HomeMy WebLinkAbout06-6227
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4. The Children were not born out of wedlock.
5. The Children are presently in the custody of the Plaintiff who resides at 8 South 15th
Street, Camp Hill, PA.
6. During the past five years, the Children have resided with the following persons and
at the following addresses:
PERSONS ADDRESSES DATES
Alan B. McCausland 8 South 15th Street 10/25/06 to
Camp Hill, PA present
Alan B. McCausland 122 South rh Street 10/1/01 to
Lemoyne, PA 10/26/06
Nancy C. McCausland 135 North 17th Street 2006-10/06
Camp Hill, PA
Nancy C. McCausland 43 W. South Street 2002 or 2003 to
Carroll Kramer Carlisle, PA 2006
Nancy C. McCausland Carlisle, P A 2000 to 2002 or
Anita McCoy 2003
Jay McCoy
7. The mother of the children is Nancy C. McCausland currently residing at 135 North
1rh Street, Camp Hill, PA.
8. The mother is married.
9. The father of the children is Alan B. McCausland currently residing at 8 South 15th
Street, Camp Hill, PA.
10. The father is married.
11. The relationship of Plaintiff to the children is that of Father.
12. The Plaintiff currently resides with the following persons:
- 2 -
. '
NAMES RELATIONSHIP
Hannah A. McCausland Daughter
Sarah E. McCausland Daughter
13. The relationship of Defendant to the children is that of mother.
14. The Defendant currently resides with the following persons:
None
RELATIONSHIP
N/A
NAMES
15. Plaintiff has not participated as a party or witness, or in another capacity, in other
litigation concerning the custody of the children in this or another court.
16. Plaintiff has no information of a custody proceeding concerning the children pending
in a Court of this Commonwealth.
17. Plaintiff does not know of a person not a party to the proceedings who has physical
custody of the children or claims to have custody or visitation rights with respect to
the children.
18. The best interest and permanent welfare of the children will be served by granting
the relief requested because:
a. Plaintiff-Father is better able to provide for the physical, educational and
emotional needs of the Children.
B. Defendant-Mother suffers from obsessive compulsive disorder as a result of
which she cannot provide a suitable home for the children.
19. Each parent whose parental rights to the children have not been terminated and the
person who has physical custody of the children have been named as parties to this
action.
- 3 -
. .,
WHEREFORE, Plaintiff requests the Court to grant:
* Shared LegaL custody of the children to the parties
* Primary physical custody of the children to Plaintiff-Father;
* Partial physical custody of the children to Defendant-Mother with no
overnight visits in her home until she gets it cleaned and orderly.
Respectfully submitted,
L F, ESQUIRE
344 Jrind d
Camp Hill, PA 17011
Phone: (717) 737-0100
Fax: (717) 975-0697
ID No. 32112 J
Date: \ b J :l,f;; / 6 (/J
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VERIFICATION
I verify that the statements made in this Custody Complaint are true and correct.
I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
4904 relating to unsworn falsification to authorities.
Date: 16(2%/6 ~
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ALAN . McCAUSLAND
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Type of Pleading: Petition for Emergency Relief
Prepared By:
Diane G. Radcliff, Esquire
3448 Trindle Road
Camp Hill, PA 17011
Supreme Court I D # 32112
Phone: 717-737-0100
Fax: 717.975-0697
Email: dianeradcliff@comcast.net
Attorney for Alan B. McCausland
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ALAN B. McCAUSLAND
Plaintiff
NO.
CIVIL TERM
v.
CIVIL ACTION - LAW
NANCY C. McCAUSLAND
Defendant
IN CUSTODY
PETITION FOR EMERGENCY RELIEF
1. The Petitioner is Alan B. McCausland, who is or will be residing at 8 South 15th
Street, Camp Hill, Cumberland County, PA. Alan B. McCausland is hereinafter
referred to as ttFather".
