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Home My WebLink About97-04876 , , "Ii .1 " Ii o , I ~ "~I " I ~ t' 1 J ~ . , ,;i " . , " " ;i! I , ,I , , ,I I' I , 'I' " ~ '. i'. , , " '. J , . ' ~ ,:'.,' , . , " ,',i " " ,,' I' :1 , " ~ ~ " " , , , ~ I', 'I, d I'," " , " 'I' i), .. ','1;, i' ", I I ., ,1 " " . i . , .1, ,;d .',' ;1 . , ....' , " , , . " , I r 1 [II \ 1'1'. t.: I, j II .1:1 I ~ . I Ii! II d . ,I I , ' )1 oClllcllal dru~s and, ha.~~d on h,'r "l.>~crvalion:; of F'llher's h~ha\'ior, bdic\'cd him 10 he undl'r 111l' inf1uenc~ or illegal d/'IP.~' Mme"H'r, MI11her quile e\Jlrc':lly pelilluned the court 10 nlllulCy Ihe custody o,der onee this ulIl1nnillh>rt l';lllll' !l1l1ght, Ill:; ndll1,lt~d that "n Febl"ary 1, IIJIIK, huher inC'1Jlncd r-.ll'lh"I,hnllh~ SUpl'/\I~cd vlsiwtioll ,,1" t(H rebnl;,ry 7, I')'.IS \,,'uld be hb resll1e",'" und Ihul i'-\oth,'r ",,11l:illed Ih;lllll,,' \'1<11,JlilHl sill' ll,'\.< '1<\1 acc",Hillik 1111\\tl'er.;lllh;lIIU"", IIII' eO\II"S cu:;tl.,dy mlkr huu nUI)\'t heen redu".J I" ",,,lien Corm ;lnd '111lhe!' II;IS nol iI"'Ul' Ih;ll Falher's rcsIl11.'nce was u \'iSllill""1 ~'IC appr,.>wJ by thc courl. II is ,j,""Clllhal Mother 1"ld F3th~r that hi:; rl'$llknl'~ w;~~ II1It ,I I'thl' 'l"cslIlln ;lnJ Ih.,t l'I'>1lalilll1 \\ollld 1I('vcr 11':1:111 Ihere, I II thl' I:<ml,;I'Y ~hllher IlId,('.11.'d 1'1 I'ath,'r IIl,11 .he ,11<1 nl'l belln(' h,~ resl<lcnlL' W,I" il Pl'IIll1ltl'<I s,'~ for \'i"',111011 '" UC('llr \Vhl'lI ';I,hel' 1I1Ji<;all'd Ih3111 was MUlh,,! snld ~he would l'heck wilh h"l ;11t'lrn~y MOlherll1J nc'llb'''~It:IlII) tnd th" Fcb'"'H\' I, 1995 "SII"'I'"1. 11,)lce"cr. IIhen F"II1,'r continued '0 h:tra.,s hcr concerlli"~, Ih~ lle~1 \'isit"lllJIIIO Ihe p,'inl Ih"t Sll.l"gC,.~ wcre stal1l1g al the p;lt1ie~. !\'\other jnlormell Father tb,,1 "he w'1\1ld call1be pl''',:e ,I' he: did lIvt kille t"'1 ~Ionl) Mor~'oVel, il 1.< l!cnied th.11 thl'''' were ,,,\cral diIY" of (\i~cussioll~ bl'Tween CClunsl'i fllr th,' rc:)pt:cti"'t' par1lc~ ~~ th~' <:l..H,lf111UH\~:tll()n hl,'l\~I,,'t.'lll'nllll~el fur tht: p;H11~~,' 111 rC:).!~lrJ III Ihi) 1:'~UC consisted of .llcrler froTll Fatl\l'r', I'11lJl1~d J ktll'l Ii (,", M,'lher', evll"~')1. "nd ol1c Iclcphl'IIl'l.r11 bl'IWllcn "'L1llsel fur bl1,rh pal'lleS rUrlhl'lIl1'"C, II 1:' d','lIied Ihnllhe dl~'<;IIS:,/IJfI" bllrWeeIlClll\lW;! rC:!;lIlft~d trlllO pro~rt.;':i~ rn t,H"I, 1111\1,.: ll..'ttt,:r bOIl\ \1otl1t:r's 1,.'ljllll(.I'1 In ~-alh..:r':. 1:I,lUW,d, \11"1111';1 l;;llllflsel illdlC.lt~" 111<\1 lli'"thel h:1I1 ",f,',n11"d 1> "th"c Ih'-It hi, rcsium",' \':OJ; 1101 an ''''''I'li'hk \'isitatirm ~IIC because sbe 11,1.1 bt'.'n 111101\1 ar" Ihat Ill<' ,""111 directeJ lJII"'!',,r.<" 1~\lllh"t ~II\'" th;lt IllTlt~, ~f()Lh{,.'r h~\d rt.'I't'l\vd i1 tllp'" \iltI1t: 1.~l'.Irt l,lIdl'l ,llltl \\'~lS :\\\.lr~' 1"II,lt! .,\tbl\.'r.~~ ro:id~'rl\'~' \1\;1" 111 a.:,:eptable \'isiulion sit~ "\lcnrdlll~',ly, it 1:; de,I' thaI l\Io'h"r ~,,"1 ~\'~II'Y Intent of "brJHI~ tJY ,he ,,'u!'t (lId,r in pr,,",'rrtillg II.... ..hll'<ll'el1 "t f.lthl'r'" ")~I<1~I1'C t'<'r ,i~11311nl1, r>;t"l;~thek~s, ,lUflflr, II lekphnne ,IInHr""\I"" h<'i,,"cell I'('IITI~;d f".Ir blllh l':li'I'e~. In whldll\1i'llher'~ "iwlUd ~ull>n'rtItld f II: 11\ 11'1;, , I filii!;' I t.l! l'lld! .111 .1, " I' 1'111 fill with F..ther\ <"(l\IJI,,~1 (h:lIlhc ","talion wOIII<1 "ccur al ....Iher.s resIJenl'l', Muthel \ '(l\IlI~d ,ds'" indicuted tu Father's \'llllIISl'l 111:11 M,)lh,,, w;\.< ill Ihar IlIlle allemplil1l/, tn fil1d annth,'r supervisor to super\'ise the visil"s her muther "..s llll" dhlle I,) d,) <0 ,'U1<1 a,< sh. did n<lt kd ""flIr...rtablc sllpervisill~.lh~ vi <II al ':alher's home tl1the allemaltvl" MOlhN" UlIlIl,cl intiml1ed"ather's eOllllscllh"I ,h~ W;L< all"il1plln~ III find a rrienu 10 Jointly SlIpel VI'" Ih,~ \'1<11"III)n \\Hhl1<:r, I hus, Mother's l'IlIIllsd ;l,<kecl Father', c,,.lI\Scl if thcre \Vas" superl'i,\'r Ih.11 l'allll'l <",,.I1,ll'erha,,, sLlggcsll_'r s"lIi VI"t' at l'arll<~1 ',< le<lIlell"", As I'alher ..nJ Falhn', \ \11 III s<'I I'''h'lll~e Olll .,1' th" sarnc oflk\', 1'.1Ih,"< r'''"I<I'1 pili M,)lh\~r'< r,,.u,,.1 1111 h,\IJ 11IJilatlllg lh;illw \\(1111.1 ;ISk 1:,Hlwr for Ihe names of a sUhslt,ulc ""IJ<'rvis,)r W1"'11 1':111",,', "",",,"1 ""l hac!.; Ilrl the rhO)lle, lie indicallld Ihal Falher had changed his mmJ arlJ Ih;ilthe ,;,,1 \I ,,"ld 11111 occur at hiS re>IJenle bur at thc Carlisi.. Spl)11< 1-:111 1'<1J'1I1/11 , A copy of the kiter, b"tIll'l'n "01111<<11 c"l1eeming thc issu!,,' or visilati,," al F"[h,,r', rC~ldc",~c arc altached herc[(l lIurkl'J e,xtllblt "AU and IIlCOrporaled by reference hcrl'irr as if>cl I<mh:ll kll::.lh ~, DelliccJ, r... Ihl' .-'mlrary, !\folhe, Illlends 10 rull> l")lnply" Ilh thl~. ""1111" order ofJ.1II1Jarv ,10. I 'JIll', In rJct, !\11lther compli,'d wllh rhl' J.1rlll:lrv Ill, lIJ9x ('<'llr! OrJ..! "!I ['cbruary S, 1')<)8 ,1t"'11 ..h,' ,1I'I''','I<'d "II'"lhe,', I'l'~lI"St. ,II IOc CIII,;I;> Sf''''''< "I11I'OllUt1l wIlh the childrl,,'ll r;llhl'r apfJl'a",,J ", a llllwly 1;\shI0I1 an<llhc ,isit \lCl\Ur,"'! alld "enl sn1l'IJthl1' \1I11t1 th" elld whell Father, irt the childr,:n's Pl'l"l,n"", and Vt'IY 101ldly, inronllcd !