Loading...
HomeMy WebLinkAbout05-5066IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA THOMAS R. FORD, Plaintiff V. REBECCA DUNCAN, Defendant CIVIL ACTION F. R. CUSTODY COMPLAINT FOR CUSTODY 1. 2. 3. 4. 5. Plaintiff is Thomas Ford, who resides at Regency Woods North, Lot #5, Carlisle, PA 17013. Defendant is Rebecca Duncan, who resides at Regency 'Woods North, Lot #5, Carlisle, PA 17013. Plaintiff seeks custody of the following child: Name Present Residence DOB Trevor Andrew Ray Ford Regency Woods North, 3/26/04 Lot #5, Carlisle, PA 17013 The child was born out of wedlock. Age The child is presently in the custody of Plaintiff and Defendant , who both reside at Regency Woods North, Lot #5, Carlisle, PA 17013. Since birth, the child has resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Thomas Ford Rimer Highway birth-5/04 Rebecca Duncan Newville, PA 17241 Pamela Duncan Judy Smith Thomas Ford Regency Woods North, Lot #5, 5/04-present Rebecca Duncan Carlisle, PA 17013 6. 8. The mother of the child is Rebecca Duncan who resides at Regency Woods North, Lot #5, Carlisle, PA 17013. She is not married. The father of the child is Thomas Ford, who also resides at Regency Woods North, Lot #5, Carlisle, PA 17013. He is not married. The relationship of plaintiff to the child is that of father. The plaintiff currently resides with the following persons. Name Relationship Rebecca Duncan Child's mother Trevor Andrew Ray Ford Child 9. The relationship of defendant to the child is that of mother. The defendant currently resides with the following persons. Name Relationship Thomas Ford Child's father Trevor Andrew Ray Ford Child 10. 11. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. The best interest and permanent welfare of the child will be served by granting the relief request because: A Court Order of custody is desired so that the Plaintiff and the child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody can be avoided, and also so that the child is not used in a manipulative fashion. 12. 13. Child. Date: A Court ordered determination of custody is required to avoid continuing conflict between the parties regarding parental responsibilities for custody. Defendant's erratic behavior and use of alcohol and/or marijuana interferes with her ability of properly care for the child. Plaintiff is able to provide the care and nurture which the child needs for healthy development in a primary physical custody situation. Plaintiff's attorney is unaware of any opposing counsel and will serve the Complaint of Custody on the opposing party directly. The proposed temporary order states that the Plaintiff Thomas Ford shall have primary physical custody of the child Trevor Andrew Ray Ford. WHEREFORE, Plaintiff requests this Court grant Plaintiff primary physical custody of Respectfully ed, John ? Attorney//for ntiff Attorney I.D. #87000 35 East High Street Suite 204 Carlisle, PA,. 17013 717-241-2446 VERIFICATION I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unworn falsification to authorities. Date: yf ?o wjf a it C_. Thomas Ford, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA THOMAS R. FORD, Plaintiff CIVIL ACTION V. REBECCA DUNCAN, Defendant F. R. CUSTODY CERTIFICATE OF SERVICE I, John J. Mangan, Esquire, attorney for Plaintiff, do hereby certify that I this day served a copy of the Custody Complaint upon the following by depositing same in the United States Mail, Certified mail/Return Receipt Requested/Restricted Delivery at Carlisle, Pennsylvania, addressed as follows: Rebecca Duncan Regency Woods North, Lot #5, Carlisle, PA 17013 Date: ?? ?? fCo Respectfiilb spbmjUed, John J.Po,gan AttomL-y or Plaintiff Attorney I.D. #87000 35 East High Street Suite 204 Carlisle, PA. 17013 717-241-2446 r? ? T ? l ? _r ( t ? ?.Si ? O' W THOMAS R. FORD IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 05-5066 CIVIL ACTION LAW REBECCA DUNCAN DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, October 04, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, November 01, 2005 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 hearing. FOR THE COURT. By: /s/ Iac2a _e M_ Verney, Esq. r ln^J Custody Conciliator ?"? The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 I h T NA S- 130 SH Q THOMAS R. FORD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 05-5066 CIVIL TERM REBECCA DUNCAN, : IN CUSTODY Defendant PRAECIPE FOR ENTRY OF APPEARANCE To Curtis R. Long, Prothonotary: Please enter my appearance on behalf of the Defendant, Rebecca Duncan, in the above captioned case. Respectfully submitted, Je fca Holst, Esquire idPenn Legal Services 401 E. Louther Street Carlisle, PA 17013 (717) 243-9400 Date: 10' a'lD 0 THOMAS R. FORD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 05-5066 CIVIL TERM REBECCA DUNCAN, : IN CUSTODY Defendant CERTIFICATE OF SERVICE I, Jessica Holst, Esquire, of MidPenn Legal Services, attorney for the Defendant, Rebecca Duncan, hereby certify that I have served a copy of the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following date and in the manner indicated below: U.S. First Class Mail. Postage Pre-Paid John J. Mangan, Esquire 35 East High Street Suite 204 Carlisle, PA 17013 MidPenn Legal Services, Inc. Date: 13 a b e J sic olst, Esquire id Penn Legal Services 401 E. Louther Street Carlisle, PA 17013 ? ? , -t r (.