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HomeMy WebLinkAbout95-02425 Alisa Dawn Ingram, Respondent/Plaintiff IN THE COURT OF COMMON PLEAS OF v. CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 96 - 2426 CIVIL TERM Rod Eugens Ingram, Petitionsr/Dsfendant CUSTODY BY1E TO SHOW CAUSE AND NOW, this '" /[; day of May 1996, a rule is entered against the respondent to show cause why the relief requested in the within Petition for Special Relief should not be granted. The Rule to Show Cause is returnable at the Protection From Abuse hearing scheduled for May 11, 1995, at 3:46 p.m. By the Court, ~/ t- AiJ-, Kevin A. Hess, J. I Alisa Dawn Ingram, Respondent/Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. Rod Eugene Ingram, Petitioner/Defendant NO. 96 - 2426 CIVIL TERM CUSTODY E.ETlJHlli FO!LQf'EQJA1J1Hlff_ The plaintiff by and through his attorney, Joan Carey, Legal Services, Inc., represents the following: 1. The respondent, Alisa Dawn Ingram, hereinafter referred to as the mother, resides at 9691 Upper Strasburg Road, Upper Strasburg, Franklin County, Pennsylvania 17266. 2. The petitioner, Rod Eugene Ingram, hereinafter referred to as the father, resides at Lot 2, Country View Estates, Bloserville, Cumberland County, Pennsylvania. 3. The parties are the parents of Shannon Marie Ingram, born January 26, 1993. 4. On May 4, 1996, a Petition for Emergency Relief wae filed by the father and an Order entered granting the father primary legal and physical custody of the child and the mother visitation at such times and places as may be mutually agreeable to the parties. (See attached Exhibit A incorporated by reference) . 6. The parties, through theIr attorneys, have been trying to negotIate a custody schedule but they are not able to agree even to a temporary SChedule penllinll the conell1atHlrl. 6, It i8 in the chIld's hest Inlerest to resume reyular perIods of cUlltody with both parente. WHEREFORE, the plaintiff requests that this court enter a temporary order setting up a shared custody schedule pending the conciliation. The plaintiff requests any other relief which is just and proper. Respectfully submitted, . .0, .J.:-i~:r;fiL 'ti <t~:_------- , " Attorney for Plaintiff LEGAL SERVICES, INC. a Irvine Row Carlisle, PA 17013 (717) 243-9400 Tho abovlllllln"id plnllltlff, Allsa Oawn Ingram, verifies that tho Btntomont.1I mad.. III t.ho abovo Petttlon are trus and correct. The pet.lt.toller Ulldnlll\.iIfHln l.hnl. folse statements herein are made subject t.o t.ho /1111111 11. lUll of 1/1 PII. e.s. 6 4904, relating to un8Wotn rllIHlflUltl,u, t.o nut.!lOrltIOS. Ollt.e: ! ! Jt I I , I I /' / / C _l'_ Lll_~:~.Ll ,( / Iy/i Ii ) Alisa Dawn Ingram, Plalritiff \ ROD EUGENE INGRAM, Petitioner : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : 1 y J 4 )'r(~M.;...(_jL(.J"" : CIVIL ACI'lON. LAW : NO, CIVIL TERM : CUSTODY v. ALlSA DAWN INGRAM, Respondent ORDER AND NOW, t1111 'f" day of . 1995, upon review ofthe attached Y'rI ,q 'I Petition for Special Relief, It \a hereby ORDERED that, pending further Order of th18 Court, Rod Eupne lnjp'8L. ahalI have both primary 1ep1 ar.d ph,yllcal cuatody of the chUd, Shannon Marie lnp'am, born JanUlll)' 26, 1991! and that A1\aa Dawn I/IIlI'lIIII BhalI have ~ vialtatlon with the chUd at IUCb t1mel and pl8cel u ~ be mutual1y II/P'eeable to the partiel, BY TIlE COURT: . 