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HomeMy WebLinkAbout09-0327 ROWEN SINGLETON Plaintiff, V. SAMANTHA HANCOCK Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09- 3 a 7 CIVIL TERM IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, Rowen Singleton, by and through his attorney, Mark F. Bayley, Esquire, and presents the within complaint for custody, representing as follows: 1. The Plaintiff, Rowen Singleton, is an adult individual residing at 239 West Market Street, Apt. A, York, Pennsylvania 17401. 2. The Defendant, Samantha Hancock, is an adult individual; her current address is unknown. 3. Plaintiff seeks custody of the following children: Name Present Residence Age D/O/B Skyla Hancock With Mother (unknown) 2 years 12/14/06 Jaquez (last name on With Mother (unknown) 1 year 11/07 Birth certificate Unknown) 4. The children were born out of wedlock. 5. The relationship of the Plaintiff to the children is that of natural father. The Father currently resides with a roommate, Candice Raines. Plaintiff is not married. 6. The relationship of the Defendant to the children is that of natural mother. The Mother currently resides with the children. Defendant is not married. 7. During the past five years the children have resided with: Name Address Date Defendant Unknown Fall of '08 to present Defendant 309 B North Pitt St., Carlisle, PA 12/06-Fall of '08 8. The Plaintiff has not participated as a party or witness, or in another capacity in other litigation concerning the custody of the children in this or any other Court. 9. Plaintiff has no information of a custody proceeding concerning the children pending in any Court of this Commonwealth or any other state. 10. Other than as noted above, Plaintiff does not know of a person nor a party to the proceeding who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 11. The best interests and permanent welfare of the child require the parties to have periods of physical custody which may be agreed upon or otherwise be determined by the Court to be in the best interests of the children. WHEREFORE, Plaintiff requests this Honorable Court to schedule a custody conciliation conference. Date: U Respectfully submitted, BAYL & AN \?k F. Bayley, E uire 17 West South S eet Carlisle, PA 17013 (717) 241-2446 Supreme Court ID # 87663 Attorney for Plaintiff ROWEN SINGLETON : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW SAMANTHA HANCOCK : NO. 09- CIVIL TERM Defendant. : IN CUSTODY VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unworn falsification to authorities. Rowen S' Teton, Plaintiff t i co 4 . ROWEN SINGLETON IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-327 CIVIL ACTION LAW SAMANTHA HANCOCK DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, January 29, 2009' , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, February 26, 2009 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/ ac ueline M. Verne Es . 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 S 11 :?, It !d Z- j 6 H Z 41% OM & LITuLAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 ROWEN SINGLETON, Plaintiff V. SAMANTHA HANCOCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 2009-327 CIVIL ACTION - LAW : IN CUSTODY Please enter my appearance on behalf of the Defendant, Samantha Hancock, in the above- captioned matter. Respectfully submitted, late 21 ? 9- 11 Oq ABOM & KUTULAKIS, L.L.P. &ada '?. Michelle L. So , Esquire 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney ID No. 93034 .-% AND NOW, this 18'h day of February, 2009, I, Michelle L. Sommer, Esquire, of Abom & Kutulakis, L.L.P., hereby certify that I did serve a true and correct copy of the foregoing Praecipe for Entry of Appearance, upon the Plaintiffs Attorney by depositing, or causing to be deposited, same in the United States Mail, Certified Mail, postage prepaid addressed to the following: Mark F. Bayley, Esquire 17 West South Street Carlisle, PA 17013 Respectfully submitted, Abom&KmW d?* LLP. LW ?U) Michelle L. Somm, squire Attorney ID No.93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 C^r ....? o +v? l-- c? -z7 ? ?Z? - - ?; rn r ,`, • ,- ` -- ? , ; _',', ' =.