HomeMy WebLinkAbout94-00569
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TIlQth, W. Orl".
Pl.lnUrr
1m behaU of the
alnllr Ilhlldren I
Kenneth Heapetead
ZlQhar, R. Orl".
IN THI IXlUBT O' OOMMON PLUS O'
CUJlBKBI.AND lXllJNTY, PINNBYl.VANIA
CIVil. ACTION - LAW
&-' 0
NO. .)lo 1 ()JVlI. 1994
PROTECTION FROM ABUSP.
AND lll/BTODY
v..
Oatherine H. Orl".,
Defendant
TJiIIfQlWll J'BO'llllTlYL.<>BJlt:1
AND NOW, t.hls __.1~____ day of [lehruary 1994, upon pre8entatlon and
oon81deratlon of the within Petltlon, and upon flndln!! that. tbe alnor
ohildren, Kennet.h Hempstead and Zal)hary R. GrlUs, now realdln!! at. 127 Hershey
Road, Route 13, Sblppenshur!!, CUlIllflrlllnd County, Pcnnsylvllnla, are In
1.lIedlate and preBent. dlln!!er of abu8e froll the defendant., Cat.herlne II. Orl.lll,
the followlnll Te.porary Order IS ent.ered.
The defendant., Cat.herlnu II. GrlM!lB, whose rlHlldenoe IS, to the be8t of
the plalntl ff' s knowledge, South lIaapton Trailer Park, J,ot. 7, Shlppensburll,
Pennsylvania, IB hereby en,jolrltld from phYllll)ally abusln!! the .Inor children,
Kenneth Hellpstead and Zachllry R. GrI!!!!S, or pladnll t.hell in fear of abuse and
IS excluded froll the resldenee located at 127 lIershey Road, Rout.e 13,
ShlPpenshurll, CUlberland County, Pennsylvania, a residence wblch Is Jointly
owned, hut from IIhi(lh the defendant volunt.arlly left. on <)r ah<,ut January 30,
1994. The defendant IS berehy not.lfled that. If she reBldl's In the plaintiff's
dOllllclle cont.rary t,o t.hls Order, IIhe MY he In Indlreet crlllnal contlllpl.
which Is punlshahle hy a fine not, to r.xceed $1,000.00 and/or by a Bentclnce of
Ull t.o SIX mont.hs In Jail and any other npllroprlat.e punlahaent. ROBullptlon of
co-reBldencl' on t.he part. of t.be plalnt.lff and t.hu df'fendant, shnll not. nullity
the provlalons of t.he court. or<lor dlred.lnll till! ,h-fendant. t.o rl"fraln froll
abusinll t.he IIlnor llhlldren.
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'I 10th, W. Orl~.. I I N 'nUl r.ouR' or lXMQt PLIAB or
PlalntUI I
I CUNBIBLAHD COUNTY, PINN8YLVANIA
on behalf of the I
.lnor ohlldrenl I OIVIL ACTION - LAW
Kenneth He.p.te~1 I
lachar, B. Orl'" I NO. s~ /7 OIVIL 1984
I
,.. I PBOTICT I ON noM AIIlJIJI
c AND (lUSTODY
Oatherlne H. arl..., I
DefendlUlt I
ImfiCI
You have been Kued In court. If you wleh to defend a.alnet the clal..
.et forth In the followlJlll palles, you eUKt t,ake action pro.ptl;' after thl.
Petition, Ordor and Notice are served, by appearing pereonaUy or by attorney
at the hearlnll IIcheduled by the Court ami 11I'oR/mtlnll to the Court your
defenllol or objections to tho clallle Bet forth IIllalnet you. You are warned
that If you fall to do so tho Court aBY proceed wlthout you, and a Jud..ent
uy be entered agalnllt you by the Court wi thout further notice for any laoney
dal.od In the Pot.ltlon or for any other daill or relief requeeted by tbe
ph.lntlf!. You lay 10lle lIoney or property or other rlghtll i.portant to you.
YOU SHOUIJ) TAU: THIS PAPIR TO YOUR I.AWYKR AT ONel. IF YOU 00 NOT HAVI A
I.AWYIR OR CANNOT AFJORD ONfl, 00 TO 00 ULIPJlONE Till orrlCII SIlT PORTIf IlIL01f TO
PI NO OUT WHIRl! YOU CAN GIlT 1.t:OAL 1I11.P.
OOURT ADMINISTRATOR, 4m FLOOR
lJIOOlIIU.ANl> OOUNTY 00llRTHOU81
CARLISLE, PINNSYI.VANIA 17013
TILMPHONI NUMBIRI (717) 240~6200
TllOlhJ W. Grl... I 1 N TlIIl (:Ol)aT OF (:oMllON PUA8 OF
Plalnllff I
I C\lJlBIB/.AND OOIlNTY, PlNN8YJ.VANIA
on behalf of the I
.loor chlldrenl I 01 VII. AOTION - !.All
Kenneth He.pBlead I
ZacharJ B. Qrl"B I NO.S1J.>9 CIVil. 1111)4
I
v.. I PRO'I'ICT 1 ON noJII ADU81l
I AND CII8TODY
Calherlne H. Orl"B, I
Defend8lll I
l'Ull'lOLM.8lllJ'lC71Y.L.0iDIB
Aml..cJJan>DI
Bl1lJ.f.JJ.NJJEB.Tllt:, PJiQmTl.OJL.F.RllM ABUSE
Mll'..., 2,1. "A",J)LIJ..A,..JilI.Il1WLUllLd,dl!lJh
A,,__ADUMl
1. The plaintiff 10 an ~Iult Individual whose perBanenl addreeB IB 127
HerBhey Ro~l, Rout.e 13, Bhl ppensburg, CUBberland Count.y, Pennaylvanla, 172117.
The plal.nt,Iff brings this action on behalf of tbe minor children, Kenneth
HeBpstead and Zachary R. Orlillls.
2. The d<lfendant Is an adult Individual whoBe preeent reeldellce Ie, to
t.he best. of Illalntlff'B knowledge, Buut.h Hampt.on Trailer park, Lot 1,
Shlppensburg, Pennsylvania.
3. The defendant Is the plalntlff'lI comlllon-law-wlfe.
4. Blllce apllroxlllately 1993, t.he defendant haB alte.pted t.o cause and
haB Intentionally, knowingly, or reckleeely caused bodily Injury to the Blnor
children, Kennet.h lIeBpetead and l.aohary R. Or III!lB , and by phYBlcal Benace hall
ph,oed the. In fear of IlIBlnent scrlous bodily Injury. ThlB has Included, but
Is not IIBlt,ed to, t.he followlngl on eever"l occalllonB during t.he laBt year,
the defendant. haa punched Kenneth lIellllstead and Zachary R. Orlgg. in their
oheet,1I and forocfully grabhed thelll by the hack of their n'Jcke cauBln. the
plaintiff to fear for the children'. aafet,.
5. The plaintiff hellevllR and therefore nVllrR th"t the children,
Kenneth Ilelllllstend /Inri Zaeh/lry R. <Jrlllllll, will be In IBlle,llate and pl'eBent
d..n,er of abulle fI'ol t.he dllfelldllnt. IIh,)Uld t.hllY relaln III t.he hOle wlthuut
defendallt'lI eXlllulllon and t.he chddrllJl /Ire In need of prot,elltlon frol Buch
abu.o.
B. TIII~ABLml8'1'OJ)Y
6. The plaintiff BeukR t.elporary custody (If the follow In. ohlldrelll
NAIll P.UI.!!1U_ R.uidJllli1Jl AU
Kenneth Helpstead 127 Herahey Rd., Rt. 13 12 yr/$. old
Car-liule, VA 0011 1/27182
Zachary R. Orl.,a 127 Heuhey Rd., Rt. 13 9 Yrll. old
Carlisle, PA DOB 11/1/84
Albor-SunBhlno Orl'lIB 127 Herbhey Rd., Rt.. 13 7 )'rs. old
CarliBlo, PA llOB 12/29/8.6
Jacqueline A. Orl~lls 127 Hershey Rd., Rt. 13 ~ )'rs. old
eliI' lisle, PA 008 9/10188
The children, Zachary, Alber-Bunshlne, Bnd Jac1uellne Orl,.. were not
born out of wedlock, Bnd Kenneth lIellpstoad Is tbe lllalntUf'B step-Bon.
The children Ire preaontly 1/1 the cuatody of the plaintiff who relldel
at 127 HerRho)' Road, Rout.e 13, ClIl'llsle, Ponnlylvllnlll.
Durin. the paat five years, the chlldron havo roalded with the followln.
personB and at. t.he following addreBsoRI
tiJoU AdJI.r.!lJI.IWA llW1I
Plaintiff and 1409 S. l~th 81.. 1/89 to
Defendant Harrisburg, PA 4/90
PlalnUff and 410 N. WeRt 8t. 4/90 to
Defendant Carlisle, PA 2/93
P1B1ntlff and Various lotell and 2/93 to
Defendant calp grounde In 8/93
CUllberland Count)'
Plaintiff and 127 Hershey Rd., Rt. 13 8/93 to
Defendant Car lisle, PA 17013 1/30/94
Plalnt,lff 127 HerahllY Rd., Rt.. 13 1/30/94 to
Cnrllsle, PA preaollt
The fat.her of the children la Tllothy W. ()r illlla , tho plaintiff,
children alld can bOllt uartl tor thOIll III tho futuro.
b. The dofomlallt loft t.l11l chlldroll In the plalntlff'l ellBtody
011 llr about Jannary 30, 1994, and haa not provldod !lny Inforllat1on al to
her whereabouts.
11. The plaintiff requests that tho defendant be ordered to refrain
frOM reMoving !lny lit the children frill their luhoolR.
IJ,L.JlXillJIJ.lUYIL fOBBJIlIl101f
12. The hOllle whluh the plalntl ff Is Bilking the Court to excludll! the
defendant frOB 1B owned In the names of the plAl.ntiff and the defendant.
13. The plalnt.lff curr"ntly hall no place to stay with the children
except the Marital bOle, and the defendant voluntarily Mllved out of t.he
relldenoe on or about Jllnul1ry 30, 1994.
14. The plaintiff desires posaesslon of t.he Illobile hOlllll 110 as to give
the greatest degree of continuity to lives of tbe uhlldron and to allow theM
to contlnull their lldlwatlon I,t tb..II' sellools Rnd to contllllle thlllr school and
aoclal activities.
D-,-_-B.U 1'I.'QB.T
15. The defendant hilS a duty to support the lllalntlff and their Minor
children.
16.
plalnt.lff.
17.
18.
The defondllnt' s present omploYllllnt \lIforBatloll Is unknown to the
Tho plaintiff currently has no Income.
The plaintiff Intends to plltltlon fllr support within two weeks of
the Issullnce of 11 protective order.
IlL..lIl'ATIJDJ9.JlBOOJl~.J1fJ:QM^._PA.l)l'JIillJ
19. The plaintiff does not havll funcis available to PBY the teea for
filing I1nd servlcll.
WlIEREf'ORf:, pursuBnt 1,0 thll provlBiollR of the "Prot,ectlIJII frOM AhuRe Act"
of Octobor 7, 1976, 23 l'a.c.R.A. Sedloll 6101 'It !leg., lIa alllnded, the
plaint I rr prays thillllonur/,bla Cuurt. t,o iCrllnt. t.he followlnll relief:
A. G,'ant. a Tellmrary Order Ilursuanl, I." t.he "Prot.eot,lon frol Abuse Aot" I
1. Reljulrlnll the rlefendant to refrain frol abulIlllll the Ilnor
ohildren, Kenneth lIelPst.ead and Zaohary R. Orillllll, or placlnll t.hel In
fear of abuse.
2. Grantlnll telporary legal and physical llUBtody of tbe Ilnor
ohl1dren to the plaintiff. Requlrlnll the defendant to refrain fro.
relovlnll any of the children frol tholr BI1hoo1B.
3. Grantlnll POBsesBlon of the .oblle hOle looated at 127 Hershey
Rllad, Noute 13, ShlppenBburl!, Penneylvanla, to the plalnUff and the
children to the excluelun uf t.be defendant pendlnl! a final order In thh
aat ter.
4. Ordering the defendant to Btay away frol any reBldenoe
the plalnUff lIay ill I,he fut.ure olltabllllh for hl.Relf and the children.
B. Schedule a baarinll In aecurdance wi th the provlslonB of the
"Prot.ectlon from AbuRo Act.," and, after Ruch hearlnl!, enter an order to be In
effect for a per lod of un.. year:
1. Rellulrlng t.ho defendant. to rofraln frol abuRlng the alnor
children, Konnet.h lIelllRt,oad and Zachary R. GrlgllR, or placlnll the. In
fear of abuso.
2. Granting pORseRRlon of t.he loblle home located at. 127 lIorehey
Road, Routo 13, Shlpllenehurg. PonnRylvanla, to I,he plaintiff and the
ohlldren to tbe oxcluRlun of the defendant.
3. Orderlnll t.he defendant, t.o IItay away fro. any reRldenoe the
plalnt.lff IllY In t.he fut.ure ellt,/lhIIRh fur hllleelf /llld t.he children.
4. Or/mUng Rupport. to t.he plnlnt.lff and t,he children In an
appropf'lnl,e allount. n')'lordlnll the pl alntl ff' R IneoDle.
