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Home My WebLink About95-01332 It ~~;,"-' ,.-."- f:~ :;':{L: -L::'__ , ,'" L- .~- . , "i<f'" ")',-;;,' ,." ~:::':r:'QJ'.':' ",'- -' :-(i"~ ',T_'> !., 'J : :,' Cl r0 r() .-- o <: 'j "::'I;~l.J'I:-\ f, ~.> ~\'A>\t )-r..l,i'i~ ',' . ",J'i!;;1?lJ( "51"1}~ ::':.,"..i';::._;:;:_if:~.'~.:~~- ,_,,,,,,,,-,_,,- 4~~ '"; '~,T:~~~~ ,,,:~,'.~itlf (>:{:ff~~ '"'t.~ ,;i:ri , '...:.Jr1 , .Iie... "":\'1~1~ ~ -'\, ' -f'" .~,i'-- ,'-n ;'j; " 'rJ:i.' ..':"f ' .:~.:~ -'j\?1: f..;;:,& ',~ {;~f~l }II'j ',' '-~--,"';I 'i',.:'J~ ',' \,';.:!l ~.~~f:;~ N~{t ',~"'~ ,:,":[~f& 'J~I ,., ".:,.:1 '..::i:i~i;i ':i;9~~ ! ' ~ ; '" ,( .1 ';"'- ,. .1. (-,' , ~ ' . ,~, , :':~~I ~";~ ~t~ . ~::~h1l' .. 't J ..... . . '- ~e. ?;Jt,'/lo/ld & 'S2>e. 'C/Itwwl ATTORNEYS AT v.w 2800 MARKET STREET CAMP HILL. PENNSYlVANIA 11011 1'1'173~~39' I('tlh B O.Almona J,Ck,' J O,Altnond " (":l ;t ~ /:j, Jt.. P W vJ 0() q) IJ ~ ..J = t:I ,~ .;f; ,,"> . h t-': ' ;., ~ ,,:,}; . . +.. l'l ,,-,'- - lJ\ 0 . 0 Ll) '. t....) 01 C/ CI " N ~ 0 .. ': ~ <:> 'f) 11- I'" :,:'-. -;j 8- .::...: "E. .' - J < .... LD } f.T1 -. ... .' JEREMY E, SPAULDING, Plaintiff v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA '15- No, 133:) CIVIL TERM CIVIL ACTION - LAW IN CUSTODY JEANNE HOOD, Defendant ORDER OF COURT AND NOW, this ~ day of /V).lrc h , 1995 on consideration of the attached petition, it hereby directed that the parties and their respective counsel appear belbre o ~~"I\ S .~CA.'le\"'f ,Esquire, the conciliator, at onthe~dayof April ,I995,at q;v" ~.M.foraPre-Hearing Custody Conference, At sllch conference, an eflbrrt will be made to resolve the issues in dispute; or if this cannot be accomplished, to deline and narrow the issues to heard by the Court and to enter into a temporary order, All children age live or older may also be present at the conference. Failure to appear at this conference may provide grounds for entry of a temporary or permanent order. Hearing to be held at '1 C; Lv. Mlj fl Sf. f\'lc>-chc.11 inb'1r~ . - BY THE COURT, BY: ~L-rn-elAtnltd'F..~. Custody Conciliator ~;:; / 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 !:;,i \ I 1\ T' ['CARLISLE, PA 17013 (717) 240-6200 1 :.., . ") I t~. '" i i I :1 lit" .' 00' fl.) . ,,' ': ~.: I 1,1. 4'{ ,\; \;lJ ijl;',' .\ 'j\. , ,,~L:li i Y~i.lr;; .. I ~l ii'J : In 56. Hd 111 ZI 12 Hill - - " - JEREMY E. SPAULDING, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA V, No, CIVIL TERM JEANNE HOOD, Defendant CIVIL ACTION - LAW IN CUSTODY COMPLAINT IN CUSTODY I. The Plaintiff, Jeremy E, Spaulding, is an adult individual who currently resides at 150 Regency Woods, Carlisle, Cumberland County, Pennsylvania 17013, 2. The Defendant, Jeanne Hood, is an adult individual whose current address is 203 West Simpson Street, Mechanicsburg, Cumberland County, Pennsylvania 17055, 3, Plaintiff seeks sole custody of the following child: Zachary Aaron Spaulding, born January 31, 1993, NAME Zachary Aaron Spaulding PRESENT RESIDENCE 203 West Simpson Street, Mechanicsburg, PA 17055 AGE 2 years 4, During the child's lifetime, the parties' child has resided with the following persons at the addresses and for the periods of time indicated below: Mother 203 West Simpson Street, Mechanicsburg, PA 4/94 . Present Mother and Father 150 Regency Woods, Carlisle, PA Birth - 4/94 - . " - , The child was born out of wedlock. The child is presently in the custody of the Mother. The Mother of the child is Jeanne Hood, whose present address is 203 West Simpson Street, Mechanicsburg, Pennsylvania 17055, She is not married, The Father of the child is Jeremy E, Spaulding, who resides at 150 Regency Woods, Carlisle, P A. He is not married, 5. The relationship ofPlaintilfto the child is tha, of Father, The PlaintilT currently resides alone. 