4-d-~ J. I I':xhlhll ^ ROD EUGENE INGRAM, PeUUoner IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Y. CIVIL ACTION. LAW NO. CML TERM CUSTODY ALISA DAWN INGRAM. Retpondent pE1TI'ION FOR SPECIAL AF.I.IF.l 1. Petitioner Is Rod EUIlt-., e IIIIlflUDo an adult Indlvldual mIdIni aL Lot 2, Country View FAta_ IDOMrvIUe. Cumberland County, Pet1II8)'lvanla. end the naLura1 father of the cbIId who Is the IIIbject of the ~OCIed CIIItOdy ectiOCI. 2. ReIpondent Is AI\aa Dawn IDp'UD. an adult Indlvldual whOM current ~ Ia lIIIImown to the Pla\nwr and have bem1l1111mown aIace November 24, ~. lIeIpoIldent Ia be1Ined to be 1\YInI1n Upper Btruburl. Fnnk1In County, peDD&JlftnIa. 8. Tbe cb1Id that Is the lUbject or thla cutody ICtiOCIla BbannOCl Muie IJIIIlIIIIo bani Jmual1 l18, i1l98. Tbe ~ to thIa ICtioD are the natund perenta oC U. cbIId. 4. At. the end or March. 11195. Petitioner left the marital home due to llllrital cIIIIIcuIt1e- and Petitioner and a.pondaot haft Ibared lepI and pbyab1 cuatocl1 oC the cbIId aIace thIat time. 5. Tbe Petitioner md other wI~ haft 00... .ed U. cbIId with · .... dIri1. unkempt, 11 I, or h\IIIIfY al\er villta with the ReIpondent. \, '. ....-..............-.........-...--- , with llIII1'" mattrelO OCI the floor for both the cbIId end the ReIpondent to '-" "urInI tIm.- when I' I. Retpondent had the child. \: ,. "" April '". .... ...., "...... - " . ... " - " ... ... .. ... Retpondent and fearing for the earety and welfare of the chlId, Petitioner lIUIIIJIed I\J1\ pb.J1IIca1 cumody ! of the chlld. 'The petlUoner offered 1Upm1aed vlaltatlon to the Reepondent but the Retpondent ref\lled. 8. On May 3, 1995, the Respondent eelzed the chlld !'rom the Reepondent'. partlnta' home, who were babymttlnll for the Petilloner whlle he wee lit work by threatening lepllldlon and with th' 1:<1111111 ,\ auiIotance of a WOID8/1 {>08ina aa a reprelenlative of Women In Need, Women In Need had no luch repreeenlative auiIotlnjr the Reapondent, 9. Petitioner Ie concerned about the elate of mind of the RelpDndent, hie wife, and Ie therefore concerned I'l!1lU'd1ng the BlIf'ety or poalble abduction of the chUd Ihould the Reepondent leave the area. 10. Reepondent hu refuJed to reveal the location of the child to her hlllband, her pB/'enla or anyone elle known to the Petitioner llince her wwmoWlC8d eelzm, of the chUd on May S, 19911. 11. Petitioner'. primary concern Ie the BlIf'ety and weD bem, of hie child and, therefore, beD_ that the apeclaJ reDef requested herein Ie JlIIti1Ied 12. On May 4, 19911, Petitioner commenced an ectJon In the Court of Common PI_ or Cumberland County, PemwyIvania to oblaln lepJ and phy.lcaJ CU8tody of the chUd. WHEREFORE, PetitJor.::" Rod Eupne IJ1II'lUII, reapectfuJJ,y reqUe1t8 that, pendlllf fUrther order or th1a Court, he be iNJIted primary lepJ and p~ CUltod,y of hie chUd, Shannon MvI. Inp.m and that the Ra.pondent, AlIa Dawn IJ1II'lUII, have eupervlaed v1aitation with the chUd at euch t1m. Uld pIaceI .. III'll mutlUllly .-ble to the pert!l!lI, RespectfuUy eubmltted, LAW OFFICES OF RON TURO 5-1-1-~ Date I:>(~~~V - avid J. Spatta' 12 Bouth Bedford Street CerUale, PA 17013 (717) 2411-9688 Attorney for Petitioner r"hlh It ,\ HOD EUGENE INGHAM. I'lulnliff VN. IN TilE COUHT OF COMMON I'LEAS OF CUMBEHLAND COUNTY,I'ENNSYLVANIA CIVIL ACTION, I.AW 1)5,242,~ CIVIL TEI~M OlmEH All SA DAWN INGHAM, Defendant CUSTODY AND NOW, IhiN /1.