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HomeMy WebLinkAbout09-0465 Jay R. Braderman, Esquire Todd C. Hough, Esquire Lavery, Faherty, Young & Patterson, P. C. 225 Market Street, Suite 304 P. O. Box 1245 Harrisburg, PA 17108-1245 717.233.6633 Attorneys for Plaintiff RACHEL M. BLOUCH, Plaintiff V. BRADLEY S. BLOUCH and SARAH DAWSON, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04- L f 0 !!r CIVIL ACTION -LAW IN CUSTODY NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY AN 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 RELIEF REQUESTED B THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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, PA 17013 717-249-3166 The Court of Common Pleas of Cumberland County is required by law to comply with the American with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. Jay R. Braderman, Esquire Todd C. Hough, Esquire Lavery, Faherty, Young & Patterson, P.C. 225 Market Street, Suite 304 P. O. Box 1245 Harrisburg, PA 17108-1245 717.233.6633 Attomeys for Plaintiff RACHEL M. BLOUCH, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNSYLVANIA V. BRADLEY S. BLOUCH NO. and SARAH DAWSON, Defendants CIVIL ACTION -LAW IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes Plaintiff, Rachel Blouch, hereinafter referred to as "Mother," by and through her attorneys, Todd C. Hough, Esquire, and Lavery, Faherty, Young & Patterson, P.C., and files the following Complaint for Custody and in support of said Complaint avers the following: 1. Mother is an adult individual currently residing at 4460 Hodges Blvd., Apartment 105, Jacksonville, Duval County, Florida. 2. Defendant Bradley S. Blouch, hereinafter referred to as "Father," is an adult individual currently residing at the same address as Mother. 3. Father is an active duty member of the United States Navy and is currently at sea on the USS Roosevelt (DDG 80). 4. Mother seeks primary physical custody of the following child: NAME ADDRESS DATE OF BIRTH Gabriel Bradley Blouch same as Mother June 5, 2005 The child was born out of wedlock. It is believed the child is presently in the custody of Defendant Sarah Dawson, the child's paternal grandmother, who resides at 389 Pin Oak Lane, Carlisle, Cumberland County, Pennsylvania. Since the child's birth, the child has resided with the following persons at the following addresses: NAME Rachel M. Blouch Jan Renfroe Rand S. Renfroe Cole S. Renfroe Rachel M. Blouch Bradley S. Blouch Rachel M. Blouch Jan Renfroe Rand S. Renfroe Cole S. Renfroe Rachel M. Blouch Bradley S. Blouch Rachel M. Blouch Bradley S. Blouch Rachel M. Blouch Bradley S. Blouch ADDRESS DATES Oroville, WA 6/5/05 through 9/05 Waukegan, IL 9/05 through 3/06 Oroville, WA 3/06 through 6/06 3131 University Blvd., Apt. 15 6/06 through 6/07 Jacksonville, FL 32211 8050 Arlington Exp., Apt. Q1207 06/07 through 06/08 Jacksonville, FL 32211 4460 Hodges Blvd., Apt 105 06/08 through present Jacksonville, FL 32224 The mother of the child is Rachel M. Blouch, residing as referenced above. The father of the child is Bradley S. Blouch, residing as referenced above. The parties are currently married. 5. The relationship of Plaintiff to the child is that of Mother. The Plaintiff currently resides with the following persons: Bradley S. Blouch Gabriel B. Blouch 6. The relationship of Defendant to the child is that of Father. The Defendant currently resides with the following persons: Rachel M. Blouch Gabriel B. Blouch 7. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. Plaintiff knows of two people not a party to the proceeding that have physical custody of the child or claims to have custody or visitation rights with respect to the child. The names and addresses of these people are: NAME ADDRESS Scott D. Blouch 2225 Parkway West, Harrisburg, PA 17112 Sarah Dawson 389 Pin Oak Lane, Carlisle, PA 17015 8. The best interest and permanent welfare of the child will be served by granting the relief requested because Mother has been the primary caretaker of the child since birth and Father is currently an active duty sailor subject to rapid deployment and sea duty. 9. 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 have been given notice of the pendency of this action and the right to intervene: NAME ADDRESS BASIS OF CLAIM Scott D. Blouch 2225 Parkway West, Unknown Harrisburg, PA 17112 WHEREFORE, Plaintiff respectfully requests this Honorable Court to grant Plaintiff primary physical custody of the child. Respectfully submitted, DATE: / /ZO /,0 Lavery, Faherty, Young & Patterson, P.C. By: T C. Hough, Esquire Atty No. 91060 225 Market Street, Suite 304 P.O. Box 1245 Harrisburg, PA 17108-1245 Attys for Plaintiff VERIFICATION I verify that the statements made in this Pleading are true and correct. 