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MICHAEL STETZ,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
V.
LAURA M. STETZ,
Defendant NO. 98-1104 CIVIL TERM
IN RE: CUSTODY
ORDER OF COURT
AND NOW, this 21st day of August, 1998, after
hearing, the Court makes the following order:
1. The parties shall have shared legal custody of the
child, Gabrielle Stetz, born 8/25/94.
2, Mother shall have primary physical custody.
3. Father shall have partial physical custody as
follows:
a. From today at 5:00 p.m. until he returns to
San Diego or August 28th, 1998, whichever is sooner.
b. Each year at Christmas from December 22nd
until December 29th if visitation is to be exercised in San
Diego. From Christmas Day at noon until January 1st at noon if
visitation is to be exercised in Pennsylvania or Maryland.
If visitation is exercised in San Diego, father shall
send mother a round trip plane ticket for child at least thirty
days before commencement of visitation. The costs of
transporting the child at Christmas shall be borne by father.
c. Each summer from the Saturday after school
ends until one week before school begins, The costs of
transporting the child for summer visitation shall be borne by
mother.
d. Anytime father is in the area he may visit
with the child upon appropriate notice to mother for as long as
he is in the area.
e. At such other times as the parties agree.
4. Father's parents may visit with the child on the
first and third weekend of each month from saturday at 9:00 a.m.
until sunday at 5:00 p.m. if they so desire. At least seven
days notice shall be given to mother if they desire to exercise
any such visitation.
5. Mother shall begin counseling with a therapist who
is competent to handle dual diagnoses problems. Any therapist
chosen by mother ahall be approved by Dr. Shienvold, said
approval to be forwarded to the Court and father's counsel.
Mother shall remain in said therapy until successfully released.
Mother shall not drink any alcoholic beverages
whatsoever. A violation of the conditions set forth herein
shall be deemed a change in circumstances justifying another
hearing before this Court.
6. Mother shall provide father with all report cards
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and other school progress reports. Mother shall advise paternal
grandparents of all school activities.
7. Each parent shall continue and encourage frequent
and liberal contact with the non-custodial parent.
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I.A W OJ1I'IGHS
BARBARA SUMPLE-SULLIVAN
1\40 1J.IIJ1llll STlllmT
NIlIV OU~IIlIlIlI.^l'm,I'IlNNSYI.vANI^ 17070.1001
PIIONH (717) 77'l-I4.,n
I1AX' (717) n"-70ftU
November 16, 1998
The Honorable Edward Guido
Cumberland County Courthouse
I Courthouse Square
Carlisle, PA 17013
via fall ( 240-6462) and mail
re: Stetz v. Stetz
No. 98-110.. Civil Term
Dear Judge Guidu;
Please be advised that on November 12, 1998 Ms. Gilius notified me that she will not continue
to undertake therapy with Laura Stetz. In explaining her reason for the termination of her
involvement, Ms. Gilius advised that it is her personal and professional philosophy not to undertake
therapy wherein there are reporting requirements by the court or possible court testimony. It is my
understanding that Ms, Gilus may have attempted to communicate her position to the Court.
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When I learned of her possible intentions, I contacted Dr. Shienvold on November 9, 1998
to ask that he provide additional names and request his assistance in facilitating the scheduling of an
appointment with either a new therapist or reapproaching one of the other therapists he previously
recommended, As you may recall, some of the other therapists Dr. Shienvold previously
recommended were either not taking new clients or did not have an open appointment for several
months, I, again touched base with Dr. Shienvold on November II, 1998 concerning the status of
his efforts,
Another therapist in Ms. Gilius' group agreed to takeover Laura's therapy. Her name is
Shawna S. Brent, M.D. When I discussed this with Dr. Shienvold, he expressed reluctance to use
anyone he is not familiar with. A copy of her resume was forwarded to Dr, Shienvold on November
12, 1998, We are awaiting feedback from Dr. Shienvold for additional acceptable names of therapists
for Laura to contact, his efforts in reapproaching the previous therapists and as to the acceptability
of Dr. Brent. I understand that my client has scheduled an appointment with Dr. Brent, at least on
an interim basis.
: ~
MICHAEL STETZ, ) IN TIlE COURT OF COMMON PLEAS
I'laintiff ) OF CUMBERLAND COUNTY,
) I'ENNSYLVANIA
vs, )
) NO, 98-1104 CIVIL TERM
LAURA M. STETZ, )
Dcfcndant ) CUSTODY /VISITATION
ORDER
AND NOW, this /3-d, day of /nA Y
, 1998, upon receipt of the
Conciliator's Rcport, it appcaring that thc partics havc agrccd to thc tcrms and provisions of this
Ordcr which was dictatcd in thcir prcsencc and approvcd by thcm and thcir counscl, it is hcrcby
ordcred ancl dircctcd as follows:
I, A hcaring is scheduled for thc / ~ day of 1/ "~/.d
1998, at f': tiS o'clock L.M" in Court Room NumberS ofthc
Cumb~rland County Court House, Carlisle, Pcnnsylvania, lJoth parties, through
counsel, will provide cach othcr and thc court with a list of witncsscs ten (10)
days prior to thc datc ofthc hcaring along with a statcment as to their expected
tcstimony, Additionally, both partics will submit their proposal for a rcsolution of
the matter.
2. Thc parties agrcc that thcy shall coopcratc in a custody evaluation. The
parties shall dccide within tcn (10) days of the datc of this Ordcr who shall
complctc thc cvaluation, Thc cost ofthc cvaluation shall be dividcd such that
Fathcr shall bc rcsponsiblc for 60% and Mothcr shall bc responsiblc for 40% of
MICHAEL STETZ,
)
)
)
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)
)
)
IN TIlE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plainti/l'
vs,
LAURA M, STETZ,
NO, 98-1104 CIVIL TERM
Dcfendant
CUSTODYIVISITATION
JUDGE PREVIOUSL Y ASSIGNED: Nonc
CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE \VITI-I CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915,3-8(b), thc undcrsigncd Custody Conciliator submits the following report:
), Thc pcrtincnt information conccrning thc chiJd(rcn) who is(arc) the subject of this
litigation is as follows:
NAME
BlRTI'IDATE
CURRENTLY IN
CI1STODY OF
Gabrielle Stetz
August 25, 1994
Dcfendant
2, A Conciliation Confcrcnce was hcld on May I, 1998, and the following individuals
wcre prescnt: thc Plaintiff and his attorncy, Paigc Macdonald-Matthcs, Esquire; the Defendant
appcarcd with her attorncy, Barbara Sumplc-Sullivan, Esquirc.
3. Itcms rcsolved by agrecmcnt: Sec attached Order,
4. Issucs yctto bc rcsolvcd: An ultimatc custody schedule.
5, Thc Plaintiffs position on cusrody is as follows: Fathcr relocatcd to California in
October bascd upon what hc bclievcd to bc an agrccmcnt with his wifc that she would follow.
Thcreafier, it was dctcrmincd that she was not going to comc to California but according to him,
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shc ugrccd tolct him have custody of Ihc child during Ihc school ycur und shc would huvc
custody during thc summcr monlhs, Futhcr thcn indicatcd thut Mothcr rcncgcd on that promisc
uswcll,
Futhcr hclicvcs Ihut hc should bc thc primary custodial parcnt during thc school ycar and
havc Mothcr with thc child during thc summcr months, l'lc has raiscd an issuc about Mothcr
having an alcohol problcm und is conccrncd tlmt thc child is with bubysillcrs an exccssivc
amount of the time. Fathcr rcqucsted an cvaluation which thc Mothcr has ugrccd to in this cuse,
6, Thc Dcfcndant's position on custody is us follows: Mother disputcs the factuuI
ulIcgations with thc arrungcmcnt with Futhcr moving to California. Shc indicuted that the parties
wcrc having somc muritul difTIcultics und that Futher hud a curcer advunccment opportunity und
took it, but that bccausc of their marital problcms, shc wus not willing to move wcst. She ulso
dcnics that shc agrccd that thc child should bc in his carc primarily during thc school year.
Mothcr inrficatcd tlmt both shc and hcr husband drunk frcqucntly during thc course of
their murriagc und thut it cumc to r. point tlmt shc bclicved that she should get some out-patient
therupy for it. Shc rclatcs thut she did gct thc out-paticnt thcrupy whilc thc purties wcre togcther
und that shc docs not drink at this timc nor docs shc believc shc has un on-going alcohol
problcm. Shc bclicvcs that hcr ulcohol consumption is no more significunt tlmn Futhcr's alcohol
consumption,
Mother bclicvcs tlmt thc child should rcmain with hcr during thc school ycur und go out
with Futhcr during thc summcr months. Shc rclatcs that for thc first two und u hulfycurs ofthc
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child's life, shc workcd part-timc and thcrclorc spcnt morc timc with thc child, Shc wcnt back to
work full-timc whcn thc child was two and a half,
7, Nccd lor scparatc counscl to rcprcscnt child(rcn): Neithcr party rcqucsted.
8, Nccd lor indcpcndcnt psychological cvaluation or counseling: Scc attachcd Order,
9. A hcaring in this mattcr will takc one day.
10. Othcr mattcrs or commcnts: This is a relocation casc, Thc Conciliator rclatcd to the
partics that it was his vicw that given thc fact that the child is bcginning school in the fall, that
the court will in all likelihood havc onc of thc parents be the primary custodial parcnt during the
school timc and the other parcnt be thc primary custodial parcnt during thc non-school time,
This of course, assumcs that neither party has any outstanding issucs that would prevent him or
her from exercising extcnded pcriods of time with thc child,
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Thc parties did agrce to an cvaluation and will havc that performed. The court needs to
have this case resolvcd prior to the commenccmcnt of the school ycar.
Date: May 7,1998
Mic ael L, Bangs
Custody Conciliator
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NOTICIA
Le han demandado a usted en 1a corte. 5i usted quiere
defenderse de estas demandas expuestas en 1as paginas
diguientes, usted tiene viente (20) dias de p1azo a1 partir de
1a fecha de 1a demanda y 1a notificacion. Usted debe
presentar una apariencia escrita 0 en persona 0 por abogado y
archivar en la corte en forma escrita sus defensas 0 sUs
obj eciones alas demandas en contra de su persona. Sea
avidaso que 3i usted no se defiende, la corte tomara medidas
y puede entrar una orden contra usted sin previo aviso 0
notificacion y por cualquier queja 0 a1ivio que es pedido en
la peticion de demanda. Usted puede perder dinero 0 sus
propiedades 0 otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO
TINE ABOGADO OSI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL
SERVICIO, VAYA EN PERSONA OLLAME POR TELEFONO A LA OFICINA
CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJOPARA AVERIGUAR DON DE
SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY COURT ADMINISTRATOR
Cumberland county Courthouse
1 Courthouse Square-4th Floor
Carlisle, Pa 17013-3387
Telephone: (717) 240-6200
Respectfully submitted,
CUNNINGHAM & CHERNICOFF, P.C.
Date: ''':~Jl'\.I.Ij'~I({ -/'JI~':\"\~
------ "
By: v... l'_~ t)f h,.... "'~~'"Y'fLI...J ~ f'(,~_tt1.",-'1
Paige Macdonald-Matthes, Esquire
I. D. #66266
2320 North Second Street
P.O. Box 60457
Harrisburg, PA 17106-0457
(717) 238-6570
2
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7. The best interest and permanent welfare of the child
will be served by granting the relief requested because:
a. the child has always looked to Plaintiff
as a constant source of love and support;
b. the Defendant has a severe alcoholism
problem for which she has attempted on numerous
occasions to seek treatment for. Defendant, for
whatever reasons, has historically been unable to
complete her outpatient alcohol addiction programs
and inevitably goes back to drinking;
c. On numerous occasions Plaintiff has
observed Defendant under the influence of alcohol
in the presence of their minor child. There have
been numerous times when the level of Defendant's
intoxication has prevented her from being able to
provide adequate care for the child;
d. the Defendant suffers from depression
which is exacerbated by the Defendant's drinking
problem; and
e. the Plaintiff can provide a more stable,
loving and nurturing environment for the child than
the Defendant can provide.
4
8. Each parent whose parental rights to the child have
not been terminated and the person who has physical custody of
the child have been named as parties to this action. All
other persons, named below, who are known to have or claim a
right to custody or visitation of the child have been given
notice of the pendency of this action and the right to
intervene: None.
WHEREFORE, Plaintiff requests the Court to grant shared
legal and physical custody of Gabrielle stetz.
RespectfUlly submitted,
CUNNINGHAM & CHERNICOFF, P.C.
Date: ,.Ie" (. N. '/ ?),I,\"t
By: -S:-;~\~t' '_~,","Y\/'.A]'o,~Q;J. Nv,'t..:-4\o)/\
Paige Macdonald-Matthes, Esquire
I.D. #66266
2320 North Second Street
P.O. Box 60457
Harrisburg, PA 17106-0457
(717) 238-6570
5
VERIFICATION
I, Michael stetz, verify that the statements made in the
foregoing Complaint for custody are true and correct to the
best of my knowledge, information and belief. I understand
that false statements herein are made subject to the penalties
of 18 Pa. C.S. ~4904, relating to unsworn falsification to
authorities.
Date:
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F1LEIXJFFlCE
OF TI,l: Pr,OTI,ONOTMY
, ~ ~'t9 'M, ....~- /"'?T 0/0/ Y6' Clt.-"'E' 98 MAR 20 PH 3: 32
. ~ :z /f/'1?H1' ~t, ::1.7 O~ [ CUM5Em/.J'll) COUNTY
4, - , /1/' - PEN~m1.VIIN!A
'7~h( -/f1:M~W JJ? ~ 717W hVJ{} pttl J6'~. E'
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J.AW OI'FIOIlS
BARBARA SUMPLE-SULLIV AN
1\4uIIIllllOll STIlIlIlT
NIlW aU~IIlIUII.AND,I'IlNNSYI.vANIA 17070-1001
J'1I0NIl (717) 7....'....1\
l'AJ( (717) 77'&-7Uftn
Octobei' 6, 1998
The Honorable Edward Guido
Cumberland County Courthouse
I Courthouse Square
Carlisle, PA 17013
re: Stetz v. Stetz
No. 98-1104 Civil Term
Dear Judge Guido:
Pursuant to your Order dated August 21, 1998, enclosed please find a copy of a receipt from
Susan L, Gillis, M,S" CAAP confirmillg my client's attendance at a therapy session on September
28, 1998, As noted, Laura has another visit scheduled for October 9, 1998,
Verbal approval ofMs, Gillis was provided by Dr, Shienvold on September 22, 1998, Written
confirmation from Dr, Shienvold is also enclosed herewith. Please be advised that Laura also
continues to attend AA meetings and had a follow-up vis' th New Insights.
,
?
Barbara Sumple-Sullivan
BSSllw
Enclosure
cc: Paige Macdonald Mathes, Esquire
Laura Matthews (w/enclosure)
1/
SEP-3e-1998
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PSYCffiATRlC ASSOCIATES OF CENTRAL PENNSYLVA;'lJA
20 Erford Rood, Suite 101
Lemoyne, PA 11043 .
Ttlephone Nn,' (111)130.8555
Frd"I' TIII,D. :'Iumb", ~~'1767~18
) Poul A. Conl~ M.D.
t ) Clrol A, Flory. M,S. W.
( J Rlrbord J. FO.lo. ~'.D.
(/) SUII. L. Glllul, M,S., CMP
( ) Bre.l L. MIll1llre, Ph.D.
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I STATEMENT I
~ mo111wJs
Date ~s~lor.: -.S:!.~Appmt. Time: _I :00
-:') ~ Copay:
lYrE OF VISIT FEE ^DJt:SPlENT
CI counesy
CI b..d.hlp
AmUate..
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SSN.
Name of Pilttie,t:
DOB: .alq (p~
Primary InsuraDce:
CODE
(CIIlCLE)
In,I;M Orlented, II<hlv'or ~I.dl(ylnloncll.r
SUFpo,tlv. P1y.h.thonpy,
64'.) Dllrna.d, lure..I... E1Im
Ind. Th.rAPY 12D-30 mln)
90805 ",Irb mod IVai/mill""''''
9lI10d Ind. Therlpy (4"50 mln,
901107 wltb mrd "II/mitt urvh:n
Intulu:llvo Ps)'cholhL'l'Ap)'1
9080: Inlcrlttl". D,.It. 'ntcrvl.w i:xam
90110 1011lrocll..l"d, Thor. (2D-.10 mln)
90811 with mid (IuUmiJt SIn-fen
90812 Intorlellva Ind. Th.r.14'-'O 101.)
90813 ~Irh DIed IVlUmR( ,,"leal
Ulba:r:
9082' F.volulrl"" :IIld 11...,d.
901J.16 Family Psy.halher.py (W/O PL)
90841 F.mUy C.lalnr P'y,h.thcrAPY
90849 Mull, F'm. Grr, P1y.hu",c..PY
9lI8S~ Croup P'y'h.'herapy
00863 rh4rmocoloafc M:lnllS:;lmcnC
90880 Medl.al Hypn.lh."py
9OKH7 Inror. nr Kauhs CO FmlyIOlht'r1
90889 Prcpararlon orR'pUrl
9(;100 P!lycholoa1cal Tc:ulns
99372 Tc:Ic:phoDf CanAull
OOOUO NQ Sho\y
III t I Jmprop.r (,'.nctllarlon
JCD-9.CM DIAGNOSIS:
. ~ID.o2!871.E
. Sw.o001!4-E
. ;\-IO.o29081.E
. PS-006908.L
. PS.oO!159.L
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PLIU..SE ,\f,l,KE CllECKS,PA Y ABLE TO, l' ACP
FEElCOPAY~IENT IS E,'(PEC,,.ED ATTIME OF VISIT
THIS IS.\ BILL FOR "NY EXISTPlC: B"I.i"I;CE.~
THAT AHE NOT INSURA.\;CE R~PONSrm,ITY
DSM.IV DIAGNOSIS:
~() ~ Ou
NEXT APPOJ:'\"TME:-I
v'" Dale:
Provider', Sl2nalurc:
TOTAL p.al
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MICHAEL STETZ,
Plaintiff
.
.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 98-1104 CIVIL TERM
v.
LAURA M. STETZ,
Defendant
CUSTODY
PLAINTIFF'S PRE-TRIAL MEMORANDUM
AND NOW, comes the Plaintiff, Michael Stetz, by and
through his counsel, Cunningham & Chernicoff, P.c., and files
his Pre-Trial Memorandum in regard to the above referenced
custody matter and in support thereof avers as follows:
I. STATEMENT OF CASE
Michael Stetz (hereinafter referred to as "FATHER"), and
Laura M. Stetz (hereinafter referred to as "MOTHER"), are the
parents of one (1) minor child, Gabrielle stetz (DOB: August
25, 1994). In late summer, 1997, the FATHER received a jOb
offer as a reporter with the San Dieao Union Tribune in San
Diego, California. After much discussion concerning the jOb
offer and a proposed relocation to California with MOTHER, the
parties mutually agreed that it would be in their best
interest, as well as in the child's best interest, for the
parties to relocate to California.
The parties had been
experiencing marital problems, which were in large part
attributable to MOTHER'S alcohol problem, and it was MOTHER
who encouraged FATHER to accept the job because it would
provide the family with the "fresh start" they needed.
The original plan that was negotiated between the parties
concerning the move to California was that FATHER would go to
California in October 1997 and establish a place of residence
for his family.
Once FATHER found and established living
accommodations for the family, MOTHER and Gabrielle would join
him.
In the interim, MOTHER assured FATHER that she would
continue to seek treatment and counselling for her alcohol
addiction. This plan was negotiated by the parties with the
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assistance of their marriage counselor, Rick Sanseverino.
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Pursuant to the parties I agreement, FATHER moved to
California on October 16, 1997. At the time of his departure,
MOTHER was in counselling for her alcohol problem.
Unfortunately, MOTHER reneged on her agreement to relocate to
California, as well as her promise to continue counselling,
and in December 1997 informed FATHER that she "did not love
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him anymore", and wanted a divorce. She also informed FATHER
she was no longer in counselling. Although prior to this time
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the parties had experienced marital problems, FATHER was of
the belief that MOTHER was being truthful when she informed
him that she believed that the move to California would be a
good thing for the marriage, as it would afford both parties,
in her words, a "fresh start". Unfortunately, this was not to
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be and FATHER ultimately filed a Complaint in Divorce on
February 27, 1998.
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since October 16, 1997, the parties' daughter, Gabrielle
has been in the primary physical custody of her MOTHER. FATHER
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is somewhat reluctant to say, however, that MOTHER has been
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the "primary caregiver", of Gabrielle, in light of the fact
that FATHER believes that the child has spent more time with
third parties, in babysitting settings, then she has with her
MOTHER. Prior to his move to California on October 16, 1997,
the FATHER had been the primary caregiver of Gabrielle, even
during the time that MOTHER was only working part-time.
Indeed, it was quite common for the Defendant to mention her
dissatisfaction with being a "stay-at-home morn" to both
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FATHER, and their mutual friends.
As a consequence of the
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same, FATHER was called upon more often then not, to care for
Gabrielle, even though MOTHER was not working full-time.
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During the parties I marriage, the parties socialized
frequently.
Part of the socialization included attending
events where alcohol was served.
During the course of the
parties' marriage, it became apparent to FATHER that MOTHER
had a problem with alcohol, such that she often became
intoxicated to the point where she would have blackouts, and
would be unable to remember the events of the night before.
On numerous occasions, the FATHER would observe MOTHER under
the influence of alcohol in the presence of their minor child,
and on at least one occasion observed MOTHER under the
influence while she was supposed to be caring for a mutuG~
friend I S minor child, Quentin.
Despi te her problem with
alcohol, MOTHER has attempted, unsucceSSfully, on numerous
occasions to seek treatment for her alcoholism. MOTHER has,
for whatever reasons, been unable to complete out-patient
alcohol addiction programs and inevitably goes back to
drinking. While MOTHER claims that she has stopped drinking,
FATHER questions the sincerity of her conviction, and sadly
SUspects that it directly correlates to the upcoming custody
trial in this matter.
FATHER believes that he is the best parent suited to be
the primary custodian of Gabrielle.
The child has always
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looked to FATHER as a constant source of love and SUPPort, and
FATHER believes that he can provide a more stable, loving and
nurturing environment for the child then MOTHER can Provide.
