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HomeMy WebLinkAbout94-01166,, KRISTY M. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW IN CUSTODY PAUL E. GREEN, Defendant N0. 1166 CIVIL TERM 1994 ORDER OF COURT You, Paul Green, defendant have been sued in court to modify a Visitation Order of the child: Kaylee Green You are ordered to appear in person at , on _, at , _.m., for _ a conciliation or mediation ~rf ,/~ ~-:3a -y~9 _ a pretrial conference. , l /~ ~jt,~~ _ a hearing before the court C acs ~~ ~1 ~ vcc ~ If you fail to appear as provide SL ~` %S ~ ,custody or visitation may be entered against you ~~~ ~ ~ (r ,Test. r ~~ LL YOU SHOULD TAKE THIS PAPE ~`'J-~G• /~ (/ ~~ JU DO NOT HAVE A LAWYER OR CANNOT N~~ S~~ JO /~~ ~~• THE OFFICE "~Y/W SET FORTH BELOW TO FIND OUT WHERb ~ ~~~''~ ~(p, ~ ~y .LP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 AMERICANS NTTH DISAB1iLITIES ACT OF 1990 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 accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements nsust be made at least 72 hours prior to any hearing or business before the coon. You must attend the scheduled conference or hearing. KRISTY M. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :CIVIL ACTION-LAW IN CUSTODY PAUL E. GREEN, Defendant N0. 1166 CIVIL TERM 1994 ORDER OF COURT You, Paul Green, defendant have been sued in court to modify a Visitation Order of the child: Kaylee Green You are ordered to appear in person at , on _, at , _.m., for _ a conciliation or mediation conference. _ a pretrial conference. _ a hearing before the court. If you fail to appear as provided by this order, an order for custody, partial custody or visitation may be entered against you or the court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 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 accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. P KRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA on behalf of . her minor child, . CHRISTOPHER CLARK . CIVIL ACTION -LAW PROTECTION FROM ABUSE v. . PAUL E. GREEN, . Defendant : NO. 1166 CTVII, 1994 You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action promptly after this Petition, Order and Notice are served, by appearing personally or by attorney at the hearing scheduled by the Court and presenting to the Court your defenses or objections to the claims set forth against you. You arc warned that if you fail to do so the Court may proceed without you and a judgment may be entered against you by the Court, without further notice, for any money claimed in the Petition or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse Cazlisle, Pennsylvania 17013 717/240-6200 KRISTY M. GREEN, Plaintiff, on behalf of her minor child, CHRISTOPHER CLARK v. PAUL E. GREEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. f I66 CIVIL 1994 PROTECTION FROM ABUSE li.~• PETITION FOR 'it~111P9RatRi~PROTECTIVE ORDER The Plaintiff, through her attorneys, the Family Law Clinic, alleges the following: 1. Plaintiff is an adult individual who is residing at 519 Cherry Court, Cazlisle, Cumberland County, Pennsylvania 17013. Plaintiff brings this action on behalf of her minor child Christopher Clazk. 2. Defendant is an adult individual whose legal residence is 519 Cherry Court, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Defendant is temporarily residing at the home of Chazles and Tina Lewis, Hill Street, Mt. Holly Springs. 4. Plaintiff and defendant were married on July 31, 1993. 5. Plaintiff is the mother of Christopher Clark, who is three yeazs old. 6. Defendant is the stepfather of Christopher Clazk. 7. The Defendant has attempted to cause and has intentionally, knowingly, and recklessly caused bodily injury to plaintiff s minor child, Christopher Clazk. In addition, plaintiffs minor son has been placed in fear of imminent bodily injury and/or death. 8. On Monday, February 28, 1994, the defendant struck the plaintiffs son, Christopher on the right side of the temple, causing the child to fall to the floor and sustain a bruise. 9. The defendant has frequently called the plaintiff s child and other children in the household names including but not limited to, "piss cat" and 'shit hog". 10. The defendant and plaintiff are the parents of a daughter, ICaylee Green, born on August 22, 1992. 11. In November of 1992, the plaintiff had to call the police because the defendant had punched the plaintiff, locked himself in the house with ICaylee and refused to let the plaintiff in the house. 12. Plaintiff believes and therefore avers that her child Christopher Clark will be in immediate and present danger of serious abuse from defendant and that he is in need of protection from abuse. WHEREFORE, pursuant to the provisions of the "Protection From Abuse Act" 23 Pa.C.S. $6101 et seq., plaintiff prays this Honorable Court to grant the following relief: A. Grant a Temporary Order pursuant to the "Protection From Abuse Act". 1) Require the defendant to refrain from abusing the plaintiffs minor son, Christopher Clark, either personally or through his agents; and 2) Exclude the defendant from the residence at 519 Cherry Court, Carlisle, Cumberland County, Pennsylvania 17013. B. Schedule a hearing in accordance with the provisions of the "Protection From Abuse Act", and C. After such hearing, enter an order against the defendant, to be in effect for one year, as follows: 1) Directing the defendant to refrain from abusing the plaintiff's minor child Christopher Clark. 2) Prohibiting the defendant from having any contact with the plaintiff s minor child Christopher Clark (except as agreed to by the parties) including, but not limited to restraining the defendant from entering plaintifFs place of residence, and from harassing the plaintiff's minor child. 3) Granting possession to the plaintiff of the residence or household to the exclusion of the defendant by evicting the defendant. r~nrttvT II. IN FORI-~IA PAUPERIS 13. The allegations in paragraphs one through twelve are incorporated herein by reference. 14. Plaintiff does not have funds available to pay the costs of filing and service. WHEREFORE, plaintiff prays that the petition be filed and service shall be made without payment of costs per 23 Pa.C.S. §6106(b). Date 3~`~~G4 -ri Respectfully submitted, l t .~.._ ~:~ ~.4~-~- Ann St. Ledger Certified Legal Intern THOMAS M. PLACE LINDA E. FISHER ROBERT E. RAINS Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 or 717/240-5204 (Voicemail) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. I verify that the statements made in this Petition are true and wrrect to the best of my personal lmowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ~ !~~ sty M. Teen Date v ~ q~ t ?~ T O ~~ Cn ~~ ~ J. ~ ~•1 t N . .-~ f-~ i ~ r' ,.t . ~ ,. :_ ~ ~' MAR u 9 1994~~ KRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA on behalf of her minor child, of her minor child, . CHRISTOPHER CLARK . v, :CIVIL ACTION -LAW NO.1 t ~ b CIVIL 1994 PAUL E. GREEN, . Defendant :PROTECTION FROM ABUSE AND NOW, this ~D~'day of wt v c~ , 1994 at 9:oe A)vl., upon presentation and consideration of the within Petition, and upon finding the plaintiff's child, Christopher Clark, residing in Cumberland County, Pennsylvania, is in immediate and present danger of abuse from defendant, Paul E. Green, the following Temporary Order is entered. Defendant, Paul E. Green, is hereby enjoined from abusing or harassing plaintiff's child, Christopher Clazk, either personally or through his agents. Defendant, Paul E. Green, is hereby order to stay away from petitioner's residence at 519 Cherry Court, Cazlisle, Cumberland County, Pennsylvania. This Order shall remain in effect until pending further Order of the Court. You, Paul E. Green, aze ordered to appear in person at the scheduled hearing held on this matter on the /1.f~day of yY)Qitc~, 1994 at 3;~PM., in Courtroom No. S . Plaintiff may proceed in forma pauperis pending a further order after the hearing. Service of certified copy of the Petition and this Order shall be provided by the sheriff of Cumberland County. The Police Department of Cazlisle will be provided copies of this Order by attorney for i ~~ • ~ >> plaintiff, and are directed to enforce this Order by arrest for indirect criminal wntempt without warrant upon probable cause that this Order has been violated, whether or not the violation is committed in the presence of the police officer, 23 Pa. C.S. §6113. In the event that an arrest is made under this section, the defendant shall not be taken to jail but shall be taken without necessary delay before the Court that issued the Order. By the Court, ' "-r;~ci .~ ~~ t • KRISTY GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA on behalf of her minor child, CHRISTOPHER CLARK :CIVIL ACTION -LAW PROTECTION FROM ABUSE v. . PAUL E. GREEN, . Defendant : NO. 1166 OF 1994 ~/ ORDER OF COURT AND NOW, this +rf `4 day of Vl,(v a-~w 1994, the parties having reached an agreement on a disposition of this petition, the wurt does accept their agreement and orders as follows: 1. Without admitting any of the allegations of the petition, the Defendant agrees that he will not abuse, harass, or have contact with the Plaintiff s minor child: Christopher Clazk, personally or through his agents. 2. Defendant shall remove himself from the residence at 519 Cherry Court, Carlisle, PA, and he shall remain away from this residence for one year or until plaintiff and her minor child move out voluntarily, whichever date first occurs, except to see the daughter of the plaintiff and the defendant, or other children in household as agreed by the parties. This order shall remain in effect for one yeaz. The Police Department will be provided with a copy of this order by attorney for the Plaintiff and may enforce this order by arrest for indirect criminal contempt without warrant upon probable cause that this order has been violated, whether or not the violation is committed in the presence of the police officer. In the event that an arrest is made under this section, the Defendant shall not be taken to jail, but shall be taken without unnecessary delay before the court that issued the order. When that court is unavailable, the Defendant shall be azraigned before a District Justice, who shall set bail according to the provisions of Chapter 4000 of the Pa. Rules of Criminal Procedure. By the Court, ~, r i ~; J. ,. t ti 1 r ~, uu PH '9~1 .~,~ ,,,: ~:r ~ w I n KRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA On behalf of her minor child, CHRISTOPHER CLARK, CIVIL ACTION -LAW PROTECTION FROM ABUSE v. PAUL E. GREEN Defendant : NO. 1166 CIVIL 1994 This agreement is entered into this (~ ~"tiay of ~ y ~ ~ , 1994, between the Plaintiff, Kristy M. Green, through the Family Law Clinic, and Paul E. Green. The parties agree that the following may be entered as an order of court. 1. Without admitting any of the allegations contained in the petition, the Defendant agrees, for the mutual benefit of both parties, not to abuse the Plaintiffs minor child, Christopher Clazk, either personally or through his agents. 2. Defendant agrees not to harass Plaintiff s minor child, either personally or through his agents. 3. Defendant agrees not to enter or come within 100 yards of the Plaintiffs residence at 519 Cherry Court, Carlisle, Cumberland County, Pennsylvania, except when the parties have agreed to Defendant's presence on the premises for purposes of seeing the child of the Plaintiff and the Defendant or the Plaintiff's two other children. 4. The Defendant shall have no wntact with the Plaintiffs child, Christopher Clazk, except supervised visitation when agreed to by the parties. WHEREFORE, the parties request the court enter an order of court to reflect the above terms, to be in effect for a period of one year from the date of execution of said order. ~ ~ crr Iris .Green Defendant Plamdff Date oE~ ~- Ann St. Ledger Certified Legal Intern Thomas M. Place Robert E. Rains Linda E. Fisher Harvey A. Feldman Supervising Attorney The Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 717/240-5204 or 717/243-2968 >•„. _ .~ _. s ~` ;_, ~. h ~~ - - :7' o~ ..i .--=, .w KRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVAMA v. :CIVIL ACTION-LAW IN CUSTODY PAUL E. GREEN, . Defendant : N0. ~~lt~tCIVIL 1994 ORDER OF COURT AND NOW, this ~45ndhy of ~1`~~~h , 1994, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before, lF~. ~.~-uhc"/'~~•~~ ~~;'the conciliator, at ~"~h {~~ ,Cumberland County Courthouse, 3Ath/I In~nl. ~'~ on the day of ~ , 1994, at m., for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conferonce may provide grounds for entry of a temporary or permanent order. FOR THE COURT, Custody Conciliato / YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4th Floor CARLISLE, PA 17013 717/240-6200 ;,1, .'. NaR 11 3 4o PN '9~1 C)f ,: ~ '9FF~Cf CUMUTr;, ND ~n.Tar,Y PEHliSY(,Vdgi~~TY ,J COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. I verify that the statements made in this Custody Complaint are true and correct to the best of my personal lmowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. / ,0//. 'sry M. teen Dat ~ ~ KRISTY M. GREEN, Plaintiff, 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. I i (c(.e : NO. CIVIL 1994 PAUL E. GREEN, :CUSTODY Defendant You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Fourth Floor Carlisle, Pennsylvania 17013 (717)240-6200 3 ,... L.. '. KRISTY M. GREEN, ; IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW 1N CUSTODY PAUL E. GREEN, ~ ~(y(.~ Defendant : N0. CIVIL 1994 AND NOW, the Plaintiff, by her attorneys, the Family Law Clinic, sets forth the following cause of action: 1. The Plaintiff is Kristy M. Green, residing at 519 Cherry Court, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Paul E. Green, whose legal residence is at 519 Cherry Court, Cazlisle, but presently the defendant is staying at: 37 Big Spring Terrace, Newville, Cumberland County, Pennsylvania, 17241, the residence of Michael and Gail Marol. 3. The Plaintiff seeks custody of the following child: ~mg ~~ AEtti D.O.B. ICaylee N. Green 519 Cherry Court 18 months 8/22/92 Carlisle, PA 17013 4. The child was born out of wedlock. 5. The child is presently in the custody of Kristy M. Green, who resides at 519 Cherry Court, Cazlisle, Cumberland County, Pennsylvania 17013. 6. During the past five years, the child has resided with the following persons and at the following addresses: f ~1: ICrisry M. Green 519 Cherry Court 6/93-present Paul E. Green Carlisle, PA 17013 Shayne Clark Christopher Clark ICrisry M. Green 273 B East Pomfret Strcet Birth-6/93 Paul E. Green Cazlisle, PA 17013 Shayne Clark Christopher Clark 7. The mother of the child is Kristy M. Green, currently residing at 519 Cherry Court, Cazlisle, Cumberland County, Pennsylvania 17013. She is married. 8. The father of the child is Paul E. Green, whose legal residence is 519 Cherry Court, Cazlisle, Cumberland County, Pennsylvania; however, he is presently residing at the following address: 37 Big Spring Terrace, Newville, Cumberland County, Pennsylvania 17241. He is married. 9. The relationship of the Defendant to the child is that of father. The defendant resides with the following persons: ~tpg Relationship Michael, Gail and Jayce Marol friends 10. The relationship of plaintiff to the child is that of mother. The plaintiff currently resides with the following persons: dame Shayne Christopher I{aylee Son Son Daughter 11. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 12. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 13. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 14. The best interest and permanent welfare of the child will be served by granting the relief requested because: a) Plaintiff has been primary caretaker of the child since birth; b) Plaintiff provides the child with a home with adequate moral, emotional and physical surroundings as required to meet the child's needs; c) Plaintiff is willing to accept custody of the child; d) Plaintiff continues to exercise pazental duties and enjoys the love and affection of the child; 15. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, the Plaintiff requests the court to grant custody of the child. Date ~~ ~ ~` oCc- Ann St. Ledger Certified Legal Intern L ~ ~srel.c.~l, THOMAS M. PLACE ROBERT E. RAINS LINDA E. FISHER Supervising Attorney FAMILY LAW CLINIC j 45 North Pitt Street Cazlisle, PA 17013 717/240-5204 .. _. ,. a, x r~ ,._ ., -. MAR 1 ~ 1994~.~, 1CRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS Plaintiff, : OF CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION-LAW CUSTODY PAUL E. GREEN, Defendant : NO. ~~« OF 1994 c AND NOW, this 17~ day of March, 1994, upon consideration of the Temporary Custody Agreement entered into by the parties, the court orders as follows: 1. The Plaintiff and the Defendant shall have shared legal custody of their daughter, Kaylee Green. 2„ The Plaintiff shall have primary physical custody of Kaylee Green. 3. The Defendant shall have partial physical custody of Kaylee Green. 4. The Defendant shall have physical custody of ICaylee Green at times to be agreed upon by the parties. 5. ICaylee shall not be removed from the wmmonwealth of Pennsylvania, absent con~sent~from the Plaintiff. "6. The Defendant will refrain from the wnsumpdon of alcohol while Kaylee is in his custody. ~, ~~~ J. 07 s~ J,x W al ~~~i cayo= fyl 1ti O V 'L N .. :C Ca> a .+: j N .~afez m _~lJ mW •-FSa. Z O V MAR 1 a 19940-- IGt1STY M. GREEN, : IN THE COURT OF COMMON PLEAS Plaintiff, : OF CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION-LAW CUSTODY PAUL E. GREEN, Defendant : NO. ' ~OF 1994 TE1-"°'JRARY CtiSTODY AGREEM1~riT RE• KAYLEE GREEN ~.~ L This agreement is entered into this I ~ day of ~~^"` , 1994, between the Plaintiff, Kristy M. Green, through her attorneys, the Family Law Clinic, and the Defendant, Paul E. Green. The parties agree that the following may be entered as a wort order to be in effect until further order of this wort: 1. The Plaintiff and the Defendant shall have shared legal custody of their daughter, ICaylee Green. 2. The Plaintiff shall have primary physical custody of Kaylee Green. 3. The Defendant shall have partial physical custody of Kaylee Green. 4. The Defendant shall have physical custody of ICaylee Green at times to be agreed upon by the parties. 5. Kaylee shall not be removed from the wmmonwealth of Pennsylvania, absent consent from the Plaintiff. 6. The Defendant will refrain from the consumption of alcohol while Kaylee is in his custodhy. Dated: ") ~ Signed: 1,Gi_.J Kris M. n ~F .~,- Ann St. Ledger Certified Legal Intern aul E. Green ~! .li~L~ ~L~ Vii. -~, Thomas M. Place Robert E. Rains Linda E. Fisher Harvey A. Feldman Supervising Attorney The Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 n7/zao-s2oa or 717/243-2968 SHERII'F'S RETURN CCA?+IONWEALTH OF PENNSYLVANIA: COUfJPY OF CU~IDERLAND Kristy M. Green, on behalf of her minor child, Christopher Clark VS Paul E. Green In The Court of Common Pleas of Cumberland County, Pennsylvania No. 1166 Civil Term 1994 Temporary Protective Order Protection From Abuse and Notice Petition for Temporary Protective Order Robert L. Fink >b}4~d(i4)fXdir Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, Temporary Protective Order Protection From Abuse that he served the within and Notice Petition for Temporary Protective Order upon Paul E. Green the defendant, at 2:45 o'clock P .M. EST / SQ19mG on the 10 day of March , 19 94t 37 Bio Spring Terrace, Newville Cumberland County, Pennsylvania, by handing to Paul Green Temporary Protective Order Protection From Abuse a true and attested copy of the Notice, Petition for Temporary Protective, Order and at the same time directing his the "Notice to Plead" endorsed thereon. Sheriff's Costs: Docketing Service Affidavit Surcharge attention to the contents thereof and So answers: 14.00 ~ ~~ 2.00 23.28 Sworn and subscribed to before me this ~ day of `7)tc.,.,t~_ 19 ~'~ A.D. Prothonotary ~ R. Thanas Kline, Sheriff by ~~ Deputy Sheriff ~1 I(RISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN CUSTODY PAUL E. GREEN, . Defendant NO. 1166 CIVIL 1994 ORDER OF COURT AND NOW, 3~~5 1999, upon considerntion of the attached petition i is hereby directed that the parties and their respective counsel appear before r~`,( ~lc~.l - - ,the conciliator, at-14~~5+"'rl.l-!~r„~n~ ~ Cuv~lnrrlrrc~ CO . Cn~f hc~J`a on the ~~ day of h ,1999, at \p', ~O qm., for a Pre•Hearing Custody Conference. At such conferen e, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to detlne and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, Custody Conciliator ~~~ The Court of Common Pleas of Cumberland County is required bylaw to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 cc: .; , ~ , ,-;: ~~ ". c,91;'.,~a {:, :;: fly -~ ~. ~~~ ,~•a9.99 ~• cbj~~ ~'` ~ oy~ 3•a~•~ y'l ~"`.~' ~ s`ue`"` r iM-' ICRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA ~. :CIVIL ACTION -LAW IN CUSTODY PAUL E. GREEN, . Defendant : NO. 1166 CIVIL 1994 ORDER OF COURT You, I(rlsty M. Green, respondent, have been sued In court to enforce the Custody Order of the child: ICnylee Green. You are ordered to appear in person at on , at ,o'clock, M., for ^ n conciliation or mediation conference. ^ a pretrial conference. ^ a hearing before the court. If you fail to appear as provided by this order, an order for custody, partial custody or visitation may be entered against you or the court may issue a warrent for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 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 accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any henrtng or business before the court. You must attend the scheduled conference or hearing. BY THE COURT: Date• 1• IQiISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN CUSTODY PAUL E. GREEN, Defendant : NO. 1166 CIVIL 1994 PETITION TO ENFORCE CUSTODY ORDER 1. Pedtloner, Paul E. Green, By and through hie attorney, Lindsay Dare Baird, Esquire, respectfully represents that on the 5th day of September, 1997, an Order of Court was entered for Custody of the minor child, ICaylee Green, date of birth August 22, 1992. A true and correct copy of said Order is attached as Exhibit "A". 2. This Order should be enforced because Respondent, I(risty M. Green, natural mother of the child, has refused for the past year to allow visitation between Petltioner and the child. It is requested that visitation be enforced. 3. Respondent has refused to send Peddoner any school records and photographs of the child although directed to do so in the Order. 4. Respondent has moved and left no forwarding address or phone number with Petitioner rendering the Ordered telephone contact with his child impossible. 5. Petitioner may only place collect phone calls ns outlined in the PA Department of Corrections Telephone Procedures, attached as Exhibit "B". Respondent will have to accept the calls to enable Petitioner to maintain Ordered telephone contact with his child. Petitioner agrees to pay a percentage of the cost. WHEREFORE, Petitioner respectfully requests that the Court enforce the existing Order for Custody because it will be in the best interest of the minor child. Respc ully~su^bmitted, /~~ Lindsay Darc Baird, Esquire Attorney for Petitioner 37 South Hanover Street Carlisle, PA 17013 KRISTY M. GREEN, Plaintiff v. PAUL E. GREEN, Defendant IN TILE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY No. 116G CIVIL 1994 ORDER OF COURT AND NOW, this 5th day of September, 1997, upon consideration of the issue of custody of the parties child, Kaylee N. Green (date of birth, August 22, 1992), and pursuant to an agreement reached in open court among the parties and their counsel, William C. Vohs, Esquire, on behalf of Kristy M. Green, and Lindsay Dare Baird, Esquire, on behalf of Paul E. Green, it is ORDERED and DIRECTED as follows: 1. The temporary Order of Court dated March 17, 1994, is vacated. 2. The Plaintiff and the Defendant shall share legal custody of their minor child, Kaylee Green. ~. The Plaintiff shall have primary physical custody of the minor child, Kaylee Green. 4. The Defendant shall have visitation at any state correctional institution or prison or county prison that he is incarcerated every other Saturday, during normal visiting hours at that institution, but not longer than between 10:00 a.m. to 8:00 p.m. The Defendant is responsible for arranging transportation of the minor child for these visitations. The EXHIBIT "A" Defendant's family, specifically David or Margaret Iiandshew, may be utilized to transport Kaylee, so long as Kaylee is secured in a rear seat in a seat belt for the round trip to the institution. Any other contact by the Defendant or Defendant's family with Plaintiff other than related to the minor child is prohibited. 5. The minor child, Kaylee Green, shall not be removed from the Commonwealth of Pennsylvania without consent of the Plaintiff. 6. The Defendant may contact the minor child, Kaylee Green, by telephone one time per week between 7:00 p.m. and 8:70 p.m. on any night that is mutually agreeable by the parties. However, Defendant is enjoined from discussing any issues with the minor child, Kaylee Green, that do not relate directly with the minor child. The Defendant is not to call the minor child or the Plaintiff collect. He may, however, place third party calls to the minor child for these telephone contacts, and Plaintiff will use her best efforts to aid in the placement of such third party calls. 7. Plaintiff will use her best efforts to provide Defendant with school records and photographs of the minor child, Kaylee Green. In Tr rt.:: and tii:.: Tltis .....I ~ 'a` dr.; ~ ~ ... • •r1 .^•; haad :;r nca'~~.., 19.2.' ....~~. ~. ~..t.~,~ a',<..5....,.. '~~ Pruthor:o~ary ey the Court, J Nesley O1 Jr., WILLIAM C. VOHS, ESQUIRE For the Plaintiff LINDSAY DARE BAIRD, ESQUIRE For the Defendant wcy t COMMONWEALTH OF PENNSYLVANIA. DEPA1tTMEN7' OF CORRECTIONS INMATE TELEPHONE PROCEDURES 1. REMOVE HEADSET AND LISTEN FOR DIAL TONE 2. FOR ALL CALLS DIAL YOUR PIN NUMBER, THEN DIAL "0", THE AREA CODE, AND THEN THE NUMBER YOU WISH TO CALL. 3. IF THE PHONE NUMBER DIALED IS PERMITTED, BASED ON THE PREPROGRAMMED PARAMETERS, THE CALL WILL COMPLETE. 4. IF THE NUMBER DIALED IS NOT ALLOWED, YOU WILL HEAR A MESSAGE THAT SAYS "YOUR CALL CANNOT BE COMPLETED AS DIALED." 5. THE PARTY WILL NOW HEAR THE NORMAL "RINGING" OF THE CALLED PARTY'S PHONE. 6. WHEN THE CALLED PARTY ANSWERS THE PHONE THEY WILL HEAR THE MESSAGE "YOU HAVE A COLLECT CALL FROM INMATE JOHN DOE AT A COMMONWEALTH OF PENNSYLVANIA STATE CORRECTIONAL FACILITY. TO REFUSE THIS CALL HANG-UP. IF YOU ACCEPT THI_ SCALL DO-NOT USE CALL WAITING OR THREE WAY:CALLING FEATURES_OR YOU WIL~ CBE bISCONNECTED: ALL CONVERSATION AND CALL DETAIL EXCEPT APPROVED ATTORNEY CALLS, MAY BE MONITORED AND/OR RECORDED. TO ACCEPT THIS CALL DIAL 1 NOW." 7. THE CALLED PARTY MAY ACCEPT THE CALL WITH EITHER A TOUCH TONE OR A ROTARY PHONE. WHEN THE CALL IS ACCEPTED, THE CALLED PARTY WILL HEAR THE MESSAGE "THANK YOU." 8. EITHER PARTY MAY END THE CALL BY HANGING UP. 9. IF THl~CALLED PARTY ATTEMPTS A THREE WAY CALL, AT ANY TIME THE PHONE CON'~ROLLER WILL TERMINATE THE CALL,IF THE CALL,YED, PARTY ATTEMPTS TO RECEIVE A CALL USING CALL WAITING ~,LCgh~°: pVUILIt,TE~2JIAlNAT.E~. 10. ACCESS TO VARIOUS NUMBERS INCLUDING THE OPERATOR, 800, 900, 976, 411, 611, 911, AND 555-1212 ARE BLOCKED FROM THE INMATE TELEPHONES. 11. ALL RATES CHARGED ARE FIXED BY THE PENNSYLVANIA BOARD OF PUBLIC UTILITIES FOR COLLECT CALLS. I~4iIBIT "B" it r• %- ' - i ~ ,~~ _' `~ <' c_ ri' .i - t_ , ~ ~,`~ u '" -' - _ ~ is u r- i, . p~ :J . ~ ~ rJ .~ ... Y y. //4 ~ I verify that to the best of my knowledge and belief, the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of IS Pa.C.S.§4904 relating to unsworn falsification to authorities. /7~J ~• ~~ Paf/ul/E. Green ~i r.. ~, ~'~ °~ ~ ~ ~N <,: ~ ~~~ ~~~~ ..., .. a .• , KRISTY M. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V, CIVIL ACTION-LAW IN CUSTODY PAUL E. GREEN, Defendant NO. 1166 CIVIL TERM 1994 PETITION FOR MODIFICATION OF VISITATION ORDER PURSUANT TO PA R CIV P 1915 15(b) The Plaintiff, by her attorneys, the Family Law Clinic, respectfully represents that: 1. The parties are the parents of Kaylee Green, who was born on August 22, 1992. 2. On September 5, 1997 an Order of Court, a true and correct copy of which is attached, was entered granting Paul Green, the defendant/father, visitation rights regarding their daughter, Kaylee Green. 3. This Order should be modified because there has been a substantial change in circumstances and visitation between Kaylee and her incarcerated father is not in her best interests. 4. At the time Order was entered, Paul Green was incarcerated at the Mahoney State Correctional Institute. 5. On information and belief, the father was transferred from the Mahoney facility to the State Correctional Institution at Waymart because of his inability to get along with the other inmates and because of his proclivity to violence. 6. Kaylee currently resides with her mother in Shippensburg, PA. 7. Waymart is approximately a 360 mile round trip drive from Kaylee's residence, ~; nearly double the distance from her residence to Mahoney. 8. The existing custody order provides that two members of the father's family, David and Margaret Handshew, were to be used to transport Kaylee to and from these visitations with the father. 9. On information and belief, on one occasion, the Handshews picked up Kaylee ostensibly to transport her to see the father, but they did not do so. 10. The father was denied parole in January 1999. I1. Mandatory authority provides that there is a presumption that visitation of an incarcerated parent by his/her child is trot in the best interests of that child and that the incarcerated parent has the burden of proving otherwise. See Etter v. Rose, 454 Pa. Super. 138, 141, 684 A.2d 1092, 1093 (1996). 12. Under Pennsylvania statutory law, before making an order granting custody, partial custody or visitation to a parent who has been convicted of any of the criminal acts listed in the statute, the court is required to consider the criminal conduct and is also required to make a determination "that the parent does not pose a threat of harm to the child." See 23 Pa.C.S. § 5303. In meeting this obligation, the court is also required, per 23 Pa.C.S. § 5303(c) "to appoint a qualified professional to provide counseling to an offending parent" that "shall include a program of treatment or individual therapy." Additionally, the court is required to take testimony from that counselor "prior to issuing any order of custody, partial custody or visitation." 13. Under 23 Pa.C.S. § 5303, "a parent [that] has been convicted of or has pleaded guilty or no contest to" the crime of sexual assault (18 Pa.C.S. § 3124.1) is subject to the mandatory review and counseling requirements that are described in the prior paragraph. 14. On April 4, 1946, Paul Oreen, pleaded rolo contendere in this court to the crime of sexual assault (18 Pa.C.S. § 2!24.1) anti was consequently sentenced by this court to a sentence of "not less than 39 months, nor more than 7 years." She Commw. v. Green, 95-1105 (1996) (attached). 15. The provisions of 23 Pa.C.S. § 5303, have not been carried out and constitute a condition precedent to further visitation by the father. 16. The father is curcently incarcerated as a result of his holding the mother and their child in the family trailer against their will while threatening to kill them. 17. Because of past criminal acts directed against the mother, and because of threats made againt the child, Paul Green continues to pose a threat to the mother and her child. WHEREFORE, Ms. Green asks that the Court suspend the existing visitation order, prohibit Paul Green from talking with Kaylee by the phone, and direct that Ms. Green's only obligation be to provide Paul Green with a school photograph and report cards for Kaylee with the school and teachers' names redacted. It is further requested that this petition be heard simultaneously with Paul Green's Petition to Enforce Custody Order that is already scheduled for aPre-Hearing Custody Conference before Mr. Hubert X. Gilroy, Esq., scheduled for 10:30 A.M. on May 7, 1999. ~~~~ Matt ew Kloiber Certifidd Legal Intern ROBERT E. RAINS Supervising Attorney DONALD MARRITZ Staff Attorney FAMILY LAW CLINIC 45 N. Pitt. St. Carlisle, PA 17013 717 243-2968 VERIFICATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. 5 4904 relating to uneworn falsification to authorities. Date /~ r~.7f / ~~ -l 1 / ?~ ~ sty M. reen t _. ~.