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KEI'l'lI EDWARD COlm,
Plllintiff
IN 'I'/II~ COUR'I' m' COMMON PLEAS m'
CUMlmllLAND COUN'I'Y, PENNSYLVANIA
vs.
NO. 90-59 CIVIL TERM
CIVIL ACl'ION - LAW
ELORIA ANNm'l'E RCX>1O
Defendant
IN CUSTODY
OODER OFaxJRT
AND r<<JW, this I ,y"
consideration of the attached
and directed as follows:
day of f'~6..o/a-J , 199B, upon
CUstody Conciliation' Report, it is ordered
1. The Father, Keith Edward Corn, and the Mother, Eloria Annette
Romo, shall have shared legal cutody of Coda Zandar Rome, born October 30,
1993.
2. The Father shall have primary physical custody of the Child.
3. The Mother shall have partial physical custody of the Child on
alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m.,
beginning February 13, 199B and at such other times as mutually agreed upon
by the parties.
4. The parties shall share or alternate having custody of the Child
on holidays as follows:
A. CHRISTMAS: In every year, the Father shall have custody of
the Child from Christmas Eve at 2:00 p.m. until Christmas Day
at 2:00 p.m. and the Mother shall have custody of the Child
from Christmas Day at 2:00 p.m. until December 26 at 2:00 p.m.
B. THANKSGIVING: In every year, the Mother shall have custody of
the Child from Thanksgiving Day at 6:00 p.m. until the
following Friday at 6:00 p.m. The Father shall have custody
of the Child until 6:00 p.m. on Thanksgiving Day..
5.
C. EASTER: In every year, the Father shall have custody of the
Child on Easter Sunday until 2:00 p.m. and the Mother shall
have custody of the Child from 2:00 p.m. until 6:00 p.m.
D. MOTHER'S DAY/FATHER'S DAY: The Mother shall have custody of
the Child every year on Mother's Day from 2:00 p.m. until 6:00
p.m. and the Father shall have custody of the Child every year
on Father's Day from 2:00 p.m. until 6:00 p.m.
E. The Mother shall have a period of custody on other holidays,
not otherwise mentioned in this Order, and the Child's
birthday as arranged by mutu~ agreement of the parties.
The Mother shall have custodY)~~, Child during the surrmer
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vacation in each year for two non-consecutive 9-day periods to include two
we9kends, upon providing thirty (30) days advance notice to the Father.
6. Th9 parties shall inform each other promptly of any changes to his
or her address or telephone number.
7. The parties shall share transportation for exchanges of custody
under this Order.
8. In the event the Father requires childcare for the Child, other
than the Child's regular attendance at the YMCA Daycare Program, the Father
shall first provide the Mother with the opportunity to provide the care
before contacting other third party babysitters.
9. This Order is entered pursuant to an agreement of the parties at a
CUstody Conciliation Conference. The parties may modify the provisions of
this Order by mutual consent. In the absence of mutual consent, the terms
of this Order shall control.
BY THE COURT,
cc: Thomas J. Williams - Counsel for F er
Joan Carey, Esquire/Jennifer Gutshall - Counsel for Mother
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KIU'I'II FoOWMlIl COliN,
Plaintiff
IN 'I'IIE COUR'l' ot' COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO. 90-59
CIVIL 'I'FoRM
ELORIA ANN~PI'E ROMO,
Defondant
CIVIL ACTION - LAW
IN CUSTODY
CUS'lOOY CXH:ILIATlOO ~ REPCRl'
IN ACXXJlDANCE WITH cumERLAND CXXNl'Y RULE OF CIVIL PRO '.... fJRE
1915.3-8, the undersigned CUstody Conciliator submits the following report:
1. The pertinent information concerning the child who is the
subject of this litigation is as follows:
NAME
DATE OF BIRTH
CIlRRFNl'Ly IN CUS'lOOY OF
Coda Zandar Romo
October 30, 1993
plaintiff/Father
2. A Conciliation Conference was held on February 12, 1998, with the
following individuals in attendance: The Father, Keith Edward Corn, with
his counsel, Thomas J. Williams, Esquire, and the Mother, Eloria Annette
Romo, with her counsel, Joan Carey, Esquire and Jennifer Gutshall.
3. The parties agreed to entry of an Order in the form as attached.
R),YIJ
Date ~
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.
DarP'~~n~
CUstody Conciliator
KErnl EDWAIW CORN.
1'IIIIntirf/l'ctitloner
IN TIlE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,PENNSYLVANIA
NO. 98-59
v.
ELORIA ANNETTE ROMO,
Defendant/Rcspondent
IN CUSTODY
ORDER OF CO! JRT
AND NOW, this,2l. day of ,7~1 /I I , 1999, upon consideration of the auached I'ctition
to Reappoint Custody oneiliator, it is hcr y d'rccted that the parties and their respectivc counsel
a pear be re , the conciliator, at
'fil.; r. ' ,J ( , , " th '- f ,<.e dll'h< h(J r ,
1999, at / D : :11) R .m. for a Pre-Hearing Custody Conference. Ai such confcrence, 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 also be present at the conference. Failure to appear at the conference may provide
grounds for entry of a temporary or pennanent order.
FOR THE COURT,
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For infonnation about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact
our office. All arrangements must be made at least 72 hours prior to any hearing or business before
the court. You must attend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO
NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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KEITH EDWARD CORN,
Plllintilli'l'etitiollcr
IN TilE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,PENNSYLVANIA
v.
NO. 98-59
ELORIA ANNETTE ROMO,
DcfendllntJRespondent
IN CUSTODY
PETITION TO REAPPOINT CUSTODY C.ONClI.IATOR
AND NOW, comes Petitioner, Keith Edward Corn, by and through his attorneys,
MARTS ON, DEARDORFF, WILLIAMS & OTTO, and requests the reappointment of the Custody
Conciliator as follows:
I. Petitioner is Keith Edward Corn, an adult individual residing at 230 Union Hall Road,
Carlisle, Cumberland County, Pennsylvania.
2. Defendant is Eloria Annette Romo, an adult individual residing at 1610 Longs Gap
Road, Carlisle, Cumberland County, Pennsylvania.
3. This action concerns the parties' child, Coda Zandar Romo, born October 30, 1993.
4. A Concilation Conference was held on February 12, 1998 before Dawn S. Sunday,
Esquire.
5. A Custody Order was entered on February 18, 1998 giving PlaintifTprimary physical
custody, a copy of which is attached hereto and marked as Exhibit "A."
6. Since the entrance of this Order, the parties have had disagreements regarding the
custody of the child.
7. Petitioner would request the Order dated February 18, 1998 be amended to include
the following:
a. Petitioner would like a neutral location for the transfer of custody, such as the
North Middleton Police Department. The police have been called a number
of times in connection with transfers of custody.
b. Petitioner is concemed about overcrowding at Defendant's residence and
wants to be sure Coda has his own bedroom.
c. Petitioner is concerned that Coda is being transported in vehicles which do
not have a current inspection or being ddven by people without a current and
vlllid driver's license IInd woulll rcquest tllllt COlI II be lrllnsportcll in II vehicle
hllvinllu cnrrcnt stllte Inspectionllnd driven by someone with II cllrrcnlnnd
vlllld lIriver's license.
d. The parties coordinllte thcir interllctlons with people like school
officials/tcuchers so they lire there at diffcrcnt timcs.
e. Two things have happened to Petitioner since the Ordcr was cntcrcd. Firsl,
he got married. The other is that he lost his driver's license. This rneans that
his wife has to do the transportation for him. Petitioner would like the Ordcr
amended to reflect that Petitioner is pcrmittcd to have others act on his bchalf
(such as transportation) when he finds it necessary to do so.
WHEREFORE, PlaintitT requests Your Honorable Court to reappoint a Custody Conciliator
to set a time and place for a hearing.
MARTS ON, DEARDORFF, WILLIAMS & OTTO
By
Thomas J. WiI a
Ten East Hig eet
Carlisle, P A 17013-3093
(717) 243-3341
Attorneys for Petitioner
Date: June 24, 1999 .
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KEITII mJARO CXlRN,
Plaintiff
IN THE COURT OF ~ PLEAS OF
: CUMBEmJ\ND COUNTlC, PER/SYLVANIA
.
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va.
: NO. 98-59 CIVIL TERM
: CIVIL ACTION - LAW
ELORIA ANNETTE RalO
Defendant
:
: IN CUS'lOOY
alIER CI!' CXllRr
Am lOI, this I g-tJ... 'day of .::F ~
COI'IlIideration of the attached CUstody Conci at on OReport,
and directed as follows:
, 1998, upon
it is ordered
1. 'Ibe Father, Keith Edward Corn, and the Mother, Eloria Annette
Rano, shall have shared legal cutody of Coda' Zandar Rano, born OctOber 30,
1993.