=? ._ V THOMAS R. FORD, : IN THE COURT OF CO Plaintiff : CUMBERLAND COUNT V. : NO. 2005-5066 CIVIL TERM REBECCA DUNCAN, : CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this ?? day of NON, _, 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Thomas R. Ford and the Mother, Rebecca Duncan, shall have shared legal custody of Trevor Andrew Ray Ford, born March 26, 2004. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. The parties shall share physical custody on a 2/3/2 alternating day basis. Father shall begin his two day period on October 30, 2005. The exchange time shall 6:00 p.m. unless otherwise agreed. 3. In the event that the custodial party is in need of a babysitter for more than 2 hours, they shall contact the non-custodial parent and offer said babysitting opportunity to the non-custodial parent. 4. Thanksgiving shall be shared with Father having physical custody from 9:00 a.m. to 3:00 p.m. and Mother having physical custody from 3:00 p.m. to 9:00 p.m. 5. Christmas. The Christmas holiday shall be divided into two Blocks. Block A shall be from 12:00 noon on Christmas Eve to Christmas Day at 12:00 noon. Block B shall be from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Father shall have Block A in 2005 and Mother shall have Block B in 2005. 6. Mother's Day/Father's Day. Mother shall have physical custody of the child on Mother's Day and Father shall have physical custody of the child on Father's Day at times agreed to by the parties. ? NOV 0 1 2005 ON PLEAS OF (b -? i ?• VANIA 7. Easter, Memorial Day, July 4th and Labor Day shall be alternated by the parties such that Mother shall have physical custody of the child on Easter and July 4 `h in ` l ts?C - (fir-?,: CYx 1 ry 2006. Father shall have physical custody of the child on Memorial Day and Labor Day in 2006. 8. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference is scheduled for Monday, January 24, 2006 at 9:30 a.m. cc; X J. Mangan, Esquire, Counsel for Fath essica Holst, Esquire, Counsel for Mother J l G-(? Q V 'ruV rnT rn rr THOMAS R. FORD, Plaintiff V. REBECCA DUNCAN, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :2005-5066 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Trevor Andrew Ray Ford March 26, 2004 shared 2. A Conciliation Conference was held in this matter on November 1, 2005, with the following individuals in attendance: The Father, Thomas R. Ford, with his counsel, John J. Mangan, Esquire, and Mother, Rebecca Duncan, with her counsel, Jessica Holst, Esquire, Mid Penn Legal Services. 3. The parties agreed to an Order in the form as attached. li-, Date L I V \ U ???, cq ine M. Verney, Esquire Custody Conciliator AN M06 THOMAS R. FORD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-5066 CIVIL TERM REBECCA DUNCAN, : CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this A day of ? 2 V7 , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated November 4, 2005 shall remain in full force and effect with the following modifications. 2. The parties shall share and alternate the Thanksgiving holiday 9:00 a.m. to 3:00 p.m. and 3:00 p.m. to 9:00 p.m. Mother shall have the earlier time in even numbered years and the later time in odd numbered years. Father shall have the earlier time in odd numbered years and the later time in even numbered years. 3. The parties shall alternate the Christmas holiday as set forth in the prior Order. Mother shall have Block A in even numbered years and Block B in odd numbered years. Father shall have Block A in odd numbered years and Block B in even numbered years. 4. New Year's shall be divided into two Blocks. Block A shall be from 12:00 noon New Year's Eve to 12:00 noon New Year's Day and Block B shall be from 12:00 noon New Year's Day to 12:00 noon January 2. Father shall have Block A in even numbered years and Block B in odd numbered years. Mother shall have Block A in odd numbered years and Block B in even numbered years. 5. Each party shall be entitled to two non-consecutive, uninterrupted weeks in the summer provided they give the other party 30 days prior notice. 6. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. {_? ; - _.. cc: Jessica Hoist, Esquire, Counsel for Thomas R. Ford, pro se 167 Old Town Road Gardners, PA 17324 RV TuF CO TiRT_ ",I 9' C'UUG THOMAS R. FORD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :2005-5066 CIVIL TERM REBECCA DUNCAN, : CIVIL ACTION - LAW Defendant IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Trevor Andrew Ray Ford March 26, 2004 shared 2. A Conciliation Conference was held in this matter on January 24, 2006, with the following individuals in attendance: The Father, Thomas R. Ford, pro se, and Mother, Rebecca Duncan, with her counsel, Jessica Holst, Esquire, Mid Penn Legal Services. 