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HomeMy WebLinkAbout98-00961CA r4 'i h 1 rO' C S .' ~i ,i , , ~" ;` ~; ',. .. _. 1.: 'ir ;r- t, '` dlKw•9R~: VIN'"~71t•~ VR(Vltr: VItY.7M.: Vlk'?71N •;rl+:: ,~"qK. `.~.; '.~.:: ,;Ilf;'•71~:: VIP%7( IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE QF PENNSYLVANIA ~. SUSAN P:,. ARMOI,1', II 98 - 961 Civil N r> . ........................ ................. 19 li SN DIVORCE DECREE IN DIVORCE ANDNgW,, ,.V,,~!~t~!ti'-,,,,~1,,,., tq,9~, it is ordered and decreed that . , sosAN E. ARMOLT ........................... .................. plaintiff, and ~ . .. , .. , , , , , RICKY L. ARMOLT ........................................... defendant, are divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; NONE. The terms of tho Mtarital Settlement Agreement dated July 9, 1998 .are , incor>rvraced, .but . Pot. mexeed, , ~.nkV. this. PA,oxee,., , . . . .... . . . .. . . .~~1~ ..................... ~' ~. dy The Co r." ;- `~-'~. . 1 _...../......._ ............. tte~t~ ~tcZlca' ~'~.;4%ri~ , ,.i(cri~~ J. } .. ~Proth....t......... ~ qe wr eta ~ blu ~aa: ~ «a .o~ aw as aw ono ary ~ ali~ato-_ ae:-;a, ~x<:atx:«. ;;,o-;,;,e, ~; ~ ~.~-. 3 y} ,w: «. ,~: k~ 9 MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT made this ~ day of , 1998, by tmd between SUSAN E. AI2MOLT, (hereinafter referred to as "WIF+") and RICKY L. ARMOL'P, (hereinafter referred to as "HUSBAND"). WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully married on May 28, 1988, in the Carlisle, Pennsylvania, and ware separated on January 17, 1998. WIFE filed a Complaint in Divorce in Cumberland County, Pennsylvania, docketed at 98-961 Civil Term on February 16, 1998. The parties hereto agree and covenant as follows; The parties intend to maintain separate and permanent domiciles and to live apart from. oach other.. It is the intent and purpose of this Agreement to set forth the respective rights and duties of the parties while they continue to live apart from each other. 2. The parties have attempted to divide their matrimonial property in a manner which conforms to a just and right standard, with due regard to the nghts of each party. It is the intent of the parties that such division shall be final and shall forever determine their respective rights. The division of existing tnnrital property is not intended by the pasties to constitute in any way a sale or exchange of assets, 3, Further, the parties agree to continue living separately and apart f'rorn the other at any place or places that he or she may selert as they hove heretofore been doing. Neither party shall molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever. Each party may carry on and engage in uny employment, profession, business or other activity as he or she may deem advisable foe his or her sole use and benefit. Neither party shall interfere with the uses, ownership, enjoyment or disposition of any property now owned and not specified herein or property hereafter acquired by the other. 4. The consideration for this contract and agreement is the mutual benefit to be obtained by both of the parties hereto and the covenants and agreements of each of the parties to the other. The adequacy of the consideration for all agreements herein contained is stipulated; confessed, and admitted by the parties, and the panics intend to be legally bound hereby. Each party to the Agreement acknowledges and declares that he or she, respectively, (1) is represented by counsel of his or her own choosing; (2) is fully and completely informed of the facts relating to the subject matter of this Agreement and of the rights and liabilities of the parties; (3) enters into this Agreemont voluntarily after receiving the advice of counsel; (4) has given careful and mature thought to the making of this Agreement; (S) has carefully read each provision of this Agrearnent; and (6) fully and completely understands each provision of this Agreement, both as to the subject matter and legal effect. This Agreement shall become effective immediately as of the date of execution. 2 5. !t is the purpose attd intent of this Agreement to settle forever and completely the interest and obligations of the parties in all property that they own separately, and all property that would qualify as marital property under the Pennsylvania Divorce Code, Title 23, Section 401(e), and that is referred to in this Agreement as "Mental Property", as between themselves, their heirs and assigns. The parties have attempted to divide their Marital Property in a manner that conforms to a just and fair standard, with due regard to the rights of each Party. The division of existing Marital Property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division is being effected without the introduction of outside funds or other property not constituting a part of the marital estate. It is the further purpose of this Agreement to settle forever and completely any obligation under the Petmsylvania Divorce Code relating to spousal support or alimony. 6, Each party represents and warrants that he or she has made a full and fair disclosure to the other of all of his or her property interests of any nature, including any mortgage, pledge, lien, charge, security irterest, encumbrance, or restriction to which any property is subject, Each party further represents that he or she has made a full and fair disclosure of all debts and obligations of any nature for which he or she is currently liable or may become liable. Each further represents and warrants that. he or she has not made any gifts or transfers for inadequate consideration of Marital Property without the prior consent of the other, Each Party acknowledges that, to the extent desired, he or she has had access to all joint and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during marriage. 3 7, REAL ESTATE; WIFE will convey her interest in the marital real estate located at 9 Kimberly Lane, Carlisle, Cumberland County, Pennsylvania 17013 to HUSBAND, HUSBAND will pay WIFE the sum of Seventy Six Thousand and no/100 ($76,000.00) Dollars in consideration for her interest in the tnarital property and other considerations contained in this Marriage Settlement Agreement. Said payment will be made within thirty (30) days of the execution of this Marriage Settlement Agreement by W[FE. 8. DEBTS: Hl15HAND will be solely responsible for his own debts. W]FE will be solely responsible for her debts. HUSBAND agrees to assume all liability for the funds borrowed by the parties from Richard E. Armolt and Ruth F. Armolt, the parents of HUSBAND. HUSBAND will provideareleasefromhisparentstoWlFE. HusaArtD will indemnify and hold WIFE Qt harmless on account oP any claim against her by Richard E. Armolt or lj~P Ruth F. Armolt. Rt. 9. SPOUSAL SUPPORT: It is the mutual desire of the parties that HUSBAND will not be required to pay support or alimony pendente life to the WIFE for herself. WIFE will not provide any financial support or alimony pendente life to the HUSBAND. The parties also waive any right they have to receive alimony payments from the other following the entry of the Divorce Decree in this matter. Any child support will be as ordered by the Cumberland County Office of Domestic Relations. HUSaAND's obligation for spousal support or alimony 5~i~ pendente life shall terminate the cuts oP the Decree in Divorce. ~~ HUSBAND agrees to pay the private school tuition for his children to attend St. Patrick's School in Carlisle, Pennsylvania. HUSBAND also agrees to cooperate with the application by his children for tuition benefits from his employer provided he is able to receive the income tax exemption for such child beginning in that year of application. a I o. PER50NAG PROPERTY: TYie parties agree that the personal property shall he divided as follows: HUSBAND shall receive the following items: a, The personal property in his possession. b, His bank accounts; c. Any life insurance policy; and d. Any employee benefits except that Hi1SBAND agrees to distribute from this TIAA/CREF Account the sum of Ten Thousand and no/100 ($10,000.00) Dollars inwaqualifiedplanofWlFE. nusenniD anall cooperate in the preparation and filing with the court of a Qualified Domestic 5`~ Relations Order to give effect t•o this transfer. which the aaV parties intend to be without tax consequences to either of t::e~. WIFE shall receive the following items: • a, The personal property in her current possession„ b. Her bank accounts; c. Any life insurance policy; and d. Her employee benefits and savings plan. e, The sum of Ton Thousand and no/100 (570,000.00) Dollars from HUSBAND'S TIAA/CREF Account which will be directly deposited into a tax qualified account established by WIFE. The WIFE hereby waives all right and title which she may have in any personal property of the HUSBAND. HUSBAND likewise waives any interest which he has in the personal property of the WIFE. Henceforth, each of the parties shall own, have and enjoy independently of any claim or right of the other party, all items of personal property of every kind, nature and description and wherever situated, which are then owned or held by or which may hereafter belong to the HUSBAND or WIFE with lull power to the HUSBAND or the WIFE to dispose of same as fully and effectually, in all respects and for all purposes as if he or she were unmarried. S Each party agrees that neither will incur obligations, liens or liabilities on account of the other and that from the date of this Agreement, neither party shall contract or incur obligations, liens or any liability whatsoever on account of the other. AUTOMOBILES: a.) HUSBAND agrees to waive any and all interest which he may have in the automobiles in possession of the WIFE. b,) WIFE agrees to waive any and all interest which she may have in the automobiles in possession of the HUSBAND. They each waive any claim which they have in any automobile owned by the other party, 12, INCOME TAX EXEMPTIONS: WIFE will be entitled to declare Benjamin Armolt, bom March lQ 1990,aatd Merideth Arntolt born April I, 1992~ns `Fier Federal mcomettaxbornR exemptions each year. BYgilultiplgX~07tY919Blt7AD1dtX01AlN.•IflOY,x~BWLpQ~pt7AKRN~{Ipltdt$gX ~~ AWi'dtdl!{>btilHtJuly 24, 1979, if3E~f#d6tY~E#~tXdHEHEtibiEd636dfiFr~# However. , i'pY~i$, h"iUSBAND will HIiB receive as an income tax exemption any child who seeks tuition benefits from his employer beginning the year said beneftts are applied for by said child. WIFE agrees to sign the appropriate IRS forth which confirms said exemption. 13. INSURANCE AND EMPLOYEE BENEFITS: Tho parties agree that any life insurance policies on the life of HUSBAND or WIFE or any other employee benefits, including but not limited to retirement, profit sharing or medical benefits of either party, shall be their awn. WIFE waives all right, title and claim to HUSBAND'S employee benefits, and HUSBAND waives all r;ght, title, and claim to any of WIFE'S employee benefits. n 1 a, BENEI'ITS AND BANK ACCOUNTS: WIFE agrees to waive all right, title and interest which she may have in the savings or checking or any other bank accounts of the HUSBAND. The HUSBAND agrees to waive all interest which ha has in the bank accounts of the WIFE. 15. DIVORCE; The parties both agree to cooperate with each other in obtaining a final divorce of the marriage. It is agreed that the parties will execute and file the consents necessary to obtain the divorce, Any party who fails to cooperate with obtaining the Divorce shall pay all the costs and legal fees of the party who is seeking the divorce. 16. BREACH: If either party breaches any provisions of this Agreement, the other party should have the right, at his or her election, to sue for damages for such breach or seek such other romedies or relief as may be available to him or her, and the party breaching this contract will be responsible for payment of legal fees and costs incureed by the other in enforcing their rights under this Agreement. 17. ADDITIONAL INSTRUMENTS; Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement 18, VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, and each party acknowledges that the Agreement is fair ;md equitable, and thfit it is being entered into 7 voluntarily, and that it is nut the result of any duress ur undue influence. The provisions of this Agreement are fully understood by both parties and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any duress or undue intuence. 19. TIME SHARE: HUSBAND will waive any interest which he has in the Florida Time Share of the parties. He, will execute any documents required to convey his interest to WIFE. WIFE will be solely responsible for all the expenses and taxes related to said Time Share and she will indemnify HUSBAND for any claims related to said Time Share. 2.0. ENTIRE AGREEMENT: This Agreement contains the entire understanding of the parties and there are no representations, watxanties, covenants or undertakings other than those expressly set forth herein. 21. APPLICABLE LAW: This Agreement shall be construed under the Laws of the Commonwealth of Pennsylvania. 22. PRIOR AGREEMENTS: It is understood zed agreed that Any and all property settlatnent agreements which may or have been executed prior to the date and time of this Agreement are null and void and of no effect. 23. PAYMENT OF COSTS AND LEGAL FEES: The parties agree to pay for their own costs and legal fees required to obtain and complete the divorce. s ,~-, , 24. H'AIV_ ER OF CL__gIMS AGAINST CSTATFS: Except as herein otherwise provided, each party may dispose of his or her property in any wsrv, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the prosent or future laws of any jurisdiction, to share in the property a• the estate of the other as a result of the marital relationship, including without limitation, dower, courtesy, statutory allowance, widow's allowance, right to take In intestacy, right to take against the Will of'the other, and right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of aU such interests, rights and claims. IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day and year first above written. _ ~'x.~... s N _ 0~` (SEAL) SUSAN E. ARMOLT ICKX L. ARMOLT (SEAL,) 9 WITNESSES: COMMONWEALTH OF PENNSYLVANIA , SS. CUUN'fY OF CUMBF,RLAND PERSONALLY APPEARED BEFORE ME, this jh~~" day of ~!~_, 1998, a Notary Public, in and for the Commonwealth of Pcnnsylvania and County of Cumberland, SUSAN E, ARMOL'I', known to me (or satisfactorily proven) to be the pct'son whose name is subscribed to the within Marriage Settlement Agreement, and acknowledges that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. TEREEA J. 9URKNOLDER, NoUry PubNo C~rlNia, CumMMrM County, PA Alv ConvnWlon Eldrw Pub. Yi. 1000 COMMONWEALTH OF PENNSYLVANIA p''~ 1,,,,~,,,..,1~ SS. COUNTY OFL..~~7i 1 ~ u PERSONALLY APPEARED BEFORE ME, this-1~ day of _. ~, 1998, a Not(a~ry,~(~Public, in and for the Commonwealth of Pennsylvania d County of ~~y~l U > RICKY L. ARMOLT, known to me (or satisfactorily proven) to be thD person whose name is subscribed to the within Maniage Settlement Agreement, and acknowledges that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, f have hereunto set my hand and official seal. t ~~ ~t~n Nolarlal Seal Botzi A. Morison, Notary Public CarUSlu Doro, CumberlanU Coumyy '_ My Commisslon Er<plres Dac. 15.2000 ' filnin6v'. k's-., H,/Wr;llp A;gnnlUll!ul at N01111tl/ tc SUSAN E. ARMOLT, Ve. RICKY L. ARMOLT, To the Prothonotary; IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. 98 - 961 CIVIL TERM CIVIL ACTION -LAW Defendant ; IN DIVORCE PRAECIPE TO TRANRMIT RECORD Transmit the record, together with the fallowing information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Sertion 33011c) 3301(d111) of the Divorco Code. (Strike out inapplicable section!. 2, Date and manner of service of the complaint: r iiled Mail. Ratyrr~Receiot. signed by Defendant Rickv L Armolt dated Mar h ~.,. l.~la_8 3. (Complete either paragraph tai or (b)). (a) Date of execution of the affidavit of consent required by Section 33011x) of the Divorco Code: by the Plaintiff 7/14~i; by the Defendant 7!27/98 Ibl 111 Oate of execution of the Plaintiff's affidavit required by Section 33011d1 of the Divorce Code: n!a 121 Date of service of the Plaintiff's affidavit upon the Defendant: n/a 4. Related claims pending; None s. Complete either lal or (b). la) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Ib) Data Plaintiff's Waiver of Notice in 33011c) Divorce was filed with the Prothonotary: Date Defendant's Waiver of Notice in 33011c1 Divorce was filed with the Prothonotary; tin,. ; ~ >"w Carol J. Lindsa , ttorney f aintiff I }. _ ~~ C'? .. '_ ~.-` ~ r - ~1..' ~ 4 ~ , ' ) `. 41 ~' <) ~. ~ LL L11 [ ~ 1 ~ I r 11 lL,~'! .. CJ CSr CU c:\wp.51\unnull\dlvnrco.oum (ilc NSS.iM7R~a1 fchnmq~ 1.1,170N SUSAN E. ARMOLT, IN THE COURT OF COMMON PLEAS OF Plalntitt CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 98 - ~jli~/ CIVIL TERM , CIVIL ACTION -LAW RICKY L.. ARMOLT, Dofendant IN DIVORCE Q~U~~3._QF ~0~1RI AND now, this _~__,~~`"fit day of ''. , ~ t zi;~tl __, 1998, upon considoration of tho attached tv~oUon, it_is hereby directod that the parties and t~rospective counsel appear before \ t 1 I ~~' 1. I the conciliat r, at ~~ i i ( ~. ~r kin L'rnl ~ r,~.L~C1 r,,~Cl_A `~-r~,_L_., on the ~Q day of _ /-~,C-(... 1998, at It~?~• •~+~_ o'clock ~-.. m. for apro-hearing custody conference, Ai' such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. For the Court, Custody ConcilintoL~-r-~-- j ~,j> . YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 1717) 24~-3166 ~MER~CANS WITH DISABILITIES ACT f1F 1990 Tho Court of Common Pleas of Cumberland County, Pennsylvania, is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations availaflle to disabled individuals having business before tha court, please contact our office. All arrangements must he made at least 72 hours prior to any hearing or business before the Court. By the Court, -.~.- ------- _._..._._ J. ~i lc. ~.~ i ti.> ~a ~ ~-Il. ~ .~,, ~ t,~ a ~ C.~ 1 ; t ~ ' / ' - ~' F 4 1 1 _.~ !~ _ C e t ((` F . - ,. ~ '. . _ ~ ~~ ' ~. f i. P~ j, ,, c~. ~. w . r:AwpSl\ucmol~Vdlvurt'aeonl I'ilu ~Y9S7H-9Rd11 I~cbnmry IJ,147N SUSAN E. ARMOLT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 9®• 4L, I CIVIL TERM CIVIL ACTION -LAW RICKY L. ARMOLT, Defendant IN DIVORCE NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may procead without you and a decree of divorce or annulment may be entered against you by the Court, A judgmont may also be entorod against you for any other claim or relief requested in these papers by the Plaintiff, You may lose monoy ar property or other rights important to you, including custody or visitation of your childron. When the ground for the divorca is indignities or irretrievablo breakdown of tho marriage, you may request marriage counsoling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court douse, Carlisle, Pennsylvania, 17013. IF YOII DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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 T'HE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN OET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 1717) 249-3166 Date; ,/~~~ FLOWER, MORGENTHAL FLOWER & LINDSAY, P,C, Attorneys for Plaintiff ~-- ~ By: Carol J. L ndsay, Esquire ID N 44693 11 East High Street Carlisle, PA 17013 (717) 243-5613 ;:\wp51\nnuull\JWurcaenm file N55]k-7&UI 1'ulnuury I], I'YiR SUSAN E. ARMOLT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . NO. 98 • 9c, / CIVIL TERM . CIVIL. ACTION • LAW IN DIVORCE vs. RICKY L. ARMOLT, Defendant COMPLAINT IN DIVORCE SUSAN E. ARMOLT, Plaintiff, by her attorneys, FLOWER, MORGENTHAL, FLOWER & LINDSAY, P.C., respectfully represents: 1. The Plaintiff is Susan E. Armolt, who currently resides at 1310 Holly Plke, Carlisle, Cumberland County, Pennsylvania, whore she has resided since January 15, 1998, 2. Tha Defendant is Ricky L. Armolt, who currently resides at 9 Kimberly Lane, Carlisle, Cumberland County, Pennsylvania, where he has resided since 1992. COUNT 1 - DIVOR(:E 3. The Plaintiff and Defendant both have been bona fide residents In the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4: The Plaintiff and Defendant were married on May 28, 1988, at Carlisle, Pannsylvanla. 5. That there have been no prior actions of divorce or far annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff avers that she is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. ., c:Awp54\nnnnl~\Jlvurcacaro (ilc k5S1M.9RAl Nrl~r~wp, IJ,19~~R 7. Plaintiff has been advised of the availability of marriage counseling and o} the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. 