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HomeMy WebLinkAbout02-1395CHERYL L. VAUGHN, Plaintiff EDWARD L. VAUGHN, JR., Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : :NO. .' : CIVIL ACTION - LAW : CHILD CUSTODY COMPLAINT FOR CHILD CUSTODY AND NOW comes the Plaintiff, Cheryl L. Vaughn, by and through her attorneys, the Law Offices of Silliker and Reinhold, by Kristin R. Reinhold, Esquire, and respectfully requests this Honorable Court award her custody of the subject minor children, and in support thereto, avers the following: 1. Plaintiff is Cheryl L. Vaughn, an adult individual residing at 317 Market Street, New Cumberland, Cumberland County, Pennsylvania. 17070. 2. Defendant is Edward L. Vaughn, Jr., an adult individual residing at 508 Lewisberry Road, New Cumberland, York County, Pennsylvania. 17070. 3. The subject children are Edward Luther Vaughn, III, born July 19, 1991, and Raven Samantha Vaughn, bom December 24, 1994. 4. The relationship of the Plaintiff to the subject minor children is that of natural mother. 5. The relationship of the Defendant to the subject minor children is that of natural father. custody of the 6. The minor children have resided at the following addresses, in the following individuals: A. From 1996 to April 5,2001, the subject minor children resided with the Plaintiff and Defendant at 508 Lewisberry Road, New Cumberland, York County, Pennsylvania 17070. B. From April 5, 2001 to present, the subject minor children resided with Plaintiff at 317 Market Street, New Cumberland, Cumberland County, Pennsylvania 17070. 7. There have been no prior actions for custody of the subject minor children in this or any other jurisdiction. 8. The Plaintiffis not aware of the existence of any other individuals who have any type of claim whatsoever regarding the custody of the subject minor children. 9. The Plaintiff believes and therefore avers that she is much better able to meet the needs of the subject minor children than the Defendant. 10. The Plaintiff believes and therefore avers that it is in the best interest of the subject minor children that they be placed in her legal and physical custody. WHEREFORE, Plaintiff requests this Honorable Court award her custody of the subject minor children. Respectfully submitted, ~ Reinhold, Esqfiire 5922 Lit [estown Road Harrisburg, PA 17112 (717) 671-1500 I.D. No. 57911 Attorney for Plaintiff AFFIDAVIT and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. 4909 relating to unswom falsifications to authorities. Dated: / ¢ /¢/tT,-A~ gOO ~ :' & '/y / CHERYL L. VAUGHN PLAINTIFF V. EDWARD L. VAUGHN, JR. DEFENDANT 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-1395 CIVIL ACTION LAW IN CUSTODY AND NOW,. Tuesday, April 02, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Tuesday, April 23, 2002 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in disput~ or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Melissa P. Greevy, Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 MAY 2 0 2002. CHERYL L. VAUGHN, Plaintiff V, EDWARD L. VAUGHN, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1395 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this ~ day of May, 2002, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Cheryl L. Vaughn and Edward L. Vaughn, Jr., shall have shared legal custody of the minor children, Edward Luther Vaughn, III, born July 19, 1991 and Raven Samantha Vaughn, born December 24, 1994. 2. Physical Custody. Mother shall have primary physical custody subject to Father's rights of partial physical custody which shall be arranged as follows: A. To commence May 18, 2002 on alternate weekends from Saturday at noon until Sunday at 2:00 p.m. B. To commence May 26, 2002 on alternate weekends from Sunday at 2:00 p.m. until the children are returned to school on Monday if it is a school day. In the event that it is not a school day, Father's custodial time will end at 8:00 p.m. on Monday. C. Each Thursday from 3:00 p.m. until 7:30 p.m. If Father's work schedule permits, he may pick up the children at an earlier time for his Thursday visits. D. At such other times as the parties may agree. 3. Father shall be responsible for supervising the homework that the children may have during his periods of custody on school nights. 4. Vacation. Each party shall be entitled to two (2) non-consecutive weeks of custody for the purposes of vacation. A vacation shall run from Saturday to Saturday. The vacation schedule supersedes the regular schedule. Father shall have vacation from August 10 through 17, 2002. For future years, the parties shall provide each other notice of their chosen weeks by April 1st of each year. In the event that conflicting vacation times NO. 02-1395 CIVIL TERM have been scheduled, the party first providing written notice to the other parent shall be entitled to choice of vacation time. 5. Transportation. Mother shall participate in transportation by picking the children up at Father's home on Thursday evenings. Father shall provide all other transportation incident to his periods of custody. 6. The parties shall keep each other informed of any changes in address, work, cellular or residential telephOne numbers. 7. Holidays. The parties shall alternate the following holiday schedule effective with Father having Memorial Day 2002: New Year's Eve, New Year's Day, Easter, Memorial Day, Independence Day, Labor Day and Thanksgiving. 8. Christmas. Unless otherwise agreed, Christmas custody shall be arranged on an NB schedule delineated below: Segment A shall be from December 24th at 2:00 p.m. until December 25th at 2:00 p.m. Segment B shall be from December 25th at 2:00 p.m. to December 26th at 2:00 p.m. In even numbered years, Father shall have Segment A and Mother shall have Segment B. In odd numbered years, Mother shall have Segment A and Father shall have Segment B. 9. Neither party shall do or say anything which may estrange the children from the other parent, injure the opinion of the children as to the other parent, or hamper the free and natural development of the children's love and respect for the other parent. Each parent shall ensure that third parties also comply with this provision during his or her periods of custody. 10. In the event that there continue to be problems with the children being on time for school when they have been in Father's custody the preceding Sunday evening, counsel for Mother may request to reconvene the Custody Conciliation Conference by letter to the Conciliator. The Conference will then reconvene to consider whether Father shall continue to have the opportunity to exercise custody overnight on Sundays or whether his Sunday custody shall end by 8:00 p.m. NO. 02-1395 CIVIL TERM 11. This Order is temporary in nature. The parties may vary its terms by their mutual agreement. However, in the event that the parties cannot agree, the terms of this Order shall control pending further Order of Court. Dist: BY TH~ /Kristin R. Reinhold, Esquire, 5922 Linglestown Road, Harrisburg, PA 17112 ~ ~ ' /Timothy J. Colgan, Esquire, One S. Baltimore Street, Dillsburg, PA 17019 ~5_c~ ~ MAY 2 0 2002 CHERYL L. VAUGHN, Plaintiff V. EDWARD L. VAUGHN, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1395 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Edward Luther Vaughn, III Raven Samantha Vaughn July 19, 1991 Mother December 24, 1994 Mother 2. A Custody Conciliation Conference was held on May 14, 2002 pursuant to Mother's Complaint for Custody filed on March 21, 2002. Present for the conference were the Mother, Cheryl L. Vaugh, and her counsel, Kristin R. Rienhold, Esquire; the Father, Edward L. Vaughn, Jr., and his counsel, Timothy J. Colgan, Esquire. 3. The parties reached an agreement in--der as attached. ~,~'e Greevy, Esq-~ire ~1~lissa Peel Custody Conciliator :158379