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HomeMy WebLinkAbout00-02198 , JENNIFER S. STEVENSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 00-2198 CIVIL ACTION LAW BOBBIE D. STEVENSON Defendant IN CUSTODY ORDER OF COURT AND NOW, this ---bL day of VW, "1 , 2003, upon consideration ofthe attached Custody Conciliation Report, it~d and directed as follows: I. Pending further Order of Court or agreement of the parties the partial physical custody schedule set forth in paragraph 3 of the prior Order of this Court dated June 13,2000 is temporarily suspended and replaced with this Order. All other provisions ofthe prior Order shall continue in effect. 2. The parties shall participate in a course of coparenting counseling with a professional participating in the Mother's insurance program or other professional selected by agreement of the parties. The purpose of the counseling shall be to assist the parties in developing sufficient communication and cooperation to enable them to effectively coparent their Child. The parties shall participate in a minimum of four joint counseling sessions and thereafter shall follow the n:commendations of the counselor with respect to the duration and frequency of counseling. Each party shall be responsible to pay one half of any costs which are not paid by insurance coverage. 3. The Father shall have partial physical custody of the Child every Sunday from 8:00 am until 7:30 pm, beginning May 4,2003. The Mother shall be entitled to reschedule the Father's period of weekend custody to Saturday (rather than Sunday) for the same duration upon providing the Father with one week advance notice. 4. Within three months of completion of the course of coparenting counseling, counsel for either party or a party pro se may contact the conciliator to schedule an additional custody conciliation conference, if necessary. BY THE COURT, tI/~ cc: Susan M. Kadel, Esquire - Counsel for Mother ~ ,_ _ ., < " s: (J~ ,0,3 Bobbie D. Stevenson, Father , /rv~ C).-~. '''f= -,-- , .' ~ u ,q,' ,'," '''', ", ~, -- . """" . , " VU\f\l/iV,SNN3d' JJ.Nnm CiH'f1H'38I^lnO II] :S lid L - },~1'180 A8V10i\\{)1'-j,:,.:,',:,_::; '=0 381::HO-nJ \:"1 '.' , '"",,",, 'u'", ' ....- 1_. ,JI~Il~ I ~ ~ _,_ lIti~ ; ~'r_'-"""~"""~'im'7!f ,~~, . JENNIFER S. STEVENSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 00-2198 CIVIL ACTION LAW BOBBIE D. STEVENSON Defendant IN CUSTODY Pirior Judge: 1. Wesley Oler, Jr. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator subrnits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: ]~AME DATE OF BIRTH CURRENTLY IN CUSTODY OF Patricia M. Stevenson October 9, 1992 Mother 2. A Conciliation Conference was held on April 29, 2003, with the following individuals in attendance: The Mother, Jennifer S. Stevenson, with her counsel, Susan M. Kadel, Esquire, and the Father, Bobbie D. Stevenson, who is not represented by counsel in this matter. 3. The parties agreed to entry of an Order in the form as attached. flr.:J ,~. d.Orl '5 Da~~ Custody Conciliator Date "~j!;'''' . " . r. '0 SHERIFF'S RETURN - REGULAR CJI,SE NO: 2000-02198 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STEVENSON JENNIFER S VS STEVENSON BOBBIE D HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pensyl vania , who being duly sworn according to law, says, the within COMPLAINT - CUSTODY was served upon STEVENSON BOBBIE D the DEFENDANT , at 0018:20 HOURS, on the 24th day of May , 2000 at. 704 ERFORD ROAD CAMP HILL, PA 17011 by handing to NJlill STEVENSON (MOTHER) a true and attested copy of COMPLAINT - CUSTODY together with ORDER OF COURT and at tl1e same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.30 .00 10.00 .00 37.30 So Answers: r'~Vl-t:~/-i R. Thomas Kline OS/26/2000 JAMES, SMITH, DURKIN & CONNELL Sworn and Subscribed to before By: ;:~h~jV me this I~ day of ~ dAv-<> A.D. ~ t2 Ouu~. ,{~ prothonota~ '<, "~ . - , ~. JENNIFER S. STEVENSON, : IN THE COURT OF COMMON PLEAS OF plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. . NO. 00-2198 CIVIL TERM . : . CIVIL ACTION - LAW . BOBBIE D. STEVENSON, . . Defendant . CUSTODY . ClIDER OF CXXJRT AND /.IlCIi, this 1"3 tl day of J \i.J\ c- consideration of the attached Custody Conciliation and directed as follows: , 2000, upon Report, it is ordered 1. The Mother, Jennifer S. Stevenson, and the Father, Bobbie D. stevenson, shall have shared legal custody of Patricia M. Stevenson, born October 9, 1992. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. 2. The Mother shall have primary physical custody of the Child. 3. During the school year, the Father shall have partial physical custody of the Child on alternating weekends from Friday at 5:30 p.m. through Sunday at 7:30 p.m. During the summer school break, the Father shall have partial custody of the Child on alternating weekends from Friday at 7:15 a.m., when the Mother shall transport the Child to the Father's residence, through Monday morning, when the Father shall transport the Child to the summer school program at Rice Elementary School. In addition, dUJ:'ing the summer school break, the Father shall be entitled to have custody of the Child for 2 additional overnight periods per month, with the specific dates and times to be arranged by agreement of the parties. The Father shall transport the Child to the summer school program on weekdays when he has custody under this provision. The Father shall not schedule the 2 additional overnight periods of custody to interfere with the Mother's weekend periods of custody, unless otherwise agreed between the parties. 4. The parties shall share or alternate having custody of the Child on holidays as follows: A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall run frc:rn Christmas Eve at 12:00 noon through Christmas Day at 2:00 p.m., and Segment B, which shall run from Christmas Day at 2:00 p.m. through December 26 at 8:00 p.m. The Father shall have custody of the Child during Segment A in odd numbered years and during Segment B in even numbered years. The Mother shall have custody of the Child during Segment A in even numbered years and during Segment B ,'<'it, _" VINVlI1ASNN3d MNnW (I\VlI::EJ8IAlnJ ZS :S Hd ~ I Nill' 00 },lhd.tCi,I\j(:.:> ~jn 0, __ . ," 3C;IJJD'--O:nl:J .. ",,,,~,,,,~A'!!!l~~ ~_. ~ " .' '!- _,. ." .~Jl!!l!~l'l'ii!W~~1'Hl~~lII!"_1I1.!Il!JII!J?!!lli~ll] ,." ,.J!III~ in odd numbered years. B. ALTERNATING HOLIDAYS: The parties shall alternate having custody of the Child on the following holidays: Easter, Memorial Day, July 4th, Labor Day and Thanksgiving from 9:00 a.m. until 8:00 p.m. The alternating holiday schedule shall continue with the Mother having custody of the Child on July 4th in 2000. C. MOrHER'S DAY/FATHER'S DAY: The Mother shall have custody of the Child every year on Mother's Day from 9:00 a.m. until 8:00 p.m. and the Father shall have custody of the Child every year on Father's Day from 9:00 a.m. until 8:00 p.m. D. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 5. Unless otherwise specified in this Order, the party rece1nng custody shall be responsible to provide transportation for the exchange of custody. 6. Neither party shall use illegal drugs or consume alcohol during his or her periods of custody. 7. The Father shall ensure that all clothing sent with the Child by the Mother is returned to the Mother at the end of each period of custody. 8. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, dlC--o J. ~~_I -00 ~~?J cc: John J. Connelly, Jr., Esquire - Counsel for Mother Robert L. O'Brien, Esquire - Counsel for Father "Ii'1I " . , '" JENNIFER S. STEVENSON, . IN THE COURT OF COMMON PLEAS OF . Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-2198 CIVIL TERM : . CIVIL ACTION - LAW . BOBBIE D. STEVENSON, . . Defendant . CUSTODY . CUS'J.'ODY CXNCILIATICN SUMMARY REPOOT IN ACCXJIDANCE WITH COMBERLAND COON'.rY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF patricia Stevenson October 9, 1992 Mother 2. A Conciliation Conference was held on June 7, 2000, with the following individuals in attendance: The Mother, Jennifer S. Stevenson, with her counsel, John J. Connelly, Jr., Esquire, and the Father, Bobbie D. stevenson, with his counsel, Robert L. O'Brien, Esquire. 3. 1he parties agreed to entry of an Order in the form as attached. ~ f{ d-eJo1) Date ,.~ Custody Conciliator ",,," '0 v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLA VNIA ~NO. 00 - cX/9P C'.U~( T~ JENNIFER S. STEVENSON, PLAINTIFF BOBBIE D. STEVENSON, DEFENDANT : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before, 'l::J\W(\ s. ~'-I ' Esquire, the Concilia~r, on the .1:!: day of l\'..lhWL- 2000, at ~'. OD :t2.-.M., at s9 \,j, \-\).\1'\ &\'\ ~eCX'q(\\~ \ . Pennsylvania, for a Pre-Hearing Custody Conference. At such Conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a Temporary Order. All children age five or older may also be present at the Conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. Notification to the Defendant by the Prothonotary's Office is waived. For the Court, Date of Order: L\ \ \ '-\ IOD By --Jjo\\", ~, ~~~ \ Custody Conciliator (\::S> ') YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cwnberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717)249-3166 '1>. ,_c" ""d'~ 0;',,"" ,_",~,___,,~ ",-.'