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HomeMy WebLinkAbout87-0070 LYNN E. TROUT, et al., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVAN~ : vs. : CIVIL ACTION - LAW : NO. 70 CIVIL 1987 WENDY K. TROUT, : Defendant : CUSTODY ~ ~o~, t~s ~l ~ °~-~~ day of ~,- 1~88, the within Stipulation is hereby endorsed as an Order of Court. By the Court, WAYNE F. Sx~o~ Att .... y at Law ~ South H,anover Street 'lisle, Pennsylvania 17013 ,YNN E. TROUT, et al., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : CIVIL ACTION - LAW : NO. 70 CIVIL 1987 K. TROUT, : Defendant : CUSTODY STIPULATION FOR RELEASE OF PERFORMANCE BOND AND NOW, this~ day of .~/~ , 1988, come iff Lynn E. Trout and Defendant Wendy K. Trout, and with rard to the performance bond in the amount of $4,450.00 plus ~t, stipulate and agree that the performance bond be ~d and distributed, as follows: 1. $17.75 to the Prothonotary of Cumberland County on account of )utstanding filing fees in this matter; 2. $300.00 to Defendant Wendy K. Trout; and 3. Balance to Plaintiff Lynn E. Trout. It is the desire and intention of the parties hereto that :his Stipulation be entered in the Court of Common Pleas of ~umberland County, Pennsylvania, and that it be endorsed as an of Court so as to have the full effect thereof. I verify that the statements made in the foregoing ~ulation are true and correct. I understand that false Attorney a~ Law 5 South Hanover Street rlisle, Pennsylvania 17013 ~tatements therein are made subject to the penalties of 18 Pa. S. ~4904, relating to unsworn falsification to authorities. ~nn E. Trout I verify that the statements made in the foregoing ~tipulation are true and correct. I understand that false ents therein are made subject to the penalties of 18 Pa. S. ~4904, relating to unsworn falsification to authorities. ,,.,>~.C~..f/ , 1988 Wen~. Trout ~;AYi~E F. SX~AO,~ -2- Attorney at Law 5 South H~anover Street rllsle, Pennsylvania 170L IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA , CIVIL ACTION LAW LYNN g. TROUT~ LINDEN g. : NO. 85-S-375 AND MARY C. TROUT, : ~ ~ Plaintiffs : ~_~ vs. : I~ ~.!to ~NDY K. TROUT, : ., Defendant : Custody La_ N.: o CUSTODY CONFERENCE MEMORANDUM L~;:~: I. ISSUES A. Outstanding Rule regarding transfer of venue to Cumberlan~ County. B. Serious psychological problems of the father. C. Admissibility without further qualification of the transcript of testimony of Trooper Donald Blevins taken at the contempt hearing on August 16, 1985, at No. 85-S-6 of this Court. WITNESSES A. Wendy K. Trout B. Richard L. Deihl C. Frances Ao Deihl D. Ray L. Deihl E. Vi Smith Fo Clair Smith G. Trooper Donald Blevins H. Such other witnesses of whom Plaintiffs will be promptly notified. III. ESTIMATED TIME One-half day. ~tto~ey at Law ~ H~er E~eet Pennsylvania 17013 IV. SPECIAL REQUESTS Ao Psychological evaluation of father. B. Performance bond to secure Plaintiffs' lawful observance of any future court orders. Co Defendant's counsel fees and expenses in locating the child and seeking to enforce the custody provisions of the Protection from Abuse Order of this Court of January 10, 1985, at No. 85-S-6. V. POTENTIAL FOR SETTLEMENT Poor. Respectfully submitted, Wa~h~e 7. S]~ade - Attorney for Respondent 19~_. This being a true ~ ~' ,~ted c. opy t~ken from mhd co:::pgred ~i'bh the original Attest: Prothonotary ttorney at Law .th Hanover ~tr~et , Pennsylvania 17013 -- 2 - 1 -N THE COURT OF COMM@,~] PLEAS OF ADAMS COUNTY, PENNSYLVANIA Civil 2 ~ 3 L,rnr~ E. Trout 85-S-375 4 v. 5 ~Jendy K. Trout 6 ORDER OF COURT ~ AND NOW, this 10th day of December, 1986, upon request 8 cf h}~e Petitioner, Lynn E. Trout, a custody conference is 9 .~h~.~ule .... for December 22, 1986, at 1:00 p.m., Room ~4!1 ~.ounty Courthouse, Gettysburg, Pennsylvania. 11 BY Ti{rE COURT, 12 Gohn ~ Kuhn, d 15 mew 16 17 18 19 and attested copy taken from 21 and compared with the original 22 Attest: 24 ~ Prothonotary 25 IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA Civil Lynn E. Trout, Linden E. 85_S_375 and Mary C. Trout, Plaintiffs vs. Wendy K. Trout ? ORDER OF COURT 8 AND NOW, October 8, 1985, the parties appeared with counsel. The Court refuses the petition of the mother to transfer venue to Cumberland County. The Court Administrator is directed to schedule this case for hearing during the first part of January, 1986 and to notify the parties of the time of hearing as far in advance as possible. It is Ordered that the parties and the child submit to a psychological evaluation by Dr. Stephen Coslett. Dr. Coslett will be the Court's witness. Either party may call him. If neither party calls him, his report will be admissible without his being present. It is further Ordered that a home study be perfom~ed of the mother's home. If Adams County Children and Youth 22 Services can do this, they are requested to do so, and a 23 fee of $25 is set to be paid by the father. If the Agency cannot do it, it is requested to arrange such a study by the proper agency in Cumberland County. The father will pay the costs of that study. 1 The father is directed to file a performance bond in 2 a form approved by the Court in the principal amount of 3 $5,000. The bond may either be cash or it may be with 4 sufficient surety. The bond will be conditioned upon the 5 payment to the mother of any expenses up to the amount of e the principal incurred as a result of her enforcing her ? primary custodial rights under this order. 8 Pending the hearing, primary custody, both legal and 9 physical Of the child is awarded to the mother.' The father l0 will have custody on alternating weekends from Friday at 6:£ ll o'clock p.m. until Sunday at 6:00 o'clock p.m. The first 12 weekend will be the weekend following his posting of the ~3 bond and the approval thereof by the Court. 14 Conditioned on his filing the bond, he will also have ~5 custody from noon on December 25, 1985 until 10:OO o'clock ~s a.m. on December 26, 1985. l? The father will provide transportation in the exercise is of his partial custodial rights. Transfer of custody will 19 be at the mother's present domicile. The parties are 20 admonished to restrict communications to those necessary 21 for the welfare of the child. There will be no recriminatic ~s, 22 threats, insults or other belligerent type of communication 2s The Court will schedule a further preliminary 24 conference to consider the point of transfer if problems 25 have arisen at the mother's home. 1 The costs of Dr. Coslett's report will be equally 2 divided by the parties. The p~rty requesting Dr. Coslett's 3 appearance in Court will pay the costs of the Court 4 appearance. 5 BY THE COURT) 8 Clayton W~[coz, ~-sq. 9 Attorney for Mr. Trout lo Wayne F. Shade, Esq. Attorney for Mrs. Trout 1! akw 12 13 14 15 16 17 18 19 ~'-:.~f ~9~_. This being a true and attested copy taken from 20 and compared with the original 21 Attest: 23 ~ Prothonotary 24 ~- 25 , ,-, _ ~, t v . ~::'~U ~;:b'::UTM ,-v Casel 8~-S-375 OateofEntw May 10 , 19 8~ at 11~P3A M Attomey(PLF) L. Rex Bickley-Clayton R. Wilcox Action: Custody A~orneylDEFI ~a~e F. Shade - L~ E. Trout~ -~ Linden E. Trout ~d O'~' J COSTS: Ma~ C. Trout ~INTIFF Prothy. 