HomeMy WebLinkAbout02-3493MEGAN L. KOHLER
Plaintiff,
V.
CRAIG A. ROWLES,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
: CUSTODY
COMPLAINT FOR CUSTODY, PARTIAL CUSTODY OR VISITATION
1. The Plaintiff is Megan L. Kohler, residing at 1707 Linewood Drive, Camp Hill,
Cumberland County, Pennsylvania, 17011.
2. The Defendant is Craig A. Rowles, residing a HCR 67, box 0H9 Orchard Hills,
Mifflin, Juniata County, Pennsylvania, 17058.
3. Plaintiffs seek custody of the following children:
Name Present Residence A~e
Kaitlyn Elizabeth Rowles 1707 Linewood Drive 1 Year
Camp Hill, PA 17011
The child was bom out of wedlock.
The child is presently in the custody of Megan L. Kohler, whose currem address is 1707
Linewood Drive, Camp Hill, Pennsylvania, 17011.
During the past year, the child has resided with the following persons and at the following
addresses:
Pel~8ons
Megan L. Kohler, Bradley Kohler
Ruth Ann Kohler, Emily Kohler &
Benjamin Kohler
Addresses
1707 Linewood Drive
Camp Hill, PA 17011
Dates
6/1~/02 to
Present
Megan L. Kohler
& Craig A. Rowles
HCR 67, Box 0H9 Orchid Hills 5/02 to
Mifflin, PA 17058 6/02
Megan L. Kohler, Bradley Kohler 1707 Linewood Drive
Ruth Aun Kohler, Emily Kohler & Camp Hill, PA 17011
Benjamin Kohler
5/01 to
4/O2
The mother of the child is Megan L. Kohler, curremly residing at 1707 Linewood Drive,
Camp Hill, Pennsylvania 17011.
She is not married.
The father of the child is Craig A. Rowles, curremly residing at HCR 67, Box 0H9 Orchid
Hills, Mifflin, Pennsylvania 17058.
He is not married.
4. The relationship of Plaintiff to the child is that of mother. The Plaintiff currently
resides with the following persons:
Name Relationship
Kaitlyn Rowles Daughter
Bradley Kohler Father
Ruth Ann Kohler Mother
Emily Kohler Sister
Benjamin Kohler Brother
the following persons:
Name
None
The relationship of Defendant is that of father. The Defendant currently resides with
Relationship
6. Plalntiffhes 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.
Plaintiffhas no information of a custody proceeding concerning the child 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.
7. The best interests and permanent welfare ofthe child would he served by granting the
relief requested herein because, the mother has always been the child's primary caretaker and the
father is not capable of that responsibility.
3
8. Each parent whose paremal rights to the child has not been terminated and the person
who has physical custody of the child has been named as parties to this action. All other persons,
named below, who are known to have or claim a right to custody or visitation of the child will be
given notice of the pendency of this action and the right to intervene:
Name Address B__~.~.~_Clain2_
None
WHEREFORE, Plaintiffrequest the Court to grant custody, and legal custody oftbe child
as the Court deems appropriate.
(717) 238-3686
Supreme Court I.D. # 53729
4
VERll~ICATION
I, Megan L. Kohler, Plaintiff, verify that the facts set forth in the attached document are tree
and correct to the best of my knowledge, information and ~lief. I so state subject to the penalties
of 18 Pa. C. S. §4904 (relating to tmswom falsification to authorities).
Date Mel!lul~lb; Ko'liar~ ' '
I, Megan L. Kohler, Plaintit~ verify that the facts set forth in the attached document are true
and correct to the hest of my knowledge, information and belief. I so state subject to the penalties
of 18 Pa. C. S. ~4904 (relating to unswom fal.~cation to authorities).
DateJULY 18~ 2002 Meg~'~Kohl$~ ' -
MEGAN L. KOHLER :
PLAINTIFF :
CRAIG A. ROWLES
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
02-3493 CIVIL ACTION LAW
1N CUSTODY
F T
AND NOW, Friday, July 26, 2002 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator,
at 301 Market Street, Lemoyne, PA 17043 on Tuesday, September 03, 2002 at .10:30 AM
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 ora 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/ M¢lissa P. Greevy. 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
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
MEGAN L. KOHLER
Plaintiff,
V.
