HomeMy WebLinkAbout02-3278 IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
BARBARA A. MERREL,
Plaintiff
DENNIS E. MERREL,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
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 decree of divorce or annulment may be entered against you by the court. A
judgement may also be entered against you for any other claim or relief requested in these papers by the
Plaintiff. You may lose money or property or other rights important to you, including custody or
visitation of your children.
When grounds for the divorce is indignities or irretrievable breakdown of the marriage, you may
request marriage counseling. A list of marriage counselors is available in the office of the Prothonotary
at Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S
FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE
THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
717-249-3166
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
BARBARA A. MERREL,
Plaintiff
DENNIS E. MERREL,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE UNDER
SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE
AND NOW, comes the above named Plaintiff, Barbara A. Merrel, by and through her attorneys,
Weigle & Associates, P.C., and Richard L. Webber, Jr., Esquire, and seeks to obtain a Decree in
Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth:
Plaintiff, Barbara A. Merrel, is an adult individual presently residing at 11 Larch Drive,
Shippensburg, Cumberland County, Pennsylvania 17257, since August 2001.
Defendant, Dennis E. Merrel, is an adult individual presently residing at 11 Larch Drive,
Shippensburg, Cumberland County, Pennsylvania 17257, since August 2001.
The Plaintiff and Defendant are nationals and citizens of the United States of America, and both
have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months
immediately previous to the filing of the Complaint in Divorce.
4. The Plaintiff and Defendant were married on August 6, 1988, in Akron, Ohio.
5. There have been no prior actions of divorce or for annulment between the parties.
Plaintiff has been advised that counseling is available and the Plaintiff may have the right to
request that the court require the parties to participate in counseling.
7. The marriage is irretrievably broken.
Although presently residing at the same address, the parties have lived separate and apart since
January 1, 1999.
WEIGLE & ASSOCIATES, AC. ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397
9. The Plaintiff requests the court to enter a decree of divorce.
WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the
bonds of matrimony and for such other and further relief to which Plaintiff shall be entitled.
WEIGLE & ASSOCIATES, P.C.
By:
Richard L. Webber, Jr., Esquir~
Attorney for Plaintiff
Attorney ID #49634
126 East King Street
Shippensburg, PA 17257
Telephone 717-532-7388
WEI(3LE ~ ASSOCIATES, RC, ATTORNEYS AT LAW -- 126 EAST KING STREET SHIPPENSBURG, PA 17257-1397
VERIFICATION
I verify that the statements made in the foregoing Complaint in Divorce are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa C.S. § 4904, relating to
unswom falsification to authorities.
Dated:
Barbara A. Merrel, Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
BARBARA A. MERREL,
Plaintiff
DENNIS E. MERREL,
Defendant
CIVIL ACTION - LAW
NO. 02-3278 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA :
:
COUNTY OF CUMBERLAND :
SS
Patricia A. Frey, being duly sworn according to law, deposes and says that on July 17, 2002, a
tree and attested copy of Complaint in Divorce and Notice to Defend and Claim Rights was served
upon the Defendant, Dennis E. Merrel. Manner of service: by mailing the same postage paid, certified
mail, addressee only, and return receipt requested, at Shippensburg, Pennsylvania, addressed as follows:
11 Larch Drive, Shippensburg, PA 17257
The return receipt signed by the Defendant is evidence of delivery to him and is attached hereto
as "Exhibit A."
Patricia A. Frey
Sworn to and subscribed before
me this 22nd day of July, 2002.
Notary Public
"'-~ .......... :0 ~
~-..' ,~-"~ -. ~ '.
NotarialS .
Palrida LTome, Nolapj Pul~c
_8~em~urg Boro. Cumberland County
M~ Commi~ion Expires June 7, 2004
WEIGLE & ASSOCIATES, RE. -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
BARBARA A. MERREL,
Plaintiff
DENNIS E. MERREL,
Defendant
CIVIL ACTION - LAW
NO. 02-3278 CIVIL TERM
IN DIVORCE
PROOF O~ ~RVICE
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Re~um Receipt Fee
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Total Postage & Fees
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Dennis E. Merrel
Street, Apt. No.; or PO Box No.
1I Larch Drive
PA 17257
07/16/2002
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Rem 4 If Restricted O~llv~y la ckS.
· Pflnt your name and ad~maa on the reveme
so that we can return the card to you.
· Attach this card to the back of the mallptece,
1. Ntlcle ~ to:
Dennis E. Merrel
11 Larch Drive
Shippensburg, PA 17257
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~IBIT "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
BARBARA A. MERREL, : CIVIL ACTION - LAW
Plaintiff :
:
v. : NO. 02-3278 CIVIL TERM
DENNIS E. MERREL, :
Defendant : IN DIVORCE
AFFIDAVrY OF CONSENT
1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on July 11, 2002.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed
from the date of filing and service of the Complaint.
