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HomeMy WebLinkAbout04-33791 2 3 4 5 6 7 $ 9 10 11 12 13 14 15 16 17 19 20 21 22 23 24 25 26 Page ENTERED BY: DE IN THE CIRCUIT COURT OF THE STATE OF OREGON In the Matter of GEORGE MACKIE COR_N~ALL, Ill., Petitioner, and STEPHANIE LYNN CORNWALL, Respondent. FOR THE COUNTY OF CLACKAIvI, AS ) Case No. DR03-03721 ) ) MOTION AND ORDER ) RE: LIMITED JUDGMENT FOR ) PENDENTE LITE ) ) ) ) ) Tlds matter came before Judge Eve Miller in the Clackamas County Court, on December 8, 2003, upon the agreement of the parties. The Motion of Show Cause submitted by Respondent's attorney was settled and parties placed their agreement on the record. Petifoner, appealing by and through his attorney, Shannon Connall, and Respondent, appearing by and through her attorney, Larry J. Blake, Jr., and the Court being fully advised in the premises after reviewing the fries: IT IS HEREBY ORDERED, ADJUDGED AND DECREED that: 1. CUSTODY/PARENTING TIME. Mother shall have sole legal and physical custody of George M. Cornwall, IV., born November 11, 1998. Parenting time shall be as follows: a. Father shall only have supervised parenting plan with supervisor to be determined by agreement of parties or by further order oft&is court. 1 - MOTION AND ORDER RE: LIMITED JUDGMENT FOR PENDENTE LITE 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Page /// /// /// b. If Father travels to Pennsylvania for parenting time ~vith minor child, Father shall bear the expenses of travel and expenses associated with the supervised parenting time. Parenting time in Pennsylvania with father is most likely to be at the YWCA located in Carlisle, Pennsylvarda. c. If Father requests to have parenting time in Portland, Oregon, Father will bear the expenses for Respondent and minor child to travel and stay in Portland, Oregon for the duration of the parenting time. Father will also bear the cost of supervision for parenting time and costs associated with Mother for rrfissing dine from work. [. Mother will only be required to travel to Portland, Oregon for parenting me if the nme is ava/lable for her to travel and she agrees to travel with the minor child to Portland, Oregon. h. Mother agrees to allow father to have telephone contact with the parties' minor child prior to ch/id going to bed each evening. Mother wiJ1 lint/ate the phone call between minor ch/Id and Father with the phone call lasting a maximum of fifteen minutes. Father shall have no telephone contact with Mother other than the telephone contact Mother initiates between Father and minor child. CHILD SUPPORT. Father agrees to pay child support in the mount of $900.00 per month to Mother beginning December 15, 2003, and every month thereafter on the 15th of the month until further order of this Court. a. Father agrees to pay arrears of child support owed to Mother in the total amount of $900.00 by December 8, 2003. DEBTS, Father agrees to pay all current payments for the fam//y residence, including payments which would also include insurance costs, taxes, and homeowner fees. 2 - MOTION AND ORDER RE: LIMITED JUDGMENT FOR PENDENTE LITE 6 7 8 9 10 1I 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Page MEDICAL EXPENSES. Father agrees to continue the medical insurance premium for the benefit of Mother and minor child, and agrees to pay one-half of the minor child's uninsured medical, dental, optical and orthodontic bills that may be incurred. ATTORNEY FEES. The issue of attorneys' fees shall be deferred until final determination of this matter. EX PARTE MOTION. The Ex parte Motion filed by Petitioner and signed by Judge Tom on March 27, 2003 remains in full force dmmg the pendency of this matter. MONEY AWARD Creditor: Creditor's Address: Creditor's Attorney: Attorney's Address: Debtor: Debtor's Address: Debtor'.,; Attorney: Attorney's Address: Money Award: Attorney's Fees: Beginning Date: Ending Date: Prejudgn~ent Interest: Attorney's Fees and Costs: Post Judgnnent Interest: Stephanie Comwali 4236 Carhsle Road Gardners, PA 17324 Larry J. Blake, Jr. 3718 SW Condor, Suite 110 Portland, OR 97239 George Cornwall 1897 Boca Raton Drive Lake Oswego, OR 97034 Shannon ConnaLl 621 SW Morrison, Suite 140 Portland, OR 97205 $900.00 per month for child support. To be deterrmned at later date. December 8, 2003 9% per annum upon entry of judgment ~ Cerfi~ed Tale Copy Of TIle Original __Judge Eve{ l~iller ~ 3 - MO~~I~ ~~G~NT FOR PENO~ LI~ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Page George Mackie Cornwall, III., Petitioner Notary Pubhc of Oregon My Comrmssion Expires: Submitted by: Larry J. Blake, Jr., OSB~87172 Attorney for Respondent Stephame Lynn Cornwall, Respondent Notary Public of Oregon My Comm~sion Expires: St/pulated and Agreed to by: Shannon Connall OSB#97538 Attorney for Petitioner 4 - MOTION AND ORDER KE: LIMITED JUDGMENT FOR PENDENTE LI~IE 1 2 3 4 5 6 7 8 9 10 I1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 3O 31 32 33 34 35 36 37 38 39 4O 41 42 43 45 46 47 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACT[ON - LAW In the matter of the marriage of George bl. Cornwall, III, Petitioner, Probe and Stephanie Lynn Cornwall, Respondent 0 ¢' 37q d ;I NOTICE AND ORDER TO APPEAR PETITION FOR CONTEMPT NOTICE AND ORDER TO APPEAR PETTI'~ON FOR CONTEMPT Legal proceedings have been brought against you alleging you have willfully disobeyed an Order of the Circuit Court of the State of Oregon for the County of Clackamas Court for visitation. ~ 6.53 1. Kozlowski v. Kozlowski, 362 Pa. Super, 516, 524 A.2d 995 (1987) 2. Pa.R.C.P. No. 1915.12(b) 3. Pa.R.C.P. No. 1915.12 ff you wish to defend against the claim set forth in the following pages, you may but you are not required to file in writing with the court your defenses or objections. Whether or not you file in writing with the Court your defenses or objections, you must appear in Person in Court on , 2004, in Court Room before the Honorable COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CARLISLE COURT HOUSE 1 Court House Square Carlisle, Pennsylvania 07/12/04 I of 2 Notice and Order to Appear 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 7O 71 72 73 74 75 76 77 78 79 81 82 83 84 85 86 87 88 IF YOU DO NOT APPEAR IN PERSON, THE COURT MAY ISSUE A WARRANT FOR YOUR ARREST. If The Court finds that you have willfully failed to comply with its order in support of the Oregon Order for visitation, you may be found in contempt of Court and committed to jail, fined, or both. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. ZF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,. GO TO OR TELEPHONE THE OFFZCE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. (NAME) (Address) (Telephone Number) By the Court: Date: George M. Cornwall 11I, Petitioner 1897 Boca Ratan Drive Lake Oswego, OR 97034 (503) 784-3888 Copies by mail to: Larry Blake, Jr. 3718 SW Condor #110 Portland, OR 97239 Stephanie L. Cornwall 4236 Cadisle Road Gardners, PA. 17324 07/12/04 2of2 Notice and Order to Appear 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 tN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CML ACTION - LAW In the matter of the marriage of George M. Cornwall, III, Petitioner, Pr~e and Stephanie Lynn Cornwall, Respondent } } } Pe 11 ~ ION FOR SPECIAL RELIEF REGARDING VISITATION PETTr~ON FOR SPECL~L REL/EF REGARDING V~SITAT/ON AND NOW, this 9t~ day of July 2004, comes the Petitioner, Pro Se, to petition this Honorable Court to enter an order with respect to visitation and in support thereof, and avers as follows: 1. The parties have one minor child, George Hackle Cornwall IV, DOB November 11, 1998. 2. Petitioner is the father of the child and resides at 1897 Boca Ratan Drive, Lake Oswego, (Clackamas County), OR 97034, (503) 784-3888. The Respondent resides at 4236 Cadisle Road, Gardners, (Cumberland County), and PA 17324, (717) 486-3634. This house was purchased using non-marital assets provided by the Petitioner for the down payment and closing costs. Currently a petition for legal separation of the parties is pending in the Circuit Court of the State of Oregon for the County of Clackamas. The Respondent has additionally petitioned the court to convert the case to a dissolution proceeding. On December 8~, 2003 that court issued a Pendente lite order providing for visitaUon of the minor son by the Petitioner. A c~-tified ~oDv of this order is provided and attached herewith. The Clerk of that court suggested the use a certified copy of the Oregon order with this Honorable Court. This certified copy of the Oregon Court's order was provided to me for that express purpose. Since January 24t~, 2004 respondent has routinely contrived to prevent the ordered visitaUons by various means, including removing the minor son from Nursery School, removing him from the home. There has also been an ongoing general refusal to 0~1~04 lof2 Petition for Special Relief 48 49 5O 51 52 53 54 55 56 57 58 59 6O 61 62 63 64 65 66 67 68 69 7O 71 72 73 74 75 76 77 78 79 8O 82 83 84 85 86 87 88 89 9O 91 92 93 communicate about a vadety of topics, including the visitation schedule, or do anything else that might in any way facilitate any visitation. Respondent has by v. adous means, including fleeing from the State of Oregon, prevented any meaningful contact between Petitioner and the Minor Child since December 5, 2002. Petitioner believes that respondent recently even went so far as to place the child, for days at a time, in the homes of relatives up to 50 miles distant from the Gardners, PA residence. This apparently has been done for most of the last week. According to the Child, He was told that these actions were required so that he could be adequately protected from Petitioner. All of these actions have been for the express purpose of thwarting Petitioner's attempts to exercise even one visit as provided by the aforementioned order. Certainly, these actions do NOT serve the best interests of the klinor child. The best interests of the child would be served by provide frequent and relaxed contact in an atmosphere of adult cooperation and communication. Fear mongedng only serves to frighten the child, further straining an already damaged relationship. 10. Circuit court action is pending in Oregon to significanUy amend and ameliorate the visitation rights allowed the Petitioner under the aforementioned order, however petitioner has now made a total of five (5) transcontinental trips, without ever being permitted contact. Though two of the trips were made while petitioner lacked permission to travel outside Oregon, Petitioner has never attempted to schedule visits of a type or duration that were over and above those permitted at the time by the Oregon Courts. Wherefore Petitioner prays your Honorable Court to enter an order directing the Respondent to comply with the visitation provisions of this order without further delay or artifice. Further, that Respondent be admonished that conUnued interference with the existing and future court orders arising from these matters, will serve to subject her to possible sanctions for contempt of the Orders of This Court. George M. Cornwall III, Petitioner Copies by mail to: Larry Blake, Jr. 3718 SW Condor #110 Portland, OR 97239 Stephanie L. Cornwall 4236 Cadisle Road Gardners, PA. 17324 07/12/04 2 of 2 Petition for Special Relief 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 15 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 IN THE COURT OF COIqMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW In the matter of the marriage of George M. Cornwall, III, Petitioner, Pro ~e and Stephanie Lynn Cornwall, Respondent } } } } } } } PETITION FOR SPECLAL RELIEF REGARDING VISITATION PETTFION FOR SPECIAL RELIEF REGARDING VI$1TATION AND NOW, this gm day of 3uiy 2004, comes the PeMtioner, Pro Se, to petition this Honorable Court to enter an order with respect to visitaMon and in support thereof, and avers as follows: 1. The parties have one minor child, George Mackie Cornwall IV, DOB November 11, 1998. 