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HomeMy WebLinkAbout07-0571Suzanne Spencer Abel, Esq. 22 East Street, #6 Mt. Holly Springs, PA 17065 (717) 323-0046 spencer abel_esq@fastmail.fm IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KEITH GREENWALD, -z0 0 7 Plaintiff No.2M&CV 57I v HEIDI SHENCK, Defendant CIVIL ACTION - LAW CUSTODY NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mcis adelante en las siguientes p6ginas, debe tomar accibn dentro de los prbximos veinte (20) dias despu6s de la notificacibn de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accidn como se describe antedormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mcis aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO IMMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET 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 at 717-240-6200. 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. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KEITH GREENWALD, Plaintiff v .2vo ?7 No. 2006-CV S,7 i HEIDI SHENCK, CIVIL ACTION - LAW CUSTODY Defendant COMPLAINT FOR CUSTODY 1. The Plaintiff is Keith Greenwald, currently residing at 158 Lincoln Street, Carlisle, Cumberland County, Pennsylvania. 2 3 The Defendant is Heidi Shenck, currently residing at 18 Park Street, Mt. Holly Springs, Cumberland County, Pennsylvania. Plaintiff seeks custody of Bradley Shenck, currently residing at 158 Lincoln Street, Carlisle, Cumberland County, Pennsylvania, 10 months old (DOB 03/14/06). The child was born out of wedlock. The child is presently in the custody of Keith Greenwald who resides at 158 Lincoln Street, Carlisle, Cumberland County, Pennsylvania. During the past five (5) years, the child has resided with the following persons at the following addresses: Heidi Shenck, her boyfriend, Bambi Shenck (mother's sister), sister's boyfriend, sister's 3 young children 18 Park St., Mt Holly Springs, PA birth - 1/17/07 Keith Greenwald, Christinane Swartz 158 Lincoln St., Carlisle, PA 1/17/07 - present The mother of the child is Heidi Shenck, currently residing at 18 Park Street, Mt. Holly Springs, Cumberland County, Pennsylvania. She is single. The father of the child is Keith Greenwald, currently residing at 158 Lincoln Street, Carlisle, Cumberland County, Pennsylvania. He is single. 4. The relationship of the Plaintiff to the child is that of father. Plaintiff currently resides with the following persons: a. Christinane Swartz, Plaintiffs fiancee b. Ms. Swartz's children: i. Lisa Swartz, age 13 ii. David Hershey, age 9 iii. Faleshia Hershey, age 7 5. The relationship of the Defendant to the child is that of mother. Defendant currently resides with the following persons: a. name unknown, Defendant's boyfriend b. Bambi Shenck, Defendant's sister c. name unknown, sister's boyfriend d. Bambi Shenck's 3 children, names unknown: two boys, ages approximately 1 & 5 years, one girl, age approximately 9 years 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Page 2 Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: a. Plaintiff is providing an environment that is better situated to provide for the child's daily physical, social, emotional, and medical needs, b. Plaintiff has, and will continue to, ensure the child maintains a close relationship with Defendant. c. Plaintiff was denied all access to, and information about, the child until more than a week after the parties received the paternity tests. d. The child's basic medical needs have not been adequately addressed by Defendant. Plaintiff believes and therefore avers that child has not been seen by his doctor since he was one month old, and that child's immunization schedule lapsed. Plaintiff has brought the child's immunizations current. e. The child's basic safety and health needs have not been adequately addressed by Defendant. Plaintiff believes and therefore avers i. that child sustained an untreated burn on his upper right thigh when he rolled against the kerosene heater, ii. that Defendant brought her 9 year old niece to participate in the 10:30 pm confrontation at Plaintiffs parents' house orchestrated to Page 3 remove the child from father's protective custody, and that the niece was visibly traumatized by the events; iii. that when Plaintiff picked up the child on January 17, 2007, 1. the child was wearing only a saturated diaper; 2. Defendant's boyfriend dressed the child in clothes that were filthy, much too small, and of insufficient weight to keep the child warm in January; and 3. the diaper bag prepared by Defendant contained no food, diapers, or alternate clothing for the child, but did contain a pair of soiled ladies' underwear and a pack of rolling papers. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. No other persons are known to have or claim a right to custody or visitation of the child. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Temporary Order maintaining the status quo pending a Conciliation Conference, and an Order granting him primary physical custody of the child. Respectfully submitted, Spencer Abel Law Office Suz a Spen r Abel, Esq. Atto n ID #202443 22 East Street, #6 Mt Holly Springs, PA 17065 (717) 323-0046 Counsel for Plaintiff, Keith Greenwald Page 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KEITH GREENWALD, Plaintiff v HEIDI SHENCK, Defendant VERIFICATION No. 2006 CV CIVIL ACTION - LAW CUSTODY I VERIFY that I have personal knowledge of all facts not of record set forth in the foregoing pleading, and that such statements are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: 07 Keith Greenwald IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KEITH GREENWALD, Plaintiff No. 2006 CV v CIVIL ACTION - LAW HEIDI SHENCK, CUSTODY Defendant CERTIFICATE OF SERVICE I certify that, concurrent with filing the foregoing Complaint for Custody, 1 am this day serving a copy of same by Certified, Return Receipt Requests, First Class U.S. Mail, to the following: Heidi Shenck 18 Park Street Mt Holly Springs, PA 17065 Date: % 4 f -?L"M San O-P 0 t4 Sune Spenber Abel 22 ast Street, #6 Mt. Holly Springs, PA 17065 (717) 323-0046 spencer abel_esq@fastmail.fm C'? r., <? _. ? C__7 C 4 1 ' `.t ? r- ?? ll `i-a.. Tr Stj ? O L,rj -i] n a? ? i ?i ??? .?- ?= C3'1 "? KEITH GREENWALD IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 07-571 CIVIL ACTION LAW HEIDI SHENCK DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, February 01, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, February 08, 2007 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ ac ueline M. Verne Es q. Custody Conciliator T- IT' The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 (.p- c - e jC) FEB 16 2007 01 KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-571 CIVIL ACTION - LAW HEIDI SHENCK, Defendant IN CUSTODY ORDER OF COURT G AND NOW, this ! day of F, 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Keith Greenwald and the Mother, Heidi Shenck, shall have shared legal custody of Bradley Shenck, born March 14, 2006. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 2. The parents shall have shared physical custody of the child on a week on/week off schedule. The exchange day and time shall be Sundays at 5:00 p.m. Father's week shall begin Sunday February 18, 2007. In addition, the non-custodial parent shall have physical custody of the child on Wednesdays from 9:00 a.m. to 2:00 p.m. 3. Transportation shall be shared such that the relinquishing party shall transport to a location to be agreed to by the parties. 3 4. Neither party may remove the child from the jurisdiction without prior Order of Court or agreement of the parties. 5. Neither party shall do or say anything nor permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the chila as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. 6. 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. Another Custody Conciliation Conference is scheduled for April 18, 2007 at 8:30 a.m. BY YHE COURT, J. cc: Suzanne Spencer Abel, Esquire, Counsel for Father 7 Thomas Williams, Esquire, Counsel for Mother AY Q"." ,2. 20 6 t i(, t?S v a i I z .>> ? az ?fl? d 3HI 30 .? ,"sdt°i--( :n4 KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-571 CIVIL ACTION - LAW HEIDI SHENCK, Defendant : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Bradley Shenck March 14, 2006 shared 2. A Conciliation Conference was held in this matter on February 15, 2007, with the following in attendance: The Father, Keith Greenwald, with his counsel, Suzanne Spencer Abel, Esquire, and the Mother, Heidi Shenck, with her counsel, Thomas Williams, Esquire. The parties agreed to an Order in the form as attached. '?' - I S--o I A - - Date acq ine M. Verney, Esquire Custody Conciliator APR $ 6 KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-571 CIVIL ACTION - LAW HEIDI SHENCK, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 26`h day of April, 2007, the parties being satisfied with the current Order of Court, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, k . V I k- ac line M. Verney, Esquire, C stody Conciliator ?i11'-lr . I',, 7 - YE 1o 6 d •Z Wd 9Z M LOOZ 3RL JO 301340-031W F: \FILES\General\Cwrent\ 12325\ 12325. L pet pet 1 /tde Revised: 6/20/07 9:22AM Thomas J. Williams, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 17512 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant/Petitioner KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-571 : CIVIL ACTION - LAW HEIDI SHENCK, Defendant/Petitioner IN CUSTODY PETITION TO MODIFY CUSTODY AND NOW, comes the Defendant, Heidi Shenck (hereinafter, "Mother"), by and through her attorneys, MARTSON LAW OFFICES, and seeks full legal and physical custody ofBradley Shenck, born March 14, 2006, and, in support thereof, avers as follows: 1. The current Custody Order issued on February 16, 2007, essentially gave equally shared custody of Bradley Shenck, born March 14, 2006, to both parties. A copy of said Order is attached hereto and marked as Exhibit "A." 2. Since that time, the child has had a series of accidents while in the custody of Father, the most serious of which was a comminuted skull fracture requiring a medical evacuation flight to Hershey Medical Center where the child was admitted for five (5) nights. 3. As a result of these injuries, Cumberland County Children & Youth Services petitioned to have the child declared dependent and full custody awarded to Mother. A copy of said Order is attached hereto and marked as Exhibit "B." 4. At the dependency hearing on June 14, 2007, Martin Dias, M.D., a pediatric neurosurgeon at Hershey Medical Center, who attended the child during his admission there, testified that the manner of injury (a simple fall) was highly unlikely to have caused the serious, life threatening, comminuted skull fracture actually suffered, and that this type of injury would almost certainly have required a strong blow to the head, either by the child being thrown against an object, or an object striking the child's head. 5. Father's living facilities are primitive at best. There is no indoor plumbing. The occupants are required to use an outdoor Port-A-Potty without doors. There is only one bedroom. There are several other children, some teenagers, who also live in the residence. There are at least six (6) dogs, as well as other animals. WHEREFORE, Petitioner-Mother, Heidi Shenck, requests Your Honorable Court to award full legal and physical custody to her. Respectfully submitted, MARTSON LAW OFFICES By 1M X f? Thomas J. W 1 ams, Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Petitioner - Defendant Heidi Shenck Date: June 20, 2007 FEE I t, Z001 yj KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-571 CIVIL ACTION - LAW HEIDI SHENCK, Defendant IN CUSTODY ORDER OF COURT AND ' NOW, this ? day of Fpteft^.*? , 2007, upon /( consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Keith Greenwald and the Mother, Heidi Shenck, shall have shared legal custody of Bradley Shenck, born March 14, 2006. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 2. The parents shall have shared physical custody of the child on a week on/week off schedule. The exchange day and time shall be Sundays at 5:00 p.m. Father's week shall begin Sunday February 18, 2007. In addition, the non-custodial parent shall have physical custody of the child on Wednesdays from 9:00 a.m. to 2:00 p.m. 3. Transportation shall be shared such that the relinquishing party shall transport to a location to be agreed to by the parties. 4. Neither party may remove the child from the jurisdiction without prior Order of Court or agreement of the parties. EXHIBIT "A" 5. Neither party shall do or say anything nor permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the chilct as to the other parent, or hamper the tree and natural development of the child's love and respect for the other parent. 6. 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. Another Custody Conciliation Conference is scheduled for April 18, 2007 at 8:30 a.m. cc: Suzanne Spencer Abel, Esquire, Counsel for Father Thomas Williams, Esquire, Counsel for Mother wt ,0 Tammy Ybw ,Qf, 1 hire oft set trly hanc nd the seal of said at Cathie. Pa. o h 1? day aft ` ? KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-571 CIVIL ACTION - LAW HEIDI SHENCK, Defendant : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-5, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Bradley Shenck March 14, 2006 shared 2. A Conciliation Conference was held in this matter on February 15, 2007, with the following in attendance: The Father, Keith Greenwald, with his counsel, Suzanne Spencer Abel, Esquire, and the Mother, Heidi Shenck, with her counsel, Thomas Williams, Esquire. 3. The parties agreed to an Order in the form as attached. Date ' acq ine M. Verney, Esquire Custody Conciliator IN THE MATTER OF BRADLEY SHENCK BORN 3/14/06 A DEPENDENT JUVENILE kh AND NOW, this ?a day of ,1? ttit- ? [ ?rfi *1 7y)aj.>J? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CP-21-JV-122-2007 v? ORDER OF COURT -S%3v.t. , 2007, upon hearing of the above Master's Report, it is hereby ordered and directed that: Findings, recommendation, and report of the Master are approved. All reasonable efforts were made to prevent this placement. This order is deemed to be in the best interest of the child. Recommendations of the Master are modified as follows: BY THE COURT, I*\,- \. 0 J. M. L. Ebert, Jr. EXHIBIT "B" BRADLEY SHENCK CP-21-JV-122-2007 RECOMMENDATION OF MASTER Present at the hearing on June 12, 2007, were Lindsay Dare Baird, Esquire for CCC&YS; Robert Winesickle, Caseworker; Leslie Richards, Casework Supervisor; Cindy H bal, Esquire, court-appointed Guardian Ad Litem for the juvenile; Heidi Shenck, the mother; John Mangan, Esquire, court-appointed counsel for the mother; Tom Williams, Esquire, for the mother; Keith Greenwald, the father; Sean Shultz, Esquire, court-appointed counsel for the father; Linda Rosenberry, CASA; Julie Baughman, CASA; and Mark Dias, M.D., by telephone. . . This hearing is for the benefit of Bradley Shenck who is just a little over one year old. He was seen on May 30th, 2007, at Carlisle Regional Medical Center and then life flighted to Hershey Medical Center as a result of injuries to his skull. Dr. Mark Dias, a board certified pediatric neurosurgeon, testified that Bradley suffered a large and comminuted (that is branched) skull fracture in the back of his skull and that he developed a subdural hematoma which was potentially life threatening. The Doctor reviewed the father's report that the son had fallen backwards and hit his head on a hard plastic riding toy. The Doctor felt that such an explanation for the injury, although in theory possible, was in fact almost inconceivable. The doctor felt that an injury of this magnitude would almost only occur from a fall from a considerably greater height, from the child being slammed up against a hard object or from being struck by a hard object. The Agency is having the x-rays of the injury reviewed by Dr. Danielle Boal, who is a pediatric radiologist at Hershey Medical Center, to gain further insight into the cause of the injury. The child was in the care and custody of his father Keith Greenwald at the time he sustained the injury. The Agency caseworker indicates that the child's mother, Heidi Shenck, has been very cooperative and she is believed to be an appropriate caretaker for the child. It is recommended that Bradley Shenck be found to be a dependent juvenile by clear and convincing evidence, and that he be placed in the care and custody of his mother Heidi Shenck. It is recommended that the juvenile's father have only supervised visits with him at the Agency office at this time. It is recommended that the juvenile's mother cooperate with the Agency and successfully complete the ParentWorks program. All reasonable efforts have been made to prevent this placement. Placement of the juvenile with his mother is deemed to be safe and in his best interest. Jams D. Flower Jr., Esquire-Master VERIFICATION The foregoing Petition is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the Petition and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. A met A Heidi A. SheAckv t:) CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams Otto Gilroy & Faller, hereby certify that a copy of the foregoing Petition to Modify Custody was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Suzanne Spencer Abel, Esquire 22 East Street, #6 Mount Holly Springs, PA 17065 MARTSON LAW OFFICES *na. Eckei6ad Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: June 20, 2007 44 ? ? c A W 4- r-3 0- ? ?? Aq ' + 3 +_ ..A ? ` KEITH GREENWALD IN THE COURT OF COMMON PLEAS OF PLAINTIFF . CUMBERLAND COUNTY, PENNSYLVANIA V. HEIDI SHENCK DEFENDANT 07-571 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Monday, June 25, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at___ 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, July 24, 2007 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ ac ueline M. Verne Es q. Custody Conciliator 12 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 *-v .vim -J?ve <a. In.7 F??D'!/ ? -,?? ? ? ??-''any ?t`?? "?? ? 0 • 'lam l ?' N Ift?in ="4 J € :01 WV 9Z Nnf LOOZ AdViQlN 0HUOW 3HL 3a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KEITH GREENWALD, Plaintiff No. 2007 - 0571 V. CIVIL ACTION - LAW HEIDI SHENCK, CUSTODY Defendant MOTION TO WITHDRAW AS COUNSEL OF RECORD AND NOW comes Suzanne Spencer Abel, Esquire, attorney for Plaintiff, and presents this Motion to Withdraw as Counsel of Record, representing as follows: 1. Movant is Suzanne Spencer Abel, Esquire, attorney for Plaintiff , with offices at 22 East Street, #6, Mt. Holly Springs, Pennsylvania 17065. 2. Petitioner is Keith Greenwald, an adult individual whose last known address is 158 Beetem Hollow Road, Newville, Pennsylvania 17241. 3. Plaintiff has moved and not provided Movant with his new address or telephone number, and has continually failed to respond to communication attempts by Movant. 4. A Conciliation Conference in this matter was scheduled for July 25, 2007, at 8:30 a.m. before Jacqueline M. Verney, Esquire, Conciliator. Plaintiff failed to contact Movant 5. Continued representation of Plaintiff by Movant would be overly burdensome to Movant's practice. Page 1 6. Moreover, Movant cannot effectively represent Plaintiff without regular communication and Movant wishes to terminate her representation of Plaintiff. 7. Movant wishes to withdraw her appearance as Plaintiff's counsel of record. 8. Movant has contacted Thomas Williams, Esquire, attorney for the Defendant, and he has no objection to the request for leave to withdraw. WHEREFORE, Movant requests your Honorable Court to provide leave of Court and Order that Movant is withdrawn as counsel of record for Keith Greenwald, Plaintiff. Respectfully submitted, Spencer Abel Law Office of III 13001AA04 4 111 ? S z nne Sp cer Abel, sq. A ney ID #202443 22 East Street, #6 Mt Holly Springs, PA 17065 (717) 264-2939 spencer _abel_esq@fastmail.fm Page 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KEITH GREENWALD, Plaintiff V. HEIDI SHENCK, Defendant No. 2007 - 0571 CIVIL ACTION - LAW CUSTODY VERIFICATION I VERIFY that I have personal knowledge of all facts not of record set forth in the foregoing pleading, and that such statements are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: u lm- *?ne Spender Abel, Esquire 22 st Street, #6 Mt. Holly Springs, PA 17065 (717) 264-2939 spencer abel_esg0fastmail.fm -r ' t % IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KEITH GREENWALD, Plaintiff v. HEIDI SHENCK, Defendant No. 2007 - 0571 CIVIL ACTION - LAW CUSTODY CERTIFICATE OF SERVICE I certify that, concurrent with filing the foregoing Motion to Withdraw as Counsel of Record, I am this day serving a copy of same by First Class U.S. Mail, to the following: Thomas Williams, Esquire Martson, Deardorff, Williams, Otto, Gilroy & Faller 10 East High Street Carlisle, PA 17013 Jacqueline Verney, Esq. Custody Conciliator 44 South Hanover Street Carlisle, PA 17013 Keith Greenwald 158 Beetem Hollow Road Newville, PA 17241 Date: Suz ne Spencer Abel 22 East Street, #6 Mt. Holly Springs, PA 17065 (717) 264-2939 spencer abel_esq@fastmail.fm r? ?? ? ;, ?t'j C_.... ° '.I- -T3 M1? =-' ? f t t 1" --E-s C _ {?.? ct .. i ? ??.. ? : C'r' JUL 2 4 2007 #? KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-571 CIVIL ACTION - LAW HEIDI SHENCK, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 24th day of July, 2007, being advised that a dependency Order is in effect, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, AY Q cq ine M. Verney, Esquire, Custo Conciliator E U? JUL 2 7 200 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KEITH GREENWALD, Plaintiff No. 2007 - 0571 V. CIVIL ACTION - LAW HEIDI SHENCK, CUSTODY Defendant ORDER of COURT AND NOW, this 30 day of 10-10? , 2007, upon consideration of the Motion of Suzanne Spencer Abel, Esquire, to withdraw as counsel of record for Plaintiff, Keith Greenwald, Suzanne Spencer Abel, Esquire is hereby withdrawn as counsel of record. , J. ti?t,dAjxSN gWfYJ , }}tk.?`) n .01 wb o£ lnr cool F:\FILES\Clients\12325 H Shenck\12325.1.pettmd2 Created: 9/20/04 0:06PM Revised: 3/18/08 1:40PM Thomas J. Williams, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 17512 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant/Petitioner KEITH GREENWALD, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2007-571 CIVIL ACTION - LAW HEIDI SHENCK, Defendant/Petitioner IN CUSTODY PETITION TO MODIFY CUSTODY AND NOW, comes the Defendant, Heidi Shenck (hereinafter, "Mother"), by and through her attorneys, MARTSON LAW OFFICES, and seeks primary custody of Bradley Shenck, born March 14, 2006, and, in support thereof, avers as follows: 1. Petitioner-Mother is Heidi A. Shenck, an adult individual currently residing at 18 Park Street, Mt. Holly Springs, Cumberland County, Pennsylvania, and resides with her minor son, Bradley Shenck, the subject of this action. 3. Respondent-Father is Keith B. Greenwald, an adult individual with a last known address of 158 Beetem Hollow Road, Newville, Cumberland County, Pennsylvania; however Mother is advised that he has moved and she does not know his present address nor who lives with him other than his girlfriend, Christine Swartz. 4. The subject of this action is the parties' son, Bradley Scott Shenck, born March 14, 2006. 5. The parties entered into an agreed Custody Order dated February 16, 2007, essentially providing for alternate weeks and divided transportation, a copy of which is attached hereto as Exhibit "A." 6. On May 30, 2007, Bradley suffered a serious head injury while in the custody of his father and was life flighted to Hershey Medical Center where he was placed in the intensive care unit for several days. 7. By Order dated June 18, 2007, Children and Youth Services awarded sole custody to Mother, subject to supervised visitations by Father, which amounted eight (8) supervised visitations between June 18, 2007, and the present. 8. Mother was recently advised by Children and Youth Services that they now permit unsupervised visitations and Father called Mother to revert back to the February 17, 2007, Order of alternating weeks. 9. Mother believes that her son is not ready for alternating weeks and questions the capability of Father and his girlfriend, Christine Swartz, to properly care for Bradley; the serious and life threatening injuries suffered by Bradley on May 30, 2007, were not the first injuries suffered by Bradley while in the custody of his father and Ms. Swartz, only the most serious. 10. Mother believes that the best interest of Bradley would be served by a Custody Order as follows: a. Primary custody to Mother with alternate weekend visits to Father; b. Transportation to be provided by Father; C. Bradley to be personally supervised by Father during his visits and under no circumstances should Bradley be left in the care of Christine Swartz; d. Father's living arrangements, including the address and who he lives with, to be disclosed to Mother at all times and updated as necessary; e. Mother to be informed of where Bradley is going to be during his visits with Father and the identity of other people involved; and f. Weekend visits to be coordinated with Mother's niece, Candace, who is close to Bradley. 11. Mother does not own a car or have a driver's license; consequently, she requests that Father provide all transportation. 12. Mother is presently on unemployment compensation and receiving no support from Father. 13. The Custody Order dated February 16, 2008, was issued by the Honorable Edward E. Guido and the Honorable M. L. Ebert, Jr., issued an Order of Court dated June 18, 2007, following a Children & Youth Hearing. 14. Father is pro se in this matter, his original attorney having withdrawn, and Mother's attorney was unable to seek his concurrence on this Petition; however, it is assumed that Father would oppose this Petition. WHEREFORE, Mother, Heidi A. Shenck, requests Your Honorable Court to schedule a prompt conciliation conference with respect to Mother's custody requests described herein. Respectfully submitted, MARTSON LAW OFFICES By 1A.Wt," 'A L 01 0 Thomas J. illiams, Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Petitioner - Defendant Heidi Shenck Date: March 18, 2008 FEb 16 zoo/ 1)41 KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-571 CIVIL ACTION - LAW HEIDI SHENCK, Defendant IN CUSTODY ORDER OF COURT A AND NOW, this day of F , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Keith Greenwald and the Mother, Heidi Shenck, shall have shared legal custody of Bradley Shenck, born March 14, 2006. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 2. The parents shall have shared physical custody of the child on a week on/week off schedule. The exchange day and time shall be Sundays at 5:00 p.m. Father's week shall begin Sunday February 18, 2007. In addition, the non-custodial parent shall have physical custody of the child on Wednesdays from 9:00 a.m. to 2:00 p.m. 3. Transportation shall be shared such that the relinquishing party shall transport to a location to be agreed to by the parties. 4. Neither party may remove the child from the jurisdiction without prior Order of Court or agreement of the parties. ?l EXHIBIT "A" 5. Neither party shall do or say anything nor permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the chila as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. 