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HomeMy WebLinkAbout09-8929JOHN F. KING LAW, P.C. John F. King, Esquire ID #61919 19 S. Hanover Street Suite 103 Carlisle, PA 17013 Tel.: (717) 258-4343/Fax: (717) 422-5526 Attorney for Plaintiff ROBERT J. WOOD, Plaintiff V. TRACEY WOOD, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. o co" ,, CIVIL ACTION - LAW CUSTODY/VISITATION COMPLAINT FOR CUSTODY 1. The Plaintiff is Robert J. Wood, residing at 82 Carlisle Road, Newville, Cumberland County, Pennsylvania 17241. 2. The Defendant is Tracey Wood, residing at an unknown address, with a work address of FMC of Cumberland County, 254 E. High Street, Carlisle, Pennsylvania 17013, and work telephone number of 717-240-2944. 3. Plaintiff seeks custody of the following child: NAME PRESENT RESIDENCE AGE DOB Alexandria D. Wood 82 Carlisle Road 7 5/31/2002 Newville, Pennsylvania 17241 The child was not born out of wedlock. The child is presently in the custody of Plaintiff/Father, who resides at 82 Carlisle Road, Newville, Pennsylvania 17241 . During the past five (5) years, the child has resided with the following persons and at the following addresses: NAME RESIDENCE DATE Plaintiff Harbeson, DE 12/2004 - 09/2005 Defendant Robert Wood, Jr (son of Plaintiff) Plaintiff 237 Marcliffe Dr. 09/2005 - 12/2006 Defendant Apt. 13 Robert Wood, Jr. Valpraiso, IN Plaintiff 175 Chickasaw Ave 12/2006 - 12/2008 Defendant Pittsburgh, PA Paul Hitchens (son of Defendant) Plaintiff 82 Carlisle Rd 12/2008 - 12/11/2009 Defendant Newville, PA Defendant Address unknown 12/11/2009 - Bobby Daniels (paramour of Defendant) 12/31/09 Plaintiff 82 Carlisle Road 12/31/2009 - Newville, PA Present The mother of the child is Defendant, Tracey Wood, currently residing at address unknown. She is currently married to Plaintiff. The father of the child is Plaintiff, Robert Wood, currently residing at 82 Carlisle Road, Newville, Pennsylvania. He is currently married to the Defendant. 4. The relationship of the Plaintiff to the child is that of Father. The Plaintiff currently resides with the following persons: NAME RELATIONSHIP Subject minor child Daughter 5. The relationship of the Defendant to the child is that of Mother. The Defendant currently resides with the following persons: NAME Bobby Daniels RELATIONSHIP Paramour It is not known to Plaintiff/Father if there are any other persons residing with Defendant. 6. 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 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 because: A. Father has been the primary caregiver of the child. B. Father promotes and supports the child's academic efforts, unlike Defendant/Mother. C. Father will ensure child's attendance at school, unlike Defendant/Mother. D. Father will promote the relationship between the child and other parent, unlike Defendant/Mother. 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 a party to this action. WHEREFORE, Plaintiff requests the Court to grant primary physical custody of the child to the Plaintiff/Father with partial custody for the purposes of visitation granted to Defendant/Mother.. Dated: December 31, 2009 Respectfully submitted, JOHN F. KING LAW, P.C. J . King, Esquire 19 S. Hanover Street Suite 103 Carlisle, PA 17013 Attorney for Plaintiff VERIFICATION I, Robert J. Wood, hereby acknowledge that I am the Plaintiff in the foregoing action; that I have read the foregoing Complaint for Custody; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. 96? . W 0-"-Q Rob rt J. Wood Dated: December 31, 2009 L, ?,i U ? L? ?... V ? ! f ? I{ l.- • as . ??q d? ,9?/y *,rr? JOHN F. KING LAW, P.C. John F. King, Esquire ID #61919 19 S. Hanover Street Suite 103 Carlisle, PA 17013 Tel.: (717) 258-43431Fax: (717) 422-5526 ROBERT J. WOOD, Plaintiff V. TRACEY WOOD, Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-8929 CIVIL ACTION - LAW CUSTODYNISITATION EMERGENCY PETITION FOR SPECIAL RELIEF AND NOW comes the Petitioner, Robert J. Wood, above-named Plaintiff and natural Father of the minor child, Alexandria D. Wood, by and through his legal counsel, John F. King Law, P.C., pursuant to Pa.R.C.P. 1915.13 and hereby files the instant Emergency Petition for Special Relief seeking temporary custody, and does aver as follows: 1. The Petitioner, Robert J. Wood, is the Plaintiff in the above-captioned custody action and is the natural Father of the minor Child, Alexandria D. Wood, age 7 years. The Petitioner currently resides at 82 Carlisle Road, Newville, Cumberland County, Pennsylvania 17241. 2. The Respondent is Tracey Wood, the Defendant in the above-captioned custody action and is the natural Mother of the subject minor Child. The Respondent currently resides at 1713 Ft. Patton Drive, Harrisburg, Pennsylvania 17112, and has a cell phone number of 717-440- 6131 and work telephone number of 717-240-2944. 3. The Petitioner is represented by John F. King, Esq., 19 S. Hanover Street, Suite 103, Carlisle, Pennsylvania 17103, phone number 717-258-4343. 4. It is unknown if Respondent has retained legal counsel. 5. The Petitioner, Robert J. Wood, and the Respondent, Tracey Wood, are Husband and Wife, and until December 11, 2009, did reside together at Petitioner/Father's current residence. 6. The minor Child is Alexandria D. Wood, date of birth May 31, 2002, and who is 7 years old. 7. On the morning of Thursday, December 10, 2009, Father followed his regular (Monday-Friday) schedule by transporting his daughter, Alexandria, to her preschool at the Newville Church of the Brethren, which the Child attends before being transported to her second grade class at the Newville Elementary School. Father then traveled to his work at Pinnacle Health. Alexandria has attended the Newville Elementary School since the family moved to Father's current residence in December of 2008. 9. On the afternoon of Thursday, December 10, 2009, the Petitioner/Father followed his normal schedule, by leaving his workplace and picking up Alexandria from her afternoon daycare at the Newville Church of the Brethren, at approximately 4:15 PM. 10. On the evening of December 10, 2009, the Respondent/Mother did not return to the marital residence, did not communicate with Father, and would not return Father's telephone calls to her cell phone. 11. On the morning of Friday, December 11, 2009, Father, following his regular schedule, dropped Alexandria at her preschool daycare and then traveled to work. 12. On the afternoon of Friday, December 11, 2009, Father, following his regular schedule, arrived at Alexandria's afternoon daycare to pick her up and discovered that she was not present. He was informed that Respondent/Mother had the Child. 13. The Petitioner/Father has been the primary caregiver of Alexandria since approximately September 2005, when Mother began working. 14. After Mother's wrongful taking of Alexandria on Friday, December 11, 2009, Father was not given any information of the Child's location. 15. On Saturday, December 12, 2009, Father spent approximately 12 hours searching for Mother's car in an attempt to locate Alexandria. 16. Alexandria was wrongfully kept out of school by Respondent/Mother since Mother's taking of Alexandria on December 11, 2009, even though (as recently discovered by Father) Mother was on a leave of absence from her work from December 12, 2009, through December 27, 2009, and could have transported the child to and from daycare and school. 17. Father was first allowed to speak with Alexandria on Christmas Eve 2009, thirteen (13) days after Mother's wrongful taking, which was the only telephone communication that was allowed by Mother between December 11, 2009 and December 31, 2009. 18. On Thursday, December 31, 2009, the Petitioner/Father was finally informed of the address where Mother and daughter were staying, that being the address of Mother's paramour, Bobby Daniels, and was allowed to pick up Alexandria for a visit. 19. On Thursday, December 31, 2009, the Petitioner/Father filed a Complaint for Custody docketed as in the above caption at 09-8929. 20. Because of to the very recent date of filing of the underlying Custody Complaint, a Conciliator has not been assigned nor has a Conciliation date been determined. 21. Father has re-enrolled Alexandria in her class at Newville Elementary School, where she has attended since December 2008, and further believes such attendance would be in the Child's best interests and welfare. 22. It is believed, and therefore averred, that since December 10, 2009, Mother has been residing, and keeping Alexandria at the residence of her paramour, Bobby Daniels, which paramour's address was very recently disclosed to Petitioner/Father. 