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HomeMy WebLinkAbout97-06005 il I; i . ;I "~ J 1\ 5 ~ j 8 ~ " TODD E, SEIDEL, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V, DONNA LEE SAYERS, DEFENDANT , : 97-6005 CIVIL TERM ORDER OF COURT AND NOW, this 28th day of April, 1998, upon relation by counsel for Todd E. Seidel that his client is withdrawing the within complaint for custody, the hearing scheduled for August 17, 1998, IS CANCELLED. ~ Marcus A. McKnight, III, Esquife For Plaintiff ~A. f'I>"~L 't j211/q f. ...&:1.l. Joan Carey, Esquire For Defendant :saa / ~~F.D-OFrl'~:~ r,= r" 1," -.. ':" ~T".,y 1':3 ~F~:?8 Fii I: 10 CL't:>.1 ~ \,,c ,-i.~''ji'''I)' f-i:.;'~,' ,;: {~,,'> ;....\ dJAH 291998 TODD E. SEIDEL, PlaintiU V IIN THE COURT OF COMMON PLEAS OF ICUMBERLAND COUNTY, PENNSYLVANIA I ICIVIL ACTION - LAW I INOI 97-6005 CIVIL TERM IIN CUSTODY DONNA LEE SAYERS, Defendant COURT ORDER AND NOW, this ,? uL day of January, 1998, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as followsl 1. A hearing is scheduled in Couft Room No.2 of the Cumberland County Courthouse on the .2 -" day of GO\~ f , 1998, at t 'IS a .m. at which time testimony will be taken in the above case. At this hearing, the Father, Todd E Seidel, shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing Counsel a memorandum setting forth the history of custody in this case, the issues currently before the Court, a list of witnesses who will be called to testify for each party and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least ten days prior to the mentioned hearing date. 2. Pending further Order of ~his Court, the following temporary Custody Order is entered: A. The Mother, Donna Lee Sayers, and the Father, Todd E. Seidel, shall enjoy shared legal custody of the minor child, Ryan Daniel Seidel, born January 7, 1983. B. The Mother shall enjoy primary physical custody of the minor child. C. The Father shall enjoy temporary physical custody of the minor child on alternating weekends from Friday at 6130 p.m. until Sunday at 4:00 p.m. and such other times .. agreed upon by the parties. Father shall handle transportation for custody. 3. Any counselor for the minor child is authorized to include both parents in counseling sessions and is also authori.ed, at their discretion, to share whatever information they teel is appropriate with the parents. ,I ! J. CCI Marcus A. McKnight, III, Joan B. Carey, Esquire \\~:~'). ' ~, I v tIN THE COURT OF COMMON PLEAS OF tCUMBERLAND COUNTY, PENNSYLVANIA t tCIVIL ACTION - LAW t tNOt 97-6005 CIVIL TERM tIN CUSTODY TODD E. SEIDEL, Plaintiff DONNA LEE SAYERS, Defendant Prior Judget 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 reportt 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Ryan Daniel Seidel, born January 7, 1983. 2. A Conciliation Conference was held on January 20, 1998, with the following individuals in attendancet The Father, Todd E. Seidel, with his counsel Marcus A. McKnight, III, Esquire; and the Mother, Donna Lee Sayers, with her counsel, Joan E. Carey, Esquire. 3. This case involves a 15 year old boy who lives with his Mother. There is a prior Order from 1985 which gave the parties shared custody. However, the parties agree that the child has been living primari.ly with the Mother. There is a dispute as to how much time the Father has spent with the child. Father suggests that he has spent a fair amount of time with the child over the past few years. Mother suggests that the Father has had little contact with the son. 4. Father now has concerns relative to Mother's parenting abilities and the overall situation the son finds himself in at this time. Father notes that school reports indicate that the son is smoking marijuana and not doing very well in class. Father feels the son should come to live with him so that he can try to straighten things out. Father notes that the son's older brother has already dropped out of school and not completed high school and Father does not want to see Ryan take the same path. Mother suggests that she is taking action to ensure that Ryan is performing up to his abilities. Additionally, she notes that the Father has had no significant prior contact with the child. Mother further asserts that Ryan does not want to go to live with his Father. 5. The parties are at odds and a hearing is required. A hearing should take no more than one day. Todd E, Seidel, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO, 97-600S CIVIL TERM Donna L. Sayers, Defendant CUSTODY DEFENDANT'S MEMORANDUM ON CUSTODY I. Factual History._and R!U.il..U2.Y&.ht The defendant, Donna L. Sayers, hereinafter referred to as the mother, and the plaintiff, Todd E. Seidel, hereinafter referred to as the father, are the parents of Ryan O. Seidel (008 1/7/83). The mother and father have been divorced since 1985 and Ryan has resided with his mother, having little contact with his father. Currently, Ryan and his mother reside in a three-bedroom townhouse in Carlisle with Ashley Sayers, Ryan's half-sister, and Kyle Sayers, Ryan's half-brother. Ryan has a good relationship with his siblings with whom he has resided since their births, and the mother feels it is not in his best Interest to be separated from them. For approximately two years from 1985 until 1987, the father had regular periods of partial custody of Ryan every other weekend, From 1987 until 1997, the father stopped exercising his right to partial custody every other weekend and only saw Ryan approximately three times In ten years. Ryan and his mother repeatedly requested the father to exercise his periods of custody, but he refused. In 1997, the father contacted the mother asking to see Ryan. ~'rom the beginning of Jtinuary 1997 unt i I the present, the father has had Ryan for approximately five weekends. Ryan does not have a close relationship with his father tind his family, and finds it difficult to communicate with them. The mother is a responsible parent and has consistently taken care of Ryan, providing for his emotional and physical needs since his birth, The father has had very limited contact with Ryan since his birth and for several years had no contact with his son. The mother has monitored Ryan's school progress. She is in contact with the school counselor and is attempting to encourage and support Ryan through this school year. The mother understands that Ryan has been placed In a class where he is expected to perform above his ability. He is, therefore, having problems in school due to the advanced levei of the work, She also feels that his progress has also been affected by his struggle regarding his father's suit for custody which seems to have traumatized him, The mother encourages Ryan to visit with his father, which is difficult because of the fact that Ryan feels estranged horn his father and feels that the father abandoned him in his early childhood. Ryan, at this stage of his life, has developed friends and other activities which make a regular alternating weekend schedule unrealistic, Ryan prefers remaining in his mother's custody, and he does not see the need to be forced into a closer relationship with a father who has not been in his life until now. furthermore, Ryan cannot communicate his feelings to his father despite several attempts to do so. Ryan has tried to cooperate with the court" ordered visits at his mother's urging, but he requests that the Court modify the Order to replace the regular periods of partial custody 011 alternating weekends with vlsltatloll that will be at times mutually agreed upon by the parties. I I. Defendant's Witnesses J..1JH The defendant, Donna L. Sayers, by and through her attorney, Joan Carey of Legal Services, Inc., sets forth this list of witnesses along with a summary of their expected testimony. 