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HomeMy WebLinkAbout96-01114 , ,i ',... v ~ 4 , 1 : ;i "'~ :- ) ;'~':\" ~"".." ~, 1 ~ \, J )-.. ~,J ....J <J-. 'I~ ti STANLEY I. JONES, . IN THE COURT OF COMMON PLEAS OF . Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . . v. . CIVIL ACTION - LAW . . 'i,- . JOANNE M. RIDLEY, . NO. H-ll14 CIVIL TERJof . Defendant . . . CIVIL ACTION - CUSTODY . COURT ORDER AND NOW, this 2Z'::! day of ",.,""" consideration of the attached Custody Conciliation ordered and directed as follows: , 1996, upon Report, it is 1. The parties shall submit themselves and the minor children to a custody evaluation to be performed by a professiollal as agreed upon by legal counsel for the parties. Costs of this evaluation shall be paid by the Father, Stanley I. Jones. Upon the conclusion of this evaluation and in the event the parties are unable to reach an agreement on a permanent order at that time, either counsel may contact the Custody Conciliator to schedule another conference for further review of this case. 2. Pending further order of this Court, it is directed that the Mother, Joanne M. Ridley, and the Father, Stanley I. Jones, shall enjoy shared legal custody of Jennifer Ann Jones, born October 30, 1384, Cynthia Louise Jones, born March 26, 1986, and Stanley Carroll Jones, born March 3, 1988. The Mother shall enjoy primary physical custody of the minor children. The Father shall enjoy periods of temporary physical custody as follows: A. One weekend a month from Saturday afternoon until Sunday evening, the times to be arranged between the parties. B. At such other times as agreed upon by the parties. 3. Counsel for the Father shall make arrangements to handle on the record any procedural claims that the maternal aunt and uncle, Julia and Thomas Watts, may assert with respect to the three children who are the subject of this custody order. STANLEY I. JONES, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : v. : CIVIL ACTION - LAW . 'fL, . JOANNE M. RIDLEY, . NO. "K-1l14 CIVIL TERM . Defendant . . : CIVIL ACTION - CUS'1'ODY HONORABLE KEVIN A. HESS CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE J..'ITH CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: PRIOR JUDGE: 1. The information pertaining to the children who are subject of this litigation is as follows: Jennifer Ann Jones, born October 30, 1984 Cynthia Louise Jones, born March 26, 1986 Stanley Carroll Jones, born March 3, 1988 2. A Conciliation Conference was held on May 10, 1996, with the following individuals in attendance: The Father, Stanley I. Jones, with his counsel, James Flower, and the Mother, Joanne M. Ridley, with her counsel, Joan Carey. 3. The parties agree to the entry of an Order in the form &s attached. sl~o{q(, Date d;-kJ. Hubert X. Gil y, Esquire Custody Conc'liator '-!B ~. .~ Jl'; . - - .'. "'Y"~.' Iii.,,;.;"". ..... .., . ..' . . .... . ... ..:; .......;.:.;~. ',. !!IJ~"_~'~ ..' . . .. .. .~ .' -. ~. _ .~. ....~ .... l I I,L' . ( . f;: i ( " :to , Ij L ,.. , '. , 'J' ~ ~ ~ '" "'" . . . '" 0 I~~ gJ 5 5 " t: ~ :z: ....l 1] ~ < 0'" ~~ ....:>< ~ ~ ~ ...,... :><=1 :;; .... tJ~ ~ ~ .... ....it x~ E ~ ~ ~ f-< rn .... .... :> "'~ '" aim t 5~ ~~ ....u ~ ~ 5 Eo< ~ .... ~ a:l .. '" ....:z: ~ ~ .. ~;"'" ~ I.... z: ~ '" w.J t; '" 02 ~ '" ..., "" ~ ~u 0 0 :z: z .... ~UN 2 4 1997 . STANLEY I JONES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY NO 96-1114 CIVIL TERM IN CUSTODY V. JOANNE M. RIDL.EY, Defendant ORDER OF COURT AND NOW THIS <(~i day of \ J( '\ (:. , 1997, upon consideration of the attached complaint, i! is hereby directed that the parties an(Up'~!~,!e~~~q.t!:!~",,",,,, counsel appear before J~r t '/.., C,LLa:l1he conclhi[ltor, at (v ",,,..k,,,u " t['....l\"c;:.t- on the ~ S day of . \ ..,J~ ,1997 at .K:LCA.M)P.M., for a Pre-Hearing Custody Conference. At su h conference, an effort wlir6e 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. BY THE COURT, BY ) (u ere nlY . ~Q.r I 0 rl C'1xJ.1iL Custody Conciliator (\.b.) J'!r 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, please contact our ottice. 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 LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OF CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 I I :' v :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : :CIVIL ACTION - LAW : :NO: 96-1114 CIVIL TERM :IN CUSTODY STANLEY I. JONES, Plaintiff JOANNE M. RIDLEY, Defendant Prior Judge: Kevin A. Hess CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Jennifer Ann Jones, born October 30, 1984; Cynthia Louise Jones, born March 26, 1986 and Stanley Carroll Jones, born March 3, 1988. 2. A Conciliation Conference was held on July 25, 1997, with the following individuals in attendance: Attorney David A. Baric on behalf of the Mother and Attorney James D. Flower, Jr. on behalf of the Father. 3. This case was before the Conciliator in May of 1996 and the parties reached a consent agreement in July of 1996. The current Order provides that the Father has custody during the year with the Mother having custody during the month of July. Mother resides in Florida. 4. Mother now suggests that Father has not been providing appropriate parental care for the children and that the children have indicated to her a desire to live with her during the year as primary custodian rather than the Father. Mother has a variety of other complaints with respect to Father's handling of the children. Father suggests that the children are doing fine and that the current custody Order should remain in effect. 5. The parties are unable to reach an agreement, and a hearing is required. A hearing should take no more than one day. 6. The Conciliator recommends an Order in the form as attached. I) {;g( qi DATE Hubert x. Gilroy, Custody Conci1iat ....-. I T' C . C -I . ... ,t ... ~ ...;:, "'urt CT -m--'" - ~-~ ........ f ..~ ..-:.,.,-....... I -...--.,/ ,.. I..:. w _., ..........,. I --~ ,...."..-..... .-41- ....-.,.., I' . . ?S4lr:sy 1'I::r:i:: Stanley I. Jones 'is. Joanne M, Ridley :0;0, 1)6-1 1.1 ,... i \/11 'l'lPrm ::- :'jow, March 22. P.)I)6 :9_ !. s:~~: O? C~G::::..!..A.'ID CO~~':'Y. ?