- i. ? -* T7 {';r .,:.? rn ?" ?:_ =.? ` .G .i FEB 2 6 200-9 4 ROWEN SINGLETON, Plaintiff V. SAMANTHA HANCOCK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-327 CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 1 S day of M y 44 , 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Rowen Singleton and the Mother, Samantha Hancock, shall have shared legal custody of Skyla Hancock, born December 14, 2006. 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 her health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 2. Mother shall have primary physical custody of the child. 3. Mother shall cooperate with a paternity test to determine whether Plaintiff is the father of Jaquez. Plaintiff shall pay for said paternity test. 4. Father shall have periods of partial physical custody of Skyla as follows: A. Saturday, February 28, 2009 from 11:00 a.m. to 1:00 p.m. This visit shall occur at Mother's home. « - C\j i ?" .. t 4L cal? . C-) B. The next 4 Saturdays, March, 7; 14, 21, and 28, 2009 from 11:00 a.m. to 1:00 p.m. Father may take the child away from Mother's home. C. The next 8 Saturdays, April 4, 11, 18, and 25, 2009 and May 2, 9, 16, 23, 2009, from 10:00 a.m. to 2:00 p.m. . 5. Father shall be responsible for all transportation and shall have an appropriate car seat for the child. 6. Father shall not use alcoholic beverages of illegal drugs immediately before or during his periods of physical custody. 7. 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. Anothez Custody Conciliation Conference is scheduled for May 26, 2009 at 8:30 a.m. BY THE COURT, 11vL r cc? ark F. Bayley, Esquire, Counsel for Father Michelle Sommer, Esquire, Counsel for Mother .opt ES m? t [cc( I 3 3?oY J. ROWEN SINGLETON, Plaintiff V. SAMANTHA HANCOCK, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-327 CIVIL ACTION - LAW : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Skyla Hancock December 14, 2006 Mother Jaquez Knight October 29, 2007 Mother 2. A Conciliation Conference was held in this matter on February 26, 2009, with the following in attendance: The Father, Rowen Singleton, with his counsel, Mark F. Bayley, Esquire, and the Mother, Samantha Hancock, with her counsel, Michelle Sommer, Esquire. 3. Mother asserted that Plaintiff was not the father of Jaquez. Father offered to pay for a paternity test to determine if he is the father. 4. The parties agreed to an Order in the form as attached. -;? -a&-o k- v Date line M. Verney, Esquire Custody Conciliator MAR 21 Zoos 6? ROWEN SINGLETON, Plaintiff V. SAMANTHA HANCOCK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-327 CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this e day of N y -L , 2009, upon consideration of the attached ustody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated March 1, 2009 shall remain in full force and effect with the following modifications: 2. Paragraph 4 shall be deleted in its entirety and replaced with the following: Father shall have periods of partial physical custody of Skyla as follows: A. Saturday, March 28, 2009 from 11:00 a.m. to 1:00 p.m. This visit shall occur at Mother's home. A. The next 4 Saturdays, April 4, 11, 18, and 25, 2009 from 11:00 a.m. to 1:00 p.m. Father may take the child away from Mother's home. B. The next 8 Saturdays, May 2, 9, 16, and 23, 2009 and June 6, 13, 20, 27, 2009 from 10:00 a.m. to 2:00 p.m. . 3. 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. Another Custody Conciliation Conference is scheduled for June 29, 2009 at 8:30 a.m. c//.ark F. BaYleY, Esquire, Counse] kr Father chelle Sommer, Esquire, Counsel for Mother ?Ql Q.S ?`I-1 15e.?1? 1 ,312 1/01 E 1 ;9 WV 1 £ 8vw 6000 '? 'r"?--!')=lid av - " ROWEN SINGLETON, Plaintiff V. SAMANTHA HANCOCK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-327 CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., J. 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 Skyla Hancock December 14, 2006 Mother 2. A telephone Conciliation Conference was held in this matter on March 26, 2009, with the following in attendance: Father's counsel, Mark F. Bayley, Esquire, and Mother's counsel, Michelle Sommer, Esquire. 3. The Honorable J. Wesley Oler, Jr. entered an Order of Court dated March 1, 2009 providing for shared legal custody, Mother having primary physical custody with Father having a phased-in partial physical custody schedule. 