HomeMy WebLinkAbout97-07188
~FEB 03 1995
THOMAS LEE WONDERS,
Plaintiff
V
,IN THE COURT OF COMMON PLEAS OF
,CUMBERLAND COUNTY, PENNSYLVANIA
,
rCIVIL ACTION - LAW
: ;1 "l'<
rNOr 97-1IW CIVIL TERM
r IN CUSTODY
KAREN RAE WONDERS,
Defendant
COURT ORDER
AND NOW, this r' day of February, 1998, upon
the attached Custody Conciliation Report, it
directed as followsr
1. The Mother, Karen Rae Wonders, and the Father, Thomas Lee
Wonders, shall enjoy shared legal custody of Tyler Thomas
Wonders, born July 22, 1991; and Morgan Paige Wonders, born
June 18, 1994.
consideration of
is ordered and
2. The Mother shall enjoy primary physical custody of the minor
children.
3. The Father shall enjoy periods of temporary physical custody
of the minor children as followsr
A. On alternating Saturdays from noon until 5:00 p.m.
B. On every Wednesday evening from 5:00 p.m. until 8rOO p.m.
C. At such other timos as agreed upon by the parties.
4. When Mother requires day care services for the minor children,
she shall contact the Father and provide the Father with the
first opportunity to give day care services to the children
rather than having the Mother's parents or another babysitter
provide those services.
5. Both parents shall cooperate in any counseling sessions
required for either minor child and both parents shall ensure
that the children attend the counseling sessions. and the
parents shall attend as required by the counselor.
6. This Order is entered pursuant to an agreement reached by the
parties at a Custody Conciliation Conference. In the event
either party desires to modify this Order, that party may
petition the Court to have the case again scheduled with the
Custody Conciliator. It is noted that Father's periods of
temporary custody do not at this time include overnight
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visitation. rhi8 provision is the. result ot 'ather'. current
living arrangements. It is anticipated that in the tuture
'~ther'8 living arrangements will change and that 'ather will
have the opportunity to have oVernight custody ot the minor
children.
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BY rHE COURT, . L
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CCI Thomas .I. Williams, Esquire
.Iohnna .I, Deily, Esquire - e
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THOMAS l.EE WONDERS,
Plaintiff
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO, 97.7188
KAREN RAE WONDERS,
Defendant
IN CUSTODY
PLAINTII1F'S PETITION TO MODIFY CUSTODY ORDER
AND NOW, comes Plllintit'lPetitioner, Thomas Lce Wonders, by and through his attorncys,
MARTSON, DEARDORFF, WILLIAMS & OTTO, IInd livers as follows:
I. Petitioner IiIcd II Custody Complllint pursullntto which a Conciliation Conference
was held on January 30, 1998.
2. At the Conciliation Confercnce, certain custody arrangcmctns were agrecd upon by
both parties and an Order was entered on February 5, 1998, a copy of which is attached hereto and
marked as Exhibit "An.
3, Following the said Order, the partics havc continucd to experience certain difficulties
regarding custody; consequently, Pctitioner is requesting that the Order be amended to add the
following:
a. The parties will only discuss the childrcn during transfers of custody. Other
marital matters would be discussed at other times ifneccssary.
b. The party having physical custody shall pcrmitte1ephone conversations with
thc children by the othcr party at all reasonablc times and free and uncensored
written communication.
c. Neither party shall make defamatory comments about the other in the
presence of the children, nor permit others to make such comments.
d, . Each party shall share with the other, without request, all significant
information, oral or writtcn, concerning the hcalth, education (both secular
and religious) or welfare of the children and shall consult and discuss all
major dccisions conccrning same.
Exhibit A
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tJ FEB 0 3 1998
THOMAS LEB WONDERS,
Plaintiff
V
:IN THB COURT OF COMMON PLEAS OF
:CUHBBRLAND COUNTY, PBNNSYLVANIA
:
:CIVIL ACTION - LAW
: 71 all
:NO: 97-788 CIVIL TERM
:IN CUSTODY
lCARBN RAE WONDERS,
Defendant
COlJRT ORDER
AND NOW, tllis Sa day of February, 1998, upon considez'ation of
the attached Custody Conciliation Report, it is ordered and
directed as follows:
1. The Mother, Karen Rae Wonders, and the Father, Thomas Lee
Wonders, shall enjoy shared legal custody of Tyler Thomas
Wonders, born July 22, 1991; and Morgan Paige Wonders, born
June 18, 1994.
2. The Mother shall enjoy primary physical custody of the minor
children.
3. The Father shall enjoy per.iods of temporary physical custody
of the minor children as follows:
A. On alternating Saturdays from noon until 5:00 p.m.
B. On every Wednesday evening from 5:00 p.m. until 8:00 p.m.
C. At such other times as agreed upon by the parties.
4. When Mother requires day care services for the minor children,
she shall contact the Father and provide the Father with the
first opportunity to give day care services to the children
rather than having tIle Mother's parents or another babysitter
provide those services.
5. Both parents shall cooperate in any counseling sessions
required for either minor child and both parents shall ensure
that the children attend the counseling sessions and the
parents shall attend as required by the counselor.
6. This Order is entered pursuant to an agreement reached by the
parties at a Custody Conciliation Confez'ence. In the event
ei ther party desires to modify this Order, that party may
petition the Court to have the case again scheduled with the
Custody Conciliator. It is noted that Father's periods of
temporary custody do not at this time .include overnight
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5, This Order is entcrcd pursuant to an agrecmcnt rcachcd by thc parties at a Custody
Conciliation Conference. [n thc evcnt cither party desircs to modify this Ordcr, that party may
pc tit ion thc Court to havc thc casc again schcdulcd with the Custody Conciliator. It in noted that
Father's periods oflcmporary custody do not at this time include vacation timc, It is anticlpatcd that
in the future, Father's living arrangemcnts will bc changcd and Fathcr will have thc opportunity to
have vacation timc with thc minor children.
6. The partics will only discuss the children during transfers of custody. Other marital
matters would be discussed at othcr timco ifneccssary.
