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Home My WebLink About97-04855 ~ ~ ~ ~ ~ ~ ~ r i , I ,,. ., , ) , .' ., '. ',,' '" , ' " :1' " . , ; I'! , , , " ,'I , , . , , 1 " , '-1"1' '1 " d" "'1 'II il " , , , , , , , I,' e I , , , .1 " I' " , ,1_; '" , , , :r' I f . , , , , i' ;I " 1'1, ,',I , 1 "..,_;,1," ,'., '1 , I , , '-tl . , , ' ;\ ,. " ,\",-, " , ~J , .1 ,,-', , , "il " ,]1 'I' -" j; 01 'I"~ I, , . , 1"'.1' . , " , , " .. ' I" I ,.11 , , , I "., " " ,'1,:'1' " ..,' , '" " , " , " r', .. II" ;' ' " " ./ q .~ ,'0, ii, "I, , " .,' II , " , 1 , ' f'I',:r',( cr T 1'1": \lW'~ 'Nrd..J .~ A~ Lt~ ",oi.1.tol N~i\Au -\.;, ~ . 'IT/Sri 1'\'/ ('r.':> ,.'1 ~J ,I; ~ " ,it Ii') II', ... Cl:i :jl' 1;(;\":11 , " ~, ! ~':\\\>ll,~I\"t:lrll",\plll S~J1h.:tlIbl.'1' "'.II)'J7 5. In the last two years, and up until September 1, 1997, Defendant has attempted to cause or has Intentionally, knowingly and recklessly caused bodily injury to the child and has placed the child In reasonable feal' of imminent serious bodily injuries. Said Instances include, but are not limited to the following: A On Monday, September 1, 1997 at approximately noon, during the period of partial custody with the Defendant, the Defendant hit the child across the face two times, grabbed him by the upper arms and shook him, and hit him several times across his bare bottom for failing to tell the Defendant certain information about Plaintiff's home which Defendant demanded. As a result of this assault, the child suffered brui~ing across the forearms; red, welting and broken blood vessels on his bottom; bruising on both cheek bones and across the bridge of his nose. The child was taken to the emergency room of 51. Joseph Hospital, Lancaster, Pennsylvania. The hospital notified Lancaster County Children and Youth Services which is conducting an investigation, During the assalJlt, the child cried and lost control of his urine, The child stopped crying because Defendant told him that the beating would not stop until he stopped crying. B. On previous periods of partial custody prior to the incident related above, Defendant abused the child by punching him in the arm and knees; hitting him across the arms, legs and buttocks; standing him in the corner for hours and threatening to make him stand In the corner overnight; and threatened to "hurt him so bad". As a result of this abuse, the child is fearful of the Defendant and does not wish to be with the Defendant without supervision. 6. Plaintiff believes and therefore avers that her son will be in immediate and present danger of abuse from the Defendant, and thaI he is in need of protection from such abuse. 7. Plaintiff desires that the Defendant be ordered to refrain from any contact with her son, unless that contact is supervised, 2 ~':\~p,H\~clrH~\pI,1 S.::pll.'1I1111rt:I' /'i,JI}ln 16. Pending a hearing on this matter, Plaintiff requests that the partial custody of the child by the Defendant be suspended and that, following a hearing, any partial custody that the Court finds Is In the child's Interest be supervised, WHEREFORE, Plaintiff prays this Honorable Court to enter a Temporary Order pursuant to the provisions of the Protection from Abuse Act. 23 Pa, C,SA ~6101 et seq" as amended, the Plaintiff prays this Honorable Court to grant a Temporary Order requiring the Defendant to refrain from abusing the child, Nicholas C, Ketrow, or placing him in fear of abuse; requiring Defendant to refrain from having any contact with the child; prohibiting Defendant frorr: harassing or 3talking the child, or from coming to the child's home or school. Plaintiff also requests a hearing in accordance with the Protection from Abuse Act, and following such hearing, the entry of an Order requiring the Defendant