HomeMy WebLinkAbout03-2094VICTOR K. TAYLOR,
Plaintiff
V.
PAULA J. TAYLOR,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
03. -zAIN
NO. CIVIL TERM
IN CUSTODY
COMPLAINT FOR CUSTODY
1. Plaintiff is Victor K. Taylor, an adult individual currently residing at 619 Glenn
Street, Shippensburg, Cumberland County, Pennsylvania.
2. Defendant is Paula J. Taylor, an adult individual currently residing at 76 Carpenter
Lane, Newburg, Cumberland County, Pennsylvania.
3. The parties are the natural parents of one child, namely, Victor Kyle Taylor, born
February 20, 1992.
The child was not born out of wedlock.
4. For the past five (5) years, or since the children's birth, the children have resided with
the following persons at the following addresses for the following periods of time:
NAME ADDRESS DATES
Victor K. Taylor
Paula J. Taylor
Paula J. Taylor
619 Glenn Street
Shippensburg, PA
76 Carpenter Lane
Shippensburg, PA
76 Carpenter Lane
December 1, 2002
to present
December 1, 2002
to present
November 1, 2002
to December 1, 2002
Victor K. Taylor
Paula J. Taylor
76 Carpenter Lane
Shippensburg, PA
birth to
November 1, 2002
The natural mother of the children is Paula J. Taylor who resides as aforesaid.
She is married.
The natural father of the children is Victor K. Taylor who resides as aforesaid.
He is married.
5.
6.
7.
8.
9.
The relationship of the Plaintiff to the child is that of natural father. The Plaintiff
currently resides with the minor child at issue on an alternating weekly basis and his
parents, Victor and Carole Taylor.
The relationship of the Defendant to the child is that of natural mother. Respondent
currently resides with the minor child on an alternating weekly basis.
The parties are not subject to any Order of Court concerning custody of their child,
although Plaintiff filed a Petition for Special Relief contemporaneously with the filign
of this Complaint, requesting primary legal and shared physical custody of the child.
Plaintiff has no information of any custody proceedings concerning the children
pending in any Court of this Commonwealth, other than the aforesaid Petition for
Special Relief.
It is in the best interest and permanent welfare of the children to grant the relief
requested because:
a.) Since approximately December 1, 2002, the parties have exercised shared physical
custody of the child on an alternating weekly basis, exchanging custody of the child
on Sundays;
b.) Plaintiff began his weekly custody period with the child on Sunday, April 27, 2003, at
which time the child indicated to Plaintiff that he was suffering from a severe
headache, had little appetite and felt generally "dazed;"
C.) Following school on Monday, April 28, 2003, the child returned to Plaintiff's home
and exhibited extreme argumentative behavior, was not focused properly on tasks at
hand, and complained that he continued to suffer from a severe headache;
d.) Plaintiff took the child to the family physician, Dr. Thomas Steinour, on Tuesday,
April 29, 2003, whereupon the child revealed to the doctor that his mother gave him
medication the prior week, for purposes of controlling Attention Deficit Disorder,
which medication was prescribed by Dr. Michael Grossberg, a pediatric physician
located in the Chambersburg area;
e.) Plaintiff was completely unaware that Defendant provided medication to the child;
f.) Plaintiff was not consulted for purposes of a new evaluation with a new physician,
Dr. Grossberg, to evaluate the child for Attention Deficit Disorder and prescription
medication to control such a disorder;
g.) The child's family physician discovered that the child suffered a negative reaction to
the medication prescribed by Dr. Grossberg, and, further, that the child suffered from
a medical condition, a sinus infection, which was exacerbated by the Attention Deficit
Disorder medication and, therefore, discontinued the child's use of such medication;
h.) Dr. Steinour has provided medical services and treatment to the child for
approximately three years;
i.) The child has been evaluated at least two times since approximately 2002, for
purposes of discovering whether the child's academic and behavioral difficulties were
the result of Attention Deficit Disorder;
j.) Both evaluations ruled out the possibility of the child suffering from Attention Deficit
Disorder, and, instead, it was discovered that the child suffered from a learning
disability;
k.) Following the second psychoeducational evaluation, school personnel, Plaintiff and
Defendant implemented a comprehensive plan to address the child's academic and
behavioral issues;
1.) Said plan did not include the use of medication;
m.) Plaintiff believes and, therefore, avers that Defendant's attempts to medicate the child
have not been taken with the child's best interests in consideration;
n.) Plaintiff believes and, therefore, avers, that Defendant's medication of the child
without Plaintiff's knowledge or consent, and without the knowledge or consent of
the prior evaluators or the child's family physician have placed the child's physical
health in jeopardy and have disrupted his educational progress;
o.) Plaintiff provides health insurance coverage for the child;
p.) Defendant used the Plaintiff's insurance for purposes of the child's appointment and
medication with Dr. Grossberg;
q.) Defendant has, in the past, refused to share the costs of unreimbursed medical
expenses incurred for the child;
r.) Plaintiff is concerned that Defendant's continued abuse of health insurance will result
in extraordinary unreimbursed medical expense to the parties.
10. Plaintiff desires the entry of an Order of Court to provide the for Plaintiff to exercise
primary legal custody and for the parties to share physical custody of the child.
11. Plaintiff does not know any person not a party to these proceedings who claims to
have custody over visitation rights with respect to the children.
WHEREFORE, Plaintiff requests your Honorable Court to schedule a Custody
Conciliation Conference followed by a hearing at which time he should be granted primary legal
and shared physical custody of the child.
Respectfully submitted,
( il/l
cc
Mary ou atas, Esquire
Attorney r Plaintiff
f
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
VERIFICATION
I verify that the statements made in the foregoing document 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 falsifications to authorities.
DATE: 5///3 V r
" k 1??
VICTOR K. TAYLOR, Petitioner
" t J
,
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9
VICTOR K. TAYLOR, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
PAULA J. TAYLOR,
: NO. CIVIL TERM
Defendant/Respondent IN CUSTODY
PETITION FOR SPECIAL RELIEF
AND NOW, come Petitioner, Victor K. Taylor, by and through his counsel of record,
Marylou Matas, and petitions the Court as follows:
1. Petitioner is the above named Plaintiff, Victor K. Taylor, an adult individual currently
residing at 619 Glenn Street, Shippensburg, Cumberland County, Pennsylvania.
2. Respondent is the above named Defendant, Paula J. Taylor, an adult individual
currently residing at 76 Carpenter Lane, Newburg, Cumberland County,
Pennsylvania.
3. The parties are the natural parents of one child, namely, Victor Kyle Taylor, born
February 20, 1992.
4. Contemporaneously with filing this Petition for Special Relief, Petitioner has filed a
Complaint for Custody, requesting shared legal and primary physical custody of the
child at issue.
5. The parties separated on or about November 1, 2002.
6. Since approximately December 2002, the parties have exercised shared physical
custody of the child on an alternating weekly basis, exchanging custody of the child
on Sundays.
7. The child attends the fifth grade at Nancy Grayson Elementary School, of the
Shippensburg Area School District.
8. The child was evaluated previously by a psychiatrist, in 2002, whereupon it was
determined that the child did not meet diagnostic criteria as a student with Attention
Deficit Hyperactivity Disorder, and the possibility of administering medication to
control such disorder was eliminated.
9. On or about January 21, 2003, an second evaluation report was issued following the
child's psychoeducational evaluation due to concerns regarding his performance
across academic and behavioral areas. A copy of said evaluation report is attached
hereto and incorporated herein by reference as "Exhibit A."
10. Following said evaluation, it was determined that the child suffered from a learning
disability.
11. Based upon the discovery of the child's learning disability, various school personnel,
Petitioner and Respondent implemented a plan to provide the child with specialized
instruction for academic and behavioral areas.
12. Petitioner, Respondent and school personnel followed that plan from its
implementation through April 20, 2003.
13. Petitioner does not know whether school personnel continue to follow the plan as
originally implemented.
14. Petitioner believes that Respondent does not follow the plan as originally
implemented, for the reasons set forth below.
15. Petitioner began his weekly custody period with the child on Sunday, April 27, 2003,
at which time the child indicated to Petitioner that he was suffering from a severe
headache, had little appetite and felt generally "dazed."
16. Following school on Monday, April 28, 2003, the child returned to Petitioner's home
and exhibited extreme argumentative behavior, was not focused properly on tasks at
hand, and complained that he continued to suffer from a severe headache.
17. Petitioner took the child to the family physician, Dr. Thomas Steinour, on Tuesday,
April 29, 2003, whereupon the child revealed to the doctor that his mother gave him
medication the prior week, for purposes of controlling Attention Deficit Disorder,
which medication was prescribed by Dr. Michael Grossberg, a pediatric physician
located in the Chambersburg area.
18. Petitioner was completely unaware that Respondent provided medication to the child.
19. Petitioner was not consulted for purposes of a new evaluation with a new physician,
Dr. Grossberg, to evaluate the child for Attention Deficit Disorder and prescription
medication to control such a disorder.
20. The child's family physician discovered that the child suffered a negative reaction to
the medication prescribed by Dr. Grossberg, and, further, that the child suffered from
a medical condition, a sinus infection, which was exacerbated by the Attention Deficit
Disorder medication and, therefore, discontinued the child's use of such medication.
21. Dr. Steinour has provided medical services and treatment to the child for
approximately three years.
22. Petitioner believes and, therefore, avers that Respondent's actions have not been
taken with the child's best interests in consideration.
23. Petitioner believes and, therefore, avers, that Respondent's actions have placed the
child's physical health in jeopardy and have disrupted his educational progress.
24. Petitioner believes that, without an Order providing him with primary legal and
shared physical custody, Respondent will further endanger the child's health and
education by forcing the child to continue medication.
25. Contemporaneously with the filing of this Petition for Special Relief, Petitioner has
filed a Complaint for Custody.
26. Petitioner is better capable of providing for the child's physical, educational, financial
and emotional needs.
27. It is in the child's best interests to be in Petitioner's primary legal custody and to
remain in the parties' shared physical custody pending further Order of Court or
agreement of the parties.
28. In the event a Temporary Order is not entered in this matter, Petitioner fears that
Respondent may refuse Petitioner any periods of custody due to her insistence that
the child continue this medication and Petitioner's refusal to administer such
medication.
29. Respondent, Paula J. Taylor, has been provided with a copy of this Petition, by first
class U.S. mail and facsimile to her counsel, M. Teri Hall Stiltner, Esquire.
WHEREFORE, Petitioner requests your Honorable Court to enter an Order providing
Petitioner with temporary primary legal and shared physical custody of the child pending further
Order of Court or agreement of the parties.
Respectfully submitted,
Marylo atas, Esquire
Attorney or Plaintiff/Petitioner
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
VERIFICATION
I verify that the statements made in the foregoing document 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 falsifications to authorities.
DATE: 51113 V 4?. v k '1 4?
VICTOR K. TAYL , Plaintiff/Petitioner
4
Lincoln
Intermediate
Unit No. 12
LINCOLN INTERMEDIATE UNIT #12
EVALUATION REPORT (ER) Format
***********************************************************aSchool Age
[X] Initial Referral (Complete all following components excluding Reevaluation Only
section)
[ ] Reevaluation (Complete Demographics, Reason for Referral and then proceed to the
section titled "Reevaluation Only". Complete all other components only if additional
data is determined as needed under the Reevaluation component.)
DEMOGRAPHICS:
Student Name: Victor (Kyle) Taylor Date of Report: 1/21/03
School District: Shippensburg Area School District
School: Nancy Grayson Elementary School
Student Birth Date: 2/20/92 Grade: 5
Current Educational Program: Regular Education
Other Demographic Data, As Needed: N/A
REASON(S) FOR REFERRAL:
Kyle was referred for a psychoeducational evaluation due to concerns regarding his
performance across academic and behavioral areas. Despite the implementation of
interventions throughout the Instructional Support Team (IST) process, minimal progress
was noted. The purpose of this evaluation is to determine: 1) if Kyle has a disability and
2) if Kyle needs specially designed instruction.