23. On Sunday, January 3, 2010, Petitioner/Father informed Respondent/Mother that it was his intention to re-enroll Alexandria at Newville Elementary School. 24. On Sunday, January 3, 2010, upon learning of Father's intention regarding Alexandria, the Respondent/Mother did become angry, and did state to Petitioner the following: "You better watch your back 2417" and her paramour, Bobby Daniels, stated to the Petitioner, "I will snap your f ing neck" 25. The marital residence where Father continues to reside is now leased in Father's name only, subsequent to Mother having contacted the landlord and having terminated the previous leasehold. 26. On Sunday, January 3, 2010, the Respondent/Mother and her paramour, Bobby Daniels, did drive to the marital residence where Father and Alexandria were then present, opened the garage door with a remote in possession of Mother, blew the horn repeatedly, and Mother came onto the front porch and pounded on the front door. 27. The Pennsylvania Police were called by Father and did respond. It is unknown if charges were filed, since Mother and paramour had departed the premises prior to the police having arrived and taken a report. 28. On this morning of Monday, January 4, 2010, Father received a text message from Mother that said, "I don't want to leave without Alex. 1 know I am not Mother of the Year, but she is my reason for being. " 29. Petitioner/Father is very fearful that absent a Court Order, Mother will once again wrongfully take the Child to paramour's home in Dauphin County, Pennsylvania, or to an unknown address, causing Child to once again miss an inordinate amount of school, and interfering with the Father/daughter relationship, much to the Child's detriment and harm. 30. Father believes, and therefore avers, that it is not in the Child's best interests, but is rather detrimental and harmful to the Child, to be again uprooted and relocated to the home of Mother's paramour, or to an unknown address. 31. The Petitioner/Father will ensure that the subject minor Child, Alexandria, attends school, by following his normal schedule of dropping off the child at her preschool daycare and picking up the Child from her afternoon daycare, unlike Mother. 32. Father will ensure interaction between the other parent and the Child, unlike Mother. 33. Petitioner/Father believes, and therefore avers, that Alexandria's inexcusable absence from school since December 11, 2009, which absence was caused and allowed by Mother, was harmful to the Child's well being. WHEREFORE, the Petitioner/Father respectfully requests this Honorable Court grant his Petition for Special Relief, and issue an Order granting the Petitioner/Father temporary primary physical custody of the Child, Alexandria D. Wood, born May 31, 2002, until such time as the Complaint of Custody which was filed by Father on December 31, 2009, is determined. Dated: January 1 2010 d., te _ V john F. King, ] ID# 61919 19 S. Hanover Suite 103 Carlisle, PA 17013 (717) 258-4343 (717) 422-5526 FAX Attorney for Petitioner CERTIFICATE OF SERVICE I hereby certify that I am this day of January, 2010, serving the foregoing Petition for Special Relief upon the person and in the manner indicated below which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure. First Class Mail and certified mail: Tracey Wood 1713 Ft. Patton Drive Harrisburg, PA 17112 VERIFICATION I, Robert J. Wood, hereby acknowledge that I am the Plaintiff in the foregoing action; that I have read the foregoing Emergency Petition for Special Relief; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. 1 RoNrt J. Wood Dated: January_q _, 2010 - r,f': L `y` ?' r? ? ??' a ? ? ?? ? ?' ? ? ?? ?3?7? 0 v'•, JAN o a zoos ROBERT J. WOOD, v. TRACEY WOOD, Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-8929 ORDER AND NOW this CIVIL ACTION - LAW CUSTODYNISITATION day of January, 2010, upon consideration of the attached Petition for Special Relief seekin& temporary custody, it is hereby ORDERED and DECREED that said Petition is NTED. Ck4d' e??a ?r a -?bteec -- t 1-s # t es tom: rs!mT Taint fnr C`?ictn cr? ?uh;?l? .,,^n lby , - Pte.. 0 ! 3 ong as said pa 'Q ion ro riate B 1HEi 3 J. ICE OF 4WTH(C+ffMY 2611 JAI -6 AM 9: 06 CUMEU'Ai4iD Cam PENNSYLVtV //L 1 ?d ^ L"v ??- •?t l.?G? ROBERT J. WOOD IN THE COURT OF COMMON PLEAS OF PLAIN"1114 CUMBERLAND COUNTY, PF NNSYL.VANIA V. 2009-8929 CIVIL ACTION LAW TRACEY WOOD DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, January 07, 2010 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, January 21, 2010 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 hearin(_j. FOR THE COURT, By: /s/ fac uellne M. Verney Es_q. _ Custody Conciliator f 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 "PHIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTII BELOW TO FIND OUT WLIERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 "Telephone (717) 249-3166 F FIL.LL1-r?lµrr,r AY 1010 j,l,q -8 P"i 12: 3 4 ROBERT J. WOOD, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLZfANIA V. NO. 09-8929 CIVIL TERM 7=_'.'T? R TRACEY WOOD, CIVIL ACTION - LAW Defendant CUSTODY/VISITATION ? L _ CD N ORDER OF COURT -C AND NOW, this 8th day of January, 2010, after hearing, we enter the following Order which is meant to be temporary only and not to affect the rights of either party after a full and fair hearing to merits: 1. The parties shall share joint legal custody of their child, Alexandria D. Wood, age 7 years. 2. Mother shall have primary physical custody of the child subject to Father's periods of visitation as follows: a. Every other weekend from after school on Friday until the beginning of school on Monday commencing January 15, 2010. b. Every Thursday night from after school on Thursday until the commencement of school on Friday. C. At such other times as the parties shall agree. Both parties shall see that the child attends her current school unless otherwise agreed between the parties. By the Court, Edward E. Guido, J. 'John F. King, Esquire At orney for Plaintiff Tracey Wood 1713 Fort Patton Drive Harrisburg, PA 17112-8512 Defendant, Pro se srs C-6f ruaIL (. JUL 1 Z 2010 ROBERT J. WOOD, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : N0.2009-8929 CIVIL ACTION -LAW n ~' TRACEY WOOD, C.': r9 =y c.. ~ --~, Defendant : IN CUSTODY .. r- ~ , ;-~ , t ~~? ~ N ? ~ r ..,-, C :~~ n _ er ORDER OF COURT ~ ~~_ cv ~~~ AND NOW, this 9th day of July, 2010, being advised that the parties have reconciled, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, ~~ , ~~ acq ine M. Verney, Esquire, Custody nciliator IUL24 53 UMBERL�I'D CrjUtl'rY � li�xYL`Jt�Fdl > Tanner Law Offices, LLC 3507 Market Street, Suite 303 Camp Hill, PA 17011 Phone: (717) 731-8114 Fax (717) 731-8115 ROBERT WOOD, § IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner § CUMBERLAND COUNTY, PENNSYLVANIA V. § CIVIL ACTION § CUSTODY/VISITATION TRACEY WOOD, § Defendant/Respondent § NO. 09-8929 PETITION FOR MODIFICATION OF A CUSTODY ORDER AND NOW,comes the Petitioner,Robert Wood,by his attorney,Tanner Law Offices, LLC, and represents as follows: 1. Petitioner, Robert Wood, is an adult individual currently residing at 936 Iroquois Court, Harrisburg, Dauphin County, Pennsylvania 17109. 2. Respondent, Tracey Wood, is an adult individual currently residing at 73 Partridge Circle, Carlisle, Cumberland County, Pennsylvania 17015. 3. Petitioner and Respondent are the natural parents of the following minor child: Alexandria D. Wood, born May 31, 2002 (hereinafter referred to as "the child".) 4. During the past five(5)years,the child has resided with the following persons d�J� at the following addresses: h13.C>0 /9 J C# 3086 Person (s)- Address: Dates: Tracey Wood 73 Partridge Circle 7/13- Present Carlisle, PA Tracey Wood 815 Marshall Dr. 12/11 - 6/13 Carlisle, PA Robert Wood 815 Marshall Dr. 6/10 - 11/11 Tracey Wood Carlisle, PA Robert Wood 82 Carlisle Rd 12/08 - 5/10 Tracey Wood Newville, PA 5. Petitioner respectfully represents that on January 8, 2010, an Order of Court was entered providing the parties with joint legal custody and providing Respondent with primary physical custody(Exhibit "A"). 6. The parties reconciled thereafter and as a result, the conciliator relinquished jurisdiction of this matter on July 9, 2010. 7. Petitioner has no information of a custody proceeding concerning the child pending in any other court of this Commonwealth or any other court. 8. The parties lived together with the child until November of 2011 at which time Petitioner left. 9. From November 2011 until May 2013,Petitioner watched the child overnight in Respondent's home while Respondent worked third shift. 10. Respondent is unable to watch the child at night due to her work schedule. 11. In May 2013, Respondent hired a third party to care for their child while Respondent works third shift. 