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Home My WebLink About00-06823 ~I . - '. - . ~ >' '. I' h, "",,' JANICE DEPUTY. * IN THE COURT OF COMMON PLEAS Plaintiff. * CUMBERLANDCOUNTY,PENNSYLVANIA * vs. * NO. 00-6823 CIVIL TERM * NO. 99-7133 CIVIL TERM JOHN R. DEPUTY, * Defendant. * CUSTODY STIPULATION FOR AN AGREED ORDER OF CUSTODY AND NOW, the parties, by and through their attorneys, stipulate and agree as follows: I. LEGAL CUSTODY 1. The parties hereby agree to share legal custody of their minor children, Ange.la Deputy born March 21, 1987 and Dana Deputy born May 9, 1991. All decisions affecting the children's growth and development including, but not limited to: choice of camp, if any; choice of child care providers; medical and dental treatment; psychotherapy, psychoanalysis, or like treatment; decisions relating to actual or potential litigation involving the children, directly or as beneficiary, other than custody litigation; education, both secular and religious; scholastic athletic pursuits and other extracurricular activities; shall be considered major decisions and shall be made by the parents jointly, after discussion and consultation with each other and with a view towards obtaining and following a harmonious policy in the children's best interest. 2. Each party agrees to keep the other informed of the progress of the children's education, therapy and social adjustments. Each party agrees not to impair the other party's right to shared legal custody of the children. Each party agrees to give support to the other in the role as parent and to take into account the consensus of the other for the physical and emotional well-being of the children. 3. While in the presence of the children, neither parent shall make or permit any other person to make, any remarks or do anything which could in any way be construed as derogatory or uncomplimentary to the other parent, nor to undermine or -~~ ok. I ~ . """,: adversely affect the relationship between the other parent and the children. It shall be the express duty of each parent to uphold the other parent as one whom the children should respect and love. 4. Each parent shall have the duty to notify the other of any event or activity that could reasonably be expected to be of significant concern to the other parent. 5. The parents shall communicate directly with one another concerning any parenting issue requiring consultation and agreement and regarding any proposed modifications to the physical custody schedule, which may from time to time become necessary, and shall specifically not use the children as messengers. Furthermore, neither parent shall discuss with the children any proposed changes to the physical custody schedule, or any other issue requiring consultation and agreement, prior to discussing the matter and reaching an agreement with the other parent. To facilitate communication between the parties, they have retained the services of Dr. Stanley Schneider. His participation in this capacity shall not disqualify him from serving or testifying as a custody evaluator in this matter or any other proceeding involving the children. All of the services provided by Dr. Schneider not covered by insurance shall be paid by Father. On or about the 15th day of every month for not less than three (3) months following the entry of this Order, the parties shall have a half-hour telephone consultation with each other and Dr. Schneider to discuss the best interests of the children, their parenting and any other topics Dr. Schneider deems relevant. Also for at least three (3) months following entry of this Order both parents shall participate at least once monthly in telephone conversations with Angela's Intensive Care Manager (now Mickey Myers), with any uninsured costs paid by Father. Father shall initiate and pay for the conference calls, provided that the Intensive Care Manager is agreeable to these conferences. 6. With regard to any emergency decisions which must be made, the parent with whom the children are physically residing or visiting at the time shall be permitted to make the decision necessitated by the emergency without consulting the other parent in advance. However, that parent shall inform the other of the emergency and 2 - - _ L J ~ - " consult with him/her as soon as possible. Day-to-day decisions of a routine nature shall be the responsibility of the parent having physical custody at the time. 7. Each parent shall be en~itled to complete and full information from any doctor, therapist, counselor, dentist, teacher mental health case worker or any institution or authority and have copies of any treatment plans, records and reports given to them as a parent. Such documents include, but are not limited to, medical reports, academic and school report cards, birth certificates, and other records relating to the children. Both parents may attend school conferences and activities. Each parent will promptly advise the other of any significant event or treatment involving the children, utilizing facsimile transmission, e-mail or telephone, at the notifying parents option. Within ten (10) days of the entry of this Order, Mother shall prepare and supply to Father a complete list of all physicians, health care providers, psychologists, counselors, caseworkers, school counselors and institutions who have provided within the last six (6) months and are now providing either child with services, including the providers street address, telephone, fax and e-mail address. Within twenty (20) days of the entry of this Order, Father and/or Mother shall request from each provider the consent form required by that provider to release complete information regarding each child, including verbal and written reports. Mother and Father shall promptly thereafter sign these consents and deliver them to each provider, thereby enabling each parent to have access to all available information regarding each child. Should the providers change, Mother will promptly provide Father with the contact information and any additional consent necessary for parents to execute to effect the continuing intent of this paragraph. Should either child's authorization be required for the release of information, both parents will use their best efforts to obtain the child's authorization. Should the child seek to exclude one parent from receiving information, the other parent shall nevertheless supply it if available to him/her. Should the child attempt to bar both parents, either, upon demonstrating legal authority for the Court to do so, may seek an Order requiring the child to execute releases or providers to fully inform both parents. It will be Mother's primary 3 ~~ ~. il.nr~ft I " .il!i.. ,,-- ~"M~ responsibility to provide Father with copies of report cards, school counselor reports, the school calendar and notifications of major school events. 8. Neither parent shall schedule activities or appointments for the children which '("ould require their attendance or participation at said activity or appointment during a time when they are scheduled to be in the physical custody of the other parent without that parent's express prior approval. 9. Both parties will attend any individual therapy or counseling recommended for either of them by Dr. Schneider, provided that Father is solely responsible for any uninsured costs for this individual counseling. II PHYSICAL CUSTODY Mother shall have primary physical custody. Father shall have partial custody as periodically determined by mutual agreement. Failing mutual agreement to the contrary, the following schedule shall apply: 1. Up to sixty (60) days, which need not be consecutive, with Father annually with both children simultaneously, which may be exercised upon forty-five (45) days notice to Mother, but shall not conflict with her holiday or vacation time with the children or with the children's attendance at school and shall not occur during the first seven (7) days following adjournment of the school year, nor during the seven (7) days immediately prior to the resumption of school, so that Mother can with assist with the transition from school to summer vacation back to school. 2. The parties shall share fairly or equally time with the children on Thanksgiving Day, Christmas and on Easter Sunday. 3. Each parent shall have physical custody of the children for attendance at family funerals, near death situations and at weddings with reasonable notice to the other parent. 4. Father's partial custody shall be exercised within the continental United States. 4 ,,~,.."- .J , N""""""",' 5. Both parents will supply the other with an itinerary, address and telephone number where the children are at all times. III. TRANSPORTATION Father shall provide all transportation necessary for his partial custody, except that Mother shall drive up to ninety (90) miles from her residence to share half the driving with Father for all custody exchanges, at mid-point locations to be mutually determined. IV. COMMUNICATION BY TELEPHONE. INTERNET AND OTHER MEANS The parties agree that there shall be regular fax, e-mail, telephone and/or internet access at least once weekly between the children and both parents without monitoring or eavesdropping by either parent interfering with privacy requested by either child. The parents shall place telephone calls to the children so as not to interfere their bedtimes. Each child shall be permitted free access to send e-mails, faxes or to place calls to Father at any time they desire, so long as Father pays for all telephone calls. Mother will maintain computer service, internet access and e-mail capability to facilitate communication by Father with her and the children, except for unavailable lapses in service due to technical problems or breakdowns beyond Mother's control. V. RELOCATION The parties have negotiated the custody and partial custody portions of this Agreement based upon existing circumstances, and in particular, based updn Wife's current residences in Cumberland County, Pennsylvania, and Father's residence in Jedda, Kingdom of Saudi Arabia. If either parent desires to establish a residence more than fifty (50) miles from their present residence, they shall give the other parent at 5 I 1___ .,- ! ~ ~{\,' least ninety (90) days' written notice in advance of the proposed move, in order to give the parties the opportunity to confer, prior to the relocation, and to establish a mutually satisfactory arrangement as to custody and partial custody in light of the changed circumstances. In the event that the parties are unable to reach an agreement, then the Court of Common Pleas of Cumberland County shall have jurisdiction over them to fashion appropriate custody/partial custody orders. This Stipulation shall be entered as an Order of the Cour 1 J eintraub, Esquire Attorney for Defendant Approved and entered as an Order of Court. Date: I Jkko t..r/J2l~~).~ J. / :<. - '1-0{) RX3 6 ... ',,",c.~ ," t.~ ,U . >~, ", '."'f'.:'" ',,-, , , - " - . ~ .<. ~'" ,-"., '"""""'1 ~-' ~" ,~ F'L~~-o --,.'.c l 1"-1 I ;I_!~ I ,_ I _.~ ,IV.... OF Tj-F: P~~CTHONOTARY 00 DEe -., AH 8: I 4 ell, 'B""" '.- "("'JNTY VitI[: ::.HLi"i'~U !...),)i i PENNSYLVN~iA .'.'" ., ..,'.,' ".lx, "",,,,,,,,,,,llUII!'JI " " ~-~, ' '~"~"'_..>' d-~"','-'n'"' " , .,lJ,..,~,:, ...1111,'1:'"'''' .. :':'3' ,'' --, ~"" ~~ I"~~ ~ - ^ I ~" ~~,*~,b", . JUN 2 3 2003 ~ JANICE DEPUTY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA Plaintiff v. NO. 99-7133 CIVIL TERM NO. 00-6823 CIVIL TERM JOHN R. DEPUTY, CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this ,p'{ day of ~~003. upon consideration of the attached Custody Conciliation Summary Report, the Order of December 6, 2000 is modified as follows: 1. Father's periods of partial custody as provided under Section II Part 4 may occur outside of the United States but may not be exercised in the Middle East. Immediately upon determining where he and the children are going to be during his period of Custody, Father shall notify Mother of the specific location. Prior to departure, Mother shall be provided with the children's flight itinerary and confirmation of the telephone number where they will be staying. . 2. Mother will assist with arranging for a passports. If expedited passports are needed. Father shall be responsible for up to $150 per child of the extra costs to Mother tOl obtain them. Said costs shall be due to Mother prior to the children's departure. 4. Mother will assist by providing transportation to and from Baltimore Washington International Airport or Harrisburg International Airport as required to facilitate Father's custodial period. 5. Section IV shall be modified to provide that Mother will make the children available at the prevailing time in New Cumberland, Pennsylvania for a telephone call of up to fifteen minutes with their father. Father will provide a calling card to offset the costs of the international telephone calls. 5. Father shall also be permitted to establish an e-mail account for the parties youngest child. 6. Section II Subpart 2 shall be modified to allow the alternating of the followin~1 holidays: Easter, Thanksgiving and Christmas. The alternating schedule shall commenCEI with Father having custody Thanksgiving 2003. The custodial period for these holidays shall be defined to commence the day school is dismissed for the holiday break and to end at noon on the day before school resumes. . I I - , ~ ~_b~"~~~;.;~.'.",- NO. 99-7133 CIVIL TERM NO. 00-6823 CIVIL TERM 7. Section II Subpart 1 shall be modified to provide that Father shall be allowed additional periods of partial custody for up to tell (10) days at a time when he is in the United States on business so long as it does not interfere with Mother's vacation or holiday schedule. Father will notify Mother of any upcoming business trips within forty-eight (48) hours of his receipt of the information that the business trip will occur. 8. In the event that either party is aggrieved by the terms of this Order, the matter may be listed for hearing upon proper filing of a Petition within 10 days of the date of this Order. BY J. Dis!: Nichole M. StaleyO'Gorman, Esquire, 1719 North Front Street, Harrisburg, PA 17102-2392 ~ ~cL- Janice Deputy, 401 Summit Road, Rear Apartment, New Cumberland, PA 17070 . , 7.01-03 0- . ''',~ 1[1, ,.w ~ '\j'~~~~"" ~ 'I ""' ~"~ ^ ~.' - '^""""'l" ,. -,", ,= " X"~'^~"' J"._" ~'" ,- ~ FILED-OfFICE OF THE- PRc)n-{)NOT/\RY >1', 03 JUL - I Ar\ II: 11 CUM8EF;U:,/',U COUNTY PENi\lSYLVANIA J~~~.~"",~.~~~~,.~"""""", .<..__~W('Wi'",,,O::~i::;l!i'j\''W~~rr.l}wr:m$!JW,i~j!~.\;~,,jil.~mI!''''''=F'~ )1!!J - J '~1iII ,J ~I ~bF~ itlllliaL , ''ifllllilIIt"" .. , , ~ JANICE DEPUTY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7133 CIVIL TERM NO. 00-6823 CIVIL TERM v. JOHN R. DEPUTY, CIVIL ACTION - LAW Defendant IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Angela Deputy Dana Deputy March 21,1987 May 9.1991 Mother Mother 2. A Custody Conciliation Conference was held on June 2, 2003 in response to Father's Petition for Contempt and Modification for Custody file on April 14, 2003. Present for the conference were the Father's counsel, Nichole M. Staley O'Gorman, Esquire; the Mother, Janice Deputy. Mother attended pro se. The Father did not attend, as he resides in France. Following the Conciliation, Father's counsel sent a letter asking for an Order regarding the Agreed upon issues and a hearing on the remaining issues. Two conference calls were initiated after Mother objected to the contents of the letter and Father's plans changed. 3. Mother and Father's counsel were able to reach agreements with regard to allowing the children to travel to France for some of Father's summer custodial period, getting Mother's assistance with transportation to and from Baltimore Washington International Airport incident to custodial exchanges, Mother's assistance with obtaining a passports, forwarding copies of report cards, providing names of health care practitioners treating the children, agreeing that Father may set up an e-mail account for the younger child, obtaining Mother's cooperation with the use of a calling call for the purposes oif maintaining telephone contact between the children and Father and setting a consistent time for the children to have a weekly telephone call with Father. Additionally, agreements were made with regard to modifications to the holiday schedule and additional custodial time when Father is in the United States on business. ''--l! - ~ " ~~.. ,-1- ~ ~ m--~.- 'u'~~, . , , , NO. 99-7133 CIVIL TERM NO. 00-6823 CIVIL TERM 4. Issues upon which the parties did not agree were: A. Whether or not Father could have custody to occur in other than the United States or France. B. Whether or not Mother would be required to share in the cost of airline transportation associated with the children's periods of custody with Father. 5. Mother's position was as follows: Mother would agree to the children participating in custodial visits only in France or the United States. Mother expressed concern that some countries may not be safe and that some countries may not honor our court's custody orders, such as Saudi Arabia. Mother wanted the children to return two weeks prior to the start of school on August 26, 2003. Mother would not agree to sharing the costs associated with the airline flights incident to Father's custodial time, Mother agreed that she could transport back and forth to Baltimore Washington International Airport. However. she states that she cannot afford to contribute on the cost sharing of the airline tickets to Florida. She also refuses to absorb any of the costs associated with flights to and from France. She reasons that Father made a choice to work and live in France and that as a result he should be responsible for covering the transportation costs. 6. Father's position is as follows: Father has recently learned his Visa in France cannot be renewed. This may mean that he does not use his entire upcoming custodial time in France. He would like to be able to occur in other countries. should he need to relocate, for employment reasons. Because of the change in Father's employment circumstances, he may not be able to provide much notice of his vacation plans for custody of the girls, but, agreed to provide Mother with an itinerary and contact phone numbers prior to the girls departure. He also agreed to pay extra fees of $150 per child for expedited passports. He believes Mother should contribute to the cost of the transportation, either equally or pro rata based on the parties net incomes. ~ ~-~I __I. ;..Iio,.. . , . NO. 99-7133 CIVIL TERM NO. 00-6823 CIVIL TERM " I - "'~'~ ~', ~'- 7. The Order attached reflects modifications to the Order of December 6, 2000 as agreed by the parties with a recommendation regardi the locus of Father's custodial periods. b /~ ID Date M ~ :214741 Me issa Peel Greevy, Esquire Custody Conciliator -" ~" - l,' COpy JANICE DEPUTY, Plaintiff/Respondent v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 00-6823 Civil Term ~ No. 99-7133 Civil Term JOHN R. DEPUTY, Defendant/Petitioner CUSTODY AND NOW this .:J. 1_1tr[ ORDER of J..JI/ , 2003, pursuant to Defendant's Demand for i ~ '" ~;, 4i " to occur No. .s- ~~ ItA Hearing, a hearing , 2003 at~ is hereby scheduled ~.M. in Courtroom , the Honorable Edward E. Guido, presiding. BY THE COURT, .'1-; l I t \1 /:.-,/,.;,.4'/ ~-: "" ,.,' ~ d I J. 4 , Distribution: "~1 Nichole M. Staley O'Gorman, Esquire 1719 North Front Street, Harrisburg, PA 1710l- ~ 'f , - Janice Deputy 550 Bridge Street, New Cumberland, PA 17070 ~ ~.I 1 .:1 :~,i l! ;.1 I >..;i -'or '..'.1. , ,:i }:i :;.1 ;'I': I, ~ I" i..:..I~ .1., _ ~"" ,,' , ';"c. , illSi'! Home I :Home IInbox I(Compose IAddress Book I Options Help john_deputy@hotmail.com i S;;"e :"dd~s(e~j I '. BI~~k 1 Previous Next I Close From: Jana65@aol.com ---..-.,--.,--. .._._--_.__._._.~._--_...-._---_."----~"._._--~_. To: john_de.!'uty@hotrnait~E!__ ____. ._________.___, Subject: ~_~o.!.~Ppo,!ng _'!ly.I<i~~__.._____.__,__.___._________________ Date: Sat, 11 Aug 2001i8:37:42 EDT i Reply I 'Re~yAiI]T~~~r(oei~~ll~:t in- Fold;;:::Ii-----.-----------.--.;-;.;;;;,~~~~~~';~~~~on So how do you feel about the health insurance? I will forward your lovely email onto Sally at Domestic Relations (just for the record). 1m sorry you feel slighted by what Judge Guido ordered. But it is the law and it is legally, ethically and morally binding and you are responsible for your children. 