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HomeMy WebLinkAbout01-2844 FX v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA, 9TH ruDICIAL DISTRICT RANDI A. LONG, Plaintiff CLARENCE S. LONG, ilr, Defendant No, 01-2844 CIVIL ACTION - CUSTODY ORDER AND NOW, this of , 2002, upon consideratiqn of the attached Petition For Modification of Custody Order, it is hereby directed that the Parties and their respective counsel appear before , the conciliator, at on the day of , 200---, at ,m. for a Pre-Hearing Custody Conference. At ~uch 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 intp a temporary order. All children age five (5) or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporllJl)' or permanent order. BY THE COURT: Custody Conciliator The Cumberland County Court of Common Pleas for the 9th Judicial District 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 haviiIg business before the Court, please contact ourdffice, All arrangements must be made at least 72 hours prior to any hearing or business before the Court, You must attend the scheduled conference or hearing, YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHEREYOU CAN GET LEGAL HELP. Cumberland County Bar Associ~tion 2 Liberty Avenue ' Carlisle, PA 17013 Telephone (717) 249-3166 .-;;~, '-~ ! " '.' -1 , - i RANDI A. LONG, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA. NO. Ol-~ty e'o,(;-~ CIVIL ACTION - LAW IN DIVORCE AND CUSTODY vs. CLARENCE S. LONG, III, 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 conciliator, at 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. Either party may bring the child who is subject of this custody action age 5 or older to the conference, but the child's/children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. , the on FOR THE COURT, By: Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 . v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL VANIA, 9TH JUDICIAL DISTRICT RANDI A LONG, Plaintiff CLARENCE S, LONG, III, Defendant No, 01-2844 CIVIL ACTION - CUSTqDY NOTICE YOU HAVE BEEN SUED IN COURT, If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you, You are warned that if you fail to do so the case may proceed without you and a judgement may be entered against you by the Court without further noti,ee for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. 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 OFFICES SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, DAUPHIN COUNTY LAWYER REFERAL SERVJCE 213 NORTH FRONT STREET HARRISBURG, PA 17101 (717) 232-7536 CENTRAL PENNSYL VANIA LEGAL SERVICES 213A NORTH FRONT STREET HARRISBURG, PA 17101 1-800-932-0356 ';~. ! " 1-' " ~ -. ~ - , v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA, 9TH JUDICIAL DISTRICT RANDI A LONG, Plaintiff CLARENCE S, LONG, III, Defendant No. 01-2844 CIVIL ACTION - CUSTODY PETITION FOR MODIFICATION OF CUSTODY ORDER . NOW COMES, the Defendant, CLARENCE S. LONG, ill, pursuant to 1915,1 et seq, of the Pennsylvania Rules of Civil Procedure to petition this Honorable Court for a change in the custody order entered in the above-captioned action. Defendant requ.ests that this Honorable Court grant Defendant primary physical custody and shared legal custody of the minor children, Alexandria p, Long and Catelyn S. Long, In support of this petition, Defendant assert the following: 1. Defendant, CLARENCE S. LONG, III, (hereinafter Father) is an adult individual residing at 7081 Spring Road, Shermans Dale, Peny County, Pennsylvania, 2, Plaintiff, RANDI A LONG, (hereinafter Mother) is an adult individual residing at 67 Country View Estate, Upper Frankford Township, Cumberland County, Pennsylvania, 3, The subject children of this action, ALEXANDRIA p, LONG was born February 10,1992 and CATELYN S. LONG was born February 22, 2000, 4, A custody conciliation conference was held on May 17, 2001 in Attorney Dawn Sunday's Office, " 5, A custody order was executed by the Honorable 1. Wesley Oler, Jr. on JJJIle 21,2001. A follow up conference was held in Attorney Sunday's office on October 23, 2001 and a custody order was executed by the Honorablll J, Wesley Oler, Jr. on November 2, 2001. A true and correct copy of the '"c""",,"~ ~ _ ~ '- . I' - T.."l . ,I -"- " :;:'it~ '.' ~,',' Custody Conciliation Summary Report and Custody Order of November 2, 2001 are attached hereto and Marked Exhibit "A", 6. Since the entry of the within mentioned custody order, there has been a significant change of circumstances that directly and substantially impacts the parties' respective custody rights, These changes in circumstances are as fol}pws: a.) Defendant believes that the minor children are not being properly cared for. b) The minor children are not being bathed properly or of1;en and their appearance is unkempt. c) The minor child, Alexandria, has two incidents of lice infestation, d) Defendant believes that the minor children are not being fed properly and healthy, ' , e) Alexandria's grades in school have plummeted and are )low very poor. f) The teacher and counselor at the minor child's school have expressed concern to the Defendant over the minor child's appearance, ability to perform in class and behavior. g) Defendant believes that the minor children do not have proper supervision or discipline, 7, The minor children are not presently being raised in a safe and stable environment. 8, Father is better able to provide a safe, stable and loving environment in which to raise the child. ' 9. Defendant seeks primary physical custody and shared legal custody of the minor children, 10, Defendant prays that this Honorable Court grant the relief requested because said relief will serve the best interest of the children, ' WHEREFORE, Defendant respectfully requests that this Honorable Court fant him primary physical custody and shared legal custody of the minor children, ALEXANDRIA p, LONG and CATEL YN S. LONG, " ,~ , , " I , ~ !'~r , - - " ~ 1 " Respectfully submitted: "., " - ,"'1 Barbara L. Wevodau, Esqujre Supreme Court ID, No. 85673 P,O, Box 264 NewBloomfield,PA 17068 (717) 582-8883 - " ':" I v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA, 9TH JUDICIAL DISTRICT RANDI A. LONG, Plaintiff CLARENCE S. LONG, ill, Defendant No, 01-2844 CIVIL ACTION - CUSTODY VERIFICATION I verify that the statements made in the attached PETITION FOR MODIFICATION OF CUSTODY ORDER are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa,C.S, 4904 relating to unsworn falsification to authorities. DATE: ,~~ ~ ( Clarence S, Long, ill '''~.~ ,>> f"','--i I ~ '- '" - ""I"""" -."", "-~ v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTy PENNSYLVANIA, 9TH JUDICIAL DISlRICT RANDI A. LONG, Plaintiff CLARENCE S, LONG, m, Defendant No. 01-2844 CIVIL ACTION - CUSTODY CERTIFICATEO.F SERVICE I, Barbara L. Wevodau, Esquire, hereby certifY that, on this date, a true and correct copy of the foregoing Petition for Modification of Custody was served upon Jane Alexander, Esquire, attorney for the Plaintiff, RANDI A. LONG, by mailing a certified true copy via first class mail from the New Bloomfield Post Office, New Bloomfield, Pennsylvania to the following address: Jane M, Alexander, ,Esq, 148 S. Baltimore Street P,O, Box 421 Dillsburg, PA 17019-0421 ttorney for Defendant Barbara L W evodau,Esq, Supreme Court ID# 85,673 P,O. Box 264 New Bloomfield, P A 17p68 (717) 582-8883 "'~^.,< J'.' ., ~~ ~ 'I r " 1 ' , -----T:' :- '. " AMERICANS WITH DISABILITIES ACT OF 1990 The Cumberland County Court of Common Pleas is required by law to comply with the Americans with Disabilities Act of 1990, For information about acceJSible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact my 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, '~;~~f1J!il, I' , ., f'" - ;"$ _ - rrr~, ~~o-., ~ ~ ~ "",~.,,~ '~,'.~-,.~,,~._,. ,w,;,,,..~, "~'_.'~" IIUI ~ T1i' " " -kl (') C' (:J c: j ];J & ;;" ~"-r: 7- -cr;' It !Tij -;.' - "" 1 , C'~ Ce- o. -< ~::::: ........ -- C> ~. JU 0 ~ ,"':'> -- ..J -V '0 (....) ~ p:- i- ""I ...,-.-J"""".,_~., ,",*;Il<I~J1<NIiEi'l~flIW'<"!'l~W'~~t'm:5Q1ff.trfi,-'r;'"fJi'~"""c"';-<;""F--""""""'''1;',j\" '';'-'''; """"~~Fr~!jj'1r~~!a;'~~'1ifC"JT4~~"jf~'!'