The I>lalnl,I'f furt.her aRks thllt, t.hlH P'lt,lt,l<m he filed and eervlld
wlt.huut. lUIYlllent. of I:Ollt.H, Ilendlnll n further urder nt. t.he hfJarlnll, and that. a
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unneQe.~ary delay b~fore the ~Qurt that I~.ued the Order.
When
that court i~ unavailable, the defendant shall be taken before
the appropriate district Justice.
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IN l'HE COURT Of COMMON PLE~S OF
CUM8ERL~ND COUNTY, pENN8YLVANI~
CIVIL ~CTION - l~W
NO. 609 CIVIL 1884
PROTECTION FROM ~BU8E
AND cUSTODY
Timothy W. Grigg~,
Plaintiff
on behalf of hie
minor children:
Kenneth Hempatead
Zachary R. Griggs
Catherine H. Griggs,
Defendant
~ND NOW,
.c.u.nQQ.'t.~QEB
this _J,{ day of February,
1994, upon
coneideration of the partIes' Consent Agreement, the following
Order is entered with regard to custody of the parties'
ohildren, Kenneth Hempstead, Zachary R. Griggs, Amber-Sunehine
Griggs, and Jacqueline A. Griggs.
1. The plaintiff, hereinafter referred to as the father,
will have primary physical and legal custody of the children.
2. The defendant, hereinafter referred to as the mother,
will have partial custody of Amber-Sunshine and Jacqueline A.
Griggs at times and places agreed upon by the parties.
3. The mother' will have supervieed visitation of Kenneth
Hempstead and Zachary R. Griggs, at times and places agreed upon
by the parti8ll.
4. The mother will refrain from removing any of the minor
childrsn from their schools without thQ father's permiseion.
5. Each parent will notify the other immediately of medical
emergencies which arise while the children are in that parent's
care.
6. Neither parent shall do anything which may estrange the
children from the other parent, or injure the opinion of the
children ae to the other parent or whioh may hamper the 'ree
and natural development of the children', love or re.pect 'or the
other parent.
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10 ~o AH '911
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 669 CIVIL 1994
PROTECTION FROM ABUSE
AND CUSTODY
Timothy W. Griggs,
Plaintiff
on behalf of hie
minor children:
~enneth Hempstead
Zachary R. Grigg.
Catherine H. Grigg.,
Defendant
!2QtHi.EtH __~.-.E.EM.et:H
"tA
This Agreement is ontered on this...iJL..__ day of February,
1994, by the plaintiff, Timothy W. Griggs, and the defendant,
catherine H. Grigos. The plaintiff is represented by Joan Carey
of Legal Services, Inc.; the defendant is unrepresented but is
aware of her right to have an attorney. The parties agree that
the follOWing may be entered as an Order of Court.
1. Tho defendant, Catherine H. Griggs, agrees to refrain
from abusing thq plaintiff's minor children, Kenneth Hempstead
and Zachary R. Griggs, or from placing them in fear of abuse.
2. The defendant agrees to pay support to the plaintiff in
the amount of "00.00 evry two weeks payable by mail beginning
March ", 1994, until an Order is entered by the Domestic
Relations Office.
3. The defendant, although entering into this Agreement,
does not admit the allegations made in the Petition.
4. The defendant understands that the Protective Order
entered in this matter shall be in effect fOI a period of one
year.
6. The defondant understands that this Order will be
enforceable in the same manner as the Court's prior Temporary
Protective Order entered in this case.
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6. The defendant and the plaintiff agree to th~ entry of
a Cuetody Order regarding their children, Kenneth Hempstead,
Zachary R Griggs, Ambsr-Sun~hine Grigg8, and Jacqueline Grigg8,
providing the following:
a. The father will have primary physical and legal
custody of ths children.
b. The mother will have partial cU8tody of Amber-
Sunshine and Jacqueline A. Griggs at times and place. agreed
upon by the parties.
c. The mother will have supervised visitation of
Kenneth Hempstead and Zachary R. Griggs, at time. and place.
agreed upon by the parties.
d. The mother will refrain from removing any of the
minor children from their schools without the father's
permission.
e. Each parent agrees to notify the other immediately
of medical emergencies which arise while the children are in
that parent's care.
f. The parente realize that their children's well
being is paramount to any differences they might have
between thsmselves. Therefore, they agree that neither
parent will do anything which may estrange the children from
the other parent, or injure t,he opinion of the children 8S
to the other parent Lr which may hampsr the free and natural
development of the children's love or respect for the other
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Jim,. K. Jc)II'., t:.qulr,
411 11l1II1 L(mlhur Slrcel
Cnrlllle. PA 171)JJ.2/)~7
(717) 241).4)2')/)
III'
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i'rn't"'If~\1~_'i<l (';~'I'tI"lhioIiil~'~
TIMOTHV W. GRIGGS,
Plaintiff/Respondent
IN '1'1110: COUR'I' (>10' COMMON PLEAS Of'
CUMBE:RLAND COUN'rv, PH:NtiIlVrNANIA
NO. 94-0569 CIVIL TERM
vs.
CIVIL ACTION--LAW
CA'l'HERINE H. GRIGGS I
Defendant/Petitioner
cus'rODV
ORDER Of' COUR'l'
AND NOW, this l.1th.. day of ()c( n'lI b.... , 1995, upon
<Jonsideration of the attached complaint, it is hereby direoted
that the parties and their respective counsel appear before the
conoiliator \)m.L.~ ,:JI..'I'dn_L\ \ ("'''l . at .~: rr){.\,n51', m.k.L. t:>fl
on the _ /""', day ~f '],,''''~, 199Ji,
~. m., for a Pre-Hearing Custody Conference.' At suoh oon-
ference, an effort will be made to resolve the issues in disputel
or if this cannot be accomplished, to define and narrow the
issues to be heard by the oourt, and to enter into a temporary
order. All children 8ge 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.
FOR TilE COURT,
Bye
The Court of Common Pleas of Cumberland County is required by law
to comply with the Americans with Disabilities Act of 1990. For
information about accesssible facilities and reasonable acooffioda-
tions 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. Vou must attend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWVER AT ONCE. IF VOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET f'ORTH BELOW TO f'IND OU'l' WHERE VOU CAN GET LEGAL HELP.
OFFICE OE' THE COURT ADMINISTRATOR
COURTIIOUSE, 4TH FLOOR
CARLISLE, FA 17013
(717) 240-6200
(
vs.
IN THE COURT OF COMMON VLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-0569 CIVIL TERM
CIVIL ACTION--LAW
TIMOTHY W. GRIGGS,
Plaintiff/Respondent
CATHERINE H. GRIGGS,
Defendant/Petitioner
CUSTODY
PETITION FOR MODIFICATION OF A PA~TIAL
CUSTODY OR VISITATION ORDER
AND NOW, comes Petitioner Catherine H. Griggs, through her
attorney James K. Jones, Esquire, and brings this Petition for
Modification of a Partial Custody or Visitation Order, a state'-
ment of which follows:
1. On February 14, 1994, an Order of Court was entered for
Custody and Partial Custody, a true and correct copy of which is
attached.
2. This order should be modified because:
a. Respondent is hospitalized with what is believed to
be blood clots in his le9;
b. Respondent has el<perienced reourring medical prob-
lems such as stomach ulsers, high blood pressure and kidney
problems that inhibit his ability to care for the children;
c. The children have lived with Petitioner since
November 9, 1995 and have adjusted well to their new home
and school;
d. Respondent in the past has prevented Petitioner
Tim9thy W. GriQQs,
Plaintiff
an behalf af hilt
minor chi ldren:
Kenneth Hempst.ad
Zachary R. Griggs
V8.
IN mE COIIIH OF COMMON PLEAS 01'
CIJMBERLANU COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 569 CIVIL 1994
PROTECTION FROM ABIJSE
AND CUSTODY
Cather i ne ~l. Gr i ggs,
Defendant
AND NOW,
I (' C!!UQ.Qy"....QBQEB
thi s _.L, m day of February, 1994, upon
consideration of the parties' Conaent Agreement, the followIng
Order is sntered with regard to custody of the parties'
children, Kenneth Hempstead, Zachary R. Griggs, Amber-Sunshine
Griggs, and Jacqueline A. Griggs.
1. The plaintiff, hereinafter referred to as the father,
will have primary physical and legal custody of the children.
2. The defendant, hereinafter referred to as the mother,
will have partial custody of Amber-Sunshlne and Jacqueline A.
Griogs at times and places agreed upon by the parties.
3. The mother will have suporvised visitation of Kenneth
Hempstead and Zachary R. Griggs, at times and places agreed upon
by the part i es.
4. The mother wi 11 refrain from removing any of the minor
chIldren from their schools without the father's permission.
5. Each parent will notify the other immediately of medical
emergencies Which arise while the children are in that parent's
care.
6. Neither parent shall do anything which may estrange the
children from the other parent, or injure the opinion of the
children ~8 to the other purunt or which may hamper the free
and nat4ral development of thu children's love or respect for the
other parent.
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TIMOTHY W. GRIGGS, I
Plaintiff/Respondent I
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CATHERINE H. GRIGGS I
Defendant/Petitionerl
IN THr. COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
94-0669 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
IN REI TEMPORARY ORDER
PETITION FOR SPECIAL RELIEF
ORDI:Jt OF COURT
AND NOW, thie 38th day of December, 1996, t~ie
.att.r having been called on a Petition for Special Reli.f, the
following temporory order is entered:
1. Physioal custody of Amber-Sunshine Grigg_,
Jacqueline A. Griggs and Zachary R. Griggs shall be with their
father, Timothy W. Griggs.
2. The mother, catherine H. Griggs, shall have
t.mporary physical custody of these three children every other
we.kend from Friday after school until sunday evening at 7100
p.m., the first weekend commencing on Friday, January 6, 1996.
This temporary order shall remain in effect
pending any further order to be entered af~~r the scheduled
concilietion conferenoe on the current petition of the mother
e.eking cuetody of the three children.
,
By the court';
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Edgar B. Bay
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Joan carey, Esquire
Coun..l for the Plaintiff/Respondent
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Jame. Jon.., Esquire, Esquire
Coun..l for the Defendant/Petitioner
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-0569 CIVIL TERM
CIVIL ACTION--LAW
TIMOTHY W. GRIGGS,
Plaintiff/Respondent
CATHERINE H. GRIGGS,
Defendant/Petitioner
CUSTODY
PETITION f'OR SPECIAL. REl.t.UlE
1. On February 15, 1994, this Court entered an Order for
oustody and partial custody granting plaintiff primary physioal
and legal custody of the parties children.
2. Since the time of the order, defendant has maintained
contact with the childr.en.
3. Plaintiff has suffered from various physical illnesses
inoluding stomach ulcers, high blood pressuro and kidney problems
which limit his ability to care for the children.
4. On Novembor 9, 1995, plaintiff was hospitalized and
custody of the children was given to defendant by plaintiff.
5. The children were enrolled in the Carlisle School Dis-
trict and have adjusted woll to their new schools.
6. On December 14, 1995, defendant filed a petition to
modify the custody order and the court scheduled a Pre-Hearing
Custody Conferenoe for ,January 16, 1996 before the conclJ.iator
appointed in this matter.
7. On December 24, 1995, plaintiff appeared at defendant's
residence with police officers to regain custody of the children
bas~d upon the February 15, 1994 oustody Qrder. An agreement was
made that he oould take the children for ()hristmas from :l: 00 p. m.
to 6:00 p.m. Despite this agreement, plaintiff has not returned
the children at this point.
6. Defendant requests that this Court maintain the status
quo that existed before pLaintiff's breaoh of his agreement since
the children are due to return to school on January 2, 1996 and
will be unable to due so as plaintiff residos outside the Car-
lisle School District and further, the children have adapted well
to living with their mother and desire to remain with her.
Defendant is also concerned that plaintiff's physical limitations
will inhinit his ability to properly care for the children pend-
ing the oonciliator's conference.
WHEREFORE, plaintiff requests this Court to grant temporary
oustody to defendant/petitioner pending resolution of the oustody
matt.er.
Respectfully submitted,
/,) "'-)
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J~S K. Jones, uire
Attorney for P~itioner
Suite 222, 401 E. Louther
Carlisle, PA 17013-2657
(717) 240-0296
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iONOTARY
ERLAND COUNTY COUIHHOUSE
:OURTHOUSE SQUARE
SLE, PA 170"-3381
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T1moehy W, Gri99s
460$ Warrington Avenue
M.ohaniosbur9/ PA 17056
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'l'IMO'I'IlY W. OrUO(lIl,
Plaintiff/Respondent
IN 'l'lm CClUR'I' ()li' COMMON PI,1':A5 OF
ClJMlIEIU..ANIl COlJN'l'Y, PENNSYLVANIA
NCl. 94-0569 CIVIL TERM
V/l.
CIVIl. AC'l'IClN-"LAW
CATHERINE II. GRIGGS,
Defendant/Petitioner
ClJS'l'ODY
PU:'l'l'l'ION ["OR SI'J:,CIAI, RUll,rEF'
1. On F'ebruary 15, 1994, lhis Court entered an Ordor for
ouotody and partial oustody granting plaintiff prirndry physioal
and legal oustody of the parlies children.
2. Since the time of the order, defendant has maintained
contact with the children.