7. Thc party having physical custody shall pcnnit tclephone convcrsations with thc
children by the other party at all reasonable timcs and free and unccnsorcd written communication;
provided, however, that telcphone calls will be Iimitcd to the hours of 5:00 p,m. to 8:QO p.m. during
school nights and will only be availablc when the childrcn arc, in fact, at homc. [n that regard,
Mother shall cnsurc that the childrcn arc availablc cvcry Monday night at 7:30 p.m, to reccive a
telephonc call from their Father.
8. Neithcr party shall makc defamatory commcnts about thc other in the prcsenclJ of the
childrcn, nor penn it others to make such commcnts.
9. Each party shall share with the other, upon request, all significant infonnation, oral
or written, conceming the health, education (both secular and rcligious) or welfare of the children
and shall consult and discuso all major decisions conccming samc.
10. Thc partics shall communicate with each othcr with rcgard to the children at all
reasonable times when requestcd -this includes answcring the phonc or promptly rctuming messages
left on an answering machi:lc.
1 [. Both parties shall avoid speaking obscenities and othcr disparaging remarks, and
other typcs of argumcnts with thc other party in thc prcscncc of the children,
12, Neither party shall question thc childrcn regarding details of where thcy were and
what they did while in the custody of thc other parcn!.
13. If either of the partics is accompanied by a friend during a changc of custody, the
fricnd should stay in thc vehicle and not cnter onto thc property of the othcr party.
. \\"\~Wl~ ~ c..\,j~'..\C\ ~
Plaintiff
: IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
: PENNSYLVANIA
v,
. \(0,\.,,,\ ~l\e. ,,~\\~c \ ')
Defendant
: CIVIL ACTION LAW
,
; NO. -1 \'K'.~ CIVIL 19'1,
: CUSTODY VISITATION
ORDER OF COURT
And now, this \:"ll g 1(1'1~, upon cOl1sidelation of the attached complaint, it is hereby directed
thatt~e above p~~es ~d thei,!:.respective cCJUl1scl appear before \'\-hor \- 'f..., h, \ r?,J... '
EsqUire, the conCIliator, at \\t>.'~ 1"1'\ \~r~~1U'I\, (, ~r ffic\ (0 (() ~~ ~ '
Pennsylvania, on the S day of tl" blU:lr....\ ' 1999, at B;. , .I P.M.,
for a Pre-hearing Custody Conference. At such conference, an effort will bc 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 ordcr, All children age five or older may be present at
the conference. Failure to appear at the confcrence may provide grounds for the entry of a
temporl\l'Y or penn anent order.
FOR THE COURT:
By: ~
Custody Conciliator
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 AVENUE
CARLISLE, PA 17013
(717) 249-3166
1-800-990-9108
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DEC~7,~
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THOMAS LIlE WONDERS,
, .
, Petitioner
v,
,
IN THE COURT OF COMMON PLEAS ,OF
, CUMBERLAND COUNTY, PENNSYL VANIA,
NO, 9~"7l88
KAREN RAE WONDERS,
Respondent
IN CUSTODY
RIII.F. TO SHOW CAIIS~
'AND NOW, this _ day ofDccembe;/1998, upon cOl1llideralion ofilie foregoing Petition, '
a Rule is hereby issued upon Respondent 10 show cause, if any there be, why th~ rellefprayed for
should not be ~ted,
Rule relumable __ days after service,
BY THE COURT,
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1,)14111
THOMAS LEE WONDERS,
Pctitioncr
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO,97-7188
KAREN RAE WONDERS,
Rcspondcnt
IN CUSTODY
PETITION..EOllCilllTEMI'T MUl.
TIlE.NEORCE CUSTODY ORDER
AND NOW, Pctitioncr, Thomas Lce Wonders, by and through his allomcys, MARTSON
DEARDORFF WILLIAMS & OTTO, and prays Your Honorablc COUlt to find Respondcnt, Karcn
Rae Wonders, in contempt ofthc Custody Ordcr dated Scplcmbcr 2, 1998, and, in support thereforc,
avcrs as follows:
I. Thc parlics arc thc parcnts of two minor children, the custody ofwhieh is govcmcd
by an Order of Your Honorablc Court datcd Scptcmher 2, 1998, a copy of which is attached hereto
and marked as Exhibit "A."
2. Paragraph 3 of said Ordcr providcs, iI/IeI' alia, that Pctitioncr will havc custody ofthc
children on Thanksgiving Day from 3:00 p.m, until 8:00 p,m,
3. On Wcdncsday, Novembcr 25, 1998, thc day before Thanksgiving, Respondent.
adviscd Pctitioncr that he should pick thc childrcnup at her parcnts' house at 3:00 p,m. the ncxt day,
Thanksgiving, November 26, 1998.
4. In accordancc with such instructions, Petitioner went to Respondcnt's pat'cnts' house,
located at 708 Doubling Gap Road, Ncwvillc, PA, to pick up his children, At that timc, the
following occulTed:
a, Respondent's aunt, namc unknown, initially came out to spcak to Petitioncr
in an altcmptto convince Petitioner not to takc his childrcn;
b. During this time, Respondcnt was on thc porch scrcaming rcmarks at
Petitioncr and screaming at her aunt not to speak to Pctitioncr;
c. Pctitioncr persistcd in tclling the aunt that hc wantcd to havc his childrcn for
Thanksgiving;
d. Rcspondcnts' parents camc out onto the porch and yellcd at PClltioncr that he
had no right to take his childrcn, that he shouldn't takc them and that: "You
lell your childrcn, You didn't want thc childrcn," and similar words,
Rcspondcnt's lIunt told Respondentllnd her lumBy scverultimcs to be quiet
und go buck into the house, but they pcrsisted,
c. Thc childrcn were prcsent with Rcspondcnt und hcr purents while the above
verbul exchunges occurrcd;
f. Petitioncr thcreaftcr lell to avoid a confrontation,
5. Petitioncr cull cd the Pcnnsylvunia Statc Policc und the Statc Constable, telling thcm
of the Court Order; howcver, he wus udviscd it was a civil maltcr und Pctitioner nccded to take it up
with the Judge.
