HomeMy WebLinkAbout05-28960.5 -?2 89?
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CP-21-JV-0234-2004
IN THE MATTER OF COLLYN BARTON, born May 8, 1996
IN THE MATTER OF DARRYN BARTON, born December 6, 1998
ORDER OF COURT
AND NOW, this 27th day of May, 2005, the Court
Administrator is directed to file our order dated January 12,
2005, at CP-21-JV-0234-2004 regarding Collyn Barton and Darryn
Barton to a custody docket in the Prothonotary's Office to be
captioned Scott Barton vs. Belinda Barton. Filing fees are
waived.
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Edward E. Guido, J.
Lindsay Dare Baird, Esquire
For CCC&YS
Jacqueline M. Verney, Esquire
G.A.L. for Children
Maggi E. Colwell, Esquire
For Father
Belinda Barton
198 Black Gap Road, Lot 134
Fayetteville, PA 17222
Mother, Pro se
Juvenile Probation
CCC&YS
CASA
Court Administrator
Prothonotary
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CP-21-JV-0234-2004
IN THE MATTER OF COLLYN BARTON, born May 8, 1996
IN THE MATTER OF DARRYN BARTON, born December 6, 1998
ORDER OF COURT.
AND NOW, this 27th day of May, 2005, after
hearing, we reaffirm primary physical custody of the children in
their Father subject to periods of partial physical custody in
the Mother as the parties shall agree. The parties shall have
shared legal custody of their children, Collyn Barton, born
May 8, 1996, and Darryn Barton, born December 6, 1998.
Mother shall have partial physical custody in the
summer of 2005 from 9:30 a.m. today until 9:00 a.m. on August 1,
2005.
During her periods of partial physical custody,
Mother shall cooperate with the Cumberland Children and Youth
Agency so that they may supervise her care of these children as
they are her other two children. The following specific
conditions shall be obeyed:
1. The children are not to be alone with her
paramour, Kenneth Hershey, under any circumstances whatsoever.
2. Mother shall assure that nobody talks to these
children regarding the custodial arrangements.
If the parties are unable to agree on any period
of partial physical custody in the future, this matter shall
proceed through conciliation and then to hearing if necessary.
The Mother shall make the children available on
Wednesdays between 7:30 p.m. and 9:30 p.m. Eastern Time to
receive telephone calls from their Father.
The appointment of Mrs. Verney as G.A.L. is
vacated.
Lindsay Dare Baird, Esquire
For CCC&YS
Jacqueline M. Verney, Esquire
G.A.L. for Children
Maggi E. Colwell, Esquire
For the Father
Belinda Barton
198 Black Gap Road, Lot 134
Fayetteville, PA 17222
Mother, Pro se
Juvenile Probation
CCC&YS
CASA
Court Administrator
Prothonotary
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MAY 2 9 2008
BELINDA BARTON,
Plaintiff
V.
SCOTT BARTON,
Defendant
Prior Judge: Edward E. Guido, J.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 05-2896 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW this a day of ) 0088,, upon consideration of the attached Custody
Conciliation Report, it is Ordered and Directed as follows:
1. This Order is entered pursJ?jma?nt to a Custod Conciliation Conference. A Custody Hearing is
hereby sc eduled on the 41V* day of 2008 at 9.30 am/pm in Courtroom
number,? in the Cumberland County ourt of Common Pleas, Carlisle, PA 17013 at which
time testimony will be taken. The issue to be addressed is whether or not it is appropriate for
Father to financially assist Mother with her transportation expenses. 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 s 1 be filed at least five days prior to the hearing date.
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2. The Order of Court dated J 18, 2008 hall rem in ful force and effect with the
following modification:
In regard to paragraph 4 of the Order dated January 18, 2008,
Custody Exchanges: The Mother and Father shall share the transportation obligations
for the custody exchanges. The exchange location shall be at the Wal-Mart in
Indianapolis, Indiana no later than 7:00 pm (EST) on a Saturday, unless otherwise
mutually agreed upon. Indianapolis is approximately the half-way point between
Mother and Father's residences. Father shall be obligated to pay his expenses related to
dropping off/picking up the Children in Indianapolis and Mother shall be obligated to
pay her expenses related to dropping off/picking up the Children in Indianapolis.
3. 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.
