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Home My WebLink About06-5537 . . KOPE & ASSOCIATES BY: LESLEYJ.BEAM,ESQ. ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com Attorney for Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA NO. C)(.. - .5S27 C.iuL'-r~ CIVIL ACTION - LAW IN CUSTODY SHAWN ADAMS, Plaintiff, JENNIFER ADAMS, Defendant. CUSTODY COMPLAINT 1. The Plaintiff is Shawn Adams residing at 122 Old Mill Drive, Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is Jennifer Adams residing at 776 Mount Rock Road, Shippensburg, Franklin County, Pennsylvania. 3. Plaintiff seeks primary physical and legal custody of the following children: NAME PRESENT RESIDENCE AGE Connor Adams 122 Old Mill Drive Camp Hill, PA 1 year D.O.8. 7/13/2005 4. Connor Adams (hereinafter the "child") was born in wedlock. 5. The child is presently residing with the Plaintiff. 6. During the past five years, the children have resided with the following persons and at the following addresses: PERSONS ADDRESSES DATES Shawn Adams Jennifer Adams 122 Old Mill Drive Camp Hill, PA 13051 Mongul Road Newberg, P A August 2006 - Present Shawn Adams Birth-August 2006 7. The mother of the child is Jennifer Adams, currently residing at 776 Mount Rock Road, Shippensburg, Franklin County, Pennsylvania. She is married. 8. The father of the child is Shawn Adams, currently residing at 122 Old Mill Drive, Camp Hill, Cumberland County, Pennsylvania. He is married. 9. The relationship of Plaintiff to the child is that of Father. The Plaintiff currently resides with the following persons: NAME RELATIONSHIP Joseph Adams Maureen Adams Father Mother Connor Adams Child 10. The relationship of Defendant to the child is that of Mother. It is unknown at this time with whom the Defendant currently resides. 11. Plaintiff has not participated as a party in previous litigation concerning the custody of the child. 12. Plaintiff does not know of a person not a party to the proceeding who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 13. Plaintiff is requesting primary legal and physical custody of the child. 14. Defendant's son, the child's half-brother (hereinafter the "half-brother"), recently faced juvenile proceedings after he choked and killed a dog. After such proceedings, the half-brother was sent to a mental facility. The half-brother is a real and constant threat to the child's safety. 15. Defendant disappeared for three weeks with the child, giving Plaintiff neither address nor phone where the child could be located. Plaintiff was only made aware of the child's location when the Defendant's friends, with whom she and the child were staying, called Plaintiffs parents for money for the child's keep. 16. Upon speaking with the Defendant's friends, who were keeping the child on a farm, Plaintiff learned that the child was only being given one bottle per day, and was being fed and nourished inadequately and inappropriately for a thirteen- month baby. Specifically, the child was being given caffeinated iced tea as a main staple to drink. 17. Defendant continues to move around from location to location, without establishing a home where the child would have constant surroundings and security. 18. Plaintiff is living in an apartment space connected to his parents' home. Plaintiffs father is a retired police officer and Plaintiffs mother is a special education teacher. Both Plaintiffs father and mother are willing and able to watch and care for the child when Plaintiff is working, and have been doing so. 19. The best interest and permanent welfare of the child will be served by the granting relief requested because: (a) The mental and emotional well being of the child will be served if he continues to live with the Plaintiff on a regular basis. (b) Plaintiff is able to provide a stable and safe home and emotional environment for the child; (c) Plaintiff has the facilities to provide for the care, comfort and control of the child, as well as the intention and desire to do so. 20. