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HomeMy WebLinkAbout06-2756 AMANDA NICHOLSON, : IN TIIE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA VS. N0.06-a1 CLrv[LTERM ALBERT HALL, Defendant IN CUSTODY COMPLAINT IN CUSTODY Petitioner, Amanda Nicholson, by and through her counsel, Grace E. D'Alo of MidPenn Legal Services, states the following: 1. Plaintiff, hereinafter referred to as the Mother, resides at 154 West Penn St., Carlisle, PA 17013. 2. The above Defendant, Albert Hall, currently resides at 204 W. North Street, Carlisle, PA 17013. 3. Mother and Defendant are the natural parents of Maliek Albert Hall, born December 15, 2002. 4. Mother and Defendant were never married. 5. There is no prior order of court granting either party legal custody of Maliek. 6. Maliek has lived with the parties at the following addresses for the time specified: • From his birth until May 2005, Maliek lived with Mother and Defendant at 426 W. Penn Street in Carlisle. • In May 2005, Defendant moved out of the residence on West Penn Street and Maliek continued to live there with Mother until May 7, 2006. • From May 2006, when Defendant took Maliek from Mother's custody, Maliek has lived with the Defendant and not seen his mother. 7. The Defendant is not acting in Maliek's best interest for reasons including, but not limited to, the following: a. The Defendant has not allowed Mother to visit Maliek or exercise periods of partial custody since May 7, 2006; b. The Defendant has consistently acted to deny Mother visitation and partial custody of Maliek; c. The Defendant has encouraged his extended family to deny mother contact with Maliek; d. The Defendant refuses to provide Mother with information as to whether Maliek is receiving the care that is necessary and appropriate for him; 8. Mother can best provide for Maliek for reasons including, but not limited to, the following: a. The Mother is presently able to provide for Maliek by giving him a nurturing and stable home environment and providing for his emotional, physical, medical and educational needs; b. Mother's is close to members of her extended family who are interested in caring for and nurturing Maliek; c. Mother can best facilitate and maintain any contact between Maliek and the Defendant. 9. Mother requests that the Court grant her primary physical custody and shared legal custody of Maliek. WHEREFORE, Petitioner respectfully requests the following: a. Mother be granted primary physical custody and shared legal custody of Maliek; b. Defendant be granted shared legal custody and periods of partial custody and visitation; c. Any other relief this court deems just and proper. submitted, ?V Ur ce E. D'Alo Attorney ID #26146 Attorney for Plaintiff/ Petitioner MidPenn Legal Services 401 E. Louther Street Carlisle, PA 17013 VERIFICATION The above-named Plaintiff, Amanda Nicholson, verifies that the statements made in the attached complaint in custody are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: IS-\'S-C)(0 w? rdd N ( Amanda Nicholson AMANDA NICHOLSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY PENNSYLVANIA VS. ALBERT HALL, No. 06- CIVIL TERM Defendant IN CUSTODY AFFIDAVIT OF SERVICE BY MAIL I, Grace D'Alo, do hereby swear that I served Albert Hall with a Complaint in Custody and Petition for Special Relief on May 15, 2006, by regular mail, first class, to the person and address below: Albert Hall 204 W. North Street Carlisle, PA 17013 I, Grace E. D'Alo, verify that the statements made in this Affidavit of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: OL\- I © b AMANDA NICHOLSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY PENNSYLVANIA VS. ALBERT HALL, No. 06- CIVIL TERM Defendant . 'IN CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Amanda Nicholson, Plaintiff, to proceed in forma ap uneris. I, Grace E. D'Alo, attorney for the party proceeding in forma ap uneris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Geoffrey Biringer Attorneys for Plaintiff MidPenn Legal Services 401 E. Louther St. Carlisle, PA 17013 (717) 243-9400 Kn cn r AMANDA NICHOLSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA VS. No. 00'Q Crvn. TERM ALBERT HALL, Defendant IN CUSTODY PETITION FOR SPECIAL RELIEF Plaintiff, Amanda Nicholson, by and through her counsel, Grace E. D'Alo of MidPenn Legal Services, states the following: 1. Plaintiff, hereinafter referred to as Mother, resides at 426 W. Penn Street, Carlisle, Cumberland County, PA, 17013. 2. The above Defendant currently resides at 42 W. North Street, Carlisle, Cumberland County, Pennsylvania. Mother and Defendant are the natural parents of Maliek Albert Hall, born December 15, 2002. 4. Mother and Defendant were never married. 5. There is no prior order of court granting either party legal custody of Maliek. 6. Maliek has lived with the parties at the following addresses for the time specified: • From his birth until May 2005, Maliek lived with Mother and Defendant at 426 W. Penn Street in Carlisle. • In May 2005, Defendant moved out of the residence on West Penn Street and Maliek continued to live there with Mother until May 7, 2006. • From May 2006, when Defendant took Maliek from Mother's custody, Maliek has lived with the Defendant and not seen his mother. 