HomeMy WebLinkAbout96-04577
J.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KEVIN T. LITRENTA,
Plaintiff
v.
NO. 96-4577
CHRISTINE L. KETROW,
Defendant
CIVIL ACTION - LAW
CUSTODY
ORDER
AND NOW, this ~.. day of
/~ /J': I
.
, 1997 , it is
hereby ORDERED and DECREED that the provisions of the stipulation
for Entry of custody Order entered into between the parties which
is attached hereto, are incorporated herein as an Order of this
Court.
BY THE COURT:
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FEE-I9-.1997 16:16
HOWETT,KISSI'GER,MILES,FC
717 23^54e2 P.03
IN THE COURT OF COMMON FLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KEVIN T. LITRENTA,
Plaintiff
)
)
)
) NO, 96-4577
)
) CIVI~ ACTION - LAW
) CUSTODY
v.
CHRISTINE L. KETROW,
Defendan-c
STIPULATION FOR ENTRY OF CUSTODY ORDER
AND NOW, this ~~ day of
~ , 199~ COr.le the
parties in the above-captioned ac~icn and enter into this
stipulation:
WHEREAS, Plai~ciff, Kevin T. Litrenta (hereinafter referred
to as "Father"), ar,d Defendant, cl:ristine L. Retro'" (hereinafter
referred to as "Mother"), are the parents of one :ainor child
namely Nicholas C. KetroW (hereinafter referred to as
"Nicholas"), born June 14, 1989; and
WHEREAS, Nicholas is presently in the primary physical
custody of Mother: and
WHEREAS, on August 15, 1996, Father initiated a Complaint
for Shared Legal and physical Custody docketed to the above-
captioned number in the court of Common Pleas of CUr.lber1and
County, Pennsylvania in which he requested shared legal and
physical custody of Nicholas; and
WHEREAS, the parties have deternined that it is in the best
interests of Nicholas that the pending cuscody issue be resolved
amicably between them, and after negotiations in which both
parties were represented by counsel of their choice, the parties
'.
FE~I~I997 16:17
717 23<:S4e2 p .04
HOWETT.KI5SINGER,MILES,F~
have reached an agreement as to the Fhysica1 and legal custody of
Nicholas.
NOW THEREFORE, with the foregoing recitals being hereinafter
incorporated by reference tlerein and deemed as an essential part
hereof, and intending to be legally bocnd hereby, and for other
good and sufficient ccnsideration, the receipt of which is hereby
acknowledged, the parties mutually agree and stipulate as
follows:
1. Leqal custody. Legal custody as that tern is
defined by 23 Pa.C.S.A. ~5302 shall be shared eGUal1y between the
parties.
2. Ha;oritv phvsica1 custody. Majority physical
custody of Nicholas shall be in ~other.
3. partial Phvsica1 custodY. Father shall have
partial physical custody rights ~ith Nicholas as follows:
a. weekends. Every other weekend from Friday at
6:30 p.m. through sunday at 7:00 p.m.
b. Holidavs. Alternating holidays from 9:00
a.m. through 9:00 p.m. Said holidays shall consist of New Year's
Day, Easter, Memorial Day, July 4th, and Labor DaY.
c. Thanksqivinq. In 1997 and in all odd-
numbered years thereafter, Father shall be entitled to physical
custody of Nicholas from 9:00 a.m. Thanksgiving Day through the
following Sunday at 7:00 p.m. Likewise, in 1998 and in all even-
numbered years thereafter, Mother shall be entitled to physical
2
FEB-I9-1937 1&:17
HOWETT,KISSINGER,MILES,PC
717 23~54e2 P.~5
custody oC Nicholas Crom Thanksgiving Day at 9:00 a.m. through
the following sunday at 7:00 p.m.
d. ~hristmas. In 1996 and all even-numbered
years thereafter, rather shall be entitled to physical custody of
Nichc1as fron 12:00 p.m. Christmas Eve through 12:00 p.m.
Christ~as Day. In 1997 and all odd-numbered years thereafter,
Father shall be entitled to physical custody of NiCholas frem
12:00 p.m. Chris.mas Day through 12:00 p.m. Dec8nbar 26. !n 1996
and all even-numbered years ~her8after, Mother shall be entitled
to physical custody of Nicholas from 12:00 p.m. Christmas Day
through 12:00 p.m. December 26. In 1997 and all odd-nUmbered
years thereafter, Mother shall be entitled to physical custody of
Nicholas from 12:00 p.m. Christmas Eve through 12:00 p.m.
Christmas Day. The remainder of Nicholas' christmas/New Year
break from school shall be equally divided between the parties as
they agree.
e. sorinq Break. Father shall be entitled to
one-half of Nicholas' spring break :rom school as the parties may
agree.
f. Summer vaoation. Father shall be entitled to
three (3) weeks of physical custody of Nicholas during the
traditional sunmer school vacation in 1997 with one week
occurring in June, cne week in July, and one week in August as
the parties may agree. commencing in 1998 and thereafter, Father
shall be entitled to four (4) weeks of physical custody of
Nicholas during the traditional summer school vacation with one
3
FEB-l~I937 tG:18
HOWETT.KI5SI~KJER,MILES.FC
717 23.54eZ P.06
week occurring in June, two weeks in J~ly. and one ~eek in August
as the parties ~ay agree.
4. Sohool Choice. The parties acknowledge that they
have discussed the possibility of Nicholas' attendance at
Lancaster Country Day School commencing in the fall 1997. The
parties agree to continue these discussions so as to reach
agreement in the best interests of Nicholas regarding the school
choice tor 1997 and thereafter. The parties agree that Nicholas'
school shall not be changed without consultation between the
parties and no less than sixty (60) days advance written notice
to Father.
5. Father'S Dav/Mother's Day. Father shall a1~ays
have physical custody of Nicholas on Father's Day from 9:00 a.m.
through 9:00 p.~. Mother shall always have physical custody of
Nicholas on Mother's Day from 9:00 a.m. through 9:00 p.m.
6. Additional Time. Both parties agree that Father
may spend additional time with NiCholas at such other times as
the parties may mutually agree.
7. BDccial circumstances, The parties agree that
should special circumstances arise they shall discuss said
circumstances and if they are in agreement, modify their custody
agreement to accommodate the special circumstances.
8. Entry of court Order. The parties agree that the
terms of this stipulation for Entry of custody Order shall be
entered as an Order of Court at the request of either party and
enforceable by the court as if a full hearing had been conducted.
4
FEB-l~1997 t6:18
ffJl<.ETT. KISS II'G:R. mLES.FC
717 234S4~2 P.~7
IN WITNESS WHEREOF, the parties have signed, sealed and
acknowledged this Stipulation.
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KEVIN T. LITRENTA,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 96-4577
CIVIL TERM
CHRISTINE L. KETROW
Defendant
CHILD CUSTODY/VISITATION
CUSl'ODY COOCILIATIOO SlHIARY REPORT
IN ACCORDANCE WITH CU!BERLAND CXXlNTY RULE OF CIVIL PROCEiJURE
1915.3-a, the undersigned Custody Conciliator submits the following report:
NAME
BIRTHDATE
alRRENTLY IN aJSTOIJY OF
Defendant/Mother
1. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
Nicholas C. Ketrow
June 14, 1989
2. A Conciliation Conference was held on September 10, 1996, with the
fOllowing individuals in attendance: The Father, Kevin T. Litrenta, with
his counsel, Donald E. Kissinger, Esquire, and the Mother, Christine L.