1. Donna L. Sayers - Defendant. Ms. Sayers will testify as to her angoing care and concern for her children, Including Ryan; his close relationship with her and his half slblingsj and Ryan's relationship with his father after not seeing him for several years. 2. Ryan Seidel Minor child of Donna Sayers Ilnd Todd Seidel. Ryan will testify to his relationship with his mother and siblings, the effects of being abandoned by his father, and his preference to live with his mother, half-brother, and half-sister, 3. Heather Deardorff - Carlisle High School Guidance Counselor. Ms, Deardorff will testify as to Ryan's academic placement and his mother's attempts to correct the situation, ii I ~ I J '!B . roo s;! f~lilU !11!i . ~ ole ~t !l l:l I ;1 ~H . ..Ill ~ ~ Ii. ~i !I~~~ ~~ H ItA Ao~ . I a . I ~ ~ . ~ I!I i ~ ... ~ '.' - & -~ LAw c" lei'S '-~'~'#'n. ,j//. ./i;'~7/f/ J. (.;;;~;A~'.J . . t~MAR 301998 TODD E. SEIDEL. PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VI. : CIVIL ACTION. LAW : NO. 600S CIVIL 1997 DONNA LEE SAYERS, DEFENDANT : IN CUSTODY MEMORANDUM OF PETITIONER. TODD E. SEIDEL L Hutorv OrCu!lodv or ease: The parties in this case are Todd E, Seidel and Donna Lee Sayers who were separated on March I, 1984, and were divorced in Cumberland County at 2578 Civil 1984 in Augult of 1985. The panies are the natural parents of Ryan Daniel Seidel, born January 7,1983, age IS. The Court previously entered an Order for Custody in this case dated April 10., 1985, for shared custody of Ryan and his older brother. The parties later signed a stipulation providing that primary custody of Ryan would be with his mother, Donna Lee Sayers, This case has been brought by the father, Todd E, Seidel, who seeks a change of primary custody of Ryan Seidel to reside with him at the Dover Area School District. The reasons for the change are that Ryan has admitted to using drugs and is working substantially below his ability in school. He is currently failing nearly every subject at Carlisle High School. Mother is unable to properly motivate and supervise Ryan, Last year, Ryan's older brother, Jason Seidel, dropped out of school. Mr, Seidel seeks to provide a stable home for his son, Mother has separated from her second husband increasing the instability of her home life with Ryan. u. lwt.t: Whether the Petition of the father should be granted which would enable Ryan a new start in a new school district. - ' :. . ". ,.., . TODD E. SEIDEL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNS'iLVANIA : CI'VIL ACTION - LAW : : 2578 CIVIL 1984 : vs DONNA LEE SEIDEL, Defendant IN CUSTODY ORDER OF COURT AND NOW, April 10, 1985, upon the matter having been called for hearing, custody arrangements for Jason, age five, and Ryan, age two, shall be as follows: They shall be with their father, Todd E. Seidel, from 7:00 p.m. Sundays through 6:0.0. p.m. Thursdays; they shall be with their mother, Donna Lee Seidel, from 6:00 p.m. Thursdays through 7:00 p.m. Sundays. This order is contingent upon the mother residing with her par- ents and forthwith undertaking a psychiatric evaluation and pursuing any recommendations made as a result of that evaluation. Both parties shall have joint legal custody as that phrase is defined and used in the Custody and Visitation Act which both counsel have explained to the parties, which basically means you will parti- cipate jointly in decision making for your two children. This court will retain jurisdiction and entertain any further request for modification of this order, either by hearing or by con- sent agreement in the future. ~rcus A. McKnight, III, Esq. For the Plaintiff By the Court, Jeffrey Sunday, Esq. For the Defendant Edgar B. Bayley, J. :pbl TODD E. SEIDEL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVA.~IA CIVIL ACTION LAW vs. NO. 2578 CIVIL 1984 DONNA LEE SEIDEL, Defendant IN CUSTODY CUSTODY AND SUPPORT STIPULATION IT IS HEREBY STIPULATED that physical custody of Jason T.Seide1 and Ryan D. Seidel shall be with their mother, Donna Lee Seidel, with visitation for their father, Todd E. Seide1,evflry other weekend from Friday at 7:00 P. M. until Sunday at 7:00 p, M., commencing on Friday, July 19, 1985. IT IS FURTHER STIPULATED that Todd E. Seidel shall pay Donna Lee Seidel $125.0.0 biweekly as ordered by the Cumberland County Domestic Relations Office at 486 Civil 1984; DR # 11692. Dated: July 9, 1985 /'I) !: s= '1 D . i"""rvH~'l.....0 _ -:- . J .V::.tt / Donna L. Seidel Dated: ~;;~~ CERTIFICATE OF SERVICE I, Marcus A McKnight, 111, Esquire, hereby certifY that on thi s date a true and correct copy of the Memorandum was served by first class United States mail, postage paid in Carlisle, Pennaylvania 170.13, upon the foUowing Joan E, Carey, Esquire Legal Services, Inc 8 Irvine Row Carlisle, PA 170.13 Allomey for Defendant Donna Lee Say~rs ./'?v By: Marcu., McKnight. Ulre 60. Wes omfret Slreet Carlisle, Pennsylvania 170. 13 (717) 249-2353 Supreme COUIt 10. No, 25476 Allomey for Plaintiff, Todd E, Seidel T & HUGHES Date: March 30., 1998 3 r . ~~ ~! ~ II! g I !~~~ . il!~! . ~ ~ ~ ~I r i ~ Ii j.! gl .... ' ~ II !~ "'11I alS~ ~~ :5 ~ I t; ;:~ ~~ Ig ~ Ill! l!l i , l> ". . ..... .. , I ~ . .' MAR 3 0 1998 TODD E, SEIDEL, PLAL'ITlFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VI. : CIVIL ACTION. LAW : NO. 6005 CIVIL 1997 DONNA LEE SAYERS, DEFENDANT : IN CUSTODY MEMORANDUM OF PETITIONER. TODD E. SEIDEL L Histon' or Custody of Case: The parties in this case are Todd E Seidel and DOMa Lee Sayers who were separated on March I, 1984, and were divorced in Cumberland County at 2578 Civil 1984 in August of 1985. The parties are the natural parents of Ryan Daniel Seidel, born January 7, 1983, age 15. The Court previously entered an Order for Custody in this case dated April I 0, 1985, for shared custody of Ryan and his older brother. The parties later signed a slipulation providing that primary custody of Ryan would be with his mother, DOMa Lee Sayers, This case has been brought by Ihe father, Todd E, Seidel, who seeks a change of primary custody of Ryan Seidel to reside with him at the Dover Area School District. The reasons for the change are that Ryan has admitted to using drugs and is working substantially below his ability in school. He is currently failing nearly every subject at Carlisle High School. Mother is unable to properly motivate and supervise Ryan, Last year, Ryan's older brother, Jason Seidel, dropped out of school. Mr, Seidel seeks to provide a stable home for his son, Mother has separated from her second husband increasing the instability of her home life with Ryan, U. !ul.!f: Whether the Petition of the father should be granted which would enable Ryan a new start in a new school district. IlL List orWirn~ue!: 1. Todd E, Seidel will discuss his relationship with Ryan and his ability to provide a home for him in the Dover School District 2, Vicki Lynn Seidel, the stepmother of Ryan, will testify regarding her desire to help him stabilize his life in order to provide him the opportunity to complete his education. 