2. The Father shall have primary physical euatody of the Child.
3. 'Ibe Mother shall have partial physical custody of'the Child on
alternating weekends fran Friday at 6:00 p.m. until Sunday' at 6:00 p.m.,
beginning February 13, 1998 and at such other times as mutually agreed upon
by the parties. ' , ~,
4. ' 'Ibe parties" shallaliare or alterilate' having custody of the Child
on holidays as follows: ' , ' '",' ' ,
A. CllRIS'l'MAS: In every year, the Father shall have custody of
the Child fran Christmas Eve at 2:00 p.m. until Chrisbnas Day
at 2:00 p.m. and the Mother shall have custody of the Child
fran Chrisbnas Day at 2:00 p.m. until DecenDer 26 at 2:00 p.m.
B. TllANKSGIVING: In every year, the Mother shall have custody of
the Child fran Thanksgiving Day at 6:00 p.m. until the
following Friday at 6:00 p.m. The Father shall have custody
of the Child until 6:00 p.m. on Thanksgiving Day..
C. EASTER: In every year, the Father shall have custody of the
Child on Easter Sunday until 2:00 p.m. and the Mother shall
have custody of the Child fran 2:00 p.m. until 6:00 p.m.
D. MCn'HER'S DAY/FATHER'S DAY: The Mother shall have custody of
the Child every year on Mother's Day from 2:00 p.m. until 6:00
p.m. and the Father shall have custody of the Child every year
on Father's Day from 2:00 p.m. until 6:00 p.m.
. E. The Mother shall have a period of custody on other holidays,
not otherwise mentioned in this Order; and the Child's
birthday as arranged by mutual agreement of the parties.
5. The Mother shall have custody of the Child during the sUllll1E!r
"
EXHIBIT "A"
vacation in each year for two non-consec:lJtive 9-day periods to include two
weekends, upon providing thirty (30) c1aya advance notice to the Father.
6. The parties shall inform each other promptly of any changes to his
or her address or telephone number.
7. The parties shall share transportation for exchanges of custody
under this Order.
8. In the event the Father requires childcare for the adld, other
than the Olild's regular attendance at the YMCA Daycare Program, the Father
shall first provide the Mother with the opportunity to provide the care
before contacting other third party babysitters.
9. This Order is ent9red pursuant to an agreement of the parties at a
Custody Conciliation Conference. The parties may modify the provisions of
this OI:'der by III.Itual consent. In the absence of mutual consent, the terms
of this Order shall control.
BY THE CXXlRT,
I.~J~ a..,~
cc: Thomas J. Williams - Counsel for Father
Joan Carey, Esquire/Jennifer Gutshall - Counsel for Mother
TRUE COPY FROM RECORD
,.,' I man}' wh'3reof, III~' 1'"0: ) f.~t my hand
alOt! iilJ seal of said Courl at Cal:isI9, Pa.
This ...."..8..~. day oL.Z..d.t-..,., 19.~f"
"''''''MM..,~....a....]f='~'M_
cDPc;' Prothonotary
KEITH EDWARD aJI\N, I IN TIlE <XlURT OF CCH>lOO PLEAS OF
Plllintiff I ctJo\BERLAND COUNTl{, PENNSYLVANIA
I
VIS. . NO. 98-59 CIVIL TElUI
.
:
ELORIA Am!'1"1'E Ra1O, . CIVIL ACTION - LAW
.
Defendant . IN CUS'1OOY
.
CDS'1aJlC CXH:ILIATIm SlMIARY RBPtRl'
IN AOCXIUlllNCB wrm aJIlI!RI.AR) cxuny RIJLB a!" CIVIL PIl(.~..Jm
1915.3-8, the undersigned CUstody Conciliator subnits the following report:
1. 'l11e pertinent information concerning the Child who is the
subject of this litigation is as follows:,
\
NIlMB
DM:'E CI1' BDmJ
CURRBRl'LY IN <=>-...Uli a!'
Coda Zandar Romo
October 30, 1993
Plaintiff/Father
2. A Conciliation Conference was held on Februar.y 12, 1998, with the
following individuals in attendance: 'ltie' Father, Keith Edward Corn, with
his counsel, Thomas J. Williams, Esquire, and 'the Mother, Eloda Annette
Romo, with her counsel, Joan Carey, Esquire arid Jennifer Gutshall.
3. 'ltie parties agreed to entry of an Order in the form as attached.
k:.-bru
Date ~
1cJ,.. t9 'lB-
.
(O~J-<1~
Dawn s. sunday, re
CUstody Conciliator
"
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VERWICATl.OlS
The foregoing I'elitionlo Reappoint Custody Concililltor is bllsed upon infonlll1tion which
hus been gUlhered by illY counsel in the prcpllrntion of the Illwsuil. The Iunguagc of the doeumcnt
is thai of counselund not my own. I hllvc read the docurnent and to the extent that it is based upon
infonnlltion which I havc given to my counsel, it is lrue IInd correct to thc bcst of my knowledgc,
infornlation and belief. To lhe ex lent that thc content of the document is that of counsel, I have
relied upon counsel in making this verification.
This statement and verification are made subjcct to the penalties of 18 I'a. C.S. Section 4904
relating to unsworn falsification to authorities, which provides that if I make knowingly false
avennents, 1 may be subject to criminal penaltics.
/)i;~ (:n1/\
Keith Edward Corn
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KEITH EDWARD CORN.
I'lnintilr
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LA W
v
ELORIA ANNElTE ROMO-DEW ALT,
Dcfendant
NO. 98-59 CIVIL
IN CUSTODY
COURT ORnER
AND NOW, this 1(,' day of Scptember, 1999, upon considcration of the attached Custody
Conciliation Report, it is ordered and directcd as follows:
I. This Court's Order of February 18, 1998 is ratified subject to the modifications as
set forth below.
2. Paragraph 7 of the February 18, 1998 Order is modificd such that exchange of
custody for the minor child shall take place at the North Middleton Township Police
Department. Either parent or their new spouse may deliver or pick up the child with
the arrangement at the Police Station.
3. After the parties have exchanged custody at the Police Station for three (3) separate
occasions and in the event the Mother at that time feels that the Police Station is not
an appropriate place for exchange of custody, counsel for the Mother may petition
the court directly for the scheduling ofa short hearing to address the sole issue of the
place of exchange of custody.
4. In light of the fact that the parties share legal custody of the minor child, the Father
is specifically directed to share with the Mother all infonnation in advance
concerning the child's schooling, health issues and all other related matters. Mother
shall be given the names, addresses and phone numbers of all physicians and this
order hereby authorizes all school officials and medical personnel to deal with the
Mother concerning any and all infonnation of the minor child and to release to the
Mother any and all documentation conceming the minor child.
5. While the child is in the custody of the Mother, the Mother shall ensure that the child
has his own separate bedroom or, in the alternative, sleeps in a bedroom with same
sex children.
BY THE COURT,
I1/L
cc:
Thomas Williams, Esq.
Joan Carey. Esq.
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IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,I'ENNSYLV ANIA
CIVIL ACTION - LA W
KEITH EDWARD CORN.
I'lnintitr
ELORIA ANNETI'E ROMO-DEWALT,
Dcfcndant
NO. 98.59 CIVIL
IN CUSTODY
Prior Judgc: Kcvin A. ('less
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the following report:
I. The pertinent infonnation pertaining to the child who is thc subject of this litigation is as
follows:
Codn Zondar Romo, born October 30, 1993.
2. A Conciliation Conference was held on Scptember 10, 1999, with the following individuals
in attendance:
The Father, Keith E. Com, with his counsel, Thomas Williams, Esquire; and the Mother,
Eloria A. Romo-Dewalt, with her counsel, Joan Carey, Esquire.
3.
The parties are before the Conciliator on a variety of issucs. It is crystal clear to the
Conciliator that the parties equally are unable to work with or communicate with the other
parent. 'The parties are having a problem with exchange of custody. The police have been
involved in exchange of custody at least 1-5 times over the past eighteen months. The
Father suggests an exchange of custody at the police station based upon a suggestion made
by the police. The Mother, who does not have a license, suggested that this may be a
problem. The Conciliator notes that the Mother lives approximately five minutes from the
North Middleton Township Police Department and that her current husband has a current
driver's license.
j
4. Based upon the infonnation at the Custody Conciliation Conference, the Conciliator
recommends an the entry of an order in the fonn as attached.
