HomeMy WebLinkAbout97-05604
... ,:Ii
E
J
,
.
S
J
j
J
/
-.J
:r-
o
~
~
"""I
v- ,
,
,
,
I
\1
II
,I
II
. .,~'
Flrl>CH:C~
c;~ i;'-: : ,"-' '. ,~,r.\.'T{
97 un" ?'I 1 ,I (~: fl2
CUi,~:_,.... .... _ ')J:m'
Fl:r ::.:) I'L\~ \; <>\
TRACY L. GROHMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
ROBERT J. GROHMAN,
Defendant
NO. 97-05604 CIVIL TERM
CUSTODY
1.1.. QU~r9DY -XRffl .~
AND NOW, this "1----- day of ~'^"'-_~..__ __h_' 1997, upon
consideration of the parties' Consent Agreement, the following
Order is entered with regard to custody of the parties'
children, Samantha Nicole Grohman d.o.b. 9-3-90 and Niko1as Mikel
Grohman d.o.b. 2-1-93
The defendant, Robert J. Grohman, hereinafter referred to as
the father, and the plaintiff, Tracy L. Grohman, hereinafter
referred to as the mother, agree to the entry of the following
Order regarding custody of their children, Samantha Nicole
Grohman d.c.b. 9-3-90 and Nikolas Mikel Grohman 2-1-93.
1. The mother and the father shall have shared legal and
physical custody of the children.
2. Physical custody shall be shared on an alternating
weekly schedule as follows:
Week 1: The mother ~hall have Monday after school
until Tuesday Morning and Wednesday after school until 7:30 p.m.
and Thursday after school until Sunday at 6:00 p.m.. The father
shall have all other times.
Week 2: The mother shall have Wednesday after school
until 7:30 p.m., Thursday after school until Friday at 8:00 p.m.
The father shall have all other times.
3. The father and mother shall alternate custody on the
following holidays: Thanksgiving, Christmas, and Easter with one
parent having the children from the day before the holiday until
the holiday at 2:00 p.m. and the other parent having the children
from the holiday at 2:00 p.m. until the day after the holiday.
The mother shull have the period beginning the day before the
holidays in 1997, and odd numbered years thereafter.
4. The parent who has the children according to the
alternating weekly schedule in paragraph 2 will have custody on
the following holidays: Memorial Day, the Fourth of July and
Labor Day unless otherwise agreed by the parties.
5. The mother and the father shall alternate custody of the
children on their birthdays with the mother having them in 1998
and even number years thereafter.
6. The mother shall have the children on Mother's Day and
the father shall have the children on Father's Day.
7. During the summer months and when school is not in
session, the parties shall abide by the alternating weekly
schedule in paragraph 2 with custody being transferred at places
agreed upon by the parties.
8. The mother and the father shall have periods of vacation
with the children at mutually agreed upon times and with at least
two weeks notice to the other parent.
9. The mother and father, by mutual agreement, may vary
from this schedule at any time, but the Orde~ shall remain in
effect until further order of court.
10. The mother and father agree that each shall notify the
other of all medical care the children receive while in that
parent's care. Each parent shall notify the other immediately of
medical emergencies which arise while the children are in that
parent's care.
11. The mother and the father shall discuss the children's
extra curricular activities before the children are enrolled.
12. The mother and father shall discuss pertinent issues
regarding the children such as haircuts, braces etc. before
making a decision.
13. If either the mother or the father moves farther than 25
miles away from the other, the person who has moved will be
responsible for transportation of the children; neither party
shall move a distance which will make this order impractical
without modifying this order.
14. Neither the mother nor the father shall petition to
modify the custody order without first attempting to settle the
matter by agreement.
15. The parties realize that their children's well being is
paramount to any differences they might have between themselves.
Therefore, they agree that neither party shall do anything which
may estrange the children from the other parent, or injure the
opinion of the children as to the other parent or which may
hamper the free and natural development of the children's love or
respect for the other parent.