40.00 Pd. T~ ~ ~0 Pd. VS. Home Study 2g. OO "' Sheriff ret. filed . · Date of service DEFENDANT Sheriff cost May 10, 198~: Complaint for Custody ~d Visitation filed. May 10, 198~: Order of Co~t filed. (Custody conference to be held 198g at 8:~0 A.M. in Room ~411 of the Ad~s Co~ty Courthouse) ~'-~ May 31~ 1985: Motto~ FOr Continuance and Order cE Court Ellen. (Mearino ' continued until ~ne 28t 1985 at 8:30 July 2. 198g: Praecioe to Discontinue filed. Parke~ D. L~ew~ Au~st 23. 198~: Petition of Defend~t r Tr~sfer of Venue ~rsuant to PA. R.C.P. l~l~.2(d) ~d Order of Court filed, A~ NOW, this 23rd da~ of Au~st. 198~. uoon consideration of the within Petition ~d u~on Motion of Wa~e F. Shade. Eseuire. Attomey fo~ ~ Defender, a R~e t~ issued upon Plaintiffs to ~how Cause why the follo~in~ relief aho~d not be ~ted: (a) transfer of venue of this case to the Court of Common pleas of C~berl~d Cowry, Pe~avlv~ia; ~d (b) suspension of the partial custody provisions ~der penai~E Order of this Co~t, dated J~ua~ lO, 198~, at No. 8~-S-6 pending ~ther Order of Co~t in t~s case. R~e retu~able within 1~ days of dat~ o~ By the Court, /s/ Oscar F. Spicer P.J. August 29, 198~: Petition to Withdraw as Counsel filed by L. Rex Bicklev, Esquire. I_ August 30. 198~: Rule to Show Cause filed. AND NOWt.this 29th day of August, 198~ upon consideration of the foregoinE Petition and on Motion of L. Rex Bickley, EsquSre~ a Rule is directed to Lynn E. Trout, Linden E. and Mar-/ C. Trout, to show cause why counsel for the Plaintiff should not be permitted to withdraw. RULE RETURNABLE October 11~ 1985 at 9:00 a.m. BY THE COURT: /s/Oscar F. Spicer J. September 25. 1985: Petition for CustodY Conference ~nd Order of tours filed. (conference to be held October 8, 1985 at 1:00 ~.m. in Room ~11) ~ October 9. 1985: Order of Court dated October 8. 1985 filed. (The Cour$ Administrator is directed to schedule this case for hearin~ durin~ the , hearing as far in ad--ca aa possible. The child and the parties are to .submit to a psychological evaluation by Dr. Stephen. Coslett. Dr. Coslett i nartv calls him. his renort will be admissible without his betn~ nresent. Home study be nerformed of the mother's home. Father to file a oerformanse bond in a form annrovad bv the Court in the nrincinal ~mm,~nt of $$.000. The bond may either be cash or it may be with a sufficien$ sureSv~ The bond will be conditioned upon the payment to the mother of any expenses up to the amount of the principal incurred as a result of her enforcing her primary custodial rishts under this order. Pending the hearing, primary custodyt both legal and physical of the child is awarded to the mother. The father will have custsdV on alternating weekends frsm Friday at 6;00 o'clock p.m. until Sunday at 6:00 o'clock p.m. The first weekend will be the weekend followinM his posting of the bond and the approval thereof by the Court.) ~ ~ . October 11. 1985: Ca~e called. Judge entered Order. October 21. 198~: Petition for Annroval of Bond filed bv Clavl~ R,. for lmlalnttffs. (Bond attached) October 21. 1985: Order filed, ORDR~ .. AND NOW! this 18th day of October~ 1985, the bond filed in the Lynn E. Trout, et al, : No. 85-S-375 Plaintiffs : "CONTINUED" vs. : Action in Custody Wendy K. Trout, : Defe~ant above referenoed matter bv Lynn E. Trout is herebv approved. The Prothonotary_ 8hall keen the ~rOO0.OO under his contac1 unit. il Order of Court, BY THE COURT: /s/ Oscar F. Spicer p.J. December 18, 1985: Order of Court filed. ORDER OF COURT AND NOW, December 17, 1985, it is Ordered that the hearing in the above capt$oned matter be scheduled for January 31:1986 at 9:00 a.m. in Court Room #2 of the Adams County Courthouse. BY THE COURT, /s/Oscar F. Spicer P.J. January 28, 1986: Motion for Continuance filed. : January 30, 1986: Order of Court filed. ORDER OF COURT AND NOW, this 30th day of January, 1986, upon consideration of the foregoing Motion to Continue, the hearing in the above captioned matter scheduled for January 31, 1986, is hereby continued. The case shall be heard in the future at the call of either party. The current schedule of temporary custody previously entered by this Court shall continue pending luther hearing and Order of Court. BY THE COURT: /s/John D. Kuhn J. June 13. 1986: Motion To Withdraw filed bv Clayton R. Wilcox. Esauire. June 17. 1986~Order of CQurt dated June 16. 1986. filed. (Motion filg~ aranted.) June 19, 1986: Praeci~e filed. And Now, this 19th day of June, 1986, the appearance of Clayton R. Wilcox, Esquire, is hereby withdrawn in the above referenced case. Parker D. Lerew, Prothonotary ~ Dg~uty~rothonotary November 26~ 1986~ Motion to Continue filed by Lynn E~ Trout~ December 10~ 1986: Order of Court filed. (Custody Conference to b9 hgl~ December 22~ 1986 at 1:00 p.m. in Room 411.) I December 10~ 1986: Petition of Defendant for Transfer of Venue Pursuant to · PA'. R.C.P. 1915.2(d) and Order of Court filed. (Rule Returnable December 22, 1986 at 1:00 o'clock ~.m.) December 22, 1986: Custody Conference Memorandum filed. December 24, 1986: Order of Court dated December 22, 1986. filed. (Primary physical and legal custody of the parties' minor child awarded to the mother. Father to have partial physical custody of the parties' minor child as stated in the order. Based upon agreement of the parties~ venue of this matter trans- ferred to Cumberland County, Pennsylvania.) January 2, 1987: Ail papers mailed to Lawrence E. We]ker. Prothonotary ~f Cumberland Count~. (Certified Mail receipt No. P 382 820 638) and ~ttested e0D~ taken f~0m anR ~0m~reR with the original Attest: LYNN E. TROUT, LINDEN E. : IN THE COURT OF COMMON PLEAS OF AND MARY C. TROUT, : ADAMS COUNTY, PENNSYLVANIA Plaintiffs : : CIVIL ACTION - LAW vs. : ~NO. 85-S-375 WENDY K. TROUT, : Defendant : CUSTODY ORDER OF COURT AND NOW, this i~~day of December, 1986, upon consideration of the within Petition and upon Motion of Wayne F. Shade, Esquire, Attorney for Defendant, a Rule is issued upon Plaintiff LYNN E. TROUT to Show Cause why the following relief should not be granted: (a) transfer of venue of this case to the Court of Common Pleas of Cumberland County, Pennsylvania; (b) payment of the fees of Dr. Coslett from the performance bond posted in this case; and (c) payment of the counsel fees of Petitioner for preparation of this Petition and attendance at the Custody Conference scheduled for December 22, 1986, at the request of Plaintiff LYNN E. TROUT. Rule returnable December 22, 1986, at 1:00 o'clock p.m. By the Court, and attested copy taken from / ~'J' and compared with the original louthH~over Street sic, Pennsylvania 17013 5YNN E. TROUT, LINDEN E. : IN THE COURT OF COMMON PLEAS OF AND MARY C. TROUT, : ADAMS COUNTY, PENNSYLVANIA Plaintiffs : : CIVIL ACTION - LAW ~ vs. : NO. 85-S-375 : WENDY K. TROUT, : Defendant : CUSTODY PETITION OF DEFENDANT FOR TRANSFER OF VENUE PURSUANT TO PA. R.C.P. 1915.2(d) TO THE HONORABLE, THE JUDGE OF SAID COURT: The Petition of Defendant WENDY K. TROUT, by her Attorney, Wayne-F. Shade, Esquire, respectfully represents, as follows: 1. Petitioner WENDY K. TROUT is an adult individual, the Defendant herein and the natural mother of Eric Lynn Trout, the child who is the subject of these proceedings and who was born on ~ovember 17, 1983. 