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KENNETH L. ZEIGLER, JR.,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
NO. 97 - 5831 CIVIL
IN CUSTODY
v
PAMELA L. ZEIGLER,
Defendant
~OURT ORDER
AND NOW, this &1 day of December, 2000, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
I. A hearing is sched.l1led in Courtroom No. 2 of the Cumberland County Courthouse
on the 1st day of '-jJlaLcL ,2001, at
/: ~('.... eM. at which time testimony will be taken on the Father's Petition
for Contempt. The Father, Kenneth L. Zeigler, Jr., shall be the moving party and
shall proceed initially with testimony.
2. Pending said hearing and pending any further Order of Court, this Court's prior
Order of June 20, 2000 shall remain in effect and Mother is hereby directed to abide
by the custody provisions of that Order. Additionally, Father shall also have custody
of the minor child on Friday, December 22, 2000 from 4:00 p.m. until 8:00 p.m.
This shall be in addition to the time Father is scheduled to exercise custody with the
minor child on Christmas Day pursuant to the June 20, 2000 Order.
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J.
cc:
Marcus A. McKnight, Esquire .,. ,...:t..~ I.J..;J 1- tv
Bradley L. Griffie, Esquire C.f'';''
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LA W
NO. 97 - S83I CIVIL
IN CUSTODY
KENNETH L. ZEIGLER, JR.,
Plaintiff
PAMELA L. ZEIGLER,
Defendant
Prior Judge: Edgar B. Bayley
CONCILIATION CONFERENCE SUMMARY ~PORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the following report:
I. The pertinent infonnation pertaining to the child who is the subject of this litigation is as
follows:
Kenneth Nonnan Zeigler, born March 27, 1994.
2. A Conciliation Conference was held on December 20, 2000 with the following individuals
in attendance:
The Father, Kenneth L. Zeigler, Jr., with his counsel, Marcus A. McKnight, Esquire; and the
Mother, Pamela L. Zeigler, with her counsel, Bradley L. Griffie, Esquire.
3. Before the Court is a Petition for Contempt and special relief. The parties are at odds and
could not reach an agreement. The Conciliator recommends the entry of an order in the
fonn as attached.
t;;'/:ll/OO
DATE I
VJt1w
Hubert X. Gilroy, Esq .
Custody Conciliator
.
KENNETU L. ZEIGLER, JR..
Plaintiff/Respondent
JAN I I
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
; CIVIL ACTION - LAW
'IJIJ,~
v.
PAMELA L. ZEIGLER, NO. 97.5831 CIVIL TERM
Defendant/Petitioner : IN CUSTODY
OJlDER OF COURT
AND NOW this II day of ") VlttI/t. , 2001 upon presentation and
consideration of thc within Petition lor Contempt and Spcdal Relief, it is hereby ordered and
directed that the request made by Defendant/Petitioner to find Plaintiff/Respondent in contempt
and to modify the Custody Order based upon the request for special rclief shall be heard before
the Court on March I, 2001, at 1:30 p.m, in Courtroom II 2 of the Cumberland County
Courthouse, Carlisle. Pennsylvania, togcther with the Pctition for Contempt and Spccial Relief
prcviously filcd by PlaintifT/Respondcnt.
Plail ff/Re: ondcntm~ kcep Dcfjl1dant/Pctitio/ler advise1l alltimerof hi]' reside?ce,
his home elepho e number 'fd thc arral"gcmcnts for <pre of the c1fild at any Jime tfllltthe ~i1d
is wi Plainti iRcspondent.
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BY TUE COURT,
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Edgar B, Bayley, Judgc
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Marcus A. McKnight, III, Esquire
Allomey fo/' PlaillliJPRespollilell1
Bradley L. Gri mc. Esquire
AllomeyjiJ/' Deji!lldl/III/Pelilioller
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KENNETH L. ZEIGL.ER, JR"
Plainti ff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLVANIA
v.
: CIVIL ACTION . LAW
PAMELA L. ZEIGLER, NO. 97.5831 CIVIL TERM
Defendant/Petitioner : IN CUSTODY
fEIjTION FOR CONTEMPT AND SPECIAL REIJEF
COUNT I
Contempt
AND NOW comes Petitioner, Pamela L. Zeigler, by and through her counsel of record,
Bradley L. Griftie, Esquire, and the law lirm of Griflie & Associates and petitions the Court as
follows:
I. Your Petitioner is the above named Defendant, Pamela L. Zeigler, an adult individual
currently residing at 1466 Woods Road, Lot 4. Shippensburg, Cumberland County,
Pennsylvania.
2. Your Respondent is the above named Plaintiff, Kenneth L. Zeigler. Jr., an adult
individual whose last known residence is 1420 Valley Road, Marysville, Perry
County, Pennsylvania.
3. The parties are the natural parents of one child, namely, Kenneth Nonnan M. Zeigler,
born March 27, 1994,
4. The parties are subject to and Order of Court dated June 20, 2000, relative to eustody
of the child, which Order is attached hereto and incorporated herein by reference as
Exhibit "A."
5. Respondent has a history of intermiuenl involvement in the child's life, where he is
involved in Ihe child's life for a period of time and then has no involvement or
contact with the child for a period of time.
6. On or about October 7. 2000, as the parties wcre attempting to exchange custody of
the child following the child's soccer game, Respondent and his girlfriend becamc
vcrbally confrontational and threatcning to Petitioner, which caused great fear for
Petitioner, particularly since she has a Protection from Abuse Order in effect against
Respondent.
7. Because of the threats of Respondent and his girlfriend, the local police department
was called and intervened.
8. By the time the police arrived, Respondent and his girlfriend had left the scene and
made no further contact whatsoever with Petitioner or the child for the remainder of
the weekend and, therefore, Respondent did not exercise his visit that weekend.
9. At the time of thc next scheduled visit on October 21, 2000, Respondent appeared at
Petitioner's home on Saturday morning contrary to the arrangements that the parties
had agreed upon and followed since August 2000, whereby the parties exchanged
custody of the child following the child's soccer game on Saturday morning.
10. When Petitioner reminded Respondent that they had followed these arrangements for
several months and she expected to take the child to his soccer game, where the
custody exchange would occur afterwards, Respondent became irate and left
Petitioner's home.
11. Respondent made no contact whatsoever with Petitioner or the child from the
morning of October 21, 2000, until the conciliation conference held on this mailer orl
December 20,2000, on Respondent's Petition for Contempt and Special Relief.
12. For a period of two months, as had bcen Respondent's pallem, Respondent made no
contact whatsoever with the child and failcd to comply with the Court's Order of June
20, 2000, as follows:
a.) Respondent did not appear for any of his scheduled visits from October 21, 2000,
forward until following the conciliation on December 20, 2000;
b.) Respondent failed to notify Petitioner at least forty. eight (48) hours in advance if
he was working and, therefore, was unable to exercise the various periods of
partial custody that were to have occurred from October 21, 2000, through
December 20, 2000, which notice is required under the Order if the visits arc not
to be exercised;
c.) Respondent made no contact whatsoevcr with the Child or Petitioner relative to
his period of holiday time that he was to spcnd with the child over Thanksgiving
vacation period pursuant to the Court Ordcr;
d.) When in Respondent's care. Respondent has failed to provide the child with
prescribcd medications and trcatment as required by paragraph 8 of the aforesaid
Order; and
16. Petitioner and the conciliator urged Respondcnt to make tclephone contact with the
child since he had once again cxperienced a several month period of not having any
contact whatsoever with the child, and in order to ease the concems of the child
relative to Rcspondcnt's desire to have conlact with the child.
17. Respondent made one telephonc call on the evcning of Dcccmber 21, 2000, and
spokc to the child for approximatcly two minutcs.
18, Thc contact with thc child on Friday Dcccmbcr 22, 2000, and on Christmas Day
appearcd to occur without incident and thc child responded favorably to those visits,
19, Respondent's ncxt schcdulcd visit occurrcd on Dcccmbcr 30.31 pursuant to the
Court's Ordcr of June 20, 2000.
20. The child rcturncd from the visit that weckend in a hysterical condition duc to what
occurrcd ovcr his wcckcnd with Respondent, without any commcnt from Respondent
to Pctitioner conccrning what occurred over thc wcekend,
21, Petitioncr and hcr parcnts allcmptcd to calm thc child and discover what had created
such an cmotional disturbancc for the child.
22. The child finally began to discuss somc of the issues and incidents that occurrcd at
Respondcnt's rcsidcnce over the wcekend which caused him to be so extremely upsct
and afraid of furthcr in volvcmcnt with Rcspondcnt,
23. The child adviscd Petitioner and hcr parent's that:
a.) Saturday, December 30, 2000, during his visit with Respondent he was taken to
another woman's home and introduced to the woman in a fashion that eaused the
child to believe this wus Respondent's new girlfriend, even though Respondent is
residing with another girlfriend;
b.) Respondent advised the ehild that, at this point, he had not made plans to move
from his current girlfriends to his new girlfriend's home;
e.) On Sunday, December 31, the child, his cousin, and his paternal grandparents
(Respondent's mother and stepfather) were removed from the home by
Respondent's girlfriend. who owns the home and advised not to return;
d.) The child, his cousin, and his paternal grandparents went into the basement in the
home through an outside entrance, as the child in particular had no where else to
go at that time;
e.) During the remainder of the day the child, his cousin, and his paternal
grandparents remained in the basement of Respondent's girlfriend's home while
Respondent and his girlfriend were engaged in a extreme verbal and physical
alterclltion in the upstairs living quarters of the home that could be heard by the
child;
f.) Res!Jondentthen sat the child down and diseusscd with the ehild that Respondent
would be living somewhere else and, therefore, his visits with his son would take
place somewhere else;
g.) As part of Respondent's girlfriend's tirade she advised the child that she would be
keeping his dog and the child would not see his dog again;
h.) On Saturday night, the child slept on the couch in the home with his father rather
then either of them sleeping in beds for reasons that were unknown to the ehild
but which caused him concern and fear; and
L) On Sunday, as the child was being dropped ofT, Respondent's girlfriend, who
came along to return the child told the child "( hope like hell you never come
back here again."
24. All of what the ehild witnessed over the weekend has caused him to be extremely
fearful and afraid to be with Respondent and particularly around Respondent's
girlfriend.
25. The child has had difficulty at times in his relationship with Respondent and refused
to have contact with Respondent, which ha~ caused Petitioner to positive toward and
extremely supportive of that relationship, as well as forceful with the child in
requiring him to maintain his contact with Respondent, as had occurred from the
entry of the Order on June 20, 2000, through September 2000.
26. Since the incidcnts referenced above, Respondent has made no contact whatsoever
with Petitioner or with the child to advise Petitioner of any changes in his living
arrangement nor to alleviate his fears. concerns, and emotional turmoil of the child.
27. Respondent has a histl1ry of physical abuse of Petitioner and threats of physical abuse
against her, which has resulted in the entry of various Protection from Abuse Orders
against Respondent over the past several years.
2M, The physical and verbal altercations, which the child witnessed and/or olverheard, the
child's prior witnessing of such alterations between Respondent and his girlfriend,
along with all of the mailers incidental to those confrontations have created
tremendous fear in the child of returning to Respondent's home with Respondent's
girlfriend, fear of being around Respondent's girlfriend, and, in general, a fear of
being away from Petitioner,
29. The child has been begging Petitioner asking that he not be required to go with
Respondent for his upcoming visits.
30, Although Petitioner is very concerned over adverse repercussions of making contact
with Respondent. particularly at Respondent's girlfriend's residence, she has
suggested to the child that he telephone Respondent with Petitioner's assistance,
which the child vehemently refuses to do.
31, The child, who will be seven years old in two months, does well in school, is already
involved in extracurricular activities, and is otherwise a good and responsible child.
32. Petitioner did not promote or suggest any responses to the child relative to the cause
of his emotional state upon returning from his last visit with Respondent, but rather
simply asked the child to explain his emotional turmoil and reason for his fear.
JJ. Petitioner believes and, therefore, avers that the present situation in Respondent's
homc, eombincd with Fathcr's limitcd relationship with the child is having and will
continue to have a negativc, pennanent impact upon the child psychologically,
emotionally, and mentally.
WHEREFORE, Petitioner requests your Honorable Court to enter an Order vacating
Respondent's periods of partial custody us set forth in the Order of June 22, 2000, direct the
parties to make arrangements for Respondent to have supervised contact with the child pending
the hearing in this mailer scheduled for March I, 200 I, and take testimony relative to the within
Petition for Contempt and Special Relief at the hearing presently scheduled in this matter for
March I, 200 I, at 1 :30 p.m.
Respectfully submitted,
(
riffie, Esquire
jar De!el/{lulII/Pelilioner
IFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347.5552
.JUN 0 7 2000 fJ
KENNElli L. ZEIGLER, JR.,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CU~mERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 97-5831 CML
IN CUSTODY
v
PAMELA L. ZEIGLER.
Defendant
COURT ORDER
AND NOW, this dO day of June, 2000, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
I. All prior custody orders are vacated.
2. The Mother, Pamela L. Zeigler, and the Father, Kenneth L. Zeigler, Jr., shall enjoy
shared legal custody of Kenneth N. M. Zeigler, born Man:h 27,1994.
3. The Mother shall enjoy primary physical custody of the minor child.
4. Father shall enjoy periods of temporary physical custody of the minor child as
follows:
A. On alternating weekends during the swnmer from Saturday at 8:00
a.m. until Sunday at 8:00 p.m. During the school year, Father shall
return the child on Sunday evening at 7;00 p.m. In the event Father
knows he will be working on a weekend that he is scheduled to have
custody of the minor child, Father shall notify Mother at least 48
hours in advance that he has work that weekend and he will not be
exercising custody. The parties will work between themselves to
arrange for a make-up we~kend.
5. The holidays of July 4111, Labor Day, Easter and :Vlemorial Day shall be alternated
with Mother having July 4111 in 2000 and Easter in 2001. with Father having Labor
Day in 2000 and MemOlial Day in 2001. The parties will alternate thereafter.
6. The Thanksgiving holiday shall be handled with Mother having custody from 9:00
a.m. until 3:00 p.m. and the Father having custody from 3:00 p,rn. until 8:00 p.m.
The Christmas holiday shall be handled with Father having custody on Christmas
Eve from 9:00 a.m. until 8:00 p.m. and Mother having custody from 8:00 p.m. on
Christmas Eve through the end of Christmas Day. New Year's holiday shall be
handled with Father having custody from 9:00 a.m. on New Year's Eve until 8:00
p.m. on New Year's Eve and Mother ha\;ng custody from 8;00 p.m. on New Year's
Eve through New Year's Day.
EXHIBIT A
7. Starting in the summer of 2001, Father shall have one week of vacation with the
minor child whicr. shall be Father's week off work. Father shall nOlify Mother in
May of each year as 10 the specific date of his week off from work. Mother shall
also be entitled to take one week of vacation in the summer that may require Father
10 altemate his visitation schedule depending upon when Mother will be exercising
her week of summer vacation with the minor child.
8. Both parents shall ensure thaI the minor child is provided with doctor prescribed
medication in accordance with any prescriplion thaI is provided by any treating
physician.
9. Neither party shall expose the child 10 cigarette smoking when the child is in their
custody.
10. Father shall provide Mother with a lelephone nWllber thaI he can be reached at all
times, to be Father's beeper nwnber or cell phone number. In the event Father does
not return calls or il becomes problemalic 10 the degree that Mother is WUlble 10
reach Father in times of necessity, Father will be required in the future 10 provide
Mother with his home phone number.
It. In the event either party desires 10 modify this order in the future, that party may
petition the Court 10 have the case again scheduled for a Cuslody Conciliation
Conference.
BY TIlE COURT,
ISk")~/1h) Il..&/-;
Edgar B. ayley
cc: Bradley L. Griffie, Esquire
Marcus A. McKnight, m, Esquire
T~'!J! COpy FRO RECO~D
In To.: "! f.' .'d. I h"e nlO set my hind
.nd 110; ;.;;.1 of uid (JurI a arlisle. Pa.
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ProlhonotalV
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IN TIlE COURT OF COMMON PLEAS OF
CilltffiERLAND COUNTY, PENNSYL V AN1A
CIVIL ACTION. LAW
NO. 97.5831 CIVIL
IN CUSTODY
KENNETII L. ZEIGLER, JR..
Plaintiff
PAMELA L. ZEIGLER,
Defendant
Prior Judge: Edgar B. Bayley
CONCILI~UON CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH TIlE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
191 SJ.8(b), the W1de~igned Custody Conciliator submits the following repott:
I. The pertinent information pertaining to the child who is the subject of this litigation is as
follows:
KeMeth N. M. Zeigler, born March 27, 1994.
2. A Conciliation Conference was held on June \, 2000, with the following individuals in
attendance:
The Father, Kenneth L. Zeigler, Jr., with his counsel, Marcus A. McKnight, III, Esquire; and
the Mother, Pamela L. Zeigler, with her counsel, Bradley L. Griffie, Esquire.
3. Based upon the recommendation of the Conciliator, the parties tentatively agree to the entty
of an order in the fonn as attached.
0!~/(;b
DATE
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KENNETH L. ZEIGLER. JR..
Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
97-3831 CIVIL TERM
PAMELA L. ZEIGLER,
Respondent
IN CUSTODY
ORDER OF COURT
AND NOW. this ~ day of October 2000, upon consideration of the attached Petition
for Special Relief,
IT IS HEREBY ORDERED that a hearing regarding this Petition for Special Relief is
hereby scheduled for 'II f1,lt~. -.k., 2000, at ~'clock -f-.m. in Courtroom Number
~, Cumberland County Courthouse, Carlisle, Pennsylvania 17013 at which time the parties
along with their legal counsel shall appear in person.
Edgar B. Bayley, udge
t~ 1Y{aJuL
/(J -/9-00
RJ{.3 .
KENNETH L. ZEIGLER, JR.,
Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
~~
,
v.
CIVIL ACTION - LAW
97-5831 CIVIL TERM
PAMELA L. ZEIGLER,
Respondent
IN CUSTODY
PETITION FOR SPECIAL RELIEF
AND NOW, this 16th day of October 2000, comes thc Petitioncr, Kcnneth L. Zeigler, Jr.,
by his attorneys, Irwin, McKnight & Hughes, and makes thc following Petition for Special Relief
against the Respondent, Pamcla L. Zciglcr:
I.
Thc pctitioner is Kenncth L. Zeiglcr, Jr., an adult individual who resides at 1420 Vallf.Y
Road, Marysvillc, Perry County, Pcnnsylvania 17053.
2.
The rcspondcnt is Pamcla Lcc Zeiglcr, an adult individual whose current address may be
1466 Woods Road, Lot #4, Shippensburg, Cumberland County, Pennsylvania 17257.
3.
