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Home My WebLink About09-1181 CEBRUM GEORGE, II, Plaintiff Vs. BROOK A. HODGE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO..O 9- J1 Y J CIVIL TERM IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff, Cebrum George H, is adult individual residing at 712 Gobin Drive, Carlisle, Cumberland County, PA 17013. 2. The Defendant, Brook A. Hodge, is an adult individual residing at 444 North West Street, Carlisle, Cumberland County, PA 17013. 3. Plaintiff seeks custody of the following child: NAME RESIDENCE Sejhne Amir Lillian Palmer, 444 North West Street Carlisle, PA 17013 The child was born out of wedlock. DOB AGE August 13, 2008 6 months During their lives, the child has resided with the following persons and at the following addresses: NAME ADDRESS Brook A. Hodge and Gwen Palmer 444 North West Street, Carlisle, PA 17013 DATES August 2008 to present 4. The mother of the child is Brook A. Hodge who currently has an address at 444 North West Street, Carlisle, PA 17013 She is unmarried. The father of the child is Cebrum George II who currently resides at 712 Gobin Drive, Carlisle, PA 17013. He is not married. 5. Plaintiff has not participated as a parry or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 6. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested for the following reasons: A. A Court Order of custody and structured visitation is desired so that the Plaintiff and the child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. B. A Court ordered determination of custody is required to avoid continuing conflict between the parties regarding parental responsibility for custody. 8. 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. WHEREFORE, Plaintiff requests the Court to grant shared legal custody and partial physical custody of child to Plaintiff. Respectfully submitted, ANDREWS & JOHNSON By: T to P. Andrews, Esq. A rney for Plaintiff 78 West Pomfret Street Carlisle, PA 17013 Telephone: (717) 243-0123 COMMONWEALTH OF PENNSYLVANIA ) . SS. COUNTY OF CUMBERLAND ) I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. DATE: - ,-9/?r-- Cebrum George 01. CEBRUM GEORGE, II, Plaintiff Vs. BROOK A. HODGE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL TERM : IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that on this date, 2 - 2?-- , 2009, I mailed a copy of Custody Complaint to the following person at the following address by U.S. Mail, Certified mail, postage prepaid, return receipt requested, delivered to addressee only: Brook Hodge 444 North West Street Carlisle, PA 17013 I verify that the statements made in the foregoing Certificate of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unswom falsification to authorities. ANDREWS & JOHNSON By: 0or P. Andrews, Esq. Attorneys for Plaintiff 78 W. Pomfret Street Carlisle, PA 17013 (717) 243-0123 X N ? tV (' w p SV -r a CEBRUM GEORGE, II, : IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2009-1181 CIVIL TERM BROOK A HODGE, Defendant IN CUSTODY PRAECIPE FOR ENTRY OF APPEARANCE To The Prothonotary: Please enter my appearance on behalf of the defendant, BROOK A. HODGE, in the above captioned case. Respectfully submitted, IRWIN & Mq*NIGHT, tl By: Marcus cKnight,11" 60 West omfret Street Carlisle, nnsylvania 17013 (717) 249- 3 Date: March 4, 2009 CEBRUM GEORGE, II, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2009-1181 CIVIL TERM BROOK A HODGE, Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached Praecipe for Entry of Appearance 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: Taylor P. Andrews, Esq. Andrews & Johnson 78 West Pomfret Street Carlisle, PA 17013-3216 By: IRWIN & McIiiIGHT, P.C. 60 WesfPomfret StreetU Carlisle, PA 17013 (717) 249-2353 Supreme Court I.D. No. 25476 Date: March 4, 2009 t AM to -? CEBRUM GEORGE II IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. BROOK A. HODGE DEFENDANT 2009-1181 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, March 04, 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, March 26, 2009 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/ 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 *v,z ?N?/1?SNN?d AiNno? 90:4 Nd ? - HOW ,Pkh- C ,0-h . AWIONOH! d 3HI Jo 301440 -MV G APR 1 5` 2009 G CEBRUM GEORGE, II, Plaintiff V. BROOK A. HODGE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-1181 CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 10day of R Qr% \ , 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Cebrum George, Il and the Mother, Brook A. Hodge, shall have shared legal custody of Sejhne Amir Lillian Palmer, born August 13, 2008. 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. Father shall have the following phased-in periods of partial physical custody and shall be present for all periods of partial physical custody: A. Wednesday, April 15, 2009 from 7 p.m. to 9:00 p.m. and Saturday, April 18, 2009 from 1:00 p.m. to 4:00 p.m., both supervised by Mother. B. Thereafter Father's periods of partial physical custody shall be unsupervised. For the next four weeks, one weekday every week from 5:00 p.m. to 8:00 p.m. and every Saturday from 1:00 p.m. to 4:00 p.m. C. For the next four weeks, two weekdays every week from 5:00 p.m. to 8:00 p.m. and every Saturday from 1:00 p.m. to 4:00 p.m. D. For the next four weeks, two weekdays every week from 5:00 p.m. to 8:00 p.m. and alternating weekends from Friday at 6:00 p.m. to Sunday at 6:00 p.m. E. Thereafter, one weekday overnight each week from 5:00 p.m. to 8:00 a.m. and alternating weekends from Friday at 6:00 p.m. to Sunday at 6:00 p.m. F. Such other times as the parties agree. 4. Holidays: A. Thanksgiving shall be alternated among the parties from 8:00 a.m. to 6:00 p.m. with Mother always having odd numbered years and Father always having even numbered years. B. Christmas shall be divided into two Blocks. Block A shall be from 2:00 p.m. Christmas Eve to 2:00 p.m. Christmas Day and Block B from 2:00 p.m. Christmas Day to 7:00 p.m. December 26. Mother shall have Block A in 2009 and 2010 and Father shall have Block B in 2009 and 2010. Thereafter, Father shall have Block A in odd numbered years and Block B in even numbered years. Mother shall have Block A in even numbered years and Block B in odd numbered years. C. Child's birthday. Each party shall have at least 3 hours of custodial time with the child on the child's birthday. 