appropriate care for the Child as
primary custodian.
6. The Father's position on custody is as follows: The Father believes it would be in the
Child's best interest to continue to reside primarily with the Father in Pennsylvania. The Father
expressed concern about the Mother's instability in relocating back and forth between Pennsylvania
and Florida and indicated that he has no information concerning the Mother's residence in Florida.
The Father stated that when he attempts to contact the Mother by telephone in Florida, he reaches a
business number. The Father adamantly denied all of the Mother's allegations regarding inadequate
care for the Child, including inappropriate touching and the other allegations concerning the Child's
physical well-being. The Father believes that the Mother is making false allegations to the authorities
in order to obtain custody and terminate her support obligations. Although the Father agrees to the
Mother having custodial time with the Child in Pennsylvania pending the hearing, the Father expressed
serious concerns about the Child traveling to Florida for custodial periods. The Father suspects that the
Mother will make false allegations to authorities in Florida which will result in proceedings detaining
the Child in Florida until the issues are resolved.
7. As in the prior conference in January, it was very difficult to sort through the accusations,
multiple concerns and contradictions in an effort to establish temporary arrangements pending the
hearing. However, based on the representations made by the parties during this conference and
developments which have occurred since the January conference, the conciliator recommends an Order
in the form as attached providing for the Mother to have partial custody in Pennsylvania. It should be
noted that the Mother strongly objects to the recommendation that the Child remain in the
Commonwealth pending the hearing. However, these arrangements appear to be the best alternative to
maintain stability for the Child and to prevent duplicative proceedings in another jurisdiction.
Although the Mother has a place to stay at her parents' home in Pennsylvania, the Mother indicated it
would be difficult for her to take additional time off from employment in her father-in-law's business
and, therefore, the Mother requests that the hearing be expedited as much as possible.
2-00 3
Date Dawn S. Sunday, Esqu
Custody Conciliator
JOSHUA B. SINGER, : IN THE COURT OF COMMON PLEAS
Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA
V : NO. 01-6599
KERI ANN CRAWFORD, : CIVIL ACTION
Defendant/Petitioner :CUSTODY
ORDER OF COURT
day of r , 2003, upon review of the
AND NOW, this ?? -
attached Petition for Hearing, it is hereby ORDERED that, a custody hearing is scheduled
on the,_.304day ofQ 2003 at 9.30 o'clockAL.m. at the Cumberland
Carlisle,
County Courthouse, One Courthouse Square, Courtroom Number ,
Pennsylvania.
J•
6'q" -9
? `r
0%
VINVAIAPNN3d
iS:S HIV 6Z OIN ?o
JOSHUA B. SINGER, IN THE COURT OF COMMON PLEAS SEP 0 5 1003
PLAINTIFF CUMBERLAND COUNTY,
PENNSYLVANIA
V.
NO. 01 - 6599
KERI ANN CRAWFORD,
DEFENDANT CIVIL ACTION - CUSTODY
ORDER OF COURT
AND NOW, this ir? Itay of 12003 it is hereby ORDERED
DEN i
that Plaintiffs Continuance Request is iievi A. ust
ear
on easasse tortn in hxlii i o ai s
003
r
.
BY T RT:
Edward 1.. Guido, Judge
CERTIFIED COPIES TO:
teven Howell, Esquire
619 Bridge Street
New Cumberland, PA 17070
/Patricia J. Romano, Esquire
4711 Locust Lane
Harrisburg, PA 17109
?RKs
05"?$
?nNWIAsNtQd
/UM , a??
JOSHUA B. SINGER,
Plaintiff/Respondent
V.
KERI ANN CRAWFORD,
Defendant/Petitioner
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 01-6599
CIVIL ACTION
:CUSTODY
MOTION TO QUASH SUBPOENA
AND NOW, comes the Defendant/Petitioner, Keri Ann Crawford, nka Keri Ann
Torrent, by and through her attorney, Patricia J. Romano, Esquire, and respectfully files the
following Motion to Quash Subpoena:
1. On 8/28/03, this Honorable Court issued an Order scheduling a custody hearing
for 10/13/03 at 9:30 a.m. See Exhibit A.
2. On 9/26/03, a subpoena was issued to "Thomas Place, Esquire, Robert Rains,
Esquire or their designee with personal knowledge of the Family Law Clinic's
Representation in the above captioned case," to testify and to bring with them all records
concerning Clay B. Singer or Keri Ann Crawford. See Exhibit B.
3. The Family Law Clinic represented Defendant, Keri Crawford (Torrent) until
4/4/03 when the Clinic's Petition to Withdraw was granted. See Exhibit C.
4. Any information the Clinic has regarding Defendant is protected by attorney/
client privilege.
5
6.
privilege.
Defendant has not waived this attorney/client privilege.
To allow testimony by the Clinic or its representatives would violate this
WHEREFORE, Defendant respectfully requests this Honorable Court to grant the
Motion to Quash Subpoena.
Respectfully Submitted,
0
Dated: O
4?=I-
Patricia J. Roman
4711 Locust Lane
Harrisburg, PA 1'7
(717) 657-0632
Id. No.
JOSHUA B. SINGER, : IN THE COURT OF COMMON PLEAS
Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 01-6599
KERI ANN CRAWFORD, : CIVIL ACTION
Defendant/Petitioner : CUSTODY
VERIFICATION
I verify that the statements made in the foregoing are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904
relating to unsworn falsification to authorities.
By
Date:
Exhibit A
!1 ::?]JI !1'?A°--ur? aV, iL A'V'.??t?sd ??iy iu?r vac=
ATTORNEY AT LAW
471 1 Locust Lane .-
Harrisburg, PA 17109
(717)657-0632 Fax:(717)657-1512
AUG 2 6 2333 I
JOSHUA B. SINGER, : IN THE COURT OF COMMON PLEAS
Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 01-6599
KERI ANN CRAWFORD, : CIVIL ACTION
Defendant/Petitioner :CUSTODY
ORDER OF COURT
AND NOW, this Qt??day of
2003, upon review of the
-17
AuSa4
attached Petition for Hearing, it is hereby ORDERED that a custody hearing is scheduled
on the /-V "day of , 2003 at 9=3d o'clockA-.m. at the Cumberland
County Courthouse, One Courthouse Square, Courtroom Number S, Carlisle,
Pennsylvania.