7. The Defendant is not acting in Maliek's best interest for reasons including, but not limited to, the following: a. On May 7, Defendant took Maliek from Mother's custody with the express understanding that Maliek would be returned later in the day. b. The Defendant has not allowed Mother to visit Maliek or exercise periods of partial custody since May 7, 2006; c. The Defendant has consistently acted to deny Mother visitation and partial custody of Maliek; d. The Defendant has encouraged his extended family to deny mother contact with Maliek; e. The Defendant refuses to provide Mother with information as to whether Maliek is receiving the care that is necessary and appropriate for him; f. Up until May 7, 2006, Defendant was not an active presence in Maliek's life. Defendant has traumatized Maliek and by denying Mother access to Maliek and Defendant's continued denial further traumatizes Maliek; g. Mother tried to talk to Defendant by telephone but he would not give her information about Maliek's health, education or welfare nor would he give her any information about his future plans with respect to custody; h. Mother believes that Defendant cannot provide Maliek with appropriate sleeping arrangements; 8. Mother can best provide for Maliek for reasons including, but not limited to, the following: a. The Mother is presently able to provide for Maliek by giving him a nurturing and stable home environment and providing for his emotional, physical, medical and educational needs; b. Mother's is close to members of her extended family who are interested in caring for and nurturing Maliek; c. Mother can best facilitate and maintain any contact between Maliek and the Defendant. 9. Mother requests that the Court grant her primary physical custody and shared legal custody of Maliek.. 10. Mother is the parent who can best provide for Maliek for reasons including, but not limited to, the following: a. The mother is presently able to provide for Maliek by giving Maliek a nurturing and stable home environment and providing for her emotional, physical, medical and educational needs; b. Since Maliek's birth, Mother is the person who has provided for the daily needs of Maliek and is the person most capable of caring for them; c. Mother can best facilitate and maintain any contact between Maliek and the Defendant. 11. Without this Court's intervention, Mother and Maliek are at risk of irreparable harm by being denied contact with each other. WHEREFORE, Petitioner respectfully requests the following: V a. Amanda Nicholson shall have primary legal and physical custody of Maliek. b. The custodial rights of Defendant shall be limited to visitation and partial custody as ordered by this Court or agreed to by the parties. c. Defendant is prohibited from removing the children from Pennsylvania except as provided by this Court's custody order; I Any other relief this court deems just and proper. Respectfully submitted, D'Alo #26146 for Plaintiff/ Petitioner MidPenn Legal Services 401 E. Louther St. Carlisle, PA 17013 AMANDA NICHOLSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND? COUNTY PENNSYLVANIA VS. No. 001 CIVIL TERM ALBERT HALL, Defendant IN CUSTODY AFFIDAVIT OF SERVICE BY MAIL I, Grace E. D'Alo, do hereby swear that I served ALBERT HALL with a Petition for Special Relief on September 7, 2005, by REGULAR, FIRIST CLASS, U.S MAIL to the person and address below: Albert Hall 42 W. North Street Carlisle, PA 17013 I, Grace E. D'Alo, verify that the statements made in this Affidavit of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. Date:("NVAA ? ' ?J c ?' r y ? -c ? ?z ? r - -p ? ` ?' ? ,}ice t, . . , _ ?? f ? ? >1 ? _ S ? ? W J -.3 AMANDA NICHOLSON, PLAINTIFF V. ALBERT HALL, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 06-2756 CIVIL CIVIL ACTION - LAW IN CUSTODY IN RE: PETITION FOR SPECIAL RELIEF SEEKING CUSTODY ORDER OF COURT AND NOW, this 18th day of May, 2006, upon consideration of the attached Petition for Special Relief, IT IS ORDERED AND DIRECTED: A. Defendant is ordered to immediately return the child, Maliek Hall, to the care and custody of his mother, Amanda Nicholson, the Plaintiff in the above-captioned matter. B. Plaintiff, Amanda Nicholson, shall have primary physical and shared legal custody of Maliek Hall. C. That the parties and their respective counsel appear before this Honorable Court on May 25, 2006 at 3:00 p.m. for a hearing on said Petition. By the Court, Grace E. D'Alo, Esqu Xorney for Plaintiff ,Pbert Hall, Esquire bas ire a 'O O M. L. Ebert, Jr. U J lD 91:£ Wd 81 AVW 400Z A'&iOi OG'ii0lild ]Hi d0 3?L.4?-031!d AMANDA NICHOLSON IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ALBERT HALL 06-2756 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, May 19, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at__ 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, June 29, 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 hearing. FOR THE COURT. By: /s/ Hubert X. Gilro Es q. 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 : 7 ?i ? ..ca o AMANDA NICHOLSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : IN CUSTODY ALBERT HALL, Defendant :NO. 06-2756 CIVIL TERM MOTION FOR CONTINUANCE Defendant, Albert Hall, by and through his attorneys, the Family Law Clinic, represent the following in support of his Motion for Continuance: 1. On May 15, 2006 Plaintiff filed a Complaint irk Custody. The Order of Court dated May 19, 2006 schedules custody conciliation on Thursday, June 29, 2006 at 8:30 a.m. before Hubert Gilroy, Esquire. 2. On May 15, 2006, Plaintiff filed a Petition for, Special Relief Seeking Emergency Custody Pursuant to PA R.C.P. 1915.13. The Order of Court dated May 18, 2006 schedules a hearing on the Petition for Special Relief for Thursday, May 25, 2006 at 3:00 p.m. before the Honorable M. L. Ebert, Jr. 3. The Order of Court dated May 18, 2006 grants Plaintiff shared legal and primary physical custody of the parties' minor child, Maliek Hall, born December 15, 2002, pending further Order of Court. 