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HomeMy WebLinkAbout05-4484 DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05- '1'1:1'1 CIVIL TERM vs. DENNIS E. ROBINSON, Defendant CUSTODY COMPLAINT FOR CUSTODY I. The plaintiff is Deanna M. Robinson, hereinafter referred to as Mother. Mother currently lives in Dauphin County at an address she respectfully requests this Court to keep confidential so that she may avoid the harassing, stalking, and abusive behavior of the Defendant. 2. The defendant is Dennis E. Robinson, hereinafter referred to as Father, resides at 610 Erford Road, Camp Hill, PA 17011. 3. Defendant and Mother are the parents of Evonna M. Vazquez, born October 27, 2003, hereinafter referred to as Evonna. 4. Mother seeks primary physical custody of her daughter Evonna. 5. Mother and Father are currently married but separated. 6. Evonna is currently in the custody of Defendant pursuant to a custody order entered by this Court on May 6, 2004, at the recommendation of Conciliator Melissa M. Greevy at Civil Docket No. 04-4888. A copy of that Order is attached to this Complaint. 7. Although Mother relinquished her rights to custody and visitation she has had frequent and prolonged contact with Evonna since October of2004, including: a) Sharing custody on a fifty-fifty basis between January and March 2005; b) Keeping Evonna more or less full time between June 2005 through mid-August 2005; c) At other times between November 2004 and August 2005 as Father would allow. 8. Mother has paid child support since May of 2004 and provided other cash and material assistance to the Defendant for Evonna's care including but not limted to: a) Paying for daycare expenses; b) Providing Defendant with clothes for Evonna for winter, spring and summer including coats, shoes, dresses, pants, and tops. c) Providing the Defendant with diapers on a regular basis; d) Providing the Defendant with food for Evonna on a regular basis. 9. Mother's decision to relinquish custody in May 2004 was due to her frustration with Defendant's aggressive, abusive and manipulative behaviors at all custody exchanges and Mother was coping with the following problems: a) Mother's older daughter from another relationship suffered trauma and psychological harm from the abuse she witnessed her mother endure during custody transfers and, because of the meeting times and locations Mother had no option but to bring her older daughter with her to the transfer locations; b) Mother was homeless and living at Safe Harbor and struggling to try to pressure Mother into resuming their relationship was both burdensome anli unwelcome. c) Defendant's unrelenting telephone calls, verbal abuse, harassment, and uncooperative behavior in connection with all matters relating to Evonna. lO. At the present time, Mother believes that it is in Evonna's best interest to live primarily with her for the following reasons: a) Mother is gainfully employed and can provide for Evonna; b) Mother has a stable home environment that is safe and appropriate for Evonna; c) Mother has a support system of family and friends close to her and who are available to help her with matters relating to visitation and custody transfers; e) Mother is able to spend time with Evonna and provide her daily care. f) Mother is willing to communicate with and work cooperatively with the Defendant to co-parent his daughter and will encourage both the mother/daughter and father/daughter relationship. II. Defendant has not acted in the best interest of Evonna in ways including but not limited to the following: a) Defendant uses Evonna to try and control Mother's behavior, for example, by telling her that if she gives up her boyfriend she can see Evonna. b) Defendant works a night shift and sleeps during the day even when he is the soul caretaker for Evonna; c) Mother has observed Evonna in Defendant's care being dirty, unchanged, unclothed and hungry. d) Mother fears that without a custody order in place that gives her appropriate rights, Defendant will continue to deprive her of regular contact with her daughter or, worse, manipulate her ability to see Evonna without regard to Evonna's need to stay in contact with her mother; e) Defendant is likely to be going to jail for driving with a suspended license and Mother is anxious that Evonna be placed in her care and custody during this time; f) Defendant's continued aggression, such as his recent attempt to run Mother off the road because she was with another man, show a lack of control; g) Defendant has taught Evonna behaviors that are inappropriate and causing her difficulty in daycare and social situations. 12. Each parent whose parental rights to Evonna have not been terminated and the person who has physical custody of Evonna has been named as s party to this action. WHEREFORE, Mother requests this Court to grant him the following relief: a) Grant her primary custody of Evonna. b) Grant Defendant periods of partial custody of Evonna based on a schedule that accommodates both parents and at reasonable time and protected, neutral site such as the Harrisburg Police Station; c) Establish an appropriate holiday schedule so that each party is able to have time with Evonna. d) Order that the parents shall share transportation responsibilities. e) Any additional relief the court deems proper. Respectfully submitted, Grace E. D'Alo Attorney for Plaintiff Mid Penn Legal Services 8 Irvine Row Carlisle, PAl 70 13 (717) 243-9400 MAY 0 4 2004,; It Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-488 CIVIL TERM CIVIL ACTION - LAW DENNIS E. ROBINSON, JR., v. DEANNA M. ROBINSON, IN CUSTODY Defendant OLER, J. --- TEMPORARY ORDER OF COURT AND NOW, this Ir ~ day of ~ ' 2004, upon consideration of the attached Custody Conciliation Summary R port, it is hereby ordered and directed as follows: 1. Leoal Custody. The Father, Dennis E. Robinson, Jr., shall have sole legal custody of the minor child, Evonna M. Vazquez, born October 27, 2003, and shall therefore have sole responsibility for decision making regarding the child's general well-being including but not limited to all decisions regarding her health, education and religious upbringing. 2. Physical Custody. Father shall have sole physical custody of the minor child. BY THE COURT: /sf '-). iV~ (()fJh. C). I' J~Wesley ler, Jr., J: Dis!: James H. Rowland, Jr.. Esquire, 812 N. 17th Street, Harrisburg, PA 17103.1497 Grace D'AJo, Esquire, 8 Irvine Row, Carlisle, PA 17013 rng}~~ Ct:;P'V t~ r'~,(jM r~~L'(:()rH) In r~~t111KiiiJ' Wliflf~}( i hi;... l:nw !k~ my t\ano ~;::j itill ~! Ii sail1 eoo., at (~tL~, Pa. Ii'll: ~-.JaY 'd.~ ~ JOtJ'I . C}.'1" a ?!L",I.. '. ~ . ProtlJonotarv VERIFICATION The above-named PLAINTIFF, Deanna M. Robinson, 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. 8/001 1\= Date: v< 'e:; I I Deanna 0 r--.' 0 (;..:;:. C":::J " 1::7' ... ::;:l ~-- .J_ -r (;') n'~ \~:: (T", \- (...} C;"; 0 r> ("; n ::;;, -, C;" ...( ..0 - DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05- 4'i~ICNIL TERM vs. DENNIS E. ROBINSON, Defendant CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Deanna Robinson, Plaintiff, to proceed in forma pauperis. I, Grace E. D' Ala, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. .cillo eD'Alo J e ica Diamondstone Geoffrey Biringer Attorneys for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 ----- r-' CJ 'f}~ C-J CJ ?" ..." o ... .-< ":C-n ;"ne, -:-,\1";": ..'.)";) ~ ~~\ (~), r~\)\ , - U1 ,0 <:--,-." .~ - DEANNA M. ROBINSON PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 05-4484 CIVIL ACTION LAW DENNIS E. ROBINSON DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, September 01, 2005 , upon consideration ofthe attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland County Courthouse, Carlisle on Thur.duy, October 13, 2005 , the conciliator, at 8:30 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 hearinl!. FOR THE COURT. By: /s/ Hubert X. GilroV, Esq. Custody Conciliator pi' The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For infonnation about accessible 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 HA VE 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 rf ~Jr::t',::;:t Ii0 50 '( b ""'-rJ """'(J' -A rr"if -6? ~ ~ fi 1:'.6 . yX' ~ ~ 1IrxJf'9 5O.e6 },LNf'(' ' "'I"'"' 1"\ 'oJ 60:Z \U Z-d-~sri'"" ,.., )~UV /'11',' , \UVJ..