Ketrow, with her counsel, P. Richard Wagner, Esquire.
3.
The parties agreed to
entry of an Order in the form as attached.
;(2n/A_J..d, <,- ae":i/
Dawn S. Sunday, Esquire
Custody Conciliator
Date
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KEVIN T. LITRENTA,
Plaintiff
v.
NO.
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CHRISTINE L, KETROW,
Defendant
CIVIL ACTION - LAW
CUSTODY
ORDER OF COUR'l'
AND NOW, "j 1 , 17.' , .' I II, , 1996, upon consideration of
the attached complaInt, it ~s hereby directed that the parties
and their respective counsel appear before j '" ."11" ,j tr "
Esquire, t~econcil+ator, at -j IJ'!,~ /.,1..:.1 !1l,r/.'I.;,-,/.,I,,\((
Pennsy1van~a, on . 'n' ", I" ,v the I' 'I day of CJr {It. I
1996, at ',"./.( o'clock f!-:..m. 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, Either party may bring the child
who is the subject of this custody action to the conference, but
the child's attendance is not mandatory, Failure to appear at
the conference may provide grounds for entry of a temporary or
permanent order.
FOR THE COURT,
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Custody Conciliator J /1,>,.,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE
YOU CAN GET LEGAL HELP.
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law
to comply with the Americans with Disabilities Act of 1990. For
information about accessible facilities and reasonable
accommodations available to disabled individuals having business
before the court, please contact our 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.
OFFICE OF THE COURT ADMINISTRATOR
Cumberland County Courthouse, Fourth Floor
1 Courthouse Square
carlisle, PA 17013
Telephone: (717) 240-6200
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KEVIN T. LITRENTA,
Plaintiff
v.
NO.
CHRISTINE L. KETROW,
Defendant
CIVIL ACTION - LAW
CUSTODY
COMPLAINT FOR SHARED LEGAL AND PHYSICAL CUSTODY
AND NOW, Plaintiff Kevin T. Litrenta, by and through his
counsel, Howett, Kissinger & Miles, P.C., files a Complaint for
Shared Legal and Physical Custody against Defendant, Christine L.
Name
Present Address Date of Birth
Ketrow, and in support thereof, avers the following:
1. Plaintiff is Kevin T. Litrenta (hereinafter
referred to as "Father"), who currently resides at 110 North Duke
Street, Suite 203, Lancaster, Lancaster County, Pennsylvania,
17602.
2, Defendant is Christine L. Ketrow (hereinafter
referred to as "Mother"), who currently resides at 107 West
Portland Street, Mechanicsburg, Cumberland County, Pennsylvania,
17055.
3, Plaintiff seeks partial custody of the following
child:
Nicholas C. Ketrow
107 \vest Portland Street June 14, 1989
Mechanicsburg, PA 17055
The child was born out of wedlock.
The child is presently in the custody of Mother who
currently resides at 107 west Portland Streett Mechanicsburg,
Cumberland County, pennsy1vania, 17055.
During the past five years/ the child resided with the
following persons and at the following addresses:
Persons
Addresses
Dates
Christine L. Ketrow
107 West Portland street
Mechanicsburg, PA 17055
2 years
Christine L. Ketrow
and paramour
Unknown
3 years
The mother of the child is Christine L, Ketrow, who
currently resides at 107 West Portland Streett Mechanicsburg,
Cumberland County, pennsylvania, 17055.
She is single.
The father of the child is Kevin T. Litrenta, who
currently resides at 110 North Duke Streett suite 203, Lancaster,
Lancaster County, Pennsy1vania, 17602.
He is single.
4, The relationship of Plaintiff to the child is that
of natural father. Plaintiff currently resides with the
following person:
Name
Relationship
Suzanne Mayad
Fiancee
5. The relationship of Defendant to the child is that
of natural mother, Defendant currently resides alone.
6, Plaintiff has not participated as a party or
witness, or in another capacity, in other litigation concerning
the custody of the child in this or another court.
Plaintiff has no information of a custody proceeding
concerning the child pending in a court of this Commonwealth.
Plaintiff does not know of a person not a party to the
proceedings who has physical custody of the child or claims to
have custody or visitation rights with respect to the child.
7. The best interests and permanent welfare of the
child will be served by granting the relief requested because
Mother has denied Father partial physical custody of the child
without cause and Father desires re-initiation of extended
regular contact with the child.
8. Each parent whose parental rights to the child has
not been terminated and the persons who have physical custody of
the child have been named as parties to this action.
WHEREFORE, Plaintiff Kevin T. Litrenta, respectfully
requests that this Honorable Court enter an Order granting him
shared legal and physical custody of the child.
Respectfully submitted,
Date:
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HOWETT, KISSINGER & MILES, p.e.
130 Walnut Street
P.O. Box 810
Harrisburg, PA 17108
Telephone: 717/234-2616
Counsel for Plaintiff
Kevin T. Litrenta
VERIFICATION
I, Kevin T. Litrenta, hereby sweur und affirm that the facts
contained in the foregoing Complaint for Shared Legal & Physical Custa'fl&
true and correct to the best of my knowledge, information and
belief and are made subject to the penalties of 18 Pd.C.S. 94904
Date:
August 15,
fa1sificatiG(~ dr\flyes,' . .
1996 ~ I~
Kevin T. Litrentu
relating to unsworn
child any threat to "takc custody of the child away from thc mothcr", and it is instructivc that
Defendant/Respondent includcs such an allcgation in hcr Counter-Claim whcn
Petitioner/Plaintiff has to datc notl1led a petition secking primary physical custody ofthc child.
It is denied that "father has been a feature of the child's life only for the last two years. . .",
although it is acknowledged that Plaintiff/Petitioner had little contact with the child over an
extended period at the bcginning of the child's life.
23, Denied as stated. It is admittcd that Plaintiff/Petitioner advised Lancaster County
Case Worker, Anne Daniels that the child has wet the bed and defecated on the floor in his home.
Moreover, Defendant/Respondent, Christine Ketrow had previously admitted to
Plaintiff7Petitioner that the child had wet the bed in her home as well.
24. Denied, It is emphatically denied that the child is being emotionally damaged by
continuing visitation with PlaintifflPetitioner. It is acknowledged and has been repeatedly
asserted by Plaintiff7Petitioner that the child is in need of counseling and evaluation, and
Plaintiffi'Petitioner intends to fully cooperate in such counseling and/or evaluation. It is
specifically denied that any basis exists for this court to ordcr PlaintifflPetitioner to refrain from
exercising periods of partial custody at this time.
2
WHEREFORE, PlaintiWPetitioncr rcquests that this Honorablc Court dismiss thc
Counter-Claim with prejudice and direct that partial custody rcsume pursuant to this court's
order of April 3, 1997 as modified by thc order of August 27, 1998.
