HomeMy WebLinkAbout01-3577
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MELVIN J. WOLFE, JR
PLAINTIFF
V.
CHRISTINA M. WOLFE
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
01-3577 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW,
Thursday, June 14, 2001
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq.
at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on Tuesday, July 24, 2001
, the conciliator,
at 11:00 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: Isl
Melissa P. Greevy, Esq. ~
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 an'angements
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
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
MELVIN 1. WOLFE, JR.
PLAINTIFF
vs.
)
)
) No. OF 2001
)
) 0\ - ..d~77
)
)
Clo'llY~
CHRISTINA M. WOLFE,
DEFENDANT
ORDER OF COURT
AND NOW, this _ day of ,2001, upon consideration of the
attached Complaint for Custody, it is hereby directed that the parties and their respective counsel
appear before , the conciliator, at
, on the day of , 2001 at o'clock
_' m. for a pre-hearing custody conference. At such conference, an effort will be made to resolve the
issues in dispute; or it this cannot be accomplished, to define and narrow the issues to be heard by the
Court, and to enter into a temporary order. Failure to appear at the conference may provide grounds
for entry of a temporary or permanent order.
For the Court,
By
Custody Conciliator
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER 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
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County, Pennsylvania, is required by law to
comply with the Americans with Disabilities 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.
By the Court:
Dated:
J.
..
L:\CUSTODY\KEVIN-D\ WOLFE.CUS
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV ANlA
CIVIL ACTION - LAW
vs.
)
)
) No.
)
)
)
)
-OF 2001 0 (- 35-?? Cc,vd
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MELVIN J. WOLFE, JR.
PLAINTIFF
CHRISTINA M. WOLFE,
DEFENDANT
COMPLAINT FOR Cl JSTODY
1. The Plaintiff is Melvin J. Wolfe, Jr., an adult individual residing at 155 Market Street,
Highspire, Pennsylvania 17034.
2. The Defendant is Christina M, Wolfe, an adult individual currently residing at 1082
Oyster Mill Road, Camp Hill, Pennsylvania,
3. Plaintiff seeks custody of the following children:
NAME
PRESENT RESIDENCE
AGE
Melvin J. Wolfe, III
(12/25/93)
1082 Oyster Mill Rd.
Camp Hill, P A
7
Dustin A. Wolfe
(10/8/96)
1082 Oyster Mill Rd.
Camp Hill, P A
4
Amber L. Wolfe
(10/31/97)
1082 Oyster Mill Rd.
3
Melvin 1. Wolfe, III was born out of wedlock and Dustin A. and Amber L. Wolfe were not born
out of wedlock.
The children are presently in the custody of Defendant.
4. During the last five years, the children have resided with the following persons at the
following places:
,"
a. From Oct. 95 to Oct. 97 with both parents at 49 Paxton Street, Highspire, P A
b. From Oct. 97 to Oct. 99 with both parents at 404 N. Third Street, Steelton, P A
c. From Oct. 99 to March 2001 with both parents at 1082 Oyster Mill Rd., Camp Hill,
PA.
d. From March 2001 to May 18,2001 with Defendant at 1082 Oyster Mill Rd., Camp
Hill, P A.
e. From May 18, 2001 to Present - Melvin III with Father at 155 Market Street,
Highspire, Pennsylvania and Dustin and Amber with Mother at 1082 Oyster Mill Rd., Camp Hill,
PA.
5. The mother of the children is Christina M, Wolfe, currently residing at 1082 Oyster
Mill Road, Camp Hill, Pennsylvania.
She is married at the present time.
6. The father of the children is Melvin J. Wolfe, Jr., currently residing at 155 Market
Street, Highspire, Pennsylvania.
He is married at the present time.
7. The relationship of plaintiff to the children is that of natural father. The plaintiff
currently resides with the following persons:
Name
Relationship
Mr. & Mrs. Melvin J . Wolfe
Mother & Father
Sister
8. The relationship of Defendant to the children is that of natural mother. The defendant
currently resides with the following persons:
Name
Relationship
Father
9. Plaintiff has not participated as a party or witness, or in another capacity, in other
litigation concerning the custody of the children in this or another Court.
,
10, Plaintiffhas no information of a custody proceeding concerning the children pending
in a court of this Commonwealth.
11. The Plaintiff does not know of any other person not a party to these proceedings who
has physical custody of the children or claims to have custody or visitation rights with respect to
the children.
12, The best interest and permanent welfare of the children will be served by granting
primary custody to the Plaintiff herein because:
a. Father is better able to provide stable environment for children.
b. Father is better able to provide for the physical, financial and emotional needs
of the children,
13. Each parent whose parental rights to the children have not been terminated and the
person who has physical custody of the children have been named as parties to this action.
WHEREFORE, Plaintiff requests this Honorable Court grant custody of the children
By:
.'
I verify that the statements made in this Complaint for Custody are true and
correct. I understand that false statements herein are made subject to the penalties of18 Pa. C.S.
Section 4904 relating to unsworn falsification to authorities.
Dated: (/' - S - Ci I
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Plaintiff
AUG 0 2 200~1\~
IN THE COURT OF COMMON PLEAS OF 0" .