to refrain from abusing the child, placing the child In fear of abuse, having any contact with the child outside of supervision, from tlarassing or stalking the child, or coming to the child's school or residence, and modifying the Court's Order of April 3, 1997 as the Court deems in the child's best interest and for his protection. Plaintiff also requests that the Defendant be ordered to pay the costs of filing the instant action, serving the Court's Order on the Defendant and reasonable attorney's fees. The Plaintiff prays for such other relief as the Court may deem just and proper. FLOWER, MORGENTHAL, FLOWER & LINDSAY Attorneys for Plaintiff Date: By: 1'IlL 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KEVIN T. LITRENTA, I Plaintitt I I , v. I NO. 96-4577 I CHRISTINE L. KETROW, I CIVIL ACTION - LAW Defendant ) CUSTODY ORDER AND NOW, this JIlIL day of ~ , 1997, it is hereby ORDERED and DECREED that the provisions of the stipulation for Entry of custody Order entered into between the parties which is attached hereto, are incorporated herein as an Order of this Court. BY THE COURT: . I 1~4'<-x.... d. ~ J. TRlJ:C: CO?Y ~~CM RECORD I .- .' , 1'1 ..~. '. . ,,". ..... : ,.r\'I' 'I' ,,,./-,. "'~Ij . ~'.. .l' 0' ~f~'. !,r~HI to '.'. " '_, , ~.' ,~.,;:,; ,i~ ('....:j.:.f. ~Ja. ~1t7C"I1. .t1f,,~. ,'4!4..: PrQtll.1notalY , . FEIl-!!H 997 1&' 1& HQWETT.KISSIHJ8R,MILES,PC 717 23ol~e2 P.":! Ilf 'I'HE COURT or COHMON PLEAS OF ~BERLAND COUlfTY, PENNSYLVANIA KEVIN T. LITREHTA. ) PlaintHf ) ) v. ) NO. 96-4!17 ) CHRISTINE L. KETROW, ) CIVIL ACTIOlf - lAW Defendant ) CUSTODY ITIPOLATION rOR ENTRY or CUSTODY OROII AND NOW, this G ~ day o~ ~ , 199-1 cOr.le the parties in the above-captioned ac~icn and enter into this stipulation: WHER!AS, Pl.i~titt, Kevin T. Litrenta (hereinatter re~erred to as "Father"l. and Defendant, Christine L. Xetro'" (hereinafter referred to liS "Mother"), are the parents of one minor child namely ~icholas C. K_trow (hereinafter referred to ae "Nicholas"). born June 14, 1989: and WBlREAS, Nicholas is presently in the p:imary physical custody ot Mother: and WBlREAS, on Auq\llt 15, 1996. Father initiated a Complaint tor Shared Leqal and Physical CUstody docketed to the above- caption.d number In the court ot Common Pleas of Cumberland county, Pennsylvania In which he requested shared 1_9al and physical custody of Nicholas, and WBIRlAS, the partie. have determined that it is in the beat int.rests of Nicholas that the pending cus:ody i..ue be r.solved amicably betw.en them, and after neqotlations In which both partie. were represent.d by counsel ot their Choice, the partie. FEIl-I9-I997 16' 17 HDWETT.KISSI~,MILES.FC 717 23<<541i!2 1".04 have reached an agTeement as to the Fhysical and legll custody ot Nicholas. ~. T..RlFa.., with the toregoing recitals being hereinafter incorporated by referenr.e herein and deemed as an essential part hereof. and intending to be legally bound hereby. and tor other good and sufficient ccnsideration. the receipt ot .hich is hereby acknowledged, the parties mutually agree and stipulate as follows: 1. ~eQal ~~st~. Legal custody as t~at tern is defined by 23 Pa.C.S.A. !5302 shall be shared e~ally bet~een the parti... 2. Ka~ofitv 'bvsical custody. Majority physical custody of Nicholas shall be in Mother. 3. .artlal 'hysical custody. father shall have partial physical custody =iqhts with NiCholas as tollows: a. ,eetends. Every other weekend ~=cm Friday at 6130 p.m. through sunday at 7:00 p.o. b. lolldavl. Alternating holidays tr~ 9:00 a.m. through 9:00 p.m. Said holidays shall consist ot New ~ear'. Day, Eastnr, Memorial Oay, July 4th. and Labor Day. o. TbaDk.qiviaa. In 1997 and in all odd- numbered years thereatter, rather shali be entitled to phy.ical cu.tody of NiCholas tro~ 9:00 a.m. Thanksq1v1nq Day throuqh the tollovinq Sunday at 7:00 p.