~ KRISTY M. GREEN, Plaintiff v. PAUL E. GREEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . CIVIL ACTION - LAW IN CUSTODY No. 1166 CIVIL 1994 ORDER OF COURT AND NOW, this 5th day of September, 1997, upon consideration of the issue of custody of the parties' child, Kaylee N. Green (date of birth, August 22, 1992), and pursuant to an agreement reached in open court among the parties and their counsel, William C. Vohs, Esquire, on behalf of Kristy M. Green, and Lindsay Dare Baird, Esquire, on behalf of Paul E. Green, it is ORDERED and DIRECTED as follows: 1. The temporary Order of Court dated March 17, 1994, is vacated. 2. The Plaintiff land the Defendant shall share legal custody of their minor child, Kaylee Green.. 3. The Plaintiff shall have primary physical custody of the minor child, Kaylee Green. 4. The Defendant shall have visitation at any state correctional institution or prison or county prison that he is incarcerated every other Saturday, during normal visiting hours at that institution, but not longer than between 10:00 a.m. to 8:00 p.m. The Defendant is responsible for arranging transportation of the minor child for these visitations. The Defendant's family, specifically David or Margaret Handshew, may be utilized to transport Kaylee, so long as Kaylee is secured in a rear seat in a seat belt for the round trip to the institution. Any other contact by the Defendant or Defendant's family with Plaintiff other than related to the minor child is prohibited. _ 5. The minor child, Kaylee Green, shall not be removed from the Commonwealth of Pennsylvania without consent of the Plaintiff. 6. The Defendant may contact the minor child, Kaylee Green, by telephone one time per week between 7:00 p.m. and 8:30 p.m. on any night that is mutually agreeable by the parties. However, Defendant is enjoined from discussing any issues with the minor child, Kaylee Green, that do not relate directly with the minor child. The Defendant is not to call the t minor child or the Plaintiff collect. He may, however, place third party calls to the minor child for these telephone contacts, and Plaintiff will us.e her best efforts to aid in the placement of such third party calls. 7. Plaintiff will use her best efforts to provide Defendant with school records and photographs of the minor child, Kaylee Green. ~^ - - ..~.: il2tld `a ..; ~• 1-C,• Proliionotary By the Court, J Nesley O1 Jr., {. _~. ~' I 3> WILLIAM C. VOHS, ESQUIRE `' For the Plaintiff i ~. ~' LINDSAY DARE HAIRD, ESQUIRE For the Defendant `: wcy ;. i i ~" { ~.. k ~; i; i i i i 1 ~. ~ ~l-.~ -q5 COMMONWEALTH V. PAUL EIIGENE GREEN OTNs E003970-1 E726578-6 E230426-0 IN THE COURT OF COMMON PLEAS OF CSTL03ERLAND COUNTY, PENNSYLVANIA s _ s 94-2000 CRIMINAL TERM AFFIANT: PTL. JOHN 3ANCENITO s 95-1105 CRIMINAL TERM CHARGE: (F) SEXUAL ASSAULT AFFIANT: TPR. LEONARD LANDER 95-0296 CRIMINAL TERM CHARGES (E) SPOUSAL SEXUAL . ASSAULT AFFIANT: CHIEF DUANE LEBO IN RE: NOLO CONTENDERE PLEAS & ORDER OF COURT AND NOW, this 4th day of April, 1996, the Defendant, Paul Eugene Green, appeared in court today represented by Samuel W. Milker, Esquire, Assistant Public Defender. Pleas era accepted se follows: =? ~~~ To 95-1105, the Court accepts a plea of 1's'oly ~s •: ~~ ~~ contenders to a charge of Sexual Assault, Count F, a vioiati~$~`~ :; m of 18 PS 3124.1 as provided by the Act 10 approved March 3lst~? 1995, to be effective 60 days after March 31st, 1995. m To 95-0296, Count E, the Court accepts a plea of polo contenders to the charge of Spousal Sexual Assault. The pleas of nolo contenders to these two charges are now accepted by the Commonwealth in full satisfaction of all outstanding charges presently pending against Mr. Green in this County. At the time that the pleas of polo contenders were accepted, the District Attorney related to the Court that a plea agreement had been entered into concerning the sentence on these two charges. I have heard the agreement. I will accept the agreement, and impose sentence ae follows: f~C'l'~ .. ,. To 95-0296, Count E, sentence of the Count is the Defendant pay the costa of prosecution, undergo imprisonment is a State Institution for not lase than 39 months nor more than 7 years. Sentence to date from September let, 1995, and run concurrent with any other seateace the Defendant is presently undergoing. To 95-1105, Count F, eet+tence of the Court is the Defendant pay the costa of prosecution, undergo imprisonment is a State Institution for not lees than 39 months, nor more thaw 7 years. Sentence to date from September iet, 1995, and run concurrent with any other seateace the Defendant has been presently directed to serve. The Court further directs that the Defendant not be transported to a State Institution until such time ae the District Attorney's office informs the Court that they are recommending a transfer at that time. I would direct that this sentence order be transcribed, along with the colloquy that took place prior to the sentence being imposed. By the Court, r ~ Harold E. She y, P.J. Travis N. eery, Esquire Assistant District Attorney Samuel W. Milker, Esquire Assistant Public Defender Probation 3CIC CCP :mal KRISTY M. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V, :CIVIL ACTION-LAW IN CUSTODY PAUL E. GREEN, Defendant N0. 1166 CIVIL TERM 1994 CERTIFICATE OF SERVICE I, Matthew Kloiber, Certified Legal Intern, Family Law Clinic, hereby certify that on Friday, April 30, 1999, I served the Defendant with a true and correct copy of the Plaintiff's Petition for Modification of Visitation Order, by hand delivering the said document to the office of Defendants's Counsel, Lindsay Dare Baird, located at 37 South Hanover Street, Carlisle, Pennsylvania, 17013-3307. Mat ew Kloiber Certified Legal Intern Dated: April 30, 1999 ~ : y ~(.' N i r ~~~.:. ~J z ~ ~.:~ 1 r r,~•. G, •,~;; ~ . ~~ ~'iC„ ~ ..t ' t` ~ ~ v f~AY 31999 IQtISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTX, PENNSYLVANIA ~, :CIVIL ACTION -LAW IN CUSTODY PAUL E. GREEN, Defendant NO. 1166 CIVIL 1994 AND NOW, ~ ~ 3 1999, upon consIderatIon of the attached petition, it is hereby directed that the parties and their respective counsel a pear before \ \ ~~ r~ X ~~~«~ - ~ _cQ -, the conciliator, at ' ih~ ~_ ._~ .,__ ~ r _ r.-. ,.Sl..r. ~S~ _ on the ~_ day of ,1999, at 10• ~ q.m., for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, Custody Conciliator Ur ~~ 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 accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 cc: PENNSYLVA, I!~ ~y99 ~ ~~~~~~~~ ~ ~ KRISTY M. GREEN, : 1N THE COURT OF COMMON PLEAS Plaintiff, : OF CUMBERLAND COUNTY, :PENNSYLVANIA CIVIL ACTION-LAW y, : IN CUSTODY PAUL E. GREEN, Defendant : NO. 1166 CIVIL 1994 I accept service of the attached Custody Agreement and Temporary Order of Court, on this c~~ ~ ~~' day of March, 1994. r i ,1 / ' n Y e Paul E. Green 1 <ti v' :aC ~: ;„ x 93 Big Spring Terrace Newville, PA 17241 ~ ~~ x rya u=ox ~a Ifl W 20..! ryrxy N .:,a~~n gyn. ~:~ r.'!a WiJ .. ~. ~ '" a s Qo LJ CASH AR NOMINAI RAP PnNn CERTIFICATION OF BAIL I OTN •-- - AND DISCHARGE vs jp.b.wxa N~xne uo Paul E. Green Big Spring Terrace, Lot N97 ROR Ira surety) ^ Naninal Bnil Bail (total nnaunt sal, if am/1 S Conditions of Release (aside bait appearuq at cant when repWe0) nJ Nu cr ¢erx+NO 1166 Civil 1994 Contempt (Violation of Protection Fran Abuse Order) ACTION ~txxl Courtroan NO. 2 TO. ^OetenlbnCanter I horebY certily that sullicbnt bail boa been entered ^ RY Iho delenMnt ^ On behalf of the delendant by: ^ Cash in lull amount al bail ^ Perconlago cash ball ^ Money furnlsFred by ^ Delerdant ^ 3rd Party (lk'aue Ahl (Pima a AObw a SudYl • Rotund of cosh bail will be rnado within 20 days alter linal dispositbn. (Pa.R.Cr.P.AO15(b) l • Relund of all other IyPes of bail will be made {x«nPtN otter 20 days Idbwing linal dispositbn. (Pa.R.G.P.4O151o)1 • Bdng Cash Bail Receipt to Clerk of Court. On J Wesley Olen Jr. _ I1ISCHARGE THE ABOVE•NAMED DEFENDANT FflOM CUSTODY IF APPEARANCE OR BAIL BOND DETAINED FOR NO OTHER CAUSE THAN THE ABOVE STATED. Given urdor my hard arxl t1w Offbial Seal of this Court. THIS BOND IS VALID FOR THE ENTRE PROCEEDINGS AND UNTIL FULL AND FINAL DISPOSITION OF THE CASE INCLUDING FINAL 11Th day ol-~•"~j~-' 10~.. DISPOSITION OF ANY PETITION FOR WRIT OF CERTIORARI OR This APPEAL TIMELY FILED IN THE SUPREME COURT OF THE UNITED ~~,,,, (SEAL) STATES. ~ ra•• d cwr a asvq "°' Pmthonota WE. THE UNDERSIGNED, defondant and surety. our suceesaora, hairs and oaaigna, oro joint) dollars ltC orally hound to pay to t;e Commonwealth of Pennaylvonie tho sum of SEE REVERSE SIDE FOR BAIL CONDITIONS TO BE USED ONLY FOR PERCENTAGE CASH BAIL• The urdersignod about to becomo Surety in ttw cue cited herein. beinSl duly sworn (a affirmed), depose ~ P s~'number Is 1. I resde al .-. and my occupatbn I hove no undisposed of criminal cases against me pending in the Courts of the aloresaid County, except as lolbws: Irue arxl cormct. and I work for 3. I am rut Surely on mry bond of any kind except ns Idbws: n+rE ~MOaNr aEFEND~M 4. I have carefully read the foregoinO alfidnvit and knew it {s I ACKNOWLEDGE THAT I AM LEGALLY RESPONSIBLE FOR THE FULL AMOU T OF E B L. Tllo lolbwinp xMFwwlodgearcrd is afro applicabb _._ ISEALI it Puvicenbgo Cosh Bail is reed. ;,xir+x of a ofrrNU.Nr THIS BOND SIGNED ON ADr~I,_l.~ t0-~- ISEALI Carl ; a1 P PENNSYLVANIA. ~ ppdsrrwn, &jil Agency, a priv~to nl_ Sig ratue of Surofy )May Sigrid anrf acknowkWgod before me this individual a organization!. Except when delerdanl B mbasrM m hls suit recoglizanco (RORI, this must bo sigled b all bail sitrmUons, 11th _day of AAr~ -. 19 _]~ including ramrl4al bail. -'7 ! rcg. d can a aw.~o~~ notary Y SmrY No o RuF.s+~y a~Mmrr Lcw'ae /b 6 f.Paria, Dora uxK: •r,rs: ORIGINAL ' ~`. KRISTY M. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW INDIRECT CRIMINAL CONTEMPT PAUL E. GREEN, Defendant 94-1166 CIVIL TERM IN RE: BAIL SET AND TRIAL SCHEDULED ORDER OF COURT AND NOW, this 11th day of April, 1994, upon consideration of the indirect criminal contempt complaint filed in the above-captioned matter, and the Defendant, Paul E. Green, now appearing in court with the Public Defender, Timothy L. Clawges, Esquire, and it having been requested that bail be sat pending a trial to be held on Wednesday, April 13, 1994, and the Commonwealth in the parson of Will Gabig, Esquire, having indicated no objection to the Defendants release on his own recognizance, the Defendant is ordered to be released on his own recognizance on this charge, conditioned upon his executing the necessary bail documents and being and remaining on good behavior. Trial is scheduled for Wednesday, April 13, 1994, at 8:00 a.m. in Courtroom No. 2, Cumberland County Courthouse, Carlisle, Pennsylvania, at which time the Defendant is directed to appear without further order of Court. By the Court, J. Wesley Ole r., t,....~ _ ..,~.. ~P8 13 3 06 PN '9~ dtFflCp OF ~•,t , J~:;HCK;"dfiY CUkSc:~' aHR Cr,,,HTY FEhMSTi..d t!d t ~ M f ~ WILLIAM I. GABIG, ESQUIRE~~ ~I~~ ~C~ ~l/3/9y Sr. Assistant District Attorney TIMOTHY L. CLAWGES, ESQUIRE~,QL/If, C(~.1.4/~ ~y y1~319~ Assistant Public Defender CCP wcy CHrIiINAL COMPLAINT (POLICE) DISTRICT JUSTICE MAGISTERIAL DISTRICT NO. COMMONWEALTH OF PENNSYLVANIA DEFENDANT: VS• ~tE r Paul E. Green I Patrolman Kenneth E. Gossert #10 AND Unknown Address /,\'wnrnfAlflunU ADDRESS of Aisle Police Department (ldenflli•drtwttmrnf nr ugrm7•npn:lrnhrl anJry~6firulsuMln'bp,lU R.S.A. white/mete/ S-iD-65 AKA do hereby slate: (I) ®( I accuse the above named defendant, who lives at the address set forth above or. _ ^ I accuse an individual whose name is unknown to me but who is described as >. -`, ^ his nickname or Popular design:uion is unknown to me mld, therefore. I hove designated him herein as John ~• Doc: with violating the penal laws of the Contmonwcaltll of Pennsylvania at 519 Cherry Court Carlisle.Pa. ~ 1fYun•• Idnlrul SulxlA•4+AIn/ •1°~r in Qmberland County on or about 9110 hours ADri 8,1994 V ParliClpanl5 WClC (((/hrn•nrm/wrtlrl/wnn, plnrc dndr numrs hrn•, nMvfLlg Uuvuunr~JaMnv Arli•nJanfk Paul E. Green (2) The acts committed by the accused were: 0 INDIRECT' CRIMINAL OONTITiPT. 'The defendant violated the Order issued under the Protection From Abuse Act in No. 1166 Civil 1994 on 17th day of March 1994,by the Honorable J.Wesley Oler Jr. ,which Order directeddefendANt not to: come within 100 yards of residence of Kristy M.GreetT at 519 I~terry Court except where a prior agreement had been made, in that the defetTdant did come to the residence at 519 Cherry Court,Carlisle,Pa. and did beat on the door and did want admitted to the residence witiTOUt prior agreement. PROT3ABLE CAUSE: On April 8,1994 Paul E. Green went to the residence of Kristy Green, 519 Cherry Court Carlisle,PA. at apporximately 2110 hours and did beat on the door attd did want to enter the residence without prior agreement from Kristy Green. This is in violatiotT of PFA Order 1166 of 1994 issued by Judge J.Wesley Oler,Jr. not allowing Paul E. Green within 100 yards of residence at 519 Cherry Court. all of which were against the peace and dignity of the Commonwealth of Pennsylvania and contrary to the Act of Assembly, or in violation of "' 10190•' and of the Act of .Tana 9 f1g78`Pro"e^ en' aei-`Ahlia (Srcrdln) ISub•snflnn) or the - Ordinance of " r Adfnrul SuA-Ahlslnn / (3) 1 ask that u warrant of arrest or a summons be issued and that the accused be required to answer the charges I have made. (4) 1 verify that the facts set forth in this complaint arc true and correct to the best of my knowledge or information and belief. This verification is made subject to the Penalties of Section 4904 of the {imes Codc (I8 Ya. C. S. § 4904) relating to unsworn falsification to authorities. ,~ ,, / ~~ April ~ ,19 94 _ q l v AND NOW, on this date ~ ~- 119 ~ I certify the comPln• t has been properly comp) tcd and verified, and that there is Probable cause for issuance of Process. D9 - I -- of ~ ~( L) /,IluRisfrriul lJ/snhll I laulnR Anfho/ill'/ P ,,h'~, .. Q 959"r.J_ AOPC 411~a0 ~I;li,~';~ll '.+.h Rt V[ h5t ':Illl. IZ ifi l:'.::'il 1; F .,-~ i~,a'~I r,. ~Ii CRIMINAL COMPLAINY-"~~(POLICE) DISTRICT JUSTICE mA01u IEN1AL DISTRICT NO. ~1 ---- ~ , ~~ r- 95922 COMMONWEALTH OF PENNSYLVANIA DEFENDANT: VS. NAME r ~ ~. P8U1 E. ` GCeEft I• Patrolman Kenneth L. Gossert ~lU AND >,~j~D~ Address , /11'mnrr/Allinnll ADDflESS - ~ !'(~'... Z'i1r1Ys1e Police Department ~ r_' ~r l (/Jtnlllil J~rylrnnlvu uragrnn•npm.+enrn/nuJryrllliruhuMfiyisiarrl R.S.A. y~C~I1181e~ %~lab I 1 - ~i1+ t _._ ANA ~f •~, t do hereby stair. j" I ! •)t (I) 2^t I accuse the above named defendant, who lives ut the address set forth above or, ~ , ^ 1 accuse an individual whose Hume is unknown to me but who is described as ~ I E ^ his nickname or popular designation is unknown to me and, therefore. I have designated him herein~as~Jlihn Doe; with violating the penal lows of the Commonwealth of Pennsylvania nt 519 (7terrv Cnnrt C tisl~aPA•~ ~ !lYua•• Afrirui Subl{IcLfhaU I !,~- In (lnflsnrlarxl County on of aboal ?11C1 hours A r,~ it Ar1gQYa ~'°, PartlClpanl5 wOrC (1/Ihem wem/rlrtlrlpanls, plmrlhrlnwmrs brrc.n•)ti•uling Um nuurrrjuh,nr J~IrnJunl).~ y, '" Paul r. Green (2) The acts committed by the accused were: ~ INUIRLCf CRIMTt+AL Cx)ttI'l2llyf. The defendant violated the (Trder issued under the F'rotectlon Fran Abuse Act in No. 11fi6 Civil 1994 on ].7th clay of Ptarch 1994,by the Honorable J.blesley Oler Jr.,whicii Oceler directeddeferxiANt not to: carte wiUtin 100 yards of residence of Kristy PI. Green at 519 Cherry Cr~urt except tvl~ere a prior agreement lord been made, in that the deferxlant did tune to the residence at 519 t]terLy CNUrt,Cnrlisle,Pa, arxi did beat on the door arxi did want admitted to the residetx:e witiwut prior agreement. PRUI3AE)LE: CAUSE: On April 8,1994 Paul 1. Green went to Che residence of Kristy Green, 519 Cherry Court Ca'rlisle,PA. at apporxiawtely 2110 hours arxi did heat un the door arxi did want to enter Ure residence without prior agreement fran Kristy Green. This is in violatmDn of PEA Urder 11G6 of 1`l94 issued by Judge J.Wesley Oler,Jr. out allowing Paul Li. Green witJtin 100 yards of reaicierx:e ht 519 Uterry Court. all of which were against the peace and dignity of the Commonwealth of Pennsylvania and contrary to the Act of Assembly, or in violation of = -:.. _.. '. and : ' ' ` '- "" of the Act of ~v. «Ipn (Sub •srrllnnl or the " ' Ordinance of A==') (Adltlrul Sub -JtrLrlnn l • (3) I ask that a warrant of arrest or n summons be issued and that the accused be required to answer the charges 1 have made. (4) I verify that the facts set forth in this complaint ore true and correct to the best of my knowledge or information and belief. This verification is mode subject to the penalties of Section 4904 of the~limcs Cpde (I8 Pa. C. S. § 4904) relating to unswom falsification to authorities. / ._Ai~il Q . 19 c'__.lt- - AND NOW, on this date ~ L 119 ~, I certi~Itc compla' t has bee p party compl red and verified, and that there is probable cause for issuance of process. (AlaR6lrriaf Dlrtrlnl (/ssuing dulhprlny Aox a 1 t-ea YOU ARE COMMANDED TO APPEAR BEFORE UNDERSIGNED AT: IIIMI. - :Mil. ri •tl summons scnco py senates rasa, return recelpr requesrca. on the Jay of __ -___. III l.gl'•mfum I ! li1lr 1 for a preliminary hearing upon the charges In Ina above cnmpleinl according to law. II you tail to appoar el the Dmo and place, as elalod above. a warrant well De losued for your arroat. 0x11 will De sal al Iha prohminary hearing. you bran Iha dghl to be reprofenled by a Wwyer end II you wnnol atlord a lawyer nno wtll De anpned to represent you. OAil I.SOl 11 ISFhU tiummon. rewmcJ undclicrnd un the dal of _ _._ 19 1q'!~du.n'r nrnrrt•1;,I ,.I ,;. ; KRISTY M. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA y, CIVIL ACTION - LAW INDIRECT CRIMINAL CONTEMPT PAUL E. GREEN, . Defendant 94-1166 CIVIL TERM IN RE: COMPLAINT DISMISSED ORDER OF COURT AND NOW, this 13th day of April, 1994, upon consideration of the complaint for indirect criminal contempt, and the alleged victim having failed to appear for the trial in this matter, the complaint is dismissed with prejudice. ey the Court, ., J esley O r Jr., ' WILLIAM I. GABIG, ESQUIRE - ~ ~~ y~~y Lue~ Sr. Assistant District Attorne TIMOTHY L. CLAWGES, ESQUIRE -Co(~Sent'y~14 Wey Assistant Public Defender ~u wcy RL APR I'I 9 53 ~H'9~ ,i f•tCc CUMbEk:."~D CQJhFT FENNS1t'+~Y~ ~~ 5-~7~"ry XRISTY M. GREEN, :IN TXE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v :NO. 1166 - CIVIL - 1994 PAUL E. GREEN, Defendant :CIVIL ACTION - CUSTODY COURT ORDER AND NOW, this ~ 7 ~ day of , 1994, the Conciliator being advised that the parties hav reached an Agreement in this matter, the Conciliator relinquishe jurisdiction of the case. V/(i-Cl a Hubert X. Gilroy, Esquire Custody Concili or ~ , _a'f HAY ~~ a 33 aN ~9~ .:' , nt,~ ~~ ~ c~ ~tSY p n.~. .+., .. , ~~.. ~-off - er rn~rY~r ~d, ~C~~'--~ --- r -----__ nn ~,. __..~ ~.~cP.~.C_l.____~~__ In the Court of Common P1eaa of Cumlxslaad County, Peaetsyh~ania N,~. ---~~r_iitc--------------- ctvu. I~.T.w~.- ._.'_! _1.c1.f~__~_.l~U~~~iGl!"~l~a?_._ __~_> __C:Y_~er----~.cZC--- ~-A ~, rn __ _____ - ~I__~i_' _____ Prothonotary 19___-~ ,ti~ep ;or Plaintiff. ~`~. '! ~~~_ ;`k Y t S~ w a M U w a a ~. 1 w SEP I G IO 55 :iN '9~ ;~,~ ct ~ ;gig.; 1hY }: ~. i,, ~ f . ' ~ f ;j ,~;,;, ''` i ~f , ~ i ' ~~ ~ ,, li:' 1 }., ~~ '_ _..__ RRISTY M. GREEN, Plaintiff v. PAUL E. GREEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW N0. 94-1166 CIVIL TERM ' ORDER OF COURT ` AND NOW, Chia ~~ day of December, 1996, upon consideration of Defendant's request in a letter dated December 2, 1996, for appointment of counsel to represent him in a custody matter, and Legal Services having apparently been unable to locate an attorney who will represent him pro bono, Lindsay Dare Baird, Esq., 37 South r Hanover Street, Carlisle, PA 17013 is APPOINTED to represent him on the matter of custody only. DEFENDANT is requested to communicate in the future with his appointed counsel rather than the Court concerning his custody matter. BY THE COURT, .l. ~'~ o~ Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 Attorney for Plaintiff Ron Turo, Esq. . 32 South Bedford Street Carlisle, PA 17013 ~, Former Attorney for Defendant 1ti1~,4r BeIrvine Rowes, Inc. Carlisle, PA 17013 ealey Oler, J J. . „~ ~. ~ r: ~ ~~ ~. t~ 1~ --~ !~ -~ :,5 ..~ J l tal `i =< Court Administrator's Office j'uc...~ ?d ~'~.rr~L~x.~••• c . „~~~y~ ,,,~ Lindsay Dare Baird, Eeq. 37 South Hanover Street Carlisle, PA 17013 Court-Appointed Counsel for Defendant Paul Green, DA-2337 301 Morea Road Frackville, PA 17932 Defendant :rc i * f' :IN THE COURT OF COMMON PLEAS OF K~i§ ~~ G~t(~ Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V :CIVIL ACTION - LAW * /~ :NO. I f 6 6 CIVIL 19 9~ I'u~ ( F, C.rcen Defendant :CUSTODY/VISITATION ORDER OF COIIRT AND NOW, this (date)212o~91 , upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before Nc~~•.+ ~. G~(:u rc , the ConClli~tor, at tl e_ (~- 6,~ L.J (,,, ,, ~~, /e ~,. F hd ~sr 4F' Floor ior~. A+cQ on the 7~_day of _RP'%~ , 19 7 , at ~;o /~,M:, for a Prehearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the Issues to be heard•by the court, and to enter .into a temporary order. Either pasty may bring the child who is the subject of this custody action to the conference, but the child/children's attendance is not mandatory. Failure to appear at the conference•may provide grounds for entry of a temporary or pezmanent order. FOR TXE COURT: Custody on i iat r -~- YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TXE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF TXE COURT ADMINISTRATOR COURTHOUSE, FOURTH FLOOR CARLISLE PA 17013 (717) 240-6200 FLrR-C?, r CE ~,~ ren z~, rc~ s: u~ C~',..~ .'.14:'. ~..1 '~41~1~1,~ r•~r;wsr~-vw~~a~ day y7 ~1~ u~~ 7o C.y~ o`~rJ • ~. tJNDHAY.DAREBAIRD. BHOUIRg. q. A ~T011NSY~AT LAW J17N117N.NANbVi11 f77iLRT. QAI1LIiLt, r~fiNiYLVANIA /70fi - .-17171 MY•\711 IAI{ M>t•~110; ICRISTY M. GREEN, : 1N THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION • LAW v. : CUSTODY/VISITATION PAUL E. GREEN, : NO. 1 I6G OF 1994 Defendant ORDER OF COURT You, ICristy M. Green, respondent, have been sued in court to modify partial custody or visitation of the child: Kaylcc Green. You arc ordered to nppcar in person at on , at ,o'clock, _M., for ^ a conciliation or mediation conference. i7 a pretrial confercncc. a hearing before the court. If you fail to appear as provided by this order, an order for custody, partial custody or visitation may be entered against you or the court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WFIERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (7l7) 240-6200 AMERICANS WITH DISABILITIES ACT OF 1990 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 accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. Ali nrrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled confercncc or hearing. BY THE COURT: Date• 1• KRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW ~, : CUSTODYNISITATION PAUL E. GREEN, : NO. I IGG OF 1994 Defendant PETITION FOR MODIFICATION OF TEMPORARY PARTIAL CUSTODYNISITATION ORDER 1. The Petition of Paul E. Green respectfully represents that on the 17th day of March, 1994, a Temporary Order of Court was entered for Partial Physical Custody, a true and correct copy of which is attached. 2. This Order should be modified because the mother of the Petitioner's minor child, I~aylcc Green, refuses to allow visitation between Petitioner and the minor child. It is requested that visitation be ordered. WHEREFORE, Petitioner respectfully requests that the Court modify the existing Order for Partial Custody because it will be in the best interest of the child. Rcspcctfully submitted, - ~~ ~~ ~-- ////~~ p rc Baird Es uirc Lindsay , q Attorney for Petitioner 37 S. Hanover Street Carlisle, Pennsylvania 17013 I certify that the statements in the foregoing pleading arc, to the extent of my knowlege and belief, true and correct. 1 understand that false statements herein arc made subject to the penalties of l8 PACS 4904 relating to unsworn falsification to authorities. Li dsay Darc Baird, Esquire KRISTY M. GREEN, Plaintiff, v. PAUL E. GREEN, Defendant MAR 1 ^ ~1994~J,.~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL AC'f10N-LAW ; CUSTODY NO. ~~~~ OF 1994 ~ n consideration of the Temporary Custody AND NOW, this ~ 7~ day of March, 1994, upo Agreement entered into by the parties, the court orders as follows: 1, The Plaintiff and the Defendant shall have shared legal custody of their daughter, Kaylee Green. 2„ The Plaintiff shall have primary physical custody of Kaylce Green. 3. The Defendant shall have partial physical custody of Kaylce Green. 4. The Defendant shall have physical custody of Kaylce Grcen at times to be agreed upon by the parties. $, Kaylee shall not be removed from the commonwealth of Pennsylvania, absent consent from the Plaintiff. 6. The Defendant will refrain from the consumption of alcohol while Kaylce is in his custody. ,. ~ t n, / V i J. ~~~ MnH ~ l• 1~~;4~1~~ KRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS Plaintiff, : OF CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION-LAW CUSTODY PAUL E. GREEN, Defendant : NO. ' h'~OF 1994 TEMPORARY CUSTODY AGREEMFNT RE= KAYLEF REEK ~'~ ~ This agreement is entered into this ~ ~ day of ~(4-` 1994, bctwcen the Plaintiff, Kristy M. Green, through her attorneys, the Family Law Clinic, and the Defendant, Paul E. Grcen. The parties agree that the following may be entered as a court order to be in effect until further order of this court: 1. Kaylce Green. 2. 3. 4. The Plaintiff and the Defendant shall have shared Icgal custody of their daughter, The Plaintiff shall have primary physical custody of Kaylce Green. The Defendant shall have partial physical custody of Kaylce Green. The Defendant shall have physical custody of Kaylce Green at times to be agreed upon by the parties. 5. Kaylce shall not be removed from the commonwealth of Pennsylvania, absent consent from the Plaintiff. 6. The Defendant will refrain from the consumption of alcohol while Kaylce is in his custody. Dated: ~~ / `- _ ~ l ~ Signed: S 1./~i ,.~ Kristy M. G,tcen Ann St. Ledger Certified Legal Intern c~ .G'YiGI,L, ~ L5 1,,, ~, Thomas M. Place Robert E. Rains Linda E. Fisher Harvey A. Feldman Supervising Atlomey The Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 717/240-5204 or 717/243-2968 - ~ I ~ ~.~~ %~ aul E. Grccn o~ ~~ r; (~~ '° C f , J_~ ~' ` ~ _ ~ ~ ~ ~ :~, a~ • ~ ~ ~+ Y ~ Q'~ - v ~ (j~ rT 1 ~ ' ' ~ ` ~ ~ U ~~ AUTHORITY TO PAY COURT APPOINTED COUNSEL MAY O G 199j~,L' '-~ I. COURT 2. VOUCHER D Dlsmcl Justice O Common Pleas ^ Appellate ^ Omer N° 2 4 3 6 ]. fOR ID J . C.P, APPELLATE) ~. AT (CITY/STATEI S. BUDGET CODE ~{ -U 6. IN THE CASE OF T. CHAROEIOFFENSE IPUROON CITATIONI B. O PETTY OFFENSE ~,/,~f /^I ~~/fe0~ ra /[~.~/ L• ~,.rfi~ O FELONYOMISOEMEANOR 9. PROC EDINGS IOescnbs bnNlyl /, ~ / 11. PERSON REPRESENTED 12. CIVIL DOCKET N0. (C7~Pr(/'Ctf-ir. /if /LCQI,/f /r ~r.~~ 1 0 o.r.ne.nl•Aa.b ~+' ~ / ~ 7 7 O ADDwum 19. CRIMINAL DOCKET NO ~ O aDD.Ile1 S 7 ,laden Penuona 6 D MtlelNl Wunefa l e Wnn VbuDOn 7 O P CM 10. PERSON gEPRESENTED (Full Namel aro rge ee e O P.obauonu Cnargae wan vleuuon Ia. APPEAL9000KET NO. / ~a/, ~C)l(• = P Llc1~ 9 a Olnar q ~~ • I~ I8. NAME OF ATTORNEY/PAYEE AND MAILING ADDRESS aoor mu ~(~ / ~i{i /f/~ c~ ~ ~~/i ~. % ~~P,1 Undeey Dere Baird NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE 37 South Hanover Street Corlislu, PA 77073.3307 ._ a> [ ~ I-: 17. TELE ONE No. te. aaCU^sECUattrNaOnuNNo CLAIM FOR ' SERVICES OR EXPE SES tg. t=. - RVICE NOUPS DATES AMOUNTS CLAIMED a. Arr Idnmenl pg/or PNe ;n Mulaph nu per tutor bma tool b P mery Hil(Hrp adore to obtain 'In Court' Com• penutlon. Enlo told Oebw. c M-YOna end eeeuuU I U S a BaA Nringr" _ ~ O e. Sanrdptle Nelg/ega U U 2 1, TnU q. RerOtabon Hurlnpa n Juvemis Nnnnpa r Appula Coun 19A. TOTALIN COURT COMP. 1 Omar ISDecty on eaamonal anubl TOTAL HOURSw %t:50 PERFIOUR f 20. a. Interviews an onl~ren~nH .,• //.tom( %Cr+C/~/< •/ ^~ ' / ~" Mualpp rab per Iqur Umu tplal ~ ~ b. Obulmn and rwww+n retoraa q 9 - .:~ c % c /• /.,~ • ~ 1 koura Enter told •Oul of Caun' Compenuuon Glow. O j c Legd refaarcn ano bwl wnlmg r ~ ~ Q ~- . O c0i o. Invefogaava ano omu work (Speafy on eooisond dleeul ~ «. • - y 9 ~ 90A TOTAL OUT OF COURT l nC( COMP. .,~(( (t Ylct C ~( C1 TOTAL HOURS ~ x fa PER FLOUR ~ f c ~ ~~~ cv 2t. ITEMIZATION OF REIMBURSABLE EX PENSES AMT. PER ITEM AAlea a f.25 r mile ^ W 21A TOTAL ITlMI2lD E%P. ~f 22. CERTIFICATION OF ATTORNEY/PAYEE 27. GRAND TOTAL CUtMlD Haa comperoallpn sne/or nlmbunemenl tar work In Idle seta Pnvloutly been applied lo!/ OYES ~~ NO • f ~-~(~ Ryes were ou DUa~ O YE9 ONO Il a b ko loT Ho m h7 Cr . y y ; yw m wen you W w uc Hea Ina parson reprefanteo paid any money to you, or to your know aA9e arlyane alas. In connaotlon with tns maKer for 2e.0lDUCT. PRIOR PYMTS. wnlcn you ware apOmntao to promos repragntallon9 OYES ~ NO Il yeA 91 q astole on adeillanal Me 1 ~ ~ ~ f w / z ~/ ~/ i S ~ / - 1 swear or atbrm Ina Uuln or aortaotnen !! - `f~(k f 25. NET AMOUNT CLAIMED ot Ina adore atatsmnnta Slpnel • W Anomey/ eye D.I. f • ` f •rl. 28 ,~ o~n ~.I ,. I„u S9nalwe d 1 / / I / t c 27. AMT. APP110VE0 Copy 1 • Mail to G/ourt Administrator at completion of gervlce 1 • - LINDSAY DARE BAIRD . Hmorer • Grlisle, PA 11013 • (11 May 5, 1997 At Law (111) 243.8110 EXPLANATION OF CHARGES: Paul E. Green No. 94 - 1166 1/13/97 Procure and review file 4/17/97 Pre-hearing custody with H. Gilroy, Esq. 4/25/97 Research and memorandum as requested by Attorney Gilroy 12/96- 04/97 Extensive correspondence and postage Total: 6 hours ®$40.00 = $240.00 .50 hours .50 hours 3.0 hours 2.0 hours. Thank you! ~e~-- . ,~ MAY 2 9 199~~ 1(RISTY M. GREEN, Plaintiff V PAUL E. GREEN, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :NO: 1166 OF 1999 :IN CUSTODY COURT ORDER 1997, upon AND NOW, this ~ daY of -~.r~--~' consideration of t e attached Custody Conci cation Report, it is ordered and directed as follows: 1. A 1~wring is scheduled in the above case in Court Room No., 5 of the Cumberland County Court Xouae on the ~-t~G day of ' ~ 1997 at ~~~.m. At this hearing, the issue w 11 be whether the Father's visitation rights may be terminated or suspended as a result of the Father's present incarceration. Counsel for the parties shall file with the Court a memorandum setting forth the history of custody in this case, each party's position with respect to Father's ability to exercise visitation with the child while he is incarcerated, any legal authority supporting each party's position, a list of witnesses the parties will call to testify and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least ten days prior to the hearing date. 2. appropriater Order totprov de for Father'stattendance at the hearing. BY THE COURT, cc: Lindsay Dare Baird, Esquire \ William C. Vohs, Esquire r ,.Cet~,rcac2 y~Q`"~d ~-~~97~ KRISTY M. GREEN, Plaintiff v PAUL E. GREEN, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :NO: 1166 OF 1994 :IN CUSTODY Prior Judge: J. Wesley Oler, Jr. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WIT1! TXE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Xaylee N. Green, August 22, 1992. 2. A Conciliation Conference was held on April 17, 1997, with the following individuals in attendance: Lindsay Dare Baird, Esquire, who appeared on behalf of the Petitioner, Paul E. Green, and the Mother, Xriaty M. Green, with her counsel, William C. Vohs, Esquire. 3. The Father is incarcerated. The Mother has not been taking the child to see the Father. The Father is now seeking visitation rights at the Prison. The Mother's position is that the Father assaulted her and held her and the child hostage for several hours. The Mother suggests that Father has demonstrated "a reckless and wanton lack of concern for the child's welfare" and, on that basis, visitation rights can be denied to the Father pursuant to applicable Pennsylvania law. 4. A hearing is required for the Court to consider whether visitation for the Father may be denied and, if such rights are granted, the circumstances for the granting of the visitation rights. The hearing should take no more than one- half day. 5. The Conciliator recommends an Order in the form as attached. ~~ DAT .~ w. RRISTY M. GREEN, Plaintiff v. PAUL E. GREEN, Defendant IN TEE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW N0. 