HomeMy WebLinkAbout01-06923
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JOEL NICOLE BRYAN,
Plaintiff
: In The Court of Common Pleas of
: CUMBERLAND County,
v.
: Pennsylvania
: Civil Action - Law
KEITH DAVID JOHNSON,
Defendant
: No. 01-6923
.
.
: Protection From Abuse and
: Custody
FINAL ORDER OF COURT
Defendant's Name is: KEITH DAVID JOHNSON
Defendant's Date of Birth is: August 9, 1966
N ame( s) of All protected persons, including Plaintiff and minor children:
1. JOEL NICOLE BRYAN
AND NOW, thiA~~Day of December, 2001 the court having jurisdiction over the parties and
the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows:
Plaintiff, Joel Nicole Bryan, is represented by Joan Carey of MidPenn Legal Services; Defendant,
Keith David Johnson, is unrepresented, but has been advised of his right to representation in this
matter.
Defendant, although agreeing to the terms of this 'brder, does not admit to the allegations made in
the Petition.
Plaintiffs request for a final protection order is granted..
1. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any other protected person in
any place where they might be found.
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2. Except as provided in Paragraph 4 ofthis Order, Defendant is prohibited from having ANY
CONTACT with the Plaintiff, or any other person protected under this Order, at any location,
including but not limited to any contact at Plaintiff's school, business, or place of employement.
Defendant is specifically ordered to stay away from the following locations for the duration of
this order.
Plaintiff's current residence or any other residence she may establish during the term of
this Order:
68 East Main Street
Newville, PA
Defendant's contact with Plaintiff of a non-harassing nature by telephone and/or in
person during transfer of custody of the parties' minor child at Plaintit1f's residence or
any other location, shall not be deemed a violation ofthe CONTACT provisions in the
above paragraph (2) and/or paragraph 3 ofthis Order. Defendant's communication with
Plaintiff shall be limited to information regarding the parties' minor child.
3. Except as provided in Paragraph 4 of this Order, Defendant shall not contact the Plaintiff, or
any other person protected under this Order, by telephone or by any other means, including
through third persons.
4. Custody of the following minor children:
1. JARROD SCOTT JOHNSON
shall be as follows:
. Primary physical custody of the minor child/ren is awarded to the
Plaintiff.
. Defendant shall have periods of partial custody with the parties' minor
child as set out in the attached Custody Order.
Defendant's contact with Plaintiff of a non-harassing nature by
telephone and/or in person during transfer of custody of the parties'
minor child at Plaintiff's residence or any other location, shall not be
deemed a violation ofthe CONTACT provisions (paragraphs 2 and 3) of
this Order. Defendant's communication with Plaintiff shall be limited to
information regarding the parties' minor child.
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5. The following additional relief is granted as authorized by g6108 of the Act:
Defendant is prohibited from having any contact with Plaintiff's relathres, except as may
be necessary with respect to communicating information regarding theiparties' minor
child.
Defendant is ordered to refrain from harassing Plaintiff's relatives.
Defendant is enjoined from damaging or destroying any property ownlld solely by
Plaintiff.
The court costs and fees are waived.
6. A certified copy of this Order shall be provided to the police department where Plaintiff resides
and any other agency specified hereafter:
NEWVILLE POLICE DEPARTMENT
7. THIS ORDER SUPERSEDES:
1. ANY PRIOR PF A ORDER
2. ANY PRIOR ORDER RELATING TO CHILD CUSTODY
8. All provisions of this order shall expire on: June 17, 2003
NOTICE TO THE DEFENDANT
VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF
INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A FINE OF UP TO $1,000
AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S. g6114. VIOLATION
MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENAL TIES UNDER
THE PENNSYL VANIA CRIMES CODE.
THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF
COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE COMMONWEALTH OF
PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACT, 18 U.S.C. g2265. IF
YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS
ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER
THAT ACT. 18 U.S.C gg2261-2262. IF THE BRADY INDICATOR PARAGRAPH APPEARS
IN THE ORDER, YOU MAYBE SUBJECT TO FEDERAL PROSECUTION AND
PENALTIES UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACT, 18
D.S.C. g922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR
AMMUNITION.
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NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over the plaintiff's residence OR any location where a violation
of this order occurs OR where the defendant may be located, shall enforce this order. An arrest for
violation of Paragraphs 1 through 4 of this order may be without warrant, based soley on probable
cause, whether or not the violation is committed in the presence of the police. 23 Pa.C.S. ~6113.
Subsequent to arrest, the police officer shall seize all weapons used or threatened to be used
during the violation of the protection order or during prior incidents of abuse. The shall maintain
possession of the weapons until further order of this Court.
When the defendant is placed under arrest for violation of this order, the defendant shall be taken
to the appropriate authority or authorities before whom defendant is to be arraigned. A
"Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police
officer OR the plaintiff. Plaintiff's presence and signature are not required to file the complaint.
If sufficient grounds for violation of this order are alleged, the defendant shall be arraigned, bond
set and both parties given notice of the date of the hearing.
. s Order is entered pursuant to the consent of Plain
t Judge
J6an Carey, Attorne or Plaintiff
MidPenn Legal Services ~
8 Irvine Row ~ ~ I.;/.I'r.ol
Carlisle, P A 17013
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JOEL NICOLE BRYAN,
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYL VANIA
vs.
: NO. 01- 6923 CIVIL TERM
KEITH DAVID JOHNSON,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
CUSTODY ORDER
AND NOW, this Iff?' day of December, 2001, the following Order is entered by consent of
the parties with regard to custody of the parties' child, Jarrod Scott Johnson, D.O.B.: 3/21/01.
1. Plaintiff, hereinafter referred to as the mother, and Defendant, hereinafter referred to
as the father, shall share legal custody of the child.
2. The mother shall have primary physical custody of the child.
3. The father shall have partial custody of the child on alternating weekends from Friday
at 4:00 p.m. until Sunday at 6:00 p.m., two weekday periods (days to be agreed by the parties) from
4:00 p.m. until 7:00 p.m., and on other days and at times mutually agreed by the parties.
4. The parties shall share the Thanksgiving Day holiday with the mother having the
child until 3:00 p.m. and the father having the child from 3:00 p.m. until 8:00 p.m. (or through
Friday at 6:00 p.m. ifhe does not work the day after Thanksgiving, and through Sunday at 6:00 p.m.
if it is his scheduled weekend with the child
5. The father and mother shall alternate the Christmas holiday with one parent having
the child on Christmas Eve from noon until Christmas Day at noon, and the other parent having the
child from noon on Christmas Day until December 26th at noon. The mother shall commence the
schedule having the child on Christmas Eve in 2001, and in odd years thereafter, and the father shall
have the children in the even years.
6. The mother shall have the child on Mother's Day from 9:00 a.m. and keep him for the
remainder ofthe day, and the father shall have the child on Father's Day from 9:00 a.m. until 6:00
. p.m.
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7. The father shall have the right to partial custody of the child for 1 week of vacation
each year. The father shall give the mother two weeks notice as to when his period of custody will
take place. The mother shall have the right to have the child on weekends during that time unless
the father takes the child on a vacation trip including weekends. The mother also has the right to
take the child on a vacation including a maximum of 2 weekends. The vacationing parent shall
provide the other parent with a complete address and telephone nurnber where the child will be
during the vacation period.
8. The mother and father, by mutual agreement, may vary from this schedule at any
time, but this Custody Order extends beyond the expiration of the above-captioned Final Order of
Court and remains in effect pending further Order of Court regarding custody.
9. The mother and father agree that each shall notify the other immediately of medical
emergency which may arise while the child is in that parent's care.
10. Neither party shall do anything which may estrange the child from the other parent, or
injure the opinion of the child as to the other parent or which may hamper the free and natural
development of the child's love or respect for the other parent.
an Carey, Attorne or Plaintiff
MidPennLegalServces ~ ~ j,J.../loO/
8 Irvine Row
Carlisle, PA 17013
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OFFICE OF WE PROI'HCHJtARY
CUMBERLAND COONTY COUR'mOOSE
ONE cnJRTHOOSE OOUARE
CARLISLE. PA. 17013-3387
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(717) 240-6195
FAX (717) 240-6573
VIA !ELECOPIER
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PA STATE POLICE . Ct"t. flltllu.u.
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FAX #:
717-249-0779
RKM: CURTIS R. LONG
RE: PYA ORDERS
MESSAGE :
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ttrJtain infi:llm3l:itn ttet is p:ivi)f;grl. o:nfidEntial a:rl ~ fron rli....'O"'lre ~ "{PU",*"" larJ. If
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tti$trib.1tio:l cr ~ d. this OO'I1l\ni.ca".Jm is strictly IWtihited. If}Q.I te\e :rEmiwd ltus
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RECEIVED AUG 22 2005)1"
JOEL NICOLE BRYAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
CIVIL ACTION - LAW
KEITH DAVID JOHNSON,
Defendant
NO. 01-6923 CIVIL TERM
IN CUSTODY
COURT ORDER
AND NOW, this Z'-\. day of August, 2005, upon consideration of the attached
Custody Conciliation Report, it is ordered and directed as follows:
1. A hearing is scheduled in Court Room No. 2 of the Cumberland County
Courthouse on Thursday, August 25, 2005 at 3:00 p.m. At this hearing, the
Father shall be the moving party and shall proceed initially with testimony. In
addition to other issues to be addressed at the hearing, the following issues will be
addressed:
A. Mother's unwillinguess to advise the Father where she resides so Father could
pick up the child for exchange of visitation.
B. Mother's unwillingness to advise the Father of where the child is attending day
care.
C. Mother's apparent unwillingness to abide by the existing Order to ensure that
Father has his alternating weekend custody times and other times as pursuant
to the existing Order.
2. Mother is directed to bring the minor child to the hearing. Furthermore, the
parties should be prepared to address at this hearing the potential of the Court
transferring cnstody of the minor child to the Father in the event Mother is held in
contempt and the Court determines that a change of custody is reqnired. Mother
shall bring a third party to the Courthouse to take care of the minor child outside
of the Court Room during the proceedings.
