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HomeMy WebLinkAbout05-2463 GEORGE THOMAS TAYLOR, VI, Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. JOYVON DAVIS, Defendant IN THE COURT OF COMMON PLEAS OF NO. 05- Z y lp 3 CIVIL TERM CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is George Thomas Taylor, VI, hereinafter referred to as Father. Father's permanent residence is 1823 Park Street, Harrisburg, Dauphin County, Pennsylvania 17103. 2. The defendant is Joyvon Davis, hereinafter referred to as Mother, residing at 2206 Cedar Run Drive - Apartment K, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Father seeks a schedule for periods of partial custody of the minor child: Name George Thomas Taylor, VII Present Residence 2206 Cedar Run Drive Apartment K Camp Hill, PA 17011 The child was born out of wedlock. The child is presently in the custody of Mother. Age 12/1/01 DOB, 3 % years old 4. During the child's lifetime, he has resided with the following persons and at the following addresses: Name Address Date George Thomas Taylor, VI 2206 Cedar Run Drive birth - 1/8/04 Joyvon Davis Apartment K Jaquaya Davis Camp Hill, PA 17011 Joyvon Davis 2206 Cedar Run Drive 1/8/04 - present Jaquaya Davis Apartment K Camp Hill, PA 17011 5. The Father currently resides with the following persons: Name Relationship Mary Hoffman Mother Tony McNeill, Sr. Stepfather Tony McNeill, Jr. Brother Elijah McNeill Nephew 6. It is believed that Mother currently resides with the following persons: Name Relationship Jaquaya Davis Daughter George Thomas Taylor, VII Son with Father 7. Father has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 8. Father has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 9. Father does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 10. The best interest and permanent welfare of George will be served by granting the relief requested for reasons including, but not limited to the following: a) Father has a stable home environment that is safe and appropriate for periods of partial physical custody with George. b) Father lives with his family and they are willing to open their home to George during periods of partial custody. c) Prior to leaving the home he shared with Mother, Father was present to help care for George since his birth. d) Father is willing to communicate with and work cooperatively with Mother to co-parent George and will encourage both the mother/son and father/son relationships. e) Since January 2005, Mother has allowed Father about seven (7) opportunities to have George for weekend visits and Father has accepted each of those opportunities to spend time with his son. f) Father's prior involvement with George while he lived in Mother's home enables him to provide all necessary and appropriate care for George while he is in Father's care. g) Mother has not acted in the best interest of George in ways including but not limited to the following: i) Mother has denied Father regular contact with George, and when Mother does allow Father to exercise weekend custody of George, it is sporadic and inconsistent. ii) Mother prevents the healthy development of a bond between Father and George by refusing to allow them to have regular contact with each other. iii) Father fears that without a custody order in place, Mother will continue to deprive him of regular contact with George, which will cause difficulty in trying to maintain a father/son relationship. It. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child, have been named as parties to this action. WHEREFORE, the Father requests this Court to grant the following relief: a) Grant the parties shared legal custody of the child. b) Grant Mother primary physical custody of the child c) Grant Father periods of partial custody: 1. Alternating weekends from Friday at 3:00 p.m. until Sunday at 10:00 p.m. 2. Every Tuesday and Thursday evening from 6:00 p.m. until 9:00 p.m. d) Establish an appropriate holiday schedule to allow each parent time with the child. e) Any additional relief this Court finds just and proper. Jessica D famondstone, Esquire Mid Penn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 • VERIFICATION The above-named PLAINTIFF, GEORGE THOMAS TAYLOR, VI, verifies that the statements made in the above Complaint For Custody are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: GEORGE Y OMAS TAY OR, VI GEORGE THOMAS TAYLOR, VI, Plaintiff vs, JOYVON DAVIS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05- CIVIL TERM CUSTODY AFFIDAVIT OF SERVICE BY MAIL I, Jessica Diamondstone, do hereby swear that I served Joyvon Davis with a Complaint For Custody on GL 2005 by certified mail, return receipt, restricted delivery, to the person and address below: Joyvon Davis 2206 Cedar Run Drive Apartment K Camp Hill, PA 17011 I, Jessica Diamondstone, verify that the statements made in this Affidavit of Service 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 unsworn falsification to authorities. Date: cs? l?5 Si ature: z`? C 7 co Ir r -t1 H ? r1 J r1i 'i C? GEORGE THOMAS TAYLOR, VI, Plaintiff JOYVON DAVIS, To the Prothonotary: vs. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05- aq(j CIVIL TERM CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow, George Thomas Taylor, VI, to proceed in forma ap Ueris. I, Jessica Diamondstone, attorney for the party proceeding in forma oauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Jessica Diondstone'E MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 /`" : ? ? _t ? ?' r?: . it-` ?_ _. Ci+ i _, ? .,_ GEORGE THOMAS TAYLOR, VI IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JOYVON DAVIS DEFENDANT 05-2463 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NO W, Tuesday. May 17, 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 Thursday, June 09, 2005 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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 hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: !s/ Jacqueline M, Verney, EsT. -__ 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 in'iformation 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 schedules 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 4wvv p J RECEIVED JUN 13 2005 011 GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-2463 CIVIL TERM JOYVON DAVIS, : CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this ! 1-1 day of 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Custody Conciliation Conference scheduled for June 9, 2005 at 9:30 a.m. is hereby continued until June 28, 2005 at 8:30 a.m. BY THE COURT, cc ssica Diamondstone, Esquire, Counsel for Father ,,Joyvon Davis, pro se 2206 Cedar Run Drive Apt Camp Hill, PA 17011 p RECEIVED JUN 13 2005 e GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. JOYVON DAVIS, 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 : 2005-2463 CIVIL TERM CIVIL ACTION - LAW litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF George Thomas Taylor, VII December 1, 2001 Mother 2. A Conciliation Conference was held in this matter on June 9, 2005, with the following individuals in attendance: The Father, George Thomas Taylor, VI, with his counsel, Jessica Diamondstone, Esquire, Mid Penn Legal Services. Mother, Joyvon Davi, did not appear and it was determined that proper service of the complaint had not been perfected. 3. Father's counsel requested a continuance and the scheduling of another Conciliation Conference. Date acqu ine M. Verney, Esquire Custody Conciliator ?? ?-? e r-- :ain c? r7 ? ' ?' - ` .?. ? ?.. C ? ' 7 = i ?i ??GY u Lri ?._ '„ .. ?4(J _ =? LLi u_ u? c ?. c?+ 0 GEORGE THOMAS TAYLOR, VI, Plaintiff VS. JOYVON DAVIS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-2463 CIVIL TERM CUSTODY CERTIFICATE OF SERVICE 1, , the undersigned, hereby state that I served a copy of: 1. A Complaint in Custody 2. An Order for a custody conciliation for June 9, 2005, at 9:30 a.m., and 3. An Order rescheduling the conciliation for June 28, 2005, at 8:30 a.m., in the above-captioned matter upon Defendant by handing the papers to c at the following address: 10a a q1 4tfr erJ Ff on the day of T 2005, at approximately S. 00 o'clock PM .m. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Ps.C.S. Section 4904, relating to unswom falsification to authorities. Date:6-an-05 N Sign ree Title 4 Address JUN 2 4 206 OUt?? ;:: - -- - on c_. rte" rn"r" k7'-F J! 7 S J RECEIVED JUN 2 8 2005-3" ,%I-- GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-2463 CIVIL TERM JOYVON DAVIS, : CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of ,? Ll a 6'., , 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, George Thomas Taylor, VI, and the Mother, Joyvon Davis, shall have shared legal custody of George Thomas Taylor, VII, born December 1, 2001. 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 his health, education and religion. The Mother shall have primary physical custody of the Child. The Father shall have the following periods of partial physical custody: A. Beginning July 7, 2005, from Thursday at 6:00 p.m. to Saturday at 10:00 a.m. and alternating weekly thereafter at the same times and days. B. On alternating weeks from Friday at 4:00 p.m. to Sunday at 4:00 p.m. and alternating weekly thereafter at the same times and days. C. Such other times as the parties agree. 4. Father shall be responsible for all transportation. 5. Thanksgiving shall be shared such that Mother shall always have physical custody of the Child from 9:00 a.m. to 3:00 p.m. and Father shall always have physical custody of the Child from 3:00 p.m. to 9:00 p.m. 6. Christmas shall be divided into two Blocks. Block A shall be from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block B shall be from 12:00 noon on Christmas Day to December 26 at 12:00 noon. Father shall have physical custody of the Child during Block A in odd numbered years and for Block B in even numbered years. Mother shall have physical custody of the Child during Block B in odd numbered years and Block A in even numbered years. - v • 4 c' ' x 7 c. Cal. t r:_ Y a r 7. Father shall be entitled to one full week of physical custody during the year from Friday to Friday, provided he give Mother 30 days prior notice. 8. Mother shall have physical custody of the Child on Mother's Day. Father shall have physical custody of the Child on Father's Day. 9. Neither party shall do or say anything or permit a third party to do or say anything that may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. 10. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. TV TT n" ? rTnT cc: Jessica Diamondstone, Esquire, Counsel Joyvon Davis, pro se 108 Balm Street Harrisburg, PA17103 L GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. JOYVON DAVIS, 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: 2005-2463 CIVIL TERM : CIVIL ACTION - LAIN 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF George Thomas Taylor, VII December 1, 2001 Mother 2. A Conciliation Conference was held in this matter on June 28, 2005, with the following individuals in attendance: The Father, George Thomas Taylor, VI, with his counsel, Jessica Diamondstone, Esquire, Mid Penn Legal Services. Mother, Joyvon Davis, did not appear although she was served with the complaint and notice of conference. 3. The honorable J. Wesley Oler, Jr. entered an Order of Court dated June 14, 2005 continuing the Conciliation Conference to June 28., 2005. 4. Father requested an Order in the form as attached. Date acq line M. Verney, Esquire Custody Conciliator GEORGE THOMAS TAYLOR, VI, Plaintiff/Petitioner V. JOYVON DAVIS, Defendant/Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-2463 CIVIL TERM IN CUSTODY PETITION FOR CONTEMPT AND MODIFICATION Petitioner, George Thomas Taylor, VI, by and through his counsel, MidPenn Legal Services, states the following: 1. Plaintiff/Petitioner, hereinafter referred to as Father, resides at 1823 Park Street, Harrisburg, Dauphin County, Pennsylvania 17103. 2. Defendant/Respondent, hereinafter referred to as Mother, resides at 2206 Cedar Run Drive - Apartment K, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The above-named parties are the natural parents of George Thomas Taylor, VII, born December 1, 2001. 4. The current Custody Order, attached as Exhibit "A" and incorporated herein by reference, is dated June 30, 2005. The Order, in pertinent part, grants the parties shared legal custody of George VII. Mother has primary physical custody with Father having periods of temporary physical custody every week either Thursday to Saturday or Friday to Sunday. 