HomeMy WebLinkAbout02-1533
vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No.Gd--1533 Civil Term
CUSTODY
METFORD K. JACKSON,
Plaintiff
CYNTHIA C. NASH,
Defendant
COMPLAINT FOR CUSTODY
1. Plaintiff is Metford K. Jackson, who currently resides at 218 N. 18th St., Camp
Hill, Cumberland County, Pennsylvania, 17011.
2. Defendant is Cynthia C. Nash, who currently resides in Harrisburg, Dauphin
County, Pennsylvania) LA,.(\ d. wo,..f:;.s cd- \/er:. 'Co "', I (J.f, rJ. Dv t-e. 5+,
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3. Plaintiff seeks full custody of the following children:
NAME
Kayla Jackson
ADDRESS
218 N. 18th St.
Camp Hill, Pa. 17011
oo.a
11/17/96
The child was born out of wedlock.
The child is in the custody of: Father, Metford K. Jackson.
During the past five years, the child has resided with the following persons and at
the following addresses:
NAME
ADDRESSES
DATES
Metford Jackson and
Cynthia Nash
205 Johnston Ave.
Plainfield, New Jersey
Birth - Sept. 1999
Metford Jackson and
Cynthia Nash
218 N. 18th St.
Camp Hill, Pa. 17011
Sept. 1999 - present.
The mother of the child is: Cynthia C. Nash, currently residing in Harrisburg,
(specific address unknown).
She is married to Russell Nash.
The father of the child is: Metford Jackson, currently residing at 218 N. 18th St.,
Camp Hill, Pa. 17011.
He is married to Juana Jackson.
4. The relationship of plaintiff to the children is that of FATHER. The plaintiff
currently resides with Kayla Jackson.
5. The relationship of defendant to the children is that of MOTHER. It is
believed that the defendant currently resides with a paramour, B. Hill.
6. Plaintiff has participated as a party in other litigation concerning the custody
of the child in New Jersey. A custody Order was entered in New Jersey based upon the
parties agreement in November 1998. (See Exhibit A).
Plaintiff has no information of a custody proceeding concerning the children
pending in a court of this Commonwealth.
Plaintiff does not know of a party to the proceedings who has physical
custody of the children or claims to have custody or visitation rights with respect to the
children.
"
7. The best interest and permanent welfare of the child will be served by
granting primary custody to Father because: Father is in a better position to provide a
stable home and care for the child. Mother left the home without informing Father of
her whereabouts. and has a history of drug and alcohol abuse.
8. Each parent whose parental rights to the child have not been terminated and
the person who has physical custody of the child have been named as parties to this
action.
WHEREFORE, Plaintiff requests the court to grant custody of the child.
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. 94904 relating to unsworn falsification to authorities.
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Date: tf - / .. Od-.
J ne A ,squire
I . No. 79465
17 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
MAR-25-2002 04'14 PM MAIL_ROOM
717 975 9'3'33
P.02
NON.DISSOLunON OUBR roll 'J'Ir.U1ItnRARY CUSTODY AND VISIT A TfON
SVPIRlOR COIJRT or NEW JII.RSBY . CHANCDY DIVISION- FAMILY PART, \JN1ON COVNTY
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ORDER OF: .)4. CVSTODY [ ] VISITATION .
M t. The followiq parties have been properly notirled by mail subpoena of the Hearlna in the within
matter:
Notice4 Appeared
[ ] b4 Natural Mother
[ ] kJ Natural father
[ ] [ ] Ma1emal Orand
[ ] [ ] PatenW Orand
,J'tl \ f\'f""
k'<3 2. Court finds tbat 1empOmyfcustOdy of:
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Noticed Appeared
[ ] [ J Relative
[ 1 [ ] -D.Y,F.S.
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is hereby awarded to: M ~r;k...r.>... ..... C. AliA. sh
baaed upon: [] Best Interests fmding
( ] Testimony of
,pel Consent of pames
[ ] Recommendation of: [..J DYFS ( ) PO Report [ } Other:
( ] 3. SUpervillld Visitation .
Pi 4. Visitation awarded to fA.e.t"~r ~ :r;" O{...so~ u follows:
Day(s)lHoun: A-tt~.t'r'...-t4 lo._l~_~ v.>Ifl,. ~ ~ l..6~ "~Cfr.
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[ ) S. Third partY visitation: Party:
Place:
[ 'I 6. ProbationlConsortiumlDYFS to conduct investigation RE: ( ] CUSlody
[ ) Other
l ] 7, Beneficiary of supPOrt under docket: is hereby clwIged to:
( ) 8, Other conditions:
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PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
METFORD K. JACKSON
v.
02-1533 CIVIL ACTION LAW
CYNTHIA C. NASH
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Tuesday, April 09, 2002
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumherland County Conrthouse, Carlisle on Friday, May 03, 2002 at 1:30 PM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to tbe conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: Isl
Tacqueline M. VernlO" Esq(y^
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 TOYOURATIORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATIORNEY 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
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MAY 0 7 20U2 Y
METFORD K. JACKSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 2002-1533 CIVIL TERM
CYNTHIA C. NASH,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this ~ day of fYl"" , 2002, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. The Father, Metford K. Jackson, and the Mother, Cynthia C. Nash, shall
have shared legal custody of Kayla Jackson, born November 17, 1996. Each parent shall
have an equal right, to be exercised jointly with the other parent, to make all major non-
emergency decisions affecting the Child's general well-being including, but not limited
to, all decisions regarding her health, education and religion.
2. Father shall have primary physical custody of the child.
3. Mother shall have the following periods of partial physical custody:
A. Beginning the weekend of May 10, 2002, alternating weekends from
Fridays at 8:00 p.m. to Sundays at 3:00 p.m.
4. Mother shall have physical custody of the Child on Mother's Day, Father
shall have physical custody of the Child on Father's Day, both at times agreed by the
parties.
5. The Christmas holiday share be divided into two Blocks. Block A shall be
from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block B shall be
from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have
Block A in even numbered years and Block B in odd numbered years. Father shall have
Block A in odd numbered years and Block B in even numbered years.
6. Thanksgiving Day shall be shared by the parties. Mother shall have
physical custody ofthe Child from 8:00 a.m. to 3:00 p.m. Father shall have physical
custody of the Child beginning at 3:00 p.m.
7. Easter shall be shared by the parties. Mother shall have physical custody
of the Child from 8:00 a.m. to 1:00 p.m. Father shall have physical custody ofthe Child
beginning at 1 :00 p.m.
"
8. The parties shall alternate the following holidays: Memorial Day, July 4th,
and Labor Day. Mother shall have physical custody of the Child on Memorial Day,
2002. When any of the holidays fall on Monday immediately following Mother's
weekend, Mother shall have physical custody of the Child on Sunday night into Monday,
returning the Child to Father at 3:00 p.m.
9. Neither party shall consume alcoholic beverages to the point of
intoxication or use illegal drugs while in the presence of the Child, nor permit any third
party to be in the Child's presence while intoxicated or under the influence of illegal
drugs.
10. Neither party shall remove the child from the jurisdiction without prior
notification to the non-custodial party of the address, location and telephone number
where the Child will be.
11.
other party.
Both parties shall provide a current telephone number and address to the
12.
the Child.
Transportation shall be shared such that the receiving party shall transport
13.
8:00 p.m.
The parties are entitled to liberal telephone contact with the child prior to
14. Neither party shall do anything, nor permit any third party from doing
anything that may estrange the Child from the other party, or injure the opinion of the
Child as to the other party, or may hamper the free and natural development of the
Child's love or affection for the other party.
15. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of' r shall control.
J.
cc: Jane Adams, Esquire, Counsel for Father
Cynthia C. Nash
1705 N. Second Street
Harrisburg, PA 17102
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METFORD K. JACKSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: 2002-1533 CIVIL TERM
CYNTHIA C. NASH,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
PRIOR JUDGE: None
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH CURRENTLY IN CUSTODY OF
Kayla Jackson
November 17, 1996 Father
2. A Conciliation Conference was held in this matter on May 3, 2002, with
the following individuals in attendance: The Father, Metford K. Jackson, with his
counsel, Jane Adams, Esquire and the Mother, Cynthia C. Nash, pro se.
3. The parties agreed to entry of an Order in the form as attached.
;) - {; -0 ~
Date
METFORD K. JACKSON, : IN THE COURT OF COMMON PLEAS OF
PLAINTIFF/PETITIONER : CUMBERLAND COUNTY,
: PENNSYL VANIA
vs. : NO.2002-1533 CIVIL TERM
CYNTHIA C. NASH, : CIVIL ACTION - LAW
DEFENDANT/RESPONDENT : IN CUSTODY
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this complaint and notice are
served, by entering a written appearance personally or by attomey and filing in writing with the
court your defenses or objections to the claims set forth against you. You are warned that if you
fail to do so the case may proceed without you and a judgment may be entered against you by the
court without further notice for any money claimed in the complaint or for any other claim or
relief requested by the Plaintiff/Petitioner. You may lose money or property or other rights
important to you.