3, Heather Deardorff, Guidance Counselor at Swartz Building at Carlisle High School, will testify regarding Ryan'3 difficulties in school as well as his attitude toward his parents and his future, 4, Phil Sayers, estranged husband of the mother, Donna Lee Sayers, will testifY regarding the lack of supervision that n:other is able to provide Ryan. 5, Mr and Mrs, George Seidel, the grandparents of Ryan Seidel, will describe their contact with Ryan and the relationship he has enjoyed with his father, IV. Conclusion: The father, Todd E. Seidel, seeks primary physical custody of his son in order to provide him a final opportunity to complete his high school education, IRWIN, Me ' Date: March 30.,1998 By: A, M ' igh ;sq. 60. W t Pomfret Street Carli e, PA 1710.3 (717) 249.2353 Supreme Court I,D, No, 25476 Attorney for Plaintiff, Todd E. Seidel 2 ~ ~ . . TODD E. SEIDEL, . IN THE COURT OF COMMON PLEAS OF . Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I CIVIL ACTION - LAW vs . . : 2578 CIVIL 1984 DONNA LEE SEIDEL, . . Defendant . IN CUSTODY . ORDER OF COURT AND NOW, April 10, 1985, upon the matter having been called for hearing, custody arrangements for Jason, age five, and Ryan, age two, shall be as follows: They shall be with their father, Todd E. Seidel, from 7:0.0 p.m. Sundays through 6:0.0 p.m. Thursdays; they shall be with their mother, Donna Lee Seidel, from 6:00 p.m. Thursdays through 7:00 p.m. Sundays. This order is contingent upon the mother residing with her par- ents and forthwith undertaking a psychiatric evaluation and pursuing any recommendations made as a result of that evaluation. Both parties shall have joint l~ga1 custody as that phrase is defined and used in the Custody and Visitation Act which both counsel have explained to the parties, which basically means you will parti- cipate jointly in decision making for your two children. This court will retain jurisdiction and entertuin any further request for modification of this order, either by hearing or by con- sent agreement in the future. ~rcus A. McKnight, III, Esq. For tne Pluintiff By the Court, Jeffrey Sunduy, Esq. For the Defendant Edgar B. Bayley, J. :pbl i i~! ~ .!~I . ~ I i I . ~ ~ ~ ~ ~ . I i~~ .~I - ! I~!~ ~I :1 ~. fj Ii. l:: . !l ~ i ;! ....fal J ,,'" ~tlEl s . "'~ ~ I .. .. ~eo . gl'l "'ia Ii; eo: I> ~ S !!2 'I r ~ ~ . . . - . . . .'." ,. /<"~/ /. . . .' , ~MAR 30 1998 ~ TODD E. SEIDEL, PLAINTIFF VI. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION. LAW : NO. 6005 CIVIL 1997 DONNA LEE SAYERS, DEFENDANT : IN CUSTODY MEMORANDUM OF PETITIONER. TODD E. SEIDEL I. HistorY ofCu!todv urease: The parties in this case are Todd E. Seidel and Donna Lee Sayers who were separated on March I. 1984, and were divorced in Cumberland County at 2578 Civil 1984 in August of 1985, The parties are the natural parents of Ryan Daniel Seidel, born January 7. 1983, age 15, The Court previously entered an Order for Custody in this case dated April 1 0, 1985, for shared custody of Ryan and his older brother. The parties later signed a stipulation providing that primary custody of Ryan would be with his mother, Donna Lee Sayers. This case has been brought by the father, Todd E. Seidel, who seeks a change of primary custody of Ryan Seidel to reside with him at the Dover Area School District. The reasons for the change are that Ryan has admitted to using drugs and is working substantially below his ability in school. He is currently failing nearly every subject at Carlisle High School. Mother is unable to properly motivate and supervise Ryan. Last year, Ryan's older brother. Jason Seidel, dropped out of school. Mr. Seidel seeks to provide a stable home for his son, Mother has separated from her second husband increasing the instability of her home life with Ryan, II. ~: Whether the Petition of the father should be granted which would enable Ryan a new start in a new school district. Ill. List orWitnttttt: 1. Todd E. Seidel will discuss his relationship with Ryan and his ability to provide a home for him in the Dover School District. 2. Vicki Lynn Seidel, the stepmother of Ryan, will testifY regarding her desire to help him stabilize his life in order 10 provide him the opportunity to complete his education, 3. Heather Deardorff. Guidance Counselor at Swartz Building at Carlisle High School, will testifY regarding Ryan's difficulties in school as well as his attitude toward his parents and his future. 4. Phil Sayers, estranged husband of the mother, Donna Lee Sayers, will testifY regarding the lack of supervision thaI mother is able to provide Ryan. 5, Mr. and Mrs. George Seidel, the grandparents t'f Ryan Seidel, will describe their contact wilh Ryan and the relationship he has enjoyed with his father. IV. Conclusion: The father, Todd E. Seidel, seeks primary physical custody of his son in order to provide him a final opportunity to complete his high school education. IRWIN, Me Date: March 30, 1998 By: A. M . igh sq. 60 W t PomtTet Street Carlis e, PA 17103 (717) 249-2353 Supreme Court I.D. No. 25476 Attorney for Plaintiff, Todd E. Seidel 2 TODD E. SEIDEL, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I CIVIL ACTION - LAW vs I . 2578 CIVIL 1984 . DONNA LEE SEIDEL, I Defendant . IN CUSTODY . ORDER OF COURT AND NOW, April 10, 1985, upon the matter having been called for hearing, custody arrangements for Jason, age five, and Ryan, age two, shall be as follows: They shall be with their father, Todd E. Seidel, from 7:00 p.m. Sundays through 6:00 p.m. Thursdays; they shall be with their mother, Donna Lee Seidel, from 6:00 p.m. Thursdays through 7:00 p.m. Sundays. This order is contingent upon the mother residing with her par- ents and forthwith undertaking a psychiatric evaluation and pursuing any recommendations made as a result of that evaluation. Both parties shall have joint legal custody as that phrase is defined and used in the Custody and Visitation Act which both counsel have explained to the parties, which basically means you will parti- cipate jointly in decision making for your two children. This court will retain jurisdiction and entertain any further request for modification of this order, either by hearing or by con- sent agreement in the future. ~rcus A. McKnight, III, Esq. For the Plaintiff By the Court, Jeffrey Sunday, Esq. For the Defendant Edgar B. Bayley, J. :pbl (;ERTIFICA TE OF SERVICE I, Marcus A, McKnight, III, Esquire, hereby certifY that on this date a true and correct copy of the Memorandum was served by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, upon the following: Joan E, Carey, Esquire Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 Attorney for Defendant Donna Lee Sayers /7 'V By: MareuI. MeKnight, ulrt 60 Wes omfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court 10. No. 25476 Attorney for Plaintiff, Todd E. Seidel T & HUGHES Date: March 30, 1998 3 :t:- v X -r 8 ~ :J ~ nl 'Q) . - ~ 11 ~ ~ ~ ~ u ;:.