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.
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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.
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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
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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
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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
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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
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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
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ROD INOItAM,
PlalnUlT
: IN TilE COUIlT OF COMMON PLEAS
: CUMnEltLAND COUNTY,PENNBYlNANIA
: CIVIL ACTION. LAW
'I y,
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ij ALIBA INGHAM.
;1 Ilcfcmlllnl
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: 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
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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
.
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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.
.
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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
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avid J. Bpot~~
32 Bouth Bedford Street
Carlisle, PA 17013
(717) 245.9888
Attorney for Plainllffs
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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
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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.