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HomeMy WebLinkAbout01-2015 FX JASON W. HOCKENBERRY PlaintiffJRespondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - CUSTODY WENDY M. STINE Defendant/Petitioner NO. 01-2015 CIVIL TERM ORDER OF COURT AND NOW, this day of June, 2001, upon consideration ofthe Defendant/Petitioner's Petition for Special Relief to stay Recommended Order of Conciliator Pending a Hearing, the following Order is entered regarding Custody of Bryson Wayne Hockenberry, born April 10, 2000: 1. Defendant/Petitioner, Wendy M. Stine, hereinafter referred to as the mother and PlaintifflRespondent, Jason Hockenberry, hereinafter referred to as the father, shall share legal custody. 2. The mother shall have primary physical custody. 3. The father shall have partial custody according to the following schedule: a. Every other weekend from Saturday at II :00 a.m. until Sunday at 1 :00 p.m. b. From II :00 a.m. to 5:00 p.m. on the alternate Sundays. c. Two evenings each week from 5:00 p.m. until 8:00 p.m. d. Other times agreed upon by the parties. 4. Defendant shall submit to a drug screening blood test within 24 hours of the entry of this Order. 5. A full custody hearing is scheduled for the day of ,2001, at .m., in Court Room No. ofthe Cumberland County Courthouse, Carlisle, Pennsylvania. ,~;;=" '-' ,-"~-,, . > l . , f .. ,"~"'''''''~~ This Order shall remain in effect pending further Order of the Court after a hearing. By the Court, J. Wesley Oler, Jr., Judge Galen R. Waltz, Attorney for Plaintiff/Respondent 28 South Pitt Street Carlisle, P A 17013 Joan Carey, Attorney for DefendantlPetitioner Mid-Penn Legal Services 8 Irvine Row Carlisle, P A 17013 """"~ ,JUt 82001" JASON W. HOCKENBERRY Plaintiffi'Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CNIL ACTION - CUSTODY WENDY M. STINE DefendantlPetitioner NO. 01-2015 CIVIL TERM ORDER OF COURT AND NOW, this day of June, 2001, upon consideration of the DefendantIPetitioner's Petition for Special Relief to stay Recommended Order of Conciliator Pending a Hearing, the following Order is entered regarding Custody of Bryson Wayne Hockenberry, born AprillO, 2000: 1. The Order of April 11 , 2001 shall remain in effect pending further Order of the Court. 2. Defendant shall submit to a drug screening blood test within 24 hours ofthe entry of this Order. 3. A hearing regarding Plaintiffs petition for special relief is scheduled for the day of ,2001, at .m., in Court Room No. of the Cumberland County Courthouse, Carlisle, Pennsylvania. ~ ' 4. A full custody hearing is scheduled for the day of ,2001, at .m., in Court Room No. of the Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, J. Wesley O1er, Jr., Judge Galen R. Waltz, Attorney for PlaintifflRespondent 28 South Pitt Street Carlisle, P A 17013 Joan Carey, Attorney for DefendantlPetitioner Mid-Penn Legal Services 8 Irvine Row Carlisle, PA 17013 ''''''f~ ".._-~. - " ~-'~ ~~'" - ,,~ . . ... . ... JASON W. HOCKENBERRY Plaintiffi'Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - CUSTODY WENDY M. STINE Defendant/Petitioner NO. 01-2015CML TERM ORDER OF COURT AND NOW, this day ofJune, 2001, upon consideration of the Defendant/Petitioner's Petition for Special Relief to stay Recommended Order of Conciliator Pending a Hearing, the following Order is entered regarding Custody of Bryson Wayne Hockenberry, born April 10, 2000: 1. Defendant/Petitioner, Wendy M. Stine, hereinafter referred to as the mother and Plaintiff/Respondent, Jason Hockenberry, hereinafter referred to as the father, shall share legal custody. 2. The mother shall have primary physical custody. 3. The father shall have partial custody according to the following schedule: a. Every other weekend from Saturday at II :00 a.m. until Sunday at I :00 p.m. b. From 11:00 a.m. to 5:00 p.m. on the alternate Sundays. c. Two evenings each week from 5:00 p.m. until 8:00 p.m. d. Other times agreed upon by the parties. 4. Defendant shall submit to a drug screening blood test within 24 hours of the entry of this Order. 5. A full custody hearing is scheduled for the day of ,2001, at .m., in Court Room No. of the Cumberland County Courthouse, Carlisle, Pennsylvania. ""i"'1!I!'i~,_,,_., ..,. I~ " ~ ~",. . ""IIT ~'''!lII1 - -.... This Order shall remain in effect pending further Order of the Court after a hearing. By the Court, J. Wesley Oler, Jr., Judge Galen R. Waltz, Attorney for PlaintifflRespondent 28 South Pitt Street Carlisle, P A 17013 Joan Carey, Attorney for DefendantlPetitioner Mid-Penn Legal Services 8 Irvine Row Carlisle, P A 17013 r:;' 1-"' T'"':'""'" ~, - , ':-.,' ~ ,JUN 1 82001tP JASON W. HOCKENBERRY PlaintifflRespondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - CUSTODY WENDY M. STINE Defendant/Petitioner NO. 01-2015 CIVIL TERM ORDER OF COURT AND NOW, this day of June, 2001, upon consideration of the Defendant/Petitioner's Petition for Special Relief to stay Recommended Order of Conciliator Pending a Hearing, the following Order is entered regarding Custody of Bryson Wayne Hockenberry, born April 10, 2000: I. The Order of April II , 200 I shall remain in effect pending further Order of the Court. 2. Defendant shall submit to a drug screening blood test within 24 hours of the entry of this Order. 3. A hearing regarding Plaintiff's petition for special relief is scheduled for the day of ' ,2001, at .m., in Court Room No. of the Cumberland County Courthouse, Carlisle, Pennsylvania. 4. A full custody hearing is scheduled for the day of ,2001, at .m., in Court Room No. of the Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, J. Wesley Oler, Jr., Judge Galen R. Waltz, Attorney for PlaintifflRespondent 28 South Pitt Street Carlisle, P A 17013 Joan Carey, Attorney for Defendant/Petitioner Mid-Penn Legal Services 8 Irvine Row Carlisle, PA 17013 .~"~Jl'lfl,h" ,~ .. JASON W. HOCKENBERRY Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - CUSTODY WENDYM. STINE DefendantJPetitioner NO. 01-2015 CIVIL TERM ORDER OF COURT AND NOW, this day ofJune, 2001, upon consideration of the DefendantJPetitioner's Petition for Special Relief to stay Recommended Order of Conciliator Pending a Hearing, the following Order is entered regarding Custody of Bryson Wayne Hockenberry, born April 10, 2000: I. DefendantJPetitioner, Wendy M. Stine, hereinafter referred to as the mother and Plaintiff/Respondent, Jason Hockenberry, hereinafter referred to as the father, shall share legal custody. 2. The mother shall have primary physical custody. 3. The father shall have partial custody according to the following schedule: a. Every other weekend from Saturday at II :00 a.m. until Sunday at I :00 p.m. b. From 11:00 a.m. to 5:00 p.m. on the alternate Sundays. c. Two evenings each week from 5:00 p.m. until 8:00 p.m. d. Other times agreed upon by the parties. 4. Defendant shall submit to a drug screening blood test within 24 hours of the entry of this Order. 5. A full custody hearing is scheduled for the day of , 200 I, at .m., in Court Room No. of the Cumberland County Courthouse, Carlisle, Peunsylvania. '-:!!il,.~"",.. "~ ,- ~,"- ,..,.,,-", - This Order shall remain in effect pending further Order of the Court after a hearing. By the Court, J. Wesley Oler, Jr., Judge Galen R. Waltz, Attorney for Plaintiff/Respondent 28 South Pitt Street Carlisle, PA 17013 Joan Carey, Attorney for DefendantJPetitioner Mid-Penn Legal Services 8 Irvine Row Carlisle, PA 17013 ~!~ .. ~ ~ ~ " '- JASON W. HOCKENBERRY Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA v. CIVIL ACTION - CUSTODY WENDY M. STINE DefendantJPetitioner " NO. 01-2015 CIVIL TERM ORDER OF COURT AND NOW, this day of June, 2001, upon consideration ofthe DefendantJPetitioner's Petition for Special Relief to stay Recommended Order of Conciliator Pending a Hearing, the following Order is entered regarding Custody of Bryson Wayne Hockenberry, born April 10, 2000: 1. The Order of April 11, 2001 shall remain in effect pending further Order of the Court. 2. Defendant shall submit to a drug screening blood test within 24 hours of the entry of this Order. 3. A hearing regarding Plaintiff's petition for special relief is scheduled for the day of ,2001, at .m., in Court Room No. of the Cumberland County Courthouse, Carlisle, Pennsylvania. 4. A full custody hearing is scheduled for the day of ,2001, at .m., in Court Room No. ofthe Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, J. Wesley oter, Jr., Judge Galen R. Waltz, Attorney for Plaintiff/Respondent 28 South Pitt Street Carlisle, PA 17013 Joan Carey, Attorney for DefendantJPetitioner Mid-Penn Legal Services, 8 Irvine Row Carlisle, P A 17013 '-';m]i~ , "0 I -, - I ['~ . 1 , ." , . ~-- ~ ~ JASON W. HOCKENBERRY Plaintif:flRespondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - CUSTODY WENDY M. STINE Defendant/Petitioner NO. 01-2015 CIVIL TERM ORDER OF COURT AND NOW, this day of June, 2001, upon consideration of the Defendant/Petitioner's Petition for Special Relief to stay Recommended Order of Conciliator Pending a Hearing, the following Order is entered regarding Custody of Bryson Wayne Hockenberry, born Aprill0, 2000: 1. Defendant/Petitioner, Wendy M. Stine, hereinafter referred to as the mother and Plaintifti'Respondent, Jason Hockenberry, hereinafter referred to as the father, shall share legal custody. 2. The mother shall have primary physical custody. 3. The father shall have partial custody according to the following schedule: a. Every other weekend from Saturday at 11 :00 a.m. until Sunday at I :00 p.m. b. From II :00 a.m. to 5 :00 p.m. on the alternate Sundays. c. Two evenings each week from 5:00 p.m. until 8:00 p.m. d. Other times agreed upon by the parties. 4. Defendant shall submit to a drug screening blood test within 24 hours of the entry of this Order. 5. A full custody hearing is scheduled for the day of ,2001, at .m., in Court Room No. of the Cumberland County Courthouse Carlisle , , Peunsylvania. ~~,~ . _", c ,. 1'-. '"'1- -'" 1" " This Order shall remain in effect pending further Order ofthe Court after a hearing. By the Court, 1. Wesley Oler, Jr., Judge Galen R. Waltz, Attorney for Plaintiffi'Respondent 28 South Pitt Street Carlisle, PA 17013 Joan Carey, Attorney for DefendantlPetitioner Mid-Penn Legal Services 8 Irvine Row Carlisle, P A 17013 ;-~rT"l'!ff~,l_ "~-, ' < - ~- 'I~'~."'" -1~ - , JASON W. HOCKENBERRY Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - CUSTODY WENDY M. STINE DefcndantlPetitioner NO. 01-2015 CIVIL TERM ORDER OF COURT AND NOW, this day of June, 2001, upon consideration of the DefendantlPetitioner's Petition for Special Relief to stay Recommended Order of Conciliator Pending a Hearing, the following Order is entered regarding Custody of Bryson Wayne Hockenberry, born April 10, 2000: 1. The Order of April 11, 2001 shall remain in effect pending further Order of the Court. 2. Defendant shall submit to a drug screening blood test within 24 hours of the entry of this Order. 3. A hearing regarding Plaintiffs petition for special relief is scheduled for the day of ,2001, at .m., in Court Room No. of the ,Cumberland County Courthouse, Carlisle, Pennsylvania. 4. A full custody hearing is scheduled for the day of ,2001, at .m., in Court Room No. ofthe Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, J. Wesley Oler, Jr., Judge Galen R. Waltz, Attorney for PlaintiffiRespondent 28 South Pitt Street Carlisle, PA 17013 Joan Carey, Attorney for DefendantlPetitioner Mid-Penn Legal Services 8 Irvine Row Carlisle, PA 17013 'i'r~_,"~_",:,_ ~"_'_ ~,_'; I ,~' " f' ,-" , " ., " JI,fffl JUN 1 82001ft7 JASON W. HOCKENBERRY Plaintiflj~espondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - CUSTODY WENDY M. STINE DefendantIPetitioner NO. 01-2015 CIVIL TERM ORDER OF COURT AND NOW, this day of June, 2001, upon consideration DefendantIPetitioner's Petition for Special ~elief to stay Recommende rder of Conciliator Pending a Hearing, the following Order is entered regarding Custod ofBiyson Wayne Hockenberry, born April 1 0, 2000: 1. DefendantlPetitioner, Wendy M. Stine, hereinafte referred to as the mother and PlaintifflRespondent, Jason Hockenberry, hereinafter reD ed to as the father, shall share legal custody. 2. The mother shall have primary physica custody. 3. The father shall have partial custo according to the following schedule: a. Every other weekend om Saturday at 11 :00 a.m. until Sunday at 1 :00 p.m. 5:00 p.m. on the alternate Sundays. c. Two evenin each week from 5:00 p.m. until 8:00 p.m. s agreed upon by the parties. 4. Defendant s all submit to a drug screening blood test within 24 hours of the entry of this Order. 5. A ful ustody hearing is scheduled for the day of ,2001, ., in Court ~oom No. of the Cumberland County Courthouse, Carlisle, ( ! - "?"",~~~ ~ W'. l' 'r-"'.~ - ~~ ,~~ .1 ~'~'" , ." This Order shall remain in effect pending further Order of the Court after a hearing. By the Court, J. Wesley Oler, Jr., Judge Galen R. Waltz, Attorney for Plaintiffi'Respondent 28 South Pitt Street Carlisle, P A 17013 Joan Carey, Attorney for DefendantlPetitioner Mid-Penn Legal Services 8 Irvine Row Carlisle, P A 17013 -~,~~ . 'e_ I':' "I , 'I ~ . ~ _~~_"'>ll ._ '"'-l~"-'-'O_~~ JASON W. HOCKENBERRY Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - CUSTODY WENDY M. STINE Defendant/Petitioner NO. 01-2015 CIVIL TERM ORDER OF COURT AND NOW, this day of June, 2001, upon consideration of the Defendant/Petitioner's Petition for Special Reliefto stay Recommended Order of Conciliator Pending a Hearing, the following Order is entered regarding Custody of Bryson Wayne Hockenberry, born April 10, 2000: I. The Order of April II , 200 I shall remain in effect pending further Order of the Court. 2. Defendant shall submit to a drug screening blood test within 24 hours of the entry of this Order. 3. A hearing regarding Plaintiff's petition for special relief is scheduled for the day of ,2001, at .m., in Court Room No. of the Cumberland County Courthouse, Carlisle, Pennsylvania; 4. A full custody hearing is scheduled for the day of ,2001, at .m., in Court Room No. of the Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, J. Wesley Oler, Jr., Judge Galen R. Waltz, Attorney for Plaintiff/Respondent 28 South Pitt Street Carlisle, P A 17013 Joan Carey, Attorney for Defendant/Petitioner Mid-Penn Legal Services 8 Irvine Row Carlisle, P A 17013 '-""''W<'III~,,\, r ,-"~ r". ~ .~ ~~~~~ "1 ~ f",~ ;ir"-" " .' v. : IN THE COURT OF COMMON P S : CUMBERLAND COUNTY, PENN YLVANIA : NO. 01- .;?O/S'-- CIVIL TERM : CIVIL ACTION - CUSTODY JASON W. HOCKENBERRY, Plaintiff WENDY M. STINE, Defendant ORDER AND NOW this day of , 2001 after eviewing the allegations contained within the Petition for Emergency Relief, it is here ordered that the Defendant, Wendy M. Stine, shall produce the minor child, Bryson ayne Hockenberry for the father, Jason W. Hockenberry, on April 8, 2001 at 8:00 .m. the Plaintiff shall return minor, Bryson Wayne Hockenberry, to mother April 8, 2 01 at or about 8:00 P.M. BY THE COURT, J '''~'?''