J.
Exhibit B
, -rI -
JOSHUA F3. SINGER,
PLAINTIF?
VS.
KERI ANN C'RAWFORD,
DEFENDANT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
2001-659'j
File No.
SUBPOENA TO ATTEND AND TESTIFY
THOMAS PLACE, ESQUIRE, ROBERT RAINS, ESQUIRE OR
TO' THEIR -DESIGNEE WITH PF.R DfiAL KNaKLFZGF,••OF 'PHE p!AXILY T AW Cr, iNTCS
REPRESENTATION IN THE ABOVE CAPTIONED CASE.
/ Orr°tFEiRYfh-P?-3 -• - ----
CARLISLE PA 17013
1 You are ordered by the court to come to CUMBERLAND COUNTY COURTHOUSE
-
COURTROOM N 5
(Specify courtroom or other place)
Carlisle Cumberland
at County, Pennsylvania, on October-1-3, 2003
at : 30 o'clock,_ A. M., to testify on behalf of
Plaintiff
in the above case, and to remain until excused.
2 And bring with you the following:
Ar.L RECORDS CONCERNING CLAY B. SINGER OR KERI ANN CRAWFORD
It you fail to attend or to produce the documents or things required by this subpoena, you may be subject to
the sanctions authorized by Rule 234.5 of the Pennsylvania Rules of Civil Procedure, including but not
limited to costs, attorney fees and imprisonment
REQUESTED BY A PARTY/ATTORNEY IN COMPLIANCE WITH Pa. R. C. P. No. 234.21
Name: Steven Howell, Esquire
Address: 619 Bridge Street
New Cumberland, PA 17070
Teleprone 770-1277
Sup ?:,te C,)w! ID a 61063
--
Care _
Seal of Iho cowl --
BN1 T/H?- COU'R?i
? PrGfhOnOtdryiC!er?, ?rd?! n G^
Ott.c,al Note. This fora, of subpoena shall be used whenever 3 >-,uopioena 's issuabie..ncludinq neann-s r,
onnectien with 7epositions and before arbitrators, masters, commissioners, etc, in compliance vith Pa. R, C.
No 234 1 it a subpoena for e production of (JCCUments, records or things is desired. complete paragrapn
F"H 7 ?'-,
Exhibit C
APR 0 2 2003
JOSHUA B. SINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION -LAW
IN CUSTODY
KERI A. CRAWFORD,
Defendant NO. 01 - 6599 CIVIL TERM
ORDER OF COURT
AND NOW, this day ofx 2003, upon presentation and
consideration of the within Petition to Make Rule Absolute, the Rule entered by Order on March 7,
2003, is hereby made ABSOLUTE and Petitioner, the Family Law Clinic, is permitted to
withdraw as counsel for Defendant, Keri A. Crawford.
J.
JOSHUA B. SINGER IN THE COURT OF COMMON PLEAS OF
V. CUMBERLAND COUNTY, PENNSYLVANIA
.
KERI A. CRAWFORD NO, 2001-6599 CIVIL TERM
ORDER OF COURT
AND NOW, this 7T" day of MARCH, 2003, a Rule is issued upon defendant
Ked A. Crawford to Show Cause why the Family Law Clinic should not be allowed
to withdraw as her counsel.
Said Rule is returnable twenty (20) days after :service.
With the concurrence of Plaintiff's counsel, the hearing scheduled in this
matter for March 21, 2003, at 9:30 a.m. is continued to allow for the resolution
of this matter and to allow defendant to obtain alternate counsel, if necessary.
We will reschedule the hearing upon request of either parry.
Diane Radcliff, Esquire
Family Law Clinic
Lucy Johnston-Walsh, Esquire
sid
{ x1 .( --
ry
Edward E. Guido, J.
JOSHUA B. SINGER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION-LAW
IN CUSTODY
KERI A. CRAWFORD, 4
Defendant NO. 01 - 6599 CIVIL TERM
n.
PETITION TO MAKE RULE ABSOLUTE
y.,
L- ,_.
AND NOW, comes petitioner, the Family Law Clinic, and petitions the court fol"$:
1. Petitioner, the Family Law Clinic, is counsel of record for the above-named
Defendant, Keri A. Crawford.
2. Petitioner filed a Petition for Rule to Show Cause for Leave to Withdraw in this
matter on March 6, 2003. On March 7, 2003, this Court issued an Order of Court for Ms. Crawford
to show cause why the Family Law Clinic should not be permitted to withdraw.
A copy of the Petition for Rule to Show Cause for Leave to 'Withdraw and Order of Court are
attached.
3. The March 7, 2003 Order of Court permitted Ms. Crawford to object to the
Family Law Clinic's request to withdraw within twenty (20) days after service.
4. A true and correct copy of the Petition for Rule to Show Cause for Leave to Withdraw
and the Order of Court was served upon Defendant, Keri A. Crawford, by first class mail, postage
prepaid, at 3524 September Drive, #1, Camp Hill, PA 17011, on March 10, 2003.
5. A true and correct copy of the Petition for Rule to Show Cause for Leave to Withdraw
and the Order of Court was served upon Plaintiffs attorney, Diane Radcliff, by first class mail,
postage prepaid, at 3448 Trindle Road, Camp Hill, PA 17011 on March 10, 2003.
6. Twenty (20) days have passed since the Rule was served upon the Respondent
and Plaintiff s counsel, and no response or objection has been filed.
WHEREFORE, the Family Law Clinic requests this Court to enter an Order permitting the
Family Law Clinic to withdraw as counsel for Keri A. Crawford in this matter.
Date: L
r ? l
/Douglas 'A. Miltenberger
Certified Legal Intern
HOM LACE
ROBERT E. RAINS
LUCY JOHNSTON-WALSH
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
JOSHUA B. SINGER,
Plaintiff
V.
KERI ANN CRAWFORD,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-6599
CIVIL ACTION
CUSTODY
CERTIFICATE OF SERVICE
AND NOW, this (;? day of 2003, I, Katherine A. Frey,
secretary to Patricia J. Romano, Esquire, Attorney for the Defendant, hereby certifies that a
copy of the within document has been served upon Steven Howell, Esquire, attorney for the
Plaintiff, by depositing a copy of the same in the United States mail, first class, postage
prepaid, at Harrisburg, Pennsylvania, to the following addressee:
Steven Howell, Esquire
619 Bridge Street
New Cumberland, PA 17070
By:?Aa-..s-
Katherine A. Frey
c. ;:' c?
l
2 ? 7 ?
nor:; :.
