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SHARON L. WOLF,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYL VANIA
V.
: NO. 2001-1822 CIVIL TERM
JAMES L. BROOM, JR,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this t'J 11, day of r4;> I ,2001, upon
consideration ofthe attached Custody Conciliation Report, it is ordered and directed as
follows:
1. The prior Order of Court dated March 29,2001 is hereby vacated.
2. The Mother, Sharon 1. Wolf, and the Father, James 1. Broom, Jr., shall
have shared legal custody of Kayla R. Wolf, born July 25, 2000.' 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 her health, education and religion.
3. Mother shall have primary physical custody of the child with Father
having periods of partial custody as follows:
A. Beginning Sunday, May 5, 2001 at 6:00 p.m. to Sunday May 12,2001 at
12:00 noon and alternating thereafter on a weekly basis from Sunday at
6:00 p.m. to Sunday at 12:00 noon.
B. Such other times as the parties agree.
4. The following holidays shall be split with each party having a block of
time as they agree: Easter, the child's birthday and Thanksgiving.
5. The Christmas holiday shall be in two blocks which shall be alternated by
the parties with Block A being December 24, at 12:00 noon to December 25 at 12:00
noon and Block B being from December 25 at 12:00 noon to December 26 at 12:00 noon.
Father shall have Block A in odd numbered years; Mother shall have Block A in even
numbered years.
6. Mother shall have time with the child on Mother's Day; Father shall have
time with the child on Father's Day.
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Each parent shall have time with the child on their respective birthdays.
8.
Father shall provide transportation unless agreed otherwise by the parties.
9. The parties shall keep each other advised immediately relative to any
emergencies, medical or otherwise, 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, each party shall have the right to visit the child as
often as helshe deems consistent with the proper medical care of the child.
10. 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,
cc: Joan Carey, Esquire - Counsel for Mother
Tim Colgan, Esquire - Counsel for Father
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SHARON L, WOLF,
Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLV ANIA
CIVIL ACTION - LAW
V.
JAMES L. BROOM, JR.,
Defendant
: NO.2001-1822 CIVIL TERM
: IN CUSTODY
PRIOR JUDGE: J. WESLEY OLER, JR
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
Kay1a R. Wolf
July 25, 2000
Mother
2. A Conciliation Conference was held May 2, 2001 with the following
individuals in attendance: The Mother, Sharon 1. Wolf, with her counsel, Joan Carey,
Esquire, and David Lopez, Esquire, and the Father, James 1. Broom, Jr., with his
counsel, Tim Colgan, Esquire.
3. The Court previously entered an Order on March 29,2001 as a result of
Mother's Petition for Special Relief. The Order provided for shared legal custody and
primary physical custody with Mother. Father was granted partial physical custody as the
parties agree.
4. The parties agreed to entry of an Order in the form attached.
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acq ine M. Verney, Esquire
Custody Conciliator
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SHARON L. WOLF,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LAW
JAMES L. BROOM, JR.,
Defendant
NO. 01-1822 CIVIL TERM
ORDER OF COURT
AND NOW, this 29th day of March, 2001, upon consideration of Plaintiffs
Petition for Special Relief respecting the parties' child, Kayla R. Wolf (d.o.b. July 25,
2000), it is ordered and directed as follows:
1. A hearing on the petition is scheduled for Monday, April 9,
2001, at 1:30 p.m., in Courtroom No. I, Cumberland County
Courthouse, Carlisle, Pennsylvania.
2. Pending the hearing, legal custody of the child shall be shared
by the parties, primary physical custody of the child shall be in the
mother, and partial or temporary physical custody of the child shall
be in the father at such times as the parties mutually agree.
BY THE COURT,
Joan Carey, Esq.
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
Attorney for Plaintiff
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James L. Broom, Jr.
400 East Spring Valley Road
Dillsburg, PA 17019
Defendant, Pro Se
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Sharon L. Wolf,
Plaintiff/ Petitioner
:IN THE COURT OF COMMON PLEAS OF
v.