4. Mother's counsel asserted that Father had not exercised any of the time set forth in the Order of Court dated March 1, 2009. Father's counsel asserted that Father had various excuses for not exercising the time and requested another opportunity to do so. 5. Counsel for the parties agreed to an Order in the form as attached. Date acq a M. Verney, Esquire Custody Conciliator Ij . KBOM ?' UTLILAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 ROWEN SINGLETON, Plaintiff V. SAMANTHA HANCOCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2009-327 CIVIL ACTION - LAW : IN CUSTODY AND NOW, the Defendant, Samantha Hancock, by and through her attorney, Michelle L. Sommer, Esquire, avers the following: 1. The Defendant, Samantha Hancock, respectfully represents that Plaintiff, Rowen Singleton, by and through his counsel, Mark F. Bayley, Esquire, filed a Complaint for Custody on or about January 18, 2009. (A true and correct copy of the Complaint for Custody is attached hereto as Exhibit A.) 2. A Custody Conciliation was held on February 26, 2009, before Conciliator Jacqueline M. Verney, Esquire. 3. On March 1, 2009, an Order of Court was entered for custody of Skyla Hancock, born December 14, 2006, granting Father graduated visitation of the minor child beginning on Saturday, February 28, 2009 from 11:00 a.m. to 1:00 p.m. at Mother's residence. (A true and correct copy of the March 1, 2009, Order of Court is attached hereto as Exhibit B.) 4. Father did not exercise his visitation on February 28, 2009 because he "didn't want to drive all the way up there and drive back when he had to work." 5. Said Order gave Father Visitation of the minor child on the next four Saturdays, March 7, 14, 21 and 28, 2009 from 11:00 a.m. to 1:00 P.M. 6. Father did not exercise his visitation on March 7, 14 or 21. a. Father did not show at all for his scheduled visitation on March 7s' and Mother waited until 11:30 and attempted to make contact with Father several times to no avail to see if he was planning on coming that morning to see his daughter. b. Father had an argument on the morning of March 14`}' with his current girlfriend that lasted -throughout his scheduled time of visitation and as a result he missed the 11:00 a.m. to 1:00 p.m. Court Ordered time to see his daughter. 7. As a result of the missed visitations, undersigned counsel requested a telephone Conference Call with Conciliator Verney and the Plaintiff's Counsel to address these missed visitations. (A true and correct copy of the March16, 2009, Letter is attached hereto as Exhibit C.) 8. A Conciliation Conference Call was held on March 26, 2009 due to the fact that Father had not exercised any visitation of the minor child according to the Court Order dated March 1, 2009. 9. A new Order for Custody was entered on March 27, 2009 as a result of the telephone Conciliation Conference in which Father was given visitation on Saturday, March 28, 2009 from 11:00 a.m. to 1:00 p.m. (A true and correct copy of the March 27, 2009, Order of Court is attached hereto as Exhibit D.) 10. An agreement was reached between the parties that Father would not exercise visitation on March 28, 2009 because Mother had to work a 12-hour shift and would begin his scheduled visitation the following Saturday, April 4, 2009. 11. Said Order gave Father visitation of the minor child the next four Saturdays, April 4, 11, 18 and 25, 2009 from 11:00 a.m. to 1:00 p.m. a. Once again, Father did not exercise custody of the minor child on April 4, 2009, because of an outstanding bench warrant for his arrest due to his failure to show at his Petition for Contempt Hearing for Domestic Relations. b. Father did not exercise custody of the minor child on April 11, 2009, because he alleges he did not know where the Defendant is currently residing; however, he is aware that the Plaintiff is currently staying with her grandmother and would know this address from when the Plaintiff and the Defendant were a couple. 12. Plaintiff initially filed his Complaint for Custody in January requesting visitation of his daughter and since then he has not made a single scheduled Court Ordered visitation; visitations in which he had initially requested. 