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BY T~O
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LR'uby D. Weeks, Esqnire
....,Jessica Diamondstone, Esquire
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JOEL NICOLE BRYAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
CIVIL ACTION - LAW
KEITH DAVID JOHNSON,
Defendant
NO. 01-6923 CIVIL TERM
IN CUSTODY
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVllL RULE OF
PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following
report:
I. The pertinent information pertaining to the child who is the subject of this litigation
is as follows:
Jarrod Scott Johnson, born March 21, 2001
2. A Conciliation Conference was held on August 18, 2005 with the following individuals
in attendance:
The Mother, Joel Nicole Bryan, with her counsel, Jessica Diamondstone, Esquire
The Father, Keith David Johnson, with his counsel, Ruby D. Weeks, Esquire
3. There is an existing Order of Court from 2001 which was entered! pursuant to a
Consent Agreement that provides Mother with primary cnstody llItld Father with
times of temporary cnstody to include alternating weekends, a few evenings per
week, holidays, etc. Father rded a petition in May of this year seeking to modify the
Order and to find the Mother in contempt becanse of the Mother's IilDwillingness or
inability to abide by the Order. The parties had an initial Conciliation on May 26, at
which time an agreement was reached for the Mother to abide by the Order with
provisions that exchange of custody would take place at a WalMart. Since that time,
Father has shown up at the scheduled times for exchange of custody and Mother has '
not attended on a number of occasions. Mother has not given Father a phone
nnrnber he can reach her. Mother has not provided Father with an address where he
can come and pick up the child. Mother asserts some vague allegations of prior
misconduct of the Father with respect to a protection from abuse matter as a basis
for these concerns. Father indicates that there was never a permanent protection
from abuse order entered against him and that the matter was dismissed. He denies
any abuse toward the Mother and suggests that there is no reason why exchange of
cnstody cannot take place at the Mother's home.
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4. Despite the Conciliator's suggestion that Father be able to see the child! by picking the
child up at the Mother's home (it is also noted that the Mother does not have a car
and is unable to provide transportation herself and must rely on family friends),
Mother refused at the Conciliation to provide an address for her home in order to
facilitate Father seeing the child. Mother also refused to provide the location of the
day care center where the child is enrolled in day care. It is noted Father is paying
support through the Domestic Relations Office, and it is assnrned that a portion of
that support reflects day care expenses.
5. The Court must conduct an immediate hearing to address these issues, and the Court
should consider the possibility of transferring custody of the minor child to the
Father in light of the Mother's blatant obstructionist behavior and violation of the
existing Order.
6. The Conciliator recommends an Order in the form as attached.
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JOEL NICOLE BRYAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
vs.
: CUMBERLAND COUNTY, PENNSYLVANIA
; NO. 01- <0923
CIVIL TERM
KEITH p,qll',1\JOHNSON,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
NOTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may
pmceed against you and a FINAL Order may be entered against you granting the relief requested in the
Petition. In particular, you may be evicted from your residence and lose other important rights.
A heariD,g on this matter is scheduled on the /7 r;ta'y of December, 2001, at / ~ 30 ~m., in
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Courtroom NO......L.- on the 4 Floor ofthe Cumberland County Courthouse, 1 Courthouse Square,
Carlisle, Pennsylvania.
You MUST obey the Order that is attached until it is modified or terminated by the court after notice
and hearing. If you disobey this Order, the police may arrest you. Violation oftms Order may subject you
to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six
months in jail under 23 Pa.C.S. g6114. Violation may also subject you to prosecution and criminal penalties
trllder the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. g2265, this Order is enforceable
anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you
travel outside of the state and intentionally violate this Order, you may be subject to federal criminal
proceedings under the Violence Against Women Act, 18 U.S.C. g 2261-2262.
You should take this paper to your lawyer at once. You have the right to have a lawyer represent
you at the hearing. The court will not, however, appoint a lawyer for you. If you do not have a lawyer or
cannot afford one, go to or telephone the office set forth below to find out where you can get legal help. If
you cannot find a lawyer, you may have to proceed without one.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue, Carlisle, Pennsylvania 17013
Telephone Number: (717)249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our
office. All arrangements must be made at least 72 hours prior to any hearing or business before the court.
You must attend the scheduled conference or hearing.
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JOEL NICOLE BRYAN,
Plaintiff
: In The Court of Common Pleas of
: CUMBERLAND County,
v.
: Pennsylvania
: Civil Action - Law
KEITH DAVID JOHNSON,
Defendant
.
: No. 01- (.,'1203
: Protection From Abuse and
: Custody
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is: KEITH DAVID JOHNSON
Defendant's Date of Birth is: August 9,1966
Name(s) of All protected persons, including Plaintiff and minor children:
1. JOEL NICOLE BRYAN
AND NOW, on 7th Day of December, 2001 upon consideration of the attached
Petition for Protection from Abuse, the court hereby enters the following Temporary
Order:
Plaintiffs request for a temporary protection order is granted.
1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in
any place where they might be found.
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2. Except for such contact with the minor childlren as may be permitted under
paragraph 4 of this Order, Defendant is prohibited from having ANY CONTACT
with Plaintiff, or any other person protected under this Order, at any location,
including but not limited to any contact at Plaintiff's school, business, or place of
employment. Defendant is specifically ordered to stay away from the following
locations for the duration of this order.
Plaintiff's current residence or any other residence she may establish during
the term of this Order:
68 East Main Street
Newville, PA
Defendant's contact with Plaintiff of a non-harassing nature by telephone
and/or in person during transfer of custody of the parties' minor child at
Plaintiff's residence or any other location, shall not be deemed a violation of
the above CONTACT provision and the provisions in paragraph 30fthis
Order. Defendant's communication with Plaintiff shall be limited to
information regarding the parties' minor child.
3. Except for such contact with the minor childlren as may be permitted under
paragraph 4 of this Order, Defendant shall not contact Plaintiff, or any other
person protected under this Order, by telephone or by any other means, including
through third persons.
4. Pending the outcome of the final hearing in this matter, Plaintiff is awarded
temporary custody of the following minor child1ren:
1. JARROD SCOTT JOHNSON
Until the final hearing, all contact between Defendant and the childlren shall be
limited to the following:
Pending the hearing scheduled in this matter, Defendant shall have periods
of partial custody with the parties' minor child, JARROD SCOTT
JOHNSON, on dates and at times mutually agreed by the parties.
Defendant's contact with Plaintiff of a non-harassing nature by telephone
and/or in person during transfer of custody of the parties' minor child at
Plaintiff's residence or any other location, shall not be deemed a violation of
the contact provisions (paragraphs 2 and 3) ofthis Order. Defendant's
communication with Plaintiff shall be limited to information regarllling the
parties' minor child.
The 10callaw enforcement agency in the jurisdiction where the child1ren are
located shall ensure that the childlren are placed in the care and control ofthe
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Plaintiff in accordance with the terms of this Order.
5. The following additional relief is granted:
Defendant is prohibited from having any contact with Plaintiffs relatives,
except as the court may find necessary with respect to partial custody with
the minor child.
Defendant is ordered to refrain from harassing Plaintiffs relatives.
Defendant is enjoined from damaging or destroying any property owned
solely by Plaintiff.
6. A certified copy ofthis Order shall be provided to the police department where
Plaintiff resides and any other agency specified hereafter:
NEWVILLE POLICE DEPARTMENT
7. The sheriff, police or other law enforcement agencies are directed to serve the
Defendant with a copy of the Petition, any Order issued, and the Order for
Hearing without prepayment of costs. The Petitioner will inform the designated
authority of any addresses, other than the Defendant's residence, where Defendant
can be served. The Prothonotary is directed to file this Petition and Order without
prepayment of costs.
8. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL JUNE 7, 2003 OR UNTIL OTHERWISE
MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND
HEARING.
NOTICE TO THE DEFENDANT
Defendant is hereby notified that violation of this Order may result in arrest for
indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or
up to six months in jail. 23 Pa.C.S. g6114. Consent of the Plaintiff to Defendant's
return to the residence shall not invalidate this Order, which can only be changed or
modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S.
g6113. Defendant is further notified that violation of this Order may subject him/her
to state charges and penalties under the Pennsylvania Crimes Code and to federal
charges and penalties under the Violence Against Women Act, 18 U.S.c. gg2261-
2262.
NOTICE TO LAW ENFORCEMENT OFFICIALS
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This Order shall be enforced by the police who have jurisdiction over the plaintiff's
residence OR any location where a violation of this order occurs OR where the
defendant may be located. If defendant violates Paragraphs 1 through 4 of this
Order, defendant shall be arrested on the charge ofIndirect Criminal Contempt. An
arrest for violation of this Order may be made without warrant, based solely on
probable cause, whether or not the violation is committed in the presence oflaw
enforcement.
Subsequent to an arrest, the law enforcement officer shall seize all weapons used or
threatened to be used during the violation of this Order OR during prior incidents of
abuse. Weapons must forthwith be delivered to the Sheriff's office of the county
which issued this Order, which office shall maintain possession ofthe weapons until
further Order of this court, unless the weapon/s are evidence of a crime, in which
case, they shall remain with the law enforcement agency whose officer made the
arrest.
Judge
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Distribution to:
Joan Carey, Attorney for Plainyff 1;)-7-6 ( J
MidPennLegalServices - cci,es ~C5oNall" G\lV/2.N ie ~ @ ,Mi:JI-<
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PF AD Number: V A1383446M
JOEL NICOLE BRYAN,
Plaintiff
: In The Court of CommQn Pleas of
: CUMBERLAND Countly,
v.
: Pennsylvania
: Civil Action - Law
KEITH DAVID JOHNSON,
Defendant
: No. 01-
.
: Protection From Abuse and
: Custody
PETITION FOR PROTECTION FROM ABUSE
1. Plaintiff's name is:
JOEL NICOLE BRYAN
2. I, (the Plaintiff), am filing this Petition on behalf of:
- myself
3. Name(s) of ALL person(s), including minor children, who seek protection from abuse.
a. JOEL NICOLE BRYAN
4. Plaintiff's Address is : c/o Sharon Bryan, 68 East Main Street, Newville, P A 17241
5. Defendant's Name is:
KEITH DAVID JOHNSON
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6. Defendant is believed to live at the following address:
4 Fairfield Street, Apt. 1 , Newville, PA 17241
7. Defendant's Date of Birth is:
August 9, 1966
8. Defendant's Place of employment is:
Allen Distribution, 600 Allen Road, Bldg. #5, Carlisle, P A. Telephone: (717) 258-
3040. Shift: 5:00 a.m.-3:30 p.m.
9. Defendant is an adult.
10. The relationship between the Plaintiff and the Defendant is:
Parents ofthe same children
Current or former sexual/intimate partner
11. The Plaintiff and the Defendant been involved in the following court actions:
a. Custody
12. Other details of the court action are:
JOHNSON v. BRYAN, Cumberland County, Pennsylvania, No. 01-5378, Civil,
Custody. No custody order was entered. The parties reconciled prior to the custody
conciliation conference scheduled for October 29, 2001, with Conciliator Melissa
Greevy, Esq. The conference was cancelled at the request of Matthew J. Eshelman,
Attorney for Plaintiff, and on October 25, 2001, Ms. Greevy relinqnisll.ed
jurisdiction of the case.
13. The defendant has been involved in a criminal court action.
14. Plaintiff and Defendant are the parents of the following minor child/ren:
a. JARROD SCOTT JOHNSON
Age: 8 months.
Child's address is: c/o Sharon Bryan, 68 East Main Street, Newville, P A 17241
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15. Plaintiff is seeking an Order of child custody as part of this petition.
The following is a list of the children and where they have live for the past 5 years:
a. JARROD SCOTT JOHNSON
For the past 5 years, this child has lived with:
Plaintiff, and her step-mother, Sharon Bryan, at 68 East Main Street, Newville,
P A, from December 5, 2001, to the present.