\.,';~'\i\.).-U,:.~~~d :3L'\L' ~\Q' ~'f'" "...ll....'-- :L:I !G-o:!IH - ty RECEIVED n 1 7 rn~;1PY DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW DENNIS E. ROBINSON, Defendant NO. 05-4484 IN CUSTODY COURT ORDER AND NOW, this l ~ lGmy of October, 2005, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. A hearing is scheduled in Court Room No. 1 of the Cumberland County Courthouse r~," V./ 8.COc;, on the vi /u'llay of y.e(J--' , 29&5-at / .1t2fL.m. At this hearing, the mother shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall me with the Court and opposing counsel a memorandum setting forth the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This memorandum shall be med at least five days prior to the mentioned hearing date. 2. Pending further Order of this Court, this Court's Order of May 6, 2004 is vacated and replaced with the following TEMPORARY Order: a. The father, Dennis E. Robinson, Jr., and the motber, Deanna M. Robinson, shall enjoy shared legal custody of Evouna M. Vazquez, born October 27,2003. b. The father shall enjoy primary physical custody of the minor child. ~ I 1!\" 1'_1 o h .r t! r <.:'"I'v 'c,'::) f) I I "';r1 flr'I,"1,7 ,> j <,j",].". ~ _, ',. "'" ..,,, v '"' ;!CJ c. The mother shall enjoy periods of temporary physical custody with the minor child as follows: i. Alternating weekends from Saturday at 9:00 a.m. until Tuesday at 3:00 p.m. ii. At such other times as agreed upon by the parties. 3. In the event there are any holidays that need to be addressed prior to the hearing and the parties are unable to reach an agreement with respect to visitation on holidays, legal counsel for the parties may contact the Custody Conciliator directly to conduct a Conciliation Conference over the telephone with the Conciliator then having the ability to recommend a further Order to this Court to address any holiday issues. 4. Exchange of custody shan be handled with father delivering the child to mother's home on Saturday morning. The exchange shan take place outside of the home and at 9:00 a.m. promptly. For return of custody mother shall deliver the child at 3:00 p.m. on each Tuesday to the designated daycare center which is in Harrisburg. If mother relocates, mother shan promptly notify father of her new address for exchange of custody. If father modifies the existing daycare arrangements, he shall promptly notify mother as to where to take the child on Tuesday. The parties may modify this arrangement with respect to exchange of custody as they agree. Absent an agreement, the provisions of this paragraph and the Order as set forth above shan control. BY THE COURT, c~ce D' Alo, Esquire ~es H. Rowland, Esquire -1 ~/J~ 1~11f'/oS- ~ DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW DENNIS E. ROBINSON, Defendant NO. 05-4484 IN CUSTODY Prior Judge: J. Wesley Oler CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Evonna M. Vazquez, born October 27,2003. 2. A Conciliation Conference was held on October 13, 2005, with the following individuals in attendance: The father, Dennis E. Robinson, with his counsel, James H. Rowland, Jr., Esquire and the mother, Deanna M. Robinson, with her counsel, Grace D' Alo , Esquire. 3. The history in this case is that mother basically relinquished custody to the father in May of 2004. However, mother says that since that time she has seen the child on numerous occasions and has had overnight custody on numerous occasions. Father disagrees. The parties seem to have a dramatic difference of opinion with respect to the factual history of this case. For example, mother suggests that she has had the child approximately four months of overnight contact in 2005, while the father suggests that it was no more than ten days. It was clear to the Conciliator that the mother has been exercising some custody with the minor child since the May 2004 Order. Father even suggested that the parties romantically reconciled since that time. 4. Mother is requesting every weekend from Saturday to Tuesday. Father is suggesting that he would agree to alternating weekends. The Conciliator notes that the mother works on every other Saturday. Based upon on the current status quo (which is difficult to determine in light of the disagreement between the parties on what is exactly happening right now) and the prior Order the Conciliator is recommending that mother have alternating weekends from Saturday until Tuesday. Mother desires more time than what is being suggested, while father is in agreement with the Conciliator's recommendation. However, the mother has requested a hearing and the Conciliator recommends an Order in the form as attached. 10-(7- D ~ DATE (]L~J fJJ'~1 I Hubert X. Gilroy, Esquire Custody Conciliator . ~ DEANNA M. ROBINSON, vs. DENNIS E. ROBINSON, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-4484 CIVIL TERM CUSTODY PRAECIPE TO WITHDRAW COMPLAINT To the Prothonotary: Please withdraw without prejudice the Complaint in Custody brought by Plaintiff, Deanna Robinson, in the above captioned case. Respectfully submitted: C\C~ ~.. ,\JcDD Gr e E. D'Alo, Esq, M PENN LEGAL SERVICES 401 East Louther Street Carlisle, P A 17013 (717) 243-9400 .' (~J ~~\ :. ..-:-' {.f" ~"\ ~~.} I.:.,.J _-A :...t::- ',;' -- c' ..~' --. I.;? "'.~ (~, "~ -' J- .... L"y RECEIVED FE8 2 ,7'"' IJA<( DEANNA M. ROBINSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 05-4484 CIVIL TERM DENNIS E. ROBINSON, Defendant CUSTODY ORDER AND NOW, this 2- 2.. J day of Feb , 2006, the Custody Complaint filed by the Plaintiff in the above captioned case is hereby withdrawn without prejudice to either party. BY THE COURT ~ J. J---- ..J 3-. (J G, ~ .I~~J..~ ~% . ~J C-) r."J ':;-"J ,~- lL C' DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COMMOM PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA CIVIL ACTION - LAW vs. NUMBER: 05-4484 DENNIS E. ROBINSON, JR., Defendant IN CUSTODY MOTION TO MODIFY CUSTODY ORDER NOW COMES the Plaintiff, DEANNA M. ROBINSON, by her attomey, Charles E. Petrie, and respectfully represents as follows: 1. Plaintiff is DEANNA M. ROBINSON, who currently resides at 420 Green Springs Road, Newville, County of Cumberland, Pennsylvania. 2. Defendant is DENNIS E. ROBINSON, JR., who currently resides at an address unknown to Plaintiff. 3. Plaintiff and Defendant are the natural parents of a minor child, EVONNA MARIE VAZQUEZ, bom October 27,2003. 4. That on October 18, 2005, a Custody Order was entered by the Honorable J. Wesley Oler granting temporary physical and shared legal custody to Plaintiff. A copy of said Order is attached hereto. 5. Plaintiff seeks an Order of primary physical custody. ,. WHEREFORE, Plaintiff respectfully requests that Your Honorable Court modify the Order granting Plaintiff primary physical custody of the minor child. Respectfully submitted, ~f~ CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiff ty R!""C,!\lcn C. [,1 L...LJ 1 ,.., '11'01 r , ,,' ':!" Any ~ i'..' '"'oY''' DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW DENNIS E. ROBINSON, Defendant NO. 05-4484 IN CUSTODY COURT ORDER AND NOW, this l"'6 tLaay of October, 2005, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. A hearing is scheduled in Court Room.No. 1 of the Cumberland County Courthouse ." A"" ~ClJc:' on the v(B/u'aay of jIe;t,- r , 2005-at / '7tL.f2- .m. At this hearing, the mother shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall fIle with the Court and 9Pposing counsel a memorandum. setting forth the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This memorandum shall be fIled at least five days prior to the mentioned hearing date. 2. Pending further Order of this Court, this Court's Order of May 6, 2004 is vacated and replaced with the following TEMPORARY Order: a. The father, Dennis E. Robinson, Jr., and the mother, Deanna M. Robinson, shall enjoy shared legal custody of Evonna M. Vazquez, born October 27,2003. b. The father shall enjoy primary physical custody of the minor child. c. The mother shall enjoy periods of temporary physical custody with the minor child as follows: i. Alternating weekends from Saturday at 9:00 a.m. until Tuesday at 3:00 p.m. ii. At such other times as agreed upon by the parties. 