8. Plaintiff requests the Court to enter a decree of divorce. COUNT I! - CUSTOD~(1 9. The Plaintiff seeks custody of the following children: Joshua Armolt, age 18 years, born July 24, °1979; Benjamin Armolt, age 7 years, born March 10, 1990, and Meredith Armolt, age 5 years, born April 1, 1992. The children were not born out of wedlock. The children are presently in the custody of Susan E. Armolt, who resides at 1310 Holly Pike Carlisle, Pennsylvania. During the past five years, the children have resided with the following parsons and at the following addresses: NAME ADDRESS FROM TO Susan Armolt Susan Armo~t Ricky L. Armolt 1310 Holly Pike Carlisle, Pennsylvania 9 Kimberly Lane Carlisle, Pennsylvania January 15, 1998 to Present 1992 to ,January 15, 1998 T'he mother of the children is Susan E. Armolt, residing at 1310 Holly Pike, Carlisle, Cumberland County, Pennsylvania. She is married. a_:~r c:\wp51\nrnudl\Jivnrro.cunl rile *$.S7ti 9%.UI rcbrmip~ I], 1'l9F The father of the children is Ricky l.. Armolt, residing at 9 Kimberly Lane, Carlisle, Cumberland County, Pennsylvania. Ne is married, 10. The relationship of the Plaintiff to the children is that of Mother, The Plaintiff currently resides with the children. 11. The relationship of the Defendant to the child is that of Father, Tha Defendant currently resides with no other person, 12. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation concerning the custody of the children in this or another Jurisdiction. 13. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of the Commonwealth. 14. The Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 15, The best interest and permanent welfare of the children will be served by granting the relief requested because: a) The Plaintiff can best provide for the physical and emotional needs of her children. b) Since birth, Plaintiff has been the primary caretaker of her children. 16. Each parent whose parental rights to the children have nut been terminated and the person who has physical custody of the children has boon named as parties to this action. ~~ r!\wp51~\ilnwdi\dlvurcu,e~~m (tlc RfS;i,4~9Nd~l FobnNrp I1, I'P1k WHEREFORE, the Plaintiff requests this Court to grant primary physical custody of the children to the Plaintiff, FLOWER, MORGENTHAL FLOWER 8, LINDSAY, P.C. Attornoyg for Plaintiff \ t3y.--~~~~ ~ J - --_ ~ Carol J. L' dsay, Esquire ID # 44693 11 East High Street l-. Carlisle, PA 17013 Date;,_ ~j~' ~~~ (717) 243-5513 ~eL~ a c:\wM1tl\urmnll\divria•arom flc N5S]N-9Nd+1 I~cl+ruun~ I1,19Uk V FI ATIQN I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 49(14, relating to unsworn falsification to authorities. .. ~ '~ + Susan E. Armolt 5 SUSAN E. ARMOLT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 98 - 961 CIVIL TERM CIVIL ACTION -LAW RICKY L. ARMOLT, Defendant IN DIVORCE ~E T FI AT~QF SEF3'VICE AND now, this ~. day pf _ ~ 1996, I, GAROL J. LINDSAY, Esquire, of the law }Irm o} FLOWER, MORGENTHAL, FLOWER & LINDSAY, Attorneys, hereby certify that I served the Defendant, Ricky L. Armolt, on March 5, 1998 with the Complaint In Divorce by Certified Mall, Return Receipt Requested, Rostrictod Delivery, Addressee Only, addressed to: Mr. Ricky L. Armolt 9 Kimberly Lane Carlisle, PA 170'13 and proof thereof, the signed Return Receipt Card, is attached hereto, FLOWER, MORGENTHAL, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff f3y,~ arol J. Lindsay, Esquire ID # 44693 11 East Hlgh Street Carlisle, PA 17013 (-117) 243-5513 ~m SUSAN E. ARMOLT, . Ptalntift vs. RICKY L. ARMOLT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98 - 961 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE P OOF OF SERVICE RCdhpINR game 1 enWa 21a eddtbnel eenker. e0arigap Neme 3, Ie, end Ib I aIRO With t0 feCRIVR thR . follOWlllp BBrVICeR (lor en •rltY you name aid eddnte an Rn nvene of Isle brm w Mel we an raurn lee °~ wyou. eMre IBR): R M ^ rpt tm1RMC~n1 thN bnn to IM hoM of Ilw mellRleoe, a on IM beck H RMMM'Refum RecN R waai•o a +a lM rpea dose na nAdYdirRRSe gR 'R Add re st pp^~ ~;j~ .~~• ~ { n meH pwebaowlM R~ ~ ReCNpI will show to N1gm MN elide wee dullwn . G~ F~ ,, ~g, p T7 2.'CP~A9~LRB(fD911VA~'fLY d YM IM date 8 cle Addreoted to: Consult poetmasler for Ise. 4a. ArNcls umber Mr. Ricky L. Armolt P 198 568 315 9 KimbeY]. Lane y 4b.9RrvicR ype ^ Repletered A Certified Carlisle, PA 17013 ^ ExpreseMall ^ Insured ^ RetwnRocekNbrAlerd>orKllae ^ COD 7. Date o alive ,~ N By: (Pant Nen1s) 9, ressee'a Address ( my U uetfa~- end les Is Paid) netun• ddrsseseorAys '~~ ~~ PB Form 3ei r 1994 Oflieatn ehrm ane ~~ i I!, ~~ ,~ i i 4 I , ~ t11 • t , ~ I -. .. 1 1 1 ~ t-,~ ., .. t I~ u. ,. _ 1 I II ._ ~ _ __ ~. I,.if ~ ~ (-~~ ,. 1 1 ~~ ~ ., 1,_~ i ~- .. 1 ,, SUSAN E. ARMOLT, ~ IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. N0: 98 - 961 CIVIL TERM RICKY L. ARMOLT, CIVIL ACTION -LAW Defendant ; IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint In Uivorce under § 3301(c) of the Dlvorc® Code was flied on February 20, 1998. 2. Tho marriage of plalntlH and dofondant Is Irretrievably broken and ninety days have elapsed Irom the date of Illing and service of tho Complaint. 3. I consent to tho ontry of a final Decree hi Divorce after service of notice of Intention to request entry of the Docree. I verity that the statements made Ih this AHidavit are true and correct to the best of my knowledge, Information and beUef, ;understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 rolating to unsworn falslllcatlon to authorities. Susan E. Armolt, PIaIn11N -=-=-c_~~ ~ v nGyrr . NTR-_Y O_F A .DIVORCE DECREE UNDER 3301 c OF THE.___ p~y_pR~E CODE consent to the entry of a final Decreo of Divorce without notlce. 2• I Understand that I may lose rights concerning alimony, division of property, lawyer's feea or expenses It I do not claim them before a divorce Is granted. 3• I understand that I will not be divorced until a Divorce Decree Is enterod by the Court and that a copy of the Decreo will be sent to me Immediately aHer it is fllod with the Prothonotary. I vorlfy that the statements mado In ihls Affidavit are true and correct to the best of my knowledge, Information and belief. I understand that false statements horeln are rnade subject to the ponaltles of 18 Pa.C,S, 4904 retating to unsworn falslllcatlon to authoritlas. Susan E. Armolt, PlalntlH Date, ,_.__~ -------- . 1 r,.y ~,. ~.~ C: t-^ _ i ..- .. .. ~ L. ~ ., .. ~ ''; ti.~,"1 I. L'S ~ 1111.1 ?,1 .1 ' ~C MC . ~.) ,L~ C7 .. SUSAN E. ARMOLT, IN THE COURT OF COMMON PLEAS OF Plalntitt CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 98 - 961 CIVIL TERM CIVIL ACTION -LAW RICKY L, ARMOLT, Defendant IN DIVORCE AFFIDAVIT OF CONSENT i. A Complaint In Divorce under 5 3301(c) of the Divorce Code was Iiled on February 20, 1898. 2. The marriage of plaintiff and defendant Is irretrievably broken and ninety days have elapsed from the data of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of Intention to request entry of the Decree. I verify that the statements made in ihls AHldavlt are true and correct to the best of my knowledge, Information ancf belief. I understand that false statements heroin are made sub)eot to the penalties of 1B Pa.C.S. A904 relating to unsworn talsiflcatlon to authorities. R' ky L. Armolt, D tendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 433010 OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's lees or expenses if I do not claim them before a divorce Is granted. 3. I understand that I will not be divorced until a Divorce Decree Is entered by the Ceurt and that a copy of the Decree will be sent to me immediately after It is filed with the Prothonotary. I verify that the statements made in this AHldavll are true and correct to the best of my knowledge, Information anti belle(. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn fatsiflcatlon to authorities. .Armolt, Defendant Date: _- ~a1y ._~ ~ ~ ~J c r~ '' c: ~: H.: LI~ ~ ~..~ I w\t 7 . r f~ ~ ~~ 7e~7. ~;. O i`, I `.I .. 77 , ~ /. Sul ~l.. ~~ '~ i i .. A4 , ~ .. i c:Au~~!tl~urnudl\sUpulnl~~ni,ruh ~Illr N55,tR!~K.III 61un~~i LI,I'fUk SUSAN E. ARMOLT, IN THt3 COURT OF COMMON PLEAS OF PlaintlH CUM®ERLAND COUNTY, PENNSYLVANIA ~s• CIVIL ACTION -LAW . N0, 9b-961 CIVIL TERM RICKY L. ARMOLT, , Defendant IN CUSTODY ORDER OF COURT AND NOW this (~ __ day of _~-_, 1998, upon consideration of the within Stipulation of the Parties for Custody, the terms of said Stipulation are hereby made an Order of Court. ev tnA n~~~ ~rt / r.~.. c:\wp.§I\urm~di\siipulmiun.eus filu NSS1R!18.u1 'April GJ99N SUSAN E. ARMOLT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA va. CIVIL ACTION -LAW NO. 98-961 CIVIL TERM RICKY L. ARMOLT, Defendant IN CUSTODY ST/P~ILATION OF THE PART/ES FOR CUSTODY The parties hereto are SUSAN E. ARMOLT, of 1310 Holly Pike, Carlisle, Pennsylvania 17013, hereinafter Mother; and RICKY L. ARMOLT, of 9 Kimberly Lane, Carlisle, Cumberland County, Pennsylvania 17013, hereinafter Father. The partios stipulate as follows: 1. They are tho parents of Joshua Armolt, born July 24, 1979; Benjamin Armolt, born March 1q, 1990; and Meredith Armolt, born April 1, 1992. 2. Tha parties shall share legal custody of said children. 3. Mother shall have primary physical custody of said children, and Father shall partial custody on the following schedule: a. Every other weekend from Friday after school until Sunday at 7:00 p. m. b. Every Monday and Wednesday from after school (3;00 p. m. during school vacations) i.antil 7:00 p.m. In the event that Mother requires child care while she works, she will give to Father or to his parents the right to care for the children at other times than those set out In this Order before using a paid babysitter. c• Unless otherwise agreed by the parties, three non-consecutive weeks per year with 30 days notice to Mother. Mother will also give notice to Father when she intends to take weeks of vacation from her work with the children. ~~:\wr~`•t\urmulll;aipulalion.cux lilt NSS1K.4ft~Ul Mnrch 24,1'NtR d. In even numbered years on New Year's Day and on Labor Day and In odd numbered years on Memorial Day and the Fourth of July. Mother shall have custody of the children in even numbered years on Memorial Day and the Fourth of July, and in odd numbered years on New Year's Day and Labor Day. e. On'ihanksgiving and Easter during one of two blocks of time on ttlose holidays; the first block being from 9:00 a.m. to 2:00 p.rrr., and the second block being from 2:00 p. m. to 7:U0 p.m. The parties shall alternate these blocks of time in a given year, so that in even numbered years Fathor will have tfie morning block on Thanksgiving and tho afternoon block on Easter, and in odd numbered years, Mother wilt have the morning block on Thanksgiving and the afternoon block on Easter. f, Every Father's Day from 9:00 a.m. to 7:00 p.m. Mother shall have every Mother's Day from 9:00 a.m. to 7;00 p.m. g. On alternating periods of time at Christmas, the first of said periods extending from Christmas Eve at 1:00 p.m. to Christmas Day at 1:00 p.m. and the second of such periods extending from Christmas Day at 1:00 p.m. to December 26th at 1:00 p.m. These poricds of time shall alternate annually, commencing in 1998 with Mother having the period of time between Christmas Eve at 1:00 p.m. and Christmas Day at 1:00 p.m. h, The poriods of partial custody specially set out for holidays and Mother's Day and Father's Day shall take precedence over the alternating weekend and mid-week partial custody schedule as set out in Paragraphs A and B above. At such other times as tha parties shall agree. 4. The parties shall say nothing in the presence of the children, nor shall they do anything in the presence of the children which will injuro tho regard the children have for each parent. The parties will not discuss economic or divorce Issues within the hearing of the children. The parties acknowleclgo that breach of this term of their Stipulation shall be as egregious a violation of the Court's Order as failure to provide custody as set out herein. .~ r.\a~pSV\nrnluil\:dlpululunle'us I-c N,SSIh!lq.ul ~llnrrh Ll, t94H 5. Thls Agreement may be entered as an Order of Court, WITNESS: ••-- -._ -' Susan E. A~ m It _. _ ~. Ricky L, Arm ~~~ ` ~ ~' ~~ Ili ~, ., ~ ~ ~ ~ .I .. i, ~ . ~ r . ~_ 1t L~ ~,. - ' ~ ' . ~~, tl _ ~ r--. f it 4 U~ . ~ _ ~ / ~. ~~ck~~ L . ~YIti'~o\ k Plaintiff v, a , ..7-1~t'n ~~ ~ (V~(~ T Dofendant IN THE COURT OF COMMON PLEA5 OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW IJO. ~~(U~ CIVIL 19~'~ ; CUSTODY VISITATION And now, this ~ 12,a~y., upon consideration of the attachod complaint, it is heroby directed that the above parties and their res ective counsel appear before .~_~~.-~+,-~-~--r-•- Esquire, the conciliator at-~l(`~-t ~~...,-u~l'-\~~~<<' <<~`'~ ~~` r ~"- M P M' Pennsylvania, on the ~ day of _~il.' , 1999, at ~j,~~Q-_ for a Pre~hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order..All children age five or older may be present at the conference. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent order, FOR THE COURT: Custody ConcrNator U t'1a>1 YOU SHQULD 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 ,.. . _, ~i; .. !i~~Vti !o ~dS ~ ~9 CL' ~ c' '"u~s ~ RICKY L. ARMOLT, : IN THE COURT' OF COMMON PLEAS OF Petitioner/Defendant :CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION -LAW 98.961 CIVIL 'PERM SUSAN E. ARMOLT, , Respondent/Plalnfiff IN CUSTODY ORDER OF COURT AND NOW, this day of June 1999, the Petition for Contempt is hereby referred to the Custody Conciliator who has a previously scheduled Custody Conciliation set for July 8, 1994, at 9:30 a.m. before Hubert X. Gilroy, Esquire, Custody Conciliator, ~m Floor of the Cumberland County Courthouse, Carlisle, Pennsylvania 17013• (3y the Court; RICKY L, ARMOLT, Petltloner/Defendant v. SUSAN E. ARMOLT, Respondent/Plaintiff W'I'NE COURT OF' COMMON PLEAS Of CUMBERLAND COUNTY, PENNSYLVANIA CIVIL AC'f10N -LAW 98-961 CIVIL TERM IN CUS'1'OUY PETITION I.OR CONTEMPT AND NOW, this 23rd day of June, 1999, comes the Petitioner/Defendant, Ricky L, Armolt, by his attorneys, (twin, McKnight and Hughes, and presents the following Petition for Contompt• The Petitioner/Detiendant is Ricky L, Armolt, an adult individual residing at 4 Kimberly Lana, Carlisle, Cumberland County, Pennsylvania 17013, 2. The Respondent/Plaintiff is Susan E, Armolt, an adult individual residing 1310 Holly Piko, Carlisle, Cumberland County, Pennsylvania, 17013. 3, The parties are the natural Parents ~f two minor children, namely, Benjamin Amtolt, born March 10, 1990, and Meredith Armolt, born April I, 1992, 4, Tho petitioner has filed an action in custody seoking more time and maintaining the children in their present school, 5, The respondent, Susan R. Annolt, has used her inFluence on the children to seek to estrange them from their father and to seek their compliance to switch schools. G, The respondent, Susan E.. Armolt, has sought to interfere with the existing custody rights of the petitioner as set forth by Stipulation in Exhibit "A" which is attached hereto. 7, Qn Saturday, June 19, 1999, the respondent sought to deny visitation of the petitioner nn Father's Day. The petitioner insisted being with his children on Father's Day and was able to do so. 8, On June 21, 1999, the petitioner sought to pick up the children at 3:00 p.rn. The children refused to go based upon the instructions they were given by the respondent. The petitioner resumed with his parents at G:00 p.m. to pick up the children, and the children and the respondent were gone. 2 I~ ~f 1 9. i. , The petitioner believes that the respondent has undertaken a deliberate campaign to estrange the children from him and seeks a Cnding of contempt together with reasonable legal fees against the respondent. ~, ~:f i. ,: WHEREFORE, Petitioner/Defendant, respectfully seeks a finding of contempt and the award of reasonable attorney fees against the respondent. i Respectfully submitted, IRWIN, McKNICEIT & HUGHES ~~~~ Byt Marcus A. cKnight, I Euqulrc Attorney fo Petitioner/Defe dent, ~ Ricky Armolt _ 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717)249-2353 Supreme Court L D. No, 25476 i s Data: June 23, 1999 ~ i i 3 M SUSAN E. ARMOLT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW . NO. 98-961 CIVIL TERM RICKY L. ARMOLT, , Defendant IN CUSTODY AND NOW this / 3 day of t ,_~, 1998, upon consideration ~ of the within Stipulation of the Parties for Custody, the. farms of said Stipulation era hereby ~ made an Order of Court. ' By the Court, U ~ .e.. J. ~'nIJ~ ~^RY FR^M RE~QRD In T,;am:~iv ,.,h ~acf, I I~. ~ ~ ~~r~,~ sot my hand and Iha seal of said Cau~t at Carlisle, Pa, Thls ..,,1,... da of ... ,~ .Prothonotary SUSAN E. ARMOLT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA va, CIVIL ACTION • LAW NO, 98.961 CIVIL TERM RICKY L. ARMOLT, , Defendant IN CUSTODY ~° ~ ~~~~ ' ; -~, i _, ,- - T/P CATION OF ~,E PARTS '.:, ~- F~ USTODY ' " ::a The parties hereto are SUSAN E. ARMOI.T, of 1310 Holly Pike, Carlisle, Pennsylvania 17013, hereinafter Mother; and RICKY L. ARMOLT, of 9 Kimberly Lane, Carlisle, Cumberland County, Pennsylvania 17013, hereinafter Father. The parties stipulate as follows: 1. They are the parents of Joshua Armolt, born July 24, 1979; BenJamin Armolt, born March 10, 1990; and Meredith Armolt, born April 1, 1992. 2. The parties shall share legal custody of said children, 3. Mother shall have primary physical custody of said children, and Father shall partial custody on the following schedule: a. Every other weekend from Friday after school until Sunday at 7:00 p,m. b. Every Monday and Wednesday from after school (3:00 p.m, during school vacations) until 7;00 p,m. In the event that Mother requires child care while she works, she will give to Father or to his parents the right to care for file children at other times than those set out in this Ordor before using a paid babysitter. c, Unless utherwise agreed by the parties, three non-consecutive weeks per yoar with 30 days notice to Maurer. Mother will also give notice to Father when she intends to take weeks of vacation ffom her work with the children. d. In even numbered years on New Year's Day and on Labor Day and in odd numbered years on Memorial Day and the Fourth of July. Mother shall have custody of the children In even numbered years on Memorial Day and the Fourth of July, and in odd numbered years on New Year's Day and Labor Day. e. On Thanksgiving and Easter during one of two blocks of time ors those holidays; the first block being from 9:OD a.m. to 2:00 p,m., and the second block being from 2:D0 p.m. to 7:00 p.m. The parties shall alternate these blocf<s of time In a given year, so that in even numbered years Father will have the morning block on 'thanksgiving and the aft3rnoon block on Easter, and in ndd numbered years, Mother will have the morning block on Thanksgiving and the afternoon block an Easter, f. Every Father's Day from 9:00 a.m. to 7:00 p.m. Mother shall have every Mother's Day from 9:00 a.m. to 7:00 p.m. g. On alternating periods of time at Christmas, the first of said periods extending from Christmas Eve at 1:00 p.m. to Christmas Day at 1:00 p.m. and the second of such periods extending from Christmas Day at 1:00 p.m. to December 26th at 1:00 p.m. These periods of time shall alternate annually, commencing in 1998 with Mother having the period of time between Christmas Eve at 1:00 p.m. and Christmas Day at 1:00 p.m. h. The periods of partial custody specially set cut for holidays and Mother's Day and Father's Day shall take precedence over the alternating weekend and mid-week partial custody schedule as set out in Paragraphs A and B ahove. At such other times as the parties shall agree. 4. The parties shall say nothing in the presence of the children, nor shall they do anything in the presence of the children which will injure the regard ttie children have for each parent. The parties will not discuss economic or divorce issues within the hearing of the children. The parties acknowledge that breach of this term of their Stipulation shall be as egregious a violation of the Court's Order as failure to provide custody as set out herein. ,, _. ... I) C.\x'~I,il\nfnl~lll \nI I~IDI+11~tln.l'lIS Ills .1~.1J.III~~MIII HnfCll .i,IY.M1 5. .This Agroement may he entered as an Order of Court, W17NESS: Susan E. Armcit ~' ~~ ~~ Ricky L, Armolt v~R~r~cA~r~orr The foregoing Petition tier Contemp' is based upon infi~rmation which has been gathered by counsel and myself in the preparation of this action. 