94-1166 CIVIL TERM ORDER OF COURT AND NOW, this ~ ~ day of June, 1997, upon consideration of the attached letter from William C. Vohs, Eaq., attorney for Plaintiff, and upon agreement of counsel, the custody hearing previously scheduled for August 29, 1997, is RESCHEDULED to Friday, September 5, 1997, at 1:30 p.m., in Courtroom No. 5, Cumberland County Courthouse, Carlisle, Pennsylvania. William C. Vohs, Esq. Suite 2, 11 West Pomfret Street Carlisle, PA 17013 Attorney for Plaintiff Lindsay Dare Baird, Esq. 37 South Hanover Street Carlisle, PA 17013 Attorney for Defendant :rc _ ems,,- n,~',~t ~/~.~ 5~. ,d• ~' ~ .. (i '1 '~~l t. i~ :"~~i~il LV iv ».~J ...: ~.. BY THE COURT, • ` HANFT SC VOSB r 11TTtl11H IS Vfi AT LAW 11 ~~~IS ti'1' ~tSlN 1~1/1!T tiTlt 1!1!T. ti1tI TIS l~A IS 1.1li l.lt. h11 171/lit TIIC II A[S I. .). ((AHPT Wli.T.lADI C. ~~(IIIM May 30, 1997 The Honorable Wesley Oler Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 REs Green v. Green No. 94-1166 Civil Term In Custody Dear Judge Oler: (717) ~ l0-tS t37t3 PA% (717) S2 •Lll-O JO7 Please accept this letter as a request for a continuance for the hearing scheduled for Friday, August 29, 1997 at 1:30 in the above-referenced matter. I am scheduled to be out of the office on that date. Should you have any questions or need any additional information, please do not hesitate to contact me. Very truly yours, HANFT VOHS William C. Vohs WCVsdln cc: Rristy Green ~uN a 2 ~~ ICRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. : CUSTODYMSITATION PAUL E. GREEN, : NO. 1166 OF 1994 Defendant ORDER OF COURT AND NOW, this __ L 9 ~ day of w ~ ~ ~ `_ _ _ , 1997, upon consideration of the attached Request for Writ to Transport, the Cumberland County Sheriffs Department is hereby ordered to transport Paul L. Green from the State Correctional Institution at Mahoney to arrive in Cumberland County Prison no later than Thursday, September 4, 1997, for a Custody Hearing scheduled for September 5, 1997 at 1:30 p.m. before the Honorable Judge Oler. By the Court ~y ~~ J. cc: Cumberland County Sheriffs Department 1 Courthouse Square, Carlisle, PA !7013 William C. Vohs, Esquire Suite 2 11 West Pomfret, Carlisle, PA 17013 Lindsay Dare Baird, Esquire 37 South Hancver Carlisle, PA 17013 rr ~ ~~ ar:~~~ li Fci~: pia t';'.' ?< +; 11 ~Ib crt~,Q~,,~h S1 `r(J ~ `J~u.1d ICRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. : CUSTODYMSITATION PAUL E. GREEN, : NO. 1166 OF 1994 Defendant REQUEST FOR WRIT TO TRANSPORT AND NOW, comes Paul E. Green, the Defendant, by and through his attorney Lindsay Dare Baird, Esquire, and respectfully requests transportation from the State Correctional Institution at Mahoney to Cumberland County Prison for the purpose of attending the Custody Hearing scheduled for September 5, 1997 at 1:30 p.m. before the Honorable Judge Oler. Respectfully submitted, indsay Dare~nird, Esquire Attorney for Defendant 37 South Hanover Street Carlisle, PA !7013 (7!7)243-5732 ~ r _ „~~ ,._ ~: 1t. _ A f ~ , ~ - u_i. ~ ; : ~~. G r' '? U r ~. STATE OF PENNSYLVANIA, ss Cumberland County, .._ The Commonwealth of Pennsylvania to the State Correctional Institution at Mohoney GREETING By an Act of Assembly of 1785, we command you to have the body or bodies of .Paul_G.__GI'SeR___________________ before the Hon. _1..Wesley__Oler _1 r_________________ of the Court of _ ....COIfMQD _ PJ,eas.. .. _ .... _ _ _ _ _ _ _ _ _ _ of said County, on .Friday _ tho .5th day of Sept_~ 1997_, hou$e Rm.S a}1:_}0__ o'clock, .P M, et theCumb. Co..Cou~t; in the Borough of Carlisle, together with the cause of his detention in your custody. Then end there fio do and receive all and singular those things which our said Judge shell consider and adjudge in that bohalf. Witness the Honorable _.J,_34e$ley,_Q~,e_;._~r___________________________ Judge of our said Court, at Carlisle, the _ . _ _?9 th _ _ . day of _$eptember _ _ A.D. 19.9.2 _ Lawrence E. Welker____________,___. ---------------------- Prothonotary and Clerk of Court Deputy TRUE CAPY FROM RECORD In Testimony whereof, I bore unto set my hand and the seal of said Court at Carllslo, Pa rhI ~+~ ddy~ 1 yf3~~ I,/1o,y, ~ ~ ~_ Prothonotary , I 1 1 ' 1 1 1 ~ ~ ~ 1 ; 1 ; ~ I 1 I I 1 ~ I ; ; ~ ~ 1 ' 1 1 ' I 1 ~ 1 1 1 ~ ' I 1 I E 1 1 , I ' ' 1 I I 1 1 1 1 I N ' I I ' •1 1 Q 1 y. 1 •F '..~ 1 I ~ I I I L' ~ y~ V Q ~ I I 1 i ; ; p O I N v W N ~ •~ 1 i 1 1 I 1 I V I H 1 I D •'i 1 i 1 i 1 1 I 1 ~ ' i 1 4 ' i . J-1 'O N~ 1 ~ U ' I ~ i ~ ' m I bl N ; 1 1 ~.•1 ~ 1 I i •~ I '~ H o 1 I 1 1 Q~1 y~ I ~ I , q = 1 ~ w n m 1 ~ ~ I ~ e ~ I I , ' ° > .+ N ~ ~ N. I ~ N N a r i ~ N ' I , .I t~' ~ ~ ,+. I m m n I ; ~ ~ E. o . ,n I I ~ I ~ L,' ~ ~ I 3 , I • .c W ~ ~ .•~ ~ ~ ~ 1 I 1 x.11 I ~ 1 ' ~ 7 N {} 1 I N' rl' I i 1 N O •'•1 fV I Z ~ ~ •H' 7; I 1 ~ 'O N r•I 1 ~ w' ~ ~ m ~ acl ~ ~ • n I amUn I AUTHORITY TO PAY COURT APPOINTED COUNSEL OC1 Q 2 1991 ~ , t.000Rr 2. VOUCHER ^ District Justice ^ Common Pleaa ~ Appallele ^ Other N_ 2 6 8 7. FOR 10 J. C.P., APPELLATE) ~. AT (CITY/STATE) 5. BUDGET CODE ~Ia • - a~ o - ~.3c: ~ 8. IN THE CASE OF 7. CHAROE/OFFENSE IPUROON CITATIONI B. O PETTY OfFENSE / ~ P M E E j Yrf • O FELONY O MISDEMEANOR a i.Q . f ~ ,Q~7r AU.C .U 9. PROCEEDINGS (Oascube bnallyl I1. PERSON REPRESENTED 12. CIVIL DOCKET NO. ~ ~,,/ ~~ /1~('~ ~?//CO ~• L C(~S~~A! t O oel.nd.nnAdml : D o.r.ndam•J...nila 9y-//G ~i f QsEh¢ , © O 7 O appuum 1J CRIMINAL DOCKET NO . D aooalu . C) ~^ S O Haow Penroner E-~ 1 '~j 6 U Mtlanal Wdnaaa !> I . P ' ~~ t0 PERSON REPRESENTED IFuII Namel uMn Cnarpu wan VroUbon 7 O a O Oroaanonar Cnapaa wan vwlatwn t 14 APPEALS DOCKIi7 NO. a O Otner ~ 1 ~ -• :, [~ ~ /'' • ~ 18. NAME OF ATTORNEY/PAYEE AND- MAILING ADDRESS ~ ~ r+i auor Dal. 7 ~,v C G Lindsay Dere Baird "" _:? / ~ / ~ rhf i(f'c'»l'~Gd7(/ ~ 11 ~ 37 South Henove~ Street ' NAME OF COMMON PLEAS JU GE ASSIGNED TO CASE Carllele, PA 77013.3307 17. TELEPHONE N0. 19. SpCIq SECURITV NO OaFm wO CLAIM FOR SERVICES OR EXPENSES 19. SERVICE HOUPS DATES AMOUNTS CLAIMED a. Arrarpnmenl enNOr PIH MuII1pM qU par hour hmH IoIFI b Pqummary Mutlrrp hopfa to obtain 'In Coun• Com~ penaallon. Enter total below. C Monona and Raduaala S 6 Bad Hurlnpa ~ U a. Sentend Hurlnpa ~ = I. Trial p. RevocNion NuHnpa n. Juvamla Hunnpa '~. i. Appsaia Coun 1BA TOTAL IN C UR COMP. t. Otner ISpeary on eddihonal annal . /, ,~ . ~yC ~ f TOT OURS ~ / J YifAPERFiOUR , 20. a. Inlervmwa and oonleruou ~• Mu16pp raU qr W hmn total ~ b. Obwmnp and reruvnnp racorda hoora. Enter tot 'Out of Coun' wmpenullpr 4 j G legal gafafoh and brNl wrlhnp Cu d. Invesvpaove and omerwaklSpaah on addilbrtL anaenl 20A TOTAL OUT OF COURT COMP. „~ / TOTAL HOUR9 ~ ~ )S,f•t(PERHOUR w ~ 21. ITEMIZATION OF REIMBURSABLE EX PENSES AMT. PER ITEM Mdea e5.25 rmle s o: w 2 O 21A TOTAL ITEMIZED E%P. ~ S 22. CERTIFICATION OF ATTORNEY/PAYEE 27. GRAND TOTAL CLAIMED Has compensation and/or relmbu emenl for work In Ihla we prwlouaM been applbd lo/1 OYES ~'NO ~ f ~ I uyes were ou ad? OYES ~ NO Il h? b h T H i . y p ow muc ye4 yw om vnnyou pa d Has the parson reDrssanled paid any money to you, or to your knowledge anyone elss.ln connaelkln with the mortar for 2a. OFDUCT. PRIOR PYMTS. winch you were apoomled to prowds raprasenlallon? OYES ,!Q NO , I~s4 p{ya data pn addill ul rear ~ f I swear or alhrm Iha train or cortectnua -_ ,(O i 25. NET AMOUNT CLAIMED of Inc above atalemonls 9pnalun of norney/Payee Oate . f // S 1I I~' ~-w~ rr- 28 +~c~n ~.I'~ •wi v. S,pnnura of ~ Q o ~ ~ ~~~~ Jvdpa - ~ D l 27. AMT. APPIIOVIO G - a e: . s a O ~~~ r~ ! opy t • Mail to C uo~t Administrator at completion of service i KRISTY M. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA y, CIVIL ACTION - LAW IN CUSTODY PAUL E. GREEN, . Defendant No. 1166 CIVIL 1994 AND NOW, this 5th day oP September, 1997, upon consideration of the issue of custody of the parties child, Kaylee N. Green (date of birth, August 22, 1992), and pursuant to an agreement reached in open court among the parties and their counsel, William C. Vohs, Esquire, on behalf of Kristy M. Green, and Lindsay Dare Baird, Esquire, on behalf of Paul E. Green, it is ORDERED and DIRECTED as follows: 1. The temporary Order of Court dated March 17, 1994, is vacated. 2. The Plaintiff and the Defendant shall share legal custody of their minor child, Kaylee Green. 3. The Plaintiff shall have primary physical custody of the minor child, Kaylee Green. 4. The Defendant shall have visitation at any state correctional institution or prison or county prison that he is incarcerated every other Saturday, during normal visiting hours at that institution, but not longer than between 10:00 a.m. to 8:00 p.m. The Defendant is responsible for arranging transportation of the minor child for these visitations. The F~LEf}-0FFlCF 0~ Tt; • ~ n;H~~:OTPRY CUtl~Geri'i'!`.~ L~~l~hii i FE~VttiSYI~',ti4t~ ` Defendants family, specifically David or Margaret Handshew, may be utilized to transport Kaylee, so long as Kaylee is secured in a rear seat in a seat belt for the round trip to the institution. Any other contact by the Defendant or Defendants family with Plaintiff other than related to the minor child is prohibited. 5. The minor child, Kaylee Green, shall not be removed from the Commonwealth of Pennsylvania without consent of the Plaintiff. 6. The Defendant may contact the minor child, Kaylee Green, by telephone one time per week between 7:00 p.m. and 8:30 p.m. on any night that is mutually agreeable by the parties. However, Defendant is enjoined from discussing any issues with the minor child, Kaylee Green, that do not relate directly with the minor child. The Defendant is not to call the minor child or the Plaintiff collect. He may, however, place third party calls to the minor child for these telephone contacts, and Plaintiff will use her best efforts to aid in the placement of such third party calls. 7. Plaintiff will use her best efforts to provide Defendant with school records and photographs of the minor child, Kaylee Green. ey the Court, J Nesley O1 Jr., ' WILLIAM C. VDHS, ESQUIRE ~ ~7 For the Plaintiff _, /+~,'_,.., ~,u..~•G ~~ LINDSAY DARE BAIRD, ESQUIRE ""J__ '~'~~ For the Defendant wcy MAY 141999t~- KRISTY M. GREEN, Plaintiff v PAUL E. GREEN, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.94-1166 CIVIL IN CUSTODY COURT ORDER AND NOW, this _~~day of May, 1999, apre-hearing conference is scheduled in the above case on the _Z~~ day of , 1999, at : 30 ~.M. to be held in chambers. Counsel for the partic, ~ shall attend this conference. At least 2 days prior to this conference, Counsel for the parties shall file a memorandum with the Court outlining the procedural issues involved in this case as they relate to 23 Pa.C.S. § 5303. Counsel for the parties shall also explore prior to the pre-hearing conference some options with respect to any evaluation that would be required for the Father. The memorandtun shall also give the Court the background on the Father's criminal record that would trigger the implications of 23 Pa.C.S. § 5303. BY THE COURT, cc: 'fodd Green _ ~,~,,~,,, Lindsay Baird, Esq. /Wesley Oler, ,s~.to/94 . .,6• ~. ~' '~ c_ ~:~ •,~ ; :,; ., ~ . ' ~ = `~, '=} `;; ~7 ,~ _. .r) ' '.~....: - w :.: ref i -1 J N :" '~~ -^ KRISTY M. GREEN, Plaintiff PAUL E. GREEN, Defendant Prior Judge: J. Wesley Oler, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.94.1166 CIVIL M CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT fN ACCORDANCE WITFI 7'FIE CUMBERLAND COUNTY CIVIL RULE OP PROCEDURE 1915.3-li(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Kaylee Green, bom August 22, 1992. 2. A Conciliation Conference was held on May 7, 1999, with the following individuals in attendance: The Mother, Kristy M. Green, with her counsel, Todd Green, Esquire of the Dickinson School of Law Family Lnw Clinic; and Lindsay Baird, Esquire who appeared on behalf of the Defendant. 3. The Father is incarcerated. There is a prior order in place whereby the Father gets to see his daughter on alternating Saturdays with arrangements for the Father's family to transport the child. Circumstances have changed since that September 1997 Order. Situations have occurred whereby the transporting parties have picked up the child and have, in fact, not taken the child to visit the Father. Additionally, the transporting parties have not returned the child in accordance with the order. Furthermore, Mother now notes that under 23 Pa.C.S. § 5303, the Court is mandated to make a determination upon a potential threat of harp to the child before the child can be required to visit with the Father in light of the Father's criminal record. [t is also provided in §5303 that the Court must order an evaluation of a parent in those situations where a parent has a particular criminal record that falls under the scope of § 5303. 4. The Conciliator secs the primary issue a procedural one in this case. The Courl must make a determination whether an evaluation of the Father will be ordered and how that evaluation would be accomplished with the Father currently incarcerated at the Waymart State Correctional Institution. For that reason, the Conciliator believes apre-hearing conference should be scheduled before the Court. The Conciliator recommends an order in the forth as attached. DATE Hulx~ roy, Esquire Custody C ncilietor ,. w SUPREME COURT OF PENNSYLVANIA WESTERN DISTRICT AUY d OEnA60. E80UIiE DFPIl~Y Pn07NONOTARY PATRCHEF CIENKMD May 21, 1999 (~POENli4~YLVANIA H~AR~IIDMI88ION1RDL=8) OP ELIGIBLY L7-W BTDDENT Leann Mnetoscio 257 S. West Street Carlisle, PA 17013 Professor Robert Rains Professor Thomas Place Donald Marritz, Esquire The Family Law Clinic THE DICKINSON SCHOOL OF LAW 45 N. Pitt Street Carlisle, PA 17013 001 C aNLDINa iei~a:~w pt7l easx~e M~/Mnwr;arwubyaw The above-nemed law student has been approved and certified under Pa. B.A.R. 321 ~ 322 by: Harvey Feldman, Associate Dean The Dickinson School of Law The Pennsylvania State University 150 South College Street Carlisle, PA 17013 as a duly enrolled law student who has com leted at least three coodacharecter~fhasgbeentadequatelYtcrein~dvandnistofrcomp~etentf Iegal ability to perform as a legal intern as of May 21, 1999. Pursuant to such certification and in accordance with and subject to the provisions of Pa. B.A.R. 321 & 322, the above student has been registered and you have been approved to perform the duties of supervising attorney. signature and the seal o! Court, p)ay 21, 1999. /dal IU Z; ,I-; ,Y.r KRISTY M. GREEN IN THE COURT OF COMMON PLEAS OF Plnintift' CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW IN CUSTODY PAUL E. GREEN Defendant NO. I IG6 CIVIL TERM 1994 CONSFNT AND APPROVAL FOR APPEARANCE UNDER Pa.B.A.R. 322 I hereby consent to the appearance of Leann Mattoscio, a Certified Legal Intern under the supervision of an attorney, in the above-entitled custody proceeding before the Honorable J. Wesley Oler, Jr. at 1:30 p.m. on Friday, October 22, 1999. Date: October 22, 1999 As the supervising altomcy for Leann Mattoscio, certified under Pa.B.A.R. 322, I approve of her appearance on behalf of the above-named client in the above-named proceeding. Date: October 22, 1999 ROBERT E. RAINS Supervising Attomcy DONALD M. MARR-TZ Staff Attomcy FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 PLAINTIFF'S EXHIBIT KRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION-LAW IN CUSTODY PAUL E. GREEN Defendant. : N0. 1166 CIVIL TERM 1994 And now this 19's day of October, 1999, the parties in the above-captioned matter, by and through their respective counsel, stipulate to the following facts: 1. If questioned, the child, Kaylee Green, would say that she would like to see her father, Paul E. Green. 2. The distance from Shippensburg, Pennsylvania to S.C.I. Waymart is approximately 185.5 miles one-way, with an estimated travel time each way of 3 hours and 42 minutes. 3. Visiting hours at S.C.I. Waymart are from 9:30 a.m. until 4:30 p.m. on weekends. Visitation with an inmate is a "full contact" visit. it takes place in a visiting room, and there are staff members on hand to supervise the room. ~ ' au.~. ~axtit.~ Leann Mattoscio ~Ce~rtifie~d~L/eg~al Int/e~rn IL/~^~/l G-~ / ~cG1'La~ Robert E. Rains Thomas M. Place Supervising Attorneys Donald Marritz Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Counsel for Plaintiff Lindsay Dare 1~avd 37 South Hanover Street Carlisle, PA 17013 (717)243-5732 Counsel for Defendant c ~ ~' mom? n iitgg~i~~~pL ~~ ~ ~~ o ~ , w,z~~~<<~ ~r r TRUE C~~PrYed, RMOteMt~aRto~A~ to TtutAttottl- and d said rt at ~a9 9 9 TM aY ~rolhn rv FAMILY TREATMENT ASSOCIATES Paul E. Green Psychological Consultation August 9, 1999 Paul E. Green is a thirty-four year-old, Caucasian male who was referred by the Court of Common Pleas of Cumberland County. He is presently involved in a custody matter involving his child, Kaylee, age 6. Mr. Green is presently an inmate at the State Correctional Institute at Waymart, Pennsylvania and this was the setting for this consultation. Mr. Green is a normally developed thirty-four year old male who was dressed in prison clothing. He is an amputee, having lost his right arm in an industrial accident. He wears his hair long. He appears to be very neat, clean and tidy. Mr. Green was pleasant and cooperative throughout the interview and he appeared to be comfortable with the interview process. Mr. and Mrs. Green (Kristy) were married on July 31, 1993 and this marriage produced one child, Kaylee who was born on August 22, 1992. This was the second marriage for Mr. Green with his first marriage ending in annulment. He stated that his first wife cheated on him while he was in prison. Kristy Green was married previously and she had two sons, Shane and Christopher, ages 9 and 8. Mr. Green states that he had weekend visitations with his daughter and step- sons before going to prison. Mr. Green reports that Kristy is now living with another man and this relationship has produced one child. Mr. Green states that he had a "fantastic" relationship with his daughter and that she visited him for the first two years of this period of incarceration. He states that he sends her cards for birthdays and holidays but he gets nothing in return. He states that he has received one picture and a copy of one report card since he has been in prison in spite of a court order directing his ex-wife to share information with him. When asked what he wants at this time, Mr. Green stated that he would like telephone contact and visitation with this daughter. He stated that he would be willing to assume responsibility for all costs in regard to visits and phone contact. '~ 117 BROAD STREET, STROUDSBURG, PA 18360 • (570) 424-6049 • Fax (~ ='; '~ `~ .". Mr. Green has a fairly extensive criminal record. He was sentenced two to six years for Burglary in 1986 and he was paroled after serving two years. He served five months for Criminal Trespass in 1985. He also served four months for Corruption of Minors and Statutory Rape in 1989. In 1983 he was convicted of Disorderly Conduct. He also was convicted of Driving Under the Influence of Alcohol in 1991. Mr. Green is presently serving a 39 month to 7 year sentence for Spousal Sexual Assault. He stated that he pled no contest as there were other charges against him. He also stated "I did some things but I did not do what I was convicted of - I would have ytan at trial." When questioned about his record, Mr. Green was defensive, tended to project blame onto others and did not accept responsibility for his own behavior. He denied having a problem with substance abuse in spite of his D.U.I. and morals conviction which involved marijuana. Mr. Green denied ever sexually abusing his ex-wife and he stated that he had no history of sexual misconduct. He focused a great deal of his attention on his ex-wife and what he perceives as her many problems. He believes that she is trying to keep his daughter from him and he in fact questions whether she is an adequate parent. Mr. Green's parents are deceased and he has very little contact with any family members. He does have a cousin who used to transport his daughter for visits however this became too much of a burden because of the distance involved. Mr. Green states that his childhood was unremarkable. He did not graduate high school but he did obtain a G.E.D. He has not served any military service time. He states that he was always steadily employed at unskilled or semi-skilled labor type jobs. He was employed as a painter at the prison but was recently transferred to the garment factory where he can earn more money. He is very proud of his work record and the fact that he never collected disability benefits. In regard to future plans, he states Z just want to hold her", referring to his daughter. He also plans on "working" as much as I can so that I can rebuild my life. He is willing to participate in counseling with his daughter in order to provide for a comfortable reunification. Mr. Green has been evaluated psychiatrically on several occasions but he states that treatment was never recommended. Mental Status Exam: Orientation: Client is well oriented to person, place and time. Speech: Speech is somewhat rapid and pressured. It is well modulated. He is very loquacious. Affect: Affect is appropriate to content of discussion. Mood: Stable. Client denies depressive symptoms. He shows no indication of manic thoughts or behavior. Thought Content: Logical and coherent. No evidence of delusions, paranoia or Suicidal or Homicidal ideation. He is manipulative and calculating. Thought Processes: No evidence of psychosis. No hallucina- tions or illusions present. Judgment: Obviously impaired. Insight: This is lacking. Client does not accept responsibility for his own actions. He shows little remorse. Attention: He displayed no sign of hyperactivity, destractable thinking or short attention span. Memory: Short and long-term memory are intact. Impulse Control: Appears to be limited by history. Diagnosis: I Adjustment Disorder with Mixed Disturbance of Conduct and Emotion II Personality Disorder, Anti-Social Type III Loss of right arm IV Problems with legal system Problems with primary support group V GAF 60 Recommendations: 1. Client should be involved in on-going counseling to help him better accept responsibility for his behavior and to help him to relate better with others. 2. He expresses genuine love and concern for his daughter, and to my knowledge, has never caused her any harm. Visiting and phone contact may be helpful to both parties. 3. In view of his history, visiting should be closely monitored and supervised. 9. When released, a counseling program to help facilitate reunification would be very helpful. ~jca,~_ ~ .. d~ Bruce E. Snyder, MS Licensed Psychologist PA# PS0004106-L SC1 WHM 1NMHIE RECORDS TEL:570-488-2551 May 28'99 15:01 No. ~ ~ ~, COMMONWEALTH OF PENNSYLVANIA Department of Corectlone SCI Waymart (870) 488.6811 May 28,1899 SUBJECT: GREEN, Paul, DA2337 TO; TO WHOM IT MAY CONCERN FROM: JOSEPH P. NISH INMATE PROGRAMS MANAGER Please be advised that Mr. Green has completed the (allowing programs at SCI Waymart: i) Human Sexuality 2) Co-Dependency 3) Drug end Alcohol Education 4) Domestic Violence Additionally, Mr. Green has been participating in the Sex Offender Therapy Program since 3198. This program Is for individuals who accept responsibility for their sexually assaultive behavior. Please be advised that Mr. Green has signed an Authorization for Release of Information from the Department of Corrections and this Information is protected by Federal Regulations that has secondary dlsseminetion or re-disclosure. If you have any questions regarding Mr. Green, you can contact hfs counselor, Fred Grasso at (570) 488-5811, extension 3400. EXHIBIT 2 IO•ZZC~Q L1~-f .•.t: M 1NMHIt KtI:UKOS TEL:570-488-2551 May 28'99 ,~ n CO-D8PS8D~liCY Q8O0Y AGB. 118T188 PIIOO>iWfB DAQO A11D ALOO8OL BDIIOATIO]t Z6 ii This is a three month drug and aioohoi education program for inmates who ere waiting !or placement in the Therapeutic Community or have a limited eubatanca abua• history. Thi^ program includes: therapeutic, educational and eel!-help groups. 8871 OYP8ND888 OAOIIFB sIIBAH aBIIIALITY is 13 This group focuses on providing participants information on human sexuality, anatomy and phyoiolagy. Other topioa inaludad are values and sexual behavior, patterns o! sexual response, payahoaexual life-styles, and reproductive sexuality. The group i^ didaatiej however, time is made for dialogue. Group consists oP ten sessions, approximately i hours in length. MI®O. T88811PY DOM8aTI0 VIOL~fOB Q31OIIP 11 19 This group provides educational and therapeutic intervention for inmates oonviated oP arimae o! domestic violence. Tha goal of the group is to find alternatives to aggrsasion and stop the cycle of violonoa. The group will consist o! 12 members. It will meat weekly for one hour and !or 10-12 sessions. sax orrsxDSa This group is a compulsive as a means to interaction. o!landars. 15: 13 l3 odueational in nature and foouaaa on co-dependency as disorder. This disorder i^ learned by family members cope with stress resulting trom dysfunctional family This pparticular group is presented to aonviatad sax It consists o! tan one hour sessions. .02 ^ :~~ v KRISTY M. GREEN, Plaintiff v. PAUL E. GREEN, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN CUSTODY NO. 1166 CIVIL TERM 1994 Please accept for filing the attached Order of this Court of April 4, 1996, in commonwealth v. Paul Eugene teen, No. 95-1105 Criminal Term. This Order was referred to in Paragraph 14 of Plaintiff's Petition for Modification of Visitation Order of April 30, 1999, but was omitted inadvertantly. etat~,~ Leann Mattoscio Certified Legal Intern ~~U Thomas M. Place Robert Rains SUPERVISING ATTORNEYS Donald Marritz STAFF ATTORNEY THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Dated: June 1, 1999 ~l-~-q5 V. PAUL EIIOENE GREEN OTN: E003970-1 E726578-6 E230426-0 IN RE: NOLO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94-2000 CRIMINAL TERM AFFIANT: PTL. JOHN 3ANCENITO 95-1105 CRIMINAL TERM CHARGE: (F) SEXUAL ASSAULT AFFIANT: TPR. LEONARD LANDER 95-0296 CRIMINAL TERM CHARGE: (E) SPOUSAL SEXUAL ASSAULT AFFIANT: CHIEF DUANE LEBO PLEAS & SENTENCING ORDER OF COURT AND NOW, this 4th day of April, 1996, the Defendant, Paul Eugene Green, appeared in court today represented by Samuel W. Milker, Esquire, Assistant Public Defender. Pleas are accepted as follows: :~ - ~ ~~~ To 95-1105, the Court accepts a plea of iY'oly ° •; .o •~ coatendere to a charge of Sexual Assault, Count F, a violatic~ff - of of 18 2S 3124.1 as provided by the Act 10 approved March 3IetI? 1995, to be effective 60 days after March 31st, 1995. To 95-0296, Count E, the Court accepts a plea of nolo coatendere to the charge of Spousal Sexual Assault. The pleas of polo contenders to these two charges are now accepted by the Commonwealth in full satisfaction of all outstanding charges presently pending against Mr. Green in this County. At the time that the pleas of solo contenders were accepted, the District Attorney related to the Court that a plea agreement had been entered into concerning the sentence on these two charges. I have heard the agreement. I will accept the agreement, and impose sentence as follows: fY~i~ ~ y .. To 95-0296, Count E, sentence of the Court ie the Defendant pay the coats of prosecution, undergo imprisonment is a State Institution for not lase than 39 months nor more than 7 years. Sentence to date from September 1st, 1995, and run concurrent with any other sentence the Defendant is presently undergoing. To 95-1105, Count F, sentence of the Court is the Defendant pay the costa of prosecution, undergo imprisonateat in a State Institution for not less than 39 months, nor more than 7 years. Sentence to date from September let, 1995, and run concurrent with any other sentence the Defendant has been presently directed to serve. The Court further directs that the Defendant not be transported to a State Institution until such time as the District Attorney's office informs the Court that they are recommending a transfer at that time. I would direct that this sentence order be transcribed, along with the colloquy that took place prior to the sentence being imposed. By ithe Court, Harold E. She y, P.J. Travis N. Assistant Samuel W. Assistant Probation SCIC CCP Gary, Esquire District Attorney Milker, Esquire Public Defender :mal 1- C~ {'- [' y7 ;~ 'i: ~!: - ... ~~:] ~- 1 ~;i - _. ~ ~- ~~~ :~ l.' :3~ ~ .i • _. KRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION-LAW :IN CUSTODY PAUL E. GREEN, Defendant : NO. 1166 CIVIL TERM 1994 CERTIFICATE OF SERVICE I, Leann Mattoscio, hereby certify that I am this date serving a true and correct copy of Plaintiffs Praecipe dated June 1, 1999, along with a copy of this Court's Order in Commonwealth v. Paul Eugene Green, No. 95-1105 Criminal Term, on Lindsey Dare Baird by mailing a copy through first-class U.S. mail, postage prepaid to the following address: Lindsey Dare Baird, Esquire 37 South Hanover Street Carlisle, PA 17013 u~ti~ ~e ~i~c~ Leann Mattoscio Certified Legal Intern THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Date: June 1, 1999 i.'r,.., ~. _ c~ ~. c: ` ~ i " ~_ , ' ui. i . _ ' ~ 1' ~ ~ `' ~ < ~ .. ~ : 1 . ~, - _ ~ ,iii. i. . ~. ~'~ .~ KRISTY M. GREEN, Plaintiff v. PAUL E. GREEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.94-1166 CIVIL TERM ORDER OF COURT AND NOW, this ~ ~ day of July, 1999, upon consideration of the parties' petition with regard to custody of the parties' daughter, Kaylee Green (d.o.b. August 22, 1992), and pursuant to agreement of counsel, Bruce E. Snyder, M.S., is appointed pursuant to 23 Pa. C.S. §5303(c) to provide counseling and to provide testimony regarding the provision of such counseling at a maximum cost to the county of $500.00. See 23 Pa. C.S. §5303(c). COUNSEL are requested to notify the court at such time as they desire a hearing on the petitions herein. Robert E. Rains, Esq. Thomas M. Place, Esq. Supervising Attorneys Donald Marritz, Esq. Staff Attorney Leann Mattoscio Legal Intern FAMILY LAW CLINIC 45 North Pitt Street BY THE COURT, ~~n~ rA ^I ~ .t^~~i-1 it ~' h Ce~'. - ;;~~~nY c~ ~~i 19 ('11 3.19 C~J~;t>>„~: ~: .:GJ~T~ ~r;. ,~,. t'Gu.~~L~;~~-v'r~ '~"~". Lindsay Dare Baird, Esq. 37 South Hanovcr Street Carlisle, PA 17013 Court-appointed attorney for Defendant Court Administrator -~{~~„mil G2~zLv~...«,~l. :rc J 111 ~' Q 1999 ~J AUTHORITY TO PAY COURT APPOINTED COUNSEL I. COURT 2~ V0U NaR 314 9 ^ DISIrICt J lice Common Pleas O Appellelo ^ Olhar J. FOR 10 . C.P.. APPELLATE) / 4. AT (CITY/STATE) t~ Ul~_C~OE S 1 S IN T H E CA F 8 . E O 7. CHARGE/OFFENSE IPUROON CITATIONI OFFENSE S. 0 PERY " ~ // ~~ ~ A ~ry,7t AZ .l7uL Ye I~ l' OFELONYOMISDEMEANOR 9 PRO EDINGS(Describe Orlally) 1I. PERSON REPRESENTED 12. CIVIL DOCKET NO/s~`1dr s J'r ( 1 O p•I•ne•nr•Aerp / I,~ `/~~ ~ ~ ` ' ~ ^%~~ L C(A ~/[ryr, ~('y)(rr ~(C h'(IV 7 O AoD•nam iS CRIMINAL DOCKET NO , . J . ^ ADDe~lae . ! ^ Hab•al P•hUen•r 6 U Maurw Wenns P w IO. PERSON REPRESENTED (Full Name) nn vauh°n r ^ uWe Cnara•a a U Proo.non.r Cnupee Wun Vwyuon 1s, APPEALS DOCKET NO (' ~ r/ / ` 9 O Omec ~, te. NAME OF ATTORNEYIPAYEE AND Aoor b.rte 1~(° • ,~y MAILING ADDRESS Lindsey Dere Baird // ,~ ~rNCUi bZt / // /! l ~~M 37 South Hanover Street 7 . . Cerllale, PA 17013.330 NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE 17. TELEPHONE Na 18. ldculsECUaitr HO Onlur no -'~3.1 r .. .) r9`- CLAIM FOR SERVICES OR EXPENSES 19. SERVICE HOURS DATE9 AMOUNTS CLAIMED a. Arnipnmanl and/or Plea MuttIDM me per bent hmea total ' ' b Prenm~nary Hurled hours to pbbin In Coun Com• penaallon. Enter total Oalew. C Monona and Raduub 2 d 9u1 Mudnpa ~ O e. Semencs Hunnpa U 2 1. Teal d. RwoOlldn Haarlnps n. Juvenile Heannpa . ADDean Coun 19A TOTAL IN COURT COMP. i Omer ISpeaty an eddinonal anaalal U '~ . '] O ~/ TOTAL HOURS w ~ U s, XRHOUR S ~~ ~ O 20. a. Interviews and conlerenctl ~ ~~ • ~' ~ Mulhply tab per hour hmea total LL 0. Oouminq and rewavnnQ reco•da , • 7 ~ noun. Enter toW 'OW of Coun' eompensatlon Oelow. O ¢ .- ~ c Ledal research and Orel wnnnp ( ~ . ~ ^ .(`ty O ~ d. Invesbgaova end omen wok ISpe6ry 011 additional ahaatsl 20A TOTAL OUT OF COURT COMP. Bp ~j ~ S TOTAL HOUR9 ~ ~ Xi ERHOUR / 0 r'ti 2t. ITEMIZATION OF REIMBURSABLE EX PENSES AMT. PER ITEM Mdoa a 5.25 r mde a W S 0 21A TOTAL ITEMIZED EXP. ~S 22. CER IIFICATION OF ATTORNEY/PAYEE 27. ORAND TOTAL CLAIMED Has compnnaahon and/or ralmbu~l'~anl for work In Ihb ease Drsvlouah bean applied tor'! OYES ~NO w f ~~ ~ ~ u ea were ou s? OYES R5 NO Il h l 7 H h7 , G y . y pal ysa byw om were you pe owmue d Has Ina person reDressnled psi a money to you, or le your know) dpe anyone else, In eonneclton with the manor for p~, DEDUCT. PRIOR PYMT3. wn~cn you were aopomled to provide repraaanlatlon7 O VES ~NO ICI s'~a OUjs details on additlpnd abash S w 1 swear or alhrm Ina truth or eorteelnsu /1 /~l'~lrt[1r 7•a C- ~~/ 9 25. NET AMOUNT CLAIMED of Ina aoOVe alalemenb Spnatul of Anomey/ arse Dab ~: /~ ~ ..