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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
ROBERT ENSMINGER,
Plaintiff
NO. 96-3332 CIVIL TERM
MICHELE RENEE ENSMINGER,
Defendant
CIVIL ACTION - LAW
CUSTODY
AND NOW, this
ORDER
'1 il, day of -1J":) v t ..... ~ eJ ,1997, upon receipt
of the Conciliator's Report, the Mother having appeared with counsel and advising
the Conciliator that she no longer wishes to pursue the Petition for Modification and
Contempt that she flied, It is hereby ordered and directed that all prior Orders
entared In this case shall remain in full force and effect.
BY THE COURT,
Joan Carey, Esquire
Scott M. Staller, Esquire
j/~
J. ~SLEY OLER, J
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5, Pursuant to Paragraph # 3, Subpart A, Petitioner, Michelle R. Ensminger, is to luwe
visitation on alternating weekends and one evening during the week,
6, On Friday, August 29, 1997, and Wednesday, September 3, 1997, Petitioner was
unable to obtain her children for her period of visitation,
7, Respondent has failed and/or refused to comply with the order of October 25, 1996 in
that RllSpondent has denied Petitioner her period of visitation,
8, Petitioner requests that this Honorable Court find Respondent in contempt of court for
failing and/or refusing to comply with the court order dated October 25, 1996 for the reasons set
forth abovo,
WHEREFORE, Petitioner requests that this Honorable Court find Respondent in
contempt of court for failing and/or refusing to comply with the court order dated October 25,
1996 for the reasons set forth in the above Petition for Civil Contempt for Disobedience of
Custody Order,
COUNT II. PETITION FOR MODIFICATION OF CUSTODY
---------.--.----------------------
The Petitioner, Michele Renee Ensminger, files the within Petition for Modification of Custody,
and respectfully represents:
9, Paragraphs I through 4 are hereby and herein incorporated by reference as though the
same were fully set forth herein,
10, Petilioner seeks primary physical custody of the children for the following reasons:
A, The children have started to engage in shoplifting while in the custody of their
father and have been present when their father has engaged in shoplifting certain items;
,
II. Petitioner also believes it is in the best interest of the children to have partial custody
for the purposes of visitation on an alternating weekend schedule as well as alternating holiday
schedule. because Petitioner believes there is a lack of stability in the lives of the children,
WHEREFORE, Petitioner respeclfully requests primary, physical custody of the children
with partial custody for the purposes of visitation on an alternating weekend schedule as well as
an alternating holiday schedule,
Respectfully submilled by,
~?I~~/ D.
SCOII M, Staller, Esquire
p, 0, Box 264
New Bloomfield, PA 17068
Telephone: (717) 582-7574
Attorney for DefendantJPelitioner
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(l9I1999.opo:lOllunol3. 19961MCD/PARI'4070
'1
ROBERT ENSMINOER,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUk~TY. PENNSYLVANIA
NO. lIb ',3] 3.;J ~1~f-Yetlt1
CIVIL ACTION. CUSTODY
Plaintiff
v.
MICHELE RENEE ENSMINOER,
Defandant
COMPLAINT FOR CUSTODY
AND NOW, come, tha Plaintiff, Robert Ensmlngar, by and through his ettorneys, Johnson, Duffla,
Stewart & Weidner, end In support of this Complaint for Custody avers as follows:
1. The Plaintiff Is Robert Ensminger, rasldlng at 146 East Dauphin Streat, Enola, Cumbarland
County, Pennsylvania, 17026.
2. The Defandant Is Michele Renea Ensmingar, re~lding at 181 South Frontier Street,
Wickenbarg, Arizona.
3. The Plaintiff saaks physical custody of the following children:
NAME
PRESENT RESIDENCE
~
Jered Thomas Ensminger
146 East Dauphin Street
Enola, PA 17026
6
Nevin William Ensmlngar
146 East Dauphin Street
Enola, PA 17026
4
The children were born out of wadlock. The children are presently In tha custody of Plslntlff,
Robart Ensminger, who resides at 146 East Dauphin Street, Enola, Pennsylvania.
