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BOBBY WHITE,
Defendant
AND NOW, this 1}.f:y of
the attached Custody
directed as follows:
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PATRICIA RICHWINE,
Plaintiff
tIN THE COURT OF COMMON PLEAS OF
tCUMBERLAND COUNTY, PENNSYLVANIA
t
tNO. 3149 - CIVIL - 1995
t
t
tCIVIL ACTION - CUSTODY
v
, 1995, upon consideration of
Report, it is ordered and
1. Pending further Order of this Court, this Court's temporary
Custody Order entered July 5, 1995, shall remain in effect
subject to the following modificationst
A. The alternating weekends shall end on Monday at 2130 P.M.
instead of 3 P.M,
B. Father shall also have temporary custody on every
Wednesday from 6 P,M, until 9 P.M,
C. The parties shall share transportation with the non-
custodial parent picking the child up. Father will
handle transportation on Wednesday evenings,
D. Both parties shall keep the other party advised
concerning their living arrangements and location of
their home.
A He~ring is ~pheduled in this case in Courtroom No. 3 on the
~ day of t>t i-r'Il',\,,- , 1995, at I {dfJM. at which time
testimony will be taken, At this Ilearing, the Father, Bobby
White, Jr" shall be deemed to be the moving party and shall
proceed initially with testimony, Counsel for the parties
shall file with the Court and opposing counsel a Memorandum
setting forth the history of custody in this case, the issues
to be addressed by the Court, each party's position with
respect to custody, a list of witnesses that will be called to
testify and a summary of the anticipated testimony of each
witness. This Memorandum shall be filed at least ten days
prior to the Ilearing date.
BY
David J, Spotts, Esquire
Joan Carey, Esquire
offer
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DATE
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,IN THE COURT OF COMMON PLEAS OF
,CUMBERLAND COUNTY, PENNSYLVANIA
,
,NO. 3149 - CIVIL - 1995
,
,
,CIVIL ACTION - CUSTODY
JUDGE GEORGE E. HOFFER
PATRICIA RICHWINE,
Plaintiff
BOBBY WHITE,
,O.,fendant
PRIOR JUDGE'
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 pertinent information pertaining to the child who is the
subject of this litigation is as follows,
Brooks Allen White, born May 6, 1991,
2. A Conciliation Conference was held on August 17, 1995, with
the following individuals in attendance'
The Father, Bobby Allen White, Jr" with his counsel, David
spotts, Esquire, and the Mother, patricia Richwine, with her
counsel, Joan Carey, Esquire.
3. There is currently a temporary Order in place. The Father is
seeking primary physical custody. The Mother feels that she
should maintain primary physical custody. The parties are at
odds on a number of issues and a Hearing is necessary.
4. The Conciliator recommends an Order in the form as attached.
,IUN 1 2 /!/95
\..
PATRICIA RICHWINE,
Plaint if f
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95- ~/f( CIVIL TERM
CUSTODY
v.
BOBBY WHITE,
Defendant
PRMCJl'lLTQ PRoctam IN _.fORMA pA.\U'Jm 113
To the Prothonotary:
Kindly allow, PATRICIA RICHWINE, Plaintiff, to proceed in
forJl\!! pauP!lri...
I, Joan Carey, attorney for the party proceeding in forma
pauperis, certifY that I believe the party is unable to pay the
costs and that I am providing free legal services to the party.
The party's affidavit showing inability to pay the costs of
litigation is attached hereto.
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. Joan Carey /j
Attorney for Plaintiff
LEGAL SERVICES, INC.
a Irvine RoW
Carlisle, PA 17013
(717) 243-9400
PATRICIA RICHWINE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-~IL/lj CIVIL TERM
CUSTODY
v.
BOBBY WHITE,
Defendant
ArI1.P..AYJ'l'"llUHll'PORT _9f.._.P.RrIU!lll
19R..t.J;;A V It T.Q )'RQ<:: RRP I Ii f'QRMA..J.'A!lI'ERlll
1. I am the plaintiff in the above matter and because of my
financial condition am unable to pay the fees and costs of
prosecuting, defending, or appealing the action or proceeding,
2. I am unable to obtain funds from anyone, including my
family and associates, to pay the costs of litigation,
3. I represent that the information below relating to my
ability to pay the fees and costs is true and correct.