3. In the event there are any holidays that need to be addressed prior to the hearing and the parties are unable to reach an agreement with respect to visitation on holidays, legal counsel for the parties may contact the Custody Conciliator directly to conduct a Conciliation Conference over the telephone with the Conciliator then having the ability to recommend a further Order to this Court to address any holiday issues. 4. Exchange of custody shall be handled with father delivering the child to mother's home on Saturday morning. The exchange shall take place outside of the home and at 9:00 a.m. promptly. For return of custody mother shall deliver the child at 3:00 p.m. on each Tuesday to the designated daycare center which is in Harrisburg. If mother relocates, mother shall promptly notify father of her new address for exchange of custody. If father modifies the existing daycare arrangements, he shall promptly notify mother as to where to take the child on Tuesday. The parties may modify this arrangement with respect to exchange of custody as they agree. Absent an agreement, the provisions of this paragraph and the Order as set forth above shall control. BY THE COURT, c~ce D'Alo, Esquire , ~es H. Rowland, Esquire '-l ~)/Ud 7/~~'/ itJIIFI(}~ ~ , f\' \Lb 10 DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW DENNIS E. ROBINSON, Defendant NO. 05-4484 IN CUSTODY Prior Judge: J. Wesley Oler CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Evonna M. Vazquez, born October 27,2003. 2. A Conciliation Conference was held on October 13, 2005, with the following individuals in attendance: The father, Dennis E. Robinson, with his counsel, James H. Rowland, Jr., Esquire and the mother, Deanna M. Robinson, with her counsel, Grace D' AIo , Esquire. 3. The history in this case is that mother basically relinquished custody to the father in May of 2004. However, mother says that since that time she has seen the child on numerous occasions and has had overnight custody on numerous occasions. Father disagrees. The parties seem to have a dramatic difference of opinion with respect to the factual history of this case. For example, mother suggests that she has had the child approximately four months of overnight contact in 2005, while the father suggests that it was no more than ten days. It was clear to the Conciliator that the mother has been exercising some custody with the minor child since the May 2004 Order. Father even suggested that the parties romantically reconciled since that time. 4. Mother is requesting every weekend from Saturday to Tuesday. Father is suggesting that he would agree to alternating weekends. The Conciliator notes that the mother works on every other Saturday. Based upon on the current status quo (which is difficult to determine in light of the disagreement between the parties on what is exactly happening right now) and the prior Order the Conciliator is recommending that mother have alternating weekends from Saturday until Tuesday. Mother desires more time than what is being suggested, while father is in agreement with the Conciliator's recommendation. However, the mother has requested a hearing and the Conciliator recommends an Order in the form as attached. IO-tt- D ~ DATE iJiJ fJ4 Hubert X. Gilroy, Esquire/ Custody Conciliator / COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I verify that the statements in the foregoing Motion 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. ~- t9- 00 DATE DEAN i0 ~ ~ ~ 'II; ~ """ D ~ ~ ~ W F '8 J- ".~ _w f"..) - ;"--." (:,:~) .<. f-,) '. DEANNA M. ROBINSON PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 05-4484 CIVIL ACTION LAW DENNIS E. ROBINSON. JR. DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, June 22, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday. Au~ust 17,2006 , the conciliator, at 2:30 PM 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 deline and narrow the issues to be heard by the court, and to enter into a temporary order. All children age live 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 hearin~. FOR THE COURT. By: Isl Hubert X. Gilrov. Esq. Custody Conciliator p'fy" The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For infonnation about accessible 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 HA VE 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 , rf ""'t'f?'" 11 "": ~ 4"'J 10,ee 1 ~ ~ tk--"'" r': ~ ,..,. "'" -":o/'d Y :7 ~ ~ qq,f!e,? ~ jp ~ "7l ,.'" "'" -f"? 'J{/' "",-9 "1'';''(\) "(., ,\,.'. \' "\)~ 1. , \\ ' I \" \\ -J \~., ,clCV' ,;:).0 .\,- . \'J' ,'c ':;Al-;;l' , ,_' ',"_: ", :.,':, ',':_'_~U .,..JI \ "e:'\t \ \J\'....~-.i' .'.~r::' ("\.- '~.'""\\ \ 1\,\..I~. _:~"),,~;<;<I,.~ \,-,J . DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COMMOM PLEAS OF CUMBERLAND COUN1Y, PENNSYLVANIA vs. NUMBER: 05-4484 CML ACTION LAW DENNIS E. ROBINSON, JR., Defendant IN CUSTODY PETITION FOR EMERGENCY CUSTODY RELIEF TO THE HONORABLE J. WESLEY OLER, JUDGE NOW COMES Plaintiff, DEANNA M. ROBINSON, by and through her attomey, Charles E. Petrie, and respectfully represents as follows: 1. Plaintiff is DEANNA M. ROBINSON, who currently resides at 420 Green Springs Road, Newville, County of Cumberland, Pennsylvania. 2. Defendant is DENNIS E. ROBINSON, JR., who currently resides at 1104 Route 47, Rio Grande, New Jersey. 3. Plaintiff and Defendant are the natural parents of a minor child, EVONNA MARIE VAZQUES, bom October 27,2003. 4. That on October 18, 2005, the Honorable J. Wesley Oler entered an Order granting primary physical custody of the minor child to the Defendant and temporary physical custody to the Plaintiff. 5. That on June 21, 2006, Plaintiff filed a Motion to Modify Custody and a Custody Conciliation Conference is scheduled for August 17, 2006, at 2:30 P.M. Copies of said Order and Motion are attached hereto. 6. That on June 30, 2006, Defendant was served with a copy of the Order of Court and Motion to Modify. 7. The following events have occurred that warrant the filing of this Petition for Emergency Custody Relief: a. The minor child suffered a broken leg on June 4, 2006, while in the care of Defendant's girlfriend. b. That on Friday, June 9,2006, Defendant dropped off the minor child to reside with the Plaintiff because the Defendant reported that he was homeless. c. Defendant promised that he would see the minor child every Thursday and Sunday. He visited the child only once since June 9, on Father's Day for about two hours. Defendant never spoke to Plaintiff about returning custody of the child to Defendant. d. Plaintiff filed a Motion to Modify Custody on June 21, 2006, to have primary physical custody changed to Plaintiff. e. The Custody Conciliation Conference is scheduled for August 17,2006, at 2:30 p.m. f. Defendant was served on June 30, 2006, by certified mail with a copy of the Motion and Order scheduling the conference. g. Defendant is now attempting to retrieve custody of the child. On July 6, 2006, Defendant went to the home of Mary West, the child's babysitter, and repeatedly drove up and down the street and called Ms. West repeateffiy from his cell phone demanding the child. Defendant has called Plaintiff repeatedly demanding the immediate retum of the child to Defendant. Plaintiff refuses to retum the child to Defendant because Plaintiff fears another injury to the child and Plaintiff knows nothing of Defendant's