1m glad you are happily married and wish you a very happy life with Sophie, you make such a lovely couple. Once school starts everyone's schedule should settle down to a more stable routine, giving you the opportunity to converse with the girls on a more regular basis. We simply are not home at 3 in the afternoon, and the girls cannot be expected to not have a life on the weekends waiting around to see if you call. I have however, forwarded your messages onto them, so they at least know there is some effort on your part and you have not totally abandoned them. Have a great day, Janice [Reply I !Repiy:"ill iR;;:;;;~;;j-1 ioe,e;llput in Folder..:. Printer Friendlv Version [JJ1{:ii,"," MSi'! Home I Hotmail I Web Search ! Shopping I Money I PeoplelltChat '''''c.,>,' @ 2001 Microsoft Corporation. All rights reserved. TERMS OF USE TRUSTe Approved Privacy Statement A,l> ! ( I.";~illi&'!i Search tl r- I ~-" Hotmail Free New Pop Mail Find Mes' Reminder DirectorlE illSi'! Wo MSN frar M5N Gen M5N ltai\ MSN Japi MSN Kon ~15N Netl MSN Swe TlMSN MSN Taiv More MSI I . ..Igetmsg?curmbox=FOOOOOOOO 1 &a=b90 1 b7c803ab94bc1674c31917d 1 cfl:lO&msg=MSG9975(8/12/200 1 ';) fE1(HIBIT ] It' f namrc.s D ~-~~ . ~t ,msn,"Ict. Hotmail<5> john_deputy@hotmail.com Inb2x I Previous Paa~ From: Jana65@aol.com To : john_deputy@hotmail.com Subject: Re: Date: Sun. 19 Aug 2001 12:08:18 EDT Can't give you a specific time to call the girls suggest you figure something else out before you call again. If you must send email to the girls you can do so with my email address. this has not changed. also Angela's email is still the same as when you last emailed her...which was well over 6 months ago. The passport situation is in your hands, I will not do this for you, and in any event the girls will not be permitted to visit you there...lol...are you crazy!! Anything else you need to know? Janice IDSII~ @ 2001 Microsoft Corporation. All nghts reserved. TERMS OF USE TRUST. AOD1:Q\'~ n \) ~1 ~'If\. ,\ , it t c \. ~ ~~ \. . .Jgetmsg?curmbox=FOOOOOOOO 1&a=544b808fd2933827c553b124e4b8b4ab&msg=MSG9982:8/19/200 1 "~ , ,-, ~, - ~ ..,,'1 .~,. ;', ~ I ~ Hotmail HotmaU!> john_deputy@hotmail.com Inbox I Previous Paae From: Jana65@aol.com To: john_deputy@hotmail.com Subject: Re: Date: Sun, i9 Aug 200115:50:53 EDT I will pass your email onto my lawyer about not being able to visit the US, as I suspect, it is all just BS and just another delay on your part. Again, the girls will NOTbe permitted to visit you in Saudi Arabia, end of subject. No one is denying your parental rights, in fact we have done everything possible to get you more involved with your children courts included. You should come here to visit, so many people are awaiting your return. The court ordered email accounthasbeenestablished.it.sright here. your mail will be printed out for the girls to read. And they can respond at will. You may start using it at any time. The girls will not be permitted to use the emaiI accounts you have created for them. I will not subject my system to unknown territory. Now if you are willing to get the girls their own systems we should talk. And for your information, the girls aren't as terrified as you would have yourself believe them to be. They can't wait to tell me all about your conversatious with them when they finally are able to get the phone with you. Of course. it may be a while before any conversations with Angela happens, she's entered a stage where she does not want to have anything to do with you, hopefuI1y it won't last too long. And you have yet to establish what is best for the children, and goingftom history you can't establish crap. . There is no reason for you and I to communicate through email any longer unless it is an emergency or to update information. Please direct all correspondence to domestic relations or my lawyer. ,( k." ,,;-. ,,_ __ -~, '_ ,:y'. "-, ,., <, , l'l'~i!t~ Pag~ lot] f\\ \1 V'" \ @ 2001 Microsoft Corporation. All rights reserved. TERMS OF USE TRUSTe Aooroved PrivacY Statement .. ./getmsg?curmbox=FOOOOOOOO 1&a=490e7a3e3116b20ec2187c 164749b65d&msg=MSG99828/20/200] .. ~ "" ~~'" , -"1-,., ',' _"':" ~~"-"_,_'h.""",_,,__';,"i '.~"'''' Hotmail@ john_deputy@hotmail.com In!l!!l\ p!"jlyious Pa-M from : Jana65@aol.com To : john_deputy@hotmall.com Subject: Re: Phone calls Date: 5at, 17 Nov 2001 22:42:59 EST Dear John, In response to your email correspondence dated 11/15/01 12:51:50 Pacific Standard Time, I want to reiterate the available communication methods you have available to you regarding our daughters: .Angela and Dana, which are assured by our most recent custodial and support order. You may Initiate telephone contact with the girls at any time that is deemed appropriate provided it does not conflict with their school, social activities and sleep. Since your current residence in Saudi Arabia creates time difference conflicts, please take those into consideration when electing telephone contact with Angela and Dana. This has not been an issue in the past, however, it is necessary to restate this. On the issue of email communication: You are aware of and have elected to communicate with the girls through existing email accounts that are provided for them. Please continue to use these, you are not restricted by myself or any other party in using this form of communication, nor will you ever be. However, because of the sometimes impersonal nature of emails In general, please continue to call the girls, as they always look forward to hearing your voice. Especially in these times with the instabilities of where you live, I know they do worry about you sometimes. Regarding your requestto use a special hotmail email account you have established for Angela and Dana, I will not permit their use of those accounts. It is in their best interest to communicate with you, and sufflci.ent means are in place at this time which do not require modification. Regarding your mention of instant messenger service through hotmail, I again restate what Is mentioned above. That is not a viable solution to communication between you and them and I will not allow, nor support that method. On the issue of Internet telephone communication, since the telephone service between the USA and Saudi Arabia is viable, I will not permit, nor encourage this method be used for our daughters to communicate. I realize you must incur an expense every time you call them, however, the expense is not unreasonable. There are many low cost options you may explore at your leisure to lower your cost of telephone contact. Since you have voluntarily elected to garner employment overseas, it is your responsibility to absorb any expense and effort to communicate with Angela and Dana, and of course, anyone else you wish to, such as your family and your friends. To summ<!lrize my position on these issues, John, I feel our daughters require a good relationship with you and I will not interfere with that. Rather, I will encourage it. I am vigilant about their Internet usage and will continue to be, as is my responsibility, and your responsibility as their mom and dad. Since the current methods of long distance communication do not restrict or deny communication between you and them there is no need to change it. I do want to emphasize that your decision to live so far away from Dana and Angela may not be in their best interest. They have expressed a desire to see you more and do want a closer relationship with you. Since there are employment opportunities in the USA, this may be an option you will want to explore in the near future. I want our daughters to have the best of everything. I know you may not be happy with this letter, but again, the existing forms of communication are sufficient. The only thing lacking is your physical presence to them. I do not say this to create new issues, I only say it to clarify what I think the issue really is. As far as communication between you and I, I will contact you via email to keep you up to date and informed <!IS to what is happening in their lives. I am sure they talk to you about how they are and what they do, but, I think it would be good to also tell you about as well. If you do not want these, you have the option of not reading them and deleting them, but I feel it is important to do this since they may not tell you some little things that you or I might feel is important. I also ask that you modify the 'tone' of your letters to me. There is no need for us to verbally attack one another, make insinuations, insult, belittle or accuse one another of wrong doing or detrimental behavior. Please do not misunderstand, I will defend myself against insults, belittling and A .~ 1 J)' httnol/lwl1 fcl.hwllhotm~iLm.nc.om/c.lTi-hin/lT"tm.lT?c.llrmho,,=FOOOOOOOOl &~=~Rcl7f~?4?... 11/18/01 "'1-,' ' ~ - ~, ,_,._,n . - ~ ;,,'0' derogatory remarks you make. I will also defend and protect Dana and Angela when I feel it is necessary. But you will not receive any from me, and I hope your messages to me are empty of those as well. They do nothing to help you, me or the girls. Instead. they weaken the communication that is so important involving the girls. Janice . @ 2001 Microsoft Corporation. All rights reserved. TERMS OF USE TRUSTe Aooroved Privacv Statement http://lwllfd.1awn.hotmai1.msn.com/cgi-bin/getmsg?curmbox=FOOOOOOOOl&a=a8d7fa242'...11/18/0 1 ~ ~ - -,. -."'" < "-- __C~'I"-;""_F:'''~''<'C ~'-,jJ~ '_~"+'_"->.,_,,^j,"-,,..'w ""cr":'-"'-' :,:--~, ':',:~\',,;",-,~",-::,;'>-''',,:.' ;:';lll"~_': Uver the past two years and beyOnd there have been prOblems and concerns Wllth . communication with Angela and Dana. This issue and others have been addressed in court and behind doors. It is in the best interest of all concerned that communication be unobstructed. I have set up Hotmail accounts for the girls and had configured them as not to allow anything beyond their appropriate ages. You have been aware of this for many months. This allowed instant access for them to me and visa versa. You have disallowed this without reason. he hotmail is a free email service which has the best antivirus program availablEl. II downloads or attachments are scanned prior to viewing by any costumer. You . ourself have a hotmail account and have for some time and are aware of the sa1fe guards. he new instant messanger service, which is an update for the pre-existing service, lIows phone calls to be placed from computer to computer at little to no charge. his will allow greater access to my children. All that you will need to do is to download the latest version which takes less than 5 minutes, provide head phones/microphone, which I have already provided, and allow Angela and Dana to use it hat I am asking for and have been is nothing that will require a super human effort. I have done all of the work that I am able to. From you it will take five minutes. I believe that this is a reasonable request in all eyes. I will suggest that you put all differences behind you and look towards the immediate and long term future of Angela and Dana and their contact with me. The all rests in your court for the time being and has rested squarely there for some ime. Lack of action on your part is a detriment, and continues to be, to the healthy growth emotionally of Angela and Dana which will effect them for the rest of their lives and their childrens lives. They naturally will pass on what they have and ontinue to learn. hat have you to say? 1;\ .\ \ httn://lwll fcllRWll.hotmRi1.msnc.om/c.l1i-hin/c1Rsn/RNIrtp..Rsn l1/HIIOl . '''-'' ! ~,.,.jl " ..,,1-,. . - ."'~ .' '--", licc",",~-;,- .", H otmc!u I@ john_deputy@hotmail.com inbox I Previous Pa~ From: PrettyKitty4950@aol.com To: john_deputy@hotmail.com Subject: HI dad Date: Tue, 4 Dec 200i 19:45:02 EST HI dad, How are you? I'm fine. I'm sorry I never got back on to talking to you over Internet but you know about the whole privacy issue. That just bothers me. Anyways. it's been so hot up here. it seems like it is never going to snow. I'm so stoked for snowboarding though. I even dream about snow. Sad huh? Have you read the Harry Potter books yet? You need to. they are so good, Dana's presents came today. we practically had to put restraints on her to hold her back. It was so funny! And now mom's got to find a good place to hide them. That should be fun. Ok, well...e-mall me back as soon as you get this. love angela @ 2001 Microsoft: Corporation. All rights reserved. TERMS OF USE TRUSTe Aporoved Plivacy Statement ;( . ..Igetmsg'!curmbox FUUUUUUUU l&a b~cKl6~e54c3b611lt6blc~Ucll/7 auu 1 . I', " J. ". ., ' ,. ,',,' > .. ,.~:;";'" i:',__, ,.. "'.'; ',. ..".' ' ,;",,;;' ',,' < .~ ',,-'l<1,~ Hotmail Message Page 1 00 MSN Home I My MSN I Hotmail I Web Search I Shopping I Money I People &. Chat IE!:II (Ii i l<"j-'J. .. . '-1:...J'.....I<:JJ~ " . Home LlnbOX r Compose [Address BOOk] Options Help john_deputy@hotmail.com --~--lJr.;;:::':;:-1 i Save Address(es) ~ From: PrettyRabbit21@aol.com To : john deputy@hotmall.com Subject: Re: hi princess Date: Tue, 5 Feb 2002 13:33:32 EST I Reply II Reply All II Forward I I Delete IlputinFoideL.:. r~ Calend:o, PtllyjJ1us lIIext I C!!!.s.e Hotmall Free New Special 0 POP Malll Find Me5~ Remindl~r DirectoriE Printer Friendlv Version MSN 111'0 MSN Fmr MSN Ge", No, I DO NOT WA TCH IT. J ~!~~~~: MSN Netl HEARD IT FROM MY . ~~~S~:j: More Msr FRIENDS. MONDA Y I WA~ HOME FROM SCHOOL BECAUSE/, AM, FEELING WELL AND TUESDA Y WITCH IS TODA Y /, AM, BECAUSE /,AM, FEELING WELL. WE STILL DIDN'T GET A PACKAGE IN THE MAIL. I CAN'T WAIT TILL hnn:lllwl1 frl hwl1hntmHi1.msnc.nmlc."i-hin/""tms,,?c.nrmhrw=F000000001 &H=tl?7htlAHO"t... 2/16/02 le,','-' '- -'-~"'~'~~_' ",_", "".cl.J~;:;;.,~I",-",' 'i,. L~ ...._,. '. ,.... ---- - iIiIiI~~ -,." .,-, "~. .~~ IT GETS HERE. I ASKED MOM IF I COULD CALL TO GRANDMA'S HOUSE TO SEE IF WE COULD GO DOWN ON VALENTINE WEEKEND BUT SHE SAID THA T GRANDMA AND THEM PROBABL Y DON'T WANT ANYTHING TO DO WITH US. DON'T TELL MOM THIS BUT I, AM, TO CALL DOWN THIS WEEK V TO SEE THEM OR TO VISITOR JUST TO TALK TO THEM. .WELL, I HA VE TO GO AND LIE DOWN SO http://lwllfd.lawll.hotmai1.msn.com/cgi-bin/getmsg?curmbox=FOOOOOOOO 1 &a=627b6aaOeb... 2/16102 " , - . j , ,1-' "J I " -,,-,. - -.' -, --". '"-",'_-_"'FO'--_;('"__"'_'".j'''__J..~_,'"~,-,"". ~""....J..~~J ,I CAN GET BETTER FOR SCHOOL TOMORROW. LOVE, DANA AND MIDNIGHT AND SHEEBA AND DARBY I NAMED HER (PRINCESS) jJ:J31 rj!tt More Useful Everyday MSN Hllme I My MSN I Hotmail I Web Search I Shopping I Money I People & Chat @ 2002 Microsoft Corporation. All rights reserved. TERMS OF USE TRUSTe Approved Privacy Statement I http://lwllfd.lawll.hotmail.msn.comlcgi-binlgetmsg?curmbox=FOOOOOOOO 1 &a=627b6aaOeb... 2/16/02 - :-1.- ",'_.'_ Hotmail Message MSN Home I My MSN I Hotmail t Web Search UJJ:0JJ, People &. Chat Home r Inbox r Compose r Address BOOk] Options Help john_deputy@hotmail.com .s~~eAdd;~~~(~~)IBI~~kl Previous Next I Close From: Jana65@aol.com ......," ".............,..-....-.... -.""................,.--."--. To: ::'john deputy@hotmall.com> .._...._..._~._...__....__....._...~_.__.._.. SUbject: Re: Recent Date: Fri, 22 Mar 200215:14:53 EST Replvl :R-;PiY.Ai~ I.F~;;;11 ~ Del;i~'1 [PutinF~lde;"'jjlli Printer Friendlv Version No offense guys, suggesting you get double prints made and mail them through the post mail. The pic files could contain computer viruses or compromise the security of our accounts, and we don't want to risk loosing one of the two means of your communication with the girls. Please do not take this personally or feel it is directed at you as an attempt to block communication, rather please understand that the girlS use the computers for school and personal research and we don't want to jeopardize loosing such a ~aluable resource. CiLJJ{:J]j MSN Home I My MSN I Hotmail I Web Search @ 2002 Microsoft Corporation. All rights reseIVed. TERMS OF USE I Shopping I Money I People lit Chat 'TRUSTe Approved Privacy Statement It ,,~~ ~ ~:H-~,;i,JJ- Page 1 of 1 - I~~" Calendu, Hotmaii Free New Special () POP Maj. Find Mes~ Reminder Directorl,s MSNW" ~lSN Frar MSN Ge" MSN Ita I', MSN Jap., MSN Kor" ~1SN Netl MSN Sw" T1MSN MSN Tai~\ More MS' I http://lwllfd.lawll.hotmai1.msn.comlcgi-bin/getmsg?curmbox~FOOOOOOOO 1 &a~f68b563 ... 3/24/2002 ~~ , --. '. ,-. -I~ . , . _ l ,-- ,.-c -'~""-'- Page I of I ear Dana, promise you that there was not a virus on the pictures. We sent them out at the very same time to alot f people and they all wrote and said how nice we looked and Gabby is getting big and all that. Even Jeremiah and Cody's grandma who has the same virus scanners and stuff had no problem. I will send some through the mail next month for you. I did call yesterday but there was no answer at all. Did you o out or was the ringer on the phone off or something like that? Don't get upset, my dear. IfI make ou a promise, I will certainly fulfill it. Do not let your mother and your sister get to you with silliness. love you very very very much and will never ever ever forget about you. I talk about you and think about you every day, princess. I will call today, so check and make sure the ringer is on the phone. If ou go out, I will try a little later, but if not, then I will write. I am also sending you a game for the laystation. Dana, it should work. Soph sends them to Miah and Cody and they haven't had any roblems with them and they have Playstation and Dreamcast. Okay? Anyway, I love you and miss ou very much. All My Love Forever, DAD From: PrettyRabbit21@aol.com To: john _ deputy@hotmail.com Subject: Re: hi, princess! Date: Sat, 23 Mar 200216:39:27 EST No, I DIDN'T LOOK AT THE PICTIJRES IT SAID THAT THERE WAS A VIRUS ON IT SO MY MOM SAID THAT SHE COULDN'T OPEN IT OR IT WOULD GIVE OUR COMPUTER A IRUS. BUT MOM SAID THAT YOU CAN SEND THEM IN THE MAIL IF YOU WANT. HOW COME YOU EVER CALLED TODAY YOU SAID THAT YOU WOULD? WELL, HAVE TO RUN. LOVE, DANA AND MIDNIGHT 1\ f:.,.t ~/ / http://lwllfdJawll.hotmail.msn.com/cgi-bin/dasp/EN/rte.asp 3/24/2002 - .-.o. "' I ~ ". '~__L " ""'F 1 '"',_ - -O-~*\1'" Hotmail Page 1 01"2 ,.-,- ';c,-" Lfu:Jiliu . Hotmail@ john_deputy@hotmall.com , Inbox I Previous Page From: Mail Delivery Subsystem <MAILER-DAEMON@aol.com> To: <john_deputy@hotmail.com> Subject: Retumed mail: User unknown Date: Thu, 9 May 2002 16:26:23-{)4Q0 (EDT) The original message was received at Thu, 9 May 2002 16:26:02 -0400 (EDT) from f186.1aw11.hotmai1.com [64.4.17.186] *** ATTENTION *** Your e-mail is being returned to you because there was a problem with its delivery. The address which was undeliverable is listed in the section labeled: ,,----- The following addresses had permanent fatal errors -----". The reason your mail is being returned to you is listed in the section labeled: J1~____ Transcript of Session Follows -----". The line beginning with "<<<" describes the specific reason your e-mail could not be delivered. The next line contains a second error message which is a general translation for other e-mail servers. Please direct further questions regarding this message to your e-mail administrator. --AOL Postmaster ----- The following addresses had permanent fatal errors ----- <orettvrabbit21@ao1.com> ----- Transcript of session follows ----- while talking to air-xa05.mail.aol.com.: >>> RCPT To:<orettvrabbit21@aol.com> <<< 550 MAILBOX NOT rOUND 550 <orettvr~bbit2l@aol.com>... User unknown -7 /) Reporting-MTA: dns; rly-xa05.rnx.aol.com Arrival-Date: Thu, 9 May 2002 16:26:02 -0400 (EDT) Final-Recipient: RFCB22; prettvrabbit21@aol.com Action: failed status: 2.0.0 Remote-MTA: DNS; air-xa05.mail.aol.com Diagnostic-Code: SMT?; 250 OK Last-Attempt-Date: TAU, 9 May 2002 16:26:23 -0400 (EDT) HAPPY BIRTHDAY DANA!!!!!!! I AM GLAD THAT YOU RECIEVED AND LIKE YOUR . ../getmsg'!curmbox t'uuuuuuuu l&a d3eY51bdU15acb 17Mcc3M163451 1 UI2UUZ " 01,__ .,- -~I ' -oJ'o"_o_~,,, Hotmail Page 1 of3 !JJJBJ(!d. H otma i I@ john_deputy@hotmail.com lnbox I Previous Pall'! From: Mail Delivery Subsystem <MAIlER-DAEMDN@aol.com> To: <john_deputy@hotmail.oom> Subject: Returned mail: User unknown Date: Fri, 10 May 2002 01:35:22 'O'i!lO (EDT) The original message was received at Fri, 10 May 2002 01:35:01 -0400 (EDT) from f236.1awll.hotmail.com [64.4.17.236J *** ATTENTION *** Your e-mail is being returned to you because there was a problem with its delivery. The addre~s which was undeliverable is listed in the section labeled: ,,----- The following addresses had permanent fatal errors _____". The reason your mail is being returned to you is listed in the section labeled: ,,----- Tran5cript of s~ssion Follows -----". The line beginning with "<<<" d~scribes the specific reason your e-mail could not be delivered. The next lin~ contains a second error message which is a general translation for other e~mail servers. Please direct further. questions, regarding this message to your e-mail administrator. --AOL Postmaster ----- The following addresses had permanent fatal errors ----- <iana65@aol.com> >>> ~<<< /550 ----- Transcript of session follows ----- while talking to air-xeOl.mail.aol.com.: RCPT To:<iana65@gol.com> 550 MAILBOX NOT tOUND <iana65@aol.com>... User unknown Reporting-MTA: dns; ~ly-xe03.mx.aol.com Arrival-Date: Fri, 10 May 2002 01:35:01 -0400 (EDT) Final-Recipient: RFC822; iana65@aol.com Action: failed Status: 2.0.0 Remote-MTA: DNS; air~xeOl.mail.aol.com Diagnostic-Code: SMTP; 250 OK Last-Attempt-Date: Fri, 10 May 2002 01:35:22 -0400 (EDT) Has Dana changed her email? I ask this because of returned emails, user unknown. Also no one answers the phone and no answering machine at your place for more than a week now. >From: Mail Delivery SubsyStem >To: >Subject: Returned mail: User unknown >Date: Thu, 9 May 2002 16:26:23 -0400 (EDT) > > The original message was received at Thu, 9 May 2002 16:26:02 -0400 (EDT) >from f186.1awll.hobnail.com [64.4.17.186] > > >*** ATTENTION *** > .. .lgelIDsg'Tcurm'OoX'h'Plr(}'UOotrmrr&'ir 'aa6er~W~1%n:;e7a7 c4~7K5/ 1 U11UUl A ,/J (17 V,;./ t ...l ~ -" .,' ~- ,',- " 0"___"'_"."