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Thomas E. Chaffins, Esq.
COURT ADMINISTRATOR
ONE COURTHOUSE SQUARE
CARLISLE, PA 17013
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JIM D. MORTENSEN and
DARLA H. MORTENSEN,
Plaintiff
vs.
SANDA SUE MORTENSEN,
Defendant
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 95-4639 CIVIL TERM
CIVIL ACTION - CUSTODY
ORDER
AND NOW, this Jri..tJ... day of J:)R.r.-Ltv ,1995, upon
consideration of the attached Custody Conciliation Report, It is ordered and directed
as follows:
P,lmary custody of the minor child, Tarah Nicole Mortensen,
d.o.b. 19 April 1983, is granted to her maternal grandparents, Jim D.
and Daria Mortensen.
Either party may request a hearing on this matter in the event
that the Custody Complaint and Order are successfully served upon
the natural mother, Sanda Sue Mortensen.
Joseph L. Hitchings, Esquire
Ms. Sanda Sue Mortensen
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BY THE COURT,
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TRUE C~py FROM RECORD
In Tcstim~:1Y \ h r:,af. I h. r,' 1):1!0 set my hand
and the seal of sa:d (0'1rl at Carli!lc Pa
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lhis H.13 H ,day of.f0,g~,:"" 19.9.f.
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
JIM D. MORTENSEN and
DARLA H. MORTENSEN,
Plaintiff
SANDA SUE MORTENSEN,
Defendant
NO. 95-4639 CIVIL TERM
CIVIL ACTION - CUSTODY
JUDGE PREVIOUSLY ASSIGNED: None (No Judicial Conflicts)
CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8(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:
NAME
BIRTHDATE
CURRENTLY IN
CUSTODY OF
Tarah Nicole Mortensen 19 April 1983
Plaintiffs/Grandparents
2. A Conciliation Conference was scheduled for 7 December 1995,
3. Items resolved by agreement: None.
4. Issues yet to be resolved: None currently.
5. The Plaintiffs' position on custody Is as follows: The Plaintiffs are the
grandparents and need to have a custody order so that insurance can be obtained
for the child.
1
,
,-
6. The Defendent's position on custody Is as follows: Unknown.
7. Need for separate counsel to represent child: None requested and the
Conciliator does not believe It Is necessary.
8. Need for Independent psychological evaluation or counseling: None
requested and the Conciliator does not believe It Is necessary.
9. Other matters and comments: This Is an unusual case. The grandparents
have had custody of their 12 year old granddaughter since 1989. The grandfather
was recently transferred to Pennsylvania. The natural mother continues to reside In
California.
The natural mother turned the child over to the grandparents because of
recurring drug addictions. Apparently the natural mother essentially lives on the
streets. The parents have sporadic contact with their daughter. Their daughter
Indicated to them that she would sign a stipulation so that they could obtain
custody. Their attorney forwarded a custody stipulation to her in California at the
grandfather's last business address, but she has failed to pick the stipulation up,
She also has had no contact with the parents since that date, which was some
time In September, 1995.
The grandfather needs to have a custody order so that he can obtain health
Insurance for the minor child. An order granting him custody wlli not prejudice the
2
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OIOOSI-OOOOI/Au~u.128, 1995IJLH/MH/46098
1M D, MORTENSEN and
ARLA H. MORTENSEN.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
NO, 95- 4 ~ 37 CIVIL TERM
CIVIL ACTION - CUSTODY
Plaintiffs
Y5.
ANDA SUE MORTENSEN.
Defendanl
ORORR OF COURT
AND NOW, upon consider...illn of lhe allached Complaint. it is hereby directed that the parties and their
respective counsel appear hefllre M ic. \.-C<f' L go 'l'.IS t-~,. . the Conciliator, on the aj1JJday
f Octcbe'l'" . 1995. at L/ P.m. L"!Jffi.~-.18"h51:(N,pH,I'Af)or of the ClIl"'hprland County
CllllrlhllU~9 I f"nllrthllll<p '>IIUUV, C'lrlirle, Pennsylvania, fllr a Pre-Hearing Cuslody Conference. At such conference,
an effort will he made to resolve the issues and disputes; or if this cannot be accomplished. to define and narrow the
issues III he heard by the Courl, and to enler into a temporary Order. All children age five or older ~ralso be
present at Ihe conference. Failure III appear at the cllnference may provide grounds for entry of a lemporary or
permanent Order.
For Ihe Court.
By: ~ttc:h ~cL,i J..,g..etn'i1..Jf'~(
Custody ConclIialor ~. I
YOU SIIOUI.D TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORO ONE, GO TO OR TELEI'1I0NE TilE OFFICE SET FORTH BELOW TO
FIND om WIIERE YOU CAN G1IT LEG,\L IIEI.I'.
Cuurt Adminisualllr
Cumherl:md County Cllurlhouse
I CllUllhlluse Square
C.lrlisle. Pennsylvania 17013.3387
Telephone: (717) 2~0.6200
SEP 6 2 57 PH '95
Of T:I ~ '-I~~' 9' flCE
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OIOO~I.OOOOII^u~u.t :8, 199"JLlI/MII/46098
. .
