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HomeMy WebLinkAbout98-02468 thllt upon FlIthcr's rclcasc Mothcl' would hllvc primary physical custody of thc child with FlIthcr having pcriods of partial custody, Thc partic!; would sharc Icgal custody oflhc child, including thc right to makc non-cmcrgcncy mcdiclll dccision, lill' thc child, On Octohcr 26, 2005, this Court issucd an Ordcr that in cs.~cnl:c rcl1cctcd thc tcrms ofthc partics' Custody Agrccmcnt IInd StipullItion, Copics ofthc partics' Custody Agrccmcntand Stipulation and this Court's Ordcr ofOctobcr 26, 2005, arc attachcd as Exhibits "A" and "8" rcspr.ctivcly, and arc incorporatcd by rcll~rcncc hcrcin, 5, Whcn thr. child was Iivc ycars old, hc was diagnoscd with certain mcntal disordcrs, Thc child has reccived wide-rnnging trcatmcnts for thosc illncsses including hospitalization at Philhavcn BchavioralHealth Services, Ilc has bccn taking prcscribed mcdication to trcat his i1lncsscs sincc approximatcly agc five, 6, On Dcccmber 29, 2005, Dr, Mohammed Khan, M.D., and Sandra Abbey, CRNt', of Family Lifl: Servicc!;. Diakon Lutheran Social Ministrics, conductcd a psychological evaluation of thc child, Dr, Khan and Nursc Abbcy found that. thc child was "unable to maintain in the community" and rccommendcd that the child bc placcd in a rcsidcntial trcatment facility, 7,. The child was partially hospitalizcd at Pinnacle Health Bchavioral Scrviccs from January 30, 2006. to February 8. 2006, for the plll'pOSC of furthcr cvaluating his condition, Upon thc child's discharge, thc child's doctors at Pinnacle Health Bchavioral Serviccs recommcndcd that hc be placcd in a residcntial treatmcnt facility, 8, Thc child is schcdulcd to bcgin residcntial trcatmcnt at Philhavcn Bchaviol'lll Hcalthl'arc Scrvices on April 13, 2006, Trcatmcnt Icngth varics by paticnt but typically lasts II minimum of six months_ 9, On 01' about March 20, 2006, Fathcl' clllled Faith Bixlcr, Admissions Coordinator at Philhaven, indicating that hc docs not agrcc with thc child being placcd in rcsidcntial trcatmcnt at Philhavcn and will not conscnt to thc child's placcmcnt at thc facility, 10, Counscl for Philhavcn has informcd thc undcrsigncd counscl Il)r Mother that Philhavcll cannot acccptthc child I'm trcatmcnt (lVCr thc Father's objcction, givcn the current Order of sharcd leg.,1 custody, 11, Mother bclicvcs that Fathcr docs not havc a good-faith rcason to object to the child's placcmcnt in rcsidcntialtrcatmcnt at Philhavcn, 12, Mother bclievcs that if thc child is not plm:cd inrcsidential trcatment at Philhaven Behavioral Hcalthcarc SCl'viccs on Aprill3, 2006, he will have to wait at least six marc months beforc Philhavcn can admit him, 13, Mothcr bclicvcs and thcrcforc avcrs that it is in thc bcst intcrests of the child that Mothcr be grantcd solc Icgal custody of the child, pending further order of court, so that Mothcr can consent to the child's placcmcnt in residcntial treatment at Philhavcn Bchavioral Hcalthcarc Scrviccs over Father's objcction, 3. The parties listed above had previously been Involved In a custody action In reference to this child before this ~Ionorable Court. 4. Following a custody conciliation conference, the mother was granted primary physical custody with periods of partial custody to be given to the father. 5. Upon mutual consent, the partieS now believe that the best Interests and welfare of the child, Aaron Harbaugh, born on October 20, 1995, would best be served If primary physical and legal custody was with Michelle Louthlan, as Indicated by their !lignatures below from August 26, 2005, until February 21, 2006. 6. Following FebrualY 21, 2006, the parties desire the Mother to maintain primary physical custody of the child with Father to have partial custody of the child with a minimum of three hours per week and alternating weekends as mutually agreed between the parties, 7, Following February 21,2006, the Mother, Michelle Louthlan, and the Father, David Harbaugh, shall have shared legal custody of Aaron Harbaugh, born October 20, 1995. Each parent, following February 21, 2006, shall have an equal right, to be exerdsed Jointly with the other parent, to make all major non-emergency dedslons affecting the child's general well-being Including, but not limited to, all decisions regarding his health, education and religion. S, In the event Father works during his period of partial custody, he will contact mother to care for Aaron Harbaugh; alternatively, a mutually approved caretaker will be found by father to care for Ailron during Father's periods of partial clIstCldv- F:'lth,';i'1qi'l'p.'; 10 ,lllow i\:JrCiI1 tn p<lI'ticlpatp in imy nl~eded continlled prO\.lrarn ~lrf >- N (.:' ~;; c.-:J '~4 ,;-> .. ~, (-I' <" ~r:'.~ \1.1... <~; h~~-[~ ~,.,~ ; ..-{. C1~:" , C)t l~f;! to ., t _ CI~ C'..J ~ f~! r2W ('~ .~ ""l4 ;It :JC lJ... \,C) .. 0 I:~_' :':J (';.,':;) ,.... (.) t a I (: :(; c: r,~ -' .. , ,'1 CJ ..It "1 II I , '. ) ,', \ [" (.'-, ,,- t: :i" Ll.. ("I (', ,:;, fill, .l.lf\ , , ~d! I ';'H fij tJ.. , ."'. ! ::;,) [,I_ I ....J .,. lL. C~, :':,) () 0'\ I,) " development of the children's love or respect for the other party. 7. Defendant shall pay $393.98 for the repair to Plalntlfrs sliding glass door. 8. Defendant shall pay Plaintiff for the medical coSls associated with the treatment for Plaintiff's eye. 9. 11le Court Order entered in this lTlatter will be in effect for a period of one (I) year and can be extended beyond that time if the Court finds that the Defendant has committed an act of abuse or has engaged In a pattern that Indicates risks of harm to the petitioner. 111ls Court Order wlll be enforceable in the same manner as the Court's prior Temporary Protection Order entered in this case. 10. The Mechanlcsburg Police Department wlll be provided with a copy of this order by attorney for the Plaintiff and may enforce this order by arrest for Indirect criminai contempt without warrant upon probable cause that this order has been violated, whether or not the violation is committed in the presence of the police officer. III the event that an arrest is made under this section, the Defendant shall not be taken to jail but shall be taken without unnecessary delay before the court that issued the order. When that court Is unavailable, the Defendant shail be Iaken before the appropriate district justice. (23 P.S. fi6113). ~ r- ~ ,.:l .. gQ 9 ..) .:( 4')"" ~~ ~ t)~~:' , "I (,:);'~:'I ?,! 1"" ,,0 Ii. N 1/, Cc -;.' .1\,: _I :)g~ -.l F :::') :,; ~ ~ -) U ," > i ! D . j ~ i 'i ft~ ~~ ft~ ~ U ii U,' . ! ~! I'I II ~ ~I . . f 1~I~i II lil~ ~~I II Ii rfg'IIIBlml! ~rli5elli ! !rl lil~ " iil ~ ~ iiill'!i ~ ~ i ~ft I; 'I ri ! lip! !; . I ! dn I fP,hl1l if. 'I' f i ~d I ~ n ~Ii~i ~ ~ f " I I !g~ ~ ! I' 111111 I ~ ~ . .' i ~ 81~1i! g d HI,! r r ! I! I I~ ~ i I~~! i ~I ~I~i~~ ~ ~B I !;!~~!~f~! n! ~ ',~ ~ 12~ ~~lIlm Ir >-1 f ~"~H ~ ~ i Iii III li~ii ililld!j!ii!li.ll.!ill . .) '- '), (1'1 ,5 ~ .,t;;; 1 "-' .~ t <>i -" '" -0 l~f:, ..1' ;:-: ll"; . ~Ur; ~ f.l~) {, (i,; tL i~':' (~~, C, '.' C:. J'it." (0') 11.' \(! lV, rl..: (I ~b. 't' o Z{ f; :: i ,I,'J .',:;j' I t) ::~; ')"[J !PrJ.,. ~:'~ -'5 o J ~ ~ ~ ~ ~,S :::J 1 i?i ~ il ~>~ '... t:l g; g "' ~.~ 'Iil .... 5 ~ ~ .... '~ ~ ~ .. ~ ,D r i H :s ;S ~ ~ I- ,~ I! ~ < ~ ~ ~~ ~ Cii ~ ~ ~J 0.1 ~1 G . ~~ > ffi . 0< ! ~ !i ..1 ffl CIJ ,.. i z ~ d 0 ~ H ~ [-l H ~ ~g ):! .~ ~ Q // t< ',.-" ;; '" .' ~ - . . & ~PR 3 ~ 1998 8. The Defendant is believed to be employed al Consolidated Frcightways in Cllrlisle, Pennsylvanill. 9. The residence of the abused person (my residence) from which I am asking the Court to exclude the Defendant is owned in illY name, that being thl) nallle of Michelle L Louthian, and is located at 32 East Keller Street, Mechanicsburg, Pennsylvania 17055. I bought the property on or about September 28, 1996. 10. The facts of the most recent incidents of abuse are as follows: On April :W, 1998 at about 1000 a.m., David grabbed me in the arms and left bruises. He also kicked out the glass window in my sliding glass door. He did these things in front of our son, Aaron Harbaugh, date of birth, October 20, 1995. This occurred at illY home at 32 East Keller Street, Mechanicsburg, PA 17055. 11. The Defendant has physically abused me in the past. The following are some examples of recent and bad abuse of conduct: On Easter Sunday, April 12, 1998, at approximately 5:30 a.m., after an early morning of arguing and some other violence, David punched me in the eye, causing profuse bleeding and a black eye. My eye required four stitches, which I got that day at First Place Care Hospital, Mechanicsburg, P A Although the punch to the eye was not done in front of Aaron, some of the other violence and the yelling and the threats were done in front of our son, Aaron Harbaugh, and he also saw the bleeding afterwards. This was done while the Defendant was drunk, and the Defendant has a major and long standing drinking and marijuana problem; is on probation for DUI and is driving under a suspended operator's license, There hils been II long stllnding history of IIbuse IInd I hlld II PFA Order IIgainst David from October, 1996 until October, 1997, but we reconciled IInd startcd living togcthcr agllin, in approximatcly thc Summcr of 1997. 