1. The Respondent is Nancy C. McCausland, residing at 135 North 17th Street, Camp
Hill, Cumberland County, PA. Nancy C. McCausland is hereinafter referred to as
UMother" .
2. The parties are husband and wife.
3. The parties are the parents of two minor children, to wit:
* Hannah A. McCausland, age 14, born 5/9/1992
* Sarah E. McCausland, age 11, born 7/4/1995.
2
4. Petitioner has filed a Custody Complaint concurrently herewith in which he is
seeking custody of the Children, Hannah A. McCausland and Sarah E. McCausland,
hereinafter referred to as the "Children".
5. The is no custody order entered in this or any other jurisdiction regarding the
Children.
6. Up until recently the parties have been sharing physical custody of the Children.
Sometimes Father had a greater period of custody and sometimes mother has a
greater period of custody.
7. Earlier in 2006 Mother moved back to her current residence located at 135 North
1 rh Street, Camp Hill, PA where she resided with the children (the children lived
at this residence on an approximate Y2 time basis).
8. Mother suffers from obsessive compulsive disorder which makes her unable to
throw anything away and results in her accumulating trash and other items.
9. Father just recently learned that due to Mother's mental disorder the residence
which she was providing for the children was in a state of disrepair, was strew
with trash and other items and was generally not a suitable, healthful and/or safe
environment for the children.
10. Pictures of the interior of Mother's home located at 135 North 17th Street, Camp
Hill, PA are attached hereto, marked Plaintiff's Ex 1-A through 1-H and made a
part hereof.
11. Father believes that the Children's health and safety would be in jeopardy if they
were permitted to stay with Mother at her residence overnight.
12. When Father has attempted to stop Mother from taking the Children, she has
created such a scene that he has been forced to flee his home and hide with the
Children just to stop her yelling and screaming in front of the children and to
prevent her from entering into his home.
Wherefore, Father respectfully requests this Honorable Court to enter an order granting
3
him primary physical custody of the Children subject to limited partial physical custody
rights for mother as set forth on the attached proposed order.
Respectfully submitted,
L1FF, ESQUIRE
e Road
Camp Hill, PA 17011
Phone: (717) 737-0100
Supreme Court 10 # 32112
Attorney for Petitioner, Alan B. McCausland
4
VERIFICATION
I verify that the statements made in the foregoing Petition for Emergency Relief
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.
ALAN B. McCAUSLAND
!O/x/6b
,
DATED:
5
CERTIFICATE OF SERVICE
I, DIANE G. RADCLIFF, ESQUIRE, hereby certify that on O(!.,T()8e1l 2&, ~o(J) ,
served a true and correct copy of the Petition for Emergency Relief upon the
Defendant, Nancy C. McCausland, by mailing same by first class mail, postage prepaid,
addressed as follows:
Nancy B. McCausland
1 35 North 17th Street
Camp Hill, PA 17011
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FILED
MAY 2,200611:42 AM
Jennifer Wertz
: IN THE COURT OF COMMON
: PLEAS OF HUNTINGDON
: COUNTY, PENNSYL VANIA
Plaintiff
v.
: CIVIL DIVISION - LA W
Chad Rhoades
; O/s. -(.,2;H. (!tc.><-L'7-~
: No. 2006-591
Defendant
FINAL ORDER OF COURT
Defendant's Name: Chad Rhoades
Defendant's Date of Birth: December 7,1976
Names and Dates of Birth of All Protected Persons, including Plaintiff and minor
children:
Names
1. JenniferVVenz
Dates of Birth
September 9,1979
Plaintiff or Protected Person(s) is/are:
[] spouse or former spouse of Defendant
[] parent of a common child with Defendant
[X] current or former sexual or intimate partner with Defendant
[] child of Plaintiff
[] child of Defendant
[] family member related by blood (consanguinity) to Defendant
[] family member related by marriage or affinity to Defendant
[] sibling (person who shares biological parenthood) of Defendant
[X] current or former cohabitant (person who lives with) Defendant.