Q99999.()QOOOIJun. 13. 1\l961MCD/PAR/54070
During the past five (51 yeers. the children hava residad with the following parsons and et tha
following addresses:
NAMe ADDRESS DATES
lal Robert Ensminger 146 East Dauphin Street December 20. 1996 through Present
Enola. PA 17025
Ib) Robert end Michele 205 Michael Drive April 15, 1995 through
Ensminger Middletown. PA 17057 December 20, 1995
leI Robart and Michele Dauphin. PA On or about December, 1994
Ensminger through April 15, 1995
Id) Robert end Michele 146 East Dauphin Straet January 15, 1993 through
Ensminger Enola, PA 17025 Decembar of 1994
(e) Robert end Mlchale 236 South Enola Drlva
Ensminger Enola. PA 17025
The mother of the children is Michele Ranee Ensmlngar, currently residing at 181 South frontlar
Straat, Wickanbarg, Arizona. She is currently merried to tha Plelntiff.
The father of tha children Is tha Plaintiff, Robart Ensminger, currently residing et 146 East Dauphin
Street, Enola, Pennsylvania. He is currently married to the Defendant.
4. The relationship of tha Plaintiff to the children Is that of father. Tha Plaintiff currently
resides with the following persons:
NAME
RELATIONSHIP
Jared Thomas Ensminger
Son
Nevin William Ensminger
Son
.2 -
ClIl9l'99.0Q020IJuno 13. 1996JMCD/PARI'4070
(c) From December. 1995 through the middle of May. 1996, the Dafendant made
no attampt to contact her children or her husband, theraby essentially abandoning her
family to cohabltata with her boyfriend, Steven Sultzbarg, In Phoenix, Arizona.
(d) On or about May 10, 1996, the Plaintiff received s letter from the Dafendant
In an attempt to contact the Defendant and her children.
(e) On June 8, 1996, tha Defendant and her boyfriend, Steven Sultzberg, arrived
In Baltimore. Maryland, on a flight from Phoanlx. Arizona, arriving In Centrel Pennsylvania
on that same dete.
(f) The Defendant then contacted the Plaintiff regarding a short visitation with
the two (2) minor parties, Jared Thomas Ensmlngar end Nevin WIlliam Ensminger.
(g) The Defendant and her boyfriend. on Monday, June 10, 1996, assured and
reassured the Plaintiff that his minor sons would be raturnad by 8:00 P.M. on TueSday,
June 11, 1996.
(h) On Tuasday, Juna 11, 1996, tha Plaintiff received a phona call from the
Defendant stating that the Dafandant was leaving for Ocean City. Maryland, with her
boyfrland and tha two (2) minor children.
(I) The Dafendant snd her boyfriend have Indicatad that they are taking the
minor children to Phoenix, Arizona, permanently on a flight departing Baltimore, Washington
International Airport, on Juna 15, 1996.
8. The Defendant, by abendoning har minor children has proven herself unfit ss e parent. As
a result of tha Defendent's abandonment, the Plaintiff and his sons heve grown extremely close and It
would be In the best Interest of the children to remain In the full custody of tha Plaintiff, their fathar.
.4-
Q99999.ooc120/Juno 13, I9961MCD/PARlH070
9. Each pareOlt whose parental rights to tha children have not been terminated and the person
who has physical custody of the child have baen named as parties to this action.
WHEREFORE, Plaintiff requests the Court to grant legal custody of the children to the Plaintiff.
Respactfully submitted,
JOHNSON, DUFFIE, STEWART & WEIDNER
OATE:~' 1996
By:
-?-r:~~ (? I
Mark C. Duffie, Esquire
Attorney 1.0. No. 76906
301 Market Street
P. 0, Box 109
Lemoyne, PA 17043-0109
Telephone (717) 761-4640
Attorneys for Plaintiff
- 6 -
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ROBERT ENSMINGER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - CUSTODY
v,
MICHELE RENEE ENSMINGER,
Defendant
96-3332 CIVIL TERM
ORDER OF COURT
AND NOW, this 28th day of June, 1996, upon
c~n.ideration of the Plaintiff's Petition To Prevent Removal of
Children from Jurisdiction Pursuant to Pa. R, civ, 1915.13 and
Request for Immediate Hearing, and pursuant to an agreement
between the parties in open court as announced by their counsel,
Mark C, DUffie, Esquire, on behalf of the Plaintiff, and Scott
M, staller, Esquire, on behalf of the Defendant, it is ordered
and directed with respect to the parties' children, Jared Thomas
Ensminger and Nevin William Ensminger, pending further Order of
Court and the conciliation in this case, as follows:
1, The parties shall share legal custody of their
children,
2, The parties shall share physical custody of the
children on an alternating weekly basis with each week of such
custody commencing on Monday at 11:00 a,m. and ending at 11:00
a,m, the fOllowing Monday. Exchanges of custody shall occur at
the Plaintiff's residence at 146 East Dauphin street, Enola,
Pennsylvania, The mother's initial period of custody herein
shall begin on Monday, July 1, 1996, at 11:00 a,m,
3, The Plaintiff shall provide to the Defendant
the tee-ball schedule which applies to Jared Thomas Ensminger,
,
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: IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:
:CIVIL ACTION - LAr-/
.