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.
Cumberland County Bar Association
32 South Bedford Street
Carlisle P A 17013
(717) 249-3166
1-800-990-9108
METFORD K. JACKSON,
PLAINTIFFIPETITIONER
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
VS.
: NO.2002-1533 CIVll, TERM
CYNTHIA C. NASH, : CIVll, ACTION - LAW
DEFENDANTIRESPONDENT : IN CUSTODY
PETITION FOR MODIFICATION OF CUSTODY ORDER
AND NOW, comes thePlaintitTIPetitioner, METFORD K. JACKSON, by and through
his counsel, Susan Kay Candiello, Esquire, of the Law Firm of Susan Kay Candiello, P.C, and
files this Petition for Modification of Custody Order upon a cause of action of which the
following is a statement:
L PlaintitTIPetitioner is METFORD K JACKSON, an.adult individual, who
currently resides at 218 South 18th Street, Camp Hill, Cumberland County, Pennsylvania, 1701 L
2. Defendant/Respondent is CYNTHIA C. NASH, an adult individual, who
currently resides at c/o Bruce Hill, 1705 North 2nd Street, Harrisburg, Dauphin County,
Pennsylvania, 17102.
3. PlaintitTIPetitioner seeks Full Legal Custody and Primary Physical Custody of the
following child:
Name Present Residence
Date of Birth
KA YLA MONIQUE JACKSON 218 South 18th Street
Camp Hill, P A
November 17, 1996
4. The child was born out of wedlock
5. The child is presently in the Primary Physical custody ofPlaintitTlPetitioner who
resides at 218 South 18th Street, Camp Hill, Cumberland County, Pennsylvania, 17011.
6. During the-past four (4) years, the child has resided with the following persons at
the following addresses:
Name(s)
Address
Dates
PlaintifflPetitioner and
DefendantlRespondent
(Two different apartments in September 1999 to
same complex) 108 Mayfair Drive November 2001
and 3526 September Drive
Camp Hill, P A
PlaintifflPetitioner and
DefendantlRespondent
218 South 18th Street
Camp Hill P A
November, 2001 to
February 14, 2002
PlaintifflPetitioner
218 South 18th Street
Camp Hill P A
February 14, 2002 to
Present
7. The mother of the child is the DefendantlRespondent who currently resides at c/o
Bruce Hill, 1705 North 2nd Street, Harrisburg, Dauphin County., Pennsylvania, 17102.
8. PlaintifflPetitioner has resided alone with his daughter, Kayla Monique Jackson,
since February 14, 2002.
9. The father of the child is the PlaintifflPetitioner who resides alone with the child.
10. The mother of the child is the DefendantlRespondent who resides with Bruce Hill.
11. The relationship ofPlaintifflPetitioner to the child is that of natural father.
12. The relationship ofDefendantlRespondent to the child is that of natural mother.
DefendantlRespondent currently resides with the following persons:
Name
RelatioDshio
Bruce Hill
Paramour
13. PlaintifflPetitioner has participated as a party in a prior custody agreement
concerning the custody of the child in this court. The court, tenn and number, and its
relationship to this action are as follows: the court was Cumberland County, the docket number
F. The child is currently being seen by a counselor, Dennis Graybill, with
Guidance Associates in Camp Hill, Pennsylvania, because of the
statements and treatment to the child by the Defendant/Respondent;
G. The child consistently states she does not want to be with her mother
as a result of the above stated reasons.
17. Each party whose parental rights to the child have not been terminated and
the person who has physical custody of the child have been named as parties to this
action.
WHEREFORE, Plaintiff/Petitioner, METFORD K. JACKSON, requests this
Honorable Court to grant him FULL LEGAL and PRIMARY PHYSICAL CUSTODY and
Defendant/Respondent, CYNTHIA C. NASH, PARTIAL PHYSICAL CUSTODY of the
minor child, KA YLA MONIQUE JACKSON.
Respectfully submitted,
LAW FIRM OF SUSAN KAY CANDIELLO, P.C.
Dated: AugusatL 2003
Susan Kay Ceo uire
Counsel for Pi< inti 'Petitioner
PAI.D. #6499
5021 East Trindle Road
Suite 100
Mechanicsburg P A 17050
(717) 796-1930
VERIFICATION
The undersigned hereby verifies that the facts averred in the foregoing document are true
and correct to the best of his knowledge, information, and belief This verification is made
subject to the penalties of 18 Pa. C.SA ~4904 relating to unsworn falsification to authorities.
DATED: / S'OCJ o.!
~ 1-.r1_. J. K..(L.e.~ - ...J
~CiQSON
EXHIBIT "A"
'/
MAY 0 7 2oU2 j)
METFORD K. JACKSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 2002-1533 CHilL TERM
CYNTHIA C. NASH,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this ~_ day of (fI.lIfr ,2002, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
I. The Father, Metford K. Jackson, and the Mother, Cynthia C.Nash, shall
have shared legal custody ofKayla Jackson, born November 17, 1996. Each parent shall
have an equal right, to be exercised jointly with the other parent, to make all major non-
emergency decisions affecting the Child's general well-being including, but not limited
to, all decisions regarding her health, education and religion.
2. Father shall have primary physical custody of the child.
. 3. Mothet shall have the following periods of partial physical custody:
A. Beginning the weekend of May 10, 2002, alternating weekends from
Fridays at 8:00 p.m. to Sundays at 3:00 p.m.
4. Mother shall have physical cllstody of the Child on Mother's Day, Father
shall have physical custody of the Child on Father's Day, both at times agreed by the
parties.
5. The Christmas holiday share be divided into two Blocks. Block A shall be
from Christmas Eve at 12tOO noon to Christmas Day at 12:00 noon. Block B shall be
from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have
Block A in even numbered years and Block B in odd number-:d years. Father shall have
Block A in odd numbered years and Block B in even numbered years.
6, Thanksgiving Day shall be shared by the parties. Mother shall have
physical custody of the Child from 8:00 a.m. to 3:00 p.m. Father shall have physical
custody of the Child beginning at 3:00 p.m.
7. Easter shall be shared by the parties. Mother shall have physical custody
of the Child from 8:00 a.m. to 1:00 p,m. Father shall have physical custody of the Child
beginning at I :00 p.m.
8. The parties shall alternate the following holidays: Memorial Day, July 4th,
and Labor Day, Mother shall have physical custody of the Child on Memorial Day,
2002. When any of the holidays fall on Monday immediately following Mother's
weekend, Mother shall have physical custody of the Child on Sunday night into Monday,
returning the Child to Father at 3 :00 p.m.
9. Neither party shall consume alcoholic beverages to the point of
intoxication or use illegal drugs while in the presence of the Child, nor permit any third
party to be in the Child's presence while intoxicated or under the' influence of illegal
drugs.
10. Neither party shall remove the child from the jurisdiction without prior
notification to the non-custodial party of the address, locaticm and telephone number
where the Child will be.
11.
other party.
Both parties shall provide a current telephone number and address to the
12.
the Child.
Transportation shall be shared such that the receiving party shall transport
13.
8:00 p,m.
The parties are entitled to liberal telephone contact with the child prior to
14. Neither party shall do anything, nor permit any third party from doing
anything that may estrange the Child from the other party, or injure the opinion of the
Child as to the other party, or may hamper the free and natural development of the
Child's love or affection for the other party.
15. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms oft . r shall control.
J,
cc: Jane Adams, Esquire, Counsel for Father
Cynthia C, Nash
1705 N. Second Street
Harrisburg, PA 17102
TRUE COpy FROM RECOFi[~
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METFORD K. JACKSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
V.
: 2002-1533 CIVIL TERM
CYNTHIA C. NASH,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
PRIOR JUDGE: None
CUSTODY CONCILIATION SUMMARY. REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIl,
PROCEDURE 1915.3-8, the undersigned Custody Condliator submits the following
report:
1. The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH CURRENTLY IN CUSTODY OF
Kayla Jackson
November 17,1996 Father
2. A Conciliation Conference was held in this matter on May 3, 2002, with
the following individuals in attendance: The Father, Metford K. Jackson, with his
counsel, Jane Adams, Esquire and the Mother, Cynthia C. Nash, pro se.
,
.).
The parties agreed to entry of an Order in the fonn as attached.
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Date
9h,
cqu ine M. Verney, Esquire.