CRAIG A. ROWLES,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 02-3493 Civil
:
: CIVIL ACTION - LAW
: CUSTODY
AFFIDAVIT OF SERVICE PURSUANT TO PA. R. CIV. P. 405
I, Anthony T. McBeth, Esq., attorney for the Plaintiffin the captioned action, hereby swear
that I have served the Complaint upon Defendant in the captioned action by mailing a certified copy
of same to it addressed as follows: Craig A. Rowles, HCR 67, Box OH9 Orchard Hills, Mifflin, PA
17058. Said mailing was by first class mail, postage prepaid, certified, return receipt requested. Said
mailing was effected on August 5, 2002.
The return receipt, purportedly bearing the signature of the Defendant, and showing a delivery
date of August 6, 2002, is attached hereto, marked Exhibit "A" and incorporated herein by reference.
Date(~
~,nt~eth, Esq. - --
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item 4 if Restricted Deliv~j is desired.
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so that we can return the card to you.
· Attach this card to the back of the mailpiece,
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1. Article Acldressed to:
D. is daiive~ [] Yes
ff YES, enter delivery address below: n No
3. Service Type
~'Certlfiecl Mail [] Express Mall
[] Registered [] Rmum Receipt for Merchandise
[] Insured Mail r-I C.O.D.
4. Restricted Delive~ (Ex~ra Fee) n
2. ArticleN~umber (Copy fromserWce/abe/J _ __ . m
PS Form 381 1, July 1999 Domestic Return Receipt
ii,
102595'00'M~0952
EXHIBIT "A"
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
SS:
Sworn and subscribed before me this ~"~ day of ~ ~--
NOTARY PUBLIC ~J
,2002.
My commissions expires:
Notarial Seal
Melissa S. Snyder, Notary Public
Hanlsburg, Dauphin County
My Commission Expires Feb. 24, 2003
Member, Pennsylvania Associahon o~ hotaries
OCT ~ 5 ~'002 ~"
MEGAN L. KOHLER,
Plaintiff
V,
CRAIG A. ROWLES,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-3493 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
ORDER TO RELINQUISH JURISDICTION
AND NOW, this 10th day of October, 2002, the Conciliator having provided the parties a thirty
(30) day continuance in her Report on September 5, 2002, and the Conciliator having received no
further request for the Custody Conciliation Conference to reconvene, hereby relinquishes
jurisdiction of the above captioned matter.
~~squire
Custody Conciliator
:163760
MEGAN L. KOHLER
Plaintiff,
Vo
CRAIG A. ROWLES,
Defendant
: 1N THE COURT OF COM/VION PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 02-3493 Civil Term
:
: CIVIL ACTION - LAW
: CUSTODY
PLAINTIFF'S PETITION FOR CONCILIATION
The captioned action was filed on or about July 23, 2002.
Just prior to the scheduled date of conciliation by Melissa Peel Greevy, Attorney at Law,
Plaintiff and Defendant reconciled, and did not report as scheduled for the conciliation.
3. Since then, Plaintiff and Defendant have separated, and there is a need for pursuit of the
captioned action; accordingly, Plaintiff requests that the Court reappoint Melissa Peel Greevy,
Attorney at Law as conciliator and convene a conciliation.
4. All relevant facts, with the parties now separated again, are the same as they were when the
action was originally filed. A copy of the complaint that represented the original filing, showing the
parties' whereaboms and the residence of the child, is attached hereto, marked "Exhibit "A" and
incorporated herein by reference.
WHEREFORE, Plaintiffrequests this Honorable Court to reappoint Melissa Peel Greevy,
Attorney at Law as conciliator, convene a conciliation and provide any other relief this Court deems
appropriate.
' ony T. McBeth, ~q.
Attorney for Plaintiff/
407 North Front St4 Firs~Floor
Harrisburg, iPA 171~1
(717) 238-3586
Supreme Court I.D. # 53729
MEGAN L. KOHLER
Plainti~,
V.
CRAIG A. ROWLES,
Defendant
: 1N THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
:NO.
:
: CIVIL ACTION - LAW
: CUSTODY
ORDER OF COURT
AND NOW, , upon consideration of the attached Complaint, it is
hereby directed that the parties and their respective counsel appear before
, the Conciliator, on the day o:[ ,2002,
at__ .m., at the location of , Pennsylvania at
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 ora temporary or
permanent Order. '
FOR THE COURT:
By:.
Custody Conference Officer
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 befi>re the court, please contact our
office. All arrangements must 'be made at least 72 hours prior to any scheduled 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 LEGAd[, HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
EXHIBIT "A"
MEGAN L. KOHLER
Plaintiff,
V.
