HomeMy WebLinkAbout05-6298YORK COUNTY
12j02/05
SEACHRIST, JENELLE R
VS.
SEACHRIST, RICKY F
PARTY TYPE
COURTHOUSE
CIVIL ACTION DOCKET
PAGE:
CASE NO: 2000-SU-003084-Y31 YK Y03
FILING DATE: 06/26/00
JUDGE:
LITIGANT PARTY NAME
-------------------- -------- ----------------------------------------
ATTORNEY P001 MILLER, MARTIN
PLAINTIFF FOR CIVI P001 SEACHRIST, JENELLE R
DEFENDANT FOR CIVI D001 SEACHRIST, RICKY F
1
DATE FEE/AMOUNT
11j17/O5 00161 00212
NOTICE GIVEN RE: PA R. C. P. 236 MAILED TO JENELLE SEACHRIST &
CUMBERLAND CO PROTHY ON 11-17-OS C~ 3
FAXED TO GEORGE STUDZINSKI ON 11-17-OS @ 2:37
11/17/05 00161 00212
*ORDER DIRECTING CASE TO BE TRANSFERED TO CUMBERLAND CO BY CT
RICHARD K RENN JUDGE
11j10/OS 00157 00042
*CASE REACTIVATED
11/02/05 00154 00217
*PETITION TO TRANSFER VENUE TO CUMBERLAND COUNTY PA PURSUANT TO RULE
OF CIVIL PROCEDURE 1915.2 (D) W/CERT OF SVC
11J02J05 00154 00216 AS TO SEACHRIST, RICKY F
*PRAECIPE TO PROCEED IN FORMA PAUPERIS
O5j19/04 00072 00058
*CASE INACTIVE PER LOCAL RULE 6036
06/26/00 00080 0037 5.00
CUSTODY FEE RE: ACT 119-96
06/26/00 00080 0037
ORDER APPROVING STIPULATION
BY THE CT:RICHARD K RENN JUDGE
06j26/00 00080 0037 82.00
STIPULATION FOR CUSTODY
TOTAL NUMBER OF ENTRIES: 9
REQUESTED BY: VLG
******* END OF REPORT *******
CERTIFIED &orp the recm• the Court of Common Pleas of o Cou~ty~en v. a
t}tds ~?~ ~ day of e. A.ll. 'LO ~S ~~~~Q'~
Pamela S. Lee, Prothonotary
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IN THE COURT OF COMMON PLEAS OF YORK COUNTY,
PENNSYLVANIA
JENELLE R. SEACHRIST
VS
RICKY SEACHRIST
No. 2000-SU-03084-Y03
York, Pa., Thursday, November 10, 2005
Before Honorable Richard K. Renn, Judge
APPEARANCES:
GEORGE R. STUDZINSKI, Esqu;re
For the Defendant
* + +
AND, NOW, this tenth day of November,
2005, the Court has this matter before it on a petition
to transfer venue to Cumberland County.
Based on the ~~~~~w-~~~~ in the petition
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and argument of counsel, we believe that it is more
appropriate for Cumberland County to hear this matter
than York County, given the location of the parties and
the residence of the child.
Accordingly, we will stay any further
proceedings in this matter upon request. We will direct
the Prothonotary's Office to transfer any files or
proceedings to Cumberland County so that the matter can
proceed pursuant to their procedure.
We direct a copy of this Order shall be
sent to Jenelle Seachrist, the Plaintiff, at her last
known address of 388 Pin Oak Road, Carlisle, PA 17013,
and to counsel for Petitioner. We would also direct a
copy of this Order to the Prothonotary of Cumberland
County.
BY THE COORT:
~d K. Renn
~Y~~~161Q212
ank
11/14/05
No. 2000-SU-03084-Y03
CERTIFIED fr m the recd the Court of Common Pleas oC~o~unt~e y
this ~~ day of A.D. 20 ~~ G~=ii=L%'=- _
/ Pamela Saotery
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IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA
JENELLE R. SEACHRIST
Plaintiff
v.
RICKY F. SEACHRIST
Defendant
NO.
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CIVIL ACTION -LAW
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CUSTODY -~- -
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PETITION TO TRANSFER VENUE TO CUMBERLAND COUNTY PENNSYLV~IIA
PURSUANT TO RULE OF CIVIL PROCEDURE 1915.2(d)
AND NOW, comes your petitioner, Ricky F. Seachrist, through his attorneys,
George R. Studzinski, Esquire and MidPenn Legal Services, and petitions this
Honorable Court to transfer this action to the Court of Common Pleas of Cumberland
County, Pennsylvania, and support thereof avers as follows:
1. Petitioner (Father) is Ricky F. Seachrist, an adult individual residing at 6945 F,
New Oxford Road, Harrisburg, Pennsylvania 17112.
