HomeMy WebLinkAbout00-02461LEONARD W. HENDRICKSON,
Plaintiff
V.
KRISTI L. HENDRICKSON,
Defendant
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
CUSTODY
PRAECIPE
Attached is a certified copy of a Divorce Decree entered in the Family Court, First
Circuit of the State of Hawaii, on March 1, 1999, which Decree includes provisions for
child custody (See paragraphs 5 and 6), awarding the parties joint legal custody of the
parties' minor child, Lauren Colleen Hendrickson, born November 3, 1996, and physical
custody of the said minor child to the Defendant, Kristi L. Hendrickson with such
visitation for the Plaintiff, Leonard W. Hendrickson, as agreed by the parties. Pursuant
to 23 Pa. C.S. §5356, authorizing the filing of a custody decree from another state in the
Courts of Pennsylvania, please register and file the attached certified Order on the
Cumberland County Foreign Custody docket and assign an appropriate FCD number,
as well as a Common Pleas Custody docket number, and index to the name of both
parties.
submitted,
R N WEIDNER
l
St phen J.11 zur,?njn, Esquire
rney .: 653
508 North Second Street
P.O. Box 845
Harrisburg, PA 17108-0845
(717) 234-4182
Attorney for Defendant
Kristi L. Hendrickson
DATE: April 18, 2000
STATE OF HAWAII CASE NUMBER
FAMILY COURT DIVORCE DECREE
FIRST CIRCUIT
(With Children) p
FC-D NO. 1? -C?il°I
1
This document is prepared by
Leonard W. He n d r i k c on ? Plaintiff ZI Defendant ? Atty. for Plalnuff ? AtIX for Defendant
PLAINTIFF Kri S i . HPndYi rkenn
(Full Name) Name
92-1007 Ala'a St. #204
Vs.
uaf,nm of biI 46707
Address
Kristi L. Hendrickson
DEFENDANT city. State, zip
(Full Name) Phone 679-fiSR1
Presiding Judge Date ofHea rglR V e
^ by Judge
CHRISTINE E. KURiYAMq w
FEB 18 19(91(,(
A hearing was held before the Presiding Judge or an affidavit was submitted and the Court waived hearing on this matter. After
full consideration of the evidence, the Court finds the material allegations of the Complaint for Divorce to be true. Plaintiff is entitled
to a divorce from the bonds of matrimony. The Court has jurisdiction to enter this Divorce Decree. In this Divorce Decree, Plaintiff
is referred to as ?t Husband Q Wife, and Defendant is referred to R.s ? Husband $Q Wife.
IT IS HEREBY ORDERED, ADJUDGED AND DECREED that:
Aoft-
1. Decree: A decree of divorce is granted to 6'Flusu
? Wife. The bonds of matrimony between Husband and Wife are hereby
dissolved. The parties are restored to the status of single persons. Either party is permitted to marry after the effective date of this
Divorce Decree.
2. Effective Date: This Divorce Decree is effective after it is signed and filed by the CourL
3. Alimony-
92 3A. Neither party shall be required to pay alimony to the other party.
? 3B. Beginning with a first paymenton the , day of Mamnru,
? Husband ? Wife shall pay to ? Husband ? Wife alimony of $ per month. to be paid
? in one amount of $ by the _ day of each month.
? in two equal installments of $ by the _ and days of each month.
Alimony shall continue for _ months and terminate with the payment due ^+^?+Y^ t
Alimony shall terminate upon the death of either Husband or Wife.
Alimony ? shall ? shall not terminate upon the recipient's remarriage.
4. The parties have 1 child(ren) together:
Name (first, middle, last) Date of Birth
Lauren Colleen Hendrickson 11/3/96 _
_ -4 =3 rn
5. Custody: o - rn
5A. Legal Custody of the above-named minor child(ren) is: (j G v
? Awarded to Husband
? Awarded to Wife
C$Awarded to Husband and Wife, jointly.
? Reserved for a court of competent jurisdiction.
FORMNO. 073106 a/§6
(Page 1)
DIVORCE DECREE" CHILDREN) 1FP-06e
I do hereby certify that this is a full, true and
correct copy of the original on file in this office.