-' - . ,,--.., '; ",'~'}"'I--,,'''-~ "" >"-J:' ','-, . o _ ".'~ 'II! -~ if .,_ .,l ff JASON W. HOCKENBERRY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01- ;:o;..{ CIVIL TERM : CIVIL ACTION - CUSTODy.... v. WENDY M. STINE, Defendant ORDER OF COURT AND NOW, this day of , 2001, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , Esq., 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. FOR THE COURT, By: Custody Conciliator The Court of Common Pleas d 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 C(,ntact our office. All arrangements must be made at least 72 hours prior to any hearing i)r business before the Court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. ,,",,,,, .. "." ':\ 'cl. ''c.,,, '" ' PA Lawyer Referral Service Pennsylvania Bar Association 100 South Street P.O. Box 186 Harrisburg, PA 17108 (800) 692-7375 f" ",- _'_' ,'0_,",<,_", I~ ,t"'''''", ' "1,,," ,,- , , " -'''',~'.l, -7," I ~r , JASON W. HOCKENBERRY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01- 020/1}' CIVIL TERM : CIVIL ACTION - CUSTODY v. WENDY M. STINE, Defendant COMPLAINT FOR CUSTODY 1. Plaintiff is Jason W. Hockenberry, an adult individual whose residence is at 401 Baltimore Road, Shippensburg, Cumberland County, Pennsylvania. 2. Defendant is Wendy M. Stine, an adult individual whose residence is at 2 Strohm Road, Shippensburg, Cumberland County, Pennsylvania. 3. Plaintiff seeks custody of his child Bryson Wayne Hockenberry, born April 10, 2000, currently residing at 2 Strohm Road, Shippensburg, Cumberland County, Pennsylvania. 4. The child is presently in the custody of Defendant. 5. Since the child's birth, the child has resided at the following addresses: Name Address Dates Wendy M. Stine April 10, 2000 - Current 2 Strohm Road Shippensburg, PA 17257 6. The relationship of the Plaintiff to the child is that of natural father. 7. The relationship of the Defendant to the child is that of natural mother. 8. Neither party has been married nor is married. 9. The Plaintiff has not participated as a party or in any other capacity, in other litigation concerning the custody of the child in this or any other Court. 10. Since on or about November 24, 2000 and except for an isolated and restricted 1 hour March 10, 2001 visit, the Plaintiff has been repeatedly denied visitation and/or custody of his son, Bryson Wayne Hockenberry. 11. Defendant has established a pattern of promising the minor child to his father and withdrawing the visitation at the last minute at great mental and emotional F~' -. ~;"m~", ',_ ',; .<,_ ," .,,_ " If -.---- , expense to both child and father; in fact, defendant uses the child as leverage against the plaintiff. 12. Defendant advised Plaintiff that he could have visitation with his son on Christmas Eve between the hours of 3:30 P.M. and 6:30 P.M.; subsequent to the first conversation setting the time of visitation, the Defendant contacted the Plaintiff a second time restricting the visitation from 3:30 P.M. to 5:30 P.M.; the Defendant failed to provide the minor child, Bryson Wayne Hockenberry, to the Plaintiff for his scheduled Christmas Eve visitation. 13. On March 23, 2001 during telephone contact initiated by defendant to Angie Ocker, plaintiff's girlfriend's residence, defendant advised Ms. Ocker" . . . she [defendant] was in control and Jason would not be getting Bryson for [plaintiff's]sister's wedding [scheduled for Saturday, March 31, 2001]" or words to that effect. [Exhibit 1, attached and incorporated herein]. 14. On or about March 30, 2001, via attorney and paternal grandfather intervention, the defendant agreed that the minor child would be provided to paternal grandfather at 9:00 a.m. Saturday, March 31, 2001 and minor child would be returned to defendant on or about 5:00 or 6:00p.m., Saturday, March 31, 2001 by the paternal grandfather. 15. In preparation for the visitation and the minor child's attendance at the wedding, plaintiff purchased clothes and other necessaries for the child. 16. On or about Friday, March 30, 2001 at 5:20p.m., defendant telephoned Ms. Ocker's residence and advised Ms. Ocker, after discussion, "If it was going to be like this, maybe Jason won't see Bryson Saturday" or words to that effect. 17. Immediately following the 5:20p.m. March 30, 2001 telephone contact to Ms. Ocker, Defendant attempted to contact plaintiff a second time at Ms. Ocker's residence followed by a third attempt by the defendant's mother who after identifying herself to Ms. Ocker called Ms. Ocker a "Fuckin Bitch" or words to that effect. 18. None of the telephone contacts to the Ocker residence involved emergency minor child information. ~- 19. On two occasions, March 23, 2001 and March 30, 2001, repeated, obscene and harassing telephone calls initiated by Wendy, Kendra and Mrs. Stine to Ms. Ocker's residence were reported to the Franklin County State Police. 20. Ms. Ocker has a minor daughter residing with her and the minor daughter intercepted one of the harassing telephone calls placed by defendant. 21. Plaintiff has made numerous requests from defendant for a visitation with his son on Sunday, April 8, 2001 from 8:00 a.m. until 8:00 p.m. and as of this filing date, no response from defendant has occurred; it is expected that consistent with the father's previously denied advanced requests for visitation that this request will ultimately result in a non-visitation. 22. It is believed and therefore averred that the defendant is alcohol and/or drug dependent. 23. The best interest and permanent welfare of the child will be served by granting the relief requested because prior to plainitffs November separation from defendant, the Plaintiff was primarily responsible for providing the child with food, clothing, furnishing, love, care and other nurturing qualities. 24. 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. No other persons are known to have or claim to have any right to custody or visitation of the child other than the parties to this action. WHEREFORE, Plaintiff requests your Honorable Court grant sole legal and physical custody of the minor child, Bryson Wayne Hockenberry, to the father, Jason W. Hockenberry, the Plaintiff herein. Respectfully Submitted TURO LAW OFFICES ~~~~) Date en R. Waltz Turo Law Offices 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff .' '. ~',~".,' ''''~'---"~ '1' . I, VERIFICATION I verify that the statements made in the foregoing Custody Complaint are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. Q-2-t'J/ Date d~ $~~ _--. ,Jason W. Hockenbe ~ . . . . Turo Law Offices www.TuroLaw.com 28 South Pitt Street Carlisle, Pennsylvania 17013 (717) 245-9688 (800) 562-9778 Fax (717) 245-2165 RON TURO, Esquire ROBERT J. MULDERIG, Esquire DAVID A. GREENE, Esquire GALEN R. WALTZ, Esquire March 28, 2001 Paula Burkett Sent by facsimile 243-8026 Mid Penn Legal Services 8 Irvine Row Carlisle, PA 17013 Re: Stine v. Hockenberry Dear Ms. Burkett: Apparently on Friday, March 23, 2001, Wendy and/or Kendra telephoned Jason Hockenberry's girlfriend's house two (2) times. In each instance the girlfriend would not provide the telephone to Jason since the telephone calls did not directly involve Bryson or Bryson's welfare. The callers, Wendy or Kendra, were advised not to place calls at the residence which they were calling. The Franklin County State Police were contacted and a record has been established. Unfortunately, during the course of one of those two telephone calls, Wendy advised Angie (Jason's girlfriend) that "she [Wendy] was in control and Jason would not be getting Bryson for his sister's wedding scheduled for Saturday, March 31, 2001" or words to the effect. I am writing this letter solely to ask you to intervene with your client and secure a commitment from Wendy permitting Bryson to visit with his father from 8:00 A.M. Saturday, March 31, 2001 to 8:00 P.M. Saturday, March 31, 2001. Jason's sister is being married in McConnellsburg Church and the wedding is at 11 :00 A.M. Jason has already purchased clothing and an outfit for Bryson's expected attendance at the wedding. Please advise me before 5:00 P.M. Thursday, March 29, 2001, whether Jason can have Bryson this weekend for the Saturday wedding. It is my intention to file the necessary emergency papers to secure Wendy's attention in this matter if she is unwilling to allow Bryson to be with his father, aunt and paternal family members for Saturday's wedding celebration. i .~ 'jJ:X/ilelt ./',."... . . In addition, we previously requested to have Bryson April 8, 2001. Please advise the willingness of your client to allow Bryson to be with Jason from 8:00 A.M. to 8:00 P.M. April 8, 2001 in order that Jason can use the day to celebrate Bryson's upcoming birthday as well as to take Bryson to an Easter egg hunt. Jason is willing to retrieve Bryson from Wendy's residence at 8:00 A.M. as well as to return Bryson at 8:00 P.M. times. In the event Wendy agrees to amicably allow Bryson to attend these events, please have Wendy provide the necessary formula, food, milk, medicine, whatever Bryson needs so that Jason can see that the child is properly attended to with the food and drinks that he has come accustomed to. It was hoped that these matters could be handled in a mature adult fashion. Since time is of the essence, please advise me to the wishes of your client before 5:00 P.M. Thursday, March 29, 2001. Sincerely Yours, GALEN R. WALTZ, ESQUIRE GWaltz@TuroLaw.com GRW/rms cc: Jason Hockenberry \'1" ;V _,_. , ~ I '~9 ',,-, ":1-. ' ...~~-, ,,'~" ~ "~"........'" ',,~'iI> -"!""'I1f _ _~_ " <,_". "c ",""~." e. ' ~r . . CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Complaint for Custody upon Joan Carey, Esquire, by dMsiting same in th~ United States Mail, first class, postage pre-paid on the $ day of ~{Yl11 , 2001, from Carlisle, Pennsylvania, addressed as follows: Joan Carey, Esquire Legal Services, Inc. 8 Irvine Road Carlisle, PA 17013 TURO LAW OFFICES ~ en R. Waltz, 28 South Pitt Str Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff "run -"'"' _.,,--- -" '.', "< ,,~, !--,,....,.~~,-q:' -- ~ -- ~ .~, - ->'~'.'I I"' _''''''''''''''''''"0'__'' -"",'~~'"--~"'-.I~,",-'...,~-" ~'M-~-'-'~'_r"'-''''-''''i-:l.~."a''v}<'i.:j&""" 0 () , '...- n ~ ~ -:"";-, .,-'t ~ c: :r --r', ~,-- " s-v~ L'~ I~, (/, G', B Un ~ ~ ~~: ~ '\ j:::-, ~"-. " ~ \ :~! " 0:, :~< \J . ~ ~ _c ~.JJ1!l:_J1.~_MJI}~~i~!!~Jr*,"WW~..;'T'Y1liil\\:l~~~~.~~~$rn~~~'; i1r~~ , , , '" ,I .. !i JASON W. HOCKENBERRY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ~ NO. 01-A ()}s-' CIVIL TERM v. WENDY M. STINE, Defendant : CIVIL ACTION - CUSTODY EMERGENCY PETITION FOR RELIEF 1. A Complaint for Custody was filed in this matter on April 6, 2001. 2. Plaintiff is Jason Wayne Hockenberry an adult who resides at 401 Baltimore Road, Shippensburg, Cumberland County, Pennsylvania. 3. Defendant is Wendy M. Stine, an adult individual whose residence is at 2 Strohm Road, Shippensburg, Cumberland County, Pennsylvania. 4. Prior to Christmas the Plaintiff requested to see his son and was promised by the Defendant that he could have a visitation during Christmas. 5. Defendant failed and refused to produce the minor child for the Christmas visitation. 6. An agreement was recently reached between the Plaintiff and Defendant to provide the minor child during March 31, 2001 from 9:00 a.m. until 5:00 p.m. 7. March 31, 2001 was the Plaintiffs sister's wedding and the Plaintiff had purchased clothing and necessaries for the minor child to attend the wedding. 8. On March 30, 2001 at or around 5:00 p.m. the Defendant advised the Plaintiffs girlfriend that the Plaintiff may not be seeing his son on March 31, 2001. 9. On or around 7:00 a.m., March 31, 2001, the Defendant advised Plaintiffs father that the minor child was ill and therefore would not be produced for the visitation. 10. The Plaintiff contacted the minor child's physician and it is believed and therefore averred that there were no appointments for the minor child on March 31, 2001. 11. Defendant has been using the minor child as a form of leverage with the father and father's family. ...... ~. ." . i 12. The father previously requested to have his son April 8, 2001 for the purposes of taking him to an Easter egg hunt and celebrating the minor child's birthday. 13. It is believed and therefore averred that the father will be deniedlrefused visitation with his son on April 8, 2001. Wherefore, Plaintiff respectfully requests this honorable court to enter an order requiring the Defendant to produce the minor child to the Plaintiff at 8:00 a.m. April 8, 2001 and that the Plaintiff shall return the minor child to the Defendant at 8:00 p.m. on April 8, 2001. Respectfully Submitted TURO LAW OFFICES 1//(!)4/d/ Date " alen R. Wal 28 South Pitt treet Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff ,,,~ ,~ . -,.-,~-,-, -;.,.. ! if.,;.,.'\,>-"~}t .: ,.....1 , ".- ,,..,-~ '-~~' ,',-' ~ vr ." CERTIFICAtE OF SERVICE I hereby certify that I served a true and correct copy of the Petition for Relief upon Joan Carey, Esquire, by depositing same in the United States Mail, first class, postage pre-paid on the J Ii day of ;4~yo.' J ,2001, from Carlisle, v Pennsylvania, addressed as follows: Joan Carey, Esquire Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 TURO LAW OFFICES c::"'> .- - en R. Waltz, Esq . 28 South Pitt Stree Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff '--, --,I..' -1'<"'" 'I >f- ~ - " - ful " 'I" \-1 <' ~~"' __J, If_ ..-,.,,~;~!",' , ~ " .0' , ,." '=" ',",^ - .". , ''I'" ""00',. '" "~ -"'-';'~ ~"" ."",~",> """1 'O'~-" Iiii~"'" m~!iI ., U\] ~ <0 0 -r:::- C) c: ~ ~ ~--" -!~.,,. vL~' " ~j -,-, Q~(~ :-T.J ~ .?----- --,'."- ~ (jj ~ ~' -. ~ r:. ~:~'~ ~ ~~: , Co) ~ --') J~ ~ ~_:.... ~ _" ~\~~1JR-<;.-'N~ffl'!pnN'~'f"W'lt'Wig~1H!~~~~~'I}~"l~I,_ ,_,'._',., '''~\I'-"rf' ,~, JASON HOCKENBERRY, Plaintiff ~at,....J 'i (Q) ~\) l1> 11:. (nfl . \J~-\ (.