2. Respondent LYNN E. TROUT, is adult individual and Plaintiff herein who resides at 115 White Oak Tree Road, York Springs, Adams County, Pennsylvania. 3. With the exception of the period from June 15, 1985, through July 30, 1985, when Plaintiff LYNN E TROUT unlawfully retained custody of the subject child in violation of the partial custody provisions of the Order of your Honorable Court of January 10, 1985, docketed to No. 85-S-6, the child who is the subject of these proceedings has lived primarily with Defendant in Cumberland County since December of 1984, a period of two years. W~Y~z F. Attorney at Law Sous H~over Street rltsle, Pennsylvania 1701~ LYNN E. TROUT, LINDEN E. : IN THE COURT OF COMMON PLEAS OF AND MARY C. TROUT, : ADAMS COUNTY, PENNSYLVANIA Plaintiffs : ~ : CIVIL ACTION - LAW vs. : NO. 85-S-375 : ~ENDY K. TROUT, : Defendant : CUSTODY PETITION OF DEFENDANT FOR TRANSFER OF VENUE PURSUANT TO PA. R.C.P. 1915.2(d) FO THE HONORABLE, THE JUDGE OF SAID COURT: The Petition of Defendant WENDY K. TROUT, by her Attorney, Wayne F. Shade, Esquire, respectfully represents, as follows: 1. Petitioner WENDY K. TROUT is an adult individual, the Defendant herein and the natural mother of Eric Lynn Trout, the child who is the subject of these proceedings and who was born on ~ovember 17, 1983. 2. Respondents LYNN E. TROUT, LINDEN E. TROUT and MARY C. TROUT ~re adult individuals and Plaintiffs herein who reside at 115 White Oak Tree Road, York Springs, Adams County, Pennsylvania. 3. With the exception of the period from June 15, 1985, through July 30, 1985, when Plaintiff LYNN E TROUT unlawfully retained custody of the subject child in violation of the partial custody provisions of the Order of your Honorable Court of January 10, 1985, docketed to No. 85-S-6, the child who is the subject of these proceedings has lived primarily with Defendant in Cumberland County since December of 1984, a period of two years. Attorney at Law 5 South H~over Street arlisle, Pennsylvania 17012 4. After release of Plaintiff LYNN E. TROUT from the Adams CoUnty Prison for indirect criminal contempt as a result of his violation of the aforesaid Order of January 10, 1985, Plaintiff, LYNN E. TROUT, by his Attorney, Clayton R. Wilcox, Esquire, filed herein a Petition for Custody Conference on September 25, 1985. 5. At the Custody Conference on October 8, 1985, an interim Order was entered, a copy of which is attached hereto as Exhibit "a". 6. The hearing referenced in said Order of October 8, 1985, to be scheduled for the early part of January of 1986 was scheduled for January 31, 1986. 7. On January 30, 1986, at the request of Plaintiff LYNN E. TROUT, this hearing was continued generally. 8. In June of 1986, Plaintiff LYNN E. TROUT disengaged his counsel. 9. From January 30, 1986, through December of 1986, Plaintiff LYNN E. TROUT has done nothing to pursue partial custody. 10. The aforesaid Custody Conference Order of October 8, 1985, ordered a psychological evaluation of Plaintiff LYNN E. TROUT and ordered him to pay one-half of the expense therefor. Attorney at Law 5 Sou~ Hanover Street .rlisle, Pennsylvania 17013 -- 2 - Plaintiff LYNN E. TROUT has repeatedly and continually refused to pay said obligation as evidenced by a copy of a letter from Dr. Coslett dated June 30, 1986, which is attached hereto as Exhibit "B" and incorporated herein by reference as though fully set forth. 12. As indicated in our initial Petition for Transfer of Venue filed herein in August of 1985, the conduct of Plaintiff LYNN E. TROUT throughout this entire case has been and will continue to be such that frequent supervision of any future orders will be necessary, and resort to the Court of Common Pleas of Adams County by the natural mother is unduly burdensome and expensive to her when the child is residing in Cumberland County, Pennsylvania. 13. Petitioner WENDY K. TROUT intends to continue to reside permanently in Cumberland County, Pennsylvania. WHEREFORE, Petitioner respectfully prays that your Honorable Court issue a Rule upon Plaintiff LYNN E. TROUT to Show Cause why the following relief should not be granted: (a) transfer of venue of this case to the Court of Common Pleas of Cumberland County, Pennsylvania; (b) payment of the fees of Dr. Coslett from the performance bond posted in this case; and (c) payment of the counsel fees of Petitioner for preparation of this Petition and attendance at the Custody Attornoy at Law -- 3 - 5 South H~over ~treot :lisle, Pennsylvania 17013 197~-. This being ~ true amd attested copy tmken from ~nd co~P~red with the original kttest: ~-~ Prothonoto, rY Conference scheduled for December 22, 1986, at the request of Plaintiff LYNN E. TROUT. ~ayn~/F. Shade Attorney for Defendant I hereby verify that the statements made in this Petition are true and correct. I understand that false statements herein made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. Date: December 9, 1986 Wendy ~/Trout ~' ~?~_ 19~. This being a true and attested copy taken from and compared with the original Attest: Prothonotary -4- AYNE F. SHA.E ~ttorney at Law ~th HanOver ~treet :, ~ennsy]v~nla 1~0~3 iN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA Civil Lynn E. Trout, Linden E. -and Mary C. Trout, 85-S-375 Plaintiffs VS. Wendy K. Trout ORDER OF COURT AND NOW, October 8, 1985, the Parties appeared with 'Counsel. The Court refuses the petition of the mother to %ransfer venue to Cumberland County. The Court Administrator is directed to schedule this case for hearing during the first part of January, 1986 and to notify the parties of the time of hearing as far in advance as possible. It is Ordered that the par~ies and the child submit to a psychological evaluation by Dr. Stephen Coslett. Dr. Coslett will be the Court's witness. Either party may call him. If neither party calls him, his report will be admissible without his being present. It is further Ordered that a home study be Performed of the mother's home. If Adams County Children and Youth Services can do thia, they are requested to do so, and a fee of ~o~ , .o~. be paid by the father. If the Agency cannot ,J.o .it, it i.