/
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-:
-
G'? .: t _
` fJ :;)
JOSHUA B. SINGER,
Plaintiff
v
KERI ANN CRAWFORD,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO.2001- 6599 CIVIL ACTION - LAW
MOTION TO QUASH SUBPOENA
Thomas Place, Esquire and Robert Rains, Esquire along with the Family Law Clinic of the
Dickinson School of Law of the Pennsylvania State University by their attorneys, Broujos
& Gilroy, P.C., sets forth the following:
1
A custody hearing is scheduled in the above case before the Honorable Edward E. Guido
for Monday, October 13, 2003 at 9:30 a.m.
2
A subpoena was issued by Plaintiff to Thomas Place, Esquire and Robert Rains, Esquire
directing them or their designee to appear to testify at the said hearing and to bring all
records concerning the parties to the above hearing. Attached hereto and marked Exhibit
"A" is a copy of the subpoena issued in the above matter.
3
The Family Law Clinic of the Dickinson School of Law of the Pennsylvania State
University previously represented Keri Ann Crawford.
4
Any information Attorney Place, Attorney Rains or the Dickinson School of Law of the
Pennsylvania State University Family Law Clinic would have concerning this case is
protected by the attorney/client privilege and Defendant has not waived this privilege. In
fact, Defendant's counsel has also filed a Motion to Quash the Subpoena. Pennsylvania
Rules on Evidence 501 provides that privileges such as the attorney/client privilege is
unaffected by the adoption of the Rules on Evidence.
WHEREFORE, Petitioners request your Honorable Court to quash the subpoena issued in
this matter.
Respectfully submitted,
Hubert X. ilro;y, Esquire
Attorney or Petitioners
Broujos & Gilroy, P.C.
4 North Hanover Street
Carlisle, PA 17013
(717) 243-4574
Supreme Court ID No. 29943
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
JOSHUA B. SINGER,
PLAINTIFF
VS.
KF.RI ANN CRAWFORD,
DEFENDANT
File No.
2001-6599
SUBPOENA TO ATTEND AND TESTIFY
THOMAS PLACE, ESQUIRE, ROBERT RAINS, ESQUIRE OR
TO: THEIR DE$TQ.NPP WITH PF.RRnx T. KNnwr Fnr:F OF Trt'I< rAJ. * hX 'IT INK'S
REPRESENTATION IN THE ABOVE CAPTIONED CASE.
4-5-NORTH PITT STREET
CARLISLE PA 17013 -
You are ordered by the court to Come to
COURTROOM # 5
CUMBERLAND COUNTY COURTHOUSE
Carlisle
at
at 9:30
Plaintiff
2.
(Specify court,oom or other place)
Cumberland __ County, Pennsylvania, on ,.,UCtober, 1 3, 2003
__M., to testify on behalf of
o'clock, __.I.
ALL RECORDS CONCERNING CLAY B. SINGER OR KERI ANN CRAWFORD
in the above case, and to remain until excused.
And bring with you the following:
If you fail to attend or to produce the documents or things required by this subpoena, you may be subject to
the sanctions authorized by Rule 234.5 of the Pennsylvania Rules of Civil Procedure, including but not
limited to costs, attorney fees and imprisonment.
REOUESTED BY A PARTY/ATTORNEY IN COMPLIANCE WITH Pa. R C. P No. 234.2(a):
Name. -Steven Howell, Esquire
Address: 619 Bridge Street
Now Cumbor.land, Ph 17070
Telephone:_. 770-1277 __ -
Supreme Court 10 # 62063
Date del' I
Sea of the Court
BY THTH COUR
Prothonotary/Clerk, Civil i on
L
Deputy
Official Note: This form of subpoena shall be used whenever a subpoena is issuable, including hearings in
connection with depositions and before arbitrators, masters, commissioners, etc. in compliance with Pa. R. C.
P. No. 234.1, if a subpoena for a production of documents, records or things is desired, complete paragraph
2
(Eil. 7/97)
11 EXHIBIT
c y( ,, J
JOSHUA B. SINGER,
Plaintiff
v
KERI ANN CRAWFORD,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001- 6599
COURT ORDER
CIVIL ACTION - LAW
AND NOW, this gA day of October, 2003, upon review of the attached
Motion to Quash, it is hereby ordered that the Subpoena issued to Thomas Place, Esquire,
Robert Rains, Esquire and the Family Law Clinic of the Dickinson School of Law of the
Pennsylvania State University is hereby quashed.
BY
By
cc: Hubert X. Gilroy, Esquire
Attorney for Petitioners
Steven Howell, Esquire
Attorney for Plaintiff
Patricia J. Romano, Esquire
Attorney for Defendant
Edward E. Guido
J.
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JOSHUA B. SINGER,
PLAINTIFF
V.
KERI ANN CRAWFORD,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 01 - 6599
CIVIL ACTION - CUSTODY
ANSWER WITH NEW MATTER TO DEFENDANT'S MOTION TO
QUASH SUBPOENA
TO: Defendant Keri Ann Crawford
c/o Patricia J. Romano, Esquire
4711 Locust Lane
Harrisburg, PA 17109
NOTICE TO PLEAD
YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED
NEW MATTER WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A
JUDGMENT MAY BE ENTERED AGAINST YOU.
1. ADMITTED.
2. DENIED. THE SUBPOENA WAS SERVED OCTOBER 6, 2003.
3. ADMITTED.
4. DENIED FOR THE REASONS SET FORTH IN NEW MATTER.
5. DENIED FOR THE REASONS SET FORTH IN NEW MATTER.
6. DENIED FOR THE REASONS SET FORTH IN NEW MATTER.
NEW MATTER
7. It is believed that the Defendant in this case will argue on October 13, 2003 that
she was unaware of this Court's January 23, 2003 Order granting Father primary custody in this
case and that she did not receive a copy of the Order from her then counsel, the Family Law
Clinic. It is expected that Father will present testimony from Detective Martz and Cathy Lyman
(CYS Caseworker) that the Defendant claimed there was no custody order in effect when she
removed the child from Father in early June 2003.
