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HomeMy WebLinkAbout08-6634REBECCA L. WHISNER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY PAUL D. WHISNER, Defendant : NO. 0 P LaG 3 `? CIVIL TERM COMPLAINT FOR CUSTODY The plaintiff, Rebecca L. Whisner, by her attorneys, the Family Law Clinic, sets forth the following cause of action in custody. 1. The plaintiff is Rebecca L. Whisner, residing at 422 Ricky Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The defendant is Paul D. Whisner, residing at 296 South Street, Hanover, Adams County, Pennsylvania 17331. 3. Plaintiff seeks primary custody o£ Name Present Residence Age Jessie Whisner 422 Ricky Road 5 Mechanicsburg, PA 17055 Angel Whisner 422 Ricky Road, PA 17055 3 Mechanicsburg, PA 17055 Reece Whisner 422 Ricky Road 1 Mechanicsburg, PA 17055 Jessie Whisner was born out of wedlock. Angel and Reece Whisner were born in wedlock. The children are presently in the custody of Rebecca L. Whisner, who resides at 422 Ricky Road, Mechanicsburg, PA 17055. During the past five years the children have resided with the following persons at the following addresses: Persons Rebecca Whisner Address 422 Ricky Road Mechanicsburg, PA 17055 Dates July2003-January2004 Rebecca and Paul Whisner 1355 Glendale Aveenue January 2004-April 2004 Camphill, PA 17033 66 Betty Nelson Court April 2004- August 2004 Rebecca Whisner Carlisle, PA 17013 422 Ricky Road Mechanicsburg, PA 17055 422 Ricky Road Mechanicsburg, PA 17055 Aug. 2004-Sept. 2005 Sept. 2005-Feb. 2006 11 West High Street Apartment 8 Carlisle, PA 17013 Rebecca and Paul Whisner 10 West High Street Apartment 326 Carlisle, PA 17013 Harvon Motel Hanover Street Carlisle, PA 17013 156 North West Street Carlisle, PA 17103 267 Lincoln Street Carlisle, PA 17013 Rebecca Whisner 422 Ricky Road Mechanicsburg, PA 17055 The mother of the children is Rebecca L. Whisner. She is married. The father of the children is Paul. D. Whisner. He is married. Jan. 2005-March 2005 March 2005-Jan. 2006 Feb. 2006-March 2006 April 2006-Nov. 2006 Dec. 2006-June 2007 July 2007-Present 4. The relationship of Plaintiff to the children is that of mother. The Plaintiff currently resides with the following persons: Name Jessie Whisner Angel Whisner Reece Whisner Relationship child child child The relationship of Defendant to the child is that of father. The Defendant currently resides with the following persons: Name Jennifer Horn Relationship girlfriend 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth, or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: a. Plaintiff has been the children's primary caretaker for all of the children's life; b. Plaintiff provides the children with a stable home and environment with adequate moral, emotional, and physical surroundings as required to meet the children's needs; c. Plaintiff has permitted contact between Defendant and the children and will continue to do so; d. Plaintiff is willing to accept custody of the children. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody to the children have been named as parties to this action. WHEREFORE, Plaintiff requests the court to grant her shared legal custody and primary physical custody of the children, with the father having periods of partial custody. Respectfully submitted, Date: J r 1 f L-7 'Lo % - Amy racher Certified Legal Intern MEGA RIESMEYER Supervising Attorney THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties 18 Pa.C.S. § 4904 r lating to unsworn falsification to authorities. Rebecca L. Whisner V C..3 rqy C7 f_ :7.- Rebecca L. Whisner, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANI A V. : CIVIL ACTION - LAW IN CUSTODY Paul D. Whisner, > Defendant NO. 08-W34 CIVIL TERM `' PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: > F Kindly allow Rebecca L. Whisner, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date 1</7/cq Respectfully submitted, Amy ac er Certi d Legal Intern A G RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 WD kut k ?. ?? CZ) t i1 Rebecca L. Whisner, Plaintiff V. : Paul D. Whisner, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY NO. 08-6634 CIVIL TERM AFFIDAVIT OF SERVICE I, Amy Bracher, hereby certify that I personally served a true and correct copy of the Custody Complaint on Paul D. Whisner, Defendant, at The Cumberland County Prison on Tuesday, November 11, 2008 at 12:40 p.m. I verify that the statements made in this Affidavit of Service are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. Date: If'/3 C'] rv Y-s r- GJ Oml ? 