~ (J 26+•+~~~-~~'~ Sq~aw•a of G// C 27. =MS. APPR+O~VED~~ Copy 1 -Mail to Court Adminlstrator at completion of service r ~ r I_" N ~; !. ..~: .. r, _ ~: -~ iii! J ~ K a: ~-~ r1 U AUTHORITY TO PAY COURT APPOINTED COUNSEL A!Jr n 3 1S99Gd I.couar 2.vou o ~ Olslnct Justice O Common Pleas O Appellate O Other N 3157 7. fOR ID J, C.P, APPELLATE) ~. AT tClTV/STATE) 5. BU06ET CODE t7 8. IN THE CASE Of 7. CNARGFIOFFENSE IPUROON CITATIONI e. O PETTY OFFENSE ~ ~, va ~ O FELONVOMISOEMEANOP r ~ r r 9. PRO EEDwGS 10ascnba paellYl I I, PERSON REPRESENTED 1Z. CIVIL DOCKET NO. 1 O Delendenl•bua ~~, ~' //~( f f' 7 D Oebndanl Ju.ero4 / .Lrt ;/ f/ t _ n q i't h l t{.I f ~~~~ c~ n e ~ ~ O Appmanl . O Appal.. lJ. CRIMINAL DOCKET NO,J - S D NapN{PNOpnet e D uuer,awnnas ltlan d lwln V T O P W CMr /O PERSON REPRESENTED (Full Namal g L N pe e O Prppeuonn LnarOaa wan Va4uan It. APPEALS DOCKET NO. 1S. NAME OF ATTORNEVIPAYEE ANO C/ Aopr Dsle ~a' U ' ~I MAILING ADDRESS /1 C .. / ~ d h Tlt,t rV rvEh Lt-far~C_ ~ (J P_ Straet H novar 37 Sout NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE Carlisle, PA 17013.3307 17. TELEPHONE Na 1e. SOCIaISECURIry NO OREnrNO ay 'a3a G ~ a-~ S CLAIM FOR SERVICES OR EXPENSES 19. SERVICE NOUPS GATES AMOUNTS CLAIMED a Arrupnmanl and/or Plea Mulllply rala par noun Irma talal o Pranmmary Nnnrp IIOYra to oola{n •In CourY com• pangtlon. Enlar low Oabw. c Monona and ReOuola R Q Ban NNfmOa ~ O e Sentence NeannOa U 2 1. Tnal 0. Rerdtallpn NHrlnpa n. Juvemla NnnnOa .. Appeua Coun 19A TOTAL IN COURT COMP. L Olner ISPK~Iy on addillonal aNala) f ~/ CN U , 'r! TOTAL HOURS- r ~ V ss .X•~O PERHOUR f rT T S [) 20. a. Intarvuwa an0 donlpendea MVltiply tale par hour Umn total 6 Oolunln0 and rerwwnn0 racor0e noura Enter total •Oul of Coun' W ti cOmpanaallon INIIOW. 0 7 c Lpal rnaarcn and Onel wntm0 . ~' ~ y O cOi d. Mvesppaava era oo+er worx (Spaary ad6oonal aMabl 20A TOTAL OUT OF COURT COMP. TOTAL HOURS- ~ ~ ~E~ RHWR -S ~ ~ , 2 t. ITEMIZATION OF REIMBURSABLE EX PENSES AMT. PER ITEM Mllea eS.25 rmle x W S '- O 21 A TOTAL ITEMIZlD EXP. wS 22. CERTIFICATION OF ATTORNEY/PAYEE 2~. GRAND TOTAL CLAIMED Naa cpmpenaalion and/or reime!~n~ant for work In Inb wa provbualy Msn appuad 1017 OYES ~NO • f (~ 5 L,v Il yea were you pa~oT ^ YE9 ;p NO Il a b whom ware aldT Nowm ou h7 , y ; y y p uc has lne person represented Oal any money to yoµato your kn lades elryona elss.ln rAnnactbn with US maKar for 2l DEDUCT. PRIOR PYMTS. wn~cn you were apoolnted to proNda rapreaanletlon7 D YES ~NO `11~; Olv OatYQla on additional aheala ~ f w 1 swear or alhrm the Irutn or eanactnaaa ~'+~ ~ ~tatN- ~ -47 -~T~ al lna aoora slalemnNS 25. NET AM~NT CLAIMED SlOnalun of Anomay/ ayai. Dale -_ ~ ~ l"tJ 26 +~'a~~~~rn S,Onalured ~ 27. AMT. APPROVED C~ py 1 -Mail to Court Administrator at completion of service ~- ., - ,. ~ ,, .. . _ , :" .: :; ;' ';, ' ' _ ~ %; r ~ . ~~ _ ~ . ~~ r . ~,, ; : ~~. (, 'r,r '.,. ~~~ ' `~T,~ , ~. ~1~~;~'iS'tjt~, ~:~~' KRISTY M. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW PAUL E. GREEN, 94-I 166 CIVIL TERM Defendant ORDER OF COURT AND NO W, this .~`/ ~ day of August, 1999, upon consideration of Defendant's Petition to Enforce Custody Order, filed March 15, 1999, and Plaintiffs Petition for Modification of Visitation Order pursuant to Pa.R.Civ.P. 1915.15(b), and following apre- hearing conference held on June 7, 1999, the appointment of Bruce E. Snyder, M.S., pursuant to 23 Pa.C.S. § 5303, and production of a report by the appointee, a hearing on the parties' petitions with regard to custody of the parties' daughter, Kaylee Green (d.o.b. August 22, 1992), is scheduled for Friday, October 22, 1999, at 1:30 p.m. in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. Defendant, who is in a state correctional institution, may participate by telephone if this can be arranged by his counsel. BY THE COURT, n ,.. Robert E. Rains, Esquire Thomas M. Place, Gsquirc Supervising Attomeys Donald Marritz, Esquire StaffAttorncy Leann Mattoscio Legal Intem Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 Attomeys for Plaintiff Lindsay Darc Daird, Esquire 37 South Hanover Street Carlisle, PA 17013 _ Co~o• n~C. Fr/a S~q 9_ .,d.'d', Court-appointed attorney for Defendant Court Administrator Sheriffs Office :rlm •~ KRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN CUSTODY PAUL E. GREEN, Defendant NO. 1166 CIVIL 1994 AND NOW, this _L ~~ day of , 1999, upon consideration of the attached Request for rit to Transport, the Cumberland County Sheriffs Department is hereby ordered to transport Paul E Green from the State Correctional Institution at Wayy~~}}art to arrive in Cumberland County Prison no later than Thursday, October i~', 1999, for a Custody Hearing scheduled for October 22, 1999 at 1:30 p.m. in Courtroom No. 1, Cumberland County Courthouse, before the Honorable Judge Oler. cc: Cumberland County Sheriffs Department - Pow _ /f ~~ Q ~1-~ 1 Courthouse Square, Carlisle, PA 17013 9•i•99 ~ / Leann Mattoscio, Legal Intern . ~~ ~a~/ 9. /, 91 Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 Lindsay Dare Baird, Esquire . ~ ~„ ~~,~ 4-/ •9f' 37 South Hanover Street Carlisle, PA 17013 Court-appointed attorney for Defendant By the Court i-_.:. R. r, , t' ~ ii A't I. S9 SFP I Pi ?~+5~i-i .I Clifsl.. 7:J LV1111'1 1 ~'..; Y~L'~ii'JJYL::~E~'\ _~ 9./•91 os~~lr to .~L~ a,~ ~ ~~~ ~ ~ ~ E .~ ~r~ ~ ~ oulc, . ~e~ -~ a« F ~ . - ~~ ~ •- I~RISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA ~, : CIViL ACTION • LAW IN CUSTODY PAUL E. GREEN, Defendant NO. (166 CIViL 1994 REQUEST FOR WRIT TO'pRANSPORT AND NOW, comes Paul E. Green, the Defendant, by and through his attorney Lindsay Dare Baird, Esquirc, and respectfully requests transportation from the State Correctional Institution at Waymart to Cumberland County Prison for the purpose of attending the custody hearing scheduled for Friday, October 22, 1999, at 1:30 p.m. in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania before the Honorable Judge Oler. Respectfully submitted, (~ ;L,tpl~i~~tC JV Lindsay Dare Boaird, Esquire Attorney for the Defendant 37 South Hanover Street Carlisle, PA 17013 (717) 243-5732 r ,ica ;3 SEP - - Iii 7_~ `l+ ., ~: ' J STATE OF PENNSYLVANIA, ss Cumberland County, The Commonwealth of Pennsylvania to the State Correctional Institution of Waymart GREETING By an Act of Assembly of 1785, we command you to have the body or bodies of ____Paul_E._Grt'eD___________________ before the Hon. __. J..Wesley_Oler,_Jr._________________ of the Court of ____Camoon_Pleas____________________ of said County, on _FYiday___ the _22 _ dayof~tot~l9.99, Ctxm. No. 1 a} __1_30 o'clock, P•. M, at the _~~_CO~ .COL1L*h_°,~fethe Borough of Carlisle, together with the cause of his detention in your custody. Then and there to do and receive all and singular those things which our :aid Judge shell consider and adjudge in that behalf. Witness the Honorable ..___~~_WeBley Oler,_ Jr_______ ____________________ Judge of our said Court, et Carlisle, the _ _ 1st _ . _ _ . day of _ ~ptember _ _ _ _ _ _ _ _ _ _ A.D. 19 99 _ _CUrtis R._Long___________________.-__-- Prothonotary and Clerk of Court ~ _~..~r- - ------- --- }~ - - Deputy ~~ l/ a 1 O~ 0 Z 1 i ~i E~ ~i 1~1 i ~I ~, i W. i ~I a. I N ~ 7 ~ 1 ~ A ' ~ N M ~ O o ' n _ .-~ ~ ~ o ~ a~i 3 ' ~,~IN i i ~' ~ i ~ i ~ ~ V i ~€ ~~ 1 'a 1 1 i KRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA v :CIVIL ACTION-LAW IN CUSTODY PAUL E. GREEN Defendant. : NO. 1166 CIVIL TERM 1994 STIPUt.AT1ON And now this 19'" day of October, 1999, the parties in the above-captioned matter, by and through their respective counsel, stipulate to the following facts: I. If questioned, the child, Kaylee Green, would say that she would like to see her father, Paul E. Green. 2. The distance from Shippensburg, Pennsylvania to S.C.I. Waymart is approximately 185.5 miles one-way, with an estimated travel time each way of 3 hours and 42 minutes. 3. Visiting hours at S.C.I. Waymnrt are from 9:30 a.m. until 4:30 p.m. on weekends. Visitation with nn inmate is a "full contact" visit. It takes place in a visiting room, and there are staff members on hand to supervise the room. Leann Mattoseio Certified Legal Intem ~ Robert E. Rains Thomas M. Place Supervising Attorneys Donald Mnrtitz Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 i !/.~li Lin say Dare rd ~~ 37 South Hanover Street Carlisle, PA 17013 (717)243-5732 Counsel for Defendant Counsel for Plaintiff Q C ~s ..~ ~~ ~~. o~ ~L: ~ ~~' _ ~. V ~F, O ~~ U Q~1 V .~ ".., KRISTY M. GREEN, Plaintiff v. PAUL E. GREEN, Defendant N0.94-1166 CIVIL TERM ORDER OF COURT AND NOW, this ~/6`F~day of October, 1999, upon consideration of Defendant's Petition To Enforce Custody Order and Plaintiff s Petition for Modification of Visitation Order Pursuant to PA. R. Civ. P. 1915.15(b), with respect to the parties' child, Kaylee Green (d.o.b. August 22, 1992), it is ordered and directed as follows: 1. Legal custody of the child shall be shared by the parties. 2. Primary physical custody of the child shall be in the mother; 3. The father shall have visitation rights with respect to the child as follows: a. Following two telephone conversations on successive weeks with the child, at the father's expense, each month on the third Saturday of each month for a period of up to three hours at the state correctional institution at which the father is an inmate, supervised by a person approved by the court upon motion of the father's counsel, and transported by a person approved by the court upon motion of the father's counsel; b. At such other times as the parties may mutually agree. IN THE COURT OF COMMON PLEAS OF , CUMBERLAND COUNTY, PENNSYLVANIA , CIVIL ACTION -LAW BY THE COURT, •.~ ~~~.~~~',.~ r vG :~ Q^. I? 7 P i 3:14 -,~ ~ ~~~~ C,!!! ~:~.,~~~: i'~. ..;~,.,~ „t l 4 I „ Robert E. Rains, Esq. Thomas M. Place, Esq. Supervising Attorneys Donald Marritz, Esq. Staff Attorney Leann Mattoscio Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, Pa 17013 Attorneys for Plaintiff Lindsay Dare Baird, Esq. 37 South Hanover Street Carlisle, PA 17013 Court-appointed attorney for Defendant :rc :• AUTHORITY TO PAY COURT APPOINTED COUNSEL FEB $ 8 2000 t. count 2.v000HER N~ 3 3 6 4 O D~stricl Justice ^ Common Pleas O Appellate O 0171er FOR ID J. CP, APPELLATE) ~. AT (CITY/STATE) 6 BUDGET CODE e IN 7HE OAilEF vts ~ pL /tP•~ 7. CHAROE/OFFENSE IPURDON CITATIONI 0. O PETTY OFFENSE rs ~~jj 7C ~ - i f O FELONYOMISDEMEANOR 9 P,nOCEEDINGSIDascnbs bnelly) 11. PERSON REPRESENTED 12. CIVIL DOCKET NO. //~ ! N/ t O ar.~wanl•Aauu 2 D D/lendanl •JY.en~4 /I 9~-~~~~/ ((rS~ 1, (•lS(f. C~i1 ~C(C1,I r[C (, J ~ a O Apgnanl • O APPaM. 1y CRIMINAL DOCKET NO S 7 „aoau Panuonar e O Nabrul Wdnua t 10 PERSON REPRESENTED /Full Namal eran 7 O vars.. Cnarpea vnln ve e O Probauonu Cnupad Wnn vaWwn 1e, APPEALS DOCKET NO. //~' \ ~• `7rzNn ~1[ [.712 ~•~ E ( ~Q e O Olbc / , . / /A ~/_ Auor b.rte .rc V 18. NAME OF ATTORNEY/PAYEE AND MAILING ADDRESS ) I Lindsey Dere Beird ~ ~ (fin 37 South Henovar Stroet NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE Carllolo, PA 17013.3307 17. TELEPHONE Na te. SOCUt4ECUanrNO OA[wNn CLAIM FOR SERVICES OR EXPENSES tg, SERVICE HOURS DATES AMOUNTS CLAIMED a. Arra~anmenl and/or Plu Multiply rab qr noW hmn local b Prlnmmary Munro hdYtl 10 dbtaln •In DourY Com• gnaaoon. Enur tort below. C Mollonf and ReWUIa 2 d Bad Haarinpa ~ O e. sanlena Hunnoa U Z I. Thal io•dd• o. Rarocallon Hurlnof n. Juvends Haumoa r. Apulia Coun 1gA TOTAL IN COURT COMP. r Olner ISgcM on additional muul TOTAL HOURS. a . S .~ PER HOUR f ~ ~ ~ S U 10. a. Interv~ewa and conlaranpn Multipy rate qr hour time total ' ~ n OOtammo and rwiewlno recadf hgra Emu local •Out of Cqn ComgnNtlOn ONOw. O ~ ~. ~ c Lepal reaaarpn and Deal wrdlno O u d. Invesooaova and omar work (Speoty an additlonal fheeta) 20A TOTAL OUT OF COURT COMP. TOTAL HOURS. S S 'K{fO PERHOUR ~7 , / S r~S 7 ~. r~ l,~ 2 t. ITEMIZATION OF REIMBURSABLE E% PENSES AMT. PER ITEM 7AIea a 5.25 r milli a w ~. / .~• O = O 2fA TOTAL ITEMIZED E%P. ?? s ~' v[.J 22. CERTIFICATION OF ATTORNEY/PAYEE 2S ORAND TOTAL CLAIMED Haf compensation and/or rsimbunemsnl la work In Ihb eue prerkwaN been epptied 1o// OYES ~~ NO w f -3,h. •~ ~ p Il e4were ou aid? OYES hl NO Il l H b h l h7 y y p ye4 yw am were youg owmuc d Haf the Dorton represented ald an mono Io uu, or to our knowle y p Y y y y dga en one ales, In donnsdtlon with Ihs meaar for 2<. DEDUCT. PRIOR PYMTS. which you were appomtad to wovida rspraasnlatlon? OYES !~ NO U ye4 Olre'llelup on eddillonel fksste ~ S 1 1 swear or allnm Ire Irulh or ppnactneu -- Y. A.i/'yi: .!"Y J .>tr ~tt 25. HET AMOUNT CLAIMED or lne above ualemnnlf 8gnelura of hdrnay area Otis 2B+•'o•r~~~i ~~ .arw Sp"slurs of ,~~7 ~6CO tw - ~ / 27.AMT. APPCROnVED _ os -OUC /" 1 ZJL I . f O '(. J A Copy 1 • Mail to G`OGrt Adminlstrator at completion of service fl! Fit ~~ FiC~: 00 Mks -7 AFl 9:52 CU~:fc~r:~i~iJ CCUNiy P~~'SYW~IVq .~ ~A . f l 911199 10/5/99 10/20/99 10/22/99 10/25/99 9/99-11 /99 Writ to Transport, Order & filing Subpoena witnesses Hearing research, doc. & exhibit prep. Toil call from CCP/client Meet with client Meet with witnesses Hearing Toil call from CCP/client Numerous letters to client .50 @ 45.00 22.50 .50 @ 45.00 22.50 2 @ 45.00 90.00 1 @ 1.15 1.15 1 @ 45.00 45.00 1 @ 45.00 45.00 2.5 @ 55.00 137.50 1 @ 1.15 1.15 .50 @ 45.00 22.50 TOTAL 387.30 LONG DISTANCE CHARGES BILL FROM 717-243-5732 BILLED ON BEHALF OF VALUE-ADDED COIAM REF DATE TIME PLACE CALLED 1 OCT 20 O1t42s00pw CARLISLE PA 2 OCT 25 10 r54t00as CARLISLE PA SlA3T07AL SUBTOTAL FOR 717-243-5732 f '•_ ~~ ."~` ~ I/ ~ I `' 1 ` i.r~i C ' C Y~v It' ~ yL, ~~ LV~ C • 1J NU6ER CALLED FROM PLACE~FRON NU-BER CODE MIN ANOtMr' 717-243-5732 CARLISLE PA 717-246-8787 AOS 2.0 1.15 717-243-5732 CARLISLE PA1 717-245-8787 ADS 4.0 1.151 ~ ~~~ i n TOTAL LONG DISTANCE_CHARGES ;IJ~ty J4 y~~~w ~ ~~.\M~.1 ...`i~lUl ~a~~~ ~ 1 <C~4.. .+ .. 'I(.^,'.. :u u.~CalY a.-m.w..~.-. _.. 7. ~fi 'il 2.30! 2.30 AUTHORITY TO PAY COURT APPOINTED COUNSEL '~~;i i 2. VOUCHER t. COURT N° 4 6 4 6 O Dlstrlct Justice O Common Pleas ^ APPallale ^ Other J. FOR ID J., C.P. APPEIlATE1 4. AT (CITY/STATE) UD E~ O ~E ~ -~ V B. IN THE CAitiE9P - u' t'n / tt / %7 7. CHARGE/OFFENSE (PUROON GTATIONI ENSE B. O PETTY OFF O FEIONYDMISDEMEANOR w 9. PROCEEDINGS (Dssenbe bnally) 11. PERSON REPRESENTED 12. CIVIL DOCKET NO. ~) /% I i D D•r•nd•nI•AGYII 7 O DN•ndant •Ju~•ml• ~~-/i G IJ(~ ~7 ~ ~tJ !1 $/'[' q<~ (/ /. 7 D •oP•uant 19. CRIMINAL DOCKEL NO • O •PP•un S 7 H•0•ef P•IIr1eMr 6 D M•1.1u1 WAnH• J G ParoM• Cnarp•d W~In Wol.ucn tq. APPEALS DOCKET NO. 10. PERSON REPRESENTED IFYX Namel e O Prob•uonu Cnnp•e wan Wp4non /'1 s 9 D Om•[ 1 E. NAME OF ATTORNEY/PAYEE AND f ~' ~ ~ ~~ MAILING ADDRESS + I •PPI D+r• Dare Baird ,,ff~~ / ~ Und9ey 37 SoutbH° 3307 ~ J!L CSCtf L'Ur Jt 17013. A ~ , ~ Carlislor P NAME OF COMMON PLEAS JUDOE ASSIGN D TO CASE 17. TELEPHONE No. la. soausECVPIr.r.o oREUrrro CLAIM FOR SERVICES OR EXPENSES SERVICE 1B HOURS DATES AMOUNTS CLAIMED , a. Arnipnmenl and/or PIU MulUpb nu per hour puree lobl hours to obtain 'In Court' com~ b. Pqummery Hudnp peroallon. Enter total below. C Mo110na and Rpueere a Bad Nunnpa ~ e. Sentence HunnOa tl 1. Tnel 2 - p. RevocalWn HuNnpa R Juvenile Hudnps f Appaela Court 19A TOTAL tN COURT COMP, I Olhar (Speedy on addillonal snub) TOTAL HOURS w FId1R w 5 20. L Inlanruwe and conbnntu ~ I /S S AC'O MulnpN np per Mur bursa lObl hpUEL Enlef IOlel'Dul 01 CWId• u b Obluninp and reNernnp records - OOmpenullon allow. . O ¢ c lapel reauren and Onal wtllirlp O~ d. Inwaagatlve and oNer work lSpeoh on arldilional Neer) 200. GAAP OUT OF COURT ~~..~~ TOTAL HOUR9~ /T/, S' dHbPERHWR 5 r~`G).a~ .~ 4~ 2 i. ITEMIZATION OF REIMBURSABLE EXPENSES AMT. PER ITEM AAile a 5.25 J urge X W u << rr7 ~ ~'~i l ~iri ism. / ~ " ~ ~ - / 21A TOTAL ITEMI2E0 EXP. r ( O O _ _ 5 ~~ G, 22. CERTIFICATION OFATTORNEY/PAYEE 29. GRAND TOTAL CLAIMED Has compenaauon and/or nimbunemanl for work In ihb cue pnvlouaty Wen epplled lotJ OYES D NO ~ 5 ~ / h ,, / S Il yea.wareyou pald7 DYES D NO Ilysa bywhdm were you peid7 Howmueh7 pq, DEDUCT. PRIOR PYMTS. Haf Ina person repraaenled geld any money to you, U io your kndwladpe anyone alas, In eonnaetbn with the mener for ~ 5 rovide rsprsunlelion7 OYES ONO 11 yes, glue Oalalla on edditlpul aheete r olnlad to n n you we p w ic e app I awur or allbm Ne truth or eoneetneu ?~ Dale /Pare twe d AKOmf nb 8gn n b l f l 25. NET AMOUNT ClA1ME0 ~ 5 ~ / ~"~ / , y a a ove a a emo a I o , , ~ 28.erniom n nw ~ - S9nUmed / {' " ~ 'J 27. AMT. APPROVED ,. w 5 ~S ~~.ur«r ~ Judge F /~ (% `~/ ~ 111 ~Oelt r r ~ ~D t ~ 06py 1 • Mail to Colin Administrator at eompleUon of service „;„ U1hi':YIi P.1 I:9 PcP1NSYLU~~'~:!A r t t ~ ~ _-~ ~{~ i ~ n l Momhly statement: November 28, 2000 6 of s Customer number ~4 ~• 717.213.6732.847 AT&T AT&T charges Call 1-500.222.0400 for billing inquiries Sprint provides billing on behal/ of AT&T. There is no connection between Sprint and AT$T. Please review all charges appearing in this section. Any question regnrding these,eharges should be referred to the numher provided for billing inquires. Summary of ATf1rT charges Long Distance services Direct dial charges 717-243.6732 10.05 Taxes Federal tax .30 State tax .60 Total AT&T charges i10.e8 Direct dial Itemized calls ., .~ 1 Oct 11 3:28 P CARLISLE. PA 717-243.5732 Day 15.0 ..; .10.05 Irom PAYPHONEPA 570.188.571? Operatorasaist Torol direct dial charges 510.05 -~. J~~rlll ~. Monthly statement: March 25, 2001 s of e Customer number 717.243.8732.847 ZpD'' ZPDI charges r Call 7-888.509A734 for billing Inquiries Sprint provides billing on behall o/ZPDI. There is no connection between Sprint and ZPDI. Please review all charges appearing m this section. Any question regarding these.charges should be referred to the number provided for billing rnquines. Summary of ZPDI charges Charges billed on behalf of Value Added Comm Call 1-888.509.0734 for billing inquiries Long Distance services Direct dial charges 717-243.5732 2.60 Total Value Added Comm charges 52.60 Taxes Federal tax .08 State tax .18 Total ZPDI charges 52.84 Value Added Comm itemised cells Dlraet dial ftemtzed calls . ~ f ~. 1 Mar 2 2 Mart 1:08 P CARLISLE, PA Irom CARLISf E, PA 3:18 P CARLISLE, PA _lrorn CARLISLE, PA 717.213.5732 Day 8.0 1.30 717-715-8787 Operatorassiat 717.2!3.5732 Day 2.0 - 1.30 717-2d5.8787 Operotorasclst KRISTY M. GREEN, Plaintiff v. PAUL E. GREEN, Defendant ~ a, < LtAtD9AY IIARF; BA1Rb ~ ~" r a ' ' ~ nrro~iex er i.i~w •,, ~ •s9~sc+u'iti ft~rioven 8niccr -. '~ ; ° peNNeit4v~MA 17Q1s~9807 ;.; QI~IU}ieLS , ,'' , .. ;; (n7) sas~6792' lA)c (71,Y) 4A8.8~10' -; ~' IN TEIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.94-1166 CIVIL TERM ORDER OF COURT AND NOW, this 19'h day of September, 2002, upon consideration of the Petition to Withdraw as Counsel, a Rule is hereby issued upon Plaintiff and Defendant to show cause ~vhy the relief requested should not be granted. RULE RETURNABLE within 20 days of the date of this order. iLindsay Dare Baird, Esq. 37 South Hanover Street Carlisle, PA 17013 /Kristy M. Green 3 Barry Circle Shippensburg, PA 17257 Plaintiff i Paul E. Green 32 East Main Street Newville, PA !7241 :rc ~o~ 9 ~ ~~ C ,Q~ 0~.\°1 n`3!~!` ~~ i.'i. i ~ 14i„ BY THE COURT, '. i ~- ~~ ~. KRISTY M. GREEN, Plaintiff v. PAUL E. GREEN, Defendant AND NOW, This day of foregoing petition, it is herby ordered thaC IN TFIE COURT OP COMMON 1'LL•AS Of CUME3ERLAND COUN'T'Y, PENNSYLVANIA CIVIL ACTION -LAW IN CUSTODY NO. 1166 CIVIL 1994 2002 upon consideration of the (I) a rule is issued upon the respondcnt to show cause why the petitioner is not entitled to the relief requested: (2) the respondent shall file an answer to the petition within twenty days of service upon the respondcnt; (3) the petition shall be decided under Pa. R.C..P. Nn. 206.7; (4) argument shall be held on , 2002 at M. in room of the Courthouse. (6) Notice of the entry of this order shall be provided to all parties by the petitioner. BY THE COURT: J. Cc: Lindsay D. Baird, Esquire Mr. Paul E. Green Ms. Kristy M. Green KRISTY M. GREEN, PlaintifT v. PAUL E. GREEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW IN CUSTODY NO. 1166 CIVIL 1994 AND NOW COMES, Lindsay Dare Baird, Esquire, hercinaltcr referred to as petitioner who moves this Court to grant her motion to withdraw as counsel and in support thereof respectfully represents the following: On December 6, 1996, the court appointed Lindsay Dare Baird, Esquire to represent the defendant/respondent in his custody matter. 2. On September I, 2002, the respondent was released from prison. 3. The respondent contacted counsel to assist him in visitation with his daughter. 4. Court appointed representation by Lindsay Dare Baird, Esquire, is no longer necessary because the respondent is back in the community and presumably able to work. 5. Lindsay Dare Baird, Esquire seeks to withdraw as counsel of record for the client. WHEREFORE, Lindsay Darc Baird, Esquire prays this Honorable Court to grant her motion to withdraw as counsel in the above-captioned matter. Respectfully submitted, 1~2c,.~- ni3say D• aird, Esquire 37 S. Hanover Street Carlisle, PA 17013 (717)243-5732 Petitioner and Attorney t'or Defendant cc: Mc Paul G Green Ms. Kristy M. Green 1 verify that to the best of my knowledge and belief, the statements in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS §4904 relating to unsworn falsification to authorities. ~~ ~ dsay Dare ird, Esq ire etitioner r-. >: - ~ ~ i'r <.ir a. ; ~';i ;; i_ -? ~- is{^. U. V~ _s ~., ~.~ AUTHORITY TO PAY COURT APPOINTED COUNSEL NOV 7 5 2007 ~ ~ 1. COURT 2. VOwUfCHER ,"I 5 5 91 l O Dlslrlct Justice O Common Pleas ^ Appellate ^ Other No J. FOR ID J, C.P., APPELLATE) i 4. AT (CITY/STATE) e. BUDGET fpDE a B. IN 1NE CASE OF 9. PROCEEDINGS (D•u//r10• Driellyl /'~~i~im ~o l~ri~/rY/a~J PERSON REPREpSENT//E`~D (Full Nemal AOPI Dala ~~ •G ~ ~~/ NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE 10. CRIMINAL DOCKET NO 14, APPEALS DOCKET NO. 18. NAME OF ATTORNEY/PAYEE AND MAILING ADDRESS 17. te. en0lor PNe C MDIION mo Reow 2 6 Bea Hurinpe ~ e. Sentence Nuonpe O O I. Tnel z R Jurande Heerinpe . Appub Coun L Olner ISoeClly on e0oillonel eMetal TOTAL HOURS w 20. a Interviews ens eonlereneu ~ e/f fIJT u. 6 ODle~ninp ens revlewfrp reCGes O ¢ e Lpel rneercn and Dnel wrlDnp e / M ~ O p. InvasoO+Dve arW ogler work (Speafy pn eddieond sN ou TOTAL HOURS w 21 (PURDON 8. O PETT7 OrrGnJt D FELONY D MISDEMEANOR 12. crva Docl~u %dda~ 9~ i~~G it. PERSON REPRESENTED t ~ wl.na.m•Aawt 2 ^ D•Lnaam •Jo.emle J O APPelhnl • ^ aoP•n•• S ^ Haeeu P•onon•r e ^ Malerul Wdneff 7 O Parpl•• CMrD•e Wdn Wolanon e O vme•uon•r Cnne•e wan vrounon 0 ^ Oln•r ~•r~~ Undsey Dare Belyd ' ^nuth flenover Street i : e ,,, :, i'A 17013.3307 Na Its. -S ~ 3~• %f50 PERHOUR I w f COMP. ~ ~ ~ a MuthPN nN per naur 6mef total hOYra Enter lOtel'Oul al Coun- wmpensellon allow. •• q / 20A TOTAL OUT OF COURT COMP. ¢ r a ~ •%O rnfr ~ i Q~ 'Y•'lA x I 21A TOTAL ITlMIZED E%P. r O wf U O 22. CERTIFICATION OF ATTORNEY/PAYEE 2A GRAND TOTAL CLAIMED Haf compsnaetlon anNor relm emsnt for woAc In thle we pnvlouaN Dee^ applied for? OYES ~NO ~ f Ilyaa.were rouperaT OYES ~NO IlysabYwhomwre youMldT Howmueh7 24, DEDUCT. PRIOR PYMTS. Haf Ins person reproanlad peal en money to you, or to your kn sdps enyons des, In conneelbn with Ns meRer for ~ f wnicn you ware apPOIn1eC to proMOe repreeentellon7 OYES NO I ye ~plve d loll on eeeitlonel sheets 1 !wear or alllrm Ins Irutn or eoneelneu ~~'fT ' ~~~ 23. NET AMOUNT CLAIMED 01 Ins aDOre llalamenla 8q • /P ee Oele ~ f 28+~'Wn.vlu 27. AMT.A/ 9~ D O/ nw 59nnur• d L~OZ - f / 7 ,...arr. Juop. - -DU.: NOV ~ 9 7. MuIIIPN me per naur Umu Io W hours to oDlein 'In Coun' com• penullon. Enter tole! Dlow. Copy 1 • Mail to Court Administrator at completion of service ~Y~ s CA SLt 0 CARLISLE. Pemsylvenie 170132935 39/17/2002 1800)275-8777 03:23:06 PM Soles Reeetpt Product Sele Unit Flnel Descrfptton Oty Price Price ?A 17110 return :+ae ~t 31.75 Certified x,30 Label $erlal N: 000656916122 !slue PVI: rE41VILL"c ?A 17241 40.37 Flrst-Cless Return aeceipt 41.75 Cartlfted 32.30 Lobe) Serial N: 70012510000658916146 Issue PVI: ;4.42 SHIFPENSBURG PA 1725 7 .37 rlrst-Class Return Rscelpt 41.',5 Certtfled 52.30 letrei Sertsl N: 70012510000658916139 Iscua ..:=:e.. pVI: 34,42 Total: ~~ 312.39 Paid by: Cash 820.00 Change Cue: -37.11 B111N: 1000200921319 Clerk: 02 Refunds only per OMM P014 --shank you for your business Cuatoeer Copy S~ ' ~ ,~ ,. LINDSAY DARE BAIRD , , ' ` G;_ `.. ,. .~ ( 4t ~~. 4 ATTORNEY AT LAW ; ' ~ ~ $7 90UTFi FIANOVBR BTREEM1' ~ ti w ~ 9 ~' ~-~'+ r 7 ~ ~., >~ C~IO.tet.E, YENNSriviWU 17018.3$07 ` , ~': ' •,, , (717) 78.6792 YAX (717)143, 8110 '- '-• : ~ , ~ ,, , KRISTY M. GREEN, IN THE COURT OF COMMON PLEAS OF 0 Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA • qv - n~~ MAY U 4 200~~ v. NO. t PAUL E. GREEN, :CIVIL ACTION-LAW Defendant : IN CUSTODY ORDER OF COURT ~Ut ~ , Lo~o~ H AND NOW, this_~ day of Nevember;-~ee3; upon consideration of the attached custody stipulation with respect to the parties' child, Kaylee Green, born August 22, 1992, the terms of the stipulation are entered as an order of court. BY THE COURT, D J. Kristy M. Green 3 Barry Circle Shippensburg, PA 17257 Lindsay Dare Baird, Esquire 37 South Hanover Street Carlisle, PA 17013 Attorney for Father ~~ ,r pc vY .tc~.cce ~~_ ~~ ,.. F1LFJ-~r;;;'4 Ur The Ff?UiHtti..,~~~1,?}' ~,~ 2004 HhY -o rY"ii 2~ 17 Pc' '~','Y11~: ~> ~',1 KRISTY M. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 96-1166 PAUL E. GREEN, :CIVIL ACTION-LAW Defendant : IN CUSTODY STIPULATION FOR CUSTODY STIPULATION made this 2~_day of r~ , 2004, between Kristy M. Green, hereinafter referred to as Mother, and Paul E. Green, hereinafter referred to as Father. WHEREAS, the above-named Mother and Father had born to them the following child on the following date: Kaylee Green August 22, 1992 AND WHEREAS, the above-named Mother and Father desire to enter into a Stipulation as to the custody of the above-said child: NOW, THEREFORE, in order to effectuate the above purpose, the above-named Mother and Father hereby stipulate that: 1. Mother and Father shall share legal custody of the child. 2. Father shall have primary physical custody of the child. 3. Mother shall have partial physical custody of the child as agreed upon by both parents. 4. Father agrees not to file for child support. TO THIS PURPOSE, The parties hereto intend to be legally bound by the terms of this Stipulation and desire to have the Stipulation entered as an~g rder of Court. nO~ r~~~ ~ ~ r,~~ ~ndsay Dar Baird; Esquire /~ ~/ Witness Y,. /F i ~i0 y {lQ~ CfJ ti- _af. ~ G S V ~ N ~'' ~i c ~ ~ c ~~ !:?1 M ;t~ ~n ' 1 .1;'. ' U-Z F-' `~ :ll Cl ' S N /~/ •~~ / IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTY M. GREEN, Respondent No. 1994 - 1166 v PAUL E. GREEN, Petitioner CIVIL ACTION -LAW CUSTODY PETITION FOR MODIFICATION OF A CUSTODY ORDER AND NOW, this ~ day of April, 2007, comes Petitioner, Kristy Green, by and through her attorney, Suzanne Spencer Abel, Esq., and who avers as follows: 1. The petition of Kristy Green respectfully represents that on May 6, 2004, an Order of Court was entered based upon the parties' Stipulation Agreement, a true and correct copy of which are attached. 2. This Order should be modified because the Petitioner has, for the past 3 years, been denied regular visitation and communication with the minor child, to wit: a. Respondent refuses to cooperate in good faith with all prior attempts to schedule and maintain regular, consistent contact between Petitioner and their daughter, in violation of the parties Stipulation Agreement; b. Respondent directly and indirectly discourages their daughter from honoring the minimal contact Respondent does schedule, substantially disrupting Petitioner's relationship with their daughter; c. Respondent consistently sends Petitioner's phone calls to voice mail, effectively prohibiting direct communication with their daughter; and, d. Respondent repeatedly fails to convey to their daughter Petitioner's messages, further intermeddling with Petitioner's attempts to communicate with their daughter. 3. Further, the Order should be modified because the minor child's home environment exposes her to a physically, emotionally, and socially unsafe environment, as evidenced when the minor child was referred to her school's student assistance program by her peers and school guidance counselor, which services were unilaterally refused by Respondent. 4. Petitioner believes, and therefore avers, that Respondent's blatantly disrespectful conduct toward Petitioner negatively impacts Mother's relationship with their daughter. 5. Based upon the deteriorating relationship between mother and daughter, Petitioner believes the child requires a therapeutic psychological evaluation with treatment recommendations to determine from what, if any, services the child may benefit. Petitioner seeks an Order directing such an evaluation. WHEREFORE, Petitioner, Kristy Green, respectfully requests this Honorable Court modify the existing Order to provide for primary custody with the Petitioner, and to order a therapeutic psychological evaluation with treatment recommendations of the minor child, because it will be in the best interest of the child. Respectfully submitted, Spencer Abel Law Office ~ Suza Spe Abel, Esq. Attor I D #202443 22 East Street, #6 Mt Holly Springs, PA 17065 {717) 323-0046 spencer abel_esq~a7fastmail.fm Counsel for Petitioner Page 2 ' f • ~ ~ • ', LINDSAY DARE BAiRD ' '' ' ~ ,• , ~ f ; ~ •" A'1'1'ORN1dY AT LIIW ~ '. ~~ k .~.~ 1.,• ' 37 9ovrn IUNOV~R Q'rtta~i' ~ 1 ~,~ ., .~ ~ .. ~ ~ ~ ~ " , ~'~ • ~~ ~ ~ ,. ~ 'Q~.j~Wi, PiiNNSYLYi1NIA 170193307 - -~ r ,. ~ :'~k. ? ... . _ . , '. . ~ . ~ 1717) ~48•~73Z ~ YNC (7~7) X43.8114 ;~ . ' : ~ f ° . ~., ~ ~.. ~ ~ ',~ ~,. ---- KRISTY M. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA qy _ l~c,~ MAY U 4 2 y, NO. 9 PAUL E. GREEN, :CIVIL ACTION-LAW Defendant : iN CUSTODY ORpER OF COURT ~~` Zoo `~ ANp NOW, this day of beF,-983; upon consideration of the attached custody stipulation with respect to the parties' child, Kayiee Green, born August 22, 1992, the terms of the stipulation are entered as an order of cour#. BY THE COURT, J. Kristy M. Green 3 Barry Circle Shippensburg, PA 17257 Lindsay Dare Baird, Esquire 37 South Hanover Street Carlisle, PA 17013 Attorney for Father ~d~-~Y ~~d L•- ~ . KRISTY M. GREEN, 1N THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. N0. 96.1166 PAUL E. GREEN, :CIVIL ACTION-LAW Defendant ; IN CUSTODY STIPULATION FOR CUSTODY STIPULATION made this 2~~day of ,~'ri , 2004, between Kristy M. Green, hereinafter referred to as Mother, and Paul E. Green, hereinafter referred to as Father. WHEREAS, the above-named Mother and Father had born to them the following child on the following date: Kaylee Green August 22, 1992 AND WHEREAS, the above-named Mother and Father desire to enter into a Stipulation as to the custody of the above-said child; NOW, THEREFORE, in order to effectuate the above purpose, the above-named Mother and Father hereby stipulate that: 1. Mother and Father shad share legal custody of the child. 2. Father shall have primary physical custody of the child. 3. Mother shall have partial physical custody of the child as agreed upon by both parents. 4. Father agrees not to file for child support. TO THIS PURPOSE, The parties hereto intend to be legally bound by the terms of this Stipulation and desire to have the Stipulation entered as an~rder of Court. ~O~ r~ .[ ~~ X ~G~~ ~ndsay Dar Baird,`Esquire ~~~ ,/ Witness IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTY M. GREEN, Respondent No. 1994 -1166 v CIVIL ACTION -LAW PAUL E. GREEN, Petitioner CUSTODY VERIFiCAT10N I VERIFY that I have personal knowledge of all facts not of record set forth in the foregoing pleading, and that such statements are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: ~ t {N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRlSTY M. GREEN, Respondent No. 1904 - 1166 v CIVIL ACTION -LAW PAUL E. GREEN, Petitioner CUSTODY CERTIFICATE OF SERVICE l certify that, concurrent with filing the foregoing Pefition for Modification of a Custody Order, ! am this day serving a copy of same by Certified, Return Receipt Requests, First Class U.S. Mail, to the following: Paul E. Green 175 B 7th Street New Cumberland, PA 17070 Date: ~/ Suza~e SperTcbr Abel 22 East Street, #6 Mt. Holly Springs, PA 17065 (717) 323-0046 spencer abel_esq@fastmail.fm ~` ~ "'__ ~..~ `..