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ALJ!18HA J(, MAGUL I IN Tli! COURT OF COMMON PLJlA8
fidntitf I CUMBF.RJ,AND COUNTY, PfJNNSYLVANIA
I
v. I NO. 4l CIVIl, 1994
I
STfJVIlN J. MAGILL, ,
Defendant . CIVIL ACTION - I.AW
Mi'lDA.VU_.QI'_SER'lI.cl:
AND NOW, this / J:( , II day of F'ebruary, 1994, comes Gary J.
Imblum, Esquire, Attorney for Plaint.iff, who being duly sworn
according to law deposes and saya that..
1. A CUBtody Complaint under Section 3301(c) of the Divorco
Code was filed on January 4, 1994.
2. On or about February 3, 1994, a certified copy of the
Complaint and the Order scheduling the euotody Conference were sent
to the Defendant via certified mail, restricted delivery, return
receipt request.ed pursuant to PA. R.C.P. 1920.4.
3. On or about February II, 1994, undersigned counsel for
Plaintiff received the return recelpt card signed by the Defendant
or his agent dated February 5, 1994.
Said receipt is attached
hereto as Exhibit "A" and by this reference incorporated herein.
Respectfully submitted,
KNUP: '/OYK, p.e. ,/ ( ~
1-- ); ,!Y
Atty. I,D. No. 42606
Attorney for Plaintiff
ALlin .. MAGILL, I IN TIll C011RT or COMMON PLIAI
Plaintiff I CUMlIRLAHD COUNTY, PIIHN8YLVAHIA
I 41 (I I. (I , ( /1'1 r., 4
v. I NO,
I
8TIVIIN J. MAGILL, I CIVIL ACTION - LAW
Delendant I
OBlWl.-Ol'-_.gw,U
You, STEVEN J. MAGII,r" Defendant, have been Bued in court to
obtain cUBtody, partial custody or visitation of the child, DANIEL
STEVEN MAGILL.
You are ordered to
Le (Y'vy" ~
o'clock ~m., for
~a conciliation or mediation conference.
appear in person at ~ 5-' (1/
.' on ---1-; hl"'~ 5 " I,
13Th ,Sf,
,
,atL
a pretrial conference.
a hearing before the court,
......~,'w...<d L. f M.
(.,.,10. Y (O",(,t,,,I,.,
order, an order for
If you fail to appear as provided by this
custody, partial custody or visitation may be entered against you
or the court may issue a warrant for your arreat.
YOU SHOULD TAKF: 'I'HIS PAPER 'I'O YOUR r,AWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTI! BF:r,OW TO F'IND OUT WHERE YOU CAN GET LEGAL
HELP.
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURT HOUSE, FOURTH FLOOR
ONE COURTHOUSE SQUARE
CARLISLE PA 17013
,
ALI..A It. MAGILL, , IN T.I COURT or COMMON PLIA.
PldntUt . CUMBIRLAND COUNTY, ....NH8YLVANIA
,
v. . NO.
I
ITIVIIK J. MAGILL, I CIVIL ACTION - LAW
Detendent I
COHfLAXHT__I"OB....C.UITOIlX
AND NOW comes the Plaintiff, AI,t:SIIA K. MAGII,[" by and through
her attorneys, Knupp & Kodak, P.c., and respectfully repreoentsl
1. The Plaintiff is AI,E:SIIA K. MAGILL, an adult individual
residing at 9 Sherwood Drive, Mechanicsburg, Cumberland County,
Pennsylvania.
2. The Defendant is STEVEN J. MAGILL, an adult individual
residing at R.D., Box 494, New Bloomfield, Perry County,
Pennsylvania.
3. Plaintiff seeks custody of the following child.
tlAml
PRESENT RESID~~
AG::
Daniel Steven Magill
8 Sherwood Drive
Mechanicsburg, PA
2 years
4. The child was not born out of wedlock.
The child is presently in the custody ot Alesha K. Maq1l1
at her residence at 8 Sherwood Drive, Mechanicsburg, PA,
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II ,\"ltl'~lll 110, I'. .