The parties arc thc natural parents of one minor child, namely Kenneth Nonnan Marshall
Zciglcr, born March 27, 2994.
2
4.
Upon consideration of the Custody Conciliation Report, Edgar B. Bayley, Judge, issued
an Order of Court dated June 20, 2000, which granted periods of temporary physical custody of
Kenneth Norman Marshall Zeigler. A copy of that Order of Court is attached hereto and is
marked as Exhibit "A".
5.
The respondent, Pamela L. Zeigler, has refused to abide by Order of Court dated June 20, 2000,
by refusing to allow Petitioner, Kenneth L. Zeigler, Jr., his periods of temporary physical custody
as indicated in said Order without interference on interruption.
6.
The petitioner seeks to maintain his periods of temporary physical custody of the minor
child as stated in the Order of Court dated June 20, 2000, without interference or interruption by
the respondent.
7.
On Saturday, October 7,2000. the parties had agreed that custody of Kenneth Nonnall
Marshall Zeigler would transfer immediately following his soccer game at approximately 12:00
noon. The petitioner sought to exercise his period of temporary custody. The respondent placed
their son in her car, locked the doors, and refused to let him leave with the petitioner.
3
EXHIBIT A
JUN 0 7 2000~
KENNF.TIl L. ZEIGLER, JR.,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 97.5831 CIVIL
IN CUSTODY
v
PAMELA L. ZEIGLER,
Defendant
COURT ORDER
AND NOW, this ,J() day of June, 2000, upon consideration of the attached Custody
Conciliation Report, it Is ordered and directed as follows:
I. All prior custody orders are vacated.
2. The Mother, Pamela L. Zeigler, and the Father, Kenneth L. Zeigler, Jr., shall enjoy
shared legal custody of Kenneth N. M. Zeigler, born March 27,1994.
3. The Mother shall enjoy primary physical custody of the minor child.
4. Father shall enjoy periods of temponuy physical custody of the minor child as
follows:
A. On alternating weekends during the sununer from Saturday at 8:00
a.m. until Sunday at 8:00 p.m. DIlling the school year, Father shall
return the child on Sunday evening at 7:00 p.m. In the event Father
knows he will be working on a weekend that he Is scheduled to have
custody of the minor child, Father shall notify Mother at least 48
hours in advance that he has work that weekend and he will not be
exercising custody. The parties will work between themsdves to
arrange for a make. up weekend.
5. The holidays of July 4th, Labor Day, Easter and Memorial Day shall be alternated
with Mother having July 4th in 2000 and Easter in 200 I, with Father having Labor
Day in 2000 and Memorial Day in 200 1. The parties will alternate thereafter.
6. The Thanksgiving holiday shall be handled with Mother having custody from 9:00
a.m. Wltll 3:00 p.m. and the Father having custody from 3:00 p.m. until 8:00 p.m.
The Christmas holiday shall be handled with Father having custody on Christmas
Eve from 9:00 a.m. until 8:00 p.m. and Mother having custody from 8:00 p,m. on
Christmas Eve through the end of Christmas Day. New Year's holiday shall be
handled with Father having custody from 9:00 a.m. on New Year's Eve WlIII 8:00
p.m. on New Year's Eve and Mother having custody from 8:00 p.m. on New Year's
Eve through New Year's Day.
KENNETH L. ZEIGLER, JR.,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
NO. 97-5831 CIVIL
IN CUSTODY
~.
v
PAMELA L. ZEIGLER,
Defendant
Prior Judge: Edgar B. Bayley
CONCILlA nON CONFERENCE SUMMARY REPORT
IN ACCORDANCE WffiI THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undcrsigned Custody Conciliator submits thc following report:
I. The pertincnt infonnation pertaining to thc child who is the subject of this litigation is as
!ollows:
KeMeth N. M. Zeigler, born March 27, 1994.
2. A Conciliation Conference was held on June I, 2000, with the following individuals in
attendance:
The Father, KClUlcth L. Zeigler, Jr., with his counsel, Marcus A. McKnight, III, Esquire; and
the Mother, Pamela L. Zeigler, with her counsel, Bradley L. Griffie, Esquire.
3. Based upon the recommendation of the Conciliator, the parties tentatively agree to the entry
of an order in the fonn as attached.
~ Ct lOb
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The foregoing Petition for Special Relief is based upon infonnation which has been
gathered by counsel and myself in the preparation of this action. I have read the statements made
in this document and they are true and correct to the best of my knowledge, infonnation and
belief. [understand that falsc statements hcrein made arc subject to the pcnaltics of 18 Pa.
C.S.A. Section 4904, relating to unsworn falsification to authorities.
Date: 10 - \1....
,2000
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KENNETH I.. ZEIGl.ER, JR..
Plainliff
IN n IE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYL VANI,\
v
CIVIL ACTION. l.A W
PAMELA L. ZEIGLER,
Defendant
NO. 97.583 I CIVIL
IN CUSTODY
t
"
COURT ORDER
AND NOW,this q;tJ..- day of April. 1999, upon considcralion of the attached Custody
Conciliation Report, it is ordered and direcled as follows;
I. A hearing is scheduled in Courtroom No.2 of the Cumberland Coumy Courthouse on
Ihe I :l.~ay of "'y? la.~ ' 1999, at2:.ts.t!.M. at which time testimony will be
taken in the above case. oAI this hearing, the Father. Kenneth L. Zeigler. Jr" shall be
the moving party and shall proceed initially with testimony. The hearing will be
limited to Father's petition to hold Mother in comempt for violation of the existing
Custody order and on Mother's rcquestto have the existing Custody Order be modified
on the issue of whether Father's visitation with the minor child shall be limited only to
homes that do not include ~ cats or other.animals !hat would adversely affect the
child's asthma condition. ..... j ;:tl..., .fc-J"'..... c~ ,.".... ~ a,.,.,-,-C
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2. Pending further order fonn this court, the existing order of November 16, 1998 shall
remain in effect subject to the following modi fications:
A. Father's periods of alternating weekend visitation with the minor child
shall be on alternating weekends on SalUrday and Sunday of each
weekend from 8:00 a.m. until 8:00 p.m. Father shall pick up the minor
child at the maternal grandfather's house. These p~'liods oflemporary
custody shall not extend into overnight until after the Court conducts a
hearing on the matters outlined above.
B. In all other respects, the November 16, 1998 order shall remain in
effect.
BY THE COURT,
cc:
Michael Rundle, Esq.
Kenneth Zeiglcr
IS l C'(l"c.~ -Jj. ";)~,~ C;j J.
Tr.UE COpy FRO~A RECORD
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This 9 -;tL dJY of D.{:Ji..C . 19..1.'i..
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
KENNETH L. ZEIGLER. JR"
PlaintilT
PAMELA L. ZEIGLER,
Defendant
NO, 97-5831 CIVIL
IN CUSTODY
~'1!"
,
COURT ORDER
AND NOW, this gl.h day of April, 1999, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
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A hearing is scheduled in Courtroom No.2 of the Cumberland County Courthouse on
the ~dayof '-'Y'i'~, 1999, at<J..!s:JL.M. at which time testimony will be
taken in the above cose. IS hcanng, the Father, KeMeth L. ZeIgler, Jr., shall be
the moving party and shall proceed initially with testimony. The hearing will be
limited to Father's petition to hold Mother in contempt for violation of the existing
Custody order and on Mother's request to have the existing Custody Order be modified
on the issue of whether Father's visitation with the minor child shall be limited only to
homes that do not include any cats or other animals that would adversC\1y affect th~ e.JI...
child'sosthmaconll.itio!1. r4=~ v7u..~ rlM~~, CN'_~ )<\"',....
\Ssua.,~~n~~l-. ~. I~
Pending further order fonn this court, the existing order of November 16, 1998 shall '--:,(,/'
remain in effect subject to the following modifications:
2.
A. Father's periods of alternating weekend visitation with the minor child
shall be on alternating weekends on Saturday and Sunday of each
weekend ITom 8:00 a.m. until 8:00 p,m. Father shall pick up the minor
child at the maternal brrandfathcr's house. These periods ofternporary
custody shall not extend into ovemight until after the Court conducts a
hearing on the mailers outlined above.
B. In 011 other respects, the November 16, 1998 order shall remain in
effect.
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Kenneth Zeigler
I
v
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
KENNETH L.. ZEIGLER, JR.,
Plainlit1.
PAMELA L. ZEIGLER,
Defendant
NO. 97.5831 CIVIL
IN CUSTODY
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Prior Judge; Edgar B, Bayley
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b).the undersigned Custody Conciliator submits the following report:
I. The pertinent inlormation pertaining to the child who is the subject of this litigation is as
follows:
Kcnneth M. N. Zeigler, born March 27,1994.
2. A Conciliation Conference was held on April I , 1999, with the following individuals in
attendance:
The Father, Kenneth L. Zeigler, Jr., who appeared without counsel; and the Mother, Pamela
L. Zeigler, with her counsel, Michael Rundle, Esquire.
4.
Father is now petitioning for contempt alleging that Mother interfered with his custody on
the first 2 scheduled visitations last year. Mother counters that Father has not made any
attempt to see the child at all over the past J months. Furthermore, Mother suggests that
Father has cats at his home and that the child should not be exposed to the cats. Father
indicates that he disagrees with Mother's position on that matter.
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3.
This is the second time this case is before the Conciliator in 6 months. Last November, the
Conciliator conducted a conference in this case relating to Father's pro se petition to hold
Mother in contempt. At that time, an agreement was reached with Father to have specified
periods of visitation on alternating wcekends.
5. The Conciliator advised the Mother that she must abide by the existing Order. The
Conciliator also advised the Father that he must appear as scheduled under the existing
Order or forfeit any suggestion that the Mother is in contempt.
6. A hearing is required in this matter. Because of the difficulties lhat have been encountered
over the last few months, the Conciliator believes the prior order needs to be slightly
modified.
7. Thll Conciliator recommends an order in the form as attached.
~
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NQV 1 3 1995/.iJ
KENNETlI L. ZEIGLER, Jr..
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
CIVIL ACTION - LAW
NO.97.5831 CIVIL
IN CUSTODY
PAMELA L. ZEIGLER,
Defendant
COURT ORDER
AND NOW. this \ b day of November, 1998, upon consideration of the attached Custody
Conciliation Report. it is ordered and directed as follows:
I. This Court's prior order of January 20, 1998 is vacated.
2. The Father's petition for contempt is deemed withdrawn with the understanding
that, in the event Father files any similar petitions in the future, Father may raise
issues from the prior Pctition for Contcmpt in any future petitions.
3. The Mother, Pwncla L. Zeiglcr, and the Father. Kenncth 1.. Zeiglcr, Jr., shall enjoy
shared legal custody of the minor child Kcnneth N.M. Zeigler, born March 27,
1994.
4. The Mother shall enjoy primary physical custody of thc minor child.
5. The Father shall enjoy temporary physical custody ofthc minor child as follows:
A. On alternating weckcnds on Saturday and Sunday from 6:30 a.m.
until 6:30 p.m. Fathcr shall provide transportation for exchange of
custody. In thc cvent Fathcr cannot pick thc child up by 6:30 a.m. on
each morning, Fathcr shall notify Mothcr in advance by 6:00 a.m. If
Fathcr is late or unablc to comc early in the morning, Mother shall
then havc thc option of thcn delivering thc child to her Father's
hornc where thc Fathcr may pick thc child up.
B. At such othcr timcs as agrced upon by thc partics.
C. Fathcr's altcrnating wcekend custody, effective Fcbruary I. 1999,
shall includc an ovcrnight and shall cxtcnd from Saturday morning
through Sunday evcning.
6. For Thanksgiving 1998, Fathcr shall have custody fonn 3:00 p.m. until 8:00 p.m.
7. For the Christmas holiday, Father shall have custody from 9;00 on Christmas Eve
until 8:00 p.m. on Christmas Eve. Mother shall enjoy Christmas Day with the child.
8.
For New Year's. Father shall have custody from 9;00 a.m. on New Year's Eve until
8:00 p.m. on New Year's Eve, with Mother enjoying custody on New Year's Day.
This custody schedule shall supercede the alternating weekend schedule.
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9. Neither party shall expose the child to cigarette smoking when the child is in their
custody.
10. Neither parent shall make disparaging remarks to the child concerning the other
parent or the other parent's family.
II. Both parties shall enjoy reasonable telephone contact with the minor child when the
child is in the other parents' custody.
.,
J.
cc: Michael Rundle, Esquire
Kenneth Zeigler
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KENNETH L. ZEIGLER, JR.
Plaintifi.
IN THE COURT OF COMMON PLEAS OF
CUMBERI.AND COUNTY. PENNSYLVAN[A
v
CIVIL ACTION - LAW
NO. 97-583 [ CIV[L
IN CUSTODY
PAMELA L. ZE[GLER.
Defendant
Prior Judge: Ed.....ard E. Guido
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the following report:
I. The pertinent infonnalion pertaining to the child who is the subject of this litigation is as
follows:
Kenneth N.M. Zeigler. born March 27,1994.
2. A Conciliation Conference was held on November [2. [998, with the following individuals
in attendance:
The Father. Kenneth L. Zeigler, who appeared without counsel; and the Mother, Pamela L.
Zeigler. with her counsel Michael R. Rundle, Esquire.
3. The parties agree on the entry of an order in the limn as attached.
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Custody Conciliator
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- IN THE COURT OP COMMON PLEAS OP CUHBHRLAND COUNTY
DOCKET NO. 97-5831
KENNETH L. ZEIGLER JR.
B5 Parsonage Street
Newville, Pa. 1724i
vs.
PAMELA L. ZEIGLER
341 Farmington Drive
Shippensburg, Pa. 17257
Plaintiff
Defendant
PETITION FOR PSYCHOLOGICAL EVALUATION
I, KENNETH L. ZEIGLER JR., representing myself, am requesting that
my wife PAMELA L. ~EIGLER undergo a psychological evaluation.
Due to the events which have occurred during our marriage and since
our separation, I am inclined to believe that Pamela has an existing
and ongoing mental health issue which needs to be addressed.
I feel my sons' well-being depends on whether Pamela receives appropriate
attention in this matter and subsequent help to deter further inapropriate
behavior which is affecting my sons' well-being, attitude and growth as
a person.
There are numerous reasons for this request, the number one being I
feel my son will display these same negative qualities later in life
if there is not intervention at an early stage.
I would also ask the Court to Order an evaluation of my son to ensure
there is no permanent damage done by Pamelas' constant "authoritarian"
,
style of parenting.
Please find attached a partial listing of issues warranting the above
request for a psychological evaluation. There are many more if the
Court finds a need for more information.
FOR THESE REASONS, I request the Court schedule a psychological eval-
uation in the above mentioned case at the soonest possible time.
I solemnly affirm under the penalties of perjury that the contents of
the foregoing paper are true to the best of my knowledge, information,
and belief.
Date
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9-,;B-Q8
. ragu 2 of 3
Appendage to Petition For Psychological Evaluation
REASONS FOR EVALUATION REQUEST:
1. When my son was 15 months old, my wife was downstairs with him and
he was fussing. I heard him squeal very loudly as if he had been
hurt, so I quietly went half way down the stairs to listen.
At that time I heard my son squeal again and my wife said "shut up
or i'11 knock you out I"
At that point I proceeded the rest of the way down the stairs and
told Pamela there is no way a mother should ever say something like
that to her child, and that she had better not ever let me find out
she harmed our son.
NOTE: At this time I told Pamela she had to get some help and she
replied there was nothing wrong with her.
2. Throughout our marriage Pamela stole money from my wallet, even
though she was employed. For over two years I had money missing
and Pamela denied any involvement even though we were the only
people in the house, aside from our son.
NOTE: On three occasions, I awoke to find Pamela standing over me
with my wallet in her hands, and each time there was money missing
from it. Other times I was unaware this happened until later when I
woke up and checked. This behavior is not what I want my son to
learn.
3. Pamela was dismissed from her employment at Shippensburg Health
Care Center on July 10, 1997, for reasons unknown to me.
Pamela continued for two weeks to get up in the morning and put on
the 'act' of going to work as usual, never telling me she was no
longer working. I found this out by calling Shippensburg Health
Care Center to inquire if she was there. The Director informed me
that Pamela had been dismissed, and that he could not give me any
more information on it.
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4. On March 28 , 1997 , Pamela and Kenny were in a hotel room
with my mother and sister. This was the night before my sisters'
wedding. Pamela left a hot curling iron in reach and my son touched
it, burning his fingers. She became outraged because he touched it
and was crying. She stated to him" I wish you had never been born"
and that if he didn't stop crying she was leaving and taking him
home.
5. On April 26, 1998, Pamela called my residence and started harassing
me about my 'personal business'. I told her I was done talking to
her and I hung up. She immediately called back and left a message
on my answering machine tape stating if I did not pick up the
phone I would not see my son again. This was just one of many
threatening/ harassing messages left by Pamela.
I currently have in my posession the tape with the messages still
intact. There were also numerous threats which were not recorded.
NOTE: I subsequently had my phone number changed and was denied
visitation rights because I would not furnish Pamela with my new
phone number.
.
.
Page 3 of 3
Appendage to Petition For Psychological Evaluation
REASONS FOR EVALUATION REQUEST CONTINUED:
6. On May 6, 1998, I had my son for visitation. Myself and a f~iend
took our children to the store. My friend was helping my son out
ot the car and he stated to my friend, "Let me alone. My mommy
told me to tell you that". My son should not be subjected to this
or any other type of coersion concerning visitation or our re-
lationship as father and son, or my personal relationships.
7. On May 14, 1998, I received a letter from Pamelas' attorney, Mr.
Michael R. Rundle, stating that I did not have auto insurance and
if I could not show proof of such insurance coverage, I would not
be allowed to pick up my son for the Memorial Day weekend visit-
ation. Pamela and I were on the same insurance policy after our
separation. She dropped me off the insurance without my knowledge
specifically to try and interfere with my visitation. I obtained
my own insurance and showed proof when I picked my son up that
weekend. This was nothing more than 'legal harassment.
8. On June 4, 1998, I received a call from a customer service rep-
resentative from Sprint Telephone informing me that my wife was
attempting to obtain my new phone number~ I told them I did not
want her to have my number due to the calls I received previously
stated in number 5 on the preceeding page.
NOTE: There were also numerous calls made to my place of employment
by Pamela. The security personnel at Lear corp. can attest to this
fact as I eventually asked them to no longer accept calls from her.