Custody Conciliator
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METFORD K. JACKSON
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
02-1533 CIVIL ACTION LAW
CYN1HIA C. NASH
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Thursday, August 28, 2003
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, September 25, 2003 at 8:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will bt: made to resolve the issues in dispute; or
if this cannot be accomplished, to defme and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT.
By: Isl
Jacqueline M. Verntry. Esq.
Custody Conciliator
c,
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 lELEPHONE TIlE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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METFORD K. JACKSON,
PLAlNTIFFIPETITIONER
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
VS.
: NO.2002-1533 CIVIL TERM
CYNTHIA C. NASH, : CIVIL ACTION - LAW
DEFENDANTIRESPONDENT : IN CUSTODY
AFFIDAVIT OF SERVICE CERTIFIED MAIL
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
Be it known, that on the J I+~ day of ~~i\. , 2003, before me, the
subscriber, a Notary Public, personally appeared SUSAN KAY CANDIELLO, who, being duly
sworn according to law, did depose and state as follows:
L I am an attorney licensed to practice law in the Commonwealth of Pennsylvania.
2. I represent Metford K. Jackson, Plaintiff/Petitioner in the above-captioned matter.
3. On September 2,2003, a true and correct copy of the Petition for Modification of
Custody Order was deposited for delivery with the US. Postal Service in Mechanicsburg,
Pennsylvania, being Certified/First Class Mail, restricted delivery, return receipt requested,
Article No. 7001 2510000344398966, and addressed to the Defendant/Respondent, Cynthia C.
Nash, at 1705 North 2nd Street, Harrisburg, PA 17102.
4. The return receipt card signed by the Defendant/Respondent, Cynthia Nash,
showing a date of service of September 6,2003, is attached hereto as Exhibit "A".
5. Service by certified mail meets the requirements ofPaRC.P. 404(2) and
PaRC.P. 403.
SWORN TO AND SUBSCRIBED before me, a Notary Public, this ~ day of
~--n-1'N\.~ ,2003.
J!~ \'l"\\h~Lt 1 ~ K, 1~~y.J
Notary Public
My Commission Expires:~ 4) cYOOS
Notarial Seal
Kimberty R Hanford, Notary Public
Mechanlcsbulll Bora. Cumbertand County
My Commission Expires Apr. 4, 2005
EXHIBIT "A"
. Complete ~ems 1, 2, and 3. Also complete
Item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mail piece,
or on the front If space permits.
C~~~Z~C~ fIXl6"
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RESTRICTED
DELIVERY
D. Is delivery ack:l1'8SS different from Item 1?
if YES. enter delivery address below:
3. SelVice Type
'5t"Certifled Mail [J Express Mall
UAegistered Cl Return Receipt for Merchan_
Cllnsured Mall Cl C.O.D.
4. RestI1cled DoIvery? (I:JlIra Fee) jl(yOl
7001 2510 0003 4439 8966
2. Article Number
(Tmnsfer from service label)
PS Fonn 3811, August 2001
DomestIc Return Receipt
2ACPRI..(lS.p..4(J81
METFORD K. JACKSON, : IN THE COURT OF COMMON PLEAS OF
PLAINTIFFIPETITIONER : CUMBERLAND COUNTY,
: PENNSYLVANIA
vs. : NO.2002-1533 CIVIL TERM
CYNTHIA C. NASH, : CIVIL ACTION - LAW
DEFENDANTIRESPONDENT : IN CUSTODY
AFFIDAVIT OF SERVICE CERTIFIED MAIL
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
Be it known, that on the Irf<\. day of /00 (*n~;") ,2003, before me, the
subscriber, a Notary Public, personally appeared SUSAN KAY CANDIELLO, who, being duly
sworn according to law, did depose and state as follows:
L I am an attorney licensed to practice law in the Commonwealth of Pennsylvania.
2. I represent Metford K. Jackson, Plaintiff/Petitioner in the above-captioned matter.
3. On September 11, 2003, a true and correct copy iDfthe September 11, 2003 letter
to Jacqueline M. Verney, Esquire, was deposited for delivery with the US. Postal Service in
Mechanicsburg, Pennsylvania, being Certified/First Class Mail, restricted delivery, return receipt
requested, Article No. 7001 2510000344398942, and addressed to the Defendant/Respondent,
Cynthia C. Nash, at 1705 North 2nd Street, Harrisburg, PA 17102.
4. The return receipt card signed by the Defendant/Respondent, C Nash, showing a
date of service of September 13, 2003, is attached hereto as Exhibit "A".
5. Service by certified mail meets the requirements ofPaRCP. 404(2) and
PaRC.P.403.
SWORN TO AND SUBSCRIBED before me, a Notary Public, this I ')~ day of
~~\~ ,2003.
~\.~\~5\k 6 ~. \~~\.Q
Notary Public
My Commission Expires: ~ L{ I ctDS;
~ Notarial Seal
MecI1Klm~,r' Hanford, Notary Public
... rg Boro, Cumberland County
My Commission Expires Apr. 4, 2005
EXHIBIT "A"
. Complete items 1, 2, and 3. Also complete
ttem 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can retum the card to you.
. Attach this card to the back of the mailpiece,
or on the front If space permits.
1. Article Addressed to: L
c.~~~l.o. C. f00..51\
\'105 t0~~ ;J'Q ~;tfEei
po.\\\~bll.C~ m If)ID~
RESTRICTED
DELIVERY
~s~e
B. Received by (!"rinted Nome)
O. Is delivery addl'ess different from Item 11
If YES. enter delivery address below:
3. Service Type
~ertifled Miilil CJ Express Mail
Cl Registered Cl Retum Receipt for Merchandlee
Cllnsured Meil Cl C.O.D.
4. _DeIImy?(ExlnlFee) Xy..
7001 2510 0003 4439 8942
2. Article Number
rr_trom__)
PS Form 3811, August 2001
2ACPR1-o3-P.....
DomeetIc Return Receipt
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OCT~003
METFORD K. JACKSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 2002-1533 CIVIL TERM
CYNTHIA C. NASH,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this (}11" day of ~ ,2003, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. The prior Order of Court dated May 7, 2002 shall remain in full force and
effect except that Mother's partial physical custody is susp,:nded pending the
investigation of Dauphin County Children & Youth.
2. In the event that the investigation of Dauphin County Children and Youth
is unfounded, the prior Order shall automatically be reinstated and Mother shall receive
substitute time for any missed physical custody periods.
3. This Order is entered pursuant to the agreement of the parties at a Custody
Conciliation Conference. The parties may modify the terms of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control. Either
party may contact the conciliator to schedule another co .. tion conference.
Edward E. Guido,
J.
ccv8'usan Kay Candiello, Esquire, for Father
vt"ynthia C. Nash, pro se
1705 North 2nd Street
Harrisburg, P A 17102
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V.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: 2002-1533 CIVIL TERM
METFORD K. JACKSON,
Plaintiff
CYNTHIA C. NASH,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
PRIOR JUDGE: Edward E. Guido, J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH CURRENTLY IN CUSTODY OF
Kayla Monique Jackson
November 17, 1996 Father
2. A Conciliation Conference was held in this matter on October 17, 2003.
The Father, Metford K. Jackson, appeared with his counsel, Susan K. Candiello, Esquire.
Mother, Cynthia C. Nash, pro se.
3. A prior Order of Court dated May 7, 2002 was entered by the Honorable
Edward E. Guido granting shared legal custody, Father having primary physical custody
and Mother having partial physical custody on alternating weekends and holidays.
4. Father indicated that the Child advised school authorities that she was
struck in the arm by Mother. Father's understanding is that Dauphin County Children
and Youth is investigating the matter.
5. Pending the investigation of Dauphin County Children & Youth, the
parties agree~ to the entry of the Order in the/form as attaChed.. I /
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Date ! Jac line M. Verney, Esquire
v Custody Conciliator
MAR ~ 2004
METFORD K. JACKSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
V.
: CIVIL ACTION - LAW
CYNTHIA C. NASH,
Defendant
: NO. 2002-1533 CIVIL TERM
: IN CUSTODY
ORDER OF COURT
AND NOW, this ~31A day of f'/I ~ , 2004, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. A Hearing is sched~ed in Court Room No. S" , of the Cumberland
County Court House, on the 17 day of ('III "'J" ' 2004, at "i:()~
o'clock, A.. . M., at which time testimony will be taKen. For purposes of this Hearing,
the Father shall be deemed to be the moving party and shall proceed initially with
testimony. Counsel for each party shall file with the Court and opposing counsel a
Memorandum setting forth each party's position on custody, a list of witnesses who will
be expected to testify at the Hearing and a summary of the anticipated testimony of each
witness. These Memoranda shall be filed at least ten days prior to the Hearing date.