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff requests that this Honorable Court grant the following relief: (a) Award Plaintiff primary physical and legal custody of the child. Respectfully Submitted, Dated: ~ r~/oCo By: VERI FICA liON I, Shawn Adams, the Plaintiff in this matter, have read the foregoing Complaint. verify that my averments in this Complaint are true and correct and based upon my personal knowledge. I understand that any false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsifications to authorities. Dated: C\- \5 -0\0 ~€'''i'-~ n..,.~L~ Shawn Adams A:) 0 ~ \t ^ --.... ~ J...> n r--) ~ C'.;;:> . ~ c..? 0 0" :::::. (/) ~~ -- (), ("'l"l .~ -u "'"Q ~ N -om -J :06 w 0 .....-!.-:o r:: -0 ~c -i ~ 1J ,,) __1 3'. 8M 5U l- (i! ( .~ w ~ 0;) .. .'1' SHAWN ADAMS PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. 06-5537 CIVIL ACTION LAW JENNIFER ADAMS DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, September 27, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. at 39 West Main Street, Mecbanicsburg, PA 17055 on Tuesday, October 24, 2006 , the conciliator, at 12:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or ifthis 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: Isl Dawn S. Sunday, 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 ~~r.~~~ .~?~~~u, ~.~$ r~,P{l V1N\';\lASNt.j3d I ; ~ In"'. ".-' ,'~"" "-, ,..... ,...,. '^'n'" 1\-11 \. n ,> ,I :,' ,. < '. '.'-~. '--i'T:~H ~ V 20 :21 tld 62 d3S 900Z AtNJ.Oi'!CHLUbd 3H1 .:10 3;~;lj:!O'03ll::1 ")cJ -6c: - 6 ");7- 6e- /l 1t?'K - (; . . Shawn Adams, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-5537 CIVIL TERM Jennifer Adams, Defendant, : CIVIL ACTION : IN CUSTODY PRELIMINARY OBJECTIONS TO CUSTODY COMPLAINT, PURSUANT TO Pa.R.C.P. & 1028(a)(1) Defendant Jennifer Adams, files these preliminary objections pursuant to Pa.R.C.P. No. 1 028( a) (1 ) and in support thereof avers the foHowing: 1. The instant matter before the Court is a custody action. 2. On September 21, 2006, Plaintiff Shawn Adams filed a Custody Complaint against Defendant Jennifer Adams in the Court of Common Pleas of Cumberland County, Pennsylvania, seeking custody of Connor Adams, born July 13, 2005 (see attached "Exhibit A"). 3. Defendant Jennifer Adams was served with a copy of the Custody Complaint on October 9, 2006. 4. Paragraph Six of the Custody Complaint avers that the child, Connor Adams, has resided at 122 Old Mill Road, Camp Hill, Cumberland County, Pennsylvania for approximately two months, since August of2006. 5. Paragraph Six of the Custody Complaint also avers that both parties and the child, Connor Adams, resided at 13051 Mongul Road, Newberg, Franklin County, Pennsylvania, for a thirteen-month period from the child's birth to August of2006. 6. Pursuant to 23 Pa.C.S. ~ 5421(a)(1), 23 Pa.C.S. S 5471 and Pa.R.C.P No.1915.2(a)(1)(i), a custody action may only be filed if a court has jurisdiction to make an initial child custody determination. A court has jurisdiction only if the county is the home county ,- of the child on the date of the commencement of the proceeding, or was the home county of the child within six months before the commencement of the proceeding. 7. Pursuant to 23 Pa.C.S. S 5402 and 23 Pa.C.S. S 5471, and Pa.R.C.P. No. 1915.1(b), home county means the county in which the child lived with a parent for at least six consecutive months immediately before the commencement of a child custody proceeding. 8. Neither party resided in Cumberland County with the child for a period of six consecutive months. Therefore, the Court of Common Pleas of Cumberland County lacks jurisdiction over this matter. 