4. Defendant was unable obtain legal counsel until the afternoon of Wednesday, May 24, 2006. 5. Defendant requests a continuance of the May 25, 2006 hearing to enable his legal counsel to adequately prepare for the hearing. 6. Pursuant to C.C.R.P. 208.2(d) concurrence of opposing counsel in this motion was sought and obtained. Date: May 25, 2006 Respectfully Submitted, Woodward si Legal Intern AS M. PLACE 2T E. RAINS JOHNSTON-WALSH MACDONALD-FOX ising Attorneys FAN41LY LAW CLINIC 45 Forth Pitt Street Carlisle, PA 17013 (711)243-2968 Fax: (717) 243-3639 o C7 cr. 0 =C? F, I (V < r) MAY 2 5 2006 AMANDA NICHOLSON, : IN THE COURT OF COMMON PLEAS OF U Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : IN CUSTODY ALBERT HALL, Defendant : NO. 06- 2756 CIVIL TERM ORDER OF COURT it AND NOW, this I S day of t`1. , 2006, upon consideration of the attached Motion for Continuance, the motion is granted. The hearing scheduled for May 25, 2006 at 3:00 p.m. is continued generally to the call of either party. Pending the Conciliation Conference scheduled for June 29, 2006, the Order of Court dated May 18, 2006 shall remain in full force and effect. BY THE COURT: S 1s ol. Date 4`? V! N' ; S Z .C bld SZ MW HE l.???1Gh¢?J Ilt?4d ?Hl ?0 Alb AMANDA NICHOLSON, Plaintiff v ALBERT HALL, Defendant 5 JUL 0 6 2006 r : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-2756 IN CUSTODY COURT ORDER AND NOW, this t h day of 2006, upon consideration of the attached Custody Conciliation report, it is ordered and directed that this Court's prior Order of May 18, 2006 is vacated and replaced with the following Order: 1. The mother, Amanda Nicholson, and the father, Albert Hall, shall enjoy shared legal custody of Maliek Albert Hall, born December 15, 2002. 2. The mother shall enjoy primary physical custody of the minor child. 3. The father shall enjoy periods of temporary physical custody of the minor child as follows: a. On every week when the father is off work during the week, he shall have custody for two days. For example, if the father is off work on Tuesday and Wednesday, he shall have custody of the minor child from Monday evening at or about 5:00 p.m. until Wednesday evening at or about 5:00 p.m. b. Every Friday from when father is off work until Saturday morning when father shall return the minor child to the mother prior to father going to work. c. At such other times as agreed on by the parties. 4. The parties shall meet with the Custody Conciliator again for a second Custody Conciliation Conference on September 8, 2006 at 8:30 a.m. At that time, both parties reserve the right to suggest that the above custody arrangement is not working out and that they may advance a different position for custody arrangement either at the Conference or at a subsequent Court hearing. 5. Both parties shall enjoy the right of first refusal with the respect to providing daycare for the minor child. In the event the custodial parent is unable to care for the minor child for three hours or more, the custodial parent must notify the non-custodial parent first to provide that parent with the opportunity to provide daycare for the child. BY THE COURT, '?N --? ?XA -V- Judge e M.L. Ebert cc: Jessica Holst, Esquire _ Gillian Woodward, Student Attorney 4. - _s AMANDA NICHOLSON, Plaintiff/ Respondent V. ALBERT HALL, Defendant/ Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY No. 06- 2756 CIVIL TERM PETITION FOR SPECIAL RELIEF SEEKING EMERGENCY CUSTODY PURSUANT TO PA R.C.P. 1915.13 AND NOW, this 19L day of 2006, pursuant to Rule 1915.13 of the Pennsylvania Rules of Civil Procedure, comes the Petitioner, Albert Hall, by his attorneys, the Family Law Clinic, seeking emergency custody of the minor child, Maliek Hall, born December 15`h, 2002. In support of his Petition for Emergency Relief, Petitioner avers the following: 1. The petitioner is Albert Hall (hereinafter Father), Father of the minor child, Maliek Hall (hereinafter child). 2. The respondent is Amanda Nicholson (hereinafter mother), mother of the minor child, residing at 154 West Penn Street, Carlisle, PA 17013. 3. Mother is the biological mother (hereinafter "Mother") of the child. 4. The parties resided together until November 1", 2004. 5. For much of the child's life, Mother and Father shared parenting duties. 6. Following their separation on November 1", 2004, the parties agreed to an informal custody arrangement such that Father had custodial periods with the child. 7. Mother filed a complaint for custody on May 15th, 2006, and the parties attended conciliation on Thursday, June 11 th, 2006. 8. The current custody order grants Mother primary custody and Father periods of partial custody. A copy of the current Custody Order is attached as "Exhibit A." 9. The evening of Sunday, July 23rd, 2006, Father was informed by a neighbor that his son was alone in the Mother's apartment. Father went to Mother's residence and found the front door open. Upon entering the apartment, he found his son alone in the apartment. 10. Father immediately called the Carlisle Police Department at 11:26 p.m. Police contacted Cumberland County Children and Youth Services. 11. The police noted that Mother's apartment was extremely dirty and unfit for a child. See attached police log entry, "Exhibit B." 12. As per police log entry, Mother drove home to her apartment intoxicated. 13. The Police released the child into Father's custody, as per direction from Cumberland County Children and Youth Services. 