~ w~~ 0 if J :IN THE COURT OF COMMON PLEAS OF I :CUMBERLAND COUNTY, PENNSYLVANIA v. :NO.01-2015 CIVIL TERM WENDY M. STINE, Defendant :CUSTODY Pre-Hearing Memorandum of Defendant 1. History and Issues: Wendy Stine (hereinafter mother) is the mother of Bryson Wayne Hockenberry born April 10, 2000. On March 22,2601 this Court entered a Protection From Abuse Order docketed at No. 2001-709, which in pertinent part, granted mother primary physical custody. On Aprilll, 2001 by agreement of the parties, the Court entered an Order granting primary physical custody of the child to Wendy Stine and partial custody to Jason Hockenberry (hereinafter father), the father of the child. A Conciliation Conference before Attorney Jacqueline Verney, Custody Conciliator, was held June 13,2001. Upon recommendation of the conciliator, the Court vacated the April 11, 2001, Custody Order, and an Order was entered on June 18,2001 which granted shared physical custody to the mother and father. The mother filed a Petition for Special Relief to Stay the Recommended Order of the Conciliator Pending a Hearing. The Court denied the stay without prejudice and endeavored to schedule an expedited hearing. See Exhibit A. attached and incorporated by reference. The mother feels that it is in the best interest of the child for him to be returned to her custody subject to periods of partial custody in the father. Under the facts of the case including, but not limited to, those in the mother's Special Relief Petition, shared custody is not appropriate. II Witnesses This list includes, but is not limited to, the following witnesses: 1. Wendy Stine The defendant, who is the mother of the child, is to testify about her relationship with her child and why she believes it is in the best interest of the child to remain in her custody primarily. She will also testify as to the father's parenting skills and behavior she believes adversely affects the child.. -;o.:;~~ '" "I ," - - i"T ~. ~--~ - - i _0 -~~ ;<-T~-"-'- ~ ~~. d. " -~~'~"II\l~-. ~_ , 2. Theresa Stine This witness is Wendy's mother. She can testify as to the relationship of the mother and father to the child and their parenting, including behavior by the father which has adversely affected the child. She can also testify as to child's relationship with the grandparents. 3. Kendra Stine This witness is Wendy's sister. She can testify as to the relationship of mother and father to the child and their parenting, including behavior by the father which has adversely affected the child. 4. Theresa Cook Theresa is Jason Hockenberry's ex-girlfriend. She will testify as to behavior of the father which may adversely impact the child. 5. Connie Wright Connie is Wendy's aunt. She will testify as to Wendy's parenting and the father's behavior which has adversely affected the child. She will also testify as to the child's socialization with her child and other relatives. 6. Patricia Barklow Patricia is Kendra's friend. She will testify as to behavior by the father which has adversely affected the child.. Defendant reserves the right to call additional witnesses as rebuttal witnesses. aVl '. Lopez and Joan Care Attorneys for Defendant MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 ~~ ,. '.," -- :. '~~N ._.f "-," -- r ~ JASON W. HOCKENBERRY PlaintifflRespondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - CUSTODY WENDY M. STINE Defendant/Petitioner NO. 01-2015 CIVIL TERM ~J):J'I,TION FOR SPECIAL RELIEF TO STAYRECOMMENDED ORDER OF CONCILIATOR PENDING A HEARING Defendant/Petitioner, Wendy Stine, by and through her counsel, Joan Carey and David Lopez of MidPenn Legal Services, states the following: 1. Defendant/Petitioner, Wendy Stine, hereinafter referred to as the mother, currently resides at 2 Strohm Road, Shippensburg, Cumberland County, Pennsylvania, 17257. 2. PlaintifflRespondent, Jason W. Hockenberry, hereinafter referred to as the father, currently resides at 401 Baltimore Road, Shippensburg, Cumberland County, Pennsylvania. 3. The mother and father are the natural parents of Bryson Wayne Hockenberry, born April 10, 2000. 4. The Plaintiff filed a Complaint for Custody and a Conciliation Conference was held on June 13,2001, before Jacqueline M. Verney, Esquire. 5. At the conclusion of the Conciliation Conference, the mother and father had not mutually agreed to modify the Order of April 11 , 2001. However, the Conciliator told the mother and father that she was recommending an brder for shared legal and physical custody of the minor child on a week/on, week/off arrangement. The Conciliator advised the mother and the father that the schedule would commence on Sunday, June 17, 2001. 6. The Mother requests that the Conciliator's recommended Order be stayed pending a hearing for reasons including, but not limited to, the following: a) An incident in November, 2000, involved the minor child when he was just seven months old in which the father forcefully shoved the child to the floor causing the mother to fear for the child's safety. b) On March 22,2001, a Protection from Abuse Order was entered by the Court by an agreement of the parties. The PF A granted the mother primary physical custody of the child with no provision for visitation to the father who had been granted supervised visits under the Temporary 'W'1~1ll~ , , ,~.,' , ,- ,-~ . . ~.~ --~-~~ """".;,,,,,,,,,,-~, = .= , Order (a copy of the Protection from Abuse Pe~tion and Final Order ~s . attached hereto, incorporated by reference herem, and marked as Exhibit A). c) On April 11, 2001, upon consideration of the plaintiffs Emergency Relief Petition and pursuant to an agreement reached between the mother and father, this Court entered an Order granting the mother primary physical custody and the father partial physical custody gradually extending the time father spent with the child from limited daytime . periods to alternate weekends from Saturday at 8:00 am. to Sunday at 8:00 p.m. (a copy of the April 11, 2001 Order is attached hereto, incorporated by reference herein, and marked as Exhibit B). d) During the June 13;2001 Conciliation Conference, the mother proposed a custody schedule further extending the father's periods of partial custody to include an additional four hours each week and six additional hours on the Sunday the father did not have custody. The father indicated that he would accept nothing less than, equally shared custody. e) When the Conciliator recommended shared l~gal and physical custody, the mother was adamantly opposed to tjlls arrangement and requested that the current Order reniain'in effect peniling a hearing. )l1 the alternative, the mother offered extended partial custody tiine to the father pending the hearing. Again, father refused to accept anything less than equally shared custody. 7. It is in the child's best interest to maintain the April 11, 2001, Order which grants the mother primary physical custody pending a hearing for reasous including, but not limited to, the following: a) The mother has been the primary care-giver for the child since birth. b) Since his birth, the father has only had the child for two overnight visits scheduled for the father, and the father was not with the child for one of those scheduled Qvernights. The father's periods of partial custody have only been exercised with the paternal grandmother or girlfriend present. The father has not cared for the child for a significant period alone. c) The child is lactose intolerant, which requires special care which the father refuses to provide. In fact, he gives the child milk in spite of the documents recommending not to. d) The father has only been with the child for one overnight visit and the mother fears that the father will not be able to care for the child for a full week. ',"'ffl~~" " r". , ..,~ ~l ~l!If._ ~_,~^ e) During the father's limited periods of partial custody with the child, he has bad him in several different locations and he has not established a stable environment. f) The mother and father agreed to be screened for drugs by a blood test to be administered to both parties the day of the Conciliation Conference. The mother complied with the conciliator. The father has not submitted himself for drug testing, and the ml?ther feels that the Court should at least wait until the results are. verified. g) Because of the father's work schedule, he is out of Pennsylvania from Sunday until Friday every week and he is currently not available to care for the child during the week. h) The father does not communicate with the mother regarding the child; therefore, shared custody is not appropriate in this case before modifying the existing Order. i) The mother questions whether the father's insistence on equally shared custody is to benefit the child or to benefit him financially since he is currently over $700 in arrears on his child support. 8. Petitioner's attorneys contacted Respondent's attorney, Galen Waltz, to obtain a statement of concurrence, and he does not concur with the granting of the relief requested. WHEREFORE, Defendant/Petitioner requests that the Court grant the following: a) Refrain from signing the Conciliator's recommended Order, and continue the. Order of April II, 200 I pending further Order of Court and schedule an expedited hearing on the narrow issue of whether joint custody is appropriate in this case pending a full custody hearing, or b) If the Conciliator's recommended Order has been signed, vacate the Order and schedule an expedited hearing on the narrow issue of whether joint custody is appropriate in this case pending a full custody hearing. c) In the alternative, enter an interim Order pending further Order, after a full custody hearing, which is consistent with the mother's proposal for extended periods of partial custody. ~-_WJ~"Ii!l_ e, "" ' _ ~_ _~ ~ c- I I~ ~ '-'~ ~!' "" ~ =~,- _.:,"1 ~ d) Any additional relief this Court deems just and proper. <i~:.__ I.-~ " Respectfully submitted, o Carey and David Lo z Attorneys for Defendan etitioner MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 '1 ~.~,.."",.,.,--- - I .. -,~ . ~" . \ VERIFICATION The above-named Defendant/Petitioner, Wendy M. Stine, verifies that the statements made in the above Petition to Stay Recommended Order of Conciliator Pending a Hearing are true and correct. Defendant/Petitioner understands that false statements herein are made subject to the penalties of 18 Pa. C.S. !i4904, relating to unsworn falsification to authorities. n... ~/ h, 6O::J I ,.~wr~~ .~" 'r ~"'~ , ~r . "I - .~ -~=, ~n ,oJ ~ JASON W. HOC~~ERRY, PlamtItt IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. WENDY M. STINE, Defendant : NO. 2001-2015 CIVIL TERM CIVIL ACTION - LAW IN RE: PLAINTIFF'S COMPLAINT FOR CUSTODY BEFORE OLER. J. ORDER OF COURT AND NOW, this 1 ~ day of AUGUST, 2001, upon consideration of Plaintiff s complaint for custody with respect to the parties' child, Bryson Wayne Hockenberry (d.o.b. April 1 0, 2000) (hereafter, the child), and following a hearing held on August 6, 2001, it is ordered and directed as follows: 1. Legal custody of the child shall be shared by the parties. 2. Primary physical custody of the child shall be in Defendant, the mother. 3. Temporary or partial physical custody of the child shall be in Plaintiff, the father, at the following times: a. On alternating weekends, from Friday at 7:00 p.m, until Sunday at 7:00 p.m. b. On Thanksgiving Day from 2:00 p.m. until the following Sunday at 7:00 p.m. c. During June, July and August, for the first full week of each month commencing on Sunday at 7:00 p.m. until the following Sunday at "',4.m;!ii C"",:\",~ , , I--~' '_' --' . " 1-' "~, .. .... , 't,~,A' ~ "_Ii .. ~, fj ~"'-..,,- 7:00 p.m. (These week-long periods shall be in addition to Defendant's periods of custody on alternating weekends.) Provided, that for the month of August, 2001, Plaintiffs one-week period shall be from August 19, 2001, until August 26,2001. 4. Notwithstanding the foregoing, Defendant shall have custody of the child on Christmas Day until 2:00 p.m., and Plaintiff shall have custody ofthe child from 2:00 p.m. on Christmas Day until 7:00 p.m. on January 30, 2001. 5. Transportation for exchanges of custody shall be the responsibility of the party receiving custody. 6. Nothing herein is intended to preclude the parties from deviating from the terms of this order by mutual agreement. 7. All prior custody orders are vacated. By the Court, Galen R. Waltz, Esquire 28 South Pitt Street Carlisle, Pa. 17013 For the Plaintiff ,Jr., . ~ ~~~~ Joan Carey, Esquire Mid-Penn Legal Services, Inc. 8 Irvine Row Carlisle, Pa. 17013 For the Defendant :sld e-',,>,_, '-"1-- -1,' , " AJ.Nf!~~b:J,u.'1 ' " rcA,'.',vlI/!i;.'1...J ~ '..: ,)',:, ';;IV S U'8 . ' !':!?tlMI~ . !ill 1'1/0 '. (") ADI O~ ">r ,v'lJQ'V(e/. VI/V Ii) ~-]:J{!~~j:;;~~~." -:~--f/ J,~ ^() 1/.:/ ...., '';U .,~. J.. " " ;'" ,,~, .;. .. ~ L_~iJ_~ ,_"~JIl!!Iir~. "_...mctl~~Il'~$>j,$.!l";~t"l'Hi,~~[i'!}'W~l\\!i\W~~i!!~-.~"''i;P;'1!llfffm,~~~__:,_", ,__~~~~~l JASON W. HOCKENBERRY PLAINTIFF V. WENDY M. STINE DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-2015 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, May 15, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueliue M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, June 01, 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, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Jacqueline M. VernlO'. Esq.iJtl 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 TIllS PAPER TO YOUR ATTORNEY AT ONCE. IFYOUDONOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE SET FORTIl BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ':~~ . t. I "~ 1" i"";--": I 1 - 'ill d~ ~ ~ - '~~"".=r.~1 ,,". -~ -~ ~",,,,,~,~ -~ -. - ~- '~'.~'",' -. '~ 0; :I;~~;71 ? ~ ~ ~/ 1r/-1/"f' ~ ~? ~ ~ 1~'1/,> ~ r '1 ~ ~) r'? I~''ll? lfiNVi\lASNi',gd 'lNI(lrv'J ("I ""." '''''"''''1'''' /'I .\)'., .'_1;' -'.:1":::-;1'110 h"'1 [J'"j If' ~, 'l '. 91 ),"iH 10 AtJ\f.LCt;\!j,l.. , ,2:. - ~":-"~-~ "",~p~~~~~~~!!R"'l"~ ~;li''ii'",'W,;,''TI~=i~~~r;;~''1'8'''''-''''''''\'~_'~''iZ~!;>1''~WJ!i~~lji!:(j!lF,~~~~~~~ . ,'d,_"'!!,' , ~ JASON W. HOCKENBERRY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW WENDY M. STINE, Defendant NO. 01-2015 CIVIL TERM ORDER OF COURT AND NOW, this 6th day of April, 2001, upon consideration of Plaintiffs Emergency Petition for Relief, a hearing is scheduled for Wednesday, April 11, 2000, at 11:15 a.m., in Courtroom No.1, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, J Galen R. Waltz, Esq.. &J.!'DO.., . 28 South Pitt Street - rei ~ Carlisle, PA 17013 Attorney for Plaintiff 'i~/tJf Joan Carey, Esq. - ./lAd. ~ ~ Mid-Penn Legal Serv{ceS, '1llc. 8 Irvine Row Carlisle, PA 17013 Attorney for Defendant 'I;PI :rc ";~""" - -,,-~ '---"---"~' ,",_ .'1'''''' ,.-, .,,,-< , ._ _C . _. .~ i~ ~ JASON W. HOCKENBERRY Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V CIVIL ACTION - CUSTODY WENDY M. STINE Defendant NO. 01-2015 CIVIL TERM ORDER OF COURT AND NOW, this 11th day of April, 2001, upon consideration of Plaintiff's Emergency Petition for Relief and pursuant to an agreement reached between and among the parties and their counsel in open court, with respect to custody of the parties' child, Bryson Wayne Hockenberry (date of birth April 10, 2000), it is ordered and directed as follows: The mother will have primary physical custody of the child. The father will have partial custody of the child according to the following schedule: Each Sunday beginning Easter Sunday from 10:00 a.m to 5:00 p.m.; beginning the weekend of May 20th, from Saturday at 11:00 a.mto Sunday at 11:00 a.m. on alternate weekends for two weekends; and then the alternate weekends continue from Saturday at 8:00 a.m. until Sunday at 8:00 p.m.; and other times agreed upon if the agreement is made in writing between the parties. The parties will share transportation to facilitate the exchange of custody with the party receiving custody picking the child up at the other party's residence. This temporary order shall remain in effect pending By the Court, ~ (\ / ~,\,\,D\ l) 0 W the custody conciliation conference and further order of the Court. f"""';f!"