1 understar4 that false statements herein are made subject to the penalties of 18 Pa.C.s. § 4904 relating to unswom falsification to authorities. r? z9 zoQ 9 !, , RACHEL M. BLOUCCH------ r ?. ra z-?s ? ? 4 ? f ? ; ? ? J , ..? ??? ?? W 'te`a ,"? ..,- ^? r Jay R. Braderman, Esquire Todd C. Hough, Esquire Lavery, Faherty, Young & Patterson, P.C. 225 Market Street, Suite 304 P. O. Box 1245 Harrisburg, PA 17108-1245 717.233.6633 Attomeys for Plaintiff RACHEL M. BLOUCH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. BRADLEY S. BLOUCH No. 0%-?(lOS and SARAH DAWSON, Defendants CIVIL ACTION -LAW IN CUSTODY EMERGENCY PETITION FOR SPECIAL RELIEF AND NOW comes Plaintiff, Rachel Blouch, hereinafter referred to as "Mother,„ by and through her attorneys, Todd C. Hough, Esquire, and Lavery, Faherty, Young & Patterson, P.C., and files the following Emergency Petition for Special Relief and in support of said Emergency Petition avers the following: 1. Mother is an adult individual currently residing at 4460 Hodges Blvd., Apartment 105, Jacksonville, Duval County, Florida. 2. Defendant Bradley S. Blouch, hereinafter referred to as "Father," is an adult individual currently residing at the same address as Mother. 3. Father is an active duty member of the United States Navy and is currently at sea on the USS Roosevelt (DDG 80). 4. Defendant Sarah Dawson, hereinafter referred to as "Paternal Grandmother," is an adult individual currently residing at 389 Pin Oak Lane, Carlisle, Cumberland County, Pennsylvania. 5. Mother and Father are the natural parents of the following minor child: Gabriel B. Blouch, born on June 5, 2005. 6. Mother has been the primary caregiver for the child since his birth. 7. Scott D. Blouch, hereinafter referred to as "Paternal Grandfather," is an adult individual currently residing at 2225 Parkway West, Harrisburg, Dauphin County, Pennsylvania. 8. On or about January 2, 2009, Father asked Mother if she would agree to allow the child to spend some time with Father's parents in Pennsylvania. 9. Mother agreed to allow the child to spend three weeks with Paternal Grandfather with the expectation that the child would be returned to her in Jacksonville, Florida, on January 24, 2009. 10. On or about January 3, 2009, Paternal Grandfather transported the child from Jacksonville, Florida to his residence in Harrisburg, Pennsylvania. 11. Mother spoke with the child by telephone almost every night during the three-week visit. 12. On January 22, 2009, Father called Mother and asked if the child could stay in Pennsylvania until he returned from his sea duty. 13. Mother refused and asked to have the child returned to her on January 24, 2009 as originally planned. 14. Later on January 22, 2009, Mother received a phone call from Paternal Grandfather saying that he could not afford to drive back down to Jacksonville, Florida, so he would just continue to keep the child. 15. Mother said this was unacceptable and said that she would drive to Harrisburg on January 23, 2009, arriving on January 24, 2009, in order to pick up the child. 16. On January 24, 2009, while Mother was en route to Harrisburg, Paternal Grandfather called her and said that she should not come to Pennsylvania because he had been given "custody papers" by Father and would be using those "papers" to gain custody of the child. Additionally, he said he did not have the child as the child was with Sarah Dawson, hereinafter referred to as "Paternal Grandmother," a resident of Cumberland County, Pennsylvania. 17. Paternal Grandmother has also refused to return the child to Mother. 18. No custody action has been filed with the Dauphin County Prothonotary or Cumberland County Prothonotary as of January 29, 2009. 