2. Pending further Order of Court or agreement of the parties, the May 7,
2002 and October 21, 2003 Orders of Court shall remain in full force and effect with the
following modification:
3. Mother may participate in the child's counseling. Both parties shall sign
releases so that the counselor may exchange information concerning the child with both
parents.
4. The parties may modify this Order by mutual agreement. In the absence
of mutual consent, the terms of this Order shall control.
Edward E. Guido,
J.
cc;;Susan Kay Candiello, Esquire, counsel for Father ~ '0)
/Cynthia C. Nash, pro se -V -v d...
1705 North 2na Street O' ~ J
Harrisburg, PA 17102 -%
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MAR 1 8 2004
METFORD K. JACKSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: CIVIL ACTION - LAW
CYNTHIA C. NASH,
Defendant
: NO. 2002-1533 CIVIL TERM
: IN CUSTODY
PRIOR JUDGE: EDWARD E. GUIDO, J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Kayla Monique Jackson November 17, 1996 Father
2. A Conciliation Conference was held March 17,2004 with the following
individuals in attendance: The Father, Metford K. Jackson, with his counsel, Susan Kay
Candiello, Esquire, and the Mother, Cynthia C. Nash, pro se.
3. The Court previously entered Orders of Court on May 7, 2002, and
October 21,2003 providing for shared legal custody, with Father having primary physical
custody and Mother having alternating weekends.
4. Father's position on custody is as follows: Father seeks full legal custody
and primary physical custody, with Mother having no overnights. Father is concerned
with the sleeping arrangements for his daughter, claiming that daughter must sleep in the
same room with her Mother and her boyfriend. Father is also concerned about fights
between Mother and boyfriend in the child's presence. Father agrees that Mother should
be involved with the child's counselor. Father maintains that Mother received all make
up time she was entitled to under the October 21, 2003 Order of Court.
5. Mother's position on custody is as follows: Mother seeks shared legal
custody and partial physical custody, but wants more time than the current Order
providing for alternating weekends. Mother wishes to be involved with the child's
counselor. Mother maintains that Father does not communicate with her on legal custody
issues such as selection of a counselor or school matters. Mother asserts that she is
entitled to one more weekend pursuant to the October 21, 2003 Order of Court.
6. The Conciliator recommends an Order in the form as attached scheduling
a Hearing and continuing the Order of May 7, 2002. It is expected that the Hearing will
require one day.
3 -;2 3 -01
Date
/0.t{
cqu ne M. Verney, Esquire
ustody Conciliator
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METFORD K. JACKSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
02-1533 CIVIL
CYNTHIA C. NASH,
Defendant
IN CUSTODY
ORDER
AND NOW, this
I~
day of April, 2004, hearing in the above captioned matter
set for May 17,2004, is continued to Monday, May 24, 2004, at 10:00 a.m. in Courtroom
Number 5, Cumberland County Couriliouse, Carlisle, PA.
Edward E. Guido, J.
Susan Kay Candiello, Esquire
For the Plaintiff
Cynthia C. Nash, Pro Se
1705 North 2nd Street
Harrisburg, PA 17102
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METFORD K. JACKSON,
Plaintiff
IN THE COURT OF COMMON PLEAS\
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 2002-1533 Civil Term
CYNTHIA C. NASH,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this / ytIa day of ~__, 2004, upon request of
the Attorney for the Defendant, Cynthia C. Nash, and without objection by the
attorney for the Plaintiff, Medford K. Jackson, it is hereby Ordered that the
HomJ "h,duled ~ Mund,y, M,y 24, 2004, i, continued to ~ th,
JJ day of J.luAlZ ,2004, at}: I)() 1.m. in Courtroom #5 of
the Cumberland County Courthouse, Carlisle, Pennsylvania, at which time all
parties shall appear.
Distribution:
v6iane M. Dils, Esquire, 1017 North Front Street, Han-isburg, PA 17102
~usan Kay Candiello, Esquire, 5021 East Trindle Road, Suite 100, Mechanicsburg,
PAI7050
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ATTORNEYS AT LAW
ARTHUR K. OILS
DIANE M. OILS
1017 NORTH FRONT STREET
HARRISBURG, PENNSYLVANIA 1710:1
PHONE: (717) 233-8743
FAX: (717) 233.2567
May 14,2004
The Honorable Edward E. Guido
Cumberland County Courthouse
One Courthouse Square
Carlisle, P A 17013
RE: Metford K. Jackson vs. Cynthia C. Nash
Docket No. 2002-1533 Civil Term (Custody)
Dear Judge Guido:
Cynthia C. Nash has requested that I represent her in connection with a Hearing
scheduled before your Honorable Court in the above matter for Monday, May 24,
2004, at 10:00 a.m. Attorney Susan Kay Candiello represents the Plaintiff,
Metford K. Jackson.
I am unavailable to attend the scheduled Hearing in the above matter due to a
commitment in the Court of Common Pleas of York County to commence at Trial
during their Custody Trial Term between May 24" 2004, and June 4, 2004.
Attorney Candiello has indicated that she does not oppose my request to continue
the above-captioned matter.
Enclosed is a proposed Order. It is respectfully requested that the above-captioned
custody matter be rescheduled to another date and time.
Thank you for your assistance in this matter.
~very t~IY ~ourS'();6', \ .
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cc: Susan Kay Candiello, Esquire
METFORD K. JACKSON,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2002-1533 CIVIL TERM
CYNTHIA C. NASH,
DEFENDANT
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 21st day of June, 2004, after
hearing, our order of May 7, 2002, shall be modified to add the
following provisions:
16. The parties shall take immediate steps to arrange
for co-parent counseling with Mr. Graybill through Guidance
Associates. To the extent that the counseling is not covered by
insurance, the parties shall share the costs.
17. Mother shall contact Mr. Graybill immediately to
begin counseling with her daughter.
18. Mother and Father shall e-mail each other on a
daily basis regarding their child. We suggest that they share
something positive that occurred in the life of the child. [It
is also important that they share any bad news regarding the life
of the child, and we suggest e-mail is the most neutral way of
doing it. It also gives them a record so that we can review it
in the future.] The party who has physical custody of the
child shall institute the e-mail. This procedure shall be
followed for at least 60 days. Copies of the e-mails are to be
saved and filed with this Court as an exhibit to this hearing.
We will then refer to the e-mails in any future proceedings
before us.
In all other respects, our order of May 7, 2002,
shall remain in full force and effect.
By the Court,
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Susan Kay Candiello, Esquire
For the Plaintiff
Diane M. Dils, Esquire
For the Defendant
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v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
METFORD K. JACKSON,
Plaintiff
CYNTHIA C. NASH,
Defendant
IN CUSTODY
NO. 2002-1533 CIVIL TERM
PETITION FOR EMERGENCY RELIEF
AND NOW, comes Plaintiff, Metford K. Jackson, filing the within Petition for
Emergency Relief, and avers as follows:
1. The Plaintiff is Metford K. Jackson (hereinafter referred to as
"Father"), residing at 218 S. 18th Street, Camp Hill, Cumberland County, Pennsylvania.
2. The Defendant is Cynthia C. Nash (hereinafter referred to as
"Mother"), residing at 1583 Trindle Road, Mechanicsburg, Cumberland County,
Pennsylvania.
3. The parties are the parents of one minor daughter, Kayla Jackson,
born November 17,1996.
4. Two Custody Orders have been entered with regard to this matter,
Le., on May 7, 2002 and on June 21, 2004 (copies attached hereto).
5. Under the terms of the Court Order dated May 7, 2002, Mother has
partial custody of the parties' child on alternating weekends.
6. Kayla has witnessed numerous physical altercations in the past
between Mother and her boyfriend.
7. During Mother's partial custodial period with the child on or about
June 10, 2006, the child witnessed an altercation between Mother and her boyfriend
during which Mother hit her boyfriend in the face and drew blood.
8. Pursuant to the Court Order dated June 21, 2004, Father has
continued to have Kayla counsel with Mr. Dennis Graybill of Guidance Associates.
9. Because Kayla was upset by the June 10, 2006 altercation between
Mother and her boyfriend, Father had Kayla meet with Mr. Graybill.
10. Dennis Graybill, the child's counselor, has indicated that because of
the impact of this most recent altercation on Kayla, Mother's periods of partial custody
should be suspended until he can address the situation with the parties and Kayla in
counseling.
WHEREFORE, Father respectfully requests that Mother's periods of partial
custody be suspended until Dennis Graybill can address the impact of Mother's behavior
on Kayla and advise the parties of an appropriate arrangement for Mother's contact with
Kayla.
~~411-A~
Sandra L. Meilton, Esquire
TUCKER ARENSBERG, P.C.