residence. WHEREFORE, Plaintiff respectfully requests that Your Honorable Court enter an Order granting Plaintiff primary physical custody of the subject minor child until further order of court. Respectfully submitted, ~c4- CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attomey for Plaintiff ;y tlr-CElij~.O r""'~ -I,-.t '}f"f'1i ' fit: 1'1 C.' c",.' ,! ""./;)y DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL. ACTION - LAW DENNIS E. ROBINSON, Defendant NO. 05-4484 IN CUSTODY COURT ORDER AND NOW, this l "6IGiay of October, 2005, upon cousideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. A hearing is scheduled in Court Room No.1 of the Cumberland County Courthouse on the ;J-3#uayof ,SIa~, , fo,"~t Dtlp-.m. At this hearing, the mother shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall me with the Court and ,opposing counsel a memorandum setting forth the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This memorandum shall be fIled at least five days prior to the mentioned hearing date. 2. Pending further Order of this Court, this Court's Order of May 6, 2004 is vacated and replaced with the following TEMPORARY Order: a. The father, Dennis E. Robinson, Jr., and the mother, Deanna M. Robinson, shall enjoy shared legal custody of Evonna M. Vazquez, born October 27,2003. b. The father shall enjoy primary physical custody of the minor child. c. The mother shall enjoy periods of temporary physical custody with the minor child as follows: i. Alternating weekends from Saturday at 9:00 a.m. until Tuesday at 3:00 p.m. ii. At such other times as agreed upon by the parties. 3. In the event there are any holidays that need to be addressed prior to the hearing and the parties are unable to reach an agreement with respect to visitation on holidays, legal counsel for the parties may contact the Custody Conciliator directly to conduct a Conciliation Conference over the telephone with the Conciliator then having the ability to recommend a further Order to this Court to address any holiday issues. 4. Exchange of custody shall be handled with father delivering the child to mother's home on Saturday morning. The exchange shall take place outside of the home and at 9:00 a.m. promptly. For return of custody mother shall deliver the child at 3:00 p.m. on each Tuesday to the designated daycare center which is in Harrisburg. If mother relocates, mother shall promptly notify father of her new address for exchange of custody. If father modifies the existing daycare arrangements, he shall promptly notify mother as to where to take the child on Tuesday. The parties may modify this arrangement with respect to exchange of custody as they agree. Absent an agreement, the provisions of this paragraph and the Order as set forth above shall control. BY THE COURT /1 t ;; In ge J. Wes / /; '} ccc..%race D' Alo, Esquire . . ,,' . ,res H. ROWla. nd, Esquire .~ ~'V5 ~ ~. ,.::7~,,/ 'Db\i.~ ~0W /10 X/ .; ~ ).~,?, ,r' i tJ If piuS- .Au (~ LV j(Y \ U DEANNA M. ROBINSON PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. 05-4484 CIVIL ACTION LAW DENNIS E. ROBINSON, JR. DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, June 22, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. . the conciliator, at 4th Floor. Cumberland County Courtbouse, Carlisle on Thursday, AU2ust 17, 2006 at 2:30 PM 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 hearin!!.. FOR THE COURT. By: Isl Hubert X Gilroy, 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 infonnation about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact ollr office. All arrangements mllst be made at least 72 hOllrs prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 'I'N ,."......\A r.ECORD TRUE t"',r:.' " '. " ,j IICIto set my \'land \II Testill\f'" , !1 , "" ., ,.....isle Po. IInd t\'le s.,;', c:' s.,: .~,:.h\ at \081' , ..::;I~ ........ . ...::l~. uJ J of.. "..".., ;;J;::,L Th!l .."wr.."",..". I K ~''I' t-..u....~....".".PI~~. DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COMMOM PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VB. NUMBER: 05-4484 CIVIL ACTION LAW DENNIS E. ROBINSON, JR., Defendant IN CUSTODY AFFIDAVIT OF SERVICE CHARLES E. PETRIE, Esquire, being duly sworn according to law, deposes and states that he served a true and correct copy of the ORDER OF COURT and MOTION TO MODIFY CUSTODY ORDER, upon DENNIS E. ROBINSON. JR.. defendant, in the above-captioned matter, by mailing a true and correct copy of same by U.S. Certified Mail, return receipt requested, Article Number 70042510000683676661 postage prepaid, on June 26. 2006, to the following address: Name: Dennis E. Robinson, Jr. Address: 1104 Route 47 (rear House), Rio Grande, NJ 08242 Defendant personally received said documents on June 30.2006, as evidenced by his signature on the certified mail return receipt card which is attached hereto and marked Exhibit "A". I verify that the statements in the foregoing Affidavit 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. . Complele II1lms 1. 2. and 3. Also complete Item 4 n Restrtcled 0eI1ve1y Is desired. . PrInt your name and add",.,'-an the _ 80 thai we can Illlum tha ClIId to you. II AIIIii::h thl. C8fd.to the back of the mallplece, or an the ,space permI\B. 1. Ar1IcIeAdd_to: Dennis E. Robinson, Jr. 110t Route 47 (Rear House) Rio Grande, NJ 08242 X "~!>y( ~(l ~ D.lodelMlry__fnlmll8ml? KYES,_t\eINert __ 3'iE~ COrtlfIod Mall C ElCpI-. Mall RogIoIe.od C RotwnRocelptlotMt.......odlae e_MaIl . C c,Q.p. 4. __ DoIIv8ry? (Ex/nI Fee} 'Ills 2.Ar1IcIe_ r--~/IIbeIJ PS Fon113811. August 2001 7004 2510 0006 8367 b661 IlomeotIc Return ReceIpt_ (J;J~d 'I 1Q26D5o(12.M.1S40 COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I verify that the statements in the foregoing Petition 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. (~ (- O~ DATE . . DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COM MOM PLEAS OF CUMBERLAND COUNTI, PENNSYLVANIA vs. NUMBER: 05-4484 CML ACTION LAW DENNIS E. ROBINSON, JR., Defendant IN CUSTODY CERTIFICATE OF SERVICE I, KELLY P. ROBERTS, Paralegal, for Attorney Charles E. Petrie, hereby certify that on July 7,2006, a true and correct copy of the attached Petition for Emergency Custody Relief, was served by First class mail, postage prepaid on the following: DENNIS E. ROBINSON, JR. 1104 ROUTE 47 RIO GRANDE, NJ 08242 JAMES H. ROWLAND, JR., ESQUIRE 812-A NORTH 17TH STREET HARRISBURG, PA A copy was served by fax on July 7, 2006 to number (717) 233-8137 HUBERT X. GILROY, ESQUIRE 4 NORTH HANOVER STREET CARLISLE, PA 17013 DATED: Julv 7.2006 CHARLES E. PETRIE, ESQUIRE elly P. oberts 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 (') r-~') C) ,"'; ,., " '''j1 r t ~ c;.. ~;-' <-~.~ :::1 -.'''''' ". ~ , -, _.J """ <:> '7 - .. .. " r,,) .Ji V; I " C~'1 c:. '6 vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-4484 CIVIL ACTION LAW DEANNA M. ROBINSON, Plaintiff DENNIS E. ROBINSON, JR., Defendant : IN CUSTODY RESPONSE TO E~R.GENCY CUSTODY IY:LIEF PETmON 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. a. Denied. It is admitted that the child injured her leg on June 4, 2006. However, the Defendant was present, and the child was playing with three other children on a trampoline. b. The Defendant has never been homeless, nor has he ever told the Defendant he was homeless. As a matter of fact, the Defendant has lived at the New Jersey address alleged in this petition since January 2006. c. Denied. The Defendant visited the child on Fathers' Day all day. Since then, the Plaintiff has made the child unavailable to him. When he did show up to get the child, the Plaintiff had moved from the address listed in the petition and no one knows of her whereabouts. d. Admitted. The petition is simply a ruse to get primary physical custody prior to the scheduled custody hearing and in contradiction of the existing court order. e. Admitted. f. Admitted. g. Admitted in part. The date was July 7, 2006. 