1 have reucl the statements made in this document and they arc true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4)04, relating to unsworn falsification to authorities, RICKY L. ARMOI,'I', Petitioner/Ucfendant v. SUSAN E. ARMOLT, Respondent/Plaintiff IN'i'HE COURT OF COMMON PLEA5 OH" t CUMRF,RLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 9R-961 CIVIL TERM IN CUSTODY 1."ERTIFtCATE OF SERVICE I, Marcus A. McKnight, I I1, Esquire, hereby certify that a copy of attached Petition for Contempt was served upon the following by depositing a true and correct copy of the same in tho United States mail, first Class, postage prepaid in Carlisle, PA, on the date referenced below and addressed as follows: Carol ,1, Lindsay, Gsq. Flower, Flower & Lindsay I i East High Strcct Carlisle, PA 17013 IRWIN, McKNIGHT & HUGHES ~~;_ ,~ By; Mar s A. Mc night, II, Esquire 60 est Po fret Street Carlisle, Penns ivauia 013 (717) 249•'1353 Supreme Court I,D. No. 25476 Dato; June l3, 1999 RICKY L. ARMOLT, Petitioner/Defunrlant v, SUSAN E. ARNIOLT, Respondent/PlaiutN'f IN'F'HE COURT OF COMMON PLEAS OF CUMBERLAND C:OUN'i'Y, PENNSYLVANIA , CIVII, AC"PION - hAlV 961-19N8 (.'IVII, TF,RN1 IN CUS'1'OI)Y PRGHF,ARING CUSTODY ML,MORA_N_UUM or nrrFNDANT, RICKY L. ARMOLT 1, Statement of Casc: T'he narrow issue for the Court is whether the children in this case, being Benjamin Armolt, born March 10, 1991), age nine (9), and Meredith Armolt, born April 1, 1992, age seven (7), should remain at Saint Patrick's Parochial School in Carlisle or be moved to the public school system. Both parties agreed to place the children in private school at St. Patrick's School.. "Che father aF;recd to pay fbr the costs of their education and has done so. The mothet• asserts that the older child, Benjamin, has Icaming disabilities and wants both children in the public school. St. Patrick's School has hired a special teacher to concentrate on learning disabilities of St. Patrick's students. "fhe Rdher does not know why the mother wants to also remove Meredith Armolt who has done well at St. Patrick's School. lI, Is~st c: Whether khe Mother may remove both children from private paroehtal school where they have attended since they began school, Ili. List of Witnesses; I. Ricky L, Arnwlt will doscrihc tho oduoaUrnt of the chlldren et SL Pt+trigk's School IV, Posltlon of the Fnthcr: The ftdhcr has met with thu principals mul teachers at both St. Patrick's School and the Moreland Elementary School He rc+nains convinced that the interests of both children arc best served by trooping them at St. Patrick's School. St. Patrick's School is now able to provide special hell~r t?n• 13egjamin's learning disabilities. The fr+ther bclievus strongly that his daughter, Meredith, should remain at St, Patrick's School where she has started her education. The father does believe that the mother nu+y have other unstated reasons for the desire to chango schools. He helievos that the hest interests of the children should prevail which would permit them to remain at SL Patrick's School R~r the coming school year, V. Memorandum: The father has been unable to find any appellate case in the C'onunonwealth which is diroctly deahng with the issue hetin•c this Court. Pennsylvania Courts have addressed the issue of whether the cost of private schooling is a rcnsonable need of a minor child. The test is stated in Braxton v. Nrnxton 5 D. Rz C.4th 61., 65 (C.P. Dot+nvare County 1990) is: "Where the child is a minor.. ,the ++pplicable test is whether the cost of private schooling is a reasonable need of the child and a reasonable expectation and expense of the parents. In deterrnining if the need is roasonable, the court must determine if the child will benefit from private schooling. hi addition the court must determine if private schooling is consistent with the family's standard o!'living and station in life before separ+tion," Francis v. Francis, 358 Pa. Super, 391 ~_, 517 A.2d 997, 1000 (1986). Sce also Litmans v. Litmana, 449 Pa. Super. 209,__. 6~3 A.2d 382.395 (1996); Braxton v. Braxton, 5 D & C,4th 62, 65 (C'.P. Delaware County 1990), In this case, both ptu•tics agrcud to caul the ohildren to private sohool. ~ The fathor has paid kito cost for that education, "fhc ohildrun arc benefiting from that education, The mother's reason for changing schools tin' b_ otlt children le not sufficient to overcome the benefits and the disruption which changing schools would create, VI. Estimated Length of Trlal: The estimated lenk~th of trial is one-half (1l2) hour to (1) ono dour. Respectfully Submitted, IRWIN, McKN-CH & HUGHES ~_~, ~ _~ _~ / ~N Ry; Marcus A, dlc1C ig I Esq. 60 West Pomfret Street Carlisle, PA 171 fi3 (717) 249-2353 Date; Austtst25, 1999 , Supreme Court LD. No. 21476 Attorney for defendant , Ricky L. Armolt 3 RICKY L. ARM01.T, IN TIIE COURT Oh COMMON PLEAS OF' • Petltioucr/Ucfendant : CUMBh.RLAND CbUNTY, PENNSYLVANIA v. CIVIL AC'I'!ON - I.AW 9fi1-1998 CIVIL'I'ERM SUSAN E, ARMOLT, , Respondent/Plaintiff IN CUS'COUY CER'fIP7C'ATE 9F' SERVICE 1, Marcus A. McKnight, 111, lisquirc, hereby certify that on this rlute a true and correct .copy of the Pre-!-!caring Custody Memorandum of Dcfcnrlant, Ricky I_,. Armolt was served by first elass,United States mail, postage paid in Carlisle, Pennsylvania f 7013, upon the following; Ca-rol J, Lindsay, Esq, PLOWER, FLOWGR & LINDSAY I 1 Gast High Street Carlisle, PA 17013 IRWIN, McKNICHT & HUGHES I,,,/ , ~"~ By: Marc s A. Mc night, 1, Esquire 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court LD. No. 25476 Atte~rney for Petitioner/Defendant Ricky L, Airnolt Data: August 25, 1999 4 MAY 01 1998 SUSAN E. ARMOLT, :TN THE COURT OF COMMON FLEAS OF Plaintiff tCUMSERLAND COUNTY, PENNSYLVANIA V rCTVII, ACTION - LAW RTCXY L. ARMULT, sNO: 98-961 CZVIL TER1N Defendant :lN CUSTODY ~~ COURT ORDER AND NOW, this o~ T _ day of April. 2998, the Conciliator being advised that the parties have reached an agreement, the Conciliator. reIinqulshes jurisdiction. Hubert X. G Troy, E Custody C ciliator SUSAN E. ARMOLT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. N0. 98 - 961 CIVIL PERM CIVIL ACTION -LAW RICKY L. ARMOLT, , Defendant IN DIVORCE 110TICE OF INTENTION TO RE$t~ME PRIOR NAME NOTICE IS HEREBY QIVEN that SUSAN E. ARMOLT, the Plaintitf in the above matter, having been granted a Final Decree in Divorce on Qu~~~,~,1 I~-L, hereby intends to resume and hereafter use the previous name of SUSAN E. KUNTZ, and gives this written notice avowing her intention in accordance with the provisions of the Act of April 2, 1980, P.L., 23 P.S. 702, effective July 1, 1980. <-;. f^~ A Susan F.. Annolt, Potitionor TO BE KNOWN AS; :ti -~~ lJ Susan E. Kuntz COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND sa ON this, the __ :'~ rr_ day of _~il[,[Yr[.;7:{ 1998, before me, a Notary Public, personally appeared SUSAN E. ARMOLT, knowri to me ar satisfactory proven to be the person whose Warne is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto sat my hand and official seal. t,, ; 1 ;. t' - Notary Public NOTARIAL 6 TBRGBA J. aURK11pLpER, Nopry q,b~ Ga4N, CurM~rWk1 Co,mN, PA My Canminebn F.R~Irss feb. 21, 2000 ~~ N ri ~ a ~? J t i ~ ~ ~ ~~1 ., ''~ ~~ r I ~ ~ r - , ~ a.w tf I ,1. ,. n.. `=+ ll.Y .<ri RICKY L. ARMOLT, Petitioner/Defendant v. SUSAN E. ARMOG'r, RespondentlPlainUff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 98-961 CIV[L'I'ERM IN CUSTODY ORDER of couR'r AND NOW, this _~_ day of _~p~.._, 199c'I_ ,upon consideration of the att~ hed .petition, it is hereby directed that the parties and their respective counsel ap ear before ~~~(~, ~~\~~Esquir©, the conciliator, at'w~~ (~ ~ ~_r,~i(~, on the ~, day of _~t,([~ , 199 at ~~ . M, for aPre-l]earing Custody Conference. At such conference, an effort vill be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court and to enter into a temporary order. All children age five or older may also be praseut at the conference. Failure to appear at this conference may provide grounds for entry of a temporary or pernianent order. dy the Court, Custody Conciliator `~'~~ - YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. LF YOU DO NOT HAVE A LA'iVYER OR CANNOT AhF'ORU ONE, GO TO OR TF,LEPHONE THE OFFICE SET FORTH BEhOW TO FIND OUT WHERF. YOU CAN GE'r LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 1-800-990.9108 I ,'j~l ' ,, ~ H, ' l,'~,~, ~ ,', Sri J L ~~~~ ~ ~ ~~1y ~s~~y ~9~ co~~l,~~~~' .-~ ,y..~r~~., AMERICANS WI'fli DISABILI'f1ES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office, All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. 2 RICKY L. ARMOLT, Petitloner/Defendant v. SUSAN E. ARMOLT, Respondent/Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 9k-961 CIVIL'I'ERM !N CUSTODY PETITION FOR CUSTODI' AND NOW, this 20th day of May, 1999, comes the Petitioner/Defendant, Ricky L. Arn~olt, by his attorneys, Irwin, McKnight and F[ughes, and presents the following Petition for; Custody. The Petitioner/Defendant is Ricky L. Arrnolt, an adult individual residing at 9 Kimberly Lane, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Respondent/Plaintiff is Susan E, Armolt, an adult individual residing 1310 Holly Pike, Carlisle, Cumberland County, Pennsylvania, 17013. 3. The parties arc the natural parents of two minor children, namely, Benjamin Armolt, born march 10, 1990, and Meredith Arnrolt, born April I, 1992. 4. The parties wero residents of the Commonwealth of Pennsylvania since birth. 3 5, The parties entered into a Stipulation signed by Judge Edgar B. Bayley on April 13, 1998, a copy of which is attached hereto and made a part of this Petition. 6. The children seek to reside with their father or in the alternative, spend more time with their father. 7, The Respondent/Plaintiff, Susan E. Armolt, seeks to remove the children from St, Patrick's School and enroll them in public school. The Petitioner/Defendant opposes said change which will be detrimental to the welfare of the chilren. 8. The Petitioner/Defendant woks equal physical custody or primary physical custody of the children. 9. The best interest of the childrenr require that the court grant the request of the Petitioner/Defendant as set tbrth above. 4 WHEREFORE, Petitioner/Defendant, respectfully seeks the entry of an Order of Court seeking shared legal custody as well as setting a schedule which would provide regular periods of custody by the petitioner/plaintiff with his children. Respectfully submitted, IRWIN, McKNIGHT & HUGHES B ; ~ ~/ ~~ Y Mareus . McKnigh , squ~e Attorney or Petitioner/Defendant, Ricky L. Annolt 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court t, D. No. 25476 Date: May 20, 1999 SUSAN E. ARMOLT, IN THE COURT OF COMMON PLEAS OF PlaintlN CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW NO. 98.961 CIVIL TERM RICKY L. ARMOLT, Defendant IN CUSTODY Q.~B..-4`.E.~Q 1~iT AND NOW this /3 day of ~ ~',G ~, 1998, upon consideration of the within Stipulation of the Parties for Custody, the terms of said Stipulation are hereby made an Order of Court. By the Court, J, TP+)t C!)PY FR^M RECORD In T~~:.t.mo~ry ~r•h ~•>c`, (I~,~ r~ ~irt~, set my hand .and tho seal of said C.~urt at Carpsia, Pa. This ....L.~~.,. day of .?~R~n.Q, 19..,..~~ .«...._,..~N.Qi~.....C.S.~.... Pr~ortho o ~,........_.. ~~, . SUSAN E. ARMOLT, : Plalntift . vs. . RICKY L. ARMOLT, pefendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION • LAW NO. 98-961 CIVIL TERM IN CUSTODY _ry i ~C .J \, _. , P1JL ,~N OF THE PARTIES fOR CUSTODY The parties hereto are SUSAN E. ARMOLT, of 1310 Holly Pike, Carlisle, Pennsylvania 17013, hereinafter Mother; and RICKY L. ARMOLT, of 9 Kimberly Lane, Carlisle, Cumberland County, Pennsylvania 17013, hereinafter Father. The parties stipulate as follows: 1. They are the parents of Joshua Armolt, born July 24, 1979; Benjamin Armolt, born March 10, 1990; and Meredith Armolt, born April 1, 1992. 2. The parties shall share legal custody of said children. 3. Mother shall have primary physical custody of said children, and Father shall partial custody on the following schedule: a, Every other weekend from Friday after school until Sunday at 7:00 p.m. b. Every Monday and Wednesday from after school (3:00 p.m. during school vacations) until 7:00 p.m. In the event that Mother requires child care while she works, she will give to Fattier or to his parents the right to care for the children at other times than those set out in this Ordar before using a paid babysitter. a Unless otherwise agreed by the parties, three non-consecutive weeks per year with 30 days notice to Mother. Mother wil! also givo notice to Father when she Intends to take weeks of vacation from her work with the children. [.\w'wl\Jf111U11 \SOr~111At1Ulblua uW I]P ,n.IMlll ~dlJµll c4.t d. In even numbered years on New Year's Day and on Labor Day and in odd numbered years on Memorial Uay and the Fourth of July. Mother shall have custody of the children in even numbered years on Memorial Day and the Fourth of July, and in odd numbered years on New Year's Day and Labor Day, e. On Thanksgiving and Easter during ane of two blocks of time on those holidays; the first block being }torn 9:00 a.m. to 2:00 p.m., and the second block being from 2:00 p.m. to 7:00 p.m. The parties shall alternate these blocks of time in a g(ven year, so that in even numbered years Father will have the morning block on Thanksgiving and t!~e afternoon black on Easter, and in ndd numbered years, Mother will have the morning block on Thanksgiving and the afternoon block on Easter. f, Every Father's Day from 9:00 a.m. to 7:00 p.m, Mother shall have every Mother's Day from 9:00 a.m. to 7:00 p.m. g, On alternating periods of time at Christmas, the first of said periods extending from Christmas Eve at 1:00 p,m. to Christmas Day at 1:00 p.m. and the second of such periods extending from Christmas Day at 1:00 p.m. to December 26th at 1:00 p.m. These periods of tirrre shall alternate annually, commencing in 1998 with Mother having the period of time between Christmas Eve at 1:00 p.m. and Christmas Day at i :00 p, m. h. The periods of partial custody specially set out for holidays and Mother's Day and Father's Day shall take precedence over the alternating weekend and mid-week partial custody sr,hedule as set out in Paragraphs A and 8 abovo. i, At such other limos as the parties shall agree. 4. Tho parties shall say nothing in the presence of the children, nor shall they do anything rn the presence of the children which will injure the regard the children have for each parent. The parties will not discuss economic or divorce issues within the hearing of the children. The parties acknowledge that breach of this term of their Stipulation shall be as egregieus a violation of the Court's Order as failure to provide custody as set out horein. a\wltil\armull\~hpulauun,ws hlc N.U.IIi.'1R.U1 Nnrrn .~.I ~~'/n 5. This Agreement may be entered as an Order of Court, WITNESS: Susan E. Armolt/ Ricky L. Armolt VERIFICATION 9'he foregoing Petition for Custody is bused upon information which has boon gathored by my counsel and myself in the preparation of this action. 1 have read the statotnents made in this document and they are true and correct to the best of my knowledge, information and belief, I understand that false statements herein made are subject to the penahies of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities, _.-l-G~ _ '~~~~___ RICKY L. ARMOLT nave: MAy z0. 1999 RICKY L. ARMULT, : IN THE COURT OF COMMON PLEAS OF' Petitioner/Defendant ;CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION -LAW 98-961 CIVIL'fERM SUSAN F„ ARMOL'I', , Respondent/Plaintlff IN CUSTODY CERTIFICATE OF SERVICE I, Marcus A, McKnight, 111, Esquire, hereby certify that a copy of the Petition for Custody was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania 17013, on the date referenced below and addressed as follows: CAROL J. LINDSAY FLOWER, FLOWER & LINDSAY 11 EAST HIGH STREET CARLISLE, PA 170! 3 IRWIN, McKNIGHT Sc F )GHES ~~ / By; Marcus A. Mc t, III, re 60 West Po et Street Carlisle, ennsylvania 17013 - (717) 24 353 Supreme Cou 5476 Data; May 2Q 1999 JU! 1 6 199 .~ ~.; RICKY L, ARMOf;I', M'I'HE COURT OE' COMMON PLEAS OF Plaintiff CUMDEiRLAND COUN"I'Y, PENNSYLVANIA v CIVIL, AC"PION -LAW SUSAN E, ARMOL'I', NO, 98-961 CIVIL Defendant IN CLJS"I'ODY Ci)URT iDRDF.R ANll NOW, this .._~~ day of July, 1999, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows; 1, 'fhe parties shall meet for another Conciliation Conference on Wednesday, August 18, 1999 at 3;00 p.rn. 'I'hc purpose of this conference is to explore the options with respect to the placement of the minor children in either the Crestview School or St. Patrick's. 2, Pending further order of this court, the existing Custody Orderahall remain in effect. DY TFIIi COUR"C, Edgar D. E3ayl cc; Marcus A. McKnight, III, Esq.._ ~` f,,lc4+,~+~~wl~~~C '7 ~o%y, Carol J, Lindsay, Esq, ~ ~ RICKY L. ARMOLT', IN "I'HI3 LOUR'(' OF CUMh10N PLEAS OF Plaintiff CUMI3F?RLAND COUNTY, PENNSYLVANIA v ; CIVIL AC'I"ION -LAW SUSAN E, ARMOL,T, NO, 9R-961 CIVIL Uef:ndant IN CUSTODY Prior Judge; fsdgar B. Bayley CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WI'fll TIME CLIMBERL,AND COUN'T'Y CIVIL RULE OF PROCEDURE 1915,3 ~R(b j, the undersigned Custody Conciliator submits the Ibllowing report; 1. The pertinent inforrnatian pertaining to the children who arc the suhjeet of this litigation is as fogows: Benjamin Arniolt, born March 10, 1990; and Meredith Armolt, horn April I, 1992, 2, A Conciliation Conference was held on .luly R, 1999, with the fi~llowing individuals in attondanw: The Father, Ricky L. Armolt, with his counsel, Marous A. McKnight, 111, Esquire; and the Mother, Susan E. Armolt, with her counsel, Carol J. Lindsay, Esquire. 3• The parties agree to'.he entry of an order in the form as attached. DATE Hubert X, Oilry ,Esquire -' Custody Coif iliator Apuappuo) palo/UUOwsq pi1a1114awiq H Iwwaaoldwl fpaap Alluglpuo~ pafogmowaq palogluowaq ~ luawaamdwl fpaaq ApuaPpuo~ palo+puowaq palmpuawaq av luawanoldwl fpaap ~ - ~ > > ~ ~~ \~ \ 1 \ l \ i o ry 6 N «. G c o o w « '^ a. .'y w r b y » +k C O d ? C p m ~ ~ u n u •b tD ~ V ~ u o .~ ur a .v ~ a n 3 +. c .`+ ~ ,~ y ~ N 'CI ry y. ~ a N al V a '' a o -a `^ 2 a' N o v v -4 v ~I O 'y ~ 6 ~ .~ b, O. R p Y N ~ V b Y H O .G « ; ~ b O C N C ~ ~ V C Q N b O 3 O ~ ~ ~ tt ~' } O d O C O N N O ~ 61 N N YVN~ Y H 0 'C OV' N .O ~ Y ~ ~ V b O O Q N Apuggmo~ palogwawaq palolpuowaq v luawoaoldwl fpaap Apuappuo~ paloq+uowaq palogfuowaq M luawanoldwl fpaaq Apuappuo) palmpuowaq pgogmowaq r Iwwanoldwl +paap a ~' .r• - M 1 r, ~' N ~ c. ~ ~ _ o e j z ~ e ~ ° _ , --_ m W ~ w ~ $ L 4 Q a ~ r N N b E o w ~ O "' a n J \~ \~ 1 > \ __ \~ w e .a < - ~ ° 9 c a c c r C ~ ~ c d K t9 w e b o ~ y ~ b~ m mo b i b, ,r ' - N Nw Ok C ti N S ~ C V q 6 N C ~ G C ~ -T~ C C d ~ O ~ C + - b v 6 w ~' d M N T' b y N C d O Q .' v ~ N b b o H .. 'L u 9 o s v Z W ~ O' Q ' O d 'a H b 6 V 4 y 4 1- 4 u N fY . 3 N al m p~ ifr 1 y ~ OC b 6 H ~ ~ u 4 a W m °o . y y m -a- r C w 0 ~ w C -~ d 61 v c y N w C, ° ; OI .C. e. N N y C p i O .°1 ~ N O y v C y ~ ~' v .. ~ N O i N o~ {9 .°. y = Y °. d w C en 'w Y m v N E O w. d 1 N Y O o ~ - - p ~ ~ ~ ro ~' t N .~ ~ ~ ,y ..~ V A ~ z ~ ~ Mr ~ ti N Q ' ' r c fn C~ I- Q. ~I -~ ~ f. ~ ~~ ~ ~ f' U ~ ~ P'. n ~ vi .. F ^. .Z ` ,: ~ , L "'. _ i .~ 'I M ~ kT u M N ~i ~; I1~ ~ v r~ 4i V ~~~ ~r \' `, ~, v 7 ,I ,~ v /- / ( _ w Y ~ ~~ 1 Q \ V ~ ~ ~.. ~~ d y 7 o `a tD `o a °~ ~ N d ~ Q V ~A ;'i Saint Patrick School Faculty and Staff List 1999 - 2000 .POSITION TEACHER AUi)RESS PHONE Principal S. Karen 310 Fairview St. 258.9527 Washabaugh Carlisle, 17013 Asst. to the S, Dorothy Kelm 310 Fairview St. 258.9527 Pdneipal Carlisle, 17013 BA Mrs, Mazgaret Shenk 33 Wnlnut Street 258.3483 Teacher P.O.Box 392 Boiling Springs, I'I007 88 Mrs. Joyce Haug I lUl W. Powderhorn Rd, 795.8654 Teacher Mechanicsburg, 17055 7A Mrs, )udy Mullery 4 Black Oak Ct. 258.5307 Teacher Boiling Spgs, 17001 7B Miss Jill Staudinger 26 N, F.arl St. Apt. B 532.3375 Teacher Shippensburg,17257 6A Mrs. Noreen Dempsey 1886 Mary Lane 258.8903 Teacher Cazlisle, 17013 6B Mrs. Grace Tilford 1 126 Acre Drive 240.0899 Teacher Carlisle, 17013 5A Mrs. Joanne Rossiter 1888 Mary Lane 219.9047 Teacher Carlisle, 17013 SB Mrs. Penny Cecere 1871 Old Main Dr.. 477.1906 Teacher Shippensburg, 17257-2299 4A Mrs. Brigette Guyer 738 W, Nonh Street 243.9440 Teacher Carlsilc, 17013 4B Mrs. Jennifer Kuhn 1023 Northfield Dr. 243.7667 Teacher Cnrlislc, 17013 Birthday 12na 03/22 12/03 02/23 11/21 07/02 06/29 07/27 02/07 08/05 05/12 12(07 ~. PHONE Birthday POSlT10N TEACHER ADDRESS Marygracc Scltrer 243.2368 1 N 1 sl Ca 05104 3A Mrs. 7013 e I Teacher 258.0691 05131 3B Mrs. Cindee Fenton 1156 Linn Dr, Carllsle, 1013 Teacher 249•R611 S 09130 Antoinettc Crcason Mrs trcct 312 Croghan 2A , Carlisle, 17013 Teacher G97.3257 02105 2B Mrs.1'heresa Kerstetter 168 Mulberry Drive Mechanicsburg, 17055 Teacher 249.0607 U31D7 Kathy Schumache Mrs h r C 1 to . 