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HomeMy WebLinkAbout00-08358 AMY L. CORNMAN, PLAINTIFF/RESPONDENT V. JEFFREY A. CORNMAN, SR., DEFENDANT/PETITIONER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-8358 CIVIL TERM ORDER OF COURT AND NOW, this Z? day of August, 2001, a hearing on the within petition for emergency relief shall be conducted in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania, at 9:15 a.m., Thursday, August 30, 2001. By Edgar B. Timothy J. Colgan, Esqiure For Plaintiff/Respondent Arthur K. Dils, Esquire For Petitioner J. 63 " :saa ' ?,y ?. ,; ??: ... -??????,. ?,,?;JIn F?? ? ?,?'L?., ., .?, AMY L. CORNMAN, Plaintiff/Respondent VS. JEFFREY A. CORNMAN, SR., Defendant/Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-8358 CIVIL ACTION - LAW CUSTODY PETITION FOR EMERGENCY RELIEF AND NOW, this day of August 2001, comes your Petitioner, Jeffrey A. Cornman, Sr., by his attorney, Arthur K. Dils, Esquire, and respectfully requests the following: 1. Your Petitioner is Jeffrey A. Cornman, Sr., the Defendant above named, an adult individual who currently resides at 10 Mountain Road, Dillsburg, York County, Pennsylvania 17019. 2. The Respondent is Amy L. Cornman, the Plaintiff above named, an adult individual who currently resides at 614 State Street, Lemoyne, Cumberland County, Pennsylvania 17043. 3. Your Petitioner and the Respondent are the natural parents of two children: namely, Jeffrey A. Cornman, Jr., born May 28, 1992, and Mason W. Cornman, born January 2, 1996. 2 4. Attached hereto and marked Exhibit "A" is a Court Order dated January 11, 2001, setting forth the parties Agreement of shared physical and legal custody of the minor children. 5. Paragraph 8 of said Order sets forth that the minor children shall remain in school in the Northern York School District, at least, until a conclusion of the 2000/2001 school year. Said school district is within the home of your Petitioner, Jeffrey A. Cornman, Sr. 6. The Respondent and your Petitioner had previously agreed that the children would continue in the Northern York School District, namely, South Mountain Elementary School in Dillsburg, Pennsylvania. 7. The Respondent, Amy L. Comman, approximately three weeks ago, registered the minor children to attend the school located within her home in Lemoyne, Pennsylvania, without the agreement of your Petitioner, Jeffrey A. Cornman, Sr. 8. Jeffrey A. Cornman, Jr., age 9 years, did complete the 2000/2001 school year at South Mountain Elementary School in Dillsburg, Pennsylvania, where he attained A's and B's on his report card. 9. The Northern York Elementary School District, specifically, South Mountain Elementary School, is the third school district which Jeffrey A. 3 Cornman has attended since he started school, in the custody of the Respondent, Amy L. Cornman. 10. It is in the best interest of Jeffrey A. Cornman, Jr., and Mason W. Cornman, who will be attending kindergarten in the 2001/2002 school year, to continue to be enrolled in the Northern York School District, to attend the South Mountain Elementary School. 11. Simultaneously with the filing of this Petition, your Petitioner has filed a Complaint to Modify the Court Order, which is attached hereto and marked Exhibit "A". 12. The Respondent, Amy L. Cornman, is dissatisfied with her requirement to travel from her home in Lemoyne, Pennsylvania, taking the children to school in Dillsburg, Pennsylvania, and then having to reach her employment in Harrisburg, Pennsylvania, during her weeks of custody. 13. Your Petitioner, Jeffrey A. Cornman, Sr., and/or his fiance are able to assist in the traveling requirements of the children during the Respondent's weeks of custody, in that they are agreeable to share the transportation, meeting half way. 14. The Respondent, Amy L. Cornman, is not agreeable to the children continuing to attend the South Mountain Elementary School, and hence, has 4 registered them, without the agreement of your Petitioner, in her school district. 15. Your Petitioner, Jeffrey A. Comman, Sr., is in construction and, for the most part, his work schedule is flexible. 16. It is not in the best interest that the minor children be moved from their school, the South Mountain Elementary School, in that, Jeffrey A. Comman, Jr., has adjusted well, has attained high grades, has friends in school, and is looking forward to returning to the same school. 17. If the Respondent, Amy L. Cornman, is permitted to register the children in the school district in Lemoyne, Pennsylvania, this will be the 4t` school district, which the minor child, Jeffrey A. Cornman, Jr., has attended. 18. Your Petitioner, Jeffrey A. Cornman, Sr., resides with his fiance and their child, Madaline, age 16 months, the sibling of Jeffrey A. Cornman, Jr., and Mason W. Comman. 19. The Respondent, Amy L. Comman, failed to comply with the Court Order dated January 11, 2001, in that, in Paragraph 7, the Respondent was directed to file a Petition with your Honorable Court to modify the Order, if an agreement could not be reached between the parties, which she failed to do. 5 20. The Respondent, Amy L. Comman, has lived in numerous residences since your Petitioner and the Respondent separated. 21. The minor children each have their own bedrooms with your Petitioner, Jeffrey A. Cornman, Jr., in that your Petitioner and your fiance currently reside in a four-bedroom home on 17 acres in Dillsburg, Pennsylvania. 22. Your Petitioner is better able to provide a stable home for his minor children. 23. Your Petitioner and his fiance are able to assist in the transportation of the Respondent during her weeks of custody with the minor children. It is not necessary for her to travel from Lemoyne to Dillsburg and back to Harrisburg for her employment. 24. The Respondent, Amy L. Comman, is not considering the best interest of the children and the stability attained in the Northern York School District. 25. Your Petitioner, Jeffrey A. Comman, Sr., respectfully requests your Honorable Court to Order the minor children to continue to be enrolled in the Northern York School District and to attend the South Mountain Elementary School commencing the 2001/2002 school year and that this matter be referred to a Conciliator promptly for a re-evaluation of the Court Order. 6 WHEREFORE, your Petitioner, Jeffrey A. Cormnan, Sr., respectfully prays your Honorable Court to grant his Petition for Emergency Relief. Respectfully submitted, BY: hur K: Dils, Esquire 1017 North Front Street Harrisburg, PA 17102 (717) 232-9724 I.D. No. 07056 Date: d i 7 , AMY L CORNMAN, : riamun ; JEFFREY A. COWMAN, SIL, Defendant R' t• IN'hM COURT OF COMMON FLEAS OF CtJN%B A VD COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. OD- 8358 Crin[L IN CUSTODY COURT ORDER AND NOW9 this ` {L ay of JMW, '2001, upon eon"rotion of the attwhed Custody Conciliation Reports it is ordered and diteoted as IbUows: . 1. The Moor, Amy L Cor mw4 and the Falhdr, Jeffiry, A. Common, Sr., sbatl eajoy abated legal and aheeed physical custody of Jeffrey A. Common, Jr.. born May 28, 1992; and Mason W. Common, born January, 2,1996. 