14. Father regularly receives custody of the child dirty, hungry, with rashes, bruises, and on one occasion with a black eye. 15. Mother has not been awake for the Saturday morning custody exchange on the following dates: Saturday, July 1St, 2006; Saturday, July 8', 2006; Saturday, July 15a', 2006. Mother has only been awake for the Saturday morning custody exchange on one occasion: Saturday, July 22nd, 2006. 16. During Conciliation Mother agreed to be awake on Saturday momings to receive custody of the child. Mother's continued failure to be awake to receive custody of the child interferes with Father's work schedule, as he must find someone to care for the child and he is consequently late for work. 17. Father believes and therefore avers that it is in the best interests of the minor child that Father be granted shared legal and primary physical custody of the child, pending further Order of Court. WHEREFORE, the Petitioner, Albert Hall, respectfully requests that this Honorable Court grant Petitioner shared legal and primary physical custody of the Child, as it is in the child's best interest. '( (,A5(0 Date Respectfully submitted, `( Gillian Woodward Certified Legal Intern Az &e 84hu LUCY HNSTON-WALSH ROBERT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX MEGAN MALONE Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013-2899 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing Petition for Special Relief are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: 7 BLS cC- Albert Hall, Petitioner AMANDA NICHOLSON, Plaintiff V ALBERT HALL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 06-2756 : IN CUSTODY COURT ORDER AND NOW, this •y °-- day of I,,Ify , 2006, upon consideration of the attached Custody Conciliation report, it is ordered and directed that this Court's prior Order of May 18, 2006 is vacated and replaced with the following Order: 1. The mother, Amanda Nicholson, and the father, Albert Hall, shall enjoy shared legal custody of Maliek Albert Hall, born December 15, 2002. 2. The mother shall enjoy primary physical custody of the minor child. 3. The father shall enjoy periods of temporary physical custody of the minor child as follows: a. On every week when the father is off work during the week, he shall have custody for two days. For example, if the father is off work on Tuesday and Wednesday, he shall have custody of the minor child from Monday evening at or about 5:00 p.m. until Wednesday evening at or about 5:00 p.m. b. Every Friday from when father is off work until Saturday morning when father shall return the minor child to the mother prior to father going to work. c. At such other times as agreed on by the parties. 4. The parties shall meet with the Custody Conciliator again for a second Custody Conciliation Conference on September 8, 2006 at 8:30 a.m. At that time, both parties reserve the right to suggest that the above custody arrangement is not working out and that they may advance a different position for custody arrangement either at the Conference or at a subsequent Court hearing. 5. Both parties shall enjoy the right of first refusal with the respect to providing daycare for the minor child. In the event the custodial parent is unable to care for the minor child for three hours or more, the custodial parent must notify the non-custodial parent first to provide that parent with the opportunity to provide daycare for the child. BY THE COURT, ,/s[ Ah Jf ELL <? . Judge M.L. Ebert cc: Jessica Holst, Esquire Gillian Woodward, Student Attorney ??: ?`yyy?sW?SiTyt' i?ttrta+?J txz?? ,.:ti : e;l r? #ld 2f rl _.. _ r ? ?w Pr (DISIPINC) RLH1 UCFPCARM DISPATCH INCIDENT: 20060701325 CAR PAGE: 1 CALL TYPE: CIVIL (O-AGENCY) LOCATION ------------------ ----------------- ----- GRID CCL ----- UCR IPG DISP O PRI 00154 W PENN ST --------- 0500 816 ----- 0000 ------ Y ---- 04 --------- 5 ALARP CTAK DPAT ------------------- VEH-REGISTRAT ---------------- MAKE ----- DATE ---------- RECV DISP ARRV CLR TOTT REP N RLW4 RLW4 20060723 ---- 2326 ----- 2326 ------ 2328 ---- 0031 --------- 0065 R UNIT BADG OFFICER ------------------- 04 4 PARSON ---------------- DANIEL ----- F ---------- 20060723 ---- ------ 2326 ----- 2328 ---- 0031 --------- 12 12 MILLER W D 20060723 2340 2342 0010 04 4 PARSON DANIEL F 20060723 2327 2330 0000 NAMES: HALL ALBERT (C) 717 900 0000 NICHOLSON AMANDA A (A) 000 000 0000 154 B WEST PENN ST. KOSER VIRGINA (0) 000 240 5311 CCC& Y CASE WORKER COMMENTS: HALL, 204 W NORTH ST, REPORTED HIS 3 YR OLD LEFT ALONE BY MOTHER AT 154 W PENN ST. 04 ON CALL. C & Y CALLED. 2351 - CPL 12 REPORTING 1015. 2356 - 4 ENROUTE WITH FEMALE 1015 TO BOOKING, MIL 40932. ENDING MILAGE 40934. CALIQUE HALL (3) THREE Y.O.A WAS FOUND ALONE IN 154B WEST PENN. CHILD WAS TAKEN FROM THE HOME AND RELEASED TO HIS FATHER ALBERT HALL PER CHILDREN AND YOUTH. MOTHER ARRIVED ONSCENE IN A VOLKSWAGON JETTA (AMANDA NICHOLSON) SAME WAS INTOXICATED, REFUSED/FAILED SFST. 10-15 TAKEN TO BOOKING. 154B WEST PENN WAS EXTREMELY DIRTY AND CLUTTERED ANF UNFIT FOR A CHILD TO WLAKING AROUND. CHILDREN AND YOUTH OBSERVED THE HOME. REPORT TO BE FILED (CC/MV/ MI) EXHIBIT (DISIPINC) DISPATCH INCIDENT: 20060701325 CAR VIRGINA KOSER CCC&Y REQUESTED AN OFFICER GO TO 153 A W PENN ST AND SEE A JUVENILE NAME PARIS AGE 15 OR 16 AND SEE IF MOTHER HAD HER DOING THE BABY SITTING WHILE SHE WAS AWAY. 40 ON CALL TIME 1000 HRS RLH1 UCFPCARM PAGE JUL z s 2006r AMANDA NICHOLSON, IN THE COURT OF COMMON PLEAS Plaintiff/ Respondent OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW IN CUSTODY ALBERT HALL, : Defendant/ Petitioner No. 06-2756 CIVIL TERM ORDER OF COURT AND NOW, this ?day of _f4 2006, upon consideration of the attached Petition for Special Relief, it is hereby Ordered as follows: 1. Albert Hall, Petitioner, shall have shared legal and primary physical custody of the minor child, Maliek Hall. 2. The parties and their respective counsel shall appear before the Court on the hd- day of Oyu , 2006, at /0 Am. in Courtroom Number 5 , Cumberland County Courthouse, Carlisle, Pennsylvania 17013. BY THE COURT, uAV I- ? J. o`0 IV T? a? ? 