HomeMy WebLinkAbout02-5868MELISSA D. JACOBS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
IN CUSTODY
GLENN A. WOMER, r ?.? to
Defendant NO. CIVIL TERM
COMPLAINT FOR CUSTODY
The plaintiff, Melissa D. Jacobs, by her attorneys, the Family Law Clinic, sets forth the
following cause of action:
1. The plaintiff is Melissa D. Jacobs, residing at 905 North Arch Street, Mechanicsburg,
Cumberland County, Pennsylvania, 17055.
2. The defendant is Glenn A. Womer, residing at 5041 5t° Avenue, Lake Ariel, Wayne
County, Pennsylvania, 18436.
3. Plaintiff seeks custody of the following children:
Name Present Residence
Date- of Birth
Matthew Jacobs-Womer 905 North Arch Street, Mechanicsburg, PA
9/17/98
Amanda Jacobs-Womer 905 North Arch Street, Mechanicsburg, PA
7/8/01
The children were born out of wedlock.
The children are presently in the custody of Melissa D. Jacobs, who resides at 905 North
Arch Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055.
During the past four years, the children have resided with the following persons and at the
following addresses:
Persons Address
1) Matthew Dates
Melissa Jacobs 905 North Arch Street, Mechanicsburg, PA
Lloyd D. Jacobs Weekdays, 6/99 - 6/00
Diane L. Jacobs
Glenn Womer
and Melissa Jacobs 12 W. State Street, Delmar, MD 21825
Weekends,6/99 - 2/00
Glenn Womer
and Melissa Jacobs 7050 Sixty Foot Road, Pittsville, MD 21850
Weekends, 2/00 - 6/00
Melissa Jacobs 905 North Arch Street, Mechanicsburg, PA
Lloyd D. Jacobs 6/00 - currently
Diane L. Jacobs
2) Amanda
Melissa Jacobs 905 North Arch Street, Mechanicsburg, PA
7/8/01 -currently
The mother of the children is Melissa Jacobs, currently residing at 905 North Arch Street,
Cumberland County, Pennsylvania, 17055.
She is single.
The father ofthe children is Glenn Womer, currently residing at 5041 5'Avenue, LakeAriel,
Wayne County, Pennsylvania, 18436.
He is married.
4. The relationship of the plaintiff to the child is that of mother. The plaintiff resides with
the following persons:
Name
Relationship
Lloyd D. Jacobs Father
Diane L. Jacobs
Mother
Matthew A. Jacobs
Son
Amanda R. Jacobs
Daughter
5. The relationship of defendant to the child is that of father
with the following persons:
Name Relationship
Maria Reakes Womer Wife
Elan Royster Step daughter
Anthony Royster Step son
Ryan C. Womer Son
Brandon M. Womer Son
The defendant currently resides
Jessica K. Womer Daughter
6. Plaintiff has not participated as a
party or witness, or in another capacity, in other
litigation concerning the custody of the children in this or another court.
Plaintiff has no information of a custody
court of this Commonwealth or any other state.
proceeding concerning the children pending in a
Plaintiff does not know of a person not a party to the proceedings who has physical custody
of the children or claims to have custody or visitation rights with respect to the children.
7. The best interest and permanent welfare of the children will be served by granting the
relief requested because:
a) Plaintiff has been the primary caretaker of the children since birth;
b) Plaintiff provides the children with a home with the necessary moral, emotional, and
physical surroundings to meet the children's needs;
C) Plaintiff continues to exercise parental duties on behalf of the children and enjoys the love
and affection of the children;
d) Plaintiff is willing to grant the father periods of partial custody in order for the children
to develop strong parent/child relationships with both parents.
8. Each parent whose parental rights to the children have not been terminated and the person
who has physical custody of the children have been named as parties to this action.
WHEREFORE, plaintiff requests the court to grant her primary physical custody of the
children.