~ -C ~. ~~ KRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA on behalf of her minor child, CHRISTOPHER CLARK CIVIL ACTION -LAW PROTECTION FROM ABUSE v. PAUL E. GREEN, Defendant : NO. 1 I bb CIVIL 1994 You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action promptly after this Petition, Order and Notice are served, by appearing personally or by attorney at the hearing scheduled by the Court and presenting to the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the Court may proceed without you and a judgment may be entered against you by the Court, without further notice, for any money claimed in the Petition or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse Carlisle, Pennsylvania 17013 717/240-6200 KRISTY M. GREEN, Plaintiff, on behalf of her minor child, CHRISTOPHER CLARK v. PAUL E. GREEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. t I b b CIVIL 1994 PROTECTION FROM ABUSE 4'.J PETITION FOR 'P~MPORARX PROTECTIVE ORDER The Plaintiff, through her attorneys, the Family Law Clinic, alleges the following: COUNT L PROTECTION FROM ABUSE 1. Plaintiff is an adult individual who is residing at 519 Cherry Court, Cazlisle, Cumberland County, Pennsylvania 17013. Plaintiff brings this action on behalf of her minor child Christopher Clark. 2. Defendant is an adult individual whose legal residence is 519 Cherry Court, Cazlisle, Cumberland County, Pennsylvania 17013. 3. The Defendant is temporarily residing at the home of Charles and Tina Lewis, Hill Street, Mt. Holly Springs. 4. Plaintiff and defendant were married on July 31, 1993. 5. Plaintiff is the mother of Christopher Clark, who is three yeazs old. 6. Defendant is the stepfather of Christopher Clazk. 7. The Defendant has attempted to cause and has intentionally, knowingly, and recklessly caused bodily injury to plainfiffls minor child, Christopher Clark. In addition, plaintiff s minor son has been placed in feaz of imminent bodily injury and/or death. 8. On Monday, February 28, 1994, the defendant struck the plaintiffls son, Christopher on the right side of the temple, causing the child to fall to the floor and sustain a bruise. 9. The defendant has frequently called the plaintiff s child and other children in the household names including but not limited to, "piss cat" and "shit hog". 10. The defendant and plaintiff are the parents of a daughter, I{aylee Green, born on August 22, 1992. 11. In November of 1992, the plaintiff had to call the police because the defendant had punched the plaintiff, locked himself in the house with Kaylee and refused to let the plaintiff in the house. 12. Plaintiff believes and therefore avers that her child Christopher Clark will be in immediate and present danger of serious abuse from defendant and that he is in need of protection from abuse. Wf~REFORE, pursuant to the provisions of the "Protection From Abuse Act" 23 Pa.C.5. §6101 et seq., plaintiff prays this Honorable Court to grant the following relief: A. Grant a Temporary larder pursuant to the "Protection From Abuse Act". 1) Require the defendant to refrain from abusing the plaintiff's minor son, Christopher Clark, either personally or through his agents; and 2) Exclude the defendant from the residence at 519 Cherry Court, Carlisle, Cumberland County, Pennsylvania 17013. B. Schedule a hearing in accordance with the provisions of the "Protection From Abuse Act", and C. After such hearing, enter an order against the defendant, to be in effect for one year, as follows: 1) Directing the defendant to refrain from abusing the plaintiffs minor child Christopher Clark. 2) Prohibiting the defendant from having any contact with the plaintiff s minor child Christopher Clark (except as agreed to by the parties) including, but not limited to restraining the defendant from entering plaintiffs place of residence, and from harassing the plaintiffs minor child. 3) Granting possession to the plaintiff of the residence or household to the exclusion of the defendant by evicting the defendant. COUNT II. IN FORMA PAUPI/'RIS 13. The allegations in paragraphs one through twelve are incorporated herein by reference. 14. Plaintiff does not have funds available to pay the costs of filing and service. WHEREFORE, plaintiff prays that the petition be filed and service shall be made without payment of costs per 23 Pa.C.S. §6106(b). Respectfully subm~it~te~d/,, ~--- Date ~ ~ ~ ~ ~ ~{ ~~,~,_ ~ d,"_"-2S Ann St. Ledger Certified Legal Intern 7^ ¢-. THOMAS M. PLACE LINDA E. FISHER ROBERT E. RAINS Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Cazlisle, PA 17013 717/243-2968 or 717/240-5204 (Voicemail) COMMONWEALTH OF PENNSYLVANIA COiINTY OF CUMBERLAND SS. I verify that the statements made in this Petition are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ' A/_ ~. ^^~I~~c/v `/ sty M~,Green Date ~~9/7 MAR ~ ~ 1994 ~~ KRISTY M. GREEN, Plaintiff on behalf of her minor child, of her minor child, CHRISTOPHER CLARK v. PAUL E. GREEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. ! lob CIVIL 1994 PROTECTION FROM ABUSE TEMPORARY PROTECTIVE ORDER AND NOW, this ~D~day of ~Mvc-~ , 1994 at 9:mBjb1., upon presentation and consideration of the within Petition, and upon finding the plaintiff s child, Christopher Clazk, residing in Cumberland County, Pennsylvania, is in immediate and present danger of abuse from defendant, Paul E. Green, the following Temporary Order is entered. Defendant, Paul E. Green, is hereby enjoined from abusing or harassing plaintiffls child, Christopher Clark, either personally or through his agents. Defendant, Paul E. Green, is hereby order to stay away from petitioner's residence at 519 Cherry Court, Cazlisle, Cumberland County, Pennsylvania. This Order shall remain in effect until pending further Order of the Court. You, Paul E. Green, are ordered to appear in person at the scheduled hearing held on this matter on the J~.~day of Yr7~~, 1994 at ,~:.3pP.M., in Courtroom No. S- Plaintiff may proceed in forma pauperis pending a further order after the hearing. Service of certified copy of the Petition and this Order shall be provided by the sheriff of Cumberland County. The Police Department of Cazlisle will be provided copies of this Order by attorney for plaintiff, and are directed to enforce this Order by arrest for indirect criminal contempt without warrant upon probable cause that this Order has been violated, whether or not the violation is committed in the presence of the police officer, 23 Pa. C.S. §6113. In the event that an arrest is made under this section, the defendant shall not be taken to jail but shall be taken without necessary delay before the Court that issued the Order. By the Court, -~ ,~~ ~,~ KRISTY GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA on behalf of her minor child, CHRISTOPHER CLARK :CIVIL ACTION -LAW PROTECTION FROM ABUSE v. PAUL E. GREEN, Defendant : NO. 1166 OF 1994 ORDER OF COURT AND NOW, this ~~t`'t day of VW y c-~ 1994, the parties having reached an agreement on a disposition of this petition, the court does accept their agreement and orders as follows: 1. Without admitting any of the allegations of the petition, the Defendant agrees that he will not abuse, harass, or have contact with the Plaintiff s minor child: Christopher Clark, personally or through his agents. 2. Defendant shall remove himself from the residence at 519 Cherry Court, Carlisle, PA, and he shall remain away from this residence for one year or until plaintiff and her minor child move out voluntarily, whichever date first occurs, except to see the daughter of the plaintiff and the defendant, or other children in household as agreed by the parties. This order shall remain in effect for one year. The Police Department will be provided with a copy of this order by attorney for the Plaintiff and may enforce this order by arrest for indirect criminal contempt without warrant upon probable cause that this order has been violated, whether or not the violation is committed in the presence of the police officer. In the event that an arrest is made under this secfion, the Defendant shall not be taken to jail, but shall be taken without unnecessary delay before the court that issued the order. When that court is unavailable, the Defendant shall be arraigned before a District 7usflce, who shall set bail according to the provisions of Chapter 4000 of the Pa. Rules of Criminal Procedure. By the Court, ~ ~ ~ J7.~ KRISTY M. GREEN, Plaintiff, On behalf of her minor child, CHRISTOPHER CLARK, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVII. ACTION -LAW PROTECTION FROM ABUSE v. PAUL E. GREEN Defendant NO. 1166 CIVIL 1994 CONSENT AGRF.F.MENT This agreement is entered into this ~rf 4~ay of ~/-,I y ~~ , 1994, between the Plaintiff, Kristy M. Green, through the Family Law Clinic, and Paul E. Green. The parties agree that the following may be entered as an order of court. 1. Without admitting any of the allegations contained in the petition, the Defendant agrees, for the mutual benefit of both parties, not to abuse the Plaintiffls minor child, Christopher Clazk, either personally or through his agents, 2. Defendant agrees not to harass Plaintiff's minor child, either personally or through his agents. 3. Defendant agrees not to enter or come within 100 yazds of the Plaintiffls residence at 519 Cherry Court, Cazlisle, Cumberland County, Pennsylvania, except when the parties have agreed to Defendant's presence on the premises for purposes of seeing the child of the Plaintiff and the Defendant or the Plaintiffls two other children. 4. The Defendant shall have no contact with the Plaintiffls child, Christopher Clazk, except supervised visitation when agreed to by the parties. WHEREFORE, the parties request the court enter an order of court to reflect the above terms, to be in effect for a period of one yeaz from the date of execution of said order. Paul Green Kristy Ivy. GreEn Defendant Plaintiff Date .~/~7~y Ann St. Ledger o - 2f Certified Legal Intern Thomas M. Place Robert E. Rains Linda E. Fisher Harvey A. Feldman Supervising Attorney The Family Law Clinic 45 North Pitt Street Cazlisle, PA 17013 717/240-5204 or 717/243-2968 .----• KRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION-LAW IN CUSTODY PAUL E. GREEN, Defendant : NO.~I~~GCIVIL 1994 ORDER OF COURT AND NOW, this ~`6~d y of ~f~~ 1994, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appeaz before, roy"fs+. ~~-~hc/'~~. ~~ ~~, the conciliator, at ~"}h ~~°~ ,Cumberland County Courthouse, c?'q t h/I iv~~ ~:',~ on the ~°'day of ti~ , 1994, at m., for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, Custody Conciliat _.~~~' YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4th Floor CARLISLE, pA 17013 717x240-6200 ~, Ptkt'+iT.tSbN ~t1Mgv0 QN7~u38H d9i'2vMOHlCi~,f :~r,O0 3~~d.it._ '; dp h6. Nd oe ~ Il arp COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. I verify that the statements made in this Custody Complaint aze true and correct to the best of my personal ]mowledge and belief. I understand that false statements herein aze made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ~~~ ~~'~~ sty M~reen Date_ ~~(!~/QY KRISTY M. GREEN, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. I! toLQ NO. CIVIL 1994 PAUL E. GREEN, :CUSTODY Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Fourth Floor Carlisle, Pennsylvania 17013 (717)240-6200 KRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN CUSTODY PAUL E. GREEN, ~ ~ C¢CQ Defendant : NO. CIVIL. 1994 COMPLAINT FOR CUSTODY AND NOW, the Plaintiff, by her attorneys, the Family Law Clinic, sets forth the following cause of action: 1. The Plaintiff is Kristy M. Green, residing at 519 Cherry Court, Cazlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Paul E. Green, whose legal residence is at 519 Cherry Court, Cazlisle, but presently the defendant is staying at: 37 Big Spring Terrace, Newville, Cumberland County, Pennsylvania, 17241, the residence of Michael and Gail Mazol. 3. The Plaintiff seeks custody of the following child: Name ~~ ~ D•O•B• Kaylee N. Green 519 Cherry Court Cazlisle, PA 17013 4. The child was born out of wedlock. 18 months 8/22/92 5. The child is presently in the custody of Kristy M. Green, who resides at 519 Cherry Court, Carlisle, Cumberland County, Pennsylvania 17013. 6. During the past five yeazs, the child has resided with the following persons and at the following addresses: Address ~~ Kristy M. Green 519 Cherry Court 6/93-present Paul E. Green Cazlisle, PA 17013 Shayne Clark Christopher Clazk ]Cristy M. Green 273 B East Pomfret Street Birth-6/93 Paul E. Green Carlisle, PA 17013 Shayne Clazk Christopher Clark 7. The mother of the child is I{risty M. Green, currently residing at 519 Cherry Court, Cazlisle, Cumberland County, Pennsylvania 17013. She is marred. 8. The father of the child is Paul E. Green, whose legal residence is 519 Cherry Court, Cazlisle, Cumberland County, Pennsylvania; however, he is presently residing at the following address: 37 Big Spring Terrace, Newville, Cumberland County, Pennsylvania 17241. He is married. 9. The relationship of the Defendant to the child is that of father. The defendant resides with the following persons: Name Relationship Michael, Gail and Jayce Marol friends 10. The relationship of plaintiff to the child is that of mother. The plaintiff currently resides with the following persons: Name Shayne Christopher ICaylee ~telationship Son Son Daughter 11. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 12. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 13. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 14. The best interest and permanent welfare of the child will be served by granting the relief requested because: a) Plaintiff has been primary caretaker of the child since birth; b) Plaintiff provides the child with a home with adequate moral, emotional and physical surroundings as required to meet the child's needs; c) Plaintiff is willing to accept custody of the child; d) Plaintiff continues to exercise pazental dudes and enjoys the love and affection of the child; 15. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, the Plaintiff requests the court to grant custody of the child. Date 3~ I5~ 11 y ~,,,,., v~ oCg-ck~.~ Ann St, Ledger Certified Legal Intern L~ -c~-e, ~ ~s~Cl~ THOMAS M. PLACE ROBERT E. RAINS LINDA E. FISHER Supervising Attorney FAMII.Y LAW CLINIC 45 North Pitt Street Cazlisle, PA 17013 717/240-5204 MAR 1 ~ 1994..`_ KRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS Plaintiff, : OF CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION-LAW CUSTODY PAUL E. GREEN, Defendant : NO. ~ ~ [C OF 1994 TEMPORARY ORAER OF COURT AND NOW, this ~ 7~day of March, 1994, upon consideration of the Temporary Custody Agreement entered into by the parties, the court orders as follows: 1. The Plaintiff and the Defendant shall have shared legal custody of their daughter, .:> Kaylee Green. 3.: ~, The Plaintiff shall have primary physical custody of Kaylee Green. s 3. The Defendant shall have partial physical custody of Kaylee Green. 4. The Defendant shall have physical custody of Kaylee Green at times to be agreed upon by the parties. 5. Kaylee shall not be removed from the commonwealth of Pennsylvania, absent consent from the Plaintiff. 6. The Defendant will refrain from the consumption of alcohol while Kaylee is in his custody. ~~ Q ~ Vol. !ii/ C T ~ O 90 mt=_, =mrn ~_ OD Y~cr. N r T r x* ~K z •r c CL! ~~~T N s'n¢~ W ~x rn~p `~ t0 (? > MAR ?~: ^ 1994..., KRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS Plaintiff, : OF CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVII, ACTION-LAW CUSTODY PAUL E. GREEN, Defendant : NO. ' ~OF 1994 TEMPORARY CUSTODY AGREEMENT RE: KAYLEE GREEN ,f" ~ This agreement is entered into this ~ ~ day of ~~"'` , 1994, between the Plaintiff, Kristy M. Green, through her attorneys, the Family Law Clinic, and the Defendant, Paul E. Green. The parties agree that the following may be entered as a court order to be in effect until further order of this court: 1. The Plaintiff and the Defendant shall have shared legal custody of their daughter, Kaylee Green. 2. The Plaintiff shall have primary physical custody of Kaylee Green. 3. The Defendant shall have partial physical custody of Kaylee Green. 4. The Defendant shall have physical custody of Kaylee Green at times to be agreed upon by the parties. 5. Kaylee shall not be removed from the commonwealth of Pennsylvania, absent consent from the Plaintiff. 6. The Defendant will refrain from the consumption of alcohol while ICaylee is in his custody. /, Dated: , ~~ -]~q ~~ Signed: ~/U ~~,1//- ;U'LG:C~J Kris M. Gy~een ,~ /~ „~c>.~~ aul E. Green ~,~- ~ ~; Ann St. Ledger Certified Legal Intern ~. Thomas M. Place Robert E. Rains Linda E. Fisher Harvey A. Feldman Supervising Attorney The Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 717/240-5204 or 717/243-2968 SI-IERIFF'S RETURN CG.~iONWEAI,TH OF PENNSYLVANIA: COUNTY OF CUMBERLAND Kristy M. Green, on behalf of her minor child, Christopher Clark VS Paul E. Green Robert L.. Fink In The Court of Common Pleas of Cumberland County, Pennsylvania No. 1166 Civil Term 1994 Temporary Protective Order Protection From Abuse and Notice Petition for Temporary Protective Order ~HI&L@C~f}fX~r Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn accoxrling to law, says, Temporary Protective Order Protection From Abuse that he served the within and Notice Petition for Temporary Protective Order upon Paul E. Green P .M. EST / S~ on the 10 the defendant, at 2:45 o'clock day of March 19 94it 37 Big Spring Terrace, Newville Ctunberland County, Pennsylvania, by handing to Paul Green Temporary Protective Order Protection From Abusi a true and attested copy of the Notice, Petition for Temporary Protective, Order and at the same time directing his the "Notice to Plead" endorsed thereon. Sheriff's Costs: Docketing Service Affidavit Surcharge attention to the contents thereof and So answers: 14.00 ~~ ~~~ 7.28 X~ 2.00 23.28 Sworn and subscribed to before me this /S~ day of `71i~,c.~/ 19 Rn'/~ A.D. ~~ Q. Prothonotary h~"eu., A R. Thomas Kline, Sheriff by ~~~'%x1%~~ Deputy Sheriff I<RISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW : IN CUSTODX PAUL E. GREEN, Defendant NO. 1166 CIVIL 1994 ORDER OF COURT AND NOW, 5 ~~5 1999, upon consideration of the attached petition i is hereby directed that the pazties and their respective counsel appeaz before ~~ l(. ~~~ ~ f d` 7 ~~ ,the conciliator, at ~nr ~"~" (~ ~ . ~ ~ ~P~ ~, C~ur~YTCC~ CO . ('c,X~S on the .~ day of M(1\~ ,1999, at ~~ ~, 30 q m.> for a Pre•Hearing Custody Conference. At such conferen e, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appeaz at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: Cu~ y Conciliator ~-n~~ ~~ , ll 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 accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please rnntact our office. All azrangements must be made at least 72 hours prior to any heazing or business before the court. You must attend the scheduled conference or heazing. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 cc: ~~ ~ ~ ~`"~ dd6~~' r -, ;, ,, -;~, ;z t ~ ..;'~ ~~ ~ ~-'r' ~~lC~^,J~~~i,t Jl.% KRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN CUSTODY PAUL E. GREEN, Defendant : NO. 1166 CIVIL 1994 ORDER OF COURT You, I<risty M. Green, respondent, have been sued in court to enforce the Custody Order of the child: I<aylee Green. You are ordered to appear in person at on , at ,o'clock, M., for ^ a conciliation or mediation conference. ^ a pretrial conference. ^ a hearing before the court. If you fail to appear as provided by this order, an order for custody, partial custody or visitation may be entered against you or the court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 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 accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. BY THE COURT: Date: J• KRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN CUSTODY PAUL E. GREEN, Defendant : NO. 1166 CIVIL 1994 PETITION TO ENFORCE CUSTODY ORDER 1. Petitioner, Paul E. Green, By and through his attorney, Lindsay Dare Baird, Esquire, respectfully represents that on the 5th day of September, 1997, an Order of Court was entered for Custody of the minor child, ICaylee Green, date of birth August 22, 1992. A true and correct copy of said Order is attached as Exhibit "A". 2. This Order should be enforced because Respondent, ICristy M. Green, natural mother of the child, has refused for the past year to allow visitation between Petitioner and the child. It is requested that visitation be enforced. 3. Respondent has refused to send Petitioner any school records and photographs of the child although directed to do so in the Order. 4. Respondent has moved and left no forwarding address or phone number with Petitioner rendering the Ordered telephone contact with his child impossible. 5. Petitioner may only place collect phone calls as outlined in the PA Department of Corrections Telephone Procedures, attached as Exhibit "B". Respondent will have to accept the calls to enable Petitioner to maintain Ordered telephone contact with his child. Petitioner agrees to pay a percentage of the cost. WHEREFORE, Petitioner respectfully requests that the Court enforce the existing Order for Custody because it will be in the best interest of the minor child. Respe ally submitted, Lindsay Dare Baird, Esquire Attorney for Petitioner 37 South Hanover Street Carlisle, PA 17013 KRISTY M. GREEN, Plaintiff v. PAUL E. GREEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY No. 1166 CIVIL 1994 ORDER OF COURT AND NOW, this 5th day of September, 1997, upon consideration of the issue of custody of the parties' child, Kaylee N. Green (date of birth, August 22, 1992), and pursuant to an agreement reached in open court among the parties and their counsel, William C. Vohs, Esquire, on behalf of Kristy M. Green, and Lindsay Dare Baird, Esquire, on behalf of Paul E. Green, it is ORDERED and DIRECTED as follows: 1. The temporary Order of Court dated March 17, 1994, is vacated. 2. The Plaintiff and the Defendant shall share legal custody of their minor child, Kaylee Green. 3. The Plaintiff shall have primary physical custody of the minor child, Kaylee Green. 4. The Defendant shall have visitation at any state correctional institution or prison or county prison that he is incarcerated every other Saturday, during normal visiting hours at that institution, but not longer than between 10:00 a.m. to 8:00 p.m. The Defendant is responsible far arranging transportation of the minor child for these visitations. The EXHIBIT "A" Defendant's family, specifically David or Margaret Handshew, may be utilized to transport Kaylee, so long as Kaylee is secured in a rear seat in a seat belt for the round trip to the institution. Any other contact by the Defendant or Defendant's family with Plaintiff other than related to the minor child is prohibited. 5. The minor child, Kaylee Green, shall not be removed from the Commonwealth of Pennsylvania without consent of the Plaintiff. 6. The Defendant may contact the minor child, Kaylee Green, by telephone one time per week between 7:00 p.m. and 8:30 p.m. on any night that is mutually agreeable by the parties. However, Defendant is enjoined from discussing any issues with the minor child, Kaylee Green, that do not relate directly with the minor child. The Defendant is not to call the minor child or the Plaintiff collect. He may, however, place third party calls to the minor child for these telephone contacts, and Plaintiff will use her best efforts to aid in the placement of such third party calls. 7. Plaintiff will use her best efforts to provide Defendant with school records and photographs of the minor child, Kaylee Green. In Tent a.r ny hagd and 9h~ ~~ i.^ Pa. This .... L.gc'tY'' c6;~ ;;~ _.~t~~::.., 19.~.-~ •Proiho„o By the Court, LUG ~o J Nesley O1e~~ Jr., ~ ' V WILLIAM C. VOHS, ESQUIRE For the Plaintiff LINDSAY DARE BAIRD, ESQUIRE For the Defendant wcy - COMMONWEALTH OF PENNSYLVANIA. ' DEPARTMENT OF CORRECTIONS INMATE TELEPHONE PROCEDURES REMOVE HEADSET AND LISTEN FOR DIAL TONE 2. FOR ALL CALLS DIAL YOUR PIN NUMBER, THEN DIAL "0", THE AREA CODE, AND THEN THE NUMBER YOU WISH TO CALL. 3. IF THE PHONE NUMBER DIALED IS PERMITTED, BASED ON THE PREPROGRAMMED PARAMETERS, THE CALL WILL COMPLETE. 4. IF THE NUMBER DIALED IS NOT ALLOWED, YOU WILL HEAR A MESSAGE THAT SAYS "YOUR CALL CANNOT BE COMPLETED AS DIALED." 5. THE PARTY WILL NOW HEAR THE NORMAL "RINGING" OF THE CALLED PARTY'S PHONE. 6. WHEN THE CALLED PARTY ANSWERS THE PHONE THEY WILL HEAR THE MESSAGE "YOU HAVE A COLLECT CALL FROM INMATE JOHN DOE AT A COMMONWEALTH OF PENNSYLVANIA STATE CORRECTIONAL FACILITY. TO REFUSE THIS CALL HANG-UP. IF YOU ACCEPT THIS CALL DO NOT USE~CACL WAITING OR THREE WAI~'CALLING FEATURES,OR YOU IML CBE biSCONNECTEDs ALL CONVERSATION AND CALL DETAIL EXCEPT APPROVED ATTORNEY CALLS, MAY BE MONITORED AND/OR RECORDED. TO ACCEPT THIS CALL DIAL 1 NOW." 7. THE CALLED PARTY MAY ACCEPT THE CALL WITH EITHER A TOUCH TONE OR A ROTARY PHONE. WHEN THE CALL IS ACCEPTED, THE CALLED PARTY WILL HEAR THE MESSAGE "THANK YOU." 8. EITHER PARTY MAY END THE CALL BY HANGING UP. 9. IRTHIC,ALLED PARTY ATTEMPTS A THREE WAY CALL, AT ANY TIME; THE PHONE CONT„~2O,LLER WILL TERMINATE THE CALL~IF THE CALLED" PARTY ATTEMPTS TO RECEIVE A CALL USING CALL WAITIN ~~ ;~11VIL~FraM1~iI~T.~,, 10. ACCESS TO VARIOUS NUMBERS INCLUDING THE OPERATOR, 800, 900, 976, 411, 611, 911, AND 555-1212 ARE BLOCKED FROM THE INMATE TELEPHONES. 11. ALL RATES CHARGED ARE FIXED BY THE PENNSYLVANIA BOARD OF PUBLIC UTILITIES FOR COLLECT CALLS. F~3IBIT "B" v v- ii4 ~ I verify that to the best of my knowledge and belief, the statements made in the foregoing document are true. and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.§4904 relating to unsworn falsification to authorities. ~~ ~ i ~ ~. Paul E. Green c ,o ~~ ~ - ,~~- ~ %~ C C ~' M1j P ~ c ~ `~ ~~ w +N ti 1,~) a ~ KRISTY M. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW IN CUSTODY PAUL E. GREEN, Defendant NO. 1166 CIVIL TERM 1994 PETITION FOR MODIFICATION OF VISTTATION ORDER PURSUANT TO PA. R. CIV. P. 1915.15(b) The Plaintiff, by her attorneys, the Family Law Clinic, respectfully represents that: 1. The parties are the parents of Kaylee Green, who was born on August 22, 1992. 2. On September 5, 1997 an Order of Court, a true and correct copy of which is attached, was entered granting Paul Green, the defendant/father, visitation rights regarding their daughter, Kaylee Green. 3. This Order should be modified because there has been a substantial change in circumstances and visitation between Kaylee and her incarcerated father is not in her best interests. 4. At the time Order was entered, Paul Green was incarcerated at the Mahoney State Correctional Institute. 5. On information and belief, the father was transferred from the Mahoney facility to the State Correctional Institution at Waymart because of his inability to get along with the other inmates and because of his proclivity to violence. 6. Kaylee currently resides with her mother in Shippensburg, PA. 7. Waymart is approximately a 360 mile round trip drive from Kaylee's residence, nearly double the distance from her residence to Mahoney. 8. The existing custody order provides that two members of the father's family, David and Margaret Handshew, were to be used to transport Kaylee to and from these visitations with the father. 9. On information and belief, on one occasion, the Handshews picked up Kaylee ostensibly to transport her to see the father, but they did not do so. 10. The father was denied parole in January 1999. 11. Mandatory authority provides that there is a presumption that visitation of an incarcerated parent by his/her child is not in the best interests of that child and that the incarcerated parent has the burden of proving otherwise. See Etter v. Rose, 454 Pa. Super. 138, 141, 684 A.2d 1092, 1093 (1996). 12. Under Pennsylvania statutory law, before making an order granting custody, partial custody or visitation to a parent who has been convicted of any of the criminal acts listed in the statute, the court is required to consider the criminal conduct and is also required to make a determination "that the parent does not pose a threat of harm to the child." See 23 Pa.C.S. § 5303. In meeting this obligation, the court is also required, per 23 Pa.C.S. § 5303(c) "to appoint a qualified professional to provide counseling to an offending parent" that "shall include a program of treatment or individual therapy." Additionally, the court is required to take testimony from that counselor "prior to issuing any order of custody, partial custody or visitation. " 13. Under 23 Pa.C.S. § 5303, "a parent [that] has been convicted of or has pleaded guilty or no contest to" the crime of sexual assault (18 Pa.C.S. § 3124.1) is subject to the mandatory review and counseling requirements that are described in the prior paragraph. 14. On April 4, 1996, Paul Green, pleaded polo contendere in this court to the crime of sexual assault (18 Pa.C.S. § 2124.1) and was consequently sentenced by this court to a sentence of "not less than 39 months, nor more than 7 years." See Commw. v. Green, 95-1105 (1996) (attached). 15. The provisions of 23 Pa.C.S. § 5303, have not been carried out and constitute a condition precedent to further visitation by the father. 16. The father is currently incarcerated as a result of his holding the mother and their child in the family trailer against their will while threatening to kill them. 17. Because of past criminal acts directed against the mother, and because of threats made againt the child, Paul Green continues to pose a threat to the mother and her child. WHEREFORE, Ms. Green asks that the Court suspend the existing visitation order, prohibit Paul Green from talking with Kaylee by the phone, and direct that Ms. Green's only obligation be to provide Paul Green with a school photograph and report cards for Kaylee with the school and teachers' names redacted. It is further requested that this petition be heard simultaneously with Paul Green's Petition to Enforce Custody Order that is already scheduled for aPre-Hearing Custody Conference before Mr. Hubert X. Gilroy, Esq., scheduled for 10:30 A.M. on May 7, 1999. q~~r~/Lft,'/ ~~v V -' Ma ew Kloiber Certifidd Legal Intern ROBERT E. RAINS Supervising Attorney DONALD MARRITZ Staff Attorney FAMILY LAW CLINIC 45 N. Pitt. St. Carlisle, PA 17013 717 243-2968 VERIFICATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date ~~ ~ J ~ ` -l / ~ ~ ~~~~~. sty M~reen ,- ~.. ~. . KRISTY M. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN CUSTODY PAUL E. GREEN, Defendant No. 1166 CIVIL 1994 ORDER OF COURT AND NOW, this 5th day of September, 1997, upon consideration of the issue of custody of the parties' child, Kaylee N. Green (date of birth, August 22, 1992), and pursuant to an agreement reached in open court among the parties and their counsel, William C. Vohs, Esquire, on behalf of Kristy M. Green, and Lindsay Dare Baird, Esquire, on behalf of Paul E. Green, it is ORDERED and DIRECTED as follows: 1. The temporary Order of Court dated March 17, 1994, is vacated. ~ 2. The Plaintiff and the Defendant shall share legal custody of their minor child, Kaylee Green.. 3. The Plaintiff shall have primary physical custody of the minor child, Kaylee Green. 4. The Defendant shall have visitation at any state correctional institution or prison or county prison that he is incarcerated every other Saturday, during normal visiting hours at that institution, but not longer than between 10:00 a.m. to 8:00 p.m. The Defendant is responsible for arranging transportation of the minor child for these visitations. The Defendant's family, specifically David or Margaret Handshew, may be utilized to transport Kaylee, so long as Kaylee is secured in a rear seat in a seat belt for the round trip to the institution. Any other contact by the Defendant or Defendant's family with Plaintiff other than related to the minor child is prohibited. _ 5. The minor child, Kaylee Green, shall not be removed from the Commonwealth of Pennsylvania without consent of the Plaintiff. 6. The Defendant may contact the minor child, Kaylee Green, by telephone one time per week between 7:00 p.m. and 8:30 p.m. on any night that is mutually agreeable by the parties. However, Defendant is enjoined from discussing any issues with the minor child, Kaylee Green, that do not relate directly with the minor child. The Defendant is not to call the minor child or the Plaintiff collect. He may, however, place third party calls to the minor child for these telephone contacts, and Plaintiff will use her best efforts to aid in the placement of such third party calls. 