141' r?\ IU ,. AMANDA NICHOLSON, Plaintiff/Respondent V. ALBERT HALL, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 06-2756 CIVIL TERM IN RE: PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 2nd day of August, 2006, after hearing, the Court finds in favor of the Petitioner and grants his Petition for Special Relief. IT IS HEREBY ORDERED AND DIRECTED that Albert Hall will have legal and primary physical custody of this minor child until the custody conciliation hearing scheduled for September 8, 2006. In the interim, the parties are directed to develop a visitation schedule for the mother which will not include overnight visits pending completion of the custody conciliation hearing. By the Court, ? essica Holst, Esquire MidPenn Legal Services For the Plaintiff/Respondent M. L. Ebert, Jr., Anne MacDonald-Fox, Esquire V?511ian Woodward, Certified Legal Intern Family Law Clinic For the Defendant/Petitioner O :mtf f I I SEP 1 $ 2805 AMANDA NICHOLSON, : IN THE COURT OF COM US OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW ALBERT HALL, NO. 06-2756 Defendant IN CUSTODY COURT ORDER AND NOW, this ST Z day of September, 2006, upon consideration of the attached Custody Conciliation report, it is ordered and directed that this Court's prior Orders of July 7, 2006 and August 2, 2006 are vacated and replaced with the following Order: 1. Amanda Nicholson, hereinafter referred to as Mother, and Albert Hall, hereinafter referred to as Father, shall share legal custody of the child. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major, non-emergency decisions affecting the children's general well- being including, but not limited to, all decisions regarding his health, education and religion. Each parent shall be entitled to all records and information pertaining to the children, including, but not limited to, medical, dental, religious or school records, and the resident address of the children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Father shall have primary physical custody of Maliek. 3. Mother shall have periods of partial physical custody of Maliek according to the following schedule: a. During the day when Father is working. b. On the two nights Mother is off of work, she will have Maliek for overnight visits and shall stay home with the minor child. 4. Mother and Father will coordinate the times for the visits during Father's work day and Mother will communicate with Father to provide sufficient notice of her nights off each week. 5. For exchange of custody, the parent with custody shall deliver the child to the other parent. 6. During the summer months, each party shall have physical custody of Maliek for a full week in June, July and August. The parties shall notify each other of their intended weeks of vacation thirty (30) days in advance. The parties shall work cooperatively in coordinating their vacations so as not to interfere with the other parent's vacation plans. 7. It is understood that the period of uninterrupted vacation does not require that either party leave the area for the selected week. If, however, either party must work during that time, Maliek will stay with the non-custodial parent until the end of the custodial parent's work day so that Maliek will have appropriate supervision. 8. The parties shall work together to ensure that they both have the opportunity to spend time with Maliek on major holidays including, but not limited to: New Year's Day, Easter, Memorial Day, July 4, Labor Day, Halloween, Thanksgiving, Maliek's Birthday, and Christmas. 9. Mother shall always have custody of Maliek for Mother's Day and Father shall always have custody of Maliek for Father's Day. 10. Neither party shall do anything which may estrange Maliek from the other parent, or injure Maliek's opinion as to the other parent or which may hamper the free and natural development of Maliek's love or respect for the other parent. Both parties shall provide Maliek with a "safety zone" by discouraging third parties from making negative remarks about either parent when Maliek is within earshot. 11. The parties may modify the schedule in the event they reach an agreement between themselves. Absent an agreement, the custody schedule set forth above shall control. 12. The parties intend to be bound by the terms of this Agreement and intend for this Agreement to be made an Order of Court. 13. Neither parent shall consume alcohol when they have custody of the minor child. BY THE COURT, ?* ?-I" Ur--tA'I- - Judge M.L. Ebert cc%J'e"ssica Hoist, Esquire ,.began Riesmeyer, Esqui! J SO -. h Wd I Z d3S 90OZ Ad1'ia4c;Aioa3 3H1 AO 3')H4?-_,-r-Mtj AMANDA NICHOLSON, Plaintiff v ALBERT HALL, Defendant Prior Judge: M.L. Ebert : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-2756 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Maliek Albert Hall, born December 15, 2002. 2. A Conciliation Conference was held on September 8, 2006, with the following individuals in attendance: The mother, Amanda Nicholson, with her counsel, Jessica Holst, Esquire, and the father, Albert Hall, with his counsel, Megan Riesmeyer. 3. The parties agree to the entry of an Order in the form as attached. (?