Defendant was served in accordance with Pa. R.C.P. 1930.4 and provided notice
of the time, date and location of the hearing scheduled in this matter.
Appearances by Parties and/or Counsel:
· Plaintiff appeared personally and is unrepresented.
· Defendant appeared personally and is unrepresented.
https://www.jnet.state.pa.us/PF ADFullTextJPF ADFullTextServlet?pfadcriteria=cG5vPTI... 10/24/2006
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Page 2 of3
"
AND NOW, this 2nd Day of May, 2006 the court having jurisdiction over the
parties and the subject-matter, it is ORDERED, ADmDGED and DECREED as
follows:
Plaintiffs request for a Final Protection Order is granted, after hearing upon
finding abuse within the PF A Act.
Plaintiffs request for a fin"al protection order is granted.
1. Defendant shall not abuse, stalk, harass, threaten or attempt to use physical
force that would reasonably be expected to cause bodily injury to the Plaintiff or
any other protected person in any place where they might be found.
2. Defendant is prohibited from having ANY CONTACT with the Plaintiff, or
any other person protected under this Order, at any location, including but not
limited to any contact at Plaintiffs school, business, or place of employment.
3. Defendant shall not contact the Plaintiff, or any other person protected under
this Order, by telephone or by any other means, including through third persons.
4. The following additional relief is granted as authorized by ~61 08 of the Act:
- Defendant is prohibited from having any contact with Plaintiffs relatives
and Plaintiffs children listed in this petition, except as the court may find
necessary with respect to partial custody and/or visitation with the minor
child/ren.
5. All provisions of this order shall expire on: November 2, 2007
NOTICE TO THE DEFENDANT
VIOLA TION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE
CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE
BY A FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX
MONTHS. 23 PA.C.S. ~6114. VIOLATION MAY ALSO SUBJECT YOU TO
PROSECUTION AND CRIMINAL PENAL TIES UNDER THE
PENNSYL VANIA CRIMES CODE.
THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE
DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE
COMMONWEAL TH OF PUERTO RICO UNDER THE VIOLENCE AGAINST
WOMEN ACT, 18 U.S.C. ~2265. IF YOU TRAVEL OUTSIDE OF THE STATE
AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAYBE SUBJECT
TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C
~~2261-2262. IF YOU POSSESS A FIREARM OR ANY AMMUNITION
WHILE THIS ORDER IS IN EFFECT, YOU MAYBE CHARGED WITH A
https:/ /www.jnet.state.pa.usIPF ADFullText/PF ADFullTextServlet?pfadcriteria=cG5vPTI... 10/24/2006
Page 3 of3
.
.
-.
FEDERAL OFFENSE EVEN IF THIS PENNSYLVANIA ORDER DOES NOT
EXPRESSL Y PROHIBIT YOU FROM POSSESSING FIREARMS OR
AMMUNITION. 18 U.S.C. ~922(g)(8).
NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over the plaintiffs residence OR any location
where a violation of this order occurs OR where the defendant may be located,
shall enforce this order. An arrest for violation of Paragraphs 1 through 3 of this
order may be without warrant, based solely on probable cause, whether or not the
violation is committed in the presence of the police. 23 Pa.C.S. ~6113.
Subsequent to arrest, the police officer shall seize all weapons used or threatened
to be used during the violation of the protection order or during prior incidents of
abuse. The HUNGTINGDON COUNTY SHERIFF shall maintain possession of
the weapons until further order of this Court.
When the defendant is placed under arrest for violation of this order, the defendant
shall be taken to the appropriate authority or authorities before whom defendant is
to be arraigned. A "Complaint for Indirect Criminal Contempt" shall then be
completed and signed by the police officer OR the plaintiff. Plaintiffs presence
and signature are not required to file the complaint.