-\... co :::=y ci.::ue:: cl:..: 3h="~ oJ Cnlllmhia C-Ju:;:r ::J :.~:=".::.: ~ '.V:::. ~ ~~u=::...-u ::b; _"..l. u == ...~~ :..:c:i ~~ <Ji =: ?!Jl::.::. <6"''..:~ . .' , .' ....' ,,/ t" !ac.-":: ;'f '===er...1J:d C.n&:tT. ?3. Affidavit or .. . ~e:-n~ :'jow, ~9 -. o..:!cc "t 1:".-cl ::~ wti.~:~ '~;:ca 1; :y :::U:6i :Q J, c:-::pr ct ~ :J:-=.;::u ,.. U1d -,,";.. Cawtl :0 - ~ .::::::.:s :"~:==L So :x=w=- SCc:S ci ~u.:tTl :'2.. == :.:l3 _ 6:, :of ~9_ cosn ::~~""''1C:::: ~C!!..Z.'.GZ A::wA;-r;:- 3 5-=:: m<! s:.:i:sc:::-:::d !:c:::=: ------ s t_ "--a, IN CHAMBERS Jennifer Ann Jones Cynthia Louise Jones Stanley Carroll Jones FOR THE DEFENDANT Joanne M. Jones INDEX TO WITNESSES Pages 3-16 Pages 16-23 Pages 23-34 DIRECT CROSS REDIRECT RECROSS 35 45 48 49 2 1 BY THE COURT: 2 Q The record can reflect th&t we are in 3 chambers with counsel and that we are also with Jennifer Ann 4 Jones. And you wel'e born October 30th? 5 A Yes. 6 Q You are going to have a birthday coming up. 7 How old are you going to be? 8 A Thirteen. 9 Q Do you know what this is about today, why we 10 are here today? 11 A To discuss what's going to happen to us after 12 the custody hearing. 13 Q Okay. And in making that decision I need to 14 find out some things about you and about your situation. 15 Have you ever talked to a judge before about anything? 16 A No. 17 Q Well, I am just, believe it or not, just a 18 regular, ordinary person. So you don't have to be nervous 19 or anything like that. What grade are you in? 20 21 22 23 24 25 A Seventh. Q And that's the middle school? A Yes. Q And you live in Carlisle, right? A Yeah. Q So you are going to Wilson or are you going 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 to Lamberton? A Wilson. Q And do you have one teacher or is the middle school where you move around from class to class? A I move around from class to class. Q How many different teachers do you have in the course of a day? A I have four. And then I have a German teacher. Q A German teacher, you are taking German? A Yes, Ms. Graham. And Mr. Foley was replaced. And then Mrs. Baker, and Mr. Palm and then -- Q A whole bunch? A Yes. Q German is a hard language for a seventh grader. Do you do pretty well in school? A Yes. Q What sort of grades do you get? A Fours and Fives. Q What's your favorite Bubject? A Art. Q And do you like to draw or paint? A Yes. Q A little of both? A Both. 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q You do that at home as well as at school? A Yes. Q And speaking of home, right now you are living with your father, right? A And grandpa. Q And grandpa. Is there grandma too? A Yeah, Nana. Q Where do they live? A On Spring Road. Q Where? A Spring Road. Q Down here when you go right at the car wash or out north of town and go past Masland Carpet, or do you come out at the Weis Market? A You kind of go past what's called the Buggy Bath and then past the Turkey Hill. Q Okay. A A few houses down. Q What kind of house is it? Can you describe it to me? A It is a big house. It has three bedrooms. One and a half baths, a large kitchen and dining room, like a big living room that is split in half by the piano, which I sometimes play. Q Do you? 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A And then the one-half is hardwood floor, the other carpet and has a fireplace. o How about outside, do you have room to play? A Yes. The backyard is really big. The front yard is really big. There are two swing sets, one for the older kids and one for the younger kids. And you get a bus to school obviously? Yes. About what time do you catch a bus? About 7:12. Sometimes he is late. Sometimes 0 A 0 A he is early. 0 A 0 A 0 I see bus drivers haven't changed. He has other pick-ups. What time do they get you home? About 3:30. Tell me about a typical afternoon. Once you get off of school and you are home, what are your favorite activities? What sorts of things do you do? A Read. First I do my homework and then I read. Sometimes I might play one of the CD's in the computer. o You have a computer at home? A Yeah. At grandpa's. o Is that your grandpa's? A Yeah. My nana and grandpa's computer. 6 1 2 3 4 S 6 7 8 9 10 11 12 13 14 lS 16 17 18 19 20 21 22 23 24 2S Q Did you have a computer before when you were 1 i ving with YOUt. pop? A Yeah. Q He knows how to work a computer too? A Yes. Q You said there were three bedrooms in the house. Who sleeps where? A My nana and grandpa sleep in the master bedroom. My dad and my brother in his old room. And me and my sister share a bedroom which used to be my Aunt Ginny's room. Q So you and Cynthia have a room together? A Yes. We are used to that because we are used to sharing. Q When did you move into your grandparents' house? A I can tell you the exact date. It was Thursday, August 28th, around midnight. Q Around midnight? A We just came from seeing a movie and our stepmother dropped us off at grandpa's. Q I guess your stepmom and your dad had had an argument? A I don't know. I thought everything was okay. I didn't know what happened. 7 1 Q Sometimes there are surprises about that kind 2 of stuff. And give me that date again. You said August ) when? 4 A August 28th. 5 Q August 28th? 6 A It was a Thursday. 7 Q What do you think about your situation there 8 at your grandpa's and nana's? 9 A It is rather complicated. Sometimes fun. 10 Q Tell me what you mean when you say it is 11 rather complicated? 12 A Well, sometimes I forget that Monday I have 13 to put the garbage in the garbage can in the bedroom or that 14 Thursdays he vacuums. 15 Q So I gather there are some rules in the 16 house? 17 A. Yes. 18 Q Who makes those rules? 19 A Nana and grandpa both. They decide together. 20 Q And do all the kids have different or your 21 own chores to do? 22 A Basically we have to pick up our stuff, make 2) our beds, and empty the garbage on Mondays. Me and Cindy we 24 have to strip the beds for the sheets to be washed on 25 Saturdays. And Stanley I think his is done on Sunday. 