12. I, as the abuscd pcrson, am in immincnt danger of further abuse and lam afraid of Defendant. A Court Order is neccssary to protect me. 13. I believe that servicc cannot be safely effcctcd by an adult individual other than a .Iaw enforcemcnt oft1ccr such as thc Sherifl' of Cumberland County. 14. I ask for attorney fees and costs pursuant to the Protection From Abuse Act. 15. 1 have sufl'ered out-of-pocket losses as a result of the Defendant's abuse, namely the destruction of my sliding glass door to my house as aforesaid. In addition, David has taken some of my belongings and I would like to get them back. WHEREFORE, Plaintiffrequcsts that this Honorable Court to reward the following relief: A Grant a Temporary Order pursuant to the Protection From Abuse Act that orders the Defendant to stop abusing, harassing, threatening and/or stalking the abused and stop placing the abused in fear of abuse in any place where she may be found. In addition, prohibiting the Defendant from going back into the Plaintiff's home at 32 East Keller Street, Mechanicsburg, PA 17055. Prohibiting the Defendant from having any conduct with thc abused, including but not limited to restraining the Defendant from entering her place of employment, busincss, school or recreation of the abused person and from harassing the abused or the abused person's relatives. Granting temporary custody of the abused minor child, Aaron Harbaugh to the Plaintiff, Michelle L Louthian. ,/ ";0;....., f"", 8. The Defendant is believed to be employed at Consolidated Freightways in Carlisle, Pennsylvania, 9. The residence of the abused person (my residence) tTom which I am asking the Court to exclude the Detendant is owned in my name, that being the name of Michelle 1. Louthian, and is located at 32 East Keller Street, Mechanicsburg, Pennsylvania 17055. I bought the property on or about September 28, 1996. 10. The facts of the most recent incidents of abuse are as follows: On April 20, 1998 at about 10'00 a.m, David grabbed me il! the arms and left bruises. He also kicked out the glass window in my sliding glass door. He did these things in fi'ont of our son, Aaron Harbaugh, date of birth, October 20, 1995. This occurred at my home at 32 East Keller Street, ivlechanicsburg, PA 17055. I 1. The Defendant has physically abused me in the past The following are some examples o{i-ecent and bad abuse of conduct: On Easter Sunday, April 12, 1998, at approximately 5:30 a.m., after an early morning of arguing and some other violence, David '" punched me in the eye, causing profuse bleeding and a black eye. My eye required four stitches, which I got that day at First Place Care Hospital, Mechanicsburg, P A Although the punch to the eye was not done in front of Aaron, some of the other violence and the yelling and the threats were done in front of aliI' son, Aaron Harbaugh, and he also saw the bleeding afterwards. This was done while the Defendant was drunk, and the Defendant has a major and long standing drinking and marijuana problem; is on probation for DUl and is driving under a SUspended operator's license. \ t~'\ There has been a long standing history of abuse and I had a PF A Order against David tram October, 1996 until October, 1997, but we reconciled and started living together again, In approximately the Summer of 1997. 12. r, as the abused person, am in imminent danger offunher abuse and ram afruid of Defendant. A Coun Order is necessary to protect me, . . 13. r believe that service cannot be safely effected by an adult individual other than II law enforcement officer such as the Sheriff of Cumber/and County 14. r ask for attorney fees and costs purSUant to the Protection From Abuse Act. 15. r have suffered out-of-pocket losses as a result of the Defendant's abuse, namely the destruction of my sliding glass door to my house as aforesaid. In addition, David hus taken some of my belongings and r would like to get them back. WHEREFORE, Plaintiff requests that this Honorable Coun to reward the fol/owing relief A Grant a Temporary Order pursuant to the Protection From Abuse Act that orders h '" the Defendant to stop abusing, harassing, threatening and/or stalking the abused and stop placing the abused in fear of abuse in any place where she may be found. In addition, prohibiting the Defendant from going back into the Plaintitrs home at 32 Ellst Keller Street, Mechanicsburg, PA 17055. Prohibiting the Defendant from having any conduct with the abused, inclUding but riot limited to restraining the Defendatlt from entering her place of employment, bUBiness, school 01' recreation of the abused person and from harassing the abused 01' the abused person' 5 rclutives Granting temporary custody of the abused minor child, Aaron Harbaugh to the Plainlill; Michelle L Louthian. FlUI) .O,:FICf: or II';: )1 ii": j)T/lfW 98 .JUt 29 Pi'! :;: n (3 OUM8Gil.iI:n (,\)\IN'IY P':NI'''''I''''I'' c ,1\J~'Vf\j' !,'\ . MICHELLE LCUrHIAN, Plaintiff IN 'l'HE COURT OF CO'lMON PLEAS OF CUMBERL~~D COUNTY, PB~SYLVAN1A VB. I I NO. 98-2468 CIVIl, TERM I CIVIL AC~ION - LAW I I IN CUSTODY DAVID E. HARBAUGH, Defendant aIDIlR OP COORT AND IQ/, this ]'\ consideration of the attached and directed as follows: -, day of '') .{Ja Custody Conciliat all R pOrt, , 1998, upon it is ordered 1. The Mother, Michelle Louthian, and the Father, David E. Harbaugh, shall have shared legal custody of Aaron Harbaugh, born October 20, 1995. Each parent shall have an equal right, too be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not 1.imited to, all decisions regarding his health, education and religion. 2. The Mother shall have primary physical custody of the Child. 3. The Father shall have partial physical custody of the Child from Thursday, July 16, 1998 at 5:30 p.m. wltil the following Friday motning at 7:15 a.m. when the Child shall be returned to the Hardees restaurant in Meohanicsburg by the Father or Bonnie Mills, in the Father'a place. On an ongoing basis, the Father shall have cuatody of the Child on alternating weekends, beginning July 24, 1998 from Friday at 7:00 p.m. until Sunday at 8:30 p.m. In the event the Father works on that Friday evening until 8:00 p.m., the Father shall notify the Mother prompUy to make arrangements to piCk up the Child after work. In the event the ~'ather works on that Friday evening until midnight or later, the Father shall have custody of the Child beginning the following saturday IOClrning at 8:00 a.m. In addition, the Father shall have custody of t.he Child every Tuesday from 5:30 p.m. until 8:30 p.m., with the exception of Tuesday, July 28, 1998 when the Father shall have custody of the Child for a picnic from 5:00 p.m. until no later than 9:00 p.m. The Father shall contact the Mother by telephone when leaving the picnic. The parties shall be flexible in rescheduling the Father's periods of weekday custody as necessary when the Father has to work on Tuesday. 4. The parties shall exchange custody of the Child at the Htlrdees restaurant on Simpson Street in Mechanicsburg for all exchanges of custody under this Order except when the parties are exchanging custody on saturday morning at 8:00 a.m. and the Father is unable to obtain transportation, in which event, the Mother shall bring the Child to the 'l'urkey Hill store across the street from the Father's residence. CAPIIAL ARIA INlfli~lf[)IATf IiNII PAGI J S 1I1D1 N I AI IINDANCI HIS lOllY 06/04/03 " ()S . ()~, SrLllENl : IDI-76- ~,W;6 IIAIiBAiXiH, MIWN __~'A_'. MAIN 1.0: DAY DAIl mAN'; n,ACIIIJl UISllilCI RESIO GROUP iKIME HRS MaR ~ 001 W 05/08/31 1'111 00:1 WITTENMYER, PAULINE 1-15-21-650-3 MECIIANICSBURG AREA 1 RES F 004 013 ~ 05/09/19 /\2 CM 014 I 0~;!09/20 A< oo~ 015 W 05/09/21 A2 IIO~ 016 R 05/09/22 A" <. oo~ 017 F 05/09/23 A2 004 021 R 05/09/29 A2 004 033 T 05/10/18 A2 004 036 F 05/10/21 A2 004 039 W 05/10/26 A2 004 041 F 05110/28 A2 004 059 T 05/11/29 A2 004 073 T U5/12/20 A2 004 076 T 06/01/03 A2 004 077 W 06/01/0~ A2 004 078 Ii 06/01/05 A2 004 079 F 06/01/06 A2 004 087 R 06/01/19 W05 004 108 T 06/02/21 R06 003 WITTENMYER, PAULINE 1'15,21,650.3 ~IECHANICSBURG AREA 1 RES F 004 113 T 06/02/28 A2 004 115 R 06/03/02 A? 004 117 M 06/03/06 A? 004 liB T 06/03/07 A2 004 119 W 06/03/08 A2 004 120 R 06/03/09 A2 004 121 r 06/03/10 A2 004 122 M 06/03/13 A2 EXCUSEO UNEXCUSED TOTAL TOTAL ABSENCES