HomeMy WebLinkAbout97-00509
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MARY G. BROWN,
Plaintiff
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
vs.
97-0509 CIVIL
ROGER A. BROWN, JR.,
Defendant
CIVIL ACTION - CUSTODY
ORDER
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consi~eration of.the testimony adduced, it is ordered and directed that:
I. The parties shall have shared legal custody of the minor child, Benjamin R. Brown,
born December r5, 1986. Each parent shall have the right to participate in the major decisions
effecting the child including, but not limited to, medical. religious and educational.
2. The mother shall have primary physical custody of Benjamin R. Brown.
3. Partial physical custody of Benjamin R. Brown is granted to the father, as follows:
a. Three out of four weekends based on the mother's work schedule from Saturday
morning at 6:00 a.m. until Sunday evening at 7:00 p,m. The plaintiff shall provide all
transportation for the periods of panial custodv pursuant to this pllrnllt'atlh. In the event
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the defendant wishes to secure custody on Friday evening, he shall meet the plaintiff half-
way between the plaintiff's home and defendant's home at a location and time agreed
upon by the panies.
b. During the summer school vacation of the minor child, the defendant shall have a
period of custody beginning on Saturday morning at 6:00 a.m. of Father's Day weekend
and extending until one week before school begins. The mother shall have panial
EXHIBIT "A"
parent. Both shall encourage the child to have significant contact with the other parent,
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nor pennit others to stllte, in the presence of the child, derogatory comments about the other
BY TIlE COURT,
John J. Connelly, Jr, Esquire
For the Plaintiff
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.. ~ CucHe sCams;:' ESqui~e
For the Defendant
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R.HOADS B SINON LLP
ATTORNEYS AT lAW
PETER K. UONAMAN
ROBERT A. LONGO
I~~ NO,4.:' It I.It-U ""14.U-1
4.1 W15T STitCH STREET
MANit ElM, PA 11~.1"l
(7111 Oa5.2~02
LANCASTER. r^ 17002
M. LUCILE 5EAMAN
JESSt R. RUttL
KIMBERLY ALBR1CltT NOtL
DEAN r. PltRMATTEI
TtLEPHONE f 7171 :U)7.!")127
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410 MAIN STRtET
lANDI5VIlLE, P^ 1753"
17111608-2.UO
December 18, 1997
Hon. Kevin A. Hess
CUMBERLAND COUNTY COURTHOUSE
1 Courthouse Square
Carlisle PA 17013
RE: BROWN v. BROWN - CUSTODY
NO. 97-509
Dear Judge Hess:
Enclosed please find Mr. Brown's proposed custody Order. I
advised you after the hearing on December 3rd, that my client
wished to submit a proposed Order. My client believes that
the enclosed Order is fair and equitable to both parties. As
noted by Dr. Sheinvold and as contained in the recommendations
in his custody evaluation, Ms. Brown unilaterally decided to
move to Reedsville without a careful consideration of the
impact of that move on Mr. Brown's relationship with Benjamin.
The enclosed Order allows Mr. Brown to recoup some of the time
that he has lost as result of Ms. Brown's move to Reedsville.
As you are aware from the testimony, Ms. Brown is working
three consecutive weekends out of four and, thus, she was
agreeable to Mr. Brown having his son for those three
consecutive weekends. Again, as recommended by Dr. Sheinvold,
the schedule proposed in this Order is fashioned to include as
many three day weekends as possible with Father during the
school year. The Christmas vacation is shared equally and the
only other holiday Father is specifically requesting is the
Thanksgiving holiday and the school vacation associated
therewith. Again, this allows Father some quality time with
his child during the school year.
Dr. Sheinvold recommended that Ms. Brown should be responsible
for a majority of the transportation during the school year.
Since she drives to Cumberland county on a regular basis for
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
MARY G. BROWN
vs.
No. 97-509 Civil
ROGER A. BROWN, JR.
o R D E R
AND NOW, this day of , 1997, after
a custody hearing the Court enters the following Order:
1. LEGAL CUSTODY of Benjamin R. Brown child of the Parties,
shall be shared by the Parents. Each Parent shall have the right
to participate in the major decisions affecting the children,
including, but not limited to, medical, religious, and education
decisions.
2. Mother shall have primary physical custody of Benjamin R.
Brown.
3. Partial physical custody of Benjamin R. Brown is granted
to Father, as follows:
A. During the school year, Father shall have physical
custody three consecutive weekends out of each four
weekend period beginning December 27, 1997, from
Friday at 7 PM until Sunday at 7PM. In the event
the child does not have school on a Monday
following father's weekend, Father shall keep the
child until Monday at 7PM, or if the child also has
a vacation day the fallowing Tuesday, Father shall
keep the child until Tuesday at 7PM.
B. During the summer months when the child is not in
school, Father shall have primary physical custody
beginning 10 days after the last regularly
scheduled school day until one day prior to the
start of school. Mother shall have partial
physical custody one four day weekend out of each
four week period during the summer. If mother takes
her week of vacation over the fourth of July then
she shall have the 4th every year. If she does not
take vacation, the parties shall alternate the
holiday.
C. Each Parent shall have one week of uninterrupted
vacation with the child during summer vacation with
thirty days notice to the other Parent.
D. Whichever parent has the child for the weekend,
that parent shall also have the holidays of Easter,
Memorial Day and Labor Day. Father shall have every
Thanksgiving and the entire school vacation
associated with that holiday.
E. The Parties shall divide the holiday of Christmas
and the child's Christmas vacation as follows:
(1) After school on the child's last day of school
until half way through the vacation period(which in
a typical year will be Dec. 29th or 30th) with
Father,
(2) The end of Father's vacation period until the
child returns to school with mother.
F. Mother's Day shall be with the Mother, and Father's
Day shall be with the Father 9:00 A.M. until 7:00
P.M.
4. All transportation for the foregoing schedule shall be
provided by mother.
5. Both Parents shall permit reasonable telephone access to
the child when the child is in his/her custody.
6. The Parents are encouraged to accommodate the reasonable
requests of the other Parent for alterations of any agreed upon
schedule, as the circumstances and the best interests of the child
require.
7. Both Parents shall encourage the child to love and
respect the other and shall not state, nor all other to state, in
the presence of the child, derogatory comments about the other
Parent. Both shall encourage the child to have significant contact
with the other Parent, and shall make certain that the child is
ready on time for the transfer of physical custody from one Parent
to the other.
BY THE COURT:
JUDGE
ATTEST:
Copies to: M. Lucile Seaman, Esq.
John J. Connelly, Jr., Esq.
B. During the summer school vacation of the minor child, Defendant
shall have a period of custody beginning on Saturday morning 6:00 a.m. of Father's
Day weekend and extending until one (1) week before school begins. During
Defendant's period of summer custody, Plaintiff shall be entitled to partial custody of
the minor child during her off weekends which will occur one (1) out of every four (4)
weekends from Friday evening at 7:00 p.m. until the following Wednesday evening
at 7:00 p.rn, time, Plaintiff shall also be entitled to two (2) weeks of vacation taken
either consecutively or separately at Plaintiff's election with thirty (30) days notice in
writing to the Defendant. The Plaintiff, when electing a vacation week, Plaintiff must
Include in the vacation week her extended weekend time provided for in this
paragraph.
4, The parties shall alternate the following major holidays: in even
numbered years the Defendant shall have Easter and the Fourth of July and the
Plaintiff shall have Memorial Day and Labor Day, In odd numbered years the exact
opposite schedule shall apply.
5. The Christmas and Thanksgiving holidays shall be divided as follows:
The Plaintiff shall have the Thanksgiving holiday including the weekend in even
numbered years, and the Defendant in odd numbered years. As to Christmas, the
Christmas school holiday of the child shall be divided in the middle of the child's
school vacation with the father having the first half of the school vacation to include
Christmas Day from the evening of the day the child begins his Christmas vacation
"
MARY G. BROWN,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 509 CIVil 1997
v.
ROBERT A. BROWN, JR.,
DEFENDANT
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW this _ day of
. 1997 after hearing held in the above-
captioned matter, the following Order Is entered:
1, The parties shall have shared legal custody of the minor child, Benjamin
R. Brown, born December 15, 1986,
2. Primary physical custody shall be In the Plaintiff, Mary G. Brown.
3, Partial custody rights shall be in the Defendant, Roger A. Brown, Jr"
based on the following schedule:
A. Three (3) out of four (4) weekends based on the mother's work
schedule from Saturday morning at 6:00 a.m. until Sunday evening at 7:00 p.m.
Plaintiff shall provide all transportation for the scheduled weekends. In the event that
Defendant wishes to secure custody on Friday evening, he shall meet Plaintiff halfway
between Plaintiff's home and Defendant's home at a location and time agreed upon
by the parties.
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B, During the summer school vacation of the minor child, Defendant
shall have a period of custody beginning on Saturday morning 6:00 a.m. of Father's
Day weekend and extending until one (1) week before school begins, During
Defendant's period of summer custody, Plaintiff shall be entitled to partial custody of
the minor child during her off weekends which will occur one (1) out of every four (4)
weekends from Friday evening at 7:00 p.m. until the following Wednesday evening
at 7:00 p,m, time, Plaintiff shall also be entitled to two (2) weeks of vacation taken
either consecutively or separately at Plaintiff's election with thirty (30) days notice In
writing to the Defendant, The Plaintiff, when electing a vacation week, Plaintiff must
include in the vacation week her extended weekend time provided for In this
paragraph.