_,,;.,,,', ~ - :r~I:' he P A support was modified as to the support amount which includes, medical coverage. Please ead the Child support modification document signed by judge Guido which states what each party . s responsible for. . will not be receiving any mail sent to any other address other than my own. My address is here in rance. From: "Musketeers 3" To: "john_deputy" Subject: Re: Mail Date: Mon, 9 Dec 2002 18:02:47 -0600 You should really take some time to read over the divorce decree. AGAIN, it is your responsibility or any and all charges not covered by your insurance. There shouldn't be too much left to pay with Ie Golden Rule as neither of the girls have that coverage anymore. Any remaining balances with e Golden Rule insurance will remain your responsibility. As far as changing addresses, get a life. Any mail that comes in your name I will continue to forward it on to Allentown and will not be eturned to any post office. If you have a problem with this then I suggest for the last time that you contact the companies directly or better yet the post office. Legally your parents can accept mail for you on your behalf, you are pulling your information out of your ass as usual. What's the matter, aren't you getting any? Please, I have better things to do, and so should you. ----- Original Message ----- From: JOHN DEPUTY Sent: Monday, December 09. 2002 9:14 AM To: musketeers_3@msn.com Subject: Re: Mail ~ r The mail sent to you is not for you to forward on to me. I have never had my address as any ddress you have been at since divorce. If you are talking about receiving medical type mail, ie bills, en they are your responsibility and should not have my name on them. The name should be either gela or Dana. I have paid for the insurance and my percentage of the bills as per the court. The balance is your responsibility. You wanted and kept changing tlle billing address, ie jolm deputy, to our location. I am so tired of changing the address back that I deal with the insurance company . rect for the claims and pay directly. The procedure for any mail sent to your address for me is to return to sender saying that tlus person does not reside at this address. As for mail sent to my parents. Legally they cannot and will not accept mail on my behalf just as you catmot. This is not by my choice but rather the law of the natter. My legal address is not within the U.S. nor has it been since March 2000. I do feel tllat the 15.00 required to send the parcel is not unreasonable considering it is but once a year. $1.25 a onth out of the budget is more tllan an acceptable amount to cover the slupping. Don't be petty. I have found a person living here in France who is your relative. I Catlllot afford to post the mail to Ie states so I am going to post it to them and hopefully they will send it on to you. How rediculous . s that? > >From: "Musketeers 3" >>To: "jolm_deputy" >Subject: Re: Mail >Date: Mon, 9 Dec 200207:50:58 -0600 > -.- ~ I _~" ,,"' .1 I~- . ~ -" =,u ~'1c'i"' >One other solution would be to contact the companies that send your mail to me and have the ddress changed to whatever you wish. Or perhaps to leave a forwarding address with the post ffice. > >----- Original Message ----- >From: JOHN DEPUTY >Sent: Monday, December 09, 2002 3:07 AM >To: musketeers_3@msn.com >Subject: Re: Mail > > The mail sent to you is not for you to forward on to me. The procedure for any mail sent to your ddress for me is to return to sender saying that tillS person does not reside at tillS address. As for nail sent to my parents. Legally they cannot and will not accept mail on my behalf just as you cannot. This is not by my choice but rather the law of the matter. My legal address is not within tile .S. nor has it been since March 2000. I do feel that the $15.00 required to send the parcel is not nreasonable considering it is but once a year. $1.25 a month out of tile budget is more than an acceptable amount to cover the shipping. Don't be petty. > > > >From: "Musketeers 3" > >To: "john_deputy" > >Subject: Re: Mail > >Date: Sun, 8 Dec 2002 18:48: 17 -0600 >> > >1 suggest you tell your parents to forward all mail onto you. This is a choice for you. The mail I orward on is directed to you and most of it effects your credit, so it would be in your best interest to ave them do tins. > >The xmas presents that Dana has picked out for you and yours will be mailed to Allentown so, as we can not afford the airmail charges, again it is your choice if you wish to receive them or ot. > >One other solution would be to contact the companies that send your mail to me and have the ddress changed to whatever you wish. Or perhaps to leave a forwarding address with the post office. > >I'm sony that this goes against what you want but it is the easiest solution for me. >> > >----- Original Message ----- > >From: JOHN DEPUTY > >Sent: Sunday, December 08, 2002 II :36 AM > >To: musketeers_3@msn.com > >Subject: Mail >> > > Any mail to me not sent to my France address will either be retumed to sender or be returned o tile postman for disposition. Any questions? >> >> >> >> >> > >The new MSN 8: smart spam protection and 2 months FREE* Get more from the Web. FREE SN Explorer download: http://explorer.msn.com >> r /'" I.... >> >the newMSN 8 and get 2 months FREE* Get more from the Web. FREE MSNExplorer download: lrttp://explorer.msn.com ~ I .,j-- "- --'" , .,,1- ~, H,LI..H'l J.J.VUlli:lU- Page 1 of I Hotmail@ john_deputy@hotmail.com Inbox I Previous Page From: "Angela Deputy" <angelflShOO5@msn.com> To : john_deputy@hotmall.com Date: Wed, 01 Jan 2003 17:19:57 -0500 Hello. How are you and how was your New Year's? I'm tired and mine was fun. I stayed the night at my friend Lauren's house and we went to Harrisburg for a while. We didn't go to sleep until 5:30am and then we got up at 2pm and went to a diner in our pyjamas. I really don't want to go back to school tommorrow. We have finals all next week and then we switch classes on the 18th. But my classes next semester are so hard. I don't know if I'm going to be able to keep up. I have a bowling match after school tommorrow until 5:30pm and then I have therapy at 6pm. I think I'm going to stop going though. I feel the same as I did when I first started, so I don't think it's helping at all. And it's just another thing for Jan to use against me when we fight anyways. I think I'm on the verge of snapping. I seriously can't take her anymore. She's $0 uneducated, but feels that she can be critcial of everything. And then she assumes that since I'm a genius, that somehow raises her intellect. I don't understand her at all. And we just had to get Sheeba put to sle~p last Saturday so she's even more upset and tempermental lately. I'm honestly thinking about running away again. I don't think I can take her anymore. I've been slitting my wrists for a long time (,1 think you knew that) but it's getting so bad that I think I'Ve messed up some nerves in my wrist. My whole hand just randomly goes numb sometimes and I can't feel anything. It's so strange. And people have been beginning to notice my immense amount of scars so l'Ve had to start wearing wristbands when my clothes don't cover my wrists. I know it probably makes you sad to hear all of this but I feel that I need to spill to someone. Hopefully I'll hear back fLam you soon. MSN 8 with e-mail virus protection service: 2 months FREE* http://join.msn.com/? page=features/viruS Hotmail@ I -- L~I ,"' john_deputy@hotmail.com lnbox '-' "~' ';""', ,-, -,-,;" ~.~,- . ~ Previous page Iiilisilliil~!;r," From: "Angela Deputy" <angelftshOO5@msn.com> To : john_deputy@hotmail.com Date: Fri, 03 Jan 2003 10:01:54 -0500 Yeah, I thought having therapy would be good for a while there too, until last night. I really just wanted someone to vent to, someone to talk to that I know I could trust and confide my secrets in. No. I've been going to this lady for a long time. First it started out every week for an hour and now it's every other week for an hour. But anyways, I have tried so hard up until this point to tell this woman what I was really feeling on the inside, which isn't good. Last night, I told her about my cutting and burning and how I take laxatives after I eat and just everything that I haven't told her before. 1hat must have been one of the worst decisions that I have made in a long time. Becaus~ she brought Jan in and told her everything, without preparing me for it at all. So Jan is trying as hard as she can to get me admitted into the hospital again. I really don't want this at all, whether I need it or not. I think she's taking me tonight afte~ she comes home from work. We have off today on acount of snow, so 1'm just sitting around paranoid and shaking. I thought therapy would help me but now I'm hurting very badly. My life is getting so much better though, which is what I can't understand. wan and I's relationship was improving a little, I started talking to you again, my grades are higher than ever, I have lots of friends. I just feel so much worse inside. God, this is all Jan's fault. I hate her. I don't want to go to the hospital and her getting involved in this has made it considerably worse. No one understands how much worse this situation has gotten with her involvement. And worst of all, last night, I wouldn't show Jan or my therapist any of my wounds, and they don't beleive me. t think what I do to myself is personal and therefore my choice to whom I show it. I think not being believed is the worst emotion I have ever experienced. The therapist says that self-mutilation is something people do because they want others to see. I don't think that and I don't want others to see. So, that's where I'm at right now and I have no clue what comes next. Whatever it is, I'll try to get to a computer to contact Y9U. Or if I can't get to a computer I'll write or call. Take care. And I'm sorry. . . Protect your PC - get McAfee. com VirusScan Online http://dinic.mcafee.com/clinic/ibuv/campaign.asp? cid=3963 http://lwllfd.lawll.hotmail.msn.com/cgi -bin/getmsg?cunnbox=F995467 507 &a=28cac... 3/6/2003 Hotmail@ 1- L~ ".- john_deputy@hotmail.com Inbox I " ~~ -"', '-'~,- -. PreviouS Page ~~c- From: "Angela Deputy" <angelfish005@msn.com> To: john_deputy@hotmail.com Date: Fri, 03 Jan 2003 14:48:09 -0500 I would rather undr~ss on national television than show anyone my cuts and burns. I think they are the most personal things I have. I view them as more personal than my writing, drawings, and paintings. I especially wouldn't show my therapist because Jan was right in the room and because she had already betrayed my trust. I never want to see her again. If I don't get committed to a hospital tonight or anytime soon, r am through with therapists. I am sick of having my trust betrayed and I am definately sick of not being beleived. And if anyone ever tells me that the only reason I hurt myself is for attention I don't know what I'll do because that would have to be one of the worst things you could ever say to a cutter. It's especailly insulting to me because I don't know why I do it. It's not for attention or I would be showing people by now and I would have told someone a long time ago when it first started. It's not because I want to die either because if is was, I would be dead already. I honestly have yet to figure the whole situation out. I switch therapists constantly. Once I feel threatened by one or betrayed, I'll just move on to another or stop going for a while. I wouldn't mind if you talked to my therapist except for I'm not going anymore, ever. And I really hope that I don't get committed tonight. I'm dreading Jan coming home because I have no clue what is going to happen. I know that she can't have roe committed, as I am over 14. But my therapist could if she convinces the people at the hospital that I am a danger to myself or others. I don't want to go back to the hospital. STOP MORE SPAM with the new MSN 8 and get 2 months FREE* http://join.msn.com/? page~features/junl<mail http://lwllfd.1awll.hotmai1.msn.com!cgi-bin/getmsg?cunnbox=F995467 507 &a=28cac... 3/6/2003 . ~ . ~ , "" lV~1J1" ~J.VI.Llla..U_ - Hotmail@ john_deputy@hotmail.com Inbox I Previous Page From: "Angela Deputy" <angelftsh005@msn.com> To : john_deputy@hotmail.com Subject: hi Date: Sun, 23 Feb 2003 17:47:37 -0500 <'~ - ~ -0- Dad, Hi. How are you? Sorry I didnlt write you earlier. lIve been really busy with school and getting better from Canada. It was -40 the whole time. I was so sick and had like an asthma attack or something. I was coughing constantly and just couldn't breathe properly. Then I started losing my voice so my French teacher took me to the hospital on our way home, because of the snow we had to rent a hotel for a night in Reading. So that night she took one other kid and me to the hospital. I had to use a nebulizer and they said I had asthma and an ear infection, so now I have to use this inhaler like twice a day. It really sucks because ever since the cold of Canada, it's been even harder for me to breathe right. I don't know. And the Quebec City mascot was this huge scary marshmallow guy named "Bonhomme" (good man in English) and he was EVERYWHERE. Store windows, houses, buses, just everywhere. And he was always winking so it made his black eyes look really creepy. And Canadians are just crazy in general. They eat everything with maple syrup on it. I must have lost ten pounds! I ordered a hamburger and fries (really American of me) and there was maple syrup on it. err! It was so frustrating because not only did I have to figure out the culture and customs, I also had to eat maple syrup at every meal. I did get the chocolates you sent me though. They're excellent. Oh yeah, mom asked me what I wanted for my birthday a couple of weeks ago and two nights ago I told her that I wanted her to let me come see you over ------ the summer. After talking about it for a while she said that the decree says visitation in the US only. Then she said that she wanted you to talk to her about it. So I don't know what's going on with that but I would like you to talk to her so she doesn't think that too much stuff is going on behind her back. She gets really paranoid about that. I got my pictures dev~loped from Canada and as soon as I get the copies of negatives that I want, I'll be senQing you some. Oh, and I thought of the perfect time for you to call to talk to me. Inst~ad of calling on Saturday morning (because I'm not home) you could call around 3:15pm ~y time. On Wednesdays or something. I think it would be better that way because Dana an~ I are both home and mom isn't. Or if you just wanted to call to talk to me and then call Dana normally on the weekend. Whatever works. But I've got to get going now. I'm ~oing out in like 5 minutes. 1111 probably be able to write to you on a regular basis now, so I'll talk to you soon. Love, Angela , ! j ._~--~ I - :!Ili...t/~~ -- - """",,""""'-'--" . -" i~-J......... J - " ~", ,-, ,-, .iJl!J\->;I' >>> >> >> >>>From: "Musketeers _3" To: john_deputy@hotmail.com. >>>SallyKreitzer@pacses.com Date: Mon, 17 Mar 200317:12:27 -0500 >>> > > >John, I just received in the mail today registration for summer >>>camp. Dana will be attending the YMCA Day Camp this summer. I need >>>to know what if any week/s you would like for visitation here in >>>the States. I need this information by Thursday March 20th as >>>registration is this weekend. No changes will be made once >>>registration is done as the camp must be paid for in full and no >>>money is refundable. August 18th-22nd is the last week before >>>school and I ask you not choose this week as we must prepare for >>>back to school unless of course you would be helping with these >>>costs then I would consider it. Kind Regards, Janice >>> >>> ..~~-.~ ."~ -_I "'-_ .1 ~ . ,~ Iii<< HotmaU" john_cleputy@hotmaii.com Inbox I Previous Page From: "Musketeers _3u <musketeers~3@msn.com> To : john_deputy@hotmail.com CC: m.pettinnati@pastatelaw.com Subject: Re: Date : Wed, 19 Mar 2003 16:49:42 -0500 You contradict yourself. If in fact you did contribute to camp costs your pockets would be affected too. Please read over support guidelines for proper clarification as to child support. Camp costs are not covered. Which is neither here nor there. ViSitation will take place in the States unless you do happen to get the decree modified. Which is highly doubtful. We already have plans for our yearly weekly vacation to Georgia in July. Unfortunately the whole month is not feasible. Do you have any other weeks that you are interested in? And for proper planning and for the record I need to know where this visitation will be taking place. .J From: "JOHN DEPUTY" <john_deputy@hotman.com> To: musketeers_3@msn.com Subject: Re: Date: Wed, 19 Mar 2003 13:59:33 +0000 j\ Jan, I had sent email at least a month ago detailing to you that I will be exercising my visitation during the month qf July (inclusive the 1st through the 31st). Please see below. I am petitioning!for the visitation to be modified so that the girls will be able to come to visit with me here in France. I see no problem at this juncture with getting that through, unless air travel becomes an issue at that time, in which case I would not allow the girls to fly. As this is the field in which I am employed I trust my own judgement on air safety, not discounting your opinion. Therefore, it would be a waste of your money to schedule YMCA camp for the mOnth of July, though if you choose to do so it will be your pocket alone that is affected. You should keep in mind, however, that I do indeed already contribute to the costs of camp. It is covered with my monthly support check. This a complete copy and paste of our communication regarding your denial of visitation dated January 1st 2003: That is a shame for the girls. It is a great consolation to me that they will, sooner than we think, be able to make their own decisions with regards to their relationship with me. As far as the summer goes, then, I need a firm commitment from you that the month of July will be a good time to visit uninteruptect. I would, of course, expect you not to interfere with this time frame, but realize that, as per your standard operating procedure, you seem unable to extend yourself this far. The children have both expressed-wanting to spend more -time with me throuh the year and again I have made a way to accomplish this. Yet again you have found a way to thwart this. Rise to the challenge of being a productive parent rather than scheming. Using the children to punish me only results in punishing them. From: "Musketeers 3" To: john_deputy@hotmaiI.COm Subject: Re: insurance bills Date: Tue, 31 Dec 2002 22:45:12 -0500 1m afraid I have bad news. The decree states that visitation is to take place in the States. I think under current world events this would be a wise decision at this time. Please consider visitation State side. From: "john deputy" To: musketeers_3@msn.com Subject: Re: insurance bills Date: Tue, 31 Dee 2002 08:10:15 +0000 http://lw1lfd.lawI1.hotmail.msn.com/cgi-bin/getmsg?cunnbox=F995467507 &a=2a3e... 4/19/2003 ..-- ~ -I ,~ -I > >>Frdm: "JOHN DEPUTY" >'>To: musketeers 3@msn.com >>Subject: Re: Date: Wed, 19 Mar 200313:59:33 +0000 >> >> >>Jan, >>1 had sent email at least a month ago detailing to you that 1 will >>be exercising my visitation during the month of July (inclusive the >>1st through the 31st). Please see below. 1 am petitioning for the > >visitation to be modified so that the girls will be able to come to >>visit with me here in France. 1 see no problem at this juncture > >with getting that through. unless air travel becomes an issue at >>that time, in which case 1 would not allow the girls to fly. As >>this is the field in which 1 am employed 1 trust my own judgement >>on air safety, not discounting your opinion. Therefore, it would >>be a waste of your money to schedule YMCA camp for the month of >>July, though if you choose to do so it will be your pocket alone >>that is affected. You should keep in mind. however, that 1 do >>indeed already contribute to the costs of camp. It is covered with >>my monthly support check. >> > > This a complete copy and paste of our communication regarding your >>denial of visitation dated January 1st 2003: >> >>That is a shame for the girls. It is a great consolation to me >>that they Will, sooner than we think, be able to make their own > >decisions with regards to their relationship with me. As far as the >>summer goes, then, 1 need a firm commitment from you that the month >>of July will be a good time to visit uninterupted. 