~'-.~ ""'~f"_ '-"""-,'"'--,~",';r---"-,'f""" J_,,_ .' "- '" -~-, --; ,~ - -- ~.""" -, " 'lIIIiill- III _ ~"~.~,~. ' l_..~ ~ h '-1";"'''; ,',' ~ , ~ ~ ~ ",.'- ~~ - - -~~-~ 7, "':-'-":'-':"-,'JIL\qy nJ 'Cln /"' ..it liI'li, ! pI i rl. <j ~J I ji L..'.:. CUr/;:J:hL/,'c\D r:ni H'.JTv' PEi\JNSYL'\/i'I~;;^~' , 1\ "t\ 1/.//-00 ~,~ ;?n,,~ 7J ~~ /1-1)- t::Pt:J 71~ ~ ~ ~~ tVI?";:>?> ~ ;n~ -z;; ~~ ~ ,"-'~" ",-, " -., --p'. 1< v. : IN 1HE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLA VNIA ~ NO. (rl). ;1I9i ~ -r.t- JENNIFER S. STEVENSON, PLAINTIFF BOBBIE D. STEVENSON, DEFENDANT : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT You, Bobbie D. Stevenson, Defendant, have been sued in Court to obtain custody, partial custody or visitation of the child: Patricia M. Stevenson. You are ordered to appear in person at the Cumberland Courthouse, One Courthouse Square, Carlisle, Pennsylvania, on the day of , 2000, at o'clock .m. You are further ordered to bring with you the child: Patricia M. Stevenson. If you fail to appear as provided by this Order or to bring the child, an Order for custody, partial custody or visitation may be entered against you or the Court may issue a warrant for your arrest. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE 1HE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Phone: (717) 249-3166 BY THE COURT: 1. Ii II ii 'C _C" ,,- ,-'-I~":""':0',1C_,-,-,~_c ,,_... "~~.--""W " '~'1 'n ":'7"-Cf=:_ ',' .i. ",:t_~d.'~_,<-"_> " < .' -'- .. - __ '.' -- , '~" TIc- _ . v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLA VNIA ; NO. tJV - .:Jl1f C;;J 7A- JENNIFER S. STEVENSON, PLAINTIFF BOBBIE D. STEVENSON, DEFENDANT : CIVIL ACTION - LAW : IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Jennifer S. Stevenson, who currently resides at 53 Fairfield Street, Carlisle, Cumberland, County, Pennsylvania 17013. 2. The Defendant is Bobbie D. Stevenson, who resides at 704 Erford Road, Camp Hill, Pennsylvania 17011. 3. The Defendant is presently incarcerated at the Cumberland County Prison, having been sentenced on the charges of Simple Assault, Resisting Arrest, Disorderly Conduct and Public Drunkeness. He has been in the Cumberland County Prison since November 23, 1999 and is scheduled to be released on April 12, 2000. 4. Plaintiff seeks primary custody of the following child: NAME PRESENT RESIDENCE D.O.B. Patricia M. Stevenson 53 Fairfield Street Carlisle, Pennsylvania 10/9/92 The child was not born out of wedlock. '-il", , -~~< "-~--~";-,,' .,.' ..,,' .~ "_" ,",--~~r"_"_t: ,_""-,...",,.' ,no ,- .'. "', ".'-, -~ , . . The child is presently in the custody of Jennifer S. Stevenson who resides at 53 Fairfield Street, Carlisle, Pennsylvania. During the past five years, the child has resided with the following persons and at the following addresses: NAME RESIDENCE DATE Jennifer S. Stevenson (Mother) Bobbie D. Stevenson (Father) 109 Twin Hills Road Dillsburg, Pennsylvania 01/95 - 04/96 Jennifer S. Stevenson Terry & Marcia Duncan (Grandparents) 208 Locust Drive New Cumberland, Pennsylvania 04/96 - 01/98 Jennifer S. Stevenson 703 Seventh Street New Cumberland, Pennsylvania 01/98 - 09/98 Jennifer S. Stevenson Charles Moose (Fiancee) 53 Fairfield Street Carlisle, Pennsylvania 09/98 - Present The mother of the child is Jennifer S. Stevenson, currently residing at 53 Fairfield Street, Carlisle, Pennsylvania. She is divorced. The father of the child is Bobbie D. Stevenson, currently, Pennsylvania. He is divorced. 4. The relationship of Plaintiff to the child is that of mother. The Plaintiff currently resides with the following person/persons: NAME RELATIONSHIP Patricia M. Stevenson Daughter Charles Moose Fiancee 5. The relationship of Defendant to the child is that off ather. The Defendant is ])I .,',"<'___ ,'" , ,._ '...'>",. ?!_~,.,.,._ '>-<f"C'-:'__T.~~' ',"'"i,,-,,~~,,"< ,-". .' ,....,<-<.- ."-,, -'~-'P,-. -f~ <.- , T '." ,_, ,! ',~ ,_ ", currently s with the following person/persons: NAME RELATIONSHIP Mr. and Mrs. Stevenson Parents 6. There is a Custody Order in existence entered on September 2, 1997 in the Court of Common Pleas, York County, Pennsylvania, attached hereto and marked Exhibit "A". At the time of the entry of the Order, the Plaintiff in this action resided in York County, having moved to Cumberland County in September of 1998. The Defendant has always resided in Cumberland County. 7. The existing Custody Order provides for overnight rights of partial custody in the Defendant which is not in the minor child's best interest. 8. Given the Defendant's violent propensity, his abuse of alcohol and the possession of a gun in his vehicle at the time of his arrest, it believed and therefore averred that it is not in the minor child's best interest for the Defendant to have overnight rights of partial custody at the present time. 9. Plaintiff has participated as a party in litigation concerning the custody of the child in the custody action in York County indexed to no. 96 SU 01582 03. 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. 10. The best interest and permanent welfare of the child will be served by granting the relief requested. II. Each parent whose parental rights to the child have not' been terminated and the person who has physical custody of the child has been named as parties to this action. 'jj ~~ ".., 'or """:,', ~,' ,,-,"c'''' H"'" '. ,> , ,~ " ,~'".V,"!<"'-'~l~ '" .',',T. _","', "?",oy.',, _," , " _~,~" -", "" .""., .-' ~,"' WHEREFORE, the Plaintiff, Jennifer S. Stevenson, requests the court to grant primary custody of the minor child, Patricia M. Stevenson, to her. Date: !r ~ 3 -00 CONNELLY LLP " ",-,. ~_~"'1'\'j")'1'"V!';~-___;=" ".~ .~ -'-t,,'"'<--'"<''''''''~'_?';-''--'+_'-'-'''-''''-''' ,-_'_'~"" -~"-<'-'- ,., - " -"., ",,-., VERIFICATION I verify that the statements made in this Pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: .?r.;? 8 -DD !/VI/Vli., -;), 5k{~) . - ~." ". . ',' ~- "'~,...~"~--. EXHIBIT "A" _ _',"" >, '.." c ",,, -,' ','.' .'''"'0'__ ,~. '." " '-'" - -. , BOBBIE D. STEVENSON, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS YORK COUNTY, PENNSYLVANIA v. NO. 96 SU 01582 03 <=> "" .." ..... ..." (""") rn ("') 1""1 ,." 0 -0 ~, -<c: ~~ D,;;V I -:In :::0 ' c..:l :oJm :;X:....-: 0- .. -,," ::- -..<:: -oCi """";r'T'! c:: ::It 00 l:>(/) c:9- :z fTl C) ...., w -' ~ ::0 -< JENNIFER S. STEVENSON, Defendant/Petitioner CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this~':! day of ,~ ,1997, upon consideration of the attached Stipulation of the Parties and Counsel, the following Order is entered: The Defendant/Mother, Jennifer S. Stevenson, shall have primary physical custody of the minor child, Patricia M. Stevenson, born October 9, 1992, subject to the partial custody rights of the Plaintiff/Father, Bobbie D. Stevenson, as follows: 1. Mother's primary physical custody shall begin on Sunday, August 24, 1997, with the child being returned to the mother's custody on that day at 8:00 p.m., and at 8:00 p.m. on the Sunday evening preceding the beginning of school in each year hereafter should the child be with the father at that time. 2. The father shall have partial custody rights each Wednesday beginning when he picks up the child from pre-school at the end of the school day until 8:00 p.m. when the child will be delivered to the mother. 3. Alternating weekends beginning with the father picking up the child at pre-school at the end of the school day on Friday until Sunday at 8:00 p.m. ~-I 'L . Mo., "' c .,-- ~-"', ~ ,~,m 4. The parties shall alternate the following holidays: Labor Day, Thanksgiving, Easter, Memorial Day and the Fourth of July from 9:00 a.m. until 8:00 p.m. with the first holiday being Labor Day 1997, which shall be the father's holiday. 5. Christmas Eve and Christmas Day shall be divided based on the following schedule: Segment A: From 12:00 Noon Christmas Eve Day until 2:00 p.m. Christmas Day; and Segment B: From 2:00 p.m. on Christmas Day until 8:00 p.m. December 26, 1997. This schedule shall be alternated between the parties with the father having Segment A in 1997. 6. Mother's Day with mother and Father's Day with father regardless of the weekend schedule from 9:00 a.m. until 8:00 p.m. on the day designated. 7. The parties shall share the summer as follows: The father shall have custody of the child from 8:00 p.m. on Sunday until Wednesday morning when the child will be dropped off at day care. Mother shall have physical custody from Wednesday when the child will be picked up at day care until 9:00 a.m. on Saturday. The parties shall alternate the weekend period from 9:00 a.m. on Saturday to 6:00 p.m. on Sunday. '"", , ,-. -- >'- , -, " " - 8. During the summer school holiday, each parent shall be entitled to two (2) weeks vacation with each week encompassing a total of seven (7) days to include the parent's weekend. These vacation weeks shall be taken either separately or consecutively at the party's election. Each parent shall give the other parent a minimum of thirty (30) days notice of the weeks selected in the summer. The parent first giving notice shall have a right to select their weeks. 