5. Mother has willfully disobeyed the Order in ways including, but not limited to, the following: a. Mother has made it difficult for Father to exercise his periods of physical custody by repeatedly changing the location where Father is to pick-up George VII. It has taken Father up to three (3) telephone calls and an hour of travel to get George VII for a custodial visit. b. On at least six (6) occasions, Father has not had a visit with George VII because Mother does not comply with the Order and Father cannot find Mother by telephone. c. On several occasions, Father's visits began late because he has spent extra time chasing Mother between Dauphin and Cumberland Counties trying to find her so he can pick up George VII. d. Mother fails to provide Father with information pertaining to legal custody of George VII. Father is not aware of doctor's appointments, pre-school or daycare information, or other pertinent medical information regarding George VII. 6. Mother is not acting in George VII's best interest for reasons including, but not limited to, the following: a. Mother has deliberately interfered with Father's partial physical custody of George VII, in ways set forth in Paragraph Five of this Petition for Contempt and Modification. b. Mother's interference with Father's periods of partial physical custody negatively impacts Father's attempt to develop a healthy father/son relationship with George VII. c. Mother's failure to advise Father of matters pertaining to legal custody of George VII, prevents Father from actively participating in a parental capacity and renders him unable to contribute to decisions regarding George VII's well-being. d. Father is concerned that Mother is using illegal substances while George VII, is in her care or when he is returned to her care following a weekend with Father. Father is familiar with Mother's behavior when she is under the influence of drugs and her recent behavior during a custody exchange caused Father some concern for George VIPs safety and well-being. Father is entitled to a modification of the current order, which is in George's best interest, for reasons including but not limited to the following: a. Father wants to maintain the relationship that he has established with George VII. At this young age, it is very important for George VII to have regular and ongoing contact with Father for his emotional well being and development. b. In Order to prevent the ongoing problems regarding custody exchanges, Father would like to have the receiving party provide transportation for George VII. On alternating Thursdays or Fridays, Father would pick up George VII from Mother and on alternating Saturdays or Sundays, Mother would get George VII at the end of Father's custodial period. c. To further prevent problems during custody exchanges and to ensure that his visits start on time, Father would like Mother to provide him with twenty-four (24) hours notice as to where she and George VII will be when it is time for Father to get George V II if they will not be at Mother's residence in Camp Hill. 8. It is unknown whether Defendant is represented and counsel for Plaintiff is unable to request concurrence for the relief requested in this Petition. WHEREFORE, Father respectfully requests the following: a. That this Court find Mother in contempt of the existing June 30, 2005, Court Order. b. That this matter be scheduled for a custody conciliation to modify the terms of the current custody Order. c. That Mother and Father continue to share legal custody of George VII. d. That Father continue to have periods of partial custody as outlined in the June 30, 2005, Order. e. That transportation responsibilities be modified so that the receiving party provides transportation. f. That Mother be required to provide Father with twenty-four (24) hours notice of where she and George VII will be when it is time for Father to begin his custodial periods. If Mother does not contact Father twenty-four (24) hours in advance, she is expected to be at her Camp Hill residence on time for the custody exchange when Father arrives to begin his custodial weekend. g. That Mother provide Father with all information relevant to legal custody to which he is entitled such as daycare/preschool information, doctor's visits, etc., in a timely manner. h. Any other relief this Court finds just and proper. Jessi a Holst, Esquire Mi enn Legal Services 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 RECEIVED JUN ? 3 me, " GEORGE THOMAS TAYLOR, V1, : IN THE COURT OF CONINION PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLV.NIA V. :NO. 2005-2403 CIVIL TERNI JOYVON DAVIS, : CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NO'W, this .30 day of 2005, upon consideration of the attached Custody Conc' iation Report, it is ordered and directed as follows: 1. The Father, George Thomas Taylor, VI, and the Mother, Jowon Davis, shall have shared legal custody of George Thomas Taylor, VII, born December 1, 2001_ 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 his health, education and religion. The Mother shall have primary physical custody of the Child. The Father shall have the following periods of partial physical custody: A. Beginning July 7, 2005, from Thursday at 6:00 p m. to Saturday at 10:00 a.m. and altemating weekly thereafter at the same times and days. B. On alternating weeks from Fridav at 4:00 p.m. tc Sunday at 4:00 p.m. and alternating weekly thereafter at the same times and days. C. Such other times as the parties agree. Father shall be responsible for all transportation. 5. Thanksgiving shall be shared such that Mother shall always have physical custody of the Child from 9:00 a.m. to 3:00 p.m. and Father shall always have physical custody of the Child from 3:00 p.m. to 9:00 p.m. 6. Christmas shall be divided into two Blocks. Block A shall be from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block B shall be from 12:00 noon on Christmas Day to December 26 at 12:00 noon. Father shall have physical custody of the Child during Block A in odd numbered years and for Block B in even numbered years. Mother shall have physical custody of the Child during Block B in odd numbered years and Block A in even numbered years. r3 i -) 11 7. Father shall be entitled to one full week of physical custody during the year from Friday to Friday, provided he give Mother 30 days prior notice. 8. Mother shall haves physical custody of the Child on Mother's Dav. Father shall have physical custody of the Child on Father's Day. 9. Neither party shall do or say anything or permit a third party to do or say anything that may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. 10. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, J. cc: Jessica Diamondstone, Esquire, Counsel for Father Joy-von Davis, pro se 108 Balm Street Harrisburg, PA17103 s ?3?a4'=;a ?a.a t j ?t 0 GEORGE THOMAS TAYLOR VI, :IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COU',NTY, PENNSYLVANIA V. : 2005-2463 CIVIL TERM JOYVON DAVIS, : CIVIL ACTION-LAW 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: I . The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF George Thomas Taylor, VII December 1, 2001 Mother 2. A Conciliation Conference was held in this matter on June 28, 2005, with the following individuals in attendance: The Father, George Thomas Taylor, VI, with his counsel, Jessica Diamondstone, Esquire, Mid Penn Legal Services. Mother, Joyvon Davis, did not appear although she was served with the complaint and notice of conference. 3. The honorable J. Wesley Oler, Jr. entered an Order of Court dated June 14, 2005 continuing the Conciliation Conference to June 28, 2005. 4. Father requested an Order in the form as attached. Date acq line M. Verney, Esquire ,,/ Custody Conciliator VERIFICATION The above-named PLAINTIFF, GEORGE THOMAS TAYLOR, VI, verifies that the statements made in the above Petition for contempt and modification are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: GEORGE TWOMAS TAYL , VI 11 GEORGE THOMAS TAYLOR, VI, Plaintiff/Petitioner v. JOYVON DAVIS, Defendant/Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-2463 CIVIL TERM IN CUSTODY CERTIFICATE OF SERVICE I, Jessica Holst, Esquire, of MidPenn Legal Services, attorney for Plaintiff, George Thomas Taylor, VI, hereby certify that I have served a copy of the forgoing Petition for Contempt and Modification on the following date and in the manner indicated below: U.S. First Class Certified Mail, Return Receipt, Restricted Delivery Joyvon Davis 2206 Cedar Run Drive - Apartment K Camp Hill, PA 17011 Date: / / Je ica Fltflst, Esquire idPenn Legal Services 401 East Louther Street Carlisle, PA 17013 (717)243-9400 r' ^.i j-'r, VJ V C_J 4 GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 05-2463 CIVIL TERM JOYVON DAVIS, Defendant/Respondent : IN CUSTODY To the Prothonotary: PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow, George Thomas Taylor, VI, Plaintiff, to proceed in forma au eri s. I, Jessica Holst, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Jess a l4olst, Esquire 'dPenn Legal Services 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 -ri { G -.. GEORGE THOMAS TAYLOR, VI IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY. PENNSYLVANIA V. JOYVON DAVIS DEFENDANT 05-2463 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, January-24,2006 __, 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, February 14, 2006 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 hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Belief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ ac ueGne M. Vemey Es l r Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of' 1990. For information about accessible tacilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 c:?i'y?-1J- j? ? /'?f/'"'?? ?'???? •?V - %1 Cam. /? ?? ? ?2 ?D?h?l G-i ?- l y GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-2463 CIVIL ACTION - LAW JOYVON DAVIS, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 215 r day of -Fe L 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated June 30, 2005 shall remain in full force and effect with the following modifications to take effect the first weekend of March, 2006: 2. Transportation shall be shared such that the receiving party shall transport the Child. 3. Mother shall provide Father with twenty-four (24) hours prior notice of where she and the Child will be when it is time for Father to begin his custodial periods. In the event Mother does not contact Father twenty-four (24) hours in advance, she is expected to be at her Camp Hill residence on time for the custody exchange when Father arrives to begin his custodial weekend. 4. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. cc: Jessica Holst, Esquire, Counsel for Fathe Joyvon Davis, pro se 2206 Cedar Run Drive Apt. K Camp Hill, PA 17011 J? RV TFIR (YIT TRT ` ,J ?? i'?! L..3 ?' L? x, l _ cV i? GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff a CUMBERLAND COUNTY, PENNSYLVANIA V. :2005-2463 CIVIL ACTION - LAW : JOYVON DAVIS, 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 is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF George Thomas Taylor, VII December 1, 2001 Mother 2. A Conciliation Conference was held in this matter on February 16, 2006, with the following individuals in attendance: The Father, George Thomas Taylor, VI, with his counsel, Jessica Holst, Esquire, Mid Penn Legal Services. Mother, Joyvon Davis, did not appear although she was served with notice of the conference. 3. The Honorable J. Wesley Oler, Jr. entered an Order of Court dated June 30, 2005 providing for shared legal custody, Mother having primary physical custody and Father having two overnights each week with the child. 4. Father requested an Order in the form as attached. 'o Date JXcqu ine M. Verney, Esquire Custody Conciliator GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 05-2463 CIVIL TERM JOYVON DAVIS, Defendant/Respondent IN CUSTODY PETITION FOR CONTEMPT AND MODIFICATION Petitioner, George Thomas Taylor, VI, by and through his counsel, MidPenn Legal Services, states the following: 1. Plaintiff/Petitioner, hereinafter referred to as Father, resides at 3266 Rosstown Road - Unit 6, Wellsville, York County, Pennsylvania 17365. 2. Defendant/Respondent, hereinafter referred to as Mother, is believed to reside at 2206 Cedar Run Drive - Apartment K, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The above-named parties are the natural parents of George Thomas Taylor, VII, born December 1, 2001. 4. The current Custody Order, attached as Exhibit "A" and incorporated herein by reference, is dated February 21, 2006. The Order, in pertinent part, grants the parties shared legal custody of George VII. Mother has primary physical custody with Father having periods of temporary physical custody every week either Thursday to Saturday or Friday to Sunday. 