If sufficient grounds for violation of this order are alleged, the defendant shall be
arraigned, bond set and both parties given notice of the date of the hearing.
BY THE COURT:
Stewart Kurtz, Judge
MAY 2, 2006
Date
Distribution to:
Plaintiff, Defendant, Sheriff, P A State Police, Local Police
This verifies that the above document is on file with the Huntingdon County Office of the
Prothonotary .
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN1Y, PENNSYLVANIA
ALAN B. McCAUSLAND
Plaintiff
NO. 05-6227 CIVIL TERM
v.
CIVIL ACTION . LAW
NANCY C. McCAUSLAND
Defendant
IN CUSTODY
STIPULA rlOH FOR Ef'4TRY OF TEMPORARY CUSTODY ORDER
AND NOW this lit day of November, 2006, Lindsay Maday, Esqutre attorney for Nancy
C. McCausland and Diane G. RadcliffJ Esquire, attorney for Alan 8. McCausland, being duly
authorized by the parties, hereby stipulate and agree that the foregoing order may be entered
as a Order of Court in th;s case, and that each shall be bound by a facsimHe sf~nature on this
Stipulation.
IN WITNESS WHEREOF the parties legal counsel have set their hands and seals the day and
year below wr1tt~n.
WITNESS:
{SEAL}
- 1 -
TOTAL P.05
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ALAN B. McCAUSLAND
Plaintiff
NO. 06-6227
CIVIL TERM
v.
CIVIL ACTION - LAW
NANCY C. McCAUSLAND
Defendant
IN CUSTODY
AFFIDAVIT OF SERVICE
I, the undersigned, being duly sworn/affirmed according to law, deposes and says:
1.
I am over 18 years of age and am not related to either party to this action.
[tY
I served a true and correct copy of the Custody Complaint, Petition for Emergency Relief and
Order of Court, properly endorsed with a Notice to Plead, upon the Defendant, Nancy C.
McCausland, on J 0" 1..1-~ by the manner checked below:
a. Hand; ng a copy to Defendant at I,.U ,4.s h. '1 ~- G- JlA!l. .' f/.I~" AI ~ ~""...(
C...-- ~t-'~o '1,4,-1-, NoLol<1 'PAA-I... ~,fc..t-..o4oori ~JR.. "') <}
2.
Handing a copy to , an adult member of the family with
whom the Defendant resides at Defendant's residence located at
, or if that person is not a
member of Defendant's family, then said person is the adult person in charge of
Defendant's said residence;
[ ]
b.
[ ]
c.
Handing a copy to , at ,
said person being the Defendant's agent or to the person for the time being in charge
of Defendant's office or ususal place of business located at
~~~
~<.l...~ )(0.,(. J u.,.
(Printed name)
Sworn to and subscribed before me
a Notary Public in and for
Cumberland County, Pennsylvania
this ~ay of ()il7~ , 20 Oc/'
~vf~
NOTARY PUBLIC
My commission expires:
COMMO!'IWEr,UH OF PEI"!..NSYLVA!;lIA
----.--Notari,~
DebG'Iclh L. Oon~3Y. Notary Public
Camp Hm Bora. ClJmberland County
Mv Coo;'l1ission Exoirp-s Sept 23, 2007
Mem~er. penn~~n Of Notaries
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€:I ORIGINAL
NOV 0 J 2006
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ALAN B. McCAUSLAND
Plaintiff
NO. 06-6227 CIVIL TERM
v.
CIVIL ACTION - LAW
NANCY C. McCAUSLAND
Defendant
IN CUSTODY
TEMPORARY CUSTODY ORDER
AND NOW, this ~_day of November, 2006, the Court having been advised that the
parties, Alan B. McCausland ("Father") and Nancy C. McCausland, ("Mother") have
reached a temporary agreement regarding custody of their minor children, Hannah A.
