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Home My WebLink About00-03028 ~ TOM R]:'1X:7t . f:>OV~MQ1l, P!i-N N9'11-V AN::!-A gys-re.M Or: 9CJlOOL A9Sf.99Mf.Ni 9">'001 pr6Fjk.. ~ptNNSiit'iRO AREA SD 890 Valley Street Enola, PA 17025 District Phone: (717) 732-3601 Director Of Curro & Instr.: Keith M. Voelker Wf:?f.Nt iI.i1~ . Si'C"PJ'T ARY OF [::WCATWN 1'1"'1'l.- "rr EAST PENNSBORO AREA SHS 425 Shady Lane Enola, PA 17025-0000 School Phone: (717) 732-0723 Principal: Craig Robbins LEVEl.: HIGH SCHOOL A high school level profile presents state assessment results on page 5 for grades 9 and 11, as appropriate. ENROLLMENT AND ATTENDANCE School Year 1998-99 Enrollment Grade School Oistrict Age 4 KDG 0 0 Age 5 KDG 0 205 Grade 1 0 224 Grade 2 0 228 Grade 3 0 215 Grade 4 0 206 Grade 5 0 217 Grade 6 0 214 Elementary Ungraded 0 0 Grade 7 0 210 Grade 8 0 208 Grade 9 185 185 Grade 10 194 194 Grade 11 181 181 Grade 12 179 179 Secondary Ungraded 0 0 Total Enrollment 739 2,666 II GRADUATES II Student Attendance Rates (School Year 1998-99): School 92.8% District 95.0% State Sample 93.0% Percent Low Income (School Year 1998-99): Percent Enrolled In: School District State 19.0% 17.3% 31.7% Intended Pursuits for School Year 1997-98 Graduates: Percent of Students Graduate Intentions: School State Postsecondary degree-granti~g institution '~'70:9% Postsecondary non-degree-granting institution 0.6% Obtain ajob 19.4% Join the military 4.2% Homemaking 0.6% PENNSYLVANIA DEPARTMENT OF EDUCATION 68,8% 3.8% 14.4% 3.9% 0.6% EAST PENNSBORO AREA SO EAST PENNSBORO AREA SHS High School level - Page 1 " II ENROLLMENT STAB I L I TV II Grade 9 Enrollment Stability (School Year 1998-99): Students Began Attending: Before this school year At the start of school year Between school year start and Januarv 1, 1999 After January " 1999 Percent 93% 5% 1% 1% Grade 11 Enrollment Stability (School Year 1998-99): Students Began Attending: Before this school year At the start of school year Between school year start and Januarv 1,1999 After January " 1999 Percent 94% 1% 3% 3% II DROPOUTS II Dropouts (School Year 1997-98): Grade Grade Grade Grade Ungraded Secondarv Dropouts 9 10 11 12 Secondarv Number of dropouts for this school 1 5 7 10 Dropout Rates School 0.5% 2.7% 3.8% 5.6% District 0.5% 2.7% 3.8% 5.6% State 2.8% 4.0% 4.7% 4.2% 2.7% II CLASS SI ZE IJ Class Size (School Year 1998-99): Number of Students 1 to 20 21 to 23 24 to 26 2710 29 30 or more This School .63.0% "16.7% .10.5% .':"'."'~~:'6% U% PENNSYlVANIA DEPARTMENT OF EDUCATION Percent of Classes State-wide Sample Comparisons for Public SchoolS Serving: Elementary Secondary Elementary Grades Grades and Only Only Secondary 24.5% 32.8% 16.6% 32.6% 20.1% 17.4% 27.9% 23.0% 27.9% 10.8% 16.3% 22.1% 4.2% 7.8% 15.8% EAST PENNSBORO AREA SO EAST PENNSBORO AREA SHS High School Level - Page 2 STAFFING Number of Professional Staff (School Year 1998-99): School District Full- Part- Full- Part- time time time time Administrative/ Supervisory 3 0 11 0 Classroom Teachers 51 5 172 8 Counselors 3 0 7 0 Librarians 1 0 4 0 Other Service Coordinators 1 0 6 0 Other 1 1 1 1 Teacher Absenteeism (School Year 1998-99): Percent of Contractual Days School District Teachers absent for personal reasons: 4.3% 4,9% Teacher Professional Development (School Year 1998-99): Percent of Contractual Days School District Teachers pursued professional development activities: 2.8% 2,8% PENNSYlVANIA DEPARTMENT OF EDUCATION PROGRAMS AVA I LABLE I N TH I S SCHOOL The following programs/opportunitieslinitiatives were offered and/or actively supported at this school during the 1998-99 school year: Academic Programs/Opportunities/I nitiatives ",,)..ncourse ,clustefor major """'Music,;ourseciuster or major ." Tutorial or eifra help programs "'" Required physical education courses .,. School-to-work activities .,. Consumer and homemaking education .,. Industrial arts/technology education "" Driver education ""'Hi~tlO~!~~;fc~l~t~1n: "'" Acceleration-programs "" Enrichment programs "" Foreign language courses (level 5 and above) "",.bista:nce'iearnirig "" Work'based learning "" ~fuliereducatfoiicoiiiSe"offe'rliigs .""",Q"""""""""""""<,,, ''''', """'Careei"iixplciriiiioii/careerresource' center "'" fridependent study courses ".. , ""Tech Prep "","'Hlgii;SchooIs:tliat-work initiative. Supporting Programs/Opportunities/I nitiatives "" After school programs/clubs "" Interscholastic sports "" Band/orchestra "" Chorus "'" Theater/arts activities or productions "'" Community service programs/opportunities "'" Parent involvement programs/organizations "" On-site lunch service "'" Intramural sports "" Business partnerships "" Work study EAST PENNSBORO AREA SO EAST PENNSBORO AREA SHS High School level - Page 3 VOCAT I ONAL PROGRAMS Approved Occupational Vocational Education Programs (School Year 1998-99): Vocational Technical School Program Category Agriculture Business Marketing & Distribution Health Home Economics. Trades and Industry Diversified Occupations This School v v V V V V This category does not include approved non~occupational consumer and homemaking education programs. Note: Table reflects PA Department of Education occupational program approvals. Included are approved programs at this school and any area vocational-technical schaol serving this school via a fonnal participation agreement (Articles of Agreement). Other vocational programs may be available. Contact school for further information. TECHNOLOGY AND LIBRARY RESOURCES School Year 1998-99: This school's library had an estimated 12,400 tities for books, periodicals, pamphlets, maps, videotapes, films, software, and other electronic media. Individual library titles were checked out 8,400 times during the school year. "'ThfS1l:h(jllrti~d 236 computers avililable for student ~~!tl~~,~r~~.s~~oiii~~~~iS '~~& liq4\Pped with .. i;Q:Rl:l1\'I ca~abiJities,.,.This school hadacces,s to i!ilfcij;aOMtitIes for student use. Location Types of Equipment Broadcast Cabie Internet TV TV School Teacher Workrooms Classrooms Computer Labs Library/Media Centers V V V V V V V V V V V V' V V V COLLEGE ENTRANCE EXAM I NAT I ON BOARD ADVANCED PLACEMENT PART I C I PAT I ON Percent of 11th and 12th Graders Taking CEEB Advanced Placement Exam (1998-99): School State English 2,5% 3.2% Math/Computer Science 2.6% Sci ence 2.4% Social SciencelHistory 3.6% 4.0% Art & Music 0.2% Languages 0.3% 0,3% PENNSYLVANIA DEPARTMENT OF EDUCATION Percent of 11th and 12th Graders Tested scoring 3 or Above on Exam (1998-99): School State English 71.8% 69.7% Math/Computer Science 67,4% Science 61.5% Social SciencelHistory 69.2% 63.0% Art & Music 70.2% Languages 100.0% 61.3% EAST PENNSBORO AREA SO EAST PENNSBORO AREA SHS High School level - Page 4 - ,.# '. PENNSVLVAN I ASVSTEM OF SCHOOL ASSESSMENT Grade 11 Mathematics and Reading Assessment Results (1999) Mathematics School District State Similar Schools+ School Scaled Scores ~;1~1Q >:i3~d' '1300 1270-1320++ School Scaled Scores e1t90 ~'1290 . 1300 1270-1330++ Top 24% 24% 25% 22% Top 27% 27% 23% 21% Reading School District State Similar Schools+ Grade 9 Writing Assessment Results (1999) Writin School District State Sample Similar Schools+ School Scaled Scores ':: 1380 p 1380 1330 1330-1410++ Excellent 7% 7% 5% 6% Percent of Students Achieving Scores in the FOllowing Score Groups: High-middle low-middle 24% 30% 24% 30% 25% 25% 27% 26% High-middle 30% 30% 26% 28% low-middle 18% 18% 26% 25% Bottom 19% 19% 26% 26% Bottom 29% 29% 23% 25% Percent of Students Achieving Scores in the Following Score Categories: Good Fair Weak 16% 71% 6% 16% 71% 6% 23% 51% 17% 30% 52% 11% + A set of schools that are socioeconomically similar to this school ++ The score band within which this school's set of similar schools tended to score Poor 0% 0% 3% 1% II TITLE I EL I G I B I L I TV AND PROGRAMS II Title I Eligibility Title I Programs Ineligible for Title I services Reading and language Arts - Mathematics Other PENNSYLVANIA DEPARTMENT OF EDUCATION EAST PENNSBORO AREA SD EAST PENNSBORO AREA SHS High School Level - Page 5 -' TOM UIX7.e: . 0Off.M09.. P f3.N N9'Y L-V AN;:..A gY9Te.fII Or: SCHOOL- A9t3f.99Mf.Ni '30hool ?r-oFil.", 'l'lQRTHEIlNTEBANON so- . 'l'$chool'Orive Fredericksburg, PA 17026-0100 District Phone: (570) 865-2117 Reading Coordinator: Leigh Kuhn IEVEC- HIGH -SCHOOL A high school level profile presents state assessment results on page 5 for grades 9 and 11, as appropriate. WbtNf. II, J/ J:.C'fOY:. . ~c.P..f.1' ATi.Y ()f" ,e:VUCATZON 1"'r7<t -- rt NORTHERN LEBANON SHS School Drive, Box 100 Fredericksburg, PA 17026-0000 School Phone: (717) 865-2117 Principal: Michael Murphy II ENROLLMENT AND ATTENDANCE School Year 1998-99 Enrollment Grade School District Age 4 KOG 0 0 Age 5 KOG 0 188 Grade 1 0 157 Grade 2 0 200 Grade 3 0 197 Grade 4 0 188 Grade 5 0 189 Grade 6 0 174 Elementary Ungraded 0 17 Grade 7 0 183 Grade 8 0 186 Grade 9 193 193 Grade 10 188 188 Grade 11 183 183 Grade 12 204 204 Secondary Ungraded 5 13 Total Enrollment 773 2,460 II GRADUATES II Student Attendance Rates (School Year 1998-99): School 93.6% II District 95.3% State Sample 93.0% Percent Low Income (School Year 1998-99): Percent Enrolled In: School District State 12.1% 15.6% 31.7% Intended Pursuits for School Year 1997-98 Graduates: Percent of Students Graduate Intentions: School State Postsecondary degree-grantl!!!!.._.,. institution Tj)jI:A~fc. 68.8% Postsecondary non-degree-granting institution 9.2% 3.8% Obtain a job 20.7% 14.4% Join the military 7.5% 3.9% Homemaking 2.9% 0.6% NORTHERN LEBANON SO NORTHERN LEBANON SHS High School Level - Page 1 PENNSYLVANIA DEPARTMENT OF EDUCATION II ENROLLMENT STAB I L I TV II Grade 9 Enrollment Stability (School Year 1998-99): Students Began Attending: Before this school year At the start of school year Between school year start and January 1, 1999 After January 1, 1999 Percent 95% 4% 1% 1% Grade 11 Enrollment Stability (School Year 1998-99): Students Began Attending: Before this school year At the start of school year Between school year start and January 1, 1999 After January 1,1999 Percent 94% 3% 1% 1% II DROPOUTS II Dropouts (School Year 1997-98): Grade Grade Grade Grade Ungraded Secondary Dropouts 9 10 11 12 Secondary Number of dropouts for this school 4 11 9 7 Dropout Rates School 2.0% 5.5% 4.2% 3.8% District 2.0% 5.5% 4.2% 3.8% 0.0% State 2.8% 4.0% 4.7% 4.2% 2.7% II CLASS SIZE II Class Size (School Year 1998-99): Number of Students 1 to 20 21 to 23 24 to 26 2Ho 29 30 or more This School .56.2% " '.22:6% ( 13.1% ..2..9%. 5:1% PENNSYLVANIA DEPARTMENT OF EDUCATION Percent of Classes State-wide Sample Comparisons for Public Schools Serving: Elementary Secondary Elementary Grades Grades and Only Only Secondary 24.5% 32.8% 16.6% 32.6% 20.1% 17.4% 27.9% 23.0% 27.9% 10.8% 16.3% 22.1% 4.2% 7.8% 15.8% NORTHERN LEBANON SO NORTHERN LEBANON SHS High School level - Page 2 ,- STAFFING Number of Professional Staff (School Year 1998-99): School District Full- Part- Full- Part- time time time time Administrative/ Supervisory 5 0 9 0 Classroom Teachers 57 1 152 3 Counselors 2 0 6 0 librarians 1 0 2 0 Other Service Coordinators 4 0 7 0 Other 1 0 1 0 Teacher Absenteeism (School Year 1998-99): Percent of Contractual Days School District Teachers absent for personal reasons: 3.1% 3.5% Teacher Professional Development (School Year 1998-99): Percent of Contractual Days School District Teachers pursued professional development activities: 4.5% 4.2% PENNSYLVANIA DEPARTMENT OF EDUCATION PROGRAMS AVA I LABLE I N TH I S SCHOOL The following programs/opportunities/initiatives were offered and/or actively supported at this school during the 1998-99 school year: Academic Programs/Opportun ities/I nitiatives "" Tutorial or extra help programs eo Required physical education courses "" School-to-work activities eo Consumer and homemaking education eo Industrial arts/technology education "" Driver education eo Acceleration programs eo Enrichment programs "" Foreign language courses (level 5 and above) eo Work-based learning eo Independent study courses eo Tech Prep Supporting Programs/Opportunities/Initiatives eo After school programs/clubs ... I nterscholastic sports eo Band/orchestra .,. Chorus "" Theater/arts activities or productions .,. Community service programs/opportunities ". Parent involvement programs/organizations ... On-site lunch service eoilrt'~ltebreakfast service. "" Intramural sports ... Business partnerships ... Work study NORTHERN LEBANON SO NORTHERN LEBANON SHS High School Level - Page 3 VOCAT I ONAL PROGRAMS Approved Occupational Vocational Education Programs (School Year 1998-99): Vocational Technical School Program Category Agri culture Business Marketing & Distribution Health Home Economics' Trades and Industry Diversified Occupations This School v v v v v v This category does not include approved non~occupational consumer and