8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q You need to write all that down somewhere. Have you written that down or are you trying to remember it all? A I am trying to remember it all. Q Other than that sort of thing, I mean, are you happy there? A Yes. Q You get along well with nana and grandpa? A Yeah. Q When was the last time you saw your mom? A Just today in the small room. Q Yesterday? MR. O'BRIEN: Today. THE COURT: She is here? JENNIFER: Yeah. And the time -- THE COURT: Why did I get the impression MR. FLOIIER: There was a memo which Mr. O'Brien had not expected her to be here. He was surprised, as I was, that she decided to come. JENNIFER: And the time before that it was the end of July when she brought us back up. BY THE COURT: Q And you had been living with your dad for about a year? A Yes. 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q And before that you were living for many years I guess with your mommy? A Yes. Q I heard that she lived quite a few different places? A Yes. Q How did you feel about that? A I didn't like it, because I lost my favorite teddy bear the first place we lived. Q Oh my goodness. And then you just moved around? A Yes. Q That was not your favorite thing to do, move around I gather? A No. Q You like teddy bears. I can tell from your shirt. A Yeah. Q And do you have any pets? A Yes. Q A cat? A No. Two finches. Q Two fishes. A Not fish, finches. They are little birds. Q Finches. Yeah, I know what you mean. 10 1 A They are about an inch high or something. 2 Q Do you have any feelings one way or the other 3 about whether you want to keep lJving up here or whether you 4 want to go with your mom or any thoughts on that matter? 5 A Well, I really don't like Florida because of 6 the banana spiders and pimento bugs. 7 Q You are quite an entomologist. I am not sure 8 I would recognize them. 9 A Well, a banana spider is poisonolls. A 10 pimento bug is the size of a giant cockroach. And I would 11 rather stay up here because I like the weather better. 12 Q I don't want to put words in your mouth, but 13 is the fact that you are settled into school and everything, 14 does that have anything to do with it? 15 A Yeah. Because all my friends are in 16 Carlisle. 17 Q Do you have any other relatives in Florida 18 other than your mom? 19 A My aunt and my uncle. 20 Q How about up here other than grandpa and 21 nana? 22 A Oh, in Florida I also have second cousins and 23 third cousins. They are in Pensacola. Up here I have my 24 aunt and uncle. They are going to be moving to Pensacola 25 with their daughter. And I have my aunt and uncle and my 11 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 other grandmother who lives on Spring Road. Q That's your mom's mother? A She is my other grandmother who lives on Spring Road. Nana is my grandmother. Q Any other relatives you can think of? A Cousins allover the place. My Uncle George is in Perry County. My Uncle Sam he is living with my grandmother. My Aunt Sharon is in Alaska. But other than that I can't think of anybody. Q Have you ever visited her in Alaska? A No. Q How long have you been playing the piano? A Oh, since the beginning of school started. I only playa few things. Q You have a teacher or you are trying to sound it out yourself? A I do it myself. I have music books. Q It sounds like you are a very talented young lady. I don't know if the attorneys have any questions. I have been asking a lot of questions. Anything you want to ask me? A Not really. Q Okay. Fair enough. THE COURT: Mr. Flower. MR. FLOWER: I have nothing to ask. 12 1 MR. O'BRIEN: Just a couple questions, Jen. 2 BY MR, O'BRIEN: 3 Q Jennifer, you remember meeting with me in my 4 office during the summer when your mom brought you up? 5 A Yes. 6 Q At that point in time apparently you were 7 living in a rather small apartment with your father and your 8 stepmother and a couple of their children? 9 A Yeah. 10 Q And you weren't happy living there is what 11 you told me, is that right? 12 A Yes. 13 Q But you are happier now that you are staying 14 with your grandparents? 15 A Yes. 16 Q And that's a bigger house and it has more 17 room and a yard and all those things you just told the 18 judge? 19 A Yeah. 20 Q And as I told your mother, that Mr. Flower 21 and I wouldn't, you know, tell anything that you say back to 22 your parents, that, you know, we just want you to feel 23 comfortable, that you can be honest with the judge and with 24 Mr. Flower and myself. So as I understand then, you are 25 happy where you are and would you like to stay there? 13 1 A Yeah. 2 Q You would like to see your mother on a 3 regular basis and have phone calls with her' and so forth? 4 A Well, usually I don't call her on the phone. 5 Q Why is that? 6 A Well, because I don't know, I just don't. I 7 like to write to her better. I can write things in words 8 better than say them. 9 Q Well, if it could be arranged that your 10 mother could call and speak with you at your grandparents' 11 house occasionally, would you like that? And you could 12 speak right to her, and she could write you of course? 13 A I don't know. 14 Q So you don't have any strong feelings one way 15 or the other about speaking with her? 16 A Yeah. Just as long as I am still able to 17 write to her. 18 Q Now, she only gets to see you presently for a 19 couple weeks in July and over Christmas? 20 A Yes. Every other Christmas. 21 Q Every other Christmas? 