9. The proper venue for this custody action is Franklin County, Pennsylvania: because both parties and the child resided in Franklin County for a period of more than six consecutive months immediately prior to the commencement of the child custody proceeding, the Court of Common Pleas of Franklin County has jurisdiction over this custody matter. 10. Defendant Jennifer Adams, through her counsel, Franklin County Legal Services, filed a Complaint for Custody in the Court of Common Pleas of Franklin County on September 27,2006, seeking custody of both of the parties' children, Connor Adams, born July 13,2005 and Cayden Adams, born September 18,2006. 11. The judge assigned to the Complaint for Custody filed in the Franklin County Court of Common Pleas is the Honorable Richard 1. Walsh. WHEREFORE, Defendant Jennifer Adams respectfully requests that this Court dismiss the Custody Complaint filed September 21, 2006 so that the custody action may proceed in the court with proper jurisdiction. /OAft>6 Respectfully Submitted, ~1I1t~ Kathleen N. McKeown Certified Legal Intern Date: 4kt' . PLACE ROBERT . RAINS ~/ LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 VERIFICATION I verify that the statements made in the foregoing Preliminary Objections to Custody Complaint are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. f-q~o~ ~I~~ fenni:6 Adams Date ~ Shawn Adams, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VB. : NO. 06-5537 CIVIL TERM Jennifer Adams, Defendant, : CIVIL ACTION : IN CUSTODY CERTIFICATE OF SERVICE I, Kathleen N. McKeown, Family Law Clinic, hereby certify that I am serving a true and correct copy of Defendant's Preliminary Objections to Custody Complaint, pursuant to Pa.R.C.P. S 1028(a)(l) on Lesley J. Beam, Esquire, counsel for Plaintiff, at 4660 Trindle Road, Suite 201, Camp Hill, PAl 70 11 via facsimile and U. S. mail, first class on October 9, 2006. $uJ!.1lt;(~ FAMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 ~:; <:::'.J ..::1-' I \..0 (') ':n --I _C\_ ---n r-'l ~".n T~-' "..--1 ,---', \,' ' c' ) - -'"I ,'t' 0' .., "',i'n ~~~ ,)v .< c...J Shawn Adams, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Vlll. : NO. 06-5537 CIVIL TERM Jennifer Adams, Defendant, : CIVIL ACTION : IN CUSTODY ORDER OF COURT AND NOW, this 1.1 ~ day of October, 2006, upon consideration of Preliminary Objections to Custody Complaint filed by the Defendant, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Plaintiff to show cause why the Defendant should not be granted the relief requested; 2. The Plaintiff will file an answer on or before N()\le.~\ot.t' 10 ,2006; 3. Ifno answer to the Rule to Show Cause is filed by the required date, the relief requested by the Defendant shall be granted upon the Court's receipt of a Motion Requesting Rule Be Made Absolute. If the Plaintiff files an answer to this Rule to Show Cause, and the answer raises disputed issues of material fact, an evidentiary hearing will then be scheduled on the earliest available date. The Prothonotary is directed to forward said Answer to this Court. BY THE COURT, ~~~~ J. \/f!\Jvt;\l}~S~\:~\Jjd I t "'nr'" <, "", '~"'~"'In'" I\.,.U "'; :'~ ),! ., ::'!'~:,j-.,jl \t .J SO :~ Hd L2 1JO 900l .. l\ ,,~" "" . -'41 'e .l h{11 j i.'\:. ~!"( ".*i..... t f\ULJ.......)!'....), ..Jl-.i. ?i8i+'i)..C31!.:J KOPE & ASSOCIATES, LLC BY: LESLEYJ. BEAM, ESQ. ATTORNEY 1.0.91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com Attorney for Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA NO. 06-5537 SHAWN ADAMS, Plaintiff, JENNIFER ADAMS, Defendant. CIVIL ACTION - LAW IN CUSTODY MOTION FOR LEAVE TO WITHDRAW AS COUNSEL AND NOW comes, Lesley J. Beam, Esquire and Kope & Associates, LLC, and files the following Motion for Leave to Withdraw as Counsel and in support thereof avers as follows: 1. Movant is Lesley J. Beaml Esquire and Kope & Associates, LLC who are presently counsel of record for Plaintiff, Shawn Adamsl in the above-captioned action. 