FATHER has taken such efforts to ensure that the best interest
of the child will be served, by moving to Point Lorna, a lovely
residential area of San Diego, California, which is only five
(5) minutes from his Place of employment, and five (5) minutes
from the school that Gabrielle would attend, Silver Gate
Elementary School, a magnet school. FATHER does not Work in
the evenings, nor on weekends, whereas as MOTHER freqUently is
called to work in the evening and on weekends thus, FATHER
could provide a structured environment for Gabrielle which is
so important for a young child. FATHER believes that he can
provide a loving and nurturing environment for Gabrielle in
hi.s home in San Diego, California, well at the same time,
enCOuraging, and facilitating, the On-gOing relationship that
Gabrielle currently enjoys with her paternal grandparents,
FATHER would agree to facilitate visitation with MOTHER during
the summer months provided, of course, that MOTHER faithfUlly
attends alcohol counselling and receives the help she needs.
FATHER would ensure that MOTHER would be included in all
parenting decisions sUch as sChoOling and activities for
Gabrielle.
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II. ANTICIPATED LENGTH OF HEARING:
One and one-half (1~) days.
III. WITNESSES
A.
Plaintiff, as on direct.
Plaintiff will testify
concerning each parties' parenting roles during the course of
the parties' marriage.
Plaintiff will further testify
concerning his concerns about Defendant's alcoholism, and its
effect on Gabrielle.
B. Defendant, as on cross
C. Teresa Candori. Mutual friend of the Plaintiff and
Defendant.
Ms. Candori will testify concerning her
relationship with the Plaintiff and the Defendant, as both
their neighbor and friend during the period of time that the
Plaintiff and Defendant resided together as husband and wife
in Harrisburg, Pennsylvania. Ms. Candori will also testify
concerning her observations of both Plaintiff and Defendant as
a parent, and will testify concerning her observations of the
Defendant's problems and dissatisfaction in providing care for
Gabrielle and the problems she experienced with Defendant when
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she entrusted her own son to Defendant's care. Finally, Ms.
Candori will testify concerning Defendant's statements that
she did not like having to stay at home and care for
Gabrielle.
D.
Patrick LaForge.
A former social friend of the
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Plaintiff and Defendant, and former co-worker of Defendant.
Mr. LaForge will testify concerning his social interaction
with the Plaintiff and the Defendant, and his observations of
Defendant's continued Willingness to drink to a point of
intoxication at most every social event. Mr. LaForge will
also testify concerning his observations of both Plaintiff and
Defendant's parenting skills and interaction with their minor
child, Gabrielle.
E. Len stetz. Plaintiff's father. Plaintiff's father
will testify concerning his observations of both Plaintiff's
and Defendant's parenting abilities, and their interaction
with Gabrielle.
F.
Edith stetz.
Plaintiff's mother.
Plaintiff's
mother will testify concerning his observations of both
Plaintiff's and Defendant's parenting abilities, and their
7
interaction with Gabrielle.
Plaintiff reserves the right to call additional
witnesses, with advance notice of the same being provided to
Defendant's counsel, and the Court.
IV. EXPERT WITNESSES
Arnold Shienvold, Ph.D. was the court appointed joint
evaluator. He will testify concerning his recommendations.
V. UNUSUAL LEGAL OR EVIDENTIARY MATTERS
None at this time.
VI. PROPOSED RESOLUTION
Plaintiff respectfully requests that this Honorable Court
award him primary physical custody of Gabrielle, with
Defendant being awarded partial physical custody for purposes
of visitation as follows:
1. Summer: Defendant shall have Gabrielle eight (8)
weeks during the summer, as was originally agreed to by the
parties in December 1997;
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2. School Vacation: Defendant shall have Gabrielle for
all school breaks greater than four (4) days contingent upon
the ability the ensure the young child's safety during cross
country travel;
3. Such other times as the parties can agree.
Respectfully submitted,
CUNNINGHAM & CHERNICOFF, P.C.
Date: Auqust 11. 1998
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By: 1....-, It. "II' ~ \\,,^,.,~ ',^-~,tY ~x,.\t\..+H"'0
Paige Macdonald-Matthes, Esquire
I. D. #66266
2320 North Second Street
P.O. Box 60457
Harrisburg, PA 17106-0457
(717) 238-6570
(Attorneys for Plaintiff)
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CERTIFICATE OF SERVICE
I, Paige Macdonald-Mattes, Esquire, hereby certify that
a true and correct copy of the foregoing Pre-Trial Memorandum
was served by first-class mail, postage prepaid, on the
following:
Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, Pa 17070
(Attorneys for Defendant)
Respectfully submitted,
CUNNINGHAM & CHERNICOFF, P.C.
Date: Auqust 11. 1998
By: ~~, ,\;--,,"1',,).~_ \Y\N.tlhP<,
Paige Macdonald-Matthes, Esquire
I. D. #66266
2320 North Second Street
P.O. Box 60457
Harrisburg, PA 17106-0457
(717) 238-6570
(Attorneys for Plaintiff)
10
JOIUMN D. CUNNINl;IIMI
IIOIIElIT E. CI mIINICOFI:
I'AIGE ~IACIX1NAI.IHIAITIIE~
MAIlC W. WITZIG
EDWIN A.D. ~CIII\'AIlI'l.
CUNNINGHAM & CI-IERNICOFF, P.c.
/I'ITOIlNEYS AT I.AW
2320 NOKI'I I SECOND STIUiET
1',0. BOX (,0,157
IIAIlRISBUIlG. I'ENNSYI.VANIA 17111(o,(J.I57
II(S NO, 2.1.227.1IJ"
IIEII~1 my TEI.El'llllNE
(717) 51,1.2H.U
IEI.I'I'llllNE
(717) 2:lH.f15711
FAX
(717)2,lK..IIltI'1
August 11, 1998
Mr. curtis R. Long
Cumberland County Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
Re: Stetz v. Stetz
Docket No. 98-1104 Civil Term
Plaintiff's Pre-Trial Memorandum
Dear Mr. Long:
Enclosed for filing is an original and three (3) copies of the
Plaintiff's Pre-Trial Memorandum per Judge Guido's Order dated May
13, 1998.
I would respectfully request that you time-stamp the
enclosed copies and mail the time-stamped copies to me in the self-
addressed, stamped envelopes enclosed herewith.
Thank you for your time and attention to this matter.
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Very truly yours,
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CUNNINGHAM & CHERNICOFF, P.C.
~~ c=--~ ~\~cS,''V'.ld'_\'.~'I''-::J
Paige Macdonald-Matthes
PMM/dlb
Enclosures
cc: Barbara Sumple-Sullivan, Esquire
Michael Stetz
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necessary to make long-distance co-parenting work, Defendant will insure that Plaintiff is
included on the parenting issues such as schooling and activities, Defendant will also allow liberal
visitation with paternal grandparents, who live in this area.
II.
ANTICIPATED LENGTH OF HEARING:
One and one-half (] 1/2) days.
III. WITNESSES
A, Defendant, as on direct. She will testifY each party's parenting role and her plans to
include Father as much as possible even though he is in California.
B. Plaintiff, as on cross.
C, Amanda Hermitt. Gabrielle's caregiver since late December. She will testifY as to her
observations of Defendant as a parent. She will also confirm that she has not seen any
evidence of Mother drinking.
D. Brian, A friend of Mother's from the AA program. He will testifY as to Mother's
continued success in the program.
E.
Virginia Ruff. Friend and caregiver for Gabrielle. She will testifY as to her
observations of Defendant as a parent. She will also confirm that she has not seen any
evidence of Mother drinking.
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Channah Aviles, Neighbor and occasional babysitter. She will testifY as to her
observations of Defendant as a parent. She will also confirm that she has not seen any
evidence of Mother drinking,
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G, Maureen Hughes. Mother's boss. She will testifY that Mother is a responsible person.
Defendant reserves her right to call ad 4itional witnesses upon review of Plaintitl"s Pre-Trial
Memorandum,
IV. EXPERT WITNESSES
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Arnold Shienvold, Ph.D. was the court appointed joint evaluator. He will testifY concerning
his recommendations.
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Team Work.s High Conflict Intervention Program
0,
The High Conflict Couple and Children (Part One)
party's ends wilh arguments, tears, threats
or accusations,
In conflict for more than two years.
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HIUh ConllJct Custody cases Usually
lnvolw parCl1ls thar havc difficulty
sharJng thc chlldrcn or can'r agree on
I child sharing Issues, A case may
I become highly conlllclual (or many reasons, High
conll/cl Cl\!es I1t one or more of the fOlloWing
criteria: Cuses where there have been;
I. Frequcnt COllrt litigation or diSputes, over
minor or major child .haring issues,
· Any fonn of physical violence,
Inllmldnllon or stalking,
Any form of verbal Or
non-verbal aggression,
abuse, harassment or
UlCeats,
Continuous and chronic
co-parcnting
dimcullies, even over
minor issues,
An Inability to protect
the children from the
conflict, or one parent
or both may actually encourage the
children to side with one of them,
An inability ro recognize that the children
are separate from the parent's own iSsues
o( anger and hun,
An inability to move past the conflict and
build a new !ffe with the children, as a
single parent,
Highly litIgated with allegations (false or
true) of abUse of any kind,
One where One parent refuses to share the
children with the other parent,
Appearances at family coUrt services three
or more rimes in one year,
An Inability to get along in front of the
children and communication between the
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About 75-80% of the litigated family or
relationship break up (with children) will setUe
down within tlle tirst two to three years after the
initial break up. Anolher 25% of the break up
cases will become high conflict cases. These
cases remain emotionally contlictual and usually
increase in their intensity as the conflict
continues, Some of these oases last for years.
Some parents never ger over the hurt, ~ger and
bitterness of the break up and the conflICt.
There are common characteristics that run
through rhese high conflict cases, These
characteristics include relationships where one of
the partners is not prepared or willing to accept
the break up because they have become very
dependent upon the other Partner in their
relationShip, or one or both of the Partners has
experienced a traumatic loss in their lives, either
in their childhood or in the marriage, Such as the
death of a child or a family member and never
dealt with the first loss; the seCond loss now
compounds the firsr loss.
Whatever the reason for the break up. one
or both of the Partners are wounded by the break
up so much, that they are unable or unWilling to
give up their partner High conflict cases can be
exacerbated due to additional problems such as
alcohol, drugs, emotional, sexual or physical
addition or abuse. In high conflicr cases. a parent
who feels like they have lost their identity or
security. due to the break up, becomes o.bsessed
with What has happened to them, either In a
victimized way Or revengeful way. The conflict
keeps the couple communicating with each other,
so the relationShip doesn't really have a chance to
end. One parent usually continues the conflict,
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, while one parent reacts to the
conflict. Both have a part in
keeping the conflict going,
however,
The bottom line for these
high conflict cases, is that they are
right! They rnust prove, at all costs, that they are
the best parent, and perhaps the only parent to
have contact or custody of their children, The
energy spent in proving their side of the story to
courts, counselors and family members become
polarized toward that end, they are obsessed with
proving they are right and the other parent is
wrong, Going to great lengths to validate their
argument. Gathering declarations, testimonv, and
evidence that prove that they are right and the
other wrong, they are good and the other parent is
bad. They become so polarized in their attitudes
about the other parent, they believe that the other
parent is really bad, has serious problems, and
should have limited or no contact with their
children,
The longer the conflict goes on, the deeper
the wounds from the break up, the more polarized
the parents become.
As the conflict continues, parents' fear of
losing their children begins to be confirmed with
actions taken by the other parent, attorneys,
counselors and judges, An emotionally wounded
parent sees the loss of the children along with the
loss of the partner as too much to handle, and their
efforts to keep that from happening increases.
The children in this conflict are now
caught in a huge struggle. The fight over who is
best for the children actually ends up destroying
the children, The conflict has an impact upon the
children, creating permanent emotional and social
scars. While the parents continue to argue over the
children, they are actually destroying them, with
their fighting,
The children of high conflict break up do
not get the nurturing that they need from their
I parents, because the parents are too preoccupied
with their own emotional issues to nurture their
l' alienated children, These children usually become
ClOeena L. SlAcer, MA, July 1998 2
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emotionally empty, These children grow up
unemotional, plastic in their feelings, and unable
to share in an intimate way wi...., others. As
parents draw the children into the conflict, the
children deny their own needs in order to help
their wounded parents handle theirs. These
children miss out on the very thing each parent in
the fight, promises they are beller at giVing, their
nurturine and love,
Ab y conflict that the children are involved
in will harr.l children emotionally. Ideally, if
parents separate and their conflict ends, the
children will do better adjusting to the break up
than if the conflict continues for years. In these
cases however, conflict continues past the break
up. The children never get a chance to heal,
High conflict cases are trouble for the
court system. The family is usually in constant
litigation, the parents continue to fight and argue
ill front of the children, they emotionally suck the
children into the conflict through subtle and
blatant efforts. Often the courts helplessly make
stabs at stopping the conflict, which is driven by a
force of it's own. The children in this conflict are
forced to choose between loving and hating their
parents and siding with one parent over the other,
The child's ability to think for themselves, to
believe in their own worth becomes destroyed.
Children become involved by having to
choose sides, picking one parent over the other,
which they may do this just to keep peace and
stability in their lives, They may find themselves
having to care for a victimized parent or
wounded parent, because that parent is unable to
care for themselves. These children become
emotionally stunted in their ability to carry on
peer relationships and friendships with others,
because they have not learned to have normal
relationships with others. Their ability to bave
healthy adult relationships is seriously
jeopardized, Children who have been involved in
high conflict cases, as ehildren themselves, repeat
the same high conflict, emotionally driven cycle
in their own lives as adults.
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The /larents, who arc so focused on the
fighl, can 'I /lrotectlheir children, The conflict
which has an energy of Its own possesses the
parenls, Lltigarion bccomes a way of life. The
/larents gel emollonally charged up for the fight,
and generato llIore energy to keep the fight going,
They derive energy from the fight through
constlll1t cOntacl with altomeys,judges,
pSYChologists, IInd counselors who may actually
IUrt11er the gap bel ween the pare/lls, Counselors,
teachers III1d day care providers, family members
and friends are drawn into
the battle by being asked to
write declarations or
teslifY, Meanwhile, the
children become the
ViClims. They become
Inanimate objects to their parents, and are seen
Instead as weapons to jab and joust at the other
parent, They are the pieces of territory pare/lls
fight Over that declares who the winner of the war
Is,
The children caught in the conflicr, will
love their parents, with unconditional love, If they
are forced by coercion to take sides, they will
make choices to end the conflict, even if it means
they take sides with one parent against the other.
The parents have diffiCUltly understanding that
children love both parent, unless a choice must be
made by the child in order to surviVe emotionally,
Both pare/lls actually continue the conflict,
even if one parent is more fOcused on the fighr
than the other. One pare/ll may be more
aggravated, more angry and mare i/llent in the
conquest. One parent may be the instigator and the
other parent may be the responder, but both
pare/llS continue the conflict by their reactions to
the fight. They continue the fight, by filing COu"
actions, demanding Psychological evaluations,
requesting Supervised visitation, refusing to share
the children, or refusing to share information
about the children,
Conflict is alWays hannfulto the children,
because children do not have the words or
experience to describe what they are feeling, so
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Part I
rhey act out with aggression, depression, or
dcnial, The children experience all kinds of
problems because of the conflict, psychosomatic
and physical ailments stemming from the stress of
the conflict, behavioral difficulties at school and I
at home.
Parents are so preoccupied with the fight, I
they are unable to actually listen and hear what
their children tell them. Some parents, may have I
difficulty actually understanding that their child /.
has separate feelings from theirs. They may not
be able to undersrand that the children are hurting
in different Ways than they are. Some parents
actually Cannot separate themselves from their I
children, because tltey see their children as a
physiCal extension of themselves, not a separate
person with feelings, needs and dreams. These
childr,m have to fend for themselves.
Many children think they are responsible
for the break up. They also think they are
responsible for gelting their parents back together
again, It is a tremendous burden for children to I
carry, Children also magically believe that if they .
had cleaner rooms or were nicer to others, their
pru-ents may not have split up. They may think I
that if they were really sick, they could somehow
get their parents back together again. Many I
children become perfectionists, desperately trying I
to please everyone in their lives though unrealistic
expectations, by selling high standards for
themselves at school, for their Performance with
grades, in Sports, so they can prove that they are I
perfect enough to be laved by both. Their failure
at being perfect may actually send them into
temper tantrums, uncontrollable anger or severe I
depression.
Children also think that if their parents I
quit loving each other, they will quit loving too. .
They wony about being unloved. Because
parents are emotionally needy themselves, the
child does not get reassurance that this belief is
not true, Emotionally Wounded parents may
create unhealthy connections to their children.
Being enmeshed in a parent's life creates
unhealthy trawna for children, Children end up
3
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taking care of the wounded parent. The children
are told negative things about their other parent,
by a parent who doesn't see the child as separate
from themselves. The child has to learn to bow to
handle that information, and protect the wounded
, parent,
What children need the most frorn their
parents, is for the parents to end the conflict.
They need to be able to be removed from the
stress of the verbal exchanges and emotional
slugging that they are caught in the middle of,
One parent must admit that the fight has been
destructive and it can't continue if the children are
to have a chance at having normal adult
relationships.
That parent can do a few sirnple actions to
reduce the conflict immediately, The first step is
I to want to end the conflict. The second is to come
up ,'lith a creative way to exchange the children
away from each other. No face to face contact.
The parent who can suggest this and implement
this will immediately reap the rewards of this little
task. By ending any face to face contact, the
anxiety felt by the parent prior to and during the
exchanges will be lessened, By calming do"'n at
, least one parent, the parent can begin to think
again, they can come up with ways to reinforce
their love for their children. They can solve
cbildren's behavior problems, using the energy
that had been directed at the fight or flight
syndrome of the high conflict.
Part two has several powerful suggestions
that when followed will work to end the conflict
and build positive relationships that the children
desperately need from their parents.
CO.ena L, St..or, MA, July t998
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Some of this informatior. has been taken from:
ImDasses of Divorce (The Dynamics and
Resolution of Family Confli~t) by Janet R,
Johnston Ph.D, and Linda E. G. Campbell, 1988.
In the Name of the Child (A Developmental
Approach to Understanding and Helping children
of conflicted and Violent Divorce) by Janet R.
Johnston, Ph,D. & Vivienne Roseby, Ph, D. 1997.
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How to End the High Conflict!
If you are involved in a high conflict
child sharing relationship, there are some
actions you can immediately take to stop the
conflict. The fastest way to reduce the conflict
between both of you, is to stop any unnecessaJY
face to fa~'e or verbal cOllTact with the other
parent, This includes telephone and e.mail or
US. Mail. If one partner insists on leaving
messages or letters, have some friend listen to
them or read them first to decide if that
communication is necessary for
you to respond to,
Face to Face Contact
Every time you have face to face
contact or even a minor
interaction with your ex-partner,
your body goes through a high
anxiety stress state, which results
in the fight or flight experience
that comes when you are
suddenly attacked or frightened,
You may experience mild to severe anxiety, two
to three days prior to these exchanges or
interactions. (If this conflict has gone on for any
length of time, you may be unaware of how
stressful this is on you and your family. It takes
approximately 72 hours for your body to recover
from the stress attack, if you exchange children
again within that week, you body is constantly
in high anxiety stress state!
As you mentally prepare for what 'might
happen' at the next exchange, such as negative
verbal interactions or any form of physical
aggression or threats, and perhaps police
intervention; the negative anticipation over that
exchange is enough to send your body and mind
CCDeena 1. Stacer, MA
into the fight or flight stress cycle, two to three
days prior to the actual exchange.
Your children also experience this stress,
reading the stress from you and their own wony
about seeing their parents having words or
worse. The best way to exchange children is to
have the exchanges occur in a day care facility,
after school, or at one of the child's
extracurricular events, where one parent can
leave the child while the child participates in the
aC1ivity and the other parent comes to pick them
up. A minimum of one hour between the parent's
exchanges is recommended. This allows the
child to transition from one home to the other,
readying for that parent.
If your children are old enough to go
outside to the curb, the exchanges can occur in
front of the house, with one parent remaining
inside the doorway, while the other parent drives
up and honks, The children must be packed and
ready to go at the sound of the honk, There
should be no lingering, no discussion and no
messages exchanged between the parents.
Written Communication
Another helpful way to reduce the
conflict is to communicate with the other parent
in \'ITiting only, All communication with them
should be sent by fax, e-mail or U.S. Mail. Never
deliver anv communication face to face or
throueh the children.
Follow this rule for a minimum of two
years, and when the conflict has settled down,
you may be able to communicate face to face
again. In some cases, where, the conflict between
the parents will never be resolved, because of the
5
All rights reserved. June 1998
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,_. __ .---1
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By Deena L. Stnccr, MA
conflict bctwccn the couplcs, the best these
parents can anticipate, is that they co-exist as
individuals, sharing the same child but never co.
parenting or allending cvcnts togcthcr,
Child Sharing Schedules and Tips
All child sharing schcdules should be clearly
and specifically defined, with timE.'s, locations,
and designation as to whom the parent dropping
off or picking up will be, This eliminates
unnecessary comrnunication between the
parties.
A copy of the Team Works Parenting
Plnn is available for the parents to use as a way
to nail down all exchange times, dates and
locations, In high conflict situations, both
parents must stick to the child sharing plan
without any deviation, whatsoever, for that
minimum two.year period oftime, By keeping
this consistency, the parents have little to argue
over, because visits follow like clockwork and
the children knew when, where and who they
, will bc with every day. They need this
consistency. Changing schedules rnenns that one
parent has to comrnunicate with the other, and
the other can say 'yes' or 'no', creating conflict.
Plan on having the children attend only
the events that occur on your time, rather than
on the other parent's time, If your child has a
party for a friend, the parent who has the child
that weekend, is responsible for taking them to
the party. Infonnation about his party should be
sent via fax or e-mail so it is timely, Note like
this should say something such as, "Jamie has a
birthday party for Sherry on Saturday from 9-
Ila,m. Copy of invitation is enclosed,"
Emergencies
Emergencies are just that, emergencies,
Child sharing exchanges should only be altered
if the child or one parent is injured, severely ill
or an unavoidable catastrophe occurs. This
would be the only valid reason for verbal
communication, and it is very rare that this kind
of emergency would occur in families, so there
L Cl:lD,eena L. Stacer, MA
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Part 2
should be very little, if any verbal or face to face
contact between parents.
To keep the children out of the middle,
ncver, never, ncver exchange notes, letters, child
support checks, or any other communication to
the other parent via the children, Both parents
should never attend a child's doctor appointment
together, Open houses. sporting events, and extra
curricular activities should never be attended by
both parents at the same time, for that minimum
two-year period of time, Usually the parent who
has the child during that time should attend that
event. The parent who is not attending should
make alternative plans with the school or the
program to attend a dress rehearsal or practice
prior to that event. For example, a science fair
can be attended by one parent
during the school day rather then
in the evening.