3. I consent to the entry of a fmal decree of divorce after service of notice of intention to request
entry of the decree.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unswom
falsification to authorities.
Barbara A. Merrel, Plaintiff
WEIGLE En ASSOCIATES, ~C. -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
BARBARA A. MERREL,
Plaintiff
DENNIS E. MERREL,
Defendant
CIVIL ACTION - LAW
NO. 02-3278 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER ~ 3301(e) AND § 3301(d) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or
expenses if I do not claim them before a divome is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a
copy of the decree will be sent to me immediately after it is filed with the prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn
falsification to authorities.
Dated:
Barbara A. Merrel, Plaintiff
WEIGLE & ASSOCIATES, P.C. -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
BARBARA A. MERREL,
Plaintiff
DENNIS E. MERREL,
Defendant
CIVIL ACTION - LAW
NO. 02-3278 CIVIL TERM
IN DIVORCE
statements herein are made
falsification to authorities.
AFFIDAVIT OF CONSENT
A complaim in divorce under § 3301(c) of the Divorce Code was filed on July 11, 2002.
The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed
from the date of filing and service of the Complaint.
I consent to the entry of a final decree of divorce after service of notice of intention to request
entry of the decree.
I verify that the statements made in this affidavit are tree and correct. I understand that false
subject to the penalties of 18 Pa. C.S. § 4904 relating to unswom
Dated:
De'~-~E. Merrel, Defendant
WEIGLE & ASSOCIATES, P.C. -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
BARBARA A. MERREL,
Plaintiff
DENNIS E. MERREL,
Defendant
CIVIL ACTION - LAW
NO. 02-3278 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO RE UEST ENTRY OF A
DIVORCE DECREE UNDER 3301 e AND 3301 d OF THE DIVO CE CODE
I. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or
expenses ifI do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a
copy of the decree will be sent to me immediately after it is filed with the prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn
falsification to authorities.
Dennis E. Merrel, Defendant
WEIGLE & ASSOCIATES, P-C. -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
BARBARA A. MERREL,
Plaintiff
DENNIS E. MERREL,
Defendant
To the Prothonotary:
CIVIL ACTION - LAW
NO. 02-3278 CIVIL TERM
IN DIVORCE
.PRAECIPE TO TRANSMIT RECORB
decree: Transmit the record, together with the following information, to the court for entry of a divorce
Grounds for divorce: irretrievable breakdown under § 3301 (c) of the Divorce Code.
Date and manner of service of the complaint: July 17, 2002, by mailing postage paid, certified
mail, addressee only, and return receipt requested at Shippensburg, Pennsylvania.
Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Cod,::
by Plaintiff, October 16, 2002; and by Defendant, October 16, 2002.
Related claims pending: None
Date Plaintiff's Waiver in § 3301(c) Divorce was filed with the prothonotary:
October 21, 2002
Date Defendant's Waiver of Notice in § 3301 (c) Divorce was filed with the prothonotary:
October 21, 2002
WEIGLE & ASSOCIATES, P.C.
Richard L. Webber, Jr., Esq~re /
Attorney for Plaintiff
Attorney ID # 49634
126 East King Street
Shippensburg, PA 17257
Telephone (717)532-7388
WEIGLE & ASSOCIATES, RC. -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397
BARBARA A. HERREI.,
Plaintiff
VERSUS
DENNIS E. I~RREL,
Defendznt
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
NO. 02-3278
DECREE IN
DIVORCE
AND NOW,
,_200?, It '$ ORDERED AND
DECREED THAT
BARBARA A. t4ERREL
__, PLAINTIFF,
AND
DENIqXS E. HERREL
, DEFENDANT,
ArE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JurISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD iN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YEt BEEN ENTERED;
~o~e
BY THE COURT://~/ .
~~ PROTH O NOTARi'
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
BARBARA A. MERREL, : CIVIL ACTION - LAW
Plaintiff :
v. : NO. 02-3278
DENNIS E. MERREL, :
Defendant : IN CUSTODY
COMPLAINT FOR CUSTODY
The Plaintiff is Barbara A. Merrel, presently residing at 11 Larch Drive, Shippensburg,
Cumberland County, Pennsylvania 17257.
The Defendant is Dennis E. Merrel, presently residing at 15850 North Thompson Peak Parkway
1105, Scottsdale, Arizona 85260.
Plaintiff seeks custody of the following children:
NAME
Jennifer Madilyn Merrel
PRESENT RESIDENCE
11 Larch Drive
Shippensburg, PA 17257
AGE
11 years
DOB: 3/16/92
Ian Matthew Merrel
11 Larch Drive
Shippensburg, PA 17257
9 years
DOB: 10/5/93
The children were not bom outside the bonds of matrimony.
