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Home My WebLink About05-1854 v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005- IPS1-f CI UL L ~ 'VL~ CIVIL ACTION - LAW CUSTODY RANDI-BRUCE THICKEY, Plaintiff JAMIE R. THICKEY, Defendant COMPLAINT FOR CUSTODY 1. The Plaintiff is Randi-Bruce Thickey, an adult individual residing at 9 Yankee Drive, Mount Holly Springs, Cumberland County, Pennsylvania. 2. The Defendant is Jamie R. Thickey, an adult individual residing at 196 South Middlesex Road, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of the following child: NAME PRESENT RESIDENCE AGE/(DATE OF BIRTH) Makayla K Thickey 196 South Middlesex Road Carlisle, Pennsylvania 4 August 26. 2000 The child named above was not born out of wedlock. The child named above is presently in the custody of Defendant at her residence as indicated in Paragraph 2, above, 4. During the last five (5) years, the child subject to this custody action resided with the following persons and at the following addresses: PERSONS ADDRESSES DATES Plaintiff, Defendant and 196 South Middlesex Road 2000 to May 2004 Slade A. Thickey Carlisle, Pennsylvania Defendant and Jeffrey Graham 196 South Middlesex Road May 2004 to present Carlisle, Pennsylvania LAW OFFICES SNELBAKER & Plaintiff and Slade A. Thickey 9 Yankee Drive May 2004 to present BRENNEMAN, P.C. Mount Holly Springs, P A The mother of the child is Defendant Jamie R. Thickey, who is currently residing at the address indicated in Paragraph 2, above. She is not married to Plaintiff. The father of the child is PlaintiffRandi-Bruce Thickey, who is currently residing at the address indicated in Paragraph I, above. He is not married to Defendant. 5. The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with the following persons: NAME RELATIONSHIP Slade A. Thickey Son 6, The relationship of Defendant to the child is that of mother. The Defendant currently resides with the following persons: NAME RELATIONSHIP Jeffrey Graham None 7. Plaintiff has not participated as a party or witness or in any other capacity, in other litigation concerning the custody of the parties' child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to these proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child, LAW OFFICES SNELBAKER & BRENNEMAN, P.C. -2- RECEIVED JUL 05100SyI' ;y RANDI-BRUCE THICKEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : CIVIL ACTION - LAW JAMIE R. (TRICKEY) GRAHAM,: NO. 2005-1854 CIVIL TERM Defendant : IN CUSTODY ORDER OF COURT AND NOW, this A day of .:! v \ :1 ' 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A Hearing is scheduled in Court Room No. _ I , of the Cumberland County Court House, on the /,,(;i day of ~)bV ,2005, at /'36' o'clock, L. M., at which time testimony will be taken. For purposes of this Hearing, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten days prior to the Hearing date. 2. The prior Order of Court is hereby vacated. Pending further Order of Court or agreement of the parties, the following shall remain in effect: 3. The Father, Randi-Bruce Thickey, and the Mother, Jamie R. (Thickey) Graham shall have shared legal custody of Makayla K. Thickey, born August 26, 2000. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding her health, education and religion. 4. Mother shall have primary physical custody of the child. 5. Father shall have the following periods of partial physical custody of the child: A. Every weekend from Friday at 8:45 p.m. to Sunday at 8:30 p.m., unless Mother notifies Father two weeks in advance, in which case she may have one weekend per month. B. One week in the summer from Friday to Friday provided he give Mother 2 weeks prior notice. C. Thanksgiving Day in odd numbered years. D. Every Christmas Eve from 12:00 noon to 9:30 p.m. E, Such other times as the parties agree. V1NVAlASNN3d AlNnCn ':"f\1"'~i:3m^jno II :Z \old 9- lor sooz AW10NOH10Cid 3Hl .:10 3::JI:HCKJ31I:J 6. Father shall be responsible for all transportation. 7. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, cc: Keith O. Brenneman, counsel for Father Jane Alexander, Esquire, counsel for Mother ,/ . ~ 1-0".00 ~ 9- ~ 'J'}~ ?