4. The parties shall alternate the following major holidays: In even
numbered years the Defendant shall have Easter and the Fourth of July and the
Plaintiff shall have Memorial Day and Labor Day. In odd numbered years the exact
opposite schedule shall apply,
5, The Christmas and Thanksgiving holidays shall be divided as follows:
The Plaintiff shall have the Thanksgiving holiday Including the weekend In even
numbered years, and the Defendant In odd numbered years. As to Christmas, the
Christmas school holiday of the child shall be divided in the middle of the child's
school vacation with the father having the first half of the school vacation to include
Christmas Day from the evening of the day the child begins his Christmas vacation
B. During the summer school vacation of the minor child, Defendant
shall have a period of custody beginning on Saturday morning 6:00 a,m, of Father's
Day weekend and extending until one (1) week before school begins, During
Defendant's period of summer custody, Plaintiff shall be entitled to partial custody of
the minor child during her off weekends which will occur one (1) out of every four (4)
weekends from Friday evening at 7:00 p.m. until the following Wednesday evening
at 7:00 p.m, time, Plaintiff shall also be entitled to two (2) weeks of vacation taken
either consecutively or separately at Plaintiff's election with thirty (30) days notice in
writing to the Defendant. The Plaintiff, when electing a vacation week, Plaintiff must
include in the vacation week her extended weekend time provided for in this
paragraph.
4. The parties shall alternate the following major holidays: in even
numbered years the Defendant shall have Easter and the Fourth of July and the
Plaintiff shall have Memorial Day and Labor Day, In odd numbered years the exact
opposite schedule shall apply,
5, The Christmas and Thanksgiving holidays shall be divided as follows:
The Plaintiff shall have the Thanksgiving holiday including the weekend in even
numbered years, and the Defendant in odd numbered years, As to Christmas, the
Christmas school holiday of the child shall be divided in the middle of the child's
school vacation with the father having the first half of the school vacation to include
Christmas Day from the evening of the day the child begins his Christmas vacation
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MARY G, BROWN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO, 97.509 CIVIL TERM
ROGER A, BROWN, JR"
Defendant
CIVIL ACTION. LAW
IN CUSTODY
HEARING MEMORANDUM
AND NOW, comes the above named Plaintiff, Mary G. Brown, by and through
her attorneys, Connelly, Reid & Spade, by John J, Connelly, Jr" Esquire, and submits
the following In accordance with the Court's Order dated April 16, 1997:
1, ISSUES FOR RESOLUTION:
Plaintiff shall remain primary custodian of the child with Defendant
having partial custody three (3) weekends per month and the parties sharing the
summer equally.
2, ANTICIPATED EXHIBITS:
None. However, Plaintiff reserves the right to supplement this answer
should such become necessary or available.
3. EXPERT WITNESSES:
Arnold T, Shienvold, Ph,D,
2151 Linglestown Road, Suite 200
Harrisburg, PA 17110
Dr, Shlenvold will testify as to the recommendations based on his
."
MARY G, BROWN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 97-509 CIVIL TERM
ROGER A, BROWN, JR"
Defendant
CIVIL ACTION - LAW
IN CUSTODY
HEARING MEMORANDUM
AND NOW, comes the above named Plaintiff, Mary G. Brown, by and through
her attorneys, Connelly, Reid & Spade, by John J. Connelly, Jr" Esquire, and submits
the following In accordance with the Court's Order dated April 16, 1997:
1. ISSUES FOR RESOLUTION:
Plaintiff shall remain primary custodian of the child with Defendant
having partial custody throe (3) weekends per month and the parties sharing the
summer equally.
2. ANTICIPATED EXHIBITS:
None. However, Plaintiff reserves the right to supplement this answer
should such become necessary or available.
3. EXPERT WITNESSES:
Arnold T. Shienvold, Ph.D.
2151 Linglestown Road, Suite 200
Harrisburg,PA 17110
Dr. Shicnvold will testify as to the recommendations based on his
J
MARY G. BROWN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
r:
v,
NO, 97-509 CIVIL TERM
ROGER A. BROWN, JR.,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
HEARING MEMORANDUM
AND NOW, comes the above named Plaintiff, Mary G, Brown, by and through
her attorneys, Connelly, Reid & Spade, by John J. Connelly, Jr., Esquire, and submits
the following In accordance with the Court's Order dated April 16, 1997:
1, ISSUES FOR RESOLUTION:
Plaintiff shall remain primary custodian of the child with Defendant
having partial custody three (3) weekends per month and the parties sharing the
summer equally.
2, ANTICIPATED EXHIBITS:
None. However, Plaintiff reserves the right to supplement this answer
should such become necessary or available,
3. EXPERT WITNESSES:
Arnold T, Shienvold, Ph,D,
2151 Linglestown Road, Suite 200
Harrisburg, PA 17110
Dr. Shienvold will testify as to the recommendations based on his
custody evaluation dated September 3, 1997 and his recommendation that the
Plaintiff remain the primary custodian,
4, ANTICIPATED FACTUAL WITNESSES:
Plaintiff Intends to call the following factual witnesses:
Mary G, Brown, Plaintiff
68 Barrville Mountain Road
Reedsvllle, PA 17084
Plaintiff will testify as to her relationship with her child, her child's school
performance and her reasons why the child should remain in her primary custody.
Michelle Dunn, Plaintiff's Neice
Ms, Dunn resided for a period of time with the Plaintiff and will testify
as to the Plaintiff's and Defendant's interaction with tho minor child and with each
other.
Respectfully submitted,
CONNELLY, REID & SPADE
Date: II-J.{r, -01
BY:
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EAST PENNSBORO AREA SCHOOL DISTRICT
KINDERGARTEN PROGRESS REPORT
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REPORT TO PARENTS - GRADE 1
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Choo",," .1 11I111( ,l!',j d"""(\I1' ,.Ir... ." \" "'1\.: .c:.:. r..,
. , -, --.--- C; "
\Vrilec. fnr 1I,111(1l1" pltrpf)~I'" <:- -
Move~ (rom Ir;;;P~I;"r\-~p,,:I'n.: 'n t ""\I",tl\",11 \pl~i~~--'- c~ c, (,
Qrally eKprr~"f'(, irlf','..--;:l~~.~;j;- . - .-- ----.-.- i; c, ~ c..,
Li~len~ ,1nft (('..pnnd.. .~j,I',~~~i;~i~~--' __ u___.___~ J\J l\l
N 1\J
~~EM~T1CS.. -
'- -- .
Unrlf'rq"nd~ ",1';"1\" l,lI:" (J <.. c,
Undt'rf,',l~r~ ~~lh!',lr III,., ',1'" .---- H__'__ -,-- C..,
--... ..--------. ~<; C, '" (..,
Can cnunl hy 1 '<;. In i!JC
Can counl Ill' 10\ '0 ;~~ -- -- ., . --.-..- Co,
c) ,; ~
Can counl by 5 '.. 10 1M ____ ______4__.~___ . C, ,
"
Can counl hv 1" '''_5.1),_ _ - . .'. n ':' " ,<:
c
Unrlrrl'olilnrf, ( nnf "pI III "'11'1('\ .. ---. f
Unrlrrli,.lrHf" (n;" "1" nl pi,1I f' ':.1111" . ---._.
one... Il'n.. ,'. ,S
Can wflle ,lnn ..~i~~-r~-l~~h(~~-j;rr',I~:~"'" c.:. e:.
HANDWRITING
--.- ..~ -,- , - - 1\
Forms letler~ corr('e Ilv _S N N
Uses prorwr ';PM ,q~ ..---.,.-- S " N ,"l
App!iPl; ...kdl.. Il~.-fl:",~i~-~~HL ,- - ...- --_..__.- <; I' " 11/
SCIENCE n " c -. ,
HEALTH/NUTRITION c r;, S c.
,
SOCIAL STUDIES c .s ,c:, c,
MUSIC C, tJ ,c;;. ,')
ART c., ."i S S
PHYSICAL EDUC^T10'i c; '...: .c..; ,c..:,
,
SOCI^L-PERSO'i .11 1lf\'11 01'\11 '1 -
o_~t~~!f'.~lt!~ II :". """, S-,: .(':- :.;. ,
i- .,)
I.. (1}11t'f'lHl~ .\l1t: f II". II,,,..,. 0_ S "
- ---... .... -- 7:!-
Work.. Illdl'IWIH!,"'!!" .~. C' ,
\Vorh (,lrf'fully ,1l~J ;'-f~;'I.\' .--, 0-..... ____on " '"
COmplelp.fo w()rk-;;;;II~'~-;' , ,. 0..__.--_.-.- 5- - ~ "
Follow.. dUI't "'~l '_'d' .- ..-.'-___.0____- Q
N J~ 1\
P,HII(IIl.llh I;,':p',' on.
, ,,, "":1' '.'1' l~_ .~ 1 '-,
-'Oi~~~ ~( bo": 'I ' ~, , C; -
--'--- .. i1-
Srl/.co/H,.ll I'C.' 1\/
Is fr"pt'(II111 _. -_..0_- .- c:.. '
."> ,'I
^SSIGNMENT
N,lme -Bt, (L
/,
t \f .~ ~I..J n
i,
. __/-!J::.-n :.:JuL_!L-._
Teacher COmmenl\
(Second Period)
';d,J...w ~11.9 p,,,-,'
t-cJ;.;ta.,....l..I~~ ~.--L r.
}u(l,-l..01-9 CI....d.- ~Il;t.v.
J --Mv'(... /'M'.;(; ALt."'" $""
drl1J.M,.t""rlU.d:; h~ ...&.rt.',,;
~''''U~'ht,''''! ...;(:.u-) -'Yl'.cH~< ~-~
'fX"'" .~. /Ii, .~ 1t'1"/_I~, i-'_'
.<J.fJa.~''''-<;1 . ~ .,~~t .1.( tti 'I..
.f'l,1'K.Ltlln/' __
'"' t1-~cher Comment';M',,<_
'<:1'71.("'" W (Third Period) (d~<..t -,&.,
~~ j<-<-l<l.-lrl:MJ. 'TW....'!
;t~rU..., kl)~ A- ;lma..u
(L~t ;tJ.v h~,,*'- .
~H.i.e.j ...-M..' .i.J ./YII.o-t'~'?tbJJJr"
.-t-,.:.du.-c:b.I-MJ.- ,;t~.f-r...u,
~ -k~::r-i1.5P~I~n.9 -
il-~ ~ttt.I.L...rr.... '
~LI,J _u...,.,;[,.,:..~ ;tJ ./K., {~.,..:
a J,.U..' A./, .t,t~" r L...1 JJ.., ,vl-tdL ,-t
Au., ;CJ Teacher Comment',A....l Lt"1'l..