3. Plaintiff has suffered from various physical illnesses
including stomach ulcers, high blood pressure and kidney problems
which limit his ability to care for the children.
4. On November 9, 1995, plaintiff was hospitalized and
custody of the children was given to defendant by plaintiff.
5. The children were enrolled in the Carlisle Sohool Dis-
trict and have adjusted well to their new 50hools.
6. On December 14, 1995, defendant filed a petition to
modify the custody order and the courl scheduled a Pre-Hearing
Custody Conference tor ,January 16, 1996 before the conciliator
appointed in this matter.
7. On !lecembeI' 24, 1995, pj,'linUff appearod at defendant's
residence with police officers to regain custody of the children
""
'l'IMO'I'IIY W. OIH<JG/J,
plaintiff/Respondent
IN 'I'm: COUR'I' Ol" COMMON Pl,EAS OF
CUMllFlIU,ANl> COUN'l'Y / PIilNNSYrNAtilA
NO. 9~-D569 CIVIL TERM
Viii.
CIVIL ACTION--LAW
CM'flf:R I NF: II. GR !Clel/J ,
Defendant/Velilionor
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PE'I'I'l'l.ON [,'Ol{ SI'F:CIAr, RE:1.UJ.f.
1. On February 15, 1994/ thi B Court entered
custody and partial custody granting plaintiff primary physical
and legal custody of the parties children.
2. Since the time of Lhe order, defendant has maintained
contact with the children.
3. Plaintiff has suffered from various physical illnesses
including stomach ulcers, high blood pressure and kidney problems
which lImit his ability to care for the childr~n.
4. On Novomber 9/ 1995, pl.aintiff was hospil:alized Bnd
custody of the children was given lo defendant by plainliff.
5. The children were enrolled in the Carlisle School Ois-
trict and have adjusted well to their new schools.
6. On December 14, 1995/ defendant filed a petition to
modify the custody order and the court scheduled a Pre-Hearing
Custody Conferenco for ,Januar.y 16, 1996 before the concilialor
appointed in this matter..
7. On December 24/ 1995, plaintiff appeared at defendant's
residence with police officers to regain custody of the children
~
based upon the February 15/ 1994 custody order. An agreement was
made that hO could tako the children for Christmas from 2:00 p.m.
to 6:00 p.m. Deapite tll.la aqrnoment/ piaintiff. has not returned
the children 'at 1.I11a point.
O. Defendant requests that this Court maintain the stntus
quo that existed before pla1ntiff's breach of his agreement since
the children are due to return to school on January 2, 1996 and
will be unable to due so oa plaintiff realdea outside the Car-
lisle School District and further, the children have adapted well
to living with their mothor and deaire to remain with her.
Defendant is also concerned that plaintiff's physical limitations
will inhibit his ability to properly care for the children pend-
ing tho conciliator's conference.
WHEREFORE, plaintiff requests this Court to grant temporary
custody to defondant/petitioner pending resolution of the custody
matter.
Respectfully submitted,
,-,I ", ~ I
(_,__..-. ~t'- /"_.:------.
J~~~ K. JOnes,~4Uire
Attorney for p~titionor
Suite 222, 401 E. Louther 51:.
Carlisle, PA 17013-2657
(717) 240-0296
I'll fD.'" i' l'ir:E
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I IN THE COURT OF COMMON PLBAS OF
I CUM2ERI,AND COUNTY, PENNSYLVANIA
.
. CIVIL ACTION - CUSTODY
.
. 94 - 569
.
.
TIMOTHY w. GRIGGS,
Plaintif,t
CATHERINE H. STONE,
(formerly CATHERINE H. GRIGGS)
Defendant
cmJGAlULU'U'U.olL '9JI. JlO JUrl,CAUOILjU'_ _.c.u_U..oJU_--OADD
TO THE HONORABLE, THE JUDGES OF THE SAID COURT.
I. Plaintiff is Timothy w. Griggs, an adult individual who
currently resides at 127 Hershey Road, Shippensburg, Cumberland
county, Pennsylvania 17257.
2. Defendant is catherine H. Stone (formerly Catherine H.
Griggs), an adult individual who currently resides at 48 West High
Street, Apartment 3, CarliSle, Cumberland County, Pennsylvania 17013.
3. PlaintHf seeks modification of a prior custody order
involving minor children Zachary R. Griggs (D.O.B. 11/1/84), Amber
Sunshine Griggs (D.O.B. 12/29/86) and Jacqueline,A. Griggs (D.O.B.
9/10/88) .
4. Plaintiff and Defendant have not lived together for many
years and maintain separate residences.
5. During the past three (3) years, the children have primarily
resided with Plaintiff at his address located at 127 Hershey Road,
Shippensburg, Pennsylvania.
6. The natural mother of the children is Defendant who currently
resides with a male friend, Reith Stone.
7. The natural father of the children is Plaintiff who
currently resides with Charlene E. Christmas.
8. A prior custody order dated January 25, 1996 (attached
hereto as Exhibit A) presently exists, however circumstanoes have
changed requiring modificaHon of such order.
9. Plaintiff has no knowledge of any other litigation
concerning the cust.ody of the children in this or another. court
and Plaintiff has no information of a custody proceeding
concerning the children pending in a court of this Commonwealth.
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.
10. During the past several months, the children have
reported to Plaintiff that Defendant and her male friend have been
engaged in dealings of drugs and using drugs in the presence of
the children.
11. The children have advised Plaintiff that Defendant and
her male friend use drugs and the smell of such drugs make the
children sick.
12. The children are presently engaged in Drug Alcohol
Resistance Education (DARE) programs and Defendants use of
controlled substances is contrary to the education they are
reoeivillg.
13. upon further questioning by Plaintiff, the children told
2
Plaintiff that Defendant purchased mariiuftna in their presence and
that Defendant has used cocaine in their pre8ence.
14. Paragraph 6 of the most recent cU8tody order requires
that Mother retrain from the use of illegal drugs in the presence
of the children.
15. Plaintiff has discovered head lice on the children
following visits to Defendant's residence on sever.al different
occa8ions during the past several months.
16. Defendant's conduct and activities involving the use and
sale of drugs, in or outslde the presence of the children,
con8titutes dangerous and criminal activity causing severe and
potentially irreparable harm to the minor children.
17. As a result of Dofendant's activity, communications
between the parties have been strained, custody contacts have been
irregular and disrupting to Plaintiff and the children.
18. Petitioner 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.
19. A current custody order and agreement is necessary to
reflect the change in circumstances since the parties's last
agreement.
20. The best interests and permanent welfare of the children
will be served by ordering that both parties share legal cU8tody
of the children and directing that the prosent custody order be
J
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modified witn an O~der directing that Plaintiff shall have p~ima~y
physical custody of the children and that Defendant shall have
periodD of partial, supe~v}.sed o~ x'estrictod custody activities
for the following ~easons'
(A) plaintiff is a fit parent who can take ca~e of the
children and who can provide them with a supportive, safe and
healthy environment,
(B) Defendant's conduct and behavio~ is not in the belt
interest of the children in that,
(i) Defendant has blatantly Ilsed, sold and dealt controlled
and illegal drugs in the presence of the minor children in
vj,olation of the January 25, 1996 Court Order, and
(ii) Defendant has placed the children in dangerous and
uncertain environments wJ,thQut Plaintiff's consent and Defendant
continues to act in an irresponsible manner without consideration
ot the interests of the minor children, and
(iii) Defendant is unable to provide the children with a clean
and healthy environment when the children spend time with her.
(iv) Defendant's use of illegal drugs and denial of
respollsibility for such use has resulted in hostile communications
towards plaintiff in the presence of the child~ell,
21. Each parent whose parental rights to the children have not
been terminated and the person who has physical custody at the children
have been named as parties to this action.
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TIMOl'HY W. GR WGS ,
Plaintiff
VB.
r IN THE COURT OF COMMoN PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I NO. 94-0569 CIVIL 1'ERM
r
1 CIVIL A~rION - LAW
I CUSTODY
CAT/lERlNE H. GRIGGS,
Defendant
00DIIlR 011' CXlORT
-
AND ~, this
upon consideration of the
is ordertd and directed as
~ .,
attached
follOW/ill
day of .) ,~
CUstody Conciliation Suhmary
, 1996"
Report, it
1. A Hearing is achedullld In Court Room No. J,t. ., of the
Cu.rland j:?~ Court Houae on the ;,~-ti day of '~1A..7 ,
1996, at ,:, .m. at which time testimony 1n 'tf\ls case will be
taken. At t, s 8aring, the Mother, Catherine H. Griggs, shall be deemed to
be the moving party and shall proceed Initially with testimony. Counsel for
each party shall file with the Court and oppoalng counsel a memorandum
.ettlng forth their position on custody and also setting forth a list of
witnesses who will testify at the Hearing along with the anticiP4ted
testimony of each witneas. This memorandum shall be fllod at leaat ten (10)
days prior to the Hearing date.
2. In the ev~nt either party retains an expert for purposea of further
eVal',ation of the custody situation, that party shall provide information
concerning the expert and any supplemental repon ta oppoalng counael ..It
least ttn (0) days prior to the Hearing date. An expert will not be
p*rmltttd to testify at thll /learing unleas a written report is provided to
opposing counsel within the foregoing time frame. In the event the parties
are Ilatistied with the written report, the parties may stipulate to the
adniasion of s profesllional's report Into the record in lieu of that
profeasional's testimony.
3. Pending further of this Court, the Mother, Catherine H. Griggs, and
the Father, Timothy W. Griggs, shall have shared legal custody of Zachary R.
Griggs, born November I, 1984, Amber Sunshine Griggs, born December 29, 1986
and Jacqueline A. Griggs, born September 10, 1988. The Father shall have
primary physical custody of the Children.
4. The Mother shall have partial phYSical custody of the Children on
alternating weekends from Friday after school until Sunday evening at 7100
p.m.
5. The parties shall share custody of the Children on Easter Sunday in
1996 at times to be mutually agreed upon by the parties.
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TIMOl'I:'l W. GRIGGS,
Plaintiff
IN THE COURT OF ca-It<<JN PLEAS OF
C[JMBERI,ANO COUN'l'Y, PENNSYl.VANIA
va.
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NO. 94-0569
CIVIL TERM
CATHERINE H. GRIGGS,
Defendant
CIVIL ACTION - LAW
cusroOY
amIIlR 01' <nJR'1'
NID tor, this 2, .," day of ,) ,~
I,lpon consideration of the attached Custody Conciliation SU1rmary
is orderecl and directed as followsl
, 1996,
Report, it:
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1. A Hearing is scheduled in cou):'t Room No. ~ ), of the
cuni:>erland ~:~./~ Court House on the ;,~-tA day of '1.1.. 1 ,
1996, at <"~I .m. at which time testimony in a case will be
taken. At t s Hearing, the Mother, Catherine H. Grl9gs, shall be deemed to
be the moving party and shall proceed Initially with testimony. Counsel for
each party shall file with the Court and oppcllJing counsel s memorsndum
setting forth their position on custody and also setting forth a 1 ist of
witnesses who will testify at the Hearing slong with the antiCipated
testimony of each witness. This memorandum shall be filed at least ten (10)
days prior to the Hearing date.
2. In the event either party retains an expert for purposes of further
evalustion of the custody situation, that party shall prOVide information
concerning the expert and any supplemental report to opposing collnsel at
least ten (10) days prior to the Hearing dllte. An expert will not be
permitted to testify at the Hearing unless s wrItten report is provided to
opposing counsel within the foregoing time frame. In the event the parties
an satisfied with the written report, the parties may stipulate to the
admission of a professional's report Into the record in lieu of that
profesalonal's testimony.
3. Pending further of this Court, the Mother, Clltherine H. Grlg9s, and
the Father, Timothy W. Griggs, shall have shared legal custody of zachary R.
Griggs, born November I, 1984, Amber Sunshine Griggs, born December 29, 1986
and Jacqueline A. Griggs, born September 10, 1988. The Father shall have
primary physical custody of the Children.
4. The Mother shall have partial physical custody of the Children on
alternating weekends from Friday after school until Sunday evening at 7:00
p,m.
5. The parties shall share custody of the Children on Easter Sunday in
1996 at times to be mutually agreed upon by the parties.
TIMOrHY W. GRIGGS, I IN THE COURT OF CC>>IMON PLEAS Ot'
Plaintiff I CUMBERLAND COUNTY, PENNSYl.VANIA
I
VII. I NO. 94.0569 CIVIL TElUol
I
CATHERINE H. GRIGGS, I CIVIL ACTION - LAW
Defendant I CUSTODY
PRIQ{ JlJD(IBr Bdgor B. Sayley
WSTOOY aJoICIJ.IATI<Jf IUllARY RJIlIlaf1'
IN ~ WITH aKl8RLANO CXUfl'Y RUtH CI CIVIL m;..NIllRB
1915.3.6, the undersigned Custody Concillstor submits the following report 1
I. The relevant information pertaining to the Children who are the
subjects of this litigation is as followsl
~
Zachary R. Griggs
Amber Sunshine Griggs
Jacqueline A. Griggs
BIRTHDATE
CURRENTLY IN CUSTODY OF
November I, 1984
December 29, 1986
September 10, 1988
Plaintiff/Father
Plaintiff/Father
Plaintiff/Father
2. A Conciliation Conference was held on January 16, 1996, with the
following individuals in attendance I The Mother, Catherine H. Griggs, with
her counsel, James K. Jones, Esquire, and Joan Carey, Esquire, counsol for
the Fathor, Timothy W. Griggs. The Father was not able to attend the
Conference due to a miscommunication with counsel. However, Ms. Carey wss
able to contact Mr. Griggs by telephone to discuss developments during the
Conference.