12. Petitioner believes and therefore avers that it is in the best interest of the child to live primarily with him to enable her to have the stability of one household and caregiver. Petitioner believes that it is in the child's best interest to be cared for by a parent who is available rather than a third party. WHEREFORE, Petitioner respectfully requests that the Court modify the existing Order to provide joint legal custody and primary physical custody to Petitioner. Respectfully submitted, Date: 7 3 3 Tabetha A. Tanner, Esquire Attorney for Petitioner Supreme Court I.D. No.: 91979 VERIFICATION I, Robert Wood, hereby verify that the statements made in this Petition for Modification of Custody Order are true and correct.I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: v 2 V OkuA7�AIJ Robe Wood, Plaintiff/Petitioner i ROBERT J. WOOD, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLMN� 4=� V. NO. 09-8929 CIVIL TERM r_,y 74.. � TRACEY WOOD, CIVIL ACTION - LAW Defendant CUSTODY/VISITATION 7� S" tT� ('D m .. co N ORDER OF COURT AND NOW, this 8th day of January, 2010, after hearing, we enter the following Order which is meant to be temporary only and not to affect the rights of either party after a full and fair hearing to merits : 1 . The parties shall share joint legal custody of their child, Alexandria D. Wood, age 7 years. 2 . Mother shall have primary physical custody of the child subject to Father' s periods of visitation as follows : a. Every other weekend from after school on Friday until the beginning of school on Monday commencing January 15, 2010 . b. Every Thursday night from after school on Thursday until the commencement of school on Friday. C . At such other times as the parties shall agree . Both parties shall see that the child attends her current school unless otherwise agreed between the parties . By the Court, Edward E. Guido, J. JUL 12 2010 ROBERT J.WOOD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. : NO.2009-8929 CIVIL ACTION-LAW *-' , TRACEY WOOD, Defendant : IN CUSTODY ORDER OF COURT `P c r-? y-'' AND NOW,this 9t'day of July, 2010,being advised that the parties have reconciled,the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, acq ine M. Verney, Esquire, Custody QVnciliator ROBERT WOOD IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-8929 CIVIL ACTION LAW rn a� zr Cn TRACEY WOOD C.A.4 :711 1_1 T -<> C=) C_ IN CUSTODY r-Z t DEFENDANT *C7) CID zt., ORDER OF COURT I CD AND NOW, Tuesday,July 30,2013 upon consideration of the attached Complaint, it is hereby directed that pat-ties and their'respective counsel appear before Jacqueline M.Verney,Esq.,the conciliator, at 4th Floor,Cumberland County Courthouse,Carlisle on Friday,August 30,2013 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/ _fac queUne M. Verne Es q., Custody Conciliator ty 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 8op-les 6 '. 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 Syr LCW ()Fplces' ROBERT WOOD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA CD V. NO. 2009-8929 CIVIL ACTION-LAg E5 r 1^1 t/�) rnm rn TRACEY WOOD, Defendant IN CUSTODY C_— rr C) i ORDER OF COURT AND NOW, thisl 440� day 2013, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I The prior Order of Court dated January 8, 2010 is hereby vacated. 2. The Father, Robert Wood and the Mother, Tracey Wood, shall have shared legal custody of Alexandria D. Wood,born May 31, 2002. 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. 3. The parties shall share physical custody of the child on a week on/week off basis with Friday at 5:00 p.m. being the day and time of exchange. Father's week shall begin August 30, 2013. 4. The parties shall share holidays as agreed. 5. RELOCATION: No parry 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. 6. This Order is entered pursuant to 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 GO RT, J. cc!Robert Wood, p ro se /936 Iroquois Court Harrisburg, PA 17109 ✓ Tracey Wood, pro se 73 Partridge Circle Carlisle, PA 17015 DES' Pb'a I 9 /3 ROBERT WOOD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. : NO. 2009-8929 CIVIL ACTION - LAW TRACEY WOOD, . Defendant : IN CUSTODY PRIOR JUDGE: Edward E. Guido,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 Alexandria D. Wood May 31, 2002 Mother 2. A Conciliation Conference was held in this matter on August 30, 2013, with the following in attendance: The Father, Robert Wood,pro se. Mother,Tracey Wood,pro se,although receiving notice of the conference,did not attend. 3. The Honorable Edward E. Guido previously entered an Order of Court dated January 8, 2010 providing for shared legal custody, Mother having primary physical custody with Father having periods of partial physical custody on alternating weekends and every Thursday overnight. 4. Father requested an Order in the form as attached. 36-1 Date Date Esquire Custody Conciliator COURT OF COMMON PLEAS OF CUMBERLAND COUNTY; PENNSYLVANIA CIVIL ACTION - LAW ROBERT WOOD, Plaintiff v. TRACEY WOOD, Defendant No. 2009-8929 Petition for Modification 1. Petitioner is Plaintiff, ROBERT WOOD, who currently resides at 715 Colonial Ct., Mechanicsburg, Cumberland County, PA 17050. 2. Respondent is Defendant, TRACEY WOOD, who currently resides at 73 Partridge Circle, Carlisle, Cumberland County, PA 17015. 3. Petitioner and Respondent are the natural parents of the following child: Name ALEXANDRIA D. WOOD Age 11 years 4. A custody order was entered on 9-3-2013, in the Cumberland County Court of Common Pleas. A copy of the custody order is attached. 5. Petitioner seeks to modify the custody order because: CYS has been contacted 2 times regarding mother, once by Middlesex Police, and once by Eagle View Middle School. Daughter has numerous lates in mothers care, and absenses...but none while with father. Father has been employed since the age of 18, mother has difficult time keeping jobs. Daughter has been exposed to MANY things because of mothers behavior and lack of supervision. Daughters school work suffers greatly when in her mothers care. 6. Petitioner believes the custody order should be changed as follows: 1 want FULL CUSTODY of Alexandria, with mother having visitation every other weekend, if the court sees that as necessary. ?g42.3.04 A'4 30q177 Petition for Modification Page 3 of 5 WHEREFORE, Petitioner respectfully requests that this Court modify the Order as requested. Date: Li 2oi ROB RT WOOD, Plaintiff Verification. I, ROBERT WOOD, Plaintiff, verify that the facts stated in the foregoing Petition are true and correct to the best of my knowledge, information and belief. Petitioner understands that false statements therein are subject to the penalties of 18 Pa. C.S.A. ' 4904 relating to unsworn falsification to authorities. Date: ERT WOOD, Plaintiff Petition for Modification Page 4 of 5 ROBERT WOOD, Plaintiff V. TRACEY WOOD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-8929 CIVIL ACTION - LAW • () • c=3 -173 IN CUSTODY rnw zr" z" c.nr- -0> <c) 7=•c-) ORDER OF COURT AND NOW, thisa 401 day of LdL1i6E.L , 2013, upon consideration of the at-taclied-Cusiody Conciliation eporcitirOitietad-afi-d-difected as - follows: 0 c.r? 1. The prior Order of Court dated January 8, 2010 is hereby vacated. 2. The Father, Robert Wood and the Mother, Tracey Wood, shall have shared legal custody of Alexandria D. Wood, born May 31, 2002. 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 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. 3. The parties shall share physical custody of the child on a week on/week off basis with Friday at 5:00 p.m. being the day and time of exchange. Father's week shall begin August 30, 2013. 4. The parties shall share holidays as agreed. 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. 6. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. cc: Robert Wood, pro se 936 Iroquois Court Harrisburg, PA 17109 Tracey Wood, pro se 73 Partridge Circle Carlisle, PA 17015 TRUE COPY FROM RECORD In Testimony whereof, 1 he re unto se i my hand and the of said . I at Carlisle, Pa, This 7- day of , 20 A3 Pr nopttor 2J2 74 ROBERT WOOD, Plaintiff V. TRACEY WOOD, Defendant : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-8929 CIVIL ACTION - LAW 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 Alexandria D. Wood May 31, 2002 Mother 2. A Conciliation Conference was held in this matter on August 30, 2013, with the following in attendance: The Father, Robert Wood, pro se. Mother, Tracey Wood, pro se, although receiving notice of the conference, did not attend. 