homemaking education programs. Note: Table reflects PA Department of Education occupational program approvals. Included are approved programs at this school and any area vocationalMtechnical school serving this school via a formal participation agreement (Articles of Agreement). Other vocational programs may be available. Contact school for further infonnation. TECHNOLOGV AND L I BRARV RESOURCES School Year 1998-99: This school's library had an estimated 33,000 titles for books, periodicals, pamphlets, maps, videotapes, films, software, and other electronic media. Individual library titles were checked out 12,600 times during the school year. IhIS~6~~lh~d .175 computersava.Hable for stud~nt . ~se;i30of these computers were equipped with . C~~ROMcapabmHes:..thisschoof had '.access to iirCD~ROMtlfiesfoiSi:udeiit..use: . location Types of Equipment Broadcast Cable I nternet TV TV School Teacher Workrooms Classrooms Computer Labs library/Media Centers v v v v v v v V' V' v V' COLLEGE ENTRANCE EXAM I NAT I ON BOARD ADVANCED PLACEMENT PART I C I PAT I ON Percent of 11th and 12th Graders Taking CEEB Advanced Placement Exam (1998-99): English Math/Computer Science Science Social SclencelHistory Art & Music Languages School 2.1% 3.4% State 3.2% 2.6% 2.4% 4.0% 0.2% 0.3% 0.8% PENNSYlVANIA DEPARTMENT OF EDUCATION Percent of 11th and 12th Graders Tested scoring 3 or Above on Exam (1998-99): English Math/Computer Science Science Social Science/History Art & Music Languages School 62.5% 53.8% State 69.7% 67.4% 61.5% 63.0% 70.2% 61.3% 100.0% NORTHERN LEBANON SO NORTHERN LEBANON SHS High School Level - Page 4 PENNSYLVAN I A SYSTEM OF SCHOOL ASSESSMENT Grade 11 Mathematics and Reading Assessment Results (1999) Percent of Students Achieving Scores School Scaled in the Fallowing Score Groups: Mathematics Scores Top High-middle Low-middle Bottom School 1220' 12% 22% 29% 38% District 1220 12% 22% 29% 38% State 1300 23% 25% 25% 26% Similar Schools+ 1280-1320++ 20% 29% 30% 21% School Scaled Reading Scores Top High-middle Low-middle Bottom School ' "i'J24'O 20% 22% 24% 35% District 1240 20% 22% 24% 35% State 1300 25% 26% 26% 23% Similar Schools+ 1270-1360++ 26% 29% 26% 19% Grade 9 Writing Assessment Results (1999) Writing School District State Sample Simi lar Schools+ School Scaled Scores ~tZ'8Q , 1280' 1330 1350-1390++ Excellent 5% 5% 5% 5% Percent of Students Achieving Scores in the Following Score Categories: Good Fair Weak 9% 49% 28% 9% 49% 28% 23% 51% 17% 26% 54% 13% Poor 7% 7% 3% 1% + A set of schools that are socioeconomically similar to this school ++ The score band within which this school's set of similar schools tended to score II TITLE I EL I G I B I L I TV AND PROGRAMS II Title I Eligibility Title I Programs Ineligible for Title I services Reading and Language Arts -Mathematics Other PENNSYLVANIA DEPARTMENT OF EDUCATION NORTHERN LEBANON SO NORTHERN LEBANON SHS High School level - Page 5 ,-~ " ",,-, ~" '. . ,- ;:=:'"i ..'...............,... ., ';;;liG:IJ/i1J9~f].fl.!NliJ.~: ..... ....,,,;;;;.,fjflllillliBil.:u - .................,.. ... _,.>~.i,'r~9~~~$Jtft~iji'E ............ .,' <> ..... ;', '.' '_'_', ...-.:. ;:'__:__:"':>_,,: .~",'~'" ,.>>.----..:...:~;:,: ,....~.._..:.." ,:___~..-<.>"::<~:~ :,~'_~:::''''''' '_:,:C_'". :'~',,>.-:,:-> :;\~/_,,::,~_-:;-,- ., __. ......,p:/Giiii/,; ...'.... ..:lIilr;ttJt.(}Jf.<.. :' ~~ _: '-:: ;. -,: ,:,::-: ,::' ~', ': '. ::: ~:,'- :<: :--~:,:...':> ,: ::-:' ::' :-: -"': ,.-':-: -~:, -- :~,: - -" . 'j'~~JfJt#l:iJi .-",,',-,--, .ftfJ.~'11... EAST PENNSBORilAREA SO !ISO Valley Street Enela, PA 17025 District Phone; (717) 732-3501 Oi,ector Of Curro " InSU.: Keith M. Voelker EAST PENNSBORO AIlEA MS. 529 NonIJ Enola !IriYe Enola, PA l1ll25-OOOO St:!Ioll1 PIlmIe: (7m 732-11771 Principal: Stephen A. AndreJack LEVEL: MIDDLE This middle 1_ profile p-esents state _ """Its en page 4 for grades 6 and 8, as approprI.... Addiliooal prnIilc(s) issued fortllis school prnscn'.Mproscnt state as>=t results fer otI1cr "l'Jll'lllll'ialIl grade levels (5, 9. cr 11) housed in tIlis _I. Schopl Year 1998-99 Enrilllme.1t Grade Schclol District Age4KllG 0 0 Student Attendance Rates (School Year 1998.99): Age5KllG 0 205 i,1/ade 1 0 224 SUIte Grade 2 0 228 School District Sample Grade 3 0 215 95.1% 95.0% 93.0% Grade 4 0 2il6 Grade :; 211 217 Grade 6 214 214 Elementary Ungraded " 0 v Grade 7 210 210 Percent low Income (Schoo! Yeat 1998-99): Gr.ide 8 208 208 Grade 9 0 185 Percent Er.ollad In: Grade 10 il 194 Sehool District State Grade 11 0 181 20.11% 17.3% 31.7% Grade 12 0 179 SemndlllY UlI;II'llded C II Total EllioUment 849 2,666 EAST PEtlt.lSBOllO AREA $ll EAST I"'d4NSBORO AR(A MS PENNSYLVANIA DEPARTMENT OF EDUCATION Middle Level - Page 1 ;; Pl:TlTleNEIVS I)"i.HJV-M<-7 'f ,; EXHIBIT . .f , illl";60 Mo..e.. ""'~' ~- .....---1 ~ ~. ~ -~ .' li.,-,! . . School Year 1998-99: This sdIoo1'$ libmrj ha~ an estimated 16,000 titles fIIr bOoks periodicals, pamphlets, maps, videotapeS, films, software, and other electronic media. lndividuallibrarj titles ware checked ab"t 9,200 times dlB'ing the sch!lOl year. Dropouts (School Year 1997-98): Secondary Grade Grade Grade Ungraded Dropouts 7 8 11 Secondary :''umbe; of drOJIflL'U for this schocll 0 0 Dropout Rates School 0.0% 0.0% District 0.0% 0.0% 0.5% State 0.0% 0.1% 2.8% 2.7% This school had 221 computers available for student use; 170 of t':e5e OOIllputers _e equipped with CD-ROM capabllitias. This stal ".ad 8ct"..$S to 140 CD-ROM titles for student use. LoCation TY\lCs of Equipment Broadcast Cable Internet 1'J TV School Teacher Workrooms Classrooms Ciil1lputer labs Ubrarj/Media C&ntm II tI II II tI II II II Glade 8 EI!!lII!ment Stability (Seo'iool Year 1_-119): SWl!ems !le!llln ,Iltte!!l!ill!l: Before this schocll year At t.~.e stalt of s;;hool';&ar Between schocll year StaIt arR! Januery 1, 1999 Aftill' JallUary 1, 1999 Percent 94% 4% 2% 1% 32 Class Sill! (SchOllI 'fear 1998-99)., Number of students 1 to 20 2Ho 23 24t02$ 27 to 2ll 30ar more This School 12.1% 15.2% 30.3% 21.2% 21.2% Percent of Classes State-wide Simple Cii~SOIIS fIIr Pilbllc St:hools Strvill!l: Elementaly Seoorlilary EI~..ary Glades Gmdas and Gnly GnlY Secondaiy 24.5% 32.8% 16.6% 32.6% 20.1% 17.4% 27.9% 23.0% 27.9% 10.0% 16.3% 22.1% 4.2% 7.8% 15.9% EAST PENNSBOllO AREA SO EAST PENNSBOIIO AREA liiS Middle level - Page 2 PENNSYLVANIA DEPARTMENT OF EDUCATION . - . ii.",'-: , N~ of Professiar.al Staff, TIIa fallawing pl1ljjIlIIl\S/apportunitieslinitilltives (Scllool Yeu 199IH!9): _ offer.l!l .'ar actively supported at this schOOl during tlte 19!1ll.99 school JIlar: School District Full- Part- FUll- Part- Al:adenric PmgramslOpportpnitieslll1itiatives time time time time ... Required art oourses Administrative! ... Required music courses SuperviSOJy 2 0 11 0 ... Accelfll'8tion programs Classroom ... Enrichment programs Teachers 53 3 172 8 ... Tutorial or extra help programs CoullSellllS 2 0 7 0 ... Foreign language oourses Libmrians 1 0 4 II ... Required physic:el education courses Other Servil:e OJ> Industrial artsItechnology education Coordinatms 2 0 6 0 ... Career explorationleareer resol8C8 center Other 0 0 1 1 ... Consumer and hOmemaking education TeaclH!r Absenteeism (School YE;ai 19!1IMI9); Pllrcent of Contl'actual Days School District Teachel$ absent for PD..!'SOnal reasons: 4.2% 4,9% TelIcher Professiolill! Development (ScIIGGl YGIIi 19"..lI-OO): Poo:o::t of Contractllal Days Schoo! District Teachers pursued professio!!l!! developr..ent activities: 2.7% 2.8~ PENNSYLVANIA DEPARTMENT OF EDUCATION 93% Supporting l'n!!lf!!l!$IDP~!l!liti!!Sllllitiatives OJ> Afta; sct'olIOl prograillSlclubs 31.70% ... !/l!!'aml!ral sports ... BlInd/orchestra ... Chorus ~ Thll3tllrllllU activities or prodUCtions ... Parent involvement programslorganiutiOIlS .". Busin= pmtne:ships .... ComlftUnity selVice programs/op/!ortI!mties ... o"..lt. lunch servial E.~ PE.1,J!\!S8Oll0 AREA SIl EAST PENNSBORO AREA MS Middle Level - Page 3 .,,'~ - _l - -~ - . ;" " . " M/lt/lemati::s School Dis1rict State Similar Schools+ Grade II Ma~ics am! Readlll!l Assessment Results (1999) , Percent of Students Achieving Scores Sl:!!jlol Scaled in the Following Score Groups: Sco.res TlIP High-middle Low-middle Bottom 1340 25% 311% :M% 11% 1340 25% 30% 34% 11% 1300 23% 25% 28% 24% 1290-1350++ 24% 30% 29% 17% School sealed Scores 1300 1300 1310 1300-1350++ Top 19% 1!l'l(, 25% 2j% High-mldll'.e 33% 33% 2&% 28% low-middle 27% Bottom 21% Reading School Disll'ict State Similar Schools+ 2~'" .m 21% 25% 25% 24% 19% Wiiting School Dislrict StIl'Ul Sample Similar Sthools+ IlraH6~ti?Assessme~~O_) School Scaled SOOfes 1230 1230 1240 1260-1310++ Excellent 2% 2% 4% 3% Pen:ent ,of StuderdS AChieving Scores in the Following Score Clitil!lories: Good Fair Weak 37% 54% 1% 31% 54% 1% 39% 45% 10% 48% 43% 5% Poilf 0% 93% 1% 0% + A set of schools that are socioewt.Giiiicaltj similar to this school ++ )'I:~SCIJ!e cbl;~ lIVi!hi~ wl;i~t, Il;i~ ~I'sset ofsll!lill!l' .schGp!stended t9 ,~ Title I Ellgibilit1 Tide II'r\lglaIllS ###11# Ineligible fer Title ! services Reading and lal1guage Arts Mathematics Other PENNSYLVANIA DEPARTMENT OF EDUCATION EAST PEtlt~SBORO AREA SO EAST .....NNSBOllO AREA MS Middle Level - Page 4 "- "" ~'~ ~A ,~"" " ~~" ...d.,..; . .. t.P~Rft9i , &J&fi.N()fi..'...... , , ,-"" '.",'" ',. '~'" ',' ' "'.- ,dtG'ifilt, .,.......~" lKf1Iklcktd:6il ~\....,....".,,'.iie~il&gJ.it~~~$fs(.. ..'.........'.... <ii5i..J....,...ti.-r. c<~j~c...(...."'.,.....,.................~.'................(...... tJ........'. ~i~~..... ~l. c...... ......,., .', -';'--""-J,':,:r-:",;):::J>::'~1i~~I"~:,,:;,,,'V:r::,:, ,:""'-,=:J~'l1:l;/'~,~--,,, , _,' '" ' , ' ",'., ':':'" ,-:.",',.,>--,.:,:,:,:.;--~: ":':::,,:__::,; n<n'':.-'::':'''':'''::'':'' ':'"",:-:::-, ~cll'r~f~li ..........,.AS(Ji~sSmt.tJ$ ~:. _,J.',. , "', -'",~'" , "" ....,--'.-- '''''''<-'-'''',:::;':':> /.; ,~" ,',"",',',',': ',' ,."n"",,, ' '"",",'" ",.- ',''', ','-,',,' -', ',,--, ::', ': ',", ,~>,''',':" ,:,--.', '..,,",'--.-' ',,,' ","".:"'". ,--'>. '...'"",,",',--":, ,,','. ,'..':' ...., ,'", "",,,,,,,',',,.. ,",' ", " " ", '", , ' -- ............................'...........................'.......'.............' __, ",', ,'n, '.' ...,. 1,1!lf"r1 -,,".',', ',,',,',' -- "" ,",'--"',,,"", ',"':,', ,-- ,", '.. :,:~ -..'~'~:~'<':' " -- '; ;~' NORTHERN L"BANON SD 1 School Drf.le Fredericksburg, PA 11026-0100 District Phone: (570) 865-2117 Reading COordinator: Leigh Kuhn NORTHERN LEBANON JHS School Drive. Box 1011 Fredericksburg. PA 11026-0100 Sdiool Phone: (717) 865-2117 Princip.I:Mich.el Murphy LEVEL: MIDDLE This R'JI!tlIe love! profile preseI11$ state.....-.em results on page 4 for grades 8 and 9, a. appropriate. l!!i. Sthooll'l!Ceived a sc!!ool perfl!l1l12!\tO achi..- awan!. Schooi Year 1998-99 ElII'!IiIll!ent Grada School District Aga 4 KDG I) I) Studant Attendance Rates (SchGlll VllIIJ' 1998-99): Age 5 IlDG 0 188 Grade 1 0 151 State Grade 2 0 200 School District Sampla Grade 3 0 '197 94.7% 95.3% 93.0% Grade 4 0 1811 Grade 5 0 ili9 Graae6 0 114 EIementaJy Ungraded 0 17 Grad~ 7 183 183 Pen:ent low Income (ScIillGI Year 1998-99): Grade 8 186 186 Gradeg Q 193 Percent Enrolled In: Grade 10 0 188 School District Stale Grade 11 II 193 16.6% 15.6% 31.7% Grade 12 0 204 Secondary Ungraded 8 13 Total Enrollment 317 2,460 PENNSYLVANIA DEPARTMENT OF EDUCATION tlORTHEPN l!!!AI.lOIJ SD NiilliHERN LEBANON JHS Middle level - Page 1 ;; p[JIller4ER'S EXHIBIT 2 /J1.fIV,4~,.,., :.. ; ! .. 1""'/1>0 mo-€- .' ^ - '~~'ii- , Schoo! Year 1998-99: DrOJlOuts (School Year 1997-98): This school'slibrary had an lIStimated 3;1,000 titles for books periOdll;als, pamphlets, maps, videotapes, films, software, Second8ly C-rade Grade Grade Ungraded and otl1er electronic media. Dropouts 7 l! 9 Secor.dary Individual !ib!ll'Y titles were checked out 12,600 times Nu!!'.ber of during the school year. dropouts for this school 0 0 0 This school had 175 compull!r$ avanable for student use; 130 of these computers were eq'Jipped willi Dropout Rates CD-ROM capabilities. this school had access to School 0.0% 0.0% 0.0% 10 CD-ROM titles for student use. District 0.0% 0.0% 2.0% 0.0% State 0.0% 0.1% 2,8% 2.7% location School Teacl;er W;;;l;rooms Classrooms Computer labs librmylMedia Center Types of Equipment ll."08dcast cable InfBmet TV TV ~, ~ ~ tI ~ ~' ~ ~ ~ tI ~ tI tI Grede 8 Enrollment Stabili~ (School Veal' 1998-99): Students Began Attending: Bafor; this school year At the start of school year Batwea.'1 school year start and JanU8IY t, 1999 After Jailiillly 1, 1999 Percent 93% 5% 1% 1% Class Size (School Vear 1998-99): Number of Studonts 1to20 2Uo 23 24 to 28 271029 30 or WOlie this School 23.5% 29.4% 38.2% 7.4% 1.5% Elementary Grades Only 24.5% 32.6% 27.11% 10.11% 4.2% Percent of CIas$es State-wide Sample Compari511ns for Public Schools Serving: SecorIIIary Elementary Grades and Only Secondaly 32.8% 16.6% ZO.1% 17.4% 23.0% 27.9% 16.3% 2'1.1% 7.8% 15.8% NORtHERN LEBANON SD NORTHERN LEBANON JHS Middle level - Page 2 PENNSYLVANIA DEPARTMENT OF EDUCATION , j 1- ~ ,'. .