13. Defendant believes and therefore avers that she has made every effort to be available for the Plaintiff on Saturday morning; however, Plaintiff has provided excuse after excuse. 14. Defendant believes and therefore avers that if the Plaintiff truly wanted to spend time with his daughter he would make every effort to get to Carlisle to be with her during the scheduled time, rather then spend the time arguing with the Defendant on the phone that it will take too long to drive from York to Carlisle to get there and "he'll be late". 15. Defendant believes and therefore avers that the Plaintiff is having these conversations on his cellular phone and can continue the phone call while driving if he so desires to see is daughter; however he would rather just cancel the visit and make an excuse. 16. Defendant believes and therefore avers that she has incurred unnecessary legal fees and costs to address this matter and is now asking that the Plaintiff be responsible for these costs since it appears that he does not take his initial filing seriously and has wasted not only the Court's time, but the Defendant's time and money. WHEREFORE, Mother/Defendant requests that the Court modify the existing order for partial custody, grant Mother full physical and legal custody of the child and ask that the Father/Plaintiff be responsible for all counsel fees and costs associated with this docketed matter. Respectfully submitted, DATE ABOM & KUTULAKIS, L.L.P. Michelle L. Somme , squire Supreme Court ID No. 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Defendant I, SAMANTHA HANCOCK, verify that the statements made in this Petition to Modify Custody are true and correct. 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 ?y t15# J, ROWEN SINGLETON : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW SAMANTHA HANCOCK : NO.09- _3a 7 CIVIL TERM Defendant. : IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, Rowen Singleton, by and through his attorney, Mark F. Bayley, Esquire, and presents the within complaint for custody, representing as follows: 1. The Plaintiff, Rowen Singleton, is an adult individual residing at 239 West Market Street, Apt. A, York, Pennsylvania 17401. 2. The Defendant, Samantha Hancock, is an adult individual; her current address is unknown. 3. Plaintiff seeks custody of the following children: Name Present Residence Age D/OB Skyla Hancock With Mother (unknown) 2 years 12/14/06 Jaquez (last name on With Mother (unknown) 1 year 11/07 Birth certificate Unknown) 4. The children were born out of wedlock. 5. The relationship of the Plaintiff to the children is that of natural father. The Father currently resides with a roommate, Candice Raines. Plaintiff is not married. 6. The relationship of the Defendant to the children is that of natural mother. The Mother currently resides with the children. Defendant is not married. 7. During the past five years the children have resided with: EXI IIBIT A _.. Name Address Date Defendant Unknown Fall of '08 to present Defendant 309 B North Pitt St., Carlisle, PA 12/06-Fall of '08 8. The Plaintiff has not participated as a party or witness, or in another capacity in other litigation concerning the custody of the children in this or any other Court. 9. Plaintiff has no information of a custody proceeding concerning the children pending in any Court of this Commonwealth or any other state. 10. Other than as noted above, Plaintiff does not know of a person nor a party to the proceeding who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 11. The best interests and permanent welfare of the child require the parties to have periods of physical custody which may be agreed upon or otherwise be determined by the Court to be in the best interests of the children. WIEREFORE, Plaintiff requests this Honorable Court to schedule a custody conciliation conference. Date: ?U/ Respectfully submitted, B & AN F. Bayley, E*ire 17 West South S t Carlisle, PA 17013 (717) 241-2446 Supreme Court ID # 87663 Attorney for Plaintiff ROWEN SINGLETON : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW SAMANTHA HANCOCK : NO. 09- CIVIL TERM Defendant. : IN CUSTODY VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unworn falsification to authorities. 