HomeMy WebLinkAbout96-00444
~
L.
<..
~
.
.n
"7
-J
L.
~
I-
t
~
J
-::r
'7'
"::t:
.'
)-
~.
:
.'
~/
i!
.'
.~i.
,,;.
:,;
,,:.,i
\~
"
~~ II
~~~ I
ih~~ 19
~~ "' '"
;; c. J M l!l
.... .., -g ~ . ~:::
.... ~
.r< I 5 I' ." <
.., '(,Ill,- 5'"
I'~ . , fij II ., .
g! . ... ~
~~ tlS r~ 101. iii t " "
~ I~~ ~ ll' M -a
~ 0,.
J! Q:: ~
- ::... 11
. !aj;ld,..._
~I~" u . ...
! I") S
i
. . . ,
. .'
. .
i
I
i
,
I
EDWARD C. TERREL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs.
: NO. 96-444
CIVIL TERM
CARLA J. TERREL,
Defendant
.
.
: CIVIL ACTION - LAW
: IN CUSTODY
aIDER OF CXXlRT
AND Nai, this /(,. . day of
upon consideration of the attached Custody
ordered and directed as follows:
fIJ~ , 1997,
Conciliation Report, it is
1. The prior Orders of this Court dated Septenber 17, 1996 and
Decenber 18, 1996 are vacated and replaced with this Order.
2. The parties shall submit themselves and the Children to a
custody evaluation to be performed by Stanley Schneider, PhD, who was
selected by agreement of the parties and counsel. The Father shall be
responsible for the costs of the evaluation.
3. The Father, Edward C. Terrel, and the Mother, Carla J.
Terrel, shall have shared legal custody of John E. Terrel, born May 30,
1986, and Elizabeth C. Terrel, born July 5, 1988.
4. Pending further Order of this Court or agreement of the
parties, the Mother shall have primary physical custody of the Children and
the Father shall have visitation with the Children at the Mother's
residence and with the Mother present for four hours on alternating
Saturdays. For a portion of this four hour period, the Father may take the
Children to the school playground across the street fran the Mother's
residence or to the play area in the Mother's apartment canplex wi th the
Mother present.
5. If the Mother consents and is present, the Father may have
additional periods of visitation with the Children as arranged by mutual
agreement of the parties.
6. The Father shall have an additional period of visitation with
the Children on Christmas Eve fran 5:00 p.m. until 9:00 p.m. at the
Mother's residence with the Mother present.
7. The Father shall be entitled to contact the Children by
telephone every Wednesday evening at 7:00 p.m. and the Mother shall
cooperate in making the Children available for this scheduled telephone
call. The Father may also contact the Children by telephone at other
reasonable times as the Children are available. The Mother may be present
in the room with the Children but shall not directly monitor the Father's
telephone calls on the line.
8. The Father shall complete an approved sexual offenders
program as recommended by the Cumberland County Children and Youth
Services. The Father's voluntary participation in such a program shall not
be construed as an admission of any allegations.
cc: Jordan D. CUnningham, Esquire-for Father
Jan Terpening/Joan Carey, Esquire-for Mother
J.
9. Upon the conclusion of the custody evaluation and in the
event that the parties are not able at that time to establish custody
arrangements by agreement, either party may petition the Court to have this
case again scheduled with tho Custody Conciliator for a Conference.
C.<~_rro<C....C!..'<' 1t/17/'l?,
,...!l.1'.
.....
EDWARD C. TERREL,
Plaintiff
:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs.
NO. 96-444
CIVIL TERM
.
.
CARLA J. TERREL,
Defendant
: CIVIL ACTION - LAW
: IN CUS'roDY
PRIm JUDGE: Kevin A. IIeBs
CUSTODY aH:ILIATION 5U'IlARY REPCRT
IN ACCDUlANCE WITII cnmERLAND CXUlTY RULE OF CIVIL PIl() '","JRE
1915.3-8, the undersigned CUstody Conciliator submits the fOllowing report:
1. The pertinent information concerning the Children who are the
subjects of this litigation is as follows:
NAME
Dl\TE OF BIRTH
CURRPBl'LY IN CUSTODY OF
Elizabeth C. Terrel
John E. Terrel
July 5, 1988
May 30, 1986
Defendant/Mother
Defendant/Mother
2. As stated in prior Reports, this case involves a very difficult
family situation including serious issues/allegations which the parties
have been addressing in counseling for the Children and themselves. In
order to resolve the custody dispute, the Father has attended a seventy
week sexual offenders program (allegations denied) through Holy Spirit
Hospital. Recently, Children and Youth Services have become involved in
this matter in connection with the Mother's obligation to supervise
visitation, which has further complicated resolution of this case. The
parties are scheduled to begin a custody evaluation in December through the
office of Stanley Schneider, PhD. Several Conciliation Conferences have
been held over the last two years (without the necessity of a Hearing to
date) with the most recent Conference having been held on April 22, 1997.
The following individuals attended that Conference: The Father, Edward C.
Terrel, with his counsel, Jordan D. CUnningham, Esquire, and the Mother,
Carla J. Terrel, with her representative, Jan Terpening.
3. At the April 22, 1997 Conference, the parties agreed to
participate in a custody evaluation, although the issue as to whether the
Father would be able to pay the expenses of the evaluation was left open
for determination. It was also agreed that the existing order will remain
in effect without overnight periodS of custody with the Father for the
parties' son during the school year except upon the recommendation of the
evaluator. Additional changes to the existing order which are reflected in
the attached proposed order resulted from a telephone conference with
counsel for both parties on September 25, 1997.
4.
The COnciliator recommends an order in the form as attached.
~hnf ..dJ,M1r/~'r
wn S. Sunday, Esqu re
CUstody Conciliator
IVov&nbu 10 199 7
DATE .
~"r." r-"~'-
rll 'l..~'.rl
....._ l' ,~-',...' ....'1", ';"--:':"T" ""(
I '. " ~. . ,"
..., ",,' ,..,
qll~~\! t 1 /,1I G: L S
CUi ";":'1 " . ,,':: I"rrv
V:Ioo<_ .i..4" 'w'- .......'1
PEt',i'SI~'/A": A
~
il;~ ~
! ~ i I -~
~ ~ !
, ...
, t
~ I~
,
~
~
~
~~
II
". ,^
" ~ o!l _:!I
... 11 ~ ~!;
tp, ~..:
!It. 'II ,_ .
..1 . I .:l !o"
~i"l'" =
....b _ .0
II ~ .c ,2
,5 ::; c
;3 "'~
la.PllJu~.!:
..,
,
. '.
..
UHii. t'J ~
~
~
EIMARD C. TERREL, . IN THE COURT OF CXlMMON PLEAS OF
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. : NO. 96-444 CIVIL TERM
:
CiUlLA J. TERREL, . CIVIL ACTION - LAW
.
Defendant : IN CUSTODY
OODBIt OFaxm
AND lOi, this /". day of :!Xu. W , 1996, upon
consideration of the attached CUstody Conciliation Report, it is ordered
and directed as follows:
1. This Court's prior Order dated SepteniJer 17, 1996 shall remain in
effect in conjunction with the additional provisions set forth in this
Order.
2. The Father shall have one overnight period of Custody per month
with the parties' son, John, which shall take place at the following dates
and times:
From Friday, DeceniJer 27, 1996 at 5:00 p.m. until
Saturday, Decenber 28, 1996 at 12:00 noon, when the
Father shall return the Chil~ to the Mother's residence
and then begin the period of visitation with both
Children in accordance with the regular schedule.
Fran Saturday, January 18, 1997 at 1:00 p.m. until
Sunday, January 19, 1997 at 1:00 p.m..
Fran Saturday, February 15, 1997 at 1:00 p.m. until
Sunday, February 16, 1997 at 1:00 p.m.
Fran Saturday, March 15, 1997 at 1:00 p.m. until Sunday,
March 16, 1997 at 1:00 p.m.
3. The Father shall have an additional period of visitation with the
Children on Chrisbnas Eve from 5:00 p.m. until 9:00 p.m. at the Mother's
residence.
4. If any problema or disputes arise between the parties concerning
overnight custody, the parties shall address those issues with the parties'
counselor, Steve Holland and also involve the parties' legal counsel if
necessary. The parties agree to be bound by the reconmendations of the
counselor for resolution.
...
5. The parties and their counsel shall meet with the CUstody
Conciliator, Dawn S. Sunday, Esquire for a Conferen.:e to be held on March
16, 1997 at 9:00 a.m.
6. This Order is entered pursuant to an agreement of the parties at a
CUstody Conciliation Conference. The parties may modify the provisions of
this Order by mutual agreement. In the absence of mutual agreement, the
terms of this Order shall control.
BY THE CXXJRT,
,/IlL
cc: Jordan D. CUMingham, Esquire for pla tiff/Father
Jan Terpenning and Joan Carey, Esquire for Defendant/Mother
ect:.~.("Y><~'O'J... 1~/''1lq(..
.>1> ii' .