~.; r'eq~ested to arl-;~ge such a study by the proper a~encs~ in '"k:n;b~lund ~ . ,.,o~zr~ty. The father, w/Il pay the co~ts of that stu,?y. EXHIBIT "A-i" The father is directed to file a performance bond in a form approved by the Court in the principal amount.of $5,000. The bond may either be cash or it may be with sufficient surety. The bond will be conditioned upon the payment to the mother of any expenses up to the amount of the principal incurred as a result of her enforcing her primary custodial rights under this order. Pending the hearing, primary custody, both legal and physical of the child is awarded to the mother. The father wall have custody on alternating weekends from Friday at 6:00 o'clock p.m. until Sunday at 6:00 o'clock p.m. The first weekend will be the weekend following his posting of the bond and the approval thereof by the Court. Conditioned on his filing the bond, he will also have custody from noon on December 25, 1985 until 10:O0 o'clock a.m. on December 26, 1985. The father will provide transportation in the exercise of his partial custodial rights. Transfer of custody will be at the mother's present domicile. The parties are admonished to restrict communications to those necessary for the welfare of the child. There will be no recriminations, threats, insults or other belligerent type 'of communication. Th(} Codrt will schedule a further preliminary conference to consider the point of transfer if problems have az'isen at the mother's home. EXHIBIT "A-2" The costs of Dr. Coslett's report will be equally divided by the parties. The party requesting Dr. Coslett's appearance in Court will pay the costs of the Court appearance. BY THE COURT, Clayton ~,ilcox, ESq. Attorney for Mr. Trout Wayne F. Shade, Esq. Attorney for ~s. Trout akw EXHIBIT "A-3" STEPHEN B. COSL.ETT, Ph,D, CLINICAL PSYCHOLOGIST BELVEDERE MEDICAL CENTER 850 WALNUT BOTTOM ROAD CARLISLE. PA 17013 .-' TELEPHONE 717-243-6717 June 30, 1986 F~. I.D 23-2088617 Wayne Shade, Esq. Attorney-at-Law 5 South Hanover Street Carlisle, PA 17013 RE: Trout Custody Dear Attorney Shade: ! am writing you regarding the Trout Custody and the outstanding bill of $250.00 owed by Mr. Lynn Trout. -I am aware that Lynn Trout was not your client but thought you might be able to give me some options in trying to collect this unpaid balance. I have been billing Mr. Trout monthly and have also advised him that I would be happy to set a payment plan that was mutually desirable. I have not heard from him in any way. I have also written his attorney, Clayton Wilcox on two different occasions, namely January 6 and April 24 1986 Likewise, ! have had no response from him. ' ' If you could give me any suggestions as to what options ! have in this case for collection, I would very much appreciate it. Thank you for your assistance in this matter. Sincerely, Stephen B Coslett, Ph.D' Clinical Psychologist bc EXHIBIT "B" No. 85-S-375 ' PRAECIPE FILED Office of the PROTHONOTARY of Adams County PARKER, D. LEREW HELEN L. WOERNER Chiel' Depuly ~-..~-'~ (7171 334-6781 ~ Exts. 285 & 286 ~ II.,._ P. O. Box 541 Courthouse Gettysburg, PA 17325 TO: ATTORNEYS PRACTICING BEFORE THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA. FROM: PROTHONOTARY'S OFFICE RE: Lynn E. Trout, et al, No. 85-s-375 Plaintiff Action in Cn~.,~nr?y VS. Wendy ~r m ~ ..... rotl._t ezCndant Please make service of the Rule and file an Affidavit of Service with this office. Dated: December 10, 1986 i~ Prothonotary IN THE COURT OF COMMON PLE~S OF ADAMS COUNTY, PENNSYLVANIA CIVIL Lynn E. Trout, Linden E. Trout : No. 85-S-375 Mary C. Trout : VS. : Wendy C. Trout : ORDER OF COURT AND NOW, this .30th day of January, 1986, upon consideration of the foregoing Motion to Continue, the hearing in the above captioned matter scheduled for January 31, 1986, is hereby continued. The case shall be heard in the future at the call of either party. The current schedule of temporary custody previously entered by this Court shall continue pending further hearing and Order of this Court. BY THE COURT: A~z~ 19_~_~. This being a true and attested copy taken from ~nd con,De, red with the original IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA CIVIL Lynn E.~Trout, Linden E. Trout : No. 85-S-375 and Mary C. Trout : VS. Wendy C. Trout : MOTION FOR CONTINUANCE AND NOW, this ?_~' day of January, 1986, Plaintiff, Lynn E. Trout, by his counsel, Wilcox and James, files a Motion to continue as follows 1. Hearing is scheduled in the above captioned matter for Friday, January 31, 1986. 2. The undersigned has been scheduled to try a criminal case on the aforesaid date. 3. Counsel for Plaintiff has notified counsel for Defendants, who has indicated that he has no objection to the continuance. Counsel for both parties have agreed that the existing schedule of periods of partial custody previously established by Your Honorable Court continue pending furth~er Order of Court. WHEREFORE, Counsel for Plaintiff requests that the matter be continued at the call of either party. ~-~. ~_ 19~. This being a true WILCOX & JAMES c,nfi~ attested copy taken from a'~ co:~:pared with the original .At~czt: ........By: _^ ~ Ulay~;~n R. Wilco~ Esquire -~~~ Attorney for Lynn E. Trout  Prothonotary - IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA Lynn E. Trout, Linden E. Trout : No. 85-S-375 Mary C. Trout : : vs. : Custody Action : Wendy C. Trout : ORDER OF COURT AND NOW, this 16th day o~'M~fy, 1986, upon consideratior of the foregoing Motion to Withdraw and lack of any objection filed thereto by Lynn E. Trout, it is hereby ordered that the Motion filed by Clayton R. Wilcox, Esquire, to withdraw as counsel for Lynn E. Trout in this case is hereby granted. BY THE COURT: ~., ~ ,, i9~. This being a true and attested copy taken from ~nd con'~p~red with the original !ttest: FILED Prothonotar2z ~ PROTHONOTARy IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA Lynn E. Trout, Linden E. Trout : No. 85-S-375 Mary C. Trout, : Plaintiffs : : VS. : : Custody Action Wendy C. Trout, : Defendant : MOTION TO WITHDRAW 1. The undersigned is counsel of record for Lynn E. Trout in the above referenced custody action. 2. The once positive attorney-client relationship no longer exists between the undersigned and Lynn E. Trout. 3. The undersigned does not represent the other two Petitioners who do not have counsel of record. 4. It is in the best interest of all those concerned that the undersigned be permitted to withdraw from this case. 5. The ten (10) day notice to the client required by Rule 9 of the Adams County Rules of Civil Procedure has been provided to Lynn E. Trout. WHEREFORE, the undersigned requests that he be permitted to withdraw as counsel in the above re~ ' ~lg~f? ~ sW~e~in~'~ Esquire __~. ~? i true \1_ ~)C3',.d~-~ ~ and attested copy taken from ~w~u. Attest: ~rothonota~y IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA CIVIL Lynn Eo Trout, Linden E. Trout and 85-S-375 Mary C. Trout Vo Wendy C. Trout ORDER OF COURT AND NOW~ December 17, 1985, it is Ordered that the nearing in the above captioned matter be scheduled for January 31, 1986 at 9:00 a.m. in Court Room #2 of the Adams County Courthouse. 12 BY THE COURT, 13 15 J p oJ. 16 17 19 car and attester copy taken from 21 and co:.pared with the original 22 Attest: 2~ ~ Prothonotary 25 IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA ' NOTICE OF HEARING To: Clayton Wilcox~ Esq.~ 238 Baltimore St.~ Gettysburg~ PA 17325 ..Wayne Shader Esq.~ 5 S. Hanover St.