-'F'i~'r~lt~f~''"'~lltW~)'C Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA. RANDI A. LONG, vs. NO. CLARENCE S. LONG, III, Defendant CML ACTION - LAW IN DIVORCE AND CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A Judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the office of the Prothonotary at the Cumberland County Court House, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA. RANDl A. LONG, vs. NO. CLARENCE S. LONG, III, Defendant CIVIL ACTION - LAW IN DIVORCE AND CUSTODY A VISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion con prontitud. Se Ie avisa que si no se defiende, el caso puede proceder sin usted y decreto de divorcio 0 anulamiento puede ser emitido en su contra por la Corte. Una decision puede tambien ser emitida en su contra por cualquier otra queja 0 compensacion rec1amados por el demandant. Usted puede perder dinero, 0 propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades 0 rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotry, en la Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL HONORARlOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DlVORCIO 0 ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDlATO. SI NO TIENE 0 NO PUEDE PAGAR UN ABOGADO, VAYA 0 LLAME A LA OFICINA INDlCADA ABAJO PARA A VERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 , ~ ~," ce_ ,- II I RAND! A. LONG, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA, NO. 0 I.~, 1'1./,/ ~ J~ Plaintiff vs. CLARENCE S. LONG, III, Defendant CIVIL ACTION - LAW IN DIVORCE AND CUSTODY COMPLAINT UNDER SECTION 3301 (C) OF THE DIVORCE CODE COUNT I ANDNOW,this /flAYOf the Plaintiff, Randi A. Long, by her attorney, Jane ,2001, comes Alexander, Esquire, and files this Complaint upon a cause of action of which the following is a statement. 1. Plaintiff is Randi A. Long, 32 years of age, who currently resides at 67 Country View Estate, Upper Frankford Township, Cumberland County, Newville, Pennsylvania, 17241. 2. Defendant is Clarence S. Long, III, 36 years of age, who currently resides at 7081 Spring Road, P. O. Box 61, Shermans Dale, Pennsylvania, 17090. 3. Plaintiff and Defendant have both resided in the Commonwealth of Pennsylvania for at least six (6) months prior to the filing ,of the Complaint in Divorce. 4. The Plaintiff and Defendant were married on November 28, 1992 in Carlisle, Pennsylvania. 5. There were two (2) children born between the parties, Alexandrea P. Long, age 9 years, born February 10, 1992 prior to marriage and Catelyn S. Long, age 1 year, born February 22,2000 during the marriage. 6. There were no prior actions in divorce or annulment commenced by the parties. Il 7. The parties have not entered into a written agreement as to alimony, counsel fees, cost and property division. 8. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. While the parties were domiciled within the Commonwealth of Pennsylvania, and through no fault of Plaintiff, the innocent and injured spouse, the Defendant, in violation of the marriage vows and the laws of the Commonwealth, has offered such indignities to the person of the Plaintiff as to render her condition intolerable and life burdensome. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. COUNT n 10. The allegations of Paragraph one (1) through nine (9) are incorporated herein by reference and made a part hereof. 11. The marriage is irretrievably broken. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. COUNT HI 12. The allegations of Paragraph one (1) through nine (9) and Paragraphs ten (10) and eleven (11) are incorporated herein by reference and made a part hereof. 7',_~~,,;. 1- - ~ . ~. - 11 - "'<':~.1,,;."",," M' :; 'I 13. Plaintiff and Defendant have acquiredproperty, both real and personal during their marriage. 14. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property of whatsoever kind and wheresoever situate and for such further relief as the Court may deem equitable and just. COUNTY IV COMPLAINT FOR CUSTODY 15. The Plaintiff seeks primary physical and joint legal custody of the following children, Alexandrea P. Long, age 9 years, born February 10, 1992 and Catelyn S. Long, age 1 year, born February 22,2000. 16. The first child, Alexandrea P. Long, was born between the parties prior to marriage and the second child, Catelyn S. Long, was born between the parties during this marriage. 17. The children are presently in the custody of the Plaintiff. 18. The children have resided with the Plaintiff and Defendant from 1995 to 1997 at 25 W. Big Spring Avenue, Apartment 1, Newville, PA. From 1997 to 1999 Plaintiff, Defendant and the children lived at 820 York Road, Carlisle, PA 17013. From April 16, 1999 to April 16, 2001 Plaintiff, Defendant and the children lived at 67 Country View Estate, Newville, PA 17241. From April 16, 2001 to date Plaintiff and both children lived at 67 Country View Estate, Newville, PA 17241. ~ 19. The relationship of the Plaintiff to the children is that of natural mother. 20. The relationship of the Defendant to the children is that of natural father. 21. The Plaintiff has not participated as a party or as a witness, or in any other capacity, in other litigation concerning the custody of these children in this or any other Court. 22. The Plaintiff has no information of a custody proceeding concerning the children pending in any other court within this Commonwealth. 23. The Plaintiff knows of no other persons, not a party to these proceedings, who has visitation or custody rights with respect to the children. 24. The best interest and permanent welfare of the children will be served by 11 granting the Plaintiff primary physical custody and joint legal custody because with partial visitation to Defendant on the second weekend of each moth. The Plaintiff is able to provide the children with a good environment and proper care of the children and has, during the life of the children, been the primary care giver particularly since the Defendant moved out. WHEREFORE, the Plaintiff requests your Honorable Court to grant her primary physical custody of the subject children with reasonable rights of visitation to the Defendant and that the Defendant shall not use alcoholic beverages when he has custody of the children and he shall not remove the children from the jurisdiction of the Pennsylvania Courts. Respectfully Submitted, 11 Verification I verify that the statements made in this Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. I ,I ,~(~ d7- OJ .d~' t2 ~I- Date: COMMONWEALTH OF PENNSYLVANIA S.S COUNTY OF YORK Before me, the undersigned officer, a Notary Public, in and for the said Commonwealth and County, Personally appeared Randi A. Long who, being affirmed according to law, deposes and says that the facts and matters set forth in the foregoing Complaint are true and correct to the best of her knowledge, information and belief. J:u~' tl ~ diA.Long ~ Sworn to and S;;'~~d before me this ,,2 day of L. , 2001. /L: NotalIaI Seal Halvard E. Alexander, NO!IIJ PuIIIIc Dllsburg Bore, York CoiinIr My ComrnIssfon Expires Apr. 21; lOR Member, Pennsylvania AssociatlonolNollllls RANDI A, LONG PLAINTIFF V, CLARENCE S. LONG, III DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-2844 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, May 17, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawu S. Sunday, Esq. , the conciliator, at 39 West Maiu Street, Mechauicsburg, PA 17055 on Tuesday, Juue 12, 2001 at 11:30 a.m. for a Pre-Hearing Custody Conference, At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court herehy directs the parties to furnish auy 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 Dawn S. Sunday. Esq. /it? Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~~. l' ._" ..~ I" ~ ~ , " iL~>i~'i,!I'~1l!,"i;g'li'&iJl-<lli%o ' 'eo' ' ;;i;<",s..<.4!;O:'c,!i,"ilii'i\,!t<oI~\i,~'<ll!;~>i.i",,,,N.'Mi+Hj'.'<':h"'l'::'.~i,+;"dj:ili::,;;",ni!&;;'ki1.~,;t4~1!l.\~~!i<!i>!i!;!;ri~~i~~ j """W'_~'~'~ ililtliID or: - D:::i':"'iC[ :c~,!' (':''',!CnARY "'I' P'V 18 -. , iJ rln 1 ,.-ii ,: ')[,. ,J. C; '''I'''''' " , uIVi"'c,' "C<'''L.' : ''{'', II"ITY . ~., l...{.,j" \,;'0' '4 PENi'~SYl)/,!lNi;\ S/tf'~1 tV. ~ M~ -t 4 ~ J/f-cv ~ ~ ~' ~. J'/ftJl ~ ~ -t;. ~~1t I ~ .,_ ~ ,~, ~~~~",,"'~ ,,,,c~,~,~~,,,,,,,,,V",,~". _~," , ~ ,.. '.' ''"'r "I., . > ' ,,... ",. ,~~, ,~ ,~ ", ._.C" ""_,~,~~,. :, " .1 i' !I i'l 'ri 11 ,I 1 il I 1 ;j I il :i i 11 I II 'i 1 I I ro . Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA RANDI A. LONG, VS. NO. 01-2844 CIVIL TERM CLARENCE S. LONG, III, Defendant CIVIL ACTION - LAW IN DIVORCE AND CUSTODY AFFJDA VIT OF SERVICE AND NOW, this ~~; ,2001 personally appeared Jane M. Alexander, Esquire who swears accordin' 0 law, that a true and correct copy of a COMPLAINT IN DIVORCE AND CUSTODY was caused to be served by certified mail with return receipt requested upon the said, Clarence S. Long, III 7081 Spring Road P. O. Box 61 Shermans Dale, P A 17090 on May 17. 2001 by leaving the same at the Dillsburg Post Office with postage pre-paid thereon as evidenced by the mailing receipt and return receipt hereto attahced and made a part hereof. Sworn and subscribed before me this ;l..tt !'!f- day of , , 2001. Notarial Seal Halva[d E. Alexander, Notary Public Dlllsburg 8oro, York COU!\lY My CommissIon Expires Apr. 23, 2005 Member. PennsyiVaniaAssociallonOlNo!alles - - I IF" ~" ..' ",~,.....