, .
, I,
Elizabeth C. Terrel
John E. Terrel
July 5, 1988
May 30, 1986
Defendant/Mother
Defendant/Mother
...
EOOARD C. TERREL, . IN THE COURT OF CXX1MON PLEAS OF
.
Plaintiff . CUMBERLAND CXXJNTl{, PENNSYLVANIA
.
.
.
vs. . t-.'O. 96-444 CIVIL TERM
.
.
.
CARLA J. TERREL, : CIVIL ACTION - LAW
Defendant . IN CUSTODY
.
PRIm JUDGB: Kevin A. Hess
QJS'lOOY cxu:ILIATION &J9IARY REPatT
IN ACXnUlANC8 wrm CDlBBRLAND CXllBl'Y RULE OF CIVIL PR(lo ."" 'IJRB
1915.3-8, the undersigned CUstody Conciliator submits the following report:
1. 'Dle pertinent information concerning the Olildren who are the
subjects of this litigation is as follows:
NAME
BIRI.'IIDATB
CIlRRFBl'Ly Dl QJS'lOOY OF
2. A fourth Conciliation Conference was held in this matter on
Decentler 11, 1996, with the fOllowing individuals in attendance: the
Father, Edwartl C. Terrel, with his counsel, Jordan D. CUMingham, Esquire,
and the Mother, Carla J. Terrel, with her representative, Jan TerpeMing,
Paralegal.
3. 'Dle parties agreed to entry of an Order in the form as attached.
/1,~<t.~do,~
~/s. sunday~t;d
CUstody Conciliator
ia- / Id-/q.~
. .
Date
;I~I ~ i'~l w~
i~E~ .... ~ ~; .Ii. ~!:
....
. u ~ '... ~ t/tel~~
~
i~!~ i'~ . Ill, 11 ,5 ,
~ i~ ~I i-iL . ' ~ f.D
.!!l !l Ill, I ~ ~
~ !l ~ .c ,.
; == ~ a
,- f<:l, 0'.-6
d~i . !;l . ,,'" ~
u . . ...
! ..,
i
-- III . #
... .
EDWARD C. TERREL,
Plaintiff
: IN THE COURT OF cctolMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 96-444
CIVIL TERM
CARLA J. TERREL,
Defendant
: CIVIL ACTION - LAW
: PARTIAL CUSTODY
OOOBR OF CXlURT
AND tDf, this ct.
upon consideration of the attached
ordered and directed as follows:
day of !'J'J19!tClt , 1996,
Custody Conciliation Report, it is
1. The Mother, Carla J. Terrel, and the Father, Edward C. Terrel,
shall have shared legal custody of Elizabeth C. Terrel, born July 5, 19B8
and John E. Terrel, born May 30, 1986.
2. The Mother shall have primary physical custody of the Children.
3. The parties shall submit themselves and the Children including Chad
M. Husted, age 16, to a program of counseling/therapy by a prOfessional
counselor to be selected by the parties and counsel within ten days of the
date of the Conciliation Conference. If the parties are unable to select a
counselor by mutual agreement, the parties through counsel, may contact the
Custody Conciliator for a telephone conference. The purpose of the
counseling is to reestablish a relationship of trust between the Father and
the Children in the aftermath of abuse allegations and to obtain a
professional evaluation of the desirability of expanding the visitation
schedule to include periods of partial physical custody. The cost of the
counseling shall be apportioned between the parties with the Father paying
seventy percent and the Mother paying thirty percent of the counseling
expenses not reimbursed by the parties' medical insurance.
4. The Father shall complete an approved sexual offenders program as
suggested by the Cumberland County Children and Youth Services. The
Father's voluntary participation in such a program shall not be construed as
an admission of any allegations of abuse.
5. The Father shall have supervised visitation with the Children at
the Mother's residence on alternating Saturdays as follows:
A. March 9, 1996 - Two and a half hours with a third party present
in the room for the entire period.
8. March 23, 1996 - Two and a half hours with a third party
present for the first one hour and fifteen minutes of the
period.
C. April 6, 1996 - Three hours with a third party present in the
room for the first one hour of the period.
D. April 20, 1996 - Three hours with a third party present in the
room for the first one-half hour of the period.
--
~
.
.
.'
~-
,~.;-:
I:.!J(
~,2 .
,""'..'
C":
r/
,'-'.
.f:,
I_~
<\J
~
,
~-
."
.-
f..j:
::}
I
r
/_'.1:S
. ,~'~ ~.'
,~~:I
" ':":
'"
.~
,.'
,:;:J
,-
"
:::-:)'
. .;
<
,
E. May 4, 1996 - Three hours with no third party present in the
room during the entire period.
F. May 18, 1996 - Three and a half hours with no third party
present in the room during the entire period.
G. June 1, 1996 and thereafter - Four hours with no third party
present in the room during the entire period.
6. The parties and their counsel shall meet with the Custody
Conciliator, Dawn S. Sunday, Esquire, for a second Conference to be held
three months after the date of the parties' first counseling session.
7. This Order is entered pursuant to an agreement of the parties at a
Custody Conciliation Conference. The parties may modify the terms of this
Order by mutual agreement. In the absence of mutual agreement, the
provisions of this Order shall control.
BY THE COURT,
cc: Jordan D. Cunningham, Esquire
Joan Carey, Esquire and Sonya M.
J.
J--l1k II'U'...AI -1/$",416
Paralegal '
"
.
'.
EDWARD C. TERREL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 96-444
CIVIL TERM
CARLA J. TERREL,
Defendant
CIVIL ACTION - LAW
PARTIAL CUSTODY
aJSTOOl( CCfiCILIATIaf SlJoIMARl( REPORT
IN AcxnulANCE wrm cnmERLAND CXUflY RULE OF CIVIL ~
1915.3-B, the undersigned Custody Conciliator submits the following report:
1. The relevant information pertaining to the Children who are the
subjects of this litigation is as follows:
NAME
BIRTHDATE
CURRENTLY IN CUSTODY OF
John E. Terrel
Elizabeth C. Terrel
Chad M. Husted (step-son)
May
July
30, 19B6
5, 1988
age 16
Defendant/Mother
Defendant/Mother
Defendant/Mother
2. A Conciliation Conference was held on February 27, 1996, with the
following individuals in attendance: The Father, Edward C. Terrel, with his
counsel, Jordan D. Cunningham, Esquire, and the Mother, Carla J. Terrel,
with her counsel, Joan Carey, Esquire and Sonya M. Hinkel, Paralegal.
3.
The parties agreed to entry of an Order in the form as attached.
f.?h" " .l-Lr j )'1
Dawn S. Sunday
Custody Conciliator (
rdJ'V........l .~'J I''J-ifl
( .
Date
{!j~
~~ffi
~I~ 13
i t .... ~ ....
.... ... ~~ ,gc'JlwiS
.... t w,g~t:.:
":lJ~ .... c w -
... tit j, , .;;...
c: ~ 1; .s ~
ill~ ,.... . ~I
I~ ~ '.... ;.J . I ~ f:.O
iil 18 fit t "" ~
... \ w .D
~ =... c CI
~ J! ~ ,d
:= :2 ~..c:
. ~ ia. I:(;.eft, r) ~
~~. lJ . .-.
! ~
~~~ i
.' .,
'.
JUI, 1 u ,;;So
$'t:
"
'.
'.
EDWARD C. TERREL, . IN THE COURT OF CXXolMON PLEAS OF
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. . NO. 96-444 CIVIL TERM
.
.
.
CARLA J. TERREL, .
.
Defendant . IN CUSTODY
.
OODER OF' CXXlRT
AND NCM, this 13" day of:4.... , 1996, upon
consideration of the attached Custody Conciliation Report, it is ordered and
directed as follows:
1. Pending further Order of this Court or agreement of the
parties, this Court's prior Order dated March 4, 1996 shall continue in
effect with the following modifications:
A. The Father shall have visitation
Mother's residence for four
Saturdays.
with the Children at the
hours on alternating
B. The Mother shall cooperate with the counselor's (Steve
Holland) reconmendations with regard to periods of
unsupervis~ partial custody for the Father with the
parties' son, John.
C. As long as the parties' counselor (Steve Holland)
continues to schedule two counseling sessions per week,
the Father agrees to pay an additional Twenty ($20.00)
Dollars per week above the seventy (70%) percent Father is
responsible to pay under paragraph 3. of this Court's
prior Order. If the counselor conducts fewer sessions,
the counseling expenses shall be apportioned between the
parties with the Father paying seventy (70%) percent and
the Mother paying thirty (30%) percent.
D. The Father shall be entitled to contact the Children by
telephone every Wednesday evening at 7:00 p.m. and the
Mother shall cooperate in making the Children available
for this scheduled telephone call. The Father may also
contact the Children by telephone at other reasonable
times as the Children are available.
2. The parties and their counsel shall meet with the Custody
Conciliator, Dawn S. Sunday, Esquire, for a third Conference to be held on
September 10, 1996 at 1:00 p.m.