6. Paragrnph 8 of the Custody Order, Exhibit "A," providcs that: "Ncithcr party shull
makc defumatory comments about the othcr in thc prcscncc of the childrcn, nor pcrmit others to
make such comments."
7. Respondcnt is in bllltunt violation ofthc Court's Custody Order.
8. The cvcnts describcd herein ure no\ isolatcd incidents und rcfiect a continuing paltcm
on thc part of Rcspondent of interfcring with Pctitioncr's rclationship with his children,
WHEREFORE, Petitioncr prays Your Honorable Court to do thc following:
a, Hold Respondcnt in contempt of the Custody Ordcr;
b, Impose a fine on Respondent to discourage furthcr conduct in the future;
c. Reimburse Petitioner for his expenses in having to enforce the Custody
Order;
d, Amend the Custody Order to providc that it should be cnforccd by law
ellforcemcnt agencies where thcrc is an obvious violation;
c. Such other and further rclief as the Court deems just and appropriate under
the circumstanccs.
Date: Deccmbcr 3, 1998
MARTSON DEARDORFF WILLIAMS & OTTO
B\.:!.~.J. ,,~-
Ten East High Strcet
Carlisle, P A 17013-3093
(717) 243-3341
Attorneys for Pctitioncr Thomas Lcc Wondcrs
p,
Exhibit A,
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THOMAS Ll!B WONDERS,
Plaintiff
IN THE COURT Of COMMON PLEAS OP
CUMBERLANI) COUNTY, PENNSYLVANIA
NO. 97.7188
v.
KAREN RAE WONDERS,
Defendant
IN CUSTODY
STI.PULA~~N OF THE PARTqr..~
I '. It is ba'cby stipulated by and bctwCCD tho parties oftbilllCliOll,!bat tho Custody prderoftbil
CGuIt dated Pebnwy 5, 1998 sbaJl besuperscdCd by the attached G\lltody Order.
C"
"'f~'" W~~ tr~ { ~
Tbomu fWiliillJll, Esquinl Thomas L. Woodell
Attorney rotPlaintiff Plaintiff
J
~~~~
. . Karen R. Wonders
Defendant
8
~
S. This Order Is cntmd pursuant to an agreement reached by the parties at a Custody
Conciliation Conference:. In the event either party desires to modify this Order, that party may
petition dIe Court to have the cue again scheduled with the Custody Conciliator. It is noted that
Father's periods oft.emporary custody do not at this time include vacation time. It is anticipated that
in the future, Father's living arrangements will be ~hanged and Father will have the opportunity to
have vacation time with the minor children.
6. The parties wiU only discuss the children during transfers of custody. Other marital
matters would be discussed at other times ifnecessnry.
7. The party having physical custody shllll permit telephone conversations with the
children by the other party at 1lI1 reasonable times and Iitc and uncensored written communication;
provided, however, that telephone calls will be limited to the ~ours of5:oo p.m. to 8:00 p.m. during
school nights and will only be available when the children arc, in flIct. at home. In that n:gard,
Mother shall ensure that the children arc available every Monday night at 7:30 p.m. to receive a
telephone call from their Father.
8. Neither party shllll make defamatory comments aboulthe other in the prcsenco oflhc
children, nor pennit others to make such comments.
9. Each party shall share with the other, upon requesl,llIl significant information, oral
or written, concerning the health, education (both secular and religious) or welfare of the children
and shall consult and discuss all majl'r decisions concerning same.
10. The parties shall communicate with each other with n:gard to the children at all
reasonable times when requested. this includes lIl1SWering the phone or promptly returning messages
left on an lIl1SWering machine.
II. Both parties shall avoid speaking obsccnitie~ and other disparaging remarks, and
other types of arguments with the other party in the presence of the children.
12. Neither party shall question the children regarding details ofwherc they were and
what they did while in the custody of the other parent.
13. If either of the parties is accompanied by a friend during a change of custody, thll
friend should stay in the vehicle and not enter onto the property of the other party.
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,."'.rd- 02l19IW II :401 AM
11.01
v.
IN THE C.oURT .oF C.oMM.oN PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO,97.7l88
TH.oMAS LBE WONDERS,
Pctitloncr
KAREN RAE W.oNDERS,
Rcspondcnt
IN CUSTODY
MOTI()N TO WITHDRAW
. AND N.oW, comcs MARTSON DEARDORFF WILLIAMS & .oTT.o, uttorneys for
Plaintiff, Thomas Lce Wonders, and seeks Court upprovulto wilhdmw us counscl for the following
reasons:
I. Mr. Wonders and the undersigned counsel have dcvclopcd irrcconciluble differcnces
as to the appropriate strategr for the litigation of this custody muttcr such lhut thc undersigned
counsel finds it difficult to curry out the instructions of Mr, Wdndcrs inthul rcgard.
2. Mr. Wonders consents to thc withdraw oflhc undcrsigncd us his counsel us cvidenccd
by Exhibit A,
Respectfully submitted, .
,
MARTSON DEARDORFF WILLIAMS & OTTO
By -rL-~f~'^'.i1 duo ~
Thomus J, Will" IS, Esquire
Ten Eust High trcet. .
Carlisle, PA 1701.3.3093
(717) 243-3341
Attorneys for Pluintiff
Date: February 19, 1999
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CF.RTIFICATE OF SF.RVICE
I, Triola D. Eckenroud, an authorizcd ugcnt for Murtsoll, Dourdorfl; WiIIlums & Olto, ,hcl'eby
certifY thuta copy of the foregoing Motlc,h to Wlthdruw Will; servcd this dote by depositing sUllie ill
the Post Office at Carlisle, PA, first closs moil, postuge prepoid, addressed us follows:
Johnna J, Deily, Esquire
SAlOIS, SHUFF & MAS LAND
26 West High Street
P,O. Box 560
Carlisle, P A 17013
MARTSON, DEARDORFF, WILLIAMS & OTTO
Dated: Febnuiry 19,1999
... mof'\"U.~ lee. ~~ ~ ':,.