-- ~~ ~ I I ~~!m ~ I~!~~ .. ... i ~ I ! jll II ~ B 8 .. .1 ~ ' I i !~ ~~g B ... ~! ... &.1'" ! ~ ~ I ; ~ ~i II~/ ad: ... i i ; '" g .... . tl a UOI , I> 4 l 101 '" ~ i = i j . '" . . , J "'~ j~. lIer.... . i'.0,:.' . ,: i'!'L' , ., . ~...,." . /, /":.>_t,/--::/ \t. i;..,/.tr.J TODD E. SEIDEL, Petitioner : IN THE COURT OF COMMON PLEAS OF : CVMBJ:RLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION. LAW 97. L.lQ5' CIVIL TERM DONNA LEE SAYERS, Respondent IN CUSTODY ORDER Qf COURT AND NOW, this"; \ day of Or \ ('"bel . 1997, upon consideration of the attached petition, it is hereby directed that the parties and their respective counsel appear before \ U=\'\ '/..' 6,\fO}.- Esquire. the conciliator, at \k L.{n (C1\kHC'?n\ L)l'b'f\jl'd{~ \lIi!hr<l'C, on the ~ day of . IOc\\...XJ. ('t';;; 19~ at ~M. for a Pre-HCJUing Custody Conference. At such conference, an effort will b 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 permanent order. By the Court, By: '~lLQ~ X,~1jl'Q~ % Custody Conciliator (~ , . 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 WIIERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse I Courtbouse Square, 4th Floor Carlisle, Pennsylvania 17013 (717) 240-6200 /' 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 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 prior to any hearing or business before the court, You must attend the scheduled conference or hearing, 4, Petitior.er desirel primary physi.:al custody of the minor ~hiId and primary legal custody with periods of visitation to respondent as can be mutually arranged between the parties, s, The best interests and permanent. welfare of the minor child require that primary physical custody and primary legal custody be as provided above. WHEREFORE, the petitioner, Todd E. Seidel, respectfully reque~ts that he be awarded primary physical custody and primary legal custody of the minor child as provided herein, RespectfuUy submitted, 60 w.l.t PomCr tree! Carlbi~sylvania 17013 717-149-1353 Supreme Court 1.0. No. 15476 Oetober -lL,1997 ~ The foregoing Petition is based upon information which has been gathered by my counsel and myself in the preparation of this action, I have read the statements made in this Petition and they are true and correct to the best of my knowledge. information 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: October ~'8 .1997 .1 d ic!~ .\(l\l\l. ::,(O,cVo\ Plaintiff : IN TilE COURT OF CoMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA v, · \::X:1"I\Q Let:. '2P.'j er ~ Defendant : CIVIL ACTION tAW :' NO, ~().S"'CIVIL 19"i1 : CUSTODY VISIT A TION ORDER OF COURT And now, this dl' ~IY~ ,upon consideration of the attached complaint, it is hereb that the above parties and their respective counsel ap Esquire, the conciliator, at ~, Pennsylvania, on the ,)h day of ~Ac.(' ( ~", , 1998, at Ie'), co 0 . 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 permanent order, FOR THE COURT: By: ~\9\C\i)( <f1~'~I~ Custody Conciliator (l'J::):'\ 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 our WHERE YOU CAN GET LEGAL HELP, THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY A VENUE CARLISLE, PA 17013 (717) 249-3166 (-800-990-9108 .- ._~ '."-.-.- I' "I. :' C,( (':'> t"C"n 1''\ :~ ~' ,:. ";l i ."1' .."\ ,J .,' d' ... Ct_';.'~ "_,~_...~f"{ ~',:,N,... iL"".' \ .J'13 W oj. ~~ .lNJ/~ 4 ;W(/~ C) '/3~y '7t~~ vm.J/ <~ ~ (fz~ ~ ;2 "/3 -~ t'~ ~tY' -.. i-/, J&/~ #, . , "" ' .. --=- . __.;ll. '~ , ;:",) ',' , . ',I , (f II ; . , . ~ , '" I OJ ' (\ cr ;.J . ;i I ~ '.' I~~I I s , ~ I ~ ~ .;:: .~ ~E i .~( ! ~i~B ~a ~. $ I ~. 101'" ! "'..... !l I ; !! If t: g~ ..... l:: ! I .. I ~[ 101" .... El3 II ~ ~ i r eo: ~'" . ~ i 'I I> . " . .. . . . ' . " /,/ ., ,. . //.'. ')I"~/ ,\- , 1:,,/,,, , , J 199b 1/' , ..~.. . ., . TODD E. SEIDEL, PLAINTIFFIPETITlONER : IN THE COURT QIo' COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 97-6005 DONNA LEE SAYERS, DEFENDANTffiESONDENT CIVIL TERM IN CUSTODY PETITION FOR CONTEMPT AND NOW, this 10th day of February, 1998, comes the plaintift7petitioner. Todd E. Seidel. by his attorneys, Irwin, McKnight & Hughes, and makes the following Petition for a Finding of Contempt against Donna Lee Sayers, defendant/respondent: 1. The petitioner is Todd E, Seidel, an adult individual residing at 86 South Main Street, Dover, Pennsylvania 17315. 2. The respondent is DOMa Lee Sayers, an adult individual residing at 1871 Douglas Drive, Carlisle, Pennsylvania 17013, 3, The parties are the parents of Daniel Seidel, born January 7, 1983, 4, The parties appeared before the custody conciliator, Hubert X, Gilroy, and an Order of Court was entered on January 3, 1998, which awarded the petitioner temporary physical custody of his son, Ryan, A copy of said Order of Court is attached hereto as Exhibit. A. · 2 S, On January 23. 1998, the petitioner picked up his son at 6:30 p.m, as scheduled. His son inunediately informed the petitioner that his mother was going to call and get him on Saturday at 1:00 p,m, The father refused to end visitation, Thereafter, Ms, Sayers called Mr, Seidel or hi, son seven (7) times while he was at his father's home, Finally, the petitioner agreed to retUrn him early at 6:00 p.m. on Saturday, January 24, 1998. 6, The next period of temporary custody was scheduled for the petitioner at 6:30 p.m. on Friday, February 6, 1998, On the February 5, 1998, petitioner's son, Ryan, called his father and said he did not want to visit. The petitioner insisted on keeping the schedule. The respondent, Ms, Sayers, was not supportive and refused to tell her son to keep the custody schedule. On February 6, 1998, the petitioner went to the respondent's address and the respondent and Ryan Seidel were not at home. The petitioner waited until 7:00 p,m. and left t 0 return to his home, 7. The child, Ryan Seidel, has stated that he intends to refuse further \ isitation with his father, 8, The most recent grades for Ryan have been very poor at Carlisle High School, Ryan is at risk for completing his high school education, 3 EXHIBIT "A" $JAN 2 9 1998 TODD E. SEIDEL, Plaintiff v IIN THE COURT OF COMMON PLEAS OF ICUMBERLAND COUNTY, PENNSYLVANIA I ICIVIL ACTION - LAW I INOI 97-6005 CIVIL TERM IIN CUSTODY DONNA LEE SAYERS, Defendant COURT ORDER .Nl AND NOW, this 3 day of January, 1998, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Court Room No.2 of the Cumberland County Courthouse on the ~,..J. day of ().,"':"'L , 1998, at ll: l./S a .m. at which time testimony wi'fT be taken in the above case. At this hearing, the Father, Todd