3. The parties may modify the provisions of this Order by mutual
~
#
.
conaent. In the abaence of mutual agreement, the terms of this Order shall
control.
CCI Jordan O. Cunningham, Esquire _
Joan carey, Esquire
BY THE COURT,
AU-
~J... tol,..,/"/".
,..&,6'.
,'..'.'
'.
FlLED-OFFlct
0;. !; r: n:OiJ'')'1::rr,IRY
% .WN II, 1:11 U:? I
CU,',:c.:.:.i1L.'.:,U COliNIY
PENNSYLVANIA
, "
....
. '
EDWARD C. TERREL, : IN THE COURT OF CCXolMON PLEAS OF
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. . NO. 96-444 CIVIL TERM
.
.
.
CARLA J. TERREL, .
.
Defendant . IN CUSTODY
.
PRICR JUDGB: Kevin A. Hess
aJS'nDY CXH:ILIATICtI SUlMARY REPCRT
IN ACalmANCE WI'.l'II cnmBRLAND ~ RULE 011' CIVIL PIll> 'K> ..JRE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The relevant information pertaining to the Children who are
the subjects of this litigation is as follows:
NAME
BIRTHDATE
CURRENTLY IN CUSTODY OF
Elizabeth C. Terrel
John E. Terrel
July 5, 1988
May 30, 1986
Defendant/Mother
Defendant/Mother
2. The initial Conciliation Conference was held in this matter on
February 29, 1996. This Court entered an Order on March 4, 1996 reflecting
the parties' agreement and awarding primary physical custody to the Mother,
shared legal custody, partially supervised visitation for the Father and
counseling for the parties and the Children.
3. A second Conciliation Conference was held pursuant to a
provision in the prior Order on June 5, 1996. The following individuals
were in attendance: The Father, Edward C. Terrel, with his counsel, Jordan
o. Cunningham, Esquire, and the Mother, Carla J. Terrel, with her counsel,
Joan Carey, Esquire, Sonya M. Hinkel, Paralegal and Michelle Hamilton, law
student.
4. At the Conciliation Conference, the Conciliator spoke by
telephone with Steve Holland, a counselor with the West Shore Psychological
Services who has been working with both the parties and the Children for
approximately two months. Based upon the counselor's recommendations
regarding the advisability of expanded visitation/partial custody for the
Father, the parties agree to entry of an or~. in the form as attached.
~ (, 177v U,~'')/,,'~,
Date' Dawn S. Sunday, Esqu1re I
Custody Conciliator
.'~.~l
~
'-"
f:>~
~I~i ~ :.I. ....
~Q,s~ ~~ .a '" j ~
.a. ~ ~
. u~ ~ .... JJ I ~...
.... .~
...
f:>~ ; .... . ~I \ )'; ,:=:
I~ g! iJ . I .:! ~
'tit. . of': =
18 ~ I r -.-
; ~ .c ,9
~~!@ . :: !i
:3 .ii! "'.-
. ~ J;{J ., -'\ ~
U . . "
~~~O I ..,
i
; bDolY.
.
vs.
: NO. 96-444
CIVIL TERM
-,.'
EDWARD C. TERREL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COllN1Y, PENNSYLVANIA
.
.
:
CARLA J. TERREL,
Defendant
.
.
.
.
: CHILD CUSTODY/VISITATION
au>ER OF CXXJRT
AND ~, this /7' day
consideration of the attached custody
ordered and directed as follows:
of )',,,a:t.- , 1996, upon
Conciliation Summary Report, it is
1. The prior Orders of this Court dated March 4, 1996 and June 13,
1996 are vacated and replaced by this Order.
2. The Mother, Carla J. Terrel, and the Father, Edward C. Terrel,
shall have shared legal custody of Elizabeth C. Terrel, born July 5, 19BB
and John E. Terrel, born May 30, 19B6.
3. The Mother shall have primary physical custody of the Children.
4. The parties shall continue to submit themselves and the Children,
inclUding Chad M. Houston, age 16, to the program of counseling/therapy
currently conducted by West Shore Psychological Services. The purpose of
the counseling is to reestablish a relationship of trust between the Father
and the Children and between the parties in the aftermath of abuse
allegations and to obtain a prOfessional evaluation recOllll1ending ongoing
custody arrangements. The cost of the counseling shall be apportioned
between the parties with the Father paying seventy (70%) per cell.. and the
Mother paying thirty (30%) per cent of the counseling expenses not
reimbursed by the parties' medical insurance.
5. As long as the parties' counselor (Steve HOlland) continues to
schedule two counseling sessions per week, the Father agrees to pay an
additional Twenty ($20.00) Dollars per week above the Seventy (70%) per
cent the Father is responsible to pay under the preceding paragraph of this
Order. If the counselor conducts fewer sessions, the counseling expenses
shall be apportioned between the parties with the Father paying seventy
(70%) per cent and the Mother paying Thirty (30%) per cent.
6. The Father shall complete an approved sexual offenders program as
reccxrmended by the Cumberland County Children and Youth Services. The
Father's voluntary participation in such a program shall not be construed
as an admission of any allegations of abuse.
7. The Father shall have visitation with the Children at the Mother's
residence for four hours on alternating Saturdays. For a portion of this
four hour period, the Father may take the Children (or either Child
individually) to the school playground across the street from the Mother's
residence or to the play area in the Mother's apartment complex if the
r.":'
.
~
Mother consents.
8. The Mother shall cooperate with the counselor's (Steve Holland's)
recoomendations with regard to periods of unsupervised partial custody for
the Father with the parties I son John.
9. If the Mother consents, the Father may have additional one hour
periods of partial custody with both Children together as arranged by
mutual agreement of the parties.
10. The Father shall be entitled to contact the Children by telephone
every Wednesday evening at 7:00 p.m. and the Mother shall cooperate in
making the Children available for this scheduled telephone call. The
Father may also contact the Children by telephone at other reasonable times
as the Children are available.
11. The parties and their counsel shall meet with the CUstody
Conciliator, Dawn S. Sunday, Esquire for a fourth Conference to be held on
December 10, 1996 at 9:30 a.m.
12. This Order is entered pursuant to an agreement of the parties at a
Custody Conciliation Conference. The parties may modify the provisions of
this Order by mutual consent. In the absence of mutual consent the terms
of this Order shall control.
BY THE COURT,
<'/ /,1!ql#,
..l.1' '
cc:
Jordan D. Cunningham, Esquire for P. aintiff _ f'~"'~
Joan Carey, Esquire for Defendant - ..
.
FLED-Q;:FIC:
C/- ~"- "''-'I''';;".~,:,
,~- rw" 1'.1
..':.J.""ll.;
;,,;; In: r.6
Ci.....~;.:.. ".:. '.. '" ._.111 rt
I~~;'~: '~'/L.Vj'\o\~~\
,
'1
.
EDWARD C. TERREL, . IN THE COURT OF WlMON PLEAS OF
.
Plaintiff . CUMBERLAND COllNTY, PENNSYLVANIA
.
:
vs. . NO. 96-444 CIVIL TERM
.
.
.
CARLA J. TERREL, :
Defendant . CHILD CUSTODY/VISITATION
.
PRIat JtlDGB: Kevin A. Hess
aJS'lmY CXNCILIATION SUlMARY REP(Rl'
IN ACCXlUlANCE wrm CDIBI!RLAND <XXNlY RULE 01." CIVIL PIlCI< ."" (JRE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the
subjects of this litigation is as follows:
NA/'lE
BIRTIIDATE
aJRRJltlJ.'LY IN aJS'lmY 01."
Elizabeth C. Terrel
John E. Terrel
July 5, 1988
May 30, 1986
Defendant/Mother
Defendant/Mother
2. The initial Conciliation Conference was held in this matter on
February 29, 1996. This Court entered an Order on March 4, 1996 reflecting
the parties I agreement and awarding primary physical custody to the Mother,
shared legal custody, partially supervised visitation for the Father and
counseling for the parties and the Children. A second Conference was held
on June 5, 1996 after which an Order was entered by the Court on June 13,
1996 modifying the prior Order to provide for telephone contact between the
Father and the Children and partial custody for the Father with the
parties' son.
3. A third Conciliation Conference was held in this matter on
Septellber 10, 1996. The following individuals were in attendance: The
Father, Edward C. Terrel, with his counsel, Jordan D. CUnningham, Esquire
and the Mother, Carla J. Terrel, with her counsel, Joan Carey, Esquire and
Jan Terpening, Paralegal.
4. At the Conciliation Conference, the Conciliator again spoke by
telephone with Steve Holland, a counselor with the West Shore Psychological
Services, who has been working with both the parties and the Children since
the initial Conciliation Conference held in this case. The parties agreed
to the counselor's recommendations for slightly expanded opportunities for
visitation and partial physical custody of the Children by the Father.