Plaintiff
: IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
: PENNSYLVANIA
: CIVIL ACTION LAW
v,
... \<.ClR.\'\ ~o.c. ~e..\'.:)
Defendant
,
,
: NO:l \ '6"& CIVIL.19 q I
: CUSTODY VISITATION
ORDER OF COURT
And now, this "A \ ~\'lj, upon consideration of the attached complaint, it is hereby directed
that t?C above pa~~es and their res~tive C~I appear befor~~ ~ ~~~~~-'
EsqUIre, the conclhator, at -\\-..e U; \"\, C e~\(f'le) ("c\ f::' ,
Pennsylvania, on the \", dayof ~?\c.lY'\Irr(',19 9,at3','''() "P,M.,
for a Pre-hearing Custody Conference, At such conference, an effort will be made to resolve the
issues in dispute; or ifthis 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: _~\ k 'Y. rb~~l~
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 WHERE YOU CAN GET LEGAL HELP.
THE CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
1-800-990-9108
,
AUG - 3 199~
IN THE COURT OF COMMON PLEAS OF.
CUMBERLAND COUNTY, PENNSYLVANIA
THOMAS LEE WONDERS,
Pctitioncr
Civil Action Luw - In Custody
v.
No, 97-7188
KAREN RAE WONDERS,
Respondent
NOTICE AND ORDER TO AI'PEAR
Legul procccdings huvc bccn brought uguinst you ullcging you have willfully disobcyed an
Order of Court for Custody,
If you wish to defend against the claim sct forth in the following pages, you muy but are not
rcquired to file in writing with thc court your dcfenses or objections.
Whether or not you file in writing with the court your defenses or objcctions, you must
appeur in person in court on at ,m.. in
Courtroom of the Cumberland COllnty Courthouse, Courthouse Square, Carlisle, PA.
IF YOU DO NOT APPEAR IN PERSON, THE COURT MA Y ISSUE A WARRANT FOR
YOUR ARREST.
If the Court finds that you have willfully fuilcd to comply with its Ordcr for Custody, you
muy be found to be in contcmpt of court and committcd to jail, fined or both.
YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT
HA VE A LA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET L.EGAL HELP.
Cumberland Coullty Bl,lr Association
LawYer Referral Service
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
Mlchacl J, Hann. Esquire
Attorney I,D. No, 57976
19 Brookwood A venue, Suite 106
Carlisle, P A 17013
(717) 249-5373
. Attorney for Petitioner
BY THE COURT:
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ATTORNIV ~ Cot,JN5!LlOR ^T L",w
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S. Respondent hus willfully tidied 10 ubide by the Custody Order llf September 2, 1998
uml the Order of Court of December 23, 1998. thercinuller collectively culled "Custody Orders")
in thut she hus not allowed Petitioner to huvc telllpnrury physicul custody of the children us
rcquired In Purugruphs 3A. 3B. 3C. 3D. und 3E,
6. Respondent hus willfully fuiled to ubide by the Order in IImt she hus refuscd to
cooperute ill counseling sessions or insure thut the children ullend counseling sessions us required
in Puragraph 4 of the Custody Orders,
7. Respondent hus willfully lullcd to ubide by the Order in thut she hlL~ not ullowed
telephone conversutions between the Petitioner und the children us requircd in Purugraph 7 of thc
Custody Orders.
8. Respondent hus willfully lullcd to ubide by the Order in thut she hus and continues to
makc defumutory comments ubout the Pctitioncr in the presence of the children und permits her
family to do so us well, of whieh is ull in violution of Purugraph 8 of the Custody Orders,
9. Respondent hus willfully fuiled to ubide by the Order in thut shc hus not shared any
information regarding the chlldrcn's heullh, cducation or welfare. cven though specllicully
requestcd to do so by Petitioncr and such uction violutes Paragruph 9 of thc Custody Orders.
10. Respondcnt has willfully luilcd to ubide by the Order in that shc has not avoidcd
speaking obscenities und other disparuging rcmarks and other types of urguments in the presence
of the children, and such action viQlates Paragraph II of the Custody Orders..
I]. Respondcnt has willfully luiled to abide by the Ordcr in that shc has continuully
questioned the children regarding details of where thcy were and whut they did while in the
custody of Pctitioner, and such action is in violation of Puragruph 12 of the Custody Orders.
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THOMAS LEE WONDERS,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-7188
KAREN RAE WONDERS,
Defendant
IN CUSTODY
CUSTODY ORDF.R
Upon consideration of the attached Stipulation, it is hmby Ordered and Directed as follows:
J. The Mother, Karen Rae Wonders, and the Father, Thomas Lee Wonders, shall ctijoy
shared legal custody ofTylerTholl1/1S Wonders, born July 22,1991 and Morgan Paige Wonders,
bomJlI!le 18,1994.
2. The Mother shall enjoy primary physical custody of the minor children.
3. The Father shall ctijoy periods of temporary physical cu.~t(ldy of the minor children
as follows:
A. On alternating weekends from 5:00 p,m. on Friday until 4:30 p.m. on
SalIuday; provided, however, that Father occupies the residence that he owns
or leases and that Father must be personally with the children while in his
physical custody and he shall not leave them in the care of others. This shall
not includo the premises located at 135 Springfield Road;
B. On every Wednesday evening from 5:00 p,in. until 8:00 p.m.;
C. When Father does not have to work. be slulll bave the children every other
FridllY from 6:45 a.m. until 5:00 p.m: wben the children arc offschool and
Mother has to work.
D. Every other Saturday from 9:00 a.m. until 4:30 p.rn;
E. On the following Holidays from 3:00 p.m. until 8:00 p.m.:
I. Easter
2. Thanksgiving
3. Christmas
F. At such oUler times as agreed upon by the parties.
4. Both parents shall cooperate in any counseling sessions required for either minor
child and both parents shall ensure that the children attend the counseling sessions and the parents
shall attend aa required by the cOllnSolor.
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Exhibit B
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"U/U/.. 14111 FAX 711-ZU+1UO
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THOMAS LEE WONDERS,
P!alIItl1f
: IN TIlE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v
.
.
: CIVIL ACIlON . LAW
KAREN RAE WOND~RS,
Dcfendlnl
.
