HomeMy WebLinkAbout01-5962
ROBERT S. COWMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
LORRAINE R. COWMAN,
Defendant
CIVIL ACTION - LAW
NO. 2001- S9(.~ CIVIL TERM
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set forth in the
foregoing 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 in 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:
Office of the Prothonotary
Cwnberland County Court House
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.
Cwnberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
ROBERT S. COWMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
LORRAINE R. COWMAN,
Defendant
CIVIL ACTION - LAW
NO. 2001- S9'-~ CIVIL TERM
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed in
the Court of Common Pleas of Cumberland County. This notice is to advise you that in
accordance with Section 3302(d) of the Divorce Code, you may request that the court require
you and your spouse to attend marriage counseling prior to a divorce being handed down by the
court. A list of professional marriage counselors is available at the Cumberland County Court
House, One Courthouse Square, Carlisle, Pennsylvania. You are advised that this list is kept as a
convenience to you and you are not bound to choose a counselor from this list. All necessary
arrangements and the cost of counseling sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver
of your right to request counseling.
..
ROBERT S. COWMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
LORRAINE R. COWMAN,
Defendant
CIVIL ACTION - LAW
NO. 2001- .cq~~ CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE
UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE
AND NOW comes the above-named Plaintiff, ROBERT S. COWMAN, by his attorney,
Michael 1. Bangs, Esquire, and makes the following Complaint in Divorce:
I. The Plaintiff is ROBERT S. COWMAN, an adult individual who currently resides at
218 North 29th Street, Camp Hill, Cumberland County, Pennsylvania.
2. The Defendant is LORRAINE R. COWMAN, an adult individual who currently
resides at 218 North 29th Street, Camp Hill, Cumberland County, Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth
of Pennsylvania for at least six months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on November 13, 1993, in New
Cumberland, Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. This marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff
may have the right to request that the Court require the parties to participate in counseling.
8. The Plaintiff requests this Court to enter a Decree of Divorce in this matter pursuant to
Section 3301(c) ofthe Divorce Code.
. .
.
WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to
Section 3301(c) of the Divorce Code.
I verifY that the statements made in this Complaint are true and correct. I understand that
any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. Section 4904
(unsworn falsification to authorities).
/()/;Z./o /
Date
M-vvf~~ ~
ROBERT S. COWMAN
MICHAEL 1. BANGS
Attorney for Plaintiff
302 South 18th Street
Camp Hill, PA 17011
(717) 730-7310
Supreme Court ID #41263
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ROBERT S. COWMAN,
Plaintiff
vs.
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYL VANIA
LORRAINE R. COWMAN,
Defendant
NO. 2001-5962 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF SERVICE BY CERTIFIED MAIL
MICHAEL 1. BANGS, being duly swornlic(;{)l",cIing to Ill\\'. clt'"J1MPS and ~ _.fullows:
I. That he is'the attorney for the Plaintiff herein.
2. That on October 22, 2001, a true and correct copy of the Divorce Complaint filed in
the above-captioned matter was delivered to the United States Postal Service in Camp Hill,
Pennsylvania, as certified mail (Receipt No. 7000 1670 0000 8954 0687) return receipt
requested, addressed to the Defendant herein.
3. That a return receipt card was received from the U.S. Postal Service signed by the
Defendant herein showing a date of service of October 24,2001. Said card is attached hereto as
Exhibit A.
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EXHIBIT A
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ROBERT S. COWMAN,
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v.
:CIVIL ACTION - LAW
:IN DIVORCE
LORRAINE R. COWMAN,
Defendant
:NO. d-COj-S'f(c'J-
PRAECIPE FOR ENTRY OF APPEARANCE
To the Prothonotary:
Kindly enter the appearance of Thomas A. Beckley, Esquire, Elizabeth S.
Beckley, Esquire and Beckley & Madden, of Counsel, on behalf of the Defendant,
Lorraine R. Cowman, in the above-captioned matter.
DATED I:J-JT-OI ~~~
Of Counsel
BECKLEY & MADDEN
212 North Third Street
P.O. Box 11998
Harrisburg, Pennsylvania 17108
(717) 233-7691
.
CERTIFICATE OF SERVICE
I, Elizabeth S. Beckley, Esquire, hereby certify that a true and correct copy of the
foregoing document was this day served upon the person and in the manner indicated
below.
SERVICE BY FIRST CLASS MAIL:
Michael L. Bangs, Esquire
Attorney at Law
302 South 18th Street
Camp Hill, P A 17011
DATED: {).-J-:j--O/
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ROBERT S. COWMAN,
Plaintiff
vs.
)
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
NO. 2001-5962 CIVIL TERM
LORRAINE R. COWMAN,
Defendant
IN CUSTODY
COMPLAINT IN CUSTODY
AND NOW comes the Plaintiff, ROBERT S. COWMAN, by his attorney, Michael 1.
Bangs, and makes the following Complaint for Custody:
I. The Plaintiff is ROBERT S. COWMAN, an adult individual who resides at 218 South
29th Street, Camp Hill, Cumberland County, Pennsylvania.
2. The Defendant is LORRAINE R. COWMAN, an adult individual who resides at 50
South 22nd Street, Apartment 4, Camp Hill, Cumberland County, Pennsylvania.
,"
3. The Plaintiff and Defendant are husband and wife.
4. The Plaintiff and Defendant are the parents of two minor children: Kathleen (d.o.b.
11/13/94) and Peter (d.o.b. 12/23/97).
5. Plaintiff seeks an award of primary physical custody of the children.
6. The children were not born out of wedlock and at the time of this Complaint, the
children reside with both parents at the marital residence and in the joint legal and physical
custody of both parents.
7. During the past five years, the minor children have resided with the following persons
at the following addresses:
A. From November 13, 1994 to
October, 2002
218 South 29th Street
Camp Hill, P A
:"
B. From October, 2002 to
Present
50 South 220d Street, Apt. 4
Camp Hill, P A
8. The father of the children is the Plaintiff who reside:s at the address set out above. He
is married to the Defendant.
9. The mother of the children is the Defendant who resides at the address set out above.
She is married to the Plaintiff.
10. The Plaintiff is the natural father of the children. Plaintiff currently resides with his
mother.
:;'
11. The Defendant is the natural mother of the children. Defendant currently resides
with the children.
12. The Plaintiff has not participated as a party or in any other way in any litigation
concerning the custody of the children in this or any other comt.
The Plaintiff has no information of a custody proceeding concerning the children pending
in a court of this or any other jurisdiction.
Plaintiff knows of no other person not a party to this action already who has physical
custody of or claims to have custody or visitation rights to the said children.
,','
2
13. The best interests and permanent welfare of the children will be served by granting
the relief requested by Plaintiff for the following reasons:
A. The parties entered into a Memorandum of Understanding for a
custodial arrangement between the parties. This Memorandum of Understanding
was pending a completed evaluation by Dr. Arnold Shienvold. Attached hereto
and marked as Exhibit A is a true and correct copy of the Memorandum of
Understanding which was entered in December, 2002.
B. In September, 2003 Dr. Shienvold completed the evaluation. Attached
hereto and marked as Exhibit B is a true and correct copy of the evaluation.
Dr. Shienvold made some specific recommendations on the evaluation and in
particular as it relates to the current custody arrangement, one of which was to
refrain from the continued use of alcohol.
C. Soon after the completion of the evaluation, Plaintiff became aware
that Defendant had been arrested for another D.U.I. Subsequent to that
knowledge, Plaintiff became aware that Defendant had been arrested for a second
D.U.I.
D. The parties, through counsel, agreed that Defendant undergo a
supervised visitation based upon the recommendation of Dr. Shienvold, the
supervised visitation to occur on the following schedule: Tuesday and Thursday
evenings from 5:30 p.m. until 7:30 p.m. and every Sunday from 2:30 p.m. until
6:30 p.m. This supervised visitation commenced in November, 2003.
3
E. In January to early February, 2004, Defendaat requested unsupervised
visitation and the parties again went back to Dr. Shienvold for recommendation.
Dr. Shienvold initially made a recommendation dated February 23, 2004 wherein
he suggested that Defendant have periods of unsupervised visitation on Tuesday
and Thursday evenings from after school until 8:00 p.m. and on Saturday or
Sunday from 12:00 p.m. until 8:00 p.m. Attached herel:O and marked as Exhibit C
is a true and correct copy of the recommendation dated February 23, 2004.
F. Subsequent to that follow-up, Dr. Shienvold became aware of some
additional information which resulted in his letter of March 8, 2004 wherein he
rescinded the recommendation of February 23, 2004 and indicated that Defendant
should be back on supervised visitation. This was a direct result of some
inaccuracies that Defendant stated and the fact that she had continued to drink and
putting the children in danger. Attached hereto and marked as Exhibit D is a true
and correct copy of Dr. Shienvold's letter of March 8, 2004.
G. Recently, Defendant has switched counsel and arbitrarily, on the
weekend of April 30, 2004, when Plaintiff was out of town, picked up the children
and had unsupervised contact with them. This is contrary to the plan set up the
Plaintiff and occurred while he was out of town.
H. Defendant is unfit to have anything but sup<:rvised visitation until she
proves that she has got control of her sobriety and otherwise complies with the
recommendation made by Dr. Shienvold.
4
14. Each parent whose parental rights to the children have not been terminated and the
person who has physical custody of the children have been named as parties to this action.
WHEREFORE, ROBERT S. COWMAN, requests this Honorable Court enter an Order
granting him primary physical custody of the children Kathleen Cowman and Peter Cowman,
subject to periods of partial custody on a supervised basis only in accordance with the
recommendation of Dr. Shienvold.
MICHAEL L. BANGS
Attorney for Plaintiff
429 South 18th Street
Camp Hill, PA 17011
(717) 730-7310
Supreme Court II> #41263
5
VERIFICATION
I verify that the statements made in this document are true and correct. I understand that
any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 (unsworn
falsification to authorities).
Date: 7 '1(l() 0 t/
~~~
ROBERT S. COWMAN
6
EXHIBIT A
(Memorandum of Understanding)
ROBERT S. COWMAN,
Plaintiff
vs.
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 2001-5962 CIVIL TERM
LORRAINE R. COWMAN,
Defendant
CIVIL ACTION - LA W
IN DIVORCE
MEMORANDUM OF UNDERSTANDING
THE PARTIES shall share legal custody of their minor children, Kathleen
(d.o.b. 11113/94) and Peter (d.o.b. 12/23/97). Physical custody shall be as follows:
1. Rob shall have the following periods of partial custody:
A. Week I: Wednesday after school until Saturday at 12:00 noon at
which time Lorraine shall pick up the children at Rob's residence. This schedule
shall commence on November 6, 2002, and alternate thereafter.
B. Week 2: Wednesday after school until Sunday at 6:00 p.m. at which
time Rob shall drop the children off at Lorraine's resid,ence. This schedule shall
commence on November 13,2002, and alternate thereafter.