(a) Name : ~ttl.gj,a Ric\ll41nlL______,
Address: 159 Bie SPIlne Terrace
,__Newvi.1le I YA, lU..i,l__,_u_, _m
Social Secur i t Y Number I .~.11J.,::~.=.ll.7 3
(b) If you are presently employed, state
Bmployer: ,tl9miL.__,___ .,._,
Address: _H/A. ......_.__'
Salary or wages per month :N/-^- ,_.' ____,,,_
Type of work: Ii/A
If you are presently unemployed, state
Date of last employment: 1991
Salary or wages per month: ,'J~!L!HLum
Type of work: ,~a\lIhi!l,L_ 'u.__~_____
(e) Other income within the past twelve months
Business or professionlN/A
Other self -employment :,N/A ..",..-,
Interest:N/'" ,'..___,_
Dividends: filA ...._,_ _._____
PenBion and annuities: NIA_
Social Security benefits:.JIlA_,__
Support payment a : _, UlHL!!Q.____,___
Disabllit y payments: NI ^ ,,, _,__
Unemployment compenaation and
supplemental bend its: N/,." ,......,..,_____
Workman I 6 compenaa t ion: ..JiIlL___.
Public Assistance: ,'37cn,OQ_"....,___,
Other: _ li/A
(d) Other contributions to household support
Wife Husband Name: NgrHL ,
If your (huaband) (wife) is employed, state
Bmployer: Nons
Salary or wages per month:
..NoM,
Type of work:
N91\I) , ,__,,__
Contributions from children: _KQn~,
(e) Property owned
Cash: "_,,I'!.onII, ,_,
Checking Account: ,Npo!!.
Savings Account: None
Certificates of Deposit: Non!!""....,
Real Batate (including home) I Jilln,_,..,__,__"
Hotor vehicle: Make Ngne
Year
Cost
Amount owed
Stocks; bonds: Nons
Otherl N9nll
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTV, PENNSVLVANIA
NO. 91"- -)}'-I'I CIVIL TERM
CUSTODY
Patricia Richwine.
Plaintiff
v.
Bobby White,
De fend ant
TIDi~RLC!HiTQPY_ Q.RI2f1R
AND NOW, thiS..('J_..,_ day of June, 1995, upon
consideration of the Petition for Special Relief, temporary
custody is granted to the plaintiff pending further Order of
Court, and the defendant is ordered to return Brooks Allen White
to the plaintiff's custody immediately. The police are ordered
to facilitate the return of custody to the plaintiff.
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Patricia Richwine,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
v.
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 91- WI't' CIVIL TERM
CUSTODY
Bobby White,
Defendant
r.ltIU,QILl'QLSP.E!; I^I. ..R!~HijF
The Plaintiff, by and through her attorney, Joan Carey, of
Legal Services, Inc., represents the following:
1. The plaintiff, Patricia Richwine, hereinafter referred
to as the mother, resides at 159 Big Spring Terrace, Newville,
Cumberland County, Pennsylvania.
2. The defendant, Bobby White, hereinafter referred to as
the father, resides at an address unknown to the plaintiff.
3. The parties are the parents of Brooks Allen White, the
child.
4. A Complaint for CUBtody was filed in the above-captioned
matter simultaneously with this Petition. A conciliation
conference will be scheduled.
5. The mother has been the primary caretaker of the child
from his birth in May 6, 1991, until approximately May 29, 1995,
when the father refused to return the child to his mother after a
visit with him.
6. The father is not acting in the best interest of the
child by keeping the child in hiding and denying him contact with
hiB mother.
7. Since approximately May 29, 1995, the mother has made
attempts to have the child returned to her custody, in ways
'.' a. '~:~:--"
including the following:
a. The mother has made repeated requests of the
paternal relatives to have the child returned to
her custody, and they have refused to do ao or inform
her of the child's whereabouts or wellbeing.
b. The mother has gone to the residences of the
paternal relatives to find the child, including the
grandparents where the father took the child when he
visited with him, and they have refused to reveal the
child's whereabouts.
B. The mother has concerns regarding the well-being of the
child for the following reasons:
a. The father has never provided long-term care for the
child.
b. The father has relatives residing outside of
Pennaylvania and the mother fears that the father will
remove the child from this jurisdiction.
c. The father is denying the child any contact,
including telephone contact, with his mother and
siblings.
9. The mother does not know the father's whereabouts and
haa no way to serve the defendant of notice of custody
proceedings. Neither the police nor the Parent Locator Service
will assist the mother in locating the father without a court
order granting her custody.
WHEREFORE, the plaintiff requests that this court enter a
Temporary Order granting temporary custody of the child to the
The above-named plaintiff, PATRICIA RICHWINE, vurifies that
the statements made in the above Petition are true and correct.