~'{fff
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KElTII flOW ARD CORN
PLAINTIFF
V.
flLORIA ANNErm ROMO.DEW ALT
DEFENDANT
IN TilE COURT OF COMMON I'LEAS OF
CUMIlEIU.AND COUNTY.I'ENNSYLVANIA
9H-S9 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COIIRT
AND NOW, this 9th day of January. 2001. upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear before Dawn S, Sunday, Esq. ,the conciliator,
at 39 West Main Street, Mechanlcsburg, PAt 7055 on thc 7th day oU'ebruary ,200 I, at 1 :00 p.m.
for a Pre-Hearing Custody Conference. At such eonfcrenee, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to deline and nalTOW the issues to be heard by the court, and to enter into a temporary
order. All children age live or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or penn anent order.
FOR THE COURT,
By: Isl
Dawn S. SIII/day,~
Custody Coneiliat .
~
I
I
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with DisabiIites Act of 1990. For infonnation about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the
schedulcd conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR A'rrORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATfORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty A venue
Carlisle. Pennsylvania 17013
Telephone (717) 249-3166
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KEITH EI)WARI> CORN,
l'laln tlff/Responden t
: IN THE COURT OF COMMON I'LEAS OF
: CUMIIEIU,ANI> COUNTY, I'ENNSYLV ANIA
: CIVIL ACTION
v.
ELORIA ANNETTE ROMO-DEWALT : No. 98-59 CIVIL
Defendant/Petitioner : IN CUSTODY
ORDER OF COURT
AND NOW, this _ day of
, 200 I, a Contempt hearing is scheduled
in Courtroom #
o'clock _m. on the
,2001,
, day of
at
at the Cumberland County, Courthouse at Carlisle, Pennsylvania.
J.
Distribution:
Karl E. Rominger, Esquire
Thomas J. Williams, Esquire
KI~ITII EI>W Aim C()I{N,
I'hlln t I ffll{cspondcn t
: IN TIlE COURT OF COMMON I'LEAS OF
: CUMUlmLANI> COUNTY, I'ENNSYLVANIA
: CIVIL ACTION
v.
ELORIA ANNETTE ROMO-DEW AI. T : No. 98-59 CIVIL
Dcfcndllntll'ctitioncr : IN CUSTODY
I'ETITION FOR CONTEMPT
AND NOW, comes Eloria Annette Romo-Dewalt by and through her counsel, Karl E.
Rominger, Esquire and Petitions this Honorable Court to find the Plaintiff, Keith Edward Com, in
Contempt ofa Modified Custody Order for the following reason:
I. Petitioner has not been allowed to exercise her custodial rights as outlined in
the Modified Custody Order previously in place by the Honorable Judge Kevin A. Hess dated
September 16,1999, and attached hereto as Exhibit "A".
2. In particular, Petitioner has been denied visitation, information regarding school
and health issues and other related matters.
WHEREFORE, Petitioner requests that this Honorable Court schedule a hearing to find
the Plaintiff in Contempt ofa Court Order and grant all proper and just relief.
Respectfully submitted,
L'~ ~14/?~
Eloria Annette Romo-Dewalt Karl E. Rominger,Esquire
155 South Hanover Street
Carlisle, PAl 7013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Petitioner
,
-
KEITH EI>WAlm CORN,
1'1111 n t lffll{cs pond en t
: IN THE COURT OF COMMON I'LEAS OF
: CUMIIERLANI> COUNTY,I'ENNSYLV ANIA
: CIVIL ACTION
v.
ELORIA ANNETTE IWMO-DEW AI. T : No. 98-59 CIVIL
I)cfcndant/Petitioner : IN CUSTOI>Y
CERTIFICATE OF SERVICE
I, Karl E. Rominger, Esquire, attorney for Eloria Annette Romo-Dewalt, do hereby certifY
that 1 this day served a copy of the within Petition for Contempt upon the following by depositing
same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as
follows:
Thomas J. Williams
Martson, Deardorff, Williams & Otto
10 East High Street
Carlisle, PA 17013
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Karl E. Rominger, Esquire
Dated: January 5, 2001
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KEITH EDWARD CORN,
Plaintifr
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLV ANIA
CIVIL ACTION - LAW
v
ELORIA ANNE'ITE ROMO-DEW ALT,
Defendant
NO. 98-59 CIVIL
IN CUSTODY
COURT ORDER
AND NOW, this 1t..tJ..day of September, 1999, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
i. lilis Court's Order of February 18, 1998 is ratified subject to the modifications as
set forth below.
2. Paragraph 7 of the February 18, 1998 Order is modified such that exchange of
custody for the minor child shall take place at the North Middleton Township Police
Department. Either parent or their new spouse may deliver or pick up the child with
the arrangement at the Police Station.
3. After the parties have exchanged custody at the Police Station for three (3) separate
occasions and in the event the Mother at that time feels that the Police Station is not
an appropriate place for exchange of custody, counsel for the Mother may petition
the court directly for the scheduling of a short hearing to address the sole issue of the
place of exchange of custody.
4. In light of the fact that the parties share legal custody of the minor child, the Father
is specifically directed to share with the Mother all information in advance
eoncerning the child's schooling, health issues and all other related matters. Mother
shall be given the names, addresses and phone numbers of all physicians and this
order hereby authorizes all school officials and medical personnel to deal with the
Mother concerning any and all information of the minor child and to release to the
Mother any and all documentation conceming the minor child.
5. While the child is in the custody of the Mother, the Mother shall ensure that the child
has his own separate bedroom or, in the a1temative, sleeps in a bedroom with same
sex children.
BY THE COURT,
cc:
Thomas Williams, Esq.
Joan Carey, Esq.
1..,1 7d..;~ (~ . J..k~ J.
Kevin A. Hess "1";" !;~ r:: F"'f ;:;: "1~,1 RECORD
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EXHIBIT "A"
v
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 98-59 CIVIL
IN CUSTODY
KEITH EDWARD CORN,
Plainlin'
ELORIA ANNElTE ROMO-DEW ALT,
Defendant
Prior Judge: Kcvin A. l'less
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
19I5.3-8(b), thc undersigned Custody Conciliator submits the following report:
I. The pertinent infonnation pertaining to the child who is the subject of this litigation is as
follows:
Coda Zondar Romo, born October 30, 1993.
2. A Coneiliation Conferencc was held on September 10,1999, with the following individuals
in attendance:
The Father, Keith E. Com, with his counsel, Thomas Williams, Esquire; and the Mother,
Eloria A. Romo-Dewalt, with her counsel, Joan Carey, Esquire.
3. The parties are before the Conciliator on a variety of issues. It is crystal clear to the
Conciliator that the parties equally arc unable to work with or communicate with the other
parent. The partics are having a problem with exchange of custody. The police have been
involved in exchange of custody at least 1-5 times over the past eighteen months. The
Father suggests an exchange of custody at the police station based upon a suggestion made
by the police. The Mother, who does not have a license, suggested that this may be a
problem. The Conciliator notes that the Mother lives approximately fivc minutcs from the
North Middleton Township Police Department and that her current husband has a current
driver's license.
4. Based upon the information at the Custody Conciliation Conference, the Conciliator
recommends an the entry of an order in the form as attached.
~
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KEITH EDWARD CORN,
Plaintiff
:
IN THE COURT .OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
.
vs.
NO. 98-59 CIVIL TERM
CIVIL ACTION - LAW
ELORIA ANNETTE ROMO
Defendant
.
.
.
.
.
.
IN CUSTODY
ORDER OF CXXJRT
AND ocw, this , '3 tJ~ day of "=fi t{,'lf'''ll~
consideration of the attached CUstody Concil atlon eport,
and directed as follows:
, 1998, upon
it is ordered
1. The Father, Keith Edward Corn, and the Mother, Eloria Annette
Ramo, shall have shared legal cutody of Coda Zandar Romo, born October 30,
1993.
2. The Father shall have primary physical custody of the Child.
3. The Mother shall have partial physical custody of the Child on
alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m.,
beginning February 13, 1998 and at such other times as mutually agreed upon
by the parties.
4. The parties shall share or alternate having custody of the Child
on holidays as follows:
A. CHRISTMAS: In every year, the Father shall have custody of'
the Child from Christmas Eve at 2:00 p.m. until Christmas Day
at 2:00 p.m. and the Mother shall have custody of the Child
from Christmas Day at 2:00 p.m. until December 26 at 2:00 p.m.