8. It is believed that the Defendant in this case will argue on October 13, 2003 that
she was unaware of this Court's March 21, 2003 custody trial or the March 7, 2003 Order.
9. It is believed that the Defendant in this case will argue on October 13, 2003 that
she fired the Family Law Clinic and was unaware of their efforts to withdraw from representation
or this Court's subsequent Orders.
10. Father seeks to introduce into evidence the following information which is not
subject to any attorney client privilege:
a. Family Law Clinic mailed to the Defendant a copy of the January 23, 2003
Order granting Father primary physical custody and that this mail was not returned by the Post
Office.
b. Family Law Clinic notified the Defendant in writing of the March 21,
2003 custody trial and that the mail was not returned by the Post Office.
C. Family Law Clinic was unable to maintain contact by telephone with the
Defendant and that the Defendant failed to appear at meetings or cooperate regarding the custody
of the minor child.
d. Family Law Clinic mailed to the Defendant a copy of the Court's March 7,
2003 Order allowing the Defendant to request a hearing at any time and this mail was not
returned by the Post Office.
e. Family Law Clinic mailed to the Defendant the Petition to Withdraw and
Rule to Show Cause dated April 4, 2003 and this mail was not returned by the Post Office.
11. The telephone contact testimony is critical since one of the Defendant's chief
complaints is that she is unable to have telephone contact with the child. Father seeks to show
that Defendant is difficult to reach by telephone as experienced by the Defendant's own prior
counsel.
12. The attorney client privilege does not apply since Rule of Professional Conduct
1.6 (c)(3) governs a situation where a client or former client seeks to make a representation
before the Court which a lawyer knows to be inaccurate. In this case, it would be improper for
the Defendant to argue ignorance of the Orders dated January 23, 2003, April 4, 2003 and March
7, 2003 when the Family Law Clinic is expected to testify that it mailed copies of these Orders to
the Defendant's address and the mail was never returned by the Post Office.
Respectfully submitted,
BY: z Axo
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court I.D. 62063
Attorney for Plaintiff
Certificate of Service
I hereby certify that on the date set forth below a true and correct copy of the foregoing
document was served upon all interested parties via postage prepaid, first class United States
Mail addressed as follows:
Patricia J. Romano, Esquire
4711 Locust Lane
Harrisburg, PA 17109
Robert Rains, Esquire
Family Law Clinic
45 North Pitt Street
Carlisle, PA 17013
Date: October 8, 2003
i
JOSHUA B. SINGER,
Plaintiff/Respondent
V.
KERI ANN CRAWFORD,
Defendant/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-6599 CIVIL TERM
CIVIL ACTION - CUSTODY
CUSTODY
ORDER OF COURT
AND NOW, this 13th day of October, 2003, after hearing,
all prior custody orders are vacated and replaced with the
following:
1. The parties shall share legal custody of their Child,
Clay B. Singer, born May 9, 2000.
2. Father shall have primary physical custody of the Child
subject to periods of partial physical custody with the Mother a
follows:
A. In odd numbered years from November 1 to
November 30.
B. In even numbered years from December 1 to
December 31.
C. In all years:
i. From February 1 to the last day of February.
ii. From May 1 to May 31.
iii. From August 15 to September 15.
D. Such other times as the parties may agree.
Mother shall be be responsible for all transportation
the Child to and from all visits. Provided, however, that Fa
shall take the Child, at the request of Mother, to any airport
within 100 miles of his residence.
3. The custodial parent shall make the Child available for
phone calls from the non-custodial parent every Wednesday and
Sunday at 7:00 p.m.
4. Father shall make the Child available to visit with the
maternal grandparents one weekend per month in each month that
Mother does not have her visits. Said visits with the maternal
grandparents to last from Friday at 5:30 p.m. until Sunday at
8:00 p.m. The grandparents shall be responsible for
transportation unless otherwise agreed.
5. Neither party shall disparage the other in front of the
Child, nor shall they allow family members or anyone else to do
so.
6. Father shall cooperate with Mother to make the Child
available for any appointments scheduled with counselors, such
Ms. Green. Provided, however, that Father shall be given at
least seven days' notice by e-mail or in writing of said
appointment.
7. The parties shall keep each other apprised of a current
e-mail address. The custodial parent shall initiate an e-mail
each day to the non-custodial parent letting him or her know
something positive about the Child's life or development. The
other party shall respond. The parties shall keep copies of sai
e-mails to present to this Court at any future hearing. We
suggest that all other correspondence, of a non-emergency nature
be conducted through e-mails so that a record exists.
8
Xteven Howell, Esquire
Attorney for Plaintiff/Respondent
Patricia J. Romano, Esquire
Attorney for Defendant/Petitioner
srs
This Court shall maintain jurisdiction.
Edward E. Guido, J.
i G ':3 Q"1 IJO
r
Stephanie E. DiVittore, Esquire
Attorney I.D. No. 85906
RHOADS & SINON LLP
One South Market Square, 12th Floor
P.O. Box 1146
Harrisburg, PA 17108-1146
(717) 233-5731
Attorneys for Defendant
JOSHUA B. SINGER,
Plaintiff
V.
KERI ANN CRAWFORD,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.01-6599 CIVIL TERM
CIVIL ACTION -- CUSTODY
PETITION FOR MODIFICATION OF CUSTODY ORDER
NOW COMES Defendant Keri Ann Crawford n/k/a Keri Ann Torrent ("Torrent") by and
through her attorneys, Rhoads & Sinon LLP, and files the within Petition for Modification of
Custody Order as follows:
1. On or about November 26, 2001, Plaintiff filed a Petition for Custody seeking
custody of minor child Clay Singer, born May 9, 2000.
2. In the Petition, Plaintiff sought custody of the child, alleging the child was in
danger of physical and mental abuse while in the custody of Torrent. Contrary to Plaintiffs
representations, however, the child was never in danger of physical, mental or any type of abuse
while in Torrent's care. Instead, the evidence at all hearings in this matter have demonstrated that
Torrent is a responsible mother that loves her child and has, at all times, properly cared for him.