2. Lorraine shall have the following periods of partial custody:
A. Week 1: Saturday at 12:00 noon until Wednesday morning when she
shall deliver the children to school or if the children art: not in school, until the
normal after school pickup. This schedule shall comm,ence on November 9, 2002,
and alternate thereafter.
B. Week 2: Sunday at 6:00 p.m. until Wednesday morning when she
shall deliver the children to school or if the children art: not in school, until the
normal after school pickup. This schedule shall commence on November 17,
2002, and alternate thereafter.
3. The parties shall alternate the holiday schedule, those holidays being defined as
Thanksgiving, Easter, Memorial Day, Fourth of July and Labor Day. This alternating schedule
shall commence with Rob having Thanksgiving in 2002, and shall alternate thereafter. These
periods of exclusive custody shall be from 9:00 a.m. until 7:00 p.m., and shall take precedence
over the normal schedule.
4. The Christmas holiday shall be broken into two segments. Segment A shall be from
Christmas Eve at I :00 p.m. until Christmas Day at I :00 p.m. Segment B shall be from Christmas
Day from I :00 p.m. until December 26th at I :00 p.m. In the ye:ar 2002 and all even-numbered
years thereafter, Lorraine will have Segment A and Rob will have Segment B. In the year 2003
and all odd-numbered years thereafter, Rob will have Segment A and Lorraine will have
Segment B.
5. During the summer, both parties shall have the option to take two (2) full non-
consecutive uninterrupted weeks of vacation time with the children. The parties shall provide
each other with notice as to when they intend to exercise these weeks of vacation by April 30th of
each year. Whoever provides the other with notice first of the weeks in which they expect to
exercise these periods of vacation shall be entitled to the first choice of the vacation time.
6. The non-custodial parent shall have the first right of refusal to provide care for the
children if the party who has the children in their custody intends to be away from the children
for two hours or more. It is the obligation of that parent to call the non-custodial parent to see if
they are available and willing to provide the care for the children during that period of time.
2
7. The parties agree that they shall submit themselves and their minor children to an
evaluation to be performed by Riegler Shienvold and Associatt:s. Rob agrees to initially pay
$2,500.00 for the evaluation. Rob reserves the right to seek reimbursement for any portion of
these costs deemed appropriate at a future date.
8. On a temporary basis, and in consideration of the payment by Rob of the current day
care costs (not including the summer costs which is to be determined), Rob will pay to Lorraine,
on a bi-weekly basis, the sum of $345.23. He shall make those payments directly to Lorraine on
or before his regular pay date.
9. The parties agree for the 2002 taxes they shall coope:rate with each other in making
sure the taxes are prepared and filed, and the parties will evenly split any refunds.
10. Both parties understand that this agreement is an attempt by them to make an interim
agreement. Nothing in this Memorandum of Understanding shall prejudice either party from
asserting any rights that they may have to an appropriate custodial situation or an appropriate
support payment.
WITNESS
ROBERT S. COWMAN
WITNESS
LORRAINE R. COWMAN
3
EXHIBIT B
(Evaluation of September, 2003)
. ~\l Riegler: Shienvold
'.11 & AssocIates
Elliot Riegler, Ph.D. (1948-.1999)
Arnold T. Shienvold. Ph.D
Melinda Eash, MS
James Eash, LSW
Bonnie Howard, Ph.D.
Amy K. Keisling, ACSW, LCSW, BCD
Tracy Richards, QCSW, LCSW
Dyanne Seymore, QCSW, LCSW
Jeffrey Pincus, Ph.D
Ann Vergales, ACSW, LSW, BCD
Lisa R. Paponetti. MA
Chrissi Hart, Ph.D.
Gregory Plotica, MA
CUSTODY EVALUATION
ROBERT S. COWMAN vs. LORRAINE R. COWMAN
NO.2001-5962 CIVIL TERM
Referred By: Mutual consent of the parties
Referral Reason: To conduct a comprehensive custody evaluation and to make recommendations
regarding the most appropriate custodial arrangements for Kathleen Ryder
Cowman, DOB 11113/94, and Peter Thomas Cowman, DOB 12/23/97
Individual Interviews:
Robert Cowman
Lorraine Cowman
Kathleen Cowman
Peter Cowman
3/28/03, 5/7/03, 5/28/03, 6/2/03
3/25/03, 5/8/03, 5/23/03
6/4/03, 7/1'103
6/4/03, 7/1103
Psychological Testing:
Minnesota Multiphasic Personality Inventory-2 (MMPI-2)
*Robert Cowman
*Lorraine Cowman
Bricklin Perceptual Scale (BPS)
*Kathleen Cowman
Home Study: Each parent's residence was evaluated for safety t;oncerns and the children were
observed interacting with each parent in the homt: environment
Parent-Child Interaction: The children were observed interacting with each parent in the office
setting
Additional Information: 1. Memorandum of Understanding between 80 b and Lorraine
regarding the custodial arrangement for the children
2151 Linglestown Road, Suite 200 . Harrisburg, Pennsylvania 17110 . (717) 540-1313 . Fax: (717) 540-1416
Cowman v. Cowman
Page 2
2. School Records for Kathleen CO\vman from Shaeffer Elementary
School
3. Therapy notes on Kathleen from Danielle Drydan of Guidance
Associates
4. Therapy notes for Lorraine Cowman from Guidance Associates
5. Letter dated May 30, 2003 to Mr. and Mrs. Cowman from Paul M.
Healey, Ph.D. regarding Kathleen's school attendance problems
6. Records for Lorraine Cowman from the Caron Foundation
7. Undated letter to Mr. and Mrs. Cowman from Paul M. Healey,
Ph.D. regarding attendance problems of Kathleen from Sept. 2, 02
to April 2, 03
8. Memo from Robert Cowman titl(:d "APROXIMATE HISTORY OF
LORRAINE COWMAN'S DRINKING SINCE 1993"
9. Memo from Robert Cowman titl(:d "WORK HISTORY OF
LORRAINE COWMAN SINCE 1993"
10. Letters dated May 21,2003, undated, June 4, 2003 and June 25
2003 from Lorraine Cowman to Dr. Shienvold
The recommendations at the conclusion of this report are based on all of these sources of
information.
Background:
Robert and Lorraine Cowman currently are sharing the physical and legal custody of their
two children, Kathleen and Peter. Lorraine has physical custody from either Saturday at
noontime, or Sunday at 6:00 P.M. until Wednesday and Robert has physical custody from
Wednesday until either Saturday or Sunday. That particular ar:angement has been in effect since
November, 2002. Prior to that, they briefly used a somewhat different shared arrangement.
Lorraine and Robert have been physically separated since November, 2002. However, Robert
had filed for divorce in October of the previous year.
It is Robert who has filed for a change of custody, although Lorraine stated that she, too,
would prefer that the arrangement be changed. Robert is seekiGg primary physical custody. He
believes that he is "more suited" to be the primary custodian because he has been "the rock of the
Cowman v. Cowman
Page 3
fanilly, steadily employed who adds stability that Lorraine does not have." However, Robert also
believes that it is important for the children to have both parents available and would be amenable
to a shared custodial arrangement if Lorraine were healthy enough to handle one.
Robert feels the children's best interests are served by living primarily with him. He
reported that Lorraine is an active alcoholic who has a long history offailed attempts at
rehabilitation. In fact, according to Robert, it was Lorraine's us,e of alcohol that caused him to
eventually file for divorce. Robert stated that prior to his marriage to Lorraine he was unaware of
the extent of her drinkiGg. However, upon returning from their honeymoon, and ever since, there
have been a series of incidents with regard to drinking that have interfered with the marriage.
Robert noted multiple therapies, interventions, rehabilitation attempts and legal difficulties
throughout the marriage.
As a function of her drinking, Lorraine has been unable 1to maintain stable employment.
Robert noted that Lorraine's work history is replete with her leaving jobs, being fired and periods
of unemployment. He noted that there was a brief time period when Lorraine was a stay-at-home
mother by choice, but the other times were a result of post-recovery therapies, or firings
secondary to her drinking.
Robert stated that although he thought that Lorraine had been sober for the past year and
a half, he did not trust that she could remain sober, and therefore was leery about the ability to
maintain a shared custodial arrangement. However, Robert reported that Lorraine is a good and
capable mother when she is not drinking.
Lorraine believes that she should become the primary physical custodian of the children
and the sole legal custodian. In fact, Lorraine is of the opinion that Robert should be allowed
supervised visitation, only. Lorraine claimed that Robert leaves the children unattended when he
has custody of them. She stated that he verbally and physically abuses the children. For example,
Lorraine stated that Robert has called Kathleen "a fucking bitch." She alleged that Robert has
choked her in front of the children and that he has shoved and pushed her. Lorraine reported that
the police were called to their home in the past.
Lorraine reported that Robert physically abused Kathleen last year. At the time he was
"verbally attacking the children" at bedtime. He appeared to be angry and "grabbed Kathleen,
pulled her and was going to pull her over the stair rail." Lorraine called 911. Lorraine indicated
that the children have become frightened of their father and are intimidated by him. According to
Lorraine, Robert would threaten to kick her out of the house, talce all the money and gain custody
of the children.
Lorraine stated that she and Robert know that the children would prefer to live with her.
She reported that since the separation the children are "going downhill." Lorraine stated that
Kathleen's grades have been declining and she is reporting that her stomach hurts. Kathleen is
Cowman v. Cowman
Page 4
frequently tired and tries to go to sleep before having to go to h:r father's house. Lorraine
complained that Robert prefers to play golf than to be with the c:hildren. She also stated that he
does not supervise them closely enough when he has them in his custody.
On the other hand, Lorraine feels that she has always been the primary provider of care for
the children. She perceives herself as the parent who provides the children with their emotional
security. Lorraine feels that she is the nurturing parent who is a,ctive in the children's lives.
History:
Robert and Lorraine met in 1992 and after dating for a year, they married on November
13, 1993. Robert feels that he may have ignored the red-flags be noticed about Lorraine's
drinkiGg. Lorraine felt that Robert was "bold" and rushed her irlto marriage. Robert indicated
that he knew that Lorraine had a DUI that pre-dated their marriage, but he did not see her as an
alcoholic.
Robert and Lorraine wanted children, but Kathleen was not a planned pregnancy.
Lorraine admitted that she is a binge drinker who was drinking fairly heavily at the time she
became pregnant. Lorraine pointed out that Rob also drank a considerable amount during the
marriage. Nonetheless, Lorraine was able to remain abstinent during the pregnancy. Lorraine did
not feel that Rob was supportive of the pregnancy. She stated that he is "addicted to golf," and
would frequently leave her alone. Rob stated that Lorraine was in intensive out-patient
counseling at the time of the pregnancy. The labor and delivery of Kathleen went well and the
baby was healthy.
