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HomeMy WebLinkAbout06-3895 .. J DAVID ALAN JOHNSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06- :5 l?7') CIVIL TERM STACEY LYNN FERRY, Defendant CUSTODY COMPLAINT I. Plaintiff is David Alan Johnson, hereinafter referred to as Father. Father resides at 36 Town Mills, Shippensburg, Cumberland County, Pennsylvania 17257. 2. Defendant is Stacey Lynn Ferry, hereinafter referred to as Defendant. 3. Defendant's permanent address is 3589 Orrstown Rd. Orrstown, Franklin County, Pennsylvania 17244. 4. Father seeks primary physical custody ofthe minor child: Name Chance Johnson Present Residence 3589 Orrstown Rd. Orrstown, P A 17050 Age 10107/93 DOB, 12 yrs old. Chance was born out of wedlock 5. Chance is currently in Defendant's custody. 6. Defendant wrongfully refused to retum the child to father after her last visitation and continues to refuse father any contact or visitation. 7. During his lifetime, Chance has resided with the following persons and at the following addresses: Name Address Date Stacey Lynn Ferry Various addresses unknown to Father but including several in Shippensburg and a move for three years to Polk County, Florida birth - 10105 ~ f David Alan Johnson 36 Towne Mills Shippensburg, P A 17257 10105-06/06 Stacey Lynn Ferry 3589 Orrstown Rd. Orrstown, P A 17244 06/06-present 8. Father currently resides with the following persons: Name Relationship Lesley Burns Girlfriend Trevor Thomas Son of girlfriend Emily Johnson DOB 6/1 0105 Daughter of Lesley and Father 9. It is believed that Defendant lives with the following persons: Name Relationship Chastity DOB 8/2/92 Daughter of Defendant and Father Shivanna Sipes Daughter of Defendant Adult Male Boyfriend 10. Father seeks primary physical custody, which is in Chance's best interest, for reasons including but not limited to the following: a. Chance has lived continuously with his father for the past year and has made significant improvement socially, emotionally and academically. b. Chance has leaming and behavioral problems and has prescribed medications. Father monitors and administers Chance's medications. c. Chance is a borderline diabetic and has weight and appetite control problems. Father monitors Chance's diet. d. Chance benefits from psychological counseling. Father takes Chance to all of his family counseling appointments. t- . e. Chance is currently on probation. Father monitor's Chances activities and actions and ensures his participation in required community service projects. f. Father provides stable home environment and supervision for Chance. 11. Defendant has not acted in Chance's best interests in ways including but not limited to the following: a. Defendant does not monitor Chance's diet even though he is borderline diabetic. b. Defendant has failed to keep Chance's family counseling sessions. c. Defendant does not monitor and supervise the administering of Chance's medications. d. Defendant's behavior is erratic and harsh towards Chance. e. Defendant does not make sure that Chance keeps up with his community service projects that he must complete because he is on probation. f. Defendant has unreasonably prevented Chance from talking to or seeing his Father. 12. Defendant picked up Chance on June 28, 2006 for a visitation and has failed to return him to the Father. Defendant has also refused Father any contact with his son. 13. Father is afraid that Defendant will leave the state with Chance as she has done in the past. 14. There is a prior custody order from Polk County, Florida issued in 2002. Father is seeking a copy of that order which was obtained when he was incarcerated in Pennsylvania. Father did not participate in this custody proceeding. IS. On October 7, 2005, Defendant relinquished custody of Chance to Father. (See attached.) 16. Jurisdiction should be in Cumberland County, Pennsylvania because all parties reside in or near Cumberland County. 23 PA. CONS. STAT. ANN. S 5421 (a) (1-2) (2004), S 5422 (b) (2004). 