Defendant, at 4 Fairfield Street, Apt. 1, Newville, P A, from December 3, 2001,
to December 5, 2001.
Plaintiff and Defendant, at 4 Fairfield Street, Apt. 1, Newville, P A, from early
November 2001, to December 3, 2001.
Plaintiff, her .cousin, Heather Reagan, her husband, Bill Reagan, and their
children Harley Reagan and Juel Reagan, at 224 B Street, Carlisle, P A, from
October 2, 2001, to early November 2001.
Defendant, at 4 Fairfield Street, Apt. 1, Newville, PA, from September 2, 2001,
to October 2, 2001.
Plaintiff and the Reagan Family, at 224 B Street, Carlisle, P A, from the child's
date of birth on March 21, 2001, to September 2, 2001.
16. The facts of the most recent incident of abuse are as follows:
On about Monday, December 03, 2001
location: 4 Fairfield Street, Apt. 1, Newville, PA.
Defendant argued with Plaintiff when she tried to leave with the parties' 8-month-old baby,
grabbed her wrist and restrained her, grabbed the baby out of her arms, and flung the child into
the crib. Defendant shoved Plaintiff down onto the couch, grabbed her by the neck with both his
hands, pushed her down to tb.e floor, choked her, and threatened that he would kill her with his
bare hands if he had to. Plaintiff got away from Defendant and left the residence to avoid
further abuse. Plaintiff reported the incident to the Newville Police, who issued a citation to
Defendant for harassment. Plaintiff sustained scratches on her neck and arm, and bruising and
soreness about her arm as a result of this incident.
17. The police department( s) or law enforcement agencies that should be provided with a copy of the
protection order are:
NEWVILLE POLICE DEPARTMENT
18. There is an immediate and present danger of further abuse from the Defendant.
19. The Defendant owes a duty of support to Plaintiff and/or minor child/ren.
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20. FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER A
TEMPORARY ORDER, and AFTER HEARING, A FINAL ORDER THAT WOULD DO THE
FOLLOWING:
a. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/or
minor child/ren in any place where Plaintiff may be found.
b. Award Plaintifftemporary custody of the minor child/ren and place the following
restrictions on contact between Defendant and child/ren:
Pending the hearing scheduled in this matter, Defendant shall have periods of
partial custody with the parties' minor child, JARROD SCOTT JOHNSON,
on dates and at times mutually agreed by the parties.
Defendant's contact with Plaintiff of a non-harassing nature by telephone
and/or in person during transfer of custody of the parties' minor child at
Plaintiff's residence or any other location, shall not be deemed a violation of
the CONTACT provisions in paragraphs 2 and 3 of the attached Temporary
Protection From Abuse Order. Defendant's communication with Plaintiff shall
be limited to information regarding the parties' minor child.
c. Prohibit Defendant from having any contact with Plaintiff and/or minor child/ren,
either in person, by telephone, or in writing, personally or through third persons,
including but not limited to any contact at Plaintiff's school, business, or place of
employment, except as the court may find necessary with respect to partial custody
and/or visitation with the minor child/ren.
d. Prohibit Defendant from having any contact with Plaintiff's relatives and Plaintiff's
children listed in this petition, except as the court may find necessary with respect
to partial custody and/or visitation with the minor child/ren.
e. Order Defendant to pay temporary support to Plaintiff and/or the minor child/ren,
including medical support .
f. Order Defendant to pay the costs ofthis action, including filing and service fees.
g. Order the following additional relief, not listed above:
Order Defendant to refrain from harassing Plaintiff's relatives.
Enjoin Defendant from damaging or destroying any property owned solely by
Plaintiff.
h. Grant such other relief as the court deems appropriate.
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1. Order the police or other law enforcement agency to serve the Defendant with a
copy of this Petition, any Order issued, and the Order for Hearing. The petitioner
will inform the designated authority of any addresses, other than the Defendant's
residence, where Defendant can be served.
Respectfully Submitted by: /l,--< _, (22 " - /
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Agency: MidPenn Legal Services
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400 or
1-800-822-5288
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VERIFICA nON
I verify that I am the Petitioner as designated in the present action and that the facts and
statements contained in the above Petition are true and correct to the best of my knowledge. I
understand that any false statements are made subject to the penalties ofl8 Pa.C.S.~4904, relating to
unsworn falsification to authorities.
Dated: I? / DS.j 01
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12/07/01 FRI 15:11 FAX 717 240 6573
CliMB CO PROTHONOTARY
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OFFICE OF 'IHS PROIllCNOTARY
CUMBERJ:J\ND a::.uNTY COURTHClJSE
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ONE c::cmm-fOOS E SQUARE:
CARLISLE. PA. 17013-3387
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(717) 240-6195
FAX (717) 240-6573
VIA TELECOPIER
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Pl< STATE POLICE - Cellf. f'dfJc.t.S~.. ,.." (J. t...S.
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FAX g;
717-249-0779
~: CURTIS R. LONG
RE: PFA ORDERS
MESSAGE :
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N:>. OF PAGES (INCLUDING COVER SHEET)
This n -:J:' is itltel.W ally fir lte \&!) of lte irdi.v:iO..el cr: 6'lti.1:1/ to Irkrldl is is <111. I, <nl mJf
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JOEL NICOLE BRYAN
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
01-6923 CIVIL ACTION LAW
KJoITH DAVID JOHNSON
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW, Wednesday, May 11, 2005 ,upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hnbert X. Gilroy, E.q. , the conciliator,
at 4th Floor, Cnmberland Connty Conrthonse, Carlisle on Thnrsday, May 26, 2005 at 9:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older mav 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 alI existing Protection from Abnse orders,
Speci311 Relief orders. and Custody orders to the conciliator 48 bours prior to schednled hearing.
FOR THE COURT.
By: /s/
Hubert X Gilrov, Esq.
Custody Conciliator
y
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. AlI 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. IFYOUDONOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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JOEL NICOLE BRYAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY
: PENNSYLVANIA
CIVIL ACTION - CUSTODY
vs.
KEITH DAVID JOHNSON,
Defendant
: NO. 01-6923 CIVIL
ORDER OF COURT
AND NOW, this
day of
,2005, in consideration of the
within Petition, a Rule is issued upon Joel Nicole Bryan, to show cause, if any she
has, why she should not be adjudged in contempt ofthe Order of December 18,
2001, and primary physical custody of the child placed with Keith David Johnson.
Said Rule is returnable and to be heard in Court Room No. , 4th Floor,
Cumberland County Court House on , the day of
2005, at o'clock, .M.
If you fail to appear as provided by this Order or to bring the child, an
Order for custody, partial custody or visitation may be entered against you or the
Court may issue a warrant for your arrest.
Service to be made by certified mail upon Respondent.
BY THE COURT,
J.
CC Ruby D. Weeks, Esquire for Defendant-Petitioner
Joel Nicole Bryan, Plaintiff-Respondent
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JOEL NICOLE BRYAN,
Plaintiff
: IN THE COURT OF COMMON
: PLEAS OF CUMBERLAND
:COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - CUSTODY
KEITH DAVID JOHNSON,
Defendant
: NO. 01-6923 CIVIL
PETITION TO MODIFY CUSTODY AND FOR A FINDING OF
CONTEMPT AGAINST PLAINTIFF
AND NOW comes Keith David Johnson, by his attorney, Ruby D. Weeks,
Esquire, and petitions the Court as follows:
1. Petitioner is Keith David Johnson, the father, who resides at 4 Fairfield
Street, #1, Newville, Pa.
2. Respondent is Joel Nicole Bryan, the mother, who resides at Apartment
6, Building 3526, September Drive, Camp Hill, Pa.
3. The parties, who were never married, are the natural parents of Jarrod
Scott Johnson, born March 21,2001, the subject of this Petition.
4. The parties were before this Court on December 18, 2001, at which
time the mother was granted primary physical custody and the father periods of
partial custody, with shared legal custody.
5. Following entry of the December 18,2001, order, the mother and the child
lived with the father for three years; two days after Christmas 2004, the mother left,
taking the child.
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6. Since Easter weekend 2005, the mother has refused to abide by the
Court Order and has refused contact with the father or to allow him his periods of
partial custody with the child.
7. The mother resides with her step-mother, Sharon Bryan and her adult
daughter, in a two bedroom apartment, and the father believes that the step-mother
is also responsible for his inability to see or have his child.
8. Additionally, the father does not know whether or not the mother is
currently employed, or whether or not she is receiving the mental health treatment
and medication.
WHEREFORE, Petitioner respectfully requests your Honorable Court to
issue a Rule upon Joel Nicole Bryan to show cause, if any she has, why she
should not be adjudged in Contempt of the prior Order and further prays
the Court to transfer primary physical custody to Petitioner, with the same periods
of partial custody to be with Respondent.
Respectfully submitted,
~~.
Date: May 5, 2005
Ruby D. Weeks, Esquire
Attorney for Petitioner-Father
cc Keith David Johnson, Petitioner-Father
Joel Nicole Bryan, Respondent-Mother
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COMMONWEALTH OF PENNSYLVANIA
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COUNTY OF CUMBERLAND
Personally appeared before me, a Notary Public in and for the
Commonwealth and County aforesaid, the under-signed, being duly sworn
according to law, deposes and says that the facts set forth in the
foregoing Petition are true and correct.
Sworn to and subscribed to
before me this ~d day
of cmay ,2005.
Common of Pen nla
NOTARIAL SEAL
SIIlIlI.EY p, C\.E\IENGER. NolaIy Public
C8dIsIe Boro. CUmbe/l8I1d CourtlY
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Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
JOEL NICOLE BRYAN,
vs.
: NO. 01- 6923 CIVIL TERM
KEITH DAVID JOHNSON,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
CUSTODY ORDER
. AND NOW, thisi3' ffy day of December, 2001, the following Order is entered by consent of
the parties with regard to custody of the parties'child, Jarrod Scott Johnson, D.O.B.: 3/21/01.
1. Plaintiff, hereinafterreferred to as the mother, and Defendant, hereinafter referred to
as the father, shall share legal custodyof the child.
2. The mother shall have primary physical custody of the child.
3. The father shall have partial custody of the child on alternating weekends from Friday
at 4:00 p.in. until Sundafat' 6:00 p.m.,two weekday perioas (days to be agreed by the parties) from
4:00 p.m. until 7:00 p.m., and on other days and at times mutually agreed by the parties.
4. The parties shall share the Thanksgiving Day holiday with the rnother having the
child until 3:00 p.m. and the father having the child from 3:00 p.m. until 8:00 p.m. (or through
Friday at 6:00 p.m. ifhe does not work the day after Thanksgiving, and through Sunday at 6:00 p.m.
if it is his scheduled weekend with the child
5. The father and mother shall alternate the Christmas holiday with one parent having
the child on Christmas Eve from noon until Christmas Day at noon, and the othe:r parent having the
child from noon on Christmas Day until December 26th at noon. The mother shall commence the
schedule having the child on Christmas Eve in 200 1, and in odd years thereafter, and the father shall
have the children in the even years.