'TO"" (Foutth Period)
p...,-~.n.c.'t.V./ .
l' Ill'>"" L.n-rrJ ..J.<..A..tI. ("t.M.J 1'- (., C
.e, ,~.t...:~ i4 ~k t'.. h.fo-t1..l \.
(l l'-<\,' ~! A-t11,.t.(..\.,..) ;.:.;,
A...../o..a....T.C1.- ,A;J /llAI-t a,;<--
1~~'Mv,
-R(uWA..- 1 ~);e II, (l~J - ,
{ ,<.< I"tt.l..{t1'-;' -f), r...) _.. .
l.<<tcL tl't.v ).(,., J(,.IlWll..,,) .r<J~ d.
I /J~ t"f..., cl.. ,"l>t..{( 'I"' L
Grade 1. for Ihe next School TOlm
. I
.~" (ov(\A'V JI-/lc-/Lkr"-'
",1. hl'l'n
TII,H hrr'~ '1~.1,1It1lr'
, .
"'-4
.L.I'..I~~'.
"":
/............
&AST PBKlISBORO I\RBA &aIOOL D18TRIC'l'
PRI-RlFIRIIAL
OOHSULTI\TIOll RJQa118T
00'" IDBllTlAL
t
..
,
,
o
8TUDBHTI:-~r; I t'1 B (C'll..J''\. DOBI/;?/;)/r~
BtJILDIl101 E.', /,..t1':f-r?fC!lV 5"h"" I
RlrIIUUIlO Tll\CBlR. 1i't'J. 8 (lL r~e f' .
<:1" I... JD . DM'll. 10/1/ /q,3
GJWl.. /
88" JI&J -7J -19 7f.."
2,
Ducr lbe the prlmary academlc andlor behavloral d1tf1cII1U.. that the
.tlldent l. 8wperl.nclnq In the cla..room,
, j. : .' u..J;w..t.
'"'6l.1\.,j1-"'-' v ,{,4 )"'~UC/l.-<4 ~rv ~~, ~n...G. ..,
-1X-1 Hvw....o. iJ,... A./U It L"< "4 .a.4'Vt M;t<.~ ~ oJ.."w II'< ~V
,).~ ~t'I,.O..vtul- -&.J (J...(..l.c .-t-d..~4tJ ~v .A-~(cJ.,tt,.
~~~ ........ e-,(,.... .c.-~~,~,
Check the three most outstandinq probleme YOII are ob.ervin;,
.Iorqanlzational/Study Skills Readinq Skilll
:::Receptive/Ewpressive Lanquaqe ---Hath Skilll
Hotlvatlon ---Wrltin; proce.. Skilll
Ztnapproprlate Behav iors ,./'ine Hotor
___Difficulty I\cceptinq Rules Interperlonal Relationlhip.
___other. Describe
1,
3,
De.cribe 'pecifically what steps you've taken in the clalsroom to re.olve
the problems the student is ewhibitinq,
1- I .A.J.~
,><U.A.t..''1 ,(..1<- ,(,.~\..~
/.Mp +,.......J (t.~v
4, I\re the etudent' e parente aware 01 your concern? '" ~.. Delcribo parent
contacts/discussions,
~v ,C<t-lL. '~n.l-t'l<..v n..J
PTD t~fl-q'; AL.......~ ,..... ~
t'a.~ II, IH.3
~I l~q,3
I
5,
Has the student ever been retained? riD
If ye., what ;rade?
6, Check the support services the student ie receivin; at thil timo.
___S/L Therapy
___Readinq Support
___Readinq Recovery
___Hath slIpport
___Colln.elin;
___other I
,
7, Rate thll etudent' e ecademic and "ohavioral progrell in relation to
claeeroom peere,
Week AvenI e Strong
R.ading ./
Math ./
Writ1nq (Mechanice) ./
Written hprueion .v
Spelling ~/A
'in. Motor Development /
S.lt-Control /
/
S.lt-Contidence v
Peer Interaction ,/
Adult Interaction ./
Compl.tinq Alliqnmentl /
,/
Clall Participltion .
'ollowing Dirlctione ,/
Learn!nq Rate IV
B, II the Itudent abient excellively? ~ It yal, indicat. the numb.r ot
daYI, _ .
9. 00.1 the Itudent take any medication on a regular balil? JVn
bplalnl
(Check with echool nuree)
10. Are there any medical concernl ot tamily probleml that may be contributing
to the Itudent' I learning probleml? ~ A;W ..p a"rV ~ ~
OUIDMCI IID'ORKl\'l'IOH
TIlT
H.tro:Olitan Readin.es Teet
Btantord Achievlment Teltl
Reading Total
Math Total
'l'ota 1 Score
BooRlIS)
&//16 _ ~
DAft
.fk3
-
-
oth-Lennon
WISC-R/Individual I,Q, Test
other I
-
-
-
-
,
1
';::p I);",::) \ I ~,( /
EAST PENNSBORO AREA SCHOOL DISTRICT
RFI'ORT TO PARENTS - GRADES 2-4
EXPLANATION OF GRADES
o - Olllq,'lldln~ \"olk 1'\( ('I,d.. !'\IH'll.illlll\" I 1Il1provln~-Onlv if student received "N" previously,
S - S.llP;"(,H Im\ \\Il!~ "'f'I'I.. "\I'I'f I,.I'(I!1.. bul "ltll not meeting expectations
, ",,,,1, ,,"prol'enwnl-Work does nol meet expectations
1'1 2ncl J,d 41h
LANGUAGE ARTS --,-----,-
Has a pO\III\'f' ,'1l-,!~;;~~;;;;1:'~':;;'(.'-1~ ~ c., ...; <.,
. .~-- .-* 5-.,
U~tS rn~yrr:~"'hlll!l .~-;!:.. _..-__.. __ _. ~ '? ::J
Dru'tmln(>.. WIPf! 1'1,'.11\:"1;' oI"llllo.:h iii" "I!I"~ OJ (011.,'\1 ::i '-1 c., ~
-=-'-;--,- .- . --_.-,---
Applit!... Inll\~~~_"II.'~:I'~'~~_" 'II 11\"'1"1.1,." 'II .. __.n ~-- c., --, :.:J
U...e!t 11ppfoprl,llf' f~~'.!~'"'~f_': ",~~~~ ..!\~d\ ,~ '" ._u._ ____. ~'J ~, =.,
H.1\ d pml1'V(1 ,lllllutll' to\\',lId.. \\'rl"~.!:__. _.___._____ S C, IV I
Chome~ d IOplC _.~~1c1 dt'\f.lol1\ idf',llo._~r1..\'III,Il.'_~____. c;-- C'J ^J .L
\'Vfltel.i for \iH'lltl~ pllfpmf" '1 c., I\J .l-
-,--_._~. - c)
^hlr 10 rrVllo.l' ,IlHI ,.dll S <.J ::>
--.-. - - ...----
lhf'" (flftl" I -Ill': ~ "I: ", .' ,'j \ I i,l\ \\': II' '\: 2- c~ c; ,::,
Ofdll~' r'(llftl'__"__.~.dl':I" .1 '1'1" \ C', i ~) I~
n -, - :J
Lislem and fl'''POllrl.. .1I1prnp/l"".I, S ,) r 10
>
MATHEMATICS
--~._-- .- ..--..---- -
Number (on(ppllo. _.---_..--~._.-- - ---- 10 C, Ic;.J
BilSIC fMI\ --- _P. S. C-) 1'-,
\\'orct I'If(1h!,';~'. 0' C:J I..>
SCIENCE ::J In c, ':J
- ') Ie:, 1.5
SOCIAL STUDIES c)
HEALTH S Ie:, c) S
MUSIC C) Ie., ) 5
ART l"l c, ~ 5-
PHYSICAL EDUC~T10" I~ ) C ~
HANDWRITI"r. '-> c, c ::J
,
SOCIAL-PERSOo"j~1 IJfVfl OP"I' I
Puts forth l'iforl -- .,.-. I
~_':. ~- N
Is courteous and (-OIl~HII~;:;I;" - .. S
~ '->
Is developmg sPlj.rf'1i.lnc(> .--_. ,- -'- - ._-_.._----~ :-
---.-.-- <0- ::J =...
listens anrl cone ('ntr,1lN " ~ N .J..
- .--- --. --_. -, -- ---
Use~ limp WifoP!, " " N IX
IA'ork\ lnrl('l'Ipnr!I"'~\ -- ...--- . c,
., ., ~
Workli (.ItPlull\, -~_...- ---- ..-- C, 'J
- - .--...-.+"---- S ';:)
\Norks ne,lllv ;., S " ::>
Follows direcljon~---- --- ._, -_..---,,-----_.
" S " ':.:>
Participatefo hl.lpiullv 111 ~rOtJ-I~-~\n~' . ._..-.4-___- -~ C,
--~.- ._-,_... ~) ':.?
Cares for (rhnqr~;;:;;;;,,1 prnl~~~'- S C.., '., S
Ohey\ srhnnl r~i,;Io." n. .. S <:) S
, ------ ':>
Sp!r-rnnlrnl ~ ,) ,..., ~
, '-'---'"-+
Complel(,li \\'Ofk on I:'''" 0;-. 1\' i\J .AI.
Teacher Comments
(Second Period)
Teacher Commenll
(Third Period)
Teacher Comments
(Fourth Period)
'I
c. v\. ':5~ ~CI
-\~,c-"
C
-'l;"-'''-..I.,,",
h(j\). /"~l
'-,
r0Q...~
-.) (~(J r
\-\l.l. '..)(,
~C}U {'-\\-,
\ (\
(~\U rJ ~
ASSIGNMENT
\lam€' o.~. ~O ,)-{.C-u;"'fL ".1_ 11I'I'n
Teacher's SiRn,'tuH' ~ ~ .:X. 4l
..p<\'\jn:...,..ttu~
Grade 'I
(Ot the ne'l School Tetm.