EDUCATIONAL LEVELS OF PERFORMANCE AND EDUCATIONAL NEEDS
OF THE CHILD:
At the time of evaluation, Kyle wa:
grade at Nancy Grayson Elementz
information was obtained from a
Throughout his Kindergarten school
development, overall appropriate
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a 10 year, 10 month old young man attending 5'h
y School in Shippensburg, PA. The following
review of Kyle's permanent and IST records.
year, Kyle evidenced inconsistent social-emotional
intellectual and academic progress, and good
F?hi b-fI 'A"
coordination with large and small muscle skills. Records indicate that Kyle was referred
to the IST due to his difficulties functioning within a large group setting, emerging
sporadic behaviors, and need for constant attention. A variety of interventions were
implemented including the use of a parent/teacher communication system, time-out,
modifications to the classroom environment, positive behavior reinforcement, teacher
monitoring, positive behavior counseling, and the provision of a positive parent training
video to the parents. During a follow-up IST meeting, reports suggested that Kyle had
made progress in the behavior area. Over the 30-day intervention period, there was
ongoing teacher/parent communication. Kyle worked with the Guidance Counselor on
positive behavior, making good choices, and the "Stop and Think" program. It was
determined that Kyle would exit the IST process and continue to be monitored by the
classroom and IST teacher. Teacher reports indicated that Kyle evidenced some
difficulty with self-control throughout the year but that he made good academic and
behavioral progress by the end of the school year.
Kyle was promoted to I" grade for the 98/99 school year. He continued to show progress
in all areas. Teacher reports indicate that Kyle needed additional practice to strengthen
his reading skills. Behaviorally, Kyle's first grade teacher noted concerns in the areas of
self-discipline and control. During a parent/teacher conference in the Spring, a plan to
improve Kyle's behavior was developed. Teacher reports suggested that Kyle was
attempting to monitor his behaviors with this system and improvements were noted.
Academically, some inconsistencies in his Language Arts performance was noted
throughout the school year, but his performance in almost all other academic domains
was appropriate.
During Kyle's 2nd grade school year (1999/2000), continuing concerns regarding Kyle's
inconsistent academic and behavioral performance emerged. Grade reports suggest that
Kyle demonstrated inconsistent Language Arts performance particularly with regard to
his oral reading and written language skills. Behaviorally, primary difficulties were
noted with regard to inconsistent work and social habits and poor self-control. Due to his
impulsive behavior, inattention, and inappropriate classroom behaviors, Kyle was again
referred to the IST. Interventions within the classroom were implemented including the
use of preferential seating, close teacher proximity, the development of a ticket system
resulting in loss of recess and parent/school communication, the use of office or noon
notes, and home reinforcement. In addition, behavior checklists were completed by his
teachers and reviewed by the school psychologist. It was concluded at that time that Kyle
demonstrated some of the characteristics of a child diagnosed with attention difficulties
and may benefit from further medical evaluation. Upon additional medical examination,
Kyle was not diagnosed with Attention Deficit Hyperactivity Disorder and medical
treatment was not recommended. As such, the IST continued to implement behavioral
interventions in the classroom and Kyle was followed by the IST on a monitoring basis
throughout the remainder of his 2nd grade school year.
He continued to struggle academically and behaviorally throughout his 3`d grade year.
His reading was reportedly on grade level, with more difficulty in emerging with regard
to his written language skills. He continued to evidence satisfactory mathematical skills,
5E-921
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3
social studies, and science/health grades. His work and social habits continued to need
improvement, according to teacher reports, including his ability to follow directions,
listen attentively, work independently, and complete quality work on time. This pattern
of performance continued throughout the 2001/2002 school year (4t' grade) during which
the following end-of-the-year grades were reported: Reading, D; Writing, D; Spelling,
B+; Mathematics, C; Social Studies, C; and Science/Health, B. Results of group
administered standardized ability and achievement testing revealed High overall reading
skills, Low overall math skills, and Average written language skills. On the Otis-Lennon
School Ability Test, Kyle evidenced verbal reasoning skills within the lower limits of the
Average range. His nonverbal reasoning skills were less well-developed and fell within
the Borderline-Low Average range.
Kyle was promoted to 5' grade for the 2002/2003 school year and was referred to the
IST shortly after the beginning of the school year primarily due to his inability focus and
tendency to disrupt his classmates throughout the school day. Strategies to be
implemented included the use of positive and negative reinforcement, seat moved away
from classmates, school counseling, use of agenda, principal's involvement, and referral
to CAIU Behavioral Specialist. In addition, Kyle was referred for a Multidisciplinary
Evaluation in order to determine the nature and degree of Kyle's academic and behavior
difficulties.
EVALUATION DATA RESULTS OF DIRECT INTERVENTION-The team will
include information on the following areas that impact the student's ability to access
the general curriculum:
- Physical, social or cultural background information relevant to the chil d's
disability and need for special education.
According to the school nurse, Kyle passed vision and hearing screenings with
performances on screening measures within the normal limits. No significant illnesses or
injuries are reported in his medical record that are believed to impact his ability to access
the general curriculum. Parent reports indicate that there is a clear relationship between
Kyle's sugar consumption and behavioral performance. There is no medical condition in
Kyle's health records related to this observation.
Socially, Kyle reportedly has difficulty maintaining friendships. His behaviors can be
extremely disruptive to his peers (e.g. making "fart" noises, humming, etc.) and often
elicit negative peer reactions. Past parent and teacher reports indicate that Kyle
demonstrates behavior in which he appears to be showing off or clowning at times. In
addition, he can be rather demanding and bossy toward his classmates and at times this
behavior alienates him from his peers. There have reportedly been times when he gets
into arguments with a number of his peers.
Current parent reports on the Achenbach Child Behavior Checklist describe Kyle as a
lovable, funny, and kind child. He reportedly has at least one close friend and
participates in many extracurricular activities including baseball, wrestling, and cub
scouts. On an additional rating scale used to assess a variety of clinical behaviors, the
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4
Conners' Parent Rating Scale Revised, Kyle's parents reported that Kyle evidences
elevated levels of oppositional behaviors, inattention, and social problems. More
specifically, Kyle's parents responded affirmatively to items suggesting that Kyle does
not attend to details, is easily distracted, actively defies or refuses to comply with adult
requests, has temper outbursts, does not know how to make friends, and does not get
invited to friends' houses.
According to current teacher reports, Kyle is a kind student who wants to please and be
accepted by his peers. He enjoys talking to the teacher and sharing things he may be
doing at home or in sports activities. He has times when he makes noises or laughs to get
other students' attention. His peers do not appear to desire interaction with Kyle. On the
Achenbach Teacher Report Form, a standardized rating scale used to assess the presence
and degree of clinically significant social and emotional difficulties, elevated scores
emerged on items assessing Social Problems in which Kyle's teacher reported that he
"Doesn't get along with other pupils", "Feels that no one (peers) likes him", is "not liked
by his peers", and sometimes "feels worthless or inferior".
On a standardized self-report scale, the Behavior Assessment System for Children,
designed to facilitate the differential diagnosis and classification of a variety of emotional
and behavior disorders of children, Kyle evidenced clinically significant deficits in
interpersonal relationships and elevated ratings of social stress. He responded
affirmatively to items indicating that he perceived other students hated to be with him, his
classmates make fun of him, people do not enjoy being around him, and that others do
not have respect for him. In addition, he reported that he is bothered when others tease
him, he feels lonely, and worries that others will say bad things to him.
No cultural concerns are noted at the present time.
• Current classroom based assessments and observations and observations by
teachers and related service providers.
Mrs. Bowers (5'1' grade teacher)- "Kyle has trouble staying focused in class. He rarely
knows where we are in the text when called on in class. He continues to have a few
outbursts in class where he laughs or makes some type of noise. He also, at times, will
try to get students' attention to make them laugh. It appears that Kyle is getting help
from [his parents]. The agenda is used to keep his parents abreast of what work Kyle has
to complete. Most homework is complete. However,, work assigned to be completed in
class is rarely completed Kyle goes to the library at lunch time many days to complete
work.
Kyle has made some improvement in most areas this marking period. His
behavior has also been better. But the last week Kyle has had some problems controlling
his behavior. Socially, Kyle has problems getting along with his peers. Kyle wants to be
liked by the class, however, he does not know how to behave and to relate to the students
in order to be accepted ". Current teacher reports indicate that Kyle is currently receiving
C's and D's in all academic areas. His primary difficulty is reportedly his inability to
focus.
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Mrs. Haller (Library)- "Kyle has improved his behavior which helps with the academics.
Note that Kyle sits at my teaching table. This seems to be satisfactory to him and eye
contact can stop unacceptable behavior ". Additional reports indicate that Kyle
demonstrates appropriate behavior most of the time with some inconsistencies with
regard to his ability to work cooperatively with his peers, ask for help when needed, and
ask for clarification/repetition.
Mr. Burkholder (Art)- "Kyle continues to blurt out strange noises: burps, coughs,
etc... He occasionally discusses disgusting or sexual topics with his classmates (who are
offended). He does not show common courtesy to other students nor respect for me ".
According to teacher ratings, Kyle appears to understand lectures and asks for help or
clarification as needed. He demonstrates greater inconsistencies with regard to his
attention, participation, communication with peers, organizational skills, and classroom
behavior.
Mrs. Allison (Vocal Music)- "[Kyle is] distracted and tries to distract others. " Teacher
reports suggest considerable inconsistencies in Kyle's classroom performance with
particular concerns emerging with regard to his preparedness for class, cooperation with
peers, and requesting teacher assistance/clarification.
Mrs. Runyan (Physical Education)- "He could do better in his effort to do the things
asked of him. He acts like the class clown at times. [He] doesn't always pay attention.
He was better at the beginning of the year". He is typically attentive, understands
lessons, follows directions, and participates appropriately. Primary concerns emerge with
regard to his overall classroom behavior and failure to ask for help when needed.
Kyle was observed by the school psychologist for approximately 30 minutes during a
whole-class teacher directed math lesson. Kyle was observed to be on-task
approximately 81 % of the time, as compared to his same-sex peers who were observed to
be on-task approximately 91% of the time [85% + is considered optimal for learning].
His desk was noted to be pulled away from the rest of his peers and positioned facing his
peers in front of the classroom. He appeared to demonstrate elevated levels of
restlessness and fidgetiness. He was observed resting his head on his desk on several
occasions as well as mouthing his fingers. On one occasion for approximately 1 minute,
Kyle was observed to be engaged in nonverbal dialogue with a peer across the room. He
was observed giggling and laughing and attended to the reaction of the school
psychologist on several occasions. During discussion periods, Kyle volunteered his
participation on several occasions and transitioned his attention to the appropriate peer
speaker. At the end of the lecture portion of this lesson, Kyle was awarded a check mark
on his behavior chart for demonstrating overall appropriate attention. The students were
instructed to write their assignments in their agendas and to then begin working on a
worksheet being passed out. Kyle transitioned extremely slowly and was still writing
assignments into his agenda while other students had completed several math problems
on the worksheet. Once redirected to the worksheet with the teacher prompt "Quickly,
Quickly", Kyle was observed to work at a very slow pace.