ABSENCES ABSENCES TAROIES _0 24,0 24,0 0 ACl"':' i\\c31;1J , I~y~ ~~\ L cssm CAPIIAL AREA INIERMEOIAII lINI r PAm I SllIlJENI AmNIJANCE HISIURY 06104/0:1 Wl-/6-!;B!i6 IIARIIAlIGl1. AARON 011 - 0<::> STUDENT: C'~_____ MAIN LOC DAY DAlE lRANS II ACHER IJISTRICl RESID GROUP flOME fiRS MBR 004 001 M 04108130 EOI 001 KIIAMf'R, DENISE 1-15-21-650-3 MWIANICSIIURG AREA IRES E 004 019 M 04109121 A2 004 02,1 M 04/1010') r 004 025 T 0411010!, I 004 038 M 04/10125 1 004044 T 04111102 WO~I 014 046 W 04/11103 R02 028 WAY, SUSAN 1-15-21.650'3 flECHANICSBURG AREA 4 1306- 13 HERSHEY MEDICAL CENT f 014 050 T 04111/09 W02 004 050 W 04/11110 1106 007 KRAMER, DENISE 1,15-21-650-3 MECHANICSOURG AREA 1 RES F 004 051 R 04/11111 Al 004 061 W 04112/01 WOE, 004 069 M 04112/13 R06 001 KRAfIER, DENISE 1-15.2\.650-3 flECHANICSOIJRG AREA 1 RES F 004 095 M 05101/,il A2 004 108 R 05/02111 WOS 014 112 W 05/02123 R06 028 WAY, SUSAN 1-15,,21-650-3 MECHAN ICSBURG AREA 4 1306- 13 'HERSHEY MEDICAL CENT F 014 115 M 05/02128 W02 004 116 R 05/03103 ROli 001 KRAMER, DENISE 1-15-21-650-3 MECIWilCSBURG AREA 1 RES r 004 116 R 05/03103 I 004 119 1 05/03108 W05 004 123 T 05103/15 R06 001 KfWIER, OENISE 1.15-21-650.3 MECHANICSBlIRG AREA 1 RES r 004 149 M 05/0'1/25 Al 004 150 T 05/04/26 ,\1 004 151 W 05/0'1121 Al 004 ]71 F 05/05/27 T EXCUSEO ' UNEXCUSED TOTAL TOTAL ABSENCES ABSENCES ABSENCES TARDIES 4,0 2,0 6.0 5 ~ \!-.)oS \ :;, \}.,<::re 'f\ d - '\ \\e9oJ Yi-\ kg 0, \ tt:f1\ P . \N / '() -~ " \~\ tJr" 3. The parties listed above had previously been Involved In a custody actlon In reference to this child before This Honorable Court. 4. Following a custody conciliation conference, the mother was granted primary physical custody with periods of partial custody to be given to the father. 5. Upon mutual consent, the parties now believe that the best Interests and welfare of the child, Aaron Harbaugh, bom on October 20, 1995, would best be served If primary physical and legal custody was with Michelle Louthlan, as Indicated by their signatures below from August 26, 2005, until February 21, 2006. 6. Following February 2.1, 2006, the parties desire the Mother to maintain primary physical custody of the child with Father to have partial custody of the child with a minimum of three hours per week and alternating weekends as mutually agreed between the parties. 7. Following February 21, 2006, the Mother, Michelle Louthlan, and the Father, David Harbaugh, shall have shared legal custody of Aaron Harbaugh, born October 20, 1995. Each parent, following February 21, 2006, shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being Including, but not limited to, all decisions regarding his health, education and religion. 8. In the event Father works during his period of partial custody, he will contact mother to care for Aaron Harbaugh; alternatively, a mutually approved caretaker will be found by father to care for Aaron during Father's periods of partial custody. Father agrees to allow Aaron to participate In any needed continued program ....... . , ,... N " i"t~ .:1' 0 '" (:0 ".:' ) U.l~' _,I 'j r () .~ -, Ii: ~,i:c .' .J l I :::1 , -- t/i ;':','1 "J.! .../ I li n,-: ~I:I ~:c "1" (;1'1 , Co. "':;'1.; " IL_ -. 1./_ "... \~'.'j ,;;'.) U i~'~) C) ~'~,l ii ~~; 4. On October 26, 2005, this Court issued an Order In the above-caplioned uction plll'suantto u stipulation and Custody agreemcnt ofthc purties. Thc Order gl'llnted Mother prlmury legal and physical custody of the child until Futher's release from York County Prison on Fehnlllry 21,2006. Upon Futher's relcuse, Mother would huve primury physicul custody of the child und share legal custody with Futher. 5. On March 28, 2006, Mother tiled a Petition for Special Relief Seeking Emergency Custody Pursuant to P A R.C.P. 1915.13. Mothcr sought emergency legal custody of the child so thut the child could be placed in residential treatment at Philhuven Behaviol'lll Healthcare Services on April 13,2006, despite Fatlwr's opposition to the child's placement at that fucility. 6. After a hearing, by Order on April 10,2006, this Court granted Mother the relief she requested, giving her temporary legal custody of the child. A footnote to the April 10,2006 Order provides that temporary Il~gal custody wus granted to Mother so thut she could obtain the neeessury residential treutment for the child at Philhaven. 7. In order for Philhaven to admit the child, Mother's insurance company needed to authorize the child's placement at Philhaven by no later than April 11,2006. 8. On April 11,2006, undersigned counsel notified Mother of the April 10, 2006 Order. 9. Mother notified her insurance company of this Court's April 10, 2006 Order on April 11,2006, but the insurance company did not authorize thc child's placement at Philhaven until April 13,2006. Consequently, Philhaven was unable to admit the child into residential treatment. Mother cannot be provided a specific date for the next available admission. 10. On April 12, 2006, Ms. Angclu BUI'ge, Allron's intensive euse ml\nuger, through the Stevens Center, secured udmisslon for the child lit The Brlldley Center which is located in Pittsburgh, Allegheny County, Pennsylvunla. The child is scheduled to begin residentiul treatmenlut The Bl'lIdley Center on 01' ubollt April 25, 2006. Ms. Burge is also seeking to locate u fueility for AUl'On's case closer to home. Approvlll for this admission from the heulth insurance provider was obtained on April 13,2006. 11. Similur to Philhaven Behaviol'lll Heulthcare Services, the duration of residential treatment varies by patient but typically lasts a minimum of six months. Also similar to Philhaven, the residential treatment prognun at Ilradley Cenler will allow both Mother and Father access to the child during his time in residence. 12. Mother is filing this Petition because she believes that this Court's April I 0,2006 Order only gives Mother the authority to place the child in residential treatment at Phil haven Behavioral J\ealthcare Services. 13. Mother believes and therefore avers that it is in the best interests of the child thut Mother be granted tempomry sole legal cllstody of the child, pending further order of court, so that Mother can consent to the child's placement in a residential treatment facility. WHEREFORE Petitioner, Michellc Louthian, respectfully requests this Honorable Court grant Petitioner temporary sole legal cllstody of the Child, Aaron Harbaugh, so that Mother can ensure that the child is placcd in a residential treatment fucillty. .'>.. C'I C/'; -.. ~;.~ '::~) Ui.' I ,?r ''1!'" , ' ~~p i:1 '. . '. - rj" ~1 Lt.. a=.:'U~1 0.::- i/,,/ n.. rl.: Ht,' )U.. l..~l , ll, '-.., 0 l;:;" .~) C.:~ 0 (".J ~( '" ... Mr. David E. Harbaugh, Planllff/Petltloner v. :IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVAINIA : CIVIL ACTION - LAW : IN CUSTODY Ms. Mlc:helle L. Louthlan, : DefendanURespondent : No. 98-2468 CIVIL TERM PETITON FOR SPECIAL RELIEF SEEKING EMERGENCY CUSTODY PURSUANT TO PA R.C.P.1915.3 AND NOW, this 7th day or April, 2006, pursuant to rule 1915.13 of the Pennsylvalnla Rules of Civil Procedure, comes the Petitioner, David Harbaugh seeking emergency legal custody of the minor child, Aaron Harbaugh, born October 20,1995, sothat the child may be placed in a stable and safe environment free from Iminetmortal danger mental and/or emotlnal abuse, 2 threats of severe bodily harrn and fear of life. In support of his Petitlonfor Emergencyefllef, Petltoner avers the following: 1. The Petitioner Is David Harbaugh ("Father"), the father of the chlld,resldlng at 3919 Rosemont Avenue, Camp Hili, Pa 17011-7814. 2. The Respondent Is Michelle Louthlan ("Mother"), the mother of the chllld,resldlng at 27 Laurel Drive, Mechanlcllburg, Pa 17055. 3, The child Is Aaron Harbaugh, born October 20,1995. 4. On March 28th 2006, the mother filed a Petition for special rellefseeklng emergency custody pursuant to PA R.C.P. 1915.13 withwiththls honorable court, in the Petition mother states that father does not have a good- faith reason for objecting to child's placement In Phllhaven Behavior Sevrlves. 5. On October 26 2005, this court issued that Is essence reflected the terms of parties' Custody Agreement and Sipulation that order reflects that father had the child's "best interests" in mind as father did not want Incarceration to hinder mothers con cernes for necessary treatment for child for the six months father was to be confiend. 