Date:
/o;Y!t
Respectfully submi tted,
Donald T. Kissinger, Esquir
HOWETT, KISSINGER & LEY, P.c.
130 Walnut Street
P.O. Box 8iO
Harrisburg, P A 17108
Telephone: (717) 234-2616
Counsel for Plaintiffi'Petitioner Kevin T. Litrcnta
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Bayley, J.
/
,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KEVIN T. L1TRENTA,
Pcti tioncrfP lain ti ff
v.
)
)
)
)
)
)
)
NO. 96 - 4577
CHRISTINE L. KETROW,
Respondent/Dcfcndant
CIVIL ACTION - LA W
CUSTODY
ORDER
AND NOW, this 1 A~ day of oJvt
, 1999, the Pctition for
Appointment of Psychological Evaluator shall be consolidated for hearing with thc matters
previously scheduled to be heard on October 1], 1999 commencing at 1 :30 p.m. in the above-
captioned matter.
'--
(
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KEVIN T, LITRENTA,
Petitioncr/Plaintiff
)
)
)
)
)
)
)
CIVIL ACTION - LA W
CUSTODY
v.
NO. 96 - 4577
CHRISTINE L. KETROW,
Respondent/Dcfendant
PETITION FOR APPOINTMENT OF PSYCHOLOGICAL EVALUATOR
AND NOW comcs Kevin T. Litrcnta, by and through his cc."lsel, Howett, Kissinger &
Conley, P.C, who respcctfully sets forth thc following:
1. Petitioner is Plaintiff in the above-captioncd action in custody, whcrcin
Respondent is Defendant.
2, On August 26, 1999, Petitioner l1Ied a Pctition for Contempt and Special
Relief Pursuant to Pa. R.C.P. 1915.13. This court schcdulcd hearing with regard to said Petition
to be conducted October 11, 1999 commcncing at 1 :30 p.m.
3. On August 27, 1999, Petitioner rcceivcd a phonc call from Senior
Caseworker Anne Daniel at Lancastcr County Childrcn and Youth Serviccs at which time Daniel
indicated that a referral of suspected abuse of minor child, subjcct to the custody proceeding,
Nicholas C. Ketrow, born June 14, 1989 (hereinal1er rcfcrrcd to as "Child"), had just been made
to that office. Daniel advised Petitioner that hc should not pickup the child for his regularly
scheduled alternating wcekend partial custody on Friday, August 27,
4. Pctitioncr rcqucstcd from Danicl a dcscription ofallcgcd acts rcsulting in
thc refcrral, but Danicl rcfuscd to go into dctail, stating that such information would hc rcvcalcd
to Petitioncr at intcrvicw with hcr. Pctitioncr rcqucstcd the carli cst availablc intcrvicw timc, and
Daniel conductcd intcrvicw of Pctitioncr on thc morning of August 31, 1999. During said
interview, Daniel acknowledgcd to Petitioncr that the child had alrcady rccantcd allegations sct
forth in the original rcfcrral.
5. Atthc time of said intcrview, Danicl recommcndcd that Petitioncr agrcc to
participate in counseling with the child, and she further statcd that she bclieved a comprehensivc
evaluation of the matter by a qualified mcntal health profcssional was appropriate. Pctitioncr
expressed willingness to participate in both counscling and the p.valuation, and Petitioner made
Daniel aware of the fact that hc had l1Icd thc Petition for Contcmpt and Special RclicfPursuant
to Pa, C.R.P. 1915.13 rcqucsting, inter alia, cvaluation and counseling for the child the day prior
to Daniel's original contact to him.
6. In said August 31 interview, the undcrsigned counsel advised Danicl that
Arnold Shicnvold, Ph.D., BCFE had becn appointed by this court to invcstigatc similar
allegations ofabusc arising in Scptcmbcr 1997. Atthaltimc, Respondcnt had I1lcd a Petition for
Protection from Abusc docketed to No. 97-4855 in the Cumbcrland County Court. Said
Protection from Abusc Pctition was subscqucntly withdrawn and tcrminatcd after complction of
Shienvo1d's invcstigation and various scssions with both partics and thc child.
7. Danicl statcd that Rcspondcnt had cmphatically cxprcsscd unwillingness
to have an cva1uation conductcd by Shicnvold in conjunction with thc currcnt rcfcrral. She
originally providcd the undcrsigncd counscl with a namc of a Lancastcr COllnty mcnta1 health
2
professional who had assisted that agency with the cvaluation on a regular basis in thc past.
Pctitioncr through counsel conveycd to Daniel his willingncss to have that individual pcrfornl an
evaluation.
8. By lettcr dalcd Scptcmbcr 2, 1999, Danicl advised thc undersigned
counsel that Respondcnt had agrecd to "have thc child cvaluatcd" and to havc the Child attend
ongoing counseling scssions ifsuch action would bc thc rccommcndation of Daniel's
assessmcnt. In said letter, Daniel stated for the I1rst timc that shc would prefer having the Child
evaluatcd in the Cumbcr1and County arca. Daniel stated that Rcspondent had arrangcd for the
Child to bc seen by a "Dr. Michael Kazor" because Dr. Kazor was a participating medical
providcr with her emp10ymcnt plan.
9. Al1cr immediate subscqucnt invcstigation, Petitioner was able to ascertain
Ihat Kazor was not a psychiatrist or Ph,D. in psychology and did not utilizc the "Doctor"
dcsignation. Subsequent investigation has revealcd that Kazor works full-time in or through the
Camp Hill Prison and has a part-time counscling practice.
10. Petitioner has spoken with Kazor who describes his professional
designation as a 1icenscd social workcr. Dr. Kazor statcd that hc had becn engaged for thc
purpose of counseling for attention deficit and bchavioral problems of the Child in school, but
Kazor added that hc was unsure whether hc would continuc to scc thc Child.
II. Danicl has now c1carly statcd to Pctitioncr and Respondent's counsel that
the instant CYS referral will not rcsult in an indicatcd I1nding. Danicl stated that hcr report will
be completed within the rclativcly ncar futurc.
3
12, Carol 1. Lindsay Esquirc, cOllnscl for Respondcnt, has ask cd Pctitioncr
through counscl to rcfrain from cxcrcising any partial custody rights until such timc as he and thc
child havc cngagcd in some form of counscling and thc counsclor rccommcnds re-initiation of
contact. Lindsay has rcquestcd that Pctitioncr agrce that Stanlcy Schncidcr, Ph.D. bc a mutually
sclected counsc10r in the case, and Pctitioncr assumcs that Kazor would no longer bc involvcd in
thc matter.
13. Lindsay has clearly stated to thc undersigncd counsel thai Respondcnt
does not intend to have Ihe child and/or parties evaluatcd as per thc original recommcndation of
Daniel.
14. Petitioner bclieves and thcrefore avers that the bcst intcrest of the minor
child would be most fully scrved by conduct ofa comprehensivc psychological cvaluation of the
child, both parties, Respondent's parents, Rcspondcnt's boyfricnd and Petitoncr's wife Suzanne
Litrenta. Dr. Shienvold is familiar with the child and thc child was comfortablc with Shicnvold
during his invo1vemcnt in 1atc 1997 through mid 1998.