-. .,.-- Number of Professiollal Staff TIte following prograQlli/opport!!nities/initiati1re$ (School Ymr 1998-99): w!!.!!! offered and/or actively supported at this school during tile 11l9l1-9!1schilill )1!8r: St!loo! District Full- Part- Full- Part- Academic P1DgramslopportUllities/lnitiatives time time time time Q Required art courses Administrative/ Q Required music courses Supentisory 0 (I 9 0 ... Acceleration programs Classroom ... Tutorial or extra help programs Teac~ 18 1 152 3 ... Foreign language courses Counselors 2 (I 6 0 ". Required physical education coLll'$es Ubrarians 0 0 2 0 .... Industrial arts/technology education Other Service ... CaIeer exploration/career nl5OUJl:e center Coordinatws 0 0 7 0 ... Consull1\ll" and !Iomemaking education Other 0 0 1 0 Teacher Absenteeism (School Year: 1998-99): Percent of Conbactual Days School District Teachlll5 absent for pel50nal raaso.,s: 6.3% 3.5% Percent of Contractual flays S~ing Programs/O~!lRitiesllnitiatives .,. fare school programsldUbs ... After school programs/clubs ... lland/crchestra ... Chorus ... Parent involvement programs/organizatio!!$ ... On-site lunch Slli"lice laacher Profe5$ionalllelralojlment (School Year 1998-99): T_hers puT$uad professional development activities: $cI".oo1 District 4.5% 4.2% PENNSYLVANIA DEPARTMENT OF EDUCATION NORTHERN LEBANON SD NORTHERt~ LEllAt.'ON JHS Middle level - Page 3 .~~ - .. .,'1 ,'., '"", ~ Grade 8 Mathematll:S and Reading ~enll!eslllt5.(1999) Percent of Students Al;hievirog Scores School Scaled in the Following Score GroUllS: MafJlematics Scores 'top High-middle low.mlddle Bottom School 1290 15% 34% 31% 20% District 1290 15% 34% 31% 20% State, 1300 23% 25% 21!'l(, 24% Similar Schotlls+ 1300-1360++ 24% 31% 29% 11% School Scaied !leading Scores Top High-middle Low..middle Bottom School 1320 23% 34% 25% 18% District 1320 23% 34% 25% 18% State 1310 25% 26% 25% 24% Similar Schools+ 1310-1370++ 31% 29% 24% 17% Grade 9 Writing Assess..rnel!t ResIIIts (1999)" Writif!!l 51:0001 District State Sample Similar s.."'hoOls+ .. This school did not have g;ade S students + A set of SChools that are socioeconomically similar to this school ++. The score bar.d within wIIiclJ this sc:hoofs S1lt of similar set-rilols tended to score SCIlool Scaled Scores Pen:ent of Students Achieving Scoles In the following sc:ore Calecjorles: Ext:eIlent Good fair Weak "- 1330 5% 23% 51% 11% 3% TItle I Eli~ibility Ineligible for Title I services Title I Progn!IIlS Reading and Language Arts Mltthematics Other PENNSYLVANIA DEPARTMENT OF EDUCATION NORTHERN LEBiiNON Sf) NORTHERN LEBANON JHS Mimlll1"'I1!/1!I- fllIp.4 ._ I. ~. .[ , JAMES R. HAWK, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-3028 CIVil TERM : CIVil ACTION - LAW : CUSTODY DEBORAH S. MOGEL, DefendanUPetitioner PRE-TRIAL MEMORANDUM AND NOW, comes the Plaintiff/Respondent, JAMES R. HAWK, by and through his attorney, MINDY S. GOODMAN, Attorney at law, and files the following Pre-Trial Memorandum. I. Statement of the Case: Plaintiff and Defendant are the natural parents of three minor children whose names and dates of birth are as follows: ANDREW J. HAWK Born August 6, 1986 ARIEL J. HAWK Born February 8,1991 ARIKA J. HAWK Born March 14, 1992 Plaintiff filed for custody on or about May 16, 2000, seeking primary custody of the parties' minor children. A Custody Conciliation was held on July 25,2000 before Custody Conference Officer Dawn S. Sunday, Esquire. By agreement of the parties and subsequently by Order of August 3, 2000, Defendant was awarded primary physical custody of the child, partial custody to Plaintiff. Additionally, the children were Ordered to remain in the East Pennsboro 1 - ,. , '" School District pending further Order of Court and either party intending to relocate, was to provide the other party with at least 50-days' notice so that the issue of custody could be revisited prior to the relocation. Defendant did not give Plaintiff any notice prior to relocating to lebanon County; however, Defendant filed a Petition for Modification of Custody on or about October 18, 2000. Due to the travel to and from school and the impact Plaintiff believed this to have on the children, Plaintiff filed an Emergency Petition for Special Relief seeking temporary primary custody pending a hearing. A hearing regarding the Emergency Petition was held on November 1, 2000, the Petition was granted in part and denied in part, and a full-blown custody hearing was scheduled for November 17, 2000 at 8:30 a.m. II. Issue: Whether it is in the best interests of the children for Plaintiff to be granted primary physical cUl?tody of the minor children subject to partial custody with the Defendant. III. Stipulated Issues and Facts: a. Mother presently has primary physical custody of the minor children and has relocated the children to Lebanon County. 2 _hi""-'~' '~'d b. Prior to moving temporarily to the City of Harrisburg in April of 2000, the children lived their entire lives in Cumberland County in the Enola/Summerdale area. c. If the Defendant retains primary custody of the minor children and chooses to remain in Lebanon County, the children, against their wishes, will be forced to change schools and they will be forced to relocate away from home town they have always known, and away from their friends and family who remain in the Enola/Summerdale area of Cumberland County. IV. Witnesses: a. Plaintiff will testify concerning his ability to provide the day- to-day care and maintenance of the children, the children's positive physical and emotional responses to him being awarded primary custody, the detrimental impact that the relocation to Lebanon County will have on the children, and the positive nature of the relationship that the children have with their father, with Jill Hawk, the Plaintiff's wife, and with all of their friends and family members who live in the Enola/Summerdale area. Plaintiff will also testify about what he believes to be a workable custodial arrangement that he believes is in the children's best interest and still allows for continued growth of the relationship between Defendant and her children. 3 .J ~ 00 '"'" b. Jill Hawk, the Plaintiff's wife, will testify that based on her observations and her relationship with the children, the best interests of the children will be served by granting primary custody of the minor children to Plaintiff. c. Barbara Hawk, the Plaintiffs mother, will testify that based on her observations and her relationship with the children, the best interests of the children will be served by granting primary custody of the minor children to Plaintiff. d. Russell Hawk, the Plaintiffs father, will testify that based on his observations and his relationship with the children, the best interests of the children will be served by granting primary custody of the minor children to Plaintiff. e. E. Thomas Fry, the Plaintiffs uncle, will testify that based on his observations and his relationship with the children, the best interests of the children will be served by granting primary custody of the minor children to Plaintiff. f. John Hawk, the Plaintiffs brother, will testify that based on his observations and his relationship with the children, the best interests of the children will be served by granting primary custody of the minor children to Plaintiff. g. Plaintiff reserves the right to supplement this list as the need may arise at the hearing. 4 ,,=....... V. Exhibits: a. Defendant reserves the right to supplement this list of exhibits as the need may arise at the hearing. VI. Proposed Resolution: Taking into consideration that the Plaintiff is ready, willing and able to assume primary custody of the children, a resolution to this matter that will have the least impact on the children because they will not have to switch schools and will not have to relocate away from their family and friends, the Plaintiff proposes that the he be awarded primary custody of the children subject to partial custody by Defendant. Respectfully submitted, BY: ~6==A.- Mindy S. Goodman Attorney at Law Attorney 1.0. #78407 2080 Linglestown Road Harrisburg, PA 17110 (717) 540-8742 Attorney for Plaintiff/Respondent DATE: J l -::j- -00 5 , ".....,~I~. ..~ I -.-,- _,',,' ~: 0",,;;'" " ,~ ;. _, .. ~ ~ , ~, JAIVIES R. HAWK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-3028 CIVIL TERM ,DEBORAH S. MOGEL, Defendant : CIVIL ACTION--LA W : CUSTODY MOTHER'S PRE-TRIAL STATEMENT WITNESSES: 1. Deborah S. Mogel, mother of the children. Mother shall testifY in regard to the background of this matter and this families' current situation in Fredericksburg. 2. Sandra Wolfe, principle at North Lebanon Middle School. Mrs. Wolfe will ..' ~ 'I testifY in regard to the North Lebanon Middle School in regard to its academic and extra-curricular programs. 3. Betsy Merkle, Special Education Director at North Lebanon Middle School. Ms. Merkle' will testifY in regard to the special education program in North Lebanon Middle School. ISS.,UES FOR RESOLUTION: The parties are the parents of three children: Andrew J. Hawk (14 years old; dob 8/6/86; dghth grade), Ariel J. Hawk (9 years old; dob 2/8/91; fourth grade) and Arika J. Hawk (8 years Q~d; rob 3/14/92; third grade), The children lived with the parties until the parents separated in , February, 1995. The childreIi..remained in the residence with their mother until they moved in October of 1995 to a new residence within the same school district. The family moved once again in November, 1997 when Mother married her current husband, Michael Mogel. On April 12, 2000, a fire occurred at this residence and the family was forced to relocate to Harrisburg. Under the circumstances, the East Pennsboro School District permitted the children to remain in lheii-school district. On October 15,2000, Mother and her family relocated to Fredericksburg, Bennsylvania (Lebanon County), where they now reside. ;., ~ i"; ',,::,' .~~,,' ~ ,'-" -i'-,N',,: " . "- -. After a Custody Conciliation held on July 25, 2000, the parties agreed that it would continue to be in the childrens' best interest to remain with Mother provided they remain in the East Pennsboro School District. This arrangement became increasingly difficult upon the childrells' relocation to Fredericksburg. Mother therefore requested that the Order be modified to permit the children to register in the Northern Lebanon School District. Father objected to this change and therefore a hearing was scheduled before this Court. The primary issue in this hearing would appear to be whether it is in the best interest of the children to remain in the East Pennsboro School District and therefore live with Father or for them to transfer to the Northern Lebanon School District and remain with Mother. It is not anticipated that the current custody schedule would need to be significantly changed with the possible exception of the Tuesday evening visits set forth in paragraph three of the Court's August 3,2000 Order. Respectfully submitted, ., J K. Jones, Es Attorney for Defe ant 7 Irvine Row Carlisle, PA 17013 (717) 240-0296 ..'. ~,',_ ""d'_'_ _,' "'__~ ;"C~"J , JAMES R. HAWK IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA, V. DEBORAH S. MOGEL : NO. 2000-3028 CNIL TERM ORDER OF COURT AND NOW, this 1sT day of NOVEMBER, 2000, a hearing on Plaintiffs Petition for Special Relief is scheduled for Friday, November 3, 2000, at 10:00 a.m. in Courtroom # 5 of the Cumberland County Courthouse, Carlisle, Pa. We will hear testimony from only the parties. The children shall not attend. Edward E. Guido, J. Mindy S. Goodman, Esquire For the Plaintiff Diane Sommers Baker, Esquire For the Defendant :sld - ~~:w- T " ,",_, ~_J(]I! " ~e ". !':;1.[D~-C;:F1CE Or:' \JI'-!-::YU\RY OO~,'n\i-::: "c' 8'''>Q ~~ t 'V HII '.)., CUM8EFiU'JiD COUNlY PENNSYLVANIA ~~~JIII~lImrMl'M~~llIlP!nn~~~__..,.",!_ '9r~" .-~" ~~ - J " )* ti JAMES R. HAWK, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-3028 : CIVIL ACTION - LAW : CUSTODY DEBORAH S. MOGEL, Defendant ORDER AND NOW, upon consideration of the attached Emergency Petition for Special Relief, it is hereby Ordered and Decreed that the Plaintiff is granted primary custody of the parties' minor children pending a full hearing on this matter before the Court. Defendant shall have partial physical custody of the minor children every other weekend from Friday at 6:00 p.m. until Sunday at 7:00 p.m. By the Court: Judge ,_ ,"'"~'"O ,~ ~ a- J..t.