<"',,, ',' -I ,c' '-~I I' - ~ "M ~"~" ill I ." =.~~~ .-. ~ ,,~.,,"-, '-",~",_'''1 -,",;. "'(0 ,^,,',U'"'''' -"i'~"'~'~~" "" "<"'WIi~W,li.1I . j !\.J.i\!I~~I!\I"i,'\1)8j\ii\:!'N"nJ ~~ (~ : '," , !, I , , 1 1] .,~_ _,_, ,_, _""~''''''''''__'''_''_'''''' ,_, J1JI_ ~~~~~Im!I'l"",~~.m~.",,"!,,__,,~,~!l1~Wf,ij'iW~[I!I~jjlnf~iii!~~~~.m!!~~Jll;i!!l~~~. ',"Pc,\ :--' "~' "~ . ....,. l',~' <"'-, ;';"''''' .4,., ~;{1,", . 4 Galen R. Waltz, Esquire 28 South pitt Street Carlisle, PA 17013 For the Plaintiff Joan Carey, Esquire Mid-Penn Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 For the Defendant pcb , '-'."'-' .'~ '-no I ~- I" JUN 15 2001tf7 JASON W. HOCKENBERRY Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - CUSTODY WENDYM. STINE DefendantJPetitioner NO. 01-2015 CIVIL TERM PETITION FOR SPECIAL RELIEF TO STAY RECOMMENDED ORDER OF CONCILIATOR PENDING A HEARING DefendantJPetitioner, Wendy Stine, by and through her counsel, Joan Carey and David Lopez of MidPenn Legal Services, states the following: 1. DefendantJPetitioner, Wendy Stine, hereinafter referred to as the mother, currently resides at 2 Strohm Road, Shippensburg, Cumberland County, Pennsylvania, 17257. 2. Plaintiff/Respondent, Jason W. Hockenberry, hereinafter referred to as the father, currently resides at 401 Baltimore Road, Shippensburg, Cumberland County, Pennsylvania. 3. The mother and father are the natural parents of Bryson Wayne Hockenberry, born April 10, 2000. 4. The Plaintiff filed a Complaint for Custody and a Conciliation Conference was held on June 13,2001, before Jacqueline M. Verney, Esquire. 5. At the conclusion of the Conciliation Conference, the mother and father had not mutually agreed to modify the Order of April 11, 2001. However, the Conciliator told the mother and father that she was recommending an Order for shared legal and physical custody of the minor child on a week/on, week/off arrangement. The Conciliator advised the mother and the father that the schedule would commence on Sunday, June 17,2001. 6. The Mother requests that the Conciliator's recommended Order be stayed pending a hearing for reasons including, but not limited to, the following: a) An incident in November, 2000, involved the minor child when he was just seven months old in which the father forcefully shoved the child to the floor causing the mother to fear for the child's safety. b) On March 22, 200 I, a Protection from Abuse Order was entered by the Court by an agreement ofthe parties. The PF A granted the mother primary physical custody of the child with no provision for visitation to the father who had been granted supervised visits under the Temporary U",,_~, ._, ^ r r.....,"',~'""I : ~. ~~ "'~ ~..,o~ ''"''''~'''''''''''~_" Order (a copy of the Protection from Abuse Petition and Final Order is attached hereto, incorporated by reference herein, and marked as Exhibit A). c) On April!!, 200!, upon consideration of the plaintiff's Emergency Relief Petition and pursuant to an agreement reached between the mother and father, this Court entered an Order granting the mother primary physical custody and the father partial physical custody gradually extending the time father spent with the child from limited daytime periods to alternate weekends from Saturday at 8:00 a.m. to Sunday at 8:00 p.m. (a copy of the April 11, 2001 Order is attached hereto, incorporated by reference herein, and marked as Exhibit B). d) During the June 13,2001 Conciliation Conference, the mother proposed a custody schedule further extending the father's periods of partial custody to include an additional four hours each week and six additional hours on the Sunday the father did not have custody. The father indicated that he would accept nothing less than equally shared custody. e) When the Conciliator recommended shared legal and physical custody, the mother was adamantly opposed to this arrimgement and requested that the current Order remain in effect pending a hearing. In the alternative, the mother offered extended partial custody time to the father pending the hearing. Again, father refused to accept anything less than equally shared custody. 7. It is in the child's best interest to maintain the April 11, 2001, Order which grants the mother primary physical custody pending a hearing for reasons including, but not limited to, the following: a) The mother has been the primary care-giver for the child since birth. b) Since his birth, the father has only had the child for two overnight visits scheduled for the father, and the father was not with the child for one of those scheduled overnights. The father's periods of partial custody have only been exercised with the paternal grandmother or girlfriend present. The father has not cared for the child for a significant period alone. c) The child is lactose intolerant, which requires special care which the father refuses to provide. In fact, he gives the child milk in spite of the documents recommending not to. d) The father has only been with the child for one overnight visit and the mother fears that the father will not be able to care for the child for a full week. "~*"~"""" ,." ~ - . e) During the father's limited periods of partial custody with the child, he has had him in several different locations and he has not established a stable environment. f) The mother and father agreed to be screened for drugs by a blood test to be administered to both parties the day of the Conciliation Conference. The mother complied with the conciliator. The father has not submitted himself for drug testing, and the mother feels that the Court should at least wait until the results are verified. g) Because of the father's work schedule, he is out of Pennsylvania from Sunday until Friday every week and he is currently not available to care for the child during the week. h) The father does not communicate with the mother regarding the child; therefore, shared custody is not appropriate in this case before modifying the existing Order. i) The mother questions whether the father's insistence on equally shared custody is to benefit the child or to benefit him fmancially since he is currently over $700 in arrears on his child support. 8. Petitioner's attorneys contacted Respondent's attorney, Galen Waltz, to obtain a statement of concurrence, and he does not concur with the granting of the relief requested. WHEREFORE, Defendant/Petitioner requests that the Court grant the following: a) Refrain from signing the Conciliator's recommended Order, and continue the Order of April II , 200 I pending further Order of Court and schedule an expedited hearing on the narrow issue of whether joint custody is appropriate in this case pending a full custody hearing, or b) If the Conciliator's recommended Order has been signed, vacate the Order and schedule an expedited hearing on the narrow issue of whether joint custody is appropriate in this case pending a full custody hearing. c) In the alternative, enter an interim Order pending further Order, after a full custody hearing, which is consistent with the mother's proposal for extended periods of partial custody. ''-'~I "_~"'" ~1~"- - -',- "_"",_ " -I d) Any additional relief this Court deems just and proper. Respectfully submitted, L~ {folk Carey and David pez Attorneys for DefendantJPetitioner MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 /''Wi!.'_~,~ ~ ~ " I -~ I_e ~~ - VERIFICATION The abovecnamed DefendantlPetitioner, Wendy M. Stine, verifies that the statements made in the above Petition to Stay Recommended Order of Conciliator Pending a Hearing are true and correct. DefendantlPetitioner understands that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. Um ~I 10, bO::J I '-'~~-" 'r or, ~I--"'- -I ~, ~. MAR 2 2 200" tJJ Wendy M. Stine, Plaintiff : IN THE COURT OF : COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYL VANIA v. Jason Wayne Hockenberry, Defendant : No. 01-709 : CML ACTION - LAW : PROTECTION FROM ABUSE : AND CUSTODY . FINAL ORDER OF COURT. Defendant's Name is: Jason Wayne Hockenberry Defendailt's Date of Birth is: July 27,1978 Name(s) of Ail protected persons, including Plaintiff and minor children: 1. Wendy M. Stine J.i). n cI AND NOW, 1:his.J,6drDay of March, 2001 the court having jurisdiction over the parties and the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows: Upon agreement of the parties for the entry of a consent order, this order will be entered without any admission of liability by the defendant and without a finding of abuse by this court: Plaintiff's request for a final protection order is granted. 1. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any other protected person in any place where they might be found. 2. Custody of the following minor children: 1. Bryson Wayne Hockenberry shall be as follows: · Custody of the minor child, Bryson Wayne Hockenberry, shall be as follows: temporary EXHIBIT J A "=!I"!'!~.'-"-' "~""",,,----~ - r~^'-" r - ~ '\ _ n_~_- ._. ""~_"".,"" ,~,__~! primary physical custody of the minor child is awarded to Plaintiff, Wendy Stine, pending a subsequent determination involving custody. 3. The following additional relief is granted as authorized by 96108 of the Act: Defendant shall not damage or destroy any property owned by . Plaintiff. Defendant shall not harass Plaintiff's relatives. The court costs and fees are waived. 4. A certified copy of this Order shall be provided to the police . department where Plaintiff resides and any other agency spec~fied hereafter: Mid Cumberland Valley Regional Police Department Middlesex Police Department 5. THIS ORDER SUPERSEDES: 1. ANY PRIOR PF A ORDER 2. ANY PRIOR ORDER RELATING TO CHILD CUSTODY 6. All provisions of this order shall expire on: February 5, 2002 NOTICE TO THE DEFENDANT VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 P A.C.S. 96114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. "-'''''''''''!$iI~I!'I~ .. f":" ~o "T"~" I - fI-- ~'"_~ TillS ORDERIS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE COMMONwEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOl\1EN ACT, 18 U.S.C. ~2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C ~~226l- 2262. IF THE BRADY INDICATOR PARAGRAPH APPEARS IN THE ORDER, YOU MAY BE SUBJECT TO FEDERAL PROSECUTION AND PENALTIES UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACT, 18 U.S.C. ~922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION. NOTICE TO LAW ENFORCEMENT OFFICIALS The police who have jurisdiction over the plaintiff's residence OR any location where a violation of this order occurs OR where the defendant may be located, shall enforce this order. An arrest for violation of Paragraphs 1 through 2 of this order may be without warrant, based soley on probable cause, whether or not the violation is committed in the presence of the police. 23 Pa.C.S. ~6l13. Subsequent to arrest, the police officer shall seize all weapons used or threatened to be used during the violation of the protection order or during prior incidents of abuse. The Cumberland County Sheriff shall maintain possession of the weapons until further order oftms Court. When the defendant is placed under arrest for violation of this order, the defendant shall be taken to the appropriate authority or authorities before whom defendant is to be arraigned. A "Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police officer OR the plaintiff. Plaintiff's presence and signature are not required to file the complaint. If sufficient grounds for violation of this order are alleged, the defendant shall be arraigned, bond set and both parties given notice of the date of the hear',ng. Date T~~:~':' --: ;."'~ ~';Cf)R~ _I III leit!r,; . ,C,,) Serf my hallG ~rh: t ....:iti;l>JYR~~~:.:'a: ." ......~.... .. . Prothonetary '~;p~~~ 1--' - " ~_1Il ~ ~.~, ,~'- - If entered pursuant to the consent of Plaintiff and Defendant: ~~m~ Wendy Stin r Plaintiff ' CareYr Attor idPenn Legal Ser 8 Irvine Row Carlisler PA 17013 '~";jl-"I~'"""'-~""'\I O_I~'1 ~, .---- r Defendant r Attorney , ~- -~ . " PFAD Number: JT1l89192E Wendy M. Stine, Plaintiff : IN THE COURT OF : COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYL V ANlA v. Jason Wayne Hockenberry, Defendant : No. : CML ACTION - LAW : PROTECTION FROM ABUSE : AND CUSTODY PETITION FOR PROTECTION FROM ABUSE 1. Plaintiff's name is: Wendy M. Stine 2. I, (the Plaintiff), am filing this Petition on behalf of: - myself 3. Name(s) of ALL person(s),.inc1uding minor children, who s\lek protection from abuse. a. Wendy M. Stine 4. Plaintiff's Address is : 2 Strohm Rd. , Shippensburg, P A 17257 5. Defendant's Name is: Jason Wayne Hockenberry 6. Defendant is believed to live at the following address: 401 Baltimore Rd. , Shippensburg, P A 17257 7. Defendant's Date of Birth is: July 27, 1978 8. Defendant's Place of employment is: "'.~"''l''~_'I!';!!lf~, r. I~'" , . - ~- --""""--,--,,,, Newburg Steel Erectors 9. Defendant is an adult. 10. The relationship between the Plaintiff and the Defendant is: Parents of the same children Current or former sexualfintimate partner 11. The Plaintiff and the Defendant beeuinvolved in the following court actions: a. Support 12. Other details of the court action are: Cumberland County 13. The defendant has been involved in a criminal court action. 14. Plaintiff and Defendant are the parents of the following minor childJren: a. Bryson Wayne Hockenberry Age:9 mos. Child's address is: 2 Strohm Rd. , Shippensburg, P A 17257 15. Plaintiff is seeking an Order of child custody as part of this petition. The following is a list of the children and where they have live for the past 5 years: a. Bryson Wayne Hockenberry For the past 5 years, this child has lived with: Plaintiff, Defendant, 2 Strohm Rd., 4/10/2000 to present Maternal grandparents, Shippensburg, P A and Aunt Defendant left the residence November 24, 2000. 16. The facts of the most recent incident of abuse are as follows: On or about November 24, 2000, Defendant followed Plaintiff to her car, threatened to kill her, and punched her in the back of the head. Plaintiff sought medical attention at the Chambersburg HospitaL Plaintiff suffered a concussion and headache as a result of the abuse. Defendant was arrested and charged with simple assault, disorderly conduct, harassment, and fighting. 17. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor childJren, (including any threats, injuries, or incidents of stalking) are as follows: O~'"-"''''''''''"''';'>'~ ^.,,--, ~1'l <-,,-'"1 r-- '"1""" ~ -I In or about November 2000, Defendant grabbed the then seven month old child forcefully shoving him on to the floor, pushing and pulling him, causing Plaintiff to fear for the child's safety. In or .about October 2000, Defendant grabbed Plaintiff by the hair and shoved her head into the car window while she was driving. Plaintiff suffered a headache and bump on her head due to the incident of abuse. On or about August 27, 2000, Defendant grabbed Plaintiff by her hair and screamed vile names at her. When Plaintiff walked away, Defendant followed her, kicked her in the back causing her to fall forward, and choked her until she gasped for air. When a neighbor called police, Defendant fled the area. Plaintiff suffered red marks and bruising on her throat. On or about January 1 2000, Defendant punched Plaintiff in the eye with his fist causing her eye to bleed and swell shut. Plaintiff's face remained bruised for approximately one month and suffered a bruised retena due to the incident. In or about 1998, Defendant grabbed Plaintiff by the shirt and she fell to the ground hitting her head on a rock. When Defendant pulled away in his truck, he ran over Plaintiff's hand breaking her hand and her fingers. Defendant left Plaintiff on the ground and drove away. Plaintiff sought medical treatment for her injuries. Since approximately 1996, Defendant has abused Plaintiff in ways including the following: choked, pushed, threw her down, punched, and slapped her. On several occasions, Defendant threatened to kill Plaintiff. Defendant hit Plamtiff numerous times as she held the minor child causing him to cry. Plaintiff has suffered bruises, broken bones, swollen face and eye; cuts; stitches in her head, and two concussions. 18. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: Mid Cumberland Valley Regional Police Department Middlesex Police Department 19. There is an immediate and present danger offurther abuse from the Defendant. 20. FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER A TEMPORARY ORDER, and AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING: a. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/or minor child/ren in any place where Plaintiff may be found. b. Award Plaintiff temporary custody of the minor childJren and place the following restrictions on contact between Defendant and child/ren: Plaintiff shall have primary physical and legal custody of the minor child. Defendant shall have supervised visitation with the maternal grandfather providing the supervision at times and places agreed upon by the parties. Defendant may visit the minor child supervised by the maternal -'t""'~~~''I' _" -;;". .r'_ ft""F"'", "~- -",.~~.~ . 'grandfather at Plaintiff's residence while she is at work. Phone calls to Plaintiff in reference tlf the child shall not be deemed a violation ofthis Order. c. Prohibit Defendant from having any contact with Plaintiff and/or minor childJren, either in person, by telephone, or in writing, personally or through third persons, including but not limited to any contact at Plaintiff's school, business, or place of employment, exc\lPt as the court may find necessary with respect to partial custody and/or visitation with the minor childlren. d. Order Defendant to pay the costs of this action, including filing and service fees. e. Order the following additional relief, not listed above: Order Defendant.to refrain from harassing Plaintiff's relatives. Order Defendant to be enjoined from damaging or destroying any property owned by Plaintiff. Defendant shall pay $250.00 to one of MidPenn Legal Services fnnders as reimbursement forlitigatiolll in this case. f. Grant such other relief as the court deems appropriate. g. Order the police or other law enforcement agenC)' to serve the Defendant with a copy of this Petition, any Order issued, and the Order for Hearing. The petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. Respectfully submitted, Date: o(-f}-O / Joan Carey, Attorney fo MID-PENN LEGAL S 8 Irvine Row Carlisle, PA 17013 Distribution to: MidPenn Legal Services Fax and Mail PSP .~~- "r l' , . VERIFICATION I 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. Dated: 0\.;... d.-9 - 0 I ~YI\. ~ Wendy Stine aintiff '-'9_"''''''r''-'''"'''"~,, ~ - ,- - I ~ ~ I~ - JASON W. HOCKENBERRY Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTYr PE1{NSYLVANIA v CIVIL ACTION - CUSTODY WENDY M. STINE Defendant NO. 01-2015 CIVIL TERM ORDER OF COURT AND NOW, this 11th day of A~ril, 2001, u~on consideration of Plaintiff's Emergency Petition for Relief and pursuant to an agreement reached between and among the parties and their counsel in open court, with respect to custody of the parties' child, Bryson Wayne Hockenberry (date of birth April 10, 2000), it is ordered and directed as follows: The mother will have primary physical custody of the child. The father will have ~artial custody of the child according to the following schedule: Each Sunday beginning Easter Sunday from 10;00 a.m to 5:00 p.m.; begipning the weekend of May 20th, from Saturday at 11:00 a.m to Sunday at 11:00 a.m. on alternate weekends for two weekends; and then the alternate weekends continue from Saturday at 8:00 a.m. until Sunday at 8:00 p.m.; and other times agreed u~on if the agreement is made in writing between the parties. The parties will share transportation to facilitate the exchange of custody with the party receiving custody picking the child up at the other party's residence. This temporary order shall remain in effect pending the.custody conciliation conference and further order of the Court. By the Courtr cA I EXHIBIT g _","'"'f"~ffiI_...~._, t , I~ ~ ~-"~ ----, ._~- - " .~~ "c"-'<~ f\' '1 !"'~:_ffl';1"c"_, Galen R. Waltz, Esquire 28 South Pitt Street Carlisle, PA 17013 For the Plaintiff Joan CareYr Esquire Mid-Penn Legal Services, 8 Irvine Row Carlisle, PA 17013 For the Defendant pcb I"" - -, Inc. . , / v' "1" t JUtU 4 ZOOI tJI7 JASON W. HOCKENBERRY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLV ANIA V. CIVIL ACTION - LAW WENDY M. STINE, Defendant NO. 2001-2015 CIVIL TERM IN CUSTODY ORDER OF COURT ANDNOW,this l~l't. dayof -lu.J7c... , 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: '1.. " 1. A Hearing is scheduled in Court Room No. I , of the Cumberland CouotyCourtHouse,onthebLA.. dayof Ol"fi/J:(" , 2001, at (F30 o'clock, Lt.. M., at which time testimony will be t en. For purposes of this Hearing, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Couosel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten days prior to the Hearing date. 2. The Order of Court dated April II , 200 I is hereby vacated. 3. Pending further Order of Court or agreement of the parties, the following shall remain in effect: A. Father, Jason W. Hockenberry, and Mother, Wendy M. Stine, shall share legal custody ofthe child, Bryson Wayne Hockenberry, DOB April 10, 2000. Each parent shall have 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. B. Mother and Father shall share physical custody of the child such that Father shall have physical custody of the child beginning Suoday, June 17,2001 at 6:00 p.m. uotil Juoe 24, 2001 at 6:00 p.m. and alternating on a weekly basis thereafter. 4. Both parties shall attempt to obtain a full drug screen on Juoe 13,2001 and share the results with opposing couosel. In the event that the parties shall be uoable to obtain a drug screen on Juoe 13,2001, they shall immediately upon receipt of a copy of this Court Order, obtain said drug screen and share the results with opposing counsel. ".il'~F"'!""".'''''''''T ~_~~. 1 '1 ~ 1 I F . ~~~ ~=,~ -~ ,p. .. .~~~ ' =~~"' h. - "1-' ". , ~" ~ ~ \iiNv'!ilFSN~2~" HNi\cn 01'!dlc:Ut!"jnCl ~~ " d "",.-, 0/ l,,!_ (,{, 'V 1" ,. I 1,.;(Yj' I,G D I hiJ }\.:.' !Ii' "" \I.JV_-' :\0 !!O~ 1 ,_,r!l!lll '~",'f_",.7R: ,__~~'lf~~"i.?Jf5ff"l,',~"'~:m~~~_~~~ ,_ ?-,~~,.,; , 5. Neither party will consume alcoholic beverages or use illegal drugs while the child is in their custody. 6. Neither party shall transport the child in an automobile without a child safety seat. 7. The parties shall keep each other advised immediately relative to any emergencies, medical or otherwise, concerning the child. During such illness or medical emergency, each party shall have the right to visit the child as often as he/she deems consistent with the proper medical care of the child. 8. Neither party shall do anything that may estrange the child from the other party, or injure the opinion of the child as to the other party, or may hamper the free and natural development of the child's love or affection for the other party. BY THE COURT, ly 0~{jf\~ l,. JpJO cc: Galen R. Waltz, Esquire - Father David Lopez, Esquire - Mother 4\~ i"~W~",.^ . . 1 ~ I T"" ! JASON W. HOCKENBERRY, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLV ANIA V. CIVIL ACTION - LAW WENDY M. STINE, Defendant NO. 2001-2015 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 conceming the Child who is the subjects ofthis litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Bryson Wayne Hockenberry April 10, 2000 Mother 2, A Conciliation Conference was held June 13,2001 with the following individuals in attendance: The Father, Jason W. Hockenberry, with his counsel, Galen R. Waltz, Esquire, and the Mother, Wendy M. Stine, with her counsel, David Lopez, Esquire, from MidPenn Legal Services. 3. The Court previously entered an Order dated April 11, 2001, pursuant to Plaintiff's Emergency Petition and upon agreement of the parties providing for Plaintiff- Father to begin graduated periods of physical custody of the child, culminating in alternating weekends from Saturday at 8:00 a.m. to Sunday at 8:00 p.m. and such other times as the parties agree. Mother has refused additional times for Father. A PF A Order is also in effect against Father dated March 22,2001, docketed at No. 2001-709. The PF A Order provided for Mother to have temporary physical custody of the child pending a subsequent determination of custody. 4. Father's position on custody is as follows: Father seeks shared legal custody and shared physical custody from Sunday to Sunday at 6:00 p.m. Father claims he has witnesses to testify that Mother has transported the child in her vehicle without a child safety seat or seat belt on three separate occasions. Father, who works in New Jersey, will rearrange his work schedule to work in this area during his week of custody. >:"""""'1~A, ._, HI -~ I , " . Father claims he takes appropriate care of the child, and that the child has been received from Mother with a diaper rash and sick. He only feeds the child the formula Mother provides for the child. 5. Mother's position on custody is as follows: Mother seeks shared legal custody and primary physical custody with Father having altemating weekends from Saturday at 11 :00 a.m. to Sunday at I :00 p.m.; the off Sunday from 11 :00 a.m. to 5:00 p.m. and one weeknight evening from 5:00 to 8:00 p.m. Mother claims Father inappropriately cares for the child while the child is in his custody. The child has been returned w,itlla c!illper ra~h~nQfeyer. Mot~er further claims Father hasfed the child an inappropriate formula while in his care. Mother alleges Father has a drug problem. 6. The Conciliator recommends an Order in the form as attached, vacating the prior Order of Court dated April II , 200 I and scheduling a Hearing. It is expected that the Hearing will require one day. (P-il{--t:J / Date I ~9n,tL. Jac eline M. Vemey, Esquire Custody Conciliator "-:."-'''..0''....,...,. , ~-. r "" r T' / ,. . JASON W. HOCKENBERRY, Plaintiff JUi'l Z 2 ZGC" IN THE COURT OF COMMON PLEAS OF ~ CUMBERLAND COUNTY, PENNSYL VANIA v. CML ACTION - LAW WENDY M. STINE, Defendant NO. 01-2015 CIVIL TERM ORDER OF COURT AND NOW, this 18th day of June, 2001, upon consideration of Defendant's Petition for Special Relief To Stay Recommended Order of Conciliator Pending a Hearing, and the court being of the view that the Conciliator has had the most recent and best opportunity to evaluate the parties and their circumstances, the petition for a stay is denied, without prejudice to Defendant's right to maintain at the hearing before the court that a permanent order of custody should provide for primary custody in her. THE COURT will endeavor to expedite the hearing in this case. BY THE COURT, Galen R. Waltz, Esq. 28 South Pitt Street Carlisle, PA 17013 Attorney for Plaintiff (VWI'M G ~/?-(7( 0 c' C ..~ -0 6:~' L D)n~; c: ~~.. -"- cr~ .' ~c:: " )>........ z~ -.... 5~ S~) z :< :::> -..! ~-fl Joan Carey, Esq. Mid-Penn Legal Services, Inc. Md fCr>(Yla{/'rG/~f) 8 Irvine Row Carlisle, PA 17013 Attorney for Defendant ~~ ']:;'; :::0 -< :rc . .,':~~ '.'-<i Ii ~~~. ~ JASON W. HOCKENBERRY Plaintiff /Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA . . v. CIVIL ACTION - CUSTODY WENDYM. STINE DefendantlPetitioner NO. 01-2015 CIVIL TERM PETITION FOR SPECIAL RELIEF TO STAY RECOMMENDED ORDER OF CONCILIATOR PENDING A HEARING Defendant/Petitioner, Wendy Stine, by and through her counsel, Joan Carey and David Lopez of MidPenn Legal Services, states the following: 1. DefendantlPetitioner, Wendy Stine, hereinafterreferred to as the mother, currently resides at 2 Strolun Road, Shippensburg, Cumberland County, Pennsylvania, 17257. 2. Plaintiff /Respondent, Jason W. Hockenberry, hereinafter referred to as the father, currently resides at 401 Baltimore Road, Shippensburg, Cumberland County, Pennsylvania. 3. The mother and father are the natural parents of Bryson Wayne Hockenberry, born April 10, 2000. 4. The Plaintiff filed a Complaint for Custody and a Conciliation Conference was held on June 13, 2001, before Jacqueline M. Verney, Esquire. 5. At the conclusion of the Conciliation Conference, the mother and father had not mutually agreed to modify the Order of April II, 2001. However, the Conciliator told the mother and father that she was reconunending an Order for shared legal and physical custody of the minor child on a week/on, week/off arrangement. The Conciliator advised the mother and the father that the schedule would conunence on Sunday, June 17,2001. 