7. Plaintiff will use her best efforts to provide Defendant with school records and photographs of the minor child, Kaylee Green. ~n .. T.= i1217d t _, a. .. 9 fix. ~~f ,, ~ s. `~.?. n,., _ J ..........,...~i-.~a~s....~~..~.... -~cw.s.~ ~, ~~~• Proinonotary . By the Court, ~~ ~~ J Plesley O1 Jr.~ ' WILLIAM C. VOHS, ESQUIRE For the Plaintiff LINDSAY DARE BAIRD, ESQUIRE For the Defendant wcy ~l-~-q5 COMMONWEALTH V. PAUL EIIGENE GREEN OTN: E003970-1 E726578-6 E230426-0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA _ 94-2000 CRIMINAL TERM AFFIANT: PTL. JOHN SANCENITO 95-1105 CRIMINAL TERM CHARGE: (F) SEXIIAL ASSAIILT AFFIANT: TPR. LEONARD LANDER 95-0296 CRIMINAL TERM CHARGE: (E) SPOIISAL SEXIIAL ASSAIILT AFFIANT: CHIEF DUANE LEBO IN RE: NOLO CONTENDERE PLEAS & SENTENCING ORDER OF COIIRT AND NOW, this 4th day of April, 1996, the Defendant, Paul Eugene Green, appeared in court today represented by Samuel W. Milkes, Esquire, Assistant Public Defender. Pleas are accepted as follows: _ a ~- c To 95-1105, the Court accepts a plea of Ti'o;1o ~' c~T O contendere to a charge of Sexual Assault, Count F, a vioiatio~i~ ~n m of 18 PS 3124.1 as provided by the Act 10 approved March 31st 1995, to be effective 60 days after March 31st, 1995.,-, To 95-0296, Count E, the Court accepts a plea of nolo contendere to the charge of Spousal Sexual Assault. The pleas of nolo contendere to these two charges are aow accepted by the Commonwealth in full satisfaction of all outstanding charges presently pending against Mr. Green in this County. At the time that the pleas of nolo contendere were accepted, the District Attorney related to the Court that a plea agreement had been entered into concerning the sentence on these two changes. I have heard the agreement. I will accept the agreement, and impose sentence as follows: To 95-0296, Count E, sentence of the Court is the Defendant pay the costs of prosecution, undergo imprisonment in a State Institution for not less than 39 months nor more than 7 years. Sentence to date from September lat, 1995, and run concurrent with any other sentence the Defendant is presently undergoing. To 95-1105, Count F, sentence of the Court is the Defendant pay the costs of prosecution, undergo imprisonment in a State Institution for not less than 39 months, nor more than 7 years. Sentence to date from September 1st, 1995, and run concurrent with any other sentence the Defendant has been presently directed to serve. The Court further directs that the Defendant not be transported to a State Institution until such time as the District Attorney's office informs the Court that they are recommending a transfer at that time. I would direct that this sentence order be transcribed, along with the colloquy that took place prior to the sentence being imposed. By the Court, L~~ f ~ Harold E. She P.J. Y• Travis N. Assistant Samuel W. Assistant Probation SCIC CCP Gery, Esquire District Attorney Milkes, Esquire Public Defender :mal KRISTY M. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW IN CUSTODY PAUL E. GREEN, Defendant NO. 1166 CIVIL TERM 1994 CERTIFICATE OF SERVICE I, Matthew Kloiber, Certified Legal Intern, Family Law Clinic, hereby certify that on Friday, April 30, 1999, I served the Defendant with a true and correct copy of the Plaintiff's Petition for Modification of Visitation Order, by hand delivering the said document to the office of Defendants's Counsel, Lindsay Dare Baird, located at 37 South Hanover Street, Carlisle, Pemmsylvania, 17013-3307. Mat ew ffioiber Certified Legal Intern Dated: April 30, 1999 ~~ ~n O __ -» --~ i J E _ ~~ tPj o c:J = L =j V - - •r ",~-.-~ ' J `` - rn fJ ~ ~ ` ~_~ ~a JJ -< f1~AY ~ 7999j ICRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN CUSTODY PAUL E. GREEN, Defendant NO. 1166 CIVIL 1994 ORDER OF COURT AND NOW, ~ ~ 3 1999, upon consideration of the attached petition, it is hereby directed that the pazties and their respective counsel appeaz before ~~f ~ X• ~'~\\fCT"~ ~ ESC. ,the conciliator, at '~hc_4{'^~1 ~~.IY`~-tktlc~ C'd. ~I'~ r~-k1nCu5C. on the ~_ day of ~ ,1999, at 10-_ SO q,m., for a Pre•Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and nazrow the issues to be heard by the court, and to enter into a temporazy order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, Bye ~~~~ ~~ Custody Conciliator , C ~ 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 accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All azrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or heazing. YOU SHOULD TRICE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIIVD OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 cc: ("r~° ~ ~ ~ ~~ ~''° 66,5 ,S' vir~dm~sNN~d ~ G ~Cyl >!':' ~~- ANN 66 ~~~~ ~G-~~lld KRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS Plaintiff, : OF CUMBERLAND COUNTY, :PENNSYLVANIA CIVIL ACTION-LAW v. : IN CUSTODY PAUL E. GREEN, Defendant : NO. 1166 CIVIL 1994 ACCEPTANCE OF SERVICE I accept service of the attached Custody Agreement and Temporary Order of Court, on this k' ~.' ~~- day of March, 1994. .~ ~ ,-: ~/. ~J; Paul E. Green 93 Big Spring Terrace Newville, PA 17241 ~~ ~ L' T m '{ N zrne',, z T'` rZ"T ,_ox ~i Y't~~ ~~ CERTIFICATION OF BAIL OTN AND DISCHARGE COMMONWEALTH VS. (Delentlant Name and Adtlress) Paul E, Green Big Spring Terrace, Lot #97 Newville, Pa. 17241 ~f ROR (no surety) [] Nominal Bail ^ Bail (total amount set, if any) $ ^ Conditions of Release (aside from appearing at court when required:) POLICE CASE NO. OJ. NO. G.P. TERM 8 NO. GHARGE(Sy Contempt (Violation of Protection Fran Abuse Order) 1166 Civil 1994 DATE OF CHARGE(S) NEXT COURT ACTION PATE AND TIME LOCATION 4/13/94- 8:00 A.M. Courtroom No. 2 TO: ^ Detention Center Cu[nborl~o d rCounty COUrthou: I hereby certify that sufficient bail has been entered ^ By the defendant ^ On behalf of the defendant by: SECURITY OR SURETV (IF ANV) ^ Cash in full amount of bail ^ Percentage cash bail ^ Money furnished by ^ Defendant ^ 3rd Party JUDGE OR ISSUING AUTHORITY Hon. J. Wesley Oler, Jr. (attach addendum, if necessary) (Name & Atldress o/ Surety) (License No.) • Refund of cash bail will be made within 20 days after final disposition. (Pa.R.Cr.P.4015(b) ) • Refund of all other types of bail will be made promptly after 20 days following final disposition. (Pa.R.Cr.P.4015(a) ) • Bring Cash Bail Receipt to Clerk of Court. DISCHARGE THE ABOVE~NAMED DEFENDANT FflOM CUSTODY IF APPEARANCE OR BAIL BOND DETAINED FOR NO OTHER CAUSE THAN THE ABOVE STATED. THIS BOND IS VALID FOR THE ENTIRE PROCEEDINGS AND UNTIL Given under my hand and the Official Seal of this Court. FULL AND FINAL DISPOSITION OF THE CASE INCLUDING FINAL DISPOSITION OF ANV PETITION FOR WRIT OF CERTIORARI OR this 11th day of_ Apri 1 , 1994_. APPEAL TIMELY FILED IN THE SUPREME COURT OF THE UNITED /~ /~ STATES. t /~, - l+t,• ~I'L.c.fZQ'['`" ~ Q~'j . (SEAL) (/ y Icrek or coed er Issemy AGmon~j 7~ty ProthOriOtary WE, THE UNDERSIGNED, defendant and surety, our successors, heirs and assigns, are jointly and severally bound to pay to the Commonwealth of Pennsylvania the sum of dollars ($ ). SEE REVERSE SIDE FOR BAIL CONDITIONS TO BE USED ONLY FOR PERCENTAGE CASH BAIL: The undersigned about to become Surety in the case cited herein, being duly sworn (or affirmed), deposes and says: 1. I reside at and my occupation is 2. I have no undisposed of criminal cases against me pending in the Courts of the aforesaid County, except as follows: and I work for my phone number is 3. I am not Surety on any bond of any kind except as follows: DATE AMOUNT DEFENDANT 4. I have carefully reatl the foregoing affidavit and know it is true and correct. I ACKNOWLEDGE THAT I AM LEGALLY RESPONSIBLE FOR THE FULL AMOU T~E BPAA~L. The /ollowing acknowledgement is also applicable /~`~/J/'c if Percentage Cash Bail is used. ~ /.! - IGNA RE OF DEFENDANT `~ THIS BOND SIGNED ON April 11 19_2 at. CaTI iGIP PENNSYLVANIA. Signature of Surety (May be Bondsman, Bail Agency, a private Signed and acknowledged before me this individual a organization). Exoept when defendant is released on his 11th day of April , 1g~L)~ own recognizance (ROR), this must be signed in all bail situations, /~ including nominal bars ~ 7 (CMk o/ Court or Issuing Aufho~'ty) / / nOta~ ADDRESS OF SURETV, SURETV COM6ANV OR DEFENDANT (SEAL (SEAL Suety No. w Professional e0nd3men Lk;er~,ve No. 8 EYPirarion Dete AOPG 413-82 DRIGMd4L BAIL CONDITIONS The CONDITIONS of this bond are that the defendant wi!I: (1) Appear before the is5uirg authority and in the Courts et the Goumy M Rennsylvana at all Nn~ 3s hie p~en~ may be required, Ordered or directed, unfit full arld Ilnal dspodtlon cf hie cae=. b Glead b answer and defend as ordered the aforesaid charge or cf - ~ges. (2) Submit hin'self to all orders and process:, of the ~~umg aulho'h, or Gcurt. (3) The UE`ENC::NT end SURETY must give written nonce to the issuing authority, C:erk of Courts, the Disirst Attorney AND Court Bail Agowy, of any Ghan in hie etklress within lorry-eight hours of the date of his change of address. (4) Comply with any speci/ic requirement of release imposed by the issuing authority or Court, such as a satisfactory participatbn in a designated program. (5) Neither do, nor cause to be done, nor permit to he done en h5 nr her hehaH, any act proscribed by Crimes Code section 4952 (relating to mlimidation of witnesses yr victims) or section 4953 4relating to r¢taliation against witnesses or victims) (18 Pa. C.S. §§ 4952.4953). (6) Obey such other contlhions as the Court, or Eourt Bail Agency with leave of IsBUing authority or Court, may irrpOaB. f defendant pertcros the conditions as 5ei forth I>tvsin, than this bond is to be void, cdhsrwLr tho scan ~i:_ II remain in full brce and this band in the tc0 sum theracf shall be lorieited P.nd further, in Occo=etance with law, We W hereby empower 9ny attorney Ot any court of ^ctMn th nomaeaRh of Pennsyvania or elsawherr~ 20 appear for us al any fime, + .;"ate ~ led, arxl n~nsthe• or not r _ .~ obllaaaen bo m default, brr 1: ~ ~: as. ' i l in (avof or the Comm.:,xrealth of Pennsylvania far use t `S ~ assgns as of ar y c~ sass n of muri or rtn:oN of r '1 .^- ~ ~ ab a sum .rxl cost s _ cA errors, without stay ~~ r, a~zt ~~ extension upon o, k ~ ~r real estate le hereby waived, xnno' J '. ~d the exempton of a ~r~~ tat pfcperiy tram levy and sale c y . ,. u,eil rn s also hereby ozpressly Lac ;:'.d ~c haneR of exemption is rl ie ,dnr a C el;tua of s..-ry examptbn law no,+ in tome c which rnfly be passed heieafle: ~ ".rid fi, - , doing ;his shall be sufficiem voarmnt A tropy o. ihs bond and warrant L c f ~ J in asid rr „n, a shall not be necessary ro file the cdginal as a warrant o/ Bltorney, any la:: or, ule of Inc Court .r the contrary, not withstanding. KRISTY M. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW INDIRECT CRIMINAL CONTEMPT PAUL E. GREEN, Defendant 94-1166 CIVIL TERM IN RE: BAIL SET AND TRIAL SCHEDULED ORDER OF COURT AND NOW, this 11th day of April, 1994, upon consideration of the indirect criminal contempt complaint filed in the above-captioned matter, and the Defendant, Paul E. Green, now appearing in court with the Public Defender, Timothy L. Clawges, Esquire, and it having been requested that bail be set pending a trial to be held on Wednesday, April 13, 1994, and the Commonwealth in the person of Will Gabig, Esquire, having indicated no objection to the Defendant's release on his own recognizance, the Defendant is ordered to be released on his own recognizance on this charge, conditioned upon his executing the necessary bail documents and being and remaining on good behavior. Trial is scheduled for Wednesday, April 13, 1994, at 8:00 a.m. in Courtroom No. 2, Cumberland County Courthouse, Carlisle, Pennsylvania, at which time the Defendant is directed to appear without further Order of Court. By the Court, ,, ~ ~~ ~~ a~~~ ~ ~,~/ J. Wesle Ole fir. 3Y V Y A1K~~,~;~ ~ h..~~.k ~A. 3~t~il - -" .~u Ib~ Nd so ~ ~ I adp >~~,° icy ~'/~3/9y WILLIAM I. GABIG, ESQUIRE"'- ~ ~"'~`Y Sr. Assistant District Attorney TIMOTHY L. CLAWGES, ESQUIRE-,~/~, ~~/_~ ~ `f~~3~9~ Assistant Public Defender CCP wcy ~Rt:~INAL COMPLAIN ~ (POLICE) DISTRICT JUSTICE MAGISTERIAL DISTRICT NO. CLAg7T ~, ; ~~Ta, ,i,,,,,,~„~xaOMhi~ ^ ~' Complaint Numbers if Other Participants A 95922 ~~ i'"°. (°''" 94-o4s~o f.~~ y 4 - ~ r ~ ra Cti,:~2 ~~.. COMMONWEALTH OF PENNSYLVANIA DEFENDANT: VS. NAME r I?87.1Z E. Green I Patrolman Kenneth E. Gossert #10 AND ~ ~gsg (Name ojA~anr) ADDRESS ~ ' of CArlisle Police Department (Identify department or agenc9~represemed ar~d political subdivision) R.S.A. wktl~ulgl.~/y~1~.,(y*, AKA do hereby state: (1) ~ I accuse the above named defendant, who lives at the address set forth above or, ^ 1 accuse an individual whose name is unknown to me but who is described as 0 a c ^ his nickname or popular designation is unknown to me and, therefore, I have designated him herein as John o Doe; with violating the penal laws of the Commonwealth of Pennsylvania at 519 Cherry Court Carlisle, Pa. c (Place-Politico! Subdivision) in Ctmtberland County on or about 2110 hours April 8,1994 V PalticlpantS Were (if there were participants,place their names here, repeating the name of above defendant): Paul E. Green (2) The acts committed by the accused were: ~ INDIRECT CRIMINAL CONI'FINPT. The defendant violated the Order issued under the Protection From Abuse Act in No. 1166 Civil 1994 on 17th day of March 1994,by the Honorable ).Wesley Oler Jr.,which Order directeddefendANt not to: come within 100 yards of residence of Kristy M. Green at 519 Cherry Court except where a prior agreement had been made, in that the defendant did come to the residence at 519 Cherry Court,Carlisle,Pa. and did beat on the door and did want admitted to the residence without prior agreement. PROBABLE GSUSE: On April 8,1994 Paul E. Green went to the residence of Kristy Green, 519 Gherry Court Carlisle,PA. at apporximately 2110 hours and did beat on the door acid did want to enter the residence without prior agreement from Kristy Green. This is in violation of PFA Order 1166 of 1994 issued by Judge J. Wesley Oler,Jr. not allowing Paul E. Green within 100 yards of residence at 519 Cherry Court. all of which were against the peace and dignity of the Commonwealth of Pennsylvania and contrary [o the Act of Assembly, or in violation of ~%~~ ,;;;. 4~<~~%t and ~y~~4* „, ~~~~ of the Act of'~i% ~, ""'r~~~""~""~°"~~~'~t!' (Section) (Sub-sechon) or the ;,. ,r ,#~ ~; Ordinance of „; ~~~ . ,~ . , ,~~~dax~~~/~~~~"~~~f~~i~'~7;~''^. (Politrca! Sub-division) (3) I ask that a warrant of arrest or a summons be issued and that [he accused be required to answer the charges I have made. (4) I verify that [he facts se[ forth in this complaint are true and correct to the best of my knowledge or information and belief. This verification is made subject to the penalties of Section 4904 of the mes Code (18 Pa. C. S. § 4904) relating to unsworn falsification to authorities. April f~ , 19 94 ~~\ ..~p pp ~ ( gnamre plainan[) `~, AND NOW, on this date ! ~ / /~ ~ L- ~ 19 ~ I certify/the compla}'~t has been properly compl ted and verified, and that there is probable cause for issuance of process. ~] / 1- I !\ ~ Jl1/'ll ~ L) (Magisterial Disdict) (/suing Authortry) AOPC 471-88 ORIGNNAL-SEE REVERSE SIDE FOR WAIVER AND FOOTNOTES J x~ ~~~~~ KRISTY M. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW INDIRECT CRIMINAL CONTEMPT PAUL E. GREEN, Defendant 94-1166 CIVIL TERM IN RE: COMPLAINT DISMISSED ORDER OF COURT AND NOW, this 13th day of April, 1994, upon consideration of the complaint for indirect criminal contempt, and the alleged victim having failed to appear for the trial in this matter, the complaint is dismissed with prejudice. By the Court, '.. J~.f esley Ol~r, Jr.`';' WILLIAM I . GABIG, ESQUIRE " (uS/e./~. `~~/y w~~l~! Sr. Assistant District Attorne TIMOTHY L. CLAWGES, ESQUIRE -C~%~{ Se/~'~''f/1`f (/~~~ Assistant Public Defender VU wcy y, , ! i 1 .~ .,.~ ,a~t <<'- KRISTY M. GREEN, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v :NO. 1166 - CIVIL - 1994 PAUL E. GREEN, Defendant :CIVIL ACTION - CUSTODY COURT ORDER AND NOW, this ~ ?~ day of ~~~ 1994, the Conciliator being advised that the parties hav reached an Agreement in this matter, the Conciliator relinquishe jurisdiction of the case. Hubert X. Gilroy, Esquire Custody Concili or ~ ^.r ~;,y 1 O J \)~ 1 ~ ~ ~ 1 ~ ~ 1 1 ~ ~ 1 1 11 e ; 1 ~~ ~ ~i ~ ~4d~~ ;~} y 1~~ ~ ~ 1 L -' ~t ~ 1 ~ 11 ~1 ~1 ; i ~ i ~; a o ~- ~ t ~ ~~ ~ n b i p~ i i i 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 ti i i i i i i i i i i i i w t rl-:- ~~ x J I ~~ ;~ .. " ,~ ~ ;~ ~' a ~o ~~ ~~ ' b D ~ ~ ~ n ~g~i G Y E , w. l Y ti ! ~ 0 i w a '., U W a; a a i t ~: ~° i { SfP lb ~~ 55 dM ~~~ ,;F , c.. r, 4, ~ ,~ y KRISTY M. GREEN, Plaintiff v. PAUL E. GREEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW N0. 94-1166 CIVIL TERM ORDER OF COURT AND NOW, this `~ day of December, 1996, upon consideration of Defendant's request in a letter dated December 2, 1996, for appointment of counsel to represent him in a custody matter, and Legal Services having apparently been unable to locate an attorney who will represent him pro bono, Lindsay Dare Baird, Esq., 37 South Hanover Street, Carlisle, PA 17013 is APPOINTED to represent him on the matter of custody only. DEFENDANT is requested to communicate in the future with his appointed counsel rather than the Court concerning his custody matter. BY THE COURT, ~~~ O~ J. ~Pesley Oler, J J. ~,c~ ~~ Family Law Clinic f-' ~-, 45 North Pitt Street Carlisle, PA 17013 `; ~~ Attorney for Plaintiff ~'`.! _ r~ Ron Turo, Esg. ,,, 32 South Bedford Street ~~, _` Carlisle, PA 17013 Former Attorney for Defendant I~I4b Legal Services, Inc. ll' ~ 8 Irvine Row Carlisle, PA 17013 Court Administrator's Office -~vccc.,~. Td ~`•~'~'~J~-~ . iaj~~96 2C.. Lindsay Dare Baird, Esq. 37 South Hanover Street Carlisle, PA 17013 Court-Appointed Counsel for Defendant Paul Green, DA-2337 301 Morea Road Frackville, PA 17932 Defendant :rc I~RISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF :Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. : CUSTODYNISITATION PAUL E. GREEN, : NO. 1166 OF 1994 Defendant PETITION FOR MODIFICATION OF TEMPORARY PARTIAL CUSTODYNISITATION ORDER The Petition of Paul E. Green respectfully represents that on the 17th day of March, 1994, a Temporary Order of Court was entered for Partial Physical Custody, a true and correct copy of which is attached. 2. This Order should be modified because the mother of the Petitioner's minor child, ICaylee Green, refuses to allow visitation between Petitioner and the minor child. It is requested that visitation be ordered. WHEREFORE, Petitioner respectfully requests that the Court modify the existing Order for Partial Custody because it will be in the best interest of the child. Respectfully submitted, 11 d- `i~~~~~ Lin say Dare Baird, Esquire Attorney for Petitioner 37 S. Hanover Street Carlisle, Pennsylvania 17013 I certify that the statements ix- the foregoing pleading are, to the extent of my knowlege and belief, true and correct. I understand that false statements herein are made subject to the penalties of 18 PACS 4904 relating to unsworn falsification to authorities. •• nn 11~~ ~G~-~~ Li dsay Dare Baird, Esquire KRISTY M. GREEN, Plaintiff, v. PAUL E. GREEN, Defendant MAR 1 ~ I994~~ IN TIIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW CUSTODY NO. ~ ~ ~` OF 1994 TEMPORARY ORDER OF COURT AND NOW, this J 7~day of Mazch, 1994, upon consideration of the Temporary Custody Agreement entered into by the parties, the court orders as follows: 1. The Plaintiff and the Defendant shall have shared legal custody of their daughter, Kaylee Green. 2., The Plaintiff shall have primary physical custody of Kaylee Green. 3. The Defendant shall have partial physical custody of Kaylee Green. 4. The Defendant shall have physical custody of Kaylee Green at times to be agreed upon by the parties. 5. Kaylee shall not be removed from the commonwealth of Pennsylvania, absent consent from the Plaintiff. 6. The Defendant will refrain from the consumption of alcohol while Kaylee is in his custody. ~ / I ~ T ~~ vV YJ ( ~ ~~~L / MAR } ' I^n,q~~,,,, KRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS Plaintiff, : OF CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION-LAW CUSTODY PAUL E. GREEN, Defendant : NO. ' h~>OF 1994 TEMPORARY CUSTODY AGREEMENT RE; KAYLEE GREEN 'r1 L This agreement is entered into this ~ ~ day of ~~` 1994, between the Plaintiff, Kristy M. Green, through her attorneys, the Family Law Clinic, and the Defendant, Paul E. Green. The parties agree that the following may be entered as a court order to be in effect until further order of this court: 1. The Plaintiff and the Defendant shall have shared legal custody of their daughter, Kaylee Green. 2. The Plaintiff shall have primary physical custody of Kaylee Green. 3. The Defendant shall have partial physical custody of Kaylee Green. 4. The Defendant shall have physical custody of Kaylee Green at times to be agreed upon by the parties. 5. Kaylee shall not be removed from the commonwealth of Pennsylvania, absent consent from the Plaintiff. 6. The Defendant will refrain from the consumption of alcohol while Kaylee is in his custody. -7 ~7 Dated: , F~~/ / ' `7 `~ i Signed: ~/IA/I~~ ,~.~'(4 ~,!~l ,i Kristy M. Green J; ~/ %~ aul E. Green t N`-,~- 41-' ` U~-G~cL _ Ann St. Ledger ~' Certified Legal Intern Thomas M. Place Robert E. Rains Linda E. Fisher Harvey A. Feldman Supervising Attorney The Family Law Clinic 45 North Pitt Street Cazlisle, PA 17013 717/240-5204 or 717/243-2968 ~ ` ~° o `i ~ Y ". 7 ib ~ r r ~~ rj ~ ~: a. y~ '' - -%~ :.y ~ ~ m :., ~o "a -c * ~ ~ /'~ (~,,~~,~ :IN THE COURT OF COMMON PLEAS OF 5 Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V * 1/a~ ~ ~• ~r~~en Defendant :CIVIL ACTION - LAW NO . ~ (6 ~ CIVIL I9 q :CUSTODY/VISITATION ORDER OF COIIRT AND NOW, this- (date)Z`~o~q~ , upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before ~'~c~iei)- X. G%(/v~/y,esg, , the COnCi.118tOr, at ?~Q (~... tir~(s,.~ (ovn '~~ (oo /.f ~ti~ P ~f/1 Flo o/ /oM~,r~^CQ on the ~i 1''11 day of fFO~~`~ 19 ~ at ~~ 3 v /?-,M:, for a Prehearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be' heard•by the court, and to enter iato a temporary order. Either party may bring the child who is the subject of this custody action to the conference, but the child/children's attendance is not mandatory. Failure to appear 'at the-conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: Y~ ~` B Custody on il'iatDr ~ ~ RS YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTX BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, FOURTH FLOOR CARLISLE PA 17013 (717)240-6200 4h~~c ~~ c,~ hz~c~ ~! 'hN•~ \>IPiI-P~~I~:~f~t,~,~-~ '~, ~-,;~ ., ,,, L~1 •i ui<J '''G ~~~ Ci 3~!CJ-{!~ iii AUTHORITY TO PAY COURT APPOINTED COUNSEL t. COURT ^ District Justice ^ Common Pleas ^ Appellate ^ Other 3. FOR (D.J., C.P., APPELLATE) 4. AT (CITY/STATE) .6. 1IN THE CASE OF 7. CHARGE/OFFENSE (PUROON CITATION) /~ i/SJ~~/ M. (.7/CCr~ Ya ~/ ~ ~7~CPr) . 9. PROCEEDINGS (Describe briefly) 10. P`E//R~SON REPRxE~JSEN>T/ED (Full Name) Appl Dale ,a' ~ -9e~ 11. PERSON REPRESENTED 1 ^ Delsn4ent-Adult 2 ^ Defendant-Juvenile J ^ ADpellant a ^ Appellee 5 7 Habeas Petitioner 6 ^ Material Wdnesa ^ Parolee Charged Wrth Violation a ^ Probationer Charged Wim Violslion 9 ^ Otner: ~oyi ~ a.~~i ~%. O~Q~r NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE >- a> >- ~ 7 !--:. W~ ~ :;. 19. u-,-.. °-i ~~~RVICE a. Arr i~ent'.~/or PHe ~q b. PAIN~{iihary H.3t~7ting ~-: =i 7 c. M04oyfAand y_quaat;~~~~ d Bed LLringsg" '~ ~ e. Senldpae HeaDlage (~ U L Trial 2 g. Revocation Hearings n. Juvenile Meeringa i. Appeals coon i~ Other (Specity pn additional sheets) MAY 0 61997 '~ 2. VOUCHER N_ 2436 5. BUDGET CODE S. O PETTY OFFENSE ^ FEIONV ^ MISDEMEANOR 12. CIVIL DOCKET NO. 9'-y //(QLv 13. CRIMINAL DOCKET N0. 14. APPEALS DOCKET NO. 16. NAME OF ATTORNEY/PAYEE AND MAILING ADDRESS Lindsey Dare Baird 97 South Hanover Street Cariisie, PA 17013-3307 1T. TELE HONE NO. 19. SOCIaL5E0URIiY NO On EINNO CLAIM FOR SERVICES OR EXPENSES HOURS DATES AMOUNTS CLAIMED MuI1101y rats per hour times total hours to obtain "In Coun" com- psnselion. Enter total DllOw. 790. TOTAL IN COURT COMP, TOTAL HOUR S ~ XX 350 PER HOUR 20. / a. Interviews en conlarenc 1~ /T'.YC~, ('pnC///q19/ . `} C7 /" ~~ 'Q~ LL b. Obtaining antl reviewing records ~ ,j U ~. /~ • 9 O ¢ a Legal research antl brief writing ~ ~ .5(.~ ~ ~ C~'~- O O tl. Investigative.and other work (Specify on additional sheets) ~ /~' - y~ - ~~ 9 ~`rnns,~v7xL'¢rrec ~2[ a ~ ~ ~ ~ TOTAL HOURS = /~ ` X Sao PER HOUR 2t. ITEMIZATION OF REIMBURSABLE EXPENSES _ AMT. PER ITEM _ Mileage $.25 per mile x - w 2 O 22. CERTIFICATION OF ATTORNEY/PAYEE 11//'' Has compensation and/or reimburosmant for work In this teas provlousy been apOtled toR ^ YES ENO Il yes, were you paidT ^ YES ONO Ifyse, bywhom wero you paldT Now muehT Has the person represented paid any money to you, or to your know~e~Qga anyone else, In connection with the mallet for which you were appointed to provide repreaenlatipnT ^ YES ~ NO II ya give datai_I ~ n additional she~ttS~ I swear or atlirm the Vulh or cortactneaa 4 / .J ~5 ' `1~ ~" of the above statements Spnat Anome~/y/7aye U Dets'J rlyl Slgnalure of ~~avue Nr Judge - Date: 2 Copy 1 -Mail to'Gourt Administrator at completion of service ~f Multiply rats per hour times total hours. Enter total "Out of Court" eompenaatlpn below. 200. TOTAL OUT OP COURT COMP. -$a~~.~J 210. TOTAL ITEMIZED lXP. ~S 23. GRAND TDTA/L CLAIMED $ ~~(] Oc> 24. DEDUCT. PRIOR PYMTS. ~S 25. NET AMOU~~N~/T CLAIMED 3 ~7v - arJ 2T. AMT. APP110VED 'S a.'{O a'aC7 LINDSAY DARE BAIRD Attorn~e ~ At Law 31 S. Hanover • Carlisle, PA 11013 • (111)243-5732•Fax (717) 243-8110 May 5, 1997 EXPLANATION OF CHARGES: Paul E. Green No. 94 - 1166 1/13/97 Procure and review file 4/17/97 Pre-hearing custody with H. Gilroy, Esq. 4/25/97 Reseazch and memorandum as requested by Attorney Gilroy 12/96- 04/97 Extensive correspondence and postage Total: 6 hours @ $40.00 = $240.00 .50 hours .50 hours 3.0 hours 2.0 hours Thankyou!~ O ~ ~~ MAY 2 9 1997c~ KRZSTY M. GREEN, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENN5YLVANIA V :CIVIL ACTION - LAW PAUL E. GREEN, :NO: 1166 OF 1994 Defendant :IN CUSTODY COURT ORDER AND NOW, this ~~ day of ~) , 1997, upon consideration of the attached Custody Conci~ iation Report, it is ordered and directed as follows: 1. A h acing is scheduled in the above case in Court Room No., of the Cumberland County Court House on the °''~ day of , 1997 at l~.m. At this hearing, the issue will be whether the Father's visitation rights may be terminated or suspended as a result of the Father's present incarceration. Counsel for the parties shall file with the Court a memorandum setting forth the history of custody in this case, each party's position with respect to Father's ability to exercise visitation with the child while he is incarcerated, any legal authority supporting each party's position, a list of witnesses the parties will call to testify and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least ten days prior to the hearing date. 2. Counsel for the Father shall present to the Court the appropriate Order to provide for Father's attendance at the hearing. cc: Lindsay Dare Baird, Esquire \ William C. Vohs, Esquire j BY THE COURT, 1 ~ ©~ (/ ~( J. J. ~es ey Oler,~Jr. 1 ~~-~-~ G • ~ - 9 7 /~7 KRISTY M. GREEN, Plaintiff V PAUL E. GREEN, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :NO: 1166 OF 1994 :IN CUSTODY Prior Judge: J. Wesley Oler, Jr. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Kaylee N. Green, August 22, 1992. 2. A Conciliation Conference was held on April 17, 1997, with the following individuals in attendance: Lindsay Dare Baird, Esquire, who appeared on behalf of the Petitioner, Paul E. Green, and the Mother, Kristy M. Green, with her counsel, William C. Vohs, Esquire. 3. The Father is incarcerated. The Mother has not been taking the child to see the Father. The Father is now seeking visitation rights at the Prison. The Mother's position is that the Father assaulted her and held her and the child hostage for several hours. The Mother suggests that Father has demonstrated "a reckless and wanton Zack of concern for the child's welfare" and, on that basis, visitation rights can be denied to the Father pursuant to applicable Pennsylvania law. 4. A hearing is required for the Court to consider whether visitation for the Father may be denied and, if such rights are granted, the circumstances for the granting of the visitation rights. The hearing should take no more than one- half day. 5. The Conciliator recommends an Order in the form as attached. ~~ a/ ~~ DATES ~/i~ Hu ert X. Gilroy Esquire Custody Concili for KRISTY M. GREEN, Plaintiff v. PAUL E. GREEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW N0. 94-1166 CIVIL TERM ORDER OF COURT AND NOW, this ~ IN day of June, 1997, upon consideration of the attached letter from William C. Vohs, Esq., attorney for Plaintiff, and upon agreement of counsel, the custody hearing previously scheduled for August 29, 1997, is RESCHEDULED to Friday, September 5, 1997, at 1:30 p.m., in Courtroom No. 5, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, ~~ ~ ~~ J Wesley Ole~Jr., William C. Vohs, Esq. Suite 2, 11 West Pomfret Street Carlisle, PA 17013 Attorney for Plaintiff Lindsay Dare Baird, Esq. 37 South Hanover Street Carlisle, PA 17013 Attorney for Defendant :rc ,~• ~;, I. .~, on ~~~~~,~ ^I -. n ,_ ~1 u~ H.Alv~*T 8e Voss ATTORNEYS AT LAW 11 WEST POMFRET STREET, SUITE 2 CARLISLE, PA 17013 MICHAEL J. ILINFT WILLIAM C. POH6 May 30, 1997 The Honorable Wesley Oler Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 RE: Green v. Green No. 94-1166 Civil Term In Custody Dear Judge Oler: (717) 249-5373 F!.X (7 V) 249-O ~L57 Please accept this letter as a request for a continuance for the hearing scheduled for Friday, August 29, 1997 at 1:30 in the above-referenced matter. i am scheduled to be out of the office on that date. Should you have any questions or need any additional information, please do not hesitate to contact me. Very truly yours, HANFT VOHS Wil iam C. Vohs WCV:dln cc: Kristy Green ~uN ~ 2 1397 rwuemo~casionximeaurxw~re~mu KRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. : CUSTODYMSITATION PAUL E. GREEN, : NO. 1166 OF 1994 Defendant OAI2ER9F~OIJRT AND NOW, this __~ q ~ day of _~ ~ __}~_~~ _ __ , 1997, upon consideration of the attached Request for Writ to Transport, the Cumberland County Sheriffs Department is hereby ordered to transport Paul L. Green from the State Correctional Institution at Mahoney to arrive in Cumberland County Prison no later than Thursday, September 4, 1997, for a Custody Hearing scheduled for September 5, 1997 at 1:30 p.m. before the Honorable Judge Oler. By the Court __ __~f/--~~ _ -~-4'E~ - __ ' J. cc: Cumberland County Sheriffs Department 1 Courthouse Square, Carlisle, PA 17013 William C. Vohs, Esquire Suite 2 11 West Pomfret, Cazlisle, PA 17013 Lindsay Daze Baird, Esquire 37 South Hanover Carlisle, PA 17013 `~ ``~' -i -n .~ J Sri :.`~. , ,!c~ _ _.~ ` : 'ri = < ~ ~ V.i _{ J r~, s , .~ STATE OF PENNSYLVANIA, ss Cumberland County, The Commonwealth of Pennsylvania to the State Correctional Institution at Mohoney GREETING By an Acf of Assembly of 1785, we command you to have the body or bodies of _P_a_ul_L._ Green ___________________ before the Hon. _.i._fva&1~~ Qls_r__1s,________________ of the Court of ____COm[fLQn_Pleas____._____________ of said County, on .Friday _ the S h day of _Sept ~ 1997., house Rm.S atl__30__ o'clock, _?'M, at theCumb. Co_._Court,,-in the Borough of Carlisle, together with the cause of his detention in your custody. Then and there to do and receive all and singular those things which our said Judge shall consider and adjudge in that behalf. Witness the Honorable __J,_ Wesley_Oler,_Jr_________________________ Judge of our said Court, at Carlisle, the ____?9th_ _ _ day of _September _ __ __ A.D. 19 97_ Lawrence E. Welker -------------------------- - ----- Prothonotary and Clerk of Court Deputy TRUE COPY FROM RECORD In Testimorry whereof, t here unto set my hand and the seal of said Court at Cartisle, ~7 this .~4~ days Prothonotary D Q 1 K ~C~wr rN vr- ~t ry 7 i r (!z p. N r-O m ~ N C N w I~ rt~ ~ fD ~ N~ ~ J T N w ro N ry Nb7 (D r C [D J (U d o ry r- ~ ry w to p. rt ry m cn m ~ rt ,n o_ d m a N v' N ,ti ~~ C r ~~ ~~ iry i~ i~ N 'x ~ry i f,. m ~rt 3 G1 ~ry i~ i~ i~ i I I I Z O ,c i rn rn C7 r- N- r m ~ I ~ ~ ~ ~~~~ AUTHORITY TO PAY COURT APPOINTED COUNSEL t. COURT 2. VOUCHER - ^ District Justice ^ Common Pleas ^ ApDellate ^ Other 2 6 81 N~ 3. FOR (D.J., C.P., APPELLATE) 4. AT (CITY/STATE) 5. SUDGET CODE ~i- a~_<,a6, try. B. IN THE CASE OF 7. CHARGE/OFFENSE (PURDON CITATION) %~ie/S~/ /vf ~j,Q~s ~/RU~ ~; ~~~c ~ a. O PETTY OFFENSE O FELONY O MISDEMEANOR 9. PROCEEDINGS (Describe briefly) 11. PERSON REPRESENTED 12. CIVIL DOCKET NO. //~~ ~~ ~ I ^ Dalandant~Adull ~/: ./ ," 2 ^ Delendanh Juvenile / i.C~ ~' '~ ~~(.