Circuit Court, First Circuit
5B. Physical Custody of the above-named minor child(ren) is:
? Awarded to Husband with a detailed visitation/time sharing schedule to Wife as described in paragraph 6.
® Awarded to Wife with a detailed visitation/time sharing schedule to Husband as described paragraph 6.
? Awarded to Husband and Wife, jointly, with a visitation/time sharing schedule as described in paragraph 6B below.
? Reserved for a court of competent jurisdiction.
6. Visitation/Time Sharing Schedule shall be as follows:
6A. The parties shall arrange reasonable visitation.
? 6B. Visitation/time sharing schedule shall be as follows:
7. ® Unless specified in paragraph 24 of this decree, Husband and Wife shall keep each otherinformed of his/herresidence address
and telephone number for so long as any child of the parties is a minor and for so long thereafter as there is a support order.
8. Child Support:
?U SA. Beginning with the lust payment on the -I , s t_ day of ma h 1q29 Husband shall pay to Wife for the
support of the parties' child(ren) $ 3 90.00 per child, for a total of $ 390.00 per month.
? 8B. Beginning with the first payment on the day of . Wife shall pay to Husband for the
support of the parties' child(ren) $ per child, for a total of $ per month.
? 8C. Child support is reserved for a court of competent jurisdiction.
® 8D. Payments of child support shall continue for each child until the child attains the age of eighteen years, or graduates from
high school, or discontinues high school, whichever occurs last. Child support shall further continue uninterrupted
(including during regular school vacation periods) until the age of 23 as long as the child continues his or her education
post-high school on a full-time basis at an accredited college or university or in a vocational or trade school.
® 8E. The Child Support Enforcement Agency (CSEA) is made a party for the limited issue of child support.
9. Method of Child Support Payment ( Check either 9a OR 9b):
? 9A. All payments shall be made payable to and through the Child Support Enforcement Agency (CSEA), P.O. Box 1860,
Honolulu, Hawai' i 96805-1860, and pursuant to the Order of Income Withholding which shall be filed with this decree.
® 9B. Direct Payment
aChild support payments shall be paid by Husband directly to Wife.
? Child support payments shall be paid by Wife directly to Husband.
® In all direct payment cases, either Husband or Wife may void the direct payment arrangement at any time and apply
for services from the CSEA to receive payments through the agency. If the child(ren) of the parties receive(s) public
assistance from the Department of Human Services, foster care payments or Social Security or if either parent applies
to the CSEA, CSEA may immediately void a direct payment arrangement by sending notice by regular mail to both
parents at their last known addresses as set forth in this Divorce Decree.
10. Post-High School Education Support:
Q10A. Husband shall pay -5k%D and Wife shall pay _5Q%a of the educational expenses of the child(ren) for so long as the
child(ren) is/are a full-time student at an accredited college or university or vocational or trade school and under the age
of 23.
FORM NO. 073106 aloe (Page 2) DIVORCE DECREE tmTM GRRARep ?,r+
? 10B. For payment of expenses related to the child(ren) attending private school see paragraph 24 below.
MIDC. Forthesepurposes,educational expenses shall bedefinedtoinclude tuition, fees andthecosts ofnecessary booksandother
course materials.
11. Child Health Care: For so long as Husband or Wife has an obligation to pay child support and/or educational support:
MIA. Husband shall maintain medical and dental insurance for the benefit of the child(ren).
? 11B. Wife shall maintain medical and dental insurance for the benefit of the child(ren).
? I1C. Husband shall pay the medical and dental expenses of the child(ren) not paid by insurance up to $
per calendar year. Any additional medical and dental expenses not covered by insurance shall be paid _ % by Husband
and _ % by Wife.
U111). Wife shall pay the medical and dental expenses of the child(ren) not paid by insurance up to $ per
calendar year. Any additional medical and dental expenses not covered by insurance shall be paid _ % by Husband
and _ % by Wife.
12. Life Insurance for the Benefit of Child(ren): 2 5 , 0 0 0
12A. Husband shall maintain life insurance on his life with a minimum death benefit of $ for the benefit of the
child(ren) so long as there is a child support and/or educational support obligation.
