The URL can be used to link to this page

Home My WebLink About97-04894 I' ,I.~ , ',. 'I I ,I '\' /I~" ',t, li'..'l , 'i\j r,', II '1, I' , 't,n: 1 1 ;1," /1, ii', , :\ r " i~ ',1 "'l .'1'/ I';,! ,;.it: , ,,'/ ,',:,1, " ,,' I' 1.1' I, \. ~ ~ ~ " :, " ;1', I! '. '1 I , Ii" 1 " , ! ,,'i., I ','I, " ,I I, " I, ,;' I I "I ~ I, 'I , , I I, " I' I'i ,':1, " , I I "" 1";1, ,I 'j; " I,. I I ~ " ~ J " t,' " "" I I '" T I , " ~ " , I, \ . "'1 I / 'I / / 'I , , " , " I if I, , I 'I .1 \," I , 'I I .. " " , , I, , , , '. I I , , I I I', , I. \ I " " .,II I I 'I " , '''\ I, I ,I 'i ,I; '" ,'I;, 'i' i: "I "I , 'j ,1.1 !I' I: I "", ",',1". ',:, , I ;! " " I I , '1 !' ,i' , , ,I', I' '"Ii> , '11 , I, I I "f,1 '1 " ,", ,'1 I" " '1,1 .\ f,'1 " )' , I I I, I , 1,1 , :' "I " I " , , , .,'1 ,h ,. I" I I " , ,,' " , "1 "I , ,\ 'I " ',,', "'I',, 'I " ~ q... 0.- ~ ,I', ", ,I, I',i I I . t'-o ~ it I,' SANDRA M. BROOKER, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I No. 17- 4 Sri 4.. ()~-~~.L VS. " I I MICHAEL L. BROOKER, I CIVIL ACTION - AT LAW Defendant CUSTODY ORDER You, MICHAEL L. BROOKER, Defendant in the above-captioned custody action, have been sued in court to obtain custody of the following childl ZACHARY M..BROOKER. You are ordered to appear in person at on the day of II a Pre-Trial Conf~rence. a Hearing before the Court. If you fail to appear as provided by this Order, an Order for custody may be entered against you, or the Court may issue a warrant for your arrest. YOU SHOUI,D TAKE THIS PAPER TO YOUR LAWYER A'l' ONCE. IF YOU DO NOT DAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TaB OPPICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 II SANDRA M. BROOKBR, I IN THE COURT OF COMMON PLBAS OF Plaintiff I CUMBBRLAND COUNTY, PBNNSYLVANIA I vs. I No. I MICIiAEL L. BROOKBR, I CIVIL ACTION - AT LAW Defendant I CUSTODY VERIFICATION I, SANDRA M. BROOKER, state that I am the Plaintiff in the above-captioned case and that the facts eet forth in the above Complaint for Custody are true and correct to the best of my knowledge, information, and belief. I realize that false statemente herein are subject to the penalties for unsworn falsification to authorities under 18 Pa. C.S. S 4940. . ) ~ d(-7tJ";' If (' /)/ /// // '. '- ~: ""'A+-11-- 2LA Sandra M. Brooker Datelr,)Qr{ il) If'll I I " , " :-- -:-1 "'\.. ,~:i tor: (~~ UJr=~ " " J , ~..:;. ( ), " , , ..1 '", " I'-.i' 1,1 .;~ ,. SJi, , :\ r~;i " "-t.1 (" ';'. I J...! '.,.. ,uJ, 1 0-" '1\.1.) u...;l (\,)', 1L!4-; I" c.;) .."* " r- '.:..:) (') a" <...) , " , , I' I, , , 'J,' " 'i' " " , .. I, "I , <II , ,d "I ;i " ,. (1\ ,..,. ",--. II 0: .. '" ; " , , '. , I " ((', " I, ('J " II~ I " ._J c t...:..: .. .. " 1-, " (-' (,J , W' " " : ' , ! /, " , , r: , 1\ l 4 F " SANDRA M. BROOKBR-WONTROBA, I IN 'rH! COURT OF COMMON PLEAS OF Plaintiff I CUMBBRLAND COUNTY, PBNNSYLVANIA I vs. I No. 97 - 4894 Civil Torm I MICHAEL L. BROOKER, I CIVIL ACTION - LAW Defendant I CUSTODY AND NOW, this .2-1 · ORDER day of T~'; , 1998, Zachary M. Brooker, born September 26, 1994, shall not be removed from Pennsylvania wiUIQut a ~litteR e1!aer by this El8Iurt:. /,"-#I.~ ~ ,1;..~ ~, ~' //4-- J. / II I' I I . SANDRA M. BROOKBR-WONTROBA, I IN THE COURT OF COMMON PLBAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I V8. . No. 97 - 4694 civil Term . I MICH!