6. 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. Another Custody Conciliation Conference is scheduled for April 18, 2007 at 8:30 a.m. BY THE COURT, J. cc: Suzanne Spencer Abel, Esquire, Counsel for Father Thomas Williams, Esquire, Counsel for Mother Olt Tammy w4 V, 101re wft set my h«afu: nd the soal of said CAx r, at CarNW, Pa. h16 117day /q .1vo l ,ter, w KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-571 CIVIL ACTION - LAW HEIDI SHENCK, Defendant : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Bradley Shenck March 14, 2006 shared 2. A Conciliation Conference was held in this matter on February 15, 2007, with the following in attendance: The Father, Keith Greenwald, with his counsel, Suzanne Spencer Abel, Esquire, and the Mother, Heidi Shenck, with her counsel, Thomas Williams, Esquire. 3. The parties agreed to an Order in the form as attached. Date acq ine M. Verney, Esquire Custody Conciliator tl? IN THE MATTER OF IN THE COURT OF COMMON PLEAS OF BRADLEY SHENCK CUMBERLAND COUNTY, PENNSYLVANIA BORN 3/14/06 A DEPENDENT JUVENILE CP-21-JV-122-2007 ORDER OF COURT th AND NOW, this 1a day of 2007, upon hearing of the above Master's Report, it is hereby ordered and directed that: Findings, recommendation, and report of the Master are approved. All reasonable efforts were made to prevent this placement. This order is deemed to be in the best interest of the child. Recommendations of the Master are modified as follows: BY THE COURT, 'k-? ?xj %10 J. M. L. Ebert, Jr. EXHIBIT "B" BRADLEY SHENCK CP-21-JV-122-2007 RECOMMENDATION OF MASTER Present at the hearing on June 12, 2007, were Lindsay Dare Baird, Esquire for CCC&YS; Robert Winesickle, Caseworker; Leslie Richards, Casework Supervisor Cindy Hribal, Esquire, court-appointed Guardian Ad Litem for the juvenile; Heidi Shenck, the mother; John Magian, Esquire, court-appointed counsel for the mother; Tom Williams, Esquire, for the mother; Keith Greenwald, the father; Sean Shultz, Esquire, court-appointed counsel for the father; Linda Rosenberry, CASA; Julie Baughman, CASA; and Mark Dias, M.D., by telephone. This hearing is for the benefit of Bradley Shenck who is just a little over one year old. He was seen on May 30th, 2007, at Carlisle Regional Medical Center and then life flighted to Hershey Medical Center as a result of injuries to his skull. Dr. Mark Dias, a board certified pediatric neurosurgeon, testified that Bradley suffered a large and comminuted (that is branched) skull fracture in the back of his skull and that he developed a subdural hematoma which was potentially life threatening. The Doctor reviewed the father's report that the son had fallen backwards and hit his head on a hard plastic riding toy. The Doctor felt that such an explanation for the injury, although in theory possible, was in fact almost inconceivable. The doctor felt that an injury of this magnitude would almost only occur from a fall from a considerably greater height, from the child being slammed up against a hard object or from being struck by a hard object. The Agency is having the x-rays of the injury reviewed by Dr. Danielle Boal, who is a pediatric radiologist at Hershey Medical Center, to gain further insight into the cause of the injury. The child was in the care and custody of his father Keith Greenwald at the time he sustained the injury. The Agency caseworker indicates that the child's mother, Heidi Shenck, has been very cooperative. and she is believed to be an appropriate caretaker for the child. It is recommended that Bradley Shenck be found to be a dependent juvenile by clear and convincing evidence, and that he be placed in the care and custody of his mother Heidi Shenck. It is recommended that the juvenile's father have only supervised visits with him at the Agency office at this time. It is recommended that the juvenile's mother cooperate with the Agency and successfully complete the ParentWorks program. All reasonable efforts have been made to prevent this placement. Placement of the juvenile with his mother is deemed to be safe and in his best interest. A ` James D. Flower Jr., Esquire-Master VERIFICATION Subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities, I hereby certify that I am the Defendant in the above-captioned action; that the foregoing Petition is based upon information which I have furnished to counsel and information which has been gathered by counsel in the preparation of the defense of this lawsuit; that the language of the Defendant is that of counsel and not of me; that I have read the Petition and to the extent they are based upon information which I have given to counsel that they are true and correct to the best of my knowledge, information and belief. ,'Heidi Shenek Date: ]it ZaoIr CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams Otto Gilroy & Faller, hereby certify that a copy of the foregoing Petition to Modify Custody was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Mr. Keith Greenwald 158 Beetem Hollow Road Newville, PA 17241 MARTSON LAW OFFICES Y T tEEaass;tig-hh enroad Ten Street Carlisle, PA 17013 (717) 243-3341 Dated: March 18, 2008 r Nb W ? rn fn KEITH GREENWALD IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2007-571 CIVIL ACTION LAW HEIDI SHENCK IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, March 19, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, April 24, 2008 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ jacqueline M. Verney, Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 A (NI 10d 01-1:1 141d 0O W HOZ :'Hi 20 , RPR 16 2008 K" KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-571 CIVIL ACTION - LAW HEIDI SHENCK, Defendant IN CUSTODY ORDER OF COURT AND NOW, this ;t day of kouj , 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A Hearing is schedgled in Court Room No. 3 , of the Cum rland County Court House, on the 111" day of , 2008, at 040 o'clock, A . M., at which time testimony win be taken. For purposes of this Hearing, the Mother shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least five days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the prior Order of Court dated February 16, 2007 in the custody matter and the June 18, 2007 Order of Court in the Juvenile Depende cy matter shall remain in ful orce r?d e? ct exce t as Ass ?j, .ri.r? modified by this Ord r 40 ?. 3. The Father, Keith Greenwdld and the Mother, eidi Shenck, shall have shared legal custody of Bradley Shenck, born March 14, 2006. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 4. Mother shall have primary physical custody of the child. 5. Father shall have periods of partial physical custody of the child on alternating weekends, beginning May 2, 2008 from Friday at 4:00 p.m. to Sunday at 4:00 p.m. The child shall be personally supervised by Father at all times, unless the identity of the adult is known to Mother. Under no circumstances may the child be supervised by Christine Swartz. 6. In the event that Mother is in need of a babysitter for more than two (2) hours, she shall contact Father or paternal grandparents and offer said babysitting opportunity to them. 7. Father shall be responsible for all transportation. 8. Neither party may remove the child from the jurisdiction without prior Order of Court or agreement of the parties. 9. Neither party shall do or say anything nor permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. 10. This Order of Court shall be filed in the Juvenile Court matter at No. CP- 21-J V-122-2007. 11. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY TW E COURT, J. cc: Thomas Williams, Esquire, Counsel for Mother -Keith Greenwald, pro se 50 Bonnybrook Road Lot 23 Carlisle, P A17013 -indsay D. Baird, Esquire, CCC&YS -'Sean Shultz, Esquire, Counsel for Father (juvenile action) Cindy Hribal, Esquire, GAL (juvenile action) ::John Mangan, Esquire, counsel for Mother (juvenile action) C-OP i es m ?Lt*LQ, '?l 10l4? 9 C : "J? N J (APR Sb 2ooee KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-571 CIVIL ACTION - LAW HEIDI SHENCK, Defendant : IN CUSTODY PRIOR JUDGE: Edward E. Guido (custody Order) M.L. Ebert, Jr. (juvenile dependency Order) CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Bradley Shenck March 14, 2006 Mother 2. A Conciliation Conference was held in this matter on April 24, 2008, with the following in attendance: The Mother, Heidi Shenck, with her counsel, Thomas Williams, Esquire and the Father, Keith Greenwald, pro se. 1. The Honorable Edward E. Guido previously entered an Order of Court dated February 16, 2007 providing for shared legal custody and shared physical custody on a week on/week off schedule. On June 18, 2007, the Honorable M.L. Ebert, Jr. entered an Order of Court at No. CP-21 -JV- 122-2007 providing for Mother to have care and custody of the child, with Father having supervised visitation. The child continues to be dependent. 2. Mother's position on custody is as follows: Mother seeks shared legal and primary physical custody, with Father having alternating weekends. Mother asserts that the child was injured while in Father's custody. Mother is currently not working and is available to care for the child. 3. Father's position on custody is as follows: Father seeks shared legal custody and shared physical custody. Father is currently unemployed and can care for the child. Father indicates that Children & Youth Services is not opposed to Father having unsupervised periods. This was confirmed by a telephone call to C&Y. 4. The Conciliator recommends an Order in the form as attached scheduling a Hearing and granting shred legal custody, Mother having primary physical custody with Father having alternating weekends. It is expected that the Hearing will require one-half day. q -,V-6 fl Date L:?Z? k U acq line M. Verney, Esquire Custody Conciliator N4 KEITH GREENWALD, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS NO. 2007-571 CIVIL ACTION - LAW HEIDI SHENCK, Defendant IN CUSTODY ORDER OF COURT AND NOW, this 11th day of June, 2008, after hearing, all prior custody orders are vacated and replaced with the following: 1. The Father, Keith Greenwald and the Mother, Heidi Shenck, shall have shared legal custody of Bradley Shenck, born March 14, 2006. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education, and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious, or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher, or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to received copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. child. 2. Mother shall have primary physical custody of the 3. Father shall have periods of partial custody of the child on alternating weekends from Friday at 4:00 p.m. until Sunday at 4:00 p.m. The child shall be personally supervised by Father at all times unless the identify of the adult supervisor is known to and approved by Mother. Under no circumstances may the Child be supervised or alone in the presence of Christine Swartz. 4. In the event that Mother is in need of a babysitter for more than two (2) hours, she shall contact Father or paternal grandparents and offer said babysitting opportunity to them. 5. Father shall be responsible for all transportation. Both parties shall insist upon a car seat being ' 1 used at all times when the child is in a vehicle. 6. Holiday visitation shall be as agreed upon by the parties. If the parties are unable to agree, the matter should be referred to conciliation. 7. Neither party may remove the child from the jurisdiction without prior Order of Court or agreement of the parties. 8. Neither party shall do or say anything nor permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect fore other parent. Edward E. Guido, J. /Thomas Williams, Esquire For the Mother ./ Keith Greenwald, Pro Se 50 Bonnybrook Road, Lot 23 Carlisle, PA 17013 .,.Lindsay D. Baird, Esquire For CCC&YS ?ean Shultz, Esquire For the Father in the Juvenile matter Cindy Hribal, Esquire GAL in the Juvenile matter -/ John Mangan, Esquire For the Mother in the Juvenile matter CCC&YS mlc &P I S mak(cc a '6 L/rz?o£3 `t NyVAIAQ,NN3 AiNnorl S£; I I WV Z I NIAr OOOZ MVW d :D 30 L-IjCt-M KEITH GREENWALD, Plaintiff / Petitioner V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2007-0571 CIVIL ACTION - LAW HEIDI SHENCK, Defendant / Respondent IN CUSTODY PETITION FOR MODIFICATION OF A CUSTODY ORDER, AND FOR ADJUDICATION OF CIVIL CONTEMPT BY RESPONDENT AND NOW, this -1!4?? day of July, 2009, comes Keith Greenwald, Petitioner, by and through his attorney, Suzanne Spencer Abel, Esq.., and who avers as follows: 1. 2. 3. 4. 5. The Petitioner is Keith Greenwald, in the above captioned matter. He is represented by legal counsel, Suzanne Spencer Abel, Esq. The Respondent is Heidi Shenck, Defendant in the above captioned matter. She is represented by Thomas Williams, Esq. The minor child at issue is Bradley Shenck, D.O.B. March 14, 2006. On June 11, 2008, the Honorable Judge Edward Guido entered an Order of Court granting Mother primary physical custody and granting Father alternating weekend periods of partial custody from Friday at 4:00 PM through Sunday at 4:00 PM. A true and correct copy of the Order is attached as Exhibit A. Since entry of the Order, Respondent has failed or refused to comply with the provisions of the Order, to wit: a. Paragraph 1 of the Order requires the parents notify each other of the child and parent's physical address. On or about June 30, 2009, Respondent vacated her 18 Park Street, Mt. Holly Springs, PA residence and has not returned. Respondent refuses to disclose her current residence to Petitioner. b. Paragraph 3 of the Order provides that Father shall have periods of partial custody from Friday at 4:00 PM through Sunday at 4:00 PM. i. Since the entry of the Order, Respondent has consistently refused to allow Petitioner to exercise his custodial rights at 4:00 PM Friday. Instead, Respondent has insisted Petitioner accept her unilaterally imposed modified visitation schedule of monthly, rather than alternating weekend, visitation beginning around 1:00 PM Saturday, ending approximately 24 hours later. ii. Petitioner was last permitted to see the child on Memorial Day weekend, from May 22 through May 24, 2009. iii. Respondent continually thwarts Petitioner's attempts to enforce his custodial rights, to wit, when Father arrives at Mother's residence as directed by Mother, Father finds neither Mother nor child are home. c. Paragraph 8 of the Order provides that neither party may say or do anything to interfere with the child's relationship with the other parent. Petitioner was advised by Respondent that Respondent intends to enlist in the armed forces, and further intends to leave the child with an undisclosed friend at an undisclosed location in a year-round camp ground. Respondent adamantly insists she would not allow the child to live with Petitioner. 6. Petitioner believes Respondent is in continuous, material contempt of the Order of Court dated June 11, 2008, and that such contempt substantially jeopardizes the best interests of the minor child's immediate and long term physical and emotional health and safety, as well as the child's relationship with Petitioner, and therefore, requests a hearing in this matter. 7. In light of Respondent's refusal to disclose the residential address of the child, as well as her ongoing efforts to reduce or eliminate Petitioner's custodial time, Respondent's actions are thwarting Petitioner's efforts to freely and naturally develop his relationship with the child. To assure Petitioner's regular access to the child, he seeks a modification of the current Order to permit alternating weekly custodial periods for the parties. 8. Further, based upon Respondent's assertion that she intends to seek out-of-state employment with the United States Armed Forces, Petitioner seeks an Order stating that primary custody of the child reverts to him should Respondent leave the area. Therefore, Petitioner believes a modification of the current order is timely because it is in the best interests of the child to maintain stability in the child's life and to permit the development of a Father-son relationship. WHEREFORE, Petitioner respectfully requests this Honorable Court to enter an Order finding Respondent in Contempt of Court, and immediately and temporarily suspend Respondent's visitation rights, pending a hearing on the matter. Additionally, Petitioner respectfully requests this Honorable Court to modify the custody order granting the parties shared physical custody of the child, in the form of the proposed order, attached as Exhibit B. Respectfully submitted, Spencer Abel Law Office I Ai A A 6 -Abd Suz nn Spence Abel, Esq. Attokne? No: 202443 P.O. Box 1161 Carlisle, PA 17013 (717) 829-3206 Home Office SpencerAbel@comcast.net KEITH GREENWALD, IN THE COURT OF COMMON PLEAS OF Plaintiff / Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 2007-0571 CIVIL ACTION - LAW HEIDI SHENCK, Defendant / Respondent IN CUSTODY VERIFICATION I verify that the statements made in this document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 1S Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Keith Greenwald KEITH GREENWALD, IN THE COURT OF COMMON PLEAS OF Plaintiff / Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 2007-0571 CIVIL ACTION - LAW HEIDI SHENCK, Defendant / Respondent IN CUSTODY CERTIFICATE OF SERVICE I certify that, concurrent with filing the foregoing Petition for Modification of a Custody Order and Adjudication of Civil Contempt by Respondent, I am this day serving a copy of same by First Class U.S. Mail, to the following counsel of record for Respondent: Thomas Williams, Esquire Manson, Deardorff, Williams, Otto, Gilroy Est Faller 10 East High Street Carlisle, PA 17013 Date: anne p ncer Abel Atty # 202443 IW. Box 1161 Carlisle, PA 17013 (717) 829-3206 Home Office SpencerAbel@comcast.net d ti KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS NO. 2007-571 CIVIL ACTION - LAW HEIDI SHENCK, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 11th day of June, 2008, after hearing, all prior custody orders are vacated and replaced with the following: 1. The Father, Keith Greenwald and the Mother, Heidi Shenck, shall have shared legal custody of Bradley Shenck, born March 14, 2006. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education, and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious, or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher, or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to received copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 2. Mother shall have primary physical custody of the child. 3. Father shall have periods of partial custody of the child on alternating weekends from Friday at 4:00 p.m. until Sunday at 4:00 p.m. The child shall be personally supervised by Father at all times unless the identify of the adult supervisor is known to and approved by Mother. Under no circumstances may the Child be supervised or alone in the presence of Christine Swartz. 4. In the event that Mother is in need of a babysitter for more than two (2) hours, she shall contact Father or paternal grandparents and offer said babysitting opportunity to them. 5. Father shall be responsible for all transportation. Both parties shall insist upon a car seat being Ekfto rr 'A '' N used at all times when the child is in a vehicle. 6. Holiday visitation shall be as agreed upon by the parties. If the parties are unable to agree, the matter should be referred to conciliation. 7. Neither party may remove the child from the jurisdiction without prior Order of Court or agreement of the parties. 8. Neither party shall do or say anything nor permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect for other parent. . uuiao, j. /Thomas Williams, Esquire For the Mother Z Keith Greenwald, Pro Se 50 Bonnybrook Road, Lot 23 C rlisle, PA 17013 Lindsay D. Baird, Esquire For CCC&YS ?ean Shultz, Esquire For the Father in the Juvenile matter Cindy Hribal, Esquire GAL in the Juvenile matter -i John Mangan, Esquire For the Mother in the Juvenile matter CCC&YS :mlc COP 146s, Mtlk L/rz?o? -l? KEITH GREENWALD, IN THE COURT OF COMMON PLEAS OF Plaintiff / Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. No. 2007-0571 CIVIL ACTION - LAW HEIDI SHENCK, Defendant / Respondent IN CUSTODY ORDER OF COURT AND NOW, this day of , 200_, upon consideration of the Conciliator's Report, all prior custody orders are vacated and replaced with the following: 1. The Father, Keith Greenwald, and the Mother, Heidi Shenck, shall have shared legal custody of Bradley Shenck, born March 14, 2006. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding his health, education, and religion. Pursuant to the terms of 23 Pa.C.S. 45309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious, or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher, or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to timely receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 2. This Court finds Mother in Contempt of Court for repeatedly failing to comply with the terms and conditions of the previous order dated June 11, 2008, i.e. failing or refusing to release the child to Father for his custodial periods, failing or refusing to provide Father with the residence address of the child and Mother, failing or refusing to contact Father or paternal grandparents for babysitting opportunities, 3. Father and Mother shall share physical custody of the child. The parents shall have week-long custodial periods beginning and ending on Fridays at 4:00 PM. 4. Neither parent shall consume, or be under the influence of, alcohol or drugs while the child is in his/her custody. EKxr -,g*% 5. The child shall not be supervised or alone in the presence of Christine Swartz. 6. In the event that Mother is in need of a babysitter for more than two (2) hours, she shall contact Father or paternal grandparents and offer said babysitting opportunity to them. 7. The parties shall share transportation, with the custodial exchanges to occur at the Sheetz in Mt. Holly Springs, PA. Both parties shall insist upon a car seat being used at all times when the child is in a vehicle. Holiday visitation shall be as agreed upon by the parties. If the parties are unable to agree, Father shall have custody from 8:00 AM through 2:00 PM and Mother shall have custody from 2:00 PM through 8:00 PM for holidays in odd years. The schedule shall be reversed in even years. Holiday visitation shall supersede the regular custody schedule. 9. Neither party may remove the child from the jurisdiction without prior Order of Court or agreement of the parties. 10. Neither party shall do or say anything nor permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. By the Court, Edward E. Guido, J. DISTRIBUTION: Thomas Williams, Esquire For the Mother Suzanne Spencer Abel, Esquire For the Father ?d ?iU ?G ?1 L'?Sh ,?e? a ? 7ti 7S KFITII GREENWALD IN THE COURT OF COMMON PLEAS OF 11L.A1\TIFF CUMBERLAND COUNTY, PENNSYLVANIA ?2007-571 CIVIL ACTION LAW HFIDI SHENCK IN CUSTODY DEFENDANT ORDER OF COURT ?NI) NOGG Friday, July 17, 2009 upon consideration of the attached Complaint, it is herchv directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, August 06, 2009 _ at 9:30 AM fora Prc-hearing Custod} Conference. At such conference, an effort will be made to resolve the issues in dispute; or il'this cannot be accomplished, to define and narrow the issues to be beard by the court, and to enter into a temporary order- Filllure to Linwar at the conference may provide grounds for entry of a temporary or permanent order. H )c 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 hearinit. FOR THE COURT, By: /s/ ac uellne M. Verne Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans kith I)ISahlllles Act of 1990. For information about accessible facilities and reasonable accommodations my ulahle to disabled individuals having business before the court, please contact our office. All arrangements mint he mode at least 72 hours prior to any hearing or business before the court. You must attend the scheduled con!'crence or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT IIA\ 1, AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET F()R 1-11 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 OF THE ', •7- .20 -&s 7,. -er 2009 JUL 20 AM 1o: !; c t&&, • 'J'A ( PEN, NSY(.,t/1 N1A &? - ,,? " Z? -",4 AUG 212009 6 KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-571 CIVIL ACTION - LAW HEIDI SHENCK, Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of '2o 0 , upon consideration of the attached Custody Conciliati n Report, it is ordered l directed as follows: 1. Father hereby withdraws his Petition for Contempt. 2. The prior Order of Court dated June 11, 2008 shall remain in full force and effect with the following modifications and additions: 3. The parties shall share physical custody of the child on a week on/week off basis, with the exchange day and time being Friday at 4:00 p.m. Alternating weeks shall begin on August 28, 2009 with Father having the first week. Father shall also have physical custody of the child from Friday, August 21, 2009 at 4:00 p.m. to Friday, August 28, 2009 at 4:00 p.m. as makeup time for not having physical custody of child since May 24, 2009. 4. Transportation shall be shared such that the parties shall exchange custody at the Carlisle Police Station on Lincoln Street. 5. Jurisdiction shall remain in Cumberland County, although Father is permitted to exercise his custody in his Perry County home. 6. In the event that either party is in need of a babysitter for more than 2 hours, they shall contact the non-custodial parent and offer said time to the non-custodial parent. 7. Physical custody on holidays, which shall take precedence over the regular schedule, shall be as designated below: HOLIDAYS AND TIMES ODD EVEN SPECIAL DAYS YEARS YEARS Easter Day 1st half From 9:00 a.m.to 3:00 p.m. Father Father Easter Day 2"d half From 3:00 p.m. to 9:00 p.m. Mother Mother Memorial Day From 9:00 a.m. to 9:00 p.m. Mother Father Independence Day From 9:00 a.m. to 9:00 p.m. Father Mother Labor Day From 9:00 a.m. to 9:00 p.m. Mother Father Thanksgiving I" half From 9:00 a.m. to 3:00 p.m. Father Father Thanksgiving 2"d half From 3:00 p.m. to 9:00 p.m. Mother Mother Christmas I" half From 12:00 noon on 12/24 to 12:00 noon on 12/25 Father Mother Christmas 2"d half From 12:00 noon on 12/25 to 12:00 noon on 12/26 Mother Father Mother's Day From 9:00 a.m. to 9:00 p.m. Mother Mother Father's Day From 9:00 a.m. to 9:00 p.m. Father Father Good Friday From 9:00 a.m. to 9:00 p.m. Father Father New Year's Day I" half From 9:00 a.m. to 3:00 p.m. Father Mother New Year's Day 2nd half From 3:00 p.m. to 9:00 p.m. Mother Father Mother's Birthday From 9:00 a.m. to 9:00 p.m. Mother Mother Father's Birthday From 9:00 a.m. to 9:00 p.m. Father Father First Day of Fishing Season From Friday before at 4:00 p.m. to Saturday at 4:00 p.m. Father Father Whoever has Trick or Treat night From 5:00 p.m. to 9:00 p.m., if on the same physical Alternate from night in both parent's municipality; if on custody on the prior year different night, then each parent will have week on/week physical custody on their respective nights. off schedule 8. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE J. cc: Suzanne Spencer Abel, Esquire, Counsel for Father Thomas Williams, Esquire, Counsel for Mother Ca tes eytz.tL" KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-571 CIVIL ACTION - LAW HEIDI SHENCK, Defendant : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME Bradley Shenck DATE OF BIRTH CURRENTLY IN CUSTODY OF March 14, 2006 Mother 2. A Conciliation Conference was held in this matter on August 20, 2009, with the following in attendance: The Father, Keith Greenwald, with his counsel, Suzanne Spencer Abel, Esquire and Mother, Heidi Shenck, with her counsel, Thomas Williams, Esquire. 3. The Honorable Edward E. Guido previously entered an Order of Court dated June 11, 2008 providing for shared legal custody, Mother having primary physical custody and Father having periods of partial physical custody on alternating weekends from Friday at 4:00 p.m. to Sunday at 4:00 p.m. 4. The parties agreed to the entry of an Order in the form as attached. J"')-0'&2 1/? , - - ? '? Date acq ine M. Verney, Esquire Custody Conciliator OF THr. 2009 AUG 24 PH 1: 58 KEITH GREENWALD IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVAN t? V . 2007-571 CIVIL ACTION LAW CD T, HEIDI SHENCK IN CUSTODY" DEFENDANT _ ORDER OF COURT AND NOW, _ Monday, June 11, 2012 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, June 29, 2012 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: __/s/ ac ueline M. Verne Es T. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street ? e d . cofy 07a,400( k ? A/s? ? (o ey Ord ?Y?rl oIW-r Plh rr v evpy P>aceol , Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 AE KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-571 CIVIL ACTION - LAW HEIDI SHENCK, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 9 Aday of Z- tmA? , 2012, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A Hearing is scheduled in Court Room No. ." , of the Cumberland County C urt House, on the _Vjj? day of , 2012, at /y : o'clock. M., at which time testimony will be to en. For purposes of this Hearing, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least five days prior to the Hearing date. 2. Pending the hearing, the prior Orders of Court of the Honorable Edward E. Guido dated June 11, 2008 and August 24, 2009 shall remain in full force and effect with the following modification. Mother shall have primary physical custody of the child. 4. Father shall have periods of partial physical custody of the child on every weekend from Friday at 4:00 p.m. to Monday at 4:00 p.m. If the child starts school, Father shall be responsible for transporting the child to school on Monday mornings. 5. Transportation shall be shared such that the parties shall exchange custody at the Carlisle Police Station. 6. Father shall assure that Christine Swartz shall absolutely not have any unsupervised contact with the child. Father shall be the supervisor. 7. The parties shall have reasonable telephone contact with the child. 8. 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 C Edward E. Guido, 6-11 cc: Jessica Holst, Esquire, MidPenn Legal Services, Counsel for Father Heidi Shenck, pro se Lot 2 Tip Top Circle Carlisle, PA 17015 J. r? 3 ? mW c_ CA r- c-, 3 c. KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-571 CIVIL ACTION - LAW HEIDI SHENCK, Defendant : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Bradley Shenck March 14, 2006 Mother 2. A Conciliation Conference was held July 2, 2012 with the following individuals in attendance: The Father, Keith Greenwald, with his counsel, Jessica Holst, Esquire, MidPenn Legal Services, and the Mother, Heidi Shenck, pro se. 3. Father filed for Modification and Contempt alleging that Mother has failed to allow any contact with Father since October of 2009. A prior Order of Court dated August 24, 2009, provided for shared physical custody on a week on/week off schedule. Father's position on custody is as follows: Father seeks a finding of contempt and shared legal and primary physical custody of the child. Father believes that Mother attempted suicide in May of 2012. Father admits that the child was dependent through Cumberland County, but the dependency was terminated prior to the Court's Order of August 24, 2009. Father denies Mother's allegations that the child was abused in October of 2009. 4. Mother's position on custody is as follows: Mother seeks shared legal and primary physical custody. She believes that Father's paramour, Christine Swartz physically abused the child in October 2009. Mother reported it to Perry County C&Y, which unfounded the report. Mother requests the child have no contact with Christine Swartz and does not trust Father to protect the child from abuse. The pertinent information concerning the Child who is the subject of this 5. The Conciliator recommends an Order in the form as attached scheduling a Hearing and granting Father every weekend from Friday to Monday, pending a hearing. It is expected that the Hearing will require one-half day. 1 a - j,-z- _ fit., ?- Date ac line A Verney, Esquire Custody Conciliator KEITH GREENWALD, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2007-571 CIVIL TERM HEIDI SHENCK, CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this 8th day of August, 2012, after hearing, we find beyond a reasonable doubt that Mother has willfully violated our prior custody orders, and she is adjudicated to be in contempt thereof. The sentence of the Court is that she undergo imprisonment in the Cumberland County Prison for 6 months. TI condition of purge is that she faithfully comply with all terl of the custody Order entered today's date. She is paroled immediately on the condition that she abide with the conditiol of purge. Failure to comply with any provision of our custod1 Order shall result in the issuance of a bench warrant for her arrest and her being brought immediately before this Court. //'/'Jessica Holst, Esquire MidPenn Legal Services For the Plaintiff V"Jane Adams, Esquire For the Defendant CCP srs COP; ?s zx ;:z a7 -<.> w t=: co =r co By the Court, KEITH GREENWALD, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2007-571 CIVIL TERM HEIDI SHENCK, CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this 8th day of August, 2012, after hearing, it is ordered and directed as follows: 1. The Father, Keith Greenwald, and the Mother, Heidi Shenck, shall have shared legal custody of Bradley ShenIck, born March 14, 2006. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding his health, education, and religion. Pursuant to the terms of 23 Pa. C.S. Section 5309, each parent shall be entitled to al records and information pertaining to the child including, not limited to, medical, dental, religious, or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, copes thereof, with the other parent within such reasonable time as to make the records and information of reasonable use or to the other parent. Both. parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher, or authority and copies of any reports given to them as parents including, but not limited o: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-t - school nights, and the like. 2. Mother shall have primary physical custody of child. 3. Father shall have partial physical custody as follows: A. When school is not in session, every weekend from Friday at 4:00 p.m. until Monday at 4:00 p.m. B. When school is in session, every other weekend from Friday at 4:00 p.m. until Monday at the beginning of school. If the child has off school school on Monday, then the visitation shall extend until Tuesday at the beginning of school. It shall be Father's responsibility to see that the child gets to school or to return the child the evening before so that Mother can get him to school. C. Such other times as the parties agree. 4. Physical custody on holidays, which shall take precedence over the regular schedule, shall be as designated Dn the schedule attached as Exhibit A. 5. Transportation shall be shared, with all Gusto y exchanges to be at the Pennsylvania State Police Barracks in Carlisle. 6. No party shall be permitted to relocate the residence of the child which significantly impairs the ability to exercise custody unless every individual who has custodial rights to the child consents to the proposed relocation. A person proposing to relocate must comply with 23 Pa. C.S. Section 5337. 7. Neither party shall do or say anything nor permit a third party to do or say anything that may estrange he child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. 8. The custodial parent shall ensure that the chi d talks with the non-custodial parent by telephone on a daily basis. 9. Each party shall keep the other informed of hi or her address at all times. 10. The child is to be re-enrolled in counseling forthwith. Mother shall notify Father as to the name and address of the counselor. Father may participate in the counseling to the extent requested by the counsel or. Father ay also provide the counselor with input regarding F ather's concerns and issues to be addressed. By the Court, c= ' n. d'"sue r- C= c'-- C. ` (P y CD I t LZ -? Edward E. Guido, J. CO _ ?a 1" Jessica Holst, Esquire MidPenn Legal Services For the Plaintiff ? Jane Adams, Esquire For the Defendant ?? PS l C• l ev s r s EM Mffld HOLIDAYS AND SPECIAL DAYS TIMES ODD YEARS EVEN YEARS i Easter Day I" half From 9:00 a.m.to 3:00 p.m. Father Fathe r Easter Day 2"d half From 3:00 p.m. to 9:00 p.m. Mother Mo t` t r Memorial Day From 9:00 a.m. to 9:00 p.m. Mother Fathe r Independence Day From 9:00 a.m. to 9:00 p.m. Father Moth ,-r Labor Day From 9:00 a.m. to 9:00 p.m. Mother Fathe r Thanksgiving I" half From 9:00 a.m. to 3:00 p.m. Father Fath r Thanksgiving 2nd half From 3:00 p.m. to 9:00 p.m. Mother Moth r Christmas I" half From 12:00 noon on 12/24 to 12:00 noon on 12/25 Father Moth er Christmas 2"d half From 12:00 noon on 12/25 to 12:00 noon on 12/26 Mother Fathe r Mother's Day From 9:00 a.m. to 9:00 p.m. Mother Mothe r Father's Day From 9:00 a.m. to 9:00 p.m. Father Fathe r Good Friday From 9:00 a.m. to 9:00 p.m. Father Fathe r New Year's Day 15t half From 9:00 a.m. to 3:00 p.m. Father Mothe r New Year's Day 2nd half From 3:00 p.m. to 9:00 p.m. Mother Fathe Mother's Birthday From 9:00 a.m. to 9:00 p.m. Mother Mothe r Father's Birthday From 9:00 a.m. to 9:00 p.m. Father Fathe r First Day of Fishing Season From Friday before at 4:00 p.m. to Saturday at 4:00 p.m. Father Fathe Trick or Treat night From 5:00 p.m. to 9:00 p.m., if on the same night in both parent's municipality; if on different night, then each parent will have physical custody on their respective nights. Whoever has physical custody on the week on/week off schedule Alternate priory from ar KEITH GREENWALD, IN THE COURT OF COMMON PLE~ O~ Plaintiff/Petitioner :CUMBERLAND COUNTY, PENNSI'~V ~IA~ zrn ~ r~r v. ~ ~ :CIVIL ACTION -LAW cnr- "~ .~' ~° -t~'' • C' T ~ -'i CJ HEIDI SHENCK, N0.2007-571 CIVIL yam. © -v ~ ~ Defendant/Respondent IN CUSTODY ~ ~ ~ ~ ~ f PETITION FOR EMERGENCY RELIEF Petitioner, Keith Greenwald, by and through his counsel, MidPenn Legal Services, states the following: 1. Petitioner, hereinafter referred to as Father, resides at 110 Huckleberry Road, New Bloomfield, Perry County, Pennsylvania~17068. 2. Respondent, hereinafter referred to as Mother, is believed to reside at present at 39 Cold Spring Road, Carlisle, Cumberland County, Pennsylvania 17015. On November 8, 2012, Mother provided Father with a new address of 1521 Thompson Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. 'It is unknown as to when Mother actually plans to move to that address. 3. The parties are the parents of the minor child, Bradley Shenck, born March 14, 2006. Bradley is 6 %s years old. 4. The most~recent custody Orders were entered on August 8, 2012 by the Honorable Edward )/'. Guido. The first Order found Mother in contempt of the prior custody Order and set forth a sentence of six months imprisonment with immediate parole so long as she complied'with the conditions of the new custody Order. The second Order granted the parties shared legal custody, gave Mother primary physical custody and gave Father periods of partial physical custody. The Order also prohibited relocation as defined by the custody statute. 5. Since the entry of the August 8, 2012 Orders, Father has had difficulties as a result of Mother's non-compliance with the custody Order and with constant interference from Mother's significant other. a. Mother did not register Bradley in the school that she testified to at the custody hearing, Mount Rock Elementary School in Big Spring School District and instead enrolled him in North Dickinson Elementary School because she moved to a new address the day after the custody hearing on August 8, 2012. b. Mother changed her telephone nufnber which caused difficulty getting Bradley enrrolled in counseling and when Father took steps to move the process forward, Mother could not be reached at the number she provided to the counseling center and Bradley's intake process was unnecessarily delayed. c. Despite repeated reminders that Father does not have Internet access at home and cannot read attachments sent to his cellular phone, Mother sends information via email attachments and then after the fact provides the hazd copies to Father at exchanges so Father frequently misses information or gets information after the fait. d. VV~en Mother missed a call from Bradley while Bradley was in Father's custody she reported to the State Police that she had not heazd from the child and the State Police went to Father's house at 12:45am to do a safety check on the child. e. On November 8, 2012 Father attended a pazent/teacher conference and at that time learned that Bradley was being withdrawn from the school but was not enrolled in a new school yet. Mother advised that Bradley would likely be enrrolled at Lower Allen, Rossmoyne or Bible Baptist. At that same time, Mother c gave Father her new address in Mechanicsburg and noted that it was temporary until the new baby was born and that after that, they would be moving again. f. At no time has Father consented to Bradley's relocation and Mother has not followed the relocation process as outlined at 23 Pa.C.S. §5337. This move should be deemed a relocation as it substantially interferes with Father's custodial time by adding another 15-20 minutes in travel time and requires Bradley to wake up about half an hour earlier, closer to 4:30a.m., in order to get to school on time on Monday morning. g. Mother's actions are not in Bradley's best interests as she continues to create an environment of instability and constant change. This is Bradley's third address since the August 8~' hearing and b3~ Mother's own admission, there is likely to be a fourth once the new baby is born later this year. h. Mother has refused to work cooperatively with Father to ensure an ongoing father/son relationship. i. 1Vrother's behavior suggests an on-going desire to estrange Bradley from Father and to interfere with the father/son relationship. j. Father is best able to provide for Bradley as his primary caregiver and can provide Bradley with consistency and stability as far as both a residence and an education. k. Father is more apt to work cooperatively with Mother to nurture an ongoing, healthy mother/son relationship and he will ensure Mother's advance notice of all appointments, conferences, activities, presentations, counseling sessions or other mutters pertaining to Bradley so that she can actively participate in all aspects of Bradley's life. 6. Without this Court's intervention, Father has a concern that Bradley is at risk by Mother's ongoing failure to work cooperatively with Father as well has her continued instability and inconsistency. 7. Counsel for Father has confirmed that Attorney Jane Adams represents Mother and that she does not concur with the relief requested in this Petition. WHEREFORE, Father respectfully requests that the Court order the following: a. Mother shall transfer custody of the minor child, Bradley Shenck, born Mazch 14, 2006, to Father. b. Until further order of court, the parties shall share legal custody of Bradley. c. This matter shall be scheduled for an emergency hearing. d. Until further order of court, Father shall have primary physical custody of Bradley an~ Mother shall have periods of partial physical custody on alternating weekends from Friday at 4:OOp.m. until Sunday at 7:OOp.m. e. Father is ordered to ensure that Bradley is enrolled in school forthwith and that Bradley continues with any counseling services already in place. f. The local police or other appropriate law enforcement agency shall assist Father in obtaining custody of Bradley from Respondent or other adult who may have custody of Bradley. g. Any other relief this Court finds just and equitable. Cazlisle, PA 17013 VERIFICATION The above-named PETITIONER, Keith Greenwald, verifies that the statements made in the above PETITION FOR EMERGENCY RELIEF are true and correct. Petitioner understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date . ~~- ~ - ~~~ ~..~~ Keith Greenwald EXHIBIT A KEITH GREENWALD, IN THE .COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2007-571 CIVIL TERM HEIDI SHENCK, CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this 8th day of August, 2012, after hearing, we find beyond a reasonable doubt that Mother has willfully violated our prior custody Orders, and she is adjudicated to be in contempt thereof. The sentence of the Court is that she undergo imprisonment in the Cumberland County Prison for 6 months. The condition of purge is that she faithfully comply with all terms of the custody Order entered today's date. She is paroled immediately on the condition that she abide with the condition of purge. Failure to comply with any provision of our custody Order shall result in the issuance of a bench warrant for her arrest and her being brought immediately before this Court. By the Court, essica Holst, Esquire fMidPenn Legal Services For the Plaintiff c~ f..~ N ~~ ~ r .~,~ ~ o r~ ~ ~Q ~,,~° CxJ .~: ~ rv Jane Adams, Esquire For the Defendant CCP srs :;, --i "~ t^: 1 ~~ z'=n ~'#"f ~. TRUE COPY FROM RECORD and In Testimony whereof, i here unto set my and the t of said Court at Carlisle, Pa. Tltlt ~y ~ 20 ~- "~1~~r/ Prothonotary EXHIBIT I KEITH GREENWALD, Plaintiff v. HEIDI SHENCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-571 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this 8th day of August, 2012, after hearing, it is ordered and directed as follows: 1. The Father, Keith Greenwald, and the Mother, Heidi Shenck, shall have shared legal custody of Bradley Shenck, born March 14, 2006. Each parent shall have an equal right, to be exercised jointly with the other parent,. to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding his health, education, and religion. Pursuant to the terms of 23 Pa. C.S. Section 5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious, or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher, or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to- school nights, and the like. 2. Mother shall have primary physical custody of the child. 3. Father shall have partial physical custody as follows: A. When school is not in session, every weekend from Friday at 4:00 p.m. until Monday at 4:00 p.m. B. When school is in session, every other weekend from Friday at 4:00 p.m. until Monday at the beginning of school. If the child has off school school on Monday, then the visitation shall extend until Tuesday at the beginning of school. It shall be Father's responsibility to see that the child gets to school or to return the child the evening before so that Mother can get him to school. C. Such other times as the parties agree. 4. Physical custody on holidays, which shall take precedence over the regular schedule, shall be as designated on the schedule attached as Exhibit A. 5. Transportation shall be shared, with all custody exchanges to be at the Pennsylvania State Police Barracks in Carlisle. 6. No party shall be permitted to relocate the residence of the child which significantly impairs the ability to exercise custody unless every individual who has custodial rights to the child consents to the proposed relocation. A person proposing to relocate must comply with 23 Pa. C.S. Section 5337. 7. Neither party shall do or say anything nor. permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. 8. The custodial parent shall ensure that the child talks with the non-custodial parent by telephone on a daily basis. 9. Each party shall keep the other informed of his or her address at all times. 10. The child is to be re-enrolled in counseling forthwith. Mother shall notify Father as to the name and address of the counselor. Father may participate in the counseling to the extent requested by the counselor. Father may also provide the counselor with input regarding Father's concerns and issues to be addressed. By the Court , C :~,: `:' _; pis ?s M --- ~,F- "" ~'~,' Edward E. Guido, J. ~~ -r,,,~- • ca , '`'' _ ~ N ~ yJT~essica Holst, Esquire 1/"MidPenn Legal Services For the Plaintiff Jane Adams, Esquire For the Defendant srs TRUE COPY FROM RECORD in Testimony whereof, I here unto set my hand and the /seal of said Co at Cariisl 20 f.2 This _1iL day of _S~ (/ , Prothonotary ~~ HOLIDAYS AND SPECIAL DAYS TIMES ODD yE~ EVEN ~~ Easter Day 1~ half From 9:00 a.m.to 3:00 p.m. Father Father Easter Day 2nd half From 3:00 p.m. to 9:00 p.m. Mother Mother Memorial Day From 9:00 a.m. to 9:00 p.m. Mother Father Independence Day From 9:00 a.m. to 9:00 p.m. Father Mother Labor Day From 9:00 a.m. to 9:00 p.m. Mother Father Thanksgiving 1 ~` half From 9:00 a.m. to 3:00 p.m. Father Father Thanksgiving 2"d half From 3:00 p.m. to 9:00 p.m. Mother Mother Christmas 1 ~` half From 12:00 noon on 12/24 to 12:00 noon on 12/25 Father Mother Christmas 2"d half From 12:00 noon on 12/25 to 12:00 noon on 12/26 Mother Father Mother's Day From 9:00 a.m. to 9:00 p.m. Mother Mother Father's Day From 9:00 a.m. to 9:00 p.m. Father Father Good Friday From 9:00 a.m. to 9:00 p.m. Father Father New Year's Day 1 S` half From 9:00 a.m. to 3:00 p.m. Father Mother New Year's Day 2"d half From 3:00 p.m. to 9:00 p.m. Mother Father Mother's Birthday From 9:00 a.m. to 9:00 p.m. Mother Mother Father's Birthday From 9:00 a.m. to 9:00 p.m. Father Father First Day of Fishing Season From Friday before at 4:00 p.m. to Saturday at 4:00 p.m. Father Father Trick or Treat night From 5:00 p.m. to 9:00 p.m., if on the same night in both parent's municipality; if on different night, then each parent will have h sicat Gusto on their res dive ni hts. Whoever has physical custody on the week on/week off schedule Alternate from prior year `~ \ ~~~ ~.. / KEITH GREENWALD, Plaintiff/Petitioner v. HEIDI SHENCK, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.2007-571 CIVIL 1N CUSTODY ORDER OF COURT ~ ~ a~~ AND NOW, this /~ day of ~ ,upon consi eration of the Petition for Emergency Relief, the following order is entered: mor c i orn ey. •~ This matter shall be scheduled for an emergency hearing on ~~,~ at ~:~ ~.m. in Courtroom Number 3. on ` tn. unlit S^un evemn at Y g ad ~rvices a rea y it"p .. - I~espnrFCl~rrf--sr-~ult . By th Burr, Edward E. Guido, Judge Distribution: / Jessica Holst, Esquire MidPenn Legal Services 401 E. Louther Street Carlisle, PA 17013 ~ ~ '- _., .b~ ^~ -- ~/ Jane Adams, Esquire ~~ ~ `~; -?-` z r`; ~? ~ F-... 17 West South Street ~~- ~ ;,~~`, Carlisle, PA 17013 ~~" ~' ~;~` -C~ -s~ ~~,._ -~ ~L fj KEITH GREENWALD, Plaintiff v. HEIDI SHENCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-571 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this 19th day of November, 2012, after hearing on Father's emergency petition, it is hereby ordered and directed that the custody Order of August 8, 2012, is amended as follows: 1. The pick-up time in Paragraph 3-B shall be 6:00 p.m. 2. "The Pennsylvania State Police Barracks in Carlisle" is deleted from Paragraph 5 and replaced with "The Silver Spring Township Police Station." 3. Paragraph 11 shall be added: 11. Mother shall not change the child's school without the written agreement of Father or prior Order of this Court. 4. In all other respects, the custody Order of August 8, 2012, shall remain in full force and effect. By the Court, F ,, g. ~, c~ ~ y P'- C:? ~ 1'_~ ~r iJ .~ "art! ~~" ~ 7~-; Edward E. Guido, J. -<~ ~ mac-:. T.' n ~ .p,, __. ZG ~~~4'; (Jessica Holst, Esquire ~c:~ ::' Attorney for Plaintiff ~ cn -_.t /Jane Adams, Esquire Attorney for Defendant srs ~p~25 N~cx~~~CG` ~-~aD~ja ,~°-/GL pi C0 "moo Allison C. Gossett, PA ID No. 314900 r.:ter__,. Pamela L. Purdy, PA ID No. 85783 t w Law Office of Pamela L. Purdy, LLC < -r, 1820 Linglestown Road Harrisburg, PA 17110 (717) 221-8303 tel (717) 221-8403 fax Allison @purdylawoffice.corn Attorney for Plaintiff KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2007-571 HEIDI SHENCK, n/k/a, • HEIDI SHOEMAKER, : CIVIL ACTION — LAW Defendant : IN CUSTODY PETITION FOR EMERGENCY RELIEF IN CUSTODY AND NOW, Plaintiff, by and through his counsel, the Law Office of Pamela L. Purdy, LLC, files this Petition for Emergency Relief in Custody, and in support thereof, avers the following: 1. Petitioner/Plaintiff is Keith Greenwald (hereinafter"Father"), who currently resides at 110 Huckleberry Road, New Bloomfield, Perry County, Pennsylvania. 2. Respondent/Defendant is Heidi Shoemaker (hereinafter "Mother"), who is believed to reside in York County, Pennsylvania. 3. Mother and Father are the parents of Bradley Shenck, age seven (DOB 03/14/06) (hereinafter," radley"). 83.00 P11 4. The parties are operating under the following Orders of Court: C NOS aa.�s3 a. An August 8, 2012 Custody Order; b. An August 8, 2012 Order of Court which finds Mother to be in contempt of the parties' prior custody Order, places Mother on parole, and conditions her parole upon her future compliance with the August 8, 2012 Custody Order; and c. A November 19, 2012 Order of Court requiring Mother to obtain Father's written consent or the Court's approval prior to changing Bradley's school. 5. Since the entry of these orders, in August 2013, Bradley disclosed to Father that Bradley's cousin Candace has been sexually abusing him. 6. Candace, who is currently fourteen (14) years old, resided with Bradley and Mother from August 2012 to October 2012. 7. Bradley further disclosed to Father that he told Mother about the abuse when it first happened and that Mother yelled at Candace to never do it again. S. Mother never shared this information with Father. 9. After Bradley disclosed the abuse to Father, Father immediately reported it to Cumberland County Children and Youth Services (hereinafter"Children and Youth"), and Bradley was subsequently interviewed by Shiloh Hagerty of their office. 10. After interviewing Bradley, Children and Youth referred Bradley's case to the Pennsylvania State Police, where the investigation into this matter is ongoing and is being led by Trooper Krista M. Miller. 11. Children and Youth also issued a Safety Plan, which states that Bradley is to have no contact with Candace until further directed by their agency. A true and correct copy of the August 12, 2013 Safety Plan issued by the Cumberland County Children and Youth Services office is attached hereto, made a part hereof and marked as Exhibit "A". 