6. The relationship of the Pl:lintiffs to the minu, child is that of maternal grandparents. The Plaintiffs
currenlly reside with the folluwing persons:
~
Relationshin
Granddaughter
Tarah Nicule Monensen
7, The relalionshipof Defendant to Ihe minor child Is that of mother. II is unknown with whom the
Defendanl currently resides.
8. During Ihe pasl five (5) years, the minor child has resided with Ihe following persons and at the
following addresses:
~
Address
Period of Time
Jim D. Monensen
Daria H. Monensen
28232 Paseo Andante
San Juan Capistrano, CA 92675
April 1989-July 1995
Jim 0, Monensen
Daria H. Monensen
1312 Kiner Boulevard
Carlisle, PA 17013
July 1995 to present
9. The Plaintiffs have nut paniclp:lled as a pany or witness, or in another capacity, in other litigation
cuncerning the cuslUdy of the child in this or another coun.
10, The Plaintiffs have no informatiun of a custody proceeding concerning the child pending in a coun of
Ihis Communwealth.
II. The Plaintiffs do nul knuw uf a person nut a pany to Ihe proceedings who has physical custody of the
child or claims tu have custudy or visiulliun rights with respect to the child.
12. Each knuwn pllrent whuse parental rights to the child have not been terminated and the persons who
have physlc;d custody of the child hllve heen mImed as pllnies to this action.
OIOO51-0000I/Au~u.1 ~8, 1995/ILH/MII/46098
. ,
13. The hesl Inlere.~t ami permanenl welfare of the child will be served by granting the relief requested
because Plaintiffs are the minor child's primary custodians and care givers and such a custody orde, would officially
confirm Ihe panle.~' arrangements.
WIIBRBFORB, Plaintiffs, Jim D. Monensen and Daria H. Monensen, respeclfully ,equest this Coun to grant
them primary physical custody of Iheir minor granddaughler, Tarah Nicole Monensen.
Respeclfully submiued,
JOHNSON, DUFFIE, STEWART & WEIDNER
Date: i'-~ S~ q ~
By:
seph L. Hllchings
I\uorney I,D, No. 65551
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
Telephone (717) 761-4540
Auorneys for Plainllffs
OIOO"-f)OOOIIAuGu.117, 1995IJLH/MIl/46098
.
VP.RIFICATION
,
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We, :ktme6 0, Mortensen and Daria H, Murtensen, verify thai the statements made in the foregoing Complaint
for Cuslody are true and correct to the best of our knowledge, Infurmatlon and belief. We understand that false
stalements herein are made subject 10 the penalties of 18 Pa.C.S. 64904 ,elating 10 unsworn falsllicallon 10 authorities,
Date: ~() ~
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Dale: 'J<J A-u/.
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Daria H. Mortensen
JIM D. MORTENSEN and
DARLA H, MORTENSEN,
Plaintiff
vs,
SANDA SUE MORTENSEN,
Dafendant
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 95-4639 CIVIL TERM
CIVIL ACTION. CUSTODY
ORDER
AND NOW, this I :dL day of i),.u ~., t ,d , 1995, upon
consideration of the atteched Custody Conciliation Report, it is ordered and directed
as follows:
Primary custody of the minor child, Tarah Nicole Mortensen,
d.o,b. 19 April 1983, is granted to her maternal grandparents, Jim D.
and Daria Mortensen.
Either party may request a hearing on this matter in the event
that the Custody Complaint and Order are successfully served upon
the natural mother, Sanda Sue Mortensen.
BY THE COURT,
J.
Joseph L, Hitchings, Esquire _ ~ .-n\.<'...:e...t
Ms. Sanda Sue Mortensen ~-lJ
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6. The Defendant's position on custody Is as follows: Unknown.
7. Need for separate counsel to represent child: None requested and the
Conciliator does not believe it is necessary.
8. Need for independent psychological evaluation or counseling: None
requested and the Conciliator does not believe it is necessary,
9. Other matters and comments: This is an unusual case. The grandparents
have had custody of their 12 year old granddaughter since 1989. The grandfather
was racently transferred to Pennsylvania. The natural mother continues to reside In
California.
The natural mother turned the child over to the grandparents because of
recurring drug addictions. Apparently the natural mother essentially lives on the
streets. The parents have sporadic contact with their daughter. Their daughter
indicated to them that she would sign a stipulation so that they could obtain
custody. Their attorney forwarded a custody stipulation to her in California at the
grandfather's last business address, but she has failed to pick the stipulation up.
She also has had no contact with the parents since that date, which was some
time in September, 1995.
The grandfather needs to have a custody order so that he can obtain health
insurance for the minor child. An order granting him custody will not prejudice the
2
rights of the mother to open up the matter in the event that she shows any desire
to reacquaint herself with her daughter.
Date: 11 December 1995
~ujJ { ~2
Micliael L, Bangs
Custody Conciliator
3