CRAIG A. ROWLES,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO.
:
: CIVIL ACTION - LAW
: CUSTODY
COMPLAINT FOR CUSTODY, PARTIAL CUSTODY OR VISITATION
1. The Plaintiff is Megan L. Kohler, residing at 1707 Linewood Drive, Camp Hill,
Cumberland County, Pennsylvania, 17011.
2. The Defendant is Craig A. Rowles, residing a HCR 67, box 0H9 Orchard Hills,
Mifflin, Juniata County, Pennsylvania, 17058.
Plaintiffs seek custody of the following children:
Name Present Residence
Age
Kaitlyn Elizabeth Rowles
1707 Linewood Drive
Camp Hill, pA 17011
1 Year
The child was bom out of wedlock.
The child is presently in the custody of Megan L. Kohler, whose current address is 1707
Linewood Drive, Camp Hill, Pennsylvania, 17011.
During the past year, the child has resided with the following persons and at the following
addresses:
Persons Addresses Dates
Megan L. Kohler, Bradley Kohler 1707 Linewood Drive 6/13/02 to
Ruth Ann Kohler, Emily Kohler & Camp Hill, PA 17011 Present
Benjamin Kohler
Megan L. Kohler HCR 67, Box 0H9 Orchid Hills 5/02 to
& Craig A. Rowles Mifflin, PA 17058 6/02
Megan L. Kohler, Bradley Kohler 1707 Linewood Drive 5/01 to
Ruth Ann Kohler, Emily Kohler & Camp Hill, PA 17011 4/02
Benjamin Kohler
The mother of the child is Megan L. Kohler, currently residing at 1707 Linewood Drive,
Camp Hill, Pennsylvania 17011.
She is not married.
The father of the child is Craig A. Rowles, currently residhag at HCR 67, Box 0H9 Orchid
Hills, Mifflin, Pennsylvania 17058.
He is not married.
4. The relationship of Plaintiff to the child is that of :mother. The Plaintiff currently
resides with the following persons:
Name Relationship
Kaitlyn Rowles
Bradley Kohler
Ruth Ann Kohler
Emily Kohler
Benjamin Kohler
'Daughter
Father
Mother
Sister .
Brother
o
the following persons:
Name
None
The relationship of Defendant is that of father. The Defendant currently resides with
Relationship
6. Plaintiffhas not participated as a party or witness, or in another capacity, in other
litigation concerning the custody of the child in this or another courl.
Plaintiffhas no information of a custody proceeding cor~cernJng the child pending in a COUrt
of this Commonwealth.
Plaintiffdoes 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.
7. The best interests and permanent welfare of the child would be served by granting the
relief requested herein because, the mother has always been the child's primary caretaker and the
father is not capable of that responsibility.
3
8. Each parent whose parental rights to the child has not been terminated and the person
who has physical custody of the child has been named as parties to this action· All other persons,
named below, who are known to have or claim a right to custody or visitation of the child will be
given notice of the pendency of this action and the right to intervene:
Name Address. Basis of Claim
None
WHEREFORE, Plaintiff request the Court to grant custody, and legal custody of the child
as the Court deems appropriate.
t onyT. McB .w~q.
(717) 238-3686
Supreme Cotu~ I.D. # 53729
4
VERIFICATION
I, Megan L. Kohler, Plaintiff, verify that the facts set forth in the attached document are true
and correct to the best of my knowledge, information and belief. I so state subject to the penalties
of 18 Pa. C. S. {}4904 (relating to unswom falsification to authorities):
Date
VERIFICATION
I, Megan L. Kohler, Plaintiff, verify that the facts set fon:h in the attached document are tree
and correct to the best of my knowledge, information and belie:[ I so state subject to the penalties
of 18 Pa. C. S. {}4904 (relating to unswom falsification to anthorities).
¢$1
MEGAN L. KOHLER
PLArN~FF
V.
CRAIG A. ROWLES
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:
02-3493 CIVIL ACTION LAW
:
: iN CUSTODY
ORDER OF COURT
AND NOW, Tuesday, August 05, 2003 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. _, the conciliator,
at 301 Market Street, Lemoyne, PA 17043 on Monday, September 08, 2003 at 8:30 AM
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 defme 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 l~resent at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permm~ent 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/ Melissa P. Greevy, 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 SttOULD TAKE TillS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
ItAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE SET
FORTH BELOW TO F1ND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
MEGAN L. KOHLER
Plaintiff,
V.