By the Court,
TRACY L. GROHMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
va.
ROBERT J. GROHMAN,
Defendant
NO. 97-05604 CIVIL TERM
CUSTODY
CONSENT _AGREEM!;NT
This Agreement is entered on this
day of_
1997, by the plaintiff, Tracy L. Grohman, and the defendant,
Robert J. Grohman. The plaintiff is represented by Elizabeth B.
Stone, of STONE La FAVER & STONE; the defendant is represented by
Joan Carey of LEGAL SERVICES, INC.
The defendant, Robert J. Grohman, hereinafter referred to as
the father, and the plaintiff, Tracy L. Grohman, hereinafter
referred to as the mother, agree to the entry of the following
Order regarding custody of their children, Samantha Nicole
Grohman d.o.b. 9-3-90 and Niko1as Mikel Grohman 2-1-93.
1. The mother and the father shall have shared legal and
physical custody of the children.
2. Physical custody shall be shared on an alternating
weekly schedule as follows:
Week 1: The mother shall have Monday after school
until Tuesday morning, Wednesday after school until 7:30 p.m. and
Thursday after school until Sunday at 6:00 p.m.. The father shall
have all other times.
Week 2: The mother shall have Wednesday after school
until 7:30 p.m. and Thursday after school until Friday at 8:00
a.m. The father shall have all other times.
3. The father and mother shall alternate custody on the
fOllowing holidays: Thanksgiving, Christmas, and Easter with one
parent having the children from the day before the holiday until
the holiday at 2:00 p.m. and the other parent having the children
from the holiday at 2:00 p.m. until the day after the holiday.
The mother shall have the period beginning the day before the
holidays in 1997, and odd numbered years thereafter.
4. The parent who has the children according to the
alternating weekly schedule in paragraph 2 will have custody on
the following holidays: Memorial Day, the Fourth of July and
Labor Day unless otherwise agreed by the parties.
5. The mother and the father shall alternate custody of the
children on their birthdays with the mother having them in 1998
and even number years thereafter.
6. The mother shall have the children on Mother's Day and
the father shall have the children on Father's Day.
7. During the summer months and when school is not in
session, the parties shall abide by the alternating weekly
schedule in paragraph 2 with custody being transferred at places
agreed upon by the parties.
8. The mother and the father shall have periods of vacation
with the children at mutually agreed upon times and with at least
two weeks notice to the other parent.
9. The mother and father, by mutual agreement, may vary
from this schedule at any time, but the Order shall remain in
effect until further order of court.
10. The mother and father agree that each shall notify the
other of all medical care the children receive while in that
parent's care. Each parent shall notify the other immediately of
medical emergencies which arise while the children are in that
parent's care.
11. The mother and the father shall discuss the children's
extra curricular activities before the children are enrolled.
12. The mother and father shall discuss pertinent issues
regarding thA children such as haircuts, braces etc. before
making a decision.
13. If either the mother or the father moves farther than 25
miles away from the other, the person who has moved will be
responsible for transportation of the children; neither party
shall move a distance which will make this order impractical
without modifying this order.
14. Neither the mother nor the father shall petition to
modify the custody order without first attempting to settle the
matter by agreement.
15. The parties realize that their children's well being is
paramount to any differences they might have between themselves.
Therefore, they agree that neither party shall do anything which
may estrange the children from the other parent, or injure the
opinion of the children as to the other parent or which may
hamper the free and natural development of the children's love or
respect for the other parent.
WHEREFORE, the parties request that an Order of Court be
entered to reflect the above terms.
-
~I\l'\b
.U-\"'- -
rohman, P intiff
~(). C}}7
R~-~ Grohman, Defendant
~~
Elizabe
Attorn y
STONE, er & STONE
414 Bridge Street P.O. Box E
New Cumberland, PA 17070
(717) 774-7435
Joan Carey
Attorney for Defendant
LEGAL SERVICES, INC.
a Irvine Row
Carlisle, PA 17013
(717) 243-9400
(i
I
I
I
I~
i
'~
~
~""\
.....:::.