19. Pursuing the custody matter though the normal litigation process could cause irreparable harm to the child, therefore, Mother requests special relief for the following reasons: A. Mother allowed the child to visit Paternal Grandfather with the understanding that the child would be returned to her on January 24, 2009. B. Grandfather has refused to return the child to Mother without reason. C. Mother has not been permitted to speak to child on January 25, 2009 or January 26, 2009. D. On January 28, 2009, Paternal Grandmother said that child is suffering from asthma and requested that Mother send child's asthma medication to her, however it was not a rush because she had some medication the child could use. E. It is believed that Paternal Grandparents are trying to turn the affections of the child against Mother because on January 28, 2009, child adamantly refused to speak to Mother on the telephone, except to say "Goodnight." F. Grandfather was entrusted with the care of the child by Mother and he has now transferred care of the child to another without Mother's permission and against Mother's wishes. G. Neither Grandparent has standing under 23 Pa.C.S § 5313 with which to pursue an action for custody of child. H. It is believed that Father is attempting to manipulate the legal system by inducing his parents to hold the child in Pennsylvania against Mother's wishes and her rights as a parent to legal custody and primary physical custody of the child. Under the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA), 23 Pa.C.S.A. § 5401 et seq., proper jurisdiction of this custody dispute lies in Duval County, Florida as that jurisdiction is the "home state" of the parties and has the necessary connection to the parties and the child, being the residence of Mother, Father and the child since June 2006, and upon the child's return to Mother, the custody matter should proceed before the appropriate court in that jurisdiction. WHEREFORE, Plaintiff requests this Honorable Court grant her Emergency Petition for Special Relief and: 1. Order the immediate return of the child to Mother's custody; and 2. Transfer the matter to Duval County Circuit Court, Duval County, DATE: Florida, under the provisions of the UCCJEA for further handling in accordance with the local rules within that jurisdiction. Respectfully submitted, BY: Todd ough, Esquire Atty No. 91060 Lavery, Faherty, Young & Patterson, P.C. 225 Market Street, Suite 304 P.O. Box 1245 Harrisburg, PA 17108-1245 Attorneys for Plaintiff VERIFICATION I verify that the statements made in this Pleading are true and correct. I understhrnj that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. C RACHEL M. BLOLj?- '^ JAN 29 2009y_ RACHEL M. BLOUCH, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA V. BRADLEY S. BLOUCH NO. and CIVIL ACTION - LAW SARAH DAWSON, IN CUSTODY Defendants ORDER OF COURT AND NOW, this 30.- day of , 2009, based upon the pleadings presented it is hereby ORDERED and DECREED that: 1) Gabriel B. Blouch, born June 5, 2005, shall be immediately returned to Mother's care; end-- /4? a,,;, ?vr ?? - 2) Further can in this tter shall a staye 1!e this ourt Duval County, Florida. 0/,00,000,2 'Poo i i a' , `Ftl a.3., l'7 _?-I CL ?.. C-4 I" ?t Jay R. Biederman, Esquire Todd C. Hough, Esquire Lavery, Faherty, Young & Patterson, P.C. 225 Market Street Suite 304 P. O. Box 1245 Harrisburg, PA 17108-1245 717.233.6633 Attorneys forP/aintiff RACHEL M. SLOUCH, Plaintiff V. BRADLEY S. BLOUCH and SARAH DAWSON, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09 - 465 CIVIL ACTION -LAW IN CUSTODY EMERGENCY PETITION FOR CONTEMPT AND ENFORCEMENT AND NOW comes Plaintiff, Rachel Blouch, hereinafter referred to as "Mother," by and through her attorneys, Todd C. Hough, Esquire, and Lavery, Faherty, Young & Patterson, P.C., and files the following Emergency Petition for Special Relief and in support of said Emergency Petition avers the following: 1. Mother is an adult individual currently residing at 4460 Hodges Blvd., Apartment 105, Jacksonville, Duval County, Florida. 2. Defendant Bradley S. Blouch, hereinafter referred to as "Father," is an adult individual currently residing at the same address as Mother. 3. Father is an active duty member of the United States Navy and is currently at sea on the USS Roosevelt (DDG 80). 4. Defendant Sarah Dawson, hereinafter referred to as "Paternal Grandmother," is an adult individual currently residing at 389 Pin Oak Lane, Carlisle, Cumberland County, Pennsylvania. 5. On January 30, 2009, the Honorable Kevin A. Hess entered the following Emergency Custody Order (attached hereto as Exhibit A): "AND NOW, this 3e day of January, 2009, based upon the pleadings presented it is hereby ORDERED and DECREED that: Gabriel B. Blouch, born June 5, 2005, shall be immediately returned to Mother's care pending further order." 