6, The relationship of Defendant to the child is that of Mother, The Defendant currently resides with the minor child, 7, PlaintilThas not participated as a party in other litigation concerning custody ofthe child. Plaintill'has no information ofa custody proceeding concerning the child pending in a court of this Commonwealth. ", VERIFICATION I, Jeremy E. Spaulding ,the undersigned, do hereby verify that the statements made in the foregoing instrument are true and correct to the best of my knowledge, information and belief. I understand that statements herein arc made subject to the penalties of 18 Pa. C. S, Section 4904. relating to unsworn falsification to authorities. Date: ~ - \? - I S .lIIIIIIL -- . ~ ....... . -' . . ~ . ::JWo~-"~ . .,'"... . , .... . ,....- ~----" ' " '~~ ~>~ ~I ~ :tl '-' ~ ~I It': ~i N :'1 Ji ..:g i~~s~ ... ~ "'.g.:t~!.: ~'-' '0 ~ C ~ /~ S I v;.( '01 . (l'It,1i .5 ': Q~ ~ 2: ~J iJ II( f ~ !i' !:l D': a I .. ~ a Jj ,C .. tIl ~ . ;: = ~ ~Ol s ,,~ '" ~ . ~,P, \,.._ iii ... ~ !il I ., ! B r.1~ - . , . . , . '. j' APR 1/1995) " " .' ... JEREMY E. SPAULDING, Plaintiff IN THE COURT OF ~~ON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 95-1332 CIVIL TERM JEANNE HOOD, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER OF COORT AND Nai, this \ 1 day of · f).. J consideration of the attached Custody conciKtr:;'IReport, ordered and directed as follows: , 1995, upon it is hereby 1. The Mother, Jeanne Hood, and the Father, Jeremy shall have shared legal and physical custody of the Child, Spaulding, born January 31, 1993. 2. The Mother shall have physical custody of the Child at the following times every week: Monday from 6:00 a.m. until 4:00 p.m., Tuesday from 6:00 a.m. until 4:00 p.m., and Wednesday from 6:00 a.m. until Friday at 4:00 p.m. E. Spaulding, Zachary Aaron 3. The Father shall have custody of the Child at the following times every week: Monday from 4:00 p.m. until Tuesday at 6:00 a.m., Tuesday from 4:00 p.m. until Wednesday at 6:00 a.m., and Friday from 4:00 p.m. until Monday at 6:00 a.m. 4. The Mother and the Father shall' share physical custody of the child on holidays as mutually agreed between the parties. 5. The parties may modify this custody SChedUler mutual agreement. In the absence of an agreement to modify this,Bch ule, the schedule outlined above shall control. " ' I ' " 11 BY T:HE COURT l ' J. co: Jeanne Hood Jackie J. DeArmond, Esquire c.~~QJ ........ ,,>'-C~t<<l '1-1' It/9S". ,A .'fl. - ~ rr. I' ,-, ;01 ... JEREMY E. SPAULDING, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. 95-1332 CIVIL TERM JEANNE: HOOD, Defendant CIVIL ACTION - LAW IN CUSTODY CUSTODY COOCILIATIOO 5lR'lMARY REPORT IN ACCORDANCE WITlI CDlBERLAND CXXlNl'lC RULE OF CIVIL PROCEDURE 1915.3-8, 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: NAME: BIRTHDATE CURRENTLY IN CUSTODY OF Zachary Aaron Spauldin9 January 31, 1993 Mother/Defendant 2. A Conciliation Conference was held on April 11, 1995, with the following individuals present: The Father, Jeremy E. Spaulding, with his counsel, Jackie J. DeArmond, Esquire and the Mother, Jeanne Hood, who appeared without legal counsel and the Child, Zachary Aaron Spaulding. 3. The parties agreed to the entry of an Order in the form as attached. Date ,(JpK.IJ /3 /19!J- '-;; , L~ it/JJ< ,....oIJ'(y Dawn S. Sunday , CUstody Conciliator ~ '- I~ .." [.; ., 1-' II.lCL' c.' . i.l:!'" ., , ~" ,. (')I,. -fl.- . .. ....)