2. Respondent is Shawn Adams, Plaintiff, in the above-captioned action. 3. Movant has represented Respondent, Shawn Adams, pursuant to the above docketed custody action since September 1,2006. 4. During the course of Movant's representation of Respondent, they have been unable to communicate and agree as to the course that the case shall take. 5. Respondent has failed to respond to Movant's significant attempts to contact him regarding his case and the Rule to Show Cause that was due to be filed. Respondent has also failed to keep Movant informed regarding the issues of the case. 6. Respondent has undermined Movant's ability to competently represent him. 7. Respondent has also not failed to pay his full retainer as agreed upon under the Fee Agreement signed by Respondent on September 2, 2006. Respondent has been reminded by both letters and phone calls and has not responded to requests for the full retainer. 8. The last communication with Respondent was at the beginning of November when Respondent indicated to the office that he would bring the remainder of the retainer due into the office in the following couple of days. Respondent never appeared at the office, and Movant has been unable to contact Respondent since that time. 9. Movant's withdrawal as counsel for Respondent will have no material adverse effect on Respondent's interests pursuant to Pennsylvania Rule of Professional Conduct 1.16. 10. Movant, Lesley J. Beam, Esquire and Kope & Associates, LLC, respectfully requests that they be allowed to withdraw as counsel for Respondent due to all of the above and the resulting breakdown in the attorney/client relationship. WHEREFORE, Movant respectfully requests that this Honorable Court permit Lesley J. Beam, Esquire and Kope & Associates, LLC, to withdraw as counsel for Respondent, Shawn Adams. Respectfully submitted, CERTIFICATE OF SERVICE I, Lesley J. Beam, Esquire, hereby certify that on November 20, 2006, I served a copy of the within Motion by depositing the same in the United States Mail, first class, postage prepaid in Camp Hill, Pennsylvania, addressed as follows: Kathleen N. McKeown Anne McDonald-Fox Family Law Clinic 45 N. Pitt Street Carlisle, PA 17013 Attorneys for Defendant Respectfully Submittedl KOPE & ASSOCIATES, LLC ~/;/' /7 ~ By: / / (I /lhe--__ t>/tesle~ . earn, Esquire 4660 rindle Road Suite 201 Camp Hill, PA 17011 (717) 761-7573 --4 ...,... _-1.- ( '~-t 0) C'.' -1'-: ...--'" r- , I " SHAWN ADAMS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LA W IN CUSTODY JENNIFER ADAMS, Defendant No. 06-5537 MOTION TO MAKE RULE ABSOLUTE UNDER Pa.R.C.P. No. 206.7 Defendant, Jennifer Adams, by and through her attorneys, the Family Law Clinic, petitions the Court as follows: 1. On September 21, 2006, Plaintiff filed a Complaint for Custody in the Court of Common Pleas of Cumberland County, Pennsylvania. 2. On October 9, 2006, Defendant filed Preliminary Objections to Custody Complaint pursuant to Pa.R.C.P. S 1028(a)(1) alleging that the Court of Common Pleas of Cumberland County, Pennsylvania, lacks jurisdiction over the above-captioned matter. A copy of the Preliminary Objections to Custody Complaint is attached hereto and incorporated herein by reference as Exhibit "A." 3. On October 27, 2006,. this court issued an Order of Court - Rule to Show Cause. A copy of the Order of Court - Rule to Show Cause is attached hereto and , '-. incorporated herein by reference as Exhibit "B." 4. A true and correct copy of the Preliminary Objection to Custody Complaint was served upon counsel for Plaintiff, Lesley 1. Beam, Esq., by first class mail, postage prepaid, at 4660 Trindle Road, Carnp Hill, PA 17011, on October 9, 2006. 5. A true and correct copy of the Order of Court - Rule to Show Cause was mailed to counsel for Plaintiff, Lesley 1. Beam, Esq., by first class mail, postage prepaid, at 4660 Trindle Road, Camp Hill, P A 17011, on October 28, 2006 . 