2. The parties shell work out a physical custody sr w&b on a week onhveek off baais. U? th 6 eii . of r r own a" view aaa 3. Tina parties shall she work out an arrangement whereby they share or alternate major holidays. t Doting the matow monft it is anticipated ft there will aoatimre to be a e Oft at ewlri4r wNh tba snmtiw tine ra mater OW % err/wwlr ON schedule to a schedule tlmt longer odd of time than the'tisl[ and winter months. 5. Both parents shall egjoy Seasonable telephone contact with the minor children wbile '--? - they are in the otber parem"s custody. 6. Both parade shall beep the odic parent ktmnod with respect to telephone u=Mm and addresses for to cldW= if the cliften are ever " of the Central Fermsylvaniaares. 7. This Omer is entered pursuant to an agreement reeehed by mho patties at a Custody Conciliation Confer in the event either party dashes to modify dds Order, that patty may petition the Court to have the ease again, scheduled with the Custody Conciliator. 1 1 R L This Order is enWed wilt the unfit ng they ? fibor?? Coalman, Jr., shall remain in school in the Northam York school district J a iw for the conclusion of the 20002001 school year. oo: Timothy J. Colgan, Esquire Brmoe F. Bretton, Esquire BY THE COURT, TRUE COPY FROM RECORD In toslimony Whsrcof, I hecc urHo set my h and t seal of s id Court at Carlisle, Pa. • 's ?, ,? 1 gym, n n ?,.. Prothone". VERIFICATION I verify that the statements made in this are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: A?d -a-©1 ?P ( CERTIFICATE OF SERVICE I, Arthur K. Dils, Esquire, hereby certify that a true and correct copy of the within Petition for Emergency Relief has been served upon the following individual by first class, United States mail, postage prepaid, by depositing same at the post office in Harrisburg, Pennsylvania, on the 21st day of August 2001, addressed as follows: Timothy J. Colgan, Esquire 1 South Baltimore Dillsburg, PA 17019 Date: August 21, 2001 Amy L. Cornman 614 State Street Lemoyne, PA 17043 Respectfully submitted, BY: Arthur . Dils, Esquire 1017 North Front Street Harrisburg, PA 17102 (717) 232-9724 I.D. No. 07056 8 e V C }C f C.7 _a [`l J ?i f`5 N N ci rl l` 1 l_] c -'-i erg `JIt7 .17 -C IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA AMY L. CORNMAN, Plaintiff/Respondent V8. JEFFREY A. CORNMAN, SR., Defendant/Petitioner * NO. 00-8358 * * CIVII. ACTION - LAW * CUSTODY ORDER AND NOW, this day of , 2001, upon presentation of Plaintiffs Answer to Defendant's Petition for Emergency Relief, is hereby Ordered that the Petition for Emergency Relief is Denied. It is further Ordered that the minor children may immediately continue their enrollment at the West Shore School District pending the outcome of a Conciliation Conference to be held in this matter. BY THE COURT: Honorable Edgar B. Bayley Distribution: Arthur K Dils, Esquire, 1017 N. Front Street, Harrisburg, PA 17102 Christine J. Taylor, Esquire, 1 S. Baltimore Street, Dillsburg, PA 17019 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA AMY L. CORNMAN, * NO. 00-8358 Pbintiff/Respondent * vs. * CIVIL ACTION - LAW * JEFFREY A. CORNMAN, SR, Defendant/Petitioner * CUSTODY PLAINTIFF'S ANSWER TO DEFENDANT'S PETITION FOR EMERGENCY RELIEF AND NOW, comes Plaintiff Amy L. Cornman, (hereinafter "Respondent') by and through her attorney Christine J. Taylor, Esquire of WILEY, LENOX, COLGAN, & MARZZACCO, P.C., and respectfully files the following Answer and New Matter: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Denied. To the contrary, the parties agreed that the children would enroll in the West Shore District at the conclusion of the 2000/2001 school year. 7. Admitted in part and denied in part. It is admitted that Respondent, Amy L. Cornman, enrolled the minor children to attend a school located within the district in which she resides; however, it is denied that she did so three weeks ago. To the contrary, Respondent notified Petitioner in or around the beginning of July, 2001, that pursuant to the parties' agreement, she enrolled the minor children in the West Shore School District. 8. Admitted. 9. Admitted in part and denied in part. It is admitted that South Mountain Elementary School is the third school district which their minor son, Jeffrey, attended; however, it is denied to the extent this allegation appears to hold Respondent solely responsible for the change in schools. 10. Denied. Respondent denies that it is in the children's best interest to attend school in the Northern York School District, specifically South Mountain Elementary School. To the contrary, Respondent avers that it is in the children's best interest to return to the West Shore School District where Jeffrey A. Comman, Jr. has previously attended and where Mason W. Comman will be attending kindergarten with friends whom he has nude at a day care which he attended for several years. 11. Admitted. 12. Admitted in part and denied in part. It is admitted that Respondent is dissatisfied; however, it is due to the dissatisfaction of Petitioner's failure to adhere to the agreement of the parties that the children would be enrolled in the West Shore School District. 13. The averment in Paragraph 13 is solely within the knowledge of Petitioner, and proof thereof is demanded. 14. Admitted in part and denied in part. It is admitted that Respondent is not agreeable to the children continuing their enrollment at South Mountain Elementary School; however, it is denied that she enrolled the children in her school district without the agreement of Petitioner. To the contrary, the parties agreed that at the conclusion of the 2000/2001 academic year, the children would attend school in Respondent's district. Furthermore, Respondent notified Petitioner in July, 2001, of the enrollment, to which Petitioner did not object. 15. Denied. Respondent avers that Petitioner has explained that his work schedule is not flexible. 16. Denied. It is denied that it is not the best interest the minor children be moved from South Mountain Elementary School. 17. Denied. It is denied that, should Respondent be permitted to enroll the children in West Shore School District, this will be the 4th school district Jeffrey A. Cornman, Jr. has attended. To the contrary, the parties' minor child has predominantly attended school in the West Shore School District, except for a brief period when their son attended East Pennsboro Elementary School after both parties moved from their residence after their separation and when Jeffrey A. Comman, Jr. attended South Mountain Elementary School. 18. Admitted. 19. Denied. It is denied that Respondent, Amy L. Cornman, failed to comply with Paragraph #7 of the Court Order entered in January, 2001. To the contrary, Respondent and Petitioner agreed the children would attend school in Respondent's district upon completion of the 20W/2001 academic year. 20. Denied. It is denied that Respondent has lived in numerous residences since the parties separated. To the contrary, Respondent has moved twice, the same number of times that Petitioner, Jeffrey A. Cornman, Sr., has moved. 