8. The respondent has made repeated attempts to get the child back of which he has had primary custody since April 2004. The child has had no other injuries and has been well cared for. WHEREFORE, Defendant respectfully requests Your Honorable Court deny the request for Emergency Relief because the health, welfare and safety of the child is not in jeopardy. Plaintiff should be ordered to comply with the existing order until the scheduled conciliation hearing scheduled for August 17,2006. Respectfully submitted. c. /1 1.1 , J.~ {}. ~es H. Rowland, Jr., Esquire 812 N. 17th St. Harrisburg, PA 17103 (717) 233-6787 Attorney for Defendant VERIFICATION I, DENNIS E. ROBINSON, JR., hereby certify that the statements within the foregoing document are true and correct to the best of my knowledge, information, and belief, and further state that false statements herein are made subject to the penalties of 18 Pa. C.S.~ 4904 relating to unsworn falsification to authorities. DATE: 7/7~b . . CERTIFICATE OF SER.VICE AND NOW, this ,',-" day of j.... ('1 ,2006, I, JAMES H. ROWLAND, JR., do hereby certify that I did serve the foregoing document by placing it in the United States mail, postage prepaid, addressed to the following: Charles E. Petrie, Esquire 3528 Brisban Street Harrisburg, P A 17111 Attorney for Plaintiff q_ 1-1, ;(....,_ 1 frames H. Rowland, Jr., Esquire 812 N. 17th Street Harrisburg, PA 17103 (717) 233-6787 Attorney for Defendant ~ I~ ( f ,. , C.-.' (. :-:::1 , " ;-, .....~ ~, c DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COM MOM PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. DENNIS E. ROBINSON, JR., Defendant NUMBER: 05-4484 CIVIL ACTION LAW IN CUSTODY AFFIDAVIT OF SERVICE CHARLES E. PETRIE, Esquire, being duly sworn according to law, deposes and states that he served a true and correct copy of the ORDER OF COURT and MOTION TO MODIFY CUSTODY ORDER, upon DENNIS E. ROBINSON. JR.. defendant, in the above-captioned matter, by mailing a true and correct copy of same by U.S. Certified Mail, return receipt requested, Article Number 70042510000683676661 postage prepaid, on June 26. 2006, to the following address: Name: Dennis E. Robinson, Jr. Address: 1104 Route 47 (rear House), Rio Grande, NJ 08242 Defendant personally received said documents on June 30.2006, as evidenced by his signature on the certified mail return receipt card which is attached hereto and marked Exhibit "A". I verify that the statements in the foregoing Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ec!Wn 4904, relating to unsworn falsification to authorities. . )' { cd-- PETRIE OR PLAINTIFF (2 ~, .~ ',-=-:~) i~"" ~-~~\ :-.;! \ .-I - - (jl c;:; " DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DENNIS E. ROBINSON, JR., Defendant NO. 05-4484 CIVIL TERM ORDER OF COURT AND NOW, this 10th day of July, 2006, upon consideration of Plaintiffs Petition for Emergency Custody Relief and of Defendant's Response to Emergency Custody Relief Petition, a hearing is scheduled for Thursday, July 20, 2006, at 10:45 a.m., in Courtroom No.1, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, Charles E. Petrie, Esq. 3528 Brisban Street Harrisburg, P A 17111 Attorney for Plaintiff James H. Rowland, Jr., Esq. 812 N. 17th Street Harrisburg, PA 17103 Attorney for Defendant . ?...II...O~ ~~ 0... :rc (" ,', ,; ') ! . DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW DENNIS E. ROBINSON, JR., Defendant 05-4484 CIVIL TERM IN RE: EMERGENCY PETITION ORDER OF COURT AND NOW, this 20th day of July, 2006, upon consideration of Plaintiff's Petition for Emergency Custody Relief with respect to the parties' child, Evonna Marie Vazques (date of birth, October 27, 2003), and following a hearing held on July 20, 2006, it is ordered and directed pending the scheduled conciliation conference and further Order of Court as follows: 1. Legal custody of the child shall be shared by the parties; 2. Physical custody of the child shall be shared by the parties on an alternating weekly basis, with Defendant Father's first weekly period commencing on Friday, July 21, 2006, at 7:30 p.m., and ending on Friday, July 28, 2006, at 7:30 p.m.; 3. Responsibility for transportation with respect to exchanges of custody shall be that of the party receiving custody; and 4. Nothing herein is intended to preclude "'"" -:.':) i.::J ---10' ~ '",) f-- ~'J . , the parties from deviating from the terms of this order by mutual agreement. ~arles E. Petrie, Esquire 3528 Brisban Street Harrisburg, PA 17111 For Plaintiff ~mes H. Rowland, Jr., Esquire 812 North Seventeenth Street _\ Harrisburg, PA 17013 ~ For Defendant :mae By the Court, J. \0 ~D ,~ \)<\ DEANNA M. ROBINSON, Plaintiff , , . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 05-4484 CIVIL ACTION - LAW DENNIS E. ROBINSON, JR., Defendant IN CUSTODY COURT ORDER AND NOW, this 2.~ 1:L day of August, 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Courtroom No. 1 of the Cumberland County Courthouse on the ~ day of 100"" 0 ALl J.R..A.J , 2006 at q: 3() -'L. m. At this hearing, the Father shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall me with this Court and opposing counsel a Memorandum setting forth the history of custody in this case, the issues currently before the Court, a summary of each party's position on these issues, a list of witnesses who will be called to testify on behalf of each party, and a summary of anticipated testimony of each witness. This Memorandum shall be med at least five days prior to the mentioned hearing date. 2. Pending further order of this Court, this Court's temporary Order of July 20, 2006 providing the parties share custody on a weekly basis shall remain in effect. 3. In order to address a week where Father missed custody with the child, custody of the child shall be delivered to the Father on Thursday, August 17, 2006. The alternating weekend schedule shall then commence again on September 9"' at 4:00 p.m. on Saturday afternoon, when the parties shall exchange custody and physical custody shall be alternated weekly from that time until the date of the hearing. . ' . I \ i \ i I I \ I 1 \ V;N~h\l/~S~,JNjd I "ICY"'" ,'C .. ," '-'~'''n'' 1\'.l.J\J ~r..j) ,:,,,,,~~:~!t~'1'l V S2 :01 ~lV Of: mw 900l lU\.J'r' ,,0<' ,~,' , ~Hl :10 ^CJvl;,)i'~l.;r-u..,.\:;Q ;:J :n,::UCHEllI:J , , 4. The location for exchange of custody shall be at a point determined to be equally distant between the Mother's home and the Father's home. Legal counsel for the parties shall communicate with each other on that issue and, in the event there is no agreement that can be reached, they may contact the Conciliator directly via telephone to have a telephone conference with the Conciliator. The Conciliator may then recommend an order to this Court addressing the point of exchange of custody. BY THE COURT, J. ~ ~ ~"'j o ~d~ Cc: James H. Rowland, Jr., Esquire Charles E. Petrie,Esquire , . DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 05-4484 CML ACTION - LAW DENNIS E. ROBINSON, JR., Defendant IN CUSTODY Prior Judge: The Honorable J. Wesley Oler, Jr. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WIm THE CUMBERLAND COUNTY CML RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. Tbe pertinent information pertaining to the child who is the subject of this litigation is as follows: Evouna M. Vasquez, born October 27,2003 2. A Conciliation Conference was held on August 17, 2006 with the following individuals in attendance: The Mother, Deanna M. Robinson, with her counsel, Charles E. Petrie, Esquire The Father, Dennis E. Robinson, Jr., with his counsel, James H. Rowland, Jr., Esquire 3. The Conciliator handled this case in October of 200S and, not unexpectedly, there have been quite a bit of developments since that time. The Father has relocated to New Jersey. There was an Incident earlier this summer when Mother suggested that Father relinquisbed custody of the child to her. Mother then med an action to modify support. The Father then came back to try to pick up the child and was refused custody. The Mother then med a Petition for Emergency Relief. After a bearing, Judge Oler ordered a temporary situation of a week- on/week-otT. Since that time, there was an incident when Father attempted to pick up the child and ran into difficulty because he was a few hours late (apparently without notifying the Mother in advance according to the Mother, but not according to the Father). The Father also suggests that there is some problem with an exchange of custody at the Mother's home in Newville because of Father's suggestion that the Mother's stepfather has shown animosity toward the Father. 