My Team Leaders, Dennis Smith and Scott Amig also fielded numerous
calls from Pamela in which she proceeded to discuss our personal
business. There is now a note in the security office from me asking
that Pamela not be put through to my work site as it was affecting
my work performance. It was nothing ~ore than harassment. She
would call and say it concerned our son, but when I returned her
calls it would not have anything to do with him, only her own
selfish wants and desires.
9. Pamela confessed to me, partially, that something had happened to
her as a child concerning her grandfather. She alluded to being
molested but would elaborate no further. I feel this and other
happenings in Pamelas' childhood have led to the things which are
happening now in her adulthood. She has never dealt with those
issues....... and until she does her outlook on the way life
should be will never change. These actions on her part are affecting
my sons' life, my life, and Pamelas' life.
As stated earlier, these are just some of the many reasons why I
feel Pamela should undergo a psychological evaluation.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-.';r~1 CIVIL TERM
CIVIL ACTION - LAW
PAMELA L. ZEIGLER,
Plaintiff
KENNETH L. ZEIGLER, JR.,
Defendant
ORDER OF COURT
AND NOW, this ~I day of nC\f"\-'C" r , 1997 upon
consideration of the attached Complaint, it is hereby directed
that the parties and their respective counsel appear before
\-\Jr't"r\.- '1... G,\ftN , Esquire, the Conciliator,
~"""c. U,~rr{'.)l'\~I["""7\"rt Ic.."'~ \0
at (,,.,,\-,,.;1...,,, (0. (t,-,\I",v',C" Pennsylvania, on the ~ day of
\)C-(t";,,'oer , 1997, at l o'clock, ...Q...m. 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. Either party may
hring the child who are the subject of this custody action to the
conference, but the child's attendance is not mandatory. Failure
to appear at the conference may provide grounds for entry of a
temporary or permanent order. The Pre-Hearing Custody Conference
shall be held at
FOR THE COURT:
By:~1fj\~~l\\ 'X .~~I'\h1lliA &.0 .
Custody conciliator0r.b~(~
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
OFFICE OF THE COURT ADMINISTRATOR
Cumberland County Courthouse
Fourth Floor
Carlisle, PA 17013
Telephone: (717) 240-6200
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-!/f3/ CIVIL TERM
CIVIL ACTION - LAW
~
PAMELA L. ZEIGLER,
Plaintiff
KENNETH L. ZEIGLER, JR.,
Defendant
~.
COMPLAINT FOR CUSTODY
1. The Plaintiff is Pamela L. Zeigler, residing at
341 Farmington Drive, Shippensburg, Cumberland County,
Pennsylvania.
2. The Defendant is Kenneth L. Zeigler, Jr., residing at
155 Duncan Road, Shippensburg, Cumberland County, Pennsylvania,
3. Plaintiff seeks custody of the following child:
Kenneth N. M. Zeigler, who currently resides at 341 Farmington
Drive, Shippensburg, Cumberland County, Pennsylvania, age 3
years.
The child was born out of wedlock.
Pamela L. Zeigler
341 Farmington Drive
Shippensburg, PA 17257
9/20/97
to
Present
The child is presently in the custody of the plaintiff whose
residence is set forth above.
During the past five (5) years, the child has resided with
the following persons and at the following addresses:
Name
Address
Date
Pamela L. Zeigler and
Kenneth L. Zeigler, Jr.
155 Duncan Road
Shippensburg, PA 17257
9/95
to
9/20/97
9/94 to
9/95
Pamela L. Zeigler and
Kenneth L. Zeigler, Jr.
335 East Burd Street
Shippensburg, PA 17257
.
Pamela L. Zeigler and
Kenneth L. Zeigler, Jr.
337 East Burd Street
Shippensburg, PA 17257
3/94 to
9/94
, .
residing as set forth above.
She is married.
~
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4. The mother of the child is Pamela L. Zeigler, currently
The father of the child is Kenneth L. Zeigler, Jr.,
currently residing as set forth above. He is married.
5. The relationship of the plaintiff to the child is that
of mother. She currently resides with the following persons:
~ Relationshio
Kenneth N. M. Zeigler
Son
6. The relationship of Defendant to the child is that of
father.
He currently resides with the following persons: Unknown.
7. Plaintiff has not participated as a party or witness in
other litigation concerning the custody of the child.
Plaintiff has no information of a custody proceeding
concerning the child pending in a Court of this Commonwealth.
Plaintiff does not know of a person not a party to this
proceeding who has physical custody of the child or claims to
have custody or visitation rights with respect to the child.
8. The best interest and permanent welfare of the child
will be served by granting the relief requested because the
Plaintiff has served as the primary nurturing parent for the
child since birth.
9. Each parent whose parental rights to the child has not
been terminated and the person who has physical custody of the
child have been named as parties to this action. All other
persons named below, who are known to have or claim a right to
custody or visitation of the child will be given notice of the
pendency of this action and the right to intervene: None.
WHEREFORE, Plaintiff requests the court to grant custody of
the child to Plaintiff.
FOWLER, ADDAMS & RUNDLE
By:
\\-.LLU..DQ Q.J)LL
Michael R. Rundle
Supreme Court 1.0. No. 27768
28 South Pitt Street
P.O. Box 208
Carlisle, PA 17013
(717) 249-8300
Attorneys for Plaintiff
I verify that the statements made in this Complaint are true
and correct. I understand that false statements herein are made
subject to penalties of 18 Pa.C.S. ~4904 relating to unsworn
falsification to authorities.
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Pamela L. Zei r
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PAMELA L. ZEIGLER,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:
:CIVIL ACTION - LAW
:
:NO: 97-5831 CIVIL TERM
:IN CUSTODY
V
KENNETH L. ZEIGLER,
Defendant
COURT ORDER
~"
AND NOW, this ~O day of January, 1998, upon consideration of
the attached Custody Conciliation Report, it is ordered and
directed as 'follows:
1. The Mother, Pamela L. Zeigler, and the Father, Kenneth L.
Zeigler, Jr., shall enjoy shared legal custody of the minor
child, Kenneth N. M. Zeigler, born March 27, 1994.
2. The Mother shall enjoy primary physical custody of the minor
child.
3. The Father shall enjoy temporary physical custody of the minor
child as follows:
A. On alternating weekends on Saturday and Sunday from 8:30
a.m. until 7:30 p.m.
B. At such other times as agreed upon by the parties.
4. The parties shall meet with the Custody Conciliator again for
a conference on Thursday, March 5, 1998 at 9:30 a.m. at which
time this Order will be reviewed with the parties and the
Conciliator.
5. While the Father has temporary custody of the minor child, he
shall not expose the child to cigarette smoking from the
Father or from anyone else in the child's presence.
Additionally, Father shall not allow the child to be in the
presence of Mr. and Mrs. David Rosenberger
6. This is a temporary Order issued pending the parties agreement
on a permanent order or the entry of a permanent order by the
Court. In the event this case is litigated before the Court,
any agreement reached by the parties relative to the
restrictions and limits of visitation set forth above shall
not be binding on either party.
BY THE c,~
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Michael R. Rundle, Esquire
Matthew J. Eshelman, Esquire
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Plaintiff
AUG 1 8 1998J
\j
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 97 - 5831 CIVIL TERM
CIVIL ACTION - LAW
V.
KENNETH L. ZEIGLER, JR.,
Defendant
ORDER OF COURT
tic,
AND NOW, this {I day of , 1998, the Conciliator having
been advised by counsel for the parties that the ave reached an agreement, the
Conciliator relinquishes Jurisdiction.
By:
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
DOCKE'I' NO. ~. .~R.~ J
P 2 1 '199R
~
.
KENNETH L. ZEIGLER JR.
85 Parsonage Street
Newville, Pa. 17241
717-776-5302
vs.
PAMELA L. ZEIGLER
341 Farmington Drive
Shippensburg, Pa. 17257
717-532-4986
MOTION/PETITION FOR CUSTODY CONCILIATION HEARING
I, KENNETH L. ZEIGLER JR., representing myself, state that:
1. On January 20th, 1998, an Order was placed in effect concerning
the Custody Conciliation Report in case number 97-5831.
2. At this time, the current Order is unacceptable for the following
reasons:
a. Pamela L. Zeigler is enjoying "total" physical custody of the child,
refusing visitation for no good reason. I have not seen my child
since May 26, 1998.
b. The current Order does not allow for "overnight" weekend visitation,
I cannot understand a father not being allowed to have his child
overnight, barring a very compelling reason.
c. In the current Order, I am required to pick my son up at the home
of Pamela's father, James M. Boone Jr.
Mr Boone has denied my visitation and threatened my life creating
a hostile situation which I do not want my child subjected to,
It is in no one's best interest that I pick my child up at Mr.
Roones home. This needs changed as soon as possible because I
cannot go to Mr. Boones home for fear of bodily harm.
d. In the current Order, I am required to shoulder the burden of
all transportation in the pick-up! drop-off of my son.
The transportation should be shared to include a neutral pick-up/
drop-off location.
e. The Order specifies that I shall keep my son away from Mr. and Mrs.
David Rosenberger. This was due to a P.F.A. Order which is now ex-
pired. This needs removed from the Order.
e. There was a problem with Pamela calling my house and threatening
to never let me have my son again. I have an answering machine tape
with these messages on it. For this reason, I have refused to give
her my new phone number. She has also repeatedly called my workplace
against my wishes, to which the security personnel at LEAR CORP. can
attest. The reason is always my son until I call her and it has
nothing to do with my son.
FOR THESE REASONS, I request the Court schedule a Conciliation Hearing
in the above mentioned case at the soonest possible time.
I solemnly affirm under
the foregoing paper are
and belief.
the penalties of perjury that the contents of
true to the best of my knowledge, informatio
1~/8-9B
,
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Plainliff
: IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
: PENNSYLVANIA
v.
. Qync.\o l.,.. Le~j\cr J'~ r .
Defendant
: CIVIL ACTION LAW
:: NO. S ?:>~\ CIVIL 19 G\
: CUSTODY VIS[TATION
ORDER OF COIJRT
And now, this \0 (,:)offi3, upon consideration of the attached complaint, it is hereby directed
that the above parties and their res~ective counsel ap~ before ~ ~~" ;oJ~~r~I-,
Esquire, the conciliator, a~ l\1't\ -lI" ~.\ b-,J.m I C~tI n n r ,
Pennsylvania, on the \ -;) day of ~ h \'N'r'\'rL- ("' , 1998, at c:r, :"..,('; (1J.I P.M.,
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 be present at
the conference. Failure to appear at the conference may provide grounds for the entry of a
temporary or pennanent order.
FOR THE COURT:
,
By: ..J:.illQf'>"'\ ').. J-\~ .
Custody Conciliator I .)
YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. [F YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
THE CUMBERLAND COUNTY BAR ASSOC[A T[ON
2 LIBERTY AVENUE
CARLISLE, PA [7013
(7[7) 249-3166
1.800-990-9108
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IN TilE COURT OF COMMON PLEAS OF CUMIJERLAND COUNTY
DOCKET NO. '17 - sea 31
SEP 2 1 1998
~'~
KENNETIl L. ZEIGLER JR.
85 Parsonage Street
Newville, Pa. 17241
717-776-5302
PAMELA L. ZEIGLER
341 Farmington Drive
Shl ppensburg, Pa. 17257
717-532-4986
vs.
Plaintiff
Defendant
PBTITION FOR CONTEMPT
Denial Of Visitation
I, KENNETH L. ZEIGLER JR., representing myself, state that:
1. On January 20th, 1998, the Court of Common Pleas of Cumberland
County issued an Order in case number 97-5831 granting me
visitation with my son, Kenny.
2. Since then, I have been denied visitation with the child as
ordered. The details of the denials are: On June 6th, 1998,
at approximately 8:30 a.m. I arrived at the home of James
Boone Jr. to pick up my son for our Saturday visitation.
Under the current Order I must pick him up there.
I knocked on the door and Mr. Boone came outside onto the porch,
closing the door so my son could not come out.
He told me he was relaying a message from my wife's attorney,Mr.
Michael Rundle, that if I did not furnish Mr. Boone with my new
phone number, he was not obligated to let me have my son.
My previous phone number was changed due to harassing/threatening
telephone messages trom Pamela L. Zeigler, Kenny'S mother. I am
in posession of a tape with numarous threats of not seeing my son
again. The number was changed and I prefer not to be harassed any
further.
I told Mr. Boone that I had this tape and would not give out my
num~er for fear of continued harassment on the part of Pamela.
He then told me I was not taking my son anywhere and that if I did
not leave immediately, he would inflict bodily harm. At that point
I left and contacted the State pOlice to enforce the Court Order,
but was informed they could not help me.
3. The current state of visitation is zero, which is neither serving
my son's best interest,or mine as a father for that matter.
It is my right under the Constitution to have a relationship with
my son free of interference from third parties.
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KENNETH L. ZEIGLER, JR.,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
PAMELA L. ZEIGLER,
DEFENDANT
.
.
: 97.5831 CIVIL TERM
ORDER OF COURT
AND NOW, this 28th day of October, 1998, a Rule Is entered against Pamela L.
Zeigler to show cause why her counsel, Michael R. Rundle, should not be
disqualified. Rule returnable fifteen (15) days from the date of service. Any answer
filed shall be forwarded by the Prothonotary to chambers.
By the C~,< /
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OCT 2 3 14Ul' l
. '
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KENNETH L. ZEIGLER JR.,
Plaintift
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
V
:CIVIL ACTION - LAW
:
:NO: 97-5831
: IN CUSTODY
t.
PAMELA L. ZEIGLER
Defendant
ORDBR POR SHOW OP CAUSB
,
1~
\
UPON consideration of the Petition For Removal Of Counsel and the facts
asserted in the petition, which are incorporated by reference herein,
this Court ORDERS the Defendant, Pamela L. Zeigler, to appear in Room
on the
day of
, at
a.m./p.m.
and to show cause, if any, why the Plaintiff should not be gra~ted the
relief requested in the Petition For Removal Of Counsel provided that
a copy of the Petition For Removal Of Counsel and this Order be served
on the Defendant or her attorney of record, by
on or before the
day of
,199_
Judge
Date
Serve on: MICHAEL R. RUNDLE, ESQUIRE
P.O. BOX 208
28 SOUTH PITT STREET
CARLISLE, PA. 17013
Method of Service
cc: Michael R.
Kenneth L.
~~,..,...........cc.{
Rundle, Esquire
Zeigler Jr.
lo/:J.'f/96'
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KENNETH L. ZEIGLER JR.,
Plaintiff
,IN THE COURT OF COMMON PLEAS OF
,CUMBERLAND COUNTY, PENNSYLVANIA
VS
:CIVIL ACTION - LAW
PAMELA L. ZEIGLER
Defendant
,NO: 97-5831
:IN CUSTODY
CIVIL TERM
PETITION FOR REMOVAL OF COUNSEL
(CONFLICT OF INTEREST)
I, KENNETH L. ZEIGLER JR. , representing myself, state that:
I feel there is a 'conflict of interest' regarding my wife's
legal counsel.
Mr. Michael R. Rundle, Esquire is her attorney for all her
custody matters.
Mr. R~ndle also works for the DOMESTIC RELATIONS SECTION as
'special counsel', resulting in a situation where I, as a parent,
can not get a fair deal from the above office.
With the current situation, I have found that I run into a 'brick
wall' with DOMESTIC RELATIONS no matter what my concern may be.
I have come to the conclusion that there is no way any of my concerns
will be validated with the 'conflict of interest' which now stands.
FOR THIS REASON, I request the Court issue an Order for removal of Mr.
Rundle from this case as counsel for Pamela L. Zeigler.
;Cl - ~-ge
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Plaintiff
,IN THE COURT OF COMMON PLEAS OF
,CUMBERLAND COUNTY, PENNSYLVANIA
V
,CIVIL ACTION - LAW
,
,NO. 97-5831
10RDER FOR SHOW OF CAUSE
PAMELA L. ZEIGLER
Defendant
ORDER FOR snow OF CAUSE
UPON con deration of the P}tition for Psychological Evaluation and
the facts asse ed in the p~tion, which are incorporated by reference
herein,this Cour ORDERS tge Defendant, Pamela L. Zeigler, to appear
in Room 0 the day of , at a.m./p.m.
and to show
, 199_
, why the Plaintiff shoUld not be granted the
ition for Psychological Evaluation provided
r Psychological Evaluation and this Order
relief requested in
that a copy of the
be served
r pttorney of record, by
on r before the
day of
4~ ~ ~.MJ\~~ f'Vh~ M
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Judge
Serve on, MICHAEL R. RUNDLE, ESQUIRE
P.O, BOX 206
28 SOUTH PITT STREET
CARLISLE, PA. 17013
Method of Service
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cc:
Michael R. Rundle, Esquire
Kenneth L. Zeigler JR.
----=- .
.IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
DOCKET NO. 97-5831
KENNETH L. ZEIGLER JR.
85 Parsonage Street
Newville, Pa. 17241
PAMELA L. ZEIGLER
341 Farmington Drive
Shippensburg, Pa. 17257
vs.
Plaintiff
Defendant
PETITION FOR PSYCIlOLOGICAL EVALUATION
I, KENNETH L. ZEIGLER JR., representing myself, am requesting that
my wife PAMELA L. ZEIGLER undergo a psychological evaluation.
Due to the events which have occurred during our marriage and since
our separation, I am inclined to believe that Pamela has an existing
and ongoing mental health issue which needs to be addressed.
I feel my sons' well-being depends on whether Pamela receives appropriate
attention in this matter and subsequent help to deter further inapr~priate
behavior which is affecting my sons' well-being, attitude and growth as
a person.
There are numerous reasons for this request, the number one being I
feel my son will display these same negative qualities later in life
if there is not intervention at an early stage.
I would also ask the Court to Order an evaluation of my son to ensure
there is no permanent damage done by Pamelas' constant "authoritarian"
,
style of p~renting.
Please find attached a partial listing of issues warranting the above
request for a psychological evaluation. There are many more if the
Court finds a need for more information.
FOR THESE REASONS, I request the Court schedule a psychological eval-
uation in the above mentioned case at the soonest possible time.
I solemnly affirm under the penalties of perjury that the contents of
the foregoing paper are true to the best of my knowledge, information,
and belief.
9 -,;n-qg
Date
.paQe 2 of 3
Appendage to petition For Psychological Fvaluation
REASONS FOR EVALUATION REQUEST:
1. When my son was 15 months old, my wife was downstairs with him and
he was fussing. I heard him squeal very loudly as if he had been
hurt, so I quietly went half way down the stairs to listen.
At that time I heard my son squeal again and my wife said "shut up
or i'll knock you out I"
At that point I proceeded the rest of the way down the stairs and
told Pamela there is no way a mother should ever say something like
that to her child, and that she had better not ever let me find out
she harmed our son.
NOTE: At this time I told Pamela she had to get some help and she
replied there was nothing wrong with her.