{c712B. Wife shall maintain life insurance on her life with a minimum death benefit of $ 25 , 00 Gfor the benefit of the
child(ren) so long as there is a child support and/or educational support obligation.
®12C. If Husband or Wife dies without the required insurance, Husband's or Wife's estate shall be liable to the child(ren) to the
extent that the required insurance was not maintained. Such obligation on the part of Husband's or Wife's estate shall be
accorded the highest possible priority.
13. ® All provisions in paragraphs 3, 5, 6, 7, 8, 9,10,11 and 12 are subject to further order of the court.
14. Bank Savings, Checking, Credit Union Accounts and Securities (Stocks, Bonds, Mutual Funds, etc.):
? 14A. There are none.
C XK4B. Each is awarded those titled in their name alone.
014C. Husband is awarded:
15. Vehicles (Autos, Trucks, Motorcycles, Trailers, Campers, Boats, etc.):
? 15A. There are none.
D 15B. Each party is awarded the vehicles titled in their name alone.
$715C. Husband is awarded: ._,..__97 Ford RanYger
......._ .?.. ...._..._. i
96 rlymouth Voyage
?15D. Wife is awarded:
®15E. Necessary transfer documents shall be signed no later than ten days following the filing of this Divorce Decree. If either
party fails to do so; the Director of Finance of the City and County of Honolulu is authorized and directed to transfer the
ownership of vehicle(s) if requested to do so.
FORM NO. 073106 EM
(Page 3)
DIVORCE DEGREE(MITI cnauneNI ,r-r- *
16. Real Property:
' A
jal6A. Neither party owns any interest of any kind in any real property.
? 16B. The real property shall be divided as follows:
17. Life Insurance:
? q
y 17A. There is none.
`917B. Each party is awarded the life insurance policy(ies) now, held on his/her life, together with any cash: value therein and
subject to any debt thereon.
? 17C. The life insurance shall be divided as follows:
18. Retirement Accounts/Benefits:
? 18A. There are none.
?alM Each party shall keep their own.
? 18C. The retirement accounts/benefits of the parties shall be divided as follows:
19. All Other Assets (Personal Belongings, Furniture, Household Effects, Art, Stamps, Coins, Tools, Equipment, Jewelry, Accounts
Receivable, Investment Assets, Business Assets, Cemetary Plots or Niches, Tax Refunds Due, etc.):
?Q19A. Each party is awarded the personal belongings and the household effects in his/her possession.
? 19B. Husband is awarded:
? 19C. Wife is awarded:
20. Ali Outstanding Debts:
?020A. Each party shall pay all of the credit card and other debt, if any, now in his/her name alone.
?20B. There are no joint debts.
X200. Husband shall pay: Ame-ican..._Gene*al_finance.
---Pennsylvami.a_...5-tats.-.-Empl.oyees-._C.U. visa
?20D. Wife shall pay
21. Name Change:
?21A. Wife shall resume the use of her ? birth surname ? former married name and shall be known hereafter as
M.P. gddte. lut wmt..._. ------- ........... --------_-..
?21B. Husband shall resume the use of his ? birth surname ? former married name and shall be known hereafter as
(rmmi lq JUL lame)
22. ? There is a supplemental order fled concurrently with this Divorce Decree.
FORMNO. 073106 9199 (Page 4) MV(=EoECREE(WM4CNItAREN) 1FP89a
23. ? Failure of Party to Perform: If either party fails to execute any document in compliance with this decree, the other patty
may submit a motion to the Court, requesting that the Court appoint the Chief Clerk of the Court to execute said document on
behalf of the noncompliant parry. Said motion may be done without further notice to the non-compliantparty. Such execution
by the Chief Clerk shall have the same effect as if executed by the non-compliant party.
24. Other:
Date
Judge
CHRISTIN"m E. KU731M 1 p?m A L
L9 li Y
APPROVED AS TO FORM AND CONTENT: .....