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6
Kyle was evaluated during 2 sessions for approximately 3 '/2 hours. He willingly
accompanied the school psychologist to the testing room and rapport was easily
established. Kyle engaged the examiner in conversation but was easily redirected when
testing began. Kyle appeared to demonstrate overall appropriate attention and
concentration throughout both testing sessions. He appeared to enjoy the tasks with
which he was presented, demonstrated good motivation and cooperation, and seemed to
be pleased with the individual attention offered by the testing situation. He tended to
respond slowly to task items and often required prompting on behalf of the examiner. He
generally persisted with more difficult task items, but freely admitted when he did not
know the answer to an item. During breaks, Kyle engaged the examiner in conversation
regarding recent changes to his family constellation. He reported that these changes
make him feel sad, but it appears that Kyle has a large support network including the
school counselor, his pastor, both parents, and extended family to help him cope with
these changes.
EVALUATIONS AND INFORMATION PROVIDED BY THE PARENTS OF THE
CHILD:
According to parent information, Kyle is described as a lovable and funny young man.
Academically, his mathematical skills reportedly emerge as an are of strength for Kyle.
He evidences less well-developed skills in listening, reading, writing, and speaking,
according to parent report. Socially, some concerns are present with regard to Kyle
acting like the "class clown". According to information presented on the Achenbach
Child Behavioral Checklist, no statistically significant or clinically meaningful social,
behavioral, or emotional difficulties are perceived by Kyle's parents.
IF AN ASSESSMENT IS NOT CONDUCTED UNDER STANDARD
CONDITIONS, DESCRIBE THE EXTENT TO WHICH IT VARIED FROM
STANDARD CONDITIONS:
This assessment was conducted under standard conditions and is believed to be a valid
indicator of Kyle's true skills and abilities.
SUMMARY OF FINDINGSANTERPRETATION OF ASSESSMENT RESULTS:
• Aptitude and achievement levels.
In order to evaluate Kyle's level of cognitive functioning, he was administered the
Woodcock Johnson Tests of Cognitive Abilities-Third Edition (WJ-Cog III). The WJ-Cog
III provides measures of a student's overall general intellectual ability and includes
clusters representing broad categories of cognitive abilities that are related to cognitive
performance. These categories include verbal ability, thinking ability, and cognitive
efficiency. In addition, due to the presence of significant subtest scatter in Kyle's profile
of performance, Kyle was also administered selected subtests from the Wechsler
Intelligence Scale for Children- Third Edition (WISC-III), an individually administered
test designed to assess general intelligence in order to gain a better understanding of
Kyle's level of functioning on a day-to-day basis.
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7
Kyle's overall level of intellectual ability was classified within the Low Average range
and equaled or exceeded the performance of approximately 17% of his same-aged peers.
Due to the high degree of subtest scatter within Kyle's profile of cognitive performance,
this score is not believed to be a valid indicator of Kyle's abilities. Rather, interpretation
of individual subtest performances more accurately describes Kyle's day-to-day
functioning. Kyle's verbal comprehension and language development was classified
within the Average range. His picture vocabulary skills, ability to identify word
opposites, reasoning skills, and ability to identify like words were evenly developed.
His overall performance on tasks assessing thinking abilities, or intentional cognitive
processes, was classified within the Average range with evenly developed visual
processing (analyzing and synthesizing visual input), auditory processing (analyzing and
synthesizing auditory/oral input), fluid reasoning (novel problem-solving), and long-term
retrieval abilities (ability to store information in memory and retrieve it for later use).
Significant cluster scatter was noted on tasks assessing cognitive efficiency, or cognitive
processes that are automatically engaged during learning tasks. Kyle's overall
performance fell within the significantly Impaired range of functioning. However, his
performance within this cluster was significantly scattered, suggesting that the overall
score is not the most representative indicator of Kyle's true skills and abilities within this
domain. More specifically, on tasks assessing Kyle's ability to perform mental
operations on nonmeaningful information held in short-term memory, Kyle's
performance was classified within the Borderline range (WJ-Cog III Numbers Reversed
SS = 77, 6t1i%tile). When tasks were somewhat less demanding and required only rote
recall of nonmeaningful information, Kyle was capable of demonstrating performance
within the lower limits of the Low Average range (WISC-III Digit Span ss = 7). As
information presented for recall became more meaningful, Kyle's performance was
further enhanced and was classified within the upper limits of the Low Average range
(WJ-Cog III Memory for Words SS = 87, 20t1i%tile). Finally, Kyle's short-term memory
skills were most well-developed when he was asked to perform mental operations on
both meaningful and nonmeaningful information with a strategy for remembering being
presented within task directions (WJ-Cog III Auditory Working Memory SS = 91,
28'}'%tile). His performance in the latter domain was classified within the Average range
and suggests that Kyle's short-term memory abilities are significantly enhanced when
information is meaningful and a strategy for remembering is used. This profile of
performance suggests that Kyle would benefit considerably from cognitive strategy
instruction as a means of improving learning and recall.
Kyle also demonstrated a significant weakness in his ability to process visual information
quickly and accurately, in which his overall performance ranged from the Borderline
(WISC-III Processing Speed Index SS = 77, 6"'%tile) to the Impaired (WI-Cog III
Processing Speed factor cluster SS = 59, .31/otile) range of functioning. His visual
processing involving picture cues (WJ-Cog III Decision Speed SS = 67, 1" %tile, WISC-
III Symbol Search ss = 7) were better developed than his visual processing involving
numbers and memory (WISC-III Coding ss = 4, WJ-Cog III Visual Matching SS = 58,
.30/otile) likely due to coexisting deficits in Kyle's short-term memory abilities. Kyle's
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.A
performance in these areas were significantly less well-developed than would be
expected as compared to his performance on all other areas of cognitive functioning and
represent a clinically meaningful areas of disability for Kyle. When students evidence
significant difficulty processing information quickly, they can often be perceived as
inattentive and unfocused within a classroom setting. For Kyle, these behaviors are
likely further exacerbated by his need for information to be repeated frequently due to his
short-term memory deficits.
Kyle's academic achievement was assessed using the Woodcock Johnson Tests of
Achievement-Third Edition (WJ-III Ach). The WJ-III Ach provides measures of a
student's overall academic achievement and includes clusters representing broad
curricular areas that are relevant to academic performance. These clusters include
reading, mathematics, written language, and oral language.
Current evaluation results indicate that Kyle's overall level of academic achievement fell
within the upper limits of the Low Average range and equaled or exceeded approximately
22% of his same-aged peers. Within the reading domain, Kyle's word identification skills
were appropriately developed and were classified within the Average range. His sight
word vocabulary was as well developed as would be expected for a child his age and he
demonstrated appropriate word-attack skills on unknown words. Kyle's overall
comprehension and fluency skills were slightly less well developed but still within the
Low Average range of performance. Both areas appeared to be negatively impacted by
his difficulty identifying words and processing meaning quickly and accurately.
Kyle's performance on mathematics tasks with which he was presented was classified
within the Average range. Although his calculation (untimed) and problem solving skills
were both classified within the Average range, he demonstrated more difficulty on tasks
assessing fluency (timed) or automaticity of simple arithmetic problems. His
performance in the latter domain was classified within the Borderline range and was
likely compromised by his processing speed deficits.
With regard to the written language domain, Kyle's overall performance fell within the
Average range. His spelling and written expression skills were evenly developed and
were classified within the Average range. Once again, weaker performances were rioted
on the timed writing fluency task in which Kyle was asked to generate short, simple
sentences quickly and accurately. Although all sentences completed by Kyle were done
accurately with proper grammar and spelling, he took slightly longer than the majority of
his same-aged peers to process the stimulus words and generate original sentences. His
performance in this domain was classified within the Low Average range.
Finally, Kyle's overall performance on tasks of oral language was classified within the
Average range. He demonstrated evenly developed receptive and expressive language
skills. He was able to demonstrate an understanding of verbal, auditory information and
was able to remember such meaningful information over a brief period of time prior to
retelling.
SE-921
Revised June 2001
'9
Kyle's visual motor skills were assessed using the Developmental Test of Visual Motor
Integration (VM1), which requires the student to copy geometric designs onto paper.
When compared to others her age, Kyle's performance on this instrument was
commensurate with his cognitive abilities and fell within the Average range of
functioning. This suggests that Kyle's visual motor skills, pertaining to paper and pencil
tasks are as well developed as would be expected for a child his age and level of
cognitive functioning.
• Involvement in and progress in the general education curriculum.
Kyle currently participates in the 5'?' grade general education curriculum. According to
parent and teacher reports, Kyle demonstrates considerable academic and behavioral
difficulties.
• Relevant functional and developmental evaluation (ecological evaluation, if
appropriate).
Not appropriate at this time.
• Vocational Technical Education Assessment Results (when appropriate).
Not appropriate at this time.
• Interests, Preferences, Aptitudes (when appropriate).
Not appropriate at this time.
• Functional Behavioral Assessment Results (if appropriate).
According to data collected by Ms. Noretta Kime, CAJU Behavioral Specialist in October
2002, results of a motivational assessment suggested that Kyle seemed to be seeking
attention from both peers and adults. His mode of seeking attention is through attempted
acts of humor. At the time of data collection, Ms. Kime reported that it was her belief
that Kyle was attempting to avoid or escape his learning difficulties through humor
("Better to get in trouble than to look dumb"). He also appeared rather impulsive
according to Ms. Kime's observations. Upon speaking with Kyle, Ms. Kime reported
that he was a neat and polite young man. Ms. Kime reportedly worked with the
classroom teacher to devise a reinforcement system (on the half-hour) to reward him with
1:1 time with her. Informal follow-up with the teacher suggested that Kyle was doing
well. Additional follow-up was offered as needed.
For a child suspected of having a specific learning disability, the documentation of the team's
determination of eligibility must include a statement of 1) whether the child has a speck learning
disability; 2) the basis for making the determination: 3) the relevant behavior noted during the observation
of the child; 4) the relationship of that behavior to the child's academic functioning; S) the educationally
relevant medical findings, if any; 6) whether there is a severe discrepancy between achievement and ability
that is not correctable without special education and related services; and 7) the determination of the team
concerning the effects of environmental, cultural, or economic disadvantage.
1. Kyle evidences a significant discrepancy between his verbal (school-related) and
nonverbal thinking abilities, with notable weaknesses emerging with regard to
his short-term memory and processing speed abilities. This profile of significant
SE-921
Revised June 2001
10
cognitive scatter is characteristic of children diagnosed with a learning
disability.
2. This determination has been made based upon classroom-based and norm
,?--?? referenced tests as well as observations.
53, When students evidence significant difficulty processing information quickly,
they can often be perceived as inattentive and unfocused within a classroom
setting. For Kyle, these behaviors are likely further exacerbated by his need for
information to be repeated frequently due to his short-term memory deficits.
"This information along with previous psychiatric reports suggesting that Kyle
does not '_ meet diagnostic criteria as a student with Attention Deficit
Hyperactivity Disorder, indicate that Kyle's academic difficulties are not solely
the result of behavioral difficulties, but rather likely due to a combination of
Kyle's cognitive deficits and behavioral tendencies.
4. There are no educationally relevant medical findings at this time.
5. The severe discrepancy among Kyle's cognitive abilities manifests itself in an
imperfect ability to think, speak, read, write, spell and do mathematical
calculations fluently. As such, the Multidisciplinary Team believes that special
education support using specially designed instruction will be necessary to
provide him with accommodations to support learning in the regular education
setting.
6. This disability is not believed to be the result of environmental, cultural, or
economic disadvantage.