5. The most recent Order was created to resolve problems that arose as a result of Mother's refusal to follow the prior Order dated June 30, 2005, which is attached hereto as Exhibit "B" 6. Mother has willfully disobeyed the current Order in ways including, but not limited to, the following: a. Mother continues to make it difficult for Father to exercise his periods of physical custody by repeatedly changing the location where Father is to pick-up George VII. It has taken Father up to three (3) telephone calls and an hour of travel to get George VII for a custodial visit. b. Since the February 20, 2006, Order, Father has been unable to see George VII on four of seven weekends as a direct result of Mother's actions. c. Father was most recently able to find Mother by driving from one end Harrisburg, Pennsylvania to the other end, Pennsylvania, looking for Mother's car. This was the only way Father was able to determine where George VII was during a weekend when he was supposed to be with Father. d. Mother has still failed to provide Father with information pertaining to the health and education of George VII. 7. Mother is not acting in George VIPs best interest for reasons including, but not limited to, the following: a. Mother has deliberately interfered with Father's partial physical custody of George VII, in ways set forth in Paragraph Six of this Petition for Contempt and Modification. b. Mother's interference with Father's periods of partial physical custody negatively impacts Father's attempt to develop a healthy father/son relationship with George VII. c. Mother's failure to advise Father of matters pertaining to legal custody of George VII, prevents Father from actively participating in a parental capacity and renders him unable to contribute to decisions regarding George VIPs well-being, d. Father is concerned that Mother is using illegal substances while George VII, is in her care. Father is entitled to a modification of the current order, which is in George's best interest, for reasons including but not limited to the following: a. Father wants to maintain the relationship that he has established with George VII. At this young age, it is very important for George VII to have regular and ongoing contact with Father for his emotional well being and development. b. Father has tried twice to establish an Order that provides him with sufficient periods of partial custody without imposing on Mother's custody or relationship with George VII. c. Despite the current Order's provisions regarding notice, Mother does not tell Father where she will meet Father for custody exchanges. These actions by Mother waste the financial resources of Father. d. Father is presently able to provide for George VII by giving him a nurturing and stable home environment and providing for his emotional, physical, medical and educational needs. e. Father's extended family and his fiancee's extended family are both willing and able to help with any needs that may arise while George VII is in Father's care and custody. f. Father and his fiancee have researched appropriate child care options that would be available for George VII if he were to live with Father on a primary basis. g. Father is concerned because he believes that George VII needs help with educational and speech development. Mother will not communicate with Father to address these concerns. If Father has primary custody, he will enroll George VII in Fleadstart or Preschool if these provide George VII with appropriate services. h. Father has repeatedly tried to communicate with and cooperate with Mother to effectively raise George VII. If Father were to become George VII's primary custodian, he would continue his efforts to work with Mother in raising George VII and would work to ensure that the mother/son relationship continues to develop. 8. It is unknown whether Defendant is represented and counsel for Plaintiff is unable to request concurrence for the relief requested in this Petition. WHEREFORE, Father respectfully requests the following: a. That this Court find Mother in contempt of the existing February 20, 2006, Court Order. b. That this matter be scheduled for a custody conciliation to modify the terms of the current custody Order, c. That Mother and Father continue to share legal custody of George VII. d. That Father be granted primary physical custody of George VII. c. That Mother be granted periods of partial physical custody of George VII on alternating weekends from Friday evening until Sunday evening. f. That the receiving party be responsible for providing transportation responsibilities for custody exchanges. g. That Mother provide Father with all information relevant to legal custody to which he is entitled such as daycare/preschool information, doctor's visits, etc., in a timely manner. h. Any other relief this Court finds just and proper. Je4ed Hoist, Esquire MidPenn Legal Services 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 VERIFICATION The above-named PLAINTIFF, GEORGE THOMAS TAYLOR, VI, verifies that the statements made in the above Petition for contempt and modification are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: GEORGE T)(OPFAS TAYy3R, VI GEORGE THOMAS TAYLOR, VI, Plaintiff V. JOYVON DAVIS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-2463 CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this / day of, c. 8 _ 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated June 30, 2005 shall remain in full force and effect with the following modifications to take effect the first weekend of March, 2006: 2. Transportation shall be shared such that the receiving party shall transport the Ghild. 3. Mother shall provide Father with twenty-four (24) hours prior notice of where she and the Child will be when it is time for Father to begin his custodial periods. In the event Mother does not contact Father twenty-four (24) hours in advance, she is expected to be at her Camp Hill residence on time for the custody exchange when Father arrives to begin his custodial weekend. 4. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions ofthis Order by mutual consent. In the absence of mutual consent, the terms of this Order shalt control. BY THE COURT, cc: Jessica Hoist, Esquire, Counsel for Father Joyvou Davis, pro se 2206 Cedar Run Drive Apt. K Camp Hill, PA 17011 CxNnt31? /? \l ? ) Lill, J. 4? GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2005-2463 CIVIL ACTION - LAW JOYVON DAVIS, 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 The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF George Thomas Tay toy, VII December 1, 200 t Mother 2. A Conciliation Conference was held in this matter on February 16, 2006, with the following individuals in attendance: The Father, George'Fhomas Taylor, VI, with his counsel, Jessica Holst, Esquire, Mid Pew Legal Services. Mother, Joyvon Davis, did not appear although she was served with notice of the conference. 3. "The Honorable J. Wesley Oler, Jr. entered an Order of Court dated June 30, 2005 providing for shared legal custody, Mother having primary physical custody and Father having two ovemights each week with the child. Father requested an Order in the form as attached. i Date JZcqu?line M. Verney, Esquire Custody Conciliator R?C?iV?u JU"I ? 3 iOG?'? GEORGE THOMAS TAYLOR, N 1, :IN TIME COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 2005-2t63 CIVIL TERM JOYVON DAVIS, : CIVIL ACTION- LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this _3 upon consideration of the attached Custody Conctliation Report, it is ordered and directed as follows: I. The Father, George Thomas Taylor, VI, and the Mother, Jowon Davis, shall have shared legal custody of George Thomas Taylor, VII, born December 1, 2001 Each parent shall have an equal right, to be erercisedjointly 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 his health, education and religion. 2. The Mother shall have primary physical custody of the Child. 3. The Father shall have the following periods of partial physical custody: A. Beginning July 7, 2005, from Thursday at 6:00 p-m. to Saturday at 10:00 a-m and alternating weekly thereafter at the same times and days. B. On alternating weeks from Friday at 4:00 p in, to Sunday at 400 p.m - and alternating weekly thereafter at the same times and days. C. Such other times as the parties agree. 4. Father shall be responsible for all transportation. 5. Thanksgiving shall be shared such that Mother shall always have physical custody of the Child from 9:00 a_in. to 3.00 p m. and Father shall always have physical custody of the Child from 3:00 p.m. to 9:00 p.m. 6. Christmas shall be divided into two Blocks. Block A shall be from Christmas Eve at 12:00 noon to Christmas Day at 12 00 noon. Block B shall be from 12.00 noon on Christmas Day to December 26 at 12:00 noon. Father shall have physical custody of the Child during Block A in odd numbered years and for Block B in even numbered years. Mother shall have physical custody of the. Child during Block B in odd numbered years and Block A in even numbered years. t xl--/1?3 / "7 Q Z Father shall be entitled to one full week of physical custody during the year from Friday to Friday, provided he give Mother 30 days prior notice 8. Mother shall have physical custody of the Child on Mothers Day. Father shalt hate physical custody of the Child on Eather's Day. 9. Neither party shalt do or say anything or permit a third parry to do or say anything that may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Chitd's love and respect for the other parent. 10- This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, is ? jyz?= r ??- J. cc? Jessica Diamondstone, Esquire, Counsel for Father Joyvon Davis, pro se 108 Balm Street Harrisburg, PA17103 In ? dytilvl+ ? '? •? •? 9y §t9 oYr _^ °? d d J ?'o S GEORGE THOMAS TAYLOR, VI, Plaintiff V. JOYVON DAVIS, Defendant IN THE COURT OF COVINION PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2005-2463 CIVIL TERM CIVIL ACTION - LAVV IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUNIBERLAND 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 1i6,gation is as follows: NAME DATE OF BIRTH CURRENTLY F CUSTODY OF George Thomas Taylor, VII December 1, 2001 Mother 1 A Conciliation Conference was held in this matter on June 28, 2005, with the following individuals in attendance: The Father, George Thomas Taylor, VI, with his counsel, Jessica Diamondstone, Esquire, Mid Penn Legal Services. Mother, Joyvon Davis, did not appear although she was served with the complaint and notice of conference. 3. The honorable J. Wesley Oler, Jr. entered an Order of Court dated Tune 14, 2005 continuing the Conciliation Conference to June 28, 2005, - 4- Father requested an Order in the form as attached i Date acgi3eline M;Verney, Esquire Custody Conciliator GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 05-2463 CIVIL TERM JOYVON DAVIS, Defendant/Respondent IN CUSTODY CERTIFICATE OF SERVICE I, Jessica Holst, Esquire, of MidPenn Legal Services, attorney for Plaintiff, George Thomas Taylor, VI, hereby certify that I have served a copy of the forgoing Petition for Contempt and Modification by: U.S. First Class Certified Mail, Return Receipt, Restricted Delivery and by Personal Service to: Joyvon Davis 2206 Cedar Run Drive - Apartment K Camp Hill, PA 17011 Date: I i 3 a f' 401 East Louther Street Carlisle, PA 17013 (717)243-9400 C GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 05-2463 CIVIL TERM JOYVON DAVIS, Defendant/Respondent IN CUSTODY To the Prothonotary: PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow, George Thomas Taylor, VI, Plaintiff, to proceed in forma ap uperis. I, Jessica Hoist, attorney for the party proceeding in forma ap uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Jes cK Hoist, Esquire M' Penn Legal Services 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 GEORGE THOMAS TAYLOR, VI IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JOYVON DAVIS DEFENDANT 05-2463 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Tuesday, May 092 2006 , upon consideration of the attached. Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, June 08, 2006 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 hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Jacqueline M. Verney, Esq. 1k Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 4z77 jl?V,-2 -fw-? '?/P ,sip -.q? q0? * 00 :Z Wd 01 IN 9002 MViONOrHiOdd 3H130 3X40-UTA GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 2005-2463 CIVIL TERM JOYVON DAVIS, : CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this _ d6y of J 4r a 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of Court dated June 30, 2005 and February 21, 2006 are hereby vacated. 2. The Father, George Thomas Taylor, VI, and the Mother, Joyvon Davis, shall have shared legal custody of George Thomas Taylor, VII, born December 1, 2001. 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 his health, education and religion. Pursuant to the terms of Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 3. The Mother shall have primary physical custody of the Child. 4. The Father shall have periods of partial physical custody every week from Thursday at 6:00 p.m. to Sunday at 6:00 p.m. 5. Transportation shall be shared such that the receiving party shall transport. ? ;_ ?. ?; _. - -; ?:? `, ?? .:. • , _ y : = ; ` - _„ «_ c:; ._ 6. Thanksgiving shall be shared such that Mother shall always have physical custody of the Child from 9:00 a.m. to 3:00 p.m. and Father shall always have physical custody of the Child from 3:00 p.m. to 9:00 p.m. 7. Christmas shall be divided into two Blocks. Block A shall be from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block B shall be from 12:00 noon on Christmas Day to December 26 at 12:00 noon. Father shall have physical custody of the Child during Block A in odd numbered years and for Block B in even numbered years. Mother shall have physical custody of the Child during Block B in odd numbered years and Block A in even numbered years. 8. Father shall be entitled to one full week of physical custody during the year from Friday to Friday, provided he give Mother 30 days prior notice. 9. Mother shall have physical custody of the Child on Mother's Day beginning at 9:00 a.m. 10. Neither party shall do or say anything or permit a third party to do or say anything that may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. 11. Father may litigate his allegations of contempt in the event Mother fails to abide by this Court Order. 12. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference is scheduled for September 21, 2006 at 8:30 a.m. BY THE COURT, Wesley OIdP4r., " " J. coc ica Holst, Esquire, Counsel for ?Joyvon Davis, pro se 3226 N. 6`h Street Harrisburg, PA 17110 A 01J / 9 ,04 rcwr I! ! V r?" JUN H06 GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. JOYVON DAVIS, 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: :2005-2463 CIVIL TERM : CIVIL ACTION - LAW 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF George Thomas Taylor, VII December 1, 2001 Mother 2. A Conciliation Conference was held in this matter on June 22, 2006, with the following individuals in attendance: The Father, George Thomas Taylor, VI, with his counsel, Jessica Hoist, Esquire, Mid Penn Legal Services and Mother, Joyvon Davis, pro se. 3. The Honorable J. Wesley Oler, Jr. entered Orders of Court dated June 30, 2005 and February 21, 2006 providing for shared legal custody, Mother having primary physical custody, with Father having every weekend. 