Date: ?? n?,
Sara Myer
Certified Legal Intern
O PLACE
ROBER E. RAINS
LUCYJOHNSTON-WALSH
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/243-2968
VERIFICATION
I verify that the statements made in this Custod
of my personal knowled e y Complaint are true and correct to the best
g e belief. I understand that false statements herein are made subject to
the penalties of 18 Pa.C g 4904, relating to unswom falsification to authorities.
Date: Gad
Melissa D. Jacobs, Plainti ?
MELISSA D. JACOBS IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V. 02-5868 CIVIL ACTION LAW
GLENN A. WOMER
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Friday, December 20, 2002 , 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 Wednesday, January 15, 2003 at 10:30 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: /sl _fdcgueline 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
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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DEC 11 2002
MELISSA D. JACOBS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
IN CUSTODY
GLENN A. WOMER,
Defendant : NO. CIVIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Sherif:
Kindly allow Melissa D. Jacobs, Plaintiff, to proceed in forma pauperis.
The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies
that we believe the party is unable to pay the costs and that we are providing free legal service to
the parry.
Date ?a 02
Respectfully submitted,
?:L. Dj4??t-,
Sara Myer
Certified Legal Intern
THOMA PLACE
ROBERT E. RAINS
LUCY JOHNSTON-WALSH
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
on r
f v _?7
FEB 0 6 2003
MELISSA D. JACOBS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. :NO. 2002-5868 CIVIL TERM
GLENN A. WOMER, : CIVIL ACTION - LAW
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this -4` day of Fe.L w , 2003, upon
consideration of the attached Custody Conciliation Rep rt, it is ordered and directed as
follows:
1. The Mother, Melissa D. Jacobs, and the Father, Glenn A. Womer, shall
have shared legal custody of Matthew Jacobs-Womer, born September 17, 1998 and
Amanda Jacobs-Womer, born July 8, 2001. Each parent shall have an equal right, to be
exercised jointly with the other parent, to make all major non-emergency decisions
affecting the Children's general well-being including, but not limited to, all decisions
regarding their health, education and religion.
2. Mother shall have primary physical custody of the: Children.
3. Father shall have periods of partial physical custody of Matthew as follows:
A. Beginning March 1, 2003 and continuing thereafter every third weekend
from Saturday morning at a time agreed by the parties to Sunday at 5:30
p.m. This schedule shall continue for the months of March, April and
May, 2003.
B. Beginning June, 2003, and continuing thereafter every third weekend from
Friday at 6:00 p.m. to Sunday at 5:30 p.m.
C. Mother agrees to exchange weekends in the event Father is scheduled for
weekend guard duty on his otherwise custodial weekend. Father shall
provide Mother with at least one month advance notice of his selected
weekend. This paragraph contemplates Father having 17 weekends per
year.
4. Father shall have periods of visitation with Amanda when he picks up and
drops off Matthew for his weekends and other times agreed by the parties. It is agreed
that these times shall be expanded to partial physical custody including overnights as
Amanda matures.
5. The Christmas holiday shall be divided into two Blocks. Block A shall
be from Christmas Eve at 6:00 p.m. to Christmas Day at 6:00 p.m. and Block B shall be
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from Christmas Day at 6:00 p.m. to December 26 at 6:00 p.m. Mother shall have Block
A in odd numbered years and Block B in even numbered years. Father shall have Block
B in odd numbered years and Block A in even numbered years.
6. The Easter holiday shall be alternated with Father having custody in odd
numbered years and Mother having custody in even numbered years.
7. Thanksgiving shall be alternated with Mother having custody in odd
numbered years and Father having custody in even numbered years. However when
Mother has custody, Father may pick up the children on Thursday evening and extend his
weekend period of custody.
8. Mother shall have custody of the children on Mother's Day; Father shall
have custody of the children on Father's Day, both at times agreed by the parties.
9. For the summer of 2003, Father shall be entitled to two long weekends,
one for three overnights and one for four overnights. Thereafter, Father shall be entitled
to one uninterrupted week in the summer. Father shall provide Mother with 30 days prior
notice of the exercise of his summer periods.
10. Father shall be responsible for all transportation and agrees to minimize
the time the child/children will be in the car.