\ioth"l Ihal <he w"uld be in,jail by Ih" rrexllV".:kend () :\I~rtlll:'l adrllltled 11nr lh~l,il~d a.s this O\)t.'~ rH..ll rl"qlllrl.~ a re:sp,.'rhl.'. I (I. D"rII,'d 1'" Ihe cconllary, lath.-r's P"S;','S',ll.Irr ,md flll'<lIl11ed LIS'" l,r tllq\;1! dr\lgs prl',cill,; a rl:ll1y,rt! I" hi, chlldrcn so as to llI;lkc p"rlla' plw",'al 1'llslod1' with him rtC,lllfl'lhc best inler".',1 o!' Ibe rhtlcll'en 1111111 slIdt time liS, pur"""11 I" Ih,~ Janll,lrl ,\1), 1,'l'l8 Older 01 "')'111, II has beell sho" II th;H f;Hh..r." no 'on!>:"r tinder the: ill 11\1<'1,,'" "I' ill,~.",alltrug< 1'01' ;\ :iu,raHlI'\1 ~""""t, \ . ""';'(111I Ib.. d..,k 'Ii' Ed Guido Judge' ~~ ~ ~~ ~ ~ f:- 'I' ~),~ ~. ~ ( v... r- ;;L>R ~k ~ ~.~~~ ~ ~~~;;:, ~~~ ~~.' , , . --~'S"\.;. :-;.;..:;;,'t':"'_.._!"",". , .. \ , '1- ' ',", ' .. " " , . l , . , . .. , . " . ~ I \ I ! '- Cl r; i--: t(, , C" <'1 r-:~ ~'.:; ~l~:,,: , ) ~~- p:(, ' ,'.. -.. 9~ il. ~ ,.~; -- , ~, f.." I -- IiI. " .:.. Q,': C~I \"(0 u' .:):1. [. U. I,. 0; .. i U 01 U f::5~ VJ~ ~~~ Zffi~ io.o 8 .:. ""~;S o~ I o E-oU,",'" ~ 0.... ;;:J~I'--4CO 8~!31 ..;.... ~ a- 15 ;:1 ~> . Z ....0 .... uz ..... ~~ '"' .... ~~ .... iOl . ~ ~ ., . .. . . .. ~ --. gl ~~ . CIl ~ VJ . I I 0. 0 Oil ~~~ ~~8 ~~~ CIlo.O . ~ IS~~ ~J~~ !lOW": IT. K 1"1"""" ;I-:fl ... M 11.1-:"1. l~" ~ ; ~ ,. ~ ; ~ .. all... '- " "" < ::J 1IIl in i ~ !:d W... '11 ~ c.:l ;;> t,j ~ ... ~ 7. t:: ~ Oliiil..l""o. ~ .~ :< 0 '.J "Jw:t:t-1lI tIJ ":01''''... ; :: a: ~ i ~ o = . ;. ~ waited at the Carlisle Sports Emporium for Father to appear until 12: IS p.m. When Father had not appeared by that time, Mother had an employee of the Carlisle Sports Emporium document that she was present at 12: IS p.m. by executing a document to that effect. Mother, then believing that Father was not going to appear for the visitation, exited the Carlisle Sports Emporium with the minor children and proceeded to hcr vehicle in thc parking lot. Mother proceeded to exit the parking lot of the Carlisle Sports Emporium at approximately 12:20 p.m. Mother was able to observe, that neither Father nor his vehicle was in lhe parking lot atthc time she exited. Mother admits that at approximately 1 :05 p.m. Father tclephoned Mother's residence and spoke to Mother's father. However, it is denied that Mother's father informed Father that "they were , where you were supposed to be and they are not coming back, you God damned druggie." In fact, at the time Father spoke to Mother's father, Mother had not yet returned to her residence and thus, her father was unaware of the fact that Father had not appeared for the visitation in a timely fashion. Accordingly, Mother's father very politely infomled Father that "they are where you were supposed to be." Accordingly, it is denied that there was an outburst by Mother's father however, Mother's father did terminate the phone call after informing Father that the children were where he was supposed to be. 6. Admitted. However, the tone of Father's voice in leaving the message was quite irate and not calm and concilliatory as his allegation implie~. 7. Admitted in part, denied in part. It is denied that Mother has demonstrated a history of using the children, specitically denying Father access to them for reasonable period of partial custody/visitation, based on her perception of what is in their best interest and based upon Mother's continual unilateral refusal to abide by orders of this court respecting custody and visitation. In flU:t, the only time Mother has denied Father periods of partial physical custody pwsuant to a court order is when she became aware that Father had been charged with possession of illegal drugs and, based on hcr obscrvations of Father's bchavior, believed him to be under the influence of illegal dmgs. Moreovcr, Mothcr quitc corrcctly petitioned the court to modify the custody order once this information came to light. It is admitted that on Fcbruary I, 1998, Father informed Mothcr that the supervised visitation site for February 7, 1998 would bc his residence and that Mother indicated that that visitation sitc was not acceptable. However, at that time, the court's custody order had not yet been reduccd to written form and Mother was not aware that Father's residence was a visitation site approved by the court. It is denied that Mother told Father that his residence was out of the question and that visitation would never occur there. To the contrary Mother indicated to Father that she did not believe his residence was a permitted site for visitation to occur. When Father indicated that it was Mother said she would check with her attorney. Mother did not threaten to end the February I, 1998 visitation. However, when Father continued to harass her conceming the next visitation to the point that strangers were staring