6. The Mother requests that the Conciliator's reconunended Order be stayed pending a hearing for reasons including, but not limited to, the following: a) Ao incident in November, 2000, involved the minor child when he was just seven months old in which the father forcefully shoved the child to the floor causing the mother to fear for the child's safety. b) On March 22, 200 I, a Protection from Abuse Order was entered by the Court by an agreement of the parties. The PF A granted the mother primary physical custody of the child with no provision for visitation to the father who had been granted supervised visits under the Temporary ;:;-~,<-? __ ~--_"---"", ,~'1 ,rr, ,_ "_, '_' " _ ~I ,'_ -'" ~l;SI Order (a copy of the Protection from Abuse Petition and Final Order is attached hereto, incorporated by reference herein, and marked as Exhibit A). c) On April II, 2001, upon consideration of the plaintiff's Emergency Relief Petition and pursuant to an agreement reached between the mother and father, this Court entered an Order granting the mother primary physical custody and the father partial physical custody gradually extending the time father spent with the child from limited daytime periods to alternate weekends from Saturday at 8:00 a.m. to Sunday at 8:00 p.m. (a copy of the April II, 2001 Order is attached hereto, incorporated by reference herein, and marked as Exhibit B). d) During the June 13,2001 Conciliation Conference, the mother proposed a custody schedule further extending the father's periods of partial custody to include an additional four hours each week and six additional hours on the Sunday the father did not have custody. The father indicated that he would accept nothing less than equally shared custody. e) When the Conciliator recommended shared legal and physical custody, the mother was adamantly opposed to this arrangement and requested that the current Order remain in effect pending a hearing. In the alternative, the mother offered extended partial custody time to the father pending the hearing. Again, father refused to accept anything less than equally shared custody. 7. It is in the child's best interest to maintain the April J 1,2001, Order which grants the mother primary physical custody pending a hearing for reasons including, but not limited to, the following: a) The mother has been the primary care-giver for the child since birth. b) Since his birth, the father has only had the child for two overnight visits scheduled for the father, and the father was not with the child for one of those scheduled overnights. The father's periods of partial custody have only been exercised with the paternal grandmother or girlfriend present. The father has not cared for the child for a significant period alone. c) The child is lactose intolerant, which requires special care which the father refuses to provide. In fact, he gives the child milk in spite of the documents recommending not to. d) The father has only been with the child for one overnight visit and the mother fears that the father will not be able to care for the child for a full week. ',1!-.Jlffl!![ ""~ " e) During the father's limited periods of partial custody with the child, he has had him in several different locations and he has not established a stable environment. f) The mother and father agreed to be screened for drugs by a blood test to be administered to both parties the day of the Conciliation Conference. The mother complied with the conciliator. The father has not submitted himself for drug testing, and the mother feels that the Court should at least wait uotil the results are verified. g) Because of the father's work schedule, he is out of Pennsylvania from Suoday uotil Friday every week and he is currently not available to care for the child during the week. h) The father does not commuoicate with the mother regarding the child; therefore, shared custody is not appropriate in this case before modifying the existing Order. i) The mother questions whether the father's insistence on equally shared custody is to benefit the child or to benefit him financially since he is currently over $700 in arrears on his child support. 8. Petitioner's attorneys contacted Respondent's attorney, Galen Waltz, to obtain a statement of concurrence, and he does not concur with the granting of the relief requested. WHEREFORE, Defendant/Petitioner requests that the Court grant the following: a) Refrain from signing the Conciliator's recommended Order, and continue the Order of April II , 2001 pending further Order of Court and schedule an expedited hearing on the narrow issue of whether joint custody is appropriate in this case pending a full custody hearing, or b) If the Conciliator's recommended Order has been signed, vacate the Order and schedule an expedited hearing on the narrow issue of whether joint custody is appropriate in this case pending a full custody hearing. c) In the alternative, enter an interim Order pending further Order, after a full custody hearing, which is consistent with the mother's proposal for extended periods of partial custody. '~~\~. . -~,r'" ,,, "._ . ~~, - '-I' '" , '1-"'- "-, '; F liB,. ...., '!!1"5'$WF:'<w'0fIIIl,._= "_"C d) Any additional relief this Court deems just and proper. Respectfully submitted, an areyandD idi~(/) Attorneys for DefendantlPetitioner MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 ,. - ,,,~ -" - ~ ~ ~ ..... -. -~ "...,'. .-' 'I " [,~ "o,~o" "'.", "~~"-""'" ~~ -,,~. .._"p~- -," \7;N~'p , "\ )JNnrn 'r!^"~ !N'?d ,-.~> \..!t-.h' \r""" . -' ..::';~-JYVnJ- ~.., GO::: :" (1.1 I "~o 51 1'_1.--,,., '~'i 1! 10 AJ.J\lrr'., .'-~ u\'....' II'" :1' ':;t\;<-;~i{ _ . i, . ~'Ji:J),-"-ce.t:r . jO _.i'_'~ -""'""""~"'''~--rf'(f - " --""'~ ~'T "'t"lr-(' '"M .,,!i!iillfl__ _0 1W~fwIo ~ JJR_._A-..,,JI,, _ ...jj<l!J1~.M'W''',""",li",'I,*,~"",0;~''',-);,Hl~,Wji''\~j)i\,*,%~i4f1',.l-*~~~~~~iJIlm~!~'J'!~~ \. ,)~ . jj..l' ,-~~ VERIFICATION The above-named DefendantlPetitioner, Wendy M. Stine, verifies that the statements made in the above Petition to Stay Recommended Order of Conciliator Pending a Hearing are true and correct. DefendantlPetitioner understands that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. Dol' ~ I 1o,.xxJ \ Wendy M. Sti e DefendantlPetitioner Ie__ ,_,""'" ~"~~ ~~ ""~{;(~""~, -'7-,_" _ MAR 2 2 2001 fj} Wendy M. Stine, Plaintiff : IN THE COURT OF : COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA v. : No. 01-709 Jason Wayne Hockenberry, Defendant : CML ACTION - LAW : PROTECTION FROM ABUSE : AND CUSTODY FINAL ORDER OF COURT. Defendant's Name is: Jason Wayne Hockenberry Defendant's Date of Birth is: July 27,1978 Name(s) of All protected persons, including Plaintiff and minor children: 1. Wendy M. Stine J~ n ct AND NOW, thj,s..1.6tIrDay of March, 2001 the court having jurisdiction over the parties and the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows: Upon agreement of the parties for the entry of a consent order, this order will be entered without any admission ofliability by the defendant and without a finding of abuse by this court: Plaintiffs request for a final protection order is granted. 1. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any other protected person in any place where they might be found. 2. Custody of the following minor children: 1. Bryson Wayne Hockenberry shall be as follows: . Custody of the minor child, Bryson Wayne Hockenberry, shall be as follows: temporary EXHIBIT J A - I" 1 ._, ~ , ~~ ,~Ml~ ~,A' primary physical custody of the minor child is awarded to Plaintiff, Wendy Stine, pending a subsequent determination involving custody. 3. The following additional relief is granted as authorized by g6108 of the Act: Defendant shall not damage or destroy any property owned by _ Plaintiff. Defendant shall not harass Plaintiff's relatives. The court costs and fees are waived. 4. A certified copyoftbis Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Mid Cumberland Valley Regional Police Department Middlesex Police Department 5. TmS ORDER SUPERSEDES: 1. ANYPRIORPFAORDER 2. ANY PRIOR ORDER RELATING TO CHILD CUSTODY 6. All provisions of this order shall expire on: February 5, 2002 NOTICE TO THE DEFENDANT VIOLATION OF TmS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A FINE OF UP TO $1,000 ANDIOR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.s. g6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENALTIES UNDER THE PENNSYL VANIA CRIMES CODE, j!?~1~ ~ ,~, " 1-' '_'~I-- ~ ,.~~., ~_~"'T"" ~_~Y ,;ti!'dll'~, ~, -r'.,_ THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACT, 18 U.S.C. ~2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C ~~2261- 2262. IF THE BRADY INDICATOR PARAGRAPH APPEARS IN THE ORDER, YOU MAY BE SUBJECT TO FEDERAL PROSECUTION AND PENALTIES UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACT, 18 U.S.C. ~922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION. NOTICE TO LAW ENFORCEMENT OFFICIALS The police who have jurisdiction over the plaintiffs residence OR any location where a violation of this order occurs OR where the defendant may be located, shall enforce this order. An arrest for violation of Paragraphs I through 2 of this order may be without warrant, based soley on probable cause, whether or not the violation is co=itted in the presence of the police. 23 Pa.C.S. ~6113. Subsequent to arrest, the police officer shall seize all weapons used or threatened to be used during the violation of the protection order or during prior incidents of abuse. The Cumberland County Sheriff shall maintain possession of the weapons until further order of this Court. When the defendant is placed under arrest for violation of this order, the defendant shall be taken to the appropriate authority or authorities before whom defendant is to be arraigned. A "Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police officer OR the plaintiff. Plaintiff's presence and signature are not required to file the complaint. If sufficient grounds for violation of this order are alleged, the defendant shall be arraigned, bond set and both parties given notice of the date of the hearing. J Date 1 ' -' 1- ~ "~,, ."'~"'" If entered pursuant to the consent of Plaintiff and Defendant: Wendy CareYr Attor idPenn Legal Ser 8 Irvine Row Carlisler PA 17013 l:ii~!!l!'m,IT!- , " ----- -- r Defendant PFAD Number: JT1189192E Wendy M. Stine, Plaintiff : IN THE COURT OF : COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA v. :No. Jason Wayne Hockenberry, Defendant : CIVIL ACTION - LAW : PROTECTION FROM ABUSE : AND CUSTODY PETITION FOR PROTECTION FROM ABUSE 1. Plaintiff's name is: Wendy M. Stine 2. I, (the Plaintiff), am filing this Petition on behalf of: - myself 3. Name(s) of ALL person(s),.including minor children, who s\lek protection from abuse. a. Wendy M. Stine 4. Plaintiff's Address is : 2 Strohm Rd. , Shippensburg, P A 17257 5. Defendant's Name is: Jason Wayne Hockenberry 6. Defendant is believed to live at the following address: 401 Baltimore Rd., Shippensburg, PA 17257 7. Defendant's Date of Birth is: July 27, 1978 8. Defendant's Place of employment is: ":"--",\~!~",,f"," '''-j1' ~I'--r '"-'~-'I j- ~ Newburg Steel Erectors 9. Defendant is an adult. 10. The relationship between the Plaintiff and the Defendant is: Parents of the same children Current or former sexualfintimate partner II. The Plaintiff and the Defendant beeuinvolved in the following court actions: a. Support 12. Other details of the court action are: Cumberland County 13. The defendant has been involved in a criminal court action. 14. Plaintiff and Defendant are the parents of the following minor childlren; a. Bryson Wayne Hockenberry Age:9 mos. Child's address is: 2 Strohm Rd. , Shippensburg, P A 17257 15. Plaintiff is seeking an Order of child custody as part of this petition. The following is a list of the children and where they have live for the past 5 years: a. Bryson Wayne Hockenberry For the past 5 years, this child has lived with: Plaintiff, Defendant, 2 Strohm Rd., 4/10/2000 to present Maternal grandparents, Shippensburg, P A and Aunt Defendant left the residence November 24, 2000. 16. The facts of the most recent incident of abuse are as follows: On or about November 24, 2000, Defendant followed Plaintiff to her car, threatened to kill her, and punched her in the back of the head. Plaintiff sought medical attention at the Chambersburg HospitaL Plaintiff suffered a concussion and headache as a result of the abuse. Defendant was arrested and charged with simple assault, disorderly conduct, harassment, and fighting. 17. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor childJren, (including any threats, injuries, or incidents of stalking) are as follows: -;'i~~ ." .,,-.,-, - In or about November 2000, Defendant grabbed the then seven month old child forcefully shoving him on to the floor, pushing and pulling him, causing Plaintiff to fear for the child's safety. In or .about October 2000, Defendant grabbed Plaintiff by the hair and .shoved her head into the car window while she was driving. Plaintiff suffered a headache and bump on her head due to the incident of abuse. On or about August 27, 2000, Defendant grabbed Plaintiff by her hair and screamed vile names at her. When Plaintiff walked away, Defendant followed her, kicked her in the back causing her to fall forward, and choked her until she gasped for air. When a neighbor called police, Defendant fled the area. Plaintiff suffered red marks and bruising on her throat. On or about January 1 2000, Defendant punched Plaintiff in the eye with his fist causing her eye to bleed and swell shut. Plaintiff's face remained bruised for approximately one month and suffered a bruised retena due to the incident. In or about 1998, Defendant grabbed Plaintiff by the shirt and she fell to the ground hitting her head on a rock. When Defendant pulled away in his truck, he ran over Plaintiff's hand breaking her hand and her fmgers. Defendant left Plaintiff on the ground and drove away. Plaintiff sought medical treatment for her injuries. Since approximately 1996, Defendant has abused Plaintiff in ways including the following: choked, pushed, threw her down, punched, and slapped her. On several occasions, Defendant threatened to kill Plaintiff. Defendant hit Plafutiffnumerous times as she held the minor child causing him to cry. Plaintiff has suffered bruises, broken bones, swollen face and eye; cuts; stitches in her head, and two concussions. 18. The police d\lPartment(s) or law enforcement agencies that should be provided with a copy of the protection order are: Mid Cumberland Valley Regional Police Department Middlesex Police Department 19. There is an immediate and present danger of further abuse from the Defendant. 20. FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER A TEMPORARY ORDER, and AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING: a. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/or minor childJren in any place where Plaintiff may be found. b. Award Plaintiff temporary custody of the minor childJren and place the following restrictions on contact between Defendant and childJren: Plaintiff shall have primary physical and legal custody of the minor child. Defendant shall have supervised visitation with the maternal grandfather providing the supervision at times and places agreed upon by the parties. Defendant may visit the minor child supervised by the maternal :",!