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Home My WebLink About94-04305 ~ ! j v 11 - I \[) G r{)1 -::rl ] j ~) .e, ej ;J; a\,r) .9 ~~ -:::::r - ..... s: .. .... wt;<:=t:'~ ... u 3::"';1 ~ ;:O<..l-4 N ~~i:'~ N ' .. . ~ .t '" ',' ,: u1;IC ,_I ujZ - ",J tUbJ , ;-:. 2:1\.. g ...'"' ~ - 0'" , . . -.... ...:> ~ ""'"" ~ r<" \)0- r() .... f'("\ ~ '~ r\1 <::)~~ .; , . ~ :l 0 IZi ~ ; i 1~~ ~~~ . S h. Dnlln ERRAllllJ, SCIIIFFMAN III BROWN PC Sl'lIt 106 " ' . . 204UIJ~ilf_\Ill"'N R,ll....1l IIAUI\al'llli. rA 17110.?411} AU~ 0 4 .199~ dJv t. I ! 1 . . MICHAEL GILLESPIE, plaintiff : IN THE COURT OF COMMON PLEAS . . v. :CUMBERLAND COUNTY, PENNSYLVANIA No.tH- hj~i1,-"_,, ((;KIU CIVIL ACTION - LAW MICHELLE CAMERON, Defendant CUSTODY OROER OF COURT L/~ day of A.tJGt J,.;O , 1994, upon attached comPiilht, it is hereby directed their respective counsel appear before , the conciliator, at the 7"1 day of , 1994, at /..{ .m. for a Prehearinq Custody onference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to defiine and narrow the issues to be heard by the court, and to enter into a temporary order. Either party may bring the children who are the subject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. BY THE COURT: By: k....,,/ ~lI~L. -custody Concil tor 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 4th Fl., Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 , on ~ 'f Auc 'I 3 'Il fH '91/ " .' , i 'OffiCE OF '11r.. i " ~'"tHON"'T CU~~f(;L~111J OO(III~~t "'~"5tl 'A/J,/A ,. MICHAEL GILLESPIE, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. Civil, 1994 MICHELLE CAMERON, CIVIL ACTION - LAW . . Defendant : CUSTODY CUSTODY COMPLAINT TO THE HONORABLE, THE JUDGES OF SAID COURT: 1. The Plaintiff is Michael Gillespie, who currently resides at 3447 Green Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2, The Defendant is Michelle Cameron, who currently resides at 3806 pamay Drive, Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff seeks shared legal and primary physical custody of the parties' minor children, Kelly Leah Gillespie, born January 8, 1982 and Ryan Michael Gillespie, born September 27, 1985. 4. The parties previously entered into a Postnuptial Agreement dated April 12, 1989 in which Michelle Cameron was named as primary phsyical custodian. Said Agreement was incorporated into the Divorce Decree of the parties, Docket No. 3380 Civil, 1988, (See Exhibit A) 5. The children were not born out of wedlock. 6. The children are currently in a shared physical custody arrangement with the Defendant who resides at 3806 pamay Drive, Mechanicsburg, Pennsylvania, with alternating weeks of custody for both parties. . ' 7, During the past five years the children have resided with the following persons and at the following addresses: Persons Address Dates Michelle Cameron John Cameron (Stepfather) Michelle Cameron John Cameron (Stepfather) New Cumberland, PA 1989 3806 pamay Drive Mechanicsburg, PA 1990-Present 8, The relationship of Plaintiff Michael Gillespie to the children is that of father. The Plaintiff currently resides alone. 9. The relationship of Defendant to the children is that of mother. The Defendant currently resides with her husband and the children. 10. Plaintiff has not participated as a party, witness, or otherwise in litigation concerning the custody of the children, except as stated above. 11. Plaintiff has no information of a custody proceeding concerning the children pending in a Court of this Commonwealth, 12. 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. 13. The best interests and permanent welfare of the children will be served by granting the relief requested because the chldren's emotional and physical wellbeing is in jeoparty under the current custodial arrangement. 