6. The mother shall have the child on Mother's Day from 9:00 a.m. and keep him for the
remainder of the day, and the father shall have the child on Father's Day from 9:00 a.m. until 6:00
p.m.
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7. The father shall have the right to partial custody of the child for 1 week of vacation
each year, The father shall give the mother two weeks notice as to when his period of custody will
take place. The mother shall have the right to have the child on weekends during that time unless
the father takes the child on a vacation trip including weekends. The mother also has the right to
take the child on a vacationjncluding a maximum of 2 weekends. The vacationing parent shall
provide the other parent with a complete address and telephone number where ,the child will be
during the vacation period.
8. The mother and father, by rnutual agreement, may vary from this schedule at any
time, but this Custody Order extends beyond the expiration of the above-captioned Final Order of
Court and remains in effect pending further Order of Court regarding custody.
.
9. The mother and father agree that each shall notify the other inunediately of medical
emergency which may arise while the child is in that parent's care.
10. Neither party shall do anything which may estrange the child from 1ne other parent, or
injure the opinion of the child as to the other parent or which may hamper the free and natural
~ ,"!,~ ",'"
development of the child's love or respect for the other parent.
By the Court,
JQ.an Carey, Attorne or Plaintiff
MidPenn Legal Scrv ces
8 Irvine Row
Carlisle, P A 17013
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-06923 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BRYAN JOEL NICOLE
VS
JOHNSON KEITH DAVID
RICHARD SMITH
, Sheriff Dr Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within PROTECTION FROM ABUSE
was served upon
JOHNSON KEITH DAVID
the
DEFENDANT
, at 0820:00 HOURS, on the 11th day of December, 2001
at ALLEN DISTRIBUTION #5
600 ALLEN ROAD
CARLISLE, PA 17013
by handing to
KEITH D. JOHNSON
a true and attested copy of PROTECTION FROM ABUSE
t0gether with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
3.25
.00
10.00
.00
31. 25
r~~~~.e
R. Thomas Kline
12/12/2001
LEGAL SERVICES
Sworn and Subscribed to before
By:
-"
me this
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f3
day of
Sheriff
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MEDICAL ARTS ALLERGY, PC
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PATIENT: >6I rod ~. :t,!.. '^ ~nn- .. - DATEOF-BI~T~:i :J../r,/ /0/
.. ." ~ p.R/C~ I PUNCTURE , ' D 'NiRADERMAL :
TESTING 'OA.TE: i"~' . . DATE: i
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A 2. BEECH, AMERICAN .' J A 35. DUST MITE - D.p. (3D ClOO BAUIml) ?-/5 '1"
A 3. BIRCH, MIX I A36. CAT paT -AP (10,0( BAUlmI) &4 ...;
15;..r'
A4. BOXElDER I MAPLE . J 11.37. DOGDANDER(1:10~ v) a//l -r
A 5. ELM, AMERICAN I . A 38. COCKROACH MIX (1~. Ow/v) . CJ~.....
A.6. HACKBERRY IDlio I - CONTROLS I "-
P,7. HICKORY '\ 6Z I A 39. DILUENT (~con! 01) A 0,1;, I J
A 8. MUlBERRY TREE A4(l. HISTAMINE(1mqmtI- . , '/,/'JJ.C: r / I
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A9. OAK. MIX . . . J I ONALAERO" ._~ ~ENS (1:211 ""~,
A 10. POPULAR I COTTONWOOD I OA41. TREE MIX #11 I
A 11. SYCAMORE I o A 42. CEDAR. RED ,\
o' I o A 43. PINE . I
A 12. WAlNUT TREE , . .
t13.W1LLOw,BLACK '.' . . . -,- I O.A44. SWEETGUMTREIE I
GRASSES (100,000 BAU/mt) \ o A45. RED TOP GRASS (100,000 BAU) ,
I A 14. GRASSMlX#7 (Nodhem p/ains grass) l( I/) ! D A46. ,RYE GRASS (100, boo BAlJ') I. !
~"~(,.,.. . I o A47. WEED MIX#2630 ,
A 16. TIMOTHY r [] M8. MARSHElDER I P )veRTY MIX . I
. ' .. WEEDS (1:2I1w1v) '.. . . o A 49. MOLDMIX#11 I
A 17. COCKLEBUR, COMMON 10.. ~ I D ASO. FEATHER MIX ' I
A'18; DOCK I SORREL MIX I o A51.GUINEAPIG ; I
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A '19. LAMBS QUARTER I D As2. HAMSTER HAIR I
A 20. MUGWORT I OA 53.. HORSE HAIR ~ I
A 21~ PIGWEED. R,ED ROOT . I DAM. PARAKEET I
A.t2. PLANTAIN, ENGUSH I o A 55. RABBIT . ,
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A2.4. ALTERNARIA TENIUS ~ A I I: 37. CClWSMILK, WHI LE I
A25. ASPERGiLLUS FUMIGATUS'. I . F.38. EGG, WHOLE I
A 26. FUSARIUM VASINFECTUM ';;, 1 F 5: PEANUT, MIX 1
. A Z7. HORMODENDRUM CLADOSPORIUM 0;, I .~. F 9. SOYBEAN, WHOLE ,
A2!l. HELMITHOSPORIUM I 'X F 10. WHEAT, WHOLE ( rear) I'
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MAA--F:ULL.PANELSKlN TESTlNG-4f2004.
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04/08/2005
00:51
PinnacleHealth Hospita~s
James A. Piper, M.D., Medical Director
Harrisburg, PA
Pt. Name:
Pt. Phone:
Age/Sex:
Hosp. No.:
Account #:
JOHNSON,JARROD
7173950923
4Y M
800466423
250242286
Lac.: FREDRICKSEN CENTER
Dr Joan Montello
220 Wilson Street, Med Arts Bl
Carlisle, PA 17013
T33461 COLL: 04/04/2005 UNK
Ordering Physician
REC: 04/05/2005 08:14 Dr. MONTELLO,JOAN
RAST NORTHEAST REGION
SEE NOTE
(NOTE)
\
!Allergen Name
1 CONVl % ofl MOD 1
!' kU/L lCLASS! Ref. !CLASS! NOTE# !
!Dermatophagoides farinae (d2) .! <0.35! O! 36! O!
!Cat dander (el) . ! <0.35! O! 44! O!
!Dog dander (e5) .! <0.351 01 43l 01
!Timothy grass (g6) . <0.35! O! 37! 01
1 House dust Greer (hI) <0.3-5 ! O! 37! O!
! Penic-illium notatum (ml) . <0.35! 01 411 O!
!Cladosporium herbarum (m2) . <0.35! O! 401 01
!Aspergillus fumigatus (m3) . <0.35! O! 47! O!
J !Alternaria tenuis (m6) . <0.351 O! 511 01
!Common silver birch (t3) . <0.35! O! 39! O!
!Oak (t7) . .1 <0.351 O! 461 O!
!Walnut (tlO) . . ! <0.35! O! 41! O!
!Maple leaf sycamore (tU) .! <0.35! 01 451 Ot
! Japanese cedar (tl7) . .! '<0.35! O! 37! O!
1 Pecan, Hickory (t22) . .1 <0.35! O! 47! O!
!Mulberry (t70) . . ! <0.351 O! 37! O!
!Common ragweed (short) (wI) .1 <0.35! O! 42 ! O!
lCommon mugwort (w6) .. <C.351 01 38! 01
lEnglish plantain (w9) . ! <0.35! 01 46! O!~
!Common pigweed (w14) . .! <0.351 O! 631 O/~(U
!Sheep sorrel (w18) . .1 <0.35! 01 46!
----------------------------------------------------------------------
Note 1
Common pigweed highly cross-reacts with Careless
weed
Note 2
Sheep sorrell highly cross-reacts with Yellow Dock
Immunocap allergen results may be expressed in
either kU/L or as a percentage response of the
patient specimen compared to the 0.35 kU/L
calibrator (ASM: Alternate Scoring Method-Modified
allergens) .
SPECIFIC
IgE
CLASS
j(~
kU/L
% RESPONSE
LEVEL OF ALLERGEN
SPECIFIC IgE
ANTIBODY
1-/5'" i'
~
c;~
JOHNSON,JARROD
CONTINUED
PAGE
1
~ ~ '//;310:>
0/11 .If ~ lJ",. JJL
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04/08/2005
00:51
PinnacleHealth HospitaLs
James A. Piper, M.D., Medical Director
Harrisburg, PA
Pt. Name:
Pt. Phone:
Age/Sex:
Hosp. No.:
Account #:
JOHNSON,JARROD
7173950923
4Y M
800466423
250242286
Loc.: FREDRICKSEN CENTER
Dr Joan Montello
220 Wilson Street, Med Arts Bl
Carlisle, PA 17013
T33461 COLL: 04/04/2005 UNK
Ordering Physician
REC: 04/05/2005 08:14 Dr. MONTELLO,JOAN
RAST NORTHEAST REGION (CONTINUED)
o <0.35 < OR = 70 ABSENT/UNDETECTABLE
~ 0.35 - 0.70 7~ - ~~O LOW LEVEL
2 0.71 - 3.50 ~~~ - 220 MODERATE LEVEL
3 3.5~ - 17.5 221 - 600 HIGH LEVEL
4 17.6 - 50 60~ -2000 VERY HIGH LEVEL
5 51 -~OO 2001 -6000 VERY HIGH LEVEL
6 >100 >6000 VERY HIGH LEVEL
See notes for designation of allergen tests using
one or more analyte specific reagents. In those
cases, the test was developed and its performance
characteristics determined by Quest Diagnostics.
It has not b~~n cl~ar~d or approved by the U.S.
Food and Drug Administration. The FDA has det~rmined
that such clearance is not necessary.
{AM} = Test performed by Nichols Institute Quest Diagnostics
JOHNSON,JARROD
END OF REPORT
PAGE
2
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r
MEDICAL ARTS ALLERGY, P.C.
Joan M. Montello, M.D. . Donald S. Harper, M.D.
Jack L. Armstrong, M.D. . Jodi L. Johnson, eRN.p.
AMERICAN BOARD OF ALLERGY, ASTHMA AND CLINICAL IMMUNOLOGY
MEDICAL ARl'S BUILDING
220 WILSON STREET. SUITE 213
CARLISLE. PA. 17013-3657
Phone: (717) 243-7540
Fax: (717) 243-9968
FREDRICKSEN OUTPATIENT CE.NTER
2025 TECHNOLOGY PIW'IY., SUITE 310
MECHANICSBURG, PA 17050
Phone: (717) 791-2640
Fax: (717) 791-2646
BLOOM OUTPATIENT BUILDING
4310 LONDONDERRY ROAD, SUITE 109
HARRISBURG. PA 17109
Phone: (717)920.4340
Fax: (717) 920-4341
RE: Jarrod Johnson
BD: 3-21-01
Visit: 8-10-05
I had the pleasure of seeing Jarrod for visit 8-10-05. Jarrod continues to have
significant nasal symptoms and nasal obstruction. His. mother and grandmother, who
bring him here today, feel that Nasonex at times does not even penetrate due to the nasal
obstruction. Of note: He does not appear to have frequent respiratory tract infections
such as otitis, sinusitis or bronchial infections.