22 A On even years we see her at Christmas, and on 23 odd years we see her ~n July. 24 Q In July. Okay. Would you like to see her 25 more often than that? 14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q I don't know. Okay. MR. O'BRIEN: MR. FLOWER: THE COURT: Okay. I don't have any. May I ask one thing, Your Honor? Yes. BY MR. FLOWER: Q Your dad sleeps on the sofa, is that right? A Yes. Q Is he usually sleeping during the daytime because he works at night? A Yeah. He usually sleeps during the day. Q So he is not living in the apartment any longer? A No. We have all of our stuff out of there, like a week into school, and threw the keys behind and that's it. BY THE COURT: Q What time does your dad go to work? A Well, sometimes he just comes home and stays for like a day. And then his one friend calls him that works with him. and see if they have a store in Maryland or Halifax or something and they have to do that. So he goes up there and sometimes he stays in a hotel with his friends overnight. Because they figure if it is an hour away they are not going to bother coming home. They will stay in a 15 1 hotel nearby. Sometimes he will go stay the night with his 2 friend if they have another store to do if it is not worth 3 coming home if it is just for a few hours. Sometimes we 4 don't see him for a week. But we have seen him most of this 5 week. 6 Q And was he there when you came home from 7 school, for example, or did you see him in the morning 8 before you went to school? 9 A He was sleeping before we went to school. 10 Q So in the evening he was with you? 11 A Yeah. 12 Q Do you have E-mail on your computer? 13 A I am not sure. I don't really know. 14 Q You say you like to write letters. I just 15 wondered whether you have ever done that, written anybody on 16 the computer? 17 A No . 18 Q All right. Well, thank you for talking to 19 us, Jennifer. And maybe when you go out you can call 20 Cynthia or Cindy. 21 A Cindy. 22 Q Do you want to ask her to come in? 23 (Whereupon, Cynthia Louise Jones 24 was called into chambers.) 25 BY THE COURT: 16 1 0 Hi, Cindy, how are you? I guess I gather 2 from what Jennifer told me that you kids sort of know why we 3 are here today. Your parents, I don't know how serious the 4 disagreement is, I haven't found out about that yet. But 5 there is some concern about your going to stay with dad or 6 live with mom. You sort of understand that that's why I am 7 talking to you? 8 A Yes. 9 0 You do, okay. Don't worry. I am not going 10 to put you on the spot. I just want to find out something 11 about you. That's the only reason why I am asking these 12 questions, because I might have to make some decision in 13 this case and I need to know the kids that are involved. 14 You are how old? 15 A Eleven. 16 0 And that puts you in what grade? 17 A Sixth. 18 0 Sixth grade. You go to the same school as 19 Jennifer then? 20 A Yes. 21 0 You are sixth, seventh and eighth grade at 22 Wilson Middle School? 23 A Yes. 24 0 You move around from class to class? 25 A Yes. 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q This is the first year. You have always sat in one classroom before and had one teacher? A Yes. Q Do you like school? A Yeah. Do you? Yeah. What's your favorite subject? Science. Science. Do you do experiments and things Q A Q A Q like that? A Q than science? A Q A We will be. What's your favorite activity at school other What do you like to do? Clubs. What sort of clubs do you belong to? I am in choir and computer. Q You are a singer. Do you play any instruments? A Piano. Q When did you start the piano? A About -- I don't know. Q Has it been a long time? A It has been about a year. Q About a year. I hear there is a piano in 18 -... grandpa and nana's house? A Yes. Q Do you play that? A Yes. Q Do they like to listen to you play the piano or does it bother them sometimes? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Sometimes. Q You have some chores at grandpa and nana's house, is that right? A Yes. Q What are your jobs? A Sometimes I set the table, and sometimes I clear the table. And that's in the evening time when you have Yes. And who is usually there at dinner? Me, nana, grandpa, Stanley and Jenny. Q And how about your dad, is he there Q dinner? A Q evening time? A Q A sometimes? Yes. Do you eat together as a family in the A Only when he is home. Q When he is home. I understand he does travel 19 a lot? A Q A Q A Q A Q nana's house? A Q A ---- 20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 time? A Yes. o I got a lot of information from Jennifer, so I don't think I need to ask you too many questions, but it is important for me to know are you happy where you are? A Right now? o Yes. A Sort of. o Sort of. If you could change things, what would you change? A That I would live in one place and I would never have to move again. o Do you have any strong feelings about whether it would be with mom or with dad? A Well, I don't know. o Pardon? A I don't know. o You don't know. Okay. That's fair. That's an okay answer, nothing wrong with that. Is there anything you want to ask me now? A No. o Are you sure? Okay. All right. We will see if these attorneys have any questions they want to ask. BY MR. O'BRIEN: o Do you remember me from this summer when we 21 1 talk~d in my office in the summer? 2 A Yes. 3 Q And there again, as I asked your sister at 4 that time, you were living in an apartment with your 5 stepmother and your father and it was very crowded and 6 cramped and you were not happy? 7 A Yes. 8 Q At the present time Jennifer explained to us 9 the size of your grandparents' home and the yard and 10 everything that you have there. And that's the kind of 11 house that you would like to live in and stay in? 12 A Yeah. 13 Q Do you know whether your dad intends for you 14 to continue living at that home with your grandparents? 15 A Well, they say that we can't really live 16 there very long because it is hard for them because of the 17 extra and they have already raised three kids. And my dad 18 doesn't want to pressure them. 19 Q That is going to be hard for you because you 20 will have to move again once they say it is time for you to 21 move Oil? 22 A Yes. 23 Q Because we had kind of, you know. the 24 impression maybe that you could stay there for quite awhile, 25 but that's not what you think is going to happen? 