~~, A..L-- RANDI-BRUCE THlCKEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW JAMIE R. (THlCKEY) GRAHAM,: NO. 2005-1854 CIVIL TERM Defendant : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation as follows: NAME DATE OF BIRTH grmU:NTL Y IN CUSTODY OF Makayla K. Thickey August 26, 2000 Mother 2. A Conciliation Conference was held July 1, 2005 with the following individuals in attendance: The Father, Randi-Bmce Thick,ey, with his counsel, Keith O. Brenneman, Esquire, and the Mother, Jamie R. (Thickey) Graham, with her counsel, Jane Alexander, Esquire. 3. The Court previously entered an Order on May 12,2005 providing for shared legal custody, Mother having primary physical custody and Father periods of partial physical custody every Saturday to Tuesday. 4. Father's position on custody is as follows: Father seeks shared legal and shared physical custody. Father seeks an alternating wee,kend schedule and every morning since he goes to work at 12:00 noon and the child is expected to have afternoon kindergarten beginning in August. Father submits that he has a close relationship with the child and he is available to care for the child in the mornings before work. He offers to take the child to school if possible or drop her off at her babysitter's. 5. Mother's position on custody is as follows: Mother seeks shared legal and primary physical custody with Father having every weekend, Friday to Sunday unless she notifies Father two weeks in advance to have one week(~nd per month. Mother's major concern is that if Father has the child every morning is will bt: two many exchanges and disrupt the child especially when school begins. 6. The Conciliator recommends an Order in the Jorm as attached scheduling a Hearing and granting the parents shared legal custody, Mother primary physical custody and Father hllving every weekend Friday to Sunday unless Mother provides two weeks prior notice to have one weekend per month. It is expected that the Hearing will require one-half day. -- 1-1 -D b Date b-,L~I1I~~' acq line M. Verney, Esquire Custody Conciliator LAW OFFICES SNELBAKER & BRENNEMAN, P.C. '. 8. The best interest and permanent welfare of the child will be served by granting Plaintiff physical custody of the child because Plaintiff is able to care for the child and provide a stable nurturing environment. 9. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: None. WHEREFORE, Plaintiff Randi-Bruce Thickey requests this Court to grant Plaintiff physical custody of Makayla K, Thickey. SNELBAKER & BRENNEMAN, p, C. l~ Date: April 8, 2005 By: Keith O. Brenneman, Esquire 44 West Main Street Mechanicsburg, P A 17055 (717) 697-8528 Attorneys for Plaintiff -3- LAW OFFICES SNELBAKER & BRENNEMAN. P.C. VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I derstand that false statements herein are made subject to the penalties of 18 Pa. C.S, ~4904 elating to unsworn falsification to authorities, /~d:: y~-- ," Ratmi-Bn~iCkey ate: tf / f/O~ (') 0 -<q. ~~~ J\( -- ~ " f\l -- - V"\ Q .- \) -0 }-.J ..l::. -l ""'v ?-- f" 0 -F ~ Q, ~ ~... -::::3.-,1 ~ (f\e Q ?" --~'q ::: '-:~':i~ I "!:> \ (:)()~ ~ .,~_~.;-t\ ~ ,"} 6._.- -:;;~ ':q. -/.:), (5\ ....... :'" ~ C'-' l RANDl-BRUCE THICKEY PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYl.V ANI A v, 05-1854 CIVIL ACTION LAW JAMIE R, THICKEY DEFENDANT IN CUSTODY ORDER OF COURT AND NOW. Thursday, April 1.4, 2005 , upon consideration of the attached Complaint. it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. . the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on TuesdaY",I\:l,ay 10,2005 at 10:30 AM for a Pre-Hearing Custody Conference, At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or 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 herehy 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/ lacqueline M. Verney, Esq. + f1 Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990, For infonnation about accessible facilitics 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 HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET l.EGAL HELP, Cumberland County Bar Association 32 South Bedford Street Carlislc, Pcnnsylvania 170 I 3 Telephone (717) 249-3 166 , ~ d7F"t1-ZJ/f fir? ~"~"'J'!rI ~7 . S// J/./7 . . h :Z- ;&r..n# ,11l:~th ?V. :9/ f ~t?