at the parties, Mother informed Father that she would call the police if he did not leave her alone. Moreover, it is denied that there were several days of discussions between counsel for the respective parties as the communieation between counsel for the parties in regard to this issue consisted of a letter from Father's counsel, a letter from Mother's counsel, and one telephone call between counsel for both parties. Furthermore, it is denied that the discussions between counsel resulted in no progress. In fact, in the letter from Mother's counsel to Father's counsel, Mother's counsel indicated that mother had informed Father that his rcsidence was not an acceptable visitation site because she had been unaware that the court directed otherwise but that since that time. Mother had received a copy of the court order and was aware that Father's residence was an acceptable visitation site. Accordingly, it is clear that Mother had every intent of abiding by the court order in pre~enting the children at Father's residence for visitation. Nevertheless, dllring a telephone conversation between counsel for both parties, in which Mother's counsel confirmed with Father's eounselthalthe visitation would occur at Father's residence, Mother's counsel also indicated to Father's counsel that Mothcr was at that time attempting to find allother supervisor to supervise thc visit us her mothcr was unwilling to do so and as shc did not fcel comfortable supervising the visit at Father's home. In the altcrnativc, Mother's counsel infonncd Father's counsel that she was attempting to find a friend to jointly supervise the visitation with her. Thus, Mother'~ counsel asked Father's counsel iftherc was a supervisor that Fathcr could perhaps suggest for said visits at Father's residence. As Fathcr and Father's counsel practice out of the same office. Father's counsel put Mother's counsel on hold indicating that he would ask Father for the names ofa substitute supervisor. When Father's counsel got back on the phone, hc indicated that Father had changed his mind and that the visit would not occur at his residence but at the Carlisle Sports Emporium. A copy of the letters bctween counsel conceming the issue of visitation at Father's residence are attached hereto markcd exhibit "A" and incorporated by reference herein as if set forth at length. 8. Denied. To the contrary, Mother intends to fully comply with this court's order of January 30, 1998. In fact, Mother complied with the January 30, 1998 Court Order on February 8, 1998 when she appeared at Father's request, at the Carlisle Sports Emporium with the children. Father appeared in a timely fashion and the visit occurred and went smoothly until the end when Father, in the children's presence and very loudly, informed Mother that she would be in jail by the next weekend. 9. Neither admitted nor denied as this does not require a response. 10. Denied. To the contrary. father's possession and presumed use of illegal drugs presents a danger to his children so as 10 make partial physical custody with him not in the best interest oflhe children until such time as, pursuant to the January 30,1998 order of court, it has been shown that father is no longer under the influence of illegal drugs for a sustained period -',\1' () Q \.~; .1 JOHN C. HOWiTt JR. DONALD T. KISSINGER PATIlIC1A A. MiLlS CINDY S. CONLlY LAW Of"CII o. HOWETT, KISSINGER'" MILES, P.C, 1)0 WALNUT STIlUT POST OffiCE BOX '10 HUIUSllJllO, P1NNSYLVAN1A 1'101 February 4, 1998 1717) 114.1616 'AX t717l114.1401 DEBIlA M. SHIMP. L_._I Aula'_nl VIA FA-X TRANSMISSION John R. Beinhaur, Esquire 46S0 Fritchey Street Harrisburg, PA 17109.2813 Re: DiLeonardo v. Dileonardo Dear Mr. Beinhaur: The argumentative tone of your February 3, 1998 letter to Jack, which I am responding to in his absence, is not only UMecessary but unproductive given the circumstances of this case. Moreover, it appears as though your client failed to provide you with all of the facts concerning this past weekend's supervised visitation. For instance, it does not appear that Mr. DiLeonardo informed you that he was 45 minutes late in appearing for the supervised visitation and that despite this Mrs. Dileonardo waited with the children for him to appear although she clearly had no duty to do so. Moreover, when your client insisted upon what my client has described as ranting and raving to her about various issues, Mrs. Dileonardo quite correctly instructed him that he should be spending time with his children during the supervised visitation rather than insisting that she enter into discussions with him. It is true that when Mr. Dileonardo provided her with notice that the next visitation would be at his re.sidence, that she indicated that that would not occur. However, she was not aware that the judge had indicated in his court order that Mr. DiLeonardo's residence was a possit-Ie location for the ~upervised visitations. As you know, at that point, the court order had