22 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Yes. Q Now, your dad he travels a lot, apparently works away and he is out of the house for days at a time? A Yes. Q How long has he been doing that type of work? A Well, he started about a month before Ronnie just picked up and left. Q A month before you all moved suddenly over to your grandparents' r.ome? A Yes. MR. FLOWER: You are referring to Rhonda, that was your stepmother, is that right? CYNTHIA: Yes. MR. O'BRIEN: I have no other questions. MR. FLOWER: I don't have any. THE COURT: Would you ask Stanley to come in, your brother? (Whereupon, Stanley Carroll Jones was called into chambers.) BY THE COURT: Q Hi, Stanley. Come on in and have a seat. Let's see, you were born in 1988, right? A Yes. Q So you are how old? A Nine. 23 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q And that puts you in the third grade, fourth grade? A Fourth grade. Q And where do you go to school? A Hamilton. Q Hamilton. Do you take a bus there from where you are? A No. Q You can't walk, right? A I can't walk. Q You can't walk, but you don't take a bus either? A No. Q How do you get to school? A My grandpa dri.ves me. Q He drives you to and from school every day? A Yes. Q Had you been going to Hamilton -- well, of course, in August you weren't going to school. What am I saying where did you go to school last year? A Hamilton. Q So this is the same school you have been at for how long now? A Two years. Q Do you like Hamilton? 24 1 2 3 4 S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2S A Yes. o I can tell by the smile on your face you like school. What's your favorite subject? A Recess. o Every fourth grader says that. You must all talk to each other. Other than recess what's your favorite subject? A Gym. o Okay. You like sports? A Yeah. This is why I like gym the most because it is like recess. o It is like recess. Do you have a favorite sport? A Yeah. o What is it? A Tennis. o Tennis. Good for you. You are a tennis player? A Tennis, baseball, soccer. That's it. o I think it would probably be a sport that you don't like. Do you watch sports on television? A No. o So you haven't been following the baseball play-offs or anything like that? A No. 25 1 Q Both of your sisters are pretty musicaL. Do 2 you sing or playa musical instrument of any kind? 3 A Piano. 4 Q You are all piano players. You play the 5 oiano at grandpa and nana's house? 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Yes. Q And what can you play? A Twinkle, Twinkle Little Star. Q Can you play with two hands? A Yes. Q That's very good. When you are home and not at school what are your favorite things to do? A Q you learn that? A Q sisters? A Q A Q A Q A Computer, play outside and piano. You can also work the computer? Where did Where I live. Of course. I meant who taught you, your No. You learn it in school? No. Your dad? No. You just turned it on and figured it out? Well, I wasn't able to turn it on. I let my 26 1 2 ) 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2S ~ dad and grandpa do that. Bllt now they let me turn it on. rE I want to playa CD game, [ don't like get it out, take it out, put the (,0 in. [let my nana do that, Q Once they have got it started you play this game on the computer? A '(es. Q By moving a mouse around or do you push the keyboard? A I move the mouse around. And the most fun is the magic school bus that explores the solar system. I like playing the games and that includes the keyboard. Q And you fire guns and all that stuff and shoot things? A No. I don't fire guns. Q Oh, okay. You have a less violent program I guess. Did you see your mom yesterday? A Yesterday? Q Just today? A Yeah. Q How did you feel about that you haven't seen her for awhile? A I felt pretty happy. Q Okay. Obviously you like to be with your mom? A Yes. 27 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q How about your situation now, what do you think about living at grandma and grandpa's house? A Pretty exciting and pretty dull. The reason why it is pretty dull is because my really favorite sport is T.V. Q And, what, they don't like T.V,? A They don't really like to watch T.V. Q I see. Where is the television? A In the living room. Q And it is 1I0t on very much, is that the idea? A Yes. Q And do you try to turn it on and they turn it off? A Well, I usually ask if I can watch a movie. And I pick out the movie. Q Like a movie tape on the VCR? A Yes. Q Okay. And then you turn on the movie yourself, you know how to work the VCR? A Yes. Q You had lived with your mom for a long ti~e I guess, right? A Yes. Q I heard that you moved around to all different kinds of places? 28 A dad. 0 A dad or not. 0 A born. 0 29 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 a You are not sure he is? A Yeah. a Okay. All right. I just wondered who gave you tnat idea, that's all. Anything you want to tell me about that? A No. a Okay. But you are telling me you don't mind living with your father and your grandparents? A Yeah. a Okay. A But I really want to live with my mom. a But you really want to live with your mom down in Florida? A Yes. a Okay. How do you get along with your sisters? A What? a How do you get along with your sisters? A Not much. a Really. They do girl stuff and you do guy stuff. Is that sort of where we are at on that? A Yeah. Kind of I usually do mostly well. Me and Cindy play Barbies. a Okay. That's Cindy, but not Jennifer, Jennifer is a little older? 30 1 A She is into reading. Whenever Jenny and 2 Cindy are playing Barbies I am not. 3 Q Anything you want to ask me or anything you 4 want to tell me about your situation that we haven't talked 5 about? 6 A (No response) . 7 Q No? You look like you might have something 8 on your mind or not? 9 A (No response) . 10 Q We will let the lawyers ask you questions if 11 you have any questions. 12 BY MR. FLOWER: 13 Q Anything you particularly like about being in 14 Florida? 15 16 17 18 19 20 21 22 only main thing I don't like about Florida is whenever we go 23 to the beach I can't get in the water. 24 Q You can't get in the water, how come? 25 A Well, the winter is mating time for sharks. A Yeah. Q What do you like? A No snow. Q No snow? A Yeah. Q Anything else you like to do down there? A Since there is no snow I can ride bike. The 31 1 2 3 4 5 6 ? 