618968.1
3. Following a hearing before Judge Guido, however, based on Torrent's moving to
Florida, the Court entered an order awarding shared, legal custody of the child to Plaintiff and
Torrent, and awarding primary physical custody of the child to Plaintiff with mother Torrent
exercising partial, physical custody every other month. (A copy of the October 13, 2003 Order is
attached hereto as Exhibit "A" and incorporated herein by reference).
4. Torrent moved to Florida and exercised visitation consistent with the October, 2003
Order, until such time as financial hardship prohibited travel as required by the Order.
5. Torrent subsequently returned to Pennsylvania and currently resides in
Mechanicsburg. Despite her efforts to discuss this matter with Plaintiff, and exercise visitation
with the child, Plaintiff failed to return telephone calls or be present in order for Torrent to exercise
visitation as prescribed in the October, 2003 Order or otherwise.
6. Recognizing the elapsed period of time, her return to Pennsylvania and the fact that
the child is currently enrolled in school in York County, the Court Order currently in place is no
longer practical. Instead, Torrent seeks a modification of the Court Order in order to ensure she
obtains partial, physical custody and visitation with the child, visitation and custody which does
not interfere with the child's schooling.
7. It is clearly in furtherance of the child's best interest and permanent welfare to
exercise visitation with his mother and, therefore, Torrent requests an award of partial, physical
custody of the minor child.
-2-
WHEREFORE, Petitioner, Keri Ann Crawford n/k/a Keri Ann Torrent, respectfully
requests that the Court modify the existing Order because it will be in the best interest of the child
Clay Singer.
By:
Respectfully submitted,
RHOADS & SINON, LLP
Stephanie E. DiVittore
Attorney I.D. No. 85906
One South Market Square
P.O. Box 1146
Harrisburg, PA 17108-1146
(717) 233-5731
Attorneys for Keri Ann Torrent
-3-
VERIFICATION
Ken Ann Crawford n/k/a Ken Ann Torrent, deposes and says, subject to the penalties of 18
Pa. C.S. §4904 relating to unworn falsification to authorities, that she makes this verification by
its authority and that the facts set forth in the Petition for Modification of Custody Order are true
and correct to the best of her knowledge, information and belief.
f
EL' ?u C? -_ ?2?.GZ
0 4P
Date Keri Ann Crawford n/k/a Keri Ann Torrent
EXHIBIT "A"
JOSHUA B. SINGER,
Plaintiff/Respondent
V.
KERI ANN CRAWFORD,
Defendant/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-6599 CIVIL TERM
CIVIL ACTION - CUSTODY
CUSTODY
ORDER OF COURT
AND NOW, this 13th day of October, 2003, after hearing,
all prior custody orders are vacated and replaced with the
following:
1. The parties shall share legal custody of their Child,
Clay B. Singer, born May 9, 2000.
2. Father shall have primary physical custody of the Child
subject to periods of partial physical custody with the Mother a
follows:
A. In odd numbered years from November 1 to
November 30.
B. In even numbered years from December 1 to
December 31.
C. In all years:
i. From February 1 to the last day of February.
ii. From May 1 to May 31.
iii. From August 15 to September 15.
D. Such other times as the parties may agree.
Mother shall be be responsible for all transportation o
the Child to and from all visits. Provided, however, that Fathe
shall take the Child, at the request of Mother, to any airport
within 100 miles of his residence.
3. The custodial parent shall make the Child available for
phone calls from the non-custodial parent every Wednesday and
Sunday at 7:00 p.m.
4. Father shall make the Child available to visit with the
i
maternal grandparents one weekend per month in each month that
Mother does not have her visits. Said visits with the maternal
grandparents to last from Friday at 5:30 p.m. until Sunday at
8:00 p.m. The grandparents shall be responsible for
transportation unless otherwise agreed.
5. Neither party shall disparage the other in front of the
Child, nor shall they allow family members or anyone else to do
so.
6. Father shall cooperate with Mother to make the Child
available for any appointments scheduled with counselors, such
Ms. Green. Provided, however, that Father shall be given at
least seven days' notice by e-mail or in writing of said
appointment.
7. The parties shall keep each other apprised of a current
e-mail address. The custodial parent shall initiate an e-mail
each day to the non-custodial parent letting him or her know
something positive about the Child's life or development. The
other party shall respond. The parties shall keep copies of sai
e-mails to present to this Court at any future hearing. We
suggest that all other correspondence, of a non-emergency nature
be conducted through a-mails so that a record exists.
8. This Court shall maintain jurisdiction.
B-.-Fie Court,
Edward
E. Guido, J.
v6teven Howell, Esquire
Attorney for Plaintiff/Respondent
v4atricia J. Romano, Esquire I> O
Attorney for Defendant/Petitioner R 1S
srs 16 .1 &-LI3
CERTIFICATE OF SERVICE
I hereby certify that on this A day of August, 2006, a true and correct copy of the
foregoing Petition for Modification of Custody Order was served by means of Regular Mail,
return receipt requested, upon the following:
Steven Howell, Esquire
619 Bridge Street
New Cumberland, PA 17070
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Stephanie E. DiVittore, Esquire
Attorney I.D. No. 85906
RHOADS & SINON LLP
One South Market Square, 12th Floor
P.O. Box 1146
Harrisburg, PA 17108-1146
(717) 233-5731
Attorneys for Defendant
JOSHUA B. SINGER, IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V.
KERI ANN CRAWFORD,
Defendant
NO.01-6599 CIVIL TERM
CIVIL ACTION -- CUSTODY
PRAECIPE FOR ENTRY OF APPEARANCE
Kindly enter the appearance of Stephanie E. DiVittore, Esquire and Rhoads & Sinon LLP
on behalf of Defendant Keri Ann Crawford n/k/a Keri Ann Torrent in this matter.
Respectfully submitted,
RHOADS & SINON, LLP
By: v > 1 :4tzMA--
Stephanie E. DiVittore
Attorney I.D. No. 85906
One South Market Square
P.O. Box 1146
Harrisburg, PA 17108-1146
(717) 233-5731
Attorneys for Keri Ann Torrent
618968.1
CERTIFICATE OF SERVICE
I hereby certify that on this j?day of August, 2006, a true and correct copy of the
foregoing Praecipe for Entry of Appearance was served by means of Regular Mail, postage
prepaid, upon the following:
Steven Howell, Esquire
619 Bridge Street
New Cumberland, PA 17070
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JOSHUA B. SINGER IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
KERI ANN CRAWFORD
DEFENDANT
01-6599 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Thursday, August 24, 2006 , 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 Tuesday, September 26, 2006 at 2:30 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. 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: /s/ Dawn S. Sunda Es q.