~ JAMES R. HAWK, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-3028 DEBORAH S. MOGEL, Defendant : CIVIL ACTION - lAW : CUSTODY EMERGENCY PETITION FOR SPECIAL RELIEF 1. The parties are the natural parents of three minor children, whose names and dates of birth are as follows: ANDREW J. HAWK Born August 6, 1986 ARIEL J. HAWK Born February 8,1991 ARIKA J. HAWK Born March 14, 1992 2. On or about May 16, 2000, Plaintiff filed a Complaint in Custody seeking primary custody of the parties minor children primarily because he was being prevented from having regular custody of his children and also because he was concerned that the Defendant had moved the children to the City of Harrisburg, which is outside the school district where the children have regularly attended school, and that she intended to relocate the children permanently out of their school district and away from their father. 3. A Conciliation Conference was held on July 25, 2000, before Custody Conciliator Dawn S. Sunday, Esquire, at which Plaintiff raised concern about the issues of relocation and of the children being removed from the school district. At the conference, as a result of these discussions, the parties entered into an agreement, which ultimately became an Order of Court. Said agreement 1 -"'~ "' - ,1- -- t'f!iiJ stated that "unless otherwise directed by the Court or arranged by agreement of the parties, the Children shall remain enrolled in the East Pennsboro School District." The agreement further required that either party intending to relocate must provide the other party with ". . .at least 60 days advance notice of the relocation. . . to allow sufficient opportunity to modify the custody arrangements by agreement or Court Order prior to the relocation." (A copy of the Court Order is attached hereto as Exhibit A.) 4. The above-quoted agreement was entered as an Order of Court on August 3, 2000. 5. On or about October 1, 2000, the minor children informed Plaintiff that Defendant would be relocating to Lebanon County and that the Defendant intended to pull the children out of the East Pennsboro School District on or about October 27, 2000, in direct violation of Court Order. 6. By letter of October 3, 2000, Defendant's attorney, Diane Sommers Baker, Esquire, informed the Plaintiff, by letter sent to Plaintiffs attorney, that the Defendant had decided to relocate to Fredericksburg, lebanon County, but that an exact moving date and plans had not yet been determjned. Counsel for the Defendant also indicated that the Plaintiff would no longer be able to continue having custody of his children on Tuesday nights, but no reference to the Court Order and the prohibition against removing the children from the school district was addressed. 2 _ w =~. ~ 1. "" 7. Counsel for the Plaintiff advised counsel for the Defendant that it would be a violation of Court Order to remove the children from the East Pennsboro School District, and the children were not removed. 8. In spite of the fact that the children remain enrolled at the East Pennsboro School District and without sufficient notice to the Plaintiff or regard to the best interests of the children, on or about October 14, 2000 the Defendant did relocate to Fredericksburg, Lebanon County with the minor children, and a Petition to Modify Custody was filed by the Defendant on or about October 18, 2000. 9. A Custody Conference has been scheduled in this matter for November 15, 2000 at 1 :00 p.m.; however, counsel for Plaintiff has a previously scheduled matter in Dauphin County at 2:00 p.m. and may be forced to reschedule the conference. 10. In spite of Plaintiff's offer to assume primary custody pending a hearing on the matter, the Defendant has relocated the children to lebanon County, which is approximately forty-five minutes away from the East Pennsboro School District, where the children are enrolled and currently attending school. 11. Because of the distance involved and the negative impact the travel is having on the children, coupled with Defendant's blatant disregard of the Court Order, Plaintiff seeks emergency relief and requests that he be granted primary custody of the minor children pending a full hearing in this matter. 3 ~~ --- P! 12. Plaintiff avers that the best interests of the children will be served by granting the emergency relief requested. The children are presently driving approximately forty-five minutes in each direction to and from school, which is having a detrimental effect on the children for the following reasons: a. The travel interferes with the children's ability to participate in extra-curricular activities. The children are currently enrolled in baske~ball programs with the East pennsboro Township School District but have been unable to participate; b. The children leave for school between 6:00 and 6:30 a.m. each morning in order that the Andrew may be at school by 7:30 a.m., which is his starting time. The girls are then dropped off at thejr Aunt's home, whjch is approximately one and one-half miles from the Plaintiffs home, where they spend time before they are requir~d to be at school at 8:30 a.m. This routine, if it is permitted to continue, may have a detrimental impact on the children's performance at school. c. On at least one occasion one of the children, Ariel, indicated to the Plaintiff that she fell asleep while taking a test at school. d. On Tuesday evenings, when the children spend the evening at their father's home, all of the children go to bed very early and appear extremely exhausted. 4 . '. I ~ ~ WHEREFORE, the Plaintiff respectfully requests this Honorable Court to grant the emergency relief requested and Order that the Plaintiff be granted primary custody of the parties' minor children pending a full hearing in this matter. Respectfully submitted, ~~-ab,=c9-- Mindy S. Goodman Attorney at Law 10 No. 78407 2080 linglestown Road Harrisburg, PA 17110 Attorney for Plaintiff 5 -"" - ..A:J -_~, VERIFICATION Due to the exigency of the situation and Plaintiffs inability to come to my office to personally sign the Verification, the Plaintiff and I jointly verify that the statements made in the foregoing Emergency Petition for Special Relief are true and correct to the best of our information and belief. We have reviewed each provision of the Petition over the telephone and we understand that statements made herein are subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. ~~Gt=~ Mindy S. Goodman Attorney for Plaintiff ~I<'-- . ~ ~ . ' """","_d JAMES R. HAWK, . IN THE CCURT OF COMMON PLEAS OF . Plaintiff : CUMBERLAND COONTY, PENNSYLVANIA . . vs. : NO. 00-3028 CIVIL TERM : DEBORAH S. MOGEL, . CIVIL ACTION - LAW . Defendant : CUSTODY CRDER OF COURT AND N<l'l, this .]tJ.d.... day of {JCJ.O.Un- , 2000, upon considet'ation of the attached CUstody Concilia.1:ion Report, it is ot'dered and dit'ected as follows: 1. The Fathet', James R. Hawk, and the Mothet', Debot'ah S. Mogel, shall have shared legal custody of Andrew J. Hawk, born August 6, 1986, Adel J. Hawk, born February 8, 1991 and Ar:ika J. Hawk, born Mat'ch 14, 1992. Each par-ent shall have an equal dght, to be exet'cised jointly with the othet' pat'ent, to nake all majot' non-ernet'gency decisions affecting the Childt'en's genet'al well-being including, but not limited to, all decisions t'egarding their health, education and religion. Pursuant to the terms of this pat'agt'aph each parent shall be entitled to all, t'ecot'ds and information pertaining to the Children including, but not limited to, school and medical records and information. To the extent one pat'ent has possession of any such t'ecords or information, that pat'ent shall be r-equit'ed to share the same, or copies thereof, with the othet' pat'ent within such t'easonable time as to nake the t'ecot'ds and information of r-easonable use to the othet' pat'ent. 2. The Mothet' shall have pdma1:Y physical custody of the Childt'en. 3. The Fathet' shall have pat'tial physical custody of the Childt'en on alternating weekends ft'OIO E'dday at 6:00 p.m. through Sunday at 7:00 p.m. fot' the t'emaindet' of the summet' in 2000 and during the school yeat'. In addition, the Fathet' shall have custody eve1:Y week from 6:00 p.m. on Tuesdays through Wednesday morning when the Father shall t'eturn the Children to the Mothet"s r-esidence (if the Children do not have school) Ot' tt'ansport the Children to school no eadiet' than 8:30 a.m. on school days. The Father's Tuesday overnight pedods of custody shall begin on July 25, 2000. Notwithstanding the foregoing, the Fathet' shall have custody of the Children fot' 2 consecutive weekends ft'om July 28 tht'ough July 30 and ft'OIO August 4 Wough August 6, the Mothet' shall have custody of the Children during the following two consecutive weekends and the pat'ties shall begin alternating weekends thet'eaftet'. The Mother shall have custody of the Children for vacation ft'om August 12 Wough August 19, 2000. 4. Beginning in 2001, the parties shall share having custody of the Children during the Stumlet' school bt'eak, with the specific arrangements \:0 be made by agt'eement of the parties. ,,:;,. ""I 5. 1he parties shall share or alternate having custody of the Children on holidays as follows: A. ~: The Christmas holiday shall be divided into Segment A, which shall = fran 7:00 p.m. on the last day of school before the holiday through Christmas Day at 12:00 noon, Segment B, which shall = fran Christmas Day at 12:00 noon through December 28 at 12:00 noon, and Segment C, which shall = fran December 28 at 12:00 noon through the day before school resumes at 7:00 p.m. In even numbered years, the Mother shall have custody of the Children during Segments A and C and the Father shall have custody during Segment B. In odd numbered years, the Father shall have custody of the Children during Segments A and C and the Mother shall have custody during Segment B. B. THANKSGIVING: The Thanksgiving holiday shall run from the Wednesday before Thanksgiving at 7:00 p.m. through the Friday after Thanksgiving at 7:00 p.m. 1he Father shall have custody of the Children over the Thanksgiving holiday in even numbered years and the Mother shall have custody of the Children over the Thanksgiving holiday in odd numbered years. C. MJMIU:AL DAY/LAOCR DAY: The Memorial Day and Labor Day holiday periods shall = from the Sunday before the holiday at 7:00 p.m. through the day of the holiday at 7:00 p.m. In even numbered years, the Mother shall have custody of the Children on Memorial Day and the Father shall have custody on Labor Day. In odd numbered years, the Father shall have custody of the Children on Memorial Day and the Mother shall have custody on Labor day. D. fv.L'!1lSK'S DAY/FATHER'S DAY: The Mother shall have custody of the Children every year on Mother's Day from 9:00 a.m. until 7:00 p.m. and the Father shall have custody of the Children every year on Father's Day fran 9:00 a.m. until 7:00 p.m. E. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 6. With the exception of the Father's weekday periods of partial custody when the Father. shall transport the Children to the .Mother's residence or to school, the party receiving custody of the Children shall be responsible to provide transportation for the exchange of custody. 7. Unless otherwise directed by the Court or arranged by agreement of the parties, the Children shall remain enrolled in the East pennsboro School District. 8. In the event either party intends to relocate his or her residence, that party shall provide at least 60 days advance notice of the relocation to the other party to allow sufficient opportunity to modify the custody arrangements by agreement or Court Order prior to the l;"elocation. ," '""- ,I' _ -.' 9. In the event either party is unavailable to provide care for the Children during his or her period of custody for a 4 hour period or longer, that party shall first contact the other party to offer the other party the opportunity to provide the care before contacting third party caregivers. 10. Each party shall ensure that the Children complete their homework assignments and attend their regularly scheduled activities during that party' s periodS of custody. 11. TIlis 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, /y[id,,~~ j?~;el~. cc: Mindy S. Goodman, Esquire - Counsel for Father Diane S. Baker, Esquire - Counsel for Mother TRUE COpy FROM RECORD \11 T ootlmooy Whl:lfOOf, lhere unto Sit my l',aoo ~. ...~.... ~ ....... ",. ~,,~IM.O'~.' ~~~ onotary ;J~ ~I . - ~ -~ JAMES R. HAWK, . IN TflE <XlURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. : NO. 00-3028 CIVIL TERM . . DEBORAH S. MOGEL, : CIVIL ACrION - LAW Defendant . CUSTODY . CUSTODY COOCILIATrCN SUMMARY REPCET IN ACCXIIDl\NCE WITH CUMBERLAND ClXlN'lY RULE OF crvn. PRCCEOORE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent. information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CORRENl'Ly IN CUSTODY OF Andrew J. Hawk Arie1 J. Hawk Arika J. Hawk August 6, 1986 February 8, 1991 March 14, 1992 Mother Mother Mother 2. A Conciliation Conference was held on July 25, 2000, with the following individuals in attendance: The Father, James R. Hawk, with his counsel, Mindy S. Goodman, Esquire, and the Mother, Deborah S. Mogel, with her counsel, Diane S. Baker, Esquire. 