6. The child has been In and out of treatment facilities approximately eight times since age five, these "visits" were at Hershey Physchlatrlc Ward, Kids Peace in Allentown and Phllhaven. All of these admissions were done when an Inoldent happend In mothers care. Father objected to these placements but only . times slnC'.e age five, these "visits" were at Hershey Physchlatrlc Ward, Kids Peaoe in Allentown and Phllhaven. All of these admissions were done when an Incident happend In mothers care. Father objected to these placements but only once did father refuse child to stay admitted. That was the first admission to Kids Peace when father was at Holy Spirt Emerngancy Room during Intake he was not Informed at the father's consent was needed for child's admission. On father's first visit to the Kids Peace he voiced his obJeotlons he was Infomed that the child could not stay without mutual parental consent. Child was roaleased 3 days later. Child as been in and out of Hershey Psyclatio approximatly three or four times since with father In full support of child's treatment, medication and after care. 7. To the best of fathers knowledge mother was diagnosed all BI-Polar Manic Depressive since about 14 years of agl:l. She also was a patient of Dr. Brandt (past) and Dr. Kahn (present) and nurse Sandra Abbey rofered to in Paragraph 6 of mother Petition dated 28th of March 2006. Mother cancelled an appointment and had child fill it becasue son needed It more aooording to mother. This was ok with abbyMothers most recent In-patient treatment wasdurlng the Christmas holidays of 2003-2004. This was a self admission mother checked In and checked herself out with no after care plan or change of medloatlons and no doctor. 8. Mother's irrational behavior has been shown to many past and present. Fathers Input during numerous discussions with the mental health profession has oentered on child's "Learned behavior" from mother;"On Tuesday aprll 4th 2006 at the stevens oenter Father's ooncerns about the violent/chaotic environment child endures on a dally basis goes Ignored by anyone unfamiliar to mother's malicious and devious nature. 9. Mother has repeatedly abused and violated the visitation order Issued by the honorable Judge Baley on 27th of July 1998. Father and child have lost weekend and dally visits when mother deems fit. Child's maternal grandparents have also have been denied planed visits. This oauses the child repeated stress and frustration. Fsther contacted the appropiate police force conoervlng these violations until father became frustrated with the authorltlea inability to enforce the order and due to financial oonstralnts unable to pursue the matter legally. These inoldents of denied court ordered visitation were often done in front of ohlld at an Inappropriate age and mother continues to manipulate this order as of this week. Mother will often not send child's medication on fathers weekend then blameson father for not gettln them. This Is done by mother with exlream malice towards child, father and maternal grandparents. The "evil" behavior by mother has greatly affected the child and is a huge factor In child's dlsNptlne behavior at school and at mothers. 10. Mothers irrational behavior is a record of court In York County. Mother has an older son, Zachary Louthlanborn 19th of October 1991. This child was diagnosed as "troubled" approxemently same age as younger son, Aaron. During my relationship with mother and Zack, I saw and heard abuse, harass, and threaten this child from ages five through ten. I stopped this behavior by mother when I was present. Zach wasflnally placed In his father's custody when his school (Filbert Street Elementry) testified In York County court that marks on Zach's neck was from mother's hands. Zach had told schtlol officials that his mother was trying to strangle him to death. Since I met this boy In 1994, He had been on numerous medications for ADHD and other disorders his mother had him diagnosed with by other mental health professionals. Since being placed In his fathers custody his mother has signed off all parental rights and responsibilities. This older son has been off medications since the changeln custody. No more outbursts, social skills have Improved dramatically and self- esteem Is normal from the time his envlroment changed. That has been another detremental action by mother mother. They have made It clear that any legal paperwork or personal testimony they can provide will done so at any time. The older son hates his biological mother and never wantes to see her ever again with Just cause. I do not want our Gon, Aaron, to go in this direction. Mothers Irrational and abusive nature is doing exactly thlr. to the child. Mothers youngest has been diagnosed as "mildly retarded." This just keeps going for these children. 11. Father and Mother's relationship was marked with repeated visits by the local police. Her current relationship also. Father requested these records but due to the late notice of this honorable court's hearing have not received response from two of the police department's contacted and the third, Upper Allen has responded denying fathers request without court ordered documents. 12. Child has told father that mother had told him that she was going to placement when she was a teenager but Instead went to live with different relatives. Father wishes the same for child, to live with father, father's sisters any relative maternal or paternal before six months at a strange facility fourty five minutes from any family or friends. 13. Due to mothers "evil, Malicious and devious "behaviors past and pressent and her court recorded lIfe..threatening actions against her oldest "former" son. This father begs the honorable Judge to give the father Immediate emergency custody of child, Aaron. Keep in mind that when her children do not buckle to mothers "complete control" and exhibit any resemblance of Independence, mother has progressed from mental and emotional abuse to moratal bodily harm. The threat of bodily harm was issued from mothers mouth towards child on April 3rd 2006. Child told mother he was going to call 911. Then mother changed her behavior. The volatile actions and terroristic threats should not be endured by anyone, expeclally a "troubled child" ten years old. ~. In st .... ",_., n... cr; ('oJ "b ~ "";L .. I~-< to ~ VJ~-.; .~ :c; .. 1.1. .j '";''' (t. V) I; . ""1 (~) C" r- ~ (~) ,'; I ~ \L!I... r;..... LC~~ (1;; ~~r.F~ ........ ... 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SCdnrwJ- b,,\orL OJ. I:', ?oo"\ 0. r e No ~ '3,CA n[\<' 01 R E eEl V EO eCT 1 7 Z005 rJP/ MICHELLE LOUTHIAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNlY, PENNSYLVANIA VS. No. 98-2468 CIVIL TERM DAVID HARBAUGH, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this day of , 2005, upon presentation and consideration of the within Stipulation and Agreement, it is hereby ORDERED that Michelle Louthian is hereby granted primary phYSical and legal custody of Aaron Harbaugh from August 26, 2005, until February 21, 2006. Following February 21, 2006, Michelle Louthian will continue to have primary physical of Aaron Harbaugh subject to periods of partial custody with the father and the parties shall share legal custody as set forth in the attached Stipulation and Agreement and that said Stipulation and Agreement is incorporated and made a part hereof and the terms concerning the custody of the minor child, Aaron Harbaugh, born on October 20, 1995, shall be as set forth therein. BY THE COURT: Edgar B. Bayley, Judge Distribution: William M. Shreve, Esquire, 3618 North Sixth Street, Harrisburg, PA 17110 David Harbaugh, 24 North Kitzer Street, Etters, PA . MICHELLE LOUTHIAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 98-2468 CIVIL TERM DAVID HARBAUGH, Defendant CIVIL ACTION - LAW CUSTODY CUSTODY STIPULATION AND AGREEMENT This agreement, made this ~6"'-'fy of 4u'6/ ,2005, between Michelle Louthian, Plaintiff, and David Harbaugh, Defendant, concerning the parties' minor child, Aaron Harbaugh, born October 20, 1995. WHEREAS, the parties desire to enter into a Stipulation and Agreement as to the custody of the minor child, Aaron Harbaugh, born October 20, 1995, and to have this Stipulation and Agreement made an Order of Court, the parties agree to the following: 1. Plaintiff listed above, Michelle Louthian, is the natural mother of the child, currently residing at 27 Laurel Drive, Mechanicsburg, PA. 2. Defendant listed above, David Harbaugh, is the natural father of the child, currently residing at 24 North Kitzer Street, Etters, PA. 3. The parties listed above had previously been involved in a custody action in reference to this child before This Honorable Court. 4. Following a custody conciliation conference, the mother was granted primary physical custody with periods of partial custody to be given to the father. 5. Upon mutual consent, the parties now believe that the best interests and welfare of the child, Aaron Harbaugh, born on October 20, 1995, would best be served if primary physical and legal custody was with Michelle Louthian, as indicated by their signatures below from August 26, 2005, until February 21, 2006. 