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HomeMy WebLinkAbout02-2622ANGIE MAE WATSON, Plaintiff Vo ROBERT ELLSWORTH WATSON, III Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. CIVIL TERM : IN DIVORCE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Streets, Carlisle. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone: (717) 249-3166 ANGIE M. WATSON, Plaintiff ROBERT E. WATSON, III, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-2622 CIVIL TERM : IN DIVORCE/CUSTODY NOTICE TO PLEAD You are hereby notified to file a written response to the within New Matter within twenty days (20) days from service hereof or a judgment may be entered against you. ANGIE M. WATSON, Plaintiff ROBERT E. WATSON, III, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-2622 CIVIL TERM : IN DIVORCE/CUSTODY ANSWER TO COMPLAINT UNDER §3301(C) OF THE DIVORCE CODE 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. Defendant is without sufficient knowledge or information to form a belief as to the troth of the averments in paragraph 7 but certainly there is no basis for denying counsel' s averments. 8. Admitted. 1. (second #1.) 2. (second #2.) 3. (second #3.) 4. (second #4.) 5. (second #5.) 6. (second #6.) 7. (second #7.) Admitted. Admitted. Admitted. Admitted II. CUSTODY Admitted in part denied in part. It is admitted that the relationship of the Defendant to the children is that of natural father. It is denied that he currently resides with his parents. Rather, Defendant currently resides with his sister and her husband, Anna and Cliff Howell, at 49170 Bayforest Road, Lexington Park, MD. Denied. It is denied that Plaintiff has undertaken and performed the primary responsibilities of the children. Further it is denied that Plaintiff is best able to provide the care and nurture which the children need for healthy development. 8. (second #8.) Admitted. WHEREFORE, Defendant request your Honorable Court deny Plaintiff's request for primary physical custody with visitation in Defendant. NEW MATTER Defendant's answer to Plaintiff's paragraphs 1 through 8 of the Complaint under §3301(c) of the Divorce Code and paragraphs t through 8 (second set of paragraphs 1-8) of Count II-Custody are incorporated herein as if set forth in their full text. 10. The best interest and permanent welfare of the children will be served by granting the relief requested because: Defendant provided the majority of the care for the children when the parties were residing together. Plaintiff's employment requires her to work overnight from approximately 6:00 p.m. until 6:00 a.m. When Plaintiffretums home from work, she sleeps throughout the day making her unavailable to care for the children. d. Plaintiff often leaves the children unattended during the day. Defendant fears that the children will suffer physical harm due to Plaintiff's inattentiveness. Defendant can and does have a desire to provide for the children's physical, financial, and emotional well-being. Defendant has a more stable lifestyle and can provide the children with consistency. WHEREFORE, Defendant requests your Honorable Court to schedule a custody hearing after which he shall be granted primary physical custody of the children. Respectfully submitted, Ma~l~ ~tas, E~qu~re Attorney Jbr Defendant GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243 -5551 (800) 347-5552 I, Marylou Matas, Esquire, counsel for ROBERT E. WATSON, III, hereby swear and affirm that the facts set forth in this document are true and correct to the best of my knowledge, information, and belief. I have sufficient knowledge or information and belief as to the averments stated in these pleadings, based upon my personal knowledge and information obtained ~om my client. This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date: Marylou ~[atas, Es'quire ANGIE M. WATSON, Plaimiff Vo ROBERT E. WATSON, III, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-2622 CIVIL TERM : IN DIVORCE/CUSTODY CERTIFICATE OF SERVICE I, Marylou Matas, Esquire, hereby certify that I did, the ~D -~ day of June, 2002, cause a copy of Defendant's Answer to Plaintiff's Complaint under §3301(c) of the Divorce Code to be served upon Plaintiff's attorney of record by first class mail, postage prepaid at the following address: Karl E. Rominger, Esquire Rominger & Bayley 155 South Hanover Street Carlisle, PA 17013 DATE: Marylou t~[atas, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 ANGIE MAE WATSON, Plaintiff V. ROBERT ELLSWORTH WATSON, III Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : ,t., : NO.0oZ-""-CIVIL TERM : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Angie Mae Watson, who currently resides at 145 Faith Circle, Carlisle, Cumberland County, Pennsylvania, since 1997 2. Defendant is Robert Ellsworth Watson, who currently resides at 50421 Fresh Pond Neck Road, Ridge, Maryland, since 2002. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on March 10, 1997, in St. Marys, Maryland. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available, and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree in Divorce. II. CUSTODY The plaintiff is Angie Mae Watson, residing at 145 Faith Circle, Cumberland County, Carlisle, Pennsylvania 17013. The defendant is Robert E. Watson, III, residing at 50421 Fresh Pond Neck Road, Ridge, Maryland. 20653. 