2. Respondent (Mother) is Jenelle R. Seachrist, an adult individual residing at
388 Pin Oak Lane, Carlisle, Pennsylvania 17013.
3. The parties are the natural parents of Courtney M. Seachrist, born April 29,
1996.
4. On June 22, 2000 an Order of Court regarding the minor child was entered in
the Court of Common Pleas of York County, Pennsylvania pursuant to a Stipulation for
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Custody dated June 15, 2000. 3~6~'~~ 5~~21~
5. Since June 2002, the Mother and minor child have resided continuously in
Cumberland County, Pennsylvania.
6. Since April 29, 2004, the Father has resided continuously in Dauphin County,
Pennsylvania.
7. Since the beginning of the 2002-2003 school year, the child has attended
school in Cumberland County, Pennsylvania.
8. Neither party nor the child presently have any significant connection to York
County, Pennsylvania.
9. Based on the above, this action, if filed as an original matter, could presently
be brought in the Court of Common Pleas of Cumberland County.
10. Petitioner desires to pursue litigation concerning the minor child, but
believes the convenience of the parties and witnesses would be best served if this
action were heard in Court of Common Pleas of Cumberland County, Pennsylvania.
WHEREFORE, Petitioner, Ricky F. Seachrist, requests this Honorable Court to
issue an Order transferring this action to the Court of Common Pleas of Cumberland
County, Pennsylvania.
Respectfully submitted:
MIDPENN PENNSYLVANIA LEGAL SERVICES
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George R. Studzins ~, E uire
Attorney for Plaintiff
Supreme Couaarnnt~gNr~oqq. ~5~4501
MIDPENN LEt3Y~FL~ 0~~ ES
256 East Market Street
York, Pennsylvania 17403-2058
(717) 848-3605
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VERIFICATION STATEMENT
I verify that the statements made in this Petition to Transfer Venue are true and
correct. I understand that false statements herein are made subject to the penalties of
18 Pa. C.S. §4904 relating to unsworn falsification to authorities.
Date Ricky F. eachrist
IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA
JENELLE R. SEACHRIST NO. 2000-SU-03084-03
Plaintiff
v. CIVIL ACTION -LAW
RICKY F. SEACHRIST
Defendant CUSTODY
CERTIFICATE OF SERVICE
I, George R. Studzinski, do hereby certify that on November 2, 2005, I served a
true and correct copy of the foregoing Petition to Transfer Venue upon the persons
indicated below by depositing a copy of same in the United States Mail, postage pre-
paid, at York, Pennsylvania, addressed as follows:
Jenelle R. Seachrist
388 Pin Oak Lane
Carlisle, PA 17112
Martin Miller, Esq.
204 N. George St.
Suite 200
York, PA 17401
George R. Studzinslcwl
Attorney for Defendant
Supreme Court I.D. No
54501
MidPenn Legal Services
256 East Market Street
York, PA 17400 A"' ~ ~
Telephone: (71 ext. 201
IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PA
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To the Prothonotary:
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Date: f / 0 O
A torney for 2
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IN THE COURT OF COMMON PLEAS OF YORK COUNTY. PENNSYLVANIA
JENELLE R. SEACHRIST
Plaintiff
v.
RICKY F. SEACHRIST
NO. 2000-SU-03084-03
CIVIL ACTION -LAW
Defendant CUSTODY `~
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PRAECIPE TO PROCEED IN FORMA PAUPERIS T,
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To the Prothonotary: iv
Kindly allow Ricky F. Seachrist, Defendant, to proceed In Forma Pauperis.
I, George R. Studzinski, attorney for the party proceeding In Forma Pauperis,
certify that I believe that the party is unable to pay the costs and that I am providing free
legal service to the party.
George R. Studzinskf„~sq
Attorney for Defendant
Supreme Court No. 54501
Mid Penn Legal Services
256 East Market Street
York, PA 17403-2058
Telephone: (,7.].Z.)„$605
30601540216
IN THE COURT OF COMMON PLEAS
OF YORK COUNTY, PENNSYLVANIA
JENELLE R. SEACHRIST N0. 2000-SU- O3OH4
vs.
RICKY F. SEACHRIST CIVIL ACTION -LAW
--D3
ORDER OF COURT
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AND NOW, TO WIT, this ~ day of ,
2000, pursuant to the attached Agreement and Stipulation of the Parties, it
is hereby ORDERED that Ricky F. Seachrist and Jenelle R. Seachrist,
Father and Mother respectively of Courtney M. Seachrist, born April 29,
1996, the subject of the above referenced custody proceeding, hereby
agree that the best interests and welfare of Courtney M. Seachrist would
be served by their sharing custody of the children as hereinafter outlined.