: NO. 97 .1188 CML
: IN CUSTODY
COURT ORDER
AND NOW, Ibis 2301 day of December, 1998, upon consldenllon of the I.llICbed CuslOdy
Conciliation Report, Ills orclcrcd and directed 1ha1\he exI...I"1 CUS10cly Order dared gep(em~ 2.
1998 shall rmWn In etrect with lh.e IddItlon of1hc follow/nS puagaph:
16. For eK~se of ellSlOdy, the Moth<< shall deliver lh.e dlildralto the FIIbcr IIlhc
beginning of Father's periods of eUSlody and Falhcr .hall deliver tbe ehildml blCk
to \he Molhcr at the end of his period of c:ustody. 1'be approprlalc lawenfol'\:Clncnl
officials shall have authority to enforce the terms oflhls c:USlOdy order IS aulborized
bylaw.
BY TIlE COURT,
.f.1 ~_..:.. a.. )4..~A~ J.
c:o: Thomas WUllIII\S, Esquire
Joluma Deily, Esquire
TllUE COpy FROM tU!COIlOhand
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and IhJ sPool of Ic!d Court II CarlisI.. PI. Gf.
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3, The party having physicul custody shall pennit telephone conversations with the
children by the other party ut all reasonablc times wid free and uncensored written
communication; provided, howcver, that telephonc calls will be limited to the hours
of 5:00 p.m. to 8:00 p.m, during school nights and will only be available when the
children are, in fnct, ut homc. In that regnrd, Mothcr shall ensure that the children
are available every Mondny night at 7:00 p,m. to rcccive a telephone call from their
Father,
4. In the evcnt a further ordcr of court is not entered prior to the Thanksgiving and
Christmas holiday for 1999, Father shall have custody of the children on
Thanksgiving Day from 3:00 p'm' until 8:00 p.m. and for the Christmas holiday
from Christmas Day at 12:00 p,m. through Dccembcr 26th at 12:00 p.m.
5. At the hcaring in this casc, both parties may advwlce a position for a custody
schcdule dill"crent than the tcmporary schedule outlined above and dillerent than the
schcdulc under the prior order,
6. The appropriate law enforccmcnt ollicials shull havc authority to cnforce thc tenns
of this custody order as authorized by law. This provision authorizcs a police ollicer
to deliver thc childrcn from the cllstody of one parent to another parcnt to ensurc that
the tenns of the order are being followed,
7. It is notcd that the Mother cnjoys primary physicul custody of thc minor children.
With the Mother enjoying primury physicul custody, Mothcr ussunles the obligation
of ensuring thut the childrcn follow hcr dircctives and comply with this court's
order. It shall be the rcsponsibility of the Mother to ensure thut the childrcn are
delivered to thc Father for purposes of custody as set forth ubovc, and failure of the
Mother to fidfill thc tcnns of this custody order bctwcen thc dutc of this ordcr and
the date of the hearing scheduled ubove muy subjcct the Mother to uppropriate
contempt provisions as ullowcd by law.
8. In the event thc Fathcr retains a professional to do a custody evaluation or any
counseling, MOlhcr shall cooperate with thc Father and shall attend any scssions
required by the counsclor and also dcliver the childrcn to the counselor for any
evaluation or counseling scssions scheduled, Futhcr is rcquired to puy the costs of
said cvaluation, less any applicablc insurance. In the event the Mother desircs a
similar counscling session or custody cvaluation und incurs thc cxpcnse for the
scheduling of the same, Father shall cooperate with any evaluator sclccted by
Mothcr and shall attcnd any required counscling or evaluation sessions.
9. Father shall providc all transportation for pick up and rcturn ofthc minor children.
10. Both parcnl~ shall ensure that no smoking occurs in a vehicle or a house while
occupied by either of the children.
THOMAS LEE WONDERS,
Petitioner.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
97-7188 CIVIL TERM
KAREN RAE WONDERS,
Respondent
IN CUSTODY'
IN RE: CUSTODY AGREEMENT
ORDER OF COURT
AND NOW, this 30th day of December, 1999, this
matter having been called for hearing, on agreement of the
parties, it is ordered and directed as follows:
A) The parties shall have shared legal custody
of the children. Mother shall provide, at least monthly,
to father copies of all work sent home from school. Father
shall return same to mother within ten days.
B) Mother shall have primary physical custody of
the children subject to father's periods of temporary
physical custody.
C) Father shall enjoy periods of temporary
physical custody of the children on alternating weekends,
from ,Friday at 5:30 p.m. until Sunday at 5:00 p.m. Mother
shall provide father with a list of the days that Cherub
choir is to\take place and youth club. On those Sundays
that father is to enjoy periods of temporary physical
custody that conflict with those times, father is to
deliver the children to the church by 7:45 a.m. In
instances where that happens, father shall enjoy periods of
temporary physical custody the following Sunday, trom after
church until 5:00 p,m,
D) Father shall enjoy periods of temporary
physical custody of the children on Wednesdays from 5:30
p.m. until 8:00 p.m.
E) Mother shall insure that both children are
available to speak with the father every Monday night at
7:00 p.m" and the telephone conversation.to be initiated
by father. Both parties shall permit telephone
conversations with the children by the other party at all
.reasonable times.
F) Father shall have temporary physical custody
of the children every Thanksgivingday from 3:00 p.m. until
8:00 p.m.
G) In odd years, father shall have temporary
physical custody of the children every Christmas Day from
December 25th at 12:00 p.m. through December 26th at 12:00
p.m. In even years, father shall have temporary physical
custody of the children every Christmas Eve from December
24th at 12:00 p.m. through December 25th at 12:00 p.m.
H) Father shall enjoy temporary physical custody
of the children every Easter from 3:00 p.m. until 8:00 p.m.
I) Father shall enjoy temporary physical custody
of the children every Father's Day from 9:00 a,m. until
8100 p.m. Mother shall, enjoy temporary physical of the
children every Mother's Day from 9:00 a,m. until 8:00 p.m.
J) In odd years, father shall have temporary
physical custody of the children every 4th of July from
9:00 a,m, until July 5th at noon. On even years, mother
shall have temporary physical custody of the children every
July 4th from 9:00 a.m. until July 5th at noon.