?GU X t -tc(iL ?Ccun
gnature o amts $ignat re o e en ant
SS#: 195-56-2329
Address: 98-376 Ka'Onohi St. #2
Aiea, HI 96701
Employer's Name and Address: US Navy (vP-9 )
Patrol Squadron NINE
FR9 -11R-966Lk1-54t1 ,
Date Plaintiff Signed Decree: f /1 L ?y
APPROVED AS TO FORM:
X
Signature o Attorney or Plaintiff
SS# 168-52-5473
Address: 92-1007 Ala I a St. #204
Kapolei, HI 96707
Employer's Name and Address: Dairy Queen
3615 Market St.
Camp Hill, PA 17011
Date Defendant Signed Decree: / 9
X
Signature of Attorney F
Name: Name:
FORMNO. 073106 8/98 (Page 5) DIVORCE DECREE(WRN CHILDREN) tF-0-098
r
LEONARD W. HENDRICKSON IN THE COURT OF COMMON PLEAS OF
FMSTI L.
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
00-2461 CIVIL ACTION LAW
DEFENDANT
. IN CUSTODY
ORDER OF COURT
AND NOW, Thursday, May 03, 2001 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. the conciliator,
at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on Monday, May 21, 2001 at 1:00 p.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. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/ Melissa P. Greevy, Est
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our office.
All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must
attend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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LEONARD W. HENDRICKSON, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 00-2461
KRISTI L. HENDRICKSON, : CIVIL ACTION - LAW
Defendant : IN CUSTODY
ORDER OF COURT
AND NOW, upon consideration of the attached Petition for Modification of
Custody, it is hereby directed that the parties and their respective counsel appear
before the Custody Conference Officer, on the day of
2001 at _.M. for a Pre-Hearing Custody Conference to be held
at
Pennsylvania. 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 are to be present at the Conference only if requested by the conference
officer. Failure to appear at the Conference may provide grounds for entry of a
temporary or permanent Order.
FOR THE COURT:
DA
Custody Conference Officer
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, PA 17013
(717) 249-3166
1
LEONARD W. HENDRICKSON,
Plaintiff
V.
KRISTI L. HENDRICKSON,
Defendant
I
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-2461
CIVIL ACTION - LAW
: IN CUSTODY
PETITION FOR MODIFICATION OF CUSTODY
AND NOW, the Plaintiff, LEONARD W. HENDRICKSON, by and through
his attorney, Mindy S. Goodman, Attorney at Law, files a Petition for Modification
of Custody against Defendant, and in support thereof avers as follows:
1. The parties are the natural parents of one minor child, born of
wedlock, whose name and date of birth is as follows:
LAUREN COLLEEN HENDRICKSON Born November 3, 1996
2. Plaintiff, LEONARD W. HENDRICKSON, is an adult individual
currently residing at 3909 Sunbeam Road, Apartment 812, Jacksonville, Florida,
32257.
3. The Defendant, KRISTI L. HENDRICKSON, is an adult individual
currently residing at 4904 Charles Road, Mechanicsburg, Pennsylvania, 17055.
4. By Divorce Decree entered in the Family Court, First Circuit of the
State of Hawaii, on March 1, 1999, awarded the parties shared legal custody and
primary physical custody to Defendant, subject to reasonable visitation with
Plaintiff as the parties are able to agree.
2
5. The above-referenced custody decree was registered and filed with
the Cumberland County Court of Common Pleas.
6. Plaintiff seeks to modify the Court Order and requests that he be
granted primary physical custody of the minor child and in support thereof avers
as follows:
a. Plaintiff's attempts to have custody of his child are constantly
denied by Defendant, and since the parties divorce, Plaintiff is constantly
prohibited from exercising anything but infrequent, supervised visitation
with his child;
b. Plaintiff and his side of the family are being excluded from
the minor child's life;
C. In spite of the fact that the parties share legal custody by
Court Order, Defendant does not provide Plaintiff with any information
about the important aspects of the child's life, including but not limited to,
education/daycare, medical care, and religious training;
d. Plaintiff believes that the minor child is being denied the
opportunity to get to know her half sister, the Plaintiff's other child, and this
is detrimental to the minor child;
e. Plaintiff maintains that the best interests and welfare of the
minor child will be served by granting the Plaintiff primary physical
custody, because he will best ensure that the minor child will have the
opportunity to develop a deep and meaningful relationship with both the
3
maternal and paternal sides of her family, and Plaintiff is best suited to
making sure the child grows spiritually, emotionally and developmentally,
WHEREFORE, the Plaintiff respectfully requests this Honorable Court to
grant Plaintiff's request for primary physical custody of the parties' minor child.