3 T REBECCA L. WHISNER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. PAUL D. WHISNER DEFENDANT 2008-6634 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Friday, November 14, 2008 _,upon consideration of the attached. Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, December 18, 2008 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilroy, Es q. 114 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 tNVAIASNN d h i .s Nd X11 AON 8441 huvio:, U Hiov d Ni ?O 30UO-GRJ REBECCA L. WHISNER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY PAUL D. WHISNER, _0 Defendant : NO. UV ? CIVIL TERM CUSTODY AGREEMENT THIS AGREEMENT, made this L day of December, 2008, between Rebecca L. Whisner, hereinafter Mother, and Paul D. Whisner, hereinafter Father, concerns the custody of their children: Jessie Whisner, born on July 4, 2003; Angel Whisner, born on September 13, 2005; and Reece Whisner, born on January 31, 2007. Mother and Father desire to enter into an agreement as to the custody of the children. Mother and Father agree to the following: 1. Mother and Father shall share legal custody of the children. 2. Mother shall have primary physical custody of the children. 3. Father shall have periods of partial physical custody of the children every other weekend from Saturday at 9:00 a.m. until Sunday at 8:00 p.m. 4. Father shall pick up and drop off the children at Mother's residence. 5. Christmas: In even-numbered years Father will have custody of the children from 8:00 a.m. on December 23`d until 9:00 p.m. on Christmas Eve. Mother will have custody from 9:00 p.m. on Christmas Eve until 8:00 p.m. on Christmas Day. In odd-numbered years Mother will have custody from 8:00 a.m. on December 23rd until 9:00 p.m. on Christmas Eve. Father shall have custody from 9:00 p.m. on Christmas Eve until 8:00 p.m. of Christmas Day. 6. Birthdays: In even numbered years, Mother shall have custody of the children from noon on the day before any one of the children's birthdays until noon of the child's birthday. Father will then have custody of the children from noon on the child's birthday until noon the following day. In odd numbered years, Father shall have custody of the children from noon on the day before any one of the children's birthdays until noon of the child's birthday. Mother will then have custody of the children from noon on the child's birthday until noon the following day. 7. Father shall have custody of the children on Father's Day. 8. Mother shall have custody of the children on Mother's Day. 9. The parties shall agree to share custodial time for all other holidays. 10. Vacations: Arrangements for summer vacations with the children shall be by agreement of both parties. 11. Mother and Father will notify each other of all medical care the children receive while in the parent's care. Mother and Father will notify the other immediately of medical emergencies which arise while the children are in that parent's care. 12. Each parent shall have copies of all necessary medical insurance information for the children. 13. Neither parent shall take the children out of the state of Pennsylvania without consent from the other party. 14. Each parent shall provide a telephone number and address where the children can be reached while in the custody of the other parent. 15. Each parent shall have reasonable phone contact with the children while in the custody of the other parent. 16. Neither parent will do anything which may estrange the children from the other party, or injure the opinions of the children as to the other parent or which may hamper the free and natural development of the children's love and respect for the other parent. 17. Father acknowledges that the Family Law Clinic represents only Mother's interest in this matter and has given him no legal advice other than that he should seek the advice of legal counsel. 18. The parties may modify this Agreement by mutual consent. 