E Seidel, shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing Counsel a memorandum setting forth the history of custody in this case, the issues currently before the Court, a list of witnesses who will be called to testify for each party and a sununary of the anticipated testimony of each witness. This memorandum shall be filed at least ten days prior to the mentioned hearing date. 2. Pending further Order of this Court, the following temporary Custody Order is entered: A, The Mother, Donna Lee Sayers, and the Father, Todd E. Seidel, shall enjoy shared legal custody of the minor child, Ryan Daniel Seidel, born January 7, 1983. B. The Mother shall enjoy primary physical custody of the minor child. C. The Father shall enjoy temporary physical custody of the minor child on alternating weekends from Friday at 6:30 p.m. until Sunday at 4:00 p.m. and such other times as agreed upon by the parties. Father shall handle transportation for custody. v ,IN THE COURT OF COMMON PLEAS OF ,CUMBERLAND COUNTY, PENNSYLVANIA , ,CIVIL ACTION - LAW , ,NO' 97-6005 CIVIL TERM ,IN CUSTODY TODD E. SEIDEL, Plaintiff DONNA LEE SAYERS, Defendant , Prior Judgel Edgar B, Bayley CONCILIATION CONi'ERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE 1915.3-8(b), the undersigned Custody Conciliator following report' 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows, OF PROCEDURE submits the Ryan Daniel Seidel, born January 7, 1983. 2. A Conciliation Conference was held on January 20, 1998, with the following individuals in attendance, The Father, Todd E. Seidel, with his counsel Marcus A. McKnight, III, Esquire; and the Mother, Donna Lee Sayers, with her counsel, Joan E. Carey, Esquire. 3. This case involves a 15 year old boy who lives with his Mother. There is a prior Order from 1985 which gave the parties shared custody. However, the parties agree that the child has been living primarily with the Mother. There is a dispute as to how much time the Father has spent with the child. Father suggests that he has spent a fair amount of time with the child over the past few years. Mother suggests that the Father has had little contact with the son. 4. Father now has concerns relative to Mother's parenting abilities and the overall situation the son finds himself in at this time, Father notes that school reports indicate that the son is smoking marijuana and not doing very well in class. Father feels the son should come to live with him so that he can try to straighten things out. Father notes that the son's older brother has already dropped out of school and not completed high school and Father does not want to see Ryan take the same path. Mother suggests that she is taking action to ensure that Ryan is performing up to his abilities. Additionally, she notes that the Father has had no significant prior contact with the child. Mother further asserts that Ryan does not want to go to live with his Father. 5. The parties are at odds and a hearing is required. A hearing should take no more than one day. VERIFICATION The foregoing Petition is based upon information which has been gathered by my counsel and me in the preparation of this action, I have read the statements made in this document, and it is true and correct to the best of my knowledge, information and belief, I understand that false statemenls herein made are subject to the penalties of 18 Pa.C,g,A, Section 4904, relating to unswom falsification to authorities. 4~ Date: FIlBROARY 10. 1 CJCJ8 , CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certifY that on this date a true and correct copy of the Petition for Contempt was served by first class United States mail, postas' paid in Carlisle, Pennsylvania 17013, upon the following: Joan Carey, Esquire Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 IRWIN, McKNIGHT" HUGHES By: Date: February 10, 1998 CARLISLE AUA SCHOOL DISTRICT STUDENT ASSISTANCE PROGRAM PARENT REPORT PlaN ghKk the appropriate responsel in each Jedion of thit report and add eOlDl1lentl when needed for clarity, Space II provided II t!Jc end of eech sec:ticn fa' lAY additional gamment. or observationl. The Inlb.,natlon COIlIsIned in this report wUl be ulllld by Lhc Student Assilt&IIC' T...m in order to help your IOn or daullhter, Thank you for your cooperation in completing thi. Ibnn, Student'. name: r<.Y~ll SodL- I. Edu.atlonal Chan,a _ refiua 10 1IO 10 ..hoot _ eollSlanlly lea\fllar.e for ",boo! lIeaemllou oIlnlemrln IChoot -X clecUoJl\& school performaN:e ::r: cIroppInl out of orpnlzed ...tvIt1es (sports, cltltJs, eldnCllrriculu activilia) _ wanI. 10 '*'OIl out ollChool COMMENTS II. Social Ch..,u _ chanaes In 6ienda _ unknownlliendo _ .uoc:I.lion with Mown drul or alcohol userl _ chan8".ln MnaOlllS _ alWlyllOinl"nowhere .pm.'" _ 1OCTt11\'e lelep/lone a,"""nations _ callen ..110 refuse 10 idelltlfy tllemsel-tl _ hqueftl han. up lelepllone =111 _ COllItUIIytnI -'-- O\'ertllnolilil}' .nd oulbunll ...li- wilhdr......ll\'om family _ lle.lin. of $IlIIJI Items _ diuPllc."ance of clothl.. llId money _ oftDa 11011'0"'1\& money _ uncxplained influx of money COMMENTS: .:r hll..v~ udn~';';W -1/11\.+ he. +~d.:, rk,tfJ,..,n~c..l.d-+';Dl"'rh,<,f;1i'n"~. . EXHIBIT J PlA' I.,)TI IT' ~ '1,1 " L tL"{ 11/18/1S97 1~;23 II 7240&8S8 CARL ISLE APEA SOUL PI\I;t, il& III. 1'lycholQlj"al Chan,fS __._. pcnolkllil) ckiln,o, ..L dcpm$lnn ..-L- mood ""inll _ e-ccah e IalltothCnClI __Inil.lbilir:-. hOSlilily __ ICCfeth eness 0\ cr.ruction to enlleism = 'nltrue foar of ,oininl "tia'" or bec:onIi"l '01. _n mOllsh undeNeilhl _ ~"^"Ion t.\\:lIlII/'1f .n~' md """", Of pdl'8W X difllC\ll1'! ~",,\,llIlin, "'<l",! Of .I\.~ _ dee_oed inleTe" or ple:lNr. in :ill. Qf al_1Il1. llCllvllin nelIrly '\'If)' day _ ullpftdlclllbl. beh3l101 -----::IIAlI....ll1l1lloul ---' unello''''',""lo beho,ior(l) fOf individuars pcrlOnalilY _ reelinas t>f Wllnhlt........ ~I)' eve" dlIy _ dee....oed .billl)' to Ihlnk Of (on<e1'llm.e n~ly Mry de)' _ f~llhou&hll of death or IlIlkl oIloUlllllclcle COMMENTS. ',/,dc.s /I'l.I111[ Il'.~5, II\QrIJ1/!.tlLdrH\e./,( ludh ",Ir~'l-; IV, Phyliul Chan,u _ chan,e In oppetile 0' emul. utlna habitl _ loti 0' coordinlUQJI _ alum<! spee.h _ incoh'n!nce _ mlleua.1I or reeUIIJ "on edse" _ lnoUenlion 10 dre.. and pcnol1l1l ~&Iene _ O\.nll chona" in phYllcalspp:anncc _ li,nlliconl ".1&11I loa or wei,hlllln _ ch.nge In ,Ieep patterns (f>CClst,'Cl d.ep or iJllblUlY 10 sleep allllaltl) _ tired. lelhorlic, IlIdl ot ene.". _ _m), bl.nk '''Prewon _ 1011I ot _mory _ dilaled 0. .onmicled pupill needle IlIlllk, _ 'remblln, c1isal'll'arance of droa' from IPlldlclnc cabin.. =:z: JIOlltSlion of drugl. IIcollol, or dru& plU'lIphemalill _ ,ucmplllo disguise ado" of mariJWIlIlI 01 Ilcohol wllh cilaRltes, IncellH. room diodorlur, etc.... ....A- SUJpCClerI druB Of alcohol U5Cl COMMENTS' "'>tc Cl~'C\f (.L;',"lrnl-;, J.IIS /lIAh.~( I Ill", 11.\(1 IV II'. lW h,~, b(cdlrl fi'llI d /11~I'JUlll)1I In J.~al1't, It-un'!' . --) 1.-----' /" :;,/ / Dale 11/;;:; /i7 i Du~ Date Please relurn 10 11/1811997 14:23 717240ba~e CAF1..1 SLE WEll S''>ll.l.JL H...E. 84 CA PJ..! ~..E... A.. P..