2. Petitioner is the father of the child and resides at 1897 Boca Ratan Drive, Lake Oswego, (Clackamas County), OR 97034, (503) 784-3888. The Respondent resides at 4236 Carlisle Road, Gardners, (Cumberland County), and PA 17324, (717) 486-3634. This house was purchased using non-marital assets provided by the Petitioner for the down payment and closing costs. Currently a petition for legal separation of the parties is pending in the Circuit Court of the State of Oregon for the County of Clackamas. The Respondent has additionally petitioned the court to convert the case to a dissolution proceeding. On December 8~, 2003 that court issued a Pendente Lite order providing for visitation of the minor son by the Petitioner. A certifie~l colRf of this order is provided and attached herewith. The Clerk of that court suggested the use a certified copy of the Oregon order with this Honorable Court. This certified copy of the Oregon Court's order was provided to me for that express purpose. Since January 24t~,, 2004 respondent has routinely contrived to prevent the ordered visitations by various means, induding removing the minor son from Nursery School, removing him from the home. There has also been an ongoing general refusal to 07/12/04 i of 2 Petition for Special Relief 48 49 5O 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 7O 71 72 73 74 75 76 77 78 79 8O 82 83 84 85 86 87 88 89 9O 91 92 93 communicate about a variety of topics, including the visitation schedule, or do anything else that might in any way fadlitate any visitation. Respondent has by various means, including fleeing from the State of Oregon, prevented any meaningful contact between Petitioner and the Minor Child since December 5, 2002. Petitioner believes that respondent recently even went so far as to place the child, for days at a time, in the homes of relatives up to 50 miles distant from the Gardners, PA residence. This apparently has been done for most of the last week. According to the Child, He was told that these actions were required so that he could be adequately protected from Petitioner. All of these actions have been for the express purpose of thwarting Petitioner's attempts to exercise even one visit as provided by the aforementioned order. Certainly, these, actions do NOT serve the best interests of the Minor child. The best interests of the child would be served by provide frequent and relaxed contact in an atmosphere of adult cooperation and communication. Fear mongering only serves to frighten the child, further straining an already damaged relationship. 10. Circuit court action is pending in Oregon to significantly amend and ameliorate the visitation rights allowed the Petitioner under the aforementioned order, however petitioner has now made a total of five (5) transcontinental trips, without ever being permitted contact. Though two of the trips were made while petitioner lacked permission to travel outside Oregon, Petitioner has never attempted to schedule visits of a type or duration that were over and above those permitted at the time by the Oregon Courts. Wherefore Petitioner prays your Honorable Court to enter an order directing the Respondent to comply with the visitetJon provisions of this order without further delay or artifice. Further, that Respondent be admonished that continued interference with the existing and future court orders arising from these matters~ will serve to subject her to possible sanctions for contempt of the Orders of This Court. Date: _July 8, 2004 _ ~---~, /~.-~ George M?Cornwall III, Petitioner Copies by mail to: Larry Blake, .Ir. 3718 SW Condor #110 Portland, OR 97239 Stephanie L. Cornwall 4236 Cadisle Road Gardners, PA. 17324 07/12/04 2 of 2 Petition for Special Relief 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 45 46 47 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA C~V~L ACTZON - LAW In the matter of the marriage of George M. Cornwall, III, Petitioner, Pro and Stephanie Lynn Cornwall, Respondent NOT[CE AND ORDER TO ~PPE~R PETITION FOR CONTEMPT NOTICE AND ORDER TO APPEAR PETTI'~ON FOR CONTEMPT Legal proceedings have been brought against you alleging you have willfully disobeyed an Order of the Circuit Court of the State of Oregon for the County of Clackamas Court for visitation. ~ 6.53 1. Kozlowski v. Kozlowski, 362 Pa. Super, 516, 524 A.2d 995 (1987) 2. Pa.R.C.P. No. 1915.12(b) 3. Pa.R.C.P. No. 1915.12 If you wish to defend against the claim set forth in the following pages, you may but you are not required to file in writing with the court your defenses or objections. Whether or not you file in writing with the Court your defenses or objections, you must appear in Person in Court on 2004, in Court Room before the Honorable COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CARLISLE COURT HOUSE 1 Court House Square Carlisle, Pennsylvania 07/12/04 1 of 2 Notice and Order to Appear 48 49 5O 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 81 82 83 84 85 86 87 88 IF YOU DO NOT APPEAR IN PERSON, THE COURT MAY ISSUE A WARRANT FOR YOUR ARREST. If The Court finds that you have willfully failed to comply with its order in support of the Oregon Order for visitation, you may be found in contempt of Court and committed to jail, fined, or both. YOU SHOULD TAKE TH~S PAPER TO YOUR LAWYER AT ONCE. XF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFF/CE SET FORTH BELOW TO I~ND OUT WHERE YOU CAN GET LEGAL HELP. (NANE) (Address) (Telephone Number) By the Court: Date: George M. Cornwall III, Petitioner 1897 Boca Ratan Drive Lake Oswego, OR 97034 (503) 784-3888 Copies by mail to: Larry Blake, 3r. 3718 SW Condor #110 Portland, OR 97239 Stephanie L. Cornwall 4236 Carlisle Road Gardners, PA. 17324 07/12/04 2 of 2 Notice and Order to Appear I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 I'N THE COURT OF COHHON PLEAS OF CUHBERLAND COUNTY, PA CIVIL AC I ION - LAW In the matter of the marriage of George M. Cornwall, III, Petitioner, ~.Ce and Stephanie Lynn Cornwall, Respondent } } } } } } } } } PETITION FOR SPECIAL RELIEF REGARDING VISITATION PETTrt'ON FOR SPEC~A.L REI I'EF REGARDING V~STI'ATiON AND NOW, this 9~ day of 3uly 2004, comes the Petitioner, Pro Se, to petition this Honorable Court to enter an order with respect to visitation and in support thereof, and avers as follows: 1. The parties have one minor child, George Mackie Cornwall IV, DOB November 11, 1998. 2. Petitioner is the father of the child and resides at 1897 Boca Ratan Drive, Lake Oswego, (Clackamas County), OR 97034, (503) 784-3888. The Respondent resides at 4236 Cadisle Road, Gardners, (Cumberland County), and PA 17324, (717) 486-3634. This house was purchased using non-marital assets provided by the Petitioner for the down payment and closing costs. Currently a petition for legal separation of the parties is pending in the Circuit Court of the State of Oregon for the County of Clackamas. The Respondent has additionally petitioned the court to convert the case to a dissolution proceeding. On December 8~, 2003 that court issued a Pendente Ute order providing for visitation of the minor son by the Petitioner. A certified copy of this order is provided and attached herewith. The Clerk of that court suggested the use a certified copy of the Oregon order with this Honorable Court. This certified copy of the Oregon Court's order was provided to me for that express purpose. Since 3anua~' 24~h, 2004 respondent has routinely contrived to prevent the ordered visitations by vadous means, including removing the minor son from Nursery School, removing him from the home. There has also been an ongoing general refusal to o?/i2/o4 1 of 2 Petition for Special Relief 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 communicate about a vadety of topics, including the visitation schedule, or do anything else that might in any way facilitate any visitation. Respondent has by various means~ including fleeing f~om the State of Oregon, prevented any meaningful contact between Petitioner and the Minor Child since December 5, 2002. Petitioner believes that respondent recently even went so far as to place the child, for days at a time,, in the homes of relatives up to 50 miles distant from the Gardners, PA residence. This apparently has been done for most of the last week. According to the Child, He was told that these actions were required so that he could be adequately protected from Petitioner. All of these actions have been for the express purpose of thwarting Petitioner's attempts to exercise even one visit as provided by the aforementioned order. Certainly, these actions do NOT serve the best interests of the Minor child. The best interests of the child would be served by provide frequent and relaxed contact in an atmosphere of adult cooperation and communication. Fear mongedng only serves to frighten the child, further straining an already damaged relationship. 10. Circuit court action is pending in Oregon to significantly amend and ameliorate the visitation rights allowed the Petitioner under the aforementioned order, however petitioner has now made a total of five (5) transcontinental trips, without ever being permitted contact. Though two of the tdps were made while petitioner lacked permission to travel outside Oregon, Petitioner has never attempted to schedule visits of a type or duration that were over and above those permitted at the time by the Oregon Courts. Wherefore Petitioner prays your Honorable Court to enter an order directing the Respondent to comply with the visitation provisions of this order without further delay or artifice. Further, that Respondent be admonished that continued interference with the existing and future court orders arising from these matters, will serve to subject her to possible sanctions for contempt of the Orders of This Court. George M. Cornwall III, Petitioner Copies by mail to: Lam/Blake, ]r. 3718 SW Condor #110 Portland, OR 97239 Stephanie L. Cornwall 4236 Carlisle Road Gardners, PA. 17324 07/12/04 2 of 2 Petition for Special Relief 1 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 IN THE COURT OF COHHON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW In the matter of the marriage of George M. Cornwall, III, PeUtioner, Pro~e and Stephanie Lynn Cornwall, Respondent } } } } } } } PETITION FOR SPECIAL RELIEF REGARDING VISITATION PETITION FOR SPECIAL RELIEF REGARDING VISITATION AND NOW, this 9m day of 3uiy 2004, comes the Petitioner, Pro Se, to petition this Honorable Court to enter an order with respect to visitation and in support thereof, and avers as follows: 1. The parties have one minor child, George Mackie Cornwall IV, DOB November 11, 1998. 