CONCLUSIONS
X Student is a child with a disability. Disability category: Learning Disability
(If appropriate) Secondary Disability category:
X Student is in need of specially designed instruction
Recommendations regarding special education and related services needed to enable
the child to meet goals and to participate as appropriate in the general curriculum:
Due to Kyle's profile of significant cognitive scatter resulting in an imperfect ability to
think, speak, read, write, spell and do mathematical calculations fluently, he meets the
eligibility requirements for the exceptionality of having a learning disability as defined by
Chapter 14 of the Pennsylvania State Standards for special education and as defined in
I.D.E.A., criteria for determining the existence of a learning disability. The
Multidisciplinary Team believes that this disability is not the result of visual, hearing, or
motor impairments, mental retardation, emotional disturbance, environmental, cultural, or
any economic disadvantages. The Multidisciplinary Team will convene to discuss results
and program decisions. It is recommended that Kyle receive specially designed
instruction in the form of resource and support across academic areas as needed. Due to
his deficits in short-term memory and processing speed, the following recommendations
for the development of Kyle's individualized education program are offered for
consideration:
SE-921
Revised June 2001
. .i 1
Short-Term Memory
• Use multiple modalities (e.g. auditory, visual, tactile, etc.) when presenting
directions, explanations, and instructional content.
• Engage in cognitive strategy instruction to improve short-term and long-term recall of
learned information (e.g. encourage repetition, use of mneumonic devices, chunking,
etc.).
• Have Kyle practice short-term memory skills and strategies by engaging in activities
which are purposeful (e.g. carry messages from one location to another, look up
telephone number and walk to phone, remember items on a grocery list, etc.)
• Have Kyle practice short-term memory aides such as taking notes for specific
information he needs to remember (e.g. writing assignments in agenda clearly and
specifically, taking notes during a lecture, etc.).
• Make certain Kyle is attending to the source of information that he is going to be
asked to remember (e.g. eye contact is being made, hands are free of materials,
looking at assignment, etc.).
• Teach Kyle appropriate information gathering skills (e.g., listen carefully, write down
important points, ask for clarification, wait unt9il all information is received before
beginning, etc.).
• Assess the meaningfulness of the material to the student. Remembering is more
likely to occur when the material presented is meaningful and Kyle can relate to real
experiences (e.g. explain the purpose of the assignment, relate subject matter to the
student's environment, etc.).
• Give Kyle fewer concepts to learn at any one time, spending more time on each
concept until he can master it correctly.
Processing Speed
• Give Kyle short directions, explanations, and instructions to follow. Have Kyle
repeat or paraphrase what is said to him to determine what was heard.
• Shorten the length of assignments in order that Kyle can complete assignments in the
same length of time as the other students.
• Extend time limits as needed in order that Kyle has more than enough time to
complete an assignment.
• Avoid the use of timed tests in order to minimize processing speed requirements and
to ensure the most accurate sampling of Kyle's true skills.
• Allot extra time for test taking.
• Evaluate the appropriateness of assigned tasks to determine l.) if the task is too
difficult, and 2.) if the length of time scheduled to complete the task is appropriate.
• Provide Kyle with adequate transition time between activities so that he can organize
himself.
• Communicate clearly with Kyle the amount of time he has to complete the
assignment and the exact time the assignment must be completed. Kyle may want to
use a timer in order to complete tasks within a given period of time.
SE-921
Revised June 2001
i2
Behavioral and Social Skill Difficulties
• Provide Kyle with as many academic and social successes as possible in order that
peers may view him in a more positive way.
• Identify a peer to act as a model for Kyle to imitate appropriate interactions with
peers. Consider using this peer in role-plays with the school counselor to practice
appropriate social skills.
• Individual or group counseling in a school-based setting should be provided as
needed to address choices and decision-making in social situations.
• Allow Kyle to demonstrate his sense of humor and to get positive attention from
peers by giving him a more acceptable time to make his classmates laugh. Perhaps
once a week Kyle could be given 5 minutes to tell a favorite joke or riddle. This time
could be contingent upon behavior during the previous week.
• Consider moving Kyle's desk back among his peers. Choose to place Kyle around
peers who will be supportive role models for Kyle.
• According to functional behavioral analysis, Kyle often misbehaves to get attention.
The greatest challenge for the teacher is to change Kyle's behavior by giving him as
little attention as possible when the misbehavior occurs. The following are strategies
for achieving this:
• Highlight other students who are behaving appropriately.
• Move Kyle out of the spotlight by giving him an errand to run.
• Distract the student with a task question.
• Attend to Kyle when he is on task.
• Another method that could be used to help Kyle evaluate his behavior and reflect on
when and why he tries to get attention is the Newspaper Model graphic organizer (see
attached). Sometimes a pattern emerges where it becomes evident that certain people
or certain situations provoke the attention seeker to "act out". The Newspaper Model
allows attention seekers to analyze their actions and reflect on the causes and effects
of their behavior.
OR
Student is not a child with a disability, or is a child with a disability but does
not need specially designed instruction.
COMPLETE FOR REEVALUATIONS ONLY:
DATE IEP TEAM* REVIEWED EXISTING EVALUATION DATA:
INFORMATION REVIEWED:
• Existing evaluation data
• Evaluations and information provided by the parents
• Current classroom based assessments and observations
5E-921
Revised June 2001
13
• Observations by teachers and service providers
• Whether any additions or modifications to the special education and related services
are needed to enable the child to meet the measurable annual goals in the IEP and to
participate as appropriate in the general curriculum
*IEP Team must include a school psychologist when evaluating a child with Autism,
Emotional Disturbance, Mental Retardation, Multiple Disabilities, Other Health
Impairment, Specific Learning Disability and Traumatic Brain Injury.
For a child suspected of having a specific learning disability, the documentation of the team's
determination of eligibility must include a statement of 1) whether the child has a specific learning
disability; 2) the basis for making the determination; 3) the relevant behavior noted during the observation
of the child; 4) the relationship of that behavior to the child's academic functioning; S) the educationally
relevant medical findings, if any; 6) whether there is a severe discrepancy between achievement and ability
that is not correctable without special education and related services; and 7) the determination of the team
concerning the effects of environmental, cultural, or economic disadvantage.
CONCLUSION (Select one)
[ ] The IEP Team determined that no additional data is required.
Reason(s) no additional data is required:
The student continues to be eligible for and in need of special education, or
The student no longer is eligible for special education. (The parent may
request an assessment to determine whether the student continues to be
a child with a disability)
OR
[ ] The IEP Team determined that there is a need for additional data. The LEA
shall issue the permission to reevaluate and administer tests and other
evaluation materials as may be needed to produce the following data:
Review of existing evaluation data
• Evaluations and information provided by the parents
• Current classroom based assessments and observations
• Observations by teachers and service providers
• Present levels of performance and educational needs
• Determination of continued eligibility for special education
Upon completion of the reevaluation, the district will complete the ER and issue the
report to the required members of the evaluation team.
SE-921
Revised June 2001
14
EVALUATION REPORT - SIGNATURES
TITLE
School Psychologist*
LEA/Chairperson
Regular Education Teacher
-S al 4er n Te?
Parent
N re-n t
S#ud..,+ 1 eac_her
-
YES NO
i/
e
e
e
e
t-
???XJ ?? "! 6, 1 . ? C.3f4ncC?4r Zvi -t
j
*Required for eval on of the following disability categories: Autism, Emotional Disturbance, Mental
Retardation, Multiple Disabilities, Other Health Impairments, Specific Learning Disability or Traumatic
Brain Injury. Not mandated for Deaf/Blind, Hearing Impaired, Speech/Language, Visual Impairment and
Orthopedic Impairment.
List name of person copies were given to:
Parent:
Teacher:
Building Principal:
Others:
SE-921
Revised June 2001
7t&44 ATURE
n L'
.i
?
c
15
ASSESSMENT INSTRUMENTS
Woodcock-Johnson Tests of Cognitive Ability-Third Edition (YJ-III
Subtest Standard Score Percentile Rank
Verbal Comprehension 96 39
Verbal Ability 96 39
Visual Auditory Learning 90 25
Spatial Relations 96 40
Sound Blending 103 57
Concept Formation 109 73
Thinking Ability 102 54
Visual Matching 58 0.3
Numbers Reversed 77 6
Decision Speed 67 1
Memo for Words 87 20
Cognitive Efficienc Ext. 64 1
Visual Matching 58 0.3
Decision Speed 67 1
Processing Speed 59 0.3
Numbers Reversed 77 6
Auditory Working Memo 91 28
Working Memo 80 9
Numbers Reversed 77 6
Memo for Words 87 20
Short-Term Memo 79 9
General Intellectual Ability 86 17
Standard scores were based on an average score of 100. The percentile column reflects
the percent of the general population that Kyle's score exceeded.
SE-921
Revised June 2001
Iifi
Wechsler Intelligence Scale for Children-Third Edition (WISC-III)
WISC-III Factor Score Standard Score Percentile Rank
Processing Speed 77 6
The following outline provides an estimate of Kyle's development in each of the areas
examined by the WISC-III. A scaled score of 10 is considered the average score.
Subtests Measures Scaled Score
Digit Span Auditory Short-Term Memo 7
Coding Visual Memory, Speed 4
Symbol Search Processing Seed 7
Woodcock Johnson Tests ofAchievement-Third Edition (WJ-III
Subtest Standard Score Percentile Rank
-
Letter-Word Identification 98 44
Passage Comprehension 88 21
Reading Fluency 83 12
BROAD READING 89 22
Calculation 91 28
Applied Problems 103 57
Math Fluency 73 4
BROAD MATHEMATICS 94 35
Spelling 97 41
Writing Samples 91 26
Writing Fluency 87 18
BROAD WRITTEN LANG. 91 28
Story Recall 98 45
Understanding Directions 93 32
ORAL LANGUAGE 93 33
Standard scores were based on an average score of 100. The percentile column reflects
the percent of the general population that Kyle's score exceeded.
SE-921
Revised June 2001
17
Developmental Test of Visual Motor Integration
VMI Standard Score: 95
VNE Percentile: 37'h%tile
VMI Raw Score: 20
SE-921
Revised June 2001
176 0 What to Do with the Kid Who
FOCUS STRATEGY:
The Newspaper Model
Ask attention seekers to state they t they think k is invotlved, problem is.
why,
Students should then list who thn
where, and when the problem occurs. Finally, they should write
a paragraph about the situation-
strategy
Date: Feb.,
Name: Glenn Spotlight
1 of in trouble for drawl on Marys sweater but she started it.
Problem:
Glenn
drew a
happy face
with
colored
chalk on
Mary's
sweater
When
Tuesday I I In Mrs.
Feb. 3 Martinez' art
class
Because
she thinks
she's hot
stuff and she
is always
putting me
down and
calling mel
names
have described above-4 . a paragraph commenting on the situation you 1 got mad because John and Mary think they are better than me. They never use my ideas
when we meet in groups. They are always calling me names and putting me down. I guess 1
called me a jerk and that hurt my feelings.
shouldn't have drown the happy face, but Mary
Maybe I should apologize to her. I guess I got a little carved away.
Signed: Glenn
Have another group member write a paragraph about the situation.
I called Glenn a jerk because he is always fooling around instead of helping. I know I shouldn't
call him names, but I get real frustrated with him.
signed: Mort' -
o 1992 sight Put)"o
Who
rM - -
VICTOR K. TAYLOR,
Plaintiff
V.
PAULA J. TAYLOR,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. CIVIL TERM
IN DIVORCE
CERTIFICATE OF SERVICE
I, Marylou Matas, Esquire, hereby certify that I did, the 1 S- day of May, 2003, cause a
copy of Plaintiff's Petition for Special Relief to be served upon Defendant by first class, U.S.
mail and by facsimile at the following address:
DATE: May 1, Z00:?)
M. Teri Hall Stiltner, Esquire
247 Lincoln Way East
Chambersburg, PA 17201-2295
Fax no. (717) 264-1662
Mary`1ou Matas, Esquire
Attorney for Plaintiff/Petitioner
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717)243-5551
(800)347-5552
a
1
N
v
t
r" _ 1
c?