3. The Honorable J. Wesley Oler, Jr. entered an Order of Court dated November 4, 2005 providing for shared legal and shared physical custody. 4. The parties agreed to an Order in the form as attached. b -off I 14 . Date 9acq&line M. Verney, Esquire Custody Conciliator THOMAS R. FORD, Plaintiff V. REBECCA DUNCAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2005-5066 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY AND NOW comes Petitioner, Thomas R. Ford, by and through his attorney, Mark F. Bayley, Esquire, and in support of the within petition avers as follows: 1. Thomas R. Ford, Petitioner, (hereinafter referred to as "Father"), is the Plaintiff in the above captioned-matter, and is an adult currently residing at 167 Old Town Road, Gardners, PA, 17324. 2. Rebecca Duncan, Respondent, (hereinafter referred to as "Mother"), is the Defendant in the above-captioned matter, and is an adult individual residing at Regency Woods North, Lot # 5, Carlisle, PA 17013. 3. The parties are the natural parents of. Trevor Andrew Ray Ford (born March 26, 2004) 4. A prior order was entered on November 4, 2005 by the Honorable J. Wesley Oler (copy is attached as Exhibit "A") and an addendum order was entered on January 25, 2006 (copy is attached as Exhibit "B"). 5. A change of circumstances has occurred in that Father now believes it is in the child's best interests to reside primarily with him due to the more stable and appropriate environment he can provide. WHEREFORE, Petitioner requests this Honorable Court to schedule a custody conciliation conference. Date: Respectfully submitted, BAYLEY & MANGAN Mark F. Bayley, Esquire 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court ID # 87663 Attorney for Plaintiff THOMAS R. FORD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-5066 CIVIL TERM REBECCA DUNCAN, : CIVIL ACTION - LAW Defendant IN CUSTODY ATTORNEY VERIFICATION Mark F. Bayley, Esquire, states that he is the attorney for Plaintiff in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: -- Z -7 -- C) Z5 Mark F. Bayley, Esquire Attorney for Plaintiff THOMAS R. FORD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-5066 CIVIL TERM REBECCA DUNCAN, : CIVIL ACTION - LAW Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Plaintiff do hereby certify that I this day served a copy of the foregoing document upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Jessica Holtz, Esquire MIDPENN LEGAL 401 East Louther Street, STE 103 Carlisle, PA 17013 ? 0? Dated. Z r Mark F. Bayley, Esquirdt? Attorney for Plaintiff THOMAS R. FORD, : IN THE COURT OF COMMON Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-5066 CIVIL TERM REBECCA DUNCAN, : CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of r)\/- , 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Thomas R. Ford and the Mother, Rebecca Duncan, shall have shared legal custody of Trevor Andrew Ray Ford, born March 26, 2004. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. The parties shall share physical custody on a 2/3/2 alternating day basis. Father shall begin his two day period on October 30, 2005. The exchange time shall 6:00 p.m. unless otherwise agreed. 3. In the event that the custodial party is in need of a babysitter for more than 2 hours, they shall contact the non-custodial parent and offer said babysitting opportunity to the non-custodial parent. 4. Thanksgiving shall be shared with Father having physical custody from 9:00 a.m. to 3:00 p.m. and Mother having physical custody from 3:00 P.M. to 9:00 P.M. 5. Christmas. The Christmas holiday shall be divided into two Blocks. Block A shall be from 12:00 noon on Christmas Eve to Christmas Day at 12:00 noon. Block B shall be from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Father shall have Block A in 2005 and Mother shall have Block B in 2005. 6. Mother's Day/Father's Day. Mother shall have physical custody of the child on Mother's Day and Father shall have physical custody of the child on Father's Day at times agreed to by the parties. NOV 0 ' 2005 BY: 7. Easter, Memorial Day, July 4th and Labor Day shall be alternated by the parties such that Mother shall have physical custody of the child on Easter and July 4th in 2006. Father shall have physical custody of the child on Memorial Day and Labor Day in 2006. 8. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference is scheduled for Monday, January 24, 2006 at 9:30 a.m. BY THE COURT, A J. cc: John J. Mangan, Esquire, Counsel for Father Jessica Holst, Esquire, Counsel for Mother TRUE Copy w., , eta s THOMAS R. FORD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-5066 CIVIL TERM REBECCA DUNCAN, : CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this .?5'-`' day of , 2006, upon consideration of the attached Custody Con iliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated November 4, 2005 shall remain in full force and effect with the following modifications. 