HomeMy WebLinkAbout98-06911
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THERESA M. KECK,
Plaintiff
: IN TilE COURT OF COMMOO PLEAS OF
CUMBERLAND CCJUNTY, PENNSYLVANIA
vs.
NO. ~8-69ll CIVIL TERM
CIVIL AC1'ION - LAW
KENNETII D. WARDLE, JR.,
Defendant
IN CUSTODY
ORDER OF CXlURT
M ~
AND ~, this Jf day of
consideration of the attached custody Con liation eport,
and directed as follows:
, 1999, upon
it is ordered
I. The Mother, Theresa M. Keck, and the Father, Kenneth D. Wardle,
Jr., shall have shared legal custody of Kodi Wardle, born June 9, 1998.
Each parent 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.
2. The Mother shall have primary physical custody of the Child.
3. The Father shall have partial physical custody of the Child in
accordance with the following schedule:
A. on Sunday, January 24, 1999, and Sunday, January 31, 1999,
the Father shall have a period of supervised custody with the
Child for up to 8 hours, with the time period to be arranged
during the time when the Father's sister, Tina, is available
to provide supervision.
B. on Tuesday, January 26, 1999, the Father shall have an
additional period of supervised custody for up to 3 hours with
the same arrangements for supervision as provided in
subsection A of this provision.
C. Beginning on February 1, 1999, the Father shall have
unsupervised partial physical custody of the Child on
alternating weeks from Monday at 1:00 p.m. through Tuesday at
8:00 p.m. Beginning on Sunday, February 7, 1999, the Father
shall have unsupervised periods of partial custody with the
Child during the interim alternating weeks from Sunday at 1:00
p.m. through Tuesday at 8:00 p.m.
4. The parties shall make arrangements for custody of the Child over
holidays by mutual agreement.
5. Each party shall be entitled to have a one week period of custody
(uninterrupted) during the year for vacation upon providing 30 days advance
THERESA M. KECK, IN THE a:>uRT OF <XlMMCtI PLF.J\S OF
plaintiff : CUMBERLAND COUNT'i, PENNSYLVANIA
VS. : NO. 98-6911 CIVIL TERM
:
KENNETH D. \~ARDLE, JR. : CIVIL ACTION - LAW
Defendant : CUSTODY
CUSTODY CXN:ILIATIOO SlH'IARY REPOOT
IN A<XXJRDANCE WITH <nmERLAND CXXMl'Y RULE OF CIVIL 1'I(!J.n.tJRB
1915.3-8, the undersigned custody Conciliator submits the following report:
I. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
NAME
DATE OF BIRTH
CURRENl'Ly IN CUSTODY OF
Kodi Wardle
June 9, 1998
Mother
2. A Conciliation Conference was held on January 20, 1999 , with the
following individuals in attendance: The Mother, Theresa M. Keck, with her
counsel, Michael S. Travis, Esquire, and the Father, Kenneth D. Wardle,
Jr., who was not represented by counsel in this matter.
3. The parties agreed to entry of an order in the form as attached.
Jo.-^HO'~j dJ /1'7"'7
Date 0
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((v,....- i--L. JJ.~'I
Dawn S. Sunday, Esquire
custody Conciliator
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THERESA 1\1. KECK,
1'llIintiff.
IN TilE COllin OF (,O:\I:\ION I'LEAS.
(,lIMIlEIU,ANI) COIINTY. PENNSYLVANIA
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NO.
CI\'IL TEI{:\I (U~ 1:.1'//
KENNETH I). WAlmLE. .m.
J)efemlllnl.
CIVIL ACTION - LA W
CUSTOI)Y ACTION
OImER OF COURT
ANI) NOW. upon consideration 01' the ullaehed eompluint, it is hereby directed thulthe
purties und their respective counsel uppeur bdore\,~ ~\ , J ",\, j ESlJuire. the Conciliator,
utll~J,'I,\,\:','i, \'\", ',";\\" '1\\c\,Pennsylvuniu.on \d.~j'llhe ,)(', dayofhl..199lf;
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ut ~~M.. lor u Pre-Heuring Custody Conference. At such conlercnce. un em>rl will be made to
resolve the issues in dispute; or if this cannol be uccomplished. to define and narrow the issues to
be heard by the court. and to enter into a temporary order. Either purty may bring the child who
is the subject 01' this custody action to the conference. but the children's atlendance is not
mandatory. Failure to appear at the conference may provide grounds for entry 01' a temporary or
permanent order.
For the Court,
By "..'GiH \\1\ J\. >i\\\rl\~tY?tJ,
Custody Conciliator - (~~
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IFYOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
Persons
Addresses
Dates
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Since birth. the child has resided with the ti,llowing p~rsons and at the 1.,110\\ ing
addresses:
Mother
213 North Areh Street. Apt. II
06/09/<)8 - Date
Meehaniesburg. I' A 17055
The mother ufthe child is Theresa M. Keek. currently residing at 213 North Areh
Strc~t. Apartment B. Mechanicsburg. I'A 17055.
She is singlc,
Thc fathcr ofthc child is Kcnncth D, Wardlc. Jr., currently residing at 30 West Main
Strcct. Apartmcnt 1, Mcchanicsburg, l' A 17055.
Hc is singlc.
4. The relationship of Plain tilT to thc ehild is that of mother. The Plaintiff
currcntly rcsides with thc following persons:
Namc
Relationshin to the child
Amanda Keck
Half - Sistcr
5. The rclationship of Dcfcndant to thc child is that of father. The defendant
currently rcsides with the following persons:
Namc
Relationship
No onc.
2
6. Neither party Ims participated as a party or witness. or in another capacity. in
other litigation concl'rning the custody ofthc child in this or another courl.
7. Plaintiff docs not know ofa pcrsonnot a party to the proccedings who has
physical custody of the child or claims to have custody or visitation rights with respect to the
Respectfully submittcd,
child,
8, The best interest ,111.1 permanelll wellilre of the child will be served by
granting the relicf requested because:
A. Plaintiff has participated in the primary care of the child throughout
hcr life.
B. Plaintiff can provide a stable environmenl.
C. Plaintiff can provide a loving home.
9. Each parcnt whosc parcntal rights to the child have not becn tenninated and
the person who has physical custody of the child has bccn namcd as partics to this action.
WHEREFORE, Plaintiffrequcsts this Honorable Court to grant her sharcd legal
custody and primary physical custody ofthc child subjcct to thc fathcr's pcriods of libcral
visitation.
~~acl S. Travis
Attorney for Plaintiff
Supremc Court ID No, 77399
4076 Market Street, Suite 209
Camp Hill, PA 17011
(717) 731-9502
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TIIERESA M. KEeK,
l'etilioner/P lain tiff,
IN TilE COURT OF COMMON PLEAS
CUMIJERLANI> COlJNTY,I'ENNSYL VANIA
\'.
NO. 98.6911
CIVIL TERM
KENNETH 1>. WAIWLE, JR.,
Respondent/Defendant.
CIVIL ACTION. LAW
IN CUSTODY
PETITION FOR MODIFICATION OF A PAnnAL
CUSTODY OR VISITATION ORDER
TO THE HONORAIJLE JUDGES OF SAID COURT:
I. The Petitioner/Mother is Theresa M. Keck who resides at 213 North Arch Strcct,
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Apartment B, Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. The Respondent/Father is Kenneth D. Wardlc, Jr., who resides at 30 Wcst Main
Street, Apartment 3, Mechanicsburg, Cumberland County, Pennsylvania 17055.
3. Petitioner seeks exclusive legal and physical custody, or in the alternative
allowance of supervised visitation only by the Respondent of the following child:
NAME
PRESENT RESIDENCE
DOB
Kodi Wardle
213 North Arch Street, Mech., PA
6/9/98
4. The petition of mother respectfully represents that on January 25, 1999, an Order
of Court was entered for Primary Physical Custody and Shared Legal Custody with Visitation by
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the Respondent, a true and correct copy is hereby attached.
5. Because of the Respondent, the course of visitation and partial physical custody
been tenuous and difficult since entry of the order.
(" In th~ ~urr~nt order, "uragraph R provid~s thUl, "N~ith~r purty shull e()nSUIl1~
u/cohol to th~ point of intoxi~ution during his or h~r p~riod of custody with th~ Child:'
7. On or about Tuesday. April 20. 1999. during his p~riod ofvisilUtion with Ih~
child. the R~spond~nt did drink a/cohol to the point of intoxication. and ~ngug~d in a light with
lour othcr individuuls while holding th~ ~hild,
8, Police werc summoncd to the rcsidcncc of th~ Rcspond~nt, and thc child was
surrendcr~d to thc Pctitioncr by poliec.
9. Whcn a copy of the cxisting order was produced, indicating that the Respondent
had violatcd the order by his intoxication, and was asked to releasc thc child to polie~, the
Respondent did respond "[expletivc deletcd] the order," and meaning that he did not ear~ about
the ordcr or the child's safety.
10. As a rcsult of the incident, the Respondent was cited by the police.
11. As a result of the incidcnt. the Mechanicsburg police department did contact
Childrcn and Youth Serviccs to prevcnt the Respondent from further contact with the child.
12. The child is presently in thc physical custody of Petitioner at 213 North Arch
Street, Apartment B, Mechanicsburg, PAl 7055.
13. The January 25th 1999 Order should be modified because:
A. The Respondent has endangered the welfarc of the child,
B. Thc Rcspondent has demonstratcd contempt for a valid Order of Court.
C. Modifying thc Ordcr is in the best intcrest of preventing future harm to the
child.
2
THERESA M. KECK,
Plaintiff
I N THE COUIlT OF CO"1MON PLEAS OF
CUMBERLAND COUN1'Y, PENNSYLVANIA
vs.
NO. 98-6911 CIVIL TERM
CIVIL AC'.l'ION - LAW
KENNETH D. WARDLE, JR.,
Defendant
IN CUSTODY
ORDER OF CXlORT
, ~
AND NCM, this .:J5AJi. day of .v)<M.olt.....
consideration of the attached CUstody Conci iation ~eport,
and directed as follows:
, 1999, upon
it is ordered
1. The Mother, Theresa M. Reck, and the Father, Kenneth D. Wardle,
Jr., shall have shared legal custody of Kodi Wardle, born June 9, 1998.
Each parent 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.
2. The Mother shall have primary plysical custody of the Child.
3. The Father shall have partial physical custody of the Child in
accordance with the following schedule:
A. On Sunday, January 24, 1999, and Sunday, January 31, 1999,
the Father shall have a period of supervised custody with the
Child for up to 8 hours, with the time period to be arranged
during the time when the Father's sister, Tina, is available
to provide supervision.
B. On Tuesday, January 26, 1999, the Father shall have an
additional period of supervised custody for up to 3 hours with
the same arrangements for supervision as provided in
subsection A of this provision.
C. Beginning on February I, 1999, the Father shall have
unsupervised partial physical custody of the Child on
alternating weeks from Monday at 1:00 p.m. through Tuesday at
B:OO p.m. Beginning on Sunday, February 7, 1999, the Father
shall have unsupervised periods of partial custody with the
Child during the interim alternating weeks from Sunday at 1:00
p.m. through Tuesday at B:OO p.m.
4. The parties shall make arrangements for custody of the Child over
holidays by mutual agreement.
5. Each party shall be entitled to have a one week period of custody
(uninterrupted) during the year for vacation upon providing 30 days advance
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THERESA M. KECK
Plaintiff
IN THE COURT OF COMMON PLEAS Of'
ClJ1>mERLAND COUN1'Y, PENNSYLVANIA
vs.
NO. 98-6911
CIVIL TERM
KENNETH D. WARDLE, JR.
Defendant
CIVIL ACTION - LAW
CUSTODY
ClIDER OF CXXlRT
~ -
AND NCM, this day of U UN L
consideration of the a tache<! CUstody Conciliation Report,
and directed as follows:
, 1999, upon
it is ordered
1. The prior Order of this Court dated January 25, 1999 shall
continue in effect but shall be suspended to the extent of any
inconsistencies with the provisions of this Order, which shall take
precedence.