K) In odd years, mother shall have temporary
physical custody of the children every Memorial Day and
Labor Day from 9:00 a.m, until 8:00 p.m. In even years,
father shall have temporary physical custody of the
children every Memorial Day and Labor Day from 9:00 a,m,
until 8:00 p.m.
L) Each party shall have two non-consecutive
weeks of vacati?n with the children during the children's
summer vacations. Each party shall provide the'other with
at least thirty days notice of their intention to exercise
these time periods. Neither party can exercise these weeks
during Memorial Day, 4th of July or Labor Day, In the case.
of a conflict with the weeks selected, the party that
advises the other first regarding a particular week shall
be entitled to have that week.
M) For all periods of father's temporary
physical custody father shall pick the children up at
mother's residence. At the end of father's periods of
temporary physical custody mother shall pick the children
up at father's residence, In either instance, neither
party picking the children up shall leave the vehicle, and
neither party or other persons in the residence shall leave
the residence when the children are being picked up, In
the event of snow, if father's driveway is not plowed, the
pickup point shall be the bottom of the lane,
N) During their periods of custody of the
children, both parents shall insure that no smoking occurs
in a vehicle or a house occupied by either of the children,
0) Neither party shall question the children
regarding details of their visitation with the other
parent,
agreement.
R) The parties agree that Tyler shall continue
with counseling with Elaine Reisinger at Mazzitti &
Sullivan. The parties also agree that they shall follow
any r.ecommendations of the counselor to continue with
telephone conversations. To plead further, the
children get on the telephone every Monday night, and
on occasion, they do not want to speak with the
Petitioner, through no fault of Respondent.
8. Denied; It is specifically denied that Respondent
makes defamatory comments ab0ut Petitioner, and to
plead further, it is the Petitioner through him and
his new wife who continually defame Respondent. The
defamatory comments are often repeated by the
children to the Respondent.
9. Denied; It is specif ically denied that Respondent
has not shared any infor~nlation regarding the
children's health, education or welfare. To plead
further, it is the petitioner that refuses to speak
to the Respondent, and to the best knowledge of the
Respondent, the Petitioner has never called the
doctor, the school or a therapist unless he has been
forced to.
SAlOIS.
SHUFF &
MASLAND
ATrr....YltATtlAW
16W,IIIahSI'HI
Cot,U,I.. PA
10. Denied; It is specifically denied that Respondent
has been speaking obscenities or other disparaging
remarks in the premises of the children. To plead
further, the children have learned and repeated
obscenities and other disparaging remarks directly to
the Respondent when they come home from visits with
the Petitioner.
11. Denied; It is specifically denied that Respondent
has continually questioned the children regarding
details of what they have done. To plead further, at
the time of the Petition, neither child was being
taken on a regular basis, and the children informed
the Respondent that it is the petitioner that they
are continually questioned the entire time they are
in the presence of the Petitioner and his new wife,
12. Denied; It is specifically denied that Respondent's
friend smokes in front of the children, To plead
further, the new wife of the Petitioner smokes in
front of the children all the time, and at one
specific occasion, the one minor child, Tyler, stole
cigarettes of the Petitioner's wife so that she would
not smoke in the car,
13, Denied; It is specifically denied that the Respondent
displays excessive affection toward non-family
members. To plead further, this was an allegation
that Respondent has always accused Petitioner of an~
the children have reported that they have seen the
Petitioner and his wife having sexual intercourse on
at least two different occasions directly in front of
them.
SAlOIS.
SHUFF &
MASLAND
ATfllI!&YIoAt!lo1l!I.
16 w, Utah 11'"1
CoI,U,I.. PA
14. Denied; It is specifically denied that Respondent
refused to deliver the children to the Petitioner,
To plead further, on several occasions, the
Petitioner called at the last minute and advised the
Respondent to deliver the children when he was not
present. To plead further, the Petitioner informed
Respondent that she was not welcome on the property,
and eventually the petitioner agreed to provide all
transportation and has continued to agree to do so,
WHEREFORE, the Respondent requests that the petition in
Contempt be denied, and that petitioner be required to pay
Respondent's legal fees in connection with answering this
Petition.
COUNTERCLAIM
15. The allegations in paragraph 1"14 are incorporate
herein.
16. The Petitioner has repeatedly been in contempt of the
Custody Order paragraph 3A, in that he must
personally be with the children while in his physical
custody and not leave them in care with others. He
repeatedly leaves them with his new wife, which
greatly upsets the children.
17. The Petitioner is in contempt of the Custody Order
paragraph 4, in that he has refused at all times to
cooperate in any counseling sessions required for
either children, even when arrangements were made
SAlOIS.
SHUFF &
MASLAND
~
16 w, Utah II''''
c.rU.lt, PA
directly with the counselor.
18. The Petitioner is in contempt of the Custody Order
paragraph 14, as the Petitioner's wife smokes in the
car and in the house. The children have reported
that she continually smokes, and when they come home
from visits with the Petitioner, they smell of smoke.
19. The petitioner is in contempt of the Custody Order
I
paragraph 15; as the Petitioner and his new wife
continually display affection toward each other in
front of the children. Further, the children. have
observed the Jilet1tioner and his wife having sexual
relations in front of them on at l~ast two specific
occasions.
WHEREFORE, the Respondent requests that Petitioner bEl held
in contempt of court and be required to pay Respondent's legal
fees in connection with his contempt.
Respectfully submitted,
SAIDIS, SHUFF,& MASLAND
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Pursuuntto this Court's Order of October I R. 199'9, utempornry Order wus entered
providing. inter uliu. Futher's periods oftemporury custody shull be FridllY ut5:00 pm until
Suturduy ut 7:00 pllll.lvery other weekend und Wednesduys from 5:30 pm until 8:00 pili.
Until very recently (November 1999), Mother would not ullow Tyler 10 huve periods ,of
visitutlon with Father. Alali times Futher WUK scheduled to huve the children, Futher showed up
to pick them up. More onen thun not, Mother would not ullow Tyler to visit with Futher und ut
times did not allow Morgun to visit with Futher. On severn I occasions. Futhcr showed up to pick
up the children for his scheduled visitation only to find nobody home. Since November. 1999,
Futher hus hud vlsitutlon with both of the children us provided lor in the Court Order duted
October 18. 1999.