3. Plaintiff seeks custody of the following children: Name Present Residence DOB Age Jasmine Watson 145 Faith Circle 10/13/97 5 Carlisle, PA 17013 Issiah Watson 145 Faith Circle 4/5/99 Carlisle, PA 17013 The children were not bom out of wedlock The children are presently in the custody of Angie Mae Watson who resides at 145 Faith Circle, Cumberland County, Carlisle, Pennsylvania. During the past five years, the children have resided with the following persons and at the following addresses: List All Persons Angie and Robert Watson List All Addresses 145 Faith Circle Carlisle, PA 17013 Dates 1997-2002 Angie Watson 145 Faith Circle Carlisle, PA 17013 7 Piney Court 1997-5/19/02 5/19/02 -Present He is married. The relationship ofplaintiffto the children is that of mother. The plaintiff currently resides with the following persons. Name Relationship Jasmine Watson Daughter Issiah Watson Son The relationship of defendant to the children is that of father. The defendant currently resides with the following persons. Nalne Dennis and Lydia Watson 50421 Fresh Pond Neck Rd. Ridge, MD 20653 Relationship Parems Plaintiffhas not participated as a party or wimess, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plalntiffhas no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know ora person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. The best interest and permanem welfare of the child will be served by granting the relief request because: Plaintiffhas undertaken and performed the primary paternal respons~ilities for the children. Plalntiffis best able to provide the care and nurture which the children need for healthy development. Each parent whose parental rights to the child have not been temfinated and the person who has physical custody of the child have been named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: WHEREFORE, Plaintiff requests this Court grant Plaintiff?primary physical custody with visitation in the Father. Respectfully submitted, Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff VERIFICATION I verify that I am the petitioner and that the statements made in the foregoing Petition 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. ~ Angiet"Mae Watson ANGIE MAE WATSON : : PLAINTIFF : V. .. ROBERT ELLSWORTH WATSON, III DEFENDANT : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COLrNTY, PENNSYLVANIA 02-2622 CIVIL ACTION LAW IN CUSTODY AND NOW, Tuesday, June 04, 2002 , 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 20, 2002 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. 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 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 J 21 82002 ANGLE M. WATSON, Plaintiff V ROBERT E. WATSON, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02 - 2622 CIVIL IN CUSTODY CO~TO~ER ANDNOW, this~ dayof ~0~ attached Custody Conciliation Repo~, it is~rdered , 2002, upon consideration of the and directed as follows: The Mother, Angie M. Watson, and the Father, Robert E. Watson, III, shall enjoy shared legal custody of Jasmine Watson, born October 13, 1997; and Issiah Watson, born April 5, 1999. 2. The Mother shall enjoy primary physical custody of the minor children. The Father shall enjoy temporary physical custody of the minor children on alternating weekends from Thursday evening at or about 6:00 p.m. until Sunday evening at or about 6:00 p.m. for the weekends of June 27*, July and July 25*. Counsel for the parties shall conduct a telephone conference call with the custody conciliator on Thursday, August 8, 2002 at 8:30 a.m. At that time, the parties will discuss the entry of an order for additional time for the Father in the future, and the parties will also discuss the results of a Protection from Abuse hearing which is scheduled in this case on July 29, 2002. Both parties shall allow the other parent reasonable telephone contact with the minor children. Additionally, both parties shall keep the other parent advised with respect to their address and telephone numbers and also with respect to ali daycare providers for the minor children. e This is a temporary order entered pursuant to an agreement between the parties and in recognition of the fact that there is a pending Protection from Abuse. The Father's agreement to the schedule as outlined above does not prejudice the Father from asserting a claim for primary custody or asserting a claim for additional periods of custody at a future date. Transportation for exchange of custody shall be handled with Father handling all transportation on pick up of the children on Thursday evenings. For the Sunday evening exchange, the parties shall meet at a halfway point between Father's home in Maryland and Mother's home in Carlisle with the provision that Father shall have another adult with him to ensure there are no incidents during the exchange of custody. Father's pick up point on Thursday evenings shall be at the Maternal Grandparent's home. cc: ~arylou Matas, Esquire ~ari E. Rominger, Esquire ANGLE M. WATSON, Plaintiff V ROBERT E. WATSON, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02 - 2622 CIVIL IN CUSTODY Prior Judge: 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: The pertinent information pertaining to the children who are the subject of this litigation is as follows: Jasmine Watson, born October 13, 1997; and lssiah Watson, born April 5, 1999. A Conciliation Conference was held on June 21, 2002, with the following individ,als in attendance: The Mother, Angie M. Watson, with her counsel, Karl E. Rominger, Esquire; and the Father, Robert E. Watson, III, with his counsel, Maryiou Matas, Esquire. The parties agree to the entry of an order in the for~i~ as attached. DATE Custody Conciliator ANGIE M. WATSON Plaintiff Vo ROBERT E. WATSON, III Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : No. 02-2622 CIVIL : IN CUSTODY CUSTODY STIPULATION & AGREEMENT THIS STIPULATION AND AGREEMENT entered into the day and year hereinafter set forth, by and between ROBERT E. WATSON, III, (hereinafter referred to as "Father") and ANGIEM. WATSON, (hereinafter referred to as "Mother"). WHEREAS, the parties are the natural parents of two children, namely JASMINE WATSON, born October 13, 1997, and ISSIAH WATSON, born April 5, 1999, (hereinafter referred to as "Children"); and WHEREAS, the parties live separate and apart, and wish to enter into an comprehensive stipulation and agreement relative to physical and legal custody of their Children, NOW THEREFORE, in