2. The Father shall submit himself to an alcohol evaluation to be
performed by a professional selected by agreement of counsel. The purpose
of the evaluation shall be to obtain a professional determination as to
whether the Father has a problem with alcohol abuse and to obtain
recommendations concerning further treatment or counseling if necessary.
The Father shall obtain a written report reflecting the opinions and
recommendations, if any, of the evaluator. The Father shall be responsible
to pay all costs of the evaluation.
3. Pending the outcome of the evaluation pursuant to paragraph 2 of
this Order, and an additional CUstody Conciliation Conference, if
necessary, the Father's periods of custody with the Child shall be
supervised by the Mother or another adult selected by agreement of the
parties.
4. pending the outcome of the evaluation pursuant to paragraph 2 of
this Order and an additional CUstody Conciliation Conference, if necessary,
the Father shall refrain from consuming alcohol during his periods of
custody with the Child.
5. In the event the professional conducting the evaluation determines
that the Father does not have an alcohol problem and that no further
treatment or counseling is recommended, the prior Order of this Court dated
January 25, 1999 shall be automatically reinstated in its entirety and the
provisions of this Order shall expire. In the event the professional
conducting the alcohol evaluation determines that the Father does have an
alcohol problem and recommends further treatment or counseling, either
party can contact the Custody Conciliator to schedule an additional Custody
Conciliation Conference. If the parties are not able to agree as to
whether an additional Conciliation Conference is warranted as a result of
THERESA M. KECK,
Plaintiff
: IN TilE COURT OF CCW10N PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 90-6911
CIVIL TERM
KENNETH D. WARDLE, JR.
Defendant
CIVIL ACTION - LAW
CUSTODY
PRIOO JUDGE: Edward E. QJido
CUSTODY CXH:ILIATICN SlH1ARY REPCRr
IN ACXXlIDANCE WITH <U!BERIJ\ND <XX.M'Y RULE OF CIVIL PROCEIXlRE
1915.3-8, the undersigned CUstody Conciliator submits the following report:
I. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
NAME
DATE OF BIRTH
ClIRIlfNrLy IN CUSTODY OF
Kodi Wardle
June 9, 1998
Mother
2. A Conciliation Conference was held on June 2, 1999, with the
following individuals in attendance: The Mother, Theresa M. Keck, with her
counsel, Michael S. Travis, Esquire, and the Father, Kenneth D. Wardle,
Jr., with his counsel, Lee E. Oesterling, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
Lu
Date
Da~qs~J:b{:f~
CUstody Conciliator
3 /97 /
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Kenneth I), Wardle, .Jr.
Plaintiff
JAN II 3 !UUQ.
II C;.7' {.'.'f //
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Theresu M, Keck
Delcndulll
OIWlm,OFCOIIIH'
And Now, this_duy of __' 1999, upon considemtion or the ullached
contcl11pt cOl11pluint, it is ordercd and directed as follows:
!. The prior Orders orthis Court dated January 25, 1999 and June 10, 1999 arc
vacated and replaced with this ordcr.
2. The Motheer, Theresa M, Keck, and the Futher, Kenneth D. Wurdle, .Jr., shall
have shared legal custody or Kodi Wardle, bom .June 9, 1998. Each parent shall
have an equal right, to be exercised jointly with the other parent, to make all major
non-cmergancy decisions affecting the Child's general well-being including, but not
limited to, all decisions regarding his health, education, and religion.
3. The Mother shall have primary physical custody of the Child.
4. The Father shall have partial physical custody of the Child during alternating
weeks from Thursday at 9:00a.m, through Saturday at 4:00p.m" and, during the
interim weeks on Thursday from 3:30p,m. until 8:00p.m. and on Saturday from
8:30a.m. until 4:00p.m. The Father's partial custody schedule shall begin with the
Father having custody on the interim Saturday on August 21, 1999 at 8:30 a.m.
The Father may also have custody of the Child at any other times agreed by the
parties,
5. The parties shall make arrangements for custody of the Child over holidays
by mUlual agrecment.
6. Each party shall be entitled to havc a one week period of uninterrupted
custody during the year for vacation upon providing 30 days advance notice to the
other party,
7. All exchanges of custody shall take place at the parties' residences unless
otherwise agreed by the parties.
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Theresa 1\1, Ked; has knowingl) disohe) ed 11.1.' viSllatlon order set filnh hy Ihe
Court. I would like proceedings to hegin to have her sland ill conlelllpt of court due
lulhe filllolling list of violalions:
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I. Novemher Ill. I 99lJ..Kodi was scheduled 1(lr a sleep over visitalion, Theresa
did not drop him off and would nol answer her phone when I called 10 inquire why.
2, November 27, I 99lJ--Visilalion w:ts 10 he fromll:30a.111. 104:00p,m, It was
anolher no show and once again she did not answer al her house or on the phone,
3, December 2,3, & 4, 1 999--Visitation was 10 be from 8:30a,m. Thursday
llloming until 4:00p.m, Saturday anernoon. This WllS another no show. I was able
to reach Theresa by phone this lime and lold her I was going 10 lake her hack to
court, lIer response. "Oh Well',
4. December 23. 1999..1 was scheduled to pick Kodi up at daycare aI3:30p.m.
When I gollhere he was nol present.
5. December 25, 1999--Visilation was 10 be from 8:30a,111. until 4:00p.m. It
was another no show and when Ilried 10 reach 'nlCresa Ihere was no answer.
6. December 30, 1999-- This was my weekend 10 have Kodi from 8:30a.m.
Thursday unlil 4:001',111. Saturday. Theresa did not drop him off and would nol
answer my phone calls.
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THZRESA M. K&:K, : IN TrIll ml{T or ~ PLEAS OF
Pll1intlft CUl'IBI'JU,Alm r.run.y, l'EtlNS'itVANrA
\In. NO. 00-6911 CIVIl. TERM
:
~O. WARDI,!, ,JR. :
D&fenddn t : CIVIL ACfION - LAW
: CUSTODY
CRIER OF WJRT
AND IUI, this 30 ~' day of ()u~!-;""Y , 1999, upon
oonsidet"!Ition of lhe attached C\lstody cOr;c~hation RO[JOt't, Ii: io ocdet'ed
and dit'ected ao follows:
1. The priot' Or:ders of this COuI't dated January 25, 1999 and June 10,
1999 l1t'e VZlcated and replaced \/it.h this Order.
2. The Mother, Therosa /'I. Keck, and the Fathet', Kenneth D. Wardle,
Jr., shall have shared legal custody of Kodi wardle, born June 9, 1998.
Each pat"ent shall hav", an equal right, to be exercised jointly with the
othet' parent, to make all lMjor non-emergency decisions affecting the
Child's general well-being including, but not limited to, all decilJiona
regarding his health, education and religion.
3. The Mother shall have primary physical custody of the Child.
4. The J:ather shall have partial physical custody of the Child dudng
alternating weeks frem 'l'hursday at 9:00 a.m. through Satur:day at 4:00 p.m.,
and, during the interim weeks on Thursday ft"all 3:30 p.m. until 8:00 p.m.
and on Saturoay fran 8:30 a.m. until 4:00 p.m. 111e Father's partial
custody schedule shaLl begin with the Father having c\letody on the interim
Saturday on AlJ9Ust 21, 1999 at 8:30 a.m. The Father may also have custody
of the child at any other times agreed by the parties.
5. The parties shall make arrangements for custody of the Child over
holidays by mutual agreement.
6. Each po.rty shall be entitled to have a one week period of
uninterrupted c~tody during the year for VIlC'.<Ition upon providing 30 days
advance notice to the other party.
7. All exchanges of custody shall take place at the parties I
residences unless otherwise agreed by the parties.
8. The Father: shall provide at least 24 how:s advance notice to the
Mother in the event he needs to cancel a period of partial custody.
9. In tho event the Mother: intends to relocate the Child's residence
from the Corrmonwealth of PenMylvania, the Mother shall provide at least 60
days adV4llCe noticu to tilC Father to t'fldbh tho partl..o to reviso the
c:u:ltody arrangelll&nta by Ilgrc~nt or h"vl.' the C1Jt'\tody i""Uf.'1I resolv~
thCt>U<jh the l~"llll U'iotern.
10. Neithflr party OOcl.11 con':Ul:no III enho ! :0 thf.. [..:.iIlL vI IntoxiclItion
durin;) his or har perioda or custody ..Ii th till' Child.
11. The Father shall r"m)'Jrt thllt the Mother':! tCllephont> calle to hilll
art! not blocked by his telephol1<t Llys:ern. 1l1c parties shall limit tl!}(ophono
call fl; t.o "dch otl1<:r to .:Ii tualioll.!l in 1.>11 I eh I t it! I1f'CeI3S<lry to di seu"
isou.s concerning Lhe Child or in too event of M (')m.~l'9()ncy.
12. Neither: porty shall do or say anytJdnq which troy e5tr~ thCl
Child frem the other pat'9llt, injure the opinion of thl' Olild liS to the
other parent, or hanpJr the Crell and Mtuc<ll develop1lp.nt ot the Child's
love a.'ld respect lor the ot.her pIlroot.
13. Thil!l Order is entet'ed pursuant tv .;Ill ':l<Jnernent of the parties at ...
CUStody COnciliation Confet'ence. The parties may ltOOify the provisi~ of
this Ol"der by nttual. consent. III the ilb;;!enco at mutual consont, the terms
of thLs Order ohall control.
BY 'IHE COURT,
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~rd 1';. GuuJo, J.
cc: Michael S. Trllvis, Esquire - col.ll'lSel for Mother
Lee E. ce"terling, E:.squira - COunsel for Father
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TlIEll.E$A M. KECI< , 1: l l1ie C'OUR1' '.Jlo' C'O.'Io'Y.lI 1'1.~:AS OF
Plaintiff : CllMfll::Rr.AN1l ('''aJN1'Y I PflINSYI.VA-JTA
V!J. NO. <},q-f>4 J 1 CIVrL 'rf:RM
:
KE:NNETII O. WARDLP., JR. :
De C elld",.!: CIVIL A~'XION - LAW
: C"JSTOOY
P1UCIl JODGIl: P'.dgar E. Guido
OlSlUlY ~ILIJI:rIm ~ REPCRl'
m AO:XIUJI\Ia H.mI CUIBBRI:.l\NO <XU'l.l'Y R1lLB C'E czv:n. ~
1915.3-8, the undersigned CUstody Conciliator oubmits the following report:
1. 'Itlll pertinent information concerning the Child who is the eubject
of this litigation is as follows:
aIlREN'I'Ly D! ~ OP
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NAME
w.TE OF BIRTll
KocH Wardle
June 9, 19'38
Mother
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2. A Conciliation Conference was held 00 Au;rust 18, 1999 , with the
follOlling individuals in attendance: Tho Mother, Theresa M. Reck, with her
counsel, Michael S. Travis, Esquire, and the Father, Kenneth D. Wardle,
Jr., with his counsel, Lee E. Oesterling, Esquire.
3. :the parties agreed to entry of an Or:der in the for:m as attached.
/l-vPd)f-
Date
C;.'{ /919
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Dawn S. SUnday, Esquire
Custody Conciliator
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TIIERESA M. KECK,
PlilintHf
IN TilE COURT Dr' COMfoION PLf:AS 01'
CU~lI\ERLAND COUNTY, PfJ..'NSYLVANIA
vs.
NO. 98-6911 CIVIl. TERM
KENNETIl D. WARDLI" JR.,
lJefcndilnt
CIVIL A~rION - LAW
CUSTODY
ORDER OF COURT
AND NaoI, this ~)A
consideration of the attached
and directed as follows:
day of F~
Custody conciliatR,n Report,
, 2000, upon
it is ordered
I. The prior Order of this Court dated August 30, 1999 is vacated and
replaced with this Order.