2. Petitioner is the father of the child and resides at 1897 Boca Ratan Drive, Lake Oswego, (Clackamas County), OR 97034, (503) 784-3888. The Respondent resides at 4236 Cadisle Road, Gardners, (Cumberland County), and PA 17324, (717) 486-3634. This house was purchased using non-marital assets provided by the Petitioner for the down payment and closing costs. Currently a petition for legal separation of the parties is pending in the Circuit Court of the State of Oregon for the County of Clackamas. The Respondent has additionally petitioned the court to convert the case to a dissolution proceeding. On December 8~, 2003 that court issued a Pendente Ute order providing for visitation of the minor son by the Petitioner. A certifi~l (X~l~/ of this order is provided and attached herewith. The Clerk of that court suggested the use a certified copy of the Oregon order with this Honorable Court. This certified copy of the Oregon Court's order was provided to me for that express purpose. Since 3anuary 24~, 2004 respondent has routinely contrived to prevent the ordered visitations by various means, including removing the minor son from Nursery School, removing him from the home. There has also been an ongoing general refusal to 07/12/0~ lof2 Petition for Special Relief 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 communicate about a variety of topics, including the visitation schedule, or do anything else that might in any way facilitate any visitation. Respondent has by various means~ including fleeing from the State of Oregon, prevented any meaningful contact between Petitioner and the Minor Child since December 5, 2002. Petitioner believes that respondent recently even went so far as to place the child, for days at a timer in the homes of relatives up to $0 miles distant from the Gardners, PA residence. This apparently has been done for most of the last week. According to the Child, He was told that these actions were required so that he could be adequately protected from Petitioner. All of these actions have been for the express purpose of thwarting Petitioner's attempts to exercise even one visit as provided by the aforementioned order. Certainly, these actions do NOT serve the best interests of the Minor child. The best interests of the child would be served by provide frequent and relaxed contact in an atmosphere of adult cooperation and communication. Fear mongedng only serves to frighten the child, further straining an already damaged relationship. 10. Circuit court action is pending in Oregon to significantly amend and ameliorate the visitation rights allowed the Petitioner under the aforementioned order, however petitioner has now made a total of five (5) transcontinental tdps, without ever being permitted contact. Though two of the trips were made while petitioner lacked permission to travel outside Oregon, Petitioner has never attempted to schedule visits of a type or duration that were over and above those permitted at the time by the Oregon Courts. Wherefore Petitioner prays your Honorable Court to enter an order directing the Respondent to comply with the visitation provisions of this order without further delay or artifice. Further, that Respondent be admonished that continued interference with the existing and future court orders arising from these matters, will serve to subject her to possible sanctions for contempt of the Orders of This Court. Date: _July 8, 2004 _ ~;~~, George M,/Comwall III, Petitioner Copies by mail to: Larry Blake, Jr. 3718 SW Condor #110 Portland, OR 97239 Stephanie L. Cornwall 4236 Cadisle Road Gardners, PA. 17324 07/12/04 2 of 2 Petition for Special Relief GEORGE M. CORNWALL, III PLAINTIFF STEPHANIE LYNN CORNWALL DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-3379 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursda~_July_22, 2004 _, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear beibre Dawn S. Sunda , EsY~E~q~' the conciliator at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesd_ay, August 24 2004 -- ~ at 8:30 _AM for a Pre-Hearing Custody Conference. At such conference, an eftbrt 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 tern ora order All children age five or older may also be -res ............ P ry provide grounds for entry of a temporary or permanent order. *, ~,~t at me comerence. Failure to appear at the conference may 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/ ----------dD~n S._S1tnday.~tb_~mhc Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Dlsabthtes 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff CIVIL ACTION - LAW No. 04-3379 STEPHANIE LYNN CORNWALL, Defendant .PRAECIPE TO ENTER APPEARJdNCE To the Prothonotary: Please enter my appearance on behalf of the Plaintiff, George M. Cornwall, III, in the above- captioned matter. Respectfully submitted, Dated: July ~$., 2004 HANFT & KNIGHT, P.C. Attorney I.D. No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 Attorneys for Plaintiff 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. CORNWALL, III, Plaintiff STEPHANIE LYNN CORNWALL, Defendant CIVIL ACTION - LAW No. 04-3379 CERTIFICATE OF SERVIC_I~ · ul 2004, I, Sean M. Shultz, Esquire, hereby certify that I AND NOW, this ~.. day of J y.. e fore oing Praecipe to Enter Appearance have this day served the following person with a copy of th g by first class, United States Mail, postage pre-paid, addressed as; follows: Larry Blake, Jr., Esquire 3718 SW Condor #110 Portland, Oregon 97239 Attorney for Defendant HANFT & KNIGHT, P.C. Attorney I.D. No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, Pennsy][vania 17013-9142 (717) 249-5373 Attorneys for Plaintiff GEORGE M. CORNWALL, Plaintiff/Petitioner VS. STEPHANIE LYNN CORNWALL, Defendant/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 04-3379 CIVIL ACTION - LAW IN CUSTODY .NOTICE TO PLEAD You are hereby notified to file a written response to the within New Matter within twenty days (20) days from service hereof or a judgment may be entered against you. GEORGE M. CORNWALL, III, Plaintiff/Petitioner VS. STEPHANIE LYNN CORNWALL, Defendant/Respondent : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-3379 CIVIL ACTION - LAW : : : IN CUSTODY .PRELIMINARY OBJECTIONS ,TO JURISDICTION AND VENUE AND NOW, comes Defendant/Respondent, Stephanie Lynn Cornwall, by and through her counsel, Bradley L. Griffie, Esquire, and files the following Preliminary Objections: Defendant/Respondent is an adult individual currently residing at 4236 Carlisle Road, Gardners, Cumberland County, Pennsylvania. Plaintiff/Petititoner is George M. Cornwall, III, an adult individual whose last known address is 1897 Boca Ratan Drive, Lake Oswego, Clackamas County, Oregon. The parties are the natural parents of one (1) child, ntamely, George Mackie Cornwall IV, born November 11, 1998. The parties' marital residence, the place of the child's birth, and the primary residence of the child since his birth exists in the County of Clackamas in the State of Oregon. The parties are engaged in divorce litigation, as well as custody litigation, in the Circuit Court of the State of Oregon for Clackamas Connty, which Court has entered various Orders relative to the parties' legal matters, including a Order scheduling a hearing for 9:00 a.m. on September 21, 2004. Attached hereto and incorporated herein by reference as Exhibit "A" is a faxed copy of the Order of Court from the Circuit Court of the St~,te of Oregon for the County of Clackamas setting forth the terms of custody relative to the child at issue herein, said Order being entered by agreement of the parties on December 8, 2003; a true and attested copy of the Order is being forwarded to the undersigned from Respondent's counsel in the State of Oregon. 7. There is pending, before the Circuit Court of the State of Oregon for the County of Clackamas, a Petition and Motion filed by Petitioner herein requesting unsupervised visitation time, and other modifications to that Court's prior Order. 8. Petitioner has filed a Motion requesting a custody evaluation through the Circuit Court in the State of Oregon for the County of Clackamas, which Motion is pending at present. 9. Petitioner not only has a Petition pending for unsupervised contact with the parties' child, but also has other Motions pending to which Respondent has filed an appropriate response within the last month and which will cause further proceedings before the Circuit Court of the State of Oregon for the County of Clackamas. 10. Petitioner's Petition for Special Relief filed with this Court regarding visitation references in paragraph 5 the entry of an Order following agreement of the parties made in open Court on December 8, 2003, relative to custody of the child at issue in these proceedings. 11. In paragraph 10 of Petitioner's Petition, he identifies the fact that "Circuit Court action is pending in Oregon to significantly amend and ameliorate the visitation rights allowed the Petitioner under the aforementioned Order..." 12. Petitioner's Petition, on its face, lacks appropriate venue and jurisdiction and illustrates an attempt on the part of Petitioner to fbrum shop to in some manner supersede the jurisdiction of the Circuit Court of the State of Oregon for the County of Clackamas, which has assumed and retained jurisdiction over the issue of custody in this case, with custody matters presently pending. WHEREFORE, Respondent requests your Honorable Court to dismiss Plaintiff/Petitioner's Petition for lack of proper jmisdiction and venue. Respectfully submitted, Date c~Aq~o?n'gy fi~ant/Respondent ~~~5~)$fI~, Esquire GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I veri~ that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom falsifications to authorities. ,~TEP~ANIEVLYNN CORNWALL GEORGE M. CORNWALL, III, Plaintiff/Petitioner VS. STEPHANIE LYNN CORNWALL, Defendant/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 04-3379 CIVIL ACTION - LAW : : IN CUSTODY CERTIFICATE OF SERVICE I, Bradley L. Griffie, Esquire, hereby certify that I did, the _5"' ]'q day of August, 2004, cause a copy of DefendanffRespondent's Preliminary Objections to be served upon Plaintiff/Petitioner by first class mail, postage prepaid at the following addresses: George M. Cornwall, III 1897 Boca Ratan Drive Lake Oswego, OR 97034 ~~aSnq~!iRiipondent 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 5832286222 L~ OFFICES PAGE 32/52 ! 2 4 $ 6 7 8 9 l0 Ii 14 15 17 18 19 24 25 26 IN THE CIRCUIT COURT OF THE STATE OF OREGON FOP, THE COUNTY OF CLACI~.MAS I~l the Matt~ o£ GEORGE MACI~E CORN~AiJ.,, III., Petitioner, and STEPHANFE LYNN CORNWALL, R-~pondcnt Case lqo, DK03-03721 MOTION AND ORDER RE: LIMITED JUDGMENT FOR PENI)ENTE LITE This matter came before judge Eve Miller in ~e Clackamas Coumy Co~t, on Decembex 8, 2003, upon the agreement o f the paxdes. The Motion of Show Cause'subsxUtted by Kespond~nt's attorney wa~ se~e.d and purees phced their ageeement on the ~ecord. Petition=, ~ppe~aUg bi' and thxo~gh his auomey, Shannon Co:mall, Nd Responde. ut, appea~'ing by ~ud rl~ough her attorney, L~v/j. Blake, Jr., and the Court being fully advia~d ia the peemises after revie,~emg the files: IT I$ HEREBY ORDER g.r~, ADJUDGED AND DECREED that: 1. CUSTODY/PAREN'I3NG TIM'F,, Mother sEall ha,re sole legal and physical custody of George M. Cornwall, IV., bom November ii, 1998. ]?axeating time shall be as fol]o~,i a. Fathe~ shall only have supez~dsed ~cnung plan ~ith super~sor to be dete~xnlnmd by aSreeme~t of plucties or by fut'~ex o~'der of this I ~ MOTION AND OR2DRR P,.