-/3 -'?' ? (/I DATE Hubert X. Gil y, Esquire Custody C cdiator Amanda Nicholson, : IN THE COURT OF COMMON PLEAS OF PlaintifflRespondent : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY Albert Hall, Defendant/Petitioner : NO. 06-2756 CIVIL TERM PETITION TO MODIFY CUSTODY ORDER 1. The petition of Albert Hall, by his attorneys, the Family Law Clinic, respectfully represents that on September 21, 2006, an Order of Court was entered for custody of Maliek Hall, born December 15, 2002, a true and correct copy of which is attached. Under the existing Order, Father and Mother share legal custody of the child. Father has primary physical custody and Mother has partial custody of the child. Mother is to have physical custody of the child during the day when Father is working. On the two nights Mother is off work, she has the child for overnight visits. Each party is entitled to one full week of physical custody of the child in June, July, and August. The parties are to work together to ensure they both have opportunity to spend time with the child on major holidays, and Father has custody of child on Father's Day and Mother has custody of child on Mother's Day. The parties may modify the schedule in the event they reach an agreement between themselves. 2. This Order should be modified because: a. Father and Mother agree that Father should have legal custody of the child. The parties agree that Mother should have periods of partial physical custody. A custody agreement signed by Father and Mother is attached. 3. The Honorable M. L. Ebert, Jr. has previously been assigned to this case. 4. Concurrence of opposing counsel was not sought as PlaintifflRespondent is proceeding pro se. WHEREFORE, Petitioner asks that the Court modify the existing Order for Custody and enter the attached Proposed Custody Order because it will be in the best interest of the child. Respectfully submitted, Date: 7 OW4. Holly O. V ghn Certified Legal Intern THOMAS M. PLACE ROBERT E. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. '__2 &Z;0-4_ - Date: 6Z21,2 Albert Hall CERTIFICATE OF SERVICE I, Holly O. Vaughn, Certified Legal Intern, the Family Law Clinic, hereby certify that I am serving a true and correct copy of a Petition to Modify Custody Order and Custody Agreement on the following person by first class U.S. Mail, postage prepaid, this Ith day of ?J tW6 , 2007: Amanda Nicholson 154 B West Penn Street Carlisle, PA 17013 4ko H4Holly O. Vau Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 C? 'e' _ r^? ?J -- (T? ! "".7 ? ?r..l --,(?? _ _;. „:4&.s ..?,... .? f ? _ . , y?,?l -'? Amanda Nicholson, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY Albert Hall, Defendant/Petitioner : NO. 06-2756 CIVIL TERM CUSTODY AGREEMENT THIS AGREEMENT, made this 7 day of i"f , 2007, between Amanda Nicholson, hereinafter Mother, and Albert Hall, hereinafter Father, concerns the custody of their child, Maliek Hall, born December 15, 2002. Mother and Father desire to enter into a custody agreement regarding the custody of the child. Mother and Father agree to the following. 1. Father shall have sole legal custody of the child. 2. Father shall have primary physical custody of the child. 3. Mother shall have periods of partial physical custody of the child according to the following schedule: a. Monday through Thursday during the day when Father is working; b. Two nights per inonth, to occur on nights that parties mutually agree, Mother will have the child for overnight visits and shall stay home with the minor child; c. Additional overnight visits as parties mutually agree. 4. For exchange of custody, the parent with custody shall deliver the child to the other parent. 5. The parties shall work together to ensure that they both have the opportunity to spend time with the child on major holidays including, but not limited to: New Year's Day, Easter, Memorial Day, July 4t', Labor Day, Halloween, Thanksgiving, the child's birthday, and Christmas. 6. Mother shall always have custody of the child on Mother's Day and Father shall always have custody of the child on Father's Day. 7. Neither party shall consume alcohol when the child is in his or her custody. 8. Mother and Father will notify each other of all medical care the child receives while in the parent's care. Mother and Father will notify the other immediately of medical emergencies which arise while the child is in that parent's care. 9. Neither parent will do anything which may estrange the child from the other party, or injure the opinion of the child as to the other parent or which may hamper the free and natural development of the child's love and respect for the other parent. Both parties shall provide the child with a "safety zone" by discouraging third parties from making negative remarks about either parent when the child is within earshot. 10. The parties may modify the schedule in the event they reach an agreement between themselves. Absent an agreement, the custody schedule set forth above shall control. 11. Mother acknowledges that the Family Law Clinic represented only Father's interest in this matter and has given her no legal advice other than that she should seek the advice of legal counsel. 12. The parties intend to be bound by the terms of this agreement and intend for this Agreement to be made an Order of Court. ffivu?wr yjel? ? ?? Amanda Nicho son, Albert Hall, Plaintiff/Respondent Defendant/Petitioner "64w"N"Ijuk Holly O. aughn Certified Legal Intern Counsel for Plaintiff &Aw ZL4t&&?