CURRENT MEDICATIONS
1. Nasonex is used only pm.
2. Tylenol Allergy prn.
The child did have RAST test done to some common allergens such as dust mites,
cat, dog, grass, molds, tree pollens, ragweed. All of which were negative.
PHYSICAL EXAMINATION
Temp: 100.20 Pulse: 92 and regular Resp: 20 and regular
16.5kg.
HEENT:
HT: 102.0cm. WT:
E: Conjunctivae are pink. The lids are normal.
E: Tympanic membranes are clear and mobile. External auditory.
canals are normal.
N: Nasal turbinates are pale with clear mucoid discharge. There is
SOme crusting about the turbinates.
T: Oropharynx is normal including: teeth, gum, palate, tongue.
There is no exudate of the posterior pharynx.
NECK: Neck is supple, there is no thyromegaly or cervical lymphadenopathy.
LUNGS: Lungs are clear to auscultation, there are no retractions.
CARDIAC: Cardiac exam is normal without murmurs or extra sounds.
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Page 2
Jarrod Johnson
August 10, 2005
IMPRESSION
1. Chronic non allergic rhinitis.
2. Negative allergy skin tests/Negative puncture skin tests.
RECOMMENDATIONS
1. I did recommend that the family use nasal saline irrigation and a handout was
given to them which gives them a "recipe" describing iodized salt, baking soda and
distilled water to be administered by either bulb syringe or bottle.
2. I also asked Jarrod to see Dr. Abram to be sure we are not dealing with
obstruction from large adenoids or other anatomical problems that might be helped. The
mother seems most agreeable with this plan. I have asked to see Jarrod after he has an
ENT consult.
Joan M. Montello, M.D.
JMM/ambM
c: Denise Barr, M.D., Good Hope Family Practice, 1830 Good Hope Road, Enola, PA 17025
':;;>ii,""~';;0~" ~~ _,~__f,"", __? _.
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MEDICAL ARTS ALLERGY, P.C.
Joan M. Montello, M.D. . Donald S. Harper, M.D.
Jack L. Armstrong, M.D. . Jodi L. Johnson, C.R.N.P.
AMERICAN BOARO OF AlLERGY, ASTHMA AND CLINICAL IMMUNOLOGY
MEDICAL ARTS BUILDING
220 WILSON STREET, SUITE 213
CARLISLE. PA 17013.3657
Phone: (717) 243-7540
Fax: (717) 243-9968
FREDRICKSEN OUTPATIENT CENTER
2025 TECHNOLOGY PKWY., SUITE 310
MECHANICSBURG. PA 17050
Phone: (717) 791~2640
Fax: (717) 791-2646
BLOOM OUTPATIENT BUILDING
4310 LONDONDERRY ROAD. SUITE 109
HARRISBURG. PA 171 09
Phone: (717) 920-4340
Fax: (717) 920-4341
RE: Jarrod Johnson
BD: 3-21-01
Visit: 3-16-05
1 had the pleasure of seeing Jarrod for visit 3-16-05. We were not able to do
intradermal testing today as the child resisted this procedure so we declined continuing
with testing.
His mother and grandmother, who bring him in today, feel that Nasonex has
definitely helped his symptoms and he does have better nasal breathing.
PHYSICAL EXAMINATION
Temp: 98.90 Pulse: 120 and regular
16.2kg.
HEENT:
Resp: 24 and regular HT: :t00.5cm. WT:
E: Conjunctivae are pink. The lids are normal.
E: Tympanic membranes appear clear and mobile. External
auditory canals are normal.
N: Nasal turbinates are pink without mucoid discharge.
T: Oropharynx is normal including: teeth, gum, palate, tongue.
There is no exudate of the posterior pharynx.
NECK: Neck is supple, there is no thyromegaly or cervical lymphadenopathy.
LUNGS: Lungs are clear to auscultation, there are no retractions.
CARDIAC: Cardiac exam is normal without murmurs or extra sounds.
IMPRESSION
1. Chronic rhinitis.
RECOMMENDATIONS
1. Because I was unable to do intradermal tests to really determine if there is an
allergic component to his symptoms I did ask Jarrod to get a RAST test to Northeastern
pollens as well as dust mites and ~nim~l danders. The results of the RAST tests are
pending at the time of this dictation.
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Page 2
Jarrod Johnson
March 16, 2005
2. Both his mother and grandmother seem most pleased with the use of Nason ex
and I asked them to continue this at one spray per nostril daily until I see Jarrod again
which would be in two months. The family was invited to call sooner if there is any
change or worsening of symptoms.
Joan M. Montello, M.D.
JMM/ambM
c: Denise Harr, M.D., Good Hope Family Practice, 1830 Good Hope Road, Enola, P A 17025
,;;-,,~';j
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MEDICAL ARTS ALLERGY, P.C.
Joan M. Montello, M.D. . Donald S. Harper, M.D.
Jack L. Armstrong, M.D. . Jodi L. Johnson, eRN.p.
AMERICAN BOARD OF ALLERGY, ASTHMA AND CLINICAL IMMUNOLOGY
MEDICAL ARTS BUILDING
220 WILSON STREET, SUITE 213
CARliSLE. PA 17013-3657
Phone: (717) 243-i540
Fax: (717) 243-9968
FREDRICKSEN OUTPATIENT CENTER
2025 TECHNOLOGY PKWY., SUITE 310
MECHANICSBURG. PA 17050
Phone: (717) 791-2640
Fax: (717) 791-2646
BLOOM OUTPATIENT BUILDING
4310 LONDONDERRY ROAD, SUITE 109
HARRISBURG. PA 17109
Phone: (717) 92Q.<\340
Fax: (717) 9204341
RE: Jarrod Johnson
BD: 3-21-01
Visit: 2-23-05
I had the pleasure of seeing Jarrod Johnson at the request of Dr. Denise Harr. He
is a 3 11/12tb year old child who is "always stuffY" and "sounds like he has a cold".
The mother and grandmother, who accompany Jarrod today, states that he has
been like this most of his life. In early infancy he had frequent episodes of otitis, but
never required PE tubes. Currently he seems to have frequent respiratory tract infections
during the winter months. Fortunately, he does not seem to require frequent courses of
antibiotics. He is here today primarily because of nasal congestion. The mother states he
does have noisy breathing if not snoring at bedtime.
The family does not notice a seasonal pattern that may be significant for
pollenosis.
The child has no history of recurring infections such as sinusitis or bronchial
infections. The ear infections were primarily in the first year oflife.
The child denies a history of allergies to medications such as Penicillin, Sulfa.
There are no known food allergies, bee sting allergy, latex or other contactants such as
metals, etc.
CURRENT MEDICATIONS
1. Zyrtec 1 teaspoon once a day prn nasal congestion.
NEWBORN mSTORY
The child was the product of a full term normal pregnancy, labor and delivery.
Birth weight 6 pounds 7 ounces. The infant did have some hypoglycemia in the neonatal
period, but other than that everything was normal. The first year of life he did have
recurring otitis.
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Page 2
Jarrod Jolmson
February 23, 2005
: I
'i i
REVIEW OF OTHER MEDICAL PROBLEMS
Essentially unremarkable.
PAST MEDICAL mSTORY
Non contributory for hospitalizations or surgeries.
FAMILY mSTORY
A maternal grandfather has allergies but no other relatives are !mown to have
allergies or asthma.
ENVIRONMENTAL mSTORY
A complete environmental history was reviewed with the patient's family.
PHYSICAL EXAMINATION
HR: 90 and regular Resp: 20 and regular
100.5cm.
HEENT:
Temp: 98.80 WT: 16.2kg. HT:
E: Conjunctivae are pink. The lids are normal.
E: Tympanic membranes appear clear and mobile. External
auditory canals are normal.
N: Nasal turbioates are swollen without mucoid discharge.
T: Oropharynx is normal including: teeth, gum, palate, tongue.
There is no exudate of the posterior pharynx.
NECK: Neck is supple, there is no thyromegaly or cervical lymphadenopathy.
LUNGS: Lungs are clear to auscultation, there are no retractions.
CARDIAC: Cardiac exam is normal without murmurs or extra sounds.
ABD: Abdomen is soft without hepatosplenomegaly. There are no abdominal
masses. There is no lymphadenopathy.
EXT: There is no digital clubbing, cyanosis or infection.
SKIN: The skin is clear of rashes and lesions.
PROCEDURES
The child was skin tested by the puncture technique to inhalants, animal danders,
mixed grasses, weeds (including ragweed), tree pollens, molds and foods. He had mildly
positive test to dust mites, but they did not match the histamine control as well as
fusarinm, mucor and penicillium and one tree hackberry.
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Page 3
JllITod Johnson
February 23, 2005
IMPRESSION
1. Perennial nasal congestion.
2. Mildly positive skin tests dust mites/mold (Did not match histamine control).
RECOMMENDATIONS
I started Jarrod on Nasonex 1 spray per nostril daily and our nurses instructed the
family on the proper use of the intranasal steroid spray. I would like him to stay on this
until I see him again and at that time do further intradermal tests. The family seems most
agreeable with further testing and they were invited to call at any time should there be
any further problems.
Joan M. Montello, M.D.
JMM/ambM
c: Denise Harr, M.D., Good Hope Family Practice, 1830 Good Hope Road, Enola, P A 17025
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-----
Dale. sf 21!ns
KinderCare
Dear Dr. _~ '1 r
Your patient J CcrrD d j 0~ ::')<Z>() is applying for enrollment for childcare
services at KinderCare learning Centers, Inc. We ask for your cooperation in helping us to ensure that KinderCare is
able to provide the best possible environment for this child. Your medical opinion is critical In deciding whether to enroll
this child. We do not promise enrollment to every child.
KinderCare is not a medicallrealment facUity, medical services are not provided, and the teachers are not medically
trained. KinderCare does not provi?e one-on-onecare. .
KinderCare is a'group care.facility. We provide meals and snacks, rest times, outdoor play times, and follow an
established curriculum. In addition, we provide periodic field hips to nearby parks and places of interest.
In. accordance wit state law, the ratio in this area is I teacher for every (0 children and there will be
a maximum of ' children in this area. The children in this area range in age from ~~cro ,f)-'fUr.S
KinderCare's policy.is to accept children in compliance with the Americans With Disabilities Act (ADA), its implementing
regulations and any other applicable federal, state or local laws that apply to the provision of services to those with
disabili!ies. We review each child's slluation on a case-by-case basis to determine how we can best meet the needs of
each child within the KinderCare setting. " .