15. Shienvold is a promincnt local psychological professional who has
testified frequently before thc Cumbcr1and County Court and who has vast cxpcricncc and
expertise in both psychological cvaluations for custody cascs and thosc surrounding allegations
of abuse.
16. Pctitioncr bclievcs and thcrcfore avcrs that hc should bc pernlittcd to
resume his partial custody with thc child al thc carlicst possible opportunity, and that it is
essential that an evaluator bc immedialely appointcd to makc rccommcndations to thc partics and
thc Court with rcgard to rcsumption of partial custody.
4
VERI FI CATION
I, Kevin T. Litrenta, hereby swear and affirm that the facts
Petition for Appointment of
contained in the foregoing Psychological Evaluator are
true and correct to the best of my knowledge, information and
belief and are made subject to the penalties of 18 Pa.C.S. ~4904
relating to unsworn falsification to authorities.
'o~:t~
Date:
9/29/99
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HOWETI', KISSINGER & MILES, RC.
,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KEVIN T. L1TRENT A,
Pctitioncr/Plainti ff
)
v.
,
I
)
)
)
)
)
CIVIL ACTION - LAW
CUSTODY
NO. 96-4577
CHRISTINE L. KETROW,
Respondent/Dcfendant
ORDER
AND NOW, this
day of
, 1999, upon consideration of
Petitioner/Plaintiffs Petition for Contempt and Special RcliefPursuant to Pa.R.C.P. 19515.13, it
is hereby ORDERED and DECREED that
Respondent shall immediately cause thc Child to be enrolled in the St. Joseph's School
for the commencemcnt of the 1999-2000 school year pending hearing on the merits of the
Petition and/or further Order of Court. Hearing on this matter shall be conducted on the _
day of
, 1999, commencing at _
m in court room
of the
Cumberland County Courthouse.
BY THE COURT:
J.
IIIIlI hchavioral prohlcl11s of the Child. Rcspondcnt's counsel was notified of the Petitioner's
position pursuant to Icttcr dated August 12, 1999, a copy of which is attached hereto as Exhibit
"A" allll ineorporalcd hcrcin by rcfcrcnce.
5. In a phone conversation on August 12, 1999, Respondent's counsel
advised Pctitioncr's counscl that she would not be capable of speaking with her client regarding
thc issuc 10" a pcriod of in cxccss of one wcek and that she therefore could not convey to the
undcrsigncd counscl Rcspondcnt's position with regard to the matter at that time.
6. Pctitioncr promptly contacted St. Theresa's School and was advised by
that school that thc Child had not been enrolled for the 1999-2000 school ycar.
7. Pctitioncr contacted St. Joseph's School and was advised that they were
unawarc of any changcs in the status of the Child and that they carried him on their records as
cnrollcd for said school year.
8. On August 20, 1999, Petitioner discussed the status of the Child with
Rcspondcnt and Rcspondcnt stated that she intended to make the change but it had not yet
occurrcd. Pctitioncr contactcd St. Joseph's School and St. Theresa's School on August 25, 1999,
at which timc hc Icarncd that thc Child had bccn withdrawn from St. Joseph's and enrolled in St.
Thcrcsa's for thc 1999-2000 school year which commences Monday, August 30, 1999.
9. On thc evening of August 25, 1999, Petitioner contacted Respondent by
phonc and inquircd as to thc status of the Child's enrollment. Rcspondent misreprcscnted the
timing of thc cnrollmcnt and the Petitioncr pointed out to the Respondcnt that he had spoken
with thc rcspcctivc schools about the matter. Respondent curtly stated "I'm gonna do what 1
want to do," and dirccted Petitioner to never phone her at her rcsidence in the future.
10. Petitioner learned today that Respondent had takcn initial steps to enroll
the Child in the new school before she had ever raiscd the subject with Petitioncr. Respondent's
actions since early August have been clearly calculated to mislead Pctitioncr to thc dctriment of
the Child.
] 1. During sessions conducted pursuant to court ordcr by Arnold Shicnvold,
Ph.D. in 1998, Shienvold specifically recommcnded that thc Child undcrgo ongoing and
continuous counseling. Respondent originally agreed to commcncc counseling for thc Child, but
she later failed to follow through and take the Child for any scssions, and her counscllater
suggested in writing that contact with the Child's school counsclor at St. Joseph's, Joyce
Pavolich, would be satisfactory to satisfy any necds for ongoing counseling. Petitioncr contacted
Pavolich and learned that she was only seeing thc Child rclated to disciplinary problems in
school, and Pavolich candidly acknowledgc that the Child should appropriately receive outside
counseling.
11. Records for the Child from the 1997-1998 school year at St. Joseph's
School reflected that he was late for school no less than 35 times. Petitioner understands that the
Child has a significant number oftardics or absenccs during the 1998-1999 school year.
Pavolich advised Petitioner of a special conference being conducted with thc school and attendcd
by Respondent to discuss disciplinary and educational matters, and Respondent failed to contact
Petitioncr to advise him of the conference.
12. Information gleancd by Pctitioner from Dr. Shienvold and Pavolich causcs
serious concern that the Child suffers from attcntion deficit disordcr and/or Icarning disabilities
which may require immediate evaluation and ongoing trcatmcnt. Rcspondent indicatcd to
Pctitioncr toward the cnd of the 1998-1999 school year that she blames the Child's teacher and
othcr school pcrsonncl at St. Joseph's for the current difficulties in the Child's school
pcrformancc and behavior, and Rcspondent had previously utilized similar rationale in removing
thc Child from a prior school to St. Joseph's.
13. Petitioner believes and therefore advers that any attempt to change the
Child's school at this time only scrves to cause further disruption at a critical time in the Child's
dcvelopment. Notwithstanding the past behavioral difficultics at the St. Joseph's School,
Petitioner believes and thercfore advers that said institution was making all attempts to provide
proper boundaries and resources to permit the Child to succeed.
14. Respondent's unilateral actions in removing the Child from the St.
Joseph's school over Petitioner's objection constitute contempt of the shared legal custody
provision of the April 3, 1997 custody order. Her actions have been taken without any
conveyance of any legitimate reason for another school change, and it is averred that Respondent
is again attempting to run away from rather than addrcss the Child's educational and behavioral
problcms. It is respectfully submitted that absent appropriate intervention said difficulties will
rccur at any educational institution.
WHEREFORE, Petitioner rcspectfully rcquests that this Honorable Court enter an
immediate order directing Respondent to rc-enroll the child in the St. Joseph's School pending
hearing on the merits of this Pctition for Contcmpt and for Special Relief and further order of
court. Petitioner furthcr rcqucsts that, after hcaring, this Court direct Respondent to immediately
present the Child for evaluation for attention deficit relatcd disorders and for learning disabilities
so as to permit a prompt detcnnination as to whether treatmcnt is appropriate; that this Court
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HOWETT, KISSINGER & CONLEY, P.C.
130 WALNUT STREET
POST OFFICE BOX 810
HARRISIlURO, PENmYlVi.N1A 17108
,
.