111 North Front Street
P.O. Box 889
Harrisburg, PA 17108-0889
(717) 234-4121
ATTORNEYS FOR PLAINTIFF
VERIFICATION
I, the undersigned, Metford K. Jackson, acknowledge that the facts stated in
the foregoing document are true and correct to the best of my knowledge, information and
belief.
I understand that any false statements herein are made subject to the
penalties of 18 Pa. C.SA Section 4904 relating to unsworn falsification to authorities.
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Dated:
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METFORD K. JACKSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2002-1533 CIVIL TERM
CYNTHIA C. NASH,
DEFENDANT
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 21st day of June, 2004, after
hearing, our order of May 7, 2002, shall be modified to add the
following provisions:
16. The parties shall take immediate steps to arrange
for co-parent counseling with Mr. Graybill through Guidance
Associates. To the extent that the courtselirtg is not covered by
insurance, t.he'parties' shall share the C"osts.
17. Mother shall contact Mr. Graybill immediately to
begin counseling with her daughter.
18. Mother and Father shall e-mail each other on a
daily basis regarding their child. We suggest that they share
something positive that occurred in the life of the child. [It
is also important that they share any bad news regarding the life
of the child, and we suggest e-mail is the most neutral way of
doing it. It also gives them a record so that we can review it
in the future.] The party who has physical custody of the
child shall institute the e-mail. This procedure shall be
followed for at least 60 days. Copies of the e~mails are to be
saved and filed with this Court as an exhibit to this hearing.
We will then refer to the e-mails in any future proceedings
before us.
In all other respects, our order of May 7, 2002,
shall remain in full force and effect.
By the Court,
E. Guido, J.
,~san Kay Candiello, Esquire
/hor the Plaintiff
Diane M. Dils, Esquire
For the Defendant
srs
rRVE COpy FROM RECORD
In Tutimooy whereof, i here unto set my hand
and the seal 0( said ~ at Carlisle, Pi.
This 2.2' ~y ~ /Mo'f
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ProthonotalV
METFORD K. JACKSON,
Plaintiff
. MAY 0 7 2DUe j)
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
.~-"
V.
: NO. 2002-1533 CIVIL TERM
CYNTHIA C. NASH,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this ~_ day of (YI.~ ,2002, upon
consideration of the attache.d Custody Conciliation Report: 'it is ordered and directed as
follows:
1. The Father, Metford K. Jackson, and the Mother, Cynthia C.Nash, shall
have shared legal custody of Kayla Jackson, born November 17, 1996. Each parent shall
have an equal right, to be exercised jointly with the other parent, to make all major non-
emergency decisions affecting the Child's general well-being including, but not limited
to, all decisions regarding her health, education and religion.
2.. Father shall have primary physical custody of the child.
. 3. Mother shall have the folloWing periods of partial physical custody:
A. Beginning the weekend of May 10, 2002, alternating weekends from
Fridays at 8:00 p.m. to Sundays at 3:00 p.m.
4. Mother shall have physical custody of the Child on Mother's Day, Father
shall have physical custody of the Child on Father's Day, both at times agreed by the
parties.
5. The Christmas holiday share be divided into two Blocks. Block A shall be
from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block B shall be
from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have
Block A in even numbered years and Block B in odd numbered years. Father shall have
Block A in odd numbered years and Block B in even numbered years.
6. Thanksgiving Day shall be shared by the parties. Mother shall have
physical custody of the Child from 8:00 a.m. to 3:00 p.m. Father shall have physical
custody of the Child beginning at3:00 p.m.
7. Easter shall be shared by the parties. Mother shall' have physical custody
ofthe Child from 8:00 a.m. to 1 :00 p.m. Father shall have physical custody of the Child
beginning at 1 :00 p.m.
'..'
8. The parties shall alternate the following holidays: Memorial Day, July 4th,
and Labor Day. Mother shall have physical custody of the Child on Memorial Day,
2002. When any of the holidays fall on Monday immediately following Mother's
weekend, Mother shall have physical custody of the Child on Sunday night into Monday,
returning the Child to Father at 3:00 p.m.
9. Neither party shall consume alcoholic beverages to the point of
intoxication or use illegal drugs while in the presence of the Child, nor permit any third
party to be in the Child's presence while intoxicated or under the influence of illegal
drugs.
10. Neither party shall remove the child from the jurisdiction without prior
notification to the non-custodial party of the address, location and telephone number
where the Child will be.
I I. Both parties shall provide a current telephone number and address to the
other party.
12. Transportation shall be shared such that the receiving party shall transport
the Child.
13. The parties are entitled to liberal telephone contact with the child prior to
8:00 p.m.
14. Neither party shall do anything, nor permit any third party from doing
anything that may estrange the Child from the other party, or injure the opinion of the
Child as to the other party, or may hamper the free and natural development of the
Child's love or affection for the other party.
15. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of t . r shall control.
J.
cc: Jane Adams, Esquire, Counsel for Father
Cynthia C. Nash
1705 N. Second Street
Harrisburg, PA 17102
TRUE COpy FROM RECORD
In T \ilsW'l'o:my wt!sr~(lf, I !111i\J lln~a s"t \Ii;! !lland
and the Sfh'~ Of ~a~:~ Cewi 2t .CarHu~~, Pa.
This ~~. aay c; ::J~ .g~
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~, Prothonotary
CERTIFICATE OF SERVICE
AND NOW, this ~J' ~y of June, 2006, I, Gloria M. Rine, Paralegal
to Sandra L. Meilton, Esquire, for the firm of Tucker Arensberg, P.C., hereby certify that
I have this day served a copy of the within document, by first class mail, addressed as
follows:
Diane M. Dils. Esquire
1400 N. Second Street, First Floor, Front
Harrisburg, PA 17102
Gloria M. Rine
87919,1
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METFO D K. JACKSON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
CYNTH A C. NASH,
Defendant
IN CUSTODY
NO. 2002-1533 CIVIL TERM
PETITION FOR CONTEMPT AND MODIFICATION
AND NOW COMES, the Plaintiff, Metford K. Jackson, and files the within
Petitio
1 . The Plaintiff is Metford K. Jackson (hereinafter referred to as
"Fathe "), residing at 218 S. 18th Street, Camp Hill, Cumberland County, Pennsylvania.
2. The Defendant is Cynthia C. Nash (hereinafter referred to as
"Moth r"), residing at 1583 Trindle Road, Mechanicsburg, Cumberland County,
Penn Ivania.
3. The parties are the parents of one minor daughter, Kayla Jackson,
born ovember 17,1996.
4. Two Custody Orders have been entered with regard to this matter,
Le.,o May 7,2002 and on June 21,2004 (copies attached hereto).
5. The Court Order dated June 21, 2004 sets forth Mother's
require ent to implement counseling with Mr. Graybill of Guidance Associates.
6. Mother only attended two or three counseling sessions with Mr.
Graybil. She would schedule a new appointment and then cancel the appointment.
7. Mother has refused to attend counseling indicating to Mr. Graybill
that sh is not getting anything from the sessions and that they were not doing her any
good.
8. Mother's behavior toward Kayla has been inappropriate and Mother
has b coming increasingly more aggressive toward Kayla.
9. Kayla has begun to state that she does not want to visit with her
Moth .
10. Father believes that Mother abuses drugs and alcohol and that
beca se of her behavior, Kayla is not safe when she is in her Mother's custody.
WHEREFORE, Plaintiff prays this Honorable Court:
(a) To hold Mother in contempt of the June, 2004 Order.
(b) To order drug and alcohol evaluation including hair follicle analysis;
and
(c) To order only supervised visits until the evaluation is completed.
Respectfully submitted,
~~;i~
Sandra L. Meilton, Esqui ,I. D. No. 32551
TUCKER ARENSBERG, P.C.
111 North Front Street, P.O. Box 889
Harrisburg, PA 17108-0889
(717) 234-4121
ATTORNEYS FOR PLAINTIFF
VERIFICATION
I, the undersigned, Metford K. Jackson, acknowledge that the facts stated
in the f regoing document are true and correct to the best of my knowledge, information
I understand that any false statements herein are made subject to the
penalti s of 18 Pa. C.SA Section 4904 relating to unsworn falsification to authorities.
~~ac~
Dated:
...
~
~
MET ORD K. JACKSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2002-1533 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
v.
CYN HIA C. NASH,
DEFENDANT
ORDER OF COURT
AND NOW, this 21st day of June, 2004, after
hea ing, our order of May 7, 2002, shall be modified to add the
fol owing provisions:
16. The parties shall take immediate steps to arrange
for co-parent counseling with Mr. Graybill through Guidance
ASs' ciat~s" To the extent that the counselirtg is not covered by
ins rance, t.he. parties: shall share the C"ost's.