013 17 arl sle Teacher 438.3434 08131 IB Mrs. Amy Sullivan RU Nl Box 73 Ickesburg, 17037 Teacher 1432 S ring Road 25R-6797 07107 KA Mrs. Cheryl Tumas Carllsle, 17013 Teacher 1215 Kings Circle 732.1018 05106 KB Mrs. Karen Schauber Mechanicsburg, 17055 Toachor Old York Rd. 258.6955 512 W 07114 PRE•K 314 Mts. Laura Kayda . Carlisle, 17013 Rosemarie Butl 243.1152 er 5 White Oak Courl 04130 lA•Aide Mrs. Boiling Spgs., 17007 249.6864 k H SO I r 09117 1B• Aide Ic I C Ms. Bridget Ann Gaspor 7013 I 160 Fieldstone Drive 790•D205 09128 KA•Aide Mrs. Margaret Burton Carlisle, 17013 258.8744 Dr. dl 12120 KB•Aide Mrs. Sandra Lombardo Corl stc, l )pj 691.6318 IG Royal Palm Dr. 03115 Carleen Eodice PreK A.M. Mechanicsburg, 17055 Aide 629 Adams Road 249.0089 08129 PreK P.M, Yvonne Kane Carllsle 17013 Aldo 243.9043 905 W. South St. 02105 Art Mrs. Colleen Carlisle, 17013 Recess Man, Oszustowirz 264.0561 04118 Computer Mr. Josh Woltz 1865 Edgar Avc Chambcrsburg, 17201 POSITION TEACHER ADDRESS PHONE Birthday Library Mrs. Margo Ueise q0 8uckhorn Dr. 249.4268 06/17 Cnrlislq 17013 Learning Mrs. Cindy Ycrkes 328 W. South St. 249.5957 12/04 Support Cnrlislc, 17013 Music Mrs. Karen Berry 544 D Street 243.6343 OB/16 Cnrlislc, 17013 Phys. Ed, Mrs. Monica Dils 555 N. Hannvor St. 243.0216 03/01 Carlisle, 17013 French Mrs. Pauicia Matcya 550 Petcrshurg Rd 240.0710 07/07 Carlisle, 17013 SpanLsh Mrs. Ana Maurer 33 Turnpike Rd. 423.5816 09/lR Newburg, 17240 Secretary Mrs. Mary Kay Johns 354 Saw Mill Rd. 776.4042 07/07 Ncwville, 17241 Financial Mr. John Gasper 150 Hickory Rd. 249.6864 02j21 Secretary Carlisle, 17013 DRE Mrs. Helen Richards 1003 Kessler Dr. 530.8712 09/05 :,! Shippcnsburg, 17257 DRF, Mrs. Jeannie P.O. Box 78 243-0901 08/OR Secretary Richardson Plainfield, 17081 DRF, Mndelon Oliver 12G Strayer llrive 249.3408 01/31 Volunteer Carlisle, 17013 Nurse Mrs. !Caren McVitty RDHI, Box 422 789.4466 1Oj17 Landishurg,17040 Nurse Mrs. Sally Stoops 5 Sawmill Rd. 843.3151 Duncannon,17020 Dand Mr. Larry Grier 1020 Bridge St. Apt. A 774-2541 O8/OS New Cumberland, 17070 Guidance Mrs, Darbara Kauffinan 6214 Charing Cross 691-5365 12/26 Mechanicsburg, 17055 CAIU Mrs, Marisa Grenkevich 2602 Market SL 731.1868 06/10 Rdg,lMalh Camp Hill, 17011 Spoech Mrs. Lillian Rowland 72 Ucrhyshire Dr. 243.1052 06/26 Carlisle, 17013 POSITION TEACHER ADDRESS PHONE CARES Mrs, Anissa Olunt 1279 Courtney Dr. 261.0913 Chambcrsburg, 17201 Mrs. Andrea Davidheiser 24 E. Pine St. 486-6554 Mt. Holly Springs, 17065 Mrs, Monica Dils 555 N. Hanover St. 243.0216 Carlisle, 17013 Ms, Bridget Ann Gasper 150 Hickory Rd. 249.6864 ' Cm'lisle, 17013 Mrs. Kit Davis 136 Old State Road 486-7497 (lnrdners, 17324 Cefeteda ' Mrs, Anne Groves 9Tcaberry Drive 795.7148 Carlisle, 17013 Mrs, Myrtle Laughman R Spring Gdn Est, 243.9859 Carlisle, PA 17013 Mrs. Karmae Amsbaugh 140 Log Cabin Rd. 776.7968 Newvillc, 17241 Pastoral Rev. Andrew Fomanella 140 E. Pomfret St. 243.441 I Staff Carlisle,17013 Rev, Edward Keating 140 E. Pomfret St, 243.441 I (Ted) Carlisle, 17013 Deacon Gerald Kole 864 E. Loather St. 245.9007 Carlisle, 17013 Post Chaplain Chaplain Louis Schmidt Mary Queen of Peace 245.3318 Father Mera Drive Carlisle Barracks, 17013 Maintenance Mr. Steve Mellen 328 S. Pitt Street 243.0549 Carlisle, 17013 Custodial Mr. Steve Shevlin IOSD Alexander Sp. Rd. 249.3244 Staff Newvillc, 17241 Ms, Ha T. Vu 256fi Rumson Drive 236.0784 Harrisburg, 17104 Updatod 8/22199 birthday OB/30 01/20 03/01 09/17 07/28 08/26 11/14 12/08 03/30 03/18 08(26 09/06 06/23 10!01 Student Nam@ _~onjamin Armolt SECOND and TNiRD GRADES a e " ~ _ ~ ° V " .y e s ~ x ~ x s s ` ~ S ~ H ~ a r e E e " S y E ` E e ~ ~ ~ sa ,~ ~ o , e o ~ a y L u ~ L ~i u ~ ~i ~ 'p L a u a ~i z RfllOION o 1 o z o 2 o z o 3 o x n 4 o Knows content Pnrlldpates In doss Shows ellort GRADE IANDUAOf AR7S Acquires and uses new vocnbulary Appllos reading stralegles Initlates Independent reading Roods with undorstanding Rands with axpresslon and fluency Responds to literature Masters oatgned spelling words Appllos spelling skills In wrltlen work Expreues ideas clearly Initlates wrlling Independently Uses grammar correctly Uses good handwriting Completes assignments Shows ellort MadlNed program GRADE ~ Y J ~ / ~ f f J / / / _ ~ / J / f f _ 1 / / ,~ ~/'~ 1 / ~ f r ~ J / / / ~~ / J J / c/ ~ ,~ LJ 1 ~ I l"J C. r . ~r. ~rl a iF_., P'. ~.„' ,. r ~~ I k. ,~ i i ° ~',, I u ,~ ,, •f~ 1 r ~# +, ~. I MA1H Knows basic number lasts Understands and appllos tuntepts Ufaf problem solving strategies ' Complelef assignments I Shows alters ~ Modified Program GRADE CNARACIER DEVELOPMENT Attepts responsibility for actions Prattlees sell control Observes rules of the school Aespetls property Shows respect for adults Shows raspett (or other students WarNs taoperatively In groups Markin Code A.E B =Above Average C Average D =Below Average U = Unsatislactory "Empty box means does not apply ~ V E V ~ V ~ g z y Y a .1 9Y9 E ° y Y E O ~ ° ~ ~ 8 ~ z y Y a ~ 1EBYtl1 ° Y O OO ~ ° p y ~ x y Y O C °e o ~ p Y O O e o s O fL e ~ z y Y a 5 ~ ° a Y O °e o I Z 3 4 /~ / / / / / ~ ,~ / / / / / / ATTENDANCE 1 2 3 4 Days Absent ~ I 1.5 y.5 Times iota 0 3 1 ,~~ ~ .~~, `,+ ,! .r .. Bl~ ~..~Irurr '~I COMMENTS .. ~,,~,, .o,r.~-~. ~~~~ .~;,., ~..e.~. a..~,.......~. ~}} .~:~, ~ , ~ ~ ~ ~~ i, Parem Signature -~~~ ___ ~ iti r' . ,x,• Conference Requested __ Conference Requeved - ~'.,' , COMMENTS ,, ~'~i 2. ~, l\ t~ ~lA.~ snW.~..~. ~,},,,~,,,,, a,..a .rn~~.o,, tit WU..Q,a~ uvt~W. ~hM.d„ ~nJ ~,~,~, 1n.~.~ an. J.,~en1Z ~..~ -klt.a~' r~p,i ~ '"' a~c1 vnaad•o tari~„u,.a.4 a-~ - ~.. a~ h~ ~-~ ~..~ ~ ~ ~; . , r J~A,e,~.i,.~..q a~ ,~n.a'ri~a. ~ ~ / O Parem Signature ;~~~ 'f~~ ~~~ ___ ~// Conference Requested _ Conference Requested _~S,(,..:xe,,,, ~•Y~ ! ~ COMMENTS _ 3. (~,r _, ~.b1lAJM~.O/ ~ ~ J~. .1~.1 . ~ W ~1 LJ~ a..-~ ~,4~~'-~ . ~. ~ ~ L ~ p ~ ~, " ~ ~ ~ ~ ~W.L ~11,~ W ~J Ax. ~~v J7V.~ trA~y~p,~ , y ~ u 0 Parent Signature _.~ ~ ~ - "~_~s~, ~~`__ Conference Requested __ Conferenre Requested _ COMM~nEN",YS 1 4. l~v...+ ,,WU..c1 t~. ~-R.d.a.tu...r ~1 ,~V.t.. ,~~.J ,,pA,Cd~..~ Assigned to Qrade ~_ Teacher Signature ,~p ~ ~~,~ ~~~ ~ , .. ~ ~.. ~ ,~ i r+.~ ~~~ ,' .. ~. A ~: ' ,I ' DIOCESE OF HARRISBURG ! ~' ,_~~ a ,A •' 1 i ~ u ` ~M1 Grade 1 j ,~. a~ .. a ~ ,~. ~~~~~ k r ~ 1 ~../ J $1U~8nj Nar118 _, Meredith Armolt ~_, 1998-1999 , School Year ~ ~ Teacher ~' ' ~' ~ } M~6~ 3ahn y Principal s. Karen Washabaugh ~. ~~ ~. ,~ ,. ~ ~ ~ t ,y, ~~. ,,, ~. ,~ ~. Student Name M©rs3dith Armolt FIRST GRADE g E ~ e E ~ 9 s 'E 3 ~ e e 'E 71 u ~ ~ " e - 6 a - a $ e 3 '° o ~ " e s e z o i o v x o 0 RELIGION Z 3 4 Knows content Partidpates in doss ShaWf 011011 GRADF lANOUAOE ARTS Applies wmd attack skills Assoclases sounds with letters Reads wish understanding Reads with ezpresslon and Iluen<y Recognlsas haAc vocabulory Expressos ideas clearly in writing Applies phonetic knowledge to temporary spelling Capitoll:es rorracsly Uses tome<t punctuallon Writes complete sentences Masters assigned spelling words lees good hondwriting Farms letters correctly Participates actively Shows ellort GRADE / s/ / / ~/ / ~/ V ~ ~ _ f ~~ ~ / v _ / ~ / ~/ ~, ~` !{ ~~*" ~{ ~, ,,, ', W: ~~ oE~i 1 ~;~ ~` I ~y {P 11 S ~' I st ~~ ~, 'r 1 ,. ~., ~ ~ - r~ 1 .. ~ 8 a ~~ E ~ y ]C ~ e D y a e O 6 .~ '~ 2 O 3 e tlM O O .79 L n 6 ~ x ~ e 4 e Y Q Z 3 4 V Y i / / _ / / ~ / _ S / J r/ I ~ ;~ ~ L_J L ~1 ~ J L~_ ~~~I ATTENDANCE 1 Z 3 4 Doys Absent Z 6 ~ ~- Times Late 3 2 MARNINO CODE (m lasl report S . Salislanary N .heads Improvsmenl U . UnsatislaUaiy 'Empty haw moans does ool apply. ~1 t ;, ~,r '-~~,~ ~ i t i y~'~, ~}t.. ... s ,~~ ,I „r I SA ' i ~• r jf .~ , 1 •ah (t. MAIN Uses <ounling skills Knows basic numbor facts Shows auuracy In addtflon Shows accuracy in subtraction Solves word prnbloms Undenlands/appllos rontapls Shows elfort GRADE CNARACEER DEVELOPMENT Atceptf respontlblllly for nctlans Prottites soli control Observes rules of the school Resperls property Shows rosped for adults Shows respect for other students IVorks tnnn~,-•;,rary In groups COMMENTS ~ ~~~ t~~ rJQ.~.2~ '~~19 ~~~cC~ir1,C¢ ~a c c,~ vrn.~n.t.-hay . ~ ~~ Porenl $ignalure _ ___ ~ ~i'~ ~~ ~ ' Conleien~e Requested _ __ Confoience Requeslad y~ ///```~-- COM~MyE~N~TS,, " ,,~ ' ~w ~e.~.~ ~.~Xi.w~ ~ ~?rc, ~ha.~tc,v~e . r.~' ~, Pn~enl Signatwe ~~ `~ ~~-4~~.-~__-t-__ _ [onfeiame Roquesled _ Conference Roquasled _ _ f`r 1 COMMENTS a ~t ..1 VC.I.CL ~Q U ~-~l,i,r~ --~-0 ~ti`e- 1 w 5.., .. ~.-PULE.' ~.GLGGLCI.crr~'u.G ~Cl- Ua6'C~.~~- I Assigned to Grade 2 f Teacher Signotore ~~~ 'tY'~ n ,~'~ .~ .~+ * \~ a~tw ~~, ., ,r ~.. ~ ~ ' a (791) Dloceae of Narrlaburg Permanent Elementary Schuol Record •SCHOUL Saint Patrick ___ _____ CITY Carlisle. _ Pupil Armolt Benjamin _ Thomas M Sox __ ILeell In/el!`• IlAlddlel (Dad) Address .-,9. Kimberly Lane, Carlisle, Pa_ L70LJ _ ResidentPubllcSchoolDistrict Carlisle (Mom) 148 Chester Street, Carlisle, PA L701d Change of Address _ ~ _,_________ A __ _ 486-8433 (Mom) Telephone `_..__._ Ghange of Telephone 243-2.~i41L _._ Placeol8irth Orlando, Florida Dateol8irth _;;/10/90 Citizenship NS _ SSa 590-96-6928 Roglslered Parish Saint Patrick _________~ _ Location Carlisle Admitted from ISChonU PaAeM IAtlmeael Date 8/29/95_ Grade _KB_.__ /~1,../T_..._ i Baptism _T _-_____-_.___________.__ ..,.. _ _~ma Saint Patrick ----- Carlisle, Pa. 7/1 vel~6l90 Fleet -----••----•-- - Penenca Ire Saint Patrick ----------------~--- - Carlisle,_PA -- Z/2~/~~ Euoharlat Saint Patrick _- -_ _ ,_ -_ Carlisle, PA 5/1/99 Confirmation Name I Oocuostlon I RlIIOIOn I Fdun>tlinnl('.irrlcl Father Rick L Armolt __• Comp. Proara mar Catholic C'•~o ~ Aav Mothor Susan Kuntz ~ Ifi,elenaMemenl P/T RN Catholic s ~m ~~ GUerdien Elam Con - -_~ ___ __ Sec Aov Siblings -Joshua 15}, Meredith 3 Relellonehip of pwrtllan to chlltl Home Shuetlon: One parent ( ) Parents Separalud or Divoroed (g) Restructured •- Steplalher/mother ( ) Father Remarried ( ) Mother Remarried ( ) Child resides with __. Mother_______i_ Parental Rights (incase of separation or divorce) __-.___.-_-_..-_.-_._--. IAlucn copy of corm omen Language (other then English) spoken at hamo ._~___________-_.,____ WITHDRAWAI aFnnan nr ruTe... Dste .- _._ To Cause' Dalo From vv Grade Reason Y n y 0 r m a 5 N• 5 ~ ~ d Ul 0 A L ••••~,~,..., ~euwe. ~. mnru. t urun, J UII Clly. a enouellon, 5. flnmcul Pllhmdnee, a Puenlf Wnn, / 9ctlnal gn4uael, a hul0unnnrln ml, q Omer Ileeeone Name olt __ 15an nmin - -°°--- L--------____ Y'Itomas _ Lgsl First -~-- Middle ACADEMIC ACHIEVEMENT YEAA - _ 51 '4'd •a~ GRnDE K I Z _ Ro6gion - •-- Roadmg Inr re au• English n ' I .sl_. Spel6ny G' Handwrilinq Mfllhomahcs Ira el x, ~~ Scrarrcolhloallh' - - SocialSludles - Arl •- - _Muslc _ ~ -- Phys. Ed/floallh' - dCf sr7{igmlPal,on WMF Hdbll L /flC Q Olllld IOO, A -- r, - Social Pl res4 - Days Absent ~ (~ (o ~ - Timesl.ale ~) ~• rJ' PROMDTED P~ 110 f -rlonnn maybe corrolareU wdh Srionce and/or Plrys Ed +AL•AhovoLevel GL~GradeLevel AL•BelowLevol MARKING CGDE GR ADER t-3 GRADES 4-8 A ~ Exrellanl FORM "A" B+ •VoryGood Numerical 8 -Good C+ -Above Average FORM "a" C -Avorago A - 95.100 - Excefonl D • Below Average 0+ - 90.94 - Vory Oootl F -Failing B - 95.99 -Good C* - 90.04 -Above Avorago C - 75.79 • Average D - 70.14 • Below Avorago F ~ 69 R Un der • railing Kde. (:ra dac A Almost Always 5 Sometimes N Not Yet If report card is tG be mailed to otherparent, use address listed below. __ Yes __ No (Name) (Addreea) (City/Btate/Lip) (59S) Dloceae of Harrlaburg Permanent Elementary School Redord _SCHOOL S~P.a.triCk_.5chonl---.-.--- --------._..__gTY.Carf isle-------_- Pupil ArJnn.lf.~---•------.___-~leredit-h.----- Ca.therine_..--°---- Sex ----J'' --.. Ilafll IFrrfll (M~dQlel 9 Kimberi L n© C' Gather) I Address Y_ a____~, artiste ______ Resident Public SchoolDistricl South M:.ddleton ChangeolAddrass _ 1310 Holly Pike-Carlisle (mother) _ - - __ Telephone _~=~-4.33 ~__~___-._.._ Change of Telephone 243-2440 _____ Place of Birth _S'aL.Lis.Le__-.-_ Dale of 61rth -2_].--92 Cltizsnship ate~._. SSN _-~~.,Z!L-S2495- RoglsloredParish St Patric_'k-_~ilta5~h- __- Location ~s]L'llsl~_--_.__ Admitted from (School) Gate Grade IAetlreul _ _Parlah ___ - CllylTown li State Date ®apdsm S at~ick Chul-ch __ _ Pa rarlisle _ 7-11-92 _ Flra! irat nca Eucharist _ -~ __ - --- --- _ , _-._.-___ _ -- Conllrrnation ~- -- Name ~ Ocaupatlon ~ Religion ~ Education(Circle) Father Elem Coll Ricky L Armolt _ rogrammer Catholic __ _ .+ Aev_ Mother IFUel ana Mmtlan Elam Gal untz _ 1 R.N. ___ Catholic s,~ _a~ _ Elom C:ou Guardian ~~_ Sec Atlf _ Siblings Benjamin 7 Relatlonahlp al puerdlen to child Home SltuaHon: One parent ( ) Parents Separated or Divorced (g ) Father Remarried ( ) Mother Remarried ( ) Child resides with Parental Rights (in cose of separation or divorce) Language (other than English) spoken al home WITHDRAWAL RECORD RE-ENTRY RECORD Date ~ To Cause' Data From Grade Reason Restructured -~ Steplather/mother ( ) roov KI al if x a 'Wilhtluwel Gma 1 Illneu,? OeMb. ] Lell City, ~ 0utluehan.5 fmanclnl Ddl¢ullref, a Perenlf Wuh, 1 Scnnol nequml a Infliluhnnaheafl.9 nlhar Ilnaurm Namo .~_1i5 fol t _,_ ---....-.-- -------.._-t~-x.'<~Lt<1L-.....-- ---------Catherine.----.-.. Lasl Firsl Muldlo ACADEMIC ACHIEVEMENT YEAR --- 4l - - ORADE K.. _ - -- - - - - R~Npkn-'---- / -~` - - - - Int~petMLmgunpeAns - -- - Medlernatks -- - - - ScNncrlNSM' - - -- soausruaes A - - - -- _ ~ A - -- - - - Mush _ y A 11 - Php. EdAlesAh' -- GompASr - - - - cu,~P.,rt~,a~~w~we+a A g - - -- Clrnchr fm~utlW s~wrroo,~, A ~} -- -- Day~AM~M 1'1 - I~ _ _ TMM. u« .- I I - _ - pROAIOTED _ Yom. - 'HaaNh may 6e correlated with Science and/or Phys, Ed. MARKINQ CODE A • 93.100 • Excellent B • 85.92 • Above Average C • 75.84 • Average D • 70.74 • Below Average F • Below 70•Unsatlsfactory/ Falling PreK - K Grades A Almost Always S Sometimoa N Not yet 11 report card Is to be mailed to atherparent, use address listed below. ~Yas -No (Name) (Address) Icily/Slsle/Zip) Regular Educadan ModiScsttiotts/AdaptadoYts ~~~~~~~ ~~ ~~ ~ ~ ~~ INSTR[iCTIONAL AAAPTATIONS Accompany oml diredloro with vsrilter dirodiom - Aitemadvea t0 Wfrtlag (tap y • ~ ' ~ ~ Amouat Of homework modlBed I AwlgnmesK sheet or aatebook / Droak complex dLectioae end coatmrt lato steps /' CarbanJma notebook paper for notetaking Cue student intermittently to return to lock t/ - - ProferartLl swtiag " ct . s L ~ _~ Provide roasanable e~drr time for task compledoa ~,/ Shortened writing aaignmeata ;/ -- ~ GRADQVGITETING/COUILSE MODIFICATIONS j Reasonable additional dms to compile testa/ename ~ AJtow students to take test In resource room -.~~~~, I Faams/9uizzwtests to begiven orally ModlHed gradlog ayotem . e.g. Paaa/Fail ~ Modll3ed mastery levels Oral teparta Substitute pmjecta !br test ~ Usa study guide/sheua ,/ 7 ' Suppiemantal teutts and materials INELIYCATION u ~•.~~ ww provtce coctor's Waemeet, correct dosage and supp to be administered at sdrool aader acbooi supervialoa acoording to the di.ed.r ~. ....11_.. -- --"---"- Mawau.e:.a 8dueaeon Propnm Farmer PEF - Aus~t tt~ PAOQ,,,~OF~ VI, LEAST RESTRICTIVE ENVIRONMENT (LRE) 4. PARTICIPATION IN STATE AND DISTRICT-WIDE ASSESSMENTS; ^ Student will participate in Slate and distdct•wide assessments without accommodations. ^ Student will participate Instate and dlstdcl•wido assessments with the following accommodallolts: Education progress of the student will be assessed through the following alternate method(s): B. EXPLANATION OF THE EXTENT, IF ANY, THAT THE STUDENT WILL PARTICIPATE AND NOT PARTICIPATE WITH CHILDREN WITHOUT DISABILITIES IN THE REGULAR CLASS OR IN THE GENERAL EDUCATION CURRICULUM: PARTICIPATION IN REGULAR EDUCATIOWGE^IERAL EDUCATION CURRICULUM PARTICIPATION IN SPECIAL EDUCATION READING ^ SPELLING LUNCH ^ RECESSlBREAK READING SPELLING ACADEMIC ENRICHMENTRriS ^ LUNCH ^ ENGLISH ^ HANDWRITING [] ASSEMBLIES ^ LIBRARY ^ ENGLISH ^ HANDWRITING ^ RECESS ^ ASSEMBLIES ^ MATH ^ SCIENCE ^ HOMEROOM ^ ART t-J MATH (] SCIENCE ^ LIBRARY ^ SOCIAL STUDIES ^ MUSIC ^ SOCIAL STUDIES ^ HOMEROOM ^ ART ^ HEALTH ^ UNIFIED ARTSIMS ^ PHYSICAL EDUCATION ^ ACADEMIC ENRICHMENI'IMS ^ HEALTH ^ BASIC STUDIES CLASSMS ^ MUSIC ^ PHYSICAL EDUCATION ^ ELECTIVES [] ALL ^ VOCATIONAL EDUCATION ^ GIFTED SUPPORT SERVICES SPEECH LANGUAGE SUPPORT C. PLACEMENT: 1. Appropriate Group:_Eearnina Support ~:` Level of lntervention:_S~aPPletaental Int=rvention in the Resource Instructional Environment °-~ 'Services absences, and 3. LocaNonoflntervention:keaular school which L•he student would attend if not exceptional. IndleWuallzed Education Program Formal (IEP - Auguat i9Be) PAGE CIF QR ^ Student will not participate in stato and district•wide assessment because: t n e~c „ ~\ ... RESENT EDUCATIONAL LEVELS V Q L h N ~ . . ~ e ~ ~ Ben Armolt eurrently attends !iT'GT~. grade a St. Patrick's school. He is in second grade. He receives reading support and speech and language. He has been receiving reading support and speech and language si~tce first grade. Ben seems to follow class rules, competes homework, is prepared for class, accepts help when offered, interacts with adults appropriately, accepts responsibiliL•y far own actions, responds to praise and reinforcement, attends school on a regular basis, and ~ participates in extra help sessions when offered. Hen likes the computer. He stays foeused when working on the computer. He is very verbal. Ben does put .forth effort even when he struggles. Ban likes art, science, enjoys watching educational shows on PBS. He is friendly and active. i Ben frustrates very easily and then wants to glue up. He doesn't want to try if he thinks something will be too hard. He tends to avoid challenges, has some nervous habits. He seems to worry. Ben has difficulty taking tests, with independent study skills, ' the ability to work independently, has difficulty picking up new t' concepts, has difficulty with reading comprehension skills, and is ~~ not able to read grade level materials. His written language skills axe not on grade level. N He currently works in the FIoughton Mifflin Readiuy Series, Saxon } Primary Mathematics. Reading abilities are significantly below grade level. Academic achievement is noted to be on grade level in the areas of math reasoning and listening comprehension. Dasic word ~~ identification and reading passage comprehension is developed ~_ significantly below grade level expectations. For speech present educational levels please see attached G evaluation from CER dated 3/2/99 . _ Ben did a page in Miss Cunard's room of subtraction facts and and also sentence Formation, punctuation. He is able to write his name in cursive, is able to write on the. line. Hen is able to copy words from a page though he did repeat is. He was able to capitali2e the beginning of the sentence and put a period at the end. He completed two sentences in cursive without slant. He completed two sentences in print. ~ ~~.a eww<i...~ .nan..J.~.:,.~ .Q.Uve~ ~~ bL 2. I ~''~ ~.l~ - 3.o j Se~~~~~v'~ .~ RATES OF ACQUYSYTION Rotas of Retention Ben aquires new information below grade level. Ben needs 3 to 5 repetitions to retain new information. THE STUDENT"S DISABILITY AFFECTS INVOLVEMENT AND PROGRESS IN THE GENERAL EDUCATION CURRICULUM IN THE FGLLOWING WAYSs Classroom reading difficulties and speech difficulties have the potenti: to affect class participation, peer interaction and self esteem, and ability to complete reading work with satisfactory grades. V. SPECIALLY DESIGNED INSTRUCTION, RELATED SERVICES AND SUPPLEMENTARY AI AND SERVICES. ,~ A. PROGRAM MODIFICATIONS(Physical Domain/Social Domain/Educational Dom. AND SPECIALLY DESIGNED IN5'1'RUCTION: SUBJECT SPECIALLY DESIGNED INSTRUCTION ~ - --- Reading One to one instruction Small group instruction Manipulatives - flash cards Computer Aide available Visual and verbal cues Repetition and reinforcement of instruction Testing adaptations Communication between the teacher and Learning Support Adaptations to regular classroom tests as needed IV. GOALS ANl) OBJECTIVES: (Use as many copies of this page as needed to plan for the student). Student Name Benjamin Armolt _ IBP GOALS ANa OBJECTIVES Annul GoaUProgross Report Form ANNUAL ooA~t subJectArea Aeadina Benjamin will be able to, when provided with a story at the 1-2,2-1,2-2 3_I level, read the story orally and silently, with 80 percent accuracy. _. PROGRBS$ REPORT e/Benchmark otl l Ob l ~ ~ ~ ~ '~ ~ ~ ~ g c ~ ~ jo v ona Short•lorm Inatruat ~ ' ' ' ~ (with expected levels o} achievement, $ ~ 3 ~ 3 e 3 evaluation schedule and method of evaluation) g ~ ~ N 3 r 3 >t ~ x When provided with a story at the 1-2 le el, Benjamin will be able to read all words orally, with auditory cues of no more th n three, with 80 percent accuracy, when tested every nine weeks. When provided with a story at the 2-1 level, Benjamin will be able to read all words orally, with auditory cues of not .. -:~ more than:theca, with 80 percent accurac when tested every nine weeks. When provided with a story at the 2-2 level, Benjamine will be able to read all words orally, witty auditory cues of no more than three, with 80 percent accuracy, when tested every nine weeks. When provided with a story at the 3-1 level, Benjamin will be able to read all words orally, with auditory cues of no more than three, with 80 percent accuracy, when tested every nine weeks. Indlvldwll¢~d fidua~tlon Piagnm formrl pEP - Augud 1909( PAOE__ OF _~ IV, 13OALS AND OBJECTIVES: (Use as many copies of this page as needed to plan for the student). Benjamin Armolt SubloctArea, Reading Student Neme_ ~ __~__~_ --- IEP GOALS AND O~JECTIVBS Annual OoallProgroras Rrapar! Form ANNUAL GOAL: Benjamin will be able to, when provided with 100,200, and 300 sight vocabulary words, read all sight vocabulary words, with 80 percent accuracy. PROORES 8 REPORT ctlvN®enchmark l Ob ti ~ ~ ~ g ~ 6 ~ ~ ~ e ona Short•tstryn Instruc (with expected levels of achievement, a ~ ~ ~ e o evaluation schedule and method o} evaluation) g ~ 3 ~ » ~ ~ ~ When provided with sight vocabulary using flash cards and reading activities, Benjamin will be able to read 100 sight vocabulary words, with BO percent accuracy, when tested every 9 weeks. When provided with sight vocabulary usin flash cards and reading activites, Benjamin will be able to read 200 sight vocabulary words with 80 percent accurac when tested every nine weeks. When provided with sight vocabulary, Benjamin will be able to read 300 sight vocabulary words, with BO percent accura y when tested every nine weeks. IndlvWurallnd Edua~llon Program Fmmtl (IEP - Auquet tgen) PAOE_ OF __ i tV. OOALS ANO OBJECTIVES: (Use as many copies of this page as needed to plan for the student). {I';~ 8tudentName Benjamin Armolt T__ SubJectArea &eading ' ,~ IEP OOALS AND OrJECTIMES Annual QoallPrognss Report Fo-m ~ f ANNUAL OOALo When read a story, Benjamin will be able Co tell five details pf the story with 80 percent accuracy. r PROGRESS REPORT Short•b-m Instructional ObJoctivo/Brtnchmark ~ ~ ~ ~ ~ ~ ~ ~ ~ ° ~_ ~ (with expected levels of achievement, g ~ ~ 3 ~ ~ 0 ~ 3 evaluation schedule and method of evaluation) p ~ ~ ~ K ~ ac ~ a A x S. When provided with a listening activity a d visual cues, Benjamin will tell five details of. the short story with 90 percen accuracy, when tested every nine weeks. IndlvWUrAllz~d Fducglon Proynm Format (IEP - Auyuat 1998) PAOE_ OF ~_ IV. QOALS AND OBJECTIVES: (Use as many copies of this page as needed to plan for the atudentj. F3tudentName Benjamin Armolt _ __„~, SubJectArea Readln9 IEP GOALS AND O..IECTIVES Annual Ooal/Prognso Roport Form ANNUAL AOAL: Benjamin will be able to read independently with 80 percent accuracy. Short-term Instruotlonal Objoctivo/sonchmark (with expected levels of achievement, evaluation schedule and method of evaluation) When given a story and ten minutes of independent reading time, Benjamin will remain reading without disruption,,with 80 percent accuracy, when evaluated every nine weeks. IndNklutllz~d Etlucallon Program format (IEP - Auguat 1908) PROGRESS REPORT ~~ ~~ ~~ ~~ ~N ms ~~ ~~ as ~.c ~~ s~ ~~ I ~X ~.T ~~ x PAQE___ OF,_ IV. GdALS AND 08JECTIVES; (Use as many copies of this page as needod to plan for the student). 