KEVIN T. L1TRENT A,
Plaintiff
)
)
)
)
)
)
)
IN TI-IE COURT or COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LA W
9 b'- "I-{,'77
Co~( hllJ
CHRISTINE L. KETROW,
Defendant
IN CUSTODY
RESPONSE TO COUNTER-CLAIM
AND NOW comes, Kevin T. Litrenta by an through his counscl HOWETT, KISSINGER
& CONLEY, P.c. who responds to thc Countcr-Claim as follows:
17. Admitted.
18. Admitted.
19. Admitted.
20. Dcnied. It is specifically denicd that Plaintiff/Petitioncr has violatcd the tcnns of
the August 27, 1998 Order in any fashion. Moreover, it is dcnied that Plaintiff/Pelitioner has at
any time pulled the child's hair or hit thc child in the stomach or thc legs, and specific proof
thereof is demanded.
21. Denied. It is specifically dcnied that Plaintiff/Petitioncr has engagcd in any
course of conduct which has damaged thc child emotionally. It is further dcnicd that
Plaintiff/Petitioner has refcrrcd to thc child as "Gay Boy", "Sissy Boy", "Fat Boy". It is avcrrcd
that thc nicknamc "Bucky" was affectionatcly uscd on limitcd occasions with no apparent
advcrse reaction from thc chi Id.
22. It is specifically dcnicd that Plaintiff/Petitioncr has at any time convcycd to thc
child any threat to "take custody of the child away from thc mothcr", and it is instructivc that
Defendant/Respondent includcs such an allcgation in hcr Countcr-Claim whcn
Petitioner/Plaintiff has to date not filed a pctition sccking primary physical custody ofthc child.
It is denied that "father has been a fcature of the child's lifc only for thc last two ycars.. .",
although it is acknowledged that Plaintiff/Petitioner had little contact with the child ovcr an
cxtendcd period at thc beginning ofthc child's lifc.
23. Denied as statcd. It is admitted that Plaintiff/Petitioner adviscd Lancaster County
Case Worker, Anne Daniels that the child has wet the bed and dcfecated on the floor in his home.
Moreover, Defendant/Respondent, Christine Ketrow had previously admitted to
Plaintiff/Petitioner that the child had wet the bed in her home as well.
24. Denied. It is emphatically denied that the child is being emotionally damaged by
continuing visitation with Plaintiff/Petitioner. It is acknowledged and has been repeatedly
asserted by Plaintiff/Petitioner that the child is in need of counseling and evaluation, and
Plaintiff/Petitioner intends to fully cooperatc in such counseling and/or evaluation. It is
specifically deni~d that any basis exists for this court to ordcr Plaintiff/Petitioncr to refrain from
exercising periods of partial custody at this time.
2
WHEREFORE, Plaintiff/Pctitioncr rcqucsts that this Honorablc Court dismiss the
Countcr-Claim with prcjudicc and dircct that partial custody resume pursuant to this court's
ordcr of April 3, 1997 as modificd by thc order of August 27, 1998.
Date:
/o~/t
Respcctfully submittcd,
Donald T. Kissinger, Esquir
HOWETT, KISSINGER & LEY, P.c.
130 Walnut Strcct
P.O. Box 810
Harrisburg, P A 17108
Tclephonc: (717)234-2616
Counscl for Plaintiff/Pctitioncr Kcvin T. Litrcnta
3
(
KEVIN T. L1TRENTA,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
CHRISTINE L. KETROW,
DEFENDANT
: 96-4577 CIVIL TERM
ORDER OF COURT
AND NOW, thjs~daYOfOctober, following a hearing, ITIS
ORDERED:
(1) The rights of the father Kevin T. Litrenta to periods of partial physical
custody with his son Nicholas C. Ketrow, born June 14, 1989, pursuant to the order of
March 6,1997, shall recommence with the weekend of Friday, October 22,1999, at
6:30 p.m. until Sunday, October 24, 1999, at 7:00 p.m.
(2) The parties shall forthwith make arrangements for Nicholas to undertake
therapy with Stanley E. Schneider, Ph.D., and they shall cooperate with Dr. Schneider
in all aspects of that therapy as he recommends. The cost shall be borne seventy
percent by father and thirty percent by mother.
(3) The petition of the father for the appointment of a psychological evaluator,
IS DENIED.
(4) The petition of the father to hold the mother in contempt, IS DISMISSED.
By the Court, /
~ '
" . L{A 0'/
Edgar B. Bayley, J.
\
by this Honorable Court on August 27, 199B based upon the Stipulation of the Parties. A copy of that
Court Order and the Stipulation is attached hereto as Exhibit "A". By the terms of the Court Order,
Petitioner Kevin T. Litrenta is ordered and directed to refrain from physically disciplining Nicholas C.
Ketrow.
7. After reasonable investigation Respondent is without information sufficient to form a belief
as to the averments of the statements in paragraph 7. By way of further answer, Respondent and
Ms. Daniel never discussed an evaluation at all, nor was Dr. Shienvold's role ever discussed. Further
Respondent's unwillingness to agree to an evaluation of her son by Dr. Shienvold is based on her
belief that the child has been counseled by Dr. Shienvold, and evaluated not only by Dr. Pauline
Wallin in 1996 but also by the Intermediate Unit in 1999 and is currentiy being treated with Ritalin for
Attention Deficit Disorder. A copy of the evaluation is attached hereto as Exhibit "B".
8. After reasonable investigation Respondent is without information sufficient to form a belief
as to the averments of the statements in paragraph 8.
9. Admitted that Michael Kazor has an MSW. By way of further answer, although Mr. Kazor
works in the Camp Hill prison he also maintains a counseling practice through New Vision in New
Cumberland, Pennsylvania.
10. Admitted that Mr. Kazer is counseling the child. By way of further answer, Respondent
does not know what Dr. Kazor told counsel for the Petitioner. However, Dr. Kazor is treating the
child, presentiy in part for the child's difficulties with his father as more specifically set out in the
Counter-claim below.
11. After reasonable investigation Respondent is without information sufficient to forma a belief
as tot he averments of the statements in paragraph 11.
12. Admitted.
13. Denied as stated. By way of further answer, counsel for Respondent has indicated
Respondent's willingness to have the child engage in counseling with Dr. Stanley Schneider. By way
of further answer, Dr. Schneider has agreed to act as the counselor for the child and to engage both
parents in the counseling process as needed. By way of further answer, so far as the undersigned
knows, Ms. Daniel is recommending significant counseling for the child and his father, not an
evaluation.
14. After reasonable investigation Respondent is without information sufficient to form a belief
as to the averments of the statements in paragraph 14. By way of further answer, the child has
expressed to the Respondent his mistrust of Dr. Shienvold in Iiaht of the continued physical discipline
of the child and/or abuse of the child as set out in Counter-claim. Respondent believes and therefore
avers that Petitioner is seeking a custody evaluation although he has not filed a complaint for
custody. Respondent believes and therefore asserts that a custody evaluation is not necessary and
that if it were necessary she would be so advised by the child's therapist. Further Dr. Shienvold could
not perform an evaluation as he has previously functioned as a therapist for the child and his father.
15. Admitted.
16. After reasonable investigation Respondent is without information sufficient to form a belief
as to the averments of the statements in paragraph 16. By way of further answer, Respondent is
willing to provide the child to Dr. Schneider for counseling and to egree to attend sessions with Dr.