3. By prior Order of this Court dated February 15, 1994, the Father
was granted primary physical and legal custody of the Children and the
Mother was to have periods of partial custody by mutual agreement of the
parties. Since the time of that Order, the Father has had substantial
health problems and the parties agreed tnat custody should be transferred to
the Mother on November 9, 1995, during the Father's hospitalization. After
his hospitalization, the Father attempted to regain custody of the Children
but the Mother refused. on a Petition for Special Relief, the Father
obtained an Order from thlo Court dated Decell'ber 26, 1995 awarding the
Father primary physical custody of the Children pending the Custody
Conciliation Conference. The Order further provided for the Mother to have
partial custody of the Children on alternating weekends from Friday after
school until Sunday evening at 7100 p.m.
4. The Mother's position on custody is SS follows I The Mother filed a
"etition for Primary Custody on December 14, 1995 lifter hllving had the
Children reside with her since Novear 9, 1995 during the Father'.
ho.pitalhation. The Mother believes thllt the Ii'lIther'a aerious mediclIl
problema (including removlIl of hia stomach, repeated operlltions and multiple
blood clots) prevent him from being able to provide adequllte care tor the
Children. The Mothtr lllao noted thllt the Father h/l.d been diagnoaed with
manic-depressive disorder. The Mother stilted that the Children had adjusted
well to the IIgreed upon change In cuatody in Novear 1995 IInd had been
doing better in the Cllrlisle School District from November through Decear
than they had been in the Shippensburg School District where the F/l.ther
resides. In response to the E'ather's concel:'ns thllt the Mother'lI living
situation is not adequate for all three Children, the Mother atllted thllt her
one bedroom apartment which she sharea with a rOOflllll\te, includes one
bedroom, one bathroom, a kitchen and a livingroom. The Children sleep on
separate fold-up cots in the livingroom. According to the Mother, this
arrangement worked well over the two month period she had custody. The
Mother, through counsel, indicated thllt she would be interested in having a
psychological evaluation performed at the Steven's Cent.er for both parties
and the Children to assist In resolution of thi~ custody matter.
5. The Father's position on custody is as follows I The Father's
position 11/1 expressed by counsel at the Conference, was that the Father's
health is improving, he is home from the hospital and is not curr:ently
employed. The Fllther believes he i8 physically IInd otherwise able to care
for the Children as primary custodian. The Father expressed concern that
the living, and pIlrtlcularly sleeping arrangements, at the Mother's
apartment are inappropriate and sufficient tor thoi Children. The Father
alleged that, due to pIlst incidents of physical abuse of the Children by the
Mother, it is not in the Children's best interest to reside with her. It
should be noted that the Mother denied the Fllther's allegations of lIbuse Ilnd
also made allegations IIgainst the Father concerning spouslIl abuse. The
Fllther's counsel indicated that although she does not believe a
psychological evaluation Is necessary at this point, she will consult witt)
her client to determine whether a joint evaluation would be acceptable.
6. A Hearing on the issue of primary physical custody will be
necessary in this matter. The parties were able to agree on the terms of
custody pending the Hearing with the exception that the Father proposes that
the Mother hllve partial custody of the parties' two daughters on certain
weekends and of their son on other weekends so that all three Children are
not together for periods of weekend custody at the Mother's residence.
7. A Hearing in this case should take appl:'oxlmately one-half day. The
Concilla.tor recornnends that the existing Order, dated December 28, 1995,
remain in effect pending Hearing with additional provisions agr~ed upon by
the parties as Incorporated in the attached proposed Order.
~~~
DIllin S. Sun ay, Esqu e
Custody Conciliator
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TIMOTHY W. GR1.GGS,
Plaintiff/Respondent
IN THE COURT OF COMMON PLmAS or
ClIMBERI,AND COUNTY, PENNSYLVANIA
NO. 94-0569 CIVIL TERM
vs.
CIVIL Ac'rION--LAW
CATHERINre H. GRIGGS,
Defendant/Petitioner
CUSTODY
P~TITIQN TO WIT~DRAW
PETITION FOR MODIFICATION OF A PARTIAL
C U S1 0 D Y 0 R V I S I'r(\r.I.Q.ILQIiI:l.ER
1. On Deoember 14, 1995, Petitioner filed a Petition for
Modifioation of a Partial Custody or Visitation Order in the
above matter.
2. After the parties were unable to reach an agreement at
the oonciliation conference, this Court set a hearing for April
25, 1996 at 6:45 a.m.
3. Since that time, Petitioner has found it necessary to
reside at the Domestic Violence Shelter and therefore is not in a
position at this point to request custody of the three ohildren
involved in this matter.
4. Petitioner therefore desires to withdraw her Petition for
Modification of a Partial Custody or Visitation Order and oanoel
the
hearing
set
for
April
25,
1996.
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IN THE COURT OF COMMON PLEAS OIl
CUMfJERLANl> COUNTY .PENNSYLV ANIA
CIVIL ACTION - LAW
NO, 94-~6l) CIVIL TERM
TIMOTHY W. (]~.I(J(JS.
Phdntlft'
CATHERINE H, STONE.
(furmerly CATHERINE H, (IRI(J(JS)
Defendalll
IN CUSTODY
j>j{AECIPE
TO THE l'ROTHONOTARY:
Please enter lilY appearunce un behalf uf the Defellllalll, Cutherlne H, Slone, Illlhe ~bove.
captlulled lIIallel'.
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VS.
I IN THE OOlJRT OF CXX>lMON PLEAS 01'
I CUMBERLAND COONTY, PF.NNSYLVANIA
I
I NO. 94-569 CIVIL TERM
I
I CIVIL Am'IOO - LAW
I
1 IN CUS'l'OOY
TIMOl'HV W. GRIGGS,
plaintiff
CATHERINE H. STONE,
(formerly CATHERINE H. GRIGGS)
Defendant
CIUJIIlR 01' c:nRr
AND tUf, this t~-I-
cons1deration of the sttach.ad
and directed lIS followsl
-.-'
day of ~
CUstody Conc a on Re~,
, 1999, upon
it is ordered
I. 'l't1e priOt. Order of this COI;.~, dated January 25, 1996 is vacated
and replaced with this order.
2. The Father, Timothy w. Griggs, and the Mother, catherine H. stone,
shall have shared legal r.:ustody of zachary R. Griggs, born Novel!tler 1,
1984, Alrber sunshine Griggs, born December 29, 1986, and Jacqueline A.
Griggs, born BepterrtJer 10, 1988. F.ach parent shall have an equal right, to
be exercised jointly with the other parent, to make all major non-emergency
decisionll affecting the Children's general well-being including, but not
limited to, all decisions regarding their health, education and religion.
Pursuant to the terms of this paragraph, each pIIrent shall be entitled to
all records and information pertaining to the Children including, but not
limited to, school and medical records and information. 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 auch reasonable time as to make tho records and information of
reasonable use to the other parent. In the event any of the Children
requirea a major medical procedure or medical appointment for a significant
illness, the Father shall notify the Mother 14 days in advance or, as soon
as the Father himself receives notice.
3. ~e Father shall have primary physical cu~tody of the Children.
4. The Mother shall have partial physical custody of the Children on
alternating weekends, bGginning February 5, 1999, from Friday at 4130 p.m.
until sunday at 4130 p.m.
5. 'l't1e Mother shall have custody of tho Children over the Easter
holiday weekend fran Friday, April 2, 1999 at 12100 noon through Easter
sunday at 4130 p.m.
.
6, The perty receiving custody at the children shall be responsible
to provide transportation tor the exchange ot custody.
7. OUring his or her periods of custody with the Children, neither
party shall use, oell or possess illegal drugs. In addition, both parties
Mlall ensure that, during hill or her periods of custody, the Children are
not expoaecl to third parties who may be using, selling or posseeeing
Ulll9el drugs.
8. Th~ 'ather ohall make available to the Mother's counsel a letter
fran the Father's treating physician confirming the specific nature at tM
l1lItdications which are prescribed for the Father's medical conditions and
indicating the extent by which the Father's physician is monitoring or
asse..ing the continued use of the Father's prescribed lnedications.
9. The Mother sholl undergo monthly drug tests in February, March and
April which utilize the least expensive procedures tor detecting marijuana
and t'OCaine use. 'l't1e Mother shall be rosponsible for the costs at the
drug testing. The Mother shall make availoble to the Father's counsel tho
results of the drug testing pertormed pursuant to this provision.
10. Neither party shall do or say anything which may estrange the
Children fran the other perent, injure the opinIon at the Children as to
the other parent, or hamper the free and natural developnent of the
Children '. love and respect for the other parent. The parties sholl not
harass each other, but shall speak civilly to each other in the presence at
the Children. 'l't1e parties shall COI11llunicate directly concerning i..ues
involving the Children and the custody arrangements rather than involving
the Children unnecessarily.
11. 'l't1e parties and counsel shall attend an additional custody
Conciliation Conterence in the office ot the Conciliator, Dawn S. Sunday,
on April 27, 1999 at 9100 a.m.
12. This Order is entered pursuant to an agr.eement at the parties at a
CUstody Conciliation Conterence. The parties may modify the provisione ot
this Order by mutual consent. In the absence of mutual consent, the terma
ot this order shall control.
BY THE CXXJRT,
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eel Andrew C. Sheely, !.llquire - Counsel tor Father C"...tc- "...Jd<.4'.<l Q/l/H '
James J. Ksyer, !llquire - Counsel tor Mother - " .n
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K. Respondent. by his own admission. has stated that at times he is disoriented due to his
medication,
9, The RespondenlaCC\lmpanied Zachary to Uoston in December 199K,
10, The directions Klventothe Respondent by Shrinen ChlldrenlJurn Jlospital were not
followed aner tbe childsJ)ecember. 1 <)<)8 visit,
II, Zachary was scheduled for II return visit In February 1<)9<).
12 The Petitioner had volunteered tOllccoll1pany Zachary Ihr the February visit.
U Respondent, of his own volitionllnd without any advance knowled~e on the part of
the Petitioner. COlli acted the IIppl'llpriate individuals with Ihe Shrlners to cancel the February 1<)<)<)
visit. There was no medical or le~al basis lilr that cancellation and it negatively impacted upon
Zachary's health.
14, Petitioner made Indepcndentarrangements on her own in March of 1999 to
accompany Zachary thr a make-up visit to lIoston,
,,~, When the topic of accompanying Ihe child \0 Boston was raised at the most recent
conciliation conlerence which occurred in April, 1 <)99, the Respondent objected to the Petitioner
accompanying Zachary to Boston for lurther trips, There was no basis slllted allhe conclliallon
conterence till' Ihls ,)bjecllon,
16, The parties were unable to resolve their dltTel ences in the April 1991) conCiliation
conterence In this, lInd Ihls malleI' has been Ihrwarded to the Court for a hearing that has not yet
been scheduled
17. On or about April 29, 1999. the Respondent was required to ~o to the hospital as a
result of his digestive condition, This hospital stay lasted several days,
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERl,AND COUNTY, PE:NNSYLVANIA
CIVIL ACTION- LAW
NO. 94-569 CIVIL, TERM
'1' I MO'rHY W. GR lOGS,
Plaint if f
CATHERINE H. STONE,
Defendant
IN CUSTODY
ORDER OF COURT.
AND NOW, this 23rd day of June, 1999, upon
consideration of Defendant's petition for Special Relief
Pursuant to Pa. R.C.P. 1915.13, and following a hearing, the
petition is granted to the extent that hereafter the parties
shall alternate their presence at the medical treatment of their
son, Zachary R. Griggs (date of birth NQvember I, 1984), in
Boston, Massachusetts, with the father to proceed with his
presence first in the forthcoming treatment and follow-up visit
of the child and the mother to be with the child on the next
treatment and follow-up visit. Thereafter, the parties shall
continue to alternate in this manner.
By the Court,
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Andrew C. Sheely, Esquire
127 South Market Street
Mechanicshurg, PA 17055
Attorney for Plaintiff
James J. Kayer, Esquire
4 East Liberty Avenue
Carlisle, PA 17013
Attorney for Defendant
tsrs
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from zaohery's medioal treatment for piok-up by Pefendant, and
B. Defendant IIhal! enjoy phyllical oustody of the ohildren
oommencing on Friday, August 6, 1999 at 4130 p.m. through Sunday,
August 8, 1999 at 4130 p.m., and
C. Defendant shall enjoy physical custody of the children
commencing at 4130 p.m. on Thursday, August 12, 1999 through
Thursday August 19, 1999 at 4130 p.m., and
D. Defendant shall enjoy physical custody of the children
commencing on Friday, August 27, 1999 through Sunday, August 29,
1999 at 4130 p.m.
E. Plaintiff shall enjoy physical custody of the children at
all other times during the months of July and August not
specifically identiUed as Defendant's custody period in Paragraphs
A - D above.