~: LIMITED JUDGMENT FOR PEIqDENTE I2[TE (~) 2~-a~ .0610~/2004 11:56 503228G222 LAW OFFICES P~GE: 33/52 1 2 3 4 5 6 7 8 9 lO 11 12 13 15 16 17 18 19 20 21 23 24 25 26 b. If Father t~ave~ to Pennsylvania for patea~tmg t/me with mmox child, Father shall bear the expense* of lxavei and expenses associated with the rupe~rised parenting nme. ioatentmg nme in Pennsylvania with father is most likely to be at the YWCA located in Carlisle, Penmylvania. c. If Path= requests to have parenting tmae in Portland, Oregon, Father will bear the expenses £or Respondent and minor child m ua, tel md stay in portland, Oregon for the dut~tinn of the parenting time. Father will dso bear the cost o£ supervisinn fox pareaatmg time and coats associated with Mother {or missing tun~ from worlc i. Mother will only be required to Ixavel to Portland, Oregon fox patenting time if the time is available fox her to travel and she agrees to travel with the zmao: child to Portland, Oregon. il. Mother agree* to allow £athel' to have telephone contact with the partie~' rnin_Or ' child prior to child going to bed each evening. Mothea will initiate the phone call between rmnot child and Fathelr vath the phone call l~ting a maximum of fifteen minutes. Fath~ shall have no telephone contact with Mother other than the telephone contact Mother initiate* between Father and m/nor child. .C, HILD_I,U.P_P_q~. Father agree* to pay child support in the amotmt of [900.00 pet month tO Mother beginning December 15~ 2003, arad everT mnnth therea/tar on the 15t~ of the month ulltil further order of this Court. a. Father agrees to pay arrears o£child support owed to Mother in the total amourlt of $900.00 by December 8, 2005. DEBTS. Father Saree* to pay all current paymer/ts for the family residence, including payments which would also include insurance costs, ratxe*, a~d homeowner fees. tl Iti III 2 - MOTION AND ORDER IlLB: LIiVQ-i'ED JUDG},ffiNT FOR PENDENTB LFI'~ ;08/03/2~04 1 ? 8 .I0 11 13 14 15 16 17 19 2O 21 23 Pase 11:55 503228~222 L~ OFFICES 34/52 MEDTCAI..E.~0~S~g Fathe~ agxe~ to continue the medic~] insurance premium for the benefit o£ Mother and mmo£ child, and agrees to p.'ty one-half of the minol child's u~insuxed medical, dental, optical and ~xthodontic bgls thit ma}, be incuxred. ~, The issue of attorneys' fees ~]:~11 be defer, ted until Final detel'mmation of tkis matter, ,~a~~. The Ex parte Motio0 flied by Petitioner and signed by Judge Tom on M~rch 27, 2003 rem~im in full foxce during the p~dency of this matter. MONEY AWARD Cxeditor: Cx dito~ s Address: Caeditox's Attome,/: Attomefs Address: Debtor; Debtox's Address; Debtor's Attomeg: Attom~ Address: Money Awitrd: At, omen's Fees: Beg:inning Date: Ending Date: Ptelud~ment Intexest: A~m~e Fe~ ~d Cos~; Post Ju~t Int~est: Steph~ni~ Cornwall 4236 Carlisle ]~.oad 'Gaxdners, PA 17324 Larry j. Blake, Jr. 371'8 SW Condo~, Suite IlO Pottl~d, OR 97239 George Cornwall 1897 Boc~ Rat0n Drive Like Oswego, OR 97034 Shannon Comkall 621 SW Morm~on, Suite 140 Poland, OR 97205 $900,00 per m~mth fo! ch/ld suppor[ To be detezmizxed at later chte. Deceraber 8, 21303 9% pet .nnurn upon enta:y of judgment DATED this _~_chy of ,2oo . Miller 3 - MOTION AND ORD~ RE; LIMI~ J UD GIV~.,IqT PO~, PI~NDENtrE I27TI5 88/83/2884 11:5~ 503228~222 LAW OFFICES P~GE 35/52 10 H 12 2 4 Geo,:ge Mackie Cornwall, III,, Petitioner- /~otary Public of Oregon My Commission Expires;_. Submitted by: 14 LartyJ. Bhke, Jt., OSB#87172 Attorney for Respondent 15 16 17 18 20 21 22' 23 24 25 St"ephanie Lyan Cornwall, l[espondent Notary Public of Oregon My Cot~aJssion Exp~,'%: Stipulaxed and Agreed to by: Shannon ConnaB, OSB#97538 Attorney fo~t Pelitioner 4 - ,MOTION AND OKDER RE: L,IIvIII"ED JUDGMENT FOR. PEND.FSqTE GEORGE M. CORNWALL, III, Plaintiff/Petitioner VS. STEPHANIE LYNN CORNWALL, Defendant/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-3379 CIVIL ACTION - LAW : IN CUSTODY PETITION FOR SPECIAL RELIEF AND NOW, comes Respondent, Stephanie Lynn Cornwall, by and through her counsel, Bradley L. Griffie, Esquire, and petitions the Court as follows:: 1. Your Defendant/Respondent herein is an adult individual currently residing at 4236 Carlisle Road, Gardners, Cumberland County, Pennsylvania. 2. Your Plaintiff/Petitioner herein is George M. Cornwall, III, an adult individual currently residing at 1897 Boca Ratan Drive, Lake Oswego, Clackamas County, Oregon. 3. The parties are the natural parents of one (1) child, namely, George Mackie Cornwall, IV, born November 11, 1998. 4. The parties are in the midst of litigation in the Circuit Court for the State of Oregon in the County of Clackamas, which litigation involves divorce, support, and custody relative to the parties' child, including a hearing scheduled for 9:00 a.m. on September 21, 2004 on all matters. 5. Knowing these proceedings are not only pending but are in active litigation with hearings and arguments scheduled, Plaintiff/Petitioner filed a Petition for Special Relief regarding visitation in the Court of Common Pleas of Cumberland County, Pennsylvania, a copy of said Petition being attached hereto and incorporated herein by reference as Exhibit "A." 10. 11. A faxed copy of the initial Order entered by the Circuit Court of the State of Oregon for the County of Clackamas relative to custody of the parties' child is attached hereto and incorporated herein by reference as Ey:hibit "B," identifying the fact that the Circuit Court of the State of Oregon for the County of Clackamas has continuing jurisdiction over the issue of custody of the parties' child. Various Motions have been filed by Plaintiff/Petitioner, which have caused arguments and hearings to be scheduled in Clackamas County, Oregon, which are all known to Plaintiff/Petitioner and which were pending at the time of his filing of a Petition for Special Relief regarding custody in. the Court of Common Pleas of Cumberland County, Pennsylvania. Due to Plaintiff/Petitioner's filing of his Petition, it was necessary for Defendant/Respondent to secure legal counsel and file appropriate Objections to the proceedings initiated by Plaintiff/Petitioner in the Court of Common Pleas of Cumberland County, Pennsylvania. PlaintifffPetitioner's conduct is obdurate, vexatious, and dilatory, and done solely in an effort to create additional conflict and cost for i-)efendant/Respondent. There is no basis for Plaintiff/Petitioner initiating proceedings in the Court of Common Pleas of Cumberland County while the custody matters are pending in the State of Oregon. Plaintiff/Petitioner was previously incarcerated in the State of Oregon due to his harassment of Defendant/Respondent's daughter to a prior marriage, which harassment was of a sexual nature and resulted in ,,;uch incarceration. Petitioner was recently incarcerated for his willful violation of his probation from the aforementioned criminal charges. Defendant/Respondent does not have the financial ability to pay her counsel and Plaintiff/Petitioner is, at this time, in substantial arrears relative to his child support Order in the State of Oregon. Due to Plaintiff/Petitioner's conduct, Defendant~espondent is entitled to attorney's fees from Plaintiff/Petitioner relative to all actions; taken by her counsel in the Court of Common Pleas of Cumberland County, Pennsylvania to address Plaintiff/Petitioner's Petition. Preliminary Objections to these proceeding have been filed, a copy of said Preliminary Objections being attached hereto and !incorporated herein by reference as 12. 13. 14. 15. Date Exhibit "C." Respectfully submitted, G]~FFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom falsifications to authorities. SI, t~PI~ANIE L'~'NN CORNWALL GEORGE M. CORNWALL, III, Plaintiff/Petitioner VS. STEPHANIE LYNN CORNWALL, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3379 CIVIL ACTION - LAW 1N CUSTODY CERTIFICATE OF SERVICE I, Bradley L. Griffie, Esquire, hereby certify that I (lid, the ~r~7'7/' day of August, 2004, cause a copy of Defendant/Respondent's Petition for Special Relief to be served upon Plaintiff/Petitioner by first class mail, postage prepaid at the following addresses: George M. Cornwall, III 1897 Boca Ratan Drive Lake Oswego, OR 97034 ~Fi E~, Esquire br DefJndant/Respondent & ASSOCIATES 200 Nortl~ Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 GEORGE M. CORNWALL, III PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-3379 CIVIL ACTION LAW STEPHANIE LYNN CORNWALL DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, July 22, 2004 . upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechaniesburg, PA 17055 on Tuesday, August 24, 2004 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an efforL 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 corn:t, and to enter into a temporary order. All childa'en age five or older may also be present at the conference. Failure to appear at the conference may provide grouuds for entry of a temporary or permanent order. The court hereby directs the parties to furnish an3' 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: Is/ Dawn S. Sunday. Esq. Custody Conciliator mhc The Cou~t of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information abont 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 hear/rig 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 I-~',LP. Cmnberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania Telephone (717) 249-3166 TPdJE COPY-,,.~ r,.,",_:, ..~,~ P. ECORD in Testimony whereof, [ here unto set rny hand and the seal of said Court at CarJisJe, Pa. This .....~ ..... clay of~ ........ , Prothonotary ] 2 3 4 ]'N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW 5 6 7 In the matter of the marriage of ~ George M. Cornwall, III, 9 Petitioner, Pro Se 10 ] I and 13 14 15 ]6 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Stephanie Lynn Cornwall, Respondent Pt I 11 tON FOR SPECIAL REL-~F REGARDING VIS~A~ON ~'' PETITION FOR SPECIAL RELIEF RIEGARDI'NG VISITATION AND NOW, this 9m day of .luly 2004, comes the Petitioner, Pro Se, to petition this Honorable Court to enter an order with respect to visitation and in support thereof, and avers as follows: 1. The parties have one minor child, George Mackie Cornwall ~V, DOB November 11, 1998. 2. Petitioner is the father of the child and resides at 1897 8oca Ratan Drive, Lake Oswego, (Clackamas County), OR 97034, (503) 784-3888. The Respondent resides at 4236 Carlisle Road, Gardners, (Cumberland County), and PA 17324, (717) 486-3634. This house was purchased using non-marital assets provided by the Petitioner for the down payment and closing costs. Currently a petition for legal separation of the parties is pending in the Circuit Court of the State of Oregon for the County of Clackamas. The Respondent has additionally petitioned the court to convert the case to a dissolution proceeding. On December 8m, 2003 that court issued a Pendente LitE; order providing for visitaMon of the minor son by the Petitioner. A certified copy of this order is provided and attached herewith. The Clerk of that court suggested the use a certified copy of the Oregon order with this Honorable Court. This certified copy of the Oregon Court's order was provided to me for that express purpose. Since 3anuary 24t~, 2004 respondent has routinely contrived to prevent the ordered visitations by various means, including removing the minor son from Nursery School, removing him from the home. There has also been an ongoing general refusal to 07/12/04 1 of 2 Petition for Special Relief 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 o communicate about a vadety of topics, including the visitation schedule, or do anything else that might in any way facilitate any visitation. Respondent has by various means, including fleeing from the State of Oregon, prevented any meaningful contact between Petitioner and the Minor Child since December 5, 2002. 