HomeMy WebLinkAbout96-04302I
r
,
1
r?
I l
4 I
Fe1?
l
, III r1i1 '? '
I
I'
I , I 1 ,-I
1 - 1 ! y1
?1 5
I
1 fl
, 1 1
1
I i I
,1
I , : , ,
f
I
I r ' , i 1, I ?, ! II 1 r 1 11 , ' I, rl}' 1 , 1
' 1' '
, I
11
i 1I I { ' , II I, ! ,
iIV? ' IY r
I
?
?."
' ,. •51 ? , r tl_I 1' I. ,t , r+' '.j r ? 1 ,I r',',
}," ' , ?1 ?' '' ?I?((1
?
, '
_ 1 i 1 ", . 1 I II
,I '
II It'I ?I
•.
1"
'
ll I
I
,
,
? ' 7
1 ''
i
,
,
'
I': I'
r 1 I'"
,
' ', I 1 .1?.
I ? ! I I,1!`r ( ) jr 1 rll ? ?,'
'
r V'
?t11
?
f ?
,. ,
, ,
. 1 yr
,
a ll l• s'P',
;
I I r II , i
, 1 Y aR, f 1 ? ?I
I 1 ?'' I ' I I
II`
I?,}, 11 1If J i I I
I r
t 11? 11 ' I I 1? ;11fI ;
I{r 'el 1"r e_4, ,'i 1i k17.
?
I
I ' Ir'i-: r .•I r-:
rl
_
',"I !.I t 1 1 u, ` 11 ' 1 i t 1 '
-
111 I"'1 .I I : 1 ' -I' fl !{III' I:' IIII 1I I } ' .,il r ,Ir tli ee,
1
1
r
.?I !
1 ,
t i
!I
`IIkkkPPP
I
r
.
'
),,
!
rr ,,, I
, 41IIP II i
' _...'I I ,.rl ,V
I *':'
nj, .(,
rlt
1
-
;1 rl , I' ,'a{` II ,'. I' .(r q 11 'h 'S1Iq
r
'
IF -Ilt - II 1, ! I i. ,.. C :!, ,rl, I
I?L
kl ,I'
ri L
I I
l
I
1 ,
,I i 1 } 1 } r
,, /
I '11 ?:
! ,
t l .I 1 , + .
'
11i i'a I I I !1r ??
` '
Y
I
I
I I
,
i I
,?'I r. •, II ILII I „"'III I} ?u F i ar?l ?
My
? ' Q
I
I
'
'
' (
'• '•' , j1 ( l\?... I 1 Il I" ,. I'1 S 1 I' fI III I ? 1 ji r j'
1
I
lil'
I}'
I
?
'
I
, ,
I. , i
' !
" ? , F t ?- 1
}7
rl I , (r
,
, 1 1I , 1
rl
1
r
r
jY
"" I I
I
1
1 " II
r
I
,
11} II
n
, I
I I
t
'
1 ,
k {{ of
r.'I
1. I ' I f (i ' '. I } ! 1 „
r
11 1 I!I ',
1 f 1 II 1?1 1 I 11 'Ir I P F
1
'
.I ,- I I" r
r ,' S1 I'I ?'Ir
'SI ?II1 .I ? V I, :lir 1
l ' ll, 1 1 I'
,
e.
I
'
?
P ' I
II
/ '' 1 rl ?.
_
r I .
1 i
I 1 '(
t 1 I I
I 11. II i, i. r I, ??.
AY'?
.
4
I
1. l
. r ?
111
..1' ''
fl},1'} I "I I
r 11 ,V
:.
'
II
'
1
i. 1
rl .r
i ?
? " - II
,}
I,
N
l , 1 ,I'
I I i1 II 1 {i - I ' I r llti:.•A
} .rill
?I
1
I
'
'
.
I 1. a L
? ' ( I IIn 1
' '• '' ? , 1
I " 1111 }
' '' Ir
1 1'' I I Y II. 1 ,f4, III ' '. 11"1r
' `
`
' I i, 1 , I
, ,: I ../ IF ' I it "I•
I I ? .
I 11 ,
, 'I I
11 I '
F
,
?
!
I
'
I 1 r I
I I 1,1 i} r
,r rl
, ' r l / r it I
I 1 .tl 1 r I 'I i Irl '1 111 ? ii
t
'
-11
l
'
'
I ??
'
, I
i
I ., 1 1
1 / 1
I:
.
1 1 1 !
r
"
?
'1 1 1
1 1 1 i ,I I, 'ul 7I
I I I I , ', r
il
`+r
?
, i ? 1, ', I 1 I{ .' 41 1111;•' ',I '?
' ,t?'?i?
III ill
i .
{
e
r ,' 1 1 1 r,l I I I
I 1' ? I 1' I-, J 11 1 (? i'?
I
1 I
' r i 1 i I I , q ? , 1
11 f l 1 {
,
'
'
ill ' i
I??
1 .1
I I I
1 II
'
I
.
11 .
„ ' ,•, ','rill it ,, 1 ,,, ' 11' 1' 1 ,. 'c'lr:
5'
'
1
.
'
'
'
'
I , , . 1
,, rl
l I,
-
1 ,,,' i 1 11/i?` •1 ,
'{11
I ?. lip
'
1 I . I I
I I
I I , I 1:, !I I III , , ? l ''I' s
, 1'r
`
I
i
1 1'
1
' 11
' 11,
'I
'
I I f
I I
?
I 1 I
I
1" I I
! 4
1
'
1?
I
1 '
•
I ,
' I 1' r
Y1tt
I '
'
1
I
'
I
1 I
,
1
1
r I ? 1
' i F I r. _ r1
1 (, 77
?
'
'
' lY 1 1 r ,
l., 1 1 11 1'I
I III Ira
''1151??
.'I kl rll ?i l{ ,,
., - 1 1 1 1 .
111
1 l ?I 1 1 :, 1 J Il IYI'If
r I
I
I
•) , I 1 1 M
I
I
, '1 :: ' I
' I '
1
I ,11
' I
, , (? I
,.r
i
, , 1
_i
?
1
1
!
I
1' ' '? ?
,
' 1 '' I 11 r I
I
I
I, 11 I ' 1 , „?
?
'
1
' I '' i ' I i I•_
5:, .+
: I II' I - ',? >I'1 } i
I
r
.,.
, 1 ,
1
. IkI/
I 1 1
,;1 nCl
' 'I 111 I ,. 1
' I t+?
'
1 .1
' 1 I
(
, ,I
,
I 1 I }
1i?
'
1
' 1 r II Ili' '
1 '' '
I
I II 1 11 I I 11 1 III, ? ,
i I i'
11
X11 1 I r 1 I dl 1 ' ? I II'I I 111 ? 5 ' ' ' ,I?
?
r
'{
Ir 'I '1
? l
1 ' ' I' ? 1 ?I I ! f IhJ 1 I i 1 11 II??
1. ,r ' III •I ?
' , I'I ,?1 I , ,I jI I,} L`II 1' I''.'?l lllr l'n.; ,
Y
I
'
I. I I. 1. ' S1.'
I ,'
1 1
• i
i
1 I r ,ell I 'I1 I I - I II , ,
i.
r I , r 111 I f f I 11111 li I 1, J
((??
1 ' 1
!
T•
?
I
I
- ' '?
, 1 I ?
i
? _ 5, 1
1
I
? I
p
1 11- 1 ?,5• ?' ,., I
1 1, ' , =L , 1 'r. ' 1' Irh a-, rt =I' ??
, I I
'l, I }? i 51' ''i I
r: , ?•; 1 , ?:, , ' ?', .!'?
' i lr ,
? 1 i , I r' ?i ll 1
'1
I
'i
il"
I _
1
1
,
.
I
'
`
I jr
? , r
I r'
• '' i, 1 I I `I 1 f„I 1. I I ` I 1 _
I_.I k, li}
I I ,
1' I I, ' I 1 -: I i I I,' i ? r
WALTER K. HOCKLEYj I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
V. I CIVIL ACTION - LAW
I
VALERIE C. SCANDROL, t 1996 - I.V. CIVIL TERM
Defendant t CUSTODY
Itm OF COURT
AND NOWt this day of 1996P the
attached Stipulation and Agreeme t is reby made an order of
Court and all prior orders on this matter are hereby vacated.
BY THE COURT,
I
I I
I
I
'
I
I
,
I
I ,
I,
1 ...I 1 1?
WALTER K. HOCKLEY, t IN THE COURT OF COMMON PLEAS OF
Plaintiff t CUMBERLAND COUNTY, PENNSYLVANIA
t
v, t CIVIL ACTION - LAW
t
VALERIE C, SCANDROL, t 1996-11'k,;) CIVIL TERM
Defendant t IN CUSTODY
CUSTODY
STIPULATION AND AGU
THIS AGREEMENT AND STIPULATION entered into the day and
year hereinafter set forth, by and between Valerie C. Seandrol,
(hereinafter referred to as "Mother") and Walter K. Hookley,
(hereinafter referred to as "Father").
WHEREAS, the parties are the natural parents of Jeannette
Hookley, born January 9, 1999, and Samantha Hookley, born August
27, 1994 (hereinafter the "children)t and
WHEREAS, the parties are presently separated and living in
separate residencest and
WHEREAS, the parties wish to enter into an agreement
relative to custody and partial custody of the childt and
WHEREAS, the children have lived their entire lives in
Cumberland County, Pennsylvaniar and
NOW, THEREFORE, in consideration of the mutual covenants,
promises and agreements as hereinafter set forth, the parties
agree as followst
1. The parties will have shared or joint legal custody of
the children.