12. Since the initiation of Children and Youth's investigation, Bradley has told Father that Mother has directed him to say that Candace was only 8 or 9 years old when the abuse happened, and that if he did not say that, they would hit him with "the book". 13. "The book" is a large, thick, hard book that Bradley says Mother and Mother's husband use to discipline him. 14. Bradley further stated that when he told Mother that he would not lie to Children and Youth, she called him a "little bastard" and a "son of a bitch". 15. Recently, Children and Youth has indicated that the existing Safety Plan will no longer be in effect. 16. Mother has also begun withholding Bradley from Father during his weekend periods of custody. 17. Father believes and therefore avers that Mother is keeping Bradley from Father so that she may coach and threaten him into lying about the abuse he disclosed. 18. Father further believes and therefore avers that as long as Bradley is in Mother's care, and the current Safety Plan is not continued by Children and Youth, Bradley will be at risk for suffering further abuse at the hands of Candace. 19. This fear is compounded by Father's belief that Candace continued to reside with Bradley and Mother after Bradley disclosed the abuse to Mother. 20. Furthermore, during Father's last visit with Bradley, Bradley stated that Mother and Mother's husband have been looking at a trailer in the woods, and have stated to Bradley, "Your Dad will never find us here." 21. Despite repeated requests, Mother will not tell Father where Bradley is living. 22. Father believes and therefore avers that Mother intends to abscond with Bradley to a remote location and prevent Father from finding or seeing him. 23. Mother has previously kept the child out of school for several months to prevent Father from seeing him, and Father believes, and therefore avers, that she is likely to do this again. 24. In addition to the pending sexual abuse allegations, within the last two months, on multiple occasions, Bradley has disclosed to Father that Mother and Mother's husband use a "cool pipe" that is green and brown to smoke. 25. Bradley states that they smoke this pipe when they are in the car with him, and that they sometimes drive to the top of a mountain to smoke the pipe. 26. He further indicated that their eyes look funny when they are using the pipe. 27. As Mother has previously struggled with drug addiction, Father believes that Mother and Mother's Husband are smoking illegal drugs in Bradley's presence, on a regular basis. 28. Defendant was previously represented by Jane Adams, Esquire in this matter, but as of the date of this Petition, it is unknown whether she still represents Defendant. 29. Thus, it is believed, and therefore averred, that Defendant Mother does not concur in this Petition. 30. This matter has previously been assigned to the Honorable Edward E. Guido, Jr. WHEREFORE, Petitioner respectfully requests that this Court enter a temporary order granting Father primary physical custody of the parties' son, and suspending Mother's custodial time pending a hearing on Father's Petition and completion of the investigation being conducted by the Pennsylvania State Police. Respectfully submitted, t nn ` q Allison C. Gossett Date: 6 gyp/ 13 Attorney for Plaintiff VERIFICATION I, Keith Greenwald, verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Keith Greenwald • Ittft AtS O o O . *1 I Ilitil 1 °) A A a, O p R i • cn PoAto 4.1 s....\...... ii*Itin; 0, Pa W il PA 0 4-'' _ Vt, Vc) 1'0. PA Is y _ 1 V.76‘ r,J �oA tilan„,.. F'boU 44 Z. Yr ) `14 `4-16'° ,--- , S' '' .‘ \ ?-, --- 4 3 .i., , , Ak1/4 _t, .s d p p ' W _ t Z era o .a cd t!A ,>`+� w H i ' . 14)"06 D.A,,,,. A , Vo , .\' 3 t(---. -• o. it lit,k- 3 u is U) 'Nl 'n N ` N ° C y °? A a 3' ni 4: • td v Nw `tea rail cd U CERTIFICATE OF SERVICE The undersigned certifies that on thejD day of September, 2013, a true and correct copy of the foregoing Petition for Emergency Relief and for Contempt and Modification and Contempt of Custody Order was served via facsimile, email and first class, U.S. mail upon the following: Jane Adams, Esquire 17 W South Street Carlisle, PA 17013 Allison C. Gossett Counsel for Plaintiff Off' THE�P OTHO�OTAR`r 2013 SEP 24 AM 1.1'. 34 CUMBERLAND COUNTY PENNSYLVANIA Allison C. Gossett Supreme Court I.D. #314900 Law Office of Pamela L. Purdy, LLC 1820 Linglestown Road Harrisburg, PA 17110 PH: (717) 221-8303 FX: (717) 221-8403 allison @purdylawoffice.com Attomey for Plaintiff KEITH GREENWALD, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2007-571 HEIDI SHENCK, n/k/a, HEIDI SHOEMAKER, CIVIL ACTION — LAW Defendant IN CUSTODY PRAECIPE TO THE PROTHONOTARY: Kindly withdraw the appearance of Jessica Hoist as counsel for Plaintiff, Keith Greenwald, in the above-captioned matter, and enter the appearance of Allison C. Gossett. Q J�3 4 es , H squire Allison C. Gossett, Esquire PA o. PA ID No. 314900 401 East Louther Street 1820 Linglestown Road Carlisle; PA 17013 Harrisburg, PA 17110 (717) 243-9400 (717) 221-8303 Dated: q 1a 3 f 1,3 i CERTIFICATE OF SERVICE The undersigned certifies that on this 23rd day of September, 2013, a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, upon the following: Jessica Hoist, Esquire 401 East Louther Street Carlisle, PA 17013 Jane Adams, Esquire 17 West South Street Carlisle, PA 17013 Gk Heather J. Aut ralegal Law Office of Pamela L. Purdy, LLC yakw `lOT . li IUi'{t' irP ,"s 2;313;j!�1 t SEF 25 P11 3: 12 CUMSERLAl ij COUNT PENNSYLVANIA KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2007-571 HEIDI SHENCK, n/k/a, HEIDI SHOEMAKER, : CIVIL ACTION — LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, this c( day of September, 2013, upon consideration of Plaintiffs Petition for Emergency Relief in Custody, it is hereby ORDERED: S 1. A hearing in this matter is scheduled for the "day of , 2013 in Courtroom # 3 at the Cumberland County Courthouse,/,30P.111• . - - •• . • of ;, .• . - - err :, is • • . -• . • • „ ..etT—RelherSITAThave primary p ystc- •• • • - ., - a BY THE C• :T: , J. Distribution List: ✓J e Adams, Esquire, 17 W South Street, Carlisle, PA 17013 Allison C. Gossett,,Esquire, 1820 Linglestown Road, Harrisburg, PA 17110 1 $' nzzttit, 9 -s-A2 _IM EI;L! N i:l CC•� '� s f'PLrN'3YL'r'M Ir- Allison C. Gossett, PA ID No. 314900 Pamela L. Purdy, PA ID No. 85783 Law Office of Pamela L. Purdy, LLC 1820 Linglestown Road Harrisburg, PA 17110 (717) 221-8303 tel (717) 221-8403 fax Allison @purdylawoffice.com Attorney for Plaintiff KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2007-571 • HEIDI SHENCK, n/k/a, HEIDI SHOEMAKER, : CIVIL ACTION — LAW Defendant : IN CUSTODY PETITION FOR CONTEMPT AND COUNSEL FEES AND FOR MODIFICATION OF CUSTODY ORDER AND NOW, Plaintiff, by and through his counsel, the Law Office of Pamela L. Purdy, LLC, files this Petition for Contempt and Counsel Fees and for Modification of Custody Order, and in support thereof, avers the following: 1. Petitioner/Plaintiff is Keith Greenwald (hereinafter"Father"), who currently resides at 110 Huckleberry Road, New Bloomfield, Perry County, Pennsylvania. 2. Respondent/Defendant is Heidi Shoemaker (hereinafter "Mother"), who currently resides at an unknown address in York, York County, Pennsylvania. 3. Mother and Father are the parents of Bradley Shenck, age seven (DOB 03/14/06) (hereinafter "Bradley"). $ 13.00 C/c4,5 e.tk (p«) po atb rte./1.2.44A25 4. The parties are operating under the following Orders of Court: a. An August 8, 2012 Custody Order; b. An August 8, 2012 Order of Court which finds Mother to be in contempt of the parties' prior custody Order, places Mother on parole, and conditions her parole upon her future compliance with the August 8, 2012 Custody Order; and c. A November 19, 2012 Order of Court requiring Mother to obtain Father's written consent or the Court's approval prior to changing Bradley's school. CONTEMPT AND COUNSEL FEES 5. Since August 2012, Mother has consistently violated numerous provisions of the parties' Orders. 6. With regard to Bradley's schooling, the November 19, 2012 Order directs Mother to obtain Father's written permission before switching Bradley's school, and Paragraph 1 of the parties' August 8, 2012 Custody Order states that each parent has an equal right to make decisions with regard to Bradley's education. 7. Despite the aforementioned provisions, Bradley has attended two different schools since November 2012—Lower Allen Township Elementary School in Camp Hill and Bible Baptist Elementary School in York. 8. Mother did not seek Father's permission before making this school change. 9. Additionally, as Mother has been unresponsive to any inquiry Father has made about Bradley's school, Father's knowledge of each school district change has been obtained by calling elementary schools and inquiring as to Bradley's registration there. 10. On numerous occasions, Mother has told Bradley, while he is on the phone with Father, to tell Father that he would be attending a certain school soon. 11. The most recent of these telephone conversations was at the end of August, 2013, when Mother told Bradley to tell Father that he would begin attending Newberry Elementary School in the West Shore School District rather than the Lower Allen Township Elementary School. 12. Following this conversation, when Father discovered that Bradley was not enrolled at Newberry Elementary School, Bradley shared with Father that he would be going to Bible Baptist Elementary School in York. 13. Father has since confirmed that Bradley is enrolled at Bible Baptist Elementary School in York County. 14. Paragraph 9 of the August 8, 2012 Custody Order requires both parties to keep the other informed of their address at all times. 15. Since August 2012, Mother has moved Bradley to at least three different residences, and has failed to notify Father of any of them. 16. The first of these moves took place almost immediately after the August 8, 2012 hearing, when Mother moved from Mount Holly to Camp Hill. 17. Thereafter, in June 2013, Bradley began crying and informed Father that they were being evicted from their residence in Camp Hill and would be moving again. 18. Bradley further stated that Mother told him it was his fault that they always have to move and that he has to make new friends. 19. Since being evicted from their Camp Hill residence in June 2013, Mother has refused to tell Father where Bradley is living. 20. Bradley, however, has shared with Father that they lived in a cabin in Perry County for a brief time and that, at his current residence, he sleeps on the floor because there are cockroaches and trash on his bed. 21. Bradley also told Father that Stepfather was fighting with their new landlord about money, and that they would probably have to move again. 22. As of the date of this Petition, the only information that Father has regarding Mother's current address has come from the Cumberland County Children and Youth Services Office, who has indicated that Mother resides somewhere in York. 23. Paragraph 3 of the parties' August 8, 2012 Custody Order states that Father shall have custody every weekend from Friday at 4:00 p.m. until Monday at 4:00 p.m. during the summer, and every other weekend from Friday at 4:00 p.m. until Monday at the beginning of school during the school year. 24. Since August 2012, Mother has unilaterally decided whether Father will be allowed to exercise his weekend periods of custody, and since Sunday, September 8, 2013, Mother has not allowed Father to see Bradley at all. 25. When Father attempts to call Mother about his custody periods, she does not answer the phone, and her voicemail box is full. 26. Additionally, during a phone call several weeks ago, Bradley stated that Mother and Stepfather are looking at a trailer in the woods and have told him that Father will never be able to find them there. 27. Father believes and therefore avers that Mother intends to move Bradley to a remote location in an effort to prevent him from exercising any custody period. 28. Paragraph 8 of the parties' Custody Order, states that the then custodial parent shall ensure that Bradley speaks with the non-custodial parent by telephone on a daily basis. 29. Since August 2012, the majority of the phone calls that Father has received from Bradley have taken place after 8:00 p.m., with many of them taking place between 11:00 p.m. and 12:00 a.m. midnight. 30. Furthermore, Mother has not allowed Father to communicate with Bradley via telephone since Thursday, September 19, 2013. 31. Finally, Paragraph 7 of the parties' Custody Order states that neither party shall do or say anything which may estrange the child from the other parent, or hamper the free and natural development of the child's love and respect for the other parent. 32. Since August 2012, Bradley has told Father on many occasions that he cannot hug Father or tell him he loves him in front of Mother because she will be mad. 33. Mother has willfully violated numerous provisions of this Court's August 8, 2012 and November 19, 2012 Orders of Court and, as a result, is in contempt of these Orders. 34. Father has and will incur unnecessary expenses in the preparation and presentation of this Petition, evidence of which shall be presented at trial. 35. Pursuant to 23 Pa.C.S. § 5323, a finding of contempt may be punishable by any one or more of the following: imprisonment for a period of not more than six months; a fine of not more than $500; probation for a period of not more than six months; suspension of a driver's license; and counsel fees and costs. 36. Further, 23 Pa.C.S. §5339 states that a court may award reasonable counsel fees, costs and expenses where the court finds the conduct of another party was obdurate, vexatious, repetitive or in bad faith. 37. Mother's demonstrated refusal to comply with this Court's Orders is both vexatious and in bad faith, and has been repetitive in nature. WHEREFORE, Petitioner, Keith Greenwald, respectfully requests that this Honorable Court enter an Order finding Defendant in Contempt of the November 19, 2012 and August 8, 2012 Orders of Court and impose any sanction upon Mother which this Court deems to be appropriate. MODIFICATION 38. Petitioner's Paragraphs 1-37 are incorporated herein by reference as though set forth in full. 39. Mother's contempt for the Orders of this Court demonstrates her unwillingness to co-parent with Father and act in Bradley's best interest. 40. Additionally, Mother's continued inability to maintain a stable home for Bradley is not only detrimental to his physical and emotional health, but continues to negatively impact Bradley's education. 41. There is also a pending investigation in the office of the Pennsylvania State Police regarding Bradley's statements to Father and Cumberland County Children and Youth that he was abused by his cousin while in Mother's care. 42. This alleged abuse is the subject of Father's Petition for Emergency Relief, filed with this Court on September 23, 2013. 43. For the aforementioned reasons, Father believes and therefore avers that the best interests and permanent welfare of the child will be served by granting Father and Mother shared legal custody of Bradley, with Father having primary physical custody and Mother having periods of partial physical custody. 44. Pursuant to 18 Pa.C.S. §4904, Father's Criminal Abuse/Record History Verification is attached hereto and marked as Exhibit "A". WHEREFORE, Petitioner, Keith Greenwald, respectfully requests that this Honorable Court enter an order granting the parties' shared legal custody, with Father having primary physical custody, and Mother having periods of partial physical custody. Respectfully submitted, Urt Allison C. Gossett Dated: C1)- 6 )3 Attorney for Plaintiff /19 - Ag„.1 - 8303 VERIFICATION, I verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Keith G eenwald Dated: Of 1 as 117 KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2007-571 HEIDI SHENCK, n/k/a, HEIDI SHOEMAKER, : CIVIL ACTION— LAW Defendant :. IN CUSTODY CRIMINAL RECORD/ABUSE HISTORY VERIFICATION I, kttf k n WGti GA , hereby swear or affirm, subject to penalties of law including 18 Pa.C.S. §4904 relating to unsworn falsification to authorities that: 1. Unless indicated by my checking the box next to a crime below, neither I nor any other member of my household have been convicted or pled guilty or pled no contest or was adjudicated delinquent where the record is publicly available pursuant to the Juvenile Act, 42 Pa.C.S. §6307 to any of the following crimes in Pennsylvania or a substantially equivalent crime in any other jurisdiction, including pending charges: Check Crime Self Other Date of Sentence all household conviction, that member guilty plea, apply no contest plea or pending • charges ❑ 18 Pa.C.S. Ch. 25 ❑ ❑ (relating to criminal homicide) ❑ 18 Pa.C.S. §2702 [ ❑ (relating to aggravated assault) L 18 Pa.C.S. §2706 II (relating to terroristic threats) ❑ 18 Pa.C.S. §2709.1 LI ❑ (relating to stalking) ❑ 18 Pa.C.S. §2901 C ❑ (relating to kidnapping) ❑ 18 Pa.C.S. §2902 C C (relating to unlawful restraint) n 18 Pa.C.S. §2903 I ( (- (relating to false imprisonment) P 18 Pa.C.S. §2910 n C (relating to luring a child into a motor vehicle or structure) I-] 18 Pa.C.S, §3121 ❑ ❑ (relating to rape) PI 18 Pa.C.S. §3122.1 ❑ n (relating to statutory sexual assault) n 18 Pa.C.S. §3123 C ❑ (relating to involuntary deviate sexual intercourse) n 18 Pa.C.S. §3124.1 n C (relating to sexual assault) n 18 Pa.C.S. §3125 I n (relating to aggravated indecent assault) C 18 Pa.C.S. §3126 I I I (relating to indecent assault) h 18 Pa.C.S. §3127 C ❑ (relating to indecent exposure) C 18 Pa.C.S. §3129 C I-- (relating to sexual intercourse with animal) ❑ 18 Pa.C.S. §3130 I I n (relating to conduct relating to sex offenders) ( 18 Pa.C.S. §3301 n ❑ (relating to arson and related offenses) n 18 Pa.C.S. §4302 n n (relating to incest) ❑ 18 Pa.C.S.§4303 C ❑ (relating to concealing death of child) ❑ 18 Pa.C.S. §4304 ❑ [ (relating to endangering welfare of children) ❑ 18 Pa.C.S. §4305 (1 (- (relating to dealing in infant children) ❑ 18 Pa.C.S. §5902(b) ❑ n (relating to prostitution and related offenses) ❑ 18 Pa.C.S. §5903(c) or (1 (� (d) (relating to obscene and other sexual materials and performances) (� 18 Pa.C.S. §6301 [� n (relating to corruption of minors) (� 18 Pa.C.S. §6312 U n (relating to sexual abuse of children) ❑ 18 Pa.C.S. §6318 [ U (relating to unlawful contact with minor) (� 18 Pa.C.S. §6320 (1 ❑ (relating to sexual exploitation of children) [ 18 Pa.C.S. §6114 [ ❑ (relating to contempt for violation of protection order or agreement) [ Driving under the [ ❑ influence of drugs or alcohol ❑ Manufacture, sale, n n delivery, holding, offering for sale or possession of any controlled substance or other drug or device 2. Unless indicated by my checking the box next to an item below, neither I nor any other member of my household have a history of violent or abusive conduct including the following: Check Self Other Date all household that member apply [I A finding of abuse by a Children &Youth ❑ El Agency or similar agency in Pennsylvania or similar statute in another jurisdiction E Abusive conduct as defined under the [ 1 C Protection from Abuse Act in Pennsylvania or similar statute in another jurisdiction ❑ Other: ❑ n 3. Please list any evaluation, counseling or other treatment received following conviction or finding of abuse: 4. If any conviction above applies to a household member, not a party, state that person's name, date of birth and relationship to the child: 5. If you are aware that the other party or members of the other party's household has or have a criminal/abuse history, please explain: I verify that the information above is true and correct to the best of my knowledge, information or belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C,S. §4904.relating to unsworn falsification to authorities. V 4,..' Signature Xe',./// P 6reelvad 5r Printed Name I KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2007-571 • HEIDI SHENCK, n/k/a, HEIDI SHOEMAKER, : CIVIL ACTION — LAW Defendant : IN CUSTODY CRIMINAL RECORD/ABUSE HISTORY VERIFICATION I, , hereby swear or affirm, subject to penalties of law including 18 Pa.C.S. §4904 relating to unsworn falsification to authorities that: 1. Unless indicated by my checking the box next to a crime below, neither I nor any other member of my household have been convicted or pled guilty or pled no contest or was adjudicated delinquent where the record is publicly available pursuant to the Juvenile Act, 42 Pa.C.S. §6307 to any of the following crimes in Pennsylvania or a substantially equivalent crime in any other jurisdiction, including pending charges: Check Crime Self Other Date of Sentence all household conviction, that member guilty plea, apply no contest plea or pending charges ❑ 18 Pa.C.S. Ch. 25 ❑ ❑ (relating to criminal homicide) ❑ 18 Pa.C.S. §2702 ❑ ❑ (relating to aggravated assault) ❑ 18 Pa.C.S. §2706 ❑ ❑ (relating to terroristic threats) ❑ 18 Pa.C.S. §2709.1 ❑ ❑ (relating to stalking) ❑ 18 Pa.C.S. §2901 ❑ ❑ (relating to kidnapping) ❑ 18 Pa.C.S. §2902 ❑ ❑ (relating to unlawful restraint) n 18 Pa.C.S. §2903 ❑ ❑ (relating to false imprisonment) ❑ 18 Pa.C.S. §2910 ❑ ❑ (relating to luring a child into a motor vehicle or structure) ❑ 18 Pa.C.S. §3121 ❑ ❑ (relating to rape) ❑ 18 Pa.C.S. §3122.1 ❑ ❑ (relating to statutory sexual assault) ❑ 18 Pa.C.S. §3123 ❑ ❑ (relating to involuntary deviate sexual intercourse) ❑ 18 Pa.C.S. §3124.1 ❑ ❑ (relating to sexual assault) ❑ 18 Pa.C.S. §3125 ❑ ❑ (relating to aggravated indecent assault) ❑ 18 Pa.C.S. §3126 ❑ ❑ (relating to indecent assault) ❑ 18 Pa.C.S. §3127 ❑ ❑ (relating to indecent exposure) ❑ 18 Pa.C.S. §3129 ❑ ❑ (relating to sexual intercourse with animal) ❑ 18 Pa.C.S. §3130 ❑ ❑ (relating to conduct relating to sex offenders) ❑ 18 Pa.C.S. §3301 ❑ ❑ (relating to arson and related offenses) ❑ 18 Pa.C.S. §4302 ❑ ❑ (relating to incest) ❑ 18 Pa.C.S. §4303 ❑ ❑ (relating to concealing death of child) ❑ 18 Pa.C.S. §4304 ❑ ❑ (relating to endangering welfare of children) ❑ 18 Pa.C.S. §4305 ❑ ❑ (relating to dealing in infant children) ❑ 18 Pa.C.S. §5902(b) ❑ ❑ (relating to prostitution and related offenses) ❑ 18 Pa.C.S. §5903(c) or ❑ ❑ (d) (relating to obscene and other sexual materials and performances) ❑ 18 Pa.C.S. §6301 ❑ n (relating to corruption of minors) [ 18 Pa.C.S. §6312 ❑ ❑ (relating to sexual abuse of children) ❑ 18 Pa.C.S. §6318 ❑ ❑ (relating to unlawful contact with minor) ❑ 18 Pa.C.S. §6320 ❑ ❑ (relating to sexual exploitation of children) ❑ 18 Pa.C.S. §6114 ❑ ❑ (relating to contempt for violation of protection order or agreement) ❑ Driving under the ❑ ❑ influence of drugs or alcohol ❑ Manufacture, sale, ❑ ❑ delivery, holding, offering for sale or possession of any controlled substance or other drug or device 2. Unless indicated by my checking the box next to an item below, neither I nor any other member of my household have a history of violent or abusive conduct including the following: Check Self Other Date all household that member apply ❑ A finding of abuse by a Children & Youth ❑ El Agency or similar agency in Pennsylvania or similar statute in another jurisdiction ❑ Abusive conduct as defined under the ❑ ❑ Protection from Abuse Act in Pennsylvania or similar statute in another jurisdiction ❑ Other: ❑ ❑ 3. Please list any evaluation, counseling or other treatment received following conviction or finding of abuse: 4. If any conviction above applies to a household member, not a party, state that person's name, date of birth and relationship to the child: 5. If you are aware that the other party or members of the other party's household has or have a criminal/abuse history, please explain: I verify that the information above is true and correct to the best of my knowledge, information or belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Signature Printed Name CERTIFICATE OF SERVICE The undersigned certifies that on the i day of September, 2013, a true and correct copy of the foregoing Petition for Contempt and Modification of Custody Order was served by facsimile and first-class mail, postage prepaid, upon the following: Jane Adams, Esquire 17 W South Street Carlisle, PA 17013 Allison C. Gossett KEITH GREENWALD IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA • 2007-571 CIVIL ACTION LAW HEIDI SHENCK N/K/A HEIDI SHOEMAKER IN CUSTODY DEFENDANT •• ORDER OF COURT AND NOW, Wednesday,October 02,2013 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M.Verney,Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse,Carlisle on Tuesday,October 22,2013 2:30 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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. You must file with the Court a verification regarding any criminal record or abuse history regarding you and anyone living in your household on or before the initial in-person contact with the court (including, but not limited to, a conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition. No party may make a change in the residence of any child which significantly impairs the ability of the other party to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and Pa.R.C.P. No. 1915.17 regarding relocation. FOR THE COURT, By: /s/ ,Jacqueline M. Verney, Esq.yiyi 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. M� � Cumberland County Bar Association !Et' `fit` - 32 South Bedford Street cam- z' A4-4i a. asseg Carlisle, Pennsylvania 17013 Telephone (717)249-3166 ? ;: J . Ads ,., /ol.2.�/3 nom° _ () •• J. t.)eat..)7 l KEITH GREENWALD, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA • V. HEIDI SHENCK, n/k/a • HEIDI SHOEMAKER, CIVIL ACTION - LAW Defendant/Respondent : NO. 2007-571 CIVIL TERM IN RE: PETITION FOR EMERGENCY RELIEF IN CUSTODY ORDER OF COURT AND NOW, this 30th day of September, 2013, after hearing, the Petition for Emergency Relief is denied. By the Court, Edward E. Guido, J. Allison Gossett, Esquire For the Plaintiff/Petitioner Jane Adams, Esquire For the Defendant/Respondent : lfh Copy ,Cam. /o/?I/3 • r...- KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-571 CIVIL ACTION-1' 'WF, T' HEIDI SHENCK N/K/A/ "' 'can _ HEIDI SHOEMAKER, Defendant : IN CUSTODY .t-� =° 3> I Z (` ORDER OF COURT Af AND NOW,this 4P7 day of 0 , 2013, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 'Q ke. 4-4-442 1. A pretrial conference •-• • • •.- • 4 the al•. .. cou .0,. - o e um Der ani • -• et''' . r - parties are c - -- - - •; y _�, �� � o ..a-"v �` _ .. o ... `,�., '..�� .1` • CMS'_ - • Git" . ` i. ..`.�. .. P , , / - 2. A Hearing is scheLlied in Court Room No. , of the Cumberland County Court House, on the / • day of , 2013, at ei`/!r"'4. ',4 o'clock, . M., at which time testimony will be taken. For purposes of this Hearing, Father shall be deemed to be the moving party and shall proceed initially with testimony. 3. Pending the hearing,the prior Orders of Court of the Honorable Edward E. Guido dated August, 8, 2012 and November 19, 2012 shall remain in full force and effect. 4. 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 TH e RT, 400 J. cc"�'son C. Gossett, Esquire, Counsel for Father ✓Jane Adams, Esquire, Counsel for Mother CO Fs Es Mai CgcL 1a/ash3 KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. : NO. 2007-571 CIVIL ACTION -LAW HEIDI SHENCK N/K/A/ HEIDI SHOEMAKER, • Defendant : IN CUSTODY PRIOR JUDGE: Edward E. Guido,J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8,the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Bradley Shenck March 14, 2006 Mother 2. A Conciliation Conference was held in this matter on October 22, 2013, with the following in attendance: The Father, Keith Greenwald, with his counsel, Allison C. Gossett, Esquire, and the Mother, Heidi Shoemaker, with her counsel, Jane Adams, Esquire. 