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DAWNA J. FRAKER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
Va. NO. 94- (p g CIVIL TERM
JIMMIE L. GEORGE,
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, upon consideration of the a cached Petition it is hereby directed that the parties
and their r spe?ive counsel appe r before - u bsf r G ? ? rc' ` Esquire, the Conciliator,
on the 1) `I day of V e, Fm b,- r 1994, at 51:,-0 o'clock -fL. M., in
t?jtl 100< <??b• LLLo•[[[u.?h°Ns?" Cumberland County, Pennsylvania, 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 shall/may also be present at the Conference.
Failure to appear at the Conference may provide grounds for the entry of a Temporary or Permanent
Order.
By the Court,
Date: 1 0 t/
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 FORM
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator, Fourth Floor
Cumberland County Court House
Carlisle, Pennsylvania 17013
(717) 240-6200
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DAWNA J. FRAKER,
Plaintiff
Va.
JIMMIE L. GEORGE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
NO-94- 5(y CIVIL TERM
IN CUSTODY
1. The Plaintiff Is Dawna J. Fraker, residing at 4141 Enola Road, Newville, Cumberland
County, Pennsylvania.
2. The Defendant Is Jimmie L George, residing at 2 West Middlesex Drive, Carlisle,
Cumberland County, Pennsylvania.
3. The Plaintiff seeks custody of Karissa Ann George, born January 12, 1994).
The child was born out of wedlock.
The child is presently in the custody of mother, Dawna J. Fraker, who resides at 4141 Enola
Road, Newville, Cumberland County, Pennsylvania.
During the past five years, the child has resided with the following persons and at the
following addresses: Dawna J. Fraker, mother, Barbara Fraker, grandmother and Donald Fraker,
grandfather, at 4141 Enola Road, Newville, Cumberland County, Pennsylvania.
The mother of the child is Dawna J. Fraker, currently residing at 4141 Enola Road, Newviile,
Cumberland County, Pennsylvania.
She Is unmarried.
The father of the child is Jimmie L George, currently residing at 2 West Middlesex Drive,
Carlisle, Cumberland County, Pennsylvania.
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He is unmarried.
a. The relationship of the Plaintiff to the chiles Is that of mother. The Plaintiff currently
resides with the following people:
Barbara Fraker
Donald Fraker
Mother
Father
5. The relationship of the Defendant to the child is that of father.
The Defendant currently resides with the following person:
Ross George
Carol George
Father
Mother
8. Plaintiff has not participated as a party or witness, or in any other capacity In other
litigation concerning the custody of the child in this or another Jurisdiction.
7. The Plaintiff has no information of a custody proceeding concerning the child pending
in a court of the Commonwealth.
8. The 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 chffd.
9. The best Interest and permanent welfare of the child will be served by granting ft
relief requested because:
a) The Plaintiff can best provide for the physical and emotional
needs of her child.
b) Since birth, Plaintiff has been the primary caretaker of her child.
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10. Each parent whose parental rights to the child have not been terminated and the
person who has physical custody of the child has been named as parties to this action.
WHEREFORE, the Plaintiff requests this Court to grant primary physical custody of the child
to the Plaintiff.
Respectfully submitted,
FLOWER, MORGENTHAL FLOWER & LINDSAY
Attorneys for Plaintiff
Y?
Date:
3 11
1l East High SUM
Carlisle, PA 17013
(717) 243.6613
t.
I, the undersigned, hereby verify that the statements made herein are true and correct.
I understand that false statements herein are made subject to the penalties of IS Pa. C.S. I
4904, relating to unworn falsification to authorities.
Dawna J. FrAer
Date: 7 /
2
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OCT 4 1994 (34,
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LiLu J"! Izi J4
DAWNA J. FRAKER, :IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
:
v :NO. 5618 - CIVIL - 1994
:
JIMMIE L. GEORGE, :
Defendant :CIVIL ACTION - CUSTODY
COURT ORDER
AND NOW, this 3u' day of , 1994, upon consideration of
the attached Custody Conciliat on Report, it is ordered and
directed as follows:
1. The Mother, Dawns J. Fraker, and the Father, Jimmie L. George,
shall enjoy shared legal custody of Karissa Ann George, born
January 12, 1994.
2. The Mother shall have primary physical custody of the minor
child.
3. The Father shall have physical custody of the minor child as
follows:
A. On alternating weekends on each Saturday and Sunday from
noon until 7:30 P.M. Starting the weekend of December 17,
the Father shall have custody on that weekend as set forth
above.
B. Two days a week, being weekdays, from 9 A.M. until 4 P.M.
The days for the Father's custody shall be agreed upon
between the parties. Absent an agreement between the
parties, the days shall be Tuesday and Friday.
4. The Father shall always have custody on Father's Day and tha
Mother shall always have custody on Mother's Day. This
provision shall supersede any other provision of this Order.
5. The Father shall also enjoy temporary custody on every major
holiday from 2 P.M. until 8 P.M. These holidays shall include
Christmas Day, New Years Day, Easter, Memorial Day, July 4th,
Labor Day, and Thanksgiving.
6. The parties shall arrange for the Father to have temporary
custody of the minor child on the child's birthday. In 1995,
the Father shall have custody of the child from 4 P.M. until
8 P.M. on the child's birthday.
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7. The parties may modify the above schedule as they may agree to
afford Father a reasonable opportunity to have additional
periods of temporary custody with the minor child.
8. Father shall handle all transportation for exchange of custody.
9. The parties agreed that the only babysitters for the minor
child, except in periods of emergency, shall be the Father,
Mother, and the Grandparents.