Schneider as required and to provide the child for a cornplete evaluation if that should be Dr.
Schneider's determination.
WHEREFORE, Respondent prays this Honorable Court to dismiss the Petition and order the
child and the parties hereto to engage in counseling with the frequency and duration as determined
by Dr. Stanley Schneider.
'" ........
'-
COUNTER-CLAIM
17. The captioned case is controlled by this Court's Order of April 3, 1997, as modified by the
Court's Order of August 27, 1998. The latter Order is attached hereto as Exhibit "A", the former
Order is attached hereto as Exhibit "C".
18. By the terms of the Court's Order of March 6, 1997, the parties share legal custody.
Respondent enjoys prirnary physical custody of the child and Petitioner has partial custody at certain
times including alternating weekends.
19. The Court's Order of August 27, 1998, modified the previous Order by prohibiting the
Plaintiff from physically disciplining the child.
20. Since the entry of the Court's Order on August 27, 1998, Petitioner has violated the terms
of that Order by pulling the child's hair, hitting him in the stomach and on the legs.
21. Further, since the entry of the August 27, 1998 Court Order, Petitioner has engaged in a
course of conduct toward the child which has damaged the child emotionally including, but not limited
to, calling the child names such as "Bucky", "Gay Boy", "Sissy Boy", and "Fat Boy".
22. Petitioner furthers the child's unease by threatening to take custody of the child away from
the Mother despite the fact that the child has been in the Mother's custody since birth and that the
Father has been a feature of the child's life only for the last two years having had no contact with the
child for t;'e first six years of the boy's life.
23. The child has advised the caseworker in Lancaster County and, fl1rthermore, Petitioner
has admitted, while the child is in Petitioner's custody he wets the bed and has defecated on the
floor, behavior not evidenced in Respondent's home.
24. Respondent believes and therefore avers that the child is being emotionally damaged by
continuing visitation with Petitioner, that the child is in need of counseling and that until the child's
counselor determines that Petitioner should continue contact with him, Petitioner should be ordered
by this Court to refrain from exercising periods of partial cllstody.
WHEREFORE, Respondent prays this Honorable Court to modify the Court's Order of March
6, 1997 so that Petitioner is enjoined from having no contact with the child, except as determined
through the child's counselor and therapist.
FLOWER, FLOWER & LINDSAY, P.C.
Attorneys for Defendant
"\
By:
C rol J. Lindsa ,Esquire
# 44693
11 East High Street
Carlisle, PA 17013
(717) 243-5513
Date: /C/1/tt;
KEVIN T. L1TRENTA,
Plaintiff
vs.
CHRISTINE L. KETROW,
Defendant
AND now, this
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 964577 CIVIL TERM
IN CUSTODY
CERTIFICATE OF SERVICE
'7 day of (;i'/-r:t,'ij/"
, 1999, I, Carol J.
Lindsay, Esquire, of the law firm of FLOWER, FLOWER & LINDSAY, P.C., Attorneys, hereby certify
that I served the within Answer to the Petition for Appointment of Psychological Evaluator and
Counter-claim this day by depositing same in the United States Mail. First Class, Postage Prepaid, in
Carlisle. Pennsylvania, addressed to:
Date: / t) /7 /tJ1
{ I '
Donald T. Kissinger, Esquire
HOWETT, KISSINGER & MILES, P.C.
130 Walnut Street
P.O. Box 810
Harrisburg, PA 17108
FLOWER, FLOWER & LINDSAY
Attorneys for Defendant
By:
VERIFICATION
I, the undersigned, hereby verify that the statements made herein are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904,
relating to unsworn falsification to authorities.
Date:-1Ck(f Jf1
I /
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KEVIN T. L1TRENTA,
Plaintiff
v.
)
)
)
) NO. 96-4577
)
) CIVIL ACTION - LAW
) CUSTODY
CHRISTINE L. KETROW,
Defendant
ORDER
AND NOW, this ~'1
day of
Q""'Y'<A.-T , 1 998, upon consideration
of the attached Stipulation for Entry of Order, it is hereby ORDERED and DECREED as
follows:
1. Kevin T. Litrenta shall refrain from physically disciplining Nicholas
C. Ketrow.
2. Partial custody of Nicholas C. Ketrow shall resume pursuant to the
Order of Court entered April 3, 1997.
BY THE COURT:
-1. J I C"eL!),^, r3. i53.n~d-
J.
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''',...........J&~'8'{.t' .::e~.~.........._..
.t.fitJ.. Prothonotdry
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KEVIN T. L1TRENTA,
Plaintiff
)
)
)
) NO. 96-4577
)
) CIVIL ACTION - LAW
) CUSTODY
v.
CHRISTINE L. KETROW,
Defendant
STIPULATION FOR ENTRY OF ORDER
AND NOW come Christine L. Ketrow and Kevin T. Litrenta, by and through their
counsel Carol J. Lindsay, Esquire and Donald T. Kissinger, Esquire, who stipulate and
agree as follows:
1. Kevin T. Litrenta agrees that he will refrain from physically
disciplining Nicholas C. Ketrow, born June 14, 1989.
2. The Temporary Order dated September 8, 1997 in the action
docketed to No. 97-4855 in the Court of Common Pleas of Cumberland County shall be
terminated pursuant to consent order, and the Petition for Relief under the Protection
from Abuse Act shall be withdrawn.
3. Partial custody of Nicholas C. Ketrow shall resume pursuant to the
Order of Court entered April 3, 1997 in the above-captioned action.
IN WITNESS WHEREOF, the parties hereto and their respective counsel set
their hands and seals this "2-p;; day of A-u-r; 'L~~ , 1998.
IRE
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-
Report of Psy~holo8i~al Evaluation: Nicholas Canaan Ketrow
Date of Evaluation: 1.19-99
DOB: 6-14-89
Page 2
RRA~ON FOR REFERRAL:
Nicholas is a 9-year. '-month-old third grade student at St. Joseph School referred duc to long-standing
difficulties with grades, disruptive behaviors, allention and focusing.
BACKGROUND TNFORMA nON:
Nicholas lives at home with his natural mother. Ms. Christine Ketrow. Parents have been separate<l/di-
vorced for several years, and Nicholas visits wilh his Cather every other weekend.
Mother indicated that Nicholas was the product oC a high-risk pregnancy. that he was born at 7 Ibs, , oz_
near his due date, by natural delivery, and was released after the nonnal hospiUll stay. Medically he has
been rather healthy ex~ept fOr being hospitalized Cor eight days when he was 16 mO(lthS of age due to the
flu. Additionally, he had tubes placed in his ears bilaterally when he was 2~ years old.
Most developmental milestones were met on time except lhnt "it took forever" for :-licho!as ro be toilet
trained. He does not presently bed-wet.
School hislDl"l indicates thai Nicholas attended a preschool from 9 months of age through 4 year~ of age,
and no conce1'll.l were raised. He then went to kindergarten and first grade at Emmanuel Baptist School
where he was described as having difficulty sitting still and as having social problems, but mother feels
that he did not respond well to that particular school. He then repeatc'.d first grade at 5t. Joseph School
WId things went well. as they did in second grade. At the beginning of this school year, Nicholas got off
to a poor start as regards his behavior, and academics are rather inconsist<:nt. He was previously involved
in individual psychotherapy for a period of 4 to 5 months approllimately one year ago.