4. The parties agreed to an Order in the form as attached. 6-22 -Ula l4." Date aacquMine M. Verney, Esquire Custody Conciliator Y SEP 2 1 2006 GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-2463 CIVIL TERM JOYVON DAVIS, : CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of d 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated June 27, 2006 shall remain in full force and effect with the following modifications and additions. 2. Paragraph 3 shall be deleted in its entirety and replaced with the following: Father shall have periods of partial physical custody every week from Friday at 6:00 p.m. to Sunday at 6:00 p.m. Father's times shall be extended to start on Thursday and to extend to Monday in the event of a school holiday or in-service day, or if Father can arrange to transport the child to school on Monday mornings. 3. Paragraph 8 shall be deleted in its entirety and replaced with the following: Each party shall be entitled to two (2) non-consecutive weeks of uninterrupted physical custody during the year provided they give the other party 30 days prior notice and they provide a location and telephone number where the child will be if he is to be removed from the jurisdiction. 4. Easter shall be shared such that Father shall always have physical custody of the Child from 9:00 a.m. to 3:00 p.m. and Mother shall always have physical custody of the Child from 3:00 p.m. to 9:00 p.m. 5. Memorial Day, July 4th and Labor Day shall be alternated by the parties. Father shall have physical custody for Memorial Day 2007 and the parties shall alternate thereafter. 6. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. ? _i t ? cc: 7on Holst, Esquire, Counsel for Fathe J Davis, pro se 3226 N. 6th Street Harrisburg, PA 17110 v? A i0"Oq-00 RV TUIF (Y)T TV T GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :2005-2463 CIVIL ACTION - LAW JOYVON DAVIS, 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 is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF George Thomas Taylor, VII December 1, 2001 Mother 2. A Conciliation Conference was held in this matter on September 21, 2006, with the following individuals in attendance: The Father, George Thomas Taylor, VI, with his counsel, Jessica Holst, Esquire, Mid Penn Legal Services. Mother, Joyvon Davis, did not appear. 3. The Honorable J. Wesley Oler, Jr. entered an Order of Court dated June 27, 2006 providing for shared legal custody, Mother having primary physical custody, with Father having partial physical custody every weekend. 4. Father requested an Order in the form as attached. g-z1-0? Date acq line M. Verney, Esquire Custody Conciliator LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff BY: Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 3800 Market Street Camp Hill, PA 17011 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: Isaylor@pjrlaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE THOMAS TAYLOR, VI, Plaintiff VS. No. 05-2463 CIVIL TERM JOYVON DAVIS, Defendant IN CUSTODY PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF CUSTODY ORDER The Petition of George Thomas Taylor, V1 respectfully represents: 1. That on October 2, 2006, Judge J. Wesley Oler, Jr. entered an Order modifying Order of Court Dated June 27, 2006, awarding Petitioner partial custody of the minor child: George Thomas Taylor, VII. A true and correct copy of the orders are attached to this petition. 2. Respondent has willfully failed to abide by the order in that Respondent has: a. Defendant made the minor child unavailable ten (10) weeks out of the twenty-two (22) weeks since the October 2, 2006 Order was entered; and b. Failed to pick up the child at the scheduled time eight (8) out of twelve (12) weeks Petitioner had custody of the minor child since the October 2, 2006, Order was entered. 3. Father has incurred substantial counsel fees and costs as a result of Mother's Contempt. 4. Mother should be responsible for Father's reasonable counsel fees and costs. 5. It is unknown whether Defendant is represented and counsel for Plaintiff is unable to request concurrence for the relief requested in this Petition. 6. J. Wesley Oler, Jr. has entered all previous Orders in this matter. WHEREFORE, Petitioner requests that Respondent be held in contempt of court and primary custody be awarded to Father, as well as counsel fees, costs and expenses, and any other relief this Court finds appropriate. Respectfully submitted, LAW O EICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff Peter J. Russo, Esquire ID No. 72897 Scott A. Stein, Esquire ID No. 81738 ,Elizabeth J. Saylor, Esquire ID No. 200139 Date: 3 - s -- u'7 ' SEP2?,2006 GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-2463 CIVIL TERM JOYVON DAVIS, : CIVIL ACTION LAW Defendant IN CUSTODY ORDER OF COURT ?a 10 AND NOW, this day of (go- , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated June 27, 2006 shall remain in frill force and effect with the following modifications and additions. 2. Paragraph 3 shall be deleted in its entirety and replaced with the following: Father shall have periods of partial physical custody every week from Friday at 6:00 p.m. to Sunday at 6:00 p.m. Father's times shall be extended to start on Thursday and to extend to Monday in the event of a school holiday or in-service day, or if Father can arrange to transport the child to school on Monday mornings. 3. Paragraph 8 shall be deleted in its entirety and replaced with the following: Each party shall be entitled to two (2) non-consecutive weeks of uninterrupted physical custody during the year provided they give the other party 30 days prior notice and they provide a location and telephone number where the child will be if he is to be removed from the jurisdiction. 4. Easter shall be shared such that Father shall always have physical custody of the Child from 9:00 a.m. to 3:00 p.m. and Mother shall always have physical custody of the Child from 3:00 p.m. to 9:00 p.m. 5. Memorial Day, July 4th and Labor Day shall be alternated by the parties. Father shall have physical custody for Memorial Day 2007 and the parties shall alternate thereafter. 6. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. cc: Jessica Holst, Esquire, Counsel for Fathe Joyvon Davis, pro se 3226 N. 6th Street Harrisburg, PA 17110 TRU CO 'Fly oTocz.fiMppy " ? set p E RECORD o ;et my haW Pao TY7 TT TT !'illT iTI T' GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :2005-2463 CIVIL ACTION - LAW JOYVON DAVIS, 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 is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF George Thomas Taylor, VII December 1, 2001 Mother 2. A Conciliation Conference was held in this matter on September 21, 2006, with the following individuals in attendance: The Father, George Thomas Taylor, VI, with his counsel, Jessica Holst, Esquire, Mid Penn Legal Services. Mother, Joyvon Davis, did not appear. 3. The Honorable J. Wesley Oler, Jr. entered an Order of Court dated June 27, 2006 providing for shared legal custody, Mother having primary physical custody, with Father having partial physical custody every weekend. 4 Father requested an Order in the form as attached. Date acq line M. Verney, Esquire Custody Conciliator r GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 2005-2463 CIVIL TERM JOYVON DAVIS, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, this X?AdayofkJ11fY1V , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of Court dated June 30, 2005 and February 21, 2006 are hereby vacated. 2. The Father, George Thomas Taylor, VI, and the Mother, Joyvon Davis, shall have shared legal custody of George Thomas Taylor, V11, born December 1, 2001. 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 his health, education and religion. Pursuant to the terms of Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, derital, religious or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to frill participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 3. The Mother shall have primary physical custody of the Child. 4. The Father shall have periods of partial physical custody every week from Thursday at 6:00 p.m. to Sunday at 6:00 p.m. 5. Transportation shall be shared such that the receiving party shall transport. 6. Thanksgiving shall be shared such that Mother shall always have physical custody of the Child from 9:00 a.m. to 3:00 p.m. and Father shall always have physical custody of the Child from 3:00 p.m. to 9:00 p.m. 7. Christmas shall be divided into two Blocks. Block A shall be from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block B shall be from 12:00 noon on Christmas Day to December 26 at 12:00 noon. Father shall have physical custody of the Child during Block A in odd numbered years and for Block B in even numbered years. Mother shall have physical custody of the Child during Block B in odd numbered years and Block A in even numbered years. 8. Father shall be entitled to one full week of physical custody during the year from Friday to Friday, provided he give Mother 30 days prior notice. 9. Mother shall have physical custody of the Child on Mother's Day beginning at 9:00 a.m. 10. Neither party shall do or say anything or permit a third party to do or say anything that may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other- parent. 11. Father may litigate his allegations of contempt in the event Mother fails to abide by this Court Order. 12. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference is-, scheduled for September 21, 2006 at 8:30 a.m. BY THE COUR J. Wesley Oler, Jr., cc. Jessica Holst, Esquire, Counsel for Father Joyvon Davis, pro se 3226 N. 6th Street Harrisburg, PA 17110 J. 1 l1cfie Lvlo set my hang and nnot said Co rt at .ariisin, Pa. T1!.. ay F. R thonotary GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :2005-2463 CIVIL TERM JOYVON DAVIS, : CIVIL ACTION - LAW 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 is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF George Thomas Taylor, VII December 1, 2001 Mother 2. A Conciliation Conference was held in this matter on June 22, 2006, with the following individuals in attendance: The Father, George Thomas Taylor, VI, with his counsel, Jessica Holst, Esquire, Mid Penn Legal Services and Mother, Joyvon Davis, pro se. 3. The Honorable J. Wesley Oler, Jr. entered Orders of Court dated June 30, 2005 and February 21, 2006 providing for shared legal custody, Mother having primary physical custody, with Father having every weekend. 4. The parties agreed to an Order in the form as attached. Date acgt ine M. Verney, Esquire Custody Conciliator VERIFICATION I, George Thomas Taylor, VI, verify that the statements made in the forgoing document are true and correct to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. Dated: c"?7 CC' C'? sL.. ?_ George Th mas Taylor, Y CERTIFICATE OF SERVICE I, Janet E. Bush, hereby certify that I am on this day serving a copy of the Petition for Contempt and Modification upon the person(s) and in the manner indicated below: US Regular Mail and Certified US Mail, restricted delivery, return receipt requested #7006 0810 0006 1052 7654 and addressed as follows: Joyvon Davis, pro se 3226 N. 6th Street Harrisburg, PA 17110 Date: , S- /? ? 4. '14.. LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff BY: Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 3800 Market Street Camp Hill, PA 17011 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: Isaylor@pirlaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE THOMAS TAYLOR, VI, Plaintiff VS. JOYVON DAVIS, Defendant No. 05-2463 CIVIL TERM IN CUSTODY PETITION FOR CONTEMPT AND MODIFICATION Petitioner, George Thomas Taylor, VI, by and through his counsel, The Law Offices of Peter J. Russo, P.C., states the following: 1. Plaintiff/Petitioner, hereinafter referred to as Father, resides at 3266 Rosstown Road -- Unit 6, Wellsville, York County, Pennsylvania 17365. 2. Defendant/Respondent, hereinafter referred to as Mother, is believed to reside at 3226 N. 6t" Street, Harrisburg, PA 17110. 3. The above-named parties are the natural parents of George Thomas Taylor, VII, born December 1, 2001. 4. The current Custody Order, dated October 2, 2006, is attached as Exhibit "A" and incorporated herein by reference. 5. The October 2, 2006, Order of Court modifies the prior Order of Court dated June 27, 2006, which is attached as Exhibit "B" and incorporated herein by reference. 6. The October 2, 2006, Order of Court, in pertinent part, grants the parties shared legal custody of George VII. Mother has primary physical custody with Father having period of temporary physical custody every week Friday to Sunday. 7. The most recent Orders were created to resolve problems that arose as a result of Mother's repeated refusal to follow the prior Orders dated June 30, 2005, and February 21, 2006 which are attached hereto as Exhibit "C" and Exhibit "D". 8. Mother has willfully disobeyed the current Order in ways including, but no limited to, the following: a. Mother continues to make it difficult for Father to exercise his periods of physical custody by not having the child present when father arrives to receive custody. b. Since the October 2, 2006, Order Father has been unable to see George VII on ten (10) of the twenty-two (22) weekends as direct result of Mother's actions. c. Mother has failed to timely pick up the child from Father's residence, often resulting in Father having to transport the child to Mother's residence or to daycare the following morning. d. Mother has failed to timely pick up the child on eight (8) weekends out of the twelve (12) weekends father had custody of the child. 