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HomeMy WebLinkAbout05-5466 STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF ERIN F. MINNIER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. VINCENT G. SOUTH, Defendant : CIVIL ACTION - LAW : NO. 2005- CIVIL TERM : CUSTODY PETITION FOR SPECIAL RELIEF AND NOW comes the Petitioner, Erin F. Minnier, by her anomey, Stacy B. Wolf, Esquire, and files this petition for special relief respectfully representing as follows: 1. The plaintiff is Erin F. Minnier, an adult individual residing at 144 Springfield Road, Newville, Gunberland County, Pennsylvania 17241. 2. The defendant is Vincent G. South, an adult individual with a mailing address of P.O. Box 177, Bowmanstown, Cubon County, Pennsylvania 18030. 3. The plaintiff and defendant are the natural parents of two minor children, namely: Name Valarie D. South Present Residence 144 Springfield Road Newville, PA 17241 144 Springfield Road Newville, PA 17241 Age 3 years D.O.B.5/24/2002 Patrick J. South 1 year D.O.B. 10/22/2003 4. The children are presently in the custody of plaintiff but resided with both parents from the time of birth until on or about October 18, 2005 when Mother left the residence. Since that time, the children have been in the custody of the Mother. 5. Until October 18, 2005, Mother had been living with Father and Father's wife for approximately five years. Father and Father's wife convinced Mother to orally agree to be a surrogate motherto the oldest child, Valarie. After the oldest child's birth, Mother and Father continued to have intimate relations resulting in the birth of the youngest child, Patrick Mother, Father, and Father's wife orally agreed to all be responsible for raising both children. Father, born in 1957, took advantage of Mother, born in 1981, in convincing her to be a surrogate mother, to live with Father and Father's wife, and to continue intimate relations with her following the birth of the oldest child, Valarie. Father and Father's wife refused to let Mother leave the house alone except for the rare visit to one nearby friend's house for the five years she lived with them. Mother has realized that she was in a horrible, emotionally abusive situation and has removed herself and the children from such situation as of October 18, 2005. 6. Due to the nature of the relationship among Father, Father's wife, and Mother, and the control Father and Father's wife had over Mother, Mother believes that Father and Father's wife will come to her current residence, that they are aware of, and attempt to take the children back to Carbon County. 7. Prior to October 18, 2005, the children were living in Father's wife's sister's single-wide trailer with Father, Father's wife, Father's wife's sister, Mother, five cats, and 1 dog. The children were living in Father's wife's sister's trailer because Father and Father's wife had been evicted from their prior residence and had filed for bankruptcy. These substandard living conditions present a detriment to the children's physical and emotional well-being. 8. Mother believes and therefore avers that it would be in the best interests of the children for this Court to issue an Order for Special Relief, directing Father not to remove the children from the primal)' custody of Mother, to prevent the children from being removed from the jurisdiction before a conciliation conference can be held on this matter. 9. Mother has, this date, initiated an action in Custody by the filing of a complaint with the Court. WHEREFORE, Petitioner, Erin F. Minnier prays this Honorable Court enter a Temporary Custody Order directing Respondent, Vincent G. South, not to remove the children from the primal)' custody of Petitioner or from this jurisdiction, pending further Order of Court, and directing the Court Administrator's office to schedule an expedited custody conciliation conference to address the issues raised in this matter. Dated: October Ji, 2005 Respectfully submitted, s~-&~~ 37 South Hanover Street Suite 201 Carlisle, PA 17013 Supreme Court LD. No. 88732 (717) 241-4436 