:CUMBERLAND COUNTY, PENNSYLVANIA
:NO.OI-!~CIVIL TERM
James L. Broom, Jr.,
Defendant! Respondent
:CUSTODY
TEMPORARY CUSTODY ORDER
AND NOW, this day of ,2001, upon consideration of the attached
Petition for Special Relief, the following Order is entered regarding custody of Kayla R. Wolf,
born July 25, 2000.
1. Plaintiff, Sharon L. Wolf, hereinafter referred to as the mother, shall have primary
physical and legal custody of the child.
2. Defendant, James L. Broom, Jr., hereinafter referred to as the father, shall have
partial custody of the child at times and places agreed upon by the parties.
3. The police shall enforce this Order and facilitate the transfer of custody to the
mother, Sharon Wolf.
4. This Order is entered without prejudice to either party to request a hearing.
5. This Order shall remain in effect pending further Order of Court.
By the Court,
Joan Carey
Attorney for PlaintifflPetitioner
James L. Broom
Defendant/Respondent
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Sharon L. Wolf,
Plaintiff I Petitioner
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYL VANIA
vo
:NO.
CIVIL TERM
James L. Broom, Jr.,
Defendant! Respondent
:CUSTODY
PETITION FOR SPECIAL RELIEF
PlaintifflPetitioner, Sharon L. Wolf, by and through her counsel, Joan Carey of MidPenn
Legal Services, states the following:
1. Petitioner is the above-named Plaintiff, hereinafter referred to as the mother, who
currently resides at 447 D Whiskey Run Road, Newville, Cumberland County, Pennsylvania.
20 Respondent is the above-named Defendant, James L. Broom, hereinafter referred to
as the father, who resides at 400 East Spring Valley Road, Dillsburg, York County, Pennsylvania.
30 The above-named parties are the natural parents of Kayla R.Wolf, born July 25,
2000.
4. The mother has filed a Complaint for Custody contemporaneously with the filing of
this Petition for Special Relief and has requested that a Conciliation Conference be scheduled.
50 It is in the child's best interest to be in the custody ofthe mother for reasons including
the following:
a)
b)
The mother has been the child's primary care-giver since her birth;
The mother has health insurance and other assistance to support the child;
6. The father has not acted in the child's best interest in ways including, but not limited
to the following:
a)
b)
c)
The father had no contact with the child before March of 200 1.
On or about March 25, 2001, after only his second weekend visit with the
child, the father refused to return the child to her mother saying that he
was keeping the child.
The father has refused to return the child to the mother in spite of requests
made by her and MidPenn Legal Services staff.
7. The father has told the mother that he is enrolled in the Army and is leaving in April,
therefore, he will not be able to exercise custody of the child.
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8. Without this Court's intervention, the child will be harmed by being further denied
the care and nurturing of her mother who has been her primary care-giver since her birth.
WHEREFORE, Plaintifflpetitioner requests the following:
a) The Court grant the Plaintiff temporary custody of her child pending further
order of court following a conciliation conference.
b )Any other relief this Court deems just and proper.
Respectfully submitted,
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{/olih Carey
Attorney for Plaintiff! Petitioner
MidPenn Legal Services
8 Irving Row
Carlisle, P A 17013
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VERIFICATION
I, Sharon 1. Wolf, verify that I am the Petitioner as designated in the present action and that
the facts and statements contained in the above Petition are true and correct to the best of my
knowledge. I understand that any false statements are made subject to the penalties of 18
Pa.C.S.~4904, relating to unsworn falsification to authorities.
Sharon 1. W
PlaintifflPef . oner
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SHARON 1. WOLF ,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
V.
:No. 01-1822 CIVIL TERM
JAMES 1. BROOM, JR.,
Defendant
:CIVIL ACTION- LAW
CERTIFICATE OF SERVICE
I, Jennifer Hernandez, do hereby certify that on the 4TH day
of Aoril,2001, I served a true and correct copy of the foregoing
Complaint for Custody, Petition for Special Relief, Temporary
Custody Order on the Defendant, James L. Broom, Jr., at the
address set forth below, by certified mail, restricted delivery,
return receipt requested.
James L. Broom, Jr.