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 a Mating time for sha~ks? A For sharks. They usually mate up in the Mexico Gulf. a A a A Does your mom have a boyfriend down there? Yes. How do you get along with him? Pretty good. MR. FLOWER: MR. O'BRIEN: BY MR. O'BRIEN: a Do you go by the name Stanley, Stan or hey I think that's all I have. I have a couple questions. you? A I don't go by hey you. Stanley, Stan. That's about it. a If I call you Stanley, is that okay? A Yes. o All right, Stanley. A That's my whole name. o That's your whole name. Do you get to spend much time with your dad? A No. o When you do spend time with him, do you get to play ball with him or soccer or anything like that? A No. Nothing. o He doesn't do anything with you? 32 1 A No. He is pretty tired. 2 Q Okay. We understand that he started this new 3 job about a month before you moved to your grandparents' 4 home? 5 A Yes. 6 Q Before that did he spend much time with you? 7 A No. 8 Q So most of the time that you spend doing 9 something with family members is with your sisters then? 10 A Well, before he started the job we weren't 11 getting along. 12 Q Before he started a new job, he and you were 13 not getting along, but someone was getting along, I don't 14 know who that other person was? 15 A Hailey. 16 Q Who is Hailey? 17 A My younger sister. 18 Q So your dad and Rhonda they had two children? 19 A Yes. 20 Q And how old is Hailey? 21 A Four. 22 Q Have you seen Hailey since your dad moved you 23 all into your grandparents' home? 24 A Daddy didn't move us into grandpa's. Rhonda 25 moved us there. 33 ~, 1 0 Rhonda moved you there? 2 A Yeah. She only left us with like a mystery 3 about why she left. And she only said one thing about why 4 she left. 5 6 7 8 9 10 MR. O'BRIEN: Thanks, Stanley. ,!'hat' s all I 11 have to ask you. 12 THE COURT: You can go on out and watch the 13 fish or whatever you were doing out there. Good meeting 14 you. Take care. 15 (End of proceedings in chambers.) 16 17 18 19 20 21 22 23 24 25 0 But you haven't seen Hailey since you moved? A No. 0 As I understand, you would like to move down and live in Florida with your mom? A Yes. 34 1 2 3 4 5 6 7 8 9 10 11 12 13 14 lS 16 17 18 19 20 21 22 23 24 2S MR. O'BRIEN: We are ready to proceed. Your Honor. THE COURT: Go ahead. Whereupon, JOANNE M. JONES having been duly sworn, testified as follows: DIRECT EXAMINATION BY MR. O'BRIEN: Q Would you state your name, please? A Joanne May Jones. Q And, Joanne, how old are you? A Thirty-one today. Q Now, the Judge and Mr. Flower and I were talking with your children just awhile ago. And the Judge needs to get some informati.on about your history and your present circumstances. And we were talking about that just prior to your taking the witness stand, is that correct? A Correct. Q Now, it would appear that last summer, that is the summer of 1996, that the children moved with their father, is that correct? A Correct. Yes. Q Prior to that time where had the children lived? A With me. 3S '...... Q one another? A Q A Q A Q A Q ~2 Q Did he exercise those times of visitation on 23 a regular basis? 24 A No. 25 Q As to the scheduled times, approximately what 36 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 percentage of the tLme wouLd he exercise his right to spend time wLth the chi.ldren? A r wouLd say about seventy to eLghty percent. 0 Now, Ln July of ' 96 you agreed that the children could go live wLth hLm? A Yes. o Could you explain why you agreed to that arrangement? A The children had lived with me all of their lives that they had known. And they told me that their father has changed, that he quit doing drugs. He quit smoking. He quit smoking cigarettes, and that he has changed, and that he was happier. And they wanted to give him a chance, and they wanted to get to know him. So I finally agreed to allow that. o Now, from what I see in the court records though during this same time period you had changed your home on a number of occasions? A Yes. o What was the reason that you were changing your residence on so frequent a basis? A Well, first of all, money has always been a problem, because I didn't get child support on a regular basis all the time. And at that time r did not have a job. I was unemployed. 37 1 2 Q Were you collecting assist3nce, public assistance, or anything like that? A No. Not at the time. Q When you say at the time, could you be more specific as to what time frame you are talking about? A From November of that year I was fired from :; 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 my job. Q November of 1995 or... A '95. Q '95? A Yes. I was fired from my job. And I was collecting unemployment until November of '96. And in that time I could not find a job. I had moved to Bloomsburg. And there was no jobs up there. Q What type of job had you had that you were terminated from in November of '95? A I was driving truck. Q That's presently what you do also? A Yes. Q How long have you been employed as a truck driver? A My recent job? Q Just overall since the children came along into your lives? A I got my CDL in '93. 38 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 H 20 2l. 22 23 24 25 ~ Q Prior to 1993 what type of employment had you done? A I had worked in kitchens. I worked as a night clerk in hotels, pretty much any job I could find. Q And then in '93 you got your CDL license? A Yes. Q And how many different employers did you work with after you got your CDL license? A Four -- five. Q Now, you gave the children over to their father in July of 1996, and then where did you move to? A I moved to Bradenton, Florida. Q Why did you select Bradenton, Florida. as a location to settle in? A Because I love the beaches. It was a nice area. I was hoping to get in with Tropicana. In some of the factories down there there is a lot of work. There is a lot of trucking industry. Q When did you move to Bradenton and what month? A I moved in the beginning of July of '96. Q Just about the same time or coincidental with the time that the children went to live with their father? A Correct. Q Now, since you have been down there, what 39 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 kind of employment have you had? A I drove dump truck for a company. I started there right after Christmas. And I worked there up until this past July. Whenever I came and went back home after dropping the children off the company had gone out of business while I was up here. So I did not have a job. And again I recently gained employment with another trucking company driving dump truck with my past employer's help. a With your past employer's help? A Yes. a That's the company that went out of business? A Yes. a What company are you presently working for? A Woodruff and Sons. a And could you tell us a little bit about the size of that company? A Woodruff and Sons is a nationwide contractor. I walk half a mile every morning back to my truck. It is a huge operation. a How big an operation is the truck terminal or the area that you work out of down in Bradenton? A We work allover Florida, allover the state of Florida. a would that entail your being away from home over nights? 