Do you believe your patient req,jires any modifications or accommodations In order to be ca~d f rand
participate in.;the activities provided in the KinderCare setting as described above? DYes No If yes,
indicate. beiow what these modifications would be. If necessary, use additional sheets of paper 0 the back of
this fonn.:., .
'""'"
If you have any Huestions or concerns please coniact me at '1'2_ '? - 11 2...0
KinderCare's Disabllity Services Coordinator at 1-800-633-1488, ex!. 1440.
or you may contact
Sincerely.
1--\ (\;";~.~"" ~
Doctor's Signature
-----
IIJu ~LYl ~ ~OqL
~d, r Ph 111)5' .
'11111W11
Doctor's Add ress
KinderCare Center Director
".
Doctor's Phone Number
PLEASE RETURN THIS LETTER TO:
Kindel'C(~ '("arb Ill; Center
730 Wertzvllle Road
Enola, PA 17025
KinderCare does not discriminate on the basis of disability.
KinderCare has appointed a Disability Services Coordinator to
attempt to resolve disab~ity-related issues. You can contact this
person at the address listed below or the tolllree number listed
above.
(CENTER STAMP)
KinderCare learning Centers, inc.
Disability Services Coordinator
650 NE Holladay Slreet, Suite 1400
Portland, OR 97232
1~800-633-1488, ex!. 1440
FPP-HR5-315iiE 12'QJ.
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HERITAGE MEDICAL GROUP
ADULT PATIENT INFORMATION SHEET
PATIENT INFORMATION
Date: . 5119105 10:40 am
Patient Name: Jarrod S Johnson
Date of Birth: 03121/2001
Age: 4 yrs
Mailil1g Address: 3526 September Drive Apartment 6
City/State/Zip: Camp Hill, PA 17011
Phone #: (717) 395-0923 (Home) Phone #: 0
Marital Status: []Married [XlSingle []Divorced []Widowed []Other
SS#: 170-80-1791
Sex: M
Employer:
Address:
Emergency Contact: Sharon Bryan
Telephone #1: (717) 395-0923
Family Physician: Denise F Harr MD
(Work):
Ex!.
Relationship: Grandmother
Telephone #2:
Ex!.
Other:
Referring Physician: Denise F Harr MD
Do you have insurance? 0 Yes 0 No If yes, complete the following Insurance/ Billing Information:
PRIMARY INSURANCE
Group #: 02869100
Insurance Company Name: Blue Shield . #
ID #: ZAR110813318001
Subscriber's DaB: 12/02/1958
Relationship to, Subscriber: Other
Subscriber's SS #: 209-50-9595
Subscriber: Sharon K Bryan
SECONDARY INSURANCE
Insurance Company Name:
ID#:
Group #:
Subscriber:
Relationship to Subscriber:
Subscriber's DaB:
Subscriber's SS #:
GUARANTOR. (Person responsible for co pays and for charges which are NOT covered by insurance)
Guarantor's Name: Sharon K Bryan Guarantor SS #: 209-50-9595
Address (required for accurate billing): 3526 September Drive Apartment 6 Camp Hill, PA 17011
AUTHORIZATION:
.:. I HEREBY AUTHORIZE HMG TO FURNISH INFORMATION TO ANY INSURANCE CARRIERS CONCERNING MY MEDICAL
CONDITION, AND I HEREBY IRREVOCABLY ASSIGN HMG ANY PAYMENT FOR SERVICES RENDERED.
.:. I UNDERSTAND THAT I AM RESPONSIBLE FOR ALL CHARGES WHETHER OR NOT COVERED BY INSURANCE.
.:. I CERTIJ=Y THAT THIS INFORMATION IS ACCURATE AND CURRENT AS OF THIS DATE.
SIGNATURE ~~-Y7
DATE5-}Q-O<)INITIAL sK!3
DATE ,,-to-o<i INITIAL S/<(:]
DATE INITIAL
DATE INITIAL
DATE INITIAL
DATE INITIAL
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DATE
DATE
DATE
DATE
DATE
DATE
DATE
INITIAL
INITIAL
INITIAL
INITIAL
INITIAL
INITIAL
INITIAL
INITIAL
INITIAL
INITIAL
INITIAL
INITIAL
DATE
DATE
DATE
DATE
DATE
DATE
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Cood Ilope
l"C1rnily Phy~icii1llA',
1830 Good Hope Road. Enola . PA . 17025
(717) 732-8877 . FAX (717) 732-9241
MEDICATION LISTING
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LA Left Arm
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RD Right Deltoid
LO Left Deltoid
PEDIATRIC IMMUNIZATION FLOW SHEET
Good Hope
family Physicians
1830 Good Hope Road. Enola . PA . 17025
(717) 732~8877 . FAX (717) 732-9241
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family Physicians
1830 Good Hope Road. Enola. PA. 17025
(717) 732-8877. FAX (717) 732-9241
PAGE NO, &
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Presents today as a new pt for evaluation of ongoing URl symptoms for ab01.1t the last month associated
with soine lumps on both sides of his neck that have been present since appr~ximately September 2004.
Jarrod had been under the care ofDrs on Walnut Bottom Road and the last time he was seen was
September 2004. Apparently there' was some miscommunication between mpm and dad who are in the
procd~ofseparating and then soineother information that was provided by ~ maternal grandmother who
aC,companies them on the visit tonight about how he was supposed to be recJjecked with regard to these
presumed swollen lymph nodes. Either way, mom and grandma Were very c011cerned because they were
noticing these lumps on his neck. He has had congestion and runriy nose foriat I~ast the last month
associated with some intermittent fevers. No complaints of ear pain. Occaslonal cough. Appetite
occasionally decreased but no vomiting or diarrhea. Both parents are smokets. Jarrod has been exposed to
a lot of second-hand smoke. He did have a history of recurring ear infection~ early on his life but this has
been better more recently. He never had tubes. Never had an overnight hosJilital stay or any surgery. No
medication allergies and does not take any routine medications. He was bOr$ about 1 wk early. Had a
NIeD stay at birth because of some type of a respiratory infection and low blood sugar. He did not have
any residual complications after his discharge. According to mom, his immJnizations are up-to-date.
Medical records have been requested but have not yet been transferred to our office. Family history
significant for mom, herself, with allergies.
0: NAD. He is active and well. TMs clear. Nose congested. Purulent discharte noted bilaterally.
Oropharynx with some mild erythema and PND. Neck supple. Has shotty I~ph nodes on both side of his
neck anteriorly and posteriorly. Has a cluster of nodes in the left posterior c~rvical chain and an
approximately 8mm in diameter node in the right posterior cervical area andia couple of scattered nodes in
the left anterior cervical chain. Heart regular. Lungs have clear breath sounUs throughout.
1) Acute sinusitis. 2) Reactive cervical lymphadenopathy.
Amoxicillin suspension 250mg/5m1 1.5 tsp bid x 10 days. Reassured mom apd grandma that these reactive
nodes are exactly that and should resolve as we clear the infection. I would like to recheck him in about 4
weeks to ensure that the lymph nodes are stable and to ensure that his respin.ltory symptoms have resolved.
I did discuss the effects of second-hand smoke on recurring respiratory infeqtion. We may need to entertain
the possibility of allergies also as an underlying etiology given the family history. Will await medical
records to determine when he is next due for his well exam but probably in March 2005 upon his next
birthday. With any problems or worsening of symptoms prior to the next vi~it, they will contact the office.
PUI.
12/30/04
HMGlGHFP FORM #1 (10/97)
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1830 Good Hope Road. Enola . PA. 17025
(717) 732.8877 . FAX (717) 732-9241
PAGE NO.
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He presents today for recheck of his sinus infection and reactive cervical lymphadenopathy. He completed
the Amoxicillin. He is no longer having cloudy discharge from his nose. It is now ~ore Clear. He seems
to always be congested and having a runny nose, blowing his nose a lot Grandma does think that the
reactive lymph nodes that we previously evaluated are much less thenthey had b~lln before. . Jarrod and his
. mom are currently liv.ing with the maternal step-grandmother and Jarrod's 2 maternal. step:aunts.'There is
second-hand smoke exposure. , .'" " ,.
NAD. Appears well: TMs have some chronic changes. No acute disease, Nose' is congested ,with Clear
rhinorrhea. Turbinates are somewhat pale and boggy.. Oropharynx with some mild eiythemllarid PND.
Neck supple. He continues to have some reactive cervical lymphadenopathy especially in the left posterior
cervical chain. Heart regular. Lungs - Clear breath sounds throughout. . .
I) Acute sitlusitis, resolved. 2) Allergic rhinitis.
No further antibiotics are necessary. Zyrtec syrup Y, to 1 tsp po qd. Samples and script provided. Will
check him back in about 4 weeks for re-evaluation but sooner pm. PUr.
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1830 Good Hope Road. Enola . PA. 17025
(717) 732-8877. FAX (717) 732-9241
PAGE NO. .3
NAME.,1qJ J 0 hrtY-TV)
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Presents today for follow-up of allergies. They have been giving him Zyrtec syrup I tsp at HS. He is
definitely doing better with this but mom and grandma still state that he "breaths funny" at times. When I
tried to get a feel for what they were describing, they said sometimes he sounds like he is trying to "get
something out" and I really could not determine ifthis was out of his nose or out Qfhis mouth. He does
tend to snore a fair amount. His cough is definitely better as is his congestion. He does have second-hand
smoke exposure as noted previous.
NAD. Appears well. Nose - significant congested pale appearing turbinates are still noted in the nose.
Oropharynx clear. Tonsils are not hypertrophied. Neck supple. He continues with some shotty lymph
nodes bilaterally. Nothing pronounced, fixed or mobile. Heart regnlar. Lungs clear.
Allergic rhinitis.
Continue Zyrtec syrup. Get him seen by Montello and Armstrong for an evaluation to consider if any
further testing or intervention would be recommended by theJIl especially because we are not even in the
heart of allergy season yet and I have a feeling that things may flare in the spring. Will await that .
evaluation and otherwise schedule in about 6 to 8 weeks for his 4 yr peds check. PUI.
'D~W 02/17/05
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J arrod is here for a pediatric examination. He is here with maternal grandmother. She voiced to me some
concerns about how Jarrod is being cared for by his mother, Joelle, and dad, Keith. They were never
married and are now separated. Joelle lives with her step-mother who is here today with Jarrod.