Each parent should make
their own arrangements to attend
separate school conferences, one
parent can take the spring open
house the other the fall open house.
Since conflict can erupt, at just the sight
of the other parent, the parents should work on
every creative alternative they can think of to cut
the contact down to zero. Sometimes one parent
insists on breaking these rules, but the children
are the ones to suffer if this continues to occur.
CoUrt orders may be an alternative to assist the
parent who has difficulty with this concept.
Send self.addressed stamped envelopes to
your child's teacher requesting duplicate copies
of report cards, notices and pertinent
information. Schedule separate conferences and
meetings with your child's teachers to insure you
have all the information to help your child
succeed in school. By sending self.addressed
envelopes to coaches, and leaders requesting
copies of the practices, games, team roosters and
schedules of activities also solves
communication problems.
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It only takes one of the parents to end the¼conflict!
6
All rights reserved, JW1C 1998
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ny Deena L. Staeer, MA
To end the conflict, one of the parents
has to want the conflict to end. It is apparent to
professionals involved in high conflict cases,
who it is that is having difficulty letting go of
the relationship, The one who wants to keep the
contact going, is the one who is not willing to
stop the conflict.
Because children are permanently
scarred by the chronic conflict, the parent who
wants the cc l,'ict :0 end, should focus that
energy into dcing everything they can, to stop
the face to face contact and to reduce the verbal
communication between the parents, These two
efforts alone will reduce the conflict by
approximately 75% alrnost immediately, And by
b~coming confident in your relationship with
your children, you create special bonds with the
children, (see pan three of this anicle), and do
not have to continue reacting or responding out
of fear toward the other parent. As you create
special mernories with your children, and can
you quit reacting so ernotionally to the things
said and done by the other parent. This also
reduces the conflict,
In addition to these tips, parents should
find a professional to help them get over the
loss, hurt or anger that the conflict created. Even
if one of the parents has remarried or is with a
significant other, that parent rnay not have ended
the rnarriage, Just because one parent finds
someone new, doesn't mean that they have
ended that old relationship with their ex,
Resolving these old relationship issues can be
done once the anxiety and stress the conflict
created is reduced.
Find a friend who will help you write
only 'the facts' in written form, rather than any
unnecessary cornmunication to the other parent.
When anxiety is high for both parents, any
communication between parents is seen as a
threat or an attempt to control the other.
Numerous support groups are available
to assist with issues that may be part of the
break up conflict. Team Works offers free
bimonthly workshops with speakers and
educators, as well as family law attorneys who
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I roDeena 1. Stacer, MA
L.._u
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Part 2
assist by proving information on child sharing,
finances, and other related issues, Child
development experts, teachers, educators,
psychologists can assist parents tool Finding
resources that help to rnove parents on with their
new life is essential to protecting the children.
Team Works also offers the High
Conflict Intervention Program to assist parents
with ideas, and activities that reduce the conflict
and ways to create the special relationship with
the children.
If your case is extremely conflictUal, an
alternative to litigation may be to select a
"Parenting Coordinator" who CIil1 handle
disputes between the couple, Both parents must
stipulate to this Coordinator however. When
there is at least one parent who will not or cannot
end the conflict, the parenting coordinator
becornes the professional that provides
mediation, child development assistance, parent
education, legal counsel and recommendations
for special court orders.
By providing the children with a support
person or persons, the children ean learn what to
handle the conflict and their own losses that may
not have been addres"ed with the break up and
chronic conflict, High conflict cases center
around the theme of proving that "I'm right! And
You're wrongl" whether it is one parent reacting
to this fight or both of them trying to prove they
are right the other wrong. At all costs I must win,
means that the child loses at all costs. When one
parent recognizes that winning is not fighting,
then the children actually become the winners.
The children will have a chance to calm down
and enjoy their parents. Pan three has tips to help
you build the special relationship with your
children they need when the conflict ends. Your
child needs you to weave positive anticipation
into their lives making memories they will never
forget.
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7
All r~ghts res~rved. June ~~~~
1-- '- ..---..-- '-,
I Team Works High Conflict Intervention Program
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Creating Special Memories with Your Child
(Part Three)
'I Protecting the children from conflict is the fir<t
priority in any break up situation, Children may
I not be able to verbalize how they feel or even be
" able to identifY what they
are experiencing, but
children become
I emotionally scarred for the
i rest of their lives, if the
I chronic fighting, animosity,
and stress continue.
I Having a special
bond with your children is
I easy once the conflict dies down, Often the
I energy that was put into keeping the conflict
going or reaeting to the conflict, needs to be
I redirected into energy spend on inventing
I wonderful memories for both you and your
I children. When a break up occurs, parents often
feel sad about losing the family image, But
I family is what you make it, whether it is mom
I and child, dad and child or mom, dad and child,
Because a break up has OCCUlTed, the new family
for the child is now two families. Mom's family
and Dad's family.
As the conflict dies down because rhe
face to face contact and communication has been
reduced, the childrf'J1 will experience relief.
When parents calm down, their children calm
down.
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I QOeena L, Sl1Icer, MA
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A fast and fun way to build a nurturing
bond with your children is to create a positive
events you do together. When your child goes to
the other parent's home, they will have
something to look forward when they return with
you. By inventing activities that are simple and
PH '.-I ??'l-1.
8
easy to plan together, build "positive
anticipation" with each other,
The activity or event with the child CIlJ1 be
as simple as baking cookies together, Planning
this activity means that you and your child decide
what cookies you want to bake, Get out cook
books and before going to bed at night, pick out
the recipe you both can agree on. The following
morning, make a list together of all of the
ingredients that you need to buy. When your
child goes to the other parent's home, tell them
that you will be shopping for the ingredients
together, when they return.
This little part of this activity is a~lually a
big event to children, Being with mom or dad and
planning activities together, (activities that occur
over several days) are very important in tenns of
weaving positive memories in the child's life.
While they are with the other parent, they are
thinking about the shopping and baking time with
you.
When making the cookies, you can teach
them how to bake, have "alone time" together,
and talk about how much fun this is, Decorating
cookies and waiting for them to finish baking is
also part of the momentum that weaves the happy
memories in their lives.
Don't just eat the cookies, rnake a special
placemat for each of you, to use when you eat
your cookies. Get out special tableware. Color a
paper plate, or set out your finest china. No
matter what you decide, make this time also as
special as the other pans of this event.
Bake enough cookies to give some away. I
Call up a homeless shelter or a convalescent home I
and going together, deliver the cookies. While I
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All rights reserved, JUly, 1998,
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Augusto Jose Delenne
5973 Meade Court
Harrisburg,PA 17112
(717) 541-1790
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EDUCATION: ' I ;
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California School of Professional Psychology-Fresno. Fresno, ;arlifornia
Ph.D, Clinical Psychology - JW1e 1996 (A.P.A. Approv.~d) :
Towson State University, Towson, Maryland
MA Clinical Psychology - May 1987
Roosevelt university, Chicago. Illinois
Clinical Psychology - fall 1983
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Clarion University of Pennsylvania, Clarion, Pennsylvania
BS Psychology- May 1983
WORK EXPERIENCE:
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Sept. 1992 - Present Clinical Psvcholmdst (Licensed) I',
Pinnacle Health Psychological Associa'res! i
(Private Practice Group) HarrisburgPehoM....ania
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Specializing in work ",ith children/adolescents and their familil:s.; ~rovide
comprehern.ive mental health treatment modalities, which incl~del ihdividuallherapy,
family therapy, marital therapy, group therapy, drug and alcohol assessment and
treatment, and psychological assessments. Also provide coinDlunity. education and.
consultation, ; :
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July, 1995 - Present Clinical Director . '!
Pinnacle Health Psychological Associates: :'
(Private Practice Group) Harrisburg Pefm~Y1vania
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Responsible for administrative duties relevant to the functioning ~f:l/1e group'practice.
Provide clinical case supervision for clinicians. Provide yearl~ cv,aillations far all
clinicians. C".:tdinate services with other program directors wlthid Pinnacle Health
Behavioral Services. ! ;;
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Sept. 1992 - Oct. 97
PLAINTIFF'S
EXHIBIT
Clinical Psvcholoeist
Harrisburg Institute of Psychiatry
Adolescent Partial Hospital Program
Harrisburg Pennsylvania
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1I~25''18 l-n-J
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Provided intensive and comprehensive treatment modalities~ w~ich ~nclude inpividlia\
therapy and family therapy for a specific case\oad and a co-therapist in daily group
therapy for the entire milieu, Duties also includcd case manag~erjr. formulapon and
updating treatment plans and consultation, :' .:
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1991 - Augusl1992 Tntemshill (Psvchology Intern) A,P.A~ Approved
CPC Mental Health Services, Eatont~wn'INew Jersey
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Tndividual/Family therapy: Responsibilities included a minimJm ot/l2 hours of face 10
face contact per week with children, adolescents, adults, and f.lmilies,
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Group therapy: Participated as a Co-therapist in a socialization group' for Attention
Deficit Hyperactivity Disordered boys ages 9-11. Also participateyias a co-therapist in a
coed interpersonal group for adolescents ages 15-18, i' ,
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Assessments: Responsible for completing a minimum of 10 p!ychhlogical assessment.
Techniques included, intake interview, projective and objectiv~ IEls!fug, and collateral
contacts, , ,
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[(outh counseling Program: Responsibilities included; i i.
Intake evaluations: Refenals made by Probation officefs as a recOmniendation
from a pre-judicial conference, Families were seen .for!anie~aluation and a
written report sent to probation within a two-week peri'ld,'aS,~essi~g t1l.e
appropriateness for outpatient counseling, Collateral contaCts included probation,
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police and school officials, , 'i
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Full consultation: Following adjudication. and upon,reques~ from the judge, a
written report was provided regarding disposition recoQun~~tions. .
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Retention evaluation: Upon an adolescent's detention and lui:40n diret'trequest
from the judge, a clinical assessment was made to help ~eieri,nine whether or not a
youngster should be pennitled to :~turn home prior to li disp6sition h~g.
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Chemical Dependency Services: Responsibilities included a fo~-sci~sion evalUation of
adolescents and adults who had been referred by Probation Ofticets.i Treatment also
included individual and family therapy, i ' :
Community Alternatives Program: One day per week for four InO!ltl\s, Respqnsib1e for
crisis screening and evaluation of children and adolescents for 1'v10~outh CO!ll1ty.
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Consultation and education: Consultant for a headstan program. ' ,
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1990 - June 1991 Practicum (Psvc~olog-y T:ainee) AssessmenV,!nt~rve~t.ion
CSPP PsycholOgical Sel"Vlce Center, Fresnb; talifornla
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Assessment-Juvenile Probation: Responsible for PSYChOlogiCal! ass~~ents of court
ordered juvenile offenders. Techniques included, intake interviews, projective and
objective testing, i !
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~tervention-School Based: Responsible for providing group lherdJ'~'in the elementary
sch~ol setting for Childn;n in the kinderganen through the thir~!grilde. rndivi~ual an,d
famdy therapy was proVided when deemed necessary, Parents :groups were also offered.
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1989 - August 1990 Practicum CPsvcholor!V Trninee)lMen~&!ic3Ith Clinician
Adolcscent Day Treatment Program, rligh:lon, CaJifomia
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Case rnanllger, responsible for a cllSeload of6 seriously emotionallY. disturbed (SED)
adolescents. Responsibilities included individual therapy, fllrT\'ily;~brapy.'an~ daily
group therapy, Required to develop, implement, and maintainijndi~~dulll trelitrnent plans,
Assisted in developing a program wide behavior modificanon ~ystc!l.n.
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1985 - August 1985 Psvchiatric NursinR Counselor III (Adolescents)
Taylor Manor Hospital, Ellicott City, Maryland
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Responsible for direct nursing care and implementing activitie~ forldaily lIving of
adolescent patients. .Intervening safely in crisis situations and stabilIzing patient's
behaviors. Developed and coordinated unite rules. Required to maintain individual
treatrnent plans and assist with the coordination of unit rules t<j erlsu~e the continuity of a
therapeutic milieu, Responsible for developing and implementing behavior management
contracts, !
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1986 - May 1987 PracticumlInternshio i.
Spring Grove Hospital Center, Catons'lj'ille Maryland
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Responsible for intake evaluation, individual therapy and group tliet'ilPY with seriously
emotionally disturbed adults. !
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REFE~CES: !
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Fumisbedupon request.
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Hl/FlJtwIO. PA 1110t.!700;
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20S $<Nfl ~t$.,tSIUtt
1'!ln~IT3.'A 1110_.1696
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'I " Behavior al
I :;ervlces
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Gabrielle Stetz
OOB: 6/2~/93
Oates of EtJaluation: 11/2198 & 11/6198
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Reason fdr Referral:
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Gabrielle ~tetz was referred, by Paige Macdonald-Matthes, ~tt~me~ifor Gabrielle's
father, Michael stetz, The evaluation is to determine if there is anY: Indicatiori of child
abuse fro, Gabrielle's mother. Laura Mathews. ,I .' ':
History: !
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Attomey Paige Macdonald-Matthes reported that on 10/111/00 ~a~rliblle Stetz had called
her father.! Apparently, Mr. Stetz was not home and Gabrielle left: a message.
Apparently on the message Gabrielle was heard crying afte'~ what ~ounded as though
Ms, MatheWs hit Gabrielle, Ms, Mathews was overheard apbl~lzir;.g repeatedly to
Gabrielle, while asking Gabrielle if she was okay, AttomeY F'llge Macdonald-Matthes
did provide! a copy of the answering machine message which veriJie~ the abqve "
infonnation, Attorney Paige Macdonald-Matthes also explajh~ thai on 10/16/98
Gabrielle went to her grandparents who noticed a red mark ar~u~!Gabrielle's eye,
Reportedly, according to Gabrielle and her mother, the mar~ o~dtJr(t$<I at the daycare.
Reportedl~ on 10/16/98 the daycare did not notice the mark orj Gabrielle's eye, '
Supposedly the mark around the eye occurred on the slide at /t1eldaycare, thus the
concem regarding any possible physical abuse from Mr. Stetz:~nll ~is attomey.
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IntervIew With Laura Mathews. '
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Laura MatheWs was very cooperative throughout the interviElwproqess. She;provided
backgrountl infonnation, Ms, Mathews, age 33, is currently ~~para~d from her third
husband Michael Stetz age 39. They have been separeted si~cel Q~cember 1997. Mr.
Stetz currently lives in San Diego, California. Ms. Mathews reJllorled that she would
have one year of sobriety on 11/17/98. She is reportedly Involyed iriher own' outpatient
therapy and is actively involved in AA. i
Ms, Mathews mentioned that Gabrielle talks almost daily tOlh~faUler on the telephone
a.nd she wants to foster a positive relationship between Gabrie Ie an~ her father. Ms,
Mathews believes that Gabrielle and her father have a very p itive:relationship. Ms.
Mathews described Gabrielle as bright, a handful, fun, listens wsli, lilnd an easy child,
Ms. Mathews described herself as less of a playmate with Gb~riell~J but more of a
teacher, She likes to teach Gabrielle about her colors, letters.:flniJ i1ature: For
discipline, Ms, Mathews reported using time out especially whan Gabrielle; doesn't listen
or is aggressive with the cat. Ms, Mathews admitted to losing 6er te\;nper on the evening
of 10/14/98. Ms, Mathews reported feeling tired and upset. A~pare~t1y Gabrielle was
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PLAINTIFF'S
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11-ZS:~6 l..FH'
Gabrielle Stetz
Page 2
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pushing the limits and was not cooperating, According to ~s.l M~ttiews, she!. "back
handed Gabrielle on the chest." She later mentioned that 1t\~"'S more like a'push on the
chest. Ms, Mathews stressed that she tries to choose her.baUfes ~ith Gabrielle and
does not ge,t angry with Gabrielle very often, When question~d'~~9ut a potential
parenting :class or parenting issues in I '! I
therapy, Ms, Mathews stated that she believes she interacts well with children and that
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her parenting is fine, I
Ms, Mathews explained the bruising around Gabrielle's ey~, pn!Fryday 1,0/1SI98, Ms
Mathews picked Gabrielle up from daycare. Ms Mathews app'aren~y noticed a red area
above Ga.brielle's eye, When She and Gabrielle arrived In B~tir\lo(e at Gabrielle's
grandparents, Ms, Mathews noticed the red area above Gabrlele's!eye began to reveal
bruising, Gabrielle apparently told her mother what happened injff6nt of her'
grandparents. Gabrielle explained that she hit her head on th~ Silide at daycare,
Ms, Mathews was seen briefly for the second session, She Jas iinformed about what
appeared:to be Gabrielle's guardedness and defensiveness, ~spe~aIlY about the events
occurring on 10/14/98'- Ms: Mathews was asked for suggestiqns! qn what might allow '
Gabrielle to recall or discuss the evening, One option was'to ;pla><t!1e tape of the
message, but it was stressed to Ms. Mathews that this wasnQt a' preferred ol:>tion, Ms, .
Mathews did provide more details about the evening, which pfovbcl,to be very helpful.
Ms, Mathews was not aware of the bruises above Gabrielle's left! Knee. However, she
was aware the Gabrielle had fallen while trick or treating. i
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Interviews with Gabrielle !
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Gabrielle was very neatly dressed and appeared to be hef'st~ed ~ge of 5. She
expressed a bright affect and cheerful mood throughout the irfe!rViews. Gabrielle was
rather cooperative, However, on occasion, she appeared ~of\l#t1at guarded, Gabrielle
began by writing her name, She noticed the Sorry game ar\d'ch~eltully talked about
playing games with her father, Apparently Gabrielle's father taught;her to play the game
Sorry and, she wanted to play, The games of Sorry and ConnectiF.9urwere played to
help establish a positive rapport, While playing the game sevbral ~ruises were noticed
on Gabrielle's left leg just above the knee about the sizes of ~ nickel and a dime, as well
as a red area above and around the knee, Gabrielle stated t, ,at the bruises might have
occurred on the playground, but wasn't sure. Gabrielle was very clbar about the red
mark on her knee as occurring while trick or treating. Gabriell~ apparently fell while trick
or treating. ;
Many of the questions posed to Gabrielle were asked regardilg ~61h parents, For
example Gabrielle was asked what she likes doing best with Jach 'liarent. She
responded, "I like playing games with dad best" and "I like i::uddll\19iwith mom best."
When asked about her parents being separated, Gabrielie'm~ritioried "mom and dad
don't really get along togelher." She does wish for her parent-Ito get back'together.
Gabrielle admitted to getting mad at her mother, but didn't renl1ember when qr what
about. She denied getting mad at her father. Ii.
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Gabrielle Stetz
Page 3
Gabrielle denied that her father has ever hit her when he was "n9,y. She dl~ admit that
her mother has hit her on the bullocks when angry "but she . Ii'.t dp It,an,y more.'
Gabrielle didn't recall being hit by her mother on 10/14/98, ev n after being lold that her
mother explained how she hit her, However, she did recall tHe'injury around the eye,
which supposedly occurred on 10/16/98. Gabrielle mentioned th~t ~he was ,walking up I
the slide and slipped on the way up, She stressed that her headl hit the part iof the slide
where your hands go when sliding down, She also emphasiz~~ the position'of her head
while on the slide. ! '
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For the second session, Gabrielle began by playing with the ~ohJiloose, and tf1en playing I
a charades game, After the game Gabrielle agreed to anSWer questions. She was
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asked about the message she left herfather on 10/14/98 andl'~e eYents that followed,
Initially Gabrielle didn't recall anything happening, She was tl/ell a$ked about being on
the sofa and pulling her mothers hair, Gabrielle stated "I thjn~ lremember Vtiatchlng t.v,
and J was trying to take mommy's pony tail out and mommy gpt.maf:J: Gabrielle was
asked what happened next. She stated "'think she hit me," Gabrielle slated that she
Wasn't sure where her mother hit her, Gabrielle was asked inla silly manner!if her
mother hit her on the big loe and Gabrielle stated "no, she hit me there (placing her hand,
on her chest)." Gabrielle denied being hit anywhere else, G~br.iene was questioned
about her mother being angry in the past and hilling her, and j3abri~lIe, stated "I think 2
or 3 times." When asked where her mother hit her, Gabrielle /;ta/e~ "' think r;ight here
(touching her buttocks) and it hurt and I cried." Gabrielle waslalso asked which parent
gets mad the easiest, and her response was 'mommy, now rrjommy puts me in time out
when she gets mad." Gabrielle was asked, if her father everbe~a?1e angry, and hit her
like her mother and she stated "I think he would never hit rhe,1 Gabrielle was asked
about the bruise around her eye. She clearly explained thaI she was going i:lp the slide
at her daycare, her foot slipped, and her head hit the side of tTe slide where -your hands
go. Again Gabrielle emphasized the position of her head. FInally; Gabrielle stated that
she would tell her mother if her father would ever hit or hurt h~rand she would tell her
father if her mother ever hit or hurt her, I
Summary i
Ms, Mathews and Gabrielle Stetz participated wellthrou9houtl1he i~terviewsi which
Occurred on two separate days. Gabrielle was very active a~'d i'nt'i'lIectuall~ appears to
be bright. Throughout the first interview with Gabrielle, she a -"eared somewhat
guarded regarding questions concerning her mother, For exa. pIe: Gabrielle was not
able to recall any of the events on the evening of 10/14/98, e , nafter being laId that her
mother infonned me that she had hit Gabrielle, Also Gabriell :s re~pol)se atlout her
mother hitting her on the buttocks and staling "but she won't qo it any n,ore" ~eems as
though this was recently emphasized to Gabrielle, Gabrielle'/; explanation of hitting her
head on the slide was explained very clearly and appeared to/be'legilimate. :However,
during this explanation, Gabriel/e's repeated emphasis on the positibn of her' head
seemed unusual, because of how she went out of her way to demonstrate t~e position of
her head on the slide several times, This may indicate coaching, but npt de nitively, nor
Is there any indication of who may have done the coaching. [Gabrielle isve aware of
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her mother's anger, which ~uggests that Ms, Malhews mJy bi~ori:J aLry" Ilh Ga rlel/e
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There were some conlradi~tions in Ihe statements of Ms. ~at ,~~ Ilndescri Ing i
Gabrielle. She ~escribed Gabriel/e as a handful, and she tri~s'to;~~'cklherb. Itlesiil'"
Gabrielle so she' doesn't b~come angry often, versus an easYlfun;' i1~ Whb~isten viell.