Respectfully submitted,
Mindy S. Goodman
Attorney ID No. 78407
2080 Linglestown Road
Harrisburg, PA 17110
(717) 540-8742
Attorney for Plaintiff
VERIFICATION
I verify that the statements made in the foregoing document are true and
correct. I understand that false statements made herein are subject to the
penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities.
P
Leonard W. Hen3n`c-kson ??
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LEONARD W. HENDRICKSON,
Plaintiff
vs.
JUN 1 12001
DV" '
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-2461
KRISTI L. HENDRICKSON, : CIVIL ACTION - LAW
Defendant : CUSTODY
ORDER OF COURT
AND NOW, this 131' day of June, 2001, upon consideration of the attached
Custody Conciliation Summary Report, it is hereby ordered and directed as follows:
1. Legal Custody. The parties, Leonard W. Hendrickson and Kristi L. Hendrickson,
shall have shared legal custody of the minor Child, Laura Colleen Hendrickson, born
November 3, 1996. 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 Pa. C. S. § 5309, each parent shall be entitled to all records and
information pertaining to the Child including, but not limited to, medical, dental, religious or
school records, the residence address of the Child and of the other parent. To the extent one
parent has possession of any such records or information, that parent shall be required to
share the same, or copies thereof, with the other parent with in such reasonable time as to
make the records and information of reasonable use to the other parent.
2. Physical Custody. Mother shall have primary physical custody of the minor Child.
Father shall have partial custody of the Child as follows:
A. One four-day weekend in August 2001 upon a thirty-day notice to Mother.
B. Thanksgivina 2001. From November 23, 2001, through November 26,
2001.
C. Christmas. December 26, 2001, through January 2, 2002. To begin in
2002, Father shall have a similar period of custody during the Christmas
to New Year's holiday week in even-numbered years. Mother shall have
custody for Christmas during odd-numbered years to begin in 2003.
D. Summer. Father shall have physical custody for two weeks prior to the
start of school in the month of August 2002.
3. Telephone Contact. The parties shall arrange regular telephone contact between
the Child and the non-custodial parent to occur during their periods of custody.
FA Ry
C) I; F43*(1W
COUNTY
?`i?PENNSYLVANIA
No. 00-2461
4. This Order is temporary in nature. The parties have agreed to review the provisions
of this Order at an additional Conference which shall be scheduled by the Petition of either
party in the month of August 2002.
BY THE COURT,
l/(1C?o J.
Dist: Mindy S. Goodman, Esquire, 2080 Linglestown Road, Harrisburg, PA 17110
Stephen J. Dzuranin, Esquire, 508 N. Second Street, PO Box 845, Harrisburg, PA 17108-0845
OVN b
J('N 11 20(n
LEONARD W. HENDRICKSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. NO. 00-2461
KRISTI L. HENDRICKSON, CIVIL ACTION - LAW
Defendant CUSTODY
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
Laura Colleen Hendrickson November 3, 1996
Mother
2. A Custody Conciliation Conference was held on May 31, 2001, with the following
individuals in attendance: the Father, Leonard W. Hendrickson, and his counsel, Mindy S.
Goodman, Esquire; the Mother, Kristi L. Hendrickson, and her counsel, Steve Dzuranin,
Esquire.
3. The parties were seen pursuant to the Petition to Modify filed by Father on April 25,
2001. There is a previous Custody Order which has been registered as a Foreign Custody
Docket in Cumberland County. The Family Court, First Circuit of the State of Hawaii on March
1, 1999, issued a Divorce Decree which included provisions for primary physical custody in
Mother and shared legal custody of the minor Child. This is the parties' first Custody
Conciliation Conference since the original Divorce Decree.
4. The parties reached a temporary agreement in the form of an Order as attached
with the understanding that the Order may be reviewed in August of 2002.
Date
Melissa Peel Greevy, Esquire
Custody Conciliator
Mindy S. Goodman
Attorney at Law
2215 Forest Hills Drive
Suite 35
Harrisburg, PA 17112
(717) 540-8742
LEONARD W. HENDRICKSON,
Plaintiff/Petitioner
V.
