HomeMy WebLinkAbout95-06442
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN CUSTODY
MONIQUB N. MILLER,
Plaintiff
ERIC 1. GRILL,
Defendant
NO. 95-.?W"lCIVIL TERM
ORDER OF COURT
AND NOW, this I /fiGay of NlJ..t'll,IJCI; 1995, upon consideration of the Ittlchod
complaint, It Is hereby directed that the parties and their respective counllClllJllal' before,
D . <' \ ~ SI M~n"~1i
...""n '),:>..l'" "1, the conciliator, at ~'\ lv, """'In ' , lIIlIet Sellll'f C81l.tJluulC,
on the 1I.I\'liay of On (/1".1.('1995, at1:Otf}-m., for a Prc-Hearilll Custody Conference. At
such conference, an effort will be made to resolve the Issues In dispuU:j 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. Either party may bring the child(ren) who is the subject of this custody action
to the conference, but the child/children's attendance Is not mandatory. Failure to appear at the
conference may provide grounds for entry of I temporary or permanent order.
FOR THE COURT:
By: -D<-u.A'I,j 4.. .".1/1/1. ~~ Cj,.
Custody Conciliator- -, ~ cr..- ffJl/ (
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCB. IF YOU DO
NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TUB
OFFICB SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
OFFICE OF THB COURT ADMINISTRATOR
COURTHOUSE, 4th Floor
CARLISLE, PA 17013
717/240-6200
AMERICANS wlm DISABILITIES ACT OF 11190
The Court of Common Pleas of Cumberland County Is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled Individuals having business before the court,
plrasc contact our office. Ail arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the IiCheduled conference or hearing,
MonIque N. Miller 517 161h SIreet
Dee MiI1er (Mother) New Cumberland, PA 17070
SIIphen MiI1er (Father)
Stella ChcsnaIavlle (Grandmother)
5127189.2192
'Ibc mother of the child Is Monlquc N. Miller, currently rcsIdina It 252 B. Crcstwood
Drive, Apt. A8, Camp Hill, Cumberland County, PennsylVlllla 17011 .
She is slnlle.
The father of the child is Brie J. Grill, currently rcsIdina 11233 Lasher Road, Tivoll,
New York, 12572.
He is slnlle.
4. The relationship of the defendant to the child is that of father. The plaintiff bellova
that clcfendant resides alone.
S, The relationship of plaintiff to the child Is that of mother. The plaintiff cumatly
rcsIdca with the lubject minor child, Ralcsa Miller,
6. Defendant has not putlcl..ted u a party or witncu, or in another ClplCity, in other
IItlption concernln, the custody of the child In this or another court,
Defendant has no Information of I cUllody proceedina c:onccmina the child pcndlna in
I aJUrt of this CommonweaJth.
Defendant doca not know of a penon not a party to the proceedlnas who has physical
custody of the child or claims to have cUllody or visilltion ri&hts with reapcct to the child.
NOV 1 6 19Q5tP
v.
IN 11IB COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PBNNSYLV ANIA
CIVIL ACDON . LAW
IN CUSTODY
MONlQUB N, MIIJ..BR,
Plaintiff
BRlC J. GRIlL,
Defendant
NO. 9.5- ~~ Sf ~ CIVIL TERM
JlRAECIPE TO f'lOCIi'JrD IN
FORMA ....IPIl'...
To the Prothonotary:
Kindly IIIow Monlque N. Miller, Plaintiff, 10 prclCIlIICIln rorms ..uperis.
I, John C, Stevens, or the Family Law Clinic, studenl auorney fur the put)' prooeodllll
in furma pauperi., c:ertlry that I believe the put)' Is unable 10 ..y the COllI and thai I am
providlna r.. .... aervice 10 the JIII1y. 'The put)' 's affidavit ahowillllnabll1ty to ..y the COllI
or utlpllan Is aUIdIed hereto.