(~ ~yZQy, ~ 1, LSV~~/1ll~RR---((( ~Y-t'~~~C ~CS4/' J O APOSiiant 1~9. CRIMINAL DOCKET NO. J 0 ^ ApPBllea 5 ^ Mabeas Petitioner ~- ~,j =~; 8 ^ Material Wrtneas -_ O _.i ~' ~ '~ -' 7 ^ Parolee Charged Wrtn Violation 10. PERSON REPRESENTED (Full Name) 0 O Probationer Charpea W1m Violation l ) ~ dis: APPEALS DOOISE4 NO. ~ (' ~~ QQll`` 9 ^ Other i I ~i - ., ' , C? r !~ . cC//~~ 1B. NAME OF ATTORNEY/PAYEE MAILING ADDRESS ~1'" ~7 ANDI 1 t~-~ !' ~ APOI Dale (o C~ ;~ ~~ Lindsay Dare Baird `- `~ ~ G ~~ ~ 0» 37 South Ha nover Street NAME OF COMMON PLEAS JU GE ASSIGNED TO CASE Carlisle, PA 17013-3307 17. TELEPHONE No. ~~3•5~.~ 1 S. soclaL slicuRlTV Ho OR E iH Ho /98 J2 ' k~j CLAIM FOR SERVICES OR EXPENSES 19. SERVICE HOURS DATES AMOUNTS CLAIMED a. Arraignment end/Or Plea Multiply rata per hour times total b. Preliminary Hearing hours to obtain "In Court" com~ peneatlon. Enter total below. G Motions end Requests d. Bail Hearings ~ e. Senlance Hearinga O L Trial 2 g. Revocation Hearinga ti_ ~'o`~ n. Juvenile Hearinga i. AOpeals Court 19A TOTAL IN C UR `C'OMP. ~r ~/r j. Other (Specity on additional onsets) C US ~. 9 ' ~ - IYJOU- ~. ,~ 9, ~ ~~ ` . ACH ~ .~ TOT OURS= I J Yi60'PL•R HOUR ^'~ ` 7` $ J. + v J 20. a Interviews and ConlerenCla ~ 9 • S • 9 ~ Multiply rite par q/ times total 0. Obtaining antl reviewing records O boon. Enter tot ;®ut of Coun" COmpenaetiOn ¢ ~ L egal research and brief wilting F = ~ O d. Investigadva and other work (Specify on additional sheets) 20A TOTAL OUT OF COURT COMP. y~C~ TOTAL HOURS >• ~ ~CPER HOUR ' $ /fir/ n~'~p"V 2t. ITEMIZATI.ON_ OF REIMBURSABLE EXPENSES __ AMT. PER ITEM Mileage $.25 per mile x w x ~ O 210. TOTAL ITEMIZED EXP. 22. CERTIFICATION OF ATTORNEY/PAYEE Has compensation and/or reimbu sment fa work in thla case proviousy been applied for? OYES ~NO If yes, were you paid? ^ YES ~ NO If yea, bywhom were you paW7 Howmuch7 Has the person represented paid any money to you, Or to your knowledge anyone else, In connsetlon with the matter for which you were appointed to provide reprasentatloM OYES ~NO II ea, g detai on addili al }eel I swear or allirm the truth or conectnasa ~ Pa~(~l" ~ •. S/J ,~j of the above statements gignaturo M Homey/Payee Dsle ze.a„on<,~t t, r~y~ I Signature of \ ~~, O~ O`~~ 2a ' opy 1 -Mail to Court Administrator at completion of service :$ 23. GRAND TO//TAiL CLAIMED 24. DEDUCT. PRIOR PYMTS. >. $ 25. NET AMOUNT CLAIMEDI I~ s $ //$~ tic) 27.AMT. APPROVED °$ 112. So KRISTY M. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN CUSTODY PAUL E. GREEN, Defendant No. 1166 CIVIL 1994 ORDER OF COURT AND NOW, this 5th day of September, 1997, upon consideration of the issue of custody of the parties' child, Kaylee N. Green (date of birth, August 22, 1992), and pursuant to an agreement reached in open court among the parties and their counsel, William C. Vohs, Esquire, on behalf of Kristy M. Green, and Lindsay Dare Baird, Esquire, on behalf of Paul E. Green, it is ORDERED and DIRECTED as follows: 1. The temporary Order of Court dated March 17, 1994, is vacated. 2. The Plaintiff and the Defendant shall share legal custody of their minor child, Kaylee Green. 3. The Plaintiff shall have primary physical custody of the minor child, Kaylee Green. 4. The Defendant shall have visitation at any state correctional institution or prison or county prison that he is incarcerated every other Saturday, during normal visiting hours at that institution, but not longer than between 10:00 a.m. to 8:00 p.m. The Defendant is responsible for arranging transportation of the minor child for these visitations. The >,:~1r ~~ r"~~,., ~~-1.-~n'ni i ~ c~ ~!d 6 I d3S LE, J~IL~.,O-C1311~ Defendant's family, specifically David or Margaret Handshew, may be utilized to transport Kaylee, so long as Kaylee is secured in a rear seat in a seat belt for the round trip to the institution. Any other contact by the Defendant or Defendant's family with Plaintiff other than related to the minor child is prohibited. 5. The minor child, Kaylee Green, shall not be removed from the Commonwealth of Pennsylvania without consent of the Plaintiff. 6. The Defendant may contact the minor child, Kaylee Green, by telephone one time per week between 7:00 p.m. and 8:30 p.m. on any night that is mutually agreeable by the parties. I~Iowever, Defendant is enjoined from discussing any issues with the minor child, Kaylee Green, that do not relate directly with the minor child. The Defendant is not to call the minor child or the Plaintiff collect. He may, however, place third party calls to the minor child for these telephone contacts, and Plaintiff will use her best efforts to aid in the placement of such third party calls. 7. Plaintiff will use her best efforts to provide Defendant with school records and photographs of the minor child, Kaylee Green. By the Court, ~~~~ J Nesley O1~) Jr.~ ' V WILLIAM C. VOHS, ESQUIRE For the Plaintiff ~ /' ,,.,~.~.~ 9~~~5~ LINDSAY DARE BAIRD, ESQUIRE "`'d-_ '~'~~ For the Defendant wcy MAY 141999-- KR[STY M. GREEN, Plaintiff PAUL E. GREEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION -LAW NO. 94-1166 CNIL IN CUSTODY COURT ORDER AND NOW, this ..~~,._' "day of May, 1999, apre-hearing conference is scheduled in the above case on the ~St~. day of ~ , 1999, at : 30 ~.M. to be held in chambers. Counsel for the parti s shall attend this conference. At least 2 days prior to this conference, Counsel for the pazties shall file a memorandum with the Court outlining the procedural issues involved in this case as they relate to 23 Pa.C.S. § 5303. Counsel for the pazties shall also explore prior to the pre-heazing conference some options with respect to any evaluation that would be required for the Father. The memorandum shall also give the Court the background on the Father's criminal record that would trigger the implications of 23 Pa.C.S. § 5303. BY THE COURT, ~i~~~'i ~~J. J esley Oler, .fr. cc: Todd Green _ ~~i,,, S~-to/99 . Lindsay Baird, Esq. ~, ~, ~~ ,.n ~- ~ , _ : ~ _~ r r'." -~i ...:a n -,~. 'ti7 ` ci - I i V ~~ ~.r ~ KRISTY M. GREEN, Plaintiff v PAUL E. UREEN, Defendant Prior Judge: J. Wesley Oler, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.94-1166 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the child who is the subject of this litigation is as follows: Kaylee Green, born August 22, 1992. 2. A Conciliation Conference was held on May 7, 1999, with the following individuals in attendance: The Mother, Kristy M. Green, with her counsel, Todd Green, Esquire of the Dickinson School of Law Family Law Clinic; and Lindsay Baird, Esquire who appeazed on behalf of the Defendant. The Father is incazcerated. There is a prior order in place whereby the Father gets to see his daughter on alternating Saturdays with arrangements for the Father's family to transport the child. Circumstances have changed since that September 1997 Order. Situations have occurred whereby the transporting parties have picked up the child and have, in fact, not taken the child to visit the Father. Additionally, the transporting parties have not returned the child in accordance with the order. Furthermore, Mother now notes that under 23 Pa.C.S. § 5303, the Court is mandated to make a determination upon a potential threat of harm to the child before the child can be required to visit with the Father in light of the Father's criminal record. It is also provided in §5303 that the Court must order an evaluation of a parent in those situations where a parent has a particular criminal record that falls under the scope of § 5303. 4. The Conciliator sees the primary issue a procedural one in this case. The Court must make a determination whether an evaluation of the Father will be ordered and how that evaluation would be accomplished with the Father currently incarcerated at the Waymart State Correctional Institution. For that reason, the Conciliator believes apre-hearing conference should be scheduled before the Court. The Conciliator recommends an order in the form as attached. DATE Hubert ~ roy, Esquire Custody C nciliator SUPREME COURT OF PENNSYLVANIA WESTERN DISTRICT AMYL CERAS0. ESQUIRE DEPUfY PROTHONOTARY PATRICIA A. HONARD CHEF CLERK May 21, 1999 R86ISTRATION IINDHR RIILSS 321 & 322 (P8Nl15YLVANIA HAR ADMI33ION RIILBS) OP BLICI8L8 LA9O STaD88T Leann Mattoscio 257 S. West Street Carlisle, PA 17013 TO THS APPROVBD SIIPBRVISI80 ATTORNEY: Professor Robert Rains Professor Thomas Place Donald Marritz, Esquire The Family Law Clinic THE DICKINSON SCHOOL OF LAW 45 N. Pitt Street Carlisle, PA 17013 BD7 CIiwCOUNiV BUILDING PITTSeupoH, PA 15219.2483 (112)585-2878 A1tryJAvww.eourtastatapaua The above-named law student has been approved and certified under Pa. B.A.R. 321 ~ 322 by: Harvey Feldman, Associate Dean The Dickinson School of Law The Pennsylvania State University 150 South College Street Carlisle, PA 17013 as a duly enrolled law student who has completed at least three (3) semesters of legal studies, or the equivalent thereof, is of good character, has been adequately trained and is of competent Iegal ability to perform as a legal intern as of May Z1, 1999. Pursuant to such certification and in accordance with and sub ect to the provisions of Pa. S.A.R. 321 & 322, the above stu ent has been registered and you have been approved to perform the duties of supervising attorney. my signature and the seal of a Court, y 21, 1999. my J Ce~a so, Esquire /dal ICRISTY M. GREEN IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW IN CUSTODY PAUL E. GREEN Defendant NO. 1166 CIVIL TERM 1994 CONSENT AND APPROVAL FOR APPEARANCE UNDER Pa.B.A.R. 322 I hereby consent to the appearance of Leann Mattoscio, a Certified Legal Intern under the supervision of an attorney, in the above-entitled custody proceeding before the Honorable J. Wesley Oler, Jr. at 1:30 p.m. on Friday, October 22, 1999. Date: October 22, 1999 ~ r . ty M. ~~~ LS As the supervising attorney for Leann Mattoscio, certified under Pa.B.A.R. 322, I approve of her appearance on behalf of the above-named client in the above-named proceeding. Date: October 22, 1999 ~~ ROBERT E. RAINS Supervising Attorney DONALD M. MARRITZ Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 PLAINTIFF'S EXHIBIT KRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION-LAW IN CUSTODY PAUL E. GREEN Defendant. : NO. 1166 CIVIL TERM 1994 STIPULATION And now this 19th day of October, 1999, the parties in the above-captioned matter, by and through their respective counsel, stipulate to the following facts: 1. If questioned, the child, Kaylee Green, would say that she would like to see her father, Paul E. Green. 2. The distance from Shippensburg, Pennsylvania to S.C.I. Waymart is approximately 185.5 miles one-way, with an estimated travel time each way of 3 hours and 42 minutes. 3. Visiting hours at S.C.I. Waymart are from 9:30 a.m. until 4:30 p.m. on weekends. Visitation with an inmate is a "full contact" visit. It takes place in a visiting room, and there are staff members on hand to supervise the room. ~~~~-~'}'t-'ial,~~ Leann Mattoscio ~Cert~ifie~d, cL~e-g~ahInt/er~n , Robert E. Rains Thomas M. Place Supervising Attorneys Donald Marritz Staff Attorney n~~~~td, Lin~say Dare Batrd ~' 37 South Hanover Street Carlisle, PA 17013 (717)243-5732 Counsel for Defendant FAMILY LAw CLINIC ~~~ GQPY FROM AECDiAD 45 North Pitt Street In TeslhnOml ~~~ ~ ~° tMto ~ "~ Rana Carlisle, PA 17013 Aid ~'~ Rat tH818, Pd. (717) 243-2968 T>tils /_ vnsa ~J- ~~ c^ ~, Counsel for Plaintiff prothn ry G ~t9 T ~ p =;} ~ :~ ~g ~O 'fl ~ ~~ '.. -~ o fo2z~i4~ L.K-t" FAMILY TREATMENT ASSOCIATES Paul E. Green Psychological Consultation August 9, 1999 Paul E. Green is a thirty-four year-old, Caucasian male who was referred by the Court of Common Pleas of Cumberland County. He is presently involved in a custody matter involving his child, Kaylee, age 6. Mr. Green is presently an inmate at the State Correctional Institute at Waymart, Pennsylvania and this was the setting for this consultation. Mr. Green is a normally developed thirty-four year old male who was dressed in prison clothing. He is an amputee, having lost his right arm in an industrial accident. He wears his hair long. He appears to be very neat, clean and tidy. Mr. Green was pleasant and cooperative throughout the interview and he appeared to be comfortable with the interview process. Mr. and Mrs. Green (Kristy) were married on July 31, 1993 and this marriage produced one child, Kaylee who was born on August 22, 1992. This was the second marriage for Mr. Green with his first marriage ending in annulment. He stated that his first wife cheated on him while he was in prison. Kristy Green was married previously and she had two sons, Shane and Christopher, ages 9 and 8. Mr. Green states that he had weekend visitations with his daughter and step- sons before going to prison. Mr. Green reports that Kristy is now living with another man and this relationship has produced one child. Mr. Green states that he had a "fantastic" relationship with his daughter and that she visited him for the first two years of this period of incarceration. He states that he sends her cards for birthdays and holidays but he gets nothing in return. He states that he .has received one picture and a copy of one report card since he has been in prison in spite of a court order directing his ex-wife to share information with him. When asked what he wants at this time, Mr. Green stated that he would like telephone contact and visitation with this daughter. He stated that he would be willing to assume responsibility for all costs in regard to visits and phone contact. 1'17 BROAD STREET, STROUD$BURG, PA 18360 • (570) 424-6049 • FAX ~~10 22 ``~ _~r Mr. Green has a fairly extensive criminal record. He was sentenced two to six years for Burglary in 1986 and he was paroled after serving two years. He served five months for Criminal Trespass in 1985. He also served four months for Corruption of Minors and Statutory Rape in 1984. In 1983 he was convicted of Disorderly Conduct. He also was convicted of Driving Under the Influence of Alcohol in 1991. Mr. Green is presently serving a 39 month to 7 year sentence for Spousal Sexual Assault. He stated that he pled no contest as there were other charges against him. He also stated "I did some things but I did not do what I was convicted of - I would have Ntan at trial." When questioned about his record, Mr. Green was defensive, tended to project blame onto others and did not accept responsibility for his own behavior. He denied having a problem with substance abuse in spite of his D.U.I. and morals conviction which involved marijuana. Mr. Green denied ever sexually abusing his ex-wife and he stated that he had no history of sexual misconduct. He focused a great deal of his attention on his ex-wife and what he perceives as her many problems. He believes that she is trying to keep his daughter from him and he in fact questions whether she is an adequate parent. Mr. Green's parents are deceased and he has very little contact with any family members. He does have a cousin who used to transport his daughter for visits however this became too much of a burden because of the distance involved. Mr. Green states that his childhood was unremarkable. He did not graduate high school but he did obtain a G.E.D. He has not served any military service time. He states that he was always steadily employed at unskilled or semi-skilled labor type jobs. He was employed as a painter at the prison but was recently transferred to the garment factory where he can earn more money. He is very proud of his work record and the fact that he never collected disability benefits. In regard to future plans, he states "I just want to hold her", referring to his daughter. He also plans on "working" as much as I can so that I can rebuild my life. He is willing to participate in counseling with his daughter in order to provide for a comfortable reunification. Mr. Green has been evaluated psychiatrically on several occasions but he states that treatment was never recommended. Mental Status Exam: Orientation: Speech: Affect: Mood: Client is well oriented to person, place and time. Speech is somewhat rapid and pressured. It is well modulated. He is very loquacious. Affect is appropriate to content of discussion. Stable. Client denies depressive symptoms. He shows no indication of manic thoughts or behavior. Thought Content: Logical and coherent. No evidence of delusions, paranoia or Suicidal or Homicidal ideation. He is manipulative and calculating. Thought Processes: No evidence of psychosis. No hallucina- tions or illusions present. Judgment: Obviously impaired. Insight: This is lacking. Client does not accept responsibility for his own actions. He shows little remorse. Attention: He displayed no sign of hyperactivity, destractable thinking or short attention span. Memory: Short and long-term memory are intact. Impulse Control: Appears to be limited by history. Diagnosis: I Adjustment Disorder with Mixed Disturbance of Conduct and Emotion II Personality Disorder, Anti-Social Type III Loss of right arm IV Problems with legal system Problems with primary support group V GAF = 60 Recommendations: 1. Client should be involved in on-going counseling to help him better accept responsibility for his behavior and to help him to relate better with others. 2. He expresses genuine love and concern for his daughter, and to my knowledge, has never caused her any harm. Visiting and phone contact may be helpful to both parties. 3. In view of his history, visiting should be closely monitored and supervised. 4. When released, a counseling program to help facilitate reunification would be very helpful. Bruce E. Snyder, MS Licensed Psychologist PA# PS0004106-L SC1 WRM 1NMRTE RECORDS TEL~570-488-2551 May 28'99 15.01 No .004 P.03 COMMONWEALTH OF PENNSYLVANIA Department of Corrections SCI Waymart (670) 488-6811 May 28, 1999 SUBJECT: GREEN, Paul, DA2337 TO: TO WHOM IT MAY CONCERN FROM: JOSEPH P. NISH INMATE PROGRAMS MANAGER Please be advised that Mr. Green has completed the following programs at SCI Waymart: 1) Human Sexuality 2) Co-Dependency 3) Drug and Alcohol Education 4) Domestic Violence Additionally, Mr. Green has been participating in the Sex Offender Therapy Program since 3/98. This program is for individuals who accept responsibility for their sexually assaultive behavior. Please be advised that Mr. Green has signed an Authorization for Release of Information from the Department of Corrections and this information is protected by Federal Regulations that has secondary dlsseminatlon or re-disclosure. If you have any questions regarding Mr. Green, you can contact his counselor, Fred Grasso at (570) 488-5811, extension 3400, EXHIBIT 2 I io•2z~ga ~~T SC1 wHM 1NMHIE KECURDS TEL~570-488-2551 May 28'99 15 00 No .004 P.02 EIIB. f18II88 PAOGAa1f8 DAIIa 111D ~SOL BDIICATIOaT 25 ZS Thia is a three month drug and alcohol education program Por inmates who are waiting for placement in the Therapeutic Community or have a limited substance abuse history. This program includes: therapeutic, educational and self-help groups. 8EY OFFE~iDEAB fiA0IIp8 8071A1i 6E=IIALITY 15 3S This group focuses on providing participants information on human sexuality, anatomy a»d physiology. Other topics included are values and sexual bshavior, patterns o! sexual response, psychoasxual life-styles, and reproductive sexuality. The group is didactic; however, time is made !or dialoquc. Group consists of ten sessions, approximately 1 hours in length. 1[IBC. TEEAI~PY DOI[ESTIC YIOLmtCE O1tOIIP iT 12 This group provides educational and therapeutic intervention for inmates convicted of crimes of domestic violence. The goal of the group is to find alternatives to aggression and stop the cycle of violence. Tha group will consist o! 12 members. It will mast weekly for one hour and for 10-12 sessions. 8ER OFFENDER CO-DapENDEltCY OAOIIF iS 13 Thia group is educational in nature and foauaes on co-dependency as a compulsive disorder. Thia disorder is learned by family members as a means tc cope with atreaa resulting trom dysfunctional lamily interaction. This pparticular group is praaantad to aonvictad sax offenders. It eonsiata of ten one hour aeaaiona. KRISTY M. GREEN, Plaintiff v. PAUL E. GREEN, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN CUSTODY NO. 1166 CIVIL TERM 1994 PRAECIPE Please accept for filing the attached Order of this Court of April 4, 1996, in Commonwealth v. Paul Eugene Green, No. 95-1105 Criminal Term. This Order was referred to in Paragraph 14 of Plaintiff's Petition for Modification of Visitation Order of April 30, 1999, but was omitted inadvertently. ~y~~(~ Leann Mattoscio Certified Legal Intern ~f l Thomas MWW. Place Robert Rains SUPERVISING ATTORNEYS Donald Marritz STAFF ATTORNEY THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Dated: June 1, 1999 COMMONWEALTH V. PAUL EIIGENE GREEN OTN: E003970-1 E726578-6 E230426-0 IN RE: NOLO IN TAE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94-2000 CRIMINAL TERM AFFIANT: PTL. JOHN SANCENITO 95-1105 CRIMINAL TERM CHARGE: (F) SEXUAL ASSAULT AFFIANT: TPR. LEONARD LANDER 95-0296 CRIMINAL TERM CHARGE: (E) SPOUSAL SEXIIAL ASSAULT AFFIANT: CHIEF DUANE LEBO PLEAS & SENTENCING ORDER OF COURT AND NOW, this 4th day of April, 1996, the Defendant, Paul Eugene Green, appeared in court today represented by Samuel W. Milkes, Esquire, Assistant Public Defender. Pleas are accepted as follows: A -~ To 95-1105, the Court accepts a plea of l`iglo G' ;in contenders to a charge of Sexual Assault, Count F, a vioiatio~{i`~ ~n m of 18 25 3124.1 as provided by the Act 10 approved March 31st 1995, to be effective 60 days after March 31st, 1995. ~`~-, To 95-0296, Count E, the Court accepts a plea of nolo contenders to the charge of Spousal Sexual Assault. The pleas of nolo contenders to these two charges are now accepted by the Commonwealth in full satisfaction of all outstanding charges presently pending against Mr. Green in this County. At the time that the pleas of nolo contenders were accepted, the District Attorney related to the Court that a plea agreement had been entered into concerning the sentence on these two charges. I have heard the agreement. I will accept the agreement, and impose sentence as follows: To 95-0296, Count E, sentence of the Court is the Defendant pay the costs of prosecution, undergo imprisonment in a State Institution for not less than 39 months nor more than 7 years. Sentence to date from September 1st, 1995, and run concurrent with any other sentence the Defendant is presently undergoing. To 95-1105, Count F, sentence of the Court is the Defendant pay the costs of prosecution, undergo imprisonment in a State Institution for aot less than 39 months, nor more than 7 years. Sentence to date from September 1st, 1995, and run concurrent with any other sentence the Defendant has been presently directed to serve. The Court further directs that the Defendant not be transported to a State Institution until such time as the District Attorney's office informs the Court that they are recommending a transfer at that time. I would direct that this sentence order be transcribed, along with the colloquy that took place prior to the sentence being imposed. By the Court, 1 ~~ F,tarold E. She y, P.J. Travis N. Assistant Samuel W. Assistant Probation SCIC CCP Gery, Esquire District Attorney Milker, Esquire Public Defender :mal KRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION-LAW IN CUSTODY PAUL E. GREEN, Defendant : NO. 1166 CIVIL TERM 1994 CERTIFICATE OF SERVICE I, Leann Mattoscio, hereby certify that I am this date serving a true and correct copy of Plaintiff's Praecipe dated June 1, 1999, along with a copy of this Court's Order in Commonwealth v. Paul Eugene Green, No. 95-1105 Criminal Term, on Lindsey Dare Baird by mailing a copy through first-class U.S. mail, postage prepaid to the following address: Lindsey Dare Baird, Esquire 37 South Hanover Street Carlisle, PA 17~0p1~3~ r r ,,~ _ , d-eGtln,~-.~~~~-+~ ~7 Leann Mattoscio Certified Legal Intern THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Date: June 1, 1999 KRISTY M. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW PAUL E. GREEN, Defendant N0.94-1166 CIVIL TERM ORDER OF COURT AND NOW, this ~ `~ day of July, 1999, upon consideration of the parties' petition with regard to custody of the parties' daughter, Kaylee Green (d.o.b. August 22, 1992), and pursuant to agreement of counsel, Bruce E. Snyder, M.S., is appointed pursuant to 23 Pa. C.S. §5303(c) to provide counseling and to provide testimony regarding the provision of such counseling at a maximum cost to the county of $500.00. See 23 Pa. C.S. §5303(c). COUNSEL aze requested to notify the court at such time as they desire a hearing on the petitions herein. BY THE COURT, j ~ (~~ ~/ Wesley Ol Robert E. Rains, Esq. Thomas M. Place, Esq. Supervising Attorneys Donald Marritz, Esq. Staff Attorney Leann Mattoscio Legal Intern FAMILY LAW CLINIC 45 North Pitt Street r NiP~ S~ln ~~h :_ J.1;h ~1.- r~- ~~~,.l !'J n i 4d b ~ tlif t, ~.'c~1 ~~ = a~ Lindsay Dare Baird, Esq. 37 South Hanover Street Carlisle, PA 17013 Court-appointed attorney for Defendant Court Administrator --~j~!~< G2w..P.~~„~«~= :rc 'n ~ ,;I~"j_ ._ ~ ~cl AUTHORITY TO PAY COURT APPOINTED COUNSEL 1. COURT ^ District J ice Common Pleas ^ Appellate O Other 3. FOR (D. . G.P., PPELLATE) 4. AT (CITY/STATE) 6. I/.N T`H/E CA/SyE O~,'F~/J ~ /~ d/f a/F/./ 1 I, /~ /,/. !Y't.f~Ir ya i 4.W /C ~ (Y/.r (~ N I 9. PROCEEDINGS (Describe briefly) 7. CHARGE/OFFENSE (PURDON CITATION) ~~/~~ ~ [ar (any/l[~~rcw 10. PE/R~SON REPRpESE~N~T/ED (Full Name) (~,~ ~/CLU~~C- •-4<-Lp 2'v~ - 2a,~caral~y.~-, Apol Date _(.@__(>'_/ 11. PERSON REPRESENTED t ^ Defendant-Adult 2 ^ Defendant-JweNle g ^ App811an1 a ^ Appellee 5 ^ Habeas Petitidner. 6 ^ Material Wnnsae 7 ^ Parolee Charged wile Violation e ^ Probationer Charged Wilb Violation 9 ^ Olnec xtu ,~es~oao-lyZ~ ~ / (J /! rl NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE 2. VOUCHER - N° 3149 S. BUDGET CODE o~ ~3~-~yi-~ 8. O PETTY OFFENSE ^ FELONY ^ MISpEMEANOR 12. CIVIL DOCKET N0~1 , rd{~ 9~ ii~G C%"1~t~S'~ 13. CRIMINAL DOCKET NO. 14. APPEALS DOCKET NO. 18. NAME OF ATTORNEY/PAYEE AND MAILING ADDRESS Lindsey Dare Baird 37 South Hanover Street Carlisle, PA 17013-3307 17. TELEPHONE No. ~~3~-5 ~3~ CLAIM FOR SERVICES OR EXPENSES 1g, SERVICE HOURS DATES a. Arraignment and/or Plea b. Preliminary Hearing C. Motions and RBCUesta R d. Bail Hearings ~ n. Sentence Hearlnpa O t. Trial 2 g. Revocation Hearings h. Juvenile Hlerinpa i. Appeals Court I~ Other (Speciy on additional eneetel CS I ~ ((YICd I , j O s"' ~ ~L • ~j ~j TOTAL HOURS= , j p %RHOUR 20. a. Interviews and conterencee . ~D ,3 • / S ' 9 9 u. 0. Obtaining and reviewing records _ r sO c} -~ , /5/' 9 O ~ c Legal research and brief wdtinq ~...~ ~ ~ p,.'1 ~ ^ ~ . /~ `T ~/ H~ p O tl. Investigative antl other work (Specify on additional sheen) ~ TOTAL HOURS = '1 %jl a'PER HOUR 2t. ITEM_ RATION OF REIMBURSABLE EXPENSES _ AMT. PER ITEM Mileage $.25 per mile x w 2 O 1 e. SOCIAL SECURITY NO OR EIN NO /9~•a7, •k.~49 AMOUNTS CLAIMED Multiply rate per hour times total hduq to obtain "In Court" com- pensation. Enter total helow. 19A TOTAL IN COURT COMP. =$a~- • ~ ~ Multiply rate par hour times total hours. Enter total "Out of Court" Compensation t»low. 20A TOTAL OUT OF COURT COMP. $ X70 . ~ 21A TOTAL ITEMI2ED E%P. _$ 22. CERTIFICATION OF ATTORNEY/PAYEE ~I/, Has compensation and/or reimbu~°J^lant for work In this ease provlouay bean apPlled foA ^ YES p NO Il yes,were you paid? ^ YES R5 NO Ifyea, bywhom were you peldT How much? '/ Has the person represented paid a money to you, or to your know d9e anyone else, in wnnection with the matter for which you were appointed to provide repreaentetlon? ^ YES ,~NO If ; 9 e details on additional aheeta I swear or affirm the truth or corteetneaa ll.(p~/-LLK/ '~..a e •99 of the above statements Sgnalur of Attomsy/ ayee Dele zs.~LOn~,~tc, \ / ruu ~ Signature of ~// (~ L ~.wNe Nt Jutlge - -DNe: 7 7 23. GRAND TOTAL CLAIMED =s //~ • 5v 24. DEDUCT. PRIOR PYMTS- >• S 25. NET AMOUNT CLAIMED 2T. AMT. APPROVED~~pp~~ Copy 1 -Mail to Court Administrator at completion of service O _ i,~ > `_. -. ~ti~ .1 J.) ~ AUTHORITY TO PAY COURT APPOINTED COUNSEL 1. COURT ^ District Justice ^ Common Pleas ^ Appellate ^ Other 3. FOR (D.J.. C.P., APPELLATE) 4. AT (CITY/STATE) 6. IN THE CASE OF /~ f~ "rJ Kr/SLl M. C7rCL~vs /'R4r..0C..~CF-L[[_rt-, 9. PROCEEDINGS (Descrihe briefly) 7. CHARGE/OFFENSE (PURDON CITATION( 10. PERSON REPRESENTED (Full Name) ~~,.P ~• .s41-c,e.2 n. - n a,~it,, aO g~fr r 1t. PERSON REPRESENTED 1 ^ DaNndsnt-AEWt 2 ^ Defendant Juvenile a ^ Aaoeuant a ^ Appell¢e 5 ^ Habeas Petilionet 6 ^ Material Witness ~ ^ Parplee Chsrgad With Viplation e ^ Probtlioner Chargetl With Violation 9 ^ Olhen /pot Oate (~~~' l1 ' Ci'y NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE t r ~ ~j '~, rl'-~~ A ~/~-~ 2. VOUCHER N_ 3157 5. BUDGET>JCODE ~~~[o-~~~~~ B. D PETTY OFFENSE ^ FELONY D MISDEMEANOR 12. CIVIL DOCKET NO. 9~ riloG ~'~s~1t/ 13. CRIMINAL DOCKET NO.,/ 14. APPEALS DOCKET NO. 16. NAME OF ATTORNEY/PAYEE AND MAILING ADDRESS Lindsay Dare Baird 37 South Hanover Street Carlisle, PA 17013-3307 17. TELEPHONE No. a<13-5~3a CLAIM FOR SERVICES OR EXPENSES lg. SERVICE HOURS DATES a. Arraignment antl/or Plee b. Preliminary Hearing C Mollona and Rloueats d Bail Hearings 70 n. Sentence Hearings O 2 I. Trial 9. Revocation Heeringa n. Juvenile Heeringa i. Appeals court Other (Specify on additlOnal eheetsl 1 ~//'J''~~ ~ Q / ~fJ t ~l((f~ ~Qyi . ~ r ,{~ . TOTAL HOURS n. v S () 20. a. Interviews antl confsrencea b. Obtaining antl ravlewinq recoma H - O ¢ c Legal research and brie) writing ~/J Q~~~~uAr r, S O O tl. Inw;sligatiwr and other work (Specify additional sheets) TOTAL HOURS = 21. ITEMIZATION OF REIMBURSABLE EXPENSES Mileage $.25 per mile x W S ti O ~P ~ ~ ~~ PER HIX1R ~>~~~~~0%~ ~fFt9PPER HOUR AMT. PER ITEM 19. SOCI4L SECURITY NO OR EIN NO l9~'• ~ G • ~'d-9 5' AMOUNTS CLAIMED Multiply rate per hour limes total hours 10 oblein "In Court" com• peneatlon. Enter total below. 19A TOTAL tN COURT COMP. '$ a~• 5z~ Multiply rate par hour times total hours. Entsr total "Out of Court" compensation below. 20A TOTAL OUT OF COURT COMP. $ CQ'~~ Jv 21A TOTAL ITEMIZED EXP. ~$ 22. CERTIFICATION OF ATTORNEY/PAYEE Has compensation and/or relmb ro ant for work In thle case previousy be9n aDDlled foR ^YES ~NO If yes,were youpaid? ^YES ~O Ifyes. bywhom wero you pald7 HowmuCh7 Has the person represented pai~~f~~fffffffan```"`y money to you, or t0 your knowledge anyone else, In conneetlon with the matter for which you were appointetl to provide repreaentatlon7 ^YES ~NO II 4 OlwLe dot Is an edditlonal aheetrs I swear or affirm the truth or conectnesa ~~"~~ ~ ~k~ 7 of the above statements Sgnaturs//o(,/~; tomay/ eye Dete 26 nr•wurvt nl Signature of \, ~~~ ~/ N~////' ( C, ~` narNrNr Judge ~ -Dale: ~:.~ rou 1// / /1 / a r J f ~ 1 C py 1 -Mail to CbuR Administrator at completion of service 23. ORAND TOTAL CLAIMED - $ ~i S• w 24. DEDUCT. PRIOR PVMTS. :$ 25. NET AMOCUNT CLAIMED $ ! ~ D'tJ 27.AMT. APPROVED _ _. _ i ~. ~ ~ c ' ~ ~_ -i ~ '~.J a~ f%~~r l ;~.:r, 4c J '<y ~,, ~':y - ~:,,,.^,, ,~: n4 .;c;~ , i •.l~ KRISTY M. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW PAUL E. GREEN, 94-1166 CIVIL TERM Defendant ORDER OF COURT AND NOW, this .~`/ ~ day of August, 1999, upon consideration of Defendant's Petition to Enforce Custody Order, filed March 15, 1999, and Plaintiff's Petition for Modification of Visitation Order pursuant to Pa.R.Civ.P. 1915.15(b), and following apre- hearing conference held on June 7, 1999, the appointment of Bruce E. Snyder, M.S., pursuant to 23 Pa.C.S. § 5303, and production of a report by the appointee, a hearing on the parties' petitions with regard to custody of the parties' daughter, Kaylee Green (d.o.b. August 22, 1992), is scheduled for Friday, October 22, 1999, at 1:30 p.m. in Courtroom No. 1, Cumberland County Courthouse, Cazlisle, Pennsylvania. Defendant, who is in a state correctional institution, may participate by telephone if this can be arranged by his counsel. BY THE COURT, ~~7 ~, sley Oler, Jr ,3l Robert E. Rains, Esquire Thomas M. Place, Esquire Supervising Attorneys Donald Marritz, Esquire Staff Attorney Leann Mattoscio Legal Intern Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 Attorneys for Plaintiff Lindsay Dare Baird, Esquire 37 South Hanover Street Carlisle, PA 17013 Court-appointed attorney for Defendant Court Administrator Sheriffls Office ..8 . :rlm I~RISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN CUSTODY PAUL E. GREEN, Defendant NO. 1166 CIVIL 1994 ORDER OF COURT AND NOW, this ~.