~~-p l' ~w ~ > f'7(J )'v 2;1 It "'. ,;' ,I' ~ I - \1i ~~ :2 \,\,::\ n t '.1 "'~) ~~\\\.7 ....!; ~..L~ __.V - . ".. .. RECEIVED MAY 11 7nn~ r" RANDI-BRUCE THICKEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2005-1854 CIVIL TERM JAMIE R. (TRICKEY) GRAHAM,: CIVIL ACTION - LAW Defendant : IN CUSTODY TEMPORARY ORDER OF COURT AND NOW, this · 2::-IL day of consideration of the attached Custody Conciliation Re follows: ,2005, upon rt, it is ordered and directed as cc: Keith O. Brenneman, Esquire, Counsel for other \ UMa~ Jane Alexander, Esquire, Counsel for Father I - (- -, - ~, I. The Father, Randi-Bruce Thickey, and the Mother, shall have shared legal custody of Makayla K. Thickey, born August 26, 2000. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions IIffecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. This means that both parents shall be entitled to all medical and educational informaion. 2. Mother shall have primary physical custody of the Child. 3. Beginning Saturday, May 14,2005, Father shall have periods of partial physical custody every Saturday from 6:45 p.m. to Tuesday at 7:00 a.m. when Father will drop off the child at the babysitter's. 4. Father shall be responsible for all transportation. 5. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference is scheduled for June 13, 2005 at 9:30 a.m. BY THE COURT, J. .~ 5./30{ I' J\... 6 ~ .11 :::t(, . I "\ ; HIJ enD} t.. " .1::Jl ..... "_. ".!:i"'l }'Lc.. lO' _.1 ; .I".j , " RANDI-BRUCE TRICKEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : 2005-1854 CIVIL TERM JAMIE R. (TRICKEY) GRAHAM,: CIVIL ACTION - LAW Defendant : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: ,)-IQ ~()S Date acq ine M. Verney, Esquire Custody Conciliator .~ JI~ NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Makayla K. Thickey August 26, 2000 Mother 2. A Conciliation Conference was held in this matter on May 10, 2005, with the following in attendance: The Father, Randi-Bruce Thickey, with his counsel, Keith 0, Brenneman, Esquire, and the Mother, Jamie R. (Thickey) Grrham, with her counsel, Jane Alexander, Esquire. 3. The parties agreed to an Order in the form liS attached. RANDI-BRUCE THICKEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v 05-1854 CIVIL TERM CIVIL ACTION - LAW JAMIE R. (THICKEY) GRAHAM,: Defendant IN CUSTODY IN RE: COMPLAINT FOR CUSTODY ORDER OF COURT AND NOW, this 10th day of October, 2005, upon consideration of the Plaintiff's Complaint for Custody with respect to the parties' child, Makayla K. Thickey (date of birth, August 26, 2000), and following a hearing held on this date, the record is declared closed, and the matter is taken under advisement. By the Court, ~ith O. Brenneman, Esquire 44 West Main Street Mechanicsburg, PA 17055 ~ For Plaintiff ~ne M. Alexander, Esquire 148 S. Baltimore Street Dillsburg, PA 17019 For Defendant :mae ~ l2\ ?~,}~ t':- '\~:- ,_"I C.: ~JC~;! u.--'- F 0- o - - ,:;, - - {,_J o u~ (;--;;.-;J c::.-~ ,_..1 ';.') ;,.., '...,J - RANDI-BRUCE TRICKEY, Plaintiff IN TRE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v 05-1854 CIVIL TERM CIVIL ACTION - LAW JAMIE R. (TRICKEY) GRAHAM,: Defendant IN CUSTODY IN RE: COMPLAINT FOR CUSTODY ORDER OF COURT AND NOW, this 11th day of October, 2005, upon consideration of Plaintiff's Complaint for Custody with respect to the parties' child, Makayla K. Thickey (d.o.b. August 26, 2000), following a hearing held on October 10, 2005, and based upon the Court's conclusion as to the best interest of the child, it is ordered and directed as follows: 1. Legal custody of the child shall be shared by the parties; 2. Primary physical custody of the child shall be in Defendant, the mother; 3. Temporary or partial physical custody of the child shall be in Plaintiff, the father, at the following times: a. During the school year, 1. Every weekend from Friday at 8:45 p.m. to Sunday at 8:30 p.m., unless Defendant notifies Father two weeks in advance, in which case she may have one C'\ o N ~.;..- C_ !~ t..) o ~-'" ~ (3 - ~---- weekend per month; 2. On Thanksgiving Day, from 2:00 p.m. until 8:30 p.m.; 3. From Christmas Day at 2:00 p.m. until December 30, at 8:30 p.m. b. During the summer, for alternating two-week periods; 4. Transportation for exchanges of custody shall be the responsibility of the party receiving custody; and 5. Nothing herein is intended to preclude the parties from deviating from the custodial terms of this order by mutual agreement. By the Court, ()j~ J. ~th O. Brenneman, Esquire 44 West Main Street Mechanicsburg, PA 17055 For Plaintiff :mae ~ne M. Alexander, Esquire 148 S. Baltimore Street Dillsburg, PA 17019 For Defendant