VICTOR K. TAYLOR, IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
PAULA J. TAYLOR,
DEFENDANT 03-2094 CIVIL TERM
ORDER OF COURT
AND NOW, this day of May, 2003, the petition for special relief,
IS DENIED WITHOUT A HEARING. The case shall proceed to conciliation.
By th
Edgar B. Bayley, J.
Marylou Matas, Esquire
For Plaintiff
M. Terri Hall Stiltner, Esquire o a3
For Defendant
Court Administrator
sal
V?NV/'QASNN?,4
fr. V
VICTOR K. TAYLOR IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
• 03-2094 CIVIL ACTION LAW
PAULA J. TAYLOR
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Friday, May 09, 2003 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq, , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, June 03, 2003 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. 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/ Jacqueline M Verney, Esq. u
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
of
VINVAIASWd,
JUN 1 2 2003 V
VICTOR K. TAYLOR, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V : NO. 2003-2094 CIVIL TERM
PAULA J. TAYLOR : CIVIL ACTION - LAW
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this -A day of ? 2003, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
I. The Father, Victor K. Taylor, and the Mother, Paula J. Taylor, shall have
shared legal custody of Victor Kyle Taylor, born February 20, 1992. Each parent shall
have an equal right, to be exercised jointly with the other parent, to make all major non-
emergency decisions affecting the Child's general well-being including, but not limited
to, all decisions regarding his health, education and religion. In this regard, the Child
shall not be removed from his current school district without prior Order of Court or
agreement of the parties.
2. The parents shall have shared physical custody of the Child on a week
on/week off basis. The day and time of exchange shall be Sunday at 5:30 p.m.
3. The parties shall notify each other fourteen (14) days in advance regarding
a request for an additional period of custody with the Child and/or a change in a
scheduled period of custody with the Child.
4. Summer Vacation:
A. Beginning the summer of 2003 and each odd year thereafter, Father shall
notify Mother of his selection of one consecutive week of summer vacation
and any single days of vacation no later than May 15`h of each year. Mother
shall notify Father of her selection of one consecutive week of summer
vacation and any single days of vacation no later than June 15 of each year.
In the event the week is not a regular alternating week for the requesting
parent, the parties shall agree to exchange weeks to accommodate the other
parent.
B. Beginning the summer of 2004 and each even year thereafter, Mother shall
notify Father of her selection of one consecutive week of summer vacation
1, y'n?f??usnr4?d
.u l1rJ f f t iii' a
h!, r
jl)
and any single days of vacation no later than May 15`h of each year. Father
shall notify Mother of his selection of one consecutive week of summer
vacation and any single days of vacation no later than June 15`h of each year.
In the event the week is not a regular alternating week for the requesting
parent, the parties shall agree to exchange weeks to accommodate the other
parent.
5. Holidays:
A. Thanksgiving: Mother shall have custody of the Child from 10:00 a.m. to
2:00 p.m. on Thanksgiving Day. Father shall have custody of the Child
from 2:00 p.m. to 7:00 p.m. on Thanksgiving; Day.
B. Christmas: Beginning in 2003 and every odd year thereafter, Mother shall
have custody of the Child from 7:00 p.m. on, Christmas Eve through 2:00
p.m. Christmas Day. Father shall have custody of the Child from 2:00
P.M. on Christmas Day until 7:00 p.m. on Christmas Day. Beginning in
2004 and every even year thereafter, Father shall have custody of the
Child from 7:00 p.m. on Christmas Eve through 2:00 p.m. on Christmas
Day. Mother shall have custody of the Child from 2:00 p.m. on Christmas
Day until 7:00 p.m. on Christmas Day.
C. Mother shall have custody of the Child on Mother's Day from 10:00 a.m.
until 7:00 p.m. Father shall have custody of the Child on Father's Day
from 10:00 a.m. until 7:00 p.m.
6. The parties shall keep each other advised in the event of serious illness or
medical emergency concerning the Child and shall further take any necessary steps to
ensure that the health and well-being of the Child is protected. During such illness or
medical emergency, both parties shall have the right to visit the Child as often as he or
she desires consistent with the proper medical care of the Child.
Father shall provide health insurance coverage for the Child.
g. Transportation shall be shared. The parties shall exchange custody at the
Sheetzin Shippensburg.
9. Mother and Father agree to work together to insure the best interests of
their Child. Each parent agrees to at all times encourage the Child to comply with the
terms of this Order as it relates to the periods of custody to be spend with the party.
While in the presence of the Child, neither of the parties shall make any remarks or do
anything that can in any way be construed as derogatory or uncomplimentary to the other
and it shall be the duty of each to uphold the other party as one to whom the Child should
respect and love.
10. Both parties shall insure that the Child will not view or have access to
inappropriate sexual material.
11. Either set of Grandparents is authorized to pick up the Child from school
and/or any homework assignments.
12. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terns of this Order shall control.
BY THE COURT,
cc: Marylou Matas, Esquire, Counsel for Father
Richard L. Webber, Jr., Esquire, Counsel for Mother
VICTOR K. TAYLOR, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. :2003-2094 CIVIL TERM
PAULA J. TAYLOR, : CIVIL ACTION - LAW
Defendant
IN CUSTODY
PRIOR JUDGE: Edgar B. Bayley, J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Victor Kyle Taylor February 20, 1992 shared
2. A Conciliation Conference was held in this matter on June 11, 2003, with
the following individuals in attendance: The Father, Victor K. Taylor, with his counsel,
Marylou Matas, Esquire and the Mother, Paula J. Taylor, with her counsel, Richard L.
Webber, Jr., Esquire.
3. The Honorable Edgar B. Bayley entered an Order of Court dated May 8,
2003 denying Father's Petition for Special Relief.
4. The parties agreed to the entry of an Order in the form as attached.
Date acq line A. Verney, Esquire
Custody Conciliator
VICTOR K. TAYLOR,
Plaintiff
V.
PAULA J. TAYLOR,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2003-2094 CIVIL TERM
IN CUSTODY
PETITION FOR MODIFICATION OF CUSTODY
AND NOW, comes Petitioner, Victor K. Taylor, by and through his legal counsel of
record, Marylou Matas, Esquire, and the law firm of Griffie S, Associates petitions the Court as
follows:
1. Your Petitioner is the above-named Plaintiff, Victor K. Taylor, an adult individual
currently residing at 619 Glenn Street, Shippensburg, Cumberland County,
Pennsylvania.
2. Your Respondent is the above-named Defendant, 'aula J. Taylor, an adult individual
currently residing at 76 Carpenter Lane, Newburg, Cumberland County,
Pennsylvania.
3. The parties are the natural parents of one Child, Victor Kyle Taylor, born February
20, 1992.
4. The parties are subject to an Order of Court which was entered following conciliation
on June 13, 2003, a copy of his is attached hereto and incorporated herein by
reference as Exhibit "A."
5. Since the entry of the aforementioned Order, the parties have continued to reside in
Cumberland County, thus providing this Court with ongoing jurisdiction of these
proceedings.
6. Since the entry of the Order of June 13, 2004, Respondent has been involved in
another relationship with another man and has exposed her young Child to private,
intimate sexual encounters that she engages in, causing the Child to be extremely
confused and embarrassed over these matters.
7. Respondent has exhibited an inability or lack of desire to provide for the Child's best
interests, in that she exposed him to her private sexual life.
8. The Child has reported to Petitioner that he desires to reside primarily with Petitioner.
9. The Child has indicated that he receives more positive attention from Petitioner.
10. Petitioner is better capable of providing the Child with a stable, safe and appropriate
home environment.
11. It is in the best interest and permanent welfare of the Child to provide father with
primary physical or residential custody of the Child and set forth a more detailed and
confined arrangement of partial physical custody far the Respondent
WHEREFORE, Petitioner requests your Honorable Court to schedule a conciliation
conference at which time an order should be entered providing him with primary physical or
residential custody of the Child.
Respectfully submitted,
W
Mary atas, Esquire
Attorney or Petitioner/Plaintiff
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
VERIFICATION
I verify that the statements made in the foregoing document 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 falsifications to authorities.
DATE: 7/30/f V ?C
VICTOR K. TAYLO , Petitioner/Plaintiff
JUN 1 2 2003 ?
VICTOR K. TAYLOR, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2003-2094 CIVIL TERM
PAULA J. TAYLOR : CIVIL ACTION - LAW
Defendant
IN CUSTODY
ORDER OF COURT
ef,
AND NOW, this 13 ` day of 2003,uPon
consideration of the attached Custody Conciliation Report;, it is ordered and directed as
follows:
1. The Father, Victor K. Taylor, and the Mother, Paula J. Taylor, shall have
shared legal custody of Victor Kyle Taylor, born February 20, 1992. Each parent shall
have an equal right, to be exercised jointly with the other parent, to make all major non-
emergency decisions affecting the Child's general well-being including, but not limited
to, all decisions regarding his health, education and religion. In this regard, the Child
shall not be removed from his current school district without prior Order of Court or
agreement of the parties.
2. The parents shall have shared physical custody of the Child on a week
on/week off basis. The day and time of exchange shall be Sunday at 5:30 p.m.
3. The parties shall notify each other fourteen (14) days in advance regarding
a request for an additional period of custody with the Child and/or a change in a
scheduled period of custody with the Child.
4. Summer Vacation:
A. Beginning the summer of 2003 and each odd year thereafter, Father shall
notify Mother of his selection of one consecutive week of summer vacation
and any single days of vacation no later than May 15`h of each year. Mother
shall notify Father of her selection of one consecutive week of summer
vacation and any single days of vacation no later than June 15 of each year.
In the event the week is not a regular alternating week for the requesting
parent, the parties shall agree to exchange weeks to accommodate the other
parent.
B. Beginning the summer of 2004 and each even year thereafter, Mother shall
notify Father of her selection of one consecutive week of summer vacation
EXHIBIT "A"
and any single days of vacation no later than May 15°i of each year. Father
shall notify Mother of his selection of one consecutive week of summer
vacation and any single days of vacation no later than June 15`h of each year.
In the event the week is not a regular alternating week for the requesting
parent, the parties shall agree to exchange weeks to accommodate the other
parent.
Holidays:
A. Thanksgiving: Mother shall have custody of the Child from 10:00 a.m. to
2:00 p.m. on Thanksgiving Day. Father shall have custody of the Child
from 2:00 p.m. to 7:00 p.m. on Thanksgiving Day.
B. Christmas: Beginning in 2003 and every odd year thereafter, Mother shall
have custody of the Child from 7:00 p.m. on Christmas Eve through 2:00
p.m. Christmas Day. Father shall have custody of the Child from 2:00
p.m. on Christmas Day until 7:00 p.m. on Christmas Day. Beginning in
2004 and every even year thereafter, Father shall have custody of the
Child from 7:00 p.m. on Christmas Eve through 2:00 p.m. on Christmas
Day. Mother shall have custody of the Child from 2:00 p.m. on Christmas
Day until 7:00 p.m. on Christmas Day.
C. Mother shall have custody of the Child on Mother's Day from 10:00 a.m.
until 7:00 p.m. Father shall have custody of the Child on Father's Day
from 10:00 a.m. until 7:00 p.m.
6. The parties shall keep each other advised in the event of serious illness or
medical emergency concerning the Child and shall further take any necessary steps to
ensure that the health and well-being of the Child is protected. During such illness or
medical emergency, both parties shall have the right to visit the Child as often as he or
she desires consistent with the proper medical care of the Child.
Father shall provide health insurance coverage for the Child.
8. Transportation shall be shared. The parties shall exchange custody at the
Sheetz in Shippensburg.
9. Mother and Father agree to work together to insure the best interests of
their Child. Each parent agrees to at all times encourage -the Child to comply with the
terms of this Order as it relates to the periods of custody to be spend with the party.