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
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JOSHUA B. SINGER, IN THE COURT OF COMMON PLEAS
PLAINTIFF OF CUMBERLAND COUNTY,
PENNSYLVANIA
VS.
NO. 01 - 6599
KERI ANN CRAWFORD,
a/k/a KERI ANN TORRENT,
DEFENDANT CIVIL ACTION - CUSTODY
ANSWER WITH NEW MATTER AND COUNTERCLAIM
TO: Kerri Ann Crawford a/k/a Keri Ann Torrent
c/o Stephanie E. DiVittore, Esquire
Rhoads & Sinon LLP
P.O. Box 1146
Harrisburg, PA 17108-1146
Notice to Plead
YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE
ENCLOSED NEW MATTER AND COUNTERCLAIM WITHIN TWENTY (20) DAYS
FROM SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOU.
ANSWER TO PETITION FOR MODIFICATION
ADMITTED.
2. DENIED AS STATED. The pleadings speak for themselves. It is expressly
DENIED that Defendant is a "responsible mother" that has "at all times
properly cared for him" and Plaintiff incorporates by reference his New
Matter as though fully set forth.
3. DENIED AS STATED. The pleadings and court order speak for themselves.
It is expressly DENIED that the October 13, 2003 Order provided the
Defendant with physical custody every other month. Even a cursory
examination of the October 13, 2003 Order shows that the Defendant was
provided with four monthly visitations or thirty two (32%) percent of all the
overnights on a yearly basis.
4. DENIED AS STATED. The last time Clay (DOB 5/9/00; Age 6) saw the
Defendant was December 31, 2004. Almost seventeen (17) months later on
Thursday, May 25, 2006 the Defendant made a telephone call stating that she
was coming to pick the child up at 5:00 PM on May 26, 2006. On that date
the Defendant was arrested by Newberry Township Police Department on a
bench warrant from York County. The child did not witness this arrest.
5. DENIED AS STATED. Defendant's current residential address in
Pennsylvania, if any, is unknown to Plaintiff. It should be noted that the
Petition for Modification provides no address for the Defendant and despite a
request to Attorney DiVittore on August 17, 2006 no address or telephone
number have been provided to the Plaintiff as of the filing date of this
pleading, which is more than one month later.
6. ADMITTED. It is ADMITTED that Defendant seeks this time but it is
expressly DENIED that it is in the best interest of a six year old child to be
compelled to spend time with an individual who has been a stranger in his life
since December 31, 2004 - over twenty one (21) months ago.
7. DENIED. It would be inappropriate and not in the best interests of the child
to be suddenly sent with the Defendant, who voluntarily abandoned the child
twenty one (21) months ago and has not seen the child since December 31,
2004.
NEW MATTER
8. Defendant and her counsel have failed to provide a residential address,
telephone number or even a cell phone number for the Defendant and her
actual whereabouts in Pennsylvania are unknown.
9. On July 26, 2006 Defendant was sentenced to serve thirty (30) days
incarceration in the York County Prison, which has been deferred to April 1,
2007 for failure to pay child support in a timely manner. She is thousands of
dollars in arrears.
10. Defendant last spent time with the child on December 31, 2004.
11. Defendant voluntarily failed to exercise any partial custody for the following
monthly periods:
a. February 1St - February 28th 2005;
b. May 1 s'- May 31 St 2005;
c. August 15th - September 15th 2005;
d. November 1St - November 30th 2005;
e. February 1St -February 28th 2006; and
f. May 1 st - May 26th, 2006.
12. Defendant's parents failed to exercise any weekend periods of visitation for
the last 22 months with the last weekend spent by maternal grandparents being
November 21, 2004.
13. Defendant failed to send any birthday or Christmas presents to the child since
December 31, 2004.
14. Defendant has shown no interest in the child's schooling.
15. Prior to December 31, 2004 the Defendant stopped regularly calling the child
because she claimed her long distance service was disconnected and
"someone" had taken her cell phone away.
16. The Defendant has exercised poor judgment in caring for the child. For
instance, she claimed the child was hospitalized on May 6, 2004 in Florida for
"dehydration" when in fact the four year old child had been hit in the head
with a pipe across the left side of his head.
17. Clay Singer should not be removed from Father's home which includes his
step-mother, Lynda A. Singer, and sibling Garrett H. Singer (DOB 11/9/05,
Age 10 months). The Pennsylvania Supreme Court stated the standard
regarding step-siblings as:
It has always been a strong policy in our law that in the absence of
compelling reasons to the contrary, siblings should be raised together
whenever possible. [citations omitted]. This principle is in no way
diluted by the fact that the third child in this case is a half brother.
[emphasis added]. See Albright v. Albright, 491 Pa. 320, 421 A.2d 157
at 160-161 (1980). See also Beers v. Beers, 342 Pa. Super. 465, 493
A.2d 116 (1985), Haag v, Haag, 336 Pa. Super. 491, 499-500, 485
A.2d 1189, 1193 (1984) and Mahoney v. Mahoney, 354 Pa. Super.
585, 512 A.2d 694 at 697 at Note 1 (1986) expressly discussing step
siblings.
18. The phrase "compelling reasons ... might appear synonymous with the
`clear necessity' requirement of the Juvenile Act. " Pilon v. Pilon, 342 Pa.
Super. 52, 492 A.2d 59 at 60 (1985).
19. This strong public policy only applies when the step sibling has actually
resided with the child. In the Singer matter, Clay has always resided with
Garrett. See Johns v Cioci, 2004 Pa. Super. 492, 865 A.2d 931 (2004).
Counterclaim: Contempt of October 13, 2003 Order
Defendant's Failure to Return Child From Florida on May 31, 2004:
20. The October 13, 2003 Order stated at ¶2 that "Mother shall be responsible
for all transportation of the Child to and from all visits. Provided, however,
that Father shall take the Child, at the request of Mother, to any airport
within 100 miles of his residence. "
21. At the conclusion of the May 2004 visit in Florida the Plaintiff was forced to
take time off work and drive to Florida to pick up the child because the
Defendant did not have any money to return him or drive him back to
Pennsylvania.