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vs.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
Pli:NNSYLNANIA
NO. 41 CIVIL 1994
CIVIL ACTION - CUSTODY
ALI1SHA MAGILL,
Pl~intiff/responde~t
STilVI1N J. MAG II.L ,
Defendant/petitiQne~
UfUJOII FOR 8PKIAL RILIII'
To the Honorable Judges of said court:
COMES NOW the above defendant, Steven J. Magill, by his
oounsel, Jerry A. Philpott, Esquire, and petitions the court for
special relief pursuant to Rule 1915.l.3 of the Pennsylvania Rules
of civil pro~sdure, and in support thereof avers ao follows:
1. Petitioner is Steven J. Magill, father of the child who
is the subject of the above-captioned proceeding and defendant
therein.
2. Respondent is Alesha Magill, plaintiff mother.
3. The parties have one child, Daniel Steven Megill
("Danny"), born January 23, 1991, and currently three years old.
4. There is no court order of custody and the parties have
been sharing custody, with the mother having Danny most of the
time because the father travels out of state much of the time.
5. Both mother and father are alcoholics. Father,
however, is a recovering alcoholic, having confronted his problem
in about 1990. Mother is atill in denial.
6, Since the parties' separation in the summer of 1993,
Mrs. Magill has moved sevsral timss.
1
7. Mr. Magill was becoming concerned about the effects of
Mrs. Magill's unstabls life style upon Danny as the winter
approaohed.
a. In mid-December Mr. Magill learned about an incidsnt
involving Mrs, Magill and the Hampatead Township police that made
him vory concerned about Mrs. Magill'S drinking.
9. When she was confronted about thiH, she promised she
would stay with her parents in Mechanicsburg. Mr. Magill felt
Danny would be safe in that oetting.
10. On January 30, 1994, Mr. Magill learned of an incidsnt
on January 15, 1994, that gives rise to this petition.
11. It turns out that Mrs. Magill had not moved in with her
parents, Instead, she was rooming with Linda Street, a friend.
Moreover, on January 15, Mrs. Magill hod gone to Delaware with
friends, leaving Danny in the care of yet another friend.
12. She arrived home late at night very intoxicated. The
New Cumberland police had to be summoned. She wanted to take
Danny and leave despite her intoxication. Ultimately, she passed
out in front of Danny, who had awakened to this scene.
13. Ms. Street became very concerned about Mrs. Magill's
drinking and attempted to make her an appointment with someone at
a hospital. After hearing Mrs, Magill's symptoms, that person
informed Ms. Street that Mrs. Magill sounded like she had
advanced alcoholism and that ehe should receive care immediately.
Mrs. Magill insieted that the appointment be poetponed for
2
several weeks. Ms. Street had become very concerned about the
whole situation and went to Mr. Magill's parents and filled them
in. They checked with the police and verified that there had
been such an incident.
14, Right after Mr. Magill arrived back in Pennsylvania on
January 31 and learned of all this, he contacted the undersigned.
15. In the meantime, he received notice from Mrs. Magill's
attorney that a custody action had been filed and that Mrs.
Magill is planning to remove to Delaware with Danny.
16. Mr. Magill is extremely concerned for Danny's safety in
light of these recent revelations about Mrs. Magill's condition
and behavior.
17. A letter from Mrs. Magill's counBel saYB that she wants
to move to Delaware, which will be away from her own family as
well as away from petitioner and hiB family. In addition, the
complaint served on petitioner on Februar.y 2 says that respondent
intends to move on February 4 to Delaware.