According to Rob, by January following Kathleen's birth, Lorraine was drinkiGg again.
Lorraine was working part-time and Rob's job at PHI CO was eliminated so he had returned to
working at the State Senate. Lorraine indicated that the reason she returned to work was because
of increased debt and the loss of Rob's job. Lorraine pointed out that the marriage was "weird"
because his mother lived in the house with them. Problems were mounting on both sides. Rob
was increasingly concerned about Lorraine's drinking and Lorraine was upset that Rob only cared
about playing golf
While Lorraine reported that Peter's pregnancy was plarned, Rob stated that he was
surprised by the pregnancy. Rob stated that he thought that Lorraine was taking birth control.
He was in counseling at the time secondary to the marital problems and Lorraine's drinkiGg.
Lorraine stated that the marriage was "rotten" at that time, but she hoped that a second child
would "save" the marriage. Lorraine was abstinent from drinking during the second pregnancy.
She complained that Rob was never at home and seemed disinterested in her pregnancy. Lorraine
admitted that she continued to drink heavily when she was not pregnant. She noted that after
Peter's birth her binge drinking was infrequent, but still occurred.
Cowman v. Cowman
Page 5
Lorraine went through the Caron Foundation progranGS on three separate occasions during
the marriage. She also had received a 2"d DUI during the marriage and was imprisoned for a
month. In July, 1998 Lorraine returned to Caron for 30 days. Rob attended a week long
program on co-dependency. Rob had high hopes of improvement, but became disillusioned when
Lorraine would not follow the post rehab recommendations. Lorraine returned to Caron in 2000
and following that she went to Evergreen, a half-way house. She indicated that she resented
going there because, "Rob forced me to go and he manipulated 1the counselors." Rob continued
seeing a counselor on a regular basis. He noted that when Lorraine was doing "well," she would
stop working her program and would eventually relapse.
Rob admitted that there was probably a time in the marriage when he golfed too much and
ignored Lorraine. However, he felt that after Peter's birth he tried to change his behavior and do
joint activities that were "healthy." For example, they joined a bowling league together and they
began to go to a Church study group. He felt that he was constantly trying to encourage Lorraine
to do healthy activities. However, he would not agree to participate in marriage counseling until
she was sober for four to six months and she was actively involved in her recovery program.
Rob reported that in July of2001 he went on a trip to Wisconsin with Kathleen and his
mother. While away Lorraine relapsed again and her fanilly had to take Peter out of her care.
When he returned he asked Lorraine to leave the house, but she refused. They continued living
together. Rob reported that during that time there was an occasion when Lorraine was driving
intoxicated with the children. According to Rob, it took him a year to effectuate a separation.
Lorraine reported that she wanted a divorce because, "Rob was driving me to drink." She
indicated that she had her last drink on September 24,2001.
As a post-script, Lorraine had another relapse of drinking in May, 2003 during the
evaluation. She missed an appointment with the children during that time and initially lied as to
the reason for her cancellation. However, Lorraine subsequently admitted that she had relapsed
and that was the cause of her losing another job and delaying her appointments for the
evaluation. She swore that she was no longer drinking.
Lorraine Cowman:
Lorraine is a 40 year old woman who at the beginning of the evaluation was working as a
medical assistant at West Shore Fanilly Practice. However, during the course of the evaluation
Lorraine was released from that job and was unemployed. She reported that she was interviewing
for other jobs during the summer.
Lorraine was born and raised in Harrisburg. She has four siblings and her parents remain
together. Lorraine's father worked for the Department of Educ:ation and was an artist. Her
mother stayed at home with the children while they were grOwirLg up, but now works as a travel
agent. Lorraine described her mother as a strict Polish! Catholic woman who taught the children
Cowman v. Cowman
Page 6
about morals and "right from wrong." Lorraine's father was motivating and forgiving. He was
into art and music and stimulated those interests in the children. Lorraine was school phobic as a
child and always experienced anxiety. Lorraine feels that she had Attention Deficit Disorder as a
child that went undiagnosed. Although there is no history of alcohol abuse in her fanilly, Lorraine
has a sister who has been diagnosed as schizophrenic.
Lorraine presented as an extremely anxious, hyper worrum. Her speech was rapid and
pressured in all of her interviews. Lorraine had a very difficult time focusing on the topics being
discussed and frequently found reasons, regarding the topic, to say negative things about Rob.
Lorraine, eventually, was able to get her point across, but she m:eded to be re-directed by the
evaluator to do so. Lorraine missed an appointment during the time period when she relapsed and
drank alcohol. When she appeared for appointments, Lorraine was casually dressed and well-
groomed. She was able to maintain eye-contact with the interviewer and demonstrated good
social skills. Lorraine's affect varied during different sessions. At times she appeared somewhat
flat in affect. At other times, she appeared angry and excitable.
Lorraine's drinlcing and psychological history are signifi<:ant. Lorraine currently takes
Concerta for Adult Attention Deficit Disorder. She was diagnosed with ADD several years ago
and had been taking Ritalin. This diagnosis was confirmed during one of her three stays at the
Caron Foundation. Lorraine has been diagnosed at various time:s with Alcohol Abuse,
Generalized Anxiety Disorder and Attention Deficit Disorder. She has been treated with anti-
depressant medication for her anxiety and psycho-stimulants for the attentional problems.
Lorraine has made multiple attempts at treatment for her binge drinking. She is able to
admit that she is an alcoholic. According to Lorraine, she has been treated as an in-patient and
out-patient in the past with varying degrees of success. She has an AA sponsor and indicated that
she is attending AA meetings. A review of her various counseling and in-patient records suggests
that Lorraine has limited insight into her problems with addiction, which is probably part of the
reason that she has relapsed on so many occasions. When she r,elapses her judgement becomes
impaired. There is a relationship between the marital stress, the stress of the litigation and her
continued drinking. However, even in the current evaluation, Lorraine blamed part of her
motivation to drink on Robert, rather than taking full responsibility for her drinkiGg behavior.
She also appeared to lack insight into the consequences of that behavior on the care of the
children. Lorraine tended to blame all of the children's problems on Robert's behavior, rather
than recognize that her addiction was contributing to the problems of the children.
It is apparent from the history of the relationship that Lorraine provided the majority of
the primary care for the children. She had a very good understanding of their early development
and was able to discuss in depth all areas of their activities and physical well-being. Observations
of Lorraine with the children were positive. She lives in an attractive, two-bedroom apartment in
Camp Hill. The apartment is conveniently located for the children with respect to school and
friends. The children appear comfortable in the apartment and also appear very comfortable with
Cowman v. Cowman
Page 7
their mother. The family made cookies together in the kitchen. Kathleen and her mother are
obviously very closely attached. Lorraine worked to keep both children's attention on the task.
She was positive with them regarding their efforts at the task and the family talked throughout the
session. The nature of the conversation led to the conclusion that Lorraine is active in the
children's lives at school and at home.
Lorraine completed the MMPI-2. Her testing is valid, but suggests that she was vc;ry
defensive about responding to questions about psychological issues. Individuals with this test
pattern are generally trying to present themselves in an overly positive light. It is expected that
parents involved in custody litigation will take a more defensive stance, but Lorraine's profile is
relatively high, even for that population. That finding is consistl:nt with a genuine lack of
awareness regarding her behavior and its consequences. These women will likely use denial as a
primary defense when faced with stressful situations. Lorraine' Ii profile suggests that she is a high
energy woman, who has many goals and plans. However, given her problems with focus and
organization, completing those plans may create frustration for her.
Robert Cowman:
Robert Cowman is 45 years old. He works as an analyst/researcher for the Pennsylvania
Senate. He has worked in that position for a total of 13 years, although the time was separated by
a 5 year position with PHICO. He works from 8:30 A.M. to 4:30 P.M. fives days per week. He
occasionally has to work evenings, but that is very infrequent. Robert continues to live in the
home in which the fanilly resided. The home houses his mother" who is 91 years old. The house
is in need of interior and exterior maintenance. It was noted that the carpets were stained and the
floors in the kitchen were dirty.
Robert presented as well-dressed, softly spoken man who was cooperative with the
evaluation process. Robert was a relatively serious man who was concerned about his issues
being understood by the evaluator. He was able to display a normal range of affect during his
interviews. However, in general, Rob appears to be an individual who tends to over-control his
emotional responses. He displayed appropriate social skills and he was able to attend and
concentrate throughout the sessions.
Robert was raised in Camp Hill, Pennsylvania. Robert's father was an insurance agent
who died ofa brain aneurysm two weeks prior to Robert's birth. He has an older brother and
sister who live in Milwaulcee and California, respectively. Because of the large age difference
between him and his siblings, Robert grew-up as an only child. He recognizes that he was
probably spoiled by his mother who is now 91 years old and lives with him. Robert reported that
his mother did not show her emotions very much as he was growing-up. However, she taught
him a good value system.
Cowman v. Cowman
Page 8
With respect to the allegations by Lorraine about Robert's drinkiGg, he noted that he has
never been in any trouble, either work related or community rela.ted due to his use of alcohol. He
admitted that he drinks beer on occasion, especially after playing golf or in social situations.
Robert does not smoke cigarettes, but he will have a cigar while playing golf. Robert does not
use any illegal drugs. He currently takes the anti-depressant, Eflexor, because it helps him, "calm
down." He reported that he has times when he feels relatively "strung-out" as a function of all
that is going on in his life. In the past, Robert has taken Ativan to help him sleep.
Robert denied the allegations of physical and verbal abusl: that were made against him by
Lorraine. He noted that he has been investigated by CYS with unfounded results. Robert
admitted that there was an occasion when he did not keep close enough supervision of Peter and a
neighbor reported his action to the children agency. According to Robert, the case worker simply
told him to be more careful in the future.
Robert completed the MMPI-2. His profile is valid and does not show the level of
defensiveness that was noted in Lorraine's profile. Robert denies some common problems, but his
responses are within the expectations of an individual involved in this type of an evaluation.
Robert's profile is consistent with an individual who is experiencing situational stresses.
Individuals with this profile tend to be somewhat pessimistic, dissatisfied and demanding. They
can also appear to be whiny and somewhat self-centered. Similar men have a difficulty time
expressing their anger directly. Therefore, anger is likely to be displaced in a passive-aggressive
manner. A lack of insight into psychological issues may make this individual prone to
psychosomatic illness, especially during times of stress. Anxiety is a common symptom for these
individuals.
Robert was able to describe his children's personalities in te= that were similar to
Lorraine's. He was aware of Kathleen's academic skills and deficits and has been in contact with
the school about her attendance problems. Robert also spoke about issues related to Peter's
daycare attendance and fears about his needs for socialization and consistency. Therefore, Robert
seemed to have an understanding of important developmental themes for his children and was
attempting to set goals for the children that were consistent with their needs.