_t ROB T E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Counsel for Plaintiff FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 Fax (717)243-3639 0 n -?, Fr; = CD r a AMANDA NICHOLSON IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ALBERT HALL DEFENDANT 06-2756 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, June 11, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, June 29, 2007 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 pennanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilroy, Es q. jJ0 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 9C :Zl W'd I 1 Or Laoz JUN 2 0 2001 pi AMANDA NICHOLSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION -LAW ALBERT HALL, : NO. 2006-2756 Defendant : IN CUSTODY COURT ORDER AND NOW, this /? day of June, 2007, the Conciliator being advised the parties have reached an agreement, the Conciliator relinquishes jurisdiction. _Z?w \?? Hubert X. Gil y, Esquire Custody Co ciliator F:TTES\Gener&ACurrent\12321NUcholwn v HaH ConcWation Order reUnqulshine jurisdictlon.wpd 90 ,li tliJ 0V [ nC t00Z :!I i Amanda Nicholson, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY Albert Hall, Defendant/Petitioner : NO. 06-2756 CIVIL TERM ORDER AND NOW, this ` day of JJ k 2007, the Defendant's Petition to Modify Custody Order is granted and the following P oposed Custody Agreement is entered as an Order of the Court: 1. Father shall have sole legal custody of the child. 2. Father shall have primary physical custody of the child. 3. Mother shall have periods of partial physical custody of the child according to the following schedule: a. Monday through Thursday during the day when Father is working; b. Two nights per month, to occur on nights that parties mutually agree, Mother will have the child for overnight visits and shall stay home with the minor child; c. Additional overnight visits as parties mutually agree. 4. For exchange of custody, the parent with custody shall deliver the child to the other parent. 5. The parties shall work together to ensure that they both have the opportunity to spend time with Maliek on major holidays including, but not limited to: New Year's Day, Easter, Memorial Day, July 4a', Labor Day, Halloween, Thanksgiving, Maliek's birthday, and Christmas. ?L f? ViNIO ^J ? f\j r, v P. O o s ` I wj 9- w LODZ O L ;-uJ ?Cf Y # LiJ ?l i "i -:"Hl ?O . . .1 J. 6. Mother shall always have custody of Maliek-on Mother's Day and Father shall always have custody of Maliek on Father's Day. 7. Neither party shall consume alcohol when Maliek is in his or her custody. 8. Mother and Father will notify each other of all medical care the child receives while in the parent's care. Mother and Father will notify the other immediately of medical emergencies which arise while the child is in that parent's care. 9. Neither parent will do anything which may estrange the child from the other parry, or injure the opinion of the child as to the other parent or which may hamper the free and natural development of the child's love and respect for the other parent. Both parties shall provide Maliek with a "safety zone" by discouraging third parties from making negative remarks about either parent when Maliek is within earshot. 10. The parties may modify the schedule in the event they reach an agreement between themselves. Absent an agreement, the custody schedule set forth above shall control. 11. Mother acknowledges that the Family Law Clinic represented only Father's interest in this matter and has given her no legal advice other than that she should seek the advice of legal counsel. 12. The parties intend to be bound by the terms of this agreement and intend for this Agreement to be made an Order of Court. AMANDA NICHOLSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06 - 2756 ALBERT HALL, CIVIL ACTION - LAW Defendant IN CUSTODY AFFIDAVIT OF SERVICE I, Charla Lenz, hereby certify that I served a true and correct copy of the July 6, 2007 Custody Order, on Plaintiff, Amanda Nicholson, at: 154B West Penn Street, Carlisle, Pennsylvania 17013 via First Class Mail on July 11, 2007. I verify that the statements made in this Affidavit of Service are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. Date: 1 0? -OQ? Charla Lenz Certified Legal Intern 7-1 ?'??:• ? ma --r__' r -rR ?? Amanda Nicholson, Plaintiff/Respondent V. Albert Hall, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY NO. 06- 2756 CIVIL TERM PETITION TO MODIFY CUSTODY ORDER AND NOW comes Petitioner, Albert Hall, by and through his attorneys, the Family Law Clinic, and presents the following in support of his Petition to Modify Custody Order. 1. Petitioner (hereinafter Father), respectfully represents that on July 7, 2007, an Order of Court was entered for custody of Maliek Hall, born December 15, 2002, a true and correct copy of which is attached. Under the existing Order, Father has sole legal and primary physical custody of the child. Respondent, Amanda Nicholson (hereinafter Mother) has partial physical custody of the child. Mother is to have physical custody of the child Monday through Thursday during the day when Father is working, and two nights per month, to occur when the parties mutually agree. Mother shall have additional overnight visits as the parties mutually agree. The parties may modify the schedule in the event they reach an agreement between themselves. 