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Home My WebLink About00-6047 NMJOHN CHRISTOPHER, III, Plaintiff vs. REBEKAH S. CHRISTOPHER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : Docket No. 00-6047 CIVIL ACTION LAW IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY ORDER i s- AC-D n AND NOW, comes Defendant, Rebekah S. Christopher, now known as Rebekah Green, by and through her attorney, Karen W. Miller, Esquire, of Caldwell & Kearns, P.C., and respectfully presents the following Petition for Modification of Custody Order with regard to the minor children identified in the following paragraphs, and files this Petition; and in support thereof, avers as follows: 1. Defendant is Rebekah S. Christopher, now known as Rebekah Green, an adult individual residing at 6460 Brittan Road, Harrisburg, Dauphin County, Pennsylvania, 17111. 2. Plaintiff is John S. Christopher, III, an adult individual residing at 8 Kingsbridge Circle, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff and Defendant are the natural parents of the minor children whose names are set forth in the following paragraphs. 4. Defendant seeks shared legal and primary physical custody of the following children: Name Alexandria Christopher (girl) Adrienne Christopher (girl) Address 8 Kingsbridge Circle Carlisle, PA 17013 8 Kingsbridge Circle Carlisle, PA 17013 Date of Birth/Age 7/1995 - 16 11/1996-14 oo pa a? ONA s?°g 5. Defendant seeks shared legal and periods of partial physical custody of the following child: Name Address Date of Birth/Age John Christopher, IV (boy) 6. The children were not born out of wedlock. 7. The children are presently in the custody of their Father, Plaintiff, with Mother, Defendant, having periods of partial physical custody. 8. During the past five (5) years, the children have resided with the following 8 Kingsbridge Circle Carlisle, PA 17013 11/1997-13 persons at the following addresses: Name Address Date Plaintiff, Jen Christppher, 259 South Pitt Street Jayonna Pope, Alexandria Carlisle, PA 17013 Christopher, Adrienne Christopher, John Christopher IV, Nicholes Zulli, Angeleah Christopher Plaintiff, Alexandria Christopher, 430 South Pitt Street Adrienne Christopher, John Carlisle, PA 17013 Christopher IV, Alleshia Christopher, Lisa M. Christopher Plaintiff, Alexandria Christopher, 1153 Belvedere Street Adrienne Christopher, John Carlisle, PA 17013 Christopher IV 2006 -2007 2007 - June, 2008 June, 2008 - October, 2009 Plaintiff, Angela Christopher, 327 East Louther Street October, 2009 - Alexandria Christopher, Carlisle, PA 17013 February, 2010 Adrienne Christopher, John Christopher IV, Julian Christopher Plaintiff, Angela Christopher, 8 Kingsbridge Circle Alexandria Christopher, Carlisle, PA 17013 Adrienne Christopher, John Christopher IV, Julian Christopher Plaintiff, Angela Christopher, Adrienne Christopher, John Christopher IV, Julian Christopher Defendant, Thomas Green, Alexandria Christopher 8 Kingsbridge Circle Carlisle, PA 17013 337 Swatara Creek Dr Jonestown, PA 17038 Plaintiff, Angela Christopher, 8 Kingsbridge Circle Alexandria Christopher, Carlisle, PA 17013 Adrienne Christopher, John Christopher, IV, Julian Christopher, Alivia Christopher February, 2010 - March, 2011 March, 2011 - September, 2011 March, 2011 - September, 2011 September, 2011 - October 31, 2011 Defendant, Thomas Green, 337 Swatara Creek Dr. November 1, 2011 - Adrienne Christopher Jonestown, PA 17038 present 9. The Mother of the children is Rebekah Green, currently residing at 6460 Brittan Road, Harrisburg, Dauphin County, Pennsylvania 17111. 10. The Mother of the children is no longer married to the Father. 11. The Father of the children is John Christopher, III, currently residing at 8 Kingsbridge Circle, Carlisle, Cumberland County, Pennsylvania 17013. 12. The Father of the children is no longer married to the Mother. 13. The Defendant avers that it is in the best interests and welfare of the minor children that she be granted shared legal and primary physical custody of Alexandria and Adrienne, as well as shared legal and periods of partial physical custody of John Christopher, IV. 14. Pursuant to an Order of Court dated January 30, 2002, entered by the Honorable Kevin A. Hess, Mother was granted periods of partial physical custody of the minor children. 4 true and correct copy of the Order is attached hereto as Exhibit "A " and is incorporated herein by reference. 15. Following entry of the Order, Defendant was incarcerated from July, 2002, through January, 2005. 16. Upon Defendant's release in January, 2005, despite the Order of Court, Defendant exercised periods of partial physical custody of the minor children every weekend. 