9tudentName Benjamin Armolt ~ Readiny ----------.-~_ ..ublect Area_.__ IEP GdALS AND Os•tECTIVES Annual t3oal/Prognaa Report Form ANNUAL tiOALa Benjamin will be able to read new vocabulary accuracy. at the 1-2 Level with 80 Benjamin will be able to read new vocabulary accuracy. at the 2-1 level with pert BO Benjamin will be able to read new vocabulary at the 2-2 level with perc 80 accuracy. 3-- per PRO ~ ORBS S REPO RT Short-farm InatructlonaA pb)aatty/lanchmark ~ °a i ~ ~ ~ ~ ~ ~ ~ ~ u ~ ~ (w th effected levels of achievement ~ a; ~ d , a ~ evaluation schedule and method ~! evaluation p n ~ ~ ~ ~ V K ~ ~ &~ a ~~ ~ ~ ~ ~ , When provided with 20 flashcards with vocabulary at the 1-2 level, Benjamin will be able to read words orally with verbal and visual cues, with 90 percent accuracy, when tested every nine weeks. When provided with 20 flash cards with vocabulary at the 2-1 level, Benjamin will be able to road words orally and with visual and verbal cues, with 80 percent accuracy, when tested every nine weeks. When provided with 20 flash cards with I vocabulary at the 2-2 level, Benjamin wi1]. be able to read words orally with verbal and visual cure, with BO percent accuracy, when tested every nine weeks. When provided with 20 flashcards with vocabulary at the 1-2 level, Benjamin will be able to read words orally, with no visual or verbal cues, with 80 percent ! accuracy. When providsd with flash cards with "' vocabulary at the 2-1 level, Benjamin ~~ no verbal or visual cues, with 80 percent (~ accuracy, when tested every nJ.ne weeks. a Indlvlduallzad EducNlon Program Format (IF.P _ quguat 1998) PAOE_ OF 4 ,... ~, y{:n; IV, OOAL,5 AND OE~.IECTIVES: (Use as many oopies of this page as needed to plan for the student), SludentName Benjamin Armolt Reading '-' - _._._. Subject Area_ I!P OOALB AND p~.1lCTIVlS Annual Gloal/Progrs~e Roport Form ANNUAL. GOAL: New vocabulary PROGRl88 RlPORT Short•brm Inetruotional pbjectivs/Benchmark ~ ~ ~ ~ ~ ~ ~ f5 ~ a ~ ~ (with expected levals of achievement, ~ ~ ~ ~ as o It, ~ evaluation schedule and method of evaluation) ~ ~ ! 3 ~ ~ ~ ~ K >R When provided with 20 flash cards with e vocabulary at the 2-2 level, Benjamin will be able to read words with no verb ] or visual cues, with 80 percent accurac , when tested every nine weeks. IndlvWuellzed Educellon Program forrnat (IEP - August 19Be1 PACIE__ OF _^ IV. GOALS AND OBJECTIVES: (Use as many copies of thla page as needed to plan for the atudent). StudentName~ Aen amin Armol.t ~ SubleatArea Reading ANNUAL OOALt 18P GOALS AND OBJBCTIV88 Annual Ooal/Progroos Report Form When given a story at the 1-2, 2-1, 2-2, 3-1 level, Benjamin will be able to orally and silently read a passage, answering ten comprehension questions, with 80 percent accuracy. PROGRESS REPORT Short•brm Instructional Objective/Benchmark ~ ? ~ ~ ~ ~ ~ ~ ~ `" a ~ ~ (with expected levels of achievement, ~ ' } ~ ' ~ ~ ~ °, ~ ' ° evaluation schedule and method of evaluation) ~ ~ a ~ 88.. When provided with a story at the 1-•2 level, Benjamin will be able to read the passage orally answeeing 1.0 comprehension questions with 80 percent accuracy, given verbal and visual cues, when test every nine weeks. When provided a story at the 2-1 level , Benjamin will be able to read the passage orally answering 30 comprehension questions with 80 percent accuracy, given verbal and visual cues, when tasted every nine weeks. When provided with a story at the 2-2 lev 1 Benjamin will be able to read the passage orally answering 10 comprehension questio s with 80 percent accuracy, given vernal and visual cues, when tested every nine weeks. When provided a story at the 3-1 level, Benjamin will be able to read the passage orally answering 10 comprehension questio s with 80 percent accuracy, given verbal and visual cues, when tested every nine weeks. Indivlduallx~d Eduction Nropnm Formst (II:P - Aupuet 1998) PAOE_ OF! IV. GOALS AND OBJECTIVES; (Use as many copies of this page as needed to plan for the student). Student Name` Denjatnin Armolt __, SubJectArea Reading 1^P GOALS AND 0^J^CTIdHS Annual OoatlP-ogrooo Roport Form ANNUAL OOALo Comprehension skills PROOR^SS REPORT Short•lsrm Instructional ObJocthrol^anchmark ~ ~ ~ ~ ~ ~ ~ ~ ~ (with expected levels of achievement, g ~ 3 ~ ~ '3 ~ ~ w evaluation schodule and method of evaluation) ~ ~ hl ~, r M K .~ ~ (,~[ / When provided with a story at the 2-1,2- 1-2, 3-1 level, Benjamin will be able to read a passage silently, answering 10 comprehension questions with verbal and visual cues, with HO percent accurac , when tested every 9 weeks. When provided with a story at the 1-2, 2-2, 2-1, and 3-1 level. Benjamin will be able to read a passage orally with Qo verbal or visual cues, with 80 percen accuracy, when tested every nine weeks. When provided with a story at the 1-2,2-1,2-2, and 3-1 level, Benjamin w11 be able to read a passage silently, answering 10 comprehension problsms, with no verbal or visual cues. IndlvWUtlbtW Eduoellon Program Format peP -August 1998) PAOE,_„_ OF ~~ IV. GOALS AND OBJECTIVES: (Use ass many oopies of this page as ndeded to plan for the student). StudenlNama Benjamin Armolt Reading _ Subject Area__ IBP GOALS AND ODJSCTIVBS Annual OoallProgns~ Rnpnrt Form ANNUAL ©OAL: When given new vocabulary at the 1-2,2-1,2-2, and 3-1 readiny level, Benjamin will be able to read vocabulary, with 80 percent accuracy. short.tsrm Instructlonol Objoctfve/senehmark (with effected levels of achievement, evaluation schedule and method of evaluation) PROORBSS RlPORT ~a ~x ~X ~~ ~~ ~ When given new vocabulary at. the 1-2,2-1 2-2 2-2, 3-1 levels and verbal and visual sues, Benjamin will be able to read vocabulary with BO percent accuracy, when tested every nine weeks. When given new vocabular.•y at the 1-2,2-2 2-1, 3-1 level, Benjamin will be able to read new vocabulary with no verbal or visual cues, with 80 percent accuracy IndlvWuallred Eduodlon Program Formd (IEP -. Augusl 1fl9e) PADE~__ OF _, ~. VII. DATES A. PROJECTED DATE WHEN SERVICES AND PROGRAMS WILL BEGIN: i 8a/ 3 () / 9 `~ Month Day Year B. ANTICIPATED DURATION OF SERVICES AND PROGRAMS; ~_/_, ~/ ~" - ~..C~ U O SERVICES PROVIDED ON SCHOOL DAYS ONLY Manih Day Yoar C. 7EP REVIEW/REVISION DATE(S) (Document the dales of any revlews/revislons of this IEP) / / Month Day Vear VIII. PROGRESS REPORTING: / / ! / Month Ory Veer Month Day Vear A. HOW WILL SCHOOL REPORT PROGRESS TOWARDS THE ANNUAL GOALS: [~ Regular Report Card ® IEP Progress Report ^ Other,_ ®. HOW FREQUENTLY THE SCHOOL WILL REPORT PROO'RE33 TOWARDS THE ANNUAL GOALS: ~5] Every nine (9) weeks, samo as regular education students ^ Other: IX. EXIT CRITERIA: These are the criteria, which will be used to detennine when a student Is no longer in need of speGal education services. DECISION POINTS: ® No longer requires specially designed Instruction ^ No longer of school age ^ Met designated requirements es specified in graduation plan ^ Other (specify): X. OTHER INFORMATIONlCOMMENTS: Irdlvkuallzed Education program Format (IEP -August 1899) PAOP.~ OF ~_, RICKY L. ARMOLT, Petitioner/Defond ant v. SU5AN E. ARMOLT, Respondent/Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 961-1998 C'1VIL'fERM . IN CUSTODY PRF.-HEARING CUSTODY MEMORANDUM OF DEFENDANT. RICKY L. ARMOLT I, SS„atement of Case; The parties are the parents of three (3) children, being Joshua Armolt, born July 24, 1979, age twenty (20), Benjamin Armolt, born March 10, 1990, age nine (9), and Meredith Armolt, bom April I, 1992, age seven (7). 11. ssue: Whother father will be granted additional lime with Benjamin and Meredith Armolt. III. List of Witnesses: I • Riekv L. Armolt will testify as to the care he provides his children and the love and affection which he has for his children. 2• Ruth F. Armolt will testity regarding the close relationship enjoyed by the father and the children. 3. Richard E. Armolt will testify regarding the strong relationship onjoyed by the father and the children. 4. Beniamin Armolt mill testify regarding his desire to spend time with his father. 5. Meredith Armolt will testify regarding her desire to spend time with her father. IV. Position of the Father; The father requests shared legal custody with both Benjamin and Meredith and a finding of contempt regarding mother's interference with the custody, He also believes a finding of contempt would he a deterrent to mother's repeated attempts to deny the father time with his children. Joshua Arniolt still resides with the plaintiff, Susan Armolt, and Benjamin and Meredith. Unfortunately, Joshua has repeatedly violated the law and is a negative influence on the younger children, The father seeks more time with his children and is willing to equally share physical custody of both younger children with their mother, The mother has repeatedly interfered with the father's relationship with the children. During June of 1999, the mother attempted to deny father time on Father's Day. On Monday, June 21, 1999, the children refused to go with father during his period of custody. When father returned, the mother had taken the children elsewhere. On Monday, June 28, 1999, the mother again refiised to permit the children to go with father, She apparently promised to take them to a movie, Meredith attends private school at St. Patrick's School, Benjamin attends school at Crestview Elementary School. Mother has repeatedly refused father's requests for more lima with the children. A copy of the previous Stipulation and Order of Court are attached as Exhibit "A" and Exhibit "B." 2 v. ~-ac.matod Loneth of Trial: The estimated length of trial is one•half (1/2) day. Respectfully Submitted, IRW1N+ cKNI HT & kll)GHES ~y; Marcus A, Mc night, IIL, Esq. 60 West Pomfret Street Cs+rlisle, PA 17103 (717) 249-2353 Supreme Court LU. No. 25476 Attorney for defendant Ricky L, Annolt Date: January 20, 2000 3 RICKY L. ARMOLT, Petitioner/Defendant v. SUSAN E. ARMOLT, Respondont/Plaintiff ; IN TIIF. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 961-1998 CIVIL'CF,RM 1N CUSTODY CERTIFICATE OF SERVICE I, Marcus A, McKnight, III, Esquire, hereby certify that on this date a true and correct copy of the Pre-Hearing Custody Memorandum of Defendant, Ricky L. Armolt was sowed by first class United Stntes mail, postage paid in Carlisle, Pennsylvania 11013, upon the following: Carol J. Lindsay, Esq. FLOWER, FLOWER Rc LINDSAY ll East High Strcct Carlisle, PA 17013 sy; Dato: January 20, 2000 111, Esquire 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 299-2353 Supreme Court LD. No, 25476 Attorney for Petitioner/Defendant Ricky L, Armolt 4 IRWIN, McKNIGHT & HUGHES SUSAN E. ARMOLT, RICKY L. ARMOLT, Plaintiff vs; . Defendant ; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 98-961 CIVIL TERM IN CUSTQDY ORDER OF COUNT ANU NOW this __ ! 3 day of . pia"~ 1gg6, upon consideration ~ of the within Stipulation of the Parties for Custody, the terms of said Stipulation are hereby j made an Order of Court, i By the Court, F/~, . ~~o~,,.~ J. T~+~c C^PY FR^M RECORD In i~:;;r.m-mv ,.~lr. r.;cf, I L• r• u~,t•~ set my hand end Iha coal of said Court at Carlisle, Pa. This ...,L.... day of:.,~,e, ..`r'.~ ....,..;,,.v~?Mr ~~....a.. Protho o x..19...".' SUSAN E. ARMOLT, IN THE COURT OF COMMON PLEAS OF Plaintltt CUMBERLAND COUNTY, PENNSYLVANIA V5, CIVIL ACTION -LAW NO. 96-961 CIVIL TERM RICKY L. ARMOLT, , :.,i ,~ .. Defendant ; IN CUSTODY' `l ._. - ~, .., .. -~ - ~~~AIION OF 7l~fE PARTIES ~;~;° O CUSTODy_ ' ~' - . ~~ -. The parties hereto are SUSAN E. ARMOLT, of 1310 Hnlly Pike, Carlisle, Pennsylvania 17013, hereinafter Mother; and RICKY L. ARMOLT, of 9 Kimberly Lane, Carlisle, Cumberland County, Pennsylvania 17013, hereinafter Father. The parties stipulate as fellows: 1. They are the parents of Joshua Armolt, born July 24, 1979; Ben)amin Armolt, born March 10, 1990; and Meredith Armoit, born April 1, 1992. 2. The parties shall share legal custody of said children. 3. Mother shall have primary physical custody of said children, and Father shall partial custody on the following schedule: a. Every other weekond from Friday after school until Sunday at 7;00 p.m, b. Every Monday and Wednesday from after school (3:00 p.m. during school vacations) until 7:00 p.m. In the event that Mother requires child care while she works, she will give to Father or to his parents the right to care for the children at other times than those set out In this Order before using a paid babysitter•. c, Unless otherwise agreed by the parties, three non-consecutive works per year with 30 days notice to Mother. Mofher will also give notice to Father when she intends to take weeks of vacation from her work with the children. and on Labor Day and In d, In even numbered years on New Year's Day ears on Memorial Day and the FourtearsJonyMemohlal odd numbered Y of the children in even numbers ears on New Year's shall have custody pay and the Fourth of July, and in odd numbers y Day and Labor Day. and Easter during one of two blocks of tl ~ °and the On Thank.,giving from 9:00 a.m. to 2:00 p• e, The parties shall holidays; the first blob ome2 DO p m. tc 7:00 p•m• second block being iGen year, so that in evinn alternate, these blocks of time in a g ndd numbered years, ears Father will have the morning block on Thanksg' g numbered y and the afternoon hl°ck on Easter, an in Mother will have the morning block an Thanksgiving and the afternoon block on Easter. from 9:00 a.m. to 7:00 p•m• Mother shall have f, Every Father's Day to 7;00 p.m. every Mother's Day from 9:00 a.m. eriods On alternating periods of limo at Ghristmas, the first of sal p m, to Christmas Day at 1:00 g' from Christmas Eve at ~ :00 p' from Christmas Day at extending eriods extending eriods of time shall p,m, and the second of such p m These p ttre eriod 1:00 p•m• to December 26th at 1i 009 8 with Mother having at 1;00 alternate annually, commencing' m, and Christmas DaY of limo between Christmas Eve at 1:00 p• f p.m. sand eriods of partial custody specially set ° ecedence dever the h, Thep and Father's Day shall tako p Mother's Day artial custody schedule as set out alternating weekend and mid-week p In Paragraphs A and B above. artles shall agree, i, At such othor times as the p he artles shall say nothing In the presence of the chiidron, nor shall they do 4, T p and the children havo for oach I thin in the presence of the children which will injure the f °g in the hearing of the children. any 9 parent. The parties will not discuss economic or divorce issues with re sous a The artles acknowledge that breach of this term of their Stipulation shall be as ey 9 1 p as set out herein, violation of the Court's Order as failure to provide custody !~ 5. This Agreement may be entered as an Order o} Court, wrrNess: •Susan E, Armpit ~~ -'•~ Ricky L. Armolt VERIFICATION The foregoing Petition for Custody is based upon information which has bean gathered by my counsel and myself in the preparation of this action, [have read the statements made in this document and they are tnie and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S,A, Section 4904, relating to unswom falsification to authorities, t;~' ~ i .--~ aICK~ OLT RICKY L, ARMOLT, IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V, SUSAN E. ARMOLT, DEFENDANT' 98-0961 CIVIL ORDER OF COURT AND NOW, this ~-~ day of August, 1999, following a hearing, the custody order entered on April 13, 1998, is amended to add this following additional paragraph: Benjamin Armolt shall attend public school and Meredith Armolt shall attend private school, By the Court,/~ , Marcus A. McKnight, III, Esquire For the father Carol J, Lindsay, Esquire For the mother :saa Tf'.lIT C~+TY fi;r?k1 REGARD In 1't~i,a ~i ~. h, ~ ~f; I hen: unto set my hand and Ihu seal n( sah.l Court at Carlislo, Pa. this ..~7x'f' dray of..~~.,.,,,., 19..,~~ ~ Prothunovvfary Edgar B, Bayley, J~', dWorce annolt dro January 20, 2000 ~1pN '~ ]. 20D0 h/~7 SUSAN E. ARMOLT, vs. RICKY L. ARMOLT, AND NUW, this 2~ day of follows: Plaintiff Defendant ; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0. 98 - 961 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE 2000, it appears to the Court as 1. The parties hereto who were husband and wife, seek this Order in conjunction with a final degree of dissolution of marriage dated August 11, 1998 in that action pending in this Court at the above number. 2. Ricky L. Armolt, Social Security Number 200-36-8449, hereinafter referred to as Defendant ar Participant, is presently employed by Dickinson College and is a participant in the Teachers Insurance and Annuity Association-College Retirement Equities Fund, hereinafter 'I'iAA-CREF, having the following Retirement Annuities: CREF RA Certificate JI V045539-F. 3. Participant's current and last known mailing address is 9 Kimberly Lane, Carlisle, Pennsylvania 17013. 4. Susnn Armolt Kuntz, Alternate Payee, has a current and last known address of 148 Chester Street, Carlisle, Pennsylvania 17013, and Social Security Number 182-40-8089. 