21. Denied. It is denied that the children have their own bedroom in Petitioner's home and it is denied that Petitioner has a 4-bedroom residence. To the contrary, the children share a bedroom in Petitioner's 3-bedroom home. 22. Denied. It is denied that Petitioner is better able to provide a stable home for his children. 23. The averment in Paragraph 23 is solely within the knowledge of Petitioner. After reasonable investigation, Respondent is unable to form an opinion as to the truth or falsity of the averment and therefore the same is denied and proof thereof is demanded. 24. Denied. It is denied that Respondent is not considering the best interests of the minor children. To the contrary, her efforts are based on the best interest of the minor children and the parties' understanding that the children would attend school in the West Shore School District. 25. No responsive pleading is required. WHEREFORE, Respondent respectfully requests that this Honorable Court deny Petitioner's Petition for Emergency Relief. NEW MATTER 26. Paragraphs 1 through 25 above are incorporated herein by reference. 27. Respondent avers that during the custody conciliation process in January, 2001, the parties agreed that after the conclusion of the 2000/2001 academic year, the children would no longer be enrolled in South Mountain Elementary School. 28. Respondent avers that Petitioner caused her to believe that Petitioner was moving to live within the West Shore School District at the conclusion of the 2000/2001 school year. 29. Respondent avers that during the custody conference, Petitioner was advised to move within or near the West Shore School District. 29. Paragraph 8 of the Custody Order entered January 11, 2001, states that "the minor child, Jeffrey A. Cornman, Jr., shall remain in school in the Northern York school district at least for the conclusion of the 2000/2001 school year" and therefore entertains the agreement of the parties that the children would then be enrolled in the West Shore School District 30. Pursuant to the parties' agreement, Respondent, Amy L. Comman, notified Petitioner, Jeffrey A. Cornman, Sr. in July, 2001, that she enrolled the minor children in the West Shore School District for the current, 2001/2002, academic year. 31. The first day of classes in the West Shore School District begins Monday, August 27, 2001. 32. Petitioner, Jeffrey A. Cornman, Sr,. did not object to the enrollment of the children until August 22, 2001, when, only three business days prior to the first day of school, he filed the instant Petition for Emergency Relief. 33. The parties' minor child, Jeffrey A. Common, Jr,. attended kindergarten and V2 of I st grade and %: of 2nd grade in the West Shore School District. 34. Jeffrey A. Cornman, Jr. attended V2 of 1st grade and 1/2 of 2nd grade at East Pennsboro Elementary School after both parties separated and neither party lived within West Shore School District. 35. Jeffrey A. Cornman, Jr. has friends in the West Shore School District. 36. Mason W. Common has attended a day care which is across the street from Respondent's residence for several years and would attend kindergarten at West Shore School District with the same group of children. 37. Respondent altered her work schedule in anticipation of the children attending the West Shore School District so that her hours correspond to the children's school day. WHEREFORE, Respondent respectfiilly requests that this Honorable Court denied Petitioner's Petition for Emergency Relief. Dated: 41 d/ Respectfully submitted, Y-Z. If Christine J. T r, Esquire WILEY, LE X, COLG CCO, P.C. 1 South Baltimore Street Dillsburg, PA 17019 (717) 432-9666 I.D. #82204 CERTIFICATE OF SERVICE I, Christine J. Taylor, Esquire hereby certify that I am this day serving a copy of the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States mail, first-class, postage prepaid, as follows: Arthur K. Dils 1017 North Front Street Harrisburg, PA 17102 (Attorney for Defendant/Petitioner) Dated: Z de Christine 7. TayX I WILEY, LENOY, COl 1 South Baltimore S Dillsburg, PA 17019 (717) 432-9666 I.D. #82204 P.C. VERIFICATION ) an verify that the statements made in this document are true and correct to the best of my knowledge, information, and belief I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unworn falsification to authorities. Date: LCW) - dwky?r,5n?a - ®?s??a.ana3-sa??€si.??: .- .. -' - ?6a4 _ ? _.. ?? _ .___ ?_?. -'"' "`-- n 4r'? ? 1 ?. _ r ? ?? . ? +s _ ?y%. 1J >, r N J ? ? . ? ? t. _. _ _? _ ?,? CC ATTORNEYS AT LAW 1017 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102 ARTHUR K. DILS DIANE M. RUPICH August 24, 2001 The Honorable Edgar B. Bayley Cumberland County Court House One Court House Square Carlisle, PA. 17013 RE: Amy L. Cornman, Respondent vs. Jeffrey A. Cornman, Sr., Petitioner No. 00-8358 Civil Action - Custody Dear, Judge Bayley: PHONE: (717) 233-8743 FAX: (717) 233-2567 On Friday, August 24, 2001, Attorney Christine J. Taylor called my office concerning the above captioned matter pending before your Honorable Court, we discussed the issues for approximately forty minutes. It was suggested that Attorney Taylor indicate to the Court that she was representing the mother, Amy L. Cornman, as she had indicated she called your chambers this date, and you were unavailable. I have reviewed the fax of the Respondent's attorney's Answer and must vehemently dispute the allegation that the parties agreed the children would enroll in the West Shore School District at the conclusion of the 2000/2001 school year. This was not in your Court Order. In addition, it was provided that if there w9Ao be a change in your Honorable Court's Order, that either party would file for modification, which the mother, Amy L. Cornman did not do. Lastly, t,he;mo'ther, Amy L. Cornman, went to the school in which the minor child, Jeffrey, is currently enrolled and indicated to the school authorities that she had full and primary physical custody of the child and was legally able to obtain the child's records and enroll the child elsewhere. -2- Basically, it is felt that the problem is a matter of transportation and my client has offered and agreed to assume all transportation responsibility. This was indicated in the telephone conference with Attorney Taylor. Your Honor, it was indicated to counsel for the mother that the present arrangement is working and that considering the best interest of the children, that there should be no disruption of the joint physical custody. The parties have been exchanging the children on a weekly basis; one week with the mother; one week with the father. It was explained to counsel for the mother that this arrangement has been working and has been held by our Superior Court, "if it ain't broke, why should we attempt to fix it." Very truly yours, Arthur K. Dils AKD cc: Christine J. Taylor, Esquire AMY L. CORNMAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JEFFREY A. CORNMAN, SR. DEFENDANT 00-8358 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 4th day of December , 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on the 5th day of January, 2001 , at 8:30 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 THE COURT, By: /s/ Hubert X Gilroy, Esq? Custody Conciliator 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 HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 Merl' r ? 