-
...
.,
~
~
~
(";
(.~
~
v
t't.
,~:;::~
!. -;
. ~ I
. ,-
"' l~ '"!
-."
,."
~
" ;.'.
~ .~u:~;i
... .....-
...
(51r:1 I 7 1f)97
TRACY L. GROHMAN, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
v. I NO. 97-05604 CIVIL TBRM
I
ROBBRT J. GROHMAN, I CIVIL ACTION CUSTODY
Defendant I
~RD;7;F ;~~T1 ,
AND NOW ~pon review of Petitioner' s Petition for Emergency Relief,
custody of s~:ntha Nicole Grohman and Nikolas Mikel Grohman is hereby
awarded to Petitioner Tracy L. Grohman until further order of court.
J.
~ 1 i '
. [.,
~t)\'(&.~ '0lI,~d l..lLltt.\ S,\l;ILQ
[N(Jkc1 ~\o D{l- \.\:t:IV-AGrt.hlY\C<r\
I.
l,
'. ~
l "
" , .,
L.
,-. ,
-.-' ,.' :l
~'"'T~
III
II: Q
0 ..
... A Q
f/l ~ !::
. J w <
.. ~ ~ w ..
III ft !i ~ <i
III en w "
~ ~ ~ 8 ~
~ 9 : i ..
01 ..
..d g .. :0:
- "
. 0 < .. "
III f :.
II: . '"
0 "
...
f/l
"'
.
fl\c~.t\9rohaan.p.t\lQ-'7
TRACY L. GROHMAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
:
v. : NO. 97-05604 CIVIL TERM
:
ROBERT J. GROHMAN, : CIVIL ACTION CUSTODY
Defendant :
PETITION FOR EMERGENCY RELIEF
TO THE HONORABLE, THE JUDGES OF SAID COURT:
Petitioner, TRACY L. GROHMAN, by and through her attorneys, Stone
LaFaver & Stone, respectfully represents as follows:
1. Your Petitioner is Tracy L. Grohman, who resides at 828
Allenview Drive, Mechanicflburg, Cumberland County, Pennsylvania 17055.
2. The Respondent is Robert J. Grohman who resides at 828
Allenview Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055.
3. The Respondent has filed a complaint for custody to the above
term and number seeking custody of Samantha Nicole Grohman, age 7, born
September 3, 1990 and Nikolas Mikel Grohman, age 4, born on February 1,
1993. The children both reside with the Petitioner. The children were
not born out of wedlock.
4. The Petitioner and Respondent are husband and wife although
they are planning to separate at the end of this month. No complaint in
divorce has ever been filed either in the Court of Common Pleas of
Cumberland County, Pennsylvania, or anywhere else to the knowledge of
the petitioner.
-1-
S. On or about Octoher 1, 1997, Respondent advised the Petitioner
that he had met someone on the "Internet" and he had fallen in love with
her.
6. Respondent has asked Petitioner to leave the marital residence
and hae informed her that his new "Internet Love" is moving here from
out West, in a few weeks. Respondent hae indicated that when the
"Internet Love" moves here she will be moving in with him, and wants the
children to meet her and remain with them.
7. Respondent haB refueed to allow the Petitioner to leave with
the children, so she has not left the marital home at this time.
B. Petitioner fears for children's eafety in allowing a strange
woman to move into the marital residence and watch her small children.
9. Petitioner is currently employed as a manager of a local fast
food establishment and can provide a stable and loving home environment
for the children.
10. Respondent is currently collecting unemployment, refuses to
seek employment, believed to be so that he can spend many hours on the
computer talking in "Chat rooms" and seeking out other "Internet" love
connections.
11. Petitioner has found a new residence in the area and wishes to
move there with the children, allowing the Respondent liberal visitation
rights.
12. Respondent has threatened harm to the Petitioner if she leaves
with the children.