Father and Mother shall exercise joint legal custody of the child.
Law Offices of
Martin Miller, Enquire
96 South George Street
Suite 300
York, PA 17401
Mother and Father shall has exercise physical custody of the
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child alternating weeks commencing on Saturday at noon. ~'= ~- r,
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Mother and Father shall alternate physical custody during the
following alternating holidays from 9:00 a.m. until 7:00 p.m.: New Years
Day, Memorial Day, Fourth of July, Labor Day, and Thanksgiving Day.
Father's first holiday shall be Fourth of July and Mother's first holiday shall
be Labor Day
Father shall exercise physical custody every Father's Day from
9:00 a.m. until 7:00 p.m. and Mother shall exercise physical custody every
Mother's Day from 9:00 a.m. until 7:00 p.m.
In even numbered years, Father shall exercise physical custody
from noon on Christmas Eve until noon on Christmas Day and Mother
shall exercise custody from noon on Christmas Day until noon on
December 26. In all odd numbered years, Mother shall exercise custody
from noon on Christmas Eve until noon on Christmas Day and Father shall
exercise custody from noon on Christmas Day until noon on December
26.
All holiday schedules shall take precedence over any regularly
scheduled times.
Custody may also be exercised as the parties may otherwise
mutually agree.
All transportation involving the children shall be divided equally
between Father and Mother.
The parties agree that they shall refrain from making disparaging
Law Offices of
Martin Miller, Esquire remarks or comments regarding the front of the child and
96 South George Street
Suite 300
York, PA 17401
shall take all measures deemed advisable to foster a feeling of affection
between the child and the other parent.
BY T
~~ ~~ _
Richard K. Renn, Judge ~ ---~.
Law Off ices of ~ ~ ~ ~ (1 ~ ~ R ~,~1 v t
Martin Miller, Esquire ~7 V V ~
96 South George Street
Suite 300
York, PA 17401
IN THE COURT OF COMMON PLEAS
OF YORK COUNTY, PENNSYLVANIA
JENELLE R. SEACHRIST
NO: 2000-SU
vs.
RICKY F. SEACHRIST
CIVIL ACTION -LAW
AGREEMENT AND STIPULATION FOR ORDER OF COURT
To the Honorable Richard K. Renn, Judge, Court of Common Pleas:
Jenelle R. Seachrist, and her counsel, Law Offices of Martin Miller,
Esquire, by Martin Miller, Esquire, and Ricky Searchrist, unrepresented,
do hereby Stipulate and Agree that this Honorable Court, before whom
this matter has been assigned, may enter the Order of Court hereto
attached.
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I~R'cky R. Seachrist 2'n„c
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Law Oftices of ~' ~
Martin Miller, Esquire L~ I
96 South George Street Date a e
site aoo
Vork, PA 17401
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Martin Miller, Esquire
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RICKY F. SEACHRIST, : IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner :CUMBERLAND COUNTY, PENNSYLVANIA
v. : NO. OS- ~' zCNIL ACTION
JENELLE R. SEACHRIST,
DefendanURespondent :CUSTODY
PETITION TO MODIFY CUSTODY
The Petitioner, Plaintiff, Ricky Seachrist, by and through his counsel, MidPenn Legal
Services, respectfully represents the following in support of his Petition for Modification:
1. Petitioner is Ricky Seachrist, hereinafter referred to as Father, who resides at 6945 F
New Oxford Road, Harrisburg, Dauphin County, Pennsylvania 17112.
2. Respondent is Jenelle Seachrist, hereinafter referred to as Mother, who resides at 388
Pin Oak Lane, Carlisle, Cumberland County, Pennsylvania, 17013.
3. On June 22, 2000, an Order of Court was entered in York County for custody of the
parties' minor child, Courtney M. Seachrist, born Apri129, 1996. A true and correct copy of that
Order is attached as "Exhibit A". The Order in pertinent part granted the parties shared legal
custody of Courtney Skyler and shared physical custody on a week on/week off schedule. The
Order also set forth the schedule for custody during holidays and ordered that transportation
during custody exchanges be shared by the parties.
4. By Order dated November 1Q 2005, York County transferred venue of this matter to
Cumberland County. A true and correct copy of that Order is attached as "Exhibit B".
5. Father seeks a modification of the current Order to better serve Courtney's best
interests and to establish a custody schedule that accommodates the distance between the two
parties while not interfering with Courtney's schooling.