3. The Honorable Edward E. Guido previously entered Orders of Court dated August 8, 2012,November 19, 2012 and September 30, 2013 providing for shared legal custody, Mother having primary physical custody and Father having alternating weekends. The Order of Court dated November 19, 2012 specifically forbade Mother from switching schools for the child. 4. Father's position on custody is as follows: Father seeks shared legal custody and primary physical custody, with Mother having alternating weekends. Father asserts that Mother is in contempt of the November Order because she switched the child's school without his consent or Order of Court. Father also alleges that Mother is in contempt because she has refused to advise him of her address. He believes she is currently living in a motel. Father maintains that the child would have more stability if he lived with Father, as Mother has moved at least 3 times since August, 2012. Father also suspects drug abuse by Mother. 5. Mother's position on custody is as follows: Mother seeks to maintain the status quo. Mother admits to changing schools for the child but asserts that it is a private school where he is getting more individualized attention. Mother has concerns about Father's household because of prior injuries the child has sustained and a lack of supervision. Mother asserts that she will be obtaining stable housing in the near future. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing, and maintaining the status quo. It is expected that the Hearing will require one half day. /3 Date 7acqiiine M. Verney, Esquire Custody Conciliator KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007 - 571 CIVIL ACTION - LfV HEIDI SHENCK, n/k/a : IN CUSTODY r.?° HEIDI SHOEMAKER, -c ' c Defendant : CIVIL ACTION - LAW < > PETITION TO WITHDRAW AS LEGAL COUNSEL tri AND NOW COMES the Petitioner, Jane Adams, Esquire, and files the above- referenced Petition and represents that: 1. Petitioner is Jane Adams, Esquire, (hereinafter "Petitioner"), an Attorney duly authorized to practice law in the Commonwealth of Pennsylvania, having a principal place of business located at 17 W. South St., Carlisle, Pa. 17013 2. Petitioner is currently attorney of record for Heidi Shoemaker, Defendant (hereinafter "Defendant") in the above-captioned matter. 3. Plaintiff is currently represented by Allison C. Gossett, Esquire. 4. A hearing before this Honorable Court regarding custody in this matter is currently set for December 12, 2013 at 9:15 a.m. 5. An emergency hearing was held in this matter on September 30, 2013, and a a conciliation conference was held on October 22, 2013. 6. On October 29, 2013, counsel for Defendant wrote her a letter requesting that she contact her, pay her fee, and make arrangements to meet with her and any witnesses. 7. Said letter was sent regular mail and was not returned. 8. Counsel has not heard from her client, Defendant, to prepare for the custody trial or pay her fee. 9. On December 2, 2013, Counsel called Defendant's cell phone number and got a message indicating that the "voice mailbox was full." • 10. On December 2, 2013, Counsel called Defendant's father, and asked him to please tell Defendant to call. 11. On December 3, 2013, Counsel again called Defendant's cell phone number and got a message that the voicemail box was full. 12. Counsel is requesting permission to withdraw on the above-captioned case because: (a)Counsel cannot properly prepare for the hearing scheduled in this matter because Defendant has not contacted her, or made timely arrangements to meet, prepare exhibits, and testimony. (b)Counsel has not been able to communicate with her client and Counsel does not feel she can adequately represent her if she cannot have direct and advance meaningful communication with her client. (c)Defendant has not paid the requested fee to Counsel. 13. Counsel is requesting that she be permitted to withdraw her appearance, or in the alternative, if she is not permitted to withdraw, that a continuance be granted, so counsel can prepare or so that Defendant can get other counsel. 14. Counsel contacted Allison Gossett, Esquire, Attorney for Plaintiff by telephone on the morning of December 3, 2013, and she indicated she did not object to Counsel withdrawing from this matter. It is assumed that she would not agree to a continuance. 15. This matter was previously referred to Judge Guido. WHEREFORE, Jane Adams, Esquire requests permission to withdraw her appearance from the above-captioned matter. Respectful) S :mitted, Date: I�1y �I' . 3 . I "Pb Adams, Esquire /'.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR DEFENDANT CERTIFICATE OF SERVICE AND NOW, this December 3, 2013, I, Jane Adams, Attorney for Heidi Shenck, hereby certify that a copy of this PETITION is being forwarded contemporaneously with this mailing to the following parties, by placing such in first-class mail, addressed to: Allison C. Gossett, Esquire 1820 Linglestown Road Harrisburg, Pa. 17110 Heidi Shenck 1521 Thompson Lane Mechanicsburg, Pa. 17055 Heidi Shenck, c!o Robin Shenck 39 Cold Springs Road Carlisle, Pa. 17015 Al j A i j,t.I Jan'I:da 1 , sere 1.R. o. 79465 . South St. rlisle, Pa. 17013 717) 245-8508 ATTORNEY FOR DEFENDANT KEITH B. GREENWALD, JR, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 2007—571 CIVIL ACTION—LAW HEIDI A. SHENCK,N/K/A :IN CUSTODY HEIDI A. SHOEMAKER, Defendant :CIVIL ACTION—LAW m co rn rn C77, PETITION TO REQUEST A CONTINUANCE `F' AND NOW COMES the Petitioner, Heidi Shoemaker, Defendant, and files the above—referenced Petition,requests a continuance for the custody hearing scheduled for December 12th, 2013 for the following reasons and represents that: 1. Petitioner is Heidi Shoemaker, Defendant, residing at 3452 Lisburn Road, Mechanicsburg, Pennsylvania, 17055-6731, Lower Allen Township, Cumberland County, Pennsylvania. 2. My lawyer, Jane Adams has been misrepresenting me (futher explained below). 3. My daughter got very sick and almost died and was hospitalized for three days recently of which I spent the entire time there and she is still sick and on medication. 4. On several occasions including once in the elevator in Cumberland County Court House after the emergency hearing on this case, we offered to pay Jane Adams the full amount for the next hearing at which time she refused and stated that we still had a credit with her. A second time was after the recent conciliation hearing on this case and once again Jane Adams refused to take a payment and insisted we still had a credit. 5. The same instance described above after the conciliation hearing, I met Jane Adams at her office and gave her a list of witnesses that she had asked for along with their phone numbers, who they were, where they worked and why we wanted them to testify. Jane Adams said she would get a hold of them for court. To my knowledge after speaking with a couple of the witnesses and from Jane Adams own account she has yet to contact any of them. 6. I am securing a new attorney but they are unavailable on the 12th of December, 2013,they are also unavailable December 18th, 2013, December 23'1, 2013, Christmas and January 13th, 2014 as they are in court those days and for Christmas. CERTIFICATE OF SERVICE AND NOW, this December 10th, 2013, I, Heidi Shoemaker, Defendant hereby certify that a copy of this PETITION is being forwarded contemporaneously with this mailing to the following parties, by placing such in first-class mail, addressed to: Allison C. Gossett, Esquire 1820 Linglestown Road Harrisburg, PA 17110 Jane Adams, Esquire 17 West South Street Carlisle, PA 17013 Heidi Shoemaker 3452 Lisburn Road Mechanicsburg, PA 17055 .. .__ALA ,_53u;4.. .itilLy.L, Heidi Shoemaker, Defendant (717) 713-9117 heidishenck @rocketmail.com 3452 Lisburn Road Mechanicsburg, PA 17055-6731 fa N)-Cd&C\ I r�l feT!444110, .� 4_01_ 6, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA Vs : No. (r-S tl CIVIL TERM • iuA _ .c o CIVIL ACTION - LAW �izr `�'"' Defendant IN CUSTODY (-T __ CO c r—2 CRIMINAL RECORD /ABUSE HISTORY VERIFICATION I, AltireiC0,019fhereby swear or affirm, subject to penattiest law including 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities that: 1. Unless indicated by my checking the box next to a crime below, neither I nor any other member of my household have been convicted or pled guilty or pled no contest or was adjudicated delinquent where the record is publicly available pursuant to the Juvenile Act 42 Pa.C.S. § 6307 to any of the following crimes in Pennsylvania or a substantially equivalent crime in any other jurisdiction, including pending charges: Check Crime Self Other Date of Sentence all that household conviction, apply member guilty plea, no contest plea or pending charges 18 Pa.C.S. Ch. 25 r r (relating to criminal homicide) 18 Pa.C.S. §2702 r- (relating to aggravated assault) IT 18 Pa.C.S. §2706 IT (relating to terroristic threats) 18 Pa.C.S. §2709.1 IT (relating to stalking) 18 Pa.C.S. §2901 FT (relating to kidnapping) IT 18 Pa.C.S. §2902 IT IT (relating to unlawful restraint) IT 18 Pa.C.S. §2903 IT IT (relating to false imprisonment) IT 18 Pa.C.S. §2910 IT IT (relating to luring a child into a motor vehicle or structure) IT 18 Pa.C.S. §3121 fT IT (relating to rape) fT 18 Pa.C.S. §3122.1 relating to statutory sexual assault) fT 18 Pa.C.S. §3123 IT. IT (relating to involuntary deviate sexual intercourse) IT 18 Pa.C.S. §3124.1 iTT IT (relating to sexual assault) ITT 18 Pa.C.S. §3125 (relating to aggravated indecent assault) IT 18 Pa.C.S. §3126 ITT ITT (relating to indecent assault) IT 18 Pa.C.S. §3127 IT IT (relating to indecent exposure) 18 Pa.C.S. §3129 r r (relating to sexual intercourse with animals) 18 Pa.C.S. §3130 r r (relating to conduct relating to sex offenders) 18 Pa.C.S. §3301 r r (relating to arson and related offenses) r 18 Pa.C.S. §4302 r r (relating to incest) IT 18 Pa.C.S. §4303 r r (relating to concealing death of child) 18 Pa.C.S. §4304 r IT (relating to endangering welfare of children) r 18 Pa.C.S. §4305 r r (relating to dealing in infant children) r 18 Pa.C.S. §5902(b) r r (relating to prostitution and related offenses) ET 18 Pa.C.S. §5903 r r (c) or (d) (relating to obscene and other sexual materials and performances) 18 Pa.C.S. §6301 r r (relating to corruption of minors) 18 Pa.C.S. §6312 IT (relating to sexual abuse of children) 18 Pa.C.S. §6318 IT IT (relating to unlawful contact with minor) 18 Pa.C.S. §6320 IT r (relating to sexual exploitation of children) r- 23 Pa.C.S. §6114 I; (relating to contempt for violation of Protection order or agreement) Driving under the I influence of drugs or alcohol Manufacture, sale, r delivery, holding, offering for sale or possession of any controlled substance or other drug or device 2. Unless indicated by my checking the box next to an item below, neither I nor any other member of my household have a history of violent or abusive conduct including the following: Check Self Other Date all that household apply member IT A finding of abuse by a Children &Youth ET IT Agency or similar agency in Pennsylvania or similar statute in another jurisdiction Abusive conduct as defined under the IT Protection from Abuse Act in Pennsylvania or similar statute in another jurisdiction Other: rT FT 3. Please list any evaluation, counseling or other treatment received following conviction or finding of abuse: 4. If any conviction above applies to a household member, not a party, state that person's name, date of birth and relationship to the child : 5. If you are aware that the other party or members of the party's household has or have a criminal /abuse history, please explain: I verify that the information above is true and correct to the best of my knowledge information or belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. kit A I.: IAA .6.4 Signature i-1eid; A . So ak Printed Name KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007 - 571 CIVIL ACTION W ri ' r�. `... HEIDI SHENCK, n/k/a : IN CUSTODY icy gyp.., HEIDI SHOEMAKER, : �`' t 1: Defendant : CIVIL ACTION - LAW . _, PETITION TO WITHDRAW AS LEGAL COUNSEL AND NOW COMES the Petitioner, Jane Adams, Esquire, and files the above- referenced Petition and represents that: 1. Petitioner is Jane Adams, Esquire, (hereinafter"Petitioner"), an Attorney duly authorized to practice law in the Commonwealth of Pennsylvania, having a principal place of business located at 17 W. South St., Carlisle, Pa. 17013 2. Petitioner is currently attorney of record for Heidi Shoemaker, Defendant (hereinafter"Defendant") in the above-captioned matter. 3. Plaintiff is currently represented by Allison C. Gossett, Esquire. 4. A hearing before this Honorable Court regarding custody in this matter was held on December 12, 2013 at 9:15 a.m. 5. Counsel is requesting permission to withdraw on the above-captioned case. 6. No hearing in this matter is presently scheduled, so withdrawal would be not prejudicial to the client. 7. Counsel spoke with Allison Gossett, Esquire, Attorney for Plaintiff on December 12, 2013. She indicated she did not object to Counsel withdrawing from this matter. 8. Defendant was previously served with a Motion to Withdraw appearance, which was filed on or about December 4, 2013, so she has notice that Counsel is seeking withdrawal on this case. 9. This matter is assigned to Judge Guido. WHEREFORE, Jane Adams, Esquire requests permission to withdraw her appearance from the above-captioned matter. Respectfully Submitted, Date: i.L1� �_�� ��� r (2, i �3 �,' J: e Adams, Esquire I. No. 79465 W. South St. rlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR DEFENDANT CERTIFICATE OF SERVICE AND NOW, this December 12, 2013, I, Jane Adams, Attorney for Heidi Shenck, hereby certify that a copy of this PETITION is being forwarded contemporaneously with this mailing to the following parties, by placing such in first-class mail, addressed to: Allison C. Gossett, Esquire 1820 Linglestown Road Harrisburg, Pa. 17110 Heidi Shenck 3452 Lisburn Road Mechanicsburg, Pa. 17055 . 1r J' e Adams, Esquire /J. No. 79465 W. South St. arlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR DEFENDANT KEITH GREENWALD, IN THE COURT OF COMMON PLEAg O y Plaintiff CUMBERLAND COUNTY, PENNSYi-aa3 RNIA; r*f v. NO. 2007-571 CIVIL TERM --� ` HEIDI SHENCK N/K/A HEIDI SHOEMAKER, CIVIL ACTION - LAW ;_.�' Defendant IN CUSTODY :cc) '.5 CD( ORDER OF COURT AND NOW, this 12th day of December, 2013 , after hearing, it is ordered and directed as follows : 1 . The Father, Keith Greenwald, and the Mother, Heidi Shoemaker, shall have shared legal custody of Bradley Shenck, born March 14, 2006 . Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child' s general well-being including, but not limited to, all decisions regarding his health, education, and religion. Pursuant to the terms of 23 Pa. C. S . Section 5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental , religious, or school records, the residence address of the child and the other parent . To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent . Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher, or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards . Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children' s parties, musical presentations, back-to-school nights, and the like . 2 . Father shall have primary physical custody of the child. 3 . Mother shall have partial physical custody as follows : A. When school is not in session, every weekend from Friday at 4 : 00 p.m. until Monday at 4 : 00 p.m. B. When school is in session, every other weekend from Friday at 6 : 00 p.m. until Monday at the beginning of school . If the child has off school on Monday, then the visitation shall extend until Tuesday at the beginning of school . It shall be Mother' s responsibility to see that the child gets to school or to return the child the evening before so that Father can get him to school . C. Such other times as the parties agree. 4 . The child is never to be alone with Kandace Lower while in Mother' s custody. 5 . Physical custody on holidays, which shall take precedence over the regular schedule, shall be as designated on the schedule attached as Exhibit A. 6 . Transportation shall be shared, with all custody exchanges to be at the Silver Spring Township Police Department except for the switch in 3-B. 7 . No party shall be permitted to relocate the residence of the child which significantly impairs the ability to exercise custody unless every individual who has custodial rights to the child consents to the proposed relocation. A person proposing to relocate must comply with 23 Pa. C. S . Section 5337 . 8 . Neither party shall do or say anything nor permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child' s love and respect for the other parent . 9 . The custodial parent shall ensure that the child talks with the non-custodial parent by telephone on a daily basis . 10 . Each party shall keep the other informed of his or her address at all times . 11 . Father shall ensure that the child continues in his counseling until successfully discharged. Father shall also ensure that the child keeps his evaluation for ADD at the Sadler Clinic scheduled for later this month. In that regard, Mother is directed to provide the Father with the time of said evaluation. By the Court, Edward E. Guido, J. Allison C. Gossett, Esquire .,�` � ( For the Plaintiff aJIE.S /1.tL.c. ,,L /Jane Adams, Esquire la./J3l/3 For the Defendant Sheriff srs • HOLIDAYS AND TIMES ODD EVEN SPECIAL DAYS YEARS YEARS ' Easter Day 1st half From 9:00 a.m.to 3:00 p.m. Father Father Easter Day 2nd half From 3:00 p.m.to 9:00 p.m. Mother Mother Memorial Day From 9:00 a.m.to 9:00 p.m. Mother Father Independence Day From 9:00 a.m.to 9:00 p.m. Father Mother Labor Day From 9:00 a.m.to 9:00 p.m. Mother Father Thanksgiving 1st half From 9:00 a.m.to 3:00 p.m. Father Father I-- m_ Thanksgiving 2nd half From 3:00 p.m.to 9:00 p.m. Mother Mother 6869"�c9-oO8avN3d Christmas 1st half From 12:00 noon on 12/24 to 12:00 noon on Father Mother 12/25 Christmas 2nd half From 12:00 noon on 12/25 to 12:00 noon on Mother Father 12/26 Mother's Day From 9:00 a.m.to 9:00 p.m. Mother Mother Father's Day From 9:00 a.m.to 9:00 p.m. Father Father Good Friday From 9:00 a.m.•to 9:00 p.m. Father Father New Year's Day 1st half From 9:00 a.m.to 3:00 p.m. Father Mother New Year's Day 2nd half From 3:00 p.m.to 9:00 p.m. Mother Father Mother's Birthday From 9:00 a.m.to 9:00 p.m. Mother Mother Father's Birthday From 9:00 a.m.to 9:00 p.m. Father Father First Day of Fishing Season From Friday before at 4:00 p.m.to Saturday at Father Father 4:00 p.m. Whoever has Trick or Treat night From 5:00 p.m.to 9:00 p.m.,if on the same physical Alternate from night in both parent's municipality;if on custody on the prior year different night,then each parent will have week on/week physical custody on their respective nights. off schedule KEITH GREENWALD, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2007-571 CIVIL TERM HEIDI SHENCK N/K/A HEIDI SHOEMAKER, CIVIL ACTION - LAW Defendant IN CUSTODY IN RE: CONTEMPT ORDER OF COURT AND NOW, this 12th day of December, 2013 , after hearing, we find Mother to be in contempt of our prior Order, and she is so adjudicated. In light of the fact that we have switched primary custody to Father, no sanctions will be imposed. By the Court, e;;;ii Edward E. Guido, J. ./Allison C. Gossett, Esquire For the Plaintiff ane Adams, Esquire c For the Defendant � � ter- ...._ Sheriff - ` -<> -- srs ,ci• Cop c 1.1,//3//3 , , . 3 KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007 - 571 CIVIL ACTION - LAW HEIDI SHENCK, n/k/a : IN CUSTODY HEIDI SHOEMAKER, Defendant : CIVIL ACTION - LAW ORDER OF COURT OA AND NOW, this, l� _day of beoce);444 , 2013, it is hereby ORDERED and DECREED that Jane Adams, Esquire, is permitted to withdraw her appearance on behalf of Heidi Shoemaker. BY THE CO T: d _0.///P..:-._ J. cc: 4e Adams, Esquire -0a ` '' Alison C. Gossett, Esquire vi r- — _..; 1/Heidi Shoemaker, Defendant Dc -, t gO 1 �� r r KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff • CUMBERLAND COUNTY, PENNSYLVANIA • V. • NO. 2007 - 571 CIVIL ACTION - LAW • HEIDI SHENCK, n/k/a • IN CUSTODY HEIDI SHOEMAKER, Defendant • CIVIL ACTION - LAW PRAECIPE FOR WITHDRAWAL TO THE PROTHONOTARY: Pursuant to the attached Order, please withdraw the appearance of Jane Adams, Esquire, as Attorney of record for Heidi Shoemaker. Respectfully Submitted: Date: '1 1 d A � 5 a Adams, Esquire B. No. 79465 W. South St. ' arlisle, Pa. 17013 (717) 245-8508 I NJ KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007 - 571 CIVIL ACTION - LAW HEIDI SHENCK, n/k/a : IN CUSTODY HEIDI SHOEMAKER, Defendant : CIVIL ACTION - LAW ORDER OF COURT AND NOW, this i� day of be40$4414 , 2013, it is hereby ORDERED and DECREED that Jane Adams, Esquire, is permitted to withdraw her appearance on behalf of Heidi Shoemaker. BY THE CO T: J. cc: Jane Adams, Esquire Q r=1 rr Allison C. Gossett, Esquire rri Heidi Shoemaker, Defendant r- -1 "a? ` L L+ P:-,01.110N011, :l TANNER BARCAVAGE 3507 Market Street, Suite 303 2014 FEB 14 PM 2: 45 Camp Hill, PA 17011 CUMBERLAND COUNTY Telephone: (717) 731-8114 PENNSYLVANIA Facsimile: (717) 731-8115 KEITH GREENWALD, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA v. § No. 2007-571 HEIDI SHENCK n/k/a § HEIDI SHOEMAKER, § Defendant § CIVIL ACTION - CUSTODY PETITION FOR CONTEMPT/MODIFICATION OF CUSTODY ORDER AND NOW, comes the Defendant, Heidi Shoemaker, by her attorney, Tabetha A. Tanner, Esquire, and avers the following in support of her Petition for Contempt of Custody Order: 1. Defendant, Heidi Shoemaker, hereinafter referred to as "Mother", is an adult individual currently residing at 3452 Lisburn Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Plaintiff, Keith Greenwald, hereinafter referred to as "Father", is an individual currently residing at 110 Huckleberry Road,New Bloomfield, Perry County, Pennsylvania 17068. 3. The subject minor child is Bradley Scott Shenck, born March 14, 2006. 4. The child is presently residing with Father, Father's Wife, Father's son, Wife's three children, and Wife's daughter's boyfriend. 5. A Custody Order was entered on December 12,2013,granting shared legal custody to the parties, and primary physical custody to Respondent (Exhibit A). *63.00 Po ATP/ Cf 500'7 et-30160 6. Paragraph 11 of the December 12, 2013 Order states "Father shall ensure that the child continues his counseling until successfully discharged. Father shall also ensure that the child keeps his evaluation for ADD at the Sadler clinic scheduled for later this month." 7. Petitioner asserts that the Court's intention was for the child to have the consistency of treating with the same provider that he has been treated by for the past five (5) years. 8. The child has not been successfully discharged from counseling with the Steven's Center, who has been providing care for him since 2012. 9. The child has not been successfully discharged from counseling with his rape counselor, Melissa Rosenberger at the YWCA that he has been seeing since August 2013. 10. The child has been treating with Sadler as his pediatrician and ADD evaluation for the past five years. 11. In violation of the Order, Father pulled the child out of his counseling with the Seven's Center and the YWCA without being successfully discharged. 12. In violation of the Order, Father has pulled the child out of the consistent care of Sadler. 13. The child's consistency with Sadler and the counselor's with whom he is comfortable has been interrupted. 14. Paragraph 8 of the December 12,2013 Order states"Neither party shall do or say anything nor permit a third party to do or say anything that may estrange the child from the other parent,injure the opinion of the child as to the other parent,or hamper the free and natural development of the child's love and respect for the other parent." 15. In violation of this provision,Father continuously tells the child that Mother is doing drugs and other similar unfounded statements in order to alienate child from Mother. 16. Plaintiff's conduct has begun and if not stopped, will continue to alienate the affections of the child toward Mother. 17. During the custody exchange on Friday,January 3,2014,Respondent arrived at the police station prior to Petitioner's husband. Petitioner believes that Respondent told the police (with the child present) that Petitioner was using drugs. 18. In response to Respondent's assertions to the police,prior to Petitioner's husband taking custody of the child, the police canine unit walked around Petitioner's vehicle and the police put the child in Petitioner's vehicle. 19. The interaction of the police in order for Petitioner to take custody further suggests to the child that Petitioner has done something wrong such that the police need to be so involved in the exchange, further alienating the affections of the child toward Mother. 20. Furthermore, during that exchange, Respondent provided a baggy full of purportedly prescription medications to the police and had the police try to give the medications to Petitioner's husband. The medications were not in the original pill bottles and did not have any instructions or indications as to what the medications were or what they were to be used for. 21. Upon Petitioner's husband's refusal to accept medications without the original bottles or any information about the pills, Respondent wrote a hand-written note simply providing the color of the medication and when they should be administered, but again, did not provide any information about what the pills were or why they were to be provided to the child. 22. The holiday schedule as provided in Exhibit A of the December 2013 Order clearly states that on New Year's Day in even numbered years, such as 2014,Mother is to have custody of the child from 9AM until 3PM. Petitioner's husband arrived at the exchange point at 9AM and waited until 10PM. Respondent did not show up with the child. 23. When Respondent did not show up, a call was placed to Respondent. He did not answer his phone. Further calls went right to voice mail. At approximately 4PM, Respondent called and said that he was at the exchange point at 3PM. 24. When Petitioner explained that the morning time was supposed to be hers, Respondent said that she was wrong and did not permit Petitioner to have even the rest of the afternoon with the child. 25. Respondent had a police officer from Perry County call Petitioner to tell her that it was not her morning to have the child,which is clearly contrary to the provisions of the December 2013 Order of Court. 26. Petitioner did not have any time with the child on New Year's Day. 27. Furthermore,Petitioner was not able to speak to the child until the custodial exchange on January 3, 2014. 28. Paragraph 9 of the December 2013 Order states"The custodial parent shall ensure that the child talks with the non-custodial parent by telephone on a daily basis." 29. Respondent violated this Order by refusing to permit Petitioner to speak with the child from January 1, 2014 until January 3, 2014. 