-2-
13. Petitioner seeks an order restoring the status quo and
granting temporary custody of Samantha Nicole Grohman and Nikolas Mikel
Grohman to Petitioner Tracy L. Grohman until such time as thie matter ie
resolved by agreement or further order of court.
WHEREFORE, petitioner requests this Honorable Court to enter an
order granting temporary physical custody of Samantha Nicole Grohman and
Nikolas Mikel Grchman to Tracy L. Grohman.
STONE LaFAVER &
(
zabeth B. Stop , Esquire
414 Bridge Str~t, P.O. Box E
New Cumberland, PA 17070
Telephone (717) 774-7435
Attorneys for Petitioner
-3-
.~
l'.J
'" . .. 0_ r-
c- IJ -:f.
c.., C
1..1 l/) \{I
,- M r-
, Q re l.()
, ,
, ":l
I. ~ 1=1
l~-: I ~
I..: ., <<..
'.1"...
c, tJ
,- r" :'-i
l...' . . (.l
...co:
~S
~~
i~
o a
U~
[jS
o
E-<U Z
8~S ~
U U
co:
~ ~
Z~O~
.
>
.
.,
tii
l:Il
o
l:l
o
E-<
<J)
l::>
U
cc
o
...
E-<
Z
H
:l
~
U
~
o
liq ~
ell ~ ~
III ft ~
~ ~ ~
~ I ~
..l w ~
. ~ c
f'.! f
;II .
o
...
IJJ
o
..
o
!:
8 ..
..
~ e
OJ 3
8 II
ii1 ..
'" "
:! ~
. "
~
..
:.
l><
<=>
o
E-<
<J)
l::>
U
....
....
'N
+'
<:
'N
a:t
i~
~
t:l
+'
~
'"
C
Q)
i~
o
cc
t:l
.
....:l
><
U
0,1
.
.. .
. .
S 1'11"01';, I..\F.\\'EIC N S niSI:
Ad '. .1.101 1', AT l A,'.
./oI.1,II':,[",j ',fI.,IT
"'-""11'1111111\''''' 1 \ll1Jl"
I'
fl\cu.L\lconcilr,ord
TRACY L. GROHMAN, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I C{l- S(P()4 C.,ji 1e((Y)
v. I NO.
I
ROBERT J. GROHMAN, I CIVIL ACTION CUSTODY
Defendant I
ORDER OF COURT
AND NOW, this
;;> -;.)
, 1997, upon
day of C',( ~()\:-..,(" r
consideration of the attached complaint, it is hereby directed that
the parties and their respective counsel appear before ~\~)() ,\,
':')J;,c\C\'-J E',,(l , the Conciliator, at '{() W \'-\(1\(\ ~+..
I' \,. ~
\,.l,n\"H,\[\h.r~. IA on the \ X day of t--.1"Ner\\hel , 1991,
at 9:()() , ~.M., for a Pre-Hearing Custody Conference. At such
conference, an effort will be made to resolve the issues in dispute1
or if this cannot be accomplished, to define and narrow the issues to
be heard by tho 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.
FOR THE COURT,
By: c-bnum. ~. ~I~~
Custody Conciliator (~)
YOU SHOULD TAKE THIS PAPBR TO YOUR LAWYBR AT ONCB. IF ~OU DO .or
HAVE A LAWYBR OR CANNOT AFFORD ONE, GO TO OR TBLEPHOIIB TO OPPICB
SBT PORTH BBLOW TO FIHD OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
Cumberland County Courthouse, 4th
Carlisle, PA 17013
Telephone: (717) 240-6200
fl\cu.t\9ro~n.not
TRACY L. GROHMAN, . IN THE COURT OF COMMON PLEAS OF
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
v. . NO.
.
ROBERT J. GROHMAN, . CIVIL ACTION LAW
Defendant . IN CUSTODY
HOTICE TO DEFEND
TO THE DEFENDANT NAMED HERE.