DUe: /1/zj:JS
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fled ~ntem
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ROBERT . RAINS
11IOMAS M, PLACB
KA11IBRiNB C. PBARSON
Supervlslna Attorney
GAIL R, SHBARER
Starr Attorney
11IB FAMILY LAW CLINIC
4.5 North Pitt Street
CarlI.Ie, PA 17013
(717) 243-2968
Fill: 243-3639
MONlQUB N, MILLER,
Plaintiff
IN mB COURT OF COMMON PLBAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACI10N - LAW
IN CUSTODY
v,
BRlC J. GRILL,
Defendant
NO. 95-
CIVIL TERM
AFFIDAVIT SUPPORTING PETITION FOR IRAVE
m maclurn INFOIlM4 rAIlPIl'.8m
I. I am the plaintiff In the above matter and becaUIC of my financial condition am
\llllble to pay the fClCl and COlli of ProlCCuUIlI or defendlRJ the ICtion or proceedlna.
2. I am unable 10 obtain funds from anyone, IncludiRJ my family and lIIorlstea. 10
pay die costs of IIt1ptiOll,
3. I represent that the InfonnaUon below relatiRJ 10 my abl1lty 10 pay the feel and
OOItIll true and correct.
(I) Name: Monlque N, Miller
Addresl: 252 B. Crestwood Drive
Apt. A8
Camp Hili, PA 17011
Social Security No,: 190-5().()850
.mployment
If you ue presently employed, state
Bmployer:
Addreas:
Salary or Wiles per month:
Type of work:
If you ue prelClltly unemployed, state
Date of lut employment: 1990
Salary or Wiles per month: $500.00 per month
Type of work: Sales Representative - TelecommunlcaUons
(0) Other Income within the past twelve months
Buslncll or profession: none
Other IIelf-employment: none
Interelt: none
Dividend.: none
Pension and annultiea: none
Soc1al security benefits: none
Support payments: $50,00 (first time rPIved In 2 112 Ylllll)
Disability payments: none
Unemployment oompensation and supplemental benefits: none
Workman's c:ompenlltlon: none
Public AullIanCe: $315.00 per month
Other:
Food Stamps: $212.00 per month
TuItion: $1,800.00 per ICI1ICIIU
(d) Other COIItributions to household support
(Wlfe)(Huaband) Name: N/A
If your (wife)(husband) Is employed, state
Employer:
Salary or Wllea per month:
Type of work:
Contributions from children:
Contributions from puents:
Other COIItributions:
(e) Property owned
CUb: $0.00
ChecklllllCCOllnt: $100,00
Savinas ICCOIIlIt: none
Certiflt:&tel of depoalt:
In RaIesa's name with First Federal Bank ($5(10,00 for education)
Real eatale (includlna home): none
Motor vehicle: Make ,Year none
Colt , Amount awed $
Stocb; bond.: none
Other: none
(I) Debts and obllaations
Mortalle: none
Rent: $117.00 per month
Cable: $22.93 per month
B1cc:tric: $65.00 per month
Phone: $57.00 per month
Food: $250.00per month ($2 12.00paid from Food Stamps)
Clothln.: $15.00 per month
Transportation: $50.00 per month
Day Care: $5.00 per month
Medical Expensea: $20.00 per month
Contribution to Father's Medical Expensea: $30,00 per month
lAJan.: none
Tuition: $1,822,00 per aemeater ($1,800.00 paid with Tuition Assistance)
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MONIQUB N. MlLLBR,
P1alndff
IN THB COURT OF COMMON PLBAS OF
CUMBBPLAND COUNTY, PBNNSYLV ANIA
CIVIL ACTION. LAW
IN CUSTODY
v.
BRlC J, GRIU.,
Defendant
NO, 95-6442 CIVIL TBRM
PRU'r1PE TO IIJ1NRTATE CUSTODY COMJ'LAINT
PIeue reinltate the Cullody Complaint of Miller v. Grill, docket number 95-6442.
To: Lawnnco B. Welker, ProIhonoCary
1996
Dale: ~h//9~
4
c. STBVBN
fled LepI Intern
R21f:(i(~
THOMAS M. PLACB
KATHBRINB C, PBARSON
Supervlsllll Attorney
GAIL R. SHEARER
Staff Attorney
THB FAMILY LAW CLINIC
.5 North Pitt Street
CarUlle, PA 17013
(717) 2.3-2968
Fax: 2.3-3639
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VI.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - CUSTODY
MONIOUE N. MILLER,
PlnlntiO'
ERIC J. GRILL,
Defendant
95-6442 CIVIL TERM
IN RE: MOTION FOR ENLAROEMENT OF TIME
ORDER
AND NOW, this
II GRANTED.