~. Likewise, in 1998 and in ell ev.n- numbered years thereatter. Mother shall be entitled to pby.lcal ." 2 '. FE9-19-1997 16'17 ()JETT.KISSINGER,MILES.PC 717 23454e2 P.05 cuatody of Nicholas trom Thanks~ivin9 Day at 9:00 a.m. through the tollowing sunday at 7:00 p.~. d. chriatma.. In 1996 and all even-numbered years thereatter, Father shall be entitled to physical custody of Nichclas fron 12:00 p.m. cnristmas Eve throuqh 12:00 p.m. Chrilt2es Day. I~ 1997 and all odd-numbered years thereatter, Father shall be entitled to ~hysical custody of NiCholas trom 12:00 p.m. Christmas Cay throuq~ 12:00 p.m. December 26. !n 1996 and all even-nurnb.re~ years ~h.reafter, Mother shall be entitled to physical custody of Nicholas trom 12:00 p.rn. Christmes Day through 12:00 p,~. Dec~ber 26. In 1997 and all odd-numtered years thereafter, Mother shall be entitled to physical custody ot Nicholas trom 12:00 p.m. Chriatmas Eve throuqh 12:00 p.m. Christmas Day. The remainder of Nicholas' Christmas/New Year br.ak trom school shall be equally divided bet~een the partiaa as they aqree. e. Sorina Break. Tather shall b. entitled to one-halt ot Nicholas' spring break from school as the partie. ..y agre.. f. 'n~er vacation. Father shall b. .ntitled to thr.e (3) we.ks of physical custody ot sicholas durinq the traditional suomer school vacation in 1997 with one ~..k occurrinq in June, one week in July, and on. week in Auquat a. the parti.s may aqr... commencinq 1n 1998 and thereafter, rather shall be entitled to four (4) weeks ot physical custody ot Kicholas durinq the traditional lummer school vacation with on. 3 FEB-I'7-199? 16118 HOWETT.KI;sr~.MILES.PC 111 .~S41i!2 P.06 w.ek occurring 1n June, two weeks in July, and on. ~.ek in August as the parti.. may agree. 4. School Cb~. The partie. acknowledge that thsy have discussed the possibility ot Nicholas' att.n~ance at Lancaster country Day School commencing in the fall 1991. The partie. agree to continue these discussions so as to reach agreement in the best interests ot Nicholas regarding the school choice tor 1997 and thereafter. The parties agree that Nicholas' Bchool shall not be changed without consultation between t~e parties and no less than six:y (50) days advanc9 written notice to 1ather. 5. ratber's Day/Kotber" Day. Father shall al~ay. have physical custody of Nicholas on rather's Day from 9:00 a.m. through 9:00 p.~. Kother shall always have physical custody of NIcholas on Mothor's Day tro~ 9:00 a.m. through 9:00 p.m. ,. AdditioDal Time. Soth partie. agree that rather may spend additional time with Nicholas at such other tlma. a. ~he partie. lIlay Mutually agree. 7. 8peoial Circ~ltaDces. The parties agree that should special circumstances arise they shall discuss said circumstance. and it they are in agreement, modi!y their euatody a9r.~ment to accommodate the special circumstances. I. IDtrv af Court order. Th. parties agree that the term. of this stipulation for Entry o! custody order Shall be entered as an Ord.r of Court at the request of either party an4 entorceable by tbe court as if a full h.aring had been conducted. 11<;. ,:' V,j .' \ ~ . 4 - I, f;~ '" ....' -\ ~. ; I' '''J ..:' ~u (). ,\ ..-.,:: \ f 1...., " <.i) <- CO I' I L1-'1 " L:.:l I " " .....i, .' ~Ij '-'.I~ I' (,,.-; . U.. r-- 'J t.l Ci''' (.) , I L;, \ ~T'".(,:-;':' -:,'(, ( .." .' '1'1 ;~r''":' \ ,:" '" ,'J' , l~' .' , ..~ GlF' ;'( " , " " 'I ~.. lO ... n' ",. r, i"'; III' " (': ..~ ~L' , !!, " ;- C): ~, ( '1' ! . \' , -.' le (!' ';1 .'"l. ~ iii,;;' I II'~ , , , ~,' ' 1._) . , , ~~~ ~ .... ~. ~U l\.i 3~~ III OJ III r4 =,.., ~~~ Qj 0 ....c i ~ III " "..... ~~lt: :0: r- ~... ... 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