5. This case involves a very difficult family situation including
serious issues/allegations which the parties are addressing in intensive
counseling for both the Children and themselves. In addition to the family
counseling through Steve Holland, the Children each receive individual
counseling from other organizations and the Father is attending a sexual
offenders program (allegations denied) through Holy Spirit Hospital as
provided in the initial Order. It is commendable that the parties have
persisted in their efforts to resolve the custody issues and other family
y
"
issues through counseling and have abided by the counselors'
recommendations with respect to the best interests of the Children.
6. The parties agree to entry of an Order in the form as attached,
which slightly modifies the prior Orders in accordance with the counselor's
recommendations and consolidates the provisions of all prior Orders.
a~
Dawn S. Sunday, Esqu re
Custody Conciliator
~f'k_JuA 13 /'19~
Date ,
-
JAN :3 0 199fl tf
..
BDwaRD C. TBRRBL, r
Plaintiff r
r
v. r
r
CAJlLA J. TBRRBL, r
Defendant r
IN THB COURT OF COXNON PLBAB
CUNBBRLAIlD COUJrTY, PBIIHSYLVUlIA
NO. qfr 41.;4 (7/'L".t Jl\"~
CIVIL ACTION - PARTIAL CUSTODY
ORDER OF COURT
, !
I
I
AND NOW, upon consideration of the attached Complaint, it
is hereby directed th t the p~ties and their respective
counsel appear before .,,\' U, S, , the
Conciliator, ;r the :'- \(11\ day of ,,'~, i' , 199b,
at 10' ,31.'1 .M., in the M:torney' a I..om:erem;... Reom, 4th )J
~r, CUlllberli!lld cou...t:y C"nurthouse, I'lquare. Carlisle,"<:I
Pennsylvania, 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 ~to
a Temporary Order. All children aae five and olde" - n-'" so
be Dresent at the Conference. Failure to appear at the
Conference may provide grounds for the entry of a temporary or
permanent Order.
FOR THE COURT,
'<J
l>':'"
Date of Order: 1,,')\,,\1.
By: >11
Custody Conciliato
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.
Court Administrator
Cumberland County Courthouse
4th Floor
Carlisle, PA 17013
Telephone: (717) 240-6200
.
r:l.r:~.r:F1':E
(:~ '" ::-..' "-"':~r',-::';,
(,:Hlr.T~..(.' ~,,~ ~.,:,Cl
" . . '.' " 1_' (. .,I
(:! ", ", . ., " .' \' I , .,
~..,)"../-:~: i;' L: 1,~~:',I,:\<(~:.:";; r
a.a -?&; ad' bff IJ/:J..t ~ df- ~
a.'a 1',1; '7/4 IH{;.fkt ~ ~ Y.7U0
C) .,:),~ I'd'''' M~'~ Q.&ud,.
.
. .
..
EDWARD C. TERREL,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - PARTIAL CUSTODY
CARLA J. TERREL,
Defendant
COMPLAINT POR PARTIAL CUSTODY
1. The Plaintiff is EDWARD C. TERREL, residing at 1024
AUdubon Road, Mechanicsburg, Cumberland County, Pennsylvania.
2. The Defendant is CARLA J. TERREL, residing at 541
First street, CarliSle, Cumberland County, Pennsylvania.
3. The Plaintiff seeks partial custody and visitation
of the following children:
IWm PRESENT RESIDENCE M.E:
Elizabeth C. Terrel 541 First Street 7 years
Carlisle, PA 17013
John E. Terrel 541 First Street 9 years
Carlisle, PA 17013
Chad M. Husted 541 First Street 16 years
Carlisle, PA 17013
~
The children were not born out of wedlock.
The children are presently in the custody of the
Defendant, Carla J. Terrel, who resides at 541 First street,
Carlisle, Cumberland County, Pennsylvania.
During the past five (5) years, the children had
resided with the following persons and at the following
addresses:
(LIST ALL PERSONS)
(LIST ALL ADDRESSES)
(DATES)
5/1/89 to
5/31/92
6/1/92 to
Present
Edward C. Terrel
Carla J. Terrel
1024 Audubon Road
Mechanicsburg, PA 17055
541 First Street
Carlisle, PA 17013
Carla J. Terrel
The mother of the children is Carla J. Terrel,
currently residing at 541 First Street, Carlisle, Cumberland
County, Pennsylvania. She is married.
The father of the children is Edward C. Terrel,
currently residing at 1024 Audubon Road, Mechanicsburg,
Cumberland County, Pennsylvania. He is married.
2
<:
..
4. The relationstalp of Plaintiff to the children is
natural father. The Plaintiff currently resides with the
following persons:
IWm
Margaret Lee
Billie Jo Lee
RELATIONSHIP
Girlfriend
Daughter
5. The relationShip of Defendant to the children is
that of natural mother. The Defendant currently resides with
the f~llowing persons:
IWm
John E. Terrel
Elizabeth C. Terrel
Chad M. Husted
RELATIONSHIP
Son
Daughter
Step-son
6. Plaintiff has not participated as a party or
witness, or in another capacity, in other litigation
concerning the custody of the children in this or another
Court.
Plaintiff has no information of a custody proceeding
concerning the children pending in a Court of this
Commonwealth.
3
...';-""~ 'i-(,.
o
~
~
Plaintiff does not know of a person not a party to
these proceedings who has physical custody of the children or
claims to have custody or visitation rights with respect to
the children.
7. The best interest and permanent welfare of the
children will be served by granting the relief requested
because since an allegation of child abuse, in the Summer of
1994, was filed against the Plaintiff by the Defendant,
Defendant has refused Plaintiff partial custody of the
children and has allowed only limited supervised visitation
with the children. Plaintiff desires to effect greater
contact with the children since the allegation regarding his
alleged action occurred approximately one and one-half (1-1/2)
years ago.
8. Each parent whose parental rights to the children
have not been terminated and the person who has physical
custody of the children have been named as parties to this
action. All other persons, named below, who are known to have
or claim a right to custody or visitation of the children have
been given notice of the pendency of this action and the right
to intervene: None.
4
'."
"
.
WHEREFORE, Plaintiff requests the Court to grant partial
custody of the children.
Respectfully submitted,
CUNNING~ F, P.C.
Date:
I fts/'i~
By:
J an D.
.0. #23144
2320 North Second street
P. O. Box 60457
Harrisburg, PA 17106-0457
Telephone: (717) 238-6570
(Attorneys for Plaintiff)
5
,'" _. . 0
, .
I.
VERIFICATION
I, EDWARD C. TERREL, verify that the statements made in
the foregoing COMPLAINT FOR PARTIAL CUSTODY are 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.A. S49041 relating to unsworn
falsification to authorities.
~Je~
EDWARD C. TERREL
Date: 18 ~tt~ Cfb
~
~ co i::
r~~ ".I
l.'J ('} (..~ ;~s
. ," .
IJ~L', ~'-
I.... -' "
()':' ":1
,~. ~J
,.'", : .. .
l.' .. , (',I . "
L" .. : :.-;
I , . ';,J
,
l'_ ,
LJ . ~ .--;
_. . i'-'"
,J
f,
'a"~
~
.~..~
<:::::::..
C\~
~
~
h
~
-
~
.~
~
['-'
--..
IV'\
tn
-.!-
-\..N
~ ~ l:I
'-::J ~
~
II~" H) 'Il'l 'c, fj:'
'.' ',I (_ d.:JO
IID1fARD C. TIIRRBL,
Plaintiff
IN HII COURT OJ' CODON PLIIAS i
CmmERLAIfD COtJIfTY, PEIflfSYLVUIA I
NO. Q It- I; /r 4. (i'A.-t~L .:Jl~!
CIVIL ACTION - PARTIAL CUSTODY
v.
I
I
I
I
I
:
I
CARLA J. TERRIlL,
Defendant
ORDER 01' COURT
AND NOW, upon consideration of the attached Complaint, it
is hereby directed thaJ; the parties and their respective
counsel appear before O(JJ"}-,, ~~'~ '~~ ~'~ ' the
Conciliator, on the a ':5-/1, day "~ ,~~~/"'J/A-<;;' , 1:99 G,
at IlJ:30 A.M., in the J\~e---e-'-s-Conf4treRgg RQ"';:_ 4th
:1
I 'Fleer, CUmb6rlaRQ COYRty CawrtRQYB9, S~a~8, ~3~lis16,
Pennsylvania, for a Pre-Hearing custody Conference. At such
Conference, an effort will be made to resolve the issues in
disputer 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 aae five and older -eh'1ti'1 also
be cresent at the Conference. Failure to appear at the
Conference may provide grounds for the entry of a temporary or
permanent Order.
."19 41. ~
.:r:f.
7lt.>d, .
~
.1
FOR THE COURT,
Date of Order: " 3/'9& By:
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.
Court Administrator
Cumberland County Courthouse
4th Floor
Carlisle, PA 17013
Telephone: (717) 240-6200
C)
';;
r', ~~
" , ..,
. I
: -,
',",
I' ) ~ j .,
'- , ~-J
:(")
-,., ,
,. , ,
1, .
( 1 , )1";\
.. !