consideration of mutual covenants, promises and agreements as hereinafter set forth, the parties stipulate and agree as follows: Mother and Father shall have shared legal custody of the children. Mother shall have primary physical or residential custody of the children. Father shall have periods of partial physical or residential custody of the children at the following times: o a.) On alternating weekends from Friday at 5:00 p.m. until Sunday 6:00 p.m., during the school year; b.) If the children have a long school weekend during Father's alternating weekend of custody, Father's weekend shall include the extra day off from school; c.) During the summer for four weeks, to be exercised as two periods of two consecutive weeks, with Father providing at least two weeks notice of his requested time; d.) At other times as the parties may agree. Father shall be responsible for all transportation for his custodial periods of time with the children, with the exchanges to occur at Mother's residence in Pennsylvania. The parties shall not have contact with each other during custody exchanges, so long as the current PFA is in place against Father. The parties shall alternate the holidays of Easter, Memorial Day, July 4th, Labor Day, Thanksgiving, Christmas A and Christmas B. Christmas A is defined as the first half of the minor children's break from school; Christmas B is defined as the second half of the minor children's break from school. Mother shall enjoy custody of the children for the holidays of Memorial Day, Labor Day, and Christmas A and Father shall enjoy custody of the children for the holidays of Easter, July 4th, Thanksgiving, and Christmas B for the year 2002, to alternate thereafter. The parties shall not communicate in person or hy telephone and shall have no physical contact with each other, during any period of time when a PFA is in place against Father for the protection of Mother. 10. 11. 12. Father shall be permitted to access school, daycare, extracurricular, and medical information regarding the children and Mother shall direct the above facilities to provide the requested information to Father. The parties will attempt to accommodate an arrangement so that the children shall be with Mother during Mother's Day weekend and with Father during Father's Day weekend. In the event this requires an exchange of weekends, the parties will attempt to accommodate each other to see that the children are with the respective parent during their designated Mother's Day or Father's Day weekend. The parties shall keep each other advised in the event of serious illness or medical emergency conceming the children and shall furl:her take any necessary steps to ensure that the health and well-being of the children is protected. During such illness or medical emergency, both parties shall have the fight to visit the children as often as he or she desires consistent with the proper medical care of the children. Neither parent shall do anything which may esmmge the children from the other party, injure the opinion of the children as to the ~,ther party, or which may hamper the free and natural development of the children':; love and affection for the other party. Any modification or waiver of any of the provisions of this Agreement on a permanent basis shall be effective only if made in writing, and only if executed with the same formality as this Stipulation and Agreement. The parties desire that this Stipulation and Agreement be made an Order of Court of the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over 13. 14. the issue of custody of the parties' minor children, who have resided for their entire lives in Cumberland County, Pennsylvania. The parties stipulate that in making this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the other party. The parties acknowledge that they have read and understand the provisions of this Agreement. Each party acknowledges that the Agreement is fair and equitable and that it is not the result of any duress or undue influence. 1N WITNESS WHEREOF, The parties hereto intending to be legally bound by the terms hereof, set forth their hands and seals the day and year hereinafter mentioned. WITNESSETH: ,)o 7/ Date 3 / Date ROBERT E. WATSON, III J GIE WAT§ON COMMONWEALTH OF PENNSYLVANIA : On this ~ ] day of /~(7~ , 2002, before me, the undersigned officer, personally appeared ROBERTE. WATSON, III, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purpose therein contained. 1N WITNESS WHEREOF, I hereunto set my hand and official seal. N~6tary ?ubS7" ' Notarial Seal Kadsa J. Lehman, Notary Public Carlisle Bore, Cumberland County . My Commission Expires Aug. 25, 2003 COMMONWEALTH OF PENNSYLVANIA : COUNTY OF (~//~/~/"/ff//'~,l : On this ~? day of ~d'7/7 ~ , 2002, before me, the undersigned officer, personally appeared ANGIE M. WATSON, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notarial Seal Kadsa J. Lehman, Notary Public Can'tsle Bom, Cumberland County ~,i,/Comrnisslon Expires Aug, 25, 2003 ANGIE M. WATSON Plaintiff ROBERT E. WATSON, III Defendant : IN THE COURT OF COMMON PLEAS OFN0V : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : No. 02-2622 CIVIL : IN CUSTODY ORDER OF COURT AND NOW this~-day of ~~ Stipulation and Agreement is hereby made an Order of Court. ,2002, the attached Custody CCi / Marylou Matas, Esquire Attorney for Defendant /Karl Rominger, Esquire Attorney for Plaintiff ANGLE M. WATSON, · Plaintiff ' V. ROBERT E. WATSON, II1 · Defendant ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-2622 IN CUSTODY PETITION TO MODIFY CUSTODY o Petitioner is Angie Watson, who resides at 7 Piney Court: Gardners, PA 17324. Respondent is Robert Watson, who resides at 49710 Bay Forest Road Lexington Park, MD 20653. On November 21, 2002, the Honorable Edward Guido entered a Custody Stipulation and Agreement as an Order of Court. (See Exhibit "A) Since the entry of said