not been provided to either party. In fact, Mrs. DiLeonardo telephoned me on Monday and questioned whether or not Mr. DiLeonardo's residence was an allowable location for the supervised visitations pursuant to the court order. At that POilll, I advised Mrs. Dileonardo that I believed that the court had indicated that Mr. DiLeonardo's residence was an allowable location but that I had not yet received the court order. As we now have the court order in our possession, it is clear that his residence is an allowable location for the supervised visits. However, Mrs. DiLeonardo's mother is not willing to supervi~e the visitations at any location. Furthermore, given the heightened tensions in this case, Mrs. DiLeonardo, as I am sure you can understand, does not feel comfortable supervising the visitations at Mr. DiLeonardo's residence. Accordingly, she is going to attempt to find a substitute supervisor for said visits that will be acceptable to both her and Mr. Dileonardo. In the alternative, if she is not able to find JOHN G. DILEONARDO, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNT~, PENNS~LVANIA v, CATH~ S. DILEONARDO, CIVIL ACTION - LAW Defendant/Petitioner NO, 97-4876 CIVIL TERM IN RE: CUSTOO~ ORDER OF COURT AND NOW, this 30th day of January, 1998, the parties having placed a stipulation on the record, a copy of which is attached hereto, the following order is entered pursuant to said stipulation: 1, Supervised partial custody shall commence immediately, 2. Unsupervised partial custody in accordance with the November 3rd, 1997, order will commence on Friday, February 13, 1998. Provided, however, that the commencement of such overnight unsupervised partial custody shall be conditioned upon Respondent having two drug free urine tests performed by Omega Labs, 4824 Londonderry Road. Said two tests are to be done on a random basis with times to be selected by Petitioner's counsel, Said random tests will be between February 4, 1998, and February 13, 1998. 3, When the overnight partial custody commences, it will be on alternate weekends and in accordance with the order of November 3, 1997. Provided, however, that for the first six periods of unsupervised partial custody Respondent shall submit to a drug screen urinalysis at Omega Labs on the Friday of the commencement of partial custody and the Monday morning immediately subsequent to the exercising of said partial custody, for a total of twelve additional drug screen te.ts. 4, In the event that any of the tests indicate. drug useage, unsupervised partial custody will cease immediately and supervised partial custody shall be reinstituted pending further order of this Court, 5. The costs of all drug tests referred to above shall be borne by Respondent. 6, The results of the tests shall be communicated by Omega Labs by fax and first class mail to counsel for both parties at the same time. 7, In addition to the tests described above, counsel for Petitioner may direct Respondent to submit to two more random drug screens at Omega Labs between the first and sixth weekend of unwupervised partial custody. The costs of said additional random tests shall be borne by Petitioner. 8, Notice of all random tests to be performed pursuant to this order shall be at the discretion of Petitioner's counsel, Provided, howuver, that at least three hours advance notice shall be giv~n to Respondent, Provided further, that no notice shall be given earlier than 6:00 a.m, nor later than 10:00 p,m, 9, Respondent shall. provide at least three telephone numbers to Petitioner's counsel at which he can be reached, If Respondent tails to submit to a random test as requested by Petitioner's counsel, unsupervised partial custody ohall cease immediately and supervised partial custody will commence until a hearing can be scheduled before this Court, 10, If Petitioner's counsel leaves a message on one of the answering machines at one of the numbers provided by Respondent, it will be presumed, for the purposes of this order, that he got the me5sage, Therefore, Respondent's failure to take the drug test will authorize Petitioner to cease unsupervised partial custody and to commence supervised partial custody pending further order of this Court. 11, During the period of unsupervised partial custody, the children are to be in the presence of Respondent at all times and are not to be left in the care or custOdy of anyone other than him. since the parties were unable to agree on times and places for supervised partial ~ustody, this Court orders that Respondent is granted supervised partial custody this Sunday, February 1, 1998, from 12:00 noon until 5:00 p,m,; next Saturday, February 7, 1998, from 11:00 a.m. until 4:00 p,m.; and next Sunday, February 8, 1998, from 12:00 noon until 5:00 p,m. Said supervised partial custody shall be in the company of Mary Tomczak at such places as father desires to exercise said partial custody with the children including, but waited at the Carlisle Sports Emporium