B e Court,
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,Distribution:
Megan Riesmeyer, Esq.
off Barton, 511 Combs Avenue, Huntsville, AR 72740
John J. Mangan, Esq.
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BELINDA BARTON,
Plaintiff
V.
SCOTT BARTON,
Defendant
Prior Judge: Edward E. Guido, J.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 05-2896 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVII, PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the following report:
1. The pertinent information pertaining to the Children who are the subject of this litigation is as
follows:
Name Date of Birth Currently in the Custody of
Collyn Barton 5/8/1996 Father
Darryn Barton 12/6/1998 Father
2. A Conciliation Conference was held with regard to this matter on January 7, 2008
with the following individuals in attendance:
The Mother, Belinda Barton, with her counsel, Megan Riesmeyer, Esq. and Scott
Weber, Certified Legal Intern
The Father, Scott Barton, pro se
An Order of Court was entered on January 18, 2008 by agreement.
3. The Honorable Edward E. Guido entered an Order of Court dated May 27, 2005 awarding
Father primary physical custody of the subject Children subject to Mother's partial physical
custody. Said Order was issued under the juvenile dependency docket number CP-21-JV-
0234-2004 and subsequently transferred to a civil custody docket number 05-2896.
4. The undersigned Custody Conciliator has been contacted regarding a clarification of the Order
of Court dated January 18, 2008, specifically paragraph 4, pertaining to Father forwarding a
sum of $250.00 to Mother prior to the custody exchanges.
5. Father and the subject Children live in Huntsville, Arkansas and Mother lives in Cumberland
County, Pennsylvania. The distance between their respective residences is 1,091.73 miles and
driving time is approximately 17 hours and 41 minutes. At the present time, the established
exchange location is Indianapolis, IN. The distance from Father's residence to Indianapolis is
561.99 miles and the driving time is approximately 9 hours. The distance from Mother's
residence to Indianapolis is 528.04 miles and the driving time is approximately 8 hours and 43
minutes. Paternal grandparents also reside in Indianapolis and visit with the Children during
the exchanges. At the last custody conference, the parties agreed to share transportation
obligations. However, Mother indicated that she did not have the funds to travel to the
exchange point. Father indicated that he would assist Mother by forwarding $250.00 to her
prior to her departure so that she could pick up the Children. Apparently this was done by
Father for the Easter exchange in 2008. The Children's summer vacation is approaching and
the issue of the appropriateness of Father forwarding money to Mother for the exchanges has
been brought to the undersigned's attention. Alternative options have been explored including
airfare, buses and trains without success.
6. Father's position is that he is already bearing the financial and time obligations transporting the
Children to Indianapolis, which is slightly more than Mother's obligations to Indianapolis.
Father asserts that he is willing to share the transportation for the exchanges but asserts that it is
not appropriate for him to financially assist Mother in regard to her obligations to pick up the
Children. Father indicates that he does not have ready resources to financially assist Mother
with the exchanges. Father does not oppose said exchange location because paternal
grandparents reside in Indianapolis and gives the opportunity for the Children to see their
grandparents.
7. Mother's position is that she is financially unable to travel to Indianapolis to pick up the
Children. Mother cares for her additional children not related to Father and is struggling to
make ends meet. Mother asserts that if she does not receive financial assistance from Father to
help with her expenses, she simply will not be able to see her Children for the summer. Mother
indicates that for the last exchange for Easter 2008, she had to borrow money from
friends/relatives/organizations to enable her to transport the Children to/from Indianapolis.
8. The Conciliator recommends an Order in the form as attached scheduling a Hearing before the
Court. It is the Conciliator's belief that this would be in the Child's best interest. It is expected
that the Hearing will require half a day.
9. The proposed recommended Order may contain a requirement that the parties file a pre-trial
memorandum with the Judge to whom the matter has been assigned.
,7-/Z 4??
Date
Jo gan, Esquire
C od Conciliator
BELINDA BARTON, : IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION-LAW
V.
IN CUSTODY
SCOTT BARTON,
Defendant : NO. 05 - 2896
PETITION TO CANCEL HEARING
Plaintiff, Belinda Barton, by and through her attorneys, the Family Law Clinic, hereby
requests that the Court cancel the Custody Hearing scheduled for June 27, 2008 at 9:00 am in the
above-captioned case. In support of her Petition, Plaintiff states the following:
1. Plaintiff is Belinda Barton ("Mother"), residing at RR1 Box 635, Honey Grove, PA
17035.