/'. ... (;-,..: I ! ; , Ii:!: I C : J I'. I! , :L U, II (":1 0 'J' , 00 < 1"1 . ..:l :>< Il. ..:l ~ M ..:l Z :E Ii-< H~ :>< 0< P: Ii-< ..:l I:: ~ ~Il. W .,... /0 H 8 Cl~ 1"1'0 t:l o . ~ ZI:: !!a m 0 'li.Q35E~ll! U:>< ,.:I < H,... ::E: Eo< H ,.:I Pro <Ii-< ~~~~~ ~Z :> ,.:Io-i . W QJ 0 OP H I Pll. > t-:lP Eo< 0 U < 3 fl!" Eo<U Z Il. . Ul z 8~ N 0 00 Pro 0 . !6 M H:>< 0 H <1i M 8t:l . f;'l; Eo< u< .... uo W H ..:l I <8 0 Eo< I"IP: III 00 ~ WI:: 1"1 tI:I"I 0\ ,.:IP !!a~ Il. ~~ HU 1"1 :> P: ~to 0 HZ 1"1 r;;g HU Z UH t-:l . 'tiM/IiI .9: /;~'(!YII/I .. SEP 8 .19Sh~; , JEREMY E. SPAULDING, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-1332 CIVIL TERM JEANNE HOOD, now known as JEANNE LILLY, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this ~ day of ~ror ,1998 upon consideration of the attached Petition to Modify, it is hereby directed that the parties and their respective counsel appear before ~~. ~ the conciliator, atlS \J. \-\0 'f\ ~\) ~'l ,h '3P\on the \?, day of ()C\Obc: ("" , 1998, at ~.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 narrow the issues to be heard by the court and to enter into a temporary order. Either party may bring the child/children who Is the subject of the 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 pennanent order. For the Court, By: ~U\lf\..~J\IIN\rl[) ~. Custody Conciliator l'l:b:) 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 F~.l~L'r.');:;",~:. -,~' '1\' ,'- 'e,," r\,: . . ('r-'-' t \ " 1_ ,,, I>,{.l ..\" '. ," .\'l , . (}-/O' 9; - C...td,.(?,uL Cu,;JY n''a.,ltc.L -10 f)I/y ~7:'i) 9-(". C1J> - .JD()~,c.."- 1'I1~'dtc:(_-1cJ INII M(J.J?lou( q -(C)-~ - CbPI pL'12c.!i.cl II...) f.)./.I../ .Qdbyfu RLf.... JEANNE HOOD, now known as JEANNE LILLY, Defendant CIVIL ACTION - LAW IN CUSTODY v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-1332 CIVIL TERM JEREMY E. SPAULDING, Plaintiff " lETITIO~ TQ MQDIFY AND NOW, this ~ day of September 1998, the Defendant now known as, Jeanne Li11y, by and through her attorney, Austin F. Grogan, aver the following: I. The parties are the natural parents of Zachary Aaron Spaulding, born January 31, 1993; 2. Since early 1995 the parties have cooperated with the raising of the child ., pursuant to the Order of Court dated April 17, 1995 by Edgar B. Bajley, Judge; 3. A dispute has arisen as to what is in the best interest of the child in that now the child is entering school and the natural father is insisting that he have primary custody of the minor child; 4. The mother is willing to share the educational and custodial arrangements consistent with the working agreement, which the parties have adhered to over the past year. WHEREFORE, the Defendant, Jeanne Lilly, respectfully requests this Honorable Court to order a custody conference to fine-tunc the April 17, 199 Order. Date--=rJ I I 'i ~ - ~~~ ~ i~~:1 ow ~ ~ ow i 'Jj H ~I '" ~ ~I " ~I~ (9 ,,~ I> n .. - ..g. ... ~cU .la lit,~~' ~ ~ 'iil . 2! ;~~;~ ~ ~ ~ 101 " ~ a'lll. f 0'3 ~ . a~ ,5 Jj ~ 1 . ~ ~Jor(,. ~lll d2 rol. i Ii . , .' " . .... " NOV 0 2 1990 tP ...' , .. ~ JEREMY E. SPAULDING, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 95-1332 CIVIL TERM . . JEANNE HOOD, now known as JEANNE LILLY, Defendant CIVIL ACTION - LAW : IN CUSmOY OOOER OF OOORT AND tDoI, this t consideration of the attached and directed as follows: day of .J) ~ CUstody Conciliation Report, , 1998, upon it is ordered 1. The prior order of this Court dated April 17, 1995 is vacated and replaced with this order. 2. The Father, Jeremy E. Spaulding, and the Mother, Jeanne Lilly, shall have shared legal custody of Zachary Aaron Spaulding, born January 31, 1993. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 3. During the school year, the parties shall share having physical custody of the Child as follows: The Mother shall have custody of the Child every week, from after school on Monday through Thursday before school and the Father shall have custody of the Child every week from Thursday after school through Sund3Y morning at 9:00 a.m. The parties shall alternate having custody of the Child on each week from Sunday at 9:00 a.m. through Monday at the end of the school clay. The alternating Sunday through Monday schedule shall begin with the Father having custody on October 25, 1998. The parties shall alternate having custody of the child on school in-service days and other minor school hOlidays. 4. The parties shall share having physical custody of the child during the sUlllOOr school break on an alternating weekly basis with the transfer of custody to take place each week on Mondays at 3:30 p.m. Each party shall also be enti tIed to have custody of the child for two consecutive weeks during the summer school break upon providing thirty (30) days advance notice to the other party. 5. The parties shall share or alternate having custody of the child on holidays as arranged by agreement of the parties. 6. The party receiVing custody of the Child shall be responsible to provide transportation for the exchange of custody. 7. Both parties shall refrain from using illegal drugs or alcohol to ~ -. ... the point of intoxication during his or her periods of custody with the Child. The parties shall ensure that the Child is not exposed to the use of illegal drugs or alcohol by others during his or her periods of custody. 8. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Neither party shall make disparaging comments concerning the other party in the Child's presence or hearing. 9. In the event either party has family menDers coming to visit from out of town, the parties agree to modify the custody schedule to allow the party having family coming to visit an additional twenty-four (24) hour period of custody with the child upon providing five (5) days advance notice to the other party. 10. This order is entered pursuant to an agreement of the parties at a custody Conciliation Conference. The parties may modify the provisions of this order by mutual consent. In the absence of mutual consent, the terms of this order shall control. BY THE COURT, J. cc: Keith B. DeArmond, Esquire - Counsel for Father _ c.~ ~.{ II/sl'lt. Austin F. Grogan, Esquire - Counsel for Mother u- cu ..>h,6' . ... ": JEREMY E. SPAULDING, plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA va. : NO. 95-1332 CIVIL TERM JEANNE HOOD, now known as JEANNE LILLY, Defendant : CIVIL ACTION - LAW IN CUSTODY PRIOO JUDGE: Edgar B. Bayley CUS1WY CXN:ILIATIOO 5U'IMARY REPatT IN ACXXlUll\NCE WlTIl CtI'IBERLI\ND CXUll'Y RULE OF CML ~ 19l5.3-B, 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: ~ zachary Aaron Spaulding DATE OF BIRTH CURRFNl'LY IN aJSroDY OF January 31, 1993 Mother/Father 2. A Conciliation Conference was held on october 22, 1998, with the following individuals in attendance: The Father, Jeremy E. Spaulding, with his counsel, Keith B. DeArmond, Esquire, and the Mother, Jeanne Lilly, with her counsel Austin F. Grogan, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Dr fu/",,, rJ9.. /C}9,{ Date (Q.,~ Dawn S. sunday, Esqu re CUstody conciliator .. (;~ ~, V"" (. \.L~t":, (\. -' ',\.1\, .~ \C c:"\..c \....\-.. \1:~ '{ '0 .~ ,;... \;:0 '('. .,<.-.... t~" .. .~~\..~.~. '"),.. ... ;) .., . \ ':',:'I~. -. .., "",' ',,' f;n. " ,..,\~.~.~~ \' ',-.. ') '.) .:.": \