6. Courtney's best interests will be served by granting Father's request for a
modification because:
a. Since the entry of the June 2000 Order, Father has tried to regularly exercise
his periods of custody on a weekly basis. Mother's failure to comply with the
Order severely limited and interfered with Father's ability to see Courtney on
a regular basis from 2001 through 2004.
b. Mother's decision to move to Cumberland County in 2002 further interfered
with Father's ability to have weekly periods of custody with Courtney because
of the difficulty getting her to school in Cumberland County from York
County.
c. In 2004, Father moved to Dauphin County, making it easier to see Courtney
on a more frequent schedule, but Mother still failed to follow any consistency
in allowing Father to exercise custodial time periods with Courtney.
Moreover, the distance between Dauphin County and Cumberland County
precluded the week on/week off schedule because of the difficulty in getting
Courtney to school on time.
d. Father has had more custodial time with Courtney during 2005, but still has
problems with Mother sharing transportation responsibilities.
e. Father is fully capable of caring for Courtney during periods of partial physical
custody and Courtney regulazly expresses her enjoyment when she is with
Father. Moreover, while with Father, Courtney spends time with Father's
extended family and it is important for her to maintain those relationships.
f. Father recognizes that the current Order granting the parties weekly periods of
custody with Courtney is ineffective in light of current living situations but is
concerned that without an Order specifying a new custody schedule, his visits
will be based on Mother's arbitrary decisions regarding when Father can have
periods ofpartial custody.
6. It is unknown whether Mother has legal representation in this matter and Father's
attorney is unable to seek concurrence for the relief requested.
WHEREFORE, Father respectfully requests this Court to modify the existing Order for
Custody and grant Father the following relief:
a. Grant the parties shared legal custody.
b. Grant Father periods of physical custody on weekends from 4:00 p.m.
on Fridays unti15:00 p.m. on Sundays.
c. Extend Father's weekends to incorporate days when Courtney is off of
school on Monday or Friday.
d. Establish a holiday schedule agreeable to both parties.
e. Establish a summer schedule with week on/week off custody
exchanges.
f. Order the parties to share transportation with the receiving party
providing transportation.
g. Any other relief this Court deems just and equitable.
Jessica I+Iols~t, Esquire
Mid enn Legal Services
401 E. Louther Street -Suite 103
Carlisle, PA ].7013
(717) 243-9400
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IN THE COURT OF COMi.?ON PLEAS
OF YORK COUtJTY, PENNSYLVANIA
vs
AGREEMENT AND ~T1P~ULATION FO~_r<~ER OF GQ~RT
i
JENELLE R SEACHRIST
RICKY F. SEACHRIST
To use Nrr~~•'e Pt%•2~CK P,Ern, J;.~1q~, Gouri of Common Pleas.
NO, 1000-5U
CIVIL ACT10N - LAV/
Jenelle R Seachrist, and her counsel, Law Offices of Martin Miller,
Lrw Ottrna nt
Martin Miflet, EMuiro
96 South Geor9x Svset
Suite 300
York PA 17401
Esquire, by tvtarin Mrller. Esquire. and Ricky Searchrist. unrepresented.
do hereby Stipulate and Acree that this Honorable Ccuri, tx:fcre whom
this matter has been assioned, may enter the prder of Court hereto
attache
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Jenelle R Seachnst
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Merlin Miller, Esavire
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IN THE COURT 0= GOMhtON PLEAS
OF YORK COU*iTY, Pi~i+NSYLYANIA ,
JENEtLE R. SCACHRlST r~O 2C0-SU- CJ~84 -(;
VS
RICY.Y F SEACHRIST CIVIL ACTION - LAV~:
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ORDER OF COURT
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ANQ NO`N, TG INi7", bhrs ~ 2' day c. ~_;~ ~-.-"-~.
2000, Pursuant to the attached !,greeme,~t arn] SFpulaticn a£ fhe Pari;es. R
is hereby ORDEP.ED that Ricky F. Seachrist a...d Jenelle R. Seachrist, i
Father and Mother respectively of Courtney M. Seachrist, born April 29. ~~,
1996, the subject of the above referenced custody proceeding, hereby
agree that the best interests and ~~+~!(are of Courtney 1~1. Seachrist wruld
be served by their sharing custixly of i~ re children as hereinafter outlined.