1 would, of >>course, expect you not to interfere with this time frame, but >>realize that, as per your standard operating procedure, you seem >>unable to extend yourself this far. > > The children have both expressed wanting to spend more time with me >>throuh the year and again 1 'have made a way to accomplish this. Yet >>again you have found a way to thwart this. Rise to the challenge of >>being a produ'ctive parent rather than scheming. Using the children >>to punish me only results in punishing them. >> >>' >>>From: "Musketeers _3" To: john_deputy@hotmail.com Subject: Re: >>>insurance bills Date: Tue, 31 Dee 200222:45:12 -0500 >>> >>> >>>1m afraid 1 have bad news. The decree states that visitation is to >>>take place in the States. 1 think under current world events this >>>would be a wise decision at this time. Please consider visitation >>>State side. >>> >>> >>> >>> ", , ",.- "'illl-Iill';i<l'_"L" I.. ," - d:. " -,-1- --<. paqe 2 of 5 >>1 had sent email at least a month ago detailing to you that I will >>be exercising my visitation during the month of July (inclusive the > > 1st through the 31st). Please see below. I am petitioning for the >>visitation to be modified so that the girls will be able to come to > >visit with me here in France. I see no problem at this juncture > >with getting that through, unless air travel becomes an issue at >>that time, in which case I would not allow the girls to fly. As >>this is the field in which I am employed I trust my own judgement >>on air safety, not discounting your opinion. Therefore, it would >>be a waste of your money to schedule YMCA camp for the month of >>July, though if you choose to do so it will be your pocket alone >>that is affected. You should keep in mind, however, that I do >>indeed already contribute to the costs of camp. It is covered with >>my monthly support check. >> > > This a complete copy and paste of our communication regarding your >>denial of visitation dated January 1st 2003: >> >>That is a shame for the girls. It is a great consolation to me >>that they will, sooner than we think, be able to make their own >>decisions with regards to their relationship with me. As far as the > >summer goes, then, I need a firm commitment from you that the month >>of July will be a good time to visit uninterupted. I would, of > >course, expect you not to interfere with this time frame, but >>realize that, as per your standard operating procedure, you seem > >unable to extend yourself this far. >>The children have both expressed wanting to spend more time with me > >throuh the year and again I have made a way to accomplish this. Yet >>again you have found a way to thwart this. Rise to the challenge of >>being a productive parent rather than scheming. Using the children >>to punish me only results in punishing them. >> >>- >>>From: "Musketeers _3" To: john_deputy@hotmail.com Subject: Re: >>>insurance bills Date: Tue, 31 Dee 200222:45:12 -0500 >>> >>> >>>lm afraid I have bad news. The decree states that visitation is to >>>take place in the States. I think under current world events this >>>would be a wise decision at this time. Please consider visitation >>>State side. >>> >>> >>> >>> >>> 3/20/03 - -..- ~<, I " - W-"" Hotma i I@ john_deputy@hotmail.com Inbox I Previous Page From: Dana Deputy <coffeejunki07@yahoo.com> To : john_deputy@hotmall.com Subject: HI Dad!!! Date: Fri, 13 Jun 2003 05:37:21 -0700 (PDT) Hey dad..ThIs Is Dana..Can u please not tell mom that I have been writtlng to you because I will get In trouble...Heather helped me get this e-mail thing working so that I can write to u even more..And mom doesnt know bout this or me writtlng to you so please dont tell her...Good luck finding a place and a job!!Mom said that you could work at the Harrisburg Airport or the depo..For the anny if thats how you spell it...Well..Gtg..Talk to ya later luvya, dana Do you Yahool? Free online calendar with sync to Outlook(TM). , HOWARD B. KRUG LEON P. HALLER JOHNW. PURCELLJR. JILL M. WINEKA BRIAN J. TYLER NICHOLEM. STALEY O'GORMAN , , .'. - " -~ LAW OFFICES q:>~~!3~ 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FAX (717) 234-0409 September 12, 2003 John Deputy 25 Rue Jacques Du1ud 92200 Neui11y-Sur-Sein, France "'-.,,,;-~ '. ,""~,'''-'.~ "c:. ,.,~, ~~""'i- HERSHEY (717) 533-3836 JOSEPH NISSLEY (1910-1982) JOHN W. PURCELL Of Counsel Client/Matter No. 007016-25364 BILLING SUMMARY FOR CUSTODY/CONTEMPT MATTERS Date Amount 04/14/03 (1.75 hrs. x $140) $ 245.00 05/19/03 $ 50.00 07/03/03 $1,798.00 08/22/03 $ 49.00 09/12/03 $1. 638.00 TOTAL $3.780.00 \\~~.IBIT 11 ICf1Tlurar~ ~ 1\..2 a tr. q~'7 -0 ~ S/2.S - I: JI PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 (717) 234-4178 - FAX 233-1149 April 14, 2003 Billed through 04/14/03 Bill number D07016-25364-002 NMS John Deputy 25 Rue Jacques Dulud 92200 Neuilly-Sur-Seine, France RE: Domestic ========~=========================================~=========~=== FOR PROFESSIONAL SERVICES RENDERED 03/11/03 03/14/03 04/03/03 Review email from client; Telecon with Sally Kreitzer at DRO; Respond to client email Review contents of former counsel's file Review former attorney's file; Review client e-mail regarding support issues and respond; Prepare custody petition Complete custody petition Revise and finalize custody petition 04/07/03 04/10/03 Total Fees for this bill 10.00 hrs COSTS AND EXPENSES 04/11/03 Cumberland County Prothonotary: File Petition for contempt Total Costs & Expenses for this bill $ BILLING SUMMARY Nichole M. Staley 10.00 hrs 140 /hr TOTAL FEES FOR THIS BILL 10.00 hrs $ , -. rllt.:lij[1i;,( .50 hrs 1.75 hrs 6.00 hrs 1. 50 hrs .25 hrs 1,400.00 50.00 50.00 1,400.00 1,400.00 John Deputy Bill number D07016-25364-002 NMS TOTAL COSTS & EXPENSES FOR THIS BILL TOTAL OF FEES, COSTS AND EXPENSES LESS TRUST ACCOUNT TRANSFER TOTAL AMOUNT NOW DUE BEGINNING TRUST ACCOUNT BALANCE TRUST AMOUNT APPLIED TO THIS BILL ENDING TRUST ACCOUNT BALANCE --r. ll.~~ PAGE 2 $ 50.00 ------------ $ 1,450.00 $ 1,450.00 CR ------------ $ .00 $ $ $ 3,000.00 1,450.00 CR 1,550.00 . , "^, -1ll~M" PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 (717) 234-4178 - FAX 233-1149 May 19, 2003 Billed through 05/19/03 Bill number D07016-25364-003 NMS John Deputy 25 Rue Jacques Dulud 92200 Neuilly-Sur-Seine, France RE: Domestic ==============================================:================= Account balance as of bill number 002 dated 04/14/03 Payments received since last bill Net balance of account $ $ $ 1,45;0.00 1,45;0.00 .00 COSTS AND EXPENSES 04/22/03 Cumberland Co Prothonotary: File Petition for Modification 5;0.00 Total Costs & Expenses for this bill $ 5;0.00 BILLING -SUMMARY TOTAL COSTS & EXPENSES FOR THIS BILL $ :;0.00 ------------- $ :;0.00 $ ~; 0 00 CI ------------- $ .00 TOTAL OF FEES, COSTS AND EXPENSES LESS TRUST ACCOUNT TRANSFER TOTAL AMOUNT NOW DUE BEGINNING TRUST ACCOUNT BALANCE TRUST AMOUNT APPLIED TO THIS BILL ENDING TRUST ACCOUNT BALANCE $ $ $ 1,550.00 50.00 CR 1,500.00 - J - PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 (717) 234-4178 - FAX 233-1149 July 3, 2003 Billed through 07/03/03 Bill number D07016-25364-004 NMS John Deputy 25 Rue Jacques Dulud 92200 Neuilly-Sur-Seine, France RE: Domestic :==~============================================================ Account balance as of bill number 003 dated 05/19/03 Payments received since last bill $ $ $ Net balance of account FOR PROFESSIONAL SERVICES RENDERED OS/29/03 06/01/03 06/02/03 06/02/03 06/17/03 06/18/03 06/20/03 06/20/03 06/23/03 06/25/03 06/25/03 06/25/03 Review file regarding conciliation preparation; Letter to client regarding proposed order Prepare for conciliation Attend custody conciliation Telecon with client regarding conciliation Review client emails; Respond Office conference with John Purcell, Jr. regarding custody matters Extended telecon with conciliator and mom regarding custody matters Telecon with client regarding conference with conciliator Telecon with Janice Deputy regarding travel arrangements; Telecon with client regarding same Telecon with Janice Deputy; Letters to Ms. Deputy regarding itinerary and passports Telecon with Janice Deputy regarding passports; Email to client regarding same Telecon with client regarding passports; Letter to Ms. Deputy regarding same; Review U.S. government website regarding passport procedure Telecon with Janice Deputy regarding passports; Telecon with Judge's chambers regarding order; Email to client Second telecon with Janice regarding passports 06/30/03 06/30/03 "'"--!lll!1-~ 50.00 '50.00 .00 2.00 hrs .25 hrs 2.50 hrs .50 hrs .25 hrs .25 hrs .50 hrs .25 hrs .35 hrs .75 hrs .35 hrs .50 hrs .25 hrs .25 hrs ......- John Deputy Bill number 06/30/03 07/01/03 07/02/03 07/02/03 07/02/03 .I . .;1 ~~~-"''''''.;,,", PAGE 2 D07016-25364-004 NMS Deliver consent form to Janice Deputy Review Court Order; Letter to client regarding same; Letter to mother regarding Order and travel arrangements Review conference summary; Copy client regarding same Prepare demand for hearing; Letter to court regarding same Review brief client emails (no charge) .:;0 hrs .75 hrs .25 hrs .25 hrs .00 hrs Total Fees for this bill 10.70 hrs 1,498.00 COSTS AND EXPENSES 06/23/03 BILLING SUMMARY 300.00 Janice Deputy: Passport Fees Total Costs & Expenses for this bill $ 300.00 Nichole M. Staley 10.70 hrs 140 /hr 1,498.00 TOTAL FEES FOR THIS BILL 10.70 hrs $ 1,498.00 TOTAL COSTS & EXPENSES FOR THIS BILL $ 300.00 -------.----- $ 1,798.00 $ 1,500.00 Cl -------.----- $ 298.00 TOTAL OF FEES, COSTS AND EXPENSES LESS TRUST ACCOUNT TRANSFER TOTAL AMOUNT NOW DUE BEGINNING TRUST ACCOUNT BALANCE TRUST AMOUNT APPLIED TO THIS BILL ENDING TRUST ACCOUNT BALANCE $ $ $ 1,500.00 1,500.00 CR .00 - , ~ J", ,_'I ,- . .~ '''''''~l\l! PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 (717) 234-4178 - FAX 233-1149 August 22, 2003 Billed through 08/22/03 Bill number D07016-25364-005 NMS John Deputy 25 Rue Jacques Dulud 92200 Neuilly-Sur-Seine, France RE: Domestic ==========================~===================================== Account balance as of bill number 004 dated 07/03/03 Payments received since last bill (last payment 08/19/03) Credit for prepaid funds $ 1,798.00 $ 1,798.00 -------_._--- $ .00 $ 202.00 CJ; Net balance of account FOR PROFESSIONAL SERVICES RENDERED 07/07/03 Telecon with Janice Deputy regarding plane tickets; Letter to Janice Deputy regarding same; Prepare instructions for runner regarding hand delivery . 35 hrs Total Fees for this bill .35 hrs ,l9.00 BILLING SUMMARY Nichole M. Staley .35 hrs 140 /hr 49.00 TOTAL FEES FOR THIS BILL .35 hrs $ 49.00 PREPAID CREDIT CARRIED IN ACCOUNT $ $ $ $ 49.00 TOTAL OF FEES, COSTS AND EXPENSES LESS PREPAID CREDIT 49.00 C! TOTAL AMOUNT NOW DUE .00 1!53.00 C! TRUST ACCOUNT BALANCE $ .00 ~JillIllI,r 1-. ~ ~-;, ~ ~ !&t1'.lm,'",~ PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 (717) 234-4178 - FAX 233-1149 September 11, 2003 Billed through 09/12/03 Bill number D07016-25364-008 NMS John Deputy 25 Rue Jacques Dulud 92200 Neuilly-Sur-Seine, France RE: Domestic =============================================================~== Account balance as of bill number 005 dated 08/22/03 Payments received since last bill (last payment 08/19/03) $ 49.00 $ 49.00 ------------ $ .00 $ 153.00 CR Net balance of account Credit for prepaid funds FOR PROFESSIONAL SERVICES RENDERED 08/25/03 09/03/03 09/05/03 09/08/03 09/09/03 09/10/03 09/11/03 09/12/03 Review emails from client; Respond Prepare petition for approval of telephone testimony Review file; Prepare for custody hearing Review file; Prepare for hearing Extended telecon with client regarding custody hearing preparation Review documents received from client Hearing preparation (estimated) Attend hearing (estimate) .35 hrs .35 hrs 2.50 hrs 1.00 hrs 1.00 hrs 2.50 hrs 2.00 hrs 2.00 hrs Total Fees for this bill 11.70 hrs 1,638.00 BILLING SUMMARY Nichole M. Staley 11.70 hrs 140 /hr 1,638.00 TOTAL FEES FOR THIS BILL 11.70 hrs $ 1,638.00 -' ...jlW::!;llb>I"~ - John Deputy Bill number D07016-25364-008 NMS TOTAL OF FEES, COSTS AND EXPENSES LESS PREPAID CREDIT TOTAL AMOUNT NOW DUE TRUST ACCOUNT BALANCE $ $ $ $ .00 . ill' ;)jIj_iU-t,; PAGE :2 1,638.00 153.00 CR 1,485.00 ~ , ~-- ~~ _.I~ - - ~I I _"_?~ , -'" Iil~""",;, , JOHN ROBERT DEPUTY PLAINTIFF V. JANICE F. DEPUTY DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-6823 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 13th day of October, 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective cOlUlsel appear before Melissa P. Greevy, Esq. . the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, FA 17011 on the 15tbdayof November ,2000, at 10:15 a.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 also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR 1HE COURT, By: Isl The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 " It?,~ "~ /0' J&. -t961 /,!J .If. .,tlt:1 I .'~~r~!lI;iii,,_", .. .~ ,~,,' ~.~ . -"-- -". ~'. " , .~ '~~u .~_~. "'" __ .~ ~,_ 'H ~. "~"""'- ", ..., " , n.: 0"'" 1-:' ..J-..... u,,! ," "". - '-', ;",:" rj'j ;:j: _29 CUI,.',:'-':': .'.... ;j,;..,,!::;! :,_h!'+~' I) )iJvrl/ 1-'t:.\!','.ICVI ,\/.:, ',., I" ) , \];.JIL';'\I~!l\ M~~~4~ ~ ~@ ~d_ ~ ft1~ $~~ , . _">v,, ;"l>~""m~~~..):'fNI\'l!~'R"'~~)Fl~~~iffl~~~Jj"!O~~ '-'<w.".,~ -~,. m;: ,~""'~~=~_ .1_ I ..~..J ,-- ~~ L'~a_-",,__< JOHN ROBERT DEPUTY, Plaintiff , vs. * * * * IN THE COURT OF COMMON PLEAS CUMBERLANDCOUNTY, PENNSYLVANIA * NO. t()-&4~3 ~ JANICE F. DEPUTY, Defendant. * CIVIL ACTION - LAW * CUSTODY ORDER OF COURT AND NOW, this day of , 2000, upon consideration of the attached complaint it is hereby directed that the parties and their respective counsel appear before Esquire, the Conciliator, at , Pennsylvania, on the day of 2000 at o'clock, _.m., for a Pre-Hearing 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 a temporary order. Either party may bring the child who is the subject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: By Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR 1 COURTHOUSE SQUARE, 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 ~, ,-",,,",' JOHN ROBERT DEPUTY, * IN THE COURT OF COMMON PLEAS Plaintiff, * CUMBERLANDCOUNTY, PENNSYLVANIA * vs. * NO. b1>-(,.g-':23~ I~ * JANICE F. DEPUTY, * CIVIL ACTION - LAW Defendant. * CUSTODY COMPLAINT FOR CUSTODY AND NOW, Plaintiff, John Robert Deputy, by and through his attorney, Edward J. Weintraub, Esquire, files a Complaint For Custody against Defendant, Janice F. Deputy, and in support thereof, avers the following: 1. Plaintiff is John Robert Deputy, Father, who currently resides at P.O. Box 20402, Jeddah 21455, Saudi Arabia. 2. Defendant is Janice F. Deputy, Mother, who currently resides at 1821 Bridge Street, New Cumberland, Pennsylvania 17070. 3. Plaintiff seeks custody of the following children: NAME Present Address AGE Angela M. Deputy Dana L. De put Y 1821 Bridge Street, New Cumberland, PA 1 82 1 Bridge Street, New Cumberland, PA 13 9 4. The children were not born out of wedlock. 5. The children are presently in the custody of Mother, Janice F. Deputy, who currently resides at 1821 Bridge Street, New Cumberland, Pennsylvania. ~~"". lll:lIOOll!"ili,-,,,-,, 6. During the past five (5) years the children have resided with the following persons at the following addresses: ~ons Address !:Late. Mother and Father, 118 Quail Forest Court, Savanah, GA 1992- 2/1997 Ron & Pat Klinger, 1093 Old Willow Mill Road, Mechanicsburg, PA 2/97-4/97 Mother 705 Market Street, New Cumberland, PA around 4/97 Mother 1821 Bridge Street, New Cumberland, PA around 4/98 7. The Mother of the children is Janice F. Deputy, who currently resides at 1821 Bridge Street, New Cumberland, PA 17070. 8. The Father of the children is John Robert Deputy, who currently resides at P.O. Box 20402, Jeddah 21455 Saudi Arabia. 9. The parties are not married. 10. The relationship of Plaintiff to the children is that of Father. Plaintiff currently resides with the following person: Person Relationship Sophie Deputy Wife Gabrielle Deputy Step-daughter 11. The relationship of Defendant to the children is that of Mother. Defendant currently resides with the following persons: Person Relationship Unknown 12. Plaintiff and Defendant have not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this ~, or another court, except their divorce proceeding in the State of Georgia in 1997 (attached). 13. Plaintiff and Defendant have no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 14. Plaintiff and Defendant do not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 15. The best interests and permanent welfare of the children, will be served by granting the relief requested, inter .aIi.a, because the Plaintiff Mother has been one of the children's primary caretakers. 16. Each parent whose parental rights to the children have not been terminated and the persons who have physical custody of the children have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to intervene. Name Address Basis of Claim NONE - ,,~ ~_<h~'<'_ WHEREFORE, Plaintiff respectfully request that this Honorable Court enter an Order granting him shared legal custody and primary physical custody, with Plaintiff Father to have liberal partial physical custody. By: Edward J. Weintraub, Esquire 2650 North Third Street Harrisburg, PA 17110 (717) 238-2200 Attorney 10. #17441 Dated: 0 ( A HORNEY FOR PLAINTIFF ^, "- ~. ~'_.j1,i_ '10/04/2000 18: 32 6181638 le/Mi2000 07: 23 71 7-23B~~2a~ SCHOUWENAARS STERN U~ W~!NI~~U~ PAGE 01 ,'""....... ,,'... VERIFICATION BY FACSIMILe I, John Cleputv. hereby swear and affirm that the facts contained in the foregoing Complaint for CUStody ...e true and correct end ...e mad" subject to the penalties of 18 Po. C.S. Sec. 4904 .elating to unsworn falsification to authorities. Date:J:qe-I20 ORIGINAL VERIFICATION I. Edward J. Weintraub. Esquire, verify that the contents of the foregoinQ Custody Complaint lire true end oorrect to the best of my knowllldge. information and belief, I am authorized to respond based upon information provided by John Deputy and in mv capacity as hiS counsel. I understand that I arn subject to the penaltlas of 1 SPa. C.S. Sec. 4904 relatl!'g to un$wl)rn falsification to authorities for any falsl! statemlllr\ts that I made in the foregoing document. Date: ~,DU ~ Edward J. Weintraub. Esqui'l! 5<' I I J , '1$1&'" EXHIBIT "A" - ~" I - ~"~'_"~'i IN THE SUPERIOR COURT OF CHATHAM COUNTY STATE OF GEORGIA Janice F. Deputy, Plaintiff, v. ) ) } ) ) ) ) CIVIL ACTION FILE # DR97-0157-MI John R. Deputy. Defendant. FINAL JUDGMENT AND DECREE OF DIVORCE Upon consideration of this case. upon evidence submitted as provided by law, it is the judgment of the court that a total divorce be granted, that is to say. a divorce a vinculo matrimonii, between the parties to the above stated case, upon legal principles. It is considered, ordered and decreed by the court that the marriage contract heretofore entered into between the parties to this case, from and after this date, be and is set aside and dissolved as fully and effectually as if no such contract had ever been made or entered into, and Plaintiff and Defendant in the future shall be held and considered as separate and distinct persons altogether unconnected by any nuptial union or civil contract, whatsoever, and both shall have the right to remarry. The Separation Agreement between the parties dated January 3D, 1997. and filed in this Court as part of the proceedings in this case is hereby approved and incorporated herein by reference and made a part of this Decree. Plaintiff and Defendant are each awarded the property rights, division of debts and final settlement of marital issues as the said parties agreed in accordance with the said Separation Agreement; and both parties are ordered to comply with each and every provision of said Separation Agreement and this Order. Upon the failure of either party to comply with the provisions of this Decree, either party shall be subject to punishment for contempt of Court. The Court awards custody of the child of the parties as follows: The Plaintiff and Defendant shall have joint legal custody of the minor children of the parties, to wit: ANGELA MARIE DEPUTY, born March 21, 1987 and DANA LILLIAN DEPUTY, born May 9, 1991. with physical custody being vested in the Plaintiff, Mother. .:"-- ...:.._" 10 3811d SClIIIIN3MnOHOS 8E91819 0E:E1 0006/&6/&0 - j, ;1 .~"""-~''''',' In determining child support. the Court finds as follows: Defendant's gross monthly income is $ 2) "I "0 Dollars. Plaintiffs anticipated gross monthly income shall be approximately $ 1,3QQ. Dollars. In this case child support is being determined for one (2) children. The applicable percentage of gross income to be considered is 23 percent to 28 percent. The Separation Agreement belween the parties. paragraph 7, states that the Defendant shall pay as temporary and permanent child support ~ percent of his gross monthly income. .Therefore, ..the fillal award of child support is set at $635.00 per month. Whenever, in violation of the terms of this Order there shall have been a failure to make the support payments due hereunder so that the amount unpaid is equal to or greater than the amount payable for one month, the payments required to be made may be collected by the process of continuing garnishment for support. Decree and order entered this 7 day of --11:1 A~'/~ ,199L. (~:.,.