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HomeMy WebLinkAbout02-4256STACY E. WILLIAMSON, Plaintiff PRIEST J. WILLIAMSON, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. O;t - q k '4, : CIVIL ACTION - LAW : IN CUSTODY NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property, or other rights important to you, including child custody, or child visitation. 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, PA 17013 Telephone: (717) 249-3166 STACY E. WILLIAMSON, Plaintiff PRIEST J. WILLIAMSON, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CHILD CUSTODY AND NOW comes the Plaintiff, Stacy E. Williamson, by and through her attorney, Kristin R. Reinhold, Esquire, and respectfully requests this Honorable Court award her custody of the subject minor child, and in support thereto, avers the following: 1. Plaintiffis Stacy E. Williamson, an adult individual residing at 21 Cottage Road, Mechanicsburg, Cumberland County, Pennsylvania. 17050. 2. Defendant is Priest J. Williamson, an adult individual residing at 250 Church Road, Etters, York County, Pennsylvania. 17319. 1998. 3. The subject child is Sydney Elainemarie Williamson, bom June 2, 4. The relationship of the Plaintiff to the subject minor child is that of natural mother. 5. The relationship of the Defendant to the subject minor child is that of natural father. 6. The minor child has resided at the following addresses, in the custody of the following individuals: A. From June 2, 1998 to January 2000, the subject minor child resided with both parents at 700 Cassel Road, Manchester, PA. B. From January 2000 to March 2000, the subject minor child resided with both parents at 1030 Mountaindale Drive, Marysville, PA. C. From March 2000 to September 1, 2000, the subject minor child resided with both parents at 707 Pear Street, Apt. 4, Lemoyne, PA. D. From September 1,2000 to May 2001, the subject minor child resided with the Plaintiff at 12 South Filbert Street, Mechanicsburg, PA, and with the Defendant at 250 Church Road, Etters, PA. E. From May 2001 to the present, the subject minor child has resided with the Plaintiff, Plaintiff's fiancee Dennis Kauffman, and Mr. Kauffman's two children at 21 Cottage Court, Mechanicsburg, PA 17050, and with the Defendant at 250 Church Road, Etters, PA. 7. There have been no prior actions for custody of the subject minor child in this or any other jurisdiction. 8. The Plaintiffis not aware of the existence of any other individuals who have any type of claim whatsoever regarding the custody of the subject minor child. 9. The Plaintiff believes and therefore avers that she is much better able to meet the needs of the subject minor child than the Defendant. 10. The Plaintiff believes and therefore avers that it is in the best interest of the subject minor child that she be placed in her legal and physical custody. WHEREFORE, Plaintiff requests this Honorable Court award her custody of the subject minor child. Respectfully submitted, THE LAW OFFICES OF SILLIKER & RErl%IHOLD 4.:ri 5922~Linglestown Road Harrisburg, PA 17112 (717) 671-1500 I.D. No. 57911 Attorney for Plaintiff AFFIDAVIT I, ~.~ 6a ~. W I'l],'O_~,.C~f~ hereby certify that the aforegoing is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. 4909 relating to unsworn falsifications to authorities. Dated: STACY E. WILLIAMSON PLAINTIFF PRIEST J. WILLIAMSON DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : : 02-4256 CIVIL ACTION LAW : IN CUSTODY .. ORDER OF COURT AND NOW, Friday, September 13, 2002 , upon consideration of the attached Complaint, it is hereby directed that par~ies and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Monday, October 14, 2002 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 hearing. FOR THE COURT, By: /si Melissa P. Gree~y. Esq. 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 FORT~t BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 STACY E. WILLIAMSON, Plaintiff V. PRIEST J. WlLLIAMSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4256 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this 'Z~"" day of Oc~,~,-~ ,2002, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Stacy E. Williamson and Priest J. Williamson, shall have shared legal custody of the minor child, Sydney Elainemarie Williamson, born June 2, 1998. 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 her health, education and religion. Pursuant to the terms of Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Pending further Order of Court or an agreement of the parties, the physical custody schedule which the parents have been following shall continue. 3. The Custody Conciliation Conference shall reconvene on December 2, 2002, at 12:30 p.m. at the office of the Custody Conciliator, Melissa Peel Greevy, Esquire, 301 Market Street, Lemoyne, PA 17043. BY THE COURT: Dist: Kristin R. Reinhold, Esquire, 5922 Linglestown Road, Harrisburg, PA 17112 Suzanne H. Griest, Esquire, 129 East Market Street, York, PA 17401 STACY E. WILLIAMSON, Plaintiff V. PRIEST J. WlLLIAMSON, Defendant OCT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4256 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, 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: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Sydney Elainemarie Williamson June 2, 1998 Mother 2. Mother filed a complaint for custody on September 5, 2002 because the parties have not been able to reach an agreement with regard to where the child will attend public school. Attending the October 15, 2002 conference were the Mother, Stacy E. Williamson, and her counsel, Kristin R. Reinhold, Esquire; the Father, Priest J. Williamson, and his counsel, Suzanne H. Griest, Esquire. 