for Father to appear until 12: 15 p.m. When Father had not appeared by that time, Mother had an employee of the Carlisle Sports Emporium document that she was present at 12:15 p.m. by executing a document to that effect. Mother, then believing that Father was not going 10 appear for the visitation, exited the Carlisle Sports Emporium with the minor children and proceeded to her \'ehicle in the parking lot. Mother proceeded to exit the parking lot of the Carlisle Sports Emporium at approximately 12:20 p.m. Mother was able to observe, that neither Father nor his vehicle was in the parking lot at the time she exited. Mother admits that at approximately 1:05 p,m. Father telephoned Mother's residence and spoke to Mother's father. However, it is denied that Mother's I"ther infomled Father that "they were where you were supposed to be and they are not coming back, you God damned druggie." In fact, at the time Father spoke to Mother's father, Mother had not yet retumed to her residence and thus, her father was unaware of the fact that Father had not appeared for the visitation in a timely fashion. Accordingly, Mothe:'s father very politely infomled Father that "they are where you were supposed to be." Accordingly, it is denied that there was an outburst by Mother's father however, Mother's father did terminate the phone call after infomling Father that the children were where he was supposed to be. 6. Admitted. However, the tone of Father's voice in leaving the message was quite irate and not calm and concilliatory as his allegation implics. 7. Admitted in part, denied in part. It is denied that Mother has demonstrated a history of using the children, specifically denying Father access to them for reasonable period of partial custody/visitation, based on her perception of what is in their best interest and based upon Mother's continual unilateral refusal to abide by orders of this court respecting custody and visitation. In facl, thc only lime Mother has denied Father periods of partial physical custody pursu3ntto a court order is when she became aware that Father had been charged with possession of illegal drugs and, based on her observations of Father's behavior, belicved him to be under the influence of illegal drugs. Moreover, Mother quite correctly petitioned the court 10 modify the custody order once this infonnation came to light. It is admitted that on February I, 1998, Father informed Mother that the supervised visitation site for February 7, 1998 would be his residence and that Mother indicated that that visitation sitc was not acceptable. However, at that time, the court's custody order had not yet been reduced to written form and Mother was not aware that Father's residence was a visitation site approved by the court. It is denied that Mother told Father that his residence was out of the question and that visitation would never occur there. To the contrary Mother indicat~d to Father that she did not believe his residence was a permitted site for visitation to occur. When Father indicated that it was Mother said she would check with her attorney. Mother did not threaten to end the February I, 1998 visitation. However, when Father continued to harass her concerning the next visitation to the point that strangers were staring at the parties, Mother infornled Father that she would call the police if he did not leave her alone. Moreover, it is denied that there were several days of discussions between counsel for the respective parties as the communication between counsel for the parties in regard to this issue consisted of a letter from Father's counsel, a letter from Mother's counsel, and one telephone call between counsel for both parties. Furthermore, it is denied that the discussions between counsel resulted in no progress. In fact, in the letter from Mother's counsel to Father's counsel, Mother's counsel indicated that mother had informed Father that his residence was not an acceptable visitation site because she had becn unaware that the court directed otherwise but that since that time, Mother had received a copy of the court order and was aware that Father's residence was an acceptable visitation site. Accordingly, it is clear that Mother had every intent of abiding bJlthe court order in presenting the children at Fathcr's residence for visitation. Ne.vel'1heless, during a telephone conversation between counsel for both parties, in which Mother's counsel cQnfirrned ~ ~ JOHN C. HOWfTT. JR. DONALD T. KI5IINOER rATRICIA A. MILlS CINDY I. CONLEY LAw O"IClI 0' HOWETT, KISSINGER'" MILES, RC. Il~ "'ALNUT ITRUT ron OHlCf BOX II ~ HAUIIIL'JQ, 'INNIHVANIA 17)0' February 4, 1998 ClIIl 314.2616 'All ClIII 314.5403 DIBkA M. SHIMP. Lr..1 Atllt""l VIA FAX TRANSMISSION John R. Beinhaur, Esquire 4650 Fritchey Street Harrisburg, P A 17109-2813 Re: I2.i1&onardo v. Dileonardo Dear Mr. Beinhaur: The argumentative tone of your February 3, 1998 letter to Jack, which I am responding to in his absence, is not only