- -- i" q,,(!, II , I 'I I RANDI A. LONG, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA Plaintiff VS. NO. 01-2844 CIVIL TERM CLARENCE S. LONG, III, CIVIL ACTION - LAW IN DIVORCE AND CUSTODY Defendant s <0 CJ r-- SHERMAHS DALE fA 17090 ru CJ lr CJ vpostage $ $0.55 $1.90 V Certified Fee r'- j:....' Return Receipt Fee M (Endorsement Required) ~ V1'flestricted Delivery Fee Endorsement Required) CJ CI Total Postage & Fees s rt1 R~rent's Name (Please Print Clearly) (to be completed b tr -Streer~~~r;~PO-~Oi-N~~_L_~---_--.'_-----n---._--------------------- ~ 'c;;Jg'~,!Z'P;;.fri.t'5---g.'?~---,.\',.C!.~--~.~.~---~L--.---.--....... r-- ~ ._~~...........~_. ~-- ':i ,SENDE'R:" !! '. Complete items 1 and/or 2 for additional services en . Complete items 3, 4a, and 4b.' . = . Print your name and address on the reverse of'this form so that we can return this a.. card to you. ~ . Attac~ this form to the front of the mall piece, or on the back if spac, e does not ~ permit . . Write "Retum"Ref?8ipt.Requested" on the mailpiece below the article number. . Th~ Return Receipt will show to whom the article was delivered, and the date dell....ered. 3, Article Addressed to: . I also wish" t~ recei~e the following services (for an extra fee): ill 1.~Addressee'sAddress .~ 2. JI't Restticl~d Delivery ~ Consult postmaster for fee. ._ 4a. Article Number 70qt} 3400 001'1 0<1'02 708'4-~. c 4b. Service Type \ 3 o Registered ,m Certilie'o ~ o Express Mall 0 Insurejl g> o Return Receipt for Merchandise 0 COD ''f ~ 7. Date of Deliv ry .E r 11 01 " g, 8. Addressee's Address (Only if requested .::t. and fee is paid) fij J:;; ... ," '" ~ c o 'C I" C.ltlrl-VlU S. LoVlj) III 8 ' 7015 \ 5pr\ "j ~oAd t ?O. E>O)( &\ >'Bhe.rt'Y1aVlS uale, ?A ~ " o >- !!2 PS Form 3811 , D~Gemb Domestic Return Receipt 4 102595-98-B-0229 'i'4';;1IlJfy" _",' . . . , RAND! A. LONG, Plaintiff : IN THE roURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 01-2844 CIVIL TERM : CLARENCE S. LONG, III, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF CXXIRT AND lIDl, this ? l..d- day of J tJ1J>c.- consideration of the at~Custody Conc1liation and directed as follows: , 2001, upon Report, it is ordered 1. The Mother, Randi A. Long, and the Father, Clarence S. Long, III, shall have shared legal custody of Alexandria P. Long, born February 10, 1992, and catelyn S. Long, born February 22, 2000. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 2. The Mother shall have primary physical custody of the Children. 3. The Mother shall take the Children to the Father's residence on Sunday, June 17, 2001 at 3:30 p.m. to familiarize the Children with the other children and individuals residing in the Father's residence and to afford the Mother the opportunity to see the environment in which the Children will be staying during future periods of custody with the Father. 4. The Father shall have partial physical custody of the Children at williams Grove Amusement Park on Saturday, June 23, 2001 beginning at 12:00 noon, when the parties shall meet at the back entrance to the park. Thereafter, the Father shall have custody of the Children from 1:00 p.m. until 5:00 p.m. every weekend alternating between Sundays and Saturdays. 5. During periods of custody with the Children, the Father shall refrain frOIl1 taking the Children to any tatoo parlor or bar. Further, during periods of custody, the Father shall refrain from consuming alcohol or driving without a valid drivers license. The Father shall ensure that third parties having contact with the Children comply with this provision. 6. The Father shall provide transportation for exchanges of custody on Sundays and the Mother shall provide transportation for exchanges of custody on saturdays. 7. The Mother shall promptly notify the Father when a counselor has been selected for Alexandria at the Helen Stevens Center to enable the y, ~, .~ .' 'I" . i ~';~..~, . Father to contact the counselor and participate in the counseling process if deemed appropriate by the counselor. 8. The Father shall be entitled to have liberal telephone contact with the Children. 9. In the event the parties are unable to reach an agreement as to holiday custody arrangements and expansion of partial custody to overnight periods, counsel for either party may contact the Conciliator by November I, 2001 to schedule an additional Custody Conciliation Conference. 10. This order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this order by mutual consent. In the absence of mutual consent, the terms of this order shall control. BY THE CDURT, ti( J. ) cc: Jane M. Alexander, Esquire - Counsel for Mother Daniel McGuire, Esquire - Counsel for Father _1' , "'.' .~~ f ,~ .~.- - , ~,~ to. '.<," T'" ~ . RANOI A. LONG, plaintiff : IN THE <XlURT OF <XlMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 01-2844 CIVIL TERM . . CLARENCE S. LONG, III, Defendant : CIVIL ACTION - LAW : IN CUSTODY CUSTODY CCliCILIATICN SUMMARY REPCRr IN ACCCIlDANCE WITH CUMBERLAND (J()(JN'fi' RULE OF CIVIL pPfY'RlIJRE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Olildren who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN COSTODY OF Alexandria P. Long Catelyn S. Long February 10, 1992 February 22, 2000 Mother Mother 2. A Conciliation Conference was held on June 12, 2001, with the following individuals in attendance: The Mother, Randi A. Long, with her counsel, Jane M. Alexander, Esquire, and the Father, Clarence S. Long, III, with his counsel, Daniel McGuire, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date ~ I '-I . d-oo I , ~~ Dawn S. SUnday, Esquire Custody Conciliator '.;;,~ " "_ .. '.,T ~: ,~. !'", 1'.+ ,<,..0"'"--. I, - "I',"'.I',~, - ,..- ,., ~ RANDI A. LONG, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 01-2844 CIVIL ACTION LAW CLARENCE S. LONG, III, Defendant IN CUSTODY ORDER OF COURT AND NOW, this '2 '1 J. day of -IU '" \.I e ~ Lv , 2001, consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: upon 1. The prior Order of this Court dated June 21, 2001 is vacated and replaced with this Order. 2. The Mother, Randi A. Long, and the Father, Clarence S. Long, III, shall have shared legal custody of Alexandria P. Long, born February 10,1992, and Catelyn S. Long, born February 22,2000. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of this paragraph, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 3. The Mother shall have primary physical custody of the Children. 4. The Father shall have partial physical custody of the Children on alternating weekends from Friday at 7:00 p.m. (when the Father shall pick up the Children at dance class), through Sunday at 6:00 p.m., beginning October 26,2001. 5. The parties shall share or alternate having custody of the Children on holidays as follows: A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall run from 9:00 a.m. until 8:30 p.m. on Christmas Eve, and Segment B, which shall run from 8:30 p.m. on Christmas Eve through 8:30 p.m. on Christmas Day. In odd numbered years, the Mother shall have custody during Segment A and the Father shall have custody during Segment B. In even numbered years, the Father shall have custody during Segment A and the Mother shall have custody during Segment B. B. THANKSGIVING: The Thanksgiving holiday shall be divided into Segment A, which shall run from 9:00 a.m. until 8:30 p.m. on Thanksgiving Day and Segment B, which shall run from Thanksgiving Day at 8:30 p.m. through the Friday following Thanksgiving at 8:30 p.m. In odd numbered years, the Mother shall have custody during Segment A and the \-'" ", ,- , "., ,t<'_ _- " "f~' ~-,' -" "' I" ~, ~'" "., ,'> ,t..' ~ 1 .."., ,~ r,'lI!."~l:,,,p.!!1I~~~, , , liINVlr!ASNN3d tUNnw (!"!\'l\FJi]:"lnO I (I ,r 1,1'" ^, t ..w.'DiiI7 Ij-i'~UNiO AbV.LU!'~!:~,i . ;J __..' 1; .~"'~-'"~, ~~ =!'_'~~~~"!UPP1~(~f~8'.~',~~Ji!~,!['~ic;.:),V"""K)W-"''':'''~J,,:",'!'7fli!r-;,,",~j!lf1I1f'~~;!fl'f-!':<1~~"~P;Jt.~fil'i~~@l!~!i'" I Father shall have custody during Segment B. In even numbered years, the Father shall have custody during Segment A and the Mother shall have custody during Segment B. C. EASTER: The party who has custody of the Children under the regular custody schedule on Easter shall have custody on the holiday. D. MEMORIAL DAYILABOR DAY: The Father shall have custody of the Children every year for the Memorial Day holiday from Sunday at 8:00 p.m. through Memorial Day at 7:00 p.m. The Mother shall have custody of the Children every year for the Labor Day holiday from Sunday evening at 8:00 p.m. through Labor Day at 7:00 p.m. E. INDEPENDENCE DAY: The Independence holiday shall run from 9:00 a.m. on July 4th through 9:00 a.m. on July 5th. The Mother shall have custody over the holiday in even numbered years and the Father shall have custody in odd numbered years. F. MOTHER'S DAYfFATHER'S DAY: The Mother shall have custody of the Children every year on Mother's Day from 9:00 a.m. until 6:00 p.m. and the Father shall have custody of the Children every year on Father's Day from 9:00 a.m. until 6:00 p.m. G. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 6. The Father shall be entitled to have custody of the Children every year during the summer school break for two non-consecutive weeks upon providing at least 30 days advance notice to the Mother. In the event either party intends to take the Children on vacation, that party shall provide advance notice to the other party of the address and telephone number where the Children can be contacted. 7. Unless otherwise agreed between the parties, the Father shall provide all transportation for exchanges of custody to and from the Mother's residence, with the exception of the exchanges of custody on Fridays, when the Father shall pick up the Children at dance class. 8, The Father shall ensure that the Mother has a current work telephone number and home telephone number where the Father can be contacted in the event of an emergency or to discuss issues relating to the Children. 9. The parties shall communicate directly with each other concerning issues affecting the Children without the involvement of or interference by third parties. 10. Neither party shall consume alcohol to the point of intoxication during his or her periods of custody. Each party shall ensure that third parties having contact with the Children comply with this provision during his or her periods of custody. II. Neither party shall take the Children to a tatoo parlor for extended periods of time during his or her periods of custody. 'L.. " I '"~. i' ,~ j ,~ - ~_._ =~J' 12. Neither party shall do or say anything which may estrange the Children from the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development of the Children's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Children comply with this provision. 13. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall controL BY THE COURT, J. cc: Jane M. Alexander, Esquire - Counsel for Mother Daniel McGuire, Esquire - Counsel for Father ~ ~ /I_~_o/ ~. ^~~ - .,,,'.,, "',"'l.-'" . > '.~ I',", '" _' r; I',.j - RANDI A. LONG, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VB. 01-2844 CIVIL ACTION LAW CLARENCE S. LONG, III, Defendant IN CUSTODY PRIOR JUDGE: J. Wesley 01er, Jr. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Alexandria E. Long Cate1yn S. Long February 10, 1992 February 22, 2000 Mother Mother 2. A Conciliation Conference was held on October 23,2001, with the following individuals in attendance: The Mother, Randi A. Long, with her counsel, Jane M. Alexander, Esquire, and the Father, Clarence S. Long, III, with his counsel, Daniel McGuire, Esquire. 3. The parties agreed to entry of an Order in the form as attached. r') oI-o~ J), f700 I (Q ., ~ J A.. '-'/0,_ Date I Dawn &~"daY-:&;i;;cJ' Custody Conciliator 'Wq~r " '" ,,,,,.","1"'-- -," r- ',"~' .. , , . , PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RANDI A. LONG v, 01-2844 CIVIL ACTION LAW CLARENCE S. LONG, III DEFENDANT 'IN CUSTODY ORDER OF COURT AND NOW, Thursday, May 16, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Suuday, Esq. . the conciliator, at 39 West Maiu Street, Mechauicsburl!, PA 17055 on Thursday, May 30,2002 at 10:00 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to 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 Dawn S. Sunday. Esq. Custody Conciliator \C" ".. The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 - ''''Wlir 1 . , '" ',,~.~_ '." I",' ~ , 1 . ~, - . \ h~__" ~ """. '~~,~ ~'="~ ~r -$ ~11." ~ r'c.?-~// ~ .b ~ ~7V ~IL, (V-~,5' h;p~~4Z~~ ~J'V eO'~/7 \1'Ji\'Ht"'11 ~I '~~vf\:/8NN3d " /'.,.n, )') '"'''~' " '\1J, I\..- ',. 'c ;':',,0',:' ,ii"",~DV\!n"'" '''_''e' VI h.) ':>1' .(' I' I ' (,;;J '(, ,'10 Q I ) ';1.,' 70 ,.J .;] il r.., n, 1/" I" 1\017 ,A\l)}'1.LC(/,-, :'.:.1 i ..10 '''I' 4 ~,,__ , ::!V.:J:;iO-GJ'I/::J - ^ l!''/I!!!f~~~~.,'''"~_,,o " ~'l',*~I~~I*~~!lI!!.Ilm!fl~"''''''.If'"t1f"%1;~;~.'i':''i -"""'.""~~":~'''-'''1',1'.''';''.''''';'.'''''~}'N:;;1;:i1'''Jc:C'fr:rl"f'f{,Th;F"if"f"'.",,;e;I;,."-"("'lli';~';'1'iq~~l,'~if~~ . RANDI A. LONG, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 01-2844 CIVIL ACTION LAW CLARENCE S. LONG, III Defendant IN CUSTODY ORDER OF COURT AND NOW, this 2...,J day of J lJ \'1 ' 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order ofthis Court dated November 2, 2001 shall continue in effect. 2. Based on representations and documentation presented by the Mother at the Conciliation Conference and the fact that the Father was not in attendance, the Father's Petition for Modification is dismissed, BY THE COURT, J cc: Barbara L. Wevodau, Esquire - Counsel for Father Jane M. Alexander, Esquire - Counsel for Mother ~ ~ 1.t3.0A.- c+-. "\,1~1Jt1 -- -I^" ~ < f' ,t.." " . P'!l!I! m'l" ~~ ~, .-4N~~~ >,. _.__'u_ ro ~, ~, _,~' ~~<~" "IJ~ '\ /""", , Ii'J '-,f '\ ) ! (">-,\1" r'~ , 11~'., .,. -./\01 .1\;-'('1 ,T\1.i\{ :/'{i r~l\r/"!.l~'q2/Vn:J hC:ffV~"/ "'; ? _ ~.', :'1"1' - . ,"fin vi.... ~ l..?,/I (;', . nt"'\"L.~JJ';" )... ,,'\ ,; :rr,';'i ;{:::.~":J',._:~ _.\);:.c'~)"OJ iJ.-J ...!n ~v ,.. ~. " .~v,,-,, '.'-.,0;0-;.. "'''''y,h--''''-'A,'-!''_',",,'~='' ~,",. ~,~~.~ LliiH"'"I.'i11 i -' '. 3l1;~~!~'3Wt~00'~!l-''l32''''''l{!;;'~~,~':'~'Y''~'!' """";':Y-~~"i""i2,'\~~~!emiWl'F)i)I,',;'l"F"'~'W;"~""~rqlJ("'""~W"!'1ID'~1 ... RANDI A. LONG, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 01-2844 CIVIL ACTION LAW CLARENCE S. LONG, III, Defendant IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RUlLE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Alexandrea P. Long Catelyn S. Long February 10,1992 February 22, 2000 Mother Mother 2. A Conciliation Conference was held on June 26, 2002, with the following individuals in attendance: The Mother, Randi A. Long, with her counsel, Jane M. Alexander, Esquire, and the Father's counsel, Barbara L. Wevodau, Esquire. The Father, Clarence S. Long, III, who filed this Petition for Modification, did not attend the Conference for reasons unknown to his counsel. 3. The issues raised by the Father in his Petition were discussed at the Conference and the Mother offered documentation from Alexandrea's school, physician and counselor in direct response to the Father' 5 allegations. 4. As the Father did not attend the Conference, no further Order addressing the custody arrangements is necessary at this time except to dismiss the Father's Petition for Modification, if deemed necessary by the Court. ----d-u Y/t' d-G. d-ood-- Date f!,~ Custody Conciliator ',' r ~ . " - ~ , " 1 ~ I "" ' ,~, ,. " ", 9 RANDI A. LONG, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA v. NO, 01-2844 CIVIL TERM CLARENCE S. LONG, III, Defendant IN CUSTODY PRAECIPE TO ENTER APPEARANCE AND NOW, Barbara L, Wevodau, Esquire, hereby enters her appearance for the Defendant in the above-captioned case. Date: ~ -() -o'B . n",,~ff_'t1.$I~ ,~~. T t, '.,,'r"~ , . ~ '~ ~...- ~ '"--"_'1 0 . ~, <,. ,".,<, "'~o ~ -" . " '"" ,,' """""-~ ,~-^ "~'T~~~ (} s;:: :s;~ ".._-~~..' . () co, ::) ('-'.:: .. _IT ""l","~~~,,~~.,Jr, ~.,~1~~i/J1!l~~''''r''%iW'''!i'-''Mc>I~W''''''~JlC'',t,;-;''-''''i''\''2T''--'''fC''i",~",,\)'fC)r;I?1i.~~1'''j,.tii'!I(!#;''''!li11l~,r-'''H~1!'AA~~~~1 -OJ-'-- nl!", :z-- ,,' , Cf) -- ,,..''> --~<.~ ~ ~~. ~ v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO. 01-2844 CIVIL TERM RANDI A. LONG, Plaintiff CLARENCE S, LONG, III, .. Defendant IN CUSTODY PRAECIPE TO ENTER APPEARANCE AND NOW, Barbara L. Wevodau, Esquire, hereby enters her appearance in the above-captioned case. ;2L~$J~ ,,'-*,,~m~= .., - f"' "~" - . ~" ~ -''''~- ",!.Jm: ~ , h ~ -~ I 'h "' "",' "" ~..,," ,'" , ""..'''''.. "'''''''1Ii1n:'rJ'll1i11lIl11rITiTI~t'f1r 'I'1rr n c:: ?' It' "" Jt/~~. '-- NtiC'.' ,:::> c.~, :?::tItt -r." ;:,:, I o --'1 :--,' --:<?J ~;:: ~~, .._;~~ "~~j::d ,~fr;? :'6' ", -:.,~ -~ .. ::- t.Y ::~) CO "'~~ o!ti~~~ _ JI'l;.~;;r,;:.'~!""lm'fflF~~~;I!!_!lJIlIII~ijf.<l1:~M~lr>?T0'"'2"F"'i;r;'~"""",~'i':";!".r'j"IPJ;!F'1l$-""'~iI".\~j"*,+,""'1"~~~~'~~~A,,.\j~~"IiI'''!l.ffi~~:, d_ ".'~~", , ,~. '" l RANDI A. LONG, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW CLARENCE S. LONG, III, Defendant NO. 01-2844 CIVIL TERM IN RE: PLAINTIFF'S EMERGENCY PETITION FOR SPECIAL RELIEF AND PETITION FOR CIVIL CONTEMPT ORDER OF COURT AND NOW, this 1st day of April, 2003, upon consideration of the attached letter from Barbara Wevodau, Esq., attorney for Defendant, the hearing previously scheduled for April 3, 2003, is rescheduled to Thursday, June 26, 2003, at 10:45 a. m., in Courtroom No.1, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, /' J. Jane M. Alexander, Esq. 148 S. Baltimore Street Dillsburg, PA 17019 Attorney for Plaintiff Babara Wevodau, Esq. 26 E. Main Street P.O. Box 459 New Bloomfield, P A 17068 Attorney for Defendant ~ ~, <1_01-03 0-, :rc - ,-,,,...,_..., .