~ ___ ~ ~V\ Ju.LI CHARLES B. MIK LL, JR. Judge, Superior Court of Chatham County Eastern Judicial Circuit, Georgia 1:0 39\1d S~\I\lN3MnoHOS 8E91819 0E:El 0001:/61:/60 I .u, ""--"~ T~>_"W"',-J 'f , \ rlU,1l IN ()r:r-i(:~: ( ~~, ~L) 1~q.7 . f - .- :'. Jp '.tr., SEP~RATI~ AGREEMENT I ~~~I This agreement is made the ~ day of J(/<,.....U,l..,. y . 1917. between Janice F. Deputy, herein called the 'Wife" (or "Mother" in matters relatin'g to child custody and visitation), and John R. Deputy, herein the "Husband" (or "Father" in matters relating to child custody and visitation). WHEREAS, the parties were lawfully m'ilrried on August 30, 1986 in Dillon, Dillon County, South Carolina, and lived together as Hl!Isband and Wife thereafter; but both parties have determined that their happiness reqlJires a separation and the parties, therefore, concur that a separation is necessary for the health a.nd welfare of both parties, on account of which the parties maritally separated on or abQut January 24, 1997, and will hereafter live separate and apart from the marital obligations to each other; and WHEREAS, the Husband and Wife have entered into this agreement freely and with the .. advice or opportunity of counsel, with full information as to the estate and financial circumstances of each party, and knowledge that its provisions are fair; and WHEREAS, it is the desire of both parties to finally settle, adjust, compromise, and determine their property rights, rights of support and maintenance by each party against the other by reason of their marriage, and any and all other rights existing between the parties growing out of the marriage relation; and , WHEREAS, there are two minor children as issue of this marriage, to wit: ANGELA MARIE DEPUTY, born March 21,1987; and DANA LILLIAN DEPUTY, born May 9.1991. THEREFORE, THE PARTIES HEREBY AGREE AS FOLLOWS: 1. Separate Living. The Husband and Wife may live apart. Each may reside at such place as each deems fit. However, the marriage is not terminated until the divorce, if any, is final. The Husband and Wife will not in any manner annoy, molest or disturb the other, or endeavor to compel the other to cohabit with the other. 2. DivisiOn of Marital Debt. The Husband and Wife will at all times keep each other indemnified against all debts and liabilities which they may hereafter contract and from all actions, claims. demands, co&s, damages, and expenses on account thereof. a. Wife shall be solely responsible for the following marital debts: (1) Best Buy Store Account #7001166001035461; and (2) Rich's Department Store Account # 0114410277. b. Husband shall be responsible for all remaining marital debt. c. Husband acknowledges as his separate debt his medical bills and related expenses for his treatment at Saint Joseph's Hospital, Savannah. Georgia including any Ambulance, Medical Transport and expenses incidental to his care, and assumes sole responsibility therefor and Husband shall hold Wife harmless therefrom. E0 39\1d StI\1\1N3MnOH::lS 8E9IS "[9 0E:E"[ 000Z/6l/60 L: _.L .. '--=4oi,,, d. Each party shall pay their respactive share of the remaining marital debt and shall hold the other party harmless therefrom and indemnify the other party for any loss or expense related thereto, including costs and attorney fees to enforce this Agreement. Each party shall pay their own separate other debts, incurred hereafter or prior to the marriage and shall hereafter incur no debt in the name or account of the other. 3. Separate Property of Wife. The Wife shall have and retain, as her sole and separate property, all her clothing and personal items, and other personalty now in her possession. Wife shall have and retain sole and exclusive possession of the 1988 Honda Accord LX and Wife shall maintain and pay the insurance, ad valorem taX and registration fees on said vehicle. Husband hereby agrees to sign over to Wife the title and registration on said vehicle. 4. Separate Property of Husband. The Husband shall have and retain, as his sole and separate property all his clothing and personal items, and other personalty now in his possession. 5. Division of Personal Property. The parties have heretofore divided their remaining personal property and household goods and furniture to their mutual satisfaction. Henceforth, each of the parties shall own, have, and independently enjoy, free of any claim of the other, all such items of personalty of every kind, nature and description, wherever situate, which are now owned or held by each separately, with full power in each to dispose of the same. 6. Division of Real Property. The parties own no real property. 7. Child Support. a. The Husband shall pay to Wife temporary and permanent child support in the amount of Six Hundred and Thirty Five ($635) Dollars per month, which amount is consistent with the Child Support Guidelines ofthe State of Georgia (O.C.G.A. ~ 19-6-15). b. The parties hereby agree that so Ibng as the Husband shall remain employed in the United States Army, that the Husband shall be solely responsible for obtaining, providing and maintaining adequate health, medical, clental and hospitalization insurance for the benefit of the parties' minor children. The Wife agrees to utilize any available military hospital facilities or the insurance program "CHAMPUS' for any medical needs of the parties' minor children. The parties further agree that should the Husband leave the employment of the United States Army. either voluntarily or involuntarily, that the Husband shall be solely responsible for obtaining, prOviding and maintaining adequate health, medical, dental and hospitalization insurance for the benefit of the parties minor children. The Husband shall be solely responsible for all of the insurance premiums as the said premiums come due and for any health, medical,. dental and hospitalization costs not otherwise covered by said insurance policies. Such amounts shall include, but not be limited to, any deductibles, co- payments, and non-covered expenses which are reasonably incurred for or on behalf of the said minor children. The Wife agrees to assist with the prompt filing of any insurance claims with the insurance carrier. :~ 1>0 39\1d SCJ\I\IN3MnOHOS 8E9I8IS 0E:EI 0006/56/50 '1 "" ol~'-_~'I,c; 8. Support to Wife. Husband sh311 pay to Wife as Alimony fOf her support the sum ofTwo Hundred and Fifty ($250.00) DOLLARS each and every month for a period of Twelve (12) months commencing on the 1" day of February, 1997, and due and payable on the 1" day of each month thereafter until the 18' day of January, 1998; or until the Wife dies or remarries, whichever event first occurs. The payments are intended to qualify as income to Wife and deductible to Husband for tax purposes. 9. Attorney Fees. The parties acknowledge that the Wife has incurred substantial fees and expenses of litigation for Wife's representation in matters respecting this agreement. Therefore, the Husband agrees to be responsible for payment of all attorney fees and court costs incurred by the Wife in matters respecting this agreement and the parties' divorce action. 10. Enforcement of Support. Whenever in violation of the terms of this Agreement, or any Order in which this Agreement is incorporated. there shall have been a failure to make any support payment hereunder so that the amount unpaid is equal to or greater than the !ll1'lQ~nt p'ay~~le ~~r. one mo.nth, the payments required by this Agreement may be collected by the process of Continuing Garnishment for Support. In addition, any other legal process available may be used under the laws of any state in which either parent resides to collect said sums due and past due. 11. Child Custody and Visitation. a. The temporary and permanent legal custody of the aforesaid minor children of the parties shall be in joint. b. The Mother shall have primary temporary and permanent physical custody of the minor children. c. The Father as noncustodial parent shall have liberal and reasonable visitation of the children as mutually convenient to the parties. d. In the absence of other mutually convenient periods, the following visitation rights shall pertain: I. Routine weekend visitation by noncustodial parent shall be as follows: On the first and third Saturday weekends of each month, the noncustodial parent shall have the said children from 6:00 pm on Friday to 5:00 pm on Sunday on one weekend of each month, with at least ten (10) days notice to the custodial parent prior to said visitation. ii. Noncustodial parent shall have the children during the summer vacation from school, for visitation of up to thirty five (35) days. continuous or segmented to fit his schedule. Said visitations shall begin not sooner than seven days after the end of the regular school year and shall end not later than seven days before the beginning of the new school year. . iii. The Father shall have the children on the following special days and holidays: (a) Every Father's Day; (b) The Father's Birthday; @ One-half (%) day on each of the children's birthday; (d) Alternating major holidays. 3 S0 39\!d S~\!\!N3MnOH8S 8E9l:819 0E:El: 000G/6G/60 '1 ~ ,.1 ~ " ~ """",Jlt<ili""';J"I',, iv. Each party shall have t'oth children with them for one week at Christmas lime on an altemating basis. One parent shall have the children from 6:00 pm on the last school day prior to Christmas until Noon on Christmas Day, and the other parent shall have the children from Noon on Christmas Day until 6:00 pm on New Year's Day. v. The custodial parent shall prepare the children's necessary belongings to be used during the visit, provided proper notice is given of the parent's intent to exercise any visitation right herein. vi. It shall be the responsibility of the visiting parent to transport the children at that parent's sole expense to and from the children's primary home and the place for Visitation. vii. Additional visitation may occur as mutually agreed and convenient to the parties. Each party will strive to be punctual on all visitation, but a reasonable tolerance of tardiness due to unavoidable delay will be accorded each other, provided the courtesy of a phone calf has been made to provide the expected time of arrival. In the event of inconsistency herein, visitation during specified special days or holidays shall take precedence over routine yisitllti.<?1J F~ri9.d.'1. of every other weekend. viii. Each party promises to refrain from using visitation or support of the children as a means of punishment or coercion of the other parent. Each shalf not disparage or allow anyone else to disparage in any manner the other party, but shalf strive to enhance the respect and stature of each parent in the eyes of the children, Both parents acknowledge that visitation and support are independent rights and obligations. ix. Each party agrees that the parent should make every effort to personally pick up the children at the appointed time for the visitation. Should circumstances arise whereby the parent is unable to pick up the children in person, the parent will notify the other and provide the identity of the person designated to pick up the children. x. Each party agrees to have the children ready for pick up at the appointed time and to be ready to receive the children at the end of the visitation period. xi. The visiting parent shall keep the custodial parent advised of the children's location and phone number at which the children can be reached. with phone access to the children permitted, Each parent shall be permitted to phone the children until 8:00 p,m. on any day 12. Finel Settlement. This agreement constitutes a full and finel settlement and satisfaction of any and all rights, claims and demands which either party has against the other, In 'consideration of the faithful performance of the promises, agreements and covenants contained in this Agreement, each party hereby waives, releases, and relinquishes any other claim arising from the marital relation either may have as to property division, equitable division, pension and retirement benefits, alimony for support and maintenance from the other, including but not limited to dower and curtesy, and attorney fees, whether arising by common law or statute. Each party knowingly and willingly. consents to each and all of the above. terms and conditions. so that after this Agreement, neither shall 4 9B 39\1d SCl\l\lN3MnOH8S 8E91819 BE:El B006/56150 f ~ I., I. .1". ~. I ~ = - ,,- 'W\rlHioV.'J,- , ., require anything of the other, except as otherwise provided in this Agreement, as though the marriage relation between them had never existed. 13. Incorporation In Divorce Decree. In the event that an action for divorce is instituted at any time hereafter by either party against the other, the parties hereto agree that they shall be bound by all t~e terms o.f this Agreeme~t and that this Agreement shall not be merged In any decree or Judgment In any such acllon. However. both parties state they have no objection to this Agreement being incorporated in full or in substance in any judgment or decree in any such action for divorce. 14. Additionalln~truments. Each of the parties shall promptly execute and deliver such deeds, title documents, releases, assignments, identification cards and applications therefore, and all other written instruments as may be required from time to time to fully carry into effect the terms and conditions of this agreement according to its true intent and me6lning. Each party hereby designates the other as attorney-in-fact for execution of any documents necessary to carry into effect the provisions of this Agreement. 15. Waiver'of All Claims. Except as otherwise provided, the Husband and Wife release and forever discharge the other of any and all causes of action, claim of rights, or other demands whatsoever, in law or equity, which either of the parties hereto have ever had, now have, or may have in the future against each other, except a cause of action for divorce or to enforce this Agreement. The parties acknowledge that this Agreement is neither an agreement to divorce, nor consent thereto. 16. Entire Agreement. This Agreement is the entire agreement between the parties. Both the legal and practical effects of the Agreement in each and every respect, including the financial status of the parties, have been fully explained to both parties. Each party has either consulted with independent legal counselor declined the opportunity therefore. Both parties acknowledge that the Agreement is fair and is not the result of any fraud, duress or undue influence exercised by either party or any other person upon the other party. Both parties further agree that this Agreement contains the entire understanding of the parties, there being no pron'lises, warranties. representations, covenants or undertakings not written and expressly set forth herein. 17. Modification. The parties agree that no modification or waiver of any term or provision of this Agreement shall be made or enforceable unless reduced to writing and sign~d by bo~h parties. Cohabitation by the parties with each other subseque~t to the execution of thIS Agreement shall not invalidate this Agreement, unless the parlies expressly revoke thiS Agreement in a writing signed by both parties. o ..",." .... 18. Binding Agreement undBr Georgia Law. This Agreement shall in~re to the benefit of and be binding upon the parties, their heirs. personal representatives, executors. administrators, and assigns. This agreement shall be construed under the laws of the State of Georgia. 5 L0 3811d SC:lIIIIN3MnoH8S 8E91819 0E:E1 000~/6Z/60 I "" __L . -,- ........- - . __::u,,,,<-,,,", .. IN WITNESS WHEREOF, I have Jet my hand and seal to this agreement. J~ j)ti~ L.S. nice F. Depu ACKNOWLEDGMENT CHATHAM COUNTY, GEORGIA I, THE UNDERSIGNED NOTARY, do hereby certify that Janice F. Deputy, personally appeared before me this day and acknowledged the free and voluntary execution of the foregoing instrument. .,.(_ WITNESS MY HAND AND SEAL, thisK day of _~~ ' 19t? ,(:<~5i2f~';~~?~~ //"Notary Public ..,. ~"''''''.'''<< ~~ ~ A.. ~~'*, ~'?!O'TAi,Y.!f." , ....I+- ,~ .... \- i MloConllll. 1irlI. ! ~_Z!. 2000 . ....RIJIl,., \C.~'9/~ -. .,.,.....' .. itoti'CO\J .....11...... IN WITNESS WHEREOF, I have set my hand and sea. L.S. CHATHAM COUNTY, GEORGIA I THE UNDERSIGNED NOTARY, do hereby certify that John R. Deputy, personally appeared befqre me this day and acknowledged the free and voluntary execution of the foregoing instrument. y(._. WITNESS MY HAND AND SEAL, this~ day of :J~ ' 1921 ~,,"I""'1t ~~~A~ i,.":...:.... 'e,. .~. ~'.~' ' ~'::..O,.A.;...<'~ ~~ . ~ 11+ ~\~ //'Notary Public ~\~.c.;~Jr. .' .' . ~'~'l!~\~d..~ it41 COU"~ ~'''II'''' .. ...."-, -". 6 80 38\1d S~\I\lN3f11f10KlS 8S91819 0S:S1 000~lo~lo0 , ", -1.~~)mit*I1i~W:mi~~!1i~@l\'lfii~~~i~Th&$g..t~~"""'m,"M""j'~~_'t!~jj;Mlliii!iL!lI'fiIA;;.~~"-~- l~~~'t!'I!it--~n'~" ~, "'~I_'t " - - " ~- ~, -" ,. ~" -'~~ . ~'~ ~. ~ t ~ ~ ....... ~ tJ ~I ~ &- ~ \ \ \"\ \j \~ ~ '\ ~\ , (") c: S2C ..,..:, en,"-: ;:::;,--;, '-,.-> ',.. ~(i :6';~3 :~ _,.u,. _ '<...1' I:: i:, 1::1 [, n:1 "I i ~: ~ C) C) (, --,:':1 ,:J n ...... c: u-: .J '--."<rS -1 'I ~'~ -1"1 u~~ :::;:J -< ~p-" 5 '.....) Cr. ,.-" -""" ....011 ..........~;i;;",;"'!,,,' . JOHN ROBERT DEPUTY, * IN THE COURT OF COMMON PLEAS Plaintiff, * CUMBERLANDCOUNTY, PENNSYLVANIA * vs. * NO. C/O- 6 g-,;)3 twJ * JANICE F. DEPUTY, * CIVIL ACTION - LAW Defendant. * CUSTODY AND NOW, this ORDER OF COURT ,~ ""'- -rT._ day of ~ , in consideration of the within in Emergency Petition for Special Relief, it is hereby Ordered that a Custody 4~N~lI') Conciliation Conference shall be scheduled within fi.ll (:T) days of this Order and, if necessary, a custody evaluation shall be initiated with Dr. Stanley Schneider within five (5) days thereafter or as soon as Dr. Schneider's schedule will permit. A custody hearing ,s $~e.cI...l-c:d t:oL tI..a..h-a ,." ;>000 ~ ",'00/4..;11 ..: ,.....-c:........,.., 'IIr riP will ha 8eMe8~lgg IIp....~ gSI..I5"-.tioll vr 01. SSAReiejer's eval~jV'" lJul IIV laler tnan ,F 1M. c.......,...L...-d u.....7 e.eotut.OllSofj c..,U.r', '~I j 1,6 '3 ~"\lAl911r 1 "', :i(,8S, to consider Plaintiff's request for primary physical custody and leave to relocate both children to Saudi Arabia to reside with him. . J. .~ f\ . ~ L.~ ,q_OO \0 ~ - :'~ -~,=, .,j~--. o.o~"~ _.,__~ ',~~_~, ~~,"I 11~T 11 !1 - , ~ , ~ .~~- ,.., I""'''' -.",-" -. '~-~',,~.~" , "'M_" ,J'.J ';jjHY OJ nr:T - q 1'1 3: 02 ,"[ H,_,~,'::'i:':-i..;' ,', {'"_,'"I -, rr'Y \..J""J~::""''-,' lLr-\: ti.....i'vN PENNSYLV/;NIA . !., ---nT_ :'I'!"""~~"'~f(~}i;j~~j~W~~iflWy,~~,j~~j!f~i;'!!~~~V~~r"'~_":' :_~~ ;.1" - .......,J< ......""""iO.'" JOHN ROBERT DEPUTY, * IN THE COURT OF COMMON PLEAS Plaintiff, * CUMBERLANDCOUNTY, PENNSYLVANIA * vs. * NO. f1-o _ I..! 73 ew;J fLU.- * JANICE F. DEPUTY, * CIVIL ACTION - LAW Defendant. * CUSTODY EMERGENCY PETITION FOR SPECIAL RELIEF/PRIMARY CUSTODY/RELOCATION Plaintiff, by and through his attorney, Edward J. Weintraub, Esquire, files this Emergency Petition for Special Relief and avers as follows: 1. Plaintiff is John R. Deputy, Father, who currently resides at Box 2042 Jeddah, Saudi Arabia. 2. Defendant is Janice Deputy, Mother, who resides at 1821 Bridge Street, New Cumberland, Pennsylvania 17070. 3. The parties hereto are the parents of the following minor children, who currently reside at 1821 Bridge Street, New Cumberland, Pennsylvania 17070: Angela Deputy Date of Birth 3/21/87 Dana Deputy Date of Birth 5/9/91 4. On October 5, 2000, Father filed a Complaint in Custody seeking primary physical custody of both children, believing it is in their best interest to live primarily with him at his current residence in Saudi Arabia, with periodic supervised visits with Mother. 5. Father seeks an expedited Custody Conference and if necessary an expedited custody evaluation and court hearing. 1.......;1 ,o)~'. . 6. In May and September 2000, Angela Deputy, age 13, required in-patient psychiatric care as she was both suicidal and homicidal complaining that she cannot get along with her nor live with her Mother. 7. Defendant, Mother, has a history of drug and alcohol dependency and has abused both the children physically and emotionally. 8. Plaintiff, Father, has been encouraged by the child's treating physicians and counselors to seeks primary physical custody and believes and also avers that both children want to be in his primary physical custody. 9. Because of Angela's mental state, time is of the essence. 