2. Mother shall have primary physical custody of the
children.
¦i
3. Father shall have periods of temporary or partial
physical custody of the children on the following echedulet
(a) Beginning with the first Sunday following the
execution of this Agreement by each party, from 9t00 a.m. until
6130 p.m. on each Sunday for a period of three consecutive weeks?
(b) Beginning on the fourth weekend following the
execution of this Agreement by both parties, from 9900 a.m. on
Saturday morning until 6t3o p.m, on Sunday evening on an
alternating weekend basis. The parties acknowledge that Father's
scheduled period of temporary physical custody with the children
on an alternating weekend basis is limited to the Father's work
schedule, Mother will be lenient and reasonable relative to
Father's request for additional time beyond that provided for
hereinl and
(c) At other times as the parties may agree.
4. The parties will alternate physical custody of the
children for the following holidays: New Year's Day, Easter
Sunday, Memorial Day, 4th of July and Labor Day. Father shall
have the children for Labor Day, 1996, and the parties shall then
alternate physical custody of the children each holiday
thereafter. The parent who has physical custody of the children
for the holiday shall have physical custody from 9900 a.m. until
7:30 p.m. on each such holiday.
5. The children shall always be with Mother during Mother's
Day and with Father during Father's Day, with the designated
parent having custody of the children on that day from 9t00 a.m.
until 7900 p.m.
w r
6. The parties agree that during the Thanksgiving holiday
season, they will divide the Thanksgiving holiday season into the
following two periodst
(a) From 5t00 p.m. on the Wednesday before
Thanksgiving until 2100 p.m, on Thanksgiving dayr and
(b) From 2t00 p.m. on Thanksgiving day until 6190 p.m.
on the Friday after Thanksgiving.
Father shall have the first period not forth above for
Thanksgiving 1996 and Mother shall have the second period. This
shall then alternate in 1997 and continue alternating
accordingly.
7. During the Christmas holiday season, the parties agree
that the Christmas seasons shall be divided in the following two
periods:
(a) The period from 5t00 p.m, on December 21 until
1:00 p.m. on December 25; and
(b) The period from 1t00 p.m. on December 25 until
600 p.m. on December 29.
Father shall have the first period set forth above for
Christmas 1996 and Mother shall have the second period. The
parties shall alternate these periods of physical custody for
Christmas 1997 and shall thereafter continue alternating these
periods accordingly.
B. Beginning with the summer of 1997, the parties agree that
they will share physical custody of the children on a week-
on/week-off basis. Although the children are not of school age
at the time of execution of this Agreement, the parties agree to
use the school calendar for the School District in which the
children reside in June of 1997. Using that school calendar,
Father shall have physical custody of the children from 9t00 a,m,
on the first Saturday following the end of the school year until
9100 p.m. on the following Saturday. Mother shall then have
physical custody from 9too p.m, on that Saturday until 9100 p,m.
on the next Saturday. The parties will continue alternating
weeks of physical custody with the children in this manner for
the entire summer of 1997 and all future summers accordingly.
9. The parties will keep each other advised immediately in
the event of serious illness or medical. emergency concerning the
children and shall further take any necessary steps to ensure
that the health and well being of the children is protected.
During such illness or medical emergency, both parties shall have
the right to visit the children as often as he or she desires
consistent with the proper medical care of the children.
10. Neither parent shall do anything which may estrange
the children from the other party, or injure the opinion of the
children as to the other party, or which may hamper the free and
natural development of the children's love or affection for the
other party.
11. Any modification or waiver of any of the provisions of
this Agreement shall be effective only if made in writing and
only if executed with the same formality as this stipulation and
Agreement.
12, The parties desire that this stipulation and Agreement
be made an Order of Court to the Court of Common Pleas of
Cumberland county, and further acknowledge that the Court of
Common Pleas of Cumberland County does, in fact, have
jurisdiction over the issue of custody of the partiesO minor
children and shall retain such jurisdiction should circumstances
change and either party desire or require modification of said
order.
19. The parties agree that in making this Agreement, there
has been no fraud, concealment, overreaching, coercion, or other
unfair dealing on the part of the other.
14. The parties acknowledge that they have read and
understand the provisions of this Agreement. E+ich party
acknowledges that the Agreoment is fair and equitable and that it
is not the result of any duress or undue influence.
IN WITNESS WHEREOF, the parties hereto intending to be
legally bound by the terms hereof, set forth their hands and
seals the day and year herein mentioned.
WITNESS i
k? / I. Q
11 1 IJLa .' . Data t?
11`I
Datet''
r, WALTER K. HOCKLEY. 64-
P i 1
COMMONWEALTH OF PENNSYLVANIA )
)) SS
COUNTY OF CUMBERLAND
On this the day of 1996, before
me, the undersigned officer, personally appeared Valerie C,
Scandrol, known to me (or satisfactorily proven) to be the person
whose name is subscribed to the within Agreement and acknowledged
that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official
seal.
/
?F riu'n1?,enl " "
LnPh A. Mllrl' tJolnry pobllc
Codes 0 Moro, Nnl mrlnod CoonlYy
My Commissar E.puuo Apnl 17, 20oo
COMMONWEALTH OF PENNSYLVANIA )
)) SS
COUNTY OF CUMBERLAND
On this the day of. 1996, before
me, the undersigned officer, personally appeared Walter K.
Hockley, known to me (ox satisfactorily proven) to be the person
whose name is subscribed to the within Agreement and acknowledged
that he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official
Notarial SNaI
Leah A. MIIINL Nolafy Goblet
Carlisle Bolt), Gnnhni6lnq Cooney
seal.
My COmnnssinn F.pinis Apnl V .n00
WALTVIt K. IIOCKLFY I IN TI IF COUICT OF COMMON 101-FAS 0V
I'I.AINTII'p I C'UMHI;I(I.ANI) C'OIJN'I'Y, pRNNSYI,VANIA
V,
1 96.4302 C'IVII. ACTION I.AW
VAI.liltlliC. SCANDROI
I IN C'l1S'fC)I)Y
01-TIMI)ANT
S RIMIll OhCC4;11
AND NOW,.-.--- _____,Wnllncld@y, 44ly_1J 1006 .. _ _ . _, upon consideratlot) of the uttached ComIlluiIll.
it Is hereby directed dial panics and their respective counsel appear lie6we Jsell uWine W Verney, Esq, , the voncillmor.
tit_ _ Mh Floer, Cumberlonrl_Cuumy Cyurfhamse, Cerlfele . on Tuesdev, August 23, 2005. _ a1 I000 AM
for u I're-I Icnring ('uswdy Conference, At such conlcrcnce, an eflonl will be mode to resolve the Issues in dispute; or
Willis cannot be accomplished, b delinc and narrow the issues to he heard by the court, aril to enter boo a temporary
order. All children ape the or older may also he present at the conlercnce. Fallon to appear at Ibe conference nnuv
provide grounds for entry ol'a temporary or permanent order.
The court hereby directs the purlles Io furnish any and rill exlslhllt Proteetlon I'rom Abuse orders,
Specim Relief orders, mid Custodv orders to the conelliotor 48 hours prior tun scheduled hearinW
FOR TI Ili COURT.
Hy: ,. /s/ f waype-l/nc Af, Verney, Eeq, d?
Custody Colicilialor
The court or Common I'k is ol'Cunnbcrlond County is required by Ilia to comply with the Americans
with Disubilites Act o1`1990. For hnfornuufon about accessible I'ocilitics and reosonahle accommodations
avuiluble to disabled Individuals having business before the court, please contact our office. All arrangements
must be mode lit Icast 72 hours prior to any bearing or business before the court. You must attend the scheduled
conference or henring,
YOU SHOULD TAKL TI IIS VAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
I IAVG AN ATTORNEY Olt CANNOT AI-FOKD ONE, OO TO OR ITITTI IONI: 'I'I IF. (OFFICE SE"T
i-,owriI BELOW TO FIND OUTWIIFRI YOU CAN 01::1' FOAI.111.11 .
C'umberlond C'ounly Bar AS6aCIII110o
32 South Iledibid Street
Carlisle, Pennsylvanin 17013
'I'clephone (717)249.3166
s a
(IJl(i i ;'I
?I!11, i a I'I'I 2? a;3
2006
/qt4 le
I
? I f
I
11
I
.
i.F _
I
I
RECEIVED JUL 071004' J
WALTER rR K. 110C.KI.I. 'Y, IN TIIII COURTOI- COMMON I'LEAS OF
I'labttfll' CI1MI11?3CLAND COUNTY, PFNNSYI.VANIA
viii.
CIVIL ACTION I.AW
VALFRIV C. SCANDKOI, , No. 19904302 CIVII. T PRM
Defendant IN CUSTODY
QRDER OF COURT
AND NOW, this day of 2005, It Is Ordered Thal the
Custody Order be modified to reflect: Petitioner is gramcd primary physical custody ol'Jeannelle
and Samantha I lockley with Mother has periods ol'parliai physical custody
J.
Distribution;
Michael J. Whare, Esquire
Valerie C. Scandrol
i
WAITER K. I IOCKIXY,
PlninlIMPelhioner
V.
VALERIE C. SCANDKOL,
Detends"Vitespondent
IN TI II'_ COURT OF COMMON PLEAS 017
CUMBERLAND COUNTY, PMNSYLVANIA
CIVIL. ACTION LAW
No, 1996.4302 CIVIL. TVRM
IN CUSTODY
PETITION TO MODIFY CUSTODY
I, Petitioner Is Walter K. I lockley who resides at 974 Myerstowo Road, Gardners,
Cumberland County, Pennsylvania 17324.