3. The Honorable Edward E. Guido previously entered an Order of Court dated January 8, 2010 providing for shared legal custody, Mother having primary physicai custody with Father having periods of partial physical custody on alternating weekends and every Thursday overnight. 4. Father requested an Order in the form as attached. E 30 Date acqdline M. Verney, Esquire Custody Conciliator U300 IN THE COURT OF COMMONLE Plaintiff CUMBERLAND COUNT Vs Lioo Defendant No. 2 col 9 2-7 pep CIVIL ACTION - LAW : IN CUSTODY r -7;7 r,k) CRIMINAL RECORD / ABUSE HISTORY VERIFICATION LA_Doz)E› , hereby swear or affirm, subject to penalties of law including 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities that: 1. Unless indicated by my checking the box next to a crime below, neither I nor any other member of my household have been convicted or pled guilty or pled no contest or was adjudicated delinquent where the record is publicly available pursuant to the Juvenile Act 42 Pa.C.S. § 6307 to any of the following crimes in Pennsylvania or a substantially equivalent crime in any other jurisdiction, including pending charges: Check Crime Self Other Date of Sentence all that household conviction, apply member guiltv plea, no contest plea or pending charges 18 Pa.C.S. Ch. 25 fl (relating to criminal homicide) 18 Pa.C.S. §2702 [1,7 (relating to aggravated assault) 18 Pa.C.S. §2706 (relating to terroristic threats) 18 Pa.C.S. §2709.1 (relating to stalking) 18 Pa.C.S. §2901 P1 (relating to kidnapping) P1 fl 18 Pa.C.S. §2902 (relating to unlawful restraint fl 18 Pa.C.S. §2903 (relating to false imprisonment) 18 Pa.C.S. §2910 (relating to luring a child into a motor vehicle or structure) 18 Pa.C.S. §3121 (relating to rape) 18 Pa.C.S. §3122.1 relating to statutory sexual assault) 18 Pa.C.S. §3123 relating to involuntary deviate sexual irjtercoLk•sei fl 18 Pa.C.S. §3124.1 r.7 (relating to sexual assault) 18 Pa.C.S. §3125 (relating to aggravated indecent assault) 18 Pa.C.S. §3126 fl (relating to indecent assault) 18 Pa.C.S. §3127 E (relating to indecent exposure) 18 Pa.C.S. §3129 (relating to sexual intercourse with animals) 18 Pa.C.S. §3130 EJ (relating to conduct relating to sex offenders) JT 18 Pa.C.S. §3301 (relating to to arson and related offenses) 18 Pa.C.S. §4302 E (relating to to incestl 18 Pa.C.S. §4303 (relating to concealing death of child) 18 Pa.C.S. §4304 (relating to endangering welfare of children) fT 18 Pa.C.S. §4305 (relating to dealing in infant children) IT 18 Pa.C.S. §5902(bi fl (relating to prostitution and related offenses) E fl ET 18 Pa.C.S. §5903 FT E (c) or (d) (relating to obscene and other sexual materials and performances) IT 18 Pa.C.S. §6301 (relating to corruption of minors) fl 18 Pa.C.S. §6312 (relating to sexual abuse of children) fl 18 Pa.C.S. §6318 177 (relating to unlawful contact with minor), 18 Pa.C.S. §6320 (relating to sexual exploitation of children) fT 23 Pa.C.S. §6114 (relating to contempt for violation of Protection order or agreement) Driving under the influence of drugs or alcohol Manufacture, sale, delivery, holding, offering for sale or possession of any controlled substance or other drug or device 2. Unless indicated by my checking the box next to an item below, neither I nor any other member of my household have a history of violent or abusive conduct including the following: Check all that apt* A finding of abuse by a Children & Youth Agency or similar agency in Pennsylvania or similar statute in another jurisdiction Abusive conduct as defined under the Protection from Abuse Act in Pennsylvania or similar statute in Self Other household member fl Date another jurisdiction fl Other: 3. Please list any evaluation, counseling or other treatment received following conviction or finding of abuse: 4. If any conviction above applies to a household member, not a party, state that person's name, date of birth and relationship to the child : 5. If you are aware that the other party or members of the party's household has or have a criminal / abuse history, please explain: I verify that the information above is true and correct to the best of my knowledge information or belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. of)e-ra" L&3ooi Printed Name 0 ROBERT WOOD PLAINTIFF V. TRACEY WOOD DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2009 -8929 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, April 14, 2014 , 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 Tuesday, May 20, 2014 1:30 PM for a Pre - Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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. You must file with the Court a verification regarding any criminal record or abuse history regarding you and anyone living in your household on or before the initial in- person contact with the court (including, but not limited to, a conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition. No party may make a change in the residence of any child which significantly impairs the ability of the other party to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and Pa.R.C.P. No. 1915.17 regarding relocation. FOR THE COURT, By: /s/ Jacqueline M. Verney, Esq 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 C' pe F� PicLe-exl- 1( MI6 - Pittij Velumd COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ROBERT WOOD, Plaintiff v. TRACEY WOOD, Defendant ) ) ) No. 2009-8929 ) ) ) Certificate Of Service I, ROBERT WOOD, Plaintiff in the above matter, hereby certify that on I\k4Lf q 20 1 ty , I mailed a true and correct copy of the Petition for Modification, by certified mail, return receipt requested, restricted delivery, and another copy of the same document by first class mail, postage prepaid, to: TRACEY WOOD 73 Partridge Circle Carlisle, PA igaz5 1 1 0 1 3 I certify that (check ALL of the following which are true): Certified mail: [X] The green and white sender's receipt is attached. (ATTACH receipt.) [ ] The green recipient's receipt is attached; TRACEY WOOD signed the certified mail receipt on (ATTACH receipt.) The certified mail was returned to me unsigned, with the notation that the certified mail was: [ ] refused [ ] unclaimed [ ] other notation: Neither the certified mail envelope nor the certified mail receipt was returned to me. [ ] Regular mail: The regular mail has not been returned to me. The regular mail was returned to me, with the notation: Certificate of Service Page 1 of 3 1 verify that the information in the Certificate of Service is true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904, relating to unsworn falsification to authorities. Date: ure) ROBERT WOOD ROBERT WOOD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-8929 TRACEY WOOD, Defendant : IN CUSTODY cn� C) CIVIL ACTION - LAW .7s — ref tV Lr.1 ORDER OF COURT ilf AND NOW, this i✓ day of /1 4 "" , 2014, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated September 3, 2013 is hereby vacated. 2. The Father, Robert Wood shall have sole legal custody of Alexandria D. Wood, born May 31, 2002. parties. 3. Father shall have primary physical custody of the child. 4. Mother shall have periods of partial physical custody as agreed by the 5. Transportation shall be as agreed by the parties. 6. 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. 7. This Order is entered pursuant to 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. J. 3 ccl‘ert Wood, pro se 715 Colonial Ct. Mechanicsburg, PA 17050 Tracey Wood, pro se 73 Partridge Circle Carlisle, PA 17015 C.,i'es i'ziLL slIaM •-fl ROBERT WOOD, Plaintiff V. TRACEY WOOD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-8929 CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edward E. Guido, 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 Alexandria D. Wood May 31, 2002 Mother 2. A Conciliation Conference was held in this matter on May 20, 2014, with the following in attendance: The Father, Robert Wood, pro se. Mother, Tracey Wood, .. pro se, although receiving notice of the conference, did not attend. L7 3. The Honorable Edward E. Guido previously entered an Order of Court dated September 3, 2013 providing for shared legal custody and shared physical custody . , on a week on/week off schedule. 4. Father requested an Order in the form as attached. Date Ja•4• eline M. Verney, Esquire Custody Conciliator COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TRACEY WOOD, Plaintiff v. No. 2009-8929 ROBERT WOOD, Defendant Petition for Contempt and Modification 1. Petitioner is Plaintiff, TRACEY WOOD, who currently resides at 73 Partridge Circle, Carlisle, Cumberland County, PA 17013. 2. Respondent is Defendant, ROBERT WOOD, who currently resides at 715 Colonial Ct., Mechanicsburg, Cumberland County, PA 17050. 3. Petitioner and Respondent are the natural ,parents of the following child: Name Age ALEXANDRIA D. WOOD 11 years 4. A custody order was entered on May 23, 2014, in the Cumberland County Court of Common Pleas. A copy of the custody order is attached. 