The plaintiff understands that false statements huruln are made
subject to the penalties of 18 Pa, C.S. section 4904, relating to
unsworn falsification to authorities.
Date: j".,-=_~__ C\ ~
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Patricia Richwine, plaintiff
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Patricia Richwine,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 95- 1, I lj(,' CIVIL TERM
v.
CUSTODY
Bobby White,
Defendant
QRDBR OF "COJ!RT
AND NOW, upon consideration of the attached complaint, it is
hereby directed that the parties and their respective counsel
appear before u__fl'0',L.._L:._b.J~~'i..r...':'/~,,,-, the conciliator, at
_,Jlt.h.Jl~d.'",,Jd'.'.I",,,\"''''~n the L7j~_ day of _fl,~'J.0..1L_,
1995, at t7}'_A.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. Failure to appear at the conference may provide
grounds for entry of a temporary or permanent order.
B..:.Jge Court ('
~~/'iLt;& '-l~.4'r~
YOU SHOULD TAKB THIS PAPBR TO YOUR LAWYBR AT ONCB. IF YO~I
DO NOT HAVE A LAWYBR OR CANNOT AFFORD ONB, GO TO OR TBLEPHONB THE
OFFICE BET FORTH BBLOW TO FIND OUT WHBRB YOU CAN GET LEGAL HELP.
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 11013
TELEPHONB NUMBER: (717) 240-6200
WRI Cl\tHL IiI TlLJU sMU J..l.T IIH! ..M:'L ,Qf...1.2.'LQ
The Court of Common Pleas of Cumberland county is required
by law to comply with the Americans with Disabilities Acto of
1990. For information ahout 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 scheduled hearino or
buainess before the court. You must attend the scheduled
conference or hearing.
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plaintiff to
Andrew Giant,
Tasha GIant
(plaintiff's child)
Breann8 GIant,
(plaintiff'a child)
11/91 - 5/95
16 Countryview Estates
Newville, PA
defendant
Unknown
5/23/95-present
The mother of the child is Patricia Richwine, currently
residing at 159 Big Spring Terrace, Newville, Pennsylvania.
She is single.
The father of the child is Bobby White, his whereabouts are
unknown to the plaintiff.
He is single.
4. The relationship of plaintiff to the child is that of
mother,
5. The relationship of defendant to the child is that of
father.
The plaintiff currently resides with the following persons:
Name
Rel~UQrLQh.1P
boyfriend
daughter
daughter
mother
mother's boyfriend
sister
Andrew Glant
Tasha GIant
Breanna Glant
Joyce Hiller
Norman Wilson
Tanya Richwine
6. Plaintiff has 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.
1. Plaintiff has no information of a custody proceeding
concerning the child pending in a court of this Commonwealth.
8. Plaintiff does not know of a person not a party to the
proceedings who has physical clIstody of the child or claims to
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Patricia Richwine,
Plaint i ff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-3149 CIVIL TERM
v,
Bobby White,
Defendant
CUSTODY
CQN!iJ;,tHA~R!:J:.MUn
This Agreement is entered on this
S day of July, 1995,
by the plaintiff, Patricia Richwine, and the defendant, Bobby
White, The plaintiff, hereinafter referred to as the mother, is
represented by Joan Carey of LEGAL SERVICES, INC.; the defendant,
hereinafter referred to as the father, is represented by David
Spotts of the Law Offices of Ron Turo. The parties agree to the
entry of a Temporary custody Order providing for the following
custody schedule for their child, BROOKS A. WHITE.
1. The mother shall have primary physical custody and
shared legal custody of the child.
2, The father shall have partial physical custody and
shared legal custody of the child every other weekend
from Saturday at 9:00 a.m. to Monday at 3:00 p.m.,
commencing July 8, 1995, conditioned upon his giving
t he mot her t he name, add/'ess. and phone number of the
person at whose residence where the child may be
contacted while the child is in his custody.
3. The father shall not take the child out the state
of Pennsylvania without obtaining written permission
from the mother.
4, The Temporary Custody Order shall romain in effect
pending further Order after a conciliation conference,
5, The Consent Agreement shall not be deemed an
agreement of the parties regarding final
resolution of this matter and shall in no way affect
any rights of either party in future proceedings,
6, The mother and father agree that each shall notify
the other of all medical care the child receives while
in that parent's care. Each parent shall notify the
other immediately of medical emergencies which arise
while the child is in that parent's care.