9. Each parent shall be responsible for transporting the child to her scheduled activities during that parent's period of custody. BY THE COURT: )~:J~_td~ PENNY L. BLACKWELL, JUDGE '~ " BOBBIE D. STEVENSON, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS YORK COUNTY, PENNSYLVANIA v. NO. 96 SU 01582 03 JENNIFER S. STEVENSON, Defendant/Petitioner CIVIL ACTION - LAW IN CUSTODY STIPULATION OF THE PARTIES AND COUNSEL FOR AGREED CUSTODY ORDER OF COURT WHEREAS, Jennifer S. Stevenson is the natural mother of the minor child, Patricia M. Stevenson, born October 9, 1992; and WHEREAS, Bobbie D. Stevenson is the natural father of the minor child; and WHEREAS, Jennifer S. Stevenson is represented by John J. Connelly, Jr., Esquire, and Bobbie D. Stevenson is represented by Keith B. DeArmond, Esquire; and WHEREAS, it is the desire of the parties and their respective counsel to enter into an agreed upon Custody Order; and WHEREAS, a pre-hearing custody conference is scheduled for July 9, 1997 at 1 :00 p.m. before the Honorable Penny L. Blackwell; and WHEREAS, it is the intent of the parties to cancel said conference and have the following Stipulation entered as an Order of Court. NOW THEREFORE, the parties and their respective counsel mutually agree as -.:$1? '._ -- , ", follows: The Defendant/Mother, Jennifer S. Stevenson, shall have primary physical custody of the minor child, Patricia M. Stevenson, born October 9, 1992, subject to the partial custody rights of the Plaintiff/Father, Bobbie D. Stevenson, as follows: 1. Mother's primary physical custody shall begin on Sunday, August 24, 1997, with the child being returned to the mother's custody on that day at 8:00 p.m., and at 8:00 p.m. on the Sunday evening preceding the beginning of school in each year hereafter should the child be with the father at that time. 2. The father shall have partial custody rights each Wednesday beginning when he picks up the child from pre-school at the end of the school day until 8:00 p.m. when the child will be delivered to the mother. 3. Alternating weekends beginning with the father picking up the child at pre-school at the end of the school day on Friday until Sunday at 8:00 p.m. 4. The parties shall alternate the following holidays: Labor Day, Thanksgiving, Easter, Memorial Day and the Fourth of July from 9:00 a.m. until 8:00 p.m. with the first holiday being Labor Day 1997, which shall be the father's holiday. 5. Christmas Eve and Christmas Day shall be divided based on the following schedule: Segment A: From 12:00 Noon Christmas Eve Day until 2:00 p.m. Christmas Day; and "~~ ,~, '. Segment B: From 2:00 p.m. on Christmas Day until 8:00 p.m. December 26. 1997. This schedule shall be alternated between the parties with the father having Segment A in 1997. 6. Mother's Day with mother and Father's Day with father regardless of the weekend schedule from 9:00 a.m. until 8:00 p.m. on the day designated. 7. The parties shall share the summer as follows: The father shall have custody of the child from 8:00 p.m. on Sunday until Wednesday morning when the child will be dropped off at day care. Mother shall have physical custody from Wednesday when the child will be picked up at day care until 9:00 a.m. on Saturday. The parties shall alternate the weekend period from 9:00 a.m. on Saturday to 6:00 p.m. on Sunday. 8. During the summer school holiday, each parent shall be entitled to two (2) weeks vacation with each week encompassing a total of seven (7) days to include the parent's weekend. These vacation weeks shall be taken either separately or consecutively at the party's election. Each parent shall give the other parent a minimum of thirty (30) days notice of the weeks selected in the summer. The parent first giving notice shall have a right to select their weeks. "i< ._ ,-"""".' c C , , " -~'I-"=--. 9. Each parent shall be responsible for transporting the child to her scheduled.activities during that parent's period of custody. WHEREFORE, the parties and their respective counsel hereto, set forth their signatures intending to be legally bound. WITNESSES: C\ -Je()~ ~. S{p{ If' /VI",.,r/r\ , nnifer . Stevenson ~ i = _ ~ ~i T0 & N ,."'>'" !! ""'" - ~" ~ tIllIIIIFlIlm~_~"" ,,~_,~" 0i. "q. p ~ ~6 d 0 (; '0 I 9 c.,O -;p~ Gr-,. J ~- [0 ~" ((; r:: ~~~(;. ~-'Cl C~ '7 ~ - (-:.) I::::.! ,~ "-l ::;..J (~ '~"i-~ --; ""--"g __c ;":'1 :;J .' CJ ....... " "'-> -'"I () CSrn -4 <> :'.0 -< " ~..;,,. ~-? co " ~~~fi!l!t~-;~"1f'..,,,.,.__ ~.dI!llIffilA~!liIlm~_~..~It!l~ \ JENNIFER S. STEVENSON, a/k/a JENNIFER S. MOOSE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW BOBBIE D. STEVENSON, Defendant NO. 00-2198 CIVIL TERM ORDER OF COURT AND NOW, this 31st day of March, 2003, upon consideration of Plaintiffs Petition for Emergency Relief, this matter is referred to the custody conciliation process pursuant to Cumberland County Rule of Procedure 1915.12-1, and the Court Administrator is requested to facilitate and expedite this referral. BY THE COURT, J. Susan M. Kadel, Esq. P.O. Box 650 Hershey, PA 17033 Attorney for Plaintiff Bobbie D. Stevenson 704 Erford Road Camp Hill, PA 17011 Defendant, Pro Se - ~~ '1~Of,03 ~ Cumberland County Court _ Administrator __ J.ud ~ . if/J/.3 ft-.<.../ :rc , " ,,' ":-~--''''-:'-'-~-';. '" ,~-~,---,- .,,-~- '.~-" - '\"'~ ,', , -, , r III[ -~,."' ~" ~ \lINV^l^SrIN3~, "1' .'1'"" .-J. <I\lnnl 1 p..lr'('j'~i ' ".jT; lr"~""!l,:::V { Iv f\..U\ ~". ',,' . I. ,'- ,./. ~'V .7 Li,J \ - ckr~ [0 tj.v'v .,u "" "(,\'~.,, I'" "bVl.....'J "'-:' ''''-~'~'~~'; :1','J_Ii',ui ,.1\1:1 .,.J\.)'-'- ',- .~~ ... ''''~' " ,:-jO ~~_"Il1!ll'lllllk ~""'M'Il, ,'" . _~!"1~ ";'':'"'-'''1''' JENNIFER S. STEVENSON, n/k!a JENNIFER S. MOOSE, Plaintiffi'Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ,V M,tR z 8 2003 VI. : No. 00-2198 BOBBIE D. STEVENSON, Defendant/Respondent : CIVIL ACTION - LAW : IN CUSTODY TEMPORARY ORDER OF COURT AND NOW, this day of , 2003, upon reviewing the attached Petition for Emergency Relief, it is hereby ORDERED AND DECREED that the Custody Order of June 13, 2000 be temporarily vacated. Jennifer S. Moose is granted legal and primary physical custody of the child. Respondent shall have supervised visits only pending further Order of Court, A hearing is scheduled for the day of , 2003, at .M., in Courtroom # _ of the Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT: J. -"i''?'_ >>,,",, "' ">"!"~".f"',""~i_->;,.'___._='1wr~"~',,,,, ,,"~,_ """~'7,_O~",""""~.,_,,. ""_'.-,,,'",,,,,_'.,,__.,,o,,~,,, ,~. " ,"-~,., '_'yo ~___~_"'>_'_,=,__. _,""" ",..,'__._ JENNIFER S. STEVENSON, n/k/a JENNIFER S. MOOSE, Plaintiff/Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 00-2198 BOBBIE D. STEVENSON, Defendant/Respondent : CIVIL ACTION - LAW : IN CUSTODY PETITION FOR EMERGENCY RELIEF AND NOW, comes the Petitioner, Jennifer S. Moose, by and through her counsel, Susan M. Kadel, Esquire, and avers as follows: 1. The Petitioner, Jennifer S. Moose (formerly Jennifer S. Stevenson), currently resides at 443 Shed Road, Newville, Pennsylvania, 17241. 2. The Respondent, Bobbie D. Stevenson, currently resides at 704 Erford Road, Camp Hill, Pennsylvania, 17011. 3. The parties are the parents of a minor child; Patricia M. Stevenson, born on October 9,1992, and who resides with the Petitioner. 4. The parties were divorced on September 30, 1998, by the Court of Common Pleas of Cumberland County. 5. On June 13, 2000, a Custody Order was entered by the Court of Common Pleas of Cumberland County. A true and correct copy ofthe Custody Order is attached hereto, incorporated herein, and marked as Exhibit "A". 6. A Petition for Modification of Custody Order was filed by the Petitioner, Jennifer S. Moose, contemporaneously with the filing of the within Petition for j~':0:~"""_'" '" -.' -:-":'r~"JW,~,,,_~Y. ,~,(.-"";:,,-~:~",,,,"--~,~" ,,~,,_,--, '>"-:"'~~_-"''''71'0'~, ,",",-~ _-_~"._, _.,--'{. , .~ rO.,,,--' . ...., .... , " - ,,','---- - "",'",,,", '_h_, "'>>""_" ",' ,_ _ _~",_,=. ~" ."__'__"_~:~" -",.-"",",-,--,,, '", Emergency Relief requesting that Respondent have supervised visitation only with the minor child. A custody conciliation conference has not yet been scheduled. 7. It has come to Petitioner's attention from a Patriot News article that the Respondent, Bobbie D. Stevenson, was arrested on March 21, 2003, at North Sixth and Schuylkill Streets in the city of Harrisburg by the Harrisburg City Police. He was charged with criminal attempt to possess crack cocaine and was arrested after he attempted to buy crack cocaine from a police officer posing as a street level drug dealer. A preliminary hearing is pending before District Justice James Pianka. A true and correct copy of the Patriot News article is attached hereto, incorporated herein, and marked Exhibit "BOO. 8. Defendant resides with his parents who are the child's grandparents. The child has indicated to Petitioner in recent months that during her weekends of custody with her father, they never stay overnight at the grandparents home, but rather, stay at various residences of friends of the Defendant. Petitioner is never advised as to the whereabouts of her daughter during the weekends with her father. Given the Respondent's recent drug arrest this behavior is of concern to the Petitioner. 