30. Respondent continues to violate this provision. Respondent has stated numerous times via email to Petitioner that he will have the child call at 4:30PM only. If Petitioner is unable to speak to the child at that time, she has until 6PM to return the call. After 6PM Respondent will not permit the Petitioner to speak with the child. 31. Petitioner has a 1 year old child and is pregnant. She is not always available between 4:30PM and 6PM. 32. On January 8, 2014, Petitioner called the child and got a message that stated that the telephone she was calling was not accepting calls. 33. When Petitioner spoke to the child on January 9, 2014, the child told her that he called Petitioner on January 8, but that Petitioner did not return his call. This was simply not true. The child was hurt by it, and these actions by Respondent further alienate the child from Mother. 34. On January 10, 2014, Petitioner missed the call from the child. She returned the call at 6:30PM. Despite the fact that Respondent states that the child does not go to bed until 8PM and despite the fact that she left a message, the call was not returned. 35. On January 11,2014,Petitioner called the child at 6:30PM. The child nor Respondent did not answer the phone and the call was not returned. 36. The best interest and permanent welfare of the child will be served by granting the relief requested herein. WHEREFORE, Petitioner respectfully requests that Court order the following: 1. Respondent be found in contempt of Court for violating the December 2013 Order; 2. Respondent be ordered to immediately cease counseling with the provider Respondent obtained after the entry of the December 2013 Order of Court; 3. Respondent be ordered to immediately re-engage the child with the services provided by the Steven's Center and the YWCA; 4. Respondent be ordered to immediately cease care with Loysville Family Practice; 5. Respondent be ordered to immediately re-engage the child with the services provided by Sadler Health Center. 4. Respondent be ordered to immediately cease telling the child that Mother is using drugs or in any other way speak about Mother to or around the child in a derogatory manner; 5. Respondent be ordered to return all telephone calls by Petitioner the same day that she calls, even if the calls are after 6PM; 6. Respondent be prohibited from telling the child that Petitioner did not return his phone calls; 7. Petitioner be provided with an additional day of custody to make up for the time she missed on New Year's Day; 8. Respondent be ordered to pay Petitioner's attorney's fees and costs in filing and litigating this contempt action. • Respectfully submitted, / l a, Tabetha Tanner, Esquire Supreme Court I.D. No.• 91979 Attorney for Petitioner VERIFICATION I verify that the statements made in this Petition for Contempt/Modification of Custody Order are true and correct. I understand that false statements made herein may subject me to penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: JP /q �� ' `' aosirnA Heidi Ann Shoemaker, Petitioner KEITH GREENWALD, IN THE COURT OF COMMON PLEA Off, Plaintiff CUMBERLAND COUNTY, PENNSY3ZAMI$; n z_z_-.. v. NO. 2007-571 CIVIL TERM 0)1._ HEIDI SHENCK N/K/A r- cz3 —+ct HEIDI SHOEMAKER, CIVIL ACTION - LAW Defendant IN CUSTODY C..1 : ORDER OF COURT AND NOW, this 12th day of December, 2013, after hearing, it is ordered and directed as follows : 1 . The Father, Keith Greenwald, and the Mother, Heidi Shoemaker, shall have shared legal custody of Bradley Shenck, born March 14, 2006 . Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child' s general well-being including, but not limited to, all decisions regarding his health, education, and religion. Pursuant to the terms of 23 Pa. C. S. Section 5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious, or school records, the residence address of the child and the other parent . To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent . Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher, or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth ,L ., < i .. ..,5➢n1,_ ...fl .#r�A __':7_,i .S y!i .. ., .,., e.r. 3,,.,_. ._ .w... ..'s......s_ $ certificates, school or educational attendance records or report cards . Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children' s parties, musical presentations, back-to-school nights, and the like . 2 . Father shall have primary physical custody of the child. 3 . Mother shall have partial physical custody as follows : A. When school is not in session, every weekend from Friday at 4 : 00 p.m. until Monday at 4 : 00 p.m. B. When school is in session, every other weekend from Friday at 6 : 00 p.m. until Monday at the beginning of school . If the child has off school on Monday, then the visitation shall extend until Tuesday at the beginning of school . It shall be Mother's responsibility to see that the child gets to school or to return the child the evening before so that Father can get him to school . C. Such other times as the parties agree. 4 . The child is never to be alone with Kandace Lower while in Mother' s custody. 5 . Physical custody on holidays, which shall take precedence over the regular schedule, shall be as designated on the schedule attached as Exhibit A. 6 . Transportation shall be shared, with all custody exchanges to be at the Silver Spring Township Police Department except for the switch in 3-B. 7 . No party shall be permitted to relocate the residence of the child which significantly impairs the ability • to exercise custody unless every individual who has custodial } rights to the child consents to the proposed relocation. A person proposing to relocate must comply with 23 Pa. C. S . Section 5337 . 8 . Neither party shall do or say anything nor permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child' s love and respect for the other parent . 9 . The custodial parent shall ensure that the child talks with the non-custodial parent by telephone on a daily basis. 10 . Each party shall keep the other informed of his or her address at all times . 11 . Father shall ensure that the child continues in his counseling until successfully discharged. Father shall also ensure that the child keeps his evaluation for ADD at the Sadler Clinic scheduled for later this month. In that regard, Mother is directed to provide the Father with the time of said evaluation. By the Court, Igii Edward E. Guido, J. Allison C. Gossett, Esquire For the Plaintiff aer6,s ,/Jane Adams, Esquire 1 ./13//1 For the Defendant Sheriff srs r 1 HOLIDAYS AND TIMES ODD EVEN SPECIAL DAYS YEARS YEARS ' Easter Day 1st half From 9:00 a.m.to 3:00 p.m. Father Father Easter Day 2"d half From 3:00 p.m.to 9:00 p.m. Mother Mother Memorial Day From 9:00 a.m.to 9:00 p.m. Mother Father Independence Day From 9:00 a.m.to 9:00 p.m. Father Mother Labor Day From 9:00 a.m.to 9:00 p.m. Mother Father Thanksgiving 15t half From 9:00 a.m.to 3:00 p.m. Father Father I— . m Thanksgiving 2n1 half From 3:00 p.m.to 9:00 p.m. Mother Mother 686ste9-008 miota3d Christmas ls`half From 12:00 noon on 12/24 to 12:00 noon on Father Mother 12/25 Christmas 2nd half From 12:00 noon on 12/25 to 12:00 noon on Mother Father 12/26 Mother's Day From 9:00 a.m.to 9:00 p.m. Mother Mother Father's Day From 9:00 a.m.to 9:00 p.m. Father Father Good Friday From 9:00 a.m.'to 9:00 p.m. Father Father New Year's bay 15`half From 9:00 a.m.to 3:00 p.m. Father Mother New Year's Day 2nd half From 3:00 p.m.to 9:00 p.m. Mother Father Mother's Birthday From 9:00 a.m.to 9:00 p.m. Mother Mother Father's Birthday From 9:00 a.m.to 9:00 p.m. Father Father First Day of Fishing Season From Friday before at 4:00 p.m.to Saturday at Father Father 4:00 p.m. _ Whoever has Trick or Treat night From 5:00 p.m.to 9:00 p.m.,if on the same physical Alternate from night in both parent's municipality;if on custody on the prior year different night,then each parent will have week on/week physical custody on their respective nights. off schedule KEITH GREENWALD IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PA Vs No, 2007-571 CIVIL TERM HEIDI SHENCK n/k/a t�. HEIDI SHOEMAKER : CIVIL ACTION - LAW 2 Defendant : IN CUSTODY -v3 xm s i' rte-'--' ors ) (An -- ` CRIMINAL RECORD/ABUSE HISTORY VERIFICATION r�-zcs 1, Heidi Shoemaker , hereby swear or affirm, subject to penaM of la w including 18 Pa. C.S. §4904 relating to unsworn falsification to authorities that: _ ,--• c 1. Unless indicated by my checking the box next to a crime below, neither I nor any other member of my household have been convicted or pled guilty or pled no contest or was adjudicated delinquent where the record is publicly available pursuant to the Juvenile Act 42 Pa.C.S. § 6307 to any of the following crimes in Pennsylvania or a substantially equivalent crime in any other jurisdiction, including pending charges: Check Crime Self Other Date of Sentence all that household convict apply member guilty plea. no contest plea or pending charges 18 Pa.C.S.Ch.25 r El (relating to criminal homicide) Cr 18 Pa.C.S.§2702 r El (relating to aggravated assault' 18 Pa.C.S. §2786 fT r (relating to terroristic threats) 18 Pa.C.S.§2709.1 (relating to stalking) rr 18 Pa.C.S. §2901 IT r (relating to kidnapping) I ; 18 Pa.C.S. §2902 r FE (relating to unlawful restraint) 18 Pa.C.S. §2903 7 (relating to false imprisonment! 18 Pa.C.S.§2910 CT CT (relatingto luring a child into a motor vehicle or structure! 18 Pa.C.S. §3121 C CT (relating to rape) _I 18 Pa.C.S. §3122.1 r FE relating to statutory sexual assault) 12 18 Pa.C.S. §3123 C C 'relating to involuntary deviate sexual intercourse) I 18 Pa.C.S. §3124.1 IT FE 'relating to sexual assault) 18 Pa.C.S.§3125 CT CT (relating to aggravated indecent assault) 18 Pa.C.S. §3126 C C (relating to indecent assault! I : 18 Pa.C.S. §3127 CT r (relating to indecent exposure! 18 Pa.C.S.§3129 IT IT (relating to sexual intercourse with animals) 18 Pa.C.S.§3130 IT (relating to conduct relating to sex offenders) 18 Pa.C.S. §3301 IT r (relating to arson and related offenses) I 18 Pa.C.S. §4302 IT IT (relating to incest) I _a 18 Pa.C.S. §4303 LT- !relating to concealing death of child) 18 Pa.C.S. §4304 I 7 (relating to endangering welfare of children} 1 _.' 18 Pa.C.S.§4305 1 IT (relating to dealing in infant children) 18 Pa.C.S. §5902(b) IT IT Jrelating to prostitution and related offenses] _. 18 Pa.C.S.§5903 IT r- (c)or(d) (relating to obscene and other sexual materials and performances) 18 Pa.C.S. §6301 (relating to corruption of minors] 18 Pa.C.S.§6312 IT FT (relating to sexual abuse of children' 18 Pa.C.S.§6318 r IT (relating to unlawful contact with minor) 18 Pa.C.S. §6320 FT (relating to sexual exploitation of children) 23 Pa.C.S. §6114 FT I (relating to contempt for violation of Protection order or agreement) Driving under the C (o i11 5 probakvi influence of drugs or alcohol .__ Manufacture,sale, IT delivery,holding, offering for sale or possession of any controlled substance or other drug or device 2. Unless indicated by my checking the box next to an item below, neither I nor any other member of my household have a history of violent or abusive conduct including the following: heck Self Other Date II that household . .l member -_ A finding of abuse by a Children&Youth fT I Agency or similar agency in Pennsylvania or similar statute in another iurisdiction Abusive conduct as defined under the Protection from Abuse Act in Pennsylvania or similar statute in another jurisdiction Other: E E 3. Please list any evaluation, counseling or other treatment received following conviction or finding of abuse: N/A 4. If any conviction above applies to a household member, not a party, state that person's name, date of birth and relationship to the child : 5. If you are aware that the other party or members of the party's household has or have a criminal/abuse history, please explain: I erify that the information above is true and correct to the best of my knowledge in ormation or belief. I understand that false statements herein are made subject to the p;nalties of 1.8 Pa.C.S. §4904 relating to unsworn falsification to authorities. A2L4 56-Cfritet keit Signature Heidi Shoemaker Printed Name KEITH GREENWALD IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLV, IAc 3 V. 2007-571 CIVIL ACTION LAWS f__ HEIDI SHENCK N/K/A HEIDI SHOEMAKER Nr IN CUSTODY c_• DEFENDANT C =- Z c� ORDER OF COURT c.=> AND NOW, Friday,February 21,2014 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M.Verney, Esq. , the conciliator, at 4th Floor,Cumberland County Courthouse,Carlisle on Tuesday, March 25,2014 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute: or if this cannot be accomplished,to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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. You must file with the Court a verification regarding any criminal record or abuse history regarding you and anyone living in your household on or before the initial in-person contact with the court(including, but not limited to, a conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition. No party may make a change in the residence of any child which significantly impairs the ability of the other party to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and Pa.R.C.P. No. 1915.17 regarding relocation. FOR THE COURT. By: /s/ Jacqueline M. Verney, Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court,please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. M�, rr 1 Cumberland County Bar Association I .S£ If1,14 .� 32 South Bedford Street 41-41 Q ` S__( - Carlisle, Pennsylvania 17013 �7 �a� Telephone (717)249-3166 Atiiy J . uedLoof *JP( KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2007-571 HEIDI SHENCK, n/k/a, • -, HEIDI SHOEMAKER, : CIVIL ACTION - LAW Defendant : IN CUSTODY : {�) t:7 y_- co ...i CRIMINAL RECORD/ABUSE HISTORY VERIFICATION c-:; c -- _.,, I, Keith Greenwald, hereby swear or affirm, subject to penalties of lavjc c — including 18 Pa.C.S. §4904 relating to unsworn falsification to authorities that: 1. Unless indicated by my checking the box next to a crime below, neither I nor any other member of my household have been convicted or pled guilty or pled no contest or was adjudicated delinquent where the record is publicly available pursuant to the Juvenile Act, 42 Pa.C.S. §6307 to any of the following crimes in Pennsylvania or a substantially equivalent crime in any other jurisdiction, including pending charges: Check Crime Self Other Date of Sentence all household conviction, that member guilty plea, apply no contest plea or pending charges U 18 Pa.C.S. Ch. 25 ❑ ❑ (relating to criminal homicide) ❑ 18 Pa.C.S. §2702 ❑ ❑ (relating to aggravated assault) ❑ 18 Pa.C.S. §2706 ❑ ❑ (relating to terroristic threats) n 18 Pa.C.S. §2709.1 ( I ❑ (relating to stalking) ❑ 18 Pa.C.S. §2901 ❑ ❑ . (relating to kidnapping) ❑ 18 Pa.C.S. §2902 ❑ ❑ (relating to unlawful restraint) ❑ 18 Pa.C.S. §2903 I I ❑ (relating to false imprisonment) ❑ 18 Pa.C.S. §2910 ❑ ❑ (relating to luring a child into a motor vehicle or structure) ❑ 18 Pa.C.S. §3121 U ❑ (relating to rape) (� 18 Pa.C.S. §3122.1 ❑ ❑ (relating to statutory sexual assault) ❑ 18 Pa.C.S. §3123 ❑ ❑ (relating to involuntary deviate sexual intercourse) (� 18 Pa.C.S. §3124.1 ❑ ❑ (relating to sexual assault) (� 18 Pa.C.S. §3125 I I ❑ (relating to aggravated indecent assault) ❑ 18 Pa.C.S. §3126 n ❑ (relating to indecent assault) ❑ 18 Pa.C.S. §3127 ❑ ❑ (relating to indecent exposure) ❑ 18 Pa.C.S. §3129 ❑ ❑ (relating to sexual intercourse with animal) ❑ 18 Pa.C.S. §3130 [ ❑ (relating to conduct relating to sex offenders) ❑ 18 Pa.C.S. §3301 ❑ ❑ (relating to arson and related offenses) ❑ 18 Pa.C.S. §4302 ❑ (i (relating to incest) ❑ 18 Pa.C.S. §4303 ❑ ❑ (relating to concealing death of child) ❑ 18 Pa.C.S. §4304 ❑ ❑ . (relating to endangering welfare of children) ❑ 18 Pa.C.S. §4305 I I ❑ (relating to dealing in infant children) 18 Pa.C.S. §5902(b) ❑ ❑ (relating to prostitution and related offenses) I 18 Pa.C.S. §5903(c) or n ❑ (d) (relating to obscene and other sexual materials and performances) I I 18 Pa.C.S. §6301 _ ❑ (relating to corruption of minors) ❑ 18 Pa.C.S. §6312 ❑ ❑ (relating to sexual abuse of children) ❑ 18 Pa.C.S. §6318 ❑ (relating to unlawful contact with minor) n 18 Pa.C.S. §6320 ❑ ❑ (relating to sexual exploitation of children) Cl 18 Pa.C.S. §6114 ❑ ❑ (relating to contempt for violation of protection order or agreement) ❑ Driving under the ❑ ❑ influence of drugs or alcohol ❑ Manufacture, sale, ❑ ❑ delivery, holding, offering for sale or possession of any controlled substance or other drug or device 2. Unless indicated by my checking the box next to an item below, neither I nor any other member of my household have a history of violent or abusive conduct including the following: Check Self Other Date all household that member apply jv A finding of abuse by a Children & Youth f ❑ 2/o-7 Agency or similar agency in Pennsylvania or similar statute in another jurisdiction n Abusive conduct as defined under the ❑ ❑ Protection from Abuse Act in Pennsylvania or similar statute in another jurisdiction ❑ Other: ❑ ❑ 3. Please list any evaluation, counseling or other treatment received following conviction or finding of abuse: 4. If any conviction above applies to a household member, not a party, state that person's name, date of birth and relationship to the child: 5. If you are aware that the other party or members of the other party's household has or have a criminal/abuse history, please explain: I verify that the information above is true and correct to the best of my knowledge, information or belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. IJ Signature ()( ( rinted Name 3 KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-571 CIVIL ACTION - LAW HEIDI SHENCK N/K/A/ HEIDI SHOEMAKER, r 'l Defendant : IN CUSTODY t=j, r-- .; ct s AND NOW, this .31 day of /iiii ✓Z , 2014, upon --r consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: C^ ORDER OF COURT 1. The prior Order of Court dated December 12, 2013 shall remain in full force and effect with the following modifications and additions. 2. Mother hereby withdraws her Petition for Contempt. 3. Mother shall be responsible for reinstituting individual counseling for the child at the Stevens Center. Both parties may attend these counseling appointments and have the right to participate in the counseling if the counselor recommends it. The child shall attend until successfully discharged. 4. Father shall be responsible for reinstituting individual rape counseling for the child. Both parties may attend these counseling appointments and have the right to participate if the counselor recommends it. The child shall attend until successfully discharged. 5. The child shall continue to attend Dinosaur Counseling program through the YWCA which is from 10:00 -11:30 A.M. on Saturdays. Both parties shall make a diligent effort to ensure that the child shall attend, provided their family activity schedules permit. 6. Neither party may disparage the other party to third parties in writing or orally if it is possible the child may overhear the conversation or read such remarks. This includes, but is not limited, to school logs and emails, conversations with the police, teachers, school administrators and counselors. 7. The child's school backpack shall go back and forth to Mother's house on her weekends. Mother shall ensure that the backpack accompanies the child to school. In the event books are lost, whoever is responsible for the loss shall reimburse the school for the cost. 8. Medication shall accompany the child between parents in the proper prescription bottle. The parties shall follow the recommendations of the child's physicians regarding the administration of medication. 9. The child shall continue to see his ADHD doctor from the Sadler Clinic. Mother shall be responsible for making appointments. 10. Father is permitted to transfer the child's medical records to Loysville Family Practice. Mother shall be listed as an emergency contact at Loysville Family Practice and has the right to all information concerning the child's medical care including copies of treatment reports and billing. 11. Mother is entitled to six hours of makeup time (12:00 — 6:00 p.m.) for New Year's Day. This may be taken for Mother's family reunion which is usually held around Memorial Day. 12. The non - custodial parent shall have daily telephone contact with the child which shall occur before 7:30 p.m. A return call shall be made if the non - custodial parent leaves a message anytime before 7:30 p.m. 13. 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. ccabetha Tanner, Esquire, Counsel for Mother Allison C. Gossett, Esquire, Counsel for Father Qo-r ies /Yt,1-► J. KEITH GREENWALD, Plaintiff V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2007-571 CIVIL ACTION - LAW • HEIDI SHENCK N/K/A/ HEIDI SHOEMAKER, Defendant : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Bradley Scott Shenck March 14, 2006 Father 2. A Conciliation Conference was held in this matter on March 25, 2014, with the following in attendance: The Mother, Heidi Shenck N/K/A Heidi Shoemaker, with her counsel, Tabetha Tanner, Esquire and the Father, Keith Greenwald, with his counsel, Allison C. Gossett, Esquire 3. The Honorable Edward E. Guido previously entered an Order of Court dated December 12, 2013 providing for shared legal custody, Father having primary physical custody with Mother having alternating weekends Friday to Monday during the school year and every weekend, Friday to Monday during the summer. 4. Mother filed a Petition for Contempt and Modification. 5. The parties agreed to an Order in the form as attached. Date: 3-g ac eline M. Verney, Esquire Custody Conciliator TANNER BARCAVAGE 3507 Market Street, Suite 303 Camp Hill, PA 17011 Telephone: (717) 731-8114 Facsimile: (717) 731-8115 KEITH GREENWALD, Plaintiff v. HEIDI SHENCK n/k/a HEIDI SHOEMAKER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2007-571 CIVIL ACTION - CUSTODY PETITIONER'S SECOND PETITION FOR CONTEMPT/ MODIFICATION OF CUSTODY ORDER AND NOW, comes the Defendant, Heidi Shoemaker, by her attorney, Tabetha A. Tanner, Esquire, and avers the following in support of her Petition for Contempt of Custody Order: 1. Petitioner/Defendant, Heidi Shoemaker, hereinafter referred to as "Mother", is an adult individual currently residing at 501 Windy Hill Road, Lot 137, Shermans Dale, Perry County, Pennsylvania 17090. 2. Respondent/Plaintiff, Keith Greenwald, hereinafter referred to as "Father", is an individual currently residing at 110 Huckleberry Road, New Bloomfield, Perry County, Pennsylvania 17068. 3. The subject minor child is Bradley Scott Shenck, born March 14, 2006, age 8. 4. The child is presently residing with Father, Father's Wife, Father's son, Wife's three children, and Wife's oldest daughter's boyfriend, Danny and baby, as well as Wife's youngest daughters's boyfriend, Mike. 1 5. A Custody Order was entered on December 12, 2013, granting shared legal custody to the parties, and primary physical custody to Respondent (Exhibit "A"). 6. An Order of Court was entered on March 31, 2014 which modified certain provisions of the December 12, 2013 Order of Court, but which kept the non -modified provisions in tact. (Exhibit "B") 7. Paragraph 8 of the December 12, 2013 Order states "Neither party shall do or say anything nor permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent." 8. In violation of this provision, Father continuously tells the child that Mother is doing drugs and other similar unfounded statements in order to alienate the child from Mother. 9. On or about February 14, 2014, Mother filed a Petition for Contempt for Father's continued violations of this provision, including Father writing back and forth to the child's teacher, in the child's homework log book, expressing disparaging remarks about Mother to the child. The child reads and regularly reviews the homework log book in which these disparaging and inappropriate conversations take place. 10. In paragraph 6 of the March 31, 2014 Order, the Court attempted to address this issue by mandating "Neither party may disparage the other to third parties in writing or orally if it is possible the child may overhear the conversation or read such remarks. This includes, but is not limited to, school logs and emails, conversations with police, teachers, school administrators and counselors." s 11. Despite this very clear directive, Father continues to disparage Mother in the child's homework log book when communicating with the child's teacher. As an example, on September 17, 2014, Father wrote in the child's homework log book "Bradley has been through a lot and this is just more to add to his worries. Hopefully things go well tomorrow 9-24-14 and he doesn't have to worry about his mom anymore...." (Exhibit "C") 12. On or about September 19, 2014, Father again wrote to the teacher in the child's homework log book "That's fine I know he's worried but at the same time loves her I feel so bad for him." (Exhibit "C") 13. Furthermore, Father reads the unhealthy correspondence between the parties to the minor child. This causes the child great concern and confusion and further disparages the child's image of Mother as Father selects which email passages he inappropriately reads to the child. 14. Paragraph 7 of the March 31, 2014 Order of Court states that "The child's school backpack shall go back and forth to Mother's house on her weekends..." 15. In violation of the Order, Father refuses to send the backpack and all of the contents of the backpack with the child when he goes to Mother's house. 16. In an email on October 8, 2014, Father states in defiance of the Order, "I will copy his assignment book at the end of every week and any homework he might have the Friday he comes with you and that's what I will be sending to you on your weekends and I will be taking his backpack to school Monday morning and requesting you do not touch it. I will be letting the principal and Secretary know that there will be no need to give you copies of nothing because you will already have what you need." (Exhibit "D") 17. Furthermore, in making the copies that Father does send to Mother, Father strategically crosses writings out so that Mother does not know what is written in the original copy that goes back and forth to the teacher. 18. The holiday schedule as described in Exhibit "A" of the order of December 12, 2013 states that Mother was to have the child on New Years Day from 9AM until 3PM. Despite this clear language, Father kept the child on New Years Day from 9AM until 9PM. Mother did not see the child on New Years Day. 19. Paragraph 11 of the March 31, 2014 Order of Court states "Mother is entitled to six hours of makeup time (12:00 - 6:00 p.m.) for New Year's Day. This may be taken for Mother's family reunion which is usually held around Memorial Day." 20. Paragraph 11 was a result of Father's violation of the holiday schedule as outlined in the order of December 12, 2013 and a result of the first Petition for Contempt filed by Mother. 21. Despite this very clear language, Mother did not get the child as Ordered on Memorial Day. Instead, Father kept the child for the entire Memorial Day weekend. 22. The holiday schedule as described in Exhibit "A" of the Order of December 12, 2013 states that Father is to have the child until 4:00PM on the First Day of Fishing Season. Despite this very clear language, Father kept the child until 6PM on the First Day of Fishing Season. 