~.". - , "__,. .~o,~ --..", - !&-l I I I I I I '~- ,,-,.,~ '''''~.'~ ~ 'I ".. "~-"- "''''''''' "'" . ,~< "",-"C';- . '"'.~ "-'Iiil. I \I\N\4t\lf.s\\~~'~:~g, t I "lnf",1 ":1,."dnD ,\_Ll'" " .. ,... C. ,'/ 'ld bv -(., f\ ""'11"', ,- (jd~ (!~; lu\--il;'-_':',;',"'':'- "-'.' '\UVJ."-" ,-' _. ~"J"lll , 3~)U:.1U-U:J ],:J , :;\j 'liIiiiliiV'itY'Iiii' w t ..~.M! .l'-"'IlI:__n1!!Mi.~~fl1';Ji!;I!i~:>1,lW;;',1l-'f'f!'-0\'i''ii'"~l1'.'Ji~''flf,i~"l\Wih-~gllt~liIt~ @t4&if'$,"j{t,t,'ti-;%^!i!~;~:;.";;:e;%f.i1r;;1;1Mi:0-;rW;;;:L;j.)t;.10)~)"~~'~}~t~ .3 7175827597 ELIZABETH P QUIGLEY PAGE 02 BarbUl> Wevndau. Esquire Attorney At Law 26 E. Main She"t, pO 'Am< 459 New Bloomfield, P A 17068 Phone' (717)582-4335 Pax. (717)S82-7fi97 Sent Via Fax Only (717) 240-6462 Honorable J. Wesley Oler, Jr. Cumberland County Courthouse 1 Courthouse Square Carlisle, J:> A 1 70 13 Re: Long v. Long No. 01-2844 Dear Judge Olcr, March 31,2003 r received a tax copy of the PetLhon tor :special Relief/Contempt from Attorney Alexander. Unfortunately, I have three CU!.1ody conciliations scheduled in Perry County Court on April 3ro at 9:00 a.m. I have spoken with Attorney Alexander and explained the situation. Mr. Long has returned the children to Ms, Long. I ro:n requesting that the April yo hearing be rescheduled in lieu of the children being returned, My understanding is that Attorney Alexander will not oppose the rescheduling. Thank you for your consideration of my request. Sincerely, b~ cc: Jane Alexander, Esq. ',!~"---~ ,~~ ',' . '. _' , .l__,r,~. ". ' , I - I '~;'{;J:iai\;:ft1t:r:Jt:(~:i:~~ RANDI A. LONG, Plaintiff/Petitioner: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CLARENCE S. LONG, III, Defendant/Respondent: CIVIL ACTION - LAW NO. 01-2844 CIVIL TERM ORDER OF COURT AND NOW, this 26th day of June, 2003, upon consideration of the Emergency Petition for Special Relief and Petition for Civil Contempt in the above-captioned matter and following a hearing, the Court finds that the Defendant has at least in a technical sense intentionally, voluntarily, and willfully failed to comply with the order of court herein, and he is consequently adjudicated in contempt. The sanction of the Court is that the Plaintiff be compensated in terms of lost time with the parties' child, Aiexandria P. Long (date of birth February 10, 1992) in the amount of two and a half days, said period to be selected at Plaintiff's option, and that Defendant pay to Plaintiff the sum of $50.00 for filing fees and $200.00 for attorney's fees. The parties are admonished to follow the terms of the order hereafter. By the Court, ~ () # 6.' C'" ?J rJ/L4 J " I 'f~~,"""","",,",, ,'~" l'..f1 "_fl , h'''-,o''".f, .',,~ . ..,. ~.". .~ I.'.', ~. ;,-T , -, ," ~",,~ -", ,., " ~ ~ "~,,,. .- ,~ -,- '. ,,~ ~$iil( ~ ,. /JNn~'Y7~~StY.N3d . ..-f'." ...1',.... ..';tfWno '11:B UfI . ,0" 01;,' flnr to JIJ""'I'.' /\ v,/,,)'-"" ,. '... :;;...~)nj, ,',):./q' ~.!-J" _I"i."{i-'G'''''/'' ., .:10 ~-<~ '::J I'd ",-" "',''''''''' ",~'m_ ,~ _"'~~ r-IIIIII Iir-f;t~l'ffil!llm _,~ "_ ",'> ~I, ,.~ "".~,~,"')I'L],~, \~, j-\i~!mj'[lIii!-!JYll~~~'~";~"'9',j,'t"r"NMm!'~~~@"'NW?(W!!li1'~~~;f.t'-l~l!~li!1!~ii~\:i~ffl~J~i'lJ~ll!f~'Mi3 ,zdl;::~~0j:~?>(j,1ti:~,,'ti\.;," " "~~., ", ~ne M. Alexander, Esquire For the Plaintiff ~rbara L. Wevodau, Esquire For the Defendant :lfh ,"-"" - - --I,"~ '-I ~, , .~'A_"", 1-- ~)j, ,.- !! i: IN THE COURT OF COMMON PLEAS OF CUMBERLAND, PENNSYL VANIA RANDI A. LONG, : CIVIL ACTION - LAW Plaintiff /Petitioner VS. : NO. 01-2844 CLARENCE S. LONG, m, DefendantJRespondent : IN CUSTODY EMERGENCY PETITION FOR SPECIAL RELIEF AND PETITION FOR CIVIL CONTEMPT AND NOW, TO WIT, this ~/~y of ~ 4A~~ ,2003 comes the Plaintiff/Petitioner, Randi A, Long, by and through her attorn y, Jane M. Alexander, EsqUIre, who respectfully represents: 1, PlaintifflPetitioner, Randi A. Long, is the natural mother of two (2) minor children, Alexandria p, Long, born February 10, 1992 and Catelyn S. Long, born February 22, 2000, 2, DefendantIRespondent, Clarence S. Long, Ill, is the natural father of the said two (2) minor children, 3. That on November 2,2001, Judge J. Wesley Oler, Jr. entered an order awarding Plaintiff/Petitioner primary physical custody ofthe children, Alexandria p, Long and Catelyn S. Long, A true and correct copy of the order marked Exhibit "A" is attached hereto and made a part hereof. 4, Defendant/Respondent filed a Petition for Modification of the custody order May 2002, A conciliation conference was held on June 26, 2002 before Dawn S, Sunday, Esquire. His petition was dismissed, A copy of Conciliation Summary Report marked Exhibit "B" is attached hereto and made a part hereof. 5. Defendant/Respondent has willfully failed to abide by the order in that he did not return his daughter, Alexandria, to the Plaintiff/Petitioner on Sunday, March 23, 2003 in compliance with paragraph 4 of said order. 6. Defendant/Respondent, based on allegations of abuse made by Alexandria against Plaintiff/Petitioner, reported the abuse to Children and Youth Services of Perry County on March 21, 2003, The allegations were investigated by Children and Youth Services on March 22, 2003 by Jeff Wickard of the Cumberland County Children and Youth Services. 7, After the investigation Plaintiff/Petitioner was requested to allow Alexandria to remain with , Defendant/Respondent until close of school, March 24, 2002 in order to allow the paper work to be . completed, She agreed. 8. Defendant/Respondent was advised that Alexandria should be put in her school on Monday and returned to PlaintifflPetitioner Monday evening. Defendant did not put Alexandria in school nor return her to Plaintiff/Petitioner, 9. Defendant/Respondent signed a Protection From Abuse Petition on March 24, 2003 which was filed on March 25, 2003 in the Court of Common Pleas of Perry County to No. 03-278 even though he was advised the changes were not "found," A copy of said Petition marked Exhibit "c" is attached hereto and made a part hereof. I 0, The Court declined to sign the temporary Protection from Abuse Order and schedule a hearing for April 9, 2003. Therefore custody remains with PlaintifflPetitioner. II. Defendant/Respondent has not returned Alexandria to Plaintiff/Petitioner nor has Alexandria been in school. 12, Defendant/Respondent was in the office of the Cumberland County Children and Youth on Wednesday March 26, 2003 and was advised that they found no basis for his not returning Alexandria to P laintiff/Petiti oner, WHEREFORE, Plaintiff/Petitioner request your Honorable Court that Defendant/Respondentbe held in contempt of court. AND FURTHERMORE, PlaintifflPetitioner is respectfully requesting that her daughter, Alexandria, be returned to her immediately and that the DefendantlRespondent be ordered to pay all counsel fees and costs incurred by Plaintiff/Petitioner in regard to this action and should any fines be levied against Plaintiff/Petitioner because of Alexandria's non-attendance at school Defendant/ Respondent shall be liable for payment of said fines. "-'- II VERIFICATION I verifY that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATE: ~ 2; drfiG'3 !}/1~' ;/, J1er Ran i A. Long' r~~ ~~..''',-' RANDI A. 1.0Nn, I'lailllill TN THE COURT OF COMMON PLEAS OF CUMI3ERLAND COUNTY, I'ENNSYLV ANIA vs, 01-2844 CIVIL ACTION LAW CLARENCE S. LONU, III, Defendant IN CUSTODY ORDER OF COURT AND NOW, this .J ~ day of ~~ ,2001, upon considcration ofthe aU ached Custody Conciliation Report, it is ordered and directed as follows: I. The prior Order of this Court dated June 21,2001 is vacated and replaced with this Order. 2. The Mothcr, Randi A. Long, and the Father, Clarence S. Long, III, shall have shared legal custody of Alexandria p, Long, born February 10, 1992, and Catelyn S. Long, born February 22, 2000. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency dccisions affecting the Children's general well-being including, but not limited to, all dccisions regarding their health, education and religion. Pursuant to the terms of this paragraph, each parent shall be entillcd to all records and infonnation pertaining to the Children including, but nol limitcd to, school and medical records and infonnation. 3, The Mother shall have primary physical custody of the Children. 4, The Father shall have partial physical custody of the Children on alternating weekends from Friday at 7:00 p.m. (when the Father shall pick up the Children at dance class), through Sunday at 6:00 p,m., beginning October 26,2001. 