2. Throughout our marriage Pamela stole money from my wallet, even
though she was employed. For over two years I had money missing
and Pamela denied any involvement even though we werp. the only
people in the house, aside from our son.
NOTE. On three occasions, I awoke to find Pamela standing over me
with my wallet in her hands, and each time there was money missing
from it. Other times I was unaware this happened until later when I
woke up and checked. This behavior is not what I want my son to
learn.
3. Pamela was dismissed from her employment at Shippensburg Health
Care Center on July 10, 1997, for reasons unknown to me.
Pamela continued for two weeks to get up in the morning and put on
the 'act' of going to work as usual. never telling me she was no
longer working. I found this out by calling Shippensburg Health
Care Center to inquire if she was there. The Director informed me
that Pamela had been dismissed. and that he could not give me any
more information on it.
4. On March 28 . 1997 , Pamela and Kenny were in a hotel room
with my mother and sister. This was the night before my sisters'
wedding. Pamela left a hot curling iron in reach and my son touched
it. burning his fingers. She became outraged because he touched it
and was crying. She stated to him " I wish you had never been born"
and that if he didn't stop crying she was leaving and taking him
home.
5. On April 26. 1998. Pamela called my residence and started harassing
me about my 'personal business'. I told her I was done talking to
her and I hung up. She immediately called back and left a message
on my answering machine tape stating if I did not pick up the
phone I would not see my son again. This was just one of many
threatening/ harassing messages left by Pamela.
I currently have in my posession the tape with the messages still
intact. There were also numerous threats which were not recorded.
NOTE: I subsequently had my phone number changed and was denied
visitation rights because I would not furnish Pamela with my new
phone number.
Page 3 of 3
Appendage to Petition For Psychological Evaluation
REASONS FOR EVALUATION REQUEST CONTINUED:
6. On May 6, 1998. I had my son for visitation. Myself and a friend
took our children to the store. My friend was helping my son out
of the car and he stbted to my friend, "Let me alone. My mommy
told me to tell you that". My son should not be subjected to this
or any other type of coersion concerning visitation or our re-
lationship as father and son, or my personal relationships.
7. On May 14, 199B, I received a letter from Pamelas' attorney, Mr.
Michael R. Rundle, stating that I did not have auto insurance and
if I could not show proof of such insurance coverage. I would not
be allowed to pick up my son for the Memorial Day weekend visit-
ation. Pamela and I were on the same insurance policy after our
separation. She dropped me off the insurance without my knowledge
specifically to try and interfere with my visitation. I obtained
my own insurance and showed proof when I piCked my son up that
weekend. This was nothing more than 'legal harassment.
B. On June 4, 199B, I received a call from a customer service rep-
resentative from Sprint Telephone informing me that my wife was
attempting to obtain my new phone number: I told them I did not
want her to have my number due to the calls I received previously
stated in number 5 on the preceeding page.
NOTE: There were also numerous calls made to my place of employment
by Pamela. The security personnel at Lear corp. can attest to this
fact as I eventually asked them to no longer accept calls from her.
My Team Leaders. Dennis Smith and Scctt Amig also fielded numerous
calls from Pamela in which she proceeded to discuss our personal
business. There is now a note in the security office from me asking
that Pamela not be put through to my work site as it was affecting
my work performance. It was nothing more than harassment. She
would call and say it concerned our son. but when I returned her
calls it would not have anything to do with him. only her own
selfish wants and desires.
9. Pamela confessed to me. partially, that something had happened to
her as a child concerning her grandfather. She alluded to being
molested but would elaborate no further. I feel this and other
happenings in PaMelas' childhood have led to the things which are
happening now in her adulthood. She has never dealt with those
issues....... and until she does her outlook on the way life
should be will never change. These actions on her part are affecting
my sons' life. my life. and Pamelas' life.
As stated earlier, these are just some of the many reasons why I
feel Pamela should undergo a psychological evaluation.
lC>-~ -qf!!j
Date
KENNETH L. ZEIGLER, JR.,
PLAINTIFF
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
PAMELA L. ZEIGLER,
DEFENDANT
97.5831 CIVIL TERM
ORDER OF COURT
AND NOW. this 18th day of February, 1999. the within petition for a
psychological evaluation, IS DISMISSED. t
/
,/
Michael Rundle, Esquire
Special Counsel for DRO
CoiL;...., ...........~Cl<l :1/" (l)~.1
II ...A.T.
Kenneth L. Zeigler, Jr., Pro se
1420 Valley Road
Marysvllle, PA 17053
:saa
1. A custody order was entered on November 16,1998, that rendered moot
the prior petition of Kenneth L. Zeigler, Jr., for a psychological evaluation. We will not
now Intervene to micromanage this case.
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KENNETH L. ZEIGLER, JR.,
Plaintiff
,IN THE COURT OF COMMON PLEAS OF
ICUMBERLAND COUNTY. PENNSYLVANIA
I
ICIVIL ACTION - LAW
,
INO. 97-5831
ICUSTODY/VISITATION
VS
PAMELA L. ZEIGLER
Defendant
ORDER FOR SHOW OF CADSE
UPON consideration of the petition ~or Psychological Evaluation and
the facts asserted in the petition, which are incorporated by reference
herein, this Court ORDERS the Defendant. Pamela L. Zeigler, to appear in
Room
on the
day of
, at
a.m./p.m.
and to show cause. if any, why the Plaintiff should not be granted the
relief requested in the Petition For Psychological Evaluation provided
that a copy of the Petition For Psychological Evaluation and this Order
be served on the Defendant or her attorney of record, by
on or before the
day of
, 1999.
Judge
Date
Serve anI Michael R. Rundle, Esquire
2B South pitt Street
Carlisle. Pa, 17013
M.O.S. CERTIFIED MAIL
.
~, Michael R. Rundle
Kenneth L. Zeigler. Jr.
VS
,IN THE COURT OF COMMON PLEAS OF
,CUMBERLAND COUNTY, PENNSYLVANIA
I
ICIVIL ACTION - LAW
I
INO. 97-5831
,CUSTODY/VISITATION
KENNETH L. ZEIGLER. JR..
Plaintiff
PAMELA L. ZEIGLER
Defendant
PETITION POR PSYCHOLOGICAL EVALUATION
I, KENNETH L. ZEIGLER.JR., representing myself. state that,
On October 28. 199B, Judge Edgar B. Bayley deferred a decision on a
previous Petition For Psychological Evaluation to the Custody Concili-
ator. Hubert X. Gilroy.
To date I have not received an answer on the previous Petition and
there are still things being done by Pamela L. Zeigler to lead me to
believe that she suffers from severe "chemical imbalance" resulting in
actions on her part which are severely hurting the father-child relation-
ship my son and I are trying to experience.
The latest charade on her part is as follows;
1. Pamela rushed our son to the hospital following our last visit
on November 21. 199B. citing the fact that animals at my home
made him sick.
2. Pamela then contacted Dr. Robert Hollen. our son's family doctor,
and persuaded him to write a statement saying our son has "asthma"
and cannot be exposed to animals. See Exhibits A,B,C,Cl attached.
3. Pamela is displaying actions which are clearly NOT in our sons'
best interest. She had a Medical Doctor write a statement which
is clearly UNTRUE, and you can see that by reading the attached
Exhibits. Was this for our sons' good? I know different.
4. Pamela is not being a responsible parent, she is putting our sons'
life at risk by having him subjected to medications he does not
need. She is displaying an attitude of not really caring what she
does to our son. rather using him as a 'tool of revenge' to meet
her own twisted desires.
5. Pamela is making a mockery of the system, the Court, and the rights
of her child to know his father. leading me to question the very
fact of the child being mine biologically.
6. I would beg the Court to please consider the first Petition For
Psychological Evaluation when reading this one. Kenneth N.M.
Zeigler's emotional and physical well-being depends on it.
, Pg.20f2
7. I, KENNETH L. ZEIGLER, JR., have in the past witnessed emotional and
physical abuse on the part of PAMELA L. ZEIGLER towards our son,
KENNETH N.M. ZEIGLER, resulting in the ultimate demise Of our marriage
and relationship. . .
.
POR THESE REASONS. I request the Court issue an Order For Show Of Cause,
find Pamela L. Zeigler in need of immediate mental health care, require
Pamela and our son to undergo psychological evaluation. and order any
other appropriate relief relating to her diminished mental capacity,
including; the child should be turned over to his father immediatelY
so he will no lonqer endure the pain and sUfferinq inflicted by his
mother. The father has a 10vinq home for the child where only the childs'
best interests will be met.
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KENNETH L. ZEIGLER JR..
Plaintiff
,IN THE COURT OF COMMON PLEAS OF
,CUMBERLAND COUNTY. PENNSYLVANIA
,
,CIVIL ACTION - LAW
,
,NO, 97-5831
,ORDER FOR SHOW OF CAUSE
V
PAMELA L. ZEIGLER
Defendant
ORDER FOR SHOW OF CAOSE
UPON consi ration of the Petition for Psychological Evaluation and
/
the facts asse ted in the Pe
herein.this Cou t ORDERS t
in Room n t.he,
tion. which are incorporated by
Defendant. Pamela L. Zeigler. to
day of . at
reference
appear
a.m./p.m.
and to show cause.
why the Plaintiff should not be granted the
petition for Psychological Evaluation provided
relief requeste~(n
that a COpy.~the peti
be qerved ~_t:e Defendan
on or
on for Psychological Evaluation and this Order
her attorney of record, by
day of
, 199_
1.51 &p,- ~
Judge
~..j;rlu~
.:28.
l'i'li
Date
Serve on: MIChAEL R. RUNDLE, ESQUIRE
P.O. BOX 208
2B SOUTH PITT STREET
CARLISLE. PA, 17013
Method of Service
cc:
Michael R. Rundle, Esquire
Kenneth L. Zeigler;fl.
(EXHIBIT A )
ADDAMS" RUNDLE
ATTORNEYS AT LAW
P,O, BOX 20B
28 SOUTH PITT STREET
CARLISLE, PENNSYLVANIA 17013,0208
W'LLIAM A. ADDAMS
MICHAEL R. RUNDLE
TELEPHONE 11111 248,1300
FAX 11171248,8154
November 25, 199B
HAND DBLIVBRBD
Kenneth L. Zeigler. Jr.
B5 Parsonage Street
Newville, PA 17241
RE: Custody of Kenneth N. M. Zeigler
Dear Mr. Zeigler:
As you are aware. following the visitation at your home this past
weekend. Kenny was rushed to the emergency room of Carlisle
Hospital with a severe bronchial asthmatic attack. The doctor
believes that this may have been brought on by exposure to
animals, particularly cats, in your home. I have enclosed a copy
of a written statement by his treating physician which
specifically states that your son is not to be exposed to
animals.
In light of this recent attack, your son's resistance to
asthmatic irritants is extremely low. Any contact to irritants
such as animal dander or cigarette smoke could result in his
hospitalization. We are requesting that in the boy's best
interests you forego your Thanksgiving holiday visitation with
your son. I am certain that as a caring father you do not want
to expose your child to conditions that could seriously harm him.
We are seeking your cooperation to insure that this does not
happen.
Please understand that Pam is not attempting to keep your son
from you. she is prepared to have this missed visitation rnade up
when your son's health improves. However. we cannot stress
enough the importance of protecting your son from what could
result in a life threatening situation.
Pam will keep you updated on the progress of your son's recovery
from this recent attack. We sincerely appreciate your
understanding in this matter.
Very truly yours.
ADDAMS & RUNDLE.
, -. .) \
\ \ \." llt ~,-\. ~.) ~'''''L01<.l.... '--
Michael R. Rundle
MRR/mp
(BXHIBIT B )
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RooI'" A, Ha.LIN, M 0 H.4AC<0 G. KMTt1H<l, 1.4.0
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B"""I G K,"" PA.'C
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c..-'IU. PI 17013
717.243.151'
PALe No W..o;HI7"'l PAl.cNi, -"O.(l27102.L PALe No WO~l"'l
PALeNa MOOI6241 E PAI.lCNo MA.OOOQ72.L
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SUBSTITUTION PEAM~
IN ORDER FOR A IIRANll N.....E PROOUCT 0 BE DISPENSED,
THE PRESCRIBER MUST HANOWPITE BRANO NECESSARY OR
BRAND MEOICALl.Y NECESSARY IN THE SPACE BELOW
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rsn.1R Uill r~':'nlBj)ft(~.(Bb'rrS'l ~i i rltl~~tiI. ar"'{~~r..k~iJV.IW..1i1' .1.."ff:n.l....:j1jlre-1J1l1'"'_~~..f~~bd~..d.J~~~'f'ft d~lM'4ri$U'1l fc". ~Q.
.XHIBIT C
MtOI~~ oUIl:i "'U.f~,,,'f, P C.
JO~n "1. :'9:..;I:ll.'oJ. II:.J.
:-l.l.:':-:: =:" ~.:: ._..~~.=..~.: ...::...=t~...,:" "':t.--:'
OftOMATE OF ntf <\MtJlUCAH !OAIIOOf AUlltOY .....UH<X.OGY
I'L"'~,",to..;."'i;iu..,,"...
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'.A~I~:~. ~"'~SYl....ArllA ,1lI1J.J"1
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Ap....l. ,;v, i:,r)i
Har~la ~. ~&C~Z~119, M.U.
H~U W~~n~t ~ottcm ~oad
CarLL~io ~~ I/UIJ
6Y=.: .Ku",nut;~ ~1J.'2ic;..
a;~ ;;~",;;,/;;"
Dear ur. K=at~iny,
'J,.lnani;. you tor allowiu<;j U..a i..u Sgc. .;....i.....-:.~l,. at",;...,.. t.~.;'~a
year old child W1. th d history of lilltl..".i.n<J, r"'Ulli n,;,.... ...1';; 1. t.::i.i
eyes. '1'ne motner is not .:..rtain whetil",r it ib "......UII..1. :il.oil
f~els he is worse 1.n the winter tlm... H.. does also have frequent
otitis medias in the winter. lie ildS no hilttory of astnma. He
gets o~r.asional doses of cold ana al!erqy Dlmetapp medication.
His past medical history is siqn1.f1.canc for a ra-circumci"ion
'!It- "']A nn.. y.."r. He was the product of iI fuii term, nor..l
r.r"!']'1<on,.y "..1 i vp.rp.rl hy emergency C-section because of failure
of prcgr'!ss!-:-!!. Th,,!t''! WArA no pAt'inatal or neonatal problns
in t~~ fir~t ~~llr ~f lif'!. ~.. did h"vA frequent upper respiratory
tr:1ct in!':!cticns and ct1tis m"!d!..a.,. ".. h.... h"c1 hrnnchlU. in
the p~=t ~~t h3~ never had pn'!um~nia ~~ ~r~u~. RA h"A nn history
of drt:.s O111crgi:::::::. '!'he IIlOther feel!! that Illillr. !,!,,,,,,,,..t-. .....y
contribute to ~w~~l congcetion.
In the family history, his
h1.s tather is alive and well. i1is
He has a paterna! qrandmother w~th
with aathma.
moth..r hali ll.i.U.... lr.tact1ons,
mat~cnal uncl.. naD d~lwr~~~~.
hay iev~r and d paterlld! unc!~
~alSi~ ~!H.t\.'!'~_9i~~. i:i....~ i.-=.~~,~ ...~ :ii..i..., C.u. ....'-6 ofO.L~~~
.15 '4 itq. it~ clp~~ars Wtd.J. '1'~,"J"lbOdu., we::....... ....CI~.al......~"'.... "'h~ ... r..,j
acute o1.strt!s::s. .'l'yUipanic w~uIO":d..lc:b ci.'-.: hvL'uld.~. 'rut.: n.:..w~'"
turbinates appear normal. '1'ne orophdrynx ili noclilcal, :"'''''9;' ti..l
tonslls are slJ.qhcly Lnt.i.am~d without ~XUcidi.... 'ii... ~ur'9~ al:~
clear to percussion ana au!!cultacion. '!'h~c.. dre no CdCoJ.i.dC
mllrmllr" nr ilhclomlnal masse!!. Tnere is no lymphadenopathy.
SA1" '1,~,,,'_~~u.i.{~~1. 'i"a~ clli1.d wd~ s;.;.....n ti:;~t~C1 ;;:J"i ;,:;.;.: p~::c~~::Q
tecnn1.que. He J.~ POS.1Cl.ve ':'0 liuxt::d ':l~:d..:;~C::". vi,:,...:.- c...~;;..~.; C.-:;kC
was neQat~ve whJ.ch included ciutit m.i\;'a:i, cu'U,.Ua.l. ~cJr,~......:;, t1:;':'~
pollens. molds and foods.
. .UIBIT C,l.
. MEDICAL AlITS AI.I.ERGY, PC.
JOin M. Monlllla, M.O,
IIL."'OW Q' THI AMI"Ic.t.N "C....OEM\' Of 'IOIATIlIICS
OWLOMAfI 01 'H' ...MUlllCAN aOAAO 0' Au.IAa' .,MMUrr.OI.OG'I
MIOICAI. AIIITS IUILDING
IUITl JU
220 .....ILSON STlllIIT
CARLiSI.I. "~NS'l'LV"'NlA 17013,"17
1117IJ4.J.1WO
'AX Jl3,HII
May 14, 1997
Harold G. Kretzing, M.D.
850 Walnut Bottom Road
Carlisle PA 17013
RE: Kenneth Zeigler
BD: 03/27/94
Dear Harold,
I finished the allergy evaluation on Kenneth and the only
positive skin test that he has is grass pollen. Everything
else was negative which included dust, molds, tree pollens and
animal danders as well as a few foods. He has not responded
well to Clan tin and I did add Flonase, 1 spray per nostril
daily but I advised the parents to try a combination of Claritin
and Flonase and should he continue to have problems, I would
recommend that he be evaluated by ear, nose and throat to
dettirmine whether he has other causes of nasal obstruction such
as adenoidal hypertrophy.
The parents seem very agreeable to this and they will get
back to me or you regarding the potential for an ENT referral.
li cerely,
l (.:_
J an M. Montello, M.D.
JMM/jes
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: IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
: PENNSYLVANIA
v.
. \O.0--dQ L, ~\'.)\Cr
Defendant
: CIVIL ACTION LAW
; NO. '::;3~' CIVIL 19Q,
: CUSTODY VISITATION
ORDER OF COURT
And now, this ~I \ ''fI'lq . upon consideration of the auached complaint, it is hereby directed
that the above parties and their respective counsel appear before \~rA- 'X. C"J\ \( o-~,
Esquire, the conciliator, at -\k <:;"'tl \'tr.1f ,,,,,pm 1( ,-,~(\::l"'1 (6. (tLrJ,\nn )c,,'C., ,
Pennsylvania, on the \ day of _1:~!(::L~ . 1999, atl()' :~ @/ P,M"
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 be present at
the conference. Failure to appear at the conference may provide grounds for the entry of a
temporary or pennanent order.