This suggesls that Ms. Mathews may be experiencing a signilcanl. vel of Is ress aling
wilh Gabril!'lIe's behaviors, Which is nol all Ihat unusual for a S ngl~. Wariml. ,: owev~ri
when questioned about her. parenHng, Ms Malhews appeared to ~~ortre 'sb ewhat.
defensive and denied havirlg any difficulty parenting. It would be iI?detsla~ able fOr a
parenl to minimize difficulties under lhese (evalualion) ci;cump'lanc:~s. :ThEifore i
important question is whetHer or nol Ms. Mathews minimizes ~he t~~sic!ns a d em~onal
demands of parenting to h~elf. To do this might contribute tb ong~in~ pro lem wllh
temper control., . Iii;:. i
In response to th~ reason fbr referral, there is nol a clear ihdi~~iOd \o~ this evalU~lion
that Gabrielle has been th~lviclim. of ph.y~ical ab~e perpelralt'l b~ ~ mp~h r.. Msl
Mathews. Ms. Mathews d,(J admit 10 hitting Gabnelle on Ihe G~est ,n he:ev ntng Of
10/14/98. However, Ihere is no dear indication that the briJise'ab ';. abri~ Ie's e~e
was a result of any interaction with Ms. Mathews. Based ~n tre i~ @mtiilioh gleaned
from the interviews. it seem~ likely thallhe bruise above Gab1elle'~!ey~: m~y have:
occunred on the slide at Iheldaycare. However, as stated above, I~~re lappe red tol be
some form of coaching based on Gabrielle's emphasis on the Position ~f lier head, j
As a result.ofMs, Mathews poor impUlse control on the eveni~ in:WhiJh sn~hil I
Gabrielle on the chest and Gabrielle's awareness of Ms. Math~s ~fugdr, It i ,
recommended lh~t Ms. Mathews participate in skilled parentinp.~rairilng or 0 tain th~
skilled parenting in family therapy. It is recommended llYatiM~I. MatHeWs ar1.dIGabri~IIe
participate in family therapy/to allow the parenting issues to b9'adqr~sS~d!an~ for :
Gabrielle to establish a pOSitive rapport with a therapist This could pOlentiallV provipe
Gabrielle and her mother wiih a safe ou~et to address any :typipaJ p.~rerlt dlhd conflipls
or more serious conflicts (i.e!. Ms. Mathews' anger and impuls~ conliol)) ! i
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It is also recommended that:Gabrielle's parents not be gi;>'an ajhard ~op.Y Of!t~e !
evaluation and be! instructed. to ndt discuss this evaluation.Withl~ail1.ellli~ Th~'S is I
recommended because an clngry or defensive parent may quefliorl' Or gonYrb t Gabpalle
a~out her responses. T.his rj-lay Iliad to ~ab,;elle becomin~ m~r.e d~enJ;iv~:' r m,lkipg il
difficult to develop trust In a future'theraplst. ' I ;1:.' I I
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i Licensqd qiinic;ill/ P yc~blogist
Clinica~ Direi::to~ I' 'J'
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Gabrielle Stetz
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lO:24A psychiatric Assoc/Cgnt PA
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SfIV - II/lIP
ShBWDB S. Brent, M.D.
5012 Kylock Road
Mechl1/llcsburg, PA 17055
Work: (717) 730-8555 Home: (7\7) 795-5445
DEPENDANTS
BXllIlrrNoJ
1l71!f:~~;'fi
PRACTICE EXPERiENCE
PS\'CHIATRIC ASC,OClATES OF CENTRAL fA
Providing psychiatric services to children, adolescents,
l1/ld adults. August 1998-present
Lemoyne. P A
EDUCATION
ALLEGHENY UNIVERSITY HOSPITAL Philadelphia, PA
Eutern Pennsylvania PRychiatric Institute
postgraduate Year 5, July 1997-June 1998.
UNIVERSITY HOSPITALS OF CLEVELAND Ch::veJand. OR
Division of Child and Adolescent psycbiatry
Chief Rc:sident. July 1996- June 1997.
postgraduate Years 3 l!l. 4, July 1995 - June 1997.
Department of Psychiatry
postgraduate Years 1 & 2, July 1993. June 1995.
TEMPLE UNIVERSITY SCHOOL OF MEDICINE Philadelphia, PA
Doctor of Medicine. May 1993.
UNIVERSITY OF DELAWARE Newark. OF.
Bachelor of Arts. May 1989.
Major: Life and Health Sciences Minor: Psyehulogy
Honors: Summa Cum Laude Graduate
Phi Bcta Kappa
Mortar Board
Dean's Award for Outstanding Student in Life Health Sciences Department
TEACHING AND PROJECTS
MIND COMMll'TEE, Case Western Reserve University School of Medicine
Group Leader for second year medical students. January 1996 &. January 1997.
Clinical Interview Preceptor for secund year medical students, January 1995.
LECTURES & PRESENTATIOMS
Psychopharmacology of ADHD. The Guidancc Ccntcrs. Cleveland. OH, May 1996.
Emergency Evaluation of Adolescents, University Hospitals of Cleveland, Clevcland. Oil
July 1996.
Introduction to Psychupharmacology, The Guidancc Centers, Cleveland. OH. September
1996,
Treatment with Antip~ychl)tic Medication, The GuidllOce Centers, Cleveland, OH,
September 1996.
Borderline Personality Di~order. The Guidance Center~, Clcveland, OH. September 1996.
Conduct Disordcr Treatment Strategies, The Jones Home, Clcveland, OK, October 1996.
psychiatric EvalulUions in Juvenile Court, Sponsured by The Ohio Supreme Court
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Nov-12-9B lO:24A psychiatric Assoc/Cgnt PA
P.02
Judicial Collcge, Columbus, OH, November 19'16.
Munaglng with Managcd Care: Educating and Credentlallng Psychlntrlc Residenu as
Health Maint~nance Organization Providers, American Association of nir~'Clors of
psychiatric RllSidency Directors, Charleston, SC, January 1997.
Bad To The Bone? A comparison oflWO clinical ClUes, University Ilospltals ofCI~v~land.
Depanmenl of Psychiatry Orand Rounds, Cleveland, OH. February, 1997.
The EllcctlvenllSs of the Public Acadcmie Liaison Psychiatry Program. presented at the
All Ohio Community Psyehialr)' Meeting. Cleveland, OH, March, 1995.
CLINICAL INTERVIEWING, Case Western University School of Medicine
Introductory Interviewing Skills for first year medical students, July 1995- June 1997.
PEER REVIEW Ayd. F J, The Lex/con of Psych/at">,, Neurology, and the Neum.lcl~ncc 2'"
wit ion. in press.
COMMITTEE OF PSYCHIATRIC RESIDENCY EDUCATION, University
Hospitals 0 r Cleveland, 1994.1997.
INTERESTS
Distance running. biking, skiing. traveling. playing flute, and n'Il1dern an
SOCIETY MEMBERSHIPS
ACADEMY OF CHILD AND ADOLESCENT PSYCHIATRY July 1995-prescnl.
AMERICAN PSYCHIATRIC ASSOCIATION July 1995-present.
OHIO PSYCHIATRIC ASSOCIATION July 1995 -June 1997.
ChUd & Adolescent Committee, Resident representative, July 1995 - June 1997.
PENNSYLVANIA PSYCHIATRIC ASSOCIATION July 1997- present.
I
FILED-OmCE
CF THi: pi-'r'THONOTAlW
93 nCT 26 Pilll: Ii 2
CU:';;~;~Fij';\;) COU:~iY
PEMiSYLVMii,\
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Paige Macdonald-Matthes, Esquire
For the Plaintiff/Petitioner
Barbara Sumple-Sullivan, Esquire
For the Defendant/Respondent
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 98-1104
MICHAEL STETZ,
Plaintiff/Petitioner
LAURA M. STETZ,
Defendant/Respondent
CIVIL ACTION - Custody
ORDER
AND NOW, this
day of October, 1998 upon
consideration of the Emergency petition for Custody which is
annexed hereto it is hereby
ORDERED that Emergency Petition for custody is hereby
GRANTED and the Petitioner shall be awarded sole custody of
Gabrielle stetz, age 5 years, DOB August 25, 1994, until such
time that Respondent undergoes a psychological evaluation, and
successfully completes an intensive therapy program and the
results of said evaluation and program can be reviewed by this
Court.
IT IS FURTHER ORDERED, that the child shall immediately
be placed with her paternal grandparents until Petitioner can
arrive in Cumberland county, pennsylvania, which arrival shall
be within forty-eight (48) hours after the entry of this
Order.
BY THE COURT:
J.
(I( 1-1';1'-1"1' I;: 1.1:, 'I
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IN 'I'IIE COUi{'J' el\o' COMMON l'LI;At\
(:lJMnr.RLANll COIINTY, f>r.NNSYLVAN LA
v.
Ill). !lll-n 11.\
LAIIHA M. ~;'I'F.'I'Z,
llof'nnd.1nt/Hr,o"IH,"dnnt
Cl V 1 L, AC'I" ON - Cu:;t.orly
EM~nGENpy PFoTIYION FOR cpaTODX
I\ND NOW, ""11Im: the Pl(lint.lCf'\Pctitionel", MidH,nl Stet?,
by <me! thrClllqh his counsal. cunninghnrn (Inti C:twrnico/:'t, I'.C.
Mld l'i Ie:; hiB F:llIl1rqency Peti U on 1'0'" Custody and in support
thereof avnr' il!i follows:
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rJ1he
Plctintiff\Petitionur
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Mi Chtlel
~.i tot?
(hnreinnttr,or "I'Iltitioner") (In ;1cllllt individual ""n"nntly
resldlnq at 2'167-1/2 C~ltalin"i BOtJJl~Vr)rd, Si.ln DinlJo, Bc"Jn Diego
county, Cnlifornia g2107.
2 "
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st:nl.z
Defondilllt \Ilespondcnt.
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M.
(hllr011lo1fter Respr.lnclllllt"), residinrJ at :lpj Fif'th Avent"",
I3llcOIH) Floor, New CumbC!rliltllJ, Cumberl(lnd CClllllty, P'1nnsylv(lnia
17070.
J. 'J'ho pilrties tin" t.ho natural p"rr~nt.:; of' onc. minor:
chiJcl, G.lbrieJ.le Stet.:'., "qn !> ycnrs:, DOU AlIlj\l!.:t ~~, 1994.
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4. On August 21, 199B, after a two day custody trial,
an Order of Court was entered by the Honorable Edward E. Guido
at the docket number set forth hereinabove. Pursuant to the
Order, the Respondent was granted primary physical custody of
the parties' minor child and Petitioner was granted partial
physical custody for purposes of visitation. A true and
correct copy of the August 21, 199B Order is attached hereto
and is marked as Exhibit nAn.
5. The court, recognizing that Respondent has a serious
alcohol addiction problem and that Respondent is in need of
dual diagnoses therapy, Ordc~ed the Respondent into therapy
and further directed that Respondent was to remain in therapy
until successfully released.
6. Petitioner believes and therefore avers that
Respondent's personal psychological problems are having a
negative effect on the child. Specifically, Petitioner
believes and therefore avers that Respondent is taking her
personal frustrations out on the minor child in the form of
physical and verbal abuse. Evidence of this abuse is as
follows:
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about the bruise, Respondent offered the explanation that the
bruise occurred at day care.
6. Petitioner believes and therefore avers that
Respondent, despite needing psychological help, and despite
the fact she was Ordered by the Court to obtain such help,
waited until almost one (1) month after the August 1998
hearing dates to get an appointment with a dual diagnoses
therapist, as is evidenced by her counsel's letter to
Petitioner's counsel dated September 25, 1998, the relevant
portion of which is attached hereto and is marked as Exhibit
"B".
7. Petitioner believes and therefore avers that
Respondent is not committed to obtaining the psychological
help that she needs, in light of the fact that she has
complained about the costs of such treatment, both directly to
petitioner and through her counsel, (~, Exhibit "8"), and
has told Petitioner that "she does not need to be in dual
diagnoses therapy," the Court's Order directing her into such
therapy is "bull s--t," and that "Dr. Shienvold did not know
what he was taking about when he recommended that [she] needed
dual diagnoses therapy."
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B. Petitioner believes that Gabrielle may be in real
danger from further ha~m from the Respondent as a result of
the fact the Respondent unleashes her personal frustrations in
the form of physical abuse of Gabrielle.
9. Peti tioner believes and therefore avers that an
Emergency Order granting him sole cus't:ody of the minor child
until Respondent undergoes a psychological evaluation, and
completes an intensive therapy program is necessary in order
to safe guard Gabrielle from any further harm.
10. The best interests of the child demand that this
Honorable Court intervene on her behalf and take the necessary
steps to protect Gabrielle from possible further harm at the
hand of Respondent.
WHEREFORE, Plaintiff\Petitioner, Michael stetz
respectfully requests that this Honorable Court grant this
Emergency Petition and immediately place the child into the
temporary custody of the child's paternal grandparents until
Petitioner can arrive in Cumberland County, Pennsylvania and
then up::n his arrival, award Petitioner primary physical
custody of Gabrielle stetz until such time that Respondent
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undergoes a psychological evaluation, and completes an
intensive therapy program, and the Court is provided with
satisfactory proof of Respondent I s program completion, and
further award Petitioner all such other relief as is proper
and just.
Respectfully sUbmitted,
CUNNINGHAM & CHERNICOfF, P.C
Date: October 19, 1998
By ~ ;,; '\e. \'oo.v."Al-.--o.o.d- l\~,,'N1o&1'1
Paige IlIacdonald-Matthes, Esq.
Attorney ID# 66266
2320 North Second Street
P.O. Box 60457
Harrisburg, PA 17106
(717) 238-6570
(Attorneys for Petitioner)
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EXHIBIT "A"
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MICHAEL STETZ,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
V.
LAURA M. STETZ,
Defendant NO. 98-1104 CIVIL TERM
IN RE: CUSTODY
ORDER OF COURT
AND NOW, this 21st day of August, 1998, after
hearing, the Court makes the following order:
1. The parties shall have shared legal custody of the
child, Gabrielle Stetz, born 8/25/94.
follows:
2. Mother shall have primary physical custody.
J. Father shall have partial physical custody as
a. From today at 5:00 p.m. until he returns to
San Diego or August 28th, 1998, whichever is sooner.
b. Each year at Christmas from December 22nd
until December 29th if visitation is to be exercised in San
Diego. From Christmas Day at noon until January 1st at noon if
visitation is to be exercised in Pennsylvania or Maryland.
If visitation is exercised in San Diego, father shall
send mother a round trip plane ticket for child at least thirty
days before commencement of visitation. The costs of
transporting the child at Christmas shall be borne by father.
c. Each summer from the Saturday after school
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ends until one week before school begins. The costs of
transporting the child for summer visitation shall be borne by
mother.
d. Anytime father is in the area he may visit
with the child upon appropriate notice to mother for as long as
he is in the area.
e. At such other times as the parties agree.
4. Father's parents may visit with the child on the
first and third weekend of each month from Saturday at 9:00 a.m.
until sunday at 5:00 p.m. if they so desire. At least seven
days notice shall be given to mother if they desire to exercise
any such visitation.
5. Mother shall begin counseling with a therapist who
is competent to handle dual diagnoses problems. Any therapist
chosen by mother shall be approved by Dr. Shienvold, said
approval to be forwarded to the Court and father's counsel.
Mother shall remain in said therapy until successfully released.
Mother shall not drink any alcoholic beverages
whatsoever. A violation of the conditions set forth herein
shall be deemed a change in circumstances justifying another
hearing before this Court.
6. Mother shall provide father with all report cards
and other school progress reports. Mother shall advise paternal
grandparents of all school activities.
7. Each parent shall continue and encourage frequent
and liberal contact with the non-custodial parent.
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8. This court shall retain jurisdiction.
By
Edward E. Guido, J.
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Paige Macdonald-Matthes, Esquire
For the Plaintiff
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aarbara Sumple-Sullivan, Esquire
For, the Defendant
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nl!E C0P'f FROM RECORD
In i :rot r. -., :, ~:^f, I h~re U~:~ set my hand
and :IIJ ~.c:i o~ SJ.cl Court at Carlisle, Pa.
This ......(.:~.... day of...~.:., 19.5:.r.,
\I. . n r, -{?, _..
UIIU1t11111'1~d'I\~6-"~'l->.:............u'''''''''''''_-
. ~M' Prothonotary
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EXUIOIT "0"
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MICHAEL STETZ,
plaintiff/petitioner
:IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 98-1104
v.
LAURA M. STETZ,
Defendant/Respondent
:CIVIL ACTION - custody
VERIFICATION
COMMONWEALTH OF PENNSYLVANIA
55:
COUNTY OF DAUPHIN
I, paige Macdonald-Matthes, Esquire, being duly sworn
according to law, deposes and says that she is the attorney
for Plaintiff in the within action; that the Plaintiff cannot
, .
make verification to this Emergency Petition for custody
because Plaintiff cannot timely come to Harrisburg to sign
this Verification; that the Plaintiff cannot travel to
Harrisburg, Pennsylvania to execute this verification prior to
the filing of this Emergency Petition for custody; and that
the facts set forth in the foregoing Emergency Petition for
custody are true and correct to the best of her knowledge,
information and belief.
~-'- ~ I'-~~"~~ -J;w,.1:tt.uJ
Paige Macdonald-Matthes, Esquire
SWORN and Subscribed to
before me this !q day
o~ctober, 1998.
l JI!.Au.,l... Q I)^r'-. b;-t-'--.
f NOTARY PUBLIC
..:1.-,---
NOlanal Sual
Blanche. A. Morrison. Notary Public
Harrisburg. Dauphin County
My ConHlllsslon ElCplres Nov. O. 2001
em ar, ennsy vr!nla ssoc a Jon 0 0 ., u
Nnv II.t-Jli ()~.':hlll' 11'..yC"llldl.'" I\.....tll ",'I f'1I1 P/\
--- --- -----
~'" I'SYCHIATIUC: ,\SSO< 'I Al'I':S OF CEN'/'/{AI. I'I':NNSYLVANIA
/.....J';~ 1...."I,lI'K f','MlloI',I,..\tlou'ORIClI,ulI ",''''', '\h"'I" Sm""
1'0111 A. CUIIII. M.D,
Curlll A, Ho,)', M.S.W.
Hieh.." ,I. FOIII.. ,\l.ll.
Smull I.. (;lII"\,/I1.s.. ('AAI'
Un.'IIII.. M.IIJ:lljrc~. ,Ih.".
Shll\\'lI.11 S. nl'e"II. .'1.fJ.
rhj\~, \\'illiullI\. n.n.
NovclII!>el' 10. I'/'IX
Ifullora!>'" Judgc Edward (iuido
CllIlIherland ('nIllHy COIIIl
Cuurlhousc S'lu:lrc'
C'arlisk. 1',\ 1'1Il I J
RE; Slelz v. Slel/.
Ii; 911.II04 Civil
Dear Jud~.e (iuido. '
Today. 1,'o'lIa",.'d YOur oflj(;l' 10 dlS<""s 111) pllrli"'l'alion ill Ircallll).: .'.1.' I.aura MUlhl'\V~
(Mrs. SIt~I/). I'el' Ihe dill'Clion OIYUIII ollice 'Iufr'll"",her, SUlldy, I I'rovid.. Ihe I,ll III win!;
infhrrtlnlinll to you.
Ms. Malh,'ws inilialcd IherHflY 'vith nw on Sepl"lIlher ~I). I<J'IH As IlIorll1."ly do wilh
clicnl~ who me separulcd and/ol' sharing ellslod)' llllheil' <:1';1<.1"':11, I inliJl'rucd II-b. Malhews Ihal
I donol panieiflalc ill ellslody procecdillgs in allY ma'llIcr. I II<I\'c Ihis p,'licy du,. to Ihc sewl',.
illlflaCI e01l1l I'efloning has onlh" qualily ol'thcrllp)'. III lilY experience. I"'/x.lrting tu Ihe C01lJ1
signi1i,~alllly diminish,'s Ihe Ih''fap''Ulic a/JiulI,'e .,od Ihc COlldU"1 alld Olllcum" ,'I'llwrap)'. t\b.
Malhew, ulldel'stuod this polk)'. agl"'ed 10 II, alld Ill:galllreUIII1l'nt w;lh '"l'.
GiWlllhe rc"elll eWllls wllh this "willy alld Ihe Cllun 111''''''eI1l;'"I. I l"1II IH' fling,.,
providc theraflY In Ms. Math,'\Vs, "iv,'n Ihe ","n'"1d,. "r CIIII/ll1rd"fl'U I'elll"tin,' I h'1\'" disell",,'d
Ihi.' with h,.1' and. wilh her ellnSl..'nl. h"vl..' """lIgl..'d li,1' ,\h Malh,'w, III hcginlhl'l'<lJ!) '.efl'".".,
with rny eolleat!ue. Shnwlla IIrl..'nl. M.I l. I Jr. /ll'cnl is aW<l'C or II,., dcm"nd, IIrlh.... "lIl1l'l ordcr. I
w.mh'd IlIl1l"ke you "war" Ihllll1l~' Wilhdrllwalli'lIm Ill<' Il'ealrll,'nlllUvls. Malhcws has ""thint:
In do wilh al1ylhinp, Ihllt has lIeellrrcd dnring lIlIr work I"gel/Wr. II is ',inlflly 1I11I1nl"rtlll1<ltc
I'olln\\'-lIp 10 0111' awel..'I1"'nl :lIlhe OlUsel ol'lre"II1l<'III fill' II". ",asllns I have hSII..'d.
Thllnk you lill )'our lillle and allel1lilll1.
~
rf~
Sincerely.
';~"'<'C.lI't/l..,'y.h,I<.(().I.( JAJ. (1/1(/
Susan l.. (iilius. M.S.. ("\1\1"
I in.'lIs-.'d P.'\ychClI(lJ.',I~1
W 1';I'I"rll Illl.. Still" lOt. l.en"')'III'. I'A 17114.1 (717)7:lIl.HSS~. (717) 7.10 456(, (FAXI
I . , (I~'
rbI)'
NEW INSIGHTS
MAIN OFHCE: IlEAIl 320 BHlDGE STIlEET
NEW CUMBEHlJ\ND, I'A 17070
717-77~.2535 FAX: 717-77~-7903
707 LOUCJ{S 1l0AD
YOHl<. I'A 17~0~
7r.7'8~5.2079
F/IX: 717.85~.2298
8 SOUTH HANOVEIl ST.
CAHUSLE,I'A 17013
717.2~9'7980
August 18, 1998
Barbara Sullivan
549 Bridge Street
New Cwnberland. PA 17070
Dear Barbam,
I have been retained by Lawn Matthews, who I interviewed for 2 hours on August 13 using psyeho.social
history. to assess her current status of recovery from alcohol dependency.