9. Defendant has a prior criminal record and was previously incarcerated at the Cumberland County Prison having been sentenced on the charges of simple assault, resisting arrest, disorderly conduct and public drunkenness. He was incarcerated from November 23,1999 through April 12, 2000. 10. Petitioner believes that entry of an immediate Temporary Order providing for supervised visitation is necessary to protect the minor child and is in her best interest. I I l~ '_'0', , ,-J,Y{"c"!""."'}',,,",' '?!C;;-o/;'" ....,. ""--"",,,_,,"'~;~~--"i--, ........ '" '""?" ,'_W-7_-~ . :,,-'3"'_M:.. ..<. ,,,,-' m '.' :'" -, J'''-'- _e~_"~' "-,,--%CS":!J> .w .....,. . ~-,: , ",-'.,"" L",,'f.".,'- -,,-f " . "" WHEREFORE, your Petitioner, Jennifer S. Moose, requests that the Court enter a Temporary Order granting legal and primary physical custody of the child to her and directing that all visits with the Respondent be supervised pending further Order of Court. Respectfully submitted, Date: ~cu-.1 c;n :{oo5 ;' By G;~- Su , Esqui e ----. Attorney for Plaintiff, Jennifer S. Moose James, Smith, Dietterick & Connelly Post Office Box 650 Hershey,PA 17033 (717) 533-3280 P A J.D. No. 44837 .,t..''''_ "'7.- ~ o;,<,_"_,"_~< "''1,,'' ~",,", '~'"C"" ,~- . ,_,co "__'_-..J'_,"1~'~ .'.=., _ '.",<__.~' ._" ,d''''",,-0-',,~~ " -"'i -_ ., _, +",,;=~__, __"'__"_',~, ,~ . _ ~,~-'__ o. " ~-, , . VERIFICATION I, Jennifer S. Moose, verifY that the statements made in the foregoing Pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: 3/..<C.jo5 ~ 05. --m(J(P 0 o/ennifer . Moose '!..,.~.~."=._.k... ...,... ......,..,."..~.', ,u".~..,._.."._.. ,... ", .-, .......,..'......... '''' ~" .--. ~, < >~, ',~ -, ,-' ,-, '-"""."~'[ H<~ ,,-,,'1' Exhibit" A" '-"",''',n' ,,~," --. "' -~ '" ~." ~,---- ,-,. , JElNNIFE.R S. STEVENSON, : IN THE OOORT OF OOMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . . vs. . NO. 0D-2198 CIVIL TERM . : : CIVIL ACTION - LAW BOBBIE D. STEVENSON, : Defendant : CUSTODY OODER OF CXXlR'l' AND I!Di" I this [;3 consideration of the attached and directed as follows: day of Custody , 2000, upon it is ordered 1. The Mother, Jennifer S. Stevenson, and the Father, Bobbie D. Stevenson, shall have shared legal custody of Patricia M. Stevenson, born October 9, 1992. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all dec:isions regarding her health, education and religion. 2. The Mother shall have primary physical custody of the Child. 3. During the school year, the Father shall have partial physical CUSltody of the Child on alternating weekends from Friday at 5:30 p.m. through Sunday at 7:30 p.m. During the summer school break, the Father shaill have partial custody of the Child on alternating weekends from Friday at 7:15 a.m., when the Mother shall transport the Child to the Father's residence, through Monday morning, when the Father shall transport the Child to the surruner school program at Rice Elementary School. In addition, during the summer school break, the Father shall be entitled to have cus:tody of the Child for 2 additional overnight periods per month, with the specific dates and times to be arranged by agreement of the parties. The Father shall transport the Child to the surruner school program on weekdays when he has custody under this provision. The Father shall not schedule the 2 additional overnight periOdS ot custody to interfere with the Mother I s weekend periods of custody, unless otherwise agreed between the parties. 4. The parties shall share or alternate having custody of the Child on holidays as follows: ' A. ~: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 12:00 noon through Christmas Day at 2:00 p.m., and segment B, which shall run from Christmas Day at 2:00 p.m. through December 26 at 8:00 p.m. The Father shall have custody of the Child during Segment A in odd numbered years and during Segment B in even numbered years. The Mother shall have custody of the Child during Segment A in even numbered years and during Segment B T "'-~~ , -, ~ " . " . ~- in odd numbered years. B. ALTERNATING HOLIDAYS: The parties shall alternate having custody of the Child on the following holidays: Easter, Memorial Day, July 4th, Labor Day and Thanksgiving from 9:00 a.m. until 8:00 p.m. The alternating holiday schedule shall continue with the Mother having custody of the Child on July 4th in 2000. C. MO~"tIlSt{'S DAY/FMBER'S DAY: The Mother shall have custody of the Child every year on Mother's Day from 9:00 a.m. until 8:00 p.m. and the Father shall have custody of the Child every year on Father's Day from 9:00 a.m. until 8:00 p.m. D. 1he holiday custody schedule shall supersede and take precedence over the regular custody schedule. 5. Unless otherwise specified in this Order, the party rece~vmg custody shall be responsible to provide transportation for the exchange of custody . 6. Neither party shall use illegal drugs or consume alcohol during his or her periods of custody. 7. The Father shall ensure that all clothing sent with the Child by the Mother is returned to the Mother at the end of each period of custody. 8. 1his Order is entered pursuant to an agreement of, the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Oraer by llUJtual consent. In the absence of llUJtual consent, the terms of this Order shall control. BY THE OOURT, J. IS cc: John J. Connelly, Jr., Esquire - Counsel for Mother Robert L. O'Brien, Esquire - Counsel for Father T';" ,'^ ~_.,.."v """"'M REr'C I, ',-" " .t\.\..5 ~ In T.9si:n\:_'!",' to spt! nand . . rol~~~Jtj: '''--,~ '~~"'-'''',~Y'",__","",,,'-'_r i_. '''~', _C', ' ,,,~ -,'j' .-~ - JENNIFER S. STEVENSON, : IN TIlE OJURT OF OJMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. : NO. 00-2198 CIVIL TERM : : CIVIL ACTION - LAW BOBBIE D. STEVENSON, : Defendant . CUSTODY . CUS'lOOY CXECILIATICE SDMMARY REPCRT IN ACCXIIDANCE WITH CllMBBRLAND CXXJNTY RULE OF CIVIL Pku..:JsuuKE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CDRRENTLY IN COS'l'OlJY OF Patricia Stevenson October 9, 1992 Mother 2. A Conciliation COnference was held on June 7, 2000, with the following individuals in attendance: The Mother, Jennifer S. Stevenson, with her counsel, John J. COnnelly, Jr., Esquire, and the Father, Bobbie D. Stevenson, with his counseL Robert L. O'Brien, Esquire. 3. ~e parties agreed to entry of an Order in the form as attached. . ~ ~,~) Date tJ~ ~~ Dawn S. Sunday, Esquire Custody Conciliator '."'""w..,._,,. """"""'''-., ._, . ___~__ -f - ~"' .." .- -, . , ,,~~--. '. ~n:-' '_~"."'" d""",,',^'" _0 "..- ." "- ,.." Exhibit "B" -",. 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S .. ..... y,J, , ,:".q' a ".Q ..." .... a,:; . 0 Q 0 '" " u ... -:" , 0 !:l''''= p..v "ell '" ;,.,J::',..,,'~, Ej"" v iij.::l....<tllf! on 0 " ",,, .,:::l;! on. t::"" ~ ~~i~~jE~~~~lf~~ &il~~ ~ ~~zt~ 0; bQa.o~ o'o.~~.a s ~i5 ~ ~ ....O.ILI .tJ.Q.j'Q,l~~a""d:ul-l~~..!3='-t~o -S! tIp. ~k..c'2':1l-fiU~Q)~Cl.,4)g-- e Cti.~-S c: ~'~~.~'''5 ~i tf~~r~C4) a.~e,,-g]' ~ u,S'QUO. lUCf)....~OO-a ~u.t"'iICI,) / ./ . _ "~_'~"" "," .n ~" . JENNIFER S. STEVENSON, n/k/a JENNIFER S. MOOSE, PlaintifflPetitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA Vll. : No. 00-2198 BOBBIE D. STEVENSON, Defendant/Respondent : CIVIL ACTION - LAW : IN CUSTODY CERTIFICATE OF SERVICE I, Susan M. Kadel, Esquire, of James, Smith, Dietterick & Connelly, LLP attorney for the Petitioner, Jennifer S. Moose, hereby certif'y that I have served a copy of the foregoing Petition for Emergency Relief on the following on the date and in the manner indicated below: V.S MAIL. FIRST CLASS. PRE-PAID Bobbie D. Stevenson 704 Erford Road Camp Hill, PA 17011 James, Smith, Dietterick & Connelly DATE: <J /.;n 10..."\ BY~ Sus . adel, Esquire Attorney for Petitioner Post Office Box 650 Hershey,PA 17033 (717) 533-3280 P A J.D. No. 44837 t- " -,," """"" 'f,<'N:C'f-f,".--- - ~ ....... v-J " C\ )J ()< ~~ ~ 8 ~ f! oJ. \II _~_~ _, ,. C> f? 0 C ...~_J -'n Z -~ -CJijj "~ "-l '-"-"" _!-- QiiT1 :;tJ FQ .r.:--:'_1': ;-11 ::z ~~ N J~,9 (l> ...J -: -, t2C ~ ~-':} ~:;? 71"' /S:"-D :z. :',,,,:, :.>.C) :;;U :f:' ~') rn S;; ~ .... ~ -~ ~ - MlfIr>1"'~ ~ .~,7""""~ - ) '. JENNIFER S. STEVENSON, NIKIA JENNIFER S. IN TIlE COURT OF COMMON PLEAS OF MOOSE PLAINTIFF CUMBERLAND COUN1Y, PENNSYLVANIA V. 00-2198 CML ACTION LAW BOBBIE D. STEVENSON DEFENDANT IN CUSTODY . ORDER OF COURT AND NOW, Thursday, April 03, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 WestMatnStreet, Mechanicsbnrg,PA 17055 on Tuesday, April 29, 2003 at 1:00 PM 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 aud all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR TIIE COURT. By: Isl Dawn S. Sunday. Esq. Custody Conciliator C/ 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 HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE 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 -,;,;;"'11' . ' - ,.._._1 .,' --,,'., ;u_~iil:lMIilltQl!I_[!JlIaIU~li~!Ir _~$il>;\g!V"",*~06,,;.