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HomeMy WebLinkAbout01-05352LOUISE SIGNOR, IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. RANDY S. SIGNOR, DEFENDANT 01-5352 CIVIL TERM ORDER OF COURT AND NOW, this 23rd day of March, 2004, a Rule is entered against defendant Randy S. Signor, to show cause why he should not be adjudicated in contempt. Rule returnable at a hearing to be conducted in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania, on Monday, April 19, 2004, at 3:30 p.m., at which time defendant is ordered to appear. B e urt, ~ C. ~~ Edgar B. Bayley, J. dRobert R. Laguna, Jr., Esquire 1119 North Front Street Harrisburg, PA 17102-3318 For ndy S. Signor ouise Signor, Pro se 4505 Paradise Road #2409 Apt. Las Vegas, NV 89109 :sal ,oa off. ~,~ /~ f~V ~ r~~h i ~-~~~ oo~o~~ o~dW9~ ~ ~'~'~~L b~ DSDhh ~~ ~ Pd ~a~~ nau~ ~~~ ~ , , ,~-~~ r ,~. ~,,t„~'~~ ~r ~ ~ `~ ~~~ ~`= ~ `~`' ~ `' ~",~;~ hot,+Z ,, ,, ~';~ -.~, LOUSE SIGNOR, IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V RANDY S. SIGNOR, : DEFENDANT 01-5352 CIVIL TERM ORDER OF COURT AND NOW, this `~~ day of December, 2003, the custody order of October 23, 2003, is modified to provide that defendant; Randy S. Signor, sha11 not interfere with Louise Signor having phone contract, mail and email contract, with Tyler, Amanda and Eric, or with their receiving any gifts from Louise Signor. By the B. Bayley, Robert R. Laguna, Jr., Esquire 1119 North Front Street Harrisburg, PA 17102-3318 For Randy S. 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Lake Mead Blvd. #7 2221 N. Rampart Blvd. Las Vegas, NV 89128 - Les Vegas, NV 89128 Tel. 702/255-2773 Tel. 7021258-5441 HORIZON OFFICE WINOMILLOFFICE 2854 W. Hodzon Ridge Pkwy. B-4 2851 Windmill Pkwy • Ste. 3-E Henderson, NV 89052 Henderson, NV 89014 Te1.7021897-1173 Te1.7021897-8442 HUALAPAFOFFICE SUNRISE OFFICE -9901-W:Charleston.Blvd. #3 -420 N. Nellis Blvd. • Ste. A4 Cas-Vegas; NV-88117 Les.Veges, NV 89110 Tel. 7021870-2733 Tel. 702/459$500 .SANDHILL OFFICE ~RANCHOOFFICE 387.OE,-Ftearingo~ROed •Sta: A-2 4444 N. Radoho Or.~ •LasYVeges, NV:89921 Lae Vegas; NV-89130 Tel. 7 0 2143 5-1 8 8 5 Tel. 702/858-8060 CORPORATE OFFICE 8175 Spring Mountain Road Las Vegas, NV 89146 Tel. 7021251-5552 Fax 7021253-6316 www.presllgecrulse~.com THE LAKEB OFFICE GOLD COAST HOTEL OFFICE 9101 W. Sahara Ave. • Ste. 108 4000 W. Flamingo Rd. Las Vegas, NV 89117 Las Vegas, NV 89103 Tel. 7021869-8552 Tel. 7021878.1410 GREEN VALLEY OFFICE 1000 N. Green Valley Pkwy. #250 Henderson, NV 89074 Tel. 702!381-3388 WHITNEY RANCH OFFICE SUNCOAST HOTEL OFFICE 9090 Alta Dr. Las Vegas, NV 89145 Tel. 702/836.7081 895 N. Sbphanie St. M E M B E R Henderson, NV 89014 ~~ - Tel. 70214542776 THE ORLEANS HOTEL OFFICE 4500 W: Ttopkkmr+a~Mre. - tas Vegas; NV $9103 Tel. 702/365-7260 LOk+i,c?~5 i r l.hU.kwF?Y Fei~l,Ear'1 F'NFt: (f-'-MgVYI-':+ T0: F..'R:f.C AFIAKf'Pti c720 E: ,, i:'.HAi2L..E5Ti]hl L.AS VI._GAS hIV $y'I.a2 ltalleler ]. .,AI'IAFtF_'R/ERIC/AriANDA 3.. S'CInN1TR/ f YL. F:h t.AL_RR:I:(aH'1 iChlF;'"I'S'1' LF4A AQENT BRANCH CUSTOMER NO. ACCOUNT NO. .DATE ~ s ril~xSE: ooaQ i7MAK0a °~ ' -,'d~11E " - '.CITY •'AIRPORT -:TIME - CARRIER p ~ BERVICE•AMWNT t) FIl t}1,1l i! Ik;`a ~-J t'~( I:.l tram,: $) "P. rfallFd ldNCF- - -" I;F.1 hl!-.I: Fi I~}r. '.UOa T l"1_:1`1 C05T c t).0 I: A t~ C Ea''1 ., . ... . . . . ...:....., ,. 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Hodzon Ridge Pkwy. B-0 Henderson, NV 89052 Tel. 7021597-1173 HUALAPAI OFFICE 9901 W. Chadeslon Blvd. #3 Les Vegas, NV 89117 Tel. 702/870.2733 WINDMILL OFFICE 2851 VYindm9l Pkwy • Sta. 3-E HeMereon, NV 89014 Tel. 7021897.8442 SUNRISE OFFICE 420 N. Nellls Blvd. • Ste. A-0 Las Vegas, NV 89110 Tel. 7021459.8500 SANDHILL OFFICE RANCHOOFFICE 387,9 E.~Flemingo Road • Ste,A-2 .. 4444 N. Renglo Dr:.- LarVepas; NV 89121 -- ' Las Vegas; NV 89190 Tel. 7021435-1885 Tel. 702/858-8060 .~~ F.:R:LI.; AMAKF'R 57R'.0 E. C;HAFtI_E'5'iI.TN I...AS VEGAS NV 8'i'].4,'. it>vveler 1.AMAKER/ERIC/AIIANUA :d „ S l: GNtiR /'I'Y L E R CORPORATE OFFICE 6175 Spring Mountain Road Ws Vegas, NV 89146 Tei. 702/2515552 Faz 702!253-6316 www.prestigectvises.com THE LAKES OFFICE 9101 W. Sehare Ave. • Ste. 108 Las Vegas, NV 89117 Tel. 7021889-8552 GOLD COAST HOTEL OFFICE 4000 W. Flamingo Rd. Las Vegas, NV 89103 Tel. 702/876-1410 GREEN VALLEY OFFICE 1000 N. Green Valley Phwy. i{250 Henderson, NV 89074 Tel. 7021361-3388 SUNCOAST HOTEL OFFICE 9090 Alta Dr. ' Las Vegas, NV 89145 Tal. 7021836-1O8t WHITNEY RANCH OFFICE 895 N. Stephanie St. MEMBER ~;• Henderson, NV 89014 Tel. 7021454-2776 4 ' > 1. THE ORLEANS HOTEL OFFICE 4500-W.TropicaneAve. -'oflhevel eM ~~ Las Vegas, NV 89143 Tel. 702/365.7260 1.Oh7.0e~ 1"T'T:NF'.RARY REC;EIF'T P'Af.~iE NI7: .. c^^.. AI...BRIGHT/CHRISTINA A6EMT BRANCH CUBTOMER NO. ACCOUNT NO. DATE - 0040 L7MAR04 yop ,,:.;,.: CITY •-AIRPORT TIME CARRIER ~ ~ ~S SERVICE •AMOUNi E A A ~~A ~?7.,.1111.. i V i ; ~~; VF'CaAti 7~I[)A 1)F..L. i A 403ti l UK AI•~ AiL.ANTA _ ~3$f? EtAG£i AL_L UtdF..r't-• 21- i F:Gki: US'( Clf' 767 /il_, CC)hIFO xF'G•J809 fiF.:A'I' 27^p pE%ftE::SERVE:]Iy.>< ACIAKF:R(ER:rG SEAT 27=P aa4aRF'SERVE:Dxr AMAKE.R/AMANDA SEAT' 27-C ` sltRESERVEiIx~c AL.BRT.GHT/CHRJ:STTh1A SEAT' ^c7-U ~t?¢kE5ERVEiIxa~ SIGNOR/'TYLER hi0'T' VAL.. 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L V-, - ICE Ye~ 'T.i ~ ' CN CORPORATE OFFICE 6175 Spring Mountain Road ~a•/7~/^'/~ Las Vegas, NV 89146 l (J Te1.702/251-5552 TRAVEL & CRUISES ° ~""`~ Fax 702/253-5315 sep,«nun.: www.prestigecruises.com SUMMERLIN OFFICE 7550 W. LaKe Mead Blvtl. #7 Las Veges, NV 89128 Tel. 7021255-2773 HORIZON OFFICE 2554 W. Horizon Ridge Pkwy. B-4 Henderson, NV 89052 Tel. 702/897-1173 HUALAPAhOFFICE 9901 W. Chadeelon Blvd. #3 Las Veges, NV 89717 Tel. 7021870.2733 SUN CITY OFFICE 2221 N. Rampen Blvd. Las Vegas, NV 89728 Tel. 7021258-5441 WINDMILL OFFICE 2851 Windmill Pkwy • Ste. 3-E Henderson, NV 89014 Tel. 7021897-8442 THE LAKES OFFICE 9701 W. Sahara Ave. • Ste. 108 Les Vegas, NV 89717 Tel. 702/889.8552 GREEN VALLEY OFFICE 1000 N. Green Valley Pkwy. #250 Henderson, NV 89074 TeI. 7021361-3388 GOLD COAST HOTEL OFFICE 4000 W. Flamingo Rd. Las Vegas, NV 89103 Tel. 7 0218 76-1 4 1 0 SUNCOAST HOTEL OFFICE 9090 Alta Dr. ' Las Vegas, NV 89145 Tel. 7021636.7081 SUNRISE OFFICE 420 N. Nellla Blvd. • Ste. A-4 Las Vegas, NV 89110 Tel. 7021459.6500 SANDHILL OFFICE RANCHO OFFICE 3870,E Flefrlingo'Road•.Ste.A-2; 4444 N;-Rencho0r. LasVegasrNV 89121 CeB Vegas, NV89130 Tel. 7021435-1865 Tel. 7021658-6060 WHITNEY RANCH OFFICE 695 N. Stephanie St. Henderson, NV 89014 Tel. 7021454-2776 MEMBER THE ORLEANS HOTEL OFFICE 4500 W:Troppic~eneAve. Les Vegas] NV 89103 Tel. 7021365-7260 1O61.U°.I fTl'hIFRARY RE:CF:CF'T F'At;l~ NtJ. 3 F"hIR : 7. F'-~Nl)VYE':t. To: 1-RT.r.. Ar1Al<FM `~72U E~.. CHARL..F:fiT'f.1N I..AS VFGA£i NV 597.4:' Treveler 1.,.AMA4(Ii:R/F:Rf.C/AI*IANTtA 2.AL.13RIiiHT/CHFiISTT:NA :3.SI(NT7R/TYI_E'R AGENT BRANCH CUSTOMER NO. ACCOUNT NO. DATE CHC~RYt. SUNRISE 0040 1.71'IARG4 ~ °es DAY _ DATE CITY • AIRPORT TIME CARRIER ~ bTATUIS.ASS SERVICE•AMOUNT T:hIF;I1RAN17F: U.UO SI=.RVICF: CHARGt 7UU.0(7 'T'AX G.GG SlJ13TC1TAL. AIR FARE TAX T'(:l'T'FlL AIR F'AfiF.: TCJ'T'AI_ INVCTTCL Ar1UUhIT A11C.lI.1hIT fIl.1F: THIS ArICILJhrI' :LS -I'CJ lit F. F'A:I:CI T:1Ya fa-IF:C:k F4._F:ASE: RF:CCIhII-IRM F'RF:CJLIFId7" F'I_.YF'fi N131iS Uh-`C1N CNk:CK-IN S'T'A'CF: l)R FlcCtlcFiAL. F'HUT"0 T,li. RFC2U.1:RFaI A'f A:I:RPORT >~~7UGG()U.,OU I'L.f.(iH'C INSI.IRANCF: INCL.LIIIF:U•x•>Y ~:'. I-It'll.1R f.;hIF:Ck--I:I+I FI:1R •ALL.. LICIrIF::T3T'.f.C F'1_.]:P~hICS :i3 IiC1Uri i:Ell:Cl(--:I:N F"C7Fi AL. L. 7:N'T'ki:RNAT7:C1NAl.. F'L.TGHT!ii . i Li l: 1. l., hF: F:hIFiIFiC:F~l;l. AL..L.. L.,ATF CEIE:Ck-7:NS WI1...1... L.C1SI5: 1 Fih '(4~: 4i i-'(-5~( A`.tp:i:C hrNl*IF:(hhl~!ii .. 1 H1:Sr T 1GIi~'1' 1S hil,)N kE:} Uh11:tA}.Ii..,E: - F'F::NAL., T'Y F171 CEIANI:vE:S., • IF tvAhIGELING F'L.T.fik1T$` -'s`NIU'ST`°'1.1[Y °~(? $EFpR,E'. TRpVEk'=DATE= F'OR TICkE:T 'CO RF:T'AT.hi VAI...I.1F. C7TEIER RE:STRT.CT7:f.1N3 r1AY AF'F'I_Y. '; ]:/WI::: HAVE: F21~;A1) TI~lICi 7:TINF:ttARY A AGFtF'E TT1 ~_ AI-.i.. '1-F.:'RrIS Ahil) C;C1h1CIJ:T'II:1NS I:-::JARI::ht, Or11HCF1_LAT'T:1 flhlt) CHANhitr F'FiNAI.'1'l:li:f#. ~..„ '~ nA'I 1=:.:J~.. i •b1• F ~ ^~~• ~ , , ~ ... , , ~,.~l.Nld,Q.. . ~/Y"" t`'' TFJANk YCIIJ F'C.lli YC.ll.11i Hll!;:f.Nf~SB U 0 ., 2:39 , L;iFi~.. 7.4Fi'L . ].4i 7. . 9 • SURFACE CLASS: F, A LOUISE SIGNOR, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW RANDY S. SIGNOR, Defendant 01-5352 CIVIL TERM ORDER OF COURT AND NOW, this 19th day of April, 2004, upon consideration of the Plaintiff's request that the Defendant, Randy S. Signor, be held in contempt, and neither party having appeared at the hearing scheduled for this date, the request that the Defendant be held in contempt is dismissed. By the Court, I ~ ~~~ G'~-~1 // J.f 'Wesley Ol . ,' J. /Louise Signor, Pro 5e ,~~ `-' 4505 Paradise Road #2409 Apt. Las Vegas, NV 89109 ,~obert R. Laguna, Jr., Esquire 1119 North Front Street Harrisburg, PA 17102-3318 For the Defendant pcb `~~~~~C U'S ~. ~P"~' L~~~~•0 ~ 0`~ ~' n 11~ i's, l'l A f.S ~ 41 ~ls~ ~Z ~~~ ~ODl ~~ 1~~"d1CkvONlGt~e4 3;11 ~0 ~~~•;c~-a~:~ -~~ _~A. ~...wuum.vau ~_....~~WV AFYbY'lmlYysu^avw.m - IWA:C~kTV3 WE: VSa9 .-.•a`-. ~]iRWrcx~F'M'.aar`-I ~Z _ S 3 S a. C~~ _ ~- y. ~ ~ C~ ~ ~t _ av~- _ 1f~-/ . __ __. _~~c~u_ _, .~. _ ~ C~~vv~c~. ~~ ~ -~.~-~ ~-5- ~-~r~.~- ~_e_. __~.~~ ~ d v~~_ Inc_~-v ~- ~ ~ ~ r (~l ~ ,~ ~~ .~ i ., ~~~~~ ~ _ ~'~.e..~~ cz.z.v ~. ~ ~~- .~~. _ Y~,~c _h._.._~-k~~~ ~~c~.~~ ~. _C°~w _~ _. .~ . __ . _. ~I- . . __. ~-~-_~~~ c~ _co cam- ~~. __ _ .r. -- _ __ _ _ ~ --_- _~~ -~,~ce- _ __ rl~_v ~~k~ es ..- ~ ,~ ~~, ~~- ;_ .. a-cr~ u'~ ~ _ ~~ _ _u~ ~~ [mss ~ I, ~. C vim... `~-~__t~c~- _ _ c~- _ ~~ca.~- ~he.~~ w ~~4tie,~ ~-~-k- ~ ~(~. 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CQribGVU i'lntl lfiY£y Ctii (NFlif. ~j5~ QIe ~iWtC suet Fuoi: hm-! e fox a stsy by s=,op !po-isle +_,r ; gating yo4; f:-ill, or 'r!filr 0r+ W+J£]1.S£e .)€ v+aF.zor!wNttir>es.4oln }T£.~GISTEft EGR MY ACC,pUNT C)PIk.fNE p:':p Accosnt teak::+; it .:, rr~ei;; 'o mrlrra(td you! wireless eX.p9r!9nr:B - y:.rc:~ earl r,?reck ypA:r bulan<:ia, view .+nd pay your k+i£i, up,7t~du Your rxtrAifslt=a!;t, ravrs..w call dutr:li£:t, anxf !nl,!arir rrECre. Rapister fur PAy isl;x:nura! hei'.vean now curd d4pxil 12 and yuutl he able to tcilcn arr. ulllax'£ : vi s ~k~uai preo.~t+tiun F ,1 rrvara snfunnHtioo, please ?6i£ ve~izar-:ariteet.rss crx!Y:my:rrrsxlt}r. ttla6(k E TC)1u1Qf318.E NAME. CHANgE 4+s~iy!e ~:, P~9o151ik is now ctll!ad ItU~Pietu~crk Gsliiing. €n €he conting ,1~?>.xN}., you sv;ll nniG,~ tttw nx~v,Ie fu rr!uLfla'! %Iese~ripfrc,t7 un your bill =IP.£,1.us~=FE by £N-3`detwark 0.111;.^.g. Suite c7reat terwice, p:'irr, unrt rn. v&r!gsl, naae'aairh a new testis,. Nfarc~t ~, 2t~04 Account number CU4tt}tner SPrVlrwe F'flt_jF.'+ i Ct .l 31987D391-a(ItHtY Qrfine: vSrlZi£t1a"vitals>s,~).Tilrra?tG intics£om trumhsr Plie;ee: 'Til anc: ;.+irtEr£t~ (t¢e by di«lirrr,:J 'e~E 1 1r~ronr fi50gY579'i¢ yOLFI" WI!':YIFI$3 (atEt}?3F:, Cl ~.~tl}($-~E 7..Qir.4jd. F.Aai: Vcrizer! VJir&b~s-r;., nttn-%;u~4nrn.:l ;,rrrviae, f'.(.). F:tfrx ;5'.i3, Vd::tr=elu:!:al;, P''A t n$6.Oa~3 Payment options f3ay by phone:- Dial #kPb~ t- (u7ET#3j, yr"31tL gaR225j t}r `Fi1 7 !turn yySx 4dite€e:srs trhrrre rr use our r+uiamat,!Ir7 s~yslw.,r at 7 -$tYtJ-9?2-u264, Thzlse c::tlls ar+g !alf and airtime itcre. Pay r:lnfinr?: l.d{tin to nay Arr.,o£,uit at vet itcn iuire Is s5.x,nrtt l~lCGt5C1t summarf ... :..... Pt`aviaus charge Ptr3vinus ba££lnC@ ~2't ~$ R lyrnsnt recuiVaU tY2l1 1 -('nail: you +d2 R(f ri. ta!}Ge lrfW:AfiJ __.... _... __........ ... ~t Qy.$S ~.rfJPY~It# C~lBt'QeS FAonthly chargExs Eid.38 Usage cfr.uges ;i"oS.t'?. Yarizarr VJiruk,ss su!uh;arttrrs and otii€;r chnrglaa and +: rctii+s '§i.iis Taxe -:. gnvarnme!rtcxi such n yec .~u<d t. Gs :?d 35 7titof eurreltt charges __ $094.72 "to#a! Amaurt# ~~1 B,s7 6Ya rosy apply a late paytitent eharyer pot mltnth 9gtYal to tha gt»ater of $f+. tt0 nr Y.S! ~ ~(tjre UnpN10' be121K'e, nl th8 ftrgWttlgF amet/ftf prrrmltta4 8y Yarr 6n balances aueetanAr+i{I an the n4to rMta. 7halra etul+Urs um Nq'uldaYrelllanragas artd are not a pstmatty. I Itlt11i~1.:`yNdNSWJ.~ .I.., .,Ji4:tf >iWYLItWr!« iii:yl::.f ~I le ,.,-"':~:Stlail iyL[,uWNLl..lJJ,ueiuWYIWI.•:1NAu„'r@llvilLly6UtLILtY194YlUU!Iwy~~.=4uLIJypNJti:4'YIWiWt4UUlUiy!y1'JJLyIl 5i!IIL'wVA:Rff t,I.iuie:ll®futiWYWyYIp~14111NNYWW4WmU3~ I't~.~ e~ t+ytt~IeiJ"s ,LL,~F~~y~s~nt cou~snr~ P4asut n:;tutn kris £x,rti:;n wit£r yC+tlr ;:Plat-k ar m<slrny orderr mei;Nt I'rtry;r#ds to Veriaao Witolass. #'Al~t. F1CrMl'fsi.t -:SG+ pp~,flAS:lf4k; {li t t~ptu 24 LAg 'v'E+;;It5. P1V f.!w!IU9777? un! dtns March fi. ;2Qtt9 ;+E AI:r;OUili number 9te6Te338-40QtE3 Iitvcrir:t9 number r}5i)6Y57134 $atance fohyprd... ........9125 9¢ Currrtni Charges 56,7'2 PAYMENT E}U£ IMM6nIATkt.Y Se 1657 MAKE CHECK PAYAI3t.E TC7 VERfZc7N SYIREG£88 Amaum enclosed i:haauk rrHre >ret ?ill ;:u.*e the b.:xck of !fyie slip Et yoar bilEing tu~rass h.~,~t ,,tl:fnytE<u == an}tr use 4ui~iinry nr nl'uvtr,~inp ynar ern ti! a<£Jre~;; P:7 kit, x rl,ii i ~ re jrii~L.l_AS, 7X(!5?R`+a[-G1£7n++{ {{ p [ fleat'al,~lfi lt~t ~1[la ~~ati'f3 t[l,.I~~f Y111 i.1ei3xr a~ r'€ riC7, L57L7r40111J~7,9o ?Ci:~`::Ir[JL7L7[7LOl1Lf[1uKk;'i'I:l!~?CCI`: l+~ u .'!4 __ _ _ _ _ __ i ~~. _~.,. ~~ Apr-19-04 O9:45A Alax J. Sugden PnrNat 9ieanth Chergaan - RBanthty AcCOSS.AIlewance !`urrn:ii AA7lauta~s -din yatar Pfrsd tsitt or wtron putt ehanga yatdr teatura; si: calttndTafan, qxt w!(PbJit Par a par6ai mantlr or partlan at thm a#aoaaniy ae,:ass chattgs t-atudwied Prom PPae datrs yanr hsQan sdartrAt!B tm yaaa Urst biH cycle date ar eiFoedivc date at the anlPLag(rlan atran9a, plus Plea na~.xt nr{aarite~ acax:ss cfrarge ii rve bAt yoea in adwerrrt. Wm caatcretara allowaarcn mNwtes fn t/te samr manner. 1<'ntaaarcerd 'Jervtaamn inaizido bttt arm not tr}nriaed to .iu?amari+e Catt Daiivary, V'aico atnri, text Afetssargln{!, ARshilm bVOb Racass and otdrer sea'Viams aaach as Cali Fcvavardittq. Celt Waiting. Throe-Way ': CatlJtrg,rfrni SexsyAto aa78AyaY Trearster. ~~ farhanca~d ~3mrvVii4e= ; rar9lal ~~monYh iprorirte7 - _Ieiesa' ... .... aorvicros may bm blPfrrd a monfPa iar advancx and rosy ba prmr~rtad 6assd on Pita etlective ararP and end do+ei¢ a.r Pipe INatBanCetl see'YiCa. Usage summary 111-433-4519 Bn YaLir Name Are fa Allovrance CFPrreYii &~saga ~ ............ {rromult;nei Pdinute:: P,Maniftl9' il=rurlea lid-Pdriw~r~n. (M1A+akrii~' Ie r•:iubil+?~ !!saga TaGals Curten9.11~yYga Chatgns: ................ Tatai uearga eh~gas is your Kama area 702 822 6547 P_O6 Srtt G1ata Xlarch br LtWQ i'4(aP, .1 ?;:t ~ Arrrsi.int number 9i A670.R91-nU{b:!1 invoice number 05061 S911d Txr Mristadin0 tan Mcndhly +,txrwancef 1CU rnecsa~es Fkdditianal per merxx::ge $.'t3.=.ar:i: $.r`t.u recaaivati Peak 8nsiudod rfillabFe C J 0 X35 'A$ r) ~ff Peak iaicluded E3dinbin Taut iia6E U Inrludn.9 El G $332.55 0 0 Inciwlcr~ i46 738 ifYC~6 U ..... ..._..... .... $932.55 $.aar ~f2.S.5 "b~f2.55 . __..._ .Msw,srages Tote! 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Manihiy Jlowance 29 pictures AtigitlurrerS leer IN<:tuxe S.e5 serr:, $..5 rt~relved Pi)f E?u•txc lot) P.Aaxsayin(d '~ Mnnihlg slk~warurt i00 meS>aFz^.s : Additbnal par message 5. r0 4ant, $.0:` °ar~ivett ! 9$t,~8 ~t.irnrnary 7'{7-~~."5-49°1l~ F'f3t.ll ~:~r;T~;a1~ In VOUt, Nutne Aram ...... . C't1YdC`[P[:U3d~C Pronralianal Minute:: Fhuutfi3y toiinuinx ;til-.W.ttdiork ;Mni?ile tr.. t,dobi€ei U.M1Al]p. 'idl~t~9 iy C:urrsrst tlsag+s C:harga+a Allowance __„_ _ . SGu Ge+r9reti t1XN7 GeI'.era3 Paxk ....,.h>.cluded,, ,,,.Billable q t) :fitiF` 4 It3U :~ aluo a $3.Be Clft P+rak Insiudwi Billable Tots[ t3r3 6 includutl cr o 23.Bd ii 9 lr~cSUried 93f~ 0 $.0+1 3-3.50 i ~l .y < + LOUISE SIGNOR, Plaintiff S 2 6 2003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5352 CIVIL TERM v. CIVIL ACTION -LAW RANDY S. SIGNOR, Defendant BAYLEY. J. ---- INTERIM ORDER OF COURT IN CUSTODY AND NOW, this ~aM"` day of , 2003, upon consideration of the attached Custody Conciliation Su ary Report, it is hereby ordered and directed as follows: 1. All prior Order's of this Court related to the custody of the minor children herein are hereby VACATED. 2. Physical Custody. Father shall have primary physical custody of Eric Amaker, born May 12, 1988; Amanda Amaker, born December 15, 1989; Tyler Signor, born December 18, 1996; and Holly Signor, born August 5, 1988. In the event that Mother desires to have contact with the children, such contact shall be arranged through counsel and shall be supervised through the visitation program at the Dauphin County YWCA. 3. A hearing is scheduled in Courtroom Number 2 of the Cumberland County Courthouse, on the /3~ day of ~n~-/,~.P~, 200 3 , at u~; LYE o'clock p .M., at which time testimony will be taken. For the purposes of the hearing, the Mother, Louise Signor, shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties or the parties pro se shall file with the Court and opposing counsel/party a memorandum setting forth each party's position on custody, a list of witnesses who are expected to testify at the hearing, and a summary of the anticipated testimony of each witness. These memoranda shall be filed at least ten days prior to the hearing date. NO. 01-5352 CIVIL TERM 4. In the event that Mother is aggrieved by the terms of this Interim Order, Mother retains the right to file a Petition for Special Relief. ,~ BY THE COURT: e .~' Edgar B. Bayley, J. Dist: Jeanne B. Costopoulos, Esquire, 5000 Ritter Road, Suite 202, Mechanicsburg, PA 17055 __ , _ • ~~~~~ ~ o2y~(U Roger R. Laguna, Jr., Esquire, 1119 N. Front Street, Harrisburg, PA 17102 ~""° ~ ~~ ~~ I r~ ~~ ~ ti ~_ ' °_ ~= ~ it ~; F t . t... i .~ ~ .. -__ ~ ..- -.J. .a.. _ R) C'yr 4ry,. ~`I ~.~ l ~,G i~~ ~~ ~3~ ~~ .a U t LOUISE SIGNOR, Plaintiff SEP~'6 2003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5352 CIVIL TERM v. RANDY S. SIGNOR, Defendant CIVIL ACTION -LAW IN CUSTODY 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 VL$~`{! Tyler A. Signor 'f~,~, Amanda L. Amaker -~+ Eria ~~~ -do`~llhhy Signor ~~ ~'"'~ DATE OF BIRTH December 18, 1996 December 15, 1989 May 12, 1988 August 5, 1988 CURRENTLY IN THE CUSTODY OF Father Father Father Father 2. Thd' Custody Conciliation Conference was reconvened on September 23, 2003 as provided in this Court's Order of August 12, 2003. In attendance as counsel for the Mother, Jeanne B. Costopoulos, Esquire. Counsel for the Father, Roger R. Laguna, Jr., Esquire, participated by telephone. Neither party attended the conference. 3. Father's Position on Custodv. Subsequent to the Conciliation Conference of July 17, 2003, Mother apparently took Tyler, Amanda and Eric to Las Vegas, Nevada. She was subsequently arrested for kidnapping. The children have been returned to Father. Mother had been incarcerated. However, Father's counsel reports that he had recent communication with Mother indicating that she was out of jail and coming to see the children. Father's counsel alleges that one of the children told him that Mother again had plans to sneak the children out of the house at midnight. Accordingly, Father requests that any contact Mother have with the children, pending hearing, be supervised. Father's counsel indicated that an order requiring supervised visits through the Dauphin County YWCA Program would be acceptable to his client. w NO. 01-5352 CIVIL TERM 4. Mother's Position on Custodv: Mother did not attend the conference. However, her attorney reported that she had e-mailed the Mother to advise her to either be present for the Conciliation Conference or call in during the time of the Conference. Mother's counsel reports that she has no basis to object to Father's request for supervised visitation in light of the circumstances and the ex pane communication from her client to the Conciliator. This letter has been shared with counsel for both parties. Mother's counsel advised the Conciliator that her client would not agree to supervised contact and that she wants a hearing before the Court because she believes that the circumstances in Father's home are so severe that the Court would agree with her request to return full physical and legal custody of Eric and Amanda to the Mother and to permit her to share physical custody of Tyler with the Father. Counsel further reported that the Mother intends to reside in Las Vegas, but is not known to have employment there. 5. Upon the request of counsel for the Father and with no objection from the counsel of Mother, an Order for supervised visitation will be recommended to the Court for its consideration, along with Mother's request for a hearing. In the event that Mother objects to the recommended Order, she retains her right to file a Petition for Special Relief. Counsel for Father would not object to scheduling a heari~on such petition should it be filed. ~~ ~ 9 ~ Dade Melissa Peel ~Greevy, Esquire Custody Conciliator :218755 '.:.. f; . .~ . LOUISE SIGNOR, vs. RANDY S. SIGNOR, NC7ll 0 5 2001~~ G Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5352 CIVIL ACTION -LAW CUSTODY TEMPORARY ORDER OF COURT AND NOW, this ~ day of ~CLIJ~, 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Randy S. Signor shall have sole legal and physical custody of Holly M. Signor, born August 5, 1988. 2. Louise Signor shall have sole legal and physical custody of Eric Amaker, born May 12, 1988. Eric may have contact with Mr. Signor as the parties shall mutually agree. 3. Louise Signor and Randy S. Signor shall have shared legal custody of Amanda Amaker, born December 15, 1989, and Tyler A. Signor, born December 18, 1996. 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 Pa. G. 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, and 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. Both parents shall be entitled to full participation in all educational meetings and medical/treatment planning meetings and evaluations with regard to the minor Children. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational records, attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school night, and the like. 4. The Father shall have primary physical custody of Amanda L. Amaker and Tyler J. Signor. Mother shall have partial physical custody on three of four weekends per month, arranged as three consecutive weekends with Mother and one weekend with Father and rotating between the parents three weekends with Mother, and one weekend with Father. No. 01-5352 -Civil Term Mother's first custodial weekend under this schedule shall commence on October 27, 2001. Mother's partial custodial weekends shall be defined as follows: from Friday at 8:00 p.m. until Sunday at 6:00 p.m.,if Mother is working the 7:00 a.m. to 7:00 p.m. shift; from Saturday at 9:30 a.m. until Sunday at 6:00 p.m. if Mother is working the 3:00 p.m. to 11:00 p.m. shift. The agreement of the parties with regard to Amanda's custody was based on the desire to leave Amanda in her present school and educational setting. Therefore, the arrangement for Amanda's custody has been agreed to by the parties contingent upon Amanda's remaining enrolled in the New Cumberland Middle School of the West Shore School District. If, however, because of Father's change of residence, Amanda will no longer attend New Cumberland Middle School and a change of Middle School becomes inevitable, then Mother retains the right to Petition per Modification of this Order with regard to the physical custody of Amanda. 5. Transportation. Transportation shall be provided by Father unless otherwise agreed, until such time as Mother can provide her own transportation. At that time, transportation will be shared by the parties as they shall mutually agree. In the event that Father is not able to provide transportation to Lancaster on Friday evenings for the beginning of Mother's custodial visits, he will arrange with Mother to either bring the Children to heron Saturday morning or to meet Mother at the train station in Harrisburg with the Children. Father will confer with Mother by the Wednesday preceding her custodial weekend if this is the case. 6. Thanksgiving 2001. Mother shall have custody of Tyler and Amanda from 4:00 Thanksgiving Day until Sunday following Thanksgiving at 6:00 p.m. 7. Christmas. Christmas custody shall be arranged on an A/B schedule. Segment A is December 24th through December 25th Noon and Segment B is December 25th Noon until December 26th at Noon. In 2001 and subsequent odd-numbered years, Father shall have Segment A and Mother shall have Segment B. In 2002 and subsequent even-numbered years, Mother shall have Segmeht A and Father shall have Segment B. 8. During any period of custody or visitation the parties to this Order shall not possess or use controlled substances, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise ensure, to the extent possible, that the other household members and/or household guests comply with this prohibition. 9. The non-custodial parent shall be entitled to one telephone contact per day with the Children. 10. This Order is temporary in nature and may be modified by an agreement of the parties. No. 01-5352 -Civil Term Dist: Roger R. Laguna, Esquire, 15 N. Front Street, Suite 302, Steelton, PA 17113 James W. Abraham, Esquire, 513 N. Second Street, Harrisburg, PA 17101 \\~ p\ ~~ ~~~uv~j~ ein r o,.;ti ^~ .7 r, lip" "~-=.~I> 'r, :;'J'lr t`,~~: ~: ,. LOUISE SIGNOR, vs. RANDY S. SIGNOR, CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 01-5352 CIVIL ACTION -LAW CUSTODY Defendant 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Amanda L. Amaker Eric R. Amaker Holly E. Signor Tyler A. Signor December 15, 1989 May 12, 1988 August 5, 1988 December 18, 1996 Father Mother Father Father 2. The parties were seen for their first Cumberland County Custody Conciliation Conference with this Conciliator on October 23, 2001, with the following individuals in attendance: the Mother, Louise Signor, and her counsel, James W. Abraham, Esquire; the Father, Randy S. Signor, and his counsel, Roger R. Laguna, Jr., Esquire. 3. 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'• .._ .. .• .. .. •. I& ~ ~Mwv~Om-Y1C: maHX41~uX~1u14'~zw:+..Yw$Nw:kkN~9iaNMSNfV i~iY+Y~ D ~,~~~ n~ 6 --~ ~ 6J~na--. _ `~ ~+ ~~ ~ G~-~ e n~ j ~~ ~ ~ c> od y~-A-~-e v-- f /'iLQ Irv- Illy 10/13/2003 Highspire Police Department Complaint Report ID: 2003-2760 Description: reported neighbors being loud Received By: RONALD WEBER Date Received: 10/05/2003 Time Received: 13:00 How Received: COUNTY RADIO Time Dispatched: 13:00 Time Arrived: 13:15 Time Cleared: 13:30 Location: 233 Market Street OfficerAssigned.• RONALD WEBER (RRW02) 1 o f 1 CaUer's Name: Donna Rhinehart 237 Market Street Highspire, PA 17034 Telephone No: (717)939-7775 Complaint Type: NEIGHBORHOOD PROBLEM Area: Zone 2 Hill Area How Handled: COMPLETED Comments: reported that the Signor's had been loud throughout the evening and also drug activity. Spoke to Randy regazding it. . Complaint Status: Closed TimeAna[ysis: (Minutes) Queue Time: Travel Time: 15 Response Time: 15 Action Time: 15 Informant 200o Professionnl 10/13/2003 Highspire Police Department Complaint Report ID: 2003-2540 Descripfion: REPORTED PROBLEM BETWEEN NEIGHBORS Received By: MARK STONBRAKER Date Received: 09/14/2003 Time Received: 17:05 How Received: COUNTY RADIO Time Dispatched: 17:05 Time Arrived: 17:15 Time Cleared: 17:18 Location: Officer Assigned: MARK STONBRAKER (MLSO1) 1 o f 1 Caller's Name: DONN RINEHART 237 MARKET STREET HIGH5PIRE, PA 17034 Telephone No: (717) 939-9753 Complaint Type: PHONE CALL Area: How Handled: Phone call Comments: CALLER REQUESTED A RETURN TELEPHG~tii?. CALL REFERENCE TO PROBLEMS WITH HER NEIGHBOR, RANDY SIGNOR. NO ANSWER ON CALL-BACK. DCC ADVISED COMPLAINANT INFORMED THEM THAT SHE WOULD NOT BEAT HOME. Complaint Status: Closed Time Analysis: (Minutes) Queue Time: Travel Time: 10 Response Time: 9 Action Time: 3 )'Vt ~, Informant 2000 Professionnl _- - --- - ~ ~~. ,. ,~ „t -_ .~,0~ ..0 (l(1 --- ___ `~"~ V i __ - - -- -~_~_ _ ~~ ------ ` -1- - 1 ~- _~_ ~~-~.._, "_--- _°~~__C~~-- _, LOUISE SIGNOR, Plaintiff v. RANDY S. SIGNOR, Defendant § IN THE COURT OF COMMON PLEAS OF § CUMBERLAND COUNTY, PENNSYLVANIA § NO. 01-5352 CIVIL TERM § CIVIL ACTION -LAW § IN CUSTODY DEFENDANT'S MEMORANDUM FOR CUSTODY PRE-TRIAL CONFERENCE SUBMITTED BY: Laguna Reyes Maloney, LLP Roger R. Laguna, Jr., Esquire Counsel for Defendant, Randy E. Signor 1. BRIEF SUMMARY OF CASE, INCLUDING NAMES AND DATES OF BIRTHS OF CHILDREN AT ISSUE AND THE CURRENT CUSTODY SITUATION: The parties are the parents of four (4) minor children. Namely, (1) Holly M. Signor, born August 5~', 1988; (2) Amanda L. Amaker, born December 15"' 1989; (3) Tyler J. Signor, born December 18`i', 1996; and (4) tic R. Amaker, born May 12~', 1988. Only Eric R. Amaker was born of the mamage between the parties. Father has primary physical custody of the children. The chin has resided with Father over the past several years. The Mother has a history of repeatedly abandoning the Children for months or years at a time, and returning periodically when she is not incarcerated or institutionalized. Mother is currently under indictment for kidnapping the children and taking them to Las Vegas, Nevada. The Children were returned to Father after Mother was arrested in Las Vegas. The Children are currently living in Dauphin County again and attending school in the Steel-High School District where they have been doing relatively well in all regards. 2. STATEMENT OF ISSUES EXPECTED TO ARISE DURING TRIAL: Whether Mother's excessive drug and alcohol abuse, incarceration and institutionalizations have finally rendered her mind incapable of functioning to the degree necessary to care for these Children, or any others? 2. Whether Mother intentionally and knowingly disregarded the prior Court Order in this matter when she carefully executed a well laid plan to kidnap the Children and remove them from Highspire, Pennsylvania to Las Vegas, Nevada? Whether Mother's plan to "start a new life" in Las Vegas, and take the Children with her, should be permitted to upset the status quo when the Children have been doing relatively well here in Pennsylvania? 4. Whether Mother should have anything other than supervised visits with the Children? 5. ADMISSIONS FROM PLEADINGS TO BE MADE PART OF RECORD: None. 6. STIPULATIONS OF PARTIES: None at this point. 