Order, there has been a significant change in circumstances in that: (A). Father has not been exercising his custody regularly. (B). It is difficult for mother predict whether or not father will exercise his custody which makes scheduling, babysitting and child care difficult. (C). When the children are aware that father may possibly be coming and he does not, they become distressed. The best interest of the children will be served by the Court in creating an Order which allows mother to only plan for, prepare for or initiate visitation with the father after father has given advanced notice of his intent to exercise the s~e and the parties have agreed upon the same. ANGIE M. WATSON Plaintiff Vo ROBERT E. WATSON, III Defendant IN THE COURT OF COMMON pLEAs OFb~0V CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 02-2622 CIVIL IN CUSTODY ORDER OF COURT AND NOW this~[ ~'-day of ~J~'~'t Stipulation and Agreement is hereby made an Order of Court. ,2002, the attached Custody CC: Marylou Matas, Esquire Attorney for Defendant Karl Rominger, Esquire Attorney for Plaintiff ANGIF vI. IW_~TSON Plaintiff ROBEI~ ~. WATSON, III Defendant IN THE COURT· OF COMMON PLEAS OF CUMBERLAND CouNTy PENNSYLVANIA CIVIL ACTION .. LAW : : No. 02-2622 CIVIL : IN CUSTODY ' ORDER OF COURT ND NOW this day of Stipulat on and Agrcemem is hereby made an Order of Court: · i BY THE COURT, __, 2002, ihe attached, Custody ' CC: 4a~10u Matas, Esquire Attorney for Defendant iari R~ningcr, Esquire. Attorney/or Plaintiff .[ ANGIE ROBER forth, ANGLE WA TS ~ referred ~stipulal hereina M.cWATSON Plaintiff T E. WATSON; II1' Defendant · IN THE COURT OF COMMON PLEAS~OF · CUMBERLAND COUNTY; PENNSYLVANIA : CIVIL ACTION ~ :!LAW : No. 02-2622 CIVIL : IN CUSTODY CUSTODY STIPULATION & AGREEMENT 'HIS STIPULATION AND AGREEMENT entered into 'uhe day and year hereinafter set a~d between ROBERT E. WATSON, III, (hereinafter referred. to as "Fa~er") and 14. ~WATSON, (hereinafter referred to as "Mother"). · ;EREAS, the parties are th, natural parents of two children, namely JASMINE ~, ~born October ·13, 1997, and ISSIAH WATSON, bom April' 5; 1999, (hereinafter :o as "Children"); :and /HEREAS, the parties' live separate and apart, and wish· to enter into an cOmprehensive ! . ,n i~nd agreemem relative to physical and legal custody oi'th¢';tr Children, 4OW THEREFORE, in consideration of mutual cOvenants, piomises, and agreementsl as ler i~et~ forth, the parties StiPulate and agree as follows: · .. Mother and Father shall have shared legal ·custody of the children. Mother shall have primary physical or residential custody of the.children.' Father shall have periods of partial physical or: residential, custody of the children at !h61foll°wing times: a.) On alternating weekends from FridaY at 4:00 p.m. until Sunday 6:00 p.m.., during the school year; b.) If the children have a long school 'weekend dgring Father's alternating weekend of c~stody, Father's weekend shall inciu~de the extra day off from school; c.) From approximately one week after the chilidren'are released from sch0°l until approximately one week before the children iare scheduled :to return to sChoOl, during which time Mother shah enjoy alter~ating.weekend periods of custody from Friday at 4:00 p.m. until Sunday at 6100 p.m.; d.) At other times as the parties may agree. TranspOrtation for exchange of crustody shall be handled With Father responsible for ill ~anspor~ation on pick up of the children on ~Friday eV. enings; during the school year. Mother shall be responsible for all transpo ~rtation on ~pick up of the children on ,.Friday evenings, during the summer. For the Sunday evening exchange, the' parties sh~ll meet at Exit 1'1 off of the Maryland beltway~. Fa,ther' Shall not have contact with ,.Mother during custody exchanges, so long as the PFA iS:in place against him, but ~hall arrange for a third'party to transport the children on his behalf. The.partii~s shall alternate the holidays of Easter, Memorial .Day, July'4th, Labor Day, .,Thanksgiving, Christmas A and Christmas B. Christmas A is defined as the'first half ~)f the minor children'S break from school; Chris!mas B is:defined as the secOnd half of the minor children's break from school. Mother shall enjoy custody of the children tot the holidays of Memorial Day, Labor Day,.' and Christmas A and Father shall o o 10. enjoy custody of the children for the holidays of Easter, July 4~h, Thanksgiving, and Christmas B for the year 2002, to alternate thereafter. .The parties shall not communicate in person or by telephone and shall ihave no physica, l contact with each other, during any period of time' when a PFA isl in place against Father for the protection of Mother. Father shall be permitted to access school, daycaxe, extracurricular, and medical information regarding the children and Mother shall .direct the above facilities to provide the requested information to Father. .,The parties will attempt to accommodate an arrangement so that the children 'shall 'be with Mother during Mother's Day weekend and with Father during Father"s Day Weekend. In the event'this requires an exchange of v~,eekends, the parties wil:l attempt to accommodate each other to see that the children axe with the respective parent during their designated Mother's Day or Father's Day weekend. The parties shall keep each other advised in the ew:nt of serious illness or medical emergency concerning the children and shall fu~er take any necessary steps to ensure that the health and well-being of the children :is promoted. During such illness or medical emergency, both parties shall have thefight to visit the children as Often as he or she desires consistent with the proper medical Care of the children. Neither parent shall do anything which may es,trattge the children.from the other party, injure the Opinion of the children as to the other party, or Which may l~amper the free and natural development of 'the children's 'love and affection for the other party. 