~.A A 'l'R OO!.... T\l s.TJU C1. PARENT PERMISSION FORM S1'TJDVN1' f\SSIS,'t i\NCf. PROGRt\M I live my pefmlulon for my lon/daulhter: , g'/lJJl Stidd NAME to pafticipale In the Sludent Allilt.nce PfOllf.m (SAP) of Carlisle School District IS il was elplalned lo m. by: /.f 1'-rJlI,n' r).'a.di)( {( I ~ h"IoA t:P I .110 live my permilllon for him/her to meet with a TBBNLINB AND/OR CUMBULAND PERRY D&A COUNSBLOR. I permlllhe Student Assistance Team to release relevanl information from his/her school recordl fOf the purpose of assessment. All Student Assistance Information will be maint.ined In the Itrictest confidence. __ -' /;:::7 - /~ /~/~;~ /' ~/ PARENT SIGNATURE . STUDENT SIGNATURB 11/18/1~,7 14:23 7172406838 CAFU SLE MEA SOo:x.. ~,,%. H J CARLISLE AREA SCHOOL DISTRICT STUDENT PERMISS ION FORM CONSENT FOR THE RELEASE OF CONFIDENTI AL INFORMA TION ') I I, L'IIlI' .r;'~ldl:' STUDENT'S NAME authorize TEENLI NE/CUMBI!RLAND PERRY D&A COUNSELOR TO DISCLOSE mE RfSUL T5 OF THE ASSESSMENT. RECOMMENDED ACTION PLAN & REFERRALS TO: 1. THE STUDENT ASSISTANCE TEAM 2, PARENT(S) OR GUARDIAN The purpose ot the disclosure authorized herein is to tacilitate fa mil}' involvement in au.umeat and referral. 1 understand that my records are protected under the federal regulations governing Confidentiality ot AlcohoJ and Drull Abuse Patient Records, 42 CFR Part 2, and cannot be disclosed without my written consent unless otherwise provided for in the regulations, 1 also understand that 1 may revoke this consent at any time ncept to the nteat that action has been taken in reliance on it, and that in any event this consent npires automatically one year from date of signature unless otherwise specified. Your contract will expire on: STUDENT SIGNATURB: . DATED: .,;ituuenr. Name, .:;" ,'(1,1 I, ~ t; ,.1 (PMI) ~a", 'FIf.1 1.1.1. Cpurs,jO, L 11,..j~I/S\ - /""0 5-4-3..a-:J.-Q E, S. U Marking Pd. Avg, (Circle One) ACADEMIC PROGRESS REPORT Carlisle High School 623 West Penn 51, Carlisle PA, 17013 West Building. 240-6863 Swar1z Building. 240-6842 Date C? /.P17 TUcher 111-', ~ r'{..I r/...R.... r Coun.elor f)P(( rd"... .t...! The purpose olthi. report i.IO in/arm you 01 your sludenl'. present slatus In Ihis sublod. Plu.e re"iew the comments checked below. hems not nOled were not e"aluated at this lime. Is 10 be commended lor his"'er work effort. X-Is doing unsatisfactory work Lis working below hisiher ability _Is showing impro"ement Responsibility Completion of make-up work Altention in class Completion of assignments Class altendance/punctuality Preparation for class Cooperation with classmates/teacher Comments: ~ 01'> ~ ""e" ~~:4"! <c,+c.ar..,~~ Follow-through 01 leacher directions Interest In learning Class participation Respect for rules and regulations Requests extra help when needed Use 01 school time Test/quiz/projects performance 'Jl. 'X. X' For assislance, plu.e contact either Ihetaacher or Ihe counselor, ~ Please .ign and return 10 leacher, o Need nol be returned, ParenVGuardian Sludent SignaturelDate -~ ---.------.-.-.----- -~----..---- ~ ~. . , . .-...... .- ~... 0.1. /2 I F , Mdrll,O"g Po STUDENT PROGRESS REPORT Carlisle Area School District 623 West Penn Slreet Swartz Building Phone 240-6842 Counselor Teacne, The 10110wlng evaluallon report IS beIng submItted b'f the ,nsltuctor for tne aDO..... s~blect 10 help be:h the studenl nd lt1e parer'll or guarCJlan 10 underSland lhe reasons for the presen1 !cholastu:; s~atus 01 Ine student. If you h..... Quul.Or'lS. pleau Cill Ihe schOOl 10 .urang. fOl an IPPOlnlment \Nllh the leacher Ru,onl far prlllnl p.rformence: _. FteQvent absence CnrQnlC lardlness ')l;. 1"'uIl1c,enl eldS! preOclral'Qn f'<.. Lo.No .nlereSl !e"fll In 5ludl'! II"Su'I'CIt!nl aolduce lOt Subject La"",, cas.c skil'S _. Snort allenllon span _ Refuses 10 do reQul,ed -NOll( ._ D.sClollne oloblem In class Ol,respec!lul at tllche, .nd pte'S _ FallS 10 make uP work mIssed due 10 absenc, ~ lnsulllclenl motIVatIon Limited Class parhc1cal1on :x. Homework .sSII,;InmenlS lat8, poor or Incomplete ~ Scores poorly on lest' Recommendationl: Sluden! st1ou!d be In class more o'len Slujenl st10u1d Pul tOtlh mote ,Ilorl Sl.;dent snou1cJ see. aOdlllon.11 help Sludenl "noulO meet wIlr. leacn!!r Sct'ledu1e parenlleacher ccnferenC:lf _ Sludent snould make up work mIned due 10 abs.nce SluOe"t snould Improve preparallon Sludent nelds 10 develop a more ,eflous approach 10 studln ..."."~,.-;"" "'-_ /Jc),.,-<r( W MOl tu~do~ ;t --~---t~ a nR> ~ > jf] C - & rJilt'U-(___~~----l/..)., --&-, L - 1 _ =eo- - - - . S,.danl's Nama ("""_ r , '" I hJ" ...-. ::: __ I., '.. ACADEMIC PROGflESS REPORT Carlisle High ScMol 623 West Penn SI, Carlisle PA, 17013 West Building. 240.6863 Swartz Building. 240-6842 Da!a I ~.. ? (Pr,n!) Last FuSl M.1. ;- ,4I1c..::t..I': Taachor Course -_. ",. n .J.- 5.4-3'2.1.0 e, S, U ~ Marking Pd. "yg. (CIrcle One) . >' C, '/ ! c' Counselor i' ,:.,. ,",'L'.]r' :--:;: _ ..,J Tho purpose of th,s reporl is to inlorm ycu of your studant's prasant status ,n Ih,s subJoct. Ploaso ro"iow the commants chacked below. hams nol notad we" nol ayaluatad a. th,s time. lito be lXlmmandad lor hiSi"ar work o"OrlS ,.:.., II doing unsatlSlaclory work Responsibility Completion 01 make-up work Attention in class Completion 01 assignments Class attendance/punctuality Preparation for class/QuI tZ:.>S Cooperation with class'mates/leacher Comments: r! II iJ t {~, 'ir.~~:" ,.: Follow-through of teacher directions Interest In learning Class participation I.. Respect lor rules and regulationa Requests extra help when needed ;( Use of school time TesVquizlprojects performance ,/ t'J.; A .,J-'}-,,': ;1"4'frnHt'.u..IS oJ y.. l- 'll Fet assj~ca, please contact either the teachlr or the counselor. (3"'PI.... sign and ralurn to I..char, o Naad not ba raturnad. ParanvGuardian Stud ani Signaturl/Oala .- ,,-.---- .-- - Sludant's Nama Oat. , , , ) ,':! "", ,; 7 , , ACADEMIC PROGRESS REPORT Carlisle High School 623 West Penn S1. Carlisle PA, 17013 West Building - 240.6863 Swartz 8ulldlng . 240-6842 ..... 1~1 p-..... (PMI) Last ~~st M.I. Course , _ 1.- -r _~J...""I-rr .', 5:4.3"-2iFQ ~. S, U -' . 'Marking Pd...,.,~ (Circla Ono) T..cher r~'1 . , 1'Y1.J.....J.... ,. Counsalor H I),., c.J~ {f Tha purpose ollhis r.porl is to inlorm you 01 your sludent's pr.sant slalus in this subjact, PI..sa ra"iaw the comments chacked balOw. hems nol noted wara not ayaluated at this lim.. _Is 10 be ccmm.ndad lor his"'ar work eHOrlS ----+-ls doing unsalisfactory work Responsibility Completion 01 make-up work Attention in class Completion of,assignmenls Class attendance/punctuality Preparation for class Cooperation with classmates/teacher Comments: iii ' I} 'y., J'-' ..')- 'f'... /t/~f ....,.. I - J,.,..-:J t(..:-'-tj. Ik f(lJ jj.,., ~ ~ :Jt ~",... ;,p;o~" ~ ~ ... ",+" ,;ii' ~.... -< Follow-through 01 teacher directions ( Interest In learning ...: Class participation ,,' Respect for rules and regulations Requests extra help when needed Use 01 school time TesVquizlprojects performance /'...'