B. THANKSGIVING: In every year, the Mother shall have custody of
the Child from Thanksgiving Day at 6:00 p.m. until the
following Friday a~ 6:00 p.m. The Father shall have custody
of the Child until 6:00 p.m. on Thanksgiving Day..
C. EASTER: In every year, the Father shall have custody of the
Child on Easter Sunday until 2:00 p.m. and the Mother shall
have custody of the Child from 2:00 p.m. until 6:00 p.m.
D. MOTHER'S DAY/FATHER'S DAY: The Mother shall have custody of
the Child every year on Mother's Day from 2:00 p.m. until 6:00
p.m. and the Father shall have custody of the Child every year
on Father's Day from 2:00 p.m. until 6:00 p.m.
E. The Mother shall have a period of custody on other holidays,
not otherwise mentioned in this Order, and the Child's
birthday as arranged by mutual agreement of the parties.
5. The Mother shall have custody of the Child during the summer
I
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vacation in each year for two non-consecutive 9-day periods to include two
weekends, upon providing thirty (30) days advance notice to the Father.
6. The parties shall inform each other promptly of any changes to his
or her address or telephone number.
7. The parties shall share transportation for exchanges of custody
under this Order.
8. In the event the Father requires childcare for the Child, other
than the Child's regular attendance at the YMCA Daycare Program, the Father
shall first provide the Mother with the opportunity to provide the care
before contacting other third party babysitters.
9. This Order is entered pursuant to an agreement of the parties at a
CUstody conciliation Conference. The partie~ may modiiy che prOvisions of
this Order by mutual consent. In the absence of mutual consent, the terms
of this Order shall control.
BY THE COURT,
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cc:
Thomas J. Williams - Counsel for Father
Joan carey, Esquire/Jennifer Gutshall - Counsel for Mother
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KEITII ED\'IARD CORN,
plainti r f
IN TilE COUR'l' OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 98-59
CIVIL TERM
ELORIA ANNETTE ROMO,
Defendant
CIVIL ACrION - LAW
: IN CUSTODY
CUS'l'ODY calCILIATIOO stJoIMARy REPOOT
IN 1ICXXllUll\NCE WITH ClJtIBlmIJINl) CXXlNl'lr RULE OF CIVIL PROCEOURE
1915.3-8, the undersi9ned Custody Conciliator submits the following report:
1. The pertinent information concerning the child who is the
subject of this litigation is as follows:
NAME
DATE OF BIRTH
CURRENl'Ly IN CUSTODY OF
Coda Zandar Romo
October 30, 1993
plaintiff/Father
2. A Conciliation Conference was held on February 12, 1998, with the
following individuals in attendance: The Father, Keith Edward Corn, with
his counsel, Thomas J. williams, Esquire, and the Mother, Eloria Annette
Romo, with her counsel, Joan Carey, Esquire and Jennifer Gutshall.
3. The parties agreed to entry of an Order in the form as attached.
k:JJm
Date ~
1cJ. 1998-
.
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Dawn S. Sunday, Esquire
Custody Conciliator
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LAw Ol'l'Iel: or MICIIAI'I. ). HANFT
AnUI<NISS & C," INSIII"ltS AT I.AW
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717.:.H'J,~LHJ 1,\\ 717.1,P),O,IS7 W\\'\\'.IIt\NIII^\VIIIlM.CllM
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, I'ENNSYL VANIA
KEITH EDWARD CORN,
Plaintiff
98-59 CIVIL ACTION - LAW
v.
ELORIA ANNETTE ROMO-DEW AL T,
Defendant
IN CUSTODY
PRAECIPE FOR WITHDRAWAL OF APPEARANCE
To PROTHONOTARY:
Please withdraw my appearance on behalf ofthe Plaintiff, Keith Edward Corn, in the above-
captioned matter.
"
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Thomas J. Wiffiams, Esquire
MARTSON DEARDORFF WILLIAMS & OTTO
10 East High Street
Carlisle, P A 17013-9142
(717) 243-3341
Date: ,;./ {. 10/
,/"
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PRAECIPE FOR ENTRY OF APPEARANCE
To PROTHONOTARY:
Please enter my appearance on behalf of the Plaintiff, Keith Edward Corn in the above-
. '
capl10ned matter.
LA W OFFICE OF MICHAEL J. HANFT
Date: 7- / '0 1111
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Michael J. Hanft, Esquire
Attorney ill No. 57976
19 Brookwood Avenue, Suite 106
Carlisle, PA 17013-9142
(717) 249-5373
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plaintiff/Respondent
IN THE OOURT OF cx:>>1MON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs.
: NO. 98-59
CIVIL TERM
:
ELORIA ANNETTE ROMO-DEWALT,
Defendant/Petitioner
.
.
CIVIL ACTION - LAW
IN CUSTODY
:
PRICR JUDGE: Kevin A. Bess
CUS'lOOY cx:tlCILIATIW stMIARY REPCRl'
IN ACCDlDANCE WITH cnmBRIJ\ND cx:J(Nfi RULE OF CIVIL Pll()' '1<1 a..RE
1915.3-8, the undersigned CUstody Conciliator submits the f.ollowing report:
1. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
Nl\flE
DATE OF BIRTH
CUllRENTLY IN CUS'lOOY OF
Coda Zandar Rome
October 30( 1993
Father
2. A Conciliation Conference was held on February 21, 2001, with the
following individuals in attendance: The Father, Keith Edward Corn, with
his counsel, Michael J. Hanft, Esquire, and the Mother, Eloria Annette
Rome-DeWalt, with her counsel, Karl E. Rominger, Esquire.
3. This Court previously entered Orders in this matter on February 18,
1998 and September 16, 1999 under which the Father had primary physical
custody of the Child and the Mother had partial custody on alternating
weekends from Friday through sunday. All exchanges of custody were to take
place at the North Middleton TOwnship Police Department. The Mother filed
this petitic:n for Contempt alleging that she had been denied custody in
violation of the existing Order. It became clear at the Conference that
the circumstances leading to the allegations in the Mother's Contempt
petition arose primarily due to the parties complete inability to
corrmunicate directly with each other concerning all aspects of the custody
situation. The Conciliator discussed with the parties the importance of
developing, through counseling if necessary, at least minimal communication
and cooperation for the Child's benefit. other related concerns were
discussed at the Conference including the importance of notifying the other
parent of any changes in address or telephone number and also scheduling a
weekly telephone call from the Child to the Mother.
4. Although the Mother appeared receptive to joint counseling, the
Father stated that he does not believe it is necessary for the parties to
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carmunicate. ouring the discussion for which arrangements were made for
the Child to contact the Mother by telephone on Wednesday evenings, the
Father became enraged, questioned the Court's authority to order him to
permit the telephone contact or to even participate in the Conciliation
Conference. When the Father became brash and began using obscene language,
he was escorted out of the conference roan by his attorney and the
Conference was terminated. It should be noted that the Father was advised
of his obligation as primary custodian to encourage and foster the
relationship between the O1ild and the Mother by both the Conciliator and
the Father's counsel repeatedly.
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5. While there did not appear to be a basis for a contempt finding at
the Conference on the allegations raised in the Mother's Petition, the
Father's conduct and attitude toward the custody situation at the
Conference raised concerns and in the event that an additional Petition is
filed by the Mother in the future, it may be appropriate for the Court to
address the issues directly.
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6. The Conciliator recomr.ends an Order in the form as attached. It
should be noted that the Father objected to the reconmendation of a weekly
telephone call from the O1ild to the Mother.
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plaintiff/Respondent
IN THE CXlURT OF o:JMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs.
: NO. 98-59
CIVIL TERM
:
ELORIA ANNE'lTE RCXo1O-DEWALT,
Defendant/Petitioner
: CIVIL ACTION - LAW
: IN CUSTODY
aIDER OF CXXlRT
AND toi, this Z-!
consideratioo of the attached
and directed as follows:
day of Y""~ , 2000, upon
CUstody Conciliation Report, it is ordered
1. The prior Orders of this Court dated February 18, 1998 and
September 16, 1999 shall continue in effect as modified by this Order.
2. Each party shall notify the other parent in writing of any
change in his or her current residential address or telephone number.
3. i't1e Father shall ensure that the Child contacts the Mother
by telephone every Wednesday between 7:30 p.m. and 8:30 p.m. The Father
shall not interfere in or remain on the line during the conversation
between the Mother and Child.
4. The Father shall take all steps necessary to encourage and
foster a loving relationship between the Child and the Mother. Neither
party shall do or say anything which may estrange the Child from the other
parent, injure the opinion of the Child as to the other parent, or hamper
the free and natural development of the Child's love and respect for the
other parent. Both parties shall ensure that third parties having contact
with the Child comply with this provision.