4w Lx&7 R wen S' eton, Plaintiff n C N c° O ?. .v T7 a= Fri t _ v jR7 p `? ``? Co 111-t i" ' ? C Cr"iT;.1. .;r ,n wt ; . y 2069 FEB -2 Pli 2: 4 5 Y /. FEjP 2 F?1111 "/ ROWEN SINGLETON, Plaintiff V. SAMANTHA HANCOCK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-327 IN CUSTODY ORDER OF COURT CIVIL ACTION - LAW AND NOW, this day of 4-L , 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Rowen Singleton and the Mother, Samantha Hancock, shall have shared legal custody of Skyla Hancock, born December 14, 2006. 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 her health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 2. Mother shall have primary physical custody of the child. 3. Mother shall cooperate with a paternity test to determine whether Plaintiff is the father of Jaquez. Plaintiff shall pay for said paternity test. 4. Father shall have periods of partial physical custody of Skyla as follows: A. Saturday, February 28, 2009 from 11:00 a.m. to 1:00 p.m. This visit shall occur at Mother's home. ENHBIT B B. The next 4 Saturdays, March, 7, 14, 21, and 28, 2009 from 11:00 a.m. to 1:00 p.m. Father may take the child away from Mother's home. C. The next 8 Saturdays, April 4, 11, 18, and 25, 2009 and May 2, 9, 16, 23, 2009, from 10:00 a.m. to 2:00 p.m. . 5. Father shall be responsible for all transportation and shall have an appropriate car seat for the child. 6. Father shall not use alcoholic beverages of illegal drugs immediately before or during his periods of physical custody. 7. 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. Another Custody Conciliation Conference is scheduled for May 26, 2009 at 8:30 a.m. BY THE COURT, cc: Mark F. Bayley, Esquire, Counsel for Father Michelle Sommer, Esquire, Counsel for Mother ROWEN SINGLETON, Plaintiff V. SAMANTHA HANCOCK, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-327 CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Skyla Hancock December 14, 2006 Mother Jaquez Knight October 29, 2007 Mother 2. A Conciliation Conference was held in this matter on February 26, 2009, with the following in attendance: The Father, Rowen Singleton, with his counsel, Mark F. Bayley, Esquire, and the Mother, Samantha Hancock, with her counsel, Michelle Sommer, Esquire. 3. Mother asserted that Plaintiff was not the father of Jaquez. Father offered to pay for a paternity test to determine if he is the father. 4. The parties agreed to an Order in the form as attached. Date acq line M. Verney, Esquire Custody Conciliator BO M ?' KA UTULAKIS .TroaM1E.s AT L,,. March 16, 2009 VIA FACSIMILE 243-3518 AND REGULAR MAIL Jacqueline M. Verney, Esquire 44 South Hanover Street Carlisle, PA 17013 Re. Rouen Sim u Sa mnfl aHancot* Dbc kd Na: 2009-327 OurFileNa: 09.058 Dear Attorney Verney: OFFICE LOCATIONS CARLISLE OFFICE (717) 249-0900 HARRISBURG OFFICE (717) 232-9511 CHAMBERSBURG OFFICE (717) 267-0900 YORK OFFICE (717) 846-0900 Based upon the Order of Court that was signed by Judge Oler on March 1, 2009, Father was to begin his periods of partial physical custody of Skyla beginning on Saturday, February 28, 2009 from 11:00 a.m. to 1:00 p.m. Father has failed to pick up the child for any of his scheduled visitation time. I am requesting a conference call be scheduled to discuss how we should proceed in this matter. Mr. Singleton is the one who initiated this matter to receive visitation time with his daughter but has yet to avail himself of any of the scheduled time to be with his daughter. Ms. Hancock has made Skyla available and sat at home waiting for Mr. Singleton to pick up the child only to be told by Mr. Singleton that he would not be coming to pick her up, three weeks in a row. If you are willing to schedule a conference call to discuss this matter, please contact my office and speak with my assistant, Tracy. Thank you for your attention to this matter. Sincerely, M&KUIUAEZSy LLP. Michelle L. Sommer MLS/tlf cc: Mark F. Bayley, Esquire Samantha Hancock Reply To: 36 SOUTH HANOVER STREET ENIRBIT CARLISLE, PA 17013 (717) 249-0900 FAx(717) 249-3344 MAR 2 7 Z009 ROWEN SINGLETON, Plaintiff V. SAMANTHA