Wlllecessary but unproductive given the circumstances of this case. Moreover, it appears as though )'our client (ailed to provide you with all o( the (acls concerning this past weekend's supervised visitation. For instance, it does not appear that Mr. Dileonardo infonned you that he was 45 minutes late in appearing (or the supervised visitation and that despite this Mrs. Dileonardo waited with the children (or him to appear although she clearly had no duty to do so. Moreover, when your client insisted upon what my client has described as ranting and raving to her about various issues, ~1rs. Dileonardo quite correctly instructed him that he should be spending time with his children during the supervised visitation rather than insisting that she enter into di!(ussions with him. It is true that when ~1r. Dileonardo provided her with notice that the next visitation would be at his residence, that she indicated that that would not occur. However, she was not aware that the judge had indicated in his court order that Mr. Dileonardo's residence was a possible location (or the super..ised visitations. As you know, at that point, the court order had not been provided to either party. In fact, ~1rs. Dileonardo telephoned me on Monday and questioned whether or not Mr. Dileonardo's residence was an allowable location for the supervised visitations pursuant to the court order. At that point, I advised Mrs. Dileonardo that I believed that the court had indicated that ~1r. DiLeonardo's residence was an allowable location but that I had not yet received the court order. As we now have the court order in our possession, it is clear that his residence is an allowable location (or the supervised visits. Howel'er, ~lrs. DiLeon::rdo's l11otl:er is not willing to supero'lse the visitations at any location. Furthemlore, given the heightened tensions in this case, Mrs. Dileonardo, as I am sure you can understand, does not feel comfortable supervising the visitations at Mr. DiLeonardo's residence. Accordingly, she is gcing to ::::er.'.~t to find a substitLle supervisor for said visits that will be acceptable to both her and :-'lr. DiLeonardo. In the altema:iH, i( she is not able to find ~. 1,0 (., ,.:,~ ('-) I" . . s , i tIJ'.) ..' , I , (:l{"l :\1: , ,. l'.' "' I. "'-;C ')'.J (,) ~. G" .:1' " ,) 'j'l ].,.. .,t, ' . '.~ ~i-. :-, w' 1'/1\) "'-. c.J"" I -', II ft1 :.i u 0', 0 -..-~ ~~ ~ i~~ <"l L! .... '" ~.~ VJ8~ = ~'~ QJ :.:~ '" ~;~i~ = , ~o.~~ .8- . ~0 g ~ ~~ ~ ~ i ~... ~ ~...; c.:l~uz :JlU ~ . ~ ... ... .. ~ ~'" ~- . ~~:<O..; Z.... ~ QJ VJ~ 8].... ~j ~ j i$.... i-o zoo ~~ rn ~ 'Il :;" ~(:lS'" .... ;-n .... = (:l'" T' (:l.... .... i ~ .~ . '" i!5~ <.... . CIl& ~ ...:la- ~p., ,. ~ ~ ~.~ 5:, '" ....0 SS i .... U:.: ..... .. J. . ., ) JAM .1 i 1998 '. II()Wf:'I"I~ Kl!ol!olINOf:ll & Mll.l.:l'. '~". ~ i ' ~ " ,. ''''1 , , i' " 1,.1' I , ~ n~ ~H1 ! ,~ ! ') 'J' , ! CL.." ,I \ I', , " .' ". "t" ~'1 - ~ ~ ... i ~ .) rt F , , sccretary that the secrctary believed Father to be utilizing drugs, specifically cocaine. Falher's secretary informcd Mother that she heard Father on several occasions "snorting" in his office. Moreover, when she went into his oftice to get something, shc noticcd a rollcd up piece of paper on his desk. In addition, Father's secretary infornled Mothcr that Fathcr would wear sun shades, a lot of the time, was frequently disheveled, and failed to appear at work on many occasions. 5. According, Mother advised Father that she would not allow him to have overnight custody with the children until such time as he took a drug test and the drug test came back negative. 6. As a result, Father, on September 9, 1997 tiled a complaint for custody in which he requested shared legal and partial physical custody of the parties' minor children. 7. A custody conciliation conference was scheduled and held before Michael Bangs, Esquire, on October 23, 1997. 8. At the conciliation conference, Mother advanced her position that she believed Father to be under the influence of illegal drugs much of the time and revealed to the conciliator as well as Father's counsel and Father the source of her information. 9. Father would not agree to the voluntary drug testing although he represented that he was not utilizing illegal drugs. Moreover, the custody conciliator, indicated to Mother and her counsel that based on the information Mother had that he did not believe it was enough for the court to direct drug testing. However, he indicated his willingness to place into a court order a direction that the parties will not use illegal drugs or abuse alcohol while the children are in their respective care or under their supervision. 10. Accordingly, based on the direction of the custody conciliatol', the parties entered into an agreed upon custody order. A copy of that order which is dllted November 3, 1997, is ,','" ".- ..- # i ~ ~ -- JI 1. 