Interactions between Robert and the children, both within the office and home settings,
were disturbing. In each of these situations the children were openly disrespectful and disobedient
with their father. In the office, Peter called his father an "idiot," and kept repeating the phrase.
When their father would name something that they all did together, the children would either deny
it, or say it was not fun. Peter told his father, "I told Dr. Shienvold that you hit me with the belt
because I want to live with mom." Kathleen stated that her father lied. She was unable to
provide an example of his lying and she was unable to recall when her father had hit her brother
with a belt. Robert did not know how to deal with these statements from his children.
Cowman v. Cowman
Page 9
A similar situation occurred in the home observation. NI:ither of the children would listen
to their father as he made requests of them. Kathleen consistently told him, "No!" as he would
ask her to participate in activities with him. Peter followed his sister's lead and also was reluctant
to participate in an activity with his father. Robert attempted to place some limits on the children,
but it was obviously difficult and not particularly successful. Robert did not lose his temper or
show a lot of frustration during the visits. He attempted to deal with the problems verbally, but
was unable to create behavior change.
Kathleen Cowman:
Kathleen is 8 years old and is in the third grade at Shaeffer Elementary School. Her father
describes her as "bright, confident, head-strong and competitive.." Lorraine stated that Kathleen is
a quiet child who is very athletic. Lorraine believes that Kathleen is depressed because she bites
her finger nails and cries in the morning. Robert noted that Kathleen does not appear to be as
happy as she used to be, or as other kids. As noted, Kathleen is bright, but her grades have
suffered, perhaps because she is distracted and perhaps because she has missed so many days of
school. Letters from the principal of the school indicated that the school is concerned about the
number of absences and tardiness that Kathleen has experienced.
Kathleen appears to do well with her peers. The teachers have indicated that she is well-
liked at school. According to Rob, the only individuals with whom Kathleen is disrespectful are
he, his mother and Peter. Kathleen is in excellent health. She plays on a soccer team and a
basketball team. Kathleen also enjoys swimming and, occasionally, plays golf with her father.
KatWeen's sleep appears to be good. She experiences no nightmares or night terrors.
Kathleen was initially interviewed when her father brought her to the office. She stated
that she was 8 years old. Kathleen reported that she does not lil~e school because her teachers are
too strict. Kathleen spontaneously reported, "My dad thought my mom was sick all the time. She
wasn't sick and doesn't get sick." It should be noted that this particular interview occurred days
after Lorraine had been drinking and Kathleen had missed school because she was "taking care of
her mother and brother."
Kathleen stated that her father use to yell at her mother "all the time." She stated that her
father was no longer allowed in her mother's home. According to Kathleen, her mother never
yelled at her father, even though she also stated that she could not overhear the arguments.
Kathleen was aware of the custody schedule. Kathleen was able to report that her father was
good at helping her soccer coach.
KatWeen indicated that her mother is "scared" of her father. She stated that her dad is
"always hurting us. He pulls us away from the door." According to Kathleen, on one occasion
her father pulled her arm when she was going upstairs. Kathleen stated that her mother does not
want her to see her father. She reported that her mother and father do not like one another. She
Cowman v. Cowman
Page 10
gets angry about that because it means that she has to go back and forth. However, her mother
told her that when she gets a new husband she will not have to go back and forth between houses.
Kathleen is convinced that her father will marry a mean person because he is mean and yells at
her.
According to Kathleen, her father never does anything with her and her brother. She
stated, "Dad never plays games with us, never watches television (unless it is golf), and never
takes us for ice cream." Kathleen admitted that he goes to her soccer games, "but that's not fun."
Kathleen admitted, upon confrontation, that her father has played games with them, watched
television with them and taken them to the movies. However, she defensively stated, "We went
to the movies 20 times with my mom." Kathleen went on to report that her mother does
everything with her.
Kathleen reported that she had missed her last appointment, which was scheduled for her
mother to bring her to the office, because her mother was "sleeping." She stated that her mother
sometimes falls asleep before she does. On those occasions, she and Peter stay-up late and are
able to watch television and eat candy. Kathleen admitted that she is sometimes tired at school
because she stayed up too late.
At her second interview, Kathleen tended to repeat many of the things she had previously
stated. Kathleen stated that her father does very little with her, but her mother does a lot with
her. Kathleen reported that she frequently goes to sleep after her mother and awakens before her.
She noted that when her mother is "sick" she sleeps a lot. Kathle:en stated that her father allows
her to call her mother whenever she wants. However, at her mother's house, she is not allowed
to call her father. According to Kathleen, she does not miss her lather when she is at her mother's
house, and she does not think about calling him. Kathleen stated that her life was more fun when
her parents lived together.
Kathleen completed the BPS. On that instrument, the profile is completely skewed
towards mother. She scored 29 items in her mother's direction, one in her father's direction and
there were two ties. Given the nature of the attitude and feelings that Kathleen expressed in her
interviews, it is somewhat surprising that she scored her father higher in any category, or that he
tied in any category. The profile is a reflection of the bias that Kathleen is showing and the initial
stages of alienation from her father.
Peter Cowman:
Peter is five years old and will begin kindergarten this year. His mother and father
describe Peter as happy-go-lucky and fantastic. He is constantly singing and is capable of
entertaining himself. Rob sees him as "softer" than Kathleen. He is more affectionate and more
accepting of both parents than is Kathleen. Lorraine reported that Peter has "good and bad days."
She reported that Peter is resistant at transitions to Rob's house and sometimes appears confused.
Cowman v. Cowman
Page II
Peter has been in the preschool at Oakwood Baptist Church. He had been going there for
approxIDGately a year at the time of the evaluation. Rob accused Lorraine of breaking Peter's
routine at school by keeping him home after she lost her job. He feels that caused problems for
Peter. Peter does well socially. He has friends at school, but also can be independent. Peter has
some allergies, but in general his health is good. Rob reported that Peter is difficult to get to bed,
but then sleeps well at his house. Lorraine reported that Peter does not sleep well for her.
According to Lorraine, Peter gets-up each morning saying that he had a nightmare.
Peter was initially interviewed when his father brought him to the appointment. Peter
entered the interview area and stated, "Daddy is mean to us. H(: spanked our butts with a belt
when I was 3 years old." Peter went on to state that his father yelled at him "six times for no
reason." When asked if his father does anything fun for him, he responded that his father "copy-
catted my mommy." Peter admitted that his father played soccer with him, took him to see
Thomas the Train and took him swimming. However, he added that "Rob" has a "stinky house."
Peter stated that his mother calls his father an idiot. He also stated that his mother has
told him that he "doesn't want to be with Rob." She has also told Peter that "Rob" is mean.
According to Peter, his mother told him that his father slapped h~s face when he was one year old.
Peter reported that his mother gets sick and he and his sister have to stay home to "take care of
her." They help her by letting her sleep.
At Peter's second visit, when his mother brought him, Peter was equally negative about
his father. He stated that his father calls his mother an idiot when he is with him. Peter
spontaneously stated, "I want to live with my mom." He then reported that his mother told him
to say that. Peter indicated that his mother "reminded me" of things to say at the appointment.
Peter then stated that his father never does anything fun with binl, "all he does is play golf" Peter
also reported that he was going to start school, but that his mother did not want him to go
because she wants to be with him.
Recommendations:
Rob Cowman is interested in maintaining, at least, shared custody of Kathleen and Peter.
He is very concerned about the lack of stability at Lorraine's horne, especially as a function of her
alcohol abuse. Lorraine Cowman feels that she should have prin1lll')' physical custody of Peter and
Kathleen. She also feels that Robert should only be allowed sup,:rvised access with the children
because he is "neglectful" when the children are with him.
There is no question that Lorraine has a serious drinking problem and that she admits to
being an alcoholic. Lorraine's alcoholism is not controlled at this time. She admitted to a
drinking episode during the course ofthe evaluation. It is a likely hypothesis that the children's
statements about their mother being "sick" and "sleeping," are related to a drinking episode.
Lorraine has attempted to "cover-up" those episodes or deny them.
Cowman v. Cowman
Page 12
However, in doing so she is demonstrating very poor judgement with respect to the children.
Lorraine was extremely negative about Rob and his relationship with the children.
Regardless of the topic or conversation she would find something derogatory to say about Rob's
interactions with the children. Apparently she shares that type of thinlcing with the children.
Peter was very candid about his conversations with his mother regarding his father's behavior. It
is believed that similar conversations took place between Kathleen and her mother. Lorraine's
attempts at influencing her children's feelings about their father are blatantly obvious and
inappropriate.
Lorraine appears to be very insecure and anxious, in general. There is no question that
she was the parent who was primarily responsible for the children during the marriage. Rob
admits that when she is sober she is a very good, nurturing mother. Therefore, the children are
more emotionally attached to their mother than their father. Rob was generally less involved with
the children. He is not as smooth in his parenting style as Lorraine, as noted in the observations.
However, he is also trying to deal with children who have been intentionally influenced to act
badly around him.
The combination of these issues regarding the parents makes a recommendation regarding
a parenting plan very difficult. It is impossible at this time to recommend that Lorraine be given
primary physical custody of her children. The fact that she is actiively drinking, or was so at the
end of May of this year, means that the children have been in her care when she is not in control
of herself. Actually, it makes it difficult to recommend that she continue to maintain shared
physical custody.
On the other hand, Rob does not possess the skills as a parent that Lorraine possesses. He
is slow to react to the children's behavior and does not appear to be very good at setting limits.
Rob is not as nurturing with the children as is Lorraine and he does not interact with them as
actively, or as naturally as their mother. He needs additional pradice, support and education in
dealing with the children in order to work more comfortably with them. Rob especially needs
assistance in dealing with the disrespect and disobedience that he is experiencing when the
children come from their mother's home.
It is recognized that both children are more aligned with their mother because she has been
their primary source of security all of their lives. The children reported that their mother was
always available to them while there father was frequently away from the home. Additionally, in
spite of the fact that Rob complained about Lorraine's alcohol abuse throughout the lives of the
children, he continued to allow her to care for the children while he frequently involved himself in
his work and golf
In many ways, Lorraine is the key to a successful parenting arrangement which will create
the healthiest situation for the children. First of all, Lorraine needs to become totally abstinent
Cowman v. Cowman
Page 13
from her use of alcohol. Fortunately, nothing has happened rec,ently that has endangered the
physical safety of the children secondary to her drinkiGg. However, Kathleen missed school and
fell behind academically, in part, as a function of her mother's drinkiGg. Peter's attendance at
preschool was also affected. She cannot be in charge of the children and allow them to miss
school due to her inability to function.