1. Respondent Is Valerie C. Scandrol who resides at 139 Brownstone park LIP,
Hummelstown, Pennsylvania 17036-9281.
3, On August I, 1996, the Honorable Edward Guido entered the Custody Order attached as
Exhibit "A".
4. Since the entry of sold Order, there has been a significant change In circumstances in that;
a. The mother's living conditions are not suitable for the children.
b, The petitioner is best able to undertake and pertomn the primary parental
responsibilities for the child.
c, Petitioner is best able to provide a stable household for the child.
5. The best interest ofthe child will be served by the Court In modlift said Order,
WHEREFORE, Plainlllf pray" this Court to grant the modlflcation of the Custody
Stipulation and Court Order of August I, 1996 as l'ollows, Petitioner Is granted primary physical
custody of Jeannette and Samantha Hockley with Mother has periods of partial physical custody,
Data; ?Y'1 C ? ?Gr R9spectibIly submitted,
ROMINGER, HAYLFY & WHARR
Karl E. Romhtger, Esquire
155 South Ilanover Street
Carlisle, PA 17013
(717)241.6070
Supreme Court ID 1181924
Attorney for I'laintill/Petitioner
WAL'rm K. IiOCKLI?Y,
Plahuill'
vli.
VALERIE C. SCANDROL,
Defendant
IN'I'IILI COURT OF COMMON PLP..AS Oil
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL. ACTION - LAW
No. 1996.4302 CIVILTIMM
IN CUSTODY
CENFIFICATE OF SERVICE
I, Karl R, Romhtger, Fsyuire, suoroey l'or Plahnifl, Walter I lockley, do hereby certify that
I this day serval a copy of the Perl?!nn ro A6xllfy Cuslawly upon the following by First Class Mail
delivery at Carlisle, Pennsylvania, addressed as lullows.
Valerie C. Scandrol
139 Brownstone Park IIF
Iiummelslown, PA 17036.9281
RespectlUlly submitted,
ROMINGER, RAYLEV & WRARE
Dated; 5 L'e C '? w)
Karl F. Rominger, Equire
155 South Ilanover Street
Carlisle, PA 17013
(717)241.6070
Supreme Court I D 0 81924
Attorney for PlairWif/Pelitioner
r I
WALTER K. HOCKLEY, IN THE COURT OF COMMON PLEAS OF
,a Plelnth? CUMBERLAND COUNTY, PENNSYLVANIA
vi.
CIVIL ACTION - LAW
VALERIE Cr SCANDROL, No, 1996.4302 CIVIL TERM
Defendant IN CUSTODY
i
I
II
r
VERIFICATION
CvedO that the statements made in this complaint are true and correct, I understand that
Was statements herein arc made subject to the penalties of IB Pa. Cons. Stat, § 4904 relating to
unswom falsification to authorities.
r.a .
c
Walter K. "o ey
I
PlaintifflPetitio
11 ,
1
II I
r I
I
,
I I I
I
I
I
RI: (rIV1.,1) AIIr ?,) mr)
WALTER K. NUCKI,FV, I IN TIIE; COURT CIF COMMON PLEAS OF
1'Iainllff t CI1M111-.ICLAND COUN'I'V, PENNSVL.VANIA
V, t NO, 1990.43 12 C'IVII TERM
t
VALERIE C, SC.'ANDROL, t CIVIL ACTION • LAW
pefcntlant t
t IN C IISTODV
OADVIR 01, COURT
AND NOW, this _ + day of 2005, upon
consideration ol'the attached custody c'unrillntlu Report. it Is ordered and directed us
folloWSt
I, The prior Order ol'Court dated August I, 1994 shall remain in full Ibree
and effect With file Hallowing nuuifliuuions and additions,
2. The parties shall cooperate wlth counseling for the children which Father
shall arrange and pay fim,
3, Father shall assure that Samantha attend her soccer games during his
periods of*physical custody unless the children arc attending Fenn tiune football games,
d, 'I?his Order is entered pursuant to a Custody Concilialion Conference. The
panics may modify the provisions ol'this Order by mutual consent, In the absence of
mutual consent, the terns of this Order shall conuvl. Another Conciliation Conference Is
scheduled I'or October 7, 211(5 at 2;30 p.m,
k Y TI IF COUR f.
Edward E. Outdo, J.
ec: Karl E. Rogninger, Esquire, Counsel ibr Father p ?'
Jared W.Ifandebnan, Esquire, Counsel for Mother ?-%tu. a?4.0..?¢.?C 5 aP
e
1?f_CkIV11) MG 2:17005 zr
WALTER K. HOCKLEV, t IN THE COURT ON COMMON PLEAS OF
Plwinllff t CUMBERLAND COUN'T'Y, PENNSYLVANIA
V. t 1.996.43112 CIVIL TERM
t
VALERIE C. SCANDROL, t CIVIL ACTION • LAW
Defendant t
t IN CUSTODY
PRIOR.IUDGEt Edward E. Guldu,.L
CUS'1'O1)V CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMDERLAND COUNTV RULE OF CIVIL
PROCEDURE 1915.3.8, the undersigned Custody Conciliator submits tile Iollowing
report,
1. 'file pertinent Infon nation concerning the Child who Is the subject of this
litigation is as follows;
NAME: DATE OF BIRTH CIJRItl:N'l'1.Y IN C'US'TODY OF
Jeannette Hockley January 9, 1993 Mother
Samantha Hockley August 27, 1994 Mother
2. A Conciliation Conference was held In this matter on August 23, 2005,
with the following individuals In attendance; 'T'he Father, Walter K. Hockley, with his
counsel, Karl E. Romhnger, Esquire, and the Mother, Valerie C. Scandrol, with her
counsel, Jared W. liadehnan, Esquire.
3. The Honorable Edward F., Guido entered un Order of Court dated August
I, 1996 providing for shared legal custody, Mother having primary physical custody and
Father having alternating weekends and holidays.
4. The parties agreed to the entry of an Order in the Iorm us attached.
Q .5-
Date Jac cline M. Verney, Esquire
Custody Conciliator
F
F;: (' . M-1) 140 i 0 y , ;Y
WALTER K. HOCKLEV, t IN THE COURT OF COMMON PLEAS OF
Phtintllr I CUMBERLAND COUNTV, PENNSVLVANIA
t
V, t NO. 1996.4302 CIVIL ACTION - LAW
I
VALERIE C, SCANDROL, I
Dsrendsnt t IN CUSTODY
OB)ER OF COURT
AND NOW, this Io", day of march, 2006, the Conciliator. not hearing front
Plaintiff`s counsel following a continuance from October 7, 2005, the Conciliator hereby
relinquishes jurisdiction In this mutter,
rowmE COURT,
acq -lime M, Varney, Gsqu re,?usl y Cgnci uwr
I. ,.a;,Pwl r'.7"" , I
I., 1 r I I
. II; I I I' 11 I I I
I
I
1 i
I 1
I I 1 rrl
I
. I r
I I r I
I
I I
'I
r
(II ?? I ,
t F ? ^ I
f
I' I
?
1
?Jy
? I
1 I . ? I ' I
?
11 I
I '
? i
r I
Ir
,':? I I I
I
I
I
I I 1 r
I . 1 11 I I , 1 11
I
r
I I I
I 1
I
1
I I I
1
I I
r
I I
?C
?'71,?I x}I ,?}J II'III ? .. tr?lfll l,rir! I rJ .! '?a; '11-vi ,'fff
1 ?}) II II I'1 I I rl, i1, -11 'S IFK 31,1A , tYi?
tf
„I 1 ?, I f l' t h 1 r l ' 1l 1'J? r I l? l Ftlj? tai ?IJ?•fl????
I? ? rj t 1''? 1 41 I IF i 1 F? ? I 1 r I 11 I ` i 1 ri ( }? ? f, h? k
C"rx , ,u I r 1 1 .f ( 11 1 1 ,51. }la,r lIl? yy rpl{! ,
+ . a, 8 ° 1 1 I 11 ly - 1 1` '' , 'b ((,t Yi?.r tX??`j?'J
}!kD ' ? 1 ..r ' ,J}Ff tl Ir I!1 5a a?t?E
r ? R ftal..? r lI I 1 I 1 J '. t 11 11 t, ,? ?, Il ? }1 ?':.f .:
t !tf {''' yil I , ! ' 4 1 1 11 r,; r 1. 1141,17771 I?? a, t V'???
r U` ?,t i h r 1' ` 111 r '.;tl ,' ". I 1 1 I rll r 1 1 }l}al?atfl???rl ?lr?.
It 1t t lit ?1 ) r '.I 1 , .?{i Ny7 N? i?