7, The parties realize that their child's well-being
is paramount to any differences they might have between
themselves. Therefore, they agree that neither party
shall do anything which may estrange the child from the
other parent, or injure the opinion of the child as to
the other parent or which may hamper the free and
natural development of the child's love or respect for
the other parent,
WHEREFORE, the parties request that a Temporary Custody
Order be entered to reflect the above terms.
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patricia Richwine, Plainti ff
A!:~/d-~ t, ,~-,_
Bobby W ite, 0 ~~n.t ~ '~~7
~ /) '. "/1 quo
Law Offices of Ron Turo
I 32 South Bedford Street
Carlisle, PA 17013
(717) 245-9686
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Joan Cafey 0
PhilipC. Briganti
Attorneys for Plaintiff
LEGAL SERVICES, INC,
8 Irvine Row
Carl isle, PA 11013
(117) 243-9400
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PATRICIA RICHWINE,
Plnlntlll'
I IN THE COURT OF COMMON PLEAS
I OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
v.
BOBBY WHITE
Defendant
NO. 95.3t49 CIVIL TERM
IN CUSTODY
ORDER OF COURT
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AND NOW, this ~ day of
. 1995, upon
consIderation of the attached Motion for ContinUWlce, it Is hereby directed that this action sholl be
continued untll completion of the custody evaluation IUld home study. Upon comptetlon of the custody
evaluation IUld home study, attorney for the Defendant shall notify this Court and counsel for the Plaintiff.
st which time the motter shall be rescheduled for 8 hearing.
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PATRICIA RICHWINE,
Plaintiff
IN THE COURT OF COMMON PI,EAB
OF CUMBEHLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
v.
BOBBY WHITE
DefendlUlt
NO. 95.3149 CIVIL TERM
IN CUSTODY
AFFIIlA VIT
Your aIllant, David J. Spotta, Esquire, attorney for the Defendant herein, being flrst duly sworn,
deposes IUld states that:
1. I lUll the attorney for the DefendlUlt herein, Bobby Allen WhIte, Jr. The above-captioned
matter has also been combined with No. 05.3085 Civil Term, in the Court of Common Pleas of Cumberland
County, In which Bobby Allen White. Jr. is the PlainlllT.
2. A conciliation hearing was held on August 17, 1095, but the matter was not sble to be
resolved at that stage.
3. Aner the conciliation hearing, Bobhy Allen WIute, Jr., Defendant, contacted IUl
independent expert, Guidance Associates, 412 Erford Hoad, Crunp Hill, Pennsylvania, 17011, to initiate a
custody evaluallon, to determine If the best interests 8I1d needs of the child were heing met by the current
custody arrangement.
4. Guidance Associates indicated they would need approximately two months to complete a
custody evalunllon, Including" home study, also advising they could not be ready by October 26, 1995, the
scheduled hearing date.
6. On Septemher 25, WIJ5, I conlllcted a represenlllllve of Legal Services, Inc., attorney for
PlnlnlllT, advlsln/l them ufthe sltualluninvolvlng the evaluallon and hume study Rnd requesllng agreement
for a COnllmlRlICe unlU the home study Rnd eVRlunllon could be completed. In thRt call, I WRB sdvised that
they did not feel this would he n pro hi em, hut thnt they would cnllme back with n final decision.
O. (luring the we,'k "fSeptemher 25, JIJ1J5, I plnced several more calls to Legal Services, Inc.
nttempllng to get a final answer "n this mnlter, without slIccess.
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PATRICIA RICHWINE,
PIalnLlfT
IN TilE COUIlT OF COMMON PLEAS
OF CUMnEIlI.AND COUNTY,PENNSYLVANIA
CIVil, ACTION. I.AW
v.
BOnny WIIITE
Defendant
NO. 95.3149 CIVIL TEIlM
IN CUSTODY
ct:Jll'IFIC^l'l~ 010' SMlVICI~
I cerLlfY that I served a copy or the Mollon for Conllnnance by deposltlng same In the United
1'0-
Slates Mall, first cJasa, postage prepaid from Carlisle, Pennsylvanln, on the \ \ day of October,
1995, addresaed as follows:
.,
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Joan E. Carey, Esquire
Legat Servlceti, Inc.
8 Irvine Row
Carlisle, PA 17013
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Attorneys" Counselors At La",
32 Boulh IIedfold II1rtet
CIrhIe, PA 17013
(71 n 245-8688
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PATRICIA RICHWINE,
PIRlntllT
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY. PENNSYLVANIA
v.
.
.
: CIVIL ACTION. LAW
BOUBY WHI'rE
Defendant
.
.