17." Mother shall contact Mr. Graybill immediately to
beg'n counseling with her daughter.
18. Mother and Father shall e-mail each other on a
daily basis regarding their child. We suggest that they share
so ething positive that occurred in the life of the child. [It
is also important that they share any bad news regarding the life
of the child, and we suggest e-mail is the most neutral way of
do'ng it. It also gives them a record so that we can review it
~ in the future.] The party who has physical custody of the
:5 ch'ld shall institute the e-mail. This procedure shall be
fo lowed for at least 60 days. Copies of the e~mails are to be
sa ed and filed with this Cburt as an exhibit to this hearing.
We will then refer to the e-mails in any future proceedings
be ore us.
In all other respects, our order of May 7, 2002,
sh 11 remain in full force and effect.
By the Court,
E. Guido, J.
. ~ Kay Candiello. Esquire
Vfor the Plaintiff .
Dia e M. Dils, Esquire
For the Defendant
srs
rRVE copy FROM RECORD
In Tutlrnooy wilareof, I here unto set my hand
and the seal 0( said ~ at Carlisle, Pi.
Thi~ 2.1' ~y ~ J.do. 'f
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MAY 0 7 ZDUc j)
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2002-1533 CML TERM
M TFORD K. JACKSON,
Plaintiff
C THIA C. NASH,
Defendant
.: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this ~_ day of (YI.~ ,2002, upon
co sideration of the attache,d Custody Conciliation Report, it is ordered and directed as
fol ws:
1. The Father, Metford K. Jackson, and the Mother, Cynthia C.Nash, shall
ha e shared legal custody of Kayla Jackson, born November 17, 1996. Each parent shall
ha e an equal right, to be exercised jointly with the other parent, to make al1 major non-
em rgency decisions affecting the Child's general well-being including, but not limited
to, 11 decisions regarding her health, education and religion.
2.. Fathe, shall have primary physical custody of the child.
3. Mother shall have the following periods of partial physical custody:
A. Beginning the weekend of May 10, 2002, alternating weekends from
Fridays at 8:00 p.m. to Sundays at 3:00 p.m.
4. Mathe, shall have physical custody of the Child on Mother's Day, Father
sh 11 have physical custody of the Child on Father's Day, both at times agreed by the
pies.
5. The Christmas holiday share be divided into two Blocks. Block A shall be
Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block B shall be
Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have
BI ck A in even numbered years and Block B in odd numbered years. Father shall have
BI ck A in odd numbered years and Block B in even numbered years.
6. Thanksgiving Day shall be shared by the parties. Mother shall have
ph sicalcustody of the Child from 8:00 a.m. to 3:00 p.m. Father shall have physical
cu tody of the Child beginning at 3:00 p.m.
7. Easter shall be shared by the parties. Mother: shall have physical custody
of the Child from 8:00 a.m. to 1 :00 p.m. Father shall have physical custody of the Child
be inning at 1 :00 p.m.
"
8. The parties shall alternate the following holidays: Memorial Day, July 4th,
an Labor Day. Mother shall have physical custody of the Child on Memorial Day,
20 2. When any of the holidays fall on Monday immediately following Mother's
we kend, Mother shall have physical custody of the Child on Sunday night into Monday,
re ing the Child to Father at 3:00 p.m.
9. Neither party shall consume alcoholic beverages to the point of
int xication or use illegal drugs while in the presence of the Child, nor permit any third
pa to be in the Child's presence while intoxicated or under the influence of illegal
dru s.
10. Neither party shall remove the child from the jurisdiction without prior
not fication to the non-custodial party of the address, location and telephone number
wh re the Child will be.
11. Both parties shall provide a current telephone number and address to the
oth r party.
12. Transportation shall be shared such that the receiving party shall transport
the Child.
The parties are entitled to liberal telephone contact with the child prior to
14. Neither party shall do anything, nor permit any third party from doing
an ing that may estrange the Child from the other party, or injure the opinion of the
Ch 1d as to the other party, or may hamper the free and natural development of the
C 1d's love or affection for the other party.
15. This Order is entered pursuant to an agreement of the parties at a Custody
Co ciliation Conference. The parties may modify the provisions of this Order by mutual
co sent. In the absence of mutual consent, the terms of' r shall control.
J.
cc: Jane Adams, Esquire, Counsel for Father
Cynthia C. Nash
1705 N. Second Street
Harrisburg, P A 17102
TRUE Copy FROM RECORD
In TGstlr.>.tlny ~'!!$rc.:"f, i hem unt,o $,'1 myMnd
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~. Prothonotary
CERTIFICATE OF SERVICE
AND NOW, this ~ay of June, 2006, I, Gloria M. Rine, Paralegal to
Sandra L. Meilton, Esquire, for the firm of Tucker Arensberg, P.C., hereby certify that I
have th s day served a copy of the within document, by mailing same by first class mail,
postag prepaid, addressed as follows:
Diane M. Dils. Esquire
1400 N. Second Street, First Floor, Front
Harrisburg, PA 17102
d~ ;t;,L
Gloria M. Rine
87920,1
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN CUSTODY
NO. 2002-1533 CIVIL TERM
METFORD K. JACKSON,
Plaintiff
CYNTHIA C. NASH,
Defendant
ORDER OF COURT
AND NOW, this >,~ day of ~".. to... ~ 2~0~, upo~
consideration of the within Petition for Emergency Relief, " is IlS~ ;;~E6 Af46
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METFORD K. JACKSON
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
02-1533 CIVIL ACTION LAW
CYNTHIA C. NASH
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Wednesday, July 05, 2006
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator,
at "4th Floor, Cumb~rland County Courthouse, Carlisle on Tuesday, Au!!:ust 08, 2006 at 8:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court. and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinl!,
FOR THE COURT.
By: /s/
Tacqueline M. Verney, Esq. r
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 A TTORNEY AT ONCE. IF YOU DO NOT
HA VE AN A TTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (7 I 7) 249-3166
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METFORD K. JACKSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
CYNTHIA C. NASH,
Defendant
IN CUSTODY
NO. 2002-1533 CIVIL TERM
ORDER OF COURT
AND NOW, this 5th day of July, 2006, after
hearing, and it appearing to the Court that the Defendant was
aware of this hearing and chose not to attend, we enter the
hearing in this matter after conciliation:
in any way prejudice the rights of either party on a full
following Order that is meant to be temporary only and shall not
in our prior Order are suspended until further Order of Court.
1. Mother's periods of partial custody as set forth
2. Mother may have liberal telephone and e-mail
contact with the child.
visitation with the child at a place such as the YWCA,
3. If mother wishes, she may arrange for supervised
one hour per week upon notice to father.
Children's Playroom, et cetera. Said visitation may be up to
For the
-<(ynthia C. Nash
5138 East Trindle
Mechanicsburg, PA
Defendant, Pro se
. .)'.)Sheriff
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METFORD K. JACKSON
V.
CYNTHIA C. NASH
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2002 -1533 CIVIL TERM
ORDER OF COURT
AND NOW, this 31 ST day of JULY, 2006, the attached letter shall be treated as a
request for custody modification. The Court Administrator shall refer this matter to the
conciliator.
~dra L. Meilton, Esquire
111 North Front Street
P.O. Box 889
Harrisburg, Pa. 17108-0889
~etford K. Jackson
218 South 18TH Street
Camp Hill, Pa. 17011 -.l
4nthia C. Nash
1583 East Trindle Road
Mechanicsburg,Pa. 17050
Court Administrator
:sld
Edward E. Guido, J.
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July 10, 2006
TO: Judge Edward E. Guido
From: Cynthia C. Nash,
Defendant
In Custody No: 2002-1533
Civil Term
I am in receipt of your court order however, I am asking
for a new court date so my issues can be heard. I had
mechanical problems with the automobile I was driving & my
cell phone was at home the day the 1 st hearing was scheduled
July 5, 2006. By time I got home, I was told by your
stenographer the case was over. I don't understand why
Metford Jackson is seeking emergency relief when an argument
occurred in my home on June 3rd when I had my daughter &
she returned to my home on June 16th and everything was fine.
Metford Jackson also took my daughter to New Jersey to my
Mothers' house trying to stop me from seeing her my weekend
of June 30th.
In your court order it states, if Mother wishes, I may
arrange for supervised visitation with my daughter at a place
such as the YWCA. I am not a violent person and should not
have to see my daughter under supervised visitation. I
currently work from 12 noon until 8:30pm, Monday - Friday,
so that option is impossible.
Please give me the opportunity to explain my side of the
events that did or did not occur. I can not afford legal
representation so that is why lam sending this letter on my
own.