5. Respondent has willfully violated the custody order, asfollows: Defendant has refused to allow Petitioner contact with Daughter. Defendant refuses to allow phone contact and has denied each request Petitioner has made for arranging visitation. Petitioner has made no less than two attempts daily to arrange visit with Daughter. Evidenced by saved texted messages =cell phone of Defendant. 6. Petitioner seeks to modify the custody order because: Father left Alexandria in November, 2011. Father filed for joint custody only after he was ordered to pay child support and his Exceptions to child support order where dismissed in June , 2013. Plaintiff received notice of Pre -hearing custody conference via regular mail service that indicated the time of hearing was at 2:30 pm on August 30, 2013. The actual time of conference Petition for Contempt and Modification Page 3 of 6 .D0 /9,4/72.9? & 36bq52- was 10:30 am August 30, 2013. Father was granted joint custody resulting from that conference. Father petitioned for modification of Joint custody order from September 3, 2013 alleging daughters school work suffers greatly while in Petitioners care. Petitioner can show evidence of grades / reports showing daughters school work only began to suffer following Defendant receiving shared physical custody in September, 2013. Father alleged he has been employed since age 18. Petitioner can show evidence that she was sole financial support of family for several extended periods during marriage. Father alleged Daughter has been late for school while in Petitioners care. Father has blocked Daughter from attending school in Petitioner's school district which has forced Mother to drive Daughter to and from school. Daughter had no tardiness during 20 month separation prior to Defendant obtaining joint custody in September, 2013. Father was granted sole legal custody in order on May 23, 2014 as a direct result of Plaintiff arriving late to Conference on May 20, 2014. AGAIN, Petitioner received notice of conference only via regular mail service. When Petitioner arrived at conference she was informed by Jacqueline M. Verney, Custody Conciliator that she was "Too late, recommendations have already been written". She (Jacqueline M. Verney) added that Petitioner should "file petition to modify". 7. Petitioner believes the custody order should be changed as follows: SOLE LEGAL CUSTODY TO PETITIONER OF DAUGHTER, ALEXANDRIA D. WOOD, Born May 31, 2002. WHEREFORE, Petitioner respectfully requests that this Court find Respondent in contempt of Court and modify the Order as requested. Date:C{ oi2 c?d/ TRACEY Wj OD, Plaintiff Petition for Contempt and Modification Page 4 of 6 Verification I, TRACEY WOOD, Plaintiff, verify that the facts stated in the foregoing Petition are true and correct to the best of my knowledge, information and belief. Petitioner understands that false statements therein are subject to the penalties of 18 Pa. C.S.A. ' 4904 relating to unsworn falsification to authorities. Date: /(f/i c 13 01207,y TRACEY WOOD, Plaintiff Petition for Contempt and Modification Page 5 of 6 ROBERT WOOD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA TRACEY WOOD, Defendant : NO. 2009-8929 : IN CUSTODY ORDER OF COURT AND NOW, this ,k91 day of /24 , 2014, upon consideration of the attached Custody Conciliation R port, it is ordered and directed as follows: CIVIL ACTION - LAW r C.A) The prior Order of Court dated September 3, 2013 is hereby vacated. 2. The Father, Robert Wood shall have sole legal custody of Alexandria D. Wood, born May 31, 2002. parties. 3. Father shall have primary physical custody of the child. 4. Mother shall have periods of partial physical custody as agreed by the 5. Transportation shall be as agreed by the parties. 6. 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. 7. This Order is entered pursuant to 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. TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal cf said co *t Carlisle, Pa. This ral f ,2O J. cc: Robert Wood, pro se 715 Colonial Ct. Mechanicsburg, PA 17050 Tracey Wood, pro se 73 Partridge Circle Carlisle, PA 17015 ROBERT WOOD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-8929 CIVIL ACTION - LAW TRACEY WOOD, Defendant : IN CUSTODY PRIOR JUDGE: Edward E. Guido, 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 Alexandria D. Wood May 31, 2002 Mother 2. A Conciliation Conference was held in this matter on May 20, 2014, with • the following in attendance: The Father, Robert Wood, pro se. Mother, Tracey Wood, pro se, although receiving notice of the conference, did not attend. 3. The Honorable Edward E. Guido previously entered an Order of Court dated September 3, 2013 providing for shared legal custody and shared physical custody on a week on/week off schedule. 4. Father requested an Order in the form as attached. Date at.+' eline M. Verney, Esquire U Custody Conciliator "P\NC ZAf Plaintiff Vs Nf)\)°11— Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, --r civohRIVt' Zr u).., --c", • • c ) y c . Z'r No (i0011. --reaCt CIVIL ACTION - LAW IN CUSTODY CRIMINAL RECORD / ABUSE HISTORY VERIFICATION i. ---ift,K9 , hereby swear or affirm, subject to penalties of law including 18Pa. C.S. § 4904 relating to unsworn falsification to authorities that: 1 Unless indicated by my checking the box next to a crime below, neither I nor any other member of my household have been convicted or pled guilty or pled no contest or was adjudicated delinquent where the record is publicly available pursuant to the Juvenile Act 42 Pa.C.S. § 6307 to any of the following crimes in Pennsylvania or a substantially equivalent crime in any other jurisdiction, including pending charges: Check Crime all that apply 18 Pa.C.S. Ch. 25 (relating to criminal homicide) IT 18 Pa.C.S. §2702 (relating to aggravated assault) 18 Pa.C.S. §2706 (relating to terroristic threats) fl 18 Pa.C.S. §2709.1 (relating to stalking) Self Other household member 18 Pa.C.S. §2901 fl (relating to kidnapping) El Date of Sentence conviction, guilty plea, no contest plea or pending charges to fl 18 Pa.C.S. §2902 (relating to unlawful restraint) 18 Pa.C.S. §2903 ET (relating to false imprisonment) fl 18 Pa.C.S. §2910 (relating to luring a child into a motor vehicle or structure) 18 Pa.C.S. §3121 (relating to rape) FT 18 Pa.C.S. §3122.1 relating to statutory sexual assault) F_J fl 18 Pa.C.S. §3123 IT fl (relating to involuntary deviate sexual intercourse) fl 18 Pa.C.S. §3124.1 (relating to sexual assault) fT 18 Pa.C.S. §3125 'relating to aggravated indecent assault) 18 Pa.C.S. §3126 fl (relating to indecent assault) El 18 Pa.C.S. §3127 (relating to indecent exposure) fl 18 Pa.C.S. §3129 7.1 (relating to sexual intercourse with animals) 18 Pa.C.S.J3130 fl (relating to conduct relating to sex offenders1 fl 18 Pa.C.S. §3301 (relating to arson and related offenses) 18 Pa.C.S. §4302 (relating to incest) 18 Pa.C.S. §4303 (relating to concealing death of child) 18 Pa.C.S. §4304 fl (relating to endangering welfare of children) 18 Pa.C.S. §4305 (relating to dealing in infant children) fl 18 Pa.C.S. §5902(b) E fl (relating to prostitution and related offenses) fl 18 Pa.C.S. §5903 fc) or (d) (relating to obscene and other sexual materials and performances) fT 18 Pa.C.S. §6301 fl (relating to corruption of minors1 18 Pa.C.S. §6312 FT Ei (relating to sexual abuse of children) 18 Pa.C.S. §6318 ❑ 0 (relating to unlawful contact with minor) 18 Pa.C.S. §6320 0 0 (relating to sexual exploitation of children) 23 Pa.C.S. §6114 0 0 (relating to contempt for violation of Protection order or agreement) Driving under the ! 