10. Petitioner believes that respondent recently even went so far as to place the child, for days at a time, in the homes of relatives up to 50 miles; distant from the Gardners, PA residence. This apparently has been done for most of the last week. According to the Child, He was told that these actions were required so that he could be adequately protected from Petitioner. All of these actions have been for the express purpose of thwarting Petitioner's attempts to exercise even one visit as provided b.y the aforementioned order. Certainly, these actions do NOT serve the best interests of the Minor child. The best interests of the child would be served by provide frequent and relaxed contact in an atmosphere of adult cooperation and communication. Fear mongering only serves to frighten the child, further straining an already damaged relationship. Cimuit court action is pending in Oregon to significanUy amend and ameliorate the visitation rights allowed the Petitioner under the afl~rementioned order, however petitioner has now made a total of five (5) transcontinental tdps, without ever being permitted contact. Though two of the trips were made while petitioner lacked permission to travel outside Oregon, Petitioner has new_~r attempted to schedule visits of a type or duration that were over and above those permitted at the time by the Oregon Courts. Wherefore Petitioner prays your Honorable Court to enter an order directing the Respondent to comply with the visitation provisions of this order without further delay or artifice. Further, that Respondent be admonished that continued interference with the existing and future court orders arising from these matters, will serve to subject her to possible sanctions for contempt of the Orders of This Court. George ~1. Cor-n~vhll ~I, Petitioner Copies by mail to: Larry Blake, .Ir. 3718 SW Condor #110 Portland, OR 97239 Stephanie L. Cornwall 4236 Carlisle Road Gardners, PA. 17324 07/12/04 2 of 2 Petition for Special Relief 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 IN THE COURT OF COMMON PLEAS OF CUMI~,ERLAND COUNTY, PA CIVIL ACTION - LAW In the matter of the mardage of George M. Cornwall, III, Petitioner, ~o ~ and Stephanie Lynn Cornwall, Respondent '-[ NOTICE AND ORDER TO APPEAR P~z I~ON FOR CONTEMPT NO'I'ZCE AND ORDER TO APPEAR Pt: J ~. I .~ON FOR CONTEMPT Legal proceedings have been brought against you allegincl you have willfully disobeyed an Order of the Circuit Court of the State of Oregon for the County of Clackamas Court for visitation. ~ 6.53 1. Kozlowski v. Koziowski, 362 Pa. Super, 516, 524 A.2d 995 (1987) 2. Pa.R.C.P. No. 19:LS::t2(b) 3. Pa.R.C.P. No. 19~tS.:L2 If you wish to defend against the claim set forth in the l:ollowing pages, you may but you are not required to file in writing with the court your defenses or objections. Whether or not you file in writing with the Court your defenses or objections, you must appear in Person in Court on ,, 2004, in Court Room before the Honorable COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CARLISLE COURT HOUSE I Court House Square Carlisle, Pennsylvania 07/12/04 i of 2 Notice and Order to Appear 49 5O 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 87 IF YOU DO NOT APPEAR IN PERSON, THE COURT MAY ISSUE A WARRANT FOR YOUR ARREST. If The Court finds that you have willfully failed to comply with its order in support of the Oregon Order for visitation, you may be found in contempt of Court and committed to jail, fined, or both. YOU SHOULD TAKE THZS PAPER 'TO YOUR LAWYER AT ONCE, 1'F YOU DO NOT HAVE A LAWYER OR C~.NNOT AFFORD ONE, GO TO OR TELEPHONE THE OFF'ZCE SET FORTH BELOW TO FZND OUT WHERE YOU CAN GET LEGAL HELP. (NAME) (Telephone Number) By the Court: Date: George M. Comwall III, Petitioner 1897 Boca Ratan Drive Lake Oswego, OR 97034 (503) 784-3888 Copies by mall to: Larry Blake, Jr. 3718 SW Condor #110 Portland, OR 97239 Stephanie L. Comwall 4236 Cadisle Road Gardners, PA. 17324 07/12/04 2 of 2 Notice and Order to Appear 0~/03/2084 11:56 5032286222 LAW OFFICES P~GE 32/52 2 4 6 8 9 10 t2 17 19 20 21 22 24 25 26 IN THE CIKCUIT COURT OF THE STATE OF OKEGON FOR THE COUNTY OF CLACICA_MAS Case IX!o, DK03-03721 MOTION AND ORDER RE: LIMITED JUDGMENT FOR PEI~,DENTE LITE Thi~ m~u~r c~ane before Judge Eve IMiIle. r in the Clacka~a~s Coul2ty Cou~t~ on Dece~ 8, 2003, upon ~e ~eement of &e p~rfle~. ~e Motion of Sho~ C~use' sub:~d by K~pondqnt's sc~ed ~d p~ phced &~ a~e~t on &e teco~d. Ped6on~, ~ppe~g by a~ t~o~h ~s ~om~, Shannon Cotm~, md Respond~t, appe~mg by ~d duou~ h~ a~Xom~, L~ ]. Bhke, J:., ~nd ~e Co~ ~ I5 HE.BY O~ER RD, ADJUDGED AND DECkeD 1. CUSTODY/PA~G ~, Mo~c~ s~ h~,ve sole le~ and physg~ ~to~ of Geor~ M, Comw~ ~., bom Novemb~ 1t, 1998. P~en~g ~e ~ha~ be as fo~s: · , F,~ ~h~ o~y hava supez~d p~cn~g plan wi~ sup~sor to be dete~ by ;gre~t of p~aes or by fm~ o~d~ of 1 - MOTION AND ORDER R.~: LIMI'.~D JUDGMENT FOK P!glqDP,,N'rE LrrE 08103/2084 11:56 5832286222 LAW OFFICES P~C~ 33/52 I 2 3 4 5 ? 8 10 II 12 13 14 15 16 17 18 20 21 23 24 25 26 page b. If Father travels to Pennsylvania £or patantmg time with minor child, Father shall beax the expenses of travel and expenses associated with the supervised pa,:eating time. iOarentmg ~ in Pennsylvania with £athe~ is most likely to be at the YWCA, located iii Carl/si% Permaylva~tla. c. If Fath,'* requests m have patenting Ume in Poillmd, Oregon, ]Father will bear the expenses for Respondent -~-d minor child m l~avd and stay in portland, Oregon ~or the duration of the parenting time. Father will also be~ the cost o£ supervision for pium. ntmg Ume and cost~ associated with Mother for m~ssirg me from work i. Mother ,a, ill only be required to travel to Portland, Oregon for p~entmg time if the rime'is availible fox her to travel and. she agrees to trawl with thc minor child to Portland, Oregon. ii. Mother agrees to allow £ath~ to have tel4;phone contact with the parties' m4~or ' child prior to child going to bed each evening. Moth= will initiate the phone call bemree~ minor child and Father with the phone call l~ting a maximum of fifteen minutes. Fathe. t shall have no telephone contact with Mother other than the telephone contact Mother iriitiate~ between Father and lnlnor child. ~. Father ihgreet to pay child supl>oa in r. he amount of [900.00 per month to Mother begmmng December 15, 2003, and every month tllere~ti: oi1 ~ 15~ of the l'aolith until fmthe: order of this Cou~t, a. Flther agrees 'to pay a=c~t8 of child support owed to Mother ffi the total amount of $900,00 by December 8, 200t. DEBTS, Fathe~ Sgrees to pay ail cmrent payments f~r the family residence, including payments which would also include irismcance costs, taxes, a.qd homeowner fees. / III III 2 - MOTION AND ORDER RIB: LIiVa i ~O JUDGMENT FOR PENI)ENTR LI'EE 08/03/2004 11:56 5032206222 LAW OFFICES PAGE 34/52 1 4 6 ? 10 11 13 14 15 16 17 '18 19 20 21 22 23 24 25 26 Page ~,l~:~l~.~. F~t~er l~ees to continue the medics], insurance premium fo~ the benefit of Mother and rmnor child, and a~ees to ply one-half of the mmo~ child's tmins~.~:ed medicll, dent~l, optical and O~thodontic bi.Ils that ms}, be incurred. ~. The issue of~tttomeTs' fees ~hal[ be de£etted ~mtil flxta] detel~maation of this matter. ~. The Ex paxte Motion filed by Petitioner aM s~ned by Judge Tom on M~mh 27, 2003 rem~im m ~ force during the pendency of this matter. MONEY AWARD C~ec[itor: Caeditot's Address: C.~editor's Attorney: Attorney's Address; Debt. ox; Debtor's Address; Debtor's Attorney: Attorney% Ad~kess: Molley Award: AttomeT's Fees: Scanning D.te: E~di~g Pxqu~ent A~om~% Fees Post Jud~t Stephame Cornwall 4236 Carl/fie Road 'Gutctners, PA 17324 LmTJ. Blake, Jr. 3718 SW Condoz, State 110 Foztland, OR 97239 G~orge Cornwall 1897 Boc~ EatOn D~4ve Lake Oswego, OR 97034 Shannon Corm~ 621 SW Momaon, Sui~ 140 Poffiand, OR 97205 $900,00 per month for child support. To be detem~ned at later d~te. ,) December 8, ,.003 9%p~,=numuponmtxyofjudgment DATED dais ~day of 200 . Judge Eve Mi]er 3 - MoTroN AND OR.DER 1~; LI MI'i"F..D JUDGMENT POE PENDENTS 0818312004 11:56 5832286222 LAW OFFICES PAGE 35/52 C-eorge Mackie Comwe.]l, III, Pctkio~ I0 l 1 Submitted by: 12 lqo~z7 Pubhc of Oregon My Cm~m~ion Expires;. l,~ IatryJ. Bkke, Jr., 05B#87172 Attorney for Respondent 16 17 15 19 20 21 22' 23 24 25 26 St~ph~me Lynn Cornwall, Respondent NotatT Public of Oregon My Commission Expires Stipulated and Agreed to by: Shannon Conaall, OSB#97538 ' Attorney for Petitioner 4 - MOTION AND ORDER RE: LIM/TED JUDGlvffiNT FOR PENDENTE LITR GEORGE M. CORNWALL, Plaintiff/Petitioner VS. STEPHANIE LYNN CORNWALL, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3379 CIVIL ACTION - LAW IN CUSTODY NOTICE TO PLEAD You are hereby notified to file a written response to the within New Matter within twenty days (20) days from service hereof or a judgment may be entered against you. GEORGE M. CORNWALL, III, Plaintiff/Petitioner VS. STEPHANIE LYNN CORNWALL, Defendant/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-3379 CI[VIL ACTION - LAW : iN CUSTODY PRELIMINARY OBJECTIONS TO JURISDICTION AND VENUE AND NOW, comes Defendant/Respondent, Stephanie Lynn Cornwall, by and through her counsel, Bradley L. Griffie, Esquire, and files the following Preliminary Objections: Defendant/Respondent is an adult individual currently residing at 4236 Carlisle Road, Gardners, Cumberland County, Pennsylvania. Plaintiff/Petititoner is George M. Cornwall, III, an adult individual whose last known address is 1897 Boca Ratan Drive, Lake Oswego, Clackamas County, Oregon. The parties are the natural parents of one (1) child, namely, George Mackie Cornwall IV, born November 11, 1998. The parties' marital residence, the place of the: child's birth, and the primary residence of the child since his birth exists in the County of Clackamas in the State of Oregon. The parties are engaged in divome litigation, as well as custody litigation, in the Circuit Court of the State of Oregon for Clackama~ County, which Court has entered various Orders relative to the parties' legal matters, including a Order scheduling a hearing for 9:00 a.m. on September 21, 2004. Attached hereto and incorporated herein by reference as Exhibit "A" is a faxed copy of the Order of Court from the Circuit Court of the.. State of Oregon for the County of 10. 11. 