HANCOCK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-327 : IN CUSTODY ORDER OF COURT CIVIL ACTION - LAW AND NOW, this day of M5e r . , 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated March 1, 2009 shall remain in full force and effect with the following modifications: 2. Paragraph 4 shall be deleted in its entirety and replaced with the following: Father shall have periods of partial physical custody of Skyla as follows: A. Saturday, March 28, 2009 from 11:00 a.m. to 1:00 p.m. This visit shall occur at Mother's home. A. The next 4 Saturdays, April 4, 11, 18, and 25, 2009 from 11:00 a.m. to 1:00 p.m. Father may take the child away from Mother's home. B. The next 8 Saturdays, May 2, 9, 16, and 23, 2009 and June 6, 13, 20, 27, 2009 from 10:00 a.m. to 2:00 p.m. . 3. 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. Another Custody Conciliation Conference is scheduled for June 29, 2009 at 8:30 a.m> BY THE COURT, J. WeRey Oler, Jr., J EM- BIT cc: Mark F. Bayley, Esquire, Counsel for Father Michelle Sommer, Esquire, Counsel for Mother- & $ ?: 4d am 4i" tiaR':`.d Z tat < . ? + Pa .. MAR 2 7'Wog ROWEN SINGLETON, Plaintiff V. SAMANTHA HANCOCK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-327 CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., J. 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 Skyla Hancock December 14, 2006 Mother 2. A telephone Conciliation Conference was held in this matter on March 26, 2009, with the following in attendance: Father's counsel, Mark F. Bayley, Esquire, and Mother's counsel, Michelle Sommer, Esquire. 3. The Honorable J. Wesley Oler, Jr. entered an Order of Court dated March 1, 2009 providing for shared legal custody, Mother having primary physical custody with Father having a phased-in partial physical custody schedule. 4. Mother's counsel asserted that Father had not exercised any of the time set forth in the Order of Court dated March 1, 2009. Father's counsel asserted that Father had various excuses for not exercising the time and requested another opportunity to do so. Counsel for the parties agreed to an Order in the form as attached. 3-J&-oq Q?? bt. Vie, Date acq ne M. Verney, Esquire Custody Conciliator AND NOW, this X0'1 day of April, 2009, I, Michelle L. Sommer, Esquire, of Abom & Kutulakis, L.L.P., hereby certify that I did serve a true and correct copy of the foregoing Petition for Modification of Custody, upon the Plaintiff, through his attorney, by depositing, or causing to be deposited, same in the United States First-class mail, postage prepaid addressed to the following: Mark F. Bayley, Esquire 17 West South Street Carlisle, PA 17013 Attorney for the Plaintiff Respectfully submitted, ABOM & KuTULmas, L.L.P. Um'w i &Wwo Michelle L. Sommer, Esquire Supreme Court ID No. 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Defendant R E } AGE QE THE P 'HONOTARY 2009 APR 16 Ali 10: v 4 CutAC'?.-: .L ': J, MY RENN'SYb/,^, ,?iA -4?0. d? 7? W lb) 2 ?(? Wol 3 70 ROWEN SINGLETON IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-327 CIVIL ACTION LAW SAMANTHA HANCOCK IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, April 21, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, May 21, 2009 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. 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/ ac ueline M. Verne Es . 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 OF THE TARY 2004 APP 21 PH 12:5 3 rr,,?(33,„ l?V,v .J ? , ,+ 7 MAY 2 2 U ROWEN SINGLETON, Plaintiff V. SAMANTHA HANCOCK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-327 : IN CUSTODY ORDER OF COURT CIVIL ACTION - LAW AND NOW, this z 7 l'day of 44,7 , 2009, upon consideration of the attached Custody Conciliation R rt, it is ordered and directed as follows: 1. The prior Orders of Court dated March 1, 2009 and March 27, 2009 shall remain in full force and effect with the following modifications: 2. Father's periods of partial physical custody are as follows: A. The next 4 Saturdays, May 23 and 30, 2009 and June 6 and 13, 2009 from 11:00 a.m. to 1:00 p.m. B. The next 8 Saturdays, June 20, 27, July 4, 11, 18, 25 and August 1 and 8, 2009 from 10:00 a.m. to 2:00 p.m. . 