2. The foIother, Theresa M. Keck, and the Father, Kenneth D. Wardle,
Jr., shall have shared legal custody of Kodi Wardle, born June 9, 1998.
Each parent 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.
3. The Mother shall have primary physical custody of the Child.
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4. The Father shall have partial physical custody of the Child during
alternating weeks from Thursday at 9:00 a.m. through Saturday at 4:00 p.m.,
and, during the interim weeks on Thursday from 3:30 p.m. until 8:00 p.m.
and on Saturdays from 8:30 a.m. until 4:00 p.m. The alternating weekly
schedule shall continue with the Father having custody on the interim
Thursday at 3:30 p.m. on February 17, 2000. The Father may also have
custody of the Child at any other times agreed by the parties.
In addition to the periods of custody set forth in the preceding
paragraph, the Father shall have custody of the Child on Friday, February
18, 2000 at 3:00 p.m. through saturday at 4:00 p.m. The Father shall also
have custody of the Child from Thursday, March 16, 2000 at 9:00 a.m.
through Saturday at 4:00 p.m. These specific periods shall be in addition
to the Father's regular partial custody schedule.
5. The parties shall share or al terna te having custody of the Child
on holidays as follows:
A. CHRIS'mAS:
The Christmas holiday shall be divided into
Segment A, which 8h~11 run from 9:00 ~.m. until 9:00 p.m. on
Christmas Eve, and SC<Jmcnt IJ, which shall run from Christmas
Eve at 9:00 p.m. through December 29 at 8:00 p.m. The Father
shall have custody of the Child during Segment A in odd
numbered ye~rfl and during Segment [J in even numbered years.
The Mother shall h~ve custody of the Child during Segment A in
even numbered years and during Segment B in odd numbered
years.
B. THANKSGIVING: In every year, the Mother shall have custody of
the Child on Thanksgiving Day from 9:00 a.m. until 2:00 p.m.
and the Father shall have custody on Thanksgiving Day from
2:00 p.m. until 8:00 p.m. In the event the Father's regular
weekend period of custody falls immediately after
Thanksgiving, the Father shall retain custody of the Child
through the weekend at the regular time.
C. 1IAL~/'l'RICK-(JR-TREAT: The Mother shall have custody of
the Child on trick-or-treat night in even numbered years from
5:30 p.m. until 8:30 p.m. and the Father shall have custody of
the Child on trick-or-treat night in odd numbered years from
5:30 p.m. until 8:30 p.m., unless the Father's regular weekend
period of custody immediately follows trick-or-treat night in
which case Fa ther shall retain custody through his regular
weekend period.
D. The holiday custody schedule shall supersede and take
precedence over the regular custody schedule.
6. Each party shall be entitled to have a one week period of
uninterrupted custody during the year for vacation upon providing 30 days
advance notice to the other party.
7. The party receiving custody of the Child shall be responsible to
provide transportation for the exchange. All exchanges of custody shall
take place at the parties' residences unless otherwise agreed by the
parties.
8. The Father shall provide at least 24 hours advance notice to the
Mother in the event he needs to cancel a period of partial custody.
9. In the event the Mother intends to relocate the Child's residence
from the Commonwealth of Pennsylvania, the Mother shall provide at least 60
days advance notice to the Father to enable the parties to revise the
custody arrangements by agreement or have the custody issues resolved
through the legal system.
10. Neither party shall consume alcohol to the point of intoxication
during his or her periods of custody with the Child.
11. The Father shall ensure that the Mother's telephone calls to him
are not blocked by his telephone system. The parties shall limit telephone
calls to each other to situations in which it is necessary to discuss
issues concerning the Child or in the event of an emergency.
. rj1Et:{)!1 fll rEdl
Plaintiff
: IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
: PENNSYLVANIA
v,
· K.~nN'l/.. D, tV/1n>U, ,n: I
Defendant
: CIVIL ACTIO" LAW
:' No.1'b6flll CIVIL
: CUSTODY VISITATION
ORDER OF COURT
And now, this l{, ,- Ire' , upon consideration of the attached com laint, it is hereby directed
that the above pa ies and their respective counsel appear before ,,{.
Esquire, the conciliator, at . 1 W. I-I'/IN L"L...., (e "" ,
Pennsylvania, on the~':Ifh day of rY'Io.y ,2000, at I':DO".1 P,M.,
for a Pre-hearing Custody Conference. At such conference, an effort will be made to resolve the
issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard
by the court, and to enter into a temporary order. All children age five or older may be present at
the conference. Failure to appear at the conference may provide grounds for the entry of a
temporary or permanent order.
FOR THE COURT:
By:
YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE, IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
THE CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY A VENUE
CARLISLE, P A 17013
(717) 249-3166
1-800-990-9108
.....
6. Paragraph 10 of the current Order providcs that, "Ncither party shall consumc
alcohol to the point of intoxication during his or her period of custody with the Child."
7. On or about Tuesday, April 20, 1999. during his period of visitation with the
child, the Respondent drank alcohol to the point of intoxication, and engaged in a fight with four
other individuals while holding the child. A copy of the police log of the incident is attached
hereto as Exhibit B.
8. On or about September 18, 1999, Respondcnt was cited with disorderly conduct
when he asked a sixteen ycar old girl to perform a sexual act. A copy of the newspaper article
regarding the incident is attached hereto as Exhibit C.
9. On March 25, 2000, also during his period of visitation, Respondent was arrested
for assault regarding a fight with his wife. A copy of the newspaper article regarding the incident
is attached hereto as Exhibit D.
10. Because ofthese incidents and Respondent's pattern of abusive behavior when
he drinks alcohol, the best interest of the child will be served by modifying the existing Order to
terminate ovemight visitation by Respondent.
WHEREFORE, Petitioner prays this Court to grant the modification of custody to
terminate ovemight periods of visitation with Respondent.
Pelitionfor Contempt Gnd Paymenl of Cas Is
II. Respondent has wilfully failed to obey said Order of Court, specifically by
drinking to the point of intoxication and endangering the welfare ofthe child.
12.
Your Petitioner is on a limited income. Petitioner requests that the Court award
her attorney fees and costs in the amount of $400.00. Rcspondent has the ability to pay attorney
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fees and costs,
WHEREFORE, I>etitioncr prays this Ilonornble Court to adjudgc thc Respondcnt in
contempt of Court and Order payment of counsel fees and costs or such other relief as the Court
may deem fair and just.
Respcetfully submitted.
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Michacl S. Travis
Attomey for Petitioner
Suprcmc Court ID No. 77399
4076 Market Street, Suite 209
Camp Hill, PA 17011
(717)731-9502
VERIFICATION
I verify that the statements made in this Petition are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authoritics.
DATED: I-f 3 '1/7)
-tit (J( (11)(:1 ,Jllt'( f
Theresa M. Keck, Petitioner
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THE:RESA'M. KEel< , : IN T"riE OOURT OF CXlMMO!. PLEAS OF
Plaintiff : CUMBERLAND COUN'n', PEl~5YL VANIA
:
VB. : NO. 98-6911 CIVIL TERM
.
.
KENNETH D. WARDLE, JR., : CIVIL ACTIOO - LAW
Defendant :
: CUSTODY
CRDm OF CXXlRT
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AND tOI, this 2 2 ~ day of
consideration of the attached Custody
and directed as follows:
, 2000, upon
it is ordered
1. The prior Order of this Court dated August 30, 1999 is vacated and
replaced with this Order.
2. The Mother, Theresa M. Keck, and the Father, Kenneth D. Wardle,
Jr., shall have shared legal custody of Kodi Wardle, born June 9, 1998,
Each parent 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.
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3. The Mother shall have primary physical custody of the Child.
4. The Father shall have partial physical custody of the Child during
alternating weeks from Thursday at 9:00 a.m. through Saturday at 4:00 p.m.,
and, duri"9 the interim weeks on Thursday fran 3:30 p.m. until 8:00 p.m.
and on Saturdays from 8:30 a.m. until 4:00 p.m. The alternating weekly
schedule shall continue Io1ith the Father having custody on the interim
Thursday at 3:30 p,m. on February 17, 2000. The Father may also have
custody of the Child at any other times agreed by the parties.
,
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In addition to the periods of custody set forth in the preceding
paragraph, the Father shall have custody of the Child on Friday, February
18, 2000 at' 3:00 p.m. through Saturday at 4:00 p.m. The Father shall also
have custody of the Child fran Thursday, March 16, 2000 at 9:00 a.m.
through Saturday at 4:00 p.m. These specific periods shall be in addition
to the Father's regular partial custody schedule.
5. The parties shall share or alternate having custody of the Child
on holidays as follows: EXHIBIT
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A. C8RIS'lMAs:
The Christmas holiday shall be divided
A
(
Segment A, which shall run from 9:00 /l.m. until 9:00 p.m. on
ChriBtmas Eve, and S&g1nent B, which shall run frcm ChristmaB
Eve at 9:00 p.m. through December 29 at 8:00 p.",. The Father
shall have custody of the Child during Segment A in odd
numbered years and during Segment B in even numbered years.
The Mother shall have custody of the Child during segment A in
even numbered yearB and during Segment B in odd numbered
yearB.
B. TBANKSGIVING: In every year, the Mother shall have custody of
the Child on Thanksgiving Day fran 9:00 a.m. until 2:00 p.m.
and the Father shall have custody on Thanksgiving Day from
2:00 p.m. until 8:00 p.m. In the event the Father's regular
weekend period of custody falls immediately after
Thanksgiving, the Father shall retain custody of the Child
through the weekend at the regular time.
C. ~/'IRICK-<R~: The Mother shall have custody of
the Child on trick-or-treat night in even numbered years from
5:30 p.m. until 8:30 p.m. and the Father shall have custody of
the Child on trick-or-treat night in odd mmbered years from
5:30 p.m. until 8:30 p.m., unless the Father's regular weekend
period of custody immediately follows trick-or-treat night in
which case Father shall retain custody through his regular
weekend period.
D. The holiday custody schedule shall supersede and take
precedence over the regular custody schedule.
6. Each perty shall be entitled to have a one week period of
uninterrupted custody during the year for vacation upon providing 30 days
advance notice to the other party.
7. The party receiving custody of the Child shall be responsible to
provide transportation for the exchange. All exchanges of custody shall
take place at the parties' residences unless otherwise agreed by the
parties.
8. The Father shall provide at least 24 hours advance notice to the
Mother in the event he needs to cancel a period of partial custody.
9. In the event the Mother intends to relocate the Child's residence
fran the Conmonwealth of Pennsylvania, the Mother shall provide at least 60
days advance notice to the Father to enable the parties to revise the
custody arrangements by agreement or have the custody issues resolved
through the legal system.
10. Neither party shall consume alcohol to the point of intoxication
during his or her periods of custody with the Child.
11. The Father shall ensure that the Mother's telephone calls to him
are not blocked by his telephone system. The parties shall limit telephone
calls to each other to situations in which it is necessary to discuss
issues concerning the Child or in the event of an emergency.
DISPATCH INCIDENT: 199904( 146 Men
CALL TYPE: FIGHT
~~\Vlij@
I'AGE: 1
LOCATION
GRID CCL UCR IPG DISPO PRI
-------------------------..---------------------------------------------------
00030
W MAIN ST
0404 241 0000 Y
11
3
ALARM CTAK DPAT VEH-REGISTRAT MAKE
DATE
RECV 0151' lIRRV CI,J{ TOT,), RE:I'
.. .. .. .. .. .. .. ... .. .. ... .. .. .. .. .. .. .. .. ... .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. . .. .." .. .. .. .. - .. .. .. .. .. .