- duy of Muy. 11)1)5, pending further heuring, the partleN shull Nhare legal and physical euslody of Ihe child, Shannon Marie Ingrull1. horn Junuury 26. 11)1)3. with physical cUNtody of the ..hild helng in the fathl'f from Wl'dnesday al noon until Sunday al noon und In the mother from Sunduy al noonunlil Wl'dneNday ut nonn. BY TilE ('OUIn-, Hohert J. Mulderig, Esquire dill' t...,Ll, 51/~ '('f For Ihe I'laintiff ;; , 1/L Joan Cafl'Y. Esquire For the Defendant I, I ~'ll ~t;'b' /~L '". "1,1 {!I ~'/~,r/7'f- :rlm ROD EUGENE INGRAM. Pelilioner IN 'rml COURT m' COMMON PLEAS OF CUMBERLAND COUNTY 1) ,)/(dl"-(' I,;' tile", CIVil, ACfION . LAW NO, CIVil, TEltM : CUSTODY v. ALISA DAWN INGRAM, Respondent OIlD~ll AND NOW, this -L day of nili'} 'I , 1005, upon review of the attached Petition for Special ReUef. it Lo hereby ORDERED that, pending further Order of this Court, Rod Eugene Ingram shall have bolh primary legnJ and physical custody of the chUd, Shannon Marie Ingram, born January 20, 1905 and lhat Ali88 Dawn Ingram shall have ~ vlsltalion with the child at such limes and places 88 may be mutually agreeable to the parlies, BY TIlE COURT: ,4d-~ J, 1l0D EUGENE INGRAM, Petitioner IN THE COUIlT OF COMMON PLEAS OF CUMBEllIoAND COUNTY v. ALISA DAWN lNG/tAM, ReBpondent CNlLACTION. LAW NO. CNlL TERM CUSTODY PETITION FOR SPECIAL RELIEF 1. Petitioner Is Ilod Eugene IngrlUtl, an adult lndlviduol reBidlng at Lot 2, Country View Estotes, B1oserviUe, Cumberlnnd County, Penneylvnnlo, and the noturo/ father of the chUd who Is the eubject of the nbove-coptloned custody action, 2, Respondent is AII8I1 Dawn Ingram, an adult individuol whose current addre8B Is unknown to the PlalntllT and have been unknown since November 24, 1994. Respondent Is believed to be llvlng In Upper BtrllBburg, Frnnklin County, Pennsylvania, 3, The child thot is the subject ofthis custody lICtion Is Shannon Marie Ingrl1fl1, born January 26, 1993. The Jlftl'ties to tills action are the noturo/ Jlftl'ents of the child, 4. At the end of March, 1995, Petitioner len the marital home due to marilA/ dII11cu/tiee II/ld Petitioner and Respondent hove shared legal and physical custody of the child since that tbue. 5. The Petitioner and other witne8Bes have observed the child with a raah, dirty, unkempt, or hungry afler visits with the Respondent. 6, TIm Respondent kept the chUd In an unheated troller Il/ld Inter in a two room aJlftl'tment with only a maUress on the noor for both the clllld Il/ld the llespondent to use during tbues when Respondent had the child. 7. On April 20, 1005, after repeated episodes of a lack of welfare of the child by the Respondent and feMing for the 8/lfety nnd welfare of the child, Petitioner R88umed full physical custody of the child, TIle Petitioner offered supervised visitation to the Respondent but the Respondent refused, 8. On May 3. 1095, the Respondent seized the child from the Respondent '. parents' home, Ii who were hnbyslUlng for the Petitioner while he wns at work by threntenlng legal Retlon and with the i 1::1 J '95 i. '. J .1 ,:,- ,/ 'IJ. {J,,i ('60/1 mWlJ.!./ r; ,~~ ''';J"lt _~. 'I' ~}. ),'..1<c( ~IVlLlfJ I. '~!/ .' (I <1'( fl I ! ...J I I Li'/!Cl ''If'L-dt/;;' ,: -,<21.