10. If Plaintiff, Father, lived locally he would seek immediate physical custody, but feels, on the advice of counsel, that this Honorable Court will want the benefit of a Conciliation Conference and evaluation before ruling on his request to relocate the children to Saudi Arabia. WHEREFORE, Plaintiff, Father, seeks an expedited Custody Conciliation Conference and if necessary, custody evaluation and hearing on the merits in this matter. Respectfully Submitted, By, ~1d-- Edward J. eintraub, Esquire 2650 North Third Street Harrisburg, PA 17110 (717) 238-2200 Attorney ID. #17441 Dated: ou ATTORNEY FOR PLAINTIFF :.I"'-~~ J - "- I --...~~ ~l ,~~'" ,_ -.. ~..~ 10/03/200~ 23:59 5181538 'le/e3/2~e0 15;07 71J-23e-S2BB SCHOUWENAARS ST~RN OF 't.EINI ~'j; PAGE 02 l""/-.ttJt. ~~ . ' VERIFICATION BY FACSIMILE I, John Deputy, hereby swear and affirm thet the facts contained in the foregoing Emergency Petition for Special Relief are true and correet and are made subject 10 the penalties of 18 Pa, C,S, Sec. 4904 relating to unsworn falsification to authorities. Date: 3 tJe- T ~;? ORIGINAL VERIFICATION I, Edwerd J, Weintraub. Esquire, verify that the contents of the foregoing Emergency Petition for Special Relief-Relocation are true and correet to the best of my knowledge, information and belief. 'am authorized to respond based upon information provided by John Deputy and in my capacity as his counsel. I understand that I am subject to the penalties of 18 PI. C.S, See. 4904 relating to unSworn falsification to authorities for any falsa statements that I made In ::~~:~:~' ~ / Edwar<l J. Weintraub, Esquire r" ,. - '~~~~J~,~!~':ll!~~i-i:lllii~lMi$~'--'dill;'1-:1f",';"J4-)"""'-:t;;$';W;~i~~i!lIi-1ift:dr~".1;.4~~_gl!!~~id~iIIliilllJi.iiiil1.~~~ii . (") "tiE n<i(~ IK J:.. ~r', :k C')' f; ~ ,'.-"'-", ,~,_ K ,_ -"~ , .<" --~ "" .:0 r" - c. c.:~) .::::, ....-.1 --; f...;j ~-~ " --.'~ , '_; ~L: ___'>-C) ft'" -<:; ;; . -,.~ .....w'l I 11 H i,1 ! '. ') -:-::) ~ .',,1- ,--, .1 ;,,:1- -,--,;-, . ~". JANICE DEPUTY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. JOHN R. DEPUTY, Defendant 00-6823 CIVIL TERM ~ 99-7133 CIVIL TERM ORDER OF COURT AND NOW, this 17th day of November, 2000, the parties are directed to comply with the partial custody arrangement articulated in court this date. By the Court, BRUCE BRATTON, ESQUIRE For the Plaintiff It JI-.?J-OO R~ EDWARD J. WEINTRAUB, ESQUIRE For the Defendant -'" J i! I:! II I I~ IS' ",~ """ ~R ~ c' " , ,,, ~~. ' ,~ , .,"" ,. -~, .-:.' ,-iC'TI~SiY (,.', 1."'\1 1 !') "'j; : '~.., .." '. ~)) '"-". F;-':; 2: ~! C., 'cl', .'.'..I\llY vh'iUe-, GVvl'lll PENNSYLVflNl/'., ,- .,.,~ ~.'~~ -- .1"--", .,[ "" ~~'i~!l.!l.~!1!IEl~ {.),~..~ -. . ,~~ ~.,.'~~:t.J1~~~~im'~\1H11lfJl!\'t'$'#~!I~iW"l~~liOj~'~ ='-7~:! .-1 :,.""",,1 .1,,' -> .~'''- , 'F'i! JANICE DEPUTY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. JOHN R. DEPUTY, Defendant 00-6823 CIVIL TERM~ 99-7133 CIVIL TERM ORDER OF COURT AND NOW, this 17th day of November, 2000, it appearing today a conciliation would be futile, a custody hearing in this matter will be scheduled for November 29, 2000, at 1:00 p.m. The parties are both directed to cooperate with Dr. Schneider so that a custody evaluation can be completed. If he is not prepared to testify on the 29th, we will reschedule the hearing for the purpose of taking his testimony at a later time. We can certainly hear from the parties on the 29th. By the Court, Edward E. Guido, J. It t~ -1Y\aSJ I h;2~-OO ~~5 BRUCE BRATTON, ESQUIRE For the Plaintiff EDWARD J. WEINTRAUB, ESQUIRE For the Defendant 0: m '='~_"'C ,,,-" "~",,-,,l , f'-l_~_" .', p:p<:,g H_,_, ,'n ,."~.' '-\.,J ~'~,\1 r.,l ') \~':\ )'~' f..'~ :. ;~ r ~': L' .. . .'"' 1.,-rV - - ',,,', ( I :l\\;\ \ (.....1 \~ '\._',:___\_ ~ ; '., '\l'~) .,..i --..' . '-'VIV\F:E.N~\S\{L\jt\N1J\ ,C'_~~....~ijl~Il!!;~~~>fflg,~*~*-,~'llJ .,. ~= '^~""'~'. '""- JI,~q~L,,_ "I'"". ... ,,,~-, -- .~ ' ~, JANICE DEPUTY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. JOHN R. DEPUTY, Defendant 00-6823 CIVIL TERM ~ 99-7133 CIVIL TERM ORDER OF COURT AND NOW, this 17th day of November, 2000, father's petition for special relief is denied. By the Court, EDWARD J. WEINTRAUB, ESQUIRE For the Defendant Edward E. Guido, J. f\ - 1\;)) L~ ~.oO W~ BRUCE BRATTON, ESQUIRE For the Plaintiff - ~, ';~ \~-~ ,.,..___rtl'J ...~J ^~ ",' ~:J' 'Ii-,;' ') Z \j, \':'_1 L"_ ,~,. ^ .-~'"' ~"-- '''.~'n~, ",,,,.. ,,",' . I~' iTi\?8 r' ; ~ r;~ 0.. n t.~. ."1 '.'UI'fCy ,_ ,.. "'1 '<" --~, 1 ", 'i I ['1.11'1'1''''-.'',..;\,,11.,) ^-,r...) v.v,." ,'" .- 'DC'I, 'h,IC;V,' \!l\,'<lI'\ \ C,l\ll\iu L-.. ' ,~- ~"~_ _ ~"~'~"Wi!jfj~i1'j\j*~JI11>f1tf"!):'''-~~H~_,"~:~t~~?lW~~ __ ,_~ ~~ 1~""""",,, . . . ~, , {oi~,= ,~~~, 4-@ JANICE DEPUTY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. JOHN R. DEPUTY, Defendant 00-6823 CIVIL 99-7133 CIVIL TERM / TERM IN RE: TRANSCRIPT OF PROCEEDINGS Proceedings were held before the HONORABLE EDWARD E. GUIDO, J., Cumberland County Courhtouse, Carlisle, Pennsylvania, Courtroom Number Five, November 17, 2000. APPEARANCES: BRUCE BRATTON, ESQUIRE For the Plaintiff EDWARD J. WEINTRAUB, ESQUIRE For the Defendant - , J .-1 ,< .~ ""...., ~IG;'" 1 November 17, 2000 2 Carlisle, Pennsylvania 3 4 (Whereupon, the following proceedings were held 5 at 11:28 a.m.) 6 MR. WEINTRAUB: Good morning, Your Honor. 7 THE COURT: Good morning. I have before me a 8 petition for special relief seeking a change in custody 9 alleging that the children are in danger. Is that correct, 10 Mr. Weintraub? 11 MR. WEINTRAUB: Yes, Your Honor. 12 THE COURT: And are you ready to proceed on that 13 petition? 14 MR. WEINTRAUB: We are. 15 THE COURT: Call your first witness. 16 MR. WEINTRAUB: One housekeeping detail. Your 17 Honor, when I filed the petition for special relief under 18 number 00-6823, I was unaware of a prior order of this Court 19 under number 99-7133. 20 I had checked with the Prothonotary, I wanted to 21 resolve the caption. I have given both to the reporter. I 22 believe from a housekeeping standpoint I should amend our 23 emergency petition and re-file under the prior caption. 24 THE COURT: Any problems consolidating these two 25 numbers, Mr. Bratton? 2 -. Id Jl I' ,-l I""";' ,.-, ,'-- krll -,:.; . ~~, I MR. BRATTON: No, Your Honor" I think that would 2 be appropriate. 3 THE COURT: And I see your client is not here. 4 You don't know her whereabouts other than somebody saying she 5 is in transit. 6 MR. BRATTON: Yes, Your Honor. I checked with my 7 office when she wasn't here at the stroke of 11. She had, as 8 we discussed during our conference call about our request for 9 a continuance and a clarification to what we were going to do 10 today, she arranged and appeared at Dr. Stanley Schneider's. 11 When she got somehow detained she has called my office, 12 apparently. I didn't have a chance to talk in detail. 13 She is -- 14 THE COURT: I am not going to hold Doctor -- 15 MR. WEINTRAUB: We have agreed, Your Honor, that 16 we can put Dr. Schneider on 17 THE COURT: And take Dr. Schneider if she is not 18 here. I will continue this until 1:30. Let's take 19 Dr. Schneider and go from there. 20 MR. WEINTRAUB: Dr. Schneider -- Mr. Bratton asked 21 me to clarify, it may well be after we hear Dr. Schneider's 22 testimony, there will be no further testimony offered in the 23 matter. 24 THE COURT: Okay. 25 MR. WEINTRAUB: We are aware that the children met 3 " --I I"" , - ,- ~.,~ 1 2 3 with Dr. Schneider, none of the parties are aware of his findings. THE COURT: He is not able to talk? You couldn't 4 talk with him? We started a half hour late. 5 6 trying to MR. WEINTRAUB: I think it was more a matter of as far as communication, we didn't arrive at the 7 same time. 8 THE COURT: Good enough. Swear the good doctor in. 9 10 (Whereupon, the witness was sworn.) 11 THE COURT: Okay. Dr. Schneider, I am well aware 12 of your background, your credentials. Are these children in 13 danger right now? 14 MR. WEINTRAUB: Your Honor, we have stipulated to 15 Dr. Schneider's qualifications. 16 THE COURT: I just did that. Okay. Are these l7 children in danger, Dr. Schneider? 18 THE WITNESS: No. 19 THE COURT: Okay. Mr. Weintraub, any other 20 questions? 21 MR. WEINTRAUB: (NO RESPONSE) 22 THE COURT: Now, I have set aside November 29th at 23 1:00. I have allowed you one half day, and I will at that 24 point look at the full custody issue. The limited purpose of 25 this hearing was based upon your client's allegations that: 4 ,,~ J ,I --" ,- '~ 1 these children were in danger living with their mother, where 2 they've been for quite sometime. 3 You may question Dr. Schneider with regard to his 4 opinion that they are not, and we will go from there. 5 MR. WEINTRAUB: Thank you, Your Honor. 6 Whereupon, 7 STANLEY SCHNEIDER, 8 having been duly sworn, testified as follows: 9 DIRECT EXAMINATION 10 BY MR. WEINTRAUB: 11 Q In arriving at your conclusion that they are not 12 presently in danger, was there any time in the recent past 13 where you thought they may have been in danger? 14 15 16 17 18 19 20 21 22 23 24 25 A I am not aware of any. Q Have you consulted with the treating psychologist, school counselor and the other professionals involved? A In consulting with the school counselor, and I am in the process of getting information from professionals, particularly with Angela. The parents signed consent forms, which have been mailed out, and it is my understanding that the records from Holy Spirit Hospital are in route to my office, but I have not received them. In an effort to answer the question presented in the emergency petition, I met with mother, Angela and Dana 5 ~ I I --.', ~ wi 1 this morning. I did my own assessment regarding whether I 2 believe that Angela, in particular, was at risk. 3 Q Okay. Having concluded that Angela, particularly, 4 is not at risk, and having heard his honor say that there will 5 be a hearing on November 29th, do you have an opinion as to 6 the extent to which father should have unsupervised partial 7 physical custody of the children between now and this hearing? 8 MR. BRATTON: Objection to relevancy. 9 THE COURT: Sustained. I don't need an expert: to 10 tell me that. 11 MR. WEINTRAUB: Well-- 12 THE COURT: I will look at the issue of partial 13 physical custody at 1:30. 14 Is there a reason for father not to visit with the 15 children, Dr. Schneider? Maybe I should allow you to answer 16 that. 17 THE WITNESS: There is no reason the father cannot 18 visit with the children. I have a couple caveats that you 19 should be aware of. 20 THE COURT: Okay. I will hear them. Go ahead. 21 THE WITNESS: Both children wish to spend time 22 with their father on weekends while he is in the United 23 States. This was confirmed by mother as well as each child 24 independent of one another. 25 The only concerns mother has, and this relateB 6 I", ~l!liii\lIIlllilitii'-!h; 1 particularly to Angela, is that he would -- she would like him 2 not to say anything detrimental or negative or critical about 3 the mother to the children. 4 She had some concerns, secondly, about the 5 possibility of his kid-snatching and taking the kids back to 6 Saudi Arabia. However, we talked about the notion they need 7 passports. She does not believe they have them. If they do, 8 she does not believe that the father has access to those. 9 She does not want the parents and step mom or the 10 paternal grandparents to talk to the kids about any 11 custody-related issues. No influencing, no suggestibility, 12 nothing along those lines. 13 Next, she would like to make sure that the father 14 ensures medication compliance with Angela. She is on some 15 pretty heavy-duty medications that she needs to take. And 16 finally, she would like assurance that if Angela acts up or 17 acts out in any way that he would contact the counselor that 18 is currently seeing Angela in mother's home. 19 That information can be obtained from mother. The 20 counselor's name is Terri, T-E-R-R-I, Kennedy. And if Terri 21 is not available, she would like assurance that dad would make 22 sure that a crisis center -- she mentioned Holy Spirit. I may 23 exercise partial custody so it is not logistically feasible 24 for him to drive back to Camp Hill, to Holy Spirit Hospital, 25 but some crisis center. Those were the concerns that mother I 7 _ d . '" J' - ,- l~ .1. ~. -~ 1 shared with me in my session this morning. 2 MR. WEINTRAUB: May I consult with my client? 3 THE COURT: Regarding what? 4 MR. WEINTRAUB: Having knowledge 5 THE COURT: I don't need him to do that. You can 6 discuss that with the mother. I am going to look at this 7 again at 1:30, unless you don't have -- unless you have an 8 agreement. 9 It would seem to me that these are things that can 10 be worked out between mom and dad. That was not the purpose 11 of this hearing at 1:00. I am agreeing to give you until 1:30 12 to work out custody arrangements. If you don't agree to it, I 13 will make a decision. 14 MR. WEINTRAUB: If we have a stipulation as to 15 this we can so advise your chambers, and we don't need to 16 reappear at 1:30. 17 THE COURT: That's correct. 18 MR. WEINTRAUB: Thank you, Your Honor. 19 THE COURT: Anything else from the doctor? 20 MR. WEINTRAUB: No, Your Honor. 21 THE COURT: Anything else? 22 MR. WEINTRAUB: Yeah, I did have one other 23 question for Dr. Schneider, but I think we can work that out 24 after. I am just concerned about the evaluation schedule, and 25 how that's going to relate to the hearing schedule just 8 - I' , ,,1-- I :~ - -",.";,,,,,,,,,,. .'> <~~ 1 announced from the Court. 2 THE COURT: And from my sta~dpoint I have the same 3 concerns since father lives in Saudi Arabia. The same 4 concerns that mother might have. I want to make sure that 5 this Court retains jurisdiction. 6 So as part of any interim visitation, I would ask 7 that he deliver his passport to court, he and his wife's 8 passport to court, and return them after the 29th hearing ,. 9 MR. WEINTRAUB: No concern about that, Your Honor. 10 It's never been a threat of snatch in this case. 11 THE COURT: I understand. It's better safe than 12 sorry. It appears that mom and dad should be able to work 13 this out without the Court's input on that. Is that mom 14 there? 15 (Whereupon, Janice Deputy entered the courtroom.) 16 MR. BRATTON: That's mom. 17 THE COURT: Take a 15-minute recess and work on 18 interim visitation in the meantime, and if you can work it out 19 in the next 15 minutes, I will enter an interim order. 20 21 MR. BRATTON: Got it. THE COURT: In the meantime, let me enter this 22 following order: AND NOW, today's date, father's petition for 23 special relief is denied. 24 Enter another order: AND NOW, today's date, it 25 appearing today a conciliation would be futile, a custody 9 - " J ,I -'1<; 1 hearing in this matter will be scheduled for November 29, 2 2000, at 1:00 p.m. The parties are both directed to cooperate 3 with Dr. Schneider. 4 Will you be testifying as a Court expert there or 5 are you retained by one of the parties? 6 THE WITNESS: I believe I have been retained by 7 both counsel. 8 MR. WEINTRAUB: The parties have mutually agr,eed 9 and father has paid. 10 THE WITNESS: My custody evaluation won't be done 11 by the 29th, Your Honor. 12 THE COURT: Okay. We will have the hearing on the 13 29th -- strike that. Add to that order: Both parties shall 14 cooperate with Dr. Schneider so that a custody evaluation can 15 be completed. 16 If he is not prepared to testify on the 29th, we 17 will reschedule the hearing for the purpose of taking his 18 testimony at a later time. We can certainly hear from the 19 parties on the 29th. 20 Okay. That way father won't have to come back 21 from Saudi Arabia for Dr. Schneider's testimony. Okay? Good 22 enough. 23 (A discussion was held off the record.) 24 (Whereupon, a recess was taken at 11:55 a.m.) 25 MR. WEINTRAUB: The parties have reached an 10 1-~ " J ."- ~ I ~ , .-i.0...J-- "'Ili!ii 1 agreement for father's partial physical custody of both 2 children while he is here in the United States. Every 3 weekend, generally, from Friday at 7:00 p.m. until Sunday at 4 5: 00 p. m. and Thanksgiving weekend commencing on Thursday.. 5 Thanksgiving Day at 5:30 and continuing until Sunday at 6 5:00 p.m. with -- to be in father's partial physical custody 7 within the Commonwealth of Pennsylvania, generally at the home 8 of the paternal grandparents' in Lehigh County in Allentown, 9 with all exchanges to occur at the Midway Diner on Route 78 10 half-way between Harrisburg and Allentown. 11 Father to have partial physical custody durin<:j the 12 week, every Wednesday, commencing on the Wednesday following 13 Thanksgiving from 4:30 in the afternoon until 7:30 in the 14 evening, curb-side pick up outside mother's residence with 15 father to have both children and to transport Dana to her 16 scheduled gymnastic activity during his period of partial 17 physical custody. 18 The other stipulations previously indicated by the 19 Court will apply, and mother mutually agrees that she will 20 also not prepare the children in anyway for testimony or 21 criticize father and his wife in any way. 22 THE COURT: Actually, the other stipulations 23 articulated by Dr. Schneider will apply; is that correct? 24 MR. WEINTRAUB: That is correct. 25 THE COURT: And add into that with regard to the 11 - ~.I ~< ~ ~ ,-, ~'-~ "..-- ~'" _, _ 0 1 mother knowing all of that. Do you agree with those, ma'am? 2 MRS. DEPUTY: Yes, I do. 3 THE COURT: And sir? 4 MR. DEPUTY: Yes. 5 THE COURT: Go ahead. 6 MR. BRATTON: With one or two fine points, Your 7 Honor, that Your Honor had come up with the concept that 8 passports would be deposited with the Court before the 9 visitation begins. 10 THE COURT: Correct. And we will put the court 11 reporter in charge of the passports, and they will be returned 12 at the time of the hearing on the 29th. 13 MR. BRATTON: And my understanding is that this 14 order is only to be effective until the planned return to 15 Saudi Arabia on December 4th? Is that what I heard? 16 MR. WEINTRAUB: I am saying until his return which 17 now, because of the evaluation and court schedule could extend 18 into mid-December. 19 THE COURT: If it goes past December, we will look 20 at it again. 21 22 23 24 25 MR. BRATTON: Fair enough. THE COURT: Is that agreeable, sir? MR. DEPUTY: Yes, sir. THE COURT: Ma'am, is that agreeable? MRS. DEPUTY: Yes, sir. 12 I I" " -.-1 ", i~ 1 THE COURT: And enter the following order: 2 AND NOW, today's date, the parties are directed to comply with 3 the partial custody arrangement articulated in court this 4 date. 5 That's the order I will sign. If they want you to 6 prepare a transcript of Dr. Schneider's testimony and what has 7 been dictated, you could do that, but I think they understand 8 what is going on. 9 10 MR. BRATTON: Yes, sir. MR. WEINTRAUB: We would like the transcript as 11 well as the order, and 12 13 THE COURT: Okay. MR. WEINTRAUB: and look forward to receiving 14 it from Your Honor. 15 THE COURT: YOl.j can certainly get the order before 16 . the transcript. It's a Court order so you are directed to 17 comply with that. You can leave you and your wife's passport 18 with Lorraine until the November 29th hearing. 19 MR. BRATTON: Thank you, Your Honor. 20 THE COURT: Good luck. 21 (Whereupon, court adjourned at 11:29 a.m.) 22 23 24 25 13 -I" - 1 2 3 4 5 J -~ I -- -'. "e'" ',~ .'.' _ . , , "'-J~ - ~- CERTIFICATE 6 I hereby certify that the proceedings are contained 7 fully and accurately in the notes taken by me on the above 8 cause and that this is a correct transcript of the same. 10 11 12 13 14 15 9 RPR 16 The foregoing record of the proceedings on the hearing 17 of the within matter is hereby approved and directed to be 18 filed. 19 20 21 22 23 24 25 If !J.;{fJU Date Edward E. Guido, J. Ninth Judicial District 14 l II II I" 1:1 1'1 1[' I' III iil I:'j II 1I,'j" I' I:, " 1,:1'" i', Ij iJ ii' ! ~ , I' ,:\ di I::~ :,!I 1,1, ill ill H 1;1:C.., ','" 1 ~ '" ~I~ 'M"1Jl_~_ ,~,'" .~. JJIII" ~YJ H\':\i 2. ~~ r'-,. "t'; t_,' ,,1- _,,',' \',\T,j -, r \ i:,,\j\\ ,",' JA ',":~~ .:.,'\ (/\u U';, ;.." 1--.11 \VI,--:""'>' ',~\r.\'\\It\N'"O-\ ~ PE\\\\\~v i ~,!,~ " .. ' ll~;Jij1~fftll~'ffi\1ffil~-fl:~~f,#~~~<$f~~' - "] J ,]. " ,', '""'~ '--' IiWo , N~V 1 6 2000 tJ1 JOHN R. DEPUTY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA /Va. ()o- ~gi J C(d(G.. CIVIL ACTION - LAW v. JANICEF. DEPUTY, CUSTODY Defendant ORDER AND NOW, this day of November, 2000, in consideration within motion for continuance, it is hereby ORDERED AND DECREED as follows: I. The custody hearing scheduled for November 17, 2000 is hereby continued; 2. The parties shall attend a conciliation conference to be scheduled through the offices of Melissa Greevy, Esquire, within ten (10) days of the date of this Order; 3. The custody evaluation being performed by Stanley Schneider D. Ed., shall proceed and the parties are instructed to cooperate in the prompt conclusion of such custody evaluation; and 4. A custody hearing shall be held on , 2000, at in Court Room of the Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, J. ~"-~ . - ~ . =-- ~~ ;~~'" , . . JOHN R. DEPUTY, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00-6823 Civil CIVIL ACTION - LAW JANICE F. DEPUTY, Defendant CUSTODY DEFENDANT'S MOTION FOR CONTINUANCE Defendant, Janice Deputy, natural mother of the minor children who are the subject of this custody action, respectfully requests that this Honorable Court continue/postpone the hearing scheduled for November 17, 2000, at II :00 and in support of such Motion represents as follows: 1. Plaintiff John Robert Deputy commenced this action by filing a Complaint in Custody and an Emergency Petition for Special Relief/Primary CustodylRelocation", on or about October 8, 2000, despite the pendency in this Court of a prior action docketed to No. 99-7133. 