KRISTI L. O'KEEFE,
Defendant/Respondent
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-2461
CIVIL ACTION - LAW
IN CUSTODY
PETITION FOR MODIFICATION OF CUSTODY
AND NOW, this day of 1 12 ? , 2007, comes
Plaintiff/Petitioner LEONARD W. HENDRICKSON, by and through his attorney,
Mindy S. Goodman, Attorney at Law, and files this Petition for Modification of
Custody.
1. The current address of Plaintiff/Petitioner, hereinafter referred to as
Father, is 2917 Decidely Street, Green Cove Springs, Florida 32043.
2. The current address of Defendant/Respondent, hereinafter referred
to as Mother, is 4 Ashburg Drive, Mechanicsburg, Pennsylvania 17055.
3. The parties are the parents of one minor child whose name and
date of birth are as follows:
LAUREN COLLEEN HENDRICKSON DoB November 3, 1996
4. On or about June 8, 2001, the parties entered into an agreement
with regard to custody as a result of a conciliation before Melissa Peel Greevy,
Esquire, said Agreement becoming an Order of Court dated June 13, 2001, a
copy of which is attached hereto as Exhibit A.
5. The Order of June 13, 2001 was intended to be a temporary Order
entered as a result of Father's military service and impending deployment.
6. Since the Order was entered in June of 2001, Father has made
multiple attempts to have increased custody over and above the Christmas
vacation and two weeks in the summer that are provided for in the current Order.
7. As of this date, Mother has been unwilling to grant Father any
additional periods of custody, except that Father had 22 days of custody during
the summer of 2006 to make up for summer custody denied him by Mother in
2005.
8. Father maintains that it is in the best interest of the minor child to
have more frequent and longer visits with Father in order that the two might
develop a stronger and healthier father-daughter bond.
9. In addition to developing a stronger relationship with Father, longer,
more frequent visits with Father will allow the minor child to develop a better and
stronger relationship with her sisters.
2
10. Father maintains that the best interest and welfare of the minor
child will be advanced by granting the relief requested.
WHEREFORE, Plaintiff/Petitioner respectfully requests this Honorable
Court to grant him additional periods of partial custody of the minor child who is
the subject of this petition.
Respectfully submitted,
1 ??? VII n
Mindy S. Goodman
Attorney at Law
ID No. 78407
2215 Forest Hills Drive - Suite 35
Harrisburg, PA 17112
(717) 540-8742
Attorney for the Plaintiff/Petitioner
3
VERIFICATION
I have reviewed the contents of the foregoing Petition for Modification of
Custody and I verify that the statements made in the foregoing document are true
and correct to the best of my knowledge, information and belief. I understand
that false statements made herein are subject to the penalties of 18 Pa.C.S. §
4904, relating to unsworn falsification to authorities.
Mindy S. Goodman, Esquire
Attorney for Plaintiff/Petitioner signing
on behalf of Leonard W. Hendrickson
4
-1(JN
I
LEONARD W. HENDRICKSON, IN THE COURT OF COMMON PLEAS OF 2001
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. NO. 00-2461
KRISTI L. HENDRICKSON, CIVIL ACTION - LAW
Defendant CUSTODY
ORDER OF COURT
AND NOW, this 13+? day of June, 2001, upon consideration of the attached
Custody Conciliation Summary Report, it is hereby ordered and directed as follows:
1. Legal Custody. The parties, Leonard W. Hendrickson and Kristi L. Hendrickson,
shall have shared legal custody of the minor Child, Laura Colleen Hendrickson, born
November 3, 1996. 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 Pa. C. S. § 5309, each parent shall be entitled to all records and
information pertaining to the Child including, but not limited to, medical, dental, religious or
school records, the residence address of the Child and of the other parent. To the extent one
parent has possession of any such records or information, that parent shall be required to
share the same, or copies thereof, with the other parent with in such reasonable time as to
make the records and information of reasonable use to the other parent.
2. Physical Custody. Mother shall have primary physical custody of the minor Child.
Father shall have partial custody of the Child as follows:
A. One four-day weekend in August 2001 upon a thirty-day notice to Mother.
B. Thanksgiving 2001. From November 23, 2001, through November 26,
2001.