Sincerely yours,
C~~(]N~
Cynthia C. Nash
-.,:.': ........~
METFORD K. JACKSON
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
02-1533 CIVIL ACTION LAW
CYNTHIA C. NASH
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Friday, August 04, 2006
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator,
at 4th Floor, Cumherland County Courthouse, Carlisle on Tuesday, September OS, 2006 at 10:30 AM
for a Pre. Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing,
FOR THE COURT,
By: /s/
Tacqueline M. Vemey, 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
HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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METFORD K. JACKSON
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
CYNTHIA C. NASH
: NO. 2002 - 1533 CIVIL TERM
ORDER OF COURT
AND NOW, this 31 ST day of JUL Y, 2006, the attached letter shall be treated as a
request for custody modification. The Court Administrator shall refer this matter to the
conciliator.
(:~/ '
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Edward E. Guido, J.
Sandra 1. Meilton, Esquire
III North Front Street
P.O. Box 889
Harrisburg, Pa. 17108-0889
Metford K. Jackson
218 South 18TH Street
Camp Hill, Pa. 170 II
Cynthia C. Nash
1583 East Trindle Road
Mechanicsburg, Pa. 17050
~istrator
:sld
Curtis R. Long
Prothonotary
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
<l&ffice of tbe ~rotbonotarp
(/CumberIanl:J (/Count!,
Cynthia C. Nash
1583 East Trindle Rd.
Mechanicsburg, P A 17050
August 7, 2006
Dear Cynthia C. Nash;
This letter is in response the correspondence that you sent to Judge Guido.
Judge Guido referred this matter to Custody Conciliation.
The filing fee for this modification is $50.00 (cash or money order, made
payable to Cumberland County Prothonotary).
Sincerely,
Cumberland County Prothonotary Office
~~~,~
One Courthouse Square . Carlisle, Pennsylvania 17013 . (717) 240-6195 . Fax (717) 240-6573
__~------=O;:;;;;; --~ _,
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METFORD K. JACKSON
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
02-1533 CIVIL ACTION LAW
CYNTHIA C. NASH
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Friday, August 04, 2006
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq, , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, September 05, 2006 at 1 0:3l!._,~M
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT.
By: /s/
Jacqueline M. Verney, E;z:..-
Custody Conciliator
The Court of Common Pleas of rll.,,'\..~._l
with Disabilites Art "F 1 """
CURTIS R. LONG
Prothonotary
cumberland County
One courthouse Square
Carlisle, PA 17013
FILtL>. C)~;~- J~~E
OF THE PROTHONOTARY
2006 AUG /4 PM 3: 02
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cynthia C. .Nash d
1583 E. Tnndle ~A 17050
Mechanicsburg,
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METFORD K. JACKSON,
Plaintiff
SEP 2 5 2005
i J)I r "". i
: IN THE COURT OF COMMoN"PLEA'SUFJ
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 2002-1533 CIVIL ACTION - LAW
CYNTHIA NASH,
Defendant
: IN CUSTODY
ORDER OF COURT
ANDNOW,this ~daYOf ~ , 2006, upon
consideration of the attached Custody Concihat on Report, It is ordered and dIrected as
follows:
1. A Hearing is scheduled in Court Room No. ~, of the CJlfllb~r1and
County Court House, on the It/~day of JJ~ ,2006, at ~...,rf::4.M.
o'clock, _' M., at which time testimony will be taken. For purposes of this Hearing,
the Father shall be deemed to be the moving party and shall proceed initially with
testimony. Counsel for each party shall file with the Court and opposing counsel a
Memorandum setting forth each party's position on custody, a list of witnesses who will
be expected to testify at the Hearing and a summary of the anticipated testimony of each
witness. These Memoranda shall be filed at least ten days prior to the Hearing date.
2. Pending further Order of Court or agreement of the parties, the prior
Orders of Court dated May 7, 2002, June 21, 2004 and July 5, 2006 shall remain in full
force and effect with the following addition.
3. Mother shall contact Mr. Graybill at Guidance Associates to schedule
counseling. Therapeutic visits shall commence between Mother and child when Mr.
Graybill determines the child is ready for said visits.
4. The parties may modify this Order by mutual agreement. In the absence
of mutual consent, the terms of this Order shall conttol:--
//
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Edward E. Guido, J.
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METFORD K. JACKSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 2002-1533 CIVIL ACTION - LAW
CYNTHIA NASH,
Defendant
: IN CUSTODY
PRIOR JUDGE: Edward E. Guido, J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Kayla Jackson
November 17, 1996
Father
2. A Conciliation Conference was held September 22, 2006 with the
following individuals in attendance: The Father, Metford K. Jackson, with his counsel,
Sandra L. Meilton, Esquire, and the Mother, Cynthia Nash, pro se.
3. The Honorable Edward E. Guido previously entered Orders of Court dated
May 7, 2002, June 21,2004 and July 5,2006 providing for shared legal custody, Father
having primary physical custody and Mother having supervised visitation.
4. Father's position on custody is as follows: Father seeks shared legal and
primary physical custody, with Mother having supervised visitation. Father is willing to
allow therapeutic visits between Mother and Mr. Graybill, the child's counselor. Father
maintains that the Mother is in contempt of the Court Order requiring counseling with
Mr. Graybill. He asserts that the child is fearful of visiting with Mother. Father suspects
drug and alcohol abuse and asks the Court to order hair follicle testing. Father requests
Mother sign for a passport for the child.
5. Mother's position on custody is as follows: Mother seeks shared legal
custody and partial physical custody on alternating weekends. She objects to supervised
visitation which was ordered in the July 5, 2006 Order of Court. Mother has an
explanation for not participating in the special relief hearing. She denies drug and
~
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alcohol abuse and will not voluntarily submit to the hair follicle test. She objects to a
passport for the child as she fears Father will remove the child from the jurisdiction and
secret her from Mother. Mother indicates she will voluntarily resume counseling with
Mr. Graybill in order to see her child.
6. The Conciliator recommends an Order in the form as attached scheduling
a Hearing and continuing the prior Orders granting the parents shared legal custody,
Father primary physical custody and Mother supervised visitation. It is expected that the
Hearing will require one-half day.
Q - 2- L -0 ~
Date
Il\
lac eline M. Verney, Esquire
Custody Conciliator
~ ~
METFORD K. JACKSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2002-1533 CIVIL TERM
CYNTHIA NASH,
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this 14th day of November, 2006, after
hearing, we enter the following Order, which is intended to
replace our Temporary Order of July 5, 2006:
1. Mother's periods of partial custody as set forth
in our prior Court Orders are suspended and shall be replaced by
the following:
A. Mother may visit with the child this Sunday,
November 19, 2006, beginning at 4:45 p.m., at Hoss's near
Kayla's church. She may then accompany Kayla to church
services.
B. Every Sunday thereafter father shall have
Kayla at the church at 6:00 p.m. so that she may visit with
mother a half hour before church services and sit with mother
during church services.
C. Except in cases of emergency, either party
shall give the other at least 72 hours' notice bye-mail if the
Sunday visitation cannot be accomplished.
2. Mother shall have liberal telephone and e-mail
contact with the child.
3. Mother shall participate with the daughter in
family counseling through Mr. Graybill's office.
4. These periods of supervised visitation shall be
expanded upon the recommendation of Mr. Graybill as long as that
recommendation is put in writing.
. -
'.. ..
5. It is our hope that if progress is made between
mother and the child in counseling sessions with Mr. Graybill
that the parties will be able to work out a holiday schedule
where mother can spend time with the child over Christmas. If
the parties cannot work out the details of Christmas visitation,
we will schedule a brief hearing upon petition of either party.
6. We will review this matter at an evidentiary
hearing scheduled on Wednesday, January 17, 2007, at 1:00 p.m.
We will decide the issue of the passport at that
time.
The
is DISMISSED.
Edward E. Guido, J.
Sandra L. Meilton, Esquire
For the Plaintiff
Cynthia Nash
Defendant, Pro se
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Sandra L. MeHton, Esquire
Daley, Zucker & Gingrich, LLC
1029 Scenery Drive
Harrisburg, PAl 71 09
(717) 657-4795
smeilton@dzglaw.com
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
METFORD K. JACKSON,
Plaintiff/Petitioner
No. 2002-1533 CIVIL TERM
v.
CYNTHIA NASH,
Defendant/Respondent
(In Custody)
PETITION FOR EMERGENCY RELIEF
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AND NOW, this ~ day of November, 2006, comes Plaintiff/Petitioner, Metford K.
Jackson, by and through his attorneys~1 Daley, Zucker & Gingrich, LLC, and files the following
Petition for Emergency Relief and in support thereof avers as follows:
1. Plaintiff/Petitioner, Metford K. Jackson, an adult individual, who resides at 218
South 18th Street, Camp Hill, Cumberland County, Pennsylvania.