11. Mother shall have the right to inspect Father's home for appropriateness
and safety. This shall occur in February, 2003.
12. Father shall secure all guns, hunting knives, bow and arrows and tools so
that they do not pose a safety hazard to the children.
13. Father shall not smoke in the car while Matthew is in the vehicle.
14. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control.
BY THE COURT,
J.
cc: Sara Myer, certified legal intern, Counsel for M ther
Lucy Johnston-Walsh, Esquire, Family Law Clinic (x-d" o -C- 3-67-0-3
Mark F. Bayley, Esquire, Counsel for Father
MELISSA D. JACOBS,
Plaintiff
V.
GLENN A. WOMER,
Defendant
PRIOR JUDGE: None
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:2002-5868 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMAR YREPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Children who are the subject of
this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Matthew Jacobs-Womer September 17, 1998 Mother
Amanda Jacobs-Womer July 8, 2001 Mother
2. A Conciliation Conference was held in this matter on February 5, 2003,
with the following individuals in attendance: The Mother, Melissa D. Jacobs, with her
counsel, Sara Myer, certified legal intern and Lucy Johnston-Walsh, Esquire of the
Family Law Clinic and Father, Glenn A. Womer, with his counsel, Mark F. Bayley,
Esquire.
3. The parties agreed to the entry of an Order in the form as attached.
vl - 6 - c) 3
Date
cqu ine M. Verney, Esquire
Custody Conciliator
MELISSA D. JACOBS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2002-5868 CIVIL TERM
GLENN A. WOMER, : IN CUSTODY
Defendant : JUDGE: KEVIN A. HESS
PETITION FOR CONTEMPT
AND NOW, comes Glenn A. Womer, by and through his counsel, Michael O. Palermo,
Jr., Esquire and in support of his Petition for Contempt avers as follows:
1. There was a Custody Order entered on February 7, 2003, by the Honorable Kevin A.
Hess. Attached as Exhibit "A".
2. The aforementioned Order granted Petitioner, Glenn A. Womer periods of partial
custody of the minor child, Matthew Jacobs-Womer born September 17, 1998, every
third weekend for the months of March, April and May, 2003 from a time agreed
upon by the parties on Saturday mornings until 5:30 p.m. on Sunday. Beginning
June, 2003, petitioner had partial periods of custody every third weekend from Friday
at 6:00 p.m. to Sunday at 5:30 p.m.
3. Petitioner was granted periods of visitation with the minor child, Amanda Jacobs-
Womer born July 8, 2001, when he picked up the minor child, Matthew and other
times as agreed upon by the parties. Said visitation was to have been expanded to
partial physical custody including overnights as the child matured.
4. Petitioner asserts that he has only been allowed to see the minor children twice in a
two year period.
5. Respondent does not communicate with Petitioner regarding the whereabouts of the
children and does not allow visitation and custody as ordered by the Court.
6. On several occasions in front of witnesses, Respondent has instilled fear in both
minor children by telling them, that Petitioner would kidnap them and that they would
not see Respondent again.
7. Petitioner's attorney fees are in the amount of $500.00 to file this petition and attend a
subsequent hearing on the matter.
8. Petitioner believes and therefore avers that his attorney fees should be paid by
Respondent for being in contempt of this Honorable Court.
WHEREFORE, your Petitioner respectfully requests that this Honorable Court find the
Respondent in contempt of the Court Order entered on February 7, 2003, and grant Petitioner
liberal visitation with the minor children. This Honorable Court should also direct that
Respondent is responsible to pay attorney's fees in the amount of $500.00 to Petitioner's
attorney.
Date: WV. z sr .??+
Respectfully submitted,
ROMINGER & ASSOCIATES
Michael O Palermo, Jr., squire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 93334
Attorney for Petitioner
MELISSA D. JACOBS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2002-5868 CIVIL TERM
GLENN A. WOMER, : IN CUSTODY
Defendant : JUDGE: KEVIN A. HESS
CERTIFICATE OF SERVICE
I, Michael O. Palermo, Jr. Esquire, do hereby certify that I served a copy of the Motion
upon the following by depositing same in the United States mail, postage prepaid, , at Carlisle,
Pennsylvania. addressed as follows:
Melissa D. Jacobs
905 North Arch Street
Mechanicsburg, PA 17055
Dated: i0ov 4& .