~ll!,l"'Ji!'~'l!Wilii_!l!;;MIIh"loili;M~_-w,~ ~ ~~~".~.' F!LF:D'.-C'iCf'iCF ro./:: T' ,," r-I~-"",'-' t,"" '::"'.-I'RY \..J : ,'-:'-' "; -' ~--, ",:UI,-\:+ ()::; APp -') I)"J ').,,~ ,w,t"h ," ,J ,j ,p lJ~ CU"II;,!", " -v'I" "Y JVW;::(l:"/"'\!\}U t.,'"Jt..h~1 PeNNSYLVANIA ~l3z)3 IIJ-OJ !f3 tJ,J s;t'&'~l':i!.::,,~lJ;,<_~ ",=,_ "~ .""-,'-''''"' ,,-.- '~"_'_'_~. ~",,,,._",_,,__,_>_ _='" . .""0< <_ _~'" '" . , _ J W-.~_~i;4~ ~ ~ :? d;fr< ~~;t4~ - " 'iIIllIIilLtll!Jb. ~ . '. JENNIFER S. STEVENSON, n/k/a JENNIFER S. MOOSE, PlaintifflPetitioner : IN THE COURT OF COMMON PLEAS ~ : CUMBERLAND COUNTY, PENNSYLVANIA : teA 282003 VI. : No. 00-2198 BOBBIE D. STEVENSON, Defendant/Respondent : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before, Esquire, the Conciliator, on the _ day of 4th Floor, Cumberland County Courthouse, 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 2003, at .M., at the Carlisle, Pennsylvania, for a Pre-Hearing 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 the entry of a temporary or permanent Order. Notification to the Defendant by the Prothonotary's Office is waived. For the Court, Date of Order: By Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 L~.,- '~'''c"f.~ '"",'__""~_'_~'" _ __ _ _' .. ,,-,,'H _"""""<'~_'-'"'_,.,h_,,, "",-, _;""'r"",,.~ ~, ~__ '-~ , ."'~"__ -, - -- ?" __" ~, "n_ _~___,_^~ .' .0,"" " " ..", , . I I I I I I I " ! I I I " Ii II I , I, " Ii Ii I~ I~ Ii II [I II E I' ':1 II I" Iii ':i I;, 1',1 " Iii b 1'1 iJ II II. " i' I i., I II " I I I i 11 Ii il JENNIFER S. STEVENSON, nlk/a JENNIFER S. MOOSE, PlaintifflPetitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 00-2198 BOBBIE D. STEVENSON, Defendant/Respondent : CIVIL ACTION - LAW : IN CUSTODY PETITION TO MODIFY EXISTING CUSTODY ORDER AND NOW COMES, Petitioner, Jennifer S. Moose, formerly known as Jennifer S. Stevenson, by and through her attorneys, James, Smith, Dietterick & Connelly, LLP, and Susan M. Kadel, Esquire, and files the following Petition to Modify Existing Custody Order and in support thereof, respectfully represents as follows: I. Petitioner, Jennifer S. Moose, formerly Jennifer S. Stevenson, respectfully represents that on June 13, 2000, and Order of Court was entered for custody of the parties' daughter, PatriciaM. Stevenson, born October 9,1992. A true and correct copy of the Order is attached hereto, incorporated herein, and marked Exhibit "A". 2. The Order provided, inter alia, that Plaintiff, Jennifer S. Moose, would have primary physical custody of the child and that the Defendant, Bobbie D. Stevenson, would have partial physical custody of the child on alternating weekends from Friday at 5:30 p.m. through Sunday at 7:30 p.m. 3. The Petitioner, Jennifer S. Moose, believes and therefore avers, that the Order should be modified for the following reasons: A. On March 21,2003, the Defendant, Bobbie D. Stevenson, was arrested by the Harrisburg City Police and charged with criminal attempt to possess crack "_7.0. '-_-""'f-,~- _'_;.,,,,~,.,.~_,,,, ._,., _~""" _. ~ O_7'''''.,_'~''' ""';."'."""C- _,'" -.~ - -_.".,-'---- at[ - II II " II rl " II 'I ~ j " ;j ;.1 tl Ii I l] :1 II 1:1 :,! :~ ',) ::1 I 'I ':i ~ ) ::i I :'! 1 :: "; :! i 'I J ,I I! ,~, ~ ><", ~.- '. . cocaine. He was arrested after he tried to buy crack cocaine from a police officer posing as a street level drug dealer. A true and correct copy of the Patriot News article identifying Mr. Steveoson's arrest is attached hereto, incorporated herein, and marked Exhibit "BOO. B. The Defendant, Bobbie D. Stevenson, resides with his parents. For the past several months, the child has been reporting to her mother that they do not spend the weekend when she is in custody with her father at her grandparent's home, but rather, they spend nights at various friends' homes. C. The Petitioner, Jennifer S. Moose, is never notified as to the whereabouts of her daughter during Defendant's weekend visitation. Given the Defendant's recent drug arrest, Petitioner has concerns over the residences where the child may be staying during his periods of custody. WHEREFORE, Petitioner, Jennifer S. Moose requests that the Court modify the existing Order for Custody to provide for supervised visitation for Bobbie D. Stevenson as it will be in the best interest of the child. Respectfully submitted, Date: .6 /,x7 /0-3 BY~~_ . ddel, Esquire Attorney for Plaintiff, Jennifer S. Moose James, Smith, Dietterick & Connelly Post Office Box 650 Hershey, P A 17033 (717) 533-3280 P A J.D. No. 44837 _" . ,~ "., LO<.' __._,_ .,.-. ._~- .__. "n 0.. r I I I i I I I I I I I i " I II I, Ii "I I ,I ii " li II l! Ii , Ii II !! " 'I II " 'I II. l, II f'j ~.! 11 II ,I H '1 ',I "I " i:i "j :,1 q [I ,:j ,I : ~ u n II , ~ ' , J ." "I ;'1 " e< n iI l~i fA " [1 '1 k...""."..,. . VERIFICATION I, Jennifer S. Moose, verifY that the statements made in the foregoing Pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: S! A. (, !a"!:, ',_ ." _,,,, ." "~8~_'_~_, > _"""I __~," ~__,^ ~__~_ ~"_. ,'~, c_; _ .",' "",",~"'N ~~~_ {Ylccrfl ennifer . Moose _,."~",,.,.,_^_" --,,",~ --'~.,,-o". ,f.."'''''''','o_''''''''.~_~_____''' <""-' .,., " il :i ~1I '1,<'><,,"_~'" ' ,~",__ . --"" ,- "T , " ,_~,~_,""-~ .'. -V-~- "' Exhibit" A" r,__ '. "-"c. . ' ". , JENNIFER S. STEVENSON, : IN THE aJURT OF aJMMON PLEAS OF plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-2198 CIVIL TERM . . . CIVIL ACTION - LAW . BOBBIE D. STEVENSON , : Defendant : CUSTODY OODER OF CXXlRT AND lOf, this /",3 cOl1lsideration of the attached amil directed as follows: day of CUstody , 2000, upon it is ordered 1. The Mother, Jennifer S. stevenson, and the Father, Bobbie D. Ste,venson, shall have shared legal custody of Patricia M. stevenson, born October 9, 1992. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the O1ild's general well-being including, but not limited to, all decisions regarding her health, education and religion. 2. The Mother shall have primary physical custody of the Child. :j I, II ,I I' Ji :1 :1 3. DUring the school year, the Father shall have partial physical custody of the O1ild on alternating weekends from Friday at 5:30 p.m. through sunday at 7:30 p.m. During the summer school break, the Father shall have partial custody of the O1ild on alternating weekends from Friday at 7:15 a.m., when the Mother shall transport the Child to the Father's residence, through Monday morning, when the Father shall transport the Child to the sunmer school program at Rice Elementary School. In addition, during the summer school break, the Father shall be entitled to have custody of the Child for 2 additional overnight periods per month, with the specific dates and times to be arranged by agreement of the parties. The Father shall transport the Child to the summer school program on weekdays when he hall custody under this provision. The Father shall not schedule the 2 additional overnight periods of custody to interfere with the Mother's weekend periods of custody, unless otherwise agreed between the parties. :1 ,I i :~ :1 '1 I :1 :1 , 4. The parties shall share or alternate having custody of the O1ild on holidays as follows: I A. CIIRIS'.l'MAS: The Christmas holiday shall be divided into Segment A, which shall run frem O1ristmas Eve at 12:00 noon through Christmas Day at 2:00 p.m., and Segment B, which shall run from Christmas Day at 2:00 p.m. through December 26 at 8:00 p.m. The Father shall have custody of the Child during Segment A in odd numbered years and during Segment B in even mnnbered years. The Mother shall have custody of the Child during Segment A in even numbered years and during Segment B I, :i! "I '1 I '1 'I i~ 'i :i 'jil1!I1!1.,. ,',' -"". -',' '. in odd numbered years. B. ALTERNATING HOLIDAYS: The parties shall alternate having custody of the' Child on the following holidays: Easter, Memorial Day, July 4th, Labor Day and Thanksgiving from 9:00 a.m. until 8:00 p.m. The alternating holiday schedule shall continue with the Mother having custody of the Child on July 4th in 2000. c. MO'.L"WSK'S DAY/FATfIER'S DAY: The Mother shall have custody of the Child every year on Mother's Day fran 9:00 a.m. until 8:00 p.m. and the Father shall have custody of the Child every year on Father's Day from 9:00 a.m. until 8:00 p.m. D. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 5. Unless otherwise specified in this Order, the party rece~VJ.ng custody shall be responsible to provide transportation for the exchange of custody. ,[ 'I !I I I ,! !I I I 'I " 6. Neither party shall use illegal drugs or consume alcohol during his or her periods of custody. 7. The Father shall ensure that all clothing sent with the Child by the Mother is returned to the Mother at the end of each period of custody. 8. lhis Order is entered pursuant to an agreement of the parties at a Custody conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE OJURT, J. IS 'j I , ! ~ j :J cc: John J. Connelly, Jr., Esquire - COunsel for Mother Robert L. O'Brien, Esquire - COunsel for Father 5 Te',"'" r-',",,, FI:>'"'M RECC" "', I- " ,.' ,. B""V - il \. nand -,I ! J I . ~l .,~ - ".," t"' .c..r -",.. "'.