Matthews presents with a 15 year history of alcohol usage. Ms. Matthews reports that her drinking became
out of control when she was age 30. Ms. Matthews reports that between age 30 and 32 her use increased to
5 to 7 glasses of beer or wine daily.
)
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,
Ms. Matthews also reports UlOt it was during Uus time that she was experiencing marital problems .In June
of 1997 Ms. Matthews referred herself into a Drug & Alcohol program sponsored by Hershey Medical.
Ms. Matthews reports sobriely between June of 1997 and September of 1997. In early September Mr.
Matthews' husband asked her to move out to which she did comply. Ms. Matthews, had, in September.
two I night relapses which she slates, one ofwluch she became intoxicated. During this period her
husband accepted a job in California, Ms. MatUlCws moved back into the house in mid September to
prepare the house 10 go on Ule market. Also during this time Ms. Matthews was .uso responsible for care of
daughter.
1
,
Mr. Matthews len for Califonua in mid October, Ms. Matthews was len with the rc;ponsibilities of the
financial management ofhollse. child care and orientation into new job position which involved a10t of
commuting. Ms. Matthews dropped Ollt of the lOP progrwn bUI continued involvement in AA and
abstinence from alcohol.
.~~.
] .
! I
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Ms. Matthews reports last use of alcohol being in November of 1997. This being one glass ofwine.
Between that time and present Ms. Matthews had continued to develop a support system in AA including a
sponsor who has 10 years clean and sober. In addition to her quest for recovery she had yet anoUler
promotion at work, showed and sold the joinUy owned home and moved belonging s 10 New Cwnberland
and is selVed with separation notice and sued for custody ofUle daughter she IIOS been responsible for since
September of 1997.
,
f
ComprellCmslue Serulces for Mental Health and Chemical Dependen
\t
i\
DL'dI" LaurH:
I'i 1':'; t 0 I' ill I. Ie I '"" :.;;,1'.
iIlIl ~,;O r rv.
illll writing this letlc'r ,\lU'r t!le IIcd;end 1'1'<"" he'll. whc'n
\\It' hall thu~;l.: I.t:rrll)Jc :":Ull\'\~l'.""."lt iun~, 011 thl.~ "lione.
r 1!U(..'S~ all III IIlV worst fears - thl' possibility of 1()~il1,!!
you anti Uahricl IL: - crupllJd. WCl:kl'l1ds art..' loul!lJ hert.- for lIIe.
I tr~' to Let'p bu.";.\'. hill int'\'itnhl\', tIH:l't: ill'C down t.illlt.!s und
I !.:.l~ I i\ll:-: i \H1.~~ nnd \\Cl ( r I L~tl,
Thilt's nut the kind ,'l lIIilll
ri~tlting like hell lu l>ecOlllL'
"'''fit to IH'. Ik Ii l:I'e lIIe.
llll' tnHn J want to be.
r am
The Illiln 1 want to b~ ha:... cOIlIPH''-I',.ion (Jnd undel'stnndilll!. God.
I knnw yuu are l.:oin~~ thrOll}!h YUlIr own per~oflal ht.'II. YOll urc
fightiIl.!! Cllllntll's~ wars. ;\nd til(' la<.,t thin!: ~'OU net.:d l::i
another onc C011l11ll! frnl1J IfIl'.
So no rn()r~. J alll c:llline it tr\l(,'l',
divorce llr custody, ilot 1111ti al
I wi II ne\'er again mention
"I' t IIi s slwl,es ou l.
I fit r u 1.1' I Ol'e \' 1111, I 1.:: e pIe J I i n u 11I.1' sell. I I\' i II :l C c"~ 1>1
whateve!' dt:c'ision Vou 1I,,,k'" :llld '-'0 011. It is iust hard. It is
hllrd for lIlan" reit~'lOll~i. J !U\'C ,'nu. 1 IO\'L' 11\,\' dau!.!.htcr. ..\nll
am a lonf.! wa\" (roll\ lH)llI..:.
!"!.t:t un~let bt.'cause hnv,_' oa~,:-;l.:\n. I h;tvl' PHs::iioIl for you.
passion for \\'l'itiut! lltHl PHL;~.iot1 for lirt..~ it~ell'. Passion
hrolluhl yOU ,ll1d I lo!.!elh(:['. \rc iUllIPl'd into lhi...... nUl' wacky
rcllJtionshlp. I've bt..:l,;.'ll dOln~ ~ollle :"nul .<;;l.:archin[.!. as wl,;:Jl.
r wonder: Did I Illake \.In:' Wt,l ~.it llli~,[a~:e nr my I i f't..~. lIlarryinu
thi:... WOI1l.ln': If I had to d,! it u\'cr H!.!ain. would I':
TheSl' ure lUl1~,h ljUe:.;;t inn~;. I Jollu\\'l.'d lilY heart \\'i th ,YOU. no
queslLon. I did not rulloI\' IIII' Il<~:ld, Alld. to he honest. it's
hard t.o re~ret that. I lJ.t\"c L!n.io~'t:d otlr t 1 lilt' to;!elher. I
enjoyed our It.::llIlwork. I rl..HIl \\'ol'kill~ on the hOllse. to doing
:.'; tor y i.\ ~;:::;; i 1..! IIIlH.' Jl t~; l 0 ';! l." I: II e r .
And. or cour:-:-,l.'. I'nl~,inL' o~r dilll,~.dtt~'r.
I keep l'l:III1!1<1illu 1I1\':-,ell thilt I'",,, unod :~u,.. j'/l,\a hard
wo r LeI' . I' III fa i t h f 1I I. ! J I k \.' p t...~) P II:. So r () r ~_ i \"~ r;'w f (,) r
l;.'xpln(:iJl,~'. Tlli:., ha, IJ('l'Jl d ',j J':'.::;!ul t illlC' 1"01' IIIC', (And
k 11\ 1\\ It' 'j \) ': ~ n ;', L J-e s " f LI 1 j u r \' () U . . . I (: t . :', n n t t r \' to ill d g t.:
',Vihl' ~-; ::l.ll t t \',tll;;l'. that ~ll II \'. I
Dl'ar LnUJ'd:
I'i rs I () f al I. I '.' I '"C' :-'il V.
"III ~-;prrV.
I alii writill.~ tId'. I~tt~r ,dtvr tllc' w<:d:<:nd frolll 11<:11, wl1~n
Wl.', had Ihu:.;~ ll_'rrib!l.; COIl\'l'r::-.ilti(lll" 011 thL' phol\e.
"
,Ii
I 1! U f,;,':CO sill I 0 f my Wo r~: l r l! n r S - l he po s s i h i J i l.v (l f I 0 sin u
~..ou and Uabrielle - eruPled. WcekL'nds arL' l(HI~" hen..~ for IIIl'.
I tr.\' to LL'cll hll~~;.\', hut inl.;..\.it;-tIJI...., lller(' ilr'~' (I ("H1 lilll~S.,.;illti
I !.! ld it It:{ in u:, d 11 d \I.P l' r i c~ d ,
That's not the ~:illd III IlIdll I
fighting like 11""11 tu bL'COllle
W;tll t itl
ll1<: llIan
t)l..', no:: I i (Po'c me.
\\'.'Hll to be,
I am
The llIiln I \\':ltlt t n h!"~ ha.., c.:Ol:lP(t;->~; i(\11 and understand i n:.!, (Joel.
~:no\\' ,\'Utl are 1!uin!.! lhrnuulJ ,\'nUI" own Pl'r~t)fllll lH:II. You nrL:
fight inc count IL'S~ wars, And th(' la;.,t thine: V(,U IH.'('d l~;
ar.olher tHH: Ctllllln~! from JIll',
So no more. I am callin~ i.l truce,
divorc~ or custody, nut tlltt i I al I
'f wi 11 never again IIlcnl ion
oj' thh "hab,s Ollt.
r j' t ru I). 10\'<: \'OU. kt'<:1l te II in!! ItIl'sl'l j', I wi II ilccepl
whatever decision .\'OU I1IH~~(, and ~o on', It is IU~..t hard. It is
hard fur many I'ei1,')on~i. i l<~vl' \Inti, I !U\'C III\' ddu,!.!hLer, And I
am il I OJl~ WH," r 1'0111 hOlllL',
,..
net UPS8l hL'C,'ltl~-;e h;u'c l)1l~.sion, ha\'(' pa:.,sioll for ,VOlt.
passion for wrilio1! and Pi\~;SiI.Hl fnr ife it~elf, Passion
brulIL!ht vou Hlld I to:":'l!ttler, We iU!lIIH:d into t.11 i..:; , nllr wac~:.v
relatiunship, I've h\.:l.'ll f!1)lnQ ~-;OlJll: :-;oul ::il.'arctJin!.!. as well,
I WlHHJcr: Did I make the '\Ol'~:;t llIi::.faKC nf lilY I i fL'. lJI,lrryin!!
l hi::; WlHlla 11': I r I had t () d II i t 0 \ \.;' r H t! i1 in, \\'0 11 J d l~'
These art' tDueh qUL";il ion:-i, InlluwL'd 111\' 11(,1"Irt wi ll1 ~!()U. no
qUesti(Ht. I did 11lJL follow Ill\" hl!ad, And. to bl..:: t1on0sl. it's
h a r d l L) r c ,!..! n.: l litH l, I II a \' t: 1.: II .1 .) \'l' d () U r (i IIW t (1 '..! L' l her. I
cnjo.\'l'd our te<1l1lwl1rk, I'rl..llll \\'Or~:ln!.! on lht! houst:. to doinf.!
::;tOI'." a~l:'-) i ~nllll'nl:j tO~21.' tl1l.'r,
And. of cour.':i(:, rillSllll! our dittl!!lltL'i'.
t: e f: p r I.: III i II din ,:1 1II,\" ~.; t,.' I r
\\'nl'~:er, )'mfallhful. I
L':\pIDdin!.', Till;; lI,'!:"-; 1)(;\..'11
knu", It"; tH."ell ~trL':~sILlI
Will)' :-, :..!ul j l \\1.)1 ;-;t,.'. t hitl
thnt "Ill i\:!oud '..!U\'. 1 'Ill i.\ hard
j i ~; ,_~ II t.~ () p I ~. So f () r ~! i \' C' lIl'~ t (l r
d. ',1.:-;."-.::-;11.11 il1lt' fOI ill v , (Alld
10:. \. 0:.1 . , , 1 (. t ',-; n () !. t r \" l u i u d r.: t.:
.~; i ! 1,\-, l
II
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1 tIll I Y illlpC 11'011 YUll ILl \'clI I t h r,.WI1 Iii till' towel rilly
dtJl1 t Cd!": 110\\ I\JIl~ ."\llI ~, t ; \ \' ill ""lr i ;-;hu r 1! \\'t) I k i Ill..! . wi I I
be fl.lt , l'lll .t.', IDllU : I .~ \ \)U ~, ; l \. t he ll~ I:, 01 I...' halll"L' .
So let ~ !! i \' l~ (11 i..... ",1.11111.'
nUI'Sl'!\-l';-i. And. lIlaylll'.
1.0\'l'. It I \\n \','J .
t illlt:. 1.,.(
Ill) 1"" I u I I'.'.
,,~t"J1 "acf'.. L"t >. rind
lie II rilld L,,,('h nthl.'r.
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02:02P Riegler Sh1envold & Assoc 5401416
P.02
. '
Custody Evaluation
I Elliot Riegler. Ph.D.
^fnold T. Shi~nvold, Ph.D.
I Melinda Ea.h, M.S.
J Wayne Tralla, ;\1.5.
I James W. Ea,h. L.S.\\',
1 Michael J. Asken. Ph.D.
! Illlnnie Howard. Ph.D.
AmylK. Keisling. A.eS.W.. L.S.W.
Gayle Sicchilana. M.S.
. Dlln Lawrence, L.S. W.
~
Riegler. Shienvold
& Associates
Laura Mathews V. Michael Stetz
Referred by:
i
I
Mutual consent of the parti..s following a concilial ion hearing in
Cumberland County r
Referral Reason:
To conduct a comprehensive custody evaluation nd to make
recommendations regarding the most appropria e custodial
arrangements for Gabrielle Katnna Stetz, DOB 8 5/93
Individual Interviews:
Michael Stetz approximately 3 hours I
Laura Mathews approximately 3 hours I
Minnesota Multiphasic Personality Inventory-2 (~PI-2):
'Mi~~~tz I
· Laura Mathews
Psychological Testing:
Millon Clinical Multiaxial Inventory-In (MCMI-l I):
.. · Michael Stetz .. .
"Laura Mathews
Childhood History Forms were completed by bot parents
Parent Child Interaction: Both parents were observed intcracting with Gab ielle in the office
selling.
I
Other Information 1. A Patriot News article written by Michael Stet~ on fatherhood
was provided by Laura Mathews. . .
2 A series of articles on Alcoholism were provide>> by Michael
Stetz r
3.Infonnation regarding the Silvcr Gate Enviro~enlal Science
Magnet School was provided by Michael Stelz. .
I
The recommendations at the conclusion of this report arc the result of a farefu) review of
all ofthese sources ofinformation. I
,
!
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,
I
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,
Fax: (717) 540-1416 . (717) 540- J] 13 . :! 151 LinglcslOwn Road, Suite 200 . Harriso1rg. Pennsylvania 17110
I
.~.
Aug-11-98 02:02P Riegler Shienvold & Assoc 5401416
P.03
Page 2
RE: Stetz v. Mathews
Background Information:
Michael Stetz and Laura Mathews are the biological parents of Gabrielle Stctz. Michael
currently lives in San Diego, California. He has been there for approximately th last 9 months
working as a journalist for the Union Tribune. Laura is a photographer for thc atriot News Co.
Shc and Gabrielle live in New Cumberland. Michael is suing for primary physic I custody of
Gabrielle and requesting that she live in San Diego with him for the majority of e time. Laura
believes that it is in Gabrielle's best interest to rcmain in Harrisburg with her.
Michael and Laura met in 1992, Thcy had a relatively rapid courtship were married in
March of 1993 after Laura had become pregnant with Gabriclle. Although both werc cxcited
about the prcgnancy, Laura felt that "Mike got me prcgnant as a goal." Mikc I' orts that after
being out of work for two months Laura was' complaining that she needed to w lrk. Laura
indicated that, in fact, she was home with Gabriellc over six months prior to rct ming to part time
work. At that time, she bcgan working 3 days per week. On two of those days abrielle was in
daycare. On Saturdays, Mike would carc for Gabrielle. Therefore. Laura argue that prior to her
return to full time work when Gabriclle was three and a half years old, she was I e primary care
giver. Mike disputes this belief slating that he provided much of the morning ca e for Gabrielle
prior to going to work at 10:00 am and most of the evening care for Gabrielle en hc would
return from work at 6:30 PM. Furthermore. he providcd care on Saturdays and shared the care
on Sundays.
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According to Laura, marital problems began to increase in the spring of 996. Shc
attributcs many of the problems to Mike's inflexibility. The issues wcre related 0 her working
and financial concerns. Laura admits that she began "drinking heavier" at that t e. Mike agrees
that there werc increasing marital difficulties, but feels that Laura's drinking wa the major
problem. He indicated that although she drank throughout the marriage, her he vicr drinking
meant that she started in the afternoon llnd drank until she was drunk. Such be avior became
more and more frequent.
In June of 1997, Laura recognized that her drinking was out of control. IShe enrolled in an
intensive outpatient treatment program at Hershey Medical Center. This progr entailed
treatment for 4 days per week in addition to evening meetings. Michael was su portive of
Laura's treatment by adjusting his work hours and caring for Gabrielle in Laura s absence.
During the process of her rehabilitation, Mike rcccived the job offer in San Die . Laura admits
encouraging Mike to take the job and moving to San Diego. Although there w e multiple
personal and relationship problems, both parents felt there was a chance of the arriage
succeeding and that San Diego would be a viable option for them to live.
I
Mike moved to San Diego, Icaving Gabrielle with Laura. He felt that he~ drinking had
ceascd and since she was in treatment he had less fcars of Laura's care of Gabr+le He was also
I
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Aug-11-98 02:03P Riegler Shienvold & Assoc 5401416
P,04
Page 3
RE: Stetz v. Mathews
"
convinced that Gabriclle and Laura would be joining him within she months, Un onunately,
neither Mike nor Laura were able to overcome the problems associated with l.a ra's recovery. In
December, following a visit to San Diego, Laura told l\otike that she was not goi g to join him.
Additionally, in February Mike was informed by a "friend" that Laura had been aving an affair
for quite a while. Mike infonned Laura at that time that he wanted a divorce an was tiling for
custody. He thought that Laura would agree to his being the primary care give Obviously, she
did not and the current custody disagreement ensued.
1
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Mike has several reasons why he believes he should be Ihe primary care 'iver. First, he
loves Gabrielle very much and believes that he has always be an integral part of ler life. He
describes himselfas II" hands on dad." Secondly, he believes that he has the ri ttemperament
to be a good father. He sees himself as loving, compassionate, and sacrificing. his last poinl is
important because he does not feel that Laura is sacrificing when it comes to G rielle. He sees
Laura as being more self-centered and unwilling to make Gabrielle her first prio ity Thirdly,
Mike feels that he had elCcellent role models as parents and especially an elCcelle t role model in
his father, This has helped him to develop his own "natural" skill.
r,
Most importantly, Mike is concerned about Laura's long tenn stability. is first concern
with respect to that is her drinking problem. Mike feels that during the maniag he was in denial
and ignorant to the extent of Laura's drinking problem, He slates that although the drinking
worsened throughout the marriage, Laura overused alcohol from the beginning. At its worse, she
was drinking from early in the afternoon until she went to bed. Her drinking w occurring daily
and it would often lead to blackouts. Mike is concerned that even though Laur began to get
treatment for alcoholism, she did not complete the treatment. Furthennore, ace )rding to Mike
she failed to disclose to her counselor times that she drank during her recovery. Mike alleges that
Laura admitted to drinking as late as November of 1997. He does not trust that she will maintain
her sobriety past the time of the custody evaluation.
')
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The second component of her instability, according to Mike, is the fact t at Laura has now
been manied thrce times. He is concerned that she is incapable of establishing long term, loving
relationship. Hc also alleges that Laura tends to blame her relationship failures n others rather
than herself. Mike notes that one of the reasons to initially keep Gabrielle in Ha risburg was to
maintain a stable environment for her until he was established in San Diego. Ye, once Mike had
left the area, Laura moved from their home and moved Gabrielle from the dayc e that she had
loved to a babysiuer. He feels that Laura did that because of her needs, and an nwillingness to
adjust her needs, rather that because it was best for Gabrielle.
Laura feels that Gabrielle's best interests will be served if she remains in~arriSbUrg with
her. Actually, Laura indicated that she felt that the besl arrangement for Gabrie e would be a
shared arrangement in which Laura and Mike lived in close proximity to one an ther, She
indicated that shc has asked Mike to return to this area and hc has refused '
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Page 4
RE: Stetz v. Mathews
As stated above, Laura believcs that she has always scrved in Ihe role 0 primary care
giver for Gabrielle Contrary to what Mike has indicaled, she feels that Mike 0 Iy provided
complimentary care to her. She feels Ihat his job came first and the family was condo She
described Mike as self-absorbed and gave the example that on the day before he lelllor San
Diego, he worked on his novel rather than spending time with Gabriellc. She fe Is that Mike is a
better playmatc than her with Gabrielle, but that she is the bettcr care giver.
Laura is concerned about Mike's innexibility. She perceives him as unc mpromising and
neediog to get his own way. It is her opinion that his attitude was a major sour e of the problems
in the marriage. Laura is fearful that Mike's dcsire for custody is in part retribu ion for her
decision to leave the marriage. He is also quite angry because he believes that s e had an affair,
which Laura totally denies. She also denies that shc is dating anyone at this tim , She reports
maintaining all of her free time for Gabrielle. !
Laura admits that she has had a drinking problem, but strongly feels that Mike also has a
drinking problcm. She states that Mike drank with the same frequency and patt rn that she did.
According to Laura, the only differcnce was that Mike did not drink to the poin of intoxication
very often. On the other hand, she admitted that once she began drinking, she ould oftcn bingc
until she was drunk or unconscious. She argues; however, that Mike did not co plain very much
about her drinking during the marriage. Furthcrmorc, ifhe was so concerned hy did he leave
Gabrielle with her? This is a question she asks in defense of herself.
Laura believes that she has successfully defeated her drinking problem. 'he admits that
she prematurely dropped out of counseling and that her counselor advised again .t that. She
reported that she "had to" stop becausc ofthc demands with Gabrielle and her j b. She continues
to attend AA meetings, but no longer has a sponsor. She believes that she will ot drink because
" lfllose sobriety I lose everything," and because. .. I stopped drinking for Gab ie." She denied
having a drink sincc last ycar.
Laura Mathews:
Laura is a 33 year old woman who has worked as a photographer for mtst of hcr adult
life. Her parents divlJrced when she was 11 years old and she lived with her 100 her. Her father,
who is a physician, dropped out of her life and shc has virtually no relationship ith him. He has
never seen Gabrielle. Hcr mother has visited and remains a part of Laura's life. i
i
Laura was conscientious in her participation in the evaluation. She arriv d for all
appointments on time and was well-groomed and neatly dressed. She was frien ly and compliant
with all requests during the interviews. Her mood was appropriate for the situ a on. She
appeared somcwhat noxious and serious, but was ablc to display a good sense 0 humor.
Aug-11-9B 02:04P Riegler Shienvold & Assoc 5401416
P.06
Page 5
RE: Stetz v. Mathews
Affectually, she denied any significant symptoms of amdety or depression. She r.as very
concerned aboulthe ultimate outcome of the custody battle Laura's thinking a peared to be free
of any distortions. She was able to prescnt her side ufthe stury in clear, concise terms. Nu
cognitive impairmcnts were apparent.
As noted above, Laura admitted that she has had a drinking problem in t e past. She
began drinking in high school and continued to use alcohol in college. She adm ted to using
alcohol as a strcss rcliever even in college as well as a sociallubricanl. Laura fe t that hcr alcohol
abuse was a factor in the demise of hcr second marriage. She received no treat ent for hcr
drinking until she went to Hershey in 1997. She is not in counseling at this time and denies that
she needs any. She is relying on the AA meetings she attends and the support 0 'her friend~. to
~~~ '
Laura has two previous marriages. She feels that the first one, which oc 'urred when olhe
was 20 years old, was a mistake of youth. Thc marriage lasted only a very brie time. Her second
marriage was to a Ph,D. who eventually moved to Bucknell University. That is ow Laura came
to Pennsylvania. According to Laura, she was resentful of his move here and th . fact that she did
not finish her dcgree. She began drinking heavily at that time and they ultimatc1 divorced. Laura
appears to have some difficulty with long term commitment. It appears that she tcnds to project
blame for these problems and has coped through avoidance and alcohol. This i plics a degree of
immaturity in her interpersonal relationships. '
Laura completed the MMPI-2. The profile is valid. Individuals with thi profile have
generally responded frankly to items, although they may be somewhat defensive and reluctant to
admit psychological problems. Their affect is likely to be marked by resentment. Thcy are likely
to eltperience difficulty expressing negative emotions and emotional instability ay be
characteristic. Individuals with this profile tend to have low fhlstration toleranc 's and are
impulsive. Thcy have been described as rebellious, adventurous, and sclf-center 'd. They tend to
disregard the potential or actual consequences of actions and may not learn tro experience.