;NO. in 1. CIVIL 19')t
: CUSTODY/VISITATION
V
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, 'if "t f Defendant
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ORDER OF' COURT
AND NOW, this (date) '"211 '?/n , upon consideration of the
attached complaint, it is hereby di~ected that the parties and
their respective counsel appear bef.:Jre rl"rt. L, e. I e
the conciliator, at . (l ~'( ~.... p
on the '). 1 r\ day of , 9 q"1 , at ).. '.00
p, H., for a Prehearing 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 tempora.ty order. Either
party may bring the child who iB the Bubject of this cUBtody
acti.on to the conference, but the chi.ld/chi.ldren' B attendance iB
not mandato.ty. Failure to appear at the conference 'may provide
groundB for entry of a temp,?ra.ty or permanent order.
,
FOR THE COURT:
By: /J1iJ ,L L.~,A, ~ ( r!~~ )
Custody Co~tor I
YOU SHOULD TAKB 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 7'0 FIND OUT WHERE YOU CAN GET LEGAL HELP.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, FOURTH FLOOR
CARLISLE PA 17013
(717 )240-6200
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
ROBERT ENSMINGER,
CIVIL ACTION. CUSTODY
Plaintiff/Respondent
v,
No, 96-3332 Civil Term
MICHELE RENEE ENSMINGER,
Defendant/Petitioner
PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF CUSTODY ORDER
AND NOW, comes the Petitioner, Michele Renee Ensminger, who by and through her
attorney, Scott M, Staller, Esquire, files the following Petition for Civil Contempt for
Disobedience of Custody Order, pursuant to Pa,R.C,P, 1915,12:
\, Petitioner, Michele Renee Ensminger, is an adult individual residing at 16 West Main
Street, Apt. # \, N"w Bloomfield, Perry County, Pennsylvania 17068,
2, Respondent, Robert Ensminger, is an adult individual residing at 146 E, Dauphin
Street, Apt, Right Rear, Enola, Cumberland County, Pennsylvania 17025,
3, Petitioner and Respondent are the natural parents of two children: Jared Thomas
Ensminger, born October 12, 1989, age 7, and Nevin William Ensminger, born November \6,
1991, age 5,
4, There has been a prior action for custody instituted to the above captioned case and
number and there is a custody order dated October 25, 1996 currently in effect. A copy of the
custody order dated October 25, 1996 is attached hereto as Exhibit" A" and is herein and hereby
incorporated by reference,
S, Pursuant to paragraph number eight (8) of the order dated October 25, 1996, the
parties shall share transportation equally,
6. Pursuant to the order dated October 25, 1996, the parties shall share legal custdoy of
the children,
7, Respondent has failed and/or refused to comply in the sharing of the transportation of
the children despite repeated allempls by Petitioner to reach an amicable solution for the
transportation of the childrl'n,
8, Petitioner has been required to transport the children to and from Respondent's
residence in order to obtain visitation and comply with the order dated October 25,1996,
9, Respondent has also failed and/or refused to notify Petitioner ofany and all school
related activities for Jared Thomas Ensminger,
10, Respondent has also failed and/or refused to give a copy of Jared Thomas Ensmiger's
report card to Petitioner,
11, In order to obtain a copy of Jared Thomas Ensmiger's report card, Petitioner was
required to request a copy from the school district,
12, Petitioner requests that this Honorable Court find Respondent in contempt of court
for failing and/or refusing to comply with the court order dated October 25, 1996 for the reasons
set forth above,
WHEREFORE, Petilioner requests that this Honorable Court find Respondent in
contempt of court for failing and/or refusing to comply with the court order dated October 25,
1996 for the reasons set forth in the above Petition for Civil Contempt for Disobedience of
Custody Order,
Respectfully submitted by,
_k91LM
Scott M, Staller, Esquire
p, 0, Box 264
New Bloomfield, PA 17068
Telephone: (717) 582-7574
Attorney for DefendantlPetitioner
---..-"'-"-''''
. '
VERIFICATION
I verify that the statements in this Petition for Civil Contempt are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa,C,S, ~ 4904
relating to unsworn falsification to authorities,
Date: 1/'J.'t(Q1
~-~--_...