~ ,,'~ , . JENNIFER S. STEVENSON, : IN THE CDURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-2198 CIVIL TERM : : CIVIL ACTION - LAW BOBBIE D. STEVENSON , : Defendant : CUSTODY CUS'ltlDY cx:tiCILIATIW SDMMARY REPCR:r IN ACCXIU>ANCE WITH CUMBERLAND CXXJNTY ROLE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRBNTLY IN CUSTOu% OF patricia Stevenson October 9, 1992 Mother 2. A Conciliation Conference was held on June 7, 2000, with the following individuals in attendance: TIle Mother, Jennifer S. Stevenson, with her counsel, John J. Connelly, Jr., Esquire, and the Father, Bobbie D. Stevenson, with his counsel, Robert L. O'Brien, Esquire. 3. 1he parties agreed to entry of an Order in the form as attached. J : -I -1 ~ ~,~) Date 'L~ Dawn s. Sunday, Esquire Custody Conciliator ! ""';m""'" '" _' ~~,_~__, '''''':''"r,'''-'''''': ,~ ,j.,," ~. ~-___"'_"""'_"."" ~-'f--'-, ,n , -,--q" "-", -p ",-- , ~, "'''' U.' ;;:, .=_ "__,".. '~",. _$,,_ Exhibit "B" h"' . ". '~ ~ r:rr " rJj' Ci o U " " Ii .... r:J'j, CD 2 '"0 >-." = ~,' o ~ CD S I'~C -+-I. ~". o ~ '~. 0)' ~ rJj \' 0) ~' ;. ctt ~]~ ';! ,~ ' -~ ,-~,.- ~'-',- .,,, "'""'~~?'-~'~-- ,,,._,-- "" ". ]' t:" .;::" . . - '" ~ , "A' :t:1oI, . ~ ~,ri' J'~~ "'0:..0 .-", " "', aJ bl30.. "g. s:: ILl , .r'S ~" ~ V'~ ~O'..d 8 fi'f' Cl' :1', '" - ~'..' 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CCcnoul:l. \'l:Jo':i:ltn, C .. ol'n.~ u otjZ,E: o~ ~ ~D.4'i ~. '0"- -<! ~~""..g,..." ~,<l"'iil9". '" ;:go o '5 lU a lU"ea ~ t: ~ f:-t I1.l u '8 ~ "ti iU . ~ ~ ~~zl~ot';bQ3od~O'o..~~.stu~g~ ~ .... O' t.J Q,j. ~~ l1.I U '""~ ~ !:t- 'i-o'- 0 ~ 1IJQ,,1l '~t~"2.~'t"'d..w8.~"S.4)~..c- e ~.~:SCl~~f-<~'tlfr, ~~'lSfI\JS.~(;!g] ! uB.ouu. u~~wuo~ !U.NOO "_""e:",< ~,_, ,"~ //" . " .' JENNIFER S. STEVENSON, nlk/a JENNIFER S. MOOSE, Plaintiff/Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V1!. : No. 00-2198 BOBBIE D. STEVENSON, Defendant/Respondent : CIVIL ACTION - LAW : IN CUSTODY CERTIFICATE OF SERVICE I, Susan M. Kadel, Esquire, of James, Smith, Dietterick & Connelly, LLP attorney for the Petitioner, Jennifer S. Moose, hereby certifY that I have served a copy of the foregoing Petition to ModifY Existing Custody Order on the following on the date and in the manner indicated below: D.S MAIL. FIRST CLASS. PRE-PAID :j :1 I, I " ~ ! , , !j 'j ii : ~ r~ I ~ j Bobbie D. Stevenson 704 Erford Road Camp Hill, P A 17011 James, Smith, Dietterick & Connelly DATE: ~ J~7105 , ] IJ : ~ ;f By: Susan el, Esquire Attorney for Petitioner Post Office Box 650 Hershey, P A 17033 (717) 533-3280 P A J.D. No. 44837 " ;; ; ~ rJ I ',~ ; ~ .. '~ -,. ^". ,~:',;':', """""- ,en,-", _!.'_",", "~,,,,"'__ _~m. LO, '" ,",,__o,.,,~,,^=~ ,~~ ,>, , ",~,(;---,-", ;--'._,.'IV.,5 . ,'" ~ ,,'~- ". ~ .,. .. ..,.~, "e, c" -.' .' ~-'- , ".",. . " > <~'-, tf~ ~ g is -V OJ - tt.J f' ~ ''''-'-' '~'!"'1!'~ "<' .< '" _~_~ ._, r. ","__~ ,.._ ,_~ '.' I,. . .1"'""'Lo.\r....'fg)'. o c c~ """ -or-I,} r'O(\"" '"';r'T''! zf':' ~df:'::' ~r;~ ,~ .. " ~(- $-) C Z :t -..,.~<.,^-, o <-.) :J: ):,:'':1> c..o i".,' -' o ~n .." '~l- fTi-:J I' ,-- -or'--I :;C;:J 'lc-J ---'('.::)~': c;'('j 9,1''11 2'" ::I -"D w .. lII!! JA02004 BOBBIE D. STEVENSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 00-2198 CIVIL ACTION LAW JENNIFER S. STEVENSON Defendant IN CUSTODY ORDER OF COURT AND NOW, this 22'"1 J day of J 2. ~u 2) ':L , 2004, upon consideration of the attached Custody Conciliation Report, it is ordered\illd directed as follows: 1. The prior Orders of this Court dated June13, 2000 and May 2003 are vacated and replaced with this Order. 2. The Mother, Jennifer S. Moose (Stevenson), and the Father, Bobbie D. Stevenson, shall have shared legal custody of Patricia M. Stevenson, born October 9, 1992. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to aU records and information pertaining to the Child including, but not limited to, school and medical records and information. 3. The parties agree to continue their course of co-parenting counseling with Deborah Snelson. The Father shall contact the counselor promptly to schedule a date for the next session. Each party shall be responsible to pay one-half of any costs which are not covered by insurance. 4. The Father shall submit himselfto a drug test which shall be scheduled within two weeks after the conciliation conference by the Mother. Upon notification from the Mother, the Father shall have the testing conducted within twenty-four hours. The parties shall equally share the costs of the drug testing, which shall not exceed a total of$lOO.OO. The test results shall be shared between the parties promptly. 5. The Mother shall have primary physical custody of the Child. '~*;~. "' _ _ "-" '~,'" "'I'r' - ." - , " ~, ~ ~ . ., >"" " "n, ","eo, """," V\\\j\//\\FS\]\!Jd ~'N'I'r"~ ,->,r"''''''-''l~'' I I'll J I t, ,',: ',:, ", "-:""~ \1 \ i " 1 _ ""',, ,., ,...,,' llV S I : I I,lel :::2 rn:f ~OOZ l' "I ,'," '1""1"'01 . -, 11 :l() f\d\l.t,\JN-.A1 ly 0 :j~~ \~ 381:H.o..O:n\:j .' P ''', r,_~,,,," ,.~~__"__","~,,,_ _,'"",,~ -~~ __""'_IJII'l!!lO~~~' , _ _' ._ __, . c ~ _ L_"," _ ~~ - ~~, "',,~ -. ", '-""iijj .~IYf~_"",.._, ~"~J' .. ._",~~iiF 6. The Father shall have partial physical custody of the Child as follows: A. Until such time as a negative drug test result is received by the parties, the Father shall have partial physical custody of the Child every Sunday from 8:00 am until 7:30 pm. The Mother shall be entitled to reschedule the Father's period of weekend custody to Saturday for the same duration upon providing the Father with one week advance notice. B. Beginning on the first weekend following receipt of a negative drug test result, the Father shall have partial physical custody of the Child on alternating weekends from Friday after school through Sunday at 7:30 pm and every Wednesday from after school until 8:00 pm. In addition, the Father shall be entitled to have custody of the Child for two non-consecutive weeks during each summer school break under this provision upon providing at least 30 days advance notice to the Mother. The Father's one week periods of custody shall be scheduled to include the Father's regular alternating weekend. 7. The parties shall share or alternate having custody of the Child on holidays as follows: A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 12:00 noon through Christmas Day at 2:00 pm, and Segment B, which shall run from Christmas Day at 2:00 pm through December 26 at 8:00 pm. The Father shall have custody of the Child during Segment A in odd numbered years and Segment B in even numbered years. The Mother shall have custody of the Child during Segment A in even numbered years and during Segment B in odd numbered years. 'i I I B. ALTERNATING HOLIDAYS: The parties shall alternate having custody of the Child on the following holidays: Easter, Memorial Day, July 4th, Labor Day and Thanksgiving from 9:00 am until 8:00 pm. The alternating holiday schedule shall begin with the Father having custody of the Child on Easter in 2004. i :[ C. MOTHER'S DAY / FATHER'S DAY: The Mother shall have custody of the Child every year on Mother's Day from 9:00 am until 8:00 pm and the Father shall have custody ofthe child every year on Father's Day from 9:00 am until 8:00 pm. J I I I I ,! D. The holiday custody schedule shall supercede and take precedence over the regular custody schedule. 8. The party receiving custody shall be responsible to provide transportation for the exchange of custody. 9. Neither party shall use illegal drugs or consume alcohol during his or her periods of custody. j J I "'C"!E:IIl!lf^ .---, -~ ~ 10. The parties shall ensure that all clothing sent with the Child to the other parent for periods of custody is returned to the parent at the end of each period of custody. II. Neither party shall do or say anything which may estrange the Child from the other parent, i~dure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Child comply with this provision. 12. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, J. ,Wesley Oler, J . (! v cc:v1:usan M. Kadel, Esquire - Counsel for Mother ~bbie D. Stevenson - Father · !~uL O/.J..3-o'l '-"J? - - BOBBIE D. STEVENSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 00-2198 CNIL ACTION LAW JENNIFER S. STEVENSON Defendant IN CUSTODY Prior Judge: J. Wesley Oler Jr. 