~ Carlisle~ PA 17013 YOU ARE HEREBY NOTIFIED OF THE DATE FOR HEARING IN THE FOLLOWING CASE: Lynn E. Trout~ Linden E. Trout and Mary C. Trout VS. No. 85-S-375 ...Wendy C. Trout THIS CASE IS SET TO BE HEARD IN THE ADAMS COI~NTY COURT ON January 31~ 1986 at 9:00 a.m. in Court Room #2 PLEASE BE PRESENT IN THE ADAMS COUNTY COURT, GETTYSBURG, PA., ON THE ABOVE DATE AND BE PREPARED TO PROCEED. The Office of the Adams County Court Administrator Phone: 717+334-6781-Ext. 213 Date of Notice: December 17~ 1985 cc: Judge Prothonota~ 19~_~_. ~nis being a true C.A. File and. attested copy taken from :.'i". and co.~.:~arcd with the original ~ ' ~'- - .... ._ ='-o oncno ~ary CLAYTON R. WILCOX NERE.Y CERT, TO.E ATTORNEY AT LAW A TRUE AND CORRECT COPY 238 BALTIMORE STREET CLAYTON R. WILCOX GETTYSBURG. PENNSYLVANIA 17325 717-334-85 ! 6 'BY ATTORNEY FOR IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA CIVIL LYNN E. TROUT, LINDEN E. : No. 85-S-375 TROUT AND MARY C. TROUT, : Plaintiffs : : VS. : : WENDY K. TROUT, : Defendant ORDER AND NOW, this 18th day of October, 1985, the bond filed in the above referenced matter by Lynn E. Trout is hereby apDr red BY THE COURT: ~L. ~7~ 19~_. %%~is being a true and attested ccpy taken from and co,,npared with the original Attest: ,~ /~ Prothonotary IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA CIVIL LYNN E. TROUT, LINDEN E. : No. 85-S-375 TROUT AND MARY C. TROUT, : Plaintiffs : vs. : WENDY K. TROUT, : Defendant · PETITION FOR APPROVAL OF BOND Lynn, E. Trout, by his counsel, Clayton R. Wilcox, Esquire, petitions the Court as follows: 1. By order dated October 8, 1985, Your Honorable Court entered an order establishing a schedule of temporary custody for Plainitff, Lynn E. Trout, with his son, Eric. 2. Said order was conditioned upon entry of a performance bond in the amount of $5,000.00 in a form to be approved by the Court. The bond was to be in cash or with sufficient surety. 3. The sum of $5,000.00 was deposited with the Prothonotary of Adams County, Pennsylvania, on October 10, 1985. 4. A proposed and executed bond is attached hereto. Plaintiff, Lynn E. Trout, requests approval of the attached bond. and attested copy taken from and compared with the original Attest: Clayton R. Wilcox, Esquire ~ ~,, ~ , Attorney for Plaintiffs  Prothonotary · ~,~-~- 19~. Tnis being a true .~n~_i attested copy taken from and co~pared with the original Attest:  Prothonotary IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA CIVIL LYNN E. TROUT, LINDEN E. : No. 85-S-375 TROUT AND MARY C. TROUT, : Plaintiffs : : VS. : : WENDY K. TROUT Defendant : BOND KNOW ALL MEN BY THESE PRESENTS, that I, Lynn E. Trout· of York Springs, Adams County, Pennsylvania, is held and firmly bound unto Wendy K. Trout, in the sum of Five Thousand ($5,000.00) Dollars, lawful money of the United States, to be paid to her or her certain attorney, executors· administrators, and assigns; to which payment, well and truly to be made and done, I bind myself and my heirs, executors, and administrators, firmly by these presents and sealed with my seal. The condition of this obligation is such, that if the above bound Lynn E. Trout abides by the terms and conditions of the order of court pertaining to the exercise of his right to periods of temporary custody with his son, Eric Trout, then this obligation shall be void. Otherwise, said obligation shall remain in full force and effect and the child's mother, Wendy K. Trout, shall be paid her just and reasonable expenses, up to said sum of $5,000.00, incurred by her as a result of her enforcing her primary custodial rights under said order. This bond is secured by $5,000.00 cash on deposit with the Prothonotary of Adams County, Pennsylvania, which may be used, upon order of Court to reimburse · said Wendy K. Trout for such expenses . Executed this /~-~day of October, 1985. Jnn E. Trout ~... (SEAL) WILCOX .EREa cERT, Y TO SE cLAYTON R. A TRUE ANO CORRECT ATTORNEY AT LAW CLAYTON R. WILCOX ~ 538 BALTIMORE STREET GETTYSBURG, pENNSYLVANIA 17325 . aY ATTORNEY FOR 717-:334-8516 IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LYNN E. TROUT, LINDEN E. : No. 85-S-375 AND MARY C. TROUT, : Plaintiffs : : : VS. : WENDY K. TROUT, : Defendant : Custody CUSTODY CONFERENCE MEMORANDUM A. Issues 1. Award for shared legal custody. 2. Award for primary physical custody and establishment of reasonable schedule of temporary custody in non-custodial parent. 3. Creation of temporary schedule pending final hearing with use of recital place of pick-up and delivery of the child. 4. Rights of Plaintiff's grandparents to periods of visita- tion with grandson. B. Witnesses for Plaintiffs 1. Above referenced Plaintiffs- 2. Robert E. Skelly, M.S., York Counseling and Psychological Services, 3110 East Market Street, York, Pennsylvania, 17402. 3. Rev. Landis and Rev. Bruce Smith, 13th Street, Harrisburg, Pennsylvania. 4. Donald Wheatly, Camp Hill, Pennsylvania. 5. Frank Showers and Miriam Showers, 86 Wite Oak Tree Road, York Springs, Pennsylvania- Plaintiffs reserve the right to name additional witnesses !~upon 20 days advance notice to Defendant. C. Special Requests 1. Home study of current residence of the child to be per- formed by Family Services. 2. Evaluation of Lynn Trout, Wendy Trout, and Eric Trout by independent professional not involved with psychotherapy. D. Settlement Potential Limited E. Estimated Time for Hearing 1% day. Respectfully s.ubmitted, Clayton R. Wilcox, Esquire Counsel for Plaintiffs ~_~ 19~J~. This being a and attested copy taken from and compared with the original ;_ttest:  ?rothonotgry CLAYTON R. WILCOX .ERESY CERT,. TO A TRUE AND CORRECT COPY ATTORNEY AT LAW 238 BALTIMORE STREET CLAYTON R. WILCOX GL:'TTYSBURG. PENNSYLVANIA 17325 BY ." 717-334-85 i 6 ATTORNEY FOR IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA CIVIL ACTION LAW LYNN E. TROUT, LINDEN E. : No. 85-S-375 AND MARY C. TROUT, : Plaintiffs : VS : WENDY K. TROUT, : Defendant : Custody ORDER OF COURT You, Wendy K. Trout, Defendant, have been sued in Court relating to the custody of Eric Lynn Trout. You are Ordered to appear in person at the Adams County Courthouse, Gettysburg, Pennsylvania, in Room 411, on the 8th day of October , 1985, at 1:OO o'clock p.M., for a con- ference. You are further Ordered to bring with you the child, Eric Lynn Trout. If you fail to appear as provided by this Order or to bring the child, an Order for Custody, partial custody or visitation may be entered against you or the court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator -~.~ atteste~! copy taken from Adams County Courthouse ~,g c0mpare~ with the original Gettysburg, PA 17325 !t (717) 334-6781 ~bcst: ;i ~ September 25, 1985 J' IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA CIVIL ACTION LAW LYNN E. TROUT, LINDEN E. : No. 85-S-375 AND MARY C. TROUT, : Plaintiff : : VS. : : WENDY K. TROUT, : Defendant : Custody PETITION FOR CUSTODY CONFERENCE AND NOW, this day of September, 1985, the above cap- tioned Plaintiffs make the following request: 1. On May 10, 1985, Plaintiffs filed a complaint for custody and visitation relating to his son Eric Lynn Trout. 