Apparently Joelle decided not to come.to the appointment today. Maternal grandmother does not feel that.
he is being adequately cared for. She does not feel that his nutritional needs are being met, that Joelle .
frequently does not cook appropriate meals for him and allows him to drink juice all day. She really has
no control over what happens when he visits his dad. He is supposed to see his dad every other weekend
and was seeing him a couple of times throughout the week, but because of some differences in where they
are both living now, that does not happen quite as often. Joelle does have primary custody of Jarrod. I
explained to grandma that Jarrod seemed to be appropriate as far as his height and weight today and he
seems to be developmentally showing no signs of concern. On review of records, it was indicated that he
weighed 36 pounds a year ago, although different scale, different office, I could not really validate that
definitively. I have discussed with grandma about trying to ensure that he is getting regnlar meals, to
encourage a variety offoods being offered and trying to limit juice. Because if he is truly drinking juice
all day he is obviously not going to want to eat a lot of solid foods throughout the day. If grandma had
additional concerns as far as competency of either parent to be caring for the child, then I have
recommended that perhaps she consider consultation with Social Services. Apparently there were some
allegations made in the past when J arrod was very young, so there is a file on this child. There was
nothing that I felt was threatening the welfare of this child based on the alleged information given to me
today, so I did not feel that I could make any additional intervention at this point. I did ask grandma that
if continued concerns on her part was there to request mom accompany Jarrod to a visit that we could
discuss further. PUI. DF b 3/23
HMGlGHFP FORM 111 (10197)
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- g and tOileting?@O)
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ANTICIPATORY GUIDANCE
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0.. the current schedule of the America~ Academy of Pediatrics 141 Northwest Point Blvd., Elk Grove Village. IL 60007. The schedule is
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KinderCore.
21 Ins
.
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patient ,,\o..rro d J C>~ ;')0() is applying for enroliment for childcare
vices at KinderCare learning Centers, Inc. We ask for your cooperallon in helping us 10 ensure that KinderCare is
.,51e 10 provide Ihe best possible environment for this child. Your medical opinion is critical in deciding whether to enroll
this child. We do not promise emolimenl to every child. .
KinderCare is not a medical treatment facility, medical services are not provided, and the teachers are not medicaliy
trained. KinderCare does not provide one-an-one care.
I
KinderCare is a group care.facility. We provide meals and snacks, rest times, outdoor play times, and foliow an
established curriculum. In addition, we provide periodic field trips 10 nearby parks and places of interest.
In accordance w~state law, the ratio in' this area is ~ teacher for every 10 children and there Will, ~e
il maximum of 0 children in this area. The children in this area range in age from ,~~o /5ifur.6
KinderCare's policy is to accept children in compliance with the Americans With Disabilities Act (ADA), its implementing
regulations afld any other applicable federal, state or local laws that apply to the provisiofl of services to those with
disabilities. We review each child's siiuation on a case-by-case basis t6 determifle how we can best meet the needs of
each child within the KinderCare setting. . '
Do you believe your patient requires any modifications or accommodations in order to be ca~d rand
participate in the activities provided in the KinderCare setting as described above? oVes No. If yes,
indicate belbw what these modtlications would be. If necessary, use additional sheets of paper 0 the back of
this fonn. .
If you have any questions or COflcems please contact me at '12_ '? - 11 2..0
KinderCare's Disability Services Coordiflator at 1-800-633-1488, ex!. 1440.
or you may contact
~:",.~,~~, ~
Doctor's Signature
------
KinderCare Center Director
Doctor's Phone Number
IIJv (loci ~~~L
61101. I f~ 11t)5
'l111mW7
Doctor's Address
PLEASE RETURN THIS LETTER TO:
;
Kil1d,~~~Le'ai'i:lil:fg Center
730 Wertzville Ro&d
Enola, ?A 17025
KinderCare does not discriminate on the basis of disability.
KiflderCare has appointed a Disability Services Coordinator to
attempt to resolve disability-related issues. You can contact this
person at the address listed below or the toll free number listed
above.
(CENTER STAMP)
KinderCare Leamiflg eeflters, Inc.
Disability Services Coordiflator
650 NE Holladay Street, Suite 1400
Portland, OR 97232
1-800-633-1488, ext. 1440
PPP.HRS-3166E 12/03
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TELEPHONE 717-243-1294
ATTORNE:Y AT LAW
August 18, 2005
TEN WEST HIGH STREET
CARLISLE. .:ENNS,i~.tNlt ~P2US59S5
Recer'l1:a _______......c"""~
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Good Hope Family Physicians
1830 Good Hope Road
Enola, PA
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Re: Jarrod Scott Johnson
Dear Doctors:
7
I represent Jarrod's father, Keith Johnson, in a cus y matter. Mr. Johnson
has shared legal custody per the enclosed ordC<LoLcu Qdy, Mr. Johnson will be
contacting your office to discuss Jarr9d'-sasthma ~ems-~ith th~ doctor in your
practice who has seen Jarrod and to<O.htaiii:zrropy of his medical records from
your office. Mr. Johnson understands that you may charge him for these copies.
An emergency custody hearing is set for 3:00 p.m., Thursday" August 25,
2005, before The Honorable Judge Edgar Bayley. At the present time it is not
anticipated that your testimony will be necessary. If it becomes so, I will let you
know at the earliest possible moment and will try to work it out so you could
testify by telephone.
Please do not hesitate to call if you have any questions about any ofthis.
Thank you in advance for your help in this matter.
Sincerely,
RubyD. Weeks
RDW:wkh
Enclosure(s) as noted above
cc Jessica DiamQndstone, Esquire, attorney for mother
Keith Johnson, father
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JOEL NICOLE BRYAN,
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 01- 6923 CIVIL TERM
KEITH DAVID JOHNSON,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
CUSTOD'Y ORDER
. AND NOW, thisl\" '!iv day ofDeccmber, 2001, the following Order is entered by consent of
the parties with regard to custody of the parties' child, Jarrod Scott Johnson, D.O.B.: 3/21/01.
1. Plaintiff, hereinafter referred to as the mother, and Defendant, hereinafter referred to
as the father, shall share legal custody of the child.
2. The mother shall have primary physical custody of the child.
3. The father sh~il have partial custody of the child on alternating weekends from Friday
. .
at 4:00 p.m. iii:dilSunday"':at6:00 p.m., two weekday periods (days to be agreed by the parties) from
4:00 p.rn. until 7:00 p.m., and on other days and at times mutually agreed by the parties.
4. The parties shall share the Thanksgiving Day holiday With thle mother having the
child until 3:00 p.m. and the father having the child from 3:00 p.m. until 8:00 p.m. (or through
Friday at 6:00 p.m. ifhe does not work the day after Thanksgiving, and through Sunday at 6:00 p.m.
ifit is his scheduled weekend with the child
5. The father and mother shall alternate the Christmas holiday with one parent having
the child on Christmas Eve from noon until Christmas Day at noon, and the other parent having the
child from noon on Christmas Day until December 26th at noon. The mother shall cornrnence the
schedule having the child on Christmas Eve in 200 1, and in odd years thereafter, and the father shall
have the children in the even years.
6. The mother shall have the child on Mother's Day from 9:00 a.m. and keep him for the
remainder of the day. and the father shall have the child on Father's Day from 9:00 a.m. until 6:00
p.m.
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7. The father shall have the right to partial custody ofthe child for 1 week of vacation
each year. The father shall give the mother two weeks notice as to when his period of custody will
take place. The mother shall have the right to have the child on weekends during that time unless
the father takes the child on a vacation trip including weekends. The mother also bas the right to
take the child on a vacation including a maximum of 2 weekends. The vacationing parent shall
provide the other parent with a complete address and telephone number where .the child will be
during the vacation pedod.
8. The mother and father, by mutual agreement, may vary from this schedule at any
time, but this Custody Order extends beyond the expiration of the above~captio!led Final Order of
Court and remains in effect pending further Order of Court regarding custody .
.
9. The mother and father agree that each shall notifY the other immediately of medical
emergency which may arise while the child is in that parent's care.
. .
, 10. N either party shall do anything which may estrange the child from the other parent, or
injure the opinion of the child as to the other parent or which may hamper the free and natural
~,_1." ~.",'
development of the child's love or respect for the other parent.
By the Court,
;;
Trlls Order is e"tered~JrSuantlO the consent of Plaintiff and
!j
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1Q1!n Carey, Attorne or Plaintiff
MidPenn Legal Serv ces
8 Irvine Row
Carlisle, P A 17013
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In Te.~~~htor;y t.'il~~;~:-f)i:. j h~r::.~ :,'~!~i) ,):~t :ny h~~nj
ai:': th!~ s~',ai 01 ~2~d Cm.~;t .~t C:;:rlh;je: Fa.
This I,[~ 'day ,()t,(~;~ :kaf
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MEDICAL ARTS ALLERGY, P.C.
Joan M. Montello, M.D. . Donald S. Harper, M.D.
Jack L. Armstrong, M.D. . Jodi L. Johnson, C.R.N.P.
AMERICAN BOARD OF ALLERGY. ASTHMA AND CLINICAL IMMUNOLOGY
MEDICAL ARTS BUILDING
220 WILSON STREET. SUITE 213
CARLISLE. PA 17013-3657
Phone: (717) 243-7540
Fax: (717) 243-9968
FREDRICKSEN OUTPATIENT CENTER
2025 TECHNOLOGY PKWY., SUITE 310
MECHANICSBURG. PA 17050
Phone: (717) 791-2540
Fax: (717) 791-2546
BLOOM OUTPATIENT BUILDING
4310 LONOONDERRY ROAD, SUITE 109
HARRISBURG. PA 17109
Phone: (717) 920-4340
Fax: (717) 920-4341
RE: Jarrod Johnson
BD: 3-21-01
Visit: 8-10-05
I had the pleasure of seeing Jarrod for visit 8-10-05. Jarrod continues to have
significant nasal symptoms and nasal obstruction. His mother and grandmother, who
bring him here today, feel that Nasonex attimes does not even penetrate due to the nasal
obstruction. Of note: He does not appear to have frequent respiratory tract infections
such as otitis, sinusitis or bronchial infections. ReOOl'led .' . AlJJ~'
T ~PFOOFJ300 ~ 1 72005
CURRENT MEDICATIONS -- j>T<.y,.,,,j.. C.\FCiRM Bi\TIEr'rr Done___
-'"'~<~ '~ Lc~:t-t';r S0ut
1. Nasonex is used only pm. .
~eT:~::o~i;~:::Y:T test done to some co~mZ~:~sUCh
cat, dog, grass, molds, tree pollens, ragweed. All of which w~n1~ve.
Staff Da
PHYSICAL EXAMINATION
Temp: 100.20 Pulse: 92 and regular Resp:
16.5kg. .
HEENT:
20 and regular HT: 102.0cm. WT:
E: Conjunctivae are pink. The lids are normal.
E: Tympanic membranes are clear and mobile. External auditory
canals are normal.
N: Nasal turbinates are pale with clear mucoid discharge. There is
some crusting about the turbinates.
T: Oropharynx is normal including: teeth, gum, palate, tongue.
There is no exudate of the posterior pharynx.
NECK: Neck is supple, there is no thyromegaly or cervical lymphadenopathy.
LUNGS: Lungs are clear to auscultation, there are no retractions.
CARDIAC: Cardiac exam is normal without murmurs or extra sourlds.