Acting out behavior may include lying, alcohol abuse, and seltual acting-out. Si 'Iar women have
strong identification with the female role in that they have a tendency to be pass ve, submissive
and demure. They may also experience difficulty in delaying gratification. Inte ersonally, these
individuals usually create a good first impression, but then eltperience'many inte ersonal
problems. Forming wann, intimate relationships is difficult. Marital difficulties e probable as a
result of a long history of inadequate family and social relationships. Diagnoses associated with
this profile generally relate to the long standing characterological issues as wcll s substance
abuse.
Laura also completed the MCMl.1Il Her prolile indicates a attempt to !ppear composed,
virtuous, and conventional in behavior. She is attempting to downplay any distr ssing emotions
and to deny troublesome relationships with others. This unrealistic presentation,represents more
Aug-11-98 02:0SP Riegler Shienvold & Assoc 5401416
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Pagc 6
RE: Stetz v. Mathcws
of a wish fulfillmcnt, than reality. In fact, individuals with this prolilc have a hig I nccd for
attcntinn and atTcction Thcy cxpcriencc considerablc conllicls over their tende cy to be
dependent and their lIeed to be indepcndent They tcnd to end up rescnting tho e individuals
upon whom they bccome dependent and become impulsive and sarcastic in the pression of that
resentment.
Laura demonstrated a good knowledge of Gabrielle's growth and devel pment. She was
ablc to report whcn Gabbie reached all of her developmental milestones. She s ke in glowing
tenns of how precocious her daughter appears to be. She described Gabbie as ing a very
bright, inquisitive, crcativc youngster. Shc notcd that Gabbic is ablc to handlc h rsclf wcll in
social situations and that she prcsents no particular behavior problems. Gabbie' physical
devel'Jpment is good and she dcmonstrates good linc and gross motor coordina .on. Laura fccls
that shc has becn instrumental in helping Gabbie devclop hcr artistic and creativ skills.
Laura's interactional stylc with Gabbie is relaxed and comfortablc. Laur directed hcr
attention to Gabbie and maintaincd good eye contact. Gabbie sought her mothe 's attention and
approval for various tasks. Gabbie was initially "shy" in the office, but she cont nually verbalized
with her mother. At times Laura would choose words Ihat did not appear to be age appropriate
and Gabbie did not understand them. This is in spitc ofthc fact that Gabbie has an e>ctensive
vocabulary. Laura and Gabbie showed no difficulty in their play with one anoth r. Gabbie would
attcmptto copy her mothcr's drawing stylc in an attempt to model aftcr hcr. T cy appcarcd to
enjoy working with one another and it was obvious that thcy spend time togeth r playing at home.
They drew a family picture with both mommy and daddy in it. Intercstingly, Ga bie wanted her.
mothcr to draw daddy. Laura did this without complaint.
Michael Stetz:
;
Mike is a 39 year old man who was raised in Baltimore. He has two brolhers and his
parents remain together and living in Baltimorc. They were a major sourcc of s~PPort tor Laura
and Mike in caring for Gabrielle and they remain active in helping Mike whcn h has custody.
Mike's family is Catholic and Mike is e>ctremely intcresled in maintaining Gabrj Ie in the Catholic
religion. !
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Mike was an eager participant in the evaluation proccss. His interviewstere all
conducted in one day because ofthe distance hc had to travel. He was coopera 've with all
requests and wanted to insure that he provided as much infonnation 25 possible. Mikc was
fricndly and politc. He was casually dressed for his interviilws as well as when ile was observed
with Gabbie. I
Aug-II-9B 02:051' Riegler Shienvold & Assoc 5401416
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RE: Stetz v. Mathews
Mike's mood for the interviews was pleasant, but serious. His alTect wak appropriate for
the content of the discussions. Mike indicated Ihat he is currently in trealment f~r depression
secondary to his marital situation. He sees a psychiatrist and currently takes ZOtft, an
antidepressant medication. Mike denied any significant problems with anxiety 0 her than his fears
regarding the custodial battle. Mike appears to be of above average intellectual bility. He
presented his side 01' the facts in a rational and logical manner. He displayed nOtigns of cognitive
impairment and he denied a history of severe psychiatric illness. He demonstral d good social
skills. His marriage to Laura is his first, but he has had at least one other signifi ant relationship.
Mike denies that he has a drinking problem. He admits that he would d~nk with Laura
while he was in the relationship with her. However, he stated that his drinking Jas always
controlled. He reports that he had to exhibit control because when Laura got d.Junk it was he
who would watch Gabrielle. There are no external facts consistent with a drintg problem for
l\.1.ike. He has had no OUI or any other legal problems secondary to his drinkin . He also denies
any history of blackouts or other alcohol related symptoms. He currently atten s Alanon
meetings. ,
,
Mike also completed the MMPI-2. His is a valid profile and he appears 0 have responded
frankly to the questions. Like Laura, he tended to be somewhat defensive and r luctant to admit
some psychological problems. This profile type is often obtained in individuals xperiencing
situational stress. Personality characteristics can include naivete, optimism, and self.centeredness.
Similar individuals display high drive and energy. They are mildly independent nd adaptable.
Passivity and relined characteristics are suggested. They are comfortable social and may dIsplay
an assenive all itude. They will display a high need for affection in their relation hips. Cognitively
these individuals try to avoid unpleasant situations so they tend to use denial as major defense
mechanism.
It is important to note that all of the MMPI.2 clinical scales are within nrnnallimits and
there are no psychiatric diagnoses associated with this profile.
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Mike's MCMl.I11 profile is also valid. Men who receive Ihis profile are enerally well
functioning individuals with no major personality disturbances. They may.be un ergoing stressors
and exhibiting symptoms that are transient and situational. These individuals ar concerned with
appearances and want to be seen as composed, virtuous and conventional. The are likely to deny
uncomfortable or negative feelings because of fears of losing control. They ten to be compulsive
in their approach to tasks and feel more comfortable when they are in control 0 a situation.
!
Mike also displayed an excellent knowledge of Gabrielle's growth and d~elopment. He
was aware of when she achieved her developmental milestones. He had awaren ss of her physical
development and her health related concerns. Mike took great joy in describing his daughter's
personality, He. too, sees Gabrielle as a precocious, bright, articulate little girl ho is simply a
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RE: SteIL v. Mathews
"joy." He denies any signiticant behavioral problems for her that arc beyond th~' norm for a child
her age, He believes that she is ready for Kindergarten at this time. He feels tha he has sparked
Gabrielle's interest in athletics, which he feels is very important for her self-este m. He hBS also
put a lot of thought into the importance of religion in Gabrielle's life. .
Mike and Gabrielle's interactive play was marked by fun and joy. Gabbi' obviously enjoys
being with her father. Their play together is truly interactive. Gabbie seeks phy ical contact with
her father and Mike happily responds. Mike will frequently reinforce Gabbie's tempts at any
task with genuine pride in her performance. He is fairly non-directive in his styl with her, but
will provide limits for her when necessary, Gabbie frequently sought out her fat er to tickle her
and she would then laugh with glee. The conversations between the two of the I were
appropriate and Mike used age appropriate language when talking with Gabbie.llt is obvious that
Mike and Gabbie enjoy one another's company and have spent a lot of time tog,ther.
,
Recommendations:
-II
"
Gabrielle Stetz is a very fortunate little girl in that she has two parents 10 love her very
much. Unfortunately, her parents arc unable to live together so il is necessary I assign a primary
physical custodian. Given the distance between households, and both parents I' uctance to move,
an equally shared custodial arrangement will not work. !
Givcn the facts in this situation, it is recommended.that Gabrielle be in h1r father's primary
custody during the school year and in her mother's primary custody during the ;;Cmmer recess. It
is recommended that Laura be afforded liberal access du ring the school year b01. in Pennsylvania
and California. Similarly, if during the summer Mike is in the area ofPennsylv ia. it is
recommended that he be allowed to spend time with Gabbie. The specific sche Ie of access will
depend on each parent's particular schedule, but it would be anticipated that La'jlra would be able
to visit with Gabbie at either Thanksgiving or Christmas and during any spring recess. Gabbie
should come to Pennsylvania approximately one week following the close of scHool and not
return to California until approximately one week before the beginning of the sc~ool year. Mike
should be allowed to visit his daughter in the summer if he is in the area. I
11 is rccognizcd that both ofthcsc parcnts have bcen intimately involvedt thc care and
raising of their daughter. The history seems to indicate that they shared the pri ary tBSks
associated with Gabrielle's care, and that gcnerally both of them did a good job ith those tasks.
The determinative factor in this situation is associated with Laura's drinking be+vior and her
current attitude about her behavior. ,
,
It is of great concern to this evaluator that Laura has terminated her trcatment. Inherent in
that decision is a denial of the seriousness of her problem. Laura's drinking beh viol' datcs back
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Page 9
RE: Stetz v. Mathews
to high school She has uscd alcohol almost all of her life to "relax me when I' stresscd." She
admits that alcohol was a significant factor in the demise of hcr last twu maniag 's. Although she
may not be drinking at this time, hcr reasons for not drinking arc not clearly dcfi lcd, Shc statcd
that she was fearful of the impact of drinking on the custody outcome and ofJos ng Gabbie.
Those are not the most important reasons for her to stop drinking! Laura did n t display a clear
awareness of how destructive alcohol has been to hcr Iivc. She also lacks under t1nding of the
dynamics that control her drinking. She absolutely nccds to bc in treatment andIcCdS to make
provisions to get that treatment. Laura appears to be in denial of those factors hich make her
extremely vulnerable to begin drinking again once the custodial decisions havc 'en made. If the
presence of Gabbie makes getting the help she needs difficult, then Gabbie shouJkl be with her
father so that Laura can have the time necessary to get the extent of help she ne~ds. Laura's
problems with relationships, both marital and familial are also important areas o~ focus for her
therapy, They definitely contribute to her problems.
It is felt that Mike can provide very well for Gabbie's best interests. He nows how to
care for her, they are well bonded, and he has the motivation to make her adjust enl to the West
coast a positive experience. Mike is a thoughtful father who has taken the time 0 think through
what the needs of his child will be in California. It is felt that he will fulfill his 0 ligation to ensure
and encourage the relationship between Gabrielle and her mother It is also pas ive that he is in
counseling at this time so that he can continue to examine how he has contribut d to the failure of
the mamage. Ifthere is a specific area upon which he needs work, it is his ange . at Laura for the
end ofthe marriage. There is no indication that Mike suffers with a drinking pnjblem. but at least
he continues to work with his Alanon group and his individual therapist to addr~ss any associated
issues. !
I
Ifin the future these parents move into eloser proximity with one anotheLthey should
seriously consider changing the nature of their arrangement to a more equally sh cd schedule.
Gabbie needs both of her parenls in her life to the greatest extent possible. It is~ssumed that
Laura will get the on-going counseling necessary to solidifY the progress she ha made with her
drinking and insure that she can provide a safe and stable environment for her d ughter.
')
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Arnold T. Shie !Void, Ph.D.
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RnlDENTIAL LEASE,RENTAL AGREEMENT AND DEPOSIT RECEIPT I~
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FORM 105 (II. ~ pRa....'O"AI;
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SCHOOL ACC"'UNTABILlT'l REPORT CARD
SILVER GATE
ENVIRONMENTAL SCIENCE
MAGNET
SCHOOL
SCHOOL PROFILE
Silver Gate ~lagnet School is localed in
Poinl loma. an older. well.established area of
San Diego. TIle neighborhood is economi.
callv diverse. wilh ever increasing ethnic di.
ver~ilY. The school. originally huilt in 195~.
consists of Ihree pemlanent buildings and
four portables. one used as the Iibral')"media
ccnterandOlhcrs forclass size reduction.
Student RlcllllElhnlc Compollllon
1997418
HlNo/lCUO
-"
Alt....". ~I
.
Percentlae or Tolll Enrol"',nt
Currenl stud en I enrollment is 591.
wilh 66 percent from the neighborhood
and 34 percenl transported from through.
out San Diego.
M/SSION A,\'D GOALS
San Diego City Schools has adopted a
mission statement to guide the district in
providing educational programs.
II is I"" missioll of IOllr dislri"I/IO
t!dllL'Ult! ,,/I studt!nts ill un ;II/e~
STUDENT LEARNING
. . I't:DEST ACIIIEVE~IENT
1/".., '1ft! ..dill/en/.\' ,/oillJ:?
San Diego City Schon Is students in
grades 2-11 take the Stanford Achicve-
menl Test. Ninth Edition (SAT 9) 10
measure their academic progress in basic
skills. In prior years. students in grades
2-10 were given the Slunford Achieve-
ment Tesl. Eighth/Abbreviated Edition
(ASA l'), Spanish"peaking English learn.
gralt.'d .ft.'lIl11g 10 nt.'cottlt.' rt'.'i/"mst.
"k hft.,,.alt'. fl""k.;,,~, lI11d emlll'lb.
/lllIIg mt.'mh..'r.f '!lll mllll;I.'"IIIIral
.WI.'IL'ty Ihrollgh L'.\','t.'llt.'lll't.' ill tt.'tJ"".
lUg and h'I"niH,!!.
All diSlricl schools have set several
gO<lls in c<lch of four major arcas to ac-
cumplbh this rni~sit>n:
IrnprovlOg student h:aming
Improving tcaching
Enhancing inlegration and diversity
Enhancing shared decision.making and
cornmunit~ in\'ol\ ~mcnt
Siher Gale stalThelie,e Ihat all students
Icarn 10 a positivc, supportive. qualit~. en\,j.
ronment. StafT strhc to pro\'ide academic
L!.\ccllcncc through a program b3lancing
basic sJ..llIs, aitic<ll Ihinking. enrichment.
and utililation Ill' ~ommunity resources.
F(''ilcring positive altitudes of students
allt1ut them!lcl\cs and others helps students
de\ clop a betler understanding of. and rela.
tionship wilh. people of diverse back.
gnlunds, cultures. and cthniciucs,
Sil\cr Gate's magnet focus is environ-
mcntal sciencc for all studcnls. The three
themes \\ hich rOlale Jnnually are oceans
and aquatic systems, rainforests and
grasslands, and desert and scmi.arid
lones. Hands.iHl instruction takes place
in Ihe Eco lah and E<o Garden. where
students further c\plore environmental
CUrriculum presented In the classrooms,
l'rs ellrnlh:J In .1 C,llil\Hnia 'icholllles!O
Ih.m I':: IIWllllh .lr I.'nwlkd in a California
..,,:twIll for 1':: ILl '::.l months :H1d rCI.:t:i\dn!-
1,1I1gu~lt!e .Ins 111struClltln in Spanish are
abo h:Sh,'U I'll the ;\prenda ~, .1 Spanish
LJllguagc ;\chll:\cmcnt Tcst measuring
lhl.' ..amI.' .."III JrC:IS.
Sih.er (j,1I1: ,WdCIIIS l.:llntinuc co per.
form abO\ l' il\ l'ragc "" all 'itJnuardized
:ll..'hic\CITH:nIIC"ilS.
,\frJ. flath"r" Kll!m
P";III.:I{",1
l.JfJlJ "I;"'''''t'S/I\'t't
Sa" Dil!~o, C..f 9~ ur
(M9)~~M/J9
,\lARCIf 1'N8
SIIII Dll'~O City."W..'hool.r
REPORT CARD MEETING,
INFORMA nON
Date: May 26, /998
Time: 5:00 p,m.
Place: Silver Gale, Room 7
Propo.ltlon 98 require. all public
school. In Callfomil to provide InroltlUl-
lion about themselves to Ihe public through
a School Accounlabillly Report Cord. Thi.
report card exomines Sliver Gate Elemen-
tary'. policies, progroms. ond prosrcss. At
a meeti"8 on May 26115 p.m. pll/'Cllts can
disCIW the report cord II1d uk questions.
Morc informl1ion about 011 Ire.. covered
In this report card i. Inilable It SilverGl1e
Elementary. We invhe plll'Cnls to come to Sli-
ver Gate to look at thC$C mlteriols, to meet
their childta1'. teachers, and to expond their
involvement In their children'. education.
Technology is incorporated throughout
Ihe classrooms with a focus on environmental
projects using Internet access. Hyperstudio
and many kinds ofcomputersoftware.
Our report card is organiz<d around Ihe
district goal areas. This will help parents
understand our school's strenglhs and
\!r'eaknesses as well as our success in im-
proving the school bl' meeting our goals.
. SCHOOL. TO.CAREER
TRASSITIOS
/low art ftu,ltntt prtpar~df'lr lilt
H'orld of wor"'!
Silver Gale orrers a wide varielY uf e,-
pcricnces for scudents to become familiar
wilh Plher johs and companies. We orrer
many field trips and career awareness
presentations where parents and cUlside
speakers share their t;arecrs with class-
I
rooms. We also have six parlners in edu-
cation: McDonald's, FCTCPAC, Union
Bank, Good Eanh, San Diego Pon Di,-
Iricl, and Ihe Nalure Company.
Attendance Rates
r. "
, ' -
. , .
1992-93 16.0 95,3
1993-94 19.2 95.5
1994-95 21.0 95.2'
199>96 24.7 950'
1996-97 15.4 959'
'':'QQ'esnoITriclude SlafidevBiQpmenl days
. A TTENDANCEIDROPOUTS
DtI .tl/dent. attend and 'Ia)' In "'I",,,I?
An imponant goal of all schools in our
districl is to keep studenlS in school from
early childhood Ihrough high school. The
average daily attendance rate at Silver
Gate for laSI year was 95.87 percent.
Non-apportioned absences (those
without distriel-approved excuses) ac-
counted for 15.42 percenl of all absences
TEACHING QUALITY
. TEACHING ASSIGNMENTS
Do we IIove quai/fled teoeller.?
,
There are 27 highly qualified class-.
room teachers at Silver Gate. The average
teaching experience of our teaching staff
is 13 years. Twenty-one teachers have
master's degrees. Each teacher is prop-
erly credentialed 10 teach the grade level
at which they are assigned. Many teach-
ers have additional credentials. including
bilingual. Gifted and Talented. special
education. and administrative credenti\lls.
One of our teachers was honored teacher
of the vear bv the Association of San Di-
ego Educato;s of the Gifted. Gifted and
Talented Education (GATE) cluster and
seminar classes are offered in grades 3-6.
All Grade 3-6 teachers hold GATE cre-
dentials or are in training.
. TEACHER/ADMINISTRATOR
EVALUATION
Huw ar~ ulId,erJ and QtlminiJlratort
f!w,luated?
The principal formally evaluates 11m.
ured teachers ever)' two years. T empnrary
or probationary teachers are observed fre-
quentl)' and evalualed yearly. If a
teacher's performance is not effective. the
principal identities areas requiring im-
provemc:nt and develops a program for
improvement wilh the lendler. The prin-
2
SIL VER GA TE ELEMENTARY
In 19%-97. Purental ,uppon in requcst_
ing independent SllId) conlracls ror ah-
sences nol due to illnesses would greatly
help our elTOrlto address Ihis problem.
. DISCIPLINE ,\~D CLI~IATE FOR
LEARNING
Is IhiJ ,fd",,,'" RIJrltl pitH'#! to It!nrn?
The campus is peaceful and orderly.
This environment enh.lnccs h.'arninll. The
following ptJlidcs l.:tll1lrioulC to a p~"iiri\ c.'
atmosphere of mutual respect and rcSrllm.
sitllc bl'!li1\ior:
. We 11011l1r "itudcl1ls month I} for oul.
slanding citizenship and academic
.H.::hicvclt1cnt .It Gator Uram ilsscrnblics.
. Posilhc rc\\ards indudc Lunch with the
Principal, "caught doing somelhing
good:' bumper stickers. rc.'\I.'ard time.
bus behavior 3\'w'ards. perfect attendance
certific:ues. and coupons to Midw3)'
~lcDonald's.
, The Navy volunle..s from Fleet Com-
bat Training Cenler. Pacinc
dpOlI is also c\aluatc:d every two }'cars by
a cenlral otlkc supcl'\isor.
If )'OU arc concerned about a teacher.
administrator. or olher stafr member.
there are steps Ih3t )OU can take. You can
tind them in Facts JiJl' P"'/'t!IIU sent home
with e\ery sludent at the start of the
school year. You may call the principal or
the School Services Division to discuss
this subject at an)' lim::.
. SUBSTITLTES
Do Wf' "al'f' qualJfll!d fllhtt;tlllf'f?
The district has a pool of Sllb'litute
teachers available for assignment \\ hen a
classroom teacher is absent
By state law. credentialed leachers
may substitute at any grade level and in
any subject. We Iry to place substilule
teachers in their area of e~pertise.
. 11'STRL'CTIO~AL A:-:D
LEADERSHIP I)LALlTY
HowgOfJd;.t it?
Our curri~ulurn is ,lliuned \\ ith stJle-
adopted frameworks and- guidelines. Sil-
ver Gale has a \'ariel~ Ill' programs to
reach the needs tlf our di\ersc population:
. G." rE 'icminar and cluster classrooms
. En~lish a, a Second Lan~uage IESI.)
inslruction
(FCTCP.'\C) provide one-Io.one lUtor.
ing.
" hreaklast program helps sludenls be
ready '0 learn each day.
, The Peninsula branch of L'nion Bank
recognizes SIUdents for e:'l:cellence in
beha\'ior. in academic achievement in
m"lh. and the Jr. Banker program.
, Aller.school programs for child care,
aerobics. SCOUIS, and sports are olTered.
Silvcr (jale continua"\' rcassesses its
discipline policy. relining' and ensuring it
meers current studenl needs. II is Silver
U;.Itc's goal to minimize instructional
time losllo discipline problems.
-- -.- -..,-..... -.- --~ -~-- --'.-
nslons and Ex ulslons
I:';,~r~:::-t i'
r'. .~...... .. ,..,
1992-93 8.2
1993-94 5.7
1994-95 6.2
199>96 1.3
19~7 1.6
..- SU'S'pensionsperiOOSfudBn'ii.
o
o
o
o
o
--
. ..\ frican American studenl program
, Hispanic Advocacy program
, Paraeducators suppon classroom in-
struction
, Adaplive physical education
, Speech and language therapy
. Special education resource specialist
program
Instrumental music program for grades
five and six
Physical education prep lime program.