3. The parties agreed to entry of an Order in the form as attached. ~ d-~, ;;.000 Date ~~ Custody Conciliator . 1iI1111*i\l~' I '~, ~ " ->>II="....,"""""~ "'" 1I:fliIiW"-""'~'';'~"~~~~llIilll~_!i:i.i<-''j~ " ,~-~ 8 :tJ:S: tfi cu ;;: r11 a;i?' __<2:' N< S" C'i ';';:;0 !Eo $ ~i1: 25 >- (:) ""';: fi? "'" .:::t:- is " .~:} _Yi fJ] -'J':!1 ij'<::;J :"FfS-') \~1/ "-::;;:?-1 f"!jM $' '""' , -- ~ -- .~~""~ "I -.,! JAMES R. HAWK : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. DEBORAH S. MOGEL : NO. 2000-3028 CIVIL TERM ORDER OF COURT AND NOW, this 1 ST day of NOVEMBER, 2000, a hearing on Plaintiffs Petition for Special Relief is scheduled for Friday, November 3, 2000, at 10:00 a.m. in Courtroom # 5 of the Cumberland County Courthouse, Carlisle, Pa. We will hear testimony from only the parties. The children shall not attend. Edward E. Guido, J. Mindy S. Goodman, Esquire For the Plaintiff Diane Sommers Baker, Esquire For the Defendant :sld ~~- ~,!.,:~,~D~~'~\~:~~.(C:~ -.-".) ".I,JIr'J,y 00 NDY -3 lit,} 8' ':19 'oil . '-.-' CUlVif3~FiLN'JJ COUNTY PeNNSYLVANIA tv" \Jr~ -- ,-= . _~_,~~~~~'!i'i~0I:'~1:~JW~~~_~,....~ _. ,",l!W' ",M!Ifi~ __~ll , , , ~'" . JAMES R. HAWK, Plaintiff v. : COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. Co -.?c.if CiUll y~ : CIVIL ACTION - LAW : CUSTODY DEBORAH S. MOGEL, Defendant ORDER OF COURT AND NOW, upon consideration of the attached Complaint for Custody, it is hereby directed that the parties and their respective counsel appear before the Custody Conference Officer, on the '2\9 day of -C4 U\~ , 2000 at \\-Ob --a.M. for a Pre-Hearing Custody Conference to be held at ~W KQl'\~'J \--\rC~(1\\(,~~ ' Pennsylvania. At such Conference, an effort Will b 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 childrenren age five or older~Y ~ 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: DATE: :5\\'0 DD ~, C 'b>, '> 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 Associatjon 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 5.N.00 s.ft1.OJ 5./~ -t:'O Il I-~ ,_ ~ ~.......,.~- ~~~p ~ ll!IINIlIlI__ .. FILED-~<JFFlr:r:' OF T!!~ '~~':"'::~':n-!r~:) .!(JTARY OO{,'1-~Y lq PI'~ '1, ')Q < '. "', . i.,' .,''':' C';,U:ii:,'C.,., ,.,'"'' "" Gi'IIi...,,-,:'1 '-""""1)' i.' I"~ '1',1: v ",,- '.- - .~, "-..... '..... '" [ F~';-~I\ II\,!C:VL' \ ,I,', L 'I" - \i ',\..JI '.'t\I'!.:-l &I. ~ M~ '~~ ~ '71~ ~ ~ cy. ~~ M-~ ~~~ "- - ~ ",""~JlI1III!'~~'~!'$_,",,,""'m~i!>l""W'!~mijiY~~~g;j~__~_~ ""~"~.",,JIIfiI!~ , , , JAMES R. HAWK, Plaintiff v. : COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. fJ(J- 36.2f CUx..f T~ DEBORAH S. MOGEL, Defendant : CIVIL ACTION - LAW : CUSTODY COMPLAINT FOR CUSTODY AND NOW, the Plaintiff, JAMES R. HAWK, by and through his attorney, Mindy S. Goodman, Attorney at Law, files a Complaint for Custody against Defendant, and in support thereof avers as follows: 1. The parties are the natural parents of three minor children, all children born during the parties' marriage, whose names and dates of birth are as follows: ANDREW J. HAWK Born August 6, 1986 February 8,1991 March 14, 1992 ARIEl J. HAWK Born ARIKA J. HAWK Born 2. Plaintiff, JAMES R. HAWK, is the natural Father of the children, and is an adult individual residing at 205 Louis Lane, Enola, Cumberland County, Pennsylvania 17025. 2 , __ J__ _< ,I 3. The Defendant, DEBORAH S. MOGEL, is the natural Mother of the children and is an adult individual currently residing at 1923 N. Second Street, Harrisburg, Dauphin County, Pennsylvania 17104. 4. In 1994 when the parties separated, Defendant had primary custody of the minor children and Plaintiff had liberal partial custody. 5. During the past five (5) years, the children have lived with the following person(s) at the following addresses: Person Address Date Defendant 1923 N. Second Street Harrisburg, PA 17104 4-29-00 to present Defendant 311 S. Enola Drive Enola, PA 17025 8-1-97 to 4--29-00 Defendant Summerdale Apartments Enola, PA 17025 8-1-95 to 8-1-97 6. Plaintiff now seeks primary custody of the minor children. 7. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 8. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visjtation rights wjth respect to the children. 3 . . ,- ~ ,-. , , >-;1 . 9. Plaintiff believes and therefore avers that the best interest and permanent welfare of the children will be served by granting the relief requested because: a. The children have lived in Enola, Cumberland County, Pennsylvania their entire lives, have always attended East Pennsboro School District since starting school, maternal and paternal families reside in Enola, and the children's friends reside in Enola; b. When the parties separated, Plaintiff had liberal partial custody with the children, but his custody has continuously decreased as a result of Defendant's unilateral decision to exclude Plaintiff from the children's lives. c. Even prior to moving. to Harrisburg, the Plaintiff was only permitted to see his children approximately once a week for a few hours. The children are often not permitted to telephone their father, and when he telephones the children, unless they answer the telephone, Plaintiff is told by Defendant's husband that the children are not home. None of Plaintiffs telephone calls are returned even though Plaintiff leaves messages for the children. d. On the limited occasions when Plaintiff does speak with his children on the telephone, the children are not permitted to freely discuss 4 ..l ~ _., , '" .-~- , i things with their father, the telephone calls are often monitored and are very short as the children are often yelled at to get off the telephone. e. Defendant, unless it js convenient for her and she needs a babysitter, does not allow the children to spend time with their father. f. The children have advised the Plaintiff that Defendant's husband, while disciplining the parties' son Andrew, often grabs him by the neck, thm; scaring the children and running the risk of serjous injury; and when wakjng Andrew up in the morning, the technique used by the Defendant and her husband is throwing cold water on him. g. On the few occasions when the children are permitted to visit their father, they often come to his house late in the afternoon claiming that they have not eaten all day. h. Plaintiff attends all school and extra-curricular activities that he is informed about. He would like to attend them all, but Defendant does not advise him about school activities and the children cannot because they are not permitted to telephone their father until after the activity has happened. i. Plaintiff has the means, desire and ability to care for the children and while in his care, the children will be afforded the greatest opportunity to grow spiritually, physjcally and emotionally. 5 - . ~ I .1 _ ~ , , , ,~- ,--, , j. Plaintiff will take the steps necessary to ensure that the children develop a strong and healthy relationship with thejr mother and both the maternal and paternal family members. k. The children have each expressed a desire to live with their father and their father's wife. I. If the relief requested is not granted, Defendant will further frustrate Plaintiff's efforts to be an active part of the children's lives to their detriment WHEREFORE, the Plaintiff respectfully requests this Honorable Court to grant Plaintiff's request for primary custody of the parties' three minor children. Respectfully submitted, ~.~ ~ (~Cb P-- . Mindy S. Goodman Attorney at Law Attorney ID No. 78407 2080 linglestown Road Harrisburg, PA 17110 (717) 540-8742 Attorney for Plaintiff 6 -.-", . . '. VERIFICATION I verify that the statements made in the foregoing Complaint for Custody are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. ~~W Jam R. Hawk 7 . iliI;ljjjj~'~I'km i1i1Miiri~.......!liiI!tIlf,~II!IilIi!lU'~~iMIIill;~M;l !I!I!f!!!I,~, ~ ,~ "~~ _ v __~ - ..,"'~' ?;J0 f:l~ f' ~ ,..Q lr! ~ ...Q "-.) ~,~ ~~ ~ -10.. ~ ~~~ B86~ I ::c)~ Ft -1 (') ~~ -UU) n'''irn z:n GS;~ -<.~-- G?O ~~C") ~(, :r-"'c:: :z; =< ~ . -- <::1 c::> ..... ~ -< U\ -" ::J<: w c- tl" .1 il II !I , ~ ..::1 ;kD " ~r- -om ,.-,0 i~6 Iii 1-"):0 ~'''(") <-.co ~ ~ g ~ ~ ti , --1 -. JAMES R. HAWK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 00-3028 CIVIL TERM CIVIL ACTION - LAW DEBORAH S. MOGEL, Defendant CUSTODY IN RE: PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 3rd day of November, 2000, after a brief hearing, the Plaintiff's petition for Special Relief is granted insofar as our prior order of August 3, 2000, is amended to provide that father shall have partial physical custody of the children each Tuesday evening from the time they are dismissed from school until Wednesday morning at the commencement of school. The children shall ride the bus to father's home from school on Tuesday and to school on Wednesday. In all other respects, our prior order of August 3, 2000, shall remain in full force and effect, and the remaining requests for relief in Plaintiff's petition are denied. It appears to the Court that a conciliation conference in this matter will be futile. Therefore, a full blown custody hearing is scheduled for Friday, November 17, 2000, at 8:30 a.m. .. " -,I Mindy S. ~oodman, Equire For the Plaintiff James K. Jones, Esquire For the Defendant :mae w"'""""" ~~ By the Court, ~ard E. Guido, J. ~ "~j ;~..c" ~ ,-~ ~ - -jf' - < JAMES R. HAWK PLAINTIFF V. DEBORAH S. MOGEL DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-3028 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 27TH day of OCTOBER, 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Snnday, Esq. , the conciliator, at 39 West Main Street, Mechanicsbnrl(, PA 17055 on the 15THlayof NOVEMBER, 2000, at...!;OO 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 fiV,e 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 TIIE COURT, By: Isl Dawn S. Sunday. Esq.fb 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 "'~,~"' ., /0 .JcJ .C)) /?'J:? ~t1 /tJ :30. tJt1 I (>....".. ~,_o__~ ,,' ,~., ~ -'-'--'1 _" r.~_ . '_.' "-0_,' < _ '''-'-b-~' ,,_. .," .<-." "-.. ~., '-"-'" ~~~",'" ~_l". _'. FiLt=C" .- OF "_IF ",U--OfF/(>[". '! ,[' ','DOT' '._ VI: ~ ! "\ r& j"'IQ '1'-./1\\ TARy 00 aCT 30 PM '). 1/ .J. 34 CUtvrSEF{ J _ PFlNk:i~JiB.UN7Y ad,~/U~Zdf~ /l~ >PI~ ~ df ~ t~7~ ~df.~ , - ~U_~I!IIl\f!II!l!lI~l ~ ~ _"~ l"l_Ilftll~~~~~~_~~~'l!Il'PlI~~:QQ.~ .~rlIlIIjlI! T'" ~. ""- ~" 1 ~ " -.,;,.""'""'--~t_- , JAMES R. HAWK, PlaintifflPetitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-3028 -CIVIL TERM DEBORAH S. MOGEL, Defendant/Respondent : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, , upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before _the conciliator, at on the _ day of , 1999, at_ _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. FOR THE COURT, By: Custody Conciliator 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 reasouable 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 LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTII BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION TWO LffiERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 1"".IlI!.~"~-' ~, , I L JAMES R. HAWK, PlaintiffIRespondent : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-3028 CIVIL TERM DEBORAH S. MOGEL, Defendant/Petitioner CIVIL ACTION - LAW CUSTODY PETITION TO MODIFY CUSTODY AND NOW comes Petitioner, DEBORAH S. MOGEL, by her attorney, Diane S. Baker, Esquire, and files this Petition to ModifY Custody, based upon the following: 1. Petitioner, DEBORAH S. MOGEL, is an adult individual residing at 1923 North Second Street, Harrisburg, Dauphin County, Peunsylvania. 2. Respondent, JAMES R. HAWK, is an adult individual residing at 205 Louis Lane, Enola, Cumberland County, Pennsylvania. Respondent is represented by Mindy S. Goodman, Esquire. 3. On July 25, 2000, the parties met with Custody Conciliator Dawn Sunday, Esquire, at which time they entered into an agreed upon custody order dated August 3, 2000. The August 3, 2000, custody order provides that mother has primary physical custody and father has partial physical custody. A copy of the Order is attached hereto as Exhibit A. 4. At the time of the custody conference Respondent agreed that the best interests of the children would continue to be served by Petitioner acting as the primary custodial parent. "',lh.;TU -". "~-~~~ 5. Petitioner is now moving to Fredericksburg, Lebanon County, and seeks to modifY the current visitation schedule to accommodate the move. The parties have been unable to reach an agreement. 6. Petitioner does not know of a person not party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. 