C. Christmas. December 26, 2001, through January 2, 2002. To begin in
2002, Father shall have a similar period of custody during the Christmas
to New Year's holiday week in even-numbered years. Mother shall have
custody for Christmas during odd-numbered years to begin in 2003.
D. Summer. Father shall have physical custody for two weeks prior to the
start of school in the month of August 2002.
3. Telephone Contact. The parties shall arrange regular telephone contact between
the Child and the non-custodial parent to occur during their periods of custody.
No. 00-2461
4. This Order is temporary in nature. The parties have agreed to review the provisions
of this Order at an additional Conference which shall be scheduled by the Petition of either
party in the month of August 2002.
Dist: Mindy S. Goodman, Esquire, 2080 Linglestown Road, Harrisburg, PA 17110
Stephen J. Dzuranin, Esquire, 508 N. Second Street, PO Box 845, Harrisburg, PA 17108-0845
r
TRUE COPY FROM RECORD
In Testimony whereo , i here unto set my hand
and t al o said ou at Carlisl , Pa. I
This/j ... 1Y
ry
1?
LEONARD W. HENDRICKSON, . IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
f
vs. NO. 00-2461
KRISTI L. HENDRICKSON, CIVIL ACTION - LAW
Defendant CUSTODY
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
Laura Colleen Hendrickson November 3, 1996 Mother
2. A Custody Conciliation Conference was held on May 31, 2001, with the following
individuals in attendance: the Father; Leonard W. Hendrickson, and his counsel, Mindy S.
Goodman, Esquire; the Mother, Kristi L. Hendrickson, and her counsel, Steve Dzuranin,
Esquire.
3. The parties were seen pursuant to the Petition to Modify filed by Father on April 25,
2001. There is a previous Custody Order which has been registered as a Foreign Custody
Docket in Cumberland County. The Family Court, First Circuit of the State of Hawaii on March
1, 1999, issued a Divorce Decree which included provisions for primary physical custody in
Mother and shared legal custody of the minor Child. This is the parties' first Custody
Conciliation Conference since the original Divorce Decree.
4. The parties reached a temporary agreement in the form of an Order as attached
with the understanding that the Order may be reviewed in August of 2002.
?P
Date
L4-46 CM6 4
Melissa Peel Greevy, Esquire
Custody Conciliator
O
a - r7,
1
LEONARD W. HENDRICKSON IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
KRISTI L. HENDRICKSON
DEFENDANT
00-2461 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, _ _ Friday, May 25, 2007 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, June 15, 2007 at 2:00 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 and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT.
Bv: /s/ ohn j. Mangan, jr., Esq.
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
.. . L l l L
Jr)
?.i?lJe
LEONARD W. HENDRICKSON,
PLAINTIFF
VS.
KRISTI L. HENDRICKSON, n/k/a
KRISTI L. O'KEEFE,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 00 - 2461 CIVIL ACTION LAW
CIVIL ACTION - LAW
CUSTODY
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Please mark the appearance of Steven Howell, Esquire on behalf of Defendant
Kristi L. Hendrickson n/k/a Kristi L. O'Keefe as her counsel of record.
Respectfully submitted,
BY:
StevpMowell, Esq
IWell Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
Attorney for Defendant
Certificate of Service
I hereby certify that on the date set forth below a true and correct copy of the
foregoing document was served upon the party/parties set forth below by postage
prepaid, first class United States Mail addressed as follows:
Mindy S. Goodman, Esquire (Via Telecopier 540-8743)
Suite 35, 2215 Forest Hills Drive
Harrisburg, PA 17112
Steven J. Dzuranin, Esquire (Via Telecopier 234-4224)
Wix, Wenger & Weidner
P.O. Box 845
Harrisburg, PA 17108-0845
By:
Date: June 11, 2007
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co
LEONARD W. HENDRICKSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 00-2461 CIVIL ACTION LAW
KRISTI L. HENDRICKSON, IN CUSTODY
Defendant
Prior Judge: J. Wesley Oler, Jr., J.