12. 13. 14. ~ny modification or waiver of any of the provisions of this Agreement on .a i~erraanent basis shall be effective only if made in writing, and only if executed with thc same formality as this Stipulation and' Agreement. .The parties desire that .this Stipulation and Agreement be made an Order of Court of ihe.Court of Common Pleas of Cumberland County, and further acknoxeledge that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over the'issue of custody of. the parties' minor children, who have resided' for their entire iiv,s in Cumberland County, Pennsylvania. The parties stipulate ~that in making this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the pan of the other party. The parties acknowledge that they have read and understand the provisions of this - Agreement. Each party acknowledges that the Agreement is fair and equitable and that it is not the result of any duress or undue influence. Date Date ANGLE M.' WATSON ROBERT E. WATSONi III ? 1~,I WITNESS WHEREOF, The parties hereto intending 'to be legally bound by the terms / hereof, ~et forth their hands and seals the day and year hereinafter mentioned. WITNE~$~. TH:[ COUNq to be th execulel )N.;,WEALTH OF PENNSYLVANIA · ir OF · n ihis day of 2002, before me, the undersigned ;r~onally appeared ROI~RT E. WA T$ON, 1II, kno,~n .to. ~ne (or satisfactory ::proven)' person whose name is subscribed to the within Agreement and acknoWledged that,he Seal. th~ same for the purposetherein contained. N WITNESS WHEREOF', I hereunto set my hand and official Notary Public COMM~) ~N~/EALTH OF PENNSYLVANIA ~)fi lhis day of ',. 2002, before me, the.. undersigned officer, [er~onal'ly:appeared ANGIE M. WATSON, known to :me (or satisfactory .proven) to be the perl0ni:whose::name,_ is subscribed to the within Agreement and aCknoWledged that. she ex h same for'the purpose~iherein contained. I~q WITNBs$ WHEREOF~ I hereunto set my hand and official seal.. Notary Public TOTAL P.OS ANGIE M. WATSON PLAINTIFF ROBERT E. WATSON, III DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-2622 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, February 20, 2003 , 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, March 07, 2003 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 camaot 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 mag also be l~resent 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. 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 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 170'[ 3 Telephone (717) 249-316.6 ANGIE M. WATSON Plaintiff/Respondent V. ROBERT E. WATSON, III Defendant/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : No. 02-2622 CIVIL : IN CUSTODY PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF PARTIAL CUSTODY ORDER AND NOW, comes Petitioner, Robert Watson, by and through his counsel of record, Marylou Matas, Esquire, and represents as follows: 1. Petitioner is the above named Defendant, Robert E. Watson, III, an adult individual currently residing at 50421 Fresh Pond Road, Ridge, Maryland. Respondent is the above named Plaintiff, Angie M. Watson, an adult individual currently residing at 7 Piney Court, Gardners, Cumberland County, Pennsylvania. The parties are the natural parents of two children, namely, Jasmine Watson, bom October 13, 1997, and Issiah Watson, bom April 5, 1999. The instant action was initiated with a Complaint for Custody filed by Respondent, which resulted in an Order of Court, dated July 2, 2002, following an Agreement of the parties reached at a custody conciliation conference. A copy of said Order of Court is attached hereto and incorporated herein by reference as Exhibit "A". Following continued negotiation through counsel, the parties later signed a Custody Stipulation and Agreement, which resulted in an Order of Court, dated November 21, 2002. A copy of said Order of Court is attached hereto and incorporated herein by reference as Exhibit "B". o Pursuant to the provisions of the aforesaid Order, Petitioner is entitled to exercise periods of partial custody of the children on alternating weekends from Friday to Sunday. Since the entry of the aforesaid Order, Respondent has refused to provide the children to Respondent for his periods of partial custody. Specifically, during the weekends beginning approximately January 10, 2003 and continuing to the present, Respondent has refused to allow Petitioner to exercise custody of the children pursuant to the terms of the Order. Petitioner has contacted Respondent several times since the entry of the aforesaid Order to exercise his periods of partial custody pursuant to the terms of the Order, but Respondent refuses. 10. On at least one occasion, Petitioner drove from his residence in Maryland to Respondent's residence in Pennsylvania to exercise custody of the children, but Respondent and the children were not at the residence. 11. Upon discovering that Respondent was not making the children available pursuant to the terms of the Order, Petitioner remained in the Cumberland County, Pennsylvania area for approximately four additional hours, but Respondent did not appear to make the children available. 12. Respondent has willfully failed to abide by the Court Order as stated above. 13. There is a petition pending and a request for modification of the Order of November 21, 2002, filed by Respondent, and a custody conciliation conference is scheduled for April 3, 2003. 14. Petitioner was obligated to secure counsel to pursue the within Petition for Civil Contempt and Respondent should be responsible for payment of attorney's fees associated with these proceedings that were necessitated due to her failure to abide by the terms of the Court's Order. 15. Petitioner was denied the opportunity to exercise custody of his children on at least five weekend periods of time and should be awarded additional periods of time to make up for those lost time periods. 