17. Every person with rights to custody or having actual physical custody of Chance has been \. t named as parties to this action. WHEREFORE, Plaintiff respectfully requests the following relief: a. David Alan Johnson shall have primary legal and physical custody of the children. b. The custodial rights of Defendant shall be limited to visitation 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; d. Any other relief this court deems just and proper. r ce E. D' Alo, Esquire i enn Legal Services East Louther Street Carlisle, P A 17013 (717) 243-9400 \. October 7, 2005 I Stacev Lvnn Ferrv give full custody of Chance David Johnson to his father David Alan Johnson as of October 7111 . 2005. As agreed David Alan Johnson will Pay $39.00 a week on back support and $1.00 a week on P ACSES current support Order 681000067 Docket number 301 S 94 for a term of one year being October 7111, 2006, then will be dropped to $35.00 a week on back support only, which the original support order will be dropped and closed. " No support will be paid for Chasitv Nicole Johnson because both parents have one child each. ;), ~::d~it ./ ID ~ 7 ,au.) Date \. . VERIFICATION The above-named PLAINTIFF, DAVID ALAN JOHNSON, verifies that the statements made in the above Complaint For Custody are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of I 8 Pa c.s. 94904, relating to unsworn falsification to authorities. Date:? ~ I; 2CX)/o ~~~~A- DAVID ALAN JOHNSON --- \\ \J , :.....,) c.! -" ::y:! h'; ( ~. ,;; I,;' t_:::, , , DAVID ALAN JOHNSON Plaintiff : IN THE COURT OF COMMON PLEAS OF v. : CUMBERLAND COUNTY, PENNSYLVANIA : NO.06- '3 'l!'f{ S-- CIVIL TERM : CUSTODY STACEY LYNN FERRY Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, David Johnson, Plaintiff, to proceed in forma pauperis. I, Grace D' Alo, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. ace E. D' Alo, Esq. M dPenn Legal Services 1 East Louther Street Carlisle, PA 17013 (717) 243-9400 r" ;;.,1 . .--' ,:':;7:__,~ L~ ,:,>"" ~~~ :1":' C) o (L. DAVID ALAN JOHNSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYL VANIA YS. No. 06-jll15cIVIL TERM STACEY LYNN FERRY, Defendant IN CUSTODY PETITION FOR SPECIAL RELIEF AND NOW, comes the Plaintiff, David Alan Johnson, by and through his counsel, Grace E. D' Alo of MidPenn Legal Services, states the following: 1. Plaintiff is David Alan Johnson, hereinafter referred to as Father. Father resides at 36 Town Mills, Shippensburg, Cumberland County, Pennsylvania 17257. 2. Defendant is Stacey Lynn Ferry, hereinafter referred to as Defendant. 3. Defendant's permanent address is 3589 Orrstown Rd. Orrstown, Franklin County, Pennsylvania 17244. 4. Father seeks primary physical custody of the minor child: Name Chance Johnson Present Residence Age 10/07/93 DOB, 12 yrs old. 3589 Orrstown Rd. Orrstown, P A 17050 Chance was born out of wedlock 5. Chance is currently in Defendant's custody. 6. Defendant wrongfully refused to return the child to father after her last visitation and continues to refuse father any contact or visitation. 7. During his lifetime, Chance has resided with the following persons and at the following addresses: t'< Name Address Stacey Lynn Ferry Various addresses unknown to Father but including several in Shippensburg and a move for three years to Polk County, Florida Date birth - 10/05 David Alan Johnson 36 Towne Mills Shippensburg, P A 17257 10/05-06/06 Stacey Lynn Ferry 3589 Orrstown Rd. Orrstown, P A 17244 06/06-present 8. Father currently resides with the following persons: Name Relationship Lesley Burns Girlfriend Trevor Thomas Son of girlfriend Emily Johnson DOB 6/10/05 Daughter of Lesley and Father 9. It is believed that Defendant lives with the following persons: Name Chastity DOB 8/2/92 Daughter of Defendant and Father Shivanna Sipes Daughter of defendnat Adult male Boyfriend 10. Father seeks primary physical custody, which is in Chance's best interest, for reasons including but not limited to the following: a. Chance has lived continuously with his father for the past year and has made significant improvement socially, emotionally and academically. b. Chance has learning and behavioral problems and has prescribed medications. Father monitors and administers Chance's medications. c. Chance is a borderline diabetic and has weight and appetite control problems. Father monitors Chance's diet. d. Chance benefits from psychological counseling. Father takes Chance to all of his family counseling appointments. .'