Ila Y 1 if Y ' r r, ?1 'f 1 ? 1 1 I?it1 If,
r Il rl?' CIf??? t? r'
?( $Nr?1??17? II% j tr { 11 1_ , I I 'il 1 ' '' r f+ ? I Irlr: ?}A Ytl j,,?y'F,?
tJ „1,F, t? rli, I r 1 i ?. Ili :`IFit I 1 irI?IJ151i'
All r
ell t 111,
I
4 ?r}I?It, 411 a1 N: 111 tlli' I? 1 1 ,' I 11 I Vf(r 4t+?},'ff ??f
1
II?V'a11411? I ?' I1.d r ? 1 1 .I r I 1? 1} If r ,?rtiglr' f?? ,111 i
y 1t??.` I ,al-1 1 ? I 1" Yl ill ?lr }lE'
?!• Ili a 1 .. r Ir 1 1 , r I JIlrl,d l? i?l,
9r
1'I ' 1 S
1;11
41 t
il• Vtl vJ MII 'fl l '!; r I `l r ,1 -I r
it
5 t 11 I •d .. 1 I I I ?' 1 2
`'1 ,r ? 1 ar I 'I it I 11I. / 1 ?` ? r4 n'
A1J4
111111 1 1.i '1 I , ,
(p'I?-i I r l i"• I I I I Ir l' •II ? +' II 1
If l' ( r .`111 I rI 1,.. 1 - a (1 F rfY?
1 I• I ,71 1 J 1
?,? ,h
I .• , !, Li 1 r _ I 1 1! fllJ'1 11YI lr/
1 1:
' I I I? I J .`d JlaF p
'If r}I' 11 , Y I. 1 1 ,"II ?J" IIi
114 i!1 I ?. `.. 'III 11r frLt
I ? la I ' I ' r tl 1 ?)Ik III ?1??ry?}??
1(,? I I I ' ' ? ii f IFtr}}
1 x.111 ?{ Yt9?•
II • 1 I I rlrt alll
I I I 1 - I I rl , i {1 i1}1 Al?r1 1-I
ril+ i , I 1 ? i ? I I I I II ,?}.,'liil 11th
I? 1 r I , r.r + r 1 rill 11 r ?1F ,ba
I I ? J) r• ' 1 (}'LI
al ill Ir, 1 I Y` 1 till' 1rJ?k /?1?%?.,
v ,' r,
I r'l ' I I II I?1 I I,_ 1 ?' , , ?1) It l'14111,?f
r
1111 X11{. I ?I ?,I r Ilr( , !,n I) Illr a?l
Itr nl'rl II , I 1 ! I I I r 411 y I }r la. ' , 1 ?t.
II 1 a,ll 1 ? I ? I 1 I 1 .1! I / I J' t ?1 tl YI?i 97,1 y.'7? !p;{„
111 ' I I tl ,:, .I' YYY
1 ?1 1 1111 r, F1 J I It ?? Ij?l
f' 11 1 'I,I ? 11 I- 1 •-! Irr ' ! I1 Ir
I I 1 ? 11 , ?e' tr ,c 1 V?:_
A' 1 1, ,, I+ i i I r, r l r I .; }- )? 4?'lyyi , y 1. ? t' { t
F{ ,' r f I a .I Iil, li r f l y }I;,tly '171k t,i {11,(} , _
1 l) 11t
Y 1 I? , I 1 , A PI I 1 .I ?( 1? J
1
I , ,ir ,I 1 ? I I } ' I 1 I 1 )1,Ilat Ili a1lt ljl Jrs
Il I I',1 I I.I 'i 1 I ' 1 - I ' fl Oi• f f VIIY 1}?11 ??'?11+S?1ti`1ry(?t r?
1t, I :rl 1 ' I I I I r, ._' I ?+I l i 1 FI1?P 11? (1P-
1 1 1 rl r 1 I r tl 1?.
y Vj. y.. q • r , N If
,11,1 1 1 ?' 14 I } „1 II y?'. II 1 LI ?il•'Yl?l???
1 11 , t'4tl r r It 11 t ', I tl V'lata
It I ,I, 11 .1(I fi u I I+ 1' 11 i. 1 I ? 1 11 d r. ' / 1111 1 fly rt.F. tl
, I' r 1 f 11 11 rn. I 111''4 Il ?
t I Ip, • t I , 11 Il sa?Y{jlp?r
`? P,7 1 1 ? 1 irr, 1t 11 u
Flf
j ytlli 1ff 4 r , 4}. II , I ? I 1. I I l.:f ;d
rl, r4
, I al
1??',w jf1 SYI? f 1 1 ., 1 r q; 1 Z 1 Il 1 It?,t I>~
r }Prlyd? ?''.f 1 r 1 ' f . ?V I, it 11 a 1 4 wll 141' A' }n. IL
`IPj _?'??Y•xf ?f y a 1ol•a w I• r f r-' , 44r 1 Ir
11fiil 1" 1 'vtrl
yc,
ILS?I'10tLQV1A7:?tNIX??.?IA 1 ?a .? t.l ,1, I' 1 111t 'll ?ti ?b{+it?wid.? r /)
All V;JN(I 5 be-?DT uu. ao,,)s
O ,Re- Mop 5c.nrroc.
?cx?57
-
WALTER K. HOCKLEY, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner CUMBERLAND (AUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
VALERIE C. SCANDROL, No. 19964302 CIVIL TERM
Defendant/Respondent IN CUSTODY
PETITION TO MODIFY CUSTODY
Petitioner is Walter K. Hockley who resides at 974 Myerstown Road, Gardners,
Cumberland County, Pennsylvania 17324.
2.
3.
Respondent is Valerie C. Scandrol who resides at 139 Brownstone Park #F,
Hummelstown, Pennsylvania 17036-9281.
On August 1, 1996, the Honorable Edward Guido entered the Custody Order attached as
Exhibit "A".
4. Since the entry of said Order, there has been a significant change in circumstances in that:
a. The mother's living conditions are not suitable for the children.
b. The Petitioner is best able to undertake and perform the primary parental
responsibilities for the child,
c. Petitioner is best able to provide a stable household for the child.
The best interest of the child will be served by the Court in modifying said Order.
WHEREFORE, Plaintiff prays this Court to grant the modification of the Custody
Stipulation and Court Order of August 1, 1996 as follows: Petitioner is granted primary physical
custody of Jeannette and Samantha Hockley with Mother has periods of partial physical custody.
Date: 5-,,,? t 2(/6F Respectfully submitted,
ROMINC ER, BAYLEY & WHARE
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney :For Plaintiff/Petitioner
WALTER K HOCKLEY, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vii.
CIVIL ACTION - LAW
VALERIE C. SCANDROL, No. 19964302 CIVIL TERM
Defendant IN CUSTODY
CERTIFICATE OF SERVICE
I, Karl E. Rominger, Esquire, attorney for Plaintiff, Walter Hockley, do hereby certify that
I this day served a copy of the Petition to Modify Custody upon the following by First Class Mail
delivery at Carlisle, Pennsylvania, addressed as follows:
Valerie C. Scandrol
139 Brownstone Park #F
Hummelstown, PA 17036-9281
Respectfully submitted,
ROMINGER, BAYLEY & WHARE
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Plaintiff/Petitionq
Dated:
WALTER K. HOCKLEY, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vi.
CIVIL, ACTION - LAW
VALERIE C. SCANDROL, No. 19964302 CIVIL. TERM
Defendant IN CUSTODY
VERIFICATION
I verify that the statements made in this complaint are trine and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to
unsworn falsification to authorities.
0
`?
47,
O
a
Q
3
r-
i'
w
a
cJ'?
C
i?
f
w
N
O
0
n
Cr7
?rn
a
WALTER K. HOCKLEY IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
VALERIE C. SCANDROL
DEFENDANT
96-4302 CIVIL ACTION LAW
IN CUSTODY
ORDER OF CC IrRT
AND NOW, Wednesday, July 13, 2005 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, August 23, 2005 at 10:30 AM
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 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.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT.
By: /s/ Jacqueline M. Vemey, Esq?
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. 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 ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY 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
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
C s :z Wd e 4 -Mr SOOZ
3 1Q : I Ufac :3Hl ?O
RECEIVED AUG 23 2005e
WALTER K. HOCKLEY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 1996-4302 CIVIL TERM
VALERIE C. SCANDROL, : CIVIL ACTION - LAW
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this day of , 2005, upon
consideration of the attached Custody Conciliati Report, it is ordered and directed as
follows:
1. The prior Order of Court dated August 1, 1996 shall remain in full force
and effect with the following modifications and additions.
2. The parties shall cooperate with counseling for the children which Father
shall arrange and pay for.
3. Father shall assure that Samantha attend her soccer games during his
periods of physical custody unless the children are attending Penn State football games.
4. This Order is entered pursuant to 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. Another Conciliation Conference is
scheduled for October 7, 2005 at 2:30 p.m.
COURT
Edward E. Guido, J.
cc: Karl E. Rominger, Esquire, Counsel for Father S 9_ o s
Jared W. Handelman, Esquire, Counsel for Mother 'uyzt' N Q `?°`t
I
u alt fif,r-r,,
lJd 90
?11?S?Ip?
RECEIVED AUG 23 2035 OP
WALTER K. HOCKLEY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : 1996-4302 CIVIL TERM
VALERIE C. SCANDROL, : CIVIL ACTION -LAW
Defendant
IN CUSTODY
PRIOR JUDGE: Edward E. Guido, J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Jeannette Hockley January 9, 1993 Mother
Samantha Hockley August 27, 1994 Mother
2. A Conciliation Conference was held in this matter on August 23, 2005,
with the following individuals in attendance: The Father, Walter K. Hockley, with his
counsel, Karl E. Rominger, Esquire, and the Mother, Valerie C. Scandrol, with her
counsel, Jared W. Handelman, Esquire.
3. The Honorable Edward E. Guido entered anOrder of Court dated August
1, 1996 providing for shared legal custody, Mother having primary physical custody and
Father having alternating weekends and holidays.