10. This Order is entered pursuant to an agreement of the parties
reached at a Custody Conciliation Conference. Either party
may petition to have this Order modified upon a change of
circumstances or upon either parent determining that the
Order should be modified in any way based upon the advanced
age of the child or other reasons.
BY THE COURT,
cc: Carol J. Lindsay, Esquire jd4"L,.,; ? '/31955
Arthur T. McDermott, Esquirer
a
j.
DAWNA J. FRAILER,
Plaintiff
v
JIMMIE L. GEORGE,
Defendant
sIN THE COURT OF COMMON PLEAS OF
sCUMBBRLAND COUNTY, PENNSYLVANIA
t
tNO. 5618 - CIVIL - 1994
t
s
:CIVIL ACTION - CUSTODY
CONCILIATION CONFXRWCE SUWARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL 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:
Rarissa Ann George, born January 12, 1994.
2. A Conciliation Conference was held on December 15, 1994, with
the following individuals in attendance:
The Mother, Dawna J. Fraker, with her counsel, Carol J.
Lindsay, Esquire, and the Father, Jimmie L. George, with
his counsel, Arthur T. McDermott, Esquire.
3. The parties agreed to the entry of an Order in the form as
attached.
TV UE, Ru ert X. Gilroy, Esq re
Custody Conciliator
DAWNA J. ELDER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO: 5618 - CIVIL - 1994
JIMMIE L. GEORGE,
Defendant
IN CUSTODY
PETITION FOR MODIFICATION OF CUSTODY ORDER
AND NOW, comes Jimmie L. George, by and through his attorneys, The Shagn Law Group, to
Petition the Court as follows:
1. The Plaintiff is Jimmie L. George, an adult individuals residing at 207 Frytown Road,
Carlisle, Cumberland County, Pennsylvania (hereinafter "Father").
2. The Defendant is Dawna J. Elder (formerly known as Dawna J. Fraker), an adult individual
residing at 12 Circle Drive, Mechanicsburg, Pennsylvania. (hereinafter "Mother").
3. The parties are the parents Karissa Ann George, d.o.b. 01/12/94.
4. An order was entered on December 30, 1994, granting shared legal custody of the child to
both parties, primary physical custody to Plaintiff, and periods of partial physical custody to
Defendant; a copy of the Order of Court dated March 2, 2000, is attached hereto and made a part
hereof marked as Exhibit "A."
5. Change in circumstances have occurred which should allow Defendant additional periods of
physical custody as follows:
a. The child has expressed a desire to spend more time with her Father;
b. Father has a new home to better accommodate the needs of the child;
c. Father has a more flexible work schedule which allows him to take the child directly to
school on his periods of physical custody.
WHEREFORE, the Defendant respectfully request Your Honorable Court to enter an Order for
custody of said child as follows:
1. Both Parties shall share legal custody of said child;
2. Mother shall have primary physical custody of said child,
3. Father shall have periods of partial physical custody of the child as follows:
a. Alternating weekends, from Friday after school until Monday morning;
b. One evening each week, from after school until the next morning whereby he
Would take her to school;
c. Alternating weeks in the summer when the child is not in school; and
d. Alternating holidays.
Date: 9 i0 -?- Respectfully submitted,
J a J. Kopecky, Esquire
Supreme Court ID # 53147
300 North Second Street,8t'Floor
Harrisburg, PA 17108
(717) 221-1111
SEP-1?-2007 10:38 PM
d .
08110/2007 08:09 FAX 7172211110
P.04
11004/004
I vu* that the sWments made in this Petition for iVXodifua?tion of Custody an Um And
aor,r+eat. I oodmtend that glee etatemab hen atn made 4ubjed to the penalties of 18 P& C.S.
Soxion 4904 Mating to u=wom fabdfloation to • dwdtfee.
DAs; No -
inomaie L Def ndud
7?
4
DAWNA J. ELDER IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
• 1994-5618 CIVIL ACTION LAW
JIMMIE L. GEORGE IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Tuesday, September 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 Thursday, October 25, 2007 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 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 hearin¢.
FOR THE COURT,
By: /s/ Hubert X. Gilroy, EM.
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
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OCT 8 0 2007 0'
DAWNA J. ELDER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v CIVIL ACTION - LAW
JIMMIE L. GEORGE, NO. 1994-5618
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 prior Order of
December 30, 1994 is vacated and replaced with the following Order:
1.
2.
3.
i
UMBERLAND COUNTY
OURT ADMINISTRATOR
E COURTHOUSE SQUARE
, CARLISLE, PA 17013
The mother, Dawna J. Elder, and the father, Jimmie L. George, shall enjoy shared`
legal custody of Karissa Ann George, born January 12, 1994.
The mother shall enjoy primary physical custody of the minor child.
The father shall enjoy periods of temporary physical custody of the minor child as
follows:
A. On alternating weekends during the school year from Friday at 5:00 p.m. until
Sunday at 7:00 p.m. When the minor child has commitments with the swim
team on Sunday evenings, the father will get the child to the swim team
commitments.
B. Du the summer months, the alternating weekends shall be from Friday at
Johnn4 j. Kopecky,?squire
26 West High Street
Carlisle, PA 170" --
7 ®RTNEY HOVVCS
02 1A $ 00.4' °
0004631598 NOV 06 2007
MAILED FROM ZIP CODE 1 701 3
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- NIXIE 171 CE 1 25 11/14/07
ETURN
ATTEMPTEDTO NOTDKNOWN
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