18. This leads Mr. Magill to be even more conoerned because
Danny will have no one nearby who can step in if another
situation like the one above develops,
WHEREFORE petitioner pray. that thiB court enter an order
immediately untJ.I a hearing can be held granting him temporary
physical custody of Danny, and, after hearing, an order
prohibiting respondent from being in Danny's presence when she is
intoxicated, granting petitioner primary physical custody until
3
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1\111'11 H, 20011 Danny was to he returned to his Mother at :'):]0 I'M on
Sunday, April N, 2001. Danny hud spent the duy with his paternal ~l'Undparents. Molher calls
I' Will Delaware and says she cannot he home unlilll:()() I'M Sunday eVenin~, Mothl,ir says a
nd~hhor "I.ou Ann" will come to the house and they can drop Danny olf atl):OO I'M,
Grandparents return the child to his hOllle at 1):00 I'M and till: nci~hhor inf(lCIns thelll thaI Mother
willnol return until I():OO I'M. <icundparenls help Danny do his homework and leavl,i Mother's
house at 10:00 I'M, At II :20 I'M Mother telephones ~cundparellls screalllin~ IhallhtlY had ups.:t
th.: child, Paternal ~randparents noticed that the child is ,~Iceping on the 1I0or on a mulll'css
despite Ihe tilctthat inlhe lasllive years they have purchased Iwo (2) heds till' the child,
Much 26, 2001: Child docs not go to school on Monday mornin~ hecausc his
Mother has not returned in time from a weekend "IIWay". Child was len with his auut till' the
weekend and she did not se~' that he went 10 school on Monday,
Much 22, 2001: Mother culls Father and asks If he willtakc Ihe child on her
rel!ularly sl;hedule weekend hecause she wants to "go away", Father was scheduled to work on
that weekcnd and could not. Mother then asked him to c<llIthe patenwlgcundp<lrents to watch
the child so she could go away filr the weekend,
Weel, of March IH, 2001: Schooltclephoncs p<l(ernalgrandtitther <lnd ask,s if he can
pick up Danny hecausc he wus sick, The SdlOOI suys it was unahle 10 reach Mother and Mother
has not provided Falher's telephonc numher us a conlnct in the evcnt of an emergency, Patcrnal
gcundfather picks Danny up and goes to Mother's house (ncither Ihe child nor paternal
grundtitther huve a key) and loudly knocks on the door, Mother op~~ns till' door IInd lets Ihc child
in and with no explanation shuts the door in palernulgcundtillher's titce, ()n March 24, 2001
Danny tells plltcrnul grandmother thut "Pappy .rhoultl have lall,'n me 1/1 your place he,'au.re
Mommy Irealetl me lI11e aap [tilllowing his retll"non March IN, 20()11,"
I.llte 1998:
Inulctter in her o.....n hand Mother writes:
"Danny missed his lIalloween p<lrude ul school t I'll tell you so he
docsn't h<lve ((), I went to a Ilallowl'cn p<lrty Wednesday night. I
should have known hetter .q anywlIYs to make alonll story shOl'l
I drllnk too llIuch. I callie home Ihe Ileople I was with Cllllle In
+ hlld II beer. IlIot sick + paned out IInd dldn'llIet up until
10:30. I would han tllken I)an Into schoollllte but I was 100
embllrrllssed. I don'l normlllly drink durlnll the week'" I
IhoUllh I (ould handle 11." [Emphasis Addedl, A true and correct
copy of this letter is attached hereto as Exhibit "B",
3
I), The child III1ll unen cOJnmented that he is len in the care ufthe 16 year uld cuusin
or WI aunt in New Cumberland while his Mother "~oes away" for the weekends,
I 0, The aunt in New Cumberland resides with atlellllt Ilve children many of whom
have behavillr problems, One cousin named Michael is on probation for arson WId eUII throwlnll
while WI\lther child is a run aWllY,
II, I'llternol ijrundpllrents have witnessed Mother llITive lit their home to pick ulllhe
child belnu driven by Wlother person beclluse she was too intoxicated to drive herself safely,
12, Mother hllS many different people move into the house Mllrty (unemployed male),
Scott (llITested for drunk drivin~), l.indll Street (admitted drul! use with II criminal record in
Texas) which is then I(lllowed by lln IIrl!ument with the roommates lellVinl! the residence,
13, Aside from the incidents listed in ~8 Mother on November 14, 1999 could not
pick up the child beCIIWle her sister admitted that Mother WllS in no shape to do so havinl! done
drul!S WId (;onsideruble drinking with II mlln she mel at Sierra Madre the nil!hl before, On
November 15, 1')99 MOlher called paternall!rundparents WId llsked them to take her to Holy
Spirit Crisis Center, Soon aner she was then dropped ofT at palernall!rundparents' home having
obviously been drinkinl! and lakinl! drugs the night before, Arrunl!emcnts were made by
Mother's sister to have her admitted to Lancaster Rehabilitlltion on Wednesday, November 17,
1999, Mother then ,:hanged her mind and refused treatment promisinl! to I!et her life in order,
14, Father is remlllTied in a stable relationship WId owns a house in Dauphin County
while Mother is sinllle.