While in the presence of the Child, neither of the parties shall make any remarks or do
anything that can in any way be construed as derogatory or uncomplimentary to the other
and it shall be the duty of each to uphold the other party as one to whom the Child should
respect and love.
10. Both parties shall insure that the Child will not view or have access to
inappropriate sexual material.
H. Either set of Grandparents is authorized to pick up the Child from school
and/or any homework assignments.
12. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control.
BY THE COURT,
s , G 1 r .?1?
J.
cc: Marylou Matas, Esquire, Counsel for Father
Richard L. Webber, Jr., Esquire, Counsel for Mother
TRUE COPY FROM RECORD
to Testimony whereof, 1 here unto set my hano
ang the ,seal of said Co at Carlisle, Pit.
fhi??dyY or,, ?2 ?cu3
Protho of rfi ?f y
VICTOR K. TAYLOR,
Plaintiff
V.
PAULA J. TAYLOR,
Defendant
PRIOR JUDGE: Edgar B. Bayley, J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:2003-2094 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
1. The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Victor Kyle Taylor
February 20, 1992
shared
2. A Conciliation Conference was held in this matter on June 11, 2003, with
the following individuals in attendance: The Father, Victor K. Taylor, with his counsel,
Marylou Matas, Esquire and the Mother, Paula J. Taylor, with her counsel, Richard L.
Webber, Jr., Esquire.
3. The Honorable Edgar B. Bayley entered an Order of Court dated May 8,
2003 denying Father's Petition for Special Relief.
4. The parties agreed to the entry of an Order in the form as attached.
Date acq line M. Verney, Esquire
Custody Conciliator
ca
rp
a
VICTOR K. TAYLOR
PLAINTIFF IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
v.
03-2094 CIVIL ACTION LAW
PAULA J. TAYLOR .
DEFENDANT IN CUSTODY
OR')ER --OF COURT
AND NOW, Wednesday, August 11, 2004 , Upon consideration Of the attached it is hereby directed that parties and their respective counsel appear before Jacqueline M Verney sq, Complaint,
at 4th Floor, Cumberland Count Courthouse, Carlisle on Thursda Se tember 02, 2004
4 the conciliator,
for aPre-Hearing Custody Conference. At such conference, an effort w? be'made to resolve the issues in at 9:30 dispute; AM
M
if this cannot be accomplished, to define and narrow the issues to be heard b:y the court, and to enter into a temporary
order. All children a entry 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 is/ taco: elin M. V
---- `ter Esa, __.--mhc
Custody Conciliator
Americans with CourDisabilitest Co Act of 1leas 990. f Cumberland County is required by law to comply
accommodations available to disabled individuals having business before the co?turt, 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 ATTO
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL ATTORNEY ALT ONCE. IF YOU DO NOT
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
h
C. pl, Z I 't IV UR
VICTOR K. TAYLOR,
Plaintiff
v.
PAULA J. TAYLOR,
Defendant
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2003-2094 CIVIL TERM
IN CUSTODY
PRAECIPE
Please withdraw the Petition for Modification of Custody riled on August 3, 2004.
Respectfully submitted,
Date: 9'a -D'1
I , 'l !J T?f A
Marylo atas, Esquire
Anorney for Plaintff
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
SEP 0 3 2004 p
VICTOR K. TAYLOR, : IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2003-2094 CIVIL TERM
PAULA J. TAYLOR, : CIVIL ACTION - LAW
Defendant/Respondent
IN CUSTODY
ORDER OF COURT
AND NOW, this 3`d day of September, 2004, the Conciliator having been advised
that the Petitioner has withdrawn his Petition for Modification of Custody, the
Conciliator hereby relinquishes jurisdiction in this matter.
FOR THE COURT,
icq? line M. Verney, Esquire, Custo4Conciliator
Kj
4-ri
r
)CI.
J
r?z
IN THE COURT OF COMMON PLEAS FOR
CUMBERLAND COUNTY, PENNSYLVANIA
VICTOR K. TAYLOR,
Plaintiff/Respondent
CIVIL ACTION - LAW
V.
PAULA J. TAYLOR,
Defendant/Petitioner
NO. 2003-2094 CIVIL TERM
IN CUSTODY
PETITION TO MODIFY CUSTODY
AND NOW, comes Defendant/Petitioner, Paula J. Taylor, by and through her counsel,
Richard L. Webber, Jr., Esquire, and Weigle & Associates, P.C., and petitions the Court
as follows:
1. The Defendant/Petitioner is Paula J. Taylor, an adult individual presently residing at
76 Carpenter Lane, Newburg, Cumberland County, Pennsylvania 17240.
2. The Plaintiff/Respondent is Victor K. Taylor, an adult individual presently residing at
619 Glenn Street, Shippensburg, Cumberland County, Pennsylvania 17257.
3. Defendant/Petitioner seeks custody of the following child:
NAME PRESENT RESIDENCE AGE
Victor Kyle Taylor 619 Glenn Street 12 years (DOB
Shippensburg, PA 17257 February 20, 1992)
AND
76 Carpenter Lane
Newburg, PA 17240
The child was not born outside the bonds of matrimony.
Custody of the child is presently shared equally by Plaintiff/Respondent Victor K. Taylor,
who resides at 619 Glenn Street, Shippensburg, Cumberland County, Pennsylvania 17257,
and Defendant/Respondent Paula J. Taylor, who resides at 76 Carpenter Lane, Newburg,
Cumberland County, Pennsylvania 17240.
WEIGL_E & ASSOCIATES. P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
During the past five years, the child has resided with the following persons and at the
following addresses:
4.
5.
NAME
Victor K. Taylor
Paula J. Taylor
Paula J. Taylor
Victor K. Taylor and
Paula J. Taylor
ADDRESS
619 Glenn Street
Shippensburg, PA 17257
76 Carpenter Lane
Newburg, PA 17240
76 Carpenter Lane
Newburg, PA 17240
76 Carpenter Lane
Newburg, PA 17240
DATE
December 1, 2002 to Present
(Shared physical
custody on a week on/
week off basis)
November 1, 2002 to
December 1, 2002
Birth to November 1, 2002
The mother of the child is Paula J. Taylor, currently residing at 76 Carpenter Lane,
Newburg, Cumberland County, Pennsylvania 17240. She is divorced.
The father of the child is Victor K. Taylor, currently residing at 619 Glenn Street,
Shippensburg, Cumberland County, Pennsylvania 17257. He is divorced.
The relationship of Defendant/Petitioner to the child is that of mother. The Defendant/
Petitioner currently resides with the following persons:
NAME RELATIONSHIP
Victor Kyle Taylor The Child (on a shared custody basis)
The relationship of Plaintiff/Respondent to the child is that of father. The Plaintiff/
Respondent currently resides with the following persons:
NAME RELATIONSHIP
Victor K. Taylor Father of Plaintiff/Respondent
Carole Taylor Mother of Plaintiff/Respondent
Victor Kyle Taylor The Child (on a shared custody basis)
6. Defendant/Petitioner has participated as a party or witness, or in another capacity, in other
litigation concerning the custody of the child in this or another court. Attached hereto,
labeled as Exhibit 1, and incorporated by reference herein is copy of Order of Court dated
June 13, 2003, entered to this same docket number.
Defendant/Petitioner has no information of a custody proceeding concerning the child
pending in another court of this Commonwealth.
WEIGLE & ASSOCIATES. P.C. - ATTORNEYS AT LAW -- 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397
Defendant/Petitioner does not know of a person, not a party to the proceedings, who has
physical custody of the child or claims to have custody or visitation rights with respect to
the child.
7. The best interest and permanent welfare of the child will be served by granting the relief
requested because:
A. The child desires to reside primarily with Defendant/Petitioner;
B. Defendant/Petitioner can provide a better home environment for the child; and
C. Plaintiff/Respondent admitted that he was charged with two separate DUI offenses
and that he faces possible incarceration. Defendant/Petitioner believes that
Plaintiff/Respondent's driving privileges have been suspended as a result of one of
the DUI offenses.
8. Each parent whose parental rights to the child have not been terminated and the person
who has physical custody of the child have been named as parties to this action. All other
persons, named below, who are known to have or claim a right to custody or visitation of
the child will be given notice of the pendency of this action and the right to intervene:
NAME ADDRESS BASIS OF CLAIM
None
WHEREFORE, Defendant/Petitioner requests the Court to grant primary custody of the
minor child to the Defendant/Petitioner.
WEIGLE & ASSOCIATES, P.C.
By: .?,
Richard L. Webber, Jr., Esquire
Attorney for Defendant/Petitioner
I.D.# 49634
126 East King Street
Shippensburg, PA 17257
Telephone 717-532-7388
WEIGLE & ASSOCIATES, P.C. -- ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
VERIFICATION
I verify that the statements made in the foregoing Petition to Modify Custody are true and
correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
4904, relating to unsworn falsification to authorities.
Dated: "a -0 ? ?0" .
Paula J. Taylor
WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW -- 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
.? ?uN 1 4 ZOd3 ,? J 4,u JUN 1 2 2003
VICTOR K. TAYLOR, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2003-2094 CIVIL TERM
PAULA J. TAYLOR : CIVIL ACTION - LAW
Defendant
: IN CUSTODY
ORDER OF COURT
AND NOW, this j3 t?-' day of , 2003, upon
consideration of the attached Custody Conci iation Report, it is ordered and directed as
follows:
1. The Father, Victor K. Taylor, and the Mother, Paula J. Taylor, shall have
shared legal custody of Victor Kyle Taylor, born February 20, 1992. Each parent shall
have an equal right, to be exercised jointly with the other parent, to make all major non-
emergency decisions affecting the Child's general well-being including, but not limited
to, all decisions regarding his health, education and religion. In this regard, the Child
shall not be removed from his current school district without prior Order of Court or
agreement of the parties.
2. The parents shall have shared physical custody of the Child on a week
on/week off basis. The day and time of exchange shall be Sunday at 5:30 p.m.
3. The parties shall notify each other fourteen (14) days in advance regarding
a request for an additional period of custody with the Child and/or a change in a
scheduled period of custody with the Child.
4. Summer Vacation:
A. Beginning the summer of 2003 and each odd year thereafter, Father shall
notify Mother of his selection of one consecutive week of summer vacation
and any single days of vacation no later than May 15th of each year. Mother
shall notify Father of her selection of one consecutive week of summer
vacation and any single days of vacation no later than June 15 of each year.
In the event the week is not a regular alternating week for the requesting
parent, the parties shall agree to exchange weeks to accommodate the other
parent.
B. Beginning the summer of 2004 and each even year thereafter, Mother shall
notify Father of her selection of one consecutive week of summer vacation
oo+?rrr
and any single days of vacation no later than May 15`' of each year. Father
shall notify Mother of his selection of one consecutive week of summer
vacation and any single days of vacation no later than June 15`h of each year.
In the event the week is not a regular alternating week for the requesting
parent, the parties shall agree to exchange weeks to accommodate the other
parent.
Holidays:
A. Thanksgiving: Mother shall have custody of the Child from 10:00 a.m. to
2:00 p.m. on Thanksgiving Day. Father shall have custody of the Child
from 2:00 p.m. to 7:00 p.m. on Thanksgiving Day.
B. Christmas: Beginning in 2003 and every odd year thereafter, Mother shall
have custody of the Child from 7:00 p.m. on Christmas Eve through 2:00
p.m. Christmas Day. Father shall have custody of the Child from 2:00
p.m. on Christmas Day until 7:00 p.m. on Christmas Day. Beginning in
2004 and every even year thereafter, Father shall have custody of the
Child from 7:00 p.m. on Christmas Eve through 2:00 p.m. on Christmas
Day. Mother shall have custody of the Child from 2:00 p.m. on Christmas
Day until 7:00 p.m. on Christmas Day.