F. Defendant shall pick-up the children at the commencement
of Defendant's period of custody at Plaintiff's residence and
Plaintiff shall pick-up the children from Defendant's residence at
the end of Defendant's period of Custody.
Andrew C. Sheely, Esquire
Attorney for Plaintiff
Jame~ J. Kayar, Esquire
Attorney for Defendant
BY TlfE COURT,
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TIMOTHY W. GRIGGS,
Plaintiff
IN THE) CXlURT OF CXXolMOO PLEAS 01'
CUMBERLAND COUNTY, PmNNSYLVANIA
vs.
NO. 94-569
CIVIL TERM
CATIIEIUNE It. STONE,
(formle-ly CATHERINE It. GRIGGS)
Defendant
CIVIL ACTION - LAW
IN CUSTODY
f!.DIlR 01' ~
AI<<) tQf, this \;}U day of \..-
cons idee-at ion ot the at.tached CUstody conc
and die-ected as tollowSI
I. A Headng is scheduled in COue-t Room *~ot the
CurrtleC'land County Court HoulJe, on the \ ~ day ot ~,
1999, dt 4.lS o'clock c... .m., at Which time testi ny w taken.
Foe- purposes of thIs Headng the Father shall be deemed to be the moving
party and Ilhall pt'oceed initially with testimony. Counsel for the pae-ties
8hall tUe with the Court and opposing counsel a MemorandLlll setting foe-th
each party'u position on custody, a list of witnesses who are expected to
testify at the Headng, and a Slll11l18ry of the anticipated testimony of each
witness. These Memoranda shall be filed at least ten days pdor to the
Heae-ing date.
, 1999, upon
ie ordered
2. The pdor order of this Court, dated February I, 1999 is vaGated
and replaced with this Ordee-.
3. The Father, Timothy W. Ge-iggs, and the Mother, Catherine H. Stone,
ehall have shared legal custody of Zachary R. Gdgge, born Noveriler 1,
1984, Amber sunehine Griggs, born December 29, 1986, and Jacqueline A.
Griggs, born Septeriler 10, 1988. Each parent ehall have an equal right, to
.be exercieed jointly with the other parent, to make all major non-emergency
dec1eiollll affecting the Childe-en'e general well-being including, but not
limitltd to, all decisions regarding their health, educ-'tion I'IncJ religion.
pureuant to the tet'lM of this paragraph, lIach parent ehall be entitled to
all recorde and infot'lMtion pertaining to the Childr~n inclUding, but not
limited to, school and medical records and info~l~tion. To the extent one
perent has possession of any such records or information, that parent shall
be required to share the same or copiee thereof with the other parent
within such reasonable time as to make the records and infotTll8tion of
re4ltonable use to the other parent. In the event any of the Childnn
requires a major medical procedure or medical appointment for a significant
illness, the Father shall notify the Mother 14 days in advance or, as soon
as the Father himself receives notice.
4. The Father shall have primary physical custody of the Children.
5. The Mother shall have partial Physical custody of the Children 00
alternating weekends from friday at 4130 p.m. until Slmday at 4130 p.m.
6. In addition to the Mother's regular weekend periodS of custody,
the Mother shall also have custody of the Children over Mother's Dey
weekend, from Friday at 4130 p.m. until Sunday at 4130 p.m., and during one
full week in July and 1n August (to include an additional. weekend in each
month) .
7. The party receiving custody of the Chilr.lren ahall be responsible
to provide transportation for the exchange of custody.
8. During hie or her periodS of custody with the C,hUdren, neither
party shall use, sell or possess illegal drugs. In addition, both parties
shall enllure that, duriny his or her periOOIl of custody, the Children are
not exposed to third parties who may be using, selling or possessing
illegsl drugs. Neither party shall drink alcohol to exceSll, nor allow
third parties to drink alcohol to excesll, during his or her periodS of
custody.
9. Neither party shall do or say allY thing which may ellcrange the
Children from the other perent, injure the opinion of the Children as to
the other parent, or hamper the free and natural development of the
Children'lI love and respect for the other parent. The partiee 8ha11 not
harass each other, but 8ha11 epeak civilly to each other in the pre8ence of
the Children. The partie8 8ha11 comnunicate dir.ectly concerning iS8ues
involving the Children and the cU8tody arrangements rather than involving
the Children unnece88arily.
10. In the event the parties believe that an agreement can be reached
without the neceseity of a Bearing, counsel for either party may contaot
the Conciliator to schedule an additional custody COnciliation COnference.
BY THE COORT,
J.
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COI
Andrew C. Sh..ly, Esquire - Counsel for father . , t'
J8m88 J. Kayerl Eaquire - Counsel for Mother ..., \"cill.d i'.\o ,..,
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Plaintiff
VB.
I IN THf) CXlURT OF CDlMOO PLEAS Of
I CUMBEIU,AND COON'1'Y, PENNSYLVANIA
I
I NO. 94..569 CIVIL TERM
I
I CIVIL ACTIOO - LAW
I
I IN CUSTODY
CATHERINE II. STOOE,
(formerly CATHERINE H. GRIGGS)
Defendant
PRIOt JWGII Mgar B. Bayley
~ axILIATI~ IIlIIWlY RIll'Qft'
IN AOCXlUlMCI! WITH aJGlI!RLAND CXUf1'! IWLIl at CIVIL 1'Rt);.,'"
1915.3-8, the underlligned Custody Conciliator submits the following reportl
1. The pertinent information concerning the Childrlln who are the
aubjeotll of thiB litigation ill as fol10wIII
~
Zachsry R. Grigga
Amber Sunshine Griggll
Jacqueline A. Gri9g11
MTB at BIRTH
WlRRi'1'LY IN CUfJl'OOlI'.J!:
Father
Father
Fathtl.'
November 1, 1984
December 29, 1986
. september 10, 1988
2. A Conciliation COnference was held on April 27, 1999, with the
following individuala in attendance I Tha Father, Timothy W. Griggs, with
his counllel, Andrew C. Sheely, Eaquire, and the Mother, Catherine H. stone,
with her counael, Jamell J. Kayer, Esquire.
3. ~lill Court entered an order dated February 1, 1999, reflecting the
parties' agreement at a Conciliation Conference in January under which the
Father continued to have primary phyaical cuatody of the Children and the
Mother would have partial custody on alternating weekenda. The additional
COnference was scheduled in order to aaaist the parties in establishing a
swrmer CU8tody IIchedule. Just aB the partiea had reached an agreement at
the Conference on arrangementa for the IIwrmer, the Mother requested a minor
change to the alternating weekend Bohedu1e and the Father became enraged.
All a result, the Father demandad a Hearing to eatablillh a swrmer schedule.
The Father 'a demeanor throughout the Conference wall hostile and
antagonistic, and un1es8 there is a change in attitude, it will be very
difficult for the parties to auccessfully manage an ongoing cuatody
schedule for any length of time.
4. The Mother's poeition 011 CU8tody ia all follows I The Mother
believes the alternating weekend achedule hall been going relatively well
with the exceptic..n of one incident which occurred when the Father Wll8
hOllpitalized in March. Although the Mother would like t~ apend more time
with the Children, ahe agreed to the IIwrmer cUlltody IIchedule recommended in
the attached order. Near the end of the Conference, the Mother requested
that the alternating weekend schedule be modified 110 that the return time
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TIMOTHY <lRI<lGS
Plaintitl'
IN THE COURT Of COMMON I'U:AS 0'"
CUMlUiRI.ANl> COUNTY. PENNSYLVANIA
CIVIL ACTION. LAW
NO. CIVil, l)4.~69
VS,
C\TJIERINf. H. STONE
Dllf~ndant
IN CUSTODY
PI!~TI1'I()N t'OR ('ONn:MI"1' ANI) SPt:CIAl, RELIJi:F
COMES NOW, Plaintiff. Catherine II, Stone. by nnd thfl)u~h h~r allomey lames I.
Kayer, who docs hereby aver as Ibllows:
1. Petitioner is Catherine II. Stone. an adult Individual who resides at Apartment 3. 48
West J\1~h Street, Carlisle, Cumberland Coullly, Pennsylvania
2. R~spondent Is Timothy GrllL!l!s. an adult individual who resides at 127 South Market
Street, P.O. Box, 9~. MechwllcsburlL!. Pcnllsylvania.
3. The Parlies are the parents of three minur children, Zachary R. Gril!lL!s, born,
Novcmber I, 1984, Amber S. GriglL!s, born Deccmber 29. 1986. and lacqueline A. OrllL!l!S, born
September 10. 1988
4. This Honorable Court has issued an order dated May 12, 1999, authorizing the
mother 10 have partial physical custody of the children 011 alternatinlL! weekends from Friday at
4:30 p.m. until Sunday at 4:30 p.m.
5. The Petitioner arrived to pick up the children on or about lune 2,~, 1999 at 4:30 p.m, at
the Respolldent's residence. The Respondent and his wife refused the Petitioner access to the
children claiming It was their weekend despite the fact that they had enjoyed custody on the prior
weckend.
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6. 'I'h" P"t(tloner, throuih her counsel, notilled the Respondentthroul&h his counsel of
his fullure 10 ublde by the Court Order UM u desire for un IUIdltlonul weekend to Illuke up for lost
lime.
7. Onthu followinl& weekend, July 2,1999, the Petitioner urrived ut Respondent's home
to pick up the children. There wus no one utlhe Respondent's home.
H. Whell Petitioner locuted Respondent on July 2, 1999 ut his mother's n:sidence he only
hud custody of one of the children at that time. He refused to turn the child OWl' to the Petitioner
untlllocalluw enlorcement olllclals required him to do so.
9. Neither Respondent nor his wife disclosed the location of where the party's daullhler's
wcre 011 July 2, 1999.
10. Petitioner did notllet Wl opportunity to enjoy IlIlY time with the PlU1y's dauihters on
the weekend of July 2, 1999.
II. On Friday. July 9, 1999. Petitioner arrived at Respondent's residence to piok up the
children.
12. Respondent only allowed the Petitioner to toke the porties' 2 dauihters for the
weekend.
13. After 0 conference call1nvolvlnll both parties Wld their counsel, the Petitloller
,
,(
relented Wld only took her dauihters so as to avoid lurther Incident
14. Respondent hBS threatened to dlsrupt!letltloner's scheduled periods ofphyslcBI
cllstody for the remBlnder of the summer
1 S. Petitioner believes that bo.,ed upon the Respondent's activities over the past two
,
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weekends whell she attempted to obtllin custody ofthe children. thBtthe Respondent will deprive
her of Bccess to the children lor the remainder of the sumlller, Including the specll1ed periods of
vlsitlltlllllthat would allow her to spend one full week with the children In July Ilnd AUIIUSI.
16. This mailer is scheduled for udJudication on the issue of primary custody belilre Ihis
lIonofllble Court on September I, 1999 at 9: I ~ u.m.
17. When Petition hll.ll atll:mpted to utilize the local law allthoritlesto II.Ilsist her In
obtulnlnil custody. she hll.ll encountered Wl ut ullltude best described us umbivulencc due 10 the
litclthutthe exlsthlil Order does 1I0t specify which partlculur weekend belonils to which purty.
WIIElWFORE, the Petitioner requests this 1I0noruble Court to Issue Ull Order thut will
dcslgl1ute,thc spednc periods of custody until the reilulurly scheduled heurlnl! on September I,
I,)')'),
A. To Order u "muke up" weekend for the petitioner to provide her with addltionultime
Ihut she hus been deprived due to the Respondent's actions which constitute contempt of this
Court's Order.
B. Adjudicute the Respolldenllo be in contempt of the Court's Muy 12, 1999
Order.
C. To uwurd Petitioner her u\lomey's fees II.Ilsociated with the flling und presentutlon
of lhls Petition for Contempt Wld Special Relief us the Respondent's uctions huve been obdurute
und vexatious.
D. For other such relief us the Court muy deem appropriute.
,
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VEIWIJI 'A'I'ION ()III'WAI>INOS
The fllI'Cl!llllll/ dllCIIIIII'1I1 I" hilsl.,1 II III III IlIf"J'fIIIIIIOII whkh hils bel'lI llUlhl~red by lilY
Cllllll:iel Ulld IIlysl'lf IlIlh,' prl'pllrnlhlllllf Ih", IIclIlII!. '1'111' 111I1l/IHlg,' Ill' th,' dOCIIIIII'llt lIIuy,llI pm1.
bc Ihl' JllllgUlIgl' lIf my coullsel 1I11d Illll lilY llWII, I hllVl' l'eud till' sllItCJl1ellts mllllc In this
dllCUIll,mlllnd 10 th,! l'xlcnl thlll It b hllSI'd upon 1111'111'11111111111 which I hllVl' glVl'Il 10 IllY counsd,
II Is truc nnd CllITl!Cltlltlll' bcsI of Illy kllllW!l>,lgl'. infol'lllllllllllllnd bdid', 'I'll thl' l'xllmlllHlI the
Clllltl~lIls of Ihe Slul\'JIlCIIIs Ul'e thllt of clluns"', I huVl' "died IIpOIl CllIJllSI'1 III muklng this
Vcrllkullon, J IIlldCrslUnd thul flllsl' slillenl"UI., herdn un' Inudl' Nllb.ll'cllll Ih\' pl!llultil's llf 18 I'A,
c.S. !l 4904, rdullng 10 unsWOl'1I fnlsiflculllln III IIl1lhorllh's.