0TARY F. DD DEC ?k, F 3: 3a CUivt?E???1?VCONT? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA AMY L. CORNMAN, * NO. 00 - ?35? l: lv?C ? Plaintiff VS. * CIVIL ACTION - LAW * COMPLAINT IN CUSTODY JEFFREY A. CORNMAN, SR., Defendant ORDER OF COURT AND NOW, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before the conciliator, at on the day of 2_, at in., 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 THE COURT, by: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA AMY L. CORNMAN, Plaintiff * NO. OV X 3 5"? (GrU T. w * * * CIVIL ACTION - LAW * COMPLAINT IN CUSTODY * * VS. JEFFREY A. CORNMAN, SR., Defendant COMPLAINT FOR CUSTODY AND COMES NOW, AMY L. CORNMAN, by her attorney, Timothy J. Colgan, Esq., and files the following Petition: 1. Plaintiff, AMY L. CORNMAN, resides at 614 State Street, Lemoyne, Cumberland County, Pennsylvania since October of 1999. 2. Defendant, JEFFREY A. CORNMAN, SR., resides at 10 Mountain Road, Dillsburg, York County, Pennsylvania since August of 2000. 3. Plaintiff and Defendant are the natural parents of two minor children, Jeffrey A. Cornman, Jr., D.O.B. 05/28/92; and Mason W. Comman, D.O.B. 01/02/96. 4. The children were not born out of wedlock. 5. Jeffrey A. Cornman, Jr., currently resides with the Defendant at 10 Mountain Road, Dillsburg, PA since June of 2000; from Dec. 1999 to June 2000, Jeffrey A. Cornman, Jr., resided at 614 State Street, Lemoyne, PA; from October of 1998 to December of 1999, Jeffrey A. Cornman, Jr., resided at 182 Ashford Drive, Enola, PA; and prior to December of 1999, Jeffrey A. Cornman, Jr., resided at 440 Herman Avenue, Lemoyne, PA with both parents. 6. Mason W. Cornman currently resides with the Plaintiff at 614 State Street, Lemoyne, PA; from October 1998 to December of 1999 Mason W. Comman resided at 182 Ashford Drive, Enola, PA; and prior to December of 1999, Mason W. Comman, resided at 440 Herman Avenue, Lemoyne, PA with both parents. 7. There are no court orders establishing custody or visitation. 8. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 9. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 10. The best interest and permanent welfare of the children will be served by granting the relief requested herein. WHEREFORE, Plaintiff requests the Court enter an Order granting primary physical custody and shared legal custody of the minor child to Plaintiff. Respectfully submitted, Dated: I1 - 7 - 00 Timothy J. C an e WILEY, LENOX, COLGAN & MARZZACCO, P.C. 1 South Baltimore Street Dillsburg, PA 17019 (717) 432-9666 I.D.#77944 C: I SERVER-II SERVERICLIENTSICOLG"CORNAMMCUST.PET NOU-07-2000 15:13 FROM:WILEY LENOX COLGAN 7174320426 TC:717 671 5240 P.006/006 VERIFICATION 1, AMY L. CORNMAN, verify that the statements made in this document are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: ///-7 In 2 L. CO N PlaintilT Cr ?.SERVRR- MER VERICI,lEMS7COLOAN?CORNMAMCItST.Ph,T 7174320426 PAGE-06 NOU 07 2020 15:22 JAN v AMY L. CORNMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW JEFFREY A. CORNMAN, SR., NO.00 - 8358 CIVIL Defendant IN CUSTODY COURT ORDER AND NOW, this 11?- day of January, 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Amy L. Cornman, and the Father, Jeffrey A. Cornman, Sr., shall enjoy shared legal and shared physical custody of Jeffrey A. Cornman, Jr., born May 28, 1992; and Mason W. Cornman, born January 2, 1996. 2. The parties shall work out a physical custody schedule on a week on/week off basis. Unless the parties agree otherwise, exchange of custody shall take place every Sunday at 6:00 p.m. 3. The parties shall also work out an arrangement whereby they share or alternate major holidays. 4. During the summer months, it is anticipated that there will continue to be a sharing of custody with the parties having the ability to modify the week on/week off schedule to a schedule that provides longer periods of time than the fall and winter months. 5. Both parents shall enjoy reasonable telephone contact with the minor children while they are in the other parent's custody. 6. Both parents shall keep the other parent informed with respect to telephone numbers and addresses for the children if the children are ever out of the Central Pennsylvania area. 7. This Order is entered pursuant to an agreement reached by the parties at a Custody Conciliation Conference. In the event either party desires to modify this Order, that party may petition the Court to have the case again scheduled with the Custody Conciliator. 8. This Order is entered with the understanding that the minor child, Jeffrey A. Comman, Jr., shall remain in school in the Northern York school district at least for the conclusion of the 2000/2001 school year. cc: Timothy J. Colgan, Esquire Bruce F. Bratton, Esquire 6?5 01 -11-61 ??, ?, ,. y-" l /? C .? _ i q??'P?i"§e?rra=fi:d:uYt¢mc W:;e EIF Iii AMY L. CORNMAN, Plaintiff v JEFFREY A. CORNMAN, SR., Defendant Prior Judge: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO.00 - 8358 CIVIL : IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Jeffrey A. Comman, Jr., born May 28, 1992; and Mason W. Cornman, born January 2, 1996. 2. A Conciliation Conference was held on January 5, 2001, with the following individuals in attendance: The Mother, Amy L. Comman, with her counsel, Timothy J. Colgan, Esquire; and the Father, Jeffrey A. Comman, Sr., with his counsel, Bruce F. Bmtton, Esquire. 3. The parties agree to the entry of an order in the form as attached. f ?( (;?? k?? ??t ATE Hubert X. Gilroy, E re Custody Conciliate AMY L. CORNMAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JEFFREY A. CORNMAN, SR. DEFENDANT 00-8358 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Friday, August 24, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, October 04, 2001 at 9:30 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. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilroy Esq.? Custody Conciliator 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 HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 Oi c PENIVSYi t IA 4 AMY L. CORNMAN, Plaintiff VS. JEFFREY A. CORNMAN, SR., Defendant AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before the Conciliator, at on IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.00-8358 CIVIL ACTION - LAW CUSTODY ORDER OF COURT at _.