Michele Renee Ensminger
()
'.-.'
8. During the summer months, the children will reside
prlmerily with Mother. Father will have the children every other
weekend baglnnlng on Friday at 4:00 p.m. until Sunday at 8:00 p.m.
In aciditlon. Father shall hava the children one evening each week
overnight If his work schedule permits. If the parties cannot
otherwise agree, that evening will be Wednesday. This will occur
from 4:00 p,m. until the following morning at which tlma the Father
will drop the children back to Mother's residence.
4. 80th parties will be entitled to one uninterrupted weak of summer
vacation with the children. The psrtles shall provide each other with thirty
(30) days notice as to when they Intend to exercise that period of
uninterrupted vacation. The first party to provide the other with notice gets
the first week requested.
5, The partlas shail alternate the major holidays. Those major
holidays are defined as Thanksgiving, Easter, Memorial Day, Fourth of July
and Labor Day. These holiday schedulas will Include the entire weekend
from when tha children are released from school until the end of the holiday
at which time the children will be returned at 8:00 p.m. This alternating
holiday schedule will begin with Mother having Thanksgiving In 1996.
6, The Christmas holiday will be divided Into two segments.
Segment A will occur from when the children are released from school until
3:00 p.m, Christmas Day. Sagmant 8 wlil occur from 3:00 p.m. on
Christmas Day until 3:00 p.m. December 26. This elternatlng schedule will
- --..--_..__.,--~
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
ROBERT ENSMiNGER,
Plaintiff
NO. 96-3332 CIVIL TERM
MICHELE RENEE ENSMiNGER,
Defendant
CIVIL ACTION - CUSTODY
JUDGE PREVIOUSLY ASSiGNED: The Honorabla J, Weslsy Oler, Jr.
CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8(bl, the undersigned Custody Conciliator submits the
following report:
1. The pertinent information concerning the chlld(renl who Is(arel the
subject of this litigation is as follows:
NAME
BIRTHDATE
CURRENTLY IN
CUSTODY OF
Jared Thomas Ensminger October 12,1989
Nevin William Ensminger November 16, 1991
Plaintiff
Pialntiff
2. A Conciliation Conference was held on 17 October 1996, and the
following Individuals were present: the Plaintiff and his attorney, Mark C. Duffie,
Esquire; the Defendant appeared with her attorney, Scott M. Staller, Eequire.
3. Items resolvad by agreement: See attached Order.
4. Issues yet to be resolved: Sea attached Order.
5. The Plaintiff's position on custody Is as follows: See attached Order.
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ROBERT ENSMINGER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v. NO. 96.3332 CIVIL TERM
MICHELE RENEE ENSMINGER, CIVIL ACTION - CUSTODY
Defendant
~
AND NOW, June 14. 1996, upon consideration of the attached Petition, a
hearing Is scheduled for Friday, June 28, 1996, at 8:30 a.m. In Courtroom No.5,
CumberlanCt County Courthouse, Carlisle, Cumberland County, Pennsylvania.
Pending the hearing, the parties shall share legal custody of their children,
Jared Thomas Ensminger and Nevin William Ensminger. PlaIntiff shall have
primary physical custody of the children, and Defendant shall have temporary or
partial physical custody each week from Wednesday at 7:00 p.m. until Thursday
at 7:00 p.m. Pending the hearing, the custodial periods of the parties shall be
exercised In Cumberland County, Pennsylvania, and the parent exercising custody
shall advise the other party as to where the chllaren are being kept.
By the Court,
Mark C. Duffle, Esquire
PO Box 109
Lemoyne, PA 17043-0109
J.
. Wesley e
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099999.000201Juno 13. 19961MCD/PARI'4078
ROBERT ENSMINGER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
NO.
v.
MICHELE RENEE ENSMINGER.
Defendlnt
CIVIL ACTION. CUSTODY
EMERGENCY PETITION TO PREVENT REMOVAL
OF CHILDREN FROM JURISDICTION PURSUANT TO PA. R.CIV. 797~. 73
AND REQUEST FOR IMMEDIA TE HEARING.