3. The parties were not able to reached an agreement which would resolve the physical custody and school choice issue at the conciliation conference. However, they mutually agreed to reconvene the conference after they had each had an opportunity to visit the elementary schools in their respective school districts where the child might be able to attend and to do sufficient research about the schools to make an informed decision. The parties were encouraged to participate in these visits with the schools together. 4. To the parties credit, they have worked out a mutually agreeable shared physical custody arrangement of some significant duration. The parties shall continue this arrangement pending further Order of Court or an agreement of the parties. Date -Melissa Peel Gree{/y, Esquire Custody Conciliator : 164323 STACY E. WILLIAMSON, Plaintiff V, PRIEST J. WILLIAMSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4256 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this ~"~F"' day of December, attached Custody Conciliation Summary Report, it is follows: 2002, upon consideration of the hereby ordered and directed as 1. Legal Custody. The parties, Stacy E. Williamson and Priest J. Williamson, shall have shared legal custody of the minor child, Sydney Elainemarie Williamson, born June 2, 1998. 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 her health, education and religion. Pursuant to the terms of Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Physical custody for the period from December 2, 2002 through the start of the 2003-04 academic year and for the summer 2004 and subsequent summers shall be arranged on a two-week alternating schedule as follows: A. To commence December 2, 2002, Week 1, Mother will have custody on Monday and Tuesday, Father will have custody on Wednesday and Thursday, and Mother will have custody for the weekend. B. To commence December 9, 2002, Week 2, Father will have custody on Monday and Tuesday, Mother will have custody on Wednesday and Thursday, and Father will have custody for the weekend. NO. 02-4256 CIVIL TERM C. Summer. Custody for summer 2004 and subsequent summers shall be arranged as follows: The schedule as described in Paragraph 2. A. and B. with Week 1 to commence the first Monday following school dismissal for the summer recess. D. To commence with the 2003-04 academic year, Mother shall have primary physical custody for each academic year. Father shall have partial custody two (2) evenings per week from after school until 8:00 p.m. and two (2) weekends per month. However, for the month of September, November, January, and April, unless otherwise agreed, Father shall enjoy three (3) weekends of custody per month upon seven (7) day's notice to Mother. E. Beginning with the 2003-04 school year, if the Father and child have a Monday or Friday holiday adjacent to Father's custodial weekend, Father's custodial weekend may be extended to include the holiday. For example, if the child and Father have a holiday on a Friday, Father's custodial weekend may begin on a Thursday evening after school, or if the child and Father have a Monday holiday, Father's custodial weekend may be extended to include Father returning the child to school on Tuesday morning. 3. Vacation. Each party shall be entitled to seven (7) continuous days of custody for the purposes of vacation during the school recess for summer, to include that parent's custodial weekend. The parties shall provide each other with thirty (30) days written notice of their intended vacation plans. In the event that there is a conflict in the planned vacation schedule or that the vacations would overlap, the party first providing written notice to the other parent shall have choice of the vacation. 4. In the event that either party will be enjoying a period of custody of 72 hours or more away from their home, that parent shall provide the other parent with notice of the telephone number where they can be reached and location where they will be during that period of custody. Such notice will be provided to the non-custodial parent before the custodial parent leaves their home. NO. 02-4256 CIVIL TERM 5. Holidays. A. Father shall have custody for Father's Day and his birthday. Mother shall have custody for Mother's Day and her birthday. The parties shall share time with the child on the child's birthday. B. The parties will share time with the child on Thanksgiving, Christmas and Easter as they may agree. 6. In the event the child does poorly academically at Cumberland Valley School District, the parents will consider a change of school district as an option to improve her performance, upon the recommendation of the professional educators familiar with the child. Dist: Kristin R. Reinhold, Esquire, 5922 Linglestown Road, Harrisburg, PA 17112 Suzanne H. Griest, Esquire, 129 East Market Street, York, PA 17401 / 2 -I5 STACY E. WILLIAMSON, Plaintiff V. PRIEST J. WlLLIAMSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4256 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, 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: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Sydney Elainemarie Williamson June 2, 1998 Mother and Father 2. A Custody Conciliation Conference which was scheduled as the result of an agreement reached at the Custody Conciliation Conference on October 15, 2002. Present at the second Conference on December 2, 2002 were: the Mother, Stacy E. Williamson, and her counsel, Kristin R. Reinhold, Esquire; the Father, Priest J. Williamson, and his counsel, Suzanne H. Griest, Esquire. Date The parties reached an agreement in the form of an Order as attached Melissa Peel Greevy, Esquire Custody Conciliator :165954