, , ~.' ,
(;) -<
..
,
.
:! :
. "
.~... '
..
-,
EDWARD C. TERREL,
plaintiff
.
.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - PARTIAL CUSTODY
v.
CARLA J. TERREL,
Defendant
COMPLAINT POR PARTIAL CUSTODY
1. The Plaintiff is EDWARD C. TERREL, residing at 1024
Audubon Road, Hechanicsburg, Cumberland county, Pennsylvania.
2. The Defendant is CARLA J. TERREL, residing at 541
First Street, Carlisle, Cumberland County, Pennsylvania.
3. The Plaintiff seeks partial custody and visitation
of the following children:
IWm PRESENT RESIDENCE Am<
Elizabeth C. Terrel 541 First Street 7 years
Carlisle, PA 17013
John E. Terrel 541 First Street 9 years
Carlisle, PA 17013
Chad H. Husted 541 First Street 16 years
Carlisle, PA 17013
~:ft"l _ '
.
,
The children were not born out of wedlock.
The children are presently in the custody of the
Defendant, Carla J. Terrel, who resides at 541 First street,
Carlisle, Cumberland County, Pennsylvania.
During the past five (5) years, the children had
resided with the following persons and at the following
addresses:
(LIST ALL PERSONS)
(LIST ALL ADDRESSES)
1024 Audubon Road
Mechanicsburg, PA 17055
541 First Street
Carlisle, PA 17013
(DATES)
5/1/89 to
5/31/92
6/1/92 to
Present
Edward C. Terrel
Carla J. Terrel
Carla J. Terrel
The mother of the children is Carla J. Terrel,
currently residing at 541 First Street, Carlisle, Cumberland
County, Pennsylvania. She is married.
The father of the children is Edward C. Terrel,
currently residing at 1024 Audubon Road, Mechanicsburg,
Cumberland County, Pennsylvania. He is married.
2
, ,"'.. ~ Il/I
.
4. The relationship of Plaintiff to the children is
natural father. The Plaintiff currently resides with the
following persons:
HAHEi
Margaret Lee
Billie Jo Lee
RELATIONSHIP
Girlfriend
Daughter
5. The relationship of Defendant to the children is
that of natural mother. The Defendant currently resides with
the following persons:
lfAHE:
John E. Terrel
Elizabeth C. Terrel
Chad M. Husted
RELATIONSHIP
Son
Daughter
Step-son
6. Plaintiff has not participated as a party or
witness, or in another capacity, in other litigation
concerning the custody of the children in this or another
Court.
Plaintiff has no information of a custody proceeding
concerning the children pending in a Court of this
Commonwealth.
J
':',;
.
-
Plaintiff does not know of a person not a party to
these proceedings who has physical custody of the children or
claims to have custody or visitation rights with respect to
the children.
II
7. The best interest and permanent welfare of the
children will be served by granting the relief requested
because since an allegation of child abuse, in the Summer of
1994, was filed against the Plaintiff by the Defendant,
Defendant has refused Plaintiff partial custody of the
children and has allowed only limited supervised visitation
ii
!I
I
with the children.
Plaintiff desires to effect greater
contact with the children since the allegation regarding his
alleged action occurred approximately one and one-half (1-1/2)
years ago.
8. Each parent whose parental rights to the children
have not been terminated and the person who has physical
custody of the children have been named as parties to this
action. All other persons, named below, who are known to have
or claim a right to custody or visitation of the children have
been given notice of the pendency of this action and the right
to intervene: None.
4
.;,
~ >'\' .r."
','0- -..;..-66" "1'_
.
WHEREFORE, Plaintiff requests the Court to grant partial
custody of the children.
Respectfully submitted,
By:
J9J:dan D.
1Y.D. #23144
2320 North Second Street
P. O. Box 60457
Harrisburg, PA 17106-0457
Telephone: (717) 238-6570
(Attorneys for Plaintiff)
F, P.C.
Date:
I/;;r lit;-
I
5
~
VERII'ICATION
I, EDWARD C. TERREL, verify that the statements made in
the foregoing COMPLAINT FOR PARTIAL CUSTODY are 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.A. S4904, relating to unsworn
falsification to authorities.
eAUl/l1 e ~
EDWARD C. TERREL
Date: 18 ~tu\ erG
,"-:IF,'
I
o
~ ,
EDWARD C. TERREL
I'LAINTIFF
V.
CARLA J. TERREL
DEFENDANT
IN TIlE COURT OF COMMON I'LE/\S OF
CUMBERI.AND COUNTY, I'ENNSYL VANIA
96-444
CIVil. ACTION LAW
IN CUSTODY
emBER OF COllRT
AND NOW. this 11th day or Septemher .2000. upon consideration of the allached Complaint,
it is hereby directed thatthc parties and thcir rcspcctive counsel appcar beforc Dawn S. Sunday. Esq. . the conciliator,
at 39 We.t Main Street. Meehanle.burg. P A t70SS on the !!!!!!- day of October . 2000, at tl :00 a.m.
for a Pre-Hcaring Custody Conference. At such eonfercnce, an effort will be made to resolve the issues in dispute; or
i I' this cannot be accomplished. to define and narrow the issues to be heard by the court. and to enter into a tcmporary
order, All children agc five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a tcmporary or pcrmancnt order.
FOR THE COURT.
By: /./
Dawll S. SImdap. Esq,
Custody Conciliator(1'
TIIC Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilitcs Act of 1990, For information about accessible facilities and rcasonable
accommodations available to disabled individuals having business before thc court, please contact our office.
All arrangemcnts must bc made 01 least 72 hours prior to any hearing or busincss bcforc the court. You must
allcnd thc scheduled conference or hcaring.
YOU SHOULD TAKE THIS PAPER TO YOUR ATroRNEY AT ONCE. IF YOU DO NOT
HAVE AN A 11'0RNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TI'E OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELl',
Cumberland County Bar Association
2 Liberty A vcnue
ClIrlisle.l'ennsylvanill 17013
Telephone (717) 249-3166
-."A.,' .
'.
L .\
",
. i.. .\, ", fl,:,"
~"/Ja:J &/.~~ i? 4 ~"
1-/3 ~ 7l~ fl1~ Z' ~.
Ij'/J-tr) ~~tM ~4~~
.. .
.... <', ~...
, i LI I.'
, :?'~
) -
} ; :-: , .~
" . 'or'
...,. i , ~--j
I .'
," , . ,'/!
(" , .
r : ",1
, :J....,
...~ ,
I',", ..J
~-' C) U
u ~
a: ~
If!:'::!
oUlz
s.!1!:~
ZIIl;.J I
a: >
weill
G~~I:
"M~ ,:::
:ill!ci' :::
:cza: ....
CJo::l
~~~
Z a:
::I a:
u ~
>.
Co
0
U
U
u
~
~
0
u
""
"
..
u
"
~
;-0
~
u 0
.c u
0 u
~
-...
~ 0
:200
- u
~~
~ ..
u
u .: ~
,. >..~ a
.c ~ i7 ; ,
u 0
~ ... ..
u u ~
-=-5 S .
-... ;;:
0
. .
CUNNING,HAM lk CHERNICOFF. P.C,
(-- ")
Ir~:I (I ?n""
EDWARD C. TERREL,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96 - 444 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
v.
CARLA J. TERREL,
Defendant
ORDER OF COURT
AND NOW, upon consideration of the attached Complaint, it
is hereby directed that the parties and their respective
counsel appear before Escruire, the
Conciliator, on the day of , 2000, at
.m., in the Attorney's Conference Room, 4th Floor,
Cumberland County Courthouse, Square, Carlisle, Pennsylvania,
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 acre five and older shall also be oresent at the
Conference. Failure to appear at the Conference may provide
grounds for the entry of a temporary or permanent Order.
FOR THE COURT,
Date of Order:
By:
Custody Conciliator
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
EDWARD C. TERREL,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96 - 444 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
v.
CARLA J. TERREL,
Defendant
PBTITION POR MODIPICATION OP
CHILD CUSTODY ORDBR
AND NOW, comes the above named Plaintiff, EDWARD C.
TERREL, by and through his counsel, Cunningham & Chernicoff,
P.C., and presents the following in support of his Petition:
1. Your Petitioner, EDWARD C. TERREL, is an adult
individual who resides at 1024 Audobon Road, Mechanicsburg,
Cumberland County, Pennsylvania 17055.
2. Your Respondent, CARLA J. TERREL, is an adult
individual who resides at 541 First Street, Carlisle,
Cumberland County, Pennsylvania 17013.
3. petitioner and Respondent were formerly husband and
wife, but were divorced by a Decree in Divorce entered by the
Court of Common Pleas of Cumberland County.
1
c
4. Two (2) children were born of this marriage, JOHN E.
TERREL, born on May 30, 1986, who is currently fourteen (14)
years of age; and ELIZABETH C. TERREL, born on July 5, 1988,
who is currently twelve (12) years of age.