AND NOW. comes the Plaintiff, Robert Ensminger, by end through his ettornays, Johnson, Duffle
Stewert & Weldnar, end In support of this Emargency Petition avers as follows:
1. The Petition Is Robert Ensminger, Plaintiff in the ebove-ceptloned metter.
2. The Respondent Is Michele Renee Ensminger, Defendant In the above-captioned matter.
3. The parties were married on September 11, 1994, In Enola. Cumberland County,
Pennsylvania, and were separated on or about August 25, 1995.
4. There are two (2) minor children of the marriage, Jared Thomas Ensminger, age 6, an
Nevin William Ensminger, age 4.
5. Plaintiff has filed a Complaint for Custody simultaneously with the filing of this Petition, an
Incorporates by refarence tha averments In the Complaint.
6. The parties separated on or ebout August 25, 1995, and since that tlma have not entered
Into an Agreement with respect to the custody of the two (2) minor children.
099999-0002011"nol3. 19961MCD/PARl5407.
7. Tha Petitioner. since the Respondent's departure form the marital homa in August of 1995
has been the primary care taker and has primary physical custody of the children.
8. Raspondent has taken the children from the Patltlon egelnst his will to Oceen City
Marylend, on Monday, JUlla 10. 1996.
9. Respondent indlcelad via telephone. that sha will be returning to Phoenix, Arizona, with th
two 121 minor children on June 15, 1996, departing from Baltimore, Washington International Airport.
10. The eldest child, Jared Thomas Ensminger, attends East Pennsboro Elementery School, I
Cumberland County, Pennsylvania. Nevin William Ensminger will attend pre-kindergarten at Eas
Pennsboro High School, beginning September of 1996. The children are flourishing In their present school
arrangements.
11. The children are members of the Our Lady of Lords Catholic Church, In Cumberland County.
Pennsylvania, and they regularly attend services there.
12. Tha children's pediatrician. Dr. Bruwa, Is located In Cumberland County, Pennsylvania,
Addltlonelly, the youngest. Nevin William Ensminger, recently underwent s hernie operetlon at Polyclinic
Hospital In Harrisburg, Pennsylvania. Dr. Domingo Alvera performed the surgery ond Nevin has a checkup
with Dr. Alvera schedula for July 9, 1996, at 11 :00 A.M.
13. Members of tha Petitioner's extended family. Including his mother and father, Carol and
Navin Wolfe and his five (6) brothars and sisters reside in Cumberland County. Pennsylvania.
14. The Respondent's extended family. Including har mother. Florence Phillips. and her sister.
Tracy Phillips, reside in Middletown, Dauphin County. Pennsylvania, only mlnutas from Cumberland
County, Pennsylvania. Additionally, tha Respondent's brothers. Wayna Phillips and Glenn Phillips, both
reside In the Cumbarland County area.
- 2.
O99999-OOO2OIluno 13. 19961MCD/PARl54018
16. Tha children heve effection end close bonds with thair extended family.
16. The children', friends and playmates all reside In the Cumberlend County area.
17. The Pet~ijoner has had substentlallnput into the children's lives since their birth. and ha
a cl08a and loving bond with each child.
18. The Respondent'. proposed Involuntary relocation of the ct.:ldran does not consider th
needs of the children.
19. The Respondent's proposed relocetion of the children will severely disrupt the dey-to-dey
lives of the children.
20. Respondent hes not commenced eny proceeding seeking to relocate the children.
21. If Respondent Is permitted to remove the children to Phoenix. Arlzone, under the present
clrcumstences, the Petitioner will be denied any and all custody rights as well as the comfort end
companionship of the children for which he has cared elone for the past six (61 months.
22. The ramovel of the children ageinst the will of the Petitioner is not In the best Intarast end
welfere of the children.
23. The Petitioner will be Irreparably harmed should Respondent remove the children from this
Jurisdiction.
.3.
099999.00020/Ju.oI3. 19961MCD/PARl54078
WHEREFORE, the Petitioner respectfully requests that en Order be Issued restraining Responden
from relocating the children to e new residence until further Order of this Court, and furthar request that
phYllcal custody of the children be awarded to him,
Respactfully submitted.