5. To accommodate the marital/community property distribution between the parties, IT !S ORDERED, ADJUDICATED AND DECREED AS FOLLOWS: A. Thet the T1AA-CREF annuities previously referenced are marital property; B. That subject to the execution of the documents required by TIAA-CREF and the terms of said annuities, the following portions shall be awarded to the alternate payee as sole and exclusive property to he applied to TIAA-CREF annuities subject to the terms and limitations of said annuities: Ten 'Thousand ($10,000.00) Dollars with earnings or losses thereon from July 9, 1998 until transfer to Alternate Payee, The values actually transferred will reflect interim interest and dividend earnings in 'TIAA, E~ ~J Op•hz"-l ("°' u~,~ ~y~ ~~' ;~ j •aano~ ;o xap,~p se pa~a~ua aq 6ew o~aaaq payoeaae aapap suo;~aTay oTasawo~ PaT3FTenb a47 ~E~17 aa~Re oaazay saT~zed ayZ ~R~NRNe(1~NU~ •tapto still a~naaxa o3 papaan s8 stapto raging anssl oa aonolpspn[ santasat ~.ato~ snl1, •~ •taptp saon8la~ orlsamoQ pagllectj~ a aq oa paalmta3ap ~Slsnolnatd taptp tagloa8 tapan aa~Sed aieata~ro tagioae o~ pled aq of patmbat ate golgm aa~ied a38uia~lb' ue oa slgaaag3o laam~Sed aq~ atmbat aoa swop •o `.pue s~ganaq paseatarrl aplnotd oa d~~-may atmbat lotr saop •q :pae 'aeld aq> tapan paplnotd osubtaq~o you `condo ~iae to ygaaag3o cuto3,~o adu Sae apinotd o~ aeld Sae atmbat ioa saoQ •e :taPta s!q.L '9 •tapto slg3 azll8ag o3 (3~I~-t~'I.L ~9 patlnbat,;)J sasealag 8alpnlam `s~aamnaop Ile 3~~-yyjZ o; ~rtagns ~SlaaQn 03 pa~atlp ate salyted oqZ •o :tuedToTaae~ 'aTowzV 'Z ~KoT1l '?17gdJ o~ eaolaq If!M ~~ '`dVI.L ~q Panssl s~aet~aoa 118 al saollelnwnao8 agl,~o aaoeleq aql m ~sataaal pa8 dnlsta!t,Ho IItF' 'jr3Xt~gj;~l eaolaq llvn sanlnaue panssl ~tlmaa aq~ m s~q8~~ dnlstaanno IPv' '332I~-t+`dI.L q paptooat sl ta,~saeti acp pun d321J ul aouauadxa yaam3sanat pae ~• -' ~-, , y~ a,~tot~ty •a rtvsns ~ I, ~ U,n(mIC` - r ~~ ~i divorce armolt dro Januory 20, 2000 QETERMINATION AS TO rnrALIFlCATIO~ Df: DOMCST/C X~ZA ION5~DH~ N T/CE ~ PART/L7PAN,~ AND ALTERNATF, PAYEE 1~NQ GREEMFNT TO COM!'I Y W/Tf~R Pursuant to the requirements of the Retirement F'quity Act of 1984, TIAA-CREF, as the funding vehicle for a retirement plan in which Ricky L. Armolt is a participant, hereby states as follows; 1, The attached Order of the Court of Common Pleas of Cumberland County, Pennsylvania, dated _, 2000, is a Qualified Domestic Relation Order; and 2, The Participant and the Alternate Payee are hereby notified as to the qualifications of said Order; and 3• The undersigned will comply with all of the applicable terms and conditions of said Order upon receipt of the proper documentation. Dated this __ day of ~, 2000. r i fcr TIAA-CREF E :,, I _'_ RICKY l.. ARMOLT, : IN'fHE COURT OF COMMON PLEAS OF Petitioner/Defendant :CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL AC'CION -LAW 961-1998 CIVIL TERM SUSAN E. ARMOLT', , Respondent/Plaintiff IN CUSTODY P~tE-HEARING CUS'fOllY MEMORANDUM OF UEFENDAN'f, RICKY L. ARMULT I. Statement of Case: The parties are the parents of three (3) children, being Joshua Armolt, born July 24, 1979, age twenty (20), Benjamin Armolt, born March 10, 199Q age nine (9), and Meredith Armoit, born April 1, 1992, age seven (7), II. Issue; Whether father will be granted additional time with Benjamin and Meredith Armolt, j III. List of Witnesses: 1. Rlckv L. Armolt will testify as to the care he provides his children and thr, cove and affection which he has for his children. i 2. Muth F. Armoit will testify regarding fire close relationship enjoyed by the father and the children. ; 3, Richard E. Armolt will testify regarding the strong relationship enjoyed by the father arul the children, 4. Bon min Armoit will testify regarding his desire -o spend time with his father. 5. Meredith Armolt will testify regarding her desire to spend time with her father. IV. Fosition of the Father; The father requests shared legal custody with both Benjamin and Meredith and a finchng of contempt regarding mother's interference with tho custody, He also believes a finding of contempt would he a deterrent to mother's repeated attempts to deny the father tune with his children. Joshua Armolt still resides with the plaintiff, Susan Annolt, and Benjamin and Meredith. Unfortunately, Joshua has repeatedly violated the Inw and is a negative influence on the younger children• The father seeks more time with his children and is willing to equally share physical custody of both younger children with their mother. The mother has repeatedly interfered with the father's relationship with the children. During June of 1999, the mother attempted to deny father time on Father's Day. On Monday, June 21, 1999, the children refused to go with father during his period of custody. When father rehimed, the mother had taken the children elsewhere, On Monday, June 28, 1999, the mother again refused to permit the children to go with father, She apparently promised to take them to a movie. Meredith attends private school at St. Patrick's School. Benjamin attends school at Crestview Elementary School, Mother has repeatedly refiised father's requests for more time with the children. A copy of the previous Stipulation and Order of Court are attached as Exhibit "A" and Exhibit "B," V. ~stlmated IGent[th of Tr1a1; Tha estimated length of hint is one-half (I /2} day, Respectfully Submitted, -~ ` „~ By: Mar us A. Mc 1ght, III, Esq. 60 est Pomfret Street Carlisle, PA 17103 (717) 249-2353 Supreme Court LD. No. 25476 AtG>mey for defendant Ricky L. Armolt Dtito: January 20, 2000 3 RICKY L. ARMOLT, Petitioner/Defendant v. SUSAN E. ARMOL,T, Respondent/Piainti ff IN THE COURT OF COMMON PLF,AS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 961-1998 CIVIL'PERM IN CIISTOUY CERT'IFIC'ATE OF SERVICE I, Marcus A, McKnight, III, Esquire, hereby cciiify that on this date a true and coreect copy of the Pre-Hearing Custody Mernorandum of Defendant, Ricky L. Armolt was served by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, upon the following; Carol J. Lindsay, Esq. FLOWER, FLOWER & LINDSAY ' II East High Street Carlisle, PA 17013 i j 1RWIN, McKNIG T & HUGHES ~~~ Date; January 20, 2000 By: Marcus A. Mcht, III, Fsgnlre 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717)249-2,353 Supreme Court I.D, No. 2547ti Attorney for Petitioner/Defendant Ricky L, Armolt 4 SUSAN E. ARMOLT, RICKY L. ARMOLT, Plaintiff vs: Defendant ; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSXLVANW CIVIL ACTION -LAW NO. 99-961 CIVIL TERM IN CUSTQDY Q$~ER G+E' COURT AND NOW this / 3 da of ___~~a;~-_ ~ Y ,, 1998, upon ronsideratlon of the within Stipulation of the Parties inr Custody, the terms of said Stipulation are hereby j made an Order of Court. ' ey the Court, 0 J. T!'tlr C:~PY F(t^M RECQRD In T:~;a.mony ..q,:,;ci, I Irr~ urro set my hand and Iha coal of said Curt at Carlisle, Pa. This ...,ham.. day of,~~',rz;,~~. .,~~ ,~ .Prothonotary ~" SUSAN E. ARMOLT, ; Plalntitt vs, RICKY L. ARMOLT, ; Defendant ; IN THE COURTOF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL AGTION -LAW NO. 98-96'1 CIVIL TERM IN CUSTODY '- i .. --. - -, ..~ ,= - ._. ~; ;~ .J -. .,.~. /P ~I'/ON OF THE PART/€S fOR CU TODY The parties hereto are SUSAN E. ARMOLT, of 1310 Holly Pike, Carlisle, Pennsylvania 17013, hereinafter Mother; and RICKY L. ARMOLT, of 9 Kimberly Lane, Carlisle, Cumberland Counfy, Pennsylvania 17013, hereinafter Father. The parties stipulate as follows: 1. They are the parents of Joshua Armolt, born July 24, 1979; Benjamin Armolt, born March 10, 1990; and Meredith Armolt, born April 1, 1992. 2, The parties shall share legal custody of said children. 3, Mother shall have primary physical custody of said children, and Father shall partial custody on the following schedule: a. Every other weekend from Friday after school until Sunday at 7:00 p.m. b. Every Monday and Wednesday from after school (3:00 p.m, during school vacations) until 7:00 p.m, In the event that Mother requires child care while she works, she will give to Father or to his parents the right to care for the children at other times than those set out in this Order before using a paid babysitter. c, Unless otherwise agreed by the parties, three non-consecutive weeks per year with 30 days notice to Mother. Mother will also give Helios to Father when she intends to take weeks of vacation from her work with the children. ,F~ ;, .~ ;..-, d. In even numbered years on Naw Year's Day and on Labor Day and in odd numbered years nn Merorial Day and the Fourth of July, Mother shall have custody of the children in even numbered years on Memorial Day and the Fourth of July, and in odd numbered years on New Year's Day and Labor Day.. e, On Thanksgiving and Easter during one of twa blocks of limo on those holidays; the first block being from 9:00 a.m. to 2:00 p.m„ and the second block being from 2:00 p.m, to 7;00 p.m. The partles shall alternate these blocks of time in a given year, so that in even numbered years Father will have the morning block on Thanksgiving and the afternoon block on Easter, and in odd numbered years, Mother will have the morning blork on Thanksgiving and the afternoon block on Easter. f. Every Father's Day from 9:00 a.m. to 7:00 p,m. Mother shall have every Mother's Day from 9:00 a.m. to 7:00 p.m. g. On alternating periods of time at Christmas, the first of said periods extending from Christmas Eve at 1;00 p.m. to Christmas Day at 1:00 p.m. and the second of such periods extending tram Christmas Day at 1:00 p.m. to December 26th at 1:00 p.m. Thes© periods of time shall alternate annually, commencing in 1998 with Mother having the period of time between Christmas Eve at 1:00 p.m. and Christmas Day at 1:00 p.m, h. The periods of partial custody specially set out for holidays grid Mother's Day and Father's Day shall take precedence over the alternating weekend and mid-week partial custody schedule as set out In Paragraphs A and B above, i. At such other times as the parties shall agree. 4, The parties shall say nothing in the presence of the children, nor shall they do anything in the presence of the children which will injure the regard the children have for each parent. The parties will not discuss economic or divorce issues within the hearing of the children. The partles acknowledge that breach of this term of their Stipulation shall be as egregious a violation of the Court's Order as failure to provide custody as set out herein, 5. .This Agreement may be entered as an Order of Court. WITNESS; •Susan E. Armolt/~ ' ~ Ricky t., Armolt The faregoing Petition far Custody is based upon inforrnation which has been gathered by my counsel and myself in the preparation of this action. 1 have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. 1 understand that false statements herein made are subject to the penalties of 18 Pa. C,S.A. Section 4904, relating to unsworn falsification to autlwrities. ~..~ /._~_ ~ i KICKY L; AR OLT Date: MAY 20. 199 RICKY L, ARMOLT, : IN T••IE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. SUSAN E. ARMOLT, ~ gti-0961 CIVIL DEFENDANT hORDER OP COURT AND NOW, this ~- I day of August, 1999, following a hearing, the custody order entered on April 13, 1998, is amended to add this following additional paragraph: Benjamin Armolt shall attend public school and Meredith Armolt shall attend private school, ~ By the Court, ~~ ~ Edgar B. Bayley, ,I> ., Marcus A. McKnight, III, Esquire For the father Carol J. Lindsay, Esquire For the mother aaa '1"i t'". ,~;`3^~~ fi',f)A4 i'tECfaRD InT~:~~ ~ .i ` i ~ ~;, I hr urln sat my hand anti Iho c.nl o[ <<~.I ~o~-irt ~t (arlisVe, Pa, ~ Y ....., 19..,1.E This ..., ...7x'~' da oE....Q, . ~..,..,...o.~ta.~....r.... ~ Prothoirotery P ^ Suean Armoll (Prodraarin;r Memorandum) SUSAN E. ARMOLT, Plaintiff vs. RICKEY L. ARMOLT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -- LAW N0. 98.961 IN CUSTODY PLAINTIFF'S PRE•HEARING MEMORANDUM 1. History of the case The parties hereto are the parents of three (3) children, Joshua Armolt born July 24, 1979, Benjamin Armolt born March 10, 1990 and Meredith Armolt born April 1, 1992, Joshua, now twenty years of age, was adoptad by the Defendant/Father in the course of the parties marriage. Father and Joshua are now estranged. °fhe parties separated on January 15, 1998 and divorced on August 11, 1998, On August 13, 1998, this Honorable Court entered an order for the custody of the two minor children, Benjamin and Meredith, Tho order was entered on the Stipulation of the Parties and a copy of it is attached to this Memorandum. The order called for the parties to share legal custody and for primary physical custody of the children to be in Plaintiff/Mother with rights of partial custody irl Father on alternating weekends and Mondays and Wednesdays after school from 3;00 p. m. until 7:00 p.m. Father also enjoyed three nonconsecutive weeks of custody of the children through the year and curtain Holidays. In the spring and summer of 1998, the children began a pattern of refusal to visit with their Father. Maktors were exacerbated by Father's refusal to speak to Mother, his refusal to aid in the transfer of the children when they were crying and clinging to Mother and his threats to transfer January 17, 2000 custody of the children from Mother to himself. Suaa~n Armalt (Pro•hoerln0 Meimorandum) JEnwary i%, 7000 Further, Bonjamin, who had also suffered with learning disabilities, developed an eating disorder. Mother obtained counseling for the children, Their• aversion to visits with the Father continued with resulting in Father's filing a Petition for Modification of the Custody Order and to hold Mother in Contempt of Court on Juno 19, 1999, and on June 21, 1999. Father also filed a Petition to resist the transfer of the children from St. Patrick's Elementary School to public school as requested by Mother. On August 27, 1999, following a brief hearing, this Court ordered that Benjamin should attend public school and that Meredith should attend private school. A further conciliation was held by telephone on October ?.6, 1999, on the Contempt and the Modification Petitions. No resolution having been effected by the conciliation, a hearing is set for January 27, 2000 at 8:45 a.m. on Father's Petition for Modification of the Custody Order and for Contempt. This Memorandum is submitted in anticipation of the January 27, ?.000. 2. Issues a. Whether Mother is in Contempt of Court as a result of her actions on June19, 1999, and June 21, 1999. b. Whether the best interests of the children would be served by providing primary physical custody to or shared physical custody with Father. 3. Witnesses 1. Susan Armolt Kuntz: Ms. Kuntz is the Mother of the children and will testify regarding their estrangement from their Father, and the children's difficulty bonding with their Father. 2. Susan McGraw, MSW; Ms. McGraw is the children's therapist. Ms. McGraw will testify regarding the children's relationship with their parents. 2 II Susan Annoll (pro•hoarln~ Memorandum) January 17, 2000 3, Carol Kuntz-Wallick: Ms. Kuntz-Wallick is the children's makernal grandmother who is also their child care provider on occasion. She will testify regarding the circumstances of the transfer on July 19, 1999 and the relationship between the children and both of their parents. 4. Ann Hawbaker: Ms. Hawbaker vvill testify to the children's relationship to their parents. 5. Mother reserves the right to call additional witnesses with advance notice to Father of their identity and the substance of their testimony. Respectfully submitte~f, FLOWER, FLOWER & LINDSAY Attorneys for Plaintiff By: ~ r~ n say, squir© 11 Eaat`High Sfr et Carlisle, PA 17013 (717)243-5513 LD.#44693 3 ~ a ~~ _.'.M.- SUSAN @. ARMOLT, IN THE COURT OF COMMON PLEAS OF PlalntiH CUMBERLAND COUNTY, PENNSYLVANIA ve. CIVIL ACTION • LAW NO. 98-981 CIVIL TERM RICKY L. ARMOLT, Def®ndant IN CUSTODY ORDER OF COI, AND NOW this / 3 _, day of ~ja~_~, 1898, upon oonslderatlon of the within Stlpulatlon of the Parties for Custody, tho terms of Bald Stlpulatlon are hereby madta an Order of Court. ey the Gaurt, ~ ./.._. 33 . ~,~ J. TR+.IF COpY I'R^M RECORD In T~~;,t ne~nv ~rvh. i~nf, I I~ r u; a~ sot my hand and Iha seal of said C,r,rrt of Carlislo, Pe, This ...,1.~, dny(/~~of ~ 1 19...,,7 ~.../„ . F'rolhonotery r:\wp51\armolt\siipulminacus file rySSJN-~lx•or SUSAN E. ARMOLT, RICKY L. ARMOLT, npn~ e.r~nx IN THE COURT OF COMIIiION PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION • LAW . NO. 98.961 CIVIL TERM V8. De}©ndant ; IN CUSTODY T N°U T/OlV QF THE DART/E_S FQR CUSTODY -~, c, ,. > c.> r ~ ;a r~ > ,~_: i -,~-n -~~., ,.o ; c ~~ ~~~,i' .... ill •• ,-, ~~ `'`~. The parties heroto are SUSAN E. ARMOLT, of 1310 Holly Pike, Carlisle, Pennsyivarria 17013, hereinafter b1other; and RICKY L. ARMOLT, of 9 Kimberly Lane, Carlisle, Cumberland County, Pennsylvania 17013, hereinafter Father, The parties stipulate as follows: 1. They are the parents of Joshua Arrnolt, born July 24, 1979; Benjamin Armolt, born March 10, 1990; and Meredith Armolt, born April 1, 1992. 2. The parties shall share legal custody of said children. 3. Mother shall have primary physical custody of said children, and Father shall partial custody on the following schedule: a. Every other weekend from Friday after school until Sunday at 7:00 p.m b. Every Monday and Wednesday from after school (3:00 p.m. during school vacations) until 7:00 p.m. In the event that Mother requires child care while she works, she will give to Father or to his parents the right to care for the children at other times than those set out in this Order before using a paid babysitter. c. Unless otherwise agreed by the parties, three non-consecutive weeks per year with 30 days notice to Mother. Mother will also give notice to Father when she intends to take veeeks of vacation from her work. with the children, c:\wp51\nnnull\r~llpulnllun.cux Olt- MSS 1N!IH.UI ~~lur~h bl, I'uIH d, In even numbered years on Nnw `/enr's C1rry nnrl an Labor Day and In odd numbered years on Mmm~rla) Carty and thn I~r.,urUr al July, Mather shall have oustody of the chlidren In even numhprnd years on Memorial Day and th;e Fourth of July, eurrl In cxid nurnhrlrerl years on New Year's Day and Labor Day, e, On Thanksgiving and Eastr,r clruinti one of Iwn bloclks of time on those holidays; the first black being born O.CN] rr,nn, to 2;00 p.rrr., and the second block being from Z;tH1 p,rn. l0 7;f10 p,rn The partlas shall alternate these blocks of timr, In a given year, so that In even numbered years h'athc,r will hevrr the morning block on 'thanksgiving and the attornoan black on !:aster, and in odd numbered years, Mother will have the rnornlnCl block rut TCuuiksglving and the afternoon block an Easter. 1. Every Father's Day 4rnm 9:00 er.nt, to 7:00 p,m, Mother shall have every Mother's Day Irani 9;00 a.m. to 7;00 p, m. g. On alterr•rating periods of tln,e at Christmas, the first of said periods extending from Chrishnas Eve at 1;00 p. m, tc Christmas Day at 1;00 p. m. and the saconcl of such periods extending Pram Christmas Day at 1:00 p,rn. to Deoernber 26th at 1;00 p.m. -Chase periods of time shall alternate annually, commencing in 1918 with Mother having the period of time between Christmas Eva at 1;00 p,m. and Christmas Uay at 1:00 p. rn, h. The periods of partial custody specially set out for holidays and Mother's Day and Father's Day shall take precedence over the alternating weekend and mld•week partial custody schedule as set out in Paragraphs A and a above, i. At such other times as the partlas shall agree. 4. The partlas shall say nothing Jn the presence of the children, nor shall they do anything in the presence of the cl7ilcJrc+n which will ir~0uro the regard the childr©n have for each parent. The parties will not discuss econondc or clivarce Issues witf"dn the hearing of the children. The parties acknowledge Utat hrecu;h c,l th:; teen al their Stipulation shall be as egregious a violation of the Col.rrt's Urclcrr as lailure to prnvide custody as set out herein, c;\wp51\nYmull\slipululian,cus lilc y55Jh: 1R.I11 ~inrrh 2-0,I')9e 5, Thls Agreemer~t may bo onterod as an Order of Court, WITNESS: ~. 11~h Susan E. Armolt ~~ n .~ ~~ Ricky L. Armolt CERTIH,tCA'I'H. OF SI+:RVtCF. ANU now, this__~~___day of ~ r,:.- ! , 2000, I, Carol J. ~!_L~ZL~---- Lindsay, Esquire, of the law firm of FLOWE~2; FLOWER & INDSAY, P.C„ Attorneys, hereby certify that I served the within Pre-hearing Memorandum this day by depositing same in the United States Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to: Marcus A. McKnight, III, Esquire Irwin, McKnight & Huges 60 West Pomfret Skreet Carlislo, PA 17013 FLOWER, FLOWER & LINDSAY Attorneys for Plaintiff .1 ~~ ~~ By, ., //~ c~~ Carol .Lindsay, s I~#'44693 11 East High Street Carlisle, PA 17013 (717) 243-5513 RICKY L, ARMOLT, IN THE COURT OF COMMON PLEAS OF PLAINTIFF ;CUMBERLAND COUNTY, PENNSYLVANIA V. SUSAN E, ARMOLT, , DEFENDANT :98.0961 CIVIL ORDER OF COURT AND NOW, this ~-~ ,day of August, 1999, following a hearing, the custody order entered nn Aprii 13, 1998, is amended to add this following additional paragraph: Benjamin Armolt shall attend public school and Meredith Armolt shall attend private school, By the Court, • Edgar B. Bayley, J,' Marcus A. McKnight, III, Esquire For the father Ca~,ua~ nx.M.4~.~C 8/~'I~~9 Carol J. Lindsay, Esquire ~ ~'' For the mother aaa r Ai1G 2 4.19~9Y, ~~ RICKY i,. ARMOI;I', IN THE COURT OP COMMON PLF,AS OF Plaintiff ; CUMBERLAND COUNTY, PF,NNSYLVANIA v : CIVIL ACTION -LAW 5l1SAN E. ARMOI.f, NO. 98.961 CIVIL Defendant ; IN CUSTODY CdURT dRDER AND NOW, this ~~) day of August, 1999, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1, A hearing is scheduled in Courtroom No. 2 of the Cumberland County Courthouse on Friday, August 27, 1999, at 9;15 a.m, This shall be an abbreviated hearing scheduled solely for the purpose of deciding the one issue as to whether the minor children should attend Crestview School or St. Patrick's school, Counsel for the parties shall file with the court on or before Wednesday, August 25°i, a succinct memorandum setting forth the history of custody in this case, and their clients position in detail as to which school the child should attend, cc; BY THE COURT, , -~ ._ _ °s_ J, Edgar B, Bay'le~ Carol J, Lindsay, Esq. _ c.,,.