6. Following February 21, 2006, the parties desire the Mother to maintain primary physical custody of the child with Father to have partial custody of the child with a minimum of three hours per week and alternating weekends as mutually agreed between the parties. 7. Following February 21, 2006, the Mother, Michelle Louthian, and the Father, David Harbaugh, shall have shared legal custody of Aaron Harbaugh, born October 20, 1995. Each parent, following February 21, 2006, shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 8. In the event Father works during his period of partial custody, he will contact mother to care for Aaron Harbaugh; alternatively, a mutually approved caretaker will be found by father to care for Aaron during Father's periods of partial custody. Father agrees to allow Aaron to participate in any needed continued program '. to which he is enrolled. Any time lost by Father due to child's needed enrollment in any such program will be made up at times as mutually agreed between the parties. 9. Father agrees to maintain Aaron's medication regimen during his periods of partial custody. 10. Neither Parent is allowed to drink while driving with the child during periods of custody with the child. If either parent is under the influence of alcohol at a pick up or drop off the child cannot go with that parent. 11. David Harbaugh has had the opportunity to seek the advice of counsel prior to execution of this stipulation and Agreement, and hereby acknowledges that he has not entered into this Stipulation and Agreement concerning custody of their minor child under duress or coercion or threats of any manner. The parties hereto desire that this Stipulation and Agreement be made an Order of Court. 12. It is understood by both parties that this Stipulation and Agreement is entered with the best interests of Aaron Harbaugh in mind. Date: 8- 2S- D5 ,0 F) c- ,.-- Date: 0'- of- J - () ~ &'" /"'.. l' ;1 A L!7 '~,{l k~ t ..1)--..----~-. '.. Michelle Louthian, Plaintiff '..... () -n --1 :1: .11 G..~ (r) ~. ,J .J _~.J f'..) ....:.:':' _.; . RECEIVED GCT 172005 rJP/ MICHELLE LOUTHIAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 98-2468 CIVIL TERM DAVID HARBAUGH, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this & day of ~t- . ...2005, upon presentation and consideration of the within Stipulation and Agreement, it is hereby ORDERED that Michelle Louthian is hereby granted primary physical and legal custody of Aaron Harbaugh from August 26, 2005, until February 21, 2006. Following February 21, 2006, Michelle Louthian will continue to have primary physical of Aaron Harbaugh subject to periods of partial custody with the father and the parties shall share legal custody as set forth in the attached Stipulation and Agreement and that said Stipulation and Agreement is incorporated and made a part hereof and the terms concerning the custody of the minor child, Aaron Harbaugh, born on October 20, 1995, shall be as set forth therein. .., I /J' BY THE COllRT: /r {' / L--- Edgar . ~ Distribution: --William M. Shreve, Esquire, 3618 North Sixth Street, Harrisburg, PA 17110 ......David Harbaugh, 24 North Kitzer Street, Etters, PA ~~ &;:;rP //-- \0 Ms. Michelle 1. Louthian, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY Mr. David E. Harbaugh Defendant : NO. 98-2468 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Ms. Michelle 1. Louthian , Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in fomla pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. RespectfuJly submitted, Date 3/oZt/a 1~1-flt/~ Kathleen McKeown C---> Certified Legal Intern ~-=: ~.^ - "- :> ROBERT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH WILLIAM G. MARTIN Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 ,-" ';,:;.:; c:..:," --..: .",/.' 50 ......,) 'c;) c, ':.:i1 --l ~~~} . ,'~ ('-) ~~: c r<, Ms. Michelle 1. Louthian, Plaintiff/ Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LA W IN CUSTODY Mr. David E. Harbaugh, Defendant/ Respondent No. 98-2468 CIVIL TERM PETITION FOR SPECIAL RELIEF SEEKING EMERGENCY CUSTODY PURSUANT TO PA R.c.P. 1915.13 AND NOW, this .2tt~ay of March, 2006, pursuant to Rule] 915.13 of the Pennsylvania Rules of Civil Procedure, comes the Petitioner, Michelle Louthian, by her counsel, the Family Law Clinic, seeking emergency legal custody of the minor child, Aaron Harbaugh, born October 20, 1995, so that the child may be placed in residential treatment at Philhaven Behavioral Healthcare Services on Monday, April 13, 2006, despite the Father's opposition, and receive necessary medical treatment. In support of her Petition for Emergency Relief, Petitioner avers the following: 1. The Petitioner is Michelle Louthian ("Mother"), the mother of the child, residing at 27 Laurel Drive, Mechanicsburg, P A 17055. 2. The Respondent is David Harbaugh ("Father"), the father of the child, residing at 3919 Rosemont Avenue, Camp Hill, PA 17011-7814. 3. The child is Aaron Harbaugh, born October 20, 1995. 4. In August of 2005, the parties filed a Custody Stipulation and Agreement with this Court. Pursuant to that Agreement, the parties stipulated that Mother would have primary legal and physical custody of the child until Father's release from York County Prison on February 21, 2006. The parties agreed that upon Father's release Mother would have primary physical custody of the child with Father having periods of partial custody. The parties would share legal custody of the child, including the right to make non-emergency medical decisions for the child. On October 26, 2005, this Court issued an Order that in essence reflected the terms of the parties' Custody Agreement and Stipulation. Copies of the parties' Custody Agreement and Stipulation and this Court's Order of October 26,2005, are attached as Exhibits "A" and "B" respectively, and are incorporated by reference herein. 5. When the child was five years old, he was diagnosed with certain mental disorders. The child has received wide-ranging treatments for those illnesses including hospitalization at Philhaven Behavioral Health Services. He has been taking prescribed medication to treat his illnesses since approximately age five. 6. On December 29, 2005, Dr. Mohammed Khan, M.D., and Sandra Abbey, eRNP, of Family Life Services, Diakon Lutheran Social Ministries, conducted a psychological evaluation of the child. Dr. Khan and Nurse Abbey found that the child was "unable to maintain in the community" and recommended that the child be placed in a residential treatment facility. 7. The child was partially hospitalized at Pinnacle Health Behavioral Services from January 30, 2006, to February 8, 2006, for the purpose of further evaluating his condition. Upon the child's discharge, the child's doctors at Pinnacle Health Behavioral Services recommended that he be placed in a residential treatment facility. 8. The child is scheduled to begin residential treatment at Philhaven Behavioral Healthcare Services on April 13, 2006. Treatment length varies by patient but typically lasts a minimum of six months. 9. On or about March 20,2006, Father called Faith Bixler, Admissions Coordinator at Philhaven, indicating that he does not agree with the child being placed in residential treatment at Philhaven and will not consent to the child's placement at the facility. 10. Counsel for Philhaven has informed the undersigned counsel for Mother that Philhaven cannot accept the child for treatment over the Father's objection, given the current Order of shared legal custody. 1 I. Mother believes that Father does not have a good-faith reason to object to the child's placement in residential treatment at Philhaven. 12. Mother believes that if the child is not placed in residential treatment at Philhaven Behavioral Healthcare Services on April 13, 2006, he will have to wait at least six more months before Philhaven can admit him. 13. Mother believes and therefore avers that it is in the best interests of the child that Mother be granted sole legal custody of the child, pending further order of court, so that Mother can consent to the child's placement in residential treatment at Philhaven Behavioral Healthcare Services over Father's objection. WHEREFORE, Petitioner, Michelle Louthian, respectfully requests that this Honorable Court grant Petitioner sole legal custody of the Child, Aaron Harbaugh, so that Mother can ensure that the child is placed in residential treatment at Philhaven Behavioral Healthcare Services and receives necessary medical treatment. Respectfully submitted, 3446 Date !'~)/l/~.__.