.2"1'
dny of March, 1996, thc within ll1otlon of the defendant
BY THE COURT,
Family Low Clinic
For the Plaintiff _ e.r~"" ~ 31;2& 141.. .
.J>' ll' ,
Erie J. Grl\1, Pro Se
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HONIQUE N. MILLER
Plantiff
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IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - CUSTOD~
ERIC J. GRILL
Defendant
NO. 95-6442
MOTION FOR ENLARGEMENT OF rIME
Now comes Eric Grill and states thst he is presently
incareratod at Allenwood Federal Prison Camp, Montgomery,
Pennsylvania and moves the court for a two week extensio._
to file memorandum to defend claim and rights in the above.
pending action.
CERTIFICATION
I certify that I have sent a true and attested copy of
this motion to plantiff's representative John C. Stevens
FAMILY LAW CLINIC, at 45 North Pitt Street, Carlisle, PA
17013-2943.
Ei;.." ~
Eric (Yo Gr
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MOOIQUE N. MILLER, I IN TilE COURT OF ca-IMOO PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
vs. I NO. 95-6442 CIVIL TERM
I
ERIC J. GRILL, I
Defendant t IN CUSTODY
(JU)8R OF mm
AND 101, this ~ day of ~ ' 1996, upon
consideration of the attached Custody Conciliation Reporl\ it is ordered and
directed as followsl
1. The Mother, Monique N. Miller, shall have sole legal and
primary physical custody of Raiesa A. Miller, born May 27, 1989.
2. The Father, Eric J. Grill, shall have periods of visitation or
partial custody with the Child only as mutually agreed by the parties.
3. Upon release from incarceration, the Fsther may Petition the
Court to enforce whatever custody rights he may have with respect to the
Child.
J.
CCI
John stevens, Legal Intern
_ ~~lL4
Eric J. Grill -u
MONIQUE N. MILLER,
Plaintiff
IN THE COUR1' OF cnIMClN PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 95-6442
CIVIL TERM
ERIC J. GRILL,
Defendant
IN CUSTODY
aJS'la)Y <XK:ILIATI<* BlIlIIARY REPOOT
IN AOCDUlANCB wrm aJtBI!RLMD <XUf1'l{ RULB OF CIVIL PRO.... (lIB
1915.3-8, the undersigned Custody Conciliator submits the following report I
1. The relevant information pertaining to the Child who is the subject
of this litigation is as follows I
NAME
BIRTHDATE
CURRENTLY IN CUSTODY OF
Raiesa A. Miller
May 27, 1989
Plaintiff/Mother
2. A Conciliation Conference was held on April 3D, 1996, with the
following individuals in attendance: The Mother, Monique N. Miller, with
her counsel, John Stevens, Legal Intern, Family Law Clinic with his
supervising attorney. The Father, Eric J. Grill, was served with the
Custody COI1'(Jlaint and Notice of the originally scheduled Custody
Conciliation. The Father filed a Motion for Enlargement of Time requesting
a two week continuance, in response to which the Conciliator scheduled a
later Conference date snd provided Notice to the Father. The Father is
currently incarcerated at the Allenwood Facility in Montgomery, PA.
3. In lieu of appearing at the conciliation Conference, the Father
submitted a proposed written agreement (a copy of which is attached hereto)
under which he agreed to relinquish all parental rights to the Child if he
were released from all responsibility for future child support and accrued
arrearages.
4. The Child was born out of wedlock and the Mother stated at the
Conference that the Father has not seen the Child since March 1993. The
Mother stated that she had just recently established a relationship between
the Child and her paternal grandfather who now has regular periods of
partial custody. The Mother does not currently intend to sign the proposed
Agreement submitted by the Father under which he would relinquish his
paternal rights with respect to the Child and, in fact, the Mother stated
that she filed this Petition to enable the Father to have visitation or
partial custody with the Child upon his release from prison.
5. The Conciliator recommends an Order in the form as attached.
DATE: //""....( SO. /77({' ((,~.. ,\ jj" .,('(<1"
. Dawn S. Sunday, EsquIre!
Custody Conciliator