BY THE CXlURT,
L
J.
cc: Michael J. Hanft, Esquire - Counsel for Father
Karl E. Rominger, Esquire - Counsel for Mother
KEITH EDWARD CORN
PLAINTIFF
V.
ELORlA ANNETIE ROMO-DEW AL T
DEFENDANT
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
98-59 CIVI L ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Wednesday, June 20, 200t , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanlcsburg, PA t70SS on Thursday, July 12, 2001 at 1:00 p.m.
for a Pre-Hearing Custody Conference. At such confcrcncc, an effort will be madc to resolve the issucs 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 prescnt at thc conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The eourt hereby directs the parties to furnIsh any and ail existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: Isl
Dawn S. Sunday. Esq./J(/
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the
Amcricans with Disabilites Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our office.
All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must
attend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATI'ORNEY AT ONCE. IF YOU DO NOT
HAVE AN A Tl'ORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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KEITH EDWARJl CORN,
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: IN THE COURT OF COMMON I'LEAS OF
: CUMnERLANI) COUNTY, I'ENNSYLVANIA
: CIVIL ACTION
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ELORlA ANNETTE ROMO-DEW AI. T : No, 98-59 CIVIL
DefendantlPetltloner : IN CUSTODY
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ORDER OF COURT
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AND NOW, this _ day of
, 200 I, a Contempt hearing is scheduled
in Courtroom #
at
o'clock _m. on the
, day of
,2001,
at the Cumberland County Courthouse, at Carlisle, Pennsylvania.
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Distribution:
Karl E. Rominger, Esquire
Michael J. Hanft, Esquire
19 Brookwood Avenue
Carlisle, PA 17013
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KEITH EDWARD CORN,
PlalntlfflRespond~nt
: IN TilE COUIn' OF COMMON I'LEAS OF
: CUMIIERLANJ) COUNTY,PENNSYLV ANIA
: CIVIL ACTION
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ELORIA ANNETTE ROMO-DEW AI. T : No. 98-59 CIVIL
DefendantlPetltloner : IN CUSTODY
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PETITION FOR CONTEMPT
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AND NOW, comes Eloria Annette Romo-Dewalt by and through her counsel, Karl E.
Rominger, Esquire and Petitions this Honorable Court to find the Plaintiff, Keith Edward Com, in
Contempt of a Modified Custody Order for the following reason:
I. Petitioner has not been allowed to exercise her custodial rights as outlined in
the Modified Custody Order previously put in place by the Honorable Judge Kevin A. Hess dated
March 9, 2000, and attached hereto as Exhibit "A".
2. In particular, Petitioner has been denied her rights under the Order in that:
A. Child is not ealling every Wednesday.
B. Petitioner had 110 visitation on Mother's Day.
C. Child does not have medications with hirn on overnight visits.
D. Child does not call at any time to speak to the Mother.
E. Father's wife interposes herself into the relationship between child and
Petitioner.
F. Father has given Mother no medical information 01' the name of any doctors or
other care givers.
G. Father has failed to utilize Mother as the first choice baby sitter when needed.
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3. Contempt is a necessary remedy Biven Fathcr's contcmptuous behavior at the
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last conciliation. (See Exhibit "A")
4. The Father is willfully failing to foster the Mother's relationship with the child.
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WHEREFORE, Petitioner requests that this Honorable Court schedule a hearing to find
the Plaintiff in Contempt of a Court Order and grant all proper and just relief, including granting
Petitioner primary physical custody pending further Order of Court.
. ,',1',',
Respectfully submitted,
c:.~<)0/
Eloria Annette Romo- alt
~~
~
':f'
Karl E. Rominger,Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 8 I 924
Attorney for Petitioner
Date: June 14,2001
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KEI'r11 EDWARD CORN,
plaintiff/Respondent
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IN 'l'IIE COUR'r OF aJMMON PLEM OF
CUMBERLAND COUN1~, PENNSYLVANIA
.
.
vs.
NO. 98-59
CIVIL TERM
ELORIA ANNETTE RaMO-DEWALT,
Defendant/Petitioner
CIVIL ACrION - LAW
IN CUSroDY
,
"
PRIOO JUDGE: Kevin A. /less
CUSIOOY CXH::ILIATICN SUHI1I\RY REl'CRl'
,
IN AccnmANCE WITH CU1BERLAND CXXIlTY RULE OF CIVIL l'IlU.:IlIJlRE
1915.3-8, the undersigned CUstody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
NAME
DATE OF BIRTII
CURREN.rLY IN CUSTODY OF
Coda Zandar Ramo
October 30, 1993
Father
2. A Conciliation Conference was held on February 21, 2001, with the
following individuals in attendance: The Father, Keith Edward Corn, with
his counsel, Michael J. Hanft, Esquire, and the Mother, Eloda Annette
Romo-DeWalt, with her counsel, Karl E. Rominger, Esquire.
3. This Court previously entered Orders in this matter on February 18,
1998 and September 16, 1999 under which the Father had primary physical
custody of the Olild and the Mother had partial custody on alternating
weekends from Friday through Sunday. All exchanges of custody were to take
place at the North Middleton TOwnship Police Department. The Mother filed
this Petition for Contempt alleging that she had been denied custody in
violation of the existing Order. It became clear at the Conference that
the circumstances leading to the allegations in the Mother's Contempt
Petition arose primarily due to the parties complete inability to
communicate directly with each other concerning all aspects of the custody
situation. The Conciliator discussed with the parties the importance of
developing, through counseling if necessary, at least minimal communication
and cooperation for the Child's benefit. Other related concerns were
discussed at the Conference including the importance of notifying the other
parent of any changes in address or telephone number and also scheduling a
weekly telephone call from the Child to the Mother.
4. Although the Mother appeared receptive to joint counseling, the
Father stated that he does not believe it is necessary for the parties to
. .
COl1Tl1unicate. During the discussion for which arrangements were made for
the Child to contact the Mother by telephone on Wednesday evenings, the
Father became enraged, questioned the Court's authority to order him to
permit the telephone contact or to even participate in the Conciliation
Conference. When the Father became brash and began using obscene language,
he was escorted out of the conference room by his attorney and the
Conference was terminated. It should be noted that the Father was advised
of his Obligation as primary custodian to encourage and foster the
relationship between the Child and the Mother by both the Conciliator and
the Father's counsel repeatedly.
5. While there did not appear to be a basis for a contempt finding at
the Conference on the allegations raised in the Mother's Petition, the
Father's conduct and attitude toward the custody situation at the
Conference raised concerns and in the event that an additional Petition is
filed by the Mother in the future, it may be appropriate for the Court to
address the issues directly.
6. The Conciliator recOl1ll1ends an Order in the form as attached. It
should be noted that the Father objected to the recommendation of a weekly
telephone call from the Child to the Mother.
-
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Dawn S. Sunday, Esquire 'j
CUstody Conciliator
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KEITH EDWARD roRN,
Plaintiff/Respondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs.
NO. 98-59
CIVIL TERM
.
.
ELORIA ANNETrE ROMO-DEWALT,
Defendant/Petitioner
CIVIL ACTION - LAW
: IN CUSTODY
aIDER OF CXlUR'l'
AND ~, this ,{.nd.
consideration of the attached
and directed as follows:
, 2000, upon
it is ordered
1. The prior Orders of this Court dated February lB, 199B and
September 16, 1999 shall continue in effect as modified by this Order.
2. Each party shall notify the other parent in writing of any
change in his or her current residential address or telephone number.
3. The Father shall ensure that the Child contacts the Mother
by telephone every Wednesday between 7:30 p.m. and B:30 p.m. The Father
shall not interfere in or remain on the line during the conversation
between the Mother and Child.
4. The Father shall take all steps necessary to encourage and
foster a loving relationship between the Child and the Mother. Neither
party shall do or say anything which may estrange the Child from the other
parent, injure the opinion of the Child as to the other parent, or hamper
the free and natural development of the Child I S love and respect for the
other parent. Both parties shall ensure that third parties having contact
with the Child comply with this provision.
BY THE COURT,
J.
cc: Michael J. Hanft, Esquire - Counsel for Father
Karl E. Rominger, Esquire - Counsel for Mother
SFP
KEITH EDWARD CORN,
Plainti IT
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v
ELORIA ANNETTE ROMO-DEW ALT,
Defendant
NO. 98-59 CIVIL
IN CUSTODY
COURT ORI>ER
AND NOW, this /t..,rf..-day of September, 1999, upon consideration of the atlllched Custody
Conciliation Report, it is ordered and directed as follows:
i. lilis Court's Order of February 18, 1998 is ratified subject to the modifications as
set forth below.