ORDER OF COURT
AND NOW this day of L , 2007, upon consideration of the attached
Custody Conciliation Report, it is Ordered and Directed as follows:
The Father, Leonard W. Hendrickson, and the Mother, Kristi L. Hendrickson (N/K/A Kristi
O'Keefe), shall have shared legal custody of Laura Colleen Hendrickson, born 11/3/96. The
parties shall have an equal right 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 23 Pa.C.S. §5309, each parent shall be entitled
to all records and information pertaining to the Child including, but not limited to, medical,
dental, religious or school records, the residence address of the Child and of the other parent.
To the extent one parent has possession of any such records or information, that parent shall be
required to share the same, or copies thereof, with the other parent within such reasonable time
as to make the records and information of reasonable use to the other parent.
2. The Mother shall enjoy primary physical custody of the Child.
3. The Father shall have periods of partial physical custody of the Child as follows.
a. In 2007, Father shall have physical custody of the Child from July 2, 2007 until July 22,
2007.
b. Father shall have the Child during the Thanksgiving break 2007.
c. In 2008, Father shall have physical custody of the Child for the Easter break.
d. In 2008 and in all subsequent years, Father shall have four weeks physical custody during
Colleen's summer vacation with the understanding that the Child shall be back in Mother's
custody before July 15, 2008.
e. Commencing 2008, Father shall have the Child for her Christmas break in all even
numbered years.
f. Commencing 2009, Father shall have the Child for her Easter and Thanksgiving break in
all odd numbered years.
g. The parties are directed to share the cost of transporting their Child for her summer and
Christmas custodial periods with Father.
h. For Father's custodial periods for Easter, Thanksgiving or Christmas, the Father is directed
to return the Child to Mother's physical custody at least two days before the Child is to
return to school.
i. The parties may alter this arrangement upon mutual agreement.
4. The parties are directed to exchange information regarding school breaks and Father is directed
to notify Mother of any proposed custodial periods and transportation plans 30 days before said
custodial period.
-q
9S :1 f-'J Z- 130 LOCI
1(
5. Telephone contact between the Child and the non-custodial parent shall be liberal as agreed
upon between the parties.
6. There shall not be any unsupervised contact between the Child and her paternal grandfather,
Wayne Hendrickson.
7. Neither party may say or do anything nor permit a third party to do or say anything that may
estrange the Child from the other party, or injure the opinion of the Child as to the other parry,
or may hamper the free and natural development of the Child's love or affection for the other
party. To the extent possible, both parties shall not allow third parties disparage the other
parent in the presence of the Child.
8. In the event of a medical emergency, the custodial party shall notify the other parties as soon
as practicable after the emergency is handled.
9. During any periods of custody or visitation, the parties shall not possess or use controlled
substances or consume/be under the influence of alcoholic beverages to the point of
intoxication. The parties shall likewise assure, to the extent possible, that other household
members and/or house guests comply with this provision.
10. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify
the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of
this Order shall control.
Di bution:
^dy Goodman, Esq., 2215 Forest Hills Drive, Ste 35, Harrisburg, PA 17112
XS phen Howell, Esquire, 619 Bridge Street, New Cumberland, PA 17070
, bin J. Mangan, Esquire
By the Court,
! a
LEONARD W. HENDRICKSON,
Plaintiff
V.
KRISTI L. HENDRICKSON,
Defendant
Prior Judge: J. Wesley Oler, Jr., J.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 00-2461 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVU, PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the following report:
The pertinent information pertaining to the Child who is the subject of this litigation is
as follows:
Name Date of Birth
Lauren Colleen Hendrickson 11/3/96
Currently in the Custody of
Mother
2. A prior Order of Court was entered June 13, 2001 by the Honorable J. Wesley Oler, Jr.
with Mother having primary physical custody subject to Father's partial physical
custody of the minor Child when the Child is not in school.
3. A Conciliation Conference was held with regard to this matter on June 15, 2007 with
the following individuals in attendance:
The Mother, Kristi Hendrickson, with her counsel, Stephen Howell, Esq.
The Father, Leonard Hendrickson, with his counsel, Mindy Goodman, Esq.
4. The parties agreed to the entry of an Order in the form as attached.
c? i-
--------------
Date John gan, Esquire
Cus dy onciliator