: NO. 95.3t49 CIVil, '1'ERM
: IN CUSTODY
OIlDEIl
AND NOW, \hls b t-. day of \lj /1~ i 1995, ilhclU 11011
\ t- -VJ (r)vdjlc& IV. (-'\.~, 1 I\J) ) ,-(-tAl I J..4A.. Lh t I!. /
ie-eet forth!!" .day of .,' - ' . . l1llJli at -,- -" '.Iutt
\J o\.}~ '-1 \4 '...u~ I ~ ,)v- . tAI.J
_~M., in Cour4fooom Na. of, ",e CumberlaMl County Cour~ouse, Carl'.'9, P~lwHlin, In
COIl8idePntlon of.the sUaohed Petition-ful l'l1'\....1lII'nmr."1'endiJijtllam"; It ~lId Is not to be removed
'A_""+1LW....l.. (,,>~'1'
from the Commonwenlth of Pennsylvnnln by either party tG1Uus acUon. ' ""'
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BY THE COURT:
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PATRICIA RlCIIWINE,
1'lninUlf
IN TilE COUHT m' COMMON PI,t:AS
m' CUMDEIU..ANI> COUNTY, PENNBYINANIA
CIVIL AC'J'ION . LAW
NO. 115.3t49 CIVil, "EHM
IN CUSTOI>Y
v.
DaDDY WHITE
I>efendllnt
PETITION t'OIl SI't:CIAL IlEUt:t'
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'I Offices of Ron Turo, who reque8t a PeUtlon for Special Hellef a8 follow8:
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AND NOW, come8 the I>efendant, Bobby A. White, Jr., by and through hl8 allorlleY8, the Law
1.
PetltlonermefendRntls Bobhy A. White. Jr., an adultlndlvldlUtI. currently re81dlng at12
Bprlngvlew Rond, Cnrllsle, Cumherland County, Penn8ylvanla.
2.
On July 5,1905, the Courtl88ued an Order ofCu8tody and Vl8ltnUon, which WR8 RIllended
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II by further Order of Court on August 24, 1005, providing for 8hared cU8tody In the parents, and with
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phY8ical cU8tody In the mother, Patricia IUchwine, and v18ltRUon right8in the father, Bobby A. White, Jr.
3.
Fsther hR8 Informntlon tlmt mother Intend8 to leave the 8tRte In the nefti' future,
spcculCRIly to go to "eXR8. without a modificaUon of the Court Order.
4. Mother hR8 not advl8ed father of any of her IntellUon8 or plnns.
5. The Order of July 5, 1095 contai1l8 a prohibition preventing the father from removing the
child from the Commonwenlth of Pennsylvania. Cou1l8el for the mother Indicated that the mother had no
plans to remove the child from the Commonwenlth of Penn8ylvanill, hence a slmllftl' prohibition RgBinst
mother WR8 not 80ughl.
6. Attempt8 were made to have eoun8el for mother voluntarily agr('e to all entry OfM Order
proltlbiUng the relocation of the rhllil out of the Commonwealt h of pen1l8ylvanla. Coun8el for mother
fnlled to respond to the8e request8,
7. Leaving the state woulcl re8ult in an inahllity of the f.ther to exerel8e his lawful vlsltnUon
and otherwl8e Interfere8 with hi. right. uncler the Order.
8. Leaving the Juri..lIrtlonal area of the Court may Justify new provl81onl to ensure
eompliance with the vi.llntlnn, nncllll.o provlsion8 fnr trnn.pnrlntlnn ro.ts alii! ol'prol'rillte IIIlIollonl.
WHEREFORE, I'etllloner requests the Court to direct the I'lninlllf not leave the state until the
Court hll8 had 11I1 opportunity to hear the parlles with respect to modlncallonsln the custody and visitation
rights and to Issue a Modlficallon Order consistent with the best interests or the child.
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Date
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nespectrully submitted,
LAW OFFICES m' nON Tuna
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., t.AwOtflce afRon Turo
A~' cOun./clII AI Law
IIIolllh IMlonIIlIwt
CIrMlt, PA 17011' .' ~
(117) a4HMI
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CERTIFICATE OF SERVICE
I eertlly that I served n true and correct copy or the Pellllon For Special Reller by depositing same
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In the United States Mnll, first class, postage pre.pnld rrom Carlisle, Pennsylvania, on the G day
or December, 1995, addressed 118 rollows:
Joan E. Carey, Esquire
Legat Services, Inc.
a Irvine Row
Carlisle, P A 17013
LAW OFFICES OF RON TURD
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