23. For Easter 2014, Mother was supposed to have the child from 3PM until 9PM. Easter was on April 20, 2014. Despite this very clear language in the custody Order, Father kept the child for the entire day, explaining this violation by stating that it was "his birthday" and therefore it was somehow permissible to violate the terms of the Order and to deny Mother this holiday time with the child. Father's date of birth is March 31. The child's date of birth is March 14. So it is unclear as to why Father believed that either birthday was on Easter Sunday, April 20, 2014. 24. For Independence Day 2014, Mother was supposed to have the child from 9AM until 9PM. Despite this very clear language in Exhibit "A" of the December 12, 2013 Order of Court, Father kept the child on Independence Day in violation of the Order of Court. 25. Paragraph 3(A) of the December 12, 2013 Order states that "when school is not in session [Mother shall have partial periods of physical custody] every weekend ...." Paragraph 3(B) of the December 12, 2013 Order states that, "when school is in session [Mother shall have partial periods of physical custody] every other weekend ..." Father unilaterally decided that "school is in session" two weeks prior to the commencement of the actual academic year, thereby denying Mother two weekends of summer custodial time. 26. On or about September 8, 2014, Father filed a merit less PFA against Mother. A hearing was held on the PFA on September 24, 2014. The PFA was dismissed on Wednesday, September 24, 2014. 27. Pursuant to the alternating weekend schedule that the parties had with the child prior to Father filing the merit less PFA, the weekend of Friday, September 27, 2014 should have been Mother's weekend with the child. 28. Had Mother had her normally scheduled weekend, Mother also would have had the child on the weekend of October 10, 2014, which would have included Columbus Day, October 13, 2014 when the child did not have school. 29. In an effort to further prevent Mother from having any holiday or additional time with the child, Father kept the child for the weekend of September 27, 2014 and therefore changed the alternating schedule and kept the child for the Columbus Day holiday as well. 30. When Mother confronted Father with regard to the Columbus Day holiday, Father's response was (after the PFA was dismissed) was "Just to verify I'm not trying to keep you apart I'm trying to keep him safe. (Exhibit "E") 31. It should be noted that despite the fact that Father calls in allegations to ChildLine on a very, very regular basis, bordering on harassment, none of Father's allegations have ever been founded against Mother. It should also be noted, however, that Father's wife is an indicated child abuser with regard to the minor child of this action due to severe head injuries sustained by the child in Father's wife's care (Exhibit "F") 32. For Trick or Treat Night 2014, Mother's Trick or Treat night was on October 30. Father's Trick or Treat Night was on October 31. Pursuant to Exhibit "A" of the December 12, 2013 Order of Court, "each parent will have physical custody on their respective night." Despite this, however, Father kept the child on both October 30 and October 31, thereby denying Mother the opportunity to spend Trick or Treat night with the child. 33. Pursuant to paragraph 1 of the December 12, 2013 Order of Court, the parties have joint legal custody of the child. Specifically, "... each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious, or school records ... To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher, or authority and copies of any reports given to thein as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children' s parties, musical presentations, back-to-school nights, and the like." 34. In violation of this provision, on or about October 18, 2014, Father took the child to the emergency room, alleging that Mother had given the child some "orange pills" which Father alleged to have been Adderral, despite Mother's assurances that she had not given him any "orange pills" nor any pills at all. 35. Mother has repeatedly asked for the name of the hospital to which Father took the child and for a copy of the medical reports from this visit. 36. After repeated requests, Father stated in an email on October 29, 2014 "Yes and on ur visitation time you will be given a copy of the report." (Exhibit "G") 37. Father failed to provide a copy of the report at the next custodial exchange. 38. In an email on October 29, 2014, Father stated that he took the child to Carlisle Hospital, but failed to provide any additional information. 39. As of the signing of this Petition for Contempt, Father has still not provided copies of the medical report to Mother. 40. Father regularly refuses to provide Mother with school papers or school information, including information about parent teacher conferences, school picture information, unedited homework logs, the child's actual homework, spelling words, etc. Father selects what pages, if any, of the child's assignment book he chooses to provide to Mother. 41. Mother has obtained a copy of the assignment book recently by going to the school and having the child obtain the book from his classroom and bring it to the office to be photocopied. 42. Father has spoken so negatively about Mother to the school personnel that the school principal, who has had very little contact with Mother until recently, accused Mother of abusing Bradley. The only way for the school to have this untrue and unfounded belief is from Father's dishonest communications with the school. 43. After obtaining a copy of the homework log from the school, Mother became aware of the conference forms and has since obtained them from the school. 44. On October 30, 2014, a note was written from the child's teacher, "2 conference papers sent home. One for Keith. One for Heidi in yellow folder."(Exhibit "H") 45. As of the signing of this Petition, Father has yet to provide Mother with her copy of the conference forms. 46. Neither the Father nor the school has provided Mother with the child's "First In Math" logon and password. "First in Math" is an online math program that the children can use to hone their math skills at home. Mother would like the opportunity to participate in this activity with the child but has no way to access the program. 47. In mid October 2014, Mother learned from the child that he was hit at school. Mother asked Father why he did not tell her that their son was hit at school and why he crossed out information in the log book that he copied and sent to her. 48. Father responded in an email on October 20, 2014, "Bradley's not getting hit at school I even asked the teacher and she said she asked him several times if he got hit and he said no. Nothing was scratched out on ur copy it was a mistake in the book so I scribbled it out." (Exhibit "I") 49. When Mother obtained a copy of the log book from the school however, on October 16, 2014, Father wrote in the child's log book to the child's teacher, "I will be calling you to discuss the situation with getting hit because he did tell me he got hit and told me again when I questioned him about your letter. I call you or you can call me (717) 275-4530)." (Exhibit "J") 50. Father, continues to violate the Order by failing to provide Mother with any information at all that is sent home with the child, including school pictures, school projects, events, and so forth. 51. Father is deliberately trying to prevent Mother's access to information and involvement in the child's school, activities and educational pursuits. 52. Paragraph 3 of the March 31, 2014 Order states "Mother shall be responsible for reinstating individual counseling for the child at the Stevens Center... The child shall attend until successfully discharged." In order for Mother to reinstate the counseling, the Stevens Center requires both parties to execute consent and intake forms. Father refuses to sign the consent and intake paperwork unless Mother signs paperwork permitting the child to engage in services at Laurel Life. 53. Father is thwarting Mother's efforts to reinstate counseling at the Stevens Center to the detriment of the parties' minor child. 54. , Paragraph 4 of the March 31, 2014 Order states, "Father shall be responsible for reinstating individual rape counseling for the child ... The child shall attend until successfully discharged." Father desires to engage the child in individual rape counseling with Laurel Life. Mother has had multiple conversations with the director of Laurel Life (717) 582-9922, who states repeatedly that Laurel Life does not offer sexual assault counseling services and that the Y provides that service. 55. Mother has repeatedly asked Father to engage the child with the Y since they do offer rape counseling and that is where the child has received these services in the past. Father refuses. 56. Father's attempts to engage the child with Laurel Life, who does not offer rape counseling services, is Father's attempt to further thwart Mother's efforts to re-engage the child with the Stevens Center where he has previously had services and where the child was 45. As of the signing of this Petition, Father has yet to provide Mother with her copy of the conference forms. 46. Neither the Father nor the school has provided Mother with the child's "First In Math" logon and password. "First in Math" is an online math program that the children can use to hone their math skills at home. Mother would like the opportunity to participate in this activity with the child but has no way to access the program. 47. In mid October 2014, Mother learned from the child that he was hit at school. Mother asked Father why he did not tell her that their son was hit at school and why he crossed out information in the log book that he copied and sent to her. 48. Father responded in an email on October 20, 2014, "Bradley's not getting hit at school I even asked the teacher and she said she asked him several times if he got hit and he said no. Nothing was scratched out on ur copy it was a mistake in the book so I scribbled it out." (Exhibit "I") 49. When Mother obtained a copy of the log book from the school however, on October 16, 2014, Father wrote in the child's log book to the child's teacher, "I will be calling you to discuss the situation with getting hit because he did tell me he got hit and told me again when I questioned him about your letter. I call you or you can call me (717) 275-4530)." (Exhibit "J") 50. Father, continues to violate the Order by failing to provide Mother with any information at all that is sent home with the child, including school pictures, school projects, events, and so forth. that the child should be seen by his pediatrician. Despite this advise, Father refused to take the child to the pediatrician or other medical care provider. 65. When the child arrived in Mother's care the next weekend, Mother noticed the green, oozing, infected spider bite. Mother took the child to Holy Spirit Hospital for care, after a week of further infection without any treatment while in Father's care, despite the urging by the school nurse that Father obtain medical treatment. 66. The doctor at Holy Spirit treated the wound and asked Mother to keep the child out of school on November 3, 2014 in order to further watch and treat the wound. (Exhibit "L) 67. Father's failure to obtain medical treatment for the child for over a week constituted medical neglect of the child. 68. The best interest and permanent welfare of the child will be served by granting the relief requested herein. WHEREFORE, Petitioner respectfully requests that Court order the following: 1. Respondent be found in contempt of Court for violating the December 2013 Order and March 31, 2014 Order; 2. Provide Mother with primary physical custody of the parties' minor child; 3. Order Respondent to immediately cooperate in executing the consent and intake forms for the Stevens Center; 4. Order Respondent to immediately re-engage the child with the services provided by the YWCA; 5. Order Respondent to immediately cease telling the child that Mother is using drugs or in any other way speak about Mother to or around the child in a derogatory manner and prohibit Father from reading correspondence between the parties to the child, or permitting the child to read or in any other way review the correspondence between the parties; 6. Order Respondent to call Petitioner by 7PM while the child is in Father's care; and to have his telephone on, with adequate battery power and to answer any call made by Mother after 7PM and before 7:30PM.; 7. Provide Mother with the entire New Year's Day, Easter, Memorial Day weekend, Columbus Day weekend, Independence Day and Labor Day holiday and Trick or Treat night (as make up time for the First Day of Fishing Season as well as the extra time that was supposed to be made up on New Year's Day but was not) in 2015 as make up time for the holiday time taken by Father in violation of the Order in 2014; 8. Provide Mother with two additional weekends to make up for the two summer weekends that Father took by unilaterally determining that the school year started 2 weeks before the commencement of school. 9. Order Father to provide the entire backpack and all of its contents, and all paperwork from school to Mother and order that if this is not done, sanctions will be immediately ordered against Father. 10. Order Father to immediately provide Mother with the First in Math logon and password information; 11. Order Father to immediately provide Mother with copies of the medical records from Carlisle Hospital; and 12. Respondent be ordered to pay Petitioner's attorney's fees and costs in filing and litigating this contempt action. Respectfully submitted, �•ewr A. 11,froti Tabetha Tanner, Esquire Supreme Court I.D. No.: 91979 Attorney for Petitioner VERIFICATION I verify that the statements made in this Petitioner's Second Petition for Contempt/Modification of Custody Order are true and correct. I understand that false statements made herein may subject me to penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: 3:6-ehiNaeA Heidi Ann Shoemaker, Petitioner KEITH GREENWALD, Plaintiff • • IN THE COURT OF COMMON PLEA OF'.:; • • CUMBERLAND COUNTY, PENNSYh3T.�NIE; ri v. •• NO. 2007-571 CIVIL TERM -7 —.t ov_HEIDI SHENCK N/K/A r-,:: HEIDI SHOEMAKER, CIVIL ACTION - LAW ; Defendant IN CUSTODY ORDER OF COURT AND NOW, this 12th day of December, 2013, after hearing, it is ordered and directed as follows: 1. The Father, Keith Greenwald, and the Mother, Heidi Shoemaker, shall have shared legal custody of Bradley Shenck, born March 14, 2006. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non -emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding his health, education, and religion. Pursuant to the terms of 23 Pa. C.S. Section 5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious, or school records, the residence address of the child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher, or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth Exhibit "A" .• '-o•rtg-k 5.')4t Wg",4-1' Vq,"4"7 ' WF•164 51.$41,43iti certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back -to -school nights, and the like. 2. Father shall have primary physical custody of the child. 3. Mother shall have partial physical custody as follows: A. When school is not in session, every weekend from Friday at 4:00 p.m. until Monday at 4:00 p.m. B. When school is in session, every other weekend from Friday at 6:00 p.m. until Monday at the beginning of school. If the child has off school on Monday, then the visitation shall extend until Tuesday at the beginning of school. It shall be Mother's responsibility to see that the child gets to school or to return the child the evening before so that Father can get him to school. C. Such other times as the parties agree. 4. The child is never to be alone with Kandace Lower while in Mother's custody. 5. Physical custody on holidays, which shall take precedence over the regular schedule, shall be as designated on the schedule attached as Exhibit A. 6. Transportation shall be shared, with all custody exchanges to be at the Silver Spring Township Police Department except for the switch in 3-B. 7. No party shall be permitted to relocate the residence of the child which significantly impairs the ability to exercise custody unless every individual who has custodial rights to the child consents to the proposed relocation. A person proposing to relocate must comply with 23 Pa. C.S. Section 5337. 8. Neither party shall do or say anything nor permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. 9. The custodial parent shall ensure that the child talks with the non-custodial parent by telephone on a daily basis. 10. Each party shall keep the other informed of his or her address at all times. 11, Father shall ensure that the child continues in his counseling until successfully discharged. Father shall also ensure that the child keeps his evaluation for ADD at the Sadler Clinic scheduled for later this month. In that regard, Mother is directed to provide the Father with the time of said evaluation. By the Court, Edward E. Guido, J. Allison C. Gossett, Esquire For the Plaintiff Jane Adams, Esquire For the Defendant Sheriff srs -3egr_s /17,151:c1.) J//3/i2 =n1 HOLIDAYS AND SPECIAL DAYS TIMES .s ODD YEARS EVEN ; YEARS Easter Day 1st half From 9:00 a.m.to 3:00 p.m. Father Father Easter Day 2"d half From 3:00 p.m. to 9:00 p.m. Mother Mother Memorial Day From 9:00 a.m. to 9:00 p.m. Mother Father Independence Day From 9:00 a.m. to 9:00 p.m. Father Mother Labor Day From 9:00 a.m. to 9:00 p.m. Mother Father Thanksgiving 1" half From 9:00 a.m. to 3:00 p.m. . Father Father Thanksgiving 2"d half From 3:00 p.m.'to 9:00 p.m. Mother Mother Christmas 1" half From 12:00 noon on 12/24 to 12:00 noon on 12125 Father Mother Christrnas 2"d half From 12:00 noon on 12/25 to 12:00 noon on 12/26 Mother Father Mother's Day From 9:00 a.m. to 9:00 p.m. Mother Mother Father's Day From 9:00 a.m. to 9:00 p.m. Father Father Good Friday From 9:00 asn..to 9:00 p.m. Father Father New Year's "Day 1' half From 9:00 a.m. to 3:00 p.m. Father Mother New Year's Day 2."d half From 3:00 p.m. to 9:00 p.m. Mother Father Mother's Birthday From 9:00 a.m. to 9:00 p.m. Mother Mother Father's Birthday From 9:00 a.m. to 9:00 p.m. Father Father First Day of Fishing Season From Friday before at 4:00 p.m. to Saturday at 4:00 p.m. Father Father Trick or Treat night From 5:00 p.m. to 9:00 p.m., if on the same night in both parent's municipality; if on different night, then each parent will have physical custody on their respective nights, Whoever has physical custody on the week on/week off schedule Alternate from prior year 3 KEITH GREENWALD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-571 CIVIL ACTION - LAV HEIDI SHENCK N/K/A/ �,. rD HEIDI SHOEMAKER, r' :r C Defendant : IN CUSTODY --<?'' r~ -R ORDER OF COURT - .-1>,..:: t --i AND NOW, this .3/f day of n%A/,Z.� , 2014, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated December 12, 2013 shall remain in full force and effect with the following modifications and additions. 2. Mother hereby withdraws her Petition for Contempt. 3. Mother shall be responsible for reinstituting individual counseling for the child at the Stevens Center. Both parties may attend these counseling appointments and have the right to participate in the counseling if the counselor recommends it. The child shall attend until successfully discharged. 4. Father shall be responsible for reinstituting individual rape counseling for the child. Both parties may attend these counseling appointments and have the right to participate if the counselor recommends it. The child shall attend until successfully discharged. 5. The child shall continue to attend Dinosaur Counseling program through the YWCA which is from 10:00 -11:30 A.M. on Saturdays. Both parties shall make a diligent effort to ensure that the child shall attend, provided their family activity schedules permit. 6. Neither party may disparage the other party to third parties in writing or orally if it is possible the child may overhear the conversation or read such remarks. This includes, but is not limited, to school logs and emails, conversations with the police, teachers, school administrators and counselors. 7. The child's school backpack shall go back and forth to Mother's house on her weekends. Mother shall ensure that the backpack accompanies the child to school. In the event books are lost, whoever is responsible for the loss shall reimburse the school for the' cost. - Exhibit "B" 8. Medication shall accompany the child between parents in the proper prescription bottle. The parties shall follow the recommendations of the child's physicians regarding the administration of medication. 9. The child shall continue to see his ADHD doctor from the Sadler Clinic. Mother shall be responsible for making appointments. 10. Father is permitted to transfer the child's medical records to Loysville Family Practice. Mother shall be listed as an emergency contact at Loysville Family Practice and has the right to all information concerning the child's medical care including copies of treatment reports and billing. 11. Mother is entitled to six hours of makeup time (12:00 — 6:00 p.m.) for New Year's Day. This may be taken for Mother's family reunion which is usually held around Memorial Day. 12. The non-custodial parent shall have daily telephone contact with the child which shall occur before 7:30 p.m. A return call shall be made if the non-custodial parent leaves a message anytime before 7:30 p.m. 13. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. cc: Tabetha Tanner, Esquire, Counsel for Mother Allison C. Gossett, Esquire, Counsel for Father J. NUE COPY FROM RECORD Fstimony whereof, I here unto set my hand c,nd the sey of said rt ete% rftslPa. This ,_ day of l.��20 Letter of the week: 0004 ,€11 Gabby's goat is to learn how to swim. Draw or write C about one of your pools. 4,40 4 15 fly rm ' MONDAY -*School Talk A sp a for you to read and write notes to and,, rom your child's teacher. :16C-51 SIGNATURE- ._ ,.._.....i!� . c f (,.,V e .. .. _ .. TUESDAY 3?,,'r(..vt let, rm . I-ke. i'LGb 16 lotc4A of p - "1 Ct- 16� C �� ', 1.5 Rem o IJ VU LeA Pt(Ciix lei VW.. UV) if -ire (. SIGNATURE J (.1 '- jb't,r. %y -Ne -;N. p WEDNESDAY I,A by i cES n , G 0 cede 17 _7,,.S i ` S Tusk rhos-.. /t adel tc A•3. �1'A •�4.�6-r-4, , - I/ -/ y l.d ii i' "eel.1 / of e_cl 6e0 rte-rl clean lie s1_e {v (.i4) 'cry Gb4ti4.L /t :J IA e" 4.'!15/A+C.." .,.y... SIGNATURE f yL ax., l%l C^'S.) I SRA. ahe, AS- fel/ 4.7. 44 61 c. , ei, .6/pa/ // yt)La, WC j UI_ J.z . „pi." el ;s GI 4 eed-z - 41`4,,:�_r ev C lY;. ") C h '� c6 (14/m ; , S' he r S 4.644 6 _.. SIGNATURE FRIDAY 19 grcck liN tvtc SOtielP1 he m►ssccl.)tnr6 • tie.t•1a tyke_ hp vt4� diel Co Mk( re i i si C� C h bT 3G N�- n W Cxri h �, Th en b 4+e -rt i° re c1 hP wa;, worned tc- CoVJ/"t yLGCGpyt,9E E Mu�e� Y1.k� I(" vcr , bu--� ► 10/1014? • re . ticc'-S e r`1181h 'o It ake to reach Lt,ih.c�+ (,L' i l ( h r' r friar gaols tats- n" of a vowet s Check REVIEW E REFLECT 1frY THURSDAY 18 My week: Exhibit "C" pt_nn_ng h_rd w_rk _. tf_rt ;aowa'N omp.ioy'euluuoids�amsuy n 29 SC) kt K !i3—h a• Tabetha Tanner, Esq From: Heidi <heidishenck@rocketmailcom> Sent: Saturday, October 25, 2014 3:50 AM To: Tabetha Tanner Subject: Fwd: Contempt of court again keeping Bradley's bookbag, assignment book, school work, etc. Sent from my iPad Begin forwarded message: From: Keith Greenwald jr <keithgreenwaldjr(a yahoo.com> Date: October 8, 2014 at 6:46:18 AM EDT To: heidishenck@rocketmail.com Subject: Re: Contempt of court again keeping Bradley's bookbag, assignment book, school work, etc. Heidi You're the one lying as usual. There was a DVD in his bookbag when I handed it to the principal before I even entered the building. I explained the situation to her and she said she would make sure it got taken care of.Also there is more than one folder in Bradley's backpack and if you really would know that is his reading folder only and the yellow folder is his homework, school work,exc...folder. So if the movie wasn't returned or wasn't in his backpack then you did something with it because I know it was in there. Then you wonder why I have a problem sending these things to your home because things come up missing and Bradley suffers because of your ignorance.`.I will copy his assignment book at the end of every week and any homework he might have the Friday he comes with you and that's what I will be sending to you on your weekends and I will be taking his backpack to school Monday morning and requesting you do not touch it..1 will be letting the principal and the Secretary know that there will be no need to give you copies of nothing because you will already have what you need. I will also be contacting the school to reassure that the movie was in fact takin care of and it better have been in that backpack or your the one that will be paying for it because I seen it in there with my own eye's Monday morning when I took his book bag to school and handed it to the principal asking her to make sure it got taken care of. Now why would I ask her to do that if the DVD wasn't in there? That makes no sence. Sincerely Keith On Tue, Oct 7, 2014 6:30 PM PDT Heidi wrote: Keith, Exhibit "D" Tabetha Tanner, Esq From: Heidi <heidishenck@rocketmail.com> Sent: Saturday, October 25, 2014 3:48 AM To: Tabetha Tanner Subject: Fwd: Stollen time! Sent from my iPad Begin forwarded message: From: Keith Greenwald jr <keithgreenwaldjr@vahoo.com> Date: October 14, 2014 at 10:49:18 PM EDT To: heidishenck@rocketmail.com Subject: Re: Stollen time! Heidi Drugs in his system from ur home from u and ur husband remember Heidi I as well as Bradley at the same time while he was in my custody not around you gave a negative drug test. But after a weekend with you gave a positive drug test. Yet you did not give a drug test. And I'm sorry but 1 still believe Bradley when he tells me you and ur husband beet him with a board then covered the bruises with cover up. And sorry I'm trying to teach our son not to lie unlike you making him lie and if he doesn't then you say you're gonna beet him. On Tue, Oct 14, 2014 2:26 PM PDT Heidi wrote: Just to be clear your a liar and your trying to make Bradley one! Then stop lying and stop keeping us apart. Bradley only ever got hurt in your care remember that and now that you have custody he had drUgs in his system. Sent from my iPad On Oct 14, 2014, at 5:09 PM, Keith Greenwald jr <keithgreenwaldjr@yahoo.com> wrote: Heidi Just to verify I'm not trying to keep u apart I'm trying to keep him safe. Exhibit "E" Cumberland County Children and Youth Services ATTACHMENT FOR CL#21-07139 Section I.F.: Perpetrator: Keith Greenwald Sex: M Relationship to Child: Father SS#: 184-62-4623. Address: 265 Lincoln Street, Carlisle, PA 17013 County: Cumberland DOB: 3/31/82 Perpetrator: Christiane Swartz Sex: F Relationship to Child: Father's paramour/Household member SS#: 168-58-8274 Address: 1924 Douglas Drive, Carlisle, PA 17013 County: Cumberland DOB: 6/16/74 Exhibit "F" (CHILD PROTE E SERVICE LAW - TITLE 23 PA 911 CHAPTER 63) PLEASE REFER TO INSTRONS ON REVERSE SIDE. EXCEPT FOR SIURE, PLEASE PRINT OR TYPE •1. NAME OF CHILD (Lest, First, In Hie!) e..:, /I 0,0,—t_�rL l �%(Gt ( '" ' � � ,. �+H �C:4�NQ.