N
IS
WRM1
19990420 1923 1829 1830 1051 1408
UNIT BAOG OFFICER
------------------------------------------------------------------------------
41
46
POV
15 MENESES
9 AGRESTA
1 WHITCOMB
WILLIAM
SHARON
RODNEY
R 19990420
L 19990420
L 19990420
1829 1830 1851
1829 1830 1851
1829 1838 1851
NAMES: WARDEL JR KENNETH K (A) 717 691 9153
30 W MAIN ST #3 MECH,PA. W/M,DOB:09/18/6S,SOC:186-60-5162
KECK ROBERT L (A) 000 000 0000
128 E LOCUST ST MECH,PA. W/M,DOB:05/10/78,SOC:202-58-99~5
DRESCHER JOHN T (0) 000 000 0000
14 SCHOOLS IDE DR MECH,PA, W/M,DOB:04/24/77,SOC:180-62-6778
SHARP JASON R (0) 999 999 9999
NONE
VONNI EDA RAYNER G (0) 999 999 9999
1 REYNOLDS ST MECH, PA. W/M,DOB:Ol/22/82, SOC:223-23-43S3
SHERIFFS DEPT CUMB COUNTY (0) 717 238 9676
DEPUTY SMITH AND CORPORAL BARRICK ASSISTED AT MY REQUEST
COMMENTS: WARDEL AND KECK WERE INTOXICATED. AS DRESCHER,
SHARP AND VONNIEDA WALKED UNDER THE BALCONY OF
WARDEL'S APARTMENT, KECK BE~~ TO VERBALLY ~~USE
THE THREE, HE ACCUSED THEM OF STEALING AND BURNING
HIS TRUCK.
BOTH HE AND WARDEL LEFT THE APARTMENT TO CONFRONT
THE THREE ON THE STREET LEVEL. WARDEL WAS CARRYING
HIS YOUNG CHILD IN HIS ARMS. *REFERAL WILL BE MADE
TO CHILDREN AND YOUTH SERVICES (DISP 1999-04-248).
WARDEL WAS LOUD AND UNCOOPERATIVE, THIS WAS THE
SECOND FIGHT THAT WARDEL WAS PRESENT AT FOR THIS
SHIFT. BOTH HE AND KECK WERE INTOXICATED. THEY
WERE BOTH WARNED WITH (M) DISORDERLY CONDUCT.
.
CITATIONS FOR PUBLIC DRUNKENNESS TO BE FILED
AGAINST BOTH KECK AND WARDEL, NO CHARGES AGAINST
DRESCHER, SHARP OR VONNIEDA.
.
REFER TO DISPATCH #1999-04-248 FOR A CUSTODY ISSUE
INVOLVING THIS DISPATCH.
PUBLIC DRUNKENNESS CRIME REPORTS 201 AND 202-99
EXHIBIT
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DISPATCH INCIDENT: 19990,\, 248 MCB (
CALL TYPE: OFFENSES AGAINST FAMILY & CHILDREN
PAGE: 1
LOCATION
GRID CCL
UCR IPO DISI'O PRJ
00030
W MAIN ST
0404 200 0000
y
06
J
ALARM CTAK DPAT VEH-REGISTRAT MAKE
DATE
RECV DISP ARRV CI.R 1'01'1' HEI'
--.-.-----------------------.-----------------.------.---.-------.----.---.---
N
15
WRMl
19990420 1845 1845 1845 1851 0006 N
UNIT BADG OFFICER
41
46
POV
15 MENESES
9 AGRESTA
1 WHITCOMB
WILLIAM
SHARON
RODNEY
R 19990420
L 19990420
L 19990420
1845 1845 1851
1845 1845 1851
1845 1845 1851
NAMES: KECK TERESA M (C) 717 796 1848
213 N ARCH ST MECH,PA. W/F. ooB:Ol/3I/72. SOC:206-48-4235
WARDEL KENNETH 0 (0) 717 691 9153
30 W MAIN ST #3 MECH, PA. ooB:09/18/65, SOC:186-60-5162
SHERIFFS DEPT CUMB COUNTY (0) 717 238 9676
DEPUTY SMITH AND CORPORAL BARRICK C.C.S.D. ASSISTED MY REQUEST
COMMENTS: REFER TO DISPATCH #1999-04-248 AND CRIME REPORTS
201 AND 202-99.
.
WHILE AT THE PREVIOUS DISPATCH, FIGHT AND PUBLIC
DRUNKENNESS, KECK ARRIVED AT THE SCENE WITH A
COURT ORDER, SEE ATTACHED ORDER, WHICH STATES ON
PAGE 2 #8 THAT NEITHER PARTY SHALL BE INTOXICATED
WHILE HAVING CUTODY OF THEY'RE CHILD.
WARDEL WAS NOT ONLY INTOXICATED, HE LEFT HIS APART
-MENT TO ENGAGE IN A CONFRONTATION WHITH THREE SUB
-JECTS WHILE CARRYING THE BABY IN HIS ARMS.
FOR THE CHILDS SAFETY THE ORDER WAS ENFORCED.
I ASKED WARDEL TO GIVE RECK THE BABY DUE TO HIS
CONDITION. HE RELUCTANTLY COMPLIED.
I WILL CONTACT CHILDREN AND YOUTH SERVICES REGARD-
-ING WARDEL'S ACTIONS WHILE HOLDING THE BABY.
A CITATION FOR PUBLIC DRUNKENNESS WILL BE FILED
AGAINST HIM.
-- a Mechanicsburg
\ couple:We'reinnocent
, By JOlGph CreiS Ihe ~\ll came Oul of a nearb~ build.
! s,ntln,l R,pontf in~ '" !>u~ ~oda~ al a vending
.\ _ ___- llIaehine aClO~S Ihe slleel. !-Ie ~a\d
\ A Meeh.nic~!>urg ""man ha' Ihe inlo~ica,ed man on tile slIeel
aceu"d a \lOrough rolice (lmeel of "as Ih. one ",hi> llIade lhe le\lld
\ failin~ 10 do his dUI}' ."d I'rcaledl~ comm.nl. and Ihe girl m\sta~enly
, ,.\ ha..~sing h.1 b~ liling citalions.., idenlifl.d Wardle as the colpril, :."
" Jean.ne Wl\fdle 01 ~O W, Main St. W31dl. said the offieel has a pel"
'\ wcnl \lclore bOlough couneillasl ,onal 'endella agarnst him and has
, weel. 10 complain a"',ol an alleged fII.d groundless citations against
S'r\. IS inridenl, him and his wife,
She said Ih. t>ffieer "1t>ng(u1IY The t>mccI. ,",'hI>se name is being
is,"cd cilalions apin" her and hCI wilhheld because he haS not been
hu,!>and bul did nt>lhing ahllUI an charged .,ith ,",'Iongdoing. said he
intoxicated man she alleges <'I"'"d went 10 Main Street mat evening 10
himself and used o\l",enc language in"sligate a disorderly conduct
and ge'IU'" "hile "all.in~ ur and comrlainl, \lpon arriving, he Ullked
down Main S\l..llhal esening. liTSI 10 Ihe Waldles. asl.in~ if mere
In a phone intelS ic" Frida} the wa' a plohlem, The officel said mcy
. officel said hc did hi, dutS. as a an'\\clcdlhallhCle was no plohlem.
I. police t>ffieel and issued the cila. The omCCl said he men spo~e 10
lions !>a;ed on information he the caller, who described and poinl-
I receiscd Icgardin~ Ihe incid.nl. Hc ed out WaldIe and agreed to Icsti(y
said he ncs'er saW the into,icated in court. The callel also a~reed 10
man on Ihe sueel Ihat ni~hl. !-lad he plo,'idc a wrillen stalement of what
,een lhe indi-idual Of had hc happened todore, durin~ and afler
Icceis'ed a complainl atoout him. he thc olftcer's ams'al at me seene,
said. he would h,\e in\csti<ated, Based on Ihat. me o!f>c" said he
MIS. \\'3Idle s,ld ,he, her hu,\land had enough probah1e cau" to issue
Kenneth and another man "ele cilalions againSlthe Waldles,
,'id,otaping the inlo,icalCd man flom Borough SolicilOI William Sunday
the haleony o( Ihell apartmenl when told 1'011', WaldIe lasl wee~ that
the olfte" arti\ed and \Old her hU'- council is a legislali" bO<l~ and she
hand and th' olher man thatthe\ had should ta~e her concerns \lCfote the
J h<,n identm,d in an inddent io\ol\- court, council presidenl Gelald FOI'
ing a teen,agcd ~ill and Ihal each f) agreed, saying "this has nOlhing
would receive a criminal dlation, 10 do with horoUgh council:'
MIS. Wardle said th' officer did police Chid Rodnes Whitcomb
nol ad,i" them o( the e,acl chalge, would nOI cortunent on-the Wardles'
II was only laler that het hushand citalions, He did sa~ he received a
lecei\ed a disorderly conduct dla. coPy of Ihe War dles- videolape a
tion saying he asked a 16.}e3l-01d month aftelthe aneged incident.
gill to retform a sexual act, Mrs, The chief said the oflieer did not
WaldIe ""d she al,o leceived a elta, see Ihe aelions of the man me W3I-
tion in the mail in connection wilh dIes alleee ~'a' inloxicated. In light
the c\Onl' Ihal night. of the laPe' an investigation is undel
Kennelh W3Idle lold The Sentinel w'y and chatges ma~ he filed againSI
that, alone point duting me evening, mat indi\idual, Whilcomb said.
,n Kenneth
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10 Ibe ..i,\in~ m.ddle "h,.,I,
lartici-
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Wall) Shan\,rfh' Senlinel
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l Halloween parade
\~ more gymna."lk~ te~m.
',1' I F6-l, fanelest; Gill Horses
,l~, ,eariesl; Junier ',ifitstplace, Sands' Marshall,
,p6:>I,me,IComieal;' '.6mallnoals -
1$53 ,nd Juniol Gill '..'first place, Eric and John
l. moSl original. Gaspieh: second place, Blownie
sTroop 1865.
.PYA1- cheellcadet" . ~ ',Large floats
P'i,",1- pee Wee foot- r J'irsl place. E,P, Schanel Scniol
place, W,S, YMC..... ~.~ter Rhylhm Raseals,
''"':' -'~;.
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(s~ie ,_. -. --,-~-'.~~creiih car'iS~ iirl~'{(e-ifi[wv~1!,~)~n;.~~u ~"'i~"I')';)I>i-'iI :--
O<L'~9. 1957; . son, Carl E, of A' t ' .
pbenburg' Ihree daughlers vmy p.Kk conra'nlng cred,l card., monel and idenuficallon "asSlolen ,
tab A. Soll~nberger of Waynes: ~I Fa.. Edd,... in lhe fi"l block of WeSI HIgh Sueel, Carlisle, Sunc1i)' mom,
, Mary 0, Ben of Fayeneville .ng, Carll\te pohce 53Y bel,:,een I and I :J() a,m. 'omeone olole the small
!.Ois M, Allen of Chambenburj; blue pIck belong'nglo Knsun Me"ner, 28, from the bJl'.
iler, Louise B, Hunsecker:Of -"" h ' . .
JIlbcrsburg; Ihree brOlher.;,;'lfIerC ant S sign taken down '
lnc< B. and Mahlon B" both c\r, "
JIlbersburg and Russell 8. 'of' A ha.nd'pll~led ..gn was Iaken fromlhe Herh Merchanl on We'l Pomrret
)sbu'll; and 10 grandchildren,'" Slreel.''' C.rll,1e ,ulllell"~e "';1I.een Thur,d.y nighl and Friday muming,
I was preceded in dealh by a Carlisle police say me "gn IS ,alued al SIOO.
her, Orville B,
IC Rev, R, Lero)' Eberly and the
, James Sollenberger, his son,in.
. will officiale al se"ices, Burill
: be in Air Hill Cemelery, Cham.
lIourg,
riends may call Tuesday from 6 10
,m, al Thomas L, Oeisel Funeral
me. 333 Falling Spring Road,
.mbenburg, and Wednesday from
~ 10 10:30 a,m, al the church,
,temorial conlribulions may be
Je 10 his church,
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Police probe assault in Carlisle
Carlisle polke are looking for a man "ho alleged I)' assaulted anolher man
Sunday morning al Veleran's Park on Soulh Hanmer SUe<l,
Police say a\ 3.,"!, Oeorge A, Die". 21. repuned he "'JS a"ailing a ride
home an., dnnkmg 10 the bars dO"nIO"n "hen. Hi,pank man wilh a bald
or sha\'ed head approached him on fOOl and hil him in the face.