After school enrichment in Spanish.
French. and Ponuguese.
There are numerous mentor quality
leachers on sile. wilh special skills which
are shared wilh others. as well as leachers
who have been fo""all)' appoil1led as dis-
trict mentor teachers. Last year. due to
funding reductions. paraeducator time in
c:ach classroom was reduced to one hour
and fifteen minutes a da~',
~lanv Ill' Ihe teachin~ staff assume
leadership roles wilhin ihe school and
district as ~C) planners. ~ommillce chair.
persons. and diSHkt ~urriculum repre.
senlatives.
TI::J.chers vuluntarily seek protessional
devc:lopment through university courses.
conferences. workshops. and institutes on
local. state. and nalional le'oels. This en-
School Accountability Report Card
Class Size r' tributlon
,
Number of Students per CI..eroom
..-....-.. ..-.-.-- ---.-----. ... .------.',
Class Size by Grade, 1995-96
\.-~ M~.c........t:~'..J r"PlL..-. {..': I ". t. .".., I - ; ....'. ...~.& .) . 'I . ~. I'..
,I -l~'~ir(, '.Leo'.. ..~~. ,', '. ~I ,~ dC:J'!.J . ,'~.J. .. .J.I. ,
31
31
25
26
26
26
25 26
25 26
26 25
17
32 31 18
33 30
_~.L
31
31
31
..- . .-.- -~. .,... . -. -. .... --- '-"
Class Size by Grade, 1996-97
1~':~.1<".':.1"',.1 ~].. ,~~:tL:~;i;}:4~~:I~' tl.,~.iM~It{.~ :~:E:;e :.~~
31 20 20 31 27 33 30 15 31
32 20 20 31 18 32 30 30
1S 18 30
19 20
19
._._.....~.. .--"--."~" -.----...
_._._._._ .._ ".. n._ _.__._~
Class Size by Grade, 1997-98
r.:UIU:'!~i131~B_"~
20 20 20 19 20 32 30 32 20 31
19 20 20 19 32 31 32
20 19 19 20
20 19 20 19
....... _._..__1~___._...___
.
4
SILVER GATE ELEMENTARY
School Accountability Report Card
H
dbles Ihem, to' bring Ihe besl or currenl
leachi~g practices 10 our school.
. INSTRUCTIONAL TIME
'10'" much Ilm~ IJ Ih.,~ 10'
. ,I,ucllon'
\II dislrlcl schools meet or exceed
Sl.. requiremenls ror annunl instruc-
lion.1 ',inules. Silver Gale will hnve 40
minir' 10 dnys Ihis yenr. During Ihese
mi,' ,um dnys our slalTholds grade level
m. . lings. in-service trainin!!-. magnet
~'Irriculum development meetings. and
parent conferences.
K 41,400 36.000
1-3 55,300 50,400
4-6 55.300 54.000
. TRAINING AND CURRICULUM
IMPROVEMENT
IVIInI au ...~ doing 10 Imp'ol'~ J/alf!
The slnffnnd principnl orSilverGale nre.
com mined 10 ongoing proressional devd-'.
opment ror all members or our eduenlionnl'
lenm. including principnl.leachers. parenls.
nnd clnssroom nides. The prineipnl sup-
ports opportunities ror individunls 10 nuend
conrerences, workshops. nnd mcnlor
lencher demonslrnlions. During Ihe Insl
Ihree yenrs, Silver Gnle stnlT hn,e pnnici-
pnled in sevenleen slalTdevelopmenl days.
Those non-sludenl dnys hnve been used 10
attend alT-site conferences to camp":lc our
Program Qunlily Review (PQR). 10 creale
our Annunl Action Plan, 10 conducl cur-
riculum dc\clopment around our em'iron-
mental science magnet theme and to
collnbornle ns n school slatTand communilY
to enhance our instructional program.
This )'enr, staff nnd pnrenls auended a
variely of in-service training programs,
on and ofr sile. in Ihe rollowing areas:
technology including internet. parent
educalion in Spanish and English. special
education compliances. site-based man.
agement. portfolio assessment and stand.
ards. In addition. our school and slaff
have been represented al the sl.lIe lan-
guage Arts Convention. the California
Slale Reading Associalion Convention.
Ihe annual f\ssocialion lor the Gifted con-
ference. the Nalional Science Teachers
School Accountability Rcpon Curd
..oeinlion. lhe Malh Conference, and
olher districl workshops and conrerences.
Eighl leachers nre alien ding sessions 10
enhnnce Iheir insln,clional skills wilh 5Iu-
denls who arc learning English. Paraedu-
eators continue 10 bt trained in areas.
including disaster preparedness. lan-
guage arts instruclion. piny ground super-
vision und games rule,. and hcahh issues,
Each lime 5Ial'fallend special workshops
and/or confcrcncclIij thc) share informa-
tion with ,)lher ~1i1rr.
. CO\':-;SEI./:-;O A:-;() SI'I'I'I1RT
SER VICES
U'/"'tlllpptlrt dtl WI' tlfft"r ttllJt!"t.t"!
Studentllij al Sil\er Gilte receive it vitri-
CI~' ot'support \Cr\ ices from highly quali-
lied credemiatcd slalT who work aI Silver
Gate, These scr\' ices include:
. A districI counsclor IWO and one.halr
da).s a week and a guidance aide six
hours per dal
. One full-lime resource spedalisllo pro-
vide small group pull-oul service
. A music leacherlwo hall:days per week
. A nurse one oa)' per \\eek
. Two pnn'lime health aSSi5lanlS
. A rull-lime magnel resource leacher
. An adaplive physical educalion leacher
one session per week
. A full-lime physical educalion leacher
facililaling Ihe prep'lime progrnm
. A language. speech and hearing special-
ist two days per week
. A school ps~chologistoneda~ per week
. Two paraeduc~uor'i \\ ho coordinate the
librar'}' program
. An occupational therapist serving stu-
dents with special needs.
As in prcvious )ear5. \\c l1a\t: Sl:cn a
decrease in our support llijcrvil:es due to
Slate cuts in funding,
. TEXTBOOKS ASD
ISSTRL'CTlOSAL \IA TERIALS
JlIHf} 1.'lIrr~nt flU "liT maur;ull '!
Tht: district decides \\ hich textbooks
will be uscd and pro\ ides them to schools
accordin~ to cnrnlhncnt. "\ew Icxth,)oks in
~1 suhject area Jn~ JL!oplt~d ~\'er)' eight ~'ears ..
according to the "late textboo~ rl:\'iew cy-
~Ie, rhis ~'ear schools will use newl)'
adopled le.\lboo~s and malerials in heallh.
fhe '"Slnlcllonal program al Silver aale
llscsa variety ofrnalcrials in addiliontvtcxt-
REPORT CARD COMMITTEE
The lol/lII',.;nl{ p<lrentJ <lnd .ttc!!1 mn-
,,.ihll't!d in dl!\.t!/oping llrij Tt!port card:
Jur..: IJnlrndmf:,p""n'
Mark Ci1nllll,ltdchtr
OunnJ f)cll~JI.'r'JfJI"lr '1'''0'1",
Il.ub.ui1 ~ICln,{l'''h'I/,I''
C.lnnlC I'IJnl/.'..dd,..,
~1;Vlol "H1!tlf1.1nO,tnUMU"'If'No" ,IUI.II.m'
Slmlln I"llnr\,rm..n,
frJnl. \\"llIlr,ltlld,..,
buoks. ir,c1uding workbooks. enC)'c1ope-
Ilia>;. dictionaries. maps. charts. comput.
ers. calcuhllors. audiovisual e~uipmenl.
and resource malerials. In addilion. class-
rooms use core literature sets from our
districl instruclional media center. and
no,'el selS r,om our school library. Every
Sludent is provided with textbooks and
sullicienl suppon mnlerials.
All studenls have access to the Silver
Gale library at regularly scheduled class-
room visils and al recess. Our library is
Slacked with nearly 14,000 fiction and
non.ficlion books. Each year Ihrough par-
ents. Friends or Silver Gale, and PTA do-
nations Ihe inventory increases.
. SCHOOL FACILITIES AND
SAFETY
Ho... c1~an, sale, and o,d~,ly Is ou,
''''100/?
To promole student and slatT safety,
we review procedures for sludent emer-
gencies. fires. and disasters with Ihe Slaff.
parenlS, and studenls. Disaster supplies
are available in each room. There is a
problem wilh occasional nighttime and
weekend vandalism. grnmti. litter. and
misuse or propen)'.
. CLASS SIZE
.~,~ fOm~ 01 rh~ daJJ~J 100 la'g~'
Silver Gale Elementary's class sizes ror
the laslthree )eat'5 are sho"'n on p3~e".
Last year all dislrict studenlS in grndes
I and 1 parllcipaled in Ihe Slale's Clnss
Size Reduclion Progrnm. which in its lirsl
~ ear \\3S limited 10 grades I and ~,
We believe we could do a better job of
cducating sludenlS if our class enroll-
mcnls in grades 4. S. and 6 were lower.
Current elTons 10 reduce leacher-Io-stu-
den I ralios include regrouping. deploy-
ment. peer conching. and tutoring.
SILVER GATE ELEMENTARY
5
IN;f,EGRATION AND 0'- 'ERSITY
. RACE ..\ND HUMAN RELA TlONS
Do s,udm/J 8" along .../,11 .a~II
o,",,?
Over H percent of our studenlS live
outside the residential area of the school.
Our students are from varied elhnic back.
grounds and are all part of the Silver Gate
family. Part of our emphasis is 10 help
children de, clop an appreciation and an
understanding of the diversily of back.
grounds of others. Classroom teachers in.
volve children in multicultural activilies
such as I:omparati\.'c literature analysis.
. CO~I~lliNITY 1:O;\'OI.\'DIE:O;T
SHARED DECISION-MAKING
Dfll!.t SIf,'er GIlII! K'e/t'm"L' pllrelll
Ilnll L'ommlllllty In",,/l'effltllt'l
Our PT.-\'s volunleer hours and fund.
raising have enhanced the ,chool wilh en-
richment programs. technological
malerials and equipment. field trips.
classroom and Eco Lab support, and
more. Some activities include: Bimonthly
newsletter. Book E.,change. Reading In-
centi\'c program. Silent t\uetjon. and Arts
and Sciencef~lultlcultural Fair.
With money from the various fund
raisers. com pUlers and sound equlpmcnt
FINANCES
. EXPENDITURES AI'D SERVICES
OFFERED
WI..,. dllts /. all go?
The adjoining budget chart sh",,, the
major areas of district funding for Silver
Gate Elementan' and olher district
schools. It includ;, all monies budceted
from the general fund e.scept those for
transportation. maintenance and opera.
lions. and district administration.
Each school receives ;10 instructional
bud.et based on enroll men I and pro-
llr3ms and on formulas set b,,' Board of
Education polic)', state law, ;grccments
\\"ith emplo~'ee bargaining units. and
guideJin~s of outside funding agencies.
6
h..\~ h~1.'n pur..:hascd. n schnol directory
hilS bCt'1l crcated. schnol\\'ide assemblies
IH1\C been financcd. and donations to
dilS'iroolT1S ha\'c been made.
t\cti\'jtic'i involving the community
include our long-slanding partnership
with the I'av)' fleet Combat Training
Center Pacilie (FCTCPAC) and slUdenl
leachers from local universities. The
~lidwa) ~IcDonald's restaurant supports
,chool acti"ilies by providing food.
drinks and studenl incentives.
The San Dle~o POrl OistricI, Union
Bank. the Natu;e Company. and Good
School Budget, 1996-97
c~::i;t;~~E;~,~ ';.~! .i~.~~
Bul:llMt~MIIll . :!Sjl
GeneralOperalions 2,582 2,615
SpeCial Education 246 415
Integration 432 183
Gifted and T alenled 122 20
SpeCJal Proje~~s___.._, _ J01__oo_ '!.?!L
Total 3.483 3.661
Gene,al Operiitio;;;":'5eNlCes~nlatenals, and
support to the general education program
Special Education-programs offenng stu-
dents With speCIal needs appropnate. IndIVIdu-
alized educatIon
Integration-the dIStriCt's volunlary integrahon
effort to counter the rnoaVethOlc ISolation of puells
Gifted and Talented-specialized learning as.
slstance for students With great abIlity. aChIeve-
ment. or potential
Special Projects-monles from agencies (e.g..
federal statel earmar1led for specific services
. Based on Iota I student enrollment
SIL VER GATE ELEMENTARY
..
'.
"
culture simulalion" music and art history
projecl', and re,earch reports. As a resull
of everyone', efTorts, the atmo'phere on
campus i, generally harmonious.
We continue to InveSligate way' 10 in-
crease parent participation.
E8rt~ support the: environmental science
focus of ollr magnel program.
The Friends of Silver Gate i, a non-
profil corpotation compri,ed of con-
cerned parents and teachers whose goal is
to support our Eco lab and academic pro-
grams Ihrough fund-raising.
The Silver Gate Sehool Site Coun-
cil/Sit. Governance Team (SSC/SGT) Is
one shared decision making body. This
team of parents, teachers, stafT and prin-
cipal form the vision and direction for
Silver Gate. The SSe/SGT meelings are
open 10 the public. Staff and community
involvement is encouraged.
Salary and Budget Data,
Teache~ and AdministratD~,
1995-96
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Percentage of general fund expendItures Does
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.
S~hool A~~ountability Report Card
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STATE L1CENSEO
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OUf Mission Statement
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-The Peninsula Family YMCA is 1
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dedicated to improving the quality of
human life and to helping all people j
realize their fullest potential ,)
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through development of the )
spirit. mind and body. - PLAINTIFF'S I
I ')
I EXHIBIT I
Volunteers: I
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A Big Part of the i
Peninsula Family YMCA k.. l
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As a YMCA Volunteer you could: I \
(
. Instill the values of fair play al a I I
coach counselor. I
. Help youngsters learn to swim.
. Tell the YMCA story in the Annual Sustaining
Campaign and much more.
. Volunteers are at the very heart of the YMCA I
Movement. Throughout the YMCA's history t
we have relied on lay persons of the commu-
nity to serve In many capacities: !r~ cS: \~~
. Administrative policy making ,
. Program Services 3:1 '" ~ I,
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. Fund Raising z"_~g,
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. Creative!Technical ~~ 'Iil Q :t
. Camping/Caravan Leadership , \ ,
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1Inion.!tibufLC.
COPLEY NEWBPAPERf,
Aug. 15/ 1998
Dear Sir:
When Michael Stetz interviewed with the Union-Tribune last sum~er/ we saw
him as a talented writer and reporter whose addition to our staff, we
hoped, would help us in our quesc Co become the besc regional n~wspaper
in America.
He was excited about the job and the life he expected to build here with
his family.
A companywide award he received this week for "journalistic excellence/I
and the positive response of readers to his work over the past 10 month~
echo our confidence in his future.
Beyond that, we/ve come to know Michael as a thoughtful and considerate
colleague.
As a general assignment reporter/ Michael/s schedule is Monday-Friday,
9 a.m. to 5:30 p.m. On a rotation of seven weeks, he draws a weekend shift,
for which he can plan well in advance.
Ours is a newsroom full ot parents, many of them wich children close in age
to Michael's daughter. It is important to us that our staff have full home
lives. We work with them to adjust schedules when possible and to
accommodate needs related to their families.
I hope this letter answers your questions. If it does not, I would be happy
to speak with you by telephone. You can reach me by dialing 619-293-1215.
Please ask my assistant to find me if I am not at my desk.
Ellen Bevier
Metro Editor
3&0 CAM1NO DE LA REINA.
po. DOX 101. SAN DIEoa, CALIFORNIA 92112...108
TELEPHONE 619.0199.3131
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MICHAEL STETZ,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
LAURA M. STETZ,
Defendant/Respondent
NO. 98-1104 CIVIL TERM
ORDER OF COURT
AND NOW, this 25th day of November, 1998, after
hearing, the Court sees no reason to change its order of August
21st, 1998, except as follows:
1. Both parents shall, within three months of
today's date, complete a seminar for separating families.
Mother is directed to attend the PACES seminar in Dauphin
County. Father is directed to attend a similar seminar in San
Diego or, if he's in the area, he can certainly attend the
Dauphin county seminar.
2. Mother's psychologist/psychiatrist is directed to
advise this Court immediately if mother misses an appointment
without explanation, terminates treatment, or is otherwise
deemed by the psychologist/psychiatrist to be a threat to the
child. A copy of said notification shall also go to Paige
Macdonald-Matthes, Esquire, counsel for father, and Barbara
Sumple-Sullivan, Esquire, counsel for mother.
In all other respects, the order of August 21st, 1998,
shall remain in full force and effect.
.
.}
I.AW OI'I'IUIlS
BARBARA SUMPLE-SULLIVAN
n411 1JIllllOll STIlIlIlT
Nllw GU~lIllml,^NIl, I'IlNlolSYINA1I/IA 17070-11101
]JUONU (717) 774.144n
}tAX (717) 774"7onU
:'1
February 10, 1999
The Honorable Edward Guido
Cumber/and Counly Courthouse
1 Courthouse Square
Carlisle, PA 17013
J. t:r
61" (
re: Stetz v. Stetz
No. 98-1104 Civil Term
Dear Judge Guido:
Enclosed please find Ms. Matthews' original certificate ofcoml11etion of the parenting course
pursuant to your Order dated November 25, 1998. /
/
. /'
Very tru!l:'You ;::'
'-2
~rbara Sumple-Sullivan
\0,
BSS/lw
Enclosure
cc: Paige Macdonald Mathes, Esquire (w/enclosure)
Laura Matthews
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1 (Whereupon, the testimony of Brian Freeman
2 appears as follows:)
3 MS. SUMPLE-SULLIVAN: Brian,
4 Whereupon,
5 BRIAN FREEMAN
6 having been duly sworn, testified as follows:
7 DIRECT EXAMINATION
8 BY MS, SUMPLE-SULLIVAN:
9 Q Sir, you're acquainted with --
10 MS. MACDONALD-MATTHES: Your Honor, may I ask
11 who this witness is?
12 MS. SUMPLE-SULLIVAN: Your Honor, I need to
13 just set a little precedence before I ask him a specific
14 name.
15 THE COURT: That/s fine. Go ahead.
16 BY MS. SUMPLE-SULLIVAN:
17 Q Sir, you are acquainted with Ms. Matthews
18 through Alcoholics Anonymous, is that correct?
19 A That is correct.
20 Q And you were known to her as Brian, is that
21 correct?
22 A That is correct.
23 Q You are testifying before the Court today and
24 is it your intention to waive your anonymity as part of
25 Alcoholics Anonymous?
2
,
1 A Yes, I do,
2 Q Sir, can YOll stclte your full name?
3 A My name Is Brian Freeman, My address is 435
4 Big Spring noad in New Cumberland,
5 Q And, Mr, Freeman, you're a public personality
6 in tho Centrol Pennsylvania area, is that correct?
7 A Yes, I am, ma'am,
8 Q And you currently work for Channel 8?
9 A I'm part-time with Channel 8, I'm actually
10 retired,
11 Q Okay. Again, I'm going to ask you questions
12 about how you got to know Ms. Matthews and your contact with
13 Ms, Matthews since that time period. When was the first
14 time -- contact that you had with Ms. Matthews?
15 A My first contact was at the Hershey
16 outpatient counseling which I was attending following my 28
17 days of rehab at the Caron Foundation.
18 Q Okay,
19 A It would have been in July of '97.
20 Q And this was the same Hershey lOP, which, in
21 fact, Ms, Matthews was attending?
22 A 'I'hat' s correct. I was attending the
23 outpatient therapy while part of the time period she was
24 attending the outpatient education, two separate parts that
25 were held in the same wing, so I had -- my contact with her
3
1 was late July though she was already there. She was in the
2 education part, and I was in the therapy, and then she came
3 into the aftercare is what it's actually called.
4
Q
And after you or after she left Hershey in or
5 about October of 1997, did you have contacts with her beyond
6 the Hershey group?
7
A
Yes, I did.
8
Q
And what was the nature of the contacts that
9 you had with her during that time period?
10
A
Two-fold. I would see her at meetings. We
11 had phone contact. Part of the support for each other, part
12 of recovery is having a support group for individuals and
13 dealing with issues and twelve stepping as we call it,
14
Q
Can you just describe briefly for the Judge
15 what the twelve stepping process is?
16
A
Twelve steps basically are the ways of life
17 for a recovering addict or alcoholic, It is very
18 spiritually based; in fact, the first three steps deal with
19 God. Admitting that we are powerless over alcohol; turning
20 our will and our lives over to God; and living our lives
22
That's the first three. Then it becomes a set up
'1
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under God's will instead of our own.
23
and action process, taking daily inventory, asking for
24
forgiveness from the higher power, whatever the person
25 chooses the higher power to be, making amends with
4
~I
,
1 individual", continuing the process and continuing to
2 moditato and pray on a spiritual basis,
3 Mony coli it very religious because it's actually
~ very opiritunl in yourself to become a different person than
5 we woro when wo wore drinking,
6
o
Now, when you go through these processes --
'I and you indicated that you knew Ms. Matthews from the lOP
B did you know that she never complete,;. the Hershey lOP?
9
A
I was aware of that,
10
o
And were you in contact with her at that time
11 frame?
12
A
Yes, I was,
13
o
And what did you understand the issues were
1~ that stopped her from finishing the lOP?
15
A
Primarily, not in any set order, but I know
16 what was important to her was caring for her daughter
17 because of her new job position that she had. She wanted to
18 make sure she was there for Gab. She also had to sell a
19
house, relocate, find individuals to watch Gab while she
I.
: I
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20
worked, which was quite a burden I'm sure.
21
0 Now, even though she had not completed the
Hershey lOP, to your knowledge was she involved with AA
during that time period?
A Most certainly.
0 And did you have contacts with her as on --
22
23
2~
25
"
5
~.,
, let me 'trike that, With what ba'i, or what timiog did yoo
2 have Contact with her?
3 A Well, OUr Contact started at IOP, She left
4 the outpatient early, but she completed her education
5 proee" a, I did at rehab, That wa, her rehab proee,s, Oor
' Contact was by telephone, I OCca'ionally WOold see her at a
7 meeting but mainly by telephone, and it only takes two
' people who don't have to be face to face to have a meeting,
9 Q Now, again, the idea of attendance and
10 tracking attendance at AA meetings, how many meetings are
" oCCorring for aleohalica throoghaot the Central Penn'Ylvania
12 area?