~ Kathleen McKeown C._, C,rtH~.e.._d. - Lo~og_"l 1-""7'" _ {~~"-, LUCY JOHNSTON-WALSH ROBERT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX WILLIAM G. MARTIN Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013-2899 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing Petition for Special Relief are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. S4904, relating to unsworn falsification to authorities. Date: ,}/Jf'{)G:, l ~\ .-----.... EXHIBIT [j COF, i A . RECEIVED eeT 17 Z005 rJ"ft/ MICHELLE LOUTHIAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 98-2468 CIVIL TERM DAVID HARBAUGH, Defendant CIVIL ACITON- LAW CUSTODY ORDER OF COURT AND NOW, this .z:.h- day of 0k6- . ,.2l)05, upon presentation and consideration of the within Stipulation and Agreement, it is hereby ORDERED that Michelle Louthian is hereby granted primary physical and legal custody of Aaron Harbaugh from August 26, 2005, until February 21, 2006. Following February 21, 2006, J'oilichelle Louthian will continue to have primary phy!;ical of Aaron Harbaugh subject to periods of partial custody with the father and the parties shall share legal custody as set forth in the attached Stipulation and Agreement and that said Stipulation and Agreement is incorporated and made a part hereof and the terms concerning the custody of the minor child, Aaron Harbaugh, born on October 20,1995. shall be as set forth therein. ") , ./ BY THE COllRT: ,r; /, L--I' Edgar ~ ey, Judge /! /( --~ Distribution: ....william M. Shreve, Esquire, 3618 North Sixth Street, Harrisburg, PA 17110 i/<"f}avid Harbauqh, 24 North iG1zcr Stre.et, Etters, PA - , , .\\y-.. ',\ cI,'feY '" /\~~r l}\ \~!oJ EXHIBIT I~ (J COpy RECEIVED CCT 17 Z005 tJP/ MICHELLE LOUTHIAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 98-2468 CIVIL TERM DAVID HARBAUGH, Defendant CML ACTION -- LAW CUSTODY ORDER OF COURT AND !\lOW, this day of , 2005, upon presentation and consideration of the within Stipulation and Agreement, it is hereby ORDERED that Michelle Louthian is hereby granted primary physical and legal custody of Aaron Harbaugh from August 26, 2005, until February 21, 2006. Following February 21, 2006, Michelle Louthian will continue to have primary physical of Aaron Harbaugh subject to periods of partial custody with the father and the parties shall share legal custody as set forth in the attached Stipulation and Agreement and that said Stipulation and Agreement is incorporated and made a part hereof and the terms concerning the custody of the minor child, Aaron Harbaugh, born on October 20, 1995, shall be as set forth therein. BY THE COURT: Edgar B. Bayley, Judge Di!.tribution: William M. Shreve, Esquire, 3618 North Sixth Street, Harrisburg, PA J.7110 Dav',d Ha'-'D-' ....L. ". "0->'- v......__ "'.......^t ">>ers Da r C'IUYII, L."'t 1'4 I U I J'l..H.."-CI JU ~_, !.~u.. I , I ,. '.""..) C"" ...J ,'.\ , iVlICHELLE LOUTHIAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 98-2468 CIVIL TERM DAVID HARBAUGH, Defendant CIVIL ACTION - LAW CUSTODY ,cusrO[ll'l( S1l1tIPU!.ATION AND AGREEMENT This agreement, made this .:)., j~y of ~c7,t/tS'/ ,/ ,2005, between iVlichelle Louthian, Plaintiff, and David Harbaugh, Defendant, concerning the parties' minor child, Aaron Harbaugh, born October 20, 1995. WHEREAS, the parties desire to enter into a Stipulation and Agreement as to the custody of the minor child, Aaron Harbaugh, born October 20, 1995, and to have this Stipulation and Agreement made an Order of Court, the parties agree to the following: 1. Plaintiff listed above, Michelle Louthian, is the natural mother of the child, currently residing at 27 laurel Drive, Mechanicsburg, PA. 2. Defendant listed above, David Harbaugh, is the natural father of the child, (,?siding ?:1t ?4 NOj-th Kitz.~r Str2-.2t Etters_ I I I I 3. The parties listed above had previously been involved in a custody action in reference to this child before This Honorable Court. 4. Following a custody conciliation conference, the mother was granted primary physical custody with periods of partial custody to be given to the father. 5. Upon mutual consent, the parties now believe that the best interests and welfare of the child, Aaron Harbaugh, born on October 20, 1995, would best be served if primary physical and legal custody was with Michelle Louthian, as indicated by their signatures below from August 26, 2005, until february 2.1, 2006. 6. following February 21, 2006, the parties desire the Mother to maintain primary physical custody of the child with Father to have partial custody of the child with a minimum of three hours per week and alternating weekends as mutually agreed between the parties. 7. Following February 21, 2006, the Mother, Michelle Louthian, and the Father, David Harbaugh, shall have shared legal custody of Aaron Harbaugh, born October 20, 1995. Each parent, following February 21, 2006, shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding his health, education and religion. S. In the event Father works during his period of partial custody, he will contact mother to care for Aaron Harbaugh; alternatively, a mutually approved caretaker will be Tound b~; Tather to care for Aaron during Father's periods or partial t.r) A,aron to pa.rticipate :n ~ny rl'c~et1 continL!6:1 pr(x:Jrr1n~ to which he is enrolled. Any time lost by Father due to child's needed enrollment in any such program will be made up at times as mutually agreed between the parties. 9. Father agrees to maintain Aaron's medication regimen during his periods of partial custody. 10. Neither Parent is allowed to drink while driving with the child during periods of custody with the child. If either parent is under the influence of alcohol at a pick up or drop off the child cannot go with that parent. .11. David Harbaugh has had the opportunity to seek the advice of counsel prior to execution of this stipulation and Agreement, and hereby acknowledges that he has not entered into this Stipulation and Agreement concerning custody of their minor child under duress or coercion or threats of any manner. The parties hereto desire that this Stipulation and Agreement be made an Order of Court. 12. It is understood by both parties that this Stipulation and Agreement is entered with the best interests of Aaron Harbaugh in mind. Date: 8- 2.!Y- iJ5 ~vJM David Harbaugh, Deli 8 -'\ ~ .-_. Date: ,- 01. ~) - 0 j ~ ~. T 1 I .. . Lilli {lid eG ~~- ~~ich~lIe Louthian, Plaintiff "... --------- '. ' \--, .' ",---::5 ,. " 0:' (;? f".'l --.' 1",,') () c", --I) ::'If, --I :t'" -,- ....~' f'i1;:: f",) OJ -'0 1"-.) C..) ,> 'J r'+~' '< Ms. Michelle 1. Louthian, Plaintiff! Petitioner r.--'.--C-;"'ET"r'''--) . ~ ,,_~,_"_, ",,_._-, =_;, \./ l~J~__. , \ IViI;,K 2 8 20U6 I IN THE COURT OF COM~~ OF CUMBERLAND COUNTY, PENNSYLVANIA ~ v. CIVIL ACTION - LA W IN CUSTODY Mr. David E. Harbaugh, Defendant! Respondent No. 98-2468 CIVIL TERM ORDER OF COURT AND NOW, this ~5lia:ay of/'Y\o (f t 2006, upon consideration of the attached Petition for Special Relief, a hearing regarding this Petition for Special Relief is hereby scheduled for the ~U\ day of ~, 2006 at _l'A') o'clock iL M in Courtroom Number ()., Cumberland County Courthouse, Carlisle, Pennsylvania 17013, at which time the parties shall appear in person. BY THE COURT ..,~ L'_ () ...... ('.h ;:::) '::"'3 , - '05 u , .... Mr. David E. Harbaugh, Plantiff/Petitioner v. :IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVAINIA : CIVIL ACTION - LAW : IN CUSTODY Ms. Michelle L. Louthian, Defendant/Respondent : No. 98-2468 CIVIL TERM PETITON FOR SPECIAL RELIEF SEEKING EMERGENCY CUSTODY PURSUANT TO PA R.C.P.1915.3 AND NOW, this 7th day or April, 2006, pursuant to rule 1915.13 of the Pennsylvainia Rules of Civil Procedure, comes the Petitioner, David Harbaugh seeking emergency legal custody of the minor child, Aaron Harbaugh, born October 20,1995, sothat the child may be placed in a stable and safe environment free from iminetmortal danger mental and/or emotinal abuse, 2 threats of severe bodily harm and fear of life, In support of his Petitionfor Emergency eflief, Petitoner avers the following: 1. The Petitioner is David Harbaugh ("Father"), the father of the child,residing at 3919 Rosemont Avenue, Camp Hill, Pa 17011-7814. 2. The Respondent is Michelle Louthian ("Mother"), the mother of the chilld,residing at 27 Laurel Drive, Mechanicsburg, Pa 17055. 3. The child is Aaron Harbaugh, born October 20, 1995. 4. On March 28th 2006, the mother filed a Petition for special reliefseeking emergency custody pursuant to PA R.C.P. 1915.13 Withwith this honorable court, in the Petition mother states that father does not have a good- faith reason for objecting to child's placement in Philhaven Behavior Sevrives. 5. On October 26 2005, this court issued that is essence reflected the terms of parties' Custody Agreement and Sipulation that order reflects that father had the child's "best interests" in mind as father did not want incarceration to hinder mothers concernes for necessary treatment for child for the six months father was to be confiend. 