Dietz was nol familiar with (he: person. The man is was last seen watking
nonh onlo :\onh Hanm'er Sir'" from Ihe Square,
Police say the man had a medium build and was !>erween 5 feel. 7 inches
and 5 feel. 8 inches lall,
Di~ll sUSlained bruising and s"elling 10 his righl eye bUI did nOl seek
med,callre.,men!. Police ask anyone wilh informalion 10 call 243-5252,
ams
Je is survi\'ed by his wife, Berty L.
:Allen Adams; a son, Douglas R,
Spring Run; a daughler, Deborah
of Eden\'ille; a siSler, Rose G.
hnson of Chambersburg: Ihree
andchildren: and se\'eral nieces and
:phews.
Funeral ser\'ices will be held
:ednesday al I I a,m. in John L,
gen Funeral Home, 18875 Main
I.. Dry Run, with the Rev, Ted Hale
fficiating, Burial will be in Lower
ath Valley Cemelery, Fanneltsburg.
Friends may call Tuesday from 7 10
p,m, al the funeral home.
Memori.1 conlribulions can be The following people were com milled 10 the Cumberland County Prison
"dc, ID HospiceJof the Good Shep- b~ Distri~l Ju.<lice Roben Manlo\'e o\'er Ihe weekend and, remained there
- --_u,,,.,,,,'" o.1i' i,; ;~,,;;'f~~s ~~~ ~~umr ~urWa -;;"11'0<(1 piIe1Jj;q-"'~;;''H'l,,/O};.,"Q;' "-I
' on 10 UIOa 'dd." '';:jnql!'t\ Ol"/ 0l[J JO uos "1-1 W; ,
UI!'~nn.UlJ7~L.<7 . S!I\\ ;Ill..;
.....:.u2r..llfoj:(~.". .
Couple charged with simple assault
A Mechanicsburg couple was arrc>led for simple ",sault, and Ihe husband
remains in Cum~rland Counl)' Prison this morning.
Mechanicsburg police say al I: 13 a,m, lhey recci\'Od a rcpon of a 911
hangup call from the firsl block of Well ~lain SUeel. Officers responded and
fou,nd Kenneth Wardle Jr",3-1, ~nd JeanelleWardle, 32. engaged in a fighl at
thelt resldenc~. Both suslJlned InJunes. police say.
MIS, Wardle was Irealed and rekased from Harrisburg Hospilal.
801h were arr.igned by DiSlricI Juslice Roben Manlo.e,
Wardle's bail was sel al 535,000 bail. He remain in the pri.on this mom-
(g, Mrs. Wardle's bail was sel al 55,000, which she posted. "
Three held in Cumberland County Prison
EXHIBIT
D
MICHAEL S. TRAVIS
AT TQUNf.: '( AT LAW
"016 .....AR...r:f "'~Hf[tf. !iUlft <"0..-
C AM'> IlIU. PAt. '7011
fLlll"H:lflr, "," , II '",0,0,'
"A1t "1/' 1,111.1"1'
April 4. 2000
[
1'-
, ~.
Office of the Prothonotary
and/or Custody Conciliator
One Courthouse Square
Carlisle, PA 17013
Re: Theresa M. Keck v. Kenneth D. Wardle, Jr., No. 98-6911,
Pelilion to Modify CIISIOl(1'
To thc Court and!0r Custody Conciliator:
Please be advised that petitioner's counsel will be out of town between May 1 and 15,
2000, Kindly do not set this matter for a hearing or conciliation between those dates,
Very truly yours,
Should you have any questions. please contact my office,
/~
/:d?
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1:.' ~~~~~
~ ~Tr;vis
Attorney for Petitioner
MSTlhm
, ,
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.:.',. ~,I;, '.J ~! I} r\~ ~~: r tl
CU;,:\:,~J _I' "J ,.:J'J:..1Y
i:c.Ni~Sl'll,,;~,:A
'. '
THERESA M. KECK.
Pelilionerll'lninti fr,
IN TIlE COURT OF COMMON PLEAS
CUMIJEI{LANI> COUNTY, PENNSYLVANIA
v.
NO, 9H.(J9I I
CIVIL TERM
KENNETH D. WARDLE, JR.,
Respon den t/Derendn n t,
CIVI L ACTION - LA W
: IN CUSTODY
CUSTODY STIPULATION ANI> AGREEMENT
AND NOW. comes the parties hcreto, Plaintiff: Thcresn lVI, Keek (Mothcr) nnd
Dcfendant Kenneth D, Wardle, Jr" (Falher), as said pnrties hnve reached II mutual agreement
with respect 10 the Petition to Modify Custody filed by Plaintiff on April 4. 2000, and hereby
stipulate to the following modified custody agrecment, and hereby request the Court to enter
same as an Order of Court:
I. Mother and Father share Icgal custody ofthc child Kodi Wardle, born June 9, 1998,
2. An Order of Court with respect to the child was entered on February 22, 2000, a copy
of which is attached hereto as Exhibit A,
3, Mother and Father agree to terminate Fathcr's overnight visitation for a period of six
months from the last date of signature of this agreement.
'\
,
I
I;
,
4, Further, Fnther's periods of overnight visitation will again begin only after successful
completion of drug and alcohol awareness program, evidenced by a certificate or letter of
completion from the course instructor,
i
...
5, For the purposes ofthis agreement, fathcr's visitation will end at 8:30PM during his
usual custody schedule,
JL.." H 1\;: ;~: ~t~er aspects of the February 22, 2000, Order will remain unchanged,
1'1 petlwt\~i\ij\ I
enneth D, Wardle, Jr" Defendant
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Witness
Witness
EXHIBIT
::t-
d(
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T"~1.'M. KECK, . IN TriE c:l(;~T 0: CO'N::t: PLEAS OF'
.
Plaintiff . CU':Es!:?.:J.!;.:> CCtJ';,'TY, P ::~sn V J... >;:u.
.
:
VII. . NO. 99-6911 ClVIL Ti:".M
.
.
.
m~..:..H D. ~LE, JR., : CIVIL I.C'l'Ic:r.I - U.W
De!e:\~Il,."lt .
.
. CUS'l\?D:{
.
CP.!>-::l'l OF CDJilX
J...'O to.., this 2 2 ~ cay of
cO;"..5idC':-ction o! the attb,:.';e-:: C'~to:y Co:"lciliation
~~ cir~=ted as fclJo~s:
, 20Y.J ( u;x:>n
it is c:,d~:,ed
1. ~e prior O:'.:Ser of this Co~t c=~eC l,~:ust 30, 19?3 is \'aca~ed e."ld
replaced .'ith this O:':ier.
2. The M:>:"ie:', ~,e=esa 1':. ::e-::k, and t..;e Father, 1:e:l..,eth D. v:c.!"c!e,
Jr., s!Jall ha'~e s~a:'eC le-:;al C'~s~oCi of Koei .:a:,cle, born Ju.,e 9, 1938.
Each pa:'ent s!Jall ~.:\'e a., e-:;.;.:,! right, to be exercised jointly ~:ith the
oth~:, pc.:,ent, to r.al:e all r.cjo:, nO:1-e.-;~:';~:1:Y de-cisio:1S affecting the
C'1ilci's gene:'al .'ell-being inclucing, but not Hr.,ited to, all o..cisions
r~=:'cing his health, &=ucatio~ ~~ re1ision.
3. ~e ~:othe:- s.'1a11 have p:-i..cry p.iysical C'~s~o=y of the Child.
4. The Father shall have partial physical =~oCy of t.ie Child during
alternating veeks from Thursda)' at S:OO e.m. through Saturday at 4:00 p.m.,
and, aurin; the interim .'c-e~.s on Thurs:Jay fran 3: 30 p.m. u.,til 6:00 p.m.
a.,d on Saturdays from 6:30 a.m. u..,til 4:00 p.m. The alternating "eek.Iy
sched'cle shall continue loo'ith the Fatl..er having custody on the interim
:rhur.sciay at 3:30 p.m. on Fe~ru'ry 17, 2000. The Fatl',er Iray also have
=.stody of the Chile at any otl..er tir.>es agreed by the pc.:,ties.
In a6<:lition to the ?=do:::s of C'Usto::ly set forth in the preceding
paragraph, the Fat-ier shall have C'~stoai of t."le Child on i'ricay, Febn.:a:y
18, 20:>0 at' 3:00 p.m. through SatU:'oay at 4:00 p.m. The Fat.'ler shall also
have custody of the Child fran Thursday, /".a:-ch l6, 2000 at 9:00 a.m.
through Saturday at 4:00 p.m. ~ese s?=,cific periods shall be in a:idition
to the Father's re;,""U1ar pc.rtial C'~stody schedule.
5. The parties shall sha:-e or al ternate having custody of the Child
on hoJica)'S as folIo.'s: EXHIBIT
A.~:
The Christr..as holiClay shall be divided
A
.'
!)(
:')(
~~.,~t A, which s.~.all run {rom 9:00 a.m. u,til 9:00 p.m. on
O'.ristr..u tve, an~ s..;:-oe~t B, ~-!',ic.'l shall nrl from Chr!5tr.4.S
FVI! at 9:00 p,m. thrQ~gh ~~~~~r 29 at E:oo p.m. The Father
s~.all have Cl:5tod't of the Child dOJdng S~nt A in odd
m:'~reod yn:s a.,d dudng Seog:';oel'lt B in even n-.::-bereod )'urs.
The t\~ther shall ~,~ve Cl:.Stody of the Child during S~l'It A in
Iven mr.-bend re~s a.,d dJI'ing ~l'It B in odd n\r.'~reod
ye!.:"s.
B. m/..'i'".s::::IVlNG: In eVlOr)' y"ar, the I",other shall have c:ustod't of
the Child en ~.~~iving ~y frc:rn 9:00 e.m. until 2:00 p,m.
a."ld the rather shell have C1;Stod't on Tha.~.~iving Cay fran
2:00 p.m. until 6:00 p.m. In t."e event the Father's r~lar
~~~e~d ~riod of CJstod't falls i~ietely after
Th~-.,-","h'ing, the Fat."er shell retain C1.:stody of the Child
tl'.ro:J;h t."e "Hh~c at the re-;\:la: time.
C. EA!.!.o..~/TRIO:-a:\-~: The ~;:>:""lOr shall ha\'e custoC}' of
the C"lild on tric:J;-or-t:-lOat night in e'.'el'l n-:~:-eC )'ears from
5:30 p,m. u"ltiI 6:30 p.~. a.o t."e rat.~er shall have custod't of
the Clild on tric:J;-or-t:-lOat night in oX! n-:~:-eC years fr::>rn
5:30 p.m. u,til 6:30 p.m., u11ess t."e Fat.~er's regula: "ee~end
period of CJstoCy ~~iate!y fo!!o~s tric:J;-cr-treat night in
...ohich case Fat..';er s~~all retain cu.sto=y thro'.Jgh his reg~!ar
~'e-e~en::! ~dod.
D. The h~licay cJS~:>,-'"y sc.~eC-=1e s;al1 s:J~rseCe a,d take
p~~=~~~~ce over the regular C~~O=i sc~~~~le.
6. Ecoch FCrty shall be e,titled to have a one ~'e-ek ""dod of
u.-,in~e-rrupted C"~s-tXi' di.l!"ing t.."e rear for \:::c..:tion c?=>n provicing 30 ca~'s
a=va~ce notice to ~ie ot},~r pcrty.
7. The pert}' re::eivir>;1 custe>.."y of t."e C"iId shall be responsible to
p:"o.~.ide trar..stortction fer t:Je exc.L.,::..i3e. .tJl excr,a."1ses of Cl.:sto::y s~all
ta!:e place at the perties' :-es:eac.ces u.-Jess othe-:-.'ise a;:-e-ed by the
parties.