ROBERT J. GROHMAN
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
claims set forth in the following complaint, you must take action
within twenty (20) days after the complaint and notice are served, by
entering a written appearance personally or by attorney and filing in
writing with the Court your defenses or objections to the claims set
forth against you. You are warned that if you fail ~o do so, the case
may proceed against you and a judgment may be entered against you by
the Court without further notice for any money claimed in the com-
plaint or for any other claim or relief requested by the plaintiff.
You may lose money or property, or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCB.
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONB,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
Cumberland County Courthouse
Fourth Floor
Carlisle, PA l70l3
Telephone: (717) 240-6200
'1\cu.t\9.ohaan,cae
v.
I
I
I
I
I
I
I
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION CUSTODY
NO. '/ ,) . " (.. (J'f (!,,~ '-4--,
TRACY L. GROHMAN,
Plaintiff
ROBERT J. GROHMAN,
Defendant
COMPLAINT FOR CUSTODY
1. The plaintiff is TRACY L. GROHMAN, an adult individual,
residing at 828 Allenview Drive, Mechanicsburg, PA 17055.
2. The defendant is ROBERT J. GROHMAN, an adult individual,
residing at 828 Allenview Drive, Mechanicsburg, PA 17055.
3. Plaintiff seeks primary physical custody of SAMANTHA NICOLE
GROHMAN who resides at 828 Allenview Drive, Mechanicsburg, PA 17055,
is seven (7) years of age having been born on September 3, 19901 and
NIKOLAS MIKEL GROHMAN who also resides at 828 Allenview Drive,
Mechanic~burg, PA 17055, is four (4) years of age having been born on
February 1, 1993. The children were not born out of wedlock.
The children are presently in the custody of their mother,
the Plaintiff above-named, Tracy L. Grohman, and their father, the
defendant, Robert J. Grohman. They reside at 828 Allenview Drive,
Mechanicsburg, PA 17055.
The plaintiff seeks primary physical custody of the children,
since she will be moving out soon with the children, at the request of
the defendant. Plaintiff agrees to shared legal custody of the
children with the defendant enjoying liberal minority physical
-1-
custody. The plaintiff will be moving to a new address at 4 Logan
Road, Dillsburg, Pa 17019.
During the past five years, the
children have resided with the following persons and at the following
addresses:
NAl:m.
Tracy L. and
Robert J. Grohman
ADDRESS
828 Allenview Drive
Mechanicsburg, PA 17055
382 Old Fort Road
King of Prussia, PA
DATES
12/14/96-
10/97
7/95-12/96
same
same
Wynnewood Avenue
Harrisburg, PA
9/90-7/95
The mother of the children is the plaintiff, Tracy L. Grohman,
currently residing at 828 Allenview Drive, Mechanicsburg, PA 17055.
She and the Defendant are husband and wife.
The father of the children is the defendant, Robert Joseph
Grohman, currently residing at 828 Allenview Drive, Mechanicsburg, PA
17055. He is married to the plaintiff.
4. The relationship of plaintiff to the child is that of mother.
The plaintiff currently resides with the following persons:
.HM:m.
Robert Joseph Grohman, the defendant
RELATIONSHIP
husband
S. The relationship of defendant to the children is that of
father. The defendant currently resides with the following persona.
NAME
Tracy L. Grohman, the plaintiff
RELATIONSHIP
wife
-2-
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:
(a) The children have resided with their mother since birth
who has provided a continuous living relationship with the children 1
(b) The mother is able to provide a stable home and family type
environment for the children allowing the children opportunity to
spend time with the children's father consistent with a schedule the
parties have arranged between themselves.
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.
-3-
pd\.i.\l:v.rLfL.alf
VERIFICATION
TRACY LYN GROHMAN, states that she is the Plaintiff named in the
foregoing instrument and that she is acquainted with the facts set
forth in the foregoing instrument 1 that the same are true and correct
to the best of her knowledge, information and belief 1 and that this
statement is made subject to the penalties of 18 Pa. C.S.A. S 4904
relating to unsworn falsification to authorities.
DatelOC+ ~ 1917