4. The parties agreed to the entry of an Order in the form as attached.
Date Jac eline M. Verney, Esquire
Custody Conciliator
WALTER K. HOCKLEY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 1996-4302 CIVIL ACTION - LAW
VALERIE C. SCANDROL,
Defendant : IN CUSTODY
ORDER OF COURT
AND NOW, this 10`h day of March, 2006, the Conciliator, not hearing from
Plaintiff's counsel following a continuance from October 7, 2005, the Conciliator hereby
relinquishes jurisdiction in this matter.
FOR THE COURT,
Jacq line M. Verney, Esquire, Cust y Conciliator
WALTER K. HOCKLEY,
Plaintiff/Petitioner
V.
VALERIE C. SCANDROL,
Defendant/Respondent
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
No. 1996-4302 CIVIL TERM
IN CUSTODY
PETITION TO MODIFY CUSTODY
1. Petitioner is Walter K. Hockley who resides at 974 Myerstown Road, Gardners, Cumberland
County, Pennsylvania 17324.
2. Respondent is Valerie C. Scandrol who resides at 139 Brownstone Park #F, Hummelstown,
Pennsylvania 17036-9281.
3. On August 1, 1996, the Honorable Edward Guido entered the Custody Order attached as
Exhibit "A".
4. Since the entry of said Order, there has been a significant change in circumstances in that:
a. The mother's living conditions are not suitable for the children.
b. The Petitioner is best able to undertake and perform the primary parental responsibilities
for the child.
c. Petitioner is best able to provide a stable household for the child.
d. Mother is subjecting the children to an abusive paramour.
5. The best interest of the child will be served by the Court in modifying said Order.
WHEREFORE, Plaintiff prays this Court to grant the modification of the Custody Stipulation
and Court Order of August 1, 1996 as follows: Petitioner is granted primary physical custody of
Jeannette and Samantha Hockley with Mother has periods of partial physical custody.
Respectfully submitted,
ROMMGER & WHARE
Date: September 12, 2006
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Plaintiff/Petitioner
WALTER K. HOCKLEY, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
VALERIE C. SCANDROL, No. 1996-4302 CIVIL TERM
Defendant/Respondent IN CUSTODY
VERIFICATION
I verify that the statements made in this complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to
unsworn falsification to authorities.
Walter K. Hockle
Plaintiff/Petitioner
WALTER K. HOCKLEY, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
VALERIE C. SCANDROL, No. 1996-4302 CIVIL TERM
Defendant/Respondent IN CUSTODY
CERTIFICATE OF SERVICE
I, Karl E. Rominger, Esquire, attorney for Plaintiff, Walter Hockley, do hereby certify that I
this day served a copy of the Petition to Modify Custody upon the following by First Class Mail
delivery at Carlisle, Pennsylvania, addressed as follows:
Jarad W. Handelman, Esquire
James, Smith, Dietterick & Connelly LLP
P.O. Box 650
Hershey, PA 17033
Date: September 12, 2006
Respectfully submitted,
ROMINGER & WHARE
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Plaintiff/Petitioner
105/2006 11:17 5704595443 !MR LIMITED PAGE 02
WALTER K. HOCKLEY, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
VALERIE C. SCANDROL, 1996-430a CIVIL TERM
Defendant CUSTODY
MI&R OF COURT
AND NOW, this day of 1996, the
attached Stipulation and Agreeme t is eby made an Order of
Court and all prior Orders on this matter are hereby vacated.
BY THE COURT,
;J .
F a
7
rr
Exhibit "A"
a ?
C
t1`
Ll\
o' .c
c?
--cs
N
N
w
L -^CT7
j?
W
WALTER K. HOCKLEY IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
VALERIE C. SCANDROL
DEFENDANT
96-4302 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Wednesday, September 27, 2006 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, October 19, 2006 at 10:30 AM
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 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.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/ ac ueKne M. Verne Es .
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. 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 ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY 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
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
4,2 -/LV
00 :Zl !,4A 6Z J ] S 9 092
31A JO
?? '; , ? ? ICAO
WALTER K. HOCKLEY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 1996-4302 CIVIL ACTION - LAW
VALERIE C. SCANDROL,
Defendant : IN CUSTODY
ORDER OF COURT
AND NOW, this _d day of '0 &b ' , 2006, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. A Hearing is scl?duled in Court Room No. .3 , of the Cumberland
County C urt House, on the day of , 200? , at ?ySr
o'clock, A . M., at which time testimony will e taken. For purposes of this Hearing,
the Father shall be deemed to be the moving party and shall proceed initially with
testimony. Counsel for each party shall file with the Court and opposing counsel a
Memorandum setting forth each party's position on custody, a list of witnesses who will
be expected to testify at the Hearing and a summary of the anticipated testimony of each
witness. These Memoranda shall be filed at least ten days prior to the Hearing date.
2. Pending further Order of Court or agreement of the parties, the prior
Orders of Court dated August 1, 1996 and August 26, 2005 shall remain in full force and
effect with the following modification:
3. Father shall schedule counseling for the children as soon as practicable at
his expense. Mother shall make the children available for counseling. Father shall
schedule appointments so as to minimize the effect on school attendance as much as
possible.
4. The parties may modify this Order by mutual agreement. In the absence
of mutual consent, the terms of this Order shall contr-crt.-.,,
BY -TH RT,
E. Guido, J.
cc: Karl E. Rominger, Esquire, counsel for Father
Jared W. Handelman, Esquire, counsel for Mother' ?- (b
4""
V!N 1 `ln NC1'?d
.LN
9 ? =11 HV Utz 130 9001
A G va L ? HI JCS
WALTER K. HOCKLEY,
Plaintiff
V.
VALERIE C. SCANDROL,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 1996-4302 CIVIL ACTION - LAW
: IN CUSTODY
PRIOR JUDGE: Edward E. Guido, J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Children who are the subject of
this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Jeannette Hockley January 9, 1993 Mother
Samantha Hockley August 27, 1994 Mother
2. A Conciliation Conference was held October 19, 2006 with the following
individuals in attendance: The Father, Walter K. Hockley, with his counsel, Karl E.
Rominger, Esquire, and the Mother, Valerie C. Scandrol, with her counsel, Jared W.
Handelman, Esquire.
3. The Honorable Edward E. Guido previously entered Orders of Court dated
August 1, 1996 and August 26, 2005, providing for shared legal custody, Mother having
primary physical custody and Father having alternating weekends.
4. Father's position on custody is as follows: Father seeks shared legal and
primary physical custody, with Mother having alternating weekends. Father maintains
that Mother's fiancee is inappropriate with the children.
5. Mother's position on custody is as follows: Mother seeks to maintain the
status quo. Mother asserts that the children are doing well in school and are active in
extra-curricular activities. The children have always attended their current school
district schools, all of their friends are from Mother's current home.
6. The Conciliator recommends an Order in the form as attached scheduling
a Hearing, maintaining the current Court Order with a minor modification concerning
counseling. It is expected that the Hearing will require one day.
/D -2a -U(" /& V
Date acq line M. Verney, Esquire 457
Custody Conciliator
WALTER K. HOCKLEY,
Plaintiff
vs.
VALERIE C. SCANDROL,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1996-4302
CIVIL ACTION - LAW
CUSTODY
MOTION FOR CONTINUANCE
AND NOW, comes the Defendant, Valerie C. Scandrol, by her attorney, Jarad W.
Handelman, Esquire and respectfully states as follows:
1. On October 23, 2006, an Order was issued by this Honorable Court scheduling a
custody hearing for January 3, 2007 at 8:45 a.m.
2. Counsel for Defendant is unable to appear at the scheduled hearing due to a
scheduling conflict, as he must appear at a previously scheduled custody trial in the Court of
Common Pleas of Dauphin County at that time.
3. Counsel for Plaintiff, Karl E. Rominger, Esquire, has no objection to this matter
being continued and has requested that the matter be continued until after March, 2007. Counsel
for Defendant has no objection to the matter being continued until after March, 2007.
WHEREFORE, Defendant respectfully requests that the aforesaid hearing be continued
until after March, 2007.
Respectfully submitted,
JAMES, SMITH, DIETTERICK & CONNELLY, LLP
Date: December 6, 2006 By:
JARAD W. H LMAN, ESQUIRE
I.D. No. 82629
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
Attorneys for Defendant, Valerie C. Scandrol
CERTIFICATE OF SERVICE
I, JARAD W. HANDELMAN, ESQUIRE, do hereby certify that I served a true and
correct copy of the foregoing Motion for Continuance upon the following below-named
individual(s) by depositing the same in the U.S. Mail, postage pre-paid at Hershey, Dauphin
County, Pennsylvania this ay of December, 2006.
SERVED UPON:
Karl E. Rominger, Esquire
Rominger & Whare
155 South Hanover Street
Carlisle, PA 17013
By:
JARAD W. HANDELMAN, ESQUIRE
Attorney I.D. #82629
James, Smith, Dietterick & Connelly, LLP
P.O. Box 650
Hershey, PA 17033-0650
(717) 533-3280
r-a
- 'T7 -
i-n
-w-
.
WALTER K. HOCKLEY,
Plaintiff
VS.
VALERIE C. SCANDROL,
Defendant
DEC 12 2006k
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 1996-4302
CIVIL ACTION -LAW
CUSTODY
ORDER
AND NOW, this le day of , 2006, upon presentation and consideration
of the within Motion, it is hereby ORDERED and DECREED that the custody hearing scheduled
for January 3, 2007 at 8:45 a.m. shall be continued until the 2??Iday of , 2007
f
at qS clockA _.M. in Courtroom No. 3, Cumberland County Courthouse, One Courthouse
Square, Carlisle, Pennsylvania.