Respectfully submitted,
ROMINGER & ASSOCIATES
Michael O. Pale , Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 93334
Attorney for Petitioner
MELISSA D. JACOBS,
Plaintiff
v.
GLENN A. WOMER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2002-5868 CIVIL TERM
IN CUSTODY
JUDGE: KEVIN A. HESS
VERIFICATION
I verify that the statements made in this complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to
unworn falsification to authorities.
Date: 1 07 JJ ?'," ?-
Glenn A. Womer, Petitioner
obo/? 3
FEB 0 6 2003 ft?
MELISSA D. JACOBS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2002-5868 CIVIL TERM
GLENN A. WOMER, : CIVIL ACTION - LAW
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this day of , 2003. upon
consideration of the attached Custody Conciliation port, it is ordered and directed as
follows:
1. The Mother, Melissa D. Jacobs, and the Father, Glenn A. Worrier, shall
have shared legal custody of Matthew Jacobs-Womer, born September 17, 1998 and
Amanda Jacobs-Womer, born July 8, 2001. Each parent shall have an equal right, to be
exercised jointly with the other parent, to make all major non-emergency decisions
affecting the Children's general well-being including, but not limited to, all decisions
regarding their health, education and religion.
2. Mother shall have primary physical custody of the Children.
3. Father shall have periods of partial physical custody of Matthew as follows:
A. Beginning March 1, 2003 and continuing thereafter every third weekend
from Saturday morning at a time agreed by the parties to Sunday at 5:30
p.m. This schedule shall continue for the months of March, April and
May, 2003.
B. Beginning June, 2003, and continuing thereafter every third weekend from
Friday at 6:00 p.m. to Sunday at 5:30 p.m.
C. Mother agrees to exchange weekends in the event Father is scheduled for
weekend guard duty on his otherwise custodial weekend. Father shall
provide Mother with at least one month advance notice of his selected
weekend. This paragraph contemplates Father having 17 weekends per
year.
4. Father shall have periods of visitation with Amanda when he picks up and
drops off Matthew for his weekends and other times agreed by the parties. It is agreed
that these times shall be expanded to partial physical custody including overnights as
Amanda matures.
5. The Christmas holiday shall be divided into two Blocks. Block A shall
be from Christmas Eve at 6:00 p.m. to Christmas Day at 6:00 p.m. and Block B shall be
from Christmas Day at 6:00 p.m. to December 26 at 6:00 p.m. Mother shall have Block
A in odd numbered years and Block B in even numbered years. Father shall have Block
B in odd numbered years and Block A in even numbered years.
6. The Easter holiday shall be alternated with Father having custody in odd
numbered years and Mother having custody in even numbered years.
7. Thanksgiving shall be alternated with Mother having custody in odd
numbered years and Father having custody in even numbered years. However when
Mother has custody, Father may pick up the children on Thursday evening and extend his
weekend period of custody.
8. Mother shall have custody of the children on Mother's Day; Father shall
have custody of the children on Father's Day, both at times agreed by the parties.
9. For the summer of 2003, Father shall be entitled to two long weekends.
one for three overnights and one for four overnights. Thereafter, Father shall be entitled
to one uninterrupted week in the summer. Father shall provide Mother with 30 days prior
notice of the exercise of his summer periods.
10. Father shall be responsible for all transportation and agrees to minimize
the time the child/children will be in the car.
11. Mother shall have the right to inspect Father's home for appropriateness
and safety. This shall occur in February, 2003.
12. Father shall secure all guns, hunting knives, bow and arrows and tools so
that they do not pose a safety hazard to the children.
13. Father shall not smoke in the car while Matthew is in the vehicle.
14. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control.