The children are presently in the custody of Plaintiff, who resides at 11 Larch Drive,
Shippensburg, Pennsylvania 17257.
During the past five years, the children have resided with the following persons and at the
following addresses:
NAME
Barbara A. Merrel
Jennifer M. Merrel and
Ian M. Merrel
ADDRESS
11 Larch Drive
Shippensburg, PA 17257
DATE
December 2002
to present
WEIGLE & ASSOCIATES. P,C.-- ATTORNEYS AT LAW -- 426 F--~ST KING STREET -- SHIPPENSBURG, PA 17257-1397
o
Barbara A. Men'el
Dennis A. Merrel
Jennifer M. Merrel
Ian M. Merrel
and
11 Larch Drive
Shippensburg, AP 17257
August 2001
to December, 2002
Barbara A. Merrel
Dennis A. Merrel
Jennifer M. Merrel
Ian M. Merrel
and
306 East Orange Slreet
Shippensburg, PA 17257
1998 to
July 2001
The mother of the children is Barbara A. Merrel, currently residing at 11 Larch Drive,
Shippensburg, Pennsylvania 17257. She is divorced from Defendant and single.
The father of the children is Dennis E. Merrel, currently residing at 15850 North Thompson Peak
Parkway 1105, Scottsdale, Arizona 85260. He is divorced from Plaintiff and single.
The relationship of Plaintiff to the children is that of natural mother. The Plaintiff currently
resides with the following persons:
NAME
Jennifer Madilyn Merrel
Ian Matthew Merrel
RELATIONSHIP
daughter
son
The relationship of Defendant to the children is that of natural father. The Defendant currently
resides with the following persons:
NAME
Judith (last name unknown)
Jared (last name unknown)
RELATIONSHIP
Girlfriend
Girlfriend's son
Plaintiff has participated as a party or witness, or in another capacity, in other litigation
concerning the custody of the children in this or another court.
Plaintiff has no information of a custody proceeding concerning the children pending in a court
of this Commonwealth.
Plaintiff does not know of a person, not a party to the proceedings, who has physical custody of
the children or claims to have custody or visitation rights with respect to the children.
The best interest and permanent welfare of the children will be served by granting the relief
requested because:
A. Plaintiff has been the primary caretaker of the children since birth.
B. The children presently reside with Plaintiff
C. Plaintiff is better able to care for the needs of the children.
D. Defendant resides in Arizona.
WEIGLE & ASSOCIATES. RC. -- ATTORNEYS AT LAW -- 126 EAST KING STRI--ET -- SHIPPENSBURG, PA 17257-1397
o
Each parent whose parental rights to the children have not been terminated and the person who
has physical custody of the children have been named as parties to this action.
WHEREFORE, Plaintiff requests the Court to grant both legal and primary physical custody of
the minor children to the Plaintiff.
WEIGLE & ASSOCIATES, P.C.
By:
Richard L. Webber, Jr., Esquir~
Attorney for Plaintiff
I.D.#49634
126 East King Street
Shippensburg, PA 17257
Telephone 717-532-7388
WEIGLE & ASSOCIATES, P.C.-- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397
VERIFICATION
I verify that the statements made in the foregoing Complaint for Custody 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)ated: ~/Jl ~,'! t) $
BARBARA A. MERREL
WEIGLE & ASSOCIATES, P.E.-- ATTORNEYS AT LAW -- 126 EAST KING STREET --SHIPPENSBURG, PA 17257-1397
BARBARA A. MERREL :
PLAINTIFF :
DENNIS E. MERREL
:
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
02-3278 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Wednesday, April 30, 2003 , upon. consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, June 05, 2003 at 2:00 PM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT.
By: /s/ Hubert X. Gilroy, Esq. ·
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our office.
All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must
attend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN' GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
BARBARA A. MERREL,
Plaintiff
DENNIS E. MERREL,
Defendant
CIVIL ACTION - LAW
NO. {}2-3278
IN CUSTODY
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA '
COUNTY OF CUMBERLAND '
SS
Patricia A. Frey, being duly sworn according to law, deposes and says that on May 9, 2003, a
true and attested copy of Order of Court was served upon the Defendant, Dennis E. Merrel. Manner of
service: by mailing the same postage paid, certified mail, addressee only, and return receipt requested, at
Shippensburg, Pennsylvania, addressed as follows:
Dennis E. Merrel
15850 North Thompson Peak Parkway 1105
Scottsdale, AZ 85260
The return receipt signed by the Defendant is evidence of delivery to him and is attached hereto
as "Exhibit A."
Patricia A. Frey
Sworn to and subscribed before
me this 13th day of May 2003.
Notary Public
Patricia I_Tome, Notary Public .