19. The parties intend to be bound by the terms of this agreement and intend for this Agreement to be made an Order of Court. *ulD. Whisner, Defendant eL. hi ner, P aintiff Amy r Certified Legal Intern/Counsel for Plaintiff L? MEG RIESMEYER Supervising Attorney/Counsel for Plaintiff FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 Fax (717)243-3639 cxa `Y7 . .....,, fit b DEC 1 L avid ? Rebecca L. Whisner, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW IN CUSTODY Paul D. Whisner, Defendant : NO. 08-6634 CIVIL TERM ORDER OF COURT AND NOW, this I day of 1) P. Cg ,%\i\e , 2008 upon consideration of the attached Custody Agreement, it is hereby ordered that: 1. Mother and Father shall share legal custody of the children. 2. Mother shall have primary physical custody of the children. 3. Father shall have periods of partial physical custody of the children every other weekend from Saturday at 9:00 a.m. until Sunday at 8:00 p.m. 4. Father shall pick up and drop off the children at Mother's residence. 5. Christmas: In even-numbered years Father will have custody of the children from 8:00a.m. on December 23`d until 9:00 p.m. on Christmas Eve. Mother will have custody from 9:00 p.m. on Christmas Eve until 8:00 p.m. on Christmas Day. In odd- numbered years Mother will have custody from 8:00 a.m. on December 23`d until 9:00 p.m. on Christmas Eve. Father shall have custody from 9:00 p.m. on Christmas Eve until 8:00 p.m. of Christmas Day. 6. Birthdays: In even numbered years, Mother shall have custody of the children from noon on the day before any one of the children's birthdays until noon of the child's birthday. Father will then have custody of the children from noon on the child's birthday until noon the following day. In odd numbered years, Father shall have custody of the children from noon on the day before any one of the children's birthdays until noon of the child's birthday. Mother will then have custody of the children from noon on the child's birthday until noon the following day. 7. Father shall have custody of the children on Father's Day. 8. Mother shall have custody of the children on Mother's Day. 9. The parties shall agree to share custodial time for all other holidays. 10. Vacations: Arrangements for summer vacations with the children shall be by agreement of both parties. 11. Mother and Father will notify each other of all medical care the children receive while in the parent's care. Mother and Father will notify the other immediately of medical emergencies which arise while the children are in that parent's care. 12. Each parent shall have copies of all necessary medical insurance information for the children. 13. Neither parent shall take the children out of the state of Pennsylvania without consent from the other party. 14. Each parent shall provide a telephone number and address where the children can be reached while in the custody of the other parent. 15. Each parent shall have reasonable phone contact with the children while in the custody of the other parent. 16. Neither parent will do anything which may estrange the children from the other party, or injure the opinions of the children as to the other parent or which may hamper the free and natural development of the children's love and respect for the other parent. 17. The parties may modify this Order of Court by mutual consent. BY THE COURT: --Fz - -v3rs,?yG'? "?1 C'' 'w 411-r,- REBECCA L. WHISNER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW PAUL D. WHISNER, NO. 2008-6634 Defendant IN CUSTODY ORDER et AND NOW, this day of December, 2008, the Conciliator being advised the parties have reached an agreement, the Conciliator relinquishes jurisdiction. ?4 \4, Hubert X. Gilroy, Custody Conciliar uire ? ? ?'? t G ?? i ? ? --: ; ' c?'? ,;-,-: __.. c.: a .. cx°r °- Rebecca L. Whisner, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW CUSTODY Paul D. Whisner, Defendant NO. 08 - 6634 CIVIL TERM CERTIFICATE OF SERVICE I, Amy Bracher, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the December 15, 2008 Order of Court on Paul D. Whisner by depositing a copy of the same in the United States mail addressed to 296 South Street, Hanover, PA 17331 on December 31, 2008. Amy Br her Certified Legal Intern / Anne a onald-Fox Supervisi g Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 241-3639 REBF,CCA L. WHISNER, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent :CUMBERLAND COUNTY, PF.NNS~'LVANIA ~, CIVIL ACTION -LAW