CUMBERLAND COUNTY, PENNSYLVANIA
MELVIN J. WOLFE, JR.,
vs.
NO. 01-3577
CHRISTINA M. WOLFE,
Defendant
CIVIL ACTION - LAW
CUSTODY
TEMPORARY ORDER OF COURT
AND NOW, this ,~ day of August, 2001, upon consideration of the attached
Custody Conciliation Summary Report, it is hereby ordered and directed as follows:
1. Legal Custody. The parties, Melvin J. Wolfe, Jr., and Christina M. Wolfe, shall have
shared legal custody of the minor Children, Melvin J. Wolfe, born December 25,1993, Dustin
A. Wolfe, born October 8, 1996, and Amber L. Wolfe, born October 31, 1997. Each parent
shall have an equal right, to be exercised jointly with the other parent, to make all major non-
emergency decisions affecting the Children's general well-being including, but not limited to,
all decisions regarding their health, education and religion. Pursuant to the terms of Pa. C. s.
9 5309, each parent shall be entitled to all records and information pertaining to the Children
including, but not limited to, medical, dental, religious or school records, the residence address
of the Children and of 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.
2. Physical Custody.
A. Dustin and Amber shall be in a shared custodial arrangement between the
two parents alternating on a week-on/week-off basis. The date of
exchange shall be Sunday each week with Mother's next custodial week
to begin on July 29,2001. The exchange time, unless otherwise agreed,
shall be 6:30 p.m. The exchange location, unless otherwise agreed, shall
be the Susquehanna Sports Complex parking lot.
B, Mother shall have custody of Melvin J. Wolfe, III, (Rusty), each Saturday
from 9:00 a.m. until 4:00 p.m. and each Tuesday from 5:00 p.m. until 9:00
p.m. During the school year, Mother's Tuesday custodial periods shall
end at 8:30 p.m. Mother shall have additional such periods of custody
with Melvin as the parties may agree.
3. Holidays. The following holidays shall be shared by the parties: Easter,
Independence Day, Thanksgiving and Christmas. The Children shall be with Mother on
Mother's Day and with Father on Father's Day.
No. 01-3577 Civil Term
4. The parties shall submit themselves and their minor Children to an independent
custody evaluation. The evaluator will be chosen by agreement of counsel for the parties.
The parties shall sign all necessary releases and authorizations for the evaluator to obtain
medical and psychological information pertaining to the parties. Additionally, the parties shall
extend their full cooperation to complete this evaluation in a timely fashion. The cost of the
evaluation shall be shared equally by the parties.
5. Following the completion of the independent custody evaluation and receipt of the
report by counsel, counsel for either party may contact the Custody Conciliator for an
additional Custody Conciliation Conference date if the parties are not able to reach a
resolution through counsel.
J.
Dist:
Kevin D. Dolan, Esquire, 222 S. Market Street, Suite 201, Elizabethtown, PA 17022
Gerald S. Robinson, Esquire, 4407 N. Front Street, Harrisburg, PA 17101
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Plaintiff
AUG 0 2 2;1\
IN THE COURT OF COMMON PLEAS OF '
CUMBERLAND COUNTY, PENNSYLVANIA
MELVIN J. WOLFE, JR.,
vs.
NO. 01-3577
Defendant
CIVIL ACTION - LAW
CUSTODY
CHRISTINA M. WOLFE,
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 Children who are the subject of this
litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Melvin J. Wolfe, III
Dustin A. Wolfe
Amber L. Wolfe
December 25,1993
October 8, 1996
October 31, 1997
Father
Mother
Mother
2. The parties' first Custody Conciliation Conference was held on July 24, 2001, with
the following individuals in attendance: the Father, Melvin J, Wolfe, Jr., and his counsel, Kevin
D. Dolan, Esquire; the Mother, Christina M. Wolfe, and her counsel, Gerald S. Robinson,
Esquire.
3. The parties reached an agreement in the form of an Order as attached for a
Temporary Order with regard to custody of their Children. The parties agreed that the present
Order largely reflects the status quo. However, they agreed that it may be modified as the
needs of the Children, in particular Rusty, change.
Date
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Melissa eel Greevy, EsqUire
Custody Conciliator
MELVIN J. WOLFE, JR.,
PLAINTIFF
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
VS.
: NO. 01-3577 CIVIL TERM
CHRISTINA M. WOLFE,
DEFENDANT
: CIVIL ACTION - LAW
: CUSTODY
PRAECIPE FOR WITHDRAWAL OF APPEARANCE
Please withdraw my appearance on behalf of the Defendant, Christina M. Wolfe.
Respectfully submitted,
Dated:
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GefuId S. ROb~ ;squire
PA I.D. # ().. 7
4407 North Front Street
Harrisburg P A 17110
(717) 232-8525
PRAECIPE FOR ENTRY OF APPEARANCE
Please enter my appearance on behalf of the Defendant, Christina M. Wolfe.
Respectfully submitted,
LAW FIRM OF SUSAN KAY CANDIELLO, P.C.
Dated: ~ / d-I.€ /0 2-
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Susan Kay C e
PA I.D. # 649 8
5021 East Trin e Road
Suite 100
Mechanicsburg P A 17050
(717) 796-1930
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