8. The fathe:- s";all predee at least 2<: h:>u:-s c::"E:.."lce notice to the
/',ot."e:- in the event he ne-e--'--s to ca....,~el a ~rico of partial c-.:stody.
9. In t.;e e"ent t.~e ~;C~"er inten:is to relocate the C~ile's resieen~e
fran the Co..:r.on'.'ealth of Fe-nns\'!vania, the ~;:>t.;er shall p:-ovide at least 60
cays a:!vance notice to the fat....er to ec.~le the parties to revise the
Co.lStody arra'l;e"7lents by a=r~":''''nt or ~.a...e t."e C1.:stody issues resolved
th..'"O'J9h the leo;al S}'ste'Tl.
IO. !;either p:rty shall c:onsw.>e alcohol to the point of intoxication
duril'>3 his or her periods of custody ~'ith the Child.
11. The Fat.~er shall e"lSOJre that the Mother's teleph:>ne calls to him
are not blocked by his telephone S}'ste'll. The p.arties shall limit telephone
calls to each other to situotions in which it is necessary to discuss
issues concerning the OliId or in the event of en e>.>ergency.
MAR n 4 tOUl l~
I
THERESA M, KECK.
Peli lioner/I>III in Ii rf,
IN TilE COURT OF COMMON PLEAS
CUMIJERLANI> COUNTY,PENNSYLVANIA
v.
NO. 9H-(>9I1
CIVIL TERM
KENNETH I>. W AlmU:..m..
I~es ponden I/I)ere nd IInl.
CIVIL ACTION - LAW
IN CUSTOI>Y
ORDER OF COURT
AND NOW, this _ d,IY of ,2002, upon eonsidcration of the attached
complaint, it is hereby dirceted lhat the abovc parties and their respective counsel appear bcfore
, Esquire the conciliator at
, Pcnnsylvania, on the day of , 2002,
at A,M.lP,M,. for a Pre-hearing Custody Confercnee, At such conference, an effort
will be made to resolve the issucs in dispute; or if this cannot bc accomplished. to define and
narrow the issues to be heard by thc court, and to cnter into a temporary order, All children ages
five or older may be present at the confercnee, Failure to appear at the conference may be
grounds for entry of a temporary or permancnt ordcr,
FOR THE COURT:
'I
,'{
,
~
By:
Custody Conci Iiator
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO
NOT HA VE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
LA WYER REFERRAL SERVICE
Cumberland County Bar Association
Carlisle, P A 17013
(7 I 7) 249-3166
..~,.~
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5, Respondcnt has eng~ged in ~ p~ltel'llllf hch~vior whkh is dangcrllus to the child.
(" Respondcnt has a history of akohlll relatcd prohlems, Rc.:cntly he has received
what is belicved III hc his l(Hlrth DIll cunvictiun rcsulting in a prisUlI sClllcnce which is e~peelcd
to begin on March 18, 2002.
7. Respondent has also becn chargcd with harassment against his estranged wife,
Jeanctte W~rdlc ~nd her mothcr Christina Dulrow, Respondcnt is accused of thre~lening to shoot
Jeanette W~rdle in front of her children ~nd Kodi W~rdlc, Copies of the Citations are attached as
Exhibit B, A Protection From Abuse Ordcr is pending against Rcspondenl, ~ copy of which is
attached as Exhibit C.
8, The incident also involved thc thrc~tcned use of. or throwing of knives, which
occurred during Respondent's pcriods of visitalion with Kodi Wardle,
9, On Novcmber 30, 2001 Dcfendant was taken into custody for a fight with his
wife. Jeanette Wardle, Jeanette Wardle had to e~1I Plaintiff to pick up Kodi Wardle at 4:00 A,M,
10, Paragraph 10 of the current Order provides that, "Neither party shall consume
alcohol to the point of intoxie~tion during his or her period of custody with the Child." It is
believed that Respondent was drinking on the cvcnings in question.
11, Respondent has a history of activity which is dangerous and inappropriate, On or
about September 18, 1999. Respondent w~s cited with disorderly conduct when he asked a
sixteen year old girl to perform a sexual act. A copy of the newspaper al1iele regarding the
incident is attached hereto as Exhibit D,
2
THERESA M, KECK,
PelitlonerWlaintiff,
: IN THE COURT OF CO:\IMON PLEAS
: CUMBERLAND COllNT\', J>ENNS\'LV ANIA
\',
NO, 98.6911
CIVIL n:nM
KENl'iETH D, WARDLE, JR.,
Responden tlDefenda nt.
CIVIL ACTION. LAW
: IN CUSTODY
CUSTODY STIPULA TION AND ACnEEJ\1ENT
AND NOW. comes the parties hereto, Plaintiff, llleresa M. I\eck (Mother) and
Defendanl Kenneth D, Wardle, Jr" (Father), as said parties have reached a mutual agreelllelll
with respect to the Pelilion to Modify Custody filed by Plaintiff on April 4. 2000, and hereby
stipulate to the following modilied custody agreement, and hereby request the Court to enter
same as an Order of Court:
I, Mother and Father share legal cuslody ofthc child Kodi Wardle. born June 9, 1998.
2, An Order of Court with respect to the child was entercd on February 22,2000, a copy
of which is attached hereto as Exhibit A,
3, Mother and Father agree to terminate Father's overnight \'isitalion for a period of six
rnonths frorn the last date of signature of this agreement.
,
'\
t;
}..
, "
.\
4, Further, Father's periods of overnight visitation will again begin only after successful
complelion ofdrug'imd'alcohol awareness program, evidenced by a certificate or letter of
completion from the coW'se instruclor.
5. For the purposes of this agreement, father's visitation will end at 8:30PM during his
usual custody schedule.
~ 6, All other aspects of the February 22,2000, Order will remain unchanged, , . I
\ L-: H ~ ~. lfal'\17r/rg~es t,a, p~r\t~ ~otlJllr th,e1 slllJll of ~ootookor ciun.tl fJs v1. liul~C
P"'~\,~~"''I2'',",,'''';do/.J;j"Io~''''''~;~ (z.,M
'enneth D, Wardle, Jr" Defendant ate
~
Witness
Witness
d(
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T~,I,'M. J\ECI( , . n: Tn:: cx,'?T Of CX'1::1:; PLu.s 0:
.
Plaintiff . CJ'3::;;~O c:::i.J:~, f~~:S":"l. \'J...."!A
.
.
.
V5. : N:>. 9S-€911 CTVIL Ti:""\H
.
.
~~ZI'"ri D. \o\.IJ>':>Lt, JR., . crvn J.C7r~ - IJ.,Io;
.
De!e:'ld!.,t .
.
. cusro::li'
.
CF':>-::;l Of' a:o;:a'
1.."0 Nj,', tMs 2 2 ~ eay of
C':l:":.Side-:-ction o! the ~tt.o:.."',e-: C~tc>>=-.i
~~: cir~:t~ as fc]lo~s:
, :?:>)" C;o:'1
it is c~e.~e-:3
1. ~e- prior O:'.:er of tJ-1:S C::i.zt c::te-: ':::.\:~t 3:>, 1??; ':'5 v=:ate-:: c..;d
re;~e:e-: ~'ith this O:"oe-r.
2. ~e M~~L,e-r, ~,e-=esa ~. ::f'":J.:, c...~c t.ie Fct.~,e-r, 1:E':"'....,e-th D. ;':c:cle,
Jr., .s~.a]l h!'.e s"'.::"eO 1e--;a1 C'~~::Ci of ;;xi v:arcJe, ~:'i1 Ju.,a 9, 1938.
Each ?=~~:'1t s~e11 ~.:\'e ~, e-:;21 ris~t, to t>e Ex~::-ds~c j~intly \:ith the
ot..he-:- ~:-ent, to r.c..k.e ell r..:jo:" n::':1-a"7.e:'-=E-~:Y o?::isio:-:.s cf~e-cting ~"e
C~ilo:: 9~:;.E:-e1 ,'ell-~ing .inclu:.ing{ .b'~t n::>~ lir..itE<l to, all o?cisio:'1s
re--:=:'"C.lna ~,lS he.a1th, e-.;!;JCetlO:'1 c.."lC :-eJ~Slon.
3, ~e ~:ot.he::- s.~ell ~,a\'e p~b::"i p'1ysicel C'~s~OCy o! t.~~ Child.
4. The rathe:- s~all havE rc:tial p'1:'sic.c..1 cx.:to=t of t..'1e Odld c3..rr!ng
aite-:-netin; .'ee:k.s from 'Z';-'~s::=i' et ~:O::> a.m. tJ"coi..,;h Satur::!:, et ~:OO p.m.,
c..i:, euring the inte-:-irr; \.'c-E}..s 0:1 'jh'u':"s::!ey iran 3:30 p.rr:. \l")til E:OO p.m.
~,d on SeturCays from 6:30 a.!:'" ll,til ';:00 p.m. ..:...e c..ltr:-:',eting ':e-ekly
!och~.:le shall ~ntinue "ith the Fet,her he.in; C'.>stcxJ'j 0:'1 the intrrir.1
:L'hUI"!oday at 3:30 p.m. on :~~:-,)=-'i' 17, :?C>Y.>. :L'h~ Fetf'e::- r.cy al!oo ha"..e
C'.:st~i o! t.....e Chile at ~,y ot....cr t:r.>es e=::-~eC by t..~E pc:-t:es.
In .,Odi tion to t..l;e prdces of C'.;stcCf se-t forth in t.....~ p::-e-ce-ding
~";:reph, the Fet.....~r' sh!.11 have c~stoC.i of t..'>e Child on t'rieey, Fe!:or.;=-'i'
18, 2vJO at' 3:00 p.m. Wo..",h Setu:-cey at <::00 p.m. The ,.t.l;~r' !o~all -aho
hav~ c.-.:~tcxly of the Child fra:> 7hurscay, /".c.!'ch 16, 2:>Xl at 9:00 e.m.
tnro\>gh Setu::-dey at <::00 p.m. ~,E!o~ s?,,-cific prrices shall be in z,:;dition
to th~ ,.t.!',rr's r'",::-clar partic..l c~stoCy !oc:he-:3<.:.le.
5. ::he pc.rti~s s',all s',c:e or a.J te-n-.ete ~.cving C'~sto:J:i of t.....e Child
0' hcliecJ~ as follo~s:
1l.
~:
The Cl'.r i s tr..a.s
h::>Heay shall be el\'ided
~
!)(
f' )(
~~"lt A, Io'!lich s':all run !rQ~ 9:00 e.m. u"ltil 5l:oo p.m. on
Ct,riS::.r.~S Eve, e.n: Si-"'~:'lt B, \'!'.ic'l shall n.n frar, Chrh~.u
Eve at 9:00 p.m, wOJSh ~=e.~: 29 at 8:00 p.m. The rbther
shell heve C\.:5toey of the Child c'lW'ing S~~nt A in cdd
n~red years ll."ld d.lring Seo;::~nt B in even n;r.~reoC ~'eers.
The M:>t.her shell t.elle C'l.:StodJ' of the Child d.lring S~"lt A in
even nlr.'.!:le.ed ~..e:s ll."ld d.Jrin; ~:'lt B in odd n~~red
ye~s.
B. 7S.I..'l".sGI'VlNG: In e,'!::)' yeer, t.'le t',:other shell heve C'l.:StoCi of
the Child on :<'he...,;saiving Dey fran 9:00 t.m. UI'ltil 2:00 p.m.
ll."ld the Father s~,all ~ve Cl:stody on .:I'r.a,-.'-..,iving Pay from
2:00 p.m. until 6:00 p.m. In t.~e e',le:'lt tJle reV-,er's r~lar
\'E'e<e:'ld ;:>e-rio:1 of C.lstoey falls i"""",,:ately after
Th!:."l.:,-"")h'i~1 the tether s':ell re-tain C'l:stoCi of the C"lild
t.f,:O;Jih t.'le \.Ie-eke:")c at the rE-;i:1a: tir.;e.
c.