NO.2008 - 6634 CIVIL TF. PAUL D. WHISNER, ~' Defendant/Petitioner IN CUSTODY - PETITION TO MODIFY CUSTODY AND NOW comes the Defendant/Petitioner, Paul D, Whisner, by his attorneys, Irwin & McKnight, P~.C., and presents the following Petition to Modify Custody. The Petitioner is Paul D. Whisner, an adult individual residing at 7 I ~l Stanwix Circle, Apartment 1, Carlisle, Cumberland County, Pennsylvania 17013 The F~espondent is Rebecca L.. Whisner, an adult individual was recently incarcerated in the Cumberland County Prison, Carlisle, Cumberland County, Pennsylvania 1701 ~. It believed that her current address is 422 Rickey Road, Mechanicsburg, Pennsylvania 17055. 3. The parties are the natural parents of three (3) minor children, namely Jessie Whisner, born on Julv 4, 2003; Angel Moore, born on September 13, 2005; and Reece Whisner, born on Januar~~ 31.2007. 4 The parties are currently governed by a custody Order of Court dated December 15, 2008, with attached Custody Agreement, a copy of which is attached hereto and marked as Exhibit "A". 5 Che Petitioner desires primary physical custody of said children and primary legal custody- The Respondent has signed an Agreement, a copy of which is attached hereto and marked as Exhibit "B". 6. The Respondent, Rebecca L. Whisner, has neglected said minor children, heating and abusing then-i mentally and emotionally. The Petitioner, Paul D. Whisner, requests that the Respondent undergo a psychological evaluation to determine her ability to parent said minor children. The Petitioner, Paul D. Whisner, desires that the Respondent, Rebecca L. Whisner, be denied physical custody unless supervised visitation is available of said minor children until a comprehensive psychological evaluation can be completed. 7. The hest interests and permanent welfare of the minor children requires that the Court grant the Petitioner's request as set forth above. WHF.~REFORE, Petitioner, Paul D. Whisner, respectfully requests that be granted primary physical custody and primary legal custody of the minor children, Jessie Whisner, Angel Whisner, and Reece Whisner. The Petitioner also requests that Respondent, Rebecca L. Whisner, undergo a psychological evaluation to determine her ability to parent said minor children and visitation be denied until a comprehensive psychological evaluation can he completed. Respectfully submitted, By: IRWIN & KNIGHT, P.C~ Marcu~+ A. McK ,III, Esquire Attorney for Plai 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court I. D. No. 25476 Date: October 1 ~8, 2012 VERIFICATION The foregoing Petition to Modify Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have head the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. '~ ,~~'~ l ~ - ---- PAUL D. WHISNER Date: October I8, 2012 Rebecca L. Whisner, : IN THE COURT OF COMMON PLEAS OF Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN CUSTODY Paul D. Whisner, Defendant : N0.08-6634 CIVIL TERM ORDER OF COURT AND NOW, this l J~~~ day of ~g~m~[lc.~ , 2008 upon consideration of the attached Custody Agreement, it is hereby ordered that: 1. Mother and Father shall share legal custody of the children. 2. Mather shall have primary physical custody of the children. 3. Father shall have periods of partial physical custody of the children every other weekend from Saturday at 9:00 a.m. until Sunday at 8:00 p.m. 4. Father shall pick up and drop offthe children at Mother's residence. S. Christmas: In even-numbered years Father will have custody of the children from 8:OOa.m. on December 23`~ unti19:00 p.m. on Christmas Eve. Mother will have custody from 9:00 p.m. on Christmas Eve unti18:00 p.m, on Christmas Day. In odd- numbered years Mother will have custody from 8:00 a.m. on December 23`~ until 9:00 p.m. on Christmas Eve. Father shall have custody from 9:00 p.m. on Christmas Eve unti18:00 p.m. of Christmas Day. 6. Birthdavs: In even numbered years, Mother shall have custody of the children from noon on the day before any one of the children's birthdays until noon of the child's birthday. Father will then have custody of the children from noon on the child's birthday until noon the following day. In odd numbered yeazs, Father shall have custody of the children from noon on the day before any one of the children's ~ ~ w birthdays until noon of the child's birthday. Mother will then have custody of the children from noon on the child's birthday until noon the following day. 7. Father shall have custody of the children on Father's Day. 8. Mother shall have custody of the children on Mother's Day. 9. The parties shall agree to share custodial time for all other holidays. 