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 Child who is the subject of this litigation is as fi}llows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Patricia M. Stevenson October 9,1992 Mother 2. A Conciliation Conference was held on January 14, 2004, with the following individuals in attendance: The Mother, Jennifer S. Moose (Stevenson), and the Father, Bobbie D. Stevenson. The Mother is represented in this matter by Susan M. Kadel, Esquire although the Mother's counsel did not attend the conference. The Father is not represented by counseL 3. The parties agreed to entry of an Order in the form as attached. J~ Date {s-: ;).00 <j . {l<-~b Dawn S. Sunday, Esquire Custody Conciliator ,'\:",~....... <. - -~<"~ ,"-" 4 - '_'_~,", _.,-_ .",~~-- .. .. JENNIFER S. STEVENSON N/KJ A JENNIFER S. MOOSE PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 00-2198 CIVIL ACTION LAW BOBBIE D. STEVENSON DEFENDANT IN CUSTODY ii , 'I " .1 " 'I I I, iI " ;j 'I 1 ;1 '. il :1 I fj ORDER OF COURT AND NOW, Wednesday, March 29, 2006 , upon consideration of the attached Complaint, II :1 Ii i it is h(:reby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, FA 17055 on Thursday, April 27, 2006 at 11:30 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 mav provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish auy and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearin2. FOR THE COURT. By: /s/ Dawn S. Sunday, Esq. Custody Conciliator tDl- The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For infonnation 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. Y Oll 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 (7]7) 249-3166 "" , .< " =-1 i';''''''~_~r _ ' iili9Jlj;$JlW!iDMl!<!IIl!iMliIill!i~~___i _ ~j;.Ji!~~Will~liilKiiII~"" _li~_'" .. ,. i!"\II~IIL,,, N ~_ __~~., "~ _.~ ~~rl~ri_ ~?! FlLED-O,cFj0r: OF THE PW'T,U0:-::j"^TArlV '-', 1,_c!'-U1l'lf"I. 20a6 MAR 30 PN 2: 30 cu!v;::,cc I '\..'~,i-~:~/~,,;"iL,,' ':~-:ULJ1\JT'\f Pr:.i\/i\I0\,/L\le\;)l'l - - ! "'I'\:.',r..l, JJO-CJ6 tJd,.~~t;-.4~ 330'?Jt. ~ M~ Z ~( /H~ 3;]o.~b ~ ~ ~ .ar~d - ,""_'-0_' ~ ~. ._- ........ """""""; ~ , . ";'0"'"~ .' R.JECEIVED MM 2 8 l006 S BY: IN THE COURT OF COMM N OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER S. STEVENSON, N/KIA JENNIFER S. MOOSE Original Plaintiff and current Respondent vs. NO. 00-2198 TERM BOBBIE D. STEVENSON, Original Defendant and current Petitioner CIVIL ACTION - LAW CUSTODY ORDER OF COURT You, Jennifer S. Moose, Respondent, have been sued in Court to modify custody, partial custody or visitation of the child: Patrishia M. Stevenson. AND NOW, this day of , 2006, upon consideration of the attached petition, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at on the day of , 2006, at a.m./p.m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or ifthis 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 for custody, partial custody or visitation or the Court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Page I of 4 ~ *'-' ~ , ~,.... - ,", 'fe, ,~"" .' CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, P A 17013 (717) 249-3166 (800)990-9108 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. FOR THE COURT Page 2 of 4 ..." ~ " - , ~ . .' JENNIFER S. STEVENSON, N/K/A JENNIFER S, MOOSE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Original Plaintiff and current Respondent vs. NO. 00-2198 TERM BOBBIE D. STEVENSON, Original Defendant and current Petitioner CIVIL ACTION - LAW CUSTODY PETITION FOR MODIFICATION OF A CUSTODY ORDER I. The Petitioner is Bobbie D. Stevenson and he resides at 603 Arnold Street, Apt. 4, Glenrock, Wyoming 82637. 2. The Respondent is Jennifer S. Moose and she resides at 433 Shed Road, Newville, PA 17241. 3. Bobbie D. Stevenson is the Father of the minor child, Patrishia M. Stevenson. 4. Jennifer S. Moose is the Mother of the minor child, Patrishia M. Stevenson. 5, On May 6,2003 an Order of Court was entered for partial custody ofPatrishia M. Stevenson. A copy of that Order is attached hereto as Exhibit "A". 6. Petitioner seeks primary physical and shared legal custody ofthe minor child Patrishia M. Stevenson who currently resides with Mother. 7, The current Custody Order should be modified to provide Father with primary physical custody because the minor child will be happier living with Father and Father can provide daughter with a more positive living environment then Mother. Page 3 of 4 ,-"1I4~J_, <~= ,....,""' ~~~ ,~, ~ . , . WHEREFORE, Father requests the Court modify the existing Order and grant him primary physical custody ofPatrishia M. Stevenson and shared legal custody. YOFFE & YOFFE, P,C, By ~~7!I. t7 J effi ey N. Y offe, Esq. Attorney for Father 214 Senate Avenue, Suite 404 Camp Hill, P A 17011 (717) 975-1838 Attorney ID No. 52933 jyoffe@verizon.net Page 4 of 4 ~,r~i* .-r . "~ - ~-~..... " .. ",,- r ' Original Plaintiff and current Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER S. MOOSE VS. NO. 00-2198 TERM BOBBIE D. STEVENSON, Original Defendant and current Petitioner CIVIL ACTION - LAW CUSTODY VERIFICATION I hereby state that I am an adult individual who is authorized to make this verification and that the facts set forth in the foregoing Petition are true to the best of my knowledge, infonnation, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~904 relating to unsworn falsification to authorities. Dated: :3 j/:fc b 4:~~ '?1l 0 , , - ~ t- ., v~ , c u .1 ~ ", . " JENNIFER S. STEVENSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 00-2198 CIVIL ACTION LAW BOBBIE D. STEVENSON Defendant IN CUSTODY ORDER OF COURT AND NOW, this ---I:Jt..- day of VW, "'1 , 2003, 1.!pon consideration of the attached Custody Conciliation Report, it~d and directed as follows: I. Pending further Order of Court or agreement of the parties the partial physical custody schedule set forth in paragraph 3 of the prior Order ofthis Court dated June 13, 2000 is temporarily suspended and replaced with this Order. All other provisions of the prior Order shall continue in effect. 2. The parties shall participate in a course of coparenting counseling with a professional participating in the Mother's insurance program or other professional selected by agreement ofthe parties. The purpose of the counseling shall be to assist the parties in developing sufficient communication and cooperation to enable them to effectively coparent their Child. The parties shall participate in a minimum of four joint counseling sessions and thereafter shall follow the recommendations of the counselor with respect to the duration and frequency of counseling. Each party shall be responsible to pay one half of any costs which are not paid by insurance coverage. 3. The Father shall have partial physical custody of the Child every Sunday from 8:00 am until 7:30 pm, beginning May 4,2003. The Mother shall be entitled to reschedule the Father's period of weekend custody to Saturday (rather than Sunday) for the same duration upon providing the Father with one week advance notice. 4. Within three months of completion of the course of coparenting counseling, counsel for either party or a party pro se may contact the conciliator to schedule an additional custody conciliation conference, if necessary. rf'CUE COPY FROM ftECOHu 'n TIItiIMRy whereGI. ,......UI\tD set my lwld ,'d the .. If sald Court aa CalIIsII. PI. I., let' ~ .. ~;A~~' ~(9~i- . f'''''O PI. , ProtlloliGllr' BY THE COURT, ;)/c.v J cc: Susan M. Kadel, Esquire - Counsel for Mother Bobbie D. Stevenson, Father , "Lb1.L.d ,/fv1.-(IJ...L '-'J~-- ~J~ of ,0..:; 9-,. EXHIBIT "A" ;"'9,-<",," . ~"~"'^' N> . ~ % "' ,'" . . '. " , A.J ("::) "ig. 1ft 59 ti- ...., D (') = 0 c = "TI ~ '< 0" ..... G.; 0~;~"( ::r. :r ~ J;:~ nl~ ~ -J -:;....-.'-.-- :;;0 -om (7. N ::DCJ C) ~ f- " -.l Ql , r(-' ~ - ,. '1 ;Do ." '.-n --.0 ::c: (:)('") P- C, Orn C 9 ;i:: s;J :~2 '" :n -J:- .< ;//;' ,'7 'J f ~-. -~-,--,~; .V c ~,.- .~l~il$tJlI~[W~~~~~~I~~~ --!"'" ;,,"'!'M 'BY"-" T"-"_',", l"t"'-"'I~..--.~--";" ~ I ~-,.: --';'{ '-~'''.'-'::V~~ ).. ~__4-,----",. d_c ' .__J;___ : JENNIFER S. STEVENSON N/KJ A JENNIFER S. MOOSE Plaintiff MAY 0 4: 2006 !BY:_V J IN THE COURT OF COMMON PLEAS OF ..- CUMBERLAND COUNTY, PENNSYLVANIA vs. 00-2198 CIVIL ACTION LAW BOBBIE D. STEVENSON Defendant IN CUSTODY ORDER OF COURT AND NOW, this -----1t1.-- day of fV1r~ ' 2006, upon consideration of the attached Custody Conciliation Report, it is or&ered and directed as follows: I. The prior Order of this Court entered in January 2004 shall continue in effect as modified by this Order. 2. The Father shall have partial physical custody of the Child in Wyoming for a two-week p,eriod beginning on June 26, 2006. The parties agree that in the event the Child wishes to stay with the Father for an additional period during the summer school break, the parties shall make alTangements by agreement for the Child to either return to Pennsylvania with her grandparents in mid- August or return earlier by air transportation to Pennsylvania. The Father shall be responsible to pay the costs ofthe Child's airfare from Texas (where the Mother and the Child will be visiting on June 26, 21006) to Wyoming and, from Wyoming to Pennsylvania two weeks later or at a subsequent date if the Child is departing from Wyoming prior to her grandparents' departure. 3. The Father's period of custody with the Child during the summer 2006 as provided in the pJreceding paragraph is conditioned upon the Father providing to the Mother the Father's residential address and telephone number, cell phone number and employment telephone number. Neither party shall use telephone contact information in a harassing or abusive manner. 4. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. cc: ~frey N. Y offe, Esquire - Counsel for F .l.tennifer S. Moose, Mother . ~ BY THE COURT, -'iP1 ~ .T "1" I ~ o ~5 t.J_ :r: "--~ @ff o:iE t5 '~ '" _1IIfIIIl N ~ ::> .q:. 