6. Since the entry of said Order, Paternal Grandmother has willfully failed to obey said Order as follows: a. Upon receipt of the January 30, 2009 Emergency Order on February 2, 2009, Mother made the 13-hour car ride to Pennsylvania from her residence in Jacksonville, Florida. b. On February 3, 2009, at approximately 5:00 p.m., Mother and Pennsylvania State Constable Michael P. Maugans arrived at Paternal Grandmother's residence at the address stated above. C. Constable Maugans presented Paternal Grandmother with a copy of the January 30, 2009 Emergency Order signed by Judge Hess ordering the child's immediate return to Mother's care. d. Paternal Grandmother refused to return the child to Mother's care. e. The child was present at Paternal Grandmother's residence as he attempted to come to the door to see Mother and was told to stay in the house by Paternal Grandmother. f. Paternal Grandmother presented Mother with a copy of an Emergency Motion to Maintain Temporary Placement of Minor Child that was purportedly filed on Father's behalf in Duval County, Florida, on February 3, 2009, four days after the January 30, 2009 Order of Judge Hess was entered. g. No Order was attached to the pleading and there is no indication that the pleading was indeed filed with the Duval County Circuit Court. h. As Mother has no friends or family in the area with which to stay temporarily, Mother has been forced to stay in a hotel in Carlisle, Pennsylvania, in order to seek enforcement of the January 30 2009 Order. i. Mother has to further engage the services of an attorney, at considerable cost ($175.00 hour x approx. 3 hours), in order to seek Paternal Grandmother's compliance with the January 30, 2009 Order of Judge Hess. Paternal Grandmother's refusal to return the child to Mother's care directly contravenes the January 30, 2009 Order of Judge Hess. WHEREFORE, due to the distance traveled by Mother and her need to stay in a motel while awaiting enforcement of the January 30, 2009 Order, Mother respectfully requests this Honorable Court adjudge Paternal Grandmother in contempt of Court and direct the Middlesex Township Police Department or Cumberland County Sheriffs Department to accompany Mother to Paternal Grandmother's residence and enforce the January 30, 2009 Order to include the return of child's clothing. Respectfully submitted, DATE: '71?1 /-0 Lavery, Fahe ung rson, P.C. By: Todd C. Hough, Esquire Atty No. 91060 225 Market Street, Suite 304 P.O. Box 1245 Harrisburg, PA 17108-1245 Attys for Plaintiff AN 4,E) 200 RACHEL M. BLOUCH, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA V. BRADLEY S. BLOUCH NO. and CIVIL ACTION - LAW SARAH DAWSON, IN CUSTODY Defendants ORDER OF COURT AND NOW, this 30a day of , 2009, based upon the pleadings presented it is hereby ORDERED and DECREED that: 1) Gabriel B. Blouch, bom June 5, 2005, shall be immediately retumed to Mother's care; aad ptnj;nj Ar+h w or&ft 2) %rlher::,nn this shall be s w i ou the tra r of this cu v matt t D a tv x Couw, PY RECD in t'eow" wh4r ,1 *0 wdq od y herd . Q 9 eA 4 1. 10 j J. Jay R. Bradennan, Esquire Todd C. Hough, Esquire Lavery, Faherty, Young & Patterson, P. C. 225 Market Stres( Sure 304 P. O. Box 1245 Hanisburg, PA 17108-1245 717.233.6633 Attomeys for Piaini f RACHEL M. BLOUCH, Plaintiff V. BRADLEY S. BLOUCH and SARAH DAWSON, Defendants -r: n ? O : IN THE COURT OF COMMON KEASC : OF CUMBERLAND COUNTY, PhNNS LV/si 1 _n Si! NO. =2 `; C C, CIVIL ACTION -LAW IN CUSTODY EMERGENCY PETITION FOR SPECIAL RELIEF AND NOW comes Plaintiff, Rachel Blouch, hereinafter referred to as "Mother," by and through her attorneys, Todd C. Hough, Esquire, and Lavery, Faherty, Young & Patterson, P.C., and files the following Emergency Petition for Special Relief and in support of said Emergency Petition avers the following: 1. Mother is an adult individual currently residing at 4460 Hodges Blvd., Apartment 105, Jacksonville, Duval County, Florida. 2. Defendant Bradley S. Blouch, hereinafter referred to as "Father," is an adult individual currently residing at the same address as Mother. 3. Father is an active duty member of the United States Navy and is currently at sea on the USS Roosevelt (DDG 80). 4. Defendant Sarah Dawson, hereinafter referred to as "Paternal Grandmother," is an adult individual currently residing at 389 Pin Oak Lane, Carlisle, Cumberland County, Pennsylvania. 5. Mother and Father are the natural parents of the following minor child: Gabriel B. Blouch, bom on June 5, 2005. 6. Mother has been the primary caregiver for the child since his birth. 7. Scott D. Blouch, hereinafter referred to as "Paternal Grandfather," is an adult individual currently residing at 2225 Parkway West, Harrisburg, Dauphin County, Pennsylvania. 