Be-,'/
EAST PENNSBORO AREA SCHOOL DISTRICT
REPORT TO PARENTS - 0RADES 2-4
EXPLANATION OF GRADES
0- Ollfl"oI.HHip1\! \\'nIL f'\( I'I'(:~ ,., P"t I,lllflll~ I ImnrovlJl~-Onlv if student received "N" previously,
S - ~,lli",l( Ifl'\ \\'/l.k '1'1'1'1<- 1'\.JlI'! ',\~11l11~ hUl '\Iill nol mrcling expectallons
" N,'('cI, 1I11llrovcmenl-Work does nol meel expectations
I., 2nd 3,d 41h
Teacher Comments
(Second Period)
LANGUAGE ARTS
Has a pmiti'1' .lfl;'llf!;' t;m-.\,~!~ 11'.H:"'l: .. -. .~- .-.-.. (tr' (t,.. f"'r" 111f'
U~eli C'ornprrhr~h~');' \kJ'.. . - . .. ~.=-~.~_----~_ c; -' 1Iio... ;c:
Delermlnfl~ word tTlf'.1nmi<:.~ ti'ff\llr.', d,', nr!I"": or r IllH"'1 S.s c:; .c"
Aoplies lhinkln~ "i;,l'flWI...hi;)'f'~;;;I'~f'iwIHI -----"..-- .~ ~ ----c;-
Uses appropriate re(t>rence .1ncl-".I(;t~'~k-t-li~-'~ .. ----.-- ~, 5 .~ ,Ci
Has a positive .lllllllde IOw.uc1... Wrllln~ -.;.,I ..t:') ~C; .t..l
Chomps ,1 IOrllC ,inri df'\.',.lnn' 'r/P.l'. 1M \.,-~-;;-,~.~ .f\! ...~ ^, L.:..
\Vriles (or VMinll-~.;,.ri~~,,'". - - - - .-----.---- ^ ,c c:.; r-:s-
Ahlelo rP\'i~f' ,1~-(i-f~T;,--' - --- - -------- ^ ..S c ..0
U(,(lS (oHecl ~p~1i;;,~/t: I;'--l''!'~''~'':_ '.'.'II'''~ - ____."____~.h. (~ (.9~." I ('t)o
Orallv e'pre,,", idr,,' ,II',,,I\, ,_____ . _~.~-~=~~: .. c:,c; C .~
Listens and respond!> llpprnnn,l!r'!, c:'~ C... S c...
Teacher Comments
(Third Period)
MATHEMATICS
Number concf'pl~______ ___ ___
Basic (aclli
Word prohll"fTl'
SCIENCE
SOCIAL STUDIES
HEALTH
MUSIC
ART
PHYSICAL mU(^lIn...
HANDWRITI'i(,
SOCIAL-PERSONAl. nEVFIOPW\;'
PuIS lorlh rffo"
Is courteou!o .'nd (-;;;;-'~~;~l;;
-- ._~. ~
I.. r1pvf'lnl1iJ1~ ,pH,n'h.lf\( l'
U..It'n.. ,11111 f'l-l~; l'I!1'.l!l'~
U"pfj limC'wi"f'k
\\brk.. innr!lro'Ii!I",t1\
\'\brk.. (".Hd{I!I\~--
\\'orks ne.llly
Follow~ dlrectinn..
Participa!('!'o hplpfnll\' 11' ~rnLlp \~;;;k-.-'-"
Cares for "chnnl ~'i';';~;;"-,1Ir~rli~I~.7\',
Ohry" lichon! Ill'l"
---.
5plf.ronlrnl
Compll'll'''' '~~;r-~- fl" 11m!'
--------.-- .s s
('7 ('or
----.. S ~
'? ::;;
"---- -.----------- ._ i{l; ~
, <",
c c.:> -) '"'
,:.>
~ C' -~ C;
,J -.J
, ", CJ ..s ~,
5 ,C', s. ff
~ S 1<: s
.~) CJ C; ~
,(; ~j c;; IA"
..., . C
C, .'5
~ 'j
c; C
'1--:::'
.-.--,..* ~
:.4??
N .-J
^' T T
~.:> S :"';
~ S 5
5 N c;
. ..- -~-- ----. ---.----- "1\.1' c:. _c.,
, ~' _"-' c;
" .0 --"-----.. - ~J c;~ c:;
c:- c., c..
.. ...,-.- ',5 S S
N L 'T
Teacher Comments
(Fourth Period)
.<,
c
'r
.(
"j
ASSIGNMENT
~am. .&n_ IdCCW!:). ., _ ".1' '".,." ,p.CJ:.t11G,t.cd '-10
Teache" SiRn,,,,,,,' _.~A-,...t:iL:.t,(.':{'lLL_ ..
Grade . ~
for the ne,! School Term.
!
I"
I
EAST PENNSBORO AREA SCHOOL DISTRICT
REPORT TO PARENTS - ~RADES 2-4
EXPLANATION OF GRADES
0- OutstandinK-Work pxcccd, 1"lll'Cl.lli0I1' I -- Il1lprovlI1K-Only if student received "N" previously,
S - Salidactory-Work ml'.I' .",,'rl,1I""" bUI 'I,ll nol meeting expeClalions
N ' . ",('<'CI, impt()vcment-Work does nol meel expectations
I-I 2nd lrd 4th
LANGUAGE ARTS
H~s aoositiw illtltude lowarri~ fE',uilnJil ,co, ,co;;,
Uses comprehe"\inn ,kdl~ \.'i "-C;
----------.. ------- ,;:I .c;
Determinf'fo word nlf',U1l"L:" 'hr":Jl:I, '~,'r nt!".~ qr f lIrolf'\' ~) \.::J
,.... ,. ,., ....- .-- --
Applies thlnklMR ..1',I"'~lr.. I" """11,,-1"'''1' ~~: "
Use' olpproprl.\U' .;"'t'r,.~~;;' _,-Hi .;;;,!~'~L "'1. .--.- hO_'_. -) .....c.,
Has aDO!lIII~ ,llli'lI(h~ InW~';;I\~\~~;!":\l: d'__.._,___.u l~) I...'"
-,.,-.-.. --------,- :< " ')-
Chooses a topic and rlr\<1'IOll\ l~':'.:'~_~~~~~'.~~______..__
Wriles (or varioufo f1urpou" 's c:;
Able 10 revi(,p .lnci l"dil .'----_. ----..- IS '1
Uses correcl f,r'Jrlllu~ I" ,.';:;~"l.\~'-\~',"'''~! . .--.-- -..<; ~
Orallv (>'<fH""\r\ Itl;..l~-~ ~::;;l\ _on -.- :{f~ <;
lts.len~ olnn rr\r'Jo;;rl~ .IPI~"(;I"I.l!.,I\ _.. 1
MATHEMATICS
Number coneepl~ _.~-_. .., .... r-;~ g.,
Basic faels ---.-. .-- ...-- - -- -..-- ~,
Word prahl..,,, '--'--'-- .----.---- '", ,c:.,
SCIENCE I^ -r.
SOCIAL STUDIES C; c;
HEALTH Ih ,e,
MUSIC 1/) .."1
ART c.; TIC S
PHYSICAL EDUCATION II' <",-
HANDWRITING I.f: :<
SOCIAL-PERSONAl. nrVHOP~IE"'T .. ._--,--
PUIS (orth .HM ..- . .-....-. ... -..- .. u
AI 'I-
Is courteous ann eOl,c;:df'r,ll~ --- ~._~..- --.. \.')
I, develOp;'" ,elf,rpli.nce ..--.-.--.--- ----- 1\<
..
listens and concen!rale.. --.-------
Uses time wisely -,-
Wotks independpn,!,' . ---. - ._._-. ~ ')
Works e",efull,- .. - 1.<:: 1-'"
\<\brks ne.tl" _~___~__ n .__. .. __. . ..-..- le
Follows direction!> ... - .__...----.-- - _.~ --'--' IN 7
Participates helpful!\ in Rr~~j;~~;).;L:-' -. , ,--
C; c-
Cares for school & pflrc;nn.lI'p-;nprriV- ..-..- - ,.---.. ""
'oj
----..-- -
Obeys school rule' ::, .,
Sell-control .H__ ,c:, c;
Completes wnr~ on Itf1":f' --, --.-..- ._.~--.-.._._- T\J 11\/
Teacher Comments
.-/1 _(Seco~~.e '-".
'6Le~ ~ ,L)~M :Y.
~d ..A-t<- 4cl;f'-i
.Jk --<-<1.- A.e.t.~ ~~(~i
-rc../0,.d ~ -4'~_~'V-t'....._,
-~~ .-<A~tA/-A-a-~.-v
~ _~>L -7/--?--Z:
~-~6~, :J~
-~-C:La/ X6- ~7t cpAa.!.
--mMe.. -tffl) -b~/.l.i;hi/.e;";,
Teacher Commenls
(Third Period)
Teacher Comments
(Fourth Period)
ASSIGN":IENT , I
lr&~4(..:..,.1.i'4~~<".'/~ '.... ii""" ...,____., ,
Te.cher\ SIRn."". __;?r>,:,2~ _. ,A~.(l.}.rl/...:;c > )
Grade
for Ihe nexl School Term.
"'--,
EAST 'PENNSBORO AREA SCHOOL DISTRICT
REPORT TO PARENTS - GRADES 2-4
EXPLANATION OF GRADES
o - Olll"'l.lndlll~: \Vnrk 1"( I,,'d.. f"pl'l 1.1111111.. I. ImprovlnA-OnlV if student received "N" previously,
S - S,lti~f,l( :CH\'--\Vllt~ n\f'f'l~ 1 '1"'1 !,llron, hut ,OllnDt meeling expectations
.___._ :-; -. ~~l'd, Improvemenl-Wo,k does not meet ~xpectalions
,,, ~l1rl .Ird 41h
LANGUAGE ARH
,. -- ..-- ... ,
H,l\ a PO\III\1' .1I1"IHk lfJ\\,I'd. ....\1."1 -:.".,
-.._-~- -
USt's camp'ehr~"~;;;'-'~kllt.. -, C"
Delermint',. worclllW,IIHn~~ i!H;'I1~I~ '~lf'f !ldill: (j~ ~ nni'~~I.n -., c,;
^pplies thlnkinM !iitr,1IfRI('\ In~o~;j1~.t:;:;.,,- - -. _4__ --.--- .-
I"
Uses approplldtr rpfNen,r .1nrl \Il~d~' ."I:Tl:..'''-----.- L ::,
_. .. ~ .. .- ..