7. WITNESSES TO BE CALLED: Attached hereto as Exhibit "A". 8. NAME, ADDRESS, SUBJECT OF TESTIMONY Attached hereto as Exhibit "A". 9. STATUS OF EXPERT WITNESS, REPORTS, EVALUATIONS AND STUDIES: N/A 10. STATEMENT OF OBJECTIONS OR UNUSUAL .EVIDENTIARY PROBLEMS EXPECTED TO ARISE AT TRIAL: N/A 11. SPECIAL REQUESTS, UNCOMPLETED MATTERS: None. 12. STATEMENT OF SETTLEMENT PROSPECTS: Father will cooperate to ensure that Mother has reasonable visits so long as they are supervised to the degree which would ensure the safety of the Children. _ 13. ESTIMATED TIME NEEDED FOR TRIAL: One Half Day roger R. L una, r., Esquire Attorney for efe dant Supreme Court . No. 75900 LAGUNA REYES MALONEY, LLP 1119 North Front Street Harrisburg, PA 17102 (717)233-5292 LOUISE SIGNOR, . Plaintiff V. . RANDY S. SIGNOR, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Defendant NO. 01-5352 CIVIL TERM ORDER OF COURT AND NOW, this 13th day of October, 2003, this hearing is continued for a full hearing on the merits commencing at 8:45 a.m., Tuesday, October 21, 2003. Roger R. Laguna, Jr., Esquire For Defendant Louise Signor, pro se Plaintiff Sheriff prs Cssoc~i- ~ ~~~ler~t~.he. ~i uer) ~ n l0.-S U~c~S (~ (~ IS cj cflq 4(1 0.. ~O~Ff..` o~q,~, J ~n~11~e~- S~ o~~- LOUISS SIGNOR IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNA~„_., RANDY S. SIGNOR CIVIL ACTION - LAW Defendant CUSTODY ORDER OF COURT AND NOW, this day of 2001, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before the conciliator, at on the 2001, at m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a temporary order. 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. FOR THE COURT, By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference 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 THS OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Ave. Carlisle, PA 17013 (717) 249-3166 LOUISE SIGNOR IN THS COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY,(~~PENNA. RANDY E. SIGNOR CIVIL ACTION - LAW 1 Defendant CUSTODY COMPLAINT AND NOW, comes Plaintiff, Louise Signor, by and through her attorney, James W. Abraham, Esquire, Abraham Law Offices, Harrisburg, Pennsylvania, and files the following: 1. Plaintiff, Louise Signor (hereinafter "Mother") is an adult individual who currently resides at 751 High Street, Apt. B, Lancaster, Pennsylvania. 2. Defendant, Randy E. Signor, is an adult individual who currently resides at 328 4th Street, New Cumberland, Cumberland County, Pennsylvania. 3. Father and Mother have one (1) child together as they are the natural parents of Tyler A. Signor, age 4, born December 18, 1996. There are three (3) other minor children involved hereto as follows: Amanda L. Amaker, age 11, born December 15, 1989 Sric R. Amaker, age 13, born May 12, 1988 Holly E. Signor, age 13, born August 5, 1988. Amanda L. Amaker and Sric R. Amaker are the natural children of Mother and the step-children of Father. Holly S. Signor is the natural child of Father and the step-child of Mother. 4. On August 11, 1998, an Order of Court was entered in the Court of Common Pleas of Dauphin County, which provided Father with primary physical custody of Tyler Signor, Amanda Amaker and Hollie Signor. The Order did not reference Eric Amaker. A true and correct copy of the Order is attached hereto as Exhibit nAn 5. In November, 1998, Mother commenced a custody action in Cumberland County which did not resolve in any court order as the parties eventually reconciled in May, 1999, after Mother's release from Dauphin County Prison, in which she was imprisoned on DUI and reckless endangerment charges from February through May, 1999. A true and correct copy of the Cumberland County Order terminating the custody action is attached hereto as Exhibit "B". 6. For approximately the past two (2) years, from May, 1999 through August 1, 2001, all four (4) children resided with Mother and Father at the former marital residence at 348 4th Street, New Cumberland, Pennsylvania. 7. On or about August 1, 2001, the parties separated and Mother moved to the aforesaid Lancaster, Pennsylvania address with Eric Amaker. Tyler Signor, Amanda Amaker and Hollie Signor remained with Father in New Cumberland, Pennsylvania. 8. The parties have a temporary Dauphin County Order dated August 30, 2001, pursuant to an Emergency Petition filed by Father, giving Father primary physical custody of Tyler Signor, Amanda Amaker and Hollie Signor and partial custody to Mother. Eric Amaker remains with Mother in Lancaster. A true and correct copy of the Order is attached hereto as Exhibit "C". 9. Mother believes and therefore avers that the parties agree that Mother shall have sole legal and physical custody of her natural child, Eric Amaker; and that Father shall have sole legal and physical custody of his natural child, Hollie Signor. 10. As to Amanda Amaker and Tyler Signor, Mother submits that the best interests of said children shall be served by granting Mother sole physical and legal custody of her natural child Amanda Amaker and primary physical custody of the parties' child, Tyler Signor. WHSRSFORE, Plaintiff/Mother Louise Signor, respectfully requests Your Honorable Court, to grant Mother primary physical custody of Tyler Signor and sole physical and legal custody of Amanda Amaker and Eric Amaker; and to grant Father sole physical and legal custodian of Hollie Signor. Respectfully submitted: James W. Abraham, Esq. Abraham Law Offices 513 North Second St. Harrisburg, PA 17101 (717) 232-7825 Attorney for Plaintiff, Louise Signor DATE: 9/10/01 . , VERIFICATION I, ~~ ~ ~ ~~ G ~ ~~ the undersigned, hereby verify and confirm that I have reviewed the foregoing document and the statements therein are true and correct to the best of my knowledge, information and belief. I further understand that any false statements made herein are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. / ~._ DATB : ~ ~ 30 '-~ J ~~~~L- RANDY E. SIGNOR, TN THE COURT OF COMMON PLEAS Plaintiff DAUPxZN COUNTY, PENNSYLVAx*.A v• CIVZL ACTION-DIVORCE-CUSTODY LOUISE SIGNOR, No. 2816 S 1996 Defendant ORDET2 OF COURT AND NOW, this~~ day of , 1998, a Custody Mediation Conference having been ached d, Plaintiff having appeared with Counsel, and Defendant having failed to appear despite the effectuation Of valid service, it is hereby ORDERED AND DECREED as follows: 1, The parties shall have shared legal custody of the sub.~eot minOZ' childYsn, Raridy E. Signor,Jr „ born November 26, 1980, and Holly M, Signor, born August 5, 1988, Amanda L. Amaker, born December 15, 1989, and Tyler J. Signor, born December la, 1996. 2. Plaintiff Randy E. Signor Sha11 have primary physical custody of the sub9ect minor„children.-.,. __ ~._-. 3. Defendant Louise Signor shall be entitled to reasonable, liberal, and frequent periods o£ partial custody, with the exact details subject to the agreement and express consent ct both parties. 4. In light of allegations regarding substance abuse problems, each of the parties are specifically directed to take EXHIBIT . '... whatever steps ar,e necessary to ensure the subject minor children reside in an environment free from the use of alcohol and illegal narcotics, during their custodial periods, 5. This order is temporary in nature, such that in the event Defendant Louise Signor should desire custody or additiona_ periods of partial custody, then she may request an additional custody mediation conference by filing the appropriate motion with the Office Of the Prothonotary. However, in the event that more ... than thirty days elapses after the date of this Order, she wili then be required to file a P®tition in the county of appropriate venue. 6. It is specifically agreed by Plaintiff and nis attorney that any additional matters relative to this custody case shall be filed in Cumberland County, because that has been the residence of the children for a period in excess of six months, as well as the residence of the Plaintiff. Likewise, it is further noted that the mother resides in Baltimore, Maryland. BY THE COURT: Oci~G~'a -~~/- ~-~ ~~ ~~ ~, I hart?b~/ (~F1(Ciil'/ the+, the for~go;~^g is a ir(,~~~ a!~.~a c:,r>e~c+: ^~:,;:;,.,y,,q ..n~ original I //~ Froth notary e. + ~J ~ LOUISE SIGNOR, ) IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, PENNSYLVANIA vs. ) N0.98-6615 CIVIL TERM RANDY E, SIGNOR, ) Defendant ) CUSTODY/VISITATION ORDER OF COURT AND NOW this 6 7~~ day of , 1999, having not heard from the parties since the filing of the Complaint in January, 1999, the undersigned Conciliator assumes the matter has been resolved and hereby relinquishes jurisdiction of the case. If either of the parties wishes further proceedings in this action, they should petition the Court anew. FOR THE COURT, ANGS MICHAEL L Custody Conciliator cc: James t~~. P.braham, Esquire Randy E. Signor 328 4« Street New Cumberland, PA 17070 EXHIBIT .._ .~....~~. w, RANDY E. SIGNOR, IN THE COURT OF COMMON PLEAS Petitioner DAUPHIN COUNTY, PENNSYLVANIA VS. N0.2816 S. 1996 r~~ LOUISE SIGNOR, === Respondent CIVIL ACTION -CUSTODY - ,. ~._~ _ ORDER ~ _~- '- ; c ra /~ u~ AND NOW, this ~~/ day of August, 2001 upon consideration of the ir~hambers conference with counsel, the Court hereby ORDERS that the Petitioner, Randy Signor, shall have primary physical custody of Holly M. Signor, born August 5, 1988; Amanda L. Amaker, born December 15, 1989; and Tyler J. Signor, Born December 18, 1996 subject to the mother's partial physical custody every weekend from Friday at 6:00 p.m. until Sunday at 6:00 p.m. The mother shall provide the transportation on Friday for pick up and father shall pick up the children on Sunday evening. The parties acknowledge that this Court does not have jurisdiction to hear any further matters related to this case and this matter shall be heard and filed in Cumberland County Court of Common Pleas as promptly as possible. AUG 3 0 2001 I h~re~y' csrtily thCi the foregoing final true ai7d corrVct Copy of the p±~g filed. Prothonotary Distribution: BY THE COURT: odd A. Hoover, Judge Roger R. Laguna, Jr., Esquire, l5 North Front Street, Suite 203, Steelton, PA 17113 James W. Abraham, Esquire, 513 North Second Strcet, Harrisburg, PA 17101 Deborah S. Freeman, Esquire, Deputy Civil Court A dministrator EXHIBIT CERTIFICATE OF SERVICE I, James W. Abraham, Esquire, the undersigned, do hereby certify that I have served a true and correct copy of the foregoing document, by first class mail, on the date indicated below, to the following person(s): Randy E. Signor 328 4th St. New Cumberland, PA 17070 DATE: 9/10/01 James W. Abraham, Esquire C ~ ~ d ~ ~ nv ~' J R~i;~ ~_i.1 ~__ ;.: L r -:~ .~ f'i "7 ~~ ~~ :~ ~~ ci ~r_. - ' ~;; -1'l Vii} L7 T T ~J JEANNE B. COST'OPOULOS, ESQUIRE The Executive Offices at Rossmoyne 5000 Ritter Road, Suite 202, P.O. Box 779 Mechanicsburg, PA 17055 West Shore (717) 790-9546 East Shore (717) 221-0900 October 8, 2003 Office of the Prothonotary Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Re: Louise Signor v. Randy S. Signor Custody No. Ol -5352 Dear Sir or Madam: E-mail: jbclegal(a~aol.com Facsimile: (717) 790-6019 Enclosed for filing please find an original and four copies of a Praecipe to Withdraw Appearance. l have also enclosed aself-addressed, pre-stamped envelope in which to forward to me the extra time-stamped copies of the Praecipe. Thank you for cooperation. Sincerel ours, e B. Costopoulos, Esquire CC: Hon. Edgar B. Bayley Roger R. Laguna, Jr., Esquire File LOUISE SIGNOR, :THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 01-5352 RANDY S. SIGNOR, :CIVIL ACTION - AT LAW Defendants :CUSTODY P)Zjf1FC'iPF. Tn WiTFTDRAW APPF,ARANCF To the Prothonotary: Please withdraw the appearance of Jeanne B. Costopoulos, Esquire, as attorney for the Plaintiff, Louise Signor. Dated: /~ ~ Q-3 ~~~_ BY: Jeanne B. Costopoulos, Esquire 5000 Ritter Road, Suite 202, Box 779 Mechanicsburg, PA 17055 Phone: (717) 790-9546 Supreme Ct. ID No. 68735 LOUISE SIGNOR, :THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 01-5352 RANDY S. SIGNOR, :CIVIL. ACTION - AT LAW Defendants :CUSTODY I, Jeanne B. Costopoulos, Esquire, hereby certify that this day I served a copy of the attached Praecipe upon the persons, and in the manner, indicated below, which service satisfies the requirements of the PA Rules of Civil Procedure, by depositing a copy of the same with the United States Post Office at Mechanicsburg, Pennsylvania, through first class mail, prepaid, and addressed as follows: Roger R. Laguna, Jr., Esquire 15 North Front Street, Suite 302 Steelton, PA 17113 ~~ BY: J e B. Costopoulos, Esquire 5000 Ritter Road, Suite 202, Box 779 Mechanicsburg, PA 17055 Phone: (717) 790-9546 f B ~~/off Supreme Ct. ID No. 68735 Dated: Oct-07-03 05:02P Alex J. Sugden HOLIDAY ROYALE 4505 PARADISE RD. LAS VEGAS, NEVADA 89109 (702) 733-7676 (702) 733-7123 FAX 702 822 6547 P.O1 FACSIMILE COVER SHEET DATE: '~ ~~~ ~ l ~3 TO: `j~~-~ ~ ~~ FROM: ~,~ot~~~~ 5;~,~~r YOUR FAX # `-~ t Z -133 - `Z 1 Z 3 REFERENCE: NUMBER OF PAGES INCLUD~N6 THIS COVER SHEET: NOTES: ~ Oct-07-03 05:03P Alex J. Sugden 702 822 6547 P.02 I~IZ SIGNOR ---- 'I'el: 717-733-7676 ext. 2409 I'ax:702-733-7123 QvcizzieQaol.com October 4, 2003 .alto: The Honorable Judge Baley Cumberland County Court House Court Room #2 Carlisle, Pa. Subject: Signor Vs. Sigrror liearing Date: October, 13, 2003 Custody Ht~ring. Your Honor: i 1 am sending you this letter to inform the court that 1 have decided to represent myself in the above reference hcering. I am due to appear before you on the date stated above, I have decided to dismiss my Attorney of Record Jeanne B. Costopobus. And 1 feel that even though, 1 am not legally trained I feel that 1 am best to represent my case in this matter. I humbly ask the court to grant this request due to the lact that I fcel no one is better to voice our, the kids and my feelings, wants, and wishes. Eric and Amanda wish desperately to speak to you in my favor on this matter. Eric being 15, and Amanda being 13 are capable of voicing their own opinions. 'they are not the natural children of Randy Signor, nor did Rertdy ever attempt to adopt my children. 1 have a document of custody from York County Couri House giving custody of Amanda and Eric to me from my first marriage. [beg the court to grant the wishes of Eric and Amanda and myself to all be together again. And 1 am asking the mercy of the court that you find that the best interest of Tyler Signor, age 6, be with me as well; and for his father have him summer momhs and 'some holidays, he is still such a baby and needs his mother's love. I feel the best interest in the kids growth is having both parents in their lives. Which as you hear this case you will sce that Randy did not have the feelings of the children at heart. 1 also ask the court to immediately put this whole ordeal m an end, so that the children may have some peace and we may all go on with their life. Oct-07-03 05:03P Alex J. Sugden 702 822 6547 Page 2 continued October 4, 2003 You may nut recall of the fact that there was an existing Temporary order, and Randy violated the Order that was signed by yourself, Judge Baley. 1 just, by the grace of God found the children four months ago, I had curt had contact, e-mail etc. from the children. Randy kidnapped the kids from Cumberland County, changed phone numbers, and by the Grace of Gad I did trod the children. Randy hidden them for two years. My childrai and I look forward to your favorable ruling. Respectfully submitted, P.03 Liz Signor OGt-07-03 05:03P Alex J. Sugden AOI:.~OM ~ Message View Subj: Custody Conference 9/23 10:30am Date: 9/20/2003 3:23:49 PM Eastern Daylight Time Fram: JB.C,legal To' QVCLIZZIE Liz: 702 822 6547 P.04 Page 1 of 1 As you may recall, fhe current court order dated August 12, 2003 schedules a custody conaGatlon conference before McSssa Greevy an September 23, 2003 at 10:30 a.m I contacted Ms. GreevyS office and was informed that, despite recent events, the conference will take place as scheduled unless Mr. Laguna and nryself agree to continue it. What is your position reganting tli~ conferenceT If it is not continued to a later date, you will either need to appear at the conference ar, it you're still in N~ada, you will need to tail Melissa's office (717) 761-4540 at 10:30am on the 23rd so Chet you may partidpate by phone. Also, if you want me to represe~ you at the conference on the 23rd, I will need $500.00 immediatety. Please inform me of your pMns as soon as possible. -Jeanna 8. Costopoulos, Esquire httpa/webmail, aoLcom/fmsgview.adp?folder-SUSCT l g=&uid=7099112 10/412003 Oct-07-03 05=04P Alex J. Sugtlen 702 922 6567 P.06 AOL.COM ~ Message View Page I oC 1 Subj: HEAR[NG Date: 102/2003 2:44:50 PM Fastem Daylight Time Fran: QVCI,.IZZIE To: JBClegal 1 recieved your message oltw headrp date 1 do not need M'm date to be eontlnum, this dale vall belw[ fiw, however i w01 not be nwtling your services at this time, l have N covered you rare given a lee of 7w.0g which gave me satumaya vmh the children, i made numerous eyrratls ro you wnwming the ummppkcess o1Na children and hewNhrga ware. pt no time did you over mention a emargenry peg0on of tegMto me urrtll hook meIXere inhp my own hantls and Yndad in jail. and rt Ma Aug. maegng to from of Melissa I did wt agne on anyllring wrdM-i sign enyNing. Ne oM temporary '~ omer vas vacated and theirww wegreemem oNmNianrorrtum In/rom oT Melkssa sometkw hr 8eptembm.8o '' NaMOre m my urmerarendlrrg there was no omen In eReel. Now as Issas Nls lecl meaNrg In from of Measaw well i was given e 2 day nelleo of Nis evenR and i egg have no Hw whmtaok glade m Nis meeNrg~otlrerNen you ahding Nm you shored up wiNort my consem arrd'thet K is being wmm sludge, whkh Ira toM would have heppanW anyway.8o 1 do not foul Nm i ore you anyNiog rtNm gme TH11NK YOU FOR TIIE TIME YOU WERE ARLETO HAVE MY fa111DREN AND 1 TOGETIER, D11T I BELIEVE THAT WK.L RE ALL FOR NOW. http://webmail.aol.com/fmsgview.udp7Colder/fl VUQk9Yffiuid=7181807 ]0/4/2003 une~ mums Verner war rile a is son hard working nn ur fee[ all day i door know how a wcrca +aai[reas working that 4nu~ and all week!! i knt•w not rn ¢ive a yoVS a hard Iimc when u get oFl~wurk anise no+a i knnn how it feels and my uevk hurts'." bul it wns f in i worked ar the cash rcgisler and i gut ? dollars in tips....i hod a Ill.l' for lunch today ii rca• eummv' i xn >0 dollarv uvlav._heener was gonna rnke me w uet ay nails done cause she ~~oi herz done {as[ '+etk hur i ha.'c k+uo+ vet rojamie's later so i c<wldnl go and next week she wens to _A her belly peirttd and she ++ank meld ear mine done, boil am hw fat for shall lol....would it be okay i{'i did Bel ii ions"'9li haven ask you since YIl he under ur "hons¢ roles" soon lol) well i am coons go Uyl love ya hvc ~Lwda Oct-07-03 05:06P Alex J. Sugden AOL.COM ~ Message View Subj: (no subject) Date: 9/22/2003 4:45:24 PM Eastern Daylight Time From: Babygirl26008 To: QVCLIZZIE 702 822 6547 P.O1 rage ~ or ~ Iu°. n•om i jus, wantec: t+. email a and see hnw a were..u havent emailed me back i am a Kittle ~~on-ied _well ya know + i a, .+enev r, :a2 arc alb Hurd to ,_o o ith u i vcanna go cause randy is driving me cr.tzy wU tried ,o say that the money ~h,a makr +c ~1 4,u to hills welt if he didnt spend it on everything else then he would have money fix bills...and h~ n t,,dav hr •aiel we w~•rent allowed to go ne where because i wanted to eo to the ~,amc ._.hr is so ignorant !!' well i nr s~.umu, :_~,, just wmtlyd w know that a were okay .love ya bye rut, ula http://webmail.aol.comlftnsgview.adp?folder-SUSCTIg-8tuid=7111006 10/4/2003 Oct-07-03 05:06P Alex J. Sugden 702 822 6547 P.02 AOL.C'gM ~ Message View = os~ • ~_ Subj: Re: (no subject) Date: 9!29!2003 4:57:48 PM Eastern Daylight Time From: Babygir12G008 To`. QVCLIZZIE hey mom... i miss you too...well aol is getting taken away my sn for walmart is runswithmice...lo! great huh? erics is elephantking007 (yeah i made that one too) i cant talk long cause randy is complaining about die emails and that my attitude is changing:.well its not he just never listens to what i have to say...the number is 903 2296..gota go people coming..i'll write later love ya bye..oh and i dont have minutes yet but u could text me ....and uhm dont let ne one know that i gave u the number cause randy doesnt know that i am getting minute cause he dcesnt want me to have them...well i'll watch for the pics..love ya bye ..eric and ty say hi ,;:,~~ l ~k~1 Cn~CC ~ ~71a~1~~s5.C.~~ http:/.~webmail.aol.comlfmsgview.adp?folder-SUSCTIg-&cuid=7159599 1014/2003 Oct-0703 05:07P Alex J. Sugden 702 822 6547 P.03 1©/07(2f1f13 13:ff5 8435452411 L,RIraLliv g55uKUnt.t r,.u~ u~.,.< October O6, 2003 To whom it may concern: I am vomiting in reference to the custody decision of Eric and Amanda Amaker. My name is Ann Amaker Kaminskas. 1 am ft~eir aunt form South Carolina. 1 have not seen my niece and nephew since July 10, 1998. Before that time, they visited with me on a regular basis when possible. I was very cbse to both Eric and Amanda from the tune they were bom until about 5 years ago. U faa, they both lived with my family and me for an extended period of time while Louise was frying th get some personal problems worked out. My husband and I fullysupporfed them during this time and loved them as if they were our own. When Lour anal Randy got back together to try to work thjngs out, Eric and Amanda left here and',w~t back to Pennsylvania to be with them. I was heartbroken when they left, brut had no choice but to see them off. Af, that time there was a verbal agr~mentimade between us that Eric and Amanda would spend the school months With Louise in Pa. grid the summer months with me in SC. We all vranted what was best for the children, which was to be imoMed in aN our Nves. The last time they came to visit was from June 13,1998 until July 10, 1998 when Louise and Randy were still together. I talked to them on the phone a few times after that but lost touch when the phone number that I have is no bnger in service. They have not been allowed to caU nor have i seen them during the time that Randy has had them. Although I know that I have an out-of-service number, 1 have continued Zo try to contact them periodically with the last time being May 12 of this year on Eric's birthday. Randy has kept them from having arty contact with me. This cannot be a good situation for the children. I understand that Louise has finally been able to locate her children and they waM to be reun'2sci with her. Ialso-want very much to be a part of their lives again but know thatrf they remain with Randy my chances of seeing them are very slim, as are their chance of knov+ing'their extended family. What is best for them is at stake here and they need to know flow much their family bves them. Please consider this, along with then wishes, when making your decision. Thank you. l/~ - Oct-07-03 05:07P Alex J. Sugden 702 822 6547 P.04 7"o cv~.orr. i '~` P•w~ CoNeErN. Nt 'Che uN~(~ o`~ ERt'e nwd A„,A.~da A~.a. i{eR,. S' v.,afc.~.ed -(~.s K.;ds ~Rorr u~J {~r,~` ~wuEw~ See r.~ -then.. I q~css i u A b«, ~f- S yed '~_ .~' ttvE ;~ 1-~eR~etf~{ jslr,,,ad, Fl. 9w ~ wov 1 t ucay M~~L~ tike tp u'is~'~ `th~~ ,~Fd~ ~pD~. ~IRVC `I'~Crh COr~.E' rr'iSi~" ~~~4.0~ mgt T~~'~lc~. 1 ~h~ E A ~ ~caR c/~ ~jou, ~.J `f~e~ ~ Causi a `t~.~~ hRu~ NeueR S~EtJ. ~e~ ARE UCR~^~uc(~ PAR d'T 'tI~E ~aICE.~ ~,a~~ ~~. ~. ~~soN ~~ ~-~,,~ k -~ti~~ ~~a~ ~~ be ~~~~ ~y~ wit to be ~,tt~, ?d~E~t~ -'-~a~-h~+~ . 1 uaAN ~ `fio ~Efi' m ~~ ~'oac(,~ w~tt~ `th.Fw, ,~Nd ~-ae oN/~ 4,/,rte 1 c~11 ~E-~- ~ N ~`pvC ~ raAau t~ 6G ~/11QOt~q''l, 7~,Cr 1~ (~t~~°~ ~c~ wog (~ be ~~~ti b~.Ytc.~e. a'~' l~v~ ~g l.~ i x'11 "t ~Gi i~ mo7`jiE'~ W ~ I l i ~ ~. ~~a EC~'r~ ~~ ®~_ S, Tl1e,~ 1Cicls K~o~,, wL C L~ :, ~N' c~~ L(Rn,. ~~ z~ w,~95:zt ~z 9e •soo 2599 CBL .'97 : '0N 3K1FId a,ois tp1~ s a~~ wniNS : wozu Oct-07-03 O5:O7P Alex J. Sugden AOL':GQM ~ Message View 702 822 6547 P_O5 Page 1 of 1 Subj: Re: Custody Conference 9123 10:30am Date: 9/25/2003 9:12:42 PM Eastern Daylight Time From: 16Clegal To: QVCLIZZ.IE Too late for the continuance, the conference was held on 9/23. I attended it on your behalf and you owe me $500.00. Your case is being sent up for a hearing before the judge, and in the meantime (since you cannot be trusted not to take offwith the kids), your visitation will now be supervised at the YWCA visitation center in Harrisburg. I will let you know the hearing date upon receipt from the court. In the meantime, if you're back in town let me know so we can schedule you a visit with the kids at the Y. Jeanne B. Costopouios, Esquire hnp://webmail.aol.com/fmsgview.adp?folder-SUSCTIg~uid=7137304 10/4/2003 Oct-07-03 05:08P Alex J. Sugden AOL:COM ~ Message View Subj: Re: hi sweety Date: 9/20/2003 6:26:18 PM Eastern Daylight Time From: Bab)'gir126008 To: QVCLIZZIF. 702 822 6547 P.06 Page 1 of 2 ~.ml« mom' bct:ncr +aas me it is snu hard +tiori:in4.; on ur feet all day i dclnt know how a were a t+.ritress working that i(,n and all ++tek'? i knew ^ot to s~i+o a Buys a hard time when u get off work cause now i knoo. ho+a it leds and my ncti k hutts~" b rt it was f.m i worked at the cash register and i got 5 dollars in tips....i had a F31.1 For lunch-today it trl. •. unvnr! !UI ~(1 dol far. loday .,hccner was canna take me tcl <_et my nails done causr ,Ill cot hers done last ~u~.k. .hut i li.,vc to o ewer ti:jamie's later so i couldnt go and next week she wants to s~~t her belly peirc;ed and she •.~ a,ns me t:, ~~~ t urine doac. but i am too fat (or thaC lo] ....would it be okay it'i did eel it done""'' (i have to ask you since i'll be uti;ier ur "house rules" soon Inl) well i am Yunna go ttyl love ya bye \landn http://webmail.aol.com/fmsgview.adp'?folder-SUSCTIg=&uid=7099864 10/4/2003 ,~ _. LOUISE SIGNOR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF 01-5352 CIVIL ACTION LAW V. RANDY S. SIGNOR DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, September 18, 2001 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. ,the conciliator, at 214 Senate Aveuue, Suite 105, Camp Hill, PA 17011 on Tuesday, October 23, 2001 at 11:00 a.m. for aPre-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 nan•ow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Melissa P Greev~, Esq~ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. iF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717)249-3166 -~ ~j ~~ ~l ° ~©~~~ y~~~ ~T,y~~i°,~hsurd=~ ~.: :~~ 1~ ~ LOUISE SIGNOR, Plaintiff AUG'~/12003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.01-5352 CIVIL TERM v. RANDY S. SIGNOR, Defendant BAYLEY, J. ---- CIVIL ACTION -LAW IN CUSTODY ORDER OF COURT AND NOW, this _( Z-day of August, 2003, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. This Court's Order of November 5, 2001 is modified as follows. 2. Physical Custody. Father shall have primary physical custody of Eric Amaker, born May 12, 1988; Amanda Amaker, born December 15, 1989; Tyler Signor, born December 18, 1996; and Holly Signor, born August 5, 1988. Mother shall have partial custody of Tyler, Eric and Amanda in accordance with the following schedule: A. On July 19, 2003 from 9:00 a.m. to 1:00 p.m., on July 27, 2003 from 3:00 p.m. to 7:00 p.m. and thereafter, effective August 2, 2003, each Saturday from 9:00 a.m. to 5:00 p.m. The parties shall meet for these visits at the park in Highspire, Pennsylvania. 3. It is acknowledged between the parties that they are experiencing serious divisions within their relationship, which are in turn having an adverse impact upon their ability to co-parent the subject minor children. In furtherance thereto, the parties shall participate in out-patient therapeutic family counseling to occur between Mother and the children and to occur with the parties together. The purpose of the co-parent counseling shall be to assist the parties in dealing with their communication skills and help them to better co-parent the minor children. The parties shall extend their complete cooperation to the therapist and follow any recommended course of evaluation and treatment. Failure to do so shall constitute a direct violation of this Order of Court. 4. The parties shall sign releases of information sufficiently broad to permit the release of a report to counsel regarding the parties' progress and attendance. ~.. r "' NO. 01-5352 CIVIL TERM 5. The Custody Conciliation Conference shall reconvene on September 23, 2003 at 10:30 a.m. at the office of the Custody Conciliator, Melissa Peel Greevy, Esquire, 301 Market Street, Lemoyne, PA 17043. BY THE COl'1RT: r Edgar Dist: Jeanne B. Costopoulos, Esquire, 5000 Ritter Road, Suite 202, Mechanicsburg, PA 17055 „. _ , ~ Roger R. Laguna, Jr., Esquire, 1119 N. Front Street, Harrisburg, PA 17102 ~-~`9 p_/~.d3 :wawu' -+~tis~'+faean~eoase..u ~ ,nun~csau~~~wz~~s,: tr„u . ~rea.ww a:w. .~ •~4.r'.e~rew ire' _ _ _ t ~5 ],. G~ h~~ ~ ~ , ~ -~7 K . ~~- ~- =_ '~ i i;~ ` ~ ~r J '-J '~ t °~ ~ - --- . r _, ~. ~. J ~ Y LOUISE SIGNOR, Plaintiff AUG 1 11003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5352 CIVIL TERM v. RANDY S. SIGNOR, Defendant CIVIL ACTION -LAW IN CUSTODY 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 Tyler A. Signor Amanda L. Amaker Eric R. Amaker Holly Signor DATE OF BIRTH December 18, 1996 December 15, 1989 May 12, 1988 August 5, 1988 CURRENTLY IN THE CUSTODY OF Father Father Father Father 2. The parties were seen for their second Custody Conciliation Conference on July 17, 2003 with the following individuals in attendance: the mother, Louise Signor, and her counsel, Jeanne B. Costopoulos, Esquire; the Father, Randy S. Signor, and his counsel, Roger R. Laguna, Jr., Esquire. 