(11 . ROD EUGENE INGHAM, PlnlntifT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY (If .J 4 ) 5 - ('r lV~ t \)It. /"- CIVIL ACl'ION - LAW NO, CIVIL TERM CUSTODY ". ALISA DAWN INGRAM, Defendant ORDER OF COURT You, AIlsa Dawn IngrlUll, Defendant, hR"e been sued in Court to obtRIn custody of the foUowlng chUd: ShRnnon Mlll'ie IngrlUll, date of birth, JIUlURry 26, 1993. AND NOW, this dRy of . 1995, upon consideration of the attached Complaint, It is hereby directed thRt the parties IUld their respective counsel appear before , the conciliator, at on the dRy of , 1995, at _Nt, for a Pre-Hearing Custody Conference, At such Conference, IUl efTort wiU be made to resolve the issues In dispute; or if thla cannot be accompUshed, to define IUld narrow the Issues to be helll'd by the Court, IUld to enter Into a temporary order. All children oge five or older shall wso be present at the Conference. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent order. YOU BHOULD TAKE TIIIB PAPEH TO YOUH LAWYEH AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OH TELEPHONE THE OFFICE BET FOH'rH BELOW TO FIND OUT WHERE YOU CAN GE" LEGAL HELP. Court Administrator Cumberlnnd County Courthouse Carlisle, PA 17013 (717) 240,6200 BY TilE COURT: I II II J. ROD EUGENE INGHAM, PWnllff IN THE COURT OF COMMON PLEAS OF CUMBEHI..AND COUNTY. PENNSYLVANIA v. ALISA DAWN INGltAM, Defendant CIVIL ACTION. LAW NO, CIVIL TERM CUSTODY COMPLAINT FOR CUSTODY J. PWnllff is Rod Eugene Ingram, sn adult individual whose residence Is lit Lot 2, Country View Eslotes, Bloserville, Cmnberlond County, Pennoylvsnia, 2, Defendant Is Ali8ll Dswn Ingrsnl, an adultlndividuol whose currentllddre.. Is l1IIknown to the PWnliff, but who is believed to be residing somewhere in Upper Str88burg, FronkIln County. Pennoylvsnia, 3, PWnllff seeks custody of his child. Shannon MorIe Ingr8ll1, born January 26, 1993, who resided with PWnUff until the Defendant removed the child under false pretenses. 4. The child W88 In the custody of the PWntllT unW seized by the Defendant. The current whereabouts of the child Is unknown and Defendant refuses to reveal the 10000lIon of the child, 5. Since the child's birth, she hill! resided with the following over the Jl88t five years: N8II1e Address ~ I! Hod Eugene Ingram 58 Ruslic Dr, I A1i8ll Dawn Ingram Shlppensburg, P A Jan, 03. Apr. 26, 1995 I Hod Eugene Ingram Lot 2, Country View ~}slotes 1II0serville. P A Air, lJI, 1IIll5 . ~ 3, IOOlI 6. The naturol mother or the child I. A1i88 Down Ingr8lll, whose current llddre88 Is unknown to the PloinUlr, but who works ot Cresmort, IUUtler HighwAY, Shlppensburg, Pennsylvania, 7. The nnturnl fnllter of the child I. Hod Eugene Ingram, currenUy re8iding at the above'sloled addee.s. B. The relaUon.hip of the Plalnliff 10 lhe child i. thot or IlllturAI rather, O. The relAtion.hlp or the IJerrndAntto the child 18 thot of nAturAl mother. 10, The PlalnUff hllllnot pnrUclpnted IIlI n party or In nny other eRpnclty, In other Iltlgatlon concerning the custody of the ehlld In this or any other court. 11. PlnlnUffhllllno informntlon of n cU8tody proceeding concerning the child pending In a court of thl8 Commonwenlth. 12, The best Interests nnd permanent welfare of the child will be served by grnntlng the rellef requested becnuse the Plaintiff is the primary care giver with respect to the child and because Defendant hllll failed to properly eRre for the child nnd hllll failed to provide noUce of her nddress or infonnntlon on the safety or welfare of the child. 