5, The parties shall share or alternate having custody of the Children on holidays as follows: A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall nm from '):00 :1,111, until 8:30 p.m. on Christmas Eve, and Scgmcnt n, which shall run from ll:30 p,m. on Christmas Eve through 8:30 p.m. on Christmas Day, In odd nU/1lhcred ycars, thc Mother shall have custody during Segment A and the Fathcr shall havc custody during Segment B, In even numbered years, the Father shall have custody during Segment A and the Mother shall have custody during Segment B. 13. THANKSGIVING: The Thanksgiving holiday shall be divided into Segment A, which shall rUII from 9:00 a.m. until 8:30 p.m. on Thanksgiving Day and Segment 13, which shall nm from Thanksgiving Day at 8:30 p.m. through the Friday following Thanksgiving at 8:30 P,/1l, 111 odd numhered years, the Mother shall have custody during Scgmcnt A and thc {~''n'' :'~.~< , .. \_-- ~. '-- " """ ", - ~, -" ,. Fathcr shall havc custody during Segment B. In even numbered years, thc Father shall have custody during Scgmcnt A and the Mother shall have custody during Segment 13. c. EASTlm: The party who has custody of the Children under the regular custody schedulc on Easter shall have custody on the holiday. D. MEMORIAL DAY/LABOR DAY: The Father shall have custody of the Children cvery year for the Memorial Day holiday from Sunday at 8:00 p.m, through Mcmorial Day at 7:00 p.m, The Mother shall have custody of the Childrcllcvcry ycar tor Ihc Labor Day holiday from Sunday evening at 8:00 p.m. through Labor Day at 7:00 p,m. E, INDEI'ENDENCE DAY: The Independence holiday shall run from 9:00 a.m. on July 4111 through 9:00 a.m. on July S'h. The Mother shall have custody over the holiday in even Ilumbcrcd years and the Father shall have custody in odd numbered years, F. MOTHER'S DAY/FATHER'S DAY: The Mother shall have custody of the Childrcn every year on Mother's Day from 9:00 a.m. until 6:00 p.m, and the Father shall have custody of the Children every year on Father's Day from 9:00 a.m, unlil 6:00 p,m. G, The holiday custody schedule shall supersede and take precedcnce over the regular custody schcdule. 6, The Father shall be entitled to have custody of the Children every year during the summer school brcak for two non-consecutive weeks upon providing at least 30 days advance notice to the Mother. In the event either party intends to take the Children on vacation, that party shall provide advance notice to the other party of the address and telephone number where the Children can be contactcd, 7. Unless otherwise agreed between the parties, the Father shall provide all transportation for exchanges of custody to and from the Mother's residence, with the exception of the exchanges of custody on Fridays, whcn the Father shall pick up the Children at dance class, 8, The Fathcr shall ensure that the Mother has a current work telephone numher and home telephone number where the Father can be contacted in the event of an emergency or to discuss issues relating to the Children. 9, The parties shall communicate directly with each other conceming issues affecting the Childrcn without the involvement of or interference by third parties. 10. Neither party shall consume alcohol to the point of intoxication during his or her periods of custody. Each party shall ensure that third parties having contact with the Children comply wilh this provision during his or her periods of custody. II. Ncithcr party shall take the Children to a tatoo parlor for extendcd pcriods of time during his or hcr pcriods or custody. ~\...~- -" ,~, ".~_.=---~. -~ ~~- -'~ 12. Neither party shall do or say anything which may estrange the Children from the other parent, injure the opinion of the Children as to the other parent, or hampcr the free and natural devclllplllclIlllfll1e l'hildrell's love and respect for the other parent. 130111 parlies shall CIlSllrc thatll1ird parties having contact with the Children comply with this provision. 13. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, I~ l i Iv,,"!<-r a2Clv l;; f. esl y Oler, Jr. ' , J. cc: Jane M, Alexander, Esquire - Counsel for Mother Daniel McGuire, Esquire - Counsel for Father <, II' ...'; '~~f< '/1 '7lb-l",;f.!l!._d,<--"..;2~t!L ,fl&..<.,..f,.L...?k~/(I"<.1..~___ I. imllllll~'ldrv ,i<,.~g .,., ," ~, ~"~,", . .__, .~. ,h .<. .~,,," , -.u _ ~ ""~^ , RANDI A, LONU, Plainliff IN nm COURT OF COMMON PLEAS OF CUMRERLAND COUNTY, PENNSYLVANIA vs, 01-2844 CIVIL ACTION LAW CLARENCE S, LONG, III, Defendant IN CUSTODY PRIOR JUDGI~: .I, Wesley Oler, .II'. CUSTODY CONCILIATION SUMMARY REPORT IN ACCOIWANCE WITH CUMBERLAND COUNTY RULE OF CIVIL I'ROCEDURE 1915.3-8, the undersigned Custody Concilialor submits the following report: I. The pertinenl information concerning the Children who are the suhjecls of Ihis litigation is as ri)lIows: NAMfi: DATE OFBIRTI-I CURRENTLY IN CUSTODY OF Alexandria E, Long Catelyn S, Long February 10, 1992 February 22, 2000 Mother Mother 2, A Conciliation Conference was held on October 23, 2001, with the following individuals in allendance: The Mother, Randi A. Long, with her counsel, .lane M. Alexander, Esquire, and the Father, Clarence S, Long, [II, with his counsel, Daniel McGuire, Esquire. () dv !x. 1 .J ') r-ilou I Date 3, The parties agreed to entry of an Order in Ihe form as atlached. (Q~~<--rc4L::J Dawn S. SUl'lday, EsquireO Custody Concilialor }~v ," "",;~,"""'"",~i'11",,~'.>-h ,__~, o.,_'_'__,~"" .M' -<., RANDI A, LONG, Plaintiff IN THE COURT OF COMrvlON I'II;/\S OF CUMBERLAND COUNTY. PENNSYLV ANIA vs, 01-2844 CIVIL ACTION L/\ W CLARENCE S. LONG, Ill, Defendant 1N CUSTODY PIUOR 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: I, The pertincnt information concerning the Children who are thc subjects ur Ihis litigation is as follows: NAlvm DATE OF BIRTH CURRENTLY IN CUSTODY OF Alexandrea P. Long Catclyn S. Long Fcbruary 10, 1992 February 22, 2000 Mothcr Mother 2. A Conciliation Conference was held on June 26, 2002, with thc lu\lowing indi\'itluals in atlentlance: The Mother, Randi A. Long, with her counsel, Jane M. Alexantler, Esquire. antl the Fathcr's counsel, Barbara L Wevotlau, Esquire, The Father, Clarence S, LOlIg. III. \\'lro lib! tlris Pctition for Modilication, tlitl not allentl the Conference for reasons unknown to his eOLlnseL 3. The issues raised by the Father in his Petition were discussed at the Conll:rence antl the Mother offered documentation from Alexandrea's school, physician antl counsclnr in direct response to the Father's allegations. 4, As the Father did not attcnd the Conference, no further Ortler addressing lire custotly arrangements is necessary at this time except to dismiss the Father's Petition for Motli lication, if deemetl necessary by the COUli. -..Ju lie-' ,;I C ;l-cO-?- . Date C<-<-~C~C0-j1~_._ Dawn S. Sunday, Esquire ' Custody Conciliator (' f; f?~.-b ~tJ_sW'I >,~,,- ,- , ~ ~~. " Ii I' 'I :1 "I 'I II " ~I "~I "I i ,I 'I 'I l II ,I II l ;,1 " 1,,1"'" , ""';;"~"'" " JlI! rl{,OO? RANDI /\. IONt i, "1.11111111' IN THE COURT OF COMMON PLEAS OF ('IIMJlFIII MID ('()II~ITY, PFNN,<;Yf.V ANIA vs, 01-2844 CIVIL ACTION LAW CLARENCI'S LONG, [II Defendant IN CUSTODY ORDER OF COURT AND NOW, this oK M~( day of q,/ '.' 2002, upon consideration of Ihe attached Custody Conciliation Repo~ it is ordered and directed as follows: \, The prior Oruer of this COllrt dated November 2,2001 shall continuc in effect. 2. Based on representations and documentation presented by the Mother at the Conciliation Conference and the Illct thai lhe Father was not in attendance, the Father's Petition for Modilication is dismissed, BY THE COURT, /,,~ (J IA ka /'.' '. 1. esfey O[er, Jr. ' 0110 .::L J, cc: Barbara L, Wevouau, Esquire- Counsel for Father Jallc I'd, :\IC\alldcr, I~squire ,Counsel for Mother TRUE, (:(11''; I' !:', ,,:'''/,,~;'. In T;l},ji.dnl(,ny 1-;'p;q' ,~, :. \ '.::, ( '.>~. ".,' r "", '~':',!r.) ()i'F:'j Hw :'~i~ ,'.~~ ';~""'. ' :. ~t--)' ,,: ;r..;,< i; ".'Ill' : -:-:; nl!~._;L~~),':~~/' ,,: ,'c; ~J!.,?'I, " " J:.t...L \. ' .... }"I" '........__ ..---.-. ' ...,I.t...!l!.\.{,-e.L"c_,_A..Wi' h; \lil:fnl~l~ ~rj,1 , - ',' c< _,_ _,__ ..__.~ ,P~. ~ . - -" ~ I ., , ') " ,: , ,'j ALEXANDREA P. LONG V. RANDI A. LONG :IN THE COURT OF COMMON PLEAS :OF THE 41sT JUDICIAL DISTRICT :OF PENNSYLVANIA- :PERRY COUNTY BRANCH :NO. 03-278 :P.F.A. CLARENCE S. LONG, III on behalf of minor children, (,ATI~LYN S. LONG, ORDER AND NOW, March 25, 2003, the Court having received an ex parte request for an Order, the Court declines to sign such Order, but schedules a hearing on the issue of whether or not a Protection From Abuse Order should issue for Wednesday, April 9, i i' 2003, at 8:30 a.m. in Courtroom # 2, Perry County Courthouse, New Bloomfield, il II :1 'I II 'I i II II Ii ]I Pennsylvania, at which time both the plaintiff and defendant shall be present fol' a hearing. Service of this Order shall be by the Sheriff of Perry County. , ) Cc: Plaintiff L>>~fendant Domestic Violence Sheriff PSP Local Police File ",.j -'-:1 ;po :'-":'1 '.11 0'\ d ~( I.JJ _",I rrl C' ~ ~.