2. No conference or hearing has been held thereon. 3. Plaintiff Lynn E. Trout does not currently enjoy periods of temporary custody with his son as a result of an order entered at the time he was released on parole after serving a 30 day sentence for contempt of Court. Said order was entered on Septem- ber 19, 1985, and in part of the record of an above action listed to number 85-S-6. 4. It is in the best interest of Eric that this matter proceed as quickly as possible and that maximum contact exist between Plaintiffs and Eric. 5. The provisions of the aforesaid complaint are incorporated herein by reference. WHEREFORE, Plaintiffs request that a custody conference be scheduled as soon as convenient to the Courts schedule. Clayton R. WilcOx, Esquire Counsel for Plaintiffs ~_~.~_ 19f~_. This being s true ~n~ attested copy taken from 3.nd co:~pared with the original ~.ttest: Prothonotary HEREBY cERTIFY TO BE CLAYTON R. WILCOX ATTORNEY AT LAW CLAYTON R. WILCOX 238 BALTIMORE STREET GETTYSBURG, PENNSYLVANIA 17325 BY -- ... ATTORNEY FOR 7 ! 7-334-8516 IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LYNN E. TROUT, LINDEN E. : No. 85-S-375 AND MARY C. TROUT, : Plaintiffs : : : VS. : WENDY K. TROUT, : Defendant : Custody ANSWER TO PETITION FOR TRANSFER OF VENUE AND NOW, this ~_day of September, 1985, Respondents to the above referenced Petition reply as follows: 1. Admitted. 2. Admitted. 3. It is admitted that the child Eric Lynn Trout currently resides with his mother in Cumberland County, Pennsylvania. However, the child continues to retain significant contact in Adams County. Moreover, this Court has the appropriate back- ground information because of prior contacts with the parties and is the most convenient forum to hear the case. 4. It is admitted that Respondent Lynn Trout resides in the Adams County Prison. However, it is hoped that he will be released on parole in the near future and will then be able to function as a parent in a more traditional sense. 5. Denied. Respondents herein believe that the interests of Eric Lynn Trout will be best served as set forth in the original petition filed with your Honorable Court on May 10, 1985, the terms of which are incorporated herein by reference. 6. Denied. Respondents herein intend to strictly comply with any order of Court relating to custody of EriC Lynn Trout and no enforcement orders will be required as to them. They hope that none will be required as to Wendy K. Trout, petitioner herein. 7. Respondents have no knowledge as to Petitioners intended living arrangements. WHEREFORE, Respondents to the above mentioned petition request that the relief requested therein be refused and that the relief requested in Respondents' original custody complaint be granted. We verify that the statements contained herein are true and correct. We understand that false statements are made subject to penalties under 18 Pa. C.S. §4904 relating to unsworn falsi- fication to authorities. Linden E. Trout M~ry C. ~rout and attested copy taken from ~and compared with the original Attest: ~ Prothonotary LYNN E. TROUT, LINDEN E. : IN THE COURT OF COMMON PLEAS OF AND MARY C. TROUT, : ADAMS COUNTY, PENNSYLVANIA Plaintiffs : : CIVIL ACTION - LAW vs. : NO. 85-S-375 : WENDY K. TROUT, : Defendant : CUSTODY ORDER OF COURT AND NOW, this ~- day of August, 1985, upon consideration of the within Petition and upon Motion of Wayne F. Shade, Esquire, Attorney for Defendant, a Rule is issued upon Plaintiffs to Show Cause why the following relief should not be granted: (a) transfer of venue of this case to the Court of Common Pleas of Cumberland County, Pennsylvania; and (b) suspension of tile partial custody provisions under pending Order of this Court, dated January 10, 1985, at No. 85-S-6 pending furth~Order of Court in this case. Rule returnable within [' days of date of service thereof. By the Court, ~,:id ...... ~d copy taken from and co:~:pared with the original Attornoy at Law $ ~ou~ H~over ~trmet LYNN E. TROUT, LINDEN E. : IN Tt~ COURT OF COMMON PLEAS OF AND MARY C. TROUT, : ADAMS COUNTY, PENNSYLVANIA Plaintiffs : : CIVIL ACTION - LAW vs. : NO. 85-S-375 : WENDY K. TROUT, : Defendant : CUSTODY PETITION OF DEFENDANT FOR TRANSFER OF VENUE PURSUANT"~O PA. R.C.P. 1915.2(d) TO THE HONORABLE, THE JUDGE OF SAID COURT: The Petition of Defendant WENDY K. TROUT, by her Attorney, Wayne F. Shade, Esquire, respectfully represents, as follows: 1. Petitioner WENDY K. TROUT is an adult individual, the Defendant herein and the natural mother of Eric Lynn Trout, the child who is the subject of these proceedings and who was born on November 17, 1983. 2. Respondents LYNN E. TROUT, LINDEN E. TROUT and MARY C. TROUT are adult individuals and Plaintiffs herein who reside at 115 White Oak Tree Road, York Springs, Adams County, Pennsylvania. 3. With the exception of the period from June 15, 1985, through July 30, 1985, when Plaintiff LYNN E. TROUT unlawfully retained custody of the subject child in violation of the partial custody provisions of the Order of your Honorable Court of January 10, 1985, docketed to No. 85-S-6, the child who is the subject of these proceedings has lived primarily with Defendant in Cumberland WA~E~.S~*~ County since December of 1984, a period of approximately eight Attorney at ~w $ Sou~ H~er S~eet .rltsle, Pennsylvania 17013 months as acknowledged by Plaintif~in Paragraph 7(c) of their Complaint herein. 4. In view of the incarceration of Plaintiff LYNN E. TROUT in the Adams County Prison for indirect criminal contempt as a result of his violation of the aforesaid Order of January 10, 1985, it is anticipated that the subject child w~ll continue to reside indefinitely with his mother in Cumberland County, Pennsylvania. 5. Petitioner believes and therefore avers that the evidence in this case will indicate that the best interests and general welfare of the subject child will require confirmation of primary custody in Petitioner as the natural mother. 6. Petitioner believes and therefore avers that the conduct of Plaintiffs will be Such that frequent supervision of any future orders will be necessary and that resort to the Court of Common Pleas of Adams County by the natural mother will be unduly burden- some and expensive when the child is residing in Cumberland County Pennsylvania. 7. Petitioner intends to continue to reside permanently in Cumberland County, Pennsylvania. WHEREFORE, Petitioner respectfully prays that your Honorable Court issue a Rule upon Plaintiffs to Show Cause why the following relief should not be granted: W~ F. Attorney at Law $ Sou~ H~over Street - 2 - rllsle, Pennsylvania 17013 (a) transfer of venue of this case to the Court of Common Pleas of Cumberland County, Pennsylvania; and · (b) suspension'of the partial custody provisions under the Order of this Court, dated January 10, 1985, at No. 85-S- pending further Order of Court in this case. I verify that the statements made in this Petition ara true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating tc unsworn falsification to authorities. Date: August 16, 1985 Wendy YK. Trout Wayn~F. Shade Attorney for Defendant aud attested copy taken from a-.