BY THE CMJRT,
/?11/ yl?w? (1). )4?? J.
cc: Sara Myer, certified legal intern, Counsel for Mother
Lucy Johnston-Walsh, Esquire, Family Law Clinic
Mark F. Bayley, Esquire, Counsel for Father
TRUE COPS" FROM PFMRD
In T lknony when t) , i lier unto ?g my hand
and the tal Uf said cou t at Pe.
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Pmthoavtar,?
MELISSA D. JACOBS,
Plaintiff
V.
GLENN A. WOMER,
Defendant
PRIOR JUDGE: None
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:2002-5868 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8. the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Children who are the subject of
this litication is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Matthe%?' Jacobs-Womer September 17, 1998 Mother
Amanda Jacobs-Womer July 8, 2001 Mother
2. A Conciliation Conference was held in this matter on February 5, 2003,
with the following individuals in attendance: The Mother, Melissa D. Jacobs, with her
counsel. Sara Myer, certified legal intern and Lucy Johnston-Walsh, Esquire of the
Family Law Clinic and Father, Glenn A. Womer, with his counsel, Mark F. Bayley,
Esquire.
The parties agreed to the entry of an Order in the form as attached.
Date
J/acqu6line M. Verney, Esquire v
Custody Conciliator
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MELISSA D. JACOBS
• IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
• 2002-5868 CIVIL ACTION LAW
GLENN A. WOMER
DEFENDANT IN CUSTODY
ORDER OF COURT
AND NOW, __ Friday, November 30, 2007
it is hereby directed that parties and their respective counsel appear be n consideration of the attached Complaint,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thu s vJacqueline M. Verney, Esq. the conciliator,
ecember 20, 2007 _ at 10 ly
for aPre-Hearing Custody Conference. At such conference, an effort will be, Dmad
if this cannot be accomplished, to define and narrow the issues to be heard by the e to resolve the issues to dispute; or
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 fr
Special Relief orders, and Custodv orders to the conciliator 48 hours prior to s °m Abuse orders,
cheduled hearing.
FOR THE COURT,
By: /s/ ac uelrne M. Verne Es
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to com l w'
with Disabilites Act of 1990. For information about accessible facilities and reason
r p c tth the Americans
available to disabled individuals having business before the court, please contact our office.
oce. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You
conference or hearing, must attend the scheduled
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF Y
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHON OU DO NOT
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. E THE OFFICE SET
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
"q_j
4
MELISSA D. JACOBS,
Plaintiff.
V.
GLENN A. WOMER,
Defendant.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 2002-5868
CIVIL ACTION-LAW
IN CUSTODY
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance on behalf of the Plaintiff in the above-captioned matter.
Respectfully Submitted,
Carrucoli & Associates, PC
By:
Kel1y M. Did, Esquire
875 Market Street, Suite 200
Lemoyne, PA 17043
717-761-1274
Supreme Court ID# 93167
Attorneys for Plaintiff
Dated: f l q10
CERTIFICATE OF SERVICE
AND NOW on this day of January, 2008, I, Kelly M. Dick, Esquire, hereby certify
that I served the within Praecipe for Entry of Appearance this day by depositing the same in the
United States mail, postage prepaid addressed to:
Michael O. Palermo, Jr., Esquire
155 South Hanover Street
Carlisle, PA 17013
Attorney for Defendant
(tom . ?t
By:
Kelly M. Di
875 Market Street, Suite 200
Lemoyne, PA 17043
717-761-1274
Supreme Court ID# 93167
Attorneys for Plaintiff
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MELISSA D. JACOBS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2002-5868 CIVIL ACTION - LAW
GLENN A. WOMER, .
Defendant/Petitioner : IN CUSTODY
ORDER OF COURT
AND NOW, this ,'q' day of arc. v , 2008, upon
consideration of the attached Custody Conciliation R ort, it is ordered and directed as
follows:
1. The prior Order of Court dated February 7, 2003 is hereby vacated.
2. The Mother, Melissa D. Jacobs, and the Father, Glenn A. Womer, shall
have shared legal custody of Matthew Jacobs-Womer, born September 17, 1998 and
Amanda Jacobs-Womer, born July 8, 2001. Each parent shall have an equal right, to be
exercised jointly with the other parent, to make all major non-emergency decisions
affecting the Children's general well-being including, but not limited to, all decisions
regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309,
each parent shall be entitled to all records and information pertaining to the children
including, but not limited to medical, dental, religious or school records, the residence
address of the children 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 children. 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.