.1 .'r" ,-f:A_,,-J /}1V-,[.,'j r""-,, ~ I; /:,~ ,.. }"_" .J.i. './-1 '1IC', .J... . ~ ~l I. I . I n;1'(:'~ ;..If .J For assislance, please contact either the leacher or the counselor. o Plaasa SIgn and ralurn to laachar. 0' Need nol ba returned, ParenvGuardlan Sludant SignallJraiOale Slu~nrs ~m( . ~ ' :>t,(.U. ./~ (PIlOt) LaS! FilS! II. Cour.... :; c-1' 5.4-3-2&0 E, S, U Marking Pd, Avg. (Circle One) Dale 17ft/ r 7 ~'V/;~I ACADEMIC PROGRESS REPORT Carlisle High School 623 West Penn St. Carlisle PA, 17013 West Building. 240-6863 Swartz Building. 240-6842 Teacher counselor_O~~r-f..f- The purpose 01 this repon is to inform you of your student's preslnt slalus In Ihis sut'.ject Please review the comments checked below, bems not noled were not evaluated althis lime. ~ ~ be commended tor hishler work efforts ~s working below hishler ability ~IS doing unsatisl;lCtory work _Is showing improvement ,. 0<'- tp ~ . n:rt-//; ~~~ ~~.t.'~ ~~'1F/U if#~ #~Z Responsibility Follow-through of teacher directions Completion 01 make-up work Interest In learning Attention in class Class participation Completion of assignments Respect for rules and regulations Class attendance/punctuality Requests extra help when needed Preparation for class Use 01 school lime Cooperation with classmates/teacher TesVqulzlprojects performance Comments: _ f", ,1,'-' Iv h u...uI, t1 $ C. I c...uf (1 v-k "?~-If /AI .... t">7 ? () J.-f=,.' / _ ," ,... /1fl Jt~4 a'~/1"...a.v1 (I . J ", "51,1 f'-.....n~../ firer A'/fhf' f~f'r.< ,;, Cl,,,>. For aSgi tance, please contact eitner tho ~er or the coLnselor. Please sign and return to teacher. P.renllGuardian Need nol be returned, Studenl SignaturlllDate -.-' --- Carlisle Area School District 623 Wc;t Penn Street Carlisle. Penll5YllXlnia 17013-2298 TELEPHONE (717) 240-6800 Dr. GnoIA l.. FtJlll/07'. P/I,D,. S.".rintm,unl November 7. 1997 Mr. and Mrs, Philip Sayers 1871 Douglas Drive Carlisle, PA 17013 BE: RYAN SEIDEl (D.O,B.: 1/7/83) Dear Mr. and Mrs. Sayers. Ryan's absences from school on the following dates were unlawful due to the fact that required written excuses were not submitted explaining the reasons for th6se absences: SEPTEMBER 29. 1997 OCTOBER 6, 1997 OCTOBER 24, 1997 (MJNDAY) (IDNDAY) (FRIDAY) Ryan's unlawful absences are in violation of the Canpulsory Attendance Law (Section 1327) of the Commonwealth of Pennsylvania. The school law of Pennsylvania requires a school official to notify the parents of a student of this violation of the law in writing. It is important that you know that should Ryan accumulate any additional dsy(s) of unlawful absence you, as parents, are liable for a fine(s). If you have any questions regarding this letter or concerns pertaining to Ryan's attendance, please do not hesitate to call me (240-6822). You may also wish to contact Mr. Frank August, assistant principal of Carlisle High School Swartz Building (240-6837). Your anticipated cooperation in seeing that Ryan attends school each dsy and that he submits a required written excuse following any dsy of absence is appreciated. Sincerely, pupn PERSONNEL SERVICES Trl.1ln~ .A. Pf" W Margar~S. Spahr Home and School Visitor Fnclosures CARDIZEM.~[Q) (diltiazem HClh. to> i" ~"'l","" ",IOM I II (Ii.\!' !l.'. ,J:-.,c ~. t:"VI - ~.Q.1A- ~~ " 'f' ~ ' I .........0 ~.:{., c/ ;/~. 0" ~ im-ivt-eatuL !h-. - . \ ",-0 ." ,oil J' \", IV '- /{~ \' mMJ.Ja ~ ~'t w. ~RT7'N'-- -kctd::-~~ j, tN-t r:Il,~t~. tD Mr. August >!frs. Deardorff Mrs. Wertz \i/~{~7 cc: - II .. ... , ", ~ ., --. 3 ~ ~ c : ~ : . ~ . > r. I "" ~ ~ - . '" , -~ " ~ ~ - '- .. J . ~;. . - , ::: ~ ~ .' ' -- ; c. .... " c ... ; -. u : ::: > '" ... - '" ::. ... ~ .' I '" I ... - i .- .. :I J. ., ... J - i .;:, , II ~ ". . I (.. . .. i ~ ., l'l 0 a. i! z .. .. >- a . - '" '" 0 .... ~. , " J: ! I.l J: .AI ~ C J: ::J - Z .AI ~ :) - ,.. ~e 39\1d .. 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'" cl!:mx 3 III Z I .. en .. '" C ... .... .. '" III II: - ... ~ -' '" ... :: .. .- ~ ::: Q. C> '" lOJH8S '<:/~ :nS I "'C!It:l 16/17/1937 1l;12 '/172_06098 o:.i<ll3LE AREA SCHOOL PA<%: 81 CARLISLE HIGH SCHOOL--SWART~ SLOG, COUNSELING CENTER TOI~ rnoM,:ikdf~'11-4ALI~ DATE a ~7 The Counseling Center has need for a grade staeU8 report on; Studen~ :~ &idd.. SUbjact:~ . 0% ' We would Appreciate' . respone. Ae your earliest convenience, Thank you. PLEASB 1lB'r'VlOI BY. 1J.l(,I/Q7 987/l7/9~ Ap~roxi~at9 gradel .1 - Ir/B/TCHRGRAD.792 CARLISLE HIGH SCHOOL--SWARTZ BLDG. COUNSELING CENTER To~4~ ~ FROM:~~~ DATE: lollrl "7 ,'S1/- The Counseling Canter haa need for a grade status report on: Student: ~.n X-ic&--! Subject: _~ I -::n:- We would appreciate a response at your earlie.t convenience. Thank you. PLEASB llB'l'tJllH BY. (oft? /llJ7 ( . gs7/17/92 Rem4rks: ~ Up ~~. p ::+ jJ. "J, ~~~.;V Jtj cY~rY Approximate grade: I IF IB/'l'ClIRGRAD. 792 Remarks: If 'F"'- .iA trOI- ..J.;~ ..vU.l o.;t a.Lt, !-Ie ..i4 'I1Ilf ""1'/ d~ o..u.I ~ 1+ Iu ~ f"."/,"1' ~. JJ". iU4 ~rUA J.,~-'l Jt.j, ~)o c.b.~. IlL oJ. 0 ~~~~ 16 'hv ,vu..1~ ~ ~. ~.~l~ 7!l~ Teae e s signat re 16/17/1997 11:12 7172466898 CARLISLE AREA SOOJL PAEi: 82 CARLISLE HIGH SCHOOL--SWARTZ BLOG, COUNSELING CENTER TO: Approximate gradel Remulcsl ~.e ~ - o FROM I DATF.'--1!2/ '1C,7 The counseling Center has need :::::n::4~or~. Subject: lis fh.'N ' 1f We would appreciata a response at your earliest convenience. Thank you. for a PLlWlB llE'fURR BY, f{)/17/'17 I . IF/B/TCHRGRAD.792 gs7/17/92 ~~ c er . qnature - ~~ 0 .....~~ QlSa ~ t ~ . .. .. ~ '~1 II> .f~ · IIlR~" ~~il .. ~...s;~ ~ .. ... 1fD~~ ~ \ ~~~ i .~~~ III ., ~~ '95i~ t ~ ~ " ~ " It .. I ~ ~ ~ l/'llil ~Ij, " Ni ~i ... .., ~ I .. oR~ ~r<)~t Q; " :l) ij"'S VI 't. ~ t ~ lo. , S:l::: ~;,t~ N c ~... .... ~ ~ Do ~ ~ i" ~ ~~\1I~ ~~ iii~ "-~~ 1'1-\ ~..c: # ... r:i ~~~a ~! ! .~ I:: as I j, I E9 ::!)';1d "lXll-OS "8IJ<1 3lSI~ 86890~~LtL ~t:tt L661/Ll/91- r..1.'1]wt....u:. ~,""r.H. 'tr..'1~r.r-..,...~I'l'L V~. COUNSELING CENTER Approx~at. 9ra4.1~ RemarJuu C\.V1t7 --!J (Iv", f: 'I ke...t-t...( --/. ~~(_ t..'\CIf' -.111 tf1'; ~ It I ".-1(<. 'J Q,,, " 'If.""'....h. .f r.o( ..u'ft..{ I,I. ,uq- l- 1v",1L. " .,.vN. {'1('#'1(''''1 :d fv.J..- r~ /1. ~ I(~"'c H ,,~,-(';; (;\ TO, FROM; DATE I IOItc:::1Q7 r>Lf The Counseling Center has need grade status report anI Studentl~ .Jci~ SUbJect:,8~ -7tf')J1'.I" $ _ for a We would apprec~ate. a response at your earliest convenience, Thank you. PLMSE RnURN BY. to/I] /,17 /F/B/TCHRGRAD, 792 gs7/17/92 ~~~ Teache 's signature ........~_..., - CARLISLE HIGH SCHOCL--SWARTZ BLDG. COUNSELING CENTER 3 Approximate gradel ;::1;;::r~~~ DATE: /ollFi'/q 7 f1..) /~ The Counseling Center has need for a grade status report on: Studentl-'1.V#/) ~/'cld- SUbject:~i:L.L. We would appreciate a response at your earliest convenience. Thank you_ Remllrksl IYArJJ /.at ~6'S ARE ~t AftJAl;e. r /)IAuJJ /JI(C 10 SEE HIf ~'*tC h/ORG IN CLdSS ~ -- Jhs ~A<t< A um.E I4DIJ! 51U~V, PLEASI': RETURN BY: IDI/7/tJ7 /F/B/TCHRCRAD, 792 gs7/17/92 ~t/~ Teacher'. signature 5~enl:S Na~m , .11 -. -ic_ If. I U-4 (p,,,,~ (asl First { /;1,1. Course '7 - 5-4-3-2&'0 e, S, U Marking Pd, A"ll. (Circle One) Oate o/~? /r7 11~/ 2ifo- "63' Counselor Deur/V(f- ACADEMIC PROGRESS REPORT Carlisle High School 623 West Penn SI. Carlisle PA, 17013 West Building. 