6. The child has been in and out of treatment facilities approximately eight times since age five, these "visits" were at Hershey Physchiatric Ward, Kids Peace in Allentown and Philhaven. All of these admissions were done when an incident happend in mothers care. Father objected to these placements but only times since age five, these "visits" were at Hershey Physchiatric Ward, Kids Peace in Allentown and Philhaven. All of these admissions were done when an incident happend in mothers care. Father objected to these placements but only once did father refuse child to stay admitted. That was the first admission to Kids Peace when father was at Holy Spirt Emerngancy Room during intake he was not informed at the father's consent was needed for child's admission. On father's first visit to the Kids Peace he voiced his objections he was infomed that the child could not stay without mutual parental consent. Child was real eased 3 days later. Child as been in and out of Hershey Psyciatic approximatly three or four times since with father in full support of child's treatment, medication and after care. 7. To the best of fathers knowledge mother was diagnosed as Bi-Polar Manic Depressive since about 14 years of age. She also was a patient of Dr. Brandt (past) and Dr.Kahn (present) and nurse Sandra Abbey refered to in Paragraph 6 of mother Petition dated 28th of March 2006. Mother cancelled an appointment and had child fill it becasue son needed it more according to mother.This was ok with abbyMothers most recent in-patient treatment wasduring the Christmas holidays of 2003-2004. This was a self admission mother checked in and checked herself out with no after care plan or change of medications and no doctor. 8. Mother's irrational behavior has been shown to many past and present. Fathers input during numerous discussions with the mental health profession has centered on child's "Learned behavior" from mother;'On Tuesday april 4th 2006 at the stevens center Father's concerns about the violenUchaotic environment child endures on a daily basis goes ignored by anyone unfamiliar to mother's malicious and devious nature. 9. Mother has repeatedly abused and violated the visitation order issued by the honorable Judge Baley on 27th of July 1998. Father and child have lost weekend and daily visits when mother deems fit. Child's maternal grandparents have also have been denied planed visits. This causes the child repeated stress and frustration. Father contacted the appropiate police force concerving these violations until father became frustrated with the authorities inability to enforce the order and due to financial constraints unable to pursue the matter legally. These incidents of denied court ordered visitation were often done in front of child at an inappropriate age and mother continues to manipulate this order as of this week. Mother will often not send child's medication on fathers weekend then blameson father for not gettin them. This is done by mother with extream malice towards child, father and maternal grandparents. The "evil" behavior by mother has greatly affected the child and is a huge factor in child's disruptine behavior at school and at mothers. 10. Mothers irrational behavior is a record of court in York County. Mother has an older son, Zachary Louthianborn 19th of October 1991. This child was diagnosed as "troubled" approxemently same age as younger son, Aaron. During my relationship with mother and Zack, I saw and heard abuse, harass, and threaten this child from ages five through ten. I stopped this behavior by mother when I was present. Zach wasfinally placed in his father's custody when his school (Filbert Street E1ementry) testified in York County court that marks on Zach's neck was from mother's hands. Zach had told school officials that his mother was trying to strangle him to death. Since I met this boy in 1994, He had been on numerous medications for ADHD and other disorders his mother had him diagnosed with by other mental health professionals. Since being placed in his fathers custody his mother has signed off all parental rights and responsibilities. This older son has been off medications since the changein custody. No more outbursts, social skills have improved dramatically and self- esteem is normal from the time his enviroment changed. That has been another detremental action by mother mother. They have made it clear that any legal paperwork or personal testimony they can provide will done so at any time. The older son hates his biological mother and never wantes to see her ever again with just cause. I do not want our son, Aaron, to go in this direction. Mothers irrational and abusive nature is doing exactly this to the child. Mothers youngest has been diagnosed as "mildly retarded." This just keeps going for these children. 11. Father and Mother's relationship was marked with repeated visits by the local police. Her current relationship also. Father requested these records but due to the late notice of this honorable court's hearing have not received response from two of the police department's contacted and the third, Upper Allen has responded denying fathers request without court ordered documents. 12. Child has told father that mother had told him that she was going to placement when she was a teenager but instead went to live with different relatives. Father wishes the same for child, to live with father, father's sisters any relative maternal or paternal before six months at a strange facility fourty five minutes from any family or friends. 13. Due to mothers "evil, Malicious and devious "behaviors past and pressent and her court recorded life-threatening actions against her oldest "former" son. This father begs the honorable Judge to give the father immediate emergency custody of child, Aaron. Keep in mind that when her children do not buckle to mothers "complete control" and exhibit any resemblance of independence, mother has progressed from mental and emotional abuse to moratal bodily harm. The threat of bodily harm was issued from mothers mouth towards child on April 3rd 2006. Child told mother he was going to call 911. Then mother changed her behavior. The volatile actions and terroristic threats should not be endured by anyone, expecially a "troubled child" ten years old. WHEREFORE, Petitioner, David Harbaugh, respectfully requests that this honorable court grant Petitioned sole legal custody of the child, Aaron Harbaugh, to and any visitation granted to mother be supervised until child and father are comfortable with unsuperviser visits with mother. Respectfully sumbitted, 4---1- Ob ~vR~~ Date David Harbaugh Father of Child VERIFICATION I verify that the statements made in the foregoing Petition for Special Relief are true and correct, to the best of my knowlege, information and belief. I understand making any false statements would subject me to the penalties of 18 Pa.C.S 4904, relating to unsworn falsification to authorites. Date: 4-~-l-cb David Harbaugh, Petitioner this order as of this very week. AJ ~ ~ >! ;.:'j \) -n \) :-.~ ::;j ~ .--,,1 , CY "-'-" , ~-j C tJ p: -:'-i C, . . --V r. ~ C~ ..< is Ms. Michelle 1. Louthian, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW IN CUSTODY Mr. David E. Harbaugh, Defendant : NO. 98-2468 CIVIL TERM CERTIFICATE OF SERVICE I, Angel Revelant, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Petition for Special Relief in the above-captioned case on Mr. David E. Harbaugh, residing at 3919 Rosemont Avenue, Camp Hill, PA 17011-7814, by personal service on April 4, 2006, at 6:30 p.m.. _~ f5.L~}.--;( Angel Revelant Certified Legal Intern . f. i " .1 ',10,'" c L Cv /)~JJ"1j((. \ Lucy(Jo ~on-Walsh Supe Ising Attorney F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PAl 70 13 (717) 243-2968 Fax: (717) 243-3639 c .", C- {.-~ " . ~- MICHELLE L. LOUTHIAN, PLAINTIFF/PETITIONER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. DAVID E. HARBAUGH, DEFENDANVRESPONDENT 98-2468 CIVIL TERM ORDER OF COURT AND NOW, this --1 C> day of April, 2006, following a hearing on a petition for emergency relief, IT IS ORDERED that Paragraph 7 of the current custody order of October 26,2005, IS VACATED and replaced with the following: The mother Michelle Louthian is granted temporary legal custody of Aaron Harbaugh, born October 20,1995.' By the Court, ,.// Kathleen McKoewn, Certified Legal Intern The Family Law Clinic For Plaintiff ~id E. Harbaugh, Pro se t 3913 RosemontAvenue Camp Hill, PA 17011 , ) / :sal \. ( ~\~~\e. L6ll..