FOR THE COURT:
By: ')~H(A.,\\ \- '):., ~;.QJl~
Custody Conciliator ("F;l;
YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE, IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
THE CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY A VENUE
CARLISLE, P A 17013
(717) 249-3166
1-800-990-9108
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FOWLER. ADDAMS'" RUNDLE
ATTORNEYS AT LAW
28 SOUTH PITT STREET
CARLISLE, PENNSYLVANIA 17013
TELEPHONE (717) 2411-830O
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'IN THB COURT or COKKON PLBAS or CUMBBRLAND COUNTY
DOCKBT NO. 97-5831
KENNETH L. ZEIGLER, JR.,
1420 Valley Road
Harysville. Pa, 17053
717-957-3040
PAMELA L. ZEIGLER
1466 Woode Road. Lot #4
Shippenaburg, Pa. 17257
717-532-49B6
V3.
Plaintiff
Defendant
PETITION rOR CONTBMPT
Denial Of Visitation
I, KENNETH L. ZEIGLER, JR., representing myself. state thatl
1. On November 16, 199B. the Court issued an Order granting me shared
legal custody of KENNETH N.M. ZEIGLER.
2. This Order vacated a prior Order dated January 20, 199B.
3. The Order states that I shall enjoy temporary physical custody of
KENNETH N.M. ZEIGLER on alternating weekends.
a. The first visitation following the issuance of this Order was in-
terfered with in the following ways~
a1.) When I picked Kenneth up. I was on time and still had to go to
Pamela's fathers' home to pick him up. The new Order states this
should not happen unless I am late.
a2.) Pamela's step-mother informed me that Kenneth was having trouble
with his nose and she had given him his medication. ImmediatelY
following the visitation. Pamela rushed Kenneth to the Carlisle
Hospital, citing the animals at my house had caused an "allergic
attack". The events which have taken place since this time are as
follows. . . . . . . . . . . . . .
4. The visitation on November 22. 1998, was cancelled by Pamela in the
guise that the animals almost killed our son.
a.) I received a letter from Pamela's attorney, Mr. Michael R. Rundle.
Esquire, stating that basically I was the reason our son was rushed
to the hospital. See attached copy, Exhibit A .
b.) I received a copy of a statement written by Dr. Robert Hollen, a
family doctor with the Belvedere Medical Center. saying our son
has 'bronchial asthma' and cannot be exposed to animals.
See attached copy, Exhibit B.
5. I have in my possession two (2) letters from Kenneth N.M. Zeigler's
allergy specialist. Dr. Joan Montella, stating that Kenneth has no
history of "asthma" and that Kenneth is only 'allergic' to fresh-cut
grass. I was present when Kenneth had the battery of "allergy tests"
done and I knew he was not allergic to any animals.
Please find attached copies of both letters I Exhibit C and Cl.
(.IXBIBIT A )
ADDAMS" RUNDLE
A TTORNEYS A T LAW
P,O, BOX 208
28 SOUTH PITT STREET
CARLISLE, PENNSYLVANIA 17013,0208
WILLIAM A. AOOAMS
MICHAEL R. RUNDLE
TELEPHONE 17171 249.8300
PAX 17171 249.8IS4
November 25. 1998
HAND DBLIVBRBD
Kenneth L. Zeigler, Jr.
B5 Parsonage Street
Newville. PA 17241
RE: Custody of Kenneth N. M. Zeigler
Dear Mr. Zeigler:
As you are aware. following the visitation at your home this past
weekend. Kenny was rushed to the emergency room of Carlisle
Hospital with a severe bronchial asthmatic attack. The doctor
believes that this may have been brought on by exposure to
animals, particularly cats. in your home. I have enclosed a copy
of a written statement by his treating physician which
specifically states that your son is not to be exposed to
animals.
In light of this recent attack. your son's resistance to
asthmatic irritants is extremely low. Any contact to irritants
such as animal dander or cigarette smoke could result in his
hospitalization. We are requesting that in the boy's best
interests you forego your Thanksgiving holiday visitation with
your son. I am certain that as a caring father you do not want
to expose your child to conditions that could seriously harm him.
We are seeking your cooperation to insure that this does not
happen.
Please understand that Pam is not attempting to keep your son
from you. She is prepared to have this missed visitation made up
when your son's health improves. However. we cannot stress
enough the importance of protecting your son from what could
result in a life threatening situation.
Pam will keep you updated on the progress of your son's recovery
from this recent attack. We sincerely appreciate your
understanding in this matter.
Very truly yours.
ADDAMS & RUNDLE. ,
\ ,1 \
\ \, l.. 'Lt o<l \. ~-) ~.~L" .c. ..........
Michael R. Rundle
MRR/mp
IXHIBIT C
MLOICA. A~ fS ..l..,il.; v. P .C.
JOlln M. ;..It;l:ll,:.I,,;, II tI
:n~::"::~ ~'= '.~.!f..:<:'..ft .~~....:t:o."" -:.. ~":'l""!l';'
DIP'\,OMATE Of ntE ..\Mf:NICAH 'OARD O' A,UI"IJY a ....UHO\.DG.,
.",iUK:A" .;on .u...:;......;
'U1T1 111
l.IO WI..6OIlI STMil
fJUU l.b~. ~"r&S'fLvAl'lltA 1/Q1J-.lCOi
...,...\ 14' -..A
,.u Ja.tIIA
Ap~;~l. ,;v, i'J'J'
11<11:":'1..:1 ... {,,",;r.;:.l.Il~, 11.U.
~~U W<l1.nut uor.r.cm Ko~a
C.:lrLL~LO ~~ I IUI~
.\~: Kuhn.;;tn ;GlJ..9ic;:
Bri: u,;,/ ~ i j';joj
Dear ur. A.at~Lny,
'.1'uani(. you tor al10wiuy u,trOt Lu S...sc .;'';''(hi.:.Ln. Me:. J.~ '-1 ...n:..:a
year old Ch11d wl.th a hIstory at IHloilt:l:ollnlJ, rUIWt no.... ci...:i lot';';I
eves. 'rne Rlotner is not c..rtain wh..toer it ib .hlciliun..l.. lil...
feels he is ....orse 1n the ....l.nter tIme. He does also have frequtlnt
otitis medias 1n the wl.nter. He has no history of astnma. He
gets o~caRtonal doses of cold and allerqy D1metapp medication.
His past. medical history is siqnl.fl.cant for a re-Clrcumcili1on
"to ..gP nn.. ye...r. He was the product of a full term, normal
rr~']n",n,.y "..1 i vp.rprl by emergency C-section because of failure
of progr'!ssion. Th~rp wprp. no perinatal or neonatal problems
in the first year ~f ltf.., Hp rllrl hAve freq~ent upper respiratory
tr:lct in!'2ction2 and otitis m~di<'.~. Ifp h.... h..", hronchitts in
th= p~=t hut ~33 never h~d pn~umon!a or cr~up. Rp h~8 no history
of dr~; ~llcrgi~~. ~he moth~r feels thftt m!l~ ~r~~~t. m~y
contribute to ~~~wl congcet!c~.
In the family history,
hl.s father is alive and ....ell.
He has a oaternal qrandmother
with asthma.
his mothl:!r lia,; Ilinuli lntectlons,
His maternal uncll:! hall allyrgl.~';.
with hay fevgr dnd a paternal unclg
~d.b.i.uu, ~INATIOi~: ii..l..2 h~if:1l1i.. ....~ ~u.~ cr'a_ ";iY '.ve~~..;,:
1.S J 4 .k.q. it~ dppears wd-i..i. uOUCJ.o(h!U, wta.A.l L,,::::vclv~~u dl.4lU ..i. hO
acute dl.streSli. 'l'ywpanic m"U1c.ane.. a.... loUr..la.!.. 'r..t: n..&..l
turbinates appear normal. 'l'he oropharynx io nO.IU..l, llic.ugli \;l,tI
tons11s are sll.qhtly inflamed without exudattl. Thl:! lungl> artl
clear to oercussion ana auscultation. 'Ehere are no cdrdi..c
ml1rmur" or abdominal masses. Tnere is no lymphadenopathy.
SAIH 'l1~r.L._.~~ui.'J.1S:. 'rileS child ..a:;i :.ii\..i.il tC1it.ICc.1 n"f chi:! p~ncc~:;Q
tecnn1que. He ~s posic.1.vt:! (0 ulixt:d yJ:d.~":Jf=~. Oli-.-=:.: t~~:..n.; CCilC
was neqatl.ve whlch included QUilt 1111;:"';, dn.Llll..l Q<lO.;1":,,, tr",e
~ollens. molds and foods.
'.
IXHIBIT C,I.
MEDICAL ARTS ALLERGY, P,C,
Joan M. Montollo, M.D.
nLLOW 0' THI AMiAICAN ACAOfMY OF PEDIATRICS
D"LOMATI 0' THI AMERICAN 80A"0 OF ALLIRGY .IMMYNOLOQY
MIOICAI. ARTS l",tLOING
SUITt au
220WlLSON srRUT
CARLISLE, PENNSYLVANIA 170U.),,7
17171243.7140
FAX U2.HII
May 14, 1997
Harold G. Kretzing, M.D.
850 walnut Bottom Road
Carlisle PA 17013
RE: Kenneth Zeigler
BO: 03/27/94
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Dear Harold,
I finished the allergy evaluation on Kenneth and the only
positive skin test that he has is grass pollen. Everything
else was negative which included dust, molds, tree pollens and
animal danders as well as a few foods. He has not responded
well to Claritin and I did add Flonase, 1 spray per nostril
daily but I advised the parents to try a combination of Claritin
and Flonase and should he continue to have problems, I would
recommend that he be evaluated by ear, nose and throat to
determine whether he has other causes of nasal obstruction such
as adenoidal hypertrophy.
The parents seem very agreeable to this and they will get
back to me or you regarding the potential for an ENT referral.
~i cerely,
(.;'"
J an M. Montello, M.D.
JMM/jes
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PAMELA L. ZEIGLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-5B31 CIV1L TERM
CIVIL ACTION - LAW
v.
KENNETH L. ZEIGLER, JR.,
Defendant
AFFIDAVIT OF SBRVICB
COMMONWEALTH OF PENNSYLVANIA
ss
COUNTY OF CUMBERLAND
Mary M. Price, being duly sworn according to law, deposes
and says that she is a competent adult who is not a party to this
action and that on November 7, 1997, she mailed a true and
correct copy of the Complaint for Custody and Order of Court, to
Defendant Kenneth L. Zeigler, Jr., by certified mail with
restricted delivery. postage prepaid, return receipt requested
and evidenced by return receipt card No. P269 343 253, to
Defendant's last known address; that on November 24, 1997,
Defendant Kenneth L. Zeigler, Jr. did personally receive said
Complaint for Custody and Order of Court; that attached hereto,
made a part hereof and marked Exhibit "A" is return receipt card
No. P269 343 253, with Defendant's signature affixed thereon; and
that the facts set forth in the within Affidavit are true and
correct to the best of her information and belief.
~ /(")
I . . .. .
r1 . 1. (/~4/
My. Price
Sworn to and subscribed before me
this 2k..... day of ~C'\X~L,'v' , 1997.
~'Ll'Alo.UtJL
~OTAPI!~L ~fAl
M1CHAfl ~ RII';(' [: NOt.\Rv PUBLIC
SORD (IF f.A~I.r;~~ C1 !/..~3ERI ANI) (QUUTV
)tV CO~MISS1C"" EA?;~E5 O(CC~e(A 20. 1998
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I ..... yaw ftImI IN ....... en fie ....,.. at.. IIIlmli to .. .. GIft tItum lit
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..... bm ID" torf 0I1N~. QI' an.... bId!.' "*' doII_
, .~,....,.,....,~ -on..lNIIPIoIbeIow......""'**
In:. RIIum ~... Ihow 10 whom.. Iftide... dIIvnd Iftd 1M NIe
-
I 3. Altdt AddrIIMd :0:
I Kenneth L. Zeigler, Jr.
155 Duncan ROlId
ShippellBbur9, PA 17257
5, oceMd By: (PrlnINMneI
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" a Addr_'.__ t
2,Q R..1rIcIed DaIiwIy !
ConIUt ~r"""', I
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41J~269 34;' 253 j
o RaglllIrld ID c.r1lftId
o expraaa Mall 0 II'iIlftd I
o RolLm RIOIipl lor Iolofa.w. 0 COD 1
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KENNETH L. ZEIGLER, JR.,
Petitioner
: IN TilE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LA W
,.- 97-5831 CIVIL TERM
PAMELA L. ZEIGLER,
Respondent
IN CUSTODY
ORDER OF COURT
AND NOW, this '6 day of \ ',-\ rf"Or r ,1999, upon consideration of the
attached ctition, it is hcrcby dirccted that the partics and thcir respcctive cOllnscl appear
before ' , G \ \ (c{'-\ Esquire, thc conciliator, at ~\..(' l\1" r\rD( )
Cru. . ' onthe~
day of ,)oC, lo.~ . ~at ~\M, lor a Pre-Hearing Custody Conference, At such
conlerence, an ellort will be made to rcsolve the issues in dispute; or if this cannot be
accomplishcd, to definc and narrow thc issucs to bc hcard by the Court dnd to cnter into a
tcmporary ordcr, All childrcn age five or older may also be present at the conference, Failure to
appear at this conference may provide grounds for cntry of a tcmporary or pcrmancnt ordcr.
By the Court,
By:
'}4HOr\~' 'K~j)Jl~
Custody Conciliator ( \:l:>. ')
YOU SHOULD TAKE TlHS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET J.EGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsytvanla 17013
(717) 249-3166
1-800-990-9108
,
KENNETH L. ZEIGLER, JR.,
Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
99- 97-5831 CIVIL TERM
PAMELA L. ZEIGLER,
Respondent
IN CUSTODY
PETITION FOR CUSTODY
AND NOW, this 6th day of December 1999, comes the Petitioner, Kenneth L. Zeigler,
Jr., by his attorneys, Irwin, McKnight and Hughes, and presents the following Petition for
Custody.
I.
The petitioner is Kenneth L. Zeigler, Jr,. an adult individual residing at 1420 Valley
Road, Marysville, Perry County, Pennsylvania 17053,
2.
The respondent is Pamela Lee Zeigler, an adult individual residing at 1466 Woods Road.
Lot #4. Shippensburg, Cumberland County, Pennsylvania 17257.
3.
The parties are the natural parents of one minor ehild, namely, Kenneth Nonnan Marshall
Zeigler. born Mareh 27, 1994, age 5.
5.
Petitioner desires primnry physicnl euslmly of lhe ehild and joint legal custody with
periods of visitlltion to respundenl us enn he l11utuully urrunged betwccn thc partics. In the
uhernulive. the petitioner rel\uests shllrcll physlenl custody of his son with the respondent.
6.
The hcsl inlerest of the ehihl rC1lulres tlllltlhe court grnntthe petitioner's request as set
lilrth uhove,
7.
^ copy of the (lnler of ('ourt in clleet dnted April 9, 1999, is attached as Exhibit "A", and
the Onlcr of ('ourt .llItcll NO\'I"l11hcr 16, 199M is ulluehed us Elthibit "8,"
\VII t:RU'OIU:, pet II loner rcspeetfully seeks the entry of an Order of Court seeking
primllry physicIII eush"ly of the child nnd joint legal custody with periods of visitation to
respol1dcl1l us elln he l11utulllly nrrllnlled hetween the parties,
Respectfully submitted,
By:
, Esquire
enneth Lee Zeigler
Dule: Oeecmher 6, 1999
llPR n 5 1999 fIJ
KENNETH L. ZEIGLER, JR"
Plaintiff
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
\'
CIVIL ACTION - LAW
PAMELA L. ZEIGLER.
Dt"fendant
NO, 97-5831 CIVIL
IN CUSTODY
COURT ORDER
AND NOW, this q;tL day of April, 1999, upon considcration of the attached Custody
Conciliation Repon, it is ordered and directcd as follows:
I, A hearing is schedulcd in Counroom No, 2 ofthc Cumberland County Counhouse on
the I :l~ay of -y71~ , 1999, at 2:1s.t/,M, at which time tcstimony will be
taken in the above casc, OAt this hearing,thc Father, Kenneth L. Zeigler, Jr" shall be
the moving party and shall proceed initially with tcstimony, The hearing will be
limited to Father's petition to hold Mother in contempt for violation of the existing
Custody order and on Mother's request to have the existing Custody Order be modified
on the issue of whether Father's visitation with the minor child shall be limited only to
homes that do not include ~ cats or other anim~~~~~ld adversely affecl the
c\1i1d's asthma condition'L (\. j "tl..... .fc-,t-"",;: __ "- f"'- ~ ~~~C
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2. Pending further order fonn this coun, the existing order of November 16, 1998 shall
remain in effect subject to the following modifications:
A. Father's periods of alternating wcekcnd visitation with the minor child
shall be on alternating weekends on Saturday and Sunday of each
weekend from 8:00 a,m, until 8;00 p,rn. Father shall pick up the minor
child at the maternal grandfather's house, These periods of temporary
custody shall not extend into overnight until after the Coun conducts a
hearing on the mailers outlined above,
8. In all other respects, the November 16, 1998 order shall remain in
effect.
BY THE COURT,
cc:
Michael Rundle, Esq.
Kenneth Zeigler
IS! C'cl:J{.... ,.3 . )~'J G<:l J.
TRUE COpy FROM RECORD
In T'sl r."nv v I" r of 111'''-' ""," ,,' .." h"d
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and Ih" ,;ill ui :...'<1 CO:l" M Carl:"I." PJ,
This () ::tL dilY of {]/::J":"C, 19,1..1..
HH.......~.l~~,C.(}..,./~.... J~'i-':~"......-
L~' Prothonotary
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EXHIBIT "B"
7, For the Chrisunas holiday, Father shall have custody from 9:00 on Chrisunas Eve
until 8:00 p,m, on Christmas Eve, Mother shall enjoy Christmas Day with the child,
8. For New Year's, Father shull have custody from 9:00 a,m, on New Year's Eve until
8:00 p.m. on New Year's Eve, with Mother enjoying custody on New Year's Day.
l11is custody schedule shall supercede the alternating weekend schedule.
9. Neither puny shall expose the child to cigarette smoking when the child is in their
custody.
10, Neither parent shall make disparaging remarks to the child concerning the other
parenl or the other parent's iamil)',
II. Both parti,s shall enjoy reasonable telephone contact with the minor child when the
child is in the other parents' custody.