CRAIG A. ROWLES,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 02-3493 Civil Term
:
: CIVIL ACTION - LAW
: CUSTODY
_AFFIDAVIT OF SERVICE PURSUANT TO PA. R. CIV. P. 46.,
I, Anthony T. McBeth, Esq., attorney for the P/aintiffin the captioned action, hereby swear
that I have served the Complaint upon Defendant in the captioned action by mailing a certified copy
of same to it addressed as follows: Craig A. Rowles, 409 Main Street, Port Royale, PA 17082. Said
mailing was by first class mail, postage prepaid, certified, return receipt requested. Said mafiling was
effected on September 16, 2003.
The return receipt, purportedly bearing the signature o fthe Defendant, and showing a delivery
date of September 19, 2003, is attached hereto, marked Exhibit "A" and incorporated herein by
reference.
· Complete items 1, 2, and 3. Aisc complete
item 4 if Restricted Delivery is desired.
· Print your name and address on the reverse
so that we can return the card to you.
· Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
PawIt
(Transfer from service/abe~
PS Form 3811, August 2001 Domestic Return Receipt
[] Agent
[] Addresse~
Name)
address different from item 17 Yes
If YES, enter delivery address below: [] No
I 3. ~,ice Type
~,l~Certified Mail [] Express Mail
[] Registered [] Return Receipt for Merchandise
[] Insured Mail [] C,O.D.
4, Restricted Delivery? (Exl~a Fee) [] Yes
102595-01 -M-2509
EXHIBIT "A"
MEGAN L. KOHLER,
Plaintiff
V,
CRAIG A. ROWLES,
Defendant
OCT 0 g 2003¢
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-3493 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this [. O"~ day of October, 2003, upon consideration of the attached
Custody Conciliation Summary Report, it is hereby ordered and directed as follows:
1. Le.qal Custody. The parties, Megan L. Kohler and Craig A. Rowles, shall have
shared legal custody of the minor child, Kaitlyn Elizabeth Rowles, born May 14, 2001. Each
parent shall have an equal right, to be exercised jointly with the other parent, to make a~l
major non-emergency decisions affecting the child's general well-being including, but not
limited to, all decisions regarding her health, education and religion. Pursuant to the term~
of Pa. C. S. §5309, each parent shall be entitled to ail records and information pertaining tb
the child including, but not limited to, medical, dental, religious or school records, the
residence address of the child and of the other parent. To the extent one parent ha~
possession of any such records or information, that parent shall be required to share the
same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent.
2. Physical Custody. Mother shall have primary physical custody of the child
subject to Father's rights of supervised visitation which shall occur as follows:
Three (3) times per month, to occur on a Saturday or Sunday from 9:30
a.m. until 4:30 p.m. Mother shall supervise the visitation which shall occur at
the home of the Father or that of his parents. The parties will work
cooperatively to arrange the visits on a schedule that is mutually agreeable.
Appropriate consideration shall be given to the practicality of the visits should
inclement weather occur during the winter months. Under those
circumstances, the schedule may need to be rearranged to accommodate safe
travel. Mother will provide all transportation incident to these custodial visits.
3. The Custody Conciliation Conference shall reconvene on January 19,1
2004 at 1:00 p.m. at the office of the Custody Conciliator, MelJssa Peel Greevy,
Esquire, 301 Market Street, Lemoyne, PA 17043. It is contemplated at the time!
NO. 02-3493 CIVIL TERM
the Custody Conciliation Conference reconvenes that Father's request for overnight visits tO
be supervised by his mother will be considered. It is also contemplated that the
transportation arrangements incident to these periods of custody will be reviewed.
Dist:
BY THE COURT:
nthony T. McBeth, Esquire, 407 N. Front Street, 1st F oor, Harrisburg, PA 17101
raig A. Rowles, 409 Ma. in Street, Port Royal, PA 17082
MEGAN L. KOHLER,
Plaintiff
V.