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I hereby certify that a true copy of the foregoing PETITION FOR CONTEMPT AND
SP.:CIAL RELIEF was served on the IIJllowlng person(s) by First Class mail, postaie prepaid
by lorwardlng n true and correct copy unto:
Andrew Sheely, Esquire
127 S. Market St.
MechanlcsburK. P A 17055
Dated:_ 7/1'5 I(/'~
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~unnrll1~d lhut the issues rulsed In thut petlll\lIl shull ubu hI' uddressed In the upeull1lng
Septell1h~r I, 1999 heuring.
Fulher dted tlmt he hlld l,'uncerns regllrdlng the ll1uther's ulleged drug use und prohlell1s
wllh heud lice us Ihe reusons why he llIed his Ik~ell1her 199K pelitlon, Al the Ilrst ('undlilltlon
Cunferen~e, Ih~ ll1uther IIgreed tu suhll111 vulunllll'i1y lu drul;! tests liS u cunditlon upun her
cuntinuing tu re~eive Ihe ~hildren. She eumpleled une drug lest which ~onnnlled tllUllhere wen!
no signs of drug use nnd the re\llIirell1ent till' further drug tests WIIS nol Incorporuled in IIny
suhselJuentugr~ell1enls,
The mother is pllrsulng prlll1l1ry physicul custudy uf Ihe children, us she is concerned thut
the FUlhcr's disuhililies pr~c1ud<J him Ihlln hdng un uetive und ell'ccliw curcgiver till' Ihe
children, The ruther's dlsuhllilies relJuire hllll tu he IIndel' cunSILIIlI Il1I'dicutlun und he hus been
observed lu be physlcully uud lllelllully dis'lrlcnted, us well us exhihiting u "huir-triggcr" lell1per
whieh reslllted him In wulklng Ullt un his eOllIll.eI, lhe mOlher und the eusllldy conc\liulor onlWo
sepul'lIle oeeuslol)s III euncllllltlun c'lnl'crences, The 1ll00her hilS gl'llve cuncerns regurdlng Ihese
eOlldilions IInd helieves lhllt ~lIsludy shuuld be chunged, The mUlher denies uny drllg IIse of her
own und believes LillY helld lice problell1thur IllIlY exist is orlg!nllting 1l001llhe Futher's hume.
^ heurlng Inlhis ll1ullel' hus been s...heduled helill'... this lIunOl'ublc ('uurllilr September I.
1999 ut 9: 15 U,Il1,
II, WITNESS LIST
I. Clltherlne Slone, DcI'cndunt The ~hlldren's muther will Icstlfy regurd!ng her
con...erns, und Llbuutlh... Futhel' LlIld the ...ur... Ihe ...hlldn:n re...elve In his h\lUsehold, liS well
us regurdlng the relutiunships thut she hus develuped with the children und condilions
within her own hUllle.
2. Keith Slunc.. The dcfendunl'~ hushund will tcstify cUllI:ernin/,\ cunditlons inllw
mother's home, diflkultics thuI the mOlhcr hus hud rCllurdin/,\ custody exehunlles, und
other ohservntiuns he hWI hud of the ehlldrcn's interucllon with lh~' FUlhcr.
3, The pmtlcs' chlldNn The defcndunl hus no ohJcclion IOlhe purtles' ehlldrcn
helnll Inl~~rviewcd hy the Court In chamhcrs,
lII, R.:l.m.' SOlI(i/IT
Thc I>elcndunl, C^TIIEIUNE STONI':, sceKs un Ordcl' revcrslng Ihc slutus quo, She
believes thut the ehildrcn's hest Intcrest is servcd hy prlmUry physicul custody helng pluced with
Ihe muther, Legul custody of thc chlldrcn shuuld contlnuc to he shurcd hOlween the parties.
Vlsltutlon und purllul physicul ~'uslody rights of the FUlher should he consistent with the husic
selledule currenlly In eflCCL Spedlkully, FUlher would enjoy ulternaling weeKends, ultel'llutlnll
holiduys, und slgnllieunt periods of lime riming Ihe SUllllller, ^llcl'lllltlvely, Ihe mother would
seck enhllneed lime with lhe children should Ihe COIIrt deem It most uppropriule to Illuinluln
primury physiclll cuslody wllh the FUlhcr, She helieves such cnhuncemenls should include visits
with Ihe children every three weekends oUI uf evcry lilur us well us splinlng the sum Iller more
equully helween lhc purcnls.
Flnully, us Ihe punies hllvc heen unwilling 'II' unuble tu uhide hy some of Ihe more
generic ordcrs Ihlll hllve heen In eflccl slncc Ihcy cOlllmcnced Ihis cuslody dlsputc, Dclcndllnl's
counsel helleves It would he mosl uppropriute to sped fy Ihc CXllct .lutes IInd fimes thutlhe pllrlles
would exchunge cuslody. Providing the purcnts \\Ith the l1exlhlllly to muke Ihe d~~cisl()lIs on
their uwn 01' 1'1 Illlllnluln some semblunce or order in udllllnlstcring the previous custody ordcrs
thut huve been cflccI hus not becn suecesslill und hus Icd Ihe mothcr to pursue the relief she
SOUlilht inthc Contemptllnd Speelul Relief Petitions,
R~~IW~lflllly ~lIbl1lllt~d.
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KIlY r 1111\11 UWII
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('n Ii k I' 17()13
(71 243-7'122
lUll ~S.I72.~726
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agreement as to custody, and agreed to attend a subsequent
conciliation conference in April of 1999 to confirm that mother
was complying with the requests of father.
On April 27, 1999, a subsequent conciliation conference was
held as a follow-up to the January 13, 1999 conference. An Order
of Court was entered granting Father primary physical custody and
granting mother partial physical custody, every other w8filltond and
a summer vacation period of one full weak in July and August.
Subsequent to April 27, 1999, additional hearings were held
to addreBB certain health cond.itions of the parties oldflSt ohild,
Zachary. In addition, on July 23, 1999, the parties entered a
consent agreement which provided mother and father with a specific
custody agreement as to dates and times. This Agreement was
incorporated as an Order of Court dated July 23, 1999.
A hearing is presently scheduled for September 1, 1999 at
9115 a.m. before the Honorable Edgar B. Bayley.
u.,. -I.II.b..unto in Hll.to.tt}'
Petitioner is Timothy W. Griggs, who currently resides in
Shippensburg, Cumberland County, Pennsylvania. He is the natural
father of the children. Respondent is Catherine H. Stone who
currently resides in Carlisle, Cumberland County, pennsylvania
17013. She is the natural mother of the children.
2
~he children lIubjeot to thill Petition al:e Zaohary R. Griqql,
D.O.B. 11/1/84, Arnller SUllshine Grigc}II, 0.0.0. 12/29/86 and
Jaoqueline A. Griggs D.O.B. 9/10/88. The partiel formerly relided
together until 1994. Since theil, Petitioner father has had
primary physical custody of thm children and continues to do 10
today. Petitioner resides with Ch4rlene Christmas, his conunon law
wife. Respondent reside her conunon law hUBband.
l,ate last year, Petitioner/Father petitioned for a
conciliation oonference to address the childrens' comments to
lather that mother was participating in drug related aotivities.
In addition, Petitioner/Father requested Mother to address a head
lice problem at her residence.
UI.J__A~.'1.llUt.tiL8...U.d
Petitioner Beeks maintain the conditions which the parties
have been residing wlth during the past 5 years. Petitioner seeks
the entry of a standard custody agreement, with provisions which
require mother to refrain from using illogal drugs and with a
condition that she address the haad Uce problem at her home.
~etitioner requests a specific custody order so as to eliminate
confusion and modification of custody orders which have been
direoted in the past.
3
Other issues with regards to oommullications between the
parties and the children, transportation and standard vaoation
sohedules and holiday schedules need to be outlined in a Court
order so as to elim.inate any doubt as to the opnration of suoll
issues in the future.
lYL_.l.I:.og.o u,Jl..I1.UU'U I, AD,!L~.u~.t.Dl(my
(1) Timothy W. Griggs, Petitioner/Father
Shippensburg, Pennsylvania
petitioner will testify as to the issueB lIet forth in the
underlying Petition and address his present concerns with
custody.
(2) Charlene Christmas, Spouse of Petitioner/tather
Charlene Christmas will testify as to the circumstances
oonoerning the allegations of drug use and head lice problems
as stated above.
(3) Counsellor from the Helen Stevens Center, Joan Sweigart.
Tho representative trom lie lens Stevens will address the
counseling that the children have been involved w.ith and
their observations as to the interaction between the children
and their mother.
(4) Kim Mohler, Shippensburg, Pennsylvania.
Ms. Mohler will address observatiolls which she has made as to
mother's language and behavior at custody exchanges.
(5) The children. Plaintiff consents to and requests an
opportunity tor the Court to discuss the custody iBllueB with
the children.
LJ.t...l.bl...Qf_.....UJ.IDl'D.!:.-1l J.J.~.U".I..oA.l
4
agreement as to oustody, and agreed to attend a subsequent
oonoiliation oonferenoe in April of 1999 to oonfirm that mot.her
wal oomplying with the requests of tather.
On April 27, 1999, a lIubseql)ent oonoiliation oonferenoe wal
held al a tollow-up to the January 13, 1999 oonferenoe. An Order
of Court was entered granting Father primary physioal custody and
granting mother partial physical custody, every other weekend and
a summer vacation period of one full week 1.n July and August.
Subsequent to April 27, 1999, additiollal hearings were held
to address certain health conditions of the parties oldest child,
Zaohary. In addition, on July 23, 1999, the parties entered a
consent agreement which provided mother and father with a specific
custody agreement as to dates and times. This Agreement was
incorporated as an Order of Court dated July 23, 1999.
A hearing is presently scheduled tor September 1, 1999 at
9115 a.m. ~efore the Honorable Edgar B. Bayley.
U.L.JlbJ.~An.t.i_'l!IL.Hl..t..o.r.y
Petitioner is Timothy w. Griggs, who currently resides in
Bhippensburg, Cumberland county, Pennsylvania. He is the natural
tather of the ohildren. Respondent is Catherine H. Stone who
ourrently resides in Carlisle, Cumberlitnd County, Pennsylvania
17013. She is the natural mother ot the children.
2
The ohildren supjeot to this Petition are Zachary R. Griggs,
O.O.B. 11/1/84, Amber. Sunshine Griggs, O.O.B. 12/29/86 and
Jacqueline A. Griggs 0.0.9. 9/10/88. The parties formerly resided
together until 1994. Since then, Petitioner father has had
pr.imary physioal custody of the children and continues to do so
today. Petitioner resides with Charlene Christmas, his common law
wife. Respondent reside her oommon law husband.
Late last year, Petj,tioner/Father petitioned for Ii
conciliation conference to addrees the childrens' comments to
father that mother was partioipating in drug related activities.
In addition, petitioner/Father requested Mother to address a head
lice proP1em at her residence.
~a_L,_8~qyu~ti~8~U~f
petitioner seeks maintain the cOllditions which the parties
have been residing with during the past 5 YEl8rs. Petitioner seeks
the entry of a standard custody agreement, with provisions which
reqUire mother to refrain from using 111ega1 drugs and with a
condition that she address the head lice problem at her hOlM!.
Petitioner requests a specific custody order so as to eliminate
contueion and modification of cUetody orders which have been
directed in the past.
3
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J, WESLEY OLER, JR,
JUDGE
GiCfJ~ IS.
~ f\t(,
ONE COURTHOlJSE SQUARE
CARLISLE, PA 17013
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va.
1 IN TilE (XlURT 0Ii' ~ Pl"EAS Of
1 CUMBERLAND COUNTY, PENNSYLVANIA
1
1 NO. 94-569 CIVIL TERM
1
1 CIVIL ^G"l'ION - LAW
I
I IN CUS'roDY
TIMOTHY W. GRIGGS,
plaintiff
CATIfERINI!l H. STOOEI (formerly
CATHERINE H. GRIGGS),
Defendant
QUlI!lR C6 alRT
AND tUf, this 'f d, day of , 2000, upon
consideration of the attacAt'd custody ia ordered
and directed as follows 1
1. The prior Order of this Court dated May 12, 1999 is vacated and
replaced with thia Order. 'rile prior Order of thb COurt dated JUM 23,
1999 Ilhall continue in effect.
2. The Father, Timothy W. Griggs, and the Mother, Catherine H. Stone,
shall have shared legal cuatody of Zachary R. Griggs, born November 1,
1984, Amber s. Griggs, born December 29, 1986, and Jacqueline A. Gri99s,
born Septeni:>er 10, 1988. Each parent shall have an equal right, to be
exercised jointly with the other parent, to make all lI'6jor. non-emergency
deciaione affecting the Children's general well-being inclUding, but not
limited to, all decisions regarding t.heir health, education and religion.
Pursuant to the terma of thill paragraph, each parent shall be entitled to
all records and infol:1lllltion pertaining to the Children including, but not
Umited to, school and medical recorda and information. To the extent one
parent has possession of any auch records or infol:1lllltion, 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 uae to the other parent. In the event any of. the Children
requirea a lI'6jor medical procedure or medical appointment for a lIignificant
illness, the Father aha11 notify the Mother 14 daYII in advance or, as soon
as the father himself rllceives notice.