. t~ e. Chance is currently on probation. Father monitor's Chances activities and actions and ensures his participation in required community service projects. f. Father provides stable home environment and supervision for Chance. 11. Defendant has not acted in Chance's best interests in ways including but not limited to the following: a. Defendant does not monitor Chance's diet even though he is borderline diabetic. b. Defendant has failed to keep Chance's family counseling sessions. c. Defendant does not monitor and supervise the administering of Chance's medications. d. Defendant s behavior is erratic and harsh towards Chance. e. Defendant does not make sure that Chance keeps up with his community service projects that he must complete because he is on probation. f. Defendant has unreasonably prevented Chance from talking to or seeing his Father. 12. Defendant picked up Chance on June 28, 2006 for a visitation and has failed to return him to the Father. Defendant has also refused Father any contact with his son. 13. Father is afraid that Defendant will leave the state with Chance as she has done in the past. 14. There is prior custody order from Polk County, Florida. Father is seeking a copy of that order which was obtained when he was incarcerated in Pennsylvania. Father did not participate in this custody proceeding. 15. On October 7, 2005, Defendant relinquished custody of Chance to Father. (See attached. ) 16. Jurisdiction should be in Cumberland County, Pennsylvania because all parties reside in or near Cumberland County. 23 CONS. STAT. ANN. 9 5421 (a) (1-2) (2004). 17. Every person with rights to custody or having actual physical custody of Chance has been named as parties to this action. " WHEREFORE, Plaintiff respectfully requests the following relief: a. David Alan Johnson shall have primary legal and physical custody of the children. b. The custodial rights of Defendant shall be limited to visitation 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; d. Any other relief this court deems just and proper. Respectfully submitted, G e .D'Alo At ey for Plaintiff! Petitioner Mi enn Legal Services 8 Irving Row Carlisle, P A 17013 I ~ October 7, 2005 I Stacev Lvnn Ferrv give full custody of Chance David Johnson to his father David Alan Johnson as of October 7th . 2005. As agreed David Alan Johnson will Pay $39.00 a week on back support and $1.00 a week on P ACSES current support Order 681000067 Docket number 301 S 94 for a term of one year being October 7th, 2006, then will be dropped to $35.00 a week on back support only, which the original support order will be dropped and closed. No support will be paid for Chasitv Nicole Johnson because both parents have one child each. -,~ --cS ~~:d~~ /' lo~ 7 ,0<<)" Date . ., . I VERIFICATION The above-named PLAINTIFF, DAVID ALAN JOHNSON, verifies that the statements made in the above Petition for Special Relief are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. !l4904, relating to unsworn falsification to authorities. Date: 7 ~ 7 J ZDOb ~~A~tON . .. . I DAVID ALAN JOHNSON, Plaintiff :IN THE COURT OF COMMON PLEAS :OF CUMBERLAND COUNTY, :PENNSYL VANIA v. :NO.06- CIVIL TERM STACEY LYNN FERRY, Defendant : CUSTODY AFFIDAVIT OF SERVICE BY MAIL I, Grace E. D'Alo, do hereby swear that I served Stacey Lynn Ferry with a Complaint For Custody on 7oSL1J- IL, 2006 by certified mail, return receipt, restricted delivery, to the person and address below: Stacey Lynn Ferry 3589 Orrstown Rd. Orrstown, P A 17244 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: ~ ~ \0 200la ./ :-....") -, w.., ( ~.:.:': ~.:-.... '-~J :-:\1 .