400 East Spring Valley Road
Dillsburg, PA 17019
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Date
Hernandez, Le
idpenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717)243-9400
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SHARON L. WOLF,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LAW
JAMES L. BROOM, JR.,
Defendant
NO. 01-1822 CIVIL TERM
PLAINTIFF'S PETITION FOR SPECIAL RELIEF
ORDER OF COURT
AND NOW, this 9th day of April, 2001, upon relation of Joan Carey, Esq.,
attorney for Plaintiff, that the above matter has been amicably resolved, the hearing
previously scheduled in this matter for Apri19, 2001, is cancelled.
BY THE COURT,
Joan Carey, Esq.
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
Attorney for Plaintiff
Timothy J. Colgan
1 S. Baltimore Street
Dillsburg, PA 17019
Attorney for Defendant
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Sharon Louise Wolf
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
James Lee Broon, Jr.
Defendant
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NO. CIVIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Sharon Louise Wolf, Plaintiff, to proceed in forma DauDeris.
I, Joan Carev, attorney for the party proceeding in forma DauDeris, certify that I believe the party is
unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing
inability to pay the costs of litigation is attached hereto.
o Carey, Attorney aw
Attorney for Sharon Louise Wolf
MIDPENN LEGAL SERVICES
8 Irvine Row
Carlisle PA 17013
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Sharon Louise Wolf
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
James Lee Broon, Jr.
Defendant
NO.
CIVIL TERM
AFFIDAVIT IN SUPPORT OF PETITION
FOR LEAVE TO PROCEED IN FORMA PAUPERIS
I. I am the plaintiff in the above matter and because of my financial condition am unable to pay the
fees and costs of prosecuting, defending, or appealing the action or proceeding.
2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of
litigation.
3. I represent that the information below relating to my ability to pay the fees and costs is true and
correct.
(a) Name: Sharon Louise Wolf
Address: 447 D Whiskev Run Road. Newville PA 17241
(b) Social Security Number: 171-56-9073
If you are presently employed, state
Employer: NIA
Address:
Salary or wages per month:
Type of work:
If you are presently unemployed, state
6
Date of last employment: Avril 2000
Salary or wages per month: $ 6.00/hour
Type of work: Clerical/Sales
(c) Other income within the past twelve months
Business or profession:
Other self-employment:
Interest:
Dividends:
Pension and annuities:
Social Security benefits:
Support payments:
Disability payments:
Unemployment compensation and
supplemental benefits:
Workman's compensation:
Public Assistance: $316.00/month
Other:
(d) Other contributions to household support
(Wife)(Husband) Name:
If your (husband) (wife) is employed, state
Employer:
Salary or wages per month:
Type of work:
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Contributions from children:
(e) Property owned
Cash: None
Checking Account:
Savings Account:
Certificates of Deposit:
Real Estate (including home):
Motor vehicle: Make Year
Cost Amount owed
(g) Persons dependent upon you for support
(Wife) (Husband) Name:
Children, if any:
Name: Wolf. Kayla
Age: 8 months
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4. I understand that I have a continuing obligation to inform the court of improvement in my
financial circumstances which would permit me to pay the costs incurred herein.
5. I verify that the statements made in this affidavit 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.
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SHARON L. WOLF
PLAINTIFF
V.
JAMES L. BROOM, JR.
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-1822 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Friday, March 30, 2001 , upon consideration ofthe attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cnmberland County Conrthonse, Carlisle on Wednesday, May 02, 2001 at 1:30 p.m.
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to defme 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,
SpeciaI Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: Isl
Jacqueline M. Verney. Esq.tP
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 1HIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE 1HE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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Sharon L. Wolf,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
vs.
CUMBERLAND COUNTY, PENNSYLVANIA
: NO.O(-(!f)).. CIVIL TERM
James 1. Broom, Jr.,
Defendant
: CUSTODY
ORDER OF COURT
AND NOW, upon consideration of the attached complaint, it is hereby directed that the
parties and their respective counsel appear before
the conciliator, at on the _ day of ,2001, at _ .m., for
a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues
in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court,
and to enter into a temporary order. Failure to appear at the conference may provide grounds for
entry of a temporary or permanent order.
By the Court,
Date
Custody Conciliator
YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OF.FICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
CUMBERLAND COUNTY BAR ASSOCIA nON
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166 OR (800) 990-9108
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact
our office. All arrangements must be made at least 72 hours prior to any hearing or business before
the court. You must attend the scheduled conference or hearing.