4. The Father is still of the position that he should be primary custodian for a variety of reasons and is demanding a hearing. A hearing should be scheduled. The Conciliator recommends that the Father is entitled to one week to cover the week he lost earlier in August, and the Conciliator is recommending an Order to address that issue. The Conciliator also feels that the point of exchange of custody needs to be addressed, and that will also be included in the proposed Order. S. The Conciliator recommends an Order in the form as attached. Date: August d l ,2006 DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COMMOM PLEAS OF CUMBERLAND COUN1Y, PENNSYLVANIA VS. NUMBER: 05-4484 CMLACTION LAW DENNIS E. ROBINSON, JR., Defendant IN CUSTODY PETITION FOR I'IRDIRG 01' CO.TEMPT 01' ORDER 01' COURT ARD FOR MODIFICATION OF ORDBR OF COURT CONTBMPT OF ORDER OF COURT TO THE HONORABLE J. WESLEY OLER, JUDGE NOW COMES Plaintiff, DEANNA M. ROBINSON, by and through her attorney, Charles E. Petrie, and respectfully represents as follows: 1. Plaintiff is DEANNA M. ROBINSON, who currently resides at 420 Green Springs Road, Newville, County of Cumberland, Pennsylvania. 2. Defendant is DENNIS E. ROBINSON, JR., who currently resides at 1104 Route 47, Rio Grande, New Jersey. 3. Plaintiff and Defendant are the natural parents of a minor child, EVONNA MARIE VAZQUES, born October 27,2003. 4. That on August 28,2006, the Honorable J. Wesley Oler entered an Order directing that physical and legal custody of the minor child shall be shared by the parties. A copy of the Order is attached hereto. 5. The Order requires that "The location for the exchange of custody shall be at a point determined to be equally distant between the Mother's home and the Father's home." The parties determined that the meeting place for the exchange of custody would be at the Philadelphia Zoo, even though that is not the midpoint location. 6. On Sunday, October 8, 2006, the parties were to meet at the Philadelphia Zoo for Plaintiff to pick up the child for her custody week. 7. Defendant did not appear at the appointed location on October 8 with the child for Plaintiff to have her week of custody with the child. 8. Plaintiff called Defendant from the Philadelphia Zoo at the agreed- upon time and Defendant told Plaintiff that "since she was already at the Zoo, she should continue to drive to Defendant's home in Wildwood, New Jersey, to pick up the child." 9. Defendant's actions violate the Order of Court entered on August 28, 2006. WHEREFORE, Plaintiff respectfully requests that Your Honorable Court enter an Order finding Defendant to be in contempt of an Order of Court and providing such relief as Your Honorable Court may deem just and proper. MODIFICATION OF COURT ORDER 10. Plaintiff hereby incorporates paragraphs 1 through 9 above as if fully set forth herein. 11. The point determined to be equally distant between the Mother's home and the Father's home is not at the Philadelphia Zoo, but rather at the King of Prussia Mall in King of Prussia, Pennsylvania. WHEREFORE, Plaintiff respectfully requests that Your Honorable Court amend the Order of August 28, 2006, to state that the exchange of custody location shall be at the King of Prussia Mall. Respectfully submitted, ~~ CHARLES E. PETRIE 3528 Bnsban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiff DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COMMOM PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. NUMBER: 05-4484 CML ACTION LAW DENNIS E. ROBINSON, JR., Defendant IN CUSTODY CERTIFICATE OF SERVICE I, KELLY P. ROBERTS, Paralegal, for Attorney Charles E. Petrie, hereby certify that on October 11, 2006, a true and correct copy of the attached Petition for Emergency Custody Relief, was served by First class mail, postage prepaid on the following: JAMES H. ROWLAND, JR., ESQUIRE 812-A NORTH 17TH STREET HARRISBURG, PA A copy was served by fax on October 11, 2006 to number (717) 233-8137 HUBERT X. GILROY, ESQUIRE 4 NORTH HANOVER STREET CARLISLE, PA 17013 DATED: October 11. 2006 CHARLES E. PETRIE, ESQUIRE lly P. 0 berts 3528 Bnsban Street Harrisburg, PA 17111 (717) 561-1939 COMMONWEALTH OF PENNSYLVANIA COUN1Y OF DAUPHIN I verify that the statements in the foregoing Petition 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. JO-- \l -0 CO DATE ~...._____~....~-"'J" .c~C.f:4;IVED AUG 2 8 2006 BY: ~ DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 05-4484 CIVIL ACTION - LAW DENNIS E. ROBINSON, JR., Defendant IN CUSTODY COURT ORDER AND NOW, this 1 <( l-h day of August, 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Courtroo~O. 1 of *e Cumberland Couuty Courthouse on the 7+h day of WI'Il11l11:t..h ) , 2006 at 9:30 tV. . m. At this hearing, the Father shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with this Court and opposing counsel a Memorandum setting forth the history of custody in this case, the issues currently before the Court, a summary of each party's position on these issues, a list of witnesses who will be called to testify on behalf of each party, and a summary of anticipated testimony of each witness. This l'y1CUiGranrlum shall be filed at least five days prior to the mentioned hearing date. 2. Pending further order of this Court, this Court's temporary Order of July 20, 2006 providing the parties share custody on a weekly basis shall remain in effect. 3. In order to address a week where Father missed custody with the child, custody of the child shall be delivered to the Father on Thursday, August 17, 2006. The alternating weekend schedule shall then commence again on September 9th at 4:00 p.m. on Saturday afternoon, when the parties shall exchange custody and physical custody shall be alternated weekly from that time until the date of the hearing. 4. The location for exchange of custody shall be at a point determined to be equally distant between the Mother's home and the Father's home. Legal counsel for the parties shall communicate with each other on that issue and, in the event there is no agreement that can be reached, they may contact the Conciliator directly via telephone to have a telephone conference with the Conciliator. The Conciliator may then recommend an order to this Court addressing the point of exchange of custody. BY THE COURT, Cc: James H. Rowland, Jr., Esquire Charles E. Petrie,Esquire \\ ~ , ~ " , ~~ ~'. ..s:;,~ -~ ~ ~ ~ 0 '::.> -n c."~ C') ("; --f - en \.0 DEANNA M. ROBINSON PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 05-4484 CIVIL ACTION LAW DENNIS E. ROBINSON, JR. DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, October 13, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland County Cout:!house, Carlisle on Thursday, November 30, 2006 , the conciliator, 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: Isl Hubert X Gilrov, Esq. tr}t Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabi1ites Act of 1990. For infonnation 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 HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORnI BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 170 I 3 Telephone (717) 249-3166 - vf ~ fr ~~ 4vJ ?O'(j.O/ ~. P :p ~ ~Jt., 117'(/-0/ ~ ~ :2 ~ ~ 'r'? :?c?