Secondly, Lorraine needs to support the relationship of the children with her father. To
date, she has been working to undermine that relationship rather than reinforce it. Even if she was
physically and emotionally healthy, that behavior is extremely inappropriate. It leads to a sense of
alienation on the part of the children. Lorraine needs to recognize the importance for the children
of their relationship with their father. Her judgement with respect to that behavior is extremely
poor. What makes this factor more significant is the fact that Lorraine's drinking makes Rob's
involvement with the children more important and necessary. To set-up the children to be fearful
of, or dislike their father when it is essential that he care for them shows extremely poor
judgement and self-centered behavior.
Lorraine's insecurity and anxiety are affecting her judgement about the children in a
negative way. In order for Lorraine to maintain shared custody of the children she needs to be
alcohol free and supportive of the relationship of the children with their father. With respect to
the first issue, she must involve herself in her individual program to work with her anxiety and her
drinkiGg. Secondly, it is part of Lorraine's responsibility to ensure that the children are not
alienated from their father. Therefore, she and Rob must work 1I,ith the children and with a fanilly
therapist to mutually support the relationships of the children with each of them. Inherent in this
recommendation is the fact that both children need to be actively involved in counseling. They are
both negatively affected by the conflict that surrounds them.
Rob needs to continue his individual counseling. He reported that he has taken several
parenting courses during the past year. He could benefit from a parenting "coach" who could
work with him, directly with the children, so as to give him on the spot training and advice in
dealing with the children. That would be a specialized type of therapy tailored for his needs with
the children.
If all parties are in agreement with this plan, and if Lorraine is alcohol free, the shared
custodial arrangement should be continued. If, however, Lorraine is unable to maintain her
sobriety, or ifshe is unwilling or unable to support the relationship of the children with Rob, then
it is recommended that the children be primarily with their father until Lorraine is able to meet the
requirements to help the children. Furthermore, if Lorraine remains active in her addiction, her
time with the children should be supervised.
Date
f/I? /0;
~J .~r-' 0 0
Arnold T. Shienvold, Ph.D.
EXHIBIT C
(Recommendation of Dr. Shienvold dated FClbruary 23, 2004)
~\1 Riegler. Shienvold
,.11 8/ Associates
February 23,2004
Elliot Riegler. Ph.D. (1948-1999)
Amold 1. Shl~nvold. p'h.D.
Melinda Eash, MS
James Eash. LSW
Bonnie Howard, Ph.D.
Amy K. Keisling, ACSW, LCSW, BCD
Tracy Richards, QCSW. LCSW
Dyanne Sage. QCSW. LCSW
Jeffrey Pincus, Ph.D.
Ann Vergales, ACSW. LSW, BCD
Lisa R. Paponelti, MA
Chrissi Halt, Ph.D.
Gregory Plotica. MA
Kasey Shicnvold, Psy.D.
Shanen Turk-Geller, LSW
Harvey H. Shapiro. MD
Michael L. Bangs, Esquire
302 South 18th Street
Camp Hill, PA 17011
Elizabeth Beckley, Esquire
P.O. Box 11998
Harrisburg, P A 17108-1998
RE: Lorraine Cowman
Dear Attorneys,
I have had an opportunity to meet with Lorraine Cowman, Additionally, I have
interviewed her treating physician, Dr. Chris Davis, at New Insights and I have met directly with
him. Lorraine and Dr. Davis have informed me of the history of Ms. Cowman's addiction since
September 9, 2003. It is my understanding that Ms. Cowman has undergone an in-patient
rehabilitation stay, an extensive and intensive out-patient treatment with New Insights and is now
involved in a consistent out-patient treatment regiment. Additionally, Ms. Cowman is regularly
attending AA meetings. She has a sponsor and Dr. Davis is receiving inGmediate feedback as to
her continuing participation in meetings.
Given the extensive nature of her treatment, and given the fact that she has not suffered a
relapse in the last six months, I believe that Ms. Cowman is capable of beginning unsupervised
access with her children. To that extent, it is recommended that Ms. Cowman begin
unsupervised visits with the children every Tuesday and Thursday evening from after school until
8:00 p.m. Additionally, it is recommended that for the next four weekends, Ms. Cowman
alternate having the children either Saturday or Sunday from 12:00 p.m. to 8:00 p.m. Assuming
those visits go without incident and that Ms. Cowman continues her participation in her
rehabilitation/treatment program, the weekend visits could become alternate weekends from
Saturday morning until Sunday evening.
215\ Linglestown Road, Suite 200 . Harrisburg, Pennsylvania 17110 . (717) 540-1313 . Fax: (717) 540-1416
Page 2
RE: Lorraine Cowman
I am hesitant to recommend anything further at this time. It will be necessary to assess
everyone's adjustment to the changes that are being made and then make further
recommendations. Dr. Davis has assured me that he would provide on-going feedback regarding
Ms. Cowman. He also stated that he considers himself a mandated reporter of children's welfare
and would feel obligated to inform me if Ms. Cowman was drinlcing again.
If you have any questions regarding the current approach" please do not hesitate to contact
me. I have written this letter prior to Robert Cowman's appointment because of delays that have
occurred to date. If there is some change necessary secondary to Mr. Cowman's appointment, I
will write you a follow-up letter.
Sincerely,
fh'J f L~,~ef
Arnold T. Shienvold, Ph.D.
EXHIBIT D
(Letter of Dr. Shienvold dated March 8, 2004)
~
Riegler. Shienvold
&'Associates
Elliot Riegler, PhD. (1948-1999)
Amold T. Shi<;jlvold. PJo.D.
Melinda Eash, MS
James Eash, LSW
Bonnie Howard, Ph.D.
Amy K. Keisling, ACSW, LCSW, BCD
Tracy Richards, QCSW, LCSW
Dyanne Sage, QCSW, LCSW
Jeffrey Pincus, Ph.D.
Ann Vergales, ACSW, LSW, BCD
Lisa R. Paponetti, MA
Chrissi Hart, Ph.D.
Gregory Plotica, MA
Kasey Shienvold, Psy.D.
Shanen Turk-Geller, LSW
Harvey H. Shapiro, MD
March 8, 2004
Michael L. Bangs, Esquire
302 South 18th Street
Camp Hill, PA 17011
Elizabeth Beckley, Esquire
P.O. Box 11998
Harrisburg, P A 17108-1998
Dear Attorneys,
As noted in my previous letter to you, there was a possibility that I would change my
recommendation regarding unsupeI"Yised access for Lorraine Cowman after speaking with Robert
Cowman. During my interview of Mr. Cowman, it was noted that Lorraine missed two
appointments with her children two weeks ago. She told Mr. Cowman that she had gone to a
funeral of a friend in Florida. He was suspicious of her story, as was 1.
Subsequently, I spoke with her Dr. Davis who indicated to me that Lorraine had told him the
~ st9ry. I ~ue~@ v~fit,:;l.tiC!Il ()f~ ~tQry \).y sh9wing rne ~:ither receiptS for h~r pllll1~
tickets, or the tickets, themselves. Lorraine Cowman then called me arid admitted that she had
not gone to Florida. She reported that she needed a "break" from all of the pressure and simply
told everyone she was out of town.
I cannot substantiate whether or not Mrs. Cowman was drinlcing during that time, but I am
extremely uncomfortable with the fact that she lied about her whereabouts and decided not to
take her access time with her children. Therefore, I am rescinding my previous recommendation
and recommending that supervised access continue until further notice.
If you have any questions regarding this change, please feel free to contact me.
Sincerely,
{;~ y; ~
Arnold T. Shienvold, Ph.D.
2151 Linglestown Road, Suite 200 . Harrisburg, Pennsylvania 17110 . (717) 540-1313 . Fax: (717) 540-1416
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ROBERT S. COWMAN
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
01-5962 CNIL ACTION LAW
LORRAINE R. COWMAN
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Wednesday, May 12, 2004
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq.
at 301 Market Street, Lemoyne, PA 17043 on Tuesd.ay, June 15, 2004
, the conciliator,
at 8:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to 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 hearin2.
FOR THE COURT.
By: Isl
Melissa P. Greevy, Esq.
Custody Conciliator
mhc
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. IF YOU DO NOT
HA VB 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
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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JUN 2 1 2004 '( ~)
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-5962 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
ROBERT S. COWMAN,
v.
LORRAINE R. COWMAN,
Defendant
TEMPORARY ORDER OF COlJm
AND NOW, this Lv....... day of June, 2004, upon consideration of the attached
Custody Conciliation Summary Report, it is hereby ordered ~lI1d directed as follows:
1. Phvsical Custodv. The Father shall have primary physical custody of the
minor children, Kathleen Cowman, born November 13, 1994, and Peter Cowman, born
December 23,1997.
2. During the Summer school recess, Mother shall have periods of supervised
visitation each Tuesday and Thursday evening from 2:30 p.m. to 8:30 p.m. and each
Sunday from 2:30 p.m. to 7:30 p.m. During the school year, Mother's visits on Tuesdays
and Thursdays shall be from 5:30 p.m. to 8:30 p.m. Supervised visitation means that
another competent and agreed upon adult shall be presEint continuously throughout any
period of visitation with Mother as described herein. Persons who may serve as supervisors
of Mother's visitation shall include the following: Ed Reed, Deb Reed, Mike Reed, Tom
Ross, Marlene Ross, Steve Quinn. Each Sunday at the conclusion of her visit, Mother will
provide Father with advance notice of who the supervising adults will be for the visits to
occur within the next seven (7) day period. In the eve,nt that there is no supervision
available, no visit shall occur.
3. TransDortation. During the week of June 28, :2004 through July 2, 2004, when
Kathleen is at soccer camp, Father will provide transpolrtation for Kathleen to Mother's
residence at the beginning of her period of custody. Father will provide all transportation
incident to the Sunday custodial periods. Otherwise, Mother will provide transportation at
the beginning of her Tuesday and Thursday custodial periods and Father will provide
transportation at the conclusion of those periods. The parties will make the children
available for the custodial exchanges in a timely fashion and in accordance with the agreed
upon schedule delineated above.
4. Counsel for Father will provide counsel for Mother with information regarding
the drop off time for the conclusion of the Messiah College soccer camp and with the phone
number, location and itinerary for Kathleen's summer trip to Ocean City and Virginia Beach.
It shall be permissible for Kathleen to accompany her friend, Abigail, on Abigail's the family
NO. 01-5962 CIVIL TERM
vacation with her Father, Chip Wenger and her mother, Daphne Wolfkill, during that period
from July 16, 2004 through July 28,2004.
5. In the event that Father elects to take vacation during the Summer 2004, his
counsel will notify Mother's counsel of his vacation plans, duration, intended destination,
telephone number during the vacation, and intended return date.
6. During any period of custody or visitation the Father shall not possess or use
controlled substances, neither shall he consume alcoholic beverages to the point of
intoxication. He shall ensure to the extent possible that other household members and/or
house guest comply with this prohibition.
With regard to Mother, for a period of twelve (12) hours before and continuing
throughout any period of supervised visitation or partial custody with the minor children,
Mother shall consume no alcoholic beverages nor possess or use controlled substances
whatsoever.