BY THE COURT,
~~{ t.A.r- l.~. 'l3.",/,~ J.
cc: Michael Rundle, Esquire
Kenneth Zeigler
TRUE COpy FROM RECORD
In Te~timony whr-reof, I here unto set my hand
and the seal of said Court at Carlisle, Pa.
This "JIo.::!!:::"1 day OL'J'}tl,~,:,,,,, 19..1.1..
...._~),',.,a..,:,"""'~"'"...._._
olJ n ,Prothonotary
VERIFICATION
The foregoing Petition for Custody is based upon infonnation which has been
gathered by cGunsel and myself in the prcparation of this action. I have read the
statements made in this document and they are true and corrcctto the best of my
knowledge. infonnation and belief, I undcrstand that false statemcnts herein made are
subject to the penalties of 18 Pa. C.S.A, Section 4904, relating to unsworn falsification to
authorities,
Date:December 6 . 1999
KENNETH L. ZEIGLER, JR.,
Petitioner
: IN TilE COURT OF COMMON PLEAS elf'
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v.
99.97.583t CIVIL TERM
PAMELA L. ZEIGLER,
Respondent
IN CUSTODY
CERTIFICATE OF SERVICE
I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached Petition for
Custody was served upon the following by depositing a true and correct copy of the same in the
United States mail, First Class. postage prepaid in Carlisle, Pennsylvania,
on the date referenced below and addressed as follows:
Ms, Pamela Lee Zeigler
1466 Woods Road, Lot 114
Shippensburg, P A 17257
IRWIN, McKNIGHT & HUG liES
By:
Date: December 6, 1999
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Pamela L. Zeiglcr, for hcrself IN THE COURT OF COMMON PLEAS
and on bchalfofthc minor child,
Kcnncth Nonnan-Marshall Zciglcr, OF CUMBERLAND COUNTY, PENNSYL VANIA
Plaintitl'
vs. NO. 97- 5831 CIVIL TERM
Kenncth L, Zcigler. Jr,
Dcfendant PROTECTION FROM ABUSE
.l:
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I
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendanl's Name: Kenneth L. Zelgter, Jr.
i
Dcfendant's Date of Birth: 5-3-65
Dcfendant's Social Sccurity Number: 176-56-7336
Names of all Protected Persons, including Plaintitl' and minor children: Pamela Zeigler, the
Plaintiff, and the minor child, Kenneth Marshal Norman Zeigler.
AND NOW, this ~ \hy of January 2000, up(1n consideration of the attached Petition
tor Protection from Abusc, the court hereby enters the following Temporary Order:
181
D
181
I. Defendant shall not abuse, harass, stalk or threaten any of the above persons
In any place where they might be found.
2. Defcndant is cvictcd and excluded from the residenec at .,., Cumberland
County, Pennsylvania, or any other penn anent or temporary residence where Plaintiff
may live, Plaintiff is granted exclusivc posse~sion of the residence, Defendant shall have
no right or privilcge to cnter or be prcscnt on the premises,
3. Except for such contact with the minor child as permitted In the parties'
Custody Order, Defendant is prohibited from having ANY CONTACT with
Plaintiff at any location Includlnll, but not limited, to any contact at Plalntirrs
residence or place of employment. Defendant Is specifically ordered to stay away
from the followlnlllocatloD5 for the duration of this Order: 1466 Woods Road, Lot
4, Shlppensburg, Pennsylvania, 17257. And Plalntifrs place of employment located
at Moore's Lumber, Route 11, Chambersburg, Pennsylvania.
181
4. Except for such contact with the minor child as permitted In the parties'
Custody Order, Dcfendant shall not contact Plaintiff by any means, Including
through third persons.
o 5, Pending the outcome of the final hearing in this malter, Plaintiffis awarded
temporary custody of the followinll minor childlren: · (DOB ). Until the final
hearing, all contact between Defendant and the childlren shall be limited to the following:
.., The local law en lor cement agency in the jurisdiction where the childlren are located
shall ensure that the childlren are placed in the care and control of the Plaintilf in
accordance with the tenns of this Order,
o 6, Defendant shall immediately relinquish the lollowing weapons to the Sheriff's
Oftice or a designated local law enl(Jrcement agency for the delivery to the Sheriff's
Omce: A handgun. rille, and shotgun, Defendant is prohibited from possessing,
transferring or acquiring any other weapons lor the duration of this Order.
~
7.
The following additional relief is granted:
This Order shall be docketed In the office of the Prothonotary and forwarded
to the Clevland County Sheriff for service. The Prothonotary shall not send a copy
of this Order to Defendant by mall.
This Order shall remain in effect until modified or terminated by the Court
and can be Clltended beyond its original expiration date If the Court finds that
Defendant has committed another act of abuse or has engaged In a pattern or
practice thatlndleates continued risk of harm to Plaintiff and minor children.
Defendant Is enjoined from damaging or destroying any property owned
jointly by the parties or owned solely by Plaintiff.
Defendant Is to refrain from harassing Plalntlfrs relatives or the minor
children.
~ 8. A certified copy of this Order shall be provided to the police department where
Plaintiff resides and any other agency specified hereafter: Pennsylvania State Police.
o 9, THIS ORDER SUPERSEDES 0 ANY PRIOR PFA ORDER AND 0 ANY
PRIOR ORDER RELATING TO CHILD CUSTODY
~ 10. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL MODIFIED OR TERMINATED BY THIS COURT
AFTER NOTICE AND HEARING.
Pamela L. Zeiglcr, lor herself : IN THE COURT OF COMMON PLEAS
and on bchalf of the minor child,
Kenneth Nonnan-Marshall Zeiglcr, OF CUMBERLAND COUNTY, PENNSYL VANIA
Plaintift'
vs, NO, 97. 5831 CIVIL TERM
Kenneth L. Zeiglcr. Jr,
Delendant PROTECTION FROM ABUSE
PETITION FOR PROTECTION FROM ABUSE
I. Plaintitl's name is Pamela Zeiglcr.
2, This Pctition is tiled on behalf of Kenneth Nonnan-Marshall Zeigler, the minor child.
3, The names of ALL pcrsons, including PlaintitT and minor children, who seek protection
ITom abusc are Pamela Zeigler and Kenneth Nonnan-Marshall Zeigler.
4, Plaintill's address is 1466 Woods Road. Lot 4, Shippensburg, Pennsylvania, 17257.
5. Defendant is believed to 1420 Valley Road, Marysvillc, Pennsylvania.
Defendant's Social Security Number is 176-56-7336,
Defendant's date of birth is 5-3-65.
Defendant's place of employment is Lear Corporation, Carlisle, Pennsyvalnia.
6, Defendant is Plaintiffs estranged spouse.
7. Plaintiff and Defendant have been involved in the following court actions for divorce or
protection ITom abuse:
Case name
Zeigler v, Zeigler
PFA and Custody
Case no,
97-5831
Date filed !:2l!r1
1997
Cumberland County
Court of Common Pleas
Zeigler v, Zeigler
Support
131300008
8. Defendant has been involved in the following criminal court action: Defendant has been
arrested for DUI, disorderly conduct, theft, defiant trespass, forgery. escape, and burglary.
9, The facts of the most recent incident of abuse are as follows:
On or about Deccmbcr 15,1999, Dcfcndant became angry, threatened to beat-up
PlaintilT, and threatcned to blo'.v up her vehicle, Dclendant stated he did not eare if their son
was with h~r in th~ vehicle,
I (), Dcfendant hllll committ~-d the following prior acts of abuse against Plaintiff and/or the
minor childrcn:
a. In or about Sept~mber 1999, D~f~ndant thr~atened to b~at-up PlaintilT to the
point she could not bc r~cogniz~d causing her to f~ar for her safety, Defendant
plead guilty to charll~s of disorderly conduct.
b. In or about Jun~ 1999. Def~ndant thr~atcned to abuse Plaintitl.so badly she
could not be recognized, Defendant told Plaintiff he would have their son because
she would be dead exacerbating her fear,
e. Throughout the year of 1999. Defendant sent Plaintill' threatening letters
causing her to fear tor h~r safelY,
d. In or about May 1998, D~fendant forcefully pushed Plaintiff while she held
their son causing her to fear lor her safety and that of her son's, On more than one
occllllion since May 1998. Defcndant has stated to the child that he would live
with him because his mother would be dead,
e, In or about July 1997. Defendant choked PlaintitT. slapped her, pulled her hair,
and banged her head against the wall causing red marks on her neck, On one
other occasion. Defendant pushed Plaintitl'to the ground while she held their son
causing a bruise on her son's leg,
II. The lollowing police department or law enforcement agency in the area in which PlaintitT
lives should be provided with a copy of the Protection Order: Chambersburg State Police
Department,
12, There is an immediate and present danger of further abuse from the Defendant.
WHEREFORE, PLAINTIFF REQUESTS THAT THE COURT ENTER A
TEMPORARY ORDER, AND AFTER HEARING. A FINAL ORDER THAT WOULD DO
THE FOLLOWING:
A. Restrain Defendant from abusing. threatening, harassing, or stalking Plaintiff and/or
minor child in any place where PlaintilTmay be found,
B. Order Defendant to stay away from Plaintill's residencc and prohibit Defendant from
attempting to enter any temporary or pennanent residence of the Plaintitf.
.-
C, Prohibit Detendant trom having any contact with Plaintitl' and/or minor children, either in
person, by telephone, or in writing. personally or through third persons, including, but not
limited to. any contact at Plaintit1's school, business. or plac*.: of employment.
D, Prohibit Detendant trom having any contact with Plaintit1's relatives and Plaintitl's
children listed in this Petition,
E, Order Detendantto temporarily turn over weapons to the Sheritl'ofClevland County and
prohibit Defendant trom transferring. acquiring or possessing any such weapons for the duration
of the Order,
F, Order Defendant to pay thc costs of this action, including filing fecs, servicc fees, and
surcharge of $25,00,
G, Order Defcndantto pay $250,00 to reimburse onc of Legal Services. Inc, 's funding
sources for the cost of litigation in this casc,
H, Ordcr the following additional relief, not listed above:
a. The dcfendant is enjoilled from damaging or destroying any property
owned jointly by the parties or owned s'Jlcly by thc plaintitl'.
b, The defendant is to refrain from harassing the plaintift's relatives or the
minor child.
I.. Grant such othcr relicf as the court dcems appropriate.
J. Order the policc or other law cnforcement agcncy to serve the Defendant with a
copy of this Petition, any Order issued, and the Order for Hearing, The petitioner will
infonn the dcsignated authority of any addresses, other than Defendant's rcsidence, where
Defendant can be scrved,
Plaintiff prays for such other relief as may be just and proper.
Res pectfully su~/ iued,
l 'It ( .
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I an Carey J
v Attorncys for Plaintiff ~
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, P A 17013
, vcritY that I am thc Pctitioncr as Jcsignatcd in thc prcscnt action and thaI thc tacts and
statements containcd in thc abovc Pctition are truc and correct to thc bcst of my knowledge. I
understand that any false statements are madc subject to thc penalties of 18 Pa.C.S, ~4904. relating
to unsworn talsification to authorities,
Datcd:
l-/Altr J. 00 ()
ir,C(),O~[), ~7fl~ t
Pamela Zeigler. Plai "rr' -
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Pamela L. Zeigler. for herself IN TilE COURT OF COMMON PLEAS
and on behalfofthe minor child,
Kenneth Nonnan-Marshall Zeigler. OF CUMBERLAND COUNTY. PENNSYLVANIA
PlaintilT
vs, NO, 97. 5831 CIVIL TERM
Kenneth L. Zeigler. JI',
Delendant PROTECTION FROM ABUSE
AND NOW.lhis H day of February 2000, upon consideration of the allached Motion for
Continuance, the mailer scheduled lor hearing on February 4.2000, by this Court's Order ofJanuary
28, 2000, is hereby rescheduled lor hearing on
~€..br-WIol"l.J
-\.J
u
, 2000, at'$ : BOrn.
in Courtroom No. I.
The Temporary Protection From Abuse Order shall remain in eftect for a period of one year
from the date it was entered or until further Order of Court, whichever comes first.
A certilied copy of this Order for Continuance will be provided to the Chambersburg
r
Pennsylvania State Police by the plaintiffs allorney,
Joan Carey
LEGAL SERVICES, INC.
Allorney for Plaintiff
.
Kenneth Zeigler
PRO SE DEFENDANT
1420 Valley Road
Marysville, Pa
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WHEREFORE. the Plaintilfrequests that the Court grant this Motion and reschedule this
mailer for hearing. and that the Temporary Protection From Abuse Order remain in cffcct for a
period of onc year from the date it was cntered or until further Ordcr of Court. whichevcr comcs first.
Respcctfully subQ1illed.
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J an Carey. Allomcy fi laintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
..
Pamela L Zcigler, tilr herself : IN THE COURT OF COMMON PLEAS
and (In behal I' of the mitior child,
Kenneth Nonnan-Marshall Zeiglcr, : OF CUMBERLAND COUNTY, PENNSYLVANIA
Plaintill'
vs. : NO, 97- 583 I CIVIL TERM
Kenneth L Zcigler. Jr,
Defendant : PROTECTION FROM ABUSE
NOTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT, If you wish to dcfend againstthc claims set
forth in the tollowing papcrs, you must appcar at the hearing scheduled herein, If you fail 10 do
so, the case may proceed against y(lu and a FINAL Ordcr may be cntered against you granting
the relief requested in the Petition, In particular, you may be evictcd !Tom your residence and
lose (lther important rights,
A hcaring on the maller is schcduled tor the !it. day of ~"".I,!~)OOO, at ~., in
Courtroom No,J- of the Cumberland County Courthouse, Carlisle, Pentfsylvania.
\
You MUST obey the Order that is attached until It is'modlfled or terminated by the
court after notice and hearing. It' you dlsobcy this Order, the police may arrest you.
Violation of this Order may subject you to a charge of IndIrect crlmlnat contempt which Is
punishable by a fine of up to 51,000.00 and/or up to six months In jail under 23 Pa.C.S.
g6114. ViolatIon may also subject you to prosecution and criminal penalties under the
Pennsylvania Crimes Code. Under federal taw, 18 U.S.c. g2265, this Order Is enforceable
anywhere In the United States, tribal lands, U.S. Territories and the Commonwealth of
Puerto Rico. If you travel outside of the state and IntentIonally vIolate this Order, you may
be subject to federat criminal proceedings under the VIolence Against Women Act, 18
U.S.C. g 2261-2262.
YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. YOU
HAVE TIlE RIGHT TO HAVE A LAWYER REPRESENT YOU AT THE HEARING.
THE COURT WILL NOT, HOWEVER, APPOINT A LAWYER FOR YOU. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IF YOU CANNOT FIND A LAWYER, YOU MA Y HAVE TO PROCEED WITHOUT
ONE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717)249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Dlsabllltlcs Act of 1990. For information about accessible facilities and
reasonable aecommodatlons availablc to disablcd Individuals having business before the
court, please contact our office. All arrangemcnts must be made at least 72 hours prior to
any hearing or business beforc the court. You must attend the scheduled conference or
hearing.
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KENNETH L. ZEIGLER, JR.,
PLAINTIFF/PETITIONER
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
PAMELA L. ZEIGLER,
DEFENDANT/RESPONDENT : 97-5831 CIVIL TERM
ORDER OF COURT
AND NOW, this 18th day of February, 2000, IT IS ORDERED that the parties
shall strictly comply with the applicable court orders pending a further order of court
following the scheduled conciliation conference on March 2, 2000.
Marcus A. McKnight. III, Esquire
For Petitioner
Edgar B, Bayl
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Bradley L. Griffie. Esquire
For Respondent
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KENNETH L. ZEIGLER, JR.,
Plaintiff/Petitioner
: IN THE COURT OF COMMON PLEAS OF
v.
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
97.5831 CIVIL TERM
PAMELA L. ZEIGLER,
Defendant/Respondent
IN CUSTODY
PETITION FOR SPECIAL RELIEF
SEEKING TEMPORARY EMERGENCV CUSTODY
AND NOW, this 17th day of February 2000, comes the Plaintiff/Petitioner, Kenneth L. Zeigler, Jr.,
by his attorneys, Irwin, McKnight & Hughes, and makes the following Petition for Special Relief
Seeking Temporary Emergency Custody against the Defendant/Respondent, Pamela L. Zeigler:
I.
The petitioner is Kenneth L. Zeigler, Jr., an adult individual who resides at t420 Valley
Road, Marysville, Perry County, Pennsylvania 17053.
2.
The respondent is Pamela Lee Zeigler, an adult individual who resides at 1446 Woods
Road, Lot #4, Shippensburg, Cumberland County, Pennsylvania 17257.
3.
The parties are the natural parents of Kenneth Nonnan Marshall Zeigler, born March 27,
1994, age five (5) years.
2
4.
The Petitioner has a strong desire to maintain a relationship with his son and has filed a
roquest for Increased custody.
S.
The parties are subject to an Order of Court dated November 16, 1998, signed by Judge
Edgar B. Bayley, a copy of which is attached hereto and marked as Exhibit "A," That Order of
Court was modified by Order of Court dated April 9. 1999, signed by Judge Edgar B. Bayley, a
copy of which is marked as Exhibit "B" and made a part hereof.
6,
Since late June of 1999, the respondent, Pamela L. Zeigler, has refused to deliver the
child to the petitioner at the time of his scheduled custody.
7.
On December 6, 1999, the respondent, Pamela L. Zeigler, was sent a letter requesting
custody in accordance with the Court Order of December 18, 1999. A copy of this letter is
attached hereto and marked as Exhibit "C" and made a part hereof. The respondent refused to
deliver the child to the father,
8.
When Bradley Griffie, Esquire, indicated he represented the respondent, a request was
sent dated January 28, 2000, requesting custody on January 29 and January 30. 2000, in
accordance with the Order. A copy of that correspondence is attached hereto and marked as
Exhibit "0," That custody was denied by the respondent.
3
9.
By correspondence dated February 1,2000, Attomey Griffie indicated custody would
occur on February 12 and February 13,2000. A copy of said correspondence Is marked as
Exhibit "E" and made a part hereof,
10.
On February 7, 2000, Attorney Griffie sent a letter indicating that custody would not be
pennitted on February 12 and February 13, 2000. A copy of said correspondence is marked as
Exhibit "F" and is made a part hereof. The petitioner ':lid not have custody of his son on February
12 or February 13,2000.
II.
The petitioner seeks expanded custody of his son in accordance with the existing Custody
Orders. A conciliation hearing Is now set for March 2, 2000, at 8:30 a.m. before Hubert X.
Gilroy, Esquire.
12.