3. Mother shall have primary physical custody of the Children.
4. Father shall have periods of partial physical custody of the Children as
follows:
A. Beginning Saturday, February 2, 2008 from 12:00 noon to 5:00 p.m. and
continuing thereafter every third Saturday at the same times.
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B. Once Father has reoccupied his home and Maternal Grandmother has the
opportunity to inspect the home, assuming the home is appropriate and
safe, Father shall begin periods of partial physical custody from Saturday
morning, at a time acceptable to the parties to Sunday at 5:30 p.m. and
continue with this schedule every third weekend.
C. After three months of the weekends allowed in paragraph 4B, Father shall
have periods of partial physical custody from Friday between 6:00 -7:00
p.m. to Sunday at 5:30 p.m. This schedule shall continue thereafter every
three weekends.
5. The Christmas holiday shall be divided into two Blocks. Block A shall be
from Christmas Eve at 6:00 p.m. to Christmas Day at 6:00 p.m. and Block B shall be
from Christmas Day at 6:00 p.m. to December 26 at 6:00 p.m. Mother shall have Block
A in odd numbered years and Block B in even numbered years. Father shall have Block
B in odd numbered years and Block A in even numbered years.
6. The Easter holiday shall be alternated with Father having custody in odd
numbered years and Mother having custody in even numbered years.
7. Thanksgiving shall be alternated with Mother having custody in odd
numbered years and Father having custody in even numbered years. In even numbered
years Father shall have the children from Wednesday evening to Sunday at 5:30 p.m. and
in odd numbered years, Father shall have the children from Friday morning to Sunday at
5:30 p.m.
8. Mother shall have custody of the children on Mother's Day; Father shall
have custody of the children on Father's Day, both at times agreed by the parti; s.
9. Father shall have physical custody of the children for one full week in the
summer provided he give Mother 30 days prior notice and address and telephone number
where the children will be.
10. Father shall be responsible for all transportation for the Saturday 12:00
noon to 5:00 p.m. custody periods. For all other transportation, the parties shall meet at
Fort Indiantown Gap Exit of 18 1, unless Mother is on call for that weekend, in which
case Father shall be responsible for all transportation.
11. Once construction is complete on Father's home, counsel for the parties
shall arrange an inspection of Father's home by Maternal Grandmother for
appropriateness and safety.
12. Father shall secure all guns, hunting knives, bow and arrows and tools so
that they do not pose a safety hazard to the children.
13. Father shall not smoke in the car while Matthew is in the vehicle.
14. 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: Michael O. Palermo, Esquire, Counsel for Father
-Kelly McNaney Dick, Esquire, Counsel for Mother
e:5 ;Lx er%?v6cL
BY THE COURT.
JAN 2 4 2008
MELISSA D. JACOBS,
Plaintiff/Respondent
V.
GLENN A. WOMER,
Defendant/Petitioner
PRIOR JUDGE: Kevin A. Hess, J.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:2002-5868 CIVIL ACTION - LAW
: IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Children who are the subject of
this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Matthew Jacobs-Womer September 17, 1998 Mother
Amanda Jacobs-Womer July 8, 2001 Mother
2. A Conciliation Conference was held in this matter on January 23, 2008,
with the following individuals in attendance: The Father, Glenn A. Womer, with his
counsel, Michael O. Palermo, Esquire and Mother, Melissa D. Jacobs, with her counsel,
Kelly McNaney Dick, Esquire.
3. The Honorable Kevin A. Hess previously entered an Order of Court dated
February 7, 2003 providing for shared legal custody, Mother having primary physical
custody and Father having partial physical custody every third weekend.
4. The parties agreed to the entry of an Order in the form as attached.
Date acq eline M. Verney, Esquire
Custody Conciliator