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 THE COURT: BY: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 AMY L. CORNMAN, Plaintiff VS. JEFFREY A. CORNMAN, SR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-8358 CIVIL ACTION - LAW CUSTODY COMPLAINT TO MODIFY COURT ORDER DATED JANUARY 11, 2001 AND NOW, this 4-)-- day of August 2001, comes Jeffrey A. Cornman, Sr., by his attorney Arthur K. Dils, Esquire, and respectfully requests the following: 1. The Defendant, Jeffrey A. Cornman, Sr., is an adult individual who currently resides at 10 Mountain Road, Dillsburg, York County, Pennsylvania 17019. 2. The Plaintiff above named, Amy L. Cornman, is an adult individual who currently resides at 614 State Street, Lemoyne, Cumberland County, Pennsylvania 17043. 3. The above-named parties are the natural parents of two children; namely: Jeffrey A. Cornman, Jr., born May 28, 1992, and Mason W. Cornman, born January 2, 1996. 4. Attached hereto and marked Exhibit "A" is a Court Order dated January 11, 2001, which sets forth the custody arrangements of the minor children between Amy L. Cornman and Jeffrey A. Cornman, Sr. 2 5. Simultaneously with the filing of this Complaint, the Defendant, Jeffrey A. Cornman, Sr., has filed a Petition for Emergency Relief with your Honorable Court. 6. The Plaintiff, Amy L. Cornman, is in violation of the Court Order dated January 11, 2001, in that she is attempting to modify this Order, without agreement between the parties, in that, she has registered the minor children for school in her school district, said school to commence the week of August 27, 2001. 7. The Plaintiff, Amy L. Cornman, has failed to file a Petition with the Court pursuant to Paragraph 7 of said Court Order for the purpose of modification of the Court Order and for the purpose of reaching an agreement as to what school the minor children should attend for the 2001-2002 school year. 8. The Defendant, Jeffrey A. Cornman, Sr., is agreeable with the Court Order as it stands concerning shared physical and shared legal custody; however, if the Plaintiff, Amy L. Cornman, is not agreeable that the minor children continue to attend the South Mountain Elementary School in Dillsburg, Pennsylvania, it is respectfully requested that he be granted primary physical custody of the children. 9. It is in the best interest of the children that they attend the South Mountain Elementary School in Dillsburg, Pennsylvania. 3 10. It is in the best interest of the minor children that primary physical custody be granted to the Defendant, Jeffrey A. Cornman, Sr., in that the Defendant is better able to provide a stable environment for the children. 11. In addition, the minor children have a sibling at the home of Jeffrey A. Cornman, Sr., namely, Madaline, sixteen (16) months old. WHEREFORE, the Defendant, Jeffrey A. Cormnan, Sr., respectfully prays your Honorable Court to modify the Court Order dated January 11, 2001, as set forth above. Respectfully submitted, BY: Wfi&j K. Dils, Esquire 1017 North Front Street Harrisburg, PA 17102 (717) 232-9724 I.D. No. 07056 Date:/ 4 AMY L. CORNMAN, plaintiff v JEFFREY A. CORNMAN, SR., Defendant IN hffl COURT OF COMMON PLEAS OF CUM$ERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 00 - 8358 CIVIL : IN CUSTODY AND NOW, this`?'Ylay of January, 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Amy L. Comman, and the Father, Jeffrey, A. Comman, Sr., shall enjoy shared legal and shared physical custody of Jeffrey A. Comman, Jr., born May 289 1992; and Mason W. Comman, born January 2,1996. 2. The parties shall work out a physical custody schedule on a week onlweek off basis. Unless the parties agree otherwise, exchange of custody shall take place every Sunday at 6:00 p.m. 3. The parties shall also work out an arrangement whereby they share or alternate major holidays. 4. During the summer months, it is anticipated that there will continue to be a sharing eP owtatar with thr trwOes bevkw alts ebift to ntaditV dw w"k @Wwwb off schedule to a schedule that provides longer periods of time than the fall and winter months. 5. Both parents shall enjoy reasonable telephone contact with the minor children while y - they are in the other parent's custody. 6. Both parents shall keep the other parent informed with respect to telephone numbers and addresses for the children if the children are ever out of the Central Pennsylvania area 7. This Order is entered pursuant to an agreement reached by the parties at a Custody Conciliation Conference. In the event either party desires to modify this Order, that party may petition the Court to have the case again scheduled with the Custody Conciliator. EXHIBIT "A" 8. This Order is entered with, the ? that the minor child, jeffrey A. Cormnan. Jr., shall remain in school in the Northern York school district at least for the conclusion of the 2000/2001 school year. BY THE COURT, J. or. Timothy J. Colgan, Esquire Bruce F. Bratton, Esquire TRITE COPY FROM RECORD in Testimony v:hsrcof, I here unto set my had and t seal of s id Court at Carlisle, Pa. , Thl ......I ?..... of.... Qa , Ailed) I Prothonotary VERIFICATION I verify that the statements made in this God^r1&A d `?' Cu rf ?-- J4 are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dat . l ?.G 2-°° , - c? lL CERTIFICATE OF SERVICE 1, Arthur K. Dils, Esquire, hereby certify that a true and correct copy of the within Complaint for Custody has been served upon the following individual by first class, United States mail, postage prepaid, by depositing same at the post office in Harrisburg, Pennsylvania, on the 21st day of August 2001, addressed as follows: Timothy J. Colgan, Esquire 1 South Baltimore Dillsburg, PA 17019 Date: August 21, 2001 Amy L. Cornman 614 State Street Lemoyne, PA 17043 Respectfully submitted, BY: Arthur K. Di s, Esquire 1017 North Front Street Harrisburg, PA 17102 (717) 232-9724 I.D. No. 07056 5 V v w ? C-:) 1 - tl -061, n G. Pv C i. r 11 v ? AMY L. CORNMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA V. IN CUSTODY JEFFREY A. CORNMAN, SR.,: Defendant/Petitioner NO. 00-8358 CIVIL TERM ORDER OF COURT AND NOW, this 30th day of August, 2001, this matter having been called on an emergency petition by Jeffrey A. Cornman, Sr., it is ordered, pending further order of court, Jeffrey A. Cornman, Jr., and Mason W. Cornman shall attend respectfully fourth grade and kindergarten in the South Mountain School District. The case shall proceed to conciliation on father's petition to modify the current shared custody arrangement. Pending any further order of court, all the provisions of the current order of July 11, 2001, shall be maintained. If the case proceeds to litigation, the entry of this emergency order shall not prejudice the mother to seek to have the order changed for the children to attend school in the West Shore School District. Christine J. Taylor, Esquire The Wiley Group One South Baltimore Street Dillsburg, PA 17019 For the Plaintiff/Respondent Arthur K. Dils, Esquire 1017 North Front Street Harrisburg, PA 17102 For the Defendant/Petitioner F,,36- 01 4- pcb f-'?-il\!?YI fit';/?