9. Mother is not acting in George VI1's best interest for reasons including, but not limited to, the following: a. Mother has deliberately interfered with Father's partial physical custody of George VII, in ways set forth in Paragraph Eight of this Petition for Contempt and Modification. b. Mother's interference with Father's periods of partial physical custody negatively impacts Father's attempt to develop a healthy father/son relationship with George VII. c. Since the October 2, 2006, George VII hasten (10) unexcused absences from preschool. 10. Father is entitled to a modification of the current order, which is in George VIPs best interest, for reason including but not limited to the following: a. Father wants to maintain the relationship that he has established with George VII. At this young age, it is very important for George VII to have regular and ongoing contact with Father for his emotional well being and development. b. Father has tried three times to establish an Order that provides him with sufficient periods of partial custody without imposing on Mother's custody or relationship with George VII. c. Mother continual failure to make the child available for pick up and/or to timely pick up the child has additionally wasted Father's financial resources and/or time, causing injury to Father as well as his wife and daughter. d. Father is presently able to provide for George VII by giving him a nurturing and stable home environment and providing for his emotional, physical, medical and educational needs. e. Father's extended family and his wife's extended family are both willing and able to help with any needs that may arise while George VII is in Father's care and custody. f. Father and his wife have researched appropriate child care options that would be available for George VII if he were to live with Father on a primary basis. g. Father is concerned because he believes that George VII needs help with educational and speech development. Mother will not communicate with Father to address these concerns. If Father has primary custody, he will enroll George VII in Headstart or Preschool if these provide George VII with appropriate services and will enroll George VII in Wellsville Elementary School in the fall. h. Father has repeatedly tried to communicate with and cooperate with Mother to effectively raise George VII. If Father were to become George VII's primary custodian, he would continue his efforts to work with Mother in raising George VII and would work to ensure that the mother/son relationship continues to develop. 11. It is unknown whether Defendant is represented and counsel for Plaintiff is unable to request concurrence for the relief requested in this Petition. 12. J. Wesley Oler, Jr. has entered all previous Orders in this matter. WHEREFORE, Father respectfully requests the following: a. That this Court find Mother in contempt of the existing October 2, 2006, Court Order. b. That this matter be scheduled for a custody conciliation to modify the terms of the current custody Order. c. That Mother and Father continue to share legal custody of George VII. d. That Father be granted primary physical custody of George VII. e. That Mother be granted periods of partial physical custody of George VII on alternating weekends from Friday evening until Sunday evening. f. That the receiving party be responsible for providing transportation responsibilities for custody exchanges. g. That Mother be responsible for reasonable counsel fees and cost. h. Any other relief this Court finds just and proper. Respectfully submitted, LAW O ICES°OF ER J. RUSSO, P.C. _ Elizabeth J. Saylor, Esquire Date: 3 ` ID No. 200139 EXHIBIT A i 5 E P 1. 2006 . GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. JOYVON DAVIS, Defendant :NO. 2005-2463 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this day of C , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated June 27, 2006 shall remain in full force and effect with the following modifications and additions. 2. Paragraph 3 shall be deleted in its entirety and replaced with the following: Father shall have periods of partial physical custody every week from Friday at 6:00 p.m. to Sunday at 6:00 p.m. Father's times shall be extended to start on Thursday and to extend to Monday in the event of a school holiday or in-service day, or if Father can arrange to transport the child to school on Monday mornings. 3. Paragraph 8 shall be deleted in its entirety and replaced with the following: Each party shall be entitled to two (2) non-consecutive weeks of uninterrupted physical custody during the year provided they give the other party 30 days prior notice and they provide a location and telephone number where the child will be if he is to be removed from the jurisdiction. 4. Easter shall be shared such that Father shall always have physical custody of the Child from 9:00 a.m. to 3:00 p.m. and Mother shall always have physical custody of the Child from 3:00 p.m. to 9:00 p.m. 5. Memorial Day, July 4`h and Labor Day shall be alternated by the parties. Father shall have physical custody for Memorial Day 2007 and the parties shall alternate thereafter. 6. This Order is entered pursuant to a Custody Conciliation Confefence. The parties may modify the provisions of this Order by mutual consent, In the absence of mutual consent, the terms of this Order shall control. cc: Jessica Holst, Esquire, Counsel for Fathe Joyvon Davis, pro se 3226 N. 6c" Street Harrisburg, PA 17110 i COPY Frlr?, M RECORD on set my hand T') N7 `TTTT7 nnT TT-) -P GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :2005-2463 CIVIL ACTION - LAW JOYVON DAVIS, . 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 is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF George Thomas Taylor, VII December 1, 2001 Mother 2. A Conciliation Conference was held in this matter on September 21, 2006, with the following individuals in attendance: The Father, George Thomas Taylor, VI, with his counsel, Jessica Holst, Esquire, Mid Penn Legal Services. Mother, Joyvon Davis, did not appear. 3. The Honorable J. Wesley Oler, Jr. entered an Order of Court dated June 27, 2006 providing for shared legal custody, Mother having primary physical custody, with Father having partial physical custody every weekend. 4. Father requested an Order in the form as attached. (?-z? -? Date acq line M. Verney, Esquire Custody Conciliator EXHIBIT B r r GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO, 2005-2463 CIVIL TERM JOYVON DAVIS, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, this X% day of \111 fn J , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as :follows: 1. The prior Orders of Court dated June 30, 2005 and February 21, 2006 are hereby vacated. 2. The Father, George Thomas Taylor, VI, and the Mother, Joyvon Davis, shalt have shared legal custody of George Thomas Taylor, VII, born December 1, 2001. 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 his health, education and religion. Pursuant to the terms of Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete; information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back--to-school nights, and the like. 3. The Mother shall have primary physical custody of the Child. 4. The Father shall have periods of partial physical custody every week from Thursday at 6:00 p.m. to Sunday at 6:00 p.m. 5. Transportation shall be shared such that the receiving party shall transport. 6. Thanksgiving shall be shared such that Mother shall always have physical custody of the Child from 9:00 a.m. to 3:00 p.m. and Father shall always have physical custody of the Child from 3:00 p.m. to 9:00 p.m. 7. Christmas shall be divided into two Blocks. Block A shall be from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block B shall be from 12:00 noon on Christmas Day to December 26 at 12:00 noon. Father shall have physical custody of the Child during Block A in odd numbered years and for Block B in even numbered years. Mother shall have physical custody of the Child during Block B in odd numbered years and Block A in even numbered years. 8. Father shall be entitled to one full week of physical custody during the year from Friday to Friday, provided he give Mother 30 days prior notice. 9. Mother shall have physical custody of the Child on Mother's Day beginning at 9:00 a.m. 10. Neither party shall do or say anything or permit a third party to do or say anything that may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. 11. Father may litigate his allegations of contempt in the event Mother fails to abide by this Court Order. 12. This Order is entered pursuant to a Custody Conciliation Conference. The patties may modify the provisions of this Order by mutual consent. In the absence of rnutual consent, the terms of this Order shall control. Another Conciliation Conference is-, scheduled for September 21, 2006 at 8:30 a.m. BY THE COURT CC Jessica Holst, Esquire, Counsel for Father Joyvon Davis, pro se 3226 N. 6th Street Harrisburg, PA 17110 11C-re tTica set my hand aril ; f said Co rt at adisie, Pa. T1 ..%3. /n?4,?... ay f. P thonotary GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :2005-2463 CIVIL TERM ,IOYVON DAVIS, Defendant PRIOR JUDGE: J. Wesley Oler, Jr., J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-$, the undersigned Custody Conciliator submits the following report: CIVIL ACTION - LAW IN CUSTODY 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF George Thomas Taylor, VII December 1, 2001 Mother 2. A Conciliation Conference was held in this matter on June 22, 2006, with the following individuals in attendance: The Father, George Thomas Taylor, VI, with his counsel, Jessica Holst, Esquire, Mid Penn Legal Services and Mother, Joyvon Davis, pro se. The Hoorable J. Wesley Oler, Jr. entered Orders of Court dated June 30, 3. n 2005 and February 21, 2006 providing for shared legal custody, Mother having primary physical custody, with Father having every weekend. 4. The parties agreed to an Order in the form as attached. 6-ZZ.-U6 Date / Ln = )acqtt ?ine M. Verney, Esquire Custody Conciliator EXHIBIT C GEORGE TIIOMAS TAYLOR, VI, : IN T AE COURT OF CONINION PLEAS OF Plaintiff : CUMBERLAND COUNT`, PENNS'?'LVANIA V. : NO. 2005-1-463 CIVIL, ACTION - LAW dOYVON DAVIS, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this day of , 2006, upon consideration of the attached Custody Conciliation Report, It is ordered and directed as follows: 1. The prior Order of Court dated June 30, 2005 shall remain in full force and effect with the following modifications to take effect the first weekend of March, 2006- 2. Transportation shall be shared such that the receiving party shall transport the,Child. 3. Mother shall provide Father with twenty-four (24) hours prior notice of where she and the Child will be when it is time for Father to begin his custodial periods. In the event Mother does not contact Father twenty-four (24) hours in advance, she is expected to be at her Camp Hill residence on ti.ine for the custody exchange when Father arrives to begin his custodial weekend. 4. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, L z .L I LI I J cc: Jessica Holst, Esquire, Counsel for Father Joyvon Davis, pro se 2206 Cedar Run Drive Apt. K Camp Hill, PA 17011 ?! `t to-, .,'t , .-T. GFORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2_005-2463 CIVIL ACTION - LAW JO Y-VOILA DAVIS, Defendant : IN CUSTODY PRI0I1" 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 inforTnation concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF George Thomas Taylor, VII December 1, 2001 Mother 2. A Conciliation Conference was held in this matter on February 16, 2006, with '!.llc following individuals in attendance: The Father, George Thornas Taylor, VI, with his counsel, Jessica Holst, .Esquire, Mid Perin Legal Services. Mother, Joyvon Davis, did not appear although she was served with notice of the conference. 3. The Honorable J. Wesley Oler, Jr. entered an Order of Court dated June 30. 2005 providing for shared legal custody, Mother having primary physical custody and Father having two overnibhts each week with the child. 4. Father requested an Order in the form as attached. i Date J?cquoine M. Verney, Esquire t Custody Conciliator EXHIBIT D _ R?Ili4 ?;?,?, Boa CEJR;JE TI-fOtiI.-?S T?Y?O??, ?,i, : Iii T?I? COtr-1;?T t?? ?+?ti1l?t?iy PLE?? 0 Plainfff CLtirBLRL? D COti`?TY, PEN?iS`rLti ??il,? . : N0. _005-24163 Clti TE tiI JO s'VON D `,`'IS, : CIVIL ACTION - LAW Defendant LN CUSTODY ORDER OF COURT Avid INOW, this `361 ` day. Or Ll ?? 2005 upon consideration of the attached Custody Conc cation. Report, it is ordered and directed as follows: 1. The Father, George "Thomas Taylor, V1, and the Mother, Joy-von Davis, shall have shared legal custody of George Thomas Taylor, VII, born December 1, 2001. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-einergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2 The N'lother shall have primary physical custody_of the Child. 3. The Father shall have the following periods of pa-tial physical custody: A. Beginning July 7, 2005, from Thursday at 6:00 p.m. to Saturday at 10:00 a_m. and alternating weekly thereafter at the same times and days. B. On alternating weeks front Friday at 4.00 p.m. to Sunday at 4:00 p.m. and alternating weekly thereafter at the same tunes and days. C. Such other tirr,.es as the parties agree. 4. Father shall be responsible for all transportation. 