3. The. parties reached an agreement for a temporary Order in the form as attached. The Order will be reviewed at a Conciliation whi ill be set for September, 2003. iO Date Melissa Peel Greevy, Custody Conciliator :216774 LAGUNA REYES MALONEY, LLP ocr r X003 `~ 1 1 1 9 NORTH FRONT STREET, HARRISBURG, PENNSYLVANIA 1 7 1 02-33 1 8 TEL.: (71 7) 233-5292 /FAX: (71 7) 233-5394 LRMQa STANFORDALUMNI.ORG ROGER R. LAGUNA, JR. LAURA C. REYES MALONEY October 3, 2003 Prothonotary Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 RE: Louise Signor v. Randy Signor, No. 01-5352 To the Prothonotary: Please fmd enclosed an original and three (3) copies of Defendant's Memorandum for Custody Pre-trial Conference, in the above-referenced matter. Kindly time-stamp the document and keep any extra copies in the file. If you require anything further, please contact me directly and I shall provide it. Thank you for your assistance in this matter. Sincerely, ~• l~ _ ~.uw.tln~ Ro r R. Laguna, Jr., Esquire RRL/naa Copy to: File ENCLOSURES (4) LOUISE SIGNOR IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. RANDY S. SIGNOR DEFENDANT • 01-5352 CIVIL ACTION LAW IN CUSTODY ORDER OF COiTRT AND NOW, Wednesday, Juue 11, 2003 upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. ,the conciliator, at 301 Market Street, Lemoyne, PA 17043 on Thursday, July 17, 2003 at 12:30 PM for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Melissa P. Greevlt, Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~~a `~- ~ ~ '`~ ~~J Via- ~j. ~ ~/JPJH~1,tS~1l~3~ SS J ;a r~~ fi r ~ ~. ~ v ~.., ~,~~ i LOUISE SIGNOR, :THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 01-5352 RANDY S. SIGNOR, :CIVIL ACTION - AT LAW Defendants :CUSTODY AND NOW, this day of , 2003, upon consideration of Plaintiff's Petition to Modify Custody, it is hereby directed that the parties and their respective counsel appear at before ,the conciliator, on the day of , 2003, at .m., for aPre-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 the scheduled conference. FOR THE COURT: BY: Custody Conciliator The Court of Common Pleas of Cumberland County is required bylaw to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. lF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 LOUISE SIGNOR, :THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 01-5352 RANDY S. SIGNOR, :CIVIL ACTION - AT LAW Defendants :CUSTODY AND NOW, the Plaintiff, Louise Signor, by and through her attorney, Jeanne B. Costopoulos, Esquire, avers the following in support of this Petition: 1. Plaintiff, Louise Signor, is an adult individual who currently resides at 631 Clermont Avenue, Lancaster, Lancaster County, Pennsylvania, 17602. 2. The Defendant, Randy S. Signor, is an adult individual who currently resides at 233 Market Street, Highspire, Pennsylvania, 17034. 3. There is one dependent child from the relationship of Plaintiff and Defendant, namely Tyler Signor, born December 18, 1996. In addition, there are two dependent children of Plaintiff in the custody of Defendant, who is not their biological father, namely Eric Amaker, born May 12, 1988, and Amanda Amaker, born December 15, 1989. 4. The Plaintiff seeks primary physical custody of the following children: Name Present Residence Age Eric Amaker 233 Mazket Street 15 Highspire, PA 17034 DOB 5/12/88 Amanda Amaker 233 Mazket Street 13 Highspire, PA 17034 DOB 12/15/89 Tyler Signor 233 Market Street 7 Highspire, PA 17034 DOB 12/18/96 The children named above are presently in the custody of Defendant, Randy Signor, who currently resides at 233 Market Street, Highspire, Pennsylvania, 17034. The natural mother of the children is Louise Signor, Plaintiff, currently residing at 631 Clermont Avenue, Lancaster, Lancaster County, Pennsylvania, 17602. The natural father of Tyler Signor is Defendant, Randy S. Signor, currently residing at 233 Market Street, Highspire, Pennsylvania, 17034. The father of Eric Amaker and Amanda Amaker is Bobby Amaker, whose current address is unknown. Plaintiff and Defendant are married to each other, but have been separated since 2001. 5. The relationship of the Plaintiff to the children is that of natural mother. The Plaintiff currently resides with the following persons: Plaintiff sroommate -Paul Rompalo. The relationship of the Defendant to the child Tyler Signor is that of natural father. The relationship to Defendant to the children Eric Amaker and Amanda Amaker is step-father. To Plaintiffs knowledge, Defendant resides alone with the subject children and his other daughter, Holly Signor. 6. Plaintiff does not know of a person not a party to the proceedings who has physical custody of any of the children or claims to have physical custody or visitation rights with respect to the children except perhaps Bobby Amaker, who currently does not have physical custody of any of the children and whose current address is unknown. 7. The parties were previously involved in litigation regarding custody at the above term and docket number. A Temporary Order of Court was entered by the Honorable Edgar B. Bayley on November 5, 2001 following a Custody Conciliation Summary Report submitted by Melissa Peel Greevy, Esquire, Custody Conciliator, dated November 2, 2001. The Temporary Order and the Summary Report are attached as Exhibit A. 8. Defendant stopped abiding by the Temporary Order in December of 2001 and as a result, Plaintiff did not see any of her children from December of 2001 until the present, except that within the past few weeks she did make arrangements with her daughter to meet with her and they briefly maintained contact by a-mail and via a cell phone provided by Plaintiff until all such contact stopped abruptly. Plaintiff is unaware when Defendant relocated with the children to Highspire, Pennsylvania. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an order granting her full primary and legal custody of Eric Amaker and Amanda Amaker and granting both parties shared physical and legal custody of Tyler Signor. Dated: ~!/ Respectfully submitted, Jeam B. Costopoulos, Esquire ATTORNEY FOR PLAINTIFF 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Phone: (717) 790-9546 Supreme Ct. ID No. 68735 I, Louise Signor, hereby verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of I8 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date: V-~ U~ Signature: ~{y~f/1 uise Signor ~ LOUISE SIGNOR, :THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 01-5352 RANDY S. SIGNOR, :CIVIL ACTION - AT LAW Defendants :CUSTODY I, Jeanne B. Costopoulos, Esquire, hereby certify that this day I served a copy of the attached Order of Court upon the persons, and in the manner, indicated below, which service satisfies the requirements of the PA Rules of Civil Procedure, by depositing a copy of the same with the United States Post Office at Mechanicsburg, Pennsylvania, through first class mail, prepaid, and addressed as follows: Roger R. Laguna, Jr., Esquire 15 North Front Street, Suite 302 Steelton, PA 17113 Randy Signor 233 Market Street Highspire, PA 17034 BY: eanne B. Costopoulos, Esquire ATTORNEY FOR PLAINTIFF Dated: 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Phone: (717) 790-9546 Supreme Ct. ID No. 68735 EXHIBIT A LOt1tSE SIGNt;R, ;: IN THE COURT Z7F Z;OMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. - NO. 01-5352 RANDY S, SIGNOR, CIVIL ACTION -LAW Defendanfi CUSTODY , • f, r nrtPO ~ Y CIOUttr AND NOW, this __~ ~ day of f e.rn , 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Randy S. Signor shad have sofa legal and physical custody of Ho11y M. Signor, born August 5, 1988. 2. Louise Signor shall have sole legal and physical custody of Eric Amaker, born May 1.2, 1988. Eric may have contact with Mr. Signor as the parties shah mutually agree. 3. Louise Signor and Randy S. Signor shah have shared legal custody of Amanda Amaker, born December 15, 1989, and Tyler A. Signor, born December 18, 1996. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Chi{dren`s general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of Pa. C. S. § 5309, each parent shall be entitled #o ail records and information pertaining fo the Ghildren including, but not limited to, medical, dental, religious or school records, and the res'sdence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, tha# 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. Both parents shall be entitled to full participation in ail educational meetings and medical/treatment planning meetings and evaluations with regard to the minor Children. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational records, attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school night, and the like. 4, The Father shall 'have primary physicai custody of Amanda L. Amaker and Tyler J. Signor. Mother sha{I have partial physical custody on three of four weekends per month, arranged as three consecutive weekends with Mother and one weekend with 1=ether and rotating between the parents three weekends with Mo#her, and one weekend with Father. r'% , No. 01-5352 -Civil Term Mother's first custodial weekend under this schedule shall commence on October 27, 2001. Mother's partial custodial weekends shall be defined as follows: from Friday at 8:00 p.m. until Sunday at 6:00 p.m.,if Mother is working the 7:00 a.m. to 7:00 p.m. shift; from Saturday at 9:30 a.m. until Sunday at 6:00 p,m. if Mother is working the 3:00 p.m. to 11:00 p,m. shift. The agreement of the parties with regard to Amanda's custody was based on the desire to leave Amanda in her present school and educational setting. Therefore, the arrangement for Amanda's custody has been agreed to by the parties contingent upon Amanda's remaining enrolled in the New Cumberland Middle School of the West Shore School District- lf, however, because of Father's change of residence, Amanda will no longer attend New Cumberland Middle School and a change of Middle School becomes inevitable, then Mother retains the right to Petition per Modification of this Order with regard to the physical custody of Amanda. ' 5.T_ransp anon. Transportation shall be provided by Father unless otherwise agreed, until such time as Mother can provide her own transportation. At that time, Transportation wilt be shared by the parties as they shat{ mutually agree. In the event that Father is not able to provide transportation to Lancaster on Friday evenings for the beginning of Mother's custodial visits, he will arrange with Mother to either bring the Children to heron Saturday morning or to meet Mother at the train station in Harrisburg with the Children. Father will coriferwi#h Mother by the Wednesday preceding her custodial weekend if this is the case_ 6. TharJlsgiying 2001. Mother shall have custody of Tyler and Amanda from 4:00 Thanksgiving Day until Sunday following Thanksgiving at 6:00 p.m. 7. Christmas. Christmas custody shall be arranged on an A/13 schedule. Segment A is December 24`" through December 25'" Noon and Segment 13 is December 25"' Naon until December 26'" at Noon. In 2001 and subsequent odd-numbered years, Father shat{ have Segment A and,Mother shall have Segment B. In 2002 and subsequent even-numbered years, Mother shall have Segment A and Father shalt have Segment B. 8. During any period of custody or visitation the parties to this Order shat! not possess or use controlled substances, neither shall They consume alcoholic beverages to the point of intoxication. The parties shall likewise ensure, fo the extent possible, that the other household members and/or household guests comply with this prohibition. 9. The non-custodial parent shall be entitled to one telephone contact per day with the Children. 10. This Order is temporary in nature and may be modified by an agreement of the parties. -~ ._ . 1 No. 41-5352 --Civil l'etm ~Y THE COURT, ~ ~ - J. Pisi• RogerR. Laguna, Esquire, 15 N. Front Street, Suite 3Q2, Steelton, PA 171'13 James W. Abraham, Esquire. 513 N. Sewntl Street, Harrisburg, PA 17101 i t~.~.iw v4~h•~ ~ri(C.~rY~ I~~~~~ti.~i~ . • ~ whercaf, ' heee ; •~ t~'~!I hao~. 4he/~seafl of sa+d teu/rt at /1~~,'1i/5ia~ P~' i~~ / 1 h Jam.. A'F W. M'I.....~ ~~~.~ ~~:::.: mow... ~ Proth,4t~ary, ~ rr ,.. , Nou o 5 2001 . ~' t.0U1SE SIGNOR, : IN TH>= COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO.01-5352 RANDY S. SIGNOR, : CIVIL ACTION -LAW Defendant CUSTODY CU__ 8~DY CONCILIATION SUMM RY R PORT 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 TH CURRENTLY IN GUSTODX OF Amanda L. Amaker Eric R. Amaker Holly E. Signor Tyler A. Signor December 15, 1989 May 12, 1988 August 5, 1988 December 18, 1996 Father Mother Father Father 2. The parties were seen for their firsl? Cumberland County Custody Conciliation Conference with this Conciliator on October 23; 2001, with the following individuals in attendance: the Mother, Louise Signor, and her counsel, James W. Abraham, Esquire; the Father, Randy S. Signor, and his ccunsel, Roger R. Laguna, Jr., Esquire. 3. The parties reached an agreement as to a Temporary Order in the form as attached. ~ ~/ "~ D ~ Date Melissa- eel Greevy, Esquire Custody Conciliator o r_ ~.,~ u~ -~t.~ .W ~ ~ ~, Its V ~ ~ nfTl 7 'i 1 . ~<j Gf ~ W ~` , y ~ -« LOUISE SIGNOR, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW RANDY SIGNOR, . Defendant N0. 01-5352 CIVIL TERM IN RE: CUSTODY HEARING Proceedings held before the HONORABLE EDGAR B. BAYLEY, J., Cumberland County Courthouse, Carlisle, Pennsylvania, on October 13, 2003, 8:47 a.m. in Courtroom Number Two. APPEARANCES: LOUISE SIGNOR, pro se Plaintiff ROGER R. LAGUNA, JR., Esquire For the Defendant FOR THE PLAINTIFF INDEX TO WITNESSES DIRECT 1. Louise Sophia Signor By the Court By Mr. Laguna FOR THE DEFENDANT 1. Randy Signor By Mr. Laguna By Ms. Signor DIS CUSSION IN CHAMBERS 1. Eric Amaker By the Court 2. Amanda Amaker By the Court 3. Holly Signor By the Court 3 CROSS 26 60 -- -- 73 EXAMINATION 86 101 97 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 October 21, 2003, 8:47 a.m. Carlisle, Pennsylvania (Whereupon, the following proceedings were held:) THE COURT: You may take the stand. Bring your things up if you wish. MR. LAGUNA: Your Honor, I was going to make a motion to sequester any witnesses that she may have. THE COURT: It is a custody case. I am not going to sequester. Whereupon, LOUISE SOPHIA SIGNOR, having been duly sworn, testified as follows: BY THE COURT: Q State your name. A Louise Sophia Signor. Q Where do you live? A Las Vegas, Nevada. Q Your address? A 4505 Paradise Road. Q Your age? A Thirty-nine. Q Are you married? A Yes, sir. Q To whom? 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Randy Signor. Q What date? A March 26, 1996. Q And you separated the last time when? A 2000. Q Do you remember the month? A I left in August of 2000. Q Where were you living at that time? A In New Cumberland, Pennsylvania. Q Do you have children with him? A One child, correct. Q And that is? A Tyler Signor, age six. Q When you were living with him, were there other children in the household? A That is correct. Q And who were they? A That would be Randy Signor, Jr., Eric Amaker. Q Randy Signor, Jr., okay. His child? A Correct. Q His son Randy, how old is he, do you know? A I think he's, like, 22 or 23 at this time. Q And then the next one? A Eric Amaker. Q And whose child is that? 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Eric Amaker is mine to my first marriage. Q Eric. Was there another child? A Amanda Amaker to my first marriage and Holly Signor. Q Hold on. And Holly Signor. Who is the father? A Randy. Q So you have two children together? A No, only one. He had two to his prior marriage. had two to my prior marriage, and we had Tyler together. Q So Holly Signor is his child? A Correct. Q How old is she? A She's 15 at this time. Q How old is Eric and Amanda? A Eric is 15 and Amanda is 13. Q When you separated, where did you go to in August of 2000? A To Lancaster, Pennsylvania. Q What children, if any, did you take with you? A I took Eric Amaker with me. Q You took Eric Amaker? A Correct. The father and I had reached an agreement. Q Te11 me what it was. A The agreement was -- school had already started. II 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Eric was to remain with me in Lancaster. Amanda was to remain in Cumberland County, West Shore School District. Should Randy move from that residence and Amanda would be changing schools anyway, then she was to come to me. And in that course -- Q Hold on, ma'am. I can't take it as fast as you are telling me. A I'm sorry. Q Amanda would remain in school in the West Shore -- A School District, correct. Q What grade was she in at the time? A Sixth or seventh. Q And then what would happen to her? The agreement was? A The agreement was if he moved from the West Shore School District she was to come with me because she would be changing schools anyway. Q What if he didn't move from the West Shore, what was going to happen? A She would stay in the West Shore School District. Q Period? A Correct, and she would come down on the weekends. Q What did you do with Amanda? A Amanda stayed in the West Shore School District. Q I'm sorry. You told me Eric. A Correct. 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q What happened to Tyler? A Tyler we were to have -- he was to bring Tyler to me on the weekends. Q He kept Tyler? A Correct. Q How long did that arrangement last? A Not long at all, maybe -- not even a month. Q Then what happened? A Christmas a friend and I took my son -- Christmas of 2001, I took my son Eric to my sister's in Baltimore for the Christmas holiday. Apparently my other children were down there along with Holly, and Randy took it upon himself to pick up my son from Baltimore, and that was the last I had seen any of my children until four months ago. Q So at Christmas he took then which child? A Eric was in Baltimore, and my other two children were also in Baltimore at my sister's on vacation. And when Randy had gone down to pick his children up and Tyler, he also picked up Eric and never brought Eric back to me, and I didn't see my children on the weekends anymore. Q When is the last time you saw them after that, the next time? A Not until -- I believe we showed up June 11th at Melissa Greevy's. Q You did not see any of your children until 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 conciliation? A Correct. Q When was that? A Well, it would have been -- I believe it was Thursday, July 17th. Q Which year? A 2003. Q Hold on. A And the arrangements -- Q Hold on. In the interim, between Christmas 2001 and July 2003, you did not see the children. Where were you and what were you doing? A I was living in Lancaster and I was working. Q Working doing what? A I was working at Dart Container Corporation and Turkey Hill Minute Market. I was working two jobs. Q And you weren't even seeing the children on weekends? A Correct. Q Why didn't you do anything in that interim period? A He moved away from Cumberland County. He moved into Dauphin County. The phone number was changed and his family -- nobody would give me any information on where he was. Q How did you find out where he was? A He's also -- I was paying him 121 a week in child 8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 support, and Domestic Relations, when I had it transferred from Cumberland County to Lancaster County, they sent me a document that was directed for the Domestic Relations, and they made the mistake of sending me his address. Q So in this entire period of time, you are saying you didn't know where he was so you didn't see the children? A Exactly. Q When you found out through support, then what did you do? A My supervisor immediately lent me money to hire Jeanne Costopoulos. I paid her $750.00, and she had me in front of Melissa in June. Q What happened then? A Okay. The old order was vacated, and we agreed until we could get back for another agreement -- Q You had a prior order, right? A Correct. That's the one that he didn't follow. Q Hold on. How did the -- you had gone and gotten an order on November 5, 2001, right? A Correct. Q And that order provided for what? A I believe that one is where -- Q Did that keep the status quo until Christmas 2001? A Yeah. In November 1998, mother commenced a custody action in Cumberland County which did not resolve in any court 9 D O 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 order. Q After November 5, 2001, you still had Eric, right? A In what year, Your Honor? Q You still had Eric? A In what year? Q After that court order, November 5, 2001. A Until December, correct. Q And he had? A Amanda, Holly, and Tyler. Q And then at Christmas he took Eric despite what the court order said? A Correct. Q And then the next time you got into court was July 2003? A Correct. Q Now, did that change anything in July of 2003? I see an order on August 12, 2003. Is that the order that came out of that? A Okay. Yes, Your Honor. Q Did that change anything? A She said it vacated the prior order. Q What happened to the children after that? A They still remained with Randy, and I was seeing them on Saturdays. Q All of .them? 10 m 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A11 of them except for Holly. Q Hold on. On Saturdays? A Correct. Q Except for Holly. What about Holly, she wasn't involved? A She wasn't involved, no, sir. Q And then what happened? A I was seeing my children on Saturdays at a park in Dauphin County. Q Supervised? A No. Q But you were coming up here? A I was driving up to Dauphin County. Q Not taking them down to Lancaster? A No, sir. And that was to reunite mom with children because it had been so long since I had seen them. The old agreement, the one that he did not follow, she said that would be vacated and we would meet back sometime in September. But until we met back and made another agreement, I was to see the children on Saturdays. Q And did you do that? A Yes, I did. Q And the children you were seeing then were what children? A Eric, Amanda, and Tyler. 11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q And then did that change at some point? A Yes, sir, it did. Q When? A It was the fourth Saturday. Of course, you know, reuniting me with the children I saw the state that my six year old was in. He's skin and bone. I asked my daughter what's going on in the house. There's a whole bunch of situations going on in the house they live in. And it came up Paul and I were moving to Nevada, and I had discussions with the children and I said I had made -- I had called so many different people. I called Dauphin County Children and Youth. I even called the Highspire Police Officer Friday night. Q Just tell me what happened first, ma'am. A Okay. So I wanted to remove them from the situation that they were in, and I made numerous e-mails to my lawyer. Q Just tell me what happened, ma'am. A And I took the children to Nevada with me. Q Which children? A Eric, Amanda, and Tyler. Q You weren't living in Nevada at that time, right? A No, we were moving out. Q You alone were moving out? A Paul and I. 12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Paul. You had been living with a man? A Correct. Q What's his name, last name? A Rompalo, R-o-m-p-a-1-o. Q Since when had you been living with him? A 2001. Q Any other children living in the household? A No, sir. Q Does he have any other children? A He has a 14 year old. Q Living with the mother? A Correct. Q And you had been living with him in what, Lancaster? A Correct. Q What was the purpose of the move to Nevada? A We had gone out -- we had taken our vacation to Las Vegas, and the tours and talking to people it's a wonderful financial -- Q You just decided to go out? A Yes, after we came back. We were going to sell the house, which he did. We just moved a little quicker when I 'found out what was going on with the kids. Q Did you move into this Paradise Road address? A Yes. 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Is that a -- A Well, I moved right into jail. Paul moved into -- Q You moved into jail. Hold on. Paradise Road, what kind of home is it, rented? A Yeah, it's rented. Q How big? How many bedrooms? A Three. Q A three bedroom apartment? A Yeah. That's not where we're going to stay. Q And so what date did you leave with these children to Nevada? A It was Saturday, August 9th, 2003. Q Did either of you have a job out there? A No, sir. Q Does he now have a job out there? A No, sir. Q When you got out there, what happened? A The first night I went -- I got into Vegas, our destination was to meet at the University of Nevada of Las Vegas, and I got there first. He was driving the big truck. I got in ther e at 8:30. Security became suspicious -- Q Did you get arrested? A Yes. Q What date were you arrested? A I believe that would have been the 12th. 14. D O 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q On August 12 when you arrived? A Correct. Q What happened to the children at that point? A The children were placed into Child Haven. Q By the authorities? A Correct. The car was impounded. Q What happened, were the children sent back? A The children were sent back. That was a Tuesday. The children were sent back Friday. Q Did the father come out and get them? A I assume. I was in jail. I assume he's the one who came. Q So that was Monday, four days, up to the 13th. When did you get out of jail? A I believe it was September 15th. Q What were you charged with? A Three counts of kidnapping and interfering with a custody order. Q From Pennsylvania? A Correct. Q Did you make bail? What were the conditions? Did they bring you back? What happened? A Pennsylvania did not come and get me, so I was released after 35 days, and then I called -- we hired a criminal attorney and I -- 15 ~~ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q In other words, you were released? A I was released, correct. Q And then are those charges pending here in Dauphin County? A Yes, they are. Q Have you entered a plea yet? A No. That will take place November 25th. Q Have you seen the children since they were with you in Las Veg as? A Just from coming here and at my mom's funeral on Friday. Q Was that last week? A Friday of last week, correct. Q October 17th. At whose funeral? A My mother's. Q When was that? A That was Friday. Q The same day? A Correct. Q Did the father bring the children to the funeral? A Yes. Q Now, do you want to return to Vegas? A That is correct. Q With whom do you want to return to Vegas, with which children? 16 D A 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A I want to return to Vegas with Eric Amaker, Amanda Amaker, my two children, my biological children. Q Eric? A And Amanda Amaker. Q Yes. A Holly Signor. Q Hold on. You want to take his daughter? A Correct. Q Anybody else? A Tyler Signor. Q Your child together? A Our child together, correct. Q Now, at the moment do you know where these children are in school and what grades they are in? A They are in Steel High in Dauphin County. Q All of them? A Correct. Well, the three older ones. Tyler is in, I guess, first grade. Q All of them are in school? A In Dauphin County. Q What school district is that, do you know? A Not really. Q Out of Steelton where they are living with the I father? A Correct. 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 4 A tenth. Q A in first. Now, tell me what grades they are in. Holly and Eric are in, I believe, ninth grade or You don't know for sure? No. Amanda is in, I believe, eighth, and Tyler's Q Have any or all of these children ever -- have any or all of these children ever been under the care or supervision of a child welfare agency? A Yes. Q Are they currently? A Not that I'm aware of. Q When have they in the past? A There was an incident when my husband and I had a violent argument, fight, and both of us were arrested and charged wi th simple assault and they became involved. It was Cumberland County. Q Were you living with him at the time? A That is correct. Q Were the children removed from the household? A No. Q They were never removed? A No. Q Children and Youth was involved? A Correct. 18 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q That involvement has ended? A Correct. Q Why do you want to take these children to Las Vegas with you? A Okay. Before Officer Cantfield knew of my custody situation, he was more than willing to give me -- he confirmed everything that I had called him about the Friday night prior to my leaving. He introduced me to neighbors. I spoke at a lengthy -- Paul and I spoke a lengthy hour with a neighbor confirming he is on record at the Highspire Police Department, but they need proof. They just can't go barging into his house, and I just feel it's not a safe environment. Of course, I don't know what's going on in the house, but by looking at my husband, he does not look well and I just -- I just feel I'm a good mother, and I just feel that they need a female role model. And once -- she was going to come, the neighbor. Q The neighbor isn't here? A No. Q Well, you can't tell me what the neighbor is going to say then. Do you intend to go and live in Las Vegas whether you have the children or not depending on what this court order is, whether you have all or none of them or part of them? A Correct. Q You are going to go out there no matter what? 19 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Correct. We're part of a wonderful church. Q Do you intend to work in Las Vegas? A Absolutely. We have jobs waiting for us when we go back. Q What job do you have waiting? A Mine is going to be -- we got them through our pastor. He's going to have Paul in real estate and heating and air-conditioning, and I'm going to be in public relations at RMA. Q What' s RMA? A It's a revenue -- I don't have the card. It's a revenue company. Q What does a revenue company do? I don't know what that is. A Well, it's merchandising, dealing in finances, keeping track of -- it's, like, makeup. Q He's going to work in what field? A Real estate, heating and air-conditioning. They pay $22.00 an hour out there. Q Is he here today? A Yes, he is. Q How old is he? A Forty-two. Q From the time that you married the father until you moved to -- in 1996 until you moved to Lancaster in August 20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2000, were you always living with him and were the children always living in your family? A The children were always in my care, but they weren't always with Randy. Q Had you been separated more than once? A Correct. Q And the children were with you during those separations? A Correct. Q Do you have any idea what the dates of the separations were? A Okay. I had all three children from May 10th -- my three, Eric, Amanda, and Tyler. Tyler wasn't even born. I'm sorry. I had Eric and Amanda when I left him in 1996, and I had taken them to South Carolina. Q How long did you have them? A I had them with me until December of 1996. Q So you had separated in May 1996? I A Correct. Q To September '96? A To December. Q December '96? A Correct. Q And the two girls were with you in South Carolina? A Correct, until he realized I wasn't coming back, 21 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 and then he came and he snatched Holly out of school and brought her back to Pennsylvania, but Eric and Amanda remained with me. Q And then when -- you came back and reconciled in December '96? A That is correct. I was pregnant with Tyler. Q And then was there any other separations? A Yes. Q Until 2000? A Yes. Somehow when I was in South Carolina there was an order that came up in Dauphin County, and I was not present for. So this is how this infamous Dauphin County order came to be. I wasn't even in the State of Pennsylvania. I had left him then in '97 and had gone to my sister's in Baltimore. Q Who were you living with in South Carolina? A My ex-husband. Q Is that Amanda and Eric's father? A That is correct. Q Is he still down there? A No, sir. I don't know where he is. Q He's disappeared? A Correct. Q What is the family in Baltimore? A My sister. Q Does she still live down there? 