3. The Father ahBll have pr.l.mary physical custody of the Children.
4. DUring the school year, the Mother shall have partial Physical
cuatody of the Children on alternating weekends from Friday at 4130 p.m.
through sunday at 4130 p.m. and on one additional Sunday per month frall
8145 a.m. until 4100 p.m. The Mother's additional period of custody on
sunday shall be scheduled to take plaoe on the weekend following the
Mother's' first weekend period of custody each month.
During the sunmer school break each year, the partieB shall
alternate having custody of the Children on a weekly ballis with the
exchange of custody to take place each week on Friday at 5100 p.m. The
sunmer custody I!Chedule ahall begin on the first Friday after the last day
of school with the parent having custody who would otherwise have had
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custody for the weekend under the alternating weekend schedule. The
alternating weekly eohedule shall end a1 the last Friday before achool
begina, at which time the alternating weekend IIChedule shall reaume for the
Ilchool year.
5. Dur:1ng the Ilumner achool break each year beginning in 200J., each
pllrty shall be entitled to have 2 weeks of vacation with the Children upon
providing 30 daYII advance notice to the other party.
6. During the remainder of the school break in 2000, the partieB
shall alternate having custody of the Children a1 a weekly bade with the
exchanges to take place on Fridays at 5100 p.m. all folloWlI1
The Father shall have cUlltody of the Children from July 21 through
July 28.
The Mother shall have custody of the Children from July 28 through
Auguet 4.
'lhe li'ather shall have custody of the ChUdren from August 4
th,rough August 11.
The Mother shall have cuatody of the Children from Auguat 11
through August 18.
'lhe Father shall have custody of the Children from Auguat 18
through Auguat 25.
The /!IChool year alternating weekend IIchedule shall begin with the
Mother having custody of the Children on Auguat 25, 2000.
7. The parties shall share or alternate having custody of the
Childrltll on holidaya aa follows I
A. allUB'11lM1 In 2000, the Mother shall have custody of zachary
for purpollllll of obtaining medical treatment for the Child in
Boston frOln llec..mer 12 through Decentler 26 and the Father
shall have custody of Amber: and Jacqueline during that period.
'l'tle Mother ahall have cUlltody of AnDer and Jacqueline from
December 26 through the day before IIchool resume. after the
chriatmas break and the Father shall have culltody of Zachary
during that period.
Beginning in 2001, the Christmas holiday ahall be divided into
Segment A, which IIhall run from Chrilltmas Eve at 12100 nooo
through Christmas Day at l2100 noon, Segment B, which !!hall
run from Christmaa Day at 12100 noon through Decen'ber 28 at
l2100 noon, and Segment C, which shall run from December 28 at
12100 noon through 12100 nooo on the day before sohoo1 relllllll8l1
after the holiday. In odd nuntlered yearll, t,he Mother shall
have oustody of the Children during segments A snd C and the
rather !!hall have cul!tody durill9 Segment B. In eVlln numbered
years, beginning in 2002, the Father 8hall have oustody of the
Children during Segmentll A and C and the Mother ahall have
CII/ltody during Segment B.
B. ~I The Easter holiday Bhall run trom after /lchool on the
last day of school before the holiday thro'J9h Easter Sunday at
5100 p.m. The Father /lhall have custody of the Children over
the Easter holiday in odd numbered years and the Mother ehall
have custody over the holiday in even nlmbered yearB.
C. '1'IlANMGIVINGI The Thank89iving holiday ehall run from after
iCYiOoI on the Wedneaday before '1'h4nk89iVil'ICJ through the sunday
after Thankll9iving at 5100 p.m. The Mother shall have culltody
of the Children over the Thanksgiving holiday in even numbered
year/l and the Father shall have cuatody of the Children over
Thanksgiving in odd numbered years.
D. MIIDUAL DAY/JULY 4th/LABCR MYI In even numered yeare, the
Mother shall have cuatody of the Children on Memorial Day and
Labor OIly and the ~'ather shall have oulltody on July 4th. Xn
odd numbered years, the Father shall have custody of the
Children on Memorial o.y and Labor o.y and the Mothel:' IIholl
have custody on July 4th. The periode of holiday CUlltody on
Nemorial o.y and Labor OIly shall run from 10100 a.m. until
7100 p.m. and the period of custody on July 4th ~hal1 run from
10100 a.m. until after the fireworka.
l!l. M01'lIIlR'S MY/'''TfIBR'S /)AYI The Mother ehall have custody of
the Children every year on Mother's Day from 10100 a.m. until
7100 p.m. and the Father sholl have cWltody of the Children
every year on Father's OIly from 10100 a.m. until 7100 p.m.
F. The holiday custody schedule shall Bupersede and take
precedenco over the regulllr custody IIchedule.
G. In the event the Mother'lS period of holiday cUlStody falls
immediately preceding or following her regular period of
culltody, the holiday/regular period of cllBtody shall run
continuouBly without interruption.
8. Both parties shall ensure that the Children attend their regularly
loheduled activitiea dUring his or her periods of oulltody. The pertiu
shall cooperate and behave in a civil manner toward each other when they
are both attending the Children's activities.
9. Xn the event the Mother obtaina counseUng for the Children, the
Mother IIhilll IIchedule all counseUllg lIelllSions in the swrmer during the
Mother's regUlar periode of cUlltody. During t;he school year, the Mother
shall advise the Father of the counaeling lIesaiona at; least 1 week in
advance and the Father shall make the Children available tor the
oounaeUng .
10. During hia or her periodll of custody with the Children, neither
party Bhall UIl8, sell or posseas illegal druga. In addition, both parties
Bhall ensure that, during hill or her periodfl of custody, the Children are
not exposed to third parl:ies who may be using, "elUng or polllleBaing
illegal drugs, Neither party .Mall drink alcohol to excess, nor allow
thircl parties to drink alcohol to excells during hill or her period. of
custody. In the event either party ill determined to be in violation of
thi. provie1on, the other party may petition the Court for a finding of
cont8fl1lt .
11. The party receiv1/l'iJ custody of the Children shall be responsible
to provide transportation for the exchange of cuatody with the excwption of
the Motherl" periods of oustody on sundaYII during the IIChool year and
during the IIchool year when the Mother hll8 custody of the r:hildren for
purposell of counseling session", in which Cll.e the Mother lIha11 provide all
transportation.
12. The perties shall follow the reccmnendiltiona of Jacqueline's eye
doctor. I within 10 dlYII of the date of this Order, the Father shall provide
to the Mother, thro~h coulllJel, 1111 information pertaining to the
Children'lI medical inaurance and the name. and telephone nUll'bere of any
medical professional. providing treatment for the Children.
13. Neither party .hall do or say anything which lMY e.trange the
Children frail the other parent, injure t.he opinion of the Children aa to
the other parent, or hamper the free and natural development of the
Children'lI love and reapact for the other parent. The partiell shall not
herus each other, but IIhall "peak civilly to each other in the presence of
the Children. The partie" shall corrmunicate directly concerning issues
involving the Children and the custody arrangements rather than involving
the Children unnecessarily.
14. This Order ia entered purl!luant to an agreement of the partiea at a
CUstody COnciliation Conference. The partiQs may modify the provisione of
thie order by nutual consent. In the ab.eence of nutual conaent, the terms
of this order ahall control.
BY THE COORT,
COI Anckw C. Sheely, Esquire - Counael for Father
JIIIlt. J. !<ayeI', Esquire - Coun.el for Mother
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TIMOTHY W. GRIGGS,
Plaintiff
I IN 'fHE CXXJR~' Of <XJt.1t.lOO PLEAS 01
I ClXolBF.RLAND GOONTY, PENNSYLVANIA
I
I NO. 94-569 CIVIL TERM
I
I CIVIL ACTION - LAW
I
I IN CUSTODY
VS.
CATHERINE H. STONE, (fo~rly
CATHIlRINE H. GRIGGS),
Defendant
PRIOt JWGII J. NNley Ole,.., Jr:.
aJ8'JmY aHlILIATlaf SlIIMARY RIJIIlR1'
IN AaXIUlANCIl WITH aJllIBRLNID cn>>m' RlJLI at CML 1Wl''J''I-U
1915.3-8, the undersigned r.ustody Conciliator submits the followi"9 reportl
1. The pertinent information concerning the Children who are the
aubjects of thia litigation ia 4S followal
!W!!
zachary R. Grigga
Amber S. Grigga
Jacqueline A. Griggs
MTl'I or BIRTH
November 1, 1984
December 29, 1986
September 10, 1988
aJUUm'J,y IN aJ8'lQ)J at
Father
Father
Father
2. A Conciliation Conference was held on July 20, 2000, with the
following incJividualll in attendance I 'Itle Father, Timothy w. Griggs, with
his counsel, Andrew C. Sheely, Ellquire, and the Mother, catherine H. stone,
with her counsel, James J. Kayer, Eaquire.
3. The partiea agreed to entry of an order in the form as attached.
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CUatody cenci iator
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MAR J 2 1002 'i)
. IN TIlE COURT OF COMMON PLEAS OF
. <'lJMJlERI.AND COUNTY, PI!NNSYLV ANIA
TIMOTHY W GRIGGS.
Pluintlff
v,
. CIVIL ACTION. I.A W
. IN CUSTODY
CATIIERINE II STON~:, (Illl111crly
CATHERINE II GRIGGS),
l>cfclldullt
. NO '14.,')0<1 CIVIL TERM
QRI";j\ Of' ('OlliU
AND NOW, this dllyof
,2002, upun cunsidenllioll uf thc ulluched
cUlI1plaint, it is hcrchy directcd thUlthe p1ll1ics lInd their rcspcctivc cuunscl uppcur bcfore,
, thc condlilllur, lit
,un thc
duyof
, 2002, lit 111" for 1I Prc.lleurinl! Custudy Confcrcncc, At such Cllllfcrencc, nn effOlt
will hc JIlude 1<) rcsolve thc issucs ill disputc; or if this cunnot bc lIccoll1plished, 10 definc und
narruw thc issues 10 bc henrd hy thc courtlllld to cllter into u tCJllpurury order, All children l\!lC
live or oldcr II1UY 1I1so be prcscntutthc c<lllfcrcncc Fllilure tu uppeur lllthe cunfcrcnce II1ny
pruvide grounds till' cntry of a tCll1p<ll'llry or pertnuncntordcr
FOR TIlE COURT
By:
Custody C<lIlcililltur
YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LA WYER OR CANNOT AFFOIW ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTII BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP
CUJllbcrlund County Illlr Assucilllion
2 Libcrty A venuc
C'urlisle, P A 17013
(717) 241).3166
AMEltlCANS WITII ()ISABIU'm;S ACT ()[o' 1990
The COUlt of (\lIlll11Un Pleus of CUJllbcrlulld Cuunty is requircd by law to comply with the
Alllericuns with Disllbilities ActoI' 1l)')O FllI' illfol'lllutiullllboutacccssihle flldlitics nnd
rcn.'llIlllble uccuJlllllodutions available to disahlcd illdividuuls having business bcforc the court,
plcll!le contact our office AlIlIIl'llllglllncnts must be lllllde atlclL,t 72 hours prior to any hcnlinll
or busines~ bcllll'e thc court, YOUlllustullcnd the scheduled cunference or hearing,
1"
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TIMOTHY W GRIGGS,
Pluinti 1'1'
: IN TIlE COURT OF COMMON PLEAS OF
: CUMBERI.AND COUNTY, PENNSYLV ANIA
v,
. CI V I L ACTION - I.A W
: I N CUSTODY
CATHERINE H STONE, (tlll'lllerly
CATHERINE ll. OI{J()()S),
Defendunt
: NO, 94-Sb9
CIVIL TERM
UJJTIO~ TO MOJ)....Y CllSTOl)Y ORm:R
I, The petition ufCatherine II, StOlle, by her llltorneys, the Family Law Clinic,
It
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respectfully represents that on August 4, 2000, an Order of Court wus entered for custody of
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ZuchlU)' R. (,riggs, bom November I, I 9114, Amber S. Griggs, blll'll December 29, 1986, and
Jucqueline A, Griggs, born Septelllbel' 10, 1988, atnle and COITeCt copy of which is attached us
Exhibit "A", Under the existing Order, the parents share legal custody, Futher hus primllry
physical custody of the children, lInd Mother has partiul physical custody of them, During the
school yeu." Mother is to have physicul custody of the children on altel'lHlte weekends from
Friday ut4:30 p,m, until Sunday at 4:.\0 pm, and one additional Sunday per mond> from 8:4S
a,m until 4:00 p,m, During the SUllllllel1ime, Mother and Father are to altel11ute weeks, and
1I0liduys are to be shared or ultcnHlled by the p1\l1ies us they mutuully ugreed,
2, This Order should be modi tied to give Mother plimury physical custody of the
children because:
u. Father's llIediclll clmdition hus rendered hilllunuble to cure Illr the children, Upon
illfonl1utionund belief, Futher is cUl1'ently hospilUIi7.ed and recovering thllll he1\l1 valve surgery
inllm1'isburg Hospitul.
b, CUl'I'ently, the children are being cm'cd Illl' by Futher's bubysitter for extended peliods
of time because of Futher's poor medicul condition.
:,
vs.