6. The October 27, 2006, Order of Court - Rule to Show Cause permitted Plaintiff, Shawn Adams, to respond to the Preliminary Objections to Custody Complaint by filing an answer to the Preliminary Objections on or before November 20,2006. 7. Plaintiff did not respond to the October 27, 2006 Order of Court - Rule to Show Cause by filing an Answer on or before November 20, 2006. 8. Pursuant to C.C.R.P. 208.2(d), the concurrence of opposing counsel, Lesley J. Beam, Esq., has been sought. Opposing counsel does not concur. WHEREFORE, Defendant requests this Court to respond to Defendant's Preliminary Objections by issuing am Order dismissing the Complaint for Custody filed by Plaintiff on September 21, 2006. Respectfully, Date: /1/7-//0(; /' ,I , ~ ) ~ THO ROBERT . RAINS LUCY JOHNSTON- WALSH ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys F AMIL Y LA W CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 VERIFICATION I verify that the statements made in the foregoing document 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 nllsification to authorities. Date: 1/ )7/ / D0- / I Krist Ann Freego Certified Legal Intern 1 Shawn Adams, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 06-5537 CIVIL TERM v. Jennifer Adams, Defendant, : CIVIL ACTION : IN CUSTODY (') c <:. J2 c;; ~ I ~ 1 ; -~7 ". ~~.- -!.. PRELIMINARY OBJECTIONS TO CUSTODY COMPLAINT, PURSUANT TO Pa.R.C.P. & 1028(a)(1) :"'r'J _~ -<: I""'-~~ -~ ....."-" j:~'~ ~ .-< Defendant Jennifer Adams, Diles these preliminary objections pursuant to Pa.R.C.P. No. 1028( a)(1) and in support thereof avers the following: 1. The instant matter before the Court is a custody action. 2. On September 21,2006, Plaintiff Shawn Adams filed a Custody Complaint against Defendant Jennifer Adams in the Court of Common Pleas of Cumberland County, Pennsylvania, seeking custody of Connor Adams, born July 13, 2005 (see attached "Exhibit A"). 3. Defendant Jennifer'Adams was served with a copy of the Custody ,Complaint on October 9, 2006. 4. Paragraph Six of the Custody Complaint avers that the child, Connor Adams, has resided at 122 Old Mill Road, Camp Hill, Cumberland County, Pennsylvania for approximately two months, since August of 2006. 5. Paragraph Six of the Custody Complaint also avers that both parties and the child, Connor Adams, resided at 13051 Mongul Road, Newberg, Franklin County, Pennsylvania, for a thirteen-month period from the child's birth to August of 2006. 6: Pursuant to 23 Pa.C.S. S 5421(a)(1), 23 Pa.C.S. S 5471 and Pa.R.C.P No.1915.2(a)(l)(i), a custody action may only be filed if a court has jurisdiction to make an initial child custody determination. A court has jurisdiction only if the county is the home county r--.,) = c:;) er' a CJ -I I \.0 o -n :;:J n1 ::n r :9, mo - ~.... 9(1) --~ -')', f'~- -r"i :.;:2t=:i ~-rn () s;! ::0 -< -0 3:: (",.) w , of the child on the date of the commencement of the proceeding, or was the home county of the child within six months before the commencement of the proceeding. 7. Pursuant to 23 Pa.C.S. ~ 5402 and 23 Pa.C.S. ~ 5471, and Pa.R.C.P. No. 1915.1 (b), home county means the county in which the child lived with a parent for at least six consecutive months immediately before the commencement of a child custody proceeding. 8. Neither party resided in Cumberland County with the child for a period of six consecutive months. Therefore, the Court of Common Pleas of Cumberland County lacks jurisdiction over this matter. 9. The proper venue for this custody action is Franklin County, Pennsylvania: because both parties and the child resided in Franklin County for a period of more than six consecutive months immediately prior to the commencement of the child custody proceeding, the Court of Common Pleas of Franklin County has jurisdiction over this custody matter. 