+1''%I';')~rn'f!Ili~, r-' ~ .,n ~__ [-"" li- l' ..,.~= r . grandfather at Plaintiff's residence while she is at work. Phone calls to Plaintiff in reference t8 the child shall not be deemed a violation ofthis Order. c. Prohibit Defendant from having any contact with Plaintiff and/or minor childlren, either in person, by telephone, or in writing, personally or through third persons, including but not limited to any c~ntact at Plaintiffs school, business, or place of employment, except as the court may find necessary with respect to partial custody and/or visitation with the minor child/ren. d. Order Defendant to pay the costs of this action, including filing and service fees. e. Order the following additional relief, not listed above: Order Defendantto refrain from harassing Plaintiff's relatives. Order Defendant to be enjoined from damaging or destroying any property owned by Plaintiff. Defendant shall pay $250.00 to one of MidPeun Legal Services funders as reimbursement for litigation in this case. f. Grant such other relief as the court deems appropriate. g. Order the police or other law enforcement agency to serve the Defendant with a copy of this Petition, any Order issued, and the Order for Hearing. The petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. Respectfully submitted, Date: o(-~-() J Joan Carey, Attorney fo aintiff MID-PENN LEGAL S RVlCES 8 Irvine Row Carlisle,PA 17013 Distribution to: MidPenn Legal Services Fax and Mail PSP '-1:"~~~ I I ~ ."- .,. 1;11 ['T" 1 _~<~J,~~"",~ VERIFICATION I 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. 94904, relating to unsworn falsification to authorities. Dated: 0\ - 'd-9 - 0 I ~~m.~ Wendy Stine aintiff .,q~,-,~,~ 1 " ' , I'" ~""'I I 'f ~, -~, ~ JASON W. HOCKENBERRY Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTYr PENNSYLVANIA V CIVIL ACTION - CUSTODY WENDY M. STINE Defendant NO. 01-2015 CIVIL TERM ORDER OF COURT AND NOWr this 11th day of April, 2001, upon consideration of Plaintiff's Emergency Petition for Relief and pursuant to an agreement reached between and among the parties and their counsel in open court, with respect to custody of the parties' child, Bryson Wayne Hockenberry (date of birth April 10, 2000), it is ordered and directed as follows: The mother will have primary physical custody of the child. The father will have partial custody of the child according to the following schedule: Each Sunday beginning Easter Sunday from 10:00 a.m to 5:00 p.m.; beginning. the weekend of May 20thr from Saturday at 11:00 a.m to Sunday at 11:00 a.m. on alternate weekends for two weekends; and then the alternate weekends continue from Saturday at 8:00 a.m. until Sunday at 8:00 p.m.; and other times agreed upon if the agreement is made in writing between the parties. The parties will share transportation to facilitate the exchange of custody with the party receiving custody picking the child up at the other party's residence. This temporary order shall remain in effect pending the custody conciliation conference and further order of the Court. By the Court, EXHIBIT I g ;:'-',-':"","~~ffi1., , ~~"~. -, ., ," ~~ 1~" m, " ~ Galen R. Waltz, Esquire 28 South pitt Street Carlisler PA 17013 For the Plaintiff Joan Carey, Esquire Mid-Penn Legal Services, 8 Irvine Row Carlisler PA 17013 For the Defendant pcb '>i'~~_ ,_, ",I -,' Inc. / e - ~~ - JASON W. HOCKENBERRY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. WENDY M. STINE, Defendant CIVIL ACTION " LAW NO. 01-2015 CIVIL TERM IN CUSTODY AND NOW, this 6th day of August, 2001, upon consideration of Plaintiff's complaint for custody with respect to the parties' child, Bryson Wayne Hockenberry (date of birth April 10, 2000), and following a hearing held on this date, the record is declared closed and the matter is taken under advisement. By the Court, Galen R. Waltz, Esquire 28 South Pitt Street Carlisle, PA 17013 For the Plaintiff c:~~ Joan Carey, Esquire Mid-Penn Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 For the Defendant pcb '"",,,,~~WOI'1"'_~ " -':~-" 1 --',' '-"; ~ . , , ~. r~~ ~ "~~.""' 'd' "'.-~ - L" "" ___w -, ~ I' .. - 'f. , ~''''-''-' -,,^~', . -A_'_'"".~~""";..",,,,,,,,,,,,~,"_",, '. 0''''_._,_.", ,"""'';A><~>~ , . ~~-='~' 1i(f<'~' --,~' J". v1NI/^lASNN3d ALNnOO Oi'I\t'~U38vvm &t.::8HtI E..,SilVIO ^t~tlO;'{:::-:_:.._ ~., j JO j~)lJ:jo--(ij iH ._~ .~_7'" ,~'!, "c, _ _,..;., r~~ _, ~""!!!l'.. ,fl~~~~i'L""1-"'"!'1!!fjliP...!:'~~M!lW!B,,,."~~, ':'-"""':+'7,--JliJ~~~_.::._""_,,,t,.~__~<~;4 i,z,"d ,,~." -' " ~ " I V\ , ,........ ~di p- z:r.: ~.,..j <( ~~ oJ 11. ':Q ~ $;' I I ~ '-! i iq "Q f' : 15 ~ ~~. I~ $0 I' ~~ !'; ~~i; f1-":;;1 '-I. I ~e; ? Jg;,~ i I ~ 1j ~ !:$ ~:;'.;<~8 Ii'!/:;' -""~1!1i-d; ~:.:: oiO'~.~~ .( ~ ~,,\,.)~.~ ,:; ,;' l~ fi11: ~ ~~1:J; g .e>M Q ~ ' ~ ~~ ~ - $9 ! J f ~ i e i ~ ~ (j 1 .t. E , ~f:! UJ~-:;; '"d ~-a 5~1~ ~~ ig~il;: J ~,~ .9' ;f .iJI!'ldH~" ~,' ..:;..J J~' ~.. ;~ Q, ,I ':S' UI .;r ! ,?I l! ; ~ g ai ~. ~ ,~~ j3 ~~. 'l;:I 1"1 is .1(. i:; ! Q "';:! ill - ~ c: ~ I....LJ ~ ~ fj ~ ~ .. :.:. .0 '~j:l! """ El Q~. : I '........r-) ci ,o;~ l.~ ;i 1 J,' -4~ ('.. ~ ~ j f€ _ (,01-1..-400 1/..; I I .'~" oj" l ",-~: it I i:i ~ ~ c: ~ I ~~ I J i ..J~ ,":28 I.l,J l:iJ ) :s ~ J c.I 'f:l lj,,~ 1 g~ Q B E ~ g; I 0"\ f "'" '" I ~/"? "'''~" I ';:,,0lS Z2S L'tJ.. s ~j " dIHSNMOi ~~ngSN3ddIHS W~ 9z:Jl 10-Pt-Nnr ,-" , "'1__' < AMERICAN MEDICAL LABORATORIES, INC.@ . P.O. Box 10841 . 14225 Newbrook DriVe. Chantilly, VA 20153-0841 Telephone: (703) 802-6900 . (800) 336-3718 iIOCKENBERRY. JASON WAYNE ~'~nA 1 ~rom Ch9ntllly. LOLLEeTED: 07/05/2001 !-.(E.CELVEU:; ilJ7/rlJ7I 2 QilZil REPORTED,07/0e./2001 ,-",lilt: fu' 16151/ E..:.J/3"3126917 PinrENT ID, 174580145 ~-::.l IF.: EODE: NOT PROVIDED_ Pleas. note: GALEN WRLTZ :5'3125977/0 (A[)UL T ASSUMED) J_; FO;i ;:r'+'J2:~ 16151 CHAMBERSBURG HOSPITAL-D&A> TEST'RERSDN:O-COOfiT ORDERED COLL, , SI TE: CHHI'IBE:RSBUSC'l.. PH --.._,,- -'-'-~---"----4ES TS-.-,--..---------'RE SUL TS-FLAG-- REF. RANGE ----~ --UN ITS ;, S0t5/Ch:ciflt t 11 v '-1'jpdJcole:oal TOX1ColorlY ~lF.:Drr.OL.EGAL CHAIN-Of-CUSTODY REPORT. Chaln ot Custody document rec~ived ahd speci~eh F"-"l intact.. NONE-DF_tEC.IEll __" _.' 20 ho/mL as carboxy-THe ..NONE....DEl:I::L.iED. 100 ng/mL as amphetamine NOt~E DETECTE-.D Ilmit 50 -ng/~L as-benzoylecgonine NONE DETeCTED 50 nq/mL as morphine NONE nE. r",..;1 t:,U 10. hJ;l/mL ;~l';",illt."~,-~/ C;M'~nt i 11 y :.,on1"1('Jn.-r:1 {)!"uq Hbuse SCl"een Serum'~ruo Acuse- Screen f'lARLJ_lJ!'.;i\!H .18'tec-tU)n limit ;:1:YiPRE1'1~i'Tt I NEb ."i,:;tec'tlon 11mit ,~OCRINE METABOI.. I TE .::;el:eC1;lOn [J[J Ij:.'ITEt3 detectlon limit: ;.,;p ~(I"rH:.i'lc;YCLI DINE i det;ectlon limit_ Cm~FI m'\rlTORY TESTS No a.rU\:JS were detected. ..,. (Confirmatorv tEsting not .. perTormed en negatIve screens. ~ Ii-' ,~, 1 R'7J - LB, i Bic:8I ,,^x FINAL REPORT *** Nathan Sherman.'M.D. Dirac.to!!" elr -LQ,j:J~to'('i_(!JL PLAINTIfFS EXHIBIT , ,11$ __m .?r; Of ft1~ ~~-- __ NATHAN SHERMAN, M.D. "DIItECT<5R OF LABORATbRIES , ~,. - Age and sex dependent reference ranges are printed when available if age and sex are designated. Otherwise, adult values are given. 167074 R 1100 " II II n " Ii I] ii>_,_,~,,,.,, ".. CHANTILLY (Alai) COLUMBIA (A13) - ",' "~" l YI~...J"l[;m~, , T -~_. -"~" ,',..'l\. ~.",~ AMLCENTRALLABORATORY American Medical Laboratories, Inc.@ 14225 Newbrook Drive Chantilly, VA 20153-0841 AML SATELLITE LABORATORY American Medical Laboratories, Inc.@ Two Knoll North Drive Columbia, MD 21045 , . - jfL.j >"71''''' ~ ')/,1"" Y, _.. ,J t,. ....--" I L "---,~, ~".. --- "l -~ . ~ "', "--"~'~~ ."~. _J~~"(~~!fJJ_'fI!$~~~~~""':fJ'0jNl,'O(" -"t';.,. ;'~:,l~',\'''cr":'';'i.7'i''':'PJi<~Wh~r:l';l-f.#~'t.#;!f-:'!~~'1f,~,'''t,j,,,,."FAlin!j'.lil~j~t1iliit.~,.J<; DRUG TESTING CUSTODY AND A~QUEST FOAM Amer\can"M.ed'-c:a\ Laboratories,lnc.. ~ ~ 4225 Newbrook DrIve P,O. Box 10841 Chantilly, Virginia 20153-0841 703~a02-~900_ ~8QO-852-952a AMI.: ~ ~w ~!Il llll:; :>Z "g :l~_ ... -oS; 0" ~m liii m!;; ... 39126977 A. Employe'r Name. Add/SS and 1.0. No. Go..\CL\"\ WCI...\i--z.. T VUrO Lct0 d-8S0vh\~\ti Q.cu{" \ \~k PA ' :_ _~MRO Name and Address 16151'- 4651' T'1.9:2'P CHAMBERS13URG HOSPITAL-.O&A* CODE S-L , DoG 07 ll.J! \ I Y ~ l.o~ 45" "T' FAX 17172677127 15 G,Oonor&SNorEmployeeI.D.No, -0 \ ,Name --lA'iol\} D. Reason for Test: 0 Pre-employment 0 ~n,dO, m ___-,-:...~ ~e~~o-rjIC 0 Reasonable S)(SPiCiOnr.faus~ -- 0 Post ~ccident o Return to Outy D 5Pllow.W ~ OTHER (specify) !,;,OV" '"Ll'd<2.r-e'ld. TESTS REQUESTED: NQT FOR, ,D, OT TESTING , nRU~ SCREC"N _____\*2753)-- PROGRESSIVE w ~ _ ~ ~16 _____(~2Z33)--,FROGRESSIVE DRUG SCREEN *5 ___ ( +tZl 9Z 1 -- PROGf\E:Sp I V.E;PR,UG _p]::RfEN t14 __.:'J{_ O1l80!5 1 -- CHA'! N 01'" GUSTOn y .- - _____( * 05'11 -- ALCOHOL ,__J:iLC)gO _____(~1931)-- NICOTINE SCREtN ______(#2643)-- SPECIMEN STORAGE:" _ ~ _____("H3861---ALCUHOi.,., U~INE: 0 f\ "'" 5cr' ~ 6erum X #.110010 Con flfmcdbr uq 0 r ribUo,J(,.. '-- 'C..t'n. " C 4 Be r u.J'M, .\.lA. 'of'S seY'. -\- ') JAN 2001 ~ " ~ GOLtt',cTION SITE LOCATION: \ 1_ ~hlfYl bees b~n~~~:F~I;yi, t<l \... \\'2. N It' tr<..d ' Address Specimen temperature . N SPLIT SPECIMEN CnLLECTION D YES ,NO REMARKS::O (' e Co. I certify that the specimen - identified on this form is the specimea pre ted to me by the donorJprovrdlng the certification 017 Sta identification number as that set forth above, and that it has been collecta . laP.e{lf"l.P.. (mq_~fJ.8.-'ed as in ~pcprdance with app!icable/equ!re Viri.r k, 1'(1\ If\/f" . (~RlfIT) Collector's Name <~i.rst, MI, UBt} of this form, that it bears the same spfiCimen ~~.. J ) Itb I( rk. I' 'f n r"t '. \ .. ~ - . Slgnaturo 01 Collector QI~r}~;~)J ato(o.IDay r.) 'Q"'.C: . " m. "STEP 4: TO BE INITIATED BY THE COLLECTOR AND COMPLETED AS NECESSARYTHEREAmR MO. OtAY SPECIMEN RELEASED BY _m SPECIMEN RECEIVED BY * Collecto' ,I 1,. I " . "" /, ~ ,', '" ~QQ.~l!!!_~L...:..L..Ll..L-.:..L_~Li.D1L:J..L__._____ Name \1 r, ~\ -( 4'1..- f)1rr S;~~~'::'=_(J;:;tQ.,,-"'_g~__L""'~"_..._n..._ Name /<=';,J~, A C ~ u..,..~ Si~~~~:__f.: OL__:;.e.LLki1.J'..__4~:..oY-~~-_._ 0 Name rt::.., 1"" PU F CHANGE PECIMEN FOR TESTING 1 , , !~iOI , , Signature Signature , , , , 1 i6 !ol Sf STEP 5:-'0' BE COMPLETED BY THE LABORATORY iii !E, * By. sIgnIng this form, I acknowledge the specimen{s) that are labelled witb ~tbi~,- Reg'uest Form - N;: to b'e my- __Sp'e_ci~J1'S) and th:tihey ha-~e been labe ed and seared in my ~ presence. If collection was witnessed. that I release from Iia,biljty any and all persons associated. with witnessing of collection of 1]Y_.specimen. 1 also authorize AMl to conduct ~ testing for drugs and to report results to my employer or potential employer who require this te.sting. I certify that the specimen(S) is roy own and has not be!;lJ) p;lten~d< SEAL INTAcT? DyE's tj'~'o.IFNO []J30X -if 4'_ Ofi" ,~," ',' _~ (i-(JI _ reo F ITBAd [j SPEGIMI=N~ Name Name COpy 3 - TO MEDICAL REVIEW OFFICER OR EMPLOYER (OPTIONAL) _'. .. "'------....-~.~~,.p _ -'--'-'~~r'''----'-------' ~., . ,., ''''.''..~". ...........................," '" .........,,"'.... "", .". ' , '. , . ,." ' ~ ~I).\~ 3NI1S 3/tI\fW AaN3M 80NOQ NI1Df:lO LSZLl'l1d !SIl::InaSN3ddlHS aCt WHO!::llS Z .J. suorlo!Jlsal:f 'paWFwo:J o Slu;:l'l.LlasJopU3 Sse/::> N8~ ,,170 S :;i sa"\'3 ~l/61~H xaS <::> '" ZO/Lt/BO C::8/~OfSO 66/0~t:oO f-.I. S~ildx3" ~~E!Q l/lJ18 panssl \.'~iJ ,~;, ')q\"f '111 NT] I? i-l.:or)Nn 999 8<::<:: 9<:: 'Q,'~ ~c:;.,'_ ~p "" "'~ ''''--'''' - .,.', ,', :~ DEFENDANT'S EXHIBIT tI,B. $, ?i/d "-". c o . --'~~.5I:'~~~~'~:i;.~:~::-:i~~~~~.ii.~;;;;;';;;;=.;;;;;=__'" ~_=;;-.:;.::o:-,Ji;;;;:o.;;:_;;;;;;;;;=-=_=;;;;:==:::i;; , FRANKLIN COUNTY PEDIATRIC ASSOCIATES 176 South Coldbrook Avenue. Chambersburg. PA17201 I (717) 263-0550 MEDICALLY EXCUSED ABSENCE This is to confirm that ~on ~~l:e_rYy_ was seen in the office on ~.l2:0 I D ( ._' If-J.zj 0 I He/she is able to return to work/school on Limitations/Remarks: ~ ~ ~h- ~n;!z? ~ ~ur'iflw, I\'m , . ('O~CKll Y-lo-m Date DEFENDANTrS EXHIBIT <? '#""5 D . ~, I' rr ~ :.,~!!'OO!;l"11'l' ~'O'. ".J ~...!!!' I! :' "';; , r "_ ,~"""'~ <f:~ ~IENT tJ.. Emergent 0 Nonemergent EMERGENCY CARE UNIT INSTRUCTIONS d' , HOCKENB . Y BRYSON WAYNE04/08/01 CHAMO,""mURG 112 North Seventh Street 7) 267-7146 r HOS'~ Chambersburg, PA 17201 Acct#: 324077 -7 MR#: 533430 ..4'1"'-1_8_ " The treatment you have receIVed has been rendered on an emergency basis only. It IS Important that you follow discharge Instructions and receive follow-up care. Follow the Instructions below that are checked and any additional instructions given, WOUND CARE [] Keep dressing clean and dry for next _ day (a) . o Following this t.ime period, remove dressing, wash wound with soap and warm water, dry thoroughly and cover with appropriate bandage. Repeat daily until the wound has heald. o Return here for wound check in day(s). Datel o Ha~sutures removed in _ day{s). Date: 0_ times{s) a daYi wash burns thoroughly with soap and water; then reapply SilvadeI1e cream ~ redress. Keep dressing clean and dry. o Yo."pt wound has been closed wit.h Steri-strips. They must be kept clean and dry. Leave steri-strips in place until they falloff ~pontaneously in five to seven days. [J Warm wal;er soaks or compresses for 15 minutes four times daily. [J Return -immediately to the Emergency Department or your family doctor .if ,_11!igna of infection develop- in~~easing redness, swelling, pus, foul odor, red streaks, fever. ORTHOPEDIC & BACK INJURIES o lpJ2ly ipe intermittently to the affected area fo~ the next 4a hours and keep elevated to reduce swalliI).g. o Rest affected area_day(s) or until pain-free. D,us'e' crutches; do oat bear wei~ht until able to stand without pain; then slowly re~urn to normal activities. [] You may remove elastic bandage and/or -splint every_day(s). If affected area is still painful, reapply and continue use until pain-free. D Be;d.:".r~,at for the next_day(s) D We~i elastic bandage and/or splint for_____day(s). o If the extremity beiow any bandage becomes increasingly painfu~, numb, blue,or swollen, remove or loosen it immediately and contact the Emergency Department. ::J Us~,,_,a;lr cast according to the instruction sheet. Sse additional Instructions pJ:'ovided: ::J He'ad I;njury ::J Animal bite ~ Tetanus immunization series MEDICATION INSTRUCTIONS [J Get prescription filled; take or apply medicine as directed on label. Discontinue medication if allergic reaction'occurs (rash, trouble breatliing or other sudden, unexpected symptoms) and contact Emergency Department iwmediately. o Take 2-3 Advi1/Nupri~/Ibuprofen every 4~6 hours as nee~ed for pain or