C. Mother shall have custody of the Child on Mother's Day from 10:00 a.m.
until 7:00 p.m. Father shall have custody of the Child on Father's Day
from 10:00 a.m. until 7:00 p.m.
6. The parties shall keep each other advised in the event of serious illness or
medical emergency concerning the Child and shall further take any necessary steps to
ensure that the health and well-being of the Child is protected. During such illness or
medical emergency, both parties shall have the right to visit the Child as often as he or
she desires consistent with the proper medical care of the Child.
Father shall provide health insurance coverage for the Child.
8. Transportation shall be shared. The parties shall exchange custody at the
Sheetz in Shippensburg.
9. Mother and Father agree to work together to insure the best interests of
their Child. Each parent agrees to at all times encourage the Child to comply with the
terms of this Order as it relates to the periods of custody to be spentwith the party.
While in the presence of the Child, neither of the parties shall make any remarks or do
anything that can in any way be construed as derogatory or uncomplimentary to the other
and it shall be the duty of each to uphold the other party as one to whom the Child should
respect and love.
10. Both parties shall insure that the Child will not view or have access to
inappropriate sexual material.
11. Either set of Grandparents is authorized to pick up the Child from school
and/or any homework assignments.
12. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control.
BY THE COURT,
10"t7 (k&` q' J.
cc: Marylou Matas, Esquire, Counsel for Father
Richard L. Webber, Jr., Esquire, Counsel for Mother
TRUE COPY RIOM DWI D
in Testimony whereof, I bare unto t my hand
anO the seal of Bald ?.t at Giir "K Pa.
This '11-7 clay
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VICTOR K. TAYLOR IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
PAULA J. TAYLOR
DEFENDANT
03-2094 CIVIL ACTION LAW
. IN CUSTODY
ORDER OF COURT
AND NOW, Monday, December 06, 2004 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, January 04, 2005 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. 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/ jacgueline M. Verney, Esq, mnc
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)
_ ti r .r;
J
NOV 3 0 2004 t
IN THE COURT OF COMMON PLEAS FOR
CUMBERLAND COUNTY, PENNSYLVANIA
VICTOR K. TAYLOR, CIVIL ACTION - LAW
Plaintiff/Respondent
V.
NO. 2003-2094 CIVIL TERM
PAULA J. TAYLOR,
Defendant/Petitioner IN CUSTODY
ORDER OF COURT
AND NOW, this day of , 20 , 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 , 20at . 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 in to
a temporary order. All children 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.
BY THE COURT,
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 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
32 South Bedford Street
Carlisle, PA 17013
Telephone Number 717-249-3166
WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
IN THE COURT OF COMMON PLEAS FOR
CUMBERLAND COUNTY, PENNSYLVANIA
VICTOR K. TAYLOR,
PlaintifVRespondent
CIVIL ACTION - LAW
V.
PAULA J. TAYLOR,
Defendant/Petitioner
NO. 2003-2094 CIVIL TERM
IN CUS'T'ODY
PETITION TO MODIFY CUSTODY
AND NOW, comes Defendant/Petitioner, Paula J. Taylor, by and through her counsel,
Richard L. Webber, Jr., Esquire, and Weigle & Associates, P.C., and petitions the Court
as follows:
1. The Defendant/Petitioner is Paula J. Taylor, an adult individual presently residing at
76 Carpenter Lane, Newburg, Cumberland County, Pennsylvania 17240.
2. The Plaintiff/Respondent is Victor K. Taylor, an adult individual presently residing at
619 Glenn Street, Shippensburg, Cumberland County, Pennsylvania 17257.
3. Defendant/Petitioner seeks custody of the following child:
NAME PRESENT RESIDENCE AGE
Victor Kyle Taylor 619 Glenn Street 12 years (DOB
Shippensburg, PA 17257 February 20, 1992)
AND
76 Carpenter Lane
Newburg, PA 17240
The child was not born outside the bonds of matrimony.
Custody of the child is presently shared equally by Plaintiff/Respondent Victor K. Taylor,
who resides at 619 Glenn Street, Shippensburg, Cumberland County, Pennsylvania 17257,
and Defendant/Respondent Paula J. Taylor, who resides at 76 Carpenter Lane, Newburg,
Cumberland County, Pennsylvania 17240.
WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
During the past five years, the child has resided with the following persons and at the
following addresses:
4.
5
NAME
Victor K. Taylor
Paula J. Taylor
Paula J. Taylor
Victor K. Taylor and
Paula J. Taylor
ADDRESS
619 Glenn Street
Shippensburg, PA 17257
76 Carpenter Lane
Newburg, PA 17240
76 Carpenter Lane
Newburg, PA 17240
76 Carpenter Lane
Newburg, PA 17240
DATE
December 1, 2002 to Present
(Shared physical
custody on a week on/
week off basis)
November 1, 2002 to
December 1, 2002
Birth to November 1, 2002
The mother of the child is Paula J. Taylor, currently residing at 76 Carpenter Lane,
Newburg, Cumberland County, Pennsylvania 17240. She is divorced.
The father of the child is Victor K. Taylor, currently residing at 619 Glenn Street,
Shippensburg, Cumberland County, Pennsylvania 17257. He is divorced.
The relationship of Defendant/Petitioner to the child is that of mother. The Defendant/
Petitioner currently resides with the following persons:
NAME
Victor Kyle Taylor
RELATIONSHIP
The Child (on a shared custody basis)
The relationship of Plaintiff/Respondent to the chili] is that of father. The Plaintiff/
Respondent currently resides with the following persons:
NAME RELATIONSHIP
Victor K. Taylor Father of Plaintiff (Respondent
Carole Taylor Mother of Plaintiff/Respondent
Victor Kyle Taylor The Child (on a shared custody basis)
6. Defendant/Petitioner has participated as a party or witness, or in another capacity, in other
litigation concerning the custody of the child in this or another court. Attached hereto,
labeled as Exhibit 1, and incorporated by reference herein is copy of Order of Court dated
June 13, 2003, entered to this same docket number.
Defendant/Petitioner has no information of a custody proceeding concerning the child
pending in another court of this Commonwealth.
WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
Defendant/Petitioner does not know of a person, not a party to the proceedings, who has
physical custody of the child or claims to have custody or visitation rights with respect to
the child.
7. The best interest and permanent welfare of the child will be served by granting the relief
requested because:
A. The child desires to reside primarily with Defendant/Petitioner;
B. Defendant/Petitioner can provide a better home environment for the child; and
C. Plaintiff/Respondent admitted that he was charged with two separate DUI offenses
and that he faces possible incarceration. Defendant/Petitioner believes that
Plaintiff(Respondent's driving privileges have been suspended as a result of one of
the DUI offenses.
8. Each parent whose parental rights to the child have not been terminated and the person
who has physical custody of the child have been named as parties to this action. All other
persons, named below, who are known to have or claim a right to custody or visitation of
the child will be given notice of the pendency of this action and the right to intervene:
NAME ADDRESS BASIS OF CLAIM
None
WHEREFORE, Defendant/Petitioner requests the Court to grant primary custody of the
minor child to the Defendant/Petitioner.
WEIGLE. & ASSOCIATES, F.C.
Y
Richard L. Webber, Jr., Esquire
Attorney for Defendant/Petitioner
I.D.# 49634
126 East King Street
Shippensburg, PA 17257
Telephone! 717-532-7388
WEIGLE 5. ASSOCIATES. P.C. -- ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397
VERIFICATION
I verify that the statements made in the foregoing Petition to Modify Custody are true and
correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
4904, relating to unsworn falsification to authorities.
Dated:
Paula J. Taylor
WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
J yuu3 JUN 1 2 2003
iV 0 ,SUN , a 20
CD \fC?r-
VICTOR K. TAYLOR, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2003-2094 CIVIL TERM
PAULA J. TAYLOR : CIVIL ACTION - LAW
Defendant
: IN CUSTODY
ORDER OF COURT
AND NOW, this (3 day of Ou" , 2003, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. The Father, Victor K. Taylor, and the Mother, Paula J. Taylor, shall have
shared legal custody of Victor Kyle Taylor, born February 20, 1992. Each parent shall
have an equal right, to be exercised jointly with the other parent, to make all major non-
emergency decisions affecting the Child's general well-being including, but not limited
to, all decisions regarding his health, education and religion. In this regard, the Child
shall not be removed from his current school district without prior Order of Court or
agreement of the parties.
2. The parents shall have shared physical custody of the Child on a week
on/week off basis. The day and time of exchange shall be Sunday at 5:30 p.m.
3. The parties shall notify each other fourteen (14) days in advance regarding
a request for an additional period of custody with the Child and/or a change in a
scheduled period of custody with the Child.
4. Summer Vacation:
A. Beginning the summer of 2003 and each odd year thereafter, Father shall
notify Mother of his selection of one consecutive week of summer vacation
and any single days of vacation no later than May 15'h of each year. Mother
shall notify Father of her selection of one consecutive week of summer
vacation and any single days of vacation no later than June 15 of each year.
In the event the week is not a regular alternating week for the requesting
parent, the parties shall agree to exchange weeks to accommodate the other
parent.
B. Beginning the summer of 2004 and each even year thereafter, Mother shall
notify Father of her selection of one consecutive week of summer vacation
and any single days of vacation no later than May 15°i of each year. Father
shall notify Mother of his selection of one consecutive week of summer
vacation and any single days of vacation no later than June 15`h of each year.
In the event the week is not a regular alternating week for the requesting
parent, the parties shall agree to exchange weeks to accommodate the other
parent.
5. Holidays:
A. Thanksgiving: Mother shall have custody of the Child from 10:00 a.m. to
2:00 p.m. on Thanksgiving Day. Father shall have custody of the Child
from 2:00 p.m. to 7:00 p.m. on Thanksgiving Day.
B. Christmas: Beginning in 2003 and every odd year thereafter, Mother shall
have custody of the Child from 7:00 p.m. on Christmas Eve through 2:00
p.m. Christmas Day. Father shall have custody of the Child from 2:00
p.m. on Christmas Day until 7:00 p.m. on Christmas Day. Beginning in
2004 and every even year thereafter, Father shall have custody of the
Child from 7:00 p.m. on Christmas Eve through 2:00 p.m. on Christmas
Day. Mother shall have custody of the Child from 2:00 p.m. on Christmas
Day until 7:00 p.m. on Christmas Day.
C. Mother shall have custody of the Child on Mother's Day from 10:00 a.m.
until 7:00 p.m. Father shall have custody of the Child on Father's Day
from 10:00 a.m. until 7:00 p.m.
6. The parties shall keep each other advised in the event of serious illness or
medical emergency concerning the Child and shall further take any necessary steps to
ensure that the health and well-being of the Child is protected. During such illness or
medical emergency, both parties shall have the right to visit the Child as often as he or
she desires consistent with the proper medical care of the Child.
Father shall provide health insurance coverage for the Child.
8. Transportation shall be shared. The parties shall exchange custody at the
Sheetz in Shippensburg.
9. Mother and Father agree to work together to :insure the best interests of
their Child. Each parent agrees to at all times encourage the Child to comply with the
terms of this Order as it relates to the periods of custody to be spentwith the party.
While in the presence of the Child, neither of the parties shall make any remarks or do
anything that can in any way be construed as derogatory or uncomplimentary to the other
and it shall be the duty of each to uphold the other party as one to whom the Child should
respect and love.
10, Both parties shall insure that the Child will not view or have access to
inappropriate sexual material.
11. Either set of Grandparents is authorized to pick up the Child from school
and/or any homework assignments.
12. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control.
BY THE COURT,
J.
cc: Marylou Matas, Esquire, Counsel for Father
Richard L. Webber, Jr., Esquire, Counsel for Mother
TRUE. COPY FROM REWIRD
In Testimony wherw?b, 1 bare urg,,) sa-1 gay fl-and
anO the sli t of klild C at Cwftm' .