13, Each parent whose parentnJ rights to the child have not been terminated nnd the person who has physicnl custody of the child hnve been named IIlI parties to this action, No other persons are known to hnve or claim to hnve nny right to custody or visitsUon of the child other than the partlea to thin action, WHEREFORE, plnlntlff requests your Honornble Court to grant to him both primary phyalcnl and I legal cllstody of his child, Shannon Mnrle Ingram, I Respectfully submlUed. LAW OFFICES OF RON TURa .~> Ll- yr~, ]~. ) dl/~ )~~Ttr David J, BpoUs, Esquir 32 Bouth Bedford Btreet Carlisle, PA 17013 (717) 245,9088 Attorney for Plaintiff Date J... '~ ~,-~ ~ ., , -: 'J .... ., ~\~ ~ " In t.n ~ ,< .. .. .. 0_ J \' - .~ ROD INOItAM, PlalnUlT : IN TilE COUIlT OF COMMON PLEAS : CUMnEltLAND COUNTY,PENNBYlNANIA : CIVIL ACTION. LAW 'I y, I, ,: ij ALIBA INGHAM. ;1 Ilcfcmlllnl iI , I I i : NO. 05,2425 CIVIL : CURTOIJYNIBITA'I'ION CEllTIFICATE OF SEllVlCE II Illlefendanl'l counsel, Joan E. Carey, t;lqulre, on lhe 12lh day or MIl,Y, 199/1, I cerUfy that I lerved ft copy or the Complaint for Custody by perlOnaIly handinlllhe copy lo ii ., II il I' I! " , Alisa Dawn Ingram, Respondent/Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 96 - 2426 CIVIL TERM Rod Eugene Ingram, Petitioner/Defendant CUSTODY ~RT1.ElQAIJ;_QE,JlER\, I <;:1'; I, Connie Thomas, certify that! did this day hand deliver one copy of the Rule to Show Cause and the Petition for Special Relief in the above-captioned case to the address of the attorney for the petitioner/defendant, Robert J. Mulderig, 32 S. Bedford strset, Carlisle, Pennsylvania. __~dj'/tl5. Date .' ~. /; . / LA-~/iLL'L~_, Jt.~2{~~-Z_--- Connie L. Thomas Paralegal Legal services, Inc, 9 Irvine Row Carlisle, PA 11013 (111) 243-9400 . fl. \ "'I)r) . I')\-i\. 1,'.1 v I IN THE COURT OF COMMON PLEAS OF ICUMBERLAND COUNTY, PENNSYLVANIA I INO. 2425 - CIVIL - 1995 I I ICIVIL ACTION - CUSTODY ROD EUGENE INGRAM, Plaintiff ALISA DAWN INGRAM, Defendant COURT ORDER AND NOW, this 8. day of a...,....... the attached Custody ConcilIation directed as fo11owsI , 1995, upon consideration of Report, it is ordered and 1. The Father, Rod Eugene Ingram, and the Mother, A1isa Dawn Ingram, shall enjoy shared legal and shared physical custody of Shannon Marie Ingram born January 26, 1993. 2. Physical custody of the minor child shall be handled as follows I A. Father shall enjoy physical custody from Wednesday at 6 P.M. until Sunday at noon. B. Mother shall enjoy physical custody from Sunday at noon until Wednesday at 6 P.M. C. On Thursday and Friday during the day when Father is working, Mother shall be afforded the opportunity to provide day care for the child on those dates. Father shall advise Mother where she can pick the child up on Thursdays and Fridays and Father shall advise Mother when he will be returning from work at which time he will pick the child up. 3. The non-custodial parent shall handle the transportation in that the non-custodial parent shall pick the child up from the other parent. 4. The above Order conten~lates the requirement that both parties shall allow reasonable telephone access for purposes of providing information on exchange of custody. . '-'":' .. d. ~;'~,~t~j i;;,,_ ~.. .' ~ :".- -' "CT" 1',':,. ,-""_..,,. ,',- ~:;'~~ ~:~:j>: '-~ ~~ X -L;~. f '-''2o/p, ...._." '," C;',"""..C;~n',' .."'''-'~' '. 