fever greater than 101 degrees. Take with food. ' o Take two Tylenol every four hours for pain or fever greater than 101 degrees. o Continue current medicine. See medication information provided: "fi.J Antibiotics" O"Muscle relaxants -b~ti-inflammatories 0 Decongestiants/ CJUarcotics/sedatives Antihistamines ~RAL INSTRUCTIONS Increase Fluid Intake Take only small amounts of clear fluids overnight. o Gradually resume a normal diet" Carbohydrates such as toaat, plain rice, applesauce may be helpful. Dairy . products may make your symptoms worse. ~~~e vaporizer or' n~l mi~ humidif~eI;.. ~~r pain or temperature over 101 .degrees use aspirin-free medication (Tylenol, Tempra, Acetaminophen, etc.) by fol~owing s~hedule. CHILDREN'S ACETAMINOPHEN DOSAGE RECOMMENDATIONS AGE 4-11 12-23 2-3 4-5 6-8 9-10 11 12-14 GROUP _ M05 MOS YRS YRS YRS YRS YRS YRS Weight 12-17 18-23 24-35 36-47 9. (lbs.) 4B-59 60-71 71-95 and over DOSE OF 80 120 160 240 ACETAM!NOPImN 320 400 480 640 (in.ml.) mg. mg. mg, mg. mg, mg. mg. mg, DROPS 1 1.5 2 (BOIng/O.amI) - - - - - ELIXIR (160mg 5ml) .5 .75 1 1.5 2 2.5 3 " tsp. full CIlEWASLE TABLETS - 1.5 2 3 4 5 6 - (80mg each) JR. STRENGTH SWALLOWABLE - 2 2.5 3 4 TABLETS - - - (160mg each) Repeat dose every 4 hours as needed. Do not bundle child in blankets. D For pain or temperature over 101 Quse Children' 8 Motrin by following schedule. Take every 6 hours as needed. AGE 6-11 12-23 2-3 4-5 6-8 9-10 11-12 Adult GROUP MOS 'MOS YRS YRS YRS YRS YRS weight(lbs.) 13-17 18-23 24-35 36-47 48-59 60-71 71-95 FOLLOW-UP CARE INSTRUCTIONS o Return to the Emergency Depart. in ____day(s). Date: Time: o Call Dr. Telephone #: for follow-up appointment in _ day(s). o Driving restrictions: o DO NOT dd ve for the next hours/days (cirCle one) 0;;-;;; drive until evaluated by Dr. D Worker's Compenaation:Return to the Emergency Department or call your company's designated physician if you develop new sympt~ms, if your symptoms have not improved in _day(s) ,:-or if any aspect of your condition should suddenlY worsen. ~ Return to the Emergency Depart. or call your family doctor inunediately if you develop new symptoms. if your symptoms have not i~rO'Ved in '- days, or if any aspect of your condition suddenly worsen. ADDITIONAL INSTRUCTIONS [] Your x-rays have received a preliminary interpretation by the Emergency physician and will be reviewed by the radiologist within 24 hours Please call the Emergency Department in 24 hours for rir final interpretation. ~ Eye instructions: Return to the Emergency Department or call your eye doctor itmUediat.ely if increasing pain, redness, discha_rge, or blurred vision develops. D While in tf?e Emergency ROO~. your blood pressure was found to be elevated. This may be due to the stress of an Emergency department visit.We recommend your blood pressure be rechecked by your family physician within one week. [] A culture specimen has been obtained to test for bacteria. please call the Emergency Depart. in 3 days for results. D Stop Smoking. OTHER: ~ Doeage in tap ....5 1 1.5 2 2,5 3 / " Physician's Signature "7"""'_""~"'~~ - - - of the ahove instructionS'j includin~ the additional in.truGtiJ'/", sheet.. Date, L:r 1,'-0 1c---Time,,!:)<-=i.lrj A:'J'!./P.M. D~~T"~= n~n.. L"1Q(i~~~.9_^ OAf ~ \ 1__, ~.. 1- ~- ~ =~_._~ . ,~ .'- '<'--'~"''''-'''=" '-' ,,--- j! 08101101 ~" ;; 08101101 K 07116101 < \, 0710910 1 <, " 0710910 1 ~, 0710910 1 " ~06125101 it 0612510 1 ~, 0611810 1 ji 0611410 1 ;::: i!f 0611410 1 '105131101 % DEFENDANrs EXHIBIT , , l~if ~.[.;,;:J! f(~;jj;, ON-SITE DRUG TESTING CUSTODY ttN{] (}{J~;'[B(M. FORM .. AMI.: ;D.mer'can W\ed\ca\ \..a.bOTa\OT\e.s, \nc. 14225 Newbrook. Drive P.O. Box 10841 Chantilly, Virginia 20153-0841 703-802-6900 . 800-852-9526 ~TEP 1: TO BE COMPLETED BY COLLECTOR OR EMPLOYER REPRESENTATIVE d diD N B. MRO Name and Add"'.. A. Employer Nam.~, Ad ress an .. o. ::;~;! tOO'~~ ;'2~ LHAl'1m:n,,!i'lW,(;; HOSPITi'.L. r)S-~pf.~lRTH~~iiT OF PATl-'\Ol~CH;;;'V 'rrH (.~f\JD j( .TNt} E;TREETS CI'!N11.1EH,BHUIiG, P!\ :I 720 i 'l:l 7--~,~'i1'1~.-~11J71 I F f~}\ 17 iI' =-7f ::-/~~II::<7~-~i ;l? "K j" ,.Jl""N ?(lO'l, Name ,,f 1/ A'-'LP;j.:~:"'. po- ---""" Periodic 0 Re~o;;ciliie ~{?USP.i6ion/C~~se Q Post ~ccident __.... r? "'~) ;) ....- ('.1"1....;>;(' ~ ""v~:-~ .e "', .J2t",OTHER (specify) '--'"/:"'~! ~ .f 'J .. ,. ". ~::.~:::",,~,.... F- I, ... LABORATORY ACCESSION NUMBER ... CODE T ll."'i~::':; p ! i.1 f r'" "f'l i ' ,..J f ".,. (,'fvln , ,-,-, _ l' t...~.'..(,(=-.1'eL '-.. ,;, !"tV, ~.~)t" /ui ,/ (c: l{ r- -'\, \,,( ID N" -..:;.;. ~:;". I /- C. Donor SSN or Employee . . 0.' I D. Reason for Test: 0 Pre-employment 0 Random : 0 o ReturQ to Duty 0 Follow-up ON-SITE SCREEN RESULTS: (Check appropriate column) POS NEG POS NEG PCP '.L~:,) -r=- t ,,"'-" ")'t.'.,_..' -,---- \r~:')- OTHER AMP THC OPIATES ~~' ':x:-' ~ IF ANY ANAL YTES SCREEN POSITIVE SEND THE SEALED SPLIT SAMPLE TO AML FOR CONFIRMATION TESTING DEFENDANT'S EXHIBIT -- ":J"! --=' COCAINE __~~~ (Ii ,'rX' r 'n ~- --~ ~STEP 2: TO BE COMPLETED BY COLLECTOR - Specimen temperature must be read within 4 minutes of collection, o No, Record specimen temperature here Specimen temperature within range: 0 Yes, 90" -1000 F/320 - 380C ~STEP 3: TO BE COMPLETED BY COLLECTOR CO,LLECl'ON SITE L~CATION: , , ! f \ U /jJ L.Pi l'J..t'.L"k,. hI.-... _ i-"~b.) 'S.-J,.- . -... , \ ;'ibllecllon Facility V i I z.. IJ ~Nj{ VST -,." 1"'c.12-_/ 17(7) ;:;(r:,-7 71) :? Collectors Business Phor'fa No. t :)1 {ftt4/~>f'rs/:;?'l ;)/0. /"7';>(j ( .. . CIty /r . State Zip , ! REMARKS:' -,' I certify that the specimen Identlfled on this form Is the specimen presented to me by the donor provldfn the certiDcarfon on Step 4 of this form, that It bears the same specimen f~e~?:c~otrnU,"-ber as that se~~rth abo".j€1; and that ft has bee:~::!,!:::;!djbe/ef1.~nd sea!f1 as ~~. :~~ ,6 ce with applicable requirements. " .,:.,1. V / I'", -r,~, ,; ~" \ ! " .. /~ . ( ...- '4,..pr'-~ f.?J 1131()'/ I () :lj.o" 'M ... (P INT) oll~ctorlil NlilmCl (Frr:n. MI. t.nsll ,_.- '" $Ignlltur. f Colloctor Ditto Mo.fOlly/Yr.) . Tim 0 SPLIT SPECIMEN COLLECTION o YES eCNO -STEP 4: TO BE INITIATED BY THE COLLECTOR AND COMPLETED AS NECESSARY THEREAFTER UfJE SPECIME~ RELEASi;P BY SPECIMEN RECEIVi;!;l BY PURPOSE OF CHANGE MO. D Y YR r , DONOR k ! 'd\\(tr 1\ '\'~-<_L._ ,\l. * Collecto( -7~'-- . A ""- - Ie ,- PROVIDE SPECIMEN It, , I SIGNATUR ,",,,k.n ~ 1'(..,' \. .,,;;}-~ ,\ . ." ~4 " . f 1;? '(y , , \,,") l "'" \:"1'''<< ~[9.'!.aj~l!l.J:j~U.::;L_- _~=__.:.._I~:::t.r-::!.=>~=--"___ FOR TESTING : ')\ PRINT \ ",....,. . ...-I' .\. " , ' ~), ." ,- Name '7:23>"",' A. "'7;':1'11 n <1 .f , , C?lIectorl'~ \4 ._~T':.j" ~. ' , , ;:-4Y.2f /' .5}{!d J~' , , Signature In 1.--. II.' ~QlJ.aJ.l!!~~l...1LJ..i..i'l,._____ __..:.'__k.~Cl;~~' N~;e ~.~-47Jt:;---;tl.~~;~--,;t;u.---------- Vii .~" :i:::,'rUl. .r-~~ y . , ' , ;P~-f--' ..:g;;>'- Name l'''?f't." I-L . T"'.;7..1t"1 ~ ~~ I~ " , , -' , v .. oJ , I Signature Signature I , ------------------------------------- ----------------"-----"---------------- , , Name Name r , , r Signature Signa1u10 , I , r ------------------------------------- r--------------------------------------" r I Name Name , ! STEP 5: TO BE COMPLETED BY THE LABORATORY SEAL INTACT? 0 YES 0 NO - IF NO: 0 BOX 0 BAG 0 SPECIMEN * By signing this form, I acknowledgB the specimen{s) have been labeled and sealed in my presence. If collection was witnessed, thaf J release from liability 'any and all persons associated with witnessing of collection of my specimen, I also authorize AML to conduct testing for drugs and to report results to my employer or potential employer who require this testing. 1 certify that the speclmen{s) is my own and has not bean altered, - _...... n~""""'"""'A' .......... .......... .-...-_.......-_.......... _OM_. ~._- .___._."_.. JUN-29-2001 FRl 01:48 PM CHMBG HOSP LAB . .'. ' ~._.. . '" _.... . . ' FAX NO. 7172677127 P. 02 AMERICAN MEDICAL LABORATORIES, INC.@ P.O. Box 10841 . 14225 Newbrook Drive ChanUlly. VA 20153-0841 '. -' Telephone: (703) 802-6900 . (800) 336-3718" . "rJ.i\lf.~ WEhlDY ;r: Pag~ ~ Prom Ch~ntilly CDi..;._ECTED: 06/14/02121121 i RECr:~I VEl): :lI6/1.5/i'?0lZl1 REPORTED, 1216/15/201211 ~12l01i 0/ 16151/ 0/91210287 PATIf.:r'J"[' ID: lE,j,EA5",0l, S:rTE GODE, NOT' PRCVIDEiJ Please note. MD PENN lEGAL 3S12b~B&/e (ADULT ASSuMED) FOR T492:P 1"'151 CHFlrM,lERSBURG HOSPHAL.-D&A,., n:::8T REASON:Q-courn ORDE:R COLL. SHE : CHA/>18EI~81..EY, PA SERVICES ..,,-----..,-.----,....TE:STS-.-.-...."---..----flESLlL l"S-FLAl.:;--RE';-.. RANGE -.......---UN I 1'8 l8i21S/Chant illy 1edicolegal ToxicpLogy i'lEIH.COLE:G~\L CH?1 r N-OF -CUSTODY REi='ORT.. Chain of Cu~t:ody document received and ~pecimen seal in.i:;e~t" ;:~'2812ICh"nt i 11 Y 3erum Drug Rbuse 8cr~en Ir!(":!R r JUANA dete~tion iil~it 20 AMPI-j,:;:T;";'; r NES detection lilllit CiJCi:\rI\j~ i'1ETRBOLl TE detection lilfli-c OPIATES de"cection li:nit PCP (PrlENCYCLJ:DlNt=':) detection linit PI, ~s.se not e ~ NOM:: DEI !::ClED ng/mL as carboxy-THC NONE DETECTED 100 ng/mL as amphetamine NON'" DETEL:rE0 50 ng/rnL as benzoylecgafline NONE: DETECTED ~0 ng/mL a5 morphine NONE: DETEC;TED llZt nR/mL *** FINFlL RE:PORT *** rp 30~/8]-[S S2?} i'~a:thC\n SherlJl~).n, 1"1.. iJ~ Dir.ctor of Laboratories Age and lex dependent referenco mngel al'& p~nted when available if age and sex are designated. Otherwlse. aduft values are given. 167U74 R 1/'00 NATHAN SHERMAN, M.D. DIIIEC10RDP LAIlOItATORfl!$ Jj~~m: 1-:-, , ., ~ , 1'''''~' ',",'-1 JASON W. HOCKENBERRY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 01-2015 CIVIL TERM WENDY M. STINE, Defendant : CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Wendy M. Stine , Defendant, to proceed in forma pauperis: I, Joan Carey, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal service to the party. k,~ Attorney for Defendant MlDPENN LEGAL SERVICES 8 Irvine Row Carlisle, P A 17013 !ij;"", ~~ , ~., - y, ., '",' ~, ;1 ~:'~, ~ I ~ . J ,0 - ~ t I~ ,~I'!!'.?T"R)i'id~ " 2 0 , ,,' -Tf s: " .-\ -ocr; :::.g rnm G=5 Z:r' :-,,---. zr" I ~:I;;~ ;---,-,~ ro"t--.,.. GJ )>.."(' ~6 -,.j --:;4'::,- p' ",,!':-Tl ~O :x: ~O - -0 - ern )>c: .. -- :z ,:.n ,'" :2 5J t.J '< _r ~ "IlIllIT~JMIl~,~, "Jl!'i,n~I>;.fr\"'~f;";ii'\!!!~:%'f<',ij;>;''''''!'''e,~'1i'~.,,'t~~~~$1i~jj\'%",W!"i~!'.i''~-I\l~~Ji:'~ J JASON W. HOCKENBERRY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA V. WENDY M. STINE, Defendant : NO. 2001-2015 CIVIL TERM : CIVIL ACTION - LAW AMENDED ORDER OF COURT AND NOW, this 16-t~ day of AUGUST, 2001, the Order of Court dated August 7, 2001, is amended with respect to paragraph 4, so that paragraph 4 reads as follows: 4. Notwithstanding the foregoing, Defendant shall have custody of the child from 2:00 p.m. on Christmas Day until 7:00 p.m. on December 30. In all other respects,' the order of court dated August 7, 2001, shall remain as originally entered. By the Court, Galen R. Waltz, Esquire 28 South Pitt Street Carlisle, Pa. 17013 For the Plaintiff L~ l oM Joan Carey, Esquire Mid-Penn Legal Services, Inc. 8 Irvine Row Carlisle, Pa. 17013 For the Defendant :sld W,~f 'T",'. . e"," , -'I~ "1 ~ " .."." - ~"" VINV/llASNN3d A.lNn08 (1',:\{1\':F18\f~nQ 21 :\ Lid Ol81W 10 i J(1 ... :t~... " ,~ =__7,_ 'r._ , .,~"~Ifi?'~~~ " ~, ,~~,_._~"~~ "IT" ~"="_~~.'" "~_' ~"o<<' -'W"~I~"'~"r~""'=~~'-~'>--"='" '><__,~'_'" 'w__ ". ''":''-',r' Xi ,,'''~_~'' ~.';-;p,~l~"'if'['.w"f'lmtf,'<#ot<Jc:.R!<*~I~~~~."~I"'h_". _ '. __1; - ,4 JASON W. HOCKE!'ll3ERRY, PlaintIff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. WENDY M, STINE, Defendant : NO. 2001-2015 CIVIL TERM : CIVIL ACTION - LAW IN RE: PLAINTIFF'S COMPLAINT FOR CUSTODY BEFORE OLER, J. ORDER OF COURT AND NOW, this '7 ~ day of AUGUST, 2001, upon consideration of Plaintiffs complaint for custody with respect to the parties' child, Bryson Wayne Hockenberry (d.o.b. April 10, 2000) (hereafter, the child), and following a hearing held on August 6, 2001, it is ordered and directed as follows: 1, Legal custody of the child shall be shared by the parties. 2. Primary physical custody of the child shall be in Defendant, the mother. 3. Temporary or partial physical custody of the child shall be in Plaintiff, the father, at the following times: a, On alternating weekends, from Friday at 7:00 p.m, until Sunday at 7:00p.m. b. On Thanksgiving Day from 2:00 p,m, until the following Sunday at 7:00 p.m. c. During June, July and August, for the first full week of each month commencing on Sunday at 7:00 p.m. until the following Sunday at FfI r "~oy ~~ ."V'l .-' ~, ~..., ,"' 't .<~~ . '- .-' 7:00 p.m. (These week-long periods shall be in addition to Defendant's periods of custody on alternating weekends.) Provided, that for the month of August, 2001, Plaintiffs one-week period shall be from August 19, 2001, until August 26, 2001. 4, Notwithstanding the foregoing, Defendant shall have custody of the child on Christmas Day until 2:00 p.m., and Plaintiff shall have custody of the child from 2:00 p,m. on Christmas Day until 7:00 p.m, on January 30, 2001. 5. Transportation for exchanges of custody shall be the responsibility of the party receiving custody. 6. Nothing herein is intended to preclude the parties from deviating from the terms of this order by mutual agreement. 7. All prior custody orders are vacated. By the Court, Galen R. Waltz, Esquire 28 South Pitt Street Carlisle, Pa, 17013 For the Plaintiff Joan Carey, Esquire Mid-Penn Legal Services, Inc. 8 Irvine Row Carlisle, Pa. 17013 For the Defendant :sld )1~~ , ;'.< -^ ' ~" 1 r,., JASON W. HOCKENBERRY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW WENDY M. STINE, Defendant NO. 01-2015 CIVIL TERM IN RE: PLAINTIFF'S COMPLAINT FOR CUSTODY BEFORE OLER. J. SECOND AMENDED ORDER OF COURT AND NOW, this 13th day of August, 2001, the Order of Court dated August 7, 2001, is amended with respect to paragraph 4 to read as follows: 4. Notwithstanding the foregoing, Defendant shall have custody of the child on Christmas Day until 2:00 p.m., and Plaintiff shall have custody of the child from 2:00 p.m. on Christmas Day until 7:00 p.m. on December 30. In all other respects, the order of court dated August 7, 200 I, shall remain as originally entered and the amended order of court dated August 10, 2001, shall be null and void. BY THE COURT, GalenR. Waltz, Esq. 28 South Pitt Street Carlisle, PA 17013 Attorney for Plaintiff 'v'INVA1A8NN=id I "'no'1 n' ""'-H;-~I 1\.U'l U \,.i:\ '.' !r, ,.::'t!~'vn:J 8'1:8 j,'d C'l '1:"1" 1'-', " '" i ....1 iF u "^4I("" ,", ", ' AOVJ.v'!\' H-I!,' ,c' ";0 3~~:i:j;S~;~_~:~:,-.4.:!,; ~; :;:,""".~,~_" '___'>',,' -,,-_^ _~:,,' ,,,,,,,-,, ,",-,~, -.' -~" ., ,"I 'V" '""'_ ,"."~..,, ,.T, "'",' ",'. . ' 04 Joan Carey, Esq. Mid-Penn Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 Attorney for Defendant :rc :,''\;;'~'',<, '''','"''< '1- . ~" ~~~ " '" - =~. - ~ ~ 8_/'1.0/ q-. ~, -