Has a pOlillivr 11!t,~~t_'~I_' !n~\'~'~~ \"....:1: ., .. "-,
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EAST PENNSBORO AREA SCHOOL DISTRICT
RF.PORT TO PARENTS - GRADES 2-4
EXPLANATION OF GRADES
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S - Satisfactory-Work meel' expo'lall0l1s bUI still nOI meeling expectations
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PROPOSED RESOLUTION:
.
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Defendant proposes that he
partial custody granted to
DATE: -ttl:;.'rt; \ q7
have custody
mother.
/J
M:/~U
ATTO
ATTO EY FOR PLAINTIFF
RHOADS & SINON
15 N. LIME STREET
LANCASTER, PA 17602
liberal
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MARY G. BROWN,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-509 CIVIL TERM
ROGER A. BROWN, JR.,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
CERTIFICATE OF SERVICE
I, John J. Connelly, Jr., Esquire, of Connelly, Reid & Spade, attorney for the
Plaintiff, Mary G. Brown, hereby certify that I have served a copy of the foregoing
Hearing Memorandum on the fOllowing on the date and in the manner indicated below:
VIA FACSIMILE 17171 397-5267
Lucile Seaman, Esquire
Rhoads & Sinon
15 North Lime Street
Lancaster, PA 17602
CONNELLY, REID & SPADE
DATE: -.lI- ~1- q1
By:
Page 2
RE: Brown v. Brown
agreement. Due to various living situations and changes in the parent's lives over the last ten
years, there have been variations employed in the way in which Mr. Brown's access actually took
place. Nonetheless, contact between Mr. Brown and Benjamin was fairly regular and frequent up
until February of 1997.
In February of this year, Ms. Brown made the unilateral decision to move with Benjamin
to Reedsville, Pennsylvania. Reedsville is approximately one and a half hours away from the
Harrisburg area. In making this move, Ms. Brown made it virtually impossible for Mr. Brown to
maintain his mid-week access with Benjamin. Additionally, she has made it more difficult for him
to have ongoing involvement in Benjamin's school and extra-curricular activities. The end result
has been a disruption in the prior custodial access of Mr. Brown. He has been seeing Benjamin
from Saturday moming until Sunday evening on his altemating weekends. He has not been seeing
him for the mid-week visitation. He did, however, gain additional time during the summer which
amounted to approximately two and three quarters weeks.
Mr. Brown has sued fOr primary custody of his son. He feels that Ms. Brown's decision to
move to Reedsville so adversely affects his relationship with his son that it brings into question her
overall judgement with respect to the best interests of Benjamin. He also perceives Ms. Brown as
willfully violating his shared legal custodial rights. The move has also motivated Mr. Brown to
request a change of custody as a function of other concems he has regarding Ms. Brown's care of
Benjamin.
Mr. Brown feels that Ms. Brown leaves Benjamin home alone often on days and evenings
when she needs to work longer shifts. He is fearful that Benjamin has virtually no friends his own
age in his new community. He also feels that Benjamin's attitudes are changing with respect to
being open with him. He finds that Benjamin is unwilling to speak openly about things that he is
doing or activities in which he has participated in the Reedsville area. Mr. Brown feels that this is
a result of Ms. Brown's telling Benjamin that it is improper to talk with his father. Mr. Brown is
concemed that Ms. Brown does not pay enough attention to Benjamin's hygiene and cleanliness.
He reports that this was an ongoing problem for many years. He is also concerned that her
hostility towards him is expressed in the way in which she handles Benjamin during transitions.
At these transitions she will often be abrupt and verbally aggressive with Benjamin.
Mary Brown feels that her decision to move to Reedsville was definitely in Benjamin's best
interest. She reports that she and Mr. Brown were very discouraged with the East Pennsboro
School system. Benjamin had been diagnosed as having Attention Deficit Disorder and the East
Pennsboro system wanted to place him on Ritalin. The Browns did not feel that the schoo]
system was willing to deal with Benjamin's problems in a more personalized, behavioral treatment
regimen. They felt that many of his problems were with other students or the result of the
isolation and labeling that the school system did.
Page 3
RE: Brown v. Brown
Therefore, Ms. Brown felt that the school system in which she was raised in Reedsville
offered the type ofindividualized care and attention that Benjamin needed. After speaking with
the school personnel in Reedsville, she had these opinions validated and enrolled him in fourth
grade at the Brown Elementary School. According to Ms. Brown, Benjamin did well in this
setting and was promoted to the fifth grade for the 1997-98 school year.
Ms. Brown also felt that the Reedsville area offered her the type of support in raising
Benjamin that she needed. Ms. Brown is from this area and has extensive extended family in the
area. She lives very close to her mother and has already gained her support in providing
babysitting services while she works. Ms. Brown has secured a position with the Lewisberry
Hospital.
Mary does not feel that the move has to be overly disruptive to Mr. Brown's relationship
with his son. She argues that Mr. Brown had already disrupted that relationship when he elected
to move in with his fiance, Teresa Eriksen and her two children, Amanda and Andrew. She states
that Benjamin was having a very difficult time adjusting to Mr. Brown's new life style and that she
had discussed this problem with Mr. Brown. She also had Benjamin discuss this with him by
asking his father for more "one on one time" with him. According to Ms. Brown, Mr. Brown's
initial response to Benjamin was simply, "deal with it." It was not until after she moved that Mr.
Brown began to give Benjamin the type of attention that he was demanding. As a function of
that response Ms. Brown feels that by continuing the weekend visitation and' summer visitation
that Mr. Brown will be able to maintain the type of relationship that he had had with his son.
RECOMMENDATIONS:
There is no question that Mary Brown unilaterally decided to move to Reedsville without
a careful consideration of the impact of that move on Mr. Brown's relationship with Benjamin.
Furthermore, she asked for no input from Mr. Brown for this decision despite the fact that he had
shared legal custody. In so doing, she demonstrated an unwillingness to work within the
framework of her previous agreement when making major decisions affecting Benjamin.
The result of this decision making process was to anger Mr. Brown and cause him to sue
for primary custody. His anger appears justified when it comes to these particular decisions.
Nonetheless, his ability to take over the role of primary custodian is not strongly supported in the
current evaluation.
The interviews and testing of Benjamin clearly demonstrate the stronger primary bond
Benjamin has to his mother. On the Bricklin Perceptual Scales Benjamin showed a strong
preference for his mother's care over his father's. This was true in all of the areas measured by
this scale. It should be noted that Benjamin's responses do not demonstrate alienation from his
Page 4
RE: Brown v. Brown
father. That is, Benjamin sees his father as fairly competent in taking care of his needs. However,
he sees his mother as being more prepared and more competent in almost all of these areas. This
fact is further validated by Benjamin's responses on the Parent Report Cards. Although he scores
both of his parents relatively high in their ability to care for him, again, the marks are consistently
higher for mother than father.
Mr. Brown is concerned that Ms. Brown is inlluencing the way in which Benjamin is
perceiving him and his household. To some extent that may be correct, but that does not detract
from the fact that Benjamin is more closely bonded to his mother. He has been in her primary
care for ten years and has spent very little time away from her. In fact, for a very long time Mr.
Brown rarely had Benjamin overnight away from Ms. Brown's home. Even during their
separation, Mr. Brown spent a significant amount of time at Ms. Brown's residence visiting with
Benjamin.
In Benjamin's individual interviews he reinforces the fact that he prefers living at his
mother's residence. He states t~at he likes Reedsville and particularly likes his new school. He
feels that he has an opportunity there to make new friends and that in general his school days are
more fun. He indicates that his mother helps him with his homework and that she does a good job
in making sure that he is clean and neat when he goes to school. This is a direct contradiction of
one of Mr. Brown's concerns. Benjamin was also able to talk about the fun that he has with his
father when he visits him. His feelings about Teresa and her children are of Ii more neutral bent.
He sees positive things and negative things in his relationships with these individuals. He
definitely prefers some ofhis time alone with his father.
Another serious concern regarding Mr. Brown's ability to be primary caretaker has to do
due with the fact that he does not currently have a Pennsylvania driver's license. Mr. Brown is a
"habitual offender" of the driving laws in Pennsylvania. He has had his license suspended on
multiple occasions for both point aceumulation due to speeding and for driving under the
inlluence. Although Mr. Brown is currently not driving, he has in the past driven while his license
was under suspension. This has just prolonged the amount of time that he will have to go without
a license.
Besides the obvious problems that this creates in terms of transportation for himself and
Benjamin, it also raises questions regarding his general attitude about the law and the type of
model he presents with respect to that. He states that he now does not want to present that
model to Benjamin and his change in attitude is to Mr. Brown's credit. Nonetheless, one is left
with the practical problems of him being able to provide timely transportation for Benjamin for a
number of possible situations. At this point in time he relies heavily on Teresa to provide
transportation for him. However, Mr. Brown has stated that part of the reason he does not get
Benjamin on Friday evenings is because he feels badly asking Teresa to make the long ride to
Page 5
RE: Brown v. Brown
Reedsville to pick-up Benjamin. This type of reliance on others to provide transportation does
not seem like the best solution when it comes to Benjamin's needs.
There is also a problem with Mr. Brown's work schedule. Mr. Brown works in the
Lancaster area but lives in Camp Hill. He must leave for work at 5:30 am every day and does not
arrive home until 3:30 or 4:00 pm. His current plan with regards to Benjamin would be to leave
him alone from 5:30 am until 8:05 am when he would go to school. His rationale for this is that
Mary currently does it when she has to work a morning shift. However, he contradicts himself
when he raises a serious concern regarding the time that Benjamin has to spend alone while at his
mother's.