4
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Plaintiff
JUL 0 5 ~~
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-41
Al,E!SHA K. MAGill,
vs.
STEVEN J, MAGill,
Defendant
CIVIL ACTION - LAW
CUSTODY
'[EMPQBARY_OHDfRJJf-COURI
Oler, J. -- (
AND NOW, this .__11_____ day of__~L4--_-_-_, 2001, upon
consideration of the attached Custody Conciliation Summary Repo~t, it Is hereby ordered and
directed as follows:
1. LegaJ..G..ImQOy. The parents, Alesha K Magill and Steven ,). Magill, shall have
shared legal custody of the minor Child, Daniel Steven Magill, born January 23, 1991. 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 his health, education and religion, Pursuant to the terms of Pa, C, S.
~ 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. EJ:1ysical Custody. For the summer 2001 custodial time, the parties shall have a
week-on/week-off shared custody plan. Mother's custodial week shall be deemed to have
begun on June 17, 2001. Father's first custodial week under this plan shall CQmrnence June
24, 2001. The parties shall share transportation incident to their alternating periods of
custody.
3. Neither party shall do or say anything which may estrange the Child from the other
parent, Injure the opinion of the Child as to the other parent, or hamper the free and natural
development of the Child's love and respect for the other parent. Each parent shall ensure
that third parties also comply with this proVision during his or her periods of custody,
4, During any period of custody or visitation the parties to this Order shall not possess
or use controlled substances, neither shall they consume alcoholic beverages to the point of
intoxication, The parties shall likewise ensure, to the extent possible, that the other household
members and/or household guests comply with this prohibition,
Plaintiff
AUG 2 9 2M1l/\
IN THE COURT OF COMMON PLEAd 6~
CUMBERLAND COUNTY, PENNSYLVANIA
ALESHA K. MAGILL,
Defendant
NO 94-41
CIVIL ACTION.. LAW
CUSTODY
vs.
STeVEN J, MAGILL,
ORDER -OF- COURT
Oler, J, -
AND NOW, this __-,1,\ .i.L_._ day of ----4-~ - ~, ,-/ _,2001, upon
consideration of the attached Custody Conciliation Sum~s hereby ordered and
directed as follows:
1. ~..c.u.nQl1y, Tho parties, Alesha K. Magill and Steven J Magill, shall have
shared legal custody of the minor Child, Daniel Steven Magill, born January 23, 1991, 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 his health, education and religion. Pursuant to the terms of Pa, C. S. ~
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 (equired 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. Both parents shall be entitled to full participation in all
educational and medical/treatment planning meetings and evaluations with regard to the minor
Child. Each parent shall be entitled to full and complete information from any physician,
dentist, teacher or authority and copies of any reports given them as parents, including but not
limited to: medical records, birth certificates, educational records, comprehensive evaluation
reports, school records, attendance records, report cards, and Individualized Educational
Plans,
2, Ebysical Cu~, The parties shall share physical custody in the following fashion:
A Effective August 16, 2001, Father shall have custody from Thursday until
Sunday, August 20, 2001, and shall continue on alternating weeks from
Thursday after school until Monday when the Child is returned to school.
B. At all other times Mother shall have custody,