\EL L. BROOKER, I CIVIL ACTION - LAW Defendant . CUSTODY . AND NOW, this ORDBR day of 1996, it is hereby Ordered and Decreed that the Plaintiff, Sandra M. Brooker- Wontroba, ia awarded temporary, physical custody of the parties' minor child, Zachary M. Brooker, which award of custody is to be superseded by judicial approval of a recommended order of the custody conciliator. BY THE COURTI J. " I ,', SANDRA M. BROOKER-WONTROBA, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I VS. I No. 97 - 4894 Civil Term I MICHAEL L. BROOKER, I CIVIL ACTION - LAW Defendant I CUSTODY AND NOW, this ORDHR day of 1998, it is hereby Ordered and Decreed that the Defendant, Michael L. Brooker, upon leaving the Commonwealth, shall return to defend the above-captioned action at a prehearing custody conference to be scheduled by the Office of the Court Administrator. , II current address and phone number. I The Defendant will keep the Plaintiff apprised of his The Defendant will post bond in the amount of to guarantee his return to defend the above-captioned action as scheduled by the Court Administrator. BY THE COURT I J. SANDRA M. BROOKBR-WONTROBA, I IN THB COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PBNNSYLVANIA I V8. I No. 97 - 4894 Civil Term I MICHAEL L. BROOKER, I CIVIL ACTION - LAW Defendant I CUSTODY BX PARTE PBTITION FOR BMERGBNCY RELIBF The Plaintiff, Sandra M. Brooker-Wontroba, through her attorneY8, The Law Offices of Patrick F. Lauer, Jr., files this Ex Parte Petition for Emergency Relief against the Defendant, Michael L. Brooker, and in support thereof, averb the following: 1. The Plaintiff is Sandra H. Brooker-Wontroha, an adult individual and the natural Mother, who currently resides at 105 Meadow Brook Road, Lot 13, New Cumberland, Pennsylvania 17070. 2. The Defendant is Michael L. Brooker, an adult individual and the natural Father, who currently resides with his mother at 1018 South 19th Street, Harrisburg, Pennsylvania 17104. 3. The Plaintiff filed a Complaint for Custody with this Court on July 16, 1998, reque8ting primary physical cU8tody of the minor child Zachary M. Brooker (d.o.b. 9/23/94). 4. A cU8tody conciliation conference has not been Icheduled. 5. The child currently resides with the D~fend.nt. 6. The Plaintiff is oonoerned that the Defendant's intentions are to move to Arizona, taking the child with him, where such a move would not be in the best interest of the child. 7. The Defendant no longer has a permanent place of residence save that with the paternal grandmother. 8. The Defendant's immediate family lives in the Commonwealth. 9. The Defendant is not employed in Arizona, but has two jobs here in Pennsylvania. 10. The Plaintiff believes, and therefore avers, that the Defendant will refuse to make the child available to the Plaintiff for visitation. 11. The Plaintiff believes, and thorefore avers, that the Defendant has no legitimate reason to move with the child to Arizona which might anyway be in the best interest of the child. 12. The Plaintiff is willing, able, and needed to serve as a ohild care provider. 