10. Defendant Jennifer Adams, through her counsel, Franklin County Legal Services, filed a Complaint for Custody in the Court of Common Pleas of Franklin County on September 27,2006, seeking custody of both of the parties' children, Connor Adams, born July 13,2005 and Cayden Adams, born September 18, 2006. 11. The judge assigned to the Complaint for Custody filed in the Franklin County Court of Common Pleas is the Honorable Richard J. Walsh. WHEREFORE, Defendant Jennifer Adams respectfully requests that this Court dismiss the Custody Complaint filed September 21, 2006 so that the custody action may proceed in the court with proper jurisdiction. Date: Respectfully Submitted, loAA>6 ~1I11. Kathleen N. McKeown Certified Legal Intern ~~ :'PLACE ROBERT . RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys F AMIL Y LA W CLINIC 45 North Pitt Street Carlisle, PAl 7013 (717) 243-2968 VERIFICATION I verify that the statements made in the foregoing Preliminary Objections to Custody Complaint are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. 9,q-o~ ~f:f~ jennifl Adams Date Shawn Adams, Plaintiff, Vll. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-5537 CIVIL TERM Jennifer Adams, Defendant, : CNIL ACTION : IN CUSTODY CERTIFICATE OF SERVICE I, Kathleen N. McKeown, Family Law Clinic, hereby certify that I am serving a true and correct copy of Defendant's Preliminary Objections to Custody Complaint, pursuant to Pa.R.C.P. ~ 1028(a)(l) on Lesley 1. Beam, Esquire, counsel for Plaintiff, at 4660 Trindle Road, Suite 201, Camp Hill, P A 17011 via facsimile and U.S. mail, first class on October 9, 2006; ;tJ/Jwull jj!c~~ F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Shawn Adams, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA viii. : NO. 06-5537 CIVIL TERM Jennifer Adams, Defendant, : CIVIL ACTION' : IN CUSTODY ORDER OF COURT ~ AND NOW, this 1.1 d~y of October, 2006, upon consideration of Preliminary Objections to Custody Complaint filed. by the Defendant, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Plaintiff to show cause why the Defendant should not be granted the relief requested,; 2. The Plaintiff will file an answer on or before NO\le.M.\4U" 10 ,2006; 3. If no answer to the Rule to Show Cause is filed by the required date, the relief requested by the Defendant shall be granted upon the Court's receipt ofa Motion Requesting Rule Be Made Absolute. If the Plaintiff files an answer to this Rule to Show Cause, and the answer raises disputed issues of material fact, an evidentiary hearing will then be scheduled on the earliest available date. The Prothonotary is directed to forward said Answer to this Court. BY THE COURT, ~~W ... . J. Cj r-<) IJ _.....~ C c:''::;> -n ..-: 0........ ,'" --:1 1'.) -r) N U1 ::0 -<. (.0) --<;: SHAWN ADAMS, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5537 CIVIL V. CIVIL ACTION - LAW JENNIFER ADAMS, DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 22nd day of November, 2006, upon consideration of the Motion for Leave to Withdraw as Counsel filed by the Petitioner, IT IS HEREBY ORDERED AND DIRECTED that: .. 1. A Rule is issued upon the Parties to show cause why the Petitioner should not be granted permission to withdraw as counsel of record; 2. The Parties will file an answer on or before December 15, 2006; 3. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Petitioner shall be granted upon the Court's receipt of a Motion requesting Rule be made Absolute. If the Parties file an answer to this Rule to Show Cause, and the answer raises disputed issues of material fact, an evidentiary hearing will then be scheduled. The Prothonotary is directed to forward said Answer to this Court. 4. Notice of entry of this order shall be provided to all parties by the Petitioner. By the Court, Shawn Adams, Plaintiff ~Ieen N. McKeown, ell Anne MacDonald-Fox, Esquire Attorney for Defendant ~ ~'t~ k'ey J. Beam, Esquire Petitioner M. L. Ebert, Jr., J. bas 6S .'