Shlemmabu~ Boro, Cumbeda~l CountY
-l~3mmis~on Expires June 7, 2004
WEIGLE & ASSOCIATES, P.C.-- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
BARBARA A. MERREL,
Plaintiff
DENNIS E. MERREL,
Defendant
CIVIL ACTION - LAW
NO. 02-3278
IN CUSTODY
PROOF OF SERVICE
RLW Postage
025'/
MF, P~E~]gtified Fee I~ Postmark
Here
Return Receipt Fee
(Endorsement Required)
Restricted Delivery Fee
(Endorsement Required)
Total Postage & Fees ~'8.38 05ttOStt~13
Sent To
Mr. D~nnis E. Merrell
Street, Apt. No.; , ,
~om~.15850 N. Thompson Peak Pkwy 1105
.~..~,.~,. ~p~- .........................................................................
Scottsdale, Arizona 85260
· ~ Rm~ 1, 2, and 3. Aim) cemglete
~ 4 if Restricted Delivery is de~.
· Pfln~ your name and address on ~ reveme
· o that we can return the card to you.
· Attach this card to the back of the mailpiece,
or o~ the front if space permits.
1. Article Addressed to:
Mr. Dennis E. Merrell
15850 N. Thompson Peak Pkwyll05
Scottsdale, Arizona 85260
eceived by (Printed Name)
D. Is de#very address d item 17
If YES, enter delivery address below:
]~
of ~
r-I yee
[] No
RESTRICTED
~Certifled Mail I-I Express Mail
[] Registered [] Return Receipt for Merohandllm
I-1 Insured Mail [] C.O.D.
· Restricted Delivery? (Extra Fee)_
WEIGLE & ASSOCIATES, P.C. -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397
BARBARA A. MERREL,
Plaintiff
V
DENNIS E. MERREL,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
:
: NO. 02 - 3278 CIVIL
: IN CUSTODY
CO~TO~ER
AND NOW, this l! .~t day of June, 2003, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
The Mother, Barbara A. Merrel, and the Father, Dennis E. Merrel, shall
enjoy shared legal custody of Jennifer M. Merrel, born March 16, 1992; and
Ian M. Merrel, born October 5, 1993.
2. Mother shah enjoy primary physical custody of the minor children.
Father shall enjoy periods of temporary physical custody with the minor
children as follows:
Ae
For a period of at least three (3) weeks during the summer months
when children may visit Father in Arizona. Father shall pay the costs
of transportation in order to have the children delivered to and from
Arizona.
In the event Father is in the Shippeusburg area and gives Mother at
least four (4) days notice in advance, Father shall have the opportunity
to enjoy reasonable periods of custody with the minor children to
include overnight visitation.
C. At such other times as agreed upon by the parties.
In the event counsel for the parties desire to address any other issues with the
conciliator, counsel for the parties may contact the conciliator directly and
schedule a telephone conference call between the attorneys and the conciliator.
5. The children shall not be left alone with the Maternal Grandfather.
Each parent shall enjoy reasonable telephone contact with the minor children
when they are in the custody of the other parent.
CC:
Richard L. Webber, Jr., Esquire
Joan Carey, Esquire
BY THE COURT,
BARBARA A. MERREL,
Plaintiff
DENNIS E. MERREL,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION- LAW
:
: NO. 02 - 3278 CIVIL
: IN CUSTODY
Prior Judge:
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF
PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following
report:
The pertinent information pertaining to the children who are the subject of this
litigation is as follows:
Jennifer M. Merrei, born March 16, 1992; and Ian M. Merrel, born October 5,
1993.
A Conciliation Conference was held on June 5, 2003, with the following individuals in
attendance:
The Mother, Barbara A. Merrel, with her counsel, Richard L. Webber, Jr., Esquire;
and Attorney Joan E. Carey who appeared on behalf of the Father, Dennis E.
Merrel.
The parties separated in December of last year, but were divorced in October of last
year. Recently Father has relocated to Arizona. Mother indicates Father developed
a romantic interest with a woman in Arizona and that was the basis for the
relocation. Father had been working in Harrisburg and living in Cmnberland
County for the past few years.
Attorney Carey suggested that Father may seek primary physical custody of the
minor children. We attempted to get the Father on the phone for a
conference/speaker call arrangement. Although Mr. Merrel had represented to his
attorney that he would be available during the time of the custody conciliation
conference, we were unable to reach him by phone.
There is an issue with respect to the children going to Arizona. Mother wanted to
make sure there was a custody order in place befor~ she would allow the children to
visit their Father. The conciliator will recommend an order addressing an
opportunity for the children to visit Father. If Father intend to pursue primary
physical custody of the minor children, counsel for the Father can contact the
conciliator and initiate another custody conciliation conference via a telephone
conference call between counsel and the conciliator.
6. The conciliator recommends the entry of an order in the form as attached.
bert X. ~tilroy,~ Esquire
Custody Conciliator