22 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A That's correct. Q Now, there was another period of separation? A That's correct. In 1997, I was down with my sister for a few months and -- Q Where were the children? A Eric was with me and then Randy had -- Eric and Tyler and Amanda were with me, and then Randy had brought an order in 1997 taking Amanda and Tyler away from me. Q He got a Dauphin County order? A That is correct. Q Removing Amanda and Tyler? A Correct, and leaving Eric. Q And then did you reconcile? A Yes, we did. Q When was that? A That was in 1999. Q Was there any other separation involving you and he and the children until the final one? A Yes. I had gone into a rehabilitation center in Maryland and I had Tyler. Q When? A In 1998. Q This is before this incident? A Correct. Q Let's go forward for a moment. After the 1999 23 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 reconciliation, was there any further splitting up of these children or family until the final separation? A No. Q Now, back in 1998, you went into rehab for what? A I had a DUI. Q Alcohol? A Correct. Q Do you have any drug problem? A No. Q Never had any? A No. Yeah, in school and with my husband, not this husband, my first husband. Q This was in 1998, did you say, you went into rehab in Maryland? A Correct. Q How long? A Thirty days. Q The children stayed with him? A Tyler was with me, and the other three were with him. Q He was with you in the rehab? A Tyler, yes. Q And then did you reconcile? Did you go back home after the 30 days? A No. He walked out of a counseling session, took 24 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Tyler, came back to Pennsylvania. I went to my sister's in Baltimore. Q You went to your sister's alone in Baltimore? A Right. My son, Eric, was already there. Q And then when did you reconcile? Did you reconcile? A Oh, yeah. In 1999, I had -- Q How long -- in 1998, after your 30 days, how long did you sta y down in Baltimore before you got together again? A I came back in February. Q Of? A Of 1999. Q I understand. A Because due to that DUI I had Tyler -- Q And when did you go down to the rehab in 1998? A In 1998. Oh, I believe it was August or September. Q So you were separated from August of '98 until February of 1999? A Correct. There's another Dauphin County order. This is so confusing. There's another Dauphin County order. I was in reha b when that conference took place. Q Do you know when-the -- was that before or after that? MR. LAGUNA: I'm sorry, Your Honor? THE COURT: I'm asking her. 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. LAGUNA: I'm sorry. THE WITNESS: The parties separated and moved -- BY THE COURT: Q That's okay. Let that lag for awhile. Now, come up to current. Is there anything else you want to tell me as to why you feel you should be allowed to take these children -- get custody of all of these children and take them to Las Vegas? A I believe that they have been away from me entirely too long not by choice but by just down right ignoring something that we agreed upon, you know, and was signed, and, I mean, he's had them out of my life for so long. Our marriage is failed, but, you know, I suppose -- Q Is there a divorce pending or don't you know? A No, because they said to wait until I do the custody. Q There is no divorce pending? A No. I do have papers though since I am a resident of Nevada to file. THE COURT All right. Cross-examine. CROSS EXAMINATION BY MR. LAGUNA: Q Now, Ms. Signor, you've gone by several last names throughout the last several years, correct? A Well, my maiden name, my married name, and this 26 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 married name. Q Which is what, Louise Signor? A Signor. Q Amaker and Fleming? A When I sign my name, I sign Louise Signor. Q So have you ever used Amaker or Fleming otherwise? A Yes. Q Okay. Over the last several years? A I know when you brought me the divorce papers I signed Louise Fleming. Q Okay. THE COURT: So there is a divorce pending here? THE WITNESS: Until he cancelled it. THE COURT: Okay. Go ahead. BY MR. LACUNA: Q You, in fact, accepted certified mail and a divorce .from our office? A Yes, you delivered it to me. Q All right. But you told the Judge there was none pending. A Well, to my knowledge that was dropped. We didn't get divorced. We reconciled. Q You reconciled. Okay. But you're aware that Mr. Signor filed a divorce, he wanted to divorce you? A At that time. 27 ~~ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Okay. Now, you indicated -- you told the Judge that there was this one DUI in, I guess, Maryland, or where was that? A One was in Maryland. One was in Pennsylvania. Q Well, actually there were three o r four, correct? A There was three, one in 1999 and two in 1998. Q But you told the Judge about one. A Well, because that's what he was asking me at that time. Q Well, you explained that that's what got you into counseling, the one? A The benefits of being institutionalized, I believe that was your words, institutionalized and incarcerated is because, yes, I had a bounty of counselors at my disposal. Q A bounty? A A bounty. Q You have been in counseling at many different institutions on many different occasions, fair? A I think three would be fair. Q And -- A Incarcerated and -- three. Q What three institutions? A Are you calling a rehab an institution? Q Well, anywhere where they put you in and you don't walk out the doors because the Court has ordered it. 28 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A I believe it was three institutions and my incarcerations, and at one point I was not allowed to return to Randy because they knew that our marriage was too volatile. THE COURT: Wait, ma'am. He just asked you how many times you have been in counseling. Go ahead. Next question. BY MR. LACUNA: Q And when you say institutions, which institutions are you referring to? A Does it matter? An institution's an institution. THE COURT: Tell me where you got your counseling. It doesn't matter whether -- THE WITNESS: Mountain Manor, Marworth, Pennsylvania, or up in Scranton. I believe that's where it was. THE COURT: What is the third one? THE WITNESS: Actually, I can't remember a third one. I know it was incarceration and the two rehabs. BY MR. LACUNA: Q Deer Run? A Do I what? Q Does Deer Run sound familiar? A White Deer Run. We're not up to there yet. That takes us up to when I left him again in 2000. Q Okay. So that was much later in 2000. Now, you 29 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 said incarcerated. Are we talking about Dauphin County Prison? A That is correct. Q How many times? A Oh, let's see, two parole violations. Well, actually, it was three parole violations because every time they came to the house there was either alcohol in the house or it was something that Randy -- it was because of our marriage, because of the violence in our marriage. THE COURT: Ma'am, he did not ask you that. He asked you how many times have you been in prison, separate times. BY MR. LAGUNA: Q Now, Dauphin County -- THE COURT: I am asking it. Besides sentencing and going to prison and parole violations, how many times have you separately been sent to prison? That is the question. THE WITNESS: I believe safely to say three times. BY MR. LAGUNA: Q Now, that's in Pennsylvania? A Corre ct. THE C OURT: Total. BY MR. LAG UNA: Q What about Baltimore? A I've spent overnight for the DUI. Q Wasn' t ther e a DUI where you hit an ambulance or 30 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 something? A That was the DUI in Maryland. Q Did you have children in the car? A No. Q Okay. The one in Pennsylvania, you had the child? A I had Tyler in the car with me, that is correct, and I have to live with that for the rest of my life. Q You were drunk, you had an accident, a serious accident, and you had -- at that point he was just an infant? A He was two. Q He was two. And he was in the car as well? A Correct. Q Okay. Now, in 1998, on April 24th of '98, you were charged with simple assault and harassment, correct? A That is correct, and you were my lawyer. Q On April 7th, you were charged with public drunkenness, correct? A I'm sure. Q You're sure? A I know a lot happened in this marriage. Q That was his fault? A I believe we both played a part. It takes two. It's not just one. Q Well, let's talk about that. In fact, this Friday you told the Judge that you went to a funeral, your mother's 31 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 funeral? A Correct. Q Now, you have somebody new, not him, not Mr. Signor, correct? A Do you mean as far as a partner in my life? Q Yes. A Yes. Q And this last Friday, even after we were here in court, you appeared at the funeral staggering drunk? A Oh, that is not true. That is not true at all. That is not true at all. Q Were you drunk? A Absolutely not. It was my mother's funeral. Q So if we have two or three witnesses come in here and say you were visibly drunk, they would be lying? A I believe that they would, yes, because Paul was right there. Paul knows I wasn't drinking. Q Sure. Now, on June 5th, 1997, you were charged with disorderly conduct or engaging in fighting and you pled guilty, correct? A Yes. Q And you were also charged with public drunkenness and you were remanded to the -- you were remanded to prison because also there was a capias already on you for a parole violation, a detainer was issued because you had violated 32 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 parole? A Each time that I was removed from the house it was due to Randy and I fighting. Q I understand that. A And then that would turn into -- you represented me on the simple assault. THE COURT: He is only asking you did you wind up in jail? THE WITNESS: Yes. THE COURT: Next question. BY MR. LACUNA: Q On March 24th, 1997, you were arrested for simple assault in that you attempted to cause bodily injury with a deadly weapon, a knife, correct? A That's a lie. Q Were you charged with that? j A It was brought down to harassment. Both of us were fighting. Q Are you sure? A Not one hundred percent. There's a lot that happened in the marriage. Q Well, let me -- A I can't remember each detail. I did a lot of jail time and a lot of institutionalize when I was with him. Q Do you remember chasing Holly Signor and Randy 33 ~, ..~: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 around with a knife on -- A That is Randy's version. Q Let me finish the question. On March 24th, 1997, do you remember chasing Randy and Holly around with a knife while you were drunk? Just yes or no. A No. Q Do you remember the New Cumberland Police coming in and pointing a gun at you, two of them -- A Yes. Q -- and telling you to drop the knife? A I had no knife and they saw that. Q Did they point their gun at you? A I was sitting at the top of the stairs. They came around the corner. Q Did they point -- A I was upstairs when Randy -- THE COURT: Ma'am, it is such a simple question. Did they point a gun at you? THE WITNESS: No, it wasn't pointed. BY MR. LAGUNA: Q Was it out? Were they holding it? A Yes, I could see it but it was not pointed. Q In fact, they displayed it for you to see? A Yes, he had it down. Q You were also charged with aggravated assault 34 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 during that incident, correct? A I believe I was charged with aggravated assault on Randy, but that was brought down. Q Okay. And, in fact, Randy sustained a cut, and he went to the hospital for the cut, correct? A I had my teeth knocked out, and Randy had a cut. Q So the answer is? A Both of us were injured. Q And you were also charged with harassment for physically striking and kicking Holly? A I have never touched any of my children in that way. That's his word against mine. And at that point and time in Holly's life Randy put a wedge in between Holly and I. THE COURT: Hold on. You are beyond the scope. He is just threshing out criminal stuff. Next question. BY MR. LAGUNA: Q On April 12th, 1996, you were charged with aggravated assault when you injured two police officers, correct? A No. Only one police officer was injured, and that's because I was dead weight because I was drunk. They were putting me in the car, and my head fell back on her nose. Q And she had a fractured nose? A I'm not sure what she had, but I know the testimony was given that she knew that it was not intentional. That was 35 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 the bottom line in that case. Q Testimony was given about that? A That she knew it was not intentional. THE COURT: What, if anything, were you convicted of or pled to, do you remember? THE WITNESS: I really, to be honest with you, don't know. There was so much. THE COURT: Were you convicted of some offense? THE WITNESS: I was convicted of some offense, yes. THE COURT: Next question. BY MR. LAGUNA: Q You were also charged with resisting arrest, disorderly conduct and -- THE COURT: The charges aren't what is important to me. Convictions are what are important. MR. LAGUNA: Well, she was convicted of all of them. THE COURT: Well, you are not asking her that. If you want to ask her whether she was convicted of something, ask her that. BY MR. LAGUNA: Q You were convicted of all of those charges, correct? THE COURT: What charges? 36 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. LAGUNA: Q Of the aggravated assault, the assault? A Which incident? Q In fact -- THE COURT: Which incident? MR. LAGUNA: I'm sorry, Your Honor. BY MR. LAGUNA: Q You were convicted of aggravated assault because you broke the nose of a police officer who was arresting you, correct? A No, that is not correct. Q Okay. You were convicted of resisting arrest for the same incident, correct? A That could be correct. Q Disorderly conduct, correct? A That would be correct. Q Public drunkenness, correct? A That would be correct. Q You were about seven, eight months pregnant when this happened? A No, no, no. Q When you appeared for sentencing -- A Seven months pregnant? Q When you appeared for sentencing, you were ,,pregnant, very pregnant? 37 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A With Tyler. Q With Tyler? A Right. Well, that incident didn't happen when I was pregnant with Tyler. Q Okay. A I didn't even find out I was pregnant with Tyler until July. Randy didn't even know until July. Q On November 2nd, 1995, you were convicted for disorderly conduct and public drunkenness, correct? A I believe you're reading the same charges over and over and over. Q Well, I'm talking about a different date, November 2nd. That's why I'm using the date, Miss Signor. On November 2nd, 1995, you were convicted of a misdemeanor disorderly conduct and public drunkenness? Just yes or no. A I believe that there was four incidents that I was convicted, yes, only four incidents. And since being on probation, that is what kept me going back and forth, in and i out of jail. Q And as a result of the DUI .and the accident in Baltimore, you were on probation or parole there for sometime, correct? A I was on probation -- it was all one probation. Q Well, I'm talking about Baltimore. A No, I wasn't on probation -- oh, yes, I was. Yes, 38 a. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I was, but I didn't have to, like, go down there or anything, and then I was released off probation. The two went hand in hand. Q Now, on a couple of these occasions with the public drunkenness, an ambulance had to be called to your home to take you to the hospital, correct? A Because I was passed out. Q In fact, your children came home from school on two occasions, they saw you passed out once in the yard and once on the back porch and they called 911? A I believe that is correct. Q And you were hospitalized? A I don't deny that. I admit being a drunk in that marriage. I admit that. You have a copy of that. I do not deny that at all. Q You were also arrested in Florida? A For a speeding ticket? Q Excuse me. A For the speeding ticket? Q No, ma'am. On March 31st, 1986, under the name Louise Fleming for obtaining substance by fraud? A That was trying to obtain a prescription, and that was dropped because that was not my prescription and there was no -- I didn't even have a child then. Q And that was before you were married to Mr. Signor? 39 D 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A I was married to my first husband. The first child didn't come along until 1988. Q Was that arrest your husband's fault, your prior husband's fault? A My actions I am totally responsible for. ` THE COURT: That is not a proper question. Next question. MR. LAGUNA: Sorry. THE WITNESS: But I had custody -- THE COURT: Ma'am, stop, stop. Next question. Let me ask you a question. Do you still drink alcohol? THE WITNESS: Not to the point of intoxication. THE COURT: So the answer is you still drink alcohol? THE WITNESS: Yes, I do. BY MR. LAGUNA: Q And, in fact, during the short period that you had Eric Amaker in Lancaster, you became intoxicated to the point where police had to be called there as well? A I recall the incident. The police were called but only due to Randy, and they spoke to Eric and they realized -- they knew that I was not intoxicated. Q And as a result of what happened in Lancaster, Eric came and he lived with Randy, correct? A Randy took Eric from the designated vacation place 40 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that I dropped Eric off. Why Randy -- what Randy's intentions were or why he did what he did, I have no clue. I know that he stopped bringing my kids to me on the weekends, and I know that he took Eric and did not bring Eric back to me. Q Did you file anything with your attorneys to correct that situation? A We didn't know where he was, and I was working two jobs at the time. I don't have that kind of money. He's taking $121.00 a week out of my paycheck. THE COURT: The answer is you did not, right? You did not file with attorneys? THE WITNESS: No. I had no money. THE COURT: Listen to the question. BY MR. LAGUNA: Q Did you have Mr. Abraham, who was your attorney at that point, did you have him telephone me or write a letter or say anything? A He wanted $250.00 that I did not have. THE COURT: The answer is no,, right? THE WITNESS: The answer is no. THE COURT: She has answered that. BY MR. LAGUNA: Q And then as a result once Eric Amaker went with Randy from Lancaster -- A From Baltimore. 41 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Excuse me? A Randy took him from Baltimore, not Lancaster. Q I thought Lancaster was after Baltimore. A No. Q Okay. A Randy took Eric 2001, December. Eric was down at my sister's in Baltimore on Christmas vacation. Randy took it upon himself to pick my son up with the rest of his children and not bring my son back. Q And since that time Eric has lived with Randy? A He had no choice. I didn't know where he was. Q You didn't know where he was? A No, I did not know where he was. And there is a woman standing right out there that can tell you I called her. She said they were living somewhere in Highspire. Q Did you pick up the phone book by chance and call? A Yes, as a matter of fact I did. And then a lawyer got in contact with him, and he disconnected the phone number. He said to call you, which then a Paula Kunzman (phonetic) -- I was going through legal aide -- called you. Q So you picked up a phone book and you found out where he was? He was in the phone book? A And then he disconnected his phone number. No, his phone number was unlisted. Q It was unlisted. You knew where he worked for 42 ~~ _ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 about, what, 15 years, 11 years? A And when I would call there, Linda would say he was either out on the road or she does not want to get involved. People were sick of our relationship. Q So when you tell the Judge that you had no idea ~, where he was and that's why you didn't take action, that's not really accurate or fair, is it? A I believe it is accurate and fair. Q You knew he was in Highspire, you knew his phone number, you knew his attorney? A He changed his phone number. Q You knew his attorney? A I even took my cell phone to my daughter which was taken from her. That's when Paul gave me the money to hire another lawyer. Q Exactly. You took -- A And we got back in front of Melissa. Q You took a cell phone to your daughter during the period where you say you don't know where he lived? You took the cell phone -- A Well, then I found out where he lived. Q So my point is it's not really fair to tell the Judge that Randy somehow disappeared? A Randy disappeared with the children. When you leave out of the home that we resided in for how many years and 43 a 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 then you change your phone number and you move out of the county, he's hiding my kids. Q He's hiding them. In fact, he purchased a home for the kids in Highspire, correct? THE COURT: If you know. THE WITNESS: Not that I'm aware of. THE COURT: Next question. BY MR. LAGUNA: Q Now, you said they do not live in a safe environment, is that correct? A That's what I am told. Q Do you have any personal knowledge that the environment in Highspire on Market Street is not a safe environment? A From the police reports and from my ,daughter, yes, I believe that it's an unsafe environment because this is a life that my husband of today has never lived, and when I heard about it, I was shocked. Yes, it's not a good environment. Q Do you have any personal knowledge -- THE COURT: She answered your question as she understood it. I understand what she is saying. BY MR. LAGUNA: Q Now, you say your husband didn't look well. A No, he looks -- look at him. He looks, what, 120 ~ pounds. 44 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Okay. He works full-time and a part-time job? THE COURT: Well, he can tell me whether he is well or not. I am looking at him. Go ahead. Let's proceed. BY MR. LAGUNA: Q Now, you say they need -- one of the reasons -- the prime reason, I think, that you told Judge Bayley that you want to take these kids with you to Las Vegas, Nevada, is because they need a female role model. Is that fair? A My children have always been with me until I met this man. My children were safe. I am their mother. I love them. Q Okay. And I wrote down you said -- A A11 these -- Q Ma'am, I wrote down that you said they need a role model, a female role model. ~I A That's one of the things I said, yes. They need many things . That's one of many things that they need. Q You agree that the role model should be a positive role model? A I think both their parents should have a positive role model in their life, absolutely. Q Do you believe that you are a positive role model for these c hildren? A Yes, I believe I am. My life has changed. My life is not the way that it was when I was married to Randy. It was 45 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 a bad marriage, and whatever he's doing with his life he's moving on. I want to move on. I want to share our children. Q You want to move on to Las Vegas because you think that's going to provide some new opportunity for you, correct? A That's where we chose to live. There's many parents who are living apart from their children, and you work it out, three months -- my first custody order with my first husband worked out well. THE COURT: Hold on. You have chosen to live in Las Vegas for a new opportunity for the two of you. Is that a fair statement? THE WITNESS: That's a fair statement. BY MR. LAGUNA: Q Now, you cannot afford to hire a lawyer to represent you today, correct? A That is correct. Q You cannot afford to pay support in a timely manner, correct? A That is correct. Look at everything that's happened. Q How do you propose to transfer children back and forth if you guys work it out? A Through Paul Rompalo. Q Excuse me? A Through Paul Rompalo. Paul Rompalo is paying for 46 D 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 all of this. Q Paul Rompalo. How long have you known Paul? Let me ask you-this. How long have you been dating with Paul? A About a year and a half. Q Okay. And after a year and a half, Paul Rompalo is prepared to finance all of this, and you're prepared to base your decision on that? A Well, so far the man has lost a car. We've had to fly twice. He had to hire the criminal attorney for me. Thirty days while I was in jail he was there for me. He had to rent a car. We had to rent a van. Now we're living in a hotel room. We had to.stay an extra week. Yes, I trust anything that Paul is doing, any decision. Paul is a wonderful person. God put him in my life, and we belong to a nice church. Q You've had many other men in your life since Mr. Signor, correct? A That is not correct. I had two. Q And that didn't work out? A No. Q What if this doesn't work out with Paul? THE COURT: Well, that is the future. I have got to deal with the present. She is telling me what her current plans are. BY MR. LAGUNA: Q So Paul doesn't have a job, you don't have a job, 47 _. ~,r, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I but -- A Q there? A Well, sure. Paul and I had jobs before we left for Nevada, and we plan to have jobs when we go there. Q I understand. You worked for a temp service is what you told support at the last support conference? A I told them I was working for three temps. THE COURT: Well, you tell me. Before you left for Nevada -- when did you go to Nevada again? THE WITNESS: August 9th of 2003. THE COURT: Where were you working? THE WITNESS: Dart Container and Turkey Hill. THE COURT: Where was he working? THE WITNESS: Paul? for over ten years. THE COURT: Okay. Go ahead. BY MR. LAGUNA: Q Were you placed at these locations through a temp service? A In the beginning, yes. Q Now, you were on pretrial release through Dauphin Not until we get back there. Somebody is going to hook you up when you get back THE COURT: Yes. THE WITNESS: He was a supervisor at Dart Container 48 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 County, correct? A When? Q Because of these kidnapping charges. A Correct. Q Now? A Correct. Q You have bail conditions? A Correct. Q And you have pretrial release supervision? A I call in once a week, and I'm allowed to go to Vegas. They don't have a problem with that. I brought myself back to Pennsylvania to face the charges. THE COURT: Hold on. You answer his questions. He is threshing out what I need to know. BY MR. LACUNA: Q Now, let me ask you this. We have been to several, I think four or five, conciliation conferences, true? A That is correct, something like that. Q Many agreements have been reached, correct? A Yes, we've been through quite a bit. Q It was not until after you were charged with kidnapping that you told your attorney to pursue this hearing here today, and that was Jeanne Costopoulos? A That is not true. Q Is it true that at the most recent conciliation 49 :.~ _.~ _ C~ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 conference with Melissa Greevy there was an agreement that Mr. Signor would maintain primary physical custody and you would visit the, children at the park on Saturdays? A That's what we had agreed upon, but nothing was signed. Q That's what you agreed to? A Well, obviously he-had to agree to it as well. Q I understand he did. A And so did I. Q You say nothing was signed? A I didn't sign anything. Q But you agreed to it? A I agreed to meet the children on Saturdays. Everybody was working. The kids are in school. Q And an order, in fact, was signed by this Court which said you meet them on Saturdays in the park, correct? A I did not receive that. We left on the 9th. This agreement, August 12th of 2003, I wasn't even here for that one. That says, And on this day, August 12th, 2003. August 9th I was gone. August 9th we weren't even in Pennsylvania. Q Okay. But your attorney was, and she appeared at the conference on your behalf, correct? A She sent me an e-mail on the 20th stating that I was to be in front of Melissa Greevy on the 23rd of September. That e-mail was not even opened -- and I have it right here. 50 ~. D 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 That e-mail was not even opened until the 25th, and she took it upon herself to go to the conciliator hearing. Q Okay. A And she said -- and I had written -- THE COURT: Hold on. You answered the question. Next question. BY MR. LACUNA: Q Miss Signor, at some point in front of Melissa Greevy you said that you would meet with the children in the park in Highspire, correct? A Yes. Q And you were there? A Yes. Q And, in fact, you followed through with that and you did meet with them in Highspire? A Correct. Q And that was on Saturday? A Correct. Q And you were with an attorney? Yes or no. A I agreed to meet with the children on Saturdays. THE COURT: The question is, when you met with them, did you have an attorney along? THE WITNESS: When I met with the kids? THE COURT: At the park. I thought that's what the question was. Next question. Maybe I misunderstood it. 51 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. LAGUNA: Q There was a conciliation conference -- THE COURT: Wait a minute. You followed through from the conciliation conference and met these children at the park how many times? THE WITNESS: Four times. THE COURT: Next question. BY MR. LAGUNA: Q So you understood there was a custody agreement that required the children to stay with Randy and you to meet them in the park? Yes or no. A No, no. I will not agree to that. I agreed that we agreed to meet with the kids on Saturdays and then we were going to reach another -- we were going to reconvene in September. We were all going to reconvene in September. Q But that didn't happen, did it? A I wasn't in the State of Pennsylvania. I was in Nevada because I took it upon myself to take my children. Q You were in jail in Nevada? A I got arrested for taking my children. I took it upon myself to take my children, and I will have to deal with that. Q And, in fact, you wrote a letter to Melissa Greevy from Nevada saying, I know I was wrong; T will deal with the consequences; I knew I shouldn't have taken them? 52 _ ~~. ~~~ D !~ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A No. Q Et cetera. A No, no, no. I wrote Melissa Greevy a letter but I did not -- I apologized for my actions, and I stated why I did it, who I called, Dauphin County Children and Youth, the Highspire Police Department, and I had told her that the children were most anxious to talk to a judge or talk to her. Q Did you say in that letter, I don't regret what I have done; I don't feel shame in what I have done; I knew the risks involved; and I knew there could be consequences; I would do it all again? A If I had to I would do it again. Q Did you say all of what I just said? A If that's my letter, that's what I said. Q Did you say that you had been deprived of your children for at least the last year and a half? A Something to that effect. I don't have the letter in front of me. If you have it in front of you, then that's what I wrote. Q Well, I'm asking you if you remember writing that. A I wrote various letters. I don't remember every word. Q Did you write I was just a horrible wife? A If that' s what it says, that's what I wrote. Q But you don't recall that? 53 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A I recall stating it was a horrible marriage. Q Do you recall telling her that Eric and Amanda -- A Can I read the letter? THE COURT: Wait a minute. He is asking you something. If you do not recall, then say you do not recall. If you do recall, then, fine. Question. BY MR. LAGUNA: Q Do you recall telling Melissa Greevy that Eric and Amanda do not want to live with Randy; Eric and Amanda want to move out here to Nevada with me? A After the four day drive with Eric and Amanda, that is what they told me. Now, what kind of hold he has over Eric right now, I don't know, but I know Amanda wants to go with me and his daughter-wants to go with me. Q Okay. So you remember writing that? Was that a yes? A Probably. Q And you say that Eric and Amanda want to be heard? A Yes, that's what I wrote. Q So you want Judge Bayley to hear what Eric and Amanda have to say? THE COURT: I am going to hear what they have to ~ say. THE WITNESS: I wanted them to tell the Judge what ~ they told me. 54 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: Next question. BY MR. LAGUNA: Q You stated in the letter that you had to pull the convoy over, and that Tyler essentially was having a fit that he wanted to go back home, and that you were going to arrange that? A I think I had a little bit more sympathy than that. No, that's not what I wrote. I didn't write he had a fit, and, yes, I wanted to ret urn him to his father. Q Why? A Because he hadn't seen me in so long. Q And -- A And my - - it was tearing my hear t apart. Q He was a toddler. He hadn't see n you in two years -- A I have feelings. Q -- until you kidnapped him? He hasn't seen you in two years, and you yank him and put him in a car and take him to Las Vegas? A That was very selfish. Q Yeah. So he's having a fit so you say you have to return him? A I wanted to return him, that is correct. Q And you say you tried to hook up the computer to send an e-mail that you were going to return him but you 55 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 T8 19 20 21 22 23 24 25 couldn't do it? A The hotel we were at my son couldn't figure it out. I couldn't figure it out. We could not get the computer hooked up. Q Could you figure out how to pick up the phone or maybe call collect or call the police? A Well, the kids didn't know the number, and I don't know his number. They felt he was using our cell phone. Q Did you know my number? A No. Q You have called me many times over the years. A I don't know your phone number off the top of my head. THE COURT: She says she doesn't know. Next question. BY MR. LACUNA: Q Did you write in the letter to Melissa Greevy, I know I should not have taken Tyler, but how could I leave him; he is a baby, my baby, and I missed him? A That sounds fair, yes. Q So you missed him so you took him? A Now, that sounds a little selfish there. No, it was not because -- well, it was part of the reason. But I took him because I believe the children were not in a safe environment. That is the majority of the reason why I took the 56 D c~ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 kids because I sincerely felt with everything my children have told me that it was not a safe environment. Q Okay. And you stated you have no personal knowledge to back up the statement? THE COURT: That is what she stated. Don't go over what she already stated. MR. LAGUNA: All right. BY MR. LAGUNA: Q Now, you told Judge Bayley that you have never had a problem with drugs, it's just alcohol? A No, I told him my first husband and I did drugs. Q Oh, okay, I missed that. Heroin? A It was heroin and cocaine. THE COURT: When did that divorce take place? THE WITNESS: 1995 when I met Randy. But I left him in '89 because of the fact he wouldn't stop doing drugs, and I had Eric and Amanda with me from 1989 by myself until '95. THE COURT: Ma'am, I understand. BY MR. LAGUNA: Q Do you recall filling out a, I guess, outline for Gaudenzia Common Ground? A It's already been -- no. It's already been established that I was a drunk. THE COURT: She said no. Next question. Ma'am, 57 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 you must answer the questions. One of the things pro se clients always do is they want to argue. Answer questions. BY MR. LAGUNA: Q Do you remember providing Randy with a list of 25 things which you felt was wrong with your marriage and you and him? A No. Q In an effort in an ongoing part of the -- A No. Q -- evaluation? A No. Q Now, I guess you say you hired a criminal attorney? A That is correct. Q And -- A I did not hire him. Paul hired him. Q You didn't have the finances to hire him yourself? A No, I did not. Paul hired him. Q Now, before this kidnapping charge, you had never requested a hearing in front of a judge, correct, over what are we talking close to ten years, four conciliation conferences? A I'm not sure. Q And isn't it true that the most recent request for a hearing is to obtain custody as a tactic to help avoid conviction for the kidnapping charge? A How could that possibly be when I took the children 58 a ~ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 before we met back in September -- on September 23rd that I was not present. How was I to know -- I knew that it could be a possibility that I could be arrested, but that happened before I was arrested. Q Well, I thought you said that you -- A I requested to come in front of a judge when I was in jail out in Nevada. THE COURT: Hold on. She savs it is not a tactic. Next question. BY MR. LAGUNA: Q You said when you took them you knew it was a possibility that you would be arrested. A Well, sure. When you get in your car -- Q Just say yes or no. THE COURT: Well, she said yes. THE WITNESS: Yes. BY MR. LAGUNA: Q But earlier you told the Judge that you thought there was no pending order and you were allowed to do that? A And that's what I sincerely believe. I was meeting with the children on Saturdays. Q And you thought if you met with them on Saturday you could take them to Las Vegas, Nevada, and now you're telling the Judge you knew then that you might get arrested? THE COURT: She already told me she knew she might 59 C 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 get arrested. I understand what her position is. Next question. I understand what-her position is and what she did. BY MR. LAGUNA: Q Your children have been going to the Steel High School District for how long? A I'm not sure. School just started back up. Q Years? A No. THE COURT: She is not sure. Next question. MR. LAGUNA: I have nothing further, Your Honor. THE COURT: You may step down, ma'am. I am going to take a break. Reconvene at quarter after. (Whereupon, a brief recess was taken.) THE COURT: You may take the stand. I want to hear from the father. Whereupon, RANDY EUGENE SIGNOR, SR., having been duly sworn, testified as follows: DIRECT EXAMINATION BY MR. LAGUNA: Q Randy, can you say your -- Mr. Signor, can you say your full name and spell your last name. A Randy Eugene Signor, Sr., S-i-g-n-o-r. Q Where do you live, Randy, Mr. Signor. I'm sorry. Mr. Signor, where do you live? 60 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Repeat that. Q Where do you live? I'm sorry. A Highspire. Q What's the exact address? A 233 Market Street. Q How long have you lived there? A About a year and a half. Q Can you hear me okay? I know you have some hearing -- A Yeah, I can hear you. Q You can hear me okay? A Yeah, I can hear you now. THE COURT: Speak up loud. BY MR. LAGUNA: Q Where did you live before Market Street? A It was New Cumberland. Q What was the address there? A 389 Market Street -- or Fourth Street. Q And how long did you live there? A It was about five years. Q Now, did you own -- did you own 389 Market Street? A Yes, I did. Q And do you own 233 Market Street in Highspire? A Yes, I do. Q Of course you have a mortgage on it but it's -- 61 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Right. Q Now, I want to talk -- MS. SIGNOR: Excuse me. Can I object to something? THE COURT: What are you objecting to? MS. SIGNOR: The house was -- THE COURT: That is not a proper objection. You may object, but you have got to make proper objections. Next question. You will have a chance to cross-examine. MS. SIGNOR: Okay. BY MR. LAGU NA: Q Now, where is 233 Market Street in relation to Harrisburg and Highspire? A It's Highspire. Q Is that a residential area? A Yes, it is. Q Suburbs? A It's a residential area. Q You live close to a park. The park that we' ve been hearing about where the visitation occurred, how far do you live from the park? A It's about two to three blocks away. Q Walking distance for the kids? A Yes, it is. Q Do they spend time there? A Yes, they do. 62 D 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: What kind of a home, how many bedrooms? THE WITNESS: I have a four bedroom home. THE COURT: How old are you? THE WITNESS: I'm 42. THE COURT: Go ahead. BY MR. LACUNA: Q Now, where do you work? A Eureka Lubricants. THE COURT: You have got to spell that one for me. THE WITNESS: It's E-u-r-e-k-a Lubricants. THE COURT: Eureka Lubricants? THE WITNESS: Yes. THE COURT: Go ahead. BY MR. LACUNA: Q What is that? What do you do there? A I'm a warehouse person, a truck driver and mixer of .products. Q Chemical products? A Chemicals. Q How long have you worked there? A About seven years. Q Full-time? A Full-time. Q Do you have health insurance? A Yes, I do. 63 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Does it cover the kids? A Yes, it does. Q Have you ever been laid off or unemployed during those seven years? A No. Q Now, the children -- when I say children, I mean all of them. They go to school where? A Steel High, and Tyler goes to Steelton Elementary. Q The kids going to Steel High, how are their grades? A Their grades are real good. Q Do they participate in any extracurricular activities? A Yes, they do. Q Like what? A Eric's involved in weight lifting. He's gone out for -- I think he's had basketball he wants to go for and football. Tyler's involved in student council, and Amanda's getting involved in several things. Q Now, do the kids go to church? A Eric and Amanda goes to church on a full basis, yes. Q With whom? A A lady named Barb Hawk. Q Okay. How often do they go to church? A Every Sunday. 64 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Isn't there some extra church activities? A There's always church activities. I know they had bells on Wednesdays. Q Hang on. Bells on Wednesdays. What's that mean? A They play bells for the choir. Q You mean musical instruments? A Yeah. Q And that's Eric and Amanda? A Yep. Q They do that every Wednesday? A Every Wednesday. Q And what else were you going to say? A Whatever the church -- they are involved in, you know, so much with the church. THE COURT: What grades are these kids in? THE WITNESS: Eric's in tenth grade. Amanda's in eighth, and Holly's in ninth. THE COURT: How about Tyler? THE WITNESS: He's first grade. THE COURT: First grade. Okay. BY MR. LAGUNA: Q Now, you said -- now, you receive -- well, let me back up. I'm sorry. All the kids have been living electively with you for how long about? A Five, six years. 65 - - ~n~ ~1~' 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Now, full-time, they sleep there? A Yes. Q And Christmas and holidays you all participate as one family? A Yes, we do. Q Do you spend time with relatives on any of these holidays, or how does that work out? A We do visit relatives on holidays. Q Now, what do they call you? Do these kids call you Randy, dad? What do they call you? A They call me Randy and dad. Q All of them? A All of them. Q Do you go to the school as part of -- well, do you have occasion to go to their school and meet with their teachers or do anything like that? A I go to the meetings. Q What meetings would they be? A Like the PTA, open house. Q About how often does that happen you go to their schools? A Three, four times a year, parent/teacher conference. Q And you say they are doing well in school? A Doing real well. 66 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q How do the kids interact with one another? I'm going to ask you to describe are they like brother and sister or are there two separate families or how do they -- A Oh, no, they are like brothers and sisters, you know. They protect each other. Q Do they make any distinction between whose side of the family they're on? A No. Q I want to talk about last Friday. There was a funeral? A That's correct. Q Did you go to that? A Yes, I did. Q Who went with you? A That was me and the children, Eric, Holly, and Amanda. Q Did you have another -- you have another son that is not involved in this, he is an adult, correct? A Yes, I do, Randy, Jr. Q Did Randy, Jr., go with you to the funeral? A No, he was working. Q He's on his own? He's got his own family? A Yes, he does. Q Is he in the area? A Yes, he is. 67 a; 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Do you guys spend time together with his family? A Yes, we do. Q Now, when you say you took the other kids, we're talking about everybody but Randy, Jr., went to the funeral? A Right, and Tyler, okay. He's not allowed out right now. Q Why not? A He had his tonsils and adenoids taken out, so he's at home. Q And you had that done, the tonsils and adenoids? A Yes, I did. Q Did your insurance cover that? A Yes, it did. Q At the funeral did you have the occasion to contact Louise Signor? A I seen her but I did not talk to her. Q How close did you get to her? A About as far as we are right now. I Q Did the kids have the occasion to get close to her? A Holly and Amanda did. Q Did you observe her demeanor to be unusual? A Yes. We wasn't even out of the vehicle, and she got out be fore we did, the vehicle, she was -- Q Well, what did you see? A She got out of the car, and she started stumbling 68 i 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 and almost fell, and the kids says we think mom's drunk. Q Did you have the opportunity to observe her during the funeral? A Yes, I did. Q Did she appear to be drunk? A Yes, she did. Q Now, do you plan on moving anytime soon? A No. Q You plan to have the kids finish eleventh and twelfth gr ade an d graduate he re if they remain with you? A Yes. Q Your job doesn't take you away or anything like that? A No, it don't. Q The kids have friends in this area? A Yes, they do. Q They play with those friends? A Yes. Q Visi t with them? A Yes. Q Now, I want to talk a bout -- MR. LACUNA: Well, I have nothing further. THE COURT: I've got a few questions. BY THE COURT: Q Do you live alone or do you live with a woman? 69 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Yes, I do. Q What, which one? A I live with the children. Q The children. You don't live with another woman? A There's a woman staying with me right now until she gets on her feet to get a place. Q How long has she been there? A Two weeks. Q Two weeks? A Uh-huh. Q But generally there is no woman living there? A No. Q Is she a friend of yours? A She is a friend, yes. THE COURT: Do you have any questions? MS. SIGNOR: Yes, I do. MR. LAGUNA: Your Honor, may I -- first, may I do a redirect? THE COURT: You can follow-up. BY MR. LAGUNA: Q Mr. Signor, you have two witnesses that you brought to court here today, two women as character witnesses. Who are they? A One's Evelyn Bupp. Q Who is that? 70 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Evelyn is -- I call her my nanny. She helps take care of the kids, if I need anything, you know. She's there for, you know, to do it for me. Q Daily, weekly, monthly? A Weekly, daily, I mean, whenever I call her. Q Who is the other person? A The other one is -- Q You have Miss Bupp who is the nanny. You have somebody else, not the church? A My mother-in-law to my first wife. Q And who is she? A Shirley Uhler (phonetic). Q Does she spend a lot -- well, how much time does she spend, if any, with the children? A Whenever she can she spends time with the children. She's working a lot right now. Q How often do you think she sees the kids? A Once, twice a week. MR. LACUNA: Nothing further. THE COURT: Do you have questions? MS. SIGNOR: Yes, T do. THE COURT: I alert you before you start, this is the time to question him, not make statements. Question, elicit questions. If you want to make a statement, I will let you do that at the end of the case. Proceed. 71 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. SIGNOR: For the record, it was Three 24th Street in New Cumberland. THE COURT: See, you are making a statement already. Ask him questions. CROSS EXAMINATION BY MS. SIGNOR: Q You said this Inga's only lived with you for two weeks. That's not the complete truth. THE COURT: You are making a statement. Ma'am, I will let you do this but only if you ask questions. Ask questions, statements later. Question. MS. SIGNOR: Am I allowed to say -- THE COURT: You are allowed to ask questions. You know what a question is. Go ahead. MS. SIGNOR: Okay. BY MS. SIGNOR: Q When is the last time that you had them to see their southern family? A About a month ago. Q And who was that? A Nicki Fleming. Q No, no, no, I mean their southern family, Eric and Amanda's. MR. LACUNA: Your Honor, I would ask for a foundation. I'm not sure what southern family -- 72 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: Name the people. Who are you talking about? MS. SIGNOR: Ann and Dred Kaminskas, Uncle Kam in Florida. The kids have family -- THE COURT: When is the last time you have taken them down there? THE WITNESS: Probably the last time they seen them was when they were in South Carolina with her. BY MS. SIGNOR: Q And I was in South Carolina with all three of the children, correct, Holly, Amanda, and Eric? A You was in South Carolina with Eric and Amanda. I left Holly come down and visit you, yes. Q And Holly was enrolled in school, correct? A She was enrolled in school for, what, a month or less. Q No, it was two. When is the last time you had Eric to a doctor? A His last physical. Q A couple weeks ago? A Yeah, a couple weeks, not even a month ago. Q But you didn't take him to a doctor the whole time that he was away from me, correct, until a couple weeks ago? A That's correct. Q And the same with Amanda? 73 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Correct. They weren't sick. Q Are you using drugs in your house? A No. Q You're under oath. THE COURT: He said no. BY MS. SIGNOR: Q You agree that we had a bad marriage? A Yes, we did. Q Were you arrested in York County for -- MR. LAGUNA: Your Honor, it's beyond the scope of direct. THE COURT: No. I will allow it. BY MS. SIGNOR: Q Were you arrested in York County for -- what was your charges? He was your lawyer. THE COURT: Let's put it this way. Were you convicted of any offenses in York County, and if so, what and when? THE WITNESS: It was York County. I was convicted ~ of theft. THE COURT: How long ago? THE WITNESS: Three years ago. Let me think. MR. LAGUNA: Your Honor, it was not a conviction. THE COURT: Wait. You are making a statement now. He is telling me what his perception of it is. I asked a 74 ~..~. _. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 question. He answered. MR. LACUNA: I'm sorry, I just wanted -- THE COURT: You can redirect if you want. MR. LACUNA: Okay. BY MS. SIGN OR: Q You've often made statements that T'm a darn good mother. Do you deny that? A I did not make the statements. You made the statements of that. Q We've been together since 1995, correct? A That's correct. Q You've not -- I understand you've not ever heard me make that - - that you've never made that statement? A What was the statement? Q That she's a darn good mother. A I might have made that statement a few times. Q But when I was intoxicated I was not a good mother, and I shoul d not have been around the children, correct? A That's correct. Q And the majority of our marriage I was intoxicated, correct? A Correct. Q I left safely -- it's true that I left you at least five or six times? A It might have been more. 75 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q And I took the children with me, is that correct? A That's not correct. Q Are you denying the fact that when I met you in 1995 Amanda and I left and went back down to South Carolina? A In 1995, you and Amanda left and went to Baltimore. Q That was another time. I'm getting there. In 1995, then Amanda and I returned to you, correct? A That's correct. Q Okay. In 1995, Amanda and I went down to Baltimore, correct? A Correct. Q Also in 1995 I left you -- I'm sorry. And at that point I had Eric and Amanda with me in South Carolina, correct? A That's correct. Q Okay. In 1996, we married in March, correct? A Correct, March the 25th. Q And I left you two months later, correct, it was May 10th? A Somewhere around there. Q Amanda and I got on a bus and went back down to South Carolina, correct? A That's correct, I think. Q So at this point do you agree that I had Eric, Amanda, and Holly in South; Carolina? 76 .. . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A I left Holly come down and visit you. Q Do you think visiting would mean being enrolled in school? A You wanted to put her in school down there -- Q And she was? A -- for a little bit while she was down there, and I agreed on that. Q And is it not true that you were going to move down to South Carolina to buy a house? A That is true. Q We were looking for a house in South Carolina, is that true? A That's correct. Q And the marriage was not working, correct? A That is correct. Q And I would have stayed in South Carolina had I not found out I was pregnant with Tyler, correct? A I don't know that one. I don't know. Q You deny I came back because I was pregnant with Tyler, and we decided to work it out? Do you deny that? A You came back but I don't know -- Q I was pregnant with Tyler, correct? A You were pregnant with Tyler. Q And we bought the house in New Cumberland? A Correct. 77 :. -~:; 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 4 Because we had moved out of Dauphin County, correct? A Correct. 4 Okay. And the whole family at that point was living in the house on Three 24th Street, New Cumberland, correct? A Correct. Q Do you deny that you don't know anything about this York County custody order? A Which one was that? Q The York County custody order. THE COURT: Do you know anything about a York County custody order off the top of your head? THE WITNESS: Not off the top of my head, no. BY MS. SIGNOR: Q Do you deny paying for the divorce of my first husband and myself? THE COURT: That is not relevant. Next question. BY MS. SIGNOR: Q This was part of that. You do not remember you paid for the divorce? THE COURT: Wait, wait, wait. Hold on. To your knowledge, were you involved in a York County custody order? THE WITNESS: Cumberland County but not York ~ County. 78 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: Next question. BY MS. SIGNOR: Q Do you deny the fact that you picked Eric up in Baltimore in December of 2001? A It was January of 2003. Q This is 2003. A Well, yeah, yeah, 2001. Yeah, it was January. Your sister called me. Q But while we were in the courtroom here you made the statement that you picked Eric up after being left alone at my house for four days and Eric called you? A That's correct. 4 So now you're changing that story, and you're telling the Judge that now you did pick Eric up in Baltimore? A I did pick Eric up in Baltimore. Q You stated he called you from Lancaster. A He did call me from Lancaster. Q He was in Baltimore. How could he call you from Lancaster if he was in Baltimore? i A It was in November, early November when Eric was in Lancaster, Q Do you remember when I was in rehab up in Marworth? A Yes. Q Do you recall not being allowed to come back home to you? 79 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A I don't recall that. Q The probation officer, Julie Hall, stated to you I could not return to you? A I don't recall that because I picked you up from Marworth. Q You don't recall leaving the house? A I left the house several times. Q You were staying at your dad's, correct? A That's correct. Q So then you left the house, you knew that I was not allowed to come back to you, and you voluntarily left the house and left me with the three children? A That's correct. Q Okay. We did a lot -- when we weren't fighting, when I wasn't drinking, when you weren't cheating, we did a lot with the children, did we not? A Excuse me, I didn't understand that cheating part. THE COURT: Let's forget all that. During the course of your marriage, did the two of you do a lot with your children? THE WITNESS: I done a lot with the children. I can't say we done a lot with the children. THE COURT: Next question. BY MS. SIGNOR: Q Do you-deny the fact that you were to be going to 80 {;, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 counseling and you took Eric, Amanda, and Tyler and Holly to Evelyn Bupp's house when you were supposed to be going to counseling? Do you deny that? A I took -- Evelyn Bupp was watching the kids. They were not supposed to be going to counseling. Q Are you denying that that was the time for you to spend with the kids? A Yes, I am. Q Not to spend with Evelyn Bupp but to spend with you? A Evelyn Bupp didn't spend time with them. Q Do you deny cheating on me with Evelyn Bupp? THE COURT: That is not relevant. Next question. MS. SIGNOR: It's going to be relevant when she comes in to testify against me. THE COURT: It is not relevant. BY MS. SIGNOR: Q Do you deny the fact that you beat me? A I deny that as self-defense. Q According to you and your attorney. THE COURT: He told me what his position is. BY MS. SIGNOR: Q Do you deny smacking my head against the dashboard of the Jeep? A I deny. Not that I remember or recall. 81 ~., , ._ ~,., 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Do you deny emptying -- do you deny the fact that I was baby-sitting when we were living in Steelton? A Would you repeat that. Q Do you deny the fact that I had a baby-sitting job inside the home that we lived in in Steelton? A You watched a kid or two. Q Pardon? A You did watch a child or two. Q Do you deny the fact that I had them sitting waiting for their parents and you dumped empty beer cans in their little circle while they were waiting for their parents? A I picked the trash cans up to empty them. You were intoxicated. I didn't want the parents to see the cans laying around. Q Do you deny the fact that I then walked these seven children five blocks to the first parent because I did not feel that it was safe to be in t he house with you? A I don't recall that. Q Did any of the parents come to the house to pick the kids up? A I seen one or two. Q Do you deny the fact that you're lying to me right I now? THE COURT: Wait, wait. Next question. He is answering questions. He is under oath. 82 r; 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MS. SIGNOR: Q Do you deny the fact that when I was in rehab you refused to bring the children to see me? A Could you tell me what rehab that was? Q Do you deny calling me a drunk and a horrible person? A I have called you that. MR. LAGUNA: Your Honor, I object. Perhaps she could say when. MS. SIGNOR: Because he wants me -- THE COURT: Wait, wait, wait. He said he might have called her that. You say you might have called her that? THE WITNESS: Yes, I did. THE COURT: Next question. I will allow it. BY MS. SIGNOR: Q Do you feel then in a-rehab setting that that would be a safe setting to have children visit their mother or their father? A The rehab is the one that told me do not bring the children. MS. SIGNOR: I wish I could zap him for every time he lied. I have nothing further, Your Honor. THE COURT: Any further questions? MR. LAGUNA: Nothing, Your Honor. THE COURT: Sir, you may step down. I want to see 83 ~~~ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 some of these children. I want to see them all. Are they all here? MR. LAGUNA: Yes, Your Honor. THE COURT: I want to meet them all. I want to do it just with myself in chambers. MR. LAGUNA: That's fine. THE COURT: With my stenographer. In a few moments, I will send my secretary out. I want to see Eric first, Amanda second, Holly third, and then I will just say hello to Tyler. He is six, right? MR. SIGNOR: Tyler's not present, sir. THE COURT: Tyler is not here? MR. LAGUNA: He's home sick, Your Honor. THE COURT: He had his tonsils out. That's okay. He is only six, right? MR. LAGUNA: Yes, sir. THE COURT: Eric first. I will send my secretary out in a few moments. MR. LAGUNA: Would you like them in the courtroom to wait? THE COURT: No, no. I will send my secretary out. She can bring each one back individually. Five minutes. (Whereupon, a brief recess was taken.) (Whereupon, the following discussion was held with Eric Amaker in chambers.) 