~ae,,, N..o.C:.«l, g~~`~'~~ Marcus A. McKnight, Fsq, -~ 'p RICKY L, ARMOL'f, Plaintiff v SUSAN G, ARMOL1', Defendant Prior Judge: Edgar B, Bayley IN TIME COURT' OF COMMON PLEAS OF' CUMBERLAND COUNTY, PENNSYLVANIA CIVIL AC"170N -LAW NO, 98-961 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH TFiE CUMBERLAND COIJN"I'Y CIVIL RULE OF PROCEDURE 1915,3-8(b), the undersigned Custody Conciliator submits the following report: 1, Aver a second Conciliation Conference and after a conference with the Court, the Conciliator recommends the entry of an order in the form as attached. ocr z s ~ss~,;. RICKY L, ARMOLT, IN "I'FIE COUR"I' OF COMMON PI,EiA5 OF Plaintiff : CUMBI?RLAND COUNfY, PIiNNSYLVANIA ~ GVIL, AC"I'lON - L~,W SUSAN E, ARMOL'I', ; NO. 98.961 CIVIL Defendant IN CUSTODY COUR'C ORQIsR ~7~~zt`o~.G,',, AND NOW, this ~~ day of Octeber, 1999, upon consideration of the attached Custody Coneiliatinn Report, it is ordered and directed as follows: 1, A hearing is scheduled in Courtroom No, 2 of~jhe. Cumberland County Courthouse on the _~~ day of _: ~t,k.<<u ..~_ __ `, ~; at d Y`i _ fl .M. at which time testimony will be taken the abovb'casc. At this hearing, the issues of the Father's petition for conternpt and Father's request for modification of the existing custody order shall be addressed. 'fhe Father, Ricky L. Armolt, shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the court and opposing counsel a memorandum setting forth the. history of custody in this case, a detailed listing of the issues currently before this court, a list of witnesses who will testify on behalf of that party and a summary of the anticipated testimony of each witness. 'T'his memorandum shall be filed at least 10 days prior to the mentioned hearing date. 2. Pending fiirther order of this court, the existing Custody Order shall remain in effect. BY "fl-IE ec; Marcus A, McKnight, III, Esquire Carol J. Lindsay, Esquire Edgar B, Bailey" t/ ,CL~~e_a~ ,~ tutCF~e~ ~~~y-y~i Rtl~( .~ M RICKY l„ ARMOL1, Plaintiff v SUSAN E. ARMOL'I', Defendant Prior Judge; Edgar 13, l3aylcy IN TIiG COURT' OF COMMON PLEAS OP Cl1MClIiRLAND COIJN'I'Y, PENNSYLVANIA CIVIL AC"f101J -LAW PJO, 98-961 CIVIL IN CUSTODY C.'ONC[LIATION CONFF,RENCF. SUMMARY REPORT IN ACCORDANCE WI'fl1 TIiG Cl1MHGRLAND GOIJNTY CIVIL RULE OF PROCF,DURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report; 1, 'fhe pertinent informntion pertaining to the children who are the suhiect of this litigation is as follows: Degjamin Armolt, born March 10, 1990; and Meredith Arrnoh, born April 1, 1992, 2, A Conciliation Conference was held via telephone conference with counsel for both parties nn October 2G, 1999, 1'he attorneys were Marcus A. McKnight, III, Lisquire and Carol J. Lindsay, Esquire for the Mather. 3. The prior proceedings in this case involve the issue of selecting the school where the children should attend. However, there was also a pending petition for contempt and a pending petition for modification of the existing custody order. Those issues still need to be addressed by the court and the Conciliator is unable to work out an agreement between the parties, 4. The Conciliator recommends the entry of an order in the form as attached. DA E ? a 7 November 17, 1999 9 Kimberly Lane Crrlisle, PA 17013 Susan E. Kuntz 148 Chester Street Carlisle, PA 17013 Dear Susan, 1 am writing to you because of some concerns I have involving Benjamin and his participation in the Cub Scouting program. I want and am willing to have Benjamin participate in Cub scouts, and then especially in the Boy Scouts. l also am willing do take Benjamin to the scouting functions. My concerns t'or this endeavor are money and transportation. Financially [ am unable to atf'ord the full cost of enrolling Benjamin in the scouting program. The transportation issue is much the same, 1 cannot afford the cost of transporting Begjamin to and from your place to the fimctions. ~ You had stated that the Cub Scout meetings are every other Sunday when I have Benjamin and Meredith with me. You stated that the meetings are from 6:30 PM until 8:301'M. As far as the transportation part, when Begjamin does go to the Cub Scout meetings you could pick Meredith up at Saint Patrick School. After the meetings were over 1 would appreciate it very much if Benjamin could stay with me and spend Sunday night with me and I would sae that he gets to school the next day. It would give me an added chance to spend some one-on-one time with Benjamin. 1 really do not want to make any assumptions and want to get the details worked out before going ahead with registering Begjamin for the scouting progrnrn. I would like to hear your feedback and views otr this matter. Sincerely, ~~~~~~' Ricky L. Armolt November 9,1998 9 Khnberly Lane Carlisle, PA 17013 Susan E, Kuntz 1310 Ho1PA 17013 Carlisle, ~ 1998 Dear Susan, hone conversation on November 6 , in uP ou wanted to sign Benjam ith 1 ~, writing to Y°u m referenceY~u to d me 1998.'fhese lessons would be m to ~ lessons for Benjam~ •21 and 28'h s You also told me pertain' B bex 7`"', 14 , on the respective a aening.. d from the for art lessons for Dec 30 PM until 5:30 PM °Ration to an NanoY Starurn from 3: rovided the transp that you would paY for the lessons if 1 p sal. As 1 location. with the following PCOI'Owell as this some thought 1 hav end weth the children is limited as After giving ve to sP en amiu will be of benefthe art lessons e Also 1 know that ~ lessons f°r B ~ amin to and from have stated before, the time that 1 ortation for Benj precious tom • ree to provide transp Therefore 1 will ag conditions. 1 hate the children location under the following evening, r 26 1998 °i 1998, which is a Wedge onNovcmbe ~~~ 1 have the On November 25 ickup evening, 19yg, overnight with me until Y°ur scheduled P which is a Sur'day m On December 27 , 1998, ickup time ou pecembeC s 8hst Thank4giving Day• scheduled p on the four Mouday ht with me until you'' ' at 8:00 PM aragraph. children ovou gree to pick the children uP , Also that Y lessons. The dates stated m the first p Benjamin has ~ gincerely, ~~ ~~ R.ick~ pam°lt cc: Marcus A. McKnight Ill Esquire - __-~"~.1.__~'ti~ - ____ -..-__- -_.-_ t~ ~___-_.....__..'~ ~.Q~- ~.l~-p ~ ......U.K.LL~+I.~Z.ryv~.t~ crlL~lr-` _ .Vh - - ( ~ t -__ - _. _ _ -_. _ _ _ ti `\\Y ~~ ~ - \ , ~ -1y ~- __ ' ___ .__-- _ ~ n ,_-__. -_.._-- __..SV4sL __ ~ix~.~(z4A/~/14.~-dam „ ~- ~ •-__- - ~~S~W~_ --.- ___-. - -- _. -_-.--- _ --- --- _ ._ - __ --~_,_ ea.~,.Ka~ ~ ~:-~.~ - - -_ ,~._._._-- -- .__ ---~, ~,...~ _~_ a~L4 --G8.43 -- ,,z ~+ -- -~ 4 1 N` 5f5 M1~ ,. ^- - i. g i` "~~~ , ~'~ ~} ~ I ~~ I ,,` 'y~ ~, ss ~~ i+ ;.~ ~a' :'}.r ';i;ii'' „~i;, 6A v yv, r4 ~~ ; v, 3~ ~"S s ~, ~; ~; r ;. 11~i ~ ~+ ~ f ' ~~ If i4 'r .h ~4 .~ ~; ~ ,h'~n ti lor PEtlt 6XHIB ?> I ~' 1••Z .pr, ~~, Student Name Meredi th Arinolt FIRST GRADF v ~ e ` }v C Y ~ K V ~ ~ V B n' U e 4 a o n fi ~ a ~i `o ~ 'o n ~i ~ g a c o o ~ '~' o o s ~ .. ` n Rf4IBlON 2 a 3 e Knows tanlom Pnrtldpptos In doss Shows ollorl GRADE lAN0UA0f ARCS Appllos ward atloch sMlll Assodntos sounds wllh loitor Roods wll6 mrdorslmrdinl Reads wllh oxpresslon and Iluontl Rotognlsos bpsic votabulnry Exprossas (dens tloarly In wrlling Appllos phonolic gnowledge In lonrporary spoiling Cppllallsos rorretlly Uses torracl punttuatlon Wrllos tomplolo sonlontes Masters asslgnod spelling words Uses good handwrlling Forms tellers wrretlly Farfitipptes atllvely Shows ellorl GRADE .:,,~~; } E d~ ~~, i ; Er ii `;;i '3; .,~ ,~ !< CH i ;; I y r£.1 ,,, <: I I '(I i ~" MAIN Uses souutluU shills Knows bash nunrbar lasts Showt auurusy In addlllon Shows atsuracy In subtrnctlon Solvos word problmnt Undoatmrds/appllos concepts Shows ellorl GRADE ARACIfR DEVfL0Pd41N7 Assepls rosponsiblllly for asltont Prustlsos sell sonlrol Dbserves rules of the school Resposls property Shows rasped for aduhs Shows raspett lac othor students Works rooparallvely In groups L z ~ ° 2 ~ a ~ a p 4 U ~ s o o° ~ a s ~ o 8 ° u g ~ ~ s a e a s ~ ~ o ATTENDANfE 1 p g q Days Absent 2, Times loto 3 2 MARNINO (ODE (oi lost repntl S - Sulislodoiy N = tloeds Unpiovomonl U • Ihisolisln(Imy 'BnpIV box nwons Uoas uol apply. „y,. 5~; ie ?~ .,. 4t rµ5 ~ /~1 _ r ~,~ ~y~ F r r i COMyM~-E~~N~TS~ ,~ t. Jr :t~'ti.~r^'`C~~L '1.11' (-Cl' ~LQ/I2t (,Cf~"lZC1.CCI1/)L~Clrt(., ~,~"_u.~r>z.t- , Q~~ 1~.~CtQ.t~rrLE /Nuvn/~~.z.~v ,l.L u~.. ..~~d. - 2Y~'~~ ~-~:i,lx..t,cz'.C i/-nap~..e...~tc~~v /j"-" i,Cli.,P~ ~ dQ~Z.('k Jzc~a ~gqhh,,~~~L(,~~L~ r~.~r>,dou,~c.~.,~G'~l~`ti't ,tl t a. CLa~t yl c/r'-1~-~,Wu~ , (anlemno~ " ~~~~sloJ (unlmoutr, km~uoslnd ~ %1' ~ ~ fff Y COMMENTS a. `-~~tR.GJIt~{2, ,~!`"kcuj~ ~u~'w-~rv JI~C-a~2R!>vt' `~°'''~'`~°a' ~tlua ,~,,,..,~c>sc,~csc~, Y~erc. ~/oH4~c,t~.,~e ~..a.,t-~ ~k..~~lq ua~7~ ...-~~,a.iu.~. ati~~ti.~.. ~..c:4, ~-P~v-~.~ola.,,.t ~..~n L ,~-t,Q~-~, ~-lrr-,-ti~,ih~f3.1N~-,~.ei,.,,fd ~~ e ,p ~-~-~-/~ ~.,thR ~~' a'trt91-?Z. 7YU?n.R--e~vfh- ~ Pmont Si9nulm~ '` '~ ` ' (onleim¢o Nuquaslod _ _ _ (onfcien~n Roque;led _ _ l~ COMMEt!ITS p a. ~.t . Puio~ ~Q~-~,0!YV l~C~ .~~1-~ku/~.-w~-2 ~-:1.0 ~-"LC~-ue. `~YYl~ ~tl~ L.UY1. ,_.6~.vv ~,c~.,cZ,cacv `:t..rwa~ ~A-c w , .J ,,~,,a.~v~e_ ~nz.1.~->~,e.~,~l.. '~''a;t-,C1h,v~r,~c~ p~'u.A~~ ~7w' ~.,Uv~-t~`~.c~,V~,c;ti~J ~~1',11a ..~..~,ct,ti. . ,i`i'Q~y'- ~- lJ ~_d_rBY~ol.~ti~-L.~C. ~.~o.~.,.~nv~,-•.o/v Assigned to Gradn ? ~ O Teacher Signature ~~1.~~~ ~-yy ~ 'pv~ n ' o ~~,,, p, ~ J ,, ~,. ,t, !~ 'y5 ~~'i5i ~ ; t i~ ,~, l~~ 4 V ~~ ~ y ~' 1~~~;1~~ CUSTODY PROPOSAL OF RICKY L. ARMOLT January 27, 2000 L On alternate weekends: Thursday at 2:00 P.M. to Tuesday at 2:00 P,M, 2, On alternate weeks: fvtonday afternoon at 2:001'.M. to Tuesday afternoon at 2;00 P.M. 3, Expand Holidays to include overnights. 4, Four weeks vacation each year with thirty (30) days notice to Mather, Mon. Tiics. We 1. 'Chars, i~ri. Sat. Sun. D M M D D D D Mon. Tues. We 1. Th rs Fri. Sat, Sun. D M M M M M M DIOCESE ~OF HARRISBURG Grades Z and 3 Sludeni Name _ Ro.4,µ,;,, „ n,,m,,, Grade za SCf1001 Year 1998-1999 Teacher _ Mrs. Guyer. Principal S. Karen Washabaugh A~ r ,, ..... Student Name t,~„-lamin Artnolt SECOND and THIRD GRADES ~ ~ E S ~ B O _ O y v 4 n ~ C y E ~ ~ l Oj y a O O ~ n ' 8 O O n o .`. O $ p O B Y u O ~, 4 0 y y 2 o n 9 u 3 y -Y 'a 0 p o .. n @ n c 6 .. $ z 0 a a ~ ~ ~ 8 o A ~ i 6 a Q ~ u ~ u Rf[l0/ON ! ~ a o ~ e n 1 3 Knowssontont Partlslpalas In class Shows ellort GRADE [ANOUAOF AR/S Acquires and uses new votnhular Appllos reading strategios Initiates Independent ruading Reads with undarstanding Rends wllh expreulon and Iluonry ' Responds to hteralure Mastors assigned spelling words Appllos spalling skills !n wrlllen work Expressos Idoas Clearly Initidlos writing independently Uses graronmr sorrostly Uses good handwriting Completes assignments Shows ellort Modllled progrom GRADE / / ~/ / ,/ ~ -_T~.-~~ ~ a ~ ~ ~/ / ~ / J / f /~ / ~ M ~ / J / y I / / J Y `/ / / l ~' J / ,/ ~ / _ / / ~ ,~ / s/ ,s/ ,/ y l"..J ~ C, C.~ :~ _, ,4+' i ~ilr r~J .:. ~~~~ !/! ~r~.'~~ ' ih?I i j i i ~ ~ '~ ~ E U s E t; ~ a s ~ s a s ~ s a e s a ~ 8 E ~ ~ a ~ e ~ ~ o ~ e 9 '~ ~ g~ e° a o ° o L z ~ ~ _ ~ y O ~ ~ E e MAIN I 2 ,r ~ Rnaws basic number loch Underslmrds and oppllos conroph Uses ptoblem solvlny slraloglos (muplelos asslynmonls Shows ollorl Modllled Program GRADE CNARACTFB DFVf/OPMfIVT AuepU respon4bllity for aglons Pradlces soli mnlrol Obsoivos rulos of Iho school Respatls proporly Shows respect for adults Shows respect for other sludeNs Works cooparallvely In groups Markin (ode A • Exce ont B Above Average C •, Average D -Below Average U Unsatisfactory Empty box means does not apply ATTENDANCE 1 Z 3 q Days Absent ~ t L5 1, 5 Times late Q 3 I ,< ~ ~ k s r COMMENTS I. ~ .u.m~a~.yv c.u,:Sw_~u~r.,,~q, •~ c~.aaa .lxr4w...~ .a,,ri.w.a,~k. ~, ~k~~..,.~19.a.((JJ~e-d. ~t ~ ~Uuen.~1 o.n'S.~.e~w a~.cl~ ~:.a.lza.o> p~-~. .~;.,, .-~, .ure..~e.. 0 14ucnt tiignrunrc _ _.. Couferunrn kuqucsial _ ('nnrcrcnce keyucsieJ _ .... r COM M ENTS ~~ Qa ~ ~' Cy-Ww ~ ~vt~,~,~- ..p~.a.,~,a ,L," o .irv~a~.~~w...o_fl.c.o„ ~t ~a-a.o) w'~ mod, ~ .nt.a,d.~ ,.~ lu,k aa• .wee~12 ~.tn., -lh.a~r o~na) Am.d vR4a,d,.a t~anh,nua.-Q t anC - m~. - cra. „au~~o~ . ~n a-•~:v ~ I'arcm Signanuc ___ ~• _CJ ~ {~ __~ ~,~ ~ ~~IIIPICIICC RCgIICSICII __. ~.~Ollll'fM1UC lZalUl'SIQII _~j(y,,,y ~~ ~/~ '30MMENTS ~. (~~ __ C6`tu0/ ~ ~rU1"~ ~.~-l" QAA~I Jw-a Jn1 A~'" . . ~Il4b ,D~1.~lA1~J .A-e. ~v~ .A7uA ~Lll.l~ 1" ~J " ~ 1 pu.,1/ ~ ~Q 0. (~ Confcrcm'e keyues ~ 0 u 0 Pnrcm Sigwuurc--~ icrL-- Conference Requaslcd ~ ~ ~ _ _ ? ~ _--_. ~--- COMMENTS ~, ~~p~~~ r.. ~~ u. t'"`~~"~~' ~ ,)crud-e. J.,,,J .o4.c.ati.d..~ UU • Asalgned to grade ._:3 ._ Teaoher Signature __(Y~,~~____~x U --~ ,,. Mt„ CARLIST.E AREA SCii00L DISTRICT G23 west Prmn Saes Carlisle, PA 17017 GRADE THR FF, pROGRfiSS REPORT STUDENT : ~7!~41J //ii, , TEACHER:~~h~~ SCHOOL YEAR. 19~ ~r7(XJ Evrdo ou ~ for SubJect Areu E ° Exu u:ni mdicalw aehicvemetn beyond the curriculum , Swdent oxltibits exceptional undci standing of the cunlerU, wmpletes class ossiFuntcuts, mtd works independently. 5 - Satisfactory memis tlw swdcnl is performing el a level nxlwted by the curriculum for hisRtor grade. }~ . }ligh Grade L -Low Grade N ^Nr~ d~ Impmvcmcm means We child is having ddlioulty anrLor exhibiting limited progress. Childs n may eam en N by not completing assigns mots or failing to particihatc in clear. 5YW Progrea. lodlcaton + Exmllent progress in this rJcill arra ~ S Wsfactory progreav in dru skill arc - Ileeds more work in Uds drill am No mark maul, the sk II Arta wu not raview W during dais npwt period. Atteudaace } 2 3 i Davs Absom Days Late Aomoled to gods: ~-_ _-- Rapdnal in grade, Narrative 7~J._enu 2 :LLi) ~'-C~1.2.7Jt:l~lt77'Cl '-~ ,~~ ~' En;U-2t~.JtG-Q.CG..LL t. ~1.Ct972~r `.~~i '~ . ~ ., ^^ , /7' ~ 7~~~ ~CLG 0 LCL7L'y Q.2( • ~~~ LtL~ '/zcJ_`~c/b~~i~z~~~'.;aua~~~ ~' ,,_ ,_ ~. 1 : acs Y Ituvunionsl l..avel _ Conunmw _ ,.3 Phobia ~ /' \'agholLn • / Comprelwrwion y kCAU1NC lNSTRUOI'lONAI, I,f:Vf;l, ACi • Navr Clndc lavrl (KI • (hi Cinde Level BO.1)QIOW (rridr IlVCI 1 I J d Win S Corrmrmn -- / Alechsriia'{irLmnar / APPliwiai ~/ W'riurn f.mresLiai ~- ,,,~,~,~,...........~._ 1 1 J ~ Cammera~ Word Lin Commew 1)arlC PLCI.I ComputWm ~~ PILU VLlur Time Monn Mauurernem '^-~_ Robleai Solting ----~_ Fnctiorr, _V ~~" ~~ 1 I 7 , I J 1 II la Ouidal (IrcLCli:x) Almliulior_~•Y y/ ~ ._ I I J ~LTB ~ ± !i i S °°~~ _ a 1 I J ~~yy~~~~~~ /y Comrrromc 3 Jr 7 Cummenl~ I. Shows 6nptovrnxnt 7. ]. Receivra cPeciel Iwlp R. Puticilutes in clLn Waking below grLde level 3. Uxa Ldynive natcriLL 9. A. Nervk to IRLCti« a Mi Caryrleta Lnd ratuu me S' UcmartarLtn eUort lo. L home wal; on tivK home Eleluviv Wribiu I . ('LPLRIe ofbeuer work 11. IkKS nrn canpleu ~ un Ironinvork on time Socyl Ikvelopmcnt 6 W'or4 I 2 J ()Ileyl CILWngn rules Amunn rralanvibility ~., INggayc laeidvc anRu4 ~. WerkL COgierLlivcly / IkrrromtnteL reu-•cotu rnl - RheWf rtlllMy y T C~nplt94 wiafuYOry wod; on time ~~~ / Pollow~ dmtliom . / Y 14arhues neu work ` , V Urgsnlu.+1 .' WotW well irdeperderLLly / Sur on tuk Pn)s Lnern1011 r / Grades~Z,~ and f3 Student Name _ Meredith Armolt Grade zs School Year 1999-2000 Teacher Mrs. Theresa Kerstetter Principal 5. Karen Washabauah EXHIBIT _S _ ~ ~ 21 ~ [~ LILT Student Name Meredith Armolt• .. ~, ~ SECOND and THIRD GRADES 3 p Y 3 S ~ 3 ~ y O 9 Y y Y Y Y ~ Y Y 6 ~ {a '~ e g ~ ~ B ~ ! E 9 X 9 9 RELIGION i 2 3 4 Rnowssontent parllclpatos in slnss Shows ollorl GRADE LANGUAGE ARlS Asqui~- and uses new vosnhulory ;,ppHes reading strategies Initiates Independent reading Roads with understanding 's wllh expression and Iluansy Responds to hlerature Masters assigned spelling words Applies spelling skills In written work Expresses Ideas clearly -ales wriling Independently Uses grammar <orrestly Uso good handwrlling Completes asilgnmems Shows ellort Modl!!ed program GRADE J J - J J / ~/ Y }, ;, ?y: `V! ,, ~¢ r:; ~rl, ;iti H ,;,,, Marty Knows basic number la<ts Underflgnds and appliaf concepts Uses problem solving stratoglos Completes osstgnmems Shows ellort Modlped Program GRADE CNARACIER OfVfEOPMENI Accepts rofpom16111ty for gdlom Fractlcos sell conhol Dbsorves rules of the school Refpgcls property Shows respect for odults Shows respect for other students Works coopgraNvely in groups Mor~kln ,Code A • Excallenl g =Above Average f =Average D =Below Average U = Unsatislastory "Empty box means does not apply i% ~i;;i .. s ~ ~ g E u a ~ a ~ t ~ a = s E E d .U ~ s ~ R s ~ i g S 1: ~ Z a a o 3 ~ 5 Z a ~ ~ ~ e d ~ Z Z s s o d 'a ,~ '7! a e 0 /^ ~ A AiIENDANCE 1 Z 3 4 Dgyf Abfanl 2 2 ilmas Egle S Q >: ,.. < . ,6,, 5+•: ~ u6 b< ....... ~;7i' COMMENTS W p w~ m!u"e~{i ~j., ~ T i J % S a- w,ot~~~dy~.-{-~//, i hirer T Cou-A~. T.. .`i-~ 1/GvY ~f / / ~ te/ %'T', y~Ll ~~ ya~- 4,vr~t. ~raal ~lt!Sfi ~~Ered~~'1er b,tha~ n wo-~tlor-1~,1~ab, gr f-{.eV ~L'a,~-.~,.i mss "K' ~~~~~ Parem Signature __ __ Conferenc< Requested _..__ Cunfereuee keyucsted _~_ COMMENTS +~ ~' `~'rea~-fir ~epi/f' -'~ISu per ~ ~,l1sr{~~ m~reo~i ~ ~ rod ~/esvS ~~ Sis~tc• 1` a.r.a.'~ ~~~ r^PG~r+~, ~~rr.1 re~rr~ C.arr1, I:tep Np ~'hP hlt~do~a..1 w~ar~k, /nrx;k Pareul 5ignnture ~_. _____ - ', Conference requested __ Conference Requested. COMMENDS t Conference Requcsmd -,.-_~ COMMENTS a. Assigned to Orade - Teacher Signature , Parem Signature Conference Requested ~~ II I _`%`=:~ T'hc fallotving people sure s Ienced recently in t'umherlu County Cnur1. All sentences inch cost and are concurrent unless nth wise spccilied. Sentenced to Cumberlmul County Prison Boiling Springs Michncl C. Kepner, q00 block Wulnul Slrcet, 30 days Io 12 mtnu and n $300 One for pill. Cmnp 11111 David Clutrlc:; Farner, 2100 hlo of Markel Slrecl, 30 [lays In ht yc;lrs loss one cloy and n $:110 fi far D(11. John Stephen Youngblood, 20 block nl' Ensl Creshvaod Drive, rev days to 2.l months and a $3G0 tin for DIJI. Curlislc William H. I)e;utic, 100 block o Clemson Drive, two cloys to 2 mondts and a $360 fine for DUI. lalwunl Ir. Clouser, 100 block o North Pitt Street, six months to tw ycnrs less one day nn[I $qqq ht resli lotion for Ihefl by deception; n con sccutivc 5 yc;trs imm~nalintc pun ishmem +md restihnion for Ihcfl b Acception, $2fi5.62 in restilulion for bad checks, $gR.32 in reslinninn far theft by [Ieceptiun and $7q.1 l in restiunion fur Ihcfl by dcecption. Chrislnphcr A. Dilv15, 10(1 block of West North Street, nine l0 23 months for receiving stolen property and nine m 23 uumlhs for receiving stolen properly. Richard Jnhn Fspc}'. lust block of Moored;llc Read. 30 days to 20 mnnlhs and n $3(10 fine for DIJI and n cunsecwicc 911 days amt n $1,000 fine for driving while apenuing privilege is suspended or revoked, D(II-mintcd. Barry I_ec Oladfchcr, lirsl block of Kerry Avenue, one year less one day to hvo yews less tare day fur mh- hcry. Joseph P, liagcnhuch, Ig00 hinck of Pine Road, QR hours In 23 ntnnths and a $311(1 fine for DUI and a $500 I'inc for flucing or ntmmptinl; ro elude police, Knndca Sue Hlghhmds, 7(10 block of F.asy Road, 30 days to 23 months [tad a $300 tint: far DIJI. Shari M. Hofllnnn, 30(1 block of SauOt Ilunovcr Strccl; 4N hours to 23 months and n $3(1(1 fate far D(11 had n $2S tine far unlawful posses- sion of drag pnrnphcnudia. en- Schedule I, controllal suhsumce ;md red costs for unlawful possession n( a tdc snudl nmmml of marijunml. cr- Stephen Craig Myers, 1000 black of N;Inroc• Drive, 30 days to 2) mnnlhs and n $q ICI I'inc tar Ulll. Doty 1'Iclchur, 2(1(1 block nl' I lunpl 12nud, six to IR mnnlhs and $2,07S.fi1 in restiuuiun fur theft by of deception, a cnnsccutivc 30 ntgnths hs inlcnncdiulc punishment and $q,5)S.IR in restitution fur credit cards and n consecutive 12 months ck intcnnediute punishment mtd restiul• 'o lion fur theft by deception, nc New Camberhnul 1';uricia Joan Shllick, S(10 htoc•k of (1 nritlgc slrccl, IS days l0 23 mnnlhs o and a $3611 fine far DUI. e NewvlUe Kevin Fingene Allison, lust block of Bridgewater Ruud, 90 days to '23 F months and n $30(1 tine for I)UI. 3 Douglas Allen Smith, 1(10 block of Bcetem I lollow Road, 30 days l0 20 f mnnlhs and n $3(111 tiuc for DUI and o n consecutive 90 days and n $I,fi00 fine far driving while oper;iting privilege is suspended nr revoked, DUI-related. Y Shippensbur•g h1ichncl haul I looter, 100 block of Marco Circle, three lu 23 mnnlhs nntl 875 in restitullon for theft by unhnvful I;Iking nr dispnsiliun. Ilarry D.'fhonms Jr., 300 block of West Orutge slrccl, 46 hours in 23 I months and n $3U0 (iuc far DUI, i Duuphlrl Courtly I Shawn 12. liecrs, 1011 block o' I Penn slrccl, Ivliddicunvn, 4K ms to 23 months and n $31)0 ' nc for pUl and n $50 fine far [ .vu'dcrly conduct. $ Alan 12. ftlnek, 1201 black of n Ilunlcr slrccl, Ilurrisburg. Iwo days .