JOHNSON, DUFFIE, STEWART"" WEIDNER
DATE:~' 1996
By:
Mark . Duffle, Esquire
Attorney 1.0. No. 76906
301 Market Street
P. O. Box 109
Lemoyne, PA 17043-0109
Telephona (717) 761-4640
Attorneys for Plaintiff
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ROBERT ENSMINGER,
Plaintiff
vs.
MICHEL.E RENEE ENSMINGER,
Defendant
AND NOW, this
1-. L day of
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 96-3332 CIVIL TERM
CIVIL ACTION. LAW
CUSTODY
ORDER
,~
, 1997, upon receipt
of the Conciliator's Report, it appearing that the parties have reached an agreement
as to ell outstanding issues raised in Mother's Petition for Contempt, and that the
agreement was dictated in their presence and approved by them and their counsel,
it is hereby ordered and directed as follows:
1. The Order of October 26, 1996, will remeln in full force and
effect with the following modifications:
A. Mother shall be providad with any and all records
related to the children's school activities and school gredes in
accordance with her shared legal custody of the minor
children. This Information is to be provided to her by Father
and by the appropriate school district so that Mother can have
these schedules and report cards available to her.
B. The parties shall share transportation such that the
party who Is starting his or her period of partial custody or
visitation with the children shall provide the pick up for those
periods.
C. Each party Is to ba provldad with telephone access
with the children one time por week to occur on the Sunday
when the children are not In their custody. This telaphona
access shall consist of no more than one call to occur between
7:30 p,m. and 8:00 p.m. It Is understood by this provision
that this Is for purposas of talking with the children alone.
BY THE COURT,
Legal Services, Inc.
Scott M. Staller, Esquire
_ C-4-bLt- ()>:~,tt !,/JJ /fi? .
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6. The Defondant's position on custody Is as follows: Sse attach&d Order.
7. Need for separate counsel to represent chlld(ren): Neither party
requested.
8. Naed for independent psVchologlcal evaluation or counseling: None
requested and the Conciliator does not believe any is necessary.
Mlch el L. Bangs'
Custody Conciliator
;/
Date: April 26, 1997
B, During tha summer months, the children will reslda
prlmarllv with Mothar. Father will have tha children Jverv other
weekand beginning on Frldav at 4:00 p.m, until Sunday at B:OO p,m.
In sddltlon, Father shall have the children one evening each week
overnight If his work schedule permits. If the parties cannot
otherwise agrae, that evening will ba Wednesday. This will occur
from 4:00 p.m. until the following morning at which tlma the Father
will drop the children back to Mother's residence.
4. Both parties will be entitled to ona uninterrupted week of summer
vacation with the children, The parties shall provide each other with thlrtv
(30) days notice as to when they Intend to exerclsa that period of
uninterrupted vacation. The flrat party to provide the other with notice gets
the first week raquested,
6. The partlas shall alternate the major holldavs. Those major
holldavs are defined as Thanksgiving, Easter, Memorial Dav, Fourth of JulV
and Labor Dav. These holldav schedules will include tha entire weekand
from when the children are released from school until the end of the holldav
at which time the children will be returned at 8:00 p.m. This alternating
holldav schedule will bagln with Mother having Thanksgiving In 1996.
6. Tha Christmas holldav will be divided Into two segments.
Segment A will occur from when the children are released from school until
3:00 p.m, Christmas Dav. Segment B will occur from 3:00 p,m. on
Christmas Day until 3:00 p,m. December 26. This alternating schedule will
ROBERT I:NSMINGER,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 96-3332 CIVIL TERM
vs.
MICHELE RENEE ENSMINGER,
Defendant
CIVIL ACTION - CUSTODY
JUDGE PREVIOUSLY ASSIGNED: The Honorable J. Wesley Oler, Jr.
CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the
fOllOWing report:
1. The pertinent information concerning the child(ren) who Is(are) the
subject of this litigation Is as follows:
NAME
BIRTHDA TE
CURRENTLY IN
CUSTODY OF
Jared Thomas Ensminger October 12,1989
Nevin WIlliam Ensminger November 16, 1991
Plaintiff
Plaintiff
2. A Conciliation Conference was held on 17 October 1996, and the
follOWing Individuals were present: the Plaintiff and his attorney, Mark C. Duffie.
Esquire; the Defendant appeared with her attorney, Scott M. Staller, Esquire.
3. Items resolved by agreement: See attached Order.
4. Issues yet to be resolved: See attached Order.
5. The Plaintiff's position on custody is as follows: See attached Order.
,