Y THE COURT:
J.
cc: arl E. Rominger, Esquire, counsel for Father
Jarad W. Handelman, Esquire, counsel for Mother
v-00-M e9 . 03rri0:1n1 )0% CaeXel ,1 Connel ? (t LLP
S
00 -111,EV 'it 330 96OZ
WALTER K. HOCKLEY, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO.: 1996-4302
VALERIE C. SCANDROL, CIVIL ACTION - LAW
Defendant CUSTODY
Honorable Edward Guido
MOTION FOR CONTINUANCE
AND NOW, comes the Plaintiff, Walter K. Hockley, by and through his counsel, Karl E.
Rominger, Esquire, in support of this Motion avers as follows:
1. The above-captioned case is listed for a custody hearing on April 2, 2007, at 8:45 a.m.
in front of the Honorable Edward Guido.
2. Plaintiff is unavailable to attend said hearing as he has to go for surgery.
3. Counsel for the Plaintiff request that this case be continued until after June, 2007.
4. Counsel for the Defendant has been contacted and has no objection to this
continuance request.
WHEREFORE, the Plaintiff respectfully requests that the above-captioned case be
continued until sometime in July of 2007.
Date: March 23, 2007
Respectfully submitted,
Rominger & Associates
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, Pennsylvania 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Plaintiff
WALTER K. HOCKLEY, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO.: 1996-4302
VALERIE C. SCANDROL, CIVIL ACTION - LAW
Defendant CUSTODY
Honorable Edward Guido
CERTIFICATE OF SERVICE
I, Karl E. Rominger, Esquire, attorney for Plaintiff, do hereby certify that I this day served
a copy of the Motion For Continuance upon the following by depositing same in the United
States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows:
Jared W. Handelman, Esquire
P.O. Box 650
Hershey, Pennsylvania 17033
Respectfully submitted,
Rominger & Associates
Date: March 23, 2007
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, Pennsylvania 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Plaintiff
o -a p
i_-. ?_J i1
tT1
_j p
r= ` trJ :7
A
MAR S 6 2007
WALTER K. HOCKLEY, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO.: 19964302
VALERIE C. SCANDROL, CIVIL ACTION - LAW
Defendant CUSTODY
Honorable Edward Guido
ORDER OF COURT
AND NOW, this CJ day of , 2007, upon consideration of the
within Motion For Continuance, it is hereby ORDERED and DECREED that the custody
hearing scheduled for April 2, 2007, at 8:45 a.m. shall be continued until the & day of
TUe-Q- , 2007, at + D o'clock A.M. in Courtroom # / ,Cumberland
County Courthouse, Carlisle, Pennsylvania.
By the Court:
J.
Distribution:
Aar1 E. Rominger, Esquire
155 South Hanover Street
Carlisle, Pennsylvania 17013
.,,Wed W. Handelman, Esquire
P.O. Box 650
Hershey, Pennsylvania 17033
A
J
?s
LO 6Z?%
WALTER K. HOCKLEY, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO.: 1996-4302
VALERIE C. SCANDROL, CIVIL ACTION - LAW
Defendant CUSTODY
Honorable Edward Guido
MOTION FOR CONTINUANCE
AND NOW, comes the Plaintiff, Walter K. Hockley, by and through his counsel, Karl E.
Rominger, Esquire, in support of this Motion avers as follows:
1. The above-captioned case is listed for a custody hearing on June 6, 2007, at 9:30 a.m.
in front of the Honorable Edward Guido.
2. Plaintiff had major surgery on May 11, 2007, at John Hopkins Hospital.
3. Plaintiff was discharged from John Hopkins Hospital on May 29, 2007.
4. Plaintiff is unavailable to attend said hearing as he is recovering from his surgery.
5. Plaintiff can not work nor is he to be walking or engaging in stressful activity.
6. Counsel for the Plaintiff request that this case be continued until after August, 2007.
7. Counsel for the Defendant has been contacted and does not concur with this
continuance request.
WHEREFORE, the Plaintiff respectfully requests that the above-captioned case be
continued until sometime in September of 2007.
Respectfully submitted,
Rominger & Associates
Date: June 4, 2007
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, Pennsylvania 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Plaintiff
WALTER K. HOCKLEY,
Plaintiff
V.
VALERIE C. SCANDROL,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.: 19964302
CIVIL ACTION - LAW
CUSTODY
Honorable Edward Guido
CERTIFICATE OF SERVICE
I, Karl E. Rominger, Esquire, attorney for Plaintiff, do hereby certify that I this day served
a copy of the Motion For Continuance upon the following by depositing same in the United
States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows:
Jared W. Handelman, Esquire
P.O. Box 650
Hershey, Pennsylvania 17033
Respectfully submitted,
Rominger & Associates
Date: June 4, 2007
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, Pennsylvania 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Plaintiff
n rv O
Ci = C
cep ?
JUN 0 3 2007
WALTER K. HOCKLEY, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO.: 1996-4302
VALERIE C. SCANDROL, CIVIL ACTION - LAW
Defendant CUSTODY
Honorable Edward Guido
ORDER OF COURT
AND NOW, this day of 2007, upon consideration of the
within Mono For Continuance, i
h f
a - .
.
By the Court:
J.
Distribution:
1 E. Rominger, Esquire
155 South Hanover Street
-ar
Carlisle, Pennsylvania 17013
ared W. Handelman, Esquire
P.O. Box 650
Hershey, Pennsylvania 17033
vjj vn SSNINI]d
r t r
nn Vno
I s . I wd + - tailr 1002
AUVjpVe,Hidd W. JO
WALTER K. HOCKLEY,
Plaintiff
V.
VALERIE C. SCANDROL,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.: 1996-4302
CIVIL ACTION - LAW
CUSTODY
Honorable Edward Guido
PRAECIPE TO WITHDRAW
Please mark Defendant's request to Modify Custody as withdrawn at this time. aa: s-
current physical condition precludes him from continuing to seek primary custody at this time.
Respectfully submitted,
Rominger & Associates
Date: June 5, 2007
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, Pennsylvania 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Plaintiff
WALTER K. HOCKLEY,
Plaintiff
V.
VALERIE C. SCANDROL,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.: 1996-4302
CIVIL AC71ON - LAW
CUSTODY
Honorable Edward Guido
CERTIFICATE OF SERVICE
I, Karl E. Rominger, Esquire, attorney for Plaintiff, do hereby certify that I this day served
a copy of the Naecipe to Withdraw upon the following by depositing same in the United States
mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows:
Jared W. Handelman, Esquire
P.O. Box 650
Hershey, Pennsylvania 17033
Respectfully submitted,
Rominger & Associates
Date: June 5, 2007
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, Pennsylvania 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Plaintiff
4
CO
1
c-n
WALTER K. HOCKLEY,
Plaintiff/Petitioner
V.
VALERIE C. SCANDROL,
Defendant/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
No. 19964302 CIVIL TERM
IN CUSTODY
PETPI'ION TO MODIFY CUSTODY
1. Petitioner is Walter K. Hockley who resides at 974 Myerstown Road, Gardners, Cumberland
County, Pennsylvania 17324.
2. Respondent is Valerie C. Scandrol who resides at 139 Brownstone Park #F, Hummelstown,
Pennsylvania 17036-9281.
3. On August 1, 1996, the Honorable Edward Guido entered the Custody Order attached as
Exhibit "A".
4. Since the entry of said Order, there has been a significant change in circumstances in that:
a. One of the children has expressed an interest in living with Father.
b. The mother's living conditions are not suitable for the children.
c. The Petitioner is best able to undertake and perform the primary parental responsibilities
for the child.
d. Petitioner is best able to provide a stable household for the child.
e. Mother is subjecting the children to an abusive paramour.
f. Father has successfully recovered from his surgery.
5. The best interest of the child will be served by the Court in modifying said Order.
WHEREFORE, Plaintiff prays this Court to grant the modification of the Custody Stipulation
and Court Order of August 1, 1996 as follows: Petitioner is granted primary physical custody of
Jeannette and Samantha Hockley with Mother having periods of partial physical custody.
CONTEMPT
6. Previous paragraphs incorporated by reference.
7. On the weekend of November 10, 2007, Mother failed to provide the children for their
scheduled visitation.
8. No call or explanation was given.
9. Petitioner as of the date has still not heard from Mother of children.
10. This behavior has occurred before.
11. Mother is thus not in compliance with this Court's Order.
WHEREFORE, Petitioner prays that Respondent be found in contempt and make up the time
that was ordered.
Respectfully submitted,
Rominger & Associates
Date: November 15, 2007
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Plaintiff/Petitioner
WALTER K. HOCKLEY, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
VALERIE C. SCANDROL, No. 19964302 CIVIL TERM
Defendant/Respondent IN CUSTODY
VERIFICATION
I verify that the statements made in this complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to
unsworn falsification to authorities.
Walter K. Hockl
Plaintiff/Petitioner
WALTER K. HOCKLEY, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
VALERIE C. SCANDROL, No. 1996-4302 CIVIL TERM
Defendant/Respondent IN CUSTODY
CERTIFICATE OF SERVICE
I, Karl E. Rominger, Esquire, attorney for Plaintiff, Walter Hockley, do hereby certify that I
this day served a copy of the Petition to Modify Custody upon the following by First Class Mail
delivery at Carlisle, Pennsylvania, addressed as follows:
Jarad W. Handelman, Esquire
James, Smith, Dietterick & Connelly LLP
P.O. Box 650
Hershey, PA 17033
Date: November 15, 2007
Respectfully submitted,
Rominger & Associates
Karl t. Rominger, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Plaintiff/Petitioner
WALTER K. HOCKLEY, -
Plaintiff
V.