17. In January, 2011, Father was incarcerated for approximately thirty (30) days. 18. During the aforesaid time, the minor children remained at their Father's residence and were in Mother's physical custody. 19. In March, 2011, the minor child, Alexandria, moved in with Defendant and resided with Defendant until September, 2011. 20. The minor children, Alexandria and Adrienne, have expressed their wishes to reside with their Mother and transfer schools. 21. On November 1, 2011, Father contacted Mother via telephone and requested that she arrive at 3 p.m. that afternoon to take primary physical custody of the minor child, Adrienne. 22. On the aforesaid date at the aforesaid time, Mother picked up the minor child, Adrienne, and, with Father's consent, transferred the minor child, Adrienne, to Central Dauphin School District. 23. Defendant has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or any other court. 24. Defendant has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 25. Defendant does not know of a person not a party to these proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 26. The best interests and permanent welfare of the children will be served by granting the relief requested by Defendant because: a. Mother can provide a more stable living environment for the minor children; b. In approximately August, 2011, Plaintiff choked the minor child, Adrienne, causing her to passed out; The minor child, Alexandria, is declining in school; d. The relationship between Angela Christopher, Father's wife, and the minor child, Alexandria, is strained, at best; and e. Despite the minor child, Alexandria, moving back to Father's residence in September, 2011, at Father's request, the minor child, Alexandria, spends a majority of her overnights, including school nights, with friends to avoid Angela Christopher. 27. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: None. 28. Defendant does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 29. The best interests and permanent welfare of the minor children will be served by granting the relief requested herein. WHEREFORE, the Defendant/Petitioner, Rebekah S. Christopher, now known as Rebekah Green, respectfully requests that this Honorable Court enter a custody order directing that the Defendant/Petitioner has shared legal and primary physical custody of Alexandria and Adrienne, as well as shared legal and shared physical custody of John Christopher, IV. Respectfully submitted, Date: Wur6 0 , 2011 A?j . aren W. Miller, Esquire Attorney I. D. # 200037 Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110-1533 (717) 232-7661 (717) 232-2766 Attorney for Defendant, Rebekah S. Christopher, now known as Rebekah Green 11341-001/183280 ?X- JOHN CHRISTOPHER, III, plaintiff vs. REBEKAH S. CHRISTOPHER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 00-6047 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 3 e ' day of - w rRA ___, 2002, upon consideration of the attached Custody Conciliation Repo it is ordered and directed as follows: 1. The prior Order of this Court dated October 9, 2001 shall continue in effect as modified by this Order. 2. Beginning on February 1, 2002, the Mother's alternating weekend periods of custody shall be expanded to run from Friday at 6:00 p.m. through Sunday at 5:00 p.m. 3. Until such time as the requirement of supervision is terminated pursuant to the terms of this Order, the Mother's periods of custody may be supervised by either the maternal grandmother, Marjorie Grove, or her husband, Ralph Grove. 4. The requirement that the Mother's periods of custody be supervised at all times shall continue -in effect until such time as (1) The Mother has been sentenced on current charges, and (2) Written verification has been obtained from the United States Attorney's Office confirming that the Mother's cooperation in the homicide investigation and the Mother's testimony are complete. 5. Upon satisfaction of the requirements in the preceding provision of this Order, the requirement of supervision during the Mother's periods of custody shall terminate. However, the Mother shall not take the Children to Dauphin County or expose the Children, in any way, to the presence of drug users, drug traffickers or criminal activity. BY TBE COURT, cc,-?amuel L. Andes, Esquire -,Marcus A. McKnight, III, Esquire C? 61 -30-0 R?js VERIFICATION The undersigned hereby verifies that the facts set forth in the foregoing document are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: D Lam( --,7_ 1 , 2011 Rebekah`Greer% form known as Rebekah S. Christopher