0 influence of drugs or alcohol Manufacture, sale, 0 r delivery, holding, offering for sale or possession of any controlled substance or other drug or device 2. Unless indicated by my checking the box next to an item below, neither I nor any other member of my household have a history of violent or abusive conduct including the following: Check Self Other all that household apply member r! A finding of abuse by a Children & Youth 0 Agency or similar agency in Pennsylvania or similar statute in another jurisdiction 0 Abusive conduct as defined under the 01 ri Protection from Abuse Act in Pennsylvania or similar statute in Date another jurisdiction r Other: rC fl 3. Please list any evaluation, counseling or other treatment received following conviction or finding of abuse: 4. If any conviction above applies to a household member, not a party, state that person's name, date of birth and relationship to the child : 5. If you are aware that the other party or members of the party's household has or have a criminal / abuse history, please explain: I verify that the information above is true and correct to the best of my knowledge information or belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. k9azt Signature [P�/ &oat. Printed Name TRACEY WOOD IN THE COURT OF COMMON PLEAS OF PLAINTIFF Y. ROBERT WOOD DEFENDANT CUMBERLAND COUNTY, PENNSYLVANIA 2009-8929 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, May 29, 2014 , upon consideration ofthe 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 Wednesday, June 25, 2014 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 cntry ofa temporary or penilanent order. The court hereby directs the parties to furnish any and ati existing Protection from Abuse orders, Speciat Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. You must file with the Court a verification regarding any criminal record or abuse history regarding you and anyone living in your household on or before the initial in-person contact with the court (including, but not limited 10, a conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition. No party may make a change in the residence of any child which si ificantly impairs the ability of the other party to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and Pa.R.C.P. No. 1915.17 regarding relocation. FOR THE COIJRT. By: /s/ Jacqueline M. Verney, Esq. OA Custody Conciliator The Court ofConimon Pleas of Cumberland County is required by law to comply with the Americans with Disahi|itos Act of\990. 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 biisiness hefore the court. You must attend the scheduled conference or hearing. YOU SI-IOULD TAKE THIS PAPER TO YOIJR 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 OGT LEGAL HELP. - Co 'es tanOct. 'o Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (7|7)24o'3\66 _ ROBERT WOOD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. TRACEY WOOD, Defendant • : NO. 2009-8929 : IN CUSTODY ORDER OF COURT CIVIL ACTION - LAW AND NOW, this .2 % ay of dJst,/1d, . , 2014, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 2" 'at .m. in cmtrtraorirrrernber�:. _ �. i- .y -.Y • '..� _�� The parties are directed to proceed with filing a pretrial statement with the Court and the other party consistent with the Pennsylvania Rule of Civil Procedure 1915.4-4. A Hearing is scheduled in Court Room No. 3 , of the Cumberland County Cort House, on the 42 o� day of , 2014, at /. '00 o'clock, F. M., at which time testimony will be taken. For purposes of this Hearing, Mother shall be deemed to be the moving party and shall proceed initially with testimony. 2 Pending a hearing, the prior Order of Court dated May 23, 2014 shall remain in full force and effect. the The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. cc: Tracey Wood, pro se 73 Partridge Circle /Carlisle, PA 17013 /Robert Wood, pro se 715 Colonial Ct. Mechanicsburg, PA 17050 ria r)= cry CD -71 r; 3 ROBERT WOOD, Plaintiff V. TRACEY WOOD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-8929 CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edward E. Guido, 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 Alexandria D. Wood May 31, 2002 Father 2. A Conciliation Conference was held in this matter on June 25, 2014, with the following in attendance: The Mother, Tracey Wood, pro se and the Father, Robert Wood, pro se. 3. The Honorable Edward E. Guido previously entered an Order of Court dated May 23, 2014 providing for Father to have sole legal custody and primary physical custody with Mother having periods of partial physical custody as agreed by the parties. 4. Mother filed a Petition to Modify and Contempt. 5. Mother's position on custody is as follows: Mother seeks sole legal custody and sole physical custody. Mother asserts that Father had no involvement with the child for two years during which time the child did well in school. Mother asserts that the child wishes to live with her. 6. Father's position on custody is as follows: Father seeks sole legal custody and sole physical custody. Father assets that the child did poorly in school while in Mother's primary care. He indicates that CYS was involved because of truancy while in Mother's care. 7. Issues to be determined at hearing: • A. Legal physical; B. Physical custody. 8. The Conciliator recommends an Order in the form as attached scheduling a Hearing, and maintaining the status quo. It is expected that the Hearing will require one-half day. Date: 6 "•-,5-11 cqu-1 ne M. Verney, Esquire Custody Conciliator fib_ T-paeey-Wood : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : C Troc�BeB$r!'V1 DEFENDANT I RLe ) COUNTY i ,, PA. : 2009-8929 C VAL ACTION - LAW : IN CUSTODY EMERGENCY PETITION MR SPECIAL RELIEF Em ria C— r- CJI — rCJI Petition for Special Relief and avers as follows: I .la, Tracey Wood, [Monier], who currently resides at 73 Partridge Circle , Carlisle , Pa 17013 2. fit, Robert Wood, [Father], who currently resides at 715 Colonial Ct., Mechanicburg, Pa, 17015 3. The parties hereto are the parents of the following minor Alexandria D. Wood resides at 715 Colonial Ct. Mrech,��u csburg, Pa 17015 4. On May 23, 2014 The Honorable Edward E. Guido entered an Order of Custody in e Court of Common Pleas of Cumberland County providing for father to have sole legal custody and primary physical custody With Mother having periods of partial physical custody as agreed by parties. A true and correct copy of said Order of Court is marked Exhibit "A," attach 6 h hereto and made a part hereof. Order was entered by Recommendation from Conciliator , due to the plaintiff Tracey Wood, arriving 20 minutes late for hearing. 5 Pursuant to said Order of Court, Alexandria D. Wood scheduled to spend Undetermined visitation with. Mother Tracey Wood as parties agree. C, 6. The Father Robert Wood has been unwilling to allow visitation on regular basis to Plaintiff Tracey Wood , Mother or agree to reasonable visitation schedule. The Plaintiff, Tracey Wood respectfully requests that custody be revisited prior to scheduled hearing on August 22, 2014 And Order revert back to prior order From August 30, 2013 where both parents shared joint physical and joint legal custody in the interim . P'laintif'f farther requests that this Honorable Court order Defendant to pay Plaintiffs reasonable counsel fees and costs. R\JC�/` ,ys4/61/. Plaints : CUMBERLAND COUNTY, PENNSYLVANIA TRACE WOOD, : NO. 2009-8929 CIVIL ACI ION - LAW Defendant : IN CUSTODY ORDER OF COURT tkI`rr�,,tli ; ,on: �I� „MN -Lupin (+ ni�;r:► ►�xt1tllla�� C,miliiiir,,ii i�lciift�ral 1. E is I.. (I .. I tom. .aterrease-airtba----dappef, �a ' .til. in The parties are directed to proceedwith filing a pretrial moment with the Court and the other party int with the Pennsylvania Rule of Civil Prue we 1915A-4. 1 A Hearing is scheduled in Court Room No. r of the Cumberland County Ow House, on the 62?"114 day of , 2014, at if. `06 o'clock, P. M, at which time testimony will be takes For purposes of this Hearing, Mother shall be deemed to be the moving party and shall proceed initially with • testimony_ Pending a hearing, the prior Ori of Court dated May 23, 2014 shall remain in full force and effect. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the teens of this Order shall control. cc: Tracey Wood, pm se 73 Partridge Circle Carlisle;, PA 17013 Robert Wood, pro se 715 Colonial Ct. Mechanicsburg, PA 17050 1. TREE COPY FROR1RECORD In TestIniSny_w reof, tfiere ant:, sem). Prend and thus 1 of said rt -t ::aidisle. Pa. Thi ay ROBERT WOOD, Plaintiff V. TRACEY WOOD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-8929 CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edward E. Guido, 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 Alexandria D. Wood May 31, 2002 Father 2. A Conciliation Conference was held in this matter on June 25, 2014, with the following in attendance: The Mother, Tracey Wood, pro se and the Father, Robert Wood, pro se. 3. The Honorable Edward E. Guido previously entered an Order of Court dated May 23, 2014 providing for Father to have sole legal custody and primary physical custody with Mother having periods of partial physical custody as agreed by the parties. 4. Mother filed a Petition to Modify and Contempt. 5. Mother's position on custody is as follows: Mother seeks sole legal custody and sole physical custody. Mother asserts that Father had no involvement with the child for two years during which time the child did well in school. Mother asserts that the child wishes to live with her. 6. Father's position on custody is as follows: Father seeks sole legal custody and sole physical custody. Father assets that the child did poorly in school while in Mother's primary care. He indicates that CYS was involved because of truancy while in Mother's care. 7. Issues to be determined at hearing: A. Legal Physical; B. Physical custody. 