VALERIE C. SCANDROL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
1996_303( CIVIL TERM
CUSTODY
MI&M OF COUhis AND NOW, this day of 1996, the
attached Stipulation and Agreeme 4ee-by made an order of
Court and all prior orders on this matter are hereby vacated.
BY THE COURT,
L vir J.
c
7
45xWbif'A„
WALTER K. HOCKLEY, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
VALERIE C. SCANDROL, 1996 - -143Oa CIVIL TERM
Defendant IN CUSTODY
CUSTODY
STIPULATION AND AGREEMENT
THIS AGREEMENT AND STIPULATION entered into the day and
year hereinafter set forth, by and between Valerie C. Scandrol,
(hereinafter referred to as "Mother") and Walter K. Hockley,
(hereinafter referred to as "Father").
WHEREAS, the parties are the natural parents of Jeannette
Hockley, born January 9, 1993, and Samantha Hockley, born August
27, 1994 (hereinafter the "children); and
WHEREAS, the parties are presently separated and living in
separate residences; and
WHEREAS, the parties wish to enter into an agreement
relative to custody and partial custody of the child; and
WHEREAS, the children have lived their entire lives in
Cumberland County, Pennsylvania; and
NOW, THEREFORE, in consideration of the, mutual covenants,
promises and agreements as hereinafter set forth, the parties
agree as follows:
1. The parties will have shared or joint legal custody of
the children.
2. Mother shall have primary physical custody of the
children.
3. Father shall have periods of temporary or partial
physical custody of the children on the following schedule:
(a) Beginning with the first Sunday following the
execution of this Agreement by each party, from 9:00 a.m. until
6:30 p.m. on each Sunday for a period of three consecutive weeks;
(b) Beginning on the fourth weekend following the
execution of this Agreement by both parties, from 9:00 a.m. on
Saturday morning until 6:30 p.m. on Sunday evening on an
alternating weekend basis. The parties acknowledge that Father's
scheduled period of temporary physical custody with the children
on an alternating weekend basis is limited to the Father's work
schedule. Mother will be lenient and reasonable relative to
Father's request for additional time beyond that provided for
herein; and
(c) At other times as the parties may agree.
4. The parties will alternate physical custody of the
children for the following holidays: New Year's Day, Easter
Sunday, Memorial Day, 4th of July and Labor Day. Father shall
have the children for Labor Day, 1996, and the parties shall then
alternate physical custody of the children each holiday
thereafter. The parent who has physical custody of the children
for the holiday shall have physical custody from 9:00 a.m. until
7:30 p.m. on each such holiday.
5. The children shall always be with Mother during Mother's
Day and with Father during Father's Day, with the designated
parent having custody of the children on that day from 9:00 a.m.
until 7:00 p.m.
6. The parties agree that during the Thanksgiving holiday
season, they will divide the Thanksgiving holiday season into the
following two periods:
(a) From 5:00 p.m. on the Wednesday before
Thanksgiving until 2:00 p.m. on Thanksgiving day; and
(b) From 2:00 p.m. on Thanksgiving day until 6:30 p.m.
on the Friday after Thanksgiving.
Father shall have the first period set forth above for
Thanksgiving 1996 and Mother shall have the second period. This
shall then alternate in 1997 and continue alternating
accordingly.
7. During the Christmas holiday season, the parties agree
that the Christmas seasons shall be divided in the following two
periods:
(a) The period from 5:00 p.m. on December 21 until
1:00 p.m. on December 25; and
(b) The period from 1:00 p.m. on December 25 until
6:30 p.m. on December 29.
Father shall have the first period set forth above for
Christmas 1996 and Mother shall have the second period. The
parties shall alternate these periods of physical custody for
Christmas 1997 and shall thereafter continue alternating these
periods accordingly.
8. Beginning with the summer of 1997, the parties agree that
they will share physical custody of the children on a week-
on/week-off basis. Although the children are not of school age
at the time of execution of this Agreement, the parties agree to
use the school calendar for the School District in which the
children reside in June of 1997. Using that school calendar,
Father shall have physical custody of the children from 9:00 a.m.
on the first Saturday following the end of the school year until
9:00 p.m. on the following Saturday. Mother shall then have
physical custody from 9:00 p.m. on that Saturday until 9:00 p.m.
on the next Saturday. The parties will continue alternating
weeks of physical custody with the children in this manner for
the entire summer of 1997 and all future summers accordingly.
9. The parties will keep each other advised immediately in
the event of serious illness or medical emergency concerning the
children and shall further take any necessary steps to ensure
that the. health and well being of the children is protected.
During such illness or medical emergency, both parties shall have
the right to visit the children as often as he or she desires
consistent with the proper medical care of the children.
10. Neither parent shall'do anything which may estrange
the children from the other party, or injure the opinion of the
children as to the other party, or which may hamper the free and
natural development of the children's love or affection for the
other party.
11. Any modification or waiver of any of the provisions of
this Agreement shall be effective only if made in writing and
only if executed with the same formality as this Stipulation and
Agreement.
12. The parties desire that this Stipulation and Agreement
be made an Order of Court to the Court of Common Pleas of
Cumberland County, and further acknowledge that the Court of
Common Pleas of Cumberland County does, in fact, have
jurisdiction over the issue of custody of the parties' minor
children and shall retain such jurisdiction should circumstances
change and either party desire or require modification of said
Order.
13. The parties agree that in making this Agreement, there
has been no fraud, concealment, overreaching, coercion, or other
unfair dealing on the part of the other.
14. The parties acknowledge that they have read and
understand the provisions of this Agreement. Each party
acknowledges that the Agreement is fair and equitable and that it
is not the result of any duress or undue influence.
IN WITNESS WHEREOF, the parties hereto intending to be
legally bound by the terms hereof, set forth their hands and
seals the day and year herein mentioned.
WITNESS:
1 '
Dater r?
, da/Date
WALTER K. HOCKLEY
t
COMMONWEALTH OF PENNSYLVANIA )
SS
COUNTY OF CUMBERLAND )
On this the ,0 ?r day of ?J b Ll 1996, before
me, the undersigned officer, personally appeared Valerie C.
Scandrol, known to me (or satisfactorily proven) to be the person
whose name is subscribed to the within Agreement and acknowledged
that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official
seal.
Leah A. Miller, Notary Public
Carlisle 130ro, Cumberland County
My Commission Expires April 17, 2000
COMMONWEALTH OF PENNSYLVANIA )
SS
COUNTY OF CUMBERLAND(( )
On this the 4day of 1996, before
me, the undersigned officer, personally appeared Walter K.
Hockley, known to me (or satisfactorily proven) to be the person
whose name is subscribed to the within Agreement and acknowledged
that he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official
seal.
i
I yr-'
l '
Notarial Seal
Leah A. Miller, Notary Public
Carlisle Soro, Cumberland County
My Commission Expires April 17, 2000
f7
C.
'T1 t•A
t.,t
cis p
q ?
Zn7- m
MC t')
C)m
N
WALTER K. HOCKLEY
PLAINTIFF
V.
VALERIE C. SCANDROL
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
• 1996-4302 CIVIL ACTION LAW
DEFENDANT IN CUSTODY
ORDER OF COURT
AND NOW, Tuesday, November 20, 2007
upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, December 13, 2007 at 9:30 AM
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 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.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/ ac ueline M. Verne Es .
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. 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 ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY 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
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
$?v -*?- /-V? * j
I Ir
---!z /row
( ,
no
JAN 3 ] 2008 p4/
WALTER K. HOCKLEY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 1996-4302 CIVIL ACTION - LAW
VALERIE C. SCANDROL,
Defendant : IN CUSTODY
ORDER OF COURT
AND NOW, this day of , 2008, upon
consideration of the attached Custody Conciliation ?Report, it is ordered and directed as
follows:
1. A Hearing is scheduled in Court Room No. 3 , of the Cumberland
County Court House, on the day of +M &&"A , 2008, at 9P ,?
o'clock, A. M., at which time testimony will be taken. For purposes of this Hearing,
the Father shall be deemed to be the moving party and shall proceed initially with
testimony. Counsel for each party shall file with the Court and opposing counsel a
Memorandum setting forth each party's position on custody, a list of witnesses who will
be expected to testify at the Hearing and a summary of the anticipated testimony of each
witness. These Memoranda shall be filed at least five days prior to the Hearing date.
2. Pending further Order of Court or agreement of the parties, the prior
Orders of Court dated August 1, 1996 and August 26, 2005 shall remain in full force and
effect.
3. The parties may modify this Order by mutual agreement. In the absence
of mutual consent, the terms of this Order shall control.
BY HE ,
Edward E. Guido, J.
cc?Karl E. Rominger, Esquire, counsel for Father
?Jared W. Handelman, Esquire, counsel for Mother
OOF I lee rn:1, c LCC-L
a2lA11a6
\, IVA {Aq-NN3d
Z :8 WV h- 833 DOOZ
AMONUHiOW U 34
3;}1310
4.
WALTER K. HOCKLEY,
Plaintiff
V.
VALERIE C. SCANDROL,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 1996-4302 CIVIL ACTION - LAW
: IN CUSTODY
PRIOR JUDGE: Edward E. Guido, J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Children who are the subject of
this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Jeannette Hockley January 9, 1993 Mother
Samantha Hockley August 27, 1994 Mother
2. A Conciliation Conference was held January 31, 2008 with the following
individuals in attendance: The Father, Walter K. Hockley, with his counsel, Karl E.