3. The parties shall exchange custody at the McDonald's on Walnut Bottom Road in Carlisle. 4. 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. Another Custody Conciliation Conference is scheduled for August 5, 2009 at 9:30 a.m. BY THE COURT, Oler, Jt', cc: Z. F. Bayley, Esquire, Counsel for Father -**"Michelle Sommer, Esquire, Counsel for Mother ?s?as/o9 ,1- J. ,J, i ROWEN SINGLETON, Plaintiff V. SAMANTHA HANCOCK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-327 CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., J. 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 Skyla Hancock December 14, 2006 Mother 2. A Conciliation Conference was held in this matter on May 21, 2009, with the following in attendance: Mother, Samantha Hancock, with her counsel, Michelle Sommer, Esquire and Father, Rowen Singleton, with his counsel, Mark F. Bayley, Esquire. 3. The Honorable J. Wesley Oler, Jr. entered Orders of Court dated March 1, 2009 and March 27, 2009 providing for shared legal custody, Mother having primary physical custody with Father having a phased-in partial physical custody schedule. 4. Mother's counsel asserted that Father had not exercised any of the time set forth in the Orders of Court dated March 1, 2009 and March 27, 2009. Father's counsel asserted that Father had various excuses for not exercising the time, including not knowing where Mother had moved to, and requested another opportunity to do so. 5. Counsel for the parties agreed to an Order in the form as attached. 5 9 Date a eline M. Verney, Esquire Custody Conciliator .~ ROWEN SINGLETON, Plaintiff V. SAMANTHA HANCOCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2009-327 IN CUSTODY ORDER OF COURT CIVIL ACTION -LAW AND NOW, this ~~ day of , 2009, upon consideration of the attached Custody Conciliation port, it is ordered and directed as follows: 1. The prior Orders of Court dated March 1, 2009, March 27, 2009 and May 27, 2009 shall remain in full force and effect with the following modifications: 2. Father's periods of partial physical custody are as follows: A. Beginning August 8, 2009 and alternating Saturdays thereafter, from 11:00 a.m. to 1:00 p.m. with the condition that Father shall text Mother the preceding Thursday by 5:00 p.m. to advise whether he will be there or not. If he does not text her by 5:00 p.m. on the preceding Thursday, then Mother has no obligation to be at the meeting place. If a Saturday is missed, Father will be entitled to the next alternating Saturday assuming he texts Mother as provided herein. B. Such other times as the parties agree. 3. The parties shall exchange custody at the McDonald's on Walnut Bottom Road in Carlisle. 4. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, / J esley Oler, Jr cd~ark F. Bayley, Esquire, Counsel or Father / Michelle Sommers Esquire, Counsel for Mother Co ~ E.s /~-~.t~ 8 ~ dq J. ~~: ~Fiw ~r ~' A ,~}~,~Y 2G~9 r~~1~ -7 ~ I~~~ ~.~ ' . ; lh f ROWEN SINGLETON, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : N0.2009-327 CIVIL ACTION -LAW SAMANTHA HANCOCK, Defendant : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., J. 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 CURRENTLY IN CUSTODY OF Skyla Hancock December 14, 2006 Mother 2. A Conciliation Conference was held in this matter on August 5, 2009, with the following in attendance: Mother, Samantha Hancock, with her counsel, Michelle Sommer, Esquire and Father, Rowen Singleton, with his counsel, Mark F. Bayley, Esquire. 3. The Honorable J. Wesley Oler, Jr. entered Orders of Court dated March 1, 2009, March 27, 2009, and May 27, 2009 providing for shared legal custody, Mother having primary physical custody with Father having aphased-in partial physical custody schedule. 4. Mother asserted that Father, except for a'/2 hour visit at day care after the last conciliation conference, had not exercised any of the time set forth in the Orders of Court dated March 1, 2009, March 27, 2009 and May 27, 2009. Father admitted it was his fault he had not visited, but believed when he missed the first time after the last conciliation conference, that he could not visit anymore. 5. The parties agreed to an Order in the form as attached. ~'S=o ~ ~- Date Jac line M. Verney, Esquire Custody Conciliator