7. The Custody Conciliation Conference shall reconvene on August 9,2004
at 10:30 a.m. at the office of the Custody Conciliator, lIIIelissa Peel Greevy, Esquire,
301 Market Street, Lemoyne, PA 17043. ~/
BYTH~J
J.
Dls!: ~~ L. Bangs, Esquire, 429 S. 18" Street, Camp Hili, PA 17011 .
r~in L. Markley, Esquire, 2108 Market Street, Camp Hili, PA 17011 >-
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ROBERT S. COWMAN,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 01-5962 CIVIL TERM
v.
CIVIL ACTION - LAW
LORRAINE R. COWMAN,
IN CUSTODY
Defendant
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 subject of this
litigation is as follows:
NAME
DATE OF BIRTH CURRI:NTL Y IN THE CUSTODY OF
. Kathleen Cowman
Peter Cowman
November 13,1994 Father
December 23,1997 Father
2. A Custody Conciliation Conference was held on June 14, 2004 following
Father's May 5, 2004 filing of a Complaint for Custody. Present for the conference were:
the Father, Robert S. Cowman, and his counsel, Michael L. Bangs, Esquire; the Mother,
Lorraine R. Cowman, and her counsel, Marlin Markley, Esquire.
3.
attached.
~/0/o Lj
'Date/.
The parties reached an agreement as to a Temporary Order in the form as
LMa{j-~l
Melissa Peel Greevy, Esquire
Custody Conciliator
:230693
I'
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JUN 2 1 2004 r
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-5962 CIVIL TERM
CIVIL ACTION - LAW
ROBERT S. COWMAN,
v.
LORRAINE R. COWMAN,
IN CUSTODY
Defendant
TEMPORARY ORDER OF COURT
AND NOW, this (). ~ day of June, 2004, upon consideration of the attached
r"c:t"rlv r."n"iliAtinn Summarv Report, it is hereby ordered and directed as follows:
CUMBERLAND COUNTY
COURT ADMINISTRATOR
ONE COURTHOUSE SQUARE
CARLlSLE,PA17013 ,.:. '-', i (.,-,illv'"
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7': 1 JJL -2
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MARLIN L. MARKLEY, ESQUIRE
2108 MARKET STREET
CAMP HILL PA 17011
OA 0 INSUFFICIENT ADDRESS
C 0 ATTEMPTED NOT KNOWN 0 OTHER
o NO SUCH NUMBER! STREET
S 0 NOT DELIVERABLE AS ADDRESSED
. UNABLE TO FORWARD
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NOV 0 1 2004 r
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 01-5962 CIVIL TERM
ROBERT S, COWMAN,
v,
LORRAINE R. COWMAN,
CIVIL ACTION - LAW
IN CUSTODY
Defendant
BAYLEY, J. ---
TEMPORARY ORDER OF COURT
AND NOW, this ~/{.-- day of November, 2004, upon consideration of the
attached Custody Conciliation Summary Report, it is hE~reby ordered and directed as
follows:
1.
Order,
This Court's Order of June 24, 2004 is VACATED and replaced with this
2, Leaal CustodY, The parties, Robert S, Cowman and Lorraine R. Cowman,
shall have shared legal custody of the minor children, Kathleen Cowman, born November
13, 1994, and Peter Cowman,. born December 23, 1997, 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 23 Pa. C,
S, ~5309, each parent shall be entitled to all records and information pertaining to the
children including, but not limited to, medical, dental, religious or school records, the
residence address of the children and of the other parent. To the extent one parent has
possession of any such records or information, that parent shall be required to share the
same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parf~nt.
3, Physical CustodY, Father shall have primary physical custody of the minor
children subject to Mother's rights of partial custody which shall be arranged as follows:
A. During the Summer school recess, Tuesdays and Thursdays
from 2:30 p.m, until 8:30 p,m,
B, During the school year, Tuesdays and Thursdays from
immediately after school until 8:30 p,m.
C. Effective October 30, 2004, on alternating weekends, from
Saturday at 9:00 a,m. until Sunday at 7:30 p,m,
NO, 01-5962 CIVIL TERM
3, Transportation, The parent receiving custody will be responsible for providing
transportation incident to the custodial exchanges, The parties will make the children
available for the custodial exchanges in a timely fashion and in accordance with the agreed
upon schedule delineated above.
4, Holidavs, The following holiday schedule supersedes the regular schedule:
A. Alternatina Holidavs, The parties willi alternate the following
holidays: Easter, Memorial Day, Independence Day, Labor Day and
Thanksgiving, beginning with Father having Thanksgiving 2004,
B. Christmas. Christmas shall be divided into two segments,
Segment A and Segment B, Segment A shall be from December 24th at 1 :00
p,m, until December 25th at 1 :00 p,m, Segment B sh,all be from December 25th
at 1 :00 p,m, until December 26th at 1 :00 p,m, In even-numbered years,
Mother shall have Segment A and Father shall hElve Segment B, In odd-
numbered years, Father shall have Segment A and Mother shall have
Segment B,
5, Mother will have custody on November 1, 2004 immediately after school until
the children are returned to school on Wednesday, November 3, 2004,
6, During any period of custody or visitation the Father shall not possess or use
controlled substances, neither shall he consume alcoholic beverages to the point of
intoxication, He shall ensure to the extent possible that other household members and/or
house guest comply with this prohibition,
With regard to Mother, for a period of twelve (12) hours before and continuing
throughout any period of supervised visitation or partial custody with the minor children,
Mother shall consume no alcoholic beverages nor posseiss or use controlled substances
whatsoever.
7, This Order is temporary in nature, If within ninety days of the date of this
Order an additional Conference is needed, counsel 1ither party may contact the
Conciliator by letter to request that the Custody Conei!' 1011 onference be reconvened,
BY THE OURT:
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Dist: ~gtlaell. Bangs, Esquire,429 S. 18th Street, Camp Hill, PA 17011
~rlin L. Markley, Esquire, 2108 Market Street, Camp Hill, PA 17011
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 01-5962 CIVIL TERM
ROBERT S. COWMAN,
v.
CIVIL ACTION - LAW
LORRAINE R. COWMAN,
IN CUSTODY
Defendant
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 subject of this
litigation is as follows:
NAME
DATE OF BIRTH CURR.ENTLY IN THE CUSTODY OF
Kathleen Cowman
Peter Cowman
November 13, 1994 Father
December 23, 1997 Father
2, A Custody Conciliation Conference was held on October 25, 2004 as agreed
by the parties at the June 14, 2004 Conference. Present for the conference were: the
Father, Robert S, Cowman, and his counsel, Michael L. Bangs, Esquire; the Mother,
Lorraine R. Cowman, and her counsel, Marlin Markley, Esquire,
3,
attached,
The parties reached an agreement as to a Temporary Order in the form as
/O/~5!oj
Date
~~
Meli~)sa Peel Greevy, Esq ire
Custody Conciliator
:238055
vs.
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
ROBERT S. COWMAN,
Plaintiff
CIVIL ACTION - LAW
LORRAINE R COWMAN,
Defendant
NO. 2001- 5962 CIVIL TERM
AFFIDAVIT OF CONSENT
Pursuant to Pa. RC.P. Rule 1920.72
1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on
October 16, 2001
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final Decree in Divorce either after service of a Notice of
Intention to Request Entry of the Decree.
I verify that the statements made in this Affidavit are true and correct. I understand that
false statements herein are made subject to the penalties ofl8 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
:3 ) ~:vlc6
Date
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ROBERT S. COWMAN
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vs.
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
ROBERT S. COWMAN,
Plaintiff
CIVIL ACTION - LAW
LORRAINE R. COWMAN,
Defendant
NO. 2001- 5962 CIVIL TERM
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees, or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the court
and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this Affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
3(30 ( be)
Dated
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ROBERT S. COWMAN
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Plaintiff
vs.
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
LORRAINE R. COWMAN,
Defendant
NO.200l- 5962 CIVIL TERM
AFFIDAVIT OF CONSENT
Pursuant to Pa. R.C.P. Rule 1920.72
l. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
October 16, 2001
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final Decree in Divorce either after service of a Notice of
Intention to Request Entry of the Decree.
I verify that the statements made in this Affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
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vs.
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
LORRAINE R. COWMAN,
Defendant
NO.200l- 5962 CIVIL TERM
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees, or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the court
and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this Affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
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ROBERT S. COWMAN
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
LORRAINE R. COWMAN
Defendant
CIVIL DIVISION
2001-5962
CIVIL TERM
NO.
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information to the court for entry of a divorce decree:
1. Ground for divorce:
Irretrievable breakdown under 93301 (c)
8~al:l*19>at1hexllil!OIl!:tlXX>li!l!.
(Strike out inapplicable section).
2. Date and manner of service of the complaint: Served upon Defendant on 10/24/01
by certified mail, restricted delivery, return receipt requested.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by 93301 (c) of the Divorce Code:
by plaintiff 3130/05 : by defendant 3/29/05
(b) (1) Date of execution of the affidavit required by 93301 (d)
of the Divorce Code:
(2) Date of filing and service of the plaintiff's affidavit upon the respondent:
4.
Related claims pending:
There are no outstanding issues.
5. Complete either (a) or (b).
(a) Date and manner of service of the notice of intention to file praecipe to transmit record, a
copy of which is attached:
(b) Date of plaintiff's Waiver of Notice in 93301 (c) Divorce was filed with
th P th t MAILED to Prothonotar:'t on 3131/05.
e ro ono ary:
Date defendant's Waiver of Notice in 93301 (c) Divorce was filed with
the Prothonotary: MAILED to Prothonotary on 3/31/05.
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Attorney for I' tiff I b)_feAoant
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IN THE COURT OF COMMON PLE
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OF CUMBERLAND COUNTY
-,
ROBERT S.
COWMAN
PENNA.
STATE OF
Plaintiff
No.
2001-5962 CIVIL
VERSUS
LORRAINE R.
COWMAN
Defendant
DECREE IN
DIVORCE
/'
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AND NOW,
, IT IS ORD
F1ED AND
ROBERT S.
COWMAN
, PLAINT F'F,
DECREED THAT
LORRAINE R.
COWMAN
, DEFEN
AND
P.'\NT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS W
ICH HAVE
BEEN RAISED OF RE~C1f.D INY-HIS ACTION
YET BEEN ENTERED;VO~
F'OR WHICH A FINAL ORDE
HAS NOT
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There are no outstanding issues.
ATTEST:& ~ l/
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ROBERT S. COWMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 2001-5962
LORRAINE R. COWMAN,
Defendant
CIVIL ACTION - AT LAW
IN CUSTODY
PETITION FOR MODIFICATION OF A PARTIAL CUSTODY ORDER
1. The petition of Lorraine R. Cowman respectfully represents on November 4,
2004, an Order of Court was entered for partial custody, a copy of which is attached.