CRAIG A. ROWLES,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-3493 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the child who is the subject of thi,,
litigation is as follows:
NAME
DATE OF BIRTH CURRENTLY IN THE CUSTODY OF
Kaitlyn Elizabeth Rowles May 14, 2001
Mother
2. A Custody Conciliation Conference was held on October 2, 2003 with theI
following individuals in attendance: the Mother, Megan L. Kohler, and her counsel,i
Anthony T. McBeth, Esquire; the Father, Craig A. Rowles, attended pro se. i
Date
3. The parties reached an agreement on a temporary custodial Order with thei
understanding that the Order would be reviewed at a Conciliation Conference to bel~
scheduled in January 2004. '
Custody Conciliator
:219223
MEGAN L. KOHLER,
Plaintiff
CRAIG A. ROWLES,
Defendant
JAN 2 ? 2004
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-3493 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
OLER, J. ---
ORDER OF COURT
AND NOW, this ~. ~,i~. day of ~,z2004, upon consideration of the attached
Custody Conciliation Summary Report, it is hereby ordered and directed as follows:
1. Legal Custody. The Mother, Megan L. Kohler, shall have sole legal custody of
the minor child, Kaitlyn Elizabeth Rowles, born May 14, 2001. However, Mother shall have
the affirmative duty to keep the Father, Craig A. Rowles, informed regarding the child's
general well-being including, but not limited to, the child's developmental progress and
health status.
2. Physical Custod__~. Mother shall have primary physical custody of the child
subject to Father's rights of supervised visitation which shall occur at such times and places
as the parties may agree.
3. In the event that Father is aggrieved by the terms of this Order, he shall retain
the right to petition the Court for a modification thereof and a Custody Conciliation
Conference wilI be scheduled in the usual course of business.
Dist:
BY THE COURT:
,i , j. Wesley ~er~Jr.,
/
/
Anthony T. McBeth, Esquire, 407 N. Front Street, 1st Floor, Harrisburg, PA 17101~
Craig A. Rowles, 409 Main Street, Po~ Royal, PA 17082
MEGAN L. KOHLER,
Plaintiff
V,
CRAIG A. ROWLES,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-3493 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3.8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH CURRENTLY IN THE CUSTODY OF
Kaitlyn Elizabeth Rowles May 14, 2001
Mother
2. A Custody Conciliation Conference was held on January 19, 2004 with the
following individuals in attendance: the Mother, Megan L. Kohler, and her counsel,
Anthony T. McBeth, Esquire. The Father, Craig A. Rowles, did not attend.
3. The Custody Conciliation Conference for this date was scheduled by mutual
agreement of the parties at their Conference on October 2, 2003. This Court's October 10,
2003 Order set the date, time and place for the Conference in Paragraph 3. The Order was
sent to the Defendant Father at the address which he confirmed at the October 2, 2003
Conference. The Conciliator met with Mother and her counsel for approximately 45
minutes. However, the Father did not call or attend the Conference.
4. Mother's position on custody is as follows: Mother is unwilling to expand on
Father's custodial time or agree to his contact with the child which is not supervised by
Plaintiff. She reports that since the October 2, 2003 Custody Conciliation, the child's Father
was hospitalized for six (6) days due to a suicide attempt made at a time when he
discontinued the use of his psychiatric medication. She reports that he has been swearing
in front of the child which he justifies by telling her that she will learn those words someday
anyway. Additionally, Mother reports that at the visit which occurred on January 11, 2004,
Father pulled the child's pants down as she was walking by him. This caused her to trip.
She reports that Father thought this was funny. Mother is concerned that this behavior is
inappropriate and that it will continue because she claims to have seen Father do the same
thing to his own mother on at least ten (10) occasions. Mother also reports that Father has
not been taking his medication since shortly before Christmas. She obtained this
information from Father's mother and the Defendant apparently confirmed this with her last
NO. 02-3493 CIVIL TERM
week. Mother also reports the Father has a history of incarceration for crimes related to
sexual contact with underage females. She reports that he was incarcerated for this
behavior for a substantial part of the child's first eleven (11) months of life. More recently,
she reports that Father has obtained his driver's license and has had recent police
interaction because of picking up minor females who were later identified as runaways.
Mother asked that the Order be modified to provide her with sole legal custody and
supervised partial custody as the parties agree.
5. Father's position on custody: Is not known to the Conciliator because he failed
to attend the Custody Conciliation Conference.
6. Because the Custody Conciliator met with Father at the time of the original
Custody Conciliation and the Conciliator has specific recollection of Father having confirmed
his treatment for bipolar illness both on an inpatient and outpatient basis, the Conciliator
finds it to b~ appr?priate to issue the recommended Order a,~a~hed.
O te Melissa Peel Greevy, Esquire I
Custody Conciliator
:223287