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T.I.phone: (717 238-3388 Docket No.: CR 8-98 Dllte Filed: 1/5/98 OTN: F 046424-0 DEFENDANT r-: NAMa wi "DOW, I DILEONARDO, John Gabrlel 3101 Green st Harrisburg, PA 17110 I L --.J Ocfanl!MI', R~fthnlCII)' Cl 'MI... a Nlllll 0 IIKIl o Hl'!*IK 0 ~.IIW' AIIIC'1o;~" 0 IJnliIlU~" OcfcndAnt',A.K..\. Dclclll1An1'1 Sa 0lIIendlant'.D.0.8, O'lmak ~"." 2 27 54 Od.INUlt" Soclll.l SlNnl1 Nllmba DlI.ndoW'. SiD 179-42-4036 O\:lcN!w', Vdllc!cln(cmwlJOIl: Odcrnbnl'l OnYU', Lil:llUIIl NlImbd PllOtl Nllmbcr SUI' llcailWlionSlIcku{MM/VY) SeMI ComphllnlllnCI~nl Nlimbcr Ol1lplQlD11 uJ.nl Numbeln II othu PanlClpAntl ode District Attorney's Office 0 Approved DDisapproved because: (The district .loUorney mOl)' require that the complilinc. mcsc wiUTl1IIlllffid3vit. or both be llppro'ied by the attorney for the CommonwGlLh prior to niiii..- P;".R.Cr.P.I01.) tNIImI "" AIlOlNY 1Dl' Cum/IMln_ullll . PlCOl'" 'nAt 01 ~..I tS1patllR of "1111IIII' lor ClHIII'IIOIwuliJIl tDtll.) I,TrooD~r Timothy LONGENECKER N7463 U''''IN'''''''llUIl. P1C1lWPtinIOfTypliI of {kklluty 0rfIIIMIIIIl Of Aplllll' 1lI",,_1I>I ~ hlhu.ad Sybo.llwulIlIIl PA state police, Troop H Vice (O.h. kll' HIIINluI LD.) tPoh" "111M')' ORJ r'(u'" tOftlllMdnl AI'~ c.... r'(lIIIlbIIIOCAI) do hereby sll\[e: (check the appropriate box) 1 . C2a I accuse the above named defendant who Ii ves at the address set forth above o I accuse the defendant whose name is unknown to me but who is described lIS o I accuse the defendant whose name and popular designation or nickname is unknown to me and whom I have therefore designated:u John Doe with violating the penal laws of the Commonwealth of Pennsylvania at l1 01 Green st 1....'Pa~llI'lII SlIbl.IIV111OII1 Harrisburq City in Dauphin County on or about 0740 Hrs, TUesday, 12/23/97 Participants were: (if there were participants, place their names here, repeating the name of above defendant) John Dileonardo and Jennifer Maschmeyer 2. The acts committed by the accused were: (Set torth OJ ,ummi1ry o( t~c fJet! suflir.:ient to Jdvise the defendant oi the nature of the o((ense ehalied, A cilation to the Slillute aUeaiSdly violat.d. WIthout more, IS not sufficient In a ~ummat'Y case, YOlJ must CHe the specific secllon iJnd subsection of the SI:UUIC or ortJin:1nce :ill'a.dly ~ioI3{dtJ,) ct N1. P 0 SSE S S I 0 N C 0 C A I N ElM) The above defenedant was in possession of cocaine, a schedule II controlled substance, To Wit: defendant possessed numerous items containing cocaine powder residuo. EXHIBIT "OPC"I ~.(,y'j6J (Tnt.mll V'rtlUnl I .3 I "('" (Continuation or No, 2) Docket Number: CR 8-98 POLICE CRIMINAL COMPLAINT Defendlnl" 'N;:.me: John oi leonardo ct 112. P 0 SSE S S ION MAR I J U A Ii A (M) The above defendant was in possession of marijuana, a schedule I controlled substance, To wit: defendant possessed a small amount of marijuana in a plastic baggie, ct 113. P 0 SSE S S ION HAS HIS H (M) The above defondant was in possession of hashish, a schedule I controlled substance, To wit: above was in possession of three small aluminum foil containers with hashish, ct 114, P 0 SSE S S ION D RUG PAR A P HER N A L I A (M) The above defendant was in possession of drug paraphernalia, To Wit: the above was in possession of a marijuana plpe, straws containing cocaine powder, mirror with cocaine powder, and marijuana cigarette rolling' papers. all of which were against the peace and dignity of the Commonwealth of Pennsylvania and contrary to the Act of Assembly, orin violation of I. 13 a 16 .... Act 64 . (1DIi1l1lll1 IS~IOlIHUftl (,ASlaNll' (COIlllIlI (Sot.:lilllll ISwb_liUIII ('ASt.lutI) (COIIIlIl) 3. I nsk that B warrant of arrest or a summons be issued and that the defendant be required to answer the charges I have made. (In order for a warrBnt ofarrest to issue, the attached affidavit of probable CBuse must be completed and sworn to before the issuing authority,) 1 13 a 31 .... Act 64 (s.,1.' fSwb,"llun) (.ASIIIIMI) (dllllll) ,. 13 a 31 or.. Act 64 t5ol:tiUlI l$Iltt.;liUll' 1t.- ('ASIINtI) (10\llI11) 13 a ~J~ Act 64 .. .... 4. I verify that the facts sel forth in this complaint :lIe true and comCllO the best of my knowledge or information and belief. This verific;llion is made subjecllo the penalties of Section 4904 of Ihe Crimes Code (18 PA. c.s. ~ 4904) relaling 10 unsworn falsificalion to authorities. . --- (l,t ,19M" <--~ , ----. ----~. (:Ii ,1""lItAIn I) ~. AND NOW, on this dale __ January 5 .' 19 98 _' I c ify thatlbe complaint has been properly c0.~Ple:~~.~:~;~'.ified._~n affid~~t of prohabl~_~=us~be C~~~4 ~ ~?ZO_issue... SEAL IM"W..I~'I.II'I'II"'l 4." n ll,.llh.."lyl AI>PC-tll (1\i1H'll1 1"ltll1l1l1 VII'IUII) ~ . J understand that thalr children's schedules may dlctete a change in the night that this visitation shall occur. 3. The parties shall alternate the major holidays, those holidays being defined as Thanksgiving, Easter, Memorial Day, Fourth of July, and Labor Day. The Thanksgiving holidey shall ba from 12:00 noon until 9:00 p,m, The other holidays shell commence at 9:00 a.m. and end at 7:00 p.m. This alternating holiday schedule shall commence with Father having Thanksgiving in 1997. 