2. This Order should be modified because:
a) petitioner desires to spend more time with the children;
b) the children spend a lot of time at baby sitters during respondent's periods of
custody;
c) the children desire to spend additional time with the petitioner;
d) it is in the children's best interest to modify the current custody order to allow
more custodial time with petitioner.
WHEREFORE, Petitioner requests that the Court modify the existing Order for
partial custody because it will be in the best interest of the children.
Respectfully submitted,
arliwL arkley, Esquire
LawOm es of Patrick F. Lauer, Jr., L.L.C.
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 84745 Tel. (717) 763-1800
Date: 5- / 1, l 00 ('
II
,-
ROBERT S. COWMAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 2001-5962
LORRAINE R. COWMAN,
Defendant
: CIVIL ACTION-AT LAW
: IN CUSTODY
VERIFICATION
I verify that the statements made in this PETITION FOR MODIFICATION OF A
PARTIAL CUSTODY ORDER are true and correct. I understand that false statements herein
are made subject to the penalties of 18 Pa.C.S. S 4904, relating to unsworn falsification to
authorities.
Date: 5 h 'I /c~-
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1-
ROBERT S. COWMAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 2001-5962
LORRAINE R. COWMAN,
Defendant
: CIVIL ACTION - AT LAW
: IN CUSTODY
CERTIFICATE OF SERVICE
I hereby certify that I am this day serving a copy of the foregoing PETITION FOR
MODIFICATION OF A PARTIAL CUSTODY ORDER upon the person and in the manner
indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil
Procedure, by mailing a copy of the same, certified mail, retum receipt requested, to the person
named as follows:
Michael L. Bangs, Esquire
429 South 18th Street
Camp Hill, PA 17011
Respectfully submitted,
Date:
C;-j0'2uo)'
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~arlif('itarkley:i~uire
2108 M ket Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 84745 Tel. (717) 763-1800
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ROBERT S. COWMAN,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 01-5962 CIVIL TERM
v.
CIVIL ACTION - LAW
LORRAINE R. COWMAN,
IN CUSTODY
Defendant
BAYLEY, J. ---
TEMPORARY ORDER OF COURT
AND NOW, this ~/{-- day of November, 2004, upon consideration of the
attached Custody Conciliation Summary Report, it is hereby ordered and directed as
follows:
1.
Order.
This Court's Order of June 24, 2004 is VACATED and replaced with this
2. Leaal Custodv. The parties, Robert S. Cowman and Lorraine R. Cowman,
shall have shared legal custody of the minor children, Kathleen Cowman, born November
13, 1994, and Peter Cowman, born December 23, 1997. 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 23 Pa. C.
S. 95309, each parent shall be entitled to all records and information pertaining to the
children including, but not limited to, medical, dental, religious or school records, the
residence address of the children and of the other parent. To the extent one parent has
possession of any such records or information, that parent shall be required to share the
same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent.
3. Phvsical Custodv. Father shall have primary physical custody of the minor
children subject to Mother's rights of partial custody which shall be arranged as follows:
A. During the Summer school recess, Tuesdays and Thursdays
from 2:30 p.m. until 8:30 p.m.
B. During the school year, Tuesdays and Thursdays from
immediately after school until 8:30 p.m.
C. Effective October 30, 2004, on alternating weekends, from
Saturday at 9:00 a.m. until Sunday at 7:30 p.m.
NO. 01-5962 CIVIL TERM
3. TransDortation. The parent receiving custody will be responsible for providing
transportation incident to the custodial exchanges. The parties will make the children
available for the custodial exchanges in a timely fashion and in accordance with the agreed
upon schedule delineated above.
4. Holidavs. The following holiday schedule supersedes the regular schedule:
A. Alternatina Holidavs. The parties will alternate the following
holidays: Easter, Memorial Day, Independence Day, Labor Day and
Thanksgiving, beginning with Father having Thanksgiving 2004.
B. Christmas. Christmas shall be divided into two segments,
Segment A and Segment B. Segment A shall be from December 24th at 1 :00
p.m. until December 25th at 1 :00 p.m. Segment B shall be from December 25th
at 1 :00 p.m. until December 26th at 1 :00 p.m. In even-numbered years,
Mother shall have Segment A and Father shall have Segment B. In odd-
numbered years, Father shall have Segment A and Mother shall have
Segment B.
5. Mother will have custody on November 1, 2004 immediately after school until
the children are returned to school on Wednesday, November 3, 2004.
6. During any period of custody or visitation the Father shall not possess or use
controlled substances, neither shall he consume alcoholic beverages to the point of
intoxication. He shall ensure to the extent possible that other household members and/or
house guest comply with this prohibition.
With regard to Mother, for a period of twelve (12) hours before and continuing
throughout any period of supervised visitation or partial custody with the minor children,
Mother shall consume no alcoholic beverages nor possess or use controlled substances
whatsoever.
7. This Order is temporary in nature. If within ninety days of the date of this
Order an additional Conference is needed, counsel ither party may contact the
Conciliator by letter to request that the Custody Concil' Ion onference be reconvened.
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Dis!: ~stlael L. Bangs, Esquire, 429 S. 181h Street, Camp Hill, PA 17011
~rlin L. Markley, Esquire, 2108 Market Street, Camp Hill, PA 17011
~
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-5962 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
ROBERT S. COWMAN,
v.
LORRAINE R. COWMAN,
Defendant
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 children who are the subject of this
litigation is as follows:
NAME
DATE OF BIRTH CURRENTLY IN THE CUSTODY OF
Kathleen Cowman
Peter Cowman
November 13,1994 Father
December 23, 1997 Father
2. A Custody Conciliation Conference was held on October 25, 2004 as agreed
by the parties at the June 14, 2004 Conference. Present for the conference were: the
Father, Robert S. Cowman, and his counsel, Michael L. Bangs, Esquire; the Mother,
Lorraine R. Cowman, and her counsel, Marlin Markley, Esquire.
3.
attached.
The parties reached an agreement as to a Temporary Order in the form as
/O/cA5!oj
Date
~?c!lL
Melissa Peel Greevy, Esq
Custody Conciliator
:238055
ROBERT S. COWMAN
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
01-5962
CIVIL ACTION LAW
LORRAINE R. COWMAN
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Thursday, May 26, 2005
, upon consideration of the attachcd Complaint.
it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. . the conciliator,
at_~aulove's, 1901 State St., Camp HiII,PA l701l on Thursday, July 07, 2005 at 9:00 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 define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT.
By:~__
Melissa P. Greevy, Esq.
Custody Conciliator
yo"
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For infonnation about accessible facilities and reasonable accommodations
available to disabled individuals having business bcfore the court, pleasc contact our of1ice. All arrangemcnts
must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-5962 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
ROBERT S. COWMAN,
v.
LORRAINE R. COWMAN,
Defendant
BAYLEY, J. ---
ORDER OF COURT
AND NOW, this -\"-- day of July, 2005, upon I~onsideration of the attached
Custody Conciliation Summary Report, it is hereby ordered and directed as follows:
1. This Court's Order of November 4, 2004 shall remain in full force and effect.
2. The parties will participate in an updated custody evaluation with Dr. Arnold T.
Shienvold. The updated evaluation will have as its purpose to determine whether an
expansion of Mother's custodial time is appropriate and if so to have a recommendation as
to the proposed schedule for such expanded time.
3. The expense of the updated evaluation will be borne by Mother.
4. The parties may make a request to return to Custody Conciliation without
petition if such request is made to the Conciliator within ten (10) da s of counsel's receipt of
the report from Dr. Shienvold. The request may be made di y to Conciliator via fax.
/./
BY THE
Dist:
Michael L. Bangs, Esquire. 429 S. 18" Street, Camp Hill, PA 17011 ~
Marlin L. Markley, Esquire, 2108 Market Street, Camp Hill, PA 17011 (6 hi. .
Dr. AmoldT. Shienvold, 2151 Linglestown Road, Harrisburg, PA 17110 '-" ~
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ROBERT S. COWMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-5962 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
v.
LORRAINE R. COWMAN,
Defendant
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 subject of this
litigation is as follows:
NAME
DATE OF BIRTH CURRENTLY IN THE CUSTODY OF
Kathleen Cowman
Peter Cowman
November 13,1994 Father
December 23, 1997 Father
2. Mother filed a Petition for Modification of a Custody Order on May 20, 2005. A
Custody Conciliation Conference was held on July 7, 2005. Present for the conference
were: the Father, Robert S. Cowman, and his counsel, Michael L. Bangs, Esquire; the
Mother, Lorraine R. Cowman, and her counsel, Marlin L. Markley, Esquire.
3. Mother's position on custody is as follows: Mother seeks more custodial time
with the children because she and the children desire to spl~nd more time together. Mother
also reports that the children spend a lot of time at the babysitter's while in Father's custody.
She reports that she has been sober in excess of three yelars. This summer, Mother and
Father have reached an informal agreement whereby she has custody of the children all
day on Tuesdays and Thursdays. This arrangement is understood to be effective during a
summer school recess.
4. Father's position on custody is as follows: Father is not willing to surrender
primary custody to Mother. He continues to report on90in9 communication problems
between he and Mother however he will agree to cooperate with Mother's request to haye
an updated custody evaluation to assess whether expanded time with Mother is
appropriate. His agreement to do so is contingent upon Mother's agreement to pay the
costs of the evaluation services.
NO. 01-5962 Civil Term
5. The parties reached an agreement to participate in an updated custody
evaluation at Mother's expense. The question to be answered in the evaluation is whether
an expansion of custodial time for Mother is appropriate and if so to obtain a
recommendation as to the proposed schedule. The parties, further agree the Order would
be forwarded to Dr. Shienvold and that once the evaluation was completed they would have
the option to request the Custody Conciliation confer~~nvene without petition if the
'"'"1 wa' m,de 7" (10) deys of the ",port "91"9 '''; to ""'tt
at ~;a Peel Greevy, Esq
Custody Conciliator
:254185
ROBERT S. COWMAN,
Plaintiff,
IN THE COURT Of COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 2001-5962
LORRAINE R. COWMAN,
Defendant,
: CIVIL ACTION - AT LAW
: IN CUSTODY
---------------------------------------------'-------------------
ROBERT S. COWMAN,
Plaintiff,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
Docket No. 459 SUPPORT 2005
: PACSES Case No. 212107407
LORRAINE R. COWMAN,
Defendant,
: IN SUPPORT
PRTTTTON TO WTTHnRA W APPRARANCR
TO THE HONORABLE JUDGES OF SAID COURT:
AND NOW, comes Petitioner, Marlin L. Markley, Esquire, and in support of his Petition to
Withdraw Appearance, respectfully represents as follows:
1. Petitioner is Marlin L. Markley, Esquire, an attorney with offices located at 2108
Market Street, Camp Hill, Pennsylvania.