Mr. Brown's only option ifhe were to send Benjamin to school in the West Shore District
would be to try to find a latch key program that opens that early. This would put a tremendous
burden on Benjamin to have to get up that early each morning. Another option is to try to enroll
Benjamin in the Manheim School District. That is where Teresa's children currently go to school
from her mother's home. However, in choosing this option Benjamin would be forced to go to
school somewhere different from where his father lives. He would not, therefore, be sharing
school with children in his own neighbor. This could have negative effects on his friendships.
Given the problems that Benjamin has had in making friends at school, this does not seem to be a
good option.
When one looks at the primary bonding, the ability to parent, Benjamin's perceived
relationship with his parent's and the situational factors involved in being the primary custodian,
the most reasonable custodial arrangement to best meet Benjamin's needs is to leave him in the
primary custody of his mother during the school year. In making this recommendation, however,
it is important to note that by moving to Reedsville Ms. Brown has significantly affected Mr.
Brown's ability to interact with his son. Therefore, it is recommended that primary physical
custody of Benjamin should be reversed during the summer recess period such that Mr. Brown
becomes the primary custodian.
During the summer, Ms. Brown should be allowed alternate weekend visitation from
Friday afternoon until Monday morning as well as two weeks of uninterrupted vacation. During
the school year, Mr. Brown should be granted alternating weekend visitation with his son. If
possible, the alternating weekends should be fashioned to include as many three day weekends as
possible. Additionally, he should share equally in all holiday and school recess time. Time missed
due to weather related conditions should be made up on other weekends.
Ms. Brown should be responsible for the majority of transportation during the school year.
By accepting this responsibility she will be demonstrating to Benjamin how important his time
with his father is. Transportation for summer access should be shared equally between the
parents. During the school year Mr. Brown should be made aware of all of Benjamin's activities
x
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
MARY G. BROWN
Plaintiff
No 509 S of 1997
VB.
CIVIL - CUSTODY
ROGER A. BROWN, JR.
Defendant
PRAECIPE
PLEASE WITHDRAW THE APPEARANCE OF GARY L. KELLEY, ESQ. ON BEHALF OF
THE DEFENDANT, ROGER A. BROWN, JR. IN THE ABOVE CAPTIONED MATTER.
G~RL.
ALEY
PLEASE ENTER THE APPEARANCE OF M. LUCILE SEAMAN, ESQ. ON BEHALF OF
THE DEFENDANT, ROGER A. BROWN, JR., IN THE ABOVE CAPTION ACTION.
TO: PROTHONOTARY
DATE: la/d1/el?
C E SE
RNEY I. D. 67907
TTORNEY FOR PLAINTIFF
RHOADS & SINON
15 N. LIME STREET
LANCASTER, PA 17602
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MARY G. BROWN.
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
i'
I
vs.
97-509 CIVIL TERM
ROGER A. BROWN. JR..
Defendant
CIVIL ACTION - CUSTODY
ORDER
AND NOW, this
ur
-. day of September. 1997. at the request of counsel forthe
defendant. hearing in the above captioned mailer set for September 5. 1997. is continued to
Wednesday, December 3. 1997, at 9:30 a.m. in Counroom Number 4. Cumberland County
Courthouse. Carlisle. PA.
BY THE COURT.
John Connelly. Jr.. Esquire
For the Plaintiff
- C"tfu4..I()),€\.j,cl
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7A.Hess.J.
cr/'tjq'l.
...b'li'.
M. Lucile Seaman. Esquire
For the Defendant
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f1.,\{ fro 6,,,...'1
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
A.
V
R'-J'.J 11 1r..
/
Defendant
.
.
*
Ro~ ('
:CIVIL ACTION - LAW
:NO. ro 1 CIVIL
:CUSTODY/VISITATION
19q 7
ORDER OF COURT
AND NOW, this (date) l/l/t/'l , upon consideration of the
attached complaint, it is hereby directed that the parties and
their respective counsel a[}pear ,before n :(L.~I ~. 8'"t~ . (i~. ,
the conciliator, at ),0:1.'>. IS' S+, ("~~I~.'ll .
on the I), t" day of f1 .Ii h , 19 q I , at 11 00 P.t1.
H., for a Prehearing 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~y the court, and to enter into a temporary order. Either
party may bring the child who is the subject of this custody
action to the conference, but the child/children's attendance is
not mandatory. Failure to appear at the conference may provide
grounds for entry of a temporary or pexmanent order.
FOR THE COURT:
By: ~/ ~ ~C~1
Custody Conciliator ~i
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, FOURTH FLOOR
CARLISLE PA 17013
(717)240-6200
I
I
NAME
RESIDENCE
DATE
Mary G. Brown (mother) 1040 Teakwood Ln.
Barb Torchia (friend) Enola, Pennsylvania
Julia & Susan Torchia (friend's daughters)
08/92 - 05/93
Mary G. Brown (mother)
158 South Enola Dr.
Enola, Pennsylvania
05/93 - Present
The mother of the child is Mary G. Brown, currently residing at 158 South Enola
Drive, Enola, Pennsylvania. She Is divorced.
The father of the child Is Roger A. Brown, Jr., currently residing at 13 Marshall
Drive, Camp Hill, Pennsylvania. He is divorced.
4. The relationship of Plaintiff to the child Is that of mother. The Plaintiff
currently resides with the following person/persons:
NAME
RELATIONSHIP
Benjamin R. Brown
Son
5. The relationship of Defendant to the child is that of father. The
Defendant currently resides with the following person/persons:
NAME
RELATIONSHIP
Theresa and Her Son and Daughter
Girlfriend
6. Plaintiff has participated as a party or witness, or In another capacity, In
other litigation concerning the custody of the child In the Court of Common Pleas,
Dauphin County, Pennsylvania, indexed to No. 4221 S 1987. 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.
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8. On Fchruary 20. 19'17. I'lIun:111' wllcd Dcfcndanlulllls plucc of cmployment and
informcd him thut shc would hc relocutlng flllm thc IIICU und would hc withdrawing the minor
child from thc 4th gmdc of Ihc Easl I'cnnsholll Flc'/IIcnllllY School on or uhout Fcbruary 27,
)997
9, Thc I'lulntlff rcfnscd 10 plllvlllc uny spcclflCS rcgard/llg thc withdrawal and
subsclJucnt relocutlon USldc from IIlfolllung Dcfcndunt Ihul shc wuuld bc rclocating to the
Lcwistown lIrcll
10, I'I1IIntlff has rcfuscd 10 diSCUSS thc reloClltlon wilh Dcfcndant and refuses to confer
wllh him rcgardlllg Ihc rclocutlon
I J. I'I:untlff hlls u/lllalcmllv dcwlcd Ihal shc will rcloclltc and withdraw the minor
child frolll Ihc Easl I'cnnsholll I'Iclllcnlary School wllhoUI consulting with Defendant and has
suhsclJucntly wllhdrawn Ihc nunlll child fllllll school
12. 1'llIIntlfl's altlons :uc wntlal\' and vlolatlvc of thc cxprcssed tcrllls of thc parties'
~larrrllgc SClllclllcnl Aglc'clllcnl
13. I'l1IIntlfl's actlllllS mc conlr:uy 10 Ihc hcst IIllercst lInd pcrmllncnt welfarc of the
Illllllll child
14. I'lallltlfl's actions arc dlSlllplll'C 10 Ihc schooling of Ihc Illinor child.
l!i. Dcfcndanl hellcvcs and Ihcrcfillc avcrs Ihal I'I1Iintiff hlls undertaken the instant
nlllvc on a Whllll and wllhoUI applopnalc wnSldcmtlon of 1I11 partics' interests.
II.. WllhoUI Ihc Intcrvcntlon of Ihls "onomhle Court, Defendant believes that the
I'I:nntlff Will 1ll0W Ihc child wnlrlll)' to thc proVISions of the parties' Agreement and will
nnllalCllllly 1IltCI thc IC/Ills Ill' Dcfcndant's penods of partial physical custody.
17. rhc InSl:/IIllllallc'1 IS schcdulcd fill a Custody Conciliation beforc Michael Bangs,
14. ell I LlJRF.N
A. CUSTODY AND VISITATION - Parties do hereby agree that an
action in custody was brought in the Court of Common Pleas of
Dauphin County under Docket No. 4221-S-1987 by Mary G. Brown
a.a1nat R0ger A. Brown, Jr. The Parties agree to modify the
pnt1tt.I~". or th.t Ortl,.r in thf! following way:
I, I'rl""uy "hyniclIl custody shall be with the mother, Mar.y
G. Brown.
2. The Parties shall share legal custody of the child with
regard to decision making custody equally by both mother and
father.
3. Tho Father shall have periods of partial custody under
the following schedule:
a. The Father shall have the child one to two nights
per week through the week. The Father shall also have the child
every other weekend beginning on Friday evening and ending on
Sunday evening.
b. The Parties agree to alternate holidays and to
alternate Christmas in such a way that Christmas Eve through
Christmas Day at noon shall be with the mother for 1989 and
Christmas Day through December 26, at 8:00 p.m. shall be with the
father for 1989. This shall rotate in the future.
B. VISITATION MAKE-UP TIME - The parties recognize that
there may be circumstances from time to time which may prevent
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tile "ll..r.'lll.. CJt \'llllt4tlon .,t tIlt.' /"J"....d dates and times. To
that end, the parties agree that each will give timely and
reasonable notice to the other of the existence of such
circumstances.
C. ILLNESS OF CHILD - In the event of any serious illness
or .... rhi 1" .t .ny t ,...., Ilnj' ('Ilrt)' th,'n h.winq cU!ltody lof th..
..Ill,1 child shill! imm,'diat.-ly communicate with the other party by
telephone or any other means, informing the other party of the
nature of the illness.
During such illness, each party shall
have the right to visit the child as often as he or she desires,
consistent with the proper medical care of the said child. The
word "illness" as used herein shall mean any disability which
confines the child to bed under the direction of a licensed
physician for a period in excess of forty-eight (48) hours.
D. BEST INTEREST OF CHILD - The parties shall exert every
reasonable effort to maintain free access and unhampered contact
between the child and each of the parties, and to foster a
feeling of affection between the child and the other party.
Neither party shall do anything which may estrange the child from
the other party, or injure the child's opinion as to his mother
or father, or which may hamper the free and natural development
of the child's love and respect for the other party.