-, :J: -n ~'r; r= .!'L I C:) o ~ ."'- r DAVID ALAN JOHNSON, Plaintiff v. :IN THE COURT OF COMMON PLEAS :OF CUMBERLAND COUNTY, :PENNSYL VANIA ; NO. 06- ~ <?"1f S CIVIL TERM STACEY LYNN FERRY, Defendant : CUSTODY AFFIDA VII OF SERVICE BY MAIL I, Grace E. D' Alo, do hereby swear that I served Stacey Lynn Ferry with a Petition for Special Relief on~, 2006 by certified mail, return receipt, restricted delivery, to the person and address below: Stacey Lynn Ferry 3589 Orrstown Rd. Orrstown, PAl 7244 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. D,'" '}~ 10 2CUo S;",~'re -dk n ,-- r-<:J. C:~_.) c:.:;l c.,." .;.ci-1 ---1 T hl c '. i!J ~~ DAVID ALAN JOHNSON PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 06-3895 CIVIL ACTION LAW STACEY LYNN FERRY DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, July 21, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, AUKust 16, 2006 , the conciliator, 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 hearin\!. FOR THE COURT, By: /s/ Hubert X. Gilroy, Esq. ~ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For infonnation 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 (7 J 7) 249-3 I 66 ,....., . 'T! ~1jY -# ~_~ ~ 1o./~c. ~ ~ r~~""" ~l(. "JC>-J'(!'-( '$7 ~ /~'l1tV ~ -p?J '?O-te-L A.L"'''o, ,. c'w'''. -.",11 );J (' ('I '-'1' J I ,_^, < 'L~, '.,.:J I ";1 ~')ni~ '... ".L :,:,Hl 7 , , ~r::[EiVED JUL 12 ~OC6 f' , '. o DAVID ALAN JOHNSON, IN THE COURT OF COMMON PLEAS OF o Plaintiff CUMBERLAND COUNTY PENNSYLVANIA NO. 06. ~IVIL TERM YS. STACEY LYNN FERRY, Defendant IN CUSTODY ~ ORDER OF COURT AND NOW, this ~ day of :r~ ': &:,~ ~sideration of the Petition for Special Relief, the following order is entered: 1. ];)ef@Baant iB 8rilenil t8 iRUBeili.lidJ ,~l~u 111@ ekilil, rIInl~R J9IR!&9U, i6 $he ~......lvdJ vf ~t.... Pla:ul:ff.T .ltl...!ll, ..~J-...~ JvLu;)v.ll. 2. Plaintiff, Alan Johnson shall have primary physical and shared legal custody of the children; 3. Defendant is enjoined from removmg the child from Cumberland County, Pennsylvania. 4. Defendan~is ord red t~ appear before ~'u! )t .u . lfL}., day of agre(~:~ ;::tjdY and visita on schedule. this Court's appointed conciliator 06, to develop a mutually a.t-IO: 3B Jj./J1. J. Grace E. D' Alo, Attorney at Law MidPenn Legal Services 401 E. Louther St. Carlisle, PA 17013 ~~~ ~""'tl" flM...:(<4 1-;}. 'f, 0 I,. 9-. (:.. '. . " rJd -':~~Vt1J (,," ','", 11\'1 '.7. '.1'" h)"lZ - '.. I'L... (11 :;iJ: , ... RECEIVED AUG 2 3 2006 ,q7y- l DAVID ALAN JOHNSON, Plaintift' : IN THE COURT OF CO CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 06-3895 CIVIL ACTION - LAW STACEY LYNN FERRY, Defendant IN CUSTODY COURT ORDER AND NOW, this ;;fez ~day of August, 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as foDows: 1. A hearing is scheduled in Courtroom No.3 of the Cumberland County Courthouse on the d7-tf1. day of S~ ,2006 at /."()O -I. m. At this hearing the Father shall be the moving party and shaD proceed initially witJi testimony. Counsel for the parties, or the parties themselves if they do not have an attorney, shall fIle with this Court and opposing counsel a Memorandum setting forth the history of custody in this case, the issues currently before the Court, a list of witnesses who wiD be caDed to testify on behalf of each party, and a summary of anticipated testimony of each witness. This Memorandum shaD be fIled at least five days prior to the mentioned hearing date. 2. Pending further order of this Court, the foDowing temporary custody Order is entered: A. The Father, David Alan Johnson, and the Mother, Stacey Lynn Ferry, shall enjoy shared legal and shared physical custody of Chance Jo~nson, born October 7, 1993. B. Physical custody shall be handled for the remainder of the summer with the Father having custody of the minor child from 9:00 a.m. on Saturday, August 19th through 5:00 p.m. on Friday, August 25th. Thereafter, Mother shall have custody of the minor child every weekend from Friday at 5:00 -, Cc: p.m. through Sunday at 7:00 p.m. Father shaD have custody of the minor child during the school week from Sunday at 7:00 p.m. through Friday at 5:00 p.m. 3. In the event Mother retains legal counsel prior to the hearing and her legal counsel believes another custody conciliation may aid in this case, counsel for the Mother may contact the Conciliator directly to schedule another conciliation conference. BY OURT, Edward E. Guido, Judge Grace D' Alo, Esquire A 1 9. () (. ,0 &, Ms. Stacey Lynn Ferry ~ 1">><'" ~<" 3589 Orrstown Road Q- Orrstown, P A 17244 \ 1 I \ \ \ \ \ \ \ \ \ \ " \ \ \ \ ~ . Vi~<\i!ft.