RESlJLTS AND DISCUSSION:
In this one-lD-one evaluation setting, Nicholas revealed himsdf to be a very pleasant. cooperative, appro.
priately assertive, well-mannered and mature young man. He displayed good poise and appeared
interested in the various things we did. Outside of school he enjoys playing Legos, Game Boy, and flag
football. Conversational language was adequate with regard to fluency, grammar and general discourse.
However. in other areas of social development, concerns are raised. Both teacher and parent indicate that
he has difficulty in adapting to new social situations, and often at recess either plays alone or is the last
one chosen in a group game.
Emotionally and psychologically, concerns are also seen. Nieholas describes himself as a happy boy who
enjoys sledding and snowmobiling with a male Criend of his mother's. Nicholas would like to be a face
car driver or "race anything" as an adult. However, when asked to draw his family he expressed that he
didn't know which family to draw, whether it would be his mother and her boyfriend and his family, or
his father and his girlfriend and her family. He cnded up dtawing a combination of bot.'! families at an
amusement park. Projectively the drawing is suggestive of an~iety and anger. This is consistcnt with the
school guidance counselor's feelings that l\icholas is an anxious child. that he worries about the separa.
tion of his parents. and that he feels different from other kids. Checklists completed by teacher and
mother are also consistent with elevated anxiety and some depressive symptomatology. as well as atten.
tiona! difficulties. They describe him as worrying a lot, worrying about school. worrying about parMts,
and being easily upset and giving up easily.
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-'. l~J,'U~.
r
/ Report of Psychological Evaluation: Nicholas Canaan Ketrow
Date of Evaluation: 1-19-99
008: 6-14-89
Pagc 3
Nicholas also displays somc ambivalcnce toWlltds school, Though enjoying his teacher, he would prefer
to stay at borne and play with his grandpa or build models. His favorite subjccts are art, gym and, to a
lesscr extent, mathematics. His least favoriw subject is language arts because "I'm not good at it." He
admits that the teacber has to remind him to pay aMntion and that in school "I feel like jumping around."
He has recenUy gotwn into trouble in the after-school program because he has difficulty in sitting down
appropriately and will go off and walk on the ice, for cxampIe. when direcUy told not to.
Physical factors indicate that Nicholas is predominantly left handed and right footed. Though posture
and stamina were good, gross-motor skills werc rather poor. He was unable to skip, even after demon-
stration. He can not yet wink with one eye. Observation of rapid hand movements and thumb to each
finger touching indicated rather poor performance. Overall, there is a sense of neuropsychological devel-
opmental weakness.
While working on the fonnal test items. Nicholas had difficulty in sitting in his chair. prcferred to stand,
was rather antsy. and had poor sustained attention. Though on each task he could maintain attention and
com:entration, in between tasks he often had difticulty in self.monitoring,
Cognitive factors indicate that Nicholas is performing within the Average range of ability with particular
strength in verbal sleills and a decided weakness in nonverbal reasoning. Verbal skills include such things
as word defmitions and noting similarities between different word concepts. Nonverbal Reasoning includes
completing matrices and S<lquential and quantitative reasoning such as pattern analysis and inductive rea-
soning. Spatial Reasoning was within the average range. Overall, Nicholas' Verbal skills are at the Slst
percentile, his Spatial skills at the SOth percentilc, and bis Nonverbal Reasoning skills at the 10th perccn-
tile for his age, Short-term memory skills, particularly for meaningful and everyday lists of objects, were
rather poor. This is also seen in incidental memory of n line drawing (the Rey) on which Nicholas per-
fonned below the 1st percentile for his age in memory for this design. A Jot of these difficulties in his
memory and thc nonverbal reasoning areas can be ascribed to impulsive responding.
Achievement results are somewhat below expectancy in basic numerical computation sl:ills as well as
word attack s1eil1s. Results during this evaluation are ,somewhat lower than those obtained on the Iowa
Tests of Basic Skills given in October of 1998. At that point. Nicholas performed within the average
range in Reading and Total Language, and performed above average in Mathematics. These inconsistent
results are. in a sense, consistent with teacher and parent reports that one day he will do well and the next
day rathcr poorly.
PARENT CONFERENCE:
Following the evaluation a parent conference was held with Ms. Ketrow. Background information was
obtained and psychological results were discussed.
IMPRESSION ANn RECOMMENDATIONS:
Nicholas Ketrow is a 9-year, 7-month-old third grade student who has been rcferred due to long-standing
difficulties with grades, disruptive behaviors. attention and focusing. The pre>ent evaluation reveals a
very pleasant. cooperative young boy in this one.to-one situation. Cognitive development is within the
average range, with clinical difficulties noted in incidcntal memory and inductive reasoning (mainly due
c () r:. '(
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.~ of Psycholo~lcal Ev uatlon; "I ''''' '-,-- . - - -~-
Date of Evaluation: 1-19-99
to impulsive responding). Achievement levels were somewhat lower on this date as compared \0 those
on the Iowa given in October of 1998.
-fbough a certain portion of Nicholas' behaviors is due to emotional and family. factors, he does.appear 10
have attenlional, iIOpulsivity and focusing problems in addition to those difficulUes. Presendy thiS appears
10 be leadinl: to social difficulties with classmates as well as feelings of low self-confidence and self-
worth. Though sp"~ific learning disabilities cannot be ruled out at this time, his interfering behaviors
maj(e diagnosis problematic. With the above in mind, the following recommendations are made:
I J .:;'4:.1;,':,18
_ ~'. J':;/U,:"
I. Based upon present evaluation and history, I have encouraged Ms. KetroW to seek medical consulta-
tion and Intervention, if appropriate. In addition to emotional and behavioral factors, Nich<llas'
characteristics are consistent with a diagnosis of Attention Deficit Hyperactivity Disorder - Combined
Type. These behaviors are significantly and negatively impacting upon academic progress and social
skills. .~w.
2. Should medical interVention be initiated, then a trial p.:riod to see how Nie~las adjusts would be in
order.
3. Whether pharmaceutical inteT'lention is initialed or not. Nicholas contin\l~ to benefit from school
guidance counseling to help with social skills, impulse control, and geneial feelings of frustration
and low self-esteem.
<' .
4. Following a monitoring period, revisitation of possible leaming disabilities as well as Nicholas' nc:ed
for more ongoing outside-of-school psychological therapy should be made.
5. These resulls and impressions will be discussed at an upcoming Student Suppol'! Team meeting IC
which parents are invited. '
~
,
GEO d. I<URIE. c:ert. School Psychologist
P A Licensed Psychol~~t #PS-003309-L
j:. ,
c;c: Ms, Christine Ketrow. 912 Bosler Ave.. Lemoyne, PA 17043
Sporting Hill Family Health CtInter, 350 S. Sporting Hill Rd., Mechanicsburg, PA 17055
GdKJeol
99Q4700l.PSY
------- --.------
H TOTHL Fr.H"I[. 05 ~:l<
COP y
EXHIBIT "e"
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KEVIN T. LITRENTA, )
Plaintiff )
)
v. ) NO. 96-4577
)
CHRISTINE L. KETROW, ) CIVIL ACTION - LAW
Defendant ) CUSTODY
ORDER
AND NOW, this 3 NL day of
rlt~
, 1997 , it is
hereby ORDERED and DECREED that the provisions of the StipUlation
for Entry of custody Order entered into between the parties which
is attached hereto, are incorporated herein as an Order of this
Court.