Attorney for Plaintiff VERIFICATION I, the undersigned, do hereby verify that the facts set forth in this petition are true and correct to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.CS. Section 4904, relating to unsworn falsification to authorities. October Ji, 2005 0e:-' t~-y, ~. Erin F. Minnier STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF ERIN F. MINNIER, Plaintiff v. VINCENT G. SOUTH, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2005- CIVIL TERM : CUSTODY CERTIFICATE OF SERVICE I, Stacy B. Wolf, Esquire, have selVed a true and correct copy of Petition for Special Relief upon the following person and in the matter indicated: SERVICE BY U.S. MAIL: Vincent G. South P.O. Box 177 Bowmanstown, P A 18030 October f f, 2005 By: WOLF & WOLF d!::.r!1:~ Attorney for Plaintiff 37 South Hanover Street, Suites 201-202 Carlisle, Pennsylvania 17013 (717) 241-4436 Supreme Court I.D. No. 88732 ~~~ '&clt <../) \ 0- 5J ~ --.. ~ ~ ~ ~ . ~, C',:) C) . ~'11 ~~.J , c~ :-;:1 CO' ri"l ....~J ~ .. C') . '-.!:J STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF ERIN F. MINNIER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. VINCENT G. SOUTH, Defendant : CIVIL ACTION - LAW : NO. 2005-5'Y?(. CIVIL TERM : CUSTODY COMPLAINT FOR CUSTODY NOW comes the plaintiff, Erin F. Minnier, by her attorney, Stacy B. Wolf, Esquire, and presents the following complaint for custody, representing as follows: 1. The plaintiff is Erin F. Minnier, an adult individual residing at 144 Springfield Road, Newville, Onnberland County, Pennsylvania 17241. 2. The defendant is Vincent G. South, an adult individual with a mailing address of P.O. Box 177, Bowmanstown, Carbon County, Pennsylvania 18030. 3. Plaintiff seeks custody of the following children: Name Present Residence Age Valarie D. South 144 Springfield Road Newville, PA 17241 144 Springfield Road Newville, PA 17241 3 years D.O.B.5/24/2002 1 year D.O.B. 10/22/2003 Patrick J. South 4. Plaintiff and defendant are the natural parents of the children. 5. The children were born out of wedlock 6. The children are presently in the custody of plaintiff but resided with both parents from the time of birth until on or about October 18, 2005 when Mother left the residence. Since that time, the children have been in the custody of the Mother. 7. The parties have never been married to one another. 8. The mother of the children is currently single. 9. The father of the children is currently mamed. 10. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 11. Plaintiff has no infonnation of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. 12. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 13. Until October 18, 2005, Mother had been living with Father and Father's wife for approximately five years. Father and Father's wife convinced Mother to orally agree to be a surrogate mother to the oldest child, Valarie. After the oldest child's birth, Mother and Father continued intimate relations resulting in the birth of the youngest child, Patrick Mother, Father, and Father's wife orally agreed to all be responsible for raising both children. Father, born in 1957, took advantage of Mother, born in 1981, in convincing heno be a surrogate mother, to live with Father and Father's wife, and to continue intimate relations with herfollowing the birth of the oldest child, Valarie. Father and Father's wife refused to let Mother leave the house alone except for the rare visit to one nearby friend's house for the five years she lived with them. Mother has realized that she was in a homble, emotionally abusive situation and has removed herself and the children from such situation as of October 18, 2005. 14. Despite the oral agreement of surrogacy, Mother was and stilI is the primary caretaker of the children and such role was never filled by Father's wife. 15. Due to the nature of the relationship among Father, Father's wife, and Mother, and the control Father and Father's wife had over Mother, MOther believes that Father and Father's wife will come to her current residence, that they are aware of, and attempt to take the children back to Carbon County. 