McCausland born 5/9/1992 and Sarah E. McCausland born 7/4/1995, (the "Children"),
and based upon the terms of that agreement as represented by their respective legal
counsel, IT IS HEREBY ORDERED AND DECREED as follows:
1. LEGAL CUSTODY: The Parents shall have shared 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 Child's general
well-being including, but not limited to, all decisions regarding their health,
education, and religion. Pursuant to the terms of 23 PA. C.S.A. ~5309, each
Parent shall be entitled to all records and information pertaining to the Child
including, but not limited to, medical, dental, religious or school records, the
residence address of the Child 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. PHYSICAL CUSTODY: The following shall apply regarding physical custody of the
Children:
..
A. Primary/Partial Custody: Father shall have primary physical custody of the
Children and shall have physical custody of the Children for all periods not
specifically reserved for Mother as herein provided. Mother shall have
partial physical custody of the Children in accordance with, and subject to
the following custody schedule.
B. Custody Schedule: The Parents' rights of physical custody shall be in
accordance with the following schedule:
1. Alternating Weekends: The Parents shall alternate physical custody
on alternating weekends from Friday at 6pm until Sunday at 6pm.
Mother's first weekend shall be the weekend of November 3rd
through 5th.
2. Tuesday Evening: Commencing on Tuesday, November 7, 2006,
Mother shall have physical custody each Tuesday from at the end of
her work day until 9pm.
3. Thursdav Evenings: Commencing on Thursday, November 9, 2006,
Mother shall have physical custody each Thursday from at the end
of her work day until the following morning when she shall deliver
the children to school.
4. Thanksgiving: for Thanksgiving 2006 Father shall have physical
custody of the Children from Tuesday, November 24, 2006 through
Sunday, November 26, 2006 for a trip to his brother's home in
Athens, GA.
3. MODIFICATION: The Parents shall be at liberty to modify the physical custodial
periods herein provided to accommodate their respective schedules and special
events, but both Parents must be in complete agreement to any new or modified
terms. If such mutually agreed upon modification is in writing (including em ail
transmission evidencing consent), it shall be binding upon the parties to the
extent and for the duration mutually agreed upon by the Parents. No Parent
shall be deemed to be in contempt of court for abiding by the terms of any such
signed written mutual agreement.
4. TRANSPORTATION: Except as herein provided, the transportation necessary for
the custodial exchanges herein set forth shall be shared by the Parents. The
- 2 -
Parent receiving custody of the Child shall provide the transportation for that
custodial exchange
5. RESTRICTIONS: Mother's partial custody periods shall not be exercised at the real
estate located at 135 North 17th Street, Camp Hill, Cumberland County, PA. And
the children shall not be permitted in that home until further order of this Court.
6. EFFECT OF ORDER: This order revokes, replaces and supercedes all prior orders
of this Court. This Order is intended to be temporary in nature and is entered
without prejudice to either party. It shall be subject to modification including,
but not limited to, such modification as may appear appropriate at the
conciliation conference to be held in this case.
J.
Distribution To: It / ~ 't){.,
Attorney for Plaintiff: Diane G. Radcliff, Esquire, 3448 Trindle Road, Camp Hill, PA 17011 - C4J~ ~
Attorney for Defendant: Lindsay Maclay, Esquire, 1029 Scenery Drive, Harrisburg, PA 17109 ", teJ-.~ 4
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Lindsay Gingrich Maclay, Esquire
Daley, Zucker & Gingrich, LLC
1029 Scenery Drive
Harris burg, PAl 7 I 09
(717) 657-4795
lmac1av@dzglaw.com
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
ALAN B. McCAUSLAND,
Plaintiff
No. 06-6227 Civil Term
v.
Civil Action - Law
NANCY C. McCAUSLAND,
Defendant
In Custody
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of the Defendant, Nancy C. McCausland, in the
above-captioned matter.