~ .t~ II I 1:"'_'('. I, _ "Z MVJ C:-n7 (, J _ ~t,"'l JV"-,W SHAWN ADAMS, Plaintiff v. JENNIFER ADAMS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LA W IN CUSTODY No. 06-5537 ORDER OF COURT "'~ AND NOW, this 18 day of November, 2006, upon consideration of the attached Motion to Make Rule Absolute, the Custody Complaint filed September 21, 2006 is dismissed. BY THE COURT, ~'t~ M. L. Ebert Jr., Judge NOV 22 200fif VIN\iI\lASNN3d A1NnO:J C1r,~'.n~+::;8~n:> 92: II WV BZ AON 900Z Ab'\I10NOHJ.Ocd 3H1 :10 3:)!j:;lO-<ElH \ DEe 0 8 20tv Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHAWN ADAMS Ys. 06-5537 CIVIL ACTION LAW JENNIFER ADAMS Defendant IN CUSTODY ORDER AND NOW, this 4TH day of December. 2006 , the conciliator, having been notified that the Preliminary Objection has been resolved and that no further conciliations proceedings are necessary, hereby relinquishes jurisdiction. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator \-i!r.i W'j J, ("'I~ f"d I,. 'i 'VI \ ,/ \!...,,"; '~f '\.:l' JUNrU: ('::\(i,.i:;8V~n8 20 :01 ~J'1 21 :330900Z HMli',',I('Y'll(\' 'd :l'Hl' :10 ^U I' ..'vl 'hA ,~,tl .J ..,,.,\ ! "~ C'31lj .'V'I"'11 r' I ......l ..-.J_ "", '.... i KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQ. ATTORNEY 1.0. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com Attorney for Plaintiff SHAWN ADAMS, Plaintiff, vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA NO. 06-5537 JENNIFER ADAMS, Defendant. CIVIL ACTION - LAW IN CUSTODY MOTION TO MAKE RULE ABSOLUTE AND NOW, comes Petitioners Lesley J. Beam, Esquire, and Kope & Associates, LLC and motions this Court to make absolute the Order that it issued in this matter on November 22, 2006, and in support of said Motion states as follows: 1. On November 20, 2006, Petitioners filed with this Court a Motion For Leave to Withdraw as Counsel. 2. On November 22,2006, this Honorable Court, by Judge M. L. Ebert, Jr., issued a Rule to Show Cause, ruling the parties to show cause why Petitioner's Motion For Leave to Withdraw as Counsel should not be granted. A true and correct copy of said Rule to Show Cause is attached hereto and incorporated herein as Exhibit "A". 3. The Order/Rule was returnable by December 15, 2006. 4. It is past December 15, 2006 and the parties have filed no response to the Rule to Show Cause. WHEREFORE, Petitioners Lesley J. Beam, Esquire and Kope & Associates, LLC, respectfully requests that this Court make absolute the Rule to Show Cause it issued on November 22, 2006 and grant their Motion For Leave to Withdraw as Counsel. Respectfully Submitted, By: 5'-- Date: CERTIFICATE OF SERVICE I, Lesley J. Beam, Esquire, of Kope & Associates, LLC, hereby certify that on December 19, 2006 a true and correct copy of the foregoing Motion to Make Rule Absolute was served upon the below-referenced individuals at the address listed by way of first class mail, postage pre-paid: Kathleen N. McKeown Certified Legal Intern Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 ,SHAWN ADAMS, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 06-5537 CIVIL : CIVIL ACTION - LAW JENNIFER ADAMS, DEFENDANT : IN CUSTODY ORDER OF COURT AND NOW, this 22nd day of November, 2006, upon consideration of the Motion for Leave to Withdraw as Counsel filed by the Petitioner, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Parties to show cause why the Petitioner should not be granted permission to withdraw as counsel of record; 2. The Parties will file an answer on or before December 15, 2006; 3. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Petitioner shan be granted upon the Court's receipt of a Motion requesting Rule be made Absolute. If the Parties file an answer to this Rule to Show Cause, and the answer raises disputed issues of material fact, an evidentiary hearing wUl then be scheduled. The Prothonotary is directed to forward said Answer to this Court. 