2. This Order should be modified because: a. Mother has not visited with or asked to visit the child since November, 2007. b. Mother's landlord has indicated that Mother was evicted from her apartment on February 19, 2008, because 1) She discharged and removed the smoke detector; 2) She did not notify the landlord of the last custody modification, as required under the rules of the housing assistance program; 3) She broke the housekeeping rules more times than allowed by the housing assistance program; 4) She failed to maintain appliances in the apartment; 5) She kept so much trash in the apartment that the landlord could barely enter the apartment; 6) She has not paid rent since November, 2007 c. According to her landlord, Mother's apartment was in unlivable condition. d. Mother does not have an appropriate or safe place for the visits. e. Father believes and therefore avers that Mother is frequently intoxicated. f. Father believes and therefore avers that Mother is frequently in the company of known drug dealers and drug users. g. Father believes and therefore avers that Mother may have serious health problems, for which she is not seeking treatment. h. Father believes and therefore avers that Mother is unable to adequately take care of the child when the child is in her custody. i. Father believes and therefore avers that these same concerns have been ongoing since May 2006. 7) Concurrence of opposing counsel as required by C.C.R.P. 208.2(d) was not sought as the opposing party is not represented by counsel. 8) The Honorable M.L. Ebert has previously ruled upon other issues in this matter. WHEREFORE, Petitioner respectfully requests that the Court modify the existing Order for Custody and grant Father sole physical custody because it will be in the best interest of the child. Date: 7, 2009 Pao Fei Bao Certified Legal Intern AJA1.4 1--,'9 - &-1- MEGA/4 RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. § 4904 relating to unworn falsification to authorities. Date: 2- Albert Hall, Petitioner ?? ? '' `? °', a ?r' i ?, =? J ?? ?- ,j e ..._ rr? • .""'1 Yu+-J x? Amanda Nicholson, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY Albert Hall, : Defendant/Petitioner NO. 06-2756 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Albert Hall, Defendant/Petitioner, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date -W.,;?-,7, Zo0? /.?.J Oa 0 Fei Bao Certified Legal Intern ROBE E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ?..a 4- i c..7n CO AMANDA NICHOLSON IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ALBERT HALL DEFENDANT 2006-2756 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, March 05, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at------ 4th Floor,-Cumberland County Courthouse, Carlisle on Friday, April 04, 2008 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. 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/ Hubert X. Gilroy, Es q, 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 MNVAIASNN3d 9 Z -.Z Wd S- NVN DOOZ AAMINO ;.I C,dd RK JO 30UK' -ClYlIJ AMANDA NICHOLSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY ALBERT HALL, Defendant. : NO. 06-2756 CIVIL TERM CUSTODY AGREEMENT THIS AGREEMENT, made this IL day of , 2008, between Amanda Nicholson, hereinafter Mother, and Albert Hall, hereinafter Father, concerns the custody of their child: Maliek Hall, born on December 15, 2002 Mother and Father desire to enter into an agreement as to the custody of the child. Mother and Father agree to the following. 1. Father shall sole legal custody of the child. 2. Father shall have sole physical custody of the child. 3. Mother shall have visitation with the child upon Father's consent. 4. Neither party shall consume alcohol or illegal drugs when the child is in his or her care. 5. Mother and Father shall notify each other of all medical care the child receives while in the parent's care. Mother and Father shall notify the other immediately of medical emergencies which arise while the child is in that parent's care. 6. Neither party shall do anything which may estrange the child from the other party, or injure the opinion of the child as to the other parent or which may hamper the free and natural development of the child's love and respect for the other parent. 7. Mother acknowledges that the Family Law Clinic represented only Father's interest in this matter and has given him no legal advice other than that he should seek the advice of legal counsel. 8. The parties intend to be bound by the terms of this agreement and intend for this Agreement to be made an Order of Court. z Amanda Nicholson Albert Hall Plaintiff Defendant _ e4, 9, Fei Bao Certified Legal Intern Counsel for Defendant MEGA EYER ANNE M CDONALD-FOX Counsel for Plaintiff FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 Fax (717)243-3639 -? fry f_, l :? LIAR $ 8 2008 AMANDA NICHOLSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW ALBERT HALL, NO. 2006-2756 Defendant IN CUSTODY COURT ORDER AND NOW, this'd day of March, 2008, the Conciliator being advised the parties have reached an agreement, the Conciliator relinquishes jurisdiction. ?(-'o Hubert X. Gilroy, Es uire Custody Conciliato 1r Z .rt E ,°? ?Ci ft on Ao. Amanda Nicholson, Plaintiff/Respondent V. Albert Hall, Defendant/Petitioner AND NOW, this kS' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY No. 06-2756 CIVIL TERM ORDER OF COURT AR 27 2008 day of A , 2008, the following Custody Agreement is entered as an Order of the Court: 1. Father shall sole legal custody of the child. 2. Father shall have sole physical custody of the child. 3. Mother shall have visitation with the child upon Father's consent. 4. Neither party shall consume alcohol or illegal drugs when the child is in his or he r care. 5. Mother and Father shall notify each other of all medical care the child receives A hi[e in the parent's care. Mother and Father shall notify the other immediately of med ical emergencies which arise while the child is in that parent's care. 6. Neither party shall do anything which may estrange the child from the other part; ,. or injure the opinion of the child as to the other parent or which may hamper the fre and natural development of the child's love and respect for the other parent. BY THE COURT: 1?k -? La J. (--)7 IE?7 cy ''74: w gild a? 13 o///ti