Rominger, Esquire, and the Mother, Valerie C. Scandrol, with her counsel, Jared W.
Handelman, Esquire.
3. The Honorable Edward E. Guido previously entered Orders of Court dated
August 1, 1996 and October 23, 2006 providing for shared legal custody, Mother having
primary physical custody and Father having alternating weekends.
4. Father's position on custody is as follows: Father seeks shared legal and
primary physical custody, with Mother having alternating weekends. Father maintains
that Mother's paramour is inappropriate with the children and that one of the children
expressed an interest to live with Father because of conflict with Mother's paramour.
5. Mother's position on custody is as follows: Mother seeks to maintain the
status quo. Mother asserts that her paramour has moved out of the home. She further
asserts that the children are doing well in school and are active in extra-curricular
activities. The children have always attended their current school district schools, all of
their friends are from Mother's current home.
6. The Conciliator recommends an Order in the form as attached scheduling
a Hearing, maintaining the current Court Order. It is expected that the Hearing will
require one-half day.
!, 3 -oW
Date
Lv`
acq line M. Verney, Esquire
Custody Conciliator
Jarad W. Handelman, Esquire
Attorney I.D. #82629
James, Smith, Dietterick & Connelly, LLP
P.O. Box 650
Hershey, PA 17033
Telephone: 717-533-3280
Fax: 717-533-2795
e-mail: iwh@isdc.com
WALTER K. HOCKLEY,
Plaintiff
VS.
VALERIE C. SCANDROL,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1996-4302
CIVIL ACTION - LAW
CUSTODY
MOTION FOR CONTINUANCE
AND NOW, comes the Defendant, Valerie C. Scandrol, by her attorney, Jarad W.
Handelman, Esquire and respectfully states as follows:
1. On November 15, 2007, Plaintiff filed a Petition to Modify Custody, a result of
which a Custody Conciliation was held before Custody Conciliator Jacqueline M. Verney on
January 31, 2008.
2. On January 31, 2008 a Custody Conciliation Summary Report was filed with the
Court by Custody Conciliator Verney.
3. On February 1, 2008, an Order was issued by this Honorable Court scheduling a
custody hearing for March 7, 2008 at 9:30 a.m.
2. Counsel for Defendant is unable to appear at the scheduled hearing as he will be out
of the state on that date.
3. Counsel for Plaintiff has no objection to this matter being continued.
WHEREFORE, Defendant respectfully requests that the aforesaid custody hearing be
continued as requested above.
Respectfully submitted,
JAMES, SMITH, DIETTERICK & CONNELLY, LLP
Date: February 11, 2008 BY:
JARAD W. HANDELMAN, ESQUIRE
I.D. No. 82629
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
Attorney for Defendant, Valerie C. Scandrol
CERTIFICATE OF SERVICE
I, JARAD W. HANDELMAN, ESQUIRE, do hereby certify that I served a true and
correct copy of the foregoing Motion for Continuance upon the following below-named
individual(s) by depositing the same in the U.S. Mail, postage pre-paid at Hershey, Dauphin
County, Pennsylvania this 12th day of February, 2008.
SERVED UPON:
Karl E. Rominger, Esquire
Rominger & Associates
155 South Hanover Street
Carlisle, PA 17013
By:
Hershey, PA 17033-0650
(717) 533-3280
Attorney I.D. #82629
James, Smith, Dietterick & Connelly, LLP
P.O. Box 650
..?;
*
_ r?4 ?}?
j•
?o !"??
I %
FEB 14 2008 V4
WALTER K. HOCKLEY, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 1996-4302
VALERIE C. SCANDROL, :
Defendant CIVIL ACTION - LAW
CUSTODY
ORDER
r
AND NOW, this day of , 2008, upon presentation and
consideration of the within Motion, it is hereby ORDERED and DECREED that ?the?custody
hearing scheduled for March 7, 2008 at 9:30 a.m. shall be continued until the / `'r day of
2008 at '?11 '
7? oclock A.M. in Courtroom No. 3, Cumberland County
Courthouse, One Courthouse Square, Carlisle, Pennsylvania.
cc: "Karl E. Rominger, Esquire, Counsel for Father, Rominger & Associates, 155 South
Hanover Street, Carlisle, PA 17013; Telephone: 717-241-6070; Fax: 717-241-6878
?Jarad W. Handelman, Esquire, Counsel for Mother, James, Smith, Dietterick & Connelly,
LLP, P.O. Box 650, Hershey, PA 17033; Telephone: 717-533-3280; Fax: 717-533-2795
(26 P tEs MV t
41-,5166
Edward E. Guido, J.
9 S =ZI Wd S 1 83.E 9002
WALTER K. HOCKLEY, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 1996-4302 CIVIL TERM
VALERIE C. SCANDROL, CIVIL ACTION - LAW
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this 14th day of April, 2008, hearing, in
this matter is continued to June 2, 2008, at 1:00 p.m. Pending
said hearing, our prior Order shall remain in full force and
effect. Provided, however, that the children are to have no
contact whatsoever with Fred Lucas unless otherwise ordered by
this Court.
Karl E. Rominger, Esquire
For the Plaintiff
-? arad W. Handelman, Esquire
For the Defendant
srs
O'OPt E9 MIIAL
Edward E. Guido, J.
L S :8 P 91 UV 80,31
WALTER K. HOCKLEY,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
VALERIE C. SCANDROL,
Defendant
NO. 1996-4302
CIVIL ACTION -LAW
CUSTODY
STIPULATION FOR ENTRY OF CUSTODY ORDER
AND NOW, come the parties, Walter K. Hockley (hereinafter "Father"), by and
through his attorney, Karl E. Rominger, Esquire, and Defendant, Valerie C. Scandrol
(hereinafter "Mother"), by and through her attorney, Jarad W. Handelman, Esquire, to
stipulate to the entry of a Custody Order in resolution of the Petition to Modify Custody
filed by Plaintiff on November 15, 2007. The parties hereby stipulate as follows:
1. The parties shall have shared or joint legal custody of their children,
Jeannette Hockley, born January 9, 1993, and Samantha Hockley, born August 27, 1994
(hereinafter collectively the "children").
2. Mother shall have primary custody of the children.
3. Father shall have periods of temporary or partial physical custody of the
children on alternating weekends commencing at 4:30 p.m. on Friday and concluding at
4:00 p.m. on Sunday.
4. The parties shall share holidays with the children as set forth in the
Custody Stipulation and Agreement as adopted by this Honorable Court's Order of
August 1, 1996.
5. The parties shall continue transportation of the children to and from
custody exchanges in accordance with their established practice in effect at the time of
the entry of this Stipulation.
6. On the weekends that Father exercises partial physical custody of the
children, if Samantha has a soccer game or tournament, Father may elect to allow
Samantha to remain in the custody of Mother until after the soccer game or tournament
has concluded. If Father so elects, Father shall commence his custodial period with
Samantha immediately following the conclusion of the soccer game or tournament and
shall coordinate the exchange of custody of Samantha with Mother at a mutually agreed
upon time and location. Should Father elect to allow Samantha to remain in the custody
of Mother until after the soccer game or tournament, Father shall otherwise be entitled to
commence his period of partial custody with Jeanette on Friday at 4:30 p.m. Father may
also elect to commence his partial period of custody with both the children immediately
following the conclusion of the soccer game or tournament.
Should Father elect to take partial physical custody of Samantha on Friday at 4:30
p.m. and Samantha is scheduled to have a soccer game or tournament during Father's
custodial time, Father agrees to ensure that Samantha attends said game or tournament
and to transport the child to the event to permit her timely participation in same.
7. Father shall be entitled to exercise vacation with the children during the
summer. Father shall provide Mother one (1) week advance notice of his intention to
exercise vacation with the children during the summer.
8. All other provisions of the Order of August 1, 1996 not modified by the
terms of this Stipulation shall remain in full force and effect.
9. Father's Petition to Modify Custody and Contempt filed on November 15,
2007 is hereby withdrawn.
Respectfully submitted,
JAMES, SIMTH, DIETTERICK & CONNELLY, LLP
Date: June 2, 2008
9-
JARAD W. H , QUIRE
I.D. No. 82629
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
Attorney for Defendant, Valerie C. Scandrol
ROMINGER & ASSOCIATES
Date: June 2, 2008
KARL E. ROMINGER, ESQUIRE
I.D. No. 81924
155 South Hanover Street
Carlisle, PA 17013
Attorney for Plaintiff, Walter K. Hockley
r-a
AiP
cr%
CrN
WALTER K. HOCKLEY,
Plaintiff
V.
VALERIE C. SCANDROL,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1996-4302 CIVIL TERM
CIVIL ACTION -LAW
IN CUSTODY
ORDER OF COURT
JUN 0 92008
AND NOW, this Ire , da of C*'0A' 2
Y 008, upon consideration of
the within Stipulation for Custody, which is incorporated herein by reference, IT IS HEREBY
ORDERED AND DECREED that the contents of said Stipulation are hereby adopted as an
Order of Court with full weight and effect as if they had been set forth in full hereinafter.
By the Court:
J.
Distribution:
?Karl E. Rominger, Esquire
? Jared W. Handelman, Esquire
lip ?'es MUA L?'
C,/?clo8
VINVA-RSNN3d
,uNno,)
9c :11 WV I I Nn 8041
AdVi OVQHiOdd ?HI O