Father and Mother shall exercise jeirl'egal custody of the child. 1
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Mother and Father shall ha-exercise physical a.~stody of the i
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child alternating weeks commenclnp on Sat~~rday at noon; ~ ~ 1
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Mother 2nd Father sh311 alternate physical custody d~,:rnq the
fol!o'Ning alternating holidays from 9.00 a m unlal 7.00 p m New Years
Day. Memonal Day, FouRh of July, Labor Uay. and Thanksyr,~ing Day
Father's first holiday shad lie Fourth of Jufy and Mother s fin>t ho4day shall
be Labor Day
Father shall exerase physical custody every Father's Uay from
9'.00 a m until ' !10 ~ m ~.?d `.1oth:: „~aii~ ex',rCU~ physical custod}' every
Mother's Day from 9.4G a m until 7 G0 p m
In even numbered }'° Ifs. Father s~~~t PXCrCtSC ptlySGc~ CJStvdy
from noon on Chns+.mas Eve until neon on Christmas Day an j f~,M1c'her
shall exercise custody from. noon on Christmas Day until nc.;n on
December L5 In all odd cumbered years. ?~4athes shah exer.isr custody
from nocn on Christmas Eve until :,acn nn Ltris,mas Day and Father sha;f
exerase custody from noon on Christmas Day until noon on December
25
All holiday schedules shad ta!,e precedence over any regularly
Scheduled tirr:es
Custody may also be exercised as the parties may ocherw~se
mutually agree.
All transportation involving the ctuldren shall be divided equally
between Father and Mother
The par!ies agree that they shall refrain from making disparaging
Offices et
/ilfsr. Fegava
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PA 17d0r
remarks or comments regarding the vtljer P'~'~y to front of the child and
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Shalt i2}~B ait Rl9a5UfH5 de9med ad'/153h1c^. l0 ~GStAr el (C~llfl(i O~ ZVCClIp(1
beh•/een the child and the other parent
QY T~ ~
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Richard K_ Renn, Judge
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IN THE COURT OF CON:MON PEAS OF YORK COUNTY,
PENNSYLVANIA
JENELLE R. SEACHRIST
VS
RICKY SEACHRIST
No. 2000-SU--0308-Y03
York, 2a., Thursday, November 10, 2005
Before Honorable Richard K. Renn, Judge
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APPEARANCES: -~~
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GEORGE R. STUDZINSKI, Esquire ''~_"-
For the Defendant `"^
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O R D E R
AND, NOW, this tenth day of November,
2005, the Court has this batter before it on a petition
tc transfer venue ~o Cumberland County.
Based on the recitation in Y.he petition
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N0U-17-2005 THU 15:13 TEL: 17178545431 NFlME:MTDPENN LEGHL SERVICES P. 8
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and argument of counsel, :ae believe that i.t is more
appropriate for Cumberland County to hear this matter
than York County, given the location of tY;e par~ias and
the residence of the child.
Accordingly, we will stay ar.y further
proceedings in this matter upon request. We will direct
the Prothonotary's Office to transfer any files or
proceedings to Cumberland County so that the matte- can
proceed pursuant to their procedure,
We direct a copy of this Order shall be
sent to Jenelle Seachrist, the Plaintiff, at her last
known address of 388 Pin Oak Road, Carlisle, PA 17013,
and to counsel for Petitioner. Ode would also direct a
copy of this order to the Prothonotary of Cumberland
County.
ank
11/1/05
No. 2000-SU-03084-Y03
NOV-17-2005 THU 15:13 TEL:17178545431
BY THE COURT:
Judge
2
NRME:MIDPENN LEGRL SERVICES P. 3
VERIFICATION
I verify that I am the Petitioner as designated in the present action and that the facts and
statements contained in the attached Petition are true and correct to the best of my knowledge. I
understand that any false statements are made subject to the penalties of 18 Pa.C.S. §4904,
relating to unsworn falsification to authorities.
~ ~ ~ - D.~
Date Ricky . Seachrist
RICKY F. SEACHRIST, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. : NO. OS- CIVIL ACTION
JENELLE R. SEACHRIST,
Defendant :CUSTODY
CERTIFICATE OF SERVICE
I, Jessica Holst, Esquire, of MidPenn Legal Services, attorney for the Petitioner, Ricky
Seachrist, hereby certify that I have served a copy of the foregoing Petition for Modification on
the following date and in the manner indicated below:
U.S. Certified Mail, Return Receipt, Restricted Delivery
Jenelle R. Seachrist
388 Pin Oak Lane
Cazlisle, PA 17013
MidPenn
Date: ~ ~ ~ ~ J ~ l~~)
Inc.
Jess a Ylolst, Esquire
Mi enn Legal Services
401 E. Louther Street -Suite 103
Carlisle, PA 17013
_ . ~ . "_
RICKY F. SEACHRIST IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V' OS-6298 CIVIL ACTION LAW
JENELLE R. SEACHRIST
IN CUSTODY
DF,FFNDANT
ORDER OF COURT
AND NOW, _ Monday, December 19, 2005 ___, upon consideration of the attached Complaint,
is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. ,the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle ai Friday, January. 20, 2006 at 8:30 AM
for aPre-Heap m~ 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 aQe 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 ito scheduled hearing.