DALEY, ZUCKER & GINGRICH, LLC
Date: .tIN, l2Jrl,
By:
aclay,
ttomey J.D. No. 7954
1029 Scenery Drive
. Harrisburg, Pennsylvania 17109
(717) 657-4795
Attorneys for Defendant
cc: Melissa P. Greevy, Esquire, 301 Market Street, Leinoyne, P A 17043-0109
Diane G. Radcliff, Esquire, 3448 Trindle Road, Camp Hill, P A 17011
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ALAN B. MCCAUSLAND
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
06-6227 CIVIL ACTION LAW
NANCY C. MCCAUSLAND
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Tuesday, October 31,2006
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator,
at MDJ Manlove, 1901 State St., Camp Hill, PA 17011 on Tuesday, December 05, 2006 at 12:30 PM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearine.
FOR THE COURT.
By: Isl
Melissa P. Greevy, Esq.
Custody Conciliator
~
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
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 ] 7013
Telephone (717) 249-3] 66
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06-6227 CIVIL TERM
ALAN B. McCAUSLAND,
v.
CIVIL ACTION - LAW
NANCY C. McCAUSLAND,
IN CUSTODY
Defendant
Bayley, P.J.
ORDER OF COURT
AND NOW, this ~ day of December, 2006, upon consideration of the
attached Custody Conciliation Summary Report, it is hereby ordered and directed as
follows:
1. This Court's Order of November 2, 2006, shall remain in full force and effect
with the following modifications.
2. Effective December 9, 2006, Mother shall have custody commencing 9:00
p.m. Sunday until the girls are returned to school on Monday morning.
3. Holidavs. The following holiday schedule shall supercede the regular
schedule:
A. Christmas. Father shall have custody each year from December 24th at noon
until December 25th at noon. Mother shall have custody each year from
December 25th at noon until December 26th at noon.
B. New Year's Eve/New Year's Dav. Mother shall have custody each year from
December 31st at noon until January 1st at noon. Father shall have custody
each year from January 1st at noon until the children return to school, or
January 2nd at noon, which,ever first occurs.
C. Easter. The parties will share custody for the Easter holiday by their mutual
agreement.
4. Father shall e-mail his work schedule to Mother as soon as it is available. He
will promptly notify her of any changes to his work schedule. In the event Father has to
work a closing shift, Mother shall have custody of the children overnight.
... .
NO. 06-6227 CIVIL TERM
5. The Custody Conciliation Conference shall reconvene on March 7, 2007, at 2:00
p.m. with Custody Conciliator, John J. Mangan III, Esquire, at the Cumberland County
Courthouse.
BY THE COURT/'"
Dist: ~ane G. Radcliff, Esquire, 3448 Trindle Road, Camp Hill, PA 17011
j)6ndsay Gingrich Maclay, Esquire, 1029 Scenery Drive, Harrisburg, PA 17109
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06-6227 CIVIL TERM
ALAN B. McCAUSLAND,
v.
CIVIL ACTION - LAW
NANCY C. McCAUSLAND,
IN CUSTODY
Defendant
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN THE CUSTODY OF
Hannah A. McCausland
Sarah E. McCausland
May 9,1992
July 4, 1995
Father
Father
2. Father filed a Custody Complaint on October 26, 2006. A Custody
Conciliation Conference was held on December 5, 2006. Present for the conference were:
the Mother, Nancy C. McCausland, and her counsel, Lindsay Gingrich Maclay, Esquire; the
Father, Alan B. McCausland, and his counsel, Diane G. Radcliff, Esquire.
3. The parties agreed to a modification of the November 2, 2006 Order as such
that Mother would have custody of the children on Sunday overnight until they go to school
on Monday morning, commencing December 9, 2006. The parties also reached an
agreement with regard to the Christmas and New Year's holidays, Easter sharing,
notification of Father's work schedule, and a plan that would have the children be in
Mother's custody if Father has to work a closing shift. The parties also agreed to return to
conciliation in March, 2007, with Custody Conciliator Joh ngan.
/;r,7/6r
Da e
:288118