'i1::::':'~~t~. - _.',c:i,_i.:..ic::":i'.;'" . Law 0fft0I of ROn TLIta" . '.' :~.. .. OOUJ1h~'iJAlI. 'iI=,~~~,~,... . ; . (1l'1)'" 1111 ..L,,," <:.-- ;\ii..'c "'~-':: , . ~ . ~ ROD EUGENE INGHAM, Plnlnllff IN TilE counT OF COMMON PLEAS m' CUMBEnLAND COUNTY v. NO, 242ft. CIVIL. 109ft ALISA DAWN INGHAM, Defendant CIVil, ACTION. I.AW CUSTODY I I I. AND NOW, comes the plaintiff, Rod Eugene Ingrftln. by and through his sUorney's, The Law Offices of non Turo, and represents the following: I l'E11TION FOIl SECOND CONCIUATION CONFERENCE 1. On May 4, 1995, s Complaint for Custody WI\lI flied In this maller. Thnt Complaint Is Incorporated herein be reference In ita entirety. 2, On July 27, 1995, a Concillallon Conference was held in which the Parties agreed to an entry of an Order of Court. 3, On August 8, 1095, an Order of Court was entered in thla maUer which stated in part that '(\)n . the event that either party desires to modify tills Order at any lime in the future, that Party may pellllon the Court to have the CRBe IlJlllin scheduled with the custody conciliator.' 4, There are numerous 8/ld ongoing problerm regarding the custody 8/ld visitation that wu I establlahed in the Court Order of August 8, 199ft, WHEnEFORE, petitioner, Hod Eugene Ingram, respecllvely requests this Court to Order 8/lother Concillatlon Conference or for such other relief 88 the Court deerm appropriate. lrespectfully aubmlUed, I.AW OFFICES OF RON TURO 0.' l - '1 5 Date 1;i~~" avid J. Bpott Eaqul v 32 South Redford Street Carlisi., PA 17013 (717) 24ft'9688 AUorney for PlnlntifT . CERTIFICATE OF SERVICE I hereby cerllfY 1Ilftt I aerved II true and correct copy of the Complaint for Custody upon A1laa Dawn Ingram, Defendant, by depoalUnll BBlne in the United Slatea Mall, first clall8, poatage pre.pald on the i-u:i day of 'DE c. E M ~(, (L , 1005, fro.1I Carliale, Pennsylvania, addreBBed 88 follows: Joan E. Carey Legal Servicea Inc. B Irvine Row Carlisle, PA 17013 LAW OFFICES OF RON TURO -~ ~.. c).'- avid J. Bpot~~ 32 Bouth Bedford Street Carlisle, PA 17013 (717) 245.9888 Attorney for Plainllffs ir. ItJ r:: ~~ .:r 8~ 8.. :r; u;l ~B ..., 'l'':'; .. > o:J ~Lj u, I - L~ il:~l! '-, e~U) f-~ l,ll '..l-..t.4.. Ci 15 ,n =1 U\ U ROD EUGENE INGllAM. Plaintiff I IN TIm COVIn' m' COMMON PLEAS I OF CUMBERLAND COUN1Y I I NO. 2426 . CIVIL. 1996 I I CIVIl. ACTION. LAW I CUSTODY v. ALl SA DAWN INGIlAM, Defendant OIlDER OF COUIlT AND NOW, this -12..L day of flp[ I \ ,1996, upon conalderaLlon of the IItlached Pellllon. It la hereby directed lImt the parlles and their reapecUve counsel appear before _ J.~'\..II\j (.,.\ \1<'/ t",-<, . the conciliator, at l/\ h fie'" ,,,,,H. ~~th~' <Tl~ day of {Irk '/ . 1096, at ,9'1<' (I.m., for a Pre.Hearlnll Cuatody Conference. At Buch I - Conference, an effort will be RlBde to resolve the Issues In dispute; or if tWa cannot be accomplished, to defme and narrow the Issues to be heard by the Court, and to enter Into II temporary order. AU children age five or older may also be preaent at the Conference. Failure to appear at the Conference may provide grounda for entry of a temporary or permanent order. FOR THE COURT, By: The Court of Common Pleas of Cumberland County Is required by law to comply with the Americans with DlsnbiliLiea Act of 1090. For lnformaLlon about accessible facUlllea and reftBonable accommodaLlons IIvaUllble to dlSllbled Individuals