~ :J." :;JC --?; --.. . r" .)1 I. -0 ~ '~J~ ~ ~~// ;:''''!'''''''' ~ , 'v ~, ".' '."-.- , ,,,.- -" : IN THE COURT OF COMMON : PLEAS FOR THE 41 ST : JUDICIAL DISTRICT PERRY : COUNTY, PENNSYLVANIA Clarence S. Long HI on behalf of minor children, Catelyn S. Long, Alexandrea P. Long Plilintiff v. : No. 03- ')..7'6 . Randi A. Long Defendant : CIVIL ACTION - LAW : PROTECTION FROM ABUSE NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim set forth in the follo1Ning papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. Any protection order granted by a court may be considered in subsequent proceedings under Title 23 (Domestic Relations) of the Pennsylvania Consolidated Statutes, including child custody proceedings under Chapter 53 (relating to custody). f A hearing on the matter is scheduled for the . '_II.."", "'.J - ,n . . - ,;at_ ~" in CourtrOOl! v You MUST obey the Order that is attached until it is modified or terminated by the court after notice and hearing. If you disobey this Order, the police may arrest you, Under federal law, 18. U.S.c. S2265, this Order is enforceable anywhere in the United States. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act. 18 U.S.C. S2262. Violation of this Order may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. In addifion,)fyou are subject to a FINAL PROTECTION ORDER, you may be prohibited from possessing, transporting, or accepting a firearm under the 1994 Amendment to the federal Gun Control Act, 18 U.s.C. S922 (d) and (g). YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOU HAVE THE RIGHT TO HAVE A LAWYER REPRESENT YOU AT THE HEARING. THE COURT WILL NOT, HOWEVER, APPOINT A LAWYER FOR YOU. 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. IF YOU CANNOT FIND A LAWYER, YOU MAY HAVE TO PROCEED WITHOUT ONE. County Lawyer Referral Service PA LAWYER REFERAL SERVICE 1-800-692-7375 100 PINE STREET, PO BOX 166, HARRISBURG, PA 17108 PFAD Number: FJ1646779U Plaintiff : IN THE COURT OF COMMON : PLEAS FOR THE 41ST : JUDICIAL DISTRICT PERRY : COUNTY, PENNSYLVANIA Clarence S. Long III on behalf of minor children, Catelyn S. Long, Alexandrea P. Long v. :No. Randi A. Long : CIVIL ACTION - LAW : PROTECTION FROM ABUSE .' Defendant PETITION FOR PROTECTION FROM ABUSE Plaintiffs name is: Clarence S. Long III _. I, (the Filer), am filing this Petition: - as Parent of minor Plaintiff(s) ., Filer's Name is: Clarence S. Long Filer'3 Address is: 7081 Spring Rd." Shermans Dale, PA 17090 ", Name(s) of ALL person(s), including minor children, who seek protection from abuse. a. Catelyn S. Long b. Alexandrea P. Long 6. Plaintiffs Address is : 117 Steelstown Rd. , Newville, P A 17241 .. Defendant's Name is: Randi A. Long %. Defendant i.s beli.eved to Eve at the following address: " .117 Steelstown Rd., Newville, PA 17241 C), Oefendant's Social Security Number is: 4JOO-00-0000 10. Defendant's Date of Birth is: ,j"'y 30, 1969 11. Defend?.T\','s Place of employment is: C :o:J.puter Learning Network, Mechanclsburg, P A 12. Defend::r:: is an adult. 13. The re!?'::~nship between the Plaintiff and the Defendant is: ~l.'?:Juse P"::-,,nts of the same children 14. The Pl~,::',iff and the Defendant been involved in the following court actions: .... Support .. Custody I'" ' Other c:",~rrils of the court action are: ,~:~S2 Cumberland Custody order- Defendant was awarded primary physical custody r:,,~ Plaintiff given every other weekend visitation. 2002 Support hearing at Cumberland County Domestic Relations. 16. The de:-'=:-"dant has not been involved in a criminal court action. 17, Plaintif!",:1.d Defendant are the parents of the following minor child/ren: __, Catelyn S. Long Age:3 Child's address is: 117 Steelstown Rd., Newville, PA 17241 , Alexandrea P. Long Age: 11 Child's address is: 117 Steelstown Rd. , Newville, P A 17241 18. There is an existing court order regarding the custody of the Plaintiffs and Defendant's minor children. The terms of the order are: 2002 Cumberland Custody order- Defendant awarded primary physical custody and Plaintiff given every other weekend visitation. County: Cumberland State: p,~ 19, Plainti:r is seeking an Order of child custody as part of this petition. The fcl1cwing is a list of the children and where they have live for the past 5 years: ... Catelyn S. Long For the past 5 years, this child has lived with: 2001-present: 117 Steelstown Rd., Newville, PA 17241 1998-2001: 67 Country View Estates, Newville, PA 17241 Alexandria P. Long For the past 5 years, this child has lived with: 2001-present: 117 Steelstown Rd., Newville, PA 17241 1998-2001: 67 Country View Estates, Newville, P A 17241 Al'.....Aud. "4 1. Long Fo! Ii!\.- pa"l 5 JGQ..lO>, Mti3 elHIJ ta.:, l1.e8. ..ith: :'~!. The fae:s of the most recent incident of abuse are as follows: On ab:,,! Wednesday, March 19, 2003 at approximately 6:00PM locatic,,: H7 Steelstown Rd., Newville, PA 17241 The Det'endant and her two children, ages 11 and 3, were watching a movie. The girls gilt into an argumen and the three-year-old slapped her older sister. The older sister briefly held her younger sister's mouth shut. The Def. became angry and held her eleven-year-old daughter's mouth shut and sh;:!ped her repeatedly in the face. The eleven-year-old ran back into her bedroom crying. The Def. followed and grabbed the minor child around her neck and punched her in her face. The Def. proceedej to slap her in her face again, followed by punching the child in her shoulder. The three- year-ol,j tried to intervene on her sister's behalf. The Def. turned her rage on the three-year-old and slapped her several times in the face. The Def. yelled at her eleven-year-old daughter to pack her bag~. She told her to get out of her house right now. The minor child packed her bags and called r,~r friend to see if she could spend the night. When the minor child came into the living room with her backpack, the Def. changed her mind and told her that she was just trying to get through to her. On Fr!chy March 212003 when the Plaintiff picked up his two daughters for a scheduled weekend. visit, he learned of the abuse against his daughters from his oldest eleven-year-old who reported. ,< . . what 1u;l happened. The Plaintiff observed a light bruise mark on his daughter'sll:ft check. The ..d.;,;' child alsfj reported to her father that her nose hurt. The Plaintiff called Perry County Children & .- / .', Youth and reported the incident to a caseworker. A caseworker came to the residnce on Saturday' March 222003 and interviewed the oldest child. The caseworker also took thr~e pictures of the '. child's f:1ce. The Plaintiff was referred to Domestic Violence Services. ' . .<. I I" .. ','e.r" , , <'Ii' ,." Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor child/reri: ' (including- any threats, i~uries, or incidents of stalking) are as follows: During the first week of March 2003 (minor child can't recall exact date), the Defendant threw her minor child who is 11, against their refrigerator so that the child's head smacked against it. The child also sustained pain in her arm when it hit the handle ofthe refrigerator door. The Def. also i"0.1Ji1ll1~-:-:',~ ",,' 00" ,_ '0'>' f. , ',~, ,"~ slapped the child acl',~~s her face. The child reported this incident to her father's girlfriend, who in , turn, informed the171. later that same night. The Plaintiff spoke to the child's principal and guidance counselor on Monday March 10 2003 because the child had reported the incidents to these parties as well. On ThursllllY Fchrtlllry 20 2003, the Def. lost her temper with her children while trying to get them into the car. The Def. repeatedly hit her three-year-old daughter in her face once she got her into the car seat. The eleven-year-old ran around to the front of the car and tried to lock it to keep her mother out. The Def. got into the car before the doors could be locked. Once in the car, the Def. slapped her eleven- year- old repeatedly across her face. The minor eleven-year-old daughter reported this incident to her school guidance counselor. The Plaintiff is concerned for the safety and welfare of his two minor children, and at this time requests relief from the court through a Protection From Abuse order on behalf of the minor parties. 22. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: Newport PSP 23. There is an immediate and present danger of further abuse from the Defendant. 24. Plaintiff is asking the court to eyiet n~-j exclude the Defendant from the following residence: 7081 Spring Rd., Shermans Dale, P A 17090 (No eviction. Plaintiff and Defendant do not live together). Owned By: Carol Dieffenderfer 25. 