8. The best interest and permanent welfare of the children will be served by granting the relief requested because Petitioner has always been the primary caretaker for the children and provides a safe home and a stable and loving environment for the children. WHEREFORE, Petitioner requests this Honorable Court issue an order modifying the existing order and allowing Petitioner to relocate with the children, and granting Respondent partial custody at such times as are mutually agreeable. Respectfully submitted, DATE: /D-/8-DO ~~ 8abr Diane S. Bake, EsqUIre Supreme Court ill #53200 27 South Arlene Street Post Office Box 6443 Harrisburg, P A 17112-0443 (717) 671-9600 ",..-",,,, I~"'"' "~ 'N_ _ . ~ ~-- ~,. "- JAMES R. HA WI(, Plaintiff/Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-3028 DEBORAH S. MOGEL, DefendantJRespondent CIVIL ACTION - LAW CUSTODY VERIFICATION I verify that the statements made in this Petition 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. I"~~ -; - "" . t JAMES R. HAWK, Plaintiff cffi (/ll . f /11 () cJ IN THE CCURT OF ClJMMCN PLEAS OF CUMBERLAND COONTY, PENNsn VANIA ()!--& . . : . . vs. : NO. 00-3028 CIVIL TERM . . DEBORAH S. MOGEL, Defendant : CIVIL ACTION - LAW : CUSTODY CIIDER OF CXXIRT AND lDI1, this 3~ day of ~irJd- , 2000, upon consideration of the attached Custody Concili tion Report, it is ordered and directed as follows: 1. The Father, James R. Hawk, and the Mother, Deborah S. Mogel, shall have shared legal custody of Andrew J. Hawk, born August 6, 1986, Arie1 J. Hawk, .born February 8, 1991 and Arika J. Hawk, born March 14, 1992. Each parent shall have an equal right, to be exercised jointly with the other parent, to rrake all major non-emergency decisions affecting the Children's general well-being inclUding, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 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 rrake the records and information of reasonable use to the other parent. 2. The Mother shall have primary physical custody of the Children. 3. The Father shall have partial physical custody of the Children on alternating weekerlds from Friday at 6:00 p.m. through SUnday at 7:00 p.m. for the remainder of the sUlllller in 2000 and during the school year. In addition, the Father shall have custody every week from 6:00 p.m. on Tuesdays through Wednesday morning when the Father shall return the Children to the Mother's residence (if the Children do not have school) or transport the Children to school no earlier than 8:30 a.m. on school days. The Father's Tuesday overnight periods of custody shall begin on July 25, 2000. Notwithstanding the foregoing, the Father shall have custody of the Children for 2 consecutive weekends from July 28 through July 30 and from August 4 through August 6, the Mother shall have custody of the Children during the following two consecutive weekends and the parties shall begin alternating weekends thereafter. The Mother shall have custody oi the Children for vacation from August 12 chrough August 19, 2000. 4. Beginning in 2001, the parties shall share having custody of the Children during the sUll1ller school break, with the specific arrangements to be made by agreement of the parties. . :~ "~ ,- ~ tt 5. 'll1e parties shall share or alternate having custody of the Children on holidays as follows: A. CBR:rS'D!AS: The Chrisbnas holiday shall be divided into Segment A, which shall run fran 7:00 p.m. on the last day of school before the holiday through Chrisbnas Day at 12:00 noon, Segment B, which shall run fran Chrisbnas Day at 12:00 noon through December 28 at 12:00 noon, and Segment C, which shall run fran December 28 at 12:00 noon through the day before school resumes at 7:00 p.m. In even numbered years, the Mother shall have custody of the Children during Segments A and C and the Father shall have custody during Segment B. In odd numbered years, the Father shall have custody of the Children during Segments A and C and the Mother shall have custody during Segment B. B. TBANKSGrVlNG: The Thanksgiviqg holiday shall run from the Wednesday before Thanksgiving at 7:00 p.m. through the Friday after Thanksgiving at 7:00 p.m.. The Father shall have custody of the Children over the Thanksgiving holiday in even numbered years and the Mother shall have custody of the Children over the Thanksgiving holiday in odd numbered years. C. MmD,UAL DAY/LABCR DAY: The Memorial Day and Labor Day holiday periods shall run fran the Sunday before the holiday at 7:00 p.m. through the day of the holiday at 7:00 p.m. In even numbered years, the Mother shall have custody of the Children on Memorial Day and the Father shall have custody on Labor Day. In odd numbered years, the Father shall have custody of the Children on Memorial Day and the Mother shall have custody on Labor day. D. l'v~-a&<'S DAY/FM.'BER'S DAY: The Mother shall have custody of the Children every year on Mother's Day fran 9:00 a.m. until 7:00 p.m. and the Father shall have custody of the Children every year on Father's Day fran 9:00 a.m. until 7:00 p.m. E. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 6. with the exception of the Father's weekday periods of partial custody .when the Father shall transport the Children to the Mother's residence or to school, the party receiving custody of the Children shall be responsible to provide transportation for the exchange of custody. 7. unless otherwise directed by the Court or arranged by agreement of the parties, the Children shall remain enrolled in the East pennsboro School District. 8. In the event either party intenCs to relO"'...ate his or her residence; that party shall provide at least 60 days advance notice of the relocation to the other party to allow sufficient opportunity to modify the custody arrangements by agreement or Court order prior to the relocation. ,~-~.~,I-' - ~.' . -Ifl~, 9. In the event either party is unavailable to provide care for the Children during his or her period of custody for a 4 hour period or longer, that party shall first contact the other p:lrty to offer the other party the opportunity to provide the care before contacting third party caregivers. 10. Each p:lrty shall ensure that the Children complete their homework assignments and attend their regularly scheduled activities during that party's periods of custody. 11. This Order is entered pursuant to an agreement of the p:lrties 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 OOURT, /18~ 8S2i:~LrJ. cc: Mindy S. Goodman, Esquire - COunsel for Father Diane S. Baker, Esquire - COunsel for Mother "---- TRUE COpy FROM RECORD In Testimony whereof, I here unto set my hand and the ~ said ~1sIe. Pa. ~~n~o~P . ~~~ PnIII'Ionotary ,~" '~A JAMES R. HAWK, : IN THE COORT OF CDMMaiI PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . . vs. : NO. 00-3028 CIVIL TERM : DEBORAli S. MOGEL, . CIVIL ACTION - LAW . Defendant . CUSTODY . CUSI.tlDY CCNCILIATICIiI &MIARY REPCRI.' IN ACCClmANCE Wl'J.'B CDmERLAND CDDlIJ'J.'Y RDLE OF CIVIL PR('"J<lO.llCE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRI.'H CDRRIl:NTLY IN ClJS'~()Ui: OF Andrew J. Hawk Ariel J. Hawk Arika J. Hawk August 6, 1986 February 8, 1991 March 14, 1992 Mother Mother Mother 2. A COnciliation COnference was held on July 25, 2000, with the following individuals in attendance: The Father, James R. Hawk, with his counsel, Mindy S. Goodman, Esquire, and the Mother, Deborah S. Mogel, with her counsel, Diane S. Baker, Esquire. 3. The parties agreed to entry of an Order in the form as attached. ~d-~,~O Date a . Dawn S.~ Custody Conciliator --l "~~,." CERTIFICATE OF SERVICE I hereby certify that on this /a..iJ7 day of ()c/o/;;e, , 2000, a true and ,~ !) " ~; correct copy of the foregoing document was served on the following persons by United , " , ].' ", " States Mail, postage prepaid, addressed as follows: Mindy S. Goodman, Esquire 2080 Linglestown Road Harrisburg, P A 1711 0 I ? , , Respectfully submitted, Q/o~,(J?2~Y--- Diane S. Baker Supreme Court ill #53200 27 South Arlene Street P.O. Box 6443 Harrisburg, PA 17112-0443 (717) 671-9600 ~ I~ ,~ , ~ ~--- ---,,' <', .-- " f' n JAMES R. HAWK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA b I', r >, , , V. 00-3028 CIVIL TERM CIVIL ACTION - LAW , [-j DEBORAH S. MOGEL, Defendant CUSTODY IN RE: PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 3rd day of November, 2000, after a brief hearing, the Plaintiff's petition for Special .f li Relief is granted insofar as our prior order of August 3, 2000, is amended to provide that father shall have partial :-1 " f'_i H ;: physical custody of the children each Tuesday evening from the time they are dismissed from school until Wednesday i', ~ .: r L': ::! morning at the commencement of school. The children shall ride the bus to father's home from school on Tuesday and to school on Wednesday. In all other respects, our prior order of August 3, 2000, shall remain in full force and effect, and the remaining requests for relief in Plaintiff's petition are denied. It appears to the Court that a conciliation conference in this matter will be futile. Therefore, a full blown custody hearing is scheduled for Friday, November 17, 2000, at 8:30 a.m. .....~.. Mindy S . Goodma For th n, Equire e Plaintiff James K J . ones For the D f ,Esquire e endant :mae I ,~"- ',':-- ~--..,i~l, - o'-;;j By the Court , Edward E. Guido, J. C~Jl'3,DO R~ :iiiI~.(f~ ~," I!!R'!! " ~,,""', , ". ,..,,- I Ml._ '~lIl/Il_l' , JM ~~........... ~ ~~ - -.-~ " .-. . . .- ~. i Q a (~ '-. <:;) "'Yj ? ~ -~ -Oct; <::) :::J nl,rn "'r::: 2'":n Zi;': r ,:"; [~~f C/.l.~ c,) :, j :-<~-, .~~i~ ~c! l~! ~n ~.,,~ :':~:;'C)- :sO Ofl'"i ~ "4 -.:", )>. 3J r", -< rr ll~~~>' - - " .J ,.' '~.( , NOV 13 ZO~ JAMES R. HAWK, : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . . : vs. : NO. 00-3028 CIVIL TERM : . . CIVIL ACTION - LAW DEBORAH S. MOGEL, Defendant . . : IN CUSTODY ORDER OF C'OORT AND NOW, this 8th day of November, 2000, the Conciliator, being advised by counsel that the Court has scheduled a CUstody Hearing in this matter for November 17 and therefore a Conciliation Conference is no longer necessary, hereby relinquishes jurisdiction. The Conciliation Conference scheduled for November 15, 2000 is canceled. FOR THE COURT, A:~; CUstody Conciliator >"',~ ,-.....,,: FiL~C)-O~FiC:: "j ,., ',-1_._"--"".'(\,,,,1"1\( i.",F T!'" !; ,'. ;II,Ulr'.1"',. 00 NOV I 5 1"1'..1 3' '11 ; I'" ,(:... CUMBERU~'Ji) COUNTY PENNSYLVANIA 'ij1 ," ",.' _ 1!_'""'F'~l~1' _ ~ ~ "jIif" ~_fil!~H~li~~~'!'J!il~~!_~~l~~~~I!R!~~~Wll!~ . ~- -. " ~" i~ -~ " . , .:l JAMES R. HAWK, . IN THE COURT OF COMMON PLEAS OF . Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-3028 CIVIL TERM : DEBORAH S. MOGEL, : CIVIL ACTION - LAW Defendant . CUSTODY . OODER OF CXXJRT AND 1Dl, this 3 01 consideration of the attached and directed as follows: day of Custody ~l'. Conc~ ~at~on Report, , 2000, upon it is ordered 1. The Father, James R. Hawk, and the Mother, Deborah S. Mogel, shall have shared legal custody of Andrew J. Hawk, born August 6, 1986, Ariel J. Hawk, born February 8, 1991 and Arika J. Hawk, born March 14, 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 Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of this pal:'agraph each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 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 pal:'ent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. The Mother shall have primary physical custody of the Children. 3. The Father shall have partial physical custody of the Children on alternating weekends from Friday at 6:00 p.m. through Sunday at 7:00 p.m. for the remainder of the summer in 2000 and during the school year. In addition, the Father shall have custody every week from 6:00 p.m. on Tuesdays through Wednesday morning when the Father shall return the Children to the Mother's residence (if the Children do not have school) or transport the Children to school no earlier than 8:30 a.m. on school days. The Father's Tuesday overnight periods of custody shall begin on July 25, 2000. Notwithstanding the foregoing, the Father shall have custody of the Children for 2 consecutive weekends from July 28 through July 30 and from August 4 through August 6, the Mother shall have custody of the Children during the following two consecutive weekends and the parties shall begin alternating weekends thereafter. The Mother shall have custody of the Children for vacation from August 12 through August 19, 2000. 4. Beginning in 2001, the parties shall share having custody of the Children during the summer school break, with the specific arrangements to be made by agreement of the parties. -" ~" .,J "'~, .. . 