-LI-t7/ :(0 4-; 1 :(: L I LiO seaz A~d\{LCj' ,0, NOV 0 2 2006 I)/J r , DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 05-4484 CIVIL ACTION - LAW DENNIS E. ROBINSON, JR., Defendant IN CUSTODY COURT ORDER AND NOW, this 6,.1 day of f\jov , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Petition for Contempt filed by the Plaintiff shall be addressed by this Court at the hearing which is already scheduled for December 7, 2006 at 9:30 a.m. 2. Pending said hearing, the parties shall continue to abide by the existing Order relative to the exchange of custody at a point equally distant between the Mother's home and the Father's home. Failure of the parties to abide by this provision in the existing Order will also be addressed at the December 7th hearing. The November 15,2006 conciliation conference is cancelled. BY THE COURT, ?;. L.'.? ~:;:~) ,,:\)t~ ,"--"<t , .~.- i~~.;-\ 0- duJ \..\-~ r- '6 co - - o:"~.- .....- c- ("') \ b ~ ~_o C'~ ~ ~ ~.;..- .:~~~.- -~ -:j ,','," ....~.Y- ~ ~~;' ...;---:;. ~.t:. ? o . ) DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. : NO. 05-4484 CIVIL ACTION - LAW DENNIS E. ROBINSON, JR., Defendant IN CUSTODY Prior Judge: The Honorable J. Wesley Oler, Jr. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The Conciliator had a discussion with legal counsel for the parties in a telephone conference on October 31, 2006 to address the Petition for Contempt filed by the Plaintiff. As a result of that discussion, the Conciliator recommends an Order in the form as attached. , 2006 Date: November?' DEe 0 8 2006~ DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 05-4484 CIVIL ACTION - LAW DENNIS E. ROBINSOl\, JR., Defendant IN CUSTODY COURT ORDER / t<J J" 1'\ ~ AND NOW, thjls f- day of 0 ~. , 2006, the Conciliation having appeared for a Conference on November 30, 2006 and nor parties or their attorneys being in attendance, the Conciliator relinquishes jurisdiction. >- Cr ;:!; lu9 ~~6 1--!- .....:-: '''.' - ;::: 'YC.l ac~ :..w 0_ w!lW iE ~ l.O N 0::> .,..... _\>_ cq ,..... , W lw o -..c:> = = ~ .-~" DEANNA M. ROBINSON, (NOW Deanna Vasquez) Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW DENNIS E. ROBINSON, JR., Defendant NO. 05-4484 CIVIL TERM ORDER OF COURT AND NOW, this 8th day of December, 2006, upon consideration of Plaintiffs Petition for Finding of Contempt of Order of Court and for Modification of Order of Court, and of the general issue of custody with respect to the parties' child, Verona Marie Vasquez (i.e. October 27, 2003), and of the general issue of custody with respect to the parties' child, Verona Marie Vasquez (i.e. October 27, 2003), it is ordered and directed as follows: 1. Defendant is adjudicated in contempt and sanctioned with payment of the sum of$500.00 to the use of the county; 2. The custodial terms of the order of Court dated August 28, 2006, shall remain in full force and effect, except as modified as follows: a. The parties' weekly periods of physical custody shall commence on Sunday at 3:00 p.m. and end on the following Sunday at 3:00 p.m.; Defendant's next period of weekly physical custody shall commence on Sunday, December 17, at 3:00 p.m. b. Exchanges of custody shall take place at the inside entrance of the J.C. Penny establishment at the King of Prussia Mall; in the event that the party to receive custody is more than one-half hour late for the transfer, he or she shall be deemed to have forfeited that -- L period of custody; Plaintiff s stepfather shall not be on the premises of the mall during the custody exchange; c. During the Christmas period, Plaintiff shall have custody of the child from December 24 at 3 :00 p.m. until December 31 at 3 :00 p.m. in even numbered years, and Defendant shall have custody of the child from December 24 at 3 :00 p.m. until December 31 at 3 :00 p.m. in odd numbered years; d. Each party shall enroll m and successfully complete a course in parenting, at his or her own expense, in the vicinity of his or her residence. e. The custodial parent shall allow liberal contact between the child and the no custodial parent, at the expense of the noncustodial parent. f. Each party shall keep the other party apprised of his or her residential address at all time. 3. Nothing herein is intended to preclude the parties from deviating from the custodial terms of this order by mutual agreement. BY THE COURT, ;' ..~ /f? //Ot{ , Jr., Jr. 1 . I ! , ,l;,' I I /1 ! /v J)Wesley Charles E. Petrie, Esq. 3528 Brisban Street Harrisburg, P A 17111 Attorney for Plaintiff -w'~~ 1~/~/CJt, Dennis E. Robinson, Jr. 1104 Route 47 South Rio Grande, NJ 08242 Defendant, pro Se -We~~ 1.)./<6~f., o ~.; ~ <'-' c:r- o r"'\'"1 ("J \ C$:) ,.-- :;;::: --I ...(. 5: ~ ~-n rn-- l~ -=gO (~:-3~?, ':~~ ~i 9 ""P" "'j:) :4 UJ - &'" DEANNA M. ROBINSON, (NOW Deanna Vasquez) Plaintiff : IN THE COURT OF COMMOM PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. NUMBER: 05-4484 CML ACTION LAW DENNIS E. ROBINSON, JR., Defendant IN CUSTODY PETITION FOR FINDING OF CONTEMPI' OF ORDER OF COURT AIm FOR MODIFICATION OF ORDER OF COURT CONTEMPT OF ORDER OF COURT TO THE HONORABLE J. WESLEY OLER, JUDGE NOW COMES Plaintiff, DEANNA M. ROBINSON, by and through her attorney, Charles E. Petrie, and respectfully represents as follows: 1. Plaintiff is DEANNA M. ROBINSON, who currently resides at 420 Green Springs Road, Newville, County of Cumberland, Pennsylvania. 2. Defendant is DENNIS E. ROBINSON, JR., who currently resides at 1104 Route 47, Rio Grande, New Jersey. 3. Plaintiff and Defendant are the natural parents of a minor child, EVONNA MARIE VAZQUES, born October 27,2003. 4. That on December 7,2006, following a custody hearing, the Honorable J. Wesley Oler dictated an Order from the bench directing that physical and legal custody of the minor child shall be shared by the parties. A copy of the Order will be provided. 5. Said Order directed that Plaintiff would have physical custody of the minor child from the date of said Order (December 7, 2006) at 4:00 p.m. until December 17, 2006. 6. That Defendant failed to turn over said minor child to Plaintiff as directed. 7. The Order requires that "The location for the exchange of custody shall take place at the inside entrance of the J.C. Penney establishment at the King of Prussia Mal1." Plaintiff drove to said location and contacted the Defendant to let him know she was there. Defendant sent Plaintiff to numerous other locations where he claimed to be waiting but Plaintiff was unable to locate Defendant and said minor child. A copy of Plaintiffs Turnpike receipt is attached hereto. WHEREFORE, Plaintiff respectfully requests that Your Honorable Court enter an Order finding Defendant to be in contempt of an Order of Court and providing such relief as Your Honorable Court may deem just and proper. MODIFICATION OF COURT ORDER 8. Plaintiff hereby incorporates paragraphs 1 through 7 above as if fully set forth herein. 9. That Plaintiff, DEANNA M. ROBINSON, (now Deanna Vasquez) shall have primary physical custody of the subject minor child. WHEREFORE, Plaintiff respectfully requests that Your Honorable Court amend the Order of December 8, 2006, to grant primary physical custody of the subject minor child to Plaintiff. Respectfully submitted, ~C~ CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I verify that the statements in the foregoing Petition 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. l-Z-5-0Co DATE v. IN'niE COURT OF COMM.ON PLEAS OF ~ 0 CUMBERLAND COUNTY. PENNSY~!~ ; . --t'[':,r' ~ .~~ \"(~: ~. ('"') ~'1"\ ~/> Jo ~~'!', "';". :i.~'l .--1 , ..,.~ \1-':: '. 1;i I.,~ \.~ ?-;~:: - 15' ':c-. I..) ..s:J ;::;.\ H'~~ ~.~ .