16. Prior to October 18, 2005, the children were living in Father's wife's sister's single-wide trailer with Father, Father's wife, Father's wife's sister, Mother, five cats, and one dog. The children were living in Father's wife's sister's trailer because Father and Father's wife had been evicted from their prior residence and had filed for bankruptcy. These substandard living conditions present a detriment to the children's physical and emotional well-being. 17. The best interests and permanent welfare of the children will be seIVed by granting the relief requested herein. 18. Defendant has resided in Carbon County for approximately five years. 19. Plaintiff has always lived in the Newville area, and herfamily resides in the area, with the exception of the past five years she lived with Father and Father's wife in Carbon County. 20. Mother has friends and strong ties to the area. 21. Plaintiff fears that if Defendant is permitted to remove the children from the jurisdiction that she will be extremely limited in the opportunities she has to be with the children and will thus result in the children becoming alienated from plaintiff. Further, Plaintiff fears that if the children are taken out of her primatycustody, theywill be subject to the same emotional abuse and isolation that Mother was subject to when she lived with Defendant and Defendant's wife. 22. Plaintiff, a stay at home mother, has been the children's primary caregiver since birth. 23. Plaintiff is residing with her parents, who have sufficient means to care for the welfare of the children. Father and Father's wife are without sufficient means to provide for the children's support. 24. Plaintiff acknowledges the need for the children to have a relationship with defendant and will, if given the opportunity, work to reinforce that relationship provided protection is in place for the welfare of the children and Father agrees to anend parenting classes. 25. Bydefendant's own actions, he has demonstrated that he is not inclined, nor is he likely to take steps to support and nurture the relationship between the plaintiff and the children. Evidence of this is found in the fact that Mother's parents did not meet the children until two weeks prior to this filing. WHEREFORE, for the reasons set forth herein, plaintiff, Erin F. Minnier respectfully requests that the Court enter an order granting primary physical custody of the children to the plaintiff. Dated: October J!l, 2005 Respectfully submitted, !,:~~qiLM-fj - 37 South Hanover Street Suite 201 Carlisle, PA 17013 Supreme Court I.D. No. 88732 (717) 241-4436 Attorney for Plaintiff VERIFICATION I do hereby verify that the facts set forth in this complaint are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. October ~, 2005 c/ ~~ ' e~ I/~- Erin F. Minnier STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF ERIN F. MINNIER, Plaintiff v. VINCENT G. SOUTH, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2005- CIVIL TERM : CUSTODY CERTIFICATE OF SERVICE I, Stacy B. Wolf, Esquire, have served a true and correct copy of Complaint for G1stodyupon the following person and in the matter indicated: SERVICE BY U.S. MAIL: Vincent G. South P.O. Box 177 Bowmanstown, PA 18030 October 112005 By: WOLF & WOLF f) - ..~-1?J.~ STACY B. WOLF, ESQUIRE Attorney for Plaintiff 37 South Hanover Street, Suites 201-202 Carlisle, Pennsylvania 17013 (717) 241-4436 Supreme Court I.D. No. 88732 ~~~ "", . c{f' (}. -., c::,J -- -- ~, ~ o ~ ..-S........ ....j -S::\ c; ( ) C) -n ~ \:"1 'j) (;'? Ut o OC~005 STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2005-~'1.(.,CIVIL TERM : CUSTODY ERIN F. MINNIER, Plaintiff VINCENT G. SOUTH, Defendant ~RDER OF COURT NOW this ~ day of October, 2005 upon consideration of the Attached Petition for Special Relief, the following Order is hereby issued: 1. Pending a custody conciliation conference in this matter, primary physical custody shall be with Mother. 