8. On or about January 2, 2009, Father asked Mother if she would agree to allow the child to spend some time with Father's parents in Pennsylvania. 9. Mother agreed to allow the child to spend three weeks with Paternal Grandfather with the expectation that the child would be returned to her in Jacksonville, Florida, on January 24, 2009. 10. On or about January 3, 2009, Paternal Grandfather transported the child from Jacksonville, Florida to his residence in Harrisburg, Pennsylvania. 11. Mother spoke with the child by telephone almost every night during the three-week visit. 12. On January 22, 2009, Father called Mother and asked if the child could stay in Pennsylvania until he returned from his sea duty. 13. Mother refused and asked to have the child returned to her on January 24, 2009 as originally planned. 14. Later on January 22, 2009, Mother received a phone call from Paternal Grandfather saying that he could not afford to drive back down to Jacksonville, Florida, so he would just continue to keep the child. 15. Mother said this was unacceptable and said that she would drive to Harrisburg on January 23, 2009, arriving on January 24, 2009, in order to pick up the child. 16. On January 24, 2009, while Mother was en route to Harrisburg, Paternal Grandfather called her and said that she should not come to Pennsylvania because he had been given "custody papers" by Father and would be using those "papers" to gain custody of the child. Additionally, he said he did not have the child as the child was with Sarah Dawson, hereinafter referred to as "Paternal Grandmother," a resident of Cumberland County, Pennsylvania. 17. Patemal Grandmother has also refused to return the child to Mother. 18. No custody action has been filed with the Dauphin County Prothonotary or Cumberland County Prothonotary as of January 29, 2009. 19. Pursuing the custody matter though the normal litigation process could cause irreparable harm to the child, therefore, Mother requests special relief for the following reasons: A. Mother allowed the child to visit Paternal Grandfather with the understanding that the child would be returned to her on January 24, 2009. B. Grandfather has refused to return the child to Mother without reason. C. Mother has not been permitted to speak to child on January 25, 2009 or January 26, 2009. D. On January 28, 2009, Paternal Grandmother said that child is suffering from asthma and requested that Mother send child's asthma medication to her, however it was not a rush because she had some medication the child could use. E. It is believed that Paternal Grandparents are trying to turn the affections of the child against Mother because on January 28, 2009, child adamantly refused to speak to Mother on the telephone, except to say "Goodnight." F. Grandfather was entrusted with the care of the child by Mother and he has now transferred care of the child to another without Mother's permission and against Mother's wishes. G. Neither Grandparent has standing under 23 Pa.C.S § 5313 with which to pursue an action for custody of child. H. It is believed that Father is attempting to manipulate the legal system by inducing his parents to hold the child in Pennsylvania against Mother's wishes and her rights as a parent to legal custody and primary physical custody of the child. 1. Under the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA), 23 Pa.C.S.A. § 5401 et seq., proper jurisdiction of this custody dispute lies in Duval County, Florida as that jurisdiction is the "home state" of the parties and has the necessary connection to the parties and the child, being the residence of Mother, Father and the child since June 2006, and upon the child's return to Mother, the custody matter should proceed before the appropriate court in that jurisdiction. WHEREFORE, Plaintiff requests this Honorable Court grant her Emergency Petition for Special Relief and: 1. Order the immediate return of the child to Mother's custody; and 2. Transfer the matter to Duval County Circuit Court, Duval County, DATE: Florida, under the provisions of the UCCJEA for further handling in accordance with the local rules within that jurisdiction. /11-7 /OP10 If BY: Todd C:-Hough, Esquire Atty No. 91060 Lavery, Faherty, Young & Patterson, P.C. 225 Market Street, Suite 304 P.O. Box 1245 Harrisburg, PA 17108-1245 Attorneys for Plaintiff Respectfully submitted VERIFICATION 1 verily that the statements made in this Pleading are true and corroct. I undomtm4 that Use statements herein are made subject