2. Paragraph 7 of the February 18, 1998 Order is modified such that exchange of
custody for the minor child shall take place at the North Middleton Township Police
Department. Either parent or their new spouse may deliver or pick up the child with
the arrangement at the Police Station.
3. After the parties have exchanged custody at the Police Station for three (3) separate
occasions and in the event the Mother at that time feels that the Police Station is not
an appropriate place for exchange of custody, counsel for the Mother may petition
the court directly for the scheduling of a short hearing to address the sole issue of the
place of exchange of custody.
4. In light of the fact that the parties share legal custody of the minor child, the Father
is specifically diree:ed to share with the Mother all information in advance
conceming the child's schooling, health issues and all other related matters. Mother
shall be given the names, addresses and phone numbers of all physicians and this
order hereby authorizes all school officials and medical personnel to deal with the
Mother concerning any and all information of the minor child and to release to the
Mother any and all documentation concerning the minor child.
5. While the child is in the custody of the Mother, the Mother shall ensure that the child
has his own separate bedroom or, in the ahemative, sleeps in a bedroom with same
sex children.
BY THE COURT,
cc:
Thomas Williams, Esq.
Joan Carey, Esq.
,..,1 7d,<;~ {~. J..k~ J.
Kevin A. Hess .
;':",;:: ,:"'''f i;:"'I~.l RECORD
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EXHIBIT "A"
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IN TIlE COURT OF COMMON PLEi\S OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 98-59 CIVIL
IN CUSTODY
KEITH EDWARD CORN,
Plnintiff
ELORIA ANNElTE ROMO-DEW ALT,
Defendant
Prior Judge: Kevin A. I.less
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the following report:
I. The pertinent information pertaining to the child who is the subject of this litigation is as
follows:
Coda Zondar Romo, bom October 30, 1993.
2. A Conciliation Conference was held on September 10, 1999, with the following individuals
in attendance:
The Father, Keith E. Corn, with his counsel, Thomas Williams, Esquire; and the Mother,
Eloria A. Romo-Dewalt, with her counsel, Joan Carey, Esquire.
3. The parties are before the Conciliator on a variety of issues. It is crystal clear to the
Conciliator that the parties equally are unable to work with or communicate with the other
parent. The parties are having a problem with exchange of custody. The police have been
involved in exchange of custody at least 1-5 times over the past eighteen months. The
Father suggests an exchange of custody at the police station bused upon a suggestion made
by the police. The Mother, who does not have a license, suggested that this may be a
problem. The Conciliator notes that the Mother lives approximately five minutes from the
North Middleton Township Police Department and that her eUITent husband has a CUITent
driver's license.
4. Bused upon the information at the Custody Conciliation Conference, the Conciliator
reeommends an the entry of an order in the form as attached.
~
KEITH EDWARD CORN,
Plaintiff
.
.
IN THE: COURT .OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
.
NO. 98-59 CIVIL TERM
CIVIL ACTION - LAW
va.
ELORIA ANNETTE RCXolO
Defendant
.
.
.
.
IN CUSTODY
OODER OF COORT
AND tOl, this 13tJ~ day of ~..llll.f/Ll4- ' 1998, upon
consideration of the attached Custody ConcJ.liatJ.on '-Report, it is ordered
and directed as follows:
1. The Father, Keith Edward Corn, and the Mother, Eloria Annette
Romo, shall have shared legal cutody of Coda Zandar Romo, born October 30,
1993.
2. The' Father shall have primary physical custody of the Child.
3. The Mother shall have partial physical custody of the child on
alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m.,
beginning February 13, 1998 and at such other times as mutually agreed upon
by the parties.
4. . The parties shall share or alternate having custody of the Child
on holidays as follows:
A. CHRISTMAS: In every year, the Father shall have custody of'
the Child from Christmas Eve at 2:00 p.m. until Christmas Day
at 2:00 p.m. and the Mother shall have custody of the child
fran Christmas Day at 2:00 p.m. until December 26 at 2:00 p.m.
B. THANKSGIVING: In every year, the Mother shall have custody of
the Child from Thanksgiving Day at 6:00 p.m. until the
following Friday at 6:00 p.m. The Father shall h"ve cllstody
of the Child until 6:00 p.m. on Thanksgiving Day..
C. EASTER: In every year, the Father shall have custody of the
Child on Easter Sunday until 2:00 p.m. and the Mother shall
have custody of the Child from 2:00 p.m. until 6:00 p.m.
D. MOTHER'S DAY/FATHER'S DAY: The Mother shall have custody of
the Child every year on Mother's Day from 2:00 p.m. until 6:00
p.m. and the Father shall have custody of the Child every year
on Father's Day from 2:00 p.m. until 6:00 p.m.
E. The Mother shall have a period of custody on other holidays,
not otherwise mentioned in this Order, and the Child's
birthday as arranged by mutual agreement of the parties.
5. The Mother shall have cllstody of the Child during the summer
vacation in each year for two non-consecutive 9-day periods to include two
weekends, upon providing thirty (30) days advance notice to the Father.
6. The parties shall inform each other promptly of any changes to his
or her address or telephone number.
7. The parties shall share transportation for exchanges of custody
under this order.
8. In the event the Father requires childcare for the Child, other
than the Child's regular attendance at the YMCA Daycare Program, the Father
shall first provide the Mother with the opportunity to provide the care
before contacting other third party babysitters.
9. This order is entered pursuant to an agreement of the parties at a
Custody conciliation Conference. The partie~ may modiiy che prOvisions of
this order by mutual consent. In the absence of mutual consent, the terms
of this order shall control.
BY THE COURT,
/ ,..,} -I4.t-";',~ C(. ~~
cc: Thomas J. williams - Counsel for Father
Joan Carey, Esquire/Jennifer Gutshall - Counsel for Mother
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KEITIl EDW^RO' CORN,
Plainti~f
: IN 'l'IIE COURT 01" COMMOO PLEAS O\>
CUMBERLAND COUN'l~, PENNSYLVANI^
vs.
: NO. 98-59
CIVIL TERM
ELORIA ANNETTE ROOD,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
CUS'l'ODY COOCILIATIOO stM1I\Ry REPOOT
IN 1\CCOlUlI\NCE wrrll ctJolBti1UJINl) cnJN'I.Y mILE OF CIVIL t.'~WRB
1915.3-8, the undersigned CUstody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the
subject of this litigation is as follows:
NAME
DATE OF BIRTII
CURRFNl'Ly IN CUS'l'ODY OF
Coda Zandar Romo
October 30, 1993
plaintiff/Father
2. A Conciliation Conference was held on February 12, 1998, with the
following individuals in attendance: The Father, Keith Edward Corn, with
his counsel, Thomas J. Williams, Esquire, and the Mother, Eloria Annette
Romo, with her counsel, Joan Carey, EsqUire and Jennifer Gutshall.
3. The parties agreed to entry of an Order in the form as attached.
h--bm
Date 0.0
Ie}.. 1998-
.
lO~~
Dawn S. Sunday, Esquire
Custody Conciliator
. '
,. ;
KEITH EDWARD CORN,
Plaintiff/Respondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION
,
v,
ELORlA ANNETTE ROMO-DEW AI. T : No. 98-59 CIVIL
, , DefendantlPetitioner: IN CUSTODY
,
. I
,,,.1.
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CERTIFICATE OF SERVICE
I, Karl E. Rominger, Esquire, attorney for Eloria Annette Romo-Dewalt, do hereby certifY
that I this day served a copy of the within Petition for Contempt upon the following by depositing
same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as
"
follows:
Michael J. Hanft, Esquire
19 Brookwood Avenue
Carlisle, PA 17013
~~
Karl E. Rominger, Esquire
Dated: June 14,2001
Keith E. Corn,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
vs,
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 98-59 CIVIL TERM
Eloria A, Romo,
Defendant/Petitioner
CUSTODY
ORDER
AND NOW, t his
day of
, 1998. upon
consideration of the attached Petition for Special Relief, the
North Middleton Police Department is ordered to enforce this
Court's Order of February 18. 1998, by facilitating the transfer
of custody to the mother, Eloria A, Romo, on Friday, March 27,
1998, and alternating weekends thereafter throughout May 1998,
By the Court,
Kevin A. Hess, Judge
Thomas J, Williams
Attorney for Plaintiff/Respondent
Joan Carey
Attorney for Defendant/Petitioner
Keith E, Corn,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS,
NO. 98-59 CIVIL TERM
Eloria A. Romo,
Defendant/Petitioner
CUSTODY
RULE TO SHOW CAUSE
AND NOW, this 'Z,,:!-' day of
/?'I n,e. (. 1-/
, 1998, upon
consideration of the attached Petition for Special Relief, a Rule
is entered on the plaintiff/respondent, Keith E. Corn, to show
cause why the relief requested should not be granted, The Rule
...,o~
is returnable on the J day of
,'f 1>t'v'\o'\.