2. Pending further Order of GlUrt, Father is specifically directed not to remove the child from the primary custody of Mother or from this jurisdiction. ...:.:::r 3. The Court Administrator's office is directed to schedule - - , r l.l conciliation conference to fully address that presented in this matter. /' / .- By the, Q.oiirt, \. "-I / Ii f~ 5<.n;Lb-.1v ;Jc.LlUnLJ ~ ~ tu.+t. ~ ~ /trftj-6S (;&01 0:1 19 ~ov')" Prol~DlkOi1ot,,",rJ C"M~ Co- I</l'tH STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF ERIN F. MINNIER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. VINCENT G. SOUTH, Defendant : CIVIL ACTION - LAW : NO. 2005- CIVIL TERM : CUSTODY PETITION FOR SPECIAL RELIEF AND NOW comes the Petitioner, Erin F. Minnier, by her attorney, Stacy B. Wolf, Esquire, and files this petition for special relief respectfully representing as follows: 1. The plaintiff is Erin F. Minnier, an adult individual residing at 144 Springfield Road, Newville, Gunberland County, Pennsylvania 17241. 2. The defendant is Vincent G. South, an adult individual with a mailing address of P.O. Box 177, Bowmanstown, Carbon County, Pennsylvania 18030. 3. The plaintiff and defendant are the natural parents of two minor children, namely: ~ Valarie D. South Present Residence 144 Springfield Road Newville, PA 17241 Age 3 years D.O.B.5/24/2002 PatrickJ. South 144 Springfield Road Newville, PA 17241 1 year D.O.B. 10/22/2003 4. The children are presently in the custody of plaintiff but resided with both parents from the time of birth until on or about October 18, 2005 when Mother left the residence. Since that time, the children have been in the custody of the Mother. 5. Until October 18, 2005, Mother had been living with Father and Father's wife for approximately five years. Father and Father's wife convinced Mother to orally agree to be a surrogate mother to the oldest child, Valarie. After the oldest child's birth, Mother and Father continued to have intimate relations resulting in the birth of the youngest child, Patrick Mother, Father, and Father's wife orally agreed to all be responsible for raising both children. Father, born in 1957, took advantage of Mother, born in 1981, in convincing herto be a surrogate mother, to live with Father and Father's wife, and to continue intimate relations with her following the birth of the oldest child, Va1arie. Father and Father's wife refused to let Mother leave the house alone except for the rare visit to one nearby friend's house for the five years she lived with them. Mother has realized that she was in a horrible, emotionally abusive situation and has removed herself and the children from such situation as of October 18, 2005. 6. Due to the nature of the relationship among Father, Father's wife, and Mother, and the control Father and Father's wife had over Mother, Mother believes that Father and Father's wife will come to her current residence, that they are aware of, and attempt to take the children back to Carbon County. 7. Prior to October 18, 2005, the children were living in Father's wife's sister's single-wide trailer with Father, Father's wife, Father's wife's sister, Mother, five cats, and 1 dog. The children were living in Father's wife's sister's trailer because Father and Father's wife had been evicted from their prior residence and had filed for bankruptcy. These substandard living conditions present a detriment to the children's physical and emotional well-being. 8. Mother believes and therefore avers that it would be in the best interests of the children for this Coun to issue an Order for Special Relief, directing Father not to remove the children from the primary custody of Mother, to prevent the children from being removed from the jurisdiction before a conciliation conference can be held on this matter. 