5. Thanksgiving shall be shared such that Mother shall always have physical custody of the Child from 9:00 a.m. to 3:00 p.m. and Father shall always have physical custody of the Child from 3:00 p.m. to 9:00 p.m. 6. Christmas shall, be divided into two Blocks. Block A shall be from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block B shall be from 12:00 noon on Christmas Day to December 26 at 12:00 noon. Father shall have physical custody of the Child during Block P, in odd numbered years and for Block B in even numbered years. Mother shall have physical custody of the Child during Bock B in odd numbered years and Block. A in even numbered years, i. Father AA be entitled [o or!, ±ull ? ttk of physRai custody- during the ?31- rrom 1 riday to Friday v' provided he gu""c 1""10thcC 30 days i?i1C r ;'ottce. 8_ Motor shall have physical custody of t:<<. Child on Mothers Day. Fathel- shail have physical custody of the Child on Father's Day. 9. Neither party shall do or say a.lything or permit a third party Lc do or say anything that may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. 10. This Order is entered pursuant to a Custody Conciliation Con.,:rence. The pariies may modify the provisions of this Carder u, ,nutual conscrlt. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, J. i 17 cc: Jessica Diamondstone, Esquire, Counsel for Father Joy-von Davis, pro se 108 Balm Street Harrisburg, PA17103 ilj A Kit/i.?., r.?.' ] ?' ? ?rY ,?.?' '..P? ?l j,y f'?? -Y }? f; ?. g .rUA tei? S'?,. GEC>f GI, 'i'HO~IAS "TAYLOR, 'VT, P4 THE, COURT OF CONIti40N' PLEAS OF Plaintiff : CU,MY:,ERL.?ND COI rT4', P?_?+,NSYLjr"ANIA V- 01"VOIN DA VIS, Defendant IN CUSTODY B100IZ JUDGE: J. Wesley Oler, Jr., J. CUSTODY CONCILIATION SUNINMARY RF,PORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 2005-34e3 CIVIL-HR-NI CIVIL ACTION - LAW 1. The pertinent information concerning the Child who is the subject of this litigation is as follows. NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF George Thomas Taylor, VII December 1, 2001 Nlot`ler 2. A Conciliation Conference was held in this matter on Jane 28, %005, ,,vIth the following individuals in atte.-ldance: The Father, George Thomas Taylor, Vl, with his counsel, Jessica Diamondstone, Esquire, Mid Penn Legal Services. Mother, Joy-,on Davis, did not appear although she was served with the complaint and notice of conference. 3. The honorable J, Wesley Oler, .ir. entered an Order of Court dated June 14, ?005 continuin; the Conciliation Conference to June 28, 2005, 4. Father requested an Order in the form as attached. Date ?. acq 'line Nl',Verney Esquire Custody Conciliator GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS Plain tiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. JOYN70N DAVIS, Defendant/Respondent NO. 05-2463 CIVIL TERM IN CUSTODY CERTIFICATE OF SERVICE I, Jessica Holst, Esquire, of MidPenn Legal Services, attorney for Plaintiff, George Thomas Taylor, VI, hereby certify that I have served a copy of the forgoing Petition for Contempt and Modification by: U.S. First Class Certified Mail, Return Receipt, Restricted Delivery and by Personal Service to: Joyvon Davis 2206 Cedar Run Drive - Apartment K Camp Hill, PA 17011 Date: Jessi/a Holst, Esquire Mid Penn Legal Services 401 East Louther Street Carlisle, PA 17013 (717)243-9400 VERIFICATION I, George Thomas Taylor, VI, verify that the statements made in the forgoing document are true and correct to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. 7 P s Dated: George Thomas aylor, VII CERTIFICATE OF SERVICE I, Janet E. Bush, hereby certify that I am on this day serving a copy of the Petition for Civil Contempt for Disobedience of Custody Order upon the person(s) and in the manner indicated below: US Regular Mail and Certified US Mail, restricted delivery, return receipt requested #7006 0810 0006 1052 7647 and addressed as follows: Joyvon Davis, pro se 3226 N. 6th Street Harrisburg, PA 17110 '? - -7 Date: J et E. Bush <_ .. ?.,_ o-? ?. g..: { GEORGE THOMAS TAYLOR, VI IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JOYVON DAVIS DEFENDANT 05-2463 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Thursday, March 08, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, March 29, 2007 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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 hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Jacqueline M. Verney Es q. Custody Conciliator 111 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For inforniation 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 4fv v- !z! r rS:01 14,1V ?1 ?"*tjlIL0az 0] 11j APR 08 2001,01( GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-2463 CIVIL ACTION - LAW JOYVON DAVIS, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 3c- day of ,, , 2007, upon consideration of the attached Custody Conciliati n Report, it is ordered and directed as follows: 1. A Hearing is scheduled in Court Room No. of the Cumberland County Court House, on the &-M day of , 2007, at 9 : 3 O o'clock, A. M., at which time testimony will be en. For purposes of this Hearing, the Mother 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 parry'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. Pending further Order of Court or agreement of the parties, the prior Orders of Court dated October 2, 2006 and June 27, 2006 shall remain in full force and effect with the following additional requirement. 3. The parties shall cooperate with a custody evaluation by an evaluator selected by Father. Father shall be responsible for all costs associated with the custody evaluation. 4. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. cc izabeth J. Saylor, Esquire, counsel for ?yvon Davis, pro se 3226 N. 6t` Street Harrisburg, PA 17110 BY THE COURT, k t Lr) LU {J4T i . Yi_? LL- r.L• ?° '1 y n. { { L 5.1.. E ? GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-2463 CIVIL ACTION - LAW JOYVON DAVIS, 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 is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF George Thomas Taylor, VII December 1, 2001 Mother 2. A Conciliation Conference was held March 29, 2007 with the following individuals in attendance: The Father, George Thomas Taylor, VI, with his counsel, Elizabeth J. Saylor, Esquire, and the Mother, Joyvon Davis, pro se. 3. The Honorable J. Wesley Oler, Jr. previously entered Orders of Court dated October 2, 2006 and June 27, 2006 providing for shared legal custody, Mother having primary physical custody and Father having every weekend. 4. Father's position on custody is as follows: Father seeks shared legal and primary physical custody. Father filed a Petition for Contempt and Modification claiming that Mother had failed to transfer the child 10 out of 22 weekends and failed to pick up the child at the conclusion of Father's custodial time 8 out of 12 weekends. Father asserts that the child has had 10 unexcused absences from his Headstart program. Father maintains that he is better able to provide a stable, nurturing environment for the child and abide by any order granting mother partial physical custody. Father requests a custody evaluation and will bear the full cost thereof. 5. Mother's position on custody is as follows: Mother seeks to maintain the status quo. She denies the allegations of contempt and has explanations for the child's unexcused absences. She further maintains that she does not always have access to a vehicle in which to pick up the child at the conclusion of Father's custodial period. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and maintaining the status quo. It is expected that the Hearing will require one day. . ?,,? Date Jaq line M. Verney, Esquire Custody Conciliator . i , 0 LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff BY: Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 3800 Market Street Camp Hill, PA 17011 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: Isgylor@pgrlaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE THOMAS TAYLOR, VI, Plaintiff VS. JOYVON DAVIS, Defendant No. 05-2463 CIVIL TERM : IN CUSTODY PETITION FOR EMERGENCY RELIEF SEEKING MODIFICATION OF ORDER DATED APRIL 3.2007 AND NOW, Petitioner, George Thomas Taylor, VI, by and through his counsel, The Law Offices of Peter J. Russo, P.C., states the following: 1. Plaintiff/Petitioner, hereinafter referred to as Father, resides at 211 Bailey Street, New Cumberland, Cumberland County, Pennsylvania, 17070. 2. Defendant/Respondent, hereinafter referred to as Mother, is believed to reside at 1607 Hillside VLG, Harrisburg, PA 17110. 3. Mother is not represented by counsel. 4. The above named parties are the natural parents of the following child: Name Present Residence DOB George Thomas Taylor, VII 1607 Hillside VLG December 1, 2001 Harrisburg, PA 17110 . # ` 5. Father filed a Petition for Contempt and Modification and a Petition for Civil Contempt for Disobedience of Custody Order simultaneously on March 7, 2007. 6. Father's said Petitions addressed the following two (2) violations of the Order: (a) Mother's failure to make the child unavailable ten (10) weeks out of the twenty- two (22) weeks since the October 2, 2006 Order of Court, and (b) Mother's failure to timely pick up the child eight (8) out of the twelve (12) weeks Father received custody since the October 2, 2006 Order of Court. 7. A conciliation was Ordered for March 29, 2007, before Jacqueline M. Verney, Esquire. 8. Following the conciliation an interim Order of Court, dated April 3, 2007, was entered by the Honorable Judge J. Wesley Oler, Jr. The April 3, 2007 Order is attached as Exhibit "A" and incorporated herein by reference. 9. The April 3, 2007 Order granted Mother primary physical custody and Father partial custody periods every weekend, with Father picking up the child at Mother's residence on Friday at 6:00 P.M. and Mother picking up the child at Father's residence on Sunday at 6:00 P.M. 10. Since the conciliation, Mother has violated the Order in the following manner: a) On March 30, 2007, just one (1) day following the conciliation hearing, Mother refused to relinquish custody of the child to Father; b) Mother failed to timely pick up the child on April 6, 2007, arriving thirty (30) minutes late on Easter Sunday, after informing Father she was not coming to get the child; c) Mother timely picked up child on May 15t' but then returned to Father's home and physically attacked Father's wife and dog, caused physical damage to Father's home, and only left the premises to evade the police who were called to the scene by Father's wife; d) Mother has further failed to have the child present for pick up on May 18th or 25tH, or June 1 St, 8th, 15th, 22"d, or 29th; and e) According to third parties, Mother has moved with child. 11. In summary, in the fourteen (14) weeks since the April 3, 2007, Order was entered: a) Mother has failed to relinquish custody of the child eight (8) of those weekends; b) Mother was late picking up the child on one (1) of the six (6) weekends Mother did relinquish custody of the child; and c) Mother is believed to have moved with child and has failed to inform Father as to their whereabouts. 12. It is unknown whether Defendant is represented and counsel for Plaintiff is unable to request concurrence for the relief requested in this Petition. 13. Judge J. Wesley Oler, Jr. has entered all previous orders in this matter. WHEREFORE, Defendant requests this Honorable Court to grant the Emergency Petition and grant Father primary custody of the child until further order of court following the July 25th hearing. In the alternative, Father requests that in the very least Mother again be ordered to abide by the current custody order, specifically that Mother exchange custody at the scheduled times and provide Father with her and child's current address. Respectfully submitted, THE LA FFICE OF PETER J. RUSSO, P.C. 7 T-o-7 By: Elizabeth J. ayIor, Esquire Date Attorney I.D. No. 20013 Attorneys for Defendant 3800 Market Street Camp Hill, PA 17011 Telephone: (717) 591-1755 Facsimile: (717) 591-1755 A ?__1 itt 9 1 :9 117 6- -T0r L0OZ ]Hi JO EXHIBIT A r ? APR 0 2 2007 GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 2005-2463 CIVIL ACTION - LAW JOYVON DAVIS, Defendant : IN CUSTODY ORDER OF OURT AND NOW, this f? day of , 2007, upon consideration of the attached Custody Conciliatio Report, it is ordered and directed as follows: 1. A Hearing is scheduled in Cou om No. , of the Cumberland County Court House, on the ? day of , 2007, at 9&0 o'clock, A. M., at which time testimony will bet in. For purposes of this Hearing, the Mother 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. Pending further Order of Court or agreement of the parties, the prior Orders of Court dated October 2, 2006 and June 27, 2006 shall remain in full force and effect with the following additional requirement. 3. The parties shall cooperate with a custody evaluation by an evaluator selected by Father. Father shall be responsible for all costs associated with the custody evaluation. 4. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. BY THE CO J. Wesley Oler, Jr., a J. cc: Elizabeth J. Saylor, Esquire, counsel for Father TRUE r"`,F^" FICORD Joyvon Davis, pro se in Twin . -^t my hand 3226 N. 6`h Street an 4%e szai pa. Harrisburg, PA 17110 _ .. f ¦ QMp.: / GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-2463 CIVIL ACTION - LAW JOYVON DAVIS, 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 is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF George Thomas Taylor, VII December 1, 2001 Mother 2. A Conciliation Conference was held March 29, 2007 with the following individuals in attendance: The Father, George Thomas Taylor, VI, with his counsel, Elizabeth J. Saylor, Esquire, and the Mother, Joyvon Davis, pro se. 3. The Honorable J. Wesley Oler, Jr. previously entered Orders of Court dated October 2, 2006 and June 27, 2006 providing for shared legal custody, Mother having primary physical custody and Father having every weekend. 