16. Respondent is represented by Karl Rominger, Esquire, who has been provided with a copy of this Petition in advance and who does not concur in the request for contempt. WHEREFORE, Petitioner requests Your Honorable Court to hold Respondent, Angie M. Watson, in contempt of Court. Respectfully submitted, GRIFFIE & ASSOCIATES U ~atas, Esquire Attorney for Petitioner 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800) 347-5552 I, Marylou Matas, Esquire, counsel for ROBERT E. WATSON, III, hereby swear and affirm that the facts set forth in this document are true and correct to the best of my knowledge, information, and belief. I have sufficient knowledge or information and belief as to the averments stated in these pleadings, based upon my personal knowledge and information obtained from my client. This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: MarylohA~tas, Esquire J~~2002 ANGLE M. WATSON, Plaintiff v ROBERT E. WATSON, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02 - 2622 CIVIL IN CUSTODY COURT ORDER AND NOW, this ¢L~'~'tn day of ~ , 2002, upon consideration of the attached Custody Conciliation Repo~, it is~rdered and directed as follows: The Mother, Angie M. Watson, and the Father, Robert E. Watson, III, shall enjoy shared legal custody of Jasmine Watson, born October 13, 1997; and Issiah Watson, born April 5, 1999. 2. The Mother shall enjoy primary physical custody of the minor children. 0 The Father shall enjoy temporary physical custody of the minor children on alternating weekends from Thursday evening at or about 6:00 p.m. until Sunday evening at or about 6:00 p.m. for the weekends of June 27th, July 11~' and July 25t''. Counsel for the parties shall conduct a telephone conference call with the custody conciliator on Thursday, August 8, 2002 at 8:30 a.m. At that time, the parties will discuss the entry of an order for additional time for the Father in the future, and the parties will also discuss the results of a Protection from Abuse hearing which is scheduled in this case on July 29, 2002. Both parties shall allow the other parent reasonable telephone contact with the minor children. Additionally, both parties shall keep the other parent advised with respect to their address and telephone numbers and also with respect to all daycare providers for the minor children. This is a temporary order entered pursuant to an agreement between the parties and in recognition of the fact that there is a pending Protection from Abuse. The Father's agreement to the schedule as outlined above does not prejudice the Father from asserting a claim for primary custody or asserting a claim for additional periods of custody at a future date. Exhibit A 0 Transportation for exchange of custody shall be handled with Father handling all transportation on pick up of the children on Thursday evenings. For the Sunday evening exchange, the parties shall meet at a halfway point between Father's home in Maryland and Mother's home in Carlisle with the provision that Father shall have another adult with him to ensure there are no incidents during the exchange of custody. Father's pick up point on Thursday evenings shall be at the Maternal Grandparent's home. BY THE C¢ CC: Marylou Matas, Esquire Karl E. Rominger, Esquire ANGIE M. WATSON, Plaintiff ROBERT E. WATSON, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02 - 2622 CIVIL IN CUSTODY Prior Judge: CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF .PROCEDURE !915;3-8(b), the undersigned Custody Conciliator submits the follmving report: The pertinent information pertaining to the children who are the subject of this litigation is as follows: Jasmine Watson, born October 13, 1997; and Issiah Watson, born April 5, 1999. A Conciliation Conference was held on June 21, 2002, with the following individuals in attendance: o The Mother, Angle M. Watson, with her counsel, Karl E. Rominger, Esquire; and the Father, Robert E. Watson, III, with his counsel, Marylou Matas, Esquire. The parties agree to the entry of an order in the form as attached. DATE Custody Conciliator ANGIE M. WATSON Plaintiff ROBERT E. WATSON, III Defendant IN THE COURT OF COMMON PLEAS OF[~0V CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 02-2622 CIVIL IN CUSTODY Stipulation a~ ORDER OF COURT , 2002, the attached Custody Marylou Matas, Esquire Attorney for Defendant Karl Rominger, Esquire Attorney for Plaintiff Exhibit B ANGIE M. WATSON Plaintiff ROBERT E. WATSON, III Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : :No. 02-2622 CIVIL : IN CUSTODY ORDER OF COURT AND NOW this __ day of Stipulation and Agreement is hereby made an Order of Court. BY THE COURT, , 2002, the attached Custody Jo cc: Marylou Matas, Esquire Attorney for Defendant Karl Rominger, Esquire Attorney for Plaintiff ANGIE M. WATSON Plaintiff Vo ROBERT E. WATSON, III Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : :No. 02-2622 CIVIL : 1N CUSTODY CUSTODY STIPULATION & AGREEMENT THIS STIPULATION AND AGREEMENT entered into the day and year hereinafter set forth, by and between ROBERT E. WATSON, III, (hereinafter referred to as "Father") and ANGLE M. WATSON, (hereinafter referred to as "Mother"). WHEREAS, the parties are WATSON, born October 13, 1997, referred to as "Children"); and the natural parents of two children, namely JASMINE and ISSIAH WATSON, born April 5, 1999, (hereinafter WHEREAS, the parties live separate and apart, and wish to enter into an comprehensive stipulation and agreement relative to physical and legal custody of their Children, NOW THEREFORE, in consideration of mutual covenants, promises and agreements as hereinafter set forth, the parties stipulate and agree as follows: Mother and Father shall have shared legal custody of the children. Mother shall have primary physical or residential custody of the children. Father shall have