ID the penaMes of I$ Pa.C.S. § 4904 relating to unsrwm falaltication tD auUxxtbs. i z9 zoo 9 ; ,9 _X=44 RACHEL M. SLOUCH-----_. CERTIFICATE OF SERVICE I, Todd C. Hough, do hereby certify that on this day I served a true and correct copy of the foregoing Emergency Petition for Special Relief on the following persons in the manner as indicated: Bradley S. Blouch, ET2 USS ROOSEVELT (DDG 80) FPO, AA 34092-1297 Via U. S. Mail, Certified, Retum Receipt Requested, and Via U. S. Mail, First Class Sarah Dawson 389 Pin Oak Drive Carlisle, PA 17015 Via U. S. Mail, Certified, Return Receipt Requested, and Via U. S. Mail, First Class DATE: Z Lavery, Faherty, Young & Patterson, P.C. By: d C. Hough, Esquir Atty No. 91060 225 Market Street, Suite 304 P.O. Box 1245 Harrisburg, PA 17108-1245 Attorneys for Plaintiff 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.C.S. § 4909 relating to unsworn falsification to authorities. .2_y-gWok RACHEL M. BLOUCH -?i, ? ? ?; s 3 . .., ?_ °?y ? ? O ? /; " ? „. ,,} ' ? ? 3 ? ?J C._ ?? .. ??J . '?? r 0 b' h V_ -p? O ',u f t r L? OPI- RACHEL M. BLOUCH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 09-465 CIVIL BRADLEY S. BLOUCH and SARAH DAWSON, Defendants IN CUSTODY IN RE: PLAINTIFF'S EMERGENCY PETITION FOR CONTEMPT AND ENFORCEMENT ORDER AND NOW, this 4/* day of February, 2009, a rule is issued on the defendant, Sarah Dawson, to show cause why she should not be held in contempt of court and why she should not immediately return the child which is the subject of this case. Said rule returnable and to be heard on Friday, February 6, 2009, at 3:30 p.m. The defendant, Sarah Dawson, is directed to have the child, Gabriel B. Blouch, available at the time of the hearing. Service of this order to be made by the Sheriff forthwith. In the event that the defendant fails to appear, an order will be entered in her absence and/or a bench warrant issued for her arrest. Todd Hough, Esquire , For the Plaintiff G6P a e s 5 ??° t 09y91 Michael Tyde, Esquire For the Plaintiff - Florida co? es m ? Diane Paull, Esquire y For Bradley Blouch - Florida _y-69 BY THE COURT, Kevi A. Hess, J. C7 ? w -r} n- ? y- .. ? r4?... v,a v • ?.?r i? I""? a"a ? ?.,1 r ' i ? s RACHEL M. BLOUCH IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-465 CIVIL ACTION LAW BRADLEY S. BLOUCH AND SARAH DAWSON IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, February 03, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse; Carlisle on Friday, February. 13, 2009 at 2:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or pennanent 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/ John . Mangan, r. Es . , LA 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. ear;. + 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 ire 0 :11 wv S- 83A 61102 S o-J. -C RACHEL M. BLOUCH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 09-465 CIVIL BRADLEY S. BLOUCH and SARAH DAWSON, Defendants IN CUSTODY IN RE: PLAINTIFF'S EMERGENCY PETITION FOR CONTEMPT AND ENFORCEMENT ORDER AND NOW, this 6t' day of February, 2009, the paternal grandparents having produced the child, Gabriel, in accordance with our prior direction, it is directed that he be forthwith returned to his mother, the plaintiff, Rachel M. Blouch. Said order is entered upon the mother's assurance that she will cooperate, to the fullest extent possible, with an ongoing investigation by the DCF agency in Florida. Jurisdiction of the underlying custody matter is relinquished to the State of Florida. The complaint, seeking to hold the paternal grandmother, Sarah Dawson, in contempt of court is DISMISSED. ?7'odd Hough, Esquire For the Plaintiff arah Dawson, Pro Se 389 Pin Oak Lane Carlisle, PA 17013 X4ichael Tyde, Esquire For the Plaintiff - Florida Mane Paull, Esquire For Bradley Blouch - Florida BY THE COURT, O C I i wv Q 19316001 JO SHERIFF'S RETURN - REGULAR CASE NO: 2009-00465 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BLOUGH RACHEL M VS BLOUCH BRADLEY S ET AL RONALD E HOOVER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within ORDER OF COURT was served upon DAWSON SARAH the RESPONDANT , at 0018:20 HOURS, on the 4th day of February-, 2009 at 389 PIN OAK LANE CARLISLE, PA 17015 SARAH DAWSON by handing to RESPONDANT a true and attested copy of ORDER OF COURT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Postage Sworn and Subscibed to before me this So Answers: 18.00 5.40 .00 10.00 R. Thomas Kline .42 33.82 02/05/2009 LAVERY, FAHERTY, YOUNG, PATTER By: 1/15 day Deputy Sheriff of , A. D. v