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Jarrod Johnson
AugustlO, 2005
IMPRESSION
1. Chronic non allergic rhinitis.
2. Negative allergy skin tests/Negative puncture skin tests.
RECOMMENDATIONS
1. I did recommend that the family use nasal saline irrigation and a handout was
given to them which gives them a "recipe" describing iodized salt, baking soda and
distilled water to be administered by either bulb syringe or bottle.
2. I also asked Jarrod to see Dr. Abram to be sure we are not dealing with
obstruction from large adenoids or other anatomical problems that might be helped. The
mother seems most agreeable with this plan. I have asked to see Jarrod after. he has an
ENT consult.
Joan M. Montello, M.D.
JMM/ambM
C: Denise Harr, M.D., Good Hope Family Practice, 1830 Good Hope Road, Enola, PA 17025
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RE: Jarrod Johnson
BD: 3-21-01
Visit: 3-16-05
MEDICAL ARTS ALLERGY,. P.C.
~~v~l..0.'~-.:L,F: 0(':'(",'~
Joan M. Montello, M.D. . Donald S. ~~:D. '- - : 'C'.",' .. _
Jack L. Armstrong, M.D. . Jodi L. Joh~:~~&,,~~~ .'
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AMERICAN BOARD OF ALLERGY. ASTHMA AND cLI~.ti~R~;~.%~;~~i'U,4.~~:nat;y Dcofle
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FREDRICKSEN OUTPATIENT CENT~~..P.'';~I.~ B'~QO!il1)UTPATIENT BUILDING
2025 TECHNOLOGY PKWY., SUITE 310 43td"t5'fiIl?J IDERRY ROAD, SUITE 109
MECHANICSBURG. PA 17050 _ '!fill., 11>< HAR BURG. PA 171 09
Phone: (717) 791-2640 - 'Ji:< Ph : 7) 920-4340
Fax: (717) 791-2646 ~. 920-134.tO". .i.......
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MEDICAL ARTS BUILDING
220 WILSON STREET, SUITE 213
CARLISLE. PA 17013-3657
Phone: (717) 243-7640
Fax: (717) 243-9968
I had the pleasure of seeing Jarrod for visit 3-16-05. We were not able to do
intradermal testing today as the child resisted this procedure so we declined continuing
with testing.
His mother and grandmother, who bring him in today, feel that Nasonex has
definitely helped his symptoms and he does have better nasal breathin~.
PHYSICAL EXAMINATION
Temp: 98.90 Pulse: 120 and regular
16.2kg.
HEENT:
Resp: 24 and regular HT: 100.5cm. WT:
E: Conjunctivae are pink. The lids are normal.
E: Tympanic membranes appear clear and mobile.
auditory canals are normal.
External
}O1: 1'1asal turbinates are pink "vithout mucoid discharge.
T: Oropharynx is normal including: teeth, gum, palate, tongue.
There is no exudate of the posterior pharynx.
NECK: Neck is supple, there is no thyromegaly or cervical lymphadenopathy.
LUNGS: Lungs are clear to auscultation, there are no retractions.
CARDIAC: Cardiac exam is normal without murmurs or extra sourlds.
IMPRESSION
1. Chronic rhinitis.
RECOMMENDATIONS'
1. Because I was unable to do intradermal tests to really determine if there is an
allergic component to his symptoms I did ask Jarrod to get a RAST test to Northeastern
pollens as well as dust mites and animal danders. The results of the RAST tests are
pending at the time of this dictation.
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Page 2
Jarrod Johnson
March 16, 2005
2. Both his mother and grandmother seem most pleased with the use of Nasonex
and I asked them to continue this at one spray per nostril daily until I see: Jarrod again
which would be in two months. The family was invited to call sooner if there is any
change or worsening of symptoms.
,
,
Joan M. Montello, M.D.
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MEDICAL ARTS ALLERGY, P.C.
RE: Jarrod Johnson
BD: 3-21-01
Visit: 2-23-05
Joan M. Montello, M.D. . Donald S. Harper, M.D.
Jack L. Armstrong, M.D. . Jodi L. Johnson, GRN.P.
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AMERICAN BOARD OF ALLERGY. ASTHMA;!;Ni:r~NlS .' OLOG~{.~
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FREDRICKSEN OUTPATIENTC~j~~~'OGRES~'iiOOIiEOUTPATIENT BUILDING
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MECHANICSBURG.PA-1'.l050',:," _ ~RR\1iBUR~~.-
Phone: (717) 791o~Q..: ..., "- ...: ~4li\Ofto!lllilF) 920-434()'"
Fax: (717) 791-2646 ...,...".... -- Fax: (717) 920-4341
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MEDICAL ARTS BUILDING
220 WILSON STREET, SUITE 213
CARLISLE. PA 17013-3657
Phone: (717) 243-7540
Fax: (717) 243.9968
I had the pleasure of seeing Jarrod Johnson at the request of Dr. Denise Harr. He
is a 3 II/12th year old child who is "always stuffy" and "sounds like he has a cold".
i,
The mother and grandmother, who accompany Jarrod today, states that he has
been like this most of his life. In early infancy he had frequent episodes of otitis, but
never required PE tubes. Currently he seems to have frequent respiratory tract infections
during the winter months. Fortunately, he does not seem to require frequent courses of
antibiotics. He is here today primarily because of nasal congestion. The mother states he
does have noisy breathing if not snoring at bedtime. .
The family does not notice a seasonal pattern that may be significant for
pollenosis.
The child has no history of recurring infections such as sinusitis or bronchial
infections. The ear infections were primarily in the first year oflife.
The child denies a history of allergies to medications such as Penicillin, Sulfa.
There are no known food allergies, bee sting allergy, latex or other contactants such as
metals, etc.
CURRENT MEDICATIONS
1. Zyrtec 1 teaspoon once a day prn nasal congestion.
NEWBORN HISTORY
The child was the product of a full term normal pregnancy, labor and delivery.
Birth weight 6 pounds 7 ounces. The infant did have some hypoglycemia in the neonatal
period, but other than that everything was normal. The first year of life he did have
recurring otitis.
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Page 2
Jarrod Johnson
February 23, 2005
REVIEW OF OTHER MEDICAL PROBLEMS
Essentially unremarkable.
PAST MEDICAL IDSTORY
Non contributory for hospitalizations or surgeries.
FAMILYIDSTORY
A maternal grandfather has allergies but no other relatives are known to have
allergies or asthma.
ENVIRONMENTAL HISTORY
A complete environmental history was reviewed with the patient's family.
PHYSICAL EXAMINATION
HR: 90 and regular Resp: 20 and regular
100.5cm.
HEENT:
Temp: 98.80 WT: 16.2kg. HT:
E: Conjunctivae are pink. The lids are normal.
E: Tympanic membranes appear clear and mobile. External
auditory canals are normal.
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T: Oropharynx is normal including: teeth, gum, palate, tongue.
There is no exudate of the posterior pharynx.
NECK: Neck is supple, there is no thyromegaly or cervical lymphadenopathy.
LUNGS: Lungs are clear to auscultation, there are no retractions.
CARDIAC: Cardiac exam is normal without murmurs or extra sounds.
ABD: Abdomen is soft without hepatosplenomegaly. There are no abdominal
masses. There is no lymphadenopathy.
EXT: There is no digital clubbing, cyanosis or infection.
SKIN: The skin is clear of rashes and lesions.
PROCEDURES
The child was skin tested by the puncture technique to inhalants, animal danders,
mixed grasses, weeds (including ragweed), tree pollens, molds and foods. He had mildly
positive test to dust mites, but they did not match the histamine control as well as
fusarium, mucor and penicillium and one tree hackberry.
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Page 3
J arrod Johnson
February 23, 2005
IMPRESSION.
1. Perennial nasal congestion.
2. Mildly positive skin tests dust mites/mold (Did not match histamine control).
ro:COMMENDA TlONS
I started J arrod on N asonex 1 spray per nostril daily and our nurses instructed the
family on the proper use of the intranasal steroid spray. I would like him to stay on this
until I see him again and at that time do further intradermal tests. The family seems most
agreeable with further testing and they were invited to call at any time should there be
any. further problems.
Joan M. Montello, M.D.
JMM/ambM
c: Denise Harr, M.D., Good Hope Family Practice, 1830 Good Hope Road, Enola, P A 17025
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JOEL NICOLE BRYAN,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
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V.
KEITH DAVID JOHNSON
DEFENDANT
CIVIL TERM 01- (/,9.23
ORDER OF COURT
AND NOW, this
z:Cfl-
day of August, 2005, Joel Nicole Bryan is
adjudicated in civil contempt for violating the custody order of December 18,2001. She
may purge herself of contempt by complying with all provisions of the new custody order
Jessica Diamondstone, Esquire
For Joel Nicole Bryan
entered this date.
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Ruby Weeks, Esquire
For Keith David Johnson
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JOEL NICOLE BRYAN,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
KEITH DAVID JOHNSON
DEFENDANT
CIVIL TERM OI-(P9~
AND NOW, this
ORDER OF COURT
"2q~ day of August, 2005, following a hearing on
the merits, IT IS ORDERED:
(1) All prior custody orders are vacated and replaced with this order.
(2) Joel Nicole Bryan and Keith David Johnson shall have shared legal custody
of their son, Jarrod Johnson, born March 21, 2001.
(3) The mother shall have primary physical custody of Jarrod.
(4) The father shall have temporary physical custody of Jarrod:
(a) For as long as he is working on his current shift of 6:00 p.m. to 4 a.m.
Tuesday through Saturday, every other weekend from 7:00 p.m. on Friday until
7:00 p.m. on Monday.
(b) If his shift changes as anticipated to 4:00 p.m. to 2:00 a.m. Monday
through Friday, every other weekend from 7:00 p.m. Friday until 7:00 p.m.
Sunday.
(5) The parents shall share the Thanksgiving Day holiday with the mother having
Jarrod until 3:00 p.m., and the father having him from 3:00 p.m. until 8:00 p.m. or
through Friday at 6:00 p.m. if he does not work the next day, and through either Sunday
at 7:00 p.m. or Monday at 7:00 p.m. depending on his shift schedule, if it is his
scheduled weekend.
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(6) The father and mother shall alternate the Christmas holiday in two segments.
One parent shall have Jarrod from Christmas Eve at noon until Christmas Day at noon,
and the other parent shall have him from noon on Christmas Day until December 26th at
noon. The segments shall alternate.as per the schedule set in the prior custody order.
(7) The father may have Jarrod for a continuous two week period each summer,
Sunday to Sunday, and the mother may have him for a continuous two week period
each summer, Sunday to Sunday. Each parent shall give the other at least 30 days
notice if they intend to exercise these two week periods or any lesser slilch periods.
(8) The father shall arrange for all transfers. Transfers shall be at the mother's
home with the mother taking and bringing Jarrod to and from the vehicle used for the
/
Jessica Diamondstone, Esquire
For Joel Nicole Bryan
transfers.
Ruby Weeks, Esquire
For Keith David Johnson
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