E.'~'2\."':UUcr:-<:R-~: the ,';:>t..~er s'lall t,;'.'e c",stx)' of
the C1ild on tr.icl-or-t:-E-at rjight in e".'E-:'l n:->:.:-e-: ye-a:-s f::oo
5:3~ p.m. u"ltil 6:3~ F.~. ll."ld t.~e retber s':.lI have C.lstoCi of
tJ1e C"',ild 0:1 tricl-:..=-t:-E-a:t nis~t in cOd n___~:"e-C ~"eQrs f:-:>.71
5:3~ p.m. u"ltil 6:3~ p.m., u:i!ess t.'le :eL'ler's re-=dar \'ee:,e:1d
p:-::io: of c..:st:ey irr-loE..=ietely fol10.'s tricJ.;-=-=-t.:-t?at night in
\..hjc~ use Fc~"!i.?:" s"',cl1 re:e::n C"~tex:=y t.h:'O~l:h his re-;,'.:1cr
ve-el.e:'l: peri od.
D.
~~_ ~:>Jic=~, ~c~t:>..."y s:.i?C.:.1e s'la11 s~?=~s...::e
p. c-...e-...::'lce o. E-. the re.~u!ar C'~~cC'i sc~,e-:i:.Jl e.
aid tc...~e
~
,\
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6. .E:=ch >c:-ty s.'la11 ~ (;.,title-:i to have a O:1e "e-ek ;:>e'r:od of
u-,i.'j~E-:TLJ?teC c-..:~txi d..l!' ing Lie ye-aT for \.":::..!: i on \:;0:1 p:"o'.~i cing 30 c::~'s
a=....a..-;ce not i ce to t."le o~.hc-:' ?=:"ty.
~
7. The pert}' re=eivi~ Ci.:.5~:>..."y of t.'le C:~iId s'lall ~ res?=,nsible to
P~C"..'loe t~CJ"'..s.?='rtction fer t:le e>."c..'-.::..-;;e. ~jl ~);,cl'.=-i;e5 of c-~~tXy s~.cll
ta.1;e plcce at the ;crt i es' :-e.si oe-;,=c-s u,-':ess othe-:-.'ise a;:-e-ed by the
;:.=:t i es.
B. The Fct..hc-:- s1.;al1 p:-c....loe ct le::st 2~ hou.-s o='~'e..-;ce no~ice to t.'ie
/'::>t.~e. in the e'.'e:1t he neE-"'...s to ca.,cel a period of pcrtial C'~to:ly.
9. In t.'1e e',lent t.'1e I'ic:':,er inte:'l::ls to reloc.cte the CJ,ild's resioc-n=e
i'ra:> t.he Cc.=:J'.'ea..1th of Fe:1.;s)'!\"c"ia, t.he ~;:>:,"'e~ shell p~c\o'ide at l<;ast 60
ce}"S a=vc.ne:e notice to the rct},er to E::'",a=le the p::.rties to. re".dse the
c~toey c.rra."l=(;'">e:1t.s by c:;re-a.7"':1t or /-....'e t..~e c-ustcCi iss',)es resolved
tJ-,:-c)'.>gh the lesal system.
10. r;either pert}' s'la11 C':>:'.S'-t':le alcohol t.o t..'le point of intoxication
duri"'3 his or her p;rioes of c.:s.toCi '"ith the Child.
11. The F'aLier sial! (;'"1.S\l:'e that the ~;o:.hH'S tel e?i:>:'le c:.alIs t.o him
Are not blocl\ed OJ his tele?i~:1e '1'5~e.". 7he pcrt:es shall liJr,it tele-;>ho:'le
calls to ~ch o:.her to sitL:.tio~ in Io'!lich it i.s ne:-es~"'Y to dis~s
issues C:O:'l~rning the Ctdld or in t....e event of ll."l e<:'><;rge-nCj'.
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,;"11/, PETITION f"OR [;~,t:RGt.:, ICY -'.
- -= ^ j\lr T1rr RE~IEF ;.RO~ ABUSL ~~ ..
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I DalO FIi~'O: ';J.h..( ., , ',',.JI(t',
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O PLAINTIFF H~UlJC~ lC C. OM IJL. 'n:, , ,) f vI t
PEAMMjHJt{Tc~~~nR.\A'" A(JO.'! ~ ...~ ~
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I :Je,(,,-.H<. ~l- __ PETlnO~o~~~~pEei,I~:~~o~'~~erg~r"y r~;";' :," ellj",:" '_" -~ i '
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1\ ' ~" O""~ ~~~~;t~',?)~;t:;.~~;" "~;>X:h,\; ,H~ ,I"aro,an '"'' ~ II ~
{.,)..../4r}-- 15>(-, ',,~_,_ fid..'l7 ' _____ ,_ .-:,~ " .,
Emcrgonci reiiot rro~':;b'U~l ;~ ruquortd uecause lhere IS immedlato unu prnr,(o::i ~'~';;gr.r <..i JOll:;c I)',' i:", ,..,'~ I,}
I doloncJanl to (mo) and 10 Ihc.1UOVO IISI~d (child) (children) (Incor@:ll t ~dultJ, .' r'".:" ,.. ~ "" ~
(7'yCt ll':::J,:,a~1,l ni1'lJfl1:.'ild"'~::;~:'on.. "";::t:ii:n ,,,t"f: ~ \.:-0\\ ) ,~ . n- '!'1 \, /,', 'J,'_~,,,,, ~~
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l1'lr INGs'5f' ISSUIN, MY ,SRITY '. At ao GX parle hearing 01 10,;_ ,., .......
: ....:1l,1r: :o~;:d u;ioh G,)ojc......;~r, ''',.11~: ':, ~eCC3~njY to prO,IG~l the (plainlifl) an '~::B~J:;~;.(CI,'l~::~(;nJ ~'. J.. ':
(in::::~'~r:r;::3.1: ad!"'lt). L. ...
= ,.10....) "~QT f:,ju!10 that il ,~. !"It)l:05~a' J tiJ ~D5lJ3 a protective order. _. - __~';::'" -~.: ~.._ .. _.:--~~~~.. S
"""=""",,"~ , ~:::-:;;
! , ACTION OF ISSUING AUTHORITY "'."." ,...." :! ~
' ~~'"'..,n. :o_..,~ upen 9000 Ci:liS8 '/:0""',1 mall: is necessary 10 protec1 the (plainllll) anll above ii,10d (cnl,dIICh I, ") '-.~ ~ . ~
I \ ,'H:c,m.:il'::cr.: :Jeul;). I hn'JQ ti.1I\';'~ tnA loltcwirg a(1,ion on this petition: "::s:.. "'" ~
~ ~C;oc;e(: ~"lE- dclcr.danllo (olr~.n from abU5U1Y the plaintiff and/or mmor child, ChiJdH.'f1. inccmpe:eril a~ul: ""-f~
, ~~c"rGG :r,~ celendanllo,' '~I,c '0 Iroo, havir," eny conlaCI wllh the plaintilf or minor tOddrc"., inc1ud,n\l'OSIIi\,n,uj \ ~g L "
r-:~>; c'~fl~,du~t ~rO'~1 C!'l.terl'lH P '; ;JlacA Of ~11':':p:oymcn1 or bUSiness or school at p~atntJt: or fT\ln:::r ctliJJ~EJ~ ar.d 'rCi- .J:! ~
~~2ra:S"i:; :';12.ln~.:~. plalr,IIf1'5 (c.'1tiv=~ ~r fni,,:.r ch:lcJron /..- ~.. ~ ~
: ).G')'a,,'" 't:" ~'.I(,:,"n of nl~ G~'tn:Wllrum :"e (I'ouSor,oljj (residence) at~ 111..flJ..~4f.:ft-~ t- J, Mli.., , .. ~ '\
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:: ;\1.......;6(: ~:"IC. Clelenjnnt to pr;lvlu(~ ~~..;::a::J:6, .:l,toJrnale housing oy consent agroement ..% ~,
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ORDERS O~ i EVictiON AND 0 RESTORATION 0' ...- f.
7o:fl:i!-dt././JA<..-<-t.....-~.f.1t..tf _ (S~or,l1) (Con~tabio) (POI,ce OJfjfe'l (Police OepJrtmenl) In,comp1Iar",r. \',;',h "":,
:':'o~ c'~,'cr:s) ao.c~~~ above, YOli :1fe nOI )'/ dl(l::~tcO 0 10 O~I K(J1j.l.t~hL. . ~/-J (.!~~_...___. . __. )-
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~- ; ,'11m; n_ EXHIBIT II. f.... <;If P ~~.I" '.:. #.
=------- --....-.....:.....---.- ---
II! t,r Il"'J'rr.":~I,r" '.. .-: '
DANT ' "', '
arlleliOO-i WARNltoIG: rO:ll,Irr: I., eerr,Il:'" '~'I~/1'ltill~:. 0'oj,~"€.,,...,,, "
ffont' i! fJ.H1'!Irlx:;t: 0'; ,\ flrH~ :.r"llOf n'..>r'';.;....r~Ol: ':.,,;,.c 1;"_\'."~
ur~.,..~rt? '~l'Irll..::i,)!~h,' ,~~~,ll~~.IO ~\_I <:'0',11 r,1 c.:t.",I'l'-~,-.I',,~,;
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10 the e~i~lint middle Khool. school.
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Idmlnllltrltht bui1dmr-
,/IJn )(enDelh
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"';,11) Sh3n)..:Tht'Senlinel
Hallo~~'en parade
,ort ~mna.qin le~m.
~~, fandost; Girl HDr.;es
_ ~';"iJrif'"sl: Junior :FlJ'S1 place. Sl11ldy Marshall.
.;: 1. mO..1 comical: 1ima1l nuats
,~ and Junior Girl "_First place, Erio and John
10Sl o:i~ina1. :Gaspich: !-econd plllC'f'". Brtlwnie
, ;Troop 1865,
...L ch<<rleado..: ' ;',l.org. noats
\L Pee Wet' foot, f .First place, E,P. Sohaner Senior
I'ce, \\'.5. YMC^.,~~~, ;~~ R. h),thm Ra'Oals. '
'netS\ " Aftent;
eo" N .&:.. Dna/Ill
e\l, ,- Ollleo
I ExistingHomes, lI.-ners/
IS profes~i~~YJ~_i~stalJ...
/~ " ~~ '4:Bst.om Suill-In
:!!!...J ' C~ ~:j1 ~:iilfome Audio J
.e, ~ ':~~~~~~~~t~~,~I~~g
,0 Mechanicsburg
,! Couple:We're innocent
11 By Joseph Cress Ihe tirl CJme OUI of a nearb)' bu!,d,
StnlintlReporto, int 10 bu)' sodas al a .endong
'J machine across Ihe SUet!. He $lid
" ^. Mechanicsburg \l'oman has Ihe inloxicated man on the Slreel
accosed a borough police officer of was the one ,,'ho made Ihe lewd
failing 10 do his dUl)' and repeatedl)' commenl. and the girl mistakenly
" harassing her, b)' filing cilations,_ _ identified Wardle as the culpril, ' ;. ': -,
-. - 'Jeanelle Wardle of 30 W, Main St. Wardle said the offi",r has a per--' ,
'" wen I beforc borough"councillasl sonal ,'endelll against bim and has
, wee~ 10 complain about an alleged filed groundless citalinns against
Sep!. IS incidenl, him and his \l'ife,
She said Ihe officer wrongfull)' The officer. ..'hose name is being
hsued citalions against her and her wilhheld because he bas not been
husband bUI did nOlhing aboul an charged \l ilh "'rang doing, said he
intoxicated man she alleges e>posed wenl to Main SUet't that evening 10
himself and used oloscene language in\ eSlitale a disorderly' cnnducl
and gestures while \l'al~int up and complaint. Upon arrhing. he UsI~ed
down Main Sueellhal evening. firS! to the Wardles, as~int if there
In a pbone inlen iew Frida)' lhe was a problem, The oflieer said they
officer .said he did his dut\. as a an~"ered thai there ""as no problem.
police officer and issued the cila- The officer said he then spo~e 10
lions lo.sed on infnrmarion he th, caller, who described and poinl-
receh'ed regardint Ihe incident. He ed out Wardle and agreed 10 "stif)'
s.aid he ne\'er saw the into>.iC'ated in courl. The caller also agreed 10
man on the .slTeel lhat nicht. Hi:!d he -pfCH ide a writlen stalemenl of what
seen Ihe individual or had he happened before, durint and after
received a complain! a~(lUl him. he the "ffirer's, arrh'al allhe ~cene.
said. h!' would hne in\"esti~ated. Based on that. the officer said he
MIS, Wardle said sh" her husband had enough probable caus, to i"ue
Kenneth and another man were cil3tiom 2f'ainSl the \\'ardles.