9. Mother has, this date, initiated an action in Custody by the filing of a complaint with the Coun. WHEREFORE, Petitioner, Erin F. Minnier prays this Honorable Coun enter a Temporary ClJstody Order directing Respondent, Vincent G. Somh, not to remove the children from the primary custody of Petitioner or from this jurisdiction, pending further Order of Court, and directing the CoUrt Administrator's office to schedule an expedited custody conciliation conference to address the issues raised in this matter. Dated: October fl, 2005 Respectfully submitted, s~1}~ 37 South Hanover Street Suite 201 Carlisle, P A 17013 Supreme Court I.D. No. 88732 (717) 241-4436 Attorney for Plaintiff VERIFICATION I, the undersigned, do hereby verify that the facts set fonh in this petition are true and correct to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.CS. Section 4904, relating to unsworn falsification to authorities. October ii, 2005 ~ 0e:-~ ~7 ~~ Erin F. Minnier ' STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF ERIN F. MINNIER, Plaintiff v. VINCENT G. SOUTH, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION . LAW : NO. 2005- CIVIL TERM : CUSTODY CERTIFICATE OF SERVICE I, Stacy B. Wolf, Esquire, have served a true and correct copy of Petition for Special Relief upon the following person and in the maner indicated: SERVICE BY U.S. MAIL: Vincent G. South P.O. Box 177 Bowmanstown, PA 18030 October f r, 2005 By: WOLF & WOLF ~~ 13, r- STACY B. OLF, ESQUI Attorney for Plaintiff 37 South Hanover Street, Suites 201-202 Carlisle, Pennsylvania 17013 (717) 241-4436 Supreme Court LD. No. 88732 ~~"P 'JcJ ~ Q-- 6J 22 --.,. ~ ..,.s:) ~ ~ !,,~.J .--~ \~-?\ ~ ri'i ~.. \.." \...:) c.) ERIN F. MINNIER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV ANIA v. 05-5466 CIVIL ACTION LAW VINCENT G. SOUTH DEFENDANT IN CUSTODY ORDER OF COllRT AND NOW.__ Wedn_esday, October 2~,}()05___ , upon consideralion of the attached Complaint. it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. . the conciliator, at 4tb_Floor,<=."mberland Co_u~ty-<=ourt"--o~se,_Carlisle _ on _ ____"I"lJu.r.~d_ay'--[)e,,~111ber 01_,2005 at 8:30 AM for a Pre-l'Iearing Custody Conference. At slIch conference, an effort v.'ill be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narro\v the issues to be heard by the COLlrt, 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 mav provide grounds for entry of a temporary or pennanent 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: /s/ lac;queline jjf. VerneXLEE,_ Custody Conciliator {V' .. fJf-- The Court of Common Pleas of Cumberland Coullty is required by law to comply with the Americans with Disahilites 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 mllst 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 :\01' HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEpHO:\E THE OFFICF SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 3" South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 . 7T~??11r ~~/4;; 50S('~' ,lIlr/ ~ /iY'#f/ .rJL, so. ,3e il/ #-('1 fr'.P ~ h&tll"'? 50 $(';/ ::: -'~: ::j " : ;, J '- ';' ,';1 -", ,-~ -, WOLF & WOLF PHONE 717-241-4436 ATTORNEYS AT LAw 37 Som HANOVER STREET SUITES 201-202 CARuSLE,PENNSYLVANIA 17013 STACY B. WOLF NATHAN C. WOLF FACSIMILE 717-241-4437 December 2, 2005 T aryn Dixon, Court Administrator Cumberland County Court of Common Pleas One Courthouse Square Carlisle, PA 17013 Re: Minnier v. South No. 2005-5466 Civil Term Dear Ms. Dixon: ':::..::..--=::~._- Plaintiff has filed a Praecipe to Reinstate Complaint, in the above-captioned case, with a proposed order directing the panies to appear for a conciliation conference. Please note that Plaintiff and Defendant appeared before Jacqueline Verney, Esquire for a conciliation conference on December 1, 2005 and at this conference, Plaintiff withdrew the complaint. Plaintiff, however, has since decided to pursue her action for custody and therefore, I am asking that the Complaint be reinstated. I also ask that the future conciliation be scheduled again with :Ms. Verney. Thank you for your assistance in this matter. Very troly yours, ,JJrtut12,Mf(- Stacy B. Wolf Enclosure cc: Vincent G. South Erin F. Minnier STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF ERIN F. MINNIER, Plaintiff v. VINCENT G. SOUTH, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2005-5466 CIVIL TERM : CUSTODY PRAECIPE TO REINSTATE CUSTODY COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the complaint in