84 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY THE COURT: Q My notes say you are 15, right? A Yes. Q That sounds like a good age. Do you like being a teenager? A Yeah. Q What grade are you in? A I'm in tenth. Q At Steel High? A Yes. Q How do you like school? A It's good. I'm doing real good. Q What is your favorite subject? A Biology. Q Is it really? A Yeah. Q You like science stuff? A Yeah. Q What is your least favorite stuff? A English. Q English is a little hard? A Yeah. I don't mind reading, but we have to do book reports and everything and that just -- I don't know. I mean, I can do it, but it just doesn't interest me too much. Q Are you into sports at all? 85 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Yeah. I don't play on a team. I mean, I did back in my younger years, but then I was, like, moving back and forth. I've always missed sign-ups and everything. And then I did start to play again, like, in seventh and eighth grade and then I just -- and then I went to Steel High, and I didn't get a chance to. Q What do you like? What kind of sports do you like? A I play football, baseball, basketball. I played just about everything, tennis. I like tennis. Q Good. What kind of a sister is your sister Amanda? Is she a good sister? A Yeah, she's good. Q Is she going to tell me you are a good brother, or is she going to hedge on that? A I don't know. I hope she says I'm a good brother. Q Good for you. Let's see, Holly is living with you, right? A Yes. Q Do you get along with her? A Yeah, we get along. She's like my sister also. I get along with her. Q What type of a kid is this Tyler little guy? A He's my younger brother. He's my younger brother. I don't know. Q Is he trouble on occasions? 86 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A No, he's -- he looks up to me a lot because I play with him a lot. Q Good. How many years have you now been going over in the Steelton School District? A I started my first year in ninth grade. Q In ninth grade? A Last year. Q Before that you were in New Cumberland? A Yes. Q I understand. Now, how long, from your perspective memory wise, has it been since you have actually lived with your mother? Was that back in New Cumberland? A I haven't lived with my mother since Lancaster. Q Since Lancaster. You were in Lancaster for awhile with her? A Yes. Q Then there came a time when your stepdad came down and got you? A Well, actually I went to -- she let me go to my aunt's in Baltimore for Christmas. And after New Year's, Randy got me because mom had called and there was all this fuss -- there was this guy she was with, I forget his name, that said she had gotten really drunk and everything and had, like, (inaudible) all over his bike and everything, and she called him and was drunk. And I was fed up with it because when I 87 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 lived in Lancaster I dumped a lot of her beer out in the sink because she promised me she would quit and she wouldn't. Q She wouldn't at the time? A At the time, yes. Q She tells me she drinks now but doesn't get drunk anymore. I don't know whether that's true or not but let's hope it is. A And so Randy after -- when he picked Amanda up, I went with him, and mom didn't do anything about it. She didn't try to fight for me or anything, but she said she didn't give up on me or anything, but she was working everything out. And Randy got -- I believe Randy has custody of me now. He did get custody of me but not until -- it was awhile after that he got me from New Year's before he got custody of me; but I believe he does have custody of me now. Yeah, I'm pretty sure he does. Q How do you get along with him? Does he treat you good? A Yeah. He treats me just like I was his son. Q Does he. Good. Good. Now, I heard that apparently there was a period of time when you were meeting your mother in the Highspire Park for awhile? A Yes. Q That was the first time after a long time you had not seen her for awhile, had you? 88 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A No, I haven't seen her for a long time. I was actually kind of scared to go see her because, I mean, I had left from Lancaster, just left, and I didn't really know how she would feel about that. But the first couple times she was okay. I mean, she said, hi, I love you, and we ate at the park and played games at the park and everything, had fun. And so I guess maybe it was the second week she said that Paul was leaving for Las Vegas on a job. He was getting a new job there, and she is tagging along, and we need to make a decision if we want to go or not, it's up to us. And she is such a persuasive person, and she talks so much about how good it would be, and she was mostly pointing out towards it is Las Vegas. Q Yeah, it sounds good, doesn't it? A Yeah. And it kind of, like, just filled my head. I mean, I loved her and everything, and I was really happy to see her, but it was such a spur of the moment thing that I was just thinking without thinking. Q Okay. And you went? A And I went. Q It didn't last long because as soon as you got there I hear you got sent back? A Yeah. Q Did Randy come out and get you? A Yes, Randy flew out and brought us all back, flew 89 ~;~~. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 us back. Q And did you miss some school during this? A No, this was -- Q Was this during the summer? A Yeah, this was during the summer. It was before school, yes. Q So you came back. So you had, in effect, a one week jaunt out there. Did you drive out? A Yeah, we drove out. It took us four days. Q Well, you saw some of the country. A Yeah. Q You'll see a lot more in your time. What did you do this summer other than your little jaunt to Vegas? Did you have a job at all? Were you just playing around enjoying yourself? A Every weekend we go to Barb Hawk's. She's our youth advisor, and she's been a close friend of the family. Her son's my best friend, and her daughter is my sister's best friend. So we've known them for six years ever since we first moved to New Cumberland. So we got really involved with the church with them. Every weekend on Saturday we go over to their house and do stuff with them, and then we go to church on Sundays, and then we come home. Q Do the three of you, you and Amanda -- does Holly 90 ~.a~~ - __ ___ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 come along? A Holly used to come years ago. Like, maybe a year or two ago she used to come. But she doesn't -- she hasn't been going to church with us anymore but she goes -- like, we have camps in the summer. We go to camps every summer. She went to that one. She didn't go this year, but she usually goes to those. Q I got a pretty good feel where you are. Anything more you want to say to me while you have got me? A Do you need to know anything else? Q I don't want to put you on the spot. Your mother wants to take you out to Las Vegas, have you move out to Las Vegas. How do you feel about that? A I don't really want to move out there. I prefer to stay here. Q I understand that. Let's hope and assume your mother is improving her life and all. Would you be adverse to going out there to visit her? A Yes, I would really like -- I would like to visit her during vacations and stuff like that, but I don't want to live with her full-time. I would like to live with Randy and stay here. Q Okay. A And go to school here. THE COURT: It is nice meeting you. You are a 91 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 fine, young man. Would you send your sister back here. ERIC AMAKER: Yes. (Whereupon, the discussion with Eric Amaker was concluded.) (Whereupon, the following discussion was held with Amanda Amaker in chambers.) THE COURT: Come on back. Nice to meet you. I was just talking to your brother, and I was saying what a nice lad he is. Have a seat right over here in the corner, right here. BY THE COURT: Q I am Judge Bayley. You tell me what kind of a big brother is this? Is he a good guy? A Eric? Q Yeah. A Sure. Q Okay. What do you think he said about you, good sister? A Maybe. Q Maybe, okay. He said you are a pretty good sister. How about this little guy, Tyler? A Yeah, he's a good brother, kind of, but he gets annoying. Q I understand that. He is a little guy. Do you get along with Holly? A Um-hum, sometimes. 92 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Sometimes. Teenagers. What grade are you in? A Eighth. Q At Steel High? A Uh-huh. Q How do you like school? A Not that well. I don't like Steel High very well. Q Really. Now, let's see, you had been in New Cumberland. You were in, what, elementary in New Cumberland? A New Cumberland and I was in middle school. Q In middle school. Did you like the middle school? A Um-hum. Q You don't like Steel High that much? A Not really. Q What's your favorite subject? A Science. Q What's your least favorite subject? A Math. Q Do you play some sports? A No. I did play basketball in New Cumberland, but I don't play for Steel High. Q Any other activities you do that you like? A I like playing sports, but I don't really like playing at school sports. Q On teams, okay. You have been living with -- I guess you have been living with Randy now and not your mother 93 ~ m 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 for a few years, right? A Yeah, I think two, three, four. I don't know. Q You are not even sure. A long period of time that you did not see your mother? A Yeah. Q How does this family get along, Randy and you and the kids get along? A Well, sometimes it's really bad but -- Q Does he treat you well? A Um-hum. Q I understand that you and your brother and sometimes Holly go to a church, and you have a friend that takes you to church activities. Tell me about that. A Holly doesn't really go anymore because -- well, I work on Saturdays. So it's hard to go because they usually pick Eric up around Saturday, like, in the daytime, and I don't get off work until like 4:00 or 5:00. Q Where do you work? A Saturdays Plunkett. Q Just to get a few dollars in your pocket? A Yeah. Q I bet you like that? A Yeah. We go to church and, like, we go to camps and stuff over the summer, and then we do, like, lock-ins and stuff, and great escape we are doing in November. It's, like, 94 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I~ all these churches go to -- I don't remember what hotel it is. It is a hotel. I'm not sure where it's at though. We stay there for the weekend, and then, yeah, we do a lot of different stuff with camps and churches and stuff, and we do a lot of fund-raisers to raise the money to go. Q Good. When it came about -- I guess it was in the summer that you started seeing your mother on Saturdays at a park. Did you and your brother do that? A Um-hum. Q Were you happy to see her again? A Yeah. Q Tell me from your perspective how it came about that she took you out to Las Vegas and how you felt about that. A Well, she was leaving with Paul, and she wanted us to come with her. She just wanted to know if we wanted to come, and we both said, yeah, because I wanted to go live with her and Eric wanted to too. But I don't know why we left because now it seems kind of stupid that we just left instead of having permission and stuff, but I wanted to go live with her. I really didn't like Steel High, so I thought it would be a good chance to go, and so we both went with her. Q You got to drive across the country, but it didn't last long, did it? A Yeah. 95 ~; 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Would you like to visit her in Las Vegas? Would you like to see her? A Yeah, a lot. Q How do you feel about she wants you to move out there with her now at this point? How do you feel about that? A Well, if I did move out there, I don't want it to be now, like later on or something, maybe in the middle of the school year or something, like next year or something, but I don't want it to be right now. Q I understand. A But if I do move out there with her, I would like to come down here and visit over holidays and summers or something. Q Okay. But you would like to reestablish a relationship with her? A Um-hum. Q I can understand that. She wants that very bad. Hopefully she is doing better now than she did in the past. Do you remember much about the past and the difficulties she had and Randy had together when they lived together? A Well, it was fun some days, and then some days were really bad. I didn't want -- like, I wanted them to split up like once, but then they were fine together a lot of days and I was happy about that. But then some days they were, like, really bad and always getting in a fight, and I really wanted 96 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 them to split up or something. Q Anything else you want to tell me while I'm here trying to work this out? A Not really. THE COURT: It is nice to meet you. Do me a favor and send your big sister Holly in. Nice to meet you. AMANDA AMAKER: You too. (Whereupon, the discussion with Amanda Amaker was concluded.) (Whereupon, the following discussion was held with Holly Signor in chambers.) BY THE COURT: Q Another teenager. Are you 15? A Yeah. Q What grade? A Ninth. Q At Steel High or at middle school? A No, it's high school. Q A four year high school? A Yeah. Q Middle school last year? A No, there ain't no middle school. Q So right into high school this year? A Yeah. Q How do you like it? 97 ,~~ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A It's good. Q What is your favorite subject? A Math. Q What is your least favorite subject? A History. Q What's your favorite things when you are not studying or something, sports or activities, what do you like to do? A Go to football games and hang out with friends. Q Do they have a good team this year? A Yeah, we only lost once. Q That sounds pretty good. Is the big game at the end of the year with Harrisburg High? A Probably. Q I'm not a big football fan. A Camp Hill is in the lead, and we're in second lead, and we lost to Camp Hill our homecoming game. Q How do you get along with Eric and Amanda? A Good. Q And the little guy Tyler? A Yeah. He's everything to me. Q Is he? A Yeah. Q Do you like having a little brother? A Yeah. 98 ~, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Good. A He's spoiled though. Q Do you remember much about the days when you lived in New Cumberland with your dad and Louise? A Yeah. Q How do you get along -- well, there was a long period you didn't see Louise, am I right? III A Yeah. Q Generally, how did you get along with her? A When she was sober, we got along good, great and everything, but when she was drinking, like real drunk and everything, we fought. Q She tells me she is doing better now. We hope she is. A That's what I heard. I heard she changed from Amanda and Eric, well, mostly Amanda. Amanda really talks about her mom. But I heard she changed and everything. I don't know. I don't talk to her. Q Were you along -- did she take you out to Vegas? A No, I was not with them. Q Did you know it was going to happen? A No. It was all a shock. Q They were gone? A Yeah. Q You didn't know? 99 ._ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Amanda talked about going to Vegas but not until ' this coming summer. So I think it was a code for last summer. Q Okay. If at some point the kids go out and visit their mother in Vegas, would you want to go along and join that, or how do you feel about that right now? A I don't know. It depends because I want to see, like, how she changed and stuff. I mean, there was things in the past that made me lose trust for her. But, I mean, yeah, I mean, I would go if it was all right with my dad maybe. Q Do you get along good with your dad? A Yeah. Q You have a good relationship? A Yeah, that's my dad. I mean, I'm not going to leave my dad to go live with her. Q I understand. A I mean, that's my only father, real parent, that I got left. I mean, so -- I mean, if it comes down to visitation, I'm cool with that, but it's not like I don't know how to pick up a phone if something went down, and the same with one of them. Q Anything more you want to tell me while you have got me? A No, not really. THE COURT: I know what I need to know. I am happy to meet you. Good luck in school. I will root for Steel High 100 ~ ~ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 on your behalf. HOLLY SIGNOR: Thank you. (Whereupon, the discussion with Holly Signor was concluded.) (Whereupon, the following was held in the courtroom.) THE COURT: Do you have any other witnesses you wish to call, ma'am? MS. SIGNOR: No. THE COURT: Do you have any other witnesses you want to call? MR. LACUNA: No, Your Honor. THE COURT: The record is closed. These kids have been through a lot, but they are terrific kids, terrific kids. Off the record. (Whereupon, argument was held off the record.) (Whereupon, the hearing was concluded at 11:23 a.m.) 101 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CERTIFICATION I hereby certify that the proceedings are contained fully and accurately in the notes taken by me on the above cause and that this is a correct transcript of same. Pamela R. Sheaffer ~ ~ Official Court Reporter , The foregoing record of the proceedings on the hearing of the within matter is y roved and directed to be filed. ~% Ninth Judicial Di 102 ~A f ~~•~j,;~~~ic~~~~'c' ~ ~ , ~, r ~, r,~ „J Ci ,,,.,~~ ,~ ;:~ _. _ ~,~. BROWARD FACTORY DEAR JUDGE BALEY, I WRITE TO YOU TODAY PER REQUEST OF MY DAUGHTER, AMANDA AMAKER, WHEN YOU RESEARCH MY CASE YOU WILL FIND THAT YOU STATED THAT ERIC, AND AMANDA WERE OLD ENOUGH TO DECIDE WHERE THEY WISH TO RESIDE. AMANDA BEING 75 YEARS OF AGE WISHES TO RESIDE HERE WITH ME IN NEVADA. I WAS CHARGED WITH KIDNAPPING OF MY CHILDREN BACK IN 2003, AUG. THESE CHARGES WERE DISMISSED BY JUDGE EVANS WITH TIME SERVED. 1 HAVE A WONDERFUL JOB WITH A SUPERVISOR POSITION, AT BROWARD FACTORY SERVICE,. t HAVE A NICE RESIDENCE WITH TWO GREAT POOLS WHICH TH'E CHILDREN ENJOYED WHILE THEY VISITED IN JULY. I LIVE ALONE WITH MY CAT AND NEVER MISS WORK. MY LIFE IS STABLE AND CAOUS FREE SINCE I-LEFT THE MARRIAGE WITH RANDY SIGNOR. RANDY HAS,YET AGAIN MOVED THE CHILDREN FROM WHERE HE STATED TO YOU HE WOULD ALLOW THEM 4225 West Teco Avenue • Las Vegas, NV 89118-6805 • Ph:(702) 798-9720 Fx:(702) 798-9750 WARD FACTORY RVICE HE ALSO STATED THAT HE WOULD ABIDE WITH AMANDAS DECISION TO LIVE WITH ME IF SHE CHOSE TO DO SO. I SIMPLY HAVE NO FUNDS TO CONTINUE TO FIGHT WITH THIS MAN, HOWEVER, YOU SAID YOU WOULD ABIDE WITH MY TEENAGER'S REQUEST AS TO WHERE THEY WISH TO RESIDE. 1 WISH TO KNOW HOW TO GO ABOUT THIS, AMANDA WISHES TO SPEAK WITH YOU. AND SHE HOPES YOU WILL GRANT HER WISH TO LIVE WITH HER MOTHER. AT THIS TIME 1 HAVE NO' FUNDS TO FLY TO PA. MAY THIS BE RESOLVED BY MAIL, PHONE CALLS, FAX, ~`-{~._.? MY DAUGHTER ~N17 I WISH FOR YOUR Ii4PIME®IATE ATTENTION TO THIS URGENT MATTER. SINCERELY, LOUISE SIGNOR. 4225 West Teco Avenue • Las Vegas, NV 89118-6805 • Ph:(702) 798-9720 Fx:(702) 798-9750 TO FINISH SCHOOL AND REMAIN WITH THEIR FRIENDS. __ PAYROLL /PERSONNEL RECORD CHANGE ~~ ' ~~.~ Employee Name: ~' ~ ~ ~~ ~ ~. ~ Social Security #: ~ rf' ~ _ S 2.~ g` Date: ~~_2 j . p Su scriber: CC/DC: Job Title: O ~'~', c~ S tic !/i SO/~- Supervisor: ~ ~, ' f ~ y~~ Effective Date of Change: ~ ~ _ Z ~`~ 0 y ~a.~3At~(3t1A`!1±VtTN. ;(G1-edtntlreapl~aun=li~hal~~apply*)4~ ~s.; FROM " TO ~ Pay Rate Change $ $ Retro Pay ^ Yes ^ No Amount $ Part-Time Full Time ,'~ Department ~ ~~~'G ^ Benefit Class Code '~ Salary / ourl ^ Workers' Compensation Code ^ Other: Payro11~l3edu~hon , . .:: ~ ; ,. + Frequency: t Maximum $: ^ Uniform ^ Loan ^ Other (Explain): .. ' Persorral Change .~ ..; .. ' ` ~ ,' ~`, ' ~ ^ Name ^ Address ^ Telephone Number ^ W-4 (Supply new form) D Other (Birth, Divorce, Etc.): Employee Signature: ~ Date: 3J ~ Supervisor Signature: ~ ~ `~c- Date: ~8 y3~ o Super~lisorName (Please Print) ~'`,,.F~~ ~ , /,~~/~ 'd I1\\^`\J •tiy ^ ^ O V \.\Y\ I ~ ~ , C\ het' ~, Q -h w ~ ~ fi ~ ~ ~ ~ ~. ~. ~ N ~. ~~~ ~ ~ A N N U E O R C R A ao mz 00 ~D W O ~, :~ ,= ~, ,, ~ ~ ~, b 3 ~ 4 ~ rv n T i', ( , r N ~ ~ ~ O C a W ~ 00 00 O 0 x E w a 6 N c,~ n ,rt.. ,, ~3.-~:.,,~ "...c ~., bx ,n t.,i <^4-~.': _ tiy~a,..~_ ne wr-.l . .s'',.S -"a~ r _ ._`F3.xnxi^}3. ~. LOUISE SIGNOR, IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. RANDY S. SIGNOR DEFENDANT 01-5352 CIVIL TERM ORDER OF COURT AND NOW, this 2'~ day of October, 2003, following a hearing on the merits, IT IS ORDERED: (1) All prior custody orders are vacated and replaced with this order. (2) Randy S. Signor shall have legal custody and primary physical custody of Tyler Signor, born October 18, 1996, Amanda Amaker, born December 15, 1989, and Eric Amaker, born May 12, 1988. (3) During each summer school vacation period, Tyler, Amanda and Eric shall visit with their mother for four continuous weeks with the time being set by Louise Signor and Randy S. Signor not later than June 15t each year. Transportation shall be provided by the mother. (4) The mother shall be allowed to be with her children when she visits this area. She shall provide Randy Signor prior notice of when these visits will occur.' ' This order is premised on mother now living in Las Vegas, Nevada. k 1-;~~~i; ~^AF~~~ ~ link!\J: `d-"_r~ <w 1 1 .~. .fir, '_~~~; `., , +'1 C I ~`) Robert R. Laguna, Jr., Esquire 1119 North Front Street Harrisburg, PA 17102-3318 For Randy S. Signor Louise Signor, Pro se 4505 Paradise Road Las Vegas, NV 89109 :sal ., LOUISE SIGNOR, IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. RANDY S. SIGNOR, ; DEFENDANT 01-5352 CIVIL TERM ORDER OF COURT AND NOW, this `2~-'~ day of December, 2003, the custody order of October 23, 2003, is modified to provide that defendant, Randy S. Signor, shall not interfere with Louise Signor having phone contract, mail and email contract, with Tyler, Amanda and Eric, or with their receiving any gifts from Louise Signor. By the Edgar B. Bayley, Robert R. Laguna, Jr., Esquire 1119 North Front Street Harrisburg, PA 17102-3318 For Randy S. Signor Louise Signor, Pro se 4505 Paradise Road Las Vegas, NV 89109 .~«"~ ..ry,,,.4.~e~a.- isC-~7~-~~ ~'" . :sal ~~ ' i4mV_^411P i~-.V3u i.}~sS owYnb' ..- ~Nsywiir~ + ...1%r .ao-t r-,Ittnls4cC~ti~iti~s~i1~,'t,. .. r~~j?~~ ~~ n/?i; ~ `t! ,`,,~-`y~G,, 0~ -vyy~ ,~r~:yv• ,`~' ,7,,~ `'~ ~i) 1 ~~ ~`'L6 ~ `~' ~' LOUISE SIGNOR, IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. RANDY S. SIGNOR DEFENDANT 01-5352 CIVIL TERM ORDER OF COURT AND NOW, this 2'/ day of October, 2003, following a hearing on the merits, IT i'S ORDERED: (1) All prior custody orders are vacated and replaced with this order. (2) Randy S. Signor shall have legal custody and primary physical custody of Tyler Signor, born October 18, 1996, Amanda Amaker, born December 15, 1989, and Eric Amaker, born May 12, 1988. (3) During each summer school vacation period, Tyler, Amanda and Eric shall visit with their mother for four continuous weeks with the time being set by Louise Signor and Randy S. Signor not later than June 15t each year. Transportation shall be provided by the mother (4) The mother shall be allowed to be with her children when she visits this area. She shall provide Randy Signor prior notice of when these visits will occur.' Prothonotatr 'This order is premised on mother now living in Las Vegas, Nevada. ~~ / Robert R. Laguna, Jr., Esquire 1119 North Front Street Harrisburg, PA 17102-3318 For Randy S. Signor Louise Signor, Pro se 4505 Paradise Road Las Vegas, NV 89109 sal ~~a .:~ ~~,.. " ~ ~~6 • • ~ ~ C~ LOUISE SIGNOR, IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. RANDY S. SIGNOR DEFENDANT 01-5352 CIVIL TERM P~.~,~.~,o~ ~o m~a.~ ~y ~~hOrC~.~~e~~~,e.~ae~~~( lZ tib-o3 ~-l'~,ous~~ L ~~~ ~o~~ d ee~s~a~ ; h ~, ,. t/~_ ~et~~+o~,~ed G~.foUUE~ WU.S ~c~:I.Y"' G1,v1.~ ~~-t-5`~ ~b y~~c~ev~2n,~ ~r ~~`~~ Con,4ws:en, a.h,d fin,-~wvers.~ ('~rr~+'r,~~, ~~~ ~n~~~ v"~a. phone. ~.~ d. £,-6r~,,~.~C w'~- ~ c_4.. Vie, ~ • ~ ~ ~ wn y'~"~S Case, w~.s b2.~o/`>° ~o~ ' ~ r~,a,~ ~-t~- CA n\,,-~-C~c,(. In7 i ~ ~,~ i ! 4 ~d y~~t 1~ ~ G~ p~h2.. (~j G h. '16~r- rBUl~b~ ®~L{Py f J ~~~~" < ~e- c.5Ce,5 C{~S.re,~'.ol~' $'~ ~`~' a-~ d ems, (Yl Q" d a s bet~.~ a ~ ~Fu,C cwE~ ~ h. ~ ~` ~~ l'~- q~- Sr~ee~Pi; ~ ~Jh~v~e~ C_a.l.ls GLQ.~~~ ~~ ~~5o re ",5 rte, t1~e., ~. ~t t~a-t- ~uGo~w ~ru.~ ~-I-~,e;~ v~ <~d-~-~~ ~ ~~~ u a ~ ~ ~ Cb t~,kr~.c~ ~ ~ ~b v~y c,Pn~(cdv~~ . ~s .~-4,.es~~-~ a~-~- ~,y~ use. c~.d r~~-E- h~ s . `"`~ ' .. ~ ', ~~ S ~oS ~ ; v~,Ce..~re (~, ~~ ', ,. .. ~; - -- ------- ___ ~ -- 0 ... - ~ aP. --; - - -- - -~--- _~ : ~ ,_ _. _. , __ o ~;_ ~. ~.. a ~-~; ~-_ ~n cL- ~? ~ o ~ - - ~: ci ~ ~. LOUISE SIGNOR, IN THE COURT OF COMMON PLEAS OF PLAINTIFF :. CUMBERLAND COUNTY, PENNSYLVANIA V. RANDY S. SIGNOR DEFENDANT 01-5352 CIVIL TERM ~oh~rc~le~~-d~,e.~c«~~~ lZ ti~-o3 ~~-4~,o~,(n. ~ ~ e~ C ~ o ~-v' d e e ~s~ avg. ~ ~, ~, C U~. ~~~~+~~ed G~~oouE ~ WU.S ~ci-ar 1A,vy~ ~c.c.5'-~ ~ ytiS,C~ev~lr~, ~ l s~~~~dh I.LL'~-- ~~i~.~.~-{'h2.~e. SZ~ee~+s -~ ~r ,~~~~~~ ~on.~ws~er~, a.~,,d ~n,~rilVerS~ CA~+'~~ i ~y~ ~ ~a~s -~' 4~„~ Ca,~~a~~ via. phone. ~.~ d ~-mod l d ~. Y6~~ pve~~6~ ~®~d~vQ.vt ~ ~ ~ ~~"e-~ Co ~,w~~.- < f ~~. ~~,s d~G~,~,r~- ,. yne, ~- wd~l ~~~s~ ~~, - also re ', ~ ~-~,pl~ rwalLc n~ Pb~d V~e,~.t~,S -Ib rte, ~e. ~~ ~C n,o~ ~,lo-w y~r~.~ ~~ ~ 5~d.~,~~ ~ ~ ~~G.~ ash ~v- od~.G~c~~,, '. ~~v~u y~ ~l~u.e. ~ C~jr~cn~~v Cb~nka-cam a,,S c.~~,u a~,S ~ ..,,, ~~ ~d ,U <..~~ ~~~~; G _~ '! d L~ vv~, lour -C_ d W~~r !L ~,S~S -Q ~.~`~ D t.~,-~- o ~~ use ~~~.........))) c "_ LOUISE SIGNOR, IN THE COURT OF COMMON PLEAS OF PLAINTIFF :. CUMBERLAND COUNTY, PENNSYLVANIA V, RANDY S. SIGNOR DEFENDANT 01-5352 CIVIL TERM P~.E~~.~~o~ ~o mid-~y ~ol~~rG,{o l e ~~ r~e.~ae ~~~ lZ ti~-o3 Cam- ~1~~+o-need c~.loove~ WaS ~a'~r- q,~d- ~r.~,5~ ~ y~~dev~lr1,_ \r ~~~~ ~on,~~arL Ct.v~,d ~jn,`~V~rs~ r`.0frl~r~~~ ~ ~ ~ ' ~~`~ ~"~S Case, w~,s b e.~r~~ ~o~ ~ w+Gc,(. W i ~ Y-,.~ ~` ~ ~v~h ~ J ; ~ ~ iki~ ~ a..~ ~' ~-~ ~n~.L-~- d~ y6~~ P d~ ~d as b~ c ~~~'~- o~/'det~'~ m~ ~ f~,~, a>~ Spa ~Fwce ~ n; ~-~,, -~ ~ w~~l C'.~v~~'-isc~-~ ~rM, _ also lie ',5 ~,.~ rwc.~1~ ~~ P,uu~e, ~.c,l,s `~ rxe., 1~e_, ~: ~t ~-E- ac,Got,~ y-~.e,rN.~ ~-I-{~,n~, ~ 5~f L.~cl.~.,~~ ~ v~k ~ ~ h~ l~ ~~~ 5c~~ ~- ,~ ~ ~~ue. ~ Cb,~pcn~,-~~v C6~,k~ c,~~,~. ~,S ~`~~h~e. a+~.d ~ by s •`~~,c~n,lc 1,~c~ ~ ~ a,,w k;>~ ' ~~~ ~~~ ~~~ 1~P ~ ~~ ~ i y1,Ce..rP ~s~ ~ i~! v.. ~. -~~~ ~w~ . ~~i LOUISE SIGNOR, PLAINTIFF V. RANDY S. SIGNOR, pEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-5352 CIVIL TERM ORDER OF COURT AND NOW, this 7~ day of September, 2006, the petition to proceed in forma pauperis by filing a petition for special relief, IS DENIED. By the, ~~ -~ Edgar B. ~ndy S. Signor 455 Thundergust Mill Road Wellsville, PA 17365 wise Signor, Pro se J C/ 2312 Pennyroyal Terrace Baltimore, MD 21209 :sal ,~~'~ ' We will not proceed on a petition for special relief based on the general allegations set forth therein. Petitioner may prepare a petition to seek modification of the custody order, and concurrently file a petition in forma pauperis utilizing a form attached. ,.. ,:~ ~r ~~ ~- 1 L ^ ~ ;fin ~~ -°'ir. -4l_ _ ~ ~~ _ ~ _~ v~ f , Plaintiff vs. NO. Defendant APPLICATION FOR T.EAVE TO PROCEED IN FORMA PACJPERIS I, .due to my financial condition , azn unable to pay the cost of this action, wherefore, I request I be permitted to file in Fotzna Paupetis. Date -- + 1. I am the (plaintiff) (defendant) itn the above matter and because of my financial condition atrl unable to pay the fees and costs of prosecuting or defending the action or proceeding, 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and coaect: (a} Name: _ Address: Social Security Number: (h) Employment If you aze presently employed, state Employer: Address: Salary or wages per montl,~, Type of work:, If you are presently unemployed, state Date of last employment; Salary or wage per month: Type of work: (c) Other income within the past twelve months Business or profession: Other self-employment; Interest: Dividends: Pension and benefits: ,_ Social security benefits: Support payments: Disability payments: V, Unemployment compensation and supplemental benefits: R'orkman's compensation: Public assistance: Other: (d) Other contribntions to household support (W'ife) (FTusband) Name: If your (wife) (husband) is employed, state Employer; Salary or wages per month: Type of work: Contributions from children: Contributions from parents; Other contributions: (e) property owned . Cash . Checking account: Savings account: Certificates oFdeposit: Real estate (including home); Motor vehicle: Make Yeaz Cost ,Amount owed Stocks: bonds: Other- (k~ Debts and Obligations Mortgage: Rent: Loans: Other: 3 (g) Persons dependent upon yon Tor sapport (Wife) (Husband) Name: Children, if any: Name: Age: Other persons: Name: Relationship: ~~ Date: Petitioner Proth. - 71 You must use black ink to fill out this form. Your Name: Sip 2 2 '~dp6 _~ IN THE CUMBERLAND COUNTY COURT FOR THE STATE OF E~~`1SYLVANIA _ _ AT CARLISLE g'~ •~---- --` -- City or Town where Court is located LOUISE SIGNOR Plaintiff, vs. ) ~ i RANDY SIGNOR ) _ Your Case No .(i3`@63~2 ` 6.5~°~,5 0~ Defendant. ) CUSTODY & VISITATION ORDER (Short) The X^ plaintiff ^ defendant filed a motion and the opposing party ^ did ^did not respond in writing. A hearing ^ was ^ was not held on ,which ^ plaintiff and/or ^ defendant attended. After considering the motion and any opposition thereto, and good cause being found, the following custody and visitation IS HEREBY ORDERED for the following child(ren): Child(ren)'s Name(s) Dates of Birth TYLER`SIGNOR 12/19/86 AMANDA AMAKER 12/15/89 1) Legal Custody shall be with the ^ Mother ^ Father or ^ both parents 2) Physical Custody shall be ^ shared between the parents or ^ primarily with the ^ Mother ^ Father. The child(ren) shall reside with the ^ Mother ^ Father except for the following days and times when the child(ren) shall reside with or be with the other parent: 3) Other: Dated at PENNSYLVANIA this day 20 Judge I certify that on a copy of the above was mailed to each of the following at their addresses of record. (List names if not an agency) ^ CSSD/AG ^ CI Deputy Clerk/ Page 1 of 1 Order For Custody & Visitation (Short) SHC-1123 (4/05) . ~. ~~1;~~5c. S~ S ~ qno~ PLAI IFF FAMILY COURT' DIVISION CIVIL AC'T'ION I ~ EFENDANT D.R. NO. ~- ~~pZ PETITION FOR EMERGENCY RELIEF --CUSTODY vs. 1. Pe ' ' is (name) (~()~ ~51~ i plainti t' defendant (circle one) in an est es at (street,cit~+, st~te,zip) 2. Respondent is (name) /rL~'-r/Cr~ is plaintiff or defendant (circle one) in the and resides at (street, city, state, zi ) /.