8. The Concili or a Rearing, and mai-slinking the one-half day. ‘•- OugtoityCinnxiiliator Plaintiff Vs --f(Cte>-tkl 0& Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. •=2 609— 8$) CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CRIMIN ECOR I ABUSE HISTORY VERIFICATION I, , hereby swear or affirm, subject to penalties of law including 18 Pa. C.S. 4904 relating to unsworn falsification to authorities that: 1. Unless indicated by my checking the box next to a crime below, neither I nor any other member of my household have been convicted or pled guilty or pled no contest or was adjudicated delinquent where the record is publicly available pursuant to the Juvenile Act 42 Pa.C.S. § 6307 to any of the following crimes in Pennsylvania or a substantially equivalent crime in any other jurisdiction, including pending charges: Check Crime all that apply Self Other Date of Sentence household conviction, member guilty plea, no contest plea or pending charges 18 Pa.C.S. Ch. 25 IT (relating to criminal homicide) FT 18 Pa.C.S. §2702 El El (relating to aggravated assault) 7 18 Pa.C.S. §2706 (relating to terroristic threats) IT 18 Pa.C.S. §2709.1 El FT (relating to stalking) FT 18 Pa.C.S. §2901 IT (relating to kidnapping) CD 71 2Z rn OD m > C) X c7, FT 18 Pa.C.S. §2902 El (relating to unlawful restraint) FT 18 Pa.C.S. §2903 FT (relating to false imprisonment) FT 18 Pa.C.S. §2910 (relating to luring a child into a motor vehicle or structure) FT 18 Pa.C.S. §3121 'relating to rape) FT 18 Pa.C.S. §3122.1 FT relating to statutory sexual assault) El 18 Pa.C.S. §3123 (relating to involuntary deviate sexual intercoursel FT 18 Pa.C.S. §3124.1 FT (relating to sexual assault) FT 18 Pa.C.S. §3125 (relating to aggravated indecent assault) 7 18 Pa.C.S. §3126 FT (relating to indecent assault) El FT 18 Pa.C.S. §3127 El El frelating to indecent exposure) FT 18 Pa.C.S. §3129 (relating to sexual intercourse with animals) FT 18 Pa.C.S. §3130 FT (relating to conduct relating to sex offenders) 18 Pa.C.S. §3301. (relating to arson and related offenses) FT 18 Pa.C.S. §4302 Irelating to incest) 18 Pa.C.S. §4303 (relating to concealing death of child) FT 71 FT 18 Pa.C.S. §4304 (relating to endangering welfare of children) FT 18 Pa.C.S. §4305 FT IT (relating to dealing in infant children) FT 18 Pa.C.S. §5902(b) (relating to prostitution and related offenses) FT 18 Pa.C.S. §5903 (c) or (d) (relating to obscene and other sexual materials and performances) FT 18 Pa.C.S. §6301 FT (relating to corruption of minors) FT 18 Pa.C.S. §6312 El El (relating to sexual abuse of children) El 18 Pa.C.S. §6318 El El (relating to unlawful contact with minor) Et 18 Pa.C.S. §6320 f I (relating to sexual exploitation of children) 23 Pa.C.S. §6114 El (relating to contempt for violation of Protection order or agreement) Driving under the I1 influence of drugs or alcohol i Manufacture, sale, delivery, holding, offering for sale or possession of arty controlled substance or other drug or device E 2. Unless indicated by my checking the box next to an item below, neither I nor any other member of my household have a history of violent or abusive conduct including the following: Check Self Other all that household apply member �! A finding of abuse by a Children & Youth Agency or similar agency in Pennsylvania or similar statute in another jurisdiction Abusive conduct as defined under the r 7 Protection from Abuse Act in Pennsylvania or similar statute in Date another jurisdiction Other: n . Please list any evaluation, counseling or other treatment received following conviction or finding of abuse: 4. If any conviction above applies to a household member, not a party, state that person's name, date of birth and relationship to the child : 5. If you are aware that the other party or members of the party's household has or have a criminal / abuse history, please explain: I verify that the information above is true and correct to the best of my knowledge information or belief. I understand that false statements- herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. 6,0( / /We- /Jeelqi Printed Name ROBERT WOOD V. TRACEY WOOD : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009 — 8929 CIVIL : CIVIL ACTION - LAW ORDER OF COURT AND NOW, this 22ND day of JULY, 2014, upon consideration of Defendant's Emergency Petition for Special Relief, it is DENIED. Xol-Dert Wood 715 Colonial Court Mechanicsburg, Pa. 17015 Tracey Wood 73 Partridge Circle Carlisle, Pa. 17013 :sld C Es crt.Lc.i._ I Edward E. Guido, J. ROBERT WOOD, • IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. TRACEY WOOD, CIVIL ACTION - LAW Defendant NO. 2009-8929 CIVIL TERM IN RE: CUSTODY ORDER OF COURT AND NOW, this 22nd day of August, 2014, after hearing, all prior custody orders are vacated and replaced with the following: 1. The parties shall have joint legal custody of their child, Alexandria D. Wood, born May 31, 2002. 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 c) health, education and religion. Pursuant to the tern o23' r; Pa. C.S. Section 5309, each parent shall be entitleTo S,11 Wi- cn' ry records and information pertaining to the child incc ding, >c"--) but not limited to medical, dental, religious or sciSeR1 up records, the residence address of the child and the (55he7. , 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. The parties shall share physical custody of the child as follows: A. During the school year mother shall have primary physical custody subject to periods of partial physical custody by father every other weekend from Friday at 5:00 p.m. until Sunday at 5:00 p.m. and at such other times as the parties may agree. B. During summer vacation the parties shall share primary physical custody on a week on weekoff basis with the exchanges to take place Sunday at 5:00 p.m. The summer schedule shall start on the first Sunday after school ends and shall end on the second Sunday before school begins. Provided however, that if either party wants to take a vacation out of the area, he or she shall be entitled to one week each summer where the exchange takes place 48 hours earlier at 5:00 p.m. and ends at the normal time. The parties shall give 30 days written notice of their intention to exercise this provision. 3. The following holiday schedule shall supercede the schedule set forth above. A. Christmas. In even -numbered years, father shall have the child from noon on December 25 until 5:00 p.m. on December 30. In odd -numbered years, father shall have the child from after school on the last day before Christmas recess begins until December 25 at noon and from December 30 at 5:00 p.m. until 5:00 p.m. the night before school resumes. B. In even -numbered years, father shall have the child from after school on the last day before Thanksgiving recess begins until 4:00 p.m. on Thanksgiving day. In odd -numbered years, father shall have the child from 4:00 p.m. on Thanksgiving day until the Sunday after Thanksgiving at 5:00 p.m. C. Father shall have the child from 9:00 a.m. to 5:00 p.m. on Father's Day. D. Mother shall have the child from 9:00 a.m. to 5:00 p.m. on Mother's Day. 4. The party obtaining custody of the child shall pick the child up at the other party's residence or such other place as may be agreed. 5. Neither party shall disparage the other in the presence of the child nor say anything to turn the child against the other party. 6. 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. Section 5337. By the Court, Edward E. Guido, Robert Wood 715 Colonial Court Mechanicsburg, PA 17050 ✓ Tracey Wood 73 Partridge Circle Carlisle, PA 17013 :lfh @Op ii2.11..€4, WAL.py x COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROBERT WOOD, Plaintiff v. TRACEY WOOD, Defendant No. 2009-8929 Petition for Modification 1. Petitioner is Plaintiff, ROBERT WOOD, who currently resides at 400 Timber Circle, New Bloomfield, Perry County, PA 17068. 2. Respondent is Defendant, TRACEY WOOD, who currently resides at 73 Partridge Circle, Carlisle, Cumberland County, PA 17013. 3. Petitioner and Respondent are the natural parents of the following child: Name Age ALEXANDRIA D. WOOD 12 years 4. A custody order was entered on August 22, 2014, in the Cumberland County Court of Common Pleas. A copy of the custody order is attached. 6. Petitioner seeks to modify the custody order because: Daughter was NOT enrolled in school last week, but Domestic Relations paperwork was. As I stated in court, mother is incapable of making sure that daughter comes first. She is already truant from West Perry Middle School, where she was enrolled when I had SOLE LEGAL/ PRIMARY PHYSICAL CUSTODY. I want the Judge to make a decision based on what is best for my daughter, not by what my daughter would prefer...which is NO adult supervision or parenting. 