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Sharon L. Wolf,
IN TilE COURT OF COMMON PLEAS OF
Plaintiff
vs.
CUMBERLAND COUNTY, PENNSYL VANIA
: NO.O\ -m1- CIVIL TERM
James L. Broom, Jr.
Defendant
: CUSTODY
COMPLAINT FOR CUSTODY
I. The plaintiff is Sharon L. Wolf, residing at 447 D Whiskey Run Road, Newville,
Pennsylvania, Cumberland County, Pennsylvania.
2. The defendant is James L. Broom, Jr., residing at 400 East Spring Valley Road,
Dillsburg, York County, Pennsylvania.
3. The plaintiff seeks custody of the following child:
Name
Kayla R. Wolf
Present Residence
400 East Spring Valley Road, Dillsburg, PA
Age
8 mo.
4. The child was born out of wedlock.
5. The child has lived with James L. Broom, Jr., the father, who resides at 400 East
Spring Valley Road, Dillsburg, York County, Pennsylvania, since March 25, 2001 when he
refused to return the child to her mother after only his second weekend with her since her birth.
6. During the child's lifetime, she has resided with the following persons and at the
following addresses:
From 7/25/00 until 8/00 at the Harvon Motel, Carlisle, with the mother.
From 8/00 until 10/00 at Safe Harbor, Carlisle, with the mother.
From 10/00 until 12/00 at 12 Valley Road, Newville, PA, with Connie and Ralph
Moffett and the mother.
From 12/00 until 3/23/01 at 447D Whiskey Run Road, Newville, Pennsylvania,
with Todd Shaffer, Gracie Shaffer, and the mother.
From 3/23/01 until the present at 400 East Spring Valley Road, Dillsburg,
Pennsylvania, with the child's father, James L. Broom, Jr., the child's paternal
grandfather; James L. Broom, Sr., and the child's paternal grandmother, Barbara
Broom.
7. The mother of the child is the plaintiff, Sharon L. Wolf, currently residing at 447D
Whiskey Run Road, Newville, Pennsylvania.
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The mother is single.
8. The father ofthe child is the defendant, James 1. Broom, Jr., currently residing at 400
East Spring Valley Road, Dillsburg, York County, Pennsylvania.
The father is single.
9. The relationship of the plaintiff to the child is that of mother.
10. The relationship of the defendant to the child is that of father.
II. The defendant currently resides with the following persons:
Name
James 1. Broom, Sr.
Barbara Broom
Relationship
Child's paternal grandfather
Child's paternal grandmother
12. The plaintiff has not participated as a party or witness, or in another capacity, in other
litigation concerning the custody of the child in this or another court.
13. The plaintiff has no information on a custody proceeding concerning the child
pending in a court of this Commonwealth.
14. The child is in the current physical custody of her father because after having the child
for only his second weekend since her birth, the father refused to return the child to her mother.
15. The best interest and permanent welfare of the child will be served by granting the
relief requested for reasons including but not limited to, the following:
a) The plaintiff is the child's natural mother and has been her primary caretaker
since her birth.
b) The plaintiff has provided and can continue to provide for the needs of the
child.
c) The father has not acted in the child's best interest by denying the mother
custody of the child.
d) The child's paternal grandfather, one of the persons with whom she currently
resides, is an alcoholic and may present a danger to the child's welfare.
e) The father has told the mother that he is enrolled in the Army and is leaving in
April, and cannot exercise custody of the child.
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16. Both parents whose parental rights to the child have not been terminated have been
named as parties to this action.
WHEREFORE, the plaintiff requests this Court to grant primary physical custody of the
child to the plaintiff with visitation for the defendant at the times and places agreed upon by the
parties.
Respectfully submitted,
o Carey
Attorney for Plaintiff
MIDPENN LEGAL SERVICES
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
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VERIFICATION
I verifY that I, Sharon 1. Wolf, am the Plaintiff in the present action and that the facts and
statements contained in the above Complaint are true and correct to the best of my knowledge. I
understand that any false statements are made subject to the penalties of 18 Pa.C.S. S4904, relating
to unsworn falsification to authorities.
Dated::sb~r ry(
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