- ~ ::2. -;. ~ CIVIL ACTION - LAW DEANNA M. ROBINSON, (NOW Deanna Vasquez) Plaintiff DENNIS E. ROBINSON, JR., Defendant NO, 05-4484 CIVIL TERM ORDER OF COURT AND NOW, this 8th day of December, 2006, upon consideration of Plaintiff's Petition for Finding of Contempt of Order of Court and for Modification of Order of Court, and of the general issue of custody with respect to the parties' child, V crona Marie Vasquez (i.e. October 27, 2003), and of the general issue of custody with respect to the parties' child, Verona Marie Vasquez (Le. October 27,2003), it is ordered and directed as follows: 1. Defendant is adjudicated in contempt and sanctioned with payment of the sum of$SOO.OO to the use of the county; 2. The custodial terms of the order of Court dated August 28, 2006, shall remain in full force and effect, except as modified as follows: a. The parties' weekly periods of physical custody shall commence on Sunday at 3 :00 p.m. and end on the following Sunday at 3:00 p.m.; Defendant's next period of weekly physical custody shall commence on Sunday, December J 7, at 3:00 p.m. b. Exchanges of custody shatl take place at the inside entrance of the J.e. Penny establishm.ent at the King of Prussia M.aIl; in the event that the party to receive custody is more than one-half hour late for the transfer, he or she sban be deemed to have forfeited that 2006-12-0810:20 Page 1 period of cu.~tody; Plaintiffs stepfather shall not be on the premises of the mall during the custody exchange; c. During the Christmas period, Plaintiff shalJ have custody of the child from December 24 at 3 :00 p.rn, until December 31 at 3:00 p.m. in even numbered years, and Defendant shalJ have custody of the child from December 24 at 3:00 p.m. until December 31 at 3 :00 p.m. in odd numbered years; d. Each party shall enroll in and successfully complete a course in paren.ting, at his or. her own expense; in the vicinity of his or her residence. e, The custodial parent shan allow liberal contact between the child and the no custodial parent, at the expense of the noncustodial parent. f. Each party shall keep the other party apprised of his or her residential address at all time. 3. Nothing herein is intended to preclude the parties from deviating from the custodial terms of this order by mutual agreement. BY TH_R COURT, .-. ,. ".; J;}J/ il , Jr., Jr. Charles E. Petrie~ Esq. 3528 Brisban Street Harrisburg, P A 17111 Attorney for Plaintiff Dennis E. Robinson, Jr. 1104 Route 47 South Rio Grande, NJ 08242 Defendant, pro Se 2006-12-0810:20 Page 2 PEN N A TURNP . KE COM M FARE RECE . to .i. ::lL..'~ZA 247/0 1 9 H ,d, R R . SBUR G E DATE TIME COlL TRAN ENTRY 12/07/06 19:56 3114 2150 326/24 LANE CLASS TP UO PAID 09 1 CA $4.50 For E-'ZPass, cal i 1-877-736-6727 ". ~ (1 r--' C.) 7:J ~ c? C..- c~) -0 ~ 0'" f t. ....::~ CJ -1 t-' " ~:n r't C) r.I,' -,1 \,1\ ~r)Q \) ..... ]._'~::~ f).. \ ...... - ;J ::..r~ t ~ 'D C> -"!,., ;~,-~ c-:~ :): " r'.,) (),'n -t.J :::::J, ~ (Y ~~-.. ~ p:: c> ~ .-<: $ DEANNA M. ROBINSON PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. ()5. il'+B"I 9S 4485 CIVIL ACTION LAW DENNIS E. ROBINSON, JR. DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, December 18, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, January 18,2007 , the conciliator, 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 hearine:. FOR THE COURT. By: Isl Hubert X Gilro Es 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 HA VE 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 'F~-#-~~~ ~~ ~~~u, > ~ f;?~ ~*.p; > (" 0 :8 ~,ld 61 330 900l 3H1 :\0 3~)1 :1:;()o{]31\:l ?(? ~ ,!II. e/ 'J(J ~ I? I- 'el ~'bl. el DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. DENNIS E. ROBINSON, JR., Defendant CIVIL ACTION - LAW 05-4484 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW, this 7th day of December, 2006, upon consideration of Plaintiff's Petition for Finding of Contempt of Order of Court and For Modification of Order of Court, and of the general issue of custody with respect to the parties' child, Evonna Marie Vazques (date of birth October 27, 2003), and following a hearing, the record is declared closed and the matter is taken under advisement. Pending further order of court, the terms of the order of court dated August 28, 2006, shall remain in full force and effect; provided, that exchanges of custody shall take place at the J.C. Penny establishment in the King of Prussia Mall in Pennsylvania; and provided, further, that the mother's next period of shared custody shall commence on today's date and shall run until Sunday, December 17, 2006. By the Court, ~nnis E. Robinson, Jr., Defendant pro Se V1104 Rt 47 South Rio Grande, New Jersey 08242 ~ pcb ~arles E. Petrie, Esquire 3528 Brisban Street Harrisburg, PA 17111 For the Plaintiff 02 : II 07 "nn QW1l v \,..;,...1"; ..vU~ .:Ie) r ___~u_. DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. DENNIS E. ROBINSON, JR., Defendant CIVIL ACTION - LAW 05-4484 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW, this 7th day of December, 2006, upon co~sideration of Plaintiff's Petition for Finding of Contempt of Order of Ccurt and For Modification of Order of Ccurt, and of the general issue of custody with respect to the parties' child, Evonna ~~?~i~ V~=a~es (date of bi~th Octobe~ 27, 200?) , and following a hearing, the record 1S declared closed and the matter is taken under advisement. Pending further order of court, t~e terms of the 0_~CL G~ rcurc aated hcgust ~8, LeDo, shail r2~al~ ~~ fuJl force and effect; provided, that exchanges of custody shall take place -'- CL ~ne J.C. Penny establishment in the King of Prussia Mall in ?en~sylvan~a; and provided, further, that the mother's next period of shared custody shall commence on today's date and shall run until Sunday, December 17, 2006. Rv thp rOllrt. 4 :<.,\>--<;€.S pos~ o ~. !2 /-,; Z ? J. WESLEY OLER. JR. JUDGE ONE COURTHOUSE SQUARE CARLISLE, PA 170 13 $() J:).3~ 'j:~~ ':)E~ MAILED FROfvl ZIP CO Mr. Dennis Robinson, Jr. 1104 Rt 47 South Rio Grande, New Jersey 08242 NIXIE ose :1 70 ,0:1./04 RETURN TO SENDER NOT DELIVERAeLE AS ADDRESSED UNABLE TO FORWARD ElC: 1"70;13:3:32399 ,i.'OS19-00340--21 . ? f" eo. - (", ~ l'" ~.1:l..i.- .. J J ~ 1'1'0;1:3\1;..,j;;;l;"':S 111111111 II1II J 11111I111I'lllIllllllllllllllIlllllIl ) Illl, III I FEB 0 5 2007'11( DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW '1fl/8~ NO. 05~ IN CUSTODY DENNIS E. ROBINSON, Defendant COURT ORDER y\ AND NOW, this S day of February, 2007, the Conciliator appearing for a Conciliation Conference on February 1 and none of the parties or their attorney's being in attendance, the Conciliator relinquishes jurisdiction. F:\FILES\DATAFILE\GeneraI\Current\1Z31l\Robinllon v Robinson Order ViNV/\ l;.sr\Jr\~.=.ld I rr-r"'-"'" "~f' I "" '''''''''''''('\1'"\ l\.J.J\i iLl, i ,:," "]i"'1I IV J I :B Hit 9- 83j LOOZ AtlVIONC)HLO:Jd 3Hl .:10 38!+D"'{]31H r DEANNA M. ROBINSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. DENNIS E. ROBINSON, JR~, Defendant CIVIL ACTION - LAW 05-4484 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW, this 7th day of December, 2006, upon consideration of Plaintiff's Petition for Finding of Contempt of Order of Court and For Modification of Order of Court, and of the general issue of custody with respect to the parties' child, Evonna Marie Vazques (date of birth October 27, 2003), and following a hearing, the record lS declared closed and the matter is taken, under advisement. Pending further order of court, the terms of the 0~Qer of rourc aated August 28, 2006, shall remain ~~ full force and effect; provided, that exchanges of custody shall take place at the J.C, Penny establishment in the King of Prussia Mall in Pennsylvania; and provided, further, that the mother's next period of shared custody shall commence on today's date and shall run until Sunday, December 17, 2006. Rv the Court. 4 -... ",,~,: .')21." ~ ,,~"'\ts POs~ 0, ,,(<' S~. ~c-~-'Udb ,,~ II t: . {' f~ ~:~~<;:~J ~~'~'~'.~:__:/~ Z .. ,fLu. _'" ,~.:'"..t...;._ ...2'.,~'?;;i. ~..;, :') t~. l;nN!~ $ O! J. WESLEY OLER. JR. JUDGE ONE COURTHOUSE SQUARE CARLISLE. PA 170 I 3 ,JCC453~ 593 DEe M.A!lED FROM ZIP CO[ ~0 t!JS- - (j'/Y"c.( Mr. Dennis Robinson, Jr. 1104 Rt 47 South Rio Grande, New Jersey 08242 '. , (//,.[: () c <'001 NJ:XJ:Eoao 1 70 -01.1-04) RETURN TO SENDER NOT DELJ:VERABLE AS ADDRESSED UNABLE TO FORWARD Be: 1'70:13332399 *OS;19-00340-;.a -- Q~2~2+\;O~i~&1&&~3 1111/1111 , 11111. , 11/111111 , ." 11111.. d 11,,/1111/,,1.1111 , I , , I