2. Respondent is Lorraine R. Ross, a/k:/a, Lorraine R. Cowman who resides at 50
South 22nd Street, Apartment 4, Camp Hill, Pennsylvania.
3. Petitioner was retained by Respondent on or about March 25,2004, to represent her
in connection with her domestic relations matters.
4. A Complaint in Divorce was filed with this Honorable Court on or about October
16, 2001 thereby instituting the above-captioned action.
5. A Custody Complaint was filed with this Honorable Court on or about May 4,2004.
6. A Complaint in Support wasfiled with Honorable Court on or about June 7, 2005.
7. Petitioner anticipates that there will be prolonged proceedings in all of the above
matters.
8. On October 3, 2005 Petitioner received, from Respondent, written termination of his
legal services to Respondent. (See attached Exhibit "A").
9. Petitioner has at all times attempted to represent Respondent effectively and
vigorously to the best of his ability.
10. Petitioner asks to withdraw his appearance for Lorraine R. Ross, a/kla, Lorraine R.
Cowman because, inter alia:
a. Respondent has requested that Petitioner terminate all further legal services
regarding Respondent's case.
b. Continued representation will result in an unreasonable financial burden on
Petitioner.
WHEREFORE, Petitioner respectfully requests that his appearance be withdrawn for
Respondent and that he be removed from the docket as the attorney of record for Lorraine R. Ross,
aJkIa, Lorraine R. Cowman.
Respectfully Submitted:
-'7
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Date: October 25, 2005
Marlin L.
2108 Marke treet, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 84745 Tel. (717) 763-1800
Attorney for Plaintiff
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Septernber29ili,2005
Mr. Marlin Markley, Esq.
I am giving you this letter as a written termination of you legal services to me.
As you know, we talked on September 13ili or 12ili about my ending your services.
After you agreed, we discussed having my balance of my account made from
your office sent to me, or since you are so close to my home, I would be happy to pick
it up when Shelby calls me to let me know when it is available.
I appreciate all that you have done for me and I thank you.
Sincerely, Lorraine Ross-Cowman
sO
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Mr. Marlin Markley, Esq.
The Law Offices of Patrick F. Lauer, Jr.,
2108 Market Street Aztec Building
Camp Hill, Pa. 17011-4706
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ROBERT S. COWMAN,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 2001-5962
LORRAINE R. COWMAN,
Defendant,
: CIVIL ACTION - AT LAW
: IN CUSTODY
----------------------------------------------------------------
ROBERT S. COWMAN,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANlA
vs.
: Docket No. 459 SUPPORT 2005
: PACSES Case No. 212107407
LORRAINE R. COWMAN,
Defendant,
: IN SUPPORT
VERIFICATION
I, Marlin L. Markley, veriry that the statements made in the foregoing document are true
and correct to the best of my information, knowledge and belief. I understand that false
statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn
falsification to authorities.
Date: October 25, 2005
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ROBERT S. COWMAN,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 2001-5962
LORRAINE R. COWMAN,
Defendant,
: CIVIL ACTION - A T LAW
: IN CUSTODY
----------------------------------------------------------------
ROBERT S. COWMAN,
Plaintiff.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: Docket No. 459 SUPPORT 2005
: PACSES Case No. 212107407
LORRAINE R. COWMAN,
Defendant,
: IN SUPPORT
C.FRTIFlCATR OF SRRVlCR
I, Marlin 1. Markley, Esquire, hereby certifY that on the below-noted date I served the
foregoing Petition to Withdraw Appearance by depositing a true and exact copy thereof in the
United States Mail, first class, postage prepaid, addressed as follows:
Lorraine R. Ross
50 South 22nd Street
Apartment 4
Camp Hill, P A 17011
Michael 1. Bangs, Esquire
429 South 18th Street
Camp Hill, P A 17011
Respectfully Submitted:
--;
"
Date: October 25, 2005
, Marlin Y arkley, Esquire
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
10# 84745 Tel. (717) 763-1800
--,
ROBERT S. COWMAN,
Plaintiff,
(\
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OCT 2 7 2.005~,y"
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
,
vs.
: No. 2001-5962
LORRAINE R. COWMAN,
Defendant,
: CIVIL ACTION - AT LAW
: IN CUSTODY
ROBERT S. COWMAN,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: Docket No. 459 SUPPORT 2005
: PACSES Case No. 212107407
LORRAINE R. COWMAN,
Defendant,
: IN SUPPORT
ORn~
AND NOW, this II+- day of
, 2005, upon consideration of
~
the foregoing Petition to Withdraw Appearance of Petitioner, Marlin L. Markley, Esquire, it is
hereby ORDERED AND DECREED that Marlin L. Markley, Esquire is permitted to withdraw
as counsel for Rcspondent, Lorraine R. Ross, a/k/a, Lorraine R. Cowman.
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Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
vs.
: No. 2001-5962
LORRAINE R. COWMAN,
Defendant,
: CIVIL ACTION -- AT LAW
: IN DIVORCE
PRAFC'TPF TO WTTHORAW APPFARANC'F
TO THE PROTHONOTARY:
Kindly withdraw my appearance on behalf of Lorraine Cowman, the Defendant in the i
above-captioned matter.
Respectfully submitted,
/---7
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Date: November 8, 2005
,
Mar' arkley, Esquire
i
Law fices of Patrick F. Lauer, Jr., LLC
2108 arket Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
m# 84745 Tel. (717) 763-1800
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I RECEIVED ,
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-5962 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
"
ROBERT S. COWMAN,
v.
LORRAINE R. COWMAN,
Defendant
BAYLEY, P. J. ---
ORDER OF COURT
AND NOW, this ""2.-,\ day of August, 2006, upon consideration of the attached
Custody Conciliation SummarY Report, it is hereby ordered and directed as follows:
1. All prior Orders of this Court in this matter are VACATED and replaced with
the following Order.
2. Leaal Custody. The parties, Robert S. Cowman and Lorraine R. Cowman,
shall have shared legal custody of the minor children, Kathleen Cowman, born November
13, 1994, and Peter Cowman, born December 23, 1997. 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 23 Pa. C.
S. 95309, each parent shall be entitled to all records and information pertaining to the
children including, but not limited to, medical, dental, religious or school records, the
residence address of the children and of the other parent. To the extent one parent has
possession of any such records or information, that parent shall be required to share the
same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent.
3. Physical Custody. Father shall have primary physical custody of the minor
children subject to Mother's rights of partial custody which shall be arranged as follows:
A. Effective August 17, 2006, during summer school recess, from
Thursday at 8:30 a.m. until Monday at 10:00 a.m.
B. During summer school recess each Tuesday and Thursday at
8:30 a.m. until 10:00 a.m. the next day. The return time on Wednesday and
Friday mornings for summer subsequent to 2006 may require an adjustment to
the exchange time in accordance with the dictates of the parties' summer work
schedules.
C. Effective August 29, 2006, during the school year, Tuesdays and
Thursdays from immediately after school until 8:00 p.m.
.~
NO. 01-5962 CIVIL TERM
D. Effective September 1, 2006, during the school year, on
alternating weekends, from Friday immediately after school until Monday
morning, when the children are returned to school.
4. Transoortation. The parties will make the children available for the custodial
exchanges in a timely fashion and in accordance with the agreed upon schedule delineated
above.
5. Holidavs. The following holiday schedule supersedes the regular schedule:
A. Alternatina Holidavs. The parties will alternate the following
holidays: Easter, Memorial Day, Independence Day, Labor Day and
Thanksgiving, beginning with Mother having Labor Day 2006. The custodial
time for these holidays shall begin at 6:30 p.m. the day before the holiday and
continue until 8:30 a.m. the day after the holiday.
B. Christmas. Christmas shall be divided into two segments,
Segment A and Segment B. Segment A shall be from December 24th at 1:00
p.m. until December 25th at 1 :00 p.m. Segment B shall be from December 25th
at 1:00 p.m. until December 26th at 1:00 p.m. In even-numbered years,
Mother shall have Segment A and Father shall have Segment B. In odd-
numbered years, Father shall have Segment A and Mother shall have
Segment B.
6. During any period of custody or visitation the Father shall not possess or use
controlled substances, or consume alcoholic beverages to the point of intoxication. He shall
ensure to the extent pOSSible that other household members and/or house guests comply
with this prohibition.
With regard to Mother, for a period of twelve (12) hours before and continuing
throughout any period of partial custody with the minor children, Mother shall consume no
alcoholic beverages nor possess or use any non-prescribed controlled substances
whatsoever.
7. Vacation.
A. Summer. Each party shall be entitled to two non-consecutive weeks of
custody for purposes of summer vacation to occur during the summer school recess.
Each parties' vacation period shall commence with their ordinary custodial weekend.
For purposes of this paragraph, a week shall commence and end on Fridays. The
parties shall provide each other with not less than thirty (30) days written notice of
their intended vacation. However, the parent first to provide written notice of their
NO. 01-5962 CIVIL TERM
intended vacation period shall have choice of the vacation period in the event that the
parties have a scheduling conflict. Additionally, the vacationing parent shall provide
a telephone number and location where they can be reached during the vacation.
8. Each parent shall have the responsibility to arrange transportation for the
children to participate in the activities which are scheduled for them during that parent's
custodial period. In the event that Mother is unable to arrange transportation, she will make
the children available so the Father may get them to their activities. The parties are to
discuss the addition of any extra-curricular activities to the children's schedule. Neither
party shall unreasonably withhold their consent for the children to participate in extra-
curricular activities.
9. In the event either party is unavailable to provide care for the children during
his or her period of custody, that party shall first make a reasonable effort to contact the
other party to offer the parent the opportunity to provide care for the children before
contacting third-party caregivers.
Dist: ~chael L. Bangs, Esquire, 429 S. 18'" Street, Camp Hill, PA 17011
~ane G. Radcliff, Esquire, 3448 Trindle Road, Camp Hill, PA 17011
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IN THE COURT OF COMMON B~~F--=-
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-5962 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
ROBERT S. COWMAN,
v.
LORRAINE R. COWMAN,
Defendant
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 subject of this
litigation is as follows:
NAME
DATE OF BIRTH CURRENTLY IN THE CUSTODY OF
Kathleen Cowman
Peter Cowman
November 13,1994 Father
December 23, 1997 Father
2. A Custody Conciliation Conference was schedule for August 11, 2006 as a
follow-up to the receipt of Dr. Sheinvold's custody evaluation report. Present for the
conference were: the Father, Robert S. Cowman, and his counsel, Michael L. Bangs,
Esquire; the Mother, Lorraine R. Cowman, and her counsel, Diane G. Radcliff, Esquire.
3.
The parties reached an agreement in the ~
er as attached.
~cb 10 70
ate I
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Melissa Peel Greevy, Esqui
Custody Conciliator
:281317