12. Clackamas setting forth the terms of custody relatiw~' to the child at issue herein, said Order being entered by agreement of the parties on December 8, 2003; a true and attested copy of the Order is being forwarded to the: undersigned from Respondent's counsel in the State of Oregon. There is pending, before the Circuit Court of the Si:ate of Oregon for the County of Clackamas, a Petition and Motion filed by Petitioner herein requesting unsupervised visitation time, and other modifications to that Court's prior Order. Petitioner has filed a Motion requesting a custody evaluation through the Circuit Court in the State of Oregon for the County of Clackamas, which Motion is pending at present. Petitioner not only has a Petition pending for unsupervised contact with the parties' child, but also has other Motions pending to which Respondent has filed an appropriate response within the last month and which will cause further proceedings before the Circuit Court of the State of Oregon for the County of Clackamas. Petitioner's Petition for Special Relief filed with this Court regarding visitation references in paragraph 5 the entry of an Order following agreement of the parties made in open Court on December 8, 2003, relative to custody of the child at issue in these proceedings. In paragraph 10 of Petitioner's Petition, he identifies the fact that "Circuit Court action is pending in Oregon to significantly amend and ameliorate the visitation rights allowed the Petitioner under the aforementioned Order..." Petitioner's Petition, on its face, lacks appropriate venue and jurisdiction and illustrates an attempt on the part of Petitioner to forum shop to in some manner supersede the jurisdiction of the Circuit Court of the State of Oregon for the County of Clackamas, which has assumed and retained jurisdiction over the issue of custody in this case, with custody matters presently pending. WHEREFORE, Respondent requests your Honorable Court to dismiss Plaintiff/Petitioner's Petition for lack of proper jurisdiction and venue. Respectfully submitted, Date ~~'~Pf4~C.Defe~nquit/;Londent GRIFFIE & ASSOCIATES 200 North ttanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom falsifications to authorities. /STt~P~ANIE~LYI'FN CORNWALL GEORGE M. CORNWALL, III, Plaintiff/Petitioner VS. STEPHANIE LYNN CORNWALL, Defendant/Respondent : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND, COUNTY, PENNSYLVANIA : NO. 04-3379 CIVIL ACTION - LAW : IN CUSTODY CERTIFICATE OF SERVICE I, Bradley L. Griffie, Esquire, hereby certify that I did, the day of August, 2004, cause a copy of Defendant/Respondent's Preliminary Objections to be served upon Plaintiff/Petitioner by first class mail, postage prepaid at the following addresses: George M. Comwall, III 1897 Boca Ratan Drive Lake Oswego, OR 97034 DATE: 200 North Hanover Street Carlisle, P.A 17013 (717)243-5551 (800)347-5552 .08/03/2884 11:56 5832286222 LAW OFFICES PAGE 32/52 10 11 13 I7 19 IN THE CIILCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF CLACKAMAS In the M~ttec of ) ) GEORGE MACKIB COKNTWALL, III., ) ) Petition~, ) ) ) ) STEPHANIE LYNN COF, aXr~ALL, ) ) Case No. DK03-0372i MOTION AMD OILDF_,R RE: LIMITED JUDGMENT FOR PENDENTE LITE This matter cant be£o:e Judge Eve MJlle~ in the Clack~mas Coumy Co',ztt, on Decembez B, 2003, upon t~c agreement of t~a pa~de~. The Motion of Sho~ Cause'submitted by Kespondsnt's atto;mey wat scttlecl and paafie~ phced their al~zeement on tt~ record. Petitionez, ~ppear-mg by and through ~f attorney, Shannon Cormall, sad R~spondent, appearing by and through he: attorney, Lab-y J. Blake, J~., md the Cou~t being f~lly ad, reed in the pr,miscs a~te~ z~iearmg ~e ~es: IT IS HE'BY O~E~, ADJ~GED ~D DBC~D ~at: 1. CUSTODY/PARg~G ~. Mo~:~ shaR have :ale leg~ and phyai~ ~to~ of Ocor~ M. Coxnw~ ~., bom Novemb~ II, 1998. P~m~g ~e sha~ be ~s fo~ows~ a. Fa~ ~h~ o~y hava supei~ed ~en~g plan wi~ sup~sox to be ~te~ed by agre~t of p~ues ox by/m~er ord~ of ~ co~, 1 - MOTION AND OI~DBR ILl!: LI M-~TED JUDOlv~2qT FOP. PBIqD~-NTE :LITE OB/Bg/2D04 ~:5B 503228~222 b/~ OFF~C~ P~GE 33/52 $ 6 7 8 9 10 11 12 13 15 16 17 18 19 20 21 '22 24 23 26 Page b. If Father travels to pennsylvania for parenting tfme with minor child, Father shall bear the expense~ of txavd and expenses associated with the mpervised parenting tm'Ac, Parenting time m Pennsylvania w-ith father is most likely to be at the YWCA located m Carlisle, Pennsylvania. c. If Fat_hex requests to have pa:enema me in Portbmd, Oregon, Father will bear the expenses £or l'Les'pondent and minor child to t:avet and stay in ~urtland, Oregon £ox the duration of the parenting tlme. Father will .also be~ the cost of supervision fo~ pareaatmg nme and costa associated with Mother for tossing ume f~om wo£k i. Mother will only be required to t~avel to. Portland, Oregon £m parenting tirae if the el-me is available £m: her to travel and she agreer to travel with file minor child to Pos~lan& Oregon. ii, Mother agrees to allow £athex to have tele?hot~e coat, ct with the partie~' minor child prior to child going to bcd each evening. Mother ~ initiate the phone call between minor child and Father wxth [.he ,.phone caJl lasting a maximum of fifteen laxinutes, Father shill have no telephone contact with Mother other than the telephone contact Mother initiates between Father and minor child. ~. F~thet ag, xees to pay ch/Id support in the amount of tg00.00 per month tq Moth~ beginning December 15, 2003, and eveJ.5 month thereafter on the 15~ of the month until further order of this Court. a. Father agrees 'to pay arreax~ of child support owed to Mother in the total amonnt of $900.00 by December 8, 2005. DEBTS, Father ~g~'ees to pay all casrent paymentu fi)r the family resideace, inchiding payments which would also include insurance costs, ~axes, and homeowner fees. f/t /// II1 2 - ~fOTION AND ORDER I~: LIMA x'lzD JUDGM~'YI' FOIl. PBIqD'CblTE Lr~ ~8/03t2004 5032286222 LAW OFF]GES PAGE 34/52 2 4 $ 6 7 g .10 11 14 17 18 21 Page 4. ~. F~thcz a~:e~ to co=tloue the medical in~uxar~ce premlm~ fo: the benefit of Mothex and mmot child, and agrees to pay one-half of the mmo! child's un~suxcd medical, dental, optical and 0xllhodontic bills that may be incuxxed. 5. A_~. The issue of attorneys' fees ~hall be de£erted until final detex~"mation of thi~ m~tter. 6, ~f~. The Ex pane Motlor~ flied by Petkionex and stgned by Judge Tom on Much 27, 2003 x. emams m full foxce during the peadlmcy of this ~xatttet. MONEY AWARD Creditor: Cx~ditor's Ad&es~: Cxcditox's A. ttorncy: .Attorney's Address: Debto:; Dehtox's Adtkess; Debtor's Attorney: Attorney's Aald~ess: Money Award: Attomcy'~ Beginning Data: Ending Date: p~ejudgment Int=~t Attorney% Fees and Post Judgmmt Ste?hame Cornwall 4236 Carlisle ll~oad · Gar~iners, PA 17324 Lmy J. Blake, Jr. 3718 sw Comtox, State Po~.'tland, OK 97239 George Core.rail 1897 Boca II. at0n Drive Lake Oswego, OE. 97034 621 SW Mom~on, Suit: 140 Po~,land, OR 97205 8900.00 pe~ month fo~ child support. To be detertmned at later d~te. 9 December 8, ,~003 9% par ~nnnm upon entry of judgment DATED this ~day of , Judge Eve M~ller 3 - MOTION AND OR.DEE ILE: LIMA 1 ~u JUDGMENT FOP, P~NDENTE. LITI~ 503228G222 LAW OFFI OES PAGE 35/52 2 3 4 5 Geoz~e Meckie Cornwall, rJ[I, Petitioner 14 16 17 18 19 20 21 22 23 :24 25 26 I.~z? J. BlUe, Jz., 0SB#871'/2 Attorney for Respondent S'rePh~de Lynn Cornwall, Respondent Not~.T Public of Oregon My Commissiou Expi:es: Stipulated and Ag~ed to by: ' Shannon Connall, OSB#97538 ' Attorney fo~ Pel:kioner MOTION AND OP. DER RE: LIM/TP_.D JUDGIvI~NT FOR PENDF24TE LITE GEORGE M. CORNWALL, III, Plaintiff/Petitioner VS. STEPHANIE LYNN CORNWALL, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3379 CIVIL ACTION - LAW IN CUSTODY PETITION FOR SPECIAL RELIEF AND NOW, comes Respondent, Stephanie Lynn Cornwall, by and through her counsel, Bradley L. Griffie, Esquire, and petitions the Court as follows: 1. Your Defendant/Respondent herein is an adult individual currently residing at 4236 Carlisle Road, Gardners, Cumberland County, Pennsylvania. 2. Your Plaintiff/Petitioner herein is George M. Cornwall, III, an adult individual currently residing at 1897 Boca Ratan Drive, Lake Oswego, Clackamas County, Oregon. 3. The parties are the natural parents of one (1) child, namely, George Mackie Cornwall, IV, bom November 11, 1998. 4. The parties are in the midst of litigation in the Circuit Court for the State of Oregon in the County of Clackamas, which litigation involves divome, support, and custody relative to the parties' child, including a hearing scheduled for 9:00 a.m. on September 21, 2004 on all matters. 5. Knowing these proceedings are not only pending but are in active litigation with hearings and arguments scheduled, Plaintiff/Petitioner filed a Petition for Special Relief regarding visitation in the Court of Common Pleas of Cumberland County, Pennsylvania, a copy of said Petition being attached hereto and incorporated herein by reference as Exhibit "A." 10. 11. A faxed copy of the initial Order entered by the Cimuit Court of the State of Oregon for the County of Clackamas relative to custody of the parties' child is attached hereto and incorporated herein by reference as Exhibit "B," identifying the fact that the Circuit Court of the State of Oregon for the County of Clackamas has continuing jurisdiction over the issue of custody of the parties' child. Various Motions have been filed by Plaintiff)Petitioner, which have caused arguments and hearings to be scheduled in Clackamas County, Oregon, which are all known to Plaintiff/Petitioner and which were pending at the time of his filing of a Petition for Special Relief regarding custody in the Court of Common Pleas of Cumberland County, Pennsylvania. Due to Plaintiff/Petitioner's filing of his Petition, it was necessary for Defendant/Respondent to secure legal counsel and file appropriate Objections to the proceedings initiated by Plaintiff/Petitioner in the Court of Common Pleas of Cumberland County, Pennsylvania. Plaintiff/Petitioner's conduct is obdurate, vexatious, and dilatory, and done solely in an effort to create additional conflict and cost for Defendant/Respondent. There is no basis for Plaintiff/Petitioner initiating proceedings in the Court of Common Pleas of Cumberland County while the custody matters are pending in the State of Oregon. Plaintiff/Petitioner was previously incarcerated in the State of Oregon due to his harassment of Defendant/Respondent's daughter to a prior marriage, which harassment was of a sexual nature and resulted in such incarceration. 12. Petitioner was recently incarcerated for his willful violation of his probation from the aforementioned criminal charges. 13. Defendant/Respondent does not have the financial ability to pay her counsel and Plaintiff/Petitioner is, at this time, in substantial an'ears relative to his child support Order in the State of Oregon. 14. Due to Plaintiff/Petitioner's conduct, Defendant/Respondent is entitled to attorney's fees from Plaintiff/Petitioner relative to all actions taken by her counsel in the Court of Common Pleas of Cumberland County, Pennsylvania to address Plaintiff/Petitioner's Petition. 15. Preliminary Objections to these proceeding ha,ge been filed, a copy of said Preliminary Objections being attached hereto and incorporated herein by reference as Exhibit "C." Date Respectfully submitted, squire ~.