~ lp llsl~i l~e ,~~ complaint, 3. Petitioner's relationship to the following minor child(ren) is p / iD~~. e~ ~ LIST FULL NAME(S) AND DOB(S) OF CHILD(REN). ly ~~ Jona~ian s~na~ ale /B ~.n cla. ~t~K~ QJf ,c, /~ 4. Respondent's relationship to the child(ren) is ~~ to(/' `j ~ ~r 5. CIRCLE ONE: A. No custody order exists concerning this~/,t1~se child(ren). B. A custody order was entered on Q( ~t'D b~f OQ3 (date) that states the following: 0 ,~.a., y 6. CIRCLE ONE: complainUpetition is being filed with this petition. B. A complaint/petition was filed on (date) and a hearing has been scheduled on (date). 7. Petitioner believes that a situation exists that requires an emergency listing because: a• ThC- C/ll /C,'/~n QY't°. /107 lJl~-fe b. -7tie Chilci~r/en ~j~ve of ~.ny ~'eval e. /het ~1G~c j nO >< ,~1J2 ~/~l%v~ j~ C1n Q~!'lv6ana~'e°~ f ~v~~..lec,/~,z~~ WHEREFORE, petitioner respectfully requests that this honorable court grant the following relief Date: % ~ d ~ (/?l:~-ado ~/ /~G~ P tioner I verify that the statements made in this petition are true and correct. I understand that false statements herein are made subject to the penalties of PA. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: q °?a'~ ~ r ~~ r7Oor" rtioner - _: _ ~w.r~s~:~ua'_~rvi~.x~•=axa~- s+k'.ac.*`~xm:,.~~.,v,.w :. aa~sen r.,.as sc.~aA.a,. .w,.°.sae~-+sur..vaEw-a~n ~ r1~ C,n 2 ro~! ~ i~r f'Pt G'`' ~~; ~ -1 --rn' ~ C' W m ~ <- -a ®w -_ ~~O i5 ~ s` ~i for , pYO ~•~ 0?,1'~ me~vYa( ,etrr~ce l / o (f„» addrsl43 ~~~ ~ (area code and telephone number) P aintiffT (s) ~ ~ VS. 12Gn~-4 S ~~rrto~ Defendant(s) Term, 20 D t/O nwndQ (Year) a N0. ~ "' D,S3.~~ In Forma Pauperis Order AND NOW, this _ ; day of _ ' ,_ ~._ - . 20-a(~_ it is hereby ORDERED AND DECREED that: 1. Petitioner be permitted to proceed without paying the costs of this proceeding or posting a bond. 2. Petitioner be permitted to obtain service of the papers filed without cost. 3. Petitioner be permitted to proceed in forma pauperis as to any additional costs which accrue in the course of this proceeding. 0 (IFP/RHV.10/201q) Court Term 20and 4. If there is a monetary recovery by judgment or settlement in favor of the party permitted to proceed in forma pauperis, the exonerated fees and costs shall be taxed as costs and paid to the Prothonotary by the party paying the monetary recovery. 5. Petitioner has a continuing obligation to inform the Court of any improvement in party's financial circumstances that will enable the party to pay costs. BY THE COURT: J. L~ltiSf ~~~` for/' vs, ~~,~ ~ ~ S ` ~ ~ o~ ~p-Fi 6 ~ ~~ .~~ys%°~~ °~ eS 3S ~ G~1~: C~J Pto~eecl ~n Fo~r~~ P~~~c~c~is y ~ ~ ~~~s ~ ~-U ~ ,~~ S ~l~iv ~ J ~5-~ ~~~ ~-~ ~ ~rrup~v~j ~e ~e~-~ ~-v~ d G1~ve /tv ~ ~ S 4~ ~,Q5~2Go~~~~ ~c/(,`vS CJ/~ c S ~ /J ~~~/ ~e ~~<'~~ ® o ~, -~~~.; `~C~~ u~ ----1~ mT r ~ ~ ~ ~ ~ ~ p N ~ tel.' L .-. ACT -a -~-°~~'I U ~ ~~ ~ ~ Q ~ ~ " „~ '~" v ~ A ti A. Nikki Fleming 2312 Pennyroyal Terrace Baltimore, Maryland 21209 auntnik2Ca~uol.com 410-664-5432 September 21, 2006 To Whom it may concern: Please be advised that I am writing this letter in support of the best interests of the Amaker/Signor children, Amanda Amaker and Tyler Signor. I am the maternal aunt of these children and have been actively involved with their care for most of their lives. I have provided a place for the children to reside with their father/stepfather since November 2003. I have maintained a relationship with the children since their births but became more financially and emotionally supportive since their living circumstances were substantially altered due to circumstances beyond their control. When Randy Signor, their custodial parent, lost his job and the bank foreclosed on the family home, I invited the family to move into my mother's home which I inherited after her death in October 2003. From that time to the present, Randy Signor has not obtained any permanent means of support. Because I did not want the children's lives disrupted any more than necessary, I permitted them to remain in residence. In addition, I have given continued aid in the form of paying utility bills, purchasing a family car, and providing Randy with paid home improvement work. To try to make sure the children had a decent quality of life, I have also purchased food, school supplies, school wardrobes, and substantial holiday gifts. I took unofficial custody of their older brother, Eric Amaker in December of 2004 and provided for his care and attendance at a private high school until he left for West Virginia University in September. I write this letter because I have come to believe that it is no longer in the best interests of the children to remain in the custody of Randy Signor. Randy has been given every possible support to become a responsible parent. Unfortunately, according to those closest to him -his children, J.R. and Holly; his sister Janice Signor; his step-children Amanda and Eric Amaker - he has not taken advantage of his respite from the normal adult responsibilities of working a full- timejob, paying the rent, or supervising the children in his care. I became particularly concerned last year when the children began to report that Randy was using drugs. When the local Department of Social Services, became involved, I spoke directly with the worker, Stacy Broad, to ascertain if there was any truth to the allegations. Ultimately, I was told that the worker suspected that he was indeed abusing methamphetamine but that since the "meth" epidemic in rural Pennsylvania had saturated the system with children in need, the children would not be removed as long as they were being fed, clothed, and sent to school. The worker assured me that she would make Randy take a drug test and if it came back positive treatment would be mandatory. ~. Unfortunately, the Department of Social Services did not pursue this course of action. Those closest to Randy, particularly his sister and adult son and daughter, report that his behavior has continued to deteriorate. His son does not have a relationship with him because of his drug use, he does not speak to his daughter, and his sister only maintains a precarious relationship - subject to his unpredictable, drug influenced behavior - so that she can maintain a relationship with Holly, Amanda and Tyler. The children spend most of their time at her home and are only with Randy when school is in session - a situation driven, I suspect, by the fact that he has been called in by truant officials and has had to pay fines in the past because the children did not attend school. My concern is for the physical as well as emotional health of the children. In 2005, there was a fire at the farmhouse where they reside. The fire originated in a chimney that had been improperly vented and not sufficiently cleaned out after not being used for more than 45 years. While this event was an accident, it raises concerns about the children being left alone at the premises so much of the time. Often Tyler is "home alone" after school because there is no adult there when he gets off the school bus. I am supportive of my sister's request to have the children come live with us. Although this may not be the optimum solution it is certainly better than the alternative. She and I can provide a nurturing, secure environment for the children. Tyler, in particular, would benefit from this placement because he has unmet special educational needs that would be addressed by an extensive IEP in the Baltimore City School system or through a private placement if necessary. As I can no longer support two households, and Randy has not responded to my request to pay a reasonable rent, I am going to sell the farm. I fear that without this support, the living and psychological well-being of Amanda and Tyler will be in jeopardy if they remain in the current custodial arrangement. With the proceeds from the farm, it is my plan to either purchase a larger home where we all can live, or to help my sister obtain a home for herself and her children. I am committed to making sure that my niece and nephew have the best life possible and I plan to assist them as I did their brother. I am fortunate to have been employed by the City of Baltimore since September, 1975. With my salary as Deputy Directory of the Department of Legislative Reference I am in a position to offer my continued financial as well as emotional support. Should the Court, or its agents, have any questions, need for clarification, or further information during business hours please feel free to contact me at my office: Room 626 City Hall, 100 North Holliday Street, Baltimore, MD 21202; Phone # 410-396-4730; a-mail: Nkki.fleming_nbaltimorecity.gov. Thank you for your sage attention to this critical situation. Sincerely, A. Nikki Fleming P !j! Louise "Liz" Fleming 2312 Pennyroyal Terrace Baltimore, Maryland 21209 Phone: 410-664-9042 To: The Honorable Judge Bailey: This is an emergency petition to the Court to grant me temporary custody of my children, Amanda Amaker, age 16, and Tyler Signor, age 10. The children would reside with my sister, her son, and myself at the above address in Baltimore, Maryland. The children have spent a lot of time with my sister and feel very much at home at the condominium and in Baltimore. Given the unhealthy environment in the current house at 455 Thundergust Mill Road, Wellsville, Pa, I feel this would be an appropriate emergency placement while the Court determines a permanent placement that would be in the best interests of my minor children. Since the time that the Court granted my ex-husband, Randy Signor, custody of my children, Eric Amaker, Amanda Amaker, Tyler Signor, and Holly Signor, with 1 month of summer visitation to me, I haue not had the court-ordered access to my children. This lack of direct contact has caused my children and myself extreme emotional distress that became a factor in my receiving a DL1I and a subsequent order to either a 2 year program which would prevent me from leaving Las Vegas, where the order was issued, or 6 months in jail. Knowing that my choice to drink and drive was solely my responsibility, Ichose the sentence of 6 months, rather than to be denied access to my children for 2 years and to leave them at the mercy of my ex- husband. I did complete the sentence and am determined to make better choices so that I can be available to my children who have suffered greatly in the custody of Randy Signor. Although Randy was given the opportunity to live rent free on my family's farm until he could get himself together, he has not secured permanent employment since 2003. His erratic, drug induced behavior became so abusive, that my elder son and he began to have physical confrontations. Fearing that my son would be harmed, I allowed him to move in with my sister in Baltimore. My daughter has also been harmed by his behavior, but he refused her to move to Baltimore. Despite the fact that Randy claims to love Amanda, when angry he continually makes derogatory comments about her interracial heritage, calling her the "N" word. To present the Court with an overall picture of the living conditions at the Signor residence hi Pennsylvania, I am presenting a few situations: Randy is currently under investigation for welfare fraud, because he made false statements to the agency to receive benefits because he has not had steady employment, nor has he sought employment, since 2004. • Randy has been arrested for theft of my brother's horse trailer, which he allegedly sold . __ _ ~~. • Randy is under investigation for the suspicious disappearance of a man that witnesses saw him assault and threaten to kill. • The home has continually been investigated by Social Services because at times there has been no food in the home, the children have been truant, and there are repeated reports of drug use on the premises. • Randy and Amanda were in a confrontation that left Amanda with bruises and caused her to run into the nearby woods in fear and hide out alone for hours. • The electric has been cut off a number of times after my sister refused to continue to pay utility bills that Randy had allowed to•grow to over $900 despite being offered the opportunity to enter into a budget plan for low-income customers. • Randy's daughter found the conditions so intolerable that she fled the farm and lived with Randy's sister. • All of the children are in left at the sister's house the majority of the time and no one has anyway to communicate with Randy or to know when he will show up or if he will show up to take the children home so they can attend school. • My son has already missed 4 days of school since the school year started, there is often no food for him to take for required snacks, and often free school lunch is the only wholesome meal he has all day. Your Honor, these are just a few of the conditions that exist under the current custody arrangement. All of the older children, including my step-daughter, Holly are anxious to speak directly with the Court. This is quite a responsibility for them to assume, but, unfortunately it is not the first time. They have tried to get help for themselves be calling out to the adult world in the form of the Department of Social Services, School Counselors, and the Police Department - all to no avail. I am begging the Court to help my children and myself by allowing us to reunite as a family so that the healing can begin. Sincerely Submitted, Louise "Liz" Fleming Mary Eppler Racing Stable, Inc. 2089 Reese Road, Westminster, MD 21157-7119 September 21, 2006 To Whom It May Concern: Home: (410) 840-8156 Farm: (410) 833-1131 Fax: (410) 840-0056 Pimlico: (410) 367-5159 Louise Signor has been employed by my Company since August 22, 2006. She has been extremely helpful and very dependable. She is a great asset and she will have continued employment for as long as she continues in her reliability. If you have any questions please call me at the above phone number and I will be glad to speak to you about her. Sincerely, Mary E. Eppler i~E~~ 0r Welcome to the Mount Wasiringfon Elementary School; a gem among the schools of Baltimore City. At Mount Washington, we value scholarship of all kinds. We work to ensure that the foundational skills are in place for all students so that their success is not just our hope but our passion. We value scholarship beyond the core subjects by maintaining quality arts, sciences and humanities programs. We continue to build on our classroom technology to allow our children to become scholars for the 21st Century and beyond. !` Khu last s repsrrtir~ acid an~ysls Username: Password: Here at Mount Washington Elementary, we also value good citizenship, both as a member of out school, but also as part of our community, city, state, nation and world. By putting scholarship first, with the support of the community, we show our students that a strong; diverse education enriches lives and empowers people to do incredible things. PTO For news, information, and the ability to contact a PTO member directly. ~'~_...rv - ~ Event Caler>tdar ,~,, 9 p 9 Y t A 3 y • # # 1 A AYi Find out whats going on at Mt. °""'"'~'°" ,aro»a,. et xW~r Washin ton Elements School. g ry ae six m»x Our Staff ,~~~. `~1 `"~~ Click here to meet Mt. ' Washington Elementary's dedicated staff. t FAQ's Nave a question? You may find g ~ your answer here. Or you can ~ use our online contact form. [ Photo Gallery Home i Event Calendar I Tiger Docs I Our Staff I Kids Links ~ FAQ's I PT4 I Photo Gallery I Academic Programs I Contact Us Sec rr'~rcene Errt?-r'prtze~lnr, http://www.mtwashingtonelementary.com/ 9/21/2006 Welcome to Mt. Washington Elementary School `~ ~ Page 1 of 1 - -- - ~u; Academic Programs at Mt. Washington ~ ~~~ Password :................... Page 1 of 2 Mt. Washington Elementary School is an academically challenging learning community. All students are engaged in a stimulating and rigorous instructional program, including language arts, mathematics, social studies, and science. In primary grades language arts, Open Court, aphonics-based language arts program, is used. Students also read literature to balance this approach to literacy. Intermediate grades use a literature based program, Invitation to Literacy. Mathematics instruction includes an emphasis on problem solving. Ma#h In My World is used in primary and intermediate grades. Science instruction is inquiry-based, with an emphasis on experimental learning. DiscoveryWorks is used in primary and intermediate grades. Social studies instruction focuses on geography skills, social awareness and our government through a program, We Live Together sponsored by National Geographic. Our Mission Tha mission of the Mt Washington Elementary School is to make students aware of their historical and cultural foundations, to understand and appreciate humankind's achievements in arts; literature, philosophy, and language, and to foster students' creative self-expression so as to produce citizens who are sensitive to the human needs of individuals and who are able to function in a highly technological society. Not only will our students be adequately prepared to move from one educational level to the next, but also they will gain a broad perspective with which to carry on the traditions of a strong democratic society. The Foundations of Scholarship Without the foundational skills in education, students cannot fulfill their dreams as citizens. In order to ensure that all of our students have the maximum chance for success as adults, at the Mount Washington Elementary School we work diligently to support our young scholars in mastering the foundational subjects of language arts and mathematics. In language arts, we use the Open Court reading series in the younger grades to ensure a solid understanding of the relationship between letters and sounds. As part of a balanced approach to literacy, our younger students also discuss literature through read aloud and small group instruction. In the higher grades, we use the Houghton Miffilin reading series with supplemental novels to give students a broad range of literary experience. For mathematics; we use the Math in Our World series with a wide variety of supplemental materials to encourage advanced learning and math communications. In support of all of these programs, we have created a schedule that allows for uninterrupted time during these subjects. We also have intervention programs to assist students who are in need of an extra push, whether that is because they are falling behind or because they are ready to advance to more challenging work. By laying a solid foundation in the core subjects, we open up a world of opportunity for our students here at our school and well into the future. Scholars for the 21st Century and Beyond To help our children become more adept scholars, we have expanded our resources to help http://www.mtwashingtonelementary.com/AcademicPrograms/index.asp 9/21/2006 Academic Programs at Mt. Washington Page 2 of 2 them explore knowledge through research and discovery. Our library allows our young scholars to gain knowledge through the written word contained in picture books, novels and expository texts. Building upon this, our technology laboratory allows students to safely surf the Internet in order to research different topics explore new ideas and find new ways of looking at the world. In addition, technology is spread across the school, with computers in each classroom and a variety of advanced tools that allow teachers and students to make multi-media presentations. Scholarship in the Arts, Sciences and Humanities Here at Mount Washington, we value quality instruction in the arts, sciences and humanities because a true scholar is well rounded. In science we focus on exploring content knowledge as it is presented both in expository text as well as through experimentation and hands-on activities. Our social studies lessons explore the world around us, expanding from our neighborhood to our state and nation as the students advance in grade level. Our art classes work in multiple media to produce works that are not only exquisite, but show a broad understanding of artistic expression. All of our students participate in vocal music and as they mature, are given the chance to learn string instruments as well. Our young scholars learn to be strong in body as well, when they attend our physical education classes and during daily play time. We also offer enrichment in the sciences, arts and humanities after school. Clubs, run by our staff members and parent volunteers, allow children to choose a topic for greater attention based on their interests. Club topics change each semester, but often cover foreign languages, instrumental music, arts and crafts, reading, math and sports. Taken together, these opportunities for our children to advance their scholarship show how much we value the arts, sciences and humanities here at the Mount Washington Elementary School. Young Scholars as Young Citizens We look to our young scholars to be the great citizens of the 21st Century. We highly value good citizen scholars in our school and we support good citizenship in a variety of ways. Our school begins with a calm learning environment, where the focus is on meeting students' academic and emotional needs. Our diverse learning community reinforces the need to be sensitive to others and we are enriched by the various cultures that are represented here. Our students' complete community support projects through Student Council and Student Safety programs. A corps of peer mediators is trained in conflict resolution to help teach others how to solve problems in a productive and non-violent manner. We reward appropriate behavior is a wide variety of ways that help students to understand the importance of good citizenship not only to their own future, but for the future of the entire community as well. Home ~ Event Calendar I Tiger Docs ~ Our Staff ~ Kids Links ~ FAO's I PTO I Photo Gallery ~ Academic Programs I Contact Us Ser Greene Erterpri;,r:e Iric http://www.mtwashingtonelementary.com/AcademicPrograms/index.asp 9/21/2006 Links for Kids ,.: t}ur teat s wtfng end y&€s t Userriame: Password: Page 1 of 2 There is no subsfifute for parentai monitoring of afi web-surfing. Please make sure you are aware of ail websites your child visits and that the content mafches your famiiy's values system. 3rd Grade Test Factory Extra Curricular Fun Links PBS Kids American Girl Vince's & Larry's Safely City Fine Arts Baltimore Museum of Art Art and Music History Ancient Olympics Art History Periods and Movements History and Geography US Constitution Time For Kids The First Democrats African History Link African American History Language Arts Resources Starfall Reading Mr. Shakespeare and the Internet Reading is Fundamental The Dictionary Math and Science Resources Chesapeake Bay Foundation Chessie from the Chesapeake Bay Math games for kids Math problems far kids Teacher Recommended Sites Electing A President Education World Everybody Extra Curricular Extra Curricular Ages 5 and up Ages 8 and up Ages 8 and up Ages 9 and up Ages 5 and up Ages 8 and up Ages 8 and up Ages 9 and up Everybody Ages 5 and up Ages 9 and up Games Homework Adults Ages 8 and up Extra Curricular Homework Extra Curricular Other Educational and Cultural Resources Home ~ Event Calendar I Tiger Docs ~ Our Staff I Kids Links ~ FAO's I PTO I Photo Gallery I Academic Programs ~ Contact Us http://www.mtwashingtonelementary.com/KidsLinks/kidslink.asp 9/21/2006 ~. w., Links for Kids Page 2 of 2 3er Grdarre Errterprlsae U~: http://www.mtwashingtonelementary.com/KidsLinks/kidslink.asp 9/21/2006 Baltimore Polytechnic Institute FAQ ~~~ ~~s Is Poly's tradition of academic excellence being maintained? ~~~~~< Page 1 of 2 Absolutely. Poly students continue to be accepted by some of the nation's most selective colleges and universities. They enter honors programs and receive millions of dollars in scholarships. Many students take advanced placement courses and perform well on the exams. SAT scores are higher than the state and national averages. Finally, after exhaustive documentation, the MSDE named Poly as a "Blue Ribbon School of Excellence." How is the climate at the school? Are students safe? Poly students are very safe and students, faculty, administrators, and parents work together to maintain a safe and orderly learning environment. Dr. Dehuffs words to live by (Freedom, Responsibility, Goodness, Mercy, Perseverance, and Achievement) and the Community of Caring values (Family, Trust, Respect, Responsibility, and Caring) remain important facets of the Polytechnic experience. Students whose behavior falls short of expectations face consequences that are spelled out in the student handbook. What courses are offered at Poly? Poly offers only college preparatory courses. The B-Course is compdsed of rigorous honors courses. The A-Course includes advanced honors and advanced placement courses. A-Course students are required to complete college-level work in their senior year. How much homework are Poly students expected to do? Successful students report that most nights average 3 hours of homework (30 minutes per class.) However, projects and research assignments often require additional time. What is the academic standard for remaining at Poly? The end-of-course passing grade for each class is 70. Students who fail one or two classes must remediate them at the first opportunity. Students who fail three or more classes are reassigned to their zoned high schools. How do I contact my child's teacher? All parents are encouraged to attend Back-to-School Night where they may get contact information for specific teachers. Also, there are two scheduled conference nights per year. Parents are invited to call the school to leave messages or request conferences with individual teachers. Parents may also fill out conference request forms that are kept on the main office counter. If parents would like to confer with several teachers on the same day, they should contact the guidance counselor who ran schedule parent-teacher conferences during the school day. Has the school name been changed to Poly-Western High School? Absolutely not! The two schools only share the campus. For example, they use the auditorium on alternating days and one kitchen provides the meals served in the two separate cafeterias. However, Baltimore Polytechnic Institute and Western High School remain two entirely separate and distinct schools with their own histories, traditions, curricula, faculties, and student bodies. http://www.bpi.edu/faq.jsp 9/21/2006 Baltimore Polytechnic Institute Page 2 of 2 Should freshmen play school sports? There are many advantages to joining teams and clubs. However, parents should monitor academic performance to be sure that extra curricular activities do not compromise academic achievement. The additional difficulties posed by late afternoon transportation should also be considered. Why do we have summer reading assignments? There are a number of reasons. Increasingly, colleges are expecting students to be familiar with more books than can be included during the school year. Summer reading introduces Poly students to more of these books. The selections are tied to course goals and content and allow teachers to get started right from the first day of class. Also, summer reading helps Poly students remain competitive with college prep students in other top-notch Maryland public and private schools. These books help students to expand their vocabulary and explore additional issues and concepts. Finally, their thoughtful reading and analytical writing helps students to avoid the "summer drop-off' which results in the lass of skills over the summer. All summer assignments are collected at the beginning of the school year and the grades are included in quarter averages. Must I purchase a graphing calculator? This is highly recommended. Students will use them in class and for homework as well as on the math High School Assessments. The Mathematics Department recommends the TI 83 or the TI 83+, Since they are costly, calculators should be engraved with identification information. Who is eligible for free transportation? All city residents who live 1 1/2 miles from school will be given a booklet of bus tickets once each month. Who is eligible for free or reduced price lunches? Students who received free/reduced lunches one year will receive them for the first month of the next school year. Students must reapply each year. Applications are available in the main office. Students are strongly encouraged to apply for free/reduced lunch as such eligibility also provides other benefits such as fee waivers for SAT tests and college applications. What are the school hours?. The school day ofricially begins at 8:15 when students must be seated in their homerooms or be marked late for the day. Classes are dismissed at 3:05. However, students are allowed to enter the building at 7:30 and may remain until 4:00. Only students involved in teacher-supervised activities may stay after 4:00. How can I sign up to "shadow" at Poly? "Shadowing" provides the opportunity for eighth grade students who are interested in aitending Poly to spend the day with a ninth or tenth grader as he/she goes through the daily schedule. "Shadows" need to bring a notebook, paper, pen and pencil, as well as lunch, lunch money, or lunch tickets. "Shadows" are expected to wear appropriate attire and be attentive, active participants in class. All students from Baltimore City Public Schools must register for "shadowing" with their middle school guidance counselor. All other students, and only those students, register by calling the Poly Guidance Ofrice at 410-396-7030 or 7031, during October. http://www.bpi.edu/faq.jsp 9/21/2006 Copyright O Baltimore Polytechnic Institute 1400 W. Cold Spring Lane, Baltimore, MD 21209 Tei.: {410} 396-7026 Fax: (410) 235-5027 School Profile News Western High School > Academics- School Profile Athletics ~ PTA School Profile Western graduates include .. . . Henrietta Szold, founder of Hadassah . Judge Sarah Tilghman Hughes, who swore in Lyndon B. Johnson as president . award-winning actors Mildred Dunnock, Trazana Beverly, and Anna Deavere Smith . Clara and Etta Cone, benefactors to the Baltimore Museum of Art reporter, commentator, and author Farai Chideya . state senator Lisa Gladden and delegate Ji// Carter . city council members Belinda Conway and Stephanie Rawlings. Page 1 of 1 Founded in 1844, Western High School is a pioneer in women's public education. Western has consistently attracted students of academic excellence. A liberal arts college preparatory school, Western substantiated its reputation for scholastic achievement with a college placement of lOD% last school year. Drawn from neighborhoods throughout the city of Baltimore, the current population of 830 is racially, ethnically, and socioeconomically diverse. Western offers two academic programs: accelerated college preparatory and honors college preparatory. The accelerated college preparatory program provides students an opportunity to cover four years of high school in grades 9-11, thus enabling them to pursue advanced placement or college level work in the twelfth grade. This program was organized in 1933 in cooperation with toucher College. The honors college program provides students with the opportunity to take honors courses in the subject in which they demonstrate strength. America's most prestigious universities seek Western graduates. Western High School's philosophy provides for the development of the whole child. The school sponsors more than 40 clubs, organizations and athletic teams. A small fraction of the opportunities available to the students includes championship teams, prize-winning fine arts performances, literary and journalism publications, visual arts displays, peer facilitating and leadership opportunities. As students in a highly charged, wholesomely competitive academic atmosphere, Westernites learn to assume leadership roles to seek solutions to problems, to initiate and implement projects and to begin to take charge of their own lives. Such experiences are invaluable to young women in today's society. The uniqueness of Western High School is unquestionable. Its scholarship, tradition, and spirit, which began 16Z years ago, continues to enrich the lives of Baltimore's future leading women. Read about Western's academic programs. http://westernhighschool.org/academics/schprofile.html 9/21/2006 View a printable flyer (PDF, 180KB) on Western. _._ ~~. Requirements News ~ Calendar Activities ~ Athletics ~ PTA ~ Alumnae ~ Resources Western High School > Academics > Requirements Academic Requirements For the Classes of 2007-2010 College Preparatory • 4 English • 4 Math (AIg. I Geometry, Alg. II Pre- Calculus) • 4 Second Language • 3 Social Studies (World History, US History, American Govt.) • 3 Lab Sciences (Biology, Chemistry, Physics) • 1 Tech. Education . 