1Q. Vacations: Arrangements for summer vacations with the children shall be by agreement of both parties. 11. Mother and Father will notify each other of all medical caze the children receive while in the pazenf's care. Mother and Father will notify the other immediately of medical emergencies which arise while the children are in that parent's care. 12. Each parent shall have copies of all necessary medical insurance information for the children. 13. Neither parent shall take the children out of the state of Pennsylvania without consent from the other party. 14. Each parent shall provide a telephone number and address where the children can be reached while in the custody of the other parent. 15. Each parent shall have reasonable phone contact with the children while in the custody of the other parent. 16. Neither parent will do anything which may estrange the children from the other party, or injure the opinions of the children as to the other parent or which may hamper the free and natural development of the chiIdren's love and respect for the other parent. 17. The parties may modify this Order of Court by mutual consent. BY THE COURT: ' ``~ -- ~-._ from: 09126/2012 11:45 #293 P.004/C310 REBECCA L. WHISNER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v . :CIVIL ACTION -LAW IN CUSTODY PAUL D. WHISNER, { ~ -v~ Defendant : NO. ~~ CIVIL TERM CUSTODY AG~Ft ~N'~' THIS AGREEMENT, made this ,~~day of December, 2448, between Rebecca L. Whisper, hereinafter Mother, and Paul D. Whisper, hereinafter Father, concerns the custody of their children: Jessie Whisper, born on July 4, 2003; Angel Whisper, born on September l3, 2005; and Reece Whisper, born on January 31, 2007. Mother and Father desire to enter into an agreement as to the custody of the children. Mother and Father agree to the following: I . Mother and Father shall share Legal custody of the children. 2. Mother shall have primary physical custody of the children. 3, Father shall have periods of partial physical custody of the children every other weekend from Saturday at 9:00 a.m, until Sunday at 8:00 p.m. 4. Father shall pick up and drop off the children at Mother's residence. 5. C,~ristmas: In evernnumbered years Father will have custody of the children from 8:04 a.m. on December 23`d unti19:00 p.m. on Christmas Eve. From: 09/26/2012 11:45 #293 P.005I010 Mother will have custody from 9:00 p.m. on Christmas Eve unti18:00 p.m. on Christmas Day. 1n odd-numbered years Mother will have custody from 8;00 a.m, on December 23rd until 9:00 p.m. on Christmas Eve. Father shall have custody from 4:00 p.m. on Christmas Eve until 5:00 p.m. of Christmas Day. 6. Hirsh s: In even numbered years, Mother shall have custody of the children from noon on the day before any one of the children's birthdays until noon of the child's birthday. Father will then have custody of the children from noon an the child's birthday until noon the following day. In odd numbered years, Father shall have custody of the children from noon on the day before any one of the children's birthdays until noon of the child's birthday. Mother will then have custody of the children from noon on the child's birthday until noon the following day. ?. Father shall have custody of the children on Father's Day. 8. Mother shall have custody of the children on Mother's Day. 4. The parties shall agree to share custodial time for all other holidays. l0, Vacations; Arrangements for summer vacations with the children shall be by agreement of both parties. l l . Mother and Father will natify each other of all medical care the children receive while is the parent's care. Mother and Father will notify the other immediately of medical emergencies which arise while the children are in that parent's raze. Fram: 09126/2012 11:Gb #?_93 P.0081010 12. Each parent shall have copies of all necessary medical insurance information for the children. 