~'~ttorney for DOfendant/Petitioner GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing da,cument are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom falsifications to authorities. ST/fiPHANIE L~FNN CORNWALL GEORGE M. CORNWALL, III, Plaintiff/Petitioner : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. STEPHANIE LYNN CORNWALL, Defendant/Respondent IN CUSTODY CERTIFICATE OF SERVICE NO. 04-3379 CIVIL ACTION - LAW I, Bradley L. Griffie, Esquire, hereby certify that I did, the day of August, 2004, cause a copy of Defendant/Respondent's Petition for Special Relief to be served upon Plaintiff/Petitioner by first class mail, postage prepaid at the following addresses: George M. Cornwall, III 1897 Boca Ratan Drive Lake Oswego, OR 97034 ~i~f~, Esquire ~r Defedndant/Respondent ~ ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 GEORGE M. CORNWALL, III PLAINTIFF V. STEPHANIE LYNN CORNWALL DEFENDANT iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-3379 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, July 22, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, August 24, 2004 at 8:30 AM for a Pre-Hea~mg 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 cpm't, and to enter into a temporary order. All children are five o1' older may also be present at the conference. 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 an3' and all existing ?rotection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /si Dawn S. Sunday, Esq. Custody Conciliator mhc 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 I-LAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHEIkE YOU CAN GET LEGAL HELP. Cumberland County Bar Association EXHIBIT 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 TrdJE COPY FP;. ,A F. SCORD In Testimony whereof, I here untO set my hand and ihe seal of said Court at Carlisle, Pa. of ......... ......... . ................... ~ Prothonota~ TN THE COURT OF COMMON PLEAS OF CUMBE:RLAND COUNTY, PA CIVIL ACIION - LAW S 9 10 I1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 In the matter of the marriage of George M. Cornwall, III, Petitioner, .~ro ~ and Stephanie Lynn Cornwall, Respondent PETITION FOR SPECIAL REGARDING VIS~A~ON PE'ITI~ON FOR SPECIAL RELZEF RE~r-ARDTNG VI'SrrA'rZON AND NOW, this 9~ day of .]uly 2004, comes the Petitioner, Pro Se, to petition this Honorable Court to enter an order with respect to visitation and in :support thereof, and avers as follows: 1. The parties have one minor child, George Maclde Cornwall IV, DOB November 11, 1998. 2. Petitioner is the father of the child and resides at 1897 Boca Ratan Drive, Lake Oswego, (Clackamas County), OR 97034, (503) 784-3888. The Respondent resides at 4236 Carlisle Road, Gardnem, (Cumberland County), and PA 17324, (717) 486-3634. This house was purchased using non-marital assets provided by the Petitioner for the down payment and closing costs. Currently a petition for legal separation of the parties is pending in the Circuit Court of the State of Oregon for the County of Clackamas. The Respondent has additionally petitioned the court to convert the case to a dissolution proceeding. On December 8~, 2003 that court issued a Pendente Lite order providing for visitation of the minor son by the Petitioner. A certified cody of this order is provided and attached herewith. The Clerk of that court suggested the use a certified copy of the Oregon order with this Honorable Court. This certified copy of the Oregon Court's order was provided to me for that express purpose. Since 3anuary 24~, 2004 respondent has routinely contrived to prevent the ordered visitations by various means, including removing the minor son from Nursery School, removing him from the home. There has also been all ongoing general refusal to 07/12/04 1 of 2 Petition for Special Relief 48 49 5O 51 52 53 54 55 56 57 58 59 6O 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 9O 91 92 93 communicate about a variety of topics, including the visitation schedule, or do anything else that might in any way facilitate any visitation. Respondent has by various means, including fleeing from the State of Oregon, prevented any meaningful contact between Petitioner and the Minor Child since December 5, 2002. 7. Petitioner believes that respondent recently even went so far as to place the child, for days at a time, in the homes of relatives up to 50 miles distant from the Gardners, PA residence. This apparently has been done for most of the last week. According to the Child, He was told that these actions were required so that he could be adequately protected from Petitioner. 8. All of these actions have been for the express purpose of thwarting Petitioner's attempts to exercise even one visit as provided by the aforementioned order. Certainly, these actions do NOT serve the best interests of the Minor child. 9. The best interests of the child would be served by provide frequent and relaxed contact in an atmosphere of adult cooperation and communication. Fear mongedng only serves to frighten the child, further straining an already damaged relationship. 10. Circuit court action is pending in Oregon to significantly amend and ameliorate the visitation dghts allowed the Petitioner under the aforementioned order, however petitioner has now made a total of five (5) transcontinental tdps, without ever being permitted contact. Though two of the trips were made while petitioner lacked permission to travel outside Oregon, Petitioner has never attempted to schedule visits of a type or duration that were over and above those permitted at the time by the Oregon Courts. Wherefore Petitioner prays your Honorable Court to enter an order directing the Respondent to comply with the visitation provisions of this order without further delay or artifice. Further, that Respondent be admonished that continued interference with thE: existing and future court orders arising from these matters, will serve to subject her to possible sanctions for contempt of the Orders of This Court. George M. CornWall ~I, ' ' Copies by mail to: Larry Blake, .lr. 3718 SW Condor #110 Portland, OR 97239 Stephanie L. Cornwall 4236 Carlisle Road Gardners, PA. 17324 07/12/04 2 of 2 Petition for Special Relief 1 2 3 4 5 6 7 8 9 10 1I 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 ZN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL Ac ~ ~ON - LAW In the matter of the marriage of George M. Cornwall, III, Petitioner, Pro ~ and Stephanie Lynn Cornwall, Respondent NOTICE AND ORDER TO APPEAR PETITION FOR CONTEMPT NOT[CE AND ORDER TO APPEAR PET~I'ION FOR CONTEMPT Legal proceedings have been brought against you alleging you have willfully disobeyed an Order of the Circuit Court of the State of Oregon for the County of Clackamas Court for visitation. ~) 6.53 1. Kozlowski v. Kozlowski, 362. Pa. Super, 516, 524 A.2d 995 (1987) 2. Pa.R.C.P. No. 1915;12(b) 3. Pa.R.C.P. No. 1915.12 If you wish to defend against the claim set forth in the following pages, you may but you are not required to file in writing with the court your defenses or objections. Whether or not you file in writing with the Court your defenses or objections, you must appear in Person in Court on , 2004, in Court Room before the Honorable COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CARLISLE COURT HOUSE 1 Court House Square Carlisle, Pennsylvania 07/12/04 1 of 2 Notice and Order to Appear 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 87 88 IF YOU DO NOT APPEAR IN PERSON, THE COURT MAY ISSUE A WARRANT FOR YOUR ARREST. If The Court finds that you have willfully failed to comply with its order in support of the Oregon Order for visitation, you may be found in contempt of Court and committed to jail, fined, or both. YOU SHOULD TAKE THZS PAPER TO YOUR LAWYER AT ONCE. ?F YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFI:ZCE SET FORlrH BELOW TO FZND OUT WHERE YOU CAN GET LEGAL HELP. (NAME) .? one Number) By the Court: Date: George M. Cornwall III, Petitioner 1897 Boca Ratan Ddve Lake Oswego, OR 97034 (503) 784-3888 Copies by mail tO: Larry Blake, 3r. 3718 SW Condor #110 Portland, OR 97239 St:ephanie L Cornwall 4;).36 Carlisle Road Gardners, PA. :17324 07/12/0~ 2 of 2 Notice and Order to Appear · 08/83/2804 11:56, 5832286222 L~ OFFICES P~GE 32/52 6 7 $ 9 10 I1 12 14 16 19 20 21 22 24 25 26 IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF CLACKAMAS In the Matt~ of ) ) GEORGE MACI<IE COKlqWAIZ, III., ) ) Petition~, ) ) and ) ) STEPH/~NIE LYNN cOKNWALL, ) ) R~pon&nt, ) Case No. DK05-05721 MOTION KND ORDER RE: LIMITED JUDGMENT FOR PENDENTE LI'I~ This m~ucr em:ne before Judge Eve Milles in the Chdrtmss Coumy Court, on December 8, 2003, upon the agreement of th~ parties. The Mo*don of Show Cause submitted by K~pond~nt's a~ome~ wae settled and pames phced their agreement on the record. Peti*doner, ~ppe,ting by and through bis attorney, Shannon Coimall, ~nd Respondent, appeming by md d~rough hat attorney, Ls.try J. Blake, Jr., m_nd ~he Court being fully advised in the premises aft= reviewing the flies: IT IS HEREBY OILI~EILED, ADJUDGED AND DECKE]ED that.' 1. GUSTOD¥/PARENTING TllV[E. Mother shall have sole legal and physical custody of George M. Coxmvall, IV., bom November ll~ 1998. p~renting time ~hall be a~ £olbws: a. Father sb. all only haw aup~'vhed P'azentmg plan wi~h supeX-v~sor to be determined by agre~n~ut ofp~,'tms os by fut'the~ o~der of this cou~t. 1 ~ MOTION AND ORDER P,~: LIM.rI~D JUDGMENT FOP. I~NDF-2Cl'E LITE EXHIBIT · 08/03/2004 11:56 5032286222 LAW OFFICES PArE 33/52 1 2 3 4 6 8 9 10 11 12 13 14 16 17 18 19 20 21 '22 23 24 25 26 b. If Father ~z~vcls to p~ns¥1van~ for p~rentmg ~e ~ ~or c~d, ~pen~ of ~v~ ~d ~xpen~e~ asso~ated wJ~ ~e mpe~sed p~ ~e. P~en~g ~ m Pe~sylv~ ~ fa&e~ is most ~y to b,e at &e Penmylvama. c. If Fa&~ reques~ to have p~en~g ~e ~ PoP,ad, ~egon, Fa~er e~penses for Re~ondmt md ~o~ ~d m mavd and stay duration of the par~ ~e. Fa~ ~ ~so be~ ~e cos~ o~ supe~ismn fo~ ~e and costa asso~md ~th Mo&ex fo~ ~s~g ~e ~ i. Moth~ ~ o~y be ~eq~d to ~avd to Portland, Oregon for p~en~g ~e if ~e ~ arable fox he~ to ~avel and she agrees to ~l wi& flae ~o~ c~d to Pop, and, Oregon. ~. ~o~ a~es to ~ fath~ to have ~eleph~e conner ~ ' c~ prior to c~d gong to bed each evenmg. Mo~ ~ ~&~ ~e p~one c~ be~ ~or ~d md Fa~er ~ &e phone ~ ~ums. Fa&: ~h~ have no telephone con~t ~ Mo&: telephone contact Mo~ ~ be~ee~a Fa~e~ and ~o~ ~d. ~. Fa&er a~e: to pay c~fl s~pc,zX ~ &e amour of $900.00 per mon~ tO Mo~ be~nlng Dec~b~ 15, 2~3, m~d ~ mon~ ~e~ez on &e 15~s of ~e mo:~ ~fl f~&e~ order of ~ C0~t. a. Fa&er a~e~'to pay a~e~s of c~d support o~ed m Mo~ m $9~.00 by December 8, ~. Fa&ex ~ees to pay ~ cm~ent patens for ~e f~y r~idence, mdu~g pa~en~ ~ch ~o~fl flso mchde ~ance costa, taxes, and homeown: ~e~. /?