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5. The Plaintiff's position on custody is as follows: Plaintiff indicated that
she has been the primary care taker of the child. She moved with the minor child
back to her home town of Lewistown because the child was not doing well here
and that she had a better support system from her family in her home town. She
reports that the child is doing well and is thriving in his new environment. She
believes that an appropriate order would be for her to maintain primary custody
with an appropriate visitation schedule with Father. Because the Father does not
have a driver's license, the Mother proposes that she bring the child down when
she comes down to work here in town on an every-other weekend basis. She
works a separate job in the Camp Hill area at a nursing facility and maintains full
employment in her home town of Lewistown.
6. The Defendant's position on custody is as follows: Mother moved the
child away from him without his consent and that as a result he should have
primary custody of the child. He related that he first made a move from Lancaster
County to Camp Hill as a result of the Mother's move with employment. Now that
Mother has moved to Lewistown it has prevented him from having access with the
child on a regular basis. Father's solution to that is that he should have primary
physical custody of the child.
7. Need for separate counsel to represent child{renl: Neither party
requested.
8. Need for independent psychological evaluation or counseling: See
attached Order.
9. A hearing in this matter will take one day.
10. Other matters or comments: The child who is the issue in this case is
eleven years old. Apparently the child was having some behavioral problems in the
East Pennsboro Township school and was initially diagnosed with A.D.D. Mother
was quite concerned by this diagnosis and felt that her child was not getting the
proper attention at school. Because of the upheaval between the parties, Mother
decided to move with the child to her home town of Lewistown where she had a
support network set up.
Father was quite agitated by the move and believes that it was solely an
attempt by her to remove the child from him. Father does not have a driver's
license and apparently will not have it restored for quite some time. Therefore
transportation is an issue in this case.
The court needs to determine if the child is in fact doing well in his new
environment. If the child is doing well, then an appropriate visitation schedule
needs to be set up with Father taking into account his inability to provide
transportation for the periods of partial custody and visitation. If the child is not
doing well, then the court must make a determination as to whether or not moving
the child back to this county is appropriate.
The parties at the conciliation agreed to engage the services of a
psychologist who should be able to assist the court in determining how the child is
doing in his new environment.
Date: April 9, 1997
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Michael L. Bangs
Custody Conciliator
-
MARY G. BROWN.
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYL VANIA
\'S.
97-0509 CIVIL
ROGER A. BROWN. JR..
Dcfcndant
CIVIL ACTION - CUSTODY
ORDER
AND NOW. this
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day of January. 1998, allcr hcaring and careful
considcration of the tcstimony adduccd. it is ordcrcd and directcd that:
I. The partics shall havc sharcd Icgal custody of the minor child. Benjamin R. Brown,
born Decembcr 15, 1986. Each parent shall havc the right to participatc in thc major decisions
effccting the child including, but not Iimitcd to, mcdical. religious and educational.
2. Thc mother shall havc primary physical custody of Bcnjamin R. Brown.
3. Partial physical custody of Bcnjamin R. Brown is grantcd to the father. as follows:
a. Threc out of four wcckends bascd on thc mothcr's work schedule from Saturday
morning at 6:00 a.m. until Sunday cvcning at 7:00 p.m. Thc plaintiff shall provide all
transportation for thc periods of partial custody pursuant to this paragraph. In the cvent
thc dcfendant wishcs to sccure custody on Friday cvcning. hc shall mcct thc plaintiff half-
way bctwccn the plaintill's homc and dcfcndant's home at a location and timc agrecd
upon by the parties.
b. During thc summer school vacation of thc minor child, thc dcfendant shall have a
pcriod of custody bcginning on Saturday morning at 6:00 a.m. of Fathcr's Day wcckcnd
and cxtending until onc wcck bclorc school bcgins. Thc mother shall havc partial
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physiclll custody on onc lour-dllY wcckcnd out of cllch Illllr-wcck pcriod during thc
summcr. Euch purcnt shllll hllvc onc wcck of unintcrruptcd vlIclltion with thc child
during summcr vlIclItion with thirty dll)'s' noticc 10 thc othcr purcnt.
c. Whichcvcr pllrcnt hus thc child for thc wcckcnd, thllt parcnt shlllllllso 11lIvc thc
holidllYs of ElIstcr. Memoriul DlIY and LlIbor Du)'. Should thc lathcr's wcckcnd bccome
thus cxtcndcd, thc child shall bc rcturncd by thc partics mccting hlllfway liS sct forth in
pllragraph a.
d. Thc plaintiff shllll havc thc TlllInksgiving holiduy including thc wcckcnd in odd-
numbcred ycars and thc dcfcndant in cvcn-numbcrcd ycars. Thc partics shall divide thc
Christmas holiduy and vacation as follows:
(I) Aftcr school on thc child's last duy of school until halfway through the vacation,
with thc mothcr in cvcn-numbcrcd ycars and thc lathcr in odd-numbcrcd ycurs.
(2) Thc cnd of the vacation pcriod untilthc child rctums to school shllll be in thc
othcr parent.
c. Unless othcrwisc agreed, the mothcr shull havc custody on Mother's Day.
4. Unlcss othcrwisc notcd abovc. transportation shall bc uccomplished cithcr by the
parties mceting halfway or by rcquiring transportation on thc part of thc parcnt rccciving
custody, at the option of thc dcfcndunt.
5. Both parents shall pcrmil reasonablc tclcphonc acccss to thc child whcn the child is in
his or hcr custody. Thc parcnts arc cncouragcd 10 accommodatc thc rcasonablc rcqucsts of the
othcr parent lor 1Iltcrations ofthc schcdulc liS thc circumstanccs and bcst intercsts ofthc child
rcquirc. Both parcnts shllll cncouragc thc child to lovc lInd rcspcct thc othcr lInd shall not statc
physical cuslody 01l011l' lilllr-day WCCKl'lId 011101' ,'ach linlr-wcck pcriod dllrillg thc
summcr. Each parcnt shall havc onc Iwck of unintcrruptcd I'acationwith lhc child
dlll'ing summer vaealionwilh Ihirly days' noticc to thc other parcnt.
c. Whichever parcnt has thc child lor Ihc wcckcnd, that p.lrcnt shall also havc the
holidays of Easter, Mcmori.11 Day and Labor Day. Should the lillher's wcckend become
thus extcnded, thc child shall bc returncd by the parties meeting hall\l'ay as set forth in
puragraph a.
d. The plaintiff shall have the Thanksgiving holiday including the weekend in odd.
numbered years and the defcndant in evcn-numbered years. The panics shnll divide the
Christmas holiday and vacation as follows:
(I) Alier school on the child's last duy of school until halfway through the vacation,
with the mother in even-numbered years and the fnther in odd-numbered years.
(2) The end of the vacution period until the child returns to school shall be in the
other parent.
c. Unless otherwise agrccd. the mother shall havc custody on Mother's Day.
4. Unless otherwise noted above. transportation shall be :Iccomplished eilher by the
panics meeting hal fway or by requiring tfUnsponation on the part of the parent receiving
custody, at the oplion of the defendant.
5. Bolh parents shall permit reasonable lelephone access 10 the child when the child is in
his or her ellstody Thc parellts arc encouraged 10 accommodatc the reu"'lIahle requests oftl1\:
other parelll lor .lllerallolls ollhc sehedll'" as the ein:umstal1l:es alld hest interests of Ihe child
leqllir<: I\olh pMellls skrll ellcollral'e Ihe child III 1\lle alld respeellhc lither alld shallllo( slale
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6:00 a.m. until Sunday evening at 7:00 p.m. Mother
shall provide all transportation for the periods of
partial custody pursuant to this paragraph. In the
event Father wishes to secure custody on Friday
evening, he shall meet Mother halfway between
Mother's home and Father's home at a location and
time agreed upon by the parties.
2. Paragraph 5 of the Order shall be modified as follows:
Both parties shall permit reasonable telephone
access to the child when the child is in his or her
custody. Both parents are required to return all phone
calls to the other parent within twenty-four (24) hours
of when the phone call was placed to the other parent or
child. The parents are encouraged to accommodate the
reasonable requests of the other parent for alterations
of the schedule as the circumstances and best interests
of the child require. Both parties shall encourage the
child to love and respect the other and shall not state
nor permit others to state, in the presence of the child,
derogatory comments about the other parent. Both shall
encourage the child to have significant contact with the
other parent.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
MARY G. BROWN
Plaintiff
vs.
No. 509 CIVIL 1997
CUSTODY
ROGER A. BROWN
Defendant
ORDER
You MARY G. BROWN,
custody, partial custody
BENJAMIN R. BROWN.
have been sued in Court to obtain
or visitation of the following child:
1
of
to appear in person
Courthouse Square,
at the Cumberland
You are ordered
county Courthouse,
the_______day
at o'clock
Carll.sle,
PA, on
20___,
held in
---------------------,
_M.,
for
a
conference to be
Conference
Officer
If you fail to appear as provided by this order, an order
for custody, partial custody or visitation may be entered
against you or the court may issue a warrant for your arrest.
Room
No.
before
custody
Conference
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
District Court Administration Office
Cumberland County Courthouse
4th Floor
Carlisle, PA 17013
Telephone (717) 240-6200
AMERICANS WITH DISABILITIES
ACT OF 1990
THE COURT OF COMMON PLEAS OF LANCASTER 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 THE COURT ADMINISTRATION
OFFICE. ALL ARRANGEMENTS MUST BE MADE AT LEAST 72 HOURS PRIOR
TO ANY HEARING OR BUSINESS BEFORE THE COURT. YOU MUST ATTEND
THE SCHEDULED CONFERENCE OR HEARING.
BY THE COURT:
DATE:
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MARY G. BRCMN, . IN THE OOURT OF C'alMOO PLEAS OF
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. . NO. 97-0509 CIVIL TERM
.
:
ROGER A. BRGIN, JR., . CIVIL ACTION - LAW
.