40 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ---. A NQ. Q Could you tell us what you anticipate or are experiencing as your present work schedule with Woodruff? A With Hoodruff. Well, I work from 6:30 in the morning to 5:30 at night. My pay is $7.00 an hour. They pay one hundred percent of medical benefits. It is like a family. Q Is $7.00 per hour like an appropriate wage rat~ for a dump truck driver in Florida? A Yeah, I guess. I know some of the companies pay a little bit better. But I don't have enough experience to get one of those jobs. Q Now, are you involved with a gentleman in Florida? A Yes, I am. Q Could you tell us his name and his age and how long you have been seeing him? A His name is Richard Biggs. He is thirty-six. And I met him shortly after I moved to Florida. It was about a month after I met him I moved in with him. And we have been together since. Q And what is the type of relationship that you have with him? A We have threatened to get married. Q Does he threaten you or do you threaten him? 41 1 2 3 4 S 6 7 8 9 10 11 12 13 14 lS 16 17 18 19 20 21 22 23 24 2S -. A We threaten each other. Q What is the size of the home that the two of you share at the presen~ time? A Presently it is an efficiency apartment. There is like a large living room, bedroom, a kitchen and a And there is a lanai out in the front. What is a lanai? It is a large porch built in. Is it screened in or glassed in? No. Not right now. Now, where does he work? He works for Tropicana. How many years has he been employed there? He has been there eleven and a half years, And what type of work does he do at shower room. Q A Q A Q A Q A Q Tropicana? A Q at Tropicana? A He grosses $600.00 a week, sometimes more. Q How much time has he spent with your children? He is a pipe fitter. What income does he make from that employment A He spent a week at Christmas and the whole month of July with my children. Q And from your observations what kind of 42 1 relationship does he have with Jennifer, Cindy and Stanley? 2 A He loves my children. He told me that he 3 wished his children were more like mine. 4 Q How old are his children? 5 A Sixteen -- well, fifteen, fifteen and ten. 6 Q He is presently obviously separated from his 7 wife. Does he see his children on a regular basis? 8 A Yeah, 9 Q And where do they live? 10 A They live in the house that he and his wife 11 had bought in East Bradenton. 12 Q So that's right in the same area where you 13 are? 14 A Yes, 15 Q If the Judge were to make arrangements for 16 the children to spend more time with you on a basis, what 17 arrangements have you made, or can you make, to get more 18 rooms in your home for the children? 19 A We have decided that we are going to move to 20 East Bradenton into a larger home. My landlady has several 21 homes. And she loves us to death. So she offered us -- she 22 has been offering us for the last year a bigger home. So 23 any time we want one we have it. 24 Q East Bradenton and Bradenton, how big -- I 25 mean, are those separate communities or... 43 - 1 A No. It is the same city. It is just the 2 east side of Bradenton they call East Bradenton. And the 3 west side is the west side. 4 Q Are you familiar with the schools down there? 5 A Yes, I am. 6 Q Do they have a similar school system as here 7 in Pennsylvania where they have grammar schools and middle 8 schools and so forth? 9 A Yes. The schools in East Bradenton are much 10 better than the schools in the area I am in right now. So 11 that's another reason for moving that way. 12 Q Now, you have lived then with your boyfriend/ 13 fiance for about ten months? 14 A Roughly a year. 15 Q Roughly a year? 16 A Yeah. Almost a year. 17 Q We would like to know, you know, we have 18 heard that you threatened to marry one another, but I mean 19 the court has to understand how stable that relationship is. 20 Could you articulate and perhaps give us some more 21 illustrations of why you think this relationship will 22 continue? 23 A I am very happy with him. I feel safe with 24 him. And he feels safe with me. We have a great 25 understanding of each other's needs. I miss him. 44 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 a What hours does he work as a p:pe fitter at the Tropicana factory? A 7:30 to 4:00. a And that's a Monday through Friday schedule? A Monday through Friday. a And your work schedule yo~\ said it was, what, 6:30 to 5:30? A 6:30 to 5: 30. a Is that a Monday to Friday schedule also? A Yes, it is. a Are there day-care facilities available for the children for after school while they are young? A Yes, there is. a And have you inquired as to the cost and the location of those? A Yes, I have. MR. O'BRIEN: I have no other questions, Your Honor. CROSS-EXAMINATION BY MR. FLOWER: a Mrs. Jones, you are working presently at Woodruff and Sons? A Yes. a And how long did you say you have worked there? 