2. Defendant is Scott Barton ("Father"), residing at 511 Combs Avenue, Huntsville, AR
72740.
3. Plaintiff and Defendant are the parents of:
Collyn Barton, born May 8, 1996; and
Darryn Barton, born December 6, 1998.
4. Pursuant to the May 27, 2005 Order of Court, Father and Mother have shared legal
custody of their sons, Collyn and Darryn Barton. Father maintains primary physical
custody and Mother has partial physical custody.
5. By a Custody Complaint filed on November 26, 2007, Mother requested this Honorable
Court grant her additional periods of physical custody of the children. Mother
specifically requested physical custody from December 19, 2007 to January 2, 2008 and
asked the Court to direct Father to pay the costs of transportation.
6. Upon consideration of Mother's Complaint this Honorable Court issued an Order dated
November 30, 2007, scheduling a Pre-Hearing Custody Conciliation before John J.
Mangan, Jr., Esq., on January 7, 2008 at the Cumberland County Courthouse.
7. As a result of the January 7, 2008 Conciliation, the following agreed upon schedule was
entered as an Order of Court:
a. Father and Mother shall have shared legal custody of the Children.
b. Father shall have primary physical custody of the Children subject to Mother's
partial physical custody as follows:
Mother shall have physical custody of the Children every summer,
beginning one week after the Children's last day of school until one week
before the first day of school for the next year.
2. Commencing 2008 and in all even-numbered years, Mother shall have
physical custody of the Children for Easter one week and for Christmas
one week, with the specific understanding that this time shall commence
within two (2) days of the holiday break until two (2) days before the end
of the holiday break. In 2008, the Easter week shall be from Saturday,
March 15th through Saturday, March 22nd. The exchange times shall be
no later than 7:00 pm (EST). Father shall give Mother advance notice of
the Children's school vacation schedule at the beginning of every year.
3. Mother shall have physical custody at such other times as mutually agreed
upon.
C. Custody Exchanges: The Mother and Father shall share the transportation for the
custody exchanges. The exchange location shall be at the Wal-Mart in
Indianapolis, Indiana no later than 7:00 pm (EST) on a Saturday, unless otherwise
mutually agreed upon. Father shall forward to Mother a sum of two-hundred and
fifty dollars ($250.00) at least two (2) weeks prior to the custody exchanges.
Mother shall in turn bring any and all receipts for the cost of gasoline and tolls
that are incurred for the trip. Mother shall reimburse any unused funds to Father
as appropriate. Said sum of money may be modified as conditions warrant.
This Order remains in full force and effect as of this date.
8. By Order of the Court dated June 9, 2008, this Honorable Court has scheduled a custody
hearing for June 27, 2008 at 9:00 am in this matter.
9. Mother has advised her counsel that she is satisfied with the Court's Order of January 18,
2008 and does not desire to modify this Order at this time.
10. Mother has been named the moving parry at the hearing scheduled for June 27, 2008
despite the fact that she has no present desire to modify the January 18, 2008 Order.
11. Cumberland County Rule of Civil Procedure 1915.12-1 requires that, "All petitions for
contempt and/or modification shall be filed in the same manner as original complaints in
Rule 1915.3(1) and the Court Administrator shall refer same to the conciliator for review."
12. Mother has not petitioned this Honorable Court to modify the Order of January 18, 2008
pursuant to C.C.R.P. 1915.12-1 and C.C.R.P. 1915.3(1), nor is Mother aware of a Petition
for Modification filed by Father or on his behalf.
13. Mother believes and therefore avers that neither party has petitioned this Honorable Court
to modify the January 18, 2008 Order and that no hearing should be held on this matter.
14. Concurrence of opposing counsel is not sought pursuant to C.C.R.P. 208.2(d) as Father is
unrepresented by counsel.
15. The Honorable Edward E. Guido has previously ruled on this matter.
WHEREFORE, Mother requests that this Honorable Court cancel the hearing scheduled for June
27, 2008 at 9:00 a.m. before the Honorable Edward E. Guido. In the alternative, Mother requests
that any petition for modification be treated as described in C.C.R.P. 1915.12-1., and be set to be
heard at a conciliation.