2. Defendant/Respondent, Cynthia Nash, an adult individual, who resides at 5138
East Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania.
3. The Parties are the natural parents of one minor child, Kayla Jackson, born on
November 17, 1996.
4. An Order was entered on November 14,2006, that ordered the Respondent to
have supervised visits with the child at: child's church. See Order dated November 14,2006
attached as Exhibit "A" and incorporated by reference.
5. Upon having said visits, Respondent has made several comments to people, who
belong to the church, which put the Petitioner in a "bad light" and are unnecessary.
6. The therapist, Mr. Graybill, who oversees the ordered family counseling between
Respondent and Kayla, upon speaking with Kayla and receiving a call from a Parishioner, has
contacted counsel for the Petitioner and informed counsel about the current situation and
recommends that the supervised visits occur at another location.
7. Mr. Graybill has offered the use of his office for the above-mentioned supervised
visits.
8. The current situation is making several members of the congregation
uncomfortable as well as putting Kayla in an adverse situation.
WHEREFORE, Petitioner asks the Honorable Court to enter an Order directing the
Respondent to initiate the above-mentioned supervised visits at the YWCA Visitation Center or
at Mr. Graybill's office.
Respectfully submitted,
DALEY, ZUCKER & GINGRICH, LLC
Date: 11- d-B- {).p
By: ~~r:.~
Supreme Court I.D. #32551
1029 Scenery Drive
Harrisburg, Pennsylvania 17109
(717) 657-4795
Attorney for Plaintiff/Petitioner
EXHIBIT "A"
/I ~ '2- "Z-tP Ct?
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2002-1533 CIVIL TERM
METFORD K. JACKSON,
Plaintiff
CYNTHIA NASH,
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this 14th day of November, 2006/ after
hearing, we enter the following Order, which is intended to
replace our Tesporary Order of July 5/ 2006:
1. Mother's periods of partial custody as set forth
in our prior Court Orders are suspended and shall be replaced by
the following:
A. Mother may visit with the child this Sunday,
November 19/ 2006/ beginning at 4:45 p.m., at Hoss's near
Kayla's church. She may then accompany Kayla to church
services.
B. Eve~y Sunday thereafter father shall have
Kayla at the church at 6:00 p.m. so that she may visit with
mother a half hour before church services and sit with mother
during church services.
C. Except in cases of emergency/. either party
shall give the other at least 72 hours' notice bye-mail if the
Sunday visitation cannot be accomplished.
2. Mother shall have liberal telephone and e-mail
contact with the child.
3. Mother shall participate with the daughter in
family counseling through Mr. Graybill's office.
4. These periods of supervised visitation shall be
expanded upon the recommendation of Mr. Graybill as long as that
recommendation is put in writing.
G
I
5. It is our hope that if progress is made between
mother and the child in counseling sessions with Mr. Graybill
that the parties will be able to work out a holiday schedule
where mother can spend time with the child over Christmas. If
the parties cannot wor'k out the details of Christmas visitation,
we will schedule a brief hearing upon petition of either party.
6. We will review this matter at an evidentiary
hearing scheduled on Wednesday, January 17, 2007, at 1:00 p.m.
We will decide the issue of the passport at that
time.
The
DISMISSED.
Court,
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Edward E. Guido, J.
~ra L. Meilton, Esquire
For the Plaintiff
Cynthia Nash
Defendant, Pro se
Sheriff
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alia_" whereof, I here unte set my IlIAd
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VERIFICATION
I, the undersigned, Metford K, Jackson, acknowledge that the facts stated in the foregoing
document are true and correct to the bf:st of my knowledge, information and belief.
I understand that any false statf~ments herein are made subject to the penalties of 18 Pa.
C.S.A. Section 4904 relating to unsworn falsification to authorities.
Date: I J 'dfj - 0(,
. ...'>1~ K~
Metford K. ackson
CERTIFICATE OF SERVICE
I, Sandra L. Meilton, Esquire, hereby certify that on this ~1ay of November, 2006, a
copy of the foregoing Petition for Emergency Relief was sent via United States First Class Mail,
postage pre-paid, addressed as follows:
Ms, Cynthia Nash
5138 East Trindle Road
Me:chanicsburg, P A 17050
Defendant/Respondent
andra L. Meilton, Esq Ire
1029 Scenery Drive
Harrisburg, Pennsylvania 17109
(717) 657-4795
Attorney for Plaintiff/Petitioner
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Sandra L. MeHton, Esquire
Daley, Zucker & Gingrich, LLC
1029 Scenery Drive
Harrisburg, PAl 71 09
(717) 657-4795
smeilton@dzglaw.com
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
METFORD K. JACKSON,
Plaintiff/Petitioner
No. 2002-1533 CIVIL TERM
v.
CYNTHIA NASH,
Defendant/Respondent
(In Custody)
~
AND NOW, this ~ on~ ,~u.h~r, 2006, upon consideration of the attached Petition
for Emergency Relief, it is hereby ordered that Cynthia Nash attend all supervised visits with
Kayla Jackson at !he YWCA Visitation Ce?ter or at Mr. Ora bill's office, until ~ Co ~
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METFORD K. JACKSON
V.
CYNTHIA C. NASH
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2002 - 1533 CIVIL TERM
ORDER OF COURT
AND NOW, this 7TH day of DECEMBER, 2006, the Petition for Emergency
Relief scheduled for Thursday, December 7, 2006, at 11 :00 a.m. has been rescheduled for
WEDNESDAY. DECEMBER 13. 2006. at 3:00 v.m. in Courtroom # 3.
Sandra L. Meilton, Esquire
111 North Front Street
P.O. Box 889
Harrisburg, Pa. 17108-0889
Metford K. Jackson
218 South 18TH Street
Camp Hill, Pa, 17011
Cynthia C. Nash
5138 East Trindle Road
Mechanicsburg, Pa. 1 7050
Court Administrator
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Edward E. Guido, J.
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METFORD K. JACKSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2002-1533 CIVIL TERM
v.
CYNTHIA NASH,
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this 13th day of December, 2006, after
hearing, our Order of November 14, 2006, is modified as follows:
Paragraphs l-B and C shall be changed to provide
as follows: Supervised visits between Kayla and mother may be
arranged wherever practical, such as the YMCA, the YWCA or the
Children's Playroom, and these visits shall be on a weekly
basis.
The following shall be added to Paragraph 3:
Mother shall attempt to schedule weekly visits with Mr. Graybill
so that she can accomplish unsupervised visitation as soon as
possible.
Paragraph 4 shall be changed as follows: Periods
of unsupervised visitation may begin upon the recommendation of
Mr. Graybill as long as that recommendation is put in writing.
Paragraph No. 5 shall be replaced with the
following: Mother may visit with the child in her home on
Christmas day from 7:00 p.m. until 8:00 p.m. Provided, however,
that the child shall have access to her cell phone and may
terminate the visit by calling her father at any time.
In all other respects, our Order of November 14,
2006, shall remain in
effect.
Edward E. Guido, J.
:6 HV S I 330 9UOl
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~ndra L. Meilton, Esquire
For the Plaintiff
~hia Nash
Defendant, Pro se
Sheriff
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METFORD K. JACKSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2002-1533 CIVIL TERM
CYNTHIA NASH,
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this 17th day of January, 2007, after
hearing, our Order of May 7, 2002, is modified as follows:
1. Paragraphs 3, 4, 5, 6, 7 and 8 are temporarily
suspended and replaced with the following:
a. Mother may have supervised visits with the
child at least one hour per week as arranged to suit her
schedule upon seven days' notice to father. Said visits may be
at the YMCA, YWCA, Children's Playroom, or any similar facility,
or with a mutually agreed upon third party. They may also be,
and we would heartily recommend this, at the office of Mr.
Graybill.
b. In addition to the above, mother may have
one hour of unsupervised visitation with the child in her home
every other Saturday from noon until 1:00 p.m. Provided,
however, the child shall have access to her cell phone and may
terminate that visit by calling her father at any time.
2. The following provisions are added:
a. The child shall continue in her individual
counseling with Mr. Graybill until she is successfully
discharged.
b. We recommend, however, we cannot force the
issue, that mother work with the child and Mr. Graybill to
improve her relationship. We note that we are not comfortable
expanding periods of unsupervised visitation without some
.. ;.
positive input from Mr. Graybill or some other professional.
In all other respects, our Order of May 7, 2002,
shall remain in full force and effect.
By the Court,
Edward E. Guido, J.
~ndra L. Meilton, Esquire
For the Plaintiff
v1~nthia Nash
Defendant, Pro se
Sheriff A-J.J.,I,'IUAl)
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