14. Each parent whose parental rights to the children have " ~ not been terminated and the person who has physical custody ot the children have been named as parties to this action, WHEREFORE, Plaintiff respectfully prays that Your Honorable Court award shared legal and primary physical custody ot the parties' minor children to the Plaintiff. Respectfully submitted, , Lor rratell , Esq, SE LLI, SCHIFFMAN & BROWN suite 106 2040 Linglestown Road Harrisburg, PA 17110-9483 (717) 540-9170 I.:~ .~.~~' 'I.; ,~; I verify that the statements made in this Complaint are true and correct. 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. ~jL.9... ~ Jt.'O,~~ MICHAEL GILL PIE - .. " -?Lf I',/f 1'1 MICHAEL GILLESPIE, Plaintiff IIN THE COURT OF COMMON PLEAS OF ICUMBERLAND COUNTY, PENNSYLVANIA v . , INO, 4305 - CIVIL - 1994 MICHELLE CAMERON, Defendant . . . , ICIVIL ACTION - CUSTODY o '" COURT O~ AND NOW, this { day of , 1994, consideration of the attached Cuseody Conc liation Report, ordered and directed as follows: upon it is 1. The parties shall submit themselves and the minor children to a custody evaluation by a professional as agreed upon by legal counsel for the parties. The purpose of this evaluation shall be to determine the current custody status and for the evaluator to make a recommendation with respect to a permanent Custody Order. The evaluator shall be deemed to be independent, with the final written recommendation being submitted to legal counsel for both parties. Cost of this evaluation shall be split equally between the parties. 2. Pending further Order of this Court or agreement between the parties, custody of the minor children shall be in accordance with the written agreement of the parties dated April 12, 1989, with the revision such that the Father's temporary custody on alternating weekends shall be expanded from Sunday evening until Monday morning at which time he shall deliver the children to school. 3. Upon the receipt of the custody evaluation and in the event the parties are not at that time able to reach an agreement, either party may petition the Court to have the case again scheduled with the Custody Conciliatior for a conference, cc: = c:J -.; <::> W .:::- ,.; -0 :.: - ~ .z:.. John W, Frommer, Esquire Lori Serratelli, Esquire- I c~ ~.!.J. /III l'It ..Lf', _.' ,. . .;1\." MICHAEL GILLESPIE, Plaintiff IIN THE COURT OF COMMON PLEAS OF ICUMBERLAND COUNTY, PENNSYLVANIA v . . INO. 4305 - CIVIL - 1994 I MICHELLE CAMERON, Defendant . . ICIVIL ACTION - CUSTODY CONCILIATION CONFBRENCB SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following reportl 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Kelly Leah Gillespie, born January 8, 1982, and Ryan Michael Gillespie, born September 27, 1985. 2. A Conciliation Conference was held on October 14, 1994, with the following individuals in attendance: The Father, Michael Gillespie, with his counsel, Lori K. Serratelli, Esquire, and the Mother, Michelle Cameron, who appeared with her counsel, John W. Frommer, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. /,hrl c.t/ ~ C)t;f- h_O""," SUIlATIUI. SCHiffMAN lie BlOWN. Poc. Sum 106 1040 I.lNULUnJWN J.uo\D IIAUUllJW,r'ft .n.;...;.a. 6__ ~ MICHAEL GILLESPIB, plaintift v.. MICHELLB CAMBRON, Detendant ~~ IN THB COURT OP COMMON PLEAS OP CUMBERLAND COUNTY, PENNSYLVANIA NO. 4305 CIVIL 1994 CIVIL ACTION - LAW CUSTODY llRA.CIP. TO THB PROTHONOTARY: You are directed to withdraw the CUstody Complaint tiled by the Plaintitt in the above-captioned matter, Dated: 3 -7 - )'J- i,- ~~~ ' , Serratelli, Bsquire TELLI, SCHIPFMAN , BROWN, P.C. 2040 Linglestown Road suite 106 Harrisburg, PA 17110 (717) 540-9170 ,,-----' IR - :5 .... 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