4. Father's position on custody is as follows: Father seeks shared legal and primary physical custody. Father filed a Petition for Contempt and Modification claiming that Mother had failed to transfer the child 10 out of 22 weekends and failed to pick up the child at the conclusion of Father's custodial time 8 out of 12 weekends. Father asserts that the child has had 10 unexcused absences from his Headstart program. Father maintains that he is better able to provide a stable, nurturing environment for the child and abide by any order granting mother partial physical custody. Father requests a custody evaluation and will bear the full cost thereof. 5. Mother's position on custody is as follows: Mother seeks to maintain the status quo. She denies the allegations of contempt and has explanations for the child's unexcused absences. She further maintains that she does not always have access to a vehicle in which to pick up the child at the conclusion of Father's custodial period. 1 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and maintaining the status quo. It is expected that the Hearing will require one day. Date ; acq line M. Verney, Esquire / Custody Conciliator C GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. JOYVON DAVIS, Defendant :NO. 2005-2463 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this VA day o,f , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of Court dated June 30, 2005 and February 21, 2006 are hereby vacated. 2. The Father, George Thomas Taylor, VI, and the Mother, Joyvon Davis, shall have shared legal custody of George Thomas Taylor, VII, born December 1, 2001. 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 his health, education and religion. Pursuant to the terms of Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 3. The Mother shall have primary physical custody of the Child. 4. The Father shall have periods of partial physical custody every week from Thursday at 6:00 p.m. to Sunday at 6:00 p.m. 5. Transportation shall be shared such that the receiving party shall transport. 6. Thanksgiving shall be shared such that Mother shall always have physical custody of the Child from 9:00 a.m. to 3:00 p.m. and Father shall always have physical custody of the Child from 3:00 p.m. to 9:00 p.m. 7. Christmas shall be divided into two Blocks. Block A shall be from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block B shall be from 12:00 noon on Christmas Day to December 26 at 12:00 noon. Father shall have physical custody of the Child during Block A in odd numbered years and for Block B in even numbered years. Mother shall have physical custody of the Child during Block B in odd numbered years and Block A in even numbered years. 8. Father shall be entitled to one full week of physical custody during the year from Friday to Friday, provided he give Mother 30 days prior notice. 9. Mother shall have physical custody of the Child on Mother's Day beginning at 9:00 a.m. 10. Neither party shall do or say anything or permit a third party to do or say anything that may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. 11. Father may litigate his allegations of contempt in the event Mother fails to abide by this Court Order. 12. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference is-, scheduled for September 21, 2006 at 8:30 a.m. BY THE COUR J. Wesley Oler, Jr., cc: Jessica Holst, Esquire, Counsel for Father Joy-von Davis, pro se 3226 N. 61h Street Harrisburg, PA17110 J. 'fi t &) FR6M kfC6RD la Te 'r() m? %., ii^, cof, t ho-re Into set my hanc and ;:ii of said Co rt at arlisle, Pa. ( T1 " .... .0 aY , <?7b Prothonotary GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2005-2463 CIVIL TERM JOYVON DAVIS, : CIVIL ACTION - LAW 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 is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF George Thomas Taylor, VII December 1, 2001 Mother 2. A Conciliation Conference was held in this matter on June 22, 2006, with the following individuals in attendance: The Father, George Thomas Taylor, VI, with his counsel, Jessica Hoist, Esquire, Mid Penn Legal Services and Mother, Joyvon Davis, pro se. 3. The Honorable J. Wesley Oler, Jr. entered Orders of Court dated June 30, 2005 and February 21, 2006 providing for shared legal custody, Mother having primary physical custody, with Father having every weekend. 4. The parties agreed to an Order in the form as attached. (i- - Z z -0 Date ,? lac acgt ine M. Verney, Esquire Custody Conciliator f? SEP 2 1. 2006 i GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-2.463 CIVIL TERM JOYVON DAVIS, CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT ?a. AND NOW, this day of ne , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated June 27, 2006 shall remain in frill force and effect with the following modifications and additions. 2. Paragraph 3 shall be deleted in its entirety and replaced with the following:. Father shall have periods of partial physical custody every week from Friday at 6:00 p.m. to Sunday at 6:00 p.m. Father's times shall be extended to start on Thursday and to extend to Monday in the event of a school holiday or in-service day, or if Father can arrange to transport the child to school on Monday mornings. 3. Paragraph 8 shall be deleted in its entirety and replaced with the following: Each party shall be entitled to two (2) non-consecutive weeks of uninterrupted physical custody during the year provided they give the other party 30 days prior notice and they provide a location and telephone number where the child will be if he is to be removed from the jurisdiction. 4. Easter shall be shared such that Father shall always have physical custody of the Child from 9:00 a.m. to 3:00 p.m. and Mother shall always have physical custody of the Child from 3:00 p.m. to 9:00 p.m. 5. Memorial Day, July 4th and Labor Day shall be alternated by the parties. Father shall have physical custody for Memorial Day 2007 and the parties shall alternate thereafter. 6. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, J. Wesley Oler, Jr., /l . 7 J. cc: Jessica Hoist, Esquire, Counsel for Father Joyvon Davis, pro se 3226 N. 6th Street Harrisburg, PA 17110 TTI99- CO FROM RECORD lmon €. Als-'3-Pa. 6 t MY, MW Se.......... , GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :2005-2463 CIVIL ACTION - LAW JOYVON DAVIS, 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 is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF George Thomas Taylor, VII December 1, 2001 Mother 2. A Conciliation Conference was held in this matter on September 21, 2006, with the following individuals in attendance: The Father, George Thomas Taylor, VI, with his counsel, Jessica Holst, Esquire, Mid Penn Legal Services. Mother, Joyvon Davis, did not appear. 3. The Honorable J. Wesley Oler, Jr. entered an Order of Court dated June 27, 2006 providing for shared legal custody, Mother having primary physical custody, with Father having partial physical custody every weekend. 4. Father requested an Order in the form as attached. Date acq line M. Verney, Esquire Custody Conciliator VERIFICATION I, George Thomas Taylor, VI, verify that the statements made in the foregoing document(s) are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: 7-- Z-07 George T mas Taylor, VI LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff BY: Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 3800 Market Street Camp Hill, PA 17011 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: Isaylor@pirlaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE THOMAS TAYLOR, VI, Plaintiff No. 05-2463 CIVIL TERM VS. JOYVON DAVIS, Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Elizabeth J. Saylor, hereby certify that I am on this day serving a copy of the Petition for Emergency Relief upon the person(s) and in the manner indicated below: US Regular Mail and Certified US Mail, restricted delivery, return receipt requested and addressed as follows: Joyvon Davis, Pro Se 1607 Hillside VLG Harrisburg, PA 17110 Joyvon Davis, Pro Se 3226 N. 6th Street Harrisburg, PA 17110 Elizabe J. Saylor Date: 7 0-7 ? r? Ua' f H ca 'rte } C co roi JUL o s zoos ?r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE THOMAS TAYLOR, VI, Plaintiff VS. JOYVON DAVIS, . Defendant No. 05-2463 CIVIL TERM IN CUSTODY Judge J. Wesley Oler, Jr. ORDER OF COURT AND NOW, this day of , 2007, upon consideration of the attached Petition, a hearing is scheduled for , 2007, at/?. in Courtroom Number of the Cumberland County Courthouse, Carlisle, Pennsylvania on Plaintiff's Petition for Emergency Relief Seeking Modification of Order Dated April 3, 2007. BY THE COURT: Distribution List: J. Wesl ftOler, Jr.r ' Elizabeth J. Saylor, Esquire The Law Offices of Peter J. Russo, P.C. 3800 Market Street Camp Hill, PA 17011 Joyvon Davis, Pro Se 1607 Hillside VLG Harrisburg, PA 17110 Joyvon Davis, Pro Se 3226 N. 6t Street Harrisburg, PA 17110 R :Z HY 0 1 ]PT LGIZ GEORGE THOMAS IN THE COURT OF COMMON PLEAS OF TAYLOR, VI, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : V. CIVIL ACTION - LAW JOYVON DAVIS, Defendant NO. 05-2463 CIVIL TERM IN RE: PETITION FOR EMERGENCY RELIEF AMENDED ORDER OF COURT AND NOW, this l It' day of July, 2007, the order of court previously issued in the above matter on July 9, 2007, scheduling a hearing for August 8, 2007, is hereby amended to reflect that the date for the hearing is July 25, 2007, at 9:30 a.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, Elizabeth J. Saylor, Esq. 3800 Market Street Camp Hill, PA 17011 Attorney for Plaintiff Joyvon Davis 1607 Hillside VLG Harrisburg, PA 17110 and 3226 North Sixth Street Harrisburg, PA 17110 Defendant, pro Se 7 -/3-0-) L;- :rc 6C .Z 11d Z I `f(" LGOZ :-'Hi J10 GEORGE THOMAS TAYLOR, VI, Plaintiff V. JOYVON DAVIS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 05-2463 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW, this 25th day of July, 2007, upon consideration of Plaintiff's Petition for Emergency Relief Seeking Modification of Order Dated April 3, 2007, and Plaintiff's Petition For Contempt and Modification and following a hearing at which the Plaintiff was represented by Elizabeth J. Saylor, Esquire, and Peter Russo, Esquire, and the Defendant representing herself, the record is declared closed and the matter is taken under advisement. By the Court, / / " ? /, "PJ,- / J. W s ey 0 . , J. izabeth J. Saylor, Esquire 4/1 Peter J. Russo 3800 Market Street Camp Hill, PA 17011 For the Plaintiff /yvon Davis, Defendant, pro Se 1607 Hillside Village, Apt. E Harrisburg, PA 17103 pcb ON GEORGE THOMAS TAYLOR, VI, Plaintiff V. JOYVON DAVIS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION--LAW No. 05-2463 CIVIL TERM IN RE: PLAINTIFF'S PETITION FOR EMERGENCY RELIEF and PLAINTIFF'S PETITION FOR CONTEMPT AND MODIFICATION BEFORE OLER, J. ORDER OF COURT AND NOW, this 6th day of August, 2007, upon consideration of Plaintiffs Petition for Emergency Relief Seeking Modification of Order Dated April 3, 2007, and Plaintiff's Petition for Contempt and Modification, relating to the parties' child, George Thomas Taylor, VII (d.o.b. December 1, 2001), and following a hearing held on July 25, 2007, it is ordered and directed as follows: 1. Defendant is adjudicated in contempt and sanctioned to pay the sum of $300 to the use of the county, within 60 days of the date of this order; 2. Legal custody of the child shall be shared by the parties; provided, that, in the event of a dispute as to schooling, Plaintiff's choice as to the school to be attended by the child shall prevail; 3. Physical custody of the child shall be shared by the parties on an alternating weekly basis, with the said periods to run from Friday night at 7:00 p.m. to the following Friday night at 7:00 p.m.; 4. On Christmas Day and Thanksgiving Day, the parent who does not have custody during that week shall have custody of the child from 3:00 p.m. until 7:00 p.m. of the following day. 61 :Z Wd L- O A LOOZ AuviUNt"Dri , d ?Hi O 1 5. Transportation for purposes of exchanges of custody shall be the responsibility of the party receiving custody; 6. Nothing in this order is intended to preclude the parties from deviating from the custodial terms of the order by mutual consent. /lizabeth J. Saylor, Esq. 3 800 Market Street Camp Hill, PA 17011 Attorney for Plaintiff ./0yvon Davis ? 607 Hillside VLG Harrisburg, PA 17110 and 26 North Sixth Street J Harrisburg, PA 17110 Defendant, pro Se :rc BY THE COURT, GEORGE THOMAS TAYLOR, VI, Plaintiff V. JOYVON DAVIS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 05-2463 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY PETITION FOR CONTEMPT AND MODIFICATION OF CUSTODY ORDER AND NOW, thisay of July, 2009, comes the Plaintiff, George Thomas Taylor, VI, by and through his undersigned attorney, Joseph L. Hitchings, Esquire, and avers in support of his Petition For Contempt and Modification of Custody Order as follows: 1. The Plaintiff is George Thomas Taylor, VI, an adult individual residing at 211 Bailey Street, New Cumberland, Cumberland County, Pennsylvania 17070. Plaintiff resides at that address with his Wife, Leslie Taylor, and their children, Jade, Trey and during his custodial periods, his son, George Thomas Taylor, VII (d.o.b. December 1, 2001). 