45 Before that I worked with Sarasota Trucking. How long did you work for Sarasota Trucking? I believe it was the beginning of March. So that was maybe six months? Roughly, yeah. Did you work for them six months, am I getting that right, or was it a shorter per.iod of time? A I think it was like five and a half months, almost six months. And that takes us back to about March of '97? Yes. What job did you have before that? Before that I did not have a job. Okay. So that from July '86 to March of '87 Unemployed. Unemployed. Okay. What's your present address in Bradenton? A 1512 13th Street West, Apartment A. Q How long have you been in that specific 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q before that? A Q A 0 A Q Q A Q A Q you were A Q apartment? ~ I just started two weeks ago. Okay. What job did you have immediately A Since August of '96. 46 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 -. o August of '96. Okay. Now, you remember the petition which we filed before the last agreement for custody in which we set forth eighteen different addresses you have had over several years? A Yes. o Was that accurate pretty much? A No. o What inaccuracies appeared in that, do you recall? A No. I don't recall. But there was plenty of them. o Well, was that approximately the number of places that you had lived during that period of time? A It was fairly close, yes. o Okay. That's fine. Now, before today when was the last time you saw the kids? A The last day in July when I dropped them off, o How do you keep in touch with them in the period when you are in Florida and they are up here? A The only way I am allowed to is by writing to them. And that's only, from what I understand, if Jenny gets the mail before their father and the stepmother got home. o Well, you can call, can't you, Mrs. Jones? A No. I have tried to call. 47 -., 1 MR. FLOWER: I think that's all I have for 2 Mrs. Jones. 3 REDIRECT EXAMINATION 4 BY MR. O'BRIEN: 5 0 In regard to phone contacts, you would like 6 to have phone contacts with the children while they are at 7 their grandparents' home? 8 A I would love to. but I don't see it 9 happening. 10 0 Why is that, ma'am? 11 A Every time I called in the past Stan told me 12 that it created problems. that the children would act up 13 afterwards. And I decided I didn't want to cause that kind 14 of problems, because I knew it would come back on me. 15 0 Jennifer said that she likes to write with 16 you, to communicate with you? 17 A Right. 18 0 How often do you write one another? 19 A Usually about once, sometimes twice a month. 20 Sometimes more depending on whether I am working or not or 21 what she is doing. 22 Q Do you have the phone number of the home that 23 the children are living at now? 24 A No, I don't. I just recently found out where 25 they were living. 48 --- 1 Q When did you find out that they had moved? 2 A October 3rd I received a letter from my 3 daughter telling me the story what had happened. 4 Q That was from your daughter Jenni fer? 5 A Yes. 6 Q Did the other children include anything in 7 that letter? 8 A Stanley doesn't like to write. And Cindy, 9 from what I understand, spends almost all of her time with 10 her friend Lauren. And she hardly ever goes home. 11 MR. O'BRIEN: That's all I have then. 12 RECROSS EXAMINATION 13 BY MR. FLOWER: 14 Q Mrs. Jones, you indicated that your husband 15 had told you that Stanley acted up after you called? 16 A No. He said the children act up after I 17 call. 18 Q Okay. So then you decided not to continue to 19 call, is that correct? 20 A Correct. 21 MR. FLOWER: Nothing further, Your Honor. 22 THE COURT: Thank you. You can step down. 23 Do you have any other testimony for today? 24 MR. O'BRIEN: No. I do not, Your Honor. 25 THE COURT: Mr. Flower, is there anything you 49 -. ,'~" 1 want to offer for the r'Jcord toddY? I think we ought to get 2 the testimony of tho children transcribed and set a time and 3 see where we are. Sh... has dghts of pa>:tial custody over 4 Chr istmas'l The re if! no qUNlt ion about that? 5 MR, O'BRIEN: No. She apparently... 6 THr.: COURT: We will have the rest of the case 7 heard be fore Easter. I just wanted to make sure that there 8 is no quest Lon about custody. And it would seem to me that 9 an order setting further hearing that we could include some 10 provi8Lon concernlng teiephone access. 11 MrC FLOWER: Your Honor, I have had a chance 12 to turn a.fOund and talk to the grandparents. And they 13 certainly have no problem with Mrs. Jones calling. And they 14 certainly assured me that they are very happy to have the 15 children in their home, and are very concerned, and would 16 like to have the children and their father remain there. 17 THE COURT: Well, certainly by the beginning 18 of the next calendar year I would have available to me 19 report cards from the children. Perhaps your client, Mr. 20 O'Brien, will have made some definite decision as to whether 21 she i8 goinq to move, or do I hear her saying that she may 22 not her move may be contingent upon whether she is 23 granted custody or not? 24 MR. O'BRIEN: She indicates, Your Honor, that 25 she is movLng. 50 -- 1 THE COURT: Is moving in any event. So we 2 would then have available to us, if we have to take her 3 further testimony by telephone, perhaps we can do that. I 4 sense that I will know more about this case a little later 5 on. The situation at the grandparents' home will have had a 6 chance to stabilize. So unless there is some testimony you 7 want to offer today, Mr. Flower, I would propose to set an 8 early date in '98 and complete the record in this case and 9 make some decision when we have more information that's 10 available. 11 MR. FLOWER: That's agreeable to us, Your 12 Honor. 13 THE COURT: Let' 8 do that. And let me tell 14 both parents, cute kids, smart, delightful. 15 We will be in recess. 16 (End of proceedings.) 17 18 19 20 21 22 23 24 25 51 : I i I I 1 I 2 I , I 3 I 4 i 5 i 6 ! I 7 I 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 -'. -- CERTIFICATION I hereby certify that the proceedings are contained fully and accurateLY in the notes taken by me on the above cause and that this is a correct transcript of same. !6.ukui i'.XktdQAJ( ~ Barbara E. Graham Official Stenographer The foregoing record of the proceedings on the hearing of the within matter is hereby approved and directed to be filed. "bc.~ Date 'I iff} , /IlL A. Hess, J. Judicial District 52