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JAN 0 5 2005
VICTOR K. TAYLOR, : IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2003-2094 CIVIL TERM
PAULA J. TAYLOR : CIVIL ACTION - ;LAW
Defendant/Petitioner
IN CUSTODY
ORDER OF COURT
AND NOW, this day of Z z o . , 2005, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
The prior Order of Court dated June 13, 2003 is hereby vacated.
2. Mother, Paula J. Taylor, shall have sole legal and physical custody of
Victor Kyle Taylor, born February 20, 1992.
3. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control.
BY THE COURT,
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cc: Richard L. Webber, Jr., Esquire, Counsel for Mother
Victor K. Taylor, pro se
619 Glenn Street
Shippensburg, PA 17257
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JAN 0 5 2005 J
VICTOR K. TAYLOR, : IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA
V. :2003-2094 CIVIL 7CERM
PAULA J. TAYLOR, : CIVIL ACTION - LAW
Defendant/Petitioner
IN CUSTODY
PRIOR JUDGE: J. Wesley Oler, Jr., J.
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 Child who is the subject of this
litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Victor Kyle Taylor February 20, 1992 shared
2. A Conciliation Conference was held in this matter on January 4, 2005,
with the following individuals in attendance: The Mother, Paula J. Taylor, with her
counsel, Richard L. Webber, Jr., Esquire and Father, Victor K. Taylor, pro se.
3. The Honorable J. Wesley Oler, Jr. previously entered an Order of Court
dated June 13, 2003 providing for shared legal and shared physical custody.
4. The parties agreed to the entry of an Order i:n the form as attached.
/- N-6)i
Date
cq eline M. Verney, Esquire
Custody Conciliator
IN THE COURT OF COMMON ]PLEAS FOR
CUMBERLAND COUNTY, PENNSYLVANIA
VICTOR K. TAYLOR, CIVIL ACTION - LAW
Plaintiff
V. NO. 2003-2094 CIVIL TERM
PAULA J. TAYLOR,
Defendant IN CUSTODY
AFFIDAVIT OF SERVICE
I, Wayne Shannon, a Pennsylvania State Constable, the undersigned adult individual,
having been duly sworn upon my oath, state that I did serve a copy of the attached Petition
to Modify Custody and Order of Court dated December 6, 2004, upon Victor Taylor, an
adult member of the family residing with Victor K. Taylor, the Plaintiff, at 619 Glenn Street,
Shippensburg, Pennsylvania 17257, by personally handing a copy of the Petition and Order to
him, on the 3rd day of January, 2005, at 3:30 o'clock P.M.
Dated: I 1z
Subscribed and sworn to before me the
un rsigned Notary Public on the
day ofd n LA? , 2005.
NOiIv^ sm
MMULlow
HAW PAdft
W , b0ft Jun 7.2005
tj
Wayne S on
Pennsylvania State Constable
WEIGLE & ASSOCIATES. P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
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VICTOR K. TAYLOR,
Plaintiff
V.
PAULA J. TAYLOR,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2003-2094 CIVIL TERM
IN CUSTODY
PETITION FOR MODIFICATION OF CUSTODY
AND NOW, comes Petitioner, Victor K. Taylor, by and through his legal counsel of
record, Hannah Herman-Snyder, Esquire, and the law firm of Griffie & Associates petitions the
Court as follows:
1. Your Petitioner is the above-named Plaintiff, Victor K. Taylor, an adult individual
currently residing at 322 Walnut Dale Road, Shippensburg, Cumberland County,
Pennsylvania.
2. Your Respondent is the above-named Defendant, Paula J. Taylor, an adult
individual currently residing at 76 Carpenter Lane, Newburg, Cumberland County,
Pennsylvania.
3. The parties are the natural parents of one child, Victor Kyle Taylor, born February
20, 1992.
4. The parties are subject to an Order of Court dated January 6, 2005, which is
attached hereto and incorporated herein by reference as Exhibit "A."
5. Petitioner entered into an Agreement, which became the Order of Court on January
6, 2005, with the understanding that he would be permitted to maintain telephone
and written contact with the child.
6. Since February, 2005, Petitioner has had no contact with the child.
7. In the past six months, Petitioner has repeatedly left telephone messages for the
child at the child's last known residence and has never received a return call.
8. Petitioner has made an average of one call per week for the past six months to the
child's last known residence.
9. Petitioner has attempted to communicate with the child by way of written
correspondence and has written approximately four to five letters to the child in the
past six months and has received no response.
10. It is in the best interest and permanent welfare of the child to have contact with
Petitioner, beginning with telephone and written contact.
11. Petitioner acknowledges that it has been some time since he has had any contact
with the child and, therefore, would like to work on having partial custody on a
graduated basis, beginning with a four-hour period every other Saturday and
working up to an every other weekend schedule.
12. It is in the best interest and permanent welfare of the child to grant Petitioner
periods of partial physical custody and telephone and written contact.
13. It is in the best interest and permanent welfare of the child to grant Petitioner shared
legal custody of the child so that he may be a part of the decision making in the
child's life.
WHEREFORE, Petitioner requests your Honorable Court to schedule a conciliation
conference, followed by a hearing, if necessary, and enter an Order accordingly.
Respectfully submitted,
V,,?)-, k f-&,
Victor K. Taylor, pro s
322 Walnut Dale Road
Shippensburg, PA 17257
VERIFICATION
I verify that the statements made in the foregoing document 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 unworn falsifications to authorities.
DATE: AE oS A`
VICTOR K. TAYLOR, etitioner
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VICTOR K. TAYLOR
PLAINTIFF
V.
PAULA J. TAYLOR
DEFENDANT
AND NOW, M
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
03-2094 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
November 21, 2005 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, January 03, 2006 _ 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. 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 Custodv orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/ Jacguelrr:e M. Verney, Esq. 1 / 6
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
J7(2 j-C.,o
JAN 0 3 Z006
VICTOR K. TAYLOR, : IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2003-2094 CIVIL TERM
PAULA J. TAYLOR : CIVIL ACTION - LAW
Defendant/Respondent
IN CUSTODY
ORDER OF COURT
AND NOW, this 3, day of 72t7 , 2006, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. The prior Order of Court dated January 6, 2005 shall remain in full force
and effect with the following modification.
2. Father shall participate in counseling with the child. Both parents shall
sign necessary releases if requested by the counselor.
3. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control. Another
Conciliation Conference is scheduled for April 4, 2006 at 9:30 a.m.
cc 'ictor K. Taylor, pro se
322 lnut Dale Road
ippensburg, PA 17257
. . ichard L. Webber, Jr., Esquire, Counsel for Mother
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VICTOR K. TAYLOR, : IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA
V. : 2003-2094 CIVIL TERM
PAULA J. TAYLOR, : CIVIL ACTION - LAW
Defendant/Respondent
IN CUSTODY
PRIOR JUDGE: J. Wesley Oler, Jr., J.
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 Child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Victor Kyle Taylor
February 20, 1992
Mother
1 A Conciliation Conference was held in this matter on January 3, 2006,
with the following individuals in attendance: The Father, Victor K. Taylor, pro se and the
Mother, Paula J. Taylor, with her counsel, Richard L. Webber, Jr., Esquire.
3. The Honorable J. Wesley Oler, Jr. previously entered an Order of Court
dated January 6, 2005 providing for Mother to have sole legal and sole physical custody.
4. The parties agreed to the entry of an Order in the form as attached.
1-3 -off _ 1
Date ,Jacq ine M. Verney, Esquire
Custody Conciliator
,APR 0 p(in
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VICTOR K. TAYLOR, : IN THE COURT OF COMMON PLEliv
Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2003-2094 CIVIL TERM
PAULA J. TAYLOR : CIVIL ACTION - LAW
Defendant/Respondent
IN CUSTODY
ORDER OF COURT
AND NOW, this 5 day of A a "t--, 2006, upon
consideration of the attached Custody Conciliation Rep rt, it is ordered and directed as
follows:
1. The prior Orders of Court dated January 6, 2005 and January 3, 2006 shall
remain in full force and effect with the following modification.
2. Mother shall have primary physical custody of the child.
3. Father shall have periods of partial physical custody one weekend per
month from Friday at 6:00 p.m. to Sunday at 6:00 p.m. Father and son shall determine
which weekend it will be at the beginning of every month.
4. Father shall be entitled to additional time as requested by the child.
5. Father shall have one uninterrupted week in the summer provided he give
Mother 30 days prior notice and Father's week does not conflict with Mother's week.
6. It is understood that Kyle will take his medication while in Father's
custody.
Transportation shall be shared as agreed by the parties.
8. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control.
O\
BY THE COURT,
J. WAsley Oler, Jr.,
J.
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cc: Victor K. Taylor, pro se
322 Walnut Dale Road
Shippensburg, PA 17257
Richard L. Webber, Jr., Esquire, Counsel for Mother
AFR 1 )P6
VICTOR K. TAYLOR, : IN THE COURT OF COMMON PLEAS Of'
Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA
V. :2003-2094 CIVIL ACTION - LAW
PAULA J. TAYLOR,
Defendant/Respondent : IN CUSTODY
PRIOR JUDGE: J. Wesley Oler, Jr., J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the `ollowing,
report:
The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Victor Kyle Taylor February 20, 1992 Mother
2. A Conciliation Conference was held in this matter on April 4, 2006, with
the following individuals in attendance: The Father, Victor K. Taylor, pro se and the
Mother, Paula J. Taylor, with her counsel, Richard L. Webber, Jr., Esquire.
3. The Honorable J. Wesley Oler, Jr. previously entered Orders of Court
dated January 6, 2005 and January 3, 2006 providing for Mother to have sole legal and
sole physical custody, and Father cooperating with counseling.
4. The parties agreed to the entry of an Order in the form as attached.
Date cqu 'ne M. Verney, Esquire
Custody Conciliator
_6
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PLAINTIFF
V.
Plij)L,A j: TA&."("
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
/VCL' CIVIL ACTION LAW
IN CUSTODY
Custody Stipulations
Father(Victor k Taylor) will have sole physical custody while the mother ( Paula Jean
Taylor) will have shared legal custody. Mother shall have visitation twice a month.
Mother will provide medical and dental insurance.
Father
Victor K Taylor
V'f'- /\-, 1??
Mother
Paula Jean Taylor
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Sworn an-'j xuboviboa *
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COMMONWEALTH j-4 PINNSYLVANIA
NOTARIAL SEAL
VIKI HRONIS, Notary Public
Cumberland County, Shippensburg, PA
My Commission Expires December 9, 2012
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FILED-t4-rK_,"
OF THE PPP +";H-N!' TARY
2009 JUN 12 AM 9: 5 U
JUN 1 5 2009
)Ii dbR K-1iY'VM IN THE COURT OF COMMON PLEAS OF
pu F : CUMBZRLAM COUNTY, PENNSYLVANIA
V. NICL V*3-IM CML ACTION LAW
PAW-4 1. VAR IN CUSTODY
DEFENDANT
?,? it is hereby
Z
AND NOW, 05 day of
OMMM aad DBCRM d" the auadced Oa o* S"ulatwu is made and catered as
an OMW of dais Court.
BY THE COURT:
Fadw(Victor k Taylor) will have wk physical c uAWy vdn)c the mother ( Paula Jean
Taylor) win have shwed legal custody. Mother shall have vWtabon twice a month.
Madvw will provide medical and dental wMavnm.
Father
Victor K Taylor
Vr,?- t= T
Modes
_ NOT APA& sFx Paula Jean Taylor
Ap Ounniwion E*= Dsoambw a 8D12 X.
RLEC-?: r V ?C E
OF THE
2009 JUN 17 All 11: 4 0
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