..... ". t't1..1-f
, 1998, at a
By the Court,
IL
Judge ,
Thomas J, Williams
Attorney for Plaintiff/Respondent ",-Ml....d ^1,,\.u,ll'~Ir;~
Joan Carey
At torney for Defendant/Pet it ioner -lY"'lbCN~h.,,\.....J '~/nl'/II
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Keith E, Corn,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 98-59 CIVIL TERM
Eloria A. Romo,
Defendant/Petitioner
CUSTODY
PETITION FOR SPECIAL RELIEF
The defendant/petitioner, Eloria A. Romo, by and through her
attorney, Joan Carey of Legal Services, Inc., states the
following:
I. The defendant/petitioner, Eloria A. Romo, hereinafter
referred to as the mother, resides at 445 Longs Gap Road,
Carlisle, Pennsylvania,
2, The plaintiff/respondent, Keith E. Corn, hereinafter
referred to as the father, resides at 230 Union Hall Road,
Carlisle, Pennsylvania.
3, The parties are the parents of Coda Zandar Romo (DOB
10/30/93), hereinafter referred to as the child, The child
currently resides with the father at 230 Union Hall Road,
Carlisle, Pennsylvania,
4. A Custody Order was entered on February 18, 1998, which
granted primary physical custody of the child to the father and
partial custody to the mother including alternate weekends from
Friday until Sunday. A certified copy of the Order is attached
as Exhibit A and incorporated herein by reference.
5, The father has violated the terms of the Custody Order
in ways including, but not limited to, the following:
a' On or about February 27, 1998, the child had a 102
degree temperature; therefore, by agreement, the mother
did not get the child on Friday for her period of
custody. However, when the mother called the father on
the following Sunday to request a make up visit and
inform him of her new address, the father hung up the
telephone making it impossible for her to arrange to
see the child,
b, On or about March 14, 1998, the father refused to
allow the mother to exercise her weekend period of
custody and hung up the phone on her when she attempted
to make the custody arrangements.
c. On several occasions, the mother attempted to
contact the father by paging him and he has refused to
return her calls. On or about March 23, 1998, the
mother again tried to make contact with the father, but
the telephone number had been disconnected,
d. Since February 17, 1998, the father has denied the
mother all contact with the child in spite of attempts
by the mother herself and through counsel for the
parties.
6, Thomas J. Williams, the father's attorney of record,
was informed of the filing of this petition for contempt,
WHEREFORE, the defendant/petitioner asks that a contempt
hearing be scheduled and that the plaintiff/respondent be held in
contempt of the Custody Order, and that this court take whatever
measures are necessary, including fines and/or imprisonment, to
;:1
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\
enforce the Court's Order of February 18, 1998.
The defendant/petitioner requests that the Court order the
North Middleton Pollee Department to enforce Its Order of
February 18, 1998,
The defendant/petitioner requests any other relief which
Is just and proper,
Respectfully submitted,
h:(.,~~
Attorney for Plaintiff
Legal Services, Inc.
a Irvine Row
Carlisle, PA 17013
(717) 243-9400
I
J
The above-named plaintiff, Elorla A, Romo, verifies that the
statements made in the above Petition are true and correct. The
plaintiff understands that false statements herein are made
subject to the penalties of 18 PA. C,64904 relating to unsworn
falsification to authorities,
'f7}J/2tJ;) ~0 /,97'8
Date
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Romo , i a i n tiff
.
(,
KEITH EDWARD CDRN,
Plaintiff
: IN 'l'IIE CXlURT OF CXJoIltIOO PLEAS OF
: ctlMBERIJIND CXllN'l'I , PENNSYLVANIA
:
va.
: 00. 98-59 CIVIL TERM
: CIVIL ACl'Ial - LAW
ELORIA ANNtTrE Ra10
Defendant
.
.
: IN CUS'roOlC
aIDER (R CXllRr
AND tuf, this , gt/1. day of
consideration of the attached CUstody Cone
and directed as follows:
, 1998, upon
t is ordered
1. 111e Father, Keith Edward COrn, and the Mother, Eloria Annette
RatIO, shall have shared legal cutody of COda Zandar RatIO, born October 30,
1993.
2. 111e Father shall have primary physical custody of the Child.
3. 111e Mother shall have partial physical custody of the Child on
alternating weekends !ran Friday at 6:00 p.m. until sunday at 6:00 p.m.,
beginning February 13, 1998 and at such other times as mutlJally agreed upon
by the parties.
4. 111e parties shall share or alternate having custody of the Child
on holidays as follows:
A. CHRIS'l'MAS: In every year, the Father shall have custody of
the Child from Chrisbnas Eve at 2:00 p.m. until Chdsbnas Day
at 2:00 p.m. and the Mother shall have custody of the Child
fran Chrisbnas Day at 2:00 p.m. until Decenber 26 at 2:00 p.m.
B. THANKSGIVING: In every year, the Mother shall have custody of
the Child from 111anksgiving Day at 6:00 p.m. until the
following Friday at 6:00 p.nt. 111e Father shall have custody
of the Child until 6:00 p.m. on 'lhanksgiving Day..
C. EASTER: In every year, the Father shall have custody of the
Child on Easter sunday until 2:00 p.m. and the Mother shall
have custody of the Child fran 2:00 p.m. until 6:00 p.m.
D. MOl'IlER'S DAY/FATHER'S DAY: The Mother shall have custody of
the Child every year on Mother's Day fran 2:00 p.m. until 6:00
p.m. and the Father shall have custody of the Child every year
on Father's Day from 2:00 p.m. until 6:00 p.m.
E. The Mother shall have a period of custody on other holidays,
not otherwise mentioned in this Order, and the Child's
birthday as arranged by mutual agreement of the parties.
5. 111e Mother shall have custody of the Child during the SUlIIl1E!r
EXHIBIT A
(
(
vacation in each year for two non-consecutive 9-day periods to include two
weekends, upon providing thirty (30) days advance notice to the Father.
6. 'nle parties shall inform each other pranptly of any changes to his
or her address or telephone nurber.
7. 'nle parties shall share transportation for exchanges of custody
under this Order.
8. In the event the Father requires childcare for the Child, other
than the Child's regular attendance at the YMCA Daycare Program, the Father
shall first provide the Mother with the opportunity to provide the care
before contacting other third party babysitters.
9. 'nlis Order is entered pursuant to an agreement of the parties at a
CUstody Conciliation Conference. !DIe parties may modify the provisions of
this Order by mutual consent. In the absence of mutual consent, the terms
of this Order shall control.
BY THE CXlURT,
/01 ~'>V ct. ~
co: 'nlanas J. Williams - Counsel for Father
Joan carey, Esquire/Jennifer Gutshall - Counsel for Mother
-.....; r;,.,py FROM RECORD
I" , ' ..,'.,r, I here unto ~:t my hamf
;., ' ..,. .' :. :. 3cid Court at Carlisle, Pa,
TIi,J ...,I.,.'?:!!:: day of...~~:..., 19j8:,
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KEI'1'II EDWARD CX>RN,
Plaintiff
IN TilE COURT r>>' ~ PLEAS OF
CUMBERLAND c:xJIIffi, PENNSYT.VANIA
vs.
NO. 9B-59
CIVIL TERM
ELORIA ANNE.T1'E ROOO,
Defendant
CIVIL ACTION - LAW
IN CUsroDY
amoolC <XH:ILIATIm ~ RBPmT
IN AlXDlDl\NCB lf1'1'II <nmERLAND CXXNl.Y RULE a! CIVIL PlIO ."" ".am
1915.3-8, the undersigned CUstody Conciliator submits the following report:
1. The pertinent information concerning the Olild who is the
subject of this litigation is as follows:
NAMB
Dl\TE OF BIRl'H
CURRERl'Ly IN ~.L\.U~ OF
Coda Zandar Rano
October 30, 1993
plaintiff/Father
2. A Conciliation Conference was held on February 12, 1998, with the
following individuals in attendance: The Father, Keith Edward Corn, with
his counsel, Thanaa J. Williams, Esquire, and the Mother, Eloria Annette
Rano, with her counsel, Joan Carey, Esquire and Jennifer Gutshall.