FOR THE COURT.
By: /s/ _ Hubert X. Gilroy, I^,~.__ y y(~
Custody Conciliator ~t~~
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 covert, 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'i'O YOUK 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
33 South Bedford Street
Carlisle, Pennsylvania 0013
Telephone (717)249-3166
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DEC }. 4 2005
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RICKY F. SEACARIST,
Plaintiff
v.
JENELLE R. SEACHRIST,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
(eoZG~
NO. OS- CNIL ACTION
CUSTODY
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Ricky Seachrist, Petitioner, to proceed in forma aE uueris.
I, Jessica Holst, attorney for the party proceeding in forma p~~uperis,certify that I believe the
party is unable to pay the costs and that I am providing free legal services to the party.
? .~
Jessica Holst, Esquire
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717)243-9400
_ 5
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RICKY F. SEACHRIST, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v CIVIL ACTION -LAW
JENELLE R. SEACHRIST, NO. OS-6298
Defendant IN CUSTODY
COURT ORDER
AND NOW, this ?. h d day of rt r ar 2006, upon consideration of the
attached Custody Conciliation report, it is ordered that the York County Order of June 22,
2000 at Docket No. 2000-03084 is vacated and replaced with the following Order of Custody
in this case:
1. The father, Ricky F. Seachrist, and the mother, Jenelle R. Seachrist, shall
enjoy shared legal custody of the minor child, Courtney M. Seachrist,
born Apri129, 1996.
2. The mother shall enjoy primary physical custody of the minor child.
3. The father shall enjoy periods of temporary physical custody of the minor
child as follows:
a. On three out of four weekends from Friday at 4:00 p.m. until Sunday
at 5:00 p.m.
b. At such other times as agreed upon by the parties.
4. When father has custody of the child on a weekend and the child is off
from school on that Monday or Friday, father's weekend shall be
expanded to include those days off from school.
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5. The parties shall alternate custody of the minor child on holidays pursuant
to a schedule agreed between the parties. The holidays shall include New
Year's Day, Easter, Memorial Day, July 4'", Labor Day, Thanksgiving
and Christmas.
6. In the summer months, the parties shall share equally custody between
themselves, pursuant to a week on/ week off schedule arranged between
the parties or pursuant to some other schedule that gives the parties
relatively equal custody during the summer.
7. Mother will handle transportation for exchange of custody with the
understanding that father will contribute to mother a few dollars for
reimbursement on gas.
8. The parties may modify this schedule as they agree. Absent any agreement
the parties shall follow the schedule outlined above. In the event either
party desires to change this schedule and an agreement cannot be reached
between the parties, either party may petition the Court to have the case
again scheduled with the Custody Conciliator for a Conference.
BY THE COURT,
'\
Judge
cc: ~ssica Holst, Esquire
~elle R. Seachrist
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RICKY F. SEACHRIST,
Plaintiff
v
JENELLE R. SEACHRIST,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. OS-6298
IN CUSTODY
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:
Courtney M. Seachrist, born Apri129, 1996.
2. A Conciliation Conference was held on January 26, 2006, with the following
individuals in attendance:
The father, Ricky F. Seachrist, with his counsel, Jessica Holst, Esquire, and the
mother, Jenelle R. Seachrist, who appeared without counsel.
3. The parties agree to the entry of an Order in the form as attached.
l~3 ~~U ~
DATE Hubert X. Gilroy, squire
Custody Concili or
JENELLE R. SEACHRIST,
Plaintiff
v.
RICKY F. SEACHRIST,
Defendant
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
IN CUSTODY
NO.OS-6298 CIVIL TERM
PETITION FOR MODIFICATION OF A CUSTODY ORDER
AND NOW comes Defendant, Ricky F Seachrist, ("Father") by and through his attorneys,
the Family Law Clinic, and respectfully submits this Petition for Modification of a Custody Order,
and in support thereof avers the following:
1. On February 2, 2006, an Order of Court was entered for custody of Courtney M.
Seachrist, born Apri129, 1996, a true and correct copy of which is attached. Under the Order,
Father has partial physical custody of the child and Jenelle R. Seachrist ("Mother") has primary
physical custody of the child. Father has physical custody of the child on three out of four
weekends each month from Friday at 4:00 p.m. until Sunday at 5:00 p.m, and at such times as
agreed upon by the parties. In addition, the parents share custody during the summer and on
holidays.
2. Per agreement of the parties, Father has been caring for the child at times during the
week when Mother is unavailable due to her employment obligations.