5. Transportation shall be shared such that the receiving party shall transport, unless otherwise agreed by the parties. 6. In the event that Father takes the child out of state, he shall notify Mother as to the location and a telephone number where the child may be reached. 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. Either party may contact the Conciliator within 90 days of the date of this Order to request another conciliation conference. BY THE COURT, c a for P. Andrews, Esquire, Counsel for Father arcus A. McKnight, Esquire, Counsel for Mother J . 1. 00 :1 's l 91 ?'YV 6'DZ APR 1 5 2009 CEBRUM GEORGE, II, Plaintiff V. BROOK A. HODGE, Defendant PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: I . The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-1181 CIVIL ACTION - LAW : IN CUSTODY DATE OF BIRTH Sejhne Amir Lillian Palmer August 13, 2008 CURRENTLY IN CUSTODY OF Mother 2. A Conciliation Conference was held in this matter on April 14, 2009, with the following in attendance: The Father, Cebrum George, II, with his counsel, Taylor P. Andrews, Esquire, and the Mother, Brook A. Hodge, with her counsel, Marcus A. McKnight, III, Esquire. 3. The parties agreed to an Order in the form as attached. Date icqinee M. Verney, Esquire Custody Conciliator CEBRUM GEORGE, II, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V, : N0.2009-1181 CIVIL ACTION -LAW BROOK A. HODGE, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 14th day of September, 2009, neither party having requested another conciliation conference and ninety days having passed since the last conference, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, i- cq ine M. Verney, Esquire, stody Conciliator CEBRUM GEORGE, II IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA 2009-1181 CIVIL ACTION LAW r...z BROOK A. HODGE 2 IN CUSTODY ter-' DEFENDANT' ,.{T? C3 rV ORDER OF COURT, •- AND NOW, Monday, July 09, 2012 upon consideration of the attached Comply it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the c at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, August 14, 2012 at 2 for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dis if this cannot be accomplished., to define and narrow the issues to be heard by the court, and to enter into a ter 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/ Jacqueline M. Vemey, Esg?? _ Custody Conciliator C r-- c? ; --A C: iliator, PM or The Court of Common Pleas of Cumberland County is required by law to comply with the Amerlicans 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 arrangem nts must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheIuled 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. r Ma cvs q./yic??iyh e, //i, Ae ?eebraev' 6eor3e, // vl,Pcp,ab?ie X. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ?"Pa ,ofla/vr- ?ap? *&s 10ai1471 CEBRUM GEORGE, II, Plaintiff V. BROOK A. HODGE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2009-1181 CIVIL ACTION -LAW IN CUSTODY ORDER OF COURT 11~ 1 AND NOW, this ~ ~ day of Q ~ C , 2012, upon consideration of the attached Custody Conciliation eport, it is ordered and directed as follows: 1. The prior Order of Court dated April 16, 2009 shall remain in full force and effect with the following modifications. 2. Father shall have the following periods of partial physical custody. A. Alternating weekends, beginning August 24, 2012 from Friday at 6:00 p.m. to Monday morning when Father will be responsible for transporting the child to daycare or school. B. Every Tuesday overnight from 6:00 p.m. Tuesday to Wednesday morning when Father will be responsible for transporting the child to daycare or school. Father has the right to change this overnight to another day of the week if it conflicts with his work schedule. 3. Each party shall have physical custody of the child for 2non-consecutive uninterrupted weeks in the summer, provided they give the other parry 30-days prior notice. 4. Neither party shall do nor permit a third party to do, or say anything that would estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. 5. RELOCATION: No party shall be permitted to relocate the residence of the child which significantly impairs the ability to exercise custody unless every individual who has custodial rights to the child consents to the proposed relocation or the court approves the proposed relocation. A person proposing to relocate MUST comply with 23 Pa. C. S. § 5337. s 6. 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, M. L. Ebert, Jr., J. cc Taylor P. Andrews, Esquire, Counsel for Father /Mazcus A. McKnight, Esquire, Counsel for Mother gip! es IKa ~e~ ~~~~ia ~ . ~~ ~ ~. C' ~G ~ r" c s ~•C~' CT+ ~- '~ ~; c-~ -o ~ ~ G3 4 ill ~; ~- a ~~ ~.~ ~; ~. CEBRUM GEORGE, II, Plaintiff V. BROOK A. BODGE, Defendant PRIOR JUDGE: M. L. Ebert, 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: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2009-1181 CIVIL ACTION -LAW IN CUSTODY 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 Sejhne Amir Lillian Palmer August 13, 2008 Mother 2. A Conciliation Conference was held in this matter on August 14, 2012, with the following in attendance: The Mother, Brook A. Hodge, with her counsel, Mazcus A. McKnight, III, Esquire and the Father, Cebrum George, II, with his counsel, Taylor P. Andrews, Esquire. 3. The Honorable M. L. Ebert, Jr. previously entered an Order of Court dated April 16, 2009 providing for shazed legal custody, Mother having primary physical custody and Father having aphased-in period of partial physical custody. 4. The parties agreed to an Order in the form as attached. ,~- ~ `~ -1 'tom Date acq ine M. Verney, Esquire Custody Conciliator