periods of partial physical or residential custody of the children at the following times: o a.) On alternating weekends from Friday at 5:00 p.m. until Sunday 6:00 p.m., during the school year; b.) If the children have a long school weekend during Father's alternating weekend of custody, Father's weekend shall include the extra day off fi'om school; c.) During the summer for four weeks, to be exercised as two periods of two consecutive weeks, with Father providing at least two weeks notice of his requested time; d.) At other times as the parties may agree. Father shall be responsible for all transportation for his custodial periods of time with the children, with the exchanges to occur at Mother's residence in Pennsylvania. The parties shall not have contact with each other during custody exchanges, so long as the current PFA is in place against Father. The parties shall alternate the holidays of Easter, Memorial Day, July 4th, Labor Day, Thanksgiving, Christmas A and Christmas B. Christmas A is defined as the first half of the minor children's break from school; Christmas B is defined as the second half of the minor children's break from school. Mother shall enjoy custody of the children for the holidays of Memorial Day, Labor Day, and Christmas A and Father shall enjoy custody of the children for the holidays of Easter, July 4th, Thanksgiving, and Christmas B for the year 2002, to alternate thereafter. The parties shall not communicate in person or by telephone and shall have no physical contact with each other, during any period of time when a PFA is in place against Father for the protection of Mother. 10. 11. 12. Father shall be permitted to access school, daycare, extracurricular, and medical information regarding the children and Mother shall direct the above facilities to provide the requested information to Father. The parties will attempt to accommodate an arrangement so that the children shall be with Mother during Mother's Day weekend and with Father during Father's Day weekend. In the event this requires an exchange of weekends, the parties will attempt to accommodate each other to see that the children are with the respective parent during their designated Mother's Day or Father's Day weekend. The parties shall keep each other advised in the event of serious illness or medical emergency concerning the children and shall further take any necessary steps to ensure that the health and well-being of the children is protected. During such illness or medical emergency, both parties shall have the right to visit the children as often as he or she desires consistent with the proper medical care of the children. Neither parent shall do anything which may estrange the children from the other party, injure the opinion of the children as to the other party, or which may hamper the free and natural development of the children's love and affection for the other party. Any modification or waiver of any of the provisions of this Agreement on a permanent basis shall be effective only if made in writing, and only if executed with the same formality as this Stipulation and Agreement. The parties desire that this Stipulation and Agreement be made an Order of Court of the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over 13. 14. the issue of custody of the proxies' minor children, who have resided for their entire lives in Cumberland County, Pennsylvania. The parties stipulate that in making this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the other party. The parties acknowledge that they have read and understand the provisions of this Agreement. Each party acknowledges that the Agreement is fair and equitable and that it is not the result of any duress or undue influence. IN WITNESS WHEREOF, The parties hereto intending to be legally bound by the terms hereof, set forth their hands and seals the day and year hereinafter mentioned. WITNESSETH: Date Date ROBERT E. WATSON, III COMMONWEALTH OF PENNSYLVANIA : COUNTY OF 'l /)'1 jg(' ',f [[~ 'F"--d/ ' On this 5 ] day of d~(-.7/~//~7-~,./''~ , 2002, before me, the undersigned officer, personally appeared ROBERT E. WATSO~ III, ~own to me (or satisfacto~ proven) to be the person whose name is subscribed to the within Agreement and ac~owledged that he executed the same for the pu~ose therein contained. ~ WITNESS ~E~OF, I hereunto set my hand and official seal. ~t;v PuN~ ' . ] Gaflis[~ Bor~ Oum~a~ana OounN [ [ My ~mmi~io,, Expires Aug. 25, 2003 } COMMONWEALTH OF PENNSYLVANIA : On this day of ' , 2002, before me, the undersigned officer, personally appeared ANGIE M. WATSON, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. 3-atary Public// Notarial Seal Karisa J. Lehman, Notary Public i Carlisle Bore, Cumberland County [ L~,4¥ Commlsslon Expires Aug. 25, 2003 ANGIE MAE WATSON, Plaintiff Vo ROBERT ELLSWORTH WATSON, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002-2622 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A. Complaint in Divorce under §3301 (c) of the Divorce Code was filed on March 30, 2002, and served on,,] ~. _,q,~aei, l ; 2. The marriage of Plaintiff and Defendant is irretrievably brdken and ninety (90) days have elapsed from the date of filing and service of the Complaint. Service of notice of 3. I consent to the entry of a final Decree of Divorce afteri intention to request entry of the decree. 