2. The Defendant is Joyvon Davis., an adult individual residing at 2206 Hillside Village, Harrisburg, Dauphin County, Pennsylvania 17103. Defendant resides at that address with her daughter JaQuaya, and during his custodial periods, her son, George Thomas Taylor, VII. 3. Pursuant to Court Order entered by the Honorable J. Wesley Oler, Jr. of this Court, dated August 6, 2007, Defendant was found in contempt, and custody was modified, giving shared legal custody and shared physical custody on an alternating weekly basis, with Father being the parent responsible for school decisions, and transportation to be shared with the receiving parent responsible for picking up the child. A true and correct copy of the August 6, 2007 Order is attached hereto, incorporated herein by reference, and marked as Exhibit "A". 4. From March 20, 2009 through the present, Defendant has refused to allow Plaintiff's wife to pick up the child, despite the fact that she had done so without problem on multiple occasions in the past. This has caused a significant delay in the start times for Plaintiff's custodial periods. 5. Defendant has been verbally abusive to Plaintiff's Wife and other relatives, in front of the minor child, when they have attempted to pick him up. 6. During weeks when the minor child was with Defendant, he had multiple unexcused absences from school, resulting in the school sending a letter to Plaintiff and threatening to fine him. 7. It is believed and therefore averred that Defendant does not place a priority on the minor child attending school or completing his school related tasks, resulting in the child's poor school performance. 8. It is requested that the Defendant be found in contempt for violating the existing Custody Order, and that the custody schedule be modified to grant Plaintiff primary physical custody of the minor child during the school year with Defendant having alternating weekends. 9. It is believed and therefore averred that the best interest and permanent welfare of the minor child will be served by granting the relief requested because the father/Plaintiff can provide a loving, stable and supportive educational environment for his son. 10. Plaintiff respectfully requests that this Petition be forwarded to the Court for the scheduling of a Custody Conference. 11. Plaintiff has had to incur attorney's fees in enforcing his rights under the Custody Order, and requests that in the event Defendant is found in contempt that reasonable attorney fees be awarded. WHEREFORE, Plaintiff, George Thomas Taylor, VI, respectfully requests that this Honorable Court find the Defendant in Contempt, award attorney fees, and grant him primary physical of his minor son, George Thomas Taylor, VII, during the school year.. Respectfully Submitted, LAW JOYFICE OF JgSE]RH L. HITCHINGS Date: ?- 3 - 0 5 By: Joseph L. fftfi ks,Esq Attorney ID # 655 5000 Ritter Road, Suite Mechanicsburg, Pennsylvania 171055 Telephone: (717) 458-8123 Fax: (717) 790-6019 Attorney for Plaintiff VERIFICATION I, George Thomas Taylor, VI, verify that the statements made in this Petition For Contempt and Modification of Custody Order are true and correct to the best of my knowledge, information and belief and . I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date eorge omas Taylor, VI EXHIBIT "A" GEORGE THOMAS : IN THE COURT OF COMMON PLEAS OF TAYLOR, VI, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : CIVIL ACTION--LAW JOYVON DAVIS, Defendant : No. 05-2463 CIVIL TERM IN RE: PLAINTIFF'S PETITION FOR EMERGENCY RELIEF and PLAINTIFF'S PETITION FOR CONTEMPT AND MODIFICATION BEFORE OLER, J. ORDER OF COURT AND NOW, this 6th day of August, 2007, upon consideration of Plaintiff's Petition for Emergency Relief Seeking Modification of Order Dated April 3, 2007, and Plaintiff's Petition for Contempt and Modification, relating to the parties' child, George Thomas Taylor, VII (d.o.b. December 1, 2001), and following a hearing held on July 25, 2007, it is ordered and directed as follows: 1. Defendant is adjudicated in contempt and sanctioned to pay the sum of $300 to the use of the county, within 60 days of the date of this order; 2. Legal custody of the child shall be shared by the parties; provided, that, in the event of a dispute as to schooling, Plaintiffs choice as to the school to be attended by the child shall prevail; 3. Physical custody of the child shall be shared by the parties on an alternating weekly basis, with the said periods to run from Friday night at 7:00 p.m. to the following Friday night at 7:00 p.m.; 4. On Christmas Day and Thanksgiving Day, the parent who does not have custody during that Nveek shall have custody of the child from 3:00 p.m. until 7:00 p.m. of the following day. 5. Transportation for purposes of exchanges of custody shall be the responsibility of the party receiving custody; 6. Nothing in this order is intended to preclude the parties from deviating from the custodial terms of the order by mutual consent. Eli Beth J. Saylor, Esq. 00 Market Street Camp Hill, PA 17011 Attorney for Plaintiff Joyvon Davis 1607 Hillside VLG Harrisburg, PA 17110 and 3226 North Sixth Street Harrisburg, PA 17110 Defendant, pro Se :rc BY THE COURT, rr J. Vesley Olen-j., J. V, ?"' T w of? unto set my `of N a willr_ AL GEORGE THOMAS TAYLOR, VI, Plaintiff v. JOYVON DAVIS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 05-2463 CIVIL TERM CIVIL ACTION -LAW IN CUSTODY CERTIFICATE OF SERVICE I, Joseph L. Hitchings, Esquire, Attorney for the Plaintiff, George Thomas Taylor, VI, do hereby certify that I served a true and correct copy of the attached Petition for Contempt and Modification of Custody Order, by United States Mail, First Class, postage prepaid and by certified mail, restricted delivery upon the party listed below: Joyvon Davis 2206 Hillside Village Harrisburg, PA 17103 Date:-2 - ?- oC Respectfully Submitted, LAW OFFICE OF JOSFipH L. HITCHINGS By: - (? oseph L. Hitch s, quire Attorney ID # 65551 5000 Ritter Road, Suite 202 Mechanicsburg, Pennsylvania 17105 Telephone: (717) 458-8123 Fax: (717) 790-6019 Attorney for Plaintiff FILRD- 2OP9 22 pd, -?w-do iQ? 141-464?t5 &?,k luo fi,4 aak 635 r GEORGE THOMAS TAYLOR, VI IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA 2005-2463 CIVIL ACTION LAW JOYVON DAVIS IN CUSTODY DFFF,NDANT ORDER OF COURT AND NUVV, Friday,,Nly 17, 2009 upon consideration of the attached Complaint, it is hcreh\ directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. the conciliator, at 4th Floor, Cumberland Country Courthouse, Carlisle on Thursday, August 20, 2009 at 8:30 AM for a Pre-Hearini* Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or it this cannot he accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Fal Itlre to appear at the conference may provide grounds for entry of a temporary, or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ acqueline M. Verne Es _ Custodv Conciliator Mlle Court of Common Pleas of Cumberland County is required by law to comply with the Americans kN ith Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations ati ail thle 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. YOC! SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT I ]AVI AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FUR"hH 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 ALED- OF THE ! i FF?)T. ,.. iiA Y 2009 JUL 20 Aid 30: 42 IV PLIENI SYb/'Mtr AUG ?2 12009 GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-2463 CIVIL ACTION - LAW JOYVON DAVIS, . Defendant : IN CUSTODY ORDER OF COURT AND NOW, this Z?s day of A (? _ , 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A Hearing is scheduled in Court Room No. of the Cumberland County Court House, on the I k day of 1A,2009, at o'clock,. 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 five days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the prior Order of Court dated August 6, 2007 shall remain in full force and effect with the following modification. 3. Transportation shall be shared such that the receiving party or their designee shall transport the child. The receiving party and/or their designee shall remain in the car during the exchange of custody. 4. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. '1? 7.1 cc: Jpseph L. Hitchings, Esquire, counsel for Father Joyvon Davis, pro se 2206 Hillside Village Harrisburg, PA 17103 BY THE COURT, a GEORGE THOMAS TAYLOR, VI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-2463 CIVIL ACTION - LAW JOYVON DAVIS, 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 is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF George Thomas Taylor, VII December 1, 2001 Mother 2. A Conciliation Conference was held August 20, 2009 with the following individuals in attendance: The Father, George Thomas Taylor, VI, with his counsel, Joseph L. Hitchings, Esquire, and the Mother, Joyvon Davis, pro se. 3. The Honorable J. Wesley Oler, Jr. previously entered an Order of Court dated August 6, 2007 finding Mother in contempt, and providing for shared legal custody, but with Father being responsible for school decisions, and shared physical custody on a week on/week off basis. 4. Father's position on custody is as follows: Father seeks a finding of contempt based on Mother's refusal to relinquish physical custody of the child to Father's wife. He seeks shared legal custody, with authority to make school decisions and primary physical custody. Father asserts that during the past school year, while the child was in first grade, he accumulated 16 unexcused absences and 11 tardies while in Mother's physical custody. Father is willing to give partial physical custody on every weekend to Mother if he has physical custody during the school year. Father offered to have shared physical custody in the summer. Father believes the primary physical custody arrangement he suggests provides the needed stability for the child. 5. Mother's position on custody is as follows: Mother denies the contempt allegations. She is willing to allow Father's wife pick up the child provided both parties, or their designee, remain in their vehicle during the custody exchange. She seeks to maintain the status quo regarding custody. She denies that the child had the absentee record that Father asserts. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and maintaining the status quo, with a modification permitting a parties' designee being allowed to transport the child. It is expected that the Hearing will require one-half day. j 2. 9 / Date 64acqVeline A Verney, Esquire Custody Conciliator OR THE FRY"HONIGTARY 2009 AUG 24 PM 1: 57 GEORGE THOMAS TAYLOR, VI Plaintiff v JOYVON DAVIS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 05-2463 CIVIL TERM IN RE: PETITION FOR CONTEMPT AND MODIFICATION OF CUSTODY ORDER ORDER OF COURT AND NOW, this 7th day of December, 2009, upon consideration of Plaintiff's Petition for Contempt and Modification of Custody Order with respect to the parties' child, George Thomas Taylor, VII (date of birth, December 1, 2001), and following a hearing, the record is declared closed, and the matter is taken under advisement. Joseph L. Hitchings, Esquire 5000 Ritter Road Suite 202 Mechanicsburg, PA 17055 For Plaintiff Joyvon Davis 1607 Apartment E Hillside Village Harrisburg, PA 17103 Defendant, pro se mae ?IES /YtdlLL, By the Court, RiD-OFFICE OF THE FR-,)'PH 1'ARY 2004 DEC 14 P 2= 30 PENNSYLVA ",41A GEORGE THOMAS : IN THE COURT OF COMMON PLEAS OF TAYLOR, VI, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION V. JOYVON DAVIS, Defendant : NO. 2005-2463 CIVIL TERM IN RE: PLAINTIFF'S PETITION FOR CONTEMPT AND MODIFICATION OF CUSTODY ORDER BEFORE OLER, J. ORDER OF COURT AND NOW, this 11'' day of December, 2009, upon consideration of Plaintiff's Petition for Contempt and Modification of Custody Order, with respect to the parties' child, George Thomas Taylor, VII (d.o.b. December 1, 2001), and following a hearing held on December 7, 2009, it is ordered and directed as follows: 1. Plaintiff's Petition for Contempt is dismissed. 2. Legal custody of the child shall be shared by the parties; provided, that, in the event of a dispute as to schooling, Plaintiffs choice as to the school to be attended by the child shall prevail. 3. Physical custody of the child shall be shared by the parties in the following manner: a. During the school year, (1) Primary physical custody of the child shall be in Plaintiff, the father; (2) Temporary or partial physical custody of the child shall be in Defendant, the mother, at the following times: (a) On alternating weekends, from Friday at 7:00 p.m. until Sunday at 3:00 p.m.; (b) On Thanksgiving, from 3:00 p.m. until 7:00 p.m.; and (c) During Christmas vacation, from Christmas Day at 3:00 p.m. until December 30 at 3:00 p.m. b. During the summer, (1) Primary physical custody shall be in Defendant, the mother; and (2) Temporary or partial physical custody shall be in Plaintiff, the father, during the first full weeks of June, July and August. 4. Transportation shall be shared such that the receiving party and/or his/her designee shall transport the child. The receiving party and/or his/her designee shall remain in the car during the exchange of custody. 5. Nothing herein is intended to preclude the parties from deviating from the terms of this order by mutual agreement. -- J osePh L. Hitchings, Esq. 5000 Ritter Road Suite 202 Mechanicsburg, PA 17055 Attorney for Plaintiff J BY THE COURT, ?Joyvon Davis 1607 Hillside Village Harrisburg, PA 17110 Defendant, pro Se czPt F,S M-4 t tfx'L /z1/rr?aq FILED- OF I'E OF THE PROTf- ONOT f 2009 DEC 14 PH 2: 29 CUM_:; . ;' 1 ;. 1 7'Y t ?,?;