2. At the Plaintiff s express request, this Honorable Court entered an Order dated October 9, 2000, requiring a custody conciliation conference to be held within 10 days, requiring that a custody evaluation be undertaken by Stanley Schneider, D. Ed., within five days thereafter or as soon as Dr. Schneider's schedule would permit, and scheduling a custody hearing on November 17, 2000. 3. In discussions between Plaintiffs counsel and Defendant's counsel, Plaintiff and Defendant agreed to the conducting of a custody evaluation by Dr. Schneider and, due to the Plaintiffs absence in Saudi Arabia, to forego a custody conciliation for conference where the Plaintiff could not participate and Defendant would not agree to the relocation of her children to ~. ~~ ~ ,-~ I - -~~- ~"lilI~""gc" . Saudi Arabia. 4. Plaintiffs counsel has just advised Defendant's counsel that the Plaintiff would not even be available to participate in the evaluation to be conducted by Dr. Schneider since the Plaintiff did not intend to arrive in the United States until November 16,2000, thus making the completion of Dr. Schneider's evaluation impossible in time for the hearing on November 17. 5. Plaintiff s counsel has also advised Defendant's counsel that the Plaintiff would be available in Pennsylvania for three or four weeks. 6. Defendant has executed authorizations for the release of information by her daughter's physicians and therapists who cared for her during her involuntary committment at Holy Spirit Hospital from September 8 to September 18, 2000, and during an earlier hospitalization in April of this year and agreed to cooperate with Dr. Schneider's evaluation. Dr. Schneider has not contacted Defendant nor Plaintiff, to Defendant's knowledge, nor interviewed the children, nor advised Defendant or Defendant's counsel that he has determined the existence of any "emergency" warranting deviation from otherwise applicable procedures regarding custody matters in Cumberland County. 7. Defendant's counsel has been advised that the Plaintiff will be available in and around the Central Pennsylvania area for three or four weeks, apparently during a holiday vacation, and, thus, a conciliation conference can be rescheduled, the evaluation by Dr. Schneider completed and the matter rescheduled for a hearing after the evaluation is completed, if necessary, and in the coming weeks. 8. Defendant's counsel submits that, absent a custody evaluation report from Dr. Schneider finding an "emergency" which would require an immediate waiver of normal ;" ~n I.~ _.' ~~ ~,- , procedures and the Court's immediate involvement, the hearing scheduled for November 17,2000 at 11 :00 AM will be of no little value as the evaluation process is not completed and a further hearing will be required in the future when such evaluation is complete. Additionally, without the aid of the custody evaluation report, the hearing will be unnecessarily protracted since all treating physicians will be required to attend to testify as to the girl's prior history of sexual abuse and current bi -polar disorder and other family members may also be required to testify as to the girl's treatment, etc., before the issue of whether removal of a young and troubled girl to Saudi Arabia is in such a girl's best interest is even addressed. WHEREFORE, Defendant respectfully requests that, in order to save counsel fees, time off work and other schedule disruption, and in the interest of the Court's economy that the hearing scheduled for November 17, 2000 at 11 :00 AM be postponed, that the parties be required to attend a rescheduled conciliation conference and that a new hearing be scheduled before the Court at the Court's convenience and, if possible, within the next three or four weeks while the Plaintiff is still available in the United States visiting with his parents. It tJaU - {JU Date By Bruce F. ratton, Esquire Pa. Attorney I.D. No. 23949 2515 North Front Street P.O. Box 12106 Harrisburg, P A 171 08-2106 (717) 236-4241 Attorneys for Defendant ~ J '~~'l?,V , . CERTIFICATE OF SERVICE I hereby certify that I today served the foregoing Defendant's Motion for Continuance by sending the same via fax to: Edward J. Weintraub, Esquire Fax: (717) 238-9280 and by sending the same by First Class Mail, postage pre-paid addressed as follows: Edward 1. Weintraub, Esquire EDWARD 1. WEINTRAUB & ASSOCIATES 2650 N. Third Street Harrisburg, P A 1711 0 Date I~ fJov (J1J _____.0 _ /#f Bruce F. Bratton, Esquire Attorney for Defendant f;~-'~"i~I.~~" :l!~- ~--'-',.-"~;~ "'~>"UIl!liIUii~ftd.i_!tji:J~.~JII"1I'ili'.f.!a;li>>ij!iO<:~i'~:ru:lLI-1i1IJ,liI'".t.~, < ~~~~~~ - lkOAJJ '''Cj,;'UlM ~ ,,' ..J." , ~. , 'Ii Ii [,I ~I I f , II "I , II 'I I , 0 C,'::) ~) c: a n S ~ vG.,i ''''-- 'c:> fllrL , :z: ::r:-, Z ~,. (f) ~:_~-.: en -< L ,", r::: C) ". "-' ~ :tc~ , , z (J ::.2~ 5> C) co r- C...F ~.- s;! z ::> :< ".:.n CJ -< o f'!-~: ~~~!:~~'i~~\~:r;_;~'~~:;~,r~~,'f"~fs~~,"r~",e~;! "':"','t"t\f:%'::!~';}'';';;:'f ~ N >,:j;3;tp t>> Ln. >- l-i "'i I-'O~t:: "'i U1. I-j n 1-1. UJ (1) (Jl Z tpO c"00t"'''<j t::: "'i ~~. '1 rt OQi:l" >-'Rotp N '1 "<j >-' tplll >,:j'i O,,"rt > 0 ",p.,rt ~ 1"'10 rt ...,~ O. Z toO (Jl .c '" ..... 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'.;".'~;::7",;,;T<':f~";:;;,j'J,g~;'~2!J<j2it;'~;i,~67.tF,~t~~~)?0'ii1,'t;x;:;;':!ITfit'! ;;.!~ ~~~= ~'"~ - ~~. .L'H f~ii<~" "~_;'-r.A:~' 11/14/2000 11:47 71 72389280 STERN OR WEINTRAUB PAGE <12 .: lAW OFFICES OF EDWARD J. WEINTRAUB &ASSOCIATES PRA("TICE LIMITED TO FAMILY LAW 2650 N_ THIRD STREET HARRISBURG. PENNSYLVANIA 17110 (717) 238.2200 FAX - (717) 238-9280 [-MAIL- EWDIVORCE@AOL.COM . Edward J. W~jntraub Tonia M. Torquato Le~~l Assistant.$ Misty D. Lehman Wendy L. Shiv~ MEMORANDUM RE: Deputy No.: 00-6823 Via Facsimile TO: Honorable Edward Guido FROM: DATE: November 14, 2000 I represent John Deputy. A hearing is scheduled before your Honor on November 17, 2000 at 11 :00 a.m. I called your chambers last week and again by this memo request a telephone conference with Your Honor and Bruce Bratton, Esquire, who represents Mrs. Deputy. There are several issues I wish to clarify before our November 17, 2000 hearing: 1 . My client arid his wife are flying In from Saudi Arabia for the hearing. 2. Dr. Stanley Schneider is undertaking an initial investigation concerning whether the children are at risk and he will be available to testify on November 17. 2000 in person or by telephone. 3. We want to make sure that Defendant, Mother brings both children to the hearing to be interviewed by Your Honor, 4. We want to establish a revised interim custody schedule, permitting Plaintiff. Father to have extensive unsupervised partial custody with both children during his time in the United States, from roughly November 16. 2000 to December 16. 2000. ~ w = ="~~~~"_..... ~-," 1_''_ , ' "" ~,fuir" 11/14/2000 11:47 71 72389280 STERN OR WEINTRAUB 'Z' "~ .HoT!'~ble Edward Guido ....Page 2 November 14, 2000 5. We want to discuss how to best use the Court's limited time on Friday, November 17, 2000 at 11 :00 a.m. By copy of this memo, I am advising Bruce Bratton, Esquire of my above agenda for the proposed conference call. He will no doubt have some points of his own. My telephone number is: 238.2200 Bruce Bratton's telephone number is: 236-4241 Thank you for your consideration of this request. EJW/mdl ~J,~ ~ J < ~, ~L i.., L - 'U-e, 11/14/7Q00 11:47 71 72389280 STERN OR WEINTRAUB PAGE Ell 'I: LAW OFFICES OF EDWARD J. WEINTRAUB &.ASSOCIATES PRACI'ICE LlMITllDTO FAMILY lAW 2650 N. THIRD stREET HARllISBUkC. PENNSYLVANIA 17110 (117) 238.2200 FAJ(- (717) 238-9280 E.MA!L.EWDNORCE@AOLCOM EdW;1.l'd 1. Weintraub Tonia M. Torquato Le.l':al AssistantS Misty, D. Lehman Wenay Shive FAX COVER SHEET Date: From: Edward J. Weintraub, Esquire To: 6u.ldo Fax Number: dL\D ~ 1d-llt1d.- Remarks;~~ f: ~~ There are 3 pages being sent including cover. NOTE: IF YOU DID NOT RECEIVE ALL OF THE PAGES, OR IF YOU HAVE ANY PROBLEM WITH THE CLARITY OF THIS FAX, PLEASE CALL US AT THE NUMBER LISTED ABOVE. " 1,'- .'l.c "'~ ,. ~ .lJ.....'!rlc'; JOHN ROBERT DEPUTY, Plaintiff JANICE F. DEPUTY, Defendant CIVIL ACTION - LAW CUSTODY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA (") C) 0 ~ 0 -n :;-;... ;,..!: ,....! -0 CG c.::) m["n -..... ;7J ~~~ I :qts ~ ;r< -.J ~CJ .~tJ ;';:zO C :J>c! 7' ~ ~ ~t~j tSiy'~ .-.'-1 ?t; -< vs. NO. 00-6823 Civil ANSWER TO COMPLAINT FOR CUSTODY AND NOW, Defendant, Janice F. Deputy, by and through her attorney, Bruce F. Bratton, Esquire, files an Answer to Complaint For Custody and in support thereof, avers as follows, making reference to the paragraph numbers contained in such Complaint: 1. It is admitted that John R. Deputy is the father of the minor children involved in this custody proceeding. It is admitted that his address is a box number in Saudi Arabia. It is denied, however, that the Plaintiff resides in or at such box number. Defendant notes, however, that the "Emergency petition" filed simultaneously in this matter contains a different box number and address than is contained in the Complaint for Custody. 2. Admitted. 3. No response required, although, Defendant admits that the names, addresses and ages of the children is correctly stated. -1- " ,_,I ..1.--" .~ -.I'f 4. Admitted. 5. Admitted. 6. Admitted, except that the children resided with Mother as well as with Ron and Pat Klinger at Willow Mill Road, Mechanicsburg, PA. 7. Admitted. 8. Admitted in part and denied in part. It is admitted that the father of the children is John Robert Deputy. As to the allegations of his current residence, the answer to paragraph 1 hereof is incorporated herein by reference. 9. Admitted. The parties were divorced in Georgia on or about March 7, 1997. 10. Admitted. 11. It is admitted that the Defendant is the natural mother of tiCle children who are the subject of this Complaint. She resides, as the Plaintiff well knows, at her current address with the children only. 12. Denied. As the Plaintiff well knows, on December 1, 1999, this Honorable Court had entered an Order in an action brought, in this same Court, by the mother, based upon the agreement of the parties, which prior action is docketed to No. 99-7133 Civil in the Court of Common Pleas of Cumberland County, Pennsylvania. -2- ,'. ~ L . -"I~ ,_......-'~"~ ~~',..,'I!!lti,< 13. Denied. Defendant does have information of a custody proceeding in this Commonwealth, to which, the action docketed to No.99- 7133 Civil in the Court of Common Pleas of Cumberland County, Pennsylvania. 14. Defendant does not know what the Plaintiff may know but admits the Defendant does not know of any person not a party to the proceedin9's in 1999 nor the instant action prosecuted by the Plaintiff who has custody of the children or claims to have custody or visitation rights with respect thereto. 15. Admitted in part and denied in part. It is admitted, as alleged, that the mother, referred to erroneously as the Plaintiff, has been the children's primary caretaker for several years without financial or other assistance from the Plaintiff father, and the Defendant believes it would be in the best interest and permanent welfare of the children for her primary custodial position to remain unchanged. It is denied, however, that the best interest and permanent welfare of the children would be served by changing the custodial arrangements as requested, although the relief requested by the Plaintiff is somewhat confusing. 16. Admitted. WHEREFORE, Defendant respectfully requests that the instant action -3- ,,"~'- I" ~I,<~> I~ .'.- ,.,;c ~ --' . ~;;SI be dismissed, that the Defendant be awarded her costs in defending this action, including reasonable attorney's fees and that the Order of Court dated December 1, 1999 be modified to require father's visits to occur in the United States, and otherwise be reaffirmed. Re"p,,~~ BY:~ Bruce F. Bratton, Esquire MARTSOLF & BRATTON 2515 North Front Street P.O. Box 12106 Harrisburg, PA 17108-2106 (717) 236-4241 Attorney ID. #23949 Dated 3/ ()uht L.- crv ATTORNEY FOR DEFENDANT -4- ;l~ .,~_ I> I"", " ~ VERIFICATION I verify that the statements made in the attached Answer to Complaint For Custody are true and correct, partially upon personal knowledge and partially upon my belief; to the extent language in the attached answer is that of my attorneys, I have relied upon my attorneys in making this Verification. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn ~sification ,to authorities. eJ/~MUt (Qr~ a ice F. De ut Date: IOJ,~I/oO I I 'i~ ,~ ';""'II&i-lG,-%~ ~;r'''''''''' ~ _~' L..",..~.~, .j _I ~I~ _ -",'-- ..--- -,.' '"'HiD"'''l'J>v CERTIFICATE OF SERVICE I hereby certify that I today served a true and correct copy of the foregoing Answer To Complaint For Custody, by placing the same in the u.S. mail, postage prepaid, addressed to: Edward J. Weintraub, Esquire 2650 North Third Street Harrisburg, PA 17~110 L II (jv I " Date to IJrJlJ - _ Bruce F. Bratton, Esquire iI.I~~~ I~~_. ~ ~ . '~.~,--l- I ~ iik", .. , .. . . JOHN ROBERT DEPUTY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-6823 Civil JANICE F. DEPUTY, Defendant CIVIL ACTION - LAW CUSTODY ANSWER TO EMERGENCY PETITION FOR SPECIAL RELIEF/PRIMARY CUSTODY/RELOCATION Defendant, by and through her attorneys, Martsolf and Bratton, files this response to the "Emergency Petition" as filed by the plaintiff in this matter and avers as follows, making reference to the paragraph numbers contained in such "Emergency Petition": 1. It is admitted that John R. Deputy is the father of the minor children involved in this custody proceeding. It is admitted that his address is a box number in Saudia Arabia. It is denied, however, that the Plaintiff resides in or at such box number. Defendant notes, however, that the Complaint for Custody filed in this matter contains a different box number than the box number in the "Emergency Petition". 2. Admitted. 3. Admitted. 4. It is admitted that the Plaintiff filed a complaint in -1- - ,..~" ~'. _. J, "" ,--.;]- ,~ ""l<iI,hll-":,'. , . . ( custody on or about the date stated. Defendant denies, due to lack of knowledge, all allegations concerning the father's belief regarding the best interest of the children. To the extent the allegations of paragraph 4 of the "Emergency petition" constitute an implication or allegation that it would be in the best interest of the children to move from the United States to Saudi Arabia, the Plaintiff's temporary workplace, all such allegations are denied. 5. No response is required. 6. Admitted in part and denied in part. It is admitted that the child, Angela Deputy, has required inpatient psychiatric care at Holy Spirit Hospital and has been and continues to receive, ongoing treatment for Bipolar Disorder and Borderline Personality Disorder, the diagnosis provided by her treating psychiatrist and by the Early Intervention Program. The reasons for the child's "complaints" are, therefore, Defendant submits, related to her diagnosed illness or disorders. 7. Denied. Defendant has no history of "dependency" and has never abused the children in any fashion. 8. Defendant has no knowledge concerning what the father has interpreted to have "been encouraged by the child's treating -2- 'cl~_~_ ~- I - ,. - M ~"' ~,~.......~ \li;',1;; .. ,', physicians and counselors to seek primary physical custody". Proof of such allegation is demanded at the hearing in this matter. To the contrary, Defendant believes, and therefore avers, however, that no treating physicians or counselors would render or has rendered any such opinion or advice. To the contrary, one of the treating therapists has already advised Defendant that she has not made such a representation nor suggestion nor would do so. Such counselor's writing to such effect is attached hereto as Exhibit \\AIf. 9. Denied. To the contrary, while the Plaintiff Father has been remarried, started a new family and relocated for an employment opportunity in Saudi Arabia, the Defendant Mother has met and continues to meet the day-to-day health, welfare and other needs of both of the children who continue in her care and custody. Further, the mother has responded appropriately by seeking the correct and appropriate psychological, psychiatric, medical and other care and treatment for the child, Angela M. Deputy, even without any financial assistance from the Plaintiff Father and the child continues to receive such care as appropriately arranged by the Defendant Mother. 10. No response is required to the plaintiff Father's allegations as to what he "would seek". Defendant denies, however, -3- , .~ I . . . , that it is in the best interest of the children to be relocated to Saudi Arabia outside of the United States and beyond the jurisdiction of this Court and the courts of the United States. WHEREFORE, Defendant Mother denies that an expedited custody conciliation conference and hearing is required. Respectfully Submitted, By: Bruce F. Bratton, Esquire MARTSOLF & BRATTON 2515 North Front Street P.O. Box 12106 Harrisburg, PA 17108-2106 (717) 236-4241 Attorney ID. #23949 ATTORNEY FOR DEFENDANT Dated: 3/ tJ/vL dlJ -4- J ~"~oi#', - ,_~ -......"'~~ len' - "~ "'i1.I" " 1-=_ < ",I oJ. " ~~~~~- . . , VERIFICATION I verify that the statements made in the attached Answer to "Emergency Petition for Special Relief/Primary Custody/Relocation" are true and correct, partially upon personal knowledge and partially upon my belief; to the extent language in the attached . answer is that of my attorneys, I have relied upon my attorneys in making this Verification. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. -dc~ D1i~ . J ce F. De t~~ Date :~18110'" . , ~ ~ _~J= ~. "'~, .~~ ~. oC .....1- _',I ~ ~' >~,~"- " ",,, . . . CERTIFICATE OF SERVICE I hereby certify that I today served a true and correct copy of the foregoing Answer To Emergency Petition For Special Relief/Primary Custody/Relocation, by placing the same in the u.S. mail, postage prepaid, addressed to: Edward J. Weintraub, Esquire 2650 North Third Street Harrisburg, PA 17110 ------ l JJ 01/'( t... .s.- Cf'V Date 1ll F. Bratton, Esquire j';''''''lItdrU}:~'Pl";- '" "~.- ~C'..~ 1 ~~i.ir~~~~.lUr~' ~~ -" ~~ .';'; . ~ ~ J. -r-M' <'" " __ ~~~d_-,"", __ "_' _" ~ , , , 0 <::> 0 c: 0 -,-, <" ~ v 0;:1 25 --:;:5 mrn ,,<: r-l-~pg Z:1} zr- I 'Tlrn ej))":" -J -~J2Y -<'2: ~~:.::: C) ~C') J>......... -0 ~ " z.....; :Jt: ?'):D --0 7(") )>c: ('Srn ~ D 'J;! :u (:0 -< " I ",-,,-I I' " < J' ,I ~ " " .' ~~~~~-"r"''''~~f;H) , {;"" ,", ,,~ ,. )' " "(GUIDANCE "" "";' '".' , !;,l,',.",.' ,,"","';';" ",',^, SSO,OATES I,' ' ,,, OF ,,' , . "I .."PENNSYLVANIA ", MAIN OFFICE 412 Erford Road Camp Hill, PA 17011 Stanley E. Schneider, Ed.D. Director Camp Hill: (717) 732-2917 Hershey: (717) 533-4312 Carlisle: (717) 245-2289 Chambersburg: (717) 263-93~12 FAX: (717) 732-5375 October 12, 2000 TO WHOM IT MAY CONCERN: Angela Deputy is a patient of Guidance Associates of PA. I am Angela's therapist, and therefore have not made any recommendations regarding custody of Angela, as this would be a conflict of interest. Please call if further information is necessary. Sincerely, ~{)~ ~j Jamie Orris, MSW Licensed Social Worker JO:sm E yhJ~) it 'A I, ~Comprehensive Psychologi'cal Services . Drug and Alcohol TreatmE!nt~ __I, , ~ Iio-~~. " _~l!ffi;Jll~,'!Iiii'; JOHN ROBERT DEPUTY, * IN THE COURT OF COMMON PLEAS Plaintiff, Cumberland County, Pennsylvania * vs. * NO. 00-6823 * JANICE F. DEPUTY, * CIVIL ACTION - LAW Defendant. * CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : 55. COUNTY OF DAUPHIN I HEREBY CERTIFY that before me, the undersigned authority, a Notary Public in and for the CommonweJlth of P:nnsylvania, County of Dauphin aforesaid, personally appeared YrAlLWl/R.J? , who made oath in due form of law that on the )... 7 day of (D('~ f ' 2000, at .1/: WI1~CIOCk ;r.M., he personally served a true and correct copy of the Order of Court regarding the Custody Conciliation Conference filed herein upon the Defendant, Janice F. Deputy, at her residence at 1821 Bridge Street, New Cumberland, PA 17070. QJ;J~ Sworn to and subscribed before me on this JJ.!! day of 0dbbe tZ 2000. c/~,O.ttlm0 No ry Pu hc Notarial Seal Misty D. Lehman, Notary Public HarrisDurg. Dauphin County My CommiSSIOn Expires Aug. 2, 2004 - lMiiJ'~ ~- .. 