* � •��-- xy, c,..:. + `^ ._ I .^ �iTHDATE j lr_ Z i EX P� I...M IF.._ .tr .d ADDRESS (Street, City,) State & Zip Code) COUNTY 1A. PRESENT LOCATION IF DIFFERENT THAN ABOVE �i " ` ', .. � �x tee. �j�` f: 9y¢ ��•%,M! zg� k T +�� J� .y- .p P YRv'''+rsK re r Z, , k 5e/. � e: ' 'i tr COUNTY 2. BIOLOGICAL/ADOPTIVE MOTHER (Last, First, Initial) • Seen r'NpT ,,,, BIRTHDATE TELEPHONE NO. ADDRESS (Street, City, State & Zip Code) • COUNTY 3. BIOLOGICAL/ADOPTIVE FATHER (Last, First, Initial) SOC. SEC. NO. BIRTHDATE TELEPHONE NO. ADDRESS (Street, City, State & Zip Code) COUNTY 4. OTHER PERSON RESPONSIBLE FOR CHILD SOC. SEC. NO. BIRTHDATE RELATIONSHIP TO CHILD SEX I IM H ADDRESS (Street, City, State & Zip Code) COUNTY TELEPHONE NO. ,S. ALLEGED PERPETRATOR (Last, First, Initial) SOC. SEC. NO. BIRTHDATE RELATIONSHIP TO CHILD SEX 1M L ADDRESS (Street, City, State & Zip Code) COUNTY TELEPHONE NO. 6. FAMILY HOUSEHOLD COMPOSITION (Excluding Above Names) NAME (Last, First, Initial) RELATIONSHIP TO CHILD NAME (Last, First, Initial) RELATIONSHIP TO CHILD A. . D. B. E. _.. C. F. DESCRIBE INJURIES/CONDITION AND WHY YOU SUSPECT ABUSE/NEGLECT. INCLUDE EVIDENCE OF PRIOR ABUSE TO THIS CHILD,. SIBLING OR PERPETRATOR. (PLEASE REFER TO OPPOSITE SIDE FOR ADDITIONAL INFnRMATIONI_ PLEASE NOTE EXACT LOCATION OF THE INJURY(S) ON MODEL COUNTY WHERE ABUSE OCCURRED DATE OF INCIDENT BELOW. �, 1 V oZ'' �VQc�i'�l -I• �.�J �-- '> % ir•Sz • • • i C. C./14 -J.). c+,f)-11" i` Cry . (..P ,.:... off* C ^. t ( vki { C avvS 1 5 C .. ' r(' e`Q-12e (9 Cl/ f b `2).( 5Li e Z5r 1-- CLr)C S('„ ti 01814A 7, ACTIONS TAKEN OR ABOUT TO BE TAKEN PORTER, COUNTY AGENCY, LAW ENFORCEMENT, 01. OFFICIAL, OR OTHERS. NUTII-ICA- PHOTO- — HOSPITAL- — POLICE — MtUIL:P.11111110r TION OF Y, -RAYS GRAPHS _ I ZAT I ON - NOTIFIED .EXAM IN- CORONER — AT ION KIVIhtiGENCY 1 CUSTODY TAKEN 1 UTHER ISPaully/ii.,1 . RISK FACTORS, CHILD: A. DESCRIBE ANY PHYSICAL MENTAL OR BEHAVIORAL FACTORS THAT MAY PLACE THE CH LD AT RISK: I I UNKNOWN - ._....... B, DOES THE CHILD APPEAR TO NEED IMMEDIATE MEDICAL ATTENTION? NO[1 UNKNOWN YES IF YES, PLEASE EXPLAIN: _........_ ...... . C. LEVEL OF PAIN CHILD EXHIBITS PLEASE DESCRIBE: MILD MODERATE ID SEVERE D. DOES THE CHILD APPEAR 10 BE FEARFUL, SUICIDAL OR WITHDRAWN? IF YES, PLEASE EXPLAIN: ENO UNKNOWN YES 8. RISK FACTORS, FAMILY: A. DESCRIBE ANY CAP.STAKER/PEFIPET ATOR CHARACTERISTICS THAT PLACE THE CHILD AT RISK: 1 unnosmvviv B. DESCRI8E THE EXTENT OF E ETRATOR SI ACCESS TO CHILD: , . UNKNOWN ... C. IS TNERE ANY SUBSTANCE ABUSE IN THE HOUSEHOLD ri YES IF YES, PLEASE XPLAIN: fl NO E UNKNOWN D. DOES THE CARETAKER/PERPETRATOR HAVE A HISTORY OF VIOLENCE OR SEVERE EMOTIONAL PROBLEMS? IF YES, PLEASE EXPLAIN; 1 i 1 i NO UNKNOWN W K E. WHAT IS THE ENVIRONMENTAL (HEALTH AND SAFETY) CONDITION OF T E HOME? riU1,1, NO yvN F. WILL CHILD BE AT RI K DUE TO COUNTY AGENCY INVOLVEMENT? LilNO UNKNOWN YES IF YES, PLEASE EXPLAIN: G. ARD THERE WEAPONS IN THE HOME? 0 NO El UNKNOWN jj ns IF YES, PLEASE EXPLAIN: INSTRUCTIONS TO MANDATED PERSONS: Any persons who, in the course of their employment, occupation, or pracnce profession come into contact with children shall report or cause a report to be made to ChildLine (800-932-0313) when reasonable cause to suspect, on the basis of their medical, professional or other training and experience, that a child cotI them in their professional or of ficial capacity is a victim of child abuse. Within 48 hours after making the oral report, send on, of this report to the county children and youth agency. NOTE: If the child has been taken into custody, you Must also immediately contact the county children and youth agency .• abuse occurred. Except for confidential communications made to an ordained member of the clergy, the privileged cornmuni, between any professional person required to report and the patient or client of that person shall not apply to situations abuse arid shall not constitute grounds for failure to .report suspected abuse. CHILDLINE "',PORT OF SUSPECTED CHILD ABUSE 3 NEGLECT FOR CHILDLINE USE ONLY DATE OF ORAL REPORT PENDING COMPLAINT NUMBER 05/30/2007 21-0007139 COUNTY WHERE ABUSE OCCURRED CUMBERLAND INVESTIGATING COUNTY CPS WORKER CUMBERLAND KELLY MILLER GIVEN: TIME 23:06 DAY Wednesday PRIOR REPORTS? • YES (SEE ATTACHED) )4 NO ■ INSUFFICIENT INFO CHILDLINE WORKER KEARNEY RECEIVED: TIME 23:06 DAY Wednesctav r VA* E .''b.. asst, First, Initial) SHENCK BRADLEY SOCIAL SECURITY # DATE OF BIRTH 03/14/2006 AGE 1 YEARS 2 MONTHS 16 [iA' SEX E4 MALE • FEMALE ADDRESS (Street, City, State, and ZIP Code) 158 BEETEM HOLLOW RD, NEWVILLE, PA 17241 COUNTY CUMBERLAND 1A. PRESENT LOCATION IF DIFFERENT THAN ABOVE COUNTY 1 B. SCHOOL OR DAY CARE (NAME & ADDRESS) GRADE ■ REGULAR CLASS • SPECIAL (,:I 2. BIOLOGICAL / ADOPTIVE MOTHER (Last, First, Initial) SHENCK HEIDI SOCIAL SECURITY # DATE OF BIRTH AGE WORK TELEPHONE 1114## 4:11##- # HOME TELEPHONE i 717-486-6748-#4#F# ADDRESS (Street, City, State, & ZIP Code) 18 PARK ST, MT HOLLY, PA 17065 COUNTY CUMBERLAND 3. BIOLOGICAL / ADOPTIVE FATHER (Last, First, Initial) GREENAWALT KEITH SOCIAL SECURITY # DATE OF BIRTH AGE WORK TELEPHONE # 1#/#4#1#4##14#### HOME TELEPHONE it 000-000-0000-0000 ADDRESS (Street, City, State, & ZIP Code) 158.BEETEM HOLLOW RD, NEWVILLE, PA 17241 COUNTY CUMBERLAND 4. LEGAL GUARDIAN / AGENCY WITH CUSTODY SOCIAL SECURITY # DATE OF BIRTH AGE WORK TELEPHONE # HOME TELEPHONE_ // ADDRESS (Street, City, State, & ZIP Code) COUNTY SEX ■ MALE DEEM 5. PLACEMENT AGENCY ADDRESS (Street, City, State, & ZIP Code) COUNTY TELEPHONE # 6. ALLEGED PERPETRATOR (Last, First, Initial) UNKNOWN UNKNOWN SOCIAL SECURITY # RELATIONSHIP TO CHILD HOUSEHOLD MEMBER ADDRESS (Street, City, State, & ZIP Code) . UNKNOWN, UNKNOWN, DATE OF BIRTH AGE COUNTY SEX DMALE D FEMAI # HOME TELEPI IONI 11 ###t1 14111-####-(1# , WORK TELEPHONE 1114###-## 7. ALLEGED PERPETRATOR (Last, First, Initial) SOCIAL SECURITY # RELATIONSHIP TO CHILD ADDRESS (Street, City, State, & ZIP Code) DATE OF BIRTH AGE COUNTY WORK TELEPHO SEX DMALE ❑FLI,'UV I NE # HOME TEL FPI 1,.r.11 8. ALLEGED PERPETRATOR (Last, First, Initial) SOCIAL SECURITY # RELATIONSHIP TO CHILD ADDRESS (Street, City, State, & ZIP Code) DATE OF BIRTH AGE COUNTY WORK TELEPHO SEX DMALE UEEI'cihl1 NE # HOME TELEPI 1( i!I 9..ALLEGED PERPETRATOR (Last, First, Initial) SOCIAL SECURITY # RELATIONSHIP TO CHILD ADDRESS (Street, City, State, & ZIP Code) DATE OF BIRTH AGE COUNTY WORK TELEPHO SEX ['MALE 0F[:1Vii I1 NE # HOME TEI EPI I •N; J. 10. ALLEGED PERPETRATOR (Last, First, Initial) ADDRESS (Street, City, State, & ZIP Code) SOCIAL SECURITY # 1NI RELATIONSHIP TO CHILD SEX DMALE ❑F11\1,d E COUNTY WORK TELEPHONE # HOME TEL.:PI n 1,a i. 11. ALLEGED PERPETRATOR (Last, First, Initial) SOCIIdEALL SECURITY # JUNE RELATIONSHIP TO CHILD SEX SEX DMALE MALE ADDRESS (Street, City, State, & ZIP Code) D'A�1BIRTH AGE COUNTY WORK TELEPHONE HOME TELE 12. ALLEGED PERPETRATOR (Last, First, Initial)a t' L"SUTY # au RELATIONSHIP TO CHILD SEX El I ■ MALE ADDRESS (Street, City, State, & ZIP Code) ..��k 0 RTH AGE COUNTY WORK TELEPHONE # HOME TELE 13. ALLEGED PERPETRATOR (Last, First, Initial) SOCIAL SECURITY # RELATIONSHIP TO CHILD SEX DMALE ADDRESS (Street, City, State, & ZIP Code) i DATE OF BIRTH AGE COUNTY WORK TELEPHONE # HOME 1 PAGE 1 COMMONWEALTH OF PENNSYLVANIA - DEPARTMENT OF PUBLIC WELFARE L i;1u+l I -PI li )P:I I'I ii :Idl • 'I.PEI l v. :-'4*i:‘, I, , l‘Iil',1, , gek„..,,, :ciat*Ik-0,,6, evo ,1:',,N,a,t.L .- ..., -:', ''',,,',.,2,, ,7,;,,!,;•40;1. 1,s. -.10.4L-r., , - ,, , ,.•..-- — .,.'::. , " ' ' NAME (LAST, FIRST, INITIAL) C. DOES THE CHILD APPEAR TO BE FEARFUL SUICIDAL, OR WITHDRAWN? 0 NO [Z] UNKNOWN 0 YES (PLEASE EXPLAIN) DATE OF BIRTH or AGE A. DESCRIBE ANY CARETAKER / PERPETRATOR CHARACTERISTICS THAT PLACE THE CHILD AT RISK: RELATIONSHIP TO CHILD UNK FEMALE (FA'S HOME) D. DOES THE CARETAKER / PERPETRATOR HAVE A HISTORY OF VIOLENCE OR 0 NO ID UNKNOWN 0 YES (PLEASE EXPLAIN) SEVERE EMOTIONAL PROBLEMS? E. WHAT IS THE ENVIRONMENTAL CONDITION OF THE HOME? F. WILL THE CHILD BE AT RISK DUE TO CPS INVOLVEMENT? 0 NO Ej UNKNOWN 0 YES (PLEASE EXPLAIN) _ . ... PARAMOUR OF PARENT _..._.. . . 15. SPECIFIC ALLEGATIONS. DATE OF INCIDENT 05/30/2007- 05/30/2007 OTHER DATES - --- DESCRIBE WHAT HAPPENED TO CHILD. WHEN AND WHERE DID ALLEGED ABUSE / NEGLECT OCCUR? WHAT IS CHILD'S CURRENT CONDITION? FA TOOK CH TO ER REPORTING THAT THE CH WAS STANDING, FELL BACKWARDS AND HIT HEAD, ON PASTE TOY. CH HAS SKULLFRACTURE ANl-)-PPAIN7I! ,- THE CH WAS LIFE FLIGHTED TO HERSEY .MEDICAL CENTER. CH IS EXPECTED TO LIVE. CH IS IN PED. ICU - CYS WORKER DOES NOT KNOW AT THIS IllyiE IF 'Di+ IS CONSIDERED IN SERIOUS OR CRITICAL CONDITION. THERE ARE OTHER CHILDREN IN THE FATHER'S HOME THAT BELONG TO FA'S PARAMOUR - UNKL\IOW . NAMES AND AGES AT THIS TIME. A0 ,. ',1P4 ..;: ' '' '''''t: '''''''' ' , ..• . 't''' l'''''4;:likillAggl'atk ''''' .i. ,t' ..li ,..1.ZUW. '''."9 ' 11• ' ' ' '''1.# '' •:- `,.- 4 ' -:','.` *1", ' ,,,,,..,,,A:„4 \ ''''' ' ,,,A,61 -1, ,cvlil ' 4,- +,,:, , .-1N,5:;!; A DESCRIBE ANY PHYSICAL, MENTAL ORBEHAVIORAL FACTORS THAT MAY PLACE THE CHILD AT RISK: B. DOES THE CHILD APPEAR TO NEED IMMEDIATE MEDICAL ATTENTION? 0 NO 12) UNKNOWN 0 YES (PLEASE EXPLAIN) C. DOES THE CHILD APPEAR TO BE FEARFUL SUICIDAL, OR WITHDRAWN? 0 NO [Z] UNKNOWN 0 YES (PLEASE EXPLAIN) A. DESCRIBE ANY CARETAKER / PERPETRATOR CHARACTERISTICS THAT PLACE THE CHILD AT RISK: B. DESCRIBE THE EXTENT OF PERPETRATOR(SrACCESS TO CH1LD: C. IS THERE ANY SUBSTANCE ABUSE IN THE HOUSEHOLD? 0 NO El UNKNOWN 0 YES (PLEASE EXPLAIN) D. DOES THE CARETAKER / PERPETRATOR HAVE A HISTORY OF VIOLENCE OR 0 NO ID UNKNOWN 0 YES (PLEASE EXPLAIN) SEVERE EMOTIONAL PROBLEMS? E. WHAT IS THE ENVIRONMENTAL CONDITION OF THE HOME? F. WILL THE CHILD BE AT RISK DUE TO CPS INVOLVEMENT? 0 NO Ej UNKNOWN 0 YES (PLEASE EXPLAIN) PAGE 2 COMMONWEALTH OF PENNSYLVANIA - DEPARTMENT OF PUBLIC WELFARE Tabetha Tanner, Esq From: Heidi <heidishenck@rocketmail.com> Sent: Wednesday, October 29, 2014 1:30 AM To: Tabetha Tanner Subject: Fwd: yelling at Bradley calling him a liar Sent from my iPad Begin forwarded message: From: Keith Greenwald jr <keithgreenwaldjr@yahoo.com> Date: October 29, 2014 at 12:36:38 AM EDT To: beidishenck@rocketmail.com rocketmail.com Subject: Re: yelling at Bradley calling him a liar ES7---esand_on ur_visitatio _time you will be -given a�opy ofthe-reportf ell I never said any name before of any medication to you but you just said adderal so I assumed that's what it was and infact if it is adderal the maximum dosage at the extended release will only last for24-48 hours tops. And if you gave it to him on church day which is Sunday it would infact be out of his system -ley Monday night. But there was nothing said about Bradley not being fed I'm concerned because Bradley told me,the nurses, and the Dr after getting poked with a needle three times because he was so dehydrated as well as the they had to give him iv fluids that he had nothing to drink at all that day! I reported nothing to no one Bradley spoke not me to the nurses and Dr.Also I didn't have Bradley take drug test the Dr ordered them to see if we could find out what medication you gave him to make sure he'd be ok. And I never said u said ur a Dr??? On Tue, Oct 28, 2014 5:57 PM PDT Heidi wrote: Keith, No I never said I gave him Adderal actually I told you I never gave Bradley any medication. I'm not stupid if it was ingested it would be in his system for at least 72 hours. What is the hospital and doctor you have taken Bradley to because I would like to speak with him myself to see if that was said because you reported it. When did I say I was a doctor you keep insinuating I'm saying things I have not said or done. I never gave Bradley medication any day this week. So tw"hereis the_copyof the toxico.logyscreening_report_an copies-of-the=hospita.l? AD-kT'ItTbeen_over a -week Sent from my iPad Exhibit "G" JTJECIE,SZIffMnila Letter of the week: M) cx%3Q Miguel knows what matters most. What matters most to you? Drow or write about It. MONDAY VI School Talk 27 SIGNATURE TUESDAY 28 SIGNATURE WEDNESDAY 29 SIGNATURE THURSDAY A space for you to read and write notes to and from your child's teacher. .ino, fj 30 '� 0,0k ereAr\Ce3 Pouf' \ruyi\t, SIGNATURE v at 5 r YeAdhe o' t FRIDAY 31 SIGNATURE q 1 0 1 s d �e�4 1V1 d Check REVIEW £ REFLECT My week: 0,0; Respecting friends. 0 0 0 Respecting teachers: 0 0 0 Being on time• 0 0 0 Being organized. 0 0 0 Studying: 0 0 0 Doing my homework. 0 0 0 Paying attention in class. 0 0 0 Working in class. 0 0 0 What matters the most at school? - trying hard - staying safe and heatthy being o good friend Iluolaodwl 110 0.10 Aayi uamsuy Exhibit "H" 41 Tabetha Tanner, Esq From: Sent: To: Subject: Sent from my iPad Heidi <heidishenck@rocketmail.com> Saturday, October 25, 2014 3:55 AM Tabetha Tanner Fwd: Contempt of court order again you did not send Bradley's proper school stuff as court ordered Begin forwarded message: From: Keith Greenwald jr <keithgreenwaldjr@yahoo.com> Date: October 20, 2014 at 12:40:32 AM EDT To: heidishenck@rocketmail.com Subject: Re: Contempt of court order again you did not send Bradley's proper school stuff as court ordered Heidi 1 know what it says and it's_not what_ur saying. I have the book and also copiesrBradley'snotJ ettin hit�athool-1asked-the-teacher-and�she__said she.askced-him. severaLtimes_ifl e 6-17 g- _sc-even Fiiit andfie said_rio. Nothing was-scratched_out-on ur_copy_t was_a.mistake iii the book`so� [sc`ribled i;t out The folder isn't just a copies folder it's papers from the school copies of his assignment book for the two weeks that you don't see him and homework that your claiming you didn't and I know for a fact that you got because I put it in there so now Bradley doesn't have his homework done for Monday because you just want to make it look like I didn't send it when in fact I did really your so selfish you're only hurting Bradley. And for your information Bradley didn't work on his work during school he did it during recess not missing none of his learning time. So stop the lying. It's ok I have the book and copies of what I sent you also so say what you want. oa-copy_of.. radle_y_'s=spelling words copied right=from_his.assignnnent_book,and...Bradley 3 t oesn't have -math facts He's-studyingsod-have sod -have -none to.�give.,2 On Sun, Oct 19, 2014 7:04 PM PDT Heidi wrote: Keith, This is to document, that once again you have made up your own rules, violated the court order again and once again are in contempt of the court order! You know full well by now, especially, because I keep sending you word for Exhibit "I" OCTOBER 3(- Think This week I will set a goal to: 2 0 1 4 be It i I i i 1 • • > Record WHAT'S IMPORTANT TODAY? moi~ Act AFTER-SCHOOL MONDAY) ■13 OCTOBER c a( ` Columbus Day (USA) d . C a(/yam , h Thanksgiving Day (CAN) / 14 OCTOBER TL rnU ert tLC 6 ,";1/-;741111 yah Lt . - 1,- L ra` � " !i), a _n717._.._h:)_s. plc :r_1i_-- d Sein4-e..1 c e • 15 OCTOBER C 0 16 LA OCTOBER ._.._C4r Q.;,.) ri-\\ .0,3 .,..,.k.q.__ ..cyJ u. _-_,...:ipAk. L.. _ Li/2,4a _ ea_l t Aco _you - FRIDAY ®i. Y 217-a7s ys.3 J 1 s 17 Ld nal- re %cit» r._ 2 _.._ e._ ..._r IhfrlrYriC��. yly0;0 • 34 ,, 19 Q Best Book: Exhibit "J" Tabetha Tanner, Esq From: Sent: To: Subject: Sent from my iPad Begin forwarded message: Heidi <heidishenck@rocketmail.com> Friday, October 31, 2014 2:02 AM Tabetha Tanner Fwd: Late phone call From: Keith Greenwald jr <keithgreenwaldjr(yahoo.com> Date: October 30, 2014 at 10:41:39 PM EDT To: heidishenck(u�rocketmail.com Subject: Re: Late phone call `'-Technically I- only haveto have him. call. you.oiiee.-I'rn_-not_goingto sit aroundrand have -Bradley c I1 -you untlouuanswer..ur_phone I -have -a -life and_it doesn't -revolve around you.JAlso when you call for Bradley u all ways get ur return phone call within the time frame court ordered. So no I'm not in contempt of the order period. On Thu, Oct 30, 2014 6:58 PM PDT Heidi wrote: Keith, Really what does it matter to you? I don't have to explain myself to you! Once again, you're harassing me and changing the subject! The subject was not tonight's phone call, which I was busy for anyways and was not around the phone tonight to answer or call back and yet you once again only had Bradley try to call me_ once, butCtlie subject was last.nights late/missed phone -call which -you -only h) ad Cl-iiit ca11_one_time_9_minutes_beforethe oalYback_cutoff_time7Regardless of whether I answered tonight, was not the subject of this email, but since you want to bring up tonight's phone call, like I said, you are still in contempt of the court order, as you did not make a reasonable effort to have Bradley try to call me, having him call one time, regardless of what time you have him call, is not making a reasonable effort to try to contact me as you are ordered to do such, by the main court order! It also, doesn't explainy when I have theoption by the7 �o�nciliation.diderrtto-TcalLbefore,you-have`Bradley scall me, you.i your wife,ever_arisvver. you 1 j33i ones,_nor_do--you=ever have-Bradley-callme-in-a-timely fashion -after- I've-calle _, so it eallyJ V. -ales -no sense forme to call -first, Because yOlineverariswer_and-choose.to--have.Wadley-call) Exhibit "K" JOHN R. DIETZ EMERGENCY CENTER HOLY SPIRIT HOSPITAL CAMP HILL, PA 17011 SHENCK , B LEY S N---gMERGENCY ROOM 717-972-4300 ER1 ED GROUP 03/14/2006 Work/School Excuse Form 669083 669083 11/02/14 49200405 Mr., was/was not seen by me on and may return to work/school on Please excuse from work/school from to Restriction: Physical Education: Medications during work/school hours: Remarks: No. 59 Rev, 1/08 ETURN TO WORK OR SCHOOL Exhibit "L" JOHN R. DIETZ EMERGENCY CENTER DISCHARGE INSTRUCTIONS/TRANSITION RECORD HOLY SPIRIT HOSPITAL ' . - (747) 972-4304 fhr examination and treatment you have received:in the Emergency Center have been rendered on an emergency basis only, and are not intended to be a substitute for or an effort to provide omplc'ic medical care. If you develop new problem's'or complications contact your physician or the Emergency Center. FOLLOW THE INSTRUCTIONS CHECKED BELOW.: WOUND CARE ( ) May gently wash over wound in 24 hours with soap and water or peroxide. ( ) Change dressing times daily. Redress with Bacitracin/Neosporin and sterile dressing or leave it open if advised. ( ) Keep wound clean, dry ( ) covered ( ) uncovered SPRAINS, STRAINS, BRUISES, FRACTURES ( ) Elevate the injured part for_days to reduce swelling. ( ) Apply ice packs intermittently for days 10 reduce swelling. ( ) Ace wrap for support for_days. ( ) Wear splint ( ) At all times until follow up. ( ) For activity as needed. ( ) Use sling for support. ( ) Use crutches: ( ) As needed, weight bearing as tolerated. ( ) At all times. NO WEIGHT BEARING NECK/BACK O Wear cervical collar for support for days. ( ) Rest, avoid bending, lifting, strenuous activity for_days. ( ) Apply moist heat for minutes times daily beginning in hours. ADDITIONAL INSTRUCTIONS ( ) Encourage fluid intake ( ) Clear liquid diet. Advance to regular diet as tolerated. ( ) Oft work/school from to ( ) Return to work on ( ) Light Duty until: Restrictions: ( ) No gym/sports until ( ) Follow instructions on Workmen's Compensation Form. ( ) Wear eye patch tor hours. () If nose bleed recurs, pinch nose firmly for 5 minutes continuously, return if bleeding not controlled. ( ) The interpretation of your X -Rays are preliminary reading. Your films will be reviewed by a radiologist. You or your Physician will be contacted if there is a change in the diagnosis. PROCEDURES ( ) None ( ) Laceration Repair ( )I&D ( ) Removal of Foreign Body ( ) Procedural Sedation () Reduction of Dislocation Other MEDICATIONS ( ) Continue present medications except: Advil (Ibuprofen) or Tylenol as needed for pain, fever according to package instructions for age and weight, etc. ( ) Use the following medicines according to package instructions: 1: 2: 3: ( ) The following medicines may cause drowsiness: DO NOT DRIVE OR OPERATE MACHINERY WHILE TAKING: The prescribed antibiotic/medication, may reduce the effectiveness of medication you are currently taking. Check package instructions or consult with Pharmacist. FOLLOW-UP This is our recommendation for follow-up. If your insurance (HMO) requires a physician referral for specialty consultation, I IS YOUR RESPONSIBILITY TO OBTAIN THE NECESSARY APPROVAL. .up with: ( ) Urgi Center ( ) Occ. Health/Company Doctor roily Doctor or in days for: ( ) Follow-up ( ) Suture removal ( ) The following test was performed: ( )CBC ( ) CMP ( ) EKG ( ) X-RAY ( ) CT ( ) US ( ) OTHER IF YOU DO NOT HAVE A FAMILY PHYSICIAN .CALL 763-2900 FOR PHYSICIAN REFERRAL. ( ) Call as soon as possible for appointment ( ) Pick up your X -Rays from the Radiology Department prior to your follow-up appointment. Call 763- _ • • • • • - - ' u ready ( ) See your ph ' ' •ectalist if not improved in •a ( ) Return to E especially if you teel your conQRbrris-vreFseoiog ( ) Your blood pressure was elevated. Check with your physician. Clinical Impress ons t -r -2 I ereby ackn wledge receipt of these instruc i•ns and ' xi t Care information. I understand that I have had emergency treatment onl and that 1 may be released before all of my medi • oblems . = . nown or treated. I will arrange for follow -u • b- n instr c .. t is my responsibility to no SIGNATURE: NAT ( SIGNATURE: Nurse RN Date ON VERBALIZES UNDERSTANDING Date KEITH GREENWALD IN THE COURT OF COMMON PLEAS OF PLAINTIFF V. HEIDI SHENCK N/K/A HEIDI SHOEMAKER DEFENDANT CUMBERLAND COUNTY, PENNSYLVANIA 2007-571 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT rn C"1 w 4 CD Zi AND NOW, Friday, December 19, 2014 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, January 20, 2015 8:30 AM for a Pre -Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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. You must file with the Court a verification regarding any criminal record or abuse history regarding you and anyone living in your household on or before the initial in-person contact with the court (including, but not limited to, a conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition. No party may make a change in the residence of any child which significantly impairs the ability of the other party to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and Pa.R.C.P. No. 1915.17 regarding relocation. FOR THE COURT, By: /s/ Jacqueline M Verney, Esq�✓ Custody Conciliator TT 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. ler Cumberland County Bar Association Aka/32 South Bedford Street l�- i Carlisle, Pennsylvania 17013 • Crosse Est • Telephone (717) 249-3166 O 7 ni,e'j CST. • Veinefil Ise. 09,', Law Office of. Pamela L. Purdy, LLC Allison C. Gossett Attorney ID No. 314900 Pamela L. Purdy Attorney ID No. 85783 1820 Linglestown Rd., Harrisburg, PA 17110 Tel. (717) 221-8303; Fax (717) 221-8403 plpurdy@purdylawoffice.com allison@purdylawoffice.com Attorney for Plaintiff KEITH B. GREENWALD, JR., : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA, v. : NO. 2007-571 HEIDI A. SHENCK, N/K/A HEIDI A. SHOEMAKER,,. Defendant : CIVIL ACTION - LAW : IN CUSTODY PETITION TO WITHDRAW AS COUNSEL AND NOW comes the Law Office of Pamela L. Purdy, LLC, counsel of record for Plaintiff Keith B. Greenwald, Jr., and respectfully represents the following in support of this Petition: 1. _ Petitioner is undersigned counsel, the Law Office of Pamela L. Purdy, LLC, counsel of record for Plaintiff, Keith B. Greenwald, Jr., in the above - captioned action. 2. Defendant is Heidi A. Shenck, n/k/a Heidi A. Shoemaker, who is represented by Tabetha Tanner, Esquire. 3. Plaintiff has failed to substantially fulfill an obligation to Petitioner regarding the fees due for Petitioner's services and has been given reasonable warning that Petitioner will withdraw unless the obligation is fulfilled. 4. There is currently a custody conciliation scheduled for January 20, 2015. 5. As a result of Plaintiff's failure to fulfill his financial obligation to Petitioner, continued representation of Plaintiff will create an unreasonable financial burden on Petitioner. 6. Pursuant to Rule 1.16 of the Pennsylvania Rules of. Professional Conduct, counsel of record may terminate representation where a client has failed substantially to fulfill an obligation to the lawyer regarding the lawyer's services and has been given reasonable warning that the lawyer will withdraw unless the obligation is fulfilled, and where representation will result in an unreasonable financial burden on the lawyer. 7. Petitioner has communicated with Plaintiff on numerous occasions regarding this issue. 8. Defendant's interest is represented by Tabetha Tanner, Esquire, and as of the date of this filing she concurs in Petitioner's request. WHEREFORE, Petitioner, the Law Office of Pamela L. Purdy, LLC, respectfully requests this Honorable Court to permit Petitioner to withdraw as counsel of record for Plaintiff in the instant action. Respectfully Sub i tted, Date: iaa9- 19' Allison C. Gossett Attorney of record for Plaintiff CERTIFICATE OF SERVICE The undersigned hereby certifies that on the 6o4h day of December, 2014, a true and correct copy of the foregoing document was served by regular mailupon the following: Tabetha Tanner, Esquire 3507 Market Street, Ste. 303 Camp Hill, PA 17011 Keith Greenwald 110 Huckleberry Road New Bloomfield, PA 17068 Den -e M. Kendall, Paralegal Law Office of Pamela L. Purdy, LLC KEITH B. GREENWALD, JR., : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2007-571 HEIDI A. SHENCK, N/K/A HEIDI A. SHOEMAKER„ Defendant CIVIL ACTION - LAW IN CUSTODY ORDER AND NOW, this 14day of lefriiN, 201/upon consideration of the Petition to Withdraw as Counsel, IT IS HEREBY ORDERED AND DECREED that Petitioner, the Law Office of Pamela L. Purdy, LLC, is. granted leave to withdraw as counsel for Plaintiff, Keith B. Greenwald, Jr. BY ,HEtOUR J. Distribution: Allison C. Gossett, Esquire, 1820 Linglestown Rd., Harrisburg, PA 17110 .�Tabetha Tanner, Esquire, 3507 Market Street, Ste. 303, Camp Hill, PA 17011 Keith Greenwald, 110 Huckleberry Road, New Bloomfield, PA 17068 ,Pc 6-5 Ma, / /is igW (73 ,,r r -ter_ < L:5 cn Law Office of Pamela L. Purdy, LLC Pamela L. Purdy Attorney ID No. 85783 Allison C. Gossett Attorney ID No. 314900 1820 Linglestown Rd., Harrisburg, PA 17110 Tel. (717)221-8303; Fax (717) 221-8403 plpurdy@purdylawoffice.com allison@purdylawoffice.com Attorney for Plaintiff KEITH B. GREENWALD, JR., Plaintiff. 2015J-,1.15 PH 12: 22 O1JMBEF:LRNU LOUIk i' -:i. PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. : NO. 2007-571 HEIDI A. SHENCK, N/K.A HEIDI A. SHOEMAKER, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly withdraw the appearance of the Law Office of Pamela L. Purdy, LLC, as counsel of record for the Plaintiff in the above custody action. Law Office of Pamela L. Purdy, LLC Dated: C114-1/( S By: Pamela L. Purdy PA ID No. 85783 Allison C. Gossett PA ID No. 314900 CERTIFICATE OF SERVICE The undersigned hereby certifies that on the I day of January, 2015, a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, upon the following: ' Tabetha Tanner, Esquire 3507 Market Street, Ste. 303 Camp Hill, PA 17011 Keith Greenwald 110 Huckleberry Road New Bloomfield, PA 17068 e M. Kendall, Paralegal Law Office of Pamela L. Purdy, LLC