+??iiH OCT toot AMY L. CORNMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW JEFFREY A. CORNMAN, SR., NO.00 - 8358 CIVIL Defendant IN CUSTODY COURT ORDER AND NOW, this - day of October, 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. This Court's prior Orders of January 11, 2001 and August 30, 2001 shall remain in effect subject to the following modifications: A. During the week the Mother has custody of the minor children, Father shall arrange to provide transportation to pick the children up in the morning prior to Mother going to work so that Father can take the children to school in the Dillsburg school district. During that same week, Mother shall pick the children up at approximately 4:45 p.m. each day for return of the children to her home, with the understanding there shall be a specific pick up location every Friday at Father's home. B. Both parties shall keep the other parent promptly advised with respect to all medical, educational and social issues relating to the children. The parties are directed to exchange all pertinent documentation with respect to school information and both parties are also directed to contact the other parent in advance to alert them with respect to scheduled doctors appointments, school conferences, major social activities involving the children and their families and other similar issues. C. Absent an agreement between the parties to the contrary, holidays shall be split equally with Mother enjoying custody of the two minor children for one half of the day and Father enjoying custody of the minor children for the other half of the day. The timeframes shall be from 9:00 a.m. until 3:00 p.m. and 3:00 p.m. until 9:00 p.m. unless the parties agree otherwise. However, the Christmas holiday shall continue to be handled as the parties did last year with the parties alternating Christmas afternoon and Christmas morning. I 2. This order is entered pursuant to an agreement reached by the parties at a custody conciliation conference. In the event either party desires to modify this order, that party may petition the court to have the case again scheduled for another custody conciliation conference with the conciliator. BYrE? Edgar B. Bayley cc: Arthur K. Dils, Esquire Christine Taylor, Esquire) iwuC /v- iS- ° / -:, q,_; k__'CE ?; ??_ ?JC)T4NY 01 OCT 15 fail {O* 55 CU PENNSYLVANIA AMY L. CORNMAN, Plaintiff v JEFFREY A. CORNMAN, SR., Defendant Prior Judge: Edgar B. Bayley IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.00 - 8358 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Jeffrey A. Cornman, Jr., born May 28, 1992; and Mason W. Cornman, born January 2, 1996. 2. A Conciliation Conference was held on October 4, 2001, with the following individuals in attendance: The Mother, Amy L. Cornman, with her counsel, Christine Taylor, Esquire; and the Father, Jeffrey A. Comman, Sr., with his counsel, Arthur Dils, Esquire. 3. The parties agree to the entry of an order in the form as attached. w DAT Hubert X. Gilroy, Es uire Custody Conciliat JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff AMY L. CORNMAN, Plaintiff vs. JEFFREY A. CORNMAN, SR., Defendant THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 00-8358 CIVIL ACTION - AT LAW CUSTODY TO THE HONORABLE EDGAR B. BAYLEY, JUDGE OF SAID COURT: PLAINTIFF'S EMERGENCY PETITION TO MODIFY CUSTODY ORDER AND NOW, comes Plaintiff, Amy L. Cornman, by and through her attorney, Jeanne B. Costopoulos, Esquire, and files the within Emergency Petition to Modify Custody Order, to which she avers the following: 1. Petitioner, Plaintiff above, is Amy L. Cornman, (hereinafter referred to as Mother) an adult individual currently residing at 1010 Houck Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Respondent, Defendant above, is Jeffrey A. Cornman, Sr. (hereinafter referred to as Father), an adult individual currently incarcerated in the Cumberland County Prison, 1101 Claremont Road, Carlisle, Cumberland County, Pennsylvania. 3. The parties are the natural parents of two (2) minor children, Jeffrey A. Cornman, Jr., born May 28, 1992, and Mason W. Cornman, born January 2, 1996 (hereinafter referred to as the children). 1 4. The parties previously entered into Agreements regarding custody and the parties are subject to court orders dated January 11, 2001, August 30, 2001, and October 15, 2001. Said Orders are attached hereto as Exhibits A, B, & C which are incorporated herein by reference as though fully set forth. 5. The current Orders provides for shared legal custody as well as shared physical custody on week-on, week-off basis. 6. Mother seeks modification of physical custody such that she is granted temporary primary physical custody with Father having partial custody at such times as can be mutually agreed upon between the parties. 7. The children's best interest would best be served by granting Mother primary physical custody of the children for the following reasons: a. Father was arrested on March 31, 2007 in New Cumberland for a 2°d offense DUI and related charges docketed at CP-21-CR-0002353-2007. b. Father surrendered his driver's license and was sentenced before the Honorable M. L. Ebert on March 14, 2008 at which time he was remanded to the Cumberland County Prison. C. It is anticipated that Father will be incarcerated between 30 to 90 days, after which he is expected to remain on house arrest. d. Father did not inform Mother that he had been arrested for DUI or that he was sentenced to jail. 2 e. Father has been pretending that he is home in an effort to hide from Mother the fact that he is in jail. f. Father has inappropriately involved the children in his deception in that he has told them not to tell Mother about his situation, placing the children in the uncomfortable position of either disappointing their father or hiding the truth from their mother. g. Normally, the children walk to Father's house after school where Mother picks them up during her custodial weeks. Since Father's incarceration, the children have been locked out of Father's house so they've either waited outside for Mother to pick them up or else gone to a friend's house to wait for Mother. h. The children do not want to go to Father's residence during Father's periods of custody, especially since he is not present because he is in jail. Prior to Father's incarceration, the children had been showing signs of reluctance to go to his house due to the instability of Father's household where they were exposed to constant arguing between Father and his girlfriend, emotional abuse, physical discipline with a belt, and the general anxiety that naturally flows from residing in an unstable household in which the adults have addiction problems. Due to the above issues, from October of 2007 to early February of 2008 the parties' younger son did not accompany his older brother during Father's custodial weeks. Also, the parties' older son slept on a mattress 3 on the concrete in Father's basement until Mother gave Father furniture to make her son more comfortable when in Father's custody. k. On Friday, March 28, 2008, Mother found out that Father was in jail for DUI and the children have remained in her custody