3. Sometime after the Custody Order was entered, mother began living with her paramour.
4. Mother's paramour has a history of being arrested for possession/use of marijuana and
other drug paraphernalia, driving under the influence of alcohol, harassment through physical
contact~and lewd and threatening language.
5. Mother's paramour has been verbally and physically abusive to father's daughter.
6. Mother's paramour has been under the influence of drugs and alcohol in the presence of
father's daughter.
WHEREFORE, Petitioner asks that the Court modify the existing Custody Order to require
mother to prevent her paramour from (1) verbally and physically abusing the child, and (2} using
any drugs or narcotics in the child's presence. Father further requests that the Court modify the
current order to add a provision confirming that he shall have physical custody of the child when
Mother is unable to care for her for more than two hours due to employment obligations.
Date: 3 - 0 $ - 01 ~`' 'N ~V-~'V
Scott Weber
Certified Legal Intern
THO DACE
ROBERT .RAINS
LUCY JOHNSTON-WALSH
ANNE MACDONALD-FOX
MEGAN RIESMEYER
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
VERIFICATION
I verify that the statements made in this petition are true and correct. I understand that false
statements herein are subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification
to authorities.
Date: -3^~~^Q~ ;/•
Ricky F. eaclirist
CERTIFICATE OF SERVICE
I, Scott Weber, Certified Legal Intern, the Family Law Clinic, hereby certify that I am
serving on this date a true and correct copy of a Petition to Modify Custody Order on the following
person by first class U.S. Mail, postage prepaid, this 8th day of March, 2007 addressed as follows:
Jennelle R. Seachrist
388 Pin Oak Lane
Country Manor Trailer Park
Carlisle, PA 17015
~~
Scott Weber
Certified Legal Intern
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
4
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RICKY F. SEACHRIST, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUNIBERLAND COUNTY, PENNSYLVANIA
v CIVIL ACT10N -LAW
JENELLE R. SEACHRIST, NO.OS-6298
Defendant IN CUSTODY
COURT ORDER
AND NOW, this ~ ~ d day of C ~ ac 2006, upon consideration of the
attached Custody Conciliation report, it is ordered that the York County Order of June 22,
2000 at Docket No. 2000-03084 is vacated and replaced with the following Order of Custody
in this case:
1. The father, Ricky F. Seachrist, and the mother, Jenelle R. Seachrist, shall
enjoy shared legal custody of the minor child, Courtney 1VI. Seachrist,
born Apri129, 1496.
2. The mother shall enjoy primary physical custody of the minor child.
3. The father shall enjoy periods of temporary physical custody of the minor
child as follows:
a. On three out of four weekends froth Friday at 4:00 p.m. until Sunday
at 5:00 p,m.
b. At such other times as agreed upon by the parties.
4. When father has custody of the child on a weekend and the child is off
from school on that Monday or Friday, father's weekend shall be
expanded to include those days off from school.
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5. The parties shall alternate custody of the minor child on holidays pursuant
to a schedule agreed between the parties. The holidays shall include New
Year's Day, Easter, Memorial Day, 3uly 4`", Labor Day, Thanksgiving
and Christmas.
6. In the summer months, the parties shall share equally custody between
themselves, pursuant to a week on/ week off schedule arranged between
the parties or pursuant to some other schedule that gives the parties
relatively equal custody during the summer.
7. Mother wi11 handle transportation for exchange of custody with the
understanding that father will contribute to mother a few daliars for
reimbursement on gas.
8. The parties may modify this schedule as they agree. Absent any agreement
the parties shall follow the schedule outlined above. In the event either
party desires to change this schedule and an agreement cannot be reached
between the parties, either party may petition the Court to have the case
again scheduled with the Custody Conciliator for a Conference.
BY THE COj.1RT,
~~~.~~~
cc: ~ssica Hofst, Esquire
~elle R. Seachrist ~ n t~'
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JENELLE R. SEACHRIST,
Plaintiff
v.
RICKY F. SEACHRIST
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
IN CUSTODY
NO. OS-6298 CIVIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS
TO THE PROTHONOTARY:
Kindly allow Ricky F. Seachrist, Defendant, to proceed in forma pauperis.
The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies
that we believe the party is unable to pay the costs and that we are providing free legal service to
the party.
~ -~ g- 07
Date
Respectfully submitted,
~~G~~ ~~~
Scott Weber
Certified Legal Intern
ROB S
THO S M. PLACE
ANNE MACDONALD-FOX
LUCY JOHNSTON-WALSH
MEGAN RIESMEYER
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
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JENELLE R. SEACHRIST
PLAINTIFF
v.