Defendant : CUSTODY
au>BR OF <XXlRT
AND to, this 1'1-
consideration of the attached
and directed as follows:
-
day of oJ.......... , 2000, upon
Custody Conciliation Report, it is ordered
1. '!tie parties shall submit themselves and their minor O1ild to a
supplemental custody evaluation to be performed by Arnold Shienvold, PhD.,
who performed a previous evaluation in 1997. '!tie purpose of the evaluation
shall be to address current concerns regarding custody of the Child in
light of recent developnents and to obtain professional recccrmendations
with respect to custody. Each party shall be responsible for one-half of
the costs of the supplemental evaluation. '!tie parties shall sign any
necessary authorizations to enable the evaluator to obtain educational
records and information pertaining to the Child and any other information
deemed necessary by the evaluator. Each party shall schedule his or her
initial appointment with the evaluator within 6 weeks of the date of this
Order.
2. Within 3 months of completion of the evaluation, and in the event
the parties are not at that time able to reach an agreement regarding
ongoing custody arrangements, counsel for either party may contact the
Conciliator to schedule an additional Custody Conciliation Conference.
3. Pending further Order of Court or agreement of the parties, the
prior Orders of this Court dated January 16, 1998 and June 18, 1999 shall
continue in effect.
BY THE OOURT,
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cc: M. Lucile Seaman, Esquire - Counsel for Father
Randall E. Zimmerman, Esquire - Counsel for Mother
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Exhibit A
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MARY G. ~, . IN THE 0XlRT OF CDoll>lCN PLEAS OF
.
Plaintiff . CUMBERLAND COONTY, PENNSYLVANIA
.
.
.
VS. . NO. 97-0509 CIVIL TERM
.
.
.
ROGER A. ~, JR., : CIVIL AC'l'IOO - LAW
Defendant . CUSlalY
.
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auIlR OF CXlR1'
AtI) 10, this ~ day of -r. I · (e.. , 2000, upon
COI'lllideratioo of the attached CUstody Concii't:tfcn Report, it is ordered
and directed as follOlls:
1. 'ltie parties shall sul::rnit th_lves and their minor Olild to a
supplemental CUlltody evaluatioo to be performed by Arnold Shienvold, PhD.,
who performed a pl:'evious evaluation in 1997. 'ltie purpose of the evaluatioo
shall be to adclrellB current concerns regarding CUlltody of the Olild in
light of recent developnents and to obtain profellBional recomnendatiOl'l8
with respect to CUlltody. Each party shall be respon!Iible for ooe-half of
the costs of the supplemental evaluation. 'ltie parties shall sign any
necessary authorizatiOl'l8 to enable the evaluator to obtsin educational
records and information pertaining to the Olild and any other information
deemed necessary by the evaluator. Each party shall schedule his or her
initial appointment with the evaluator within 6 weeks of the date of this
Order.
2. Within 3 months of COlIpletion of the evaluation, and in the event
the parties are not at that time able to reach an agreement regarding
ongoing CUlltody arrangements, counsel for either party llI/lY contact the
Conciliator to schedule an additional CUstody Conciliation Conference.
3. Pending further Order of Court or agreement of the parties, the
prior Orders of this Court dated January 16, 1998 and June 18, 1999 shall
continue in effect.
TRU:; C'"'l'Y r:lr:"'. ~!:CORD
In TcEtirrlcl'.... . r:..:'.~~f, I n r "J :.:1 t,:'{ hand
end the S€:5' said Courl Jl Cdrli,iJ, Pa.
Th'}f)....l~L. ~~.:r.UJ.le..../ptQO
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rOlhonolary
BY THE 0XlRT,
'SI~.lL,
Kevin . Hess,
J.
cc: H. Lucile Seeman, Esquire - COUnsel for Father
Randall E. zirrmlrman, Esquire - COUnsel for Mother
....
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6:00 a.m. until Sunday evening at 7:00 p.m. Mother
shall provide all transportation for the periods of
partial custody pursuant to this paragraph. In the
event Father wishes to secure custody on Friday
evening, he shall meet Mother halfway between
Mother's home and Father's home at a location and
time agreed upon by the parties.
2. Paragraph 5 of the Order shall be modified as follows:
Both parties shall permit reasonable telephone
access to the child when the child is in his or her
custody. Both parents are required to return all phone
calls to the other parent within twenty-four (24) hours
of when the phone call was placed to the other parent or
child. The parents are encouraged to accommodate the
reasonable requests of the other parent for alterations
of the schedule as the circumstances and best interests
of the child require. Both parties shall encourage the
child to love and respect the other and shall not state
nor permit others to state, in the presence of the child,
derogatory comments about the other parent. Both shall
encourage the child to have significant contact with the
other parent.
'.
physical custody on one lilur-day wcckcnd out of each lilllr-week pcriod during Ihe
summcr. Each parent shall hal'e one wcek of uninll'lTupted I'acation with the child
during summer vacalion with Ihirty days' notice to Ihe other parent.
c. Whichel'er parent has thc child for the weckend, that parent shall also have thc
holidays of Eastcr, McmoriallJay and Labor Day. Should thc father's wcekcnd bccome
thus extended, thc child shall be rcturned by thc partics mceting halfway as set forth in
paragraph a.
d. The plaintiff shall hal'c the Thanksgiving holiday including the wcckend in odd-
numbered years and thc defcndant in even-numbered years. The parties shall divide the
Christmas holiday and vacation as follows:
(1) After school on the child's last day of school until halfway through the vacation,
with the mothcr in even-numbered years and the father in odd-numbered years.
(2) The cnd of the I'acation period until the child returns to school shall be in the
other parent.
e. Unless otherwisc agrccd. the mother shall havc custody on Mother's Day.
4. Unless otherwise noted abol'c, transportation shall be accomplishcd cither by the
parties mccting halfway or by rcquiring transportation on thc part ofthc parent receiving
custody, at thc option of the defcndant.
5. Both parents shall pcrmit reasonable telephone access to the child when the child is in
his or her custody. The parents arc encouragcd to accommodatc thc rcasonable rcquests ofthc
othcr parent for allerations of the schedule as the circumstances and hc~a intercsls of thc child
requirc. lIolh parents shall encourage the child Illlo\'e and respecllhe othcr and shall not slnte
, ,
1 '
MARY G. BROON,
Plaintiff
IN THE CXlURT OF cnIMOO PLEAS OF
: CUMBERLAND COONT'l, PENNS'lLVANI.~
.
.
vs.
NO. 97-0509 CIVIL TERM
.
.
ROGER A. BROON, JR.,
Defendant
: CIVIL ACTION - LAW
IN CUSTODY
.
.
aIDER OF CXXlRT
AND toI, this Z,... day of NDvt,..,I,<-
upon consideration of the attached Custody Conciliation
ordered and directed as follows:
, 2000,
Report, it is
1. The prior Orders of this Court dated Noverr.ller 9, 2000, June IB,
1999, and January 16, 1998 are vacated and replaced with this Order.
2. The Mother, Mary G. Brown, and the Father, Roger A. Brown, Jr.,
shall have shared legal custody of Benjamin R. Brown, born December 15,
1986. 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.
3. - The parties shall have physical custody of the Child in accordance
with the following schedule:
A. During the school year, the Father shall have primary
physical custody of the Child and the Mother shall have
partial custody on alternating weekends from Friday evening
at an agreed upon time through Sunday at 6:00 p.m., begiming
Friday, January 5, 2001. The alternating weekend schedule
shall be adjusted so that the Mother has custody of the Child
on all school holidays, including inservice or conference
days. In the event the school holiday falls adjacent to a
weekend which would otherwise have been the Father's regular
weekend period of custody, the Mother shall have custody for
the entire weekend and the parties shall exchange an
additional weekend to continue the schedule on the same
alternating cycle.
B. During the summer school vacation, the Mother shall have
primary physical custody of the Child and the Father shall
have custody on alternating weekends from Friday through
Sunday. The summer custody schedule shall begin with the
Mother having custody on the first Friday after the last day
of school. The school year schedule shall resume with the
Father having custody of the Child on the last full weekend
before school starts.
4. The parties shall have custody of the Child on holidays as
follows:
A. aIRISTMAS: The Christmas holiday shall be divided into
Segment A, which shall run from after school on the Child's
last day of school until halfway through the vacation, and
Segment B, which shall run from halfway through the vacation
period until the Child returns to school. The Mother shall
have custody of the Child during Segment A in even numbered
years and during Segment B in odd numbered years. The Father
shall have custody of the Child during Segment A in odd
numbered years and during Segment B in even numbered years.
Notwithstanding the foregoing, begiming in 2001, the Mother
shall have custody of the Child for 7 consecutive days during
her Segment of the Christmas holiday.
B. THANKSGIVING: The Father shall have custody of the Child
over the entire Thanksgiving school break in even numbered
years and the Mother shall have custody of the Child during
the entire Thanksgiving school break in odd numbered years.
C. BASTER/HIKIUAL DAY/LA!lCR DAY: The Mother shall have custody
of the Child every year over the Child's Easter school break
and over the Memorial Day and Labor Day weekend from Friday
through Monday.
D. JULY 4th: In odd numbered years, the Father shall have
custody of the Child for 3 days over the July 4th holiday,
and in even numbered years, the Mother shall have custody of
the Child for 3 days over the July 4th holiday.
E. ID.l'fIF2{'S DAY/FATHER'S DAY: The Mother shall have custody of
the Child over the Mother's Day weekend from Friday through
Sunday every year and the Father shall have custody of the
Child over the Father's Day weekend from Friday through
Sunday in every year.
F. The holiday custody schedule shall supersede and take
precedence over the regular custvdy schedule.
5. Each party shall be entitled to have custody of the Child for two
non-consecutive weeks during the summer school break each year upon
providing at least thirty days advance notice to the other party. The
party providing notice first shall be entitled to preference on his or her
selection of vacation dates under this provision.
6. The parties shall exchange custody of the Child at a mutually
agreeable halfway point between their residences.
7. Each party shall permit reasonable telephone access to the Child
when the Child is in that party's custody. Both parties shall return all
telephone calls to the other parent within 24 hours.
8. The parties are encouraged to accommodate the reasonable requests
of the other party for adjustments to the custody schedule as the
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