\'id<Olaping Ihe inlo,iealed man from Borough Solicitor \\"illi.m Sunday'
the baleon) of their apanm'nl when told Mrs, Wardle last" eek Ihat
! th~ officer arrh'ed and wId her hus. council is a Jegi.slali\"e body and she
band and the other man that thc\' had should la~e her concerns hefore the
been idenlified in an inridenl in\'ol\'- ctlun. Council Pres.ident Gerald For.
in~ a Icen'3!;ed ~irl and Ihat eCich f) a~reed, .saying '"lhi~ ha~ ~olhing
would recei\'e .& criminal citation. to do with tlorough counril:'
Mrs, Wardle said the oflic,", did Police Chief Rodn.. Whitcomb
nOI ad\'is.e them of Ihe e"acl charge. would not cammen! on .the V:ardles'
II \l'al onl)' later lhal her husband cil>tions, He did sa)' h, received a
recei\'ed a disorderl)' cnnduC! cita- cOPl' of the Wardles' \ideotape a
lion saying he asked a 16-year-old month aflrr the alleged incidenl
girl to perform a se>ual ac!. Mrs, The chief said the omcer did not
\Vardle said she also received a cita. see the aC'tions. of the man the "'ar.
lion in the mail in connection with dies allege was inlo),icalcd. In light
the e\'enl!o thai night. of the tape, an in\'csligation is under
Kenneth Wardle lold Th, Sentinel wa)' and ,harges mal' he filed against
Ihal, at one point during th, e\'ening, that indi\'idual, Whitcomb said,
t.
;-
HeJIth eo" . $urgery . Boarding; Professional Medica: 50"'"'1 Fa
~q:~~~~~~,~~.,- ~- ,--,
" (;' ~
(SI~,~ -:--~~;-:-:-~':c;eifitc87ciS;lini1~'rniv~TJ~a~n;.~D~''";c'j'ali)j)j''lr--.
OCLi9, 19S7; a son, CMIE. of A' I " , . - , , ,""
,bersbur,' lhree daughters VIIIY p.:k con~""ng credll cllch, mnne)' and .denulicauon "'1.1 Ilolen
rab A, SoU;nbelJer of Waynes: ~I Fur Edd,e'1 m I/lc fltst block of \\'ullllgh Sl1eeL CMlille, SuncUy morn. .
. Mary C;, Ben of FayellCville tng. CMlrsle pol,.'e uy ~~~n I and 1:30 a,m, someone .role the lmall
toil M. Allen of ChambcnbW}; , blue pack belonltnllO Knslln Messner, 28, from the bar. , , ' ,
"er, Lnuise B, Hunsecker,!?f. . . " ,
mbcrsburg; Ihrcc brothers,..:fJIerchant S sIgn taken down :, ,;'
en.. B, and Mahlon B" both 6f" .'
mbersburg and RUlSell B, 'oT' A hand'pJinlCd lign "'AI lilI<en (rom tho Herb Merchanl on Wesl Pomf"'l ';
lsbulJ; and 10 grandchild/en, ",:f' Slreel,ln CarlisI. sometime ~r"un Thursday nighl and Friday morning,
: WIS preceded In death by'a Carlisle police say the sign IHalued AI SIOO,
her, Orville B, '
" Rev. R, Leroy Eberly and the
, James Sollenberger, his son. in-
, will ofliciale al Itrvices, Burial
; be in Air Hill Cemelery. Cham.
I/ourg,
..nds may call Tursda)' from 6 10
m, al Thomas L. Geisel Funeral
me, 333 Falling Spring Road,
1mbersburg, and Wednesday from
"10 10:30 a.m, al the church,
,l.morial conlribulions ma)' be
Je 10 his church,
ams
ie is survived b)' his wife, Beny l,
:Allen Adams; a son, Douglas R.
Spring Run: a daughler, Deborah
of Edenville; a si~ler, Ros. G,
hnson o( Chambersburg: three
indchildrcn; and several nieus and
rhews,
Funeral services will be held
'ednesday al II a,m. in John l.
gell Funeral Home, 18875 ~fain
I" Dr)' Run, .'ith the Rev, Ted Hale
iOclaling, Burial will be in LOl>oer
3th Valley Cemelery. Fann.llsburg,
Frieods mal call Tuesday from 7 10
p,m, althe funeral home,
Memorial ~ontribulions can be Th~ fo!lol>oins.people were commitl.d 10 the Cumberland County Prison
"de, to HosplCe,of the Good Shep- b)' D.slr1C1 IlL'"ce Roben M.nlo'e over th, weekend and ",mained there
--.-..u,..'ft'J~r..., iiijin-w . "'4L~L, r..}. ,":'~.;"lI~~~lo~_..~.~,., _._-..~" -c.r"Jo'l~ _.--'~'1
J"""",,,~ ' ~ ~" -,....."!I){ "urw . -" P<n! woqu, :>0 "'Q,
. ,aOO\1e:lunn~o moo 'dd 3, pll!1 Jnqr!\\ ~J.I "1/1 ~ H dJeH.v"W i
nl ~uur.::lC:vJ )0 DOS' e S'e~ ;rr'#
. .DlJ.7~7 'I"
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Police probe assault in 'Carlisle
Carlisle police are looling (or a man "h~ all~gedJ)' assaulled another man
Sunday morning II Veleran's Par~ on South H.no'er SUCCI,
Police say al3 a,m, George A. Dietl, 21. reponed he "'as a"ailing a ride
home afler drin~ing in the bars do" nlO"'n 1>0 hen a Hispanic man ..ilh a bald
Or shaved head approached him on fOOl and hil him in the face,
DielZ "'as nOI familiar with th. p<rson, The man is was lasl seen walking
nOM, onlo l\'onh Hano"er SUeel from Ihe Square,
PolIce say 111. man had a medium build and "'as ""I"een 5 feeL 7 inches
and 5 feel. 8 inches rail.
Di~lZ suslained bruising and ~I>oelJing 10 hi~ righl eye bUI did nol ..ek
medlcallrealmenl. PoHce as~ an}one V.ilh inronnation (0 call 2~3.52S2.
Couple charged with simple assault
A ~fec,hanicsburg couple "as arre>led for simpl, 2;saull. and Ihe husb3nd
remains ,n, Curnberla~d Counl) Prison Ihis moming,
Mechanlcsburg police sa)' al 1:13 a,m, Ihey receiled a repon of a 911
hangup call from the firS! block of West ~Ia," Su.el, Officers responded and
fou."d K~nnel11 Wardle Jr" 3~, and JeanellC Wardle, 3~, engaged in a fight al
their resJdenCt. Both susf3ined injuries. police S3)'.
Mrs, Wardle was Ueared and rel,a'ed from Harrisburg Ho~pilaJ.
BOlh were arraigned b)' DislriCI Juslice Roben Manlo'e,
Wardle's bail .'a~ sel al 535,000 baiJ, He remain in the pri~on this mom.
ng. Mrs. Wardles bail was 5<1 al $5,000, "hich sh, posled.
f':
, !
hree held in Cumberland County Prison
EXHIBIT
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NO. 98-6911
CIVIL TERM
ThERESA M. KECK,
Plaintiff
IN TIlE CXllJRT OF COMMON PLEAS OF
CUllBERLAND COUNTY, PENNSYLVANIA
KENNETH D. WARDLE, JR.
Defendant
CIVIL ACTION - LAW
CUSTODY
OODER OF CXlURT
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AND 101, thlS ~ day of A ~ V
conBideration of the attached Custody Concll1atlon
and directed as follows:
, 1999, upon
Report, it is ordered
1. The prior orders of this Court dated January 25, 1999 and June 10,
1999 are vacated and replaced with this order.
2. The Mother, Theresa M. Keck, and the Father, Kenneth D. Wardle,
Jr., shall have shared legal custody of Kodi Wardle, born June 9, 1998.
Each parent shall have an equal right, to be exercised jointly with the
other parent, to make all major non-emergency decisions affecting the
Child'B general well-being including, but not limited to, all decisions
regarding his health, education and religion.
3. The Mother shall have primary physical custody of the Child.
4. The Father shall have partial physical custody of the Child during
alternating weeks from Thursday at 9:00 a.m. through Saturday at 4:00 p.m.,
and, during the interim weeks on Thursday fran 3:30 p.m. until 8:00 p.m.
and on Saturday from 8:30 a.m. until 4:00 p.m. The Father's partial
custody schedule shall begin with the Father having custody on the interim
Saturday on August 21, 1999 at 8:30 a.m. The Father may also have custody
of the Child at any other times agreed by the parties.
5. The parties shall make arrangements for custody of the Child over
holidays by mutual agreement.
6. Each party shall be entitled to have a one week period of
uninterrupted custody during the year for vacation upon providing 30 days
advance notice to the other party.
7. All exchanges of custody shall take place at the parties'
residences unless otherwise agreed by the parties.
8. The Father shall provide at least 24 hours advance notice to the
Mother in the event he needs to cancel a period of Fartial custody.
9. In the event the Mother intends to relocate the Child's residence
from the Commonwealth of Pennsylvania, the Mother shall provide at least 60
~~~__':L:':.T;.::::',,::_:-{'~~.-'
Michael S, Travis
Il) No. 77399
4076 Markel Slreel, Suile 109
Camp lIill. I' A 17011
(717) 731-9501
vs,
) IN THE COURT OF COMMON PLEAS OF
) CUMBERLAND COUNTY, PENNSYLVANIA
)
) NO. 98-6911 CIVIL TERM
)
) CIVIL ACTION - LAW
) IN CUSTODY
THERESA M. KECK,
Plaintiff
KENNETH D. WARDLE,JR.,
Defendant.
CUSTODY STIPULA .iON AND AGREEMENT
AND NOW, come the parties hereto, Plaintiff, Theresa M, Keck. ("Mothcr") and
Defendant, Kenneth D, Wardle, Jr., ("Father") as said parties have reached mutual agreement as
to the custody of their child Kodi Wardle, born June 9, 1998, and hereby stipulate to the
following custody agreement, and hereby request the Court to enter the same as an Order of
I, Mother and Father shall share legal custody of said child. as to all matters
regarding the child's health, education, and welfare,
2, Mother and Father shall share physical custody of said child, as Mother is
relocating to the State of Ohio, and the custody schedule shall be as follows:
Father shall have physical custody of the child, at such times as Mother may
agree, not less than three non-consecutive weeks of visitation each ycar. Father shall provide
thirty days written notice when he expects to exercise his non-consecutive weeks of visitation,
which may not interfere with the child's schooling, During periods of visitation which the parties
agree upon, Mother and Father shall meet at the New Stanton Exit of the Pennsylvania Tumpike,
The non-custodial parent shall have liberal telephone contact with the child, Father's custodial
rights shall not be affected should he move out of the Commonwealth.
3. Holidays. Holidays shall be shared at such times as the parties may agree,
4, Jeanette Wardle (Wife of Father) shall not be in the presence of the child,
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Court:
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