~\o..N I This order is entered so the mother can obtain the necessary residential treatment for Aaron at Philhaven. The suggestion by the father that physical custody should be transferred to him is wholly impractical at this time. The program at Philhaven is family directed and will allow both the mother and father access to Aaron during his time in residence. .:-.1 ~.",\ [-- L'- i~' TIME : 04/11/2006 14:58 I lAME : PROTHOHOT AR'i C LONG FAX: 7172486573 TEL : SER.# ; BROH3J606381 - TRAIISMISSlOI1 \/ERIFICA TION REPORT DATE, TIME FA>: NO. /NAME DURATION PAGE(S) F~ESUL T ~.10DE 04/11 14: 57 g243353'3 00:00:58 02 Of( STANDARD ECH OFFICE OF THE PROTHONOTARY CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, P A 17013-3387 (717) 240-6195 To: f:"o..u;'d,/ ~ (fl ~10 717 - rJ.tf3 - 3r; 3i Fax# From: Cumberland County Prothonotary RE: Loll-j..{{~^ v' JtU~u~ C-u~Jy Message: J- No of pages (including cover sheet) . ._-~--- .:1-....1 .e~~ ...l.", u...11. ......f 4oho ~",.Ii'(rin,,~l ....r pntitv to which it is MICHELLE L. LOUTHIAN, PLAINTIFF/RESPONDENT V. DAVID E. HARBAUGH, DEFENDANT/PETITIONER AND NOW, this ,",0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 98-2468 CIVIL TERM ORDER OF COURT day of April, 2006, the petition of David E. Harbaugh for emergency relief, IS DENIED.1 Edgar B. Bayley, J. Kathleen McKoewn, Certified Legal Intern The Family Law Clinic For ,~Iaintiff "~id E. Harbaugh, Pro se 3913 Rosemont Avenue Camp Hill, PA 17011 j :sal ~c-\e..\\e L6U~\Qn \j\o ~ /" \\ o ] See the order entered this date on the petition of Michelle Louthian for emergency relief. u._ ~:~ _".J .) . , ~: u_ {~ Ms. Michelle 1. Louthian, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY Mr. David E. Harbaugh Defendant : NO. 98-2468 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Ms. Michelle 1. Louthian , Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, D,,"~M06 / e vall Certified Legal Intern ~ oJCPA/t1 ~. ROBERT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH WILLIAM G. MARTIN Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 >. MICHELLE LOUTHIAN, Plaintiff/ Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LA W IN CUSTODY DAVID HARBAUGH, Defendant! Respondent No. 98-2468 PETITION FOR SPECIAL RELIEF SEEKING MODIFICATION OF THE PRIOR COURT ORDER PURSUANT TO P A R.C.P. 1915.13 AND NOW, this /1*ctay of April, 2006, pursuant to Rule 1915.13 of the Pennsylvania Rules of Civil Procedure, comes the Petitioner, Michelle Louthian, by her counsel, the Family Law Clinic, seeking modification of this Court's Order of April 1 0, 2006, giving her emergency legal custody of the minor child, Aaron Harbaugh, born October 20, 1995, so that the child could be placed in residential treatment at Philhaven Behavioral Health Services and receive necessary medical treatment. Petitioner respectfully requests emergency legal custody of Aaron Harbaugh so that he may be placed in a residential treatment facility, particularly The Bradley Center in Pittsburgh, Pennsylvania on April 25, 2006. In support of her Petition for Emergency Reliet~ Petitioner avers the following: I. The petitioner is Michelle Louthian ("Mother"), the mother of the child, residing at 27 Laurel Drive, Mechanicsburg, Pennsylvania 17055. 2. The respondent is David Harbaugh ("Father"), the father ofthe child, residing at 3919 Rosemont Avenue, Camp Hill, Pennsylvania 170 11-7814. 3. The child is Aaron Harbaugh, date of birth October 20,1995. 4. On October 26, 2005, this Court issued an Order in the above-captioned action pursuant to a stipulation and Custody agreement of the parties. The Order granted Mother primary legal and physical custody of the child until Father's release from York County Prison on February 21, 2006. Upon Father's release, Mother would have primary physical custody of the child and share legal custody with Father. 5. On March 28, 2006, Mother filed a Petition for Special Relief Seeking Emergency Custody Pursuant to PA R.C.P. 1915.13. Mother sought emergency legal custody of the child so that the child could be placed in residential treatment at Philhaven Behavioral Healthcare Services on April 13,2006, despite Father's opposition to the child's placement at that facility. 6. After a hearing, by Order on April I 0, 2006, this Court granted Mother the relief she requested, giving her temporary legal custody of the child. A footnote to the April 10, 2006 Order provides that temporary legal custody was granted to Mother so that she could obtain the necessary residential treatment for the child at Philhaven. 7. In order for Philhaven to admit the child, Mother's insurance company needed to authorize the child's placement at Philhaven by no later than April I 1,2006. 8. On April I 1,2006, undersigned counsel notified Mother of the April 10,2006 Order. 9. Mother notified her insurance company of this Court's April 10,2006 Order on April 11,2006, but the insurance company did not authorize the child's placement at Philhaven until April 13, 2006. Consequently, Philhaven was unable to admit the child into residential treatment. Mother cannot be provided a specific date for the next available admission. 10. On April 12,2006, Ms. Angela Burge, Aaron's intensive case manager, through the Stevens Center, secured admission for the child at The Bradley Center which is located in Pittsburgh, Allegheny County, Pennsylvania. The child is scheduled to begin residential treatment at The Bradley Center on or about April 25, 2006. Ms. Burge is also seeking to locate a facility for Aaron's case closer to home. Approval for this admission from the health insurance provider was obtained on April 13, 2006. I I. Similar to Philhaven Behavioral Healthcare Services, the duration of residential treatment varies by patient but typically lasts a minimum of six months. Also similar to Philhaven, the residential treatment program at Bradley Center will allow both Mother and F ather access to the child during his time in residence. 12. Mother is filing this Petition because she believes that this Court's April 10,2006 Order only gives Mother the authority to place the child in residential treatment at Philhaven Behavioral Healthcare Services. 13. Mother believes and therefore avers that it is in the best interests ofthe child that Mother be granted temporary sole legal custody of the child, pending further order of court, so that Mother can consent to the child's placement in a residential treatment facility. WHEREFORE Petitioner, Michelle Louthian, respectfully requests this Honorable Court grant Petitioner temporary sole legal custody of the Child, Aaron Harbaugh, so that Mother can ensure that the child is placed in a residential treatment facility. Respectfully submitted, ~/5~ Date Kathleen McKeown Certified Legal Intern LUCY JOHNSTON- ROBERT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX WILLIAM G. MARTIN Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013-2899 (7 I 7) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing Petition for Special Relief are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. Date: 1--/9, ()t:, " ~ -.... ,-""} -','I .--\ -n -'<"- ,.' ,,-,'~) ,.' MICHELLE L. LOUTH IAN, PLAINTIFF/PETITIONER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. DAVID E. HARBAUGH, DEFENDANT/RESPONDENT 98-2468 CIVIL TERM ORDER OF COURT AND NOW, this lo, day of April, 2006, no hearing will be scheduled on the within petition for emergency relief.1 Kathleen McKoewn, Certified Legal Intern ,{'~ :J4~"'" rJLL'PN._&.4 The Family Law Clinic (/ ? For Plaintiff David E. Harbaugh, Pro se - -t),?-:fe'e /h4J# ~//.f).', 3913 Rosemont Avenue Camp Hill, PA 17011 :sal I The order entered on April 1 0, 2006, granting Michelle Louthian "temporary legal custody of Aaron Harbaugh, born October 20, 1995," is legally sufficient for the mother to make a decision to have Aaron admitted for residential treatment, whether in Philhaven or another appropriate facility. L'} ~>J C " v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION-LAW : CUSTODY Ms. Michelle 1. Louthian, Plaintiff Mr. David E. Harbaugh, Defendant : NO. 98 - 2468 CIVIL TERM CERTIFICATE OF SERVICE I, Kathleen McKeown, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Petition for Special Relief on Mr. David E. Harbaugh, residing at 3919 Rosemont Avenue, Camp Hill, PA 17011 by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Mr. David E. Harbaugh, on the Sth day of May, 2006, as evidenced by the attached green card. 1cjjJwt!1'kt~- Kathleen N. McKeown :....=:.-c:=; Certified Legal Intern ~cJU- . FAMILY LAW CLINIC 4S North Pitt Street Carlisle, P A 17013 (717) 243-2968 Fax: (717) 243-3639 . (') ,.." = 0 c = -n :s:: "'"' '-' 0:' :3: :r::!! [!lV r- ;po "":r -< mFii ::= f' ..~ (/),):' I =86 ~~-- co 9 .." -,Ii :t:8 :3: ~~ ':? ~ ~ Ul ~ J:'" :...:: .-, ., 1. .. Do...", f.k~~l.. t!f1t~"lJ?; 11:$ .89/. .e(J$t~ ~, '.c. 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