13. Jurisdiction is established in Pennsylvania pursuant to the Uniform Child Custody Jurisdiction Act. SANDRA M. BROOKER-WONTROBA, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBBRLAND COUNTY, PBNNSYLVANIA I va. I No. 97 - 4894 Civil Term I MICHAEL L. BROOKER, I CIVIL AC'rION - LAW Defendant I CUSTODY VERIFICATION I, SANDRA M. BROOKER-WONTROBA, state that I am the Plaintiff in the above-captioned case and that the facts set forth in the attached Ex Parte Petition are true and correct to the beat of my knowledge, information, and belief. I realize that false statements herein are subject to the penalties for unaworn falsification to authorities under 18 Pa. C.S. S 4940. Datal '7/:J..1/9L r d~ 41 1V~ 'I SANDRA M. BROOKER-WONTROBA, Plaintiff I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PBNNSYLVANIA I I No. 97 - 4894 I I CIVIL ACTION - AT LAW I CUSTODY V8. MICHAEL L. BROOKER, Defendant QIDmR You, MICHAEL L. BROOKER, Defendant in the above-captioned cU8tody action, have been sued in court to obtain cU8tody of the I following child I ZACHARY M. BROOKER. ! ! You are ordered to appear in II ~I b~~.(\:: t\\("u.,\L. \:<\l""j'),Uj."on the at ''){l(.) .L.M. for a Conciliation or Mediation Conference. person --, ,~ at::t.k'::) ~,\'<,\""")\ 1C(\~) \\-. \\, I day of ~r\Ff',h:"f998, If you fail to appear as provided by thiQ Order, an Order for I custody may be entered against you, or the Court may issue a I I warrant for your arrest. I I YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 00 NOT HAVE A LAWYER OR CANNOT AFFORD ONB, GO TO OR TELEPHONE TBB ! OFFICB SBT FORTH BELOW TO FIND OUT WHERE YOU CAN GBT LEGAL BBLP. OFFICB OF TUB COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYI.vANIA 17013 (717) 240-6200 I, II i! . AMERICANS WITH DISABILITIES ACT OF 1990 ,The Court of Common Pleas of Cumberland County is required by law Ito comply with the Americans with Disabilities Act of 1990. For ! information about accessible facilities and reasonable 'accommodations available to disabled individuals having bU8ines8 before the court, please contact our office. All arrangements mU8t be made at least 72 hours prior to any hearing or bU8ine88 before the court. You must attend the scheduled confer~nce or hearing. . FOR THE COURT: DATEl ~~ j 'i.~\.\ SANDRA M. BROOKER-WONTROBA, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 97 - 4894 MICHAEL L. BROOKER, Defendant CIVIL ACTION - AT LAW CUSTODY PBTITION FOR MODIFICATION OF A PARTIAL CUSTODY OR VISITATION ORDBR The Petitioner, Sandra M. Wontroba (formerly Brooker), through her attorneys, The Law Offices of Patrick F. Lauer, Jr., files this Petition for Modification of a Partial Custody or Visitation Order against the Respondent, and in support thereof, avers the following: 1. The petition of Sandra M. Wontroba respectfully represents that on October 29, 1997, an Order of Court was entered for Partial Custody, a true and correct copy of which is attached. 2. This Order should be modified because: a. The Father has indicated his intention to move to Arizona, taking the child with him, where such a move would not be made in the bost intarests of the child; b. The Father no longer has a permanent place of residence save that with the paternal grandmother; and c. The Mother is willing, able, and needed to serve as a child care provid~r. WBBRBFORB, Petitioner request~ that the Court modify the existing Order for Partial Custody because it will be in the best interest of the child. a s bmitted, ,- " Resp tf 1 I Datel Matthe J. 2108 Marke Camp Hill, ID* 46430 shelman, Esquire Street, Azteo Building Pennsylvania 17011-4706 Tel. (717) 763-1800 DHIIIT A