4. Notice of entry of this order shall be provided to all parties by the Petitioner. By the Court, \\'tuj M. L. Ebert, Jr., J. Lesley J. Beam, Esquire Petitioner Shawn Adams, Plaintiff Kathleen N. McKeown, CLI Anne MacDonald-Fox, Esquire Attorney for Defendant bas ~ EXHIBIT (!l ~ ~ w !;( ~ ~ .... -- KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQ. ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com Attorney for Plaintiff SHAWN ADAMS, Plaintiff, vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA NO. 06-5537 JENNIFER ADAMS, Defendant. CIVIL ACTION - LAW IN CUSTODY MOTION TO MAKE RULE ABSOLUTE AND NOW, comes Petitioners Lesley J. Beam, Esquire, and Kope & Associates, LLC and motions this Court to make absolute the Order that it issued in this matter on November 22, 2006, and in support of said Motion states as follows: 1. On November 20, 2006, Petitioners filed with this Court a Motion For Leave to Withdraw as Counsel. 2. On November 22,2006, this Honorable Court, by Judge M. L. Ebert, Jr., issued a Rule to Show Cause, ruling the parties to show cause why Petitioner's Motion For Leave to Withdraw as Counsel should not be granted. A true and correct copy of said Rule to Show Cause is attached hereto and incorporated herein as Exhibit "A". 3. The Order/Rule was returnable by December 15, 2006. 4. It is past December 15, 2006 and the parties have filed no response to the Rule to Show Cause. .~ WHEREFORE, Petitioners Lesley J. Beam, Esquire and Kope & Associates, LLC, respectfully requests that this Court make absolute the Rule to Show Cause it issued on November 22, 2006 and grant their Motion For Leave to Withdraw as Counsel. Respectfully Submitted, By: Date: . , CERTIFICATE OF SERVICE I, Lesley J. Beam, Esquire, of Kope & Associates, LLC, hereby certify that on December 19, 2006 a true and correct copy of the foregoing Motion to Make Rule Absolute was served upon the below-referenced individuals at the address listed by way of first class mail, postage pre-paid: Kathleen N. McKeown Certified Legal Intern Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 ."'f ,SHAWN ADAMS, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. JENNIFER ADAMS, DEFENDANT : NO. 06-5537 CIVIL : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 22nd day of November, 2006, upon consideration of the Motion for Leave to Withdraw as Counsel filed by the Petitioner, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Parties to show cause why the Petitioner should not be granted permission to withdraw as counsel of record; 2. The Parties will file an answer on or before December 15,2006; 3. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Petitioner shaU be granted upon the Court's receipt of a Motion requesting Rule be made Absolute. If the Parties file an answer to this Rule to Show Cause, and the answer raises disputed issues of material fact, an evidentiary hearing will then be scheduled. The Prothonotary is directed to forward said Answer to this Court. 4. Notice of entry of this order shall be provided to all parties by the Petitioner. By the Court, ~tuj M. L Ebert, Jr., J. Lesley J. Beam, Esquire Petitioner Shawn Adams, Plaintiff Kathleen N. McKeown, ell Anne MacDonald-Fox, Esquire Attorney for Defendant bas ~ EXHIBIT Cl~ ~ ~ ~ ' ... DEe J 1 ZODB#! KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQ. ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com Attorney for Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA NO. 06-5537 SHAWN ADAMS, Plaintiff, JENNIFER ADAMS, Defendant. CIVIL ACTION - LAW IN CUSTODY ORDER n~ ~ Z AND NOW, this k day of J b.."~&..f"t--' 2001, on consideration of the Petitioner's Motion For Leave to Withdraw as Counsel, it is hereby ORDERED and DIRECTED that Petitioner's Petition is GRANTED. BY THE COURT: ~.irtS, ~\