13. Neither parent shall take the children out of the state of Pennsylvania without consent from the other party. i4. Each parent shall provide a telephone number and address where the children can he reached while in the custody of the other parent. l5. Each parent shall have reasonable phone contact with the children while in the custody of the other parent. 16.. Neither parent will do anything which may estrange the children from the other party, or injure the opinions of the children as to the other parent or which may hamper the free and natural development of the children's love and respect for the other parent. 17. Father acknowledges that the Family Law Clinic represents only Mother's interest in this matter and has given him na legal advice other thaw that he should seek the advice of legal counsel. 18. The parties may modify this Agreement by mutual consent. ' From: 09126!2012 11:46 #?_93 P.0071010 19. The parties intend to be bound bq the terms of this agreement and intend for taus Agreement td be made an Order of Court. y ul . Whisner, Defendant ~ ~. ebecca L. ' ner, P aintiff Amy Certified Legal Intern/Counsel far l=iaintift MEG IESMEYER Supervising Attorney/Counsel for Plaintiff FAMILY LAW CLIATIC 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 Fax (717)243-3639 (~ ~ '} r"~ 1 ~ ~, r > __ _ ;t ~ '+~t. ~ s ~-; c`. --z~^ F® ~__.~.~_._..... ~~.... w. ~. ~ •~ ~ r~ .. _ ~` _ ~~ ~ ., _ . !.-~ } ,~ t l ,: -., _ _ t i ~~~ ,y _. ~ ~~ l/ _,~- `. ~~- ~,- .r ~~ ~~~ - r ~,%~. . ~~~~ ~ ~ti REBECCA L. WHISNER, Plaintiff/Respondent v. PAUL D. WHISNER, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAVV N0.2008 - 6634 CIVIL TERM IN CUSTODY CERTIFICATE OF SERVICE 1, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached document was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: Rebecca Lynn Moore Whisper 422 Rickey Road Mechanicsburg, PA 17055 IRWIN & McIfd~1IGHT, P.C. By: Marcu A. McKnig t, squire 60 West Pomfret Street Carlisle, PA 17013 (717) 249-2353 Supreme Court LD. No. 25476 Date: October l 9, 2012 REBECCA L. WHISNER, Plaintiff/Respondent ~~. PAUL D. WHISNER, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.2008 - 6634 CIVIL 'Y~~~1VI~ IN CUSTODY `; _._ PRAECIPE TO PROCEED IN FORMA PAUPERIS , , To the Prothonotary: Kindly allow, PAUL D. WHISNER, Defendant, to proceed in forma pauperis. 1, Marcus A. McKnight, III, F,squire, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. By: Respectfully submitted, IRWIN &~GIcKNIGHT, P.C. Mares A. l~'l~cKnight, III, Esquire 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Attorney for Defendant Date: October 19, 201 REBECCA L. WHISNER C-) IN THE COURT OF COMMON PLEAS OF : " N C? Cnk -T'; `D X N -4 PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANI ?? c5 rrlrl-- cn r- ' IM N a ? V. 2008-6634 CIVIL ACTION LAW <? PAUL D. WHISNER C ?' N C.-In . yrrt IN CUSTODY f r\3 DEFENDANT .,< ORDER OF COURT AND NOW, _ Tuesday, October 23, 2012 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, November 30, 2012 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Hubert X. Gilro Es q. Custody Conciliator IV' 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 0 Telephone (717) 249-3166 r" l n /?q?j xq'cos 7r L'o p t e.S G,?lAi?c? a? %112 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REBECCA L. WHISNER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN CUSTODY PAUL D. WHISNER, Defendant : NO. 08 - 6634 CIVIL TERM PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of the Community Law Clinic on behalf of the Plaintiff, Rebecca Whisner, in the above-captioned matter. Megan iesmeyer Ria Pereira c7 ~ k r ; m w r , _..~ i ~./J ~ l ~ Y ~ A ~ AC ~ "*'~ ~ c .~ ~. ,. ~_ ~ ~~ c~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REBECCA L. WHISNER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vi. :CIVIL ACTION -LAW IN CUSTODY PAUL D. WHISNER, Defendant : NO. 08 - 6634 CIVIL TERM CERTIFICATE OF SERVICE I, Ria Pereira, hereby certify that I am serving a true and correct copy of the Praecipe to Enter Appearance on the following person, counsel forndefendant, by depositing a copy of the same in the United States mail, postage prepaid, this d ~ day of ~;C?}(~~~~ , 2012: Marcus A. Mcknight, Esquire 60 West Pomfret Street Carlisle, Pennsylvania 17 3 l ~'( ~( is Per ira Certified Legal Intern COMMUNITY LAW CLINIC 371 West South Street Carlisle, PA 17013 (717) 243-2968 Fax (717) 241-3596