Father seeks u pernlunent custody schedule us provided lor below,
II. Issues Before the Court
u. Is Mother in Contempt of this Court's Orders of September 2. 1998. Decemher 23,
1998 and Octobe!' 18. 1999? Should Futher getlhe relief requested. inCluding uttorney's fees?
b. A permunent cu~tody schedule nceds to be estublished between the purties thut
uddresses evening visits, 'overnight visits, holiduy schedule. summer vucutions, children's
blrthduys.
c. Futher currently does uli of the transportution, 1I shured transportation schedule needs
to be established.
d. Should the parties undergo counseling to help resolve outstunding unimosity towards
euch other?
III. Expected Witnesses und Anticiputed Testimony
u. Thomus Lee Wonders -- Futher or the children
b. Trucey Wonders -- Step Mother or the ehildrenund Futher's spouse is ullticiputed to
testily us to facts supporting Futher's Petition for Contempt und custody und visitution issues
c. Ruth Ann Wonders -- Futher's Mother is unticipated to testily us to fucts supporting
Futhcr's Petition 1'01' Contempt und custody and visitution issues,
d. Robert Wonders -- Futher's flit her is anticiputed to testily us to filets supporting
ruther's Pctition for COlllempt und custody und visitution issues
e. Skip Murpoe -- Stute Constuble is unticiputed to testily us tolhets supporting Father's
Petition lor Contcmpt
t: E1uinc Rissingcr -- Tylcr's counselor is unticipatcd to tcstify as to lacts reluting to hcr
counseling scssions with Tylcr, Mothcr und Futhcr.
IV. Futher's Proposed Pcmluncnt Custody Ordcr
/ a. Thc Parties shull have sharcd Icgul custody of thc children. M<.>>!lYF yhllll pW/idc, tit
~OOlR~Yr.to r alher copies or ull~rt Cllld, m,d wurlt ,elllll\J1rre'fr~I..Mo.tber shall
ap.nrize-l.ath~1 or ull rcports or Inl'ormailon rcluting 10 tliccliildren, orulorothc"iWis-e:'"rr<iinaYly
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. ,p yg".arr, tell er,t:llUnsclllr or cvu uutor.
J b. Mother shall huvc primury physicul custody ofthc childrcn subject to Futhcr's periods
of temporary physical custody.
c, Fathcr shull cnjoy pcriods of' tcmporury physical custody of the childrcn on ulternuting
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wceke:Ids from Friday ut 5:00 pm until Sunduy at.lHQ&pm. ~4l1tbllr KRall P'lC~ ~1\H~IIE lill ua~h
...child flU' thrE'J_ Uayli Lln" ~"g/' nlnng,said cl(}th~uitluhC' "hilwr':ll \JI' (', idllY~, ('"Hlli;1 ~hall rehtPfl
the ""tile. witl. tI.e chiltitr~ tin Stlllduys,
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d. Futhcr shull cnjoy pcriods of tcmporary physicul custody of thc childrcn on
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Wcdncsduys from 5:00 pmllntil S'II I J ".8:00 pm.
c. Mothcr shull cnsurc thut hoth childrcnurc uvuiluhlc nnd spcuk with Futhcr cvcry
Monduy night ut 7:00 pmlnutclcphonc cOl1vcrsutionto hc initilltcd hy Futhcr, Both purtics shull
pcnllittclcphone convcrsations with thc childrcn by Ill<: olhcr purty nt ull rcasonahlc timcs.
1', Futhcr shull huvc tcmporury physicul cllstody ofthc childrcn cvcry Thunksgiving Duy
from 3:00 pm until 8:00 pm
g. On odd ycurs, Futhcr shall huve tcmporury physical clls1.ody of thc childrcnl'vcry
Christmas Day liOlIl Dcccmhcr 25th ut 12:00 pmthrollgh Dcccmhcr 26th ut12:00 pm, On cvcn
ycurs, Futhcr shall huvc tcmporary physicul custody ofthc childrcn CVC1'Y Christmus Evc from
Decemher 24th ut 12:00 pm through Dccember 25th at 12:00 pm ,
,
h, Futhcr shull cnjoy tcmporary physicul custody of thc children cvcry Eustcr Irom 3:00
pm until 8:00 pm.
I. Father shuHcnjoy tcmporary physicul custody ofthc childrcn evcry Futhcr's Duy Irom
9:00 urn until 8:00 pm" Mothcr shull cnjoy tcmporury physicul custody ofthc children cvcry
Mothcr's Duy Irom 9:00 um until 8:00 pm.
j. Futher shull enjoy temporary physicul custody of the children every Easter Irom 3 :00
pm until 8:00 pm.
k. On odd ycars, Fathcr shull have tcmporary physical custody of the childrcn cVf:ry July
4th from 9:00 um until July 5th ut noon, On cven yeurs, Mother shull huve temporary physicul
custody of the children every July 4th Irom 9:00 um until July 5th ut noon.
I. On odd yeurs, Mother shull huve temporary physicul custody of the children cvcry
Memorlul Day und Lubor Duy Irom 9:00 um IIntil 8:00 pm. On cvcn ycars, Fathcr shall huvc
tcmporary physicul custody of thc childrcn cvcry Mcmorinl Duy und Luhor Duy Irmll 9:00 um
until 8:00 pm.
m. Euch purty shllll huvc two non consccutive wccks of vucution with thc childrcn during
thc childrcn's summcr vucution. Euch purty shull providc thc othcr with utlcust 30 du)s noticc Ill'
to thcir intention to cxcrclsc thcsc tlmc pcriods. Nelthcr p"rty clln cxcrclsc thcse wceks during
Mcmoriul Duy, July 4th or I.ahor Duy. In cusc ofu eontllct with wccks selcctcd,thc Purty thut
udvises thc othcr I1rst rcgurding (\ wcck shull be cntitlcd to huvc thut wcck,
n. For ull pcrimfof Futhcr's tcmporury physicu\ custody, Futhcr shull piek the children up
at Mother's rcsidcnce. At the cnd of FlIthcr's pcriods oftempornry physical custody, Mother
..,..\","",," ",..,.'tri; S~ ......,.'... ............... ".......'ttI'\" _'" "-...... .