240-6863 Swartz Building. 240-6842 T sacher The purposeofthil report II to inform you 01 your sludent's presenlslalus in this SUbieel2PleaS review Ihecommenll checked below, hems not noled were not evaluated allhis tlma, _Ia 10 be commended lor hislher work eHorts Is working below hisiher abilily _II doing uns.tlslaclory work _II showing improvement ~.. . .-,.0",", ~0 ~. ,.-,.0<">/.1; ~~~ ~~~ va ~G1'~JJ' ~~ No ~ J!1 ~.... "," ~/. ,<-" c.;l' ..,/ Responsibility Follow-through of teacher directions Completion of make-up work Interest In learning Attention In class Class pal'ticipatlon Completion of assignments Respect for rules and regulations Class attendance/punctuality Requests extra help when needed Preparation lor class Use of school time Cooperation with classmates/teacher ' TesVqulzlprojects performance / Comments: )/u,;/? j.;, I~ {1V7<-l- -r...{, ()1'"'4f;u;t. ~",M"I-; 7 If/~' w~ll t ,r'/,..",I(,I,~/ (:.v. tIt) CI'''Nrrl~. ol-lc..-, ~~-h ciq'J; -1/.{"td 'f' VlII~ h ) Mill), ..f'v'~ Irl~~ f,oMh( rl1j tJ.;-w~~ -Iv II l:n v}u. Far assislance. please- ';~Ia~" eilher Ihe teach'e~lhe counselor, o Please sign and relurn 10 teacher, /J tI r.vtl,< u/ I. I~ P~re'1~~uardia!L / 11 ~ ~ludent Signalure/Dale ~ Need not be returned, '( ....., 4"'" n.z.. ff t:.Y , tJ Slud~nt's Name f) $.iJ el "'......,,, (PMI) Lasl Firsl M.1. Course r. ,I - ~711f,t: 1 5-4-3-2-0 e, S, U Marking Pd, A"ll' (Circle One) Dale Ie, II f:;1 , ACADEMIC PROGRESS REPORT Carlisle High School 623 West Penn St. Carlisle PA, 17013 West Building. 240-6863 Swartz Building. 240-6842 Teacher (1'1. (>'1 ".NI6./' counselorJ. f)(''X'dCftf' The purpose 01 this report is to inform you of your sludenl's presenl stalus in Ihis subieel, Please review Ihe commenls checked below, heml nol noled were not evalualed althis lime, Is to be commended lor hislher work eHorts -Is doing unsallslaclory work - ~ " o<">/.#'. i>'""". ~~~'-{f/ '<-+c;"'~~ Responsibility Completion of make-up work Attention In class Completion of assignments Class attendance/punctuality Preparation lor class Cooperation with classmates/teacher Comments: Follow-through of teacher directions Interest In learning Class participation Respect lor rules and regulations Requests extra help when needed Use of school time TesVqulzlprojects performance #{ For assislanco, leaS8 contact either tho teacher or the counselor. . .. I:) a . ~ f i !! ~ ri ~ f~~ fhip ~ f I i 1111 19 f ~iti!!,'!li: ~ O.~H~i~ ~.~h;..J ! -. Ilnls ~~ ~ !i!'I!II!,!ll:iii!!I!I!!!!!!I!!!!! illji!:!!;! 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J j i ~i H ,,,,It r.:t u "...J y",)( ~ Hld:J U H 00.. 0 'i.:L. ,.., r-.- ~ j o o 1 j "", o V\~:l b o " I oj j o " . " " .., 1 , ;;- , .. I;;;- " j 0,8 " " N r t.. f. .., t:- _... I::- -=- . J ~ i 'lI ~ i" ji !H~l~}1 ~~ ~ II i j~ .ii..3., Q".... lJ Q. Ii: ~ w oj f i 1.1 J J ~ C) j I'.) . 10 i . ."1 . J ~ ~ 'S...~)C1( ~ ~;. ~~"""",!-. ~ "1 ;;;- " o I~ \r 1......;-. " ~ILL - \r:~ " ~1\~~lJ.J-!'\lJ - ',"v]xH 1<J:::>'.1J1:- "J J "1 " - " cl.; ,"" I-, ",~ ~ - - )(V -" ~I .. i .. -'" , 1'1 \ 1 "I ~ nljJJH~ i iJIJI Ib- , - . o _- ~...;; " -1:,::)1sl N d 1: :: ':: J " .' J -. .J, ~!I 1 0< "~f t <1i ~ OC"</1'"IV;" ~~ "("'!' - '") ~ ....', ,.j." ~ ~ - , ,01:- . ~ <i . J ~ '~i . J I".i " ... ....11.1 ~ - ~ " . ~. i'~1) ~ ~.. I I J~ rf~;@ a ~ L ql~ .;: g Ul}; ~ H J " J" 1m l/j]1 November 28,1997 Dear Mrs, Deardorff, I am writing this as a follow up to our telephone conversations of November 24 and 25,1997. I had talked with both you and the school nurs~, Mrs. Horowitz after you had expressed your concern about the number of times (13) Ryan had visited the nurse for headaches. We had talked about his headaches previously, and I had hoped that after I bought him new glasses, the headaches would stop but that has not been the case. I asked you if you thought Ryan should be seen by a doctor and you said that, yes, in your opinion, he should. I assured you that I would take him to a doctor. I contacted Ryan's mother on Nov.25 and informed her about the situation. She stated that she would make an appointment for Friday, Nov.28, so that I could have him checked by the doctor. She then called me on Nov.26 and stated that Ryan would not be seeing me on Nov,28 and that there would be no doctor appointment. I asked to speak with Ryan at that time, but I was told that he was too upset. I was then told to come to Carlisle to talk with Ryan and his older brother. I agreed to meet them at my parents' home in New Cumberland. When they arrived, it was obvious that they were both high, Ryan's brother and I did all of the talking, Ryan just sat and stared. Needless to say, nothing was resolved. The following day, I had a phone call from Mr, Sayers, Ryan's mother's estranged husband. He stated that he had been accused by Ryan's mother of telling me to have Ryan drug tested by the doctor, Apparently, that is the reason Ryan is prohibited from see~ing treatment for his headaches. As you know, I am very concerned about Ryan. Now I am even more concerned, with medical treatment being withheld. Ryan has told me that he uses drugs to cope with stress. His mother has told me that his older brother foqnd marijuana in the room Ryan shares with his younger brother. I know that he has had unexcused absences from school before and after weekends that he was not with me. Perhaps this Is all connected. I don't know. I have tried to do everything that I can possibly do to help Ryan. Unfortunately, there is no cooperation from his mother. I don't know what else to do. I have completed the forms for the SAP to the best of my ability, I can only pray that Ryan will cooperate. If there is anything more that you need me to do, please do not hesitate to call me. You have my permission to do anything on your part, to the extent that you are able, to help my son, Thank you for all of your help. EXHIBIT I fLf't'i fr Sin~eJ; .1,/, ./" .' ,./' - ~/ ...--. /~.,,~- ';?f ' / J"'.. ,.ldat J '#, custody with the father shall continue pending the next hearing. (6) Neither party shall place any pressure on Ryan regarding this custody interim period, By J. Marcus A. McKnight, III, Esquire ( t Counsel for the Plaintiff \" . 0 ~.J , tl.... L{L1" ./ COPf~t,J..l61 . 1 ~ 1,.1:1 Joan carey, Esquire Counesl for the Defendant :lkt , .,.J! ' '. '::".') ~ ': ; \i',11*- ,..:- . ',S:1. \ , ; -; \.' ~ (\ _ .. j J ~)o .J " -} t.:_... -" &APR U IS 1998 TODD E. SEIDEL, Plaint1ff V IIN THB COURT 0' COHHON PLEAS OF ICUHBERLAND COUNTY, PENNSYLVANIA I ,CIVIL ACTION - LAIi I ,NO' 97-6005 CIVIL TERM rIN CUSTODY DONNA LEE SAYERS, Defendant AND NOli, /1 this f COURT ORDER day of April 1998, the Conclliator having conducted a Conference in this case afterwhich the Petitioner withdrew the Petition for Contempt without prejudice to refile the Petition at some point in the future raising the S4me issue., the Conciliator relinquishes jurisdiction. G lroy, E.qu~re Conciliator ./ '"111:- , ..j' ,\.: (;:.! c;.' . ,. ) "