the above-referenced action on behalf of the plaintiff and transmit the same to the Court Administrator along with the attached proposed order to be relisted for a custody conciliation conference. Dated: December ~, 2005 Respectfully submitted, Stacy B. olf, Esquire 37 South Hanover Street Suite 201 Carlisle, PA 17013 Supreme Court I.D. No. 88732 (717) 241-4436 Attorney for Plaintiff STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF ERIN F. MINNIER, Plaintiff v. VINCENT G. SOUTH, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2005-5466 CIVIL TERM : CUSTODY CERTIFICATE OF SERVICE I, Stacy B. Wolf, Esquire, have selVed a true and correct copy of Praecipe to Reinstate Complaint for Custody upon the following person and in the matter indicated: SERVICE BY U.S. MAIL: Vincent G. South 187 Smith Lane Road Lehighton, PA 18235 December ~, 2005 WOLF & WOLF By: ~~e~?3.1!5- STACY B. OLF, ESQUlR .. Attorney for Plaintiff 37 South Hanover Street, Suites 201-202 Carlisle, Pennsylvania 17013 (717) 241-4436 Supreme Court I.D. No. 88732 .' , " ., -!'.. ':- } DEe 0 1 2005 "' f\ ERIN F. MINNIER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : NO. 2005-5466 CIVIL ACTION - LAW VINCENT G. SOUTH, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this :191- day of ~----..2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I. Mother's custody complaint is hereby withdrawn and the prior Order of Court dated October 19, 2005 is hereby vacated. 2. This Order is entered pursuant to an agreement of the parties at 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 COuR?,/~~/ (' J. cc: Stacy B. Wolf, Esquire, Counsel for Mother Vincent G. South, pro se 187 Smith Lane Road Leighton, P A 18925 ;;;.\ /, ~ r -' ./ ------- - . . ERIN F. MINNIER, Plaintiff DEe 0 1 200~ , '.r : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2005-5466 CIVIL ACTION - LAW VINCENT G. SOUTH, Defendant : IN CUSTODY PRIOR JUDGE: Edgar B. Bayley, 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 Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Valerie D. South Patrick J. South May 24, 2002 October 22, 2003 Mother Mother 2. A Conciliation Conference was held in this matter on December 1,2005, with the following individuals in attendance: Mother, Erin F. Minnier, with her counsel, Stacy B. Wolf, Esquire and Father, Vincent G. South, pro se. 3. The Honorable Edgar B. Bayley entered a Temporary Order of Court dated October 19,2005 providing for Mother to have primary physical custody of the children and Father not to remove the children from the jurisdiction. At the Conciliation Conference the parties advised the Conciliator that they had reconciled and requested a vacation of the prior Order of Court and Mother withdrew her custody complaint. 4. The parties agreed to the entry of an Order in the form as attached. 1)..-1-05' Date ~. , . I PLA INTI FF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA ERIN F. MINNIER V. 05-5466 CIVIL ACTION LAW VINCENT G. SOUTH IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesdax, Deeembe! 06, 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 _~!h}'I~or, Cumberland County Courthouse, Carlisl~.... on Thur~lI'%~al1uary I2,_20_0~_.._..............._...._.._ 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 dctine 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 Tacqueline_M. Verney, ~ Custody Conciliator P' 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 . ~ A'~ ~l~~ ~J G7, '1 [ , '1/ /f.-/ > t/ ...A/ C e/ . h:? ~m-/ ~!L. 5c?'{,,' ('/ j<(ll P? 7 /fT~ ~.~ ,5Cl .~. -C'! "',c-' , (,.1 ;<'1 ~..l J! .... .-,- . \'0""\ ;.., ' LL ! ERIN F. MINNIER, Plaintiff IAN I :{ LOUb :/I~ : IN THE COURT OF COMMON PLEAS OF ' : CUMBERLAND COUNTY, PENNSYL VANIA V. : NO. 2005-5466 CIVIL TERM VINCENT G. SOUTH, Defendant : CIVIL ACTION . LAW : IN CUSTODY ORDER OF COURT AND NOW, this 12h day of January, 2006, the Conciliator being advised that the plaintiff wishes to withdraw the complaint, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, d.J:.~ 1 (/CLVKZ line M. Verney, Esquire, Cus dy Conciliator }.,tJ'/.v,. E. i JI