'l!lllJllLllf' ~'~'- ",~"~;"".';""-r~ 'Ji ~tik4~'l\igtii~Ali.~j~i!Ii~ ,'-- ~[ , ~~.~" . "I -. .~~,"'" ,,<. ~ ,. ie' '" "_h ,~ '~ii "WIll"''''' >j,J~;, ....".,.--""'-'-" .,-'~ f ~w if ~t) lB ~ ~ ~ -. ("".) ~ o ,,~=.'-;.';",,",'- " & f'? ...., ~ '-J !;f? 3.i! rq::t! ,- 7:'[7/ :i)N f~' r "."r :::::!>-J i~~1 '~,:Jf5 017'1 $ -.;: Iru! j~J~_ ._ I~ ~ -"'-'~''1;;t\;c, JOHN ROBERT DEPUTY, Plaintiff, * IN THE COURT OF COMMON PLEAS Cumberland County, Pennsylvania * vs. * NO. 00-6823 * JANICE F. DEPUTY, Defendant. * CIVIL ACTION - LAW * CUSTODY 8 = c s:: 0 ..,., ~m 0 --1 C"') ..... ;'~'i,.::n z::tl N r- w~ --,,..,, -' :"i)b ~"'- ~~6 ;.::::0 -0 ~8 -1:'-'" :x i)'J:! ~~(") >c ry Orn ~ ~ (..:> :0 -< CERTIFICATE OF SERVICE I, Misty D. Lehman, Legal Assistant to Edward J. Weintraub, Esqui,re, hereby certify that on October 27, 2000, I served a true and correct copy of an Order of Court regarding the Custody Conciliation Conference dated October 24, 2000 upon Janice Deputy, Defendant, by depositing same, postage pre- paid, in the United States Mail, Harrisburg, Pennsylvania, addressed as follows: Janice Deputy 1821 Bridge Street New Cumberland, PA 17070 Date: JO-JI-00 ~~%ntlJLma0 Mis y D. L hman ;lli-'>"c ~II~ JUifilUlj - ~ ,- II """'~""""'~~~@Ij-'rl1~lfL~:i~~~~H:Jr"~ $t""""'--'~' -~ ,- ~ '. Jldiil!iIlll ~ , "C "-. - '<.'~ 0 a 0 ~ c:::> -n CI .,.-{ ~~ ("") T ....... ?1 ~t jJJ N "/",,m ~~ -.l t3'X ~o .." ~kI. ~'-:n ~(:) 'X ~0 ~2 ~ r" ~ ~ (,;l ~ "-''- -,i,"'o,',',<,,,,'","",<,""'''''",,'_ ~"". ="'~_~~.,__" ,~""",-,,~;-- "",0,,1 '"P__ C-,""H ,~ -<,"- " ~, tt ~-, - I, _I " ~-~'~~__rrIlltA'l~"<=""<'illl'ol!l"'I""""" JOHN ROBERT DEPUTY, * IN THE COURT OF COMMON PLEAS Plaintiff, Cumberland County, Pennsylvania * vs. * NO. 00-6823 * JANICE F. DEPUTY, * CIVIL ACTION - LAW Defendant. * CUSTODY CERTIFICATE OF SERVICE I, Misty D. Lehman, Legal Assistant to Edward J. Weintraub, Esquire, hereby certify that on October 11, 2000, I served a true and correct copy of an Order regarding the Emergency Petition dated October 9, 2000, and Emergency Petition for Special Relief upon Diane Baker, Esquire, counsel for the Defendant, by depositing same, postage pre-paid, in the United States Mail, Harrisburg, Pennsylvania, addressed as follows: Diane Baker, Esquire 27 South Arlene Street Harrisburg, PA 17112 Date: It> -\\-0\) .mJ~~ isty D. eh an "'" . :iiil"jr' "~Mi~'OOir'"- '~'~<""""ltliii:I\~~j:!,A~"JJJi\~fu",a'W';";'W'~1;-j.",,;:~'1l0";it!jN!'h~,*'i~,1!!.a'Wi~~~tJtrij-' Ji\jjjr!l~~_'~ ~.,..."-- nl_l.~ o r- ~ -::'-,.. -ufjJ mW" " Z:~\.' '~~~:,: ~~ .7 ':::j -< c:) C o .-,--, ~-t f'0 :? r::-? =' </' ~? ~:j 5-1 ~< ."'-'&~~~ '" , I -I -""~~~~!'!t,. ~ r- JOHN ROBERT DEPUTY, * IN THE COURT OF COMMON PLEAS Plaintiff, Cumberland County, Pennsylvania * vs. * NO. 00-6823 * JANICE F. DEPUTY, * CIVIL ACTION - LAW Defendant. * CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF DAUPHIN AND NOW, this 11th day of October, 2000 personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, Wendy L. Shive, who being duly sworn according to law, deposes and says that on October 2, 2000, a certified copy of a Complaint in Custody and Emergency Petition for Special Relief/Primary Custody/Relocation was mailed by certi~ied mail, restricted delivery, return receipt requested, to Janice Deputy, 1821 Bridge Street, New Cumberland, PA 17070 and the same was received by her on October 6, 2000 as indicated by the return receipt card which is attached hereto. .... Sworn to and SUbscr1i..~f\!or_e "me on this JL.. day of >De.1, 200, 0,' th JJ\~, lwo.v Notary Publ Notarial Seal Misty D. Lehman, Notary Public Hamsburg, Dauphin County My Commission Expires Aug. 2, 2004 ;..II..., ~ I r- , i:' $a 1 aJtlVor2 flDr',adGIffional ser:vklss. "1lMlS'3t48, a1'Uf4b. " _::: ~o~~.ams and address on the reverse of this form 80 that we can return this " _, ,ch this form to the front of the mallpiece, or on the back if space does not pennn. I, MWiite-R8Ium R8CBipt Requssted" on the mailpiece below the article numt;>er. .. IfThe Return Receipt wllI show to whom the article was delivered and the date . delivered. Consult postmaster for fee. I.', Article Addressed 10: 4air~tlbberQc6'j ~I Jo..n\ lJl. ~. 4b. Service Type : Iq~'\ ~~tlo.t sf. 0 Registered 8 ~ tJ I ,f _. ./\ _I .Ii IA 0 Express Mail {\Jew l(JJ lOt f"I'"+ Return Recei 11070 7. Oafeof oe"/ 8. Addresse s and fee Is paJ I also WlslIIO 'teoeW& ll>e I&Illi>wIIIIg servIeeS (fGr an -extra tag): 1. 0 Addressee's Address f 2. 'r1lRestricted Deliv<lry I I J f ! I J . Received By: (Prfnt Name) i .Ii . fine. OeAil861ie , "'-"- ~, + .t:r""-~.~ _ I" ~-'. .- 1- , - 1_, I '-h ,~,^ li!!ii!L~, JOHN ROBERT DEPUTY, * IN THE COURT OF COMMON PLEAS Plaintiff , Cumberland County, Pennsylvania * Gc>~L ~\ vs. * NO. DD- (..1'.:2.3 * JANICE F. DEPUTY, * CIVIL ACTION - LAW Defendant. * CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF DAUPHIN I HEREBY CERTIFY that before me, the undersigned authority, a Notary Public in and for the Com nwealth of Pennsylvania, County of Dauphin aforesaid, personally appeared 't..(;' C7;;;. ,who made oath in due form of law that on the .!j-rH day of ,2000, ati~'cIOCk .M., he personally served a true and correct copy of the Complaint in Custody and Emergency Petition for Special Relief/Primary Custody/Relocation filed herein upon the Defendant, Janice F. Deputy, at her residence at 1821 Bridge Street, New Cumberland, PA 17070. ~ b~)~ I Sworn to and subscribed before me on this ..5 day of (J ~ 2000. i!!ld-U II zJ1mv.J Nota y Public Notarial Seel Misty D. Lehman, Notary Public Harrisburg, Dauphin County My Commission ExpIres Aug. 2, 2004 I ~ ?:;: ~L ~:s ~~~ '_l_ "', '(~r<.. t;:'~ C' --' c.c 'C,_,,,_ -" '" r;;, ::::: C-- U....- n '# -- ~ 7' 5.::( (--");;;:;j () ':'2 <:\3 -,- t~~ ~~~ D_ :":> o l- t.-' o o c:' ,. 1~, ~mJL,l ,~" ~ "^,,TI. _I., 1S1mgr-lil ~_'",~.,.-.o"",,~~,?,,~,..,...~~~~1:rr;J~w!<;;I~~~1'.l~'i"!W'~~.~~~~~~"lfl!illi~,~r,~ ~.-" ,,'- L "J c"'",,",,,~.',,_,_:;,~," k>' Cj~ JANICE DEPUTY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. JOHN R. DEPUTY, Defendant 00-6823 CIVIL TERM 99-7133 CIVIL TERM ORDER OF COURT AND NOW, this 17th day of November, 2000, upon agreement of the parties the above-captioned cases are consolidated. By the Court, EDWARD J. WEINTRAUB, ESQUIRE For the Defendant Edward E. Guido, J. t.~~ }J - Jl1-00 RK3 \' BRUCE BRATTON, ESQUIRE For the Plaintiff ill- iJ, c, -""- ~ ,~" ~- rJ,) I" ~, :<i:~ "! \'-}\/ " ",- ,,', ;-"."-": \NT\{ -~1 PI !'__", ,0-1 ,!".';:L.; ....JJ.,1 CV\"lpEN~\S'(\:.}t.N\/\ __"_ ",,~~-. ,,~'!~~~.frc~,.:1 .' ,-- '" '~\J ',:-,\. t~, 1~!$]'l~tr~~~!.il:~rW'~~"",<,,_c_~_~,~"f); ," '0_ I.~_- ....1 L",_ """"",,"," '''',-.j:" , DEe 1 3 2000f/l JOHN ROBERT DEPUTY, Plaintiff, :IN THE COURT OF COMMON PLEAS :OF CUMBERLAND COUNTY, PENNSYLVANIA v. No. 00-6823 CIVIL ACTION - LAW JANICE F. DEPUTY, Defendant. IN CUSTODY ORDER OF COURT AND NOW, this 11th day of December 2000, the Conciliator, being advised by Plaintiffs counsel that all custody issues have been addressed by Judge Guido subsequent to the Petition for Special Relief, hereby relinquishes jurisdiction in this case. FOR THE COURT, Melissa Peel Greevy, Esquire Custody Conciliator 01- "~"'" ,"" -'~"'>';"~--' ~:-!L~?}-()(F~Ct rj--- ""' '.' ~"....\I.II....\"r"Af.lY \',;;':, l'.' ,!-':U',;.....Jl.J\ n'~ DcI"' u,j ,Lu 18 ~"U 2' 2S rTl ",- ~. CU' ,-". .",.- C ~"N'ry , MUthL/\;\jU 'lJu j PENNSYLVA,I\JIA .0 _~ ~p ~I _ "1""0',,<,,"-' _ ~~Jll~~Il!l,~'jfi~~~~~m, -. '~',~,,'. '" >>,'. ~, ~'" '1'~ <,' ~"",ry,~ -"=-" " 1",- ~~~~ ..J " ')l'~~,!; , JANICE DEPUTY, Plaintiff/Respondent v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 00-6823 Civil Term ~ No. 99-7133 Civil Term JOHN R. DEPUTY, Defendant/Petitioner CUSTODY AND NOW this ~)~~ ORDER of J..JY , 2003, pursuant to occur No. .s- ~~ I;' Hearing, a hearing , 2003 at~ is hereby scheduled ~.M. in Courtroom to Defendant's Demand for , the Honorable Edward E. Guido, presiding. ,.,. JtJ I J. Distribution: ~le M. Staley O'Gorman, Esquire 1719 ~orth Front Street, Harrisburg, PA 1710'- ~ Deputy '. 550 Bridge Street, New Cumberland, PA 17070 > L~,J- fY\ R K5 O']-a..~ -03 11III ,O,",_~"- , ~ , I "Nft[! i~ " ~"""""1'!Il,,~JAAl',"~ ~':;l.~.:Ci"OFFiCE OF f~' r, ,>:<,'i~'~~CNOTARY 03 ,JUL 28 PI1 2: 54 CUM8l:.HU~(~O COUl'ffY PENNSYLVANiA ~jl'Thl'j\~,-'jil~lIil~+",zwmO'.q".,m'i1"j:~i>.~.'il!l'<~J "".!~:Ii~~:&'jlll~t,_~=~ ".,IT .~ l...- . ,I - 'I'~ " ,0- ~O: ....... "... . "I~jj;~Iff'ihh " .' ~ JANICE DEPUTY, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 00-6823 Civil Term No. 99-7133 Civil Term JOHN R. DEPUTY, Defendant/Petitioner CUSTODY DEMAND FOR HEARING Pursuant to the director of the Honorable Edward E. Guido in his Order dated July 1, 2003, Defendant/Petitioner, John Deputy, hereby submits his demand for a hearing on his Petition for Contempt and Modification of Custody. Respectfully requested, 1/2(OtJ By: Ni I. 17 9 North Font Street H rrisburg, PA 17101- ( 17) 234-4178 Attorney for Defendant/Petitioner iii! -~ ~~ , :1 u' ---~",,^,-"'-j'~,~ ~d i - i' ':' f" " ~ CERTIFICATE OF SERVICE I, TRICIA KOWALCZYK, an employee of the law firm of Purcell, Krug & Haller, counsel for Defendant/Petitioner, hereby certify that service of the foregoing DEMAND FOR HEARING was made upon the following by First-Class, Regular Mail, Postage-Prepaid on July 2, 2003: Janice Deputy 550 Bridge Street New Cumberland, PA 17070 ~~~ iiimilf.:-~ '~~~~,jllfJf~';~".~milllf"''''''~~~ft~~~~~-~'''o~ ~ ~~'-, "~-- ~ , '. .~' ,0:.....0 = !"' g ~ "'", -oC.Li rnp. Z=L Z" ~, :2> !:;2" Zc:;. .......L2 -;;-c 2:, ::::2 o w C r- , N -0 :Jt '-I? "" U1 -",,,,, .........<: ~ --\ -1i;Q , ~~ :-j,:IJ ","0 ~5rn :0., ")':;0 :0 '-< '1"- " , ~~' - "''-'__'k''~>l~,; "o'~ ~il . JUl 0 3 lac '\S LAW OFFICES HOWARD B. KRUG LEON P. HALLER JOHN W. PURCELL JR. JILL M. WINEKA BRIAN J. TYLER NICHOLEM. STALEY O'GORMAN p}J~~y-~ 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FAX (717) 234-0409 HERSHEY (717) 533.3836 JOSEPH NISSLEY (1910-1982) JOHN W. PURCELL Of Counsel July 2, 2003 HAND DELIVERED Cumberland County Prothonotary's Office One Courthouse Square Carlisle, PA 17013 RE: Deputv v. Deputv Cumberland County Docket Nos. 99-7133 and 00-6823 Civil Dear Sir/Madam: Enclosed for filing please find the original and two (2) copies of a Demand for Hearing in the above-referenced matter. After filing same, please return a time-stamped copy to our runner and forward a copy of the document to the Court Administrator for scheduling of a hearing. PLEASE NOTE THAT MR. DEPUTY WILL BE IN THE COUNTRY THE WEEK OF JULY 14-18, 2003, AND WE WOULD LIKE TO SCHEDULE A HEARING FOR A DAY THAT WEEK, IF POSSIBLE. I UNDERSTAND THAT JUDGE GUIDO WILL BE IN CRIMINAL JURY TRIALS THAT WEEK; HOWEVER, MAYBE AN EXCEPTION CAN BE MADE TO HEAR THIS CASE BECAUSE MR. DEPUTY'S PRESENCE IN THE STATES. If you have any questions, do not hesitate to call me. Thank you for your assistance in this matter. Sincerely orman NMSO/plk Enclosure cc: John Deputy (w/Enclosurei 1fI1" l~~dl 1,- ~','." ,c, . .__ .." ~. I!l.~(;' -......'" JANICE DEPUTY, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 00-6823 Civil Term No. 99-7133 Civil Term JOHN R. DEPUTY, Defendant/Movant CUSTODY ORDER day of ~ hereby ORDERED that the Movant, John R. Deputy, AND NOW, this SiI' , 2003, it is testimony via telephone during the September t .#~/ :""'u..... ,. - ~ /I: may provide .~ , ~~ 2003 hearln~.~.. ~--u. "--- J. Distribution: ~Chole Staley 0' Gorman, Esquire 1719 N. Front Street, Harrisburg, PA 17102 ~anice Deputy 550 Bridge Street, New Cumberland, PA 17070 . ~41~ RKs Oq-o.5-CJ~ :iil f,.~ ~,;.I;I.t,.,U\~~ < -~- "~" ,~ rlr~l'''''''''!~n'' ,""- "-'~- () ~ ~- ~~'i; q:) CT.!, "t;....-'::__ -j"~ ~}, j~ L::::, :'2 C' 0) :/) en -0 (.s' o -11 :"-;--1 :-""1 :I:"; :5;8 ""?,~~'~ o.~:~(") .:-::.;rn '-~ . ,~ ',-,. ::0 -< "~.o --i'" -- N -' ..-1 ,.,,~. ",""''''''''l~allfJ'~~j~!!i~'~'W~IlWoiiiffiiffl~~~~wr~~i ..J. ~ = - ut~' JANICE DEPUTY, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 00-6823 Civil Term No. 99-7133 Civil Term JOHN R. DEPUTY, Defendant/Movant CUSTODY RULE TO SHOW CAUSE AND NOW, this day of , 2003, a Rule is hereby issued upon the Respondent to show cause why the attached Motion for Court Approval of Telephone Testimony should not be granted. days from service. RULE RETURNABLE BY THE COURT, J. Distribution: Nichole Staley O'Gor.man, Esquire 1719 N. Front Street, Harrisburg, PA 17102 Janice Deputy 550 Bridge Street, New Cumberland, PA 17070 ""_~ ~ ~ I - L ';1"'" , 1... " .__r. "" > JANICE DEPUTY, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 00-6823 Civil Term No. 99-7133 Civil Term JOHN R. DEPUTY, Defendant/Movant CUSTODY MOTION FOR COURT APPROVAL OF TELEPHONE TESTIMONY AND NOW, comes Movant, John R. Deputy, by and through his attorneys Purcell, Krug & Haller and files the following Motion for Court Approval of Telephone Testimony: 1. Movant is John R. Deputy, the Defendant in the above- captioned custody action. 2. Respondent is Janice Deputy, the Plaintiff in the above- captioned custody action. 3. On or about April 11, 2003, Mr. Deputy filed a Petition for Contempt and Modification of Custody. 4. The Petition is scheduled to be heard by the Honorable Judge Guido on September 12, 2003. 5. Mr. Deputy is a United Stated citizen. However, he currently works and resides in France. 6. Mr. Deputy has recently been advised that his work visa will not be renewed and he must leave the country in the next few days. 7. Mr. Deputy does not yet know where he will be residing following his departure from France. 8. It is highly likely that Mr. Deputy will not be available to attend the scheduled hearing in person. - c. ~.I," .','",-',. ..~ ''''-'iiLaiiil:iM;,; 9. Pennsylvania Rule of Civil Procedure 1930.3 provides that a party may testify by telephone with Court approval. 10. On August 25, 2003, counsel for Mr. Deputy wrote to Ms. Deputy advising of Mr: Deputy's intention to testify by telephone and requesting her to respond with any objection. To date, no objection has been received. A true and correct copy of said correspondence is attached hereto and made a part hereof as Exhibit "A". WHEREFORE, Movant respectfully requests this Honorable Court to permit him to testify by telephone at the scheduled hearing. PURCELL, KRUG AND HALLER ichole M. D #79866 719 North Front Street Harrisburg, PA 17102 717 234-4178 Esquire By Date: q/&/O 9] - ~,I" ~ "'~~ ~ "0 . , jl ;;J ~',.". ',i.:.,,i,, ,,-',-", -" ""lA, LAW OFFICES HOWARDB.KRUG LEON P. HALLER JOHN W. PuRCEU.JR. Jlll.M. WINEKA BRIAN J. 'TYLER NrCHOLEM. STALEY O'GoRMAN q:>~~r3~ 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FAX (717) 234-0409 HERSHEY (717) 533-3636 JOSEPH NISSLEY (1910.1982) JOHN W. PURCELL Of Counsel August 25, 2003 Janice Deputy 550 Bridge Street New Cumberland, PA 17070 RE: Deputv v. Deputv Dear Ms. Deputy: I am writing to inform you that Mr, Deputy intends to present his testimony at the upcoming hearing by telephone. As you know, his employment and continued residence in France is quite uncertain at the moment. Mr. Deputy is not sure where he is going to be on September 12, but feels certain he will not able to return to Pennsylvania. If you intend to lodge any objection to this type of testimony, please inform me at once so that I can present this issue to the Court for resolution. cere1y yours, NMSO/plk I cc: John Deputy (V;a Email) EXHIBIT I A ". n,J ,.',1"",."'"-'" .1 - , "". ~ ~-' ,"'.-~, ~ ~, .',-,-~.- n,_d '..." . '--'~- VERIFICATION I, JOHN DEPUTY, hereby verify that the facts contained in the foregoing Motion for Court Approval of Telephone Testimony are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: ~ ~'- -" ~. =1.1". '~~- . ,. ';0- ~ "" ,:'r"~ CERTIFICATE OF SERVICE I, TRICIA KOWALCZYK, an employee of the law firm of Purcell, Krug & Haller, counsel for Movant/Defendant, hereby certify that service of the foregoing MOTION FOR COURT APPROVAL OF TELEPHONE TESTIMONY was made upon the following by First-Class Mail, Postage Prepaid on Q-3-o3 Janice Deputy 550 Bridge Street New Cumberland, PA 17070 ~ Tricia Kowalczyk ~~~~;j!'C*,ij-;"'1j-"1;;;~~'iii;~~~!!'i\~11ii<.~lkl\!.>J~~_i81'''- '~rrn~ ,_ ,l~ .....""'-', ~",w",",,- " (') C :r:~ ~t1!1 ZC' ~~~~: S:; __. Zl--" )>0 ,;; =3. ",.,. " '" o (;..:1 (/) ,l' "':J o ;.,m ,., :::1 :-:ip1 -",_,',1 cr!,C'.J ,"\ 1 ':)~ ~~:?B orn -, ~ -< w -u ::t.'; C:'? - tJl ~ -', ~ " . iMlI 'iliiiilJ '- '~i& ~.., JANICE DEPUTY, Plaintiff/Respondent v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION ,~ LAW NO. 00-6823 CIVIL TERM~~ NO. 99-7133 CIVIL TERM JOHN R. DEPUTY, Defendant/Petitioner IN RE: CUSTODY ORDER OF COURT AND NOW, this 12th day of September, 2003, after hearing, our Order of July 1, 2003, is vacated and shall be of no further force and effect. Our Order of December 6, 2000, is modified as follows: 1. II Transportation is replaced with the following: Father shall provide all transportation necessary for his partial custody except that Mother shall assist by providing transportation to and from any airport of Father's choice located within 120 miles of Mother's current residence in New Cumberland, Pennsylvania. Further, Mother shall assist by driving up to 70 miles to meet Father at a transfer point for any visitation that will occur at Father's parents' home in Allentown, Pennsylvania. 2. IV shall be replaced with the following: Mother shall have the children available to receive phone calls from Father at 9:00 p.m. Eastern Standard Time each Wednesday. The calls may last up to 15 minutes per child. The Mother shall not be in the room, nor shall she otherwise listen to the conversation between Father and his daughters. Mother shall require the children to e-mail their Father on a daily basis. Father shall advise Mother bye-mail if he did not receive any child's e-mail on the previous day. Mother shall e-mail Father daily regarding something of interest in connection with each child. Father must j-'= "Ic" 'I. , L ~ '~ ,~.;".' '~~::ii<<I~~ ........' respond, talking about the welfare of the child. The tones of these e-mails shall be cordial or parental as is necessary. No mention of support, or other problems between Mother and Father, shall be contained in any e-mails. Copies of the e-mails between Mother and Father must be maintained to be provided to this Court as an exhibit in any future hearings. In all other respects, our Order of December 6, 2000, shall remain in full force and effect. Edward E. Guido, J. ~hole M. Staley O'Gorman, Esquire Attorney for Defendant/Petitioner ~ott A. Stein, Esquire Attorney for Plaintiff/Respondent srs ~ :V'~ ~..\ lTit >iii ... ....' " ". ,~- ~" ~,"., , ~, ~. ,_.' .""~ ~. rt'", "''''\ ^"-'" 'A,=,,-'C:;;-'f"'~' " .~^' <'~,<~~ ~- Of' 03 SEP ! u i:j:,; Q. I'. '"~ ,.;. ,:."i) CUti:~~;;7~:<;';"/~;'i\iY Pl...J~['t" '!,"\J':I'~ ' .., i,!,. ~~"~~.!!f1!!1 ,~\l€!1~'~,~ ,.,:~- ,,,<1t,~_WlJ:,!l,l~j ~~ "~" <'- '''''';~')'! ","-"~'llf t I _~_I ~, 1lIiisoIirlii~ ~ - '~, '~Mll1L~"''''' JANICE DEPUTY, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW JOHN R. DEPUTY, Defendant/Petitioner NO. 00-6823 CIVIL TERM ~ NO. 99-7133 CIVIL TERM ORDER OF COURT AND NOW, this 12th day of September, 2003, after hearing, the Petition for Contempt is DISMISSED. By the Court Edward E. Guido, J. ~chole M. Staley O'Gorman, Esquire Attorney for Defendant/Petitioner ~tt A. Stein, Esquire Attorney for Plaintiff/Respondent srs \f . p~ \ j\~~ V\'\~'iS q_\Vc0 ~ 7] ,_,' ,~~,," ,. I .,' '" l~m,.~,,.,.,.-._ , ," OF O:J") c:r:p <.'1." D ,il.;,.; c/. }""", , "<,' ,!'....' CU' .,',," , "1"-""'-" ,'; '" ",' I" 1'-, ~ ,~.-''-, :'._.' \; j " i, ,j\1 ~ ,/ PENf\)SI'-,'J I,jl^,i\!'~!.,\:~ ,'I -. ,'''' \.; !~ ~L~,,~ ",,~,JU _"" '",;--..'" ,~"-,.J,ILJrnI~~l"W,Wi_L'P~,~~L,,c ,1l~._,_.~J ~--'C"-;.,.__,~~~,:""",,-,-,, c2000 - ~ 8' ~ 3 J)e.pdy v $ JJe..pu:f1 [ (..(..~ oJ.y (0 J'tl.,f I a... I rL + ~ aJI afLu .{J/J,,~s; ^IJ,.V~ tau. SO'AAed. -hy_4u J L,,+ +(15 IIhAJ clu...f"J.. 4- jt/-Oj' WtLS ~u.~c,{ lit) s +t led... y S CO-Ylrt (.,J d f\. ,- f?' - 0 7 . . JOHN ROBERT DEPUTY, * IN THE COURT OF COMMON PLEAS Plaintiff, Cumberland County, Pennsylvania * / vs. * NO.00-6823 and 99-7133 Civil Term * JANICE F. DEPUTY, * CIVIL ACTION - LAW Defendant. * CUSTODY PRAECIPE FOR WITHDRAW OF APPEARANCE Please withdraw my appearance on behalf of Plaintiff, John Robert Deputy, in the above captioned matter without prejudice. Date:~ riO/Os PRAECIPE TO ENTER APPEARANCE Please enter my appearance on behalf of Plaintiff, John Robert Deputy, in the above captioned matter. Date: ~OJ " , CERTIFICATE OF SERVICE I, TRICIA KOWALCZYK, an employee of the law firm of Purcell, Krug & Haller, counsel for Plaintiff, hereby certify that service of the foregoing PRAECIPE FOR WITHDRAW OF APPEARANCE AND PRAECIPE TO ENTER APPEARANCE was made upon the following by First-Class, Regular Mail, Postage-Prepaid on April 11, 2003. Jennifer L. Frechette, Esquire for Edward J. Weintraub Weintraub & Associates 2650 North Third Street Harrisburg, PA 17110 \j.~ ~~iCZYk ... . c:) G~' T:~~ -~) :.j . , -'oJ u't