5. On November 16, 1997, an Order of Court was entered
by the Honorable Kevin B. Hess. A true and correct copy of
said Order is attached hereto, made part hereof, is
incorporated herein by reference and marked Exhibit liP_I".
6. Pursuant to the Order of November 16, 1997, the
parties share both legal custody of the minor children.
7. The Order of Court, in Paragraph 2, also provides
for the following:
2. The parties shall submit themselves and
the Children to a custody evaluation to be
performed by Stanley Schneider, PhD, who was
selected by agreement of the parties and counsel.
The Father shall be responsible for the costs of
the evaluation.
8. Since the entry of the Order, Dr. Schneider, on May
12, 1998, issued his recommendation.
2
"
,;....1"'\ ".~
,.,j" ."-A
~.
9. Since the entry of the Order, Petitioner has
completed the sexual offender program as recommended by
Cumberland County Children & Youth Services.
A true and
correct copy of said Certificate of Completion is attached
hereto, made part hereof, is incorporated herein by reference
and marked Exhibit "P_2".
10. Since the entry of the Court's Order of November 16,
1997, there have been substantial changes which have a
substantial impact upon the minor children's life, all of
which support that the best interests of the children would be
served by allowing the Petitioner unsupervised partial custody
of the minor children with the Petitioner, such changes
include, but are not limited to the following:
(a) Petitioner's minor son, John Terrel, has
suffered from chronic depression which has resulted in his
institutionalization on four (4) separate occasions;
(b) Petitioner's minor children are allowed to be
seen by Petitioner only in supervised settings for limited
3
i
I
,
I
I
r
-.'...,
.
"'_~,l
periods of time, which visitations take place in Respondent's
home, under Respondent's supervision;
(cl The minor children, John Terrel, age fourteen
(14) years and Elizabeth Terrel, age twelve (12) years, are of
such an age if Petitioner was to in any way abuse the children
they would be able to relate such abuse to a third party;
(d) Petitioner has remarried and established a home
and Petitioner's wife is known to the minor children;
(e) That the Respondent has taken such actions in
the past by placing all blame on the Petitioner for their
failed marriage to make it virtually impossible for Petitioner
to establish a relationship with the children without the ever
present influence of Respondent being present; and
(f) That the Respondent has not communicated with
Petitioner regarding important events in the minor children's
life, all of which is not in the minor children I s best
interests.
4
,
~
"
'~',~ ;' '. ~ III
-""""'~" ... I
WHEREFORE, your Petitioner respectfully requests the
present Order of November 16, 1997 be modified so that periods
of unsupervised partial physical custody be awarded to your
Petitioner.
Date:
(/..-t k..
.
submitted,
COFF, P.C.
By.
J an D. Esquire
.D. #231 4
2320 North Second Street
P. O. Box 60457
Harrisburg, PA 17106-0457
Telephone: (717) 238-6570
(Attorneys for Petitioner)
bl\doc.\cu8tody\petition,ter
5
VERIPICATION
I, EDWARD C. TERREL, verify that the statements made in
the foregoing PETITION FOR MODIFICATION OF CHILD CUSTODY ORDER
are 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.A. S4904, relating
to unsworn falsification to auth~rities.
fJu>tM~ e 0~
EDWARD C. TERREL
Date:
r;? - J-lf - J-ct)()
c
EXHIBIT "P-i"
.
EDWARD C. TERREL,
Plaintiff
: IN TfIE COOR'l' OF cc:toll1OO PLEAS OF
: CUMBERLAND~, PENNSYLVANIA
.
.
vs.
: NO. 96-444
CIVIL TERM
.
.
.
.
CIVIl. ACTIOO - LAW
IN ctJsroDY
CARLA J. TERREL,
Defendant
.
.
amBR Oi' CXXJRT
AND toi, this I~ tA. day of
upon consideration of the attached CUstody
ordered and directed as follows:
~fffi'~V , 1997,
Con at on Report, it is
. . ,..... '.
1. The prior Orders of this Court 'dated SepteJl'ber 17, 1996 and
Decerrber 18, 1996 are vacated and replaced with this Order.
2. The parties shall submit themselves and the Children to a
custody evaluation to be performed by stanley SChneider, PhD, who was
selected by agreement of the parties and counsel. The Father shall be
responsible for the costs of the evaluation.
3. The Father, Edward C. Terrel, and the Mother, Carla J.
Terrel, shall have shared legal custody of John E. Terrel, born May 30,
1986, and Elizabeth C. Terrel, born July 5, 1988.
4. Pending further Order of this Court or agreement of the
parties, the Mother shall have primary physical custody of the Children and
the Father shall have visitation with the Children at the Mother's
residence and with the Mother present for four hours on alternating
saturdays. For a portion of this four hour period, the Father may take the
Children to the school playground across the street fran the Mother's
residence or to the play area in the Mother's apartment canplex with the
Mother present.
5. If the Mother consents and is present, the Father may have
additional periods of visitation with the Children as arranged by mutual
agreement of the parties.
6. The Father shall have an additional period of visitation with
the Children on Christmas Eve fran 5:00 p.m. until 9:00 p.m. at the
Mother's residence with the Mother present.
7. The Father shall be entitled to contact the Children by
telephone every Wednesday evening at 7:00 p.m. and the Mother shall
cooperate in making the Children available for this scheduled telephone
call. The Father may also contact the Children by telephone at other
reasonable times as the Children are available. The Mother may be present
in the room with the Children but shall noe directly monitor the Father's
telephone calls on the line.
8. The Father shall complete an approved sexual offenders
.'
('
(..~
program aa recarrnended by the CUmberland County Children and Youth
Services. The Father's voluntsry participation in such a program shall not
be construed as an admission of any allegations.
9. Upon the conclusion of the cwstody evaluation and in the
event that the parties are not able at that time to establish custody
arrangements by agreement, either party may pet:ition the Court to have this
case again scheduled with the CUstody Conciliator for a Conference.
.I~(~A.":". a. . .~
Kev n A. Hess
J.
BY TIlE ClXJRT I
co: Jordan D. cunningham, Esquire-:for Father
Jan Terpening/Joan Carey, Esquire-for Mother
, .. - - '.
TIWE COpy FROM RECORD
In T~stimlirlY whrrr.of, I here unto set my hand
Srlt! ths 'esl of aa:d Court at Carlisle, Pa.
~ 9~
this ....1..7......., day of...J::1.fY::.:...., 19....1...
....', ..,1...'~....,{1...:~~,
_......~J.
~~. Pro
EDWARD C. TERREL,
plaintiff
: IN THE CXXJRT OF CCXoIMCW PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs.
: NO. 96-444
CIVIL TERM
.
.
CARLA J. TERREL,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
PRICR JtlDGB: Kevin A. Bess
~:LUJ% CXH::rL:rATION 5lMlARY REPCR1'
IN ACXXlUlANCB WI'1'H CDmI!:RLAND CXXNrY RDLE OF CIVlL PRO<~' '{JRB
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. i11e pertinent information concerning the Children who are the
subjecbr of this litigation is as follows:
. ...-' '.
NAME
DM'E OF BIRTH
COIlRf2lTLY IN Cu::,-,Ll.Ur OF
Defendant/Mother
Defendant/Mother
Elizabeth C. Terrel
John E. Terrel
July 5, 1988
May 30, 1986
2. As stated in prior Reports, this case involves a very difficult
family, situation including serious issues/allegations which the parties
have been addressing in counseling for the Children and themselves. In
order to resolve the custody dispute, the Father has attended a ,seventy.
week seicua1 offenders program (allegations denied) through Holy Spirit
Hospital. Recently, Children and Youth Services have become involved in
this matter in connection with the Mother's obligation to supervise
visitation, which has further complicated resolution of this case. The
parties are scheduled to begin a custody evaluation in December through the
office of stanley Schneider, PhD. Several Conciliation Conferences have
been held over the last two years (without the necessity of a Hearing to
date) with the most recent Conference having be-!n held on April 22, 1997.
The following individuals attended that Conference: The Father, Edward C.
Terrel, with his counsel, Jordan D. Cunningham, Esquire, and the Mother,
Carla J. Terrel, with her representative, Jan Terpening.
3. At the April 22, 1997 Conference, the parties agreed to
participate in a custody evaluation, although the issue as to whether the
Father wO'.11d be able to pay the expenses of the evaluation was left open
for determination. It was also agreed that the existing Order will remain
in effect without overnight periods of custody with the Father for the
parties I son during the school year except upon the recOllll1endation of the
evaluator. Additional changes to the existing Order which are reflected in
the attached proposed Order resulted from a telephone conference with
counsel for both parties on September 25, 1997.
4.
The Conciliator recOllll1ends an Order in the form as attached.
~hnf 1--tL,,,,Af7'i'
wn S. Sunday, Esqu re
CUstody Conciliator
/Vow:mhu 10 /997
DATE ..
.,. ~-.-".., .. '. <<l
.-"" ~'.-~' ..'
.,. "
EXHIBIT "p_2'.'