shull pick thc childrcn up ut Futhcr's rcsidcncc't\lfeither p"rty is uccompunicd by unothcr pcrson
or pcrsons during thc cxchungcs of custody, thosc other pcrsons to rcmuin in thc vehiclc ut ull
times.
o. During their pcriods of custody of the children, both purcnts shull insure thut no
smoking occurs in u vchiclc or u housc occupicd by eithcr of thc childrcn.
p. Neithcr p"rty shull qucstion thc childrcn rcgurding dctails of thclr visitution with thc
other purent.
q, The appropriate law enforcement officiuls shull huve uuthority to cnforce thc tcrms of
this custody order us uuthorized by luw. This provision authorizes a police ollice to dcliver the
,
children from the custody of onc purentto the other purentto ensure thlltthe terms of the order
ure being followcd.
r. Mother ussumes the obligation of cnsuring thutthc children follow her directivcs und
comply w'flthe c9Ufl~r~ It shull ~~)hefCsponsl ility oftl~,~l;It thc
children V~ercd to Fa~()~rpose of custo as s~~orth uhove und failure of the
Mot~ IO~l1 the ternls of the _:.U,~~dY Ordcr muy sub c 'Ithc Mothcr to uppropriutc contcmpt
pro~sUKu~,...r ",
"
Date: December 27, 1999
Rcspcetful1y submitted,
Mk " J. limO. ~Wft
Attorncy \D No. 57976
19 Brookwood Avenuc, Suitc 106
Carlisle, P A 17013
(717) 249.5373
Allorney lor Pctitioner/Plulntitl'
VIUMf foldlPlln"Dllu'.(}mducIWlUlI.1 M,mu,lIIdulO I\pd
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CERTIFICATE OF SERVICE
AND NOW, this 27th duy of December, 1999, I, Michuel.J. Hunn, Esquire, hereby certlty tllllt
I hnve this duy served thc foll\Jwing pcrson with n copy of the forcgoing document, by depositing
sume in the United Stntes Muil, First Cluss, Poslnge Prepnld, nddressed us tallows:
Johnnu J. Deily, Esquire
SAlOIS, SHUFF & MAS LAND
, 26 West High Street
Curlislc, PA 17013-2956
By
Ichuel J. Hnn ,Esquir
Attorncy 10 No. 57976
19 Brookwood A venue, Suitc 106
Curlisle, PA 17013.9142
(717) 249.5373
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THOMAS LEE WONDERS,
Pctitioncr
IN .rHE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA.
v.
NO, 97-7188
KAREN RAE WONDERS,
Rcspondcnt
IN CUSTODY
ERAF.C'IPE
To thc Prothonotury:
Pursuunt to thc Ordor ofCollrt dutcd Fcbruury 25, 1999, thc undcrslgncd hcrcby withdruws
Us counsel for the Pluintlff, Thomus Lec Wondcrs.
MARTSON, DEARDORFF, WILLIAMS & OTTO
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By l W.t.ov
Thomus J. Wil . illS, Esquire
Ten Eust High Street
Curlislc, PA 17013
(717) 243-3341
wA~
Date:. Murch 15,1999
Attorneys for Plaintiff
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THOMAS LEE WONDERS,
Plaintill.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 97. 1 J J' i CL.;J ., ~
KAREN RAE WONDERS,
Defendunt
IN CUSTODY
PI,AINTlFF'S COMPLAINT TO CONFIRM CUSTODY
I. Plaintiff is Thomas Lee Wonders, an udult individual, with a mailing address of558
Shippensburg Road,Cumberland County, Newville, Pennsylvania.
2. Defendant is Karen Rae Wonders, un adult individuul, who currently resides at 664
North Middle Road, Cumberland County. Newville, Pennsylvuniu.
3. Plaintiff seeks custody of the following children:
Tyler Thomas Wonders Born July 22,1991
Morgan Paige Wonders Born June 18,1994
The children were not born out of wedlock.
Since the children's births, the children huve resided with the following persons at the
following addresses for the following periods of time:
,
The children resided with the parties from the dates of their births until December 13, 1997,
after which the children huve resided with the Defendant exclusively.
4. The natural father of the children is Plaintiff who resides as aforesaid. He is married
and living separately. Plaintiff currently resides with the following:
I::Wlll: Relationship
Tracy Lehmun Friend
Dorothy Jumper Friend's Grandmother
5. The natural mother of the children is Defendant who resides as aforesaid. She is
married and living separately. The Defendant currently resides with the following:
:Manu: Relationship
Tyler Thomas Wonders Son
Morgan Paige Wonders Duughter
I
.
6. Thc purtlcs huvc not purticipAtcd in prcvious litigAtion conccrning the custody of the
child in this court or uny court.
,
The Plaintill' hUM no inlbnnation of A custody proceeding concerning the child pending in any
ot~er court.
7. The best interest and pennunent welfAre of thc child will bc served by grantinll
custody to Plaintiff because: Plaintiff is not asking for lull custody of the children at this time, '
Since the parties sepamted on December 23, 1997 at the insistence ofDcfendant, PlainUll'has been
,
~enied access to his childrcn sincc that time, und would rcquest visitations with his children,
8. Plaintiff does not know of any person not A party to these proceedings who claims
to have custody or visitation rights with respect to. the child.
WHEREFORE, Plaintiff requests your Honorable Court to set a limc and place for a hearing
at which Plaintiff requests the Court to grant him thc Custody Order. Pending said hearing, Plaintiff
reques!s visitations with his children.
MARTSON, DEARDORFF, WILLIAMS & OTro
By '1~~') 'a'&~.
Thomas J. WIlliams, Esquire
Ten East High Street
Carlisle, P A 17013
(717) 243-3341
Attorneys for Plaintiffs
Date: December 31,1997