/ //t III 2 - MOTION AND ORDER RP,: LI MI"Im-,D JUDG~NT FOR PE)',TDEN'rE LITE '08/g~/2004 11:5S 50322BS222 LAW OFFICES PAGE 34/52 ,I0 I1 14 15 18 21 22 24 25 26 ?age benefit of ~o~e~ and ~ot c~, and a~es to p~y onc-~ of ~e ~o~ ~d's u~s~ed me~c~, donzi, upfic~ and 0~odondc b~s ~at m~y be inc~ed. ~. ~e Ex p~te Mouon ~ed by Pe~ner ~nd s~ed by Ju~ Tom on M.rch 27, 2~3 r~s m ~ f~ce dumg ~e pendm~cy offs m~, MONEY AWARD C~editot: Czeclitot's Addeess: Crct~tofs ~.tto~Qcy: Attorney% Add~ess; DebtoFs Attorney: Attorney's Acl~tess: Money AwaY: Attorney% Beginning Date: Endi~ Date: p~eiudgmeut Intexesc Attomefs ]Fees ~nd Costs: Post Jud~t Steph~ie Cornwall 4236 Ca~hsle R,:~d Gexdnet~, PA 17324 LaxTJ. Blake, It. 37!'8 5W Coudoz, Suite 110 Portland, OR 97239 George Comw:all 1897 Boc~ Kat0n Drive Like Oswego, OR 97034 Shannon Connall 621 SW Mo~ison, Suite 140 Pordind, OR 97205 $900.00 p~ mx)nth fox child support. To be deter'ink,ed at hter Decembe~ 8, 2003 pet a~anum upon entry of judgment DATF.,D this ~chy of ,2oo . b - MOTION AND ORDF~ ~: Lllu~T~D JUDGMENT I:Ol~, P]~NDENTE :l~ 08/~3/2004 11:5~ 5832286222 LA~J OFFICES PAGE 35/52 2 4 6 George Madde Cornwall, HI, pcdmmer 7 :Nom? Pabiic of My Commission 9 I0 11 Submitted by: 12 13 --- -- ~ 14 15 16 17 15 19 2O 23 24 25 26 Laay J. Blake, Jr., O5B#87172 Attorney for l~spondent St~Phame Lynn Comw~dl, Respondent Notai'y Public of Oregon My Col'amlssioa Ex'ptres: _ Stipulated and Agreed to by: Shannon ConnalI, OSB#97538 Attorney fo,' Petitioner 4 - MOTION AND ORDER RE: LIMITED JUDGMENT FOR PENDBNTE ]kITE GEORGE M. CORNWALL, Plaintiff/Petitioner VS. STEPHANIE LYNN CORNWALL, Defendant/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-3379 CIVIL ACTION - LAW IN CUSTODY NOTICE TO PLEAD You are hereby notified to file a written response to the within New Matter within twenty days (20) days from service hereof or a judgment may be entered against you. GEORGE M. CORNWALL, III, Plaintiff/Petitioner VS. STEPHANIE LYNN CORNWALL, Defendant/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-3379 CIVIL ACTION- LAW : IN CUSTODY PRELIMINARY OBJECTIONS, TO JURISDICTION AND VENUE AND NOW, comes Defendant/Respondent, Stephanie Lynn Cornwall, by and through her counsel, Bradley L. Griffie, Esquire, and files the following Preliminary Objections: Defendant/Respondent is an adult individual currently residing at 4236 Carlisle Road, Gardners, Cumberland County, Pennsylvania. Plaintiff/Petititoner is George M. Cornwall, III, an adult individual whose last known address is 1897 Boca Ratan Drive, Lake Oswego, Clackamas County, Oregon. The parties are the natural parents of one (1) child, namely, George Mackie Cornwall IV, born November 11, 1998. The parties' marital residence, the place of the child's birth, and the primary residence of the child since his birth exists in the County of Clackamas in the State of Oregon. The parties are engaged in divorce litigation, as well as custody litigation, in the Circuit Court of the State of Oregon for Clackamas County, which Court has entered various Orders relative to the parties' legal matters, including a Order scheduling a hearing for 9:00 a.m. on September 21, 2004. Attached hereto and incorporated herein by reference as Exhibit "A" is a faxed copy of the Order of Court from the Circuit Court of the State of Oregon for the County of 10. 11. 12. Clackamas setting forth the terms of custody relative to the child at issue herein, said Order being entered by agreement of the parties on December 8, 2003; a tree and attested copy of the Order is being forwarded to the tmdersigned from Respondent's counsel in the State of Oregon. There is pending, before the Circuit Court of the State of Oregon for the County of Clackamas, a Petition and Motion filed by Petitioner herein requesting unsupervised visitation time, and other modifications to that Court's prior Order. Petitioner has filed a Motion requesting a custody evaluation through the Circuit Court in the State of Oregon for the County of Clackamas, which Motion is pending at present. Petitioner not only has a Petition pending for unsupervised contact with the parties' child, but also has other Motions pending to which Respondent has filed an appropriate response within the last month and which will cause further proceedings before the Circuit Court of the State of Oregon for the County of Clackamas. Petitioner's Petition for Special Relief filed with this Court regarding visitation references in paragraph 5 the entry of an Order fotlowing agreement of the parties made in open Court on December 8, 2003, relative to custody of the child at issue in these proceedings. In paragraph 10 of Petitioner's Petition, he identifies the fact that "Circuit Court action is pending in Oregon to significantly amend and ameliorate the visitation rights allowed the Petitioner under the aforementioned Order..." Petitioner's Petition, on its face, lacks appropriate venue and jurisdiction and illustrates an attempt on the part of Petitioner to forum shop to in some manner supersede the jurisdiction of the Circuit Court of the State of Oregon for the County of Clackamas, which has assumed and retained jurisdiction over the issue of custody in this case, with custody matters presently pending. WHEREFORE, Respondent requests your Honorable Court to dismiss Plaintiff/Petitioner's Petition for lack of proper jurisdiction and venue. Respectfully submitted, ~)ate ~I~, Esquire ~frt'~foC~Defendant/Respondent GRIFFIE & .ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom falsifications to authorities. DATE:_ ~EgLYNN CORNWALL GEORGE M. CORNWALL, III, Plaintiff/Petitioner VS. STEPHANIE LYNN CORNWALL, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3379 CIVIL ACTION - LAW IN CUSTODY CERTIFICATE OF SERVICE I, Bradley L. Griffie, Esquire, hereby certify that I did, the ~ ]'p/ day of August, 2004, cause a copy of DefendanffRespondent's Preliminary Objections to be served upon Plaintiff/Petitioner by first class mail, postage prepaid at the following addresses: George M. Cornwall, III 1897 Boca Ratan Drive Lake Oswego, OR 97034 DATE: GRIFFIE &fi/ASSOCIATES 200 North tlanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 '08/03/2BD4 ).1:56 5032286222 LAW OFF]CES PAGE 32/52 ! 2 3 4 $ '7 9 12 16 19 ;20 21 '22 24 25 26 ?age IN THE CIRCUiT COURT OF THE STATE OF OREGON FOR THE COUNTY OF CI,ACIC,.~MAS I~ the M~tei' of ) GEORGE MACK, IE CORNWALL, IlL, ) ) Petitioner, ) STEPHANIE LYNN coRNWA~'%, )' Respondent, Case iqo. Di~03-0372I MOTION A_ND ORDER RE: LIMITED JUDGMENT FOR PENDENTE LITE This matte~ came before Judge Eve Miller in the Ctackamas CountT Court, on December B, 2003, upon the agreement of the paztie~. The Motion of Show Cause'submitted by Responfl~nt's attorney was set'tied and parties placed their agreemetat on the record. Petition=, appe~g by and through hid attorney, Shannon Cormall, and Respondeait, appearing by and flaxo~gh bar atte,mey, Lanv/J. Blake, Jr., and the Court being fully advised m the premises after reviev,'mg the files: IT IS HE1LEBY ORI)ERED, ADJUDGED AND DECICEX.D that: 1. CUSTODY/PAReNTING TIME. Mothe~ ~hall have snle leg~d and physical custody of George M. Cornwall, IV., bom November lt, 1998. i~a~entmg time shall be as followsl a. Father shall only have su?emrised iazentmg plan ~ith superVasox to be detemxlned by agreement of p~tties o~ by fu~he~ o~der o[ tbls coup. 1 - MOTION AND ORDER ILE: LIMITED JUDOTv~.~T FOR 'P~,I~IDEN?E LITE EXHIBIT ' 08/0312~0~ 11:5~ 5832286222 L¢~ OFFICES ? P~GE 33/52 '7 9 10 11 12 13 14 16 17 25 page b. If Far. her travels to pennsylvania for parenting lime with mmo~c child, Fs~e~ sh~ be~ exp~nses of ~vd and expenses asso~ated with ~e mp~Jsed p~en~g ~e. ~ ~ pe~sylv~ ~ f~e~ is most ~y to be st ~ ~CA located m C~sle, Pem~syNama, c. If Fa~= ~eques~ to have pa~en~g ~e ~ Po~d, Oregon, ~a~er w~ bca~ ~e expenses {ox Re~ondent ~d ~o~ ~d ~ ~av~ and stay ~ p~nd, Oregon fox d~zafion of the parm~g me~ Fa~ w~ ~so be~r ~e cost oE s~e~ision fox me and cos~ assorted ~th Mo~ for mss~g t~e ~om work i. Moth~ ~ o~y be zeq~ed to =~=~ to Portland, Oregon fo~ p~en~ me me ~ av~le io~ h~r to =evil md she ~g.recs to ~l wi~ fl~c lmox c~d to Po~snd, Oregon. fi, Mo~ a~es to ~ow iafl~ to have teleph~e con.et ~ ~e pa~' c~ N~ot to zMd grog to b~d each evem~. Mo~ ~ ~te ~e phone he.em ~or c~d md Father ~ ~e phone cae ~ a ma~ of lmutes. Fa~ ~h~ have no mlephone con.ct ~ Mo~ o~er ~an ~elephone co~tsct Mo~er ~tm be~een Fa~ and ~or ~. Fa~ex a~s to pay cMfl suppoa ~ ~e amo~t of [900.00 par mon~ tq Mo~ berg Dec~b~ 15~ 2003, and ~mT mon~ flxez~e: on ~ 15~ of ~e mon~ a. Fa~ a~ees 'to p~y ~re~s of c~d ~ppon o~ed. ~ Mo~ m ~e to~ amour $9~.00 by December 8, 2005. ~. Fa~ a~ee~ to pay ~ ~rmt pa~en~ fox ~e f~y residence, mclu~g pa~enm wN~ ~o~d also ~dude ~ance cos~, caxe~, a~d homeo~m ~ee~. /// /// /// 2 - i~fOTION AND ORDER B.B: LII~/r~D JUDGlv~Drr FOR PBND~ENTI~ :LII~ · '08183/200~ 11:56 583228~222 LA~ OFFICES P~GE 34/52 2 4 6 7 8 9 .I0 13 14 16 17 20 page 4. ~. Father agrees to continue the: benefit of Mo~er and ~aoz c~d, and agrees to pay one-~ of ~e ~ot ~d'a u~s~ed me~cfl~ dental, opfic~ ~d 0x~hodonfic b~s ~at may be ine~ed. 5. ~. The ns~ of a~om~ fes ~'be deleted ~ ~ detex~afion of ~s mgttcr, 6. ~. ~e ~x p~te Mod0~ ~efl by Pe0fioner aBd s~cd by ]u~ Tom on M~ch 27, 2003 r~am~ m MONEY AWARD C~eflitoz: Cee&tot's Ad&ess: ~eR~toz's .&ttorney: Attorney's Address: Dcbtox: Debtor's g:d&ess; Debtor's Attorney: Attorney's Aad~:ess: Money Award: Attorney's Beginning Date: Ending Date: prejudgment I~.te. xest: Attorney's Fees mad Cost~: Post Judgment Interest: Stephanie Cornwall 4236 Carlisle Road Gatdners, PA 17324 Lancy J. Blake, jr. 3718 SW Condor, State 110 I%ttimd, OK 97239 George Comws~ 1897 Boce P, aton D~4ve Lake Oswego, ()K 97034 Shaxmon Connall 621 SW Momson, Suite 140 Ponlau~l, OP, 97205 $900.00 per mc,n~ for chil8 rapport. To be determie,~ed at later d~te. December 8, 2003 9% per annum upon DATEJD this .d~y of .., 200~-. Judge Eve Miller 3 - MOTION AND OR.DER II~; LII~t'EF2D JUDGMENT FOP, p.BNDENTE LI'rii , '08/03/2004 11:56 §03228G222 L~ OFFICES P~G£ 35/52 Geo'~:ge Mackie C~mwalli"IlI, Petitioner Noury Public My Commission Expires:. Submitted by: 14 LattyJ. Blak¢,J~., OSB#$7172 Attorney fo~r 15 16 17 18 2O 21 22' 24 Stepha~ie ,Lynn Cornwall, Respondent Notary Public of Oregon My Corm:~moa Expires; Stipulaled and Agzee~d to by: ' Shannon Connall, OSB#97538 Attorney fo~ P,..tition~ 4 - MOTION AND ORDBR RI~: LI~ JUDGMENT FOR PEND.BN"fE LI'I~ GEORGE M. CORNWALL, Ill, PLAINTIFF/PETITIONER : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA STEPHANiE LYNN CORNWALL, DEFENDANT/RESPONDENT : 04-3379 CIVIL TERM ORDER OF COURT AND NOW, this ~/(2 day of August, 2004, the conciliation conference scheduled before Dawn S. Sunday, EsquirE;, for Tuesday, August 24, 2004, IS CANCELLED. A hearing on the preliminary objections as to jurisdiction filed by Stephanie Lynn Cornwall shall be conducted at 11:00 a.m., Tuesday, August 24, 2004, in Courtroom Number 2, Cumberland County Courthouse, Car!isle; ,Per, sylvania. Dawn S. Sunday, Esquire Custody Conciliator Edgar B. Bay~ v~'eorge M. Cornwall, III 1897 Boca Ratan Drive Lake Oswego, OR 97034 v~'radley L. Griffie, Esquire For Defendant/Petitioner O -IZ :sal GEORGE M. CORNWALL, III, PLAINTIFF IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA STEPHANIE LYNN CORNWALL, DEFENDANT : 04-3379 CIVIL TERM ORDER OF COURT AND NOW, this day of August, 2004: (1) Finding that jurisdiction is in the Circuit Court of the State of Oregon for the County of Clackamas, the preliminary objection of Step, hanie Lynn Cornwall as to jurisdiction, IS GRANTED. This case, IS DISMISSED. ~,,~ean M. Shultz, Esquire For George M. Cornwall, III (2) The petition of Stephanie Lynn Cornwall for counsel fees, IS DENIED. Edgar B. Bayley, J. ,,,~'radley L. Griffie, Esquire For Stephanie Lynn Cornwall ~.-Dawn S. Sunday, Esquire Custody Conciliator :sal s~p o ~ ~o04 ~ GEORGE M. CORNWALL, III Plaintiff VS. STEPHANIE LYNN CORNWALL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-3379 CIVIL ACTION LAW 1N CUSTODY ORDER AND NOW, this 26th day of Augush 2004 , the conciliator, having received notice from the Court that the Mother's preliminary objections have been granted and the case dismissed for lack of jurisdiction, hereby relinquishes jurisdiction. FOR THE COURT, Custody Conciliator