$ In 23 munlhs and a $3611 'lw for d DUI. Joseph Mninm, 31(10 hh,ck of b Iloffur Slrcet, Ii;lnisburg, nine l0 23 months mul $10f1 In restihlhrnt for m unlawful delivery or mnnufncutre nr possession with intent In deliver n of Schodulc II, controlled subshmee. nt prnrdd Lec Mcck, L50O hinck of dr North Second Slrcet, liurrishurg, six sir to 23 nunnhs Fur rchlil Ihefl, ul Michncl L.cc Sims, 2110 block of Calder Slrecl, Harrixhurg, nine u, 2q M momhs far simple assault nml Itt u, $2 3fi months fur simple azsnuh• du Michael Eugene 'I'rimhlc, 20U nu block of McCnrkcl Rawl, Ilcrshry, 311 deys in 23 nu,nlhs and n $q 111 Fie n., r.. l,,,l anc h. i ! momhs far false reports law ,;,i, rcemem authorities xnd crntso uuvc 90 Buys and ;t $1,11(', tine Inr driving while nperatin privilege i suspended ur revoker DUI-related Sculcnced do slate prison hrederick I~fdw;u'd Clril'1'iths, address given. env In hvd ycnrs Ihcft by unlm~ !ill taking or displ Zion, hvo In G~rlr veers ;Ind resli lion for hurglu, v, uvn n, 1'mo yc and restitution fl~l hurghu'y, th ycnrs and Ihre, worths to sev yc;lrs hrc hurghu y ;out hvo ycnrs four ycnrs fur ; , intinal nttentpt burglary. Sentenced In hdcrmcdiutc pu nishmenl Cnnlp IUII , John Qahrlcl piLconardo, gIOC block of rJcuyshurg' Rand, 23 mnnlhs and a $500 fine far 11cr.ing or nltengtHng to elude police, n $7S fine for harnssntenl ~ ,$210 line for [hiving while opem•I,np privilege is suspended or rcvok..i n <,i5 lino far u'nl'lic control signer n ; ,i fine for driving nu the right ~~ ~,~ „f nwdwn}~, a $65 1'inc fur dri' utg ml roadways Inncs I'or hnffir, ;, $65 fine far dri-' ving vehicle ;u •ufe speed, n ~65~ fine fur cnrclr,+ [hiving, n $2q(1 fine fur reckless driving, n $25 fine for nuunhuriaed trot I'.'r nr use of reg-~ strwion and n s; , r.,,. c,~ r......... «•nu', of Curlislc Joshua Alirn Arnud6 100 block of Chester Street, 12 months ;md a 21111 line far unlawful possession of small ;annum ul' nuuijumul and n SII lino fur unluwl'ul possession ul' rug pnruphenudiu. lock ul' (inunlvicw Court ~•>q wndts and $5,960 in restiuuian for tstvrnn fnixificalinn to nuthuritics, T;avnya Lynn Jumper, first block • Regency Woods South, five ycnrs td $250 in restitution far unlawful 'livery or nutnufncturc nr posscs- m with totem to deliver n Sched- c II, controlled suhstnn[~e. Brian Kcilh Long, 100 hinck nl' n9h Earl Street, 12 months nn[I 110 in reslilutinn 1'or (heft by cr.ption and n consecutive 2q oohs and .$3,051.50 in resOhnton, Kevin li. Shugharh first block of Ilniru Avcnnr„ fi0 mnnlhs I'or lcr. Jim rzncl L'll~e 1"ttzj~cat~~lck 53 tYlary Ly1u2 I,crrae lira~tchUccrb~, N~ nBH~r Crucembcr "1., 1999 .loshua Armolt 9 Kimberly Lnnc Carlisle, PA 17017 Dear Joshua: Within the next few clays, yon will he receiving a call from a representative of ours. At our request, the caller will discuss with you the outstanding service provided by the Caron houndation and Caron's plans for the futures geforc the call, the Found;ttion has asked us to share with you our thoughts as grateful parents: When Andy entered the adolescent program at C;u•on four years ago, he thought we'd made a mistake by pushing him into treatment. 1Ic claimed he didn't have a problem ;ut<I would he home in a few days---hc soon found out otherwise, Through family, group and individualized therapy sessions, Andy began to realize the extent of his chemical dependency. 'together, our family IcR Caron with the tools needrd to heal the scars and mend our relationship. The counselors and medical team helped us build support systems, while providing follow-up care that is essential to recovery. Caron stands as a beacon of hope to individuals and fmnilies whose lives have become unmanageable hecause ofchemical dependency, a disease that affects one in every three American families. More and more families are reaching out to Caron each day for assistance in dealing with addiction, however, a good number lack the financial resources to pay for treatment. Caron's priority has always been to direct philanthropic support to aid those in need. This is why we write to you today. Our experience with the Carat Foundation changed our lives, While giving is a very personal matter, we ask you to consider the hope and inspiration at Caron and the many lives that will he impacted in the coming years. With this in mind, We hope you will consider a pledge of $200, to the Caron Foundation, which may be fulfilled in four quarterly installments of $50 over the next year. Your continued support of the Caron roundation plays n pivotal role in providing an enlightened and caring treatment cannnmily in which all those affected by the disease ofaddiction may hegin a new life. Thank you in advance for your consideration and support. Sint;crcly, cC~,,,, ,tim and I:Ilic FitzpnU•ick a PETITIONER'S EXHIBIT 7 -~ ~ .~ Page 1 1 Nnall.hAamaanue ?.5'15 Intornl-ato b[ive Ile r[lahurry, PA 1'1110 ' t•B0o-'108~~9445 Clieok M~ 276tJ5 PAYMFNT9 MAUF; ON ^EWALF' oF'i P: L'K INNON COLLEGE T H 1 9 t:9 N 0 T A P 1 4 h EX p4ANA'I'IO11 OF' DENPI•'ITFI inau radl ARMOhT, RICKY L ' ~ Pat Lentl ARMOLT, JO911UA A FiICICY L'ARMOLT Group Nnmai D,C.-FACULTY/ACADEMIC PRO 9 I(],MB L,+RLY LANE - t.0. Nol 20U-76-844901 CARLISLE, PA 1701.3 claim No.. 15-nooz4 ' natal on /05/1999 ' PAYEE, UAUOEN7tA WE9T 9110ftE/OUT PT Provldar Date of 9a Nloa TaCal, lnalSglbla Covered Coda/9nrv ices From To Chnpge Amount Coda Amount OAUDENE /A WEST 9110 01/07/1999 O1/07/Y999 50 00 30.00 90847/OTHER OUTPATIEN '. .. _, - TOTA49i 50,00 ~ 'n,00- 50.00 - Lesa De~dUOtibl@ 0.00 . ' .~ Lees Copay/COlneurance 0,00 Renef ii. 50.00 'Total tlnnef SC Peld 50.OU ' - - - Member Reeponai blllty 0,00 DE9CR1 PTI ON OF REFARK9/PENEFIT9 - COMPLAINT AND GRIEVANCE F'ROCEOURE A aov@red lndivldunl tlaa [hq, righb Co appeal adanied al elm through the Crleven0a RavlnW Proce@a. I! you wish to appeal a denial daCialonr ammact the Menrbar 9eNlces Dapa[tmant at 1.000-708-8445. EOP.IDX.98 - r PETITIONER'S R HIBIT •7 oa I _ -- ' NoA lthAanu rnnoo ~ 8575 Into t'etata Url VO Page 1 _t _ - Ila rrlnbu r9, PA 17110 1-800-7116-B44E PAYMEII'IS MAUI: DN DKNALF OF: nICKINEON COLI,F.CIE ' ' T N t B 1 9 N O T A D t Cheok qi 276275 ' PAYMEq ......... 4 L i E%PGANATI ON OP PDFIEFITS -...-• -••-....-.-~-.-...•.-.•.....--. I RICKY L ARM~LT inau redr ARM04T, RICKY L P ti 9 KIMBERLY LANE' a onti pRMOLT,JO9NUp A tl CARLISLE PA 1'] roup NamAr D,C.-FACULTY/ACADEMIC PRO , O ].3 I.D. No: 200-J6.6449~01 i - Claim No., 1676992] - j Dater 04/05/1999 ._.. ---- ---------------- ... PAYF.Er OAUDENZIA WEST SHORE/OIfFPT Pt'ov lder i ......... ........ ...... DACO of S et V1C8 .... ............ ...-...- '•'------------ - i Coda/Sal'V lees From Total -- --- ""-• tno 1191 b1e '. OAUDENZIA WEET SNp 01/26/1999 To - ChArcde CoVared Amount ~ 9D6Db/OTf1ER bin'PATIEN 01/2B /1999 E0,00 Codo Amounk - i ~ i i i . . , 50.00 . ~ .. TOTAL9t. 1 .80.06 ' .,, - . 0.00 50.00 ' Leae Dedu0tl blo O.Oq ~ Laos Copay/COlneurane9 f.. 00 Denetlt _ ED,00 ' Total peneflk Pald 50.00 ' ' Member Reaponel blllty 0,00 ' DESCRIPTION OF REMARKS/EF.NF.F[T9 A oovorad individual hen the rlghk C COMPLAINT AND D !tI EVpNCE PROCEDURE. o p If you wish to PP appeal a denial Qoolaion anl a denied atalm ao ta through the tlriovanc n Revlaw Proocsa , n ck the Member Barvl cea Department . At 1.600-780.6445 ' FOR,IDY.. 98 , 1 rays l IlmiithAanurpnca 25'15 tntnrotnta Drlva ' ' Ileu•rinbu ry, PA 1'1110 1-800 •'I BP-11445 PAYh16N'I'9 ANDY; ON DRIIALP OF': DICK RI80N COL1,6U8 Chagk Mi 7'19177 '1'II / 9 [ 8 NO T ~A N 1 L 1, ' EXPLANATION ON RF;NKFtT9 Ineuradl ARMOLT, RtCKY I. Pnt lanCi ARMOt,T, J05}IUA A RICKY L ARMOLT croup hlnmpi D.c.•encNhTV/ACADeMm rfto 9 KIMBERLY LANE- t.D. No: 200•)0-B999~01 CARLISLE, PA 17013 cla tm Wo.: 17D99et4 Data OA/l9/1499 PAVEEI DA UDDNZIA WE9T BNBRF.'/oUTPT Provider Dnte of 8arvlco 'fotnl Inpll iblo Covarad codo/9arv loon From To Charge Amount Coda Amount OAl/DEMGIA WE:BT 8110 02/04/199') 02/04/1999 50,00 50.00 9DBn6 /0'PIIE;R Oll'I'PA'('IEN OAUDEN2IA 41E9T 9110 07/11/1999 02/11/1994 50.06 50,00 90BP4/OTIIEft OUTPAt'I EN ~. TOTAG91 - 100,00 - 0,00 100.00 ' - ' Gesa Dad~wtibla B. BB ' -- ~. - ' - ~ 4eaa Coppy/COlneurange ~ 0.00 ' ~ Danef It 100,00 - To[al Panaf It Pa1d 100,00 ' Mambar Reaponn16111 [y 0.00 ' ~ ~.. DE9CRt PTIDN OF RGMARK9/RENEFtT9 COMPLAINT AND OR7 GVANCE PROCEPURE A eoverod lndivl duAl ham the right to appagl a danled ola Un through [ha Ur lavange ReVlew Progean. 7f you wleh tq pppanl a dnnlp! dealnlon, gontnat tha hlambar 9ervlcea Dgpnrtmant pt. 1000.700-Bg4g, E00. IDX. 90 t Pxge I IlcnltliASSUr'n nua 25'15 Into relate DYlve ~ Ilarrlaburq, pA 17110 . 1-000.'/00-0940 PAYMEFI'1'9 FIAPC•• UN UEIIALF' OFi nICKIN90N CClLLEOE Cheok Mi 2'14127 Tllf FI I FI FIO T A q t L4 - F;K PLANATION tlP Rt;NNFiT9. ' ' tneuradi ARMOLT, RICKY-L Patlonti ARMOLT,d0911UA A RICKY LI ARMQLi'T ClrOUp Namei D.C.-FACULq'Y/ACAnEMiC PRO 9 KIMBERLY LANE. t.n. Noi 300-36-0A49.01 CARLISLE, PA 1'7013 C'Ialm Flo, i 17099070 D<lto~ 04/19/'1999 FAYEEi UA WENZFA NEST 9110RF./Ot7PPT Provider Oato of. 9orvino 'To[al Ineligible Covered Code/9arvlass From 'fo Ghe rge Amount Cade Amount M1IPENZ.IA WE9'I' NIIO U2/lfi/1999 03/16/1999 50,00 50.00 9080fr/OTIIRR OUT PAT [F:N OAWENZIA NEST 5110 02/25/t999 03/35/1999 50,00 50.00 90006/OTIIRR OUTPA'rIEN - - ' TOTAL91 300,00 9.On 100.00 ' - liege DedUCtSble 0.00 - - 4ass Copay/COlnxuranae 0.00 ' 0anef.lt IOO,OU Tocal 0enef It Pa ld 100.00 Member Reapona1611/cy 0.00 nE9CRIPTiON OF REMARKS/DENEFiT9 COMPLAINT ANP Ufl IEVANCE PROCEOURF, A cove rod individual 'haa khe right to appeal a domed olalm through the Orlevance Rovlou Prooeea, If yuuwlsh to appeal a dontal datlle ton, 9ontant the Member 9ervloes Depa rtinent ac 1-000-•I08.0gg5. E0l1. IDK.90 + IIUd 11. hAaauran°p %5'15 Inaefntata @'!va Payn 1 - Ilarrlabury, PA 1 '/ll0 t-Roo-780.8445 YAYMENI'S MAUR Dhl DEINLI' ph'; 0[CKRISON COLL6CIF ~ Cheok NI 886789 TN I9 IR hIO T A RILL EKPLANATION OF tlt;NRh'iPS ' ~ tneurad: ARMOLT, Rt CNV L RICKY L ARMOLT Pnetantl gRhIOhT, d091NA A 9 KIMBERLY LANE croup Nama: o. c,-RArm,Ty/gcgnehnc Pno CARLISLE, PA 17013 I.D, N° 8oB•36.94g9+D1 C'la lm N°.: 1713196] Dtlta: 05/26/1994 pAVREI tlANDF.N'LiA WEST 9NOItE/OUTPT Provider Datn of 9arvlan' -Totg1 Inal lylbla Co vered Code/96rvl esa F'pom 1'0 Charge A OANUEN'l,IA WNST 9110 03/04/1999 - Ol/O4 /1999 SD BD ~ mognt Coda Am ~ ount 90806/oTIII;R otPfpAT[F.N , ' 50,00 UAU(tEN7,1A Wn;91' 9110 0,1/11/1999. 03/11/1999 50,00 '10806 /OTIIF;R OIffPATi F,N 50,00 TOTAt,9: lao, o4 0.00 100.00 ' ~ L9a8 paduotlbla 0.00 ' 4eee Copay/ColnBUranoe 0.00 ~ . Neuafl[ 300.00- . Total Eonaf It Paid 300. 00 ' - Mambar Reeponelblllty 0,00 ~. GESCRi PTi ON OR REtMRK3/EENRF iT9 ' ' - L'bMPLAINT AND ORIGyAMCF. PROCF;UNRB A covnrarl Indtvldual has the. rlght.,to apponl a domed ola lm thrrnulh the orlsva ncs Hevlaw Proeane ' If ycu wish to, appoal n denial daelnlon, pon[act the Mambar sarvlcae Departmen , t at 1.000.78 R-Bg4B, ' EDn.ID%. 9B RICKY L. ARMOLT, PLAINTIFF V. SUSAN E. ARMOLT, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 98-0981 CIVIL ORDER OF COURT AND NOW, this ~~ _day of February, 2000, following a hearing on the merits, IT 15 ORDERED: (1 } The custody order of April 13, 1998, is vacated and replaced with order. (2) Susan E. Armolt and Ricky L. Armolt, shall have shared legal custody of Benjamin Armolt, born March 10, 1990, and Meredith Arrriolt, born April 1, 1992. (3) The mother shall have primary physical custody of Benjamin and Meredith, (4} The father shall have temporary physical custody of Benjamin and Meredith as follows: (a) On alternate weekends, the first alternate weekend from Friday after school until Sunday at 7;00 p.m., and the second alternate weekend from Thursday after school until Sunday at 7:00 p.m. The mother shall determine the sequence of these alternate weekends as is most convenient for her work schedule. (b) On the Wednesday or Thursday following the father's alternate weekend from after school until 7:00 p.m. The mother shall determine the day as is most convenient for her work schedule, (c) During the summer for four non-consecutive weeks (7 days each), interspersed with four non-consecutive weeks (7 days each) for the rcicther. (d) In even numbered years on New Year's Day and on Labor Day and in odd numbered years on Memorial Day and the Fourth of July. Mother shall have even numbered years on Memorial Day and the Fourth of July, and in odd numbered years on New Year's Day and Labor Day. (e) On Thanksgiving and Easter during one of two periods; the first period from 9:00 a.m. to 2:00 p.m., and the second period from 2:00 p.m. to 7:00 p.m. The parents shall alternate these periods so that in even numbered years father will havo the morning on Thanksgiving and the afternoon on Easter, and in odd numbered years mother will have the morning on Thanksgiving and the afternoon on Easter. (f) Every Father's Day from 9:00 a.m. to 7:00 p.m. Mother shall have every Mother's Day from 9:00 a.m. to 7:00 p.m. (g) On alternating periods at Christmas, the first extending from Christmas Eva at 1:00 p.m. to Christmas Day at 1:00 p.m., and the second extending from Christmas Day at 1;00 p.m. to December 26~" at 1:00 p.m. These periods shall alternate annually as of 1998 with mother having Christmas Eve at 1:00 p.m. and Christmas Uay at 1;00 p,m. By the Cour)/ ,,,•~~ ~I Edgar B. Baylay, J. ^ RICKY L, ARMOLT, IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. , SUSAN E, ARMOLT, ; DEFENDANT : 98-0961 CIVIL ORDER OF COURT AND NOW, this ~_,day of Fobrnary, 2000, the patltlon of Rlcky L. Armolt to hold Susan E, Armolt in conternpt, IS DISMISSED. By the Court, ±-~;~ ~ ~, `v/~~ :> .~ Edgar B, Bayley, J. Marcus A, McKnight, III, Esquire For Plaintiff L'O~I~S m~c~ccC ~IG~Db Carol J, Lindsay, Esquire For Defendant aaa AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduling conference or hearing. 2 RICKY L. ARMOLT, Petitioner/Defendant v. SUSAN E. (ARMOLT) KUNTZ, Respondent/Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW : 961-1998 CIVIL TERM . IN CUSTODY PETITION TO MODIFY CUSTODY AND NOW comes the PlaintifflPetitioner, Ricky L. Armolt, by his attorneys, Irwin & McKnight, and presents the following Petition to Modify Custody. 1. The Petitioner is Ricky L. Armolt, an adult individual residing at 10 Meadow Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Respondent is Susan E. (Armolt) Kuntz, an adult individual residing at 148 Chester Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are the natural parents of two (2) minor children, namely Benjamin Armolt, born March 10, 1990, and Meridith Armolt, born April 1, 1992. 4. The parties are currently governed by a custody Order of Court dated February 10, 2000, a copy of which is attached hereto and marked as Exhibit "A". 3 5. The Petitioner desires that the parties have shared legal custody and shazed physical custody of the minor children, Benjamin Armolt, and Meridith Armolt. 6. The best interests and permanent welfare of the minor children requires that the Court grant the Petitioner's request as set forth above. WHEREFORE, Petitioner, Ricky L. Armolt, respectfully requests that the parties have shared legal custody and shared physical custody of the minor children, Benjamin Armolt, and Meridith Armolt. Respectfully submitted, IRWIN & /~ ~~ By: arcus t, I, Esquire v for Plaintiff ~i 60 West Pomfret Street \ Cazlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court I. D. No. 25~ Date: July 25, 2007 4 RICKY L. ARMOLT, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. SUSAN E. ARMOLT, DEFENDANT 98-0961 CIVIL ORDER OF COURT AND NOW, this ~ day of February, 2000, following a hearing on the merits, IT IS ORDERED: (1) The custody order of April 13, 1998, is vacated and replaced with order. (2) Susan E. Armolt and Ricky L. Armolt, shall have shared legal custody of Benjamin Armolt, born March 10, 1990, and Meredith Armolt, born April 1, 1992. (3) The mother shall have primary physical custody of Benjamin and Meredith. (4) The father shall have temporary physical custody of Benjamin and Meredith as follows: (a) On alternate weekends, the first alternate weekend from Friday after school until Sunday at 7:00 p.m., and the second alternate weekend from Thursday after school until Sunday at 7:00 p.m. The mother shall determine the sequence of these alternate weekends as is most convenient for her work schedule. (b) On the Wednesday or Thursday following the father's alternate weekend from after school until 7:00 p.m. The mother shall determine the day as is most convenient for her work schedule. (c) During the summer for four non-consecutive weeks (7 days each), interspersed with four non-consecutive weeks (7 days each) for the mother. (d) In even numbered years on New Year's Day and on Labor Day and in odd numbered years on Memorial Day and the Fourth of July. Mother shall have even numbered years on Memorial Day and the Fourth of July, and in odd numbered years on New Year's Day and Labor Day. (e) On Thanksgiving and Easter during one of two periods; the first period from 9:00 a.m. to 2:00 p.m., and the second period from 2:00 p.m. to 7:00 p.m. The parents shall alternate these periods so that in even numbered years father will have the morning on Thanksgiving and the afternoon on Easter, and in odd numbered years mother will have the morning on Thanksgiving and the afternoon on Easter. (f) Every Father's Day from 9:00 a.m. to 7:00 p.m. Mother shall have every Mother's Day from 9:00 a.m. to 7:00 p.m. (g) On alternating periods at Christmas, the first extending from Christmas Eve at 1:00 p.m. to Christmas Day at 1:00 p.m., and the second extending from Christmas Day at 1:00 p.m. to December 26th at 1:00 p.m. These periods shall alternate annually as of 1998 with mother having Christmas Eve at 1:00 p.m. and Christmas Day at 1:00 p.m. TRUE COPY FROM REOORD In Testimony whereoi`, f here unto set my hand rind the of said 0 Carlisle, ~Pa. day By the Cou^~ i ,, . Edgar B. Bayley,'J. Marcus A. McKnight, III, Esquire For the father Carol J. Lindsay, Esquire For the mother :saa RICKY L. ARMOLT, IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. SUSAN E. ARMOLT, DEFENDANT 98-0961 CIVIL ORDER OF COURT AND NOW, this ~~ day of February, 2000, the petition of Ricky L. Armolt to hold Susan E. Armolt in contempt, IS DISMISSED. By Edgar B. Bayley, i Marcus A. McKnight, III, Esquire For Plaintiff Carol J. Lindsay, Esquire For Defendant :saa TRUE COPY FROM RECORD I ~ Testimony wheroat, !mere into set my hand 2nd the aeal~of said t Carlisle, ~f'°~~ Rothaat~ry VERIFICATION The foregoing Petition to Modify Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have head the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. _. C L. LT Date: July 25, 2007 5 ~ ( (~ ~ J S'~ ~`~ ?~~~'' tiw} ~J - _ L__, ---f i'~.7 -' ~-° i C t ""'7 ` ~ ~~~'r ~~ ~ I r~~ :~~ cv --~ Q p /" RICKY L. ARMOLT IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 1998-961 CIVIL ACTION LAW SUSAN E. (ARMOLT) KUNTZ IN CUSTODY DF..,FF..,NDANT ORDER OF COURT AND NOW, Monday, July 30, 2007 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, September 05, 2007 at 8:30 AM for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilro Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabitites 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 Y-OUR 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~~-~.'r?-~C1~~l~ ~,.. RICKY L. ARMOLT, Plaintlff v SUSAN E. (ARMOLT} KUNTZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO.1998-0961 IN CUSTODY COURT ORDER AND NOW, this ~ 1 day of September, 2007, upon consideration of the attached Custody Conciliation report, it is ordered and directed that this Court's prior Order of February 10, 2000 shall remain in effect. In the event either party desires to change the prior Order, that party may petition the Court to have the case again scheduled for a conference with the Custody Conciliator. BY THE Judge Edgar cc: +,AO~ cus A. McKnight, III, Esquire assn E. (Armolt) Kuntz mesa:i c.aoay co.~.e~..~trotwrsva:i.n~. xoa cond~tlon Repert~Aaer.wpa • . ca+ ,~ ~ _ ., ~. ~~ ~. .., ~• SEP 10 2007 ~~ RICKY L. ARMOLT, Plaintiff v SUSAN E. (ARMOLT) KUNTZ, Defendant Prior Judge: Edgar B. Bayley IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.1998-0961 1N CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF FROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation are as follows: Benjamin Armolt, born March 10,1990, aad Meredith Armolt, born April 1,1992. 2. A Conciliation Conference was held on September 5, 2007, with the following individuals in attendance: The father, Ricky L. Armolt, with his counsel, Marcus A. Mckaight, III, Esquire, Esquire, and the mother, Susan E. (Armolt) Kuntz, who appeared without counsel. 3. At the conference, it was discussed that the minor child Benjamin has been living primarily with the father since April 2007. However, for a variety of reasons, the parties determined the existing custody Order should remain in place. It is noted by the Conciliator that the father should encourage Benjamin to go to visit his mother as appropriate. 4. The Conciliator recommendations an Order in the form as attached. Date: ~ Hubert X. Gilr . ,Esquire Custody COD lator