2. The parties shall share and alternate the Thanksgiving holiday 9:00 a.m. to 3:00 p.m. and 3:00 p.m. to 9:00 p.m. Mother shall have the earlier time in even numbered years and the later time in odd numbered years. Father shall have the earlier time in odd numbered years and the later time in even numbered years. 3. The parties shall alternate the Christmas holiday as set forth in the prior Order. Mother shall have Block A in even numbered years and Block B in odd numbered years. Father shall have Block A in odd numbered years and Block B in even numbered years. 4. New Year's shall be divided into two Blocks. Block A shall be from 12:00 noon New Year's Eve to 12:00 noon New Year's Day and Block B shall be from 12:00 noon New Year's Day to 12:00 noon January 2. Father shall have Block A in even numbered years and Block B in odd numbered years. Mother shall have Block A in odd numbered years and Block B in even numbered years. 5. Each party shall be entitled to two non-consecutive, uninterrupted weeks in the summer provided they give the other party 30 days prior notice. 6. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, 1 1-51 g. I IF J. cc: Jessica Hoist, Esquire, Counsel for Mother Thomas R. Ford, pro se 167 Old Town Road Gardners, PA 17324 if, an-d' ?116 wai of ttit 4?@a ?'ri?i, t rh# a Sir- Prothanab?c ?, O c g o r? ? ?'? ?:? '? w rt .y ? r? ? ?, -;?, k ? ?? ? e 'mw?`_` THOMAS R. FORD IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2005-5066 CIVIL ACTION LAW REBECCA DUNCAN IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, April 04, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on _--Monday, May 05, 2008 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. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ jacgueline M. Verney, Esg. ?p Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 v--3;4 IAU? /%?p *?, ,? 4v )ONVAIASNN3d n ^T.. L h :? Wd ? - HdV 8001 AbiQ%N(>ilQI8d Ni dO 931 THOMAS R. FORD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 05-5066 CIVIL TERM REBECCA DUNCAN, : IN CUSTODY Defendant PRAECIPE FOR ENTRY OF APPEARANCE To Curtis R. Long, Prothonotary: Please enter my appearance on behalf of the Defendant, Rebecca Duncan, in the above captioned case. Respectfully submitted, Jes o t Esquire MidPenn Legal Services 401 E. Louther Street Carlisle, PA 17013 (717) 243-9400 Date: Z30' y THOMAS R. FORD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 05-5066 CIVIL TERM REBECCA DUNCAN, : IN CUSTODY Defendant CERTIFICATE OF SERVICE I, Jessica Hoist, Esquire, of MidPenn Legal Services, attorney for the Defendant, Rebecca Duncan, hereby certify that I have served a copy of the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following date and in the manner indicated below: U.S. First Class Mail, Postage Pre-Paid Mark F. Bayley, Esquire 17 West South Street Carlisle, PA 17013 MidPenn Legal Services, Inc. Date: q- 3o' oS Jes6a Holst,'Esquire Mi Penn Legal Services 401 E. Louther Street Carlisle, PA 17013 t"'a q..... v `'? <": mot,:'" ? -7 ? ..ws _. . ', '. ?"", -??; ?? THOMAS R. FORD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-5066 CIVIL TERM REBECCA DUNCAN, : CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT 7-6 a?' AND NOW, this L rA day of , 2866, upon consideration of the attached Custody Conciliation Rep , it is ordered and directed as follows: 1. The prior Orders of Court dated November 4, 2005 and January 25, 2006 shall remain in full force and effect with the following modifications. 2. Neither party may drink alcoholic beverages to the point of intoxication immediately before or during their period of physical custody with the child. 3. Neither party may leave Trevor alone, without adult supervision, at any time either at home or in a car. 4. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. cc */dark F. Bayley, Esquire, Counsel for Fathe 16sica Holst, Esquire, Counsel for Mother I BY THE COURT, THOMAS R. FORD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :2005-5066 CIVIL TERM REBECCA DUNCAN, : CIVIL ACTION - LAW Defendant : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Trevor Andrew Ray Ford March 26, 2004 shared 2. A Conciliation Conference was held in this matter on May 19, 2008, with the following individuals in attendance: The Father, Thomas R. Ford, with his counsel, Mark F. Bayley, Esquire and Mother, Rebecca Duncan, with her counsel, Jessica Holst, Esquire, Mid Penn Legal Services. 3. The Honorable J. Wesley Oler, Jr. entered Orders of Court dated November 4, 2005 and January 25, 2006 providing for shared legal and shared physical custody, along with a holiday schedule. 4. The parties agreed to an Order in the form as attached. Date acq me M. Verney, Esquire Custody Conciliator