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. ~t/exclude Defendant from Plaintiffs residence and prohibit Defendant from attempting to enter any temporary or permanent residence of the Plaintiff. c. Award Plaintiff temporary custody of the minor child/ren and place the following restrictions on contact between Defendant and child/ren: No contact until court date at which time parties can agree on an arrangement. d. Prohibit Defendant from having any contact with Plaintiff and/or minor child/ren ~ither !n person, b~ t~lephone, or in writing, personally or through third persons, , mcludmg but not lmuted to any contact at Plaintiff's 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. e. Prohibit Defendant from having any contact with Plaintiff's relatives and Plaintiff's children listed in this petition, except as the court may find necessary with respect to partial custody and/or visitation with the minor child/ren. j~!TU"" <,- - ,-"",',-,-. f. 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 infonn the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. VERIFICATION r verify that r 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 ~~, ~~ J~_ D;m; ~ / [X,~"- '-~ ,,,.p,,.-,--~~.; ~,r.'1',;.c"", ~,,"'jl'" ". ""',.'! =' . '_'__" 0__ : IN THE COURT OF COMMON : PLEAS FOR THE 41ST : JUDICIAL DISTRICT PERRY : COUNTY, PENNSYLVANIA Clarence S. Long III on behalf of minor children, Catelyn S. Long, Alexandrea P. Long Plaintiff v, : No. Randi A. Long : CIVIL ACTION - LAW : PROTECTION FROM ABUSE Defendant TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: Randi A. Long ['efendant's Date of Birth is: July 30, 1969 D~:endant's Social Security Number is: 000-00-0000 l"U:le(s) of All protected persons, including Plaintiff and minor children: I. Catelyn S. Long 2. Alexandrea P. Long A~--JD NOW, on 25th Day of March, 2003 upon consideration of the attached P~tition for Protection from Abuse, the court hereby enters the following Temporary Order: Plaintiffs request for a temporary protection order is granted. 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in 3..tlY place where they might be found. 2. Defendant shall be 8yiet8a Illia excluded from the residence at: 7081 Spring Rd., Shermans Dale, P A 17090 (No eviction. Plaintiff and Defendant do not live together). ::Jr any other permanent or temporary residence where Plaintiff or any other person protected under this Order may live. Plaintiff is granted exclusive possession of !he residence. Defendant shall have no right or privilege to enter or be present on the premises of Plaintiff or any other person protected under this Order. 3. Except for such contact with the minor child/ren as may be permitted under paragraph 5 of this Order, Defendant is prohibited from having ANY CONTACT with Plaintiff, or any other person protected under this Order, at any location, including but not limited to any contact at Plaintiff's school, business, or place of employment. Defendant is specifically ordered to stay away from the following iocations for the duration of this order. I' ~'f:}1J.~. - .- - > "'.'j,n._' ~~ "i" .. A "'~ " - .'Jewville Elementary School 4. .':xcept for such contact with the minor child/ren as may be permitted under paragraph 5 of this Order, Defendant shall not contact Plaintiff, or any o.ther . nn'HlIl proft>c\l>d Imnrr this Order, by telephone or hy nny otlwr m('nn~. mclnnmg ~hrough third persons. 5. Fending the outcome of the final hearing in this matter, Plaintiff is awarded 'emporary custody of the following minor child/ren: 1. Catelyn S. Long 2. Alexandria P. Long 3. Al...~..Adl sa P.1.8Bg'; 0ntil the final hearing, all contact between Defendant and the child/ren shall be ::mited to the following: ,"0 contact until court date at which time parties can agree on an ":rrangement. The local law enforcement agency in the jurisdiction where the child/ren are !ocated shall ensure that the child/ren are placed in the care and control of the 'Jlaintiff in accordance with the terms of this Order. 6. :he following additional relief is granted: - Defendant is prohibited from having any contact with Plaintiffs relatives :md Plaintiffs children listed in this petition, except as the court may tind '1ecessary with respect to partial custody and/or visitation with the minor :.:hild/ren. '7. .'\ certified copy of this Order shall be provided to the police department where ?laintiff resides and any other agency specified hereafter: :'o'ewport PSP H .fhe sheriff, police or other law enforcement agencies are directed to serve the Defendant with a copy of the Petition, any Order issued, and the Order for Hearing without prepayment of costs. The Petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant :an be served. The Prothonotary is directed to file this Petition and Order without prepayment of costs. 9. THIS ORDER SUPERSEDES ANY PRIOR ORDER RELATING TO CmLD CUSTODY h THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL OTHERWISE MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. -\~:r" ~ "^ " ~,', - _, _, " " ", . . ., NOTICE TO THE DEFENDANT Defendant is hereby notified that violation of this Order may result in arrest for if'oirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or IW 10 six months injail. 2) Pa.C.S. *6114. Consent of the Plaintiff to Defendant's rc,'lm to the residence shall not invalidate this Order, which can only be changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S. 96113. Defendant is further notified that violation of this Order may subject him/her to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 D.S.C. gg2261- 2'262, NOTICE TO LAW ENFORCEMENT OFFICIALS T:is Order shall be enforced by the police who have jurisdiction over the plaintiffs residence OR any location where a violation of this order occurs OR where the de!'endant may be located. If defendant violates Paragraphs 1 through 5 of this Cr~er, defendant shall be arrested on the charge ofIndirect Criminal Contempt. An arr~st for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence of law e:-rtofcement. Scl::'sequent to an arrest, the law enforcement officer shall seize all weapons used or trxeatened to be used during the violation of this Order OR during prior incidents of ab.lse. Weapons must forthwith be delivered to the Sheriff's office of the county w':.ich issued this Order, which office shall maintain possession of the weapons until ji,;:ther Order of this court, unless the weapon/s are evidence of a crime, in which c~"e, they shall remain with the law enforcement agency whose officer made the af:'~st. BY THE COURT; Judge Date l)ist,ilmtioI1. to: PU.INTIFF DEFENDANT LOCAL POLIC: STA"E POLICE SHE?JFF DmfESTIC V'OLENCE FILE 'it,.J, . , ,"--,."." "",,". ",',', ~ ~ .~ - 'or . ~ ~"- .' P; _.~ ~., '" .".~ . > 0' " '.- , """"1-'"'' q. """ ,_ul!'!l~ "_0 '.'- ~ '"C' '" ~ - vi {' t "'h'.h'.M,ml"!ii' 1"'."""""111"'1"""" . "~' ,'", ,.,,,-"- -'.'''''''',-"-",; ... ._."._--I.IIII....~!!III (\ - lJ r " u "* (,'\ \) \ ~ !.\, ~ o So *',., 0..;'." n-,jT, ---.r- - .- ;~.~ c..... ~), c~;, ~;,,~-, ,,,,,,,". j; ;(:'::~ ~-,~ '":,:j ....;c. .l ",,,l!W8'~.')lf~;'1'l1~~,~~.P.::;g!,_!l1I:j1""'~_ "'~" .-,. (j -n '-r. ___j ',<> -:1 ,~:J ,'.) 1",' .~ ::~2 ';::'J f~;~i:~ -;-~..,--'--" ~~~ ?~ 15 -< -~ ---'"," -:::> <,.;> ~',~)'fi'II~~,,~~~ M[t;1003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND, PENNSYLVANIA RANDI A. LONG, : CIVIL ACTION - LAW Plaintiff/Petitioner VS. : NO. 01-2844 CLARENCE S. LONG, m, DefendantlRespondent : IN CUSTODY NOTICE AND ORDER TO APPEAR Legal proceedings have been brought against you alleging you have willfully disobeyed an order of court for custody and visitation. If you wish to defend against the claim set forth in the following pages, you may but are not required to file in writing with the court your defenses or objections, Whether or not you file in writing with the court your defenses or objections, you must appear in person in court on T~"";$~'~1f r,-[ -S ,2003 at---3-:..fCLll,M" in Courtroom, ~J........, Cumberland County Court House, 1 Courthouse Square, Carlisle, P A 17013. IF YOU DO NOT APPEAR IN PERSON, THE COURT MAY ISSUE A WARRANT FOR YOUR ARREST. If the court finds that you have willfully failed to comply with its order for custody and visitation, you may be found to be in contempt of court and committed to jail, fined or both. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 BY THE COURT: Date: MaeL 2-'j 2DOS Judge ~l ~ fi ~~ ~\ 'fJ ~ ~ ~~-"... , 'c',".~. ,__~~ " -,~~,~, - . 'd. (, "'.""~' L,~' """ - '-'>, ~-;":;'__."~,';,; ",.,"',..,..)., '0' _ _m "~_" ,~_' ,,,~'.., ~.'"'~ VlNV/I1J..SNN3d )J.NnO:J cr,;;!1:F8V'lnJ 8'} '.'" '1,.,',J ...., \'''' I ,~r, t.. (.J ~ t}G d"i:~ (,LJ Al:iVlO~J9;;iJ<;;j,(."L :.10 _ ~~,"~~~l'<~m'5l"ii<i~p~.'it~"""~\j!"W!'$'ilj~~~I'!l~~_^ - urni ,"r~r~' .c,' ,_,~,