;....,"l
, ,:; J
Holy Spirit Hospital
Incest Treatment Pro!lfllm
S03 Nonh 2 I st Street
Camp Hill. PA 1701 I
Jordan Cunningham. Esq.
Attorney at Law
2320 Nonh 2nd Street
Harrisburg. P A 17 I 09
Re: Edward Terrell
Dear Mr. Cunningham.
This letter is written at Mr. Terrell's request to providj: you wilhinformation pertaining
to his therapy while he Wll5 involved in the Incest OtTenders PrOb'T'llm. Mi-, Terrell began group
therapy sessions on May 22. 1996. He successfully completed the necessary educational material
on January 14. 1998 and attended his one month follow up session on February I I. J 998,
Education material presented during his course of treatment included dynamics of incest,
communication techniques. psycho-social developmenlal slages. defense mechanisms. moml /
ethical issues. stress management. sexuality. and marilal / family dynamics,
Mr. Terrell actively participated in b'TOUP discussion topics and demonstrated an
improved understanding in incest dynamics and related issues. but remained in denial
concerning his actual reponed otTense, Mr. Terrell does report significant progress in the areas
of improved communication in his current relationship with his girlfriend and family members.
Sincerely. <:-" '(
~A- d---=-
Rhett A. Bennie
.
EDWARD C. TERREL,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96 - 444 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
v.
CARLA J. TERREL,
Defendant
ORDER OF COURT
AND NOW, upon consideration of the attached Complaint, it
is hereby directed that the parties and their respective
counsel appear before Esouire, the
Conciliator, on the day of , 2000, at
.m., in the Attorney's Conference Room, 4th Floor,
Cumberland County Courthouse, Square, Carlisle, Pennsylvania,
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 aqe five and older shall also be oresent at the
Conference. Failure to appear at the Conference may provide
grounds for the entry of a temporary or permanent Order.
FOR THE COURT,
Date of Order:
By:
Custody Conciliator
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
M .
.
EDWARD C. TERREL,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96 - 444 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
CARLA J. TERREL,
Defendant
PETITION FOR MODIFICATION OF
CHILD CUSTODY ORDER
AND NOW, comes the above named Plaintiff, EDWARD C.
TERREL, by and through his counsel, Cunningham & Chernicoff,
P.C., and presents the following in support of his Petition:
1. Your Petitioner, EDWARD C. TERREL, is an adult
individual who resides at 1024 Audobon Road, Mechanicsburg,
Cumberland County, Pennsylvania 17055.
2. Your Respondent, CARLA J. TERREL, is an adul t
individual who resides at 541 first Street, Carlisle,
Cumberland County, Pennsylvania 17013.
3. Petitioner and Respondent were formerly husband and
wife, but were divorced by a Decree in Divorce entered by the
Court of Common Pleas of Cumberland County.
1
I
I
I
I
f
<
4. Two (2) children were born of this marriage, JOHN E.
TERREL, born on May 30, 1986, who is currently fourteen (14)
years of age; and ELIZABETH C. TERREL, born on July 5, 1988,
who is currently twelve (12) years of age.
5. On November 16, 1997, an Order of Court was entered
by the Honorable Kevin B. Hess. A true and correct copy of
said Order is attached hereto, made part hereof, is
incorporated herein by reference and marked Exhibit IP_1".
6. Pursuant to the Order of November 16, 1997, the
parties share both legal custody of the minor children.
7. The Order of Court, in Paragraph 2, also provides
for the following:
2. The parties shall submit themselves and
the Children to a custody evaluation to be
performed by Stanley Schneider, PhD, who was
selected by agreement of the parties and counsel.
The Father shall be responsible for the costs of
the evaluation.
8. Since the entry of the Order, Dr. Schneider, on May
12, 1998, issued his recommendation.
2
9. Since the entry of the Order, Petitioner has
completed the sexual offender program as recommended by
Cumberland County Children &. Youth Services.
A true and
correct copy of said Certificate of Completion is attached
hereto, made part hereof, is incorporated herein by reference
and marked Exhibit IP-2".
10. Since the entry of the Court's Order of November 16,
1997, there have been substantial changes which have a
substantial impact upon the minor children's life, all of
which support that the best interests of the children would be
served by allowing the Petitioner unsupervised partial custody
of the minor children with the petitioner, such changes
include, but are not limited to the following:
i
,.
(a) Petitioner's minor son, John Terrel, has
suffered from chronic depression which has resulted in his
institutionalization on four (4) separate occasions;
(b) Petitioner's minor children are allowed to be
seen by Petitioner only in supervised settings for limited
3
<
periods of time, which visitations take place in Respondent's
home, under Respondent's supervision;
(c) The minor children, John Terrel, age fourteen
(14) years and Elizabeth Terrel, age twelve (12) years, are of
such an age if Petitioner was to in any way abuse the children
they would be able to relate such abuse to a third party;
(d) Petitioner has remarried and established a home
and Petitioner's wife is known to the minor children;
(e) That the Respondent has taken such actions in
the past by placing all blame on the Petitioner for their
failed marriage to make it virtually impossible for petitioner
to establish a relationship with the children without the ever
present influence of Respondent being present; and
(f) That the Respondent has not communicated with
petitioner regarding important events in the minor children's
life, all of which is not in the minor children's best
interests.
4
<
-.--.1
WHEREFORE, your petitioner respectfully requests the
present Order of November 16, 1997 be modified so that periods
of unsupervised partial physical custody be awarded to your
Petitioner.
submitted,
Date:
(h.{ /uu
.
p.e.
By.
J an D. unningham, Esquire
.D. 11231 4
2320 North Second Street
P. O. Box 60457
Harrisburg, PA 17106-0457
Telephone: (717) 238-6570
(Attorneys for Petitioner)
bl\doc.\cuetody\petitlon,ter
5
.
I~ t:'""~; .
"-'".- _;.A~ \' ,....
VERIPICATION
I, BOWARD C. TBRREL, verify that the statements made in
the foregoing PETITION FOR MODIFICATION OF CHILD CUSTODY ORDER
are 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.A. 54904, relating
to unsworn falsification to authorities.
tJu>lM~ e 0~
EDWARD C. TERREL
Date:
fiJ -).l( - :LotJO
....."-''-,:~:>.
<
EXHIBIT "P-i"
~
,.
EIlWARIl C. TERREL,
Plaintiff
IN THE CXXlR'l' OF CCiMI'ICN PLEAS OF
CUMBERLJ\ND CXXlN'J.'Y, PENNSYLVANIA
vs.
NO. 96-444
CIVIL TERM
CARLA J. TERREL,
Defen<Wlt
CIVI~ ACTIOO - LAW
IN CUSTODY
ClUlER Of' CXXIRI.'
AND tDf, this I " tA.. day of
upon consideration of the attached CUstody
orClered IlIlCI Clirected as follows:
~~ ' 1997,
Con at on Report, it is
-,. . ,. .--. '.
1. '!he prior OrClers ot: this Court 'dated Septerrber 17, 1996 anCl
Dec:enber 18, 1996 are vacated anCl replaced with this Order.
2. '!he parties shall submit themselves anCl the ChilClren to a
custody evaluation to be performed by Stanley SchneiCler, PhD, who was
selected by agreement of the parties anCl counsel. ,The Father shall be
responsible for the costs of the evaluation.
3. '!he Father, EdwarCI C. Terrel, anCI the Mother, Carla J.
Terrel, shall have shared legal custoCly of John E. Terrel, born May 30,
1986, IlIlCI Elizabeth C. Terrel, born July 5, 1988.
4. PenCling further Order of this Court or agreement of the
parties, the Mother shall have primary physical custody of the Children and
the Father shall have visitation with the Children at the Mother's
resiClence anCl with the Mother present for four hours on alternating
Saturdays. For a portion of this four hour perioCl, the Father may take the
Children to the school playgrounCl across the street from the Mother's
residence or to the play area in the Mother's apartment catplex with the
Mother present.
5. If the Mother consents and is present, the Father may have
aClc1itional periods of visitation with the Children as arranged by mutual
agreement of the parties.
6. '!he Father shall have an aClClitional period of visitation with
the Children on Christmas Eve from 5:00 p.m. until 9:00 p.m. at the
Mother's residence with the Mother present.
7. '!he Father shall be entitled to contact the ChilClren by
telephone every Wednesday evening at 7:00 p.m. anCl the Mother shall
cooperate in making the Children available for this scheduled telephone
call. '!he Father may also contact the Children by telephone at other
reasonable times as the ChilClren are available. The Mother may be present
in the roan with the ChilClren but shall not directly monitor the Father's
telephone calls on the line.
8. '!he Father shall complete an approved sexual offenders
,
(
,-
progrlll1l u rec..........nded by the CUni:lerland County Qlildren and Youth
services. 'Dle Father's voluntary participation in such a pr.ogrlll1l shall not
be construed u an admission of any allegations.
9. Upon the conclusion of the custody evaluation and in the
event that the parties are not Bble at that time to establish custody
arrangements by agreement, either party may pej:ition the Court to have this
case again scheduled with the OIatody Conciliator for a Conference.