~i ~:o:~y2ared with the original Prothonotary WAY~z F. SHA~ Attorney at Law South Hanover Street - ~ - :Hsle, Pennsylvania I~015 LYNN E. TROUT, LINDEN E. : IN THE COURT OF COMMON PLEAS : ADAMS COUNTY, PENNSYLVANIA AND MARY C. TROUT, : Plaintiffs : CIVIL ACTION - LAW : v. : No. 85-S-375 : WENDY K. TROUT, : CUSTODY Defendant RULE TO SHOW CAUSE AND NOW, this 29thday of August , 1985, upon consideration of the foregoing Petition and on Motion of L. Rex Biekley, Esquire, a Rule is directed to Lynn E. Trout, Linden E. and Mary C. Trout, to show cause why counsel for the Plaintiff should not be permitted to withdraw. RULE RETURNABLE October 11, 1985 at 9:00 a.m. · BY THE COURT: ~nd at~=~ed copy taken from ........... r~d with the original '. ~test: Prothonotary LYNN E. TROUT, LINDEN E. : IN THE COURT OF COMMON PLEAS AND MARY C. TROUT, : ADAMS COUNTY, PENNSYLVANIA Plaintiffs : : CIVIL ACTION - LAW V. : : No. 85-S-375 WENDY K. TROUT, : Defendant : CUSTODY PETITION TO WITHDRAW AS COUNSEL The Petition of L. Rex Bickley, Esquire, respectfully represents: 1. That he is still technically counsel of record for the above-referenced Plaintiffs with respect to a Petition for Custody filed in May of 1985. 2. Your Petitioner has not seen Plaintiff Lynn E. Trout in months. 3. Plaintiff Lynn E. Trout has repeatedly refused to follow the advice and counsel of your Petitioner. WHEREFORE, the Petitioner respectfully requests that he be permitted to Withdraw as Counsel for the Plaintiffs with respect to the above-captioned matter. Respectfully submitted, ~a~c. ~ ld_~. This being a true ~ / and attested copy taken from L~' and co:.~oared with the original Rex Bickle~, ~squi re ~ Attorney fo~/~Plaint i f f s Attest: BESHORE & BICKLEY ~~ ~~ - P.O. 210 Walnut Box 142 Street  Prothonotary Harrisburg, PA 17108 (717) 234-3873 Dated: Office of the PROTHONOTARY of Adams County PARKER D. LEREW ~'~ ESTHER G. WEAVER WAYNEFirst Depu~ K. SHIELDS ~~ ~~ ;,~ ~,~.~, ~.. Second ~ Ge~sburg, Pa. 17325 TO: ATTORNEYS PRACTICING BEFORE THE COURT OF COMMON PLEAS OF ADAMS C0UNTY, PENNSYLVANIA. FROM: PROTHONOTARY'S OFFICE RE: Lynn E. Trout~ T. tnd~n ~. an~ No. 85-~-375 -- Mary C. Trout. VS. Wendy K. Trout, Action in C,,~,n~y Please make service of the Rule and file an Affidavit of Service with this office. Deputy Prothonotary Dated: August 30, 1985 LAW OFFICES BESHORE & BICKLEY ~ ' ?": 210 WALNUT STREET P.O. BO~- 14~ .... .... HARRISBURG, PENNSYLVANIA 17108 (717) 234-3873 LYNN E. TROUT, LINDEN E. : IN THE COURT OF COMMON PLEAS and MARY C. TROUT, : ADAMS COUNTY, PENNSYLVANIA Plaintiffs : CIVIL ACTION - LAW V. : : No. 85-S~75 WENDY K. TROUT, : Defendant : Custody and Visitation PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY OF ADAMS COUNTY: Kindly discontinue the conference scheduled in the above- captioned matter. Respectfully submitted, L. Rex Bickley, Esquire Attorney for Plaintiffs BESHORE & BICKLEY 210 Walnut Street P.O. Box 142 Harrisburg, PA 17108 (717) 234-3873 Dated: June 26, 1985 ~'~ 19 ~(~. This being a true ,-'' and. attested copy taken from ~._ ~ ~- ,' ~ . - with the original Prothonotary LYNN E. TROUT, LINDEN E. : IN THE COURT OF COMMON PLEAS AND MARY C. TROUT, : ADAMS COUNTY, PENNSYLVANIA Plaintiffs : : CIVIL ACTION - LAW VS. : No. WENDY K. TROUT, : Defendant : Custody and Visitation ORDER OF COURT AND NOW, this 31stday of May , 1985, upon consideration of the within Motion the hearing scheduled in the above matter for June 6, 1985 at 8:30 a.m. is continued until June 28, 1985 at 8:30 a.m. BY THE COURT, / ~At_.~ 19~_~_. This being a true and attested copy taken from a~.d o~-pared with the original i- ~ - C '~'~ LYNN E. TROUT, LINDEN E. : IN THE COURT OF COMMON PLEAS AND MARY C. TROUT, : ADAMS COUNTY, PENNSYLVANIA Plaintiffs : : CIVIL ACTION - LAW VS. : : No. WENDY K. TROUT, : Defendant : Custody and Visitation MOTION FOR CONTINUENCE TO THE HONORABLE, THE JUDGE OF SAID COURT: AND NOW, come the Plaintiffs, Lynn E. Trout, and Linden E. and Mary C. Trout, by their attorney, L. Rex Bickley, Esquire, and respectfully request that the hearing in the above matter scheduled for June 6, 1985 at 8:30 a.m. be continued until Friday June 28, 1985 at 8:30 a.m. Wayne F. Shade, Esquire, attorney for Defendant, Wendy K. Trout, does not oppose this Motion. Beshore & Bickley by: L. Rex Biekl~e'9 Attorney fo? Plaintiffs ~_,~C]___ .~9Z~'. This being a true o, n3. ~tbested copy taken from ~::d co',L?~red with the original At tr':~ '..: and attested copy taken from and co:~pared with the original Attest: ~ Prothonotary LYNN E. TROUT, LINDEN E. : IN THE COURT OF COMMON PLEAS AND MARY C. TROUT, : ADAMS COUNTY, PENNSYLVANIA Plaintiffs : : CIVIL ACTION - LAW V. .' WENDY K. TROUT, : Defendant : Custody and Visitation ORDER OF COURT You, Wendy K. Trout, Defendant, have been sued in Court to obtian custody and visitation of the child: Eric Lynn Trout. You are Ordered to appear in person at Room #4tl o£ the Adams County Courthouse on June 6 , 1985, at 8;30 A.M., for a conference. You are further Ordered to bring with you the child: Eric Lynn Trout. If you fail to appear as provided by this Order or to bring this child, an order for custody, partial custody, or visitation may be entered against you or the Court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER AT ONCE. IF YOU DO NOT HAVE A ~,,~,,~ER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH W TO FIND OUT WHERE YOU CAN GET LEGAL HELP. . ~ _~ ~ Adams County Court Administrator ~i!~C,~ ~-- Adams County Courthouse ~!i~- ~q Gettysburg, Pennsylvania ~'-° ~ (717) 334-6781 BY THE COURT: Date: May 10, ~85 ~// J' ? LYNN E. TROUT, LINDEN E. : IN THE COURT OF COMMON PLEAS AND MARY C. TROUT, : ADAMS COUNTY, PENNSYLVANZA Plaintiffs : : CIVIL ACTION - LAW WENDY K. TROUT, : Defendant : Custody and Visitation (X]f41PLAINT FOR CUSTODYAND VISITATION TO THE HONORABLE, THE JUDGE OF SAID COURT: AND NOW, come the Plaintiffs, Lynn E. Trout, and Linden E. and Mary C. Trout, by their attorney, L. Rex Bickley, Esquire, and respectfully represents that: 1. Plaintiff Lynn E. Trout, is an adult individual presently residing at 115 White Oak Tree Road, York Springs, Adams County, Pennsylvania. 2. Plaintiffs Linden E. and Mary C. Trout, are husband and wife, mother and father of Plaintiff Lynn E. Trout, and paternal grandparents of the minor child who is the subject of this Complaint and whose residence is R.D. 5, Box 144, Dillsburg, Pennsyvlania, 17019. 3. Defendant Wendy K. Trout is an adult individual presently residing at R.D. 3, Newville, Cumberland County, Pennsylvania. 4. Plaintiff Lynn E. Trout and Defendant Wendy K. Trout are husband and wife and were married on January 19, 1983. 5. Plaintiff and Defendant are the natural parents of one (1) child, namely, Eric Lynn Trout, born November 17, 1983. 6. The child was not born out of wedlock. 