RICKY F. SEACHRIST
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
• OS-6298 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Tuesc
it is hereby directed that parties and
at 4th Floor, Cumberland Coun
[arch 13, 2007 ,upon consideration of the attached Complaint,
respective counsel appear before Hubert X. Gilroy, Esq. ,the conciliator,
Carlisle on Thlursday, April 12, 2007 at 8:30 AN
for aPre-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. A11 children age five or older ma~ also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporar~ or permanent order.
The court hereby directs the p~rties 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/ 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 1)90. For i formation about accessible facilities and reasonable accommodations
available to disabled individuals h~ving business before the court, please contact our office. All arrangements
must be made at least 72 hours prig to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE fiH1S PAPER TO YOUR ATTORNEY AT ONCE. lF YOU DO NOT
HAVE AN ATTORNEY OR CA NOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT~HERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
~, 32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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Jenelle R. Seachrist, IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. :CIVIL ACTION-LAW
DIVORCE
Ricky F. Seachrist,
Defendant NO.OS - 6298 CIVIL TERM
CERTIFICATE OF SERVICE
I, Scott Weber ,Certified Legal Intern, Family Law Clinic, hereby certify that I served a
true and correct copy of the Petition for Modification of a Custody Order on March 27, 2007, on
Jenelle Seachrist residing at, 388 Pin Oak Land, Country Manor Trailer Park, Carlisle, PA
17013, by depositing a copy of the same in the United States mail, certified, restricted delivery,
return receipt requested, postage prepaid. Service was complete upon receipt by Jenelle R.
Seachrist, on the 30th day of March 2007 as evidenced by the attached green card.
°~~~.
Scott Weber
Certified Legal Intern
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
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JENELLE R. SEACHRIST
Plaintiff
v.
RICKY F. SEARCHRIST ,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
IN CUSTODY
NO. OS-6298 CIVIL TERM
PRAECIPE TO WITHDRAW CLAIM
To the Prothonotary:
Kindly allow the Defendant, Ricky F. Seachrist, to withdraw without prejudice his Petition
for Modification of a Custody Order for the following reasons:
1. The Defendant, Ricky F. Seachrist, filed a petition for modification of a custody order
on March 8, 2007.
2. The issue that created the need for the custody order to be modified has been resolved.
3. Defendant no longer wishes to modify the custody order.
For the foregoing reasons, kindly withdraw the Defendant's Petition for Modification of a
Custody Order.
~~~ ~Q~
Scott Weber
Certified Legal Intern
Anne snald-Fox,1~s
Supervisi g Attorney ~-./~
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
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APR 18 2007 /"
JENELLE R. SEACHRIST, IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v :CIVIL ACTION -LAW
RICKY F. SEACHRIST, NO. 2005-6298
Defendant IN CUSTODY
COURT ORDER
AND NOW, this 13`h day of April, 2007, the Conciliator being advised the
Defendant/Petitioner having withdrawn his Petition for Modification of A Custody Order,
the Conciliator relinquishes jurisdiction.
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Hubert X.
Custody C
,Esquire
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ID~ RPR 11'07 14 15 No .002 P.01
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PENN~TATE
The Dickinson
Schaal cif Law
VIA FACSIMILE
Hubert Gilroy, Esq.
10 East High Street
Carlisle, PA 17013
w'NIf11Iy Lfl\V I:f!inic
q nervier.. In the c:onutluitily by 4turlcnls
fnnn Penn Rlulc lfuivcraily's r)ICkinsnn
Sclwuf ul' I .aw
April 11, 2007
Re: Seachrist v. Searchrist; 05-6298; Custody
Dear Mr. Gilroy:
'I'I,i: 1)al~: N. tihttFharl
Conlmtmity Lnw (7cnlcr
45 N~rlh PiU Strcct
Carlixlc, PA 17013
Uffic.n: % i'I.243 7.9GR nr
717-24:1-kU34
Pax; 717-243-:ih3r)
This letter is to conl5rm my conversation with your paralegal today. The Family
Law Clinic represents Ricky Seachrist, defendant/petitioner in the above matter. Mr.
Seachrist has decided to withdraw his March 8, 3007 Petition For Modification of A
Custody Order. Therefore we are asking that the Pre-Hearing Custody Conference
scheduled before you at 8:30 AM on April 12, 2007 be cancelled.
The Family Law Clinic has contacted the opposing party, Jenelle Seachrist and we
have informed her of the cancellation of tomorrow's conference. We apologize for any
inconvenience this last-minute cancellation might have caused you.
Cc Ricky Seachrist
Very truly yo~ur/s', p
Scott Weber
An liyual Oppnrtuni(y lfnivcrsily