\~:~;\]N3d I 'N('" , , .-, "'~'''n'' IU ' :\.,'': .' !>j'~:.dn IV 10 :21 Hd S- d3S 900l Atl\flONOHJ:C:C:d 3Hl :10 381:J!CHEill:l DAVID ALAN JOHNSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 06-3895 CIVIL ACTION - LAW STACEY LYNN FERRY, Defendant IN CUSTODY Prior Judge: The Honorable Edward E. Guido CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CML 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: Chance Johnson, born 10/07/1993 2. A Conciliation Conference was held on August 18, 2006 with the following individuals in attendance: The Mother, Stacey Lynn Ferry, appeared without counsel. The Father, David Alan Johnson, with his counsel, Grace D' Alo, Esquire 3. This situation deals with a 12 year old boy who will be starting 7th grade in the falL The young man has some issues. He is bi-polar, has been subject to probation over the past year or so, and has some other issues. The Mother had primary custody during most of the child's life, and for a period of time lived in Florida with the boy. In October of 2005, Mother delivered custody of the child to the Father, and the Father enjoyed primary custody up until June 29, 2006. Father suggests that the child did well with him, his grades improved, and that there were no siguificant behavioral issues. 4. In June of 2006, Father delivered the child to Mother for a period of temporary custody and Mother did not return the child at that point. Mother is now asserting primary custody and suggests that she believes that Father is somewhat abusive to the .. , -. child and that it is in the best interest of the child to be in the primary custody of the Mother. The Father acknowledges that he is a disciplinarian more so than the Mother, but suggests that the child needs this discipline and also suggests that the past year has been a proven track record to show that the child will do better in a more uniform environment. 5. Interestingly, both parents acknowledge that the child has indicated that he wants to be with the Mom one week and the Father one week. The parties live a few miles from each other, and a week-onlweek-oft' situation may be a good idea but there would be issues because the child is in a special needs school program and there are problems with busing and other similar matters. Father also asserts that the more uniform situation at his home during the school week would be better for the child. 6. The Mother is unwilling to agree and a hearing is required. However, an interim custody Order must be put in place pending a hearing. The Father volunteered at the conciliation conference to a resolution with the Father having custody during the school week and the Mother having custody every weekend. Although the Mother did not agree with this, the Conciliator is of the view that such an arrangement should be tried and may be a reasonable resolution of the issue. The Conciliator recommends such an OnJer pending a hearing. 7. The Conciliator recommends an Order in the form as attached. Date: August 0 ( . 