0- O~ ".::':i c_'>oc ~W, ::JZ r::Z '_UUJ coo- ::l: :::J (.) N :lit: a... tn I >- <d: E ..." = = "" """""'U."'..""'7" "~, ,.' '~-~ fl"'...... 1 iJ9-j){ - .. " - .,->",,-~-~~~ ,p.- , _~_'~~I!!-"f'" :!' ~~_,m~,-- . - ._-'\t.Ef~"i<~r ..... '. ~=~,.,..~-Il'l'.l!II'lt ~.~ r"~-,,-' lL''i'tc'ciXs,. . JENNIFER S. STEVENSON N/K1 A JENNIFER S. MOOSE Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 00-2198 CIVIL ACTION LAW BOBBIE D. STEVENSON Defendant IN CUSTODY Prior Judge: J. Wesley Oler, Jr. 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 Child who is the subject of this litigation is as follows: ,NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Patrishia M. Stevenson October 9, 1992 Mother 2. A custody conciliation conference was held on April 27, 2006, with the following individuals in attendance: The Mother, Jennifer S. Moose (formerly Stevenson), who was not represented by counsel, and the Father's counsel, Jeffrey N. Yoffe, Esquire. The Father, Bobbie D. Stevenson, resides in Wyoming and participated in the conference by telephone. 3. The parties agreed to entry of an Order in the form as attached. Date/11.o.;J / eJoot, . I Dawn~~dad~ui~ Custody Conciliator ;i: _, ~" _ ~_ , d_ -,.-- , ~ , , . , ~ ;Yo. 02(){)Q- ;;/9f- civil +u"" Sf e.v U 56 r1. VS [0 Mfla.IY1+ 0-11 '/lli"J" o..rt:. StevC-vtSGA C J..s1()o!.. f -l-. OJ -01 7-02 ()cJ 0 lrior I 0 /ltl-t Sc:Ci A. II ed . JENNIFER S. STEVENSON, N/KJA JENNIFER S MOOSE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Original Plaintiff and current Respondent vs. NO. 00-2198 TERM BOBBIE D. STEVENSON, Original Defendant and current Petitioner CIVIL ACTION - LAW CUSTODY PETITION FOR MODIFICATION OF A CUSTODY ORDER 1. The Petitioner is Bobbie D. Stevenson and he resides at 603 Arnold Street, Apt. 4, Glenrock, Wyoming 82637. 2. The Respondent is Jennifer S. Moose and she resides at 433 Shed Road, Newville, P A I 7241. 3. Bobbie D. Stevenson is the Father of the minor child, Patrishia M. Stevenson. 4. Jennifer S Moose is the Mother of the minor child, Patrishia M. Stevenson. 5. On May 6,2003 an Order of Court was entered for partial custody ofPatrishia M. Stevenson. A copy of that Order is attached hereto as Exhibit" A". 6. Petitioner seeks primary physical and shared legal custody of the minor child Patrishia M. Stevenson who currently resides with Mother. 7. The current Custody Order should be modified to provide Father with primary physical custody because the minor child will be happier living with Father and Father can provide daughter with a more positive living environment then Mother. Page 3 of 4 I , . WHEREFORE, Father requests the Court modify the existing Order and grant him primary physical custody ofPatrishia M. Stevenson and shared legal custody. YOFFE & YOFFE, PC BY~fIlJ/i t7 Jeffi ey N. Yoffe, Esq. Attorney for Father 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 )yoffe@verizon.net Page 4 of 4 ~. -. Original Plaintiff and current Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER S. MOOSE vs. NO. 00-2198 TERM BOBBIE D. STEVENSON, Original Defendant and current Petitioner CIVIL ACTION - LAW CUSTODY VERIFICA nON I hereby state that I am an adult individual who is authorized to make this verification and that the facts set forth in the foregoing Petition are true to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. Dated: :3 //:(0 G ~~? JENNIFER S. STEVENSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 00-2198 CIVIL ACTION LAW BOBBIE D. STEVENSON Defendant IN CUSTODY ORDER OF COURT AND NOW, this ~ day of M 7 , , 2003, upon consideration of the attached Custody Conciliation Report, it~d and directed as follows: 1. Pending further Order of Court or agreement of the parties the partial physical custody schedule set forth in paragraph 3 of the prior Order of this Court dated June 13,2000 is temporarily suspended and replaced with this Order. All other provisions of the prior Order shall continue in effect. 2, The parties shall participate in a course of coparenting counseling with a professional participating in the Mother's insurance program or other professional selected by agreement of the parties, The purpose ofthe counseling shall be to assist the parties in developing sufficient communication and cooperation to enable them to effectively coparent their Child, The parties shall participate in a minimum of four joint counseling sessions and thereafter shall follow the recommendations of the counselor with respect to the duration and frequency of counseling. Each party shall be responsible to pay one half of any costs which are not paid by insurance coverage. 3. The Father shall have partial physical custody of the Child every Sunday from 8:00 am until 7:30 pm, beginning May 4,2003. The Mother shall be entitled to reschedule the Father's period of weekend custody to Saturday (rather than Sunday) for the same duration upon providing the Father with one week advance notice. 4. Within three months of completion of the course of coparenting counseling, counsel for either party or a party pro se may contact the conciliator to schedule an additional custody conciliation conference, if necessary, rf1uE COPY FROM RECOHlJ In TIItinloRy whereaI. I here unto SlIt my UAd .'(j the -' If said Court at CilIGII. PI.. IniI /1r:' ~~ II '7fl;A~~' ~b~~ . ;Ld .0 n., PI. . , ProttIonollr4 BY THE COURT, tl/C-t/ cc: Susan M. Kadel, Esquire - Counsel for Mother Bobbie D. Stevenson, Father /~.u> , /h~--C ,:). () f ,0.3 9-" EXHIBIT" A" ;v ~ ~ ~ ~ \) ~~ -- Lv tI -n ...:t .--< c i~-~~~ " ~ -J :;:) \) ~ f- ;.....) :::~~ ~ _l i (~ , --0 .. . E ->- ,.)' ;-.\ ~ r,) :iJ .-<: , '. JENNIFER S. STEVENSON N/K/A JENNIFER S. MOOSE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 00-2198 CIVILACTIONLAW BOBBIE D, STEVENSON DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, March 29, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 170~~ on ,. TJ1ursday, April 27, 2006 at 11 :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 mav 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 hearin\!,. FOR THE COURT. By:~_. Dawn S,..Sundav. Esq. ..-b!l-- 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 HA VE 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 Telephooe (7 J 7) 249-3166 I: ,"" 1/ ,crt ~ 1#, "Jol r r~ t. I'i'"'w ""';; -'Jl,ll , r;;;J; $P' / f7{'"" 4I.t, ,p'! qrJJ! { ~.<<''':CJ rr .-; \ ,)Go'V · 0,:' '''\''11 ~.J ("." '~ :lD I :;t~,<:~~\1:?:9 : JENNIFER S. STEVENSON N/K/ A JENNIFER S. MOOSE Plaintiff MAY 0 4 2006 J' BY:~ .._~_._--- '"'- IN THE COURT OF COMMON PLEAS OF '" CUMBERLAND COUNTY, PENNSYLVANIA vs. 00-2198 CNIL ACTION LAW BOBBIE D. STEVENSON Defendant IN CUSTODY ORDER OF COURT AND NOW, this ---1t1- day of (1.1,,;>~ ' 2006, upon consideration of the attached Custody Conciliation Report, it is or ered and dIrected as follows: 1. The prior Order of this Court entered in January 2004 shall continue in effect as modified by this Order. 2. The Father shall have partial physical custody ofthe Child in Wyoming for a two-week period beginning on June 26, 2006. The parties agree that in the event the Child wishes to stay with the Father for an additional period during the summer school break, the parties shall make arrangements by agreement for the Child to either return to Pennsylvania with her grandparents in mid- August or return earlier by air transportation to Pennsylvania. The Father shall be responsible to pay the costs of the Child's airfare from Texas (where the Mother and the Child will be visiting on June 26, 2006) to Wyoming and, from Wyoming to Pennsylvania two weeks later or at a subsequent date if the Child is departing from Wyoming prior to her grandparents' departure. 3. The Father's period of custody with the Child during the summer 2006 as provided in the preceding paragraph is conditioned upon the Father providing to the Mother the Father's residential address and telephone number, cell phone number and employment telephone number. Neither party shall use telephone contact information in a harassing or abusive manner. 4. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. cc: .A;t-frey N. Y offe, Esquire - Counsel for F .Aennifer S. Moose, Mother . J BY THE COURT, ~ N ?i ~ - N 3~ ~ :s:: Cl~ ~~ Q- ,:)~ ,. )0:: ..... . III ;o;~ ~i I ~~ ~ ihtn ,':00- o::~ s: "5- ~ 6 ~ ~ y .. JENNIFER S. STEVENSON N/KI A JENNIFER S. MOOSE Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 00-2198 CIVIL ACTION LAW BOBBIE D. STEVENSON Defendant IN CUSTODY Prior Judge: J. Wesley Oler, Jr. 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 Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Patrishia M. Stevenson October 9,1992 Mother 2. A custody conciliation conference was held on April 27, 2006, with the following individuals in attendance: The Mother, Jennifer S. Moose (formerly Stevenson), who was not represented by counsel, and the Father's counsel, Jeffrey N. Yoffe, Esquire. The Father, Bobbie D. Stevenson, resides in Wyoming and participated in the conference by telephone. 3. The parties agreed to entry of an Order in the form as attached. Datf'OZJ I C)oot, . I DaW~d~~ Custody Conciliator