7. Petitioner believes the custody order should be changed as follows: I want SOLE LEGAL/PRIMARY PHYSICAL, like the previous order. .�-ea ,/-4cea ,��� 3/e W6 WHEREFORE, Petitioner respectfully requests that this Court modify the Order as requested. Date: 9-2- 20/y ROERT WOOD, Plaintiff Verification I, ROBERT WOOD, Plaintiff, verify that the facts stated in the foregoing Petition are true and correct to the best of my knowledge, information and belief. Petitioner understands that false statements therein are subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Date: 9'1-20/y 8 RPlaintiff BERT W OD P 1, 0132-7-- &)o DO Plaintiff Vs 6r'19t2..o Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, P,) No. ' 00,>79 CIVIM CIVIL ACTION - LAW ry IN CUSTODY <c _ CRIMINAL RECORD / ABUSE HISTORY VERIFICATION I, 6&L (/V Di0# , hereby swear or affirm, subject to penalties of law including 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities that: 1. Unless indicated by my checking the box next to a crime below, neither I nor any other member of my household have been convicted or pled guilty or pled no contest or was adjudicated delinquent where the record is publicly available pursuant to the Juvenile Act 42 Pa.C.S. § 6307 to any of the following crimes in Pennsylvania or a substantially equivalent crime in any other jurisdiction, including pending charges: Check all that apply Crime Self Other Date of Sentence household conviction, member guilty plea, no contest plea or pending charges 18 Pa.C.S. Ch. 25 E fl (relating to criminal homicide) 18 Pa.C.S. §2702 E fl (relating to aggravated assault) 18 Pa.C.S. §2706 E El (relating to terroristic threats) 18 Pa.C.S. §2709.1 1 (relating to stalking) 18 Pa.C.S. §2901 ❑ E (relating to kidnapping) 3r fl 18 Pa.C.S. §2902 FT (relating to unlawful restraint) IT 18 Pa.C.S. §2903 7 7 (relating to false imprisonment) 18 Pa.C.S. §2910 fl E1 (relating to luring a child into a motor vehicle or structure) 18 Pa.C.S. §3121 JT (relating to rape) 17 18 Pa.C.S. §3122.1 TT] fl relating to statutory sexual assault) 18 Pa.C.S. §3123 (relating to involuntary deviate sexual intercourse) fl 18 Pa.C.S. §3124.1 EF (relating to sexual assault) F 18 Pa.C.S. §3125 (relating to aggravated indecent assault JT 18 Pa.C.S. §3126 n (relating to indecent assault) ITT 18 Pa.C.S. §3127 fl r_ (relating to indecent exposure) fl 18 Pa.C.S. §3129 (relating to sexual intercourse with animals) 7 18 Pa.C.S. §3130 EJ (relating to conduct relating to sex offenders' 18 Pa.C.S. §3301 (relating to arson and related offenses' fl 18 Pa.C.S. §4302 (relating to incest) 18 Pa.C.S. §4303 (relating to concealing death of child) 18 Pa.C.S. §4304 (relating to endangering welfare of children) 18 Pa.C.S. §4305 (relating to dealing in infant children) fl 18 Pa.C.S. §5902(b) ECTi (relating to prostitution and related offenses) 7 18 Pa.C.S. §5903 fl E (c) or (d) (relating to obscene and other sexual materials and performances) fl 18 Pa.C.S. §6301 El (relating to corruption of minors) 18 Pa.C.S. §6312 (relating to sexual abuse of children) 18 Pa.C.S. §6318 7 7 (relating to unlawful contact with minor) 1 18 Pa.C.S. §6320 (relating to sexual exploitation of children) 23 Pa.C.S. §6114 (relating to contempt for violation of Protection order or agreement) Driving under the influence of drugs or alcohol Manufacture, sale, delivery, holding, offering for sale or possession of any controlled substance or other drug or device E E I E 2. Unless indicated by my checking the box next to an item below, neither I nor any other member of my household have a history of violent or abusive conduct including the following: Check all that apply Self Other household member r A finding of abuse by a Children & Youth 7 E Agency or similar agency in Pennsylvania or similar statute in another jurisdiction } Abusive conduct as defined under the Protection from Abuse Act in Pennsylvania or similar statute in E Date another jurisdiction Other: E 3. Please list any evaluation, counseling or other treatment received following conviction or finding of abuse: 4. If any conviction above applies to a household member, not a party, state that person's name, date of birth and relationship to the child : 5. If you are aware that the other party or members of the party's household has or have a criminal / abuse history, please explain: I verify that the information above is true and correct to the best of my knowledge information or belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Db Printed Name ROBERT WOOD PLAINTIFF V. TRACEY WOOD DEFENDANT • IN THE COURT OF COMMON PLEAS OAF CUMBERLAND COUNTY, PENNSYLVAI 2009-8929 CIVIL ACTION LAW IN CUSTODY �cr ORDER OF COURT w'- 7.7 AND NOW, Friday, September 05, 2014 , 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 Wednesday, October 01, 2014 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. You must file with the Court a verification regarding any criminal record or abuse history regarding you and anyone living in your household on or before the initial in-person contact with the court (including, but not limited to, a conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition. No party may make a change in the residence of any child which significantly impairs the ability of the other party to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and Pa.R.C.P. No. 1915.17 regarding relocation. FOR THE COURT, By: /s/ Jacqueline M. Verney, Esq. 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. Copies /yJ bz el 0 PI CC •-beef o do/n � E51. 14/L Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ROBERT WOOD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. TRACEY WOOD, Defendant : NO. 2009-8929 CIVIL ACTION - LAW C) : IN CUSTODY ORDER OF COURT --off zr*� -c> r-.. AND NOW, this 3 day of aL�.6� , 2014, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: -o ry c.r) • _ min the c _-G ;4 �„ `,c ..•,. • e. The parties are directed to proceed with filing a pretrial statement with the Court and the other party consistent with the Pennsylvania Rule of Civil Procedure 1915.4-4. 2. A Hearing is scheduled in Court Room County C rt House, on the y'* day of o'clock, 1. M., at which time testimony will be taken. Father shall be deemed to be the moving party and shall. , of the Cumberland ,201.4, at / •00 For purposes of this Hearing, proceed initially with testimony. 3. Pending a hearing, the prior Order of Court dated August 22, 2014 shall remain in full force and effect. 4. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. cc: Tracey Wood, pro se 3 Partridge Circle Carlisle, PA 17013 Robert Wood, pro se 400 Timber Circle New Bloomfield, PA 17068 f► s { / fi' (_=-t, 1/ A/M J. ROBERT WOOD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-8929 CIVIL ACTION - LAW TRACEY WOOD, Defendant : IN CUSTODY PRIOR JUDGE: Edward E. Guido, 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 Alexandria D. Wood May 31, 2002 Father 2. A Conciliation Conference was held in this matter on October 1, 2014, with the following in attendance: The Mother, Tracey Wood, pro se and the Father, Robert Wood, pro se. 3. The Honorable Edward E. Guido previously entered an Order of Court dated August 22, 2014 providing for shared legal custody, Mother having primary physical custody during the school year and the parties sharing physical custody in the summer. 4. Father filed a Petition to Modify. 5. Father's position on custody is as follows: Father seeks shared legal custody and primary physical custody. Father asserts that Mother did not enroll the child in school until September 2, 2014. 6. Mother's position on custody is as follows: Mother seeks to maintain the status quo. Mother asserts that the school would not enroll the child until she could provide a copy of the Court Order to school officials. 7. The Conciliator recommends an Order in the form as attached scheduling a Hearing, and maintaining the status quo. It is expected that the Hearing will require one hour. Date: acq me M. Verney, Esquire Custody Conciliator ROBERT WOOD, Plaintiff v. TRACEY WOOD, Defendant IN CUSTODY • • • • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-8929 CIVIL TERM ORDER OF COURT AND NOW, this 4th day of December, 2014, our Order of August 22nd, 2014, shall remain in full force and effect, and Father's Petition to Modify is DENIED. By the Court, Edward E. Guido, J. ✓ Robert Wood 400 Timber Circle New Bloomfield, PA 17068 ✓ Tracey Wood 73 Partridge Circle Carlisle, PA 17013 srs ��� £s I'1. i zieM :::=EL0/7 f's`! co CO 3'4 _,