since that time. WHEREFORE, Plaintiff respectfully requests this Honorable Court to grant her immediate primary physical custody of the children. Respectfully Submitted: By: NE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 11 T Telephone No. (717) 221-0900 Date: Attorney for Plaintiff VERIFICATION I, Amy L. Cornman, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. r/ 1 Date: 7 d?? J Amy L C an CERTIFICATE OF SERVICE I, Jeanne B. Costopoulos, Esquire, hereby certify that this day I personally served a copy of the foregoing document upon the person, and in the manner, indicated below, which service satisfies the requirements of the PA Rules of Civil Procedure, by depositing a copy of the same with the United States Post Office at Mechanicsburg, Pennsylvania, through first class mail, prepaid, and addressed as follows: Jeffrey A. Cornman, Sr. c/o Cumberland County Prison 1101 Claremont Road Carlisle, PA 17013 By: J NE B. COSTOPOUL , SQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Date: ( .? v fiI.BIT ?. E AMY L. CORNMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW JEFFREY A. CORNMAN, SR_, : NO.00 - 8358 CIVIL Defendant : IN CUSTODY COURT ORDER AND NOW, this day of January, 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Amy L. Comman, and the Father, Jeffrey A. Cornman, Sr., shall enjoy shared legal and shared physical custody of Jeffrey A. Cornman, Jr., born May 28, 1992; and Mason W. Comman, born January 2,1996. 2. The parties shall work out a physical custody schedule on a week on/week off basis. Unless the parties agree otherwise, exchange of custody shall take place every Sunday at 6:00 p.m. 3. The parties shall also work out an arrangement whereby they share or alternate major holidays. 4. During the summer months, it is anticipated that. there. will continue to be a sharing of custody with the parties having the ability to modify the week on/week off schedule to a schedule that provides longer periods of time than the fall and winter months. 5. Both parents shall enjoy reasonable telephone contact with the minor children while they are in the other parent's custody. 6. Both parents shall keep the other parent informed with respect to telephone numbers and addresses for the children if the children are ever out of the Central Pennsylvania area 7. This Order is entered pursuant to an agreement reached by the parties at a Custody Conciliation Conference. In the event either party desires to modify this Order, that party may petition the Court to have the case again scheduled with the Custody Conciliator. . 8. This Order is entered with the understanding that the minor child, Jeffrey A. Cornman, Jr., shall remain in school in the Northern York school district at least for the conclusion of the 2000/2001 school year. BY THE COURT, 11 Q- cc: Timothy J. Colgan, Esquire Brace F. Bratton, Esquire TRUE COFY? FROM RECORD In 'Casfiimotiy whQrQ6 there unto. set my hand and seal of sa(d our at Car iisi Pa. 7h ll.,. •, y AMY L. CORNMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v JEFFREY A. CORNMAN, SR., Defendant Prior Judge: : CIVIL AC11ON - LAW : NO.00 - 8358 CIVIL : IN CUSTODY CONCILL4,UON_CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Jeffrey A. Cornman, Jr., born May 28, 1992; and Mason W. Cornman, born January 2, 1996. 2. A Conciliation Conference was held on January 5, 2001, with the following individuals in attendance: The Mother, Amy L. Cornman, with her counsel, Timothy J. Colgan,. Esquire; and the Father,.Jeffrey A. Cornman, Sr., with his counsel, Bruce F. Bmatton, Esquire. 3. The parties agree to the entry of an order in the form as attached. 0 15ATE Hubert X. Gilroy, 4411ire Custody Concili r iT B I3iB E AMY L. CORNMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA v. . JEFFREY A. CORNMAN, SR.,: Defendant/Petitioner . IN CUSTODY NO. 00-8358 CIVIL TERM ORDER OF COURT AND NOW, this 30th day of August, 2001, this matter having been called on an emergency petition by Jeffrey A. Cornman, Sr., it is ordered, pending further order of court, Jeffrey A. Cornman, Jr., and Mason W. Cornman shall attend respectfully fourth grade and kindergarten in the South Mountain School District. The case shall proceed to conciliation on father's petition to modify the current shared custody arrangement. Pending any further order of court, all the provisions of the current order of July 11, 2001, shall be maintained. If the case proceeds to litigation, the entry of this emergency order shall not prejudice the mother to seek to have the order changed for the children to attend school in the West Shore School District. Christine J. Taylor, Esquire The Wiley Group One South Baltimore Street Dillsburg, PA 17019 For the Plaintiff/Respondent Arthur K. Dils, Esquire 1017 North Front Street Harrisburg, PA 17102 For the Defendant/Petitioner P-3b- 01 4' pcb .IT C EX I r ' 9 1 200n AMY L. CORNMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v JEFFREY A. CORNMAN, SR., Defendant : CIVIL ACTION - LAW NO. 00 - 8358 CIVIL IN CUSTODY COURT ORDER AND NOW, this /;6' day of October, 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: This Court's prior Orders of January 11, 2001 and August 30, 2001 shall remain in effect subject to the following modifications: A. During the week the Mother has custody of the minor children, Father shall arrange to provide transportation to pick the children up in the morning prior to Mother going to work so that Father can take the children to school in the Dillsburg school district. During that same week, Mother shall pick the children up at approximately 4:45 p.m. each day for return of the children to her home, with the understanding there shall be a specific pick up location every Friday at Father's home. B. Both parties shall keep the other parent promptly advised with respect to all medical, educational and social issues relating to the children. The parties are directed to exchange all pertinent documentation with respect to school information and both parties are also directed to contact the other parent in advance to alert them with respect to scheduled doctors appointments, school conferences, major social activities involving the children and their families and other similar issues. C. Absent an agreement between the parties to the contrary, holidays shall be split equally with Mother enjoying custody of the two minor children for one half of the day and Father enjoying custody of the minor children for the other half of the day. The timeframes shall be from 9:00 a.m. until 3:00 p.m. and 3:00 p.m. until 9:00 p.m. unless the parties agree otherwise. However, the Christmas holiday shall continue to be handled as the parties did last year with the parties alternating Christmas afternoon and Christmas morning. 