~ day of u~ iv~~, 1999, upon consideration of the attached Request for ri~~ansport, the Cumberland County Sheriffs Department is hereby ordered to transport Paul £. Green from the State Correctional Institution at Way~}art to arrive in Cumberland County Prison no later than Thursday, October ~, 1999, for a Custody Hearing scheduled for October 22, 1999 at 1:30 p.m. in Courtroom No. 1, Cumberland County Courthouse, before the Honorable Judge Oler. By the Court ~~ . ~ cc: Cumberland County Sheriffs Department - (~~ „D~~ vs~~ f/ 1 Courthouse Square, Carlisle, PA 17013 9 i,99 Leann Mattoscio, Legal Intern - ~ ~ y.~ 91 Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 Lindsay Dare Baird, Esquire ~ ~ ~„ ~ q./ •gt' 37 South Hanover Street Carlisle, PA 17013 Court-appointed attorney for Defendant ~~~~~v ~.« ~~n,, ~.-~,r - ~,;~~ ;,~,~" i I~RISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN CUSTODY PAUL E. GREEN, Defendant NO. 1166 CIVIL 1994 REQUEST FOR WRIT TO TRANSPORT AND NOW, comes Paul E. Green, the Defendant, by and through his attorney Lindsay Dare Baird, Esquire, and respectfully requests transportation from the State Correctional Institution at Waymart to Cumberland County Prison for the purpose of attending the custody hearing scheduled for Friday, October 22, 1999, at 1:30 p.m. in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania before the Honorable Judge Oler. Respectfully submitthed, (~ 1a~C32:~b/~Z~-t~C_llJ Lindsay Dare Baird, Esquire Attorney for the Defendant 37 South Hanover Street Carlisle, PA 17013 (717) 243-5732 er'iiti ^~}~i~!'d?d ilil~!t ` rann 75 .~ ',. i z a~SEJ ~^, _,." STATE OF PENNSYLVANIA, ss Cumberland County, The Commonwealth of Pennsylvania to the State Correctional Institution of Waymart GREETING By an Act of Assembly of 1785, we command you to have the body or bodies of ____Fatal_E,_Gr~~n___________________ before fhe Hon. ___J._Wesley_Oler,_~Tr~_____________.___ of fhe Courf of ____Corm~an_Pleas____________________ of said !County, on _Friday___ the _?~ _ day of ~tobe~l9.9_9, 1.30 P._ Ciunb. Co. Courtho Ctxm. No. at ___:__ o'clock, __ M, at fhe __________________,'~trlethe Borough of Carlisle, together wi+h fhe cause of his detention in your custody. Then and there to do and receive all and singular those things which our said Judge shall consider and adjudge in that behalf. Witness the Honorable ____ J._ Wesley Oler,_ Jr._ Judge of our said Court, at Carlisle, the _ _ lst _ _ _ _ day of _ _ September A.D. 19.99 _ _Curtis_ R._ Long___________ _ 'Prothonotary and Clerk of Court Deputy D ~'l ~ ~ (((J~~777 CWplN1. N N ~ ~C a cD ~' W~ x ~ ~ ~ m w ~ ~ o ~t w wcn~ H` ~ ~ rt iA o_ 2 a d n 0 v N ~ro ~a i~ i i to ~~ ~~ ~~ 'a I I i I I I I N 1 '~ ir• iN err ~. ~~ iy i~ i I i I I I z 0 r+ w i H H rn rn C F... m KRISTY M. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION-LAW IN CUSTODY PAUL E. GREEN Defendant. : NO. 1166 CIVIL TERM 1994 STIPULATION And now this 19`~ day of October, 1999, the parties in the above-captioned matter, by and through their respective counsel, stipulate to the following facts: 1. If questioned, the child, Kaylee Green, would say that she would like to see her father, Paul E. Green. 2. The distance from Shippensburg, Pennsylvania to S.C.I. Waymart is approximately 185.5 miles one-way, with an estimated travel time each way of 3 hours and 42 minutes. 3. Visiting hours at S.C.I. Waymart are from 9:30 a.m. until 4:30 p.m. on weekends, Visitation with an inmate is a "full contact" visit. It takes place in a visiting room, and there are staff members on hand to supervise the room. Leann Mattoscio Certified Legal Intern Robert E. Rains Thomas M. Place Supervising Attorneys Donald Marritz Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 nClkui ~C~1/1~V`~ucki Lin say Dare rd ~ 37 South Hanover Street Carlisle, PA 17013 (717)243-5732 Counsel for Defendant Counsel for Plaintiff a ° w~ - ~~ k C? 7C U~ Yr, Li3 =.. CL ~= V ~ ~. O ~ U ~ U KRISTY M. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW PAUL E. GREEN, Defendant NO. 94-1166 CIVIL TERM ORDER OF COURT AND NOW, this x6l~day of October, 1999, upon consideration of Defendant's Petition To Enforce Custody Order and Plaintiff's Petition for Modification of Visitation Order Pursuant to PA. R. Civ. P. 1915.15(b), with respect to the parties' child, Kaylee Green (d.o.b. August 22, 1992), it is ordered and directed as follows: 1. Legal custody of the child shall be shared by the parties. 2. Primary physical custody of the child shall be in the mother; 3. The father shall have visitation rights with respect to the child as follows: a. Following two telephone conversations on successive weeks with the child, at the father's expense, each month on the third Saturday of each month for a period of up to three hours at the state correctional institution at which the father is an inmate, supervised by a person approved by the court upon motion of the father's counsel, and transported by a person approved by the court upon motion of the father's counsel; b. At such other times as the parties may mutually agree. BY THE COURT, ~~°-' J Wesley Ol r, J . Y J i ~.~~~ it l~ ~(, i'Gf a ..~ A~7J.~~ ~ i_ U ~Jl~a~) ~.1~ II7 ~..I Robert E. Rains, Esq. Thomas M. Place, Esq. Supervising Attorneys Donald Marritz, Esq. Staff Attorney Leann Mattoscio Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, Pa 17013 Attorneys for Plaintiff Lindsay Dare Baird, Esq. 37 South Hanover Street Carlisle, PA 17013 Court-appointed attorney for Defendant :rc "`~_ ~ , iP AUTHORITY TO PAY COURT APPOINTED COUNSEL FEB $ $ 2000 1. COURT ^ District Justice ^ Common Pleas ^ Appellate ^ Other 3. FOR (D.J., C.P., APPELLATE) 4. AT (CITY/STATEI 6. IN THE 00.iEEF ~YISlI y y7}, E-7 rrPn 9. PROCEEDINGS (Describe bristly) 7. CHARGE/OFFENSE (PURDON CITATION) ~u /•i~~~ 1~Le cLa /,r~r 10. PERSON REPRES~E+NTED (Full Name) f~- au / E l~ rz e r~ / ~-e fR ~Tda •z~' Appl Date /~ ' 7~ 11. PERSON REPRESENTED 1 ^ Delentlant-Atlult 2 ^ Delentlant~JUVenile 3 ^ Appellant a ^ Appellee 5 ^ Habeas Petitioner. 6 ^ Material Witness 7 ^ Parolee Chargeb Wim Violation 0 ^ Probationer Charpeo With Violation 9 ^ Other: ~ ~ l~ NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE 2. VOUCHER - N_ 3364 6 BUDGET CODE a. O PETTY OFFENSE ^ FELONYOMISDEMEANOR 12. CIVIL DOCKET NO. 9~ /i(O(! ~S~ 13. CRIMINAL DOCKET NO. 14. APPEALS DOCKET NO. 16. NAME OF ATTORNEY/PAYEE AND MAILING ADDRESS Lindsay Dare Baird 37 South Hanover Street Cal'lisle, PA 17013-3307 17. TELEPHONE No. CLAIM FOR SERVICES OR EXPENSES ty, SERVICE HOURS DATES a. Arraignment and/or Plea b. Preliminary Mearinq c. Motions and Repuasta 4 Bail Hearings ~ a. Sentence Hearings = f. Trial ~ S ~o•dd'FS , g. Revocation Hearings h. Juvenile Hearinpa i. Appeals Court i. Other (Specily on additional sheets) a'i) TOTAL HOURS = a , S dFe9D PER HOUR 20. a. Interviews ono comarences b. Obtaining and reviewing recoros ,` ` /y`T~1 ~ / ~ (i C ~ ~ ~ ~ J ~ , l b / / ~/t'~ ( O c Legal research antl brie) writing ~ l h 7 - . ~ = d. Investigative and other vrork (Specify on additional sheets) O 1FNBPER HOl1R TOTAL HOURS = S S t~~ 21. ITEMIZATION OF REIMBURSABLE EXPENSES AMT. PER ITEM Mileage $.2$ per mile x To// ~Hatr~P s ,~ ~~~ /• iS ~?• 3a O 0 22. CERTIFICATION OF ATTORNEY/PAYEE Has compensation and/or reimbursement for work In thla case prsvloush/ been epplled foR ^ VES '~l NO Il yes, were you paid? ^ YES ~(NO If yea, bywhom were you psitl7 How muchT Nas the person represented paid any money to you, or to your knowledge anyone else, in connection with the maher for which you were appointed to provide representatianT ^ YES .~ NO ig v/~fetai on additional Shasta 1 swear or affirm the truth or corteetneaa A yr/ ~ ~,~/.. ~G~ of the above statements Spnalurs of may ayes L Date 26 nrvaovt bl ~ ~~ ~~i~ O///~ rui+ 6gnalura OI /~{////Y _ •d'A ~G I/ Z 660 ~»rr.Errr Judge - ~Dsta: wl C py 1 -Mail to ~ Administrator at completion of service It~%/ .J (/TrHQ ~T~ AMOUNTS CLAIMED Multiply rate per hour times total hours to obtain "In Coun" com~ penaetlon. Enter total below. 19A TOTAL IN COURT COMP. '$ /~~ 5c7 Multipy rate per hour limes total hour. Enter total "Out of Court' compensation below. 20A TOTAL OUT OF COURT COMP. 21A TOTAL ITEMIZED EXP. ° $ ~?' ~~ 23. ORAND TOTAL CLAIMED 24. DEDUCT. PRIOR PYMTS. _$ 25. NET AMOUNT CLAIMED _$ 3k~. ~ 27. AMT. APPROVED _$ 3s2.s b1Nb'i1~~lSNN?d AIN~~~^~ C~l''~~i~^N~(!~ zs :s ~a~ ~ - ~~w co ~" EXPLANATION OF CHARGES GREEN V. GREEN 94-1166 IN CUSTODY 9/1/99 Writ to Transport, Order & filing .50 @ 45.00 22.50 Subpoena witnesses .50 @ 45.00 22.50 10/5/99 Hearing research, doc. & exhibit prep. 2 @ 45.00 90.00 10/20/99 -Toll call from CCP/client 1 @ 1.15 1.15 10/22/99 Meet with client 1 @ 45.00 45.00 Meet with witnesses 1 @ 45.00 45.00 Hearing 2.5 @ 55.00 137.50 10/25/99 Toll call from CCP/client 1 @ 1.15 1.15 9/99-11/99 Numerous letters to client .50 @ 45.00 22.50 TOTAL 387.30 LONG DISTANCE CHARGES BILL FROM 717-243-5732 BILLED ON BEHALF OF VALUE-ADDED COMM REF DATE TIME PLACE CALLED 1 OCT 20 01:42:OOpm CARLISLE PA 2 OCT 25 10:54:OOam CARLISLE PA SUBTOTAL SUBTOTAL FOR 717-243-5732 TOTAL LONG DI r ~ ~; ^ ~ i 4 ~ i !~ ~ ~ / v~ I i tti ~4", ,~ NUMBER CALLED FROM PLAC~FRON NUBER CODE NIN ANOUHr~~ 717-243-5732 CARLISLE PAS 717-245-8787 ADS 4.0 1. 5 2.30! 2.30 ry AUTHORITY TO PAY COURT APPOINTED COUNSEL 1. COURT O District Justice ^ Common Pleas ^ Appellate ^ Other 3. FOR (D.J., C.P., APPE~~,,L/LA//T~E) 4. AT (CITY/STATE) 6. IN THE fk~BP .~X.Ch / ~4 <7 7. CHARGE/OFFENSE (PURDON CITATION) vs 9. PROCEEDINGS (Describe 6riefty) C, of s,~y ~,~~,~ ~4 ~, 10. PER~S/O/~N gEPRESENTED ((/Full Name) ~/ 11. PERSON REPRESENTED I ^ Detsndant-A4Wt 2 ^ Defendant-Juvenile ^ APPellanl 4 ^ APPellee 5 ^ Haoesa Petitioner 8 ^ Malarial Wnneaa T ^ Parolee Charged Wilh Violation B ^ ProbNianer Charged With Violation 9 ^ Olner. APPt Data /~ • ~ g~ ~~ ,,/r,~~81~ ~> rlY NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE f, , ~.'~1(i~ 2. VOUCHER _ N° -4646 ,~f "-~~° ~y I-moo 8. O PETTY OFFENSE ^ FELONYOMISDEMEANOR 12. CIVIL DOCKET NO. 9y-ii~ow / ~s~/1~ 13. CRIMINAL DOCKET NO. 14. APPEALS DOCKET NO. t 6. NAME OF ATTORNEY/PAYEE AND MAILING ADDRESS Lindsey Dare Baird 37 SouthP a ~~0~3 3307 Carlisle. 17. TELEPHONE No. av 3 - s`~ sa- CLAIM FOR SERVICES OR EXPENSES 19. SERVICE HOURS DATES a. Arraignment and/or Plea b. Preliminary Heating c Motlona and RsOwets d. Bail Hearings ~ e. Sentence Hearings U 2 f. Trial g. Revocation Hearings n. Juvenile Hearings i. Appeals ^OUrt ~ Other (Specify on additlonsl sheets) TOTAL HOU RS ~ HOUR 20. // a Interviews and conlerentee `~l(/Y,Y/COf S ~5~4!/ a/r~ • ~ aw/~~ ~ b Obtaining and reviewing records ~ ~ ~~ - 3 ~~~ O ¢ a Legal research and bnel wdtirp H7 O O a. Investlgative and other work (Spalaly gn additional sheen) TOTAL HOURSa ~ ~` ~Xyq PER HOUR 21. ITEMIZATION OF REIMBURSABLE EXPENSES AMT. PER ITEM Mileage 5.2/5_per mle x ~/ /' /T~ ~/~ ( /~ W ~/'lI~ (ri'lGL9 .( q.~ (rL'!~~`7 C «CJ".~ u/! / /'/-Sg'L~ ~c7' 11 .~ Q /~ / ~ f\ ~ V ~~p al Il.r v 22. CERTIFICATION OF ATTORNEY/PAYEE Has compensation and/or reimWrasmsnt for work In this use prsvlouay Veen spelled for? OYES ^ NO tl yes,were you paid? OYES ONO Itysa, bywhom wero you lxid7 How muehl Has the person repreaente0 paid any money to you, W to your knowledge anyone else, in connection with the mailer for which you were appointed to proNde repreaentatlon? OYES ONO II ye4 give details on additlonsl sheets I swear or affirm the truth or correctness of the above statements Sipnaturo d Atte)ney/Peys~ Date 28 nnonOVEO r ~ ~ ~ lJ run I S'~wra of \,~`/,~~ oayMENI Ju e ~(/,(_~ <~ -Dsta: ~ ~ I ~~, 217J( // / i ~f I t76py 1 -Mail to Court Administrator at completion of service 18. BOCIAL SECURITY NO ON EIN NO /y'aG ' TG • $i4 ~r AMOUNTS CLAIMED Multiply rate Per hour times total hours to obtain `In Coup' com~ penaetlon. Enter total below. 190. TOTAL tN COURT COMP. >< y Multiply rate per hour times total hours. Enter total `Out of Court" eompensetion below. 20A TOTAL OUT OF COURT COMP. s c~0,a7 . J j 210. TOTAL ITEMIZED EXP. `f /~ ll~~ 23. GRAND TOTAL CLAIMED 'f ~/5 : /S 24. DEDUCT. PRIOR PYMTS. =S 25. NET AMOUNT CLAIMED_ °f ~+/5 /J 27. AMT. APPROVED sf ~ 1~ r /~ H~i1 '~,~~~~~~ '~."~I c~ ~i.1 ~'~ ~ ~'" -ir,ir~'1 i, .J ' ~~. ~ ,..; - -. ~ , t,~ t i ~~ ~ -, Monthly statement; November 25, 2000 S of e Customer number 7'17-243-5732-547 SAT&T AT&T charges ~ Call 1-800-222-0400 for billing inquiries Sprint provides billing on behalf of AT&T. There is no connection between Sprint and AT&T. Please review alt charges appearing in this section. Any question regarding these charges should be referred to the number provided for billing inquiries. Summary of AT&T charges Long Distance aervicea Direct dial charges 717-243-5732 10.05 Taxes Federal tax .30 State tax .60 Total AT&T charges 510.95 Direct dial itemized rolls ~ : - Jbon'naaanlla. 1 Oct 11 3:26 P CARLISLE, PA 717-243-5732 Day 15.0 ,... 10.05 from PAYPHONE, PA 570-488-5722 Operator assist Total direct dial charges $10.05 -.~ ~~~~ Momhly statement: March 25, 2001 S of s Customer number 717-243-5732.847 Z~']D'- ZPDI charges r Call 1-888.509.0734 for billing inquiries Sprint provides billing on behalf of ZPDI. There is no connection between Sprint and ZPDI. Please review al! charges appearing in this section. Any question regarding these charges should be referred to the number provided for billing inquiries. Summary of ZPDI charges Charges billed on behalf of Value Added Comm Call 1-888-509.0734 for billing inquiries Long Distance aervicea Direct dial charges 717-243-5732 2.60 Total Value Added Comm charges $2.60 Taxes Federal tax .08 State tax .16 Tata12PD1 charges 52.84 Value Added Comm itemized ells ? /~ ~ ~//~1 ~ ,~ DireMdialitemizedcalls ,c .~ ~-2~p~%L- s'rZLI~~~""~~~ ` .. r I .~a..r:dla. 1 Mar 2 1:08 P CARLISLE, PA 717-243-5732 Day B.0 1.30 from CARLISLE, PA 717-245-8787 Operator assist 2 Marl 3:18 p CARLISI E PA 717 743-57"17 Day 2.0 1.30 ken CARL tSLF. PA i f7-2d5 8787 Opsr.irnr asst KRISTY M. GREEN, Plaintiff v. PAUL E. GREEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN CUSTODY NO. 1166 CIVIL 1994 PETITION TO WITHDRAW AS COUNSEL AND NOW COMES, Lindsay Dare Baird, Esquire, hereinafter referred to as petitioner who moves this Court to grant her motion to withdraw as counsel and in support thereof respectfully represents the following: On December 6, 1996, the court appointed Lindsay Dare Baird, Esquire to represent the defendant/respondent in his custody matter. 2. On September 1, 2002, the respondent was released from prison. 3. The respondent contacted counsel to assist him in visitation with his daughter. 4. Court appointed representation by Lindsay Dare Baird, Esquire, is no longer necessary because the respondent is back in the community and presumably able to work. 5. Lindsay Dare Baird, Esquire seeks to withdraw as counsel of record for the client. WHEREFORE, Lindsay Dare Baird, Esquire prays this Honorable Court to grant her motion to withdraw as counsel in the above-captioned matter. Respectfully submitted, m~say D Gird, Esquire 37 S. Hanover Street Carlisle, PA 17013 (717)243-5732 Petitioner and Attorney for Defendant cc: Mr. Paul E. Green Ms. Kristy M. Green I verify that to the best of my knowledge and belief, the statements in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS §4904 relating to unsworn falsification to authorities. t cw n/,qp Q.~4~~~~---- ' dsay Dare ~ ird, Es ire Petitioner KRISTY M. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW PAUL E. GREEN, Defendant NO. 94-1166 CIVIL TERM ORDER OF COURT AND NOW, this 19~' day of September, 2002, upon consideration of the Petition to Withdraw as Counsel, a Rule is hereby issued upon Plaintiff and Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of the date of this order. BY THE COURT, ~~~~ J~ esley Oler,,J , /Lindsay Dare Baird, Esq. 37 South Hanover Street Carlisle, PA 17013 /Kristy M. Green 3 Barry Circle Shippensburg, PA 17257 Plaintiff ~ Paul E. Green 32 East Main Street Newville, PA 17241 ~~ 9 ~~. 1/ ,Q~ 0~•\°1 :rc S ~ ?. ri i~ ~ ( ~ - "~!^~~ JV-~~' _ ~. ~. AUTHORITY TO PAY COURT APPOINTED COUNSEL URT 'trio Justice ^ Common Pleas ^ Appellate Q Other 1., C.P., APPELLATE) 4, AT (CITY/STATE) 4SE OF ~Y/S/rC~n/Y~J. ~yrrCil .. PROGEEOINGS (Describe Drielly) ~~~ti~ ~ ~r•~h~~a~ 10. PERSON REPREoSENT//E++D (Full Namal 7. CHARGE/OFFENSE (PURDON CITATION) 17. PERSON REPRESENTED t ~ Oerend.m ~ Adwt 2 ^ Oetendam ~Juvenils 7 ^ APPellBnt 0 ^ ADPellee 5 ^ Habeas Petitioner B ^ Malarial Wgness 7 ^ Parolee Charged Wilh Vlobtion 8 ^ Probeuoner Cnarged Wim Violation a ^ Omee APpt Oate is 'G • 9~. /. ~/~/ NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE N@V' ' ~ ~n~7 ~ -~` 2. VOUCHER - N° X5591 S. B/Uf~/GE'rr~ DE/ ~ / ~y S. Q PETTY OFFENSE ^ FELONY O MISDEMEANOR t2. CIVIL OOCIfET NO. C 4 s 1dd1r 9-s~ /i~G S 13. CRIMINAL DOCKET NO. 14. APPEALS DOCKET NO. t fi. NAME OF ATTORNEY/PAYEE AND MAILING ADDRESS Lindsey Dare Baird „"' auth Hanover Street 4a~ii:,;_•,'txµ 17013-3307 t7.TELEPHONE NO. ta. soaA~sECUartv HO OPEir+No a t/3 S~3a- /9~~7r~'a~•9 CLAIM FOR S ERVICES OR EXPENSES 19. SERVICE HOURS DATES AMOUNTS CLAIMED a. Arraignment and/or Plea Multipy rate per hour times total b. Preliminary Haaring hours to obtain "In Court" com~ penaatlon. Enler total below. G Motlona and Requests 6 Bail Hearings 'O e. Sentence Heannge O Z L Trial g. Revocation Mesringa h. Juvenile Heednge i Appaala Court 19A TOTAL IN COURT COMP. L Other (Specity on additional ahaatq TOTAL HOUR9. NSSD PER HOUR $ 20. _a InterVrewa arw conferences (~/C~~P/~~ /~/yr,~ ~ '~-S 9~0 ~ 9,00 Multiply rata per hour times total ' " LL ~/~q~G, 0. Oblaininq and rsviaw(ng records hours. Enter total Out of Coutt compeneatlon below O ¢ ~ C Legal rosearch and bdel wdting Q /~ /Grp-, ~j p ary~S '/ • ~r ~. SO C~/G - q~ yZ . O U d. Investlgatlva and other work (Specify on additional ah/ atal 20A TOTAL OUT OF COURT COMP. TOTAL HOURS : p~ . a,,~ ~ R HOl1R ' E /D /, ~ ~-"' 2t. ITEMRATION OF REIMBURSABLE EXPENSES AMT. PER ITEM M~age 5.25 Per mla _X__ _.. __._... ---._. _ _ / ,~/~9.t?(IC /YICt/ ~o G~~Q~nf~ ~!/~{,C~rI(~a<jf 'r7~~/d xa ~• ~`~ ~ / ,~~p /), ~1[^fj°p' [>/ ( 21 A TOTAL ITEM12E0 E%P. - _: g, g~ 22. CERTIFICATION OF ATTORNEY(PAYEE 23. 6RAN0 TOTAL CLAIMED Haa compensation and/or reim sment for work in this Ws previously t»en applied fo(! p YES ~NO : S //n /1 If yes,were you paid? OYES NO Rye4trywhom were you tMld7 How much? 24. DEDUCT, PRIOR OYMTS. Has the person represented paid a money to you, Or to your kn wipe anyone else, In connection with the mailer for S wnicn you were appointed to proWde representation? D YE3 NO 11-ye ylva tail on additional sheets f swear or all(rm the truth or cortadnass ~ AQ~~~ l~'/~ ' (h~,- 25. NET AMOUNT CLAIMEC7D of the above statements s /P ee rD~a1s *• S ~~(~ Q / 2g,nronuvtu~ \ N~V ~ ~ 2~2 27. AwMf.A/ QVED / ruu Sgnatura of q I'/ oAruEnt Judge - -Dets: . v Copy 1 -Mail to Court Administrator at completion of service CARLISLE MPO CARLISLE, Pennsylvania 170132935 09/17/2002 (800)275-8777 03:23:06 PM Seles Receipt Product Sala Unit Final Description Qty Price Price ISBURG .'A 17110 $0 F!rs ss Return . t $1.75 Cartified $2.30 Label Sarla. #: 000658916122 Customer Pos -$0.'37 Subtc '. .4.05 Issue PVI: -$4.0 i~IEWVILLE PA 17241 $0.3`~ First-Class Return Receipt $1.75 Cartifiied $2.30 Label Sari al #: ;0012510000658916146 Issue PVI: $4.42 SHIFPENSBURG PA 17257 $ .37 First-Class Return Rsceipt $1.75 Certified $2.30 Labei Sar~al #; 70012510000658916139 Issue PVI: $4 42+ Total: $12.as Paia bv: Cash $20.00 Change Due: -$7.11 Bill#: '_:000200921319 C1 ark: 02 Refunds anly per DMM P014 - Thank you for your 'ousiness - Customer Copy KRISTY M. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 96-1166 PAUL E. GREEN, :CIVIL ACTION-lJ4W Defendant : IN CUSTODY STIPULATION FOR CUSTODY iti STIPULATION made this .~=day of r'> , 2004, between Kristy M. Green, hereinafter referred to as Mother, and Paul E. Green, hereinafter referred to as Father. WHEREAS, the above-named Mother and Father had born to them the following child on the following date: Kaylee Green August 22, 1992 AND WHEREAS, the above-named Mother and Father desire to enter into a Stipulation as to the custody of the above-said child: NOW, THEREFORE, in order to effectuate the above purpose, the above-named Mother and Father hereby stipulate that: Mother and Father shall share legal custody Hof the child. 2. Father shall have primary physical custody oif the child. 3. Mother shall have partial physical custody of the child as agreed upon by both parents. 4. Father agrees not to file for child support. TO THIS PURPOSE, The parties hereto intend to be legally bound by the terms of this Stipulation and desire to have the Stipulation cr -~ indsay r Baird, Esquire %~~ -<~l Witness o '~i ~ JLL' r _ . ~ ry v`~~'e 1 ' ~ w ~ ~ ~C~~ ~ T r { 1 ~ $} (.~ ( J {~ O 1' ~, va o o A ~ yT- p Y A ~' KRISTY M. GREEN, Plaintiff v. PAUL E. GREEN, Defendant IN THE COURT' OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA yy _ ~1~~ MAY NO. CIVIL ACTION-IAW IN CUSTODY ORDER OF COURT dUl ~ 7 200'1 AND NOW, this~~ day of Neae+wl~er--~9@3; upon consideration of the attached custody stipulation with respect to the parties' child, Kayle~e Green, born August 22, 1992, the terms of the stipulation are entered as an order of court. BY THE COURT, 0 0 4 2004. J. Kristy M. Green 3 Barry Circle Shippensburg, PA 17257 Lindsay Dare Baird, Esquire 37 South Hanover Street Carlisle, PA 17013 Attorney for Father ,c~.u~ ~ L~ . b'itv4?tl,',S~L~4~~~? L ! :Z ~~'d 9- ~l~W h001 A~i~.~.CPJt~H1Gi~~ ~NL ~0 ~ i!:i~0-p31L~ 9~4- C01'nrnon weal~-h ~P PA q 30 °S ~hellenb~r~er, tennis R All Filings before ~Une I ~ , aoolo Have not been scanned! '"~ ~ ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT ~~~ aooo~~ ~~ - y3~ c, ~, ~ State Commonwealth of Pennsylvania OOriginal Order/Notice Co./City/Dlst. of CUMBERLAND (~ Amended Order/Notice Date of Order/Notice 06/09/06 O Terminate Order/Notice Case Number (See Addendum for case summary) RE:SHELLENBERGER, DENNIS R. EmployerM/ithholder's Federal EIN Number Employee/Obligor's Name (Last, First, Mp BRENNER MOTORS INC 1812-30 PAXTON ST HARRISBURG PA 17104 186-30-6875 Employee/Obligor's Social Security Number 3590000028 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ o . 0o per month in current support $ o. oo per month in past-due support Arrears 12 weeks or greater? Qyes ® no $ o . oo per month in current and past-due medical support $ o . oo per month for genetic test costs $ per month in other (specify) for a total of $ 0 . o o per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ o . o o per weekly pay period. $ o . oo per biweekly pay period (every two weeks). $ o. oo per semimonthly pay period (twice a month). $ o . oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 /N ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH RV MAN Date of Order: ~~~ ~ 9 Z~~s BY THE URT: ,. ~ a Form EN-028 Service Type M OMB No.:0970.0154 Worker ID 21205 ~-- ` ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ^ If checked you are required, to provide a copy of this form to your mployee. If your employee works in a state that is different from the state that issued this order, a copy must be provi~ed to your employee even if the box is not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee%bligor. 3.* . You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee%bligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2312656840 EMPLOYEE'S/OBLIGOR'S NAME: SHELLENBERGER, DENNIS R. EMPLOYEE'S CASE IDENTIFIER: 3590000028 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee%bligor from employment, refusing to employ, or taking disciplinary action against any employee%bligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/ob-igor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11.Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 Service Type M If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at f717) 240-6225 or by FAX at (717) 240-6248 or by Internet www.childsupport.state.pa.us Page 2 of 2 OMB No.: 0970-0154 Form EN-028 Worker ID 21205 i ..r ADDENDUM Summary of Cases on Attachment DefendandObligor: SHELLENBERGER, DENNIS R. PACSES Case Number 272000024 PACSES Case Number Plaintiff Name Plaintiff Name LORETTA H. SHELLENBERGER Docket Attachment Amount Docket Attachment Amount 94-930 CIVIL $ 0.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): ^ If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ o.oo Child(ren)'s Name(s): DOB ^ If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ o.oo Child(ren)'s Name(s): DOB ^ If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. DOB ^ If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ o.oo Child(ren)'s Name(s): DOB ^ If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ o.oo Child(ren)'s Name(s): DOB ^ If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. Addendum Form EN-028 Service Type M Worker ID 21205 OMB No.: 0970-0154 _...,, C; r., =~ 4~ u-, -f'7 c .~ 1 __ ~, r- - N ,,,„.~ _ -_ ° • __; ~ `~ ~. t ~: 94- 930 ~Omrnon ~~eal.-Fh ~ ~a ~S er ~he~len b~r~ All Filings before 0lune I ~ , cool, tennis (~ Have not been scanned! - . l ~ ~7~ 0000~~- "" ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 9~ - y3(~ C/ U/ C' State Commonwealth of Pennsylvania QOriginal Order/Notice CO./City/DISC. Of CUMBERLAND O Amended Order/Notice Date of Order/Notice 06/09/06 O Terminate Order/Notice Case Number (See Addendum for case summary) RE:SHELLENBERGER, DENNIS R. EmployerNVithholder's Federal EIN Number Employee/Obligor's Name (Last, First, MI) 186-30-6875 Employee/Obligor's Social Security Number BRENNER MOTORS INC 3590000028 1812-30 PAXTON ST Employee/Obligor's Caseldentifier HARRISBURG PA 17104 (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, Mq See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ o . oo per month in current support $ o . oo per month in past-due support Arrears 12 weeks or greater? Qyes ®no $ o . oo per month in current and past-due medical support $ o . oo per month for genetic test costs $ per month in other (specify) for a total of $ 0.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ o . o o per weekly pay period. $ o . oo per biweekly pay period (every two weeks). $ o . oo per semimonthly pay period (twice a month). $ o . oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. Date of Order: ~U~ ~ 9 ZQ{~s BY THE URT: ,, ~ a Form EN-028 Service Type M onnsNo.:o9~aoisa WorkerlD 21205 ~---• ' ~~ ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ^ If checked you are required. to provide a copy of this form to your mployee. If your employee works in a state that is different from the state that issued this order, a copy must be provi~ed to your employee even if the box is not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3.* . You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2312656840 EMPLOYEE'S/OBLIGOR'S NAME: SHELLENBERGER, DENNIS R. EMPLOYEE'S CASE IDENTIFIER: 3590000028 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Antidiscrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee%bligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. ~ 1.Submitted By: If you or your employee/obligor have any questions, DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT 13 N. HANOVER ST by telephone at (717) 240-6225 or P.O. BOX 320 by FAX at (717) 240-6248 or CARLISLE PA 17013 by Internet www.childsupport.state.pa.us Service Type M Page 2 of 2 Form EN-028 Worker ID 21205 OMB No.: 0970-0154 - ~- _. ADDENDUM Summary of Cases on Attachment Defendant/Obligor: SHELLENBERGER, DENNIS R. PACSES Case Number 272000024 Plaintiff Name LORETTA H. SHELLENBERGER Docket Attachment Amount 94-930 CIVIL $ 0.00 Child(ren)'s Name(s): DOB ^ If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ o.oo Child(ren)'s Name(s): DOB ^ If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ o.oo Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ o.oo Child(ren)'s Name(s): DOB ^ If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ o.oo Child(ren)'s Name(s): DOB ^ If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ o.oo Child(ren)'s Name(s): DOB ^ If checked, you are required to enroll the child(ren) ^ If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available identified above in any health insurance coverage available through the employee's/obligor's employment. through the employee's/obligor's employment. Addendum Form EN-028 Service Type M Worker ID 21205 OMB No.: 0970-0154 C'1 r..~ <'F'~ 'rR "~ -_ ,.. ~ ~s (-~ +,r r~ ° ~ ~, _ C.' ..` g~ _ r KRISTY M. GREEN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. PAUL E. GREEN DF,FENDANT 94-1166 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT ,AND NOW, Wednesday, April 25, 2007 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle _ on Friday, May 25, 2007 at 8:30 AM for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR. THE COURT. By: /s/ Hubert X. Gilroy, Esc~~~ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 pp~~-~~ ~j ~~ ~ l ~ ~aY~~~r~t'J i ~ ~1 ~ ~ cl ~; ~JO ~ZI ~d SZ ~d~ t(lOZ At~"v - C~i~v~.lU~d CHI ~0 ~ . 1 KRISTY M. GREEN, Plaintiff v. PAUL E. GREEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.94-1166 CIVIL ACTION -LAW IN CUSTODY Prior Judge: The Honorable J. Wesley Oler, Jr. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Kaylee N. Green, born August 22,1992. 2. A Conciliation Conference was held on May 25, 2007, with the following individuals in attendance: The mother, Kristy M. Green, with her counsel, Susan Spencer Abel, Esquire, and the father, Paul E. Green, with his counsel, Richard Gan, Esquire. 3. Based upon the recommendation of the Conciliator, the parties agreed to the entry of an Order in the form as attached. Date: May 30, 2007 C'} "',.' 3 ~~` ~ ..~ ~* r i ~ °~- ~-ra :~ .. ~ 7 G; '~ ~• JUN 0 5 20p,rt ~. KRISTY M. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. PAUL E. GREEN, N0.94-1166 CIVIL ACTION -LAW Defendant IN CUSTODY COURT ORDER AND NOW, this ~ day of ~~, 2007, upon consideration of the attached Custody Conciliation report, it is ordered and directed that this Court's Order of May 6, 2004, is vacated and replaced with the following Order: 1. The mother, Kristy M. Green, and the father, Paul E. Green, shall enjoy shared legal custody of Kaylee N. Green, born August 22, 1992. 2. The father shall enjoy primary physical custody of the minor child. 3. The mother shall enjoy periods of temporary physical custody of the minor child as follows: a. On Sunday afternoon from 1:00 p.m. unti15:00 p.m. for two Sundays in a row, and then the following two Sundays the mother will not have custody. The mother shall handle transportation for exchange of custody. b. At such other times as the parties may agree. 4. In the event either party desires to modify this Custody Order, that party may Petition the Court to have the case again scheduled with the Custody Conciliator for a conference. 5. In the event the mother makes arrangements to have counseling sessions scheduled for her and the minor child, the father shall ensure that the minor child participates in those counseling sessions with the understanding that the mother will handle the transportation for the sessions. The cost of the sessions that is not paid for by insurance shall be incurred by mother or mother's insurance. BY THE COURT, J cc: Suzanne Spencer Abel, Esquire _ Richard Gan, Esquire .rc.~.c.d ~ G ' ~/-d 7 to c~ r t.L7 ~~ ~ »' i -r ~-_. ~"' L t.i,_ _y_ i ~' g"=- L _ "~'= C...~ ~- ~ ~ _n ~ ::,.. - iI'.- ~ © ~ ...J l 3 N " 4 .~ KRISTY M. GREEN, Plaintiff v. PAUL E. GREEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.94-1166 CIVIL ACTION -LAW IN CUSTODY Prior Judge: The Honorable J. Wesley Oler, Jr. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Kaylee N. Green, born August 22,1992. 2. A Conciliation Conference was held on May 25, 2007, with the following individuals in attendance: The mother, Kristy M. Green, with her counsel, Susan Spencer Abel, Esquire, and the father, Paul E. Green, with his counsel, Richard Gan, Esquire. 3. Based upon the recommendation of the Conciliator, the parties agreed to the entry of an Order in the form as attached. Date: May 30, 2007 ~? ~ ~ ~ Q m c_. " ' ~ ' : ~ ~- ! ~ rr~t . ~ ~ ' ~ -ca i ~_ T . ~ ,3'' `~ .+~~ `N / Yy - ~y