Imvlnll bualness before the Court, pleftSe contact our office. All arranllements must be made at lenst 72 hours prior to any hearlnll or bualnesa before the Court, You muat allend the scheduled conference or hearlllll' YOU SHaULl) 1'AKE TillS PAPER TO yaUIl LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYEIl 011 CANNOT AFFOllD ONE, GOTOOn TELEPIIONETHE OFFICE SET FORTH BELOW TO FIND OUT WHElm YOU CAN GET L~;GAI, HELP. Office of the Court Adminlstrntor Cumberland County Courthouae Fourth Floor CnrUale, PA 17013 (717) 240.6200 II': , , I. '. "- i. . ,'tl~'.t ," . Ii , 'I IJ" ROD EUGENE INGRAM, 1 IN THE COURT OF COMMON PLEAS OF Plaintiff 1 CUMBERLAND COUNTY, PENNSYLVANIA 1 v. 1 CIVIL ACTION - LAW 1 ALISA DAWN INGRAM, 1 NO. 2425 CIVIL 1995 Defendant 1 1 CIVIL ACTION - CUSTODY COURT ORDER AND NOW, this , z. wJ day of Y>>;</7' consideration of the attached Custody Conciliation ordered and directed dS followsl , 1996, upon Report, it is 1. This Court's prior Order of August 8, 1995, shall remain in effect subject to the following revision of paragraph 21 A. The Mother shall enjoy physical custody with the minor child at such times as agreed upon by the parties. These times shall be a minimum of every other weekend from Friday at 6100 p.m. until Sunday at 6100 p.m., along with holiday time and sununer vacation and birthday arrangements. Father should handle this arrangement in a liberal fashion so that the child has an opportunity to be with the Mother as much as possible. B. When the child is not with the Mother, the Father shall have custody of the minor child. C. The Mother should attempt to give the Father as much notice as possible of when she intends to exercise physical cuetody and any required changes in a previously scheduled time when she is to have custody. ROD EUGENE INGRAM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW : ALISA DAWN INGRAM, : NO. 2425 CIVIL 1995 Defendant : : CIVIL ACTION - CUSTODY PRIOR JUDGE: HONORABLE KEVIN A. HESS CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The information pertaining to the child who is subject of this litigation is as follows: Shannon Marie Ingram, born January 26, 1993. 2. A Conciliation Conference was held on May 9, 1996, with the following individuals in attendance: The Father, Rod Eugene rngram, with his counsel, David spotts, Esquire, and Joan Carey, Esquire, who was representing the Mother. 3. Attorney spotts indicated that service of the Conciliation Order scheduling the hearing was made upon the Mother by regular mail at her last known address. Attorney spotts also indicated that Mr. Ingram had spoken to the Mother and that the Mother acknowledged that she was aware of the Conciliation Conference. Attorney Carey indicated that the Mother has not been in touch with ller office concerning this matter and, in light of the Mother's failure to contact her attorney, Legal Services, Inc. may be petitioning to withdraw in this uase. 4. The parties were previously before the Conciliator in August of 1995, at which time a custody arrangement was agreed upon. Father now suggests that Mother has not been abiding by the prior schedule and that, in fact, Mother's time with the child has been more limited than what the August 8, 1995, order provided. Father merely wants a revised order to ref.lect what is in faot happening with respeot to physioal custody.