13 A In a given day, exclUding Sundays, Your
14 Weekly and Your Saturdays, you have a litany of 20, 25
'5 meeting, in what i, called the Harri,burg/Car'i"eIHershey
16 system, They happen allover the place at all kinds of
17 times of the day and night.
18 Q So as far as actually seeing a person on a
'9 regular basi, at a meeting, that generally i, not oCCorring,
20 A It's pretty rare with the eXCeption if YOo
21 have individuals who always go to, let's say, a 7:00
22 ,eeting, and that i, their home meetiog at their home groop,
23 that's the place you go the most or sign up as a home
24 member.
25 I'll go weeks without seeing Somebody and in
6
1 general discussion without blowing what they say, they'll
2 indicate they tried this meeting or that meeting over here
3 or over there, There are so many meetings and variables in
4 the community of people that are involved, I can miss
5 someone for months but they are still in the program.
6 Q But with your contact with Ms. Matthews from
7 basically Hershey to the present, is that correct?
8 A Yes.
9 Q Did you understand her to be attending
10 meetings regularly?
11 A Most generally because she was in contact
12 with me. Again, it's not a physical thing, but we had
13 telephone contact with other recovering individuals in a
14 meeting. It only takes two to have a meeting. You don't
15 have to walk into a building. I'm in AA. You don't have to
16 read from the big book. If you're dealing with the issues
17 and you're talking about sobriety and talking about
18 recovery, that's a meeting.
19 Q Part of this recovery and sobriety issue that
20 I understand comes -- part of this alcohol rehabilitation
21 issue--
22 A Urn-hum.
23 Q are understanding and dealing with
24 triggers, is that correct?
25 A That's correct.
7
1
Q
And did you define basically whether or not
2 Ms, Matthews made efforts to identify what her triggers
3 were?
4
MS. MACDONALD-MATTHES: Your Honor, I'm going
5 to object to this witness's foundation to answer the
6 question. I don't think that he is qualified to know what
7 her triggers are. He's not a psychologist, He doesn't know
8 anything. He hasn't testified that he knows or has had
9 conversations with Ms. Stetz concerning her background. I
10 don't think that this witness is qualified to answer that
11 question.
12
THE COURT: I'm going to let it go as her AA
13 partner. Overrule the objection. I'll give it whatever
14 weight it's worth,
15
THE WITNESS: Would you repeat the question,
16 again, please.
17 BY MS. SUMPLE-SULLIVAN:
18
Q
In your contacts with her in being mutually
19 and jointly involved with AA, was there discussion and
20
efforts by Ms. Matthews to determine what her triggers were?
21
A Most certainly. Though it was never stated,
~~
.1 (
22 I consider that once we were both -- the time period when we
23 left at our different times -- left outpatient even at
24 Hershey up to fairly recently, I was her temporary sponsor,
25 and there was a tremendous amount of sharing that goes on as
8
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part of the healing process, fifth stepping if you will,
taking a personal inventory of where your problems are and
your triggers. She identified a number of those and was
very in touch with those,
Q At any time in that process, to your
knowledge, and within the therapy that you attended with
her, had anyone -- and again if you know -- actually
diagnosed her
MS. MACDONALD-MATTHES: Objection, Your
Honor.
THE COURT: Sustained.
MS. SUMPLE-SULLIVAN:
psychiatric care?
THE COURT: Objection sustained.
BY MS. SUMPLE-SULLIVAN:
in need of
Q Can you describe, Mr. Freeman, as far as how
she was dealing with the triggers that were occurring for
her?
A Having dealt with triggers myself, which are
part of your everyday recovery, she had a load of triggers
on her that would have -- to someone who had not continued
in the program, it would have set someone off.
Q Okay.
A And I told her on many occasions that
Q Can you describe some of these things that
9
1 you and she talked about that were of conflict?
2
A
Well, I mentioned some of them earlier and
3 more a pile on situation of selling a home, packing up,
4 moving, finding a new place to live, having a new job, being
5 a single parent responsible for a little one. I have two
6 girls, so I know how that can be.
11
You hear it in the rooms, and she dealt with all
7 And in the first year of recovery, there are to be
8 no major changes. That's an unwritten, but it's a restated
9 rule over and over again. I heard it at the Caron
10 Foundation, I heard it at Hershey.
12 of those in a logical and very, very good order. She called
13
me when she was having
and I don't want to say trouble.
/
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She would call me when she was feeling the pressure, and she
worked through those pressures.
!
15
16
Q
Do you think that she can identify problems
17 in her life that would need to have a contact with you or
18 with another therapist?
19
MS. MACDONALD-MATTHES: I'm going to object
20
to that question. I again don't think that this witness is
~
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21
qualified. He's not a psychotherapist. He's not a
22
therapist of any kind.
THE COURT: Understood. Objection overruled.
23
24 I'll take it for what it's worth. Again, please?
25 BY MS. SUMPLE-SULLIVAN:
10
,
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~
1
Do you think in your -- with your months of
Q
2 contacts with her, that she has developed the ability to
3 recognize stress sourc~s that allow her or require her to
4 seek out assistance from the AA group?
5
In my opinion, yes, she has through
A
6 outpatient and in the meetings in the rooms, as we call
7 them. The tools are given to you. The rooms are the tool
8 box, and she has embraced that tool box and uses it. One of
9 the big tools is picking up the telephone and calling your
10 sponsor, and Laura has never been afraid to call,
11
In your opinion or in your conversations with
Q
12 her, has she ever denied alcohol as a problem in her life?
13
No, she's very aware that alcohol -- that she
A
14 is an alcoholic in recovery.
15
Have you had contact with Mr. Stetz as part
Q
16 of the alcohol treatment program?
17
Only one time. He attended a meeting. My
A
18 wife, myself, Laura, and Mike went to a meeting together.
19
In the course of your contact with Ms.
Q
20
Matthews, did she express any concerns about involvement
with Mr. Stetz as a potential trigger?
A There was one case that I remember very
clearly. We were at Hershey in group. Laura was -- as we
say, we have good and bad days. A bad day doesn't mean
you're going to drink, it's just dealing with life -- where,
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according to her -- we call it, the agenda, mood meetings,
Mike, according to Laura, had gone out/ purchased
beer, and brought it back to the house, It was late one
night, and she shared that in group,
o Has she acknowledged slips to you since
completion of the Hershey --
MS. MACDONALD-MATTHES: Objection. She has
not completed -- it's a mischaracteriz?i:ion of --
BY MS. SUMPLE-SULLIVAN:
o Since her termination of the Hershey
treatment?
A She admitted to the group a slip, which was a
very brave thing to do. It's very tough. The rule in the
room, in the lOP, was if you slip, tell us. Admit it. And
I can clearly remember the night that she came in. She was
extremely upset, in tears, in fact, and admitted to the
group she had slipped. She got complete support of that
group for doing that. It was a very brave thing to do.
o As far as slips in early recovery, can you
explain what happens as a result -- what the education of AA
on a slip is as part of the growth process?
A A slip is not a relapse. A relapse is going
back out/ staying out, as we say/ and continuing to drink.
A slip, as I see it and as it's generally in the rooms is a
plateau process of becoming better.
12
1
Some call it experimenting, Let's se~ if you can
2 go out and have another drink, and the slip is a good
3 educator to learn that you're an alcoholic, and, yes, you're
4 going to have to stay in AA the rest of your life, You
5 can't drink again or you'll lose everything.
6
Q
When you say 1013e everything, what does that
7 mean?
8
A
Lose everything. For me, I would lose my two
9 lovely children, my lovely wife, all the material things.
10 They don't mean a lot anymore to me, but also lose my life.
11 I go back out, I'll in a sense die at some point, I'll kill
12 myself either through addiction or just something else.
13 It's everything.
14
Q
In discussing with Ms. Matthews, you know,
15 the AA issues, did you understand that she was participating
16 in AA solely as a result of a threatened custody action
17 against her?
18
A
No. No. She's in AA for herself and for
19 Gab. Mainly, I mean, primarily for herself.
20
Q
And when you say for Gab, are you talking
21
about to retain custody or simply as the child's mother?
,
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22
A
Exactly what I said before about losing
23 everything. If -- for this alcoholic, I have to remain in
24 AA to stay sober so that I'm a better person for my kids,
25 for my children. for my friends, and for myself. It has
13
r,
1 nothing to do with motives for custody, This -- we talked
2 about this a long time,
3 Q Have you found, in your contact with her, to
4 be resistent to any of the counseling that's done by AA or
5 through your relationship with her as
6 A If I might, there's no counseling done in AA.
7 It is a program that -- she's been very, very open to it,
8 counseling on a one-to-one basis and the interpretation of
9 two addicts having or two alcoholics having a meeting
10 together.
11 She's very open to suggestions I have, and I can
12 only share my strengths, hope, and experience with her, and
13 it helps me to center her on staying sober. Likewise, she's
14 in the same boat. Counseling in AA doesn't occur, and, in
15 fact, if I might, 95 percent of the people in AA have never
16 been to a rehab, have never had outpatient, and do not go to
17 counseling for anything else, and they're sober up to 40 --
18 45 years they remain sober.
19 It's not a prerequisite and it's not necessary in
20 this alcoholic'S opinion that you need any type of
21 counseling. You've got it in an hour meeting seven days a
22 week or whatever you choose to do, whatever you feel is
23 best.
24 Q Have you h~d an opportunity to observe Ms.
25 Matthews with Gab?
14
1
A
Yes, I have,
2
Q
And can you describe for the Court what you
3 see?
4
A
I see a very loving mother, a wonderful
my girls are three and eight, and, in fact,
5
child, I had
6 Gab was over with Ms. Matthews one evening, and Gab played
7 with them. That kid is lovely, brilliant, smart, just a
8 great kid. She reminds me of mine.
9 Q Based on your constant contact with Ms.
10 Matthews, would you have known if she had slipped?
11
A
Yes.
12
Q
And to your knowledge, other than the time
13 periods that have been testified here, November of '97, have
14 you ever noticed any slip from her?
15
A
I was an alcoholic for fourteen years, and it
16 takes one to know one. And in the time period that I have
17 known her, there are changes that would occur, primarily
18
isolation, lack of communication, general demeanor that
,
, .
19 would occur, and they are tell tale. In the communication
20 process she calls me or I call her, and I would be able to
22
Q And do you or have you ever detected a slip
. .
1
II
"
21
know in an instant just because I'm an alcoholic.
23 from her?
24
A
Other than the one she admitted in
25 counseling, no.
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MS, SUMPLE-SULLIVAN: I have no further
questions, Your Honor,
THE COURT: Cross-examine.
CROSS-EXAMINATION
BY MS. MACDONALD-MATTHES:
Q Mr. Freeman, you indicate and you've
testified before this Court that you are her sponsor at AA?
A No, ma'am. I testified I considered myself
her temporary sponsor. It was never stated between the two
of us.
Q Are you aware that she told the psychologist
that she had no sponsor?
A I could believe that.
Q And are you aware that she denied the need to
seek treatment during the course of her evaluation with the
psychologist?
A I don't understand the question, ma'am.
Q Well, are you aware that Ms. Matthews or Ms.
Stetz-Matthews did not believe that she needed treatment and
revealed the same to the psychologist who testified in this
proceeding?
A I heard that testimony.
Q Well, let me ask you. You said that your
first contact with Ms. Stetz was at the rop program at
Hershey?
16
1 A Correct.
2 Q And that was following a 28-day period that
3 you spent at the Caron Foundation?
4 A That's correct, ma'am.
5 Q Now, correct me if I'm wrong, but with any
6 intensive therapy or treatment for addiction problems, there
7 is a strong recommendation that that treatment, intensive
8 treatment program be followed up with a specific number or
9 specific time amount of attendance at AA meetings in
10 addition to other treatment, is that not correct?
11 A Each out -- each, excuse me, each facility
12 like Caron Foundation has a different pattern or rule in the
13 trueness of that, and it is also based on the individual's
14 need.
15 Q Well, let's talk about Hershey. What was
16 Hershey's policy with regard to follow-up after completion
17 of the lOP program there?
18 A I have no idea, ma'am, because I went to
19 Caron Foundation. Hershey was my outpatient. It wasn't my
20 primary education like she had an outpatient.
21 Q Now, you made a distinction between therapy
22 and education. I believe when you were testifying on
23 direct, you said that she was in the education part and you
24 were in the therapy part?
25 A At my entry into the Hershey facility -- I
17
1 left Caron Foundation on July 8th and shortly thereafter
2 went into the outpatient at Hershey, I did not see Laura
3 for a couple of weeks because she was in the education
4 meetings or classes,
5 Q Tell me the difference between therapy and
6 education,
7 A The education for -- as I understood it
8 from Hershey, Laura was in the education side, which I had
9 at Caron Foundation. The aftercare for her education and
10 for my Caron Foundation was the outpatient therapy that
11 occurred.
12 Q But what's the difference between the therapy
13 and the education part?
14 A The education is what I had at Caron
15 Foundation.
16 Q But what is it?
17 A Intensive learning, getting the basics of why
18 you drink, helping you to understand that you have a
19 hereditary disease. I did not attend the education at
20 Hershey, so I can't tell you how much of a difference it is
21 from Caron Foundation.
22 There are lectures. There are medical back-ups.
23 There's a spiritual side, and speaking from the Caron side
24 at least, it's multi-faceted and it's also intertwined with
25 group sessions.
18
1 Q Are you aware that during the course of time
2 that Ms. Stetz was participating in the lOP Program at
3 lIer:'lhey, she had more than one slip?
4 A I only know of one, ma'am.
5 Q So she never shared those slips with you?
6 A I only know the existence of one, ma'am.
7 Q Now, isn't it true that AA provides a number
8 of support features for its members including, but not
9 limited to, babysitting services if one wants to go to a
10 meeting?
11 A There are absolutely, positively no
12 babysitting services in the Harrisburg/Carlisle/Lebanon area
13 that I'm aware of. In fact, the South 18th Street AA
14 doesn't allow children except for one-half hour before and
15 one-half hour after a meeting.
16 Q Do you think that the reason -- do you think
17 it's a valid reason not to seek or participate in an AA
18 meeting because you were too busy with work? Would you
19 think that is a valid reason?
20 A Rephrase that or state that again if you
21 would, please.
22 Q As a recovering alcoholic -- I don't know
23 what your addiction is, but that's not the issue here.
24 Let's say that you're an alcoholic. As a recovering
25 alcoholic, should that be your primary concern, the
19
1 recovery, the continued recovery process? Is that the
2 primary concern in your life?
3 A It's a primary concern to me, staying clean
4 and sober, yes, ma'am.
5 Q Do you think it's more important to seek an
6 AA meeting than it is to go and participate at a work out
7 session at a gym?
8 A Part of my recovery --
9 Q I'm not asking about your recovery, sir.
10 A Well, it does deal with that, ma'am, if I
11 might, It's exercise for the mind. It's very important
12 and also attending the meetings when you can,
13 Q So you think it's important to do both in
14 conjunction with one another?
15 A In conjunction with what again?
16 Q The exercising and the -- I believe you
17 said -- and going to the meetings. To do things in
18 conjunction with one another?
19 A I believe so.
20 Q But exercising doesn't take the place of
21 going to AA and AA doesn't take the place of exercising?
22 A No, they are mutually exclusive.
23 Q So to say that I'm going to go and exercise
24 and that's my therapy for the day, that's not enough for a
25 recovering alcoholic?
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A It might not be for you, ma'am,
o Well, I'm not an alcoholic, but we're not
talking about me. I'm asking as an alcoholic here, it's not
sufficient.
A That's not what -- AA intervention is that
you can choose from Column A, You can either go work out
today or go to a meeting, but by God you've got the
treatment you need. AA does not dictate going to a meeting
every day.
o Well, how often should a recovering alcoholic
go to a meeting?
A When they need to.
o So it's an on and off thing?
A It's not on and off. You stick with the
program, and you're not drinking. There is no set rule how
many meetings you go to, and there's no such thing as
membership though it's called that. There's no card.
o Now, I believe you testified on direct that
AA is not counseling?
A AA is a program of recovering that, as far as
this alcoholic is concerned, helps me to stay clean and
sober and helps me in dealing with life.
o But your words on direct were AA is not
counseling.
A It's not counseling.
21
1 airing their demons, is that correct?
2
A
That's great treatment for this alcoholic,
3
Q
But it's not psychotherapy?
It's not psychotherapy.
4
A
5
Q
Now, you talked about one of the basic tenets
6 or one of the basic beliefs of Alcoholics Anonymous is that
7 major changes are bad in the first year of recovery or is
10
11
Would you consider divorce to be a major
12
13
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I
I would if it were filed against me, yes.
14
That's not what I asked you, sir. Is
18 extramarital affair is a major decision?
19
A I don't know.
20
Q Do you think a decision to drop out of
21
treatment before completion of a treatment program is a
22
major change?
23
A No.
24
Q
You don't think that is a major change?
25
A
No.
23
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, .
1
Q
Why is that significant not to drop out of
3 major change?
2 a decision to drop out of treatment prematurely is not a
4
A
Because she continued her treatment in AA
5 meetings and by dealing and working with other people who
6 are alcoholics,
7
Q
But she did not complete her IOP, the
8 treatment program at Hershey, did she?
9
10
11 today.
12
Ma'am, neither did I.
A
Q
Well, we're not talking about you, sir,
A
I understand that, ma'am.
13 Q Now, you said that it takes an alcoholic to
14 know one. I believe that those were your words.
15
16
17
18
A
Takes a
I said alcoholic, yes, ma'am.
Q
I don't want to put words in your mouth.
J
,
,
A
Takes an alcoholic to know one.
Q
As an alcoholic, do you know when another
alcoholic has had a slip?
A It's very easy to tell.
Q So if it's very easy to tell, then you would
have known about the fact that she had a slip in September
19
20
21
22
23 of 1997?
24
25
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A
That's the one she admitted, yes, ma'am.
Q
And you would have known about the slip she
24
I I
I~
1 had in at her husband's going away party when she drunk
2 wine?
3 A I wus uware of that one.
4 Q So u slip --
5 A And if you want to split hairs, I was aware
6 of that, yes. I didn't consider that a slip.
7 Q You didn't consider that, as an alcoholic --
8 A She shouldn't drink period,
9 Q;' SO it was a slip?
10 A It was a slip.
11 Q And what about in November when she covered a
12 story at Purdue?
13 A I'm sorry?
14 Q Were you aware of her slip n November?
15 A I missed what you said prior to that, ma'am.
16 Q While she was covering a story in Purdue,
17 were you aware of her slip?
18 A No.
19 Q And were you aware that she admitted both
20 during her evaluation in this process that she did have a
21 slip in November?
22 A I was not aware of that one.
23 Q So you had this direct contact and you would
24 know if she had the slips, but you didn't know of those
25 other slips now that I've mentioned it?
25
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A She had a female sponsor during that time
period, and I did not have as much contact with her. It was
maybe once or twice a month, And in December -- and from
December on the contacts increased, so there would be a time
period where I would not have had contact with her in
November, and, in fact, also I was on vacation during two
weeks in November that I would not have had contact with
her,
Q But did she discuss her slips with you when
you returned?
A It was -- it wasn't brought up. It wasn't
part of fifth stepping.
Q At that --
THE COURT: I'm sorry?
THE WITNESS: It was not part of fifth
stepping at that point, taking our personal inventory. An
alcoholic, if I might, and in AA, we deal with now.
Yesterday is history. Tomorrow is a mystery. We deal with
today and how the person is today and what issues that
individual has today.
Are you in a position to drink. Are you having a
problem today. Do you have the urge to go out. Is there a
trigger to want to make you go out. So reviewing and taking
her inventory for past events is not for a temporary sponsor
to do. It is for a full-time sponsor or for initiating
26
.
1 meetings,
2 BY MS, MACDONALD-MATTHES:
3 Q Now, you said that you had this close contact
4 with Ms, Stetz for a period of time beginning in September
5 of 1997 to present, right?
6 A Well, actually started prior to that in terms
7 of the lOP and continued on, yes,
8 Q Okay. Do you know then why Ms. Stetz
9 wouldn't have discussed the fact that she had maybe not a
10 formal sponsor but that you were for all intents and
11 purposes a sponsor? Why wouldn't she have mentioned that
12 during the course of her psychological evaluation for her
13 custody?
14 A Maintaining another's anonymity in the
15 program is primary, and did I give her my permission to
16 bring myself into this.
17 Q She could have used just your first name,
18 though, sir.
19 A You're not even supposed to do that, ma'am.
20 When you see -- this is a quote from the room. What you see
21 here stays here. What you hear here stays here. And even
22 individuals that I see in the meetings, I can't go home and
23 tell my wife that I saw so and so.
24 Q Well, let's assume that that's the case. Why
25 would you think that she wouldn't mention that she had
27
1 although not a formal sponsor, a quasi sponsor, for all
2 intents and purposes a sponsor?
3 Why wouldn't you think she would have mentioned
4 that during the custody evaluation? Don't you think that
5 that would have been important to mention, and, as a matt~r
6 of fact, denied that she had that support system? Why would
7 she do that if, in fact, she had you during that time?
8
A
I have no idea, ma'am. I'm not her.
9
Q
As an alcoholic and a recovering alcoholic
10
A
Thank you.
11
Q
-- and the desire to continue in your
12 recovery, your desire is -- your desire to stop drinking,
13 for you your desire is to stop drinking? It's your
14
decision, is it not?
\
,
I
15
A
The decision to stop drinking? I can never
l
,
16
drink again.
17
Q
I understand that that's driven -- you made
18 that decision yourself as an alcoholic, correct?
19
A
No.
20
Q
You didn't make the decision?
21
A No, I was out of control and my wife held an
. .
~
,
!
22
intervention. I didn't realize how far I had gone. The
23 lying, the cheating, the abuse that occurred. I was an --
24 mental insanity had set in and thank God my caring, loving
25 wife held the intervention. I was sent away to Caron
28
~
~
,
1 Foundation, Today I look back and realize when I take my
2 fifth steps how nuts I was,
3
Q
You stopped drinking though for yourself, did
4 you not?
5
A
I'm sorry. I didn't hear you.
Your decision to stop drinking is for
6
Q
7 yourself?
8
THE COURT: Asked and answered, Move on to
9 another question.
10
MS. MACDONALD-MATTHES: I have no further
11 questions of this witness.
12 MS. SUMPLE-SULLIVAN: Nothing further, Your
13 Honor, \
,
I
14
THE COURT: Thank you, Mr. Freeman. You may
15
step down.
J
16
(Whereupon, the testimony of Brian Freeman
17
was concluded.)
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