2. This order is entered pursuant to an agreement reached by the parties at a custody conciliation conference. In the event either party desires to modify this order, that party may petition the court to have the case again scheduled for another custody conciliation conference with the conciliator. BY THE COURT. S J. .,d ar B. B yley cc: Arthur K. Dils, Esquire Christine Taylor, Esquire R1611 c TNG Yfro€ha G?n6 r4 t AMY L. CORNMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v JEFFREY A. CORNMAN, SR., Defendant Prior Judge: Edgar B. Bayley : CIVIL ACTION - LAW NO. 00 - 8358 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the children who are the subject of this litigation is as follows: Jeffrey A. Cornman, Jr., born May 28, 1992; and Mason W. Cornman, born January 1996. 2. A Conciliation Conference was held on October 4, 2001, with the following individuals in attendance: The Mother, Amy L. Cornman, with her counsel, Christine Taylor, Esquire; and the Father, Jeffrey A. Cornman, Sr., with his counsel, Arthur Dils, Esquire. 3. The parties agree to the entry of an order in the form as attached. DAT Hubert X. Gilroy, VEsuire Custody Conciliat A AMY L. CORNMAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2000-8358 CIVIL ACTION LAW JEFFREY A. CORNMAN, SR. . IN CUSTODY DFFF.NDANT ORDER OF COURT AND NOW, Monday, April 14, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at_ 4th Floor, Cumberland County Courthouse, Carlisle on _ Thursday, May 22, 2008 _ at 9:30 AM 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. Failure to appear at the conference may provide grounds for entrv of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilroy, Es q. Custody Conciliator 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 HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 to, j JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff AMY L. CORNMAN, THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 00-8358 JEFFREY A. CORNMAN, SR., Defendant CIVIL ACTION - AT LAW CUSTODY STIPULATION FOR AN AGREED ORDER OF CUSTODY AND NOW, come the parties, Amy L. Cornman, Plaintiff, and Jeffrey A. Cornman, Sr., Defendant, and respectfully request the following Stipulation to be entered as an Order of Court: WHEREAS the parties, Amy L. Cornman (Mother hereinafter) and Jeffrey A. Cornman, Sr. (Father hereinafter), have born to them two (2) children, namely Jeffrey A. Cornman, Jr., born May 28, 1992, and Mason W. Cornman, born January 2, 1996 (children hereinafter); and, WHEREAS, the parties are subject to prior Order of Court dated January 11, 2001, August 30, 2001, and October 15, 2001. WHEREAS, both parties desire to temporarily modify the physical custody arrangements for the children; and WHEREAS, both parties have been provided an opportunity to review this Stipulation with counsel prior to signing. THEREFORE, in consideration of the mutual covenants, promises, and agreements as 1 V- hereinafter set forth, and intending to be legally bound, the parties agree as follows: A. Effectively immediately, Mother shall have primary physical of the children subject to periods of partial custody with Father on alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m. Father's first weekend shall begin on Friday, May 3, 2008. During this time, Father shall reimburse Mother $100.00 per week for increased transportation costs associated with Father's driver's license suspension. B. Beginning on June 13, 2008 or on the first Friday following Father being released from house arrest, whichever is later, the parties' prior shared custody arrangement shall resume wherein custody is exchanged on an alternating weekly basis. During Father's driving suspension, it is anticipated that Mother will transporting the children more often than usual. Therefore, during this time and until Father's driving privileges are reinstated, Father shall pay Mother the sum of $50.00 per week towards her increased fuel costs. C. In the event Father relocates from the Northern York School District, the custody schedule set forth in Paragraph A shall be reinstated until further order of court and the children shall attend school in the school district in which Mother resides. D. Under no circumstances shall Father permit the children to be in contact with Father's ex-girlfriend, Nicole Frederick. E. During any period of custody or visitation, the parties shall not possess or use any 2 controlled substance; neither shall they consume alcoholic beverages to the point of intoxication. F. Father agrees to pay Mother 50% of the following costs within thirty (30) days of receiving receipts from Mother that said expenses were incurred and paid: 1) All un-reimbursed medical expenses; 2) All costs associated with the children's extracurricular sporting activities; 3) All costs of the children's school supplies; 4) All costs of the children's clothing. This paragraph shall become null, void, and unenforceable in the event Mother files a child support claim against Father. G. Each party acknowledges that this Stipulation has been entered into by his or her own volition, with full knowledge of the facts and full information as to his or her legal rights, each party having been provided ample opportunity to discuss with his or her independent legal counsel of the effect of the terms of this Custody Stipulation and that each believes this Custody Stipulation to be reasonable and in the best interest of the children under the circumstances and not the result of any duress or undue influence. H. It is the intention of the parties that this Custody Stipulation may be entered as an Order of Court, as if a full hearing had been held thereon and enforced pursuant to 3 the provisions of the Uniform Child Custody Jurisdiction and Enforcement Act. IN WITNESS THEREOF, and intending to be legally bound thereby, the parties hereto have hereunto set their hands and seals and the date of their acknowledgment. r Date: 6;q Date- 447 Jeanne ti. k?ostopouios, tsquire Date:z/- 2!-- c) Signature: L e ?IKXA' . Cornman, Sr. Date: Signature: WITNESS: Print name of witness 4 ??? ?. v> •.? _? +{ t?., _,, - ?, -_• s4._I .,. .? ... ?,?. ...y. MAY o a aoCAr AMY L. CORNMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW JEFFREY A. CORNMAN, NO. 2000-8358 Defendant IN CUSTODY COURT ORDER AND NOW, this Jam` day of May, 2008, the Conciliator being advised the parties have reached an agreement, the Conciliator relinquishes jurisdiction. Hubert X. Gilr , Esquire Custody Co iliator 'VN`stA1ASN AiNnor ?,t?,q38 Z 1=8 WV 9- AN MOZ AdViONQ?? .40 MY86zwa8 AMY L. CORNMAN, THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 00-8358 JEFFREY A. CORNMAN, SR., CIVIL ACTION - AT LAW Defendant CUSTODY ORDER OF COURT AND NOW, this day of , 2008, upon consideration of the within STIPULATION FOR CUSTODY, which is inc rporated herein by reference, IT IS HEREBY ORDERED AND DECREED that the contents of said Stipulation are hereby adopted as an Order of Court with full weight and effect as if they had been set forth in full hereinafter. Insofar as this Courts prior orders of January 11, 2001, August 30, 2001, and October 15, 2001 do not conflict with the within Stipulation for Custody, their terms shall remain in effect. B (THE COUR J. sad C) 4 i- F 0- i EL co C`.,'1 o ? N z CJ G ?cl m