The best interest of the child requires that the court grant the petitioner's request as set
forth above.
13.
The petitioner requests the following temporary emergency custody Order of Court
regarding Kenneth Norman Marshall Zeigler:
a. Petitioner shall have custody of Kenneth Norman Marshall Zeigler,
from Saturday, February 26, 2000 at 8:00 a,m. to Saturday evening
at 8:00 p.m. and Sunday, February 27, 2000 at 8:00 a.m. to Sunday
evening at 8:00 p.m.
4
b. On alternate weekends thereafter from Saturday morning at 8:00 a,m.
to Saturday evening at 8:00 p.m. and Sunday morning at 8:00 a.m. to
Sunday evcning at 8:00 p.m., until further Order of Court.
c. Under no circumstances may Pamela L. Zeigler or her relative take
any action to interfcre with the periods of custody by petitioner with
his son, Kenneth Nonnan Marshall Zeigler as provided herein.
WHEREFORE, the petitioner, Kenneth L. Zeigler, Jr., respectfully requests that this
Honorable Court enter an Order against the respondent, Pamela L. Zeigler, requiring her to
provide the relief set forth above to said petitioner.
Respectfully submitted,
By:
Ight, , Esquire
Allomey r P . ioner
60 West Pomfret Street
Carlisle, Pennsylvania 17013.3222
717-249-2353
Supreme Court I.D. No: 25476
Date: February 17,2000
5
.
NOV 13 199aeP
v
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION. LAW
NO. 97.5831 CIVIL
IN CUSTODY
KENNETH L. ZEIGLER, Jr.,
Plaintiff
PAMELA L. ZEIGLER,
Defendant
COURT ORDER
AND NOW, this l/P day of November. 1993, upon cOrulidcration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
I. This Court's prior order of January 20, 1998 is vacated.
2, The Father's petition for contempt is deemed ....ithdrawn with the understanding
that, in the event Father files any similar petitions in the future, Father may raise
issues from the prior Petition for Contempt in any future petitions,
3. The Mother, Pamela L. Zeigler, and the Father, Kenneth L. Zeigler, Jr., shall enjoy
shared legal custody of the minor child Kenneth N,M. Zeigler, bom March 27,
1994.
4. The Mother shall enjoy primary physical custody of the minor child,
5, The Father shall enjoy temporary physical custody of the minor ehild as follows:
A. On alternating weekends on Saturday and Sunday from 6:30 a.m,
until 6:30 p,m. Father shall provide transportation for exchange of
custody. In the event Father cannot pick the child up by 6:30 a.m. on
each moming, Father shall notify Mother in advance by 6:00 a.m, If
Father is late or unable to come early in the morning, Mother shall
then have the option of then delivering the child to her Father's
home where the Father may pick the child up,
B.
At sueh other times as agreed upon by the parties,
,
C, Father's alternating weekend custody. effective February I, 1999,
shall include an overnight and shall extend from Saturday morning
through Sunday evening.
6. For Thanksgiving 1998, Father shall have custody fonn 3:00 p,m. until 8:00 p.m.
APR 05 1999 f;IJ
KENNETH L. ZEIGLER, JR"
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LA W
v
PAMELA L, ZEIGLER,
Defendant
NO. 97-5831 CIVIL
IN CUSTODY
COURT ORDER
AND NOW, this q-t:L day of April, 1999, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
I, A hearing is scheduled in Courtroom No.2 oCthe Cumberland County Courthouse on
the I 2.~ay of ~1~ , 1999, at 2:t5.d,M. at which time testimony will be
taken in the above case. OAt this hearing, the Father, Kenneth L. Zeigler, Jr., shall be
the moving party and shall proceed initially with testimony, The hearing will be
limited to Father's petition to hold Mother in contempt for violation of the existing
Custody order and on Mother's request to have the existing Custody Order be modified
on the issue of whether Father's visitation with the minor child shall be limited only to
ho~es that do not include an,y cats or other ~mal~ !hat would adversely affecl the
cJ:Uld's asthma condition,L i-J, ;tl..., .fc-..t"~",,: ~ f"'" ~ c.~<--
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2, Pending further order Conn this court, the existing order oCNovember 16, 1998 shall
remain in e(fect subject to the following modifications:
A. Father's periods of alternating weekend visitation with the minor child
shall be on altemating weekends on Saturday and Sunday of each
weekend from 8:00 a,m. until 8:00 p,m. Father shall pick up the minor
child at the maternal grandfather's house. These periods of temporary
custody shall not extend into overnight until after the Court conducts a
hearing on the matters outlined above.
B, In all other respects, the November 16, 1998 order shall remain in
effect.
BY THE COURT,
cc:
Michael Rundle, Esq,
Kenneth Zeigler
IS I c;d..d~"'- ,3 . )b~ Co J,
TRUE COpy FROM RECORD
In T:sfm:nv "h'T:cf. I h,.,-, l'~!~ ~~t r."j hand
and the !,al oi ;..'d Co~rl at Carbl.. Pa,
This 'H,,9~H' day of Opi..e.., 19,,1..1..
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~' Prolhonolal)'
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EXHIBIT "e"
EXHIBIT "0"
<
EXHIBIT "E"
C"UFFIE & ASSOCIA l' :S
Attorneys and Counselors At Law
100 Nonb flllanr Semi
Cnl"l., '" 11013
(717) 143.5551
1(140) ]47.5551
FAX 717.10.5063
Bradley L. Grime
Krlllen Goddard Donlen
Fcbruary 1,2000
]I Nortb M.I. Slml
n.mbcnbu'l, PA 11101
(717) 167.1350
Robia .I. COlbora
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FEB 02 2000
R.pl)' to: C.rU,I.
Marcus A, McKnight, 1lI, Esq,
West Pomfret Professional Building
60 Wcst Porn fret SI.
Carlisle, PA 17013.3222
IRWIN, McKNIGHT & HUGHES
RE: Zcigler v. Zcigler
Dear Marcus:
Your facsimile correspondencc of January 28, 2000, was received in my office on Friday,
January 28, while I was in Court and settlements in Chambersburg. I did not scc that
correspondence until over the weekend and, thereforc, could not advise my client, even by
tclcphonc, that we had a propcr telephone number for Mr, Zeiglcr.
Quite frankly, we arc plcascd that hc finally has securcd an appropriatc number where he
can be contacted in the event of emcrgencies, as requircd by the Court Order. Now that he has
complied, my clicnt will, of ~ourse, follow the Court Ordcr as has always been her intention.
I suspcct that any rcqucst for emcrgcncy relief and contempt on bchalf of your client,
who has rcfuse::! to release his telcphonc number and othcrwisc failcd to take any action for
several months to have any contact with his son, would likely bc met with the same response as
he received last year whcn he proccsscd a pro se contempt action against my client in front of
Judge Bayley.
I prcsume this means your client will be available to pick the child up on Saturday
morning and Sunday morning, February 12 and 13 at 8:00 a.m. and return the child at 8:00 p.m.
on those two days. If this is not correct. please lct me know immcdiately.
BLGlklg
cc: Pamela Zeigler
.
C'UFFIE & ASSOCIA T"""S
Attorneys and Counselors At Law
Bradley L, Grime
Kristen Goddard Donsen
100 North HlaDy., St,",
Carlld.. PA 1701J
(717) 143.5551
1(100) 34'.5551
FAX 717.l4J.5G63
Robia J. GOlhom
lfl.1 "ulatlOl
February 7, 2000~~CG~a~[~
FEB 0 9 2000
31 NOMh M.I. Sl,..,
Chemhmbu'l, PA 17101
(717) 167.1J50
R.pl)' 10; Carll...
Marcus A, McKnight, III, Esq,
West Pomfret Professional Building
60 West Pomfret SI.
Carlisle, PA 17013-3222
IRWIN, McKNIGHl & HUGHES
VIA FACSIMILE AND U,S, MAIL
RE: Zeigler v. Zeigler
Dear Marcus:
The Court Order in this case requires Mr. Zeigler to provide us with a telephone number.
He has provided us with a beeper number or pager number. That is not acceptable. It is
particularly not acceptable when he doesn't return the call anyway.
In the past, my client has had a number for a beeper or pager and placed a call to Mr.
Zeigler and he did not return the call. This time, she placed a call to this number and he did not
return the call. The idea of having the phone number is so that Ms. Zeigler can contact him in
emergency situations relative to the child, whether the child was with him or with her. She
cannot do that with this beeper,
Under the present circumstances where Mr. Zeigler has made no attempts to contact his
child for four or five months until your recent demand, it seems there may be a belleI' way to
approach this situation, Although we are hopeful that the child will go with him for his Court
ordered visitation, it certainly would make sense if the child was able to have some type of
telephone contact with Mr. Zeigler prior to that visit occurring, Please provide a telephone
number by mid-week so that we do not run into additional difficulties with Mr. Zeigler having
his son.
A telephone number is a number where Mr. Zeigler can be reached by telephone, It is
time for Mr. Zeigler to stop playing games,
In addition, it is absolutely absurd that Mr. Zeigler's girlfriend feels she needs to sit in his
car and videotape the exchange of custody. In the past, he has used a tape-recorder, which is just
as absurd, My experience with our judges in this County is that they find that to be ridiculous
and also a strong suggestion that the party recording the situation is essentially pUlling on a show
for evidence purposes. We look forward to receiving Mr. Zeigler's home telephone number, not
a beeper number, pager number or someone else's phone number.
BLGlklg
cc: Pamela Zeigler
~
The foregoing Petition is based upon infonnation which has been gathered by
counsel and mysetf in the preparation of this action, I have read the statements made in this
document and they are true and correct to the best of my knowledge. infonnation and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unsworn falsification to authorities.
Date: February 17 .2000
KENNETH L. ZEIGLER, JR.,
PlalntifflPetttloner
: IN THE COURT OF COMMON PLEAS OF
v.
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
97.S831 CIVIL TERM
PAMELA L. ZEIGLER,
Defendant/Respondent
IN CUSTODY
CERTIFICATE OF SERVICE
I, Marcus A. McKnight. Ill, Esquire, hereby certify that a copy of attached Petition was
served upon the following by depositing a true and correct copy ofthe same in the United States
mail, First Class, postage prepaid in Carlisle, Pennsylvania,
on the date referenced below and addressed as follows:
Bradley L. Griffie, Esq.
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
IR:N'M'VJ~
By. Marcus A ,McKnight, III, Esquire
60 West Pam fret Street
Carlisle, P A 17013
(717) 249-2353
Supreme Court 1.0. No. 25476
Date: Februaryl7.2ooo
.
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SHERIFF'S RETURN, REGULAR
CASE NO: 1997,05831 P
COMMONI'iEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ZEIGLER PAMELA L
VS
ZEIGLER KENNETH L JR
CPL, MICHAEL BARRICK
, Sheriff or Deputy Sheriff of
Cumberland County, Pensylvania, who being duly sworn according to law,
says, the within PROTECTION FROM ABUSE, NO was served upon
ZEIGLER KENNETH L JR
the
DEFENDANT
, at 0013:36 HOURS, on the 3rd day of February, 2000
at POE: LEAR CORPORATION
CARLISLE, PA 17013
KENNETH L. ZEIGLER
SO SPRING ROAD
by handing to
a true and attested copy of PROTECTION FROM ABUSE, NO together with
OF HEARING & ORDER. TEMPORARY PROTECTION FROM
ABUSE ORDER, CONTINUANCE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
1B.00
3.10
.00
10.00
.00
31.10
Sworn and Subscr.ibed to before
me this "I'1!!- day of
'J,t...... ~C"'Cv A.D.
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V 'Prothonotary .
So ;;~~
R. Thomas Kline
02/04/2000 //)
By, ~~~..
A Deput Sheriff
,
.
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~ - 7 2~\)
KENNETH L. ZEIGLER. JR"
Plaintiff
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
NO, 97-5831 CtVIL
IN CUSTODY
v
PAMELA L. ZEIGLER,
Defendant
COURT ORDER
AND NOW. this ~ day of March, 2(00. upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
I. The existing custody schedule for the Father having -he minor child on each
Saturday and Sunday from 8:00 a,m. until 8:00 p,m. shall continue. Father shall
continue to pick up the minor child and return the minor child to the maternal
grandfather's house.
2. The parties shall meet for another Custody Conciliation Conference on April 27,
2000 at 10:30 a.m. At this Conciliation Conference, the Conciliator will address the
possibility of recommending overnight visitation to be started based upon the history
of the periods of temporary custody between the date of this order and that
Conciliation Conference. Additionally, the Conciliator will examine the issue of
telephone contact and whether the Father will be mandated to provide a home phone
number to the Mother.
3. In the event of any exigent circumstances for which either council believes this case
needs to be addresSP.d prior to the scheduled Conciliation Conference, counsel for
either party may contact the Conciliator for a telephone conference call at which
time the conciliator may recommend to the court a modification of this Order.
4. This Court's order of February t8, 2000 shall remain in effect in the sense that the
parties shall strictly comply with the applicable Court C1rders pending any further
Order of Court, I /
. ,I'
cc: Bradley L. Griffie, Esquire
Marcus A. McKnight, III, Esquire
()
J /1\.0
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JJ
v
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL ACTION - LAW
NO. 97-5831 CIVIL
IN CUSTODY
KENNETH L. ZEIGLER. JR"
Plaintiff
PAMELA L. ZEIGLER.
Defendant
Prior Judge: Edgar B, Bayley
CONCILIATION CONFERENCE SUMMARY REPOR.I
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
191 5.3-8(b), the Wldersigned Custody Conciliator submits the following report:
\. The pertinent infonnation pertaining to the child who is the subject of this litigation is as
follows:
Kenneth N. M, Zeigler, born March 27.1994.
2. A Conciliation Conference was held on March 2, 2000. with the following individuals in
attendance:
The Father, Kenneth L. Zeigler, Jr,. with his cOWlsel. Marcus A. McKnight. III. Esquire; and
the Mother, Pwne1a L. Zeigler, with her counsel, Bradley L. Griffie, Esquire,
3. Based upon the recommendation of the Conciliator, the parties tentatively agreed to the
entry of an order in the fonn as attached.
J /7/ 00
DATE
'.(./- fJ jJ
Hubert X. Gilroy, Esqui
Custody Conciliator
JUN 0 7 zoorJlJ
KENNETH L. ZEIGLER, JR,.
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 97-5831 CIVIL
IN CUSTODY
v
PAMELA L. ZEIGLER,
Defendant
COURT ORDER
AND NOW. this -z-d day of June, 2000. upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
I. All prior custody orders are vacated,
2. The Mother, Pwnela L. Zeigler, and the Father, Kenneth L. Zeigler, Jr" shall enjoy
shared legal custody of Kenneth N. M, Zeigler, born March 27. 1994.
3. The Mother shall enjoy primary physical custody of the minor child.
4. Father shall enjoy periods of temporary physical custody of the minor child as
follows:
A. On alternating weekends during the summer from Saturday at 8:00
a.m. until Sunday at 8:00 p,m, During the school year, Father shall
return the child on Sunday evening at 7:00 p,m, In the event Father
knows he will be working on a weekend that he is scheduled to have
custody of the minor child, Father shall notify Mother at least 48
hours in advance that he has work that weekend llIId he will not be
exercising custody. The parties will work between themselves to
arrange for a make-up weekend.
5. The holidays of July 4th. Labor Day, Easter and Memorial Day shall be alternated
with Mother having July 4th in 2000 and Easter in 2001. with Father having Labor
Day in 2000 and Memorial Day in 2001. The parties will alternate thereafter.
6. The Thanksgiving holiday shall be handled with Mother having custody from 9:00
a.m. until 3:00 p.m. and the Father having custody from 3:00 p,m. until 8:00 p,m.
The Christmas holiday shall be handled with Father having custody on Christmas
Eve from 9:00 a,m. until 8:00 p,m, and Mother having custody from 8:00 p,m, on
Christmas Eve through the end of Cluistmas Day, New Year's holiday shall be
handled with Father having custody from 9:00 a.m. on New Year's Eve until 8:00
p.m. on New Year's Eve and Mother having custody from 8:00 p,m. on New Year's
Eve through New Year's Day,
7. Starting in the summer of 2001, Father shall have olle week of vacation with the
minor child which shall be Father's week off work, Father shall notifY Mother in
May of each year as to the specific date of his weck off from work. Mother shall
also be entitled to take one week of vacation in the summer that may require Father
to alternate his vi~itution schedule depending upon when Mother will be exereising
her week of summer vacation with the minor child.
8. Both parents shall ensure that the minor child is provided with doctor prescribed
medication in accordance with any prescription that is provided by any treating
physician.
9. Neither party shall expose the child to cigarette smoking when the child is in their
custody.
10, Father shall provide Mother with a telephl'ne number that he CM be reached at all
times. to be Father's beeper number or cell phone nwnber. In the event Father does
not return calls or it becomes problematic to the degree that Mother is unable to
reach Father in times of necessity. Father will be required in the future to provide
Mother with his home phone number.
II. In the event either party desires to modifY this order in the future, that party may
petition the Ccun to have the case again scheduled for a CustOjly Conciliation
Conference. /
BY THE COURT,
I
,
cc:
Bradley L. Griffie, Esquire
Mareus A. McKnight, III, Esquire
"\:JJ ~w: J.
Edgar B. Bayley r r..;;
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OCT 1 7 2fnJ\
--"j\)
KENNETH L. ZEIGLER, JR.,
Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
97-5831 CIVIL TERM
PAMELA L. ZEIGLER,
Respondent
IN CUSTODY
ORDER OF COI:RT
AND NOW, this.1K day of October 2000, upon consideration of the attached Petition
for Special Relief,
IT IS HEREBY ORDERED that a hearing regarding this Petition for Special Relief is
hereby scheduled for~ove~PR '.b.-' 2000, at~'clock -fL,m. in Courtroom Number
L, Cumberland County Courthouse, Carlisle, Pennsylvania 17013 at which time the parties
along with their legal counsel shall appear in person,
BY THE COURT,
",-
KENNETH L. ZEIGLER, JR,
PETITIONER
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
PAMELA L. ZEIGLER,
RESPONDENT
: 97-5831 CIVIL TERM
ORDER OF COURT
AND NOW, this :JD day of October, 2000, upon agreement of
counsel, the special relief hearing currently scheduled for November 6, 2000, Is
cancelled and rescheduled for Monday, November 20,2000, at 10:00 a,m" In
Courtroom Number 2,
1y
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Marcus A. McKnight, III, Esquire
For Petitioner
Bradley L. Griffie, Esquire
For Respondent
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91:{: ~\d Oc 13000
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t2.
The avennenls of fact contained in paragraph twelve (12) of the New Matter are denied.