3. The parties agreed to entry of an Order in the form as attached.
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CUstody Conciliator
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Keith E. Corn,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
vs,
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 98-59 CIVIL TERM
Eloria A. Romo,
Defendant/Petitioner
CUSTODY
PRAECIPE TO WITHDRAW ACTION
On March 27, 1998, the respondent made the parties' minor
child available for the petitioner's weekend period of custody
pursuant to the Court Order of February 18, 1998, The parties
discussed their differences and agreed that neither would proceed
with any litigation at this time. Therefore, the petitioner
requests that her Petition for Special Relief (Contempt) filed on
March 27, 1998, be withdrawn without prejudice to file another
Petition regarding the same issues and incidents if the
respondent fails to abide by the Court Order in the future,
To Curt Lon!'!
Prothonotary
1998
q~!" ~~
ttorney for Defen ant/Petitioner
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KEITH EDWARD CORN,
Plaintiff
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 98- S'9 C! ,'uil <-rc12..fY')
,
I
v.
ELORIA ANNETTE ROMO
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this -B.. day of. h) '(\"119~ upon consideration of the allaehcd Complaint,
it is hereby direeted that the parties and their respective counsel appear before
t'a\... f\.s ",," ~ 184 " thc cone ilia tor, at ,~Cl \,..J , lliLC\ ...S\-'" Kfd'CN (s.~ I 'PA.
on the \0 day of R- \---r\ )rI (" "I- ' 19J& at 1\: c)Cl Q,m. for a Pre-Hea~
Custody Conference. At such conference, an effort Will be made to resolve the Issues In dispute; or
if this carmot be accomplished, to define and narrow the issues to be heard by the Court, and to enter
into a temporary order. All ehildren age five or oldcr may also be present at the conferenee. Failure
to appear at the conference may provide grounds for entry of a temporary or permanent order.
FOR THE COURT,
By: c-t'\o q ili\ J), J\ um<r\(\LA" ,& .
Custody Conciliator ~
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.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO
NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
Fourth Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
Telephone (717) 240-6200
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IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 98- S'i' C'0ll '-R.,J..rf\,
KEITH EDWARD CORN,
PllIinlilT
ELORIA ANNETTE ROMO
Defendant
IN CUSTODY
PLAINTIFF'S COMPLAINT TO CONFIRM CUSTODY
I. Plaintiff is Keith Edward Corn, an adult individual currcntly residing at 230 Union
Hall Road, Carlisle, Cumberland County, Pennsylvania.
2. Defendant is E10ria Annette Romo, an adult individual with a mailing address of 614
North Hanover Street, Carlisle, Cumberland County, Pennsylvania, whose actual residence is
unknown to Plaintiff.
3. Plaintiff seeks custody of the child, Coda Zandar Romo, who was born on October
30, 1993.
The ehild was born out of wedlock.
Since the child's birth, the ehild has resided with the following persons at the following
addresses for the following periods of time:
Since the child's birth on October 30, 1993 until June 1997, the child has resided with the
parties of this action at undisclosed addresses in Central Pennsylvania, including foster care
arrangcd by York and Adams County Child & Youth Services.
From June 1997 through September 1997, the parties lived at a trailer on Middle Road in
Newville, Pennsylvania.
From September through December 1997, the parties lived together in a farmhouse on North
Middlcton Road, Carlisle, Pennsylvania.
Since December 15, 1997 until the present, Plaintiff and the child has resided at 230 Union
Hall Road, Carlisle, Pennsylvania with Plaintiffs wife.
4. The relationship of the Plaintiff to the child is that of father. He is married and
living separately. The Plaintiff currently resides with the following:
Nmlli: Relationship
Cynthia Com Wife
Coda Zandar Romo Son
5. The relationship of the Defendant to the child is that of mother. She is single and
living separately. The Defendant currently resides with the following:
~ Relationship
Unknown
6. The parties have not participated in previous litigation conceming the custody of the
child; however, there were dependency proceedings in Adams County, at JC-96-49-1, copies of the
most recent Orders are attached.
The Plaintiff has no information of a custody proceeding concerning the ehild pending in any
other court.
7. The best interest and permanent welfare of the child will be served by granting
custody to Plaintiff because: Plaintiff is best able to provide a stable, loving, nurturing environment
for his son.
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 time and place for a hearing
at which Plaintiff requests the Court to grant hirn the Custody Order. Pending said hearing, Plaintiff
requests temporary custody.
By -rL- ? ivJi ~
Thomas J. Williams, Esquire
Ten East High Street
Carlisle, PAl 70 I3
(717) 243-3341
MARTSON, DEARDORFF, WILLIAMS & OTTO
Attorneys for Plaintiffs
Date: January 6, 1998
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IN THE COURT OF COMMON PLEAS, ADAMS COUNTY, PENNSYLVANIA
JUVENILE
I In the klterest 01:
I CODA ROMO
.
JC.
.Q6
ORDER OF COURT
AND NOW this 11th day 01 Marth, 1996, the child, age 2, and his mother appeared,
IS
lhe childs father is Incarcerated In a state correctional instftutlon. h Is alleged that the child
7
was left unattended for a significant period '01 time considering his age. Mother Is 011
· probation for a charge 01 Reckless Endangennent 01 the same child. Based ~
9 representations by the agency, the Court detenniles that II would be contrary to the childs
10 weMare to be retumed to his mother at this tine and that reasonable efforts have not
n
5
prevented the need for placement, Mother stated she Is not opposed to placement at this
IZ time, Temporary legal and p/lyslcal custody Is awarded to Adams County ChIldren and
II Youth Services. That agency may also authorize medical selVices for the child. An
14 AdjudlcallonHeerlng IsscheduledfOl' March 19, 1996,811:00 P.M,
15 Adams County Children and Youth Services shall give notice to aU Interested
lIS
persons,
17
II
19
10
lhe Public Delende~s OffICe shall provide legal representation for the child,
Parents are notified they have the right to be represented in these proceedings by a
lawyer. M a lawyer Is desired and parents cannot afford to hire OI1e, a Iawyor will be
appointed 011 proper application to represent parents free of charge. M parents have trouble
obtaining a lawyer, they may contact the Court Aaninlstrator at the Adams County
Courthouse, 111 Ba~imore Street, Gettysburg, PA 17325, telephone (717)334-6781 Ext.
213.
II
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15
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20
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F~
"~1 {,)..tT"')~T
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IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA
Juvenile
In the interest of
JC-
Coda Romo
ORDER OF COURT
AND NOW, this 19th day of March, 1996, the
child appeared with counsel. Mother appeared with
counsel. Father appeared pro se. Both mother and father
have agreed that if this case were to proceed to hearing,
the agency could and would prove by clear and convincing
evidence that the child has lacked proper parental
guidance, care and control, and that no such guidance,
care and control is presently available,
The child, through coun~el, has admitted the
allegations of the petition. Based upon these
stipulations or agreements, the Court finds the facts in
the petition to be true by clear and convincing evidence.
The child is adjudicated dependent,
The Court finds that reasonable efforts could
. .
not have prevented the need for placement and that it
would be contrary to the child's welfare to place him with
either parent.
Father is presently in jail, Mother is
presently faced with probation violation charges and
reckless endangerment charges in Adams County.
.
1 Temporary legal and physical custody shall be
2 exercised by Adams County Children and Youth Services,
3 The child shall remain in agency foster care.
4 The long term permanency plan in this
5 particular case is:
6
A. An investigation into the suitability of a
7 family member and possible placement for a temporary
8 period of time with that family member, and
9
B. A return of custody to mother and/or
10 father.
11 Costs of this proceeding shall be paid by the
12 County of Adams.
13 BY THE COURT,
14
15
16 Chester G. Schultz, Esq.
David K. James, Esq.
17 Roy A. Keefer, Esq.
rhk
Oscar F. Spicer, P.J.
18
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\
\1
\
,
VERIFICATION
The foregoing Complaint to Confirm Custody is based upon infonnation which has been
gathered by my counsel in the preparation of the lawsuit. The language of the document is that of
counsel and not my own. I have read the Complaint and to the extent that the document is based
upon information which I have given to my counsel, it is true and correct to the best of my
knowledge, information and belief. To the extent that the content of the document is that of counsel,
I have relied upon counsel in making this verification,
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities, which provides that if I make knowingly false
avennents, I may be subject to criminal penalties.
~:I ( er~/11
eith Edward Corn