5. The parties shall share or alternate having custody of the Children on holidays as follows: A. CIlRISTMl\S: The Christmas holiday shall be divided into Segmlant A, which shall run from 7:00 p.m. on the last day of school before the holiday through Christmas Day at 12:00 noon, Segment B, which shall run from Christmas Day at 12:00 noon through December 28 at 12:00 noon, and Segment C, which shall run from December 28 at 12:00 noon through the day before school resumes at 7:00 p.m. In even numbered years, the Mother shall have custody of the Children during Segments A and C and the Father shall have custody during Segment B. In odd numbered years, the Father shall have custody of the Children during Segments A and C and the Mother shall have custody during Segment B. B. THANKSGIVING: The Thanksgiving holiday shall run from the Wednesday before Thanksgiving at 7:00 p.m. through the Friday after Thanksgiving at 7:00 p.m. The Father shall have custody of the Children over the Thanksgiving holiday in even numbered years and the Mother shall have custody of the Children over the Thanksgiving holiday in odd numbered years. C. ~ DAY/LABOR DAY: The Memorial Day and Labor Day holiday periods shall run from the Sunday before the holiday at 7:00 p.m. through the day of the holiday at 7:00 p.m. In even numbered years, the Mother shall have custody of the Children on Memorial Day and the Father shall have custody on Labor Day. In odd numbered years, the Father shall have custody of the Children on Memorial Day and the Mother shall have custody on Labor day. D. MarDER'S DAY/FATHER'S DAY: The Mother shall have custody of the Children every year on Mother's Day from 9:00 a.m. until 7:00 p.m. and the Father shall have custody of the Children every year on Father's Day from 9:00 a.m. until 7:00 p.m. E. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 6. with the exception of the Father's weekday periodS of partial custody when the Father shall transport the Children to the Mother's residence or to school, the party receiving custody of the Children shall be responsible to provide transportation for the exchange of custody. 7. Unless otherwise directed by the Court or arranged by agreement of the parties, the Children shall remain enrolled in the East pennsboro School District. 8. In the event either party intends to relocate his or her residence, that party shall provide at least 60 days advance notice of the relocation to the other party to allow sufficient opportunity to modify the custody arrangements by agreement or Court Order prior to the relocation. -~ ~ " ~ 1 ~ -- -,."'~-,:;- : j:j , 9. In the event either party is unavailable to provide care for the Children during his or her period of custody for a 4 hour period or longer, that party shall first contact the other party to offer the other party the opportunity to provide the care before contacting third party caregivers. 10. Each party shall ensure that the Children complete their homework assignments and attend their regularly scheduled activities during that party's periods of custody. 11. 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. " f' J. cc: Mindy S. Goodman, Esquire - COunsel for Father Diane S. Baker, Esquire - COunsel for Mother ) CoF't.s I'"h~w.. P /400 ~ ~- ~" L -iii Hi 'il Iii ] 'I :1 , JAMES R. HAWK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-3028 CIVIL TERM : DEBORAH S. MOGEL, . CIVIL ACTION - LAW . Defendant : CUSTODY CUSTODY CUl/CILIATICI!i SUMMARY REPORT :1 II I, " 'I I] ::1 ;1 I IN AcxmDANCE WITH CUMBERLAND CCllJNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: .:, ';1 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Andrew J. Hawk Ariel J. Hawk Arika J. Hawk August 6, 1986 February 8, 1991 March 14, 1992 Mother Mother Mother 2. A Conciliation Conference was held on July 25, 2000, with the following individuals in attendance: The Father, James R. Hawk, with his counsel, Mindy S. Goodman, Esquire, and the Mother, Deborah S. Mogel, with her counsel, Diane S. Baker, Esquire. 3. The parties agreed to entry of an Order in the form as attached. ~ c2 ~,g.(X)o Date ~~ Custody Conciliator ''<, ''''' ,,,,-~, 0",.'." ~-.".,.,-,- -~ ~ ~ J-1iiiiIiiii t.:- if:,l:~ ,-,' M--j 10: tt-3 e."", "..'J'I""Y CU'v';,~~:::':." CUl 1\ i PcNh!SYLVAi-,J!A - "_~,,,~c~~ ~~~K'tIIlR'I_l~"'~~ ~~ _ ,. "' ,-.Pl!_!Wi'l>" 0=. ~~ ~ " , ... . JAMES R. HAWK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-3028 CIVIL TERM CIVIL ACTION - LAW DEBORAH S. MOGEL, Defendant CUSTODY IN RE: CUSTODY MODIFICATION ORDER OF COURT AND NOW, this 17th day of November, 2000, after he~ring, our order of August 3, 2000, is modified as follows: Paragraph 2 is modified to read that the father shall have primary physical custody of the children. Paragraph 3 is modified to read that mother shall have partial physical custody of the children every other weekend from Friday at 6:00 p.m. until Sunday at 7:00 p.m. In addition, mother may visit with the children one evening per week from after school until 8:00 p.m. Mother is to pick the children up and return them to father's home during said period of visitation. Mother shall have primary physical custody of the children every summer from the day after school is out until one week before school begins. During said periods, father shall have partial physical custody every other ~eekend, and for one full week to correspond with his vacation. Father must advise mother of that full week no . .1 - , >-<;.- . .. \ later than March 15th of each year. Paragraph 4 is deleted. Paragraph 6 is modified to provide that, with the exception of the weeknight visitation, mother shall pick the children up from father's residence to commence her periods of partial custody, and father shall retrieve the children from mother at the conclusion of said period of partial custody, and vice versa during the summer months. Paragraph 9 is deleted. Paragraph 11 is modified to provide that the parties may modify the terms of this order by mutual consent. This Court shall retain jurisdiction. In all other respects, our order of August 3, 2000, shall remain in full force and effect. By the Court, Edward E. Guido, J. :mae !CTfL;aJ ~ I /~ 2J--oo RX3 Mindy S. Goodman, Esquire For the Plaintiff James K. Jones, Esquire For the Defendant :" ~ , -~', ,~ " , I "'~. " '" "'!I""_.r-<'_.,.,.,.~4_"!'""--~,_ ![IIlI'IJ OF ') '>, [~\Jl 0; ? 9 CU~,1!:kFiL~;~'~~' COUNTY PENNSYl}J!~,N!A J.~ ~ ,,~ Ie ~ 1"'l"'1"" - fJ "I'!l'!I!'J. -,;- ~iIll~ff",~" . JAMES R. HAWK PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. 00-3028 CIVIL ACTION LAW DEBORAH S. MOGEL DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, Angust 25, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective cOlmsel appear before Dawn S. Snnday, Esq. , the conciliator, at 39 West Main Street, Mechanicsbnrg, PA 17055 on Wednesday, September 22, 2004 at 10:00 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearil1J!:. FOR THE COURT. By: Isl Dawn S. Sunday. Esq. Custody Conciliator mhc 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 ATIORNEY AT ONCE. IF YOU DO NOT HAVE AN ATIORNEY 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 . ~ ". ~lllII!I ^"_~,'~.."..,,~...,~, - t\~fr\ct. Of "\HE ??OI\-10N01~P:'l 16U~ ~UG 2& p\'\ 3: \ & C\JMB~r.\)~'4D couNT'< P6'41\\S{L\lt>N\,b.. <;f';2f~ -t:)l/' lid - t/IJff ~ 7' ~ ~ <;f.~-t)f' /!~ ~ :; ~ Y<;JI- .~l( ~ ~;;t.4' ~ 1III~~ll!'Il1"" '"C" __~ ,_ " _ ~Wif!lI!IW.fI:'.t"I~'i'-"#'!~[(W"t'W_~!1l~'~ " ~'iI,,~~'f*~ .' ~~""''-II'''-1-r.!\! ~. [ -_c - : , t-; JAMES R. HAWK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-3028 Civil Term DEBORAH S. MOGEL, Defendant : CIVIL ACTION - IN CUSTODY ORDER OF COURT You, James R. Hawk, have been sued in court to OBTAIN custody, partial custody or visitation of the child: Ariel Hawk. You are ordered to appear in person at ,on , at _.M., for o a conciliation or mediation conference. o a pretrial conference. o a hearing before the court. If you fail to appear as provided by this order, 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 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 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. BY THE COURT: Date J. " I I JAMES R. HAWK, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-3028 Civil Term DEBORAH S. MOGEL, Defendant : CIVIL ACTION - IN CUSTODY ORDER OF COURT AND NOW, the _ day of ,200--, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before, , Esquire, the conciliator, at on the _ day of ,200_, at .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 the entry of a temporary or permanent Order. For the Court, By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans witb 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. 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 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 - r ~,;il JAMES R. HA WI(, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-3028 Civil Term DEBORAH S. MOGEL, Defendant : CIVIL ACTION - IN CUSTODY PETITION TO MODIFY CUSTODY 1. The Petition of Deborah S. Mogel respectfully represents that on November 17, 2000 an Order of Court was entered for Partial Custody, a true and correct copy of which is attached. 2. This Order should be modified because the minor child Arie! Hawk, expresses a strong desire to live primarily with her mother. 3. This Order should be modified because over the years, the minor child Ariel Hawk has developed significant relationships with her mother's church family and it's youth group that are not fostered under the current custody arrangement by the father. 4. This Order should be modified because the minor child's faith is a fundamental aspect of the child's life and directly impacts the child's best interests and well-being. 5. PetitionerlMother is ready, willing and able to care for the minor child Arie! Hawk. 6. The remaining minor children have not expressed an interest in changing the existing custody arrangement. - .' '[ --, WHEREFORE, Petitioner requests that the Court modifY the existing Order for Partial Custody because it will be in the best interest and of the children. OAa J:4f\/ Christopher J.~Keller, Esquire Supreme Court ill 86889 Attorney for DefendantlPetitioner 101 South Market Street Mechanicsburg, P A 17055 (717) 790-5451 I -I. -''''- t ,,- VERIFICATION I verify that the statements made in the attached complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: ~/J7 /at{ / I C\)t~1l\ Sl1\, A f)Zj.t Debo~ S. Mogel r 0 ~ I JAMES R. HAWK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-3028 CIVIL TERM CIVIL ACTION - LAW DEBORAH S. MOGEL, Defendant CUSTODY IN RE: CUSTODY MODIFICATION ORDER OF COURT AND NOW, this 17th day of November, 2000, after hearing, our order of August 3, 2000, is modified as follows: Paragraph 2 is modified to read that the father shall have primary physical custody of the children. Paragraph 3 is modified to read that mother shall have partial physical custody of the children every other weekend from Friday at 6:00 p.m. until Sunday at 7:00 p.m. In addition, mother may visit with the children one evening per week from after school until 8:00 p.m. Mother is to pick the children up and return them to father's home during said period of visitation. Mother shall have primary physical custody of the children every summer from the day after school is out until one week before school begins. During said periods, father shall have partial physical custody every other weekend, and for one full week to correspond with his vacation. Father must advise mother of that full week no ~ ~~ I I "" later than March 15th of each year. Paragraph 4 is deleted. Paragraph 6 is modified to provide that, with the exception of the weeknight visitation, mother shall pick the children up from father's residence to commence her periods of partial custody, and father" shall retrieve the children from mother at the conclusion of said period of partial custody, and vice versa during the summer months. Paragraph 9 is deleted. Paragraph 11 is modified to provide that the parties may modify the terms of this" order by mutual consent. This Court shall retain jurisdiction. In all other respects, our order of August 3, 2000, shall remain in full force and effect. By, the Court, Edward E. Guido, J. James K. Jones, Esquire For the Defendant r RUE COPY FROM RECORD !1l T ll,nimllny wn:>ro!lf, 111a,'<j umo :lSt my llano and the ~l 01 &:id C 'It at milsle. PI. r~~~ {~ 0 _ Prothlmoml'jl :mae !.crp-L; <V 4Jl 11- 2~-oo IiX.s Mindy S. Goodman, Esquire For the Plaintiff I . . , , JAMES R. HAWK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 00-3028 Civil Term DEBORAH S. MOGEL, Defendant : CIVIL ACTION - IN CUSTODY CERTIFICATE OF SERVICE I, Christopher J. Keller, Esquire, attorney for Defendant, hereby certifY that I served a true and correct copy ofthe foregoing Petition on James R. Hawk, Plaintiff, on the date and in the manner listed below. United States First Class Mail. Postage Prepaid to: James R. Hawk 505 First Street P.O. Box 311 Summerdale, P A 17093 Date: go/;7 j;'f , Chri~~ Attorney for Defendant Supreme Court ill 86889 101 South Market Street Mechanicsburg, P A 17055 (717) 790-5451 lilllillllf '~"\j".'