On the contrary, the Petition for Special Relief is important to ensure that the petitioner's periods
of custody will not be interfered with in the future by the respondent.
WHEREFORE, the petitioner, Kenneth L. Zeigler, Jr. respectfully request that this
Honorable Court enter an Order against the respondent, Pamela L. Zeigler, requiring her to
provide the relief set forth above to said petitioner.
Respectfully submitted,
IRWIN, McKNIGHT & HUGHES
By:
A. Mc t, III, EsquIre
Attorney for Petitioner
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
717-249-2353
Supreme Court to. No: 25476
Date: Novembrer 20, 2000
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KENNETH L. ZEIGLER. JR.
PLAINTIFF
V,
Pi\MELA L. ZEIGLER
DEFENDANT
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
97.5831 C'IVIL ACTION LAW
IN CUSTODY
ORDER OF ('()\IRT
AND NOW, this 3rd day of. November, 2000. upon consideration of the attached Complaint.
it is hereby directed that the parties and their respective counsel appear before Hubert X. Gilroy, Esq. . the conciliator.
at 4tb Floor, Cumberland County Courthouse. Carlisle on thc .-!:!!!'dayof December .2000. at...1!30 a,m.
for a Pre-lIearing Custody Conference, At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished. to delinc and narrow the issues to he heard by the court. and to enter into a temporary
order. All children age live or older may also he 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: Isf
Hilbert X. GilrQy. E<,,';,
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 prim'to any hearing or business before the court. You must
allend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR A'!TORNEY AT ONCE. IF YOU DO NOT
HAVE AN A '!TORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
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Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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KENNETH L, ZEIGLER. JR.,
Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
97-S831 CIVIL TERM
PAMELA L, ZEIGLER,
Respondent
IN CUSTODY
ORDER Qf COURT
AND NOW, this day of . 2000, upon consideration of the
attached petition, it is hereby directed that the parties and their respective counsel appear
before Esquire, the conciliator, at
.onthe_dayof ,2000at_ ,M.
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 this conference may provide grounds for entry of a
temporary or pennanent order,
By the Court,
By:
Custody ConelJlator
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Oar Assoelatlon
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
1-800-990-9108
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990, For infonnation 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 scheduling conference or hearing,
r-~" .... .,...._=........,~-
KENNETH L. ZEIGLER. JR.,
Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSVLV ANIA
v.
CIVIL ACTION - LA W
97.5831 CIVIL TERM
PAMELA L, ZEIGLER.
Relpondent
IN CUSTODY
I'ETITION FOR CONTEMPT
AND NOW, this 31st day of October, 2000. comes the Petitioner, Kenneth L. Zeigler, Jr.,
by and through his attorneys, Irwin, McKnight and Hughes, and presents the following Petition
for Contempt.
I.
The petitioner is Kenneth L. Zeigler, Jr., an adult individual who resides at 1420 Valley
Road, Marysville, Perry County, Pennsylvania 17053,
2.
The respondent is Pamela Lee Zeigler, an adult individual whose current address may be
1466 Woods Road, Lot #4, Shippensburg, Cumberland County, Pennsylvania 17257.
3.
The parties arc the natural parents of one minor child, namely Kenneth Nonnan Marshall
Zeigler, born March 27, 2994.
2
4,
Upon consideration of the Custody Conciliation Report, Edgar B, Bayley, Judge, issued
an Order of Court dated June 20, 2000, which granted periods of temporary physical custody of
Kenneth Nonnan Marshall Zeigler. A copy of that Order of Court is attached hereto and is
marked as Exhibit "A".
S.
The Petitioner has filed an action in custody seeking more time with his son,
6.
The respondent, Pamela L. Zeigler, has refused to abide by Order of Court dated June 20, 2000,
by refusing to allow Petitioner, Kenneth L. Zeigler, Jr., his periods of temporary physical custody
as indicated in said Order without interference on interruption,
7,
The petitioner seeks to maintain his periods of temporary physical custody of the minor
child as stated in the Order of Court dated June 20, 2000, without interference or interruption by
the respondent.
8.
On Saturday, October 7, 2000, the parties had agreed that custody of Kenneth Nonnan
Marshall Zeigler would transfer immediately following his soccer game at approximately 12:00
noon. The petitioner sought to exercise his period of temporary custody, The respondent placed
their son in her car, locked the doors, and refused to let him leavc with the petitioner,
3
9,
The respondent deliberately denied the petitioner of his weekend period of custody with
his son.
10,
The petitioner seeks an Order of Court prohibiting the respondent from interfering with
the Court Order entered on June 20, 2000, by Judge Edgar B, Bayley, The petitioner also seeks
addi!ional time with his son as well as payment of his reasonable legal fees.
WHEREFORE, the petitioner, Kenneth L. Zeigler, Jr. respectfully request that this
Honorable Court enter an Order against the respondent, Pamela L. Zeigler, requiring her to
provide the relief set forth above to said petitioner.
RespectfuUy submitted,
IRWIN, McKNIGHT & HUGHES
By:
Date: October 31, 2000
4
~
The foregoing Petition for Contempt is based upon information which has been sathered
by counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subjt:ct to the penalties of 18 Pa, C.S.A. Section
4904, relating to unsworn falsification to authoriti~.
Date: October 31, 2000
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
KENNETH L. ZEIGLER, JR"
Plaintiff/Pctitioner
PAMELA L. ZEIGLER, : NO. 97-5831 CIVIL TERM
Dcfcndant/Rcspondcnt : IN CUSTODY
NOTICE TO PLEAO
You arc hcrcby notificd to filc a wrillcn rcsponsc to thc within NEW MATIER within
twenty days (20) days from scrvicc hereof or a judgment may be cntcrcd against you,
a.) It is admilled thatthc partics agreed thatthc cxchangc of custody, pursuant to thc
Court's Ordcr of Junc 20, 2000, would occur at 12:00 p.m. on October 7, 2000.
b,) It is admitted that the Petitioner sought to exercise his pcriod of tcmporary
custody,
c.) It is dcnicd that the Rcspondent placcd thc child in hcr car, lockcd the doors or
refused to allow thc child to leavc with thc Pctitioncr. It is avcrrcd, rathcr, that
thc child indicatcd to both partics that hc wishcd to havc thc opportunity to attend
a special community cvent that aftcrnoon with both partics. It is furthcr averred
that when the Rcspondent indicated that shc would do that, Petitioncr bccame
extremely agitated and bcgan thrcatening thc Rcspondcnt's safety and welfare
causing the Respondcnt to fcar for hcr safcty and to call the local policc
departmcnt, It is furthcr averred that by the time thc local police department
arrivcd, Pctitioner had Oed the area and Respondcnt rctained the child at that
time. It is further avcrrcd that dcspitc the factthut Petitioncr was to havc thc child
for the cntire weckend, hc made 110 lurthcr contact that weekend with Rcspondent
to make arrangcments to secure thc child. It is averrcd that Petitioncr has rcfuscd
to providc Respondent with any mcans of telephonc contact with him, dcspite the
rcquircmcnts of paragraph 10 of thc aforcsaid Order. It is further averrcd that
Pctitioncr rcfuses to givc rcquired noticc to Rcspondent as set forth in the partics'
Ordcr,
8. Denied. It is dcnied thatthc Rcspondcnt delibcratcly or in any othcr way dcnicd thc
Petitioncr his weckcnd pcriod of custody with the parties' child.
9, Admilled in part but denied as stated, It is admilled that the Petitioner seeks the relief
requested. It is denied that sueh relief is appropriate in that the Respondent has done
nothing to prohibit the Petitioner from exercising his rights under the Court's Order
of June 20, 2000. It is further denied that the Respondent has done anything to cause
Petitioner to require legal services, particularly in that the claims set forth in the
Petition for Special Relief were never even broached with Respondent or her counsel
prior to the filing of the Petition. It is further averred that the Petition for Special
Relief is, in fact, n Complnint for Contempt which was filed in the form of a Petition
for Specinl Relief in order to avoid the conciliation process where this mailer could
and should be resolved more expeditiously and with far less expense,
NEW MA TIER
10, Petitioner hns filed a Petition for Contempt against Respondent which is nllnched
hereto nnd incorporated herein by reference as Exhibit "A," which is the exact same
document Petitioner filed as his Petition for Special Relief.
11. Petitioner's Petition for Special Relief, in fact, is a Petition for Contempt, which is
evidenced by the prayer for relief, that should be heard by the conciliator pursuant to
practice in the Court of Common Pleas of Cumberland County,
12, Petitioner's Petitivn for Special Relief should be dismissed so the Petitioner for
Contempt may proceed through the appropriate legal channels,
:1
,
KENNETH L, ZEIGLER, JR.,
Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
97-5831 CML TERM
PAMELA L. ZEIGLER,
Respondent
IN CUSTODY
ORDER OF COURT
AND NOW, this day of . 2000, upon consideration of the
attached petition, it is hereby directed that the parties and their respective counsel appear
before Esquire, the conciliator, at
.onthe_dayof ,2000at_ . M.
for a Pre-Ht:aring 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 this conference may provide grounds for entry of a
temporary or pennanent order.
By the Court,
By:
Custody Conciliator
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWVER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OmCE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar AssociatIon
2 Liberty Avenue
CarUsle, Pennsylvania 17013
(717) 249-3166
1-800-990-9108
EXHIBIT A
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AMERICANS WITH DISABn..ITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodatiol18 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 scheduling conference or hearing.
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
KENNETH L, ZEIGLER., JR.,
Petitioner
97-5831 CIVIL TERM
PAMELA L. ZEIGLER.,
Respondent
IN CUSTODY
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PETITION FOR CONTEMPT
AND NOW, this 31 5t day of October, 2000, comes the Petitioner, Kenneth L. Zeigler, Jr"
by and through his attorneys, Irwin, McKnight and Hughes, and presents the following Petition
for Contempt.
I.
The petitioner is KeMeth L. Zeigler, Jr" an adult individual who resides at 1420 Valley
Road, Marysville, Perry County, PeMsylvania 17053,
2.
The respondent is Pamela Lee Zeigler, an adult individual whose current address may be
1466 Woods Road, Lot #4, Shippensburg, Cu."llberland County, PeMsylvania 17257,
3.
The parties are the natural parents of one minor child, namely Kenneth Norman Marshall
Zeigler, born March 27, 2994.
2
4,
Upon consideration of the Custody Conciliation Report, Edgar B, Bayley, Judge, issued
an Order of Court dated June 20. 2000. which granted periods oftemponuy physical custody of
Kenneth Norman Marshall Zeigler, A copy of that Order of Court is auached hereto and is
marked as Exhibit "A",
5,
The Petitioner has filed an action in custody seeking more time with his son.
6.
The respondent, Pamela L. Zeigler, has refused to abide by Order of Court dated June 20, 2000,
by refusing to allow Petitioner, KeMeth L. Zeigler, Jr., his periods of temporary physical custody
as indicated in said Order without interference on interruption.
7.
The petitioner seeks to maintain his periods of temporary physical custody of the minor
child as stated in the Order of Court dated June 20, 2000, without interference or interruption by
the respondent.
8.
On Saturday, October 7,2000, the parties had agreed that custody of KeMeth Norman
Marshall Zeigler would transfer immediately following his soccer game at apprOltimately 12:00
noon. The petitioner sought to exercise his period of temporary custody. The respondent placed
their son in her car, locked the doors, and refused to let him leave with the petitioner.
3
9.
The respondent deliberately denied the petitioner of his weekend period of custody with
his son.
10,
The petitioner seeks an Order of Court prohibiting the respondent from interfering with
the Court Order entered on June 20, 2000, by Judge Edgar B. Bayley. The petitioner also seeks
additional time with his son as well as payment of his reasonable legal fees,
WHEREFORE, the petitioner, Kenneth L. Zeigler, Jr. respectfully request that this
Honorable Court enter an Order against the respondent, Pamela L. Zeigler, requiring her to
provide the relief set forth above to said petitioner.
Respectfully submitted,
IRWIN, McKNIGHT & HUGHES
Marc s . McKnlght,
Attorne. for Petitioner
60 West Po t Street
Carllsle, Pennsylvania 17013-3222
717-249-2353
Supreme Court 1.0. No. 25476
By:
Date: October 31, 2000
4
KENNETH L, ZEIGLER, JR.,
Petldoner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
v,
PAMELA L, ZEIGLER,
Respondent
97-5831 CIVIL TERM
IN CUSTODY
!;F;RTIFICATE OF SERVICE
I, Marcus A. McKnight, U1, Esquire, do hereby certify that I have served a lnIe and
correct copy of the tbregoing Petition for Contempt upon counsel for the Respondent by placing
it in the United States Mail, first class postage prepaid in Carlisle, Pennsylvania 170 I 3, upon the
following:
Bmdley L. Griffie, Esquire
GRIFFIE &; ASSOClA TES
200 North Hanover Street
Carlisle, PA 17013
By:
- ~6
M cus A. M t, III, Esquire
Attorney for Peddoner,
Kenneth L. Zeigler, Jr.
Date: November I s~ ,2000
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JUN 0 7 2000 ft'
KENNETII L. ZEIGLER, JR"
Plaintiff
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION . LAW
NO, 97.5831 CIVIL
IN CUSTODY
v
PAMELA L. ZEIGLER,
Defendant
COURT ORDER
AND NOW, this ,f)() day of June, 2000, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
I. All prior custody orders are vacated.
2, The Mother, Pamela L. Zeigler, and the Father, Kenneth L. Zeigler, Jr" shall enjoy
shared legal custody of Kenneth N, M. Zeigler, born March 27, 1994.
3. The Mother shall enjoy primary physical custody of the minor child.
4. Father shall enjoy periods of temporary physical custody of the minor child as
follows:
A. On alternating weekends during the summer from Saturday at 8:00
am. until Sunday at 8:00 p.m. During the school year, Father shall
return the child on Sunday evening at 7:00 p.m. In the event Father
knows he will be working on a weekend that he is scheduled to have
custody of the minor child, Father shall notify Mother at least 48
hours in advance that he has work that weekend and he will not be
exercising custody. The parties will work between themselves to
arrange for a make-up weekend.
5, The holidays of July 41h, Labor Day, Easter and Memorial Day shall be alternated
with Mother having July 41h in 2000 and Easter in 2001, with Father having Labor
Day in 2000 and Memorial Day in 200 \. The parties will alternate thereafter.
6. The Thanksgiving holiday shall be handled with Mother having custody from 9:00
am. until 3:00 p.m, and the Father having custody from 3:00 p,m. until 8:00 p.m.
The Christmas holiday shall be handled with Father having custody on Christmas
Eve from 9:00 a.m, until 8:00 p.m. and Mother having custody from 8:00 p.m, on
Christmas Eve through the end of Christmas Day, New Year's holiday shall be
handled with Father having custody from 9:00 a.m. on New Year's Eve until 8;00
p.m. on New Year's Eve and Mother having custody from 8:00 p.m. on New Year's
Eve through New Year's Day.
7. Starting in the sununer of 2001, Father shall have one week of vacation with the
minor child which shall be Father's week off work. Father shall nOlify Mother in
May of each year as to the specific dale of his week off from work. Mother shall
also be entitled to take one week of vacation in the sununer that may require Father
to alternate his visitation schedule depending upon when Mother will be exercising
her week of swnmer vacation with the minor child.
8, Both parents shall ensure that the minor child is provided with doctor prescribed
medication in accordance with MY prescription that is provided by MY treating
physician.
9. Neither party shall expose the child to cigarette smoking when the child is in their
custody,
10. Father shall provide Mother with a telephone nwnber that he can be reached at all
times, to be Father's beeper nwnber or cell phone nwnber. In the event Father does
not return calls or it becomes problematic to the degree that Mother is unable to
reach Father in times of necessity, Father will be required in the future to provide
Mother with his home phone nwnber.
II, In the event either party desires to modify this order in the future, that party may
petition the Court to have the case again scheduled for a Custody Conciliation
Conference,
BY THE COURT,
Isft';J~Ah) 11..&11
Edgar B. ayley
cc: Bradley L. Griffie, Esquire
Marcus A. McKnight, 01, Esquire
T~I':: COpy FRO RECORD
III 1\11.' 'f ,,".".:1, I h~~e nlo s~t my hind
.nd t',; ,""I of said CJ~rt a ar:isle, Pa,
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Prolhono!atV
fiLE No.51? 02/16 '00 14150 ID:LHn. SCRVICES, ll'l:,
,
FAX: 7172438026
POOO 2
PAtVfELA L. ZElOLER.
for hmelfand on behalf
orthe minor child,
Kenneth Nonnan.
Marshall Zeilller,
Plalnllff
IN THE COURT OF COMMON PLl!AS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
KENNETH L. ZEIOLER, :
JR,.
Defendanl
NO, 97.5871 CIVIL TERM
FIliAL PROTECTION pRDER
Defendant's Name: KeMeth L, Zeisler, Jr.
Defendant's Date of Birth: 51316'
Defendant's Social Security Number: 176.'6-7336
Names orall Protected Penolll: Pamela Zellllor, Ihe Plalnliff.
AND NOW, this 14th day of February, 2000,1hc court havlngjurisdlctlon
over the parties and the subject-matter, It Is ORDERED, ADJUDGED, and
DECREED 05 follows:
The Plalntlff, Pamela Zeialer, is represented by Maryann Murphy of Leiil'l
Services, Inc,; the Defendant. Kenneth L. Zeisler, Is represented by MltCus A.
McKnlshl, IIJ, Esq. After a hearlnS in the: above ClIplloDed matter, the Court finds
that Defendant, Kenneth Zeisler, has abused Plaintiff, Pamela Zeisler, pursuant to
23 Pa. C,S, g6102.
Plalntlfrs request for a Final Proteclion Order Is granted,
I. Defendant shall not abuse, stalk, harass, or threaten the Plaintiff or any
other prolected person In any place where they mlllht be found.
2. The followini additional relief is granted as authorized by 66108 of the
Act:
PAMELA L, ZEIGLER, for
h~rselt and on behalf of
the minor child,
KENNETH NORMAN-MARSHALL
ZEIGLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
KENNETH L. ZEIGLER, JR"
Defendant
CIVIL ACTION - LAW
PROTECTION FROM ABUSE
<r';/
No. 97-~ CIVIL TERM
ORDER OF COURT
AND NOW, this 11th day of February, 2000,
upon c?nsideration of Plaintiff's Petition for Protection
from Abm:l1 Order. awl following a hearing, the record is
declared c~osed, the matter is taken under advisement, and
the Temporary Protection from Abuse Order entered on
January 2R, 2UOO, shall remain in full f.orce and effect,
By the Court,
J.
"
Maryann Murphy, Esquire /
For the Plaintiff
Marcus McKnight, III, Esquire
For the Defendant
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