BY THE COURT:
i1 l' ~,L(.:K.- d. 1~
J.
mm: COpy }"=RCM RECORD
;:t ':-'~'..~:';' ..~: :;' ":":~; :.:~:.:;;r;~ l.~i:::.;:;~~~{t~;1I1
l'd'!.~ ,;", d.J2,~~. /.$7
~ hI*"- '&. 1]& P.Y;LL;~_:.
Prait;onolary
R"oB-I9-1997 16:16
HDWETT,KISSI~,MILES,PC
717 23dS4e2 P.03
IN THE COURT OF COMMON ?LEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KEVIN T. LITRENTA, )
plaintiff )
)
v. J NO. 96~4577
)
CHRISTINE L. KETROli, ) CIVIL ACTION - LAW
Defendant ) CUSTODY
STIPULATION FOR ENTRY OF CUSTODY ORDER
~-o NOW, ~~is C;~ day of
~ , 199-1 cone the
parties in the above-captioned ac~ion and enter into this
stipulation:
WHEREAS, Plai~~iff, Kevin T. Litrenta (herei~after referred
to as "Father"), ar.d Defendant, CJ:ristine L. Ketro'" (hereinafter
referred to as "Mother"), are the parents of one ;ninor child
namely Nicholas c. Ketrow (hereinafter referred to as
"Nicholas"), born June 14, 1989; and
WHEREAS, NichOlas is presently in the primary physical
custody of Mother; and
WHEREAS, on August 15, 1996, Father initiated a Complaint
for Shared Legal and Physical custody docketed to the above~
captioned number in the court of Common Pleas of Cunberland
county, pennsylvania in which he requested shared legal and
physical custcdy of Nicholas; and
WHEREAS, the parties have deternined ;hat it is in the best
interests of Nicholas that the pending cus~ody issue be resolved
amicably between them, and after negotiations in which both
parties were represented by counsel ot their choice, the parties
FElH9-1997 16:17
HOWETT,KISSINGER,MILES,FC
717 23<:5402 P. 04
have reached an agreement as to the physical and legal custody of
Nicholas.
NOll 'rIlEREFORE, with tile foregoing recitals beinghereina!ter
incorporated by reference herein and deemed as an essential par~
hereof. and intending to be legallY bound nereby, and for other
good and sufficient ccnsideration, the receipt of .hich is he:eby
acknowledged, the parties mutually agree and stipulate as
follows:
1. Leoal CustodY. Legal custody as that tern is
defined by 23 Fa.C.S.A. ~5302 shall be shared e~ally between the
parties.
2. lla;oritv physical custody. l1ajority physical
custody of Nicholas shall be in Mother.
3. partial physical custody. Father shall have
partial physical custody rights with Nicholas as follows:
a. lleekends. Every other weekend frcm Friday at
6:30 p.m. through Sunday at 7:00 p.m.
b. KOlidavs. Alternating holidays fro~ 9:00
a.m. through 9:00 p.m. Said holidays shall consist of New Year's
Day, Easter, Memorial Day, July 4th, and Labor Day.
o. Thanksqivinq. In 1997 and in all odd-
numbered years thereafter, Father shall be entitled to physical
custody of NiCholas from 9:00 a.n. Thanksgiving Day through the
following Sunday at 7:00 p.m. Likewise, in 199B and in all even-
numbered years thereafter, Mother shall be entitled to physical
2
FEIl-1!H937 16: 17
iJWETT, KISSINGER, MILES, PC
717 23'54e2 P.B5
custody of Nicholas froM Thanksgiving Day at 9:00 a.m. through
the following sunday at 7:00 p.~.
d. Cbristmas. In 1996 and all even-numbered
years thereafter, Father shall be entitled to physical custody of
iiichclas froIJ 12:00 p.m. Christmas Eve through 12:00 p.m.
Christ~as Day. I~ 1997 and all odd-numbered years thereafter,
Father shall be entitled to Fhysical custody of Nicholas frcm
12:00 p.m. Chris~~as Day thrcug~ 12:00 p.m. DeC€Nber 26. !n 1996
and all even-numbere:l years thereafter, Motller shall be entitled
to physical custody of Nicholas frem 12:00 p.o. Christmas Day
through 12:00 p.~. Deceober 26. In 1997 and all odd-numeered
years thereafter, Mother shall be entitled to physical custody of
Nicholas frem 12:00 p.m. christmas Eve through 12:00 p.m.
Christmas Day. The remainder of Nicholas' Christmas/New Year
break from school shall be equallY divided between the parties as
they agree.
e, sbrina Break. Father shall be entitled to
one-half of Nicholas' spring break ~rom school as the parties may
agree.
f. Summer vacation. Father shall be entitled to
three (3) weeks of physical custody of Nicholas during the
traditional sunrner school vacation in 1997 with one week
occurring in June, cne week in July, and one week in August as
the parties may agree. commencing in 1998 and thereafter, Father
shall be entitled to four (4) weeks of physical custody of
Nicholas during the traditional summer school vacation with one
3
FEB-19-1997 ,6: 18
HOWETT,KI;SI,~,MlLES,FC
717 2~$<llJ2 P.~
week occurring in June, two weeks in July, and one week in August
as the parties may agree.
4. School Choice. The parties acknowledge that they
have discussed the possibility of Nicholas' at~endance at
Lancaster Country Day School commencing in the fall 1997. The
parties agree to continue these discussions so as to reach
agreement in the best interests of Nicholas regarding the school
choice for 1991 and thereafter. The parties agree that Nicholas'
school shall not be changed without consultation between t~e
parties and no less than six~y (50) days advance written notice
to Father.
5. Father'S Dav/Mother's Dav. father shall al~ays
have physical custody of Nicholas on Father's Day from 9:00 a.m.
through 9:00 p.~. Mother shall always have physical custody of
Nicholas on Mother's Day from 9:00 a.m. ~hrough 9:00 p.m.
6. Additional Time. Both parties agree that Father
may spend additional time ~ith NiCholas at such other times as
the parties may mutually agree.
7. Soecial circ~stances. The parties agree that
should special circumstances arise they shall discuss said
circumstances and if they are in agreement, modifY their custody
agreement to accommodate the special circumstances.
a. Entry of court order. The parties agree that the
terms of this stipulation for Entry of Custody Order shall be
entered as an Order of Court at the request of either party and
enforceable by the court as if a full hearing had been conducted.
4
FEB-19-199? 16' 18
iJUETT.KISSIHGER.MILES.PC
717 234S4e2 . P,iJ7
IN WI~NESS WHEREOF, the parties have signed, sealed and
acknowledged this stipulation.
WITN
....,'
...
:WITNESS
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~~.~)
5