<-i', "-I~~[i?J;UI!I~' -i..c-~-...i\:l,- .. liii " i ."",.e",,', .- , ." ,-~ '."....' . ....i..',;,.,., '...... ,,' ml ., ~ p ig. ~ () - '}.J 0 ~ 0 0 ...., r c::> 0 r;~: c::, ,"'I ...c: .J,~~ ~ :1'1," :rJ..,., ~ !~( l;: c: ["11..1.. G") r:n ~t:J 0) ?) 1 .~~..\C) J -[) :,c:H -~ ~';?('5 -"'" c5fn I);> u...1 )"~,: C) ~D 0) -< , "~'Ii i f . . ;' JAMES R. HAWK, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLA."ID COUNTY, PENNSYLVANIA v, NO, 00-3028 Civil Term DEBOaAII S. MOGEL, DefeadaBt : CIVIL ACTION -IN CUSTODY ORDER OF COURT You, James R. Hawk, have been sued in court to OBTAIN custody, partial custody or visitation of the child: Ariel Hawk. You are ordered to appear in person at ,on ". 1 ) on'. /f(,....A1,(:...L~( _.M., for o a conciliation or mediation conference. o a pretrilll conference. o a hearing before the court. OfF ,.{..- Il(w"t /}4-4!" -- If you fail to appear as provided by this order, 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 TmS PAPER TO VOUR 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 .GEtI,J:GAL HELP. CUMBERLAND COUNTY BAR ASSOCIA nON 2 Liberty Avenue Carlisle,PA 17013 (717) 249-3166 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 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 courl. You must attend the scheduled conference or hearing. BY THE COURT: Date 1. I , JAMES R. HAWK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 00-3028 Civil Term DEBORAH S. MOGEL, Defendant : CIVIL ACTION - IN CUSTODY ORDER OF COURT AND NOW, the _ day of ,200_, upon consideration of the attached Complaint, it is hereby direct~a.that the parties and their respective counsel appear before, , ,E~ uire, the conciliator, at ..~.. on the _ day of 200-, at . /'./ .M., for a Pre-Hearing Custody Conference. At such conference, an eff) will de to resolve the issues in dispute, or if this cannot be accomplished, to define and narrow sues to be heard by the court, and to enter into a temporary order. All children age five or ~~y also e present at the Conference. Failure to appear at the Conference may provide grrds for the entry ~emporary or permanent Order. // For the Cdv!t, / \ L \ By: Custody Conciliator 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. 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 JAMES R. HAWK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-3028 Civil Term DEBORAH S. MOGEL, Defendant : CIVIL ACTION - IN CUSTODY AMENDED PETITION TO MODIFY CUSTODY 1. The Petition of Deborah S. Mogel respectfully represents that on November 17, 2000 an Order of Court was entered for Partial Custody, a true and correct copy of which is attached. 2. This Order should be modified because the minor children Ariel J. Hawk, DaB 02/08/1991 and Arika J. Hawk, DaB 03/14/1992, express a strong desire to live primarily with their mother. 3. This Order should be modified because over the years, the minor child Ariel J. Hawk has developed significant relationships with her mother's church family and it's youth group that are not fostered under the current custody arrangement by the father. The minor child Arika J. Hawk, has also developed significant relationships with children at mother's home. 4. This Order should be modified because, girls of this age, as they are entering into young womanhood, and have expressed a strong desire to live with their mother, would greatly benefit from living with their mother during these fOlmative years. 5. This Order should be modified because the minor children's faith is a fundamental aspect of the their lives and directly impact the children's best interests and well-being. 6. PetitionerlMother is ready, willing and able to care for the minor children Ariel J. Hawk and Arika J. Hawk. 7. The remaining minor child, Andrew 1. Hawk, DOB 08/06/1986, has not expressed an interest in changing the existing custody arrangement. The remaining minor child is the oldest child, who should be graduating from high school soon. WHEREFORE, Petitioner respectfully requests that the Court modify the existing Order for Partial Custody, by awarding Petitioner/mother primary physical custody of the two minor girls, because it will be in the best interest and of the children to do so. a~ ~A/L- Christopher J;/Keller, Esquire Supreme Court ill 86889 Attorney for Defendant/Petitioner 101 South Market Street Mechanicsburg, PA 17055 (717) 790-5451 I '" - '---'f~;;;?' VERIFICATION I verify that the statements made in the attached complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. g4904 relating to unsworn falsification to authorities. Date: /(}/lr/oq I I ~)- ~~ , , .-, JAMES R. HAWK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-3028 CIVIL TERM CIVIL ACTION - LAW DEBORAH S. MOGEL, Defendant CUSTODY IN RE: CUSTODY MODIFICATION ORDER OF COURT AND NOW, this 17th day of November, 2000, after hearing, our order of August 3, 2000, is modified as follows: paragraph 2 is modified to read that the father shall have primary physical custody of the children. Paragraph 3 is modified to read that mother shall have partial physical custody of the children every other weekend from Friday at 6:00 p.m. until Sunday at 7:00 p.m. In addition, mother may visit with the children one evening per week from after school until 8:00 p.m. Mother is to pick the children up and return them to father's home during said period of visitation. Mother shall have primary physical custody of the children every summer from the day after school is out until one week before school begins. During said periods, father shall have partial physical custody every other weekend, and for one full week to correspond with his vacation. Father must advise mother of that full week no later than March 15th of each year. Paragraph 4 is deleted. Paragraph 6 is modified to provide that, with the exception of the weeknight visitation, mother shall pick the children up from father's residence to commence her periods of partial custody, and father shall retrieve the children from mother at the conclusion of said period of partial custody, and vice versa during the summer months. Paragraph 9 is deleted. Paragraph 11 is modified to provide that the parties may modify the terms of this order by mutual consent. This Court shall retain jurisdiction. In all other respects, our order of August 3, 2000, shall remain in full force and effect. By the Court, Edward E. Guido, J. James K. Jones, Esquire For the Defendant r RUE COPY FROM RECORD !11 Ttl,ltimony wf!:>recf, llleru U1'10:1St my llano and tl;e ~j 01 Sl:id ~ ll.j c'lllislll. Pa. This {~;;,y 11 ~ ~_' <-<4 /I Prottll'nOl'ary :mae !.crpt;QJ 4Jl 1/-2~-OO ~X-3 Mindy S. Goodman, Esquire For the Plaintiff , JAMES R. HAWK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 00-3028 Civil Term DEBORAH S. MOGEL, Defendant : CIVIL ACTION - IN CUSTODY CERTIFICATE OF SERVICE I, Christopher J. Keller, Esquire, attorney for Defendant, hereby certify that I served a true and correct copy ofthe foregoing Petition on James R. Hawk, Plaintiff, on the date and in the manner listed below. United States First Class Mail. Postage Prenaid to: James R. Hawk 505 First Street P.O. Box 311 Summerdale, P A 17093 Date: /0/15/1'( I ( CAI) ~~ Christopher J./Keller, Esquire Attorney for Defendant Supreme Court ill 86889 101 South Market Street Mechanicsburg, PA 17055 (717) 790-5451 d~J-';~~-- .~ i,_~"_- - MW<t '" 'II " 'rJiolJ'.'" " '-'-';;". ','. ~;u ""'M..:..,---..:;1'ri.lli' 'u ""'. ",__ rr ~ Ji . \N ..... 0 '" <\ ...\ ~ r c -l: f9 ~ ,I ,.,.', '1IiIlf""'" ...~fi ",I , I! Ii i~i II II II II i'"I, " Ii I ,..., t.=::l C"...;I .r:- i'::) Ie ~ -~ o --n :;:1- F11r}d --OHl :ny (~Q .~~ ""rj (~'J} .::-,;.<;. ) ,:5rn ,., ~ Ul :q ~I,.. r:~1 01 o --- ""' , " JAMES R. HAWK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. NO. 00-3028 CIVIL ACTION LAW DEBORAH S. MOGEL, Defendant IN CUSTODY ORDER OF COURT AND NOW, this this Wednesday, Anl!ust 25th, 2004 , upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday. Esquire, the Conciliator, at 39 West Main Street. Mechanicsburl! PA 17055 ,on Tuesday, October 19, 2004, at 9:00 a.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 defme 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:--.JsI Dawn S. Sundav. ESQ. Custody Conciliator 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. 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,P A 17013 Telephone (717) 249-3166 1iIlI_ '~J~~,--~-j"';;';'-J,",~;,;-"~o'i~,",--" ' ' , ,... ....Df' ""..~,,,,",l . """."", '"",,,' lIliIlIi h 1""==.",1 , ",' _.:c.o' " '","" .,,, ",'- ',,', '''''' , ,.,., 'i t1 i " I , 'I I '1 I I () t--..) c:; C~ 0 ~ ~n C> ..... ~ ~:JJ /"'r- -orn esT :::I'd .L--H " c'5 a:::::n1 i':5 ;:;! ~ 22 '" ' " ' '-0'" ~> ".' _,. .c_".' . ~' , ,. ,. , JAMES R. HAWK Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 00-3028 CNIL ACTION LAW DEBORAH S. MOGEL Defendant IN CUSTODY ORDER OF COURT AND NOW, this , ~ day of rJ ~ , 2004, consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: upon 1. The parties shall make the necessary arrangements for the Children to participate in therapeutic family counseling with a professional to be selected by agreement between the parties. The purpose ofthe counseling shall be to address concerns which have arisen with regard to the custody situation and to obtain guidance as to the Children's needs and arrangements which will best meet those needs. All unreimbursed costs of cOlUlseling shall be shared equally between the parties. 2. Within 60 days after completion of cOlUlseling and receipt of guidance from the counselor, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference, if necessary. 3. Pending further Order of Court or agreement of the parties, the prior Orders of this Court dated August 3, 2000 and November 17,2000 shall continue in effect. Edward E. Guido J. '^\_o~ \\'U I I I' ~.""..' ~ ~j,,, " " '-. , ,-',,-. " ~w,' .".,..-. '_ ". , . I -- ~ ".-~ , '-'^'-'- ~ --- ~iCE OF ~'fROTHClNOTN1Y 2nO~ NOV -I PM I: 06 CUI ':;,;:;n' "I',"', r"O"NITY l'Ikil,..-r'l.\....J"It 4U v U l PENNSYLVANIA ,,,"v.' ....',""",.. """"'~''''''~~"'f ,~~-~~~ - ::_~'-_r__'^~ .r.." -~- ,=" '.';', ;~ ",.1 A,,",, ,..,-, '...,,~', _ .,' ,-;~-l,,;:_ '-,k'",~_-,"~":,",,-"_--:~>.!_,,..,.~,,_ _"o'J~I_<V; " , --,,-' . ;/. . OCT 2 B 1a04 Q ({ ,. . JAMES R. HAWK Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 00- 3028 CNIL ACTION LAW DEBORAH S. MOGEL Defendant IN CUSTODY Prior Judge: Edward E. Guido CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Arie! J. Hawk Arika J. Hawk February 8,1991 March 14, 1992 Father Father 2. A conciliation conference was held on October 19, 2004, with the following individuals in attendance: The Father, James R. Hawk, with his counsel, Mindy S. Goodman, Esquire, and the Mother, Deborah S. Mogel, with her counsel, Christopher J. Keller, Esquire. 3. The Mother filed an amended Petition for Modification seeking primary physical custody of the Children, who have been in the Father's primary care by Order dated November 17, 2000. The parties discussed both the alternatives of obtaining additional information pertaining to the Children's needs and interests through the counseling process or a custody evaluation. The parties agreed to have the Children participate in counseling but that the conciliator would hold this Report and Order pending a decision by the Father as to whether he wished to proceed with an evaluation. 3. The conciliator has been advised by the Father's counsel that the Father agrees to proceed with counseling, as opposed to an evaluation, at this time and submits an Order in the form as attached reflecting the parties' agreement at the conference. f) cJ-o Ixr dC" ;:)ex) <( . Date iJ~rJf7J Dawn S. Sunday, Esquire Custody Conciliator . . .-- - " ,,- -'< "'~e ~ _.;,_ ,_on "'-"r_"-'- .... , EDWIN E. HERSHEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW TANNOR D. TORRARO, : Defendant NO. 00-3076 CIVIL TERM ORDER OF COURT AND NOW, this 1st day of November, 2004, upon consideration of the Motion of Defendant, Tannor D. Torraro, To Compel Plaintiff To Respond to Interrogatories and Request for Production of Documents, a Rule is hereby issued upon Plaintiff to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT, ~cus A. McKnight, Esq. 60 West Pomfret Street Carlisle, P A 17013 Attorney for Plaintiff t-e11arles B. Calkins, Esq. no South Northern Way York, PA 17402 Attorney for Defendant ~ :rc - ~=-~-'~"',.".~, - -= ~, ~r ,_~_Jt~ --~ ^.~ 'C " - ,-~- RlE[HJFRCE OF THE PROTHONOTARY ZOO'I NOV -I PM 3: 23 Cl Il.l;' ~-( 'I c. <. :<', ,-~r';j F'T'\y . ',",']f"'\'~~, M;""j :,1)' ';\1, ...... ,-...... .~,." h.. '_ ,~- VI '\! PENNS'rl.VtlNii\ ... ,""",~. . ~,-.p~.. J:V,. _.~~ _~ f _(I!K!'. 'I 1lIP!lII!WIlQ~""!'1'" ""T'" ,1.\!IlI