22. Plaintiff's out of pocket loss totals $600.00 and the Defendant is solely
responsible for this expenditure since she utterly failed to comply with the
Order of October 13, 2003.
Defendant's Failure to Send E-Mail or Provide a Current E-Mail Address:
23. The October 13, 2003 Order stated at $7 that "The parties shall keep each
other apprised of a current e-mail address ... The parties shall keep copies of
said a-mails to present to this Court at any future hearing."
24. Plaintiff Joshua Singer sent hundreds of a-mails to the Defendant and her
mother/step-father from October 13, 2003 to October 24, 2005. Plaintiff sent
a total of five hundred eighty five (585) a-mails for this period which works
out to be more than that required under the Order of Court.
25. In sharp contrast since October 13, 2003 Defendant Kerri Crawford sent sixty
(61) a-mails and stopped all a-mails on November 19, 2004.
26. Prior to November 19, 2004 the Defendant failed to comply with the ¶7 of the
October 13, 2003 Order as follows:
Period When Child is With Defendant Number of E-Mails Sent Missin
November 1St - November 30th 2003 22 a-mails 8 e-mails
February 1 st - February 28th 2004 17 a-mails 11 a-mails
May 1 st - May 31St 2004 11 a-mails 20 a-mails
August 15th - September 15th 2004 11 e-mails 19 a-mails
December 1St - December 31St 2004 No e-mails 31 a-mails
Counterclaim: Sole Legal and Physical Custody Should Be
Vested with the Plaintiff
27. The Defendant has shown no interest in the child's health, education or
welfare after returning - once again - to Florida soon after December 31,
2004.
28. Since 2003 the Defendant has utterly failed to provide any financial support
for the child with the exception of her $2,000.00 cash bail which she posted in
late May 2006 in order to be released from York County Prison.
29. The Defendant's living conditions are unstable. She has moved to and from
Florida at least four times since November 2002.
30. Even the Defendant's prior attorneys find it difficult to maintain contact as
shown in the Petition to Withdraw filed by the Family Law Clinic because she
"failed to maintain contact", "consistently failed to return telephone call[s]",
"failed to respond to correspondence", and "missed meetings".
31. The Defendant is incapable of living at any one address for a length of time.
Contrast this with the Plaintiff who continues to reside in the same house.
32. The Defendant's refusal to provide a residential address despite repeated
requests from Plaintiff and his counsel demonstrates that she is incapable of
conducting herself in a reasonable manner.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to vest sole
physical and sole legal custody of Clay Singer with him and award him his actual
travel expenses, lost wages and counsel fees incurred in filing this Counterclaim for
Contempt.
Respectfully submitted,
By:
Law Firm
619 Bridge Street
New Cumberland, PA 17070
Supreme Court ID 62063
Attorney for Plaintiff
Certificate of Service
I hereby certify that on the date set forth below a true and correct copy of
the foregoing document was served upon the party/parties set forth below by postage
prepaid, first class United States Mail addressed as follows:
Stephanie E. DiVittore, Esquire
Rhoads & Sinon LLP
P.O. Box 1146
Harrisburg, PA 17108-1146
By
Date: September 29, 2006
VERIFICATION
I/we verify that the statements made in the foregoing document are true and
correct. I/we understand that false statements herein are made subject to the penalties of
18 Pa. C.S.Al 5pction 4904 relating to unsworn falsification to authorities.
BY:
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JOSHUA B. SINGER
Plaintiff
vs.
KERI ANN CRAWFORD
Defendant
OCT 0 4 200
IN THE COURT OF CC lNf M4NPLEAS--()F--
CUMBERLAND COUNTY,PENNSYLVANIA
01-6599 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this ` A day of &ZG*47 2006 upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The parties shall arrange for the Child to engage in therapeutic family counseling, with
the parties participating as recommended by the counselor, with a professional selected by
agreement between the parties. The purpose of the counseling shall be to facilitate the resumption
of contact between the Child and the Mother in a manner conducive to the Child's emotional well-
being and to address any adjustment issues which may arise. The parties shall cooperate in
following the counselor's guidance as to the process of reunification and ongoing counseling. All
costs of the counseling which are not covered by insurance shall be shared equally between the
parties.
2. Counsel for either party may contact the conciliator within 90 days of the date of this
Order to schedule an additional conciliation conference, if necessary at that time.
J.
cc: t ven Howell, Esquire - Counsel for Father
4ephanie E. DiVittore, Esquire - Counsel for Mother
v
Edward E. Guido
I)o
V
JOSHUA B. SINGER
Plaintiff
vs.
KERI ANN CRAWFORD
Defendant
Prior Judge: Edward E. Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSLVANIA
01-6599 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Clay B. Singer May 9, 2000 Father
2. A custody conciliation conference was held on October 3, 2006, with the following
individuals in attendance: The Mother, Keri Ann Crawford, with her counsel, Stephanie E.
DiVittore, and the Father, Joshua B. Singer, with his counsel, Steven Howell.
3. The parties agreed to entry of an Order in the form as attached.
Date
Dawn S. Sunday, Esquire
Custody Conciliator
JOSHUA B. SINGER,
PLAINTIFF
VS.
KERI ANN CRAWFORD,
a/k/a KERI ANN TORRENT,
DEFENDANT
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 01 - 6599
CIVIL ACTION - CUSTODY
PETITION TO MODIFY OCTOBER 9, 2006 ORDER
1. Plaintiff Joshua B. Singer is the natural father of Clay Singer (DOB 5/9/00; Age
6).
2. Defendant Keri Ann Crawford is the natural mother of Clay Singer.
3. The last time the Defendant exercised visitation with the child was December 31,
2004 - over twenty eight (28) months ago.
4. In late August 2006 the Defendant filed a Petition to Modify Custody.
5. On October 3, 2006 a conference was held before Dawn Sunday, Esquire and the
parties agreed to an Order attached as Exhibit "A" upon the express representation
by the Defendant that she intended to take this process seriously and not simply
enter the child's life and then abandon him once again.
6. On October 4, 2006 Defendant's counsel requested a copy of the child's birth
certificate and his health insurance card so the Defendant could schedule the
counseling. In this same October 4th letter Defendant's counsel indicated that
Guidance Associates had immediate openings.