1 Fine Arts • 1 Physical Education • 1/2 Health • 1/2 Latin Connections (2007, 2008) • 1/2 Freshman Seminar (2009) ------------------------- 22 Required Courses 6 Electives (min. 2 advanced) Teacher Academy . 4 English • 4 Math (AIg. I Geometry, AIg. II Pre- Calculus) . 4 Levels of Same Second Language . 3 Social Studies (World History, US History, American Govt.) . 3 Lab Sciences (Biology, Chemistry, Physics) • 1 Tech. Education • 1 Fine Arts . 1 Physical Education • 1 Human Growth and Development through Adol. • 1 Teaching as a Profession • 1 Foundations of Curriculum and Instruction • 1 Educational Academy Internship • 1/2 Health • 1/2 Latin Connections (Classes of 2007, 2008) Accelerated College Preparatory Page 1 of 2 • 3 Honors, 1 AP English • 4 Math (AIg. I, Geometry, AIg. II Pre- Calculus) • 4 Second Language • 4 Social Studies (World History, US History, American Govt., Economics Honors) • 3 Lab Sciences (Biology, Chemistry, Physics) 1 Tech. Education (Sci., Tech. & Soc./Computers in Science) • 1 Fine Arts • 1 Physical Education • 1/2 Latin Connections (2007, 2008) • 1/2 Freshman Seminar (2009) 23 Required Courses 5 Electives (min. 2 advanced) Requirements for this program: Cumulative GPA of 3.0 Min., 4 hon. courses per yr. (sophomore-senior year), must take 3 Advanced Placement courses http.//westernhighschool.org/academics/curricula.html 9/21/2006 Requirements . 1/2 Freshman Seminar (beg. with Class of 2009) ------------------------- 22 Required Courses 2 Electives (min. 2 advanced) Page 2 of 2 . Freshmen placed in Algebra I may take two math classes in the sophomore year in order to enroll in Calculus in the senior year. Teacher Recommendation required. . Honors and Accelerated courses are available to all 10th, 11th, and 12th graders. Placement in honors and acceler-ated courses is determined by teacher recommendation the previous spring and year-end grades. . Students must enroll in a minimum of four credits each year from among the English, Mathematics, Social Studies, Science, and Foreign Language offerings. . Advanced electives are classes from the English, Mathematics, Science, Social Studies, and World & Classical Lan-guages Departments. http.//westernhighschool.org/academics/curricula.html 9/21/2006 News Profile ~ Academics ~ Activities ~ Athletics ~ PTA ~ Alumnae Western High School > News News Page 1 of 1 Parents are encouraged to attend Back-to-School Night on Thursday, September 14, 5:00-7:00 p.m. • Welcome to new staff members Millicent Boone (Paraprofessional), Ramona Browne (English), Kelly Caswell (Assistant Principal), Elizabeth Cullen (Spanish), Stephanie Farmer (Assistant Principal), Brian Garrity (English), Stephanie Novak (English), and Paulette Walton (Office Assistant). School begins on Monday, August 28 for all students. Welcome to returning students and to the Class of 2010! Dress Code notice: Western will not have uniforms for the 2006-07 school year. Our school, however, is a place of business. Students are required to dress appropriately, adhering to the BCPSS dress code. . The Required Summer Reading list, charts, and literature concepts guide are posted on the English Department page. . Sign up for our 3rd annual Eva Scott Scholarship Golf Tournament on Saturday, September, 16, 2006! Western bids farewell to veteran staff Suzanne Held, Marva Thomas and Elizabeth Walsh, retiring, and to Janice Nelson, leaving for another position in BCPSS. . Landa McLaurin, principal since 1998, leaves Western as of ]ulv. BCPSS has announced a search for her replacement and appointed Eleanor Matthews as Managing Assistant Principal for the interrim. • ...and see our archived news items for 2005-2006, 2004-2005, 2003- . 2004, and 2002-2003. http://westernhighschool.org/news/news.html 9/21/2006 ~,~.,~..,w..~wwar.:.; m..e,..,~ ..-_.___ _ .. - err,,.. Athletics Page 1 of 1 Profile ~ Academics Western High School > Athletics Athletics Athletics . Support Western Teams! Come see the Doves' games! . See Western's Softball Team in action! (plays with Ouicktime) . 2005-2006 Athleltic Teams and Schedules: For current season, click on the team shown below to see schedules and game records. Western's Athletic Teams Fall Varsity Cross Country Soccer ].V. Volleyball Varsity Volleyball 4fVinter J.V. Basketball Varsity Basketball Varsity Swimming Indoor Track Modern Dance Spring ].V. Badminton Varsity Badminton J.V. Softball Varsity Softball Varsity Track Varsity Tennis Varsity Lacrosse http://westernhighschool.org/athletics/athletics.html 9/21/2006 _., -- -~ ~. News News ~ Calendar ~ Prafi(e ~ Academics ~ Activities ~ Athletics ~ PTA News Page 1 of 1 Parents are encouraged to attend Back-to-School Night on Thursday, September 14, 5:00-7:00 p.m. Welcome to new staff members Millicent Boone (Paraprofessional), Ramona Browne (English), Kelly Caswell (Assistant Principal), Elizabeth Cullen (Spanish), Stephanie Farmer (Assistant Principal), Brian Garrity (English), Stephanie Novak (English), and Paulette Walton (Office Assistant). . School begins on Monday, August 28 for all students. Welcome to returning students and to the Class of 2010! Dress Code notice: Western will not have uniforms for the 2006-07 school year. Our school, however, is a place of business. Students are required to dress appropriately, adhering to the BCPSS dress code. . The Required Summer Reading list, charts, and literature concepts guide are posted on the English Department ~age. . Sign up for our 3rd annual Eva Scott Scholarship Golf Tournament on Saturday, September, 16, 2006! Western bids farewell to veteran staff Suzanne Held, Marva Thomas and Elizabeth Walsh, retiring, and to Janice Nelson, leaving for another position in BCPSS. . Landa McLaurin, principal since 1998, leaves Western as of ]uly. BCPSS has announced a search for her replacement and appointed Eleanor Matthews as Managing Assistant Principal for the interrim. . ...and see our archived news items for 2005-2006, 2004-2005, 2003- 2004,and 2002-2003. http://westernhighschool.org/news/news.html 9/21/2006 Western High School > News :. .~~~~~. News Archive, 2005-2006 News ~ Calendar ~ Profile ~ Academics ~ Activities ~ Athletics ~ PTA ~ Alumnae Western High School > News Archive, 2005-2006 News Archive, 2005-2006 Page 1 of 2 • Former Western teacher Nancy Colgan passed away in May. Ms. Colgan touched many lives at Western over more than 30 years of service. • Western's Track and Field team won the Class 3A state championships on May 28. . The Combined Bands of Western High School and Polytechnic Institute participated in the Williamsburg, Virginia, Heritage Musical Festival on April 22, winning 4 awards. . The Aoril 20th Sun featured Western's ]avaneh Jabbari, Shatera Kimbrough, Sophia Mavronis, and Julia Embry, who, along with many other Westernites, attended "Little Women" at the Hippodrome and will participate in a panel discussion with local leaders. • Senior Shalaiyah Sommerville was named "Girls Athlete of the Week" on April 19 by the Baltimore Sun. . Thursday, March 30 was Interview Dav at Western. Community professionals interviewed our students, who learned how to prepare for and succeed in job interviews. . Recent media reports (The Sun, March 23 and March 24) have raised concern among our students, parents, staff, and alumnae that Western has lowered its standards for next year's incoming 9th graders. Western did not lower its standards. However, in March Western received a list of students admitted for next year by BCPSS; over 100 students on the list do not meet our entrance standards, which have been published and disseminated by Western and the school system for many years. Thus far, all students admitted to next year's ninth grade at Western were chosen by the central offices of the Baltimore City Public School System. Western had no input into any admission decision and was not notified that BCPSS had changed admissions standards for Western. . Athletes Zhondria Benn, Akeema Richards, Theresa Lewis, and Shalaiyah Sommerville named to Sun All Metro teams! . The Western High School community mourns the loss of Francine Lamoureux, instructor of Spanish and French since 1998. . Baltimore City school officials have cancelled the three remaining "early-release" professional development days that require students to attend school for ahalf-day only. Therefore, students will REMAIN IN SCHOOL ALL DAY and receive a full day of instruction on the following dates: Friday, February 17, 2006, Friday, April 28, 2006 and Friday, May 26, 2006. Report cards will be issued,to students on Monday, January 30. Parents are encouraged to speak with their daughters' teachers at Parent Conference night on Tuesday, January 31, 5-7 p.m. • BCPSS invites you to a community meeting to RANK your PREFERENCES for HIGH SCHOOLS throughout the City on Saturday, January 7, 2006. • Report cards will be issued to students on Monday, January 30. Parents are encouraged to speak with their daughters' teachers at Parent Conference night on Tuesday, January 31, 5-7 p.m. • Both of BCPSS' proposed options for high school facilities call for Western remaining at its current site, http://westernhighschool.org/news/newsarch/newsarch06.html 9/21/2006 News,Arcl}ive, 2005-2006 Page 2 of 2 for renovating its building, and for allowing an increase in enrollment to 1,000. • BCPSS invites final public input into Facilities Plannino (school closings, etc.) at meeting on December 7. • Western among top schools in state on the English 2 portion of the Maryland School Assessment! • Class of 2007 celebrated at Junior Day assembly. • 3 Western seniors sign national letters of intent, earn full college athletic scholarships. • Varsity Soccer team wins District IX (City) Championship! • Western Doves win city volleyball championship! Doves also capture J.V. Volleyball City Championship. • Western holds Open House for prospective students and their parents/guardians on October 16 (3-5 p.m.) and November 13 (6-8 p.m.). • BCPSS is planning to rebuild and update its entire facility inventory (school buildings), which could have major implications for Western. Please attend the community dialogues. • Western's SAT scores rise in 2005. • The Maryland Report Card provides detailed information on Western's performance last year. The scores of most Maryland schools, as well as the state average, declined somewhat from the previous year. Some of Western's scores dipped also, but Western showed dramatic improvement in Geometry. • Western welcomes new staff members Susanna Gray-Rice (Guidance), Lee Griffin (Guidance), Sam Mathews (Mathematics), Janice Nelson (Health), John Shock (English), and Jim Sweigert (Russian). • Fond farewells to departing Western staff Sergei Brazhnikov (Russian), Nancy Flanagan (English), Barbara Golaski (Guidance), Margaret Harmon (Latin), Karen Hodges (Social Studies), Joanne Parker (English), and Celestine Scott (Mathematics), each of whom accepted a position elsewhere within BCPSS. • Welcome to the Class of 2009! Orientation for 9th-grade students begins at 9:00 a.m. on August 26. . School opens for all students on August 29th. • Sign up for our 2nd annual Eva Scott Scholarship Golf Tournament on Saturday, September, 17, 2005! http://westernhighschool.org/news/newsarch/newsarch06.htm1 9/21/2006 ~ b r W;;~' f`-',-~ -- .Y __ '~ ~ ... __ '~ OCT p ~~~ZQQ6 LOUISE (SIGNOR) FLEMING IN THE COURT OF COMMON PLEAS ~----~ OF CUMBERLAND COUNTY, PLANTIFF PENNSYLVANIA V. RANDY SIGNOR O1-5352 CIVIL TERM DEFENDANT ORDER OF COURT AND NOW, this ~ ~ x day of ~c.hd.ir 2006, the petition to Proceed in forma pauperis J~filing a petition for modification of child custody has been; ~~ ~+N T~ ~ By the Court, ~~ Louise (Signor) Fleming, Pro se 2312 Pennyroyal Terrace Baltimore, MD 21209 ~o '"~'~ B. Bayley, J. Randy E. Signor 455 Thundergust Mill Road. Wellsville, Pa 17365 r + " - i ~s = , ,.4, Y. ~ t , i ~o~y --- ~~~~ C.o~~~ 1. ~lP,n~iin~' vs. . Defendant ~~d4 v ~~~Or ~~ vssyl u~~ c 4. APPLICATT(7N IFOR LEAVE TO PROCEED IN FORMA PAUPERTS I, IOLc.iSL S~i1Gc. `7~/~~~auetomyfinancial conditXOn , am unable to pay the cost of this action, wherefore, I request I be permitted to fete in Forma k'auperis, ~~h;~~~'e~;~~ (ss~o~~ d~~~ Date ~.~ 1. I am the (plaintiff) (defendant) in the above matter and because of my financial condition atn unable to pay the fees and costs of prosecuting or defending the action or proceeding, 2. I am unable to obtain funds from anyone, including my family and associates, to pay the casts of litigation, 3. I represent that the information below relating to my ability to pay the fees and costs is lsue and corzect; j ~ nar~ (a) Name: L6Le,~SC~ V~f~D~1%4~ "f' ~~D~/E~ ~~,% Address: ac3!°'Z 2 ~5czlf,'~-iooe - m c o2/a~ i Social Security Number: J ~ ~ "Sa - ~a3 (h) p',mployment If you are presently employed, state Employer: Address; Salary or wages per montt,~ Type of work;, t.[ D If you aze presently t Date of last employment: _ Salary or wage per month: _ Type of work: (c) Other income within the past twelve months Business or profession: ~~ /'i~ ~_ ~~~, QtUersetf-employment; Interest: Dividends: Pension and benefits: Ek} ~ o"l~~'. Social security benefits: ~ p Support payments: ~~/'O~~ /h4d71~1 {Disability payments: ~f '~~ ~ (X~ '~i/ ~bdl .S ~OL/~<~ ~ ~~d ~~ ~ ~~35 .~ ~l sops ~~~~~ ~5P~e e ~ ~1~~~~ ~ ~~° ~'G ~,v /Jew fires ~~, ~~~ s ~~ ~.~~ .:.. ~~~, ., 6 w Tlnemployment compensation and supplementat benefits: Workman's compensation: Public assistance: Other; (d) Otizer contributions to honsehold ('IyJ'ife) (I~nsband) Name; If your (wife) (husband} is e Employer: Salary or wades pet month: Type o£ work: Contributions from children: Contributions from parents; Other contributions: (e) Property owned 'Checking account: Savings account: Certificates of deposit; Real estate (including home): Motor vehicle: Make Cost Stocks: bonds: Other: Year Amount owed (f) Debts and Obligations Mortgage: Rent: l~ ,~ S /JQS~~~ ~in~.s,~~`a l reeds /hey -~o ~~ee~0 J/~s~1 ~r~ `~cS ~"~ yam-" ` ~ ~ ~ U• It , W e ~o'~ ~ ~Sa ~/o v~ d ~ ~5 n e ecrS ~~ ~nCu,da- a-r~ d 7~ lei ~~- ~ iS -~%~'~i e cs Cv ~/~, ~5't.~c(~ ~,~ ~j~~~~, v~ e S, Clod %~~~ ~fc , ~- ~ ~-F- rno ~ ~ ~~~ ~~ . ~vbC'A#~aklta3.3..k .."«~ ,. ~ - -~_ .:.!;; _.~teutle .n'a?vl/M1'LaRM'.Y' Ya2.ttkt5.'=X.~ andd v. 4a... • - .a••"~~ ~. ~~~ wv~~~~ ~~,viorr~ ~,~-~ ~ his iS ~ V~~ ~~~~'.~ ~vu-l / S~cern _e.U~U~ ~.cf-Ke~ ~!y ~n~~ .~- t~~(Ce, ~~ ~e5 ;~ I~+ e, n e.~~5 d-~ `'f~ ~- C~j~ 6 ~~o~ L~S~i i~ 7~ ~~ ~2Ce_ ~~~(e „Q~(h.~GL rz-~~ ~~~ ~i'~'id~'Ttid~~ ~ ~ Q,/r~ -~ Q,~ d ,~rrir~G / )~rM ~°- ~c._ ~'j~,~-~ `~~ ~'o `~ ~D~d~ LcJ~C.~~ d~ y y~ ~, ~~~`~~d GJ/~ ~ 1 ~ Gc.~S~ 7~'~ ~, ~ ~~ ~ , `~~~~~~ vz,rrS J •~ R . t, (g) Persons dependent upon you for support (Wife) (Husband) Name; Children, if anv: Other persons: Name: Relatio ,~. Date: ~NbI b ~ . Name: ~,~i C, 1-~JhGt/,~~2- /~~ Age r'TUVLG t1 ~CL/ ;!-1'fMiiX ~b~ ~~ ,~ ~'Ct ~ ~a , c` `flees-i a~1y Patitioner ~ ~~~ i hav. Proth. - 71 LOUISE (SIGNOR) FLEMING IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY. PENNSYLVANIA V. RANDY SIGNOR DEFENDANT 01-5352 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Frida_ ,October 13, 2006 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. ,the conciliator, at MDJ Maalove,1901 State St., Camp Hill, PA 17011 on Wednesday, November 15, 2006 at 8:30 AM for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Melissa P. Greevy, Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~~ N ~~ ~ ~~~ ~~~ ~~~-~ ~,i;i,;, ; I,t;~.,~~a ~~ f liQ4~L''vV:'I.~!: :7CI -ry +i"iJ. it .~O'l/. cat ~o•L/-o/ ~L!- o/ r OCT Q 8,2A96 T. ,~~-, Person Filing Motion: Name: Louise Sophia Fleming_ Si or) Daytime Telephone No. 410-6 4G 5432 Mailing Address: 2312 Pennyroyal Terrace. Baltimore Maryland 21209 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, FOR THE STATE OF PENNYSYLVANIA CASE NO. 01-5352 Civil Term MOTION TO CHANGE CUSTODY, SUPPORT OR VISITATION 1. PARENT INFORMATION Father: Full name:Randy S. Signor Date of Birth: 5/1/61 Mailing address:455 Thundergust Mill Road, Wellsville, Pennvslvania 17365 Residence address (if different): Daytime phone number: Most recent employer: Not Employed Dates of employment: Employers address: Mother: Full name:Louise Sophia Flemine Date of Birth:10/18/64 Mailing address: Residence address (if different): Daytime phone number: Most recent employerMary Engler Racing_Stables Dates of employmentAueust 22 2006 Employer's address:Pimilico Race Track. Baltimore. Maryland :~~ 'Custodian (other than Darenfl: Full name: Date of Birth: Mailing address: Residence address (if different): Daytime Phone number: 2. CHILDREN ]List the names of all children covered by your most recent court order. Child's Name Date of Birth Who is Child Living With? Tyler Signor 12/29/96 Randy Signor Amanda Amaker 12/15/89 Randy Signor Eric Amaker 05(12/88 A. Nikki Fleming Holly Signor 08/05/88 Unknown -runaway [Attach extra pages for any additional children.] is the custody and visitation arrangement for each child the same as ordered by the court in its most recent order? Yes No X_ If your answer is `ho" for any child, explain in detail how the child's current custody and visitation arrangement is different from what the court ordered. [Attach extra pages if necessary.] Eric Amaker removed himself from Randv's care in 2003 because of the continued violent confrontations between his stepfather and himself. He moved in with my sister and her son at 2312 Pennyroyal Terrace Baltimore, Maryland 21209. There he was enrolled by my sister in Cardinal Gibbons, a private Catholic boys school, from which he graduated in 2006. He is currently enrolled in his freshman year at West Virginia University. Holly Signor after spending the entire summer without seeing her father. ran away from home because of his drug use and fear of his violent reaction to her pregnancX While Amanda Amaker and Tyler Signor remain in Randy's legal custody, they spend much of their time at his sister, Janice Signor's residence in Highspire, Pa. because there is often no adult supervision in the home and no food for the children.ln reality, although Amanda is supposed to be at Janice's she actually is spending unsupervised time at her teenage friend's residence nearby _ 5~- .u~um- ..i ...... ... ........ ... &it 3. CHANGE IN CUSTODY OR VISITATION NOTE: A change uI custody will not be granted unless there has been a substanfial change in circumstances since the last order was entered. Also, the requested change must be in the best interests of the children. See page 3 of the Instructions about "best interests." Do you want the custody or visitation order changed? (Check all that apply.) X Custody X Visitation _ No change in custody or visitation Explain in detail what changes you want the court to order and why. [Attach extra pages if necessary.] I am urging the Court to grant my request for an immediate hearing to assess the living situation of my minor children. I wish the Court to heaz from them the horror of their currently living situation under the custody of Randy Signor. Randy has reroeatedl +~gone against .the Court's order for custodv and visitation and continues to do so The children are anxious to sneak to the Court on their own behalf and will give the Court afirst-hand account of how the situation has changed since the Court issued the original order. Sroecifically: Amanda at age 16 is in immediate danger and in a vulnerable position because of the company Randy habitually keens, their questionable character, and their anti-social behavior. Amanda can attest to the fact that she is often in the company of adult males who either have active warrants, aze on roazole or probation, or who have spent time in jail for maior offenses. Randy is not roviding a supervisory role because he is razely there -most ni lg_Its he does not come home until 3 or 4 a.m., disturbing her sleep with in appropriate and irrational rantings and ravings. Randy has also allowed known prostitutes to live at the farm unfil my sister found out and insisted that theme removed from the roremises because of the negative impact on the children. Tyler's educational progress has also been hindered by this environment. In addition to the obvious social implications, his educational progress has been impacted by lack of parental involvement. Tamer exhibits behavior that is indicative of ADHD and is unable to perform educationally at the increasingly discouraged to the point that he will stop trying and will be doomed to a life of underachievement or criminal behavior. These brief examples of changes in the custodial situation since the Court's oripJnal order are the basis for my reauest for a change in that order. The custodial pazent has not met the Courts order to provide for the needs of the children. The children have been emotionally and ph sy icall~neglected. Mr. Signor has been unable to rorovide for the basic needs of the children, often relying on my family for monetary support in addition to the free living~uarters he has been supplied with since 2003. Had it not been for my sister, the children would not have had food, would not have had clothing, the electricity would have been fumed off many times, the phone bill would have og ne unpaid, and there would not have been any means of transportation. I ask that the Court Grant me custodv of the minor children and to modify the child support order as is appropriate (due to would be detrimental and traumatic to sever the fies between father and son but because of the dangers inherent in the irrational behavior of substance abusers, I feel suroervision is necessary. I also request that the Court not order visitation between Amanda and Randy Because of his past physical and emofional abuse Amanda has expressed the desire to "never see him again". She is anxious to express her wishes directly to the Court and I suspect that there may be more abuse than she is ready to acknowledge ~~ Notice to Parties: If there is a change in custody or visitation, the court is required to consider whether the child support order must also be changed. Travel Expenses. Travel expenses necessary to exercise visitation should be allocated between the parties as follows: 4. CHANGE IN CHILD SUPPORT NOTE: Tn order to obtain an increase or decrease in support payments because of a change in income of the person making the payments, the change in income must be both long term and significant. The court will not modify a support order because of a minor or temporary increase or decrease in income. The general guideline for determining whether a change in income is significant is if the change is enough to raise or lower the support payments by 15% or more: You must attach any documentation you have that supports your request. Examples include pay stubs, tax returns, and proof of social security or disability benefits. Do you want the Support payments for the above children to be: increased decreased no change in support payments Check all of the following boxes that explain why you are requesting an increase or decrease. [Attach extra pages if necessary.] a. The income of the person making the child support payments has increased or decreased. (If you check this box, attach documentation of the increase or decrease and explain why it has occurred.) b. Support payments should be changed because there has been a change in where the children are living. (If you check this box, list the dates when the living arrangements changed, explain what the current living arrangements are, and attach any documents you have to support your claim.) c. Support payments should be changed because there has been a change in the availability or cost of medical insurance for the children or because medical expenses for the children have increased or decreased. (If you check this box, attach all available documents that support the requested change.) d. Other (Be speck and attach any supporting documents.) Income Withholding. If your current support order in this case does not require immediate income withholding but CSSD is enforcing the order, the court will be required to order immediate income withholding in its modification order unless one of the three exceptions authorized by Alaska Statute 25.27.062(m) applies. For an explanation of those exceptions, see form DR-10, pages 13- 14 (available at the court). Is CSSD currently enforcing your support order Yes No If yes, is there a reason why the court should not order immediate income withholding? 5. REQtnxEn ATTACHMENTS. Each of the items listed below MUST be attached to this motion. Check each box to indicate that you have completed and attached the item. A copy of your most recent child support order Child Custody Jurisdiction Affidavit (form DR-150) Child Support Guidelines Affidavit (form DR-305) Shared Custody Child Support Calculation (form DR-306) (required only if shared custody has been ordered or is being requested) or form DR-307 (for divided custody) or form DR-308 (for hybrid custody). All documentation needed to support your request for a change in custody, visitation or support. OATH OR AFFIRMATION NOTE: You must sign this in front of a notary. A court clerk can provide this notary service for you at no charge. Bring a photo ID with you for the notarization. I swear or affirm that the above statements and any attachments are true to the best of my knowledge and belief. Date Signature of Person Filing Motion Printed Name Subscribed and sworn to or affirmed before me at ,Alaska on . Date Clerk of Court, Notary Public or other person authorized to administer oaths. (SEAL) My commission expires: [You must complete the Certificate of Service on the next page. CERTIFICATE OF SERVICE [MUST BE COMPLETED] I certify that I served a copy of this motion and all the documents checked in paragraph 5 as shown below: On Other Parent (Instructions: You must also send a Response Packet to the other parent.) I mailed (first class mail) hand delivered to the other parent a copy of (1) this motion and all documents checked in paragraph 5 and (2) a Response Packet. Name of Other Parent: Address: Date mailed or delivered: On Other Parent's Attorney (Instructions: If the other parent was represented by an attorney within the last year, you must send the attorney a copy of this motion and all the documents checked in paragraph 5.) I mailed (first class mail) hand delivered to the attorney a copy of this motion and all the documents checked in paragraph 5. Name of Other Party's Attorney: Address: Date mailed or delivered: On the Child Support Services Division (Instructions: If the Child Support Services Division (CSSD) is enforcing this order, you must send a copy of this motion and all the documents checked in paragraph 5 to the Attorney General's Office.) I mailed (first class mail) hand delivered a copy of this motion and all the documents checked in paragraph 5 to: Attorney General's Office Collections and Support Section 1031 West Fourth Avenue, Suite 200 Anchorage, AK 99501 Date mailed or delivered: Signature of Person Filing Motion .~~h~$1+}4 .1 n _v_M-an+ rtY:.iAis 45niS#y*-k1 mi 41?+~}„6451 a{'Y}'$1+i~'7°uzfLtll~~#~S ~ ~ ~ ~~x~~Y~ '°2~ c~ c ~= ~; ~ ~ '~ `' : Q ---1 ry~i r.,- C°7 f31~ - C.fl ~_~ ~ - -D -~~ t-. ' - } l G - ::-n ~ ,. ~ - ~~ ~._~ .t o~~