Respectfully Submitted,
Michael A. O'Donnell
Certified Legal Intern
".,4 ?(A W-,
Meg Riesmeyer
Supervising Attorney
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
Phone: (717) 243-2968
Fax: (717) 243-3639
VERIFICATION
Understanding that the making of any false statement would subject me to the penalties
of 18 Pa.C.S § 4904, I verify that the Family Law Clinic is counsel for the Plaintiff in the present
action, and that the facts and statements contained in the above Petition are true and correct, to
the best of my knowledge, information and belief.
(0- t7.OK
Date Michael A. O'Donnell
Certified Legal Intern
&MAX I
Meg esmeyer
Supervising Attorney
BELINDA BARTON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION-LAW
IN CUSTODY
SCOTT BARTON,
Defendant NO. 05 - 2896 CIVIL TERM
CERTIFICATE OF SERVICE
I, Michael O'Donnell, Certified Legal Intern, Family Law Clinic, hereby certify that I
served a true and correct copy of the Petition to Cancel Hearing on Scott Barton, residing at, 511
Combs Avenue, Huntsville, AR 72740, by depositing a copy of the same in the United States
mail, postage prepaid.
? ? ?el_ /?O_ ?_&?
Michael O'Donnell
Certified Legal Intern
Mega# Riesmeyer
Supervising Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
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BELINDA BARTON,
Plaintiff
V.
SCOTT BARTON,
Defendant
I 1'! 1 7 2009
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN CUSTODY
NO. 05 - 2896
ORDER OF COURT
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AND NOW, this day of ra , 2008, upon consideration of Plaintiff's Petition
to Cancel Hearing, it is hereby ordered and directed as follows:
I . Plaintiff s Petition to Cancel the hearing scheduled for June 27, 2008 at 9:00 am
before the Honorable Edward E. Guido, is ipmAe X15yo IC>Fw. w;ARAC 140- iWt tte
2. %4@ 0148malix- tioned
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P-akAi" gehetWed for the -L-= &y of , 2000i .
cc: amily Law Clinic, for Plaintiff
Scott Barton, pro se, Defendant
./John J. Mangan, Jr., Esq., Conciliator
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: IN THE COURT OF COMMON PLEAS OF
BELINDA BARTON, Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS NO. 05-2896 CIVIL ACTION LAW
IN CUSTODY
SCOTT BARTON,
Defendant :
ORDER OF COURT
AND NOW, this 27th day of June, 2008, our order of
January 18, 2008, as modified by the order dated June 9, 2008,
shall be amended to incorporate the stipulation articulated on the
record today, a copy of which is attached hereto. In all other
2008, and June
rovisions of the order of January 18,
respects, the p
9, 2008, which are not inconsistent with this agreement shall
remain in full force and effect.
r/ramily clinic
Michael O'Donnell, Certif
Megan Riesmeyer, Esquire
For the Plaintiff
?t Barton, pro se
511 Combs Avenue
Huntsville, AR 72740
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STIPULATION
MR. O'DONNELL: Yes, Your Honor we've reached the
following agreement in the matter of Belinda Barton v. Scott
Barton:
For Christmas in even numbered years, Scott Barton has
agreed to forward a sum of $250 two weeks prior to the custody
exchange which will take place on the first Saturday which the
children are off from school. Belinda has agreed to return the
children on the Saturday prior to school beginning.
For summer every year, Scott Barton has agreed to
forward $250 to Belinda Barton for travel expenses. He will submit
that $250 for travel expenses 2 weeks prior to the custody
exchange. The exchange will take place one week after the children
finish school. It will be on a Saturday at 7 p.m. as per the prior
order. Belinda has agreed to return the children one week prior to
going back to the school with the only exception for this year we
reached an agreement she will return the children on August 9th,
2008.
For spring breaks, Father has agreed to lot Mother
know on January 1st, of even numbered years when the children's
spring break will be. Mother will provide her own travel expenses
for spring breaks in even numbered years, and Mother has agreed to
allow Father notice one month in advance whether or not she will be
able to cover these travel expenses. If she cannot cover the
travel expenses, the children will remain in Arkansas. That's all,
Your Honor.
THE COURT: Mr. Barton, do you agree with?
MR. BARTON: Yes, sir.