7. On October 4, 2006 Plaintiff's counsel faxed a letter stating that Mr. Singer had
no opposition to Guidance Associates.
4-
8. On October 11, 2006 Plaintiff's counsel complied with the October 4th request
and sent the birth certificate and health insurance card.
9. On October 11, 2006 Defendant and her counsel had: (a) the insurance
information; (b) the birth certificate; and (c) an agreement to use Guidance
Associates.
10. On January 31, 2007 Plaintiff's counsel received a fax from Defendant's counsel
claiming that a "Consent Form [had been] previously forwarded by [Guidance
Associates]". No such form was ever received by the Plaintiff or his counsel.
11. On February 1, 2007 Plaintiff's counsel wrote to Defendant's counsel and stated
that no such forms had been received.
12. On March 16, 2007 Plaintiff's counsel received for the first time the consent
forms from Defendant's counsel and they were sent to his client for execution.
13. The Defendant's failure to timely act between the October 3, 2006 conference and
March 16, 2007 - a period of nearly 5 1/2 months - leads the Plaintiff to believe
that she does not intend to seriously participate in counseling but simply upset the
child by re-introducing herself only to abandon him yet again. Defendant has
abandoned the child twice before.
14. Plaintiff does not believe that the Defendant intends to seriously participate in
counseling with the child.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to vest sole
physical and sole legal custody of Clay Singer with him and modify the October 9th
Order to eliminate the need for any counseling.
Respectfully submitted,
By:
Nowell 'Law Firm
619 Bridge Street
New Cumberland, PA 17070
Supreme Court ID 62063
Attorney for Plaintiff
Certificate of Service
I hereby certify that on the date set forth below a true and correct copy of
the foregoing document was served upon the party/parties set forth below by postage
prepaid, first class United States Mail addressed as follows:
Stephanie E. DiVittore, Esquire
Rhoads & Sinon LLP
P.O. Box 1146
Harrisburg, PA 17108-1146
By:
Date: April 18, 2007
04/16/2007 12:12 7177701278 HOWELL LAW FIRM PAGE 01/06
VERIFICATION
I/we verify that the statements made in. the foregoing document are true and
correct. I/we understand that false statements herein are rttade subject to the penalties of
1.8 Pa. C.S.A. c ' n 4904 relating to unsworn falsifcation to authorities.
? J
BY:
shua S. Si r
N it
IN THE COURT OF C LNfl L-R-L
JOSHUA B. SINGER
plaintiff CUMBERLAND COUNTY,PENNSYLVANIA
x
vs. 01-6599 CIVIL ACTION LAW
KERI ANN CR.AWFORD
Defendant IN CUSTODY
ORDER OF COURT
?? ;
AND NOW, tlus day of. 2006, upon - of?A- consideration of the attached Custody Conciliation, Report, it is ordered and directed as follows:
.'
I.. The parties shall arrange for the Child to engage in therapeutic family counseling, with
0ae parties participating as recommended by the counselor, with a professional selected by
agreement between the parties. The purpose of the counseling shall be to facilitate the resumption
of contact between the Child and the Mother in a manner conducive to the Child's emotiona) well-
being and to address any adjustment issues which may arise. The parties shall cooperate in
following the counselor's guidance as to the process of reunification and ongoing counseling. All
costs of the counseling which are not covered by insurance shall be shared equally between the
parties.
2. Counsel for either party may contact the conciliator within 90 days of the date of this
Order to schedule an additional conciliation conference, if necessary at that time.
1,
,
Edward E. Guido J.
cc: Steven Howell, Esquire - Counsel for Father
Stephanie E. DiVittore, Esquire - Counsel for Mother
EXHIBIT
A
TRUE COPS' FR('%M RECORD
In Testimony whereof., : . -.-ito set my hand
SOl f said ours of Carlisle,. e.
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JOSHUA B. SINGER IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
v' 01-6599 CIVIL ACTION LAW
KERI ANN CRAWFORD
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Thursday, April 26, 2007 , 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 Tuesday, May 29, 2007 at 1:30 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. 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: /s/ Dawn S. Sunday, Esq. Ilk
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
:Z 14d 9Z M LODZ
4 .? JUN 11 2001
JOSHUA B. SINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. 01-6599 CIVIL ACTION LAW
KERI ANN CRAWFORD,
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this / e _ day of 0.--& , 2007, upon
consideration of the attached Custody Conciliation ort, it is ordered and directed as follows:
1. The parties shall arrange for the Child to engage in therapeutic family counseling at
Guidance Associates, with the parties participating as recommended by the counselor. The purpose of
the counseling shall be to facilitate the resumption of contact between the Child and the Mother in a
manner conducive to the Child's emotional well-being and to address any adjustment issues which
may arise. The parties shall cooperate in following the counselor's guidance as to the process of
reunification and ongoing counseling. All costs of the counseling which are not covered by insurance
shall be shared equally between the parties. The Mother shall be responsible to schedule the sessions
and shall make every effort to accommodate the Father's work schedule to ensure that the Father is
available for sessions involving either the Father, the Child or both. The Mother shall provide at least
seven (7) days' advance written notice to the Father's counsel of any sessions for which the Father is to
make the Child available or in which the Father is participating. The Mother shall schedule the initial
sessions within thirty (30) days of the date of this Order.
2. Counsel for either party may contact the conciliator within ninety (90) days of the date of
this Order to schedule an additional custody conciliation conference, if necessary.
cc: Stephanie E. DiVittore, Esquire - Counsel for Mother
Steven Howell, Esquire - Counsel for Father -'
?-?y-o7
Edward E. Guido J.
ro
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...rs
t
JOSHUA B. SINGER,
Plaintiff
VS.
KERI ANN CRAWFORD,
Defendant
Prior Judge: Edward E. Guido
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-6599 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Clay B. Singer May 9, 2000 Father
2. A custody conciliation conference was held on June 7, 2007, with the following individuals
in attendance: the Father, Joshua B. Singer, with his counsel, Steven Howell, Esquire, and the Mother,
Keri Ann Torrent, formerly Crawford, with her counsel, Stephanie E. DiVittore, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
L""?= cl,
c??e -7 3 on ?7
Date Dawn S. Sunday, Esquire 61
Custody Conciliator