1 I VERIFY THAT THE STATEMENTS MADE IN THE FOREQOING AFFIDAVIT 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: ANGIE MYAE WATSON, Plaintiff ANGIE MAE WATSON, Plaintiff Vo ROBERT ELLSWORTH WATSON, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLANT) COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002-2622 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST, THE ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODI~ 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted, i 3. I understand that I will not be divorce until Et divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is files with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT 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: GIE M~VAT'S0~, Plaihtif~ - ANGIE MAE WATSON, Plaintiff ROBERT ELLSWORTH WATSON, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002-2622 CIVIL TERIV~ IN DIVORCE AFFIDAVIT OF CONSENT 1. A. Complaint in Divorce under {}3301 (c) of the Divorce Code was filed on March 30, 2002, and served onJO~ ~'. ogt~O~ 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after Service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREqOING AFFIDAVIT 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. , ROBERT ELLSWORTH WATSON, III, Defendant ANGIE MAE WATSON, Plaintiff Vo ROBERT ELLSWORTH WATSON, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002-2622 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODEi I consent to the entry of a final decree in divorce without notiee. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorce until a divorce decree is entered by the Court and that a copy of the decree will be sent to me irmnediately afiOr it is files with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FORE( ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STA' ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §49 UNSWORN FALSIFICATION TO AUTHORITIES. iOING AFFIDAVIT FEMENTS HEREIN 94 RELATING TO DATE: ROBERT ELLSWORTH WATSON, III, Defendant ANGIE M. WATSON PLAINTIFF ROBERT E. WATSON, III DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-2622 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, April 11, 2003 , 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, May 01, 2003 at 2:00 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 hearing. FOR THECOURT~ 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 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) 249-3~[66 APR 1 4 2003 ANGLE M. WATSON, Plaintiff v ROBERT E. WATSON, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02 - 2622 CIVIL IN CUSTODY COURT ORDER AND NOW, this I~' ~' day of April, 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that this court's prior order of November 21, 2002 shall remain in effect subject to the following modifications: The parties shall communicate every Wednesday the weekend before Father is scheduled to have temporary custody of the minor children to confirm Father will be taking custody that weekend and to make arrangements with respect to exchange or visitation. This communication may be by phone call with the understanding that there shall be no threatening or abusive language during the phone call and the contents of the phone call shall be limited strictly to communication regarding exchange custody of the minor children. Counsel for the parties shall conduct a telephone conference call with the conciliator on Friday, May 23, 2003 at 8:30 a.m. The purpose of this telephone conference shall be to monitor how Father has done with meeting the custody schedule as set forth in the order and to also address Father's request that he be given additional time during the smnmer months to make up for time earlier this year when he missed weekends with the minor children. CC: Karl Rominger, Esquire Marylou Matas, Esquire Edward E. Guido ANGIE M. WATSON, Plaintiff V ROBERT E. WATSON, III, Defendant Prior Judge: Edward E. Guido IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02 - 2622 CIVIL 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: e The pertinent information pertaining to the children who are the subject of this litigation is as follows: Jasmine Watson, born October 13, 1997; and lsiah Watson, born October 5, 1999. A Conciliation Conference was held on April 3, 2003, with the following individuals in attendance: The Mother, Angie M. Watson, with her counsel, Karl Rominger, Esquire; and the Father, Robert E. Watson, III, with his counsel, Marylou Matas, Esquire. The parties agree to the entry of the two orders in the form as attached, one relating to custody and one relating to a modification of a Protection From Abuse Order. C~stody ~oGnic'~i~ ANGLE MAE WATSON, Plaintiff Vo ROBERT ELLSWORTH WATSON, III Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · CIVIL ACTION - LAW · NO. 2002 - 2622 CIVIL TERM · IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified mail, June 3, 2002. 3. Date of execution of the affidavit of consent required by § 3301(c) or The Divorce Code: by the Plaintiff, April 8, 2003; by the Defendant, April 8, 2003. Related claims pending: None 4. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: April 8, 2003· Date Defendant's Waiver of Notice in §3301 (c) Divorce was flied with the Prothonotary: April 8, 2003. Date: April 10, 2003 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID No. 81924 IN THE STATE OF Anqie Mae Watson~ Plaintiff VERSUS Robert Ellsworth Watson, III Defendant COURT OF COMMON Of CUMBERLAND COUNTY , ~~,~, PENNA. N o. 2002-2~22 PLEAS Civil DECREE IN DIVORCE , IT IS ORDERED AND DECREED THAT Angie Mae Watson Robert Ellsworth, Watson, III AND , PLAINTIFF, , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT rETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED Of RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YEt BEEN ENTERED; Non~ BY TH~ PROTHONOTARY THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff Defendant VS. File No. IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the of.~ ~ iL , hereby elects to resume the day prior surname of ~ ~ ~~ , and gives this written notice pursuant to the provisions of 54 P.S. S 704. Signature Signature of name being resumed COMMONWEALTH OF PENNSYLVANIA: : SS. COUNTY OF CUMBERLAND : On the day of · , before me, a Notary Public, personally appe~ed 'the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. seal. In Witness Whereof, [lave hereunto set my hand and official I My commission Expires APril 4; 2005