J ' IN TilE <XlURT Of <nIMOO PLEAS 01'
I CUMBERLAND COONTY, PENNSYLVANIA
I
I NO. 94-569 CIVIL '!'EIIM
I
I CIVIL I\C'I'IOO - [,AW
t
I IN CUSTODY
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TIMOl'HY W/'GRIGGS,
plaintiff
CATHERINE II. S~E, (formerly
CA'!'HERINE II. GRIGGS),
Defendant
,
auJBR 01 CXll\\'l'
. AND tQI, this ~~ dnyof OIl ('"" ",L .' 2000, upon
c""'e1~l"fl'!ijrJ'l .'11'. .'"he acr,:ic fI f.;lllJtdy '~~ITiirOr.~" T., il1 M"flL'r,:l
J1ndl'Jl'r.lic~ed as' loHowsl
1. The priol:' order of this CoUt't dated May 12, 1999 is vacated and
replaced with this order. The prtOI:' order. of thia Court dated June 23,
19~9 shall continue in effect.
2. 'ltIe Father, Timothy W. Gr.iggs, and the Mother, Catherine II. stone, ~!
shall have shal:'ed legal cUlltody of Zachllry R. Griggs, born November 1,
1984, Amber s'. Gdggs, born December. 29, 1986, and Jacqueline A. Gl:'igge,
born September 10, 1gee. Each parent shall have an equal right, to be
exercised jointly with the other. parent, to make all major non-emergency
dacillions affecting the Childrlln's genel:'al well-being inclUding, but not
limited to, ~ decisiona reqar.ding their health, education and religion.
Pursuant to t. terms of this paragraph, each parent shall be entitled to
aU records an information pertaining to the Children inclooing, but not
limited to, school and medical cecorclnl snd information. To the extent one
parent haa posa"aaion of llIlY such rocordB or information, that pBr.ent shall
be requiroo 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 par.ent. In the event any of the Children ,
requires a major medical pr.ooedure or medical appointment for a significant,'
illness, the Fathll~ shall notify the Mother. 14 days in adVllllce 01:', aa soon
as the Father himself receives notice.
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3. The Father shall have pr.imaty ~ysical custody of the Children.
4. During the school year, the Mother. shall havll partial physical
custody of the Childrell on altllr.nating '..eekends from Friday at 4130 p.m.
through Sunda~' at 4130 p.m. and on one additional sunda', per month frail
8145 a.m. until 4100 p.m. The Mother'lI additional period of cuBtody on
Sunday IIhall be scheduled to take place on the wellkend following the
Mother's firllt weekend period of custody each month.
During the llunll10r school break each year, the plIrties shall
alternatll having custody of the Children on a weekly basis with the
exchange of r.ustody to take place each week on f'riday at 5100 p.m. '!'he
Ilurrmer custody .uchedule shllll begin on tho first Friday after the last day
of IIchoo1 with the par.ent having custody who would otherwise have had
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custody for the w.ek.nd und.r the a1t.rnating week.nd schedule, '11l.
11t.rnating we.kly schedule shall end al the last Fr1day before . school
bec.11na, at wh1ch tillllt the alternating weekend eohedu1. shall resllll1fl for the
Ichoo1 year.
5. During the sunmer achool br'ak aach year beginning in 2001, Hch
party shall be entitled to have 2 weeks of vaclltion with the Children upon
PJ:'Oviding 30 daya IIcIvance notice to the other party.
6. During the remnin"er of the school break in 2000, the partieB
shall alternate having custody of the Children on a Ii'e.kly b4aia with the
exchallges to take place on Ii'ridays at 5100 p.m. 8B followsl
The rather ahal1 have custody of tho Children from July 21 through
July 28.
The Mother ahall have custody of the Children from July 28 through
Augll8t 4.
The Father ahall hav. cuatody of the Children from AugWlt 4
through AuguIJt ll.
'11le Mother shllll hllve custody of the Children from Auguat .11
through August lB.
The rather shall have custody of the Children from August lB
through August 25.
The school year alternating weekend IIchedu1e shall begin with the
Mother having custody of the Children on August 25, 2000.
7. '!tie pIlrties shall share or alternate having custody of the
Children on holidays as follollSI
A. ~I In 2000, the Mother ahall have custody of zachary
fOC' purposea of obtaining medical treatment for the Child in
Boeton fcan Oeclllltler .t2 thrr.lll<;lh ""oc:mber 26 tIIld the e'ather
bhell have eUlltody of Amber and Jacqueline during that periOd.
'1he Mother shall have custody of Amber and Jacqueline from
Dec~r 26 tl)rough the dllY before school reaLl1lea after the
Chrillt:mas brealt and the Father shall hsve cuatody of Zachary
during that period.
Beginning in 2001, the Christmas holiday shsll be divided into
Segment A, which Shllll run from Christmas Eve at 12100 noon
through Christmas OIly at 12100 noon, Segment B, which ahall
run from Christmas Oay at 12100 noon through tpcember 28 at
12100 noon, and &lgmAllt C, which Mall run frolll DeCember 2!1 at
l2100 noon through 12100 noon on the day before school resllll1flll
after the hol14ay. In odd numbered years, the Mother shall
have CUlltody of the Children during Segments A and C and the
father shall have euatody during Segment B. In even numb.red
years, beginning in 2002, the Father shall have custody of thll
Children during Segments A and C and the Mother IIh..!! fl..""
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Cll.8tody during Segment B.
S. ~I The Easter holidllY ahall run fran after achool on the
last--day of school before the holiday throU<Jh Eaater Sunday at
!5100 p.m. The Father ahall hllve cuatody of the Children over
the EaIJter holiday in odd numbered years and the Mother Mllll
have custody Over the holiday in even nUll'bered years.
C~ ~m" The Thankegiving holidllY shall run from after
_chool '!:lie WlIdneaday before 'l'hankegiving through the Sunday
litter Thll>&J<sgivil19 at 5100 p.m. 'lhe Mothet' shaU have CUlltocSy
of the Children over the Thank8'iJiving holiday in even numbered
years and the Father shall have custody of the Children over
'1'tIankagivil19 in odd numbered Yl/are. .
D. Hl.oJOlUJ\L UAlc/J'ULlt' 4~ DI\lt'. In even nunbtred years, the
MOEner ahlll! have cuatody of the Children on Memorial o.y and
Labor Oay and the Father shall have cuatody on July 4th. In
odd nllllbered years, the Father ehllll have custody of the
OIildren on Memorial o.y and Labor Day and the Mother &hall
hllve custody on July 4th. The periods of holiday CUBtody on
MellJorial o.y and Labor Day shall run fran 10.00 a.m. until
7100 p.m. and the period of custody on July 4th shall run from
10,00 a.m. until after the fireworks.
E. ~'S DI\lt'hAmBR'S Mlt'. The Mother BhaU have custody of
the Children every year on Mother's Day from lO.OO a.m. until
7.00 p.m. and the Father ehllU have cuatody of the Children
every year on Father'B Day from 10100 a.m. until 7.00 p.m.
r. '1'tIe holiday oustody achedule ahall lIuper.ede and take
precedence over the regUlar cuotody IIOhedule.
G. In the event the Mother's perie.:! of holiday custody faUa
in1nediately preceding or following har regular perie.:! of
OUIIte.:!y, the holiday/regular period of custody IIhall run .
continuou.ly without: interruption.
8. Both pertie. shall ensure that the Children attend their regularly
scheduled activities during his or her perioda of CUBtody. 'lhe perUea
ehaU cooperate and behav. in a civil lIlMner toward each other When they
are both attending the Children's activitiea.
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9. In the event the Mother obtaine counaeling for the Children, the
Mother IIhall schedule all counseling sessiona in the sunmer during the
Mother's reguler periods of CUBtody. During the school year, the Mother
.hall advise the Father of the counseling lIessions at least 1 week in
advance and the Fat,her ahall make the Children available for the
counaeling.
10. During hie or her periods of custody with the Children, neither
party ahall use, 11_11 or possess illegal drugs. In addition, both parties
shall eneure that, during hia or her periods of custody, the Children are
not exposed to third parties who may be using, selling or pollaessing
.
illegal drugs. NQither party shall drink alcohol to excess, nor sllow
third parties to drink alcohol to excess during his or her periods of
cu"tocly. In the event either par:ty ia determined to be in violation of
this provision, the other party may petition the Court for a f1ndill9 of
contempt.
11. The party ceceiving cuatody of the ChUdren IIhall be responsible
to provide transportation for the exchange of. custody with the axception of
the Mother's periods of cUilltody on Sunday" dudng the school year and
during the school year whllO the Mother hll8 cuatody of the Children for
purposes of counaeling sessions, in which case the Mother shllll pr9vide all
transportation.
l2. The par:ties ehall follow the reccxrrnendations of Jacqueline'lJ eye
dootor. Within 10 days of the date of thia order:, the Father shall provide
to the Mother., through counsel, all information pertaining to the
Children's medical inBurance llnd the names and telephone numbere of any
medical professionals providing treatment for the Children.
13. Neither party shall do or flay anything which may estrange the
Children from the other parent, injure the opinion of the Children u to
the other parent, or hamper thll free and natural development of the
Children's love and r:espect for the other parent. The parties shall not
harlll:lB each other, but shall apeak civilly to each other in the preaence of
the Children. TIIll partills shall conmunicate directly concerning iB"ues
involving the Children end the custody arrangements rather than involving
the Children unneceaearily.
14. This Ordar is entered pursuant to an agreement of the pl!rtiolJ at a
CU"tody Conciliation Conference. The part illS may modify the provisiona of
this order by nutual consent. In the absence of mutual consent, the tel:lllB
of this order shall control.
",
TRUE COllY rr."~ RECOIlD
In TOlllmuny ',,:' ,1\ L.
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;~~~,~1!..~ft' Vi.; A". (iJr/;slo p~
~:;t~' , QQ
, pr~th~~~rw
BY TlI.E CXlURT,
OCI An~ew c. Sheely, Esquire - Counlle1 for Father
James J. Kayer, ElBquire - Counsel for Mother
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Vi;lm'IC'A'J'ION
I vc:rify thlltthc: 811Ilc:mc:nts IllUdc in this pClilion lIrc truc lInd Clm'ccl. I undc:r8lund thnt
fulslI shllcmc:nls hc:rein urc subjccllu thc pCllUlti~s of I H PlI es ~ 4904 rcluth1llto unswom
fulsit1cUliollto lIuthoritie:s,
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ClIthe:l'ine H. Stone
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I, MCIlWI Mulonc, CC111t1ed LCl!ullntem, the Fumily Luw Clinic, hereby certify thllt IIIIri
servinllutrue l1Ild COlrect copy of n Petitiun to Mudify Custody Order on the followini penonl
by I1rlt clll8s U,S, MlIiI, poslllj!e prcplliJ, this 7th dllY of Murch, 2002:
Timothy W GrillllS
127 Hershey Roud
Shippensburll, P A 17257
Timothy W, Griggs
HUllisburll Hospitlll
III South Front Street
Hunisburll, PA 17101
Andrew C. Sheely
127 South Murket Street
Mechl1llicsburSI PA 17055
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FAMIL Y LA W CLINIC
4S North Pitt Street
Carlisle, PA 17013
717-243-2968
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TIMOTHY W. ORIGGS,
Pluintlff
IN THE COURT OF COMMON Pl.EAS OF
CUMBERLAND COUNTY, llENNSYl.VANIA
V8.
94-569
CIVIL ACTION LAW
CATHERINE H. STONE (timnerly Gri!!lls),;
Defcndunt
IN CUSTODY
PRIOR JUDGEI J, Wesley OIer, Jr,
CUSTODY CONCII.IATIQ~ SVl\JMARY 8f,~OR'(
IN ACCORDANCE WITH CUMBERI.AND COUNTY RUU OF CIVil,
PROCEDURE 1915.3-8, tho undersi!!ned Custody Conciliutor submits the following report;
I. Tho pertinent Inlonnutlon concemlrl!! the Children who ure the subjects of this litigation is
as follows;
&MI
D"Tt Q.' l)IR1'fI
CURRf;NTI.Y IN CUSTOQY QF
Zaehury Grllllls
Amber S. Origlls
Jacqueline Griggs
November 1, 1984
December 29, 1986
September 10, 1988
2, A Conciliutlon Conference was hcld on June 5, 2002, with the following individuals in
attendance; The Father, Timothy W. GriM!!S, with his counsel, Andrew C. Sheely, Esquire, and the
Mother, Catherine H. Stone, with her counsel, Bryon R. Kaster and Lucy Johnston-Walsh, Esquire.
3. The parties ugreed to entry of un Order in the foml as attuched.
Date
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_~L,,-1j~~d!f'}
Duwn g, Sunday, Esquire
Custody Conciliator
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CUM>3I;i". /'!'f) ',I.)JN IY
PENNSYl.VANI^
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8. The provisions of thi~ Order shall continue in effcct pcndillll UII uddltionul Custody
Conciliation Conference, which Il)ay be scheduled at the request ofthe Father's counsel, Ifnecel8ory,
BY THE COURT,
~fbQL.!
esley Oler, Jr. .
J,
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cc: Andrew C. Sheely, Esquire - Counsel for Father
Bryon Kaster and Lucy Johnston-Walsh, Esquire - Counsel for Mother
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