4. The Christmas holiday shall be broken into two segments. Segment A shall be from Christmas Eve at 12:00 noon until Christmas Day at 12:00; Segment B shall be from Christmas Day at 12:00 noon until December 26th at 12:00 noon. Mother shall have Sogment A in 1997 and all odd-numbered years thereafter and Segment B in 1998 and all even-numbered years thereafter. Father shall have Segment A in 1998 and all even-numbered years thereafter and Segment B in 1997 and all odd-numbered years thereafter, 5. Father shall be entitled to one week in June, one week in July, and one week in August of every summer. He shall provide Mother with notice by April 1 st of each year as to which weeks he intends to exercise these periods of exclusive custody. Mother shall be entitled to two uninterrupted weeks of custody during the summer. She will provide Father with notice by April 16th of each year as to the weeks In which she intends to exercise these periods of exclusive custody. 6. Father shall have the children on Father's Day and Mother shall have the children on Mother's Day, These period a of partial custody and visitation shall occur from 12:00 noon until S:OO p.m. 7. The parties agree that there shall be no use of illegal drugs or abuse of alcohol while the children are in their respective care or under their supervision. S. When Father is picking up the children at Mother's residence, Father agrees that he shall stay in his vehicle and the children shall be prepared and ready to come with him and shall go to the Father's vehicle. It is the understanding of this paragraph that the drop off and delivery of the children should involve that alone and that there should be no unnecessary contact between either party or anyone at the residences while that occurs. 9. Both parties shall ensure that while the children are in his or her physical custody, that they shall attend on a regular basis Sunday Roman Catholic church services. However, both parties acknowledge that from time to time due to vacation schedules, illness and other JOHN G, DiLEONARDO, Plaintiff v, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. tj ". 'If 7 ~ &vd --r:-. IN CUSTODY CATHY S. DiLEONARDO, Defendant COMPLAINT FOR CUSTODY 1. The Plaintiff is John G. DiLeonardo, residing at 3101 Green Street, Harrisburg, PA 17110, 2. The Defendant is Cathy S. DiLeonardo, residing at 6 Charisma Drive, Camp Hill, FA 17011. 3, Plaintiff seeks shared legal and partial physical custody of the following children: Name Present Residence Age Christine Marie 6 Charisma Drive 10, born DiLeonardo Camp Hill, FA 17011 11/11/86 Rebecca Ann 6 Charisma Drive 8, born DiLeonardo Camp Hill, PA 17011 10/05/88 The children were not born out of wedlock. The children are presently in the custody of Cathy S. DiLeonardo, who resides at 6 Charisma Drive, Camp Hill, PA 17011, During the past five years, the children have resided with the following persons and at the fOllowing addresses: Plaintiff and 6 Charisma Drive 1992 to Defendant Camp Hill, PA 17011 6/19/97 Defendant 6 Charisma Drive 6/19/97 Camp Hill, PA 17011 6/?/97 Defendant and 6 Charisma Orive 6/?/97 Maternal Grand- Camp Hill, PA 17011 Present parents The mother of the children is Cathy S. DiLeonardo, who currently resides at 6 Charisma Drive, Camp Hill, PA 17011. She is married. The father of the children is John S, DiLeonardo, currently'residing at 3101 Green Street, Harrisburg, PA 17011. He is married. 4, The relationship of Plaintiff to the children is that of father, The Plaintiff currently resides with Jennifer Marschmeyer. 5. The relationship of Defendant to the children is that of mother. Defendant currently resides with the parties' two children, Christine and Rebecca along with maternal. grandparents, Alois E. and Mary Tomczak. 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 proceeding concerning the children pending in a court of this Commonwealth. 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 Plaintiff desires to remain active in the children' s lives and desires a set schedule of partial custody as set forth below, 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. 9. Pl;lintiff desires the following schedule of custody: a. The parents shall share legal custody of the ahildren and each parent shall consult with the other concerning all major decisions affecting the children, including but not limited to, health, education and religion, b. Alternating weekends from Friday at 5:00 p.m. until Sunday at 5:00 p.m, The parent receiving custody shall pick up the children at the beginning of their respective custodial period. c, Father shall have partial custody of the ahildren one evening per week picking up the girls at '. :> C') }- fJ:; V: I.:::: ~~. " ~'J ~) 0.':( ,'- I~h.,; lLl." , ':2r ' ". [J... c.. r , . .1 ~'l f-. ?-;-j (;:.\1, I F:::" I.Lrl.- ~ ",)# [1;1 ' >-. '-lCu -.:, ':':1(.1.. 1:-- CJ d "J r' " 01 , , Li