BY TIlE CCXlRT,
.I~f~""':"" a. . ~
Kev n A. Hess
J.
co: Jordan O. CUnningham, Esquire..:for Father ' '.
Jan Terpening/Joan carey, Esquire-for Mother
. ..-,,' ...
TRUI COpy FROM RECORD
In T cstinlMY whp.rr.of, I here unto set my hand
ilrid the leel olaa:d Court at Carlisle, Pa.
this ....1.'1:-::::.. day of,..:J1.fY::.:;..., 19.f.:l..
.--.....;~.....~..:~~'
~fda-' Pro
,
..
EDWARD C. TERREL,
Plaintiff
IN THE COURT OF ~ PLEAS OF
CUMBERLAND CCXlN'1'Y, PENNSYLVANIA
vs.
NO. 96-444
CIVIL TERM
CARLA J. TERREL,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
PRI~ JtlDGB: Kevin A. Bes8
"""':l.UJx' CX'NCILIATION ~ REPCRr
IN ACXXlUlANC:B WI'1'B CDIBERLAND cx:unY RIlLE CP CIVn. 19?0 ~~ 'UHB
1915.3-8, the undersigned CU8tody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the
subjecbr of this litigation is as follows:
~
Elizabeth C. Terrel
John E. Terrel
. .--. '"
DA1'E OF BIRm
CDRRIlHTLY IN """":l.UJf CP
July 5, 1988
May 30, 1986
Defendant/Mother
Defendant/Mother
2. As stated in prior Reports, this case involves a very difficult
family, situation including serious issues/allegations which the parties
have been addressing in counseling for the Children and themselves. In
order to resolve the custody dispute, the Father has attended a 'seventy,
week seXual offenders program (allegations denied) through Holy Spirit
Hospital. Recently, Children and Youth Services have become involved in
this matter in connection with the Mother's obligation to supervise
visitation, which has further complicated resolution of this case. The
parties are scheduled to begin a custody evaluation in December through the
office of Stanley Schneider, PhD. Several Conciliation Conferences have
been held over the last two years (without the necessity of a Hearing to
date) with the most recent Conference having been held on April 22, 1997.
The following individuals attended that Conference: The Father, Edward C.
Terrel, with his counsel, Jordan D. Cunningham, Esquire, and the Mother,
Carla J. Terrel, with her representative, Jan Terpening.
3. At the April 22, 1997 Conference, the parties agreed to
participate in a custody evaluation, although the issue as to whether the
Father would be able to pay the expenses of the evaluation was left open
for determination. It was also agreed that the existing Order will remain
in effect without overnight periods of custody with the Father for the
parties' son during the school year except upon the recommendation of the
evaluator. Additional changes to the existing Order which are reflected in
the attached proposed Order resulted from a telephone conference with
counsel for both parties on September 25, 1997.
4. The Conciliator recommends
an Order in the form as attached.
~h nf IL~At'/t', {
wn S. Sunday, Esqu re
CUstody Conciliator
~heA 10 /997
DATE .
EXHIBIT "p_2'!
~
,
":~
'-... :")
. f~'.J
Holy Spirit Hospital
["cest Treatment Program
S03 North 21st Street
Camp Hill. PA 17011
Jordan Cunnin!lham, Esq.
Attorney at Law
2320 North 2nd Street
Harrisburg. PA 17109
Re: Edward Terrell
Dear,Mr. Cunningham.
This letter is written at Mr. Terrell's request to provi~ you with.information pertaining
to his therapy while he was involved in the Incest Offenders Program. Mr. Terrell began group
thempy sessions on May 22, 1996. He successfully completed the necessary educational material
on January 14. ] 998 and attended his one month follow up session on February II. 1998.
Education material presented during his course of treatment included dynamics of incest.
communication techniques. p5!'cho-social developmental stages, defense mechanisms. moral I
ethical issues. stress management. sexuality. and marilall family dynamics.
Mr. Terrell actively participated in group discussion topics and demonstmted an
improved understanding in incest dynamics and related issues. but remained in denial
concerning his actual reponed offense. Mr. Terrell does repon significant progress in the areas
of improved communication in his current relationship with his girlfriend and family members.
~iO~;~
Rhett A. Bennie
~i~ ~
Dl~ ~ :::l .u ... ::::
~~~al j ~~ jgkB~;;2
... = ~ -
.u = = ~
l: <<II = . "'Cl;
,ftl . II . <<IIl\l,~ ~
i!d~ I~ ~ '8 I'lIl iii :. == .c
I E .. ~ lj
os 1i e ~ ,-
;:: ~ ~
. iimlll~il
d2 t.I .
~ ==
I ~
DC r'~ 4 2tfl)~
"
EDWARD C. TERREL, : IN THE COURT OF CXlMMCX'l PLEAS OF
Plaintiff : CUMBERLAND CXXJNTll, PENNSYLVANIA
.
.
VS. . NO. 96-444 CIVIL TERM
.
:
. CIVIL ACTION - LAW
.
CARLA J. TERREL, .
.
Defendant . CUSTODY
.
alDER OF <XXlRT
AND NCW, this 2. ej'
consideration of the attached
and directed as follows:
day of O<.k b-v , 2000, upon
Custody Conciliation Report, it is ordered
1. The prior Order of this Court dated NovellCer 16, 1997 is vacated
and replaced with this Order.
2. The Father, Edward C. Terrel, and the Mother, carla J. Terrel,
shall have shared legal custody of John E. Terrel, born May 30, 1986, and
Elizabeth C. Terrel, born July 5, 1988.
3. The Mother shall have primary physical custody of the Children.
4. The Father shall have partial physical custody of the parties'
son, John, on alternating Saturdays fran 12:00 noon until 4:00 p.m.
begiMing Saturday, October 21, 2000. During the interim weeks and also on
an alternating weekly basis, the Father shall have a period of superviSed
visitation with the parties' daughter, Elizabeth for a minimum of 2 hours
at a supervising agency selected by agreement of the parties.
5. The Father shall be entitled to contact the Children by telephone
every Wednesday afternoon at 3:30 p.m. and the Mother shall cooperate in
making the Children available for the scheduled telephone call. The Father
may also contact the Children by telephone at other reasonable times as the
Children are available. The Mother may be present in the room with the
Children but shall not directly monitor the Father's telephone calls on the
line.
6. The Father shall have an additional period of visitation with the
Children on Christmas Eve fran 5:00 p.m. until 9:00 p.m. This period of
visitation shall be supervised unless otherwise agreed between the parties
or unless otherwise recommended by the Children's and the Father's
counselor.
7. The Father and the Children chall participate in a course of
counseling with stanley Schneider or other professional selected by
agreement of the parties. The purpose of the counseling shall be to
address problems which have arisen in the relationship between the Father
and the Children and to obtain recommendations concerning an ongoing
progressive partial custody/visitation schedule for both Children. The
Father shall be responsible to pay any costs of counseling which are not
reiniJursed by insurance coverage. '!he parties shall comply with the
recoamendatiOl18 of the counselor with respect to interim and ongoing
cuetody arrangements, as well as the frequency and duration of the
counseling sessions.
B. Within 90 days after receipt of the counselor's reconmenclation,
counsel for either party may contact the Conciliator to schedule an
additional CUstody Conciliation Conference, if necessary.
BY THE CXXJRT,
::Jt H1.!--
J.
co: Julie A. McConahy, Esquire - Counsel for Father> u.A.u' .k.( ID'.].I.' tJu
Joan Carey, Esquire - ~unsel for Mother I . /)'\1\.... ,
--r- '
~' :'" ~f..-' ,
EDWARD C. TERREL,
Plaintiff
IN THE CXXJRT OF CXlMMOO PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 96-444
CIVIL TERM
CIVIL ACTION - LAW
CARLA J. TERREL,
Defendant
CUSTODY
PRICE JIJDGB: Kevin A. Hees
aJS'lmY aH:ILIATION SlMlARl' REPCRl'
IN ACCXlUlANCB wrm cnmBRLAND CXUll'lC RIlLE OF CIVIL PRO< "'" um
1915.3-8, the undersigned CUstody Conciliator submits the following report:
1. 'll1e pertinent information concerning the Olildren who are the
subjects of this litigation is as follows:
NAME
MTB OF BlR1'8
aJRRml'LY IN aJS'lOOY OF
John E. Terrel
Elizabeth C. Terrel
May 30, 1986
July 5, 1988
Mother
Mother
2. A Conciliation Conference was held on October 18, 2000, with the
following individuals in attendance: 'll1e Father, Edward C. Terrel, with
his counsel, Julie A. MCConahy, Esquire and the Mother, Carla J. Terrel,
with her counsel, Joan Carey, Esquire and JeMifer Hernandez.
3. The parties agreed to entry of an Order in the form as attached.
()C/-v}"./J c:JO. 02a?r)
Date '
tU~._~
Dawn S. Sunday, Esqu re
Custody Conciliator