7. Since birth the child has lived at the following addres- ses: (a) From November 17, 1983, the date on which the child was born, until some time in October of 1984, the child resided with the Plaintiff and Defendant at the following address: 83 Buttonwood Drive, Dillsburg, Pennsylvania 17019. (b) From sometime in October of 1984 until sometime in the end of December of 1984, the child resided with the Plaintiff and Defendant at the follow- ing address: 115 White Oak Tree Road, York Springs, Adams County, Pennsylvania. (c) Since the end of December, 1984, the child has lived primarily with the Defendant at the home of the Defendant's parents: R.D. 3, Newville, Cumberland County, Pennsylvania. 8. On January 10, 1985, this Honorable Court entered an Order with respect to Plaintiff, Lynn Trout, pursuant to Protection from Abuse Petition, a copy of which Order is attached. Aside from that Order, Plaintiffs have not participated as parties or witnesses, or in another capacity, in other litigation concerning the custody of the child in this or another Court. 9. Plaintiffs have no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. 10. Plaintiffs know of no person not a party to the proceeding who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 11. The best interests and permanent welfare of the child will be served by granting the relief requested because the natural father has established a loving and supportive relationship with his child and the child's development over the long term will be promoted by the custodial support, care and love of the natural father. Additionally, the paternal grandparents have established a loving, supportive relationship with the child which will be of lasting value and benefit to the child. WHEREFORE, the natural father requests that he be granted custody of the minor child, Erie L. Trout, and additionally, ~ Plaintiffs Linden E. and Mary C. Trout, the paternal grandparents, respectfully request that they be granted the right of regular visitation with their grandson. 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.C.S. §4904 relating to unsworn falsification to authorities. Lynn E. Trout 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.C.S. §4904 relating to unsworn _f_.alsifieation to authorities. · -'~' 19~_. ~his being a true and attested copy taken from Attest: _ ~ ~/ Linden E.~ Trout  ~o~hono tary 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.C.S. §4904 relating to unsworn falsification to authorities. Marry C. 0~rout Respectfully submitted, L. Rex Bickley, ES'~uire Attorney for Plaintiffs BESHORE & BICKLEY 210 Walnut Street P.O. Box 142 Harrisburg, PA 17108 (717) 234-3873 Date: May 10, 1985 CO1V~VIONWEALTH OF PENNSYLVANIA : : SS: COUNTY OF YORK : VERIFICATION Before me, a Notary Public, in and for the said County and Commonwealth, personally appeared, Lynn E. Trout, Linden E. Trout, and Mary C. Trout, who, being duly sworn according to law, depose and say that the facts set forth in the foregoing "Complaint" are true and correct to the best of their knowledge, information and belief. Linden E. Trout Mar?y C. /rout SWORN TO AND SUBSCRIBED before me this /~ day of '-~. , 1985. Notary Publie d/ WANDA W. 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OL 6 ~ 8 ~no~ ~pu~ ~o~ ~au~o~q~ L _'£ 'uqn~ -Q(~£ 9 ~H~OD ~H~ ~8 ~ ~q ~nb~ p~s ~q ii~Hs ~p~o s~q~ ~o s~so~ ~ ~ LYNN E. TROUT, · IN THE COURT OF COMMON PLEAS OF Plaintiff · CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW V. " : NO. 70 CIVIL TERM 1987 WENDY K. BOYD, a.k.a : WENDY K. TROUT, : Defendant : IN DIVORCE ORDER OF COURT AND NOW, this [VJ day of ~'~x " 2000, Plaintiff LYNN E. TROUT and Defendant WENDY K. BOYD, being represented by their independently selected private counsel, respectively, Melissa Peel Greevy, Esquire, and Wayne F. Shade, Esquire, and having stipulated and agreed with regard to custody of their minor child, Eric L. Trout, born November 17;' 1983, it is hereby ordered and decreed, as follows: 1. Shared legal custody of said child as contemplated by 23 Pa.C.S. §5302 will be in both of the parties hereto as the natural parents. 2. Primary physical custody of said child shall be in Lynn E. Trout subject to reasonable rights of partial physical custody in Wendy K. Boyd as the parties hereto may from time to time agree. WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 By the Court, J. Melissa Peel Greevy, Esquire ]~ ~,.~ Attorney for Plaintiff Wayne F. Shade, Esquire Attorney for Defendant WAYNE F. SHADE Attorney at Law 53 West Pomffet Street Carlisle, Pennsylvania 17013 LYNN E. TROUT, . IN THE COURT OF COMMON PLEAS OF Plaintiff · ~UMBERLAND COUNTY, PENNSYLVANIA · CIVIL ACTION - LAW V. · NO. 70 CIVIL TERM 1987 WENDY K. BOYD, a.k.a ' WENDY K. TROUT, ' Defendant · IN DIVORCE STIPULATION FOR CHILD CUSTODY AND NOW, this day of ,2000, come Plaintiff LYNN E. TROUT and Defendant WENDY K. BOYD, by and through their respective attorneys, Melissa Peel Greevy, Esquire, and Wayne F. Shade, Esquire, and with regard to custody of their minor child, Eric L. Trout, born November 17, 1983, stipulate and agree, as follows: 1. Shared legal custody of said child as contemplated by 23 Pa.C.S. §5302 will be in both of the parties hereto as the natural parents. 2. Primary physical custody of said child shall be in Lynn E. Trout subject to reasonable rights of partial physical custody in Wendy K. Boyd as the parties hereto may from time to time agree. WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 Defendant does not agree to transfer of primary physical custody of the child to Plaintiff. She simply knowingly, voluntarily and intelligently acquiesces in that transfer on the basis of her considered view that it would be futile to attempt to oppose the transfer due to the age of the child. There is no admission of the allegations of the Petition for Modification of a Custody Order. 5. It is the desire and intention of the parties hereto that this Stipulation for Child Custody be entered in the Court of Common Pleas of Cumberland County, Pennsylvania, and that it be endorsed as an Order of Court so as to have the full effect thereof. [I Melissa'-l~;eel (~reevy, Esquire ., W~yne t(. Shade, Esquire Attorney for Plaintiff Attorney for Defendant WAYNE F. SHAD~ Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 I verify that the statements made .in the foregoing Stipulation are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities. Date: I verify that the statements made in the foregoing Stipulation 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. WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 LYNN E. TROUT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 87-70 CIVIL TERM : : CIVIL ACTION - LAW WENDY K. BOYD, : Defendant : IN CUSTODY AND NC~, this 9th day of May, 2000, the Conciliator, being advised by Plaintiff's counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction in this case. The Custody Conciliation Conference scheduled for May 17, 2000 is canceled. FOR THE COURT~ Dawn S. Sunday, Esquire Custody Conciliator