2006 VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06.3895 CIVIL ACTION. LAW DA VID ALAN JOHNSON, Plaintiff STACEY LYNN FERRY, Defendant : IN CUSTODY STIPULATION OF PARTIES The parties in the above-captioned case hereby stipulate to the following order being entered: I. The Father, David Alan Johnson, and the Mother, Stacey Lynn Ferry, shall enjoy shared legal and shared physical custody of Chance Johnson, born October 7, 1993. II. Physical custody shall be handled for the remainder of the summer with the Father having custody of the minor child from 9:00 a.m. on Saturday, August 19th through 5:00 p.m. on Friday, August 25th. Thereafter, Mother shall have custody of the minor child every weekend from Friday at 5:00 p.m. through Sunday at 7:00 p.m. Father shall have custody of the minor child during the school week from Sunday at 7 :00 p.m. through Friday at 5:00 p.m. This Order is the same as the temporary custody Order entered by this Court on August 29, 2006. ~~~ 9 .~& ok> DA VID ALAN JOHNSON, FATHER Date 9 -Jk,-DLo Date I . DAVID ALAN JOHNSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA VS. No. 06-3895 CIVll.. TERM STACEY LYNN FERRY, Defendant IN CUSTODY AFFIDAVIT OF SERVICE I, Grace E. D' Alo of MidPenn Legal Services, do hereby swear that I served Stacey Lynn Ferry with the attached Stipulation of Parties and Order on September 27, 2006, by regular mail, U.S. First Class mail at the following address: Stacey Lynn Ferry 3589 Orrstown Road Orrstown, P A 17244 I verify that that the statements made in this Affidavit of Service are true and correct. Date: September 27,2006 ..". 'CcG- ~ ,tJ c:iJ " ) Gra e E. D' Alo A. ey for Plaintiff/ Petitioner MidPenn Legal Services 8 Irving Row Carlisle, P A 17013 r---:> c::-") c-:;") <:;;r' (/) rn -0 N -J o -n ~-n fi'p -g ill -1)0 'f ,.~~ ::.........0 ,'.- rn 91 1E :<. -0 ~ (.,) . DAVID ALAN JOHNSON, Plaintiff vs. STACEY LYNN FERRY, Defendant SEP 2 5 2006vKY' IN THE COURT OF COMMON PLEAS OF Y' CUMBERLAND COUNTY, PENNSYL VANIA : NO. 06-3895 CIVIL ACTION - LAW IN CUSTODY COURT ORDER JAA AND NOW, this ;)8 day of September, 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that the hearing scheduled in the above case on September 27, 2006 at 1:00 p.m. is cancelled. The temporary custody Order entered on August 29, 2006 shall remain in place. Cc: ~e D' Alo, Esquire ~Stacey Lynn Ferry 3589 Orrstown Road Orrstown, P A 17244 ~ BY THE CQ!JRI, .~ .-." , '"""'-. ./ ) Edw~rd E. Guido, Judge \/IN\/1\1 ~s~'.ir\r:Jd I ! I<.lr'V-''-o, '~, ....,,.,./i ' n"'l {\..:.r.J, :'1..,1,\ ~ ' -~,,-~t;(i'i V 91 :01 ~IV 62 d3S 900Z At1Vll:1\()1._.:..LC:,Ud 3Hl :10 jCj::t:-:{)~C1311:J y DAVID ALAN JOHNSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 06-3895 CIVIL ACTION - LAW STACEY LYNN FERRY, Defendant IN CUSTODY Prior Judge: The Honorable Edward E. Guido CONCILIATION REPORT The Conciliator was contacted by counsel for the Father in this case who represented that all parties agreed that the September 27,2006 hearing may be cancelled and the existing temporary Order may remain in place. The Conciliator recommends an Order in the form as attached. Date: September ~ , 2006 Hubert X. Gilr , Esquire Custody Cone . ator D . . ... - SEP 2 82005 r vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA : NO. 06-3895 CIVIL ACTION - LAW DA VID ALAN JOHNSON, Plaintiff STACEY LYNN FERRY, Defendant IN CUSTODY ORDER The following Order from the above-captioned case is permanently entered: I. The Father, David Alan Johnson, and the Mother, Stacey Lynn Ferry, shall enjoy shared legal and shared physical custody of Chance Johnson, born October 7, 1993. II. Physical custody shall be handled for the remainder of the summer with the Father having custody of the minor child from 9:00 a.m. on Saturday, August 19th through 5:00 p.m. on Friday, August 25th. Thereafter, Mother shall have custody of the minor child every weekend from Friday at 5:00 p.m. through Sunday at 7:00 p.m. Father shall have custody of the minor child during the school week from Sunday at 7:00 p.m. through Friday at 5:00 p.m. BY TJ.:IE, ,/~ L/" ,,,,,.- ~.,~~- r/J~ Edward E. Guido, Judge cc:~ce D' Alo, Esquire ~ /"'I:~' Stacey Lynn